# I NDIANA 

# D EPARTMENT OF 

# E NVIRONMENTAL 

# M ANAGEMENT We make Indiana a cleaner, healthier place to live.

Joseph E. Kernan 100 North Senate Avenue Governor P.O. Box 6015 June 15, 2004 Indianapolis, Indiana 46206-6015 Lori F. Kaplan (317) 232-8603 Commissioner (800) 451-6027 www.in.gov/idem

Page 1 of 2 FNTVOP.dot 9/16/03

Recycled Paper An Equal Opportunity Employer Please Recycle TO: Interested Parties / Applicant

RE: ESSROC Cement Corporation / 019-6016-00008

FROM: Paul Dubenetzky Chief, Permits Branch Office of Air Quality 

## Notice of Decision: Approval – Effective Immediately

Please be advised that on behalf of the Commissioner of the Department of Environmental Management, I have issued a decision regarding the enclosed matter. Pursuant to IC 13-15-5-3, this permit is effective immediately, unless a petition for stay of effectiveness is filed and granted, and may be revoked or modified in accordance with the provisions of IC 13-15-7-1.

If you wish to challenge this decision, IC 4-21.5-3-7 and IC 13-15-6-1(b) or IC 13-15-6-1(a) require that you file a petition for administrative review. This petition may include a request for stay of effectiveness and must be submitted to the Office of Environmental Adjudication, 100 North Senate Avenue, Government Center North, Room 1049, Indianapolis, IN 46204.

For an initial Title V Operating Permit , a petition for administrative review must be submitted to the Office of Environmental Adjudication within thirty (30) days from the receipt of this notice provided under IC 13-15-5-3, pursuant to IC 13-15-6-1(b). For a Title V Operating Permit renewal , a petition for administrative review must be submitted to the Office of Environmental Adjudication within fifteen (15) days from the receipt of this notice provided under IC 13-15-5-3, pursuant to IC 13-15-6-1(a).

The filing of a petition for administrative review is complete on the earliest of the following dates that apply to the filing: (1) the date the document is delivered to the Office of Environmental Adjudication (OEA); (2) the date of the postmark on the envelope containing the document, if the document is mailed to OEA by U.S. mail; or (3) The date on which the document is deposited with a private carrier, as shown by receipt issued by the carrier, if the document is sent to the OEA by private carrier.

The petition must include facts demonstrating that you are either the applicant, a person aggrieved or adversely affected by the decision or otherwise entitled to review by law. Please identify the permit, decision, or other order for which you seek review by permit number, name of the applicant, location, date of this notice and all of the following: (1) the name and address of the person making the request; (2) the interest of the person making the request; (3) identification of any persons represented by the person making the request; (4) the reasons, with particularity, for the request; (5) the issues, with particularity, proposed for considerations at any hearing; and(6) identification of the terms and conditions which, in the judgment of the person making the request, would be appropriate in the case in question to satisfy the requirements of the law governing documents of the type issued by the Commissioner.

Pursuant to 326 IAC 2-7-18(d), any person may petition the U.S. EPA to object to the issuance of an initial Title V operating permit, permit renewal, or modification within sixty (60) days of the end of the forty-five (45) day EPA review period. Such an objection must be based only on issues that were raised with reasonable specificity during the public comment period, unless the petitioner demonstrates that it was impractible to raise such issues, or if the grounds for such objection arose after the comment period.

To petition the U.S. EPA to object to the issuance of a Title V operating permit, contact:

U.S. Environmental Protection Agency 401 M Street Washington, D.C. 20406

If you have technical questions regarding the enclosed documents, please contact the Office of Air Quality, Permits Branch at (317) 233-0178. Callers from within Indiana may call toll-free at 1-800-451- 6027, ext. 3-0178.

Enclosures FNTVOP.dot 9/16/03

# PART 70 OPERATING PERMIT OFFICE OF AIR QUALITY

ESSROC Cement Corporation Highway 31 Speed, Indiana 47172

(herein known as the Permittee) is hereby authorized to operate subject to the conditions contained herein, the source described in Section A (Source Summary) of this permit.



### The Permittee must comply with all conditions of this permit. Noncompliance with any provisions of this permit is grounds for enforcement action; permit termination, revocation and reissuance, or modification; or denial of a permit renewal application. Noncompliance with any provision of this permit, except any provision specifically designated as not federally enforceable, constitutes a violation of the Clean Air Act. It shall not be a defense for the Permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this permit. An emergency does constitute an affirmative defense in an enforcement action provided the Permittee complies with the applicable requirements set forth in Section B, Emergency Provisions.

This permit is issued in accordance with 326 IAC 2 and 40 CFR Part 70 Appendix A and contains the conditions and provisions specified in 326 IA C 2-7 as required by 42 U.S.C. 7401, et. seq. (Clean Air Act as amended by the 1990 Clean Air Act Amendments), 40 CFR Part 70.6, IC 13-15 and IC 13-17.

Operation Permit No.: T019-6016-00008

Issued by: Original Signed by Janet McCabe Janet G. McCabe, Assistant Commissioner Office of Air Quality Issuance Date: June 15, 2004

Expiration Date: June 15, 2009ESSROC Cement Corporation Page 2 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore



### TABLE OF CONTENTS

A SOURCE SUMMARY 

### A.1 General Information [326 IAC 2-7-4(c) ] [326 IAC 2-7-5(15)] [326 IAC 2-7-1(22)] A.2 Part 70 Source Definition [326 IAC 2-7-1(22)] A.3 Emission Units and Pollution Control Equipment Summary [326 IAC 2-7-4(c)(3)] [326 IAC 2-7-5(15)] A.4 Specifically Regulated Insignificant Activi ties [326 IAC 2-7-1( 21)] [326 IAC 2-7-4(c)] [326 IAC 2-7-5(15)] A.5 Part 70 Permit Applicability [326 IAC 2-7-2]

B GENERAL CONDITIONS B.1 Definitions [326 IAC 2-7-1] B.2 Permit Term [326 IAC 2-7-5(2)] [326 IAC 2-1.1-9.5] B.3 Enforceability [326 IAC 2-7-7] B.4 Termination of Right to Operate [326 IAC 2-7-10] [326 IAC 2-7-4(a)] B.5 Severability [326 IAC 2-7-5(5)] B.6 Property Rights or Exclusive Privilege [326 IAC 2-7-5(6)(D)] B.7 Duty to Provide Information [326 IAC 2-7-5(6)(E)] B.8 Certification [326 IAC 2-7-4(f)] [326 IAC 2-7-6(1)] 

### [326 IAC 2-7-5(3)(C)] B.9 Annual Compliance Certification [326 IAC 2-7-6(5)] B.10 Preventive Maintenance Plan [326 IAC 2- 7-5(1),(3)and (13)][326 IAC 2-7-6(1)and(6)] [326 IAC 1-6-3] B.11 Emergency Provisions [326 IAC 2-7-16] B.12 Permit Shield [326 IAC 2-7-15] [326 IAC 2-7-20] [326 IAC 2-7-12] B.13 Prior Permits Superseded [326 IAC 2-1.1-9.5] B.14 Deviations from Permit Requirements and Conditions [326 IAC 2-7-5(3)(C)(ii)] B.15 Permit Modification, Reopening, Revocation and Reissuance, or Termination [326 IAC 2-7-5(6)(C)] [326 IA C 2-7-8(a)] [326 IAC 2-7-9] B.16 Permit Renewal [326 IAC 2-7-4] B.17 Permit Amendment or Modification [326 IAC 2-7-11][326 IAC 2-7-12] B.18 Permit Revision Under Economic Incentiv es and Other Programs [326 IAC 2-7-5(8)] [326 IAC 2-7-12 (b)(2)] B.19 Operational Flexibility [326 IAC 2-7-20] [326 IAC 2-7-10.5] B.20 Source Modification Requirement [326 IAC 2-7-10.5] B.21 Inspection and Entry [ 326 IAC 2-7-6] [IC 13-14-2-2][IC 13-30-3-1] [IC 13-30-3-2] B.22 Transfer of Ownership or Operational Control [326 IAC 2-7-11] B.23 Annual Fee Payment [326 IAC 2-7- 19] [326 IAC 2-7-5(7)][326 IAC 2-1.1-7] B.24 Credible Evidence [326 IAC 2- 7-5(3)][326 IAC 2-7-6][62 FR 8314]

C SOURCE OPERATION CONDITIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

Emission Limitations and Standards [326 IAC 2-7-5(1)] C.1 Opacity [326 IAC 5-1] C.2 Open Burning [326 IAC 4-1] [IC 13-17-9] C.3 Incineration [326 IAC 4-2] [326 IAC 9-1-2] C.4 Fugitive Dust Emissions [326 IAC 6-4] C.5 Operation of Equipment [326 IAC 2-7-6(6)] C.6 Stack Height [326 IAC 1-7] C.7 Asbestos Abatement Projects [326 IA C 14-10] [326 IAC 18] [40 CFR 61, Subpart M]

Testing Requirements [326 IAC 2-7-6(1)] C.8 Performance Testing [326 IAC 3-6]ESSROC Cement Corporation Page 3 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore



### Compliance Requirements [326 IAC 2-1.1-11] C.9 Compliance Requirements [326 IAC 2-1.1-11]

Compliance Monitoring Requirements [ 326 IAC 2-7-5(1)] [326 IAC 2-7-6(1)] C.10 Compliance Monitoring [326 IA C 2-7-5(3)] [326 IAC 2-7-6(1)] C.11 Maintenance of Continuous Opacity Moni toring Equipment[326 IAC 2-7-5(3)(A)(iii)] C.12 Maintenance of Continuous Emission Monito ring Equipment [326 IAC 2-7-5(3)(A)(iii)] C.13 Monitoring Methods [326 IAC 3][40 CFR 60][40 CFR 63] C.14 Pressure Gauge and Other Instrument Specifications [326 IAC 2-1.1-11] [326 IAC 2-7-5(3)][326 IAC 2-7-6(1)]

Corrective Actions and Response Steps [326 IAC 2-7-5] [326 IAC 2-7-6] C.15 Emergency Reduction Plans [ 326 IAC 1-5-2] [326 IAC 1-5-3] C.16 Risk Management Plan [326 IAC 2-7-5(12)] [40 CFR 68] C.17 Compliance Response Plan - Preparation, Implementation, Records, and Reports [326 IAC 2-7-5] [326 IAC 2-7-6] C.18 Actions Related to Noncompliance Dem onstrated by a Stack Test [326 IAC 2-7-5] [326 IAC 2-7-6]

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-19] C.19 Emission Statement [326 IAC 2-7-5(3)(C )(iii)] [326 IAC 2-7-5(7) ] [326 IAC 2-7-19(c)] [326 IAC 2-6] C.20 General Record Keeping Requirement s [326 IAC 2-7-5(3)] [326 IAC 2-7-6] C.21 General Reporting Requirements [326 IAC 2-7-5(3)(C)] [326 IAC 2-1.1-11] C.22 NESHAP Notification and Reporting Requirements [40 CFR 63, Subparts A and LLL]

Stratospheric Ozone Protection C.23 Compliance with 40 CFR 82 and 326 IAC 22-1

D.1 FACILITY OPERATION CONDITIONS - Quarry Activities, Stockpile Operations, Raw Material Sizing, and CKD Operations

Emission Limitations and Standards [326 IAC 2-7-5(1)] D.1.1 Particulate Matter (PM) [326 IAC 6-1-2] [326 IAC 2-2] D.1.2 Determinations of Nonapplicability [40 CFR 60, Subparts A, F, and OOO] [40 CFR 63, Subparts A and LLL] D.1.3 Preventive Maintenance Plan [326 IAC 2-7-5(13)]

Compliance Determination Requirements D.1.4 Particulate Matter (PM) D.1.5 Testing Requirements [326 IAC 2-7-6(1), (6)]

Compliance Monitoring Requirements [326 IAC 2-7-6(1)] [326 IAC 2-7-5(1)] D.1.6 Visible Emissions Notations D.1.7 Parametric Monitoring D.1.8 Baghouse Inspections D.1.9 Broken or Failed Bag Detection

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-19] D.1.10 Record Keeping Requirements D.1.11 Reporting RequirementsESSROC Cement Corporation Page 4 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore

D.2 FACILITY OPERATION CONDITIONS - Miscellaneous Facilities, Clay Processing Operations, Finish Operations Crane Storage Facilities, Fossil Fuel Storage and Handling Facilities, Clinker Hand ling Facilities, Clinker Handling to Crane Stor age Facilities, Finish Mill Facilities, and Silos

Emission Limitations and Standards [326 IAC 2-7-5(1)] D.2.1 Particulate Matter (PM) [326 IAC 6-1-2] [326 IAC 2-2] D.2.2 General Provisions Relating to NESHAP [326 IAC 20-1][40 CFR Part 63, Subpart A] D.2.3 NESHAP Emissions Limitations [40 CFR 63, Subpart LLL][326 IAC 20-27-1] D.2.4 Determinations of Nonapplicability [40 CFR Part 63, Subpart A] D.2.5 Prevention of Significant Deterioration [326 IAC 2-2] D.2.6 Preventive Maintenance Plan [326 IAC 2-7-5(13)]

Compliance Determination Requirements D.2.7 Testing Requirements [326 IAC 2-7-6(1),(6)] D.2.8 Particulate Matter (PM) D.2.9 NESHAP Monitoring Requirements [40 CFR 63, Subpart LLL][326 IAC 20-27-1]

Compliance Monitoring Requirements [326 IAC 2-7-6(1)] [326 IAC 2-7-5(1)] D.2.10 Visible Emissions Notations D.2.11 Baghouse Parametric Monitoring D.2.12 Baghouse Inspections D.2.13 Broken or Failed Bag Detection D.2.14 ESP Parametric Monitoring

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-19] D.2.15 Record Keeping Requirements D.2.16 Reporting Requirements

D.3 FACILITY OPERATION CONDITIONS - Raw Mill Facilities, Coal Handling, Milling, and Storage Faciliti es, Kilns and Clinker Coolers

Emission Limitations and Standards [326 IAC 2-7-5(1)] D.3.1 Particulate Matter [326 IAC 6-1-17] D.3.2 Particulate Matter [326 IAC 6-1-2] [326 IAC 2-2] [326 IAC 2-7-6(3)] [326 IAC 2-7-15] D.3.3 Sulfur Dioxide (SO 2 ) [326 IAC 7-1.1-1] D.3.4 General Provisions Relating to NESHAP [326 IAC 20-1][40 CFR Part 63, Subpart A] D.3.5 NESHAP Emission Limitations [40 CFR 63, Subpart LLL][326 IAC 20-27-1] D.3.6 Determinations of Nonapplicability [40 CFR 60, Subparts A and F] D.3.7 NOx Emissions [326 IAC 10-1] D.3.8 NSPS for Coal Preparation Plants [326 IAC 12] [40 CFR 60, Subpart Y] D.3.9 Preventive Maintenance Plan [326 IAC 2-7-5(13)]

Compliance Determination Requirements D.3.10 Testing Requirements [40 CFR 63, Subpart LLL][326 IAC 20-27-1] [326 IAC 2-7-6(1),(6)] [326 IAC 2-1-3(i)(8)]

D.3.11 Particulate Matter (PM) D.3.12 Sulfur Dioxide Emissions and Sulfur Content [326 IAC 2-7-5(A)] [326 IAC 2-7-6] D.3.13 Sulfur Dioxide Emissions and Sulfur Content [326 IAC 2-7-5(A)] [326 IAC 2-7-6]ESSROC Cement Corporation Page 5 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore

D.3.14 Continuous Emissions Monitoring [326 IAC 3-5] [40 CFR 63, Subpart LLL] [326 IAC 2-7-6(1),(6)] D.3.15 NESHAP Monitoring Requirements [40 CFR 63, Subpart LLL][326 IAC 20-27-1]

Compliance Monitoring Requirements [326 IAC 2-7-6(1)] [326 IAC 2-7-5(1)] D.3.16 ESP Parametric Monitoring D.3.17 Opacity Readings D.3.18 Visible Emissions Notations D.3.19 Baghouse Parametric Monitoring D.3.20 Baghouse Inspections D.3.21 Broken or Failed Bag Detection

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-19] D.3.22 Record Keeping Requirements D.3.23 Reporting Requirements



### D.4 FACILITY OPERATION CONDITIONS - Degreasing Operations

Emission Limitations and Standards [326 IAC 2-7-5(1)] D.4.1 Volatile Organic Compounds (VOC) [326 IAC 8-3-2] D.4.2 Volatile Organic Compounds (VOC) [326 IAC 8-3-5] D.4.3 

### Material Requirements for Cold Cleaning Degreasers [326 IAC 8-3-8 ] D.4.4 Determination of Nonapplicability [40 CFR 60.460 Subpart T] [40 CFR 60 Subparts A and F] [40 CFR 63 Subparts A and LLL]



### D.5 FACILITY OPERATION CONDITIONS - Insignifican t Activities Emission Limitations and Standards [326 IAC 2-7-5(1)] D.5.1 Nonattainment Area Particulate Matter Limitations (PM) [326 IAC 6-1-2]



### Certification Emergency Occurrence Report Quarterly Reports Quarterly Deviation and Compliance Monitoring ReportESSROC Cement Corporation Page 6 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore

SECTION A SOURCE SUMMARY

This permit is based on information requested by the Indiana Department of Environmental Management (IDEM), Office of Air Quality (OAQ). The information describing the source contained in conditions A.1 through A.4 and the description boxes in Sections D is descriptive information and does not constitute enforceable conditions. However, the Permittee should be aware that a physical change or a change in the method of operation that may render this descriptive information obsolete or inaccurate may trigger requirements for the Permittee to obtain additional permi ts or seek modification of this permit pursuant to 326 IAC 2, or change other applicable requirements presented in the permit application.

A.1 General Information [326 IAC 2-7-4(c)] [326 IAC 2-7-5(15)] [326 IAC 2-7-1(22)] The Permittee owns and operates a portland cement manufacturing plant.

Responsible Official: Plant Manager Source Address: Highway 31, Speed, Indiana 47172 Mailing Address: Highway 31, Speed, Indiana 47172-1305 General Source Phone Number: 812 246-5472 SIC Code: 3241 County Location: Clark Source Location Status: Nonattainment for ozone under the 8-hour standard, Attainment for all other criteria pollutants Source Status: Part 70 Permit Program Major Source, under PSD Rules 

### Major Source, Section 112 of the Clean Air Act 1 of 28 listed source categories



### A.2 Part 70 Source Definition [326 IAC 2-7-1(22)] This Portland cement manufacturing company consists of two (2) plants:

(a) ESSROC Cement Corporation, #00008 is located at Highway 31, Speed, IN 47172; and

(b) Hanson Aggregates Midwest Inc. - A ggrock Quarries, #05017 is located at 5501 Highway 403, Sellersburg, IN 47172.

IDEM has determined that ESSROC Cement Co rporation and Hanson Aggregates are not under the common control of ESSROC Cement Corporat ion; therefore they are considered separate sources for the purposes of Part 70 applicability.

A.3 Emission Units and Pollution Control Equipment Summary [326 IAC 2-7-4(c)(3)] [326 IAC 2-7-5(15)] This stationary source consists of the following emission units and pollution control devices:

Quarry activities

(1) Quarry drilling, identified as EU01, constructed in 1982, with particulate matter (PM) emissions controlled by one (1) baghouse, identified as the drilling rig baghouse 01 and exhausting to stack EP01. Note: the “baghouse” controlling thequarry drilling has no exhaust to the atmosphere. Dust is collected and then redeposited into the ground.

(2) Quarry blasting, identified as EU75, constructed prior to 1945, with associated fugitive particulate matter (PM) emissions.

(3) Raw material (limestone) loading to trucks, identified as EU76, constructed inESSROC Cement Corporation Page 7 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore

1948, with particulate matter emissions uncontrolled.

Raw material stockpile operations

(4) Raw material (clay overburden) unloadi ng to strippings stockpile, identified as EU78, constructed in 1948, with emissions uncontrolled.

(5) Strippings stockpile, identified as EU145, created before 1945.

(6) Truck unloading to additive hopper or additi ve storage pile (sand, iron, or Missouri clay), identified as EU99, constructed in 1948, with emissions uncontrolled.

(7) Silica/Alumina/Iron additive storage pile, identified as EU100, created before 1945.

(8) Additive clay blend pile, identified as EU101, created before 1945.

(9) Truck unloading to clay storage piles, identified as EU102, constructed in 1948, with emissions uncontrolled.

(10) uncovered clay storage pile, identified as EU103, created before 1945.

(11) covered clay storage pile, identified as EU104, created before 1945.

Raw Material Sizing Operations

(12) Raw material unloading to stone surge pile or primary crusher, identified as EU80, with emissions uncontrolled, commenced before 1956.

(13) Stone surge pile, identified as EU81, created before 1956.

(14) One (1) primary crusher, identified as EU82, constructed in 1956, with a nominal throughput of 700 tons per hour, with PM emissions uncontrolled.

(15) One (1) covered conveyor belt for transferring stone from primary crusher to screens, identified as EU83, constructed in 1956, with a nominal throughput of 700 tons per hour, with emissions uncontrolled.

(16) Screens, identified as EU84, with a nominal throughput of 700 tons per hour, constructed in 1956, with emissions uncontrolled.

(17) One (1) secondary crusher, identified as EU02, constructed in 1956, with a nominal throughput of 1050 tons per hour, with PM emissions controlled by one (1) baghouse, identified as baghouse 200, and exhausting to one (1) stack, identified as EP02.

(18) Covered conveyor for transferring stone from screens and secondary crusher to tertiary crusher or stone ladder bypass, identified as EU03, constructed in 1956, with a nominal throughput of 1050 tons per hour, with PM emissions controlled by one (1) baghouse, identified as baghouse 201, and exhausting to one (1) stack, identified as EP03.

(19) Two (2) tertiary crushers, identified as EU04 and EU04a, both constructed in 1956, each with a nominal throughput of 350 tons per hour, with PM emissionsESSROC Cement Corporation Page 8 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore

from both crushers controlled by one (1) baghouse, identified as baghouse 201, and exhausting to one (1) stack, identified as EP03.

(20) One (1) conveyor used to bypass tertiary crusher, referred to as the stone ladder bypass, identified as EU05, constructed in 1956, with emissions controlled by a baghouse, identified as baghouse 201, and exhausting to one (1) stack, identified as EP03.

(21) One (1) covered conveyor for transferring material from stone ladder and tertiary crusher to traveling belt, identified as EU85, constructed in 1956, with a nominal throughput of 700 tons per hour, with emissions uncontrolled, with emissions uncontrolled.

(22) One (1) traveling belt for transferring material from covered conveyor to North and South stone bins, identified as EU86, constructed in 1956, with a nominal throughput of 700 tons per hour, with emissions uncontrolled.

(23) North stone bin, identified as EU06, constructed in 1956, with emissions controlled by a baghouse, identified as baghouse 101, and exhausting to one (1) stack, identified as EP04.

(24) South stone bin, identified as EU07, constructed in 1956, with emissions controlled by one (1) baghouse, identified as baghouse 102, and exhausting to one (1) stack, identified as EP05.

(25) Stone conveyor transfer to truck, identified as EU87, constructed in 1956, with a nominal throughput of 700 tons per hour, with emissions uncontrolled.

(26) One (1) truck unloading station to crushed limestone storage pile, identified as EU89, constructed in 1956, with emissions uncontrolled.

(27) One (1) truck loading station from crushed limestone storage pile, identified as EU91, constructed in 1956, with emissions uncontrolled.

(28) One (1) truck unloading station to truck dump hopper, identified as EU93, constructed in 1956, with emissions uncontrolled.

(29) One (1) truck unloading station to emergency limestone storage pile or truck dump hopper, identified as EU94, constructed in 1956, with emissions uncontrolled.

(30) Crushed limestone storage piles, identified as EU90, created before 1957.

(31) Emergency limestone storage pile, identified as EU95, created during 1957.

(32) One (1) truck dump hopper, identified as EU96, constructed in 1977, with emission uncontrolled.

(33) One (1) limestone conveyor for transferring limestone from the truck dump hopper to the main limestone storage pile, identified as EU97, constructed in 1977, with a nominal throughput of 700 tons per hour, with emissions uncontrolled.

(34) Main limestone storage pile, identified as EU98, created during 1957.ESSROC Cement Corporation Page 9 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore

Kiln #1 Cement Kiln Dust (CKD) Operations

(35) One (1) dust tank system, identified as EU21, constructed in 1971 with a nominal throughput of 100 tons per hour, with emissions controlled by a baghouse, identified as baghouse 210, and exhausting to stack EP17.

(36) truck loading from the dust tank system, identified as EU113, with emissions uncontrolled, commenced during July 1971.

(37) CKD storage pile, identified as EU118, created before 1945.

(38) CKD sales loadout spout (kiln #1 dust tank), identified as EU155, constructed in 1996, with emissions controlled by a baghouse, with a nominal air flow rate of 2400 actual cubic feet per minute, identified as baghouse 266 (CE98) and exhausting to stack EP98.

Kiln #2 Cement Kiln Dust (CKD) Operations

(39) truck loading from the elevator dust tank, identified as EU115, with emissions uncontrolled, commenced during 1977.

(40) truck unloading to CKD storage pile, identified as EU117, with emissions uncontrolled, commenced during 1977.

Miscellaneous Facilities

(41) Plant Roads, identified as EU152.

(42) Vacuum system, identified as EU73, constructed in 1985, with emissions controlled by a baghouse with a nominal air flow rate of 400 actual cubic feet per minute, identified as baghouse 250, and exhausting to stack EP75.

(43) One (1) warehouse conveyor system for conveying bagged cement, identified as EU74, constructed in 1985, with emissions controlled by a baghouse with a nominal air flow rate of 1650 actual c ubic feet per minute, identified as baghouse 249, and exhausting to stack EP76.

Clay Processing Operations

(44) Clay hopper, identified as EU105, constructed prior to 1945.

(45) One (1) covered conveyor system for transferring material from storage piles and clay hopper to the clay crusher, identified as EU106, constructed before 1954, with a nominal throughput of 300 tons per hour, with emissions uncontrolled.

(46) One (1) clay crusher, identified as EU08, constructed in 1977, with a nominal throughput of 40 tons per hour, with emissions controlled by a baghouse, identified as baghouse 227, and exhausting to stack EP07.

Finish Operations Cr ane Storage Facilities

(47) Emergency BP stone storage pile, identified as EU128, created before 1945.ESSROC Cement Corporation Page 10 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore

(48) One (1) truck unloading station to Emergency BP stone storage pile or Crane storage pile, identified as EU127, with emissions uncontrolled, commenced before 1945.

(49) One (1) truck unloading station to gypsum storage piles, identified as EU129, with emissions uncontrolled, commenced before 1945.

(50) Crane storage building, including gypsum storage bin, stone storage bin, two (2) clinker storage bins, and stone, clinker, and gypsum storage piles, identified as EU131, constructed in 1935.

(51) gypsum storage piles, identified as EU130 and EU134, created before 1945.

Fossil Fuel Storage a nd Handling Facilities

(52) one (1) truck unloading station to the reserve coal storage pile, identified as EU136, constructed in June 1971, with emissions uncontrolled.

(53) One (1) reserve coal storage pile, identified as EU137, created in May 1971.

(54) one (1) coal storage pile, identified as EU142, constructed prior to 1945.

(55) One (1) coal draw-up covered conveying system for transferring material from the coal/alternate energy storage pile to the coal transfer tower, identified as EU63, constructed in June 1972, with a nominal throughput of 200 tons per hour, with emissions controlled by one (1) baghouse, identified as baghouse 206, and exhausting to stack EP77.

(56) Coal transfer tower, identified as EU64, constructed in June 1972, with a nominal throughput of 200 tons per hour, with emissions controlled by one (1) baghouse, identified as baghouse 207, and exhausting to stack EP78.

(57) One (1) coal bin, identified as EU65, constructed in June 1972, with emissions controlled by one (1) baghouse, identified as baghouse 208, and exhausting to stack EP79.

Kiln #1 Clinker Handling Facilities

(58) One (1) #1 clinker drag conveyor for transferring clinker from clinker cooler #1 to the apron conveyor, identified as EU23, constructed in May 1971, with a nominal throughput of 100 tons per hour, with emissions controlled by a baghouse, identified as baghouse 217, and exhausting to one (1) stack identified as EP19.

(59) apron conveyor for transferring clinker from the #1 clinker drag conveyor to either the clinker can #1 or the long belt, identified as EU24, constructed in May 1971, with a nominal throughput of 100 tons per hour, with emissions controlled by two baghouses, identified as baghouse 218, exhausting to one (1) stack identified as EP20 and baghouse 31382, exhausting to one (1) stack identified as EPN1.

(60) clinker can #1, which is a vertical bin with a lid used for storing off-spec clinker, identified as EU114, constructed in May 1971, with emissions controlled by two baghouses, identified as baghouse 218, exhausting to one (1) stack identified as EP20 and baghouseESSROC Cement Corporation Page 11 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore

31382, exhausting to one (1) stack identified as EPN1.

Kiln #2 Clinker Handling Facilities

(61) One (1) #2 clinker drag conveyor for transferring clinker from clinker cooler #2 to the aumond conveyor, identified as EU30, constructed in 1977, with a nominal throughput of 150 tons per hour, with emissions controlled by a baghouse, identified as baghouse 233, and exhausting to one (1) stack identified as EP25.

(62) One (1) aumond conveyor used for transferring clinker from the #2 clinker drag conveyor to the clinker can #2 or the cross belt, identified as EU31, constructed in 1977, with a nominal throughput of 150 tons per hour, with emissions controlled by two baghouses, identified as baghouse 234, exhausting to one (1) stack identified as EP26 and baghouse 31382, exhausting to one (1) stack identified as EPN1.

(63) One (1) cross belt for transferring clinker from the aumond conveyor to the long belt, identified as EU119, constructed in May 1971, with a nominal throughput of 150 tons per hour, with emissions controlled by a baghouse, identified as baghouse 235, and exhausting to one (1) stack identified as EP21.

(64) clinker can #2, which is a vertical bin with a lid used for storing off-spec clinker, identified as EU120, constructed in 1977, with emissions controlled by two baghouses, identified as baghouse 234, exhausting to one (1) stack identified as EP26 and baghouse 31382, exhausting to one (1) stack identified as EPN1.

Clinker Handling to Cr ane Storage Facilities

(65) One (1) long belt for transferring clinker from the apron conveyor and the cross belt to the North clinker transfer tower, identified as EU25, constructed in May 1971, with a nominal throughput of 200 tons per hour, with emissions controlled by a baghouse, identified as baghouse 219, and exhausting to one (1) stack identified as EP27.

(66) One (1) North clinker transfer tower for transferring clinker from the long belt to the covered incline belt (shuttle belt), identified as EU32, constructed in 1972, with a nominal throughput of 200 tons per hour, with emissions controlled by a baghouse, identified as baghouse 219, and exhausting to one (1) stack identified as EP27.

(67) One (1) covered incline belt (Shuttle belt) used for transferring clinker from the North clinker transfer tower to the North clinker storage building, identified as EU33, constructed in 1972, with a nominal throughput of 200 tons per hour, with emissions controlled by a baghouse, identified as baghouse 220, and exhausting to one (1) stack identified as EP28.

(68) One (1) clinker storage pile, identified as EU121, created before 1960.

(69) North clinker storage pile, identified as EU122, created in May 1971.

(70) North clinker storage building, identified as EU123, constructed in 1960.

(71) One (1) North reclaim clinker covered conveyor system used to transfer clinker from the North clinker storage building to either, 1) the South reclaim clinker covered conveyor system (EU124) or, 2) the 2D finish mill clinker bin transferESSROC Cement Corporation Page 12 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore

(EU44) transfer tower (covered conveyor), identified as EU34, constructed in 1962, with a nominal throughput of 200 tons per hour, with emissions controlled by a baghouse, identified as baghouse 245, and exhausting to one (1) stack identified as EP29.

(72) One (1) South reclaim clinker covered conveyor used to transfer clinker from the North reclaim clinker covered conveyor system to the crane storage building, identified as EU124, constructed in May 1971, with a nominal throughput of 200 tons per hour, with emissions controlled by two baghouses, identified as baghouse 202, exhausting to one (1) stack identified as EP39 and baghouse 31499, exhausting to one (1) stack identified as EPN2.

(73) Truck loading station, used for loading material from the North clinker storage pile, identified as EU125, constructed in May 1971, with emissions uncontrolled.

(74) Truck unloading station, used for loadi ng material to the crane storage building, identified as EU126, constructed in May 1971, with emissions uncontrolled.

2ABC Finish Mill Facilities

(75) One (1) CKD/Lime tank, identified as EU146, constructed in 1964, with emissions controlled by a baghouse, identified as baghouse 143, and exhausting to one (1) stack identified as EP84.

(76) one (1) gypsum/stone transfer circuit ABC mills, including material transfers and scales, identified as EU35, constructed in 1964, with a nominal throughput of 300 tons per hour, with emissions controlled by two (2) baghouses, identified as baghouses 131 and 132, and exhausting to two (2) stacks identified as EP30 and EP31.

(77) one (1) clinker transfer circuit ABC mills, including conveyor transfers and clinker scales, identified as EU36, constructed in 1964, with a nominal throughput of 200 tons per hour, with emissions controlled by two baghouses, identified as baghouse 31495, exhausting to one (1) stack identified as EPN3, and baghouse 31496, exhausting to one (1) stack, identified as EPN4.

(78) two (2) clinker elevators, identified as EU37, constructed in 1969, with a nominal throughput of 200 tons per hour, with emissions controlled by a baghouse, identified as baghouse 134, and exhausting to one (1) stack identified as EP34.

(79) One (1) 2BC finish mill feed belt, identified as EU132, constructed in 1977, with a nominal throughput of 200 tons per hour, with emissions uncontrolled.

(80) 2A hopper / preliminary ball mill used to grind clinker and gypsum, identified as EU38, constructed in 1948, with a nominal throughput of 24 tons per hour, with emissions controlled by a baghouse, identified as baghouse 133, and exhausting to one (1) stack identified as EP33.

(81) one (1) finish mill circuit 2A, which includes three (3) elevators, finish mill, separator, and air transport system, collectively identified as EU39, constructed in 1948, with a nominal throughput of 24 tons per hour, with emissions controlled by a baghouse, identified as baghouse 134, and exhausting to one (1) stack identified as EP34.

(82) one (1) finish mill circuit 2B, which includes the feed hopper, feed belt, finish mill,ESSROC Cement Corporation Page 13 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore

elevator, and air transport system, collectiv ely identified as EU40, constructed in 1953, with a nominal throughput of 25 tons per hour, with emissions controlled by a baghouse, identified as baghouse 135, and exhausting to one (1) stack identified as EP35.

(83) one (1) finish mill circuit 2C, which includes the feed hopper, feed belt, finish mill, and elevator, collectively identified as EU 42, constructed in 1960, with a nominal throughput of 36 tons per hour, with emissions controlled by a baghouse, identified as baghouse 137, and exhausting to one (1) stack identified as EP37.

(84) One (1) separator and cement cooler, used in conjunction with the finish mill circuit 2C, identified as EU43, constructed in 1960 and 1964 respectively, with a nominal throughput of 36 tons per hour, with emissions controlled by a baghouse, identified as baghouse 137, and exhausting to one (1) stack identified as EP37.

(85) One (1) separator and cement cooler, used in conjunction with the finish mill circuit 2B, identified as EU41, constructed in 1953 and 1955 respectively, with a nominal throughput of 25 tons per hour, with emissions controlled by a baghouse, identified as baghouse 135, and exhausting to one (1) stack identified as EP35.

(86) One (1) BP tank for storing finished product (cement), identified as EU48, constructed in 1965, with a nominal throughput of 700 tons per hour, with emissions controlled by a baghouse, identified as baghouse 144, and exhausting to one (1) stack identified as EP81.

(87) One (1) pump used to transfer finished product (cement) from the BP tank to silos, identified as EU49, constructed in 1966, with a nominal throughput of 50 tons per hour, with emissions controlled by a baghouse, identified as baghouse 146, and exhausting to one (1) stack identified as EP82.

2D Finish Mill Facilities

(88) one (1) gypsum elevator used to transfer material from the gypsum storage piles to the clinker draw-up system D mill, identified as EU135, constructed in 1964, with a nominal throughput of 45 tons per hour, with emissions controlled by a baghouse, identified as baghouse 120, and exhausting to one (1) stack identified as EP40.

(89) one (1) 2D finish mill clinker bin, which includes the elevator, conveyor belts, and air transport system, identified as EU44, constructed in 1964, with a nominal throughput of 300 tons per hour, with emissions controlled by one (1) baghouses

, identified as baghouses 120, and exhausting to stack identified as EP40.

(90) one (1) 2D finish mill clinker / gypsum feed circuit which includes scales and feed belts, identified as EU45, constructed in 1964, with a nominal throughput of 140 tons per hour, with emissions controlled by three (3) baghouses, identified as baghouse 262, exhausting to one (1) stack identified as EP94, baghouse 31497 exhausting to one (1) stack identified as EPN5, and baghouse 31498 exhausting to one (1) stack identified as EPN6.

(91) one (1) 2D finish mill roll press circuit, which includes a roller press (crusher), identified as EU46, constructed in 1999, with a nominal throughput of 140 tons per hour, with emissions controlled by three (3) baghouses, identified as baghouses 261, 262, and 263, and exhausting to three (3) stacks identified asESSROC Cement Corporation Page 14 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore

EP93, EP94, and EP95.

(92) one (1) 2D finish mill circuit, which includes conveyor transfer, elevator, finish mill, elevator, classifier, and three (3) cement coolers, identified as EU47, constructed in 1964, with a nominal throughput of 140 tons per hour, with emissions controlled by a baghouse, identified as baghouse 139, and exhausting to one (1) stack identified as EP41.

Finish Product 501-Silos Storage and Packing Facilities

(93) 501-Silos 30-44, identified as EU54, constructed in 1965, with emissions controlled by five (5) baghouses, identified as baghouses 224, 225, 246, 150, and 151, and exhausting to five (5) stacks identified as EP63 through EP67.

(94) one (1) BIC mixer for mixing lime and pigment with the clinker, identified as EU55, constructed in 1973, with a nominal throughput of 45 tons per hour, with emissions controlled by a baghouse, identified as baghouse 226, and exhausting to one (1) stack identified as EP68.

(95) one (1) BIC packer for loading cement into bags, identified as EU56, constructed in 1973, with a nominal throughput of 45 tons per hour, with emissions controlled by a baghouse, identified as baghouse 226, and exhausting to one (1) stack identified as EP68.

Finish Product 506-Silos Storage, P acking, and Bulk Loading Facilities

(96) 506-Silos 56-73, identified as EU53, constructed in 1958, with emissions controlled by fourteen (14) baghouses, identified as baghouses 159 through 172, and exhausting to fourteen (14) stacks identified as EP49 through EP62.

(97) Two (2) bulk loading stations for railroad cars and trucks, identified as EU57 and EU58, constructed in 1954, each with a nominal throughput of 200 tons per hour, with emissions controlled by baghouses 176 and 177 respectively, and exhausting to stacks EP69 and EP70 respectively.

(98) One (1) packer #1 for loading cement into bags, identified as EU59, constructed in 1960, with a nominal throughput of 45 tons per hour, with emissions controlled by a baghouse, identified as baghouse 173, and exhausting to one (1) stack identified as EP71.

(99) One (1) packer #2 for loading cement into bags, identified as EU60, constructed in 1960, with a nominal throughput of 45 tons per hour, with emissions controlled by a baghouse, identified as baghouse 174, and exhausting to one (1) stack identified as EP72.

(100) One (1) packer #3 for loading cement into bags, identified as EU61, constructed in 1960, with a nominal throughput of 45 tons per hour, with emissions controlled by a baghouse, identified as baghouse 175, and exhausting to one (1) stack identified as EP73.

(101) one (1) bag compression station, identified as EU62, constructed in 1960, with a nominal throughput of 45 tons per hour, with emissions controlled by a baghouse, identified as baghouse 242, and exhausting to one (1) stack identified as EP74.ESSROC Cement Corporation Page 15 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore

Finish Product 504-Silos Storag e and Bulk Loading Facilities

(102) 504-Silos 45-48, and 50-55, identified as EU51, constructed in 1959, with emissions controlled by four (4) baghouses, identified as baghouses 153 through 156, and exhausting to four (4) stacks identified as EP44 through EP47.

(103) One (1) bulk loading station for trucks and railroad cars, identified as EU52, constructed in 1959, with a nominal throughput of 200 tons per hour, with emissions controlled by baghouse 152, and exhausting to stack EP48.

(104) 504 Silos Bank/Silo 49 (CKD sales), identified as EU153, constructed in 1959, with emissions controlled by a baghouse, identified as baghouse 264 and exhausting to stack EP96.

(105) CKD sales loadout spout, identified as EU154, constructed in 1999, with emissions controlled by a baghouse, identified as baghouse 265 and exhausting to stack EP97.

Finish Product 502-Silos Storag e and Bulk Loading Facilities

(106) 502-Silos 1, 2, and 7-11, identified as EU50, constructed in 1966, with emissions controlled by two (2) baghouses, identified as baghouses 148 and 149 respectively, and exhausting to two (2) stacks identified as EP42 and EP43.

Raw Mill Facilities

(107) Two (2) pneumatic truck unloading stati ons to additive bins, identified as EU107 and EU108, constructed in July 1976, with emissions controlled by one (1) baghouse, identified as baghouse 228, and exhausting to stack EP09.

(108) One (1) clay hopper, identified as EU109, constructed in July 1976, with emissions uncontrolled.

(109) Three (3) additive bins for flyash, bottom ash, or iron, identified as EU10, EU11, and EU12 respectively, equipped with two (2) elevators, constructed in 1977, with emissions controlled by one (1) baghouse, identified as baghouse 228 and exhausting to stack EP09. One of the elevators was replaced in 1994.

(110) One (1) C-15 covered conveyor system for transferring material from the clay breaker, additive bin 2, and the main limestone storage pile to the triple gate, identified as EU09, constructed in 1977, with a nominal throughput of 300 tons per hour, with emissions controlled by two (2) baghouses, identified as baghouses 227 and 229, and exhausting to stacks EP07 and EP08 respectively.

(111) One (1) Loesche raw mill, identified as EU14, constructed in 1977, with a nominal throughput of 300 tons per hour, with emissions controlled by one (1) electrostatic precipitator, identified as ESP15, and exhausting to stack S-15.

(112) one (1) sidewinder (pneumatic transfer pump) used for pumping the kiln feed from silos to triple gate, identified as EU15, constructed in 1977, with a nominal throughput of 300 tons per hour, with emissions controlled by one (1) baghouse, identified as baghouse 247 and exhausting to stack EP-11.

(113) One (1) raw material pile, identified as EU112.ESSROC Cement Corporation Page 16 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore

(114) one (1) oil-fired furnace, referred to as the Todd Furnace, used for Loesche mill heating, identified as EU13, constructed in 1977, with a nominal heat input capacity of 55 million British thermal units per hour, with emissions controlled byone (1) electrostatic precipitator, identified as ESP15, and exhausting to stack S15.

(115) blend silo #1 for blending kiln feed, identified as EU16, constructed in May 1971, with emissions controlled by one (1) baghouse, identified as baghouse 211, and exhausting to stack EP12

(116) blend silo #2 for blending kiln feed, identified as EU17, constructed in 1977, with emissions controlled by one (1) baghouse, identified as baghouse 230, and exhausting to stack EP13

(117) one (1) calibration system, identified as EU18, constructed in May 1971, with emissions controlled by one (1) baghouse, identified as baghouse 212, and exhausting to stack EP14.

Coal handling, milling and storage facilities

(118) Coal (crusher) mill #1, identified as EU66 servicing kiln #1, constructed in May 1971, with a nominal throughput of 12.5 tons per hour, with emissions routed to kiln #1 and controlled by baghouse 221 and exhausting to one (1) stack, identified as (EP16) S-14. Note: For the purposes of NSPS Subpart Y applicability, this is also a thermal dryer.

(119) Coal (crusher) mill #2, identified as EU67 servicing kiln #2, constructed in 1977, with a nominal throughput of 14 tons per hour, with emissions controlled by one (1) baghouse, identified as baghouse 252, and exhausting to stack EP88. Note: For the purposes of NSPS Subpart Y applicability, this is also a thermal dryer.

(120) one (1) fuel oil-fired air heater for kiln #1 coal mill, identified as EU68, constructed in May 1971, with a nominal heat input capacity of 5.3 million British thermal units per hour, with emissions exhausting directly to the kiln #1 coal mill then routed to kiln #1 and controlled by one (1) baghouse, identified as baghouse 221 and exhausting to stack S-14.

(121) one (1) fuel oil-fired air heater for kiln #2 coal mill, identified as EU69, constructed in 1977, with a nominal heat input capacity of 5.3 million British thermal units per hour, with emissions exhausting directly to the kiln #2 coal mill controlled by one (1) baghouse and two (2) electrostatic precipitators (ESPs), identified as baghouse 252, ESP15, and ESP16 (alkali bypass system), respectively, and exhausting to stacks EP88, S-15, and S-16 respectively.

(122) Kiln #2 coal dust silo, identified as EU149, constructed in 1996, with emissions controlled by one baghouse with a nominal air flow rate of 200 actual cubic feet per minute, identified as baghouse 253 and exhausting to one (1) stack identified as EP101.

(123) Kiln #2 coal weigh system, identified as EU150, constructed in 1996, with a nominal throughput of 20 tons per hour, with emissions controlled by one filter, identified as filter 254 and exhausting to a vent.

(124) Kiln #2 coal handling system, identified as EU151, constructed in 1996, with a nominal throughput of 20 tons per hour, with emissions controlled by one filter,ESSROC Cement Corporation Page 17 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore

identified as filter 255 and exhausting to a vent.

The kiln #1 and kiln #2 facilities

(125) One (1) feed system for kiln #1, identified as EU19, constructed in May 1971, with a nominal throughput of 105 tons per hour, with PM emissions from the alleviator controlled by one (1) baghouse, identified as baghouse 209 and exhausting to stack EP15 and with PM emissions from the scales and pump controlled by one (1) baghouse, identified as baghouse 212 and exhausting to stack EP12.

(126) One (1) long dry process rotary cement kiln #1, identified as EU20, constructed in May 1971, with a nominal heat input capacity of 184 million Btu per hour, with a nominal production rate of 60 tons per hour (as clinker), with PM emissions controlled by one (1) baghouse, identified as baghouse 221, and exhausting to one (1) stack, identified as S-14.

(127) One (1) feed system for kiln #2, identified as EU26, constructed in 1977, with a nominal throughput of 175 tons per hour, with PM emissions controlled by one (1) baghouse, identified as baghouse 231, and exhausting to stack EP80.

(128) One (1) dry process rotary cement kiln #2 and associated preheater unit, equipped with an alkali bypass, identified as EU27, constructed in 1977, with a nominal heat input capacity of 302 million Btu per hour, with a nominal production rate of 105 tons per hour (as clinker), with PM emissions controlled by two (2) electrostatic precipitators, identified as ESP15 and ESP16 (alkali bypass system), and exhausting to stacks, identified as S-15 and S-16 respectively.

(129) One (1) Elevator/dust tank (alkali bypass) for kiln #2, identified as EU28, constructed in 1977, with emissions controlled by a baghouse, identified as baghouse 232, and exhausting to stack EP23.

The clinker cooler #1 facilities

(130) One (1) grate clinker cooler #1, identified as EU22, constructed in May 1971, with a nominal throughput rate of 60 tons per hour, with PM emissions controlled by one (1) baghouse, identified as baghouse 222, and exhausting to one (1) stack, identified as S-13.

The clinker cooler #2 facilities

(131) One (1) grate clinker cooler #2, identified as EU29, constructed in 1977, with a nominal throughput of 105 tons per hour, with PM emissions controlled by one (1) baghouse, identified as baghouse 17, and exhausting to one (1) stack, identified as S-17.

A.4 Specifically Regulated Insignificant Activi ties [326 IAC 2-7-1(21)] [326 IAC 2-7-4(c)] [326 IAC 2-7-5(15)] This stationary source also includes the following insignificant activities which are specifically regulated, as defined in 326 IAC 2-7-1(21):

(1) degreasing operations. [326 IAC 8-3-2] [326 IAC 8-3-5] [326 IAC 8-3-8]

(2) underground conveyors; [326 IAC 6-1-2]

(3) coal bunker and coal scale exhausts and associated dust collector vents; [326 IAC 6-1-2]ESSROC Cement Corporation Page 18 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore

This stationary source also includes other insigni ficant activities as defined at 326 IAC 2-7-1(21) identified in the Technical Support Document for this permit that are not specifically regulated hereunder.

A.5 Part 70 Permit Applicability [326 IAC 2-7-2] This stationary source is required to have a Part 70 permit by 326 IAC 2-7-2 (Applicability) because:

(1) It is a major source, as defined in 326 IAC 2-7-1(22); and

(2) It is a source in a source category designated by the United States Environmental Protection Agency (U.S. EPA) under 40 CFR 70.3 (Part 70 - Applicability).ESSROC Cement Corporation Page 19 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore

SECTION B GENERAL CONDITIONS



### B.1 Definitions [326 IAC 2-7-1] Terms in this permit shall have the definition assigned to such terms in the referenced regulation. In the absence of definitions in the referenced regulation, the applicable definitions found in the statutes or regulations (IC 13- 11, 326 IAC 1-2 and 326 IAC 2-7) shall prevail.

B.2 Permit Term [326 IAC 2-7-5(2)] [326 IAC 2-1.1-9.5] This permit is issued for a fixed term of five (5) years from the issuance date of this permit, as determined in accordance with IC 4-21.5-3-5( f) and IC 13-15-5-3. Subsequent revisions, modifications, or amendments of this permit do not affect the expiration date.

B.3 Enforceability [326 IAC 2-7-7] Unless otherwise stated, all terms and conditions in this permit, including any provisions designed to limit the source's potential to em it, are enforceable by IDEM, the United States Environmental Protection Agency (U.S. EPA) and by citizens in accordance with the Clean Air Act.

B.4 Termination of Right to Operate [326 IAC 2-7-10] [326 IAC 2-7-4(a)] The Permittee's right to operate this source term inates with the expiration of this permit unless a timely and complete renewal application is submitted at least nine (9) months prior to the date of expiration of the source’s existing permit, c onsistent with 326 IAC 2- 7-3 and 326 IAC 2-7-4(a).

B.5 Severability [326 IAC 2-7-5(5)] The provisions of this permit are severable; a determination that any portion of this permit is invalid shall not affect the validity of the remainder of the permit.

B.6 Property Rights or Exclusive Privilege [326 IAC 2-7-5(6)(D)] This permit does not convey any property right s of any sort or any exclusive privilege.

B.7 Duty to Provide Information [326 IAC 2-7-5(6)(E)] (a) The Permittee shall furnish to IDEM, OAQ, within a reasonable time, any information that IDEM, OAQ, may request in writing to determine whether cause exists for modifying, revoking and reissuing, or terminating this permit, or to determine compliance with this permit. The submittal by the Permittee does require the certification by the “responsible official” as defined by 326 IAC 2-7-1(34). Upon request, the Permittee shall also furnish to IDEM, OAQ, copies of records required to be kept by this permit.

(b) For information furnished by the Permittee to IDEM, OAQ, the Permittee may include a claim of confidentiality in accordance with 326 IAC 17.1. When furnishing copies of requested records directly to U. S. EPA, the Permittee may assert a claim of confidentiality in accordance with 40 CFR 2, Subpart B.

B.8 Certification [326 IAC 2-7-4(f)] [ 326 IAC 2-7-6(1)] [326 IAC 2-7-5(3)(C)] (a) Where specifically designated by this per mit or required by an applicable requirement, any application form, report, or compliance certification submitted shall contain certification by a responsible official of truth, accuracy, and completeness. This certification shall state that, based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate, and complete.

(b) One (1) certification shall be included, using the attached Certification Form, with each submittal requiring certification.

(c) A responsible official is defined at 326 IAC 2-7-1(34).ESSROC Cement Corporation Page 20 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore


### B.9 Annual Compliance Certification [326 IAC 2-7-6(5)] (a) The Permittee shall annually submit a comp liance certification report which addresses the status of the source’s compliance wit h the terms and conditions contained in this permit, including emission limitations, standards, or work practices. The initial certification shall cover the time period fr om the date of final permit issuance through December 31 of the same year. All subsequent certifications shall cover the time period from January 1 to December 31 of the prev ious year, and shall be submitted in letter form no later than April 15 of each year to:

Indiana Department of Environmental Management Compliance Data Section, Office of Air Quality 100 North Senate Avenue, P. O. Box 6015 Indianapolis, Indiana 46206-6015

and

United States Environmental Protection Agency, Region V Air and Radiation Division, Air Enforcement Branch - Indiana (AE-17J) 77 West Jackson Boulevard Chicago, Illinois 60604-3590

(b) The annual compliance certification report r equired by this permit shall be considered timely if the date postmarked on the envelope or certified mail receipt, or affixed by the shipper on the private shipping receipt, is on or before the date it is due. If the document is submitted by any other means, it shall be considered timely if received by IDEM, OAQ, on or before the date it is due.

(c) The annual compliance certification report shall include the following:

(1) The identification of each term or condition of this permit that is the basis of the certification;

(2) The compliance status;

(3) Whether compliance was continuous or intermittent;

(4) The methods used for determining the compliance status of the source, currently and over the reporting period consistent with 326 IAC 2-7-5(3); and

(5) Such other facts, as specified in Sect ions D of this permit, as IDEM, OAQ may require to determine the compliance status of the source.

The submittal by the Permittee does require the certification by the “responsible official” as defined by 326 IAC 2-7-1(34).

B.10 Preventive Maintenance Plan [326 IAC 2-7-5( 1),(3) and (13)] [326 IAC 2-7-6(1) and (6)] [326 IAC 1-6-3] (a) If required by specific condi tion(s) in Section D of this permit, the Permittee shall prepare and maintain Preventive Maintenance Plans (PMPs) within ninety (90) days after issuance of this permit, including the following information on each facility:

(1) Identification of the individual(s) responsible for inspecting, maintaining, and repairing emission control devices;ESSROC Cement Corporation Page 21 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore


### (2) A description of the items or conditi ons that will be inspected and the inspection schedule for said items or conditions; and

(3) Identification and quantification of the replacement parts that will be maintained in inventory for quick replacement.

If, due to circumstances beyond the Permittee’s control, the PMPs cannot be prepared and maintained within the above time frame, the Permittee may extend the date an additional ninety (90) days provided the Permittee notifies:

Indiana Department of Environmental Management Compliance Branch, Office of Air Quality 100 North Senate Avenue, P. O. Box 6015 Indianapolis, Indiana 46206-6015

The PMP extension notification does not requi re the certification by the “responsible official” as defined by 326 IAC 2-7-1(34).

(b) The Permittee shall implement the PMPs, including any required record keeping, as necessary to ensure that failure to implem ent a PMP does not cause or contribute to an exceedance of any limitation on emissions or potential to emit.

(c) A copy of the PMPs shall be submitted to IDEM, OAQ, upon request and within a reasonable time, and shall be subject to review and approval by IDEM, OAQ. IDEM, OAQ may require the Permittee to revise its PMPs whenever lack of proper maintenance causes or is t he primary contributor to an exceedance of any limitation on emissions or potential to emit. The PMP does not require the certification by the “responsible official” as defined by 326 IAC 2-7-1(34).

(d) To the extent the Permittee is required by 40 CFR Part 63 to have an Operations and Maintenance (O&M) Plan for a unit, such plan is deemed to satisfy the PMP requirements of 326 IAC 1-6-3 for that unit.

B.11 Emergency Provisions [326 IAC 2-7-16] (a) An emergency, as defined in 326 IAC 2-7- 1(12), is not an affirmative defense for an action brought for noncompliance with a f ederal or state health-based emission limitation, except as other wise provided in 326 IAC 2-7-16.

(b) An emergency, as defined in 326 IAC 2-7-1( 12), constitutes an affirmative defense to an action brought for noncompliance with a tec hnology-based emission limitation if the affirmative defense of an emergency is demonstrated through properly signed, contemporaneous operating logs or other rele vant evidence that describe the following:

(1) An emergency occurred and the Permittee can, to the extent possible, identify the causes of the emergency;

(2) The permitted facility was at the time being properly operated;

(3) During the period of an emergency, the Permittee took all reasonable steps to minimize levels of emissions that exceeded the emission standards or other requirements in this permit;

(4) For each emergency lasting one (1) hour or more, the Permittee notified the IDEM Southwest Regional Office within f our (4) daytime business hours after theESSROC Cement Corporation Page 22 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore


### beginning of the emergency, or after the emergency was discovered or reasonably should have been discovered;

IDEM Southwest Regional Office Telephone Number: 812-436-2570 Facsimile Number: 812-436-2572

(5) For each emergency lasting one (1) hour or more, the Permittee submitted the attached Emergency Occurrence Report Form or its equivalent, either by mail or facsimile to:

IDEM Southwest Regional Office 208 Northwest 4 th 

### Street Suite 201 Evansville, Indiana 47708

within two (2) working days of the time when emission limitations were exceeded due to the emergency.

The notice fulfills the requirement of 326 IAC 2-7-5(3)(C)(ii) and must contain the following:

(A) A description of the emergency;

(B) Any steps taken to mitigate the emissions; and

(C) Corrective actions taken.

The notification which shall be submitted by the Permittee does not require the certification by the “responsible offi cial” as defined by 326 IAC 2-7-1(34).

(6) The Permittee immediately took all reasonable steps to correct the emergency.

(c) In any enforcement proceeding, the Permitt ee seeking to establish the occurrence of an emergency has the burden of proof.

(d) This emergency provision supersedes 326 IAC 1-6 (Malfunctions). This permit condition is in addition to any emergency or upset provision contained in any applicable requirement.

(e) IDEM, OAQ, and the IDEM Southwest Regional Office may require that the Preventive Maintenance Plans required under 326 IAC 2-7- 4-(c)(9) be revised in response to an emergency.

(f) Failure to notify the IDEM Southwest Regional Office by telephone or facsimile of an emergency lasting more than one (1) hour in accordance with (b)(4) and (5) of this condition shall constitute a violation of 326 IAC 2-7 and any other applicable rules.

(g) If the emergency situation causes a dev iation from a technology-based limit, the Permittee may continue to operate the affected emitting facilities during the emergency provided the Permittee immediately takes all reasonable steps to correct the emergency and minimize emissions.

(h) The Permittee shall include all emergencies in the Quarterly Deviation and ComplianceESSROC Cement Corporation Page 23 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore


### Monitoring Report.

B.12 Permit Shield [326 IAC 2-7-15] [326 IAC 2-7-20] [326 IAC 2-7-12] (a) Pursuant to 326 IAC 2-7-15, the Permitt ee has been granted a permit shield. The permit shield provides that compliance with the conditions of this permit shall be deemed in compliance with any applicable requirements as of the date of permit issuance, provided that either the applicable requirements are included and specifically identified in this permit or the permit contains an explicit determination or concise summary of a determination that other specifically ident ified requirements are not applicable. The Indiana statutes from IC 13 and rules from 326 IAC, referenced in conditions in this permit, are those applicable at the time the permit was issued. The issuance or possession of this permit shall not al one constitute a defense against an alleged violation of any law, regulation or standard, except for the requirement to obtain a Part 70 permit under 326 IAC 2-7 or for applicable r equirements for which a permit shield has been granted.

This permit shield does not extend to app licable requirements which are promulgated after the date of issuance of this permit unl ess this permit has been modified to reflect such new requirements.

(b) In addition to the nonapplicability determinations set forth in Sections D of this permit, the IDEM, OAQ has made the following det erminations regarding this source:

(1) Construction Permit CP019-3340-00008, issued on September 5, 1997, which allowed the source to burn waste tires as a fuel in their kilns, has been voluntarily withdrawn by the source. T he source is no longer permitted to burn waste tires.

(2) All previous permits issued to this source listed 326 IAC 6-3-2 (Process Operations) or 326 IAC 6-2 (Particulate Limitations for Sources of Indirect Heating) as being applicable requirement s. None of these conditions are applicable because IDEM, OAQ has deter mined that 326 IAC 6-1 is applicable to all particulate emitting facilities at this source.

(c) If, after issuance of this permit, it is determined that the permit is in nonconformance with an applicable requirement that applied to the source on the date of permit issuance, IDEM, OAQ, shall immediately take steps to reopen and revise this permit and issue a compliance order to the Permittee to ens ure expeditious compliance with the applicable requirement until the permit is reissued. T he permit shield shall continue in effect so long as the Permittee is in compliance with the compliance order.

(d) No permit shield shall apply to any permit term or condition that is determined after issuance of this permit to have been based on erroneous information supplied in the permit application. Erroneous information means information that the Permittee knew to be false, or in the exercise of reasonabl e care should have been known to be false, at the time the information was submitted.

(e) Nothing in 326 IAC 2-7-15 or in this per mit shall alter or affect the following:

(1) The provisions of Section 303 of the Clean Air Act (emergency orders), including the authority of the U.S. EPA under Section 303 of the Clean Air Act;

(2) The liability of the Permittee for any violation of applicable requirements prior toESSROC Cement Corporation Page 24 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore


### or at the time of this permit's issuance;

(3) The applicable requirements of the acid rain program, consistent with Section 408(a) of the Clean Air Act; and

(4) The ability of U.S. EPA to obtain information from the Permittee under Section 114 of the Clean Air Act.

(f) This permit shield is not applicable to any change made under 326 IAC 2-7-20(b)(2) (Sections 502(b)(10) of the Clean Air Ac t changes) and 326 IAC 2-7-20(c)(2) (trading based on State Implementation Plan (SIP) provisions).

(g) This permit shield is not applicable to modifications eligible for group processing until after IDEM, OAQ, has issued the modifications. [326 IAC 2-7-12(c)(7)]

(h) This permit shield is not applicable to minor Part 70 permit modifications until after IDEM, OAQ, has issued the modification. [326 IAC 2-7-12(b)(8)]

B.13 Prior Permits Superseded [326 IAC 2-1.1-9.5] (a) All terms and conditions of previous per mits issued pursuant to permitting programs approved into the state implementation plan have been either

(1) incorporated as originally stated,

(2) revised, or

(3) deleted

by this permit.

(b) All previous registrations and permits are superseded by this permit.

B.14 Deviations from Permit Requirements and Conditions [326 IAC 2-7-5(3)(C)] (a) Deviations from any permit requirement s (for emergencies see Section B - Emergency Provisions), the probable cause of su ch deviations, and any response steps or preventive measures taken shall be reported to:

Indiana Department of Environmental Management Compliance Data Section, Office of Air Quality 100 North Senate Av enue, P.O. Box 6015 Indianapolis, Indiana 46206-6015

using the attached Quarterly Deviation and Compliance Monitoring Report, or its equivalent. A deviation required to be r eported pursuant to an applicable requirement that exists independent of this permit, shall be reported according to the schedule stated in the applicable requirement and does not need to be included in this report.

The Quarterly Deviation and Compliance Monitoring Report does require the certification by the “responsible official” as defined by 326 IAC 2-7-1(34).

(b) A deviation is an exceedance of a permit limitation or a failure to comply with a requirement of the permit.ESSROC Cement Corporation Page 25 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore


### B.15 Permit Modification, Reopening, Revocation and Reissuance, or Termination [326 IAC 2-7-5(6)(C)] [326 IAC 2-7-8(a)] [326 IAC 2-7-9] (a) This permit may be modified, reopened, revoked and reissued, or terminated for cause. The filing of a request by the Permittee for a Part 70 permit modification, revocation and reissuance, or termination, or of a notification of planned changes or anticipated noncompliance does not stay any condition of this permit. [326 IAC 2-7-5(6)(C)] The notification by the Permittee does require the certification by the “responsible official” as defined by 326 IAC 2-7-1(34).

(b) This permit shall be reopened and revised under any of the circumstances listed in IC 13-15-7-2 or if IDEM, OAQ, determines any of the following:

(1) That this permit contains a material mistake.

(2) That inaccurate statements were made in establishing the emissions standards or other terms or conditions.

(3) That this permit must be revised or revoked to assure compliance with an applicable requirement. [326 IAC 2-7-9(a)(3)]

(c) Proceedings by IDEM, OAQ, to reopen and revise this permit shall follow the same procedures as apply to initial permit issuanc e and shall affect only those parts of this permit for which cause to reopen exists. Such reopening and revision shall be made as expeditiously as practic able. [326 IAC 2-7-9(b)]

(d) The reopening and revision of this permit, under 326 IAC 2-7-9(a), shall not be initiated before notice of such intent is provided to the Permittee by IDEM, OAQ, at least thirty (30) days in advance of the date this permi t is to be reopened, except that IDEM, OAQ, may provide a shorter time period in the case of an emergency. [326 IAC 2-7-9(c)]

B.16 Permit Renewal [326 IAC 2-7-4] (a) The application for renewal shall be submi tted using the application form or forms prescribed by IDEM, OAQ, and shall include the information specified in 326 IAC 2-7-4. Such information shall be included in the application for each emission unit at this source, except those emission units included on t he trivial or insignificant activities list contained in 326 IAC 2-7-1(21) and 326 IAC 2-7-1(40). The renewal application does require the certification by the “responsible official” as defined by 326 IAC 2-7-1(34).

Request for renewal shall be submitted to:

Indiana Department of Environmental Management Permits Branch, Office of Air Quality 100 North Senate Av enue, P.O. Box 6015 Indianapolis, Indiana 46206-6015

(b) Timely Submittal of Permit Renewal [326 IAC 2-7-4(a)(1)(D)]

(1) A timely renewal application is one that is:

(A) Submitted at least nine (9) months prior to the date of the expiration of this permit; and

(B) If the date postmarked on the envelope or certified mail receipt, or affixed by the shipper on the private shipping receipt, is on or before theESSROC Cement Corporation Page 26 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore



### date it is due. If the document is s ubmitted by any other means, it shall be considered timely if received by IDEM, OAQ, on or before the date it is due.

(2) If IDEM, OAQ, upon receiving a timely and complete permit application, fails to issue or deny the permit renewal prior to the expiration date of this permit, this existing permit shall not expire and all terms and conditions shall continue in effect, including any permit shield provided in 326 IAC 2-7-15, until the renewal permit has been issued or denied.

(c) Right to Operate After Application for Renewal [326 IAC 2-7-3] If the Permittee submits a timely and complete application for renewal of this permit, the source’s failure to have a permit is not a violation of 326 IAC 2-7 until IDEM, OAQ takes final action on the renewal application, except that this protection shall cease to apply if, subsequent to the completeness determination, the Permittee fails to submit by the deadline specified in writing by IDEM, OAQ, any additional information identified as being needed to process the application.

(d) United States Environmental Protection A gency Authority [326 IAC 2-7-8(e)] If IDEM, OAQ, fails to act in a timely way on a Part 70 permit renewal, the U.S. EPA may invoke its authority under Section 505(e) of the Clean Air Act to terminate or revoke and reissue a Part 70 permit.

B.17 Permit Amendment or Modification [326 IAC 2-7-11] [326 IAC 2-7-12] (a) Permit amendments and modifications are governed by the requirements of 326 IAC 2- 7-11 or 326 IAC 2-7-12 whenever the Permitt ee seeks to amend or modify this permit.

(b) Any application requesting an amendment or modification of this permit shall be submitted to:

Indiana Department of Environmental Management Permits Branch, Office of Air Quality 100 North Senate Av enue, P.O. Box 6015 Indianapolis, Indiana 46206-6015

Any such application shall be certified by the “responsible official” as defined by 326 IAC 2-7-1(34).

(c) The Permittee may implement administrative amendment changes addressed in the request for an administrative amendment immediately upon submittal of the request. [326 IAC 2-7-11(c)(3)]

(d) No permit amendment or modification is required for the addition, operation or removal of a nonroad engine, as defined in 40 CFR 89.2.

B.18 Permit Revision Under Economic Incentiv es and Other Programs [326 IAC 2-7-5(8)] [326 IAC 2-7-12 (b)(2)] (a) No Part 70 permit revision shall be requi red under any approved economic incentives, marketable Part 70 permits, emissions trading, and other similar programs or processes for changes that are provided for in a Part 70 permit.

(b) Notwithstanding 326 IAC 2-7-12(b)(1)(D)(i) and 326 IAC 2-7-12(c)(1), minor Part 70 permit modification procedures may be used for Part 70 modifications involving the use of economic incentives, marketable Part 70 permits, emissions trading, and other similarESSROC Cement Corporation Page 27 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore


### approaches to the extent that such minor Part 70 permit modification procedures are explicitly provided for in the applicable State Implementation Plan (SIP) or in applicable requirements promulgated or approved by the U.S. EPA.

B.19 Operational Flexibility [326 IAC 2-7-20] [326 IAC 2-7-10.5] (a) The Permittee may make any change or changes at the source that are described in 326 IAC 2-7-20(b), (c), or (e), without a prio r permit revision, if each of the following conditions is met:

(1) The changes are not modifications under any provision of Title I of the Clean Air Act;

(2) Any preconstruction approval requi red by 326 IAC 2-7-10.5 has been obtained;

(3) The changes do not result in emissions which exceed the emissions allowable under this permit (whether expressed herein as a rate of emissions or in terms of total emissions);

(4) The Permittee notifies the:

Indiana Department of Environmental Management Permits Branch, Office of Air Quality 100 North Senate Avenue, P. O. Box 6015 Indianapolis, Indiana 46206-6015

and

United States Environmental Protection Agency, Region V Air and Radiation Division, Regulation Development Branch - Indiana (AR-18J) 77 West Jackson Boulevard Chicago, Illinois 60604-3590

in advance of the change by written notific ation at least ten (10) days in advance of the proposed change. The Permittee shall attach every such notice to the Permittee's copy of this permit; and

(5) The Permittee maintains records on-site which document, on a rolling five (5) year basis, all such changes and emissions trading that are subject to 326 IAC 2-7-20(b), (c), or (e) and makes such records available, upon reasonable request, for public review.

Such records shall consist of all information required to be submitted to IDEM, OAQ, in the notices specified in 326 IAC 2-7-20(b)(1), (c)(1), and (e)(2).

(b) The Permittee may make Section 502(b)(10) of the Clean Air Act changes (this term is defined at 326 IAC 2-7-1(36)) without a permit re vision, subject to the constraint of 326 IAC 2-7-20(a). For each such Section 502( b)(10) of the Clean Air Act change, the required written notification shall include the following:

(1) A brief description of the change within the source;

(2) The date on which the change will occur;

(3) Any change in emissions; andESSROC Cement Corporation Page 28 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore



### (4) Any permit term or condition that is no longer applicable as a result of the change.

The notification which shall be submitted is not considered an application form, report or compliance certification. Therefore, the notification by the Permittee does not require the certification by the “responsible o fficial” as defined by 326 IAC 2-7-1(34).

(c) Emission Trades [326 IAC 2-7-20(c)] The Permittee may trade increases and decreases in emissions in the source, where the applicable SIP provides for such emission trades without requiring a permit revision, subject to the constraints of Section (a) of this condition and those in 326 IAC 2-7-20(c).

(d) Alternative Operating Scenarios [326 IAC 2-7-20(d)] The Permittee may make changes at the sour ce within the range of alternative operating scenarios that are described in the terms and conditions of this permit in accordance with 326 IAC 2-7-5(9). No prior notificati on of IDEM, OAQ, or U.S. EPA is required.

B.20 Source Modification Requirement [326 IAC 2-7-10.5] A modification, construction, or reconstructi on is governed by the requirements of 326 IAC 2 and 326 IAC 2-7-10.5.

B.21 Inspection and Entry [326 IAC 2-7-6] [IC 13-14-2-2] [IC 13-17-3-2] [IC 13-30-3-1] Upon presentation of proper identification ca rds, credentials, and other documents as may be required by law, and subject to the Permittee’ s right under all applicable laws and regulations to assert that the information collected by the agency is confidential and entitled to be treated as such, the Permittee shall a llow IDEM, OAQ, U.S. EPA, or an authorized repr esentative to perform the following:

(a) Enter upon the Permittee's premises w here a Part 70 source is located, or emissions related activity is conducted, or where records must be kept under the conditions of this permit;

(b) As authorized by the Clean Air Act, IC 13-14-2-2, IC 13-17-3-2, and IC 13-30-3-1, have access to and copy any records that must be kept under the conditions of this permit;

(c) As authorized by the Clean Air Act, IC 13-14-2-2, IC 13-17-3-2, and IC 13-30-3-1, inspect any facilities, equipment (including monitoring and air pollution control equipment), practices, or operations regulated or required under this permit;

(d) As authorized by the Clean Air Act, IC 13-14-2-2, IC 13-17-3-2, and IC 13-30-3-1, sample or monitor substances or parameters for the purpose of assuring compliance with this permit or applicable requirements; and

(e) As authorized by the Clean Air Act, IC 13-14-2-2, IC 13-17-3-2, and IC 13-30-3-1, utilize any photographic, recording, testing, monitoring, or other equipment for the purpose of assuring compliance with this permit or applicable requirements.



### B.22 Transfer of Ownership or Operational Control [326 IAC 2-7-11] (a) The Permittee must comply with the requirements of 326 IAC 2-7-11 whenever the Permittee seeks to change the ownership or operational control of the source and no other change in the permit is necessary.

(b) Any application requesting a change in the ownership or operational control of theESSROC Cement Corporation Page 29 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore


### source shall contain a written agreement cont aining a specific date for transfer of permit responsibility, coverage and liability between the current and new Permittee. The application shall be submitted to:

Indiana Department of Environmental Management Permits Branch, Office of Air Quality 100 North Senate Av enue, P.O. Box 6015 Indianapolis, Indiana 46206-6015

The application which shall be submitted by t he Permittee does require the certification by the "responsible official" as defined by 326 IAC 2-7-1(34).

(c) The Permittee may implement administrative amendment changes addressed in the request for an administrative amendment immediately upon submittal of the request. [326 IAC 2-7-11(c)(3)]

B.23 Annual Fee Payment [326 IAC 2-7-19] [326 IAC 2-7-5(7)] [326 IAC 2-1.1-7] (a) The Permittee shall pay annual fees to IDEM, OAQ within thirty (30) calendar days of receipt of a billing. Pursuant to 326 IAC 2-7-19(b), if the Permittee does not receive a bill from IDEM, OAQ the applicable fee is due April 1 of each year.

(b) Except as provided in 326 IAC 2-7-19(e), failure to pay may result in administrative enforcement action or revocation of this permit.

(c) The Permittee may call the following telephone numbers: 1-800-451-6027 or 317-233- 4230 (ask for OAQ, I/M & Billing Section), to determine the appropriate permit fee.

B.24 Credible Evidence [326 IAC 2- 7-5(3)][326 IAC 2-7-6][62 FR 8314] Notwithstanding the conditions of this permit t hat state specific methods that may be used to demonstrate compliance with, or a violation of , applicable requirements, any person (including the Permittee) may also use other credible evidence to demonstrate compliance with, or a violation of, any term or condition of this permit.ESSROC Cement Corporation Page 30 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore



### SECTION C SOURCE OPERATION CONDITIONS

Entire Source

Emission Limitations and Standards [326 IAC 2-7-5(1)]

C.1 Opacity [326 IAC 5-1] Pursuant to 326 IAC 5-1-2 (Opacity Limitations ), except as provided in 326 IAC 5-1-3 (Temporary Alternative Opacity Limitations), opac ity shall meet the following, unless otherwise stated in this permit:

(a) Opacity shall not exceed an average of forty percent (40%) in any one (1) six (6) minute averaging period as determined in 326 IAC 5-1-4.

(b) Opacity shall not exceed sixty percent (60%) for more than a cumulative total of fifteen (15) minutes (sixty (60) readings as measured according to 40 CFR 60, Appendix A, Method 9 or fifteen (15) one (1) minute nonoverlapping integrated averages for a continuous opacity monitor) in a six (6) hour period.

C.2 Open Burning [326 IAC 4-1] [IC 13-17-9] The Permittee shall not open burn any material ex cept as provided in 326 IAC 4-1-3, 326 IAC 4- 1-4 or 326 IAC 4-1-6. The previous sentenc e notwithstanding, the Permittee may open burn in accordance with an open burning approval issued by the Commissioner under 326 IAC 4-1-4.1. 326 IAC 4-1-3 (a)(2)(A) and (B) are not federally enforceable.

C.3 Incineration [326 IAC 4-2] [326 IAC 9-1-2] The Permittee shall not operate an incinerator or incinerate any waste or refuse except as provided in 326 IAC 4-2 and 326 IAC 9-1-2. 326 IAC 9-1-2 is not federally enforceable.

C.4 Fugitive Dust Emissions [326 IAC 6-4] (a) The Permittee shall not allow fugitive dust to escape beyond the property line or boundaries of the property, right-of-way, or eas ement on which the source is located, in a manner that would violate 326 IAC 6-4 (Fugitive Dust Emissions). 326 IAC 6-4-2(4) is not federally enforceable.

(b) In order to comply with 326 IAC 6-4, the Permittee shall comply with the fugitive dust control plan, which includes the following requirements:

(1) Vehicular traffic shall follow established roadways (paved and unpaved) and observe the POSTED speed limit of 15 mph (excluding the quarry).

(2) Individuals responsible for loading, unloading, and/or transfer of materials will be trained in Best Management Practices (BMPs) which will minimize or eliminate fugitive emissions and include instruction on:

(A) Filling the transportation contai ners properly by not overfilling;

(B) Loading trucks so that no part of the load comes within 6 inches of the top of any sideboard, side panel, or tail gate;

(C) Filling the loader bucket properly by not overfilling;

(D) Minimize free fall heights; and,ESSROC Cement Corporation Page 31 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore


### (E) Taking all reasonable precautionary measures to reduce or eliminate the generation of fugitive dust.

(3) Feeders for unloading & transfer operations will be connected directly to bins, hoppers and tanks.

(4) Leaks in potential sources of fugitive emissions will be repaired in a timely

manner.

(5) Paved roads and parking lots in the plant will be swept on a daily basis (Monday-Friday), weather permitting. The sweeper will not be operated during rainy days.

(6) Unpaved roads will be watered, as needed. Due to safety concerns, road watering will not be conducted when the temperature is below 35oF or when the temperature is expected to fall below freezing while the roads are wet.

(7) The C-4 belt water spray dust suppression system will replaced by May 31, 2004. This system will be operated on a continuous basis while the material handling equipment is in operation, exc ept during freezing conditions which could cause material handling problems (a t temperatures below 35o or when the temperatures are expected to be below freezing while the material is wet).

(8) Stock/Storage Piles The areas around the Stock/Storage Piles are to be maintained in such a manner as to minimize the potential for fugitive particulate matter emissions. (A) The area around the Piles is to be swept or watered as necessary. (B) Restrict traffic flow in and around the storage areas.

(9) Clinker Storage Building Dust Control Plan The openings in the roof and sides of the building will be sealed, and all belts will be covered. This phase of the clinker building dust control plan will be completed by May 31, 2004.

By July 31, 2004, Essroc will submit to IDEM a report including a description of the actions taken with respect to the Clinker Storage Building and an evaluation of the effectiveness of those actions.

C.5 Operation of Equipment [326 IAC 2-7-6(6)] Except as otherwise provided by statute or rule , or in this permit, all air pollution control equipment listed in this permit and used to co mply with an applicable requirement shall be operated at all times that the emission units vented to the control equipment are in operation.

C.6 Stack Height [326 IAC 1-7] The Permittee shall comply with the applicabl e provisions of 326 IAC 1-7 (Stack Height Provisions), for all exhaust stacks through which a potential (before controls) of twenty-five (25) tons per year or more of particulate matter or su lfur dioxide is emitted. The provisions of 326 IAC 1-7-2, 326 IAC 1-7-3(c) and (d), 326 IAC 1-7- 4(a)(3), (e), and (f), and 326 IAC 1-7-5(d) are not federally enforceable.

C.7 Asbestos Abatement Projects [326 IAC 14-10] [326 IAC 18] [40 CFR 61.140] The Permittee shall comply with the applicable requirements of 326 IAC 14-10, 326 IAC 18, and 40 CFR 61.140 when conducting any asbestos abatem ent project covered by those rules.ESSROC Cement Corporation Page 32 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore


### Testing Requirements [326 IAC 2-7-6(1)]

C.8 Performance Testing [326 IAC 3-6] (a) All testing shall be performed according to the provisions of 326 IAC 3-6 (Source Sampling Procedures), except as provi ded elsewhere in this permit, utilizing any applicable procedures and analysis methods specified in 40 CFR 51, 40 CFR 60, 40 CFR 61, 40 CFR 63, 40 CFR 75, or other procedures approved by IDEM, OAQ.

A test protocol, except as provided elsew here in this permit, shall be submitted to:

Indiana Department of Environmental Management Compliance Data Section, Office of Air Quality 100 North Senate Avenue, P. O. Box 6015 Indianapolis, Indiana 46206-6015

no later than thirty-five (35) days prior to the intended test date. The protocol submitted by the Permittee does not require certificati on by the "responsible official" as defined by 326 IAC 2-7-1(34).

(b) The Permittee shall notify IDEM, OAQ of the actual test date at least fourteen (14) days prior to the actual test date. The notification submitted by the Permittee does not require certification by the "responsible offi cial" as defined by 326 IAC 2-7-1(34).

(c) Pursuant to 326 IAC 3-6-4(b), all test reports must be received by IDEM, OAQ not later than forty-five (45) days after the completion of the testing. An extension may be granted by IDEM, OAQ, if the source submits to IDEM, OAQ, a reasonable written explanation not later than five (5) days prior to the end of the initial forty-five (45) day period.

Compliance Requirements [326 IAC 2-1.1-11]

C.9 Compliance Requirements [326 IAC 2-1.1-11] The commissioner may require stack testing, monitoring, or reporting at any time to assure compliance with all applicable requirements by issuing an order under 326 IAC 2-1.1-11. Any monitoring or testing shall be performed in accordance with 326 IAC 3 or other methods approved by the commissioner or the U. S. EPA. The Permittee shall have the right to seek administrative or judicial review of an order to test.

Compliance Monitoring Requirements [ 326 IAC 2-7-5(1)] [326 IAC 2-7-6(1)]

C.10 Compliance Monitoring [326 IA C 2-7-5(3)] [326 IAC 2-7-6(1)] Unless otherwise specified in this permit, all monitoring and record keeping requirements not already legally required shall be implemented wit hin ninety (90) days of permit issuance. If required by Section D, the Permittee shall be responsible for installing any necessary equipment and initiating any required monitoring related to that equipment. If due to circumstances beyond its control, that equipment cannot be installed and operated within ninety (90) days, the Permittee may extend the compliance schedule related to the equipment for an additional ninety (90) days provided the Permittee notifies:

Indiana Department of Environmental Management Compliance Branch, Office of Air Quality 100 North Senate Avenue, P. O. Box 6015 Indianapolis, Indiana 46206-6015ESSROC Cement Corporation Page 33 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore


### in writing, prior to the end of the initial ninety (90) day compliance schedule, with full justification of the reasons for the inability to meet this date.

The notification which shall be submitted by the Permittee does require the certification by the “responsible official” as defined by 326 IAC 2-7-1(34).

Unless otherwise specified in the approval for the new emission unit(s), compliance monitoring for new emission units or emission units added through a source modification shall be implemented when operation begins.

C.11 Maintenance of Continuous Opacity Monito ring Equipment [326 IAC 2-7-5(3)(A)(iii)] (a) The Permittee shall install, calibrate, maintain, and operate all necessary continuous opacity monitoring systems (COMS) and related equipment.

(b) All continuous opacity monitoring systems s hall meet the performance specifications of 40 CFR 60, Appendix B, Performance Specific ation No. 1, and are subject to monitor system certification requirements pursuant to 326 IAC 3-5.

(c) In the event that a breakdown of a continuous opacity monitoring system occurs, a record shall be made of the time and reason of the breakdown and efforts made to correct the problem.

C.12 Maintenance of Continuous Emission Monito ring Equipment [326 IAC 2-7-5(3)(A)(iii)] (a) The Permittee shall install, calibrate, maintain, and operate all necessary continuous emission monitoring systems (CEMS) and related equipment.

(b) All continuous emission monitoring systems shall meet all applicable performance specifications of 40 CFR 60 or any other performance specificati on, and are subject to monitor system certification requirements pursuant to 326 IAC 3-5-3.

(c) In the event that a breakdown of a continuous emission monitoring system occurs, a record shall be made of the times and reasons of the breakdown and efforts made to correct the problem.

(d) Whenever a continuous emission monitor other than an opacity monitor is malfunctioning or is down for maintenance or repairs, the following shall be used as an alternative to continuous data collection:

(1) If the CEM is required for monitoring NO X 

### or SO 2 

### emissions pursuant to 40 CFR 75 (Title IV Acid Rain program) or 326 IAC 10-4 (NO X 

### Budget Trading Program), the Permittee shall comply with the relevant requirements of 40 CFR 75 Subpart D - Missing Data Substitution Procedures.

(2) If the CEM is not used to monitor NO X 

### or SO 2 

### emissions pursuant to 40 CFR 75 or 326 IAC 10-4, then supplemental or intermittent monitoring of the parameter shall be implemented as specified in Section D of this permit until such time as the emission monitor system is back in operation.

(e) Nothing in this permit shall excuse the Permittee from complying with the requirements to operate a continuous emission monitoring system pursuant to 326 IAC 10-1 and/or 326 IAC 10-3.ESSROC Cement Corporation Page 34 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore


### C.13 Monitoring Methods [326 IAC 3] [40 CFR 60] [40 CFR 63] Any monitoring or testing required by Section D of this permit shall be performed according to the provisions of 326 IAC 3, 40 CFR 60, Appendix A, 40 CFR 60 Appendix B, 40 CFR 63, or other approved methods as s pecified in this permit.

C.14 Pressure Gauge and Other Instrument Specific ations [326 IAC 2-1.1-11] [326 IAC 2-7-5(3)] [326 IAC 2-7-6(1)] (a) Whenever a condition in this permit require s the measurement of pressure drop across any part of the unit or its control device, the gauge employed shall have a scale such that the expected normal reading shall be no less than twenty percent (20%) of full scale and be accurate within plus or minus two percent ( ±2%) of full scale reading.

(b) Whenever a condition in this permit requires the measurement of a temperature, or T-R set voltage or current, the instrument employed shall have a scale such that the expected normal reading shall be no less than twenty percent (20%) of full scale and be accurate within plus or minus two percent ( ±2%) of full scale reading.

(c) The Permittee may request the IDEM, OAQ approve the use of a pressure gauge or other instrument that does not meet the above specifications provided the Permittee can demonstrate an alternative pressure gauge or other instrument specification will adequately ensure compliance with permit c onditions requiring the measurement of pressure drop or other parameters.

Corrective Actions and Response Step s [326 IAC 2-7-5] [326 IAC 2-7-6]

C.15 Emergency Reduction Plans [ 326 IAC 1-5-2] [326 IAC 1-5-3] Pursuant to 326 IAC 1-5-2 (Emer gency Reduction Plans; Submission):

(a) The Permittee shall prepare written emergenc y reduction plans (ERP s) consistent with safe operating procedures.

(b) These ERPs shall be submitted for approval to:

Indiana Department of Environmental Management Compliance Branch, Office of Air Quality 100 North Senate Av enue, P.O. Box 6015 Indianapolis, Indiana 46206-6015

within ninety (90) days after the date of issuance of this permit.

The ERP does require the certification by the “responsible official” as defined by 326 IAC 2-7-1(34).

(c) If the ERP is disapproved by IDEM, OAQ, the Permittee shall have an additional thirty (30) days to resolve the differences and submit an approvable ERP.

(d) These ERPs shall state those actions that will be taken, when each episode level is declared, to reduce or eliminate emi ssions of the appropriate air pollutants.

(e) Said ERPs shall also identify the sources of air pollutants, the approximate amount of reduction of the pollutants, and a brief descr iption of the manner in which the reduction will be achieved.

(f) Upon direct notification by IDEM, OAQ, that a specific air pollution episode level is inESSROC Cement Corporation Page 35 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore


### effect, the Permittee shall immediately put into effect the actions stipulated in the approved ERP for the appropriate episode level. [326 IAC 1-5-3]

C.16 Risk Management Plan [326 IAC 2-7-5(12)] [40 CFR 68.215] If a regulated substance, as defined in 40 CFR 68, is present at a source in more than a threshold quantity, the Permittee must comply with the applicable requirements of 40 CFR 68.

C.17 Compliance Response Plan - Preparation, Implementation, Records, and Reports [326 IAC 2-7- 5] [326 IAC 2-7-6] (a) The Permittee is required to prepare a Compliance Response Plan (CRP) for each compliance monitoring condition of this permit. If the Permittee is required to have an Operations and Maintenance (O&M) Plan under 40 CFR 63, such plan shall be deemed to satisfy the requirements for a CRP for those compliance monitoring conditions. A CRP shall be submitted to IDEM, OAQ upon request. The CRP shall be prepared within ninety (90) days after issuance of this permit by the Permittee, maintained on site, and comprised of:

(1) Reasonable response steps that may be implemented in the event that a response step is needed pursuant to the requirements of Section D of this permit; and an expected time frame fo r taking reasonable response steps.

(2) If, at any time, the Permittee takes reasonable response steps that are not set forth in the Permittee’s current Compliance Response Plan or O&M Plan and the Permittee documents such response in accordance with subsection (e) below, the Permittee shall amend its Compliance Response Plan or O&M Plan to include such response steps taken.

The O&M Plan shall be submitted within the ti me frames specified by the applicable 40 CFR 63 requirement.

(b) For each compliance monitoring conditi on of this permit, reasonable response steps shall be taken when indicated by the provisions of that compliance monitoring condition as follows:

(1) Reasonable response steps shall be taken as set forth in the Permittee’s current Compliance Response Plan or O&M Plan; or

(2) If none of the reasonable response st eps listed in the Compliance Response Plan or O&M Plan is applicable or responsive to the excursion, the Permittee shall devise and implement additional response steps as expeditiously as practical. Taking such additional re sponse steps shall not be considered a deviation from this permit so long as the Permittee documents such response steps in accordance with this condition.

(3) If the Permittee determines that additional response steps would necessitate that the emissions unit or control device be shut down, and it will be 10 days or more until the unit or device will be shut down, then the Permittee shall promptly notify the IDEM, OAQ of the expected date of the shut down, the status of the applicable compliance monitoring paramet er with respect to normal, and the results of the actions taken up to the time of notification.

(4) Failure to take response steps sha ll be considered a deviation from the permit.

(c) The Permittee is not required to take any further response steps for any of the followingESSROC Cement Corporation Page 36 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore



### reasons:

(1) A false reading occurs due to the malfunction of the monitoring equipment and prompt action was taken to correct the monitoring equipment.

(2) The Permittee has determined that the compliance monitoring parameters established in the permit conditions are technically inappropriate, has previously submitted a request for a minor permit modification to the permit, and such request has not been denied.

(3) An automatic measurement was taken when the process was not operating.

(4) The process has already returned or is returning to operating within “normal” parameters and no response steps are required.

(d) When implementing reasonable steps in response to a compliance monitoring condition, if the Permittee determines that an exceedance of an emission limitation has occurred, the Permittee shall report such deviations pursuant to Section B - Deviations from Permit Requirements and Conditions.

(e) The Permittee shall record all instances when, in accordance with Section D, response steps are taken. In the event of an em ergency, the provisions of 326 IAC 2-7-16 (Emergency Provisions) requiring prompt corre ctive action to mitigate emissions shall prevail.

(f) Except as otherwise provided by a rule or provided specifically in Section D, all monitoring as required in Section D shall be performed when the emission unit is operating, except for time necessary to perform quality assurance and maintenance activities.

C.18 Actions Related to Noncompliance Dem onstrated by a Stack Test [326 IAC 2-7-5] [326 IAC 2-7-6] (a) When the results of a stack test performed in conformance with Section C - Performance Testing, of this permit exceed the level specified in any condition of this permit, the Permittee shall take appropriate response actions. The Permittee shall submit a description of these response actions to IDEM, OAQ, within thirty (30) days of receipt of the test results. The Permittee shall take appropriate action to minimize excess emissions from the affected fac ility while the response actions are being implemented.

(b) A retest to demonstrate compliance shall be performed within one hundred twenty (120) days of receipt of the original test result s. Should the Permittee demonstrate to IDEM, OAQ that retesting in one-hundred and twenty (120) days is not practicable, IDEM, OAQ may extend the retesting deadline.

(c) IDEM, OAQ reserves the authority to take any actions allowed under law in response to noncompliant stack tests.

The response action documents submitted pursuant to this condition do require the certification by the “responsible official” as defined by 326 IAC 2-7-1(34).ESSROC Cement Corporation Page 37 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore


### Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-19]

C.19 Emission Statement [326 IAC 2-7-5(3)(C )(iii)] [326 IAC 2-7-5(7) ] [326 IAC 2-7-19(c)] [326 IAC 2-6] (a) The Permittee shall submit an emission statement certified pursuant to the requirements of 326 IAC 2-6. This statement must be received in accordance with the compliance schedule specified in 326 IAC 2-6-3 and must comply with the minimum requirements specified in 326 IAC 2-6-4. The submittal should cover the period identified in 326 IAC 2-6. The emission statement shall meet the following requirements:

(1) Indicate estimated actual emissions of criteria pollutants from the source, in compliance with 326 IAC 2-6 (Emission Reporting);

(2) Indicate estimated actual emissions of other regulated pollutants (as defined by 326 IAC 2-7-1(32) (“Regulated pollutant which is used only for purposes of Section 19 of this rule”) from the source, for purposes of Part 70 fee assessment.

(b) The statement must be submitted to:

Indiana Department of Environmental Management Technical Support and Modeling Section, Office of Air Quality 100 North Senate Avenue, P. O. Box 6015 Indianapolis, Indiana 46206-6015

The emission statement does require the certification by the “responsible official” as defined by 326 IAC 2-7-1(34).

(c) The annual emission statement required by this permit shall be considered timely if the date postmarked on the envelope or certified mail receipt, or affixed by the shipper on the private shipping receipt, is on or before the date it is due. If the document is submitted by any other means, it shall be c onsidered timely if received by IDEM, OAQ on or before the date it is due.

C.20 General Record Keeping Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-6] (a) Records of all required monitoring data, reports and support information required by this permit shall be retained for a period of at least five (5) years from the date of monitoring sample, measurement, report, or application. These records shall be physically present or electronically accessible at the source location for a minimum of three (3) years. The records may be stored elsewhere for the remaining two (2) years as long as they are available upon request. If the Commissioner makes a request for records to the Permittee, the Permittee shall furnish the records to the Commissioner within a reasonable time.

(b) Unless otherwise specified in this permi t, all record keeping requirements not already legally required shall be implemented withi n ninety (90) days of permit issuance.

C.21 General Reporting Requirements [326 IAC 2-7-5(3)(C)] [326 IAC 2-1.1-11] (a) The source shall submit the attached Q uarterly Deviation and Compliance Monitoring Report or its equivalent. Any deviation from permit requirements, the date(s) of each deviation, the cause of the deviation, and the response steps taken must be reported. This report shall be submitted within thirty (30) days of the end of the reporting period. The Quarterly Deviation and Compliance Monitoring Report shall include the certification by the “responsible official” as defined by 326 IAC 2-7-1(34).ESSROC Cement Corporation Page 38 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore


### (b) The report required in (a) of this condition and reports required by conditions in Section D of this permit shall be submitted to:

Indiana Department of Environmental Management Compliance Data Section, Office of Air Quality 100 North Senate Avenue, P. O. Box 6015 Indianapolis, Indiana 46206-6015

(c) Unless otherwise specified in this permi t, any notice, report, or other submission required by this permit shall be consider ed timely if the date postmarked on the envelope or certified mail receipt, or affixed by the shipper on the private shipping receipt, is on or before the date it is due. If the document is submitted by any other means, it shall be considered timely if rece ived by IDEM, OAQ, on or before the date it is due.

(d) Unless otherwise specified in this permit, all reports required in Section D of this permit shall be submitted within thirty (30) days of the end of the reporting period. All reports do require the certification by the “responsib le official” as defined by 326 IAC 2-7-1(34).

(e) The first report shall cover the period comm encing on the date of issuance of this permit and ending on the last day of the reporting period. Reporting periods are based on calendar years.

C.22 NESHAP Notification and Reporting Requirements [40 CFR Part 63, Subparts A, and LLL] The Permittee shall comply with all reporting provisions specified in 40 CFR Part 63, Subpart LLL, and in particular:

(a) The Permittee shall submit an initial notification in accordance with 40 CFR 63.9(b) (Subpart A, General Provisions). The Permittee provided the following information:

(1) The name and address of the Permittee;

(2) The address (i.e., physical location) of the affected source;

(3) An identification of the relevant standard, or other requirement, that is the basis of the notification and the source's compliance date;

(4) A brief description of the nature, size, design, and method of operation of the source, including its operating design capacity and an identification of each point of emission for each hazardous air pollutant, or if a definitive identification is not yet possible, a preliminary identification of each point of emission for each hazardous air pollutant; and

(5) A statement of whether the affected source is a major source or an area source.

(b) The Permittee shall submit a notification of performance tests, as required by 40 CFR 63.7 and 40 CFR 63.9(e).

(c) The Permittee shall submit a notification of opacity and visible emission observations as required by 40 CFR 63.1349 in accordance with 40 CFR 63.6(h)(5) and 40 CFR 63.9(f).

(d) The Permittee shall submit notification, as required by 40 CFR 63.9(g), of the date that continuous emission monitor performance ev aluation required by 40 CFR 63.8(e) is scheduled to begin.ESSROC Cement Corporation Page 39 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore
(e) The Permittee shall submit notification of compliance status, as required by 40 CFR 63.9(h).

(f) The notification(s) required in this section shall be submitted to:

Indiana Department of Environmental Management Compliance Data Section, Office of Air Quality 100 North Senate Avenue, P.O. Box 6015 Indianapolis, Indiana 46206-6015

and

United States Environmental Protection Agency, Region V Air and Radiation Division, Air Enforcement Branch - Indiana (AE-17J) 77 West Jackson Boulevard Chicago, Illinois 60604-3590



### Stratospheric Ozone Protection

C.23 Compliance with 40 CFR 82 and 326 IAC 22-1 Pursuant to 40 CFR 82 (Protection of Stratospher ic Ozone), Subpart F, except as provided for motor vehicle air conditioners in Subpart B, the Permittee shall comply with the standards for recycling and emissions reduction:

(a) Persons opening appliances for maintenance, se rvice, repair, or disposal must comply with the required practices pursuant to 40 CFR 82.156.

(b) Equipment used during the maintenance, serv ice, repair, or disposal of appliances must comply with the standards for recycling and recovery equipment pursuant to 40 CFR 82.158.

(c) Persons performing maintenance, service, repair, or disposal of appliances must be certified by an approved technician certification program pursuant to 40 CFR 82.161.ESSROC Cement Corporation Page 40 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore

SECTION D.1 FACILITY OPERATION CONDITIONS

Facility Description [326 IAC 2-7-5(15)] Note: Complete facility descriptions are in Section A.2. Quarry activities (1) Quarry drilling, identified as EU01. (2) Quarry blasting, identified as EU75. (3) Raw material (limestone) loading to trucks, identified as EU76.

Raw material stockpile operations (4) Raw material (clay overburden) unloading to strippings stockpile, identified as EU78. (5) Strippings stockpile, identified as EU145. (6) Truck unloading to additive hopper or addi tive storage pile, identified as EU99. (7) Silica/Alumina/Iron additive storage pile, identified as EU100. (8) Additive clay blend pile, identified as EU101. (9) Truck unloading to clay storage piles, identified as EU102. (10) uncovered clay storage pile, identified as EU103. (11) covered clay storage pile, identified as EU104.

Raw Material Sizing Operations (12) Raw material unloading to stone surge pile or primary crusher, identified as EU80. (13) Stone surge pile, identified as EU81. (14) One (1) primary crusher, identified as EU82. (15) One (1) covered conveyor belt, identified as EU83. (16) Screens, identified as EU84. (17) One (1) secondary crusher, identified as EU02. (18) Covered conveyor, identified as EU03. (19) Two (2) tertiary crushers, identified as EU04 and EU04a. (20) One (1) conveyor used to bypass tertiary crusher, identified as EU05. (21) One (1) covered conveyor, identified as EU85. (22) One (1) traveling belt, identified as EU86. (23) North stone bin, identified as EU06. (24) South stone bin, identified as EU07. (25) Stone conveyor transfer to truck, identified as EU87. (26) One (1) truck unloading station to crushed limestone storage pile, identified as EU89. (27) One (1) truck loading station from crushed limestone storage pile, identified as EU91. (28) One (1) truck unloading station to truck dump hopper, identified as EU93. (29) One (1) truck unloading station to emergency limestone storage pile, identified as EU94. (30) Crushed limestone storage piles, identified as EU90. (31) Emergency limestone storage pile, identified as EU95. (32) One (1) truck dump hopper, identified as EU96. (33) One (1) limestone conveyor, identified as EU97. (34) Main limestone storage pile, identified as EU98.

Kiln #1 Cement Kiln Dust (CKD) Operations (35) One (1) dust tank system, identified as EU21. (36) truck loading from the dust tank system, identified as EU113. (37) CKD storage pile, identified as EU118. (38) CKD sales loadout spout (kiln #1 dust tank), identified as EU155.

Kiln #2 Cement Kiln Dust (CKD) Operations (39) truck loading from the elevator dust tank, identified as EU115. (40) truck unloading to CKD storage pile, identified as EU117.

(The information describing the process contained in this facility description box is descriptive information and does not constitute enforceable conditions.)ESSROC Cement Corporation Page 41 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore
Emission Limitations and Standards [326 IAC 2-7-5(1)]

D.1.1 Particulate Matter (PM) [326 IAC 6-1-2] [326 IAC 2-2] (a) Pursuant to 326 IAC 6-1-2 (Nonattainment Area Particulate Limitations), the PM emission rate from each of the raw material sizing operations, the kiln #1 cement kiln dust (CKD) operations, and the kiln #2 cement kiln dust (CKD) operations shall each not exceed 0.03 grains per dry standard cubic foot of exhaust air.

(b) 

### In order to render the requirements of 326 IAC 2-2 (PSD) not applicable, the PM10 emissions from the baghouse controlling the CKD sales loadout spout (kiln #1 dust tank) (EU155) shall not exceed 0.65 pounds per hour and the PM emissions shall not exceed 1.08 pounds per hour. Therefore, the requirements of 

### 326 IAC 2-2 (PSD) shall not apply.

(c) 

### In order to render the requirements of 326 IAC 2-2 (PSD) not applicable, the number of holes drilled by the quarry drilling process shall not exceed 38,000 per 12 consecutive month period and the PM emissions shall not exceed 1.3 pounds per hole. Therefore, the requirements of 

### 326 IAC 2-2 (PSD) shall not apply.

D.1.2 Determinations of Nonapplicability [40 CFR 60, Subparts A, F, and OOO] [40 CFR 63, Subparts A and LLL] (a) None of the quarry activities, raw material stockpile operations, or raw material sizing operations listed in this section are subject to the requirements of the New Source Performance Standards (NSPS), 40 CFR 60, Subparts A and F (Standards of Performance for Portland Cement Plants) because they are not affected facilities under this rule.

(b) None of the cement kiln dust operations listed in this section are subject to the requirements of the New Source Performance Standards (NSPS), 40 CFR 60, Subparts A and F (Standards of Performance for Portland Cement Plants), because they are not considered affected facilities under this rule.

(c) None of the quarry activities, raw material stockpile operations, or raw material sizing facilities/emission units listed in this section are subject to the requirements of the National Emissions Standards for Hazardous Air Pollutants (NESHAP) 40 CFR 63 Subparts A and LLL, because they are not affected facilities under this rule.

(d) None of the cement kiln dust operations listed in this section are subject to the requirements of the National Emissions Standards for Hazardous Air Pollutants (NESHAP) 40 CFR 63 Subparts A and LLL, because they are not considered affected facilities under this rule.

(e) None of the facilities/emission units listed in this section are subject to the requirements of the NSPS, 40 CFR 60, S ubpart OOO (Standards of Performance for Nonmeta llic Mineral Processing Plants) because they were constructed prior to the applicability date of August 31, 1983.

D.1.3 Preventive Maintenance Plan [326 IAC 2-7-5(13)] A Preventive Maintenance Plan, in accordance wi th Section B - Preventive Maintenance Plan, of this permit, is required for the control devices listed in this section.ESSROC Cement Corporation Page 42 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore
Compliance Determination Requirements

D.1.4 Particulate Matter (PM) Except as otherwise provided by statute, rule, or this permit, in order to comply with the limits in Condition D.1.1 each baghouse for PM control shall be in operation at all times when its associated facility is in operation.

D.1.5 Testing Requirements [326 IAC 2-7-6(1),(6)] [326 IAC 2-1.1-11] 

### Within 180 days after issuance of this Part 70 permit, in order to demonstrate compliance with Condition D.1.1, the Permittee shall perform PM and PM10 testing on baghouse 266 controlling the CKD sales loadout spout (kiln #1 dust tank) (EU155) 

### utilizing methods as approved by the Commissioner. PM10 includes filterable and condens ible PM10. Testing shall be conducted in accordance with Section C- Performance Testing. All associated facilities exhausting to a single stack must all be operating when determining compliance with the limit.

Compliance Monitoring Requirements [326 IAC 2-7-6(1)] [326 IAC 2-7-5(1)]

D.1.6 Visible Emissions Notations (a) Visible emission notations of each of the baghouse stack exhausts shall be performed once per shift during normal daylight operations. A trained employee shall record whether visible emissions are present.

(b) 

### For processes operated continuously, "normal" means those conditions prevailing, or expected to prevail, eighty percent (80%) of the time the process is in operation, not counting startup or shut down time.

(c) In the case of batch or discontinuous operations, readings shall be taken during that part of the operation that would normally be expected to cause the greatest emissions.

(d) A trained employee is an employee who has worked at the plant at least one (1) month and has been trained in the appearance and characteristics of visible emissions for that specific process.

(e) If visible emissions are observed crossing the property line, the Permittee shall implement the appropriate procedures as set out in its Compliance Response Plan. 

### Failure to take response steps in accordance with Se ction C - Compliance Response Plan - Preparation, Implementation, Records, and Reports, shall be considered a deviation from this permit.

(f) If visible emissions are present at any baghouse stack, the Permittee shall implement appropriate procedures as set out in its Compliance Response Plan for such facility. 

### Failure to take response steps in accordance with Section C - Compliance Response Plan - Preparation, Implementation, Records, and Reports, shall be considered a deviation from this permit.

D.1.7 Parametric Monitoring The Permittee shall record the static pressure drop across each baghouse, at least once per shift when the associated facility is in operation. When for any one reading, the pressure drop across a baghouse is outside the normal range of 1.0 to 8.0 inches of water or the range established during the most recent stack test, the Permittee shall take reasonable response steps in accordance with 

### Section C - Compliance Response Plan - Preparation, Implementation, Records, and Reports . A pressure reading that is outside the normal range is not a deviation from this permit. 

### Failure to take response steps in accordance with Section C - Compliance Response Plan - Preparation, Implementation, Records, and Reports, shall be considered a deviation from this permit.ESSROC Cement Corporation Page 43 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore
The instrument used for determining the pressure shall comply with Section C - Pressure Gauge and Other Instrument Specifications, of this permit, shall be subject to approval by IDEM, OAQ, and shall be calibrated at least once every six (6) months.

D.1.8 Baghouse Inspections An inspection shall be performed each calendar quarter of all bags controlling the facilities listed in this section. Inspections required by this condition shall not be performed in consecutive months. All defective bags shall be replaced.

D.1.9 Broken or Failed Bag Detection In the event that bag failure has been observed.

(a) 

### For multi-compartment units, the affected compartments will be shut down immediately until the failed units have been repaired or replaced. Within eight (8) business hours of the determination of failure, response steps according to the timetable described in the Compliance Response Plan shall be initiated. For any failure with corresponding response steps and timetable not described in the Compliance Response Plan, response steps shall be devised within eight (8) business hours of discovery of the failure and shall include a timetable for completion. Failure to take response steps in accordance with Section C - Compliance Response Plan - Preparation, Implementation, Records, and Reports, shall be consi dered a deviation from this permit. If operations continue after bag failure is observed and it will be 10 days or more after the failure is observed before the failed units will be repaired or replaced, the Permittee shall promptly notify the IDEM, OAQ of the expected date the failed units will be repaired or replaced. The notification shall also include the status of the applicable compliance monitoring parameters with respect to normal, and the results of any response actions taken up to the time of notification.

(b) 

### For single compartment baghouses, if failure is indicated by a significant drop in the baghouse’s pressure readings with visible emissi ons present or the failure is indicated by an opacity violation, or if bag failure is determined by other means, such as gas temperatures, flow rates, air infiltration, l eaks, dust traces or triboflows, then the failed units and the associated process will be shut down immediately until the failed units have been repaired or replaced. Operations may continue only if the event qualifies as an emergency and the Permittee satisfies the requirements of the emergency provisions of this permit (Section B - Emergency Provisions).

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-19]

D.1.10 Record Keeping Requirements (a) To document compliance with Condition D.1.6, the Permittee shall maintain records of visible emission notations of the baghouse stack exhausts once per shift.

(b) To document compliance with Condition D.1.7, the Permittee shall maintain records of the
pressure drop across each baghouse once per shift.

(c) To document compliance with Condition D.1.8, the Permittee shall maintain records of the results of the inspections required under Condition D.1.8.

(d) To document compliance with Condition D.1.1(c), the Permittee shall maintain records of the number of holes drilled at the quarry. All records shall be maintained in accordance with Section C - General Record Keeping Requirements, of this permit.

(e) To document compliance with Condition D.1.3, the Permittee shall maintain of records of any additional inspections prescribed by the Preventive Maintenance Plan.ESSROC Cement Corporation Page 44 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore
(f) All records shall be maintained in accordance with Section C - General Record Keeping Requirements, of this permit.

D.1.11 Reporting Requirements A quarterly summary of the information to document compliance with the limit specified in Condition D.1.1(c) shall be submitted to the address listed in Section C - General Reporting Requirements, of this permit, using the reporting form located at the end of this permit, or its equivalent, within thirty (30) days after the end of the quarter being reported. This report submitted by the Permittee does require the certification by the “responsible official” as defined by 326 IAC 2-7-1(34).ESSROC Cement Corporation Page 45 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore

SECTION D.2 FACILITY OPERATION CONDITIONS

Facility Description [326 IAC 2-7-5(15)] Note: Complete facility descriptions are in Section A.2. Miscellaneous Facilities (41) Plant Roads, identified as EU152. (42) Vacuum system, identified as EU73. (43) One (1) warehouse conveyor system for conveying bagged cement, identified as EU74.

Clay Processing Operations (44) Clay hopper, identified as EU105. (45) One (1) covered conveyor system, identified as EU106. (46) One (1) clay crusher, identified as EU08.

Finish Operations Cr ane Storage Facilities (47) Emergency BP stone storage pile, identified as EU128. (48) One (1) truck unloading station, identified as EU127. (49) One (1) truck unloading station to gypsum storage piles, identified as EU129. (50) Crane storage building, identified as EU131. (51) gypsum storage piles, identified as EU130 and EU134.

Fossil Fuel Storage a nd Handling Facilities (52) one (1) truck unloading station to the reserve coal storage pile, identified as EU136 . (53) One (1) reserve coal storage pile, identified as EU137. (54) one (1) coal storage pile, identified as EU142. (55) One (1) coal draw-up covered conveying system, identified as EU63. (56) Coal transfer tower, identified as EU64. (57) One (1) coal bin, identified as EU65.

Kiln #1 Clinker Handling Facilities (58) One (1) #1 clinker drag conveyor, identified as EU23. (59) apron conveyor, identified as EU24. (60) clinker can #1, identified as EU114.

Kiln #2 Clinker Handling Facilities (61) One (1) #2 clinker drag conveyor, identified as EU30. (62) One (1) aumond conveyor, identified as EU31. (63) One (1) cross belt, identified as EU119. (64) clinker can #2, identified as EU120.

(The information describing the process contained in this facility description box is descriptive information and does not constitute enforceable conditions.)ESSROC Cement Corporation Page 46 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore

Facility Description [326 IAC 2-7-5(15)] continued Note: Complete facility descriptions are in Section A.2. Clinker Handling to Cr ane Storage Facilities (65) One (1) long belt, identified as EU25. (66) One (1) North clinker transfer tower, identified as EU32. (67) One (1) covered incline belt (Shuttle belt), identified as EU33. (68) One (1) clinker storage pile, identified as EU121. (69) North clinker storage pile, identified as EU122. (70) North clinker storage building, identified as EU123. (71) One (1) North reclaim clinker covered conveyor system, identified as EU34. (72) One (1) South reclaim clinker covered conveyor, identified as EU124. (73) Truck loading station, identified as EU125. (74) Truck unloading station, identified as EU126.

2ABC Finish Mill Facilities (75) One (1) CKD/Lime tank, identified as EU146. (76) one (1) gypsum/stone transfer circuit ABC mills, identified as EU35. (77) one (1) clinker transfer circuit ABC mills, identified as EU36. (78) two (2) clinker elevators, identified as EU37. (79) One (1) 2BC finish mill feed belt, identified as EU132. (80) 2A hopper / preliminary ball mill used to grind clinker and gypsum, identified as EU38. (81) one (1) finish mill circuit 2A, identified as EU39. (82) one (1) finish mill circuit 2B, identified as EU40. (83) one (1) finish mill circuit 2C, identified as EU42. (84) One (1) separator and cement cooler, identified as EU43. (85) One (1) separator and cement cooler, identified as EU41. (86) One (1) BP tank for storing finished product (cement), identified as EU48. (87) One (1) pump used to transfer material from the BP tank to silos, identified as EU49.

Finish Mill 2 Facilities (88) one (1) gypsum elevator, identified as EU135. (89) one (1) 2D finish mill clinker bin, identified as EU44. (90) one (1) 2D finish mill clinker / gypsum feed circuit, identified as EU45. (91) one (1) 2D finish mill roll press circuit, identified as EU46. (92) one (1) 2D finish mill circuit, identified as EU47.

Finish Product 501-Silos Storage and Packing Facilities (93) 501-Silos 30-44, identified as EU54. (94) One (1) BIC mixer for mixing lime and pigment with the clinker, identified as EU55. (95) one (1) BIC packer for loading cement into bags, identified as EU56.

Finish Product 506-Silos Storage, P acking, and Bulk Loading Facilities (96) 506-Silos 56-73, identified as EU53. (97) Two (2) bulk loading stations for railroad cars and trucks, identified as EU57 and EU58. (98) One (1) packer #1 for loading cement into bags, identified as EU59. (99) One (1) packer #2 for loading cement into bags, identified as EU60. (100) One (1) packer #3 for loading cement into bags, identified as EU61. (101) one (1) bag compression station, identified as EU62.



### (The information describing the process contained in this facility description box is descriptive information and does not consti tute enforceable conditions.)ESSROC Cement Corporation Page 47 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore

Facility Description [326 IAC 2-7-5(15)] continued Note: Complete facility descriptions are in Section A.2. Finish Product 504-Silos Storag e and Bulk Loading Facilities (102) 504-Silos 45-48, and 50-55, identified as EU51. (103) One (1) bulk loading station for trucks and railroad cars, identified as EU52.

Finish Product 504-Silos Storag e and Bulk Loading Facilities (continued) (104) 504 Silos Bank/Silo 49 (CKD sales), identified as EU153. (105) CKD sales loadout spout, identified as EU154.

Finish Product 502-Silos Storag e and Bulk Loading Facilities (106) 502-Silos 1, 2, and 7-11, identified as EU50.



### (The information describing the process contained in this facility description box is descriptive information and does not consti tute enforceable conditions.)

Emission Limitations and Standards [326 IAC 2-7-5(1)]

D.2.1 Particulate Matter (PM) [326 IAC 6-1-2] Pursuant to 326 IAC 6-1-2 (Nonattainment Area Particulate Limitations), the PM emission rate from each of the miscellaneous facilities, clay processing operations, finish operations crane storage facilities, fossil fuel storage and handling facilities, kiln #1 clinker handling facilities, kiln #2 clinker handling facilities, clinker handling to crane storage facilities, 2ABC finish mill facilities, finish mill #2 facilities, finish product 501-silos storage and packing facilities, finish production 506- silos storage, packing, and bulk loading facilities, finish product 504-silos storage and bulk loading facilities, and finish product 502-silos storage and bulk loading facilities shall each not exceed 0.03 grains per dry standard cubic foot of exhaust air.

D.2.2 General Provisions Relating to NESHAP [326 IAC 20-1][40 CFR Part 63, Subpart A] Except when otherwise specified in 40 CFR Part 63, Subpart LLL, the provisions of 40 CFR Part 63, Subpart A - General Provisions, which are incorporated by reference in 326 IAC 20-1, apply to all of the facilities described in this section, except for the open/unenclosed material stockpiles and haul roads.

D.2.3 NESHAP Emissions Limitation [40 CFR 63, Subpart LLL] [326 IAC 20-27-1] The NESHAP 40 CFR 63, Subpart LLL and 326 IAC 20-27-1 applies to all of the emission units listed in this section, except for the open/unenclosed material stockpiles and haul roads. Pursuant to 40 CFR 63.1348 (Emissions Standards and Operating Limits), on and after June 14, 2002, which is the compliance date for the National Emission Standards for Hazardous Air Pollutants (NESHAP) from the Portland Cement Manufacturing Industry, the visible emissions from each of the affected facilities listed in this section shall not exceed ten percent (10%) opacity.

D.2.4 Determinations of Nonapplicability [40 CFR 60, Subparts A and F] Emission units EU63 through EU65, EU30 thr ough EU33, EU120, EU132, EU46, EU73, EU74, EU55 and EU56 are not subject to the requirements of the New Source Performance Standards (NSPS), 40 CFR 60, Subparts A and F (Standards of Performance for Portland Cement Plants) because the requirements of the NESHAP 40 CFR 63 Subpart LLL superseded the requirements of the NSPS on June 14, 2002. None of the other facilities listed in this are subject to the requirements of the New Source Performance Standards (NSPS), 40 CFR 60, Subparts A and F (Standards of Performance for Portland Cement Plants) because they are not affected facilities under this rule, or they were constructed prior to the applicability date of August 17, 1971.ESSROC Cement Corporation Page 48 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore
D.2.5 Prevention of Significant De terioration (PSD) [326 IAC 2-2] 

### In order to render the requirements of PSD not applicable, the following conditions shall apply:

(d) The PM emissions from baghouses 261, 262, 31497, 31498, and 263 controlling the 2D finish mill roll press circuit (EU46) shall not exceed 4.53 pounds per hour (limit for all three baghouses combined).

(e) The PM10 emissions from baghouses 261, 262, 31497, 31498 and 263 controlling the 2D finish mill roll press circuit (EU46) shall not exceed 2.71 pounds per hour (limit for all three baghouses combined).

(f) The PM emissions from baghouse 249 controlling the warehouse conveyor system (EU74) shall not exceed 4.58 pounds per hour.

(g) The PM emissions from baghouse 250 controlling the vacuum system (EU73) shall not exceed 1.11 pounds per hour.

(h) The PM emissions from baghouse 265 controlling the CKD sales loadout spout (EU154) shall not exceed 1.15 pounds per hour.

(i) The PM10 emissions from baghouse 265 controlling the CKD sales loadout spout (EU154) shall not exceed 0.69 pounds per hour.



### Therefore, the requirements of 326 IAC 2-2 (PSD) are not applicable.

D.2.6 Preventive Maintenance Plan [326 IAC 2-7-5(13)] [40 CFR 63, Subpart LLL] A Preventive Maintenance Plan, in accordance wi th Section B - Preventive Maintenance Plan, of this permit, is required for the control devices listed in this section.

Compliance Determination Requirements

D.2.7 Testing Requirements [326 IAC 2-7-6(1),(6)] [326 IAC 2-1.1-11] [40 CFR 60, Subpart F] [40 CFR 63, Subpart LLL] (a) No later than 180 days after June 14, 2002, which is the compliance date for the Portland Cement Manufacturing Industry NESHAP, the Permittee shall demonstrate compliance with the limits established in Condition D.2.3 by conducting a test in accordance with 40 CFR 63.1349, Method 9 of 40 CFR Part 60, Appendix A, and Section C - Performance Testing.

(b) 

### In order to demonstrate compliance with Conditions D.2.5 and D.2.1, the Permittee shall perform testing on the facilities listed in the following table, utilizing methods as approved by the Commissioner. These tests shall be conducted within 180 days after issuance of this Part 70 permit.

Processes Control Device ID Pollutants to test

vacuum system (EU73) baghouse 250 PM

warehouse conveyor system (EU74) baghouse 249 PM

CKD sales loadout spout (kiln #1 dust tank) (EU155) baghouse 266 PMESSROC Cement Corporation Page 49 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore

Processes Control Device ID Pollutants to test

south reclaim clinker covered conveyor (EU124) baghouse 120 PM

2D finish mill clinker bin (EU44) and gypsum elevator (EU135) baghouse 120 PM

2D finish mill roll press circuit (EU46) and 2D finish mill clinker / gypsum feed circuit (EU45) baghouses 261, 262, and 263 PM and PM10



### 2D finish mill circuit (EU47) baghouse 139 PM

CKD sales loadout spout (EU154) baghouse 265 PM

Elevators (2) (EU37) 2A finish mill circuit (EU39) baghouse 134 PM

Separator and Cement cooler (EU41) baghouse 136 PM

Sidewinder (EU15) baghouse 247 PM

Blend silo #2 (EU17) baghouse 230 PM

CKD/Lime tank (EU146) baghouse 143 PM

calibration system (EU18) baghouse 212 PM



### PM-10 includes filterable and condensible PM -10. Testing shall be conducted in accordance with Section C- Performance Testing. All associated facilities exhausting to a single stack must all be operating when determining compliance with the limit.

D.2.8 Particulate Matter (PM) Except as otherwise provided by statute, rule, or this permit, in order to comply with conditions D.2.1, D.2.3, and D.2.5 each baghouse for PM control shall be in operation at all times when its associated facility is in operation.

D.2.9 NESHAP Monitoring Requirements [40 CFR 63, Subpart LLL][326 IAC 20-27-1] (a) Pursuant to 40 CFR 63.1350 (Monitoring Requirements), the Permittee shall prepare a written operations and maintenance plan for each affected source by June 14, 2002, which is the compliance date for the National Emission Standards for Hazardous Air Pollutants (NESHAP) from the Portland Cement Manufacturing Industry. The plan shall include the following information:

(1) Procedures for proper operation and maintenance of the affected sources and associated air pollution control device(s) in order to meet the emissions limit in Condition D.2.3; and

(2) Procedures to be used to periodically monitor the facilities listed in this section,ESSROC Cement Corporation Page 50 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore
which are subject to opacity standards under 40 CFR 63.1348. Such procedures must include the following provisions:

(A) The Permittee shall conduct a monthly 1-minute visible emissions test of each affected source except for the finish mills, in accordance with 40 CFR 60, Appendix A, Method 22. The test must be conducted while the affected source is in operation.

(B) If no visible emissions are observed in six consecutive monthly tests for any affected source, the Permittee may decrease the frequency of testing from monthly to semi-annually for that affected source. If visible emissions are observed during any semi-annual test, the Permittee shall resume testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests.

(C) If no visible emissions are observed during the semi-annual test for any affected source, the Permittee may decrease the frequency of testing from semi-annually to annually for that affected source. If visible emissions are observed during any annual test, the Permittee shall resume testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests.

(D) If visible emissions are observed during any Method 22 test, the Permittee must conduct a 6-minute test of opacity in accordance with 40 CFR 60, Appendix A, Method 9. The Method 9 test must begin within one hour of any observation of visible emissions.

(3) Corrective actions to be taken when required by paragraph (b).

Failure to comply with any provision of the operations and maintenance plan shall be a violation of the standard.

(b) Pursuant to 40 CFR 63.1350 (Monitoring Requirements), the Permittee shall monitor opacity from the finish mills by conducting daily visual emissions observations of the mill sweep and air separator particulate matter control devices (PMCDs), in accordance with the procedures of 40 CFR 60, Appendix A, Method 22. The Method 22 test shall be conducted while the affected source is operating at the representative performance conditions. The duration of the Method 22 test shall be six minutes. If visible emissions are observed during any Method 22 visible emissions test, the Permittee must initiate, within one (1) hour, the corrective actions specified in the site specific operations and maintenance plan developed in accordance with 40 CFR 63.1350(a)(1) and (a)(2); and conduct a follow-up Method 22 test. If visible emissions are observed, then within 24 hours of the end of the Method 22 test in which the visible emissions were observed, the Permittee must conduct a followup Method 22 test of each stack from which visible emissions were observed during the previous Method 22 test. If visible emissions are observed during the followup Method 22 test, the Permittee must conduct a visual opacity test of each stack from which visible emissions were observed during the followup Method 22 test, in accordance with 40 CFR 60, Appendix A, Method 9. The duration of the Method 9 test shall be thirty (30) minutes.

Compliance Monitoring Requirements [326 IAC 2-7-6(1)] [326 IAC 2-7-5(1)]

D.2.10 Visible Emissions Notations (a) Visible emission notations of each of the baghouse stack exhausts shall be performedESSROC Cement Corporation Page 51 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore
once per shift during normal daylight operations. A trained employee shall record whether visible emissions are present.

(b) 

### For processes operated continuously, "normal" means those conditions prevailing, or expected to prevail, eighty percent (80%) of the time the process is in operation, not counting startup or shut down time.

(c) In the case of batch or discontinuous operations, readings shall be taken during that part of the operation that would normally be expected to cause the greatest emissions.

(d) A trained employee is an employee who has worked at the plant at least one (1) month and has been trained in the appearance and characteristics of visible emissions for that specific process.

(e) On days that the NESHAP, 40 CFR 63, Subpart LLL, monitoring required in Condition D.2.9 is performed, the Permittee may use those results to satisfy the requirements of this condition for the units subject to the NESHAP.

(f) If visible emissions are present at any baghouse or ESP stack for which a COM is not operating, the Permittee shall implement the appropriate procedures as set out in its Compliance Response Plan for such facility. 

### Failure to take response steps in accordance with Section C - Compliance Response Plan - Preparation, Implementation, Records, and Reports, shall be considered a deviation from this permit.

D.2.11 Baghouse Parametric Monitoring The Permittee shall record the static pressure drop across each baghouse, at least once per shift when the associated facility is in operation. When for any one reading, the pressure drop across a baghouse is outside the normal range of 1.0 to 8.0 inches of water or the range established during the most recent stack test, the Permittee shall take reasonable response steps in accordance with 

### Section C - Compliance Response Plan - Preparation, Implementation, Records, and Reports . A pressure reading that is outside the normal range is not a deviation from this permit. 

### Failure to take response steps in accordance with Section C - Compliance Response Plan - Preparation, Implementation, Records, and Reports, shall be considered a deviation from this permit.

The instruments used for determining the pressure shall comply with Section C - Pressure Gauge and Other Instrument Specifications, of this permit, shall be subject to approval by IDEM, OAQ, and shall be calibrated at least once every six (6) months.

D.2.12 Baghouse Inspections An inspection shall be performed each calendar quarter of all bags controlling the facilities listed in this section. Inspections required by this condition shall not be performed in consecutive months. All defective bags shall be replaced.

D.2.13 Broken or Failed Bag Detection In the event that bag failure has been observed.

(a) 

### For multi-compartment units, the affected compartments will be shut down immediately until the failed units have been repaired or replaced. Within eight (8) business hours of the determination of failure, response steps according to the timetable described in the Compliance Response Plan shall be initiated. For any failure with corresponding response steps and timetable not described in the Compliance Response Plan, response steps shall be devised within eight (8) business hours of discovery of the failure and shall include a timetable for completion. Failure to take response steps in accordance with Section C - Compliance Response Plan - Preparation, Implementation, Records, and Reports, shall be consi dered a deviation from this permit. If operationsESSROC Cement Corporation Page 52 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore
continue after bag failure is observed and it will be 10 days or more after the failure is observed before the failed units will be repaired or replaced, the Permittee shall promptly notify the IDEM, OAQ of the expected date the failed units will be repaired or replaced. The notification shall also include the status of the applicable compliance monitoring parameters with respect to normal, and the results of any response actions taken up to the time of notification.

(b) 

### For single compartment baghouses, if failure is indicated by a significant drop in the baghouse’s pressure readings with abnormal visible emissions or the failure is indicated by an opacity violation, or if bag failure is determined by other means, such as gas temperatures, flow rates, air infiltration, l eaks, dust traces or triboflows, then the failed units and the associated process will be shut down immediately until the failed units have been repaired or replaced. Operations may continue only if the event qualifies as an emergency and the Permittee satisfies the requirements of the emergency provisions of this permit (Section B - Emergency Provisions).

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-19]

D.2.14 Record Keeping Requirements (a) To document compliance with Condition D.2.10, the Permittee shall maintain records of visible emission notations of the baghouse and ESP stack exhausts once per shift, whenever a COM is not being used.

(b) To document compliance with Condition D.2.11, the Permittee shall maintain records of the pressure drop of each baghouse once per shift.

(c) To document compliance with Condition D.2.12, the Permittee shall maintain records of the results of the baghouse inspections required under Condition D.2.12.

(d) To document compliance with the NESHAP 40 CFR 63, Subpart LLL, the Permittee shall maintain all records required by 40 CFR 63.1355. These records include the following:

(1) The Permittee shall maintain files of all information (including all reports and notifications) required by 40 CFR 63.1355(a) recorded in a form suitable and readily available for inspection and review as required by 40 CFR 63.10(b)(1).

(2) The Permittee shall maintain records for each affected source as required by 40 CFR 63.10(b)(2) and (3) including:

(I) All documentation supporting initial notifications and notifications of compliance status under 40 CFR 63.9.

(II) All records of applicability determination, including supporting analyses.

(e) To document compliance with Condition D.2.6, the Permittee shall maintain of records of any additional inspections prescribed by the Preventive Maintenance Plan.

(f) All records shall be maintained in accordance with Section C - General Record Keeping Requirements, of this permit.

D.2.16 Reporting Requirements (a) To document compliance with the NESHAP 40 CFR 63, Subpart LLL, the Permittee shall report the information required by 40 CFR 63.1354, including, but not limited to the following:ESSROC Cement Corporation Page 53 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore
(1) The plan required by Condition D.2.9 shall be submitted to IDEM, OAQ and U.S. EPA by June 14, 2002, which is the compliance date for the National Emission Standards for Hazardous Air Pollutants (NESHAP) for the Portland Cement Manufacturing Industry.

(2) As required by 40 CFR 63.10(d)(2), the Permittee shall report the results of performance tests as part of the notification of compliance status, required in Section C - NESHAP Notification and Reporting Requirements.

(3) As required by 40 CFR 63.10(d)(3), the Permittee shall report the opacity results from tests required by 40 CFR 63.1349.

(4) As required by 40 CFR 63.10(d)(5), if actions taken by the Permittee during a startup, shutdown, or malfunction of an affected source (including actions taken to correct a malfunction) are consistent with the procedures specified in the source’s startup, shutdown, and malfunction plan specified in 40 CFR 63.6(e)(3), the Permittee shall state such information in a semiannual report. Reports shall only be required if a startup, shutdown, or malfunction occurred during the reporting period. The startup, shutdown, and malfunction report may be submitted simultaneously with the excess emissions and continuous monitoring system performance reports.

(5) Pursuant to 40 CFR 63.10(d)(5)(ii), any time an action taken by the Permittee during a startup, shutdown, or malfunction (including actions taken to correct a malfunction) is not consistent with the procedures in the startup, shutdown, and malfunction plan, and the source exceeds any applicable emission limitation in the relevant emission standard, the Permittee shall report the actions taken for that event within 2 working days after commencing actions inconsistent with the plan, by telephone call to the OAQ Compliance Section at (317) 233-5674 or facsimile (FAX) transmission at (317) 233-6865. The immediate report shall be followed by a letter within 7 working days after the end of the event, certified by the Permittee, explaining the circumstances of the event, the reasons for not following the startup, shutdown, and malfunction plan, and whether any excess emissions and/or parameter monitoring exceedances are believed to have occurred.

(b) In addition to being submitted to the addr ess listed in Section C - General Reporting Requirements, all reports and the operation and maintenance plan submitted pursuant to 40 CFR 63, Subpart A shall also be submitted to the U.S. EPA at the following address:

United States Environmental Protection Agency, Region V Air and Radiation Division, Regulation Development Branch - Indiana (AR-18J) 77 West Jackson Boulevard Chicago, Illinois 60604-3590

Pursuant to 40 CFR 63.10(d)(5)(i) and (ii), the reports submitted by the Permittee shall include the certification by the “responsible official” as defined by 326 IAC 2-7-1(34).ESSROC Cement Corporation Page 54 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore

SECTION D.3 FACILITY OPERATION CONDITIONS

Facility Description [326 IAC 2-7-5(15)] Note: Complete facility descriptions are in Section A.2. Raw Mill Facilities (107) Two (2) pneumatic truck unloading stations to additive bins, identified as EU107 and EU108. (108) One (1) clay hopper, identified as EU109. (109) Three (3) additive bins for flyash, bottom ash, or iron, identified as EU10, EU11, and EU12, equipped with two elevators. (110) One (1) C-15 covered conveyor system, identified as EU09. (111) One (1) Loesche raw mill with a triple gate, identified as EU14. (112) one (1) sidewinder (pneumatic transfer pump), identified as EU15. (113) One (1) raw material pile, identified as EU112. (114) one (1) oil-fired Todd furnace used for heating the Loesche raw mill, identified as EU13. (115) blend silo #1 for blending kiln feed, identified as EU16. (116) blend silo #2 for blending kiln feed, identified as EU17. (117) one (1) calibration system, identified as EU18.

Coal handling, milling and storage facilities (118) Coal (crusher) mill #1, identified as EU66. (119) Coal (crusher) mill #2, identified as EU67. (120) one (1) fuel oil-fired air heater for kiln #1 coal mill, identified as EU68. (121) one (1) fuel oil-fired air heater for kiln #2 coal mill, identified as EU69. (122) Kiln #2 coal dust silo, identified as EU149. (123) Kiln #2 coal weigh system, identified as EU150. (124) Kiln #2 coal handling system, identified as EU151.

The kiln #1 and kiln #2 facilities (125) One (1) feed system for kiln #1, identified as EU19. (126) One (1) long dry process rotary cement kiln #1, identified as EU20. (127) One (1) feed system for kiln #2, identified as EU26. (128) One (1) dry process rotary cement kiln #2 and associated preheater unit, equipped with an alkali bypass, identified as EU27. (129) One (1) Elevator/dust tank (alkali bypass) for kiln #2, identified as EU28.

The clinker cooler #1 facilities (130) One (1) grate clinker cooler #1, identified as EU22.

The clinker cooler #2 facilities (131) One (1) grate clinker cooler #2, identified as EU29.

(The information describing the processes contained in this facility description box is descriptive information and does not constitute enforceable conditions.)

Emission Limitations and Standards [326 IAC 2-7-5(1)]

D.3.1 Particulate Matter (PM) [326 IAC 6-1-17] Pursuant to 326 IAC 6-1-17 (Nonattainment Area Particulate Limitations: Clark County), the following conditions shall apply:

(1) The combined particulate matter emissions from the kiln #2 system which includes kiln #2 (EU27), kiln #2 alkali bypass (EU28), the fuel oil-fired air heater for kiln #2 (EU69), and clinker cooler #2 (EU29), shall not exceed 265.20 tons per year and 0.4 pound per ton of kiln feed (dry basis).

(2) The combined particulate matter emissions from the kiln #1 system, which includes kiln #1 (EU20), the fuel oil-fired air heater (EU68), and clinker cooler #1 (EU22), shall notESSROC Cement Corporation Page 55 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore
exceed 251.20 tons per year and 0.58 pound per ton of kiln feed (dry basis).

D.3.2 Particulate Matter (PM) [326 IAC 6-1-2] [326 IAC 2-2] [326 IAC 2-7-6(3)] [326 IAC 2-7-15] (a) Pursuant to 326 IAC 6-1-2 (Nonattainment Area Particulate Limitations), the following conditions shall apply:

(1) The particulate matter emissions from the kiln #2 feed system (EU26) shall not exceed 0.03 grains per dry standard cubic foot of exhaust air.

(2) The particulate matter emissions from the kiln #1 feed system (EU19) shall not exceed 0.03 grains per dry standard cubic foot of exhaust air.

(3) The PM emission rate from each of the coal handling, milling and storage facilities (EU66, EU67, EU149, EU150, and EU151) shall not exceed 0.03 grains per dry standard cubic foot of exhaust air.

(4) The PM emission rate from each of the raw mill facilities shall not exceed 0.03 grains per dry standard cubic foot of exhaust air.

(b) In order to render the requirements of 326 IA C 2-2 (Prevention of Significant Deterioration (PSD)) not applicable, the following conditions shall apply:

(1) The PM emissions from filter 255 controlling the kiln #2 coal handling system (EU151) shall not exceed 0.27 pounds per hour.

(2) The PM10 emissions from filter 255 controlling the kiln #2 coal handling system (EU151) shall not exceed 0.16 pounds per hour.

(3) The PM emissions from baghouse 253 controlling the kiln #2 coal dust silo (EU149) shall not exceed 3.65 pounds per hour.

(4) The PM10 emissions from baghouse 253 controlling the kiln #2 coal dust silo (EU149) shall not exceed 2.19 pounds per hour.

(5) The PM emissions from filter 254 controlling the kiln #2 coal weigh system (EU150) shall not exceed 0.68 pounds per hour.

(6) The PM10 emissions from filter 254 controlling the kiln #2 coal weigh system (EU150) shall not exceed 0.41 pounds per hour.

(7) The PM emissions from baghouse 228 controlling the elevator for transferring material from the hopper to the additive bin shall not exceed 5.68 pounds per hour.

(8) The PM10 emissions from baghouse 228 controlling the elevator for transferring material from the hopper to the additive bin shall not exceed 3.40 pounds per hour.

Therefore, the requirements of 

### 326 IAC 2-2 (PSD) shall not apply.

D.3.3 Sulfur Dioxide (SO 2 ) [326 IAC 7-1.1-1] (a) Pursuant to 326 IAC 7-1.1 (SO 2 Emissions Limitations) the SO 2 emissions from the combustion of coal or the simultaneous combustion of coal and oil, in kiln #1 and kiln #2 shall not exceed six (6.0) pounds per MMBtu heat input. Compliance shall be demonstrated on a calendar month average.ESSROC Cement Corporation Page 56 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore


### (b) Pursuant to 326 IAC 7-1.1 (SO 2 

### Emissions Limitations) the SO 2 

### emissions from the combustion of fuel oil only from each of the kilns shall not exceed five tenths (0.5) pounds per MMBtu heat input. Pursuant to 326 IAC 7-2-1, compliance shall be demonstrated on a calendar month average.

(c) Pursuant to 326 IAC 7-1.1 (SO 2 Emissions Limitations) the SO 2 emissions from each of the fuel oil-fired furnaces (EU68, and EU69) and the Todd furnace (EU13) shall not exceed 0.5 pound per million Btu of heat input when combusting fuel oil. 

### Compliance shall be demonstrated on a calendar month average.

D.3.4 General Provisions Relating to NESHAP [326 IAC 20-1][40 CFR Part 63, Subpart A] The provisions of 40 CFR Part 63, Subpart A - General Provisions, which are incorporated by reference in 326 IAC 20-1, apply to the raw mill facilities, the kiln #1 feed system (EU19), and the kiln #2 feed system (EU26), the coal handling, milling, and storage facilities (EU66, EU67, EU149, EU150, and EU151), the kiln #1 system, which includes kiln #1 (EU20), the fuel oil-fired air heater for kiln #1 (EU68), and clinker cooler #1 (EU22), and the kiln #2 system which includes kiln #2 (EU27), kiln #2 alkali bypass (EU28), the fuel oil-fired air heater for kiln #2 (EU69), and clinker cooler #2 (EU29), as described in this section except when otherwise specified in 40 CFR Part 63, Subpart LLL.

D.3.5 NESHAP Emissions Limitation [40 CFR Part 63, Subpart LLL] (a) Pursuant to 40 CFR 63.1343 (Emissions Standards and Operating Limits), on and after June 14, 2002, which is the compliance date for the National Emission Standards for Hazardous Air Pollutants (NESHAP) from the Portland Cement Manufacturing Industry, kiln #1 and kiln #2 shall be limited as follows:

(1) The particulate matter (PM) emissions from kiln #1 shall not exceed 0.30 pound per ton of feed (dry basis) to the kiln #1.

(2) The combined particulate matter emissions from the kiln #2 (EU27), the fuel oilfired air heater for kiln #2 (EU69), and kiln #2 alkali bypass (EU28) shall not exceed 0.30 pound per ton of feed (dry basis) to the kiln #2.

(3) Visible emissions from kiln #1 shall be limited to twenty percent (20%) opacity.

(4) When kiln #2 and the Loesche raw mill (EU14) are both operating, the visible emissions from the ESP controlling the Loesche raw mill and kiln #2 shall not exceed ten percent (10%) opacity. IDEM and USEPA have information that indicates that the Permittee is not in compliance with this opacity limit. The OAQ will promptly reopen this permit using the provisions of 326 IAC 2-7-9 (Permit Reopening) to include detailed requirements necessary to comply with this opacity limit and a schedule for achieving compliance with such requirement.

(5) When the Loesche raw mill (EU14) is operating and the kiln #2 is not operating, the visible emissions from the ESP controlling the Loesche raw mill shall not exceed 10% opacity.

(6) When the kiln #2 is operating and Loesche raw mill (EU14) is not operating, the visible emissions from the ESP controlling kiln #2 shall not exceed 20% opacity.

(7) Dioxin/Furan emissions shall be limited to 8.7 x 10 -11 grains per dry standard cubic foot (TEQ) corrected to seven percent oxygen; or 1.7 x 10 -10 grains per dry standard cubic foot (TEQ) corrected to seven percent oxygen, when the average of the performance test run average temperatures at the inlet to the particulate matter control device is 400 degrees Fahrenheit or less.ESSROC Cement Corporation Page 57 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore
(8) The Kilns shall operate such that the three-hour rolling average PMCD inlet temperature is no greater than the temperature established at the performance test.

(b) Pursuant to 40 CFR 63.1345 (Emissions Standards and Operating Limits), on and after June 14, 2002, which is the compliance date for the National Emission Standards for Hazardous Air Pollutants (NESHAP) from the Portland Cement Manufacturing Industry, each clinker cooler shall be limited as follows:

(1) Particulate matter (PM) emissions shall be limited to 0.10 pound per ton of feed (dry basis) to the kiln.

(2) Visible emissions shall be limited to ten percent (10%) opacity.

(c) Pursuant to 40 CFR 63.1348 (Emissions Standards and Operating Limits), on and after June 14, 2002, which is the compliance date for the National Emission Standards for Hazardous Air Pollutants (NESHAP) from the Portland Cement Manufacturing Industry, the visible emissions from the raw mill facilities, the kiln #1 feed system (EU19), the kiln #2 feed system (EU26), the coal (crusher) mill #1 (EU66), the coal (crusher) mill #2 (EU67), the fuel oil-fired air heater for kiln #1 coal mill (EU68), the fuel oil-fired air heater for kiln #2 coal mill (EU69), the kiln #2 coal dust silo (EU149), the kiln #2 coal weigh system (EU150), and the kiln #2 coal handling system (EU151) shall not exceed ten percent (10%) opacity.

D.3.6 Determinations of Nonapplicability [40 CFR 60, Subparts A and F] The raw mill facilities (EU09 through EU15, EU 17, and EU107 through EU109), the kiln #2 (EU27) and associated preheater unit, alkali bypass (EU28), and kiln #2 feed system (EU26), the clinker cooler #2 (EU29), and the coal handling, milling, and storage facilities (EU67, EU69, EU149, EU150, and EU151) are not subject to the requirements of the New Source Performance Standards (NSPS), 40 CFR 60, Subparts A and F (Standards of Performance for Portland Cement Plants) because the requirements of the NESHAP 40 CFR 63 Subpart LLL superseded the requirements of the NSPS on June 14, 2002. The kiln #1 system, the kiln #1 feed system (EU19), the clinker cooler #1 (EU22), the coal crusher mill #1 (EU66), and the fuel oil-fired air heater for kiln #1 (EU68) are not subject to the requirements of the New Source Performance Standards (NSPS), 40 CFR 60, Subparts A and F (Standards of Performance for Portland Cement Plants) because they were constructed prior to the applicability date of August 17, 1971.

D.3.7 NOx Emissions [326 IAC 10-1] [326 IAC 10-3] Pursuant to 326 IAC 10-3, beginning on May 31, 2004, the requirements of paragraph (a) below shall apply during the ozone control period of each year. Pursuant to 326 IAC 10-1, at all other times, the requirements of paragraph (b) below shall apply. The requirements of paragraph (c) below shall apply at all times.

(a) Pursuant to 326 IAC 10-3, kiln #2 shall be equipped with low-NOx burners.

(b) Pursuant to 326 IAC 10-1, NOx emissions from the dry preheater rotary cement kiln #2 (EU27) shall not exceed 5.9 pounds per ton of clinker produced on an operating day basis and 4.4 pounds per ton clinker produced on a thirty (30) day rolling average basis.

(c) Pursuant to 326 IAC 10-1, NOx emissions from the long dry rotary cement kiln #1 (EU20) shall not exceed 10.8 pounds per ton of clinker produced on an operating day basis and six (6.0) pounds per ton of clinker produced on a thirty (30) day rolling average.

D.3.8 NSPS for Coal Preparation Plants [326 IAC 12] [40 CFR 60, Subpart Y] (a) The provisions of 40 CFR Part 60, Subpart A - General Provisions, which are incorporated by reference in 326 IAC 12-1, apply to the facilities listed in paragraph (b)ESSROC Cement Corporation Page 58 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore
below, and as described in this section except when otherwise specified in 40 CFR Part 60, Subpart Y.

(b) 

### Pursuant to 40 CFR 60, Subpart Y, the fo llowing conditions shall apply to the coal handling, milling, and storage facilities, including the coal (crusher) mill #2 (EU67), and the fuel oil-fired air heater for kiln #2 (EU69):

(1) The opacity from each of these fa cilities shall be less than 20 percent.

(2) The particulate matter emissions from the coal (crusher) mill #2 (EU67) shall not exceed 0.031 grains per dry standard cubic foot of exhaust air (0.070 g/dscm).

(3) The Permittee shall install, calibrate, maintain, and continuously operate a monitoring device for the measurement of the temperature of the gas stream at the exit of the coal (crusher) mill #2 (EU67) on a continuous basis. The monitoring device is to be certified by the manufacturer and be accurate within plus or minus 3 degrees Fahrenheit. The monitoring device shall be recalibrated annually in accordance with the procedures specified in 40 CFR 60.13(b).

D.3.9 Preventive Maintenance Plan [326 IAC 2- 7-5(13)] [326 IAC 10-3] [40 CFR 63, Subpart LLL] A Preventive Maintenance Plan, in accordance wi th Section B - Preventive Maintenance Plan, of this permit, is required for all of the control devices listed in this section, and for the kilns and clinker coolers.

Compliance Determination Requirements

D.3.10 Testing Requirements [40 CFR 63, Subpart LLL] [326 IAC 20-27-1][326 IAC 2-7-6(1)(6)] [326 IAC 2-1.1-11] (a) The Permittee shall test kiln #1 (EU20), kiln #2 (EU27) and associated preheater, kiln #2 alkali bypass (EU28), clinker cooler #1 (EU22), clinker cooler #2 (EU29), kiln feed system #1 (EU19), kiln feed system #2 (EU26), kiln #2 coal dust silo (EU149), kiln #2 coal weigh system (EU150), and kiln #2 coal handling system (EU151) for PM emissions in order to demonstrate compliance with Conditions D.3.1 and D.3.2, utilizing methods as approved by the Commissioner. These tests shall be conducted within 180 days after the issuance of this Part 70 permit, or within 2.5 years after the last valid compliance demonstration, whichever is later. The tests to demonstrate compliance with Condition D.3.1 shall be repeated at least every 2.5 years from the date of this valid compliance demonstration. These tests shall be conducted in accordance with Section C - Performance Testing. All associated facilities exhausting to a single stack must all be operating when determining compliance with the limit.

(b) 

### Within 180 days after the issuance of this Part 70 permit the Permittee shall conduct a Method 5 stack test to determine compliance with the particulate matter emission limit for the coal (crusher) mill #2 (EU67) in C ondition D.3.8. The Permittee shall conductMethod 9 opacity tests to determine compliance with the opacity limits for the fuel oilfired air heater for kiln #2 coal mill (EU69) in Condition D.3.8. These tests shall be conducted in accordance with Section C - Performance Testing.

(c) No later than 180 days after June 14, 2002, which is the compliance date for the Portland Cement Manufacturing Industry NESHAP, the Permittee shall demonstrate initial compliance with the opacity limits established in Condition D.3.5(c) for the kiln #1 feed system (EU19), the kiln #2 feed system (EU26), the coal (crusher) mill #1 (EU66), the coal (crusher) mill #2 (EU67), the fuel oil-fired air heater for kiln #1 coal mill (EU68), the fuel oil-fired air heater for kiln #2 coal mill (EU69), the kiln #2 coal dust silo (EU149), the kiln #2 coal weigh system (EU150), and the kiln #2 coal handling system (EU151) byESSROC Cement Corporation Page 59 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore
conducting performance tests in accordance with 40 CFR 63.1349, Method 9 of 40 CFR Part 60, Appendix A, and Section C- Performance Testing. These tests shall be conducted in accordance with Section C - Performance Testing.

(d) No later than 180 days after June 14, 2002, which is the compliance date for the Portland Cement Manufacturing Industry NESHAP, the Permittee shall demonstrate initial compliance with the PM and opacity limits established in Condition D.3.5(b) for clinker cooler #1 and clinker cooler #2 by conducting performance tests in accordance with 40CFR 63.1349, Methods 5 and 9 of 40 CFR Part 60, Appendix A, and Section CPerformance Testing. These tests shall be repeated at least once every 5 years from the date of this valid compliance demonstration. These tests shall be conducted in accordance with Section C - Performance Testing.

(e) No later than 180 days after June 14, 2002, which is the compliance date for the Portland Cement Manufacturing Industry NESHAP, the Permittee shall demonstrate initial compliance with the PM, opacity and dioxin/furan limits established in Condition D.3.5(a) for kiln #1 and kiln #2 by conducting performance tests in accordance with 40 CFR 63.1349 and Methods 5, 9 and 23 of 40 CFR Part 60, Appendix A, respectively and Section C - Performance Testing. These tests shall be repeated at least once every 5 years from the date of this valid compliance demonstration. The Permittee is also required to repeat the performance tests for particulate matter and dioxins/furans within 90 days of initiating any significant change in the feed or fuel from that used in the previous test. These tests shall be conducted in accordance with Section C - Performance Testing.

(f) During each stack test required above, the following items shall be performed:

(1) Certified continuous opacity monitoring (COM) data shall be observed and recorded or EPA Method 9 opacity tests shall be performed.

(2) The kiln temperature and oxygen concentration shall be measured and recorded.

(3) The clinker production rate shall be measured and recorded.

(4) Pursuant to 326 IAC 3-6-3(b)(2) and 40 CFR 63.7(e), the tests shall be conducted under representative operating conditions.

(5) Pursuant to 326 IAC 3-6-3(b), during the performance tests, each kiln and clinker cooler must be operating at 95 percent of its maximum production capacity or more, or under other capacities or conditions specified and approved by IDEM, to be considered a valid test.

D.3.11 Particulate Matter (PM) Except as otherwise provided by statute, rule, or this permit, in order to comply with Conditions D.3.1, D.3.2, D.3.5, and D.3.8, the following conditions shall apply:

(a) The baghouse 209 for PM control shall be in operation at all times and control emissions from the kiln #1 feed system when the kiln #1 feed system is in operation.

(b) The baghouse 221 for PM control shall be in operation at all times and control emissions from the kiln #1 when the kiln #1 is in operation.

(c) The baghouse 231 for PM control shall be in operation at all times and control emissions from the kiln #2 feed system when the kiln #2 feed system is in operation.

(d) The electrostatic precipitators ESP15 and ESP16 for PM control shall be in operation atESSROC Cement Corporation Page 60 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore

all times and control emissions from the kiln #2 and raw mill when the kiln #2 or the raw mill is in operation.

(e) The baghouse 232 for PM control shall be in operation at all times and control emissions from the kiln #2 alkali bypass when the kiln #2 alkali bypass is in operation.

(f) The baghouse 222 for PM control shall be in operation at all times and control emissions from the clinker cooler #1 when the clinker cooler #1 is in operation.

(g) The baghouse 17 for PM control shall be in operation at all times and control emissions from the clinker cooler #2 when the clinker cooler #2 is in operation.

(h) Each baghouse or filter controlling any of the coal handling, milling, and storage facilities shall be in operation at all times when the associated facility is in operation.

D.3.12 Sulfur Dioxide Emissions and Sulfur Content [326 IAC 2-7-5(A)] [326 IAC 2-7-6] Pursuant to 326 IAC 7-2, the Permittee shall demonstrate that the sulfur dioxide emissions from coal combustion or simultaneous combustion of coal and oil, do not exceed six (6.0) pounds per MMBtu. Pursuant to 326 IAC 7-2, compliance with the limit in Condition D.3.3 shall be determined utilizing one of the following methods:

(a) Coal sampling and analysis shall be performed using one of the following procedures:

(1) Minimum Coal Sampling Requirements and Analysis Methods [326 IAC 3-7- 2(b)(3)]:

(A) The coal sample acquisition point shall be at a location where representative samples of the total coal flow to be combusted by the facility or facilities may be obtained. A single as-bunkered or as-burned sampling station may be used to represent the coal to be combusted by multiple facilities using the same stockpile feed system;

(B) Coal shall be sampled at least three (3) times per day and at least one (1) time per eight (8) hour period unless no coal is bunkered during the preceding eight (8) hour period;

(C) Minimum sample size shall be five hundred (500) grams;

(D) Samples shall be composited and analyzed at the end of each calendar month;

(E) Preparation of the coal sample, heat content analysis, and sulfur content analysis shall be determined pursuant to 326 IAC 3-7-2(c), (d), and (e); or

(2) Sample and analyze the coal pursuant to 326 IAC 3-7-2(a). Preparation of the coal sample heat content analysis, and sulfur content analysis shall be determined pursuant to 326 IAC 3-7-2(c), (d), and (e);

(3) Sample and analyze the coal pursuant to 326 IAC 3-7-3; or

(b) Compliance may also be determined by conducting a stack test for sulfur dioxide emissions from the kilns, in accordance with 326 IAC 3-6, utilizing the procedures in 40 CFR 60, Appendix A, Method 6, 6A, 6C, and 8. [326 IAC 7-2-1(d)]

(c) Upon written notification to IDEM by a facility owner or operator, continuous emission monitoring data collected and reported pursuant to 326 IAC 3-5-1 may be used as theESSROC Cement Corporation Page 61 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore
means for determining compliance with the emission limitations in 326 IAC 7-2. Upon such notification, the other requirements of 326 IAC 7-2 shall not apply. [326 IAC 7-2-1(g)]

A determination of noncompliance pursuant to any of the methods specified in (a) or (b) above shall not be refuted by evidence of compliance pursuant to the other method.

D.3.13 Sulfur Dioxide Emissions and Sulfur Content [326 IAC 2-7-5(A)] [326 IAC 2-7-6] 

### Compliance with the limit in Condition D.3.3(b) and (c) shall be determined utilizing one of the following options.

(a) Pursuant to 326 IAC 3-7-4, the Permittee shall demonstrate that the sulfur dioxide emissions do not exceed five-tenths (0.5) pounds per million Btu heat input by:

(1) Providing vendor analysis of fuel delivered, if accompanied by a vendor certification, or;

(2) Analyzing the oil sample to determine the sulfur content of the oil via the procedures in 40 CFR 60, Appendix A, Method 19.

(A) Oil samples may be collected from the fuel tank immediately after the fuel tank is filled and before any oil is combusted; and

(B) If a partially empty fuel tank is refilled, a new sample and analysis would be required upon filling.

(b) Compliance may also be determined by conducting a stack test for sulfur dioxide emissions from each of the kilns and heaters, using 40 CFR 60, Appendix A, Method 6 in accordance with the procedures in 326 IAC 3-6.

A determination of noncompliance pursuant to any of the methods specified in (a) or (b) above shall not be refuted by evidence of compliance pursuant to the other method.

D.3.14 Continuous Emissions Monitoring [326 IAC 3-5] [326 IAC 2-7-6(1),(6)] [40 CFR 63, Subpart LLL] [326 IAC 10-1] [326 IAC 10-3] (a) Pursuant to 326 IAC 3-5 (Continuous Monitoring of Emissions), 326 IAC 2-1.1-11 and 40 CFR Part 63.1350 a continuous monitoring system shall be installed, calibrated, maintained, and operated for measuring the opacity from each of the kilns, pursuant to 326 IAC 3-5. The continuous monitoring system shall be installed and operational prior to conducting the performance tests required in Condition D.3.10.

(b) Pursuant to 326 IAC 3-5 (Continuous Monitoring of Emissions), 326 IAC 2-1.1-11, 40 CFR Part 63, a continuous monitoring system shall be installed, calibrated, maintained, and operated for measuring opacity from both of the clinker coolers.

(c) The continuous monitoring systems shall meet the performance specifications of 326 IAC 3-5-2, and shall demonstrate continuous compliance with Section C - Opacity, and Conditions D.3.5(a)(3) and (b)(2) and D.3.8(b).

(d) The continuous opacity monitoring systems shall meet the performance specifications of 326 IAC 3-5-2 and 40 CFR 63.8(c).

(e) Pursuant to 326 IAC 10-1 and 326 IAC 10-3, compliance with the NOx limits for the kilns in Condition D.3.7, 326 IAC 10-1, and 326 IAC 10-3 shall be demonstrated by installing and operating a NOx continuous emissions monitor (CEM) for each stack exhausting kiln emissions. The NOx CEMs shall be certified according to procedures contained in 326 IAC 3 and 40 CFR 75 as applicable. IDEM has information that indicates that kiln #1ESSROC Cement Corporation Page 62 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore
(EU20) is not in compliance with the requirement to certify the NOx CEM as required by this condition. The OAQ will promptly reopen this permit using the provisions of 326 IAC 2-7-9 (Permit Reopening) to include detailed requirements necessary to comply with this rule and a schedule for achieving compliance with such requirements.

(f) In order for kiln #2 to come into compliance with the requirements of 326 IAC 10-1, the Permittee shall install, calibrate, maintain, and operate a NOx continuous emissions monitor (CEM) on the stack identified as EP23 for the elevator/dust tank (alkali bypass) identified as EU28 on kiln #2, within 12 months after the date of issuance of this permit. The NOx CEMs shall be certified according to procedures contained in 326 IAC 3 and 40 CFR 75 as applicable.

(g) 

### In the event that a nitrogen oxide CEMS fails, the Permittee shall monitor the oxygen content and temperature of the kiln exhaus t at least once per hour. If the oxygen content or temperature is outside the range established in the latest compliance stack test, the Permittee shall take reasonable re sponse steps in accordance with Section C - Compliance Response Plan - Preparation, Implementation, Records, and Reports. Failure to take response steps in accordance with Section C - Compliance Response Plan - Preparation, Implementation, Records, and Reports, shall be considered a deviation from this permit.

D.3.15 NESHAP Monitoring Requirements [40 CFR 63, Subpart LLL][326 IAC 20-27-1] (a) Pursuant to 40 CFR 63.1350 (Monitoring Requirements), on and after June 14, 2002, which is the compliance date for the National Emission Standards for Hazardous Air Pollutants (NESHAP) from the Portland Cement Manufacturing Industry, the Permittee shall perform the following monitoring requirements:

(1) The Permittee shall have prepared written operations and maintenance plans for kiln #1, kiln #2, clinker cooler #1, and clinker cooler #2. The plans shall include the following information:

(A) Procedures for proper operation and maintenance of kiln #1, kiln #2, clinker cooler #1, clinker cooler #2, and all associated air pollution control device(s) in order to meet the emissions limits in Condition D.3.5; and

(B) Procedures to be used during an inspection of the components of the combustion system of kiln #1 and kiln #2 at least once per year.

Failure to comply with any provision of the operations and maintenance plan shall be a violation of the standard.

(2) The Permittee shall conduct an inspection of the components of the combustion system of kiln #1 and kiln #2 at least once per year.

(3) The Permittee shall continuously monitor opacity of emissions at the outlet of the PM control device for the kiln #1, kiln #2, clinker cooler #1, and clinker cooler #2. The COMs required by Condition D.3.14 shall be used to monitor opacity emissions in accordance with the NESHAP and shall be installed, maintained, calibrated and operated as required by 40 CFR 63, Subpart A and according to 40 CFR 60, Appendix B, PS-1.

(4) The Permittee shall install, calibrate, maintain, and continuously operate a continuous monitor to record the temperature of the exhaust gases from kiln #1 and kiln #2 at the inlet to, or upstream of the kiln’s PM control device.

(A) The recorder response range must include zero and 1.5 times either ofESSROC Cement Corporation Page 63 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore
the average temperatures established according to the requirements in 40 CFR 63.1349(b)(3)(iv).

(B) The reference method must be a National Institute of Standards and Technology calibrated reference thermocouple-potentiometer system or alternate reference, subject to approval by the Administrator.

(C) The three-hour rolling average temperature shall be calculated as the average of 180 successive one-minute average temperatures.

(D) Periods of time when one-minute averages are not available shall be ignored when calculating three-hour rolling averages. When one-minute averages become available, the first one-minute average is added to the previous 179 values to calculate the three-hour rolling average.

(E) The calibration of all thermocouples and other temperature sensors shall be verified at least once every three months.

(b) Pursuant to 40 CFR 63.1350 (Monitoring Requirements), the Permittee shall prepare a written operations and maintenance plan for the kiln #1 feed system (EU19), the kiln #2 feed system (EU26), the coal (crusher) mill #1 (EU66), the coal (crusher) mill #2 (EU67), the fuel oil-fired air heater for kiln #1 coal mill (EU68), the fuel oil-fired air heater for kiln #2 coal mill (EU69), the kiln #2 coal dust silo (EU149), the kiln #2 coal weigh system (EU150), and the kiln #2 coal handling system (EU151) by June 14, 2002, which is the compliance date for the National Emission Standards for Hazardous Air Pollutants (NESHAP) from the Portland Cement Manufacturing Industry. The plan shall include the following information:

(1) Procedures for proper operation and maintenance of the affected sources and associated air pollution control device(s) in order to meet the emissions limit in Condition D.3.5; and

(2) Procedures to be used to periodically monitor the facilities listed in this section, which are subject to opacity standards under 40 CFR 63.1348. Such procedures must include the following provisions:

(A) The Permittee shall conduct a monthly 1-minute visible emissions test of each affected source, in accordance with 40 CFR 60, Appendix A, Method 22. The test must be conducted while the affected source is in operation.

(B) If no visible emissions are observed in six consecutive monthly tests for any affected source, the Permittee may decrease the frequency of testing from monthly to semi-annually for that affected source. If visible emissions are observed during any semi-annual test, the Permittee shall resume testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests.

(C) If no visible emissions are observed during the semi-annual test for any affected source, the Permittee may decrease the frequency of testing from semi-annually to annually for that affected source. If visible emissions are observed during any annual test, the Permittee shall resume testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests.ESSROC Cement Corporation Page 64 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore
(D) If visible emissions are observed during any Method 22 test, the Permittee must conduct a 6-minute test of opacity in accordance with 40 CFR 60, Appendix A, Method 9. The Method 9 test must begin within one hour of any observation of visible emissions.

(3) Corrective actions to be taken when required by paragraph (b).

Failure to comply with any provision of the operations and maintenance plan shall be a violation of the standard.

(c) Pursuant to 40 CFR 63.1350 (Monitoring Requirements), the Permittee shall monitor opacity from the raw mills by conducting daily visual emissions observations of the mill sweep and air separator particulate matter control devices (PMCDs), in accordance with the procedures of 40 CFR 60, Appendix A, Method 22. The Method 22 test shall be conducted while the affected source is operating at the representative performance conditions. The duration of the Method 22 test shall be six minutes. If visible emissions are observed during any Method 22 visible emissions test, the Permittee must initiate, within one (1) hour, the corrective actions specified in the site specific operations and maintenance plan developed in accordance with 40 CFR 63.1350(a)(1) and (a)(2); and conduct a follow-up Method 22 test. If visible emissions are observed, then within 24 hours of the end of the Method 22 test in which the visible emissions were observed, the Permittee must conduct a followup Method 22 test of each stack from which visible emissions were observed during the previous Method 22 test. If visible emissions are observed during the followup Method 22 test, the Permittee must conduct a visual opacity test of each stack from which visible emissions were observed during the followup Method 22 test, in accordance with 40 CFR 60, Appendix A, Method 9. The duration of the Method 9 test shall be thirty (30) minutes.

Compliance Monitoring Requirements [326 IAC 2-7-6(1)] [326 IAC 2-7-5(1)]

D.3.16 

### Transformer-Rectifier (T-R) Sets [326 IAC 2-7-6(1)] [326 IAC 2-7-5(1)] (a) The ability of the ESP to control particulate emissions shall be monitored once per shift, when the unit is in operation, by measuring and recording the number of T-R sets in service and the primary and secondary voltages and the currents of the transformerrectifier (T-R) sets.

(b) Reasonable response steps shall be taken in accordance with Section C - Compliance Response Plan - Preparation, Implementation, Records, and Reports whenever the percentage of T-R sets in service falls below 90 percent (90%). T-R set failure resulting in less than 90 percent (90%) availability is not a deviation from this permit. Failure to take response steps in accordance with Section C - Compliance Response Plan - Preparation, Implementation, Records, and Reports, shall be considered a deviation from this permit.

D.3.17 Opacity Readings The ability of each ESP and baghouse to control particulate emissions from the kilns and clinker coolers shall be monitored by continuously measuring and recording the opacity of emissions from the stack exhausts. The opacity shall be determined by the certified continuous opacity monitor required in Condition D.3.14.



### (a) Whenever a continuous opacity monitor (C OM) is malfunctioning or will be down for calibration, maintenance, or repairs for a period of one (1) hour or more, compliance with the applicable opacity limits shall be demonstrated by the following:

(1) Visible emission (VE) notations s hall be performed once per hour during daylight operations following the shutdown or malf unction of the primary COM. A trainedESSROC Cement Corporation Page 65 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore


### employee shall record whether emissions are normal or abnormal for the state of operation of the emission unit at the time of the reading.

(A) A trained employee is an employee who has worked at the plant at least one (1) month and has been trained in the appearance and characteristics of normal visible em issions for that specific process.

(B) If abnormal emissions are noted during two consecutive emission notations, the Permittee shall begin Method 9 opacity observations within four hours of the second abnormal notation.

(C) VE notations may be discontinued once a COM is online or formal Method 9 readings have been implemented.

(2) If a COM is not online within twenty-f our (24) hours of shutdown or malfunction of the primary COM, the Permittee shall provide certified opacity reader(s), who may be employees of the Permittee or independent contractors, to self-monitor the emissions from the emission unit stack.

(A) Visible emission readings sha ll be performed in accordance with 40 CFR 60, Appendix A, Method 9, for a minimum of five (5) consecutive six (6) minute averaging periods beginning not more than twenty-four (24) hours after the start of the malfunction or down time.

(B) Method 9 opacity readings shall be repeated for a minimum of five (5) consecutive six (6) minute averaging per iods at least once every four (4) hours during daylight operations, until such time that a COM is in operation.

(C) Method 9 readings may be discontinued once a COM is online.

(D) Any opacity exceedances determi ned by Method 9 readings shall be reported with the Quarterly Opacity Exceedances Reports.

(3) If abnormal emissions are observed, the Permittee shall take reasonable response steps in accordance with Se ction C - Compliance Response Plan - Preparation, Implementation, Records, and Reports. Observation of abnormal emissions that do not violate an applicable opacity limit is not a deviation from this permit. Failure to take response steps in accordance with Section C - Compliance Response Plan - Preparation, Implementation, Records, and Reports, shall be considered a deviation from this permit.

(b) Nothing in this permit shall excuse the Permittee from complying with the requirements to operate a continuous opacity monitoring system pursuant to 326 IAC 3-5 and 40 CFR 63, Subpart LLL.

D.3.18 Method 9 Opacity Readings and Visible Emissions Notations 

### The emission units and associated baghouses for which continuous opacity monitors are not used shall comply with the following requirements:

(a) Visible emission notations of the baghouse stack exhausts shall be performed once per shift during normal daylight operations when exhausting to the atmosphere. A trained employee shall record whether emissions are present.

(b) For processes operated continuously, "norma l" means those conditions prevailing, orESSROC Cement Corporation Page 66 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore


### expected to prevail, eighty percent (80%) of the time the process is in operation, not counting startup or shut down time.

(c) In the case of batch or discontinuous oper ations, readings shall be taken during that part of the operation that would normally be ex pected to cause the greatest emissions.

(d) A trained employee is an employee who has worked at the plant at least one (1) month and has been trained in the appearance and characteristics of normal visible emissions for that specific process.

(e) If visible emissions are present at any baghouse stack for which a COM is not required, the Permittee shall implement the appropriate procedures as set out in its Compliance Response Plan for such facility. 

### Failure to take response steps in accordance with Section C - Compliance Response Plan - Preparation, Implementation, Records, and Reports, shall be considered a devia tion from this permit.

D.3.19 Baghouse Parametric Monitoring The Permittee shall record the total static pressure drop across each baghouse, at least once per shift when the associated facility is in operation. When for any one reading, the pressure drop across a baghouse is outside the normal range of 1.0 to 8.0 inches of water or the range established during the most recent stack test, the Permittee shall take reasonable response steps in accordance with 

### Section C - Compliance Response Plan - Preparation, Implementation, Records, and Reports . A pressure reading that is outside the normal range is not a deviation from this permit. 

### Failure to take response steps in accordance with Section C - Compliance Response Plan - Preparation, Implementation, Records, and Reports, shall be considered a deviation from this permit.

The instruments used for determining the pressure shall comply with Section C - Pressure Gauge and Other Instrument Specifications, of this permit, shall be subject to approval by IDEM, OAQ, and shall be calibrated at least once every six (6) months.

D.3.20 Baghouse and ESP Inspections (a) An inspection shall be performed each calendar quarter of all bags controlling the facilities listed in this section. Inspections required by this condition shall not be performed in consecutive months. All defective bags shall be replaced.

(b) In order to document compliance with the applicable PM and dioxin/furan limits specified in Condition D.3.5 the following inspections shall be performed for each ESP during each annual shutdown, but no less often than once every 14 months, in accordance with the Preventive Maintenance Plan prepared in accordance with Section B - Preventive Maintenance Plan:

(1) Plate and electrode alignment; (2) ESP component/controller failure; (3) Air and water infiltration; and (4) Calibration of the instruments used to determine the T-R set current and voltages.

All inspections shall be made whenever there is an outage of any nature lasting more than three days unless such measurements have been taken within the past three months.

Appropriate response steps for any failures, malfunctions, or abnormal conditions in the above list found during the inspection shall be taken in accordance with Section C - Compliance Response Plan - 

### Preparation, Implementation, Records, and Reports

. 

### Failure to take response steps in accordance with Section C - Compliance Response Plan - Preparation, Implementation, Records, and Reports, shall be considered aESSROC Cement Corporation Page 67 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore


### deviation from this permit.

D.3.21 Broken or Failed Bag Detection In the event that bag failure has been observed.

(a) 

### For multi-compartment units, the affected compartments will be shut down immediately until the failed units have been repaired or replaced. Within eight (8) business hours of the determination of failure, response steps according to the timetable described in the Compliance Response Plan shall be initiated. For any failure with corresponding response steps and timetable not described in the Compliance Response Plan, response steps shall be devised within eight (8) business hours of discovery of the failure and shall include a timetable for completion. Failure to take response steps in accordance with Section C - Compliance Response Plan - Preparation, Implementation, Records, and Reports, shall be consi dered a deviation from this permit. If operations continue after bag failure is observed and it will be 10 days or more after the failure is observed before the failed units will be repaired or replaced, the Permittee shall promptly notify the IDEM, OAQ of the expected date the failed units will be repaired or replaced. The notification shall also include the status of the applicable compliance monitoring parameters with respect to normal, and the results of any response actions taken up to the time of notification.

(b) 

### For single compartment baghouses, if failure is indicated by a significant drop in the baghouse’s pressure readings with visible emissi ons present or the failure is indicated by an opacity violation, or if bag failure is determined by other means, such as gas temperatures, flow rates, air infiltration, l eaks, dust traces or triboflows, then the failed units and the associated process will be shut down immediately until the failed units have been repaired or replaced. Operations may continue only if the event qualifies as an emergency and the Permittee satisfies the requirements of the emergency provisions of this permit (Section B - Emergency Provisions).

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-19]

D.3.22 Record Keeping Requirements (a) To document compliance with Condition D.3.3, D.3.12 and D.3.13, the Permittee shall maintain records in accordance with (1) through (4) below. Records maintained for (1) through (4) shall be taken on a calendar month average and shall be complete and sufficient to establish compliance with the SO 2 emission limits established in Condition D.3.3.

(1) Calendar dates covered in the compliance determination period;

(2) Actual coal and oil usages since last compliance determination period;

(3) Sulfur content and heat content of both coal and oil used;

(4) Sulfur dioxide emission rates.

(b) Pursuant to 326 IAC 3-7-5(a), the Permittee shall develop a standard operating procedure (SOP) to be followed for sampling, handling, analysis, quality control, quality assurance, and data reporting of the information collected pursuant to 326 IAC 3-7-2 through 326 IAC 3-7-4. In addition, any revision to the SOP shall be submitted to IDEM, OAQ.

(c) To document compliance with Conditions D.3.14 through D.3.20, the Permittee shall maintain records in accordance with (1) through (9) below. Records shall be complete and sufficient to establish compliance with the limits established in this section.ESSROC Cement Corporation Page 68 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore
(1) Data and results from the most recent stack tests.

(2) All continuous emissions monitoring data.

(3) All ESP voltage and current monitoring readings as required by Condition D.3.16.

(4) The results of all baghouse and ESP inspections and the type and number of parts replaced.

(5) Visible emission notations once per shift for all baghouses.

(6) Method 9 opacity readings for the kilns and clinker coolers whenever required by this permit.

(7) 

### Once per shift records of the pressure drop of each baghouse during normal operation when venting to the atmosphere.

(8) All preventive maintenance measures taken.

(9) All response steps taken and the outcome for each.

(d) To document compliance with the NESHAP 40 CFR 63, Subpart LLL, the Permittee shall maintain all records required by 40 CFR 63.1355. These records include the following:

(1) The Permittee shall maintain files of all information (including all reports and notifications) required by 40 CFR 63.1355(a) recorded in a form suitable and readily available for inspection and review as required by 40 CFR 63.10(b)(1).

(2) The Permittee shall maintain records for each affected source as required by 40 CFR 63.10(b)(2) and (3) including:

(I) All documentation supporting initial notifications and notifications of compliance status under 40 CFR 63.9.

(II) All records of applicability determination, including supporting analyses.

(3) The Permittee shall maintain all records of continuous monitoring system data required by 40 CFR 63.10(c).



### (e) In order to document compliance with Condition D.3.5(a)(4), (5), and (6), the Permittee shall keep records of all times when the raw mill is in operation and all times when the kiln #2 is in operation.

(f) To document compliance with 40 CFR 60.250, NSPS, Subpart Y, the Permittee shall maintain records of the monitoring device measurements of the temperature of the gas stream at the exit of the thermal dryer on a continuous basis. Records shall be complete and sufficient to establish compliance with the requirements of Subpart Y.

(g) To document compliance with Condition D.3.9, the Permittee shall maintain of records of any additional inspections prescribed by the Preventive Maintenance Plan.

(h) All records shall be maintained in accordance with Section C - General Record Keeping Requirements, of this permit.

D.3.23 Reporting Requirements (a) A quarterly summary of the information to document compliance with the SO 2 limitsESSROC Cement Corporation Page 69 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore
specified in Condition D.3.3 shall be submitted to the address listed in Section C - General Reporting Requirements, of this permit, using the reporting forms located at the end of this permit, or its equivalent, within thirty (30) days after the end of the quarter being reported. These reports submitted by the Permittee do require the certification by the “responsible official” as defined by 326 IAC 2-7-1(34).

(b) Pursuant to 326 IAC 10-1 and 326 IAC 10-3, CEM performance evaluation reports shall be submitted each calendar quarter.

(c) Pursuant to 326 IAC 10-1, the source shall notify the OAQ at least thirty (30) days prior to the addition or modification of a facility that may result in a potential increase in NOx emissions.

(d) Pursuant to 326 IAC 10-1, the source may comply with the reporting requirements of 326 IAC 10-1 by submitting to the OAQ a substitute report. A substitute report is a report that satisfies an applicable state or federal reporting requirement and contains the information required to be submitted by this rule.

(e) A quarterly summary of excess opacity emissions, as defined in 326 IAC 3-5-7, from the continuous monitoring system, shall be submitted to the address listed in Section C - General Reporting Requirements, of this permit, within thirty (30) days after the end of the quarter being reported. The excess opacity summary shall also be submitted in accordance with 40 CFR 63.1354(8) (beginning June 14, 2002).

(f) Beginning June 14, 2002, the Permittee shall submit a continuous monitoring system (CMS) performance report with the excess opacity summaries, in accordance with 40 CFR 63.1354(8) and 40 CFR 63, Subpart A.

(g) Beginning June 14, 2002, the Permittee shall submit a semi-annual summary report which contains the information specified in 40 CFR 63.10(e)(3)(vi), as well as the following:

(1) All exceedances of maximum control device inlet gas temperature limits specified in Condition D.3.5.

(2) All failures to calibrate thermocouples and other temperature sensors as required under 40 CFR 63.1350(f)(7).

(3) The results of any combustion system component inspections conducted within the reporting period as required by Condition D.3.15.

(4) All failures to comply with any provision of the operation and maintenance plan developed in accordance with 40 CFR 63.1350(a).

If the total continuous monitoring system (CMS) downtime for any CEM or any CMS for the reporting period is ten percent or greater of the total operating time for the reporting period, the Permittee shall submit an excess emissions and CMS performance report along with the summary report.

(h) To document compliance with the NESHAP 40 CFR 63, Subpart LLL, the Permittee shall report the information required by 40 CFR 63.1354, including, but not limited to the following:

(1) The plan required by Condition D.3.15 shall be submitted to IDEM, OAQ and U.S. EPA by June 14, 2002, which is the compliance date for the National Emission Standards for Hazardous Air Pollutants (NESHAP) from the Portland CementESSROC Cement Corporation Page 70 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore
Manufacturing Industry.

(2) As required by 40 CFR 63.10(d)(2), the Permittee shall report the results of performance tests as part of the notification of compliance status, required in Section C - NESHAP Notification and Reporting Requirements.

(3) As required by 40 CFR 63.10(d)(3), the Permittee shall report the opacity results from tests required by 40 CFR 63.1349.

(4) As required by 40 CFR 63.10(d)(5), if actions taken by the Permittee during a startup, shutdown, or malfunction of an affected source (including actions taken to correct a malfunction) are consistent with the procedures specified in the source’s startup, shutdown, and malfunction plan specified in 40 CFR 63.6(e)(3), the Permittee shall state such information in a semiannual report. Reports shall only be required if a startup, shutdown, or malfunction occurred during the reporting period. The startup, shutdown, and malfunction report may be submitted simultaneously with the excess emissions and continuous monitoring system performance reports.

(5) Pursuant to 40 CFR 63.10(d)(5)(ii), any time an action taken by the Permittee during a startup, shutdown, or malfunction (including actions taken to correct a malfunction) is not consistent with the procedures in the startup, shutdown, and malfunction plan, and the source exceeds any applicable emission limitation in the relevant emission standard, the Permittee shall report the actions taken for that event within 2 working days after commencing actions inconsistent with the plan, by telephone call to the OAQ Compliance Section at (317) 233-5674 or facsimile (FAX) transmission at (317) 233-6865. The immediate report shall be followed by a letter within 7 working days after the end of the event, certified by the Permittee, explaining the circumstances of the event, the reasons for not following the startup, shutdown, and malfunction plan, and whether any excess emissions and/or parameter monitoring exceedances are believed to have occurred.

(i) In addition to being submitted to the addr ess listed in Section C - General Reporting Requirements, all reports submitted pursuant to 40 CFR 63, Subpart A shall also be submitted to the U.S. EPA at the following address:

United States Environmental Protection Agency, Region V Air and Radiation Division, Regulation Development Branch - Indiana (AR-18J) 77 West Jackson Boulevard Chicago, Illinois 60604-3590

Pursuant to 40 CFR 63.10(d)(5)(i) and (ii), the reports submitted by the Permittee shall include the certification by the “responsible official” as defined by 326 IAC 2-7-1(34).ESSROC Cement Corporation Page 71 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore



### SECTION D.4 FACILITY OPERATION CONDITIONS

Facility Description [326 IAC 2-7-5(15)] Insignificant Activity 

### Degreasing operations Degreasing operations that do not exceed 145 gallons per 12 months, except if subject to 326 IAC 20- 6;

(The information describing the process contained in this facility description box is descriptive information and does not constitute enforceable conditions.)



### Emission Limitations and Standards [326 IAC 2-7-5(1)]

D.4.1 Volatile Organic Compounds (VOC) [326 IAC 8-3-2] Pursuant to 326 IAC 8-3-2 (Cold Cleaner Operati ons) for cold cleaning operations constructed after January 1, 1980, the Permittee shall:

(a) Equip the cleaner with a cover;

(b) Equip the cleaner with a facility for draining cleaned parts;

(c) Close the degreaser cover whenever parts are not being handled in the cleaner;

(d) Drain cleaned parts for at least fifteen (15) seconds or unt il dripping ceases;

(e) Provide a permanent, conspicuous label summarizing the operation requirements;

(f) Store waste solvent only in covered containers and not dispose of waste solvent or transfer it to another party, in such a manner that greater than twenty percent (20%) of the waste solvent (by weight) can evaporate into the atmosphere.

D.4.2 Volatile Organic Compounds (VOC) [326 IAC 8-3-5] (a) Pursuant to 326 IAC 8-3-5(a) (Cold Cleaner Degreaser Operation and Control), for a cold cleaner degreaser facility constructi on of which commenced after July 1, 1990, the Permittee shall ensure that the following control equipment requirements are met:

(1) Equip the degreaser with a cover. The cover must be designed so that it can be easily operated with one (1) hand if:

(A) The solvent volatility is greater than two (2) kiloPascals (fifteen (15) millimeters of mercury or three-t enths (0.3) pounds per square inch) measured at thirty-eight degrees Celsius (38 O 

### C) (one hundred degrees Fahrenheit (100 O 

### F));

(B) The solvent is agitated; or

(C) The solvent is heated.

(2) Equip the degreaser with a facility for draining cleaned articles. If the solvent volatility is greater than four and three-t enths (4.3) kiloPascals (thirty-two (32) millimeters of mercury or six-tenths (0.6) pounds per square inch) measured at thirty-eight degrees Celsius (38 O 

### C) (one hundred degrees Fahrenheit (100 O 

### F)), then the drainage facility must be internal such that articles are enclosed under the cover while draining. The drainage facility may be external for applications where an internal type cannot fit into the cleaning system.ESSROC Cement Corporation Page 72 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore



### (3) Provide a permanent, conspicuous label which lists the operating requirements outlined in subsection (b).

(4) The solvent spray, if used, must be a solid, fluid stream and shall be applied at a pressure which does not cause excessive splashing.

(5) Equip the degreaser with one (1) of the following control devices if the solvent volatility is greater than four and three-t enths (4.3) kiloPascals (thirty-two (32) millimeters of mercury or six-tenths (0.6) pounds per square inch) measured at thirty-eight degrees Celsius (38 O 

### C) (one hundred degrees Fahrenheit (100 O 

### F)),or if the solvent is heated to a temperature greater than forty-eight and ninetenths degrees Celsius (48.9 O 

### C) (one hundred twenty degrees Fahrenheit (120 O 

### F)):

(A) A freeboard that attains a freeboard ratio of seventy-five hundredths (0.75) or greater.

(B) A water cover when solvent is used is insoluble in, and heavier than, water.

(C) Other systems of demonstrated equivalent control such as a refrigerated chiller of carbon adsorption. Such systems shall be submitted to the U.S. EPA as a SIP revision.

(b) Pursuant to 326 IAC 8-3-5(b) (Cold Cleaner Degreaser Operation and Control), for a cold cleaning facility construction of which commenced after July 1, 1990, the Permittee shall ensure that the following operating requirements are met:

(1) Close the cover whenever articles are not being handled in the degreaser.

(2) Drain cleaned articles for at least fift een (15) seconds or until dripping ceases.

(3) Store waste solvent only in covered containers and prohibit the disposal or transfer of waste solvent in any manner in which greater than twenty percent (20%) of the waste solvent by weight could evaporate.

D.4.3 Material Requirements for Cold Cleaning Degreasers [326 IAC 8-3-8 ] 

### Pursuant to 326 IAC 8-3-8 (Organic Solvent Degr easing Operations: material requirements for cold cleaning degreasers), the fo llowing conditions shall apply:

(a) The source shall not operate a cold cl eaning degreaser with a solvent vapor pressure that exceeds one (1) millimeter of me rcury (nineteen-thousandths (0.019) pound per square inch) measured at twenty (20) degr ees Celsius (sixty-eight (68) degrees Fahrenheit).

(b) The source shall maintain the following records for each purchase:

(1) the name and address of the solvent supplier; (2) the date of purchase; (3) the type of solvent; (4) the volume of each unit of solvent; (5) the total volume of the solvent; and (6) the true vapor pressure of the solvent measured in millimeters of mercury atESSROC Cement Corporation Page 73 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore


### twenty (20) degrees Celsius (sixty -eight (68) degrees Fahrenheit).

D.4.4 Determinations of Nonapplicability [40 CFR 63.460 (Subpart T)] [40 CFR 60, Subparts A and F] [40 CFR 63, Subparts A and LLL] 

### (a) None of the parts washers specifically lis ted in this section are subject to the requirements of the National Emissions Standards for Hazardous Air Pollutants (NESHAP) 326 IAC 20-1, 40 CFR 63.460 (Subpart T) because they do not utilize a solvent containing methylene chloride, perchloroethylene, trichloroethylene, 1,1,1- trichloroethane, carbon tetrachloride, or ch loroform, or any combination of these halogens, in a total concentration great er than five percent by weight.

(b) The parts washers at this source are not subject to the requirements of the New Source Performance Standards (NSPS), 40 CFR 60, Subparts A and F (Standards of Performance for Portland Cement Plants) because they are not considered affected facilities under this rule.

(c) The parts washers at this source are not subject to the requirements of the National Emissions Standards for Hazardous Air Pollutants (NESHAP) 40 CFR 63 Subparts A and LLL, because they are not considered affected facilities under this rule.ESSROC Cement Corporation Page 74 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore

SECTION D.5 FACILITY OPERATION CONDITIONS

Facility Description [326 IAC 2-7-5(15)] Insignificant Activities

(a) underground conveyors; [326 IAC 6-1-2]

(b) coal bunker and coal scale exhausts and associated dust collector vents; [326 IAC 6-1-2]

(The information describing the process contained in this facility description box is descriptive information and does not constitute enforceable conditions.)

Emission Limitations and Standards [326 IAC 2-7-5(1)]

D.5.1 Particulate Matter (PM) [326 IAC 6-1-2] Pursuant to 326 IAC 6-1-2 (Nonattainment Area Particulate Limitations) the allowable PM emission rate from each of the underground conveyors, the coal bunker, and coal scale shall not exceed 0.03 grains per dry standard cubic foot of exhaust air.ESSROC Cement Corporation Page 75 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore


## INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR QUALITY COMPLIANCE DATA SECTION and IDEM Southwest Regional Office PART 70 OPERATING PERMIT CERTIFICATION

Source Name: ESSROC Cement Corporation Source Address: Highway 31, Speed, Indiana 47172 Mailing Address: Highway 31, Speed, Indiana 47172 Part 70 Permit No.: T019-6016-00008
This certification shall be included when submitting monitoring, testing reports/results or other documents as required by this permit.

Please check what document is being certified:

9 Annual Compliance Certification Letter

9 Test Result (specify)

9 Report (specify)

9 Notification (specify)

9 Affidavit (specify)

9 Other (specify)

I certify that, based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate, and complete.

Signature:

Printed Name:

Title/Position:

Phone:

Date:ESSROC Cement Corporation Page 76 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore


## INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR QUALITY

COMPLIANCE BRANCH

100 North Senate Avenue P.O. Box 6015 Indianapolis, Indiana 46206-6015 Phone: 317-233-5674

Fax: 317-233-5967 and IDEM Southwest Regional Office 208 Northwest 4 th 

### Street, Suite 201 Evansville, Indiana 47708 Phone: 812-436-2570

Fax: 812-436-2572



## PART 70 OPERATING PERMIT EMERGENCY OCCURRENCE REPORT

Source Name: ESSROC Cement Corporation Source Address: Highway 31, Speed, Indiana 47172 Mailing Address: Highway 31, Speed, Indiana 47172 Part 70 Permit No.: T019-6016-00008

This form consists of 2 pages Page 1 of 2

9 This is an emergency as defined in 326 IAC 2-7-1(12) C The Permittee must notify the Office of Air Quality (OAQ), within four ( 4 ) business hours (1-800-451-6027 or 317-233-5674, as k for Compliance Section); and C The Permittee must submit notice in writing or by facsimile within two ( 2 ) working days (Facsimile Number: 317-233-5967), and follow the other requirements of 326 IAC 2-7-16.

If any of the following are not applicable, mark N/A

Facility/Equipm ent/Operation:

Control Equipment:

Permit Condition or Operation Limitation in Permit:

Description of the Emergency:

Describe the cause of the Emergency:ESSROC Cement Corporation Page 77 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore


### If any of the following are not applicable, mark N/A Page 2 of 2

Date/Time Emergency started:

Date/Time Emergency was corrected:

Was the facility being properly operated at the time of the emergency? Y N Describe:

Type of Pollutants Emitted: TSP, PM-10, SO 2 

### , VOC, NO X 

### , CO, Pb, other:

Estimated amount of pollutant(s) emitted during emergency:

Describe the steps taken to mitigate the problem:

Describe the corrective actions/response steps taken:

Describe the measures taken to minimize emissions:

If applicable, describe the reasons why continued oper ation of the facilities are necessary to prevent imminent injury to persons, severe damage to equipment, substantial loss of capital investment, or loss of product or raw materials of substantial economic value:

Form Completed by:

Title / Position:

Date:

Phone:

A certification is not required for this report.ESSROC Cement Corporation Page 78 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore


## INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR QUALITY COMPLIANCE DATA SECTION

Part 70 Quarterly Report for Use When Com busting Only Coal

Source Name: ESSROC Cement Corporation Source Address: Highway 31, Speed, Indiana 47172 Mailing Address: Highway 31, Speed, Indiana 47172 Part 70 Permit No.: T019-6016-00008 Facility: Kilns #1 and 2 Parameter: Sulfur Dioxide (SO 2 

### ) Limit: 6.0 pounds per million Btu heat input

FACILITY: YEAR:

Month Monthly Average Coal Sulfur Content

(%) Monthly Average Coal Heat Content

(MMBtu/lb) Coal Consumption

(Tons) Equivalent Sulfur Dioxide Emissions

(lbs/MMBtu)



### 9 No deviation occurred in this quarter.

9 Deviation/s occurred in this quarter. Deviation has been reported on:

Submitted by: Title / Position: Signature: Date: Phone: Attach a signed certification to complete this report.ESSROC Cement Corporation Page 79 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore


## INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR QUALITY COMPLIANCE DATA SECTION

Part 70 Quarterly Report for Use When Combusting Only Fuel Oil

Source Name: ESSROC Cement Corporation Source Address: Highway 31, Speed, Indiana 47172 Mailing Address: Highway 31, Speed, Indiana 47172 Part 70 Permit No.: T019-6016-00008 Facility: Kilns #1 and 2 Parameter: Sulfur Dioxide (SO 2 

### ) from fuel oil combustion Limit: 0.5 pounds per million Btu heat input

FACILITY: YEAR:

Month Monthly Average Fuel Oil Sulfur Content

(%) Monthly Average Fuel Oil Heat Content

(MMBtu/lb) Fuel Oil Consumption

(Gallons) Equivalent Sulfur Dioxide Emissions

(lbs/MMBtu)



### 9 No deviation occurred in this quarter.

9 Deviation/s occurred in this quarter. Deviation has been reported on:

Submitted by: Title / Position: Signature: Date: Phone:

Attach a signed certification to complete this report.ESSROC Cement Corporation Page 80 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore


## INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR QUALITY COMPLIANCE DATA SECTION

Part 70 Quarterly Report for Use When Combusting Coal and Fuel Oil Simultaneously

Source Name: ESSROC Cement Corporation Source Address: Highway 31, Speed, Indiana 47172 Mailing Address: Highway 31, Speed, Indiana 47172 Part 70 Permit No.: T019-6016-00008 Facility: Kilns #1 and 2 Parameter: Sulfur Dioxide (SO 2 

### ) from the simultaneous combustion of coal and oil Limit: 6.0 pounds per million Btu heat input

Compliance with the SO2 limit shall be determined using the following equation:

SO 2 

### emissions (lbs/MMBtu) = (Fuel oil usage x EF coeffi cient x fuel oil sulfur content + coal usage x EF coefficient x coal sulfur content) / (fuel o il usage x HHV oil + coal usage x HHV coal).

FACILITY: YEAR:

Month Monthly Average Sulfur Content

(%) Monthly Average Heat Content

(MMBtu/lb) Month Fuel Consumption Equivalent Sulfur Dioxide Emissions

(lbs/MMBtu)



### Coal Fuel Oil Coal Fuel Oil Coal (tons) Fuel Oil (gallons) This Month

1

2

3

9 No deviation occurred in this quarter.

9 Deviation/s occurred in this quarter. Deviation has been reported on:

Submitted by: Title / Position: Signature: Date: Phone:

Attach a signed certification to complete this report.ESSROC Cement Corporation Page 81 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore


## INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR QUALITY COMPLIANCE DATA SECTION

Part 70 Quarterly Report

Source Name: ESSROC Cement Corporation Source Address: Highway 31, Speed, Indiana 47172 Mailing Address: Highway 31, Speed, Indiana 47172 Part 70 Permit No.: T019-6016-00008 Facility: fuel oil-fired fur naces (EU13, EU68, and EU69) Parameter: Sulfur Dioxide (SO 2 

### ) Limit: 0.5 pounds per million Btu heat input

FACILITY: YEAR:

Month Monthly Average Fuel Oil Sulfur Content (%) Monthly Average Fuel Oil Heat Content (MMBtu/lb) Fuel Oil Consumption

(Gallons) Equivalent Sulfur Dioxide Emissions (lbs/MMBtu)

9 No deviation occurred in this quarter.

9 Deviation/s occurred in this quarter. Deviation has been reported on:

Submitted by: Title / Position: Signature: Date: Phone:

Attach a signed certification to complete this report.ESSROC Cement Corporation Page 82 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore


## INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR QUALITY COMPLIANCE DATA SECTION

Part 70 Quarterly Report

Source Name: ESSROC Cement Corporation Source Address: Highway 31, Speed, Indiana 47172 Mailing Address: Highway 31, Speed, Indiana 47172 Part 70 Permit No.: T019-6016-00008 Facility: quarry drilling Parameter: number of holes drilled Limit: 38,000 per 12 consecutive month period

YEAR:

Facility Month Column 1 Column 2 Column 1 + Column 2

This Month Previous 11 Months 12 Month Total

quarry drilling Month 1

Month 2

Month 3

9 No deviation occurred in this quarter.

9 Deviation/s occurred in this quarter. Deviation has been reported on:

Submitted by: Title / Position: Signature: Date: Phone: A certification is required for this report.ESSROC Cement Corporation Page 83 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore


## INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR QUALITY COMPLIANCE DATA SECTION

PART 70 OPERATING PERMIT QUARTERLY DEVIATION AND COMPLIANCE MONITORING REPORT

Source Name: ESSROC Cement Corporation Source Address: Highway 31, Speed, Indiana 47172 Mailing Address: Highway 31, Speed, Indiana 47172 Part 70 Permit No.: T019-6016-00008

Months: ___________ to ____________ Year: ______________ Page 1 of 2
This report shall be submitted quarterly based on a calendar year. Any deviation from the requirements, the date(s) of each deviation, t he probable cause of the deviation, and the response steps taken must be reported. Deviations t hat are required to be reported by an applicable requirement shall be reported according to the schedule stated in the applicable requirement and do not need to be included in this report. Additional pages may be attached if necessary. If no deviations occurred, please specify in the box ma rked “No deviations occurred this reporting period”.

9 NO DEVIATIONS OCCURRED THIS REPORTING PERIOD.

9 THE FOLLOWING DEVIATIONS OCCURRED THIS REPORTING PERIOD

Permit Requirement (specify permit condition #)

Date of Deviation: Duration of Deviation:

Number of Deviations:

Probable Cause of Deviation:

Response Steps Taken:

Permit Requirement (specify permit condition #)

Date of Deviation: Duration of Deviation:

Number of Deviations:

Probable Cause of Deviation:

Response Steps Taken:ESSROC Cement Corporation Page 84 of 84 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore


### Page 2 of 2

Permit Requirement (specify permit condition #)

Date of Deviation: Duration of Deviation:

Number of Deviations:

Probable Cause of Deviation:

Response Steps Taken:

Permit Requirement (specify permit condition #)

Date of Deviation: Duration of Deviation:

Number of Deviations:

Probable Cause of Deviation:

Response Steps Taken:

Permit Requirement (specify permit condition #)

Date of Deviation: Duration of Deviation:

Number of Deviations:

Probable Cause of Deviation:

Response Steps Taken:

Form Completed By:

Title/Position:

Date:

Phone:

Attach a signed certification to complete this report.

## Indiana Department of Environmental Management Office of Air Quality

Addendum to the Technical Support Document for a Part 70 Operating Permit

Source Name: ESSROC Cement Corporation Source Location: Highway 31, Speed, Indiana 47172 County: Clark SIC Code: 3241 Operation Permit No.: T019-6016-00008 Permit Reviewer: Nisha Sizemore



### On August 11, 2003, the Office of Air Quality (OAQ) had a notice published in the Clark County Evening News, Jeffersonville, Indiana, stating that ESSROC Cement Corporation had applied for a Part 70 Operating Permit to operate a portland cement manufacturing operation. The notice also stated that OAQ proposed to issue a permit for this operation and provided information on how the public could review the proposed permit and other documentation. Fi nally, the notice informed interested parties that there was a period of thirty (30) days to provi de comments on whether or not this permit should be issued as proposed. On October 28, 2003, t he OAQ held a public hearing and accepted additional comments on the proposed permit. Additionally, the comment period was extended through October 28, 2003.

On August 21, 2003, John Groan, provided wri tten comments on the proposed permit during the public comment period. The summary of the comments and any changes made as a result of the comments follows. New text is shown in bold font and deleted text is shown in strikeout font.

Comment #1

I live near the plant and I don’t enjoy the pollution put forth by the plant. They normally have a plume of dust and other material coming from the plant.

Response #1

This permit includes many new monitoring and testing requirements to ensure that particulate matter emissions are in continuous compliance with air qualit y rules. This new permit requires the source to monitor all of the particulate matter control devices each shift (including night shifts). If an abnormal situation is observed, the permit requires the Permittee to take corrective actions to fix the problem. The permit also requires stack testing for many facilitie s which the Permittee has never tested, or has not tested for several years.

Comment #2

The kiln operation is abnormally noisy. They use blasting to loosen the limestone.

Response #2

IDEM has no regulatory authority to limit noise from the plant.ESSROC Cement Corporation Page 2 of 43 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore



### On October 28, 2003, IDEM held a public hearing and accepted additional comments on the proposed permit. Below is a summary of comments received during the public hearing. IDEM’s responses and any changes made to the permit as a re sult of the comments, are shown following each of the comments. New text in the permit is shown in bold font and deleted text is shown in strikeout font.

Comments regarding Fugitive Dust

Several people commented about fugitive dust problems from the plant. People stated that cement dust is difficult to clean off of cars, houses, and other items, and that it ruins the paint on these items. One person asked if ESSROC would agree to a fugiti ve dust control plan being included in the permit.

IDEM’s Response

ESSROC has submitted a proposed fugitive dust control plan to be included in the permit. IDEM and ESSROC worked together to finalize the contents of the plan, which is now included in the permit, as Condition C.4(b). The contents of the plan are enf orceable requirements, and any changes to the plan must be approved by IDEM. IDEM believes that the plan addresses the main sources of fugitive dust at the plant, and that compliance with the plan will significantly reduce fugitive dust emissions.

C.4 Fugitive Dust Emissions [326 IAC 6-4] (a) The Permittee shall not allow fugitive dust to escape beyond the property line or boundaries of the property, right-of-way, or eas ement on which the source is located, in a manner that would violate 326 IAC 6-4 (Fugitive Dust Emissions). 326 IAC 6-4-2(4) is not federally enforceable.

(b) In order to comply with 326 IAC 6-4, the Permittee shall comply with the fugitive dust control plan, which includes the following requirements:

(1) Vehicular traffic shall follow established roadways (paved and unpaved) and observe the POSTED speed limit of 15 mph (excluding the quarry).

(2) Individuals responsible for loading, unloading, and/or transfer of materials will be trained in Best Management Practices (B MPs) which will minimize or eliminate fugitive emissions and include instruction on:

(A) Filling the transportation containers properly by not overfilling;

(B) Loading trucks so that no part of the load comes within 6 inches of the top of any sideboard, side panel, or tail gate;

(C) Filling the loader bucket properly by not overfilling;

(D) Minimize free fall heights; and,

(E) Taking all reasonable precautionary measures to reduce or eliminate the generation of fugitive dust.

(3) Feeders for unloading & transfer operations will be connected directly to bins, hoppers and tanks.ESSROC Cement Corporation Page 3 of 43 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore



### (4) Leaks in potential sources of fugitive emissions will be repaired in a timely

manner.

(5) Paved roads and parking lots in the plant will be swept on a daily basis (Monday-Friday), weather permitting. The sweeper will not be operated during rainy days.

(6) Unpaved roads will be watered, as needed. Due to safety concerns, road watering will not be conducted when the temperature is below 35oF or when the temperature is expected to fall below freezing while the roads are wet.

(7) The C-4 belt water spray dust s uppression system will replaced by May 31, 2004. This system will be operate d on a continuous basis while the material handling equipment is in operation, except during freezing conditions which could cause material handling problems (at temperatures below 35o or when the temperatures are expected to be below freezing while the material is wet).

(8) Stock/Storage Piles The areas ar ound the Stock/Storage P iles are to be main tained in such a manner as to minimize the potential for fugitive particulate matter emissions. (A) The area around the Piles is to be swept or watered as necessary. (B) Restrict traffic flow in and around the storage areas.

(9) Clinker Storage Building Dust Control Plan The openings in the roof and sides of the building will be sealed, and all belts will be covered. This phase of the clinker buildi ng dust control plan will be complete d by May 31, 2004.

By July 31, 2004 Essroc will subm it to IDEM a report including a description of the actions taken with respect to the Clinker Storage Building and an evaluation of the effectiveness of those actions.

Comments regarding Emissions at Night

Several people stated that emissions from the plant are worse during nighttime hours. Some people requested that IDEM staff perform surveillances dur ing the nighttime hours. One person suggested that ESSROC operates the plant differently on nights and weekends, which causes additional emissions and a cloud over the place, that isn’t present during the daytime. People reported dusting on their cars, which occurs at night, but not during the daytime.

IDEM’s Response

Dust and odors from the plant are likely to be stronger at night due to a condition called inversion. Inversion does not allow adequate mixing conditions in the atmosphere, which can cause emissions to be trapped near the ground. More emissions tr apped near the ground can cause increased odors. Inversion tends to occur more often at night and during poor weather conditions, because the lack of heat from the sun tends to stabilize the inversion.ESSROC Cement Corporation Page 4 of 43 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore



### The Title V permit does require ESSROC to monitor their emission control devices during the nighttime hours, as well as during the daytime hours. This monitoring will help assure that emissions control devices are operated properly at all times.

As requested, IDEM agrees to conduct some night time surveillances of the plant emissions.

Comments regarding the ESSROC’s Current Compliance Status

Some people stated that they believe ESSROC is not currently in compliance with state and federal air pollution laws. At least one person stated that no new permits should be issued to ESSROC until the equipment they operate now comes into compliance with all state and federal air pollution laws. Some people asked about the status of the current enforcement actions.

IDEM’s Response

Indiana is required to issue Title V permits to every major source, regardless of their compliance status. The Clean Air Act requires all major sources of air pollution to apply for and obtain a Title V permit. The Title V permit for ESSROC does not allow any new emission units to be constructed or operated. The Title V permit consolidates all the previous air per mits for the source into one single permit document. The Title V permit also establishes compliance moni toring provisions, which require the Permittee to monitor their emissions and pollution control equipment to assure proper operation and compliance with the emission limits in the permit. The Title V permit also establishes a schedule for some of the emission units to be stack tested on a regular basis . During a stack test, emissions are measured to determine compliance with the emission limits in t he permit. ESSROC is required to conduct several stack tests within the first year after the permit is issued.

ESSROC does have some enforcement actions pending with IDEM and the U.S. EPA. The pending cases are summarized in the table below:

Case Description of alleged violation

IDEM Case number 2001- 10884-A opacity exceedances for the periods ending January 1, 2001, April 1, 2001, July 1, 2001, and September 1, 2001;



### IDEM Case number 2002- 11635-A violations of 326 IAC 10-1 including: (1) failure to install and operate a continuous emissions monitor to measure NOx emissions from the kiln #2 alkali bypass stack; (2) excess downtime for NOx continuous emissions monitor on kiln #1; and (3) thirty-two (32) exceedances of NOx 30-day rolling average limit on kiln #1.

IDEM referral to enforcement fugitive dust violation

EPA case opacity exceedances from the kiln and raw mill

IDEM and the U.S. EPA are working with ESSROC to resolve all of these cases and to determine a compliance schedule to return the affected emission units to compliance.

With respect to emission units that are currently out of compliance with state or federal air pollutionESSROC Cement Corporation Page 5 of 43 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore



### regulations, the Clean Air Act requires the Title V permit to include a compliance schedule in the permit. The compliance schedule is a plan that outlines how the Permittee will address the compliance problems to return the affected emission units to compliance. One such compliance schedule is the fugitive dust control plan included in Condition C.4 (b) of the per mit. The contents of the fugitive dust plan are discussed in detail in IDEM’s response to Comment s Regarding Fugitive Dust. Another compliance schedule included in the Title V permit is in paragraphs (f) and (g) of Condition D.3.14. Paragraph (f) of this condition addresses the violation of ESSROC’s failure to install a continuous emissions monitor to measure NOx emissions from kiln #2, a violati on of Indiana rule 326 IAC 10-1. Paragraph (f) of Condition D.3.14 includes a schedule for ESSROC to install a continuous emissions monitor within 12 months after the Title V permit is issued. Paragraph (g) of Condition D.3.14 addresses the violation that consists of ESSROC’s failure to pass a certification test on the continuous emissions monitor for measuring NOx emissions from kiln #1. Paragraph (g) of Condition D.3.14 requires ESSROC to either pass the certification test on the existing monitor within 90 days after the Title V permit is issued, or to replace the continuous emissions monitor and pass a certification test on the new monitor within 120 days after the Title V permit is issued.

EPA and ESSROC have not yet agreed on a compliance schedule that will address the noncompliance issues alleged in EPA’s pending enforcement case against ESSROC. Therefore, the permit does not yet include any compliance schedule with respect to those violations. Once a compliance schedule has been determined, IDEM will reopen and revise the Title V permit to include the compliance schedule in the permit.

Comment Regarding IDEM’s Enforcement Process

Some people asked about how the enforcement process works and how penalties are assessed.

IDEM’s Response

IDEM’s Office of Enforcement is to respond to vi olations with timely, quality enforcement actions that accomplish three major goals: (1) achieve compliance, (2) deter future violations; and (3) result in an improved environment. Once a violation is discove red by an IDEM inspector or permit reviewer, a referral is made to the Office of Enforcement. The Office of Enforcement then issues a notice of violation (NOV), which is a letter informing the Respondent that IDEM believes violations of environmental laws or regulations have occurred. The Respondent is invited to attend a conference with IDEM to discuss the violations and solutions. Sometimes the Office of Enforcement may need to have several conferences with a Respondent to determine appropriate solutions.

If the conferences result in an agreement bet ween IDEM and the Respondent, then the Respondent may enter into an Agreed Order with IDEM. Agreed Orders contain steps the Respondent must take to comply with the law. In most cases, Agreed Orders include a fine for past violations and stipulated penalties for failure to complete any future compli ance steps. If the conferences do not result in an agreement between IDEM and the Respondent, then IDEM may issue a Commissioner’s Order, which is a unilateral order requiring specific action to correct a violation and/or pay a fine.

Although state law authorizes fines up to $25,000 per day per violation, most are much less. The amount of the fine depends on several factors, including the magnitude of the violation, the potential harm to human health and the environment, the economic benefit gained by the violator by not complying, and the violator’s efforts to achieve compliance.

More detailed information concerning IDEM’s enforce ment process is available on IDEM’s website at http://www.in.gov/idem/enforcement/oe/index.html.ESSROC Cement Corporation Page 6 of 43 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore



### Comments Regarding Odor from the Plant

At least one person commented that there is a sulphur smell from the plant. The commenter stated that he believed the odor was caused by too much oxygen in the fuel. The commenter stated that the Permittee should be required to properly monitor the ox ygen content of the fuel, so that the odor would not occur.

IDEM’s Response

IDEM does not have specific authority to regulate odor.

Comments Regarding Monitoring of the Plant

One person asked who is monitoring the plant to assure they are in compliance with the rules and regulations. Another person s uggested the inspector for ESSROC should be switched periodically, so that the inspector can remain objective and not become too friendly with ESSROC’s management. The person also asked if compliance is determined bas ed on more than just verbal assurances from ESSROC’s management.

IDEM’s Response

The Title V rules require ESSROC to certify compliance (or noncompliance) with each condition of their permit at the end of each year. In order to certify compliance, ESSROC must have ample information to determine whether each unit is in compliance. The Title V rules require the Title V permit to include provisions which require ESSROC to monitor their own operations. ESSROC must perform sufficient monitoring to be able to determine continuous compliance with the requirements of the permit. Therefore, the permit est ablishes specific items t hat ESSROC staff must moni tor in order to determine proper operation of the emission units and emission control devices. ESSROC must also keep records of all the monitoring they perform as required by the permit, as well as any preventive maintenance they perform on emission control devices. The permit also requires ESSROC to conduct stack tests on several emission units. During a stack test, the amount of emissions are measured to determine compliance with emission limits in the permit. ESSROC is responsible for hiring a company to perform the stack tests; however, OAQ staff observe the stack tests to assure that they are performed properly. The OAQ also reviews test protocols (plans stati ng how the stack tests will be performed), prior to the tests being performed. Finally, after the test company completes the final test report, OAQ staff review the report to verify the results were properly determined.

In addition to all this monitoring and stack testing, the Office of Air Quality has a Compliance Branch, which staffs several inspectors. The inspectors ’ responsibilities include conducting surveillance and full inspections of plants within their assigned region of the state. The Office of Air Quality has one inspector, Ray Schick, who is assigned the responsib ility of inspecting all of the portland cement plants in Indiana. Because portland cement plants are regulated by several complex rules and regulations, the OAQ has decided that assigning one inspector to all of the portland cement plants in Indiana, is the best and most efficient way to determine whether these plants are in compliance with all applicable rules. Portland cement plants, including ESSROC, are inspec ted at least twice per year, with the inspections being unannounced. Full inspections include not only an observation of emissions from the plant, but also a complete review of all required paperwork. In addition to full inspections, the inspector will also conduct surveillance of plant emissions to determine if there are any violations of opacity or fugitive dust rules. Surveillances differ from full inspections because surveillances do not always require the inspector to enter the plant, and surveillances do not include a review of the plant’s required paperwork. Additional inspections or surve illances will be performed if IDEM su spects compliance problems or if IDEM receives citizen complaints regarding excess emissions.ESSROC Cement Corporation Page 7 of 43 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore



### Within the past 2 years, unannounced inspections and su rveillances were conducted at the plant on the following dates:

Unannounced Inspections Surveillances

February 14, 2002 January 9, 2002

October 25, 2002 April 25, 2002

April 24, 2003, July 9, 2002
September 22, 2003 July 24, 2002

July 30, 2002

August 15, 2002

December 12, 2002

January 7, 2003

January 30, 2003

April 12, 2003

June 19, 2003

July 10, 2003

July 29, 2003

August 5, 2003

August 14, 2003

September 24, 2003

October 8, 2003

October 23, 2003

November 13, 2003

December 3, 2003

December 30, 2003

January 7, 2004

January 13, 2004

January 29, 2004

Comments regarding the Stringency of Emission Limits in the Title V PermitESSROC Cement Corporation Page 8 of 43 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore



### People asked if the Title V permit would require more stringent emission limits than what is required

now.

IDEM’s Response

In June 2002, ESSROC was required to begin complying with a more stringent federal rule, the National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Portland Cement Plants, which was established to reduce hazardous air pollutant (HAP) emissions from portland cement plants. The requirements of this rule are listed in the permit.

The permit also includes a new fugitive dust control plan, as discussed previously in IDEM’s Response to Comments regarding Fugitive Dust Emissions.

Comments regarding Visible Emissions

One person asked if emissions were in violation if they were visible.

IDEM’s Response

Emissions are not necessarily in violation of federal or state rules if they are visible. The EPA has developed a test method, EPA reference method 9, to measure the opacity of emissions that are visible. Opacity measures the amount of sunlight that is blocked by a plume of emissions. Different opacity limits may apply to different emission units at a plant, depending on the rules and regulations that govern those emission units. At ESSROC, most of the units are subject to a ten percent (10%) opacity limit. A very small number of the emission units at ESSROC ar e subject to either twent y percent (20%) or forty percent (40%) opacity limits. If a unit has a ten per cent (10%) opacity limit, then only 10% of the sunlight is allowed to be blocked by the plume of dust. T he OAQ has staff, including ESSROC’s inspector, Ray Schick, who are trained to conduct the EPA test method to read opacity and determine compliance with these limits. Additionally, ESSROC is required to operate continuous opacity monitoring systems (COMS) on each of the kilns and clinker coolers. These COMS are instruments that automatically measure and record the opacity of the emissions coming from the stack every fifteen minutes. ESSROC is required to send a report to IDEM each calendar quarter to notify IDEM of any opacity exceedances recorded by the COMS. If the opacity exceeds the app licable limit, then the emissions are in violation.

Additionally, Indiana has a regulation that disallows fugitive dust emissions from being visible crossing the property line at ground level. The inspector moni tors for this during inspections and surveillances at the plant. The permit also includes a fugitive dust c ontrol plan, which is designed to reduce fugitive dust emissions so that fugitive dust emissions will be reduced.

Comments on Grandfathered Units

One person asked if emission units at ESSROC ar e still grandfathered out of rules and regulations.

IDEM’s Response

Some rules are written to apply only to emission units that are constructed or modified after a certain date. One such rule is the New Source Performance Standard (NSPS) for Portland Cement Plants. The NSPS for cement plants applied only to kilns and other emission units at the plant that were constructed or modified after August 17, 1971. One of ESSROC’s kilns and some of the other emission units at the plant were constructed prior to this date and hav e not been modified. Therefore, these units were “grandfathered” out of the NSPS rule. However, a new rule, the NESHAP for Portland Cement Plants, was finalized in June 1999, and replaced the NSPS for Portland Cement Plants. The new NESHAP ruleESSROC Cement Corporation Page 9 of 43 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore



### is more stringent than the old NSPS rule and it applies to all the affected units at the plant, regardless of when they were constructed. Therefore, no uni ts at ESSROC are “grandfathered” out of the new NESHAP rule.

New Source Review (NSR) rules are also rules that apply only to emission units that are constructed or modified after a certain date. Counties are determined to be attainment or nonattainment for each regulated pollutant. If a County is attainment, then one set of rules, the Prevention of Significant Deterioration (PSD) rules, may apply if emissions are above the applicability thresholds. If a County is nonattainment, then another set of rules, the Emission Offset rules, may apply if emissions are above the applicability thresholds. If a unit is subject to the PSD rules in an attainment area, then the source would be required to install the best available contro l technology (BACT), which means that they would have to install the best level of control that is tec hnically and economically feasible to use. If a unit is subject to the Emission Offset rules in a nonattainm ent county, the source would be required to achieve the lowest emission rate that is technically feasible, regardless of the cost. Most of the emission units at ESSROC were constructed prior to the applicabilit y date of the NSR rules and are therefore still “grandfathered” out of any of the PSD or Emission Offs et rules. Any further modifications to these units which would increase emissions above the significanc e levels, would trigger the applicability of these rules.

Comments regarding Monitor Downtime

One person asked how does IDEM know what ESSROC is emitting when the monitors are down or not functioning properly. The person stated that monito r downtime appears to be quite frequent at this plant.

IDEM’s Response

IDEM does have enforcement cases pending against ESSROC for excess monitor downtime and for failure to install and properly certify monitors. IDEM has included a condition in the permit that requires a schedule for ESSROC to install and certify continuous emission monitors for measuring NOx emissions from the kilns within 12 months after iss uance of this permit. Please refer to Condition D.3.14 to see the detailed requirements of this condition.

IDEM has included provisions in the permit which require ESSROC to monitor the oxygen content and the temperature of the kiln exhaust once per hour , whenever the continuous emissions monitoring system (CEMS) for measuring NOx emissions is down or not functioning properly. These measurements will give some indication of continued compliance with the NOx emission limits, when the NOx CEMS is not functioning. IDEM has also included provisions in the permit requiring ESSROC to observe and keep records of the visible emissions from the stacks, whenever the continuous opacity monitor is down for more than one hour. For the fi rst 24 hours, these observations can be recorded as “normal” or “abnormal”. If the monitor is dow n for more than 24 hours, then the permit requires ESSROC to provide a person certified to conduct the EPA test Method, referred to as Method 9, to read opacity from the stack for one half hour every four hours until the monitor is back in operation.

Comments regarding Calibration of Monitors

One person asked who calibrates the continuous emissions monitoring systems (CEMS) and the continuous opacity monitoring systems (COMS) that ESSROC operates at their plant. The person would like to have the details of how IDEM assures the monitors are calibrated properly.

IDEM’s Response

Opacity monitors must go through an initial certificat ion procedure that includes two parts. The first partESSROC Cement Corporation Page 10 of 43 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore



### is done at the factory on a representative unit and cons ists of different systems/performance checks to make sure the unit is accurate. The second check is a field certification which uses calibrated filters (which simulate an opacity reading) placed in the path of the monitor’s light beam to produce a known response. The monitor also must go through a condi tioning/operational period during which it must be able to self calibrate itself for 7 days without any exceedances of its daily standard. Additionally, at least once every 24 hours the monitor will do an automatic calibration to make sure that it is still reading correctly. It will use a system which simulates 0.0% opacity and a filter which simulates an upscale opacity. Again it must pass these tests or it will be considered out of control. The monitor must also undergo quarterly audits where outside filters of known opacity are placed in the light beams path. Once again the unit must pass this quarterly audit check. In conclusion, there are detailed certification procedures for an opacity monitor as well as daily and quarterly checks which are performed to ensure that the monitor is producing reliable accurate data during periods of unit operation.

Quarterly audits are performed by ESSROC, or a company they hire to perform the tests. IDEM staff observe the tests to assure they are done correctly. IDEM staff also review the records to assure proper daily calibrations are occurring within the unit.

Continuous emissions monitors are calibrated and certified in much the same way as opacity monitors. The company installs the system and then hires another company to come in and perform a relative accuracy test audit (RATA) on the system. During a RA TA, a reference monitor is used to certify that the source’s CEMS is correctly reading the concentration of the pollutant of interest. In addition to the RATA, the source also performs a seven day drift c heck in which their monitor is sent zero and upscale calibration gases once per day. The monitor must r ead these calibration gases within certain tolerances in order to pass the seven day drift test. After certification, a RATA will be performed once per year and the zero and upscale drift tests will be done once per day every day. Additionally, in the three quarters when the RATA test is not conducted, the source must bring in additional calibration gases and complete a cylinder gas audit (CGA). In the CGA, the monitor is challenged with the known gases and must read the gases accurately within 5% to pass.

Comments regarding Ambient Air Monitoring

One person asked if an ambient air monitor could be placed near ESSROC.

IDEM’s Response

As explained in the response to comments about fugitive dust, the Part 70 permit includes an enforceable fugitive dust control plan. IDEM be lieves this plan addresses the areas of concern regarding fugitive dust, and that implementation of this plan will alleviate the fugitive dust problems in the vicinity of the plant. However, if fugitive dust problems still persist after ESSROC has been implementing the fugitive dust control plan for reasonable amount of time, IDEM will evaluate the feasibility of placing a PM10 monitor near the plant.

Comments regarding Future Complaints

People asked who complaints should be directed to in the future.

IDEM’s Response

At any time, if someone observes excess emissions from the plant and believes the emissions may be in violation of state or federal rules, then complaints can be directed to the inspector, Ray Schick, by calling IDEM’s Office of Air Quality at 1-800-451-6027, and asking to speak to Ray Schick.ESSROC Cement Corporation Page 11 of 43 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore



### If someone objects to the way the permit is wri tten, he or she can comment during the 30 day public comment period. If someone still objects to the way the permit is written after it is issued, he or she can appeal the permit. There is a thirty (30) day time period after the issuance of the permit, when the permit can be appealed. A notice that includes instructions for filing an appeal is included with the final permit package. If someone objects to the way the permit is written and believes that IDEM did not apply the Clean Air Act correctly, another option besides filing an appeal, is to petition EPA and ask them to object to the permit.

On September 10, October 28, and October 31, 2003, Jim Hauck of Baker and Daniels, on behalf of ESSROC Cement Corporation, provided written comments on the proposed permit during the public comment period. The summary of the comments and any changes made as a result of the comments follows. New text is shown in bold font and deleted text is shown in strikeout font.

Comment #1 (Section A.3 - Emission Units and Pollution Control Equipment Summary)

Condition A.3 (59) - a new baghouse has been added to control the apron conveyor, identified as baghouse 31382, exhausting to stack EPN1.

Condition A.3 (60) - a new baghouse has been added to control the clinker can #1, identified as baghouse 31382, exhausting to stack EPN1.

Condition A.3 (62) - a new baghouse has been added to control the aumond conveyor, identified as baghouse 31382, exhausting to stack EPN1.

Condition A.3 (64) - a new baghouse has been added to control the clinker can #2, identified as baghouse 31382, exhausting to stack EPN1.

Condition A.3 (72) - a new baghouse has been added to control the south reclaim clinker covered conveyor, identified as baghouse 31499, exhausting to stack EPN2.

Condition A.3(77) - Two baghouses have been added to replace former baghouse 251. The new baghouses are baghouse 31495 exhausting to stack EPN3, and baghouse 31496 exhausting to stack EPN4.

Conditions A.3(82) and (85) - The finish mill circ uit 2B (EU40) and the separator and cement cooler (EU41) exhaust to the same baghouse (number 135) and stack (EP35). Please change the facility descriptions accordingly.

Conditions A.3(83) and (84) - The finish mill circ uit 2C (EU42) and the separator and cement cooler (EU43) exhaust to the same baghouse (number 137) and stack (EP37). Please change the facility descriptions accordingly.

Condition A.3 (90) - two new baghouses have been added to control the 2D finish mill clinker / gypsum feed circuit, identified as baghouse 31497, exhaus ting to stack EPN5, and baghouse 31498 exhausting to stack EPN6.

Condition A.3(104) and (105). Please make the i ndicated changes to correct typographical errors.

(104) 504 Silos Bank/Silo 49 (CKD sales), ident ified as EU153, constructed in 1959, with emissions controlled by a baghouse, identified as baghouse 264 CE96 and exhausting to stack EP96 264

.ESSROC Cement Corporation Page 12 of 43 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore



### (105) CKD sales loadout spout, identified as EU154, constructed in 1999, with emissions controlled by a baghouse, identified as baghouse 265 (CE97) and exhausting to stack EP97 265

. Condition A.3(122). Please make t he indicated change for consistency.

(122) Kiln #2 coal dust silo, identified as EU149, constructed in 1996, with emissions controlled by one baghouse with a nominal air flow rate of 200 actual cubic feet per minute, identified as baghouse 253, and exhausting to one (1) stack identified as EP101

. Condition A.3(123) and (124). These two units exhaust to the same passive dust collector and stack. The passive dust collector has no fan associated with it and therefore is not a baghouse. For this reason, these units cannot be stack tested either. Please make the requested changes to the facility descriptions and remove these units from any testing lists.

(123) Kiln #2 coal weigh system, identified as EU150, constructed in 1996, with a nominal throughput of 20 tons per hour, with emissions controlled by one filter, identified as filter 254 and exhausting to a vent . baghouse with a nominal air flow rate of 500 actual cubic feet per minute, identified as baghouse 254

. (124) Kiln #2 coal handling system, identified as EU151, constructed in 1996, with a nominal throughput of 20 tons per hour, with emissions controlled by one filter, identified as filter 255 and exhausting to a vent . baghouse with a nominal air flow rate of 200 actual cubic feet per minute, identified as baghouse 255.

Additionally, for conditions A.3(58), ( 59), (61), (62), (63), (90), (91), ( 92), (125), (126), ( 127), (128), (130), and (131), please correct the nominal throughputs. For (58) and (59) the throughput should be 100 tph. For (61) - (63) the throughput should be 150 tph. Fo r (90) - (92) the throughput should be 140 tph. For (125) the throughput should be 105 tph. For (126) the throughput should be 60 tph. For (127) the throughput should be 175 tph. For (128) and (131) the throughput should be 105 tph. For (130) the throughput should be 60 tph.

Response #1

Because the changes are simply due to correcting errors in the original application, and not the result of any physical modifications made to the equipmen t, IDEM agrees that the requested changes do not need to be reviewed pursuant to the requirements of New Source Review (NSR). The requested changes to the descriptions have been made as shown below.

Kiln #1 Clinker Handling Facilities

(58) One (1) #1 clinker drag conveyor for transferring clinker from clinker cooler #1 to the apron conveyor, identified as EU23, constructed in May 1971, with a nominal throughput of 75 100 tons per hour, with emissions controlled by a baghouse, identified as baghouse 217, and exhausting to one (1) stack identified as EP19.

(59) apron conveyor for transferring clinker from the #1 clinker drag conveyor to either the clinker can #1 or the long belt, identified as EU24, constructed in May 1971, with a nominal throughput of 75 100 tons per hour, with emissions controlled by a two baghouse s , identified as baghouse 218, and exhausting to one (1) stack identified as EP20 and baghouse 31382, exhausting to one (1) stack identified as EPN1

.ESSROC Cement Corporation Page 13 of 43 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore

(60) clinker can #1, which is a vertical bin with a lid used for storing off-spec clinker, identified as EU114, constructed in May 1971, with emissions controlled by a two baghouse s , identified as baghouse 218, exhausting to one (1) stack identified as EP20 and baghouse 31382, exhausting to one (1) stack identified as EPN1

. Kiln #2 Clinker Handling Facilities

(61) One (1) #2 clinker drag conveyor for transferring clinker from clinker cooler #2 to the aumond conveyor, identified as EU30, constructed in 1977, with a nominal throughput of 100 150 tons per hour, with emissions controlled by a baghouse, identified as baghouse 233, and exhausting to one (1) stack identified as EP25.

(62) One (1) aumond conveyor used for transferring clinker from the #2 clinker drag conveyor to the clinker can #2 or the cross belt, identified as EU31, constructed in 1977, with a nominal throughput of 100 150 tons per hour, with emissions controlled by a two baghouse s , identified as baghouse 234, exhausting to one (1) stack identified as EP26 and baghouse 31382, exhausting to one (1) stack identified as EPN1

. (63) One (1) cross belt for transferring clinker from the aumond conveyor to the long belt, identified as EU119, constructed in May 1971, with a nominal throughput of 100 150 tons per hour, with emissions controlled by a baghouse, identified as baghouse 235, and exhausting to one (1) stack identified as EP21.

(64) clinker can #2, which is a vertical bin with a lid used for storing off-spec clinker, identified as EU120, constructed in 1977, with emissions controlled by a two baghouse s , identified as baghouse 234, exhausting to one (1) stack identified as EP26 and baghouse 31382, exhausting to one (1) stack identified as EPN1

. Clinker Handling to Cr ane Storage Facilities

(72) One (1) South reclaim clinker covered conveyor used to transfer clinker from the North reclaim clinker covered conveyor system to the crane storage building, identified as EU124, constructed in May 1971, with a nominal throughput of 200 tons per hour, with emissions controlled by a two baghouse s , identified as baghouse 202, exhausting to one (1) stack identified as EP39 and baghouse 31499, exhausting to one (1) stack identified as EPN2

.

2ABC Finish Mill Facilities

(77) one (1) clinker transfer circuit ABC mills, including conveyor transfers and clinker scales, identified as EU36, constructed in 1964, with a nominal throughput of 200 tons per hour, with emissions controlled by a two baghouse s , identified as baghouse 251 31495, and exhausting to one (1) stack identified as EP32 EPN3, and baghouse 31496, exhausting to one (1) stack, identified as EPN4

. (84) One (1) separator and cement cooler, used in conjunction with the finish mill circuit 2C, identified as EU43, constructed in 1960 and 1964 respectively, with a nominal throughput of 36 tons per hour, with emissions controlled by a baghouse, identified as baghouse 138 137 , and exhausting to one (1) stack identified as EP38 EP37

. (85) One (1) separator and cement cooler, used in conjunction with the finish mill circuit 2B,ESSROC Cement Corporation Page 14 of 43 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore

identified as EU41, constructed in 1953 and 1955 respectively, with a nominal throughput of 25 tons per hour, with emissions controlled by a baghouse, identified as baghouse 136 135 , and exhausting to one (1) stack identified as EP36 EP35

.

2D Finish Mill Facilities

(90) one (1) 2D finish mill clinker / gypsum feed circuit which includes scales and feed belts, identified as EU45, constructed in 1964, with a nominal throughput of 120 140 tons per hour, with emissions controlled by a baghouse three (3) baghouses , identified as baghouse 262, and exhausting to one (1) stack identified as EP94 , baghouse 31497 exhausting to one (1) stack identified as EPN5, and baghouse 31498 exhausting to one (1) stack identified as EPN6

. (91) one (1) 2D finish mill roll press circuit, which includes a roller press (crusher), identified as EU46, constructed in 1999, with a nominal throughput of 120 140 tons per hour, with emissions controlled by three (3) baghouses, identified as baghouses 261, 262, and 263, and exhausting to three (3) stacks identified as EP93, EP94, and EP95.

(92) one (1) 2D finish mill circuit, which includes conveyor transfer, elevator, finish mill, elevator, classifier, and three (3) cement coolers, identified as EU47, constructed in 1964, with a nominal throughput of 120 140 tons per hour, with emissions controlled by a baghouse, identified as baghouse 139, and exhausting to one (1) stack identified as EP41.

Finish Product 504-Silos Storag e and Bulk Loading Facilities

(104) 504 Silos Bank/Silo 49 (CKD sales), identified as EU153, constructed in 1959, with emissions controlled by a baghouse, identified as baghouse CE96 264 and exhausting to stack 264 EP96

. (105) CKD sales loadout spout, identified as EU154, constructed in 1999, with emissions controlled by a baghouse, identified as baghouse 265 (CE97) and exhausting to stack 265 EP97

. Coal handling, milling and storage facilities

(122) Kiln #2 coal dust silo, identified as EU149, constructed in 1996, with emissions controlled by one baghouse with a nominal air flow rate of 200 actual cubic feet per minute, identified as baghouse 253 and exhausting to one (1) stack identified as EP101

. (123) Kiln #2 coal weigh system, identified as EU150, constructed in 1996, with a nominal throughput of 20 tons per hour, with emissions controlled by one baghouse with a nominal air flow rate of 500 actual cubic feet per minute, identified as baghouse 254 filter, identified as filter 254 and exhausting to a vent

. (124) Kiln #2 coal handling system, identified as EU151, constructed in 1996, with a nominal throughput of 20 tons per hour, with emissions controlled by one baghouse with a nominal air flow rate of 200 actual cubic feet per minute, identified as baghouse 255 filter, identified as filter 255 and exhausting to a vent

.

The kiln #1 and kiln #2 facilitiesESSROC Cement Corporation Page 15 of 43 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore

(125) One (1) feed system for kiln #1, identified as EU19, constructed in May 1971, with a nominal throughput of 100 105 tons per hour, with PM emissions from the alleviator controlled by one (1) baghouse, identified as baghouse 209 and exhausting to stack EP15 and with PM emissions from the scales and pump controlled by one (1) baghouse, identified as baghouse 212 and exhausting to stack EP12.

(126) One (1) long dry process rotary cement kiln #1, identified as EU20, constructed in May 1971, with a nominal heat input capacity of 184 million Btu per hour, with a nominal production rate of 54.5 60 tons per hour (as clinker), with PM emissions controlled by one (1) baghouse, identified as baghouse 221, and exhausting to one (1) stack, identified as S-14.

(127) One (1) feed system for kiln #2, identified as EU26, constructed in 1977, with a nominal throughput of 150 175 tons per hour, with PM emissions controlled by one (1) baghouse, identified as baghouse 231, and exhausting to stack EP80.

(128) One (1) dry process rotary cement kiln #2 and associated preheater unit, equipped with an alkali bypass, identified as EU27, constructed in 1977, with a nominal heat input capacity of 302 million Btu per hour, with a nominal production rate of 96.0 105 tons per hour (as clinker), with PM emissions controlled by two (2) electrostatic precipitators, identified as ESP15 and ESP16 (alkali bypass system), and exhausting to stacks, identified as S-15 and S-16 respectively.

The clinker cooler #1 facilities

(130) One (1) grate clinker cooler #1, identified as EU22, constructed in May 1971, with a nominal throughput rate of 54.5 60 tons per hour, with PM emissions controlled by one (1)baghouse, identified as baghouse 222, and exhausting to one (1) stack, identified as S13.

The clinker cooler #2 facilities

(131) One (1) grate clinker cooler #2, identified as EU29, constructed in 1977, with a nominal throughput of 96.0 105 tons per hour, with PM emissions controlled by one (1) baghouse, identified as baghouse 17, and exhausting to one (1) stack, identified as S-17.



### Comment #2 (Conditions D.1.1, D.2.1, D.3.2, D.5.1 - Particulate Matter)

326 IAC § 6-1-1(a) states that s ources or facilities located in Clark County shall comply with the limitations in Rule 6-1-17 if the sour ce or facility is specific ally listed in that section or "the limitations of section 2 of this rule, if the source or facility is not s pecifically listed [in section 17] of this rule, but has the potential to emit one hundred (100) tons or more, or has actual emissions of ten (10) tons or more, of particulate matter per year." The rule specifica lly uses the phrase "source or facility." The Speed "source" is specifically listed in Rule 6-1-17. Three of its "facilities" ar e also listed. Because the "source" is listed, the "source" as a whole cannot be used to tri gger § 6-1-2. Only "facilit ies" not listed in § 6-1-17 can be subject to § 6-1-2. And, in order to be so subject, each such facility must meet the applicability threshold of PM PTE of 100 tpy or ac tual emissions of 10 tpy or more. Below, in specific comments, we will note those EUs which are below the applicability threshold.

A related issue concerns the definition of potential emissions, which calculates emissions without regard to control equipment "unless such equipment is (aside from air pollution control requirements) necessary for the facility to produce its normal product or is integral to the norma l operation of the facility" (326 IACESSROC Cement Corporation Page 16 of 43 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore



### § 1-2-55). In its "Background Information fo r Proposed New Source Performance Standards" for Portland Cement Plants, August 1971, EPA noted that "[b]aghouses are the most commonly employed control devices for mills, conveyors, transfer points, st orage silos, etc. Many of the dust collectors serve to recover product from exhaust gas streams and to increase product yields. Their function as air pollution control devices may, therefore, be sec ondary." As EPA realized, the use of baghouses on such equipment at the finish end of the plant (after the clinker cooler) had been routinely used to recover product long before the Clean Air Act was amended in 1970. These baghouses are therefore integral to the normal operation of the facility and their collection efficiency must be factored into the calculation of potential emissions. Below, in specific comments, we will note those EUs for which potential emissions should be calculated after controls.

Response #2

The applicability of 326 IAC 6-1-2 states that sources or facilities located in Clark County shall comply with (1) the limitations in section 8.1 through 18 of this ru le; or (2) the limitations of section 2 of this rule, if the source or facility is not specifically listed (emphasis added) in sections 8.1 through 18 of this rule, but has the potential to emit 100 tons or more , or has actual emissions of 10 tons or more, of particulate matter per year.

“Listed” means that the source or facility is subject to a limit listed in section 8.1 through 18 of the rule. The ESSROC source as a whole is not subject to any limit in 326 IAC 6-1-17. The name of the source “ESSROC Materials” appears in 326 IAC 6-1-7 only to identify the location of the three facilities at the ESSROC source that are subject to specific limits in 326 IAC 6-1-7. The three facilities that are specifically limited by 326 IAC 6-1- 7 are not subject to the requirements of 326 IAC 6-1-2. However, since ESSROC has the potential to emit more than 100 tons of particulate matter per year, all of the particulate-emitting facilities at ESSROC which are not specifically limited by 326 IAC 6-1-7 are subject to the limits listed in 326 IAC 6-1-2.

Since IDEM has already determined that the ESSROC s ource has the potential to emit particulate matter greater than 100 tons per year and actual particulate matter emissions greater than 10 tons per year, and ESSROC does not dispute the fact that the entire source has emissions above these levels, there is no need for IDEM to make a determination as to whether some of the control devices are integral to the processes they control. Additionally, IDEM does not agree that all baghouses that collect some amount of product for reuse, should be cons idered integral to the process. IDEM’s criteria for determining whether such baghouses should be c onsidered integral includes an evaluation of the annualized cost of purchasing, installing and operating the baghouse as co mpared to the cost savings from collecting and reusing the material that the baghouse captures. If there is an overwhelming cost savings from collecting and reusing the material captured by the baghouse, as compared to the annualized cost of purchasing, installing, and operating the baghouse, then such baghouse should be considered integral. ESSROC has not submitted sufficient information to make a deter mination as to whether these baghouses should be considered integral to the processes they control.

Comment #3

The permit is supposed to identify all conditions which are not federally enforceable. Title V of the CAA and 326 IAC § 2-7 authorize IDEM to impose "periodic monitoring" requirements in permits in those cases in which the applicable requirement does not provide for such. We recognize that such requirements would be federally enforceable to t he extent they are reasonable and not arbitrary or capricious. However, neither Title V nor § 2-7 authorizes monitoring requirements beyond those necessary to assure compliance. Thus, for inst ance, periodic visible emission observations would constitute periodic monitoring and would be federally enforceable. However, if periodic VE readings are required, additional requirements, such as paramet ric monitoring, baghouse inspections, etc. would notESSROC Cement Corporation Page 17 of 43 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore



### be mandated by the CAA or Rule 2-7, and w ould therefore not be federally enforceable.

Response #3

Indiana’s Title V rules concerning compliance monitoring are somewhat different than the corresponding federal counterpart. The provisions of 326 IAC 2-7-5(3) state that the Part 70 permits must include: “Monitoring and related record-keeping and reporting requirements which assure that all reasonable information is provided to evaluate continuous compliance with the applicable requirements.” IDEM believes that all of the monitoring requirements in the Part 70 permit are necessary to assure compliance and are therefore federally enforceable.

The requirements to monitor the pressure drop across the baghouses and also observe visible emissions from the stacks are not duplicative monitori ng. Visible emission notations are used to indicate whether emissions appear to be normal, while monitoring of the pressure drop of the baghouses provides an indication of whether the control device is operating properly. Since particulate limits are very low for these units (0.03 gr/dscf), an observa tion that visible emissions are “normal” would not necessarily indicate compliance with the particulate lim it, especially in the case where the control device might be operating at less than peak levels (which could be indicated by monitoring the pressure drop). Monitoring of the static pressure drop can alert the operator to relative changes (such as dust cake resistance) over a period of time. The operator c an use this information to chart trends and determine if the unit is operating within the optimal range as determined by baseline testing of the unit and manufacturer = s specifications. Pressure drop is an indi cator of a variety of conditions within the baghouse. Any deviations from the normal operati onal range of the unit, whether gradual or sudden, should alert the operator that the unit needs ma intenance. The Compliance Response Plan should include response steps to anticipate corrective ac tions when abnormal conditions arise. Both gradual and sudden changes in the pressure drop could result in damage to the bags if not properly addressed. Therefore, the OAQ believes that pressure drop readings should be taken at least once per shift, in addition to the visible emission observations. The r equirements to measure the pressure drops across the baghouses will remain unchanged in the permit.

Baghouse inspections are necessary in addition to the other monitoring requirements because an inspection can alert the operator to a problem with the baghouse that would not necessarily be identified by checking the pressure drop or the visible emissions from the stack. Identifying potential problems with the baghouse before excess emissions occur allows the Perm ittee to avoid potential violations or malfunctions.

Since all of these monitoring requirements are necessary to assure compliance with the emission limits in the permit, they are all federally enforceable pursuant to 326 IAC 2-7-5, which is a federally enforceable rule because it is part of Indiana’s approved Part 70 program. There has been no change to the permit as a result of this comment.



### Comment #4 (Compliance Monitoring Conditions)

The permit repeatedly seeks to impose redundant and unnecessary monitoring requirements. See, e.g. , sections D.1.7, D.1.8, D.1.9 and D.1.10. If visibl e emission observations are taken on a daily basis, this should be sufficient. Pressure drop readings, ins pections, etc. should be an alternative, not an additional requirement. EPA Region 7 published a "Policy on Periodic Monitoring for Opacity" in April 1997. A number of observations in that policy are re levant. Noting that Method 9 readings or COMs are not a practical solution for all situations, it suggested that the source could be required to certify that it conducted a visible emissions survey each day the plant operated and that it was or was not in compliance with the applicable limit. As an alternative , the policy notes, "a source may be able to showESSROC Cement Corporation Page 18 of 43 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore



### that a properly functioning baghouse should result in no excess visible emission as long as it operates within an established pressure drop range." In c ontrast to this reasoned approach, ESSROC’s permit requires VE readings as often as once per shift in addi tion to daily (or per shift) pressure drop readings, periodic baghouse inspections, and similar requirem ents for the ESPs on the kilns. These redundant requirements are merely cumulative and are not necessary.

Response #4

Compliance monitoring conditions such as this requi rement to perform visible emission notations, are required in order to demonstrate continuous complianc e with the permit requirements. Visible emission notations are used to indicate compliance with 326 IAC 5-1 and the particulate matter and opacity limits pursuant to 40 CFR 63, Subpart LLL and 326 IAC 6-1. Since bag failure can occur suddenly and without warning, possibly causing a violation of 326 IAC 5- 1, 326 IAC 6-1, or 40 CFR 63, Subpart LLL, the OAQ does not believe that less frequent notations would be sufficient for the Permittee to demonstrate continuous compliance.

The requirements to monitor the pressure drop across the baghouses and also observe visible emissions from the stacks are not redundant monitori ng. Compliance monitoring conditions such as this requirement to perform visible emission notations , are required in order to demonstrate continuous compliance with the permit requirements. Visible emission notations are used to indicate compliance with 326 IAC 5-1 and the particulate matter and opac ity limits pursuant to 40 CFR 63, Subpart LLL and 326 IAC 6-3-2. Since bag failure can occur suddenly and without warning, possibly causing a violation of 326 IAC 5-1, 326 IAC 6-3-2, or 40 CFR 63, Subpart LLL, the OAQ does not believe that daily visible emission notations would be sufficient for the Permittee to demonstrate continuous compliance. Once per shift visible emission notations are reasonabl e and necessary in order to demonstrate continuous compliance.

Visible emission notations are used to monitor the emissions from the stack, while monitoring of the pressure drop of the baghouses provides an indica tion of whether the control device is operating properly. An observation that visible emissions are “normal” would not necessarily indicate compliance with the particulate limit, especially in the case w here the control device might be operating at less than peak levels (which could be indicated by monitoring t he pressure drop). Monitoring of the static pressure drop can alert the operator to relati ve changes (such as dust cake resist ance) over a period of time. The operator can use this information to chart trends and determine if the unit is operating within the optimal range as determined by baseline testing of the unit and manufacturer = s specifications. Pressure drop is an indicator of a variety of conditions within t he baghouse. Any deviations from the normal operational range of the unit, whether gradual or sudden, should al ert the operator that the unit needs maintenance. The Compliance Response Plan should include respons e steps to anticipate corrective actions when abnormal conditions arise. Both gradual and sudden changes in the pressure drop could result in damage to the bags if not properly addressed. Theref ore, the OAQ believes that pressure drop readings should be taken at least once per shift, in addition to the visible emission observations.

See also response to comment #3. There has been no change to the permit as a result of this comment.

Comment #5 (Table of Contents)

C.24 (MACT Application Submittal Requirement) This listing in the Table of contents should be deleted because there is no associated permit condition in the body of the permit.

Response #5

IDEM agrees. The table of contents has been updated appropriately.ESSROC Cement Corporation Page 19 of 43 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore



### Comment #6 (Condition B.8 - Compliance with Permit Conditions)

Section B.8 (Compliance with Permit Conditions). This condition should be amended to reflect that fact that not every provision of the permit is an enforceable provision by adding the phr ase “except where it is otherwise stated in the permit” just before the phrase “is grounds for” in Condition B.8(a) and just after the phrase “not specifically designated as federally enforceable,” in Condition B.8(b).

Section B.8(a) (Compliance with Permit Conditions). In a January 31, 2002, draft amendment to NPD A/R 007 ("Guidelines for Submittal and Review of Annual Compliance Certifications . . . ."), IDEM states that " . . . a deviation from an emission limit or record keeping requirement in Section D would require that a deviation would also have to [be] identified for permit condition B.8, Compliance with Permit Conditions." We appreciate the fact that 40 C.F.R. § 70.6(a)(6)(i) requires this language, but there is nothing in Part 70, 326 IAC § 2-7 or the CAA which requires this clause be a separately enforceable provision of the permit. Requiring this to be listed as a separate deviation exposes Permittees to enforcement for at least two violations for every substantive deviation. Failure to prepare a PMP would be three violations (see, e.g. , sections B.8, B.11 and D.1.4). While we realize that EPA and IDEM could exercise enforcement discretion, Permittees would still be exposed to citizens’ suits. We suggest the following language as new section B.8(e):

A deviation from any other condition of this permit shall not give rise to a separate enforcement action for a violation of this section.

Response #6

The comment is in reference to the provisions that state that the Permittee must comply with all conditions of this permit, and that noncompliance is grounds for enforce ment action, permit termination, revocation and reissuance, etc. Permits issued under the Title V program in Indiana are enforceable by both the State and the U.S. EPA. IDEM cannot completely remove these provisions from the permit, because 326 IAC 2-7-5(6)(A) requires these provisions to be included in all Part 70 permits. However, IDEM does agree to move the provision from Section B of the permit to the title page of the permit. All subsequent conditions in Section B have been r enumbered appropriately. Condition B.8 has been deleted and changes to the title page of the permit are shown below.

B.8 Compliance with Permit Conditions [ 326 IAC 2-7-5(6)(A)] [326 IAC 2-7-5(6)(B)] (a) As provided in 326 IAC 2-7-5(6), the Permittee must comply with all conditions of this permit. Noncompliance with any provis ions of this permit is grounds for:

(1) Enforcement action;

(2) Permit termination, revocation and reissuance, or modification; or

(3) Denial of a permit renewal application.

(b) Noncompliance with any provision of this permit, except any pr ovision specifically designated as not federally enforceable, cons titutes a violation of the Clean Air Act.

(c) It shall not be a defense for the Permittee in an enforcement action that it would have been necessary to halt or reduce the permitted ac tivity in order to maintain compliance with the conditions of this permit.

(d) An emergency does constitute an affirmat ive defense in an enforcement action providedESSROC Cement Corporation Page 20 of 43 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore



### the Permittee complies with the applicable requirements set forth in Section B, Emergency Provisions.



# PART 70 OPERATING PERMIT OFFICE OF AIR QUALITY

ESSROC Cement Corporation Highway 31 Speed, Indiana 47172

(herein known as the Permittee) is hereby authorized to operate subject to the conditions contained herein, the source described in Section A (Source Summary) of this permit.

The Permittee must comply with all conditions of this permit. Noncompliance with any provisions of this permit is grounds for enforcement action; permit termination, revocation and reissuance, or modification; or denial of a permit renewal application. Noncompliance with any provision of this permit, except any provision specifically designated as not federally enforceable, constitutes a violation of the Clean Air Act. It shall not be a defense for the Permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this permit. An emergency does constitute an affirmative defense in an enforcement action provided the Permittee complies with the applicable requirements set forth in Section B, Emergency Provisions.

Comment #7 (Condition B.11 - Preventive Maintenance Plan)

Condition B.11(d) Preventive Maintenance Plan This condition should refer to the Operations and Maintenance (O&M) Plan. Additionally, other references to this plan in conditions C.17(a), (a)(2), (b)(1) and (b)(2) should also be corrected.

Response #7

The requested changes have been made as shown below. The condition has been renumbered B.10.

B.11 B.10 Preventive Maintenance Plan [326 IAC 2-7-5(1) ,(3) and (13)] [326 IAC 2-7-6(1) and (6)] [326 IAC 1-6-3]

(d) To the extent the Permittee is required by 40 CFR Part 63 to have an Operation, Maintenance, and Monitoring (OMM) Operations and Maintenance (O&M) Plan for a unit, such plan is deemed to satisfy the PMP requirements of 326 IAC 1-6-3 for that unit.

C.17 Compliance Response Plan - Preparation, Implementation, Records, and Reports [326 IAC 2-7- 5] [326 IAC 2-7-6] (a) The Permittee is required to prepare a Compliance Response Plan (CRP) for each compliance monitoring condition of this permit. If the Permittee is required to have an Operation, Maintenance, and Monitoring (OMM) Operations and Maintenance (O&M)ESSROC Cement Corporation Page 21 of 43 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore



### Plan under 40 CFR 63, such plan shall be deemed to satisfy the requirements for a CRP for those compliance monitoring conditions. A CRP shall be submitted to IDEM, OAQ upon request. The CRP shall be prepared within ninety (90) days after issuance of this permit by the Permittee, maintained on site, and comprised of:

(1) Reasonable response steps that may be implemented in the event that a response step is needed pursuant to the requirements of Section D of this permit; and an expected time frame fo r taking reasonable response steps.

(2) If, at any time, the Permittee takes reasonable response steps that are not set forth in the Permittee’s current Compliance Response Plan or OMM O&M Plan and the Permittee documents such response in accordance with subsection (e) below, the Permittee shall amend its Compliance Response Plan or OMM O&M Plan to include such response steps taken.

The OMM O&M Plan shall be submitted within the time frames specified by the applicable 40 CFR 63 requirement.

(b) For each compliance monitoring conditi on of this permit, reasonable response steps shall be taken when indicated by the provisions of that compliance monitoring condition as follows:

(1) Reasonable response steps shall be taken as set forth in the Permittee’s current Compliance Response Plan or OMM O&M Plan; or

(2) If none of the reasonable response st eps listed in the Compliance Response Plan or OMM O&M Plan is applicable or responsive to the excursion, the Permittee shall devise and implement additional response steps as expeditiously as practical. Taking su ch additional response steps shall not be considered a deviation from this permi t so long as the Permittee documents such response steps in accordance with this condition.

Comment #8 (Condition B.24 - Annual Fee Payment)

Condition B.24 The citation to 326 IAC 2-1.1-7 is listed twice.

Paragraph (b) should be deleted. 326 IAC 2-7-19 does not provide for permit revocation in response to non-payment. In any case, the provision is unnecessary and redundant because Condition B.8(a) already provides for revocation or enforce ment for non-compliance with a permit term.

Response #8

The title of the condition has been corrected to remove t he rule cite that was listed twice. The condition has been renumbered B.23

The requirements of 326 IAC 2-1.1-7 apply to all sour ces required to pay fees under any provision of 326 IAC 2. Therefore, 326 IAC 2-1. 1-7(7) is applicable, which spec ifies that nonpayment may result revocation of the permit.

B.24 B.23 Annual Fee Payment [326 IAC 2-7-19] [326 IA C 2-7-5(7)] [326 IAC 2-1.1-7] [326 IAC 2-ESSROC Cement Corporation Page 22 of 43 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore



### 1.1-7] (a) The Permittee shall pay annual fees to IDEM, OAQ within thirty (30) calendar days of receipt of a billing. Pursuant to 326 IAC 2-7-19(b), if the Permittee does not receive a bill from IDEM, OAQ the applicable fee is due April 1 of each year.

(b) Except as provided in 326 IAC 2-7-19(e), failure to pay may result in administrative enforcement action or revocation of this permit.

(c) The Permittee may call the following telephone numbers: 1-800-451-6027 or 317-233- 0425 (ask for OAQ, Technical Support and Modeling Section), to determine the appropriate permit fee.

Comment #9 (Condition C.5 - Operation of Equipment)

The requirement to always operate air pollution control equipment should be limited to those "necessary" to comply, instead of "used" to comply. There is a subtle difference between those words. A control device which is "used" to comply is always "us ed." If an EU can meet an applicable requirement even when a device is down for a brief period of time, this should not be a deviation if it is not "necessary" for that time even though it is "used" to comply.

Response #9

Calculations indicate that all the control equipment lis ted in this permit is necessary to comply with the emission limits listed in this permit. If the Permitt ee believes that some specific control devices are not necessary to comply with the emission limits in the permit, then the Permittee should, as a part of the Part 70 permit application, submit sufficient justificat ion showing that the specif ic control devices are not necessary for compliance. IDEM will review the specific information as part of the Title V review process, and make a determination as to which cont rol devices are necessary for compliance. The Permittee may also choose to conduct stack testi ng, in accordance with Section C - Performance Testing, to measure uncontrolled emission rates to show that uncontrolled emissions comply with the emission limits in the permit. If such testing is completed, IDEM will review the results and make appropriate changes to the permit if necessary. At this time, no changes have been made to Condition C.5.

Comment #10 (Condition C.12 - Ma intenance of Cont inuous Emission Monitoring Equipment)

Section C.12(d)(2) (Maintenance of Cont inuous Emission Monitoring Equipment). This section should be deleted. There is no economic ally or technically practicable way to perform supplemental or intermittent monitoring of the NOx em issions; that is why CEMS are required in the first place. ESSROC will agree that, if a CEMS goes down, it will maintain production at or below the level of operation on the most recent day that the CEMS was operational. Additionally, each of the provisions in Condition C.12 should only apply to CEMS required by the permit or necessary to comply with the permit.

Condition D.3.14(h) (Continuous Emission Monitoring) This provision should be deleted. It attempts to employ oxygen content and temperature of the kiln exhaust as a surrogate for NOx levels from the kiln when a NOx CEMS goes down. ESSROC does not believe this approach is valid, nor is it aware of any effective interim or surrogate NOx monitoring in place of a CEMS. ESSROC proposes that if the CEMS goes down, it will maintain production at or below the level of operation on the most recent day that the CEMS was operational. We believe these response steps are the only appropriate response steps that should be required.ESSROC Cement Corporation Page 23 of 43 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore



### Response #10

The Permittee is required to certify continuous compliance with all conditions of the permit. The Permittee must have sufficient information available in order to be able to certify continuous compliance. If the CEMS fails and the Permittee does not perfo rm any supplemental monitoring during the period of time when the CEMS is not operating, there will not be sufficient information available for the Permittee to be able to certify continuous compliance during that time period. Therefore, the permit must include a requirement to perform supplemental monitoring whenever the CEMS is not in operation and the emission unit is in operation.

Comment #11 (Condition C.14 - Pr essure Gauge and Other Instrument Specifications)

This section should be deleted. There is nothing in the cited authority which justifies its inclusion. Instrument specifications not set forth in 326 IA C § 3-5 should be included in the CRP, and not specified in the permit.

Response #11

IDEM believes that monitoring the pressure drop across the baghouses is important for determining the proper operation of the baghouses. In order to accurately measure the pressure drop, adequate pressure drop gauges must be used. The authority for t he condition is cited in the title of the condition.

Comment #12 (Condition C.17 - Compliance Response Plan - Preparation, Implementation, Records, and Reports)

Section C.17 (Compliance Response Plan - Preparation, Implementation, Records, and Reports). The permit imposes numerous specif ic monitoring requirements to measure compliance with applicable requirements. There should be a condition in the per mit which ties the monitoring requirements to the annual compliance certification. We suggest a new paragraph C.17(g) to read:

Compliance with the specific monito ring conditions of this Permit will provide sufficient data to evaluate and determine continuous compliance with the applicable requirement.

Section C.17(b)(2) and (b)(4) There may be instances in which the operator coul d conclude that an otherwis e appropriate or required response step is not necessary to address a specific excursion above or below a parametric range. In addition there may be instances where no response step is indicated by the CRP or necessary at all. Therefore, Condition C.17(b)(2) should include the phr ase “, as necessary.” after “as expeditiously as possible” and Condition C.17(b)(4) should be revised to read: “Failure to take response steps in accordance with the Compliance Response Plan shall be considered a deviation from the permit if such failure results in a violation of the underlying applicable requirement

. Section C.17(b)(3) There is no justification for requiring the source to report a shut down of the emissions unit. The reporting requirement must be limited to situations in which the control device is shut down, but the unit continues to operate.

Response #12

IDEM does not agree that the monitoring conditions in the permit provide sufficient data to evaluate andESSROC Cement Corporation Page 24 of 43 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore



### determine continuous compliance for all emission units. Some emission units at the plant do not have any specific compliance monitoring requirements listed in the permit. In those cases, the Permittee must rely on their own observations or other credible ev idence to evaluate compliance or noncompliance with any applicable requirements.

IDEM does not agree that the phrase “as necessa ry” is needed in paragraph (b)(2) of the condition, because the condition already says “If none of the reasonable response steps listed in the Compliance Response Plan or O&M Plan is applicable or responsiv e to the excursion...” IDEM believes this is exactly the situation which would make additional response steps “necessary.”

Paragraph (b)(4) cannot be changed as requested becaus e IDEM requires that if none of the listed response steps in the CRP are responsive to the excursion, the Permittee must devise and implement additional response steps. Additionally, the failure to take any response steps in the event of an abnormal or out of range reading is considered to be a deviation from the permit, regardless of whether it results in a violation of an emission limit. Additionally, If the Permittee notices an out of range or abnormal condition and fails to respond to it, then the Permittee would have no way of knowing if the abnormal or out of range reading resulted in a viol ation. The purpose of the CRP is to prevent a violation of an emission limit.

Paragraph (b)(3) of the condition has been changed to only require the notification when the Permittee determines that the necessary response to an abnor mal or out of range condition is to shutdown an emission unit or control device, but the shutdown will not occur for at least ten days. The notification requirement is intended to apply only to situations where the emissions unit will continue to operate for an extended period of time while the compliance monito ring parameter is out of range. It is intended to provide IDEM an opportunity to assess the situation and determine whether any additional actions are necessary to demonstrate compliance with any applicable requirements.

The Condition has been changed as follows:

C.17 Compliance Response Plan - Preparation, Implementation, Records, and Reports [326 IAC 2-7- 5] [326 IAC 2-7-6]

(b) .....

(3) If the Permittee determines that additional response steps would necessitate that the emissions unit or control device be shut down, and it will be 10 days or more until the unit or device will be shut down, then the Permittee shall promptly notify the IDEM, OAQ shall be promptly notified of the expected date of the shut down, the status of the applicable compliance monitoring parameter with respect to normal, and the results of the actions taken up to the time of notification.

Comment #13 (Condition C.19 - Emission Statement)

The closing parenthetical is missing in the rule citation in this paragraph.

Response #13

IDEM acknowledges the typographical error; how ever the condition has been revised because the emission statement rule, 326 IAC 2-6, has been revised. Final changes to the rule were adopted by theESSROC Cement Corporation Page 25 of 43 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore



### board on December 3, 2003. These changes to the condition allow the Permittee to comply with the revised rule once the revisions are final, rather than first needing to obtain a permit modification. Changes to the condition are shown below.

C.19 Emission Statement [326 IAC 2-7-5(3)(C )(iii)] [326 IAC 2-7-5(7) ] [326 IAC 2-7-19(c)] [326 IAC 2-6] (a) The Permittee shall submit an annual emission statement certified pursuant to the requirements of 326 IAC 2-6

. , that must be received by April 15 of each year This statement must be received in accordance with the compliance schedule specified in 326 IAC 2-6-3 and must comply with the minimum requirements specified in 326 IAC 2-6-4. The submittal should cover the pe riod identified in 326 IAC 2-6. The annual emission statement shall meet the following requirements:

(1) Indicate estimated actual emissions of criteria pollutants from the source, in compliance with 326 IAC 2-6 (Emission Reporting);

(2) Indicate estimated actual emissions of regulated pollutants as defined by 326 IAC 2-7-1(32) (“Regulated pollutant which is used only for purposes of Section 19 of this rule”) from the source, fo r purposes of Part 70 fee assessment.

(b) The annual emission statement covers the twelve (12) consecutive month time period starting December 1 and ending November 30. The annual emission statement must be submitted to:

The statement must be submitted to:

Indiana Department of Environmental Management Technical Support and Modeling Section, Office of Air Quality 100 North Senate Avenue, P. O. Box 6015 Indianapolis, Indiana 46206-6015

The emission statement does require the certification by the “responsible official” as defined by 326 IAC 2-7-1(34).

(c) The annual emission statement required by this permit shall be considered timely if the date postmarked on the envelope or certified mail receipt, or affixed by the shipper on the private shipping receipt, is on or before the date it is due. If the document is submitted by any other means, it shall be c onsidered timely if received by IDEM, OAQ, on or before the date it is due.

Comment #14 (Condition C.22 - NESHAP No tification and Repor ting Requirements)

Sections C.22(a) through (f) (NESHAP Notification and Reporting Requirements). ESSROC has already submitted the various notifications listed in these sections. These sections should therefore be deleted or modified to reflect this fact. Also, the word “immediately” at the end of the first sentence of C.22(a) should be deleted. Since all notifications have been submitted, the mailing address for notifications is unnecessary and paragraph (f) should be deleted.

Response #14

The requirement to submit the notifications is an applicable requirement pursuant to 40 CFR 63. Pursuant to 326 IAC 2-7-5(1), the Title V permit must include all applicable requirements. Even if theESSROC Cement Corporation Page 26 of 43 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore



### Permittee has already submitted one or more of t he notifications, the requirement is still an applicable requirement. Paragraph (a) has been changed consis tent with the other requirements to submit notifications. The typographical error has also been corrected.

The reports listed in this condition must be submitt ed to IDEM and EPA. IDEM has not yet incorporated the NESHAPs into the SIP; therefore, EPA is still responsible for enforcing the NESHAPs.

C.22 NESHAP Notification and Reporting Requirements [40 CFR Part 63, Subparts A, and LLL] The Permittee shall comply with all reporting provisions specified in 40 CFR Part 63, Subpart LLL, and in particular:

(a) The Permittee has submitted shall submit an initial notification in accordance with 40 CFR 63.9(b) (Subpart A, General Provisions) immediately . The Permittee provided the following information:

(1) The name and address of the Permittee;

(2) The address (i.e., physical location) of the affected source;

(3) An identification of the relevant standard, or other requirement, that is the basis of the notification and the source's compliance date;

(4) A brief description of the nature, size, design, and method of operation of the source, including its operating design capacity and an identification of each point of emission for each hazardous air pollutant, or if a definitive identification is not yet possible, a preliminary identification of each point of emission for each hazardous air pollutant; and

(5) A statement of whether the affected source is a major source or an area source.



### Comment #15 (NESHAP Conditions)

We recognize that a Part 70 permit is supposed to contain all applicable requirements and IDEM is reluctant to merely incorporate them by reference. We also realize that the NESHAPS are voluminous. Nevertheless, regurgitating some part of a NESHAP r equirement and incorporating the rest is the worst of both worlds. We suggest that any NESHAP be reproduced in total in an appendix to the permit and incorporated by reference into the text of the permit. In this way, the text of the permit will be easier to reference for review and compliance, especially during an inspection, and the public will still have ready access to the text of the subparts in the appendix. T here are a number of specif ic places in the permit where requirements, exemptions, exceptions, alternatives, etc. in the NESHAP were misstated or omitted. The same may be true of requirements incorporated from other CAA programs and IDEM rules.

Response #15

IDEM, OAQ is required to identify all applicable requirements in the Part 70 permit that apply to each emissions unit and to identify how the owner or oper ator will comply with the requirements for each unit in accordance with 326 IAC 2-7-5. Subsections 1 and 3 of 326 IAC 2- 7-5 specifically require that emissions limitations and standards, operational requirements, monitoring requirements, record keeping requirements, and reporting requirements are incl uded in the Part 70 permit and that all reasonable information to evaluate continuous compliance with the applicable requirements is included in the permit. The National Emissions Standards for Haza rdous Air Pollutants (NESHAPs) are typically very detailed, complex rules. Each NESHAP may cover di fferent types of emissions units as well as groupsESSROC Cement Corporation Page 27 of 43 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore



### of emissions units. Furthermore, each NESHAP may have several options available for each emissions unit from which an owner or operat or may choose to comply with the NESHAP requirements. Because of the complex nature of these requirements, in order to satisfy the permit content requirements, it is necessary to specify exactly which emissions units are subject to the NESHAP, which portion of the NESHAP requirements apply to each emissions unit, and which associated compliance option is being used.

This level of detail is particularly important because there are several stakeholders that need detail beyond a simple reference to a rule in order to us e the permit or in order to benefit from the permit. IDEM, OAQ and the United States Environmental Protection Agency must be able to immediately identify the exact applicable NESHAP requirements and det ermine if the owner or operator is complying with the NESHAP requirements. The public has the l egal authority under the Clean Air Act to know if a source is subject to a particular requirement and how the owner or operator of that source chooses to comply with that requirement. The owner or oper ator is granted a permit shield under 326 IAC 2-7-15 that provides that compliance with the conditions of the permit shall be deemed in compliance with any applicable requirements as of the date of permit iss uance, provided that the applicable requirements are included and specifically identified in the permit. Theref ore, in order to satisfy the requirements of the Part 70 rules and the needs of all of the permit stakehol ders, it is necessary to incorporate the NESHAP requirements with as much detail as is needed to identify the portions of the rule that apply and how the owner or operator will comply with the requirements.

Comment #16 (Conditions D. 1.1, D.2.5, a nd D.3.2 - Prevention of Significant De terioration)

Section D.1.1(b), D.2.5, and D.3.2. Many of the units listed in these sections have PTE below the PSD significance level. Because of this, hourly mass limits are not necessary to limit its emissions below PSD significance levels. We do not understand why you seek to place PSD limits on a non-PSD unit.

Response #16

These conditions do not place PSD limits on these units . These conditions state the limits necessary to render the requirements of 326 IAC 2-2 (PSD) not applicable.

The uncontrolled PTE of the units exceed the PSD signi ficance thresholds. The limits of 0.03 grains per dry standard cubic foot of exhaust air, pursuant to 326 IAC 6-1-2, are not sufficient to render the requirements of PSD not applicable, unless the maximu m flow rate is also established as an enforceable condition of the permit. Therefore, IDEM has included additional limits sufficient to limit the PTE below the PSD significance level.

Comment #17 (Condition D.1. 1 - Prevention of Signi ficant Deterioration)

Section D.1.1(c). There is no practical means by wh ich to measure emissions from t he drills. The 1.3 lb./hole limit is based on AP-42. Please make this condition more accurate by replacing the phrase “and the PM emissions shall not exceed 1.3 pounds per hole” with a sentence which reads: “[a]t the AP-42 factor rate of 1.3 pounds per hole, this is an effective limit of 24.7 tpy.”

Response #17

The quarry drilling process was constructed and began oper ation in 1982, which is after the effective date of the PSD regulations. ESSROC is a portland cement manufacturing plant which is one of the 28 listed source categories; therefore fugitive emissions must be counted in the PSD applicabilityESSROC Cement Corporation Page 28 of 43 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore



### determination. The unlimited PTE of the drilling proce ss exceeds 25 tons per year of PM. Therefore, an enforceable limit must be established to render t he requirements of PSD not applicable. IDEM used the AP-42 emission factor of 1.3 pounds per hole and then determined the number of holes that could be drilled without exceeding the PSD significance levels. Using the emission factor of 1.3 pounds per hole, the number of holes which can be drilled each year without exceeding the PSD significance levels is 38,000 holes. Therefore, a limit of 38,000 holes drill ed per year, combined with an emission limit of 1.3 pounds per hole, will render the requirements of PSD not applicable. Without a specific emission limit, the condition is not enforceable, and the unit would need to be reviewed pursuant to the requirements of the PSD regulations.

Comment #18 (Condition D.1.5 - Testing Requirements)

Section D.1.5. EU 155 has a PTE below PSD significance levels. Ther e is no reason to test it. At any rate, it is currently not in operation. If you must keep this section, please revise it to require testing “within 180 days after the effective date of this permit or within thirty (30) days following startup of the unit, whichever occurs later.”

Response #18

Based on the information the Permittee provided in the Part 70 application, the baghouse controlling the CKD sales loadout (kiln #1 dust tank) EU155 has a maximum outlet grain loading of 0.04 gr/acfm at ambient temperature. This is equivalent to 0.04 gr /dscf which would not comply with the requirements of 326 IAC 6-1-2 which requires a particulate matter limit of 0.03 gr/dscf. Since calculations indicate that the unit may not be in compliance with the requirements of 326 IAC 6-1-2, IDEM is requiring a stack test to demonstrate compliance with the rule. Since the emission unit is permitted to operate at any time, IDEM prefers to require a stack test within 180 day s of permit issuance, rather than wait until the Permittee decides to begin using the unit again. If the Permittee does not plan to operate the unit, then the Permittee can agree to shut it down permanently rather than including it in the Part 70 permit.

Comment #19 (Compliance Monito ring Requirements for Baghouses)

Conditions D.1.6, D.2.10, and D.3.18 (Visible Emissions Notations). There is no justification for this provision which seeks to impose a requirement for VE readings which is more stringent than the NESHAP. This section should be deleted because the O&M plan required by Subpart LLL will cover most of these requirements. ESSROC will take VE readings of all units covered by LLL in accordance therewith. For units not co vered, ESSROC proposes monthly readings. Also, the permit should state that failure to take response st eps in accordance with the CRP shall be considered a deviation, and a not a violation, and then only if such failure results in a violation of an underlying applicable requirement.

Conditions D.1.6 through D.1.9, Conditions D.2.10. - D.2.13, Conditions D.3.18 - D.3.21. See Comment 4. Additionally, as we informed you earlier, different baghouses at the Speed plant operate within different ranges. ESSROC will include thes e in the CRP; it will not accept these as permit conditions. If parametric monitoring is to be select ed in lieu of VE readings, the pressure drop should be recorded once per week and the condition should refer to readings “outside the range established in the CRP.” Finally, requiring calibration every six months is more frequent than necessary to assure compliance.

Section D.1.10, D.2.15, and D.3.22. These sections will need to be revised to reflect revisi ons to, or deletions of, sections D.1.6 - D.1.10,ESSROC Cement Corporation Page 29 of 43 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore



### D.2.10 - D.2.13, and D.3.18 - D.3.21.

Response #19

IDEM includes the normal pressure drop ranges in t he permit to ensure that t he listed normal ranges are not so wide as to make pressure drop readings a futile exercise. The Permittee indicated in the Part 70 application that the normal pressure drop range for each baghouse was 2 to 8 inches of water. IDEM has repeatedly informed the Permittee that if the r anges listed in the Part 70 permit application are not the correct normal pressure drop ranges for some of the baghouses, then the Permittee must submit the correct ranges to IDEM for inclusion in the permit. Refusal to submit the requested information forces IDEM to act on the Part 70 permit application based on the information that the Permittee has already submitted in the Part 70 permit application.

The Permittee must take response steps each time the pressure drop is outside the range listed in the permit. Failure to take a response step would be a deviation from the permit and IDEM could take enforcement action against the Permittee for these devia tions. It is not acceptable for the CRP to state a different normal pressure drop range than the permit states. If for some reason the normal pressure drop range changes, the Permittee may apply for an administrative amendment to change the listed normal pressure drop range in the permit.

The requirements to monitor the pressure drop across the baghouses and also observe visible emissions from the stacks are not redundant monitori ng. Compliance monitoring conditions such as this requirement to perform visible emission notations , are required in order to demonstrate continuous compliance with the permit requirements. Visible emission notations are used to indicate compliance with 326 IAC 5-1 and the particulate matter and opac ity limits pursuant to 40 CFR 63, Subpart LLL and 326 IAC 6-3-2. Since bag failure can occur suddenly and without warning, possibly causing a violation of 326 IAC 5-1, 326 IAC 6-3-2, or 40 CFR 63, S ubpart LLL, the OAQ does not believe that monthly visible emission notations would be sufficient for the Permittee to demonstrate continuous compliance.

Visible emission notations are used to monitor the emissions from the stack, while monitoring of the pressure drop of the baghouses provides an indica tion of whether the control device is operating properly. An observation that visible emissions are “normal” would not necessarily indicate compliance with the particulate limit, especially in the case w here the control device might be operating at less than peak levels (which could be indicated by monitoring t he pressure drop). Monitoring of the static pressure drop can alert the operator to relati ve changes (such as dust cake resist ance) over a period of time. The operator can use this information to chart trends and determine if the unit is operating within the optimal range as determined by baseline testing of the unit and manufacturer = s specifications. Pressure drop is an indicator of a variety of conditions within t he baghouse. Any deviations from the normal operational range of the unit, whether gradual or sudden, should al ert the operator that the unit needs maintenance. The Compliance Response Plan should include respons e steps to anticipate corrective actions when abnormal conditions arise. Both gradual and sudden changes in the pressure drop could result in damage to the bags if not properly addressed. Theref ore, the OAQ believes that pressure drop readings should be taken at least once per shift, in addition to the visible emission observations.

The Permittee has stated that calibration of pressure gauges every six months is more frequent than necessary to assure compliance; however, the Permittee has not suggested an alternative frequency which they believe would be sufficient to assure compliance. Additionally, in order for IDEM to be able to consider changing the required frequency for calibrating the pressure gauges, the Permittee must submit some justification (such as manufacturer’s recommendations) for why less frequent calibration is sufficient.



### All compliance monitoring conditions in the permit have been revised to indicate that failure to takeESSROC Cement Corporation Page 30 of 43 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore



### response steps is a deviation from the permit. One example of the change is shown below.

D.1.6 Visible Emissions Notations

(e) If visible emissions are observed crossing the property line, the Permittee shall implement the appropriate procedures as set out in its Compliance Response Plan. 

### Failure to take response steps in accordance with Se ction C - Compliance Response Plan - Preparation, Implementation, Records, and Reports, shall be considered a violation of deviation from this permit.

(f) If visible emissions are present at any baghouse stack, the Permittee shall implement appropriate procedures as set out in its Compliance Response Plan for such facility. 

### Failure to take response steps in accordance with Section C - Compliance Response Plan - Preparation, Implementation, Records, and Reports, shall be considered a violation of deviation from this permit.

Comment #20 (Condition D.2. 1 - Particulate Matter)

Section D.2.1. For EU 73 and EU 74, see our comments to section D.1.2 regarding the nonapplicability of 326 IAC 6-1- 2. Emission units 37, 39, 41, 44, 45, 46, 47, 73, 74, 124, 135, 146, 154, and 155 are all downstream from the clinker cooler, are controlled by baghouses, and have PM PTE less than 100 tpy and actual emissions less than 10 tpy. See our Comments 2 and 3. They should be deleted from this section.

Response #20

There has been no change made to the permit as a result of this comment. Please see the response to comment #2.

Comment #21 (Conditions D.2.6 and D.3.9 - Preventive Maintenance Plan)

The date references are obsolete and s hould be removed from these conditions.

Response #21

Since Condition B.11 (now B.10) (Preventive Maintenance Plan) already explains that, to the extent the Permittee is required to have an O&M Plan, such plan can satisfy the requirement to have a PMP, the second sentence of Conditions D.2.6 and D.3.9 has been deleted.

D.2.6 Preventive Maintenance Plan [326 IAC 2-7-5(13)] [40 CFR 63, Subpart LLL] A Preventive Maintenance Plan, in accordance wi th Section B - Preventive Maintenance Plan, of this permit, is required for the control devices listed in this section. If the Operations and Maintenance Plan required by Condition D.2.9 is developed in accordance with Section B - Preventive Maintenance Plan, then after June 14, 2002, the Operations and Maintenance Plan shall satisfy this condition.

D.3.9 Preventive Maintenance Plan [326 IAC 2- 7-5(13)] [326 IAC 10-3] [40 CFR 63, Subpart LLL] A Preventive Maintenance Plan, in accordance wi th Section B - Preventive Maintenance Plan, of this permit, is required for all of the control devices listed in this section, and for the kilns and clinker coolers. If the Operations and Maint enance Plan required by Condition D.3.15 is developed in accordance with Section B - Preventive Maintenance Plan, then after June 14, 2002, the Operations and Maintenance Plan shall satisfy this condition.ESSROC Cement Corporation Page 31 of 43 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore



### Comment #22 ( Condition D.2.7 - Testing Requirements)

ESSROC has already completed the testing requir ed by paragraph (a). The condition should be deleted or modified to reflect this fact.

Some of all of the units listed in paragraph (b) should not be subject to testing, either because they are physically unable to be tested or due to the small amount of emissions from the unit. Due to other pressing business, we have not been able to put together a specific list of which units are affected by these issues. If IDEM wishes to discuss this iss ue with us, we will be happy to provide a more detailed description.

Response #22

Based on the information the Permittee provided in the Part 70 application, all of the baghouses at the plant are guaranteed to control emissions within a range of 0.02 to 0.04 gr/acfm at ambient temperature. This indicates that the outlet grain l oading could be as high as 0.04 gr/dscf. An outlet grain loading of 0.04 gr/dscf would not comply with the requirements of 326 IAC 6-1-2, which requires a particulate matter limit of 0.03 gr/dscf. Since calculat ions indicate that many of the units at this plant may not be in compliance with the requirements of 326 IAC 6-1-2, IDEM is requiring stack testing for a representative number of baghouses at the plan t, to demonstrate compliance with the rule.

IDEM cannot fully respond to this comment without more specific information as to which units are not physically able to be tested and why.

Comment #23 (Condition D.2.14 -Transformer-Rectifier (T-R) Sets)

This condition should be deleted becaus e there are no emission units in Section D.2 of the permit that are controlled by an ESP.

Response #23

IDEM agrees. All of the units controlled by ESPs are listed in Section D.3 of the permit. Condition D.2.14 has been deleted. All subsequent condi tions in Section D.2 have been renumbered appropriately.

D.2.14 

### Transformer-Rectifier (T-R) Sets [326 IAC 2-7-6(1)] [326 IAC 2-7-5(1)] (a) The ability of the ESP to control particulate emissions shall be monitored once per shift, when the unit is in operation, by measuring and recording the number of T-R sets in service and the primary and secondary voltages and the currents of the transformerrectifier (T-R) sets.

(b) Reasonable response steps shall be taken in accordance with Section C - Compliance Response Plan - Preparation, Implementation, Records, and Reports whenever the percentage of T-R sets in service falls below 90 percent (90%). T-R set failure resulting in less than 90 percent (90%) availability is not a deviation from this permit. Failure to take response steps in accordance with Section C - Compliance Response Plan - Preparation, Implementation, Records, and Reports, shall be considered a violation of this permit.

Comment #24 (Condition D.3.5 - NESHAP Em ission Limitations)ESSROC Cement Corporation Page 32 of 43 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore



### ESSROC believes IDEM’s statement of the appropriate opacity standards regarding the kiln #2 and raw mill are incorrect and should be amended to accurately reflect the standard applicable depending on the mode in which the system is operating.

Response #24

Since the Todd furnace is available to provide heat to the raw mill, the raw mill does not meet the definition of an in-line raw mill. This is becaus e an in-line raw mill is one that is completely dependent upon the kiln for heat, and cannot be operated without heat from the kiln. Since the raw mill at this plant has an alternate heat source, it is possible to oper ate the raw mill when the kiln is shutdown and no heat is available from the kiln. Therefore, the permit states that the opacity limit for the ESP controlling the kiln and the raw mill is 10% whenever the raw mill is in operation. Whenever the raw mill is shutdown and only the kiln is in operation, the opacity limit for the ESP is 20%.

Comment #25 (Condition D.3.7 - NOx Emissions)

ESSROC disagrees with IDEM’s statement in paragraph (c ) that kiln #1 is not in compliance with these requirements and will provide additional information to IDEM regarding this issue.

Response #25

The information from the NOx continuous emissions monitor indicates that NOx emissions from kiln #1 have been in excess of the NOx emission limit required by 326 IAC 10-1. This matter is still pending with IDEM’s Office of Enforcement. Until the matter is resolved, IDEM agrees that the permit does not need to state that the unit is not in compliance with the limit. When/if a compliance schedule is finalized, the permit will be revised to include such requirements.

D.3.7 NOx Emissions [326 IAC 10-1] [326 IAC 10-3] Pursuant to 326 IAC 10-3, beginning on May 31, 2004, the requirements of paragraph (a) below shall apply during the ozone control period of each year. Pursuant to 326 IAC 10-1, at all other times, the requirements of paragraph (b) below shall apply. The requirements of paragraph (c) below shall apply at all times.

(a) Pursuant to 326 IAC 10-3, kiln #2 shall be equipped with low-NOx burners.

(b) Pursuant to 326 IAC 10-1, NOx emissions from the dry preheater rotary cement kiln #2 (EU27) shall not exceed 5.9 pounds per ton of clinker produced on an operating day basis and 4.4 pounds per ton clinker produced on a thirty (30) day rolling average basis.

(c) Pursuant to 326 IAC 10-1, NOx emissions from the long dry rotary cement kiln #1 (EU20) shall not exceed 10.8 pounds per ton of clinker produced on an operating day basis and six (6.0) pounds per ton of clinker produced on a thirty (30) day rolling average. IDEM has information that indicates that kiln #1 (EU20) is not in compliance with this rule. The OAQ will promptly reopen this permit using the provisions of 326 IAC 2-7-9 (Permit Reopening) to include detailed requirements necessary to comply with this rule and a schedule for achieving compliance with such requirements.

D.3.14 Continuous Emissions Monitoring [326 IAC 3-5] [326 IAC 2-7-6(1),(6)] [40 CFR 63, Subpart LLL] [326 IAC 10-1] [326 IAC 10-3]

(g) In order for kiln #1 to come into compliance with the requirements of 326 IAC 10-1, theESSROC Cement Corporation Page 33 of 43 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore
Permittee shall comply with one of the following options:

(1) The NOx CEM on kiln #1 shall pass an OAQ approved RATA test within 90 days after issuance of this permit; or

(2) The Permittee shall install a new NOx CEM on kiln #1 and pass an OAQ approved RATA test within 120 days after issuance of this permit. The NOx CEMs shall be certified according to procedures contained in 326 IAC 3 and 40 CFR 75 as applicable.

(h) (g) 

### In the event that a nitrogen oxide CEMS fails, the Permittee shall monitor the oxygen content and temperature of the kiln exhaus t at least once per hour. If the oxygen content or temperature is outside the range established in the latest compliance stack test, the Permittee shall take reasonable re sponse steps in accordance with Section C - Compliance Response Plan - Preparation, Implementation, Records, and Reports. Failure to take response steps in accordance with Section C - Compliance Response Plan - Preparation, Implementation, Records, and Reports, shall be considered a deviation from this permit.

Comment #26 (Condition D.3.10 - Testing Requirements)

Delete the requirement to test every 2.5 years; ther e is no authority for it. For the remaining subsections, testing requirements (performance and timing) must comply with, but be no more stringent than, Subpart LLL.

ESSROC recently completed the testing required by the NESHAP. These sections should be deleted or changed to reflect that, and require additional testing no more frequently than required by the NESHAP.

The requirement to operate the equipment at 95% or more of maximum operating capacity during performance tests should be amended to track the l anguage of 326 IAC 3-6-3, which requires that the facility be operating at 95% to 100% of permitted operat ing capacity, where “capacity” is defined as “the design capacity of the facility or other operating capacities agreed to by the source and the department” under 326 IAC 3-6-3(a)(3).

Response #26

IDEM has the authority under 326 IAC 2-1.1-11 to require testing at any time to assure compliance with all applicable requirements. Additionally, IDEM has the authority under 326 IAC 2-7-6(1) to require periodic testing to determine on-going compliance with the emission limits in the permit. Therefore, IDEM may require testing more frequently than 40 CFR 63, Subpart LLL requires. IDEM has determined that the kilns and clinker coolers should be tested every 2.5 years to show compliance with applicable rules.

The requirement to complete the initial testing is an applicable requirement pursuant to 40 CFR 63. Pursuant to 326 IAC 2-7-5(1), the Title V permit must include all applicable requirements. Even if the Permittee has already completed the initial testing, the requirement is still an applicable requirement.

Since it is not possible for a unit to operate above 100% of it’s maximum production capacity, it is not necessary to state a range that has an upper limit of 100%. Rather, it is sufficient to state that the unit must operate at 95% of its maximum production capacit y or more. The definition of “capacity” does not need to be part of the permit condition. The condition already references the rule 326 IAC 3-6-3, which includes the definition of “capacity.”ESSROC Cement Corporation Page 34 of 43 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore



### Comment #27 (Condition D.3.12 - Sulfur Dioxide Emissions and Sulfur Content)

ESSROC would like similar wording in D.3.12 to that found in D.3.13(a)(1) that would allow the use of vendor analysis for documentation and calculation of SO 2 

### emission compliance.

Response #27

Pursuant to 326 IAC 3-7-4(b), an owner or operat or may rely upon sampling and analysis procedures performed by the vendor prior to delivery. 326 IA C 3-7-2 and 326 IAC 3-7-3 do not allow the owner or operator to rely upon sampling and analysis procedur es performed by the vendor. There has been no change to this condition as a result of this comment.

Comment #28 (Condition D.3.10 - Testing Requirements)

Section D.3.10. Delete emission units 149, 150 and 151. These are subject to Subpart LLL, not Y. See, 40 CFR §63- 1356(b) as amended 4/5/02.

Response #28

Emission unit 149 is the coal dust silo; emission unit 150 is the coal weigh system; and emission unit 151 is the coal handling system. The NESHAP for Portland Cement Plants, 40 CFR 63, Subpart LLL, was amended on April 5, 2002. In the background information for the amendments, EPA explains that “Section 63.1356 of the final rule is being revised to clarify that the systems used to convey and transfer coal from the coal mill to the kiln at portland cement plants that are major sources of HAP are not subject to the NSPS for coal preparation plant (40 CFR Part 60, Subpart Y). The final portland cement NESHAP already covers conveying system transfer points associated with coal preparation plants at portland cement plants that are major sources. There is no need for these sources to be subject to duplicative requirements, i.e., to also be covered by the NSPS for coal preparation plants. Further, these emission sources will be subject to more stringent opacity requirement (10 percent) under the NESHAP than under the NSPS for coal preparation plants (40 CFR Part 60, Subpart Y). Other coal conveying transfer points will continue to be subject to the NSPS for coal preparation plants.”

Since ESSROC is a major source of HAPs and em ission units 149, 150, and 151 are conveyor transfer points associated with the coal preparation plant that are subject to the requirements of the portland cement NESHAP, IDEM agrees that according to the rule at 40 CFR 63.1356, they are exempt from the requirements of the NSPS for coal preparation plants (40 CFR Part 60, Subpart Y). Condition D.3.10 and Condition D.3.12(b) have been changed as shown below.

D.3.8 NSPS for Coal Preparation Plants [326 IAC 12] [40 CFR 60, Subpart Y] (a) The provisions of 40 CFR Part 60, Subpart A - General Provisions, which are incorporated by reference in 326 IAC 12-1, apply to the facilities listed in paragraph (b) below, and as described in this section except when otherwise specified in 40 CFR Part 60, Subpart Y.

(b) 

### Pursuant to 40 CFR 60, Subpart Y, the fo llowing conditions shall apply to the coal handling, milling, and storage facilities, including the coal (crusher) mill #2 (EU67), and the fuel oil-fired air heater for kiln #2 (EU69) , the kiln #2 coal dust silo (EU149), the kiln #2 coal weigh system (EU150), and the kiln #2 coal handling system (EU151) :

(1) The opacity from each of these fa cilities shall be less than 20 percent.ESSROC Cement Corporation Page 35 of 43 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore



### (2) The particulate matter emissions from the coal (crusher) mill #2 (EU67) shall not exceed 0.031 grains per dry standard cubic foot of exhaust air (0.070 g/dscm).

(3) The Permittee shall install, calibrate, maintain, and continuously operate a monitoring device for the measurement of the temperature of the gas stream at the exit of the coal (crusher) mill #2 (EU67) on a continuous basis. The monitoring device is to be certified by the manufacturer and be accurate within plus or minus 3 degrees Fahrenheit. The monitoring device shall be recalibrated annually in accordance with the procedures specified in 40 CFR 60.13(b).

D.3.10 Testing Requirements [40 CFR 63, Subpart LLL] [326 IAC 20-27-1][326 IAC 2-7-6(1)(6)] [326 IAC 2-1.1-11]

(b) 

### Pursuant to 40 CFR 60, Subpart Y, the Permittee shall conduct a Method 5 stack test to determine compliance with the particulate matter emission limit for the coal (crusher) mill #2 (EU67) in 40 CFR 60, Subpart Y, and Conditi on D.3.8. The Permittee shall conductMethod 9 opacity tests to determine compliance with the opacity limits for the fuel oilfired air heater for kiln #2 coal mill (EU69), kiln #2 coal dust silo (EU149), kiln #2 coal weigh system (EU150), and kiln #2 coal handling system (EU151) in Condition D.3.8. These tests shall be conducted within 180 days after issuance of this permit. These tests shall be conducted in accordance with Section C - Performance Testing.

Comment #29 (Condition D.3.14(f) - Continuous Emissions Monitoring)

ESSROC cannot comply with this provision because the alkali bypass is not in use and has not been used for a number of years. Therefore, it woul d not be possible to calibrate the unit. In addition, ESSROC intends to perform testing to determine if NOx emissions from the bypass stack can be calculated using flow meters and oxygen analyzers. ESSR OC would accept this provision if the phrase “or an alternative methodology to accurately measure or calculate NOx emissions from” were inserted after the word “on” in the third line, and the deadline was changed to read 180 days after “the effective date of this Condition, or the startup of the alkali bypass, whichever is later.”

On February 13, 2004, Jim Hauck of Baker and Daniels, on behalf of ESSROC Cement Corporation, provided supplemental comments on this issue, as follows.
As we discussed in our January 22, 2004 meeting, the alkali bypass, which is an additional emissions point for kiln #2, is used only when the chemical com position of raw materials from the quarry require it. This has not been the case for several years, but is it expected that ESSROC will need to direct gasses through the bypass stack in the future. Because it is impossible to calibrate or test a CEMs with no flow, and wasteful to require expensive monitoring equipment when nothing is being emitted through this stack to the atmosphere, ESSROC proposed that it not be required to have a CEMS in place unless gasses are flowing through the bypass stack. IDEM asked ESSROC to propose a means of verifying that no gas flow is occurring. We propose the following method for verification: The alkali by-pass stack (S-16) fan motor is driven by a 250 hp motor. Even without any load, a 250 hp motor is expected to consume 75 hp or 56 kW. We will set a trigger point to confirm the fan motor is not running. The bit will be set anytime the feeder for the by-pass equipment (including the fan motor) i ndicates more than 20 kW consumption. The bit will be monitored by our data acquisition system OSI-PI. The data acquisition system keeps aESSROC Cement Corporation Page 36 of 43 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore


### permanent record of the data. On March 10, 2004, Jim Hauck of Baker and Daniels, on behalf of ESSROC Cement Corporation, provided supplemental comments on this issue, as follows.

As we discussed, Essroc continues to believe that the alkali bypass is not required to have a NOx CEM when no emissions are passing through it, and nothing in this message is to be construed as a waiver of Essroc's right to argue that positi on in any appeal or other proceeding.

For reasons of administrative efficiency, IDEM and Essroc have attempted to identify opportunities for including language in the draft permit that will minimi ze or focus issues on appeal where the parties cannot agree on final language. In this light, E ssroc proposes that IDEM change draft condition D.3.14(f) to require installation of a NOx CEM on the alkali bypass within 12 months of permit issuance instead of 180 days. Essroc expects to bring the alkali bypass into use in those 12 months, and the suggested change will reduce the likelihood that the time element will need to be an issue on appeal.

Response #29

326 IAC 10-1-5(1) requires compliance with the lim its in 326 IAC 10-1 to be demonstrated either by using a certified continuous emissions monitor (CEMS) or by using the test methods and procedures that follow: (A) 326 IAC 3 or (B) 40 CFR 60. The compliance date of the rule was June 12 th 

### , 1996. The Permittee has chosen to keep the alkali bypass operational and operated it in April of 1998. Pursuant to 326 IAC 10-1-5(1), the Permittee must install a (CEM S); therefore the permit must include a compliance schedule.

IDEM does not agree with the Permittee’s compli ance schedule (as proposed in the February 13, 2004 comment) because it does not give a final date by which the CEMS must be installed if the alkali bypass is not restarted. The Permittee has proposed to monitor the load on the circuit to which the fan motor is connected to assure whether the alkali bypass system is in operation. IDEM does not agree that, even without any load, a 250 hp motor would consume 75 hp or 56 kW. Additionally, since the Permittee has chosen to permit the alkali bypass to operate at any time, the CEMS must be installed to assure that emissions are in compliance with the emission limit.

IDEM does agree with the Permittee’s compliance schedule (as proposed in the March 10, 2004 comment) because it does provide a final date by wh ich the CEMS must be installed, regardless of whether the alkali bypass stack is in operation.

The Condition has been changed as shown below.

D.3.14 Continuous Emissions Monitoring [326 IAC 3-5] [326 IAC 2-7-6(1),(6)] [40 CFR 63, Subpart LLL] [326 IAC 10-1] [326 IAC 10-3]

(f) In order for kiln #2 to come into compliance with the requirements of 326 IAC 10-1, the Permittee shall install, calibrate, maintain, and operate a NOx continuous emissions monitor (CEM) on the stack identified as EP23 for the elevator/dust tank (alkali bypass) identified as EU28 on kiln #2, within 180 days 12 months after the date of issuance of this permit. The NOx CEMs shall be certified according to procedures contained in 326 IAC 3 and 40 CFR 75 as applicable.



### Comment #30 (Condition D.3.16 - Transformer-Rectifier Sets)ESSROC Cement Corporation Page 37 of 43 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore


### The permit should state that failure to take re sponse steps in accordance with the CRP shall be considered a deviation, and not a violation, and then only if such failure results in a violation of an underlying applicable requirement.

Response #30

IDEM agrees that failure to take response steps is considered a deviation from the permit and has changed the condition accordingly. However, the purpos e of the condition is to prevent deviations from permitted emission limits; therefore failure to ta ke appropriate actions in response to an abnormal condition is considered a deviation from the permit, regardless of whether an emission limitation is exceeded. The condition has been changed as shown below.

D.3.16 

### Transformer-Rectifier (T-R) Sets [326 IAC 2-7-6(1)] [326 IAC 2-7-5(1)] (a) The ability of the ESP to control particulate emissions shall be monitored once per shift, when the unit is in operation, by measuring and recording the number of T-R sets in service and the primary and secondary voltages and the currents of the transformerrectifier (T-R) sets.

(b) Reasonable response steps shall be taken in accordance with Section C - Compliance Response Plan - Preparation, Implementation, Records, and Reports whenever the percentage of T-R sets in service falls below 90 percent (90%). T-R set failure resulting in less than 90 percent (90%) availability is not a deviation from this permit. Failure to take response steps in accordance with Section C - Compliance Response Plan - Preparation, Implementation, Records, and Reports, shall be considered a violation of deviation from this permit.

Comment #31 (Condition D.3.17 - Opacity Readings).

Delete this section. It belongs in the CRP. In additi on, it effectively imposes substantive requirements on ESSROC when the kiln is operating at 10% below a llowable and when the clinker cooler is operating at 20% below allowable. This has the effect of ma king the capacity limit more stringent and is therefore illegal.

Response #31

Since the opacity limits on the kilns and clinker cool ers are already very stringent, IDEM agrees that opacity trigger levels are unnecessary for these uni ts. The condition has been revised as shown below.

D.3.17 Opacity Readings The ability of each ESP and baghouse to control particulate emissions from the kilns and clinker coolers shall be monitored by continuously measuring and recording the opacity of emissions from the stack exhausts.

(a) Appropriate response steps shall be taken in accordance with Section C - Compliance Response Plan - Preparation, Implementation, Records, and Reports whenever the opacity from a kiln exceeds 18 percent for any three consecutive six-minute averaging periods, or the opacity from a clinker cooler exceeds 8 percent for any three consecutive six-minute averaging periods. 

### Failure to take response steps in accordance with Section C - Compliance Response Plan - Preparation, Implementation, Records, and Reports



### , shall be considered a violation of this permit.ESSROC Cement Corporation Page 38 of 43 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore
(b) The opacity shall be determined by the certified continuous opacity monitor required in Condition D.3.14.



### (c) (a) Whenever a continuous opacity monitor (C OM) is malfunctioning or will be down for calibration, maintenance, or repairs for a period of one (1) hour or more, compliance with the applicable opacity limits shall be demonstrated by the following:

(1) Visible emission (VE) notations s hall be performed once per hour during daylight operations following the shutdown or malf unction of the primary COM. A trained employee shall record whether emissions are normal or abnormal for the state of operation of the emission unit at the time of the reading.

(A) A trained employee is an employee who has worked at the plant at least one (1) month and has been trained in the appearance and characteristics of normal visible em issions for that specific process.

(B) If abnormal emissions are noted during two consecutive emission notations, the Permittee shall begin Method 9 opacity observations within four hours of the second abnormal notation.

(C) VE notations may be discontinued once a COM is online or formal Method 9 readings have been implemented.

(2) If a COM is not online within twenty-f our (24) hours of shutdown or malfunction of the primary COM, the Permittee shall provide certified opacity reader(s), who may be employees of the Permittee or independent contractors, to self-monitor the emissions from the emission unit stack.

(A) Visible emission readings sha ll be performed in accordance with 40 CFR 60, Appendix A, Method 9, for a minimum of five (5) consecutive six (6) minute averaging periods beginning not more than twenty-four (24) hours after the start of the malfunction or down time.

(B) Method 9 opacity readings shall be repeated for a minimum of five (5) consecutive six (6) minute averaging per iods at least once every four (4) hours during daylight operations, until such time that a COM is in operation.

(C) Method 9 readings may be discontinued once a COM is online.

(D) Any opacity exceedances determi ned by Method 9 readings shall be reported with the Quarterly Opacity Exceedances Reports.

(3) If abnormal emissions are observed, the Permittee shall take reasonable response steps in accordance with Se ction C - Compliance Response Plan - Preparation, Implementation, Records, and Reports. Observation of abnormal emissions that do not violate an applicable opacity limit is not a deviation from this permit. Failure to take response steps in accordance with Section C - Compliance Response Plan - Preparation, Implementation, Records, and Reports, shall be considered a violation of deviation from this permit.ESSROC Cement Corporation Page 39 of 43 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore


### (d) (b) Nothing in this permit shall excuse the Permittee from complying with the requirements to operate a continuous opacity monitoring system pursuant to 326 IAC 3-5 and 40 CFR 63, Subpart LLL.

Comment #32 (Condition D.3.17(c) - Opacity Readings)

This section must be deleted. The purported authority for it is 326 IAC § 2-7-5( 3)(A)(iii) which refers to "requirements concerning the use, maintenance, and, where appropriate, installation of monitoring equipment or methods" as necessary . Rule 326 IAC § 3-5 provides for the use and maintenance of COMs and provides remedies if the agency reasonabl y believes that the equipment "is malfunctioning or may be providing invalid data over an extended period." (Emphasis supplied.) In light of this language, it is arbitrary and capric ious for the agency to impose these requirements any time a COM is down for more than four hours. The TSD is devoid of any reason why conditions at the Speed plant make this provision "necessary."

Response #32

ESSROC has kilns and clinker coolers which are required to measure opacity emissions using continuous opacity monitors (COMs) pursuant to 40 CFR 63, Subpart LLL and 326 IAC 3-5. These emission units are required to comply with stringent opacity limits, twenty percent (20%) and ten percent (10%) respectively for the kilns and clinker coolers. Considering these stringent opacity limits, and the requirement to continuously measure opacity from these units, IDEM believes that four (4) hours is an extended period of time for a COM to be malfunctioning or providing invalid data. In addition to the requirement to continuously monitor opacity, ESSR OC is required to certify compliance with each condition in the permit. In order to be able to certify compliance with the applicable opacity limit, ESSROC must have sufficient info rmation at its disposal to determine whether compliance was achieved. If a COM is malfunctioning for an extended period of time and no additional visible emissions notations are completed, ESSROC will not have sufficient information to determine compliance with the applicable opacity limit during the period of time when the COM was not functioning properly. 326 IAC 2-7-5 provides the authority to require additi onal monitoring when the COM is malfunctioning.

Additionally, IDEM has recently taken enforcement action against ESSROC for excess COM downtime and excess opacity from some of these stacks. ESSROC’s compliance history indicates that COM downtime is not merely a rare o ccurrence at this plant. Theref ore, ESSROC’s compliance history provides additional justification for requiring additional monitoring when a COM is malfunctioning.

Comment #33 (Condition D.3. 18 - Method 9 Opacity Readings a nd Visible Emissi ons Notations)

In Paragraph (b) delete subparagraph (2); there is no refer ence to “normal” elsewhere in this section. In subparagraph (i), change the word “record” to “verify”.

Response #33

Subparagraph (2) has not been deleted as requested. T he word “Normal” is referenced in subparagraph (1) of the condition, which has now been re-labeled paragraph (a). IDEM has not changed the word “record” to “verify” because keeping records is a requirement to determine compliance.

Comment #34 (Condition D.3.22 - Record K eeping Requirements)

Condition D.3.22(e) Record keeping Requirements. This provision should be changed to reflect the appropriate limits addressed in Condition D.3.5(a)(4), (5), and (6).ESSROC Cement Corporation Page 40 of 43 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore


### Condition D.3.22(f) Record keeping Requirements. Typographical error. The redundant reference to "continuous basis" should be deleted.

Response #34

As explained in response to comment number 26, the limits in Condition D.3.5 are the appropriate limits; therefore, it is not necessary to revise Condition D.3.22(e).

The redundant reference to "continuous bas is" been deleted in Condition D.3.22(f).

D.3.22 Record Keeping Requirements



### (f) To document compliance with 40 CFR 60.250, NSPS, Subpart Y, the Permittee shall maintain records of the monitoring device measurements of the temperature of the gas stream at the exit of the thermal dryer on a continuous basis. This should be done on a continuous basis. Records shall be complete and sufficient to establish compliance with the requirements of Subpart Y.

Comment #35 (Condition D.5. 1 - Particulate Matter)

Section D.5. If these units are insignificant, then 326 IAC 6-1-2 does not apply. See our General Comment 2. In addition, the imposition of an applicable requirement without providing an approved monitoring technique would jeopardize ESSROC’s ability to certify compliance.

Response #35

See IDEM’s response to comment 2 for the reason that 326 IAC 6-1-2 applies. The Permittee will need to rely on emission factors and/or observations to certify compliance.

Upon further review, IDEM determined that the following revisions to the permit were necessary.

Revision #1

Paragraph (a) of Conditions D.1.9, D.2.13, and D. 3.21 (Broken or Failed Bag Detection) has been revised as shown below. IDEM has determined that if the Permittee chooses to continue operating an emission unit for more than 10 days when one or more sections of a multi-compartment baghouse have failed, the Permittee must notify IDEM. This notification allows IDEM to determine if additional actions need to be taken to determine compliance with the particulate matter and opacity limits. Changes to D.1.9(a) are shown below. The same revisions have been made to Conditions D.2.13(a) and D.3.21(a).

D.1.9 Broken or Failed Bag Detection In the event that bag failure has been observed.

(a) 

### For multi-compartment units, the affected compartments will be shut down immediately until the failed units have been repaired or r eplaced. Operations may continue only if there are no visible emissions or if the event qualifies as an emergency and the Permittee satisfies the emergency provisi ons of this permit (Section B- Emergency Provisions). Within eight (8) business hours of the determination of failure, response steps according to the timetable described in the Compliance Response Plan shall be initiated. For any failure with corresponding response steps and timetable not describedESSROC Cement Corporation Page 41 of 43 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore


### in the Compliance Response Plan, respons e steps shall be devised within eight (8) business hours of discovery of the failure and shall include a timetable for completion. Failure to take response steps in accordance with Section C - Compliance Response Plan - Preparation, Implementation, Records, and Reports, shall be considered a deviation from this permit. If operations continue after bag failure is observed and it will be 10 days or more after the failure is observed before th e failed units will be repaired or replaced, the Permittee shall promptly notify the IDEM, OAQ of the expected date the failed units will be repa ired or replaced. The notification shall also include the status of the applicable compliance monitoring parameters with respect to normal, and the results of any response actions taken up to the time of notification.

Revision #2

A requirement to keep records of any additional ins pections required by the Preventive Maintenance Plan has been added to Conditions D.1.10, D.2.14, and D.3.22.

D.1.10 Record Keeping Requirements

(e) To document compliance with Condition D.1.3, the Permittee shall maintain of records of any additional inspections prescribed by the Preventive Maintenance Plan.

(f) All records shall be maintained in accordance with Section C - General Record Keeping Requirements, of this permit.

D.2.14 Record Keeping Requirements

(e) To document compliance with Condition D.2.6, the Permittee shall maintain of records of any additional inspections prescribed by the Preventive Maintenance Plan.

(e) (f) All records shall be maintained in accordance with Section C - General Record Keeping Requirements, of this permit.

D.3.22 Record Keeping Requirements

(g) To document compliance with Condition D.3.9, the Permittee shall maintain of records of any additional inspections prescribed by the Preventive Maintenance Plan.

(g) (h) All records shall be maintained in accordance with Section C - General Record Keeping Requirements, of this permit.

Revision #2

Conditions D.2.16 and D.3.23 have been revis ed to include additional language from 40 CFR 63.10(d)(5)(ii) as shown below.

D.2.16 Reporting Requirements (a)ESSROC Cement Corporation Page 42 of 43 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore

(5) Pursuant to 40 CFR 63.10(d)(5)(ii), any time an action taken by the Permittee during a startup, shutdown, or malfunction (including actions taken to correct a malfunction) is not consistent with the procedures in the startup, shutdown, and malfunction plan, and the source exceeds any applicable emission limitation in the relevant emission standard, the Permittee shall report the actions taken for that event within 2 working days after commencing actions inconsistent with the plan, by telephone call to the OAQ Compliance Section at (317) 233-5674 or facsimile (FAX) transmission at (317) 233-6865. The immediate report shall be followed by a letter within 7 working days after the end of the event, certified by the Permittee, explaining the circumstances of the event, the reasons for not following the startup, shutdown, and malfunction plan, and whether any excess emissions and/or parameter monitoring exceedances are believed to have occurred.

D.3.23 Reporting Requirements (h)

(5) Pursuant to 40 CFR 63.10(d)(5)(ii), any time an action taken by the Permittee during a startup, shutdown, or malfunction (including actions taken to correct a malfunction) is not consistent with the procedures in the startup, shutdown, and malfunction plan, and the source exceeds any applicable emission limitation in the relevant emission standard, the Permittee shall report the actions taken for that event within 2 working days after commencing actions inconsistent with the plan, by telephone call to the OAQ Compliance Section at (317) 233-5674 or facsimile (FAX) transmission at (317) 233-6865. The immediate report shall be followed by a letter within 7 working days after the end of the event, certified by the Permittee, explaining the circumstances of the event, the reasons for not following the startup, shutdown, and malfunction plan, and whether any excess emissions and/or parameter monitoring exceedances are believed to have occurred.



### Revision #3

In accordance with the credible evidence rule (62 F ed. Reg. 8314, Feb 24, 1997); Section 113(a) of the Clean Air Act, 42 U.S. C. § 7413 (a); and a letter from the United States Environmental Protection Agency (USEPA) to IDEM, OAQ dated May 18, 2004, all permits must address the use of credible evidence; otherwise, USEPA will object to the permits. The following language will be incorporated into the permit to address credible evidence:

B.24 Credible Evidence [326 IAC 2-7-5(3)][326 IAC 2-7-6][62 FR 8314] Notwithstanding the conditions of this permit that state specific methods that may be used to demonstrate compliance with, or a violation of, applicable requirements, any person (including the Permittee) may also use other credible evidence to demonstrate compliance with, or a violation of, any term or condition of this permit.

Revision #4

On April 15, 2004, the United States Environm ental Protection Agency (U.S. EPA) named 23 Indiana counties and one partial county nonattainment for the new 8-hour ozone standard. The designations became effective on June 15, 2004. Clark County has been designated as nonattainment for the 8-hour ozone standard. The following has been added to A.1 General Information:ESSROC Cement Corporation Page 43 of 43 Speed, Indiana OP No. T019-6016-00008 Permit Reviewer: Nisha Sizemore
A.1 General Information [326 IAC 2-7-4(c)] [326 IAC 2-7-5(15)] [326 IAC 2-7-1(22)] The Permittee owns and operates a portland cement manufacturing plant.

Responsible Official: Plant Manager Source Address: Highway 31, Speed, Indiana 47172 Mailing Address: Highway 31, Speed, Indiana 47172-1305 General Source Phone Number: 812 246-5472 SIC Code: 3241 County Location: Clark Source Location Status: Nonattainment for ozone under the 8-hour standard, Attainment for all other criteria pollutants Source Status: Part 70 Permit Program Major Source, under PSD Rules 

### Major Source, Section 112 of the Clean Air Act 1 of 28 listed source categoriesPage 1 of 44 

## Indiana Department of Environmental Management Office of Air Quality
Technical Support Document (TSD) for a Part 70 Operating Permit

Source Background and Description

Source Name: ESSROC Cement Corporation Source Location: Highway 31, Speed, Indiana 47172 County: Clark SIC Code: 3241 Operation Permit No.: T019-6016-00008 Permit Reviewer: Nisha Sizemore

The Office of Air Quality (OAQ) has reviewed a Part 70 permit application from ESSROC Cement Corporation relating to the operation of a Portland cement manufacturing operation. This Part 70 permit contains provisions intended to satisfy the requirements of the construction permit rules.

Permitted Emission Units and Pollution Control Equipment

The source consists of the following permitted emission units and pollution control devices:

Quarry activities

(1) Quarry drilling, identified as EU01, constructed in 1982, with particulate matter (PM) emissions controlled by one (1) baghouse, identified as the drilling rig baghouse 01 and exhausting to stack EP01. Note: the “baghouse” controlling thequarry drilling has no exhaust to the atmosphere. Dust is collected and then redeposited into the ground.

(2) Quarry blasting, identified as EU75, constructed prior to 1945, with associated fugitive particulate matter (PM) emissions.

(3) Raw material (limestone) loading to trucks, identified as EU76, constructed in 1948, with particulate matter emissions uncontrolled.

Raw material stockpile operations

(4) Raw material (clay overburden) unloadi ng to strippings stockpile, identified as EU78, constructed in 1948, with emissions uncontrolled.

(5) Strippings stockpile, identified as EU145, created before 1945.

(6) Truck unloading to additive hopper or additi ve storage pile (sand, iron, or Missouri clay), identified as EU99, constructed in 1948, with emissions uncontrolled.

(7) Silica/Alumina/Iron additive storage pile, identified as EU100, created before 1945.

(8) Additive clay blend pile, identified as EU101, created before 1945.

(9) Truck unloading to clay storage piles, identified as EU102, constructed in 1948, with emissions uncontrolled.ESSROC Cement Corporation Page 2 of 44 Speed, Indiana T019-6016-00008 Permit Reviewer: Nisha Sizemore

(10) uncovered clay storage pile, identified as EU103, created before 1945.

(11) covered clay storage pile, identified as EU104, created before 1945.

Raw Material Sizing Operations

(12) Raw material unloading to stone surge pile or primary crusher, identified as EU80, with emissions uncontrolled, commenced before 1956.

(13) Stone surge pile, identified as EU81, created before 1956.

(14) One (1) primary crusher, identified as EU82, constructed in 1956, with a nominal throughput of 700 tons per hour, with PM emissions uncontrolled.

(15) One (1) covered conveyor belt for transferring stone from primary crusher to screens, identified as EU83, constructed in 1956, with a nominal throughput of 700 tons per hour, with emissions uncontrolled.

(16) Screens, identified as EU84, with a nominal throughput of 700 tons per hour, constructed in 1956, with emissions uncontrolled.

(17) One (1) secondary crusher, identified as EU02, constructed in 1956, with a nominal throughput of 1050 tons per hour, with PM emissions controlled by one (1) baghouse, identified as baghouse 200, and exhausting to one (1) stack, identified as EP02.

(18) Covered conveyor for transferring stone from screens and secondary crusher to tertiary crusher or stone ladder bypass, identified as EU03, constructed in 1956, with a nominal throughput of 1050 tons per hour, with PM emissions controlled by one (1) baghouse, identified as baghouse 201, and exhausting to one (1) stack, identified as EP03.

(19) Two (2) tertiary crushers, identified as EU04 and EU04a, both constructed in 1956, each with a nominal throughput of 350 tons per hour, with PM emissions from both crushers controlled by one (1) baghouse, identified as baghouse 201, and exhausting to one (1) stack, identified as EP03.

(20) One (1) conveyor used to bypass tertiary crusher, referred to as the stone ladder bypass, identified as EU05, constructed in 1956, with emissions controlled by a baghouse, identified as baghouse 201, and exhausting to one (1) stack, identified as EP03.

(21) One (1) covered conveyor for transferring material from stone ladder and tertiary crusher to traveling belt, identified as EU85, constructed in 1956, with a nominal throughput of 700 tons per hour, with emissions uncontrolled, with emissions uncontrolled.

(22) One (1) traveling belt for transferring material from covered conveyor to North and South stone bins, identified as EU86, constructed in 1956, with a nominal throughput of 700 tons per hour, with emissions uncontrolled.

(23) North stone bin, identified as EU06, constructed in 1956, with emissions controlled by a baghouse, identified as baghouse 101, and exhausting to one (1) stack, identified as EP04.ESSROC Cement Corporation Page 3 of 44 Speed, Indiana T019-6016-00008 Permit Reviewer: Nisha Sizemore

(24) South stone bin, identified as EU07, constructed in 1956, with emissions controlled by one (1) baghouse, identified as baghouse 102, and exhausting to one (1) stack, identified as EP05.

(25) Stone conveyor transfer to truck, identified as EU87, constructed in 1956, with a nominal throughput of 700 tons per hour, with emissions uncontrolled.

(26) One (1) truck unloading station to crushed limestone storage pile, identified as EU89, constructed in 1956, with emissions uncontrolled.

(27) One (1) truck loading station from crushed limestone storage pile, identified as EU91, constructed in 1956, with emissions uncontrolled.

(28) One (1) truck unloading station to truck dump hopper, identified as EU93, constructed in 1956, with emissions uncontrolled.

(29) One (1) truck unloading station to emergency limestone storage pile or truck dump hopper, identified as EU94, constructed in 1956, with emissions uncontrolled.

(30) Crushed limestone storage piles, identified as EU90, created before 1957.

(31) Emergency limestone storage pile, identified as EU95, created during 1957.

(32) One (1) truck dump hopper, identified as EU96, constructed in 1977, with emission uncontrolled.

(33) One (1) limestone conveyor for transferring limestone from the truck dump hopper to the main limestone storage pile, identified as EU97, constructed in 1977, with a nominal throughput of 700 tons per hour, with emissions uncontrolled.

(34) Main limestone storage pile, identified as EU98, created during 1957.

Kiln #1 Cement Kiln Dust (CKD) Operations

(35) One (1) dust tank system, identified as EU21, constructed in 1971 with a nominal throughput of 100 tons per hour, with emissions controlled by a baghouse, identified as baghouse 210, and exhausting to stack EP17.

(36) truck loading from the dust tank system, identified as EU113, with emissions uncontrolled, commenced during July 1971.

(37) CKD storage pile, identified as EU118, created before 1945.

(38) CKD sales loadout spout (kiln #1 dust tank), identified as EU155, constructed in 1996, with emissions controlled by a baghouse, with a nominal air flow rate of 2400 actual cubic feet per minute, identified as baghouse 266 (CE98) and exhausting to stack EP98.

Kiln #2 Cement Kiln Dust (CKD) Operations

(39) truck loading from the elevator dust tank, identified as EU115, with emissionsESSROC Cement Corporation Page 4 of 44 Speed, Indiana T019-6016-00008 Permit Reviewer: Nisha Sizemore

uncontrolled, commenced during 1977.

(40) truck unloading to CKD storage pile, identified as EU117, with emissions uncontrolled, commenced during 1977.

Miscellaneous Facilities

(41) Plant Roads, identified as EU152.

(42) Vacuum system, identified as EU73, constructed in 1985, with emissions controlled by a baghouse with a nominal air flow rate of 400 actual cubic feet per minute, identified as baghouse 250, and exhausting to stack EP75.

(43) One (1) warehouse conveyor system for conveying bagged cement, identified as EU74, constructed in 1985, with emissions controlled by a baghouse with a nominal air flow rate of 1650 actual c ubic feet per minute, identified as baghouse 249, and exhausting to stack EP76.

Clay Processing Operations

(44) Clay hopper, identified as EU105, constructed prior to 1945.

(45) One (1) covered conveyor system for transferring material from storage piles and clay hopper to the clay crusher, identified as EU106, constructed before 1954, with a nominal throughput of 300 tons per hour, with emissions uncontrolled.

(46) One (1) clay crusher, identified as EU08, constructed in 1977, with a nominal throughput of 40 tons per hour, with emissions controlled by a baghouse, identified as baghouse 227, and exhausting to stack EP07.

Finish Operations Cr ane Storage Facilities

(47) Emergency BP stone storage pile, identified as EU128, created before 1945.

(48) One (1) truck unloading station to Emergency BP stone storage pile or Crane storage pile, identified as EU127, with emissions uncontrolled, commenced before 1945.

(49) One (1) truck unloading station to gypsum storage piles, identified as EU129, with emissions uncontrolled, commenced before 1945.

(50) Crane storage building, including gypsum storage bin, stone storage bin, two (2) clinker storage bins, and stone, clinker, and gypsum storage piles, identified as EU131, constructed in 1935.

(51) gypsum storage piles, identified as EU130 and EU134, created before 1945.

Fossil Fuel Storage a nd Handling Facilities

(52) one (1) truck unloading station to the reserve coal storage pile, identified as EU136, constructed in June 1971, with emissions uncontrolled.ESSROC Cement Corporation Page 5 of 44 Speed, Indiana T019-6016-00008 Permit Reviewer: Nisha Sizemore

(53) One (1) reserve coal storage pile, identified as EU137, created in May 1971.

(54) one (1) coal storage pile, identified as EU142, constructed prior to 1945.

(55) One (1) coal draw-up covered conveying system for transferring material from the coal/alternate energy storage pile to the coal transfer tower, identified as EU63, constructed in June 1972, with a nominal throughput of 200 tons per hour, with emissions controlled by one (1) baghouse, identified as baghouse 206, and exhausting to stack EP77.

(56) Coal transfer tower, identified as EU64, constructed in June 1972, with a nominal throughput of 200 tons per hour, with emissions controlled by one (1) baghouse, identified as baghouse 207, and exhausting to stack EP78.

(57) One (1) coal bin, identified as EU65, constructed in June 1972, with emissions controlled by one (1) baghouse, identified as baghouse 208, and exhausting to stack EP79.

Kiln #1 Clinker Handling Facilities

(58) One (1) #1 clinker drag conveyor for transferring clinker from clinker cooler #1 to the apron conveyor, identified as EU23, constructed in May 1971, with a nominal throughput of 75 tons per hour, with emissions controlled by a baghouse, identified as baghouse 217, and exhausting to one (1) stack identified as EP19.

(59) apron conveyor for transferring clinker from the #1 clinker drag conveyor to either the clinker can #1 or the long belt, identified as EU24, constructed in May 1971, with a nominal throughput of 75 tons per hour, with emissions controlled by a baghouse, identified as baghouse 218, and exhausting to one (1) stack identified as EP20.

(60) clinker can #1, which is a vertical bin with a lid used for storing off-spec clinker, identified as EU114, constructed in May 1971, with emissions controlled by a baghouse, identified as baghouse 218, and exhausting to one (1) stack identified as EP20.

Kiln #2 Clinker Handling Facilities

(61) One (1) #2 clinker drag conveyor for transferring clinker from clinker cooler #2 to the aumond conveyor, identified as EU30, constructed in 1977, with a nominal throughput of 100 tons per hour, with emissions controlled by a baghouse, identified as baghouse 233, and exhausting to one (1) stack identified as EP25.

(62) One (1) aumond conveyor used for transferring clinker from the #2 clinker drag conveyor to the clinker can #2 or the cross belt, identified as EU31, constructed in 1977, with a nominal throughput of 100 tons per hour, with emissions controlled by a baghouse, identified as baghouse 234, and exhausting to one (1) stack identified as EP26.

(63) One (1) cross belt for transferring clinker from the aumond conveyor to the long belt, identified as EU119, constructed in May 1971, with a nominal throughput of 100 tons per hour, with emissions controlled by a baghouse, identified as baghouse 235, and exhausting to one (1) stack identified as EP21.ESSROC Cement Corporation Page 6 of 44 Speed, Indiana T019-6016-00008 Permit Reviewer: Nisha Sizemore

(64) clinker can #2, which is a vertical bin with a lid used for storing off-spec clinker, identified as EU120, constructed in 1977, with emissions controlled by a baghouse, identified as baghouse 234, and exhausting to one (1) stack identified as EP26.

Clinker Handling to Cr ane Storage Facilities

(65) One (1) long belt for transferring clinker from the apron conveyor and the cross belt to the North clinker transfer tower, identified as EU25, constructed in May 1971, with a nominal throughput of 200 tons per hour, with emissions controlled by a baghouse, identified as baghouse 219, and exhausting to one (1) stack identified as EP27.

(66) One (1) North clinker transfer tower for transferring clinker from the long belt to the covered incline belt (shuttle belt), identified as EU32, constructed in 1972, with a nominal throughput of 200 tons per hour, with emissions controlled by a baghouse, identified as baghouse 219, and exhausting to one (1) stack identified as EP27.

(67) One (1) covered incline belt (Shuttle belt) used for transferring clinker from the North clinker transfer tower to the North clinker storage building, identified as EU33, constructed in 1972, with a nominal throughput of 200 tons per hour, with emissions controlled by a baghouse, identified as baghouse 220, and exhausting to one (1) stack identified as EP28.

(68) One (1) clinker storage pile, identified as EU121, created before 1960.

(69) North clinker storage pile, identified as EU122, created in May 1971.

(70) North clinker storage building, identified as EU123, constructed in 1960.

(71) One (1) North reclaim clinker covered conveyor system used to transfer clinker from the North clinker storage building to either, 1) the South reclaim clinker covered conveyor system (EU124) or, 2) the 2D finish mill clinker bin transfer (EU44) transfer tower (covered conveyor), identified as EU34, constructed in 1962, with a nominal throughput of 200 tons per hour, with emissions controlled by a baghouse, identified as baghouse 245, and exhausting to one (1) stack identified as EP29.

(72) One (1) South reclaim clinker covered conveyor used to transfer clinker from the North reclaim clinker covered conveyor system to the crane storage building, identified as EU124, constructed in May 1971, with a nominal throughput of 200 tons per hour, with emissions controlled by a baghouse, identified as baghouse 202, and exhausting to one (1) stack identified as EP39.

(73) Truck loading station, used for loading material from the North clinker storage pile, identified as EU125, constructed in May 1971, with emissions uncontrolled.

(74) Truck unloading station, used for loadi ng material to the crane storage building, identified as EU126, constructed in May 1971, with emissions uncontrolled.

2ABC Finish Mill Facilities

(75) One (1) CKD/Lime tank, identified as EU146, constructed in 1964, with emissionsESSROC Cement Corporation Page 7 of 44 Speed, Indiana T019-6016-00008 Permit Reviewer: Nisha Sizemore

controlled by a baghouse, identified as baghouse 143, and exhausting to one (1) stack identified as EP84.

(76) one (1) gypsum/stone transfer circuit ABC mills, including material transfers and scales, identified as EU35, constructed in 1964, with a nominal throughput of 300 tons per hour, with emissions controlled by two (2) baghouses, identified as baghouses 131 and 132, and exhausting to two (2) stacks identified as EP30 and EP31.

(77) one (1) clinker transfer circuit ABC mills, including conveyor transfers and clinker scales, identified as EU36, constructed in 1964, with a nominal throughput of 200 tons per hour, with emissions controlled by a baghouse, identified as baghouse 251, and exhausting to one (1) stack identified as EP32.

(78) two (2) clinker elevators, identified as EU37, constructed in 1969, with a nominal throughput of 200 tons per hour, with emissions controlled by a baghouse, identified as baghouse 134, and exhausting to one (1) stack identified as EP34.

(79) One (1) 2BC finish mill feed belt, identified as EU132, constructed in 1977, with a nominal throughput of 200 tons per hour, with emissions uncontrolled.

(80) 2A hopper / preliminary ball mill used to grind clinker and gypsum, identified as EU38, constructed in 1948, with a nominal throughput of 24 tons per hour, with emissions controlled by a baghouse, identified as baghouse 133, and exhausting to one (1) stack identified as EP33.

(81) one (1) finish mill circuit 2A, which includes three (3) elevators, finish mill, separator, and air transport system, collectively identified as EU39, constructed in 1948, with a nominal throughput of 24 tons per hour, with emissions controlled by a baghouse, identified as baghouse 134, and exhausting to one (1) stack identified as EP34.

(82) one (1) finish mill circuit 2B, which includes the feed hopper, feed belt, finish mill, elevator, and air transport system, collectiv ely identified as EU40, constructed in 1953, with a nominal throughput of 25 tons per hour, with emissions controlled by a baghouse, identified as baghouse 135, and exhausting to one (1) stack identified as EP35.

(83) one (1) finish mill circuit 2C, which includes the feed hopper, feed belt, finish mill, and elevator, collectively identified as EU 42, constructed in 1960, with a nominal throughput of 36 tons per hour, with emissions controlled by a baghouse, identified as baghouse 137, and exhausting to one (1) stack identified as EP37.

(84) One (1) separator and cement cooler, used in conjunction with the finish mill circuit 2C, identified as EU43, constructed in 1960 and 1964 respectively, with a nominal throughput of 36 tons per hour, with emissions controlled by a baghouse, identified as baghouse 138, and exhausting to one (1) stack identified as EP38.

(85) One (1) separator and cement cooler, used in conjunction with the finish mill circuit 2B, identified as EU41, constructed in 1953 and 1955 respectively, with a nominal throughput of 25 tons per hour, with emissions controlled by a baghouse, identified as baghouse 136, and exhausting to one (1) stack identified as EP36.

(86) One (1) BP tank for storing finished product (cement), identified as EU48, constructed in 1965, with a nominal throughput of 700 tons per hour, withESSROC Cement Corporation Page 8 of 44 Speed, Indiana T019-6016-00008 Permit Reviewer: Nisha Sizemore

emissions controlled by a baghouse, identified as baghouse 144, and exhausting to one (1) stack identified as EP81.

(87) One (1) pump used to transfer finished product (cement) from the BP tank to silos, identified as EU49, constructed in 1966, with a nominal throughput of 50 tons per hour, with emissions controlled by a baghouse, identified as baghouse 146, and exhausting to one (1) stack identified as EP82.

2D Finish Mill Facilities

(88) one (1) gypsum elevator used to transfer material from the gypsum storage piles to the clinker draw-up system D mill, identified as EU135, constructed in 1964, with a nominal throughput of 45 tons per hour, with emissions controlled by a baghouse, identified as baghouse 120, and exhausting to one (1) stack identified as EP40.

(89) one (1) 2D finish mill clinker bin, which includes the elevator, conveyor belts, and air transport system, identified as EU44, constructed in 1964, with a nominal throughput of 300 tons per hour, with emissions controlled by one (1) baghouses

, identified as baghouses 120, and exhausting to stack identified as EP40.

(90) one (1) 2D finish mill clinker / gypsum feed circuit which includes scales and feed belts, identified as EU45, constructed in 1964, with a nominal throughput of 120 tons per hour, with emissions controlled by a baghouse, identified as baghouse 262, and exhausting to one (1) stack identified as EP94.

(91) one (1) 2D finish mill roll press circuit, which includes a roller press (crusher), identified as EU46, constructed in 1999, with a nominal throughput of 120 tons per hour, with emissions controlled by three (3) baghouses, identified as baghouses 261, 262, and 263, and exhausting to three (3) stacks identified as EP93, EP94, and EP95.

(92) one (1) 2D finish mill circuit, which includes conveyor transfer, elevator, finish mill, elevator, classifier, and three (3) cement coolers, identified as EU47, constructed in 1964, with a nominal throughput of 120 tons per hour, with emissions controlled by a baghouse, identified as baghouse 139, and exhausting to one (1) stack identified as EP41.

Finish Product 501-Silos Storage and Packing Facilities

(93) 501-Silos 30-44, identified as EU54, constructed in 1965, with emissions controlled by five (5) baghouses, identified as baghouses 224, 225, 246, 150, and 151, and exhausting to five (5) stacks identified as EP63 through EP67.

(94) one (1) BIC mixer for mixing lime and pigment with the clinker, identified as EU55, constructed in 1973, with a nominal throughput of 45 tons per hour, with emissions controlled by a baghouse, identified as baghouse 226, and exhausting to one (1) stack identified as EP68.

(95) one (1) BIC packer for loading cement into bags, identified as EU56, constructed in 1973, with a nominal throughput of 45 tons per hour, with emissions controlled by a baghouse, identified as baghouse 226, and exhausting to one (1) stack identified as EP68.ESSROC Cement Corporation Page 9 of 44 Speed, Indiana T019-6016-00008 Permit Reviewer: Nisha Sizemore

Finish Product 506-Silos Storage, P acking, and Bulk Loading Facilities

(96) 506-Silos 56-73, identified as EU53, constructed in 1958, with emissions controlled by fourteen (14) baghouses, identified as baghouses 159 through 172, and exhausting to fourteen (14) stacks identified as EP49 through EP62.

(97) Two (2) bulk loading stations for railroad cars and trucks, identified as EU57 and EU58, constructed in 1954, each with a nominal throughput of 200 tons per hour, with emissions controlled by baghouses 176 and 177 respectively, and exhausting to stacks EP69 and EP70 respectively.

(98) One (1) packer #1 for loading cement into bags, identified as EU59, constructed in 1960, with a nominal throughput of 45 tons per hour, with emissions controlled by a baghouse, identified as baghouse 173, and exhausting to one (1) stack identified as EP71.

(99) One (1) packer #2 for loading cement into bags, identified as EU60, constructed in 1960, with a nominal throughput of 45 tons per hour, with emissions controlled by a baghouse, identified as baghouse 174, and exhausting to one (1) stack identified as EP72.

(100) One (1) packer #3 for loading cement into bags, identified as EU61, constructed in 1960, with a nominal throughput of 45 tons per hour, with emissions controlled by a baghouse, identified as baghouse 175, and exhausting to one (1) stack identified as EP73.

(101) one (1) bag compression station, identified as EU62, constructed in 1960, with a nominal throughput of 45 tons per hour, with emissions controlled by a baghouse, identified as baghouse 242, and exhausting to one (1) stack identified as EP74.

Finish Product 504-Silos Storag e and Bulk Loading Facilities

(102) 504-Silos 45-48, and 50-55, identified as EU51, constructed in 1959, with emissions controlled by four (4) baghouses, identified as baghouses 153 through 156, and exhausting to four (4) stacks identified as EP44 through EP47.

(103) One (1) bulk loading station for trucks and railroad cars, identified as EU52, constructed in 1959, with a nominal throughput of 200 tons per hour, with emissions controlled by baghouse 152, and exhausting to stack EP48.

(104) 504 Silos Bank/Silo 49 (CKD sales), identified as EU153, constructed in 1959, with emissions controlled by a baghouse, identified as baghouse CE96 and exhausting to stack 264.

(105) CKD sales loadout spout, identified as EU154, constructed in 1999, with emissions controlled by a baghouse, identified as baghouse 265 (CE97) and exhausting to stack 265.

Finish Product 502-Silos Storag e and Bulk Loading Facilities

(106) 502-Silos 1, 2, and 7-11, identified as EU50, constructed in 1966, with emissions controlled by two (2) baghouses, identified as baghouses 148 and 149 respectively, and exhausting to two (2) stacks identified as EP42 and EP43.ESSROC Cement Corporation Page 10 of 44 Speed, Indiana T019-6016-00008 Permit Reviewer: Nisha Sizemore

Raw Mill Facilities

(107) Two (2) pneumatic truck unloading stati ons to additive bins, identified as EU107 and EU108, constructed in July 1976, with emissions controlled by one (1) baghouse, identified as baghouse 228, and exhausting to stack EP09.

(108) One (1) clay hopper, identified as EU109, constructed in July 1976, with emissions uncontrolled.

(109) Three (3) additive bins for flyash, bottom ash, or iron, identified as EU10, EU11, and EU12 respectively, equipped with two (2) elevators, constructed in 1977, with emissions controlled by one (1) baghouse, identified as baghouse 228 and exhausting to stack EP09.

(110) One (1) C-15 covered conveyor system for transferring material from the clay breaker, additive bin 2, and the main limestone storage pile to the triple gate, identified as EU09, constructed in 1977, with a nominal throughput of 300 tons per hour, with emissions controlled by two (2) baghouses, identified as baghouses 227 and 229, and exhausting to stacks EP07 and EP08 respectively.

(111) One (1) Loesche raw mill, identified as EU14, constructed in 1977, with a nominal throughput of 300 tons per hour, with emissions controlled by one (1) electrostatic precipitator, identified as ESP15, and exhausting to stack S-15.

(112) one (1) sidewinder (pneumatic transfer pump) used for pumping the kiln feed from silos to triple gate, identified as EU15, constructed in 1977, with a nominal throughput of 300 tons per hour, with emissions controlled by one (1) baghouse, identified as baghouse 247 and exhausting to stack EP-11.

(113) One (1) raw material pile, identified as EU112.

(114) one (1) oil-fired furnace, referred to as the Todd Furnace, used for Loesche mill heating, identified as EU13, constructed in 1977, with a nominal heat input capacity of 55 million British thermal units per hour, with emissions controlled byone (1) electrostatic precipitator, identified as ESP15, and exhausting to stack S15.

(115) blend silo #1 for blending kiln feed, identified as EU16, constructed in May 1971, with emissions controlled by one (1) baghouse, identified as baghouse 211, and exhausting to stack EP12

(116) blend silo #2 for blending kiln feed, identified as EU17, constructed in 1977, with emissions controlled by one (1) baghouse, identified as baghouse 230, and exhausting to stack EP13

(117) one (1) calibration system, identified as EU18, constructed in May 1971, with emissions controlled by one (1) baghouse, identified as baghouse 212, and exhausting to stack EP14.

Coal handling, milling and storage facilities

(118) Coal (crusher) mill #1, identified as EU66 servicing kiln #1, constructed in May 1971, with a nominal throughput of 12.5 tons per hour, with emissions routed to kiln #1 and controlled by baghouse 221 and exhausting to one (1) stack, identifiedESSROC Cement Corporation Page 11 of 44 Speed, Indiana T019-6016-00008 Permit Reviewer: Nisha Sizemore

as (EP16) S-14. Note: For the purposes of NSPS Subpart Y applicability, this is also a thermal dryer.

(119) Coal (crusher) mill #2, identified as EU67 servicing kiln #2, constructed in 1977, with a nominal throughput of 14 tons per hour, with emissions controlled by one (1) baghouse, identified as baghouse 252, and exhausting to stack EP88. Note: For the purposes of NSPS Subpart Y applicability, this is also a thermal dryer.

(120) one (1) fuel oil-fired air heater for kiln #1 coal mill, identified as EU68, constructed in May 1971, with a nominal heat input capacity of 5.3 million British thermal units per hour, with emissions exhausting directly to the kiln #1 coal mill then routed to kiln #1 and controlled by one (1) baghouse, identified as baghouse 221 and exhausting to stack S-14.

(121) one (1) fuel oil-fired air heater for kiln #2 coal mill, identified as EU69, constructed in 1977, with a nominal heat input capacity of 5.3 million British thermal units per hour, with emissions exhausting directly to the kiln #2 coal mill controlled by one (1) baghouse and two (2) electrostatic precipitators (ESPs), identified as baghouse 252, ESP15, and ESP16 (alkali bypass system), respectively, and exhausting to stacks EP88, S-15, and S-16 respectively.

(122) Kiln #2 coal dust silo, identified as EU149, constructed in 1996, with emissions controlled by one baghouse with a nominal air flow rate of 200 actual cubic feet per minute, identified as baghouse 253.

(123) Kiln #2 coal weigh system, identified as EU150, constructed in 1996, with a nominal throughput of 20 tons per hour, with emissions controlled by one baghouse with a nominal air flow rate of 500 actual cubic feet per minute, identified as baghouse 254.

(124) Kiln #2 coal handling system, identified as EU151, constructed in 1996, with a nominal throughput of 20 tons per hour, with emissions controlled by one baghouse with a nominal air flow rate of 200 actual cubic feet per minute, identified as baghouse 255.

The kiln #1 and kiln #2 facilities

(125) One (1) feed system for kiln #1, identified as EU19, constructed in May 1971, with a nominal throughput of 100 tons per hour, with PM emissions from the alleviator controlled by one (1) baghouse, identified as baghouse 209 and exhausting to stack EP15 and with PM emissions from the scales and pump controlled by one (1) baghouse, identified as baghouse 212 and exhausting to stack EP12.

(126) One (1) long dry process rotary cement kiln #1, identified as EU20, constructed in May 1971, with a nominal heat input capacity of 184 million Btu per hour, with a nominal production rate of 54.5 tons per hour (as clinker), with PM emissions controlled by one (1) baghouse, identified as baghouse 221, and exhausting to one (1) stack, identified as S-14.

(127) One (1) feed system for kiln #2, identified as EU26, constructed in 1977, with a nominal throughput of 150 tons per hour, with PM emissions controlled by one (1) baghouse, identified as baghouse 231, and exhausting to stack EP80.

(128) One (1) dry process rotary cement kiln #2 and associated preheater unit, equipped with an alkali bypass, identified as EU27, constructed in 1977, with aESSROC Cement Corporation Page 12 of 44 Speed, Indiana T019-6016-00008 Permit Reviewer: Nisha Sizemore

nominal heat input capacity of 302 million Btu per hour, with a nominal production rate of 96.0 tons per hour (as clinker), with PM emissions controlled by two (2) electrostatic precipitators, identified as ESP15 and ESP16 (alkali bypass system), and exhausting to stacks, identified as S-15 and S-16 respectively.

(129) One (1) Elevator/dust tank (alkali bypass) for kiln #2, identified as EU28, constructed in 1977, with emissions controlled by a baghouse, identified as baghouse 232, and exhausting to stack EP23.

The clinker cooler #1 facilities

(130) One (1) grate clinker cooler #1, identified as EU22, constructed in May 1971, with a nominal throughput rate of 54.5 tons per hour, with PM emissions controlled by one (1) baghouse, identified as baghouse 222, and exhausting to one (1) stack, identified as S-13.

The clinker cooler #2 facilities

(131) One (1) grate clinker cooler #2, identified as EU29, constructed in 1977, with a nominal throughput of 96.0 tons per hour, with PM emissions controlled by one (1) baghouse, identified as baghouse 17, and exhausting to one (1) stack, identified as S-17.

Unpermitted Emission Units and Pollution Control Equipment

There are no unpermitted facilities operating at this source during this review process.

Emission Units and Pollution Control Equipment

There are no new facilities.

Insignificant Activities

The source also consists of the following insigni ficant activities, as defined in 326 IAC 2-7-1(21):

(1) Space heaters, process heaters, or boilers using the following fuels:

(A) Fuel oil-fired combustion sources with heat input equal to or less than two million (2,000,000) Btu per hour and firing fuel containing less than five-tenths (0.5) percent sulfur by weight.

(2) A gasoline fuel transfer and dispensing operation handling less than or equal to 1,300 gallons per day, such as filling of tanks, locomotives, automobiles, having a storage capacity less than or equal to 10,500 gallons.

(3) A petroleum fuel other than gasoline, dis pensing facility, having a storage capacity of less than or equal to 10,500 gallons, and dispensing less than or equal to 230,000 gallons per month.

(4) The following VOC and HAP storage containers:ESSROC Cement Corporation Page 13 of 44 Speed, Indiana T019-6016-00008 Permit Reviewer: Nisha Sizemore

(A) Vessels storing lubricating oils, hydraulic oils, machining oils, and machining fluids.

(5) Refractory storage not requiring air pollution control equipment.

(6) Application of oils, greases, lubricants or other nonvolatile materials applied as temporary protective coatings.

(7) Machining where an aqueous cutting coolant continuously floods the machining interface.

(8) Closed loop heating and cooling systems.

(9) Activities associated with the treatment of wastewater streams with an oil and grease content less than or equal to 1%.

(10) Water runoff ponds for petroleum coke-cutting and coke storage piles.

(11) Any operation using aqueous solutions containing less than 1% by weight of VOCs excluding HAPs.

(12) Forced and induced draft cooling tower system not regulated under a NESHAP.

(13) Replacement or repair of electrostatic precipitators, bags in baghouses and filters in other air filtration equipment.

(14) Heat exchanger cleaning and repair.

(15) Paved and unpaved roads and parking lots with public access.

(16) Underground conveyors.

(17) Coal bunker and coal scale exhausts and associated dust collector vents.

(18) Equipment used to collect any material that might be released during a malfunction, process upset, or spill cleanup, including catch tanks, temporary liquid separators, tanks, and fluid handling equipment.

(19) Blowdown for any of the following: sight glass, boiler, compressors, pumps, and cooling tower.

(20) Emergency generators as follows:

(A) Diesel generators not exceeding 1600 horsepower.

(21) Purge double block and bleed valves.

(22) A laboratory as defined in 326 IAC 2-7-1(21)(D).

(23) Other categories with emissions below insignificant thresholds as follows:

(A) Storage tank #9 for storing #2 fuel oil, with a capacity of 20,000 gallons;

(B) Degreasing operations;

(C) Airalon storage tanks;ESSROC Cement Corporation Page 14 of 44 Speed, Indiana T019-6016-00008 Permit Reviewer: Nisha Sizemore

(D) Hydrophobe storage tank;

(E) Grinding aid storage tanks;

(F) Dust suppressant storage tank; and

(G) Additive storage tanks.

Existing Approvals

The source has constructed or has been operating under the following approvals:

(1) OP 10-03-91-0240, issued on December 28, 1989;

(2) OP 10-03-91-0241, issued on December 28, 1989;

(3) OP 10-03-91-0242, issued on December 28, 1989;

(4) OP 10-03-91-0243, issued on December 28, 1989;

(5) OP 10-03-91-0244, issued on December 28, 1989;

(6) OP 10-03-91-0245, issued on December 28, 1989;

(7) OP 10-03-91-0246, issued on December 28, 1989;

(8) OP 10-03-91-0247, issued on December 28, 1989;

(9) OP 10-03-91-0248, issued on December 28, 1989;

(10) OP 10-03-91-0249, issued on December 28, 1989;

(11) Registration 019-3269, issued December 14, 1993;

(12) Registration 019-3594, issued April 4, 1994;

(13) Exemption 019-3836, issued August 16, 1994;

(14) Registration 019-5259, issued March 28, 1996;

(15) CP 019-6430, issued August 28, 1996;

(16) CP 019-3340, issued September 5, 1997;

(17) Amendment 019-8431, issued October 8, 1997;

(18) Exemption CP 019-9944, issued October 26, 1998;

(19) Amendment 019-9359, issued October 27, 1998;

(20) CP 019-9349, issued October 27, 1998;

(21) Significant Source Modification 019-11171, issued November 25, 1999, which amendedESSROC Cement Corporation Page 15 of 44 Speed, Indiana T019-6016-00008 Permit Reviewer: Nisha Sizemore

CP019-9349;

All terms and conditions of previous permits issued pursuant to permitting programs approved into the state implementation plan have been either inco rporated as originally stated, revised, or deleted by this permit. All previous registrations and permits are superseded by this permit.

The following terms and conditions from pr evious approvals have been determined no longer applicable; therefore, were not incorporated into this Part 70 permit.

(1) All construction conditions from all previously issued permits.

Reason not incorporated: All facilities previously permitted have already been constructed; therefore, the construction conditions are no longer necessary as part of the operating permit. Any facilities that were previously permitted but have not yet been constructed would need new pre-construc tion approval before beginning construction.

(2) All conditions in previously issued permits that listed 326 IAC 6-3-2 or 326 IAC 6-2 as the authority.

Reason not incorporated:

Since this source is located in Clark County, which is one of the Counties listed in 326 IAC 6-1-7 and the source has particulate matter emissions greater than 100 tons per year, all of the facilities at this source that emit particulate matter, are subject to the requirements of 326 IAC 6-1, not 326 IAC 6-3-2 (Process Operations) or 326 IAC 6-2.

(3) 

### Construction Permit CP019-3340-00008, issued on September 5, 1997, which allowed the source to burn waste tires as a fuel in their kilns, has been revoked.

Reason not incorporated: The source is no longer permitted to burn waste tires.

Enforcement Issue

(a) IDEM has enforcement case numbers 2001-10884-A and 2002-11635-A pending against ESSROC. The cases involve the following alleged violations:

(1) opacity exceedances for the periods ending January 1, 2001, April 1, 2001, July 1, 2001, and September 1, 2001;

(2) alleged violations of 326 IAC 10-1 as follows:

(A) failure to install and operate a continuous emissions monitor (CEM) to measure NOx emissions from the kiln #2 alkali bypass system; (B) excess downtime for NOx CEM on kiln #1; and (C) 32 exceedances of NOx 30-day rolling average limit on kiln #1.

IDEM will take appropriate action regarding these alleged violations.

(b) The EPA has enforcement actions pending against ESSROC. The cases involve the following alleged violations:

(1) Opacity exceedances from the kiln and raw mill; and

(2) PSD violations for the kilns.ESSROC Cement Corporation Page 16 of 44 Speed, Indiana T019-6016-00008 Permit Reviewer: Nisha Sizemore

The EPA will take appropriate action regarding these alleged violations.

Recommendation

The staff recommends to the Commissioner that the Part 70 permit be approved. This recommendation is based on the following facts and conditions:

Unless otherwise stated, information used in this review was derived from the application and additional information submitted by the applicant.

An administratively complete Part 70 permit application for the purposes of this review was received on June 3, 1996. Additional information was received on April 25, 2000.

Emission Calculations

See Appendix A of this document for detailed emissions calculations.



### Potential To Emit

Pursuant to 326 IAC 2-1.1-1(16), Potential to Em it is defined as “the maximum capacity of a stationary source to emit any air pollutant under its physical and operational design. Any physical or operational limitation on the capacity of a source to emit an air pollutant, including air pollution control equipment and restrictions on hours of operation or type or amount of material combusted, stored, or processed shall be treat ed as part of its design if the limitation is enforceable by the U. S. EPA.”

This table reflects the PTE before controls. Control equipment is not considered federally enforceable until it has been required in a federally enforceable permit.

Pollutant Potential To Emit (tons/year) PM greater than 250 PM-10 greater than 250

SO 2 greater than 250 VOC greater than 250 CO greater than 250
NO
x greater than 250 Note: For the purpose of determining Title V applicability for particulates, PM-10, not PM, is the regulated pollutant in consideration.

HAP’s Potential Emissions after controls (tons/year) Arsenic compounds less than 10
Benzene less than 10 Beryllium compounds less than 10 Biphenyl less than 10 Bis(2-ethylhexyl)phthalate less than 10
Bromomethane less than 10 Cadmium compounds less than 10
Carbon disulfide less than 10
Chlorobenzene less than 10ESSROC Cement Corporation Page 17 of 44 Speed, Indiana T019-6016-00008 Permit Reviewer: Nisha Sizemore

HAP’s Potential Emissions after controls (tons/year)
Chloromethane less than 10 Chromium compounds less than 10

Di-n-butylphthalate less than 10

Ethylbenzene less than 10 Formaldehyde less than 10 Hydrogen chloride greater than 10 Lead compounds less than 10 Manganese compounds less than 10

Methyl ethyl ketone less than 10 Methylene chloride less than 10 Mercury compounds less than 10 Naphthalene less than 10
Phenol less than 10 Selenium compounds less than 10 Styrene less than 10
Toluene less than 10
Total PCDF less than 10
Total TCDF less than 10

Xylenes less than 10 TOTAL greater than 25 Note: The emissions for HAPs were determined through use of AP-42 emission factors. The emission factors are based on controlled emissions. Potential emissions may be greater than those stated above.

(a) The potential to emit (as defined in the Indiana Rule) of PM 10 , CO, NO X , VOC, and SO 2 are equal to or greater than 100 tons per year. Therefore, the source is subject to the provisions of 326 IAC 2-7.

(b) The potential to emit (as defined in Indiana Rule) of any single HAP are equal to or greater than ten (10) tons per year and the potential emissions (as defined in Indiana Rule) of a combination HAPs are greater than or equal to twenty-five (25) tons per year. Therefore, the source is subject to the provisions of 326 IAC 2-7.



### (c) Fugitive Emissions Since this type of operation is one of the tw enty-eight (28) listed source categories under 326 IAC 2-2 and since there are applicable New Source Performance Standards that were in effect on August 7, 1980, the fugitive emissions are counted toward determination of PSD and Emission Offset applicability.

Actual Emissions

The following table shows the actual emissions from the source. This information reflects 2001 emission data.

Pollutant Actual Emissions (tons/year) PM not reported
PM-10 901

SO 2 2410
VOC 54
CO 2083
NO
x 1629ESSROC Cement Corporation Page 18 of 44 Speed, Indiana T019-6016-00008 Permit Reviewer: Nisha Sizemore

lead 0.21 HAPs not reported

County Attainment Status

The source is located in Clark County.

Pollutant Status

PM-10 Attainment
SO 2 Attainment Ozone Attainment

CO Attainment
Lead Attainment



### (a) Volatile organic compounds (VOC) are precursors for the formation of ozone. Therefore, VOC emissions are considered w hen evaluating the rule applicability relating to the ozone standards. Clark County has been designated as attainment or unclassifiable for ozone. Therefore, VOC emissions were reviewed pursuant to the requirements for Prevention of Significant Deterioration (PSD), 326 IAC 2-2.

(b) Clark County has been classified as attainment or unclassifiable for all other criteria pollutants. Therefore, these emissions were reviewed pursuant to the requirements for Prevention of Significant Deterioration (PSD), 326 IAC 2-2.

(c) Fugitive Emissions Since this type of operation is one of the tw enty-eight (28) listed source categories under 326 IAC 2-2 and since there are applicable New Source Performance Standards that were in effect on August 7, 1980, the fugitive emissions are counted toward determination of PSD and Emission Offset applicability.

Part 70 Permit Conditions

This source is subject to the requirements of 326 IAC 2-7, pursuant to which the source has to meet the following:

(1) Emission limitations and standards, including those operational requirements and limitations that assure compliance with all applicable requirements at the time of issuance of Part 70 permits.

(2) Monitoring and related record keeping requirements which assume that all reasonable information is provided to evaluate c ontinuous compliance with the applicable requirements.

Federal Rule Applicability

40 CFR 60, Subpart F (Performance Standards for Portland Cement Plants)

Pursuant to 40 CFR 63.1356, the requirements of the NSPS Subpart F shall be ineffective after June 14, 2002, because the Portland Cement MACT shall supersede the requirements of this NSPS. The following analysis only serves to document which emission units were subject to the NSPS Subpart F prior to the effective date of the NESHAP for Portland Cement Plants 40 CFR 63, Subpart LLL.ESSROC Cement Corporation Page 19 of 44 Speed, Indiana T019-6016-00008 Permit Reviewer: Nisha Sizemore

Pursuant to 40 CFR 60.60, affected facilities include kilns, coolers, raw mill system, finish mill system, raw mill dryer, raw material storage, clinker storage, finished product storage, conveyor transfer points, and bagging and bulk loading and unl oading systems constructed or modified after the applicability date of August 17, 1971. The following affected facilities at ESSROC were subject to the requirements of the New Source Performance Standard, 326 IAC 12, (40 CFR 60.60, Subpart F).

(a) Raw Mill Facilities as follows:

(1) three (3) additive bins (EU10, EU 11, and EU12) equipped two (2) elevators - 1977

(2) C-15 covered conveyor system (EU09) - 1977

(3) Loesche raw mill (EU14) - 1977

(4) sidewinder (pneumatic transfer pump) (EU15) - 1977

(5) fuel oil-fired furnace, referred to as the Todd Furnace, used for Loesche Mill heating (EU13) - 1977

(6) blend silo #2 (EU17) - 1977

(7) two pneumatic truck unloading stations to additive bins (EU107 and EU108) - July 1976

(8) hopper (EU109) - July 1976

(b) Kiln #2 Clinker Handling facilities as follows:

(1) #2 clinker drag conveyor (EU30) - 1977

(2) aumond conveyor (EU31) - 1977

(3) clinker can #2 (EU120) - 1977

(c) Clinker Handling to Crane storage facilities as follows:

(1) North clinker transfer tower (EU32) - 1972

(2) covered incline belt (EU33) - 1972

(d) Kiln and Clinker Cooler facilities as follows:

(1) kiln #2 (EU27) and associated preheater unit, alkali bypass (EU28), and kiln #2 feed system (EU26) - 1977

(2) clinker cooler #2 (EU29) - 1977

(e) 2ABC Finish Mill Facilities as follows:

(1) finish mill feed belt (EU132) - 1977

(f) 2D Finish Mill Facilities as follows:ESSROC Cement Corporation Page 20 of 44 Speed, Indiana T019-6016-00008 Permit Reviewer: Nisha Sizemore

(1) 2D finish mill roll press circuit (EU46) - 1999

(g) Miscellaneous Facilities as follows:

(1) vacuum system (EU73) - 1985

(2) warehouse conveyor system (EU74) - 1985

(h) Finish Product 501-Silos Storage and Packing Facilities as follows:

(1) BIC mixer for mixing lime and pigment with clinker (EU55) - 1973

(2) BIC packer for loading cement into bags (EU56) - 1973

(i) Coal Handling, Milling, and Storage Facilities as follows:

(1) coal (crusher) mill #2 (EU67) - 1977

(2) fuel oil-fired coal dryer for kiln #2 (EU69) - 1977

(3) kiln #2 coal handling system (EU151) - 1996

(4) kiln #2 coal weigh system (EU150) - 1996

(5) kiln #2 coal dust silo (EU149) - 1996

(j) Fossil Fuel Storage and Handling Facilities as follows:

(1) coal draw-up covered conveyor (EU63) - June, 1972

(2) coal transfer tower (EU64) - June 1972

(3) coal bin (EU65) - June 1972

The affected facilities were required to comply with the following standards:

(a) The kiln shall be limited to 0.30 pound per ton of feed (dry basis) to the kiln and less than 20% opacity.

(b) The clinker cooler shall be limited to 0.10 pound per ton of feed (dry basis) to the kiln and less than 10% opacity.

(c) All other affected facilities shall be limited to less than 10% opacity.

Pursuant to 40 CFR 63.1356, these requirements became ineffective after June 14, 2002, because the Portland Cement MACT superseded the requirements of this NSPS.

The CKD operations were not subject to the New Source Performance Standard, 326 IAC 12, (40 CFR 60.60, Subpart F) because they are not affected facilities under the rule.

According to a memorandum dated June 12, 1995 from Kathie A. Stein, Director of Air Enforcement Division of EPA Headquarters, the nonmetallic mineral processing plant ends after the secondary crusher conveyor. The raw mill system (Subpart F) begins with the raw material storage facility. The first conveyor transfer point subject to Subpart F is the transfer point associated with the conveyor transferring material from the raw material storage to the grindingESSROC Cement Corporation Page 21 of 44 Speed, Indiana T019-6016-00008 Permit Reviewer: Nisha Sizemore

operations. Since all of the quarry activities, raw material stockpile operations, and raw material sizing operations at ESSROC Speed plant are prior to the raw material storage facility, none of these facilities are affected facilities under Subpart F.

The rest of the facilities at ESSROC were not subject to the New Source Performance Standard, 326 IAC 12, (40 CFR 60.60, Subpart F) because they were constructed prior to the applicability date of August 17, 1971.

40 CFR 60, Subpart OOO (Perform ance Standards for Nonmeta llic Mineral Processing Plants) None of the facilities at ESSROC are subject to the New Source Performance Standard 326 IAC 12, 40 CFR 60.670 (Subpart OOO) because either they were construct ed prior the applicab ility date of August 31, 1983 or they are subject to 40 CFR 60.60 (Subpart F).

40 CFR 60, Subpart Dc (Performance Standards for Steam Generating Units) ESSROC has three (3) fuel oil-fired furnaces, including the Todd furnace (EU13), the fuel oil-fired air heater for preheating kiln #1 (EU68), and the fuel oil-fired air heater for preheating kiln #2 (EU69). These three furnaces are not subject to the requirements of 40 CFR 60, Subpart Dc because they were constructed prior to June 9, 1989, which is the applicability date of the rule. Additionally, both of the air heaters have maximum heat input capacities less than 10 million British thermal units per hour.

40 CFR 60, Subparts K and Ka (Performance Standards for Petroleum Storage Tanks) ESSROC has five number 2 fuel oil storage tanks and one gasoline storage tank, with capacities ranging from 150 to 20,000 gallons. These storage tanks are not subject to the New Source Performance Standard 326 IAC 12, 40 CFR 60.110 (Subpart K), or 40 CFR 60.110a (Subpart Ka) because the storage tanks have capacities less than 40,000 gallons.

40 CFR 60, Subpart Kb (Performance Standards for Volatile Organic Liquid Storage Tanks) (a) ESSROC has three lubricating oil storage tanks, with capacities ranging from 250 to 500 gallons. These storage tanks are not subject to the New Source Performance Standard 326 IAC 12, 40 CFR 60.110b (Subpart Kb) because the tanks have capacities less than 10,500 gallons.

(b) ESSROC also has three grinding aid storage tanks locating in the finishing room area, with capacities of 11,500 gallons, 15,000 gallons, and 15,000 gallons. These storage tanks are not subject to the New Source Performance Standard 326 IAC 12, 40 CFR 60.110b (Subpart Kb) because the vapor pressure is less than 15.0 kPa.



### 40 CFR 60.730 Subpart UUU (Standards of Performance for Calciners and Dryers in Mineral Industries) None of the facilities at this source are subj ect to the requirements of the NSPS 326 IAC 12, 40 CFR 60.730 (Subpart UUU) because the source does not fit the definition of a mineral processing plant.

40 CFR 63.460 Subpart T (NESHAP for Halogenated Solvent Degreasers) The parts washers at this source are not subj ect to the requirements of the National Emissions Standards for Hazardous Air Pollutants (NESHAP) 326 IAC 20-1, 40 CFR 63.460 (Subpart T) because they do not utilize a solvent containing methylene chloride, perchloroethylene, trichloroethylene, 1,1,1-trichloroethane, carbon tetr achloride, or chloroform, or any combination of these halogens, in a total concentration greater than five percent by weight.

40 CFR 60.250 Subpart Y (Standards of Perf ormance for Coal Preparation Plants) The coal processing facilities at this source meet the definition of a coal preparation plant because they do pulverize coal. This rule est ablishes particulate emission limitations for the coal processing (coal mills) and conveying equipm ent, coal storage systems, and coal transfer and loading systems that have commenced construction or modification after October 24, 1974.ESSROC Cement Corporation Page 22 of 44 Speed, Indiana T019-6016-00008 Permit Reviewer: Nisha Sizemore

The following affected facilities at ESSROC are subject to the requirements of the New Source Performance Standard, 326 IAC 12, (40 CFR 60, Subpart Y) because they were constructed after the applicability date of October 24, 1974:



### (1) Coal (crusher) mill #2 (EU67) - 1977; Note : for the purposes of Subpart Y applicability, this unit meets the definition of a thermal dryer; and (2) Fuel-oil fired air heater for kiln #2 coal mill (EU69) - 1977.

Pursuant to 40 CFR 60, Subpart Y, the following conditions shall apply:

(1) The opacity from each of these fa cilities shall be less than 20 percent.

(2) The particulate matter emissions from the coal (crusher) mill #2 (EU67) shall not exceed 0.031 grains per dry standard cubic foot of exhaust air (0.070 g/dscm).

(3) The Permittee shall install, calibrate, maintain, and continuously operate a monitoring device for the measurement of the temperature of the gas stream at the exit of the coal (crusher) mill #2 (EU67) on a continuous basis. The monitoring device is to be certified by the manufacturer and be accurate within plus or minus 3 degrees Fahrenheit. The monitoring device shall be recalibrated annually in accordance with the procedures specified in 40 CFR 60.13(b).

(4) The Permittee shall conduct a Method 5 stack test to determine compliance with the particulate matter emission limit for the coal (crusher) mill #2 (EU67). The Permittee shall conduct a Method 9 opacity test to determine compliance with the opacity limits.

The following facilities are coal processing facilities at ESSROC but are not subject to the requirements of the New Source Performance Standard, 326 IAC 12, (40 CFR 60, Subpart Y) because they were constructed prior to the applicability date of October 24, 1974:

(1) coal (crusher) mill #1 (EU66) - May 1971; (2) fuel oil-fired air heater for kiln #1 (EU68) - May 1971; (3) truck unloading station to reserve coal storage pile (EU136) - June 1971; (4) reserve coal storage pile (EU137) - pre-1945; (5) coal storage pile (EU142) - pre-1945; (6) coal draw-up covered conveyor (EU63) - June 1972; (7) coal transfer tower (EU64) - June 1972; and (8) coal bin (EU65) - June 1972.



### Regardless of the dates of construction, the c oal (crusher) mill #1 (EU66) and the fuel oil-fired air heater for kiln #1 (EU68) would not be subj ect to the requirements of the NSPS Subpart Y because the emissions from these units exhaust to kiln #1 instead of directly to the atmosphere.

Regardless of the dates of construction, the facilities listed below are not subject to the requirements of the NSPS Subpart Y because t hese facilities are already subject to the provisions of 40 CFR 63 Subpart LLL. On Ap ril 5, 2002, EPA finalized changes to 40 CFR 63, Subpart LLL. In the preamble EPA stated that one of the changes was to clarify 63.1356 to clarify that the systems used to convey and transfer coal from the coal mill to the kiln at portland cement plants that ar e not major sources of HAP are not subject to the NSPS for coal preparation plants (40 CFR 60, Subpart Y) bec ause the final portland cement NESHAP already covers conveying system transfer points associated with coal preparation plants at portland cement plants that are major sources. EPA stated there is no need for these sources to be subject to duplicative requirements (i.e. to also be covered by the NSPS for coal preparation plants). Further, these emission sources will be subject to more stringent opacity requirements (10 percent) under the NESHAP than under the N SPS for coal preparation plants (40 CFR 60ESSROC Cement Corporation Page 23 of 44 Speed, Indiana T019-6016-00008 Permit Reviewer: Nisha Sizemore



### Subpart Y). EPA also stated that other coal c onveying transfer points will continue to be subject to the NSPS for coal preparation plants.

(1) kiln #2 coal dust silo (EU149) - 1996; (2) Kiln #2 coal weigh system (EU150) - 1996; and (3) Kiln #2 coal handling system (EU151) - 1996.

326 IAC 20-27-1 and 40 CFR 63, Subpart LLL (NESHAP for Portland Cement Plants)

(1) None of the quarry facilities/emission units, raw material stockpiles, or raw material sizing facilities/emission units at this sour ce are subject to the requirements of the National Emissions Standards for Hazardous Air Pollutants (NESHAP) 40 CFR 63 Subparts A and LLL, because they are not affe cted facilities under this rule. These facilities/emission units precede the raw material storage, which is just prior to the raw mill, in the sequence of materials handling operat ions. The rule specifically states that for portland cement plants with on-site nonmetallic mineral processing facilities, the first affected source in the sequence of material s handling operations subject to the rule is the raw material storage, which is just prior to the raw mill. The rule states that the primary and secondary crushers and any other equipment of the on-site nonmetallic mineral processing plant which precedes the ra w material storage are not subject to this rule. Furthermore, the rule states that the firs t conveyor transfer point subject to this rule is the transfer point associated with the conveyor transferring material from the raw material storage to the raw mill.

(2) None of the facilities which are part of the ce ment kiln dust operations at this source are subject to the requirements of the National Emissions Standards for Hazardous Air Pollutants (NESHAP) 40 CFR 63 Subparts A and LLL, because they are not considered affected facilities under this rule.

(3) None of the haul roads or open/unenclosed stoc kpiles are subject to the requirements of the National Emissions Standards for Hazardous Air Pollutants (NESHAP) 40 CFR 63 Subparts A and LLL, because they are not cons idered affected facilities under this rule. Clarification of this was provided in the settlement agreement entered into by the EPA and the Cement Kiln Recycling Coalition on September 7, 2001.

The rest of the facilities at ESSROC are subject to the requirements of 326 IAC 20-27-1 and 40 CFR 63, Subpart LLL (National Emission Standards for Hazardous Air Pollutants (NESHAP) for the Portland Cement Manufacturing Industry). June 14, 2002 

### is the compliance date for this rule. A summary of the applicable requirements is as follows:

(1) Pursuant to this rule the provisions of 40 CFR Part 63, Subpart A - General Provisions, which are incorporated by reference in 326 IAC 20-1, apply except when otherwise specified in 40 CFR Part 63, Subpart LLL.

(2) Pursuant to this rule the following conditions shall apply to all the affected facilities except the kilns and clinker coolers:

(a) The visible emissions from each facility shall not exceed ten percent (10%) opacity.

(b) Pursuant to 40 CFR 63.1350 (Monitoring Requirements), the Permittee shall prepare a written operations and maintenance plan for the affected facilities by June 14, 2002, which is the compliance date for the National Emission Standards for Hazardous Air Pollutants (NESHAP) from the Portland Cement Manufacturing Industry. The plan shall include the following information:ESSROC Cement Corporation Page 24 of 44 Speed, Indiana T019-6016-00008 Permit Reviewer: Nisha Sizemore

(I) Procedures for proper operation and maintenance of these facilities and associated air pollution control device(s).

(II) Procedures to be used to periodically monitor the affected facilities, which are subject to opacity standards under 40 CFR 63.1348. Such procedures must include the following provisions:

(A) The Permittee shall conduct a monthly 1-minute visible emissions test of each affected source in accordance with 40 CFR 60, Appendix A, Method 22. The test must be conducted while the affected source is in operation.

(B) If no visible emissions are observed in six consecutive monthly tests for any affected source, the Permittee may decrease the frequency of testing from monthly to semi-annually for that affected source. If visible emissions are observed during any semi-annual test, the Permittee shall resume testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests.

(C) If no visible emissions are observed during the semi-annual test for any affected source, the Permittee may decrease the frequency of testing from semi-annually to annually for that affected source. If visible emissions are observed during any annual test, the Permittee shall resume testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests.

(D) If visible emissions are observed during any Method 22 test, the Permittee must conduct a 6-minute test of opacity in accordance with 40 CFR 60, Appendix A, Method 9. The Method 9 test must begin within one hour of any observation of visible emissions.

(c) Pursuant to 40 CFR 63.1350 (Monitoring Requirements), the Permittee shall monitor opacity from the raw mills and finish mills by conducting daily visual emissions observations of the mill sweep and air separator particulate matter control devices (PMCDs), in accordance with the procedures of 40 CFR 60, Appendix A, Method 22. The Method 22 test shall be conducted while the affected source is operating at the representative performance conditions. The duration of the Method 22 test shall be six minutes. If visible emissions are observed during any Method 22 visible emissions test, the Permittee must initiate, within one (1) hour, the corrective actions specified in the site specific operations and maintenance plan developed in accordance with 40 CFR 63.1350(a)(1) and (a)(2); and conduct a follow-up Method 22 test. If visible emissions are observed, then within 24 hours of the end of the Method 22 test in which the visible emissions were observed, the Permittee must conduct a visual opacity test of each stack from which visible emissions were observed, in accordance with 40 CFR 60, Appendix A, Method 9. The duration of the Method 9 test shall be thirty minutes.

Failure to comply with any provision of the operations and maintenance plan shall be a violation of the standard.

(d) To document compliance with the NESHAP, the Permittee shall report theESSROC Cement Corporation Page 25 of 44 Speed, Indiana T019-6016-00008 Permit Reviewer: Nisha Sizemore

information required by 40 CFR 63.1354, including, but not limited to the following:

(I) The operations and maintenance plan shall be submitted to IDEM, OAQ and U.S. EPA by June 14, 2002, which is the compliance date for the National Emission Standards for Hazardous Air Pollutants (NESHAP) from the Portland Cement Manufacturing Industry.

(II) As required by 40 CFR 63.10(d)(2), the Permittee shall report the results of performance tests as part of the notification of compliance status.

(III) As required by 40 CFR 63.10(d)(3), the Permittee shall report the opacity results from tests required by 40 CFR 63.1349.

(IV) As required by 40 CFR 63.10(d)(5), if actions taken by the Permittee during a startup, shutdown, or malfunction of an affected source (including actions taken to correct a malfunction) are consistent with the procedures specified in the source’s startup, shutdown, and malfunction plan specified in 40 CFR 63.6(e)(3), the Permittee shall state such information in a semiannual report. Reports shall only be required if a startup, shutdown, or malfunction occurred during the reporting period. The startup, shutdown, and malfunction report may be submitted simultaneously with the excess emissions and continuous monitoring system performance reports.

(V) Pursuant to 40 CFR 63.10(d)(5)(ii), any time an action taken by the Permittee during a startup, shutdown, or malfunction (including actions taken to correct a malfunction) is not consistent with the procedures in the startup, shutdown, and malfunction plan, the Permittee shall report the actions taken for that event within 2 working days after commencing actions inconsistent with the plan, by telephone call or facsimile (FAX) transmission. The immediate report shall be followed by a letter within 7 working days after the end of the event, certified by the Permittee, explaining the circumstances of the event, the reasons for not following the startup, shutdown, and malfunction plan, and whether any excess emissions and/or parameter monitoring exceedances are believed to have occurred.

(3) Pursuant to this rule the following conditions shall apply to the both the kilns:

(a) Pursuant to 40 CFR 63.1348 (Emissions Standards and Operating Limits), on and after June 14, 2002, which is the compliance date for the National Emission Standards for Hazardous Air Pollutants (NESHAP) from the Portland Cement Manufacturing Industry, the kilns shall be limited as follows:

(I) Particulate matter (PM) emissions shall be limited to 0.30 pound per ton of feed (dry basis) to the kiln.

(II) Visible emissions from kiln #1 shall be limited to twenty percent (20%) opacity.

(III) When the Loesche mill is not in operation, the visible emissions from kiln #2 shall not exceed twenty percent (20%) opacity.

(IV) When the Loesche mill is in operation, the visible emissions from kiln #2 shall not exceed ten percent (10%) opacity.ESSROC Cement Corporation Page 26 of 44 Speed, Indiana T019-6016-00008 Permit Reviewer: Nisha Sizemore

(V) Dioxin/Furan emissions shall be limited to 8.7 x 10 -11 grains per dry standard cubic foot (TEQ) corrected to seven percent oxygen; or 1.7 x 10 -10 grains per dry standard cubic foot (TEQ) corrected to seven percent oxygen, when the average of the performance test run average temperatures at the inlet to the particulate matter control device is 400 degrees Fahrenheit or less.

(VI) The kilns shall be operated such that the temperature of the gas at the inlet to the kiln’s particulate matter control device does not exceed the average of the run average temperatures determined during the performance tests.

(b) Pursuant to 40 CFR 63.1349, within 180 days after June 14, 2002, which is the compliance date for the Portland Cement Manufacturing Industry NESHAP, the Permittee shall demonstrate initial compliance with the PM, opacity and dioxin/furan limits by conducting performance tests in accordance with 40 CFR 63.1349 and Methods 5, 9 and 23 of 40 CFR Part 60, Appendix A, respectively.

(c) Pursuant to 40 CFR 63.1349, compliance with the applicable PM and dioxin/furan limitations shall be determined by performance tests once every 2 1⁄2 years. The Permittee shall perform PM testing utilizing Methods 5 or 17 (40 CFR 60, Appendix A), or other methods as approved by the Commissioner. PM and dioxin/furan tests shall be performed during combustion of the fuel that results in the greatest emission rate. During each stack test, the following items shall be performed:

(I) 

### Certified continuous opacity monitoring (COM) data shall be observed and recorded or EPA Method 9 opacity tests shall be performed.

(II) The kiln temperature and oxygen concentration shall be measured and recorded.

(III) The clinker production rate shall be measured and recorded.

(d) Pursuant to 40 CFR Part 63.1350, a continuous opacity monitor shall be installed, calibrated, maintained, and operated for each kiln.

(e) Pursuant to 40 CFR 63.1350 (Monitoring Requirements), on and after June 14, 2002, which is the compliance date for the National Emission Standards for Hazardous Air Pollutants (NESHAP) for the Portland Cement Manufacturing Industry, the Permittee shall perform the following monitoring requirements:

(I) The Permittee shall have prepared a written operations and maintenance plan for the kilns. The plan shall include the following information:

(A) Procedures for proper operation and maintenance of the kilns and associated air pollution control device(s) in order to meet the emissions limits; and

(B) Procedures to be used during an inspection of the components of the combustion system of the kilns at least once per year.

Failure to comply with any provision of the operations and maintenance plan shall be a violation of the standard.ESSROC Cement Corporation Page 27 of 44 Speed, Indiana T019-6016-00008 Permit Reviewer: Nisha Sizemore

(II) The Permittee shall conduct an inspection of the components of the combustion system of kilns at least once per year.

(III) The Permittee shall continuously monitor opacity of emissions at the outlet of the PM control device. The COM shall be used to monitor opacity emissions in accordance with the NESHAP and shall be installed, maintained, calibrated and operated as required by 40 CFR 63, Subpart A and according to 40 CFR 60, Appendix B, PS-1.

(IV) The Permittee shall install, calibrate, maintain, and continuously operate a continuous monitor to record the temperature of the exhaust gases from the kilns at the inlet to, or upstream of the kiln’s PM control device. The monitor shall comply with the following:

(A) The recorder response range must include zero and 1.5 times either of the average temperatures established according to the requirements in 40 CFR 63.1349(b)(3)(iv).

(B) The reference method must be a National Institute of Standardsand Technology calibrated reference thermocouplepotentiometer system or alternate reference, subject to approval by the Administrator.

(C) The three-hour rolling average temperature shall be calculated as the average of 180 successive one-minute average temperatures.

(D) Periods of time when one-minute averages are not available shall be ignored when calculating three-hour rolling averages. When one-minute averages become available, the first one-minute average is added to the previous 179 values to calculate the three-hour rolling average.

(E) The calibration of all thermocouples and other temperature sensors shall be verified at least once every three months.

(V) The Permittee shall install, calibrate, maintain and operate a particulate matter continuous emission monitoring system (PM CEMS) to measure the particulate matter discharged to the atmosphere. The compliance deadline for installing the PM CEMS and all requirements relating to performance of the PM CEMS and implementation of the PM CEMS requirement is deferred pending further rulemaking.

(f) Pursuant to 40 CFR 63.1354, beginning June 14, 2002, the Permittee shall submit a continuous monitoring system (CMS) performance report with the excess opacity summaries, in accordance with 40 CFR 63.1354(8) and 40 CFR 63, Subpart A.

(g) Pursuant to 40 CFR 63.1354, beginning June 14, 2002, the Permittee shall submit a semi-annual summary report which contains the information specified in 40 CFR 63.10(e)(3)(vi), as well as the following:

(I) All exceedances of maximum control device inlet gas temperature limits.

(II) All failures to calibrate thermocouples and other temperature sensors as required under 40 CFR 63.1350(f)(7).ESSROC Cement Corporation Page 28 of 44 Speed, Indiana T019-6016-00008 Permit Reviewer: Nisha Sizemore

(III) The results of any combustion system component inspections conducted within the reporting period.

(IV) All failures to comply with any provision of the operation and maintenance plan developed in accordance with 40 CFR 63.1350(a).

If the total continuous monitoring system (CMS) downtime for any CEM or any CMS for the reporting period is ten percent or greater of the total operating time for the reporting period, the Permittee shall submit an excess emissions and CMS performance report along with the summary report.

(h) Pursuant to 40 CFR 63.1354, the Permittee shall report the information required by 40 CFR 63.1354, including, but not limited to the following:

(I) The operations and maintenance plan shall be submitted to IDEM, OAQ and U.S. EPA by June 14, 2002, which is the compliance date for the National Emission Standards for Hazardous Air Pollutants (NESHAP) from the Portland Cement Manufacturing Industry.

(II) As required by 40 CFR 63.10(d)(2), the Permittee shall report the results of performance tests.

(III) As required by 40 CFR 63.10(d)(3), the Permittee shall report the opacity results from tests required by 40 CFR 63.1349.

(IV) As required by 40 CFR 63.10(d)(5), if actions taken by the Permittee during a startup, shutdown, or malfunction of an affected source (including actions taken to correct a malfunction) are consistent with the procedures specified in the source’s startup, shutdown, and malfunction plan specified in 40 CFR 63.6(e)(3), the Permittee shall state such information in a semiannual report. Reports shall only be required if a startup, shutdown, or malfunction occurred during the reporting period. The startup, shutdown, and malfunction report may be submitted simultaneously with the excess emissions and continuous monitoring system performance reports.

(V) Pursuant to 40 CFR 63.10(d)(5)(ii), any time an action taken by the Permittee during a startup, shutdown, or malfunction (including actions taken to correct a malfunction) is not consistent with the procedures in the startup, shutdown, and malfunction plan, the Permittee shall report the actions taken for that event within 2 working days after commencing actions inconsistent with the plan, by telephone call or facsimile (FAX) transmission. The immediate report shall be followed by a letter within 7 working days after the end of the event, certified by the Permittee, explaining the circumstances of the event, the reasons for not following the startup, shutdown, and malfunction plan, and whether any excess emissions and/or parameter monitoring exceedances are believed to have occurred.

(4) Pursuant to this rule the following conditions shall apply to the clinker coolers (EU22 and EU29):

(a) Pursuant to 40 CFR 63.1348 (Emissions Standards and Operating Limits), on and after June 14, 2002, which is the compliance date for the National Emission Standards for Hazardous Air Pollutants (NESHAP) for the Portland CementESSROC Cement Corporation Page 29 of 44 Speed, Indiana T019-6016-00008 Permit Reviewer: Nisha Sizemore

Manufacturing Industry, each clinker cooler shall be limited as follows:

(I) Particulate matter (PM) emissions shall be limited to 0.10 pound per ton of feed (dry basis) to the kiln.

(II) Visible emissions shall be limited to ten percent (10%) opacity.

(b) Pursuant to 40 CFR 63.1349, within 180 days after June 14, 2002, which is the compliance date for the Portland Cement Manufacturing Industry NESHAP, the Permittee shall demonstrate initial compliance with the PM and opacity limits by conducting performance tests in accordance with 40 CFR 63.1349 and Methods 5 and 9 of 40 CFR Part 60, Appendix A, respectively.

(c) Pursuant to 40 CFR 63.1349, compliance with the applicable PM limitations shall be determined by performance tests once every 2 1⁄2 years, conducted in accordance with Section C - Performance Testing. The Permittee shall perform PM testing utilizing Methods 5 or 17 (40 CFR 60, Appendix A), or other methods as approved by the Commissioner.

(d) Pursuant to 40 CFR 63.1350 (Monitoring Requirements), on and after June 14, 2002, which is the compliance date for the National Emission Standards for Hazardous Air Pollutants (NESHAP) from the Portland Cement Manufacturing Industry, the Permittee shall perform the following monitoring requirements:

(I) The Permittee shall have prepared a written operations and maintenance plan for the clinker coolers. The plan shall include the procedures for proper operation and maintenance of the clinker coolers and associated air pollution control device(s) in order to meet the emissions limit. Failure to comply with any provision of the operations and maintenance plan shall be a violation of the standard.

(II) The Permittee shall continuously monitor opacity of emissions at the outlet of the PM control devices. The COM shall be used to monitor opacity emissions in accordance with the NESHAP and shall be installed, maintained, calibrated and operated as required by 40 CFR 63, Subpart A and according to 40 CFR 60, Appendix B, PS-1.

(e) Pursuant to 40 CFR 63.1354, beginning June 14, 2002, the Permittee shall submit a continuous monitoring system (CMS) performance report with the excess opacity summaries, in accordance with 40 CFR 63.1354(8) and 40 CFR 63, Subpart A.

(f) Pursuant to 40 CFR 63.1354, beginning June 14, 2002, the Permittee shall submit a semi-annual summary report which contains the information specified in 40 CFR 63.10(e)(3)(vi), as well as all failures to comply with any provision of the operation and maintenance plan developed in accordance with 40 CFR 63.1350(a). If the total continuous monitoring system (CMS) downtime for any CEM or any CMS for the reporting period is ten percent or greater of the total operating time for the reporting period, the Permittee shall submit an excess emissions and CMS performance report along with the summary report.

(g) Pursuant to 40 CFR 63.1354, the Permittee shall report the information required by 40 CFR 63.1354, including, but not limited to the following:

(I) The operations and maintenance plan shall be submitted to IDEM, OAQ and U.S. EPA by June 14, 2002, which is the compliance date for theESSROC Cement Corporation Page 30 of 44 Speed, Indiana T019-6016-00008 Permit Reviewer: Nisha Sizemore

National Emission Standards for Hazardous Air Pollutants (NESHAP) from the Portland Cement Manufacturing Industry.

(II) As required by 40 CFR 63.10(d)(2), the Permittee shall report the results of performance tests.

(III) As required by 40 CFR 63.10(d)(3), the Permittee shall report the opacity results from tests required by 40 CFR 63.1349.

(IV) As required by 40 CFR 63.10(d)(5), if actions taken by the Permittee during a startup, shutdown, or malfunction of an affected source (including actions taken to correct a malfunction) are consistent with the procedures specified in the source’s startup, shutdown, and malfunction plan specified in 40 CFR 63.6(e)(3), the Permittee shall state such information in a semiannual report. Reports shall only be required if a startup, shutdown, or malfunction occurred during the reporting period. The startup, shutdown, and malfunction report may be submitted simultaneously with the excess emissions and continuous monitoring system performance reports.

(V) Pursuant to 40 CFR 63.10(d)(5)(ii), any time an action taken by the Permittee during a startup, shutdown, or malfunction (including actions taken to correct a malfunction) is not consistent with the procedures in the startup, shutdown, and malfunction plan, the Permittee shall report the actions taken for that event within 2 working days after commencing actions inconsistent with the plan, by telephone call or facsimile (FAX) transmission. The immediate report shall be followed by a letter within 7 working days after the end of the event, certified by the Permittee, explaining the circumstances of the event, the reasons for not following the startup, shutdown, and malfunction plan, and whether any excess emissions and/or parameter monitoring exceedances are believed to have occurred.

326 IAC 20-28-1 and 40 CFR 63, Subpart EEE (National Emission Standards for Hazardous Air Pollutants for Hazardous Waste Combustors)

The kilns are not subject to the requirements of 326 IAC 20-28-1 and 40 CFR 63, Subpart EEE, (National Emission Standards for Hazardous Air Pollutants for Hazardous Waste Combustors), because the kilns do not combust hazardous waste and are not permitted to combust hazardous waste.

State Rule Applicabilit y - Entire Source

326 IAC 2-2 (Prevention of Significant Dete rioration) and 326 IAC 2-3 (Emission Offsets) Pursuant to 326 IAC 2-2 (Prevention of Significant Deterioration), this source is a major source because it is 1 of the 28 listed source categories and the potential to emit of at least one criteria pollutant is more than 100 tons per year. This source has never been reviewed under the requirements of 326 IAC 2-2 (PSD).

326 IAC 2-6 (Emission Reporting) This source is subject to 326 IAC 2-6 (Emission Reporting), because it has the potential to emit more than ten (10) tons per year of VOC and is located in Clark County. Pursuant to this rule, the owner/operator of the source must annually submit an emission statement for the source. The annual statement must be received by April 15 of each year and contain the minimum requirement as specified in 326 IAC 2-6-4. T he submittal should cover the period defined in 326ESSROC Cement Corporation Page 31 of 44 Speed, Indiana T019-6016-00008 Permit Reviewer: Nisha Sizemore

IAC 2-6-2(8) (Emission Statement Operating Year).

326 IAC 4-1 (Open Burning) The Permittee shall not open burn any material except as provided in 326 IAC 4-1-3, 326 IAC 4-1- 4 or 326 IAC 4-1-6. The previous sentence notwithstanding, the Permittee may open burn in accordance with an open burning approval issued by the Commissioner under 326 IAC 4-1-4.1.



### 326 IAC 5-1 (Opacity Limitations) Pursuant to 326 IAC 5-1-2 (Opacity Limitations ), except as provided in 326 IAC 5-1-3 (Temporary Alternative Opacity Limitations), opac ity shall meet the following, unless otherwise stated in this permit:

(a) Opacity shall not exceed an av erage of forty percent (40%) in any one (1) six (6) minute averaging period as determined in 326 IAC 5-1-4.

(b) Opacity shall not exceed sixty percent (60%) for more than a cumulative total of fifteen (15) minutes (sixty (60) readings as measured according to 40 CFR 60, Appendix A, Method 9 or fifteen (15) one (1) minute nonoverlapping integrated averages for a continuous opacity monitor) in a six (6) hour period.

Note: Only the portion of Clark County that is located in Jefferson Township is subject to an opacity limit of 30%. ESSROC’s cement manufacturing plant is located in Silver Creek Township. ESSROC’s quarry is located in Charlestown Township.

326 IAC 6-4 (Fugitive Dust Emissions) The Permittee shall not allow fugitive dust to escape beyond the property line or boundaries of the property, right-of-way, or easement on which the source is located, in a manner that would violate 326 IAC 6-4 (Fugitive Dust Emissions).

326 IAC 6-5 (Fugitive Particulate Matter Emission Limitations) 

### ESSROC is not subject to the requirements of 326 IAC 6-5 (Fugitive Particulate Matter Emission Limitations) because even though they are located in Clark County, they are not located in Jeffersonville township.

State Rule App licability - Significant Activities

326 IAC 2-2 (Prevention of Significant Deterioration) This source was a major source prior to the promulgation of the PSD rules in 1977. The source made modifications to the plant in 1982, 1985, 1994, 1996, and 1998/1999. Appendix A of this document includes a detailed analysis of the emissions of each of these modifications (see page titled “NSR Review.”)

In the case of the 2D finish mill roll press circuit, PSD minor limits have already been established in a previously issued permit. Therefore, these limits will be included in the Title V permit. The other emission units do not have enforceable limits included in previous permits that are sufficient to limit emissions below the PSD significance thresholds. Therefore these limits have also been established through the Title V review process.

In order to render the requirements of 326 IAC 2-2 not applicable, the following conditions shall apply:

(1) The PM emissions from baghouses 261, 262, and 263 controlling the 2D finish mill roll press circuit (EU46) shall not exceed 5.5 pounds per hour (limit for all three baghouses combined).ESSROC Cement Corporation Page 32 of 44 Speed, Indiana T019-6016-00008 Permit Reviewer: Nisha Sizemore

(2) The PM10 emissions from baghouses 261, 262, and 263 controlling the 2D finish mill roll press circuit (EU46) shall not exceed 3.2 pounds per hour (limit for all three baghouses combined).



### Note: Therefore, the requirements of 326 IAC 2-2 (Prevention of Significant Deterioration (PSD)) shall not apply. There is not sufficient information available to determine whether the 2D finish mill roll press circuit (EU46) is in compliance with these limits; therefore stack testing will be required to demonstrate compliance.



### (3) The PM10 emissions from the baghouse controlling the CKD sales loadout spout (kiln #1 dust tank) (EU155) shall not exceed 0.65 pounds per hour and the PM emissions shall not exceed 1.08 pounds per hour.



### (4) The number of holes drilled by the quarry drilling process shall not exceed 38,000 per 12 consecutive month period and the PM emissi ons shall not exceed 1.3 pounds per hole.

(5) The PM emissions from baghouse 249 controlling the warehouse conveyor system (EU74) shall not exceed 4.58 pounds per hour.

(6) The PM emissions from baghouse 250 controlling the vacuum system (EU73) shall not exceed 1.11 pounds per hour.

(7) The PM emissions from baghouse 265 (CE97) controlling the CKD sales loadout spout (EU154) shall not exceed 1.15 pounds per hour.

(8) The PM10 emissions from baghouse 265 (CE97) controlling the CKD sales loadout spout (EU154) shall not exceed 0.69 pounds per hour.

(9) The PM emissions from baghouse 255 controlling the kiln #2 coal handling system (EU151) shall not exceed 0.27 pounds per hour.

(10) The PM10 emissions from baghouse 255 controlling the kiln #2 coal handling system (EU151) shall not exceed 0.16 pounds per hour.

(11) The PM emissions from baghouse 253 controlling the kiln #2 coal dust silo (EU149) shall not exceed 3.65 pounds per hour.

(12) The PM10 emissions from baghouse 253 controlling the kiln #2 coal dust silo (EU149) shall not exceed 2.19 pounds per hour.

(13) The PM emissions from baghouse 254 controlling the kiln #2 coal weigh system (EU150) shall not exceed 0.68 pounds per hour.

(14) The PM10 emissions from baghouse 254 controlling the kiln #2 coal weigh system (EU150) shall not exceed 0.41 pounds per hour.

(15) The PM emissions from baghouse 228 controlling the elevator for transferring material from the hopper to the additive bin shall not exceed 5.68 pounds per hour.

(16) The PM10 emissions from baghouse 228 controlling the elevator for transferring material from the hopper to the additive bin shall not exceed 3.40 pounds per hour.

Therefore, the requirements of 326 IAC 2-2 (PSD) will not apply.ESSROC Cement Corporation Page 33 of 44 Speed, Indiana T019-6016-00008 Permit Reviewer: Nisha Sizemore

326 IAC 6-1-17 (Nonattainment Area Particulate Limitations: Clark County) This rule includes particulate matter emission limitations for specific facilities as specified below:

(a) The combined particulate matter emissions from the kiln #2 system which includes kiln #2 (EU27), kiln #2 alkali bypass (EU28), and clinker cooler #2 (EU29), shall not exceed 265.20 tons per year and 0.4 pound per ton.

(b) The combined particulate matter emissions from the kiln #1 system which includes kiln #1 (EU20) and clinker cooler #1 (EU22), shall not exceed 251.20 tons per year and 0.58 pound per ton.

326 IAC 6-1-2 (Nonattainment Area Particulate Limitations) (a) Particulate matter emissions from the fuel oil-fired air heater for kiln #2 (EU69) shall not exceed 0.15 pound per million Btu of heat input.

Notes:

(1) The Todd furnace (EU13) is not subject to the requirements of 326 IAC 6-1-2 because the emissions from the Todd furnace exhaust directly to the kiln #2 instead of to the atmosphere. The kiln #2 is already subject to the requirements of 326 IAC 6-1-17. (2) The fuel oil-fired air heater for kiln #1 (EU68) is not subject to the requirements of 326 IAC 6-1-2 because the emissions exhaust directly to kiln #1 instead of to the atmosphere. The kiln #1 is already subject to the requirements of 326 IAC 6-1- 17. (3) The fuel oil-fired air heater for kiln #2 does not exhaust to the kiln #2, but rather directly to a baghouse; therefore it is subject to the requirements of 326 IAC 6-1- 2.

(b) Particulate matter emissions from each facility not regulated by 326 IAC 6-1-17 or by (a) above (except for the Todd furnace (EU13) and the fuel oil-fired air heater for kiln #1 (EU68)) are subject to the requirements of 326 IAC 6-1-2(a). Pursuant to this rule, emissions from each of these facilities shall not exceed 0.03 grains per dry standard cubic foot (gr/dscf). These include all of the controlled facilities and all of the covered conveyors. All associated facilities exhausting to a single stack must all be operating when determining compliance with the limit.

Because there is not sufficient information available to determine whether some facilities are in compliance with these limits, stack tests are required for some of these facilities. In some cases, IDEM has determined that stack testing for one facility can be considered representative of emissions that would occur from several other facilities.ESSROC Cement Corporation Page 34 of 44 Speed, Indiana T019-6016-00008 Permit Reviewer: Nisha Sizemore

Processes Control Device ID Allowable PM Emissions

(gr/dscf) Calculated PTE After Controls (gr/dscf) Stack Testing Required (Yes or No)

Quarry activities

Quarry drilling (EU01) baghouse 01 unknown unknown no–not possible due to configuration of “baghouse,” which

has no exhaust. Emissions are collected in the “baghouse” and

re-deposited into the ground.

Raw Material Sizing Operations

secondary crusher EU02 baghouse CE200 0.03 0.04 no

Covered conveyor EU03, two tertiary crushers EU04 and EU04a, and stone ladder (EU05) baghouse CE201 0.03 0.04 no

North stone bin EU06 baghouse 101 0.03 0.04 no

South stone bin EU07 baghouses 102 and 103 0.03 0.04 no

Clay Processing Operations

Clay breaker (crusher) EU08 baghouse 227 0.03 0.04 no

Miscellaneous Facilities

vacuum system (EU73) baghouse 250 0.03 0.04 Yes

warehouse conveyor system (EU74) baghouse 249 0.03 0.04 Yes

Coal Handling, Milling, and Storage Facilities

kiln #2 coal handling system (EU151) baghouse 255 0.03 0.046 yes

kiln #2 coal dust silo (EU149) baghouse 253 0.03 0.046 yes

kiln #2 coal weigh system (EU150) baghouse 254 0.03 0.046 yes

Kiln #1 CKD Operations

CKD sales loadout (kiln #1 dust tank) (EU155) baghouse 266 0.03 0.040 yes

Clinker Handling to Crane Storage FacilitiesESSROC Cement Corporation Page 35 of 44 Speed, Indiana T019-6016-00008 Permit Reviewer: Nisha Sizemore

Processes Control Device ID Allowable PM Emissions

(gr/dscf) Calculated PTE After Controls (gr/dscf) Stack Testing Required (Yes or No)

South reclaim clinker covered conveyor EU124 baghouse 202 0.03 0.04 yes

long belt EU25 North clinker transfer tower EU32 baghouse 219 0.03 0.035 no

kiln #2 feed system EU26 baghouse 231 0.03 0.033 yes

Covered Incline / Shuttle Belt EU33 baghouse 220 0.03 0.035 no

Covered conveyor system EU34 baghouse 245 0.03 0.038 no

2ABC Finish Mill Facilities

CKD/Lime tank EU146 baghouse 143 0.03 0.035 yes

Gypsum stone transfer EU35 baghouse 131 0.03 0.040 no

baghouse 132 0.03 0.038 no

Clinker transfer circuit ABC mills EU36 baghouse 251 0.03 0.040 no

Elevators (2) EU37 2A finish mill circuit EU39 baghouse 134 0.03 0.035 yes

2A hopper / Preliminary mill EU38 baghouse 133 0.03 0.035 no

2B finish mill circuit EU40 baghouse 135 0.03 0.035 no

2C finish mill circuit EU42 baghouse 137 0.03 0.035 no

Separator and Cement cooler EU43 baghouse 138 0.03 0.035 no

Separator and Cement cooler EU41 baghouse 136 0.03 0.035 yes

2D Finish Mill Facilities

Gypsum elevator EU135 2D finish mill clinker bin EU44 baghouse 120 0.03 0.040 yes

2D finish mill circuit EU47 baghouse 139 0.03 0.035 yesESSROC Cement Corporation Page 36 of 44 Speed, Indiana T019-6016-00008 Permit Reviewer: Nisha Sizemore

Processes Control Device ID Allowable PM Emissions

(gr/dscf) Calculated PTE After Controls (gr/dscf) Stack Testing Required (Yes or No)

2D finish mill roll press circuit (EU46) and 2D finish mill clinker / gypsum feed circuit (EU45) baghouses 261, 262, and 263 0.03 0.035 yes

Fossil Fuel Storage and Handling Facilities

Covered conveyor system EU63 baghouse 206 0.03 0.040 no

Raw Mill Facilities

additive bins EU10, EU11, EU12 equipped with two elevators baghouse 228 0.03 0.04 no

Sidewinder EU15 baghouse 247 0.03 0.04 Yes

Blend silo #1 EU16 baghouse 211 0.03 0.035 no

Blend silo #2 EU17 baghouse 230 0.03 0.033 yes

Raw Mill and Kiln Facilities

kiln #1 feed system pump and (EU19) and Calibration system (EU18) baghouse 212 0.03 0.035 yes

Finish Product 504 silos storage and bulk loading facilities

504 silos (EU51) baghouses 153 through 156 0.03 0.035 no

326 IAC 7-1.1 ( Sulfur Dioxide Emission Limitations) (a) The kilns are subject to this rule because each kiln has the potential to emit greater than 25 tons per year or 10 pounds per hour of SO 2 . The SO 2 emissions from each of the kilns shall not exceed 6.0 pounds per million Btu of heat input when combusting coal or a combination of coal and oil. Compliance shall be demonstrated on a calendar month average.

(b) The fuel oil-fired furnaces (EU13, EU68, and EU69) are subject to this rule because each one has the potential to emit greater than 25 tons per year or 10 pounds per hour of SO 2 . The SO 2 emissions from each of the furnaces shall not exceed 0.5 pound per million BtuESSROC Cement Corporation Page 37 of 44 Speed, Indiana T019-6016-00008 Permit Reviewer: Nisha Sizemore

of heat input when combusting distillate fuel oil. Compliance shall be demonstrated on a calendar month average.

326 IAC 7-2-1 (Sulfur Dioxide Compliance Reporting) Pursuant to this rule, a quarterly report shall be submitted including the average sulfur content, heat content, the sulfur dioxide emission rate in pounds per million Btu, and the coal and fuel oil consumptions from each of the kilns (EU20 and EU27) and each of the fuel oil-fired furnaces (EU13, EU68, and EU69). Coal sampling and analysis data shall be collected pursuant to the procedures specified in 326 IAC 3-7-2 for coal combustion. Fuel oil sampling and analysis data shall be collected pursuant to the procedures specified in 326 IAC 3-7-4 for oil combustion.

326 IAC 8-7 (Specific VOC Reduction Requirements) 

### The requirements of 326 IAC 8-7 (Specific VOC emission reduction requirements for Lake, Porter, Clark, and Floyd Counties) are not applic able to this source, because the source is located in Clark County and the potential to emit VOC from the source (excluding exempted facilities as listed in the rule) is less than 100 tons per year. A summary of the applicability determination is shown in the following table:

Unit Description Potential to Emit VOC (tons/year) Include in Applicability Determination Notes

volatile storage tanks 10 (a) 

### no exempt per 326 IAC 8-7- 2(a)(3)(Q), volatile organic

liquid storage facilities

kiln #1 (b) 

### 6.68 yes

kiln #2 (b) 

### 75.5 yes
combustion sources 2.59 yes as per 326 IAC 8-7-2(2)(A)

Total for all units included in

applicability determination 84.77

Notes: (a) Emissions from the volatile storage tanks were estimated based on a conservative assumption. More accurate emission estimates are not necessary however, since the emissions from the storage tanks do not count toward the applicability determination of this rule.

(b) Detailed calculations of kiln emissions are shown in Appendix A.

As shown in the table above, the potential VOC emissions from all units included in the applicability determination, are less than 100 tons per year; therefore, the requirements of 326 IAC 8-7 (Specific VOC Reduction Requirements) do not apply.

326 IAC 10-1 (NOx Control in Clark and Floyd Counties) This source is subject to the requirements of this rule because it is located in Clark County and has the potential to emit NOx greater than 100 tons per year. The facilities at the source which are subject to the requirements of this rule are the following:

(1) The long dry rotary cement kiln #1 (EU20); and (2) The dry preheater rotary cement kiln #2 (EU27).

Pursuant to this rule the following conditions shall apply:ESSROC Cement Corporation Page 38 of 44 Speed, Indiana T019-6016-00008 Permit Reviewer: Nisha Sizemore

(1) NOx emissions from the long dry rotary cement kiln #1 (EU20) shall not exceed 10.8 pounds per ton of clinker produced on an operating day basis and six (6.0) pounds per ton of clinker produced on a thirty (30) day rolling average.

(2) NOx emissions from the dry preheater rotary cement kiln #2 (EU27) shall not exceed 5.9 pounds per ton of clinker produced on an operating day basis and 4.4 pounds per ton clinker produced on a thirty (30) day rolling average basis. During the ozone control period of each year after May 31, 2004, compliance with the requirements of 326 IAC 10- 3 will also satisfy the requirements 326 IAC 10-1 for kiln #2.

(3) Compliance with these limits shall be demonstrated by installing and operating a NOx continuous emissions monitor (CEM). The CEM shall be certified according to procedures contained in 326 IAC 3 and 40 CFR 75 as applicable.

(4) CEM performance evaluation reports shall be submitted each calendar quarter.

(5) The source shall notify the OAQ at least thirty (30) days prior to the addition or modification of a facility that may result in a potential increase in NOx emissions.

(6) The source may comply with the reporting requirements of this rule by submitting to the OAQ a substitute report. A substitute report is a report that satisfies an applicable state or federal reporting requirement and contains the information required to be submitted by this rule.

The kilns are not currently in compliance with the requirements of this rule.

Kiln #1 has been in violation of the NOx emissi on limit. Additionally, the NOx CEM on kiln #1 has failed the last 2 RATA tests and is currently operating without being properly certified. IDEM has requested that ESSROC submit a plan to bring kiln #1 into compliance with these requirements. To date, no such plan has been submitted. Therefore, IDEM has included provisions in the permit requiring ESSROC to either repair the CEM and pass a RATA within 90 days of issuance of this permit or replace the CEM and pass a RATA within 120 days of issuance of this permit.

ESSROC also needs to propose a compliance plan to bring kiln #1 NOx emissions into compliance with the NOx emission limits listed in 326 IAC 10-1. IDEM has requested that ESSROC submit such a compliance plan; however, ESSROC has not yet submitted a plan. Once ESSROC and IDEM agree on a compliance plan, IDEM will re-open the Part 70 permit and include the compliance plan in the permit.

The Permittee is not in compliance with the requirement to operate a NOx CEM on all stacks for kiln #2. ESSROC has not installed a NOx CEM on the alkali bypass stack for kiln #2. In order for kiln #2 to come into compliance with the requirements of 326 IAC 10-1, the Permittee shall install, calibrate, maintain, and operate a NOx continuous emissions monitor (CEM) on the stack identified as EP23 for the elevator/dust tank (alkali bypass) identified as EU28 on kiln #2, within 180 days after the date of issuance of this permit. The NOx CEMs shall be certified according to procedures contained in 326 IAC 3 and 40 CFR 75 as applicable.

326 IAC 10-3 (NOx Emission Limits)(a) Pursuant to 326 IAC 10-3, beginning on May 31, 2004, kiln #2 shall be equipped with lowNOx burners. This rule shall apply to kiln #2 during the ozone control period of each year. The requirements of 326 IAC 10-1 shall apply to kiln #2 at all other times.

(b) The requirements of 326 IAC 10-3 do not apply to kiln #1 because it is not a long dry kiln as defined in 326 IAC 10-3-2(5) because it is less than 14 feet in diameter. Therefore, the requirements of 326 IAC 10-1 (above) shall apply to kiln #1 at all times.ESSROC Cement Corporation Page 39 of 44 Speed, Indiana T019-6016-00008 Permit Reviewer: Nisha Sizemore

State Rule App licability - Insignificant Activities

326 IAC 8-4-3 (Petroleum Liquid Storage Facilities) All of the petroleum storage tanks at ESSROC have capacities less than 39,000 gallons. Therefore, the requirements of 326 IAC 8-4-3 do not apply.

326 IAC 8-4-6 (Gasoline Dispensing Facilities) The gasoline dispensing facility at ESSROC was constructed prior to July 1, 1989, and has monthly gasoline throughputs of less than 10,000 gallons. Therefore, the requirements of 326 IAC 8-4-6 do not apply.

326 IAC 8-3-2 (Cold Cleaner Operations) 

### The parts washers are subject to the requirement s of these rules. Pursuant to 326 IAC 8-3-2 (Cold Cleaner Operations), for cold cleaning oper ations constructed after January 1, 1980, the Permittee shall:

(a) Equip the cleaner with a cover;

(b) Equip the cleaner with a facility for draining cleaned parts;

(c) Close the degreaser cover whenever parts are not being handled in the cleaner;

(d) Drain cleaned parts for at least fifteen (15) seconds or unt il dripping ceases;

(e) Provide a permanent, conspicuous label summarizing the operation requirements;

(f) Store waste solvent only in covered containers and not dispose of waste solvent or transfer it to another party, in such a manner that greater than twenty percent (20%) of the waste solvent (by weight) can evaporate into the atmosphere.

326 IAC 8-3-5 (Cold Cleaner Degreaser Operation and Control) 

### (a) Pursuant to 326 IAC 8-3-5(a) (Cold Cleaner Degreaser Operation and Control), for a cold cleaner degreaser facility construction of which commenced after July 1, 1990, the Permittee shall ensure that the following control equipment requirements are met:

(1) Equip the degreaser with a cover. The cover must be designed so that it can be easily operated with one (1) hand if:

(A) The solvent volatility is greater than two (2) kiloPascals (fifteen (15) millimeters of mercury or three-t enths (0.3) pounds per square inch) measured at thirty-eight degrees Celsius (38 O 

### C) (one hundred degrees Fahrenheit (100 O 

### F));

(B) The solvent is agitated; or

(C) The solvent is heated.

(2) Equip the degreaser with a facility for draining cleaned articles. If the solvent volatility is greater than four and three-t enths (4.3) kiloPascals (thirty-two (32) millimeters of mercury or six-tenths (0.6) pounds per square inch) measured at thirty-eight degrees Celsius (38 O 

### C) (one hundred degrees Fahrenheit (100 O 

### F)), then the drainage facility must be internal such that articles are enclosed under the cover while draining. The drainage facility may be external for applications where an internal type cannot fit into the cleaning system.ESSROC Cement Corporation Page 40 of 44 Speed, Indiana T019-6016-00008 Permit Reviewer: Nisha Sizemore



### (3) Provide a permanent, conspicuous label which lists the operating requirements outlined in subsection (b).

(4) The solvent spray, if used, must be a solid, fluid stream and shall be applied at a pressure which does not cause excessive splashing.

(5) Equip the degreaser with one (1) of the following control devices if the solvent volatility is greater than four and three-t enths (4.3) kiloPascals (thirty-two (32) millimeters of mercury or six-tenths (0.6) pounds per square inch) measured at thirty-eight degrees Celsius (38 O 

### C) (one hundred degrees Fahrenheit (100 O 

### F)),or if the solvent is heated to a temperature greater than forty-eight and ninetenths degrees Celsius (48.9 O 

### C) (one hundred twenty degrees Fahrenheit (120 O 

### F)):

(A) A freeboard that attains a freeboard ratio of seventy-five hundredths (0.75) or greater.

(B) A water cover when solvent is used is insoluble in, and heavier than, water.

(C) Other systems of demonstrated equivalent control such as a refrigerated chiller of carbon adsorption. Such systems shall be submitted to the U.S. EPA as a SIP revision.

(b) Pursuant to 326 IAC 8-3-5(b) (Cold Cleaner Degreaser Operation and Control), for a cold cleaning facility construction of which commenced after July 1, 1990, the Permittee shall ensure that the following operating requirements are met:

(1) Close the cover whenever articles are not being handled in the degreaser.

(2) Drain cleaned articles for at least fift een (15) seconds or until dripping ceases.

(3) Store waste solvent only in covered containers and prohibit the disposal or transfer of waste solvent in any manner in which greater than twenty percent (20%) of the waste solvent by weight could evaporate.

326 IAC 8-3-8 

### (Organic Solvent Degreasing Operations: material requirements for cold cleaning degreasers) The cold cleaning degreasers are subject to the r equirements of this rule because the source is located in Clark County and the parts being cleaned are not considered electronic components. Pursuant to 326 IAC 8-3-8 (Organic Solvent Degr easing Operations: material requirements for cold cleaning degreasers), the fo llowing conditions shall apply:

(a) The source shall not operate a cold cl eaning degreaser with a solvent vapor pressure that exceeds one (1) millimeter of me rcury (nineteen-thousandths (0.019) pound per square inch) measured at twenty (20) degr ees Celsius (sixty-eight (68) degrees Fahrenheit).

(b) The source shall maintain the following records for each purchase:

(1) the name and address of the solvent supplier; (2) the date of purchase; (3) the type of solvent; (4) the volume of each unit of solvent;ESSROC Cement Corporation Page 41 of 44 Speed, Indiana T019-6016-00008 Permit Reviewer: Nisha Sizemore



### (5) the total volume of the solvent; and (6) the true vapor pressure of the solvent measured in millimeters of mercury at twenty (20) degrees Celsius (sixty -eight (68) degrees Fahrenheit);

Compliance Requirements

Permits issued under 326 IAC 2-7 are required to ensure that sources can demonstrate compliance with applicable state and federal rules on a more or less continuous basis. All state and federal rules contain compliance provisions, however, these provisions do not always fulfill the requirement for a more or less continuous demonstration. When this occurs IDEM, OAQ, in conjunction with the source, must develop specific conditions to satisfy 326 IAC 2-7-5. As a result, compliance requirements are divided in to two sections: Compliance Determination Requirements and Compliance Monitoring Requirements.

Compliance Determination Requirements in permit Section D are those conditions that are found more or less directly within state and federal rules and the violation of which serves as grounds for enforcement action. If these conditions are not sufficient to demonstrate continuous compliance, they will be supplemented with Compliance Monitoring Requirements, also in permit Section D. Unlike Compliance Determination Requirements, failure to meet Compliance Monitoring conditions would serve as a trigger for correctiv e actions and not grounds for enforcement action. However, a violation in relation to a complianc e monitoring condition will arise through a source’s failure to take the appropriate corrective actions within a specific time period.

The compliance monitoring requirements applicable to this source are as follows:

The various processes at ESSROC’s production plant have applicable compliance monitoring conditions as specified below:

(a) Visible emissions notations of the controlled stack exhausts (except those equipped with a COM) shall be performed once per shift during normal daylight operations. A trained employee will record whether emissions are normal or abnormal. For processes operated continuously “normal” means those conditions prevailing, or expected to prevail, eighty percent (80%) of the time the process is in operation, not counting startup or shut down time. In the case of batch or discontinuous operations, readings shall be taken during that part of the operation that would normally be expected to cause the greatest emissions. A trained employee is an employee who has worked at the plant at least one (1) month and has been trained in the appearance and characteristics of normal visible emissions for that specific process. The Compliance Response Plan for these units shall contain troubleshooting contingency and response steps for when an abnormal emission is observed. 

### Failure to take response steps in accordance with Section C - Compliance Response Plan - Preparation, Implementation, Records, and Reports, shall be considered a violation of this permit.

(b) The Permittee shall record the total static pressure drop across all of the baghouses, at least once per shift when the associated processes are in operation. The normal ranges of the baghouses are as listed in the permit. The Compliance Response Plan for these units shall contain troubleshooting contingency and response steps for when the pressure reading is outside of the normal range for any one reading. 

### Failure to take response steps in accordance with Section C - Compliance Response Plan - Preparation, Implementation, Records, and Reports, shall be considered a violation of this permit.

(c) The ability of the ESPs to control particulate emissions will be monitored continuously, when the units are in operation, by measuring and recording the opacity of the kiln exhausts. Appropriate response steps will be taken in accordance with Section C -ESSROC Cement Corporation Page 42 of 44 Speed, Indiana T019-6016-00008 Permit Reviewer: Nisha Sizemore



### Compliance Response Plan - Preparation, Implementation, Records, and Reports whenever the opacity exceeds 18 percent for any three consecutive six-minute average periods for kilns #1 and #2 and whenever the opacity exceeds 8 percent for any three consecutive six-minute average periods for clinker cooler #1 and clinker cooler #2.

(d) 

### The ability of the ESP to control particulate emissions shall be monitored once per shift, when the unit is in operation, by measuring and recording the number of T-R sets in service and the primary and secondary voltages and the currents of the transformerrectifier (T-R) sets. Reasonable response steps shall be taken in accordance with Section C - Compliance Response Plan - Preparation, Implementation, Records, and Reports whenever the percentage of T-R sets in service falls below 90 percent (90%). T-R set failure resulting in less than 90 percent (90%) availability is not a deviation from this permit. Failure to take response steps in accordance with Section C - Compliance Response Plan - Preparation, Implementation, Records, and Reports, shall be considered a violation of this permit.

(e) 

### An inspection shall be performed each ca lender quarter of all bags. Inspections required by this condition shall not be perfo rmed in consecutive months. All defective bags shall be replaced.

(f) In the event that bag failure has been observed:

(1) For multi-compartment units, the affected compartments will be shut down immediately until the failed units have been repaired or replaced. Operations may continue only if there are no visible emissions or if the event qualifies as an emergency and the Permittee satisfies the emergency provisions of this permit (Section B- Emergency Provisions). Wi thin eight (8) business hours of the determination of failure, response steps according to the timetable described in the Compliance Response Plan shall be initiated. For any failure with corresponding response steps and timetable not described in the Compliance Response Plan, response steps shall be devised within eight (8) business hours of discovery of the failure and shall include a timetable for completion. Failure to take response steps in accordance with Section C - Compliance Response Plan - Preparation, Implementation, Records, and Reports, shall be considered a violation of this permit.

(2) For single compartment baghouses, if failure is indicated by a significant drop in the baghouse’s pressure readings with abnormal visible emissions or the failure is indicated by an opacity violation, or if bag failure is determined by other means, such as gas temperatures, flow rate s, air infiltration, leaks, dust traces or triboflows, then the failed units and the associated process will be shut down immediately until the failed units have been repaired or replaced. Operations may continue only if the event qualifies as an emergency and the Permittee satisfies the requirements of the emergency provisions of this permit (Section B - Emergency Provisions).



### (g) Pursuant to 326 IAC 3-5 (Continuous Monitoring of Emissions), 326 IAC 2-1.1-11 and/or 40 CFR Parts 60 and 63, a continuous monitoring system shall be installed, calibrated, maintained, and operated for measuring opacity from each of the kilns. The continuous monitoring systems shall meet the perfo rmance specifications of 326 IAC 3-5-2.

(h) Pursuant to 326 IAC 3-5 (Continuous Monitoring of Emissions) and 326 IAC 2-1.1-11, and/or 40 CFR Parts 60 and 63 a continuous monitoring system shall be installed, calibrated, maintained, and operated for meas uring opacity from each of the clinker coolers. The continuous monitoring system s shall meet the performance specificationsESSROC Cement Corporation Page 43 of 44 Speed, Indiana T019-6016-00008 Permit Reviewer: Nisha Sizemore



### of 326 IAC 3-5-2.

(i) 

### Pursuant to 326 IAC 10-1 (NOx Control in Clark and Floyd Counties) and 326 IAC 10-3 (NOx Emission Limits) for kiln #2, a continuous monitoring system shall be installed, calibrated, maintained, and operated for measuring NOx emissions from each of the kilns. The continuous monitoring systems s hall meet the performance specifications of 326 IAC 3.

(j) In order to document compliance with the applicable PM and dioxin/furan limits specified in Condition D.3.5 the following inspections shall be performed for each ESP during each annual shutdown, but no less often than once every 14 months, in accordance with the Preventive Maintenance Plan prepared in accordance with Section B - Preventive Maintenance Plan:

(1) Plate and electrode alignment; (2) ESP component/controller failure; (3) Air and water infiltration; and (4) Calibration of the instruments used to determine the T-R set current and voltages.

All inspections shall be made whenever there is an outage of any nature lasting more than three days unless such measurements have been taken within the past three months.

Appropriate response steps for any failures, malfunctions, or abnormal conditions in the above list found during the inspection shall be taken in accordance with Section C - Compliance Response Plan - 

### Preparation, Implementation, Records, and Reports

. 

### Failure to take response steps in accordance with Section C - Compliance Response Plan - Preparation, Implementation, Records, and Reports, shall be considered a violation of this permit.

(k) Stack tests shall be performed as shown in the table on pages 33-35 of this document as well as those indicated in the table below. Stack tests shall be performed utilizing methods as approved by the Commissioner. In all cases PM10 includes filterable and condensible PM10.

Facilities to be tested Pollutants for which to test Testing Schedule

kilns #1 and #2 PM, opacity, and dioxin/furan Within 6 months after permit issuance, then once every 2.5 years

clinker coolers PM and opacity Within 6 months after permit issuance, then once every 2.5 years

These monitoring conditions are necessary because the baghouses and ESPs for the processes must operate properly to ensure compliance with 326 IAC 6-1 (Particulate Matter Emission Limitations), 326 IAC 2-2 (Prevention of Signi ficant Deterioration), 326 IAC 5-1 (Opacity Limitations), 40 CFR 60, Subpart Y (Coal Pr eparation Plants), 40 CFR 63, Subpart LLL (NESHAP for Portland Cement Plants) and 326 IAC 2-7 (Part 70).ESSROC Cement Corporation Page 44 of 44 Speed, Indiana T019-6016-00008 Permit Reviewer: Nisha Sizemore

Conclusion

The operation of this Portland cement manufacturing operation shall be subject to the conditions of the attached proposed Part 70 Permit No. T019-6016-00008.Appendix A: Emission CalculationsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemoreMaximumEmission Potential EmissionsEmission Unit Capacity Pollutant Factor PM PM10 SOx NOx VOC CO(tons/hr) (lb/ton) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)Secondary Crusher1050 PM 0.015 68.985 68.985 0.000 0.000 0.000 0.000EU02PM10 0.015SCC 3-05-020-02 SOx 0NOx 0VOC 0CO 0Pollutant Control Air Flow Outlet Grain Emissions After ControlsType of Control Device andID numberEfficiencyRate Loading PM PM10 SOx NOx VOC CO(acfm) (gr/acfm)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)baghouse 200 PM 99.8% 67000.04 0.138 0.138 0.000 0.000 0.000 0.000PM10 99.8%SOxNOxVOCCOPM EmissionsType of Control Device and ID number Temperature After Controls(degrees F)(gr/dscfm)baghouse 20070 0.04Applicable Can Compliance EmissionEmission Unit PollutantRules bedetermined?Limits(Y or N)Secondary Crusher PM 6-1-2 No0.03 A stack test will be required to demonstrate compliancegr/dscfmPM10SOxNOxVOCCOPage 1potentials-limitsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemoreMaximumEmission Potential EmissionsEmission Unit Capacity Pollutant Factor PM PM10 SOx NOx VOC CO(tons/hr) (lb/ton) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)Covered Conveyor1050 PM 0.0159 73.124 34.676 0.000 0.000 0.000 0.000EU03PM10 0.0075SCC 3-05-020-06 SOx 0NOx 0VOC 0CO 0Pollutant Control Air Flow Outlet Grain Emissions After ControlsType of Control Device andID numberEfficiencyRate Loading PM PM10 SOx NOx VOC CO(acfm) (gr/acfm)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)baghouse 201 PM 99.8% 300000.04 0.146 0.069 0.000 0.000 0.000 0.000PM10 99.8%SOxNOxVOCCOPM EmissionsType of Control Device and ID number Temperature After Controls(degrees F)(gr/dscfm)baghouse 20170 0.04Applicable Can Compliance EmissionEmission Unit PollutantRules bedetermined?Limits(Y or N)Covered Conveyor PM 6-1-2 No0.03 A stack test will be required to demonstrate compliancegr/dscfmPM10SOxNOxVOCCOPage 2potentials-limitsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemoreMaximumEmission Potential EmissionsEmission Unit Capacity Pollutant Factor PM PM10 SOx NOx VOC CO(tons/hr) (lb/ton) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)Tertiary Crusher350 PM 0.015 22.995 22.995 0.000 0.000 0.000 0.000EU04PM10 0.015SCC 3-05-020-03 SOx 0NOx 0VOC 0CO 0Pollutant Control Air Flow Outlet Grain Emissions After ControlsType of Control Device andID numberEfficiencyRate Loading PM PM10 SOx NOx VOC CO(acfm) (gr/acfm)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)baghouse 201 PM 99.8% 300000.04 0.046 0.046 0.000 0.000 0.000 0.000PM10 99.8%SOxNOxVOCCOPM EmissionsType of Control Device and ID number Temperature After Controls(degrees F)(gr/dscfm)baghouse 20170 0.04Applicable Can Compliance EmissionEmission Unit PollutantRules bedetermined?Limits(Y or N)Tertiary Crusher PM 6-1-2 No 0.03 A stack test will be required to demonstrate compliancegr/dscfmPM10SOxNOxVOCCOPage 3potentials-limitsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemoreMaximumEmission Potential EmissionsEmission Unit Capacity Pollutant Factor PM PM10 SOx NOx VOC CO(tons/hr) (lb/ton) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)Stone Ladder1050 PM 0.0014 6.439 6.439 0.000 0.000 0.000 0.000EU05PM10 0.0014SCC 3-05-020-06 SOx 0NOx 0VOC 0CO 0Pollutant Control Air Flow Outlet Grain Emissions After ControlsType of Control Device andID numberEfficiencyRate Loading PM PM10 SOx NOx VOC CO(acfm) (gr/acfm)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)baghouse 201 PM 99.8% 300000.04 0.013 0.013 0.000 0.000 0.000 0.000PM10 99.8%SOxNOxVOCCOPM EmissionsType of Control Device and ID number Temperature After Controls(degrees F)(gr/dscfm)baghouse 20170 0.04Applicable Can Compliance EmissionEmission Unit PollutantRules bedetermined?Limits(Y or N)Stone Ladder PM 6-1-2 No 0.03 A stack test will be required to demonstrate compliancegr/dscfmPM10SOxNOxVOCCOPage 4potentials-limitsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemoreMaximumEmission Potential EmissionsEmission Unit Capacity Pollutant Factor PM PM10 SOx NOx VOC CO(tons/hr) (lb/ton) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)Clay Breaker (Crusher)40 PM 0.0007 0.123 0.123 0.000 0.000 0.000 0.000EU08PM10 0.0007SCC 3-05-020-01 SOx 0NOx 0VOC 0CO 0Pollutant Control Air Flow Outlet Grain Emissions After ControlsType of Control Device andID numberEfficiencyRate Loading PM PM10 SOx NOx VOC CO(acfm) (gr/acfm)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)baghouse 227 PM 99.8% 150000.04 0.000 0.000 0.000 0.000 0.000 0.000PM10 99.8%SOxNOxVOCCOPM EmissionsType of Control Device and ID number Temperature After Controls(degrees F)(gr/dscfm)baghouse 22770 0.04Applicable Can Compliance EmissionEmission Unit PollutantRules bedetermined?Limits(Y or N)Clay Breaker (Crusher) PM 6-1-2 No 0.03 A stack test will be required to demonstrate compliancegr/dscfmPM10SOxNOxVOCCOPage 5potentials-limitsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemoreMaximumEmission Potential EmissionsEmission Unit Capacity Pollutant Factor PM PM10 SOx NOx VOC CO(tons/hr) (lb/ton) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)Covered Conveyor System1050 PM 0.0159 73.124 34.676 0.000 0.000 0.000 0.000EU09PM10 0.0075SCC 3-05-020-06 SOx 0NOx 0VOC 0CO 0Pollutant Control Air Flow Outlet Grain Emissions After ControlsType of Control Device andID numberEfficiencyRate Loading PM PM10 SOx NOx VOC CO(acfm) (gr/acfm)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)baghouse 227 PM 99.8% 150000.04 0.095 0.045 0.000 0.000 0.000 0.000baghouse 229 PM 99.8%8000 0.04 0.051 0.051total PM23000 0.146 0.096PM10 99.8%SOxNOxVOCCOPM EmissionsType of Control Device and ID number Temperature After Controls(degrees F)(gr/dscfm)baghouse 22770 0.04baghouse 22970 0.04Applicable Can Compliance EmissionEmission Unit PollutantRules bedetermined?Limits(Y or N)Covered Conveyor System PM6-1-2 No 0.03 A stack testwill be required to demonstrate compliancegr/dscfmPM10SOxNOxVOCCOPage 6potentials-limitsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemoreMaximumEmission Potential EmissionsEmission Unit Capacity Pollutant Factor PM PM10 SOx NOx VOC CO(tons/hr) (lb/ton) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)Loesche Raw Mill300 PM 0.0120 7884.000 7884.000 0.000 0.000 0.000 0.000EU14PM10 0.0120SCC 3-05-020-01 SOx 0NOx 0Note: these emission factors are for raw mills VOC 0with fabric filters so emissions before controls are CO 0estimated by using the control efficiency.Pollutant Control Air Flow Outlet Grain Emissions After ControlsType of Control Device andID numberEfficiencyRate Loading PM PM10 SOx NOx VOC CO(acfm) (gr/acfm)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)ESP15 PM 99.8%2400000.03 15.768 15.768 0.000 0.000 0.000 0.000PM10 99.8%SOxNOxVOCCOPM EmissionsType of Control Device and ID number Temperature After Controls(degrees F)(gr/dscfm)ESP15 200 0.02Applicable Can Compliance EmissionEmission Unit PollutantRules bedetermined?Limits(Y or N)Loesche Raw Mill PM 6-1-2 Yes 0.03gr/dscfmPM10SOxNOxVOCCOPage 7potentials-limitsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemoreMaximumEmission Potential EmissionsEmission Unit Capacity Pollutant Factor PM PM10 SOx NOx VOC CO(tons/hr) (lb/ton) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)Kiln #1 feed system100 PM - 1294.286 1294.286EU19PM10 -SOx -NOx -VOC -CO -Pollutant Control Air Flow Outlet Grain Emissions After ControlsType of Control Device andID numberEfficiencyRate Loading PM PM10 SOx NOx VOC CO(acfm) (gr/acfm)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)baghouse 209 PM 99.8%2600 0.02 2.589 2.589baghouse 212 PM99.8% 6250 0.04PM10 99.8%SOxNOxVOCCOPM EmissionsType of Control Device and ID number Temperature After Controls(degrees F)(gr/dscfm)baghouse 209 150 0.017baghouse 212 150 0.035Applicable Can Compliance EmissionEmission Unit PollutantRules bedetermined?Limits(Y or N)Kiln #1 feed system PM 6-1-2No 0.03 A stack test will be required to demonstrate compliancegr/dscfmPM10SOxNOxVOCCOPage 8potentials-limitsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemoreMaximumEmission Potential EmissionsEmission Unit Capacity Pollutant Factor PM PM10 SOx NOx VOC CO(tons/hr) (lb/ton) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)Clinker Cooler #154.5 PM 0.14717545 17545 0.000 0.000 0.000 0.000EU22PM10 0.147SCC 3-05-006-14 SOx 0NOx 0Note: these emission factors are for clinker coolers VOC 0with fabric filters so emissions before controls are CO 0estimated by using the control efficiency.Pollutant Control Air Flow Outlet Grain Emissions After ControlsType of Control Device andID numberEfficiencyRate Loading PM PM10 SOx NOx VOC CO(acfm) (gr/acfm)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)baghouse 222 PM 99.8%1655000.02 35.090 35.090 0.000 0.000 0.000 0.000PM10 99.8%SOxNOxVOCCOPage 9potentials-limitsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemoreMaximumEmission Potential EmissionsEmission Unit Capacity Pollutant Factor PM PM10 SOx NOx VOC CO(tons/hr) (lb/ton) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)Clinker Drag Conveyor75 PM 0.0159 5.223 2.477 0.000 0.000 0.000 0.000EU21PM10 0.0075SCC 3-05-020-06 SOx 0NOx 0VOC 0CO 0Pollutant Control Air Flow Outlet Grain Emissions After ControlsType of Control Device andID numberEfficiencyRate Loading PM PM10 SOx NOx VOC CO(acfm) (gr/acfm)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)baghouse 217 PM 99.8% 50000.04 0.010 0.005 0.000 0.000 0.000 0.000PM10 99.8%SOxNOxVOCCOPM EmissionsType of Control Device and ID number Temperature After Controls(degrees F)(gr/dscfm)baghouse 217 250 0.030Applicable Can Compliance EmissionEmission Unit PollutantRules bedetermined?Limits(Y or N)Clinker Drag Conveyor PM6-1-2 Yes 0.03gr/dscfmPM10SOxNOxVOCCOPage 10potentials-limitsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemoreMaximumEmission Potential EmissionsEmission Unit Capacity Pollutant Factor PM PM10 SOx NOx VOC CO(tons/hr) (lb/ton) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)Apron Conveyor and Clinker Can #175 PM 0.0159 5.2 2.5 0.000 0.000 0.000 0.000EU24 and EU114 PM10 0.0075SCC 3-05-020-06 SOx -NOx -VOC -CO -Pollutant Control Air Flow Outlet Grain Emissions After ControlsType of Control Device andID numberEfficiencyRate Loading PM PM10 SOx NOx VOC CO(acfm) (gr/acfm)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)baghouse 218 PM 99.8% 48000.04 1.646 1.646 0.000 0.000 0.000 0.000PM10 99.8%SOxNOxVOCCOPM EmissionsType of Control Device and ID number Temperature After Controls(degrees F)(gr/dscfm)baghouse 218 250 0.030Applicable Can Compliance EmissionEmission Unit PollutantRules bedetermined?Limits(Y or N)Apron Conveyor and Clinker Can #1 PM 6-1-2 Yes 0.03gr/dscfmPM10SOxNOxVOCCOPage 11potentials-limitsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemoreMaximumEmission Potential EmissionsEmission Unit Capacity Pollutant Factor PM PM10 SOx NOx VOC CO(tons/hr) (lb/ton) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)Long Belt200 PM 0.0159 13.928 6.605 0.000 0.000 0.000 0.000EU25PM10 0.0075SCC 3-05-020-06 SOx 0Crane Storage Facilities NOx 0VOC 0CO 0Pollutant Control Air Flow Outlet Grain Emissions After ControlsType of Control Device andID numberEfficiencyRate Loading PM PM10 SOx NOx VOC CO(acfm) (gr/acfm)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)baghouse 219 PM 99.8% 24000.04 0.028 0.013 0.000 0.000 0.000 0.000PM10 99.8%SOxNOxVOCCOPM EmissionsType of Control Device and ID number Temperature After Controls(degrees F)(gr/dscfm)baghouse 219 150 0.035Applicable Can Compliance EmissionEmission Unit PollutantRules bedetermined?Limits(Y or N)Long Belt PM 6-1-2 No 0.03 A stacktest will be required to demonstrate compliancegr/dscfmPM10SOxNOxVOCCOPage 12potentials-limitsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemoreMaximumEmission Potential EmissionsEmission Unit Capacity Pollutant Factor PM PM10 SOx NOx VOC CO(tons/hr) (lb/ton) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)Kiln #2 feed system150 PM - 514.286 514.286EU26PM10 -SOx -NOx -VOC -CO -Pollutant Control Air Flow Outlet Grain Emissions After ControlsType of Control Device andID numberEfficiencyRate Loading PM PM10 SOx NOx VOC CO(acfm) (gr/acfm)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)baghouse 231 PM 99.8%3000 0.04 1.029 1.029PM10 99.8%SOxNOxVOCCOPM EmissionsType of Control Device and ID number Temperature After Controls(degrees F)(gr/dscfm)baghouse 231 180 0.033Applicable Can Compliance EmissionEmission Unit PollutantRules bedetermined?Limits(Y or N)Kiln #2 feed system PM 6-1-2No 0.03 A stack test will be required to demonstrate compliancegr/dscfmPM10SOxNOxVOCCOPage 13potentials-limitsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemoreMaximumEmission Potential EmissionsEmission Unit Capacity Pollutant Factor PM PM10 SOx NOx VOC CO(tons/hr) (lb/ton) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)Clinker Cooler #296.0 PM 0.14730905 30905 0.000 0.000 0.000 0.000EU29PM10 0.147SCC 3-05-006-14 SOx 0NOx 0Note: these emission factors are for clinker coolers VOC 0with fabric filters so emissions before controls are CO 0estimated by using the control efficiency.Pollutant Control Air Flow Outlet Grain Emissions After ControlsType of Control Device andID numberEfficiencyRate Loading PM PM10 SOx NOx VOC CO(acfm) (gr/acfm)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)baghouse 17 PM 99.8%1655000.02 61.811 61.811 0.000 0.000 0.000 0.000PM10 99.8%SOxNOxVOCCOPage 14potentials-limitsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemoreMaximumEmission Potential EmissionsEmission Unit Capacity Pollutant Factor PM PM10 SOx NOx VOC CO(tons/hr) (lb/ton) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)Clinker Drag Conveyor100 PM 0.0159 6.964 3.303 0.000 0.000 0.000 0.000EU30PM10 0.0075SCC 3-05-020-06 SOx 0Kiln #2 Clinker Handling Facilities NOx 0VOC 0CO 0Pollutant Control Air Flow Outlet Grain Emissions After ControlsType of Control Device andID numberEfficiencyRate Loading PM PM10 SOx NOx VOC CO(acfm) (gr/acfm)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)baghouse 233 PM 99.8% 49000.04 0.014 0.007 0.000 0.000 0.000 0.000PM10 99.8%SOxNOxVOCCOPM EmissionsType of Control Device and ID number Temperature After Controls(degrees F)(gr/dscfm)baghouse 233 340 0.026Applicable Can Compliance EmissionEmission Unit PollutantRules bedetermined?Limits(Y or N)Clinker Drag Conveyor PM6-1-2 Yes 0.03gr/dscfmPM10SOxNOxVOCCOPage 15potentials-limitsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemoreMaximumEmission Potential EmissionsEmission Unit Capacity Pollutant Factor PM PM10 SOx NOx VOC CO(tons/hr) (lb/ton) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)Apron Conveyor and Clinker Can #2100 PM 0.0159 7.0 3.3 0.000 0.000 0.000 0.000EU31 and EU120 PM10 0.0075SCC 3-05-020-06 SOx -Kiln #2 Clinker Handling Facilities NOx -VOC -CO -Pollutant Control Air Flow Outlet Grain Emissions After ControlsType of Control Device andID numberEfficiencyRate Loading PM PM10 SOx NOx VOC CO(acfm) (gr/acfm)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)baghouse 234 PM 99.8% 71000.04 2.434 2.434 0.000 0.000 0.000 0.000PM10 99.8%SOxNOxVOCCOPM EmissionsType of Control Device and ID number Temperature After Controls(degrees F)(gr/dscfm)baghouse 234 340 0.026Applicable Can Compliance EmissionEmission Unit PollutantRules bedetermined?Limits(Y or N)Apron Conveyor and Clinker Can #2 PM 6-1-2 Yes 0.03gr/dscfmPM10SOxNOxVOCCOPage 16potentials-limitsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemoreMaximumEmission Potential EmissionsEmission Unit Capacity Pollutant Factor PM PM10 SOx NOx VOC CO(tons/hr) (lb/ton) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)Cross Belt100 PM 0.0159 6.964 3.303 0.000 0.000 0.000 0.000EU119PM10 0.0075SCC 3-05-020-06 SOx 0Kiln #2 Clinker Handling Facilities NOx 0VOC 0CO 0Pollutant Control Air Flow Outlet Grain Emissions After ControlsType of Control Device andID numberEfficiencyRate Loading PM PM10 SOx NOx VOC CO(acfm) (gr/acfm)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)baghouse 235 PM 99.8% 22000.04 0.014 0.007 0.000 0.000 0.000 0.000PM10 99.8%SOxNOxVOCCOPM EmissionsType of Control Device and ID number Temperature After Controls(degrees F)(gr/dscfm)baghouse 235 340 0.026Applicable Can Compliance EmissionEmission Unit PollutantRules bedetermined?Limits(Y or N)Cross Belt PM 6-1-2 Yes 0.03gr/dscfmPM10SOxNOxVOCCOPage 17potentials-limitsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemoreMaximumEmission Potential EmissionsEmission Unit Capacity Pollutant Factor PM PM10 SOx NOx VOC CO(tons/hr) (lb/ton) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)North Clinker Transfer Tower200 PM 0.0159 13.928 6.605 0.000 0.000 0.000 0.000EU32PM10 0.0075SCC 3-05-020-06 SOx 0Clinker Handling to Crane Storage Facilities NOx 0VOC 0CO 0Pollutant Control Air Flow Outlet Grain Emissions After ControlsType of Control Device andID numberEfficiencyRate Loading PM PM10 SOx NOx VOC CO(acfm) (gr/acfm)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)baghouse 219 PM 99.8% 24000.04 0.028 0.013 0.000 0.000 0.000 0.000PM10 99.8%SOxNOxVOCCOPM EmissionsType of Control Device and ID number Temperature After Controls(degrees F)(gr/dscfm)baghouse 219 150 0.035Applicable Can Compliance EmissionEmission Unit PollutantRules bedetermined?Limits(Y or N)North Clinker Transfer Tower PM 6-1-2 No0.03 A stack test will be required to demonstrate compliancegr/dscfmPM10SOxNOxVOCCOPage 18potentials-limitsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemoreMaximumEmission Potential EmissionsEmission Unit Capacity Pollutant Factor PM PM10 SOx NOx VOC CO(tons/hr) (lb/ton) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)Covered Incline/Shuttle Belt200 PM 0.0159 13.928 6.605 0.000 0.000 0.000 0.000EU33PM10 0.0075SCC 3-05-020-06 SOx 0NOx 0VOC 0CO 0Pollutant Control Air Flow Outlet Grain Emissions After ControlsType of Control Device andID numberEfficiencyRate Loading PM PM10 SOx NOx VOC CO(acfm) (gr/acfm)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)baghouse 220 PM 99.8% 28000.04 0.028 0.013 0.000 0.000 0.000 0.000PM10 99.8%SOxNOxVOCCOPM EmissionsType of Control Device and ID number Temperature After Controls(degrees F)(gr/dscfm)baghouse 220 150 0.035Applicable Can Compliance EmissionEmission Unit PollutantRules bedetermined?Limits(Y or N)Covered Incline/Shuttle Belt PM6-1-2 No 0.03 A stack testwill be required to demonstrate compliancegr/dscfmPM10SOxNOxVOCCOPage 19potentials-limitsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemoreMaximumEmission Potential EmissionsEmission Unit Capacity Pollutant Factor PM PM10 SOx NOx VOC CO(tons/hr) (lb/ton) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)Covered Conveyor System200 PM 0.0159 13.928 6.605 0.000 0.000 0.000 0.000EU34PM10 0.0075SCC 3-05-020-06 SOx 0NOx 0VOC 0CO 0Pollutant Control Air Flow Outlet Grain Emissions After ControlsType of Control Device andID numberEfficiencyRate Loading PM PM10 SOx NOx VOC CO(acfm) (gr/acfm)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)baghouse 245 PM 99.8% 30000.04 0.028 0.013 0.000 0.000 0.000 0.000PM10 99.8%SOxNOxVOCCOPM EmissionsType of Control Device and ID number Temperature After Controls(degrees F)(gr/dscfm)baghouse 245 100 0.038Applicable Can Compliance EmissionEmission Unit PollutantRules bedetermined?Limits(Y or N)Covered Conveyor System PM6-1-2 No 0.03 A stack testwill be required to demonstrate compliancegr/dscfmPM10SOxNOxVOCCOPage 20potentials-limitsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemoreMaximumEmission Potential EmissionsEmission Unit Capacity Pollutant Factor PM PM10 SOx NOx VOC CO(tons/hr) (lb/ton) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)South Reclaim Clinker Covered Conveyor200 PM 0.0159 13.928 6.605 0.000 0.000 0.000 0.000EU124PM10 0.0075SCC 3-05-020-06 SOx 0NOx 0VOC 0CO 0Pollutant Control Air Flow Outlet Grain Emissions After ControlsType of Control Device andID numberEfficiencyRate Loading PM PM10 SOx NOx VOC CO(acfm) (gr/acfm)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)baghouse 223 PM 99.8% 24000.04 0.028 0.013 0.000 0.000 0.000 0.000PM10 99.8%SOxNOxVOCCOPM EmissionsType of Control Device and ID number Temperature After Controls(degrees F)(gr/dscfm)baghouse 223 125 0.036Applicable Can Compliance EmissionEmission Unit PollutantRules bedetermined?Limits(Y or N)South Reclaim Clinker Covered Conveyor PM6-1-2 No 0.03 A stack testwill be required to demonstrate compliancegr/dscfmPM10SOxNOxVOCCOPage 21potentials-limitsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemoreMaximumEmission Potential EmissionsEmission Unit Capacity Pollutant Factor PM PM10 SOx NOx VOC CO(tons/hr) (lb/ton) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)Gypsum Stone Transfer300 PM 0.0159 20.893 9.908 0.000 0.000 0.000 0.000EU35PM10 0.0075SCC 3-05-020-06 SOx 0NOx 0VOC 0CO 0Pollutant Control Air Flow Outlet Grain Emissions After ControlsType of Control Device andID numberEfficiencyRate Loading PM PM10 SOx NOx VOC CO(acfm) (gr/acfm)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)baghouse 131 PM 99.8% 43000.04 0.014 0.006 0.000 0.000 0.000 0.000baghouse 132 PM 99.8%9000 0.04 0.028 0.013total PM13300 0 0 0PM10 99.8%SOxNOxVOCCOPM EmissionsType of Control Device and ID number Temperature After Controls(degrees F)(gr/dscfm)baghouse 131 70 0.040baghouse 132 100 0.038Applicable Can Compliance EmissionEmission Unit PollutantRules bedetermined?Limits(Y or N)Gypsum Stone Transfer PM6-1-2 No 0.03 A stack testwill be required to demonstrate compliancegr/dscfmPM10SOxNOxVOCCOPage 22potentials-limitsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemoreMaximumEmission Potential EmissionsEmission Unit Capacity Pollutant Factor PM PM10 SOx NOx VOC CO(tons/hr) (lb/ton) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)Clinker Transfer Circuit ABC Mills200 PM 0.0159 13.928 6.605 0.000 0.000 0.000 0.000EU36PM10 0.0075SCC 3-05-020-06 SOx 0NOx 0VOC 0CO 0Pollutant Control Air Flow Outlet Grain Emissions After ControlsType of Control Device andID numberEfficiencyRate Loading PM PM10 SOx NOx VOC CO(acfm) (gr/acfm)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)baghouse 251 PM 99.8% 47000.04 0.028 0.013 0.000 0.000 0.000 0.000PM10 99.8%SOxNOxVOCCOPM EmissionsType of Control Device and ID number Temperature After Controls(degrees F)(gr/dscfm)baghouse 251 70 0.040Applicable Can Compliance EmissionEmission Unit PollutantRules bedetermined?Limits(Y or N)Clinker Transfer Circuit ABC Mills PM6-1-2 No 0.03 A stack testwill be required to demonstrate compliancegr/dscfmPM10SOxNOxVOCCOPage 23potentials-limitsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemoreMaximumEmission Potential EmissionsEmission Unit Capacity Pollutant Factor PM PM10 SOx NOx VOC CO(tons/hr) (lb/ton) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)Two (2) Clinker Elevators200 PM 0.0280 12264.000 12264.000 0.000 0.000 0.000 0.000EU37PM10 0.0280SCC 3-05-007-29 SOx 0Finish Mill #1 Facilities NOx 0VOC 0CO 0Pollutant Control Air Flow Outlet Grain Emissions After ControlsType of Control Device andID numberEfficiencyRate Loading PM PM10 SOx NOx VOC CO(acfm) (gr/acfm)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)baghouse 134 PM 99.8%9000 0.04 24.52824.528 0.000 0.000 0.000 0.000PM10 99.8%SOxNOxVOCCOPM EmissionsType of Control Device and ID number Temperature After Controls(degrees F)(gr/dscfm)baghouse 134 150 0.035Applicable Can Compliance EmissionEmission Unit PollutantRules bedetermined?Limits(Y or N)Two (2) Clinker Elevators PM6-1-2 No 0.03 A stack testwill be required to demonstrate compliancegr/dscfmPM10SOxNOxVOCCOPage 24potentials-limitsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemoreMaximumEmission Potential EmissionsEmission Unit Capacity Pollutant Factor PM PM10 SOx NOx VOC CO(tons/hr) (lb/ton) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)2A Hopper / Preliminary Mill24 PM 0.0080 420.480 420.480 0.000 0.000 0.000 0.000EU38PM10 0.0080SCC 3-05-007-29 SOx 0Finish Mill #1 Facilities NOx 0Note: these emission factors are for finish mills VOC 0with fabric filters so emissions before controls are CO 0estimated by using the control efficiency.Pollutant Control Air Flow Outlet Grain Emissions After ControlsType of Control Device andID numberEfficiencyRate Loading PM PM10 SOx NOx VOC CO(acfm) (gr/acfm)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)baghouse 133 PM 99.8% 90000.04 0.841 0.841 0.000 0.000 0.000 0.000PM10 99.8%SOxNOxVOCCOPM EmissionsType of Control Device and ID number Temperature After Controls(degrees F)(gr/dscfm)baghouse 133 150 0.035Applicable Can Compliance EmissionEmission Unit PollutantRules bedetermined?Limits(Y or N)2A Hopper / Preliminary Mill PM6-1-2 No 0.03 A stack testwill be required to demonstrate compliancegr/dscfmPM10SOxNOxVOCCOPage 25potentials-limitsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemoreMaximumEmission Potential EmissionsEmission Unit Capacity Pollutant Factor PM PM10 SOx NOx VOC CO(tons/hr) (lb/ton) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)2A Finish Mill Circuit24 PM 0.0024 126.144 126.144 0.000 0.000 0.000 0.000EU39PM10 0.0024SCC 3-05-007-27 SOx 0NOx 0Note: these emission factors are for finish mills VOC 0with fabric filters so emissions before controls are CO 0estimated by using the control efficiency.Pollutant Control Air Flow Outlet Grain Emissions After ControlsType of Control Device andID numberEfficiencyRate Loading PM PM10 SOx NOx VOC CO(acfm) (gr/acfm)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)baghouse 134 PM 99.8% 90000.04 0.252 0.252 0.000 0.000 0.000 0.000PM10 99.8%SOxNOxVOCCOPM EmissionsType of Control Device and ID number Temperature After Controls(degrees F)(gr/dscfm)baghouse 134 150 0.035Applicable Can Compliance EmissionEmission Unit PollutantRules bedetermined?Limits(Y or N)2A Finish Mill Circuit PM6-1-2 No 0.03 A stack testwill be required to demonstrate compliancegr/dscfmPM10SOxNOxVOCCOPage 26potentials-limitsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemoreMaximumEmission Potential EmissionsEmission Unit Capacity Pollutant Factor PM PM10 SOx NOx VOC CO(tons/hr) (lb/ton) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)2B Finish Mill Circuit25 PM 0.0024 126.144 126.144 0.000 0.000 0.000 0.000EU40PM10 0.0024SCC 3-05-007-27 SOx 0NOx 0Note: these emission factors are for finish mills VOC 0with fabric filters so emissions before controls are CO 0estimated by using the control efficiency.Pollutant Control Air Flow Outlet Grain Emissions After ControlsType of Control Device andID numberEfficiencyRate Loading PM PM10 SOx NOx VOC CO(acfm) (gr/acfm)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)baghouse 135 PM 99.8% 250000.04 0.252 0.252 0.000 0.000 0.000 0.000PM10 99.8%SOxNOxVOCCOPM EmissionsType of Control Device and ID number Temperature After Controls(degrees F)(gr/dscfm)baghouse 135 150 0.035Applicable Can Compliance EmissionEmission Unit PollutantRules bedetermined?Limits(Y or N)2B Finish Mill Circuit PM6-1-2 No 0.03 A stack testwill be required to demonstrate compliancegr/dscfmPM10SOxNOxVOCCOPage 27potentials-limitsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemoreMaximumEmission Potential EmissionsEmission Unit Capacity Pollutant Factor PM PM10 SOx NOx VOC CO(tons/hr) (lb/ton) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)2C Finish Mill Circuit36 PM 0.0024 126.144 126.144 0.000 0.000 0.000 0.000EU42PM10 0.0024SCC 3-05-007-27 SOx 0NOx 0Note: these emission factors are for finish mills VOC 0with fabric filters so emissions before controls are CO 0estimated by using the control efficiency.Pollutant Control Air Flow Outlet Grain Emissions After ControlsType of Control Device andID numberEfficiencyRate Loading PM PM10 SOx NOx VOC CO(acfm) (gr/acfm)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)baghouse 137 PM 99.8% 270000.04 0.252 0.252 0.000 0.000 0.000 0.000PM10 99.8%SOxNOxVOCCOPM EmissionsType of Control Device and ID number Temperature After Controls(degrees F)(gr/dscfm)baghouse 137 150 0.035Applicable Can Compliance EmissionEmission Unit PollutantRules bedetermined?Limits(Y or N)2C Finish Mill Circuit PM6-1-2 No 0.03 A stack testwill be required to demonstrate compliancegr/dscfmPM10SOxNOxVOCCOPage 28potentials-limitsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemoreMaximumEmission Potential EmissionsEmission Unit Capacity Pollutant Factor PM PM10 SOx NOx VOC CO(tons/hr) (lb/ton) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)Separator and Cement Cooler36 PM 0.0280 2207.520 2207.520 0.000 0.000 0.000 0.000EU43PM10 0.0280SCC 3-05-007-29 SOx 0Finish Mill #1 Facilities NOx 0Note: these emission factors are for finish mills VOC 0with fabric filters so emissions before controls are CO 0estimated by using the control efficiency.Pollutant Control Air Flow Outlet Grain Emissions After ControlsType of Control Device andID numberEfficiencyRate Loading PM PM10 SOx NOx VOC CO(acfm) (gr/acfm)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)baghouse 138 PM 99.8% 270000.04 4.415 4.415 0.000 0.000 0.000 0.000PM10 99.8%SOxNOxVOCCOPM EmissionsType of Control Device and ID number Temperature After Controls(degrees F)(gr/dscfm)baghouse 138 150 0.035Applicable Can Compliance EmissionEmission Unit PollutantRules bedetermined?Limits(Y or N)Separator and Cement Cooler PM 6-1-2 No 0.03 A stack test will be required to demonstrate compliancegr/dscfmPM10SOxNOxVOCCOPage 29potentials-limitsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemoreMaximumEmission Potential EmissionsEmission Unit Capacity Pollutant Factor PM PM10 SOx NOx VOC CO(tons/hr) (lb/ton) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)Separator and Cement Cooler25 PM 0.0280 2207.520 2207.520 0.000 0.000 0.000 0.000EU41PM10 0.0280SCC 3-05-007-29 SOx 0Finish Mill #1 Facilities NOx 0Note: these emission factors are for finish mills VOC 0with fabric filters so emissions before controls are CO 0estimated by using the control efficiency.Pollutant Control Air Flow Outlet Grain Emissions After ControlsType of Control Device andID numberEfficiencyRate Loading PM PM10 SOx NOx VOC CO(acfm) (gr/acfm)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)baghouse 136 PM 99.8% 250000.04 4.415 4.415 0.000 0.000 0.000 0.000PM10 99.8%SOxNOxVOCCOPM EmissionsType of Control Device and ID number Temperature After Controls(degrees F)(gr/dscfm)baghouse 136 150 0.035Applicable Can Compliance EmissionEmission Unit PollutantRules bedetermined?Limits(Y or N)Separator and Cement Cooler PM 6-1-2 No 0.03 A stack test will be required to demonstrate compliancegr/dscfmPM10SOxNOxVOCCOPage 30potentials-limitsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemoreMaximumEmission Potential EmissionsEmission Unit Capacity Pollutant Factor PM PM10 SOx NOx VOC CO(tons/hr) (lb/ton) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)Gypsum Elevator45 PM 0.0014 137.970 137.970 0.000 0.000 0.000 0.000EU135PM10 0.0014SCC 3-05-020-06 SOx 0Finish Mill #2 Facilities NOx 0Note: these emission factors are for finish mills VOC 0with fabric filters so emissions before controls are CO 0estimated by using the control efficiency.Pollutant Control Air Flow Outlet Grain Emissions After ControlsType of Control Device andID numberEfficiencyRate Loading PM PM10 SOx NOx VOC CO(acfm) (gr/acfm)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)baghouse 120 PM 99.8% 60000.04 0.276 0.276 0.000 0.000 0.000 0.000PM10 99.8%SOxNOxVOCCOPM EmissionsType of Control Device and ID number Temperature After Controls(degrees F)(gr/dscfm)baghouse 120 70 0.040Applicable Can Compliance EmissionEmission Unit PollutantRules bedetermined?Limits(Y or N)Gypsum Elevator PM6-1-2 No 0.03 A stack testwill be required to demonstrate compliancegr/dscfmPM10SOxNOxVOCCOPage 31potentials-limitsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemoreMaximumEmission Potential EmissionsEmission Unit Capacity Pollutant Factor PM PM10 SOx NOx VOC CO(tons/hr) (lb/ton) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)2D Finish Mill Clinker Bin300 PM 0.0024 1576.800 1576.800 0.000 0.000 0.000 0.000EU44PM10 0.0024SCC 3-05-007-27 SOx 0NOx 0Note: these emission factors are for finish mills VOC 0with fabric filters so emissions before controls are CO 0estimated by using the control efficiency.Pollutant Control Air Flow Outlet Grain Emissions After ControlsType of Control Device andID numberEfficiencyRate Loading PM PM10 SOx NOx VOC CO(acfm) (gr/acfm)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)baghouse 120 PM 99.8% 60000.04 1.261 1.261 0.000 0.000 0.000 0.000baghouse 202 PM 99.8%9000 0.04 1.892 1.892total PM15000 3.154 3.154PM10 99.8%SOxNOxVOCCOPM EmissionsType of Control Device and ID number Temperature After Controls(degrees F)(gr/dscfm)baghouse 120 70 0.040baghouse 202 70 0.040Applicable Can Compliance EmissionEmission Unit PollutantRules bedetermined?Limits(Y or N)2D Finish Mill Clinker Bin PM 6-1-2 No 0.03 A stack testwill be required to demonstrate complianceFinish Mill #2 Facilitiesgr/dscfmPM10SOxNOxVOCCOPage 32potentials-limitsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemoreMaximumEmission Potential EmissionsEmission Unit Capacity Pollutant Factor PM PM10 SOx NOx VOC CO(tons/hr) (lb/ton) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)2D Finish Mill Roll Press Circuit120 PM 0.0360 9460.800 9460.800 0.000 0.000 0.000 0.000EU46PM10 0.0360SCC 3-05-006-28 SOx 0Finish Mill #2 Facilities NOx 0Note: these emission factors are for finish mills VOC 0with fabric filters so emissions before controls are CO 0estimated by using the control efficiency.Pollutant Control Air Flow Outlet Grain Emissions After ControlsType of Control Device andID numberEfficiencyRate Loading PM PM10 SOx NOx VOC CO(acfm) (gr/acfm)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)baghouses 261, 262, and 263 PM 99.8%18300 0.0418.922 18.922 0.000 0.000 0.000 0.000PM10 99.8%SOxNOxVOCCOPM EmissionsType of Control Device and ID number Temperature After Controls(degrees F)(gr/dscfm)baghouses 261, 262, and 263 150 0.035Applicable Can Compliance EmissionEmission Unit PollutantRules bedetermined?Limits(Y or N)2D Finish Mill Roll Press Circuit PM6-1-2 No 0.03 A stack testwill be required to demonstrate compliancegr/dscfmPM10SOxNOxVOCCOPage 33potentials-limitsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemoreMaximumEmission Potential EmissionsEmission Unit Capacity Pollutant Factor PM PM10 SOx NOx VOC CO(tons/hr) (lb/ton) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)Covered Conveyor System200 PM 0.0159 13.928 6.605 0.000 0.000 0.000 0.000EU63PM10 0.0075SCC 3-05-020-06 SOx 0NOx 0VOC 0CO 0Pollutant Control Air Flow Outlet Grain Emissions After ControlsType of Control Device andID numberEfficiencyRate Loading PM PM10 SOx NOx VOC CO(acfm) (gr/acfm)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)baghouse 206 PM 99.8% 36000.04 0.028 0.013 0.000 0.000 0.000 0.000PM10 99.8%SOxNOxVOCCOPM EmissionsType of Control Device and ID number Temperature After Controls(degrees F)(gr/dscfm)baghouse 206 70 0.040Applicable Can Compliance EmissionEmission Unit PollutantRules bedetermined?Limits(Y or N)Covered Conveyor System PM6-1-2 No 0.03 A stack testwill be required to demonstrate compliancegr/dscfmPM10SOxNOxVOCCOPage 34potentials-limitsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemoreMaximumEmission Potential EmissionsEmission Unit Capacity Pollutant Factor PM PM10 SOx NOx VOC CO(holes/yr) (lb/ton) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)Quarry Drilling7740 PM 1.3000 5.031 2.515 0.000 0.000 0.000 0.000EU01PM10 0.6500SOx 0NOx 0VOC 0CO 0Pollutant Control Air Flow Outlet Grain Emissions After ControlsType of Control Device andID numberEfficiencyRate Loading PM PM10 SOx NOx VOC CO(acfm) (gr/acfm)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)baghouse CE01 PM0.0% 5.031 2.515 0.000 0.000 0.000 0.000no known parameters for this baghouse PM10 0.0%SOxNOxVOCCOPM EmissionsType of Control Device and ID number Temperature After Controls(degrees F)(gr/dscfm)baghouse CE01 0.000Applicable Can Compliance EmissionEmission Unit PollutantRules bedetermined?Limits(Y or N)Quarry Drilling PM6-1-2 Impossible 0.03to determine gr/dscfmwithout baghouse parametersPM10SOxNOxVOCCOPage 35potentials-limitsAppendix A: Emission CalculationsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemoreMaximum Emission Potential EmissionsEmission Unit Capacity Pollutant Factor PMPM10 SOx NOxVOC CO(tons/hr) (lb/ton) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)Primary Crusher700 PM 0.5100 1563.660 52.122 0.000 0.000 0.000 0.000EU82PM10 0.0170SCC 3-05-020-01 SOx 0NOx 0VOC 0CO 0Pollutant Control AirFlow Outlet Grain Emissions After ControlsType of Control Device and ID number EfficiencyRate Loading PM PM10SOx NOx VOC CO(acfm) (gr/acfm) (Tons/Year) (Tons/Year)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)none PM 0.0% 1563.660 52.122 0.000 0.000 0.000 0.000PM10 0.0%SOxNOxVOCCObaghousesPage 1Appendix A: Emission CalculationsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemorePollutant Control AirFlow Outlet Grain Emissions After ControlsType of Control Device and ID number EfficiencyRate Loading PM PM10SOx NOx VOC CO(acfm) (gr/acfm) (Tons/Year) (Tons/Year)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)North Stone BinPM 99.8% 6000 0.04 2.057 2.057 0.000 0.000 0.000 0.000EU06 PM10 99.8%baghouse 101 SOxNOxEmissions Before ControlsEmissions are calculated using VOC PMPM10 SOx NOxVOC COcontrol device oulet grain loading CO (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)and flow rate.1028.571 1028.571 0.000 0.000 0.000 0.000PM EmissionsType of Control Device and ID number Temperature After Controls(degrees F) (gr/dscfm)baghouse 101 70 0.040Applicable CanCompliance EmissionEmission Unit Pollutant Rulesbe determined? Limits(Y or N)North Stone Bin PM 6-1-2 No 0.03 A stack test will be required to demonstrate complianceEU06gr/dscfmbaghouse 101PM10SOxNOxVOCCObaghousesPage 2Appendix A: Emission CalculationsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemorePollutant Control AirFlow Outlet Grain Emissions After ControlsType of Control Device and ID number EfficiencyRate Loading PM PM10SOx NOx VOC CO(acfm) (gr/acfm) (Tons/Year) (Tons/Year)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)South Stone Bin EU07baghouse 102 PM 99.8% 6000 0.04 2.057 2.057 0.000 0.000 0.000 0.000Emissions are calculatedusing PM10 99.8%control device oulet grain loading SOxand flow rate. NOxEmissions Before ControlsVOC PM PM10 SOx NOx VOC COCO (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)1028.571 1028.571 0.000 0.000 0.000 0.000PM EmissionsType of Control Device and ID number Temperature After Controls(degrees F) (gr/dscfm)baghouse 102 70 0.040Applicable CanCompliance EmissionEmission Unit Pollutant Rulesbe determined? Limits(Y or N)South Stone Bin EU07 PM 6-1-2 No 0.03 A stack test will be required to demonstrate compliancebaghouse 102gr/dscfmPM10SOxNOxVOCCObaghousesPage 3Appendix A: Emission CalculationsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemorePollutant Control AirFlow Outlet Grain Emissions After ControlsType of Control Device and ID number EfficiencyRate Loading PM PM10SOx NOx VOC CO(acfm) (gr/acfm) (Tons/Year) (Tons/Year)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)Additive BinsPM 99.8% 5000 0.04 1.714 1.714 0.000 0.000 0.000 0.000EU10, EU11, and EU12 PM10 99.8%baghouse 228 SOxNOxEmissions Before ControlsEmissions are calculated using VOC PMPM10 SOx NOxVOC COcontrol device oulet grain loading CO (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)and flow rate.857.143 857.143 0.000 0.000 0.000 0.000PM EmissionsType of Control Device and ID number Temperature After Controls(degrees F) (gr/dscfm)baghouse 228 70 0.040Applicable CanCompliance EmissionEmission Unit Pollutant Rulesbe determined? Limits(Y or N)Additive Bins PM 6-1-2 No 0.03 A stack test will be required to demonstrate complianceEU10, EU11, and EU12gr/dscfmbaghouse 228PM10SOxNOxVOCCObaghousesPage 4Appendix A: Emission CalculationsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemorePollutant Control AirFlow Outlet Grain Emissions After ControlsType of Control Device and ID number EfficiencyRate Loading PM PM10SOx NOx VOC CO(acfm) (gr/acfm) (Tons/Year) (Tons/Year)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)SidewinderPM 99.8% 2330 0.04 0.799 0.799 0.000 0.000 0.000 0.000EU15 PM10 99.8%baghouse 247 SOxNOxEmissions Before ControlsEmissions are calculated using VOC PMPM10 SOx NOxVOC COcontrol device oulet grain loading CO (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)and flow rate.399.429 399.429 0.000 0.000 0.000 0.000PM EmissionsType of Control Device and ID number Temperature After Controls(degrees F) (gr/dscfm)baghouse 247 70 0.040Applicable CanCompliance EmissionEmission Unit Pollutant Rulesbe determined? Limits(Y or N)Sidewinder PM 6-1-2 No 0.03 A stacktest will be required to demonstrate complianceEU15gr/dscfmbaghouse 247PM10SOxNOxVOCCObaghousesPage 5Appendix A: Emission CalculationsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemorePollutant Control AirFlow Outlet Grain Emissions After ControlsType of Control Device and ID number EfficiencyRate Loading PM PM10SOx NOx VOC CO(acfm) (gr/acfm) (Tons/Year) (Tons/Year)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)Blend Silo #1PM 99.8% 9360 0.04 3.209 3.209 0.000 0.000 0.000 0.000EU16 PM10 99.8%baghouse 211 SOxNOxEmissions Before ControlsEmissions are calculated using VOC PMPM10 SOx NOxVOC COcontrol device oulet grain loading CO (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)and flow rate.1604.571 1604.571 0.000 0.000 0.000 0.000PM EmissionsType of Control Device and ID number Temperature After Controls(degrees F) (gr/dscfm)baghouse 211 150 0.035Applicable CanCompliance EmissionEmission Unit Pollutant Rulesbe determined? Limits(Y or N)Blend Silo #1 PM 6-1-2 No 0.03 A stack test will be required to demonstrate complianceEU16gr/dscfmbaghouse 211PM10SOxNOxVOCCObaghousesPage 6Appendix A: Emission CalculationsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemorePollutant Control AirFlow Outlet Grain Emissions After ControlsType of Control Device and ID number EfficiencyRate Loading PM PM10SOx NOx VOC CO(acfm) (gr/acfm) (Tons/Year) (Tons/Year)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)Blend Silo #2PM 99.8% 13500 0.04 4.629 4.629 0.000 0.000 0.000 0.000EU17 PM10 99.8%baghouse 230 SOxNOxEmissions Before ControlsEmissions are calculated using VOC PMPM10 SOx NOxVOC COcontrol device oulet grain loading CO (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)and flow rate.2314.286 2314.286 0.000 0.000 0.000 0.000PM EmissionsType of Control Device and ID number Temperature After Controls(degrees F) (gr/dscfm)baghouse 230 180 0.033Applicable CanCompliance EmissionEmission Unit Pollutant Rulesbe determined? Limits(Y or N)Blend Silo #2 PM 6-1-2 No 0.03 A stack test will be required to demonstrate complianceEU17gr/dscfmbaghouse 230PM10SOxNOxVOCCObaghousesPage 7Appendix A: Emission CalculationsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemorePollutant Control AirFlow Outlet Grain Emissions After ControlsType of Control Device and ID number EfficiencyRate Loading PM PM10SOx NOx VOC CO(acfm) (gr/acfm) (Tons/Year) (Tons/Year)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)Calibration SystemPM 99.8% 6250 0.04 2.143 2.143 0.000 0.000 0.000 0.000EU18 PM10 99.8%baghouse 212 SOxNOxEmissions Before ControlsEmissions are calculated using VOC PMPM10 SOx NOxVOC COcontrol device oulet grain loading CO (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)and flow rate.1071.429 1071.429 0.000 0.000 0.000 0.000PM EmissionsType of Control Device and ID number Temperature After Controls(degrees F) (gr/dscfm)baghouse 212 150 0.035Applicable CanCompliance EmissionEmission Unit Pollutant Rulesbe determined? Limits(Y or N)Calibration System PM 6-1-2 No 0.03 A stack test will be required to demonstrate complianceEU18gr/dscfmbaghouse 212PM10SOxNOxVOCCObaghousesPage 8Appendix A: Emission CalculationsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemorePollutant Control AirFlow Outlet Grain Emissions After ControlsType of Control Device and ID number EfficiencyRate Loading PM PM10SOx NOx VOC CO(acfm) (gr/acfm) (Tons/Year) (Tons/Year)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)Dust Tank systemPM 99.8% 2400 0.04 0.823 0.823 0.000 0.000 0.000 0.000EU21 PM10 99.8%baghouse 210 SOxNOxEmissions Before ControlsEmissions are calculated using VOC PMPM10 SOx NOxVOC COcontrol device oulet grain loading CO (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)and flow rate.411.429 411.429 0.000 0.000 0.000 0.000PM EmissionsType of Control Device and ID number Temperature After Controls(degrees F) (gr/dscfm)baghouse 210 300 0.028Applicable CanCompliance EmissionEmission Unit Pollutant Rulesbe determined? Limits(Y or N)Dust Tank system PM 6-1-2 Yes 0.03EU21gr/dscfmbaghouse 210PM10SOxNOxVOCCObaghousesPage 9Appendix A: Emission CalculationsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemorePollutant Control AirFlow Outlet Grain Emissions After ControlsType of Control Device and ID number EfficiencyRate Loading PM PM10SOx NOx VOC CO(acfm) (gr/acfm) (Tons/Year) (Tons/Year)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)Elevator/Dust Tank Alkali BypassPM 99.8% 4200 0.04 1.440 1.440 0.000 0.000 0.000 0.000EU28 PM10 99.8%baghouse 232 SOxNOxEmissions Before ControlsEmissions are calculated using VOC PMPM10 SOx NOxVOC COcontrol device oulet grain loading CO (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)and flow rate.720.000 720.000 0.000 0.000 0.000 0.000PM EmissionsType of Control Device and ID number Temperature After Controls(degrees F) (gr/dscfm)baghouse 232 340 0.026Applicable CanCompliance EmissionEmission Unit Pollutant Rulesbe determined? Limits(Y or N)Elevator/Dust Tank Alkali Bypass PM 6-1-2 Yes 0.03EU28gr/dscfmbaghouse 232PM10SOxNOxVOCCObaghousesPage 10Appendix A: Emission CalculationsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemorePollutant Control AirFlow Outlet Grain Emissions After ControlsType of Control Device and ID number EfficiencyRate Loading PM PM10SOx NOx VOC CO(acfm) (gr/acfm) (Tons/Year) (Tons/Year)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)CKD Sales Loadout spoutPM 99.8% 2400 0.04 0.823 0.823 0.000 0.000 0.000 0.000EU154 PM10 99.8%baghouse 265 (CE97) SOxNOxEmissions Before ControlsEmissions are calculated using VOC PMPM10 SOx NOxVOC COcontrol device oulet grain loading CO (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)and flow rate.411.429 411.429 0.000 0.000 0.000 0.000PM EmissionsType of Control Device and ID number Temperature After Controls(degrees F) (gr/dscfm)baghouse 265 (CE97) 70 0.040Applicable CanCompliance EmissionEmission Unit Pollutant Rulesbe determined? Limits(Y or N)CKD Sales Loadout spout PM 6-1-2 No 0.03 A stack test will be required to demonstrate complianceEU154gr/dscfmbaghouse 265 (CE97)PM10SOxNOxVOCCObaghousesPage 11Appendix A: Emission CalculationsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemorePollutant Control AirFlow Outlet Grain Emissions After ControlsType of Control Device and ID number EfficiencyRate Loading PM PM10SOx NOx VOC CO(acfm) (gr/acfm) (Tons/Year) (Tons/Year)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)CKD Sales Loadout (kiln #1 dust tank)PM 99.8% 800 0.04 0.274 0.274 0.000 0.000 0.000 0.000EU155 PM10 99.8%baghouse 266 (CE98) SOxNOxEmissions Before ControlsEmissions are calculated using VOC PMPM10 SOx NOxVOC COcontrol device oulet grain loading CO (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)and flow rate.137.143 137.143 0.000 0.000 0.000 0.000PM EmissionsType of Control Device and ID number Temperature After Controls(degrees F) (gr/dscfm)baghouse 266 (CE98) 70 0.040Applicable CanCompliance EmissionEmission Unit Pollutant Rulesbe determined? Limits(Y or N)CKD Sales Loadout (kiln #1 dust tank) PM 6-1-2 No 0.03 A stack test will be required to demonstrate complianceEU155gr/dscfmbaghouse 266 (CE98)PM10SOxNOxVOCCObaghousesPage 12Appendix A: Emission CalculationsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemorePollutant Control AirFlow Outlet Grain Emissions After ControlsType of Control Device and ID number EfficiencyRate Loading PM PM10SOx NOx VOC CO(acfm) (gr/acfm) (Tons/Year) (Tons/Year)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)CKD/Lime TankPM 99.8% 5000 0.04 1.714 1.714 0.000 0.000 0.000 0.000EU146 PM10 99.8%baghouse 143 SOxFinish Mill #1 Facilities NOxEmissions Before ControlsEmissions are calculated using VOC PMPM10 SOx NOxVOC COcontrol device oulet grain loading CO (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)and flow rate.857.143 857.143 0.000 0.000 0.000 0.000PM EmissionsType of Control Device and ID number Temperature After Controls(degrees F) (gr/dscfm)baghouse 143 150 0.035Applicable CanCompliance EmissionEmission Unit Pollutant Rulesbe determined? Limits(Y or N)CKD/Lime Tank PM 6-1-2 No 0.03 A stack test will be required to demonstrate complianceEU146gr/dscfmbaghouse 143PM10SOxNOxVOCCObaghousesPage 13Appendix A: Emission CalculationsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemorePollutant Control AirFlow Outlet Grain Emissions After ControlsType of Control Device and ID number EfficiencyRate Loading PM PM10SOx NOx VOC CO(acfm) (gr/acfm) (Tons/Year) (Tons/Year)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)Kiln #2 coal dust siloPM 99.8% 2700 0.04 0.926 0.926 0.000 0.000 0.000 0.000EU149 PM10 99.8%baghouse 253 SOxNOxEmissions Before ControlsEmissions are calculated using VOC PMPM10 SOx NOxVOC COcontrol device oulet grain loading CO (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)and flow rate.462.857 462.857 0.000 0.000 0.000 0.000PM EmissionsType of Control Device and ID number Temperature After Controls(degrees F) (gr/dscfm)baghouse 253 0.046Applicable CanCompliance EmissionEmission Unit Pollutant Rulesbe determined? Limits(Y or N)Kiln #2 coal dust silo PM 6-1-2 No 0.03 A stack test will be required to demonstrate complianceEU149gr/dscfmbaghouse 253PM10SOxNOxVOCCObaghousesPage 14Appendix A: Emission CalculationsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemorePollutant Control AirFlow Outlet Grain Emissions After ControlsType of Control Device and ID number EfficiencyRate Loading PM PM10SOx NOx VOC CO(acfm) (gr/acfm) (Tons/Year) (Tons/Year)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)Kiln #2 coal weigh systemPM 99.8% 500 0.04 0.171 0.171 0.000 0.000 0.000 0.000EU150 PM10 99.8%baghouse 254 SOxNOxEmissions Before ControlsEmissions are calculated using VOC PMPM10 SOx NOxVOC COcontrol device oulet grain loading CO (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)and flow rate.85.714 85.714 0.000 0.000 0.000 0.000PM EmissionsType of Control Device and ID number Temperature After Controls(degrees F) (gr/dscfm)baghouse 254 0.046Applicable CanCompliance EmissionEmission Unit Pollutant Rulesbe determined? Limits(Y or N)Kiln #2 coal weigh system PM 6-1-2 No 0.03 A stack test will be required to demonstrate complianceEU150gr/dscfmbaghouse 254PM10SOxNOxVOCCObaghousesPage 15Appendix A: Emission CalculationsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemorePollutant Control AirFlow Outlet Grain Emissions After ControlsType of Control Device and ID number EfficiencyRate Loading PM PM10SOx NOx VOC CO(acfm) (gr/acfm) (Tons/Year) (Tons/Year)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)Kiln #2 coal handling systemPM 99.8% 200 0.04 0.069 0.069 0.000 0.000 0.000 0.000EU151 PM10 99.8%baghouse 255 SOxNOxEmissions Before ControlsEmissions are calculated using VOC PMPM10 SOx NOxVOC COcontrol device oulet grain loading CO (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)and flow rate.34.286 34.286 0.000 0.000 0.000 0.000PM EmissionsType of Control Device and ID number Temperature After Controls(degrees F) (gr/dscfm)baghouse 255 0.046Applicable CanCompliance EmissionEmission Unit Pollutant Rulesbe determined? Limits(Y or N)Kiln #2 coal handling system PM 6-1-2 No 0.03 A stack test will be required to demonstrate complianceEU151gr/dscfmbaghouse 255PM10SOxNOxVOCCObaghousesPage 16Appendix A: Emission CalculationsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemorePollutant Control AirFlow Outlet Grain Emissions After ControlsType of Control Device and ID number EfficiencyRate Loading PM PM10SOx NOx VOC CO(acfm) (gr/acfm) (Tons/Year) (Tons/Year)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)Vacuum SystemPM 99.8% 400 0.04 0.137 0.137 0.000 0.000 0.000 0.000EU73 PM10 99.8%baghouse 250 SOxNOxEmissions Before ControlsEmissions are calculated using VOC PMPM10 SOx NOxVOC COcontrol device oulet grain loading CO (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)and flow rate.68.571 68.571 0.000 0.000 0.000 0.000PM EmissionsType of Control Device and ID number Temperature After Controls(degrees F) (gr/dscfm)baghouse 250 70 0.040Applicable CanCompliance EmissionEmission Unit Pollutant Rulesbe determined? Limits(Y or N)Vacuum System PM 6-1-2 No 0.03 A stack test will be required to demonstrate complianceEU73gr/dscfmbaghouse 250PM10SOxNOxVOCCObaghousesPage 17Appendix A: Emission CalculationsCompany Name: ESSROC Cement Corporation, Speed PlantLocation: Speed, IndianaPermit Number: T019-6016-00008Reviewer: Nisha SizemorePollutant Control AirFlow Outlet Grain Emissions After ControlsType of Control Device and ID number EfficiencyRate Loading PM PM10SOx NOx VOC CO(acfm) (gr/acfm) (Tons/Year) (Tons/Year)(Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)Warehouse Conveyor SystemPM 99.8% 1650 0.04 0.566 0.566 0.000 0.000 0.000 0.000EU74 PM10 99.8%baghouse 249 SOxNOxEmissions Before ControlsEmissions are calculated using VOC PMPM10 SOx NOxVOC COcontrol device oulet grain loading CO (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year)and flow rate.282.857 282.857 0.000 0.000 0.000 0.000PM EmissionsType of Control Device and ID number Temperature After Controls(degrees F) (gr/dscfm)baghouse 249 70 0.040Applicable CanCompliance EmissionEmission Unit Pollutant Rulesbe determined? Limits(Y or N)Warehouse Conveyor System PM 6-1-2 No 0.03 A stack test will be required to demonstrate complianceEU74gr/dscfmbaghouse 249PM10SOxNOxVOCCObaghousesPage 18NSR Review Appendix A: Emission Calculations Company Name: ESSROC Cement Corporation, Speed Plant Location: Speed, Indiana Permit Number: T019-6016-00008 Reviewer: Nisha Sizemore

The following facilities were constructed in 1982

Emissions Before Controls Emissions After Controls Limited PM Emissions Limited PM10 Emissions Facility PM PM10 PM PM10 PM PM PM10 PM10 (tons/yr) (tons/yr) (tons/yr) (tons/yr) (tons/yr) (lbs/hr) (tons/yr) (lbs/hr) Quarry Drilling unknown unknown 5.03 2.52 24.9 5.68 N/A N/A Totals 0.00 0.00 5.03 2.52 24.9 5.68 N/A N/A PSD Significance Levels 25 N/A 25 N/A 25 N/A N/A

The following facilities were constructed in 1985

Emissions Before Controls Emissions After Controls Limited PM Emissions Limited PM10 Emissions Facility PM PM10 PM PM10 PM PM PM10 PM10 (tons/yr) (tons/yr) (tons/yr) (tons/yr) (tons/yr) (lbs/hr) (tons/yr) (lbs/hr) Vacuum System 68.57 68.57 0.14 0.14 4.86 1.11 N/A N/A Warehouse Conveyor System 282.86 282.86 0.57 0.57 20.04 4.58 N/A N/A Totals 351.43 351.43 0.70 0.70 24.90 5.68 N/A N/A PSD Significance Levels 25 15 25 15 25 N/A N/A

The following facilities were constructed in 1994

Emissions Before Controls Emissions After Controls Limited PM Emissions Limited PM10 Emissions Facility PM PM10 PM PM10 PM PM PM10 PM10 (tons/yr) (tons/yr) (tons/yr) (tons/yr) (tons/yr) (lbs/hr) (tons/yr) (lbs/hr) elevator for transferring from hopper to additive bi n 857.14 857.14 1.71 1.71 24.9 5.68 14.9 3.40 Totals 857.14 857.14 1.71 1.71 24.9 5.68 14.9 3.40 PSD Significance Levels 25 15 25 15 25 15

The following facilities were constructed in 1996

Emissions Before Controls Emissions After Controls Limited PM Emissions Limited PM10 Emissions Facility PM PM10 PM PM10 PM PM PM10 PM10 (tons/yr) (tons/yr) (tons/yr) (tons/yr) (tons/yr) (lbs/hr) (tons/yr) (lbs/hr) Kiln #2 coal handling system 34.29 34.29 0.069 0.069 1.186 0.27 0.710 0.16 Kiln #2 coal dust silo 462.86 462.86 0.926 0.926 16.007 3.65 9.579 2.19 CKD Sales Loadout (kiln #1 dust tank) 137.14 137.14 0.27 0.27 4.743 1.08 2.838 0.65 Kiln #2 coal weigh system 85.71 85.71 0.171 0.171 2.964 0.68 1.774 0.40 Totals 720.00 720.00 1.44 1.44 24.90 14.90 PSD Significance Levels 25 15 25 15 25 15

The following facilities were constructed in 1998/1999

Emissions Before Controls Emissions After Controls Limited PM Emissions Limited PM10 Emissions Facility PM PM10 PM PM10 PM PM PM10 PM10 (tons/yr) (tons/yr) (tons/yr) (tons/yr) (tons/yr) (lbs/hr) (tons/yr) (lbs/hr) CKD Sales Loadout spout 411 411 0.82 0.82 5.038 1.15 3.015 0.69 2D Finish Mill Roll Press Circuit 9461 9461 18.92 18.92 19.862 4.53 11.885 2.71 Totals 9,872.23 9,872.23 19.74 19.74 24.90 5.68 14.90 3.40 PSD Significance Levels 25 15 25 15 25 15

Note: For the CKD sales loadout spout, and the 2D finish mill roll press circuit, the emission limits necessary are lower than the controlled emissions. However, since the outlet grain loadings of these bagho uses are not known for certain, stack tests will be required to demonstrate compliance with these limits.

NSR Review Page 1ESSROC, Speed PlantSubpart FAffected Facilities include kilns, coolers, raw mill system, finish mill system, raw mill dryer, raw material storage, clinkerstorage,finished product storage, conveyor transfer points, bagging and bulk loading and unloading systems.Date: August 17, 1971Exemptions: any facility preceding raw material storage, just prior to raw mill.1st affected facility is raw material storage, just prior to raw mill; therefore,quarry operations, raw material stockpiles, and raw matieral sizing facilities are not affected facilities.Subpart OOOAffected facilities: crusher, grinding mill, screening operation, bucket elevator, belt conveyor, bagging operation, storage bin,enclosed truck or railcar loading station.If subject to Subpart F, then exempt from Subpart OOO.Date: August 31, 1983Subpart Ycoal prep plants includes coal breaking, crushing, screening, wet or dry cleaning, and thermal drying.coal conveyors, storage facilities (except open piles) and coal transfer and loading systems are applicable.Date: October 24, 1974Exemptions: any coal conveyors used to transport coal to the kilns, if the conveyors are already subject to the NESHAP SubpartLLL are exempt from Subpart Y.Subpart LLLExemptions: any facility preceding raw material storage, just prior to raw mill.1st affected facility is raw material storage, just prior to raw mill; therefore,quarry operations, raw material stockpiles, and raw matieral sizing facilities are not affected facilities.CKD operations are not affected facilities.haul roads and open/unenclosed storage piles are not affected facilities.Page 1ESSROC, Speed PlantAug 31, 1983 Oct 24, 1974 Aug 17, 1971Emission Emission Date of NSPS NSPS NSPS NESHAPUnit Unit Construction Subpart OOO Subpart Y Subpart F Subpart LLLDescription IDQuarry activitiesquarry drilling EU01 1982 pre-dates rule no, not affected facility not affected facilities no, not affected facilityquarry blasting EU75 pre-1945 pre-dates rule not affected facilities not affected facilities no, not affected facilityraw matl loading EU76 1948 pre-dates rule not affected facilities not affected facilities no, not affected facilitystone surge pile EU79 pre-1945 pre-dates rule not affected facilities not affected facilities no, not affected facilityRaw Material Stockpile Operationsraw material unloading to stockpile EU78 1948 pre-dates rule not affected facilities not affected facilities no, not affected facilitystrippings stockpile EU145 pre-1945 pre-dates rule not affected facilities not affected facilities no, not affected facilitytruck unloading to additive hopper EU99 1948 pre-dates rule not affected facilities not affected facilities no, not affected facilitysilica/alumina/iron storage pile EU100 pre-1945 pre-dates rule not affected facilities not affected facilities no, not affected facilityadditive clay blend pile EU101 pre-1945 pre-dates rule not affected facilities not affected facilities no, not affected facilitytruck unloading to clay storage piles EU102 1948 pre-dates rule not affected facilities not affected facilities no, not affected facilityuncovered clay storage pile EU103 pre-1945 pre-dates rule not affected facilities not affected facilities no, not affected facilitycovered clay storage pile EU104 pre-1945 pre-dates rule not affected facilities not affected facilities no, not affected facilityRaw Material Sizing OperationsRaw material unloading to crusher EU80 pre-1956 pre-dates rule not affected facilities not affected facilities no, not affected facilitystone surge pile EU81 pre-1945 pre-dates rule not affected facilities not affected facilities no, not affected facilityprimary crusher EU82 1956 pre-dates rule not affected facilities not affected facilities no, not affected facilitycovered conveyor (transfers stone) EU83 1956 pre-dates rule not affected facilities not affected facilities no, not affected facilityscreens EU84 1956 pre-dates rule not affected facilities not affected facilities no, not affected facilitysecondary crusher EU02 1956 pre-dates rule not affected facilities not affected facilities no, not affected facilitycovered conveyor (transfers stone) EU03 1956 pre-dates rule not affected facilities not affected facilities no, not affected facilitytertiary crushers (2) EU04 1956 pre-dates rule not affected facilities not affected facilities no, not affected facilityconveyor (transfers stone) EU05 1956 pre-dates rule not affected facilities not affected facilities no, not affected facilitycovered conveyor (transfers stone) EU85 1956 pre-dates rule not affected facilities not affected facilities no, not affected facilitytraveling belt (transfers stone) EU86 1956 pre-dates rule not affected facilities not affected facilities no, not affected facilitynorth stone bin EU06 1956 pre-dates rule not affected facilities not affected facilities no, not affected facilitysouth stone bin EU07 1956 pre-dates rule not affected facilities not affected facilities no, not affected facilitystone conveyor transfer to truck EU87 1956 pre-dates rule not affected facilities not affected facilities no, not affected facilitytruck unloading (crushed limestone) EU89 1956 pre-dates rule not affected facilities not affected facilities no, not affected facilitytruck loading (crushed limestone) EU91 1956 pre-dates rule not affected facilities not affected facilities no, not affected facilitytruck unloading EU93 1956 pre-dates rule not affected facilities not affected facilities no, not affected facilitytruck unloading (limestone) EU94 1956 pre-dates rule not affected facilities not affected facilities no, not affected facilitycrushed limestone storage piles EU90 pre-1945 pre-dates rule not affected facilities not affected facilities no, not affected facilityemergency limestone storage piles EU95 pre-1945 pre-dates rule not affected facilities not affected facilities no, not affected facilitytruck dump hopper EU96 1977 pre-dates rule not affected facilities not affected facilities no, not affected facilitylimestone conveyor EU97 1977 pre-dates rule not affected facilities not affected facilities no, not affected facilityPage 2ESSROC, Speed PlantAug 31, 1983 Oct 24, 1974 Aug 17, 1971Emission Emission Date of NSPS NSPS NSPS NESHAPUnit Unit Construction Subpart OOO Subpart Y Subpart F Subpart LLLDescription IDCKD Operationsall facilities not affected facilitiesnot affected facilities not affected facilities no, not affected facilityMiscellaneous Facilitiesvacuum system EU73 1985 notaffected facilities not affected facilitiesyes yeswarehouse conveyor system EU74 1985 not affected facilities not affected facilitiesyes, transfer points only yes, transfer points onlyClay Processing Operationsclay hopper EU105 pre-1945 not affected facilities not affected facilities pre-dates ruleyescovered conveyor system (clay) EU106 pre-1954 not affected facilities not affected facilities pre-dates ruleyesclay crusher EU08 1977 not affected facilities not affected facilities not affected facilitiesyesFinish Operations Crane Storageemergency stone storage pile EU128 pre-1945 not affected facilities not affected facilities pre-dates rule no, not affected facilitytruck unloading station EU127 pre-1945 not affected facilities not affected facilities pre-dates ruleyestruck unloading station EU129 pre-1945 not affected facilities not affected facilities pre-dates ruleyescrane storage building EU131 pre-1945 not affected facilities not affected facilities pre-dates ruleyesgypsum storage piles EU130 pre-1945 not affected facilities not affected facilities pre-dates rule no, not affected facilitygypsum storage piles EU134 pre-1945 not affected facilities not affected facilities pre-dates rule no, not affected facilityRaw Mill Facilitiespneumatic truck unloading stations EU107 July, 1976 not affected facilities not affected facilitiesyes yeshopper EU109 July, 1976 not affected facilities not affected facilitiesyes yesadditive bins equipped with 2 elevators EU10-12 1977 not affected facilities not affected facilitiesyes yesC-15 covered conveyor (clay) EU09 1977 not affected facilities not affected facilitiesyes, transfer points only yes, transfer points onlyLoesche raw mill EU14 1977 not affected facilities not affected facilitiesyes yessidewinder (pneumatic transfer pump) EU15 1977 not affected facilities not affected facilitiesyes yesraw material pile EU112 pre-1945 not affected facilities not affected facilities pre-dates rule no, not affected facilityTodd furnace (for Loesche raw mill) EU13 1977 not affected facilities not affected facilitiesyes yesblend silo #1 EU16 May, 1971 not affected facilities not affected facilities pre-dates ruleyesblend silo #2 EU17 1977 not affected facilities not affected facilitiesyes yescalibration system EU18 May, 1971 not affected facilities not affected facilities pre-dates ruleyesFossil Fuel Storage and Handlingtruck unloading station (coal) EU136 June, 1971 not affected facilities pre-dates rule pre-dates ruleyesreserve coal storage pile EU137 pre-1945 not affected facilities pre-dates rule pre-dates rule no, not affected facilitycoal storage pile EU142 pre-1945 not affected facilities pre-dates rule pre-dates rule no, not affected facilitycoal draw-up covered conveyor EU63 June, 1972 not affected facilities pre-dates ruleyes, transfer points only yes, transfer points onlycoal transfer tower EU64 June, 1972 not affected facilities pre-dates ruleyes, transfer points only yes, transfer points onlycoal bin EU65 June, 1972 not affected facilities pre-dates ruleyes yesPage 3ESSROC, Speed PlantAug 31, 1983 Oct 24, 1974 Aug 17, 1971Emission Emission Date of NSPS NSPS NSPS NESHAPUnit Unit Construction Subpart OOO Subpart Y Subpart F Subpart LLLDescription IDKiln #1 Clinker Handling Facilities#1 clinker drag conveyor (clinker) EU23 May, 1971 not affected facilities not affected facilities pre-dates ruleyesapron conveyor (clinker) EU24 May, 1971 not affected facilities not affected facilities pre-dates ruleyesclinker can #1 (off-spec clinker) EU114 May, 1971 not affected facilities not affected facilities pre-dates ruleyesKiln #2 Clinker Handling Facilities#2 clinker drag conveyor (clinker) EU30 1977 not affected facilities not affected facilitiesyes, transfer points only yes, transfer points onlyaumond conveyor (clinker) EU31 1977 not affected facilities not affected facilitiesyes, transfer points only yes, transfer points onlycross belt (clinker) EU119 May, 1971 not affected facilities not affected facilities pre-dates ruleyesclinker can #2 (off-spec clinker) EU120 1977 not affected facilities not affected facilitiesyes yesClinker Handling to Crane Storagelong belt (clinker) EU25 May, 1971 not affected facilities not affected facilities pre-dates ruleyesnorth clinker transfer tower EU32 1972 not affected facilities not affected facilitiesyes, transfer points only yes, transfer points onlycovered incline belt (clinker) EU33 1972 not affected facilities not affected facilitiesyes, transfer points only yes, transfer points onlyclinker storage pile EU121 pre-1945 not affected facilities not affected facilities pre-dates rule no, not affected facilitynorth clinker storage pile EU122 pre-1945 not affected facilities not affected facilities pre-dates rule no, not affected facilitynorth clinker storage building EU123 1960 not affected facilities not affected facilities pre-dates ruleyescovered conveyor system (clinker) EU34 1962 not affected facilities not affected facilities pre-dates ruleyessouth reclaim clinker covered conveyor EU124 May, 1971 not affected facilities not affected facilities pre-dates ruleyestruck loading station EU125 May, 1971 not affected facilities not affected facilities pre-dates ruleyestruck unloading station EU126 May, 1971 not affected facilities not affected facilities pre-dates ruleyes2ABC Finish Mill FacilitiesCKD/Lime tank EU146 1964 not affected facilities not affected facilities pre-dates ruleyesgypsum/stone transfer circuit EU35 1964 not affected facilities not affected facilities pre-dates ruleyesclinker transfer circuit ABC mills EU36 1964 not affected facilities not affected facilities pre-dates ruleyeselevators EU37 1969 not affected facilities not affected facilities pre-dates ruleyesfinish mill feed belt EU132 1977 not affected facilities not affected facilitiesyes, transfer points only yes, transfer points only2A hopper/preliminary ball mill EU38 1948 not affected facilities not affected facilities pre-dates ruleyesfinish mill circuit 2A EU39 1948 not affected facilities not affected facilities pre-dates ruleyesfinish mill circuit 2B EU40 1953 not affected facilities not affected facilities pre-dates ruleyesfinish mill circuit 2C EU42 1960 not affected facilities not affected facilities pre-dates ruleyesseparator and cement cooler EU43 1960/1964 notaffected facilities not affected facilities pre-dates ruleyesseparator and cement cooler EU41 1953/1955 notaffected facilities not affected facilities pre-dates ruleyesBP tank EU48 1965 not affected facilities not affected facilities pre-dates ruleyespump (from BP tank to silos) EU49 1966 not affected facilities not affected facilities pre-dates ruleyesPage 4ESSROC, Speed PlantAug 31, 1983 Oct 24, 1974 Aug 17, 1971Emission Emission Date of NSPS NSPS NSPS NESHAPUnit Unit Construction Subpart OOO Subpart Y Subpart F Subpart LLLDescription ID2D Finish Mill Facilitiesgypsum elevator EU135 1964 not affected facilities not affected facilities pre-dates ruleyes2D finish mill clinker bin EU44 1964 not affected facilities not affected facilities pre-dates ruleyesfinish mill clinker/gypsum feed circuit EU45 1964 not affected facilities not affected facilities pre-dates ruleyes2D finish mill roll press circuit EU46 1999 not affected facilities not affected facilitiesyes yesfinish mill circuit 2D EU47 1964 not affected facilities not affected facilities pre-dates ruleyesFinish Product Storage, Packing, and Bulk Loading501 silos EU54 1965 not affected facilities not affected facilities pre-dates ruleyesBIC mixer (lime and pigment) EU55 1973 not affected facilities not affected facilitiesyes yesBIC packer (loads cement bags) EU56 1973 not affected facilities not affected facilitiesyes yes506 silos EU53 1958 not affected facilities not affected facilities pre-dates ruleyes2 bulk loading stations EU57-58 1954 not affected facilities not affected facilities pre-dates ruleyespacker #1 EU59 1960 not affected facilities not affected facilities pre-dates ruleyespacker #2 EU60 1960 not affected facilities not affected facilities pre-dates ruleyespacker #3 EU61 1960 not affected facilities not affected facilities pre-dates ruleyesbag compression station EU62 1960 not affected facilities not affected facilities pre-dates ruleyes504 silos EU51 1959 not affected facilities not affected facilities pre-dates ruleyesbulk loading station (trucks and RR) EU52 1959 not affected facilities not affected facilities pre-dates ruleyes502 silos EU50 1966 not affected facilities not affected facilities pre-dates ruleyesCoal Handling, Milling, and Storagecoal crusher mill #1 EU66 May, 1971 not affected facilities pre-dates rule, exhausts to kiln pre-dates ruleyescoal crusher mill #2 EU67 1977 not affected facilitiesyes yes yesfuel oil-fired air heater for kiln #1 EU68 May, 1971 not affected facilities pre-dates rule, exhausts to kiln pre-dates ruleyesfuel oil-fired air heater for kiln #2 EU69 1977 not affected facilitiesyes yes yeskiln #2 coal dust silo EU149 1996 not affected facilitiesyes yes yeskiln #2 coal weigh system EU150 1996 not affected facilitiesyes yes yeskiln #2 coal handling system EU151 1996 not affected facilitiesyes yes yesKiln Facilitiesfeed system for kiln #1 EU19 May, 1971 not affected facilities not affected facilities pre-dates ruleyeskiln #1 EU20 May, 1971 not affected facilities not affected facilities pre-dates ruleyesfeed system for kiln #2 EU26 1977 not affected facilities not affected facilitiesyes yeskiln #2 EU27 1977 not affected facilities not affected facilitiesyes yeskiln #2 alkali bypass EU28 1977 not affected facilities not affected facilitiesyes yesClinker Coolerscooler #1 EU22 May, 1971 not affected facilities not affected facilities pre-dates ruleyescooler #2 EU29 1977 not affected facilities not affected facilitiesyes yesPage 5