INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

 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 IAC 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, 2009
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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 Activities [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 IAC 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 Incentives 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 IAC 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]
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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 IAC 2-7-5(3)] [326 IAC 2-7-6(1)]

C.11 Maintenance of Continuous Opacity Monitoring Equipment[326 IAC 2-7-5(3)(A)(iii)]

C.12 Maintenance of Continuous Emission Monitoring 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 Demonstrated 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 Requirements [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 Requirements
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D.2 FACILITY OPERATION CONDITIONS - Miscellaneous Facilities, Clay Processing

Operations, Finish Operations Crane Storage

Facilities, Fossil Fuel Storage and Handling

Facilities, Clinker Handling Facilities, Clinker

Handling to Crane Storage 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 Facilities, 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 (SO2) [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]
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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 - Insignificant 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 Report 
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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 permits 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. - Aggrock Quarries, #05017 is located at 5501

Highway 403, Sellersburg, IN 47172.

IDEM has determined that ESSROC Cement Corporation and Hanson Aggregates are not under

the common control of ESSROC Cement Corporation; 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 the

quarry 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
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1948, with particulate matter emissions uncontrolled.

Raw material stockpile operations

(4) Raw material (clay overburden) unloading 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 additive 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 emissions
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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.
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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 cubic 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 Crane Storage Facilities

(47) Emergency BP stone storage pile, identified as EU128, created before 1945.
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(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 and 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 baghouse
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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 Crane 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
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(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 loading 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,
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elevator, and air transport system, collectively 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 EU42, 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 as
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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, Packing, 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.
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Finish Product 504-Silos Storage 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 Storage 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 stations 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.
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(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 by

one (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,
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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 Activities [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]
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This stationary source also includes other insignificant 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).
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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 emit, 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 terminates 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, consistent 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 rights 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 permit 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).
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B.9 Annual Compliance Certification [326 IAC 2-7-6(5)]

(a) The Permittee shall annually submit a compliance certification report which addresses

the status of the source’s compliance with the terms and conditions contained in this

permit, including emission limitations, standards, or work practices. The initial

certification shall cover the time period from 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 previous 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 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 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 Sections 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 condition(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;
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(2) A description of the items or conditions 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 require 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 implement 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 the 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 federal or state health-based emission

limitation, except as otherwise 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 technology-based emission limitation if the

affirmative defense of an emergency is demonstrated through properly signed,

contemporaneous operating logs or other relevant 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 four (4) daytime business hours after the
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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 4th 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 official” 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 Permittee 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 deviation 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 Compliance
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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 Permittee 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 identified 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 alone 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 requirements for which a permit shield has

been granted.

This permit shield does not extend to applicable requirements which are promulgated

after the date of issuance of this permit unless 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 determinations 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. The 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 requirements. None of these conditions are

applicable because IDEM, OAQ has determined 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 ensure expeditious compliance with the applicable

requirement until the permit is reissued. The 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 reasonable 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 permit 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 to
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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 Act 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 permits 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 requirements (for emergencies see Section B - Emergency

Provisions), the probable cause of such 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 Avenue, 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 reported 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.
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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 issuance 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 practicable. [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 permit 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 submitted 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 the 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 Avenue, 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 the
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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.

(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 Agency 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 Permittee 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 Avenue, 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 Incentives and Other Programs [326 IAC 2-7-5(8)]

[326 IAC 2-7-12 (b)(2)]

(a) No Part 70 permit revision shall be required 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 similar
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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 prior 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 required 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 notification 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 revision, 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; and 
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(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 official” 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 source 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 notification of IDEM, OAQ, or U.S. EPA is required.

B.20 Source Modification Requirement [326 IAC 2-7-10.5]

A modification, construction, or reconstruction 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 cards, 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 allow IDEM, OAQ, U.S. EPA, or an authorized representative to

perform the following:

(a) Enter upon the Permittee's premises where 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 the
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source shall contain a written agreement containing 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 Avenue, P.O. Box 6015 

Indianapolis, Indiana 46206-6015

The application which shall be submitted by the 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 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.
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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), opacity 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 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 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 easement 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 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,
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(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, 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 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 comply 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 applicable 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 sulfur 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 abatement project covered by those rules.
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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 provided 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 elsewhere 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 certification 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 official" 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 IAC 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 within 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 46206-6015
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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 Monitoring 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 shall meet the performance specifications of

40 CFR 60, Appendix B, Performance Specification 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 Monitoring 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 specification, 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 NOX or SO2 emissions pursuant to 40 CFR

75 (Title IV Acid Rain program) or 326 IAC 10-4 (NOX 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 NOX or SO2 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.
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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 specified in this permit.

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)]

(a) Whenever a condition in this permit requires 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 conditions requiring the measurement of

pressure drop or other parameters. 

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] 

Pursuant to 326 IAC 1-5-2 (Emergency Reduction Plans; Submission):

(a) The Permittee shall prepare written emergency reduction plans (ERPs) 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 Avenue, 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 emissions 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 description 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 in
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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 for 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 time frames specified by the applicable 40

CFR 63 requirement.

(b) For each compliance monitoring condition 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 steps 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 response 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 parameter with respect to normal, and the

results of the actions taken up to the time of notification. 

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

(c) The Permittee is not required to take any further response steps for any of the following
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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 emergency, the provisions of 326 IAC 2-7-16

(Emergency Provisions) requiring prompt corrective 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 Demonstrated 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 facility 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 results. 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).
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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 considered 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 permit, all record keeping requirements not already

legally required shall be implemented within 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 Quarterly 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).
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(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 permit, any notice, report, or other submission

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 considered timely if received 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 “responsible official” as defined by 326 IAC 2-7-1(34).

(e) The first report shall cover the period commencing 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 evaluation required by 40 CFR 63.8(e) is

scheduled to begin.
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(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 Stratospheric 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, service, repair, or disposal must comply

with the required practices pursuant to 40 CFR 82.156.

 (b) Equipment used during the maintenance, service, 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.
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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 additive 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.)
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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, Subpart OOO (Standards of Performance for Nonmetallic 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 with Section B - Preventive Maintenance Plan, of

this permit, is required for the control devices listed in this section. 
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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 condensible 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 Section 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. 
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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 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 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 emissions 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, 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).

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.
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(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).
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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 Crane 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 and 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.)
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Facility Description [326 IAC 2-7-5(15)] continued Note: Complete facility descriptions are in Section

A.2.

Clinker Handling to Crane 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, Packing, 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 constitute enforceable conditions.)
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Facility Description [326 IAC 2-7-5(15)] continued Note: Complete facility descriptions are in

Section A.2.

Finish Product 504-Silos Storage 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 Storage 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 Storage 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 constitute 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 through 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. 
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D.2.5 Prevention of Significant Deterioration (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 with 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

PM
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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,
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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 performed
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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 considered a deviation from this permit. If operations
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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, 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).

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:
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(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 address 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).
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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 not
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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 IAC 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 (SO2) [326 IAC 7-1.1-1] 

(a) Pursuant to 326 IAC 7-1.1 (SO2 Emissions Limitations) the SO2 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. 
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(b) Pursuant to 326 IAC 7-1.1 (SO2 Emissions Limitations) the SO2 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 (SO2 Emissions Limitations) the SO2 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.
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(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, EU17, 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)
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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 following 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 facilities 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 with 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 Condition D.3.8. The Permittee shall conduct

Method 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) by
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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 40

CFR 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 at
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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 the
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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 #1
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(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 exhaust 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 response 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 of
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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.
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(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 (COM) 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 shall be performed once per hour during daylight

operations following the shutdown or malfunction of the primary COM. A trained
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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 emissions 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-four (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 shall 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 periods 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 determined 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 Section 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, "normal" means those conditions prevailing, or
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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 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 deviation 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 a
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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 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 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 emissions 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, 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).

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 SO2 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.
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(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 SO2 limits
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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 Cement
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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 address 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).
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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 Operations) 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 until 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 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-tenths (0.3) pounds per square inch)

measured at thirty-eight degrees Celsius (38OC) (one hundred degrees

Fahrenheit (100OF));

(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-tenths (4.3) kiloPascals (thirty-two (32)

millimeters of mercury or six-tenths (0.6) pounds per square inch) measured at

thirty-eight degrees Celsius (38OC) (one hundred degrees Fahrenheit (100OF)),

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.
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(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-tenths (4.3) kiloPascals (thirty-two (32)

millimeters of mercury or six-tenths (0.6) pounds per square inch) measured at

thirty-eight degrees Celsius (38OC) (one hundred degrees Fahrenheit (100OF)),

or if the solvent is heated to a temperature greater than forty-eight and ninetenths degrees Celsius (48.9OC) (one hundred twenty degrees Fahrenheit

(120OF)):

(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 fifteen (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 Degreasing Operations: material requirements for

cold cleaning degreasers), the following conditions shall apply:

(a) The source shall not operate a cold cleaning degreaser with a solvent vapor pressure

that exceeds one (1) millimeter of mercury (nineteen-thousandths (0.019) pound per

square inch) measured at twenty (20) degrees 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 at
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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 listed 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 chloroform, or any combination of these

halogens, in a total concentration greater 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.
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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. 
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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:
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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 4th 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, ask 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/Equipment/Operation:

Control Equipment:

Permit Condition or Operation Limitation in Permit:

Description of the Emergency:

Describe the cause of the Emergency: 
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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, SO2, VOC, NOX, 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 operation 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.
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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 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 (SO2)

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.
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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 (SO2) 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.
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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 (SO2) 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:

SO2 emissions (lbs/MMBtu) = (Fuel oil usage x EF coefficient x fuel oil sulfur content + coal usage x EF

coefficient x coal sulfur content) / (fuel oil 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.
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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 furnaces (EU13, EU68, and EU69)

Parameter: Sulfur Dioxide (SO2)

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.
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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

9No 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.
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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, the probable cause of the deviation, and the response

steps taken must be reported. Deviations that 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 marked “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:
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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. Finally, the notice informed interested parties that

there was a period of thirty (30) days to provide comments on whether or not this permit should be

issued as proposed. On October 28, 2003, the 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 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

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 quality 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 facilities 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.
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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 result 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 fugitive 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 enforceable 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 easement 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 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.
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(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, 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 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.

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 during 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 trapped 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. 
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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 permits for the source into one single permit document. 

The Title V permit also establishes compliance monitoring 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 the 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 pollution
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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 permit. The contents of the fugitive dust plan are

discussed in detail in IDEM’s response to Comments 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 violation 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 violations 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 discovered 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 between 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 compliance 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 enforcement process is available on IDEM’s website at

http://www.in.gov/idem/enforcement/oe/index.html. 
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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 oxygen 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 suggested 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 based 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 establishes specific items that ESSROC staff must monitor 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 stating 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 responsibility 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 inspected 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 surveillances will be performed if IDEM suspects compliance problems or if

IDEM receives citizen complaints regarding excess emissions.
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Within the past 2 years, unannounced inspections and surveillances 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 Permit
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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 are subject to either twenty percent (20%) or forty

percent (40%) opacity limits. If a unit has a ten percent (10%) opacity limit, then only 10% of the sunlight

is allowed to be blocked by the plume of dust. The 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 applicable 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 monitors for this during inspections and surveillances at

the plant. The permit also includes a fugitive dust control 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 are 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 have 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 rule
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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 units 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 control technology (BACT), which means that they would

have to install the best level of control that is technically and economically feasible to use. If a unit is

subject to the Emission Offset rules in a nonattainment 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 applicability date of the NSR rules and are therefore still

“grandfathered” out of any of the PSD or Emission Offset rules. Any further modifications to these units

which would increase emissions above the significance 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 monitor 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 issuance 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 first 24 hours, these observations can be recorded as

“normal” or “abnormal”. If the monitor is down 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 certification procedure that includes two parts. The first part
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is done at the factory on a representative unit and consists 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 conditioning/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 RATA, 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 check in which their monitor is sent zero and upscale

calibration gases once per day. The monitor must read 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 believes 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. 
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If someone objects to the way the permit is written, 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 circuit 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 circuit 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, exhausting to stack EPN5, and baghouse 31498 exhausting

to stack EPN6. 

Condition A.3(104) and (105). Please make the indicated changes to correct typographical errors.

(104) 504 Silos Bank/Silo 49 (CKD sales), identified as EU153, constructed in 1959, with

emissions controlled by a baghouse, identified as baghouse 264 CE96 and exhausting

to stack EP96 264.
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(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 the 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. For (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 equipment, 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

baghouses, identified as baghouse 218, and exhausting to one (1) stack identified as

EP20 and baghouse 31382, exhausting to one (1) stack identified as EPN1.
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(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 baghouses,

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

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 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 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 Crane 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 baghouses, 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 baghouses, 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,
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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 Storage 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 facilities
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(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 sources or facilities located in Clark County shall comply with the

limitations in Rule 6-1-17 if the source or facility is specifically listed in that section or "the limitations of

section 2 of this rule, if the source or facility is not specifically 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 specifically uses the phrase "source or facility." The Speed

"source" is specifically listed in Rule 6-1-17. Three of its "facilities" are also listed. Because the "source"

is listed, the "source" as a whole cannot be used to trigger § 6-1-2. Only "facilities" 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 actual 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 normal operation of the facility" (326 IAC
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§ 1-2-55). In its "Background Information for 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, storage 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 secondary." 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 rule; 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 source 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 considered integral to the process. IDEM’s criteria for determining

whether such baghouses should be considered integral includes an evaluation of the annualized cost of

purchasing, installing and operating the baghouse as compared 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 determination 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 the 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 instance, periodic visible emission observations would

constitute periodic monitoring and would be federally enforceable. However, if periodic VE readings are

required, additional requirements, such as parametric monitoring, baghouse inspections, etc. would not
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be mandated by the CAA or Rule 2-7, and would 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 monitoring. 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 observation that visible emissions are “normal” would not

necessarily indicate compliance with the particulate limit, 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 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 the

baghouse. Any deviations from the normal operational range of the unit, whether gradual or sudden,

should alert the operator that the unit needs maintenance. The Compliance Response Plan should

include response 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. 

Therefore, the OAQ believes that pressure drop readings should be taken at least once per shift, in

addition to the visible emission observations. The requirements 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 Permittee 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 visible emission observations are taken on a daily basis, this

should be sufficient. Pressure drop readings, inspections, 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 relevant. 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 show
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that a properly functioning baghouse should result in no excess visible emission as long as it operates

within an established pressure drop range." In contrast to this reasoned approach, ESSROC’s permit

requires VE readings as often as once per shift in addition to daily (or per shift) pressure drop readings,

periodic baghouse inspections, and similar requirements for the ESPs on the kilns. These redundant

requirements are merely cumulative and are not necessary.

Response #4

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 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 monitoring. 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 opacity 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 reasonable 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 indication 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 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 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 the baghouse. Any deviations from the normal operational

range of the unit, whether gradual or sudden, should alert the operator that the unit needs maintenance. 

The Compliance Response Plan should include response 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. Therefore, 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. 
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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 phrase “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 enforcement 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 renumbered 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 provisions 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 provision specifically

designated as not federally enforceable, constitutes 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 activity in order to maintain compliance

with the conditions of this permit.

(d) An emergency does constitute an affirmative defense in an enforcement action provided
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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.11B.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)
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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 for 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 condition 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 steps 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 such additional response steps shall not be

considered a deviation from this permit 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 enforcement for non-compliance with a permit term.

Response #8

The title of the condition has been corrected to remove the 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 sources required to pay fees under any provision of 326

IAC 2. Therefore, 326 IAC 2-1.1-7(7) is applicable, which specifies that nonpayment may result

revocation of the permit. 

B.24B.23 Annual Fee Payment [326 IAC 2-7-19] [326 IAC 2-7-5(7)] [326 IAC 2-1.1-7] [326 IAC 2-
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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 "used." 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 listed in this permit is necessary to comply with the

emission limits listed in this permit. If the Permittee 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 justification showing that the specific 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 control devices are necessary for compliance. The

Permittee may also choose to conduct stack testing, 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 - Maintenance of Continuous Emission Monitoring Equipment)

Section C.12(d)(2) (Maintenance of Continuous Emission Monitoring Equipment). 

This section should be deleted. There is no economically or technically practicable way to perform

supplemental or intermittent monitoring of the NOx emissions; 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.
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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 perform 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 - Pressure 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 IAC § 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 the 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 specific monitoring requirements to measure compliance with applicable

requirements. There should be a condition in the permit which ties the monitoring requirements to the

annual compliance certification. We suggest a new paragraph C.17(g) to read:

Compliance with the specific monitoring 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 could conclude that an otherwise 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 phrase “, 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 and
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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 evidence to evaluate compliance or noncompliance with

any applicable requirements. 

IDEM does not agree that the phrase “as necessary” 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 responsive 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 because 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 violation. 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 abnormal 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 monitoring 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; however 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 the
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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 period 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, for 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 considered timely if received by IDEM, OAQ,

on or before the date it is due.

Comment #14 (Condition C.22 - NESHAP Notification and Reporting 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 the
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Permittee has already submitted one or more of the notifications, the requirement is still an applicable

requirement. Paragraph (a) has been changed consistent with the other requirements to submit

notifications. The typographical error has also been corrected. 

The reports listed in this condition must be submitted 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 requirement 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. There are a number of specific 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 operator 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 included 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 Hazardous Air Pollutants (NESHAPs) are typically very

detailed, complex rules. Each NESHAP may cover different types of emissions units as well as groups
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of emissions units. Furthermore, each NESHAP may have several options available for each emissions

unit from which an owner or operator 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 use 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 determine if the owner or operator is complying

with the NESHAP requirements. The public has the legal 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 operator 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 issuance, provided that the applicable requirements are

included and specifically identified in the permit. Therefore, in order to satisfy the requirements of the

Part 70 rules and the needs of all of the permit stakeholders, 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, and D.3.2 - Prevention of Significant Deterioration)

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 significance 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 maximum 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 Significant Deterioration)

Section D.1.1(c). 

There is no practical means by which to measure emissions from the 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 operation 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 applicability
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determination. The unlimited PTE of the drilling process exceeds 25 tons per year of PM. Therefore,

an enforceable limit must be established to render the 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 drilled 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. There 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 days 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 Monitoring 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 covered, ESSROC proposes monthly readings. Also, the

permit should state that failure to take response steps 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 these in the CRP; it will not accept these as permit

conditions. If parametric monitoring is to be selected 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 revisions to, or deletions of, sections D.1.6 - D.1.10,
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D.2.10 - D.2.13, and D.3.18 - D.3.21.

Response #19

IDEM includes the normal pressure drop ranges in the permit to ensure that the 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 ranges 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 deviations. 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 monitoring. 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 opacity 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 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 indication 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 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 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 the baghouse. Any deviations from the normal operational

range of the unit, whether gradual or sudden, should alert the operator that the unit needs maintenance. 

The Compliance Response Plan should include response 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. Therefore, 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 take
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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 Section 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 should 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 with 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 with 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 Maintenance 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.
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Comment #22 (Condition D.2.7 - Testing Requirements)

ESSROC has already completed the testing required 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 issue 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 loading 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 calculations 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 plant, 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 because 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 conditions 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 Emission Limitations)
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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 because 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 operate 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, the
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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 exhaust 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 response 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; there 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 language of 326 IAC 3-6-3, which requires that the

facility be operating at 95% to 100% of permitted operating 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 capacity 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.”
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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 SO2 emission compliance.

Response #27

Pursuant to 326 IAC 3-7-4(b), an owner or operator may rely upon sampling and analysis procedures

performed by the vendor prior to delivery. 326 IAC 3-7-2 and 326 IAC 3-7-3 do not allow the owner or

operator to rely upon sampling and analysis procedures 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 emission 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 following 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 facilities shall be less than 20 percent. 
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(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 Condition D.3.8. The Permittee shall conduct

Method 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 would 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. ESSROC 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 composition 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) indicates more than 20 kW consumption. The bit

will be monitored by our data acquisition system OSI-PI. The data acquisition system keeps a
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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 position 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 minimize or focus issues on appeal where the parties

cannot agree on final language. In this light, Essroc 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 limits 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 12th, 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 (CEMS); therefore the permit must include a compliance

schedule. 

IDEM does not agree with the Permittee’s compliance 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 which 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)
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The permit should state that failure to take response 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 purpose of the condition is to prevent deviations from

permitted emission limits; therefore failure to take 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 addition, it effectively imposes substantive requirements on

ESSROC when the kiln is operating at 10% below allowable and when the clinker cooler is operating at

20% below allowable. This has the effect of making the capacity limit more stringent and is therefore

illegal.

Response #31

Since the opacity limits on the kilns and clinker coolers are already very stringent, IDEM agrees that

opacity trigger levels are unnecessary for these units. 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. 
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(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 (COM) 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 shall be performed once per hour during daylight

operations following the shutdown or malfunction 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 emissions 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-four (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 shall 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 periods 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 determined 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 Section 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.
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(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 reasonably 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 capricious 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, ESSROC 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 information 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 additional 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 occurrence at this plant. Therefore, 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 and Visible Emissions Notations)

In Paragraph (b) delete subparagraph (2); there is no reference 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. The 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 Keeping 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).
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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 basis" 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 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). 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
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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

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.

Revision #2

A requirement to keep records of any additional inspections 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 revised to include additional language from 40 CFR

63.10(d)(5)(ii) as shown below.

D.2.16 Reporting Requirements

(a) 
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(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 Fed. 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 Environmental 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:
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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
Page 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 the

quarry 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) unloading 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 additive 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.
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(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.
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(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 emissions
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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 cubic 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 Crane 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 and Handling Facilities

(52) one (1) truck unloading station to the reserve coal storage pile, identified as

EU136, constructed in June 1971, with emissions uncontrolled.
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(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.
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(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 Crane 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 loading 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
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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, collectively 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 EU42, 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, with
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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.
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Finish Product 506-Silos Storage, Packing, 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 Storage 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 Storage 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.
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Raw Mill Facilities

(107) Two (2) pneumatic truck unloading stations 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 by

one (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
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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 a
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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 insignificant 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, dispensing 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:
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(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;
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(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 amended
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CP019-9349;

All terms and conditions of previous permits issued pursuant to permitting programs approved into

the state implementation plan have been either incorporated 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 previous 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-construction 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.
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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 Emit 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 treated 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

SO2 greater than 250

VOC greater than 250

CO greater than 250

NOx 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 10
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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 PM10, CO, NOX, VOC, and SO2

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 twenty-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

SO2 2410

VOC 54

CO 2083

NOx 1629
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lead 0.21

HAPs not reported

County Attainment Status

The source is located in Clark County.

Pollutant Status

PM-10 Attainment

SO2 Attainment

Ozone Attainment

CO Attainment

Lead Attainment

(a) Volatile organic compounds (VOC) are precursors for the formation of ozone. 

Therefore, VOC emissions are considered when 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 twenty-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 continuous 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. 
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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 unloading 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, EU11, 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:
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(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 grinding
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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 (Performance Standards for Nonmetallic 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 constructed prior the applicability

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 subject 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 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 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 Performance 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 establishes particulate emission limitations for the

coal processing (coal mills) and conveying equipment, coal storage systems, and coal transfer

and loading systems that have commenced construction or modification after October 24, 1974. 
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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 facilities 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 coal (crusher) mill #1 (EU66) and the fuel oil-fired

air heater for kiln #1 (EU68) would not be subject 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 these facilities are already subject to the

provisions of 40 CFR 63 Subpart LLL. On April 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 are not major sources of HAP are not subject to the NSPS for coal

preparation plants (40 CFR 60, Subpart Y) because 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 NSPS for coal preparation plants (40 CFR 60
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Subpart Y). EPA also stated that other coal conveying 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 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 affected 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 operations. The rule specifically states that

for portland cement plants with on-site nonmetallic mineral processing facilities, the first

affected source in the sequence of materials 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 raw material storage are not subject to this

rule. Furthermore, the rule states that the first 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 cement 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 stockpiles 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. 

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:
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(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 the
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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.
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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

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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 Standards

and 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

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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 Cement
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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 the
ESSROC Cement Corporation Page 30 of 44

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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 Applicability - Entire Source

326 IAC 2-2 (Prevention of Significant Deterioration) 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. The submittal should cover the period defined in 326
ESSROC Cement Corporation Page 31 of 44

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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), opacity 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.

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 Applicability - 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

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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 emissions 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. 
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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 Facilities
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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 yes
ESSROC Cement Corporation Page 36 of 44

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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 SO2. The SO2 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 SO2. 

The SO2 emissions from each of the furnaces shall not exceed 0.5 pound per million Btu
ESSROC 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 applicable 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 emission 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 Applicability - 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 requirements of these rules. Pursuant to 326 IAC 8-3-2

(Cold Cleaner Operations), 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 until 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-tenths (0.3) pounds per square inch)

measured at thirty-eight degrees Celsius (38OC) (one hundred degrees

Fahrenheit (100OF));

(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-tenths (4.3) kiloPascals (thirty-two (32)

millimeters of mercury or six-tenths (0.6) pounds per square inch) measured at

thirty-eight degrees Celsius (38OC) (one hundred degrees Fahrenheit (100OF)),

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-tenths (4.3) kiloPascals (thirty-two (32)

millimeters of mercury or six-tenths (0.6) pounds per square inch) measured at

thirty-eight degrees Celsius (38OC) (one hundred degrees Fahrenheit (100OF)),

or if the solvent is heated to a temperature greater than forty-eight and ninetenths degrees Celsius (48.9OC) (one hundred twenty degrees Fahrenheit

(120OF)):

(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 fifteen (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 requirements 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 Degreasing Operations: material requirements for

cold cleaning degreasers), the following conditions shall apply:

(a) The source shall not operate a cold cleaning degreaser with a solvent vapor pressure

that exceeds one (1) millimeter of mercury (nineteen-thousandths (0.019) pound per

square inch) measured at twenty (20) degrees 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 into 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 corrective actions and not grounds for enforcement action. 

However, a violation in relation to a compliance 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 calender quarter of all bags. Inspections

required by this condition shall not be performed 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). 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 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 rates, 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 performance 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 measuring opacity from each of the clinker

coolers. The continuous monitoring systems shall meet the performance specifications
ESSROC 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 shall 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 Significant Deterioration), 326 IAC 5-1 (Opacity

Limitations), 40 CFR 60, Subpart Y (Coal Preparation 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 Calculations

Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Maximum Emission Potential Emissions

Emission 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 Crusher 1050 PM 0.015 68.985 68.985 0.000 0.000 0.000 0.000EU02 PM10 0.015SCC 3-05-020-02 SOx 0

NOx 0

VOC 0

CO 0

Pollutant Control Air Flow Outlet Grain Emissions After Controls

Type of Control Device and ID number Efficiency Rate 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% 6700 0.04 0.138 0.138 0.000 0.000 0.000 0.000

PM10 99.8%

SOx

NOx

VOC

CO

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 200 70 0.04

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

Secondary Crusher PM 6-1-2 No 0.03 A stack test will be required to demonstrate compliance

gr/dscfm

PM10

SOx

NOx

VOC

CO

Page 1 
Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Maximum Emission Potential Emissions

Emission 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 1050 PM 0.0159 73.124 34.676 0.000 0.000 0.000 0.000EU03 PM10 0.0075SCC 3-05-020-06 SOx 0

NOx 0

VOC 0

CO 0

Pollutant Control Air Flow Outlet Grain Emissions After Controls

Type of Control Device and ID number Efficiency Rate 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% 30000 0.04 0.146 0.069 0.000 0.000 0.000 0.000

PM10 99.8%

SOx

NOx

VOC

CO

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 201 70 0.04

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

Covered Conveyor PM 6-1-2 No 0.03 A stack test will be required to demonstrate compliance

gr/dscfm

PM10

SOx

NOx

VOC

CO

Page 2 
Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Maximum Emission Potential Emissions

Emission 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 Crusher 350 PM 0.015 22.995 22.995 0.000 0.000 0.000 0.000EU04 PM10 0.015SCC 3-05-020-03 SOx 0

NOx 0

VOC 0

CO 0

Pollutant Control Air Flow Outlet Grain Emissions After Controls

Type of Control Device and ID number Efficiency Rate 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% 30000 0.04 0.046 0.046 0.000 0.000 0.000 0.000

PM10 99.8%

SOx

NOx

VOC

CO

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 201 70 0.04

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

Tertiary Crusher PM 6-1-2 No 0.03 A stack test will be required to demonstrate compliance

gr/dscfm

PM10

SOx

NOx

VOC

CO

Page 3 
Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Maximum Emission Potential Emissions

Emission 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 Ladder 1050 PM 0.0014 6.439 6.439 0.000 0.000 0.000 0.000EU05 PM10 0.0014SCC 3-05-020-06 SOx 0

NOx 0

VOC 0

CO 0

Pollutant Control Air Flow Outlet Grain Emissions After Controls

Type of Control Device and ID number Efficiency Rate 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% 30000 0.04 0.013 0.013 0.000 0.000 0.000 0.000

PM10 99.8%

SOx

NOx

VOC

CO

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 201 70 0.04

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

Stone Ladder PM 6-1-2 No 0.03 A stack test will be required to demonstrate compliance

gr/dscfm

PM10

SOx

NOx

VOC

CO

Page 4 
Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Maximum Emission Potential Emissions

Emission 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 0.000EU08 PM10 0.0007SCC 3-05-020-01 SOx 0

NOx 0

VOC 0

CO 0

Pollutant Control Air Flow Outlet Grain Emissions After Controls

Type of Control Device and ID number Efficiency Rate 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% 15000 0.04 0.000 0.000 0.000 0.000 0.000 0.000

PM10 99.8%

SOx

NOx

VOC

CO

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 227 70 0.04

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

Clay Breaker (Crusher) PM 6-1-2 No 0.03 A stack test will be required to demonstrate compliance

gr/dscfm

PM10

SOx

NOx

VOC

CO

Page 5 
Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Maximum Emission Potential Emissions

Emission 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 System 1050 PM 0.0159 73.124 34.676 0.000 0.000 0.000 0.000EU09 PM10 0.0075SCC 3-05-020-06 SOx 0

NOx 0

VOC 0

CO 0

Pollutant Control Air Flow Outlet Grain Emissions After Controls

Type of Control Device and ID number Efficiency Rate 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% 15000 0.04 0.095 0.045 0.000 0.000 0.000 0.000baghouse 229 PM 99.8% 8000 0.04 0.051 0.051

total PM 23000 0.146 0.096

PM10 99.8%

SOx

NOx

VOC

CO

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 227 70 0.04baghouse 229 70 0.04

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

Covered Conveyor System PM 6-1-2 No 0.03 A stack test will be required to demonstrate compliance

gr/dscfm

PM10

SOx

NOx

VOC

CO

Page 6 
Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Maximum Emission Potential Emissions

Emission 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 Mill 300 PM 0.0120 7884.000 7884.000 0.000 0.000 0.000 0.000EU14 PM10 0.0120SCC 3-05-020-01 SOx 0

NOx 0

Note: 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 Controls

Type of Control Device and ID number Efficiency Rate 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% 240000 0.03 15.768 15.768 0.000 0.000 0.000 0.000

PM10 99.8%

SOx

NOx

VOC

CO

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

ESP15 200 0.02

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

Loesche Raw Mill PM 6-1-2 Yes 0.03 

gr/dscfm

PM10

SOx

NOx

VOC

CO

Page 7 
Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Maximum Emission Potential Emissions

Emission 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 system 100 PM - 1294.286 1294.286EU19 PM10 -

SOx -

NOx -

VOC -

CO -

Pollutant Control Air Flow Outlet Grain Emissions After Controls

Type of Control Device and ID number Efficiency Rate 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 PM 99.8% 6250 0.04

PM10 99.8%

SOx

NOx

VOC

CO

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 209 150 0.017baghouse 212 150 0.035

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

Kiln #1 feed system PM 6-1-2 No 0.03 A stack test will be required to demonstrate compliance

gr/dscfm

PM10

SOx

NOx

VOC

CO

Page 8 
Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Maximum Emission Potential Emissions

Emission 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 #1 54.5 PM 0.147 17545 17545 0.000 0.000 0.000 0.000

EU22 PM10 0.147SCC 3-05-006-14 SOx 0

NOx 0

Note: 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 Controls

Type of Control Device and ID number Efficiency Rate 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% 165500 0.02 35.090 35.090 0.000 0.000 0.000 0.000

PM10 99.8%

SOx

NOx

VOC

CO

Page 9 
Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Maximum Emission Potential Emissions

Emission 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 Conveyor 75 PM 0.0159 5.223 2.477 0.000 0.000 0.000 0.000EU21 PM10 0.0075SCC 3-05-020-06 SOx 0

NOx 0

VOC 0

CO 0

Pollutant Control Air Flow Outlet Grain Emissions After Controls

Type of Control Device and ID number Efficiency Rate 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% 5000 0.04 0.010 0.005 0.000 0.000 0.000 0.000

PM10 99.8%

SOx

NOx

VOC

CO

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 217 250 0.030

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

Clinker Drag Conveyor PM 6-1-2 Yes 0.03 

gr/dscfm

PM10

SOx

NOx

VOC

CO

Page 10 
Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Maximum Emission Potential Emissions

Emission 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 #1 75 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 Controls

Type of Control Device and ID number Efficiency Rate 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% 4800 0.04 1.646 1.646 0.000 0.000 0.000 0.000

PM10 99.8%

SOx

NOx

VOC

CO

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 218 250 0.030

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

Apron Conveyor and Clinker Can #1 PM 6-1-2 Yes 0.03 

gr/dscfm

PM10

SOx

NOx

VOC

CO

Page 11 
Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Maximum Emission Potential Emissions

Emission 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 Belt 200 PM 0.0159 13.928 6.605 0.000 0.000 0.000 0.000EU25 PM10 0.0075SCC 3-05-020-06 SOx 0Crane Storage Facilities NOx 0

VOC 0

CO 0

Pollutant Control Air Flow Outlet Grain Emissions After Controls

Type of Control Device and ID number Efficiency Rate 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% 2400 0.04 0.028 0.013 0.000 0.000 0.000 0.000

PM10 99.8%

SOx

NOx

VOC

CO

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 219 150 0.035

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

Long Belt PM 6-1-2 No 0.03 A stack test will be required to demonstrate compliance

gr/dscfm

PM10

SOx

NOx

VOC

CO

Page 12 
Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Maximum Emission Potential Emissions

Emission 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 system 150 PM - 514.286 514.286EU26 PM10 -

SOx -

NOx -

VOC -

CO -

Pollutant Control Air Flow Outlet Grain Emissions After Controls

Type of Control Device and ID number Efficiency Rate 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 1.029

PM10 99.8%

SOx

NOx

VOC

CO

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 231 180 0.033

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

Kiln #2 feed system PM 6-1-2 No 0.03 A stack test will be required to demonstrate compliance

gr/dscfm

PM10

SOx

NOx

VOC

CO

Page 13 
Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Maximum Emission Potential Emissions

Emission 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 #2 96.0 PM 0.147 30905 30905 0.000 0.000 0.000 0.000

EU29 PM10 0.147SCC 3-05-006-14 SOx 0

NOx 0

Note: 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 Controls

Type of Control Device and ID number Efficiency Rate 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% 165500 0.02 61.811 61.811 0.000 0.000 0.000 0.000

PM10 99.8%

SOx

NOx

VOC

CO

Page 14 
Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Maximum Emission Potential Emissions

Emission 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 Conveyor 100 PM 0.0159 6.964 3.303 0.000 0.000 0.000 0.000EU30 PM10 0.0075SCC 3-05-020-06 SOx 0Kiln #2 Clinker Handling Facilities NOx 0

VOC 0

CO 0

Pollutant Control Air Flow Outlet Grain Emissions After Controls

Type of Control Device and ID number Efficiency Rate 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% 4900 0.04 0.014 0.007 0.000 0.000 0.000 0.000

PM10 99.8%

SOx

NOx

VOC

CO

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 233 340 0.026

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

Clinker Drag Conveyor PM 6-1-2 Yes 0.03 

gr/dscfm

PM10

SOx

NOx

VOC

CO

Page 15 
Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Maximum Emission Potential Emissions

Emission 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 #2 100 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 Controls

Type of Control Device and ID number Efficiency Rate 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% 7100 0.04 2.434 2.434 0.000 0.000 0.000 0.000

PM10 99.8%

SOx

NOx

VOC

CO

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 234 340 0.026

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

Apron Conveyor and Clinker Can #2 PM 6-1-2 Yes 0.03 

gr/dscfm

PM10

SOx

NOx

VOC

CO

Page 16 
Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Maximum Emission Potential Emissions

Emission 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 Belt 100 PM 0.0159 6.964 3.303 0.000 0.000 0.000 0.000EU119 PM10 0.0075SCC 3-05-020-06 SOx 0Kiln #2 Clinker Handling Facilities NOx 0

VOC 0

CO 0

Pollutant Control Air Flow Outlet Grain Emissions After Controls

Type of Control Device and ID number Efficiency Rate 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% 2200 0.04 0.014 0.007 0.000 0.000 0.000 0.000

PM10 99.8%

SOx

NOx

VOC

CO

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 235 340 0.026

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

Cross Belt PM 6-1-2 Yes 0.03 

gr/dscfm

PM10

SOx

NOx

VOC

CO

Page 17 
Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Maximum Emission Potential Emissions

Emission 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 Tower 200 PM 0.0159 13.928 6.605 0.000 0.000 0.000 0.000EU32 PM10 0.0075SCC 3-05-020-06 SOx 0Clinker Handling to Crane Storage Facilities NOx 0

VOC 0

CO 0

Pollutant Control Air Flow Outlet Grain Emissions After Controls

Type of Control Device and ID number Efficiency Rate 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% 2400 0.04 0.028 0.013 0.000 0.000 0.000 0.000

PM10 99.8%

SOx

NOx

VOC

CO

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 219 150 0.035

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

North Clinker Transfer Tower PM 6-1-2 No 0.03 A stack test will be required to demonstrate compliance

gr/dscfm

PM10

SOx

NOx

VOC

CO

Page 18 
Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Maximum Emission Potential Emissions

Emission 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 Belt 200 PM 0.0159 13.928 6.605 0.000 0.000 0.000 0.000EU33 PM10 0.0075SCC 3-05-020-06 SOx 0

NOx 0

VOC 0

CO 0

Pollutant Control Air Flow Outlet Grain Emissions After Controls

Type of Control Device and ID number Efficiency Rate 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% 2800 0.04 0.028 0.013 0.000 0.000 0.000 0.000

PM10 99.8%

SOx

NOx

VOC

CO

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 220 150 0.035

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

Covered Incline/Shuttle Belt PM 6-1-2 No 0.03 A stack test will be required to demonstrate compliance

gr/dscfm

PM10

SOx

NOx

VOC

CO

Page 19 
Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Maximum Emission Potential Emissions

Emission 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 System 200 PM 0.0159 13.928 6.605 0.000 0.000 0.000 0.000EU34 PM10 0.0075SCC 3-05-020-06 SOx 0

NOx 0

VOC 0

CO 0

Pollutant Control Air Flow Outlet Grain Emissions After Controls

Type of Control Device and ID number Efficiency Rate 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% 3000 0.04 0.028 0.013 0.000 0.000 0.000 0.000

PM10 99.8%

SOx

NOx

VOC

CO

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 245 100 0.038

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

Covered Conveyor System PM 6-1-2 No 0.03 A stack test will be required to demonstrate compliance

gr/dscfm

PM10

SOx

NOx

VOC

CO

Page 20 
Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Maximum Emission Potential Emissions

Emission 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 Conveyor 200 PM 0.0159 13.928 6.605 0.000 0.000 0.000 0.000EU124 PM10 0.0075SCC 3-05-020-06 SOx 0

NOx 0

VOC 0

CO 0

Pollutant Control Air Flow Outlet Grain Emissions After Controls

Type of Control Device and ID number Efficiency Rate 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% 2400 0.04 0.028 0.013 0.000 0.000 0.000 0.000

PM10 99.8%

SOx

NOx

VOC

CO

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 223 125 0.036

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

South Reclaim Clinker Covered Conveyor PM 6-1-2 No 0.03 A stack test will be required to demonstrate compliance

gr/dscfm

PM10

SOx

NOx

VOC

CO

Page 21 
Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Maximum Emission Potential Emissions

Emission 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 Transfer 300 PM 0.0159 20.893 9.908 0.000 0.000 0.000 0.000EU35 PM10 0.0075SCC 3-05-020-06 SOx 0

NOx 0

VOC 0

CO 0

Pollutant Control Air Flow Outlet Grain Emissions After Controls

Type of Control Device and ID number Efficiency Rate 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% 4300 0.04 0.014 0.006 0.000 0.000 0.000 0.000baghouse 132 PM 99.8% 9000 0.04 0.028 0.013

total PM 13300 0 0 0

PM10 99.8%

SOx

NOx

VOC

CO

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 131 70 0.040baghouse 132 100 0.038

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

Gypsum Stone Transfer PM 6-1-2 No 0.03 A stack test will be required to demonstrate compliance

gr/dscfm

PM10

SOx

NOx

VOC

CO

Page 22 
Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Maximum Emission Potential Emissions

Emission 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 Mills 200 PM 0.0159 13.928 6.605 0.000 0.000 0.000 0.000EU36 PM10 0.0075SCC 3-05-020-06 SOx 0

NOx 0

VOC 0

CO 0

Pollutant Control Air Flow Outlet Grain Emissions After Controls

Type of Control Device and ID number Efficiency Rate 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% 4700 0.04 0.028 0.013 0.000 0.000 0.000 0.000

PM10 99.8%

SOx

NOx

VOC

CO

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 251 70 0.040

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

Clinker Transfer Circuit ABC Mills PM 6-1-2 No 0.03 A stack test will be required to demonstrate compliance

gr/dscfm

PM10

SOx

NOx

VOC

CO

Page 23 
Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Maximum Emission Potential Emissions

Emission 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 Elevators 200 PM 0.0280 12264.000 12264.000 0.000 0.000 0.000 0.000EU37 PM10 0.0280SCC 3-05-007-29 SOx 0Finish Mill #1 Facilities NOx 0

VOC 0

CO 0

Pollutant Control Air Flow Outlet Grain Emissions After Controls

Type of Control Device and ID number Efficiency Rate 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 24.528 24.528 0.000 0.000 0.000 0.000

PM10 99.8%

SOx

NOx

VOC

CO

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 134 150 0.035

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

Two (2) Clinker Elevators PM 6-1-2 No 0.03 A stack test will be required to demonstrate compliance

gr/dscfm

PM10

SOx

NOx

VOC

CO

Page 24 
Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Maximum Emission Potential Emissions

Emission 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 Mill 24 PM 0.0080 420.480 420.480 0.000 0.000 0.000 0.000EU38 PM10 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 Controls

Type of Control Device and ID number Efficiency Rate 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% 9000 0.04 0.841 0.841 0.000 0.000 0.000 0.000

PM10 99.8%

SOx

NOx

VOC

CO

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 133 150 0.035

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

2A Hopper / Preliminary Mill PM 6-1-2 No 0.03 A stack test will be required to demonstrate compliance

gr/dscfm

PM10

SOx

NOx

VOC

CO

Page 25 
Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Maximum Emission Potential Emissions

Emission 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 Circuit 24 PM 0.0024 126.144 126.144 0.000 0.000 0.000 0.000EU39 PM10 0.0024SCC 3-05-007-27 SOx 0

NOx 0

Note: 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 Controls

Type of Control Device and ID number Efficiency Rate 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 0.252 0.252 0.000 0.000 0.000 0.000

PM10 99.8%

SOx

NOx

VOC

CO

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 134 150 0.035

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

2A Finish Mill Circuit PM 6-1-2 No 0.03 A stack test will be required to demonstrate compliance

gr/dscfm

PM10

SOx

NOx

VOC

CO

Page 26 
Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Maximum Emission Potential Emissions

Emission 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 Circuit 25 PM 0.0024 126.144 126.144 0.000 0.000 0.000 0.000EU40 PM10 0.0024SCC 3-05-007-27 SOx 0

NOx 0

Note: 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 Controls

Type of Control Device and ID number Efficiency Rate 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% 25000 0.04 0.252 0.252 0.000 0.000 0.000 0.000

PM10 99.8%

SOx

NOx

VOC

CO

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 135 150 0.035

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

2B Finish Mill Circuit PM 6-1-2 No 0.03 A stack test will be required to demonstrate compliance

gr/dscfm

PM10

SOx

NOx

VOC

CO

Page 27 
Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Maximum Emission Potential Emissions

Emission 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 Circuit 36 PM 0.0024 126.144 126.144 0.000 0.000 0.000 0.000EU42 PM10 0.0024SCC 3-05-007-27 SOx 0

NOx 0

Note: 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 Controls

Type of Control Device and ID number Efficiency Rate 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% 27000 0.04 0.252 0.252 0.000 0.000 0.000 0.000

PM10 99.8%

SOx

NOx

VOC

CO

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 137 150 0.035

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

2C Finish Mill Circuit PM 6-1-2 No 0.03 A stack test will be required to demonstrate compliance

gr/dscfm

PM10

SOx

NOx

VOC

CO

Page 28 
Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Maximum Emission Potential Emissions

Emission 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 Cooler 36 PM 0.0280 2207.520 2207.520 0.000 0.000 0.000 0.000EU43 PM10 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 Controls

Type of Control Device and ID number Efficiency Rate 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% 27000 0.04 4.415 4.415 0.000 0.000 0.000 0.000

PM10 99.8%

SOx

NOx

VOC

CO

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 138 150 0.035

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

Separator and Cement Cooler PM 6-1-2 No 0.03 A stack test will be required to demonstrate compliance

gr/dscfm

PM10

SOx

NOx

VOC

CO

Page 29 
Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Maximum Emission Potential Emissions

Emission 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 Cooler 25 PM 0.0280 2207.520 2207.520 0.000 0.000 0.000 0.000EU41 PM10 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 Controls

Type of Control Device and ID number Efficiency Rate 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% 25000 0.04 4.415 4.415 0.000 0.000 0.000 0.000

PM10 99.8%

SOx

NOx

VOC

CO

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 136 150 0.035

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

Separator and Cement Cooler PM 6-1-2 No 0.03 A stack test will be required to demonstrate compliance

gr/dscfm

PM10

SOx

NOx

VOC

CO

Page 30 
Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Maximum Emission Potential Emissions

Emission 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 Elevator 45 PM 0.0014 137.970 137.970 0.000 0.000 0.000 0.000EU135 PM10 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 Controls

Type of Control Device and ID number Efficiency Rate 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% 6000 0.04 0.276 0.276 0.000 0.000 0.000 0.000

PM10 99.8%

SOx

NOx

VOC

CO

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 120 70 0.040

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

Gypsum Elevator PM 6-1-2 No 0.03 A stack test will be required to demonstrate compliance

gr/dscfm

PM10

SOx

NOx

VOC

CO

Page 31 
Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Maximum Emission Potential Emissions

Emission 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 Bin 300 PM 0.0024 1576.800 1576.800 0.000 0.000 0.000 0.000EU44 PM10 0.0024SCC 3-05-007-27 SOx 0

NOx 0

Note: 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 Controls

Type of Control Device and ID number Efficiency Rate 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% 6000 0.04 1.261 1.261 0.000 0.000 0.000 0.000baghouse 202 PM 99.8% 9000 0.04 1.892 1.892

total PM 15000 3.154 3.154

PM10 99.8%

SOx

NOx

VOC

CO

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 120 70 0.040baghouse 202 70 0.040

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

2D Finish Mill Clinker Bin PM 6-1-2 No 0.03 A stack test will be required to demonstrate compliance

Finish Mill #2 Facilities gr/dscfm

PM10

SOx

NOx

VOC

CO

Page 32 
Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Maximum Emission Potential Emissions

Emission 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 Circuit 120 PM 0.0360 9460.800 9460.800 0.000 0.000 0.000 0.000EU46 PM10 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 Controls

Type of Control Device and ID number Efficiency Rate 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 0.04 18.922 18.922 0.000 0.000 0.000 0.000

PM10 99.8%

SOx

NOx

VOC

CO

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouses 261, 262, and 263 150 0.035

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

2D Finish Mill Roll Press Circuit PM 6-1-2 No 0.03 A stack test will be required to demonstrate compliance

gr/dscfm

PM10

SOx

NOx

VOC

CO

Page 33 
Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Maximum Emission Potential Emissions

Emission 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 System 200 PM 0.0159 13.928 6.605 0.000 0.000 0.000 0.000EU63 PM10 0.0075SCC 3-05-020-06 SOx 0

NOx 0

VOC 0

CO 0

Pollutant Control Air Flow Outlet Grain Emissions After Controls

Type of Control Device and ID number Efficiency Rate 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% 3600 0.04 0.028 0.013 0.000 0.000 0.000 0.000

PM10 99.8%

SOx

NOx

VOC

CO

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 206 70 0.040

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

Covered Conveyor System PM 6-1-2 No 0.03 A stack test will be required to demonstrate compliance

gr/dscfm

PM10

SOx

NOx

VOC

CO

Page 34 
Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Maximum Emission Potential Emissions

Emission 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 Drilling 7740 PM 1.3000 5.031 2.515 0.000 0.000 0.000 0.000EU01 PM10 0.6500

SOx 0

NOx 0

VOC 0

CO 0

Pollutant Control Air Flow Outlet Grain Emissions After Controls

Type of Control Device and ID number Efficiency Rate Loading PM PM10 SOx NOx VOC CO

(acfm) (gr/acfm) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year

baghouse CE01 PM 0.0% 5.031 2.515 0.000 0.000 0.000 0.000no known parameters for this baghouse PM10 0.0%

SOx

NOx

VOC

CO

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse CE01 0.000

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

Quarry Drilling PM 6-1-2 Impossible 0.03 

to determine gr/dscfm

without baghouse parameters

PM10

SOx

NOx

VOC

CO

Page 35 
Appendix A: Emission Calculations

Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Maximum Emission Potential 

Emission Unit Capacity Pollutant Factor PM PM10 SOx N

(tons/hr) (lb/ton) (Tons/Year) (Tons/Year) (Tons/Year) (Tons

Primary Crusher 700 PM 0.5100 1563.660 52.122 0.000 0.0EU82 PM10 0.0170SCC 3-05-020-01 SOx 0

NOx 0

VOC 0

CO 0

Pollutant Control Air Flow Outlet Grain Emissions A

Type of Control Device and ID number Efficiency Rate Loading PM PM10 SOx N

(acfm) (gr/acfm) (Tons/Year) (Tons/Year) (Tons/Year) (Tons

none PM 0.0% 1563.660 52.122 0.000 0.0

PM10 0.0%

SOx

NOx

VOC

CO

baghouses 
Appendix A: Emission Calculations

Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Pollutant Control Air Flow Outlet Grain Emissions A

Type of Control Device and ID number Efficiency Rate Loading PM PM10 SOx N

(acfm) (gr/acfm) (Tons/Year) (Tons/Year) (Tons/Year) (Tons

North Stone Bin PM 99.8% 6000 0.04 2.057 2.057 0.000 0.0EU06 PM10 99.8%baghouse 101 SOx

NOx Emissions Be

Emissions are calculated using VOC PM PM10 SOx N

control device oulet grain loading CO (Tons/Year) (Tons/Year) (Tons/Year) (Tonsand flow rate. 1028.571 1028.571 0.000 0.0

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 101 70 0.040

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

North Stone Bin PM 6-1-2 No 0.03 A stack test will be required to EU06 gr/dscfmbaghouse 101

PM10

SOx

NOx

VOC

CO

baghouses 
Appendix A: Emission Calculations

Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Pollutant Control Air Flow Outlet Grain Emissions A

Type of Control Device and ID number Efficiency Rate Loading PM PM10 SOx N

(acfm) (gr/acfm) (Tons/Year) (Tons/Year) (Tons/Year) (Tons

South Stone Bin EU07baghouse 102 PM 99.8% 6000 0.04 2.057 2.057 0.000 0.0Emissions are calculated using PM10 99.8%control device oulet grain loading SOxand flow rate. NOx Emissions Be

VOC PM PM10 SOx N

CO (Tons/Year) (Tons/Year) (Tons/Year) (Tons

1028.571 1028.571 0.000 0.0

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 102 70 0.040

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

South Stone Bin EU07 PM 6-1-2 No 0.03 A stack test will be required to baghouse 102 gr/dscfm

PM10

SOx

NOx

VOC

CO

baghouses 
Appendix A: Emission Calculations

Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Pollutant Control Air Flow Outlet Grain Emissions A

Type of Control Device and ID number Efficiency Rate Loading PM PM10 SOx N

(acfm) (gr/acfm) (Tons/Year) (Tons/Year) (Tons/Year) (Tons

Additive Bins PM 99.8% 5000 0.04 1.714 1.714 0.000 0.0EU10, EU11, and EU12 PM10 99.8%baghouse 228 SOx

NOx Emissions Be

Emissions are calculated using VOC PM PM10 SOx N

control device oulet grain loading CO (Tons/Year) (Tons/Year) (Tons/Year) (Tonsand flow rate. 857.143 857.143 0.000 0.0

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 228 70 0.040

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

Additive Bins PM 6-1-2 No 0.03 A stack test will be required to EU10, EU11, and EU12 gr/dscfmbaghouse 228

PM10

SOx

NOx

VOC

CO

baghouses 
Appendix A: Emission Calculations

Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Pollutant Control Air Flow Outlet Grain Emissions A

Type of Control Device and ID number Efficiency Rate Loading PM PM10 SOx N

(acfm) (gr/acfm) (Tons/Year) (Tons/Year) (Tons/Year) (Tons

Sidewinder PM 99.8% 2330 0.04 0.799 0.799 0.000 0.0EU15 PM10 99.8%baghouse 247 SOx

NOx Emissions Be

Emissions are calculated using VOC PM PM10 SOx N

control device oulet grain loading CO (Tons/Year) (Tons/Year) (Tons/Year) (Tonsand flow rate. 399.429 399.429 0.000 0.0

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 247 70 0.040

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

Sidewinder PM 6-1-2 No 0.03 A stack test will be required to EU15 gr/dscfmbaghouse 247

PM10

SOx

NOx

VOC

CO

baghouses 
Appendix A: Emission Calculations

Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Pollutant Control Air Flow Outlet Grain Emissions A

Type of Control Device and ID number Efficiency Rate Loading PM PM10 SOx N

(acfm) (gr/acfm) (Tons/Year) (Tons/Year) (Tons/Year) (Tons

Blend Silo #1 PM 99.8% 9360 0.04 3.209 3.209 0.000 0.0EU16 PM10 99.8%baghouse 211 SOx

NOx Emissions Be

Emissions are calculated using VOC PM PM10 SOx N

control device oulet grain loading CO (Tons/Year) (Tons/Year) (Tons/Year) (Tonsand flow rate. 1604.571 1604.571 0.000 0.0

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 211 150 0.035

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

Blend Silo #1 PM 6-1-2 No 0.03 A stack test will be required to EU16 gr/dscfmbaghouse 211

PM10

SOx

NOx

VOC

CO

baghouses 
Appendix A: Emission Calculations

Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Pollutant Control Air Flow Outlet Grain Emissions A

Type of Control Device and ID number Efficiency Rate Loading PM PM10 SOx N

(acfm) (gr/acfm) (Tons/Year) (Tons/Year) (Tons/Year) (Tons

Blend Silo #2 PM 99.8% 13500 0.04 4.629 4.629 0.000 0.0EU17 PM10 99.8%baghouse 230 SOx

NOx Emissions Be

Emissions are calculated using VOC PM PM10 SOx N

control device oulet grain loading CO (Tons/Year) (Tons/Year) (Tons/Year) (Tonsand flow rate. 2314.286 2314.286 0.000 0.0

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 230 180 0.033

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

Blend Silo #2 PM 6-1-2 No 0.03 A stack test will be required to EU17 gr/dscfmbaghouse 230

PM10

SOx

NOx

VOC

CO

baghouses 
Appendix A: Emission Calculations

Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Pollutant Control Air Flow Outlet Grain Emissions A

Type of Control Device and ID number Efficiency Rate Loading PM PM10 SOx N

(acfm) (gr/acfm) (Tons/Year) (Tons/Year) (Tons/Year) (Tons

Calibration System PM 99.8% 6250 0.04 2.143 2.143 0.000 0.0EU18 PM10 99.8%baghouse 212 SOx

NOx Emissions Be

Emissions are calculated using VOC PM PM10 SOx N

control device oulet grain loading CO (Tons/Year) (Tons/Year) (Tons/Year) (Tonsand flow rate. 1071.429 1071.429 0.000 0.0

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 212 150 0.035

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

Calibration System PM 6-1-2 No 0.03 A stack test will be required to EU18 gr/dscfmbaghouse 212

PM10

SOx

NOx

VOC

CO

baghouses 
Appendix A: Emission Calculations

Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Pollutant Control Air Flow Outlet Grain Emissions A

Type of Control Device and ID number Efficiency Rate Loading PM PM10 SOx N

(acfm) (gr/acfm) (Tons/Year) (Tons/Year) (Tons/Year) (Tons

Dust Tank system PM 99.8% 2400 0.04 0.823 0.823 0.000 0.0EU21 PM10 99.8%baghouse 210 SOx

NOx Emissions Be

Emissions are calculated using VOC PM PM10 SOx N

control device oulet grain loading CO (Tons/Year) (Tons/Year) (Tons/Year) (Tonsand flow rate. 411.429 411.429 0.000 0.0

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 210 300 0.028

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

Dust Tank system PM 6-1-2 Yes 0.03 EU21 gr/dscfmbaghouse 210

PM10

SOx

NOx

VOC

CO

baghouses 
Appendix A: Emission Calculations

Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Pollutant Control Air Flow Outlet Grain Emissions A

Type of Control Device and ID number Efficiency Rate Loading PM PM10 SOx N

(acfm) (gr/acfm) (Tons/Year) (Tons/Year) (Tons/Year) (Tons

Elevator/Dust Tank Alkali Bypass PM 99.8% 4200 0.04 1.440 1.440 0.000 0.0EU28 PM10 99.8%baghouse 232 SOx

NOx Emissions Be

Emissions are calculated using VOC PM PM10 SOx N

control device oulet grain loading CO (Tons/Year) (Tons/Year) (Tons/Year) (Tonsand flow rate. 720.000 720.000 0.000 0.0

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 232 340 0.026

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

Elevator/Dust Tank Alkali Bypass PM 6-1-2 Yes 0.03 EU28 gr/dscfmbaghouse 232

PM10

SOx

NOx

VOC

CO

baghouses 
Appendix A: Emission Calculations

Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Pollutant Control Air Flow Outlet Grain Emissions A

Type of Control Device and ID number Efficiency Rate Loading PM PM10 SOx N

(acfm) (gr/acfm) (Tons/Year) (Tons/Year) (Tons/Year) (Tons

CKD Sales Loadout spout PM 99.8% 2400 0.04 0.823 0.823 0.000 0.0EU154 PM10 99.8%baghouse 265 (CE97) SOx

NOx Emissions Be

Emissions are calculated using VOC PM PM10 SOx N

control device oulet grain loading CO (Tons/Year) (Tons/Year) (Tons/Year) (Tonsand flow rate. 411.429 411.429 0.000 0.0

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 265 (CE97) 70 0.040

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

CKD Sales Loadout spout PM 6-1-2 No 0.03 A stack test will be required to EU154 gr/dscfmbaghouse 265 (CE97)

PM10

SOx

NOx

VOC

CO

baghouses 
Appendix A: Emission Calculations

Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Pollutant Control Air Flow Outlet Grain Emissions A

Type of Control Device and ID number Efficiency Rate Loading PM PM10 SOx N

(acfm) (gr/acfm) (Tons/Year) (Tons/Year) (Tons/Year) (Tons

CKD Sales Loadout (kiln #1 dust tank) PM 99.8% 800 0.04 0.274 0.274 0.000 0.0EU155 PM10 99.8%baghouse 266 (CE98) SOx

NOx Emissions Be

Emissions are calculated using VOC PM PM10 SOx N

control device oulet grain loading CO (Tons/Year) (Tons/Year) (Tons/Year) (Tonsand flow rate. 137.143 137.143 0.000 0.0

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 266 (CE98) 70 0.040

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be 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 EU155 gr/dscfmbaghouse 266 (CE98)

PM10

SOx

NOx

VOC

CO

baghouses 
Appendix A: Emission Calculations

Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Pollutant Control Air Flow Outlet Grain Emissions A

Type of Control Device and ID number Efficiency Rate Loading PM PM10 SOx N

(acfm) (gr/acfm) (Tons/Year) (Tons/Year) (Tons/Year) (Tons

CKD/Lime Tank PM 99.8% 5000 0.04 1.714 1.714 0.000 0.0EU146 PM10 99.8%baghouse 143 SOxFinish Mill #1 Facilities NOx Emissions BeEmissions are calculated using VOC PM PM10 SOx N

control device oulet grain loading CO (Tons/Year) (Tons/Year) (Tons/Year) (Tonsand flow rate. 857.143 857.143 0.000 0.0

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 143 150 0.035

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

CKD/Lime Tank PM 6-1-2 No 0.03 A stack test will be required to EU146 gr/dscfmbaghouse 143

PM10

SOx

NOx

VOC

CO

baghouses 
Appendix A: Emission Calculations

Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Pollutant Control Air Flow Outlet Grain Emissions A

Type of Control Device and ID number Efficiency Rate Loading PM PM10 SOx N

(acfm) (gr/acfm) (Tons/Year) (Tons/Year) (Tons/Year) (Tons

Kiln #2 coal dust silo PM 99.8% 2700 0.04 0.926 0.926 0.000 0.0EU149 PM10 99.8%baghouse 253 SOx

NOx Emissions Be

Emissions are calculated using VOC PM PM10 SOx N

control device oulet grain loading CO (Tons/Year) (Tons/Year) (Tons/Year) (Tonsand flow rate. 462.857 462.857 0.000 0.0

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 253 0.046

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

Kiln #2 coal dust silo PM 6-1-2 No 0.03 A stack test will be required to EU149 gr/dscfmbaghouse 253

PM10

SOx

NOx

VOC

CO

baghouses 
Appendix A: Emission Calculations

Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Pollutant Control Air Flow Outlet Grain Emissions A

Type of Control Device and ID number Efficiency Rate Loading PM PM10 SOx N

(acfm) (gr/acfm) (Tons/Year) (Tons/Year) (Tons/Year) (Tons

Kiln #2 coal weigh system PM 99.8% 500 0.04 0.171 0.171 0.000 0.0EU150 PM10 99.8%baghouse 254 SOx

NOx Emissions Be

Emissions are calculated using VOC PM PM10 SOx N

control device oulet grain loading CO (Tons/Year) (Tons/Year) (Tons/Year) (Tonsand flow rate. 85.714 85.714 0.000 0.0

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 254 0.046

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

Kiln #2 coal weigh system PM 6-1-2 No 0.03 A stack test will be required to EU150 gr/dscfmbaghouse 254

PM10

SOx

NOx

VOC

CO

baghouses 
Appendix A: Emission Calculations

Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Pollutant Control Air Flow Outlet Grain Emissions A

Type of Control Device and ID number Efficiency Rate Loading PM PM10 SOx N

(acfm) (gr/acfm) (Tons/Year) (Tons/Year) (Tons/Year) (Tons

Kiln #2 coal handling system PM 99.8% 200 0.04 0.069 0.069 0.000 0.0EU151 PM10 99.8%baghouse 255 SOx

NOx Emissions Be

Emissions are calculated using VOC PM PM10 SOx N

control device oulet grain loading CO (Tons/Year) (Tons/Year) (Tons/Year) (Tonsand flow rate. 34.286 34.286 0.000 0.0

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 255 0.046

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

Kiln #2 coal handling system PM 6-1-2 No 0.03 A stack test will be required to EU151 gr/dscfmbaghouse 255

PM10

SOx

NOx

VOC

CO

baghouses 
Appendix A: Emission Calculations

Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Pollutant Control Air Flow Outlet Grain Emissions A

Type of Control Device and ID number Efficiency Rate Loading PM PM10 SOx N

(acfm) (gr/acfm) (Tons/Year) (Tons/Year) (Tons/Year) (Tons

Vacuum System PM 99.8% 400 0.04 0.137 0.137 0.000 0.0EU73 PM10 99.8%baghouse 250 SOx

NOx Emissions Be

Emissions are calculated using VOC PM PM10 SOx N

control device oulet grain loading CO (Tons/Year) (Tons/Year) (Tons/Year) (Tonsand flow rate. 68.571 68.571 0.000 0.0

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 250 70 0.040

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

Vacuum System PM 6-1-2 No 0.03 A stack test will be required to EU73 gr/dscfmbaghouse 250

PM10

SOx

NOx

VOC

CO

baghouses 
Appendix A: Emission Calculations

Company Name: ESSROC Cement Corporation, Speed Plant

Location: Speed, Indiana

Permit Number: T019-6016-00008

Reviewer: Nisha Sizemore

Pollutant Control Air Flow Outlet Grain Emissions A

Type of Control Device and ID number Efficiency Rate Loading PM PM10 SOx N

(acfm) (gr/acfm) (Tons/Year) (Tons/Year) (Tons/Year) (Tons

Warehouse Conveyor System PM 99.8% 1650 0.04 0.566 0.566 0.000 0.0EU74 PM10 99.8%baghouse 249 SOx

NOx Emissions Be

Emissions are calculated using VOC PM PM10 SOx N

control device oulet grain loading CO (Tons/Year) (Tons/Year) (Tons/Year) (Tonsand flow rate. 282.857 282.857 0.000 0.0

PM Emissions

Type of Control Device and ID number Temperature After Controls

(degrees F) (gr/dscfm)

baghouse 249 70 0.040

Applicable Can Compliance Emission

Emission Unit Pollutant Rules be determined? Limits

(Y or N)

Warehouse Conveyor System PM 6-1-2 No 0.03 A stack test will be required to EU74 gr/dscfmbaghouse 249

PM10

SOx

NOx

VOC

CO

baghouses 
NSR 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 bin 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 baghouses

are not known for certain, stack tests will be required to demonstrate compliance with these limits. 

NSR Review Page 1
ESSROC, Speed Plant

Subpart FAffected Facilities include kilns, coolers, raw mill system, finish mill system, raw mill dryer, raw material storage, clinker storage,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 Subpart LLL 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 1
ESSROC, Speed Plant

Aug 31, 1983 Oct 24, 1974 Aug 17, 1971

Emission Emission Date of NSPS NSPS NSPS N

Unit Unit Construction Subpart OOO Subpart Y Subpart F Su

Description ID

Quarry activitiesquarry drilling EU01 1982 pre-dates rule no, not affected facility not affected facilities no, not quarry blasting EU75 pre-1945 pre-dates rule not affected facilities not affected facilities no, not raw matl loading EU76 1948 pre-dates rule not affected facilities not affected facilities no, not stone surge pile EU79 pre-1945 pre-dates rule not affected facilities not affected facilities no, not Raw Material Stockpile Operationsraw material unloading to stockpile EU78 1948 pre-dates rule not affected facilities not affected facilities no, not strippings stockpile EU145 pre-1945 pre-dates rule not affected facilities not affected facilities no, not truck unloading to additive hopper EU99 1948 pre-dates rule not affected facilities not affected facilities no, not silica/alumina/iron storage pile EU100 pre-1945 pre-dates rule not affected facilities not affected facilities no, not additive clay blend pile EU101 pre-1945 pre-dates rule not affected facilities not affected facilities no, not truck unloading to clay storage piles EU102 1948 pre-dates rule not affected facilities not affected facilities no, not uncovered clay storage pile EU103 pre-1945 pre-dates rule not affected facilities not affected facilities no, not covered clay storage pile EU104 pre-1945 pre-dates rule not affected facilities not affected facilities no, not Raw Material Sizing OperationsRaw material unloading to crusher EU80 pre-1956 pre-dates rule not affected facilities not affected facilities no, not stone surge pile EU81 pre-1945 pre-dates rule not affected facilities not affected facilities no, not primary crusher EU82 1956 pre-dates rule not affected facilities not affected facilities no, not covered conveyor (transfers stone) EU83 1956 pre-dates rule not affected facilities not affected facilities no, not screens EU84 1956 pre-dates rule not affected facilities not affected facilities no, not secondary crusher EU02 1956 pre-dates rule not affected facilities not affected facilities no, not covered conveyor (transfers stone) EU03 1956 pre-dates rule not affected facilities not affected facilities no, not tertiary crushers (2) EU04 1956 pre-dates rule not affected facilities not affected facilities no, not conveyor (transfers stone) EU05 1956 pre-dates rule not affected facilities not affected facilities no, not covered conveyor (transfers stone) EU85 1956 pre-dates rule not affected facilities not affected facilities no, not traveling belt (transfers stone) EU86 1956 pre-dates rule not affected facilities not affected facilities no, not north stone bin EU06 1956 pre-dates rule not affected facilities not affected facilities no, not south stone bin EU07 1956 pre-dates rule not affected facilities not affected facilities no, not stone conveyor transfer to truck EU87 1956 pre-dates rule not affected facilities not affected facilities no, not truck unloading (crushed limestone) EU89 1956 pre-dates rule not affected facilities not affected facilities no, not truck loading (crushed limestone) EU91 1956 pre-dates rule not affected facilities not affected facilities no, not truck unloading EU93 1956 pre-dates rule not affected facilities not affected facilities no, not truck unloading (limestone) EU94 1956 pre-dates rule not affected facilities not affected facilities no, not crushed limestone storage piles EU90 pre-1945 pre-dates rule not affected facilities not affected facilities no, not emergency limestone storage piles EU95 pre-1945 pre-dates rule not affected facilities not affected facilities no, not truck dump hopper EU96 1977 pre-dates rule not affected facilities not affected facilities no, not limestone conveyor EU97 1977 pre-dates rule not affected facilities not affected facilities no, not 

Page 2
ESSROC, Speed Plant

Aug 31, 1983 Oct 24, 1974 Aug 17, 1971

Emission Emission Date of NSPS NSPS NSPS N

Unit Unit Construction Subpart OOO Subpart Y Subpart F Su

Description ID

CKD Operationsall facilities not affected facilities not affected facilities not affected facilities no, not Miscellaneous Facilitiesvacuum system EU73 1985 not affected facilities not affected facilities yes warehouse conveyor system EU74 1985 not affected facilities not affected facilities yes, transfer points only yes, tranClay Processing Operationsclay hopper EU105 pre-1945 not affected facilities not affected facilities pre-dates rule covered conveyor system (clay) EU106 pre-1954 not affected facilities not affected facilities pre-dates rule clay crusher EU08 1977 not affected facilities not affected facilities not affected facilities Finish Operations Crane Storageemergency stone storage pile EU128 pre-1945 not affected facilities not affected facilities pre-dates rule no, not truck unloading station EU127 pre-1945 not affected facilities not affected facilities pre-dates rule truck unloading station EU129 pre-1945 not affected facilities not affected facilities pre-dates rule crane storage building EU131 pre-1945 not affected facilities not affected facilities pre-dates rule gypsum storage piles EU130 pre-1945 not affected facilities not affected facilities pre-dates rule no, not gypsum storage piles EU134 pre-1945 not affected facilities not affected facilities pre-dates rule no, not Raw Mill Facilitiespneumatic truck unloading stations EU107 July, 1976 not affected facilities not affected facilities yes hopper EU109 July, 1976 not affected facilities not affected facilities yes additive bins equipped with 2 elevators EU10-12 1977 not affected facilities not affected facilities yes C-15 covered conveyor (clay) EU09 1977 not affected facilities not affected facilities yes, transfer points only yes, tranLoesche raw mill EU14 1977 not affected facilities not affected facilities yes sidewinder (pneumatic transfer pump) EU15 1977 not affected facilities not affected facilities yes raw material pile EU112 pre-1945 not affected facilities not affected facilities pre-dates rule no, not Todd furnace (for Loesche raw mill) EU13 1977 not affected facilities not affected facilities yes blend silo #1 EU16 May, 1971 not affected facilities not affected facilities pre-dates rule blend silo #2 EU17 1977 not affected facilities not affected facilities yes calibration system EU18 May, 1971 not affected facilities not affected facilities pre-dates rule Fossil Fuel Storage and Handlingtruck unloading station (coal) EU136 June, 1971 not affected facilities pre-dates rule pre-dates rule reserve coal storage pile EU137 pre-1945 not affected facilities pre-dates rule pre-dates rule no, not coal storage pile EU142 pre-1945 not affected facilities pre-dates rule pre-dates rule no, not coal draw-up covered conveyor EU63 June, 1972 not affected facilities pre-dates rule yes, transfer points only yes, trancoal transfer tower EU64 June, 1972 not affected facilities pre-dates rule yes, transfer points only yes, trancoal bin EU65 June, 1972 not affected facilities pre-dates rule yes 

Page 3
ESSROC, Speed Plant

Aug 31, 1983 Oct 24, 1974 Aug 17, 1971

Emission Emission Date of NSPS NSPS NSPS N

Unit Unit Construction Subpart OOO Subpart Y Subpart F Su

Description ID

Kiln #1 Clinker Handling Facilities#1 clinker drag conveyor (clinker) EU23 May, 1971 not affected facilities not affected facilities pre-dates rule apron conveyor (clinker) EU24 May, 1971 not affected facilities not affected facilities pre-dates rule clinker can #1 (off-spec clinker) EU114 May, 1971 not affected facilities not affected facilities pre-dates rule Kiln #2 Clinker Handling Facilities#2 clinker drag conveyor (clinker) EU30 1977 not affected facilities not affected facilities yes, transfer points only yes, tranaumond conveyor (clinker) EU31 1977 not affected facilities not affected facilities yes, transfer points only yes, trancross belt (clinker) EU119 May, 1971 not affected facilities not affected facilities pre-dates rule clinker can #2 (off-spec clinker) EU120 1977 not affected facilities not affected facilities yes Clinker Handling to Crane Storagelong belt (clinker) EU25 May, 1971 not affected facilities not affected facilities pre-dates rule north clinker transfer tower EU32 1972 not affected facilities not affected facilities yes, transfer points only yes, trancovered incline belt (clinker) EU33 1972 not affected facilities not affected facilities yes, transfer points only yes, tranclinker storage pile EU121 pre-1945 not affected facilities not affected facilities pre-dates rule no, not north clinker storage pile EU122 pre-1945 not affected facilities not affected facilities pre-dates rule no, not north clinker storage building EU123 1960 not affected facilities not affected facilities pre-dates rule covered conveyor system (clinker) EU34 1962 not affected facilities not affected facilities pre-dates rule south reclaim clinker covered conveyor EU124 May, 1971 not affected facilities not affected facilities pre-dates rule truck loading station EU125 May, 1971 not affected facilities not affected facilities pre-dates rule truck unloading station EU126 May, 1971 not affected facilities not affected facilities pre-dates rule 2ABC Finish Mill FacilitiesCKD/Lime tank EU146 1964 not affected facilities not affected facilities pre-dates rule gypsum/stone transfer circuit EU35 1964 not affected facilities not affected facilities pre-dates rule clinker transfer circuit ABC mills EU36 1964 not affected facilities not affected facilities pre-dates rule elevators EU37 1969 not affected facilities not affected facilities pre-dates rule finish mill feed belt EU132 1977 not affected facilities not affected facilities yes, transfer points only yes, tran2A hopper/preliminary ball mill EU38 1948 not affected facilities not affected facilities pre-dates rule finish mill circuit 2A EU39 1948 not affected facilities not affected facilities pre-dates rule finish mill circuit 2B EU40 1953 not affected facilities not affected facilities pre-dates rule finish mill circuit 2C EU42 1960 not affected facilities not affected facilities pre-dates rule separator and cement cooler EU43 1960/1964 not affected facilities not affected facilities pre-dates rule 

separator and cement cooler EU41 1953/1955 not affected facilities not affected facilities pre-dates rule 

BP tank EU48 1965 not affected facilities not affected facilities pre-dates rule pump (from BP tank to silos) EU49 1966 not affected facilities not affected facilities pre-dates rule 

Page 4
ESSROC, Speed Plant

Aug 31, 1983 Oct 24, 1974 Aug 17, 1971

Emission Emission Date of NSPS NSPS NSPS N

Unit Unit Construction Subpart OOO Subpart Y Subpart F Su

Description ID

2D Finish Mill Facilitiesgypsum elevator EU135 1964 not affected facilities not affected facilities pre-dates rule 2D finish mill clinker bin EU44 1964 not affected facilities not affected facilities pre-dates rule finish mill clinker/gypsum feed circuit EU45 1964 not affected facilities not affected facilities pre-dates rule 2D finish mill roll press circuit EU46 1999 not affected facilities not affected facilities yes finish mill circuit 2D EU47 1964 not affected facilities not affected facilities pre-dates rule Finish Product Storage, Packing, and Bulk Loading501 silos EU54 1965 not affected facilities not affected facilities pre-dates rule BIC mixer (lime and pigment) EU55 1973 not affected facilities not affected facilities yes BIC packer (loads cement bags) EU56 1973 not affected facilities not affected facilities yes 506 silos EU53 1958 not affected facilities not affected facilities pre-dates rule 2 bulk loading stations EU57-58 1954 not affected facilities not affected facilities pre-dates rule packer #1 EU59 1960 not affected facilities not affected facilities pre-dates rule packer #2 EU60 1960 not affected facilities not affected facilities pre-dates rule packer #3 EU61 1960 not affected facilities not affected facilities pre-dates rule bag compression station EU62 1960 not affected facilities not affected facilities pre-dates rule 504 silos EU51 1959 not affected facilities not affected facilities pre-dates rule bulk loading station (trucks and RR) EU52 1959 not affected facilities not affected facilities pre-dates rule 502 silos EU50 1966 not affected facilities not affected facilities pre-dates rule Coal Handling, Milling, and Storagecoal crusher mill #1 EU66 May, 1971 not affected facilities pre-dates rule, exhausts to kiln pre-dates rule coal crusher mill #2 EU67 1977 not affected facilities yes yes fuel oil-fired air heater for kiln #1 EU68 May, 1971 not affected facilities pre-dates rule, exhausts to kiln pre-dates rule fuel oil-fired air heater for kiln #2 EU69 1977 not affected facilities yes yes kiln #2 coal dust silo EU149 1996 not affected facilities yes yes kiln #2 coal weigh system EU150 1996 not affected facilities yes yes kiln #2 coal handling system EU151 1996 not affected facilities yes yes Kiln Facilitiesfeed system for kiln #1 EU19 May, 1971 not affected facilities not affected facilities pre-dates rule kiln #1 EU20 May, 1971 not affected facilities not affected facilities pre-dates rule feed system for kiln #2 EU26 1977 not affected facilities not affected facilities yes kiln #2 EU27 1977 not affected facilities not affected facilities yes kiln #2 alkali bypass EU28 1977 not affected facilities not affected facilities yes Clinker Coolerscooler #1 EU22 May, 1971 not affected facilities not affected facilities pre-dates rule cooler #2 EU29 1977 not affected facilities not affected facilities yes 

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