**MEMORANDUM**

Date: June 6 , 20 1 3 Subject: Report of May 30 , 201 3 Site Visit to Essroc , Lo gansport, IN From: Tanya Parise , EC/R Incorporated To: Mary

Tom Kissell , U.S. Environmental Protection Agency
This memo summarizes the site visit to the Essroc fa cility in Lo gansport, IN , which was conducted on May 30 , 201 3 . Th e purposes of this visit were to:

 Enhance understanding of current processes and emission controls for the off
- site waste and recovery

operations (OSWRO) at the facility
.  Gain an understanding of the other applicable Clean Air Act regulations for the facility , including 40 CFR 264, 265, 279 and 40 CFR Parts 60, 61 and 63.  Clarify

any questions the U.S. EPA has regarding the response received from the recent information collection request for this facility
. The participants in the site visit included the following: **Essroc .**  David A. Constant

– Senior Environmental Engineer Sara Leeman

– Environmental Manager **US EPA** Mary Tom Kissell **EC/R Incorporated**  Lesley Stobert Tanya Parise This memo includes a b rief overview of this proj ect, an overview of the Essroc facility , and is followed b y a description of the specific information gathered during the visit
. **BACKGROUND** Section 112 of the Clean Air Act (CAA) establishes a two
- stage regulatory process to address emissions of hazardous air pollutants (HAP) from stationary sources. In the first stage, CAA section 112(d) requires us to promulgate technology
- based national emi ssion standards for each major source category listed under section 112(c). These technology
- based standards are often referred to as maximum achievable control technology , or MACT, standards. The National2

Emissions Standards for Hazardous Air Pollutants (NESHAP) for O ff
- Site Waste and Recovery Operations were promulgated on July 1, 1996 (61 FR 34140), and codified at 40 CFR part 63, subpart DD. The final rule was amended on July 20, 1999 (64 FR 38950)
. In the second stage of the regulatory process, the EPA is then required under CAA section 112(d)(6) to review these technology
- based standards and revise them “as necessary (taking into account developments in practices, processes, and control technologies)” no less frequentl y than every eight years. In addition, w ithin 8 years after promulgation of the MACT standards , CAA section 112(f)(2) requires the EPA to promulgate standards , if required , t o provide an ample margin of s afet y to protect public health or to prevent, taking into consideration costs , energy , safet y, and other relevant factors, an adverse environmental effect. This second stage in standard setting is referred to as the residual risk and technology review (RTR) for the standards. The EPA is in the process of conducting the RTR for the OSWRO MACT standards. As part of the RTR process, this Essroc production facility was selected for a site visit for three primary reasons: (1) it is one of several OSWRO facilities in or near the Chicago, IL area, which would enable the EPA to see several facilities in one trip, (2) based on available emissions data in the EPA’s National Emissions Inventory (NEI), this facility

had one of the higher emission rates of the OSWRO facilities identified in that database, and (3) visiting this facility would all ow the EPA to view a facility that handles waste, but whose primary line of business is not waste management , and to learn how waste is utilized in the cement production industry
. **PLANT SITE OVERVIEW** The Essroc Cement Corporation facilit y is located at 3084 West County Road 225 South, Lo gansport, IN. The Lo gansport Essroc facility is a cement production company that has been in business for 75 years. This cement manufacturing facility acquires limestone on site, which is then crushed in various steps. Th e raw materials are then mixed and ground with water (i.e., wet process) to generate a slurry mixture wh ich is then fed to a kiln. The kiln heats the material to extremely high temperatures and moves the material through the kiln. During the process some m aterial separates out as gases and the remaining material develops into the product called clinker. The clinker is then ground and cooled and subsequently mixed with gy

psum to produce Portland cement. The plant handles and integrates waste received fro m off
- site sources into facility operations as a fuel source for the kiln
. The kiln itself is the primary control device at the Essroc facility and the goal is to have the kiln running 90 percent of the time. According to Essroc representatives, the inside of the kiln is lined with a refractory shell to protect the metal from the high temperatures , and the kiln has to be shut down sometimes to protect the kiln shell. Inthe event the kiln is non
- operational, the facilit y uses carbon bed s as the backup control device for the non
- kiln operations, including the OSWRO storage tanks
. According to Essroc representatives, operations at Essroc are profitable and there are no plans to modernize the facility from the wet process to a dry process in the next 5
- 10 years. The operations are continuous, with operations occurring 24 hours a day , 7 day s a week.3

The facility receives waste from several businesses (more than 80)
. Th is facility is subject to the O SWRO MACT (subpart DD), the Hazardous Waste Combustor MACT (subpart EEE), the Portland Cement MACT (subpart LLL), and also the Resource Conservation and Recovery Act (RCRA) regulations
. **INFORMATION GATHERED DURING VISIT** The following section describe s the information gathered in relation to the three stated purposes of the visit. 1. Enhance understanding of current processes and emission controls for the off
- site waste and recovery

operations (OSWRO) at the facility
.  The facility

uses diesel fuel to start up the kiln, but then switches to burnin g waste fuel in the kiln.  The facility

receives waste in containers by trailer trucks, tanker trucks and by railcar.  Essroc receives waste in liquid, solid, and sludge form. The liquid waste is primarily waste solvents containing mostly organic liquids.  T he solid and sludge waste the facilit y receives consists of gelled resins, paint pigments, rubber
- based materials, wood, silica, clay , and solid still bottoms (i.e., tar).  Prior to being burned in the kiln, the facility tests the waste fuel for various pro perties. The fuel is analyzed to ensure it complies with the kiln fuel specifications.  The waste fuel heating value is the primary concern.  There are limits on the properties that cannot be fed to the kiln ( e.g., high concentration s of metals )
.  The rotary kiln is the primary control device at the facility, with carbon bed s as the backup. 2. Gain an understanding of the other applicable Clean Air Act regulations for the facility , includin g 40 CFR 264, 265, 279 and 40 CFR Parts 60, 61 and 63.

 The facility

c omplies with the OSWRO MACT (subpart DD), the Hazardous Waste Combustor MACT (subpart EEE), the Portland Cement MACT (subpart LLL), and also the Resource Conservation and Recovery Act (RCRA) regulations. 3. Clarify

any questions the U.S. EPA has regarding the response received from the recent information collection request for this facility
.  Ms. L eeman agreed to send information about storage tanks that was requested in the CAA section 114 information request but that was not provided in the response to th at request.