INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

 We make Indiana a cleaner, healthier place to live. 

Mitchell E. Daniels, Jr. 100 North Senate Avenue 

Governor MC 61-53 IGCN 1003 

 Indianapolis, Indiana 46204-2251 

Thomas W. Easterly (317) 232-8603 

Commissioner (800) 451-6027 

 www.IN.gov/idem 

 Recycled Paper An Equal Opportunity Employer Please Recycle 

 Part 70 Operating Permit Renewal 

OFFICE OF AIR QUALITY 

Johns Manville International, Inc. 

814 Richmond Ave 

Richmond, Indiana 47374 

(herein known as the Permittee) is hereby authorized to operate subject to the conditions contained 

herein, the source described in Section A (Source Summary) of this permit. 

The Permittee must comply with all conditions of this permit. Noncompliance with any provisions 

of this permit is grounds for enforcement action; permit termination, revocation and reissuance, 

or modification; or denial of a permit renewal application. Noncompliance with any provision of 

this permit, except any provision specifically designated as not federally enforceable, constitutes 

a violation of the Clean Air Act. It shall not be a defense for the Permittee in an enforcement 

action that it would have been necessary to halt or reduce the permitted activity in order to 

maintain compliance with the conditions of this permit. An emergency does constitute an 

affirmative defense in an enforcement action provided the Permittee complies with the applicable 

requirements set forth in Section B, Emergency Provisions. 

This permit is issued in accordance with 326 IAC 2 and 40 CFR Part 70, Appendix A and contains the 

conditions and provisions specified in 326 IAC 2-7 as required by 42 U.S.C. 7401, et. seq. (Clean Air Act 

as amended by the 1990 Clean Air Act Amendments), 40 CFR Part 70.6, IC 13-15 and IC 13-17. 

Operation Permit No.: T177-22598-00006 

Issued by: 

Matt Stuckey, Deputy Branch Chief 

Permits Branch 

Office of Air Quality 

Issuance Date: 

Expiration Date: 
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Permit Reviewer: ERG/BL 

TABLE OF CONTENTS 

A. SOURCE SUMMARY...............................................................................................................................3

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 ........................................................................................................................3

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....................................................................................................3

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

C.1 Opacity [326 IAC 5-1]

C.2 Open Burning [326 IAC 4-1] [IC 13-17-9]

C.3 Incineration [326 IAC 4-2] [326 IAC 9-1-2]

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

C.5 Stack Height [326 IAC 1-7]

C.6 Asbestos Abatement Projects [326 IAC 14-10] [326 IAC 18] [40 CFR 61, Subpart M]

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

C.7 Performance Testing [326 IAC 3-6]
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Compliance Requirements [326 IAC 2-1.1-11]

C.8 Compliance Requirements [326 IAC 2-1.1-11]

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

C.9 Compliance Monitoring [326 IAC 2-7-5(3)][326 IAC 2-7-6(1)]

C.10 Monitoring Methods [326 IAC 3] [40 CFR 60] [40 CFR 63]

C.11 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.12 Emergency Reduction Plans [326 IAC 1-5-2] [326 IAC 1-5-3]

C.13 Risk Management Plan [326 IAC 2-7-5(12)] [40 CFR 68]

C.14 Response to Excursions or Exceedances [326 IAC 2-7-5] [326 IAC 2-7-6]

C.15 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 General Record Keeping Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-6] 

 [326 IAC 2-2]

C.18 General Reporting Requirements [326 IAC 2-7-5(3)(C)] [326 IAC 2-1.1-11] 

 [326 IAC 2-2]

Stratospheric Ozone Protection

C.19 Compliance with 40 CFR 82 and 326 IAC 22-1

D.1. EMISSIONS UNIT OPERATION CONDITIONS, Raw Material Handling, Storage and Batching 

Equipment for Lines 2 and 3....................................................................................................................28

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

D.1.1 Particulate Matter (PM) [326 IAC 6.5-1-2(a)] 

D.1.2 PSD Limitations [326 IAC 2-2-3]

D.1.3 PSD Minor Modification Limitations [326 IAC 2-2]

D.1.4 Preventive Maintenance Plan [326 IAC 2-7-5(13)]

Compliance Determination Requirements

D.1.5 Particulate Matter (PM) Control

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

D.1.6 Visible Emissions Notations

D.1.7 Parametric Monitoring

D.1.8 Broken or Failed Bag Detection

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

D.1.9 Record Keeping Requirements

D.2. EMISSIONS UNIT OPERATION CONDITIONS, Electric Melter ......................................................32

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

D.2.1 PSD Minor Modification Limit [326 IAC 2-2] 

D.2.2 Particulate Matter (PM) Emission Limitations [326 IAC 6.5-1] 

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

Compliance Determination Requirements

D.2.4 Particulate Matter (PM) Control 

D.2.5 Testing Requirements [326 IAC 2-7-6(1),(6)] 
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Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

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

D.2.6 Visible Emissions Notations

D.2.7 Parametric Monitoring 

D.2.8 Broken or Failed Bag Detection

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

D.2.9 Record Keeping Requirements

D.3. EMISSIONS UNIT OPERATION CONDITIONS, Forming Facilities................................................35

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

D.3.1 PSD BACT Limitations [326 IAC 2-2-3(a)(3)]

D.3.2 PSD Minor Limitations [326 IAC 2-2]

D.3.3 Particulate Limitations Except Lake County [326 IAC 6.5-10-11]

D.3.4 Preventive Maintenance Plan [326 IAC 2-7-5(13)]

Compliance Determination Requirements

D.3.5 Control Device Operating Conditions

D.3.6 Testing Requirements [326 IAC 2-7-6(1),(6)] [326 IAC 2-1.1-11]

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

D.3.7 Visible Emissions Notations

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

D.3.8 Record Keeping Requirement

New Source Performance Standards (NSPS) Requirements [326 IAC 2-7-5(1)]

D.3.9 General Provisions Relating to New Source Performance Standards [326 IAC 12-1] [40 CFR 

 Part 60, Subpart A]

D.3.10 New Source Performance Standards for Wool Fiberglass Insulation Manufacturing Plants: 

 Requirements [40 CFR Part 60, Subpart PPP]

D.4. EMISSIONS UNIT OPERATION CONDITIONS, Shredding and Packaging Facilities..................40

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

D.4.1 PSD Minor Modification Limitations [326 IAC 2-2]

D.4.2 Particulate Matter [336 IAC 6.5-1-2]

D.4.3 Preventive Maintenance Plan [326 IAC 2-7-5(13)]

Compliance Determination Requirements

D.4.4 Particulate Matter

D.4.5 Testing Requirements [326 IAC 2-7-6(1),(6)] [326 IAC 2-1.1-11]

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

D.4.6 Visible Emissions Notations

D.4.7 Parametric Monitoring 

D.4.8 Broken or Failed Bag Detection

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

D.4.9 Record Keeping Requirements 

D.5. EMISSIONS UNIT OPERATION CONDITIONS, Ancillary Equipment............................................43

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

D.5.1 PSD Limitations [326 IAC 2-2-3]

D.5.2 PSD Minor Modification Limitations [326 IAC 2-2] 
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D.5.3 Particulate Emission Limitations [326 IAC 6.5] 

D.5.4 Sulfur Dioxide Emission Limitations [326 IAC 7-4-4] 

D.5.5 Preventive Maintenance Plan [326 IAC 2-7-5(13)] 

Compliance Determination Requirements

D.5.6 Particulate Matter

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

D.5.7 Broken or Failed Bag Detection

D.6. EMISSIONS UNIT OPERATION CONDITIONS, Degreasing Operations.......................................45

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

D.6.1 Volatile Organic Compounds (VOC) [326 IAC 8-3-2]

D.6.2 Volatile Organic Compounds (VOC) [326 IAC 8-3-5]

Certification .................................................................................................................................................47

Emergency Occurrence Report ..................................................................................................................48

Semi-Annual Natural Gas Fired Boiler Certification....................................................................................50

Quarterly Deviation and Compliance Monitoring Report ............................................................................52
Johns Manville International, Inc. Page 6 of 52 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

SECTION A SOURCE SUMMARY 

This permit is based on information requested by the Indiana Department of Environmental Management 

(IDEM), Office of Air Quality (OAQ). The information describing the source contained in conditions A.1 

through A.4 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 a fiberglass insulation manufacturing plant. 

Source Address: 814 Richmond Ave, Richmond, Indiana 47374 

Mailing Address: 814 Richmond Ave, Richmond, IN 47374 

General Source Phone Number: (765) 973-5243 

SIC Code: 3296 

County Location: Wayne 

Source Location Status: Attainment for all criteria pollutants 

Source Status: Part 70 Operating Permit Program 

 Major Source, under PSD Rules 

Minor 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) Raw Material Handling, Storage and Batching Equipment for Lines 2 and 3: 

(1) One (1) Rail car Receiving station; with a maximum capacity of 40.5 tons per 

hour, installed in 1967, and exhausting to stack S165. The raw materials received 

in rail cars are bottom unloaded into a screw conveyor that transfers the material 

to the storage silos via a bucket elevator and a diverter. The particulate emissions 

are controlled by a boot lift device that seals off the bottom of the rail car and a 

baghouse; 

(2) Eight (8) Raw Material Silos, installed in 1967. Raw materials are loaded into the 

batch silos and vented to fabric filters to control particulate emissions in the 

airstream before it is exhausted to emission points S21 through S28. The silo 

capacities are as follows: Silo #1 - 152 tons, Silo #2 - 23 tons, Silo #3 - 134 tons, 

Silo #4 - 51.8, Silo #5 - 106.7, Silo #6 - 54.6, Silo #7 - 101.3, and Silo #8 - 149.9. 

(3) Two (2) day bins; identified as Day Bin 1 and Day Bin 2; constructed in 2006; 

each with a maximum storage capacity of 57.5 tons; emissions controlled by 

baghouses (BH167 and BH168); exhausting to stacks S167 and S168. Product 

from the mixer is transferred to the day bins using an enclosed conveyor system. 

(4) One (1) Mixer; constructed in 2006; a maximum capacity of 20,125 pounds of raw 

materials per hour; emissions controlled by a sock filter; exhausting indoors to 

general ventilation. Raw materials from the storage silos are weighed and 

transferred to the mixer. 

(5) One (1) Batch Transfer System; constructed in 2006; a maximum capacity of 

20,125 pounds of raw materials per hour; emissions controlled by a baghouse; 
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exhausting indoors to general ventilation. Processed materials from the mixer are 

transferred to the day bins via the batch delivery/bucket elevator system. 

(6) One (1) Weigh Scale; constructed in 1967; a maximum capacity of 20,125 pounds 

of raw materials per hour; emissions controlled by a sock filter; exhausting indoors 

to general ventilation. Raw materials from the storage silos are weighed and 

transferred to the mixer. 

(b) One (1) Electric Melter; constructed in 2006; a maximum production rate of 20,125 pounds 

of molten glass per hour; emissions controlled by a baghouse and exhausting to stack 

S166. The molten glass flows from the melter to the Line 2 and Line 3 fiber 

forming/collection modules. 

(c) Forming Facilities: 

(1) One (1) Line 2 Forming and Collection Module; installed in 1961 and modified in 

2000 and 2006; consisting of a rotary spinner and collection conveyor; with a 

maximum unbonded glass production rate of 9,450 pounds per hour. Natural gas 

is utilized in the combustion section of the forming chamber. The maximum heat 

input capacity of the combustion section has been included in an OAQ confidential 

file. As fibers are formed, they are carried in the airstream towards a moving 

collection chain where they are captured and transferred to the shredding 

process. A water spray is applied to the airstream to control particulate matter 

emissions before the airstream is exhausted to stack S2. Under 40 CFR Part 60, 

Subpart PPP, this facility is considered a spin wool fiberglass insulation 

manufacturing line. (Formerly referred to as the Line 2 forming chamber for 

unbonded product) 

(2) One (1) Line 3 Forming and Collection Module; installed in 1961 and modified in 

2000 and 2006; consisting of a rotary spinner and collection conveyor; with a 

maximum unbonded glass production rate of 8,100 pounds per hour. Natural gas 

is utilized in the combustion section of the forming chamber. The maximum heat 

input capacity of the combustion section has been included in an OAQ confidential 

file. As fibers are formed, they are carried in the airstream towards a moving 

collection chain where they are captured and transferred to the shredding 

process. A water spray is applied to the airstream to control particulate matter 

emissions before the airstream is exhausted to stack S3. Under 40 CFR Part 60, 

Subpart PPP, this facility is considered a spin wool fiberglass insulation 

manufacturing line. (Formerly referred to as the Line 3 forming chamber for 

unbonded product) 

(d) Shredding and Packaging Facilities: 

(1) One (1) Line 2 shredding process for unbonded product, installed in 1994, with a 

maximum capacity of 9,450 pounds per hour. The shredded fiber is pneumatically 

transferred to the packaging area. During the shredding process an anti-static 

agent and oil are applied to the product and any particulate emissions in the 

airstream are controlled by a baghouse system before the airstream is exhausted 

to Stacks S85, S86 and S87; 

(2) One (1) Line 2 packaging area for unbonded product, installed in 1994 and 

modified in 2006. The airstream is separated from the unbonded shredded 

product via a rotary condensor. Fiberglass collected in the rotary condensor is 

deposited in the packaging hopper and subsequently packaged for sale using a 

bagging system. The particulate emissions in the rotary condensor airstream are 

controlled by a baghouse system before the airstream is exhausted to Stacks 
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S85, S86 and S87. The total maximum capacity of Line 2 and Line 3 packaging 

areas is 27,540 pounds per hour; 

(3) One (1) Line 3 shredding process for unbonded product, installed in 1993, with a 

maximum capacity of 8,100 pounds per hour. The shredded fiber is pneumatically 

transferred to the packaging area. During the shredding process an anti-static 

agent and oil are applied to the product and any particulate emissions in the 

airstream are controlled by a baghouse system before the airstream is exhausted 

to Stacks S12, S13 and S14; and 

(4) One (1) Line 3 packaging area for unbonded product, installed in 1993 and 

modified in 2006. The airstream is separated from the unbonded shredded 

product via a rotary condensor. Fiber glass collected in the rotary condensor is 

deposited in the packaging hopper and subsequently packaged for sale using a 

bagging system. The particulate matter emissions in the rotary condensor 

airstream are controlled by a baghouse system before the airstream is exhausted 

to Stacks S12, S13 and S14. The total maximum capacity of Line 2 and Line 3 

packaging areas is 27,540 pounds per hour. 

(e) One (1) natural gas-fired boiler, identified as B-2, installed in 1961, with a rated capacity of 

25 MMBtu per hour. The airstream from the boiler is exhausted to stack S4. 

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): 

(a) One (1) melter dust recycling system, installed in 1961 and modified in 1999 and 2006, 

and exhausted to stack S34 [326 IAC 2-2] [326 IAC 6.5-10-11]. 

(b) One (1) cold end housekeeping system, installed in 1988, with a total production capacity 

of 17,550 pounds per hour. The particulate emissions in the airstream are controlled by a 

baghouse before the airstream is exhausted indoors to general ventilation [326 IAC 2-2] 

[326 IAC 6.5-10-11]. 

(c) Two (2) degreasing operations, constructed in 2006, that do not exceed 145 gallons per 

12 months and are not subject to 326 IAC 20-6 [326 IAC 8-3-2][326 IAC 8-3-5]. 

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); 

(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). 
Johns Manville International, Inc. Page 9 of 52 

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SECTION B GENERAL CONDITIONS

B.1 Definitions [326 IAC 2-7-1] 

Terms in this permit shall have the definition assigned to such terms in the referenced regulation. 

In the absence of definitions in the referenced regulation, the applicable definitions found in the 

statutes or regulations (IC 13-11, 326 IAC 1-2 and 326 IAC 2-7) shall prevail. 

B.2 Permit Term [326 IAC 2-7-5(2)][326 IAC 2-1.1-9.5][326 IAC 2-7-4(a)(1)(D)][IC 13-15-3-6(a)] 

(a) This permit, T177-22598-00006, 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. 

(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. 
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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) The "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 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. 
Johns Manville International, Inc. Page 11 of 52 

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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) 
Johns Manville International, Inc. Page 12 of 52 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

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 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. 
Johns Manville International, Inc. Page 13 of 52 

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Permit Reviewer: ERG/BL 

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)] 
Johns Manville International, Inc. Page 14 of 52 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

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 T177-22598-00006 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. 

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 Data Section, 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: 

(1) That this permit contains a material mistake. 
Johns Manville International, Inc. Page 15 of 52 

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Permit Reviewer: ERG/BL 

(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 

Permits Branch, 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. 
Johns Manville International, Inc. Page 16 of 52 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

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

submitted to: 

Indiana Department of Environmental Management 

Permits Branch, Office of Air Quality 

100 North Senate Avenue 

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). 

(c) The Permittee may implement administrative amendment changes addressed in the 

request for an administrative amendment immediately upon submittal of the request. 

[326 IAC 2-7-11(c)(3)] 

B.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 

Permits 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, Regulation Development Branch - Indiana (AR-18J) 
Johns Manville International, Inc. Page 17 of 52 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

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. 

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

(a) A modification, construction, or reconstruction is governed by the requirements of 

326 IAC 2 and 326 IAC 2-7-10.5. 

 

(b) Any modification at an existing major source is governed by the requirements of 

326 IAC 2-2 (for sources located in NA areas). 
Johns Manville International, Inc. Page 18 of 52 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

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 

Permits Branch, 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)] 

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. 
Johns Manville International, Inc. Page 19 of 52 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

(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. 
Johns Manville International, Inc. Page 20 of 52 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

SECTION C SOURCE OPERATION CONDITIONS 

Entire Source 

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

C.1 Opacity [326 IAC 5-1] 

Pursuant to 326 IAC 5-1-2 (Opacity Limitations), except as provided in 326 IAC 5-1-3 (Temporary 

Alternative Opacity Limitations), opacity shall meet the following, unless otherwise stated in this 

permit: 

(a) Opacity shall not exceed an average of forty percent (40%) in any one (1) six (6) minute 

averaging period as determined in 326 IAC 5-1-4. 

(b) Opacity shall not exceed sixty percent (60%) for more than a cumulative total of fifteen 

(15) minutes (sixty (60) readings as measured according to 40 CFR 60, Appendix A, 

Method 9 or fifteen (15) one (1) minute nonoverlapping integrated averages for a 

continuous opacity monitor) in a six (6) hour period. 

C.2 Open Burning [326 IAC 4-1] [IC 13-17-9] 

The Permittee shall not open burn any material except as provided in 326 IAC 4-1-3, 

326 IAC 4-1-4 or 326 IAC 4-1-6. The previous sentence notwithstanding, the Permittee may 

open burn in accordance with an open burning approval issued by the Commissioner under 

326 IAC 4-1-4.1.

C.3 Incineration [326 IAC 4-2] [326 IAC 9-1-2] 

The Permittee shall not operate an incinerator or incinerate any waste or refuse except as 

provided in 326 IAC 4-2 and 326 IAC 9-1-2.

C.4 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.5 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. 

C.6 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 

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 
Johns Manville International, Inc. Page 21 of 52 

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Permit Reviewer: ERG/BL 

(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 

Asbestos Section, 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. 

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

C.7 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: 
Johns Manville International, Inc. Page 22 of 52 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

Indiana Department of Environmental Management 

Compliance Data Section, 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.8 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.9 Compliance Monitoring [326 IAC 2-7-5(3)][326 IAC 2-7-6(1)] 

Unless otherwise specified in this permit, all monitoring and record keeping requirements not 

already legally required shall be implemented within ninety (90) days of permit issuance. If 

required by Section D, the Permittee shall be responsible for installing any necessary equipment 

and initiating any required monitoring related to that equipment. If due to circumstances beyond 

its control, that equipment cannot be installed and operated within ninety (90) days, the Permittee 

may extend the compliance schedule related to the equipment for an additional ninety (90) days 

provided the Permittee notifies: 

Indiana Department of Environmental Management 

Compliance Branch, Office of Air Quality 

100 North Senate Avenue 

MC 61-53 IGCN 1003 

Indianapolis, Indiana 46204-2251 

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. 
Johns Manville International, Inc. Page 23 of 52 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

C.10 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.11 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.12 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.13 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.14 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; 

(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. 
Johns Manville International, Inc. Page 24 of 52 

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Permit Reviewer: ERG/BL 

(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.15 Actions Related to Noncompliance Demonstrated by a Stack Test [326 IAC 2-7-5][326 IAC 2-7-6] 

(a) When the results of a stack test performed in conformance with Section C - Performance 

Testing, of this permit exceed the level specified in any condition of this permit, the 

Permittee shall take appropriate response actions. The Permittee shall submit a 

description of these response actions to IDEM, OAQ, within thirty (30) days of receipt of 

the test results. The Permittee shall take appropriate action to minimize excess 

emissions from the affected facility while the response actions are being implemented. 

(b) A retest to demonstrate compliance shall be performed within one hundred twenty (120) 

days of receipt of the original test results. Should the Permittee demonstrate to IDEM, 

OAQ that retesting in one-hundred and twenty (120) days is not practicable, IDEM, OAQ 

may extend the retesting deadline. 

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

noncompliant stack tests. 

The response action documents submitted pursuant to this condition do require the certification 

by the "responsible official" as defined by 326 IAC 2-7-1(34). 

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

C.16 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(b)(2), starting in 2005 and every three (3) years thereafter, the 

Permittee shall submit by July 1 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); 

(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: 
Johns Manville International, Inc. Page 25 of 52 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

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.17 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/or 326 IAC 2-3-1(ll)) at an 

existing emissions unit, other than projects at a source with a Plantwide Applicability 

Limitation (PAL), which is not part of a “major modification” (as defined in 326 IAC 2-2-

1(ee) and/or 326 IAC 2-3-1(z)) and the Permittee elects to utilize the “projected actual 

emissions” (as defined in 326 IAC 2-2-1(rr) and/or 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/or 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; 

(ii) Projected actual emissions; 

(iii) Amount of emissions excluded under section 

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

and 
Johns Manville International, Inc. Page 26 of 52 

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Permit Reviewer: ERG/BL 

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

(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 Data Section, 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. 

(f) If the Permittee is required to comply with the recordkeeping provisions of (c) in Section 

C- General Record Keeping Requirements for any “project” (as defined in 326 IAC 2-2-1 

(qq) and/or 326 IAC 2-3-1 (ll) at an existing emissions unit, and the project meets the 

following criteria, then the Permittee shall submit a report to IDEM, OAQ : 

(1) The annual emissions, in tons per year, from the project identified in (c)(1) in 

Section C- General Record Keeping Requirements exceed the baseline actual 

emissions, as documented and maintained under Section C - General Record 

Keeping Requirements (c)(1)(C)(i), by a significant amount, as defined in 
Johns Manville International, Inc. Page 27 of 52 

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Permit Reviewer: ERG/BL 

326 IAC 2-2-1 (xx) and/or 326 IAC 2-3-1 (qq), for that regulated NSR pollutant, 

and 

(2) The emissions differ from the preconstruction projection as documented and 

maintained under Section C- General Record Keeping Requirements (c)(1)(C)(ii). 

(g) The report for project at an existing emissions unit shall be submitted within sixty (60) 

days after the end of the year and contain the following: 

(1) The name, address, and telephone number of the major stationary source. 

(2) The annual emissions calculated in accordance with (c)(2) and (3) in Section CGeneral Record Keeping Requirements. 

(3) The emissions calculated under the actual-to-projected actual test stated in 

326 IAC 2-2-2(d)(3) and/or 326 IAC 2-3-2(c)(3). 

 

(4) Any other information that the Permittee deems fit to include in this report, 

Reports required in this part shall be submitted to: 

Indiana Department of Environmental Management 

Air Compliance Section, Office of Air Quality 

100 North Senate Avenue 

MC 61-53 IGCN 1003 

Indianapolis, Indiana 46204-2251 

(h) The Permittee shall make the information required to be documented and maintained in 

accordance with (c) in Section C - General Record Keeping Requirements available for 

review upon a request for inspection by IDEM, OAQ. The general public may request 

this information from the IDEM, OAQ under 326 IAC 17.1. 

Stratospheric Ozone Protection 

C.19 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. 
Johns Manville International, Inc. Page 28 of 52 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

SECTION D.1 FACILITY OPERATION CONDITIONS 

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

(a) Raw Material Handling, Storage and Batching Equipment for Lines 2 and 3: 

(1) One (1) Rail car Receiving station; with a maximum capacity of 40.5 tons per hour, 

installed in 1967, and exhausting to stack S165. The raw materials received in rail cars 

are bottom unloaded into a screw conveyor that transfers the material to the storage silos 

via a bucket elevator and a diverter. The particulate emissions are controlled by a boot lift 

device that seals off the bottom of the rail car and a baghouse; 

(2) Eight (8) Raw Material Silos, installed in 1967. Raw materials are loaded into the batch 

silos and vented to fabric filters to control particulate emissions in the airstream before it 

is exhausted to emission points S21 through S28. The silo capacities are as follows: Silo 

#1 - 152 tons, Silo #2 - 23 tons, Silo #3 - 134 tons, Silo #4 - 51.8, Silo #5 - 106.7, Silo #6 

- 54.6, Silo #7 - 101.3, and Silo #8 - 149.9. 

(3) Two (2) day bins; identified as Day Bin 1 and Day Bin 2; constructed in 2006; each with a 

maximum storage capacity of 57.5 tons; emissions controlled by baghouses (BH167 and 

BH168); exhausting to stacks S167 and S168. Product from the mixer is transferred to 

the day bins using an enclosed conveyor system. 

(4) One (1) Mixer; constructed in 2006; a maximum capacity of 20,125 pounds of raw 

materials per hour; emissions controlled by a sock filter; exhausting indoors to general 

ventilation. Raw materials from the storage silos are weighed and transferred to the 

mixer. 

(5) One (1) Batch Transfer System; constructed in 2006; a maximum capacity of 20,125 

pounds of raw materials per hour; emissions controlled by a baghouse; exhausting 

indoors to general ventilation. Processed materials from the mixer are transferred to the 

day bins via the batch delivery/bucket elevator system. 

(6) One (1) Weigh Scale; constructed in 1967; a maximum capacity of 20,125 pounds of raw 

materials per hour; emissions controlled by a sock filter; exhausting indoors to general 

ventilation. Raw materials from the storage silos are weighed and transferred to the 

mixer. 

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

information and does not constitute enforceable conditions.) 

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

D.1.1 Particulate Matter (PM) [326 IAC 6.5-1-2(a)] 

Pursuant to 326 IAC 6.5-1-2(a), the allowable PM emissions from the following listed equipment: 

Railcar Receiving Station 

S21 Raw Material silo 

S22 Raw Material silo 

S23 Raw Material silo 

S24 Raw Material silo 

S25 Raw Material silo 

S26 Raw Material silo 
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Permit Reviewer: ERG/BL 

S27 Raw Material silo 

S28 Raw Material silo 

S164 raw material day bin 

Day Bin 1 

Day Bin 2 

Mixer 

Batch Transfer System 

Weigh Scale 

Shall each not exceed 0.03 grain per dry standard cubic foot (dscf). 

D.1.2 PSD Limitations [326 IAC 2-2-3] 

Pursuant to CP-177-5873-00006, issued April 22, 1999, and 326 IAC 2-2-3 (Best Available 

Control Technology (BACT)), the raw material handling, storage and batching facilities stated 

above shall comply with the following limitations: 

(a) The Railcar Receiving Station shall be equipped with a bootlift device or similar device 

and shall not exceed an average of three percent (3%) opacity in any 24 consecutive 

readings recorded in 15 second intervals in accordance with the applicable requirements 

of 40 CFR 60, Appendix A, Method 9; 

(b) The raw material conveyor system (which operates as part of the railcar receiving station) 

shall be enclosed and shall not exceed an average of three percent (3%) opacity in any 

24 consecutive readings recorded in 15 second intervals in accordance with the 

applicable requirements of 40 CFR 60, Appendix A, Method 9; and. 

(c) The Raw Material Silos shall be equipped with fabric filters and shall not exceed an 

average of three percent (3%) opacity in any 24 consecutive readings recorded in 15 

second intervals in accordance with the applicable requirements of 40 CFR 60, Appendix 

A, Method 9. 

D.1.3 PSD Minor Modification Limitations [326 IAC 2-2] 

In order to render the requirements of 326 IAC 2-2 not applicable to the modification completed 

pursuant to SSM 177-22008-00006, issued on August 10, 2006: 

(a) The PM10 emissions from the Day Bin 1 shall not exceed 0.01 pounds per hour. 

(b) The PM10 emissions from the Day Bin 2 shall not exceed 0.01 pounds per hour. 

(c) The PM10 emissions from the Mixer shall not exceed 0.005 pounds per hour. 

(d) The PM10 emissions from the Weigh Scale shall not exceed 0.005 pounds per hour. 

(e) The PM10 emissions from the Railcar Receiving Station shall not exceed 0.095 pounds 

per hour. 

(f) The PM10 emissions from the Raw Material Silos shall not exceed 0.04 pounds per hour, 

total. 

(g) The PM10 emissions from the Batch Transfer System shall not exceed 0.053 pounds per 

hour. 

Compliance with these limits and the limits in Conditions D.2.1, D.4.1, and D.5.2 render 326 IAC 

2-2 (Prevention of Significant Deterioration) not applicable. 
Johns Manville International, Inc. Page 30 of 52 

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D.1.4 Preventive Maintenance Plan [326 IAC 2-7-5(13)] 

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

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

Compliance Determination Requirements 

D.1.5 Particulate Matter (PM) Control 

(a) In order to comply with Conditions D.1.1 (for the rail car unloading station) and 

D.1.2(a)(1), the boot lift device or similar device and the baghouse used to control PM 

emissions and opacity from the rail car unloading station shall be in operation at all times 

the associated rail car unloading station is in operation. 

(b) In order to comply with Conditions D.1.1, D.1.2(c) and D.1.3, the baghouses used to 

control PM emissions from the Railcar Receiving Station, Raw Material Silos, Day Bin 1, 

Day Bin 2, Mixer, Batch Transfer System and Weigh Scale shall be in operation at all 

times the associated units are in operation. 

(c) In the event that bag failure is observed in a multi-compartment bagfilter, 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 2-7-6(1)] [326 IAC 2-7-5(1)] 

D.1.6 Visible Emissions Notations 

(a) Daily visible emission notations of the stack exhaust from the Railcar Receiving Station, 

Raw Material Silos, Day Bin 1 and Day Bin 2 shall be performed during normal daylight 

operations. 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.1.7 Parametric Monitoring 

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

with the Railcar Receiving Station, Raw Material Silos, and Day Bins at least once per 

day when the respective facilities are in operation. 

(b) When for any one reading, the pressure drop across the baghouse is 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 – 
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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 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.1.8 Broken or Failed Bag Detection 

(a) For a single compartment baghouses 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. Operations may continue only if the 

event qualifies as an emergency and the Permittee satisfies the requirements of the 

emergency provisions of this permit (Section B - Emergency Provisions). 

(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 have been repaired or 

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

processing of the material in the line. Operations may continue only if the event qualifies 

as an emergency and the Permittee satisfies the requirements of the emergency 

provisions of this permit (Section B - Emergency Provisions). 

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, dust traces or triboflows. 

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

D.1.9 Record Keeping Requirements 

(a) To document compliance with Conditions D.1.2 and D.1.6, the Permittee shall maintain 

records of daily visible emission notations required by Condition D.1.6. The Permittee 

shall include in its daily record when a visible emission notation is not taken and the 

reason for the lack of visible emission notation (e.g. the process did not operate that day). 

(b) To document compliance with Condition D.1.7, the Permittee shall maintain weekly 

records of the pressure drop during normal 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. 
Johns Manville International, Inc. Page 32 of 52 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

SECTION D.2 FACILITY OPERATION CONDITIONS 

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

(b) One (1) Electric Melter; constructed in 2006; a maximum production rate of 20,125 pounds of 

molten glass per hour; emissions controlled by a baghouse and exhausting to stack S166. The 

molten glass flows from the melter to the Line 2 and Line 3 fiber forming/collection modules. 

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

and does not constitute enforceable conditions.) 

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

D.2.1 PSD Minor Modification Limit [326 IAC 2-2] 

Pursuant to SSM 177-22008-00006, issued August 10, 2006, and 326 IAC 2-2 (Prevention of 

Significant Deterioration), the Electric Melter shall comply with the following limitations: 

(a) The PM10 emissions from the Electric Melter shall not exceed 0.49 pounds per hour. 

(b) The VOC emissions from the Electric Melter shall not exceed 1.1 pounds per hour. 

(c) The CO emissions from the Electric Melter shall not exceed 0.83 pounds per hour. 

Compliance with these limits in combination with the limits in Conditions D.1.3, D.4.1, and D.5.2 

will limit PM10, VOC and CO to less than 15, 40 and 100 tons per year and will render 326 IAC 2-

2 (Prevention of Significant Deterioration) not applicable to the modification completed pursuant 

to SSM 177-22008-00006 issued on August 10, 2006. 

D.2.2 Particulate Matter (PM) Emission Limitations [326 IAC 6.5-1] 

Pursuant to 326 IAC 6.5-1-2(a), the particulate matter (PM) emissions from the Electric Melter, 

shall not exceed 0.03 grains per dry standard cubic foot. 

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

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

this permit, is required for the electric melter and its baghouse. 

Compliance Determination Requirements 

D.2.4 Particulate Matter (PM) Control 

(a) In order to comply with Conditions D.2.1 and D.2.2, the baghouse for PM control shall be 

in operation at all times the associated Electric Melter is in operation. 

(b) In the event that bag failure is observed in a multi-compartment bagfilter, 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.2.5 Testing Requirements [326 IAC 2-7-6(1),(6)] 

In order to demonstrate compliance with Condition D.2.1, the Permittee shall perform PM/PM10, 

VOC and CO testing on the Electric Melter no later than 180 days after initial startup. These tests 

shall be repeated once every five (5) years from the date of valid compliance demonstration 
Johns Manville International, Inc. Page 33 of 52 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

utilizing methods approved by the Commissioner. Testing shall be conducted in accordance with 

Section C - Performance Testing. 

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

D.2.6 Visible Emissions Notations 

(a) Daily visible emission notations of the stack exhaust from the Electric Melter shall be 

performed 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.2.7 Parametric Monitoring 

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

Electric Melter, at least once per day when the process is in operation. When for any one 

reading, the pressure drop across the baghouse is outside the normal range of 2.0 and 4.0 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 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.2.8 Broken or Failed Bag Detection 

(a) For a single compartment baghouses 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. Operations may continue only if the 

event qualifies as an emergency and the Permittee satisfies the requirements of the 

emergency provisions of this permit (Section B - Emergency Provisions). 

(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 have been repaired or 

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

processing of the material in emissions unit. Operations may continue only if the event 

qualifies as an emergency and the Permittee satisfies the requirements of the emergency 

provisions of this permit (Section B - Emergency Provisions). 

Bag failure can be indicated by a significant drop in the baghouse=s pressure reading with 
Johns Manville International, Inc. Page 34 of 52 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

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

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

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

D.2.9 Record Keeping Requirements 

(a) To document compliance with Condition D.2.6, the Permittee shall maintain once per day 

records of the visible emission notations of the Electric Melter stack S166 exhaust once 

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

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

operate that day). 

(b) To document compliance with Condition D.2.7, the Permittee shall maintain once per day 

records of the pressure drop during normal operation when venting to the atmosphere. 

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. 
Johns Manville International, Inc. Page 35 of 52 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

SECTION D.3 FACILITY OPERATION CONDITIONS 

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

(c) Forming Facilities: 

(1) One (1) Line 2 Forming and Collection Module; installed in 1961 and modified in 2000 

 and 2006; consisting of a rotary spinner and collection conveyor; with a maximum 

 unbonded glass production rate of 9,450 pounds per hour. Natural gas is utilized in the 

 combustion section of the forming chamber. The maximum heat input capacity of the 

 combustion section has been included in an OAQ confidential file. As fibers are formed, 

 they are carried in the airstream towards a moving collection chain where they are 

 captured and transferred to the shredding process. A water spray is applied to the 

 airstream to control particulate matter emissions before the airstream is exhausted to 

 stack S2. Under 40 CFR Part 60, Subpart PPP, this is considered a spin wool fiberglass 

 insulation manufacturing line. (Formerly referred to as the Line 2 forming chamber for 

 unbonded product) 

 (2) One (1) Line 3 Forming and Collection Module; installed in 1961 and modified in 2000 

 and 2006; consisting of a rotary spinner and collection conveyor; with a maximum 

 unbonded glass production rate of 8,100 pounds per hour. Natural gas is utilized in the 

 combustion section of the forming chamber. The maximum heat input capacity of the 

 combustion section has been included in an OAQ confidential file. As fibers are formed, 

 they are carried in the airstream towards a moving collection chain where they are 

 captured and transferred to the shredding process. A water spray is applied to the 

 airstream to control particulate matter emissions before the airstream is exhausted to 

 stack S3. Under 40 CFR Part 60, Subpart PPP, this is considered a spin wool fiberglass 

 insulation manufacturing line. (Formerly referred to as the Line 3 forming chamber for 

 unbonded product) 

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

and does not constitute enforceable conditions.) 

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

D.3.1 PSD BACT Limitations [326 IAC 2-2(a)(3)] 

Pursuant to CP-177-5873-00006, issued April 22, 1999, and 326 IAC 2-2-3(a)(3) (Best Available 

Control Technology (BACT)), and as revised by SSM 177-22008-00006 issued on August 10, 

2006, each Forming and Collection Module shall comply with the following limitations: 

Pollutant Emission Limitations 

Facility PM/PM10 

(lbs/hr) 

VOC 

(lbs/hr) 

CO 

(lbs/hr) 

Line 2 Forming and 

Collection 10.3 6.78 21.0 

Line 3 Forming and 

Collection 10.3 6.78 21.0 

PM/PM10 means that the PM limit and the PM10 limit are the same and shall be 

measured as the sum of the filterable and condensable fractions. 
Johns Manville International, Inc. Page 36 of 52 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

D.3.2 PSD Minor Limitations [326 IAC 2-2] 

(a) In order to render 326 IAC 2-2 (Prevention of Significant Deterioration) not applicable to 

the modification completed pursuant to SSM 177-22008-00006 issued on August 10, 

2006: 

(1) The CO emissions from the L2 Forming and Collection Module shall not exceed 

15.6 pounds per hour. 

(2) The CO emissions from the L3 Forming and Collection Module shall not exceed 

15.6 pounds per hour. 

Compliance with these limits in combination with the limits in Condition D.2.1(c) shall limit 

the CO emissions increase of the modification described in SSM 177-22008-00006 to 

less than one hundred (100) tons per year. 

(b) Pursuant to CP177-5873-00006, issued April 22, 1999 and revised by T177-22598-

00006, each Forming and Collection Module shall comply with the following limitations for 

NOx in order to render 326 IAC 2-2 (Prevention of Significant Deterioration) not 

applicable: 

Facility Pollutant Emission 

Limitations, lbs/hr NOx 

Line 2 Forming and 

Collection 4.53 

Line 3 Forming and 

Collection 4.53 

Compliance with these limits shall limit the NOx emissions increase of the modification 

described in CP 177-5873-00006, issued April 22, 1999 to less than forty (40) tons per 

year. 

D.3.3 Particulate Limitations Except Lake County [326 IAC 6.5-10-11] 

Pursuant to 326 IAC 6.5-10-11, the particulate matter (PM) emissions from each Forming and 

Collection Module shall comply with the following limitations: 

PM Emission Limitations Facility tons/yr gr/dscf 

Line 2 Forming and 

Collection 58.3 0.02 

Line 3 Forming and 

Collection 123.6 0.02 

D.3.4 Preventive Maintenance Plan [326 IAC 2-7-5(13)] 

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

this permit, is required for this facility and its control device. 

Compliance Determination Requirements 

D.3.5 Control Device Operating Conditions 

In order to demonstrate compliance with Condition D.3.1, the water spray systems associated 

with the Line 2 and Line 3 Forming and Collection Modules shall be operated at all times when 

the forming sections are in operation. 

D.3.6 Testing Requirements [326 IAC 2-7-6(1),(6)] [326 IAC 2-1.1-11] 

In order to demonstrate compliance with Conditions D.3.1 and D.3.2, the Permittee shall perform 
Johns Manville International, Inc. Page 37 of 52 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

PM/PM10, VOC and CO testing on one of the Forming and Collection Modules within one 

hundred and eighty (180) days after initial startup of the Electric Melter. This test shall be 

repeated at least once every five years from the date of the most recent valid compliance 

demonstration. Testing shall be conducted in accordance with Section C - Performance Testing. 

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

D.3.7 Visible Emissions Notations 

(a) Daily visible emission notations of the stack exhaust from the Line 2 and Line 3 Forming 

and Collection Modules shall be performed during normal daylight operations. 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. 

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

D.3.8 Record Keeping Requirements 

(a) To document compliance with Condition D.3.7, the Permittee shall maintain records of 

daily visible emission notations of the stack exhaust from the Line 2 and Line 3 Forming 

and Collection Modules. The Permittee shall include in its daily record when a visible 

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

(i.e. the process did not operate that day). 

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

Requirements, of this permit. 

New Source Performance Standards (NSPS) Requirements [326 IAC 2-7-5(1)] 

D.3.9 General Provisions Relating to New Source Performance Standards [326 IAC 12-1] [40 CFR Part 

60, Subpart A] 

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

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

1-1, for Line 2 Forming and Collection Module and Line 3 Forming and Collection Module 

except as otherwise specified in 40 CFR Part 60, Subpart PPP. 

(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 
Johns Manville International, Inc. Page 38 of 52 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

MC 61-53 IGCN 1003 

Indianapolis, Indiana 46204-2251 

D.3.10 New Source Performance Standards for Wool Fiberglass Insulation Manufacturing Plants: 

Requirements [40 CFR Part 60, Subpart PPP] 

Pursuant to 40 CFR Part 60, Subpart PPP, the Permittee shall comply with the provisions of 40 

CFR Part 60, Subpart PPP for the Line 2 Forming and Collection Module and the Line 3 Forming 

and Collection Module as follows: 

PART 60—STANDARDS OF PERFORMANCE FOR NEW STATIONARY SOURCES Subpart PPP—Standard of 

Performance for Wool Fiberglass Insulation Manufacturing Plants

§ 60.680 Applicability and designation of affected facility. 

(a) The affected facility to which the provisions of this subpart apply is each rotary spin wool fiberglass insulation 

manufacturing line. 

(b) The owner or operator of any facility under paragraph (a) of this section that commences construction, 

modification, or reconstruction after February 7, 1984, is subject to the requirements of this subpart. 

§ 60.681 Definitions. 

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

this part. 

Glass pull rate means the mass of molten glass utilized in the manufacture of wool fiberglass insulation at a single 

manufacturing line in a specified time period. 

Manufacturing line means the manufacturing equipment comprising the forming section, where molten glass is 

fiberized and a fiberglass mat is formed; the curing section, where the binder resin in the mat is thermally “set;” and 

the cooling section, where the mat is cooled. 

Rotary spin means a process used to produce wool fiberglass insulation by forcing molten glass through numerous 

small orifices in the side wall of a spinner to form continuous glass fibers that are then broken into discrete lengths by 

high velocity air flow. 

Wool fiberglass insulation means a thermal insulation material composed of glass fibers and made from glass 

produced or melted at the same facility where the manufacturing line is located. 

§ 60.682 Standard for particulate matter. 

On and after the date on which the performance test required to be conducted by §60.8 is completed, no owner or 

operator subject to the provisions of this subpart shall cause to be discharged into the atmosphere from any affected 

facility any gases which contain particulate matter in excess of 5.5 kg/Mg (11.0 1b/ton) of glass pulled. 

§ 60.685 Test methods and procedures. 

(a) In conducting the performance tests required in §60.8, the owner or operator shall use as reference methods and 

procedures the test methods in appendix A of this part or other methods and procedures as specified in this section, 

except as provided in §60.8(b). 

(b) The owner or operator shall conduct performance tests while the product with the highest loss on ignition (LOI) 

expected to be produced by the affected facility is being manufactured. 

(c) The owner or operator shall determine compliance with the particulate matter standard in §60.682 as follows: 
Johns Manville International, Inc. Page 39 of 52 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

(1) The emission rate (E) of particulate matter shall be computed for each run using the following equation: 

E=(CtQsd)/(PavgK) 

where: 

E = emission rate of particulate matter, kg/Mg (lb/ton). 

Ct= concentration of particulate matter, g/dscm (gr/dscf). 

Qsd= volumetric flow rate of effluent gas, dscm/hr (dscf/hr). 

Pavg= average glass pull rate, Mg/hr (ton/hr). 

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

(2) Method 5E shall be used to determine the particulate matter concentration (Ct) and the volumetric flow rate (Qsd) 

of the effluent gas. The sampling time and sample volume shall be at least 120 minutes and 2.55 dscm (90.1 dscf). 

(3) The average glass pull rate (Pavg) for the manufacturing line shall be the arithmetic average of three glass pull rate 

(Pi) determinations taken at intervals of at least 30 minutes during each run. 

The individual glass pull rates (Pi) shall be computed using the following equation: 

Pi=K′ LsWmM [1.0−(LOI/100)] 

where: 

Pi

=glass pull rate at interval “i”, Mg/hr (ton/hr). 

Ls=line speed, m/min (ft/min). 

Wm=trimmed mat width, m (ft). 

M=mat gram weight, g/m2 (lb/ft2 ). 

LOI=loss on ignition, weight percent. 

K′=conversion factor, 6×10−5

(min-Mg)/(hr-g) [3×10−2(min-ton)/(hr-lb)]. 

(i) ASTM D2584–68 (Reapproved 1985) or 94 (incorporated by reference—see §60.17), shall be used to determine 

the LOI for each run. 

(ii) Line speed (Ls), trimmed mat width (Wm), and mat gram weight (M) shall be determined for each run from the 

process information or from direct measurements. 

(d) To comply with §60.684(d), the owner or operator shall record measurements as required in §60.684 (a) and (b) 

using the monitoring devices in §60.683 (a) and (b) during the particulate matter runs. 

[54 FR 6680, Feb. 14, 1989, as amended at 65 FR 61778, Oct. 17, 2000] 
Johns Manville International, Inc. Page 40 of 52 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

SECTION D.4 FACILITY CONDITIONS 

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

(d) Shredding and Packaging Facilities: 

(1) One (1) Line 2 shredding process for unbonded product, installed in 1994, with a 

 maximum capacity of 9,450 pounds per hour. The shredded fiber is pneumatically 

 transferred to the packaging area. During the shredding process an anti-static agent and 

 oil are applied to the product and any particulate emissions in the airstream are controlled 

 by a baghouse system before the airstream is exhausted to Stacks S85, S86 and S87; 

(2) One (1) Line 2 packaging area for unbonded product, installed in 1994 and modified in 

 2006. The airstream is separated from the unbonded shredded product via a rotary 

 condensor. Fiberglass collected in the rotary condensor is deposited in the packaging 

 hopper and subsequently packaged for sale using a bagging system. The particulate 

 emissions in the rotary condensor airstream are controlled by a baghouse system before 

 the airstream is exhausted to Stacks S85, S86 and S87. The total maximum capacity of 

 Line 2 and Line 3 packaging areas is 27,540 pounds per hour; 

(3) One (1) Line 3 shredding process for unbonded product, installed in 1993, with a 

 maximum capacity of 8,100 pounds per hour. The shredded fiber is pneumatically 

 transferred to the packaging area. During the shredding process an anti-static agent and 

 oil are applied to the product and any particulate emissions in the airstream are controlled 

 by a baghouse system before the airstream is exhausted to Stacks S12, S13 and S14; 

 and 

(4) One (1) Line 3 packaging area for unbonded product, installed in 1993 and modified in 

 2006. The airstream is separated from the unbonded shredded product via a rotary 

 condensor. Fiber glass collected in the rotary condensor is deposited in the packaging 

 hopper and subsequently packaged for sale using a bagging system. The particulate 

 matter emissions in the rotary condensor airstream are controlled by a baghouse system 

 before the airstream is exhausted to Stacks S12, S13 and S14. The total maximum 

 capacity of Line 2 and Line 3 packaging areas is 27,540 pounds per hour. 

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

and does not constitute enforceable conditions.) 

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

D.4.1 PSD Minor Modification Limitations [326 IAC 2-2] 

In order to render the requirements of 326 IAC 2-2 not applicable to the modification completed 

pursuant to SSM 177-22008-00006: 

(a) The PM10 emissions from the L2 Shredding Process and L2 Packaging Area shall not 

exceed 0.9 pounds per hour, total. 

(b) The PM10 emissions from the L3 Shredding Process and L3 Packaging Area shall not 

exceed 0.9 pounds per hour, total. 

Compliance with these limits and the limits in Conditions D.1.3, D.2.1, and D.5.2 render 326 IAC 

2-2 (Prevention of Significant Deterioration) not applicable. 
Johns Manville International, Inc. Page 41 of 52 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

D.4.2 Particulate Matter [336 IAC 6.5-1-2] 

Pursuant to 326 IAC 6.5-1-2, the allowable PM emission rates for each of the shredding and 

packaging facilities listed in this section shall not contain particulate matter in excess of 0.03 grain 

per dry standard cubic foot (dscf). 

D.4.3 Preventive Maintenance Plan [326 IAC 2-7-5(13)] 

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

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

Compliance Determination Requirements 

D.4.4 Particulate Matter 

(a) In order to comply with Conditions D.4.1 and D.4.2 the baghouses for PM control shall be 

in operation at all times the associated shredding and packaging facilities 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.4.5 Testing Requirements [326 IAC 2-7-6(1),(6)] [326 IAC 2-1.1-11] 

In order to demonstrate compliance with Condition D.4.1, the Permittee shall perform PM/PM10, 

testing on one of the Shredding and Packaging within one hundred and eighty (180) days after 

initial startup of the Electric Melter. This test shall be repeated at least once every five years from 

the date of the most recent valid compliance demonstration. Testing shall be conducted in 

accordance with Section C - Performance Testing. 

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

D.4.6 Visible Emissions Notations 

(a) Daily visible emission notations of the shredding and packaging area baghouse systems

stack exhaust shall be performed during normal daylight operations. 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.4.7 Parametric Monitoring 

The Permittee shall record the pressure drop across the baghouses used in conjunction with the 
Johns Manville International, Inc. Page 42 of 52 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

shredding and packaging process, at least once per day when the process is in operation. When 

for any one reading, the pressure drop across the baghouses are outside the normal range of 1.0 

and 8.0 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 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.4.8 Broken or Failed Bag Detection 

(a) For a single compartment baghouses 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. Operations may continue only if the 

event qualifies as an emergency and the Permittee satisfies the requirements of the 

emergency provisions of this permit (Section B - Emergency Provisions). 

(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 have been repaired or 

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

processing of the material in the line. Operations may continue only if the event qualifies 

as an emergency and the Permittee satisfies the requirements of the emergency 

provisions of this permit (Section B - Emergency Provisions). 

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, dust traces or triboflows. 

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

D.4.9 Record Keeping Requirements 

(a) To document compliance with Condition D.4.6, the Permittee shall maintain records of 

daily visible emission notations of the 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 

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

(b) To document compliance with Condition D.4.7, the Permittee shall maintain daily records 

of the pressure drop during normal operation. 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) These records shall be maintained in accordance with Section C - General Record 

Keeping Requirements. 
Johns Manville International, Inc. Page 43 of 52 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

SECTION D.5 FACILITY OPERATION CONDITIONS 

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

(e) One (1) natural gas-fired boiler, identified as B-2, installed in 1961, with a rated capacity of 25 

 MMBtu per hour. The airstream from the boiler is exhausted to stack S4. 

Insignificant Activities 

(a) One (1) melter dust recycling system, installed in 1961 and modified in 1999 and 2006, and 

 exhausted to stack S34 [326 IAC 2-2] [326 IAC 6.5-10-11]. 

(b) One (1) cold end housekeeping system, installed in 1988, with a total production capacity 

 of 17,550 pounds per hour. The particulate emissions in the airstream are controlled by a 

 baghouse before the airstream is exhausted indoors to general ventilation [326 IAC 2-2] [326 IAC 

 6.5-10-11]. 

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

and does not constitute enforceable conditions.) 

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

D.5.1 PSD Modification Limitations [326 IAC 2-2-3] 

(a) Pursuant to CP 177-5873-00006, issued April 22, 1999, and 326 IAC 2-2-3 (BACT), the 

ancillary equipment shall comply with the following particulate matter limitations: 

(1) The particulate emissions from stack S34 from the melter dust recycling system 

shall not exceed an average of three percent (3%) opacity in any 24 consecutive 

readings recorded in 15 second intervals in accordance with the applicable 

requirements of 40 CFR 60, Appendix A, Method 9; 

(2) The cold end housekeeping system shall be equipped with a baghouse system 

and shall not exceed an average of three percent (3%) opacity in any 24 

consecutive readings recorded in 15 second intervals in accordance with the 

applicable requirements of 40 CFR 60, Appendix A, Method 9; and 

(b) Pursuant to CP 177-5873-00006, issued April 22, 1999, and 326 IAC 2-2-3 (BACT), the 

ancillary equipment shall comply with the following limitations: 

Facility

Limitation 

PM/PM10 

(lbs/hr)

Melter Dust Recycling System 0.19 

Cold End Housekeeping System 0.51 

D.5.2 PSD Minor Modification Limitations [326 IAC 2-2] 

Pursuant to SSM 177-22008-00006, issued August 10, 2006, the PM10 emissions from the 

Melter Dust Recycle System shall not exceed 0.001 pounds per hour. 

Compliance with this limit in combination with the limits in Conditions D.1.3, D.2.1, and D.4.1 will 

limit the PM10 emissions to less than fifteen (15) tons per year and will render 326 IAC 2-2 

(Prevention of Significant Deterioration) not applicable to the modification completed pursuant to 
Johns Manville International, Inc. Page 44 of 52 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

SSM 177-22008-00006 issued August 10, 2006. 

D.5.3 Particulate Emission Limitations [326 IAC 6.5] 

(a) Pursuant to 326 IAC 6.5-1-2(a) (Particulate emission limitations; fuel combustion steam 

generators, asphalt concrete plant, grain elevators, foundries, mineral aggregate 

operations; modification by commissioner) the allowable PM emission rates for each of 

the ancillary equipment facilities listed in this section shall not contain particulate matter 

in excess of 0.03 grain per dry standard cubic foot (dscf). 

(b) Pursuant to 326 IAC 6.5-10-11, the natural gas-fired boiler shall not exceed 1.5 tons of 

PM per year and 0.0137 pounds of PM per million Btu. 

D.5.4 Sulfur Dioxide Emission Limitations [326 IAC 7-4-4] 

Pursuant to 326 IAC 7-4-4, (Wayne County Sulfur Dioxide Emission Limitations) the allowable 

sulfur dioxide emission rate for the natural gas-fired boiler shall not exceed 1.6 pounds per 

MMBtu/hr. 

D.5.5 Preventive Maintenance Plan [326 IAC 2-7-5(13)] 

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

this permit, is required for the ancillary equipment and the cold end housekeeping system 

baghouse. 

Compliance Determination Requirements 

D.5.6 Particulate Matter 

(a) In order to comply with Conditions D.5.1(a), (b), and D.5.3, the baghouse for PM control 

shall be in operation at all times the cold end housekeeping system 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 2-7-6(1)] [326 IAC 2-7-5(1)] 

D.5.7 Broken or Failed Bag Detection 

(a) For a single compartment baghouses 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. Operations may continue only if the 

event qualifies as an emergency and the Permittee satisfies the requirements of the 

emergency provisions of this permit (Section B - Emergency Provisions). 

(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 have been repaired or 

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

processing of the material in the line. Operations may continue only if the event qualifies 

as an emergency and the Permittee satisfies the requirements of the emergency 

provisions of this permit (Section B - Emergency Provisions). 

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, dust traces or triboflows. 
Johns Manville International, Inc. Page 45 of 52 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

 SECTION D.6 FACILITY OPERATION CONDITIONS 

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

(j) Two (2) degreasing operations, constructed in 2006, that do not exceed 145 gallons per 12 

months and are not subject to 326 IAC 20-6 [326 IAC 8-3-2][326 IAC 8-3-5]. 

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

and does not constitute enforceable conditions.) 

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

D.6.1 Volatile Organic Compounds (VOC) [326 IAC 8-3-2] 

Pursuant to 326 IAC 8-3-2 (Cold Cleaner Operations), for cold cleaning operations constructed 

after January 1, 1980, the Permittee shall: 

(a) Equip the cleaner with a cover; 

(b) Equip the cleaner with a facility for draining cleaned parts; 

(c) Close the degreaser cover whenever parts are not being handled in the cleaner; 

(d) Drain cleaned parts for at least fifteen (15) seconds or until dripping ceases; 

(e) Provide a permanent, conspicuous label summarizing the operation requirements; 

(f) Store waste solvent only in covered containers and not dispose of waste solvent or 

transfer it to another party, in such a manner that greater than twenty percent (20%) of 

the waste solvent (by weight) can evaporate into the atmosphere. 

D.6.2 Volatile Organic Compounds (VOC) [326 IAC 8-3-5] 

(a) Pursuant to 326 IAC 8-3-5(a) (Cold Cleaner Degreaser Operation and Control), for cold 

cleaner degreaser operations without remote solvent reservoirs constructed after July 1, 

1990, the Permittee shall ensure that the following control equipment requirements are 

met: 

(1) Equip the degreaser with a cover. The cover must be designed so that it can be 

easily operated with one (1) hand if: 

(A) The solvent volatility is greater than two (2) kiloPascals (fifteen (15) 

millimeters of mercury or three-tenths (0.3) pounds per square inch) 

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

Fahrenheit (100OF)); 

(B) The solvent is agitated; or 

(C) The solvent is heated. 

(2) Equip the degreaser with a facility for draining cleaned articles. If the solvent 

volatility is greater than four and three-tenths (4.3) kiloPascals (thirty-two (32) 

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

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

then the drainage facility must be internal such that articles are enclosed under 
Johns Manville International, Inc. Page 46 of 52 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

the cover while draining. The drainage facility may be external for applications 

where an internal type cannot fit into the cleaning system. 

(3) Provide a permanent, conspicuous label which lists the operating requirements 

outlined in subsection (b). 

(4) The solvent spray, if used, must be a solid, fluid stream and shall be applied at a 

pressure which does not cause excessive splashing. 

(5) Equip the degreaser with one (1) of the following control devices if the solvent 

volatility is greater than four and three-tenths (4.3) kiloPascals (thirty-two (32) 

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

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

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

(120OF)): 

(A) A freeboard that attains a freeboard ratio of seventy-five hundredths 

(0.75) or greater. 

(B) A water cover when solvent is used is insoluble in, and heavier than, 

water. 

(C) Other systems of demonstrated equivalent control such as a refrigerated 

chiller of carbon adsorption. Such systems shall be submitted to the 

U.S. EPA as a SIP revision. 

(b) Pursuant to 326 IAC 8-3-5(b) (Cold Cleaner Degreaser Operation and Control), the 

owner or operator of a cold cleaning facility construction of which commenced after July 

1, 1990, shall ensure that the following operating requirements are met: 

(1) Close the cover whenever articles are not being handled in the degreaser. 

(2) Drain cleaned articles for at least fifteen (15) seconds or until dripping ceases. 

(3) Store waste solvent only in covered containers and prohibit the disposal or 

transfer of waste solvent in any manner in which greater than twenty percent 

(20%) of the waste solvent by weight could evaporate. 
Johns Manville International, Inc. Page 47 of 52 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

PART 70 OPERATING PERMIT 

CERTIFICATION 

Source Name: Johns Manville International, Inc. 

Source Address: 814 Richmond Ave, Richmond, Indiana 47374 

Mailing Address: 814 Richmond Ave, Richmond, IN 47374 

Part 70 Permit No.: T177-22598-00006 

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: 
Johns Manville International, Inc. Page 48 of 52 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE BRANCH 

100 North Senate Avenue 

MC 61-64 IGCN 1003 

Indianapolis, Indiana 46204-2251 

Phone: 317-233-0178 

Fax: 317-233-6865 

PART 70 OPERATING PERMIT 

EMERGENCY OCCURRENCE REPORT 

Source Name: Johns Manville International, Inc. 

Source Address: 814 Richmond Ave, Richmond, Indiana 47374 

Mailing Address: 814 Richmond Ave, Richmond, IN 47374 

Part 70 Permit No.: T177-22598-00006 

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: 
Johns Manville International, Inc. Page 49 of 52 

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Permit Reviewer: ERG/BL 

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. 
Johns Manville International, Inc. Page 50 of 52 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

PART 70 OPERATING PERMIT 

SEMI-ANNUAL NATURAL GAS FIRED BOILER CERTIFICATION 

Source Name: Johns Manville International, Inc. 

Source Address: 814 Richmond Ave, Richmond, Indiana 47374 

Mailing Address: 814 Richmond Ave, Richmond, IN 47374 

Part 70 Permit No.: T177-22598-00006 

 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. 
Johns Manville International, Inc. Page 51 of 52 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

PART 70 OPERATING PERMIT 

QUARTERLY DEVIATION AND COMPLIANCE MONITORING REPORT 

Source Name: Johns Manville International, Inc. 

Source Address: 814 Richmond Ave, Richmond, Indiana 47374 

Mailing Address: 814 Richmond Ave, Richmond, IN 47374 

Part 70 Permit No.: T177-22598-00006 

 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: 
Johns Manville International, Inc. Page 52 of 52 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

Page 2 of 2 

Permit Requirement (specify permit condition #) 

Date of Deviation: Duration of Deviation: 

Number of Deviations: 

Probable Cause of Deviation: 

Response Steps Taken: 

Permit Requirement (specify permit condition #) 

Date of Deviation: Duration of Deviation: 

Number of Deviations: 

Probable Cause of Deviation: 

Response Steps Taken: 

Permit Requirement (specify permit condition #) 

Date of Deviation: Duration of Deviation: 

Number of Deviations: 

Probable Cause of Deviation: 

Response Steps Taken: 

Form Completed by: 

Title / Position: 

 

Date: 

Phone: 

 

Attach a signed certification to complete this report. 
Indiana Department of Environmental Management 

Office of Air Quality 

Addendum to the Technical Support Document 

to a Part 70 Operating Permit Renewal 

Source Background and Description 

Source Name: Johns Manville International, Inc. 

Source Location: 814 Richmond Ave Richmond, Indiana 47374 

 County: Wayne 

 SIC Code: 3296 

 Operation Permit No.: 177-22598-00006 

Permit Reviewer: ERG/BL 

 On October 17, 2007, the Office of Air Quality (OAQ) had a notice published in The Palladium 

Item, in Richmond, Indiana, stating that Johns Manville International, Inc. had applied for a Permit 

Renewal to their Part 70 Operating Permit. The notice also stated that OAQ proposed to issue a permit 

for this operation and provided information on how the public could review the proposed permit and other 

documentation. Finally, the notice informed interested parties that there was a period of thirty (30) days to 

provide comments on whether or not this permit should be issued as proposed. No public comments 

were made on the proposed permit during the 30 day public comment period. 

 Upon further review, IDEM, OAQ has decided to make the following revisions to the permit. New 

language is in bold while deleted language is in strikeout. The Table of Contents has been updated as 

necessary. 

1. The record keeping requirements in paragraph (b) of Condition D.1.9 incorrectly cite the visible 

emissions requirement, Condition D.1.6. This reference has been corrected. 

D.1.9 Record Keeping Requirements 

(a) To document compliance with Conditions D.1.2 and D.1.6, the Permittee shall maintain 

records of daily visible emission notations required by Condition D.1.6. The Permittee 

shall include in its daily record when a visible emission notation is not taken and the 

reason for the lack of visible emission notation (e.g. the process did not operate that day). 

(b) To document compliance with Condition D.1.6D.1.7, the Permittee shall maintain weekly 

records of the pressure drop during normal 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). 

. . . 

2. The record keeping requirements in paragraphs (a) and (b) of Condition D.4.9 incorrectly cite the 

testing and visible emissions requirements, Conditions D.4.5 and D.4.6. This reference has been 

corrected. 

D.4.9 Record Keeping Requirements 

(a) To document compliance with Condition D.4.5D.4.6, the Permittee shall maintain records 

of daily visible emission notations of the 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 

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

(b) To document compliance with Condition D.4.6D.4.7, the Permittee shall maintain daily 

records of the pressure drop during normal operation. 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). 

. . . 
Indiana Department of Environmental Management 

Office of Air Quality 

Technical Support Document (TSD) for a Part 70 Operating Permit Renewal 

Source Background and Description 

Source Name: Johns Manville International, Inc. 

Source Location: 814 Richmond Ave., Richmond, IN 47374 

County: Wayne 

SIC Code: 3296 

Permit Renewal No.: T177-22598-00006 

Permit Reviewer: ERG/BL 

The Office of Air Quality (OAQ) has reviewed the operating permit renewal application from Johns 

Manville International, Inc. relating to the operation of following emission units and pollution 

control devices. 

This Part 70 operating permit contains provisions intended to satisfy the requirements of the 

construction permit rules. 

Permitted Emission Units and Pollution Control Equipment 

(a) Raw Material Handling, Storage and Batching Equipment for Lines 2 and 3: 

(1) One (1) Rail car Receiving station; with a maximum capacity of 40.5 tons per 

hour, installed in 1967, and exhausting to stack S165. The raw materials received 

in rail cars are bottom unloaded into a screw conveyor that transfers the material 

to the storage silos via a bucket elevator and a diverter. The particulate emissions 

are controlled by a boot lift device that seals off the bottom of the rail car and a 

baghouse; 

(2) Eight (8) Raw Material Silos, installed in 1967. Raw materials are loaded into the 

batch silos and vented to fabric filters to control particulate emissions in the 

airstream before it is exhausted to emission points S21 through S28. The silo 

capacities are as follows: Silo #1 - 152 tons, Silo #2 - 23 tons, Silo #3 - 134 tons, 

Silo #4 - 51.8, Silo #5 - 106.7, Silo #6 - 54.6, Silo #7 - 101.3, and Silo #8 - 149.9. 

(3) Two (2) day bins; identified as Day Bin 1 and Day Bin 2; constructed in 2006; 

each with a maximum storage capacity of 57.5 tons; emissions controlled by 

baghouses (BH167 and BH168); exhausting to stacks S167 and S168. Product 

from the mixer is transferred to the day bins using an enclosed conveyor system. 

(4) One (1) Mixer; constructed in 2006; a maximum capacity of 20,125 pounds of raw 

materials per hour; emissions controlled by a sock filter; exhausting indoors to 

general ventilation. Raw materials from the storage silos are weighed and 

transferred to the mixer. 

(5) One (1) Batch Transfer System; constructed in 2006; a maximum capacity of 

20,125 pounds of raw materials per hour; emissions controlled by a baghouse; 

exhausting indoors to general ventilation. Processed materials from the mixer are 

transferred to the day bins via the batch delivery/bucket elevator system. 

(6) One (1) Weigh Scale; constructed in 1967; a maximum capacity of 20,125 pounds 

of raw materials per hour; emissions controlled by a sock filter; exhausting indoors 
Johns Manville International, Inc. Page 2 of 24 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

to general ventilation. Raw materials from the storage silos are weighed and 

transferred to the mixer. 

(b) One (1) Electric Melter; constructed in 2006; a maximum production rate of 20,125 pounds 

of molten glass per hour; emissions controlled by a baghouse and exhausting to stack 

S166. The molten glass flows from the melter to the Line 2 and Line 3 fiber 

forming/collection modules. 

(c) Forming Facilities: 

(1) One (1) Line 2 Forming and Collection Module; installed in 1961 and modified in 

2000 and 2006; consisting of a rotary spinner and collection conveyor; with a 

maximum unbonded glass production rate of 9,450 pounds per hour. Natural gas 

is utilized in the combustion section of the forming chamber. The maximum heat 

input capacity of the combustion section has been included in an OAQ confidential 

file. As fibers are formed, they are carried in the airstream towards a moving 

collection chain where they are captured and transferred to the shredding 

process. A water spray is applied to the airstream to control particulate matter 

emissions before the airstream is exhausted to stack S2. Under 40 CFR Part 60, 

Subpart PPP, this facility is considered a spin wool fiberglass insulation 

manufacturing line. (Formerly referred to as the Line 2 forming chamber for 

unbonded product) 

(2) One (1) Line 3 Forming and Collection Module; installed in 1961 and modified in 

2000 and 2006; consisting of a rotary spinner and collection conveyor; with a 

maximum unbonded glass production rate of 8,100 pounds per hour. Natural gas 

is utilized in the combustion section of the forming chamber. The maximum heat 

input capacity of the combustion section has been included in an OAQ confidential 

file. As fibers are formed, they are carried in the airstream towards a moving 

collection chain where they are captured and transferred to the shredding 

process. A water spray is applied to the airstream to control particulate matter 

emissions before the airstream is exhausted to stack S3. Under 40 CFR Part 60, 

Subpart PPP, this facility is considered a spin wool fiberglass insulation 

manufacturing line. (Formerly referred to as the Line 3 forming chamber for 

unbonded product) 

(d) Shredding and Packaging Facilities: 

(1) One (1) Line 2 shredding process for unbonded product, installed in 1994, with a 

maximum capacity of 9,450 pounds per hour. The shredded fiber is pneumatically 

transferred to the packaging area. During the shredding process an anti-static 

agent and oil are applied to the product and any particulate emissions in the 

airstream are controlled by a baghouse system before the airstream is exhausted 

to Stacks S85, S86 and S87; 

(2) One (1) Line 2 packaging area for unbonded product, installed in 1994 and 

modified in 2006. The airstream is separated from the unbonded shredded 

product via a rotary condensor. Fiberglass collected in the rotary condensor is 

deposited in the packaging hopper and subsequently packaged for sale using a 

bagging system. The particulate emissions in the rotary condensor airstream are 

controlled by a baghouse system before the airstream is exhausted to Stacks 

S85, S86 and S87. The total maximum capacity of Line 2 and Line 3 packaging 

areas is 27,540 pounds per hour; 

(3) One (1) Line 3 shredding process for unbonded product, installed in 1993, with a 

maximum capacity of 8,100 pounds per hour. The shredded fiber is pneumatically 
Johns Manville International, Inc. Page 3 of 24 

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Permit Reviewer: ERG/BL 

transferred to the packaging area. During the shredding process an anti-static 

agent and oil are applied to the product and any particulate emissions in the 

airstream are controlled by a baghouse system before the airstream is exhausted 

to Stacks S12, S13 and S14; and 

(4) One (1) Line 3 packaging area for unbonded product, installed in 1993 and 

modified in 2006. The airstream is separated from the unbonded shredded 

product via a rotary condensor. Fiber glass collected in the rotary condensor is 

deposited in the packaging hopper and subsequently packaged for sale using a 

bagging system. The particulate matter emissions in the rotary condensor 

airstream are controlled by a baghouse system before the airstream is exhausted 

to Stacks S12, S13 and S14. The total maximum capacity of Line 2 and Line 3 

packaging areas is 27,540 pounds per hour. 

(e) One (1) natural gas-fired boiler, identified as B-2, installed in 1961, with a rated capacity of 

25 MMBtu per hour. The airstream from the boiler is exhausted to stack S4. 

Unpermitted Emission Units and Pollution Control Equipment 

There are no unpermitted emission units operating at this source during this review process. 

Insignificant Activities 

The source also consists of the following insignificant activities, as defined in 326 IAC 2-7-1(21): 

(a) One (1) melter dust recycling system, installed in 1961 and modified in 1999 and 2006, 

and exhausted to stack S34 [326 IAC 2-2] [326 IAC 6.5-10-11]. 

(b) One (1) cold end housekeeping system, installed in 1988, with a total production capacity 

of 17,550 pounds per hour. The particulate emissions in the airstream are controlled by a 

baghouse before the airstream is exhausted indoors to general ventilation [326 IAC 2-2] 

[326 IAC 6.5-10-11]. 

(c) Two (2) degreasing operations, constructed in 2006, that do not exceed 145 gallons per 

12 months and are not subject to 326 IAC 20-6 [326 IAC 8-3-2][326 IAC 8-3-5]. 

(d) Natural gas-fired combustion sources with heat input equal to or less than ten million 

(10,000,000) Btu per hour. 

(e) Propane or liquified petroleum gas, or butane-fired combustion sources with heat input 

equal to or less than six million (6,000,000) Btu per hour. 

(f) Fuel oil-fired combustion sources with heat input equal to or less than two million 

(2,000,000) Btu per hour and firing fuel containing less than five-tenth (0.5) percent sulfur 

by weight. 

(g) A gasoline fuel transfer and dispensing operation handling less than or equal to 1,300 

gallons per day such as filling of tanks, locomotives, automobiles, having a storage 

capacity less than or equal to 10,500 gallons. 

(h) A petroleum fuel, other than gasoline, dispensing facility, having a storage capacity of less 

than or equal to 10,500 gallons, and dispensing less than or equal to 230,000 gallons per 

month. 

(i) Storage tanks with capacity less than or equal to 1,000 gallons and annual throughputs 

less than 12,000 gallons. 
Johns Manville International, Inc. Page 4 of 24 

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(j) Vessels storing lubricating oils, hydraulic oils, machining oils, and machining fluids. 

(k) Refractory storage not requiring air pollution control equipment. 

(l) Application of oils, greases, lubricants or other nonvolatile materials applied as temporary 

protective coatings. 

(m) Cleaners and solvents characterized as follows: (1) having a vapor pressure equal to or 

less than 2 kPa; 15mm Hg; or 0.3 psi measured at 38 degrees C (100o

F); or (2) having a 

vapor pressure equal to or less than 0.7 kPa; 5mm Hg; or 0.1 psi measured at 20oC 

(68o

F); the use of which for all cleaners and solvents combined does not exceed 145 

gallons per 12 months. 

(n) Closed loop heating and cooling systems. 

(o) Solvent recycling systems with batch capacity less than or equal to 100 gallons. 

(p) Activities associated with the treatment of wastewater streams with an oil and grease 

content less than or equal to 1% by volume. 

(q) Activities associated with the transportation and treatment of sanitary sewage, provided 

discharge to the treatment plant is under the control of the owner/operator, that is, an onsite sewage treatment facility. 

(r) Any operation using aqueous solutions containing less than 1% by weight of VOCs 

excluding HAPs. 

(s) Forced and induced draft cooling tower system not regulated under a NESHAP. 

(t) Replacement or repair of electrostatic precipitators, bags in baghouses and filters in other 

air filtration equipment. 

(u) Process vessel degassing and cleaning to prepare for internal repairs. 

(v) Paved and unpaved roads and parking lots with public access [326 IAC 6-4]. 

(w) Purging of gas lines and vessels that is related to routine maintenance and repair of 

buildings, structures, or vehicles at the source where air emissions from those activities 

would not be associated with any production process. 

(x) Equipment used to collect any material that might be released during a malfunction, 

process upset, or spill cleanup, including catch tanks, temporary liquid separators, tanks, 

and fluid handling equipment. 

(y) Five (5) standby diesel generators including: three (3) rated at 155 hp each and one (1) 

rated as 174 hp, exhausting to stacks S148, S149, S150, and S161, respectively. One (1) 

63.2 hp diesel engine used to power the emergency fire pump, which exhausts to stack 

S160. 

(z) Stationary fire pumps. 

(aa) A laboratory as defined in 326 IAC 2-7-1(21)(D). 

(bb) Activities with emissions equal to or less than the following thresholds: PM = 5 tpy; PM10 

= 5 tpy; SO2 = 10 tpy or 25 lb/day; NOx = 10 tpy; CO = 25 tpy or 25 lb/day; Pb = 0.2 tpy or 
Johns Manville International, Inc. Page 5 of 24 

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Permit Reviewer: ERG/BL 

3.29 lb/day; single HAP = 1 tpy; combination of HAPs = 2.5 tpy; and VOC = 10 tpy 

including: 

(1) Binder Tank (EPN S45), 

(2) Maintenance Welding, 

(3) Propane Expander (EPN S68), 

(4) Propane Vaporizer (EPN S75), 

(5) Stand by Generators, 

(6) 7,000 gallon Dedusting storage tank, 

(7) 300 gallon Used Oil storage tank, 

(8) Four (4) 600 gallon Emulsion storage tanks, 

(9) 300 gallon Gasoline Storage Tank (T-001), 

(10) 300 gallon Diesel Storage Tank (T-002), 

(11) 300 gallon Diesel Storage Tank (T-003), and 

(12) 300 gallon Kerosene Storage Tank (T-004). 

History

On February 6, 2006, Johns Manville International, Inc. submitted applications to the OAQ requesting 

to renew its operating permit. Johns Manville International, Inc. was issued a Part 70 Operating Permit 

on October 4, 2001. 

Existing Approvals 

Since the issuance of the Part 70 Operating Permit T177-7720-00006 on October 4, 2001, the 

source has constructed or has been operating under the following approvals as well: 

(a) Administrative Amendment 177-14315-00006, issued on November 30, 2001; 

 (b) Administrative Amendment 177-15463-00006, issued on March 11, 2002; 

 

 (c) Minor Source Modification 177-15950-00006, issued on September 16, 2002;

(d) Significant Permit Modification 177-16463-00006, issued on November 15, 2002; 

(e) Review Request 177-18566-00006, issued on March 18, 2004; 

(f) Review Request 177-19135-00006, issued on June 10, 2004; 

(g) Significant Source Modification 177-22008-00006, issued on August 10, 2006; and 

(h) Significant Permit Modification 177-22666-00006, issued on September 1, 2006. 

The following terms and conditions from previous approvals have been determined no longer 

applicable; therefore, were not incorporated into this Part 70 Operating Permit Renewal: 
Johns Manville International, Inc. Page 6 of 24 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

(a) Condition D.3.1(d) in the construction permit CP177-5873-00006, issued April 22, 1999, 

limited the NOx emissions from the Lines 2 and 3 Forming Process. These limits have 

been revised. 

 Reason for the revision: The NOx limits were designed to ensure that 326 IAC 2-2 

(Prevention of Significant Deterioration) does not apply. Due to the removal of the Line 3 

Curing Process, the Line 3 Cooling Process, the Line 6 Forming Process, and the Line 6 

Curing Process, the hourly NOx emission limits have been redistributed to the remaining 

equipment. 

 

(b) Condition D.3.1(e) in the construction permit CP177-5873-00006, issued April 22, 1999, 

limited the HAP emissions from the manufacturing lines 2, 3, and 6 to make 326 IAC 2-

4.1 not applicable. These limits have been revised. 

 

 Reason for the revision: Following the modifications documented in SPM 177-22666-

00006 issued September 1, 2006, the Modules can no longer produce bonded product 

and the only source of HAP emissions is the Electric Melter and the boilers. The total 

PTE of HAP from the source is now significantly less than 1.00 ton of any single HAP or 

of a combination of HAP per year. The HAP limit has been removed from the permit 

because it is now unnecessary. 

(c) Conditions D.5.1(a)(3), D.5.1(b) and D.5.1(c) in the construction permit CP177-5873-

00006, issued April 22, 1999, limited the PM/PM10, VOC, CO, NOx, and SO2 emissions 

from the natural gas-fired boiler (B-2). These limits have been removed. 

 Reason not incorporated: The boiler should not have been limited because it was built in 

1961 and has not been modified since that date. The boiler did stop burning fuel oil in 

1999, but this led to a reduction in emissions. Therefore, no limit should have been 

required. The uncontrolled PM/PM10, VOC, CO, SO2 and NOx emissions for this boiler 

are all less than the significant level thresholds under PSD. 

(d) Conditions D.5.1(b) and D.5.1(c) in the construction permit CP177-5873-00006, issued 

April 22, 1999, limited the PM/PM10, VOC, CO, SO2 and NOx emissions from the Melter 

Dust Recycle System (formerly the EP Dust Recycling System) and the Cold End 

Housekeeping System. The VOC and CO limits have been removed. 

 Reason not incorporated: Neither the Melter Dust Recycle System or the Cold End 

Housekeeping System produce VOC, CO, SO2, or NOx. Therefore, no limit should have 

been required. 

(d) Condition D.2.4 in the SSM 177-22008-00006, issued August 10, 2006 limited the 

production rate of the Electric Melter to less than 17,500 pounds of glass per hour. 

 Reason not incorporated: The PSD minor limits for PM10, VOC, and CO were necessary 

to make 326 IAC 2-2 (Prevention of Significant Deterioration) not applicable to the 

modification. The limits are in terms of pounds per hour. Therefore, it is not necessary to 

restrict production. 

(e) Condition D.4.1(a) in the SSM 177-22008-00006, issued August 10, 2006 limited the PM 

and PM10 emissions from the Lines 2 and 3 Shredding and Packaging. The PSD minor 

limits for PM and PM10 are necessary to make 326 IAC 2-2 (Prevention of Significant 

Deterioration) not applicable to the modification. However the limits in Condition D.4.1(a) 

and D.4.1(b) are redundant and have been removed. IDEM has revised the limit as 

follows. 
Johns Manville International, Inc. Page 7 of 24 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

D.4.1 Particulate Matter Emission Limitations 

(a) Pursuant to CP 177-5873-00006, issued April 22, 1999, 326 IAC 2-2-3(a)(3) (Prevention 

of Significant Deterioration (PSD) Rules), and as revised by SSM 177-22008-00006, 

each shredding and packaging area shall comply with the following limitations:

Facility Facility Stack PM/PM10 Emission 

Limitations (lb/hr)

Line 2 Shredding and

Packaging

S85, S86

and S87 1.86

Line 3 Shredding and

Packaging

S12, S13

and S14 3.09

PM/PM10 means that the PM limit and the PM10 limit are the same and shall be 

measured as the sum of the filterable and condensable fractions.

(b) In order to render the requirements of 326 IAC 2-2 not applicable to the modification 

completed pursuant to SSM 177-22008-00006: 

(1) The PM10 emissions from the L2 Shredding Process and L2 Packaging Area 

shall not exceed 0.9 pounds per hour, total. 

(2) The PM10 emissions from the L3 Shredding Process and L3 Packaging Area 

shall not exceed 0.9 pounds per hour, total. 

(f) Condition D.1.2(b)(8) in the SPM 177-22666-00006, issued September 1, 2006, required 

that following startup of the Electric Melter the Permittee shall permanently remove the 

existing mixer, existing bucket elevator, Day Bin 2N, Day Bin 3E, and Day Bin 3W. 

Condition D.2.4(e) required that the production rate of the Electric Melter shall not exceed 

8,750 pounds of glass per hour (on a 4-hr average basis) until the Line 2 Melt Furnace 

and Line 3 Melt Furnace have been permanently shut down. 

Line 2 and Line 3 Melt Furnaces, the Day Bins, the mixer, and bucket elevator have been 

removed. Therefore, the PSD minor limits for PM10, VOC, CO, NOx and SO2 limits have 

been removed. 

Enforcement Issue 

Title V renewal application should have been submitted nine (9) months prior to the expiration of 

the source’s existing permit. IDEM is reviewing this matter and will take appropriate action. 

Emission Calculations 

See Appendix A of this document for detailed emission calculations (Appendix A, pages 1 through 

14). 

County Attainment Status 

The source is located in Wayne County. 
Johns Manville International, Inc. Page 8 of 24 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

Pollutant Status 

PM10 Attainment 

PM 2.5 Attainment 

SO2 Attainment 

NOx Attainment 

8-hour Ozone Attainment 

CO Attainment 

Lead Attainment 

 Note: 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. 

(a) Wayne County has been classified as unclassifiable or attainment for PM2.5. U.S. EPA 

has not yet established the requirements for Prevention of Significant Deterioration (PSD), 

326 IAC 2-2 for PM2.5 emissions. Therefore, until the U.S. EPA adopts specific 

provisions for PSD review for PM2.5 emissions, it has directed states to regulate PM10 

emissions as a surrogate for PM2.5 emissions. See the State Rule Applicability – Entire 

Source section. 

(b) Volatile organic compounds (VOC) emissions 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 the ozone standard. Therefore, VOC and NOx 

emissions are considered when evaluating the rule applicability relating to ozone. Wayne

County has been designated as attainment or unclassifiable for the 8-hour ozone 

standard. Therefore, VOC and NOx emissions were reviewed pursuant to the 

requirements for Prevention of Significant Deterioration (PSD), 326 IAC 2-2. See the 

State Rule Applicability - Entire Source section. 

(c) Wayne County has been classified as attainment or unclassifiable in Indiana for PM10, 

SO2, NOx, CO, and Lead. Therefore, these emissions were reviewed pursuant to the 

requirements for Prevention of Significant Deterioration (PSD), 326 IAC 2-2. See the 

State Rule Applicability for the source section. 

(d) 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. 

(e) Fugitive Emissions 

Since this type of operation is in one of the twenty-eight (28) listed source categories 

(Glass Fiber Processing Plant) under 326 IAC 2-2 or 326 IAC 2-7, fugitive emissions are 

counted toward the determination of PSD and Part 70 applicability. 

Unrestricted Potential Emissions

This table reflects the unrestricted potential emissions of the source. 

Pollutant tons/year 

PM 1,284 

PM10 1,285 

SO2 9.77 

VOC 89.8 

CO 150 

NOx 16.9 
Johns Manville International, Inc. Page 9 of 24 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

HAPs tons/year 

Hydrogen 

Fluoride 0.23 

Total 0.23 

 (a) The potential to emit (as defined in 326 IAC 2-7-1(29)) of PM-10 and CO are greater than 

100 tons per year. Therefore, the source is subject to the provisions of 326 IAC 2-7. 

(b) The potential to emit (as defined in 326 IAC 2-7-1(29)) of all other criteria pollutants are 

less than 100 tons per year. 

Actual Emissions 

The following table shows the actual emissions reported by the source. This information reflects 

the 2003 OAQ emission data. 

Pollutant Actual Emissions (tons/year) 

PM Not reported 

PM10 72 

SO2 21 

VOC 46 

CO 89 

NOx 54 

HAP Not reported 

Part 70 Permit Conditions 

This source is subject to the requirements of 326 IAC 2-7, pursuant to which the source has to 

meet the following: 

(a) Emission limitations and standards, including those operational requirements and 

limitations that assure compliance with all applicable requirements at the time of issuance 

of Part 70 permits. 

(b) Monitoring and related record keeping requirements which assume that all reasonable 

information is provided to evaluate continuous compliance with the applicable 

requirements. 

Potential to Emit After Issuance 

The table below summarizes the potential to emit, reflecting all limits, of the emission units. Any 

control equipment is considered federally enforceable only after issuance of this Part 70 permit 

renewal, and only to the extent that the effect of the control equipment is made practically 

enforceable in the permit. 
Johns Manville International, Inc. Page 10 of 24 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

 Potential to Emit (tons/year) 

Process/Emission Unit PM PM10 SO2 VOC CO NOX HAP

Railcar Receiving 0.63(1) 0.63(1) - - - - - 

Raw Material Batch 

Silos #1 - #8 0.26(1) 0.26(1) - - - - - 

Melter daybin #1 and #2 0.18(1) 0.18(1) - - - - - 

Mixer 4.16x10-3(1) 1.39x10-3(1) - - - - - 

Batch Transfer System 0.35(1) 0.35(1) - - - - - 

Weigh Scale 4.06 x10-3(1) 4.06 x10-3(1) - - - - - 

Electric Melter 2.15(2) 2.15(2) 0.07 4.82(2) 3.64(2) 1.66 Hydrofluoric 

acid: 0.03 

Line 2 Forming and 

Collection Module 58.3(3) 58.3(3) 4.82 29.7(4) 68.3(2) 19.8(5) 

Line 3 Forming and 

Collection Module 123.6(3) 123.6(3) 4.82 29.7(4) 68.3(2) 19.8(5) - 

Line 2 Shredding and 

Packaging 8.15(4) 8.15(4) - - - - - 

Line 3 Shredding and 

Packaging 13.5(4) 13.5(4) - - - - - 

Melter Duster Recycle 

System 0.83(6) 0.83(6) - - - - - 

Cold End Housekeeping 

System 2.23(6) 2.23(6) - - - - - 

Natural Gas-fired Boiler 

(B-2) 0.20(7) 0.82(7) 0.06 0.59 9.02 10.7 Combination: 

0.20 

Total 210 211 

less 

than 

100 

less 

than 

100 

149 

less 

than 

100 

Single: 

less than 10 

Combination: 

less than 25 

PSD Major Source 

Threshold 100 100 100 100 100 100 - 

Pursuant to CP-177-5873-00006, issued April 22, 1999, and 326 IAC 6.5-10-11. 

(1) Pursuant to 326 IAC 6.5-1-2(a), the particulate matter emissions from the Mixer, Batch Transfer System, Day Bin 1 

and Day Bin 2, Melter Dust Recycle System, shall not exceed 0.03 grains per dry standard cubic foot. 

(2) Pursuant to SSM 177-22008-00006, issued August 10, 2006, in order to render the requirements of 326 IAC 2-2 

not applicable. 

(3) PM/PM10 emissions from these units (line 2 and 3 forming and collection modules) are specifically limited to 58.3 

and 123.6, respectively, pursuant to CP-177-5873-00006, issued April 22, 1999, and 326 IAC 6.5-10-11. 

(4) Pursuant to CP-177-5873-00006, issued April 22, 1999, 326 IAC 2-2-3(a)(3) and as revised by SSM 177-22008-

00006. 

(5) These units are specifically limited to 19.8 NOx tons per year, pursuant to CP-177-5873-00006, issued April 22, 

1999 and revised by T177-22598-00006, in order to render the requirements of 326 IAC 2-2 not applicable. 

(6) Pursuant to CP-177-5873-00006, issued April 22, 1999, in order to render the requirements of 326 IAC 2-2 not 

applicable. 

(7) Although this boiler is specifically limited to 1.49 tons of PM/PM10 per year, pursuant to 326 IAC 6.5-10-11, AP-42 

emission factors shows that it's potential to emit PM/PM10 are 0.20 and 0.82 ton per year, respectively. 

(a) This existing stationary source is major for PSD because the emissions of at least one 

attainment criteria pollutant are greater than one hundred (>100) tons per year, and it is 

one of the twenty-eight (28) listed source categories. 
Johns Manville International, Inc. Page 11 of 24 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

(b) Fugitive Emissions 

Since this type of operation is in one of the twenty-eight (28) listed source categories 

(Glass Fiber Processing Plant) under 326 IAC 2-2, fugitive emissions are counted toward 

the determination of PSD and Emission Offset applicability. 

Federal Rule Applicability 

The following federal rules are applicable to the source:

(a) Pursuant to 40 CFR 64.2, Compliance Assurance Monitoring (CAM) is applicable to 

existing emission units that involve a pollutant-specific emission unit and meet the 

following criteria: 

(1) has a potential to emit before controls equal to or greater than the 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 existing emission unit involved: 

Emission Unit / 

Pollutant 

Control 

Device

Used 

Emission

Limitation

(Y/N) 

Uncontrolled

PTE

(tons/year) 

Controlled

PTE

(tons/year)

Major

Source

Threshold

(tons/year) 

CAM

Applicable

(Y/N) 

Large

Unit

(Y/N)

Line 2 Forming & 

Collection - PM10 a Y greater than 

100 45.0 100 Y N 

Line 3 Forming & 

Collection - PM10 a Y greater than 100 45.0 100 Y N 

Line 2 Shredding & 

Packaging - PM10 baghouse Y greater than 

100 8.15 100 Y N 

Line 3 Shredding & 

Packaging - PM10 baghouse Y greater than 

100 13.5 100 Y N 

Line 2 Forming & 

Collection - PM a Y greater than 100 45.0 100 Y N 

Line 3 Forming & 

Collection - PM a Y greater than 

100 45.0 100 Y N 

Line 2 Shredding & 

Packaging - PM baghouse Y greater than 100 8.15 100 Y N 

Line 3 Shredding & 

Packaging - PM baghouse Y greater than 100 13.5 100 Y N 

a - fog box / wet spray collection system 

Based on this evaluation, the requirements of 40 CFR Part 64, CAM are applicable to Line 2 and 3 

Forming and Collection Processes, and Lines 2 and 3 Shredding and Packaging for PM and 

PM10. A CAM plan has been submitted and the Compliance Determination and Monitoring 

Requirements section includes a detailed description of the CAM requirements. 

The CAM plan for this unit include the confirmation that control devices (wet sprays) are operated 

in accordance with manufacturers recomendations. This requirement is detailed in the 

“Compliance Requirements” section of this TSD. 
Johns Manville International, Inc. Page 12 of 24 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

 (b) The requirements of the New Source Performance Standard for Storage Vessels for 

Petroleum Liquids for Which Construction, Reconstruction, or Modification Commenced 

After June 11, 1973, and Prior to May 19, 1978 (40 CFR 60, Subpart K) (326 IAC 12) are 

not included in this permit for the gasoline fuel transfer and dispensing operations, the 

petroleum fuel transfer and dispensing operations, or the 300 gallon storage tanks for 

gasoline, diesel, and kerosene. None of these tanks have storage capacity greater than 

151,412 liters (40,000 gallons). 

 (c) The requirements of the New Source Performance Standard for Storage Vessels for 

Petroleum Liquids for Which Construction, Reconstruction, or Modification Commenced 

After May 18, 1978, and Prior to July 23, 1984 (40 CFR 60, Subpart Ka) (326 IAC 12) are 

not included in this permit for the gasoline fuel transfer and dispensing operations, the 

petroleum fuel transfer and dispensing operations, or the 300 gallon storage tanks for 

gasoline, diesel, and kerosene. None of these tanks have storage capacity greater than 

151,412 liters (40,000 gallons). 

 (d) The requirements of the New Source Performance Standard for Volatile Organic Liquid 

Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, 

Reconstruction, or Modification Commenced After July 23, 1984, (40 CFR 60, Subpart 

Kb), are not included in this permit for the for the following storage tanks: Gasoline Tanks, 

Diesel Tanks, Kerosene Tank, Petroleum Tank, Binder Tank, Dedusting Tank, Used Oil 

Tank, and Emulsion Tanks. None of these volatile organic liquid storage vessels have a 

capacity greater than 75,000 liters (19,813 gallons). 

 (e) The requirements of the New Source Performance Standard for Glass Manufacturing 

Plants (40 CFR 60, Subpart CC) (326 IAC 12) are not included in this permit. The gasfired glass melting furnaces on lines 2 and 3 were removed following permit 177-22666-

00006 issuance on September 1, 2006. 

The requirements of 40 CFR 60, Subpart CC are not included in this permit for the electric 

melter installed in 2006. Pursuant to Section 60.290(c) the Supart does not apply to 

electric melters. 

 (f) The requirements of New Source Performance Standard for Small 

Industrial/Commercial/Institutional Steam Generating Units (40 CFR 60, Subpart Dc) (326 

IAC 12) are not included in this permit. Boiler S4 was constructed in 1961. 

 (g) The requirements of New Source Performance Standard for Wool Fiberglass Insulation 

Manufacturing Plants (40 CFR 60 Subpart PPP) (326 IAC 12) are included for wool 

fiberglass insulation manufacturing lines which are comprised of forming sections, curing 

sections, and cooling sections. 

 Pursuant to 40 CFR 60.680, each rotary spin wool fiberglass insulation manufacturing line 

constructed, reconstructed or modified after February 7, 1984 is an affected facility subject 

to the requirements of 40 CFR Part 60, Subpart PPP. The specific facilities subject to this 

rule include the following: 

(1) One (1) Line 2 Forming and Collection Module; constructed in 1961 and modified 

in 2000 and 2006; consisting of a rotary spinner and collection conveyor; with a 

maximum unbonded glass production rate of 8,750 pounds per hour. Natural gas 

is utilized in the combustion section of the forming chamber. The maximum heat 

input capacity of the combustion section is 20 MMBtu/hr. As fibers are formed, 

they are carried in the airstream towards a moving collection chain where they are 

captured and transferred to the shredding process. A water spray is applied to the 

airstream to control particulate matter emissions before the airstream is exhausted 
Johns Manville International, Inc. Page 13 of 24 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

to stack S2; (Formerly referred to as the Line 2 forming chamber for unbonded 

product) 

(2) One (1) Line 3 Forming and Collection Module; constructed in 1961 and modified 

in 2000 and 2006; consisting of a rotary spinner and collection conveyor; with a 

maximum unbonded glass production rate of 8,750 pounds per hour. Natural gas 

is utilized in the combustion section of the forming chamber. The maximum heat 

input capacity of the combustion section is 20 MMBtu/hr. As fibers are formed, 

they are carried in the airstream towards a moving collection chain where they are 

captured and transferred to the shredding process. A water spray is applied to the 

airstream to control particulate matter emissions before the airstream is exhausted 

to stack S3; (Formerly referred to as the Line 3 forming chamber for unbonded 

product) 

 The Line 2 and Line 3 Forming and Collection Modules are rotary spin wool fiberglass 

insulation manufacturing lines and have been modified after February 7, 1984. 

 Note that the monitoring, record keeping and reporting requirements specified in 40 CFR 

60.683 through 40 CFR 60.684 apply only if the affected facility uses a wet scrubbing 

control device or wet electrostatic precipitator control device. The affected facilities at this 

source do not use either type of control device. 

 

 Nonapplicable portions of the NSPS are not included in the permit. The affected facilities 

are subject to the following sections of 40 CFR Part 60, Subpart PPP: 

(1) 40 CFR 60.680 

(2) 40 CFR 60.681 

(3) 40 CFR 60.682 

(4) 40 CFR 60.685 

 

 The provisions of 40 CFR Part 60, Subpart A - General Provisions, which are incorporated 

as 326 IAC 12, apply to each affected facility described in 40 CFR 60.680 except when 

otherwise specified in 40 CFR Part 60, Subpart PPP. 

 (h) The provisions of National Emission Standards for Hazardous Air Pollutants, 40 CFR 63 

Subpart NNN, National Emission Standards for Hazardous Air Pollutants for Wool 

Fiberglass Manufacturing (326 IAC 20) are not included in this permit. Pursuant to 40 CFR 

63.1380(a), the standard applies to each wool fiberglass manufacturing facility that is 

located at a major source of HAPs. This source is not a major source of HAPs, as defined 

in 40 CFR 63.2. 

 (i) The requirements of the National Emission Standards for Hazardous Air Pollutants for 

Stationary Reciprocating Internal Combustion Engines (RICE), 40 CFR 63, Subpart ZZZZ 

(326 IAC 20), are not included in the permit for the (5) standby diesel generators. Pursuant 

to 40 CFR 63.6590(b)(3), there are no applicable requirements from 40 CFR 63, Subpart 

ZZZZ and 40 CFR 63, Subpart A for existing compression ignition (CI) stationary RICE. 

This source is not a major source of HAPs, as defined in 40 CFR 63.2. 

 (j) The requirements of the National Emission Standards for Hazardous Air Pollutants for 

Process Cooling Towers, 40 CFR 63, Subpart Q (326 IAC 20), are not included in the 

permit for the cooling tower system. This source is not a major source as defined in 40 

CFR 63.401. 

 (k) The requirements of the National Emission Standards for Hazardous Air Pollutants for 

Halogenated Solvent Cleaning, 40 CFR 63, Subpart T (326 IAC 20), are not included in 
Johns Manville International, Inc. Page 14 of 24 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

the permit for the degreasing operation because the degreasing operations do not use 

halogenated solvents and this source is not a major source of HAP emissions. 

State Rule Applicability – Entire Source 

326 IAC 2-2 (Prevention of Significant Deterioration (PSD)) 

This source is one of the 28 source categories (glass fiber processing plant) with a PSD 

applicability threshold of 100 tons per year. The potential to emit at this source is greater than 

100 tons per year. The source was first constructed, prior to PSD applicability. Therefore, no PSD 

review occured at the orginal construction. Line 2 and Line 3 Forming and Collection Modules 

were constructed in 1961. The potential to emit PM10 of these sources is greater than 100 tons 

per year. Therefore, the source has been major for PSD since the inception of the PSD rules. 

Pursuant to CP-177-5873-00006, issued April 22, 1999, the source increased the production 

capacities of the existing manufacturing lines. As a result, the PM, PM10, VOC and CO emissions 

were greater than PSD significant thresholds and required PSD review. BACT was performed for 

VOC, PM, PM10, and CO for each modified facility of the source which includes the forming, 

curing and cooling processes for Lines 2, 3, and 6. Limits below the significance thresholds were 

taken for NOx and SO2 to ensure that PSD did not apply. The BACT and PSD minor modification 

limits are as follows: 

(a) Pursuant to CP-177-5873-00006, issued April 22, 1999; and 326 IAC 2-2-3 (Prevention of 

Significant Deterioration (PSD)), from the raw material handling, storage and batching 

facilities for lines 2 and 3 shall comply with the following limitations: 

(1) The Railcar Receiving Station shall be equipped with a bootlift device or similar 

device and shall not exceed an average of three percent (3%) opacity in any 24 

consecutive readings recorded in 15 second intervals in accordance with the 

applicable requirements of 40 CFR 60, Appendix A, Method 9; The baghouse 

ensures compliance with this limit. 

(2) The raw material conveyor system (which operates as part of the railcar receiving 

station) shall be enclosed and shall not exceed an average of three percent (3%) 

opacity in any 24 consecutive readings recorded in 15 second intervals in 

accordance with the applicable requirements of 40 CFR 60, Appendix A, 

Method 9. 

(3) The raw material silos shall be equipped with fabric filters and shall not exceed 

an average of three percent (3%) opacity in any 24 consecutive readings 

recorded in 15 second intervals in accordance with the applicable requirements 

of 40 CFR 60, Appendix A, Method 9. 

(4) The forming, curing, and cooling processes shall comply with the following 

limitations: 

Pollutant Emission Limitations Facility PM/PM10 (lb/hr) VOC (lbs/hr) CO (lbs/hr) 

Line 2 Forming and 

Collection 10.3 6.78 21.0 

Line 3 Forming and 

Collection 10.3 6.78 21.0 

(5) The particulate emissions from stack S34 from the Melter Dust Recycle System 

(Formerly referred to as the EP recycling system) shall not exceed an average of 

three percent (3%) opacity in any 24 consecutive readings recorded in 15 second 
Johns Manville International, Inc. Page 15 of 24 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

intervals in accordance with the applicable requirements of 40 CFR 60, Appendix 

A, Method 9; 

(6) The cold end housekeeping system shall be equipped with a baghouse system 

and shall not exceed an average of three percent (3%) opacity in any 24 

consecutive readings recorded in 15 second intervals in accordance with the 

applicable requirements of 40 CFR 60, Appendix A, Method 9; and 

(7) The ancillary equipment shall also comply with the following limitations: 

Facility

Limitation 

PM/PM10 

(lbs/hr)

Melter Dust Recycle System 0.19 

Cold End Housekeeping 

System 0.51 

PM/PM10 means that the PM limit and the PM10 limit are the same and shall be 

measured as the sum of the filterable and condensable factions. 

(b) Pursuant to CP-177-5873-00006, issued April 22, 1999 and revised by this Part 70 

renewal permit, T177-22598-00006; in order to render the requirements of 326 IAC 2-2 

(Prevention of Significant Deterioration (PSD)) not applicable for NOx and SO2 the 

source shall comply with the following limitations: 

(1) Each manufacturing line shall comply with the following limitations: 

Facility

Pollutant Emission 

Limitations, 

NOX (lbs/hr) 

Line 2 Forming and 

Collection 4.53 

Line 3 Forming and 

Collection 4.53 

Line 6 has been permanently shut down and the limits under CP-177-5873-

00006 have been increased to compensate for removed equipment. The 

adjusted limits are below the PSD significant thresholds. 

Construction of the natural gas-fired boiler commenced in 1961 prior to the PSD 

applicability date of August 7, 1977. The boiler unit was not modified after 1961. 

The PM/PM10, VOC, CO, NOx and SO2 limits established by the CP-177-5873-

00006, issued April 22, 1999 have been removed. 

The VOC, CO, NOx and SO2 limits established by the CP-177-5873-00006, 

issued April 22, 1999 for the Melter Dust Recycle System and the Cold End 

Housekeeping System have been removed. Neither the facility produces VOC, 

CO, SO2, or NOx. Therefore, no limit should have been required. 

(c) In 2006, pursuant to SSM 177-22008-00006, issued on August 10, 2006, emission units 

(Mixer, batch transfer system, day bins, and the Electric Melter) were approved for 

construction and modification (Line 2 and Line 3 Forming and Collection Modules and the 

Melter Dust Recycle System). It should be noted that Line 6 has been permanently shut 

down, Line 2 and Line 3 Melters were demolished in 2006. 

The total increase in potential to emit PM of the modification was less than 25 tons per 
Johns Manville International, Inc. Page 16 of 24 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

year. In order to render the requirements of 326 IAC 2-2 (Prevention of Significant 

Deterioration (PSD)) not applicable to the modification completed pursuant to SSM 177-

22008-00006 issued on August 10, 2006: 

 (1) The PM10 emissions from the Day Bin 1 shall not exceed 0.01 pounds per hour. 

 (2) The PM10 emissions from the Day Bin 2 shall not exceed 0.01 pounds per hour. 

 (3) The PM10 emissions from the Mixer shall not exceed 0.005 pounds per hour. 

(4) The PM10 emissions from the Weigh Scale shall not exceed 0.005 pounds per 

hour. 

(5) The PM10 emissions from the Railcar Receiving Station shall not exceed 0.095 

pounds per hour. 

(6) The PM10 emissions from the Raw Material Silos shall not exceed 0.04 pounds 

per hour, total. 

(7) The PM10 emissions from the Batch Transfer System shall not exceed 0.053 

pounds per hour. 

(8) The PM10 emissions from the Electric Melter shall not exceed 0.49 pounds per 

hour. 

(9) The PM10 emissions from the L2 Shredding Process and L2 Packaging Area 

shall not exceed 0.9 pounds per hour, total. 

(10) The PM10 emissions from the L3 Shredding Process and L3 Packaging Area 

shall not exceed 0.9 pounds per hour, total. 

(11) The PM10 emissions from the Melter Dust Recycle System shall not exceed 

0.001 pounds per hour. 

(12) The CO emissions from the L2 Forming and Collection Module shall not exceed 

15.6 pounds per hour. 

(13) The CO emissions from the L3 Forming and Collection Module shall not exceed 

15.6 pounds per hour. 

(14) The CO emissions from the Electric Melter shall not exceed 0.83 pounds per 

hour. 

(15) The VOC emissions from the Electric Melter shall not exceed 1.1 pounds per 

hour. 

(16) Each packaging area shall comply with the following limitations: 

(a) The PM10 emissions from the L2 Shredding Process and L2 Packaging 

Area shall not exceed 0.9 pounds per hour, total. 

(b) The PM10 emissions from the L3 Shredding Process and L3 Packaging 

Area shall not exceed 0.9 pounds per hour, total. 

326 IAC 1-5-2 (Emergency Reduction Plans) 

The source submitted an Emergency Reduction Plan (ERP) on December 13, 1996. 
Johns Manville International, Inc. Page 17 of 24 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

 326 IAC 2-3 (Emission Offset) 

This source is not subject to the requirements of 326 IAC 2-3 because it is located in Wayne 

County which is designated as an attainment area for all criteria pollutants. 

326 IAC 2-4.1 (Major Sources of Hazardous Air Pollutants (HAP)) 

This source is not subject to the requirements of 326 IAC 2-4.1 because it emits less than 10 tons 

per year of a single HAP and less than 25 tons per year of a combination of HAPs. 

The sources original Part 70 permit, T177-7720-00006 issued October 4, 2001, limited the HAP 

emissions from forming facilities (lines 2, 3, and 6) to render the requirements of 40 CFR Part 63, 

Subpart NNN not applicable. This limit was necessary because the Modules could produce 

bonded fiberglass product. 

Following the modifications documented in SPM 177-22666-00006 issued September 1, 2006, the 

Modules can not produce bonded product and the only source of HAP emissions is the Electric 

Melter. Forming and collection modules (Line 2 and 3) shall not produce bonded fiberglass. The 

total PTE of HAP from the source is now significantly less than 1.00 ton of any single HAP or of a 

combination of HAP. The HAP limit has been removed from the permit because it is now 

unnecessary. 

326 IAC 2-6 (Emission Reporting) 

This source is subject to 326 IAC 2-6 (Emission Reporting) because it is required to have an 

operating permit under 326 IAC 2-7, Part 70 program. Pursuant to this rule, the Permittee shall 

submit an emission statement certified pursuant to the requirements of 326 IAC 2-6. This 

statement must be received in accordance with the compliance schedule specified in 326 IAC 2-6-

3 and must comply with the minimum requirements specified in 326 IAC 2-6-4. The submittal 

should cover the period identified in 326 IAC 2-6. 

 

326 IAC 5-1 (Opacity Limitations) 

The source is located in Wayne County, which is not one of the areas listed in 326 IAC 5-1-1(c). 

Therefore, this source is subject to the provisions of 326 IAC 5-1-2(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 the 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. 

326 IAC 6.5-1 (Particulate Matter Limitations Except Lake County - General Provisions) and 326 IAC 

 6.5-10 (Wayne County) 

Pursuant to T177-7720-000006, issued October 4, 2001, this source was subject to the 

requirements of 326 IAC 6-1-2 and 326 IAC 6-1-14. On September 1, 2005, 326 IAC 6-1 was 

repealed, 326 IAC 6-1-2 and 326 IAC 6-1-14 were replaced with 326 IAC 6.5-1-2 and 326 IAC 6.5-

10, respectively. 

Pursuant to 326 IAC 6.5-1-1(a), this source is subject to the requirements of 326 IAC 6.5-1 

because it is located in Wayne County and has potential particulate emissions greater than one 

hundred (100) tons of per year. 

Pursuant to 326 IAC 6.5-10-11 (Johns Manville Corporation), the particulate matter emissions 

from: 
Johns Manville International, Inc. Page 18 of 24 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

 (a) The natural gas-fired boiler, identified as B-2, shall not exceed 0.0137 lb/MMBtu heat input 

 and 1.5 tons per year. 

 (b) Line 3 Curing Oven shall not exceed 0.02 gr/dscf and 27.4 ton/yr. 

 (c) The L2 Forming and Collection Module shall not exceed 0.02 gr/dscf and 58.3 ton/yr. 

 (d) The L3 Forming and Collection Module shall not exceed 0.02 gr/dscf and 123.6 ton/yr. 

The requirements of New Source Performance Standard for Wool Fiberglass Insulation 

Manufacturing Plants (40 CFR 60 Subpart PPP) (326 IAC 12) are included for the Line 2 and Line 

3 Forming and Collection Modules. The limitations in 326 IAC 6.5-10-11 are more stringent than 

40 CFR 60 Subpart PPP and therefore apply. 

Pursuant to 326 IAC 6.5-1-1(a)(2), the particulate emissions from the Electric Melter, Mixer, Batch 

Transfer System, Melter Dust Recycle System, Day Bin 1, and Day Bin 2 shall not exceed 0.03 

grains per dry standard cubic foot. These facilities are not specifically listed in 326 IAC 6.5-10-11. 

 326 IAC 6-3-2 (Particulate Matter Emissions Limitations From Process Operations) 

Pursuant to 326 IAC 6-3-1(c), this rule shall not apply if a particulate matter limitation established 

in 326 IAC 6.5 (Particulate Matter Limitations Except Lake County) or 326 IAC 12 (New Source 

Performance Standards ) are more stringent. Therefore, this rule does not apply to this source, 

which is limited according to 326 IAC 6.5 and 326 IAC 12. 

 326 IAC 6-5 (Fugitive Particulate Matter Emission Limitations) 

The source is located in Wayne County and was modified after December 13, 1985. However, the 

fugitive particulate emissions are negligible. Pursuant to 326 IAC 6-5-1(b), this source is exempt 

from the requirements of 326 IAC 6-5. 

 326 IAC 11-4 (Fiberglass Insulation Manufacturing) 

Johns Manville is not subject to the requirements of this rule because these requirements apply 

only to facilities located in Shelby County that produce fiberglass insulation by the superfine (flame 

blown) process existing on June 19, 1979. 

State Rule Applicability – Boiler #2, Forming and Collection Modules 

 326 IAC 7-1.1 (Sulfur Dioxide Emission Limitations) 

Pursuant to 326 IAC 7-1.1-1, any facility with a potential to emit SO2 greater than or equal to 25 

tons per year or 10 pounds per hour shall comply with the requirements of 326 IAC 7-1.1. None of 

the sources emission units have a potential to emit SO2 greater than or equal to 25 tons per year 

or 10 pounds per hour. 

 326 IAC 7-4-4 (Wayne County Sulfur Dioxide Emission Limitations) 

Pursuant to 326 IAC 7-4-4, the following sulfur dioxide emission limitations apply in Wayne County 

for Johns Manville International, Inc. Boiler B-2 no longer burns fuel oil. Therefore, the boiler is 

able to comply with this limit. 

Unit Description Limitation 

S4 Boiler B-2 (oil/gas) 1.6 lb/MMBTU 

 326 IAC 8-1-6 (VOC Emission Limitations) 

The Line 2 and 3 Forming and Collection Modules were installed in 1961, modified in 2000, 

modified again in 2006, and have the potential to emit volatile organic compounds greater than 

twenty-five (25) tons per year, but are not subject to the requirements of 326 IAC 8-1-6. These 
Johns Manville International, Inc. Page 19 of 24 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

facilities have satisfied the requirements of 326 IAC 8-1-6 because it is subject to the more 

restrictive PSD BACT requirements for VOC pursuant to 326 IAC 2-2. 

State Rule Applicability – Degreasing Operations 

 326 IAC 8-3-2 (Cold Cleaner Operations) 

This source is located in Wayne County and the degreaing operations were constructed in 2006. 

Therefore this source is subject to 326 IAC 8-3-2. The applicator cleaning operations are subject to 

the requirements of 326 IAC 8-3-2. This rule requires that the cleaner be equipped with a cover 

and a facility for draining cleaned parts as well as that waste solvent be stored only in covered 

containers. 

 326 IAC 8-3-5 (Cold cleaner degreaser operation and control) 

(a) This degreaser is a cold cleaner degreaser without a remote solvent reservoir. It was 

constructed after July 1, 1990. Therefore, 326 IAC 8-3-5(a) applies. The Permittee shall 

ensure that the following control equipment requirements are met: 

This rule requires that the owner and operator of a cold cleaner degreaser facility shall 

ensure that the degreaser is equipped with a cover that must be designed so that it can be 

easily operated with one (1) hand if certain conditions exist. The degreaser must be 

equipped with a facility for draining cleaned articles. 

(1) Equip the degreaser with a cover. The cover must be designed so that it can be 

easily operated with one (1) hand if: 

(A) The solvent volatility is greater than two (2) kiloPascals (fifteen (15) 

millimeters of mercury or three-tenths (0.3) pounds per square inch) 

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

Fahrenheit (100OF)); 

(B) The solvent is agitated; or 

(C) The solvent is heated. 

(2) Equip the degreaser with a facility for draining cleaned articles. If the solvent 

volatility is greater than four and three-tenths (4.3) kiloPascals (thirty-two (32) 

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

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

then the drainage facility must be internal such that articles are enclosed under 

the cover while draining. The drainage facility may be external for applications 

where an internal type cannot fit into the cleaning system. 

(3) Provide a permanent, conspicuous label which lists the operating requirements 

outlined in subsection (b). 

(4) The solvent spray, if used, must be a solid, fluid stream and shall be applied at a 

pressure which does not cause excessive splashing. 

(5) Equip the degreaser with one (1) of the following control devices if the solvent 

volatility is greater than four and three-tenths (4.3) kiloPascals (thirty-two (32) 

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

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

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

(120OF)): 
Johns Manville International, Inc. Page 20 of 24 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

(A) A freeboard that attains a freeboard ratio of seventy-five hundredths 

(0.75) or greater. 

(B) A water cover when solvent is used is insoluble in, and heavier than, 

water. 

(C) Other systems of demonstrated equivalent control such as a refrigerated 

chiller of carbon adsorption. Such systems shall be submitted to the 

U.S. EPA as a SIP revision. 

(b) Pursuant to 326 IAC 8-3-5(b) (Cold Cleaner Degreaser Operation and Control), the 

owner or operator of a cold cleaning facility construction of which commenced after July 

1, 1990, shall ensure that the following operating requirements are met: 

(1) Close the cover whenever articles are not being handled in the degreaser. 

(2) Drain cleaned articles for at least fifteen (15) seconds or until dripping ceases. 

(3) Store waste solvent only in covered containers and prohibit the disposal or 

transfer of waste solvent in any manner in which greater than twenty percent 

(20%) of the waste solvent by weight could evaporate. 

Testing Requirements

Testing at the Electric Melter is required for PM/PM10, VOC and CO emissions to demonstrate 

that the requirements of 326 IAC 2-2 are not applicable and to demonstrate compliance with 326 

IAC 6.5-1-1(a)(2). The Electric Melter was constructed in 2006 and will startup in 2007. The 

Permittee shall, no later than 180 days after initial startup of the Electric Melter shall perform 

PM/PM10, VOC and CO testing. These tests shall be repeated once every five (5) years from the 

date of valid compliance demonstration utilizing methods approved by the Commissioner. 

Testing on one of the Shredding and Packaging Processes is required for PM/PM10 emissions to 

demonstrate compliance with 326 IAC 2-2-3(a)(3). The Permittee shall, no later than 180 days 

after the initial startup of the Electric Melter. 

Testing on one of the Forming and Collection Modules is required for PM/PM10, VOC and CO 

emissions to demonstrate that the requirements of 326 IAC 2-2 are not applicable and to 

demonstrate compliance with 326 IAC 2-2-3(a)(3) and 326 IAC 6.5-10-11. The Permittee shall 

perform PM/PM10, VOC and CO testing on one of the Forming and Collection Modules within 

one hundred and eighty (180) days after the initial startup of the Electric Melter. These tests shall 

also be repeated once every five (5) years from the date of valid compliance demonstration 

utilizing methods approved by the Commissioner. All testing shall be conducted in accordance 

with Section C - Performance Testing. 

Compliance Requirements 

Permits issued under 326 IAC 2-7 are required to ensure that sources can demonstrate 

compliance with applicable state and federal rules on a more or less continuous basis. All state 

and federal rules contain compliance provisions, however, these provisions do not always fulfill the 

requirement for a more or less continuous demonstration. When this occurs IDEM, OAQ in 

conjunction with the source, must develop specific conditions to satisfy 326 IAC 2-7-5. As a result, 

compliance requirements are divided into two sections: Compliance Determination Requirements 

and Compliance Monitoring Requirements. 

Compliance Determination Requirements in Section D of the permit are those conditions that are 

found more or less directly within state and federal rules and the violation of which serves as 
Johns Manville International, Inc. Page 21 of 24 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

grounds for enforcement action. If these conditions 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 

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 approporiate corrective actions within a specific time period. 

The compliance monitoring requirements applicable to this source are as follows: 

 1. Line 2 and Line 3 Forming and Collection Modules have applicable compliance 

monitoring conditions as specified below: 

(a) Visible emission notations of stacks (S2 and S3) exhaust shall be performed 

once per day during normal daylight operations. 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. 

 (f) The Permittee shall record the pressure drop across the baghouses (S86, S85, 

S12, and S13) used in conjunction with the process, at least once per day when 

the process is in operation. When for any one reading, the pressure drop across 

the baghouse is outside the normal range of 1.0 and 8.0 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 or Exceedances, 

shall be considered a deviation from this permit. 

 (g) 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. 

 (h) For multi-compartment units, 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. 
Johns Manville International, Inc. Page 22 of 24 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

 (i) For a single compartment baghouses 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. Operations 

may continue only if the event qualifies as an emergency and the Permittee 

satisfies the requirements of the emergency provisions of this permit (Section B - 

Emergency Provisions). 

 (j) 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 have 

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. 

Operations may continue only if the event qualifies as an emergency and the 

Permittee satisfies the requirements of the emergency provisions of this permit 

(Section B - Emergency Provisions). 

These monitoring conditions are necessary because the airstream and water spray 

systems associated with the Line 2 and Line 3 Forming and Collection Modules must 

operate properly to ensure compliance with 326 IAC 2-2 (Prevention of Significant 

Deterioration), 326 IAC 6.5-10-11 (Johns Manville Corporation), and 326 IAC 2-7 (Part 

70). 

2. The raw material handling, storage, and batching equipment has applicable compliance 

monitoring conditions as specified below: 

(a) Visible emission notations of the railcar unloading station stack #165, raw 

material batch silos, day bins stack exhaust 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. 

 (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.

(f) The Permittee shall record the pressure drop across the baghouse exhausting to 

stack #165 used in conjunction with the railcar unloading station, at least once 

per shift when the process is in operation when venting to the atmosphere. 

When for any one reading, the pressure drop across the baghouse is outside the 

normal range of 4.0 and 8.0 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 or Exceedances. A 

pressure reading that is outside the above mentioned range is not a deviation 
Johns Manville International, Inc. Page 23 of 24 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

from this permit. 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. 

(g) In the event that bag failure has been observed (bag failure can be indicated by a 

significant drop in the baghouses pressure reading with abnormal visible 

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

flow rate, air infiltration, leaks, dust traces or triboflows): 

 (i) For multi-compartment units, 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. 

 (ii) For a single compartment baghouses 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. Operations may continue only if the event qualifies as an 

emergency and the Permittee satisfies the requirements of the 

emergency provisions of this permit (Section B - Emergency Provisions). 

 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 have 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. Operations may continue only if the event qualifies 

as an emergency and the Permittee satisfies the requirements of the 

emergency provisions of this permit (Section B - Emergency Provisions). 

These monitoring conditions are necessary because the baghouses and fabric filters must operate 

properly to ensure compliance with 326 IAC 2-2 (Prevention of Significant Deterioration), 326 IAC 

6.5-10-11 (Johns Manville Corporation), 326 IAC 6.5-1-2 (Particulate emission limitations; fuel 

combustion steam generators, asphalt concrete plant, grain elevators, foundries, mineral 

aggregate operations; modification by commissioner), and 326 IAC 2-7 (Part 70). 

The compliance monitoring requirements applicable to this source are as follows: 

Control Parameter Frequency Range Excursions and 

Exceedances 

Water 

Pressure 

Drop 

1.0 and 7.0 

inches 

boot lift device or similar 

device and the baghouse 

used to control PM 

emissions and opacity from 

the rail car unloading station 

Visible 

Emissions 

Daily 

NormalAbnormal 

Response Steps 

The baghouses used to 

control PM emissions from 

the Railcar Receiving 

Water 

Pressure 

Drop 

Daily 1.0 and 7.0 

inches 

Response Steps 
Johns Manville International, Inc. Page 24 of 24 

Richmond, Indiana T177-22598-00006 

Permit Reviewer: ERG/BL 

Control Parameter Frequency Range Excursions and 

Exceedances 

Station, Raw Material Silos, 

Day Bin 1, Day Bin 2, Mixer, 

Batch Transfer System and 

Weigh Scale 

Visible 

Emissions 

NormalAbnormal 

Water 

Pressure 

Drop 

2.0 and 4.0 

inches The Electric Melter baghouse

Visible 

Emissions 

Daily 

NormalAbnormal 

Response Steps 

Line 2 and Line 3 Forming 

and Collection Modules 

collection chain 

Visible 

Emissions Daily NormalAbnormal Response Steps 

Water 

Pressure 

Drop 

1.0 and 8.0 

inches Shredding and packaging 

area baghouse systems Visible 

Emissions 

Daily 

NormalAbnormal 

Response Steps 

Recommendation 

The staff recommends to the Commissioner that the Part 70 permit be approved. This 

recommendation is based on the following facts and conditions: 

Unless otherwise stated, information used in this review was derived from the application and 

additional information submitted by the applicant. 

An administratively complete Part 70 permit renewal application for the purposes of this review 

was received on February 6, 2006. 

Conclusion 

The operation of this fiberglass insulation manufacturing plant shall be subject to the conditions of 

this Part 70 permit T177-22598-00006.
Appendix A: Emission Calculations 

Emissions Summary

Company Name: Johns Manville International, Inc.

Address City IN Zip: 814 Richmond Ave., Richmond IN 47374

Title V Permit #: T177-22598-00006

Reviewer: ERG/BL

Date: 

Source/Stack Description PM PM10 SO2 VOC CO 

Railcar Receiving 4.18 4.18 - - - Raw Material Batch Silos #1 - #8 1.75 1.75 - - - Melter daybin #1 and #2 0.59 0.59 - - - Mixer 0.01 0.01 - - - Batch Tansfer System 1.17 1.17 - - - Weigh Scales 0.01 0.01 - - - Electric Melter 217 217 0.07 4.84 3.65 Line 2 Forming and Collection Module 132 132 4.82 42.2 68.7 Line 3 Forming and Collection Module 132 132 4.82 42.2 68.7 Line 2 Shredding and Packaging 396 396 - - - Line 3 Shredding and Packaging 396 396 - - - Dust Recycle System 2.61E-04 2.61E-04 - - - Cold End Housekeeping System 2.23 2.23 - - - Natural Gas-fired Boiler (B-2) 0.20 0.82 0.06 0.59 9.02 Total Emissions (ton/yr) 1,284 1,285 9.77 89.8 150 

November 27, 2006

Uncontrolled, Potential To Emit (tons/year)
Appendix A: Emission Calculations 

Emissions Summary (Continued)

Source/Stack Description PM PM10 SO2 VOC CO

Railcar Receiving 0.63 0.63 (1) - -- 

Raw Material Batch Silos #1 - #8 0.26 0.26 (1) - - - Melter daybin #1 and #2 0.18 0.18 (1) - - - Mixer 4.16E-03 4.16E-03 (1) - - - Batch Tansfer system 0.35 0.35 (1) - - - Weigh Scales 4.06E-03 4.06E-03 (1) - - - Electric Melter 2.15 2.15 (2) 0.07 4.82 3.64 Line 2 Forming and Collection Module 58.3 58.3 (3) 4.82 29.7 68.3 Line 3 Forming and Collection Module 123.6 123.6 (3) 4.82 29.7 68.3 Line 2 Shredding and Packaging 8.15 8.15 (5) - - - Line 3 Shredding and Packaging 13.5 13.5 (5) - - - Dust Recycle System 0.83 0.83 (6) - - - Cold End Housekeeping System 2.23 2.23 (6) - - - Natural Gas-fired Boiler (B-2) 0.20 0.82 (6) 0.06 0.59 9.02 Total Emissions (ton/yr) 210 211 9.77 64.8 149 

(2) Pursuant to SSM 177-22008-00006, issued August 10, 2006, in order to render the requirements of 326 IAC 2-2 not applicable.(5) Pursuant to CP-177-5873-00006, issued April 22, 1999, 326 IAC 2-2-3(a)(3) and as revised by SSM 177-22008-00006.(6) Pursuant to CP-177-5873-00006, issued April 22, 1999, in order to render the requirements of 326 IAC 2-2 not applicable.

Potential to Emit After Issuance (tons/year)

(3) PM/PM10 emissions from these units (line 2 and 3 forming and collection modules) are specifically limited to 58.3 and 123.6, respectively, pursuant to CP-177-5873-00006, issued Apr(7) Although this boiler is specifically limited to 1.49 tons of PM/PM10 per year, pursuant to 326 IAC 6.5-10-11, AP-42 emission factors shows that it's potential to emit PM/PM10 are 0.20 (4) These units are specifically limited to 19.8 NOx tons per year, pursuant to CP-177-5873-00006, issued April 22, 1999 and revised by T177-22598-00006, in order to render the require(1) Pursuant to 326 IAC 6.5-1-2(a), the particulate matter emissions from the Mixer, Batch Transfer System, Day Bin 1 and Day Bin 2, Melter Dust Recycle System, shall not exceed 0.03 
Appendix A - Emission Calculations

T177-22598-00006

Title V Renewal

Page 3 of 15, TSD App A

Source: Railcar Receiving

Control Device: Baghouse and boot lift device exhausting to stack S165

Description: Raw materials off-loaded from railcar

Production

Actual lb/hr 7,519 13,907 hr/yr

Potential 17,500 lb/hr 8,760 hr/yr

Actual Production Potential Production

104,566,733 lb/yr 153,300,000 lb/yr

Potential To Emit (Based On Run Hours And Air Flow Rate)

Unit Run Time * 

(min/day)

Air Flow

(aft3

/min)

Controlled

Grain Loading

(gr/dsft3

)

Uncontrolled Grain 

Loading

(gr/dsft3)

Controlled Potential 

to Emit 

(lb/yr)

Controlled 

Potential to Emit

(ton/yr)

Uncontrolled 

Potential to Emit

(ton/yr)

Railcar Receiving 573 1,400 0.02 0.20 836 0.42 4.18

*Run time is based on the maximum capacity of the production lines.

Potential to Emit After Issuance

Unit Run Time * 

(min/day)

Air Flow

(aft3

/min)

Permitted Grain 

Loading

(gr/dsft3

)

Potential to Emit 

(lb/yr)

Potential to Emit

(ton/yr)

Railcar Receiving 573 1,400 0.03 1254 0.63

*Run time is based on the maximum capacity of the production lines.

METHODOLOGY

Potential to Emit (ton/yr) = Run Time (min/day) * Air Flow (aft3

/min) * Grain Loading (gr/dsft3) * 365 days/1yr * 1 lb/7,000 gr * 1 ton/2,000 lbs

Assume that the actual conditions of the displaced air are equal to dry standard conditions.

The assumed baghouse control effiency is 90%.
Appendix A - Emission Calculations

T177-22598-00006

Title V Renewal

Page 4 of 15, TSD App A

Source: Eight (8) Raw material Batch Silos

Control Device: Fabric filters exhausted to emission points S21 through S28

Controlled Outlet Grain Loading: 0.02 gr/dsft3

Uncontrolled Outlet Grain Loading: 0.20 gr/dsft3

Permitted Outlet Grain Loading: 0.03 gr/dsft3

Uncontrolled, Potential To Emit

Material

Run Times * 

(min/day)

Air Flow

(aft3

/min)

Potential to Emit

(lb/yr)

Potential to Emit 

(ton/yr)

Silo 1 Sand 81.9 325 278 0.14

Silo 7 Soda Ash 72.5 325 246 0.12

Silo 5 Borax 85.9 325 291 0.15

Silo 3 N Syenite 85.2 325 289 0.14

Silo 8 Plate glass Cullet 135 1,140 1,604 0.80

Silo 2 Borosilicate Cullet 12.7 325 43 0.02

Silo 4 Internal Cullet 51.1 325 173 0.09

Silo 6 BD Lime (truck) 48.3 1,140 575 0.29

Total 1.75

*Run times are based on the maximum capacity of the production lines.

Potential to Emit After Issuance

Material

Run Times * 

(min/day)

Air Flow

(aft3/min)

Potential to Emit

(lb/yr)

Permit Limit

(ton/yr)

Silo 1 Sand 81.9 325 41.7 0.02

Silo 7 Soda Ash 72.5 325 36.9 0.02

Silo 5 Borax 85.9 325 43.7 0.02

Silo 3 N Syenite 85.2 325 43.3 0.02

Silo 8 Plate glass Cullet 135 1,140 241 0.12

Silo 2 Borosilicate Cullet 12.7 325 6.48 0.00

Silo 4 Internal Cullet 51.1 325 26.0 0.01

Silo 6 BD Lime (truck) 48.3 1,140 86.2 0.04

Total 0.26

Methodology

Potential to Emit (ton/yr) = Run Time (min/day) * Air Flow (aft3/min) * Grain Loading (gr/dsft3) * 365 days/1 yr * 1 lb/7,000 gr * 1 ton/2,000 lbs

Assume that actual conditions of the air flow in the batch silos is equal to air flow at dry standard conditions.

The assumed fabric filter control effiency is 90%.
Appendix A - Emission Calculations

T177-22598-00006

Title V Renewal

Page 5 of 15, TSD App A

Source: Batch Day Bins #1 & #2

Control Device: Dust Collectors exhausting to stacks S167 and S168

Potential To Emit

Permitted Hours 8,760 hrs

Controlled Grain Loading: 0.01 gr/dsft3 Max Potential

Uncontrolled Grain Loading: 0.10 gr/dsft3

Permitted Grain Loading: 0.03 gr/dsft3

Volume Displaced: 81,900,000 aft3

/yr Rated Capacity (total)

Pollutant Permit Limit Permit Limit Uncontrolled, 

Potential to Emit Potential to Emit

(lb/hr) (ton/yr) (lb/hr) (ton/yr)

PM10 : 0.04 0.18 0.13 0.59

Methodology

Potential to Emit (ton/yr) = Volume Displaced (aft3

/yr) * Grain Loading (gr/dsft3) * 1 lb/7,000 gr * 1 ton/2,000 lbs

Assume that the actual conditions of the displaced air are equal to dry standard conditions.

The assumed dust collector control effiency is 90%.
Appendix A - Emission Calculations

T177-22598-00006

Title V Renewal

Page 6 of 15, TSD App A

Source: Mixer

Control Device: Sock Filter exhausting indoors to general ventilation

Characteristics of a Typical Batch 

Batch Mass Mass Fraction Density

Component (lb) (%) (lb/ft3

)

Sand 1,224 0.21 100

Carbocite 2.00 3.44E-04 45.0

Syenite 912 0.16 90.0

Internal Cullet 800 0.14 90.0

Borax 738 0.13 67.0

Bd Lime 331 0.06 50.0

Soda Ash 642 0.11 65.0

Borosilicate cullet 223 0.04 100

Plate Cullet 894 0.15 85.0

HERM Dust 40.0 0.01 20.0

Batch size 5,806

Batch information from J. Shock Sept 1, 2004 Preliminary PEP Batch House Capacity Increase

Production

Actual lb/hr 7,519 hr/yr 13,907

Potential 17,500 lb/hr 8,760 hr/yr

Actual Production Potential Production

104,566,733 lb/yr 153,300,000 lb/yr

Potential Gravity Loaded Volume (ft3

/yr)

Sand 323,182

Carbocite 1,173

Syenite 267,558

Internal Cullet 234,700

Borax 290,835

Bd Lime 174,793

Soda Ash 260,788

Borosilicate Cullet 58,880

Plate Cullet 277,705

HERM dust 52,807

Assume that the volume of air displaced is equal to the volume of material processed 

and the actual conditions of the displaced air are equal to dry standard conditions.

Controlled Outlet Grain Loading: 0.01 gr/dsft3

Uncontrolled Outlet Grain Loading: 0.10 gr/dsft3

Permitted Outlet Grain Loading: 0.03 gr/dsft3

Potential to Emit Permit Limit

(lb/yr) (lb/hr) (ton/yr) (lb/yr) (lb/hr) (ton/yr)

Sand 4.62 2.50E-03 2.31E-03 1.39 7.50E-04 6.93E-04

Carbocite 0.02 5.56E-03 8.38E-06 0.01 1.67E-03 2.51E-06

Syenite 3.82 2.78E-03 1.91E-03 1.15 8.33E-04 5.73E-04

Internal Cullet 3.35 2.78E-03 1.68E-03 1.01 8.33E-04 5.03E-04

Borax 4.15 3.73E-03 2.08E-03 1.25 1.12E-03 6.23E-04

Bd Li 2 50 5 00E 03 1 25E 03 0 75 1 50E 03 3 75E 04
Appendix A - Emission Calculations

T177-22598-00006

Title V Renewal

Page 7 of 15, TSD App A

Source: Batch Transfer System

Control Device: Baghouse exhausting indoors to general ventilation

Potential To Emit

Unit Run Time * 

(min/day)

Air Flow

(aft3

/min)

Controlled

 Grain Loading 

(gr/dsft3

)

Uncontrolled Grain 

Loading

(gr/dsft3)

Controlled 

Potential to Emit 

(lb/yr)

Controlled 

Potential to Emit 

(ton/yr)

Uncontrolled 

Potential to Emit

(ton/yr)

Batch Transfer 1,381 325 0.01 0.10 234 0.12 1.17

*Run time is based on the maximum capacity of the production lines.

Potential to Emit After Issuance

Unit Run Time * 

(min/day)

Air Flow

(aft3

/min)

Permitted Grain 

Loading (gr/dsft3)

Potential to Emit 

(lb/yr)

Permit Limit 

(ton/yr)

Batch Transfer 1,381 325 0.03 702 0.35

Methodology

Potential to Emit (ton/yr) = Run Time (min/day) * Air Flow (aft3

/min) * Grain Loading (gr/dsft3) * 365 days/1yr * 1 lb/7,000 gr * 1 ton/2,000 lbs

Assume that actual conditions of the air flow in the batch transfer system is equal to air flow at dry standard conditions.

The assumed baghouse control effiency is 90%.
Appendix A - Emission Calculations

T177-22598-00006

Title V Renewal

Page 8 of 15, TSD App A

Source: Weigh Scale

Control Device: Sock Filter exhausting indoors to general ventilation

Characteristics of a Typical Batch 

Batch Mass Mass Fraction Density

Component (lb) (%) (lb/ft3

)

Sand 1,224 0.18 100

Carbocite 2.00 2.98E-04 45.0

Syenite 912 0.14 90.0

Internal Cullet 800 0.12 90.0

Borax 738 0.11 67.0

Bd Lime 331 0.05 50.0

Soda Ash 642 0.10 65.0

Borosilicate cullet 223 0.03 100

Plate Cullet 894 0.13 85.0

Fluorspar 100 0.01 110

Bottle Cullet 800 0.12 95.0

HERM Dust 40.0 0.01 20.0

Batch size 6,706

Batch information from J. Shock Sept 1, 2004 Preliminary PEP Batch House Capacity Increase

Production

Actual lb/hr 7519 hr/yr 13,907

Potential 17,500 lb/hr 8760 hr/yr

Actual Production Potential Production

104,566,733 lb/yr 153,300,000 lb/yr

Potential Gravity Loaded Volume (ft3

/yr)

Sand 279808

Carbocite 1016

Syenite 231649

Internal Cullet 203201

Borax 251803

Bd Lime 151334

Soda Ash 225788

Borosilicate Cullet 50978

Plate Cullet 240435

Fluorspar 20782

Bottle Cullet 192506

HERM dust 45720

Assume that the volume of air displaced is equal to the volume of material processed

and the actual conditions of the displaced air are equal to dry standard conditions.

Controlled Outlet Grain Loading: 0.01 gr/dsft3

Uncontrolled Outlet Grain Loading: 0.10 gr/dsft3

Permitted Outlet Grain Loading: 0.03 gr/dsft3

Uncontrolled, Potential to Emit Permit Limit

(lb/yr) (ton/yr) (lb/yr) (ton/yr)

Sand 4.00 2.00E-03 1.20 6.00E-04

Carbocite 0.01 7.26E-06 0.00 2.18E-06

Syenite 3.31 1.65E-03 0.99 4.96E-04

Internal Cullet 2.90 1.45E-03 0.87 4.35E-04

Borax 3.60 1.80E-03 1.08 5.40E-04

Bd Lime 2.16 1.08E-03 0.65 3.24E-04

Soda Ash 3.23 1.61E-03 0.97 4.84E-04

Borosilicate Cullet 0 73 3 64E 04 0 22 1 09E 04
Appendix A - Emission Calculations

T177-22598-00006

Title V Renewal

Page 9 of 15, TSD App A

Source: Cold Top Electric Melter

Control Device: Baghouse exhausted to stack S166

Factors: PM10 VOC NOx CO SO2 HF

Safety Factor 10% 20% 100% 100% 100% 100%

Control Efficiency 99% 0% 0% 0% 0% 0%

Actual Emission Factors Controlled

Potential

PM10 : NA lb/lb of glass 2.83E-05

VOC : NA lb/lb of glass 6.31E-05

NOx : NA lb/lb of glass 2.17E-05

CO : NA lb/lb of glass 4.76E-05

SO2 : NA lb/lb of glass 9.16E-07

Fluoride: NA lb/lb of glass 3.67E-07

Potential To Emit

AVG. Actual Hours of Operation : 0.0 hr/yr

Actual Line Pull-Rate Average : 0.0 lb glass/hr

Permitted Hours : 8,760

Permitted Pull-Rate : 17,500 lb glass/hr After Line 2 and Line 3 Melt Furnace have been permanently shut down.

Assumed fusion loss : 15% 

Potential to Emit Line Feed-Rate: 20,125 lb glass/hr

Pollutant Permit Limit Permit Limit Uncontrolled

Potential to Emit

Uncontrolled 

Potential to Emit

(lb/hr) (ton/yr) (lb/hr) (ton/yr)

PM10 : 0.49 2.15 49.6 217 *

VOC : 1.10 4.82 1.10 4.84

NOx : - - 0.38 1.66

CO : 0.83 3.64 0.83 3.65

SO2 : - - 0.02 0.07

Single HAP : - - 0.01 0.03

* Single HAP is hydrogen fluoride (hydrofluoric acid).

Methodology

Potential to Emit (ton/yr) = Line Pull-Rate (lb glass/hr) * Potential Emission Factor (lb/lb of glass) * (1+Safety Factor) * 8,760 hrs/yr * 1 ton/2,000 lbs

Test results from a similar unit in Wertheim Germany were multiplied a safety factor to constitute a realistic upper bound for the potential emission factors.

* Uncontrolled PM10 emissions were calcuated from the controlled test results from Wertheim Germany and the available control effiency.

Based on August/ 

November 2002 test 

results from a similar 

unit in Wertheim 

Germany

No historical data, added as part of a 2006 

modification (SPM 177-22666-00006).
Appendix A - Emission Calculations

T177-22598-00006

Title V Renewal

Page 10 of 15, TSD App A

Source: Line 2 Climate Pro Collection Module 

Control Device: Fog box / wet spray collection system exhausted to stack S2

Factors: PM10 VOC NOx CO SO2

Safety Factor 20% 20% 20% 75% 10%

Assumed Current Control Efficiency 45% 10% 0% 0% 0%

Estimated Potential Control Efficiency 66% 20% 0% 0% 0%

Actual Emission Factors Controlled Potential

PM10 : 1.58E-03 lb/lb of glass 1.18E-03 Richmond Test Data -- 1/25/2001, EP Outlet, Compliance Method 5/202.

VOC : 8.26E-04 lb/lb of glass 8.81E-04 Waterville Test Data -- CBX Permit application based on Waterville data.

NOx : 4.85E-05 lb/lb of glass 5.81E-05 Richmond Test Data -- 1/25/2001, EP Outlet. Compliance.

CO : 1.02E-03 lb/lb of glass 1.79E-03 Waterville Test Data -- CBX Permit application.

SO2 : 1.14E-04 lb/lb of glass 1.26E-04 Defiance Test Data -- 1994 Defiance 2601 and 2603 on 753 Glass.

Potential To Emit

AVG. Actual Hours of Operation : 7,519 hr/yr Average for October 1, 2003 to September 30, 2005

Actual Line Pull-Rate Average : 6,228 lb glass/hr Average for October 1, 2003 to September 30, 2005

Max Potential Hours : 8,760 hr/yr Max Potential

Max Line Pull-Rate : 8,750 lb glass/hr Rated Capacity

Pollutant Permit Limit Permit Limit Potential to Emit * Potential to Emit * Uncontrolled 

Potential to Emit **

Uncontrolled, 

Potential to Emit **

(lb/hr) (ton/yr) (lb/hr) (ton/yr) (lb/hr) (ton/yr)

PM10 : 10.3 58.3 10.3 45.0 30.3 132

VOC : 6.78 29.7 7.71 33.8 9.63 42.2

NOx : 4.53 19.8 0.51 2.23 0.51 2.23

CO : 15.6 68.3 15.7 68.7 15.7 68.7

SO2 : - - 1.10 4.82 1.10 4.82

* Potential to emit includes the estimated potential control efficiency and margin of safety.

** Uncontrolled potential to emit removes the assumed control efficiency where the test data was collected and adds a safety factor to constitute a realistic upper bound.

Methodology

Controlled Potential Emission Factor (lb/lb of glass) =(Actual Emission Factor/(1-Assumed Current Control Efficiency))

*(1-Estimated Potential Control Efficiency)*(1+Safety Factor)

Potential to Emit (lbs/hr) = Max Line Pull-Rate (lb glass/hr) * Controlled Potential Emission Factor (lb/lb of glass)

Potential to Emit (ton/yr) = Potential to Emit (lbs/hr) * Max Potential Hours (hr/yr) * 1 ton/2,000 lbs

Uncontrolled, Potential to Emit (lbs/hr) = Max Line Pull-Rate (lb glass/hr) * (Actual Emission Factor/(1-Assumed Current Control Efficiency)) * (1+Safety Factor)

Uncontrolled, Potential to Emit (ton/yr) = Uncontrolled, Potential to Emit (lbs/hr) * Max Potential Hours (hr/yr) * 1 ton/2,000 lbs

Test results from a similar units were adjusted to account for control devices and multiplied by a safty factor to constitute a realistic upper bound for the potential emission 

factors.
Appendix A - Emission Calculations

T177-22598-00006

Title V Renewal

Page 11 of 15, TSD App A

Source: Line 3 Blowing Wool Collection Module

Control Device: Fog box / wet spray collection system exhausted to stack S3

Factors: PM10 VOC NOx CO SO2

Safety Factor 20% 20% 20% 75% 10%

Assumed Current Control Efficiency 45% 10% 0% 0% 0%

Estimated Potential Control Efficiency 66% 20% 0% 0% 0%

Actual Emission Factors Controlled 

Potential

PM10 : 1.58E-03 lb/lb of glass 1.18E-03 Richmond Test Data -- 1/25/2001, EP Outlet, Compliance Method 5/202.

VOC : 8.26E-04 lb/lb of glass 8.81E-04 Waterville Test Data -- CBX Permit application based on Waterville data.

NOx : 4.85E-05 lb/lb of glass 5.81E-05 Richmond Test Data -- 1/25/2001, EP Outlet. Compliance.

CO : 1.02E-03 lb/lb of glass 1.79E-03 Waterville Test Data -- CBX Permit application.

SO2 : 1.14E-04 lb/lb of glass 1.26E-04 Defiance Test Data -- 1994 Defiance 2601 and 2603 on 753 Glass.

Potential To Emit

AVG. Actual Hours of Operation : 7,100 hr/yr Average for October 1, 2003 to September 30, 2005

Actual Line Pull-Rate Average : 6,375 lb glass/hr Average for October 1, 2003 to September 30, 2005

Max Potential Hours : 8,760 hr/yr Max Potential

Max Line Pull-Rate : 8,750 lb glass/hr Rated Capacity

Pollutant Permit Limit Permit Limit Potential to Emit * Potential to Emit * Uncontrolled 

Potential to Emit **

Uncontrolled, 

Potential to Emit **

(lb/hr) (ton/yr) (lb/hr) (ton/yr) (lb/hr) (ton/yr)

PM10 : 10.3 124 10.3 45.0 30.3 132

VOC : 6.78 29.7 7.71 33.8 9.63 42.2

NOx : 4.53 19.8 0.51 2.23 0.51 2.23

CO : 15.6 68.3 15.7 68.7 15.7 68.7

SO2 : - - 1.10 4.82 1.10 4.82

* Potential to emit includes the estimated potential control efficiency and margin of safety.

** Uncontrolled potential to emit removes the assumed control efficiency where the test data was collected and adds a safety factor to constitute a realistic upper bound.

Methodology

Controlled Potential Emission Factor (lb/lb of glass) =(Actual Emission Factor/(1-Assumed Current Control Efficiency))

*(1-Estimated Potential Control Efficiency)*(1+Safety Factor)

Potential to Emit (lbs/hr) = Max Line Pull-Rate (lb glass/hr) * Controlled Potential Emission Factor (lb/lb of glass)

Potential to Emit (ton/yr) = Potential to Emit (lbs/hr) * Max Potential Hours (hr/yr) * 1 ton/2,000 lbs

Uncontrolled, Potential to Emit (lbs/hr) = Max Line Pull-Rate (lb glass/hr) * (Actual Emission Factor/(1-Assumed Current Control Efficiency)) * (1+Safety Factor)

Uncontrolled, Potential to Emit (ton/yr) = Uncontrolled, Potential to Emit (lbs/hr) * Max Potential Hours (hr/yr) * 1 ton/2,000 lbs

Test results from a similar units were adjusted to account for control devices and multiplied by a safty factor to constitute a realistic upper bound for the potential emission 

factors.
Appendix A - Emission Calculations

T177-22598-00006

Title V Renewal

Page 12 of 15, TSD App A

Source: Line 2 Shredding and Packaging

Control Device: Two baghouses in parallel exhausted to stacks S85, S86 and S87

Factors: PM10

Safety Factor 20%

Control Efficiency 99%

Actual Emission Factors Controlled Potential

PM10 : 8.60E-05 lb/lb of glass 1.032E-04 Based on grain loading

Potential To Emit

Line 2 Actual Hours of Operation : 7,519 hr/yr Average for October 1, 2003 to September 30, 2005

Glass Pull : 6,228 lb/hr Average for October 1, 2003 to September 30, 2005

Max Potential Hours : 8,760 hr/yr Max Potential

Max Line Pull-Rate : 8,750 lb/hr Rated Capacity

Pollutant Permit Limit Permit Limit Potential to Emit * Potential to Emit * Uncontrolled 

Potential to Emit **

Uncontrolled, 

Potential to Emit **

(lb/hr) (ton/yr) (lb/hr) (ton/yr) (lb/hr) (ton/yr)

PM10 : 1.86 8.15 0.90 3.96 90.4 396

* Potential to emit use the controlled potential emission factor.

** Uncontrolled potential to emit removes the control efficiency and adds a safety factor to constitute a realistic upper bound.

Methodology

Controlled potential was documented in the appendix of SSM 177-22008-00006.

Potential to Emit (lbs/hr) = Max Line Pull-Rate (lb glass/hr) * Controlled Potential Emission Factor (lb/lb of glass)

Potential to Emit (ton/yr) = Potential to Emit (lbs/hr) * Max Potential Hours (hr/yr) * 1 ton/2,000 lbs

Uncontrolled, Potential to Emit (lbs/hr) = Max Line Pull-Rate (lb glass/hr) * (Actual Emission Factor/(1-Control Efficiency)) * (1+Safety Factor)

Uncontrolled, Potential to Emit (ton/yr) = Uncontrolled, Potential to Emit (lbs/hr) * Max Potential Hours (hr/yr) * 1 ton/2,000 lbs
Appendix A - Emission Calculations

T177-22598-00006

Title V Renewal

Page 13 of 15, TSD App A

Source: Line 3 Shredding and Packaging

Control Device: Two baghouses in parallel exhausted to stacks S12, S13 and S14

Factors: PM10

Safety Factor 20%

Control Efficiency 99%

Actual Emission Factors Controlled 

Potential

PM10 : 8.60E-05 lb/lb of glass 1.032E-04 Based on grain loading

Potential To Emit

Line 2 Actual Hours of Operation : 7,100 hr/yr Average for October 1, 2003 to September 30, 2005

Glass Pull : 6,375 lb/hr Average for October 1, 2003 to September 30, 2005

Max Potential Hours : 8,760 hr/yr Max Potential

Max Line Pull-Rate : 8,750 hr/yr Rated Capacity

Pollutant Permit Limit Permit Limit Potential to Emit * Potential to Emit * Uncontrolled 

Potential to Emit **

Uncontrolled, 

Potential to Emit **

(lb/hr) (ton/yr) (lb/hr) (ton/yr) (lb/hr) (ton/yr)

PM10 : 3.09 13.5 0.90 3.96 90.4 396

* Potential to emit use the controlled potential emission factor.

** Uncontrolled potential to emit removes the control efficiency and adds a safety factor to constitute a realistic upper bound.

Methodology

Controlled potential was documented in the appendix of SSM 177-22008-00006.

Potential to Emit (lbs/hr) = Max Line Pull-Rate (lb glass/hr) * Controlled Potential Emission Factor (lb/lb of glass)

Potential to Emit (ton/yr) = Potential to Emit (lbs/hr) * Max Potential Hours (hr/yr) * 1 ton/2,000 lbs

Uncontrolled, Potential to Emit (lbs/hr) = Max Line Pull-Rate (lb glass/hr) * (Actual Emission Factor/(1-Control Efficiency)) * (1+Safety Factor)

Uncontrolled, Potential to Emit (ton/yr) = Uncontrolled, Potential to Emit (lbs/hr) * Max Potential Hours (hr/yr) * 1 ton/2,000 lbs
Appendix A - Emission Calculations

T177-22598-00006

Title V Renewal

Page 14 of 15, TSD App A

Source: Melter Dust Recycle System exhausted to stack S34

Control Device: Uncontrolled

Component Batch Mass Dust Mass Fraction Dust Density 

(lb) (%) (lb/ft3

)

Melter Recycle Dust 40.0 5.96E-03 25.0

Batch size 6,706

Based on historic recycle rates, the recycle mass was computed assuming a recycle rate of 0.596% of the total mass charged

Batch information from J. Shock Sept 1, 2004 Preliminary PEP Batch House Capacity Increase

Total Production

Actual lb/hr 7,519 hr/yr 13,907

Potential 17,500 lb/hr 8,760 hr/yr

Actual Production Potential Production

104,566,733 lb/yr 153,300,000 lb/yr

Potential Gravity Loaded Volume (ft3

/yr)

Melter Recycle Dust 36,576 ft3

/yr

Actual Outlet Grain Loading: 0.01 gr/dsft3

Uncontrolled Outlet Grain Loading: 0.10 gr/dsft3

Limited Outlet Grain Loading: * 0.03 gr/dsft3

Assume that the volume of air displaced is equal to the volume of material processed

and the actual conditions of the displaced air are equal to dry standard conditions.

PM/PM10 * PM/PM10 NOx SO2 PM/PM10 PM/PM10 PM/PM10

(lb/hr) (ton/yr) (ton/yr) (ton/yr) (lb/hr) (lb/yr) (ton/yr)

Melter Recycle Dust 0.19 0.83 0 0 5.96E-05 0.52 2.61E-04

METHODOLOGY

Potential Production (lb/yr) = Potential Production (lb/hr) * 8,760 hrs/yr

Melter Recycle Dust, Gravity Loaded Volume (ft3

/yr) = Potential Production (lb/yr) * Dust Mass Fraction (%) * Dust Density (lbs/ft3)

Potential to Emit (lb/yr) = Melter Recycle Dust, Gravity Loaded Volume (ft3

/yr) * Outlet Grain Loading (gr/dsft3) * 1 lb/7,000 gr

Potential to Emit (ton/yr) = Potential to Emit (lb/yr) * 1 ton/2,000 lbs

* Pursuant to 326 IAC 6.5-1-2(a)

** Pursuant to CP 177-5873-00006, issued April 22, 1999, and 326 IAC 2-2-3(a)(3)

Permit Limit Uncontrolled, Potential to Emit 
Appendix A - Emission Calculations

T177-22598-00006

Title V Renewal

Page 15 of 15, TSD App A

Source: Natural Gas-fired Boiler

Description: Natural Gas Combustion, MM BTU/HR <100

Heat Input Capacity Potential Throughput

MMBtu/hr MMSCF/yr

25.0 215

Pollutant

 PM* PM10* SO2 NOx** VOC CO

Emission Factor (lb/MMSCF) 1.90 7.60 0.60 100 5.50 84.0

Potential to Emit (tons/yr) 0.20 0.82 0.06 10.7 0.59 9.02

PM* PM10*

Permit Limit (lb/hr) *** 0.34 0.34

Permit Limit (tons/yr) 1.49 1.49

*PM emission factor is filterable PM only. PM10 emission factor is filterable and condensable PM combined.

**Emission factor for NOx (Uncontrolled) = 100 lb/MMSCF

*** Emission Limits pursuant to 326 IAC 6.5-10-11.

Emission factors are from AP-42, Chapter 1.4, Tables 1.4-1, 1.4-2, 1.4-3, SCC #1-02-006-02, 1-01-006-02, 1-03-006-02, and 1-03-006-03 (July 1998).

All emission factors are based on normal firing.

HAPs - Organics

 Benzene Dichlorobenzene Formaldehyde Hexane Toluene

Emission Factor (lb/MMSCF) 2.10E-03 1.20E-03 7.50E-02 1.80E+00 3.40E-03

Potential to Emit (tons/yr) 2.25E-04 1.29E-04 8.05E-03 1.93E-01 3.65E-04

HAPs - Metals

 Lead Cadmium Chromium Manganese Nickel

Emission Factor (lb/MMSCF) 5.00E-04 1.10E-03 1.40E-03 3.80E-04 2.10E-03

Potential to Emit (tons/yr) 5.37E-05 1.18E-04 1.50E-04 4.08E-05 2.25E-04

The five highest organic and metal HAPs emission factors provided above are from AP-42, Chapter 1.4, Table 1.4-2, 1.4-3 and 1.4-4 (July, 1998).

Additional HAPs emission factors are available in AP-42, Chapter 1.4.

METHODOLOGY

Potential Throughput (MMSCF/yr) = Heat Input Capacity (MMBtu/hr) x 8,760 hrs/yr x 1 MMSCF/1,020 MMBtu

Potential to Emit (tons/yr) = Potential Throughput (MMSCF/yr) x Emission Factor (lb/MMSCF) x 1 ton/2,000 lbs