INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

We Protect Hoosiers and Our Environment. 

Mitchell E. Daniels Jr. 100 North Senate Avenue 

Governor Indianapolis, Indiana 46204 

(317) 232-8603 

Thomas W. Easterly Toll Free (800) 451-6027 

Commissioner www.idem.IN.gov 

Page 1 of 2 

FNTV-PMOD.dot 1/2/08 

 Recycled Paper An Equal Opportunity Employer Please Recycle 

 

TO: Interested Parties / Applicant 

DATE: July 22, 2009 

RE: Thermafiber, Inc. / 169-27436-00009 

FROM: Matthew Stuckey, Branch 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 13-17-3-4 and 326 IAC 2, this 

permit modification 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 13-15-7-3 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 Environmental Adjudication, 100 North Senate Avenue, Government Center North, Suite N 

501E, Indianapolis, IN 46204, within eighteen (18) days of the mailing of this notice. 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 a Title 

V operating permit 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 

FNTV-PMOD.doc 3/27/08


Thermafiber, Inc. Wabash Plant First Significant Permit Mod No. 169-27436-00009 Page 2 of 56 

Wabash, Indiana Modified By: Madhurima D. Moulik T169-21103-00009 

Permit Reviewer: Josiah Balogun 

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 Emission Units and Pollution Control Equipment Summary [326 IAC 2-7-4(c)(3)] 

 [326 IAC 2-7-5(15)]

A.3 Specifically Regulated Insignificant Activities [326 IAC 2-7-1(21)][326 IAC 2-7-4(c)] 

 [326 IAC 2-7-5(15)]

A.4 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][326 IAC 2-7-4(a)(1)(D)] 

 [IC 13-15-3-6(a)]

B.3 Term of Conditions [326 IAC 2-1.1-9.5]

B.4 Enforceability [326 IAC 2-7-7]

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][326 IAC 2-7-10.5]

B.14 Termination of Right to Operate [326 IAC 2-7-10][326 IAC 2-7-4(a)]

B.15 Deviations from Permit Requirements and Conditions [326 IAC 2-7-5(3)(C)(ii)]

B.16 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.17 Permit Renewal [326 IAC 2-7-3][326 IAC 2-7-4][326 IAC 2-7-8(e)]

B.18 Permit Amendment or Modification [326 IAC 2-7-11][326 IAC 2-7-12] [40 CFR 72]

B.19 Permit Revision Under Economic Incentives and Other Programs [326 IAC 2-7-5(8)] 

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

B.20 Operational Flexibility [326 IAC 2-7-20][326 IAC 2-7-10.5]

B.21 Source Modification Requirement [326 IAC 2-7-10.5]

B.22 Inspection and Entry [326 IAC 2-7-6][IC 13-14-2-2][IC 13-30-3-1][IC 13-17-3-2]

B.23 Transfer of Ownership or Operational Control [326 IAC 2-7-11]

B.24 Annual Fee Payment [326 IAC 2-7-19] [326 IAC 2-7-5(7)][326 IAC 2-1.1-7]

B.25 Credible Evidence [326 IAC 2-7-5(3)][326 IAC 2-7-6][62 FR 8314] [326 IAC 1-1-6]

C. SOURCE OPERATION CONDITIONS

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

C.1 Particulate Emission Limitations For Processes with Process Weight Rates 

 Less Than One Hundred (100) Pounds per Hour [326 IAC 6-3-2]

C.2 Opacity [326 IAC 5-1]

C.3 Open Burning [326 IAC 4-1] [IC 13-17-9]

C.4 Incineration [326 IAC 4-2] [326 IAC 9-1-2]

C.5 Fugitive Dust Emissions [326 IAC 6-4]

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]
Thermafiber, Inc. Wabash Plant First Significant Permit Mod No. 169-27436-00009 Page 3 of 56 

Wabash, Indiana Modified By: Madhurima D. Moulik T169-21103-00009 

Permit Reviewer: Josiah Balogun 

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

C.8 Performance Testing [326 IAC 3-6]

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 Monitoring Methods [326 IAC 3] [40 CFR 60] [40 CFR 63]

C.12 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.13 Emergency Reduction Plans [326 IAC 1-5-2] [326 IAC 1-5-3]

C.14 Risk Management Plan [326 IAC 2-7-5(12)] [40 CFR 68]

C.15 Response to Excursions or Exceedances [326 IAC 2-7-5] [326 IAC 2-7-6]

C.16 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.17 Emission Statement [326 IAC 2-7-5(3)(c)(iii)] [326 IAC 2-7-5(7)] [326 IAC2-7-19(c)] 

 [326 IAC2-6] 

C.18 General Record Keeping Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-6]

C.19 General Reporting Requirements [326 IAC 2-7-5(3)(C)] [326 IAC 2-1.1-11]

Stratospheric Ozone Protection

C.20 Compliance with 40 CFR 82 and 326 IAC 22-1

D.1. EMISSIONS UNIT OPERATION CONDITIONS----Cupola #2 and #4, Blowchamber #4 and #2, 

 Curing oven #2, #2 line trimming/sizing section and #2 line cooling section

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

D.1.1 Particulate Emission Limitations for Manufacturing Processes [326 IAC 6-3-2] 

D.1.2 PSD Minor Limitations [326 IAC 2-2] 

D.1.3 Preventive Maintenance Plan [326 IAC 2-7-5(13)] 

 

Compliance Determination Requirements 

D.1.4 SO2 emissions Determinations [326 IAC 2-2] 

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

D.1.6 Caustic Injection System Operation [326 IAC 2-7-6(1)] [326 IAC 2-7-5(1)] 

D.1.7 Particulate Matter (PM) 

D.1.8 Particulate Matter (PM) 

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

D.1.9 Visible Emissions Notations

D.1.10 Parametric Monitoring 

D.1.11 Broken or Failed Detection

D.1.12 Monitoring

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

D.1.13 Record Keeping Requirement 

D.1.14 Reporting Requirements 

D.2. EMISSIONS UNIT OPERATION CONDITIONS----- Fiber bond cutting operation EU-P30
Thermafiber, Inc. Wabash Plant First Significant Permit Mod No. 169-27436-00009 Page 4 of 56 

Wabash, Indiana Modified By: Madhurima D. Moulik T169-21103-00009 

Permit Reviewer: Josiah Balogun 

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

D.2.1 PSD Minor Limits [326 IAC 2-2]

D.2.2 Particulate Emission Limitations for Manufacturing Processes [326 IAC 6-3-2] 

D.2.3 Preventive Maintenance Plan [326 IAC 2-7-5(13)]

Compliance Determination Requirements

D.2.4 Particulate Matter 

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

D.2.5 Visible Emissions Notations

D.2.6 Parametric Monitoring 

D.2.7 Broken or Failed Bag Detection

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

D.2.8 Record Keeping Requirement

D.3. EMISSIONS UNIT OPERATION CONDITIONS-----Boiler #1 and Boiler #2

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

D.3.1 Particulate Emission Limitations for Sources of Indirect Heating [326 IAC 6-2-3]

D.3.2 Particulate Emission Limitations for Sources of Indirect Heating [326 IAC 6-2-4] 

D.3.3 General Provision Relating to New Source Perfomance Standards [326 IAC 12-1][40 CFR 60, 

Subpart A] 

D.3.4 Standard of Performance for Small Industrial-Commercial Institutional Steam Generating 

Units [326 IAC 12-1][40 CFR 60, Subpart Dc] 

D.4. EMISSIONS UNIT OPERATION CONDITIONS------ Insignificant Activities

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

D.4.1 Particulate Emission Limitations for Manufacturing Processes [326 IAC 6-3-2] 

D.4.2 Particulate Emission Limitations for Manufacturing Processes [326 IAC 6-3-2]

E.1. EMISSIONS UNIT OPERATION CONDITIONS----Cupola #2, Cupola #4 and Curing Oven #2

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

E.1.1 General Provisions relating to NESHAP Subpart DDD (National Emission Standard for 

Hazardous Air Pollutants for Mineral Wool Production) [326 IAC 20-1-1][40 CFR Part 63, 

Subpart A] 

E.1.2 NESHAP Subpart DDD Requirements [40 CFR 63, Subpart DDD]

Certification

Emergency Occurrence Report

Semi-Annual Natural Gas Fired Boiler Certification 

Part 70 Quarterly Report 

Quarterly Deviation and Compliance Monitoring Report
Thermafiber, Inc. Wabash Plant First Significant Permit Mod No. 169-27436-00009 Page 5 of 56 

Wabash, Indiana Modified By: Madhurima D. Moulik T169-21103-00009 

Permit Reviewer: Josiah Balogun 

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.3 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 stationary Mineral Wool Manufacturing Source. 

Source Address: 3711 Mill Street, Wabash, Indiana 46992 

Mailing Address: 3711 Mill Street, Wabash, IN 46992 

General Source Phone Number: 260-563-2111 

SIC Code: 3296 

County Location: Wabash 

Source Location Status: Attainment for all criteria pollutants 

Source Status: Part 70 Operating Permit Program 

 Major Source, under PSD Rules 

Major Source, Section 112 of the Clean Air Act 

1 of 28 Source Categories 

A.2 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:

 (a) One (1) coke-fueled cupola #2, identified as EU-P2, constructed in 1955, refurbished in 

1995, and modified in 2009, natural gas supplemented, with a maximum capacity of 

10.47 MMBtu/hr, equipped with a 10.0 mmBTU/hr natural gas fired thermal oxidizer EUP2A and a baghouse, exhausting through Stack S1, constructed in 2003, with a 

maximum capacity of 8.5 tons of minerals per hour. 

 (b) One (1) coke-fueled cupola #4, identified as EU-P4, constructed in 1955, and refurbished 

in 1994, and modified in 2009, natural gas supplemented, with a maximum capacity of 

10.47 MMBtu/hr, equipped with a 10.0 mmBTU/hr natural gas fired thermal oxidizer EUP4A, a caustic injection system for control of SO2 emissions, and a baghouse, 

exhausting through Stack S3, constructed in 2003, with a maximum capacity of 9.5 tons 

of minerals per hour. 

 (c) One (1) blowchamber #4, identified as EU-P6, constructed in 1955, equipped with a dry 

media filter, exhausting through Stack S4, constructed in 1992, with a maximum capacity 

of 8.0 tons of fiberized minerals and 0.1 tons of dedusting annealing oil per hour. 

 (d) One (1) natural gas-fired curing oven #2, identified as EU-P7, with a maximum capacity 

of 5.7 million British thermal units per hour, exhausting through Stack S5, constructed in 

1955 and replaced in 1978, with a maximum capacity of 7.0 tons of fiberized minerals per 

hour and emissions controlled by regenerative thermal oxidizer, (RTO) constructed in 

2002. 

 (e) One (1) blowchamber #2, identified as EU-P8, equipped a dry media filter, exhausting 

through Stack S6, constructed in 1955, replaced in 1978 and refurbished in 1999, with a 

maximum capacity of 7.0 tons of fiberized minerals and 1.4 tons of binder and water per 

hour. 
Thermafiber, Inc. Wabash Plant First Significant Permit Mod No. 169-27436-00009 Page 6 of 56 

Wabash, Indiana Modified By: Madhurima D. Moulik T169-21103-00009 

Permit Reviewer: Josiah Balogun 

 (f) One (1) #2 line trimming/sizing section, identified as EU-P9, equipped with a baghouse, 

identified as CE7, exhausting through Stack S7 or inside the building, constructed in 

1955, replaced in 1978, and reconditioned in 2003, with a maximum capacity of 7.0 tons 

of fiberized minerals per hour. 

 (g) One (1) #2 line cooling section, identified as EU-P10, exhausting through Stack S8, 

constructed in 1955, and replaced in 1978, with a maximum capacity of 7.0 tons of 

fiberized minerals per hour. 

 

 (h) One (1) natural gas-fired #1 boiler, identified as EU-P11, with a maximum capacity 12.5 

million British thermal units per hour, exhausting through Stack S9, constructed in 

January 31, 1990. 

 

(i) One (1) fiber bond cutting operation identified as emission unit EU-P30, with a maximum 

capacity of 1600 linear feet of board per hour and 10.4 tons of fiber board per hour, 

originally constructed in 2002 and approved to be modified in 2007, with two (2) cutting 

stations controlled by a fabric filter baghouse, identified as DC-30, exhausting either 

externally through stack S-23 or inside the building. 

A.3 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) (One (1) natural gas-fired boiler, identified as boiler #2, with a maximum at 4.5 million 

British thermal units per hour, exhausting through Stack 10, constructed in 1977 [326 IAC 

6-2-3]; 

(2) The following equipment related to manufacturing activities not resulting in the emission 

of HAPs: brazing equipment, cutting torches, soldering equipment, welding equipment 

[326 IAC 6-3-2]; and 

(3) Conveyors as follows: covered conveyors for coke conveying of maximum capacity 80 

tons of coke per day [326 IAC 6-3-2]. 

A.4 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: 

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

(b) 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). 
Thermafiber, Inc. Wabash Plant First Significant Permit Mod No. 169-27436-00009 Page 7 of 56 

Wabash, Indiana Modified By: Madhurima D. Moulik T169-21103-00009 

Permit Reviewer: Josiah Balogun 

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][326 IAC 2-7-4(a)(1)(D)][IC 13-15-3-6(a)] 

(a) This permit, T169-21103-00009, 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 of this permit or of permits issued pursuant to Title IV of the 

Clean Air Act and 326 IAC 21 (Acid Deposition Control). 

(b) If IDEM, OAQ, upon receiving a timely and complete renewal 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. 

B.3 Term of Conditions [326 IAC 2-1.1-9.5] 

Notwithstanding the permit term of a permit to construct, a permit to operate, or a permit 

modification, any condition established in a permit issued pursuant to a permitting program 

approved in the state implementation plan shall remain in effect until: 

(a) the condition is modified in a subsequent permit action pursuant to Title I of the Clean Air 

Act; or 

(b) the emission unit to which the condition pertains permanently ceases operation. 

B.4 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.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. 
Thermafiber, Inc. Wabash Plant First Significant Permit Mod No. 169-27436-00009 Page 8 of 56 

Wabash, Indiana Modified By: Madhurima D. Moulik T169-21103-00009 

Permit Reviewer: Josiah Balogun 

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 the "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. One (1) certification may cover multiple forms in one (1) 

submittal. 

(c) A "responsible official" is defined at 326 IAC 2-7-1(34). 

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. All certifications shall 

cover the time period from January 1 to December 31 of the previous year, and shall be 

submitted no later than July 1 of each year to: 

Indiana Department of Environmental Management 

Compliance and Enforcement Branch, Office of Air Quality 

100 North Senate Avenue 

MC 61-53 IGCN 1003 

Indianapolis, Indiana 46204-2251 

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 appropriate 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. 
Thermafiber, Inc. Wabash Plant First Significant Permit Mod No. 169-27436-00009 Page 9 of 56 

Wabash, Indiana Modified By: Madhurima D. Moulik T169-21103-00009 

Permit Reviewer: Josiah Balogun 

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 maintain 

and implement Preventive Maintenance Plans (PMPs) including the following information 

on each facility: 

(1) Identification of the individual(s) responsible for inspecting, maintaining, and 

repairing emission control devices; 

(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. 

(b) 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 PMPs do not require the certification by the "responsible official" as 

defined by 326 IAC 2-7-1(34). 

(c) To the extent the Permittee is required by 40 CFR Part 60/63 to have an Operation 

Maintenance, and Monitoring (OMM) 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. 

(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 IDEM, 

OAQ, within four (4) daytime business hours after the beginning of the 

emergency, or after the emergency was discovered or reasonably should have 

been discovered; 

Telephone Number: 1-800-451-6027 (ask for Office of Air Quality, 

Compliance Section), or 

Telephone Number: 317-233-0178 (ask for Compliance Section) 
Thermafiber, Inc. Wabash Plant First Significant Permit Mod No. 169-27436-00009 Page 10 of 56 

Wabash, Indiana Modified By: Madhurima D. Moulik T169-21103-00009 

Permit Reviewer: Josiah Balogun 

Facsimile Number: 317-233-6865 

 (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: 

Indiana Department of Environmental Management 

Compliance and Enforcement Branch, Office of Air Quality 

100 North Senate Avenue 

MC 61-53 IGCN 1003 

Indianapolis, Indiana 46204-2251 

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) The Permittee seeking to establish the occurrence of an emergency shall make records 

available upon request to ensure that failure to implement a PMP did not cause or 

contribute to an exceedance of any limitations on emissions. However, IDEM, OAQ 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 IDEM, OAQ 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 

Monitoring Report. 
Thermafiber, Inc. Wabash Plant First Significant Permit Mod No. 169-27436-00009 Page 11 of 56 

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Permit Reviewer: Josiah Balogun 

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 

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) 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. 

(c) 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. 

(d) 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 

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. 

(e) 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). 

(f) 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)] 

(g) 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)] 
Thermafiber, Inc. Wabash Plant First Significant Permit Mod No. 169-27436-00009 Page 12 of 56 

Wabash, Indiana Modified By: Madhurima D. Moulik T169-21103-00009 

Permit Reviewer: Josiah Balogun 

B.13 Prior Permits Superseded [326 IAC 2-1.1-9.5][326 IAC 2-7-10.5] 

(a) All terms and conditions of permits established prior to T169-21103-00009 and issued 

pursuant to permitting programs approved into the state implementation plan have been 

either: 

(1) incorporated as originally stated, 

(2) revised under 326 IAC 2-7-10.5, or 

(3) deleted under 326 IAC 2-7-10.5. 

(b) Provided that all terms and conditions are accurately reflected in this permit, all previous 

registrations and permits are superseded by this Part 70 operating permit, except for 

permits issued pursuant to Title IV of the Clean Air Act and 326 IAC 21 (Acid Deposition 

Control) 

B.14 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.15 Deviations from Permit Requirements and Conditions [326 IAC 2-7-5(3)(C)(ii)] 

(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 and Enforcement Branch, Office of Air Quality 

100 North Senate Avenue 

MC 61-53 IGCN 1003 

Indianapolis, Indiana 46204-2251 

 

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. 

B.16 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 Operating 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: 
Thermafiber, Inc. Wabash Plant First Significant Permit Mod No. 169-27436-00009 Page 13 of 56 

Wabash, Indiana Modified By: Madhurima D. Moulik T169-21103-00009 

Permit Reviewer: Josiah Balogun 

(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.17 Permit Renewal [326 IAC 2-7-3][326 IAC 2-7-4][326 IAC 2-7-8(e)] 

(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 

Permit Administration and Support Section, Office of Air Quality 

100 North Senate Avenue 

MC 61-53 IGCN 1003 

Indianapolis, Indiana 46204-2251 

 

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

(1) Submitted at least nine (9) months prior to the date of the expiration of this 

permit; and 

(2) 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) 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. 

B.18 Permit Amendment or Modification [326 IAC 2-7-11][326 IAC 2-7-12] [40 CFR 72] 

(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. 
Thermafiber, Inc. Wabash Plant First Significant Permit Mod No. 169-27436-00009 Page 14 of 56 

Wabash, Indiana Modified By: Madhurima D. Moulik T169-21103-00009 

Permit Reviewer: Josiah Balogun 

(b) Pursuant to 326 IAC 2-7-11(b) and 326 IAC 2-7-12(a), administrative Part 70 operating 

permit amendments and permit modifications for purposes of the acid rain portion of a 

Part 70 permit shall be governed by regulations promulgated under Title IV of the Clean 

Air Act. [40 CFR 72] 

(c) Any application requesting an amendment or modification of this permit shall be 

submitted to: 

Indiana Department of Environmental Management 

Permit Administration and Support Section, Office of Air Quality 

100 North Senate Avenue 

MC 61-53 IGCN 1003 

Indianapolis, Indiana 46204-2251 

 

Any such application shall be certified by the "responsible official" as defined by 

326 IAC 2-7-1(34). 

 (d) 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.19 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) 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 

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.20 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 limitations provided in 

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 

Permit Administration and Support Section, Office of Air Quality 

100 North Senate Avenue 
Thermafiber, Inc. Wabash Plant First Significant Permit Mod No. 169-27436-00009 Page 15 of 56 

Wabash, Indiana Modified By: Madhurima D. Moulik T169-21103-00009 

Permit Reviewer: Josiah Balogun 

MC 61-53 IGCN 1003 

Indianapolis, Indiana 46204-2251 

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, on a rolling five (5) year basis, which 

document all such changes and emission trades that are subject to 

326 IAC 2-7-20(b),(c), or (e). The Permittee shall make 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 

(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 emissions increases and decreases at 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. 

(e) Backup fuel switches specifically addressed in, and limited under, Section D of this permit 

shall not be considered alternative operating scenarios. Therefore, the notification 

requirements of part (a) of this condition do not apply. 

(f) This condition does not apply to emission trades of SO2 or NOX under 326 IAC 21 or 

326 IAC 10-4. 
Thermafiber, Inc. Wabash Plant First Significant Permit Mod No. 169-27436-00009 Page 16 of 56 

Wabash, Indiana Modified By: Madhurima D. Moulik T169-21103-00009 

Permit Reviewer: Josiah Balogun 

B.21 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.22 Inspection and Entry [326 IAC 2-7-6][IC 13-14-2-2][IC 13-30-3-1][IC 13-17-3-2] 

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.23 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 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 

Permit Administration and Support Section, Office of Air Quality 

100 North Senate Avenue 

MC 61-53 IGCN 1003 

Indianapolis, Indiana 46204-2251 

 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)] 
Thermafiber, Inc. Wabash Plant First Significant Permit Mod No. 169-27436-00009 Page 17 of 56 

Wabash, Indiana Modified By: Madhurima D. Moulik T169-21103-00009 

Permit Reviewer: Josiah Balogun 

B.24 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, Billing, Licensing, and Training Section), to determine the 

appropriate permit fee. 

B.25 Credible Evidence [326 IAC 2-7-5(3)][326 IAC 2-7-6][62 FR 8314] [326 IAC 1-1-6] 

For the purpose of submitting compliance certifications or establishing whether or not the 

Permittee has violated or is in violation of any condition of this permit, nothing in this permit shall 

preclude the use, including the exclusive use, of any credible evidence or information relevant to 

whether the Permittee would have been in compliance with the condition of this permit if the 

appropriate performance or compliance test or procedure had been performed. 
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Wabash, Indiana Modified By: Madhurima D. Moulik T169-21103-00009 

Permit Reviewer: Josiah Balogun 

SECTION C SOURCE OPERATION CONDITIONS 

Entire Source 

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

C.1 Particulate Emission Limitations For Processes with Process Weight Rates Less Than One 

Hundred (100) Pounds per Hour [326 IAC 6-3-2] 

Pursuant to 326 IAC 6-3-2(e)(2), particulate emissions from any process not exempt under 

326 IAC 6-3-1(b) or (c) which has a maximum process weight rate less than 100 pounds per hour 

and the methods in 326 IAC 6-3-2(b) through (d) do not apply shall not exceed 0.551 pounds per 

hour. 

C.2 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.3 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.

C.4 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.

C.5 Fugitive Dust Emissions [326 IAC 6-4] 

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). 

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 by using ambient air quality 

modeling pursuant to 326 IAC 1-7-4. 

C.7 Asbestos Abatement Projects [326 IAC 14-10] [326 IAC 18] [40 CFR 61, Subpart M] 

(a) Notification requirements apply to each owner or operator. If the combined amount of 

regulated asbestos containing material (RACM) to be stripped, removed or disturbed is at 

least 260 linear feet on pipes or 160 square feet on other facility components, or at least 

thirty-five (35) cubic feet on all facility components, then the notification requirements of 
Thermafiber, Inc. Wabash Plant First Significant Permit Mod No. 169-27436-00009 Page 19 of 56 

Wabash, Indiana Modified By: Madhurima D. Moulik T169-21103-00009 

Permit Reviewer: Josiah Balogun 

326 IAC 14-10-3 are mandatory. All demolition projects require notification whether or 

not asbestos is present. 

(b) The Permittee shall ensure that a written notification is sent on a form provided by the 

Commissioner at least ten (10) working days before asbestos stripping or removal work 

or before demolition begins, per 326 IAC 14-10-3, and shall update such notice as 

necessary, including, but not limited to the following: 

(1) When the amount of affected asbestos containing material increases or 

decreases by at least twenty percent (20%); or 

(2) If there is a change in the following: 

(A) Asbestos removal or demolition start date; 

(B) Removal or demolition contractor; or 

(C) Waste disposal site. 

(c) The Permittee shall ensure that the notice is postmarked or delivered according to the 

guidelines set forth in 326 IAC 14-10-3(2). 

(d) The notice to be submitted shall include the information enumerated in 

326 IAC 14-10-3(3). 

All required notifications shall be submitted to: 

Indiana Department of Environmental Management 

Compliance and Enforcement Branch, Office of Air Quality 

100 North Senate Avenue 

MC 61-52 IGCN 1003 

Indianapolis, Indiana 46204-2251 

The notice shall include a signed certification from the owner or operator that the 

information provided in this notification is correct and that only Indiana licensed workers 

and project supervisors will be used to implement the asbestos removal project. The 

notifications do not require a certification by the "responsible official" as defined by 

326 IAC 2-7-1(34). 

(e) Procedures for Asbestos Emission Control 

The Permittee shall comply with the applicable emission control procedures in 

326 IAC 14-10-4 and 40 CFR 61.145(c). Per 326 IAC 14-10-1, emission control 

requirements are applicable for any removal or disturbance of RACM greater than three 

(3) linear feet on pipes or three (3) square feet on any other facility components or a total 

of at least 0.75 cubic feet on all facility components. 

(f) Demolition and Renovation 

The Permittee shall thoroughly inspect the affected facility or part of the facility where the 

demolition or renovation will occur for the presence of asbestos pursuant to 

40 CFR 61.145(a). 

(g) Indiana Accredited Asbestos Inspector 

The Permittee shall comply with 326 IAC 14-10-1(a) that requires the owner or operator, 

prior to a renovation/demolition, to use an Indiana Accredited Asbestos Inspector to 

thoroughly inspect the affected portion of the facility for the presence of asbestos. The 

requirement to use an Indiana Accredited Asbestos inspector is not federally enforceable. 
Thermafiber, Inc. Wabash Plant First Significant Permit Mod No. 169-27436-00009 Page 20 of 56 

Wabash, Indiana Modified By: Madhurima D. Moulik T169-21103-00009 

Permit Reviewer: Josiah Balogun 

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 and Enforcement Branch, Office of Air Quality 

100 North Senate Avenue 

MC 61-53 IGCN 1003 

Indianapolis, Indiana 46204-2251 

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 Permittee 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. 

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 and Enforcement Branch, Office of Air Quality 

100 North Senate Avenue 

MC 61-53 IGCN 1003 

Indianapolis, Indiana 46204-2251 
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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 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.12 Instrument Specifications [326 IAC 2-1.1-11] [326 IAC 2-7-5(3)] [326 IAC 2-7-6(1)] 

(a) When required by any condition of this permit, an analog instrument used to measure a 

parameter related to the operation of an air pollution control device shall have a scale 

such that the expected maximum reading for the normal range shall be no less than 

twenty percent (20%) of full scale. 

(b) The Permittee may request that the IDEM, OAQ approve the use of an instrument that 

does not meet the above specifications provided the Permittee can demonstrate that an 

alternative instrument specification will adequately ensure compliance with permit 

conditions requiring the measurement of the parameters. 

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

C.13 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 prepared and submitted written emergency reduction plans (ERPs) 

consistent with safe operating procedures on. 

(b) Upon direct notification by IDEM, OAQ that a specific air pollution episode level is in 

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.14 Risk Management Plan [326 IAC 2-7-5(12)] [40 CFR 68] 

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.15 Response to Excursions or Exceedances [326 IAC 2-7-5] [326 IAC 2-7-6] 

(a) Upon detecting an excursion or exceedance, the Permittee shall restore operation of the 

emissions unit (including any control device and associated capture system) to its normal 

or usual manner of operation as expeditiously as practicable in accordance with good air 

pollution control practices for minimizing emissions. 

(b) The response shall include minimizing the period of any startup, shutdown or malfunction 

and taking any necessary corrective actions to restore normal operation and prevent the 

likely recurrence of the cause of an excursion or exceedance (other than those caused by 

excused startup or shutdown conditions). Corrective actions may include, but are not 

limited to, the following: 

(1) initial inspection and evaluation; 
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(2) recording that operations returned to normal without operator action (such as 

through response by a computerized distribution control system); or 

(3) any necessary follow-up actions to return operation to within the indicator range, 

designated condition, or below the applicable emission limitation or standard, as 

applicable. 

(c) A determination of whether the Permittee has used acceptable procedures in response to 

an excursion or exceedance will be based on information available, which may include, 

but is not limited to, the following: 

(1) monitoring results; 

(2) review of operation and maintenance procedures and records; and/or 

(3) inspection of the control device, associated capture system, and the process. 

(d) Failure to take reasonable response steps shall be considered a deviation from the 

permit. 

(e) The Permittee shall maintain the following records: 

(1) monitoring data; 

(2) monitor performance data, if applicable; and 

(3) corrective actions taken. 

C.16 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 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). 

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

C.17 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) Pursuant to 326 IAC 2-6-3(a)(1), the Permittee shall submit by July 1 of each year an 

emission statement covering the previous calendar year. The emission statement shall 

contain, at a minimum, the information specified in 326 IAC 2-6-4(c) and shall meet the 

following requirements: 

(1) Indicate estimated actual emissions of all pollutants listed in 326 IAC 2-6-4(a); 
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(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 purpose of fee assessment. 

 The statement must be submitted to: 

Indiana Department of Environmental Management 

Technical Support and Modeling Section, Office of Air Quality 

100 North Senate Avenue 

MC 61-50 IGCN 1003 

Indianapolis, Indiana 46204-2251 

The emission statement does require the certification by the “responsible official” as 

defined by 326 IAC 2-7-1(34). 

(b) The 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.18 General Record Keeping Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-6][326 IAC 2-2] 

(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) If there is a “project” (as defined in 326 IAC 2-2-1 (qq) and 326 IAC 2-3-1(ll)) at an 

existing emissions unit, other than projects at a Clean Unit, which is not part of a “major 

modification” (as defined in 326 IAC 2-2-1 (ee) and 326 IAC 2-3-1 (z)) may result in 

significant emissions increase and the Permittee elects to utilize the “projected actual 

emissions” (as defined in 326 IAC 2-2-1 (rr) and 326 IAC 2-3-1 (mm)), the Permittee shall 

comply with following: 

(1) Before beginning actual construction of the “project” (as defined in 326 IAC 2-2-1 

(qq) and 326 IAC 2-3-1 (ll)) at an existing emissions unit, document and maintain 

the following records: 

(A) A description of the project. 

(B) Identification of any emissions unit whose emissions of a regulated new 

source review pollutant could be affected by the project. 

(C) A description of the applicability test used to determine that the project is 

not a major modification for any regulated NSR pollutant, including: 

(i) Baseline actual emissions; 
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(ii) Projected actual emissions; 

(iii) Amount of emissions excluded under section 

 326 IAC 2-2-1(rr)(2)(A)(iii) and 326 IAC 2-3-1(mm)(2)(A)(3); and 

(iv) An explanation for why the amount was excluded, and any 

netting calculations, if applicable. 

(2) Monitor the emissions of any regulated NSR pollutant that could increase as a 

result of the project and that is emitted by any existing emissions unit identified in 

(1)(B) above; and 

(3) Calculate and maintain a record of the annual emissions, in tons per year on a 

calendar year basis, for a period of five (5) years following resumption of regular 

operations after the change, or for a period of ten (10) years following resumption 

of regular operations after the change if the project increases the design capacity 

of or the potential to emit that regulated NSR pollutant at the emissions unit. 

C.19 General Reporting Requirements [326 IAC 2-7-5(3)(C)] [326 IAC 2-1.1-11] 

(a) The Permittee 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). 

(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 and Enforcement Branch, Office of Air Quality 

100 North Senate Avenue 

MC 61-53 IGCN 1003 

Indianapolis, Indiana 46204-2251 

 (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) Reporting periods are based on calendar years, unless otherwise specified in this permit. 

For the purpose of this permit “calendar year” means the twelve (12) month period from 

January 1 to December 31 inclusive. 
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Stratospheric Ozone Protection 

C.20 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 EMISSIONS UNIT OPERATION CONDITIONS 

Emissions Unit Description: 

 

 (a) One (1) coke-fueled cupola #2, identified as EU-P2, constructed in 1955, refurbished 

in 1995, and modified in 2009, natural gas supplemented, with a maximum capacity of 

10.47 MMBtu/hr, equipped with a 10.0 mmBTU/hr natural gas fired thermal oxidizer 

EU-P2A and a baghouse, exhausting through Stack S1, constructed in 2003, with a 

maximum capacity of 8.5 tons of minerals per hour. 

(b) One (1) coke-fueled cupola #4, identified as EU-P4, constructed in 1955, and 

refurbished in 1994, and modified in 2009, natural gas supplemented, with a maximum 

capacity of 10.47 MMBtu/hr, equipped with a 10.0 mmBTU/hr natural gas fired thermal 

oxidizer EU-P4A, a caustic injection system for control of SO2 emissions, and a 

baghouse, exhausting through Stack S3, constructed in 2003, with a maximum 

capacity of 9.5 tons of minerals per hour. 

 (c) One (1) blowchamber #4, identified as EU-P6, constructed in 1955, equipped with a 

dry media filter, exhausting through Stack S4, constructed in 1992, with a maximum 

capacity of 8.0 tons of fiberized minerals and 0.1 tons of dedusting annealing oil per 

hour; 

 (d) One (1) natural gas-fired curing oven #2, identified as EU-P7, with a maximum 

capacity of 5.7 million British thermal units per hour, exhausting through Stack S5, 

constructed in 1955 and replaced in 1978, with a maximum capacity of 7.0 tons of 

fiberized minerals per hour and emissions controlled by regenerative thermal oxidizer, 

(RTO), constructed in 2002. 

 

 (e) One (1) blowchamber #2, identified as EU-P8, equipped a dry media filter, exhausting 

through Stack S6, constructed in 1955, replaced in 1978 and refurbished in 1999, with 

a maximum capacity of 7.0 tons of fiberized minerals and 1.4 tons of binder and water 

per hour; 

 (f) One (1) #2 line trimming/sizing section, identified as EU-P9, equipped with a 

baghouse, identified as CE7, exhausting through Stack S7 or inside the building, 

constructed in 1955, replaced in 1978, and reconditioned in 2003, with a maximum 

capacity of 7.0 tons of fiberized minerals per hour; and 

 (g) One (1) #2 line cooling section, identified as EU-P10, exhausting through Stack S8, 

constructed in 1955, and replaced in 1978, with a maximum capacity of 7.0 tons of 

fiberized minerals per hour. 

 

(The information describing the process contained in this emissions unit description box is descriptive 

information and does not constitute enforceable conditions.) 

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

D.1.1 Particulate Emission Limitations for Manufacturing Processes [326 IAC 6-3-2] 

 Pursuant to 326 IAC 6-3-2(e), (Particulate Emission Limitations for Manufacturing Processes), 

 the allowable particulate matter emissions from the two (2) blowchambers, identified as EU-P6 

 and EU-P8, line trimmings/sizing section, identified as EU-P9 and #2 Line cooling section, 

 identified as EU-P10, shall not exceed the emission limit shown in the table below: 

 
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Operation Process weight 

(tons/hr) 

Allowable Limits 

(lbs/hr) 

Blowchamber #4 EU-P6 8.1 16.7 

Blowchamber #2 EU-P8 8.4 17.1 

Line trimming/sizing 

section #2 EU-P9 

7.0 15.1 

#2 Line cooling section 

EU-P10 

7.0 15.1 

 Interpolation of the data for the process weight rate up to sixty thousand (60,000) pounds per 

 hour was determined by use of the equation: 

 

 E = 4.10 x P 0.67

 

 Where: 

 P = process weight in tons/hr; and 

 E = rate of emission in pounds per hour. 

D.1.2 PSD Minor Limitations [326 IAC 2-2] 

 In order to render the requirements of 326 IAC 2-2 not applicable, the Permittee shall comply with 

the following: 

 The production in tons and the SO2 emission rates at Cupola #2 and Cupola #4 shall be limited 

such that the total SO2 emissions from Cupola #2 and Cupola #4 and the thermal oxidizers EUP2A and EU-P4A shall be less than 620 tons per twelve (12) consecutive month period, with 

compliance determined at the end of each month in accordance with Condition D.1.4. 

 Compliance with this limit shall ensure that the increase in SO2 emissions from the modification 

of Cupola #2 and Cupola #4 involving the addition of the thermal oxidizers EU-P2A and EU-P4A 

is limited to less than 40 tons per twelve (12) consecutive month period, and shall render 326 IAC 

2-2 not applicable. 

D.1.3 Preventive Maintenance Plan [326 IAC 2-7-5(13)] 

 A Preventative Maintenance Plan, in accordance with Section B - Preventive Maintenance Plan 

 of this permit, is required for these facilities and their control devices. 

Compliance Determination Requirements 

D.1.4 SO2 emissions Determinations [326 IAC 2-2] 

 Compliance with Condition D.1.2 shall be determined as follows: 

(a) SO2 emissions from EU-P2A and EU-P4A shall be calculated using the following 

equation: 

 E = [(EF2U x P2U) + (EF4U x P4U) + (EF4C x P4C)] x 1/2000 Eq. 1 

 Where: 

 E = emissions in tons per month 

 EF = SO2 emission factor in lb/ton [2U = uncontrolled Cupola 2/EU-P2A, 4U = 

uncontrolled Cupola 4/EU-P4A, 4C = controlled (scrubber) Cupola 4/EU-P4A] 

 P = monthly cupola production in tons 
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(b) Until stack test results become available, compliance shall be determined by using the 

following emission factors in Equation 1: EF2U = 16.43 lb/ton; EF4U = 15.86 lb/ton, EF4C

=4.76 lb/ton. After results from the stack tests become available, compliance shall be 

determined by using the emission factors determined in the latest stack test. 

 

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

 In order to demonstrate compliance with Condition D.1.2, the following shall apply: 

(a) Within sixty (60) days after achieving maximum capacity but no later than one hundred 

eighty (180) days after initial startup of EU-P2A and EU-P4B, the Permittee shall conduct 

performance tests on EU-P2A (uncontrolled only) and EU-P4A (controlled and 

uncontrolled) to verify the emission factors for SO2 emissions, utilizing methods as 

approved by the Commissioner. 

(b) These tests shall be repeated at least once every five (5) years from the date of the most 

recent valid compliance demonstration. 

(c) Testing shall be conducted in accordance with Section C – Performance Testing. 

D.1.6 Caustic Injection System Operation [326 IAC 2-7-6(1)] [326 IAC 2-7-5(1)] 

Except as provided by statute, rule, or this permit, the caustic injection system shall be operated 

as needed to maintain compliance with all SO2 emission limits. 

D.1.7 Particulate Matter (PM) 

 (a) In order to comply with Condition D.1.1, the baghouses for particulate control shall be 

 in operation at all times when the #2 line trimming/size section are in operation. 

 

(b) In the event that bag failure is observed in a multi-compartment baghouse, if operations 

will continue for ten (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. 

D.1.8 Particulate Matter (PM) 

(a) Inorder to comply with Condition D.1.1, the media dry filters for particulate control shall be 

 in operation at all times when the two (2) blowchambers, identified as EU-P6 and EU-P8 

 are in operation. 

 

 (b) In the event that filter failure is observed in a multi-compartment media dry filter, if 

 operations will continue for ten (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 inclued 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. 

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

D.1.9 Visible Emissions Notations 

(a) Visible emission notations of the two (2) blowerchambers, identified as EU-P6 and EUP8, line trimmings/sizing section, identified as EU-P9 and #2 line cooling section, 

 identified as EU-P10 stack exhausts shall be performed once per day during normal 

daylight operations when exhausting to the atmosphere. A trained employee shall record 

whether emissions are normal or abnormal. 
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(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 normal visible emissions 

for that specific process. 

(e) If abnormal emissions are observed, the Permittee shall take reasonable response steps 

in accordance with Section C - Response to Excursions or Exceedances. Failure to take 

response steps in accordance with Section C - Response to Excursions or Exceedances 

shall be considered a deviation from this permit. 

 

 The instrument used for determining the pressure shall comply with Section C - 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.1.10 Parametric Monitoring 

(a) The Permittee shall record the pressure drop across the baghouse used in conjunction 

with the #2 line trimming/sizing section, at least once per day when the #2 line 

trimming/sizing section is in operation when exhausting to the atmosphere. When for any 

one reading, the pressure drop across the baghouse are outside the normal range of 1.2 

and 6.0 inches of water or a range established during the latest stack test, the Permittee 

shall take reasonable response steps in accordance with Section C- Response to 

Excursions and Exceedances. A pressure reading that is outside the above mentioned 

range is not a deviation from this permit. Failure to take response steps in accordance 

with Section C - Response to Excursions and Exceedances shall be considered deviation 

from the permit. 

(b) The Permittee shall record the caustic injection rate used in conjunction with the Cupola 

#4, at least once per day when the Cupola #4 is in operation when exhausting to the 

atmosphere. When for any one reading, the injection rate is below the normal range of 

200-600 pounds of dry sorbent per hour or as established during the latest stack test, the 

Permittee shall take reasonable response steps in accordance with Section C- Response 

to Excursions and Exceedances. An injection rate that is outside the above mentioned 

range is not a deviation from this permit. Failure to take response steps in accordance 

with Section C - Response to Excursions and Exceedances shall be considered deviation 

from the permit. 

The instruments used for determining the pressure and caustic injection rate shall comply with 

Section C - 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.1.11 Broken or Failed Bag Detection 

(a) For a single compartment baghouse controlling emissions from a process operated 

continuously, a failed unit and the associated process shall be shut down immediately 

until the failed unit has been repaired or replaced. 

(b) For a single compartment baghouse controlling emissions from a batch process, the feed 

to the process shall be shut down immediately until the failed unit has been repaired or 

replaced. The emissions unit shall be shut down no later than the completion of the 
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processing of the material in the emissions unit. 

Bag failure can be indicated by a significant drop in the baghouse's pressure reading with 

abnormal visible emissions, by an opacity violation, or by other means such as gas temperature, 

flow rate, air infiltration, leaks, or dust traces. 

D.1.12 Monitoring 

(a) Daily inspections shall be performed to verify the placement, integrity and particle loading 

of the dry media filters. To monitor the performance of the dry media filters, weekly 

observations shall be made of the particulate matter from the blowchamber stacks S4 

and S6 while one or more of the blowchambers are in operation. If a condition exists 

which should result in a response step, the Permittee shall take reasonable response 

steps in accordance with section C- Response to Excursions or Exceedances. Failure to 

take response steps in accordance with Section C-Response to Excursions or 

Exceedances, shall be considered a deviation from this permit. 

(b) Monthly inspections shall be performed of the blowchamber emissions from the stacks 

and the particulate matter on the rooftops and the nearby ground. when there is a 

noticeable change in particulate matter emissions, or when evidence of particulate matter 

emission is observed, the Permittee shall take reasonable response steps in accordance 

with section C- Response to Excursions or Exceedances. Failure to take response steps 

in accordance with Section C - Response to Excursions or Exceedances, shall be 

considered a deviation from this permit. 

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

D.1.13 Record Keeping Requirements 

(a) To document compliance with Condition D.1.9, the Permittee shall maintain daily records 

of the visible emission notations of the two (2) blowchambers, identified as EU-P6 and 

EU-P8, line trimmings/sizing section, identified as EU-P9 and #2 line cooling section, 

 identified as EU-P10 stack exhaust. The Permittee shall include in its daily record when a 

visible emission notation is not taken and the reason for the lack of a visible emission 

notation, (e.g. the process did not operate that day).

 

(b) To document compliance with Condition D.1.10 the Permittee shall maintain the 

 daily records of the pressure drop across the baghouse controlling the #2 line 

 trimming/sizing section. The Permittee shall include in its daily record when a pressure 

 drop reading is not taken and the reason for the lack of a pressure drop reading, (e.g. the 

 process did not operate that day). 

 (c) To document compliance with Condition D.1.12, the Permittee shall maintain a log of 

 weekly particulate observations, and daily and monthly inspection of the filters. 

(d) To document compliance with Condition D.1.12, the Permittee shall maintain daily 

records of the caustic injection rate controlling Cupola #4. The Permittee shall include in 

its daily record when a reading is not taken and the reason for the lack of a reading, (e.g. 

the process did not operate that day). 

 

 (e) All records shall be maintained in accordance with Section C - General Record Keeping 

 Requirements of this permit. 

D.1.14 Reporting Requirements 

A quarterly summary of the information to document compliance with Condition D.1.2(a) 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 their equivalent, within thirty (30) 
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Permit Reviewer: Josiah Balogun 

days after the end of the quarter being reported. The 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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Wabash, Indiana Modified By: Madhurima D. Moulik T169-21103-00009 

Permit Reviewer: Josiah Balogun 

SECTION D.2 EMISSIONS UNIT OPERATION CONDITIONS 

Emissions Unit Description: 

 

(i) One (1) fiber bond cutting operation identified as emission unit EU-P30, with a 

maximum capacity of 1600 linear feet of board per hour and 10.4 tons of fiber board 

per hour, originally constructed in 2002 and approved to be modified in 2007, with two 

(2) cutting stations controlled by a fabric filter baghouse, identified as DC-30, 

exhausting either externally through stack S-23 or inside the building. 

(The information describing the process contained in this emissions unit description box is descriptive 

information and does not constitute enforceable conditions.) 

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

D.2.1 PSD Minor Limits [326 IAC 2-2] 

Pursuant to SSM 169-24879-00009, issued on September 18, 2007: 

(a) The PM emissions from the fiber bond cutting, identified as unit EU-P30 shall be less 

than 5.7 pounds per hour. Compliance with this limit will limit the PM emissions to less 

than twenty-five (25) tons per year and render the requirements of 326 IAC 2-2 (PSD) not 

applicable to 2002 modification. 

(b) The PM10 emissions from the fiber bond cutting, identified as unit EU-P30 shall be less 

than 3.42 pounds per hour. Compliance with this limit will limit the PM10 emissions to less 

than fifteen (15) tons per year and render the requirements of 326 IAC 2-2 (PSD) not 

applicable to 2002 modification. 

D.2.2 Particulate Emission Limitations for Manufacturing Processes [326 IAC 6-3-2] 

Pursuant to 326 IAC 6-3-2, the particulate matter (PM) from the fiber bond cutting operation, 

identified as EU-P30 shall not exceed 19.7 pounds per hour when operating at a process weight 

rate of 10.4 tons per hour. The pound per hour limitation was calculated with the following 

equation: 

Interpolation of the data for the process weight rate up to sixty thousand (60,000) pounds per 

hour shall be accomplished by use of the equation: 

 E = 4.10 P 0.67 

 Where: 

 E = rate of emission in pounds per hour and 

 P = process weight rate in tons per hour 

D.2.3 Preventive Maintenance Plan [326 IAC 2-7-5(13)] 

 A Preventive Maintenance Plan (PMP), in accordance with Section B - Preventive Maintenance 

 Plan, of this permit, is required for the fiber bond cutting operation (EU-P30) and its control 

 device. 
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Permit Reviewer: Josiah Balogun 

Compliance Determination Requirements 

D.2.4 Particulate Matter (PM) 

(a) Inorder to comply with Conditions D.2.1 and D.2.2, the baghouses for PM control shall be 

 in operation at all times when the fiber bond cutting operation (EU-P30) is in operation. 

 

 (b) In the event that bag failure is observed in a multi-compartment baghouse, if operations 

 will continue for ten (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. 

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

D.2.5 Visible Emissions Notations 

(a) Visible emission notations of the fiber bond cutting operation stack exhaust (stack S23) 

shall be performed once per day during normal daylight operations when exhausting to 

the atmosphere. A trained employee shall record whether emissions are normal or 

abnormal. 

(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 normal visible emissions 

for that specific process. 

(e) If abnormal emissions are observed, the Permittee shall take reasonable response steps 

in accordance with Section C - Response to Excursions or Exceedances. Failure to take 

response steps in accordance with Section C - Response to Excursions or Exceedances 

shall be considered a deviation from this permit. 

D.2.6 Parametric Monitoring 

 The Permittee shall record the pressure drop across the baghouse used in conjunction with the 

fiber bond cutting (EU-P30) operations, at least once per day when the fiber bond cutting (EUP30) operation is in operation when exhausting to the atmosphere. When for any one reading, the 

pressure drop across the baghouse are outside the normal range of 1.0 and 7.0 inches of water 

or a range established during the latest stack test, the Permittee shall take reasonable response 

steps in accordance with Section C- Response to Excursions and Exceedances. A pressure 

reading that is outside the above mentioned range is not a deviation from this permit. Failure to 

take response steps in accordance with Section C - Response to Excursions and Exceedances 

shall be considered deviation from the permit. 

The instrument used for determining the pressure shall comply with Section C - Instrument 

Specifications, of this permit, shall be subject to approval by IDEM, OAQ, and shall be calibrated 

at least once every six (6) months. 
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Permit Reviewer: Josiah Balogun 

D.2.7 Broken or Failed Bag Detection 

(a) For a single compartment baghouse controlling emissions from a process operated 

continuously, a failed unit and the associated process shall be shut down immediately 

until the failed unit has been repaired or replaced. 

(b) For a single compartment baghouse controlling emissions from a batch process, the feed 

to the process shall be shut down immediately until the failed unit has been repaired or 

replaced. The emissions unit shall be shut down no later than the completion of the 

processing of the material in the emissions unit. 

Bag failure can be indicated by a significant drop in the baghouse's pressure reading with 

abnormal visible emissions, by an opacity violation, or by other means such as gas temperature, 

flow rate, air infiltration, leaks, or dust traces. 

Record Keeping and Reporting Requirements [326 IAC 2-8-4(3)] 

D.2.8 Record Keeping Requirements 

(a) To document compliance with Condition D.2.5, the Permittee shall maintain daily records 

of the visible emission notations of the fiber bond cutting (EU-P30) operations stack 

exhaust. The Permittee shall include in its daily record when a visible emission notation is 

not taken and the reason for the lack of a visible emission notation, (e.g. the process did 

not operate that day).

(b) To document compliance with Condition D.2.6 the Permittee shall maintain the 

 daily records of the pressure drop across the baghouse controlling the fiber bond cutting 

 (EU-P30) operations. The Permittee shall include in its daily record when a pressure drop 

 reading is not taken and the reason for the lack of a pressure drop reading, (e.g. the 

 process did not operate that day). 

 (c) All records shall be maintained in accordance with Section C - General Record Keeping 

 Requirements of this permit. 
Thermafiber, Inc. Wabash Plant First Significant Permit Mod No. 169-27436-00009 Page 35 of 56 

Wabash, Indiana Modified By: Madhurima D. Moulik T169-21103-00009 

Permit Reviewer: Josiah Balogun 

SECTION D.3 EMISSIONS UNIT OPERATION CONDITIONS 

Emissions Unit Description: Boilers 

 

 (h) One (1) natural gas-fired #1 boiler, identified as EU-P11, with a maximum capacity 

12.5 million British thermal units per hour, exhausting through Stack S9, constructed in 

January 31, 1990; and 

(i) (One (1) natural gas-fired boiler, identified as boiler #2, with a maximum at 4.5 million 

British thermal units per hour, exhausting through Stack 10, constructed in 1977 [326 

IAC 6-2]. This boiler is an Insignificant activity. 

(The information describing the process contained in this emissions unit 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 (Particulate Emission Limitations for Sources of Indirect Heating) 

[326 IAC 6-2-3] 

Pursuant to 326 IAC 6-2-3(e), particulate matter (PM) emissions from Boiler #2 shall not exceed 

 0.6 pounds of PM per million British thermal units. 

 

D.3.2 Particulate Matter (Particulate Emission Limitations for Sources of Indirect Heating) 

 [326 IAC 6-2-4] 

Pursuant to 326 IAC 6-2-4, particulate matter (PM) emissions from the #1 Boiler, identified as EU-

 P11 shall not exceed 0.522 pounds of PM per million British thermal units. 

 

 The limits were calculated using the equation below: 

 Pt = 1.09

 Q0.26

 Where: 

 

 Pt = Pounds of particulate matter emitted per million Btu (lb/MMBtu) heat 

input; and 

 

 Q = Total source maximum operating capacity (MMBtu/hr) = 17 MMBtu/hr for 

#1 Boiler, identified as EU-P11. 

D.3.3 General Provision Relating to New Source Performance Standards [326 IAC 12-1] [40 CFR 60, 

Subpart A] 

(a) Pursuant to 40 CFR 60.1, the Permittee shall comply with the provisions of 40 CFR Part 

60 Subpart A – General Provisions, which are incorporated by reference as 326 IAC 12-1 

for the #1 Boiler, identified as EU-P11 except as otherwise specified in 40 CFR Part 60, 

Subpart Dc. 

(b) Pursuant to 40 CFR 60.10, the Permittee shall submit all required notifications and 

reports to: 

Indiana Department of Environmental Management 

Compliance Branch, Office of Air Quality 

100 North Senate Avenue, 

MC 61-53 IGCN 1003 

Indianapolis, Indiana 46204-2251 
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D.3.4 Standard of Performance for Small Industrial-Commercial Institutional Steam Generating Units 

[326 IAC 12-1] [40 CFR 60, Subpart Dc] 

 Pursuant to 40 CFR 60 Subpart Dc, the Permittee shall comply with the provisions of Standard of 

 Performance for Small Industrial-Commercial Institutional Steam Generating Units for the #1 

 Boiler, identified as EU-P11 as specified as follows: 

§ 60.40c Applicability and delegation of authority.

(a) Except as provided in paragraph (d) of this section, the affected facility to which this subpart 

applies is each steam generating unit for which construction, modification, or reconstruction is 

commenced after June 9, 1989 and that has a maximum design heat input capacity of 29 

megawatts (MW) (100 million Btu per hour (Btu/hr)) or less, but greater than or equal to 2.9 MW 

(10 million Btu/hr). 

 (b) In delegating implementation and enforcement authority to a State under section 111(c) 

 of the Clean Air Act, §60.48c(a)(4) shall be retained by the Administrator and not 

 transferred to a State. 

 Facility covered by an EPA approved State or Federal section 111(d)/129 plan implementing 

 subpart BBBB of this part is not covered by this subpart. 

[55 FR 37683, Sept. 12, 1990, as amended at 61 FR 20736, May 8, 1996; 71 FR 9884, Feb. 27, 

2006] 

§ 60.41c Definitions. 

As used in this subpart, all terms not defined herein shall have the meaning given them in the 

Clean Air Act and in subpart A of this part. 

Annual capacity factor means the ratio between the actual heat input to a steam generating unit 

from an individual fuel or combination of fuels during a period of 12 consecutive calendar months 

and the potential heat input to the steam generating unit from all fuels had the steam generating 

unit been operated for 8,760 hours during that 12-month period at the maximum design heat input 

capacity. In the case of steam generating units that are rented or leased, the actual heat input 

shall be determined based on the combined heat input from all operations of the affected facility 

during a period of 12 consecutive calendar months. 

Coal means all solid fuels classified as anthracite, bituminous, subbituminous, or lignite by the 

American Society of Testing and Materials in ASTM D388–77, 90, 91, 95, or 98a, Standard 

Specification for Classification of Coals by Rank (IBR—see §60.17), coal refuse, and petroleum 

coke. Coal-derived synthetic fuels derived from coal for the purposes of creating useful heat, 

including but not limited to solvent refined coal, gasified coal, coal-oil mixtures, and coal-water 

mixtures, are also included in this definition for the purposes of this subpart. 

Coal refuse means any by-product of coal mining or coal cleaning operations with an ash content 

greater than 50 percent (by weight) and a heating value less than 13,900 kilojoules per kilogram 

(kJ/kg) (6,000 Btu per pound (Btu/lb) on a dry basis. 

Cogeneration steam generating unit means a steam generating unit that simultaneously produces 

both electrical (or mechanical) and thermal energy from the same primary energy source. 

Combined cycle system means a system in which a separate source (such as a stationary gas 

turbine, internal combustion engine, or kiln) provides exhaust gas to a steam generating unit. 
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Combustion research means the experimental firing of any fuel or combination of fuels in a steam 

generating unit for the purpose of conducting research and development of more efficient 

combustion or more effective prevention or control of air pollutant emissions from combustion, 

provided that, during these periods of research and development, the heat generated is not used 

for any purpose other than preheating combustion air for use by that steam generating unit (i.e., 

the heat generated is released to the atmosphere without being used for space heating, process 

heating, driving pumps, preheating combustion air for other units, generating electricity, or any 

other purpose). 

Conventional technology means wet flue gas desulfurization technology, dry flue gas 

desulfurization technology, atmospheric fluidized bed combustion technology, and oil 

hydrodesulfurization technology. 

Distillate oil means fuel oil that complies with the specifications for fuel oil numbers 1 or 2, as 

defined by the American Society for Testing and Materials in ASTM D396–78, 89, 90, 92, 96, or 

98, “Standard Specification for Fuel Oils” (incorporated by reference—see §60.17). 

Dry flue gas desulfurization technology means a sulfur dioxide (SO2) control system that is 

located between the steam generating unit and the exhaust vent or stack, and that removes sulfur 

oxides from the combustion gases of the steam generating unit by contacting the combustion 

gases with an alkaline slurry or solution and forming a dry powder material. This definition 

includes devices where the dry powder material is subsequently converted to another form. 

Alkaline reagents used in dry flue gas desulfurization systems include, but are not limited to, lime 

and sodium compounds. 

Duct burner means a device that combusts fuel and that is placed in the exhaust duct from 

another source (such as a stationary gas turbine, internal combustion engine, kiln, etc.) to allow 

the firing of additional fuel to heat the exhaust gases before the exhaust gases enter a steam 

generating unit. 

Emerging technology means any SO2 control system that is not defined as a conventional 

technology under this section, and for which the owner or operator of the affected facility has 

received approval from the Administrator to operate as an emerging technology under 

§60.48c(a)(4). 

Federally enforceable means all limitations and conditions that are enforceable by the 

Administrator, including the requirements of 40 CFR Parts 60 and 61, requirements within any 

applicable State implementation plan, and any permit requirements established under 40 CFR 

52.21 or under 40 CFR 51.18 and 40 CFR 51.24. 

Fluidized bed combustion technology means a device wherein fuel is distributed onto a bed (or 

series of beds) of limestone aggregate (or other sorbent materials) for combustion; and these 

materials are forced upward in the device by the flow of combustion air and the gaseous products 

of combustion. Fluidized bed combustion technology includes, but is not limited to, bubbling bed 

units and circulating bed units. 

Fuel pretreatment means a process that removes a portion of the sulfur in a fuel before 

combustion of the fuel in a steam generating unit. 

Heat input means heat derived from combustion of fuel in a steam generating unit and does not 

include the heat derived from preheated combustion air, recirculated flue gases, or exhaust gases 

from other sources (such as stationary gas turbines, internal combustion engines, and kilns). 
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Permit Reviewer: Josiah Balogun 

Heat transfer medium means any material that is used to transfer heat from one point to another 

point. 

Maximum design heat input capacity means the ability of a steam generating unit to combust a 

stated maximum amount of fuel (or combination of fuels) on a steady state basis as determined 

by the physical design and characteristics of the steam generating unit. 

Natural gas means (1) a naturally occurring mixture of hydrocarbon and nonhydrocarbon gases 

found in geologic formations beneath the earth's surface, of which the principal constituent is 

methane, or (2) liquefied petroleum (LP) gas, as defined by the American Society for Testing and 

Materials in ASTM D1835–86, 87, 91, or 97, “Standard Specification for Liquefied Petroleum 

Gases” (incorporated by reference—see §60.17). 

Noncontinental area means the State of Hawaii, the Virgin Islands, Guam, American Samoa, the 

Commonwealth of Puerto Rico, or the Northern Mariana Islands. 

Oil means crude oil or petroleum, or a liquid fuel derived from crude oil or petroleum, including 

distillate oil and residual oil. 

Potential sulfur dioxide emission rate means the theoretical SO2emissions (nanograms per joule 

[ng/J], or pounds per million Btu [lb/million Btu] heat input) that would result from combusting fuel 

in an uncleaned state and without using emission control systems. 

Process heater means a device that is primarily used to heat a material to initiate or promote a 

chemical reaction in which the material participates as a reactant or catalyst. 

Residual oil means crude oil, fuel oil that does not comply with the specifications under the 

definition of distillate oil, and all fuel oil numbers 4, 5, and 6, as defined by the American Society 

for Testing and Materials in ASTM D396–78, 89, 90, 92, 96, or 98, “Standard Specification for 

Fuel Oils” (incorporated by reference—see §60.17). 

Steam generating unit means a device that combusts any fuel and produces steam or heats 

water or any other heat transfer medium. This term includes any duct burner that combusts fuel 

and is part of a combined cycle system. This term does not include process heaters as defined in 

this subpart. 

Steam generating unit operating day means a 24-hour period between 12:00 midnight and the 

following midnight during which any fuel is combusted at any time in the steam generating unit. It 

is not necessary for fuel to be combusted continuously for the entire 24-hour period. 

Wet flue gas desulfurization technology means an SO2control system that is located between the 

steam generating unit and the exhaust vent or stack, and that removes sulfur oxides from the 

combustion gases of the steam generating unit by contacting the combustion gases with an 

alkaline slurry or solution and forming a liquid material. This definition includes devices where the 

liquid material is subsequently converted to another form. Alkaline reagents used in wet flue gas 

desulfurization systems include, but are not limited to, lime, limestone, and sodium compounds. 

Wet scrubber system means any emission control device that mixes an aqueous stream or slurry 

with the exhaust gases from a steam generating unit to control emissions of particulate matter 

(PM) or SO2. 
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Permit Reviewer: Josiah Balogun 

Wood means wood, wood residue, bark, or any derivative fuel or residue thereof, in any form, 

including but not limited to sawdust, sanderdust, wood chips, scraps, slabs, millings, shavings, 

and processed pellets made from wood or other forest residues. 

[55 FR 37683, Sept. 12, 1990, as amended at 61 FR 20736, May 8, 1996; 65 FR 61752, Oct. 17, 

2000; 71 FR 9884, Feb. 27, 2006] 

§ 60.48c Reporting and recordkeeping requirements. 

(a) The Permittee of each affected facility shall submit notification of the date of construction or 

reconstruction, anticipated startup, and actual startup, as provided by §60.7 of this part. This 

notification shall include: 

(1) The design heat input capacity of the affected facility and identification of fuels to be 

combusted in the affected facility. 

 (g) The permittee of each affected facility shall record and maintain records of the amounts of 

each fuel combusted during each day. The Permittee of an affected facility that only burns very 

low sulfur fuel oil or other liquid or gaseous fuels with potential sulfur dioxide emissions rate of 

140 ng/J (0.32 lb/MMBtu) heat input or less shall record and maintain records of the fuels 

combusted during each calendar month. 

 (i) All records required under this section shall be maintained by the owner or operator of the 

affected facility for a period of two years following the date of such record. 

(j) The reporting period for the reports required under this subpart is each six-month period. All 

reports shall be submitted to the Administrator and shall be postmarked by the 30th day following 

the end of the reporting period. 

[55 FR 37683, Sept. 12, 1990, as amended at 64 FR 7465, Feb. 12, 1999; 65 FR 61753, Oct. 17, 

2000; 71 FR 9886, Feb. 27, 2006] 
Thermafiber, Inc. Wabash Plant First Significant Permit Mod No. 169-27436-00009 Page 40 of 56 

Wabash, Indiana Modified By: Madhurima D. Moulik T169-21103-00009 

Permit Reviewer: Josiah Balogun 

SECTION D.4 EMISSIONS UNIT OPERATION CONDITIONS 

Emissions Unit Description: Specifically Regulated Insignificant Activities

(1) The following equipment related to manufacturing activities not resulting in the 

emission of HAPs: brazing equipment, cutting torches, soldering equipment, welding 

equipment [326 IAC 6-3-2]; and 

(2) Conveyors as follows: covered conveyors for coke conveying of maximum capacity 80 

tons of coke per day [326 IAC 6-3-2]. 

(The information describing the process contained in this emissions unit description box is descriptive 

information and does not constitute enforceable conditions.) 

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

D.4.1 Particulate Emission Limitations for Manufacturing Processes [326 IAC 6-3-2] 

Pursuant to 326 IAC 6-3-2(e), (Particulate Emission Limitations for Manufacturing Processes), the 

particulate matter (PM) emissions from the insignificant activities, brazing equipment, cutting 

torches, soldering equipment, and welding equipment shall not exceed the pounds per hour 

emission rate established by the equation: 

 

 Interpolation of the data for the process weight rate up to sixty thousand (60,000) pounds per 

 hour shall be accomplished by use of the equation: 

 

 E = 4.10 x P 0.67

 

 Where: 

 P = process weight in tons/hr and 

 E = rate of emission in pounds per hour. 

D.4.2 Particulate Emission Limitations for Manufacturing Processes [326 IAC 6-3-2] 

Pursuant to 326 IAC 6-3-2(e), (Particulate Emission Limitations for Manufacturing Processes), the 

particulate matter (PM) emissions from the conveyors for coke shall not exceed the pounds per 

hour emission rate established by the equation: 

 

 Interpolation of the data for the process weight rate up to sixty thousand (60,000) pounds per 

 hour shall be accomplished by use of the equation: 

 

 E = 4.10 x P 0.67

 

 Where: 

 P = process weight in tons/hr and 

 E = rate of emission in pounds per hour. 

SECTION E EMISSIONS UNIT OPERATION CONDITIONS 
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Emissions Unit Description: NESHAP Subpart DDD

 

 (a) One (1) coke-fueled cupola #2, identified as EU-P2, constructed in 1955, refurbished 

in 1995, and modified in 2009, natural gas supplemented, with a maximum capacity of 

10.47 MMBtu/hr, equipped with a 10.0 mmBTU/hr natural gas fired thermal oxidizer 

EU-P2A and a baghouse, exhausting through Stack S1, constructed in 2003, with a 

maximum capacity of 8.5 tons of minerals per hour. 

(b) One coke-fueled cupola #4, identified as EU-P4, constructed in 1955, and refurbished 

in 1994, and modified in 2009, natural gas supplemented, with a maximum capacity of 

10.47 MMBtu/hr, equipped with a 10.0 mmBTU/hr natural gas fired thermal oxidizer 

EU-P4A, a caustic injection system for control of SO2 emissions, and a baghouse, 

exhausting through Stack S3, constructed in 2003, with a maximum capacity of 9.5 

tons of minerals per hour. 

 

 (c) One (1) natural gas-fired curing oven #2, identified as EU-P7, with a maximum 

capacity of 5.7 million British thermal units per hour, exhausting through Stack S5, 

constructed in 1955 and replaced in 1978, with a maximum capacity of 7.0 tons of 

fiberized minerals per hour and emissions controlled by regenerative thermal oxidizer, 

(RTO), constructed in 2002. 

(The information describing the process contained in this emissions unit description box is descriptive 

information and does not constitute enforceable conditions.) 

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

E.1.1 General Provisions Relating to NESHAP Subpart DDD (National Emission Standards for 

Hazardous Air Pollutants for Mineral Wool Production) [326 IAC 20-1-1][40 CFR Part 63, 

 Subpart A] 

 Pursuant to 40 CFR 63.1194, the Permittee shall comply with the provisions of 40 CFR Part 63, 

 Subpart A-General Provisions, which are incorporated by reference as 326 IAC 20-1-1, as apply 

 to the two (2) cupolas, identified as EU-P2, EU-P4 and the curing oven, identified as EU-P7 

 described in this section except when otherwise specified in 40 CFR 63, Subpart DDD. 

E.1.2 NESHAP Supart DDD Requirements [40 CFR 63, Subpart DDD] 

 Pursuant to 40 CFR, Subpart DDD, the Permittee shall comply with the provisions of 40 CFR Part 

 63, Subpart DDD, for existing mineral wool cupolas, identifed as EU-P2, EU-P4 and curing oven, 

 identified as EU-P7, beginning June 2, 2002. 

 

§ 63.1175 What is the purpose of this subpart?

This subpart establishes national emission standards for hazardous air pollutants emitted from existing, new, and 

reconstructed cupolas and curing ovens at facilities that produce mineral wool. 

§ 63.1176 Where can I find definitions of key words used in this subpart? 

The definitions of key words used in this subpart are in the Clean Air Act (Act), in §63.2 of the general provisions in 

subpart A of this part, and in §63.1196 of this subpart. 

§ 63.1177 Am I subject to this subpart? 

You are subject to this subpart if you own or operate an existing, new, or reconstructed mineral wool production 

facility that is located at a plant site that is a major source of hazardous air pollutant (HAP) emissions, meaning the 
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plant emits or has the potential to emit any single HAP at a rate of 9.07 megagrams (10 tons) or more per year or any 

combination of HAPs at a rate of 22.68 megagrams (25 tons) or more per year. 

§ 63.1178 For cupolas, what standards must I meet? 

(a) You must control emissions from each cupola as follows: 

(1) Limit emissions of particulate matter (PM) from each existing, new, or reconstructed cupola to 0.05 kilograms (kg) 

of PM per megagram (MG) (0.10 pound [lb] of PM per ton) of melt or less. 

(2) Limit emissions of carbon monoxide (CO) from each new or reconstructed cupola to either of the following: 

(i) 0.05 kg of CO per MG (0.10 lb of CO per ton) of melt or less. 

(ii) A reduction of uncontrolled CO emissions by at least 99 percent. 

(b) You must meet the following operating limits for each cupola: 

(1) Begin within one hour after the alarm on a bag leak detection system sounds, and complete in a timely manner, 

corrective actions as specified in your operations, maintenance, and monitoring plan required by §63.1187 of this 

subpart. 

(2) When the alarm on a bag leak detection system sounds for more than five percent of the total operating time in a 

six-month reporting period, develop and implement a written quality improvement plan (QIP) consistent with the 

compliance assurance monitoring requirements of §64.8(b)–(d) of 40 CFR part 64. 

(3) Additionally, for each new or reconstructed cupola, maintain the operating temperature of the incinerator so that 

the average operating temperature for each three-hour block period never falls below the average temperature 

established during the performance test. 

§ 63.1179 For curing ovens, what standards must I meet? 

(a) You must control emissions from each existing, new, or reconstructed curing oven by limiting emissions of 

formaldehyde to either of the following: 

(1) 0.03 kg of formaldehyde per MG (0.06 lb of formaldehyde per ton) of melt or less. 

(2) A reduction of uncontrolled formaldehyde emissions by at least 80 percent. 

(b) You must meet the following operating limits for each curing oven: 

(1) Maintain the free-formaldehyde content of each resin lot and the formaldehyde content of each binder formulation 

at or below the specification ranges of the resin and binder used during the performance test. 

(2) Maintain the operating temperature of each incinerator so that the average operating temperature for each threehour block period never falls below the average temperature established during the performance test. 

§ 63.1180 When must I meet these standards? 

(a) Existing cupolas and curing ovens. You must install any control devices and monitoring equipment necessary to 

meet the standards in this subpart, complete performance testing, and demonstrate compliance with all requirements 

of this subpart no later than the following: 

(1) June 2, 2002; or 
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(2) June 3, 2003 if you apply for and receive a one-year extension under section 112(i)(3)(B) of the Act. 

(b) New and reconstructed cupolas and curing ovens. You must install any control devices or monitoring equipment 

necessary to meet the standards in this subpart, complete performance testing, and demonstrate compliance with all 

requirements of this subpart by the dates in §63.7 of the general provisions in subpart A of this part. 

(c) You must comply with the standards in §§63.1178 and 63.1179 of this subpart on and after the dates in 

paragraphs (a) and (b) of this section. 

(d) You must comply with these standards at all times except during periods of startup, shutdown, or malfunction. 

§ 63.1181 How do I comply with the particulate matter standards for existing, new, and 

reconstructed cupolas? 

To comply with the PM standards, you must meet all of the following: 

(a) Install, adjust, maintain, and continuously operate a bag leak detection system for each fabric filter. 

(b) Do a performance test as specified in §63.1188 of this subpart and show compliance with the PM emission limits 

while the bag leak detection system is installed, operational, and properly adjusted. 

(c) Begin corrective actions specified in your operations, maintenance, and monitoring plan required by §63.1187 of 

this subpart within one hour after the alarm on a bag leak detection system sounds. Complete the corrective actions 

in a timely manner. 

(d) Develop and implement a written QIP consistent with compliance assurance monitoring requirements of 40 CFR 

64.8(b) through (d) when the alarm on a bag leak detection system sounds for more than five percent of the total 

operating time in a six-month reporting period. 

§ 63.1183 How do I comply with the formaldehyde standards for existing, new, and reconstructed 

curing ovens? 

To comply with the formaldehyde standards, you must meet all of the following: 

(a) Install, calibrate, maintain, and operate a device that continuously measures the operating temperature in the 

firebox of each thermal incinerator. 

(b) Do a performance test as specified in §63.1188 of this subpart while manufacturing the product that requires a 

binder formulation made with the resin containing the highest free-formaldehyde content specification range. Show 

compliance with the formaldehyde emission limits while the device for measuring incinerator operating temperature is 

installed, operational, and properly calibrated. Establish the average operating temperature as specified in 

§63.1185(a) of this subpart. 

(c) During the performance test that uses the binder formulation made with the resin containing the highest freeformaldehyde content specification range, record the free-formaldehyde content specification range of the resin used, 

and the formulation of the binder used, including the formaldehyde content and binder specification. 

(d) Following the performance test, monitor and record the free-formaldehyde content of each resin lot and the 

formulation of each batch of binder used, including the formaldehyde content. 

(e) Maintain the free-formaldehyde content of each resin lot and the formaldehyde content of each binder formulation 

at or below the specification ranges established during the performance test. 

(f) Following the performance test, measure and record the average operating temperature of the incinerator as 

specified in §63.1185(b) of this subpart. 
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(g) Maintain the operating temperature of the incinerator so that the average operating temperature for each threehour block period never falls below the average temperature established during the performance test. 

(h) Operate and maintain the incinerator as specified in your operations, maintenance, and monitoring plan required 

by §63.1187 of this subpart. 

(i) With prior approval from the Administrator, you may do short-term experimental production runs using resin where 

the free-formaldehyde content, or binder formulations where the formaldehyde content, is higher than the 

specification ranges of the resin and binder used during previous performance tests, or using experimental pollution 

prevention process modifications without first doing additional performance tests. Notification of intent to perform a 

short-term experimental production run must include the following information: 

(1) The purpose of the experimental run. 

(2) The affected production process. 

(3) How the resin free-formaldehyde content or binder formulation will deviate from previously approved levels or 

what the experimental pollution prevention process modifications are. 

(4) The duration of the experimental run. 

(5) The date and time of the experimental run. 

(6) A description of any emissions testing to be done during the experimental run. 

§ 63.1184 What do I need to know about the design specifications, installation, and operation of a 

bag leak detection system? 

A bag leak detection system must meet the following requirements: 

(a) The bag leak detection system must be certified by the manufacturer to be capable of detecting PM emissions at 

concentrations of 10 milligrams per actual cubic meter (0.0044 grains per actual cubic foot) or less. 

(b) The sensor on the bag leak detection system must provide output of relative PM emissions. 

(c) The bag leak detection system must have an alarm that will sound automatically when it detects an increase in 

relative PM emissions greater than a preset level. 

(d) The alarm must be located in an area where appropriate plant personnel will be able to hear it. 

(e) For a positive-pressure fabric filter, each compartment or cell must have a bag leak detector. For a negativepressure or induced-air fabric filter, the bag leak detector must be installed downstream of the fabric filter. If multiple 

bag leak detectors are required (for either type of fabric filter), detectors may share the system instrumentation and 

alarm. 

(f) Each triboelectric bag leak detection system must be installed, operated, adjusted, and maintained so that it 

follows EPA's “Fabric Filter Bag Leak Detection Guidance” (EPA–454/R–98–015, September 1997). Other bag leak 

detection systems must be installed, operated, adjusted, and maintained so that they follow the manufacturer's 

written specifications and recommendations. 

(g) At a minimum, initial adjustment of the system must consist of establishing the baseline output in both of the 

following ways: 

(1) Adjust the range and the averaging period of the device. 
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(2) Establish the alarm set points and the alarm delay time. 

(h) After initial adjustment, the range, averaging period, alarm set points, or alarm delay time may not be adjusted 

except as specified in the operations, maintenance, and monitoring plan required by §63.1187 of this subpart. In no 

event may the range be increased by more than 100 percent or decreased by more than 50 percent over a 365 day 

period unless a responsible official as defined in §63.2 of the general provisions in subpart A of this part certifies in 

writing to the Administrator that the fabric filter has been inspected and found to be in good operating condition. 

§ 63.1185 How do I establish the average operating temperature of an incinerator? 

(a) During the performance test, you must establish the average operating temperature of an incinerator as follows: 

(1) Continuously measure the operating temperature of the incinerator. 

(2) Determine and record the average temperatures in consecutive 15-minute blocks. 

(3) Determine and record the arithmetic average of the recorded average temperatures measured in consecutive 15-

minute blocks for each of the one-hour performance test runs. 

(4) Determine and record the arithmetic average of the three one-hour average temperatures during the performance 

test runs. The average of the three one-hour performance test runs establishes the temperature level to use to 

monitor compliance. 

(b) To comply with the requirements for maintaining the operating temperature of an incinerator after the performance 

test, you must measure and record the average operating temperature of the incinerator as required by §§63.1182 

and 63.1183 of this subpart. This average operating temperature of the incinerator is based on the arithmetic average 

of the one-hour average temperatures for each consecutive three-hour period and is determined in the same manner 

described in paragraphs (a)(1) through (a)(4) of this section. 

§ 63.1188 What performance test requirements must I meet? 

You must meet the following performance test requirements: 

(a) All monitoring systems and equipment must be installed, operational, and properly calibrated before the 

performance tests. 

(b) Do a performance test, consisting of three test runs, for each cupola and curing oven subject to this subpart at the 

maximum production rate to demonstrate compliance with each of the applicable emission limits in §§63.1178 and 

63.1179 of this subpart. 

(c) Measure emissions of PM from each existing cupola. 

(d) Measure emissions of PM and CO from each new or reconstructed cupola. 

(e) Measure emissions of formaldehyde from each existing, new or reconstructed curing oven. 

(f) Measure emissions at the outlet of the control device if complying with a numerical emission limit for PM, CO, or 

formaldehyde, or at the inlet and outlet of the control device if complying with a percent reduction emission limit for 

CO or formaldehyde. 

(g) To determine the average melt rate, measure and record the amount of raw materials, excluding coke, charged 

into and melted in each cupola during each performance test run. Determine and record the average hourly melt rate 

for each performance test run. Determine and record the arithmetic average of the average hourly melt rates 

associated with the three performance test runs. The average hourly melt rate of the three performance test runs is 

used to determine compliance with the applicable emission limits. 
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(h) Compute and record the average emissions of the three performance test runs and use the equations in §63.1190 

of this subpart to determine compliance with the applicable emission limits. 

(i) Comply with control device and process operating parameter monitoring requirements for performance testing as 

specified in this subpart. 

§ 63.1190 How do I determine compliance? 

(a) Using the results of the performance tests, you must use the following equation to determine compliance with the 

PM emission limit: 

where: 

E = Emission rate of PM, kg/Mg (lb/ton) of melt. 

C = Concentration of PM, g/dscm (gr/dscf). 

Q = Volumetric flow rate of exhaust gases, dscm/hr (dscf/hr). 

K 51= Conversion factor, 1 kg/1,000 g (1 lb/7,000 gr). 

P = Average melt rate, Mg/hr (ton/hr). 

(b) Using the results of the performance tests, you must use the following equation to determine compliance with the 

CO and formaldehyde numerical emission limits: 

where: 

E = Emission rate of measured pollutant, kg/Mg (lb/ton) of melt. 

C = Measured volume fraction of pollutant, ppm. 

MW = Molecular weight of measured pollutant, g/g-mole: 

CO = 28.01, Formaldehyde = 30.03. 

Q = Volumetric flow rate of exhaust gases, dscm/hr (dscf/hr). 

K1= Conversion factor, 1 kg/1,000 g (1 lb/453.6 g). 

K2= Conversion factor, 1,000 L/m3

 (28.3 L/ft3 ). 

K3= Conversion factor, 24.45 L/g-mole. 

P = Average melt rate, Mg/hr (ton/hr). 
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(c) Using the results of the performance tests, you must use the following equation to determine compliance with the 

CO and formaldehyde percent reduction performance standards: 

where: 

%R = Percent reduction, or collection efficiency of the control device. 

Li

= Inlet loading of pollutant, kg/Mg (lb/ton). 

Lo= Outlet loading of pollutant, kg/Mg (lb/ton). 

§ 63.1191 What notifications must I submit? 

You must submit written notifications to the Administrator as required by §63.9(b)–(h) of the general provisions in 

subpart A of this part. These notifications include, but are not limited to, the following: 

(a) Notification that the following types of sources are subject to the standard: 

(1) An area source that increases its emissions so that it becomes a major source. 

(2) A source that has an initial startup before the effective date of the standard. 

(3) A new or reconstructed source that has an initial startup after the effective date of the standard and doesn't 

require an application for approval of construction or reconstruction under §63.5(d) of the general provisions in 

subpart A of this part. 

(b) Notification of intention to construct a new major source or reconstruct a major source where the initial startup of 

the new or reconstructed source occurs after the effective date of the standard and an application for approval of 

construction or reconstruction under §63.5(d) of the general provisions in subpart A of this part is required. 

(c) Notification of special compliance obligations for a new source that is subject to special compliance requirements 

in §63.6(b)(3) and (4) of the general provisions in subpart A of this part. 

(d) Notification of a performance test at least 60 calendar days before the performance test is scheduled to begin. 

(e) Notification of compliance status. 

§ 63.1192 What recordkeeping requirements must I meet? 

You must meet the following recordkeeping requirements: 

(a) Maintain files of all information required by §63.10(b) of the general provisions in subpart A of this part, including 

all notifications and reports. 

(b) Maintain records of the following information also: 

(1) Cupola production (melt) rate (Mg/hr (tons/hr) of melt). 
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(2) All bag leak detection system alarms. Include the date and time of the alarm, when corrective actions were 

initiated, the cause of the alarm, an explanation of the corrective actions taken, and when the cause of the alarm was 

corrected. 

(3) The free-formaldehyde content of each resin lot and the binder formulation, including formaldehyde content, of 

each binder batch used in the manufacture of bonded products. 

(4) Incinerator operating temperature and results of incinerator inspections. For all periods when the average 

temperature in any three-hour block period fell below the average temperature established during the performance 

test, and all periods when the inspection identified incinerator components in need of repair or maintenance, include 

the date and time of the problem, when corrective actions were initiated, the cause of the problem, an explanation of 

the corrective actions taken, and when the cause of the problem was corrected. 

(c) Retain each record for at least five years following the date of each occurrence, measurement, corrective action, 

maintenance, record, or report. The most recent two years of records must be retained at the facility. The remaining 

three years of records may be retained off site. 

(d) Retain records on microfilm, on a computer, on computer disks, on magnetic tape disks, or on microfiche. 

(e) Report the required information on paper or on a labeled computer disk using commonly available and compatible 

computer software. 

§ 63.1193 What reports must I submit? 

You must prepare and submit reports to the Administrator as required by this subpart and §63.10 of the general 

provisions in subpart A of this part. These reports include, but are not limited to, the following: 

(a) A performance test report, as required by §63.10(d)(2) of the general provisions in subpart A of this part, that 

documents the process and control equipment operating parameters during the test period, the test methods and 

procedures, the analytical procedures, all calculations, and the results of the performance tests. 

(b) A startup, shutdown, and malfunction plan, as described in §63.6(e)(3) of the general provisions in subpart A of 

this part, that contains specific procedures for operating and maintaining the source during periods of startup, 

shutdown, and malfunction and a program of corrective action for malfunctioning process and control systems used 

to comply with the emission standards. In addition to the information required by §63.6(e)(3), your plan must include 

the following: 

(1) Procedures to determine and record what caused the malfunction and when it began and ended. 

(2) Corrective actions you will take if a process or control device malfunctions, including procedures for recording the 

actions taken to correct the malfunction or minimize emissions. 

(3) An inspection and maintenance schedule for each process and control device that is consistent with the 

manufacturer's instructions and recommendations for routine and long-term maintenance. 

(c) A report of each event as required by §63.10(b) of the general provisions in subpart A of this part, including a 

report if an action taken during a startup, shutdown, or malfunction is inconsistent with the procedures in the plan as 

described in §63.6(e)(3) of the general provisions in subpart A of this part. 

(d) An operations, maintenance, and monitoring plan as specified in §63.1187 of this subpart. 

(e) A semiannual report as required by §63.10(e)(3) of the general provisions in subpart A of this part if measured 

emissions exceed the applicable standard or a monitored parameter varies from the level established during 

performance testing. The report must contain the information specified in §63.10(c) of the general provisions, as well 

as the relevant records required by §63.1192(b) of this subpart. 
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(f) A semiannual report stating that no excess emissions or deviations of monitored parameters occurred during the 

reporting period as required by §63.10(e)(3)(v) of the general provisions in subpart A of this part if no deviations have 

occurred. 

§ 63.1194 Which general provisions apply? 

The general provisions in subpart A of this part define requirements applicable to all owners and operators affected 

by NESHAP in part 63. See Table 1 of this subpart for general provisions that apply (or don't apply) to you as an 

owner or operator subject to the requirements of this subpart. 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 
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Permit Reviewer: Josiah Balogun 

PART 70 OPERATING PERMIT 

CERTIFICATION 

Source Name: Thermafiber, Inc Wabash Plant 

Source Address: 3711 Mill Street, Wabash, Indiana 46992 

Mailing Address: 3711 Mill Street, Wabash, IN 46992 

Part 70 Permit No.: T169-21103-00009 

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: 

 Annual Compliance Certification Letter 

 Test Result (specify) 

 Report (specify) 

 Notification (specify) 

 Affidavit (specify) 

 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: Josiah Balogun 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE AND ENFORCEMENT BRANCH 

100 North Senate Avenue 

MC 61-53 IGCN 1003 

Indianapolis, Indiana 46204-2251 

Phone: 317-233-0178 

Fax: 317-233-6865 

PART 70 OPERATING PERMIT 

EMERGENCY OCCURRENCE REPORT 

Source Name: Thermafiber, Inc Wabash Plant 

Source Address: 3711 Mill Street, Wabash, Indiana 46992 

Mailing Address: 3711 Mill Street, Wabash, IN 46992 

Part 70 Permit No.: T169-21103-00009 

This form consists of 2 pages Page 1 of 2 

 This is an emergency as defined in 326 IAC 2-7-1(12) 

• The Permittee must notify the Office of Air Quality (OAQ), within four (4) business 

hours (1-800-451-6027 or 317-233-0178, ask for Compliance Section); and 

• The Permittee must submit notice in writing or by facsimile within two (2) working days 

(Facsimile Number: 317-233-6865), 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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Permit Reviewer: Josiah Balogun 

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 

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: Josiah Balogun 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE AND ENFORCEMENT BRANCH 

PART 70 OPERATING PERMIT 

SEMI-ANNUAL NATURAL GAS FIRED BOILER CERTIFICATION 

Source Name: Thermafiber, Inc Wabash Plant 

Source Address: 3711 Mill Street, Wabash, Indiana 46992 

Mailing Address: 3711 Mill Street, Wabash, IN 46992 

Part 70 Permit No.: T169-21103-00009 

 Natural Gas Only 

 Alternate Fuel burned 

From: To: 

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: 

A certification by the responsible official as defined by 326 IAC 2-7-1(34) is required for this report. 
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Permit Reviewer: Josiah Balogun 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE AND ENFORCEMENT BRANCH 

PART 70 OPERATING PERMIT QUARTERLY REPORT

Source Name: Thermafiber, Inc Wabash Plant 

Source Address: 3711 Mill Street, Wabash, Indiana 46992 

Mailing Address: 3711 Mill Street, Wabash, IN 46992 

Part 70 Permit No.: T169-21103-00009 

Facility: Cupola #2 and #4 

Parameter: SO2 emissions 

Limit: 620 tons per 12 consecutive month period 

 

Cupola #4 

YEAR: QUARTER: 

Column 1 Column 2 Column 1 + Column 2 

Month 

This Month Previous 11 Months 12 Month Total 

  No deviation occurred in this quarter. 

  Deviation/s occurred in this quarter. 

 Deviation has been reported on: 

 

Submitted by: 

Title/Position: 

Signature: 

Date: 

Telephone: 

Attach a signed certification to complete this report. 
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Permit Reviewer: Josiah Balogun 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE AND ENFORCEMENT BRANCH 

PART 70 OPERATING PERMIT 

QUARTERLY DEVIATION AND COMPLIANCE MONITORING REPORT 

Source Name: Thermafiber, Inc Wabash Plant 

Source Address: 3711 Mill Street, Wabash, Indiana 46992 

Mailing Address: 3711 Mill Street, Wabash, IN 46992 

Part 70 Permit No.: T169-21103-00009 

 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. A deviation required to be reported pursuant to an applicable 

requirement that exists independent of the permit, shall be reported according to the schedule stated 

in the applicable requirement and does 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". 

 NO DEVIATIONS OCCURRED THIS REPORTING PERIOD. 

 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

Technical Support Document (TSD) for a Part 70 

Significant Source Modification and Significant Permit Modification 

Source Description and Location 

Source Name: Thermafiber, Inc. 

Source Location: 3711 Mill Street, Wabash, Indiana 46992 

County: Wabash 

SIC Code: 3296 

Operation Permit No.: T 169-21103-00009 

Operation Permit Issuance Date: December 17, 2007 

Significant Source Modification No.: 169-27407-00009 

Significant Permit Modification No.: 169-27436-00009 

Permit Reviewer: Madhurima D. Moulik 

Existing Approvals 

The source was issued Part 70 Operating Permit No. T 169-21103-00009 on December 17, 2007. 

The source has since received the following approvals: 

(a) Administrative Amendment No. 169-26743-00009, issued on August 6, 2008. 

County Attainment Status 

The source is located in Wabash County. 

Pollutant Designation 

SO2 Better than national standards. 

CO Unclassifiable or attainment effective November 15, 1990. 

O3 Unclassifiable or attainment effective June 15, 2004, for the 8-hour 

ozone standard.1

PM10 Unclassifiable effective November 15, 1990. 

NO2 Cannot be classified or better than national standards. 

Pb Not designated. 

1

Unclassifiable or attainment effective October 18, 2000, for the 1-hour ozone 

standard which was revoked effective June 15, 2005. 

Unclassifiable or attainment effective April 5, 2005, for PM2.5. 

(a) Ozone Standards 

(1) On October 25, 2006, the Indiana Air Pollution Control Board finalized a rule 

revision to 326 IAC 1-4-1 revoking the one-hour ozone standard in Indiana. 

(2) On September 6, 2007, the Indiana Air Pollution Control Board finalized a 

temporary emergency rule to re-designate Allen, Clark, Elkhart, Floyd, LaPorte, 

and St. Joseph counties as attainment for the 8-hour ozone standard. 

(3) On November 9, 2007, the Indiana Air Pollution Control Board finalized a 

temporary emergency rule to re-designate Boone, Hamilton, Hancock, Hendricks, 

Johnson, Madison, Marion, Morgan, and Shelby counties as attainment for the 8-
Thermafiber Inc. Page 2 of 11 

Wabash, Indiana Significant Source Modification No.: 169-27407-00009 

Permit Reviewer: Madhurima Moulik Significant Permit Modification No.: 169-27436-00009 

hour ozone standard. 

(4) Volatile organic compounds (VOC) and Nitrogen Oxides (NOx) are regulated 

under the Clean Air Act (CAA) for the purposes of attaining and maintaining the 

National Ambient Air Quality Standards (NAAQS) for ozone. Therefore, VOC and 

NOx emissions are considered when evaluating the rule applicability relating to 

ozone. Wabash County has been designated as attainment or unclassifiable for 

ozone. Therefore, VOC and NOx emissions were reviewed pursuant to the 

requirements for Prevention of Significant Deterioration (PSD), 326 IAC 2-2. 

(b) Wabash County has been classified as attainment for PM2.5. On May 8, 2008, U.S. EPA 

promulgated the requirements for Prevention of Significant Deterioration (PSD) for PM2.5 

emissions, and these rules became effective on July 15, 2008. Indiana has three years 

from the publication of these rules to revise its PSD rules, 326 IAC 2-2, to include those 

requirements. The May 8, 2008 rule revisions require IDEM to regulate PM10 emissions 

as a surrogate for PM2.5 emissions until 326 IAC 2-2 is revised. 

(c) Other Criteria Pollutants 

Wabash County has been classified as attainment or unclassifiable in Indiana for all other 

criteria pollutants. Therefore, these emissions were reviewed pursuant to the 

requirements for Prevention of Significant Deterioration (PSD), 326 IAC 2-2. 

(d) Fugitive Emissions

Since this type of operation is in one of the twenty-eight (28) listed source categories 

under 326 IAC 2-2 or 326 IAC 2-3, fugitive emissions are counted toward the 

determination of PSD and Emission Offset applicability. 

Source Status 

The table below summarizes the potential to emit of the entire source, prior to the proposed 

modification, after consideration of all enforceable limits established in the effective permits: 

Pollutant tons/year 

PM >100 

PM10 >100 

SO2 >100 

VOC <100 

CO >100 

NOx >100 

Pb less than 10 

(a) This existing stationary source is major for PSD because the emissions of at least one 

criteria pollutant are greater than one hundred (>100) tons per year, and it is one of the 

twenty-eight (28) listed source categories. 

(b) Fugitive Emissions 

Since this type of operation is in one of the twenty-eight (28) listed source categories 

under 326 IAC 2-2 or 326 IAC 2-3, fugitive emissions are counted toward the 

determination of PSD and Emission Offset applicability. 

(c) These emissions are based on the Technical Support Document for Part 70 Permit No. 

T169-21103-00009. 

The table below summarizes the potential to emit HAPs for the entire source, prior to the 

proposed modification, after consideration of all enforceable limits established in the effective 

permits: 
Thermafiber Inc. Page 3 of 11 

Wabash, Indiana Significant Source Modification No.: 169-27407-00009 

Permit Reviewer: Madhurima Moulik Significant Permit Modification No.: 169-27436-00009 

HAPs tons/year 

Chromium less than 10 

Manganese less than 10 

Nickel less than 10 

Arsenic less than 10 

cadmium less than 10 

Selenium less than 10 

Carbonyl Sulfide greater than 10 

Barium less than 10 

Beryllium less than 10 

Antimony less than 10 

Lead less than 10 

Fine Mineral 

Fiber 

less than 10 

Benzene less than 10 

Dichlorobenzene less than 10 

Formaldehyde less than 10 

Hexane less than 10 

Toluene less than 10 

Total greater than 25 

This existing source is a major source of HAPs, as defined in 40 CFR 63.2, because HAP 

emissions are greater than twenty-five (25) tons per year for a combination of HAPs. Therefore, 

this source is a major source under Section 112 of the Clean Air Act (CAA). 

Actual Emissions 

The following table shows the actual emissions from the source. This information reflects the 2006

OAQ emission data. 

Pollutant Actual Emissions (tons/year) 

PM 0 

PM10 121 

SO2 411 

VOC 151 

CO 10,848 

NOx 74 

Pb 0.00 

Description of Proposed Modification

The Office of Air Quality (OAQ) has reviewed a source modification application, submitted by 

Thermafiber, Inc. on January 23, 2009, relating to the installation of two thermal oxidizers in order 

to recover heat from two existing cupolas. The thermal oxidizers will be installed between the 

existing cupolas and the existing baghouses. The thermal oxidizers will reduce the cupola 

emissions of CO, VOC, and carbonyl sulfide through thermal destruction. However, the thermal 

oxidation of carbonyl sulfide and other reduced sulfur compounds emitted from the cupola will 

result in increased SO2 emissions. 
Thermafiber Inc. Page 4 of 11 

Wabash, Indiana Significant Source Modification No.: 169-27407-00009 

Permit Reviewer: Madhurima Moulik Significant Permit Modification No.: 169-27436-00009 

The following is a list of the proposed emission units and pollution control devices: 

(a) Two (2) natural gas fired thermal oxidizers, identified as EU-P2A and EU-P4A, permitted 

in 2009, with rated capacities of 10.0 mmBTU/hr each, exhausting through Stacks S-1 

and S-3. 

Enforcement Issues 

There are no pending enforcement actions related to this modification. 

Stack Summary 

Stack ID Operation Height 

(ft) 

Diameter 

(ft) 

Flow Rate 

(acfm) 

Temperature

(

0

F) 

S-1 Cupola #2 with 

thermal oxidizer 57 3 13,000 200 

S-3 Cupola #4 with 

thermal oxidizer 57 3 12,000 200 

Emission Calculations 

The Permittee has submitted emissions calculations for the proposed project. IDEM has reviewed 

this information and has determined the emissions calculations to be accurate. See Appendix A of 

this Technical Support Document for detailed emission calculations. 

Permit Level Determination – Part 70 

Pursuant to 326 IAC 2-1.1-1(16), Potential to Emit is defined as “the maximum capacity of a 

stationary source or emission unit 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, IDEM, or the appropriate local air pollution control agency.” 

The following table is used to determine the appropriate permit level under 326 IAC 2-7-10.5. This 

table reflects the PTE before controls. Control equipment is not considered federally enforceable 

until it has been required in a federally enforceable permit. 

PTE Before Controls of the Modification 

Pollutant Potential To Emit (ton/yr) 

PM 0.6 

PM10 0.6 

PM2.5 0.6 

SO2 132.7 

VOC 0.48 

CO 7.4 

NOX 8.8 
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Wabash, Indiana Significant Source Modification No.: 169-27407-00009 

Permit Reviewer: Madhurima Moulik Significant Permit Modification No.: 169-27436-00009 

HAP PTE Before Controls of the Modification 

HAPs Potential To Emit (ton/yr) 

Single HAP Negligible 

 

TOTAL Negligible 

This source modification is subject to the Significant Source Modification requirements under 

326 IAC 2-7-10.5(f)(4) because the potential to emit sulfur dioxide is greater than twenty-five (25) 

tons per year. Additionally, the modification will be incorporated into the Part 70 Operating Permit 

through a significant permit modification issued pursuant to 326 IAC 2-7-12(d), because the 

modification requires significant changes in the existing monitoring Part 70 permit terms and 

conditions. 

Permit Level Determination – PSD Actual to Projected Actual Test 

The Permittee has provided information as part of the application for this approval that based on 

Actual to Projected Actual test (ATPA) in 326 IAC 2-2-2(d)(3), this modification at a major 

stationary source will not be major for Prevention of Significant Deterioration under 326 IAC 2-2-1. 

IDEM, OAQ has not reviewed this information and will not be making any determination in this 

regard as part of this approval. The applicant will be required to keep records and report in 

accordance with Source obligation in 326 IAC 2-2-8. See Appendix A of this Technical Support 

Document for detailed emission calculations. 

As shown in the following table, the operation of the two (2) cupolas equipped with the two (2) 

natural gas fired thermal oxidizers will result in an overall reduction of criteria pollutants. 

Projected Increase in Actual Emissions (ton/yr) 

Process / Emission Unit CO* PM PM10 NOX SO2

#

 VOC* 

Baseline Actual Emissions 

(Nov 2006 to Nov 2008) - 

Cupola #2 and Cupola #4 

11412.3 0.38 0.38 73.0 580.3 136.9 

Emissions that could have 

been accommodated - 

Cupola #2 and Cupola #4 

3587.8 0.1 0.1 23.0 0 43.1 

Projected Actual 

Emissions - Cupola #2 

and Cupola #4 

150.0 0.5 0.5 96.0 479.7 1.8 

Thermal Oxidizers 7.4 0.6 0.6 8.8 132.7 0.48 

Emissions Increase --- 0.7 0.7 8.8 32.1 --- 

PSD Significant Level 100 25 15 40 40 40 

--- ATPA calculations show an emissions decrease 

* RTO destruction efficiency for CO and VOC were assumed to be 99%. However, even at an assumed 0% 

destruction efficiency, the emissions increase from this modification are less than PSD significant levels for both CO 

and VOC. Therefore, compliance monitoring requirements are not necessary for the two (2) proposed thermal 

oxidizers to ensure that this modification is minor under 326 IAC 2-2. 

# The SO2 emission factors (uncontrolled for Cupola #2 and both controlled (through use of a caustic injection 

system) and uncontrolled for Cupola #4) used in the ATPA calculations have been included as limitations in the 

permit, and testing requirements have been included to verify these emission factors. 
Thermafiber Inc. Page 6 of 11 

Wabash, Indiana Significant Source Modification No.: 169-27407-00009 

Permit Reviewer: Madhurima Moulik Significant Permit Modification No.: 169-27436-00009 

Federal Rule Applicability Determination 

(a) Pursuant to 40 CFR 64.2, Compliance Assurance Monitoring (CAM) is applicable to each 

new or modified pollutant-specific emission unit that meets the following criteria: 

(1) has a potential to emit before controls equal to or greater than the Part 70 major 

source threshold for the pollutant involved; 

(2) is subject to an emission limitation or standard for that pollutant; and 

(3) uses a control device, as defined in 40 CFR 64.1, to comply with that emission 

limitation or standard. 

The following table is used to identify the applicability of each of the criteria, under 40 CFR 64.1, 

to each new or modified emission unit involved, for SO2: 

CAM Applicability Analysis 

Emission Unit Control 

Device

Used 

Emission

Limitation

(Y/N)

Uncontrolled

PTE

(ton/yr)

Controlled

PTE

(ton/yr)

Part 70 

Major

Source

Threshold 

(ton/yr)

CAM

Applicable

(Y/N)

Large

Unit 

(Y/N)

RTO #2 Y Y <100 <100 100 N N 

RTO #4 Y Y <100 <100 100 N N 

Based on this evaluation, the requirements of 40 CFR Part 64, CAM are not applicable to any of 

the units as part of this modification.

State Rule Applicability Determination 

The following state rules are applicable to the source due to the modification: 

326 IAC 2-2 (PSD) 

PSD and Emission Offset applicability is discussed under the Permit Level Determination – PSD 

and Emission Offset section. 

326 IAC 2-4.1 (Major Sources of Hazardous Air Pollutants (HAP)) 

The operation of the thermal oxidizers will emit less than ten (10) tons per year for a single HAP 

and less than twenty-five (25) tons per year for a combination of HAPs. Therefore, 326 IAC 2-4.1 

does not apply. 

 The remaining state rule applicabilities remain unchanged as a result of this modification. 

Compliance Determination and Monitoring Requirements 

Permits issued under 326 IAC 2-7 are required to ensure that sources can demonstrate 

compliance with all applicable state and federal rules on a continuous basis. All state and federal 

rules contain compliance provisions; however, these provisions do not always fulfill the 

requirement for a 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 

Determination Requirements are included in the permit. The Compliance Determination 

Requirements in Section D of the permit are those conditions that are found directly within state 

and federal rules and the violation of which serves as grounds for enforcement action. 

If the Compliance Determination Requirements are not sufficient to demonstrate continuous 

compliance, they will be supplemented with Compliance Monitoring Requirements, also in Section 

D of the permit. Unlike Compliance Determination Requirements, failure to meet Compliance 
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Wabash, Indiana Significant Source Modification No.: 169-27407-00009 

Permit Reviewer: Madhurima Moulik Significant Permit Modification No.: 169-27436-00009 

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 Determination Requirements applicable to this modification are as follows: 

(a) Within sixty (60) days after achieving maximum capacity but no later than one hundred 

eighty (180) days after initial startup of EU-P2A and EU-P4A, the Permittee shall conduct 

performance tests on EU-P2A and EU-P4A to verify the emission factors for SO2 

emissions. 

These compliance requirements are necessary in order to ensure that the proposed source 

modification is minor under PSD rules (326 IAC 2-2). 

Proposed Changes 

The changes listed below have been made to Part 70 Operating Permit No. T169-21103-00009. 

Deleted language appears as strikethroughs and new language appears in bold: 

1. The equipment descriptions in Sections A, D, and E of the permit have been modified to 

include the changes involved in the proposed modification. 

2. Condition D.1.2 - Carbon Monoxide (CO), Sulfur Dioxide (SO2) and Volatile Organic 

Compounds (VOC) PSD Minor Limitation, has been added to include the PSD minor 

limitations that are applicable, in order to ensure that the proposed modification is minor 

under 326 IAC 2-2. 

3. Condition D.1.5 - Testing Requirements, has been added to verify the SO2 emission 

factors used in the actual-to-projected-actual calculations submitted by the Permittee. 

4. Part 70 Quarterly Reports have been added to ensure compliance with the SO2 

emissions limitation on Cupola #2 and Cupola #4. 

5. Several of IDEM's branches and sections have been renamed. Therefore, IDEM has 

updated the addresses listed in the permit. References to Permit Administration and 

Development Section and the Permits Branch have been changed to Permit 

Administration and Support Section. References to Asbestos Section, Compliance Data 

Section, Air Compliance Section, and Compliance Branch have been changed to 

Compliance and Enforcement Branch. 

A.2 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:

(a) One (1) coke-fueled cupola #2, identified as EU-P2, constructed in 1955, refurbished in 

1995, and modified in 2009, natural gas supplemented, with a maximum capacity of 

10.47 MMBtu/hr, equipped with a 10.0 mmBTU/hr natural gas fired thermal oxidizer 

EU-P2A and a baghouse, exhausting through Stack S1, constructed in 2003, with a 

maximum capacity of 8.5 tons of minerals per hour. 

(b) One (1) coke-fueled cupola #4, identified as EU-P4, constructed in 1955, and refurbished 

in 1994, and modified in 2009, natural gas supplemented, with a maximum capacity of 

10.47 MMBtu/hr, equipped with a 10.0 mmBTU/hr natural gas fired thermal oxidizer 

EU-P4A, a caustic injection system for control of SO2 emissions, and a baghouse, 

exhausting through Stack S3, constructed in 2003, with a maximum capacity of 9.5 tons of 

minerals per hour. 

SECTION D.1 EMISSIONS UNIT OPERATION CONDITIONS 
Thermafiber Inc. Page 8 of 11 

Wabash, Indiana Significant Source Modification No.: 169-27407-00009 

Permit Reviewer: Madhurima Moulik Significant Permit Modification No.: 169-27436-00009 

Emissions Unit Description: 

 

 (a) One (1) coke-fueled cupola #2, identified as EU-P2, constructed in 1955, refurbished in 

1995, and modified in 2009, natural gas supplemented, with a maximum capacity of 

10.47 MMBtu/hr, equipped with a 10.0 mmBTU/hr natural gas fired thermal oxidizer 

EU-P2A and a baghouse, exhausting through Stack S1, constructed in 2003, with a 

maximum capacity of 8.5 tons of minerals per hour. 

(b) One (1) coke-fueled cupola #4, identified as EU-P4, constructed in 1955, and 

refurbished in 1994, and modified in 2009, natural gas supplemented, with a 

maximum capacity of 10.47 MMBtu/hr, equipped with a 10.0 mmBTU/hr natural gas 

fired thermal oxidizer EU-P4A, a caustic injection system for control of SO2 

emissions, and a baghouse, exhausting through Stack S3, constructed in 2003, with a 

maximum capacity of 9.5 tons of minerals per hour. 

 ..... 

(The information describing the process contained in this emissions unit description box is descriptive 

information and does not constitute enforceable conditions.) 

D.1.2 PSD Minor Limitations [326 IAC 2-2] 

 In order to render the requirements of 326 IAC 2-2 not applicable, the Permittee 

shall comply with the following: 

 The production in tons and the SO2 emission rates at Cupola #2 and Cupola #4 

shall be limited such that the total SO2 emissions from Cupola #2 and Cupola #4 

and the thermal oxidizers EU-P2A and EU-P4A shall be less than 620 tons per 

twelve (12) consecutive month period, with compliance determined at the end of 

each month in accordance with Condition D.1.4. 

 Compliance with this limit shall ensure that the increase in SO2 emissions from the 

modification of Cupola #2 and Cupola #4 involving the addition of the thermal 

oxidizers EU-P2A and EU-P4A is limited to less than 40 tons per twelve (12) 

consecutive month period, and shall render 326 IAC 2-2 not applicable. 

D.1.4 SO2 emissions Determinations [326 IAC 2-2] 

 Compliance with Condition D.1.2 shall be determined as follows: 

 (a) SO2 emissions from EU-P2A and EU-P4A shall be calculated using the 

following equation: 

 E = [(EF2U x P2U) + (EF4U x P4U) + (EF4C x P4C)] x 1/2000 Eq. 1 

 Where: 

 E = emissions in tons per month 

 EF = SO2 emission factor in lb/ton [2U = uncontrolled Cupola 2/EU-P2A, 4U 

= uncontrolled Cupola 4/EU-P4A, 4C = controlled (scrubber) Cupola 4/EUP4A] 

 P = monthly cupola production in tons 

 (b) Until stack test results become available, compliance shall be determined 

by using the following emission factors in Equation 1: EF2U = 16.43 lb/ton; 

EF4U = 15.86 lb/ton, EF4C = 4.76 lb/ton. After results from the stack tests 

become available, compliance shall be determined by using the emission 

factors determined in the latest stack test. 

 

D.1.5 Testing Requirements [326 IAC 2-7-6(1),(6)] [326 IAC 2-1.1-11] 
Thermafiber Inc. Page 9 of 11 

Wabash, Indiana Significant Source Modification No.: 169-27407-00009 

Permit Reviewer: Madhurima Moulik Significant Permit Modification No.: 169-27436-00009 

 In order to demonstrate compliance with Condition D.1.2, the following shall apply: 

 (a) Within sixty (60) days after achieving maximum capacity but no later than 

one hundred eighty (180) days after initial startup of EU-P2A and EU-P4A, 

the Permittee shall conduct performance tests on EU-P2A (uncontrolled 

only) and EU-P4A (controlled and uncontrolled) to verify the emission 

factors for SO2 emissions, utilizing methods as approved by the 

Commissioner. 

 (b) These tests shall be repeated at least once every five (5) years from the date 

of the most recent valid compliance demonstration. 

 (c) Testing shall be conducted in accordance with Section C – Performance 

Testing. 

D.1.6 Caustic Injection System Operation [326 IAC 2-7-6(1)] [326 IAC 2-7-5(1)] 

 Except as provided by statute, rule, or this permit, the caustic injection system 

shall be operated as needed to maintain compliance with all SO2 emission limits. 

D.1.810 Parametric Monitoring 

(a) The Permittee shall record the pressure drop across the baghouse used in 

conjunction with the #2 line trimming/sizing section, at least once per day when 

the #2 line trimming/sizing section is in operation when exhausting to the 

atmosphere. When for any one reading, the pressure drop across the baghouse 

are outside the normal range of 1.2 and 6.0 inches of water or a range 

established during the latest stack test, the Permittee shall take reasonable 

response steps in accordance with Section C- Response to Excursions and 

Exceedances. A pressure reading that is outside the above mentioned range is 

not a deviation from this permit. Failure to take response steps in accordance with 

Section C - Response to Excursions and Exceedances shall be considered 

deviation from the permit. 

 

(b) The Permittee shall record the caustic injection rate used in conjunction 

with the Cupola #4, at least once per day when the Cupola #4 is in operation 

when exhausting to the atmosphere. When for any one reading, the 

injection rate is outside the normal range of 200-600 pounds of dry sorbent 

per hour or as established during the latest stack test, the Permittee shall 

take reasonable response steps in accordance with Section C- Response to 

Excursions and Exceedances. An injection rate that is outside the above 

mentioned range is not a deviation from this permit. Failure to take 

response steps in accordance with Section C - Response to Excursions and 

Exceedances shall be considered deviation from the permit. 

The instruments used for determining the pressure and caustic injection rate shall 

comply with Section C - 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.1.1113 Record Keeping Requirements 

(a) To document compliance with Condition D.1.9, the Permittee shall maintain daily 

records of the visible emission notations of the two (2) blowchambers, identified 

as EU-P6 and EU-P8, line trimmings/sizing section, identified as EU-P9 and #2 

line cooling section, identified as EU-P10 stack exhaust. The Permittee shall 

include in its daily record when a visible emission notation is not taken and the 

reason for the lack of a visible emission notation, (e.g. the process did not 

operate that day). 

 

(b) To document compliance with Condition D.1.10 the Permittee shall maintain the 

daily records of the pressure drop across the baghouse controlling the #2 line 
Thermafiber Inc. Page 10 of 11 

Wabash, Indiana Significant Source Modification No.: 169-27407-00009 

Permit Reviewer: Madhurima Moulik Significant Permit Modification No.: 169-27436-00009 

trimming/sizing section. The Permittee shall include in its daily record when a 

pressure drop reading is not taken and the reason for the lack of a pressure drop 

reading, (e.g. the process did not operate that day). 

(c) To document compliance with Condition D.1.12, the Permittee shall maintain a 

log of weekly particulate observations, and daily and monthly inspection of the 

filters. 

(d) To document compliance with Condition D.1.12, the Permittee shall 

maintain daily records of the caustic injection rate controlling Cupola #4. 

The Permittee shall include in its daily record when a reading is not taken 

and the reason for the lack of a reading, (e.g. the process did not operate 

that day). 

 

(d e) All records shall be maintained in accordance with Section C - General Record 

Keeping Requirements of this permit. 

D.1.14 Reporting Requirements 

A quarterly summary of the information to document compliance with Condition D.1.2(a) 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 their equivalent, within 

thirty (30) days after the end of the quarter being reported. The report submitted by the 

Permittee does require the certification by the “responsible official” as defined by 326 IAC 2-7-

1(34). 

SECTION E EMISSIONS UNIT OPERATION CONDITIONS 

Emissions Unit Description: NESHAP Subpart DDD 

 

 (a) One (1) coke-fueled cupola #2, identified as EU-P2, constructed in 1955, refurbished in 

1995, and modified in 2009, natural gas supplemented, with a maximum capacity of 

10.47 MMBtu/hr, equipped with a 10.0 mmBTU/hr natural gas fired thermal oxidizer 

EU-P2A and a baghouse, exhausting through Stack S1, constructed in 2003, with a 

maximum capacity of 8.5 tons of minerals per hour. 

(b) One coke-fueled cupola #4, identified as EU-P4, constructed in 1955, and refurbished 

in 1994, and modified in 2009, natural gas supplemented, with a maximum capacity of 

10.47 MMBtu/hr, equipped with a 10.0 mmBTU/hr natural gas fired thermal oxidizer 

EU-P4A, a caustic injection system for control of SO2 emissions, and a 

baghouse, exhausting through Stack S3, constructed in 2003, with a maximum 

capacity of 9.5 tons of minerals per hour. 

 

 (c) One (1) natural gas-fired curing oven #2, identified as EU-P7, with a maximum capacity 

of 5.7 million British thermal units per hour, exhausting through Stack S5, constructed 

in 1955 and replaced in 1978, with a maximum capacity of 7.0 tons of fiberized 

minerals per hour and emissions controlled by regenerative thermal oxidizer, (RTO), 

constructed in 2002. 

(The information describing the process contained in this emissions unit description box is descriptive 

information and does not constitute enforceable conditions.) 

 
Thermafiber Inc. Page 11 of 11 

Wabash, Indiana Significant Source Modification No.: 169-27407-00009 

Permit Reviewer: Madhurima Moulik Significant Permit Modification No.: 169-27436-00009 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

PART 70 OPERATING PERMIT QUARTERLY REPORT

Source Name: Thermafiber, Inc Wabash Plant 

Source Address: 3711 Mill Street, Wabash, Indiana 46992 

Mailing Address: 3711 Mill Street, Wabash, IN 46992 

Part 70 Permit No.: T169-21103-00009 

Facility: Cupola #2 and #4 

Parameter: SO2 emissions 

Limit: 620 tons per 12 consecutive month period 

 

Cupola #4 

YEAR: QUARTER: 

Column 1 Column 2 Column 1 + Column 2 

Month 

This Month Previous 11 Months 12 Month Total 

  No deviation occurred in this quarter. 

  Deviation/s occurred in this quarter. 

 Deviation has been reported on: 

 

Submitted by: 

Title/Position: 

Signature: 

Date: 

Telephone: 

Attach a signed certification to complete this report. 

Conclusion and Recommendation 

The construction and operation of this proposed modification shall be subject to the conditions of 

the attached proposed Part 70 Significant Source Modification No. 169-27407-00009 Significant 

Permit Modification No. 169-27436-00009. The staff recommends to the Commissioner that this 

Part 70 Significant Source and Significant Permit Modification be approved. 
Thermafiber

Wabash Indiana

Annual Cupola Emissions and

Impact of Installation of a Thermal Oxidizer

Date: April 23, 2009Permit No. 169-27436-00009 Page 1 of 2

Rated capacity, 

tons/hr

Annual 

Throughput 

Potential, 

tons/year

Actual 

Throughput 

Baseline, 

tons/year

Future Projected 

Actual 

Throughput, 

tons/year

Throughput that 

could have been 

accomodated, 

tons/year

Thermal Oxidizer 

Rated Capacity, 

MMBtu/hr

%S input 

Reduction

VOC and 

destructi

Efficienc

Cupola #2 8.5 74,460 42,589 56,000 13,412 10.0 2% 99% Cupola #4 9.5 83,220 48,710 64,000 15,291 10.0 2% 99% Cupola Emission Factors, pounds/ton 

SO2 CO VOCs COS NOx PM/PM10

Cupola #2 before Mod. 13.3 0.00901Cupola #4 before Mod. 12.2 0.00788Cupola #2 after mod. 13.03 0.00901

Cupola #4 after Mod. 3.59 0.00788Thermal Oxidizer Emission Factors,RTO #2, NG CombustionRTO #4, NG CombustionRTO #2 TRS Conversion 3.40RTO #4 TRS Conversion 1.17Baseline Emissions, tons/year

SO2 CO VOCs COS NOx PM/PM10

Cupola #2 283.2 5323.6 63.9 63.9 34.1 0.19Cupola #4 297.1 6088.7 73.1 73.1 39.0 0.19

Total 580.3 11412.3 136.9 136.9 73.0 0.38

Future Projected Actual Emissions From the Cupola, tons/year

SO2 CO VOCs COS NOx PM/PM10

Cupola #2 364.952 70 0.84 0.84 44.8 0.25Cupola #4 114.7776 80 0.96 0.96 51.2 0.25

Total 479.7 150.0 1.8 1.8 96.0 0.5

Cupola Emissions that Could have Been Accomodated, tons/year

SO2 CO VOCs COS NOx PM/PM10

Cupola #2 1676.4 20.1 20.1 10.7 0.06Cupola #4 1911.3 22.9 22.9 12.2 0.06

Total 0.0 3587.8 43.1 43.1 23.0 0.1

SO2 CO VOCs COS NOx PM/PM10

Cupolas #2 & #4 -100.6 -14850.0 -178.2 -178.2 0.0 0.0

Table 1 - Unit Capacities, Production Levels and Emission Factors used in ATPA Assessment

250 3 3 1.6

2.5 0.03 0.03 1.6

0.6 NA lbs/MMCF

Table 2: Actual to Projected Actual for Existing Cupola

lbs/ton 

84 5.5 100 7.6

Actual to Projected Actual Emissions for the Cupolas 
Thermafiber

Wabash Indiana

Annual Cupola Emissions and

Impact of Installation of a Thermal Oxidizer

Page 2 of 2

SO2 CO VOCs COS NOx PM/PM10

RTO #2, NG Combustion 0.026 3.7 0.24 4.4 0.3RTO #4, NG Combustion 0.026 3.7 0.24 4.4 0.3RTO #2 TRS Conversion 95.2RTO #4 TRS Conversion 37.4

Total 132.7 7.4 0.48 0 8.8 0.7

SO2 CO VOCs COS NOx PM/PM10

Cupolas #2 and #4 -100.6 -14850.0 -178.2 -178.2 0.0 0.0

Thermal Oxidizers 132.7 7.4 0.5 0.0 8.8 0.7

Cupolas and Thermal 

Oxidizers 32.1 -14842.6 -177.7 -178.2 8.8 0.7

PSD Major Modification 

Thresholds 40 100 40 NA 40 25/15

Nov 23, 2006 to Nov 22, 2007

Nov 23, 2007 to Nov 22, 2008

2 year average, tons

Shift 1 14597 14737Shift 2 12330 13021Shift 3 15054 15438

41981 43196 42588.5

Shift 1 16588 16542Shift 2 14787 14908Shift 3 17160 17434

48535 48884 48709.5

Production on #2 Bonded Line

Production on #4 Granulated Line

Table 3 - Actual to Projected Actual for the RTO Units (Baseline Assumed to be = zero; Projected Actual = Potential)

Table 4: Actual to Projected Actual for the Cupola and RTO units
INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

We Protect Hoosiers and Our Environment. 

Mitchell E. Daniels Jr. 100 North Senate Avenue 

Governor Indianapolis, Indiana 46204 

(317) 232-8603 

Thomas W. Easterly Toll Free (800) 451-6027 

Commissioner www.idem.IN.gov 

 Recycled Paper An Equal Opportunity Employer Please Recycle 

SENT VIA U.S. MAIL: CONFIRMED DELIVERY AND SIGNATURE REQUESTED 

TO: Kale Sparling

Thermfiber, Inc. 

3711 Mill Stret 

 Wabash, Indiana 46992 

 

DATE: July 22, 2009 

FROM: Matt Stuckey, Branch Chief 

 Permits Branch 

 Office of Air Quality 

SUBJECT: Final Decision 

 Part 70 SPM 

 169-27436-00009 

Enclosed is the final decision and supporting materials for the air permit application referenced above. 

Please note that this packet contains the original, signed, permit documents. 

The final decision is being sent to you because our records indicate that you are the contact person for this 

application. However, if you are not the appropriate person within your company to receive this document, 

please forward it to the correct person. 

A copy of the final decision and supporting materials has also been sent via standard mail to: 

Eric Ryder (Thermfiber, Inc.) 

OAQ Permits Branch Interested Parties List 

If you have technical questions regarding the enclosed documents, please contact the Office of Air Quality, 

Permits Branch at (317) 233-0178, or toll-free at 1-800-451-6027 (ext. 3-0178), and ask to speak to the 

permit reviewer who prepared the permit. If you think you have received this document in error, please 

contact Joanne Smiddie-Brush of my staff at 1-800-451-6027 (ext 3-0185), or via e-mail at 

jbrush@idem.IN.gov. 

Final Applicant Cover letter.dot 11/30/07
INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

We Protect Hoosiers and Our Environment. 

Mitchell E. Daniels Jr. 100 North Senate Avenue 

Governor Indianapolis, Indiana 46204 

(317) 232-8603 

Thomas W. Easterly Toll Free (800) 451-6027 

Commissioner www.idem.IN.gov 

 Recycled Paper An Equal Opportunity Employer Please Recycle 

July 22, 2009 

TO: Wabash Carnegie Public Library 

From: Matthew Stuckey, Branch Chief 

 Permits Branch 

 Office of Air Quality 

Subject: Important Information for Display Regarding a Final Determination 

 Applicant Name: Thermfiber, Inc. 

 Permit Number: 169-27436-00009 

You previously received information to make available to the public during the public comment 

period of a draft permit. Enclosed is a copy of the final decision and supporting materials for the 

same project. Please place the enclosed information along with the information you previously 

received. To ensure that your patrons have ample opportunity to review the enclosed permit, we 

ask that you retain this document for at least 60 days. 

The applicant is responsible for placing a copy of the application in your library. If the permit 

application is not on file, or if you have any questions concerning this public review process, 

please contact Joanne Smiddie-Brush, OAQ Permits Administration Section at 1-800-451-6027, 

extension 3-0185. 

Enclosures 

Final Library.dot 11/30/07 

 
FACSIMILIE OF PS Form 3877 

Mail Code 61-53 

IDEM Staff DPABST 7/22/2009 

Thermafiber Incorporated 169-27436-00009 (final)

Name and address of Sender ► Indiana Department of Environmental Management Office of Air Quality – Permits Branch 

100 N. Senate Indianapolis, IN 46204 

Type of Mail: 

CERTIFICATE OF 

MAILING ONLY 

AFFIX STAMP HERE IF USED AS CERTIFICATE OF MAILING 

Line Article 

Number 

Name, Address, Street and Post Office Address Postage Handing 

Charges 

Act. Value (If Registered) 

Insured Value 

Due Send if COD 

RF

1 Kale Sparling Thermafiber Incorporated 3711 Mill St Wabash IN 46992 (Source CAATS) via confirmed delivery 2 Eric Ryder Dir - Mfg Thermafiber Incorporated 3711 Mill St Wabash IN 46992 (RO CAATS)3 Wabash County Commissioners 1 West Hill Street Wabash IN 46992 (Local Official)4 Wabash City Council and Mayors Office 202 South Wabash Street Wabash IN 46992 (Local Official)5 Wabash County Health Department 89 W. Hill, Memorial Hall Wabash IN 46992-3184 (Health Department)6 Ted Little Wabash County Council 1076 West 900 North North Manchester IN 46962 (Affected Party)7 Wabash Carnegie Public Library 188 W Hill St Wabash IN 46992-3048 (Library)8 9 10 11 12 13 14 15 Total number of pieces Listed by Sender 6 

Total number of Pieces Received at Post Office 

Postmaster, Per (Name of Receiving employee) 

The full declaration of value is required on all domestic anmaximum indemnity payable for the reconstruction of non

Mail document reconstructing insurance is $50,000 per pioccurrence. The maximum indemnity payable on ExpresThe maximum indemnity payable is $25,000 for registereinsurance. See Domestic Mail Manual R900, S913, an

inured and COD mail. See International Mail Manual fomail. Special handling charges apply only to Standard Ma