## I NDIANA 

## D EPARTMENT OF 

## E NVIRONMENTAL 

## M ANAGEMENT

We Protect Hoosiers and Our Environment.

Mitchell E. Daniels Jr. 100 North Senate Avenue

Governor Indianapolis, Indiana 46204 (317) 232-8603
Thomas W. Easterly Toll Free (800) 451-6027

Commissioner www.idem.IN.gov

Page 1 of 2

FNTVOP.dot 03/23/06

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

DATE: June 21, 2011

RE: Brickcraft, LLC / 021 - 23323 - 00054

FROM: Matthew Stuckey, Branch Chief

Permits Branch Office of Air Quality



## Notice of Decision: Approval – Effective Immediately

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

If you wish to challenge this decision, IC 4-21.5-3-7 an d IC 13-15-6-1(b) or IC 13-15-6-1(a) require that you file a petition for administrative review. This pe tition may include a request for stay of effectiveness and must be submitted to the Office of Environmental Adjudication, 100 North Senate Avenue, Government Center North, Suite N 501E, Indianapolis, IN 46204.

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

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

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

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

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

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

U.S. Environmental Protection Agency

401 M Street Washington, D.C. 20406

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

Enclosures

FNTVOP.dot12/3/07Brickcraft, LLC Page 2 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney



### TABLE OF CONTENTS

A. SOURCE SUMMARY

A.1 General Information [326 IAC 2-7-4(c)] [326 IAC 2-7-5(15)] [326 IAC 2-7-1(22)]

A.2 Emission Units and Pollution Control Equipment Summary [326 IAC 2-7-4(c)(3)] [326 IAC 2-7-5(15)]

A.3 Specifically Regulated Insignificant Activi ties [326 IAC 2-7-1(21)] [326 IAC 2-7-4(c)] [326 IAC 2-7-5(15)]

A.4 Part 70 Permit Applicability [326 IAC 2-7-2]

B. GENERAL CONDITIONS

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

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

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

B.4 Enforceability [326 IAC 2-7-7] [IC 13-17-12]

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 Informat ion [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 Permit Modification, Reopening, Revocation and Reissuance, or Termination [326 IAC 2-7-5(6)(C)] [326 IAC 2-7-8(a)] [326 IAC 2-7-9]

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

B.17 Permit Amendment or Modification [326 IAC 2-7-11] [326 IAC 2-7-12]

B.18 Permit Revision Under Economic Incentives and Other Programs [326 IAC 2-7-5(8)] [326 IAC 2-7-12(b)(2)]

B.19 Operational Flexibility [326 IA C 2-7-20] [326 IAC 2-7-10.5]

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

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

B.22 Transfer of Ownership or Oper ational Control [326 IAC 2-7-11]

B.23 Annual Fee Payment [326 IAC 2-7-19] [326 IAC 2-7-5(7)] [326 IAC 2-1.1-7]

B.24 Credible Evidence [326 IAC 2-7-5(3)] [326 IAC 2-7-6] [62 FR 8314] [326 IAC 1-1-6]

C. SOURCE OPERATION CONDITIONS

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

C.1 Particulate Emission Limitations For Pr ocesses with Process Weight Rates Less Than One Hundred (100) Pounds per Hour [326 IAC 6-3-2]

C.2 Opacity [326 IAC 5-1]

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

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

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

C.6 Stack Height [326 IAC 1-7]

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

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

C.8 Performance Testing [326 IAC 3-6]Brickcraft, LLC Page 3 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney

Compliance Requirements [326 IAC 2-1.1-11]

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

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

C.10 Compliance Monitoring [326 IAC 2-7-5(3)] [326 IAC 2-7-6(1)]

C.11 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 Exceedan ces [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 Requiremen ts [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]

C.17 General Record Keeping Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-6]

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

Stratospheric Ozone Protection

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

D.1 EMISSIONS UNIT OPERATION CONDITIONS

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

D.1.1 Fugitive Particulate Matter Emission Limitations [326 IAC 6-5]

D.2 EMISSIONS UNIT OPERATION CONDITIONS

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

D.2.1 Particulate [326 IAC 6-3-2]

D.2.2 Preventive Maintenance Plan [326 IAC 2-7-5(13)]

D.3 EMISSIONS UNIT OPERATION CONDITIONS

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

D.3.1 PSD Minor Limits [326 IAC 2-2]

D.3.2 HAP Minor Limits [326 IAC 2-4.1]

D.3.3 Particulate [326 IAC 6-3-2]

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

Compliance Determination Requirements

D.3.5 Emissions Control [326 IAC 2-7-6(6)]

D.3.6 Testing Requirements [326 IAC 2- 7-6(1),(6)] [326 IAC 2-1.1-11] D.3.7 Sulfur Dioxide (SO 2 ) D.3.8 Hydrogen Fluoride/Hy drofluoric Acid (HF)

D.3.9 Sulfur Content

D.3.10 Continuous Emission Monitoring [326 IAC 3-5] [326 IAC 2-7-6(1), (6)] [326 IAC 2-1.1-11] [326 IAC 2-7-5(3)(A)(iii)] [40 CFR 64]Brickcraft, LLC Page 4 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney

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

D.3.11 SO 2 and HF Monitor Downtime [326 IAC 2-7-6] [326 IAC 2-7-5(1)]

D.3.12 Visible Emissions Notations

D.3.13 Baghouse Parametric Monitoring

D.3.14 SO 2 Compliance Assurance Monitoring [40 CFR 64] D.3.15 HF Compliance Monitoring

D.3.16 Broken or Failed Bag Detection

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

D.3.17 Record Keeping Requirements

D.3.18 Reporting Requirements

E.1 FACILITY OPERATION CONDITIONS

E.1.1 General Provisions Relating to New Source Performance Standards [326 IAC 12-1] [40 CFR 60, Subpart A]

E.1.2 Standards of Performance for Nonmetallic Mi neral Processing Plants [40 CFR Part 60, Subpart OOO]

Certification Emergency Occurrence Report Quarterly Reports Quarterly Deviation and Compliance Monitoring Report

Attachment A - Fugitive Dust Control Plan

Attachment B - New Source Performance Standard s for Nonmetallic Mineral Processing PlantsBrickcraft, LLC Page 5 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney

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 informat ion describing the source contained in conditions A.1 through A.3 is descriptive information and does not constitute enforceable conditions. However, the Permittee should be aware that a physical change or a change in the method of operation that may render this descriptive information obsolete or inac curate 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 brick manufacturing plant.

Source Address: 200 North SR 59, Center Point, Indiana 47840 General Source Phone Number: (812) 835-2502

SIC Code: 3251 County Location: Clay

Source Location Status: Attainm ent for all criteria pollutants Source Status: Part 70 Operating Permit Program Minor Source, under PSD Rules Minor Source, under Section 112 of the Clean Air Act Not 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 follo wing emission units and pollution control devices:

(a) One (1) quarry, constructed in 2004, with a capacity of 125 tons of shale per hour;

(b) Three (3) outdoor aggregate storage piles, with a combined capacity of 125 tons of shale per hour.

(c) One (1) pre-kiln clay/shale/fireclay/sand processing operation, identified as EU-02, installed in 2004, with a maximum capacity of 125 tons of raw material (including clay, fireclay, shale, and sand) per hour, consisting of the following equipment:

(1) One (1) primary crusher, with a maximum capacity of 125 tons of raw material per hour, using baghouse BH-1 as partic ulate control, exhausting internally. Under NSPS Subpart OOO, this is an affe cted facility enclosed in a building;

(2) One (1) transfer conveyor, with a maximum capacity of 125 tons of raw material per hour, using a hood venting to baghouse BH-1 as particulate control, exhausting internally. Under NSPS Sub part OOO, this is an affected facility enclosed in a building;

(3) One (1) grinding and scalping screen oper ation, with a maximum capacity of 125 tons of raw material per hour, using a hood venting to baghouse BH-1 as particulate control, exhaust ing internally. Under NSPS Subpart OOO, this is an affected facility enclosed in a building;

(4) One (1) coarse material return conveyor , with a maximum capacity of 125 tons of raw material per hour, using a hood venting to baghouse BH-1 as particulate control, exhausting intern ally. Under NSPS Subpart OOO, this is an affected facility enclosed in a building;Brickcraft, LLC Page 6 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney

(5) One (1) transfer conveyor, with a maximum capacity of 125 tons of raw material per hour, using a hood venting to baghouse BH-1 as particulate control, exhausting internally. Under NSPS Sub part OOO, this is an affected facility enclosed in a building;

(6) One (1) secondary crusher, with a maximum capacity of 110 tons of raw material per hour, using a hood venting to baghouse BH-1 as particulate control, exhausting internally. Under NSPS Sub part OOO, this is an affected facility enclosed in a building;

(7) One (1) transfer conveyor, with a maximum capacity of 110 tons of raw material per hour, using a hood venting to baghouse BH-1 as particulate control, exhausting internally. Under NSPS Sub part OOO, this is an affected facility enclosed in a building;

(8) One (1) finishing screen operation, with a maximum capacity of 70 tons of raw material per hour, using a hood venting to baghouse BH-1 as particulate control, exhausting internally. Under NSPS Sub part OOO, this is an affected facility enclosed in a building;

(9) One (1) coarse material return conveyor , with a maximum capacity of 70 tons of raw material per hour, using a hood venting to baghouse BH-1 as particulate control, exhausting intern ally. Under NSPS Subpart OOO, this is an affected facility enclosed in a building;

(10) Two (2) transfer conveyors, each wi th a maximum capacity of 70 tons of raw material per hour, each using a hood venting to baghouse BH-1 as particulate control, exhausting inte rnally. Under NSPS Subpar t OOO, these are affected facilities enclosed in a building;

(11) Six (6) crushed material storage bins, each having a capacity of 100 tons, each using a hood venting to baghouse BH-1 as particulate control, exhausting internally. Under NSPS Subpart OOO, thes e are affected facilities enclosed in a building;

(12) Two (2) transfer conveyors, each wi th a maximum capacity of 60 tons of raw material per hour, each using a hood venting to baghouse BH-1 as particulate control, exhausting internally;

(13) One (1) enclosed mixi ng pugmill, with a maximum capacity of 60 tons per hour, using baghouse BH-2 as particulate control, exhausting internally;

(14) One (1) transfer conveyor, with a maxi mum capacity of 60 tons of milled material per hour, using a hood venting to baghouse BH-1 as particulate control, exhausting internally; and

(15) One (1) extrusion operation, with a maximum capacity of 60 tons of milled material per hour, with emissions uncontrolled.

(d) One (1) brick manufacturing line, identified as EU-01, installed in 2004, with a maximum capacity of 10 tons of bricks per hour, consisting of:

(1) One (1) brick dryer, with a maximum capacity of 10 tons of bricks per hour, using recycled hot air from the gas-fired kiln, exhausting through stacks D-1 and CZ-1;Brickcraft, LLC Page 7 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney

(2) One (1) natural gas-fired tunnel kiln, ra ted at 56 million British thermal units per hour, with a maximum capacity of 10 tons of bricks per hour, using a dry injection fabric filter (DIFF) as a control devic e for both hydrogen fluoride and sulfur dioxide, exhausting through stacks POC-1 and UCC-1;

(3) One (1) lime storage silo, identified as Lime Silo, constructed in 2009, permitted in 2011, with a maximum capacity of 50 tons and a maximum throughput of 25 tons per hour, exhausting to the dry in jection fabric filter (DIFF); and

(4) One (1) sodium bicarbonate storage silo, identified as Bicarb Silo, constructed in 2004, permitted in 2011, with a maximum capacity of 50 tons and a maximum throughput of 25 tons per hour, exhausting to the dry injection fabric filter (DIFF).

(e) One (1) outdoor spent injection material st orage pile, with a capacity of 185 pounds of lime/sodium bicarbonate mixture per hour.

A.3 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 fo llowing insignificant activities, as defined in 326 IAC 2-7-1(21):

(a) Natural gas-fired combustion sources with heat input equal to or less than ten million (10,000,000) British thermal units per hour:

Three (3) torpedo heaters, with no unit identific ation, each with a heat input capacity of 1.70 MMBtu per hour.

(b) Combustion source flame safety purging on start-up.

(c) Petroleum fuel (other than gasoline) dispen sing facilities, having st orage capacity of less than or equal to 10,500 gallons and dispensing less than or equal to 230,000 gallons per

month:

(1) One (1) storage tank, constructed in 2004, identified as Main, for storage of diesel fuel, with a maximum volume of 1,000 gallons; and

(2) One (1) storage tank, constructed in 20 04, identified as Quarry, for storage of diesel fuel, with a maximum volume of 2,000 gallons.

(d) VOC and HAP storage tanks with capacity less than or equal to 1,000 gallons and annual throughputs less than 12,000 gallons.

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

(f) Replacement or repair of electrostatic prec ipitators, bags in baghouses, and filters in other air filtration equipment.

(g) Paved and unpaved roads. [ 326 IAC 6-4] [326 IAC 6-5]

(h) A laboratory as defined in 326 IAC 2-7-1(20)(C).Brickcraft, LLC Page 8 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney

(i) Activities with potential emissions within any of the following thresholds: equal to or less than 5 pounds per hour or 25 pounds per day PM 10 , SO 2 , or NO

x ; equal to or less than 3 pounds per hour or 15 pounds per day VOC; equal to or less than 25 pounds per day CO; equal to or less than 0.6 tons per year or 3.29 pounds per day Pb; or greater than 1 pound per day but less than 5 pounds per day or 1 ton per year single HAP (and not regulated by a NESHAP):

(1) One (1) additive feeder, with a maximum capacity of six (6) tons per hour, using baghouse BH-1 as particulate control, exhausting internally;

(2) One (1) enclosed surge bin, with a maximum capacity of 20 tons, using baghouse BH-1 as particulate control, exhausting internally;

(3) One (1) texture feeder, with a maximu m capacity of 0.25 tons per hour, using baghouse BH-2 as particulate control, exhausting internally; and

(4) One (1) packaging area, with a maximum capacity of 38 tons per hour, using baghouse BH-2 as particulate control, exhausting internally.

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 de signated by the United States Environmental Protection Agency (U.S. EPA) under 40 CFR 70.3 (Part 70 - Applicability).Brickcraft, LLC Page 9 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney

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, T021-23323-00054, is issued for a fixed term of five (5) years from the issuance date of this permit, as determi ned 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 pl an 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 conditi on pertains permanently ceases operation.

B.4 Enforceability [326 IAC 2-7-7] [IC 13-17-12]

Unless otherwise stated, all terms and conditions in this permit, including any provisions designed to limit the source's potential to emit, are enfor ceable 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 ri ghts of any sort or any exclusive privilege.

B.7 Duty to Provide Inform ation [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 determ ine whether cause exists for modifying, revoking and reissuing, or terminating this permit, or to determine compliance with this permit. 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.Brickcraft, LLC Page 10 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney

B.8 Certification [326 IAC 2-7-4(f)] [326 IAC 2-7-6(1)] [326 IAC 2-7-5(3)(C)]
(a) A certification required by this permit me ets the requirements of 326 IAC 2-7-6(1) if:

(1) it contains a certification by a "responsible official" as defined by 326 IAC 2-7-1(34), and

(2) the certification states that, based on information and belief formed after reasonable inquiry, the statements and in formation in the document are true, accurate, and complete.

(b) The Permittee may use the attached Certification Form, or its equivalent with each submittal requiring certification. One (1) cert ification may cover multiple forms in one (1)

submittal.

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

B.9 Annual Compliance Certif ication [326 IAC 2-7-6(5)]
(a) The Permittee shall annually submit a co mpliance certification report which addresses the status of the source’s compliance with the terms and conditions contained in this permit, including emission limitations, sta ndards, or work practices. The initial certification shall cover the time period fr om the date of final permit issuance through December 31 of the same year. All subsequent certifications shall cover the time period from January 1 to December 31 of the previo us year, and shall be submitted no later than July 1 of each year to:

Indiana Department of Environmental Management Compliance and Enforcement Branch, Office of Air Quality

100 North Senate Avenue

MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251

and

United States Environmental Protection Agency, Region V Air and Radiation Division, Air Enforcement Branch - Indiana (AE-17J)

77 West Jackson Boulevard Chicago, Illinois 60604-3590

(b) The annual compliance certification report re quired 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 co mpliance status of the source, currently and over the reporting period consistent with 326 IAC 2-7-5(3); andBrickcraft, LLC Page 11 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney

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

The submittal by the Permittee does require a certification that meet s the requirements of 326 IAC 2-7-6(1) by a "responsible offici al" 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 Secti on D of this permit, the Permittee shall prepare and maintain Preventive Maintenance Plans (PMPs) no later than ninety (90) days after issuance of this permit or ninety (90) days after initial start-up, whichever is later, including the following information on each facility:

(1) Identification of the individual(s) res ponsible 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 quantific ation of the replacement pa rts that will be maintained in inventory for quick replacement.

If, due to circumstances beyond the Permittee’s control, the PMPs cannot be prepared

and maintained within the above time fram e, the Permittee may extend the date an additional ninety (90) days provided the Permittee notifies:

Indiana Department of Environmental Management Compliance and Enforcement Branch, Office of Air Quality

100 North Senate Avenue

MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251

The PMP extension notification does not r equire a certification that meets the requirements of 326 IAC 2-7-6(1) by a "responsible official" as defined by 326 IAC 2-7-1(34).

The Permittee shall implement the PMPs.

(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 ex ceedance of any limitation on emissions. The PMPs and their submittal do not require a cert ification that meets the requirements of 326 IAC 2-7-6(1) by a "responsible offici al" as defined by 326 IAC 2-7-1(34).

(c) To the extent the Permittee is requi red 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.Brickcraft, LLC Page 12 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney

(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 rele vant evidence that describe the following:

(1) An emergency occurred and the Permitt ee 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 ex ceeded 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 and Enforcement Branch), or Telephone Number: 317-233-0178 (ask for Office of Air Quality, Compliance and Enforcement Branch)

Facsimile Number: 317-233-6865

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

facsimile to:

Indiana Department of Environmental Management Compliance and Enforcement Branch, Office of Air Quality

100 North Senate Avenue

MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251

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

The notice fulfills the requirement of 326 IA C 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 a certification that meets the requirements of 326 IAC 2-7-6(1) by a "responsible official" as defined by 326 IAC 2-7-1(34).

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

(c) In any enforcement proceeding, the Permitt ee seeking to establish the occurrence of an emergency has the burden of proof.Brickcraft, LLC Page 13 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney

(d) This emergency provision supersedes 326 IA C 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 oc currence 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 Pl ans 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 affect ed emitting facilities during the emergency provided the Permittee immediately takes a ll reasonable steps to correct the emergency

and minimize emissions.

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 in cluded and specifically identified in this permit or the permit contains an explicit determination or concise summary of a determination that other specifically iden tified 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 fo r 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 deter mined 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 per mit 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 permi t term or condition that is determined after issuance of this permit to have been bas ed on erroneous information supplied in the permit application. Erroneous information m eans information that the Permittee knew to be false, or in the exercise of reasonable ca re 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 pe rmit shall alter or affect the following:

(1) The provisions of Section 303 of the Cl ean Air Act (emergency orders), including the authority of the U.S. EPA under Section 303 of the Clean Air Act;Brickcraft, LLC Page 14 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney

(2) The liability of the Permittee for any vi olation 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 inform ation 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 Ac t 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 modifi cations. [326 IAC 2-7-12(c)(7)]

(g) This permit shield is not applicable to minor Part 70 permit modifi cations until after IDEM, OAQ, has issued the modifica tion. [326 IAC 2-7-12(b)(8)]

B.13 Prior Permits Superseded [326 IA C 2-1.1-9.5] [326 IAC 2-7-10.5]
(a) All terms and conditions of permits established prior to T021-23323-00054 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 accu rately reflected in this combined permit, all previous registrations and permits are superseded by this combined new source review and 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 term inates with the expiration of this permit unless a timely and complete renewal application is submitt ed at least nine (9) months prior to the date of expiration of the source’s existing permit, cons istent with 326 IAC 2-7-3 and 326 IAC 2-7-4(a).

B.15 Permit Modification, Reopening, Revocation and Reissuance, or Termination [326 IAC 2-7-5(6)(C)] [326 IA C 2-7-8(a)] [326 IAC 2-7-9]
(a) This permit may be modified, reopened, revok ed and reissued, or terminated for cause. The filing of a request by the Permittee fo r a Part 70 Operating Permit modification,
revocation and reissuance, or termination, or of a notification of planned changes or anticipated noncompliance does not st ay any condition of this permit. [326 IAC 2-7-5(6)(C)] The notification by t he Permittee does require a certification that meets the requirements of 326 IAC 2-7-6(1) by a "responsi ble 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.Brickcraft, LLC Page 15 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney

(2) That inaccurate statements were made in establishing the emissions standards

or other terms or conditions.

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

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

B.16 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 triv ial or insignificant activities list contained in 326 IAC 2-7-1(21) and 326 IAC 2-7-1(40). The renewal application does require a

certification that meets the r equirements of 326 IAC 2-7-6(1) by a "responsible official" as defined by 326 IAC 2-7-1(34).

Request for renewal shall be submitted to:

Indiana Department of Environmental Management Permit Administration and Support Section, Office of Air Quality

100 North Senate Avenue

MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251

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

(1) Submitted at least nine (9) months prio r 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 cons idered 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 determinati on, the Permittee fails to submit by the deadline specified, pursuant to 326 IAC 2-7-4( a)(2)(D), in writing by IDEM, OAQ any additional information identified as being needed to process the application.

B.17 Permit Amendment or Modification [326 IAC 2-7-11] [326 IAC 2-7-12]
(a) Permit amendments and modification s 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.Brickcraft, LLC Page 16 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney

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

submitted to:

Indiana Department of Environmental Management Permit Administration and Support Section, Office of Air Quality

100 North Senate Avenue

MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251

Any such application does require a cert ification that meets the requirements of 326 IAC 2-7-6(1) by a "responsible offici al" as defined by 326 IAC 2-7-1(34).

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

B.18 Permit Revision Under Economic Incentives and Other Programs [326 IAC 2-7-5(8)] [326 IAC 2-7-12(b)(2)]
(a) No Part 70 permit revision or notice shall be required under any approved economic incentives, marketable Part 70 permits, emissi ons 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), mi nor 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 Stat e Implementation Plan (SIP) or in applicable requirements promulgated or approved by the U.S. EPA.

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

conditions is met:

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

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

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

(4) The Permittee notifies the:

Indiana Department of Environmental Management Permit Administration and Support Section, Office of Air Quality

100 North Senate Avenue

MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251

andBrickcraft, LLC Page 17 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney

United States Environmental Protection Agency, Region V Air and Radiation Division, Regulation De velopment Branch - Indiana (AR-18J)

77 West Jackson Boulevard Chicago, Illinois 60604-3590

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

(5) The Permittee maintains records on-site, 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 Permi ttee 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 not ification by the Permittee does not require a

certification that meets the r equirements of 326 IAC 2-7-6(1) by a "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 co nditions 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.Brickcraft, LLC Page 18 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney

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

A modification, construction, or reconstructi on is governed by the requi rements of 326 IAC 2.

B.21 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 card s, credentials, and other documents as may be required by law, and subject to the Permittee’s ri ght under all applicable laws and regulations to assert that the information collected by the age ncy is confidential and entitled to be treated as such, the Permittee shall allow IDEM, OAQ, U.S. EPA, or an authorized r epresentative 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 reco rds 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 monito ring 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 para meters for the purpose of as suring 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, an d IC 13-30-3-1, utilize any photographic, recording, testing, monitori ng, or other equipment for the purpose of assuring compliance with this permit or applicable requirements.

B.22 Transfer of Ownership or O perational Control [326 IAC 2-7-11]
(a) The Permittee must comply with the requirements of 326 IA C 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 ow nership or operational control of the source shall contain a written agreement containing a specific date for transfer of permit responsibility, coverage and liability betwe en the current and new Permittee. The application shall be submitted to:

Indiana Department of Environmental Management Permit Administration and Support Section, Office of Air Quality

100 North Senate Avenue

MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251

Any such application does require a cert ification that meets the requirements of 326 IAC 2-7-6(1) by a "responsible offici al" as defined by 326 IAC 2-7-1(34).

(c) The Permittee may implement administr ative amendment changes addressed in the request for an administrative amendment immediately upon submittal of the request. [326 IAC 2-7-11(c)(3)]Brickcraft, LLC Page 19 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney

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

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

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

B.24 Credible Evidence [326 IAC 2-7-5(3)] [ 326 IAC 2-7-6] [62 FR 8314] [326 IAC 1-1-6]
For the purpose of submitting compliance certif ications 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 compli ance with the condition of this permit if the appropriate performance or compliance te st or procedure had been performed.Brickcraft, LLC Page 20 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney

SECTION C SOURCE OPERATION CONDITIONS

Entire Source

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

C.1 Particulate Emission Limitations For Proces ses with Process Weight Rates Less Than One Hundred (100) Pounds per Hour [326 IAC 6-3-2]
Pursuant to 326 IAC 6-3-2(e)(2), particulate emissions from any process not exempt under 326 IAC 6-3-1(b) or (c) which has a maximum proc ess weight rate less than 100 pounds per hour and the methods in 326 IAC 6-3-2(b) through (d) do not apply shall not exceed 0.551 pounds per

hour.

C.2 Opacity [326 IAC 5-1]
Pursuant to 326 IAC 5-1-2 (Opacity Limitati ons), except as provided in 326 IAC 5-1-1 (Applicability) and 326 IAC 5-1-3 (Temporary Alternat ive Opacity Limitations), opacity shall meet the following, unless otherwise stated in this permit:

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

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

C.3 Open Burning [326 IAC 4-1] [IC 13-17-9]
The Permittee shall not open burn any material except as provided in 326 IAC 4-1-3,

326 IAC 4-1-4 or 326 IAC 4-1-6. The previous sentence notwithstanding, the Permittee may open burn in accordance with an open burning approval issued by the Commissioner under

326 IAC 4-1-4.1.

C.4 Incineration [326 IAC 4-2] [326 IAC 9-1-2]
The Permittee shall not operate an incinerator except as provided in 326 IAC 4-2 or in this permit. The Permittee shall not operate a refuse incine rator or refuse burning equipment except as provided in 326 IAC 9-1-2 or in this permit.

C.5 Fugitive Dust Emissions [326 IAC 6-4]
The Permittee shall not allow fugitive dust to escape beyond the property line or boundaries of the property, right-of-way, or easement on which the source is located, in a manner that would violate 326 IAC 6-4 (Fugitive Dust Emissions). 326 IAC 6-4-2(4) is not federally enforceable.

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

C.7 Asbestos Abatement Projects [326 IAC 14-10] [326 IAC 18] [40 CFR 61, Subpart M]
(a) Notification requirements apply to each owner or operator. If the combined amount of regulated asbestos containing material (RACM) to be stripped, removed or disturbed is at least 260 linear feet on pipes or 160 square f eet on other facility components, or at leastBrickcraft, LLC Page 21 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney

thirty-five (35) cubic feet on all facility co mponents, then the notific ation 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 asbest os containing material increases or decreases by at least twenty percent (20%); or

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

(A) Asbestos removal or demolition start date;

(B) Removal or demolition contractor; or

(C) Waste disposal site.

(c) The Permittee shall ensure that the notic e is postmarked or delivered according to the guidelines set forth in 326 IAC 14-10-3(2).

(d) The notice to be submitted shall include the information enumerated in 326 IAC 14-10-3(3).

All required notifications shall be submitted to:

Indiana Department of Environmental Management Compliance and Enforcement Branch, Office of Air Quality

100 North Senate Avenue

MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251

The notice shall include a signed certificati on 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 t hat meets the requirements of 326 IAC 2-7-6(1) by a "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 f eet 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 affe cted facility or part of the facility where the

demolition or renovation will occur for th e presence of asbestos pursuant to 40 CFR 61.145(a).

(g) Indiana Licensed 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 Licensed Asbestos Inspector toBrickcraft, LLC Page 22 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney

thoroughly inspect the affected po rtion of the facility for the presence of asbestos. The requirement to use an Indiana Licensed Asbesto s inspector is not federally enforceable.

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

C.8 Performance Testing [326 IAC 3-6]
(a) For performance testing required by this permit, a test protocol, except as provided elsewhere in this permit, shall be submitted to:

Indiana Department of Environmental Management Compliance and Enforcement Branch, Office of Air Quality

100 North Senate Avenue

MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251

no later than thirty-five (35) days prior to the intended test date. The protocol submitted by the Permittee does not require a certif ication that meets the requirements of 326 IAC 2-7-6(1) by a "responsible offici al" 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 notificat ion submitted by the Permittee does not require

a certification that meets the requirements of 326 IAC 2-7-6(1) by a "responsible official" as defined by 326 IAC 2-7-1(34).

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

Compliance Requirements [326 IAC 2-1.1-11]

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

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

C.10 Compliance Monitoring [326 IAC 2-7-5(3)] [326 IAC 2-7-6(1)]
Unless otherwise specified in this permit, for all monitoring requirement s not already legally required, the Permittee shall be allowed up to ninet y (90) days from the date of permit issuance or of initial start-up, whichever is later, to begin such monitoring. If due to circumstances beyond the Permittee's control, any monitoring equipment re quired by this permit cannot be installed and operated no later than ninety (90) days after permit issuance or the date of initial startup, whichever is later, the Permittee may extend the compliance schedule related to the equipment for an additional ninety (90) days provided the Permittee notifies:

Indiana Department of Environmental Management Compliance and Enforcement Branch, Office of Air Quality

100 North Senate Avenue

MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251

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.Brickcraft, LLC Page 23 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney

The notification which shall be submitted by the Pe rmittee does require a ce rtification that meets the requirements of 326 IAC 2-7-6(1) by a "respons ible official" as defined by 326 IAC 2-7-1(34).

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

C.11 Instrument Specificatio ns [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 provid ed 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 (Emer gency Reduction Plans; Submission):

(a) The Permittee shall prepare written emergen cy reduction plans (ERPs) consistent with safe operating procedures.

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

Indiana Department of Environmental Management Compliance and Enforcement Branch, Office of Air Quality

100 North Senate Avenue

MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251

no later than ninety (90) days after the date of issuance of this permit.

The ERP does require a certification that m eets the requirements of 326 IAC 2-7-6(1) by a "responsible official" as defined by 326 IAC 2-7-1(34).

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

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

(e) Said ERPs shall also identify the sources of air pollutants, the approximate amount of reduction of the pollutants, and a brief descri ption of the manner in which the reduction

will be achieved.

(f) Upon direct notification by IDEM, OAQ that a specific air pollution episode level is in effect, the Permittee shall immediately put into effect the actions stipulated in the approved ERP for the appropriate epis ode level. [326 IAC 1-5-3]Brickcraft, LLC Page 24 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney

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]
Upon detecting an excursion where a response step is required by the D Section or an exceedance of a limitation in this permit:

(a) The Permittee shall take reasonable response steps to restore operation of the emissions unit (including any control device and associ ated capture system) to its normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing excess emissions.

(b) The response shall include minimizing the period of any startup, shutdown or malfunction. The response may include, but is not limited to, the following:

(1) initial inspection and evaluation;

(2) recording that operations returned or are returning to normal without operator action (such as through response by a co mputerized distributio n control system);

or

(3) any necessary follow-up actions to return operation to normal or usual manner of operation.

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

an excursion or exceeda nce will be based on information av ailable, 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, as sociated capture system, and the process.

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

(e) The Permittee shall record the reasonable response steps 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 s pecified in any condition of this permit, the Permittee shall submit a description of its response actions to IDEM, OAQ, no later than seventy-five (75) days after the date of the test.

(b) A retest to demonstrate compliance shall be performed no later than one hundred eighty (180) days after the date of the test. Should the Permittee demonstrate to IDEM, OAQ that retesting in one hundred eighty (180) 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.Brickcraft, LLC Page 25 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney

The response action documents submitted pursuant to this condition do require a certification that meets the requirements of 326 IAC 2-7-6(1) by a "responsi ble official" as defined by 326 IAC 2-7-1(34).

Record Keeping and Reporting Requiremen ts [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]
Pursuant to 326 IAC 2-6-3(b)(3), starting in 2006 and every three (3) years thereafter, the Permittee shall submit by July 1 an emission stat ement covering the previous calendar year. The emission statement shall contain, at a minimum, the information sp ecified 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 emission s of regulated pollutants as defined by 326 IAC 2-7-1(32) (“Regulated pollutant, which is used only for purposes of Section 19 of this rule”) from the source, for purpose of fee assessment.

The statement must be submitted to:

Indiana Department of Environmental Management Technical Support and Modeling Section, Office of Air Quality

100 North Senate Avenue

MC 61-50 IGCN 1003 Indianapolis, Indiana 46204-2251

The emission statement does require a cert ification that meets the requirements of 326 IAC 2-7-6(1) by a "responsible offi cial" as defined by 326 IAC 2-7-1(34).

C.17 General Record Keeping Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-6]
(a) Records of all required monitoring data, repo rts and support information required by this permit shall be retained for a period of at l east 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 lo cation for a minimum of three (3) years. The records may be stored elsewhere for the remain ing 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, for all record keeping requirements not already legally required, the Permittee shall be allow ed up to ninety (90) days from the date of permit issuance or the date of initial start-up, whichever is later, to begin such record keeping.

C.18 General Reporting Requirements [326 IAC 2-7-5(3)(C)] [326 IAC 2-1.1-11]
(a) The Permittee shall submit the attached Quarterly Deviation and Compliance Monitoring Report or its equivalent. Any deviation from permit requirements, the date(s) of each deviation, the cause of the deviation, and the response steps taken must be reported except that a deviation required to be report ed pursuant to an applicable requirement that exists independent of this permit, shall be re ported according to the schedule stated in the applicable requirement and does not need to be included in this report. This report shall be submitted not later than thirty (30) days after the end of the reporting period. The Quarterly Deviation and Compliance Monitoring Report shall include a certification that meets the requirements of 326 IAC 2-7-6(1) by a "responsi ble official" as defined byBrickcraft, LLC Page 26 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney

326 IAC 2-7-1(34). A deviation is an exceedance of a permit limitation or a failure to comply with a requirement of the permit.

(b) The address for report submittal is:

Indiana Department of Environmental Management Compliance and Enforcement Branch, Office of Air Quality

100 North Senate Avenue

MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251

(c) Unless otherwise specified in this permit, any notice, report, or other submission required by this permit shall be considered timely if the date postmarked on the envelope or certified mail receipt, or affixed by the shipper on the private shipping receipt, is on or

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

(d) The first report shall cover the period comme ncing on the date of issuance of this permit or the date of initial start-up, whichever is later, and ending on the last day of the reporting period. Reporting periods ar e based on calendar year s, 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.

Stratospheric Ozone Protection

C.19 Compliance with 40 CFR 82 and 326 IAC 22-1
Pursuant to 40 CFR 82 (Protection of Stratosphe ric Ozone), Subpart F, except as provided for motor vehicle air conditioners in Subpart B, t he Permittee shall comply with applicable standards for recycling and emissions reduction.Brickcraft, LLC Page 27 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney

SECTION D.1 EMISSIONS UNIT OPERATION CONDITIONS

Emissions Unit Description: Fugitive Emissions

(a) One (1) quarry, constructed in 2004, with a capacity of 125 tons of shale per hour;

(b) Three (3) outdoor aggregate storage piles, with a combined capacity of 125 tons of shale per

hour.

(e) One (1) outdoor spent injection material st orage pile, with a capacity of 185 pounds of lime/sodium bicarbonate mixture per hour.

Insignificant Activities

(g) Paved and unpaved roads. [ 326 IAC 6-4] [326 IAC 6-5]

(The information describing the process contained in this emissions unit descri ption box is descriptive information and does not constitute enforceable conditions.)

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

D.1.1 Fugitive Particulate Matter Emission Limitations [326 IAC 6-5]
Pursuant to 326 IAC 6-5 (Fugitive Particulate Ma tter Emission Limitations), fugitive particulate matter emissions shall be controlled according to the plan included as Attachment A. The provisions of 326 IAC 6-5 are not federally enforceable.Brickcraft, LLC Page 28 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney

SECTION D.2 EMISSIONS UNIT OPERATION CONDITIONS

Emissions Unit Description: Aggregate Processing

(c) One (1) pre-kiln clay/shale/fireclay/sand proce ssing operation, identified as EU-02, installed in 2004, with a maximum capacity of 125 tons of raw material (including clay, fireclay, shale, and sand) per hour, consisting of the following equipment:

(1) One (1) primary crusher, with a maximum capacity of 125 tons of raw material per hour, using baghouse BH-1 as particulate control, exhaust ing internally. Under NSPS Subpart OOO, this is an affected facility enclosed in a building;

(2) One (1) transfer conveyor, with a maximum capacity of 125 tons of raw material per hour, using a hood venting to baghouse BH-1 as particulate control, exhausting internally. Under NSPS Subpart OOO, this is an affected fa cility enclosed in a building;

(3) One (1) grinding and scalping screen operati on, with a maximum capacity of 125 tons of raw material per hour, using a hood venting to baghouse BH-1 as particulate control, exhausting interna lly. Under NSPS Subpart OOO, th is is an affected facility enclosed in a building;

(4) One (1) coarse material return conveyor, with a maximum capacity of 125 tons of raw material per hour, using a hood venting to baghouse BH-1 as particulate control, exhausting internally. Unde r NSPS Subpart OOO, this is an affected facility enclosed in a building;

(5) One (1) transfer conveyor, with a maximum capacity of 125 tons of raw material per hour, using a hood venting to baghouse BH-1 as particulate control, exhausting internally. Under NSPS Subpart OOO, this is an affected fa cility enclosed in a building;

(6) One (1) secondary crusher, with a maximum capacity of 110 tons of raw material per hour, using a hood venting to baghouse BH-1 as particulate control, exhausting internally. Under NSPS Subpart OOO, this is an affected fa cility enclosed in a building;

(7) One (1) transfer conveyor, with a maximum capacity of 110 tons of raw material per hour, using a hood venting to baghouse BH-1 as particulate control, exhausting internally. Under NSPS Subpart OOO, this is an affected fa cility enclosed in a building;

(8) One (1) finishing screen operation, with a maximum capacity of 70 tons of raw material per hour, using a hood venting to baghouse BH-1 as particulate control, exhausting internally. Under NSPS Subpart OOO, this is an affected fa cility enclosed in a building;

(9) One (1) coarse material return conveyor, with a maximum capacity of 70 tons of raw material per hour, using a hood venting to baghouse BH-1 as particulate control, exhausting internally. Unde r NSPS Subpart OOO, this is an affected facility enclosed in a building;

(10) Two (2) transfer conveyors, each with a maximum capacity of 70 tons of raw material per hour, each using a hood venting to baghouse BH-1 as particulate control,Brickcraft, LLC Page 29 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney

exhausting internally. Under NSPS Sub part OOO, these are affected facilities enclosed in a building;

(11) Six (6) crushed material storage bins, each having a capacity of 100 tons, each using a hood venting to baghouse BH-1 as particulat e control, exhausting internally. Under NSPS Subpart OOO, these ar e affected facilities enclosed in a building;

(12) Two (2) transfer conveyors, each with a maximum capacity of 60 tons of raw material per hour, each using a hood venting to baghouse BH-1 as particulate control, exhausting internally;

(13) One (1) enclosed mixi ng pugmill, with a maximum capacity of 60 tons per hour, using baghouse BH-2 as particulate control, exhausting internally;

(14) One (1) transfer conveyor, with a maximu m capacity of 60 tons of milled material per hour, using a hood venting to baghouse BH-1 as particulate control, exhausting internally; and

(15) One (1) extrusion operation, with a maximu m capacity of 60 tons of milled material per hour, with emissions uncontrolled.

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

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

D.2.1 Particulate [326 IAC 6-3-2]
Pursuant to 326 IAC 6-3-2 (Particulate Emi ssion Limitations for Manufacturing Processes), particulate emissions from emission units shall not exceed allowable particulate emissions when operating at a maximum process weight ra te as specified in the table below.

The pounds per hour limitations were ca lculated using the following equation:

Interpolation and extrapolation of the data for the pr ocess weight rate in excess of sixty thousand (60,000) pounds per hour shall be accomplished by use of the equation:

E = 55.0 P 0.11 - 40 where E = rate of emission in pounds per hour, and P = process weight rate in tons per hour

The allowable emissions for each facility operati ng at its maximum process weight rate are as

follows:

Emission Unit ID Process Weight (tons/hr) Allowable Particulate Emissions (lb/hr)

Grinding and Scalping Screen Operation 125 53.55

Finishing Screen Operation 70 47.77

Pugmill 60 46.29

D.2.2 Preventive Maintenanc e Plan [326 IAC 2-7-5(13)]
A Preventive Maintenance Plan is required for th ese units and the associated control devices.

Section B - Preventive Maintenance Plan contains the Permittee's obligation with regard to the preventive maintenance plan required by this condition.Brickcraft, LLC Page 30 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney

SECTION D.3 EMISSIONS UNIT OPERATION CONDITIONS

Emissions Unit Description: Brick Manufacturing

(d) One (1) brick manufacturing line, identified as EU-01, installed in 2004, with a maximum capacity of 10 tons of bricks per hour, consisting of:

(1) One (1) brick dryer, with a maximum capacity of 10 tons of bricks per hour, using recycled hot air from the gas-fired kiln, exhausting through stacks D-1 and CZ-1;

(2) One (1) natural gas-fired tunnel kiln, rate d at 56 million British thermal units per hour, with a maximum capacity of 10 tons of bricks per hour, using a dry injection fabric filter (DIFF) as a control device for both hydr ogen fluoride and sulfur dioxide, exhausting through stacks POC-1 and UCC-1;

(3) One (1) lime storage silo, identified as Lime Silo, constructed in 2009, permitted in 2011, with a maximum capacity of 50 tons and a maximum throughput of 25 tons per hour, exhausting to the dry injection fabric filter (DIFF); and

(4) One (1) sodium bicarbonate storage silo, i dentified as Bicarb Silo, constructed in 2004, permitted in 2011, with a maximum capacity of 50 tons and a maximum throughput of 25 tons per hour, exhausting to the dry injection fabric filter (DIFF).

(The information describing the process contained in this emissions unit descri ption box is descriptive information and does not constitute enforceable conditions.)

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

D.3.1 PSD Minor Limits [326 IAC 2-2]
(a) The PM emissions from the lime silo and sodium bicarbonate silo shall not exceed 5.0 pounds per hour, each.

(b) The PM 10 emissions from the lime silo and sodium bicarbonate silo shall not exceed 17.6 pounds per hour, each.

(c) The SO 2 emissions from the dry injection fabric filter (DIFF) controlling the tunnel kiln shall not exceed 249 tons per twelve (12) co nsecutive month period, with compliance

determined at the end of each month.

(d) The dry injection fabric filter (DIFF) for PM and PM 10 control shall be in operation and

control emissions from the lime silo and sodium bicarbonate silo at all times that either of the silos are being loaded.

(e) The dry injection fabric filter (DIFF) for SO 2 control shall be in operation and control

emissions from the tunnel kiln at all times that the tunnel kiln is in operation, except for a maximum of 125 hours per twelve (12) cons ecutive month period during which the DIFF may be bypassed (for routine maintenance).

Compliance with the limits in Condition D.3.1, combined with the unrestricted potential to emit

from other units at the so urce, will limit the source-w ide potential to emit PM, PM 10 , and SO 2 to less than 250 tons per twelve (12) consecutive month period, each. Compliance with these limits renders 326 IAC 2-2 (Prevention of Sign ificant Deterioration) not applicable.Brickcraft, LLC Page 31 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney

D.3.2 HAP Minor Limits [326 IAC 2-4.1]
(a) The HF emissions from the dry injection fabric filter (DIFF) controlling the tunnel kiln shall not exceed 10 tons per twelve (12) c onsecutive month period, with compliance

determined at the end of each month.

(b) The dry injection fabric filter (DIFF) for HF control shall be in operation and control

emissions from the tunnel kiln at all times that the tunnel kiln is in operation, except for a maximum of 125 hours per twelve (12) cons ecutive month period during which the DIFF may be bypassed (for routine maintenance).

Compliance with the limits in Condition D.3.2, co mbined with the potential to emit from other units at the source, will limit the source-wide potential to emit HF to less than 10 tons per twelve (12) consecutive month period. Compliance with these limits renders 326 IAC 2-4.1 (Major Sources of Hazardous Air Pollutants) not applicable.

D.3.3 Particulate [326 IAC 6-3-2]
Pursuant to 326 IAC 6-3-2 (Particulate Emi ssion Limitations for Manufacturing Processes), particulate emissions from emission units shall not exceed allowable particulate emissions when operating at a maximum process weight ra te as specified in the table below.

The pounds per hour limitations were ca lculated using the following equation:

Interpolation and extrapolation of the data for the process weight rate up to sixty thousand (60,000) pounds per hour shall be accomplished by use of the equation:

E = 4.10 P 0.67 where E = rate of emission in pounds per hour, and P = process weight rate in tons per hour

The allowable emissions for each facility operati ng at its maximum process weight rate are as

follows:

Emission Unit ID Process Weight (tons/hr) Allowable Particulate Emissions (lb/hr)

Brick Dryer 9.05 17.9

Tunnel Kiln 9.05 17.9

Lime Storage Silo - Receiving 25 35.4

Bicarbonate Storage Silo - Receiving 25 35.4

D.3.4 Preventive Maintenanc e Plan [326 IAC 2-7-5(13)]
A Preventive Maintenance Plan is required for th ese units and the associated control devices.

Section B - Preventive Maintenance Plan contains the Permittee's obligation with regard to the preventive maintenance plan required by this condition.

Compliance Determination Requirements

D.3.5 Emissions Control [326 IAC 2-7-6(6)]
(a) In order to comply with Conditions D.3.1(a) and D.3.1(b), the dry injection fabric filter (DIFF) for particulate control shall be in oper ation and control emissions from the lime silo

and sodium bicarbonate silo at all times t hat either of the silos are being loaded.Brickcraft, LLC Page 32 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney

(b) When determining compliance with Conditions D.3.1(c) and D.3.2(a) without the use of a CEMS, the dry injection fabric filter (DIFF) for SO 2 and HF control shall be in operation

and control emissions from the tunnel kiln at all times that the tunnel kiln is in operation, except for a maximum of 125 hours per twel ve (12) consecutive month period during which the DIFF may be bypassed (for routine maintenance).

(c) In the event that bag failure is observed in a multi-compartment baghouse, if operations will continue for ten (10) days or more after t he failure is observed before the failed units will be repaired or replaced, the Permittee sh all promptly notify the IDEM, OAQ of the expected date the failed units w ill 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 acti ons taken up to the time of notification.

D.3.6 Testing Requirements [326 IA C 2-7-6(1),(6)] [326 IAC 2-1.1-11]
(a) In order to demonstrate compliance with C ondition D.3.1(c) without the use of a CEMS, the Permittee shall perform SO 2 testing of the dry injection fabric filter (DIFF) controlling the tunnel kiln utilizing methods as approved by the Commissioner at least once every five (5) years from the date of the most rece nt valid compliance demonstration. Testing shall be conducted in accordance with the provisions of 326 IAC 3-6 (Source Sampling Procedures). Section C - Performance Testi ng contains the Permittee's obligation with regard to the performance testing required by this condition.

(b) In order to demonstrate compliance with Condition D.3.2(a) without the use of a CEMS, the Permittee shall perform HF testing of the dry injection fabric filter (DIFF) controlling the tunnel kiln utilizing methods as approved by the Commissioner at least once every five (5) years from the date of the most rece nt valid compliance demonstration. Testing shall be conducted in accordance with the provisions of 326 IAC 3-6 (Source Sampling Procedures). Section C - Performance Testi ng contains the Permittee's obligation with regard to the performance testing required by this condition.

D.3.7 Sulfur Dioxide (SO 2 )
In order to determine compliance with the SO 2 emissions limit in Condition D.3.1(c), the SO 2 emissions from the tunnel kiln shall be calculated using the following formula:

E TOTAL = E CEMS + [(C x EF DIFF x H DIFF / 2000) + (C x EF NON-DIFF x H NON-DIFF / 2000)]

where:

E TOTAL = combined total tons of SO 2 emissions per month

E CEMS = total tons of SO 2 emissions per month from the tunnel kiln, as determined with the CEMS output C = average hourly throughput of the tunnel kiln for the month defined by

H DIFF and H NON-DIFF EF DIFF = SO 2 emission factor from the tunnel kiln when controlled by the DIFF, which equals 5.41 lb/ton or the most recent valid compliance

demonstration

H DIFF = total number of hours per month t he tunnel kiln was controlled by the

DIFF when the CEMS is not used to measure SO 2 2000 = lb/ton

EF NON-DIFF = SO 2 emission factor from the tunnel kiln when bypassing the DIFF, which equals 25.0 lb/ton or the most recent valid compliance

demonstration

H NON-DIFF = total number of hours per month the tunnel kiln bypassed the DIFF

when the CEMS is not used to measure SO 2Brickcraft, LLC Page 33 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney

D.3.8 Hydrogen Fluoride/Hy drofluoric Acid (HF)
In order to determine compliance with the HF emissions limit in Condition D.3.2(a), the HF emissions from the tunnel kiln shall be calculated using the following formula:

E TOTAL = E CEMS + [(C x EF DIFF x H DIFF / 2000) + (C x EF NON-DIFF x H NON-DIFF / 2000)]

where:

E TOTAL = combined total tons of HF emissions per month

E CEMS = total tons of HF emissions per month from the tunnel kiln, as determined with the CEMS output C = average hourly throughput of the tunnel kiln for the month defined by

H DIFF and H NON-DIFF EF DIFF = HF emission factor from the tunnel kiln when controlled by the DIFF, which equals 0.22 lb/ton or the most recent valid compliance

demonstration

H DIFF = total number of hours per month t he tunnel kiln was controlled by the

DIFF when the CEMS is not used to measure HF

2000 = lb/ton

EF NON-DIFF = HF emission factor from the tunnel kiln when bypassing the DIFF, which equals 0.37 lb/ton or the most recent valid compliance

demonstration

H NON-DIFF = total number of hours per month the tunnel kiln bypassed the DIFF

when the CEMS is not used to measure HF

D.3.9 Sulfur Content
In order to determine compliance with Condition D.3.1(c) when determining compliance without the use of a CEMS, the Permittee shall demonstrate that the sulfur dioxide emissions from the tunnel kiln does not exceed 25.00 pounds per ton of fired product. Compliance shall be determi ned utilizing one of the following options:

(a) Sampling and analyzing the aggregate feedst ock by using the following procedures:

(1) The aggregate sample acquisition point shall be at a location where representative samples of the feedstock to be consumed by the facility may be obtained;

(2) The aggregate shall be sampled at least one (1) time per day;

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

(4) Samples shall be composited and analyzed at the end of each calendar
quarter;

(5) Sulfur content analysis shall be deter mined by an independent laboratory; or

(b) Compliance may also be determined by conducting a stack test for sulfur dioxide emissions from the tunnel kiln, using 40 CFR 60, Appendix A, Method 6, which is conducted with such frequency as to generate the amount of information required by (a)

above.

A determination of noncompliance pursuant to any of the methods specified in (a) or (b) above shall not be refuted by evidence of compliance pursuant to the other method.Brickcraft, LLC Page 34 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney

D.3.10 Continuous Emission Monitoring [326 IAC 3- 5] [326 IAC 2-7-6(1), (6)] [326 IAC 2-1.1-11] [326 IAC 2-7-5(3)(A)(iii)] [40 CFR 64]
(a) In order to determine compliance with Conditions D.3.1(c) and D.3.2(a) when determining compliance with the use of a CEMS, the Permittee shall maintain, calibrate, and operate a continuous emission monitoring system (CEM S) and related equipment for measuring

SO 2 and HF emissions from the tunnel kiln in accordance with 326 IAC 3-5.

(b) The SO 2 and HF CEMS shall be operated at all times the tunnel kiln is in operation except for system breakdowns, repairs , calibration checks, and zero and span adjustments.

(c) Nothing in this permit shall excuse the Perm ittee from complying with the requirements to operate a CEMS pursuant to 326 IAC 3-5.

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

D.3.11 SO 2 and HF Monitor Downtime [326 IAC 2-7-6] [326 IAC 2-7-5(1)]
When determining compliance with Conditions D.3. 1(c) and D.3.2(a) with the use of a CEMS,

whenever the CEMS is down for more than twen ty-four (24) hours, a calibrated backup CEMS shall be brought online within twenty-four (24) hours of shutdown of the primary CEMS, if possible. If this is not possible, the requirement s in Condition D.3.14(b) shall be conducted to allow for determination of compliance with the SO 2 and HF emission limits.

D.3.12 Visible Emissions Notations
(a) Visible emission notations of the dry inje ction fabric filter (DIFF) exhaust shall be performed once per day during normal dayli ght operations. A trained employee shall

record whether emissions are normal or abnormal.

(b) For processes operated continuously, "nor mal" 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 opera tions, readings shall be taken during that part of the operation that would normally be ex pected to cause the greatest emissions.

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

(e) If abnormal emissions are observed, the Pe rmittee shall take reasonable response. Section C - Response to Excursions or Exc eedances contains the Permittee's obligation with regard to the reasonable response steps re quired by this condition. Failure to take response steps shall be considered a deviation from this permit.

D.3.13 Baghouse Parametric Monitoring
The Permittee shall record the pressure drop across the dry injection fabric filter (DIFF) at least once per day when any of the tunnel kiln, lime silo, and sodium bicarbonate silo are in operation. When for any one reading, the pressure drop across the DIFF is outside the normal range of 1 to 7 inches of water or a range established during the latest stack test, the Permittee shall take reasonable response. Section C - Response to Excursions or Exceedances contains the Permittee's obligation with regard to the reasonable response steps required by this condition. A reading that is outside the normal range is not a deviation from this permit. Failure to take response steps shall be considered a deviation from this permit.Brickcraft, LLC Page 35 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney

The instrument used for determining the pressure drop shall comply with Section C - Instrument Specifications, of this permit, shall be subject to approval by IDEM, OAQ and shall be calibrated or replaced at least once every six (6) months or other time period specified by the manufacturer.

The Permittee shall maintain records of t he manufacturer's specifications, if used.

D.3.14 SO 2 Compliance Assurance Monitoring [40 CFR 64]
Pursuant to 326 IAC 2 7 5(1), 326 IAC 2 7 6(1), and 40 CFR 64 (CAM):

(a) When determining compliance with the use of a CEMS, the Permittee shall operate a CEMS. When the CEMS is not operating, the Permittee shall take reasonable response. Section C - Response to Excursions or Exc eedances contains the Permittee's obligation with regard to the reasonable response steps required by this condition. A reading that indicates the CEMS is not operating is not a dev iation from this permit. Failure to take response steps shall be considered a deviation from this permit.

(b) When determining compliance without the use of a CEMS:

(1) The Permittee shall monitor the dry lime feed rate from the lime silo to the dry injection fabric filter (DIFF) continuously. When the dry lime feed rate is below 12% motor output speed (equivalent to 125 pounds per hour) or a rate established during the latest performance test, the Permittee shall take reasonable response. Section C - Response to Excursions or Exceedances contains the Permittee's obligation with regard to the reasonable response steps required by this condition. A reading that is below the above mentioned rate is not a deviation from this permit. Fa ilure to take response steps shall be considered a deviation from this permit.

(2) The Permittee shall monitor the dry sodium bicarbonate feed rate from the sodium bicarbonate silo to the dry injecti on fabric filter (DIFF) continuously. When the dry sodium bicarbonate feed rate is below 11% motor output speed (equivalent to 60 pounds per hour) or a rate established during the latest performance test, the Permittee shall take reasonable response. Section C - Response to Excursions or Exceedances co ntains the Permittee's obligation with regard to the reasonable response steps required by this condition. A reading that is below the above mentioned rate is not a deviation from this permit. Failure to take response steps shall be considered a deviation from this permit.

(3) The Permittee shall inspect the dr y lime feed system and the feed quantity on the lime silo once per day. If the lime feed quantity drops below the level established during the latest performance test or runs out, the switches and/or level sensors monitoring the interlock system on the li mestone delivery systems (including the lime screw conveyor and holding bin) ar e not functioning properly, or the
Permittee discovers cracks, holes, or ab normal/excessive wear on the indicators for the screw conveyor and holding bin, the Permittee shall take reasonable response. Section C - Response to E xcursions or Exceedances contains the Permittee's obligation with regard to the reasonable response steps required by this condition. A feed quantity that is bel ow the level established during the latest performance test is not a deviation from this permit. Failure to take response steps shall be considered a deviation from this permit.

(4) The Permittee shall inspect the dry sodium bicarbonate feed system and the feed quantity on the sodium bicarbonate silo once per day. If the sodium bicarbonate feeder setting drops below the level established during the latest performance test or runs out, the switches and/or level sensors monitoring the interlock system on the sodium bicarbonate del ivery systems, including the sodiumBrickcraft, LLC Page 36 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney

bicarbonate screw conveyor and holding bin, are not functioning properly, or the Permittee discovers cracks, holes, or ab normal/excessive wear on the indicators for the screw conveyor and holding bin, the Permittee shall take reasonable response. Section C - Response to E xcursions or Exceedances contains the Permittee's obligation with regard to the reasonable response steps required by this condition. A feed quantity that is bel ow the level established during the latest performance test is not a deviation from this permit. Failure to take response steps shall be considered a deviation from this permit.

D.3.15 HF Compliance Monitoring
(a) When determining compliance with the use of a CEMS, the Permittee shall operate a CEMS. When the CEMS is not operating, the Permittee shall take reasonable response. Section C - Response to Excursions or Exc eedances contains the Permittee's obligation with regard to the reasonable response steps required by this condition. A reading that indicates the CEMS is not operating is not a dev iation from this permit. Failure to take response steps shall be considered a deviation from this permit.

(b) When determining compliance without the use of a CEMS:

(1) The Permittee shall monitor the dry lime feed rate from the lime silo to the dry injection fabric filter (DIFF) once per day. When the dry lime feed rate is below 12% motor output speed (equivalent to 125 pounds per hour) or a rate established during the latest performance test, the Permittee shall take reasonable response. Section C - Response to Excursions or Exceedances contains the Permittee's obligation with regard to the reasonable response steps required by this condition. A reading that is below the above mentioned rate is not a deviation from this permit. Fa ilure to take response steps shall be considered a deviation from this permit.

(2) The Permittee shall monitor the dry sodium bicarbonate feed rate from the sodium bicarbonate silo to the dry injecti on fabric filter (DIFF) once per day. When the dry sodium bicarbonate feed rate is below 11% motor output speed (equivalent to 60 pounds per hour) or a rate established during the latest performance test, the Permittee shall take reasonable response. Section C - Response to Excursions or Exceedances co ntains the Permittee's obligation with regard to the reasonable response steps required by this condition. A reading that is below the above mentioned rate is not a deviation from this permit. Failure to take response steps shall be considered a deviation from this permit.

(3) The Permittee shall inspect the dr y lime feed system and the feed quantity on the lime silo once per day. If the lime feed quantity drops below the level established during the latest performance test or runs out, the switches and/or level sensors monitoring the interlock system on the li mestone delivery systems (including the lime screw conveyor and holding bin) ar e not functioning properly, or the Permittee discovers cracks, holes, or ab normal/excessive wear on the indicators for the screw conveyor and holding bin, the Permittee shall take reasonable response. Section C - Response to E xcursions or Exceedances contains the Permittee's obligation with regard to the reasonable response steps required by this condition. A feed quantity that is bel ow the level established during the latest performance test is not a deviation from this permit. Failure to take response steps shall be considered a deviation from this permit.

(4) The Permittee shall inspect the dry sodium bicarbonate feed system and the feed quantity on the sodium bicarbonate silo once per day. If the sodium bicarbonate feeder setting drops below the level established during the latest performanceBrickcraft, LLC Page 37 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney

test or runs out, the switches and/or level sensors monitoring the interlock system on the sodium bicarbonate del ivery systems, including the sodium bicarbonate screw conveyor and holding bin, are not functioning properly, or the
Permittee discovers cracks, holes, or ab normal/excessive wear on the indicators for the screw conveyor and holding bin, the Permittee shall take reasonable response. Section C - Response to E xcursions or Exceedances contains the Permittee's obligation with regard to the reasonable response steps required by this condition. A feed quantity that is bel ow the level established during the latest performance test is not a deviation from this permit. Failure to take response steps shall be considered a deviation from this permit.

D.3.16 Broken or Failed Bag Detection
In the event that failure of the dry inject ion fabric filter (DIFF) has been observed:

(a) For a single compartment baghouse controlling emissions from a process operated continuously, the feed to the process shall be shut down immediately until the failed unit has been repaired or replaced. The emissions unit shall be shut down no later than the completion of the processing of the material in the emissions unit. 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 controlli ng emissions from a batch process, the feed to the process shall be shut down immediately until the failed unit has been repaired or replaced. The emissions unit shall be shut down no later than the completion of the processing of the material in the emissions unit. Operations may continue only if the event qualifies as an emergency and the Perm ittee 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 Requiremen ts [326 IAC 2-7-5(3)] [326 IAC 2-7-19]

D.3.17 Record Keeping Requirements
(a) To document the compliance status with Conditions D.3.1(e) and D.3.2(b), the Permittee shall maintain monthly records of the amount of time the dry injection fabric filter (DIFF) was bypassed.

(b) To document the compliance status with Conditions D.3.1 and D.3.9, the Permittee shall maintain records in accordance with (1) through (3) below:

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

(2) Sulfur content of t he aggregate feedstock; and

(3) Sulfur dioxide emission rates.

Records maintained for (1) through (3) shall be taken monthly and shall be complete and sufficient to establish compliance with the emission limits established in Condition D.3.1.

(c) To document the compliance status with C ondition D.3.10, the Permittee shall maintain

records of the SO 2 and HF CEMS output. Records shall be complete and sufficient toBrickcraft, LLC Page 38 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney

establish compliance with the SO 2 and HF limits in Conditions D.3.1(f) and D.3.2(b) on a monthly basis.

(d) To document the compliance status with Condition D.3.11, the Permittee shall maintain the following information, recorded during periods of SO 2 and HF CEMS downtime:

(1) Calendar dates and beginning and ending times of CEMS downtime during the compliance determination period;

(2) Actual aggregate sulfur cont ent, during CEMS downtime; and

(3) Documentation of the emission rate of SO 2 and HF, as determined in accordance

with Conditions D.3.10 and D.3.11.

(e) To document the compliance status with Condition D.3.12, the Permittee shall maintain

records of visible emission notations of the dr y injection fabric filter (DIFF) exhaust once per day. The Permittee shall include in its da ily 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).

(f) To document the compliance status wi th Conditions D.3.13, D.3.14, and D.3.15, the Permittee shall maintain records once per day of the pressure drop and feed quantity readings. The Permittee shall include in its daily record when a pressure drop reading or feed quantity reading is not taken and the reason for the lack of pressure drop reading or feed quantity reading (e.g., the proc ess did not operate that day).

(g) Section C - General Record Keeping Requi rements contains the Permittee's obligation with regard to the records required by this condition.

D.3.18 Reporting Requirements
(a) A quarterly report of tons of SO 2 emissions to document the compliance status with Condition D.3.1(c) shall be submitted not late r than thirty (30) days after the end of the quarter being reported. Section C - Gene ral Reporting contains the Permittee's obligation with regard to the reporting required by this condition. The report submitted by the Permittee does require a certification that meets the requirements of 326 IAC 2-7-6(1) by a “responsible official” as defined by 326 IAC 2-7-1(34).

(b) A quarterly report of tons of HF emissi ons to document the compliance status with Condition D.3.2(a) shall be submitted not la ter than thirty (30) days after the end of the quarter being reported. Section C - Gene ral Reporting contains the Permittee's obligation with regard to the reporting required by this condition. The report submitted by the Permittee does require a certification that meets the requirements of 326 IAC 2-7-6(1) by a “responsible official” as defined by 326 IAC 2-7-1(34).

(c) A quarterly report of hours of operatio n when bypassing the DIFF to document the compliance status with Conditions D.3.1(e) and D.3.2(b) shall be submitted not later than thirty (30) days after the end of the quar ter being reported. Section C - General Reporting contains the Permittee's obligation wi th regard to the reporting required by this condition. The report submitted by the Perm ittee does require a certification that meets the requirements of 326 IAC 2-7-6(1) by a “re sponsible official” as defined by 326 IAC 2- 7-1(34).Brickcraft, LLC Page 39 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney

SECTION E.1 FACILITY OPERATION CONDITIONS

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

(c) One (1) pre-kiln clay/shale/fireclay/sand proce ssing operation, identified as EU-02, installed in 2004, with a maximum capacity of 125 tons of raw material (including clay, fireclay, shale, and sand) per hour, consisting of the following equipment:

(1) One (1) primary crusher, with a maximum capacity of 125 tons of raw material per hour, using baghouse BH-1 as particulate control, exhaust ing internally. Under NSPS Subpart OOO, this is an affected facility enclosed in a building;

(2) One (1) transfer conveyor, with a maximum capacity of 125 tons of raw material per hour, using a hood venting to baghouse BH-1 as particulate control, exhausting internally. Under NSPS Subpart OOO, this is an affected fa cility enclosed in a building;

(3) One (1) grinding and scalping screen operati on, with a maximum capacity of 125 tons of raw material per hour, using a hood venting to baghouse BH-1 as particulate control, exhausting interna lly. Under NSPS Subpart OOO, th is is an affected facility enclosed in a building;

(4) One (1) coarse material return conveyor, with a maximum capacity of 125 tons of raw material per hour, using a hood venting to baghouse BH-1 as particulate control, exhausting internally. Unde r NSPS Subpart OOO, this is an affected facility enclosed in a building;

(5) One (1) transfer conveyor, with a maximum capacity of 125 tons of raw material per hour, using a hood venting to baghouse BH-1 as particulate control, exhausting internally. Under NSPS Subpart OOO, this is an affected fa cility enclosed in a building;

(6) One (1) secondary crusher, with a maximum capacity of 110 tons of raw material per hour, using a hood venting to baghouse BH-1 as particulate control, exhausting internally. Under NSPS Subpart OOO, this is an affected fa cility enclosed in a building;

(7) One (1) transfer conveyor, with a maximum capacity of 110 tons of raw material per hour, using a hood venting to baghouse BH-1 as particulate control, exhausting internally. Under NSPS Subpart OOO, this is an affected fa cility enclosed in a building;

(8) One (1) finishing screen operation, with a maximum capacity of 70 tons of raw material per hour, using a hood venting to baghouse BH-1 as particulate control, exhausting internally. Under NSPS Subpart OOO, this is an affected fa cility enclosed in a building;

(9) One (1) coarse material return conveyor, with a maximum capacity of 70 tons of raw material per hour, using a hood venting to baghouse BH-1 as particulate control, exhausting internally. Unde r NSPS Subpart OOO, this is an affected facility enclosed in a building;

(10) Two (2) transfer conveyors, each with a maximum capacity of 70 tons of raw material per hour, each using a hood venting to baghouse BH-1 as particulate control, exhausting internally. Under NSPS Sub part OOO, these are affected facilities enclosed in a building;Brickcraft, LLC Page 40 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney

(11) Six (6) crushed material storage bins, each having a capacity of 100 tons, each using a hood venting to baghouse BH-1 as particulat e control, exhausting internally. Under NSPS Subpart OOO, these ar e affected facilities enclosed in a building;

(The information describing the pr ocess contained in th is facility descripti on box is descriptive information and does not constitute enforceable conditions.)

E.1.1 General Provisions Relating to New So urce Performance Standards [326 IAC 12-1] [40 CFR Part 60, Subpart A]
(a) Pursuant to 40 CFR 60.1, the Permittee sha ll comply with the provisions of 40 CFR Part 60 Subpart A – General Provisions, which are incorporated by reference as 326 IAC 12-1 for the pre-kiln clay/shale/fireclay/sand proces sing operation (EU-02) except as otherwise specified in 40 CFR Part 60, Subpart OOO.

(b) Pursuant to 40 CFR 60.19, the Permittee shall submit all required notifications and
reports to:

Indiana Department of Environmental Management Compliance and Enforcement Branch, Office of Air Quality

100 North Senate Avenue

MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251

E.1.2 Standards of Performance for Nonmetallic Mi neral Processing Plants [40 CFR Part 60, Subpart OOO]
The Permittee which engages in pr ocessing of nonmetallic mineral shall comply with the following provisions of 40 CFR Part 60, Subpart OOO, whic h are incorporated by reference as 326 IAC 12 (included as Attachment B of this permit):

(a) 40 CFR 60.670(a), (d), (e), (f); (b) 40 CFR 60.671; (c) 40 CFR 60.672(b), (d), (e)(1), (f); (d) 40 CFR 60.673; (e) 40 CFR 60.675(a), (c)(1)(i), (c)(1)(ii), (c)(2), (c)(3), (d)(2), (e), (g), (i); (f) 40 CFR 60.676(a), (f), (h), (i)(1), (j), (k); (g) Table 1 to 40 CFR 63, Subpart OOO; and (h) Table 3 to 40 CFR 63, Subpart OOO.Brickcraft, LLC Page 41 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney



### INDIANA DEPARTMENT OF EN VIRONMENTAL MANAGEMENT
OFFICE OF AIR QUALITY

COMPLIANCE AND EN FORCEMENT BRANCH

PART 70 OPERATING PERMIT

CERTIFICATION

Source Name: Brickcraft, LLC Source Address: 200 North SR 59, Center Point, Indiana 47840

Part 70 Permit No.: T021-23323-00054



## This certification shall be included when submitting monitoring, testing reports/results, or other document s 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 fo rmed after reasonable inquiry, the statements and information in the document are true, accurate, and complete.

Signature:

Printed Name:

Title/Position:

Phone:

Date:Brickcraft, LLC Page 42 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney



### INDIANA DEPARTMENT OF EN VIRONMENTAL MANAGEMENT

OFFICE OF AIR QUALITY

COMPLIANCE AND ENFORCEMENT BRANCH

100 North Senate Avenue

MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251 Phone: (317) 233-0178

Fax: (317) 233-6865

PART 70 OPERATING PERMIT

EMERGENCY OCCURRENCE REPORT

Source Name: Brickcraft, LLC Source Address: 200 North SR 59, Center Point, Indiana 47840

Part 70 Permit No.: T021-23323-00054

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:Brickcraft, LLC Page 43 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney

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 ti me of the emergency? Y N

Type of Pollutants Emitted: TSP, PM-10, SO 2 , VOC, NO X , CO, Pb, other:

Estimated amount of pollutant(s) emitted during emergency:

Describe the steps taken to mitigate the problem:

Describe the corrective actions/response steps taken:

Describe the measures taken to minimize emissions:

If applicable, describe the reasons wh y continued operation of the fac ilities are necess ary to prevent imminent injury to persons, severe damage to equipmen t, substantial loss of capital investment, or loss of product or raw materials of substantial economic value:

Form Completed by:

Title / Position:

Date:

Phone:Brickcraft, LLC Page 44 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney



## INDIANA DEPARTMENT OF EN VIRONMENTAL MANAGEMENT
OFFICE OF AIR QUALITY

COMPLIANCE AND ENFORCEMENT BRANCH

Part 70 Quarterly Report

Source Name: Brickcraft, LLC Source Address: 200 North SR 59, Center Point, Indiana 47840

Part 70 Permit No.: T021-23323-00054 Facility: Dry injecti on fabric filter (DIFF)

Parameter: SO 2 emissions Limit: Not to exceed 249 tons per twelve (12) consecutive month period

QUARTER : ___________ _____ YEAR: ________________

Month Column 1 Column 2 Column 1 + Column 2

This Month Previous 11 Months 12 Month Total

Month 1

Month 2

Month 3

 No deviation occurred in this quarter.

 Deviation/s occurred in this quarter. Deviation has been reported on:

Submitted by:

Title / Position: Signature:

Date:

Phone:Brickcraft, LLC Page 45 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney



## INDIANA DEPARTMENT OF EN VIRONMENTAL MANAGEMENT
OFFICE OF AIR QUALITY

COMPLIANCE AND ENFORCEMENT BRANCH

Part 70 Quarterly Report

Source Name: Brickcraft, LLC Source Address: 200 North SR 59, Center Point, Indiana 47840

Part 70 Permit No.: T021-23323-00054 Facility: Dry injecti on fabric filter (DIFF)

Parameter: HF emissions Limit: Not to exceed 10 tons per twelve (12) consecutive month period

QUARTER : ___________ _____ YEAR: ________________

Month Column 1 Column 2 Column 1 + Column 2

This Month Previous 11 Months 12 Month Total

Month 1

Month 2

Month 3

 No deviation occurred in this quarter.

 Deviation/s occurred in this quarter. Deviation has been reported on:

Submitted by:

Title / Position: Signature:

Date:

Phone:Brickcraft, LLC Page 46 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney



## INDIANA DEPARTMENT OF EN VIRONMENTAL MANAGEMENT
OFFICE OF AIR QUALITY

COMPLIANCE AND ENFORCEMENT BRANCH

Part 70 Quarterly Report

Source Name: Brickcraft, LLC Source Address: 200 North SR 59, Center Point, Indiana 47840

Part 70 Permit No.: T021-23323-00054 Facility: Dry injecti on fabric filter (DIFF)

Parameter: Number of hours the DIFF may be bypassed (for routine maintenance) Limit: Maximum of 125 hours per twelve (12) consecutive month period

QUARTER : ___________ _____ YEAR: ________________

Month Column 1 Column 2 Column 1 + Column 2

This Month Previous 11 Months 12 Month Total

Month 1

Month 2

Month 3

 No deviation occurred in this quarter.

 Deviation/s occurred in this quarter. Deviation has been reported on:

Submitted by:

Title / Position: Signature:

Date:

Phone:Brickcraft, LLC Page 47 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney



### INDIANA DEPARTMENT OF EN VIRONMENTAL MANAGEMENT
OFFICE OF AIR QUALITY

COMPLIANCE AND EN FORCEMENT BRANCH

PART 70 OPERATING PERMIT
QUARTERLY DEVIATION AND COMP LIANCE MONITORING REPORT

Source Name: Brickcraft, LLC Source Address: 200 North SR 59, Center Point, Indiana 47840

Part 70 Permit No.: T021-23323-00054



## Months: to Year:

Page 1 of 2

This report shall be submitted quarterly based on a calendar year. Any deviation from the requirements of this permit, 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 OCC URRED THIS R EPORTING 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:Brickcraft, LLC Page 48 of 48 Center Point, Indiana T021-23323-00054 Permit Reviewer: John Haney

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:

### Attachment B to Part 70 Operating Permit No. T021-23323-00054

Brickcraft, LLC 200 North SR 59, Center Point, IN 47840

Title 40: Protection of Environment Subpart OOO—Standards of Performance for Nonmetallic Mineral Processing Plants

Source: 74 FR 19309, Apr. 28, 2009, unless otherwise noted.

§ 60.670 Applicability and desi gnation of affected facility.

(a)(1) Except as provided in paragraphs (a)(2), (b), (c), and (d) of this section, the prov isions of this subpart are applicable to the following affected facilities in fixed or portable nonmetallic mineral pr ocessing plants: each crusher, grinding mill, screening operation, bucket elevator, belt conveyor, bagging operation, st orage bin, enclosed truck or railcar loading station. Also, crushers and grinding mills at hot mix asphalt facilities that reduce the size of nonmetallic minerals embedded in recycled asphalt pavement and subsequent affected facilities up to, but not including, the first storage silo or bin are subject to the provisions of this subpart.

(2) The provisions of this subpart do not apply to the foll owing operations: All facilities located in underground mines; plants without crushers or grinding mills above ground; and wet material processing operations (as defined in §60.671).

(b) An affected facility that is subject to the provisions of su bparts F or I of this part or that follows in the plant process any facility subject to the provisions of subparts F or I of this part is not subject to the provisions of this subpart.

(c) Facilities at the following plants are not subject to the provisions of this subpart:

(1) Fixed sand and gravel plants and crushed stone plants with capacities, as defined in §60.671, of 23 megagrams per hour (25 tons per hour) or less;

(2) Portable sand and gravel plants and crushed stone plan ts with capacities, as defined in §60.671, of 136 megagrams per hour (150 tons per hour) or less; and

(3) Common clay plants and pumice plants with capacities, as defined in §60.671, of 9 megagrams per hour (10 tons per hour) or less.

(d)(1) When an existing facility is replaced by a piece of equip ment of equal or smaller size, as defined in §60.671, having the same function as the existing facility, and there is no increase in t he amount of emissions, the new facility is exempt from the provisions of §§60. 672, 60.674, and 60.675 except as provi ded for in paragraph (d)(3) of this

section.

(2) An owner or operator complying with paragraph (d)(1) of this section shall submit the information required in §60.676(a).

(3) An owner or operator replacing all existing facilities in a production line with new facilities does not qualify for the exemption described in paragraph (d)(1) of this section a nd must comply with the prov isions of §§60.672, 60.674 and

60.675.

(e) An affected facility under paragraph (a) of this se ction that commences construction, modification, or reconstruction after August 31, 1983, is subject to the requirements of this part.

(f) Table 1 of this subpart specifies the provisions of subpart A of this part 60 that do not apply to owners and operators of affected facilities subject to this subpart or that apply with certain exceptions.

§ 60.671 Definitions.

All terms used in this subpart, but not specifically defined in this section, shall have the meaning given them in the Act and in subpart A of this part.Brickcraft, LLC Attachment B Page 2 of 12 Center Point, Indiana 40 CFR 60, Subpart OOO T021-23323-00054 Permit Reviewer: John Haney

Bagging operation means the mechanical process by which bags are filled with nonmetallic minerals.

Belt conveyor means a conveying device that transports material from one location to another by means of an

endless belt that is carried on a series of id lers and routed around a pulley at each end.

Bucket elevator means a conveying device of nonmetallic minerals consisting of a head and foot assembly which supports and drives an endless single or double strand chain or belt to which buckets are attached.

Building means any frame structure with a roof.

Capacity means the cumulative rated capacity of all initial crushers that are part of the plant.

Capture system means the equipment (including enclosures, hoods, ducts, fans, dampers, etc.) used to capture and transport particulate matter generated by one or more affected facilities to a control device.

Control device means the air pollution control equipment used to reduce particulate matter emissions released to the atmosphere from one or more affected facilit ies at a nonmetallic mineral processing plant.

Conveying system means a device for transporting materials from one piece of equipment or location to another location within a plant. Conveying systems include but are not limited to the following: Feeders, belt conveyors, bucket elevators and pneumatic systems.

Crush or Crushing means to reduce the size of nonmetallic mineral ma terial by means of physical impaction of the crusher or grinding mill upon the material.

Crusher means a machine used to crush any nonmetallic minerals, and includes, but is not limited to, the following types: Jaw, gyratory, cone, roll, rod mill, hammermill, and impactor.

Enclosed truck or railcar loading station means that portion of a nonmetallic mineral processing plant where nonmetallic minerals are loaded by an enclosed convey ing system into enclosed trucks or railcars.

Fixed plant means any nonmetallic mineral processing plant at which the processing equipment specified in §60.670(a) is attached by a cable, chain, turnbuckle, bol t or other means (except electrical connections) to any anchor, slab, or structure including bedrock.

Fugitive emission means particulate matter that is not collected by a capture system and is released to the atmosphere at the poi nt of generation.

Grinding mill means a machine used for the wet or dry fine cr ushing of any nonmetallic mineral. Grinding mills include, but are not limited to, the followi ng types: Hammer, roller, rod, pebble and ball, and fluid energy. The grinding mill includes the air conveying system, air separator, or air classifier, where such systems are used.

Initial crusher means any crusher into which nonmetallic minerals can be fed without prior crushing in the plant.

Nonmetallic mineral means any of the following minerals or any mixture of which the majority is any of the following

minerals:

(1) Crushed and Broken Stone, including Limestone, Dolomi te, Granite, Traprock, Sandstone, Quartz, Quartzite, Marl, Marble, Slate, Shale, Oil Shale, and Shell.

(2) Sand and Gravel.

(3) Clay including Kaolin, Fireclay, Bentonite, Fuller's Earth, Ball Clay, and Common Clay.

(4) Rock Salt.

(5) Gypsum (natural or synthetic).

(6) Sodium Compounds, including Sodium Carbo nate, Sodium Chloride, and Sodium Sulfate.

(7) Pumice.Brickcraft, LLC Attachment B Page 3 of 12 Center Point, Indiana 40 CFR 60, Subpart OOO T021-23323-00054 Permit Reviewer: John Haney

(8) Gilsonite.

(9) Talc and Pyrophyllite.

(10) Boron, including Borax, Kernite, and Colemanite.

(11) Barite.

(12) Fluorospar.

(13) Feldspar.

(14) Diatomite.

(15) Perlite.

(16) Vermiculite.

(17) Mica.

(18) Kyanite, including Andalusite, Sillimanite, Topaz, and Dumortierite.

Nonmetallic mineral processing plant means any combination of equipment t hat is used to crush or grind any nonmetallic mineral wherever located, including lime plants, power plants, steel mills, asphalt concrete plants, portland cement plants, or any other facility processing nonmetallic minerals except as provided in §60.670 (b) and (c).

Portable plant means any nonmetallic mineral processing plant t hat is mounted on any chassis or skids and may be moved by the application of a lifting or pulling force. In addition, there shall be no cable, chain, turnbuckle, bolt or other means (except electrical connections) by which any pi ece of equipment is attached or clamped to any anchor, slab, or structure, including bedrock t hat must be removed prior to the applicat ion of a lifting or pulling force for the purpose of transporting the unit.

Production line means all affected facilities (crushers, grinding mi lls, screening operations, bucket elevators, belt conveyors, bagging operations, storage bins, and enclosed truck and railcar loading stations) which are directly

connected or are connected t ogether by a conveying system.

Saturated material means, for purposes of this subpart, mineral materi al with sufficient surfac e moisture such that particulate matter emissions are not generated from pr ocessing of the material through screening operations, bucket elevators and belt conveyors. Material that is wetted so lely by wet suppression systems is not considered to be “saturated” for purposes of this definition.

Screening operation means a device for separating material according to size by passing undersize material through one or more mesh surfaces (screens) in series, and retaini ng oversize material on the mesh surfaces (screens). Grizzly feeders associated with truck dumping and static (non-moving) grizzlies used anywhere in the nonmetallic mineral processing plant are not c onsidered to be screening operations.

Seasonal shut down means shut down of an affected facility for a period of at least 45 consecutive days due to

weather or seasonal market conditions.

Size means the rated capacity in tons per hour of a crus her, grinding mill, bucket elevator, bagging operation, or enclosed truck or railcar loading station; the total surface area of the top screen of a screening operation; the width of a conveyor belt; and the rated capacity in tons of a storage bin.

Stack emission means the particulate matter that is released to the atmosphere from a capture system.

Storage bin means a facility for storage (including surge bins) of nonmetallic minerals prior to further processing or loading.

Transfer point means a point in a conveying operation where the nonm etallic mineral is transferred to or from a belt conveyor except where the nonmetallic mine ral is being transferred to a stockpile.Brickcraft, LLC Attachment B Page 4 of 12 Center Point, Indiana 40 CFR 60, Subpart OOO T021-23323-00054 Permit Reviewer: John Haney

Truck dumping means the unloading of nonmetallic minerals from mo vable vehicles designed to transport nonmetallic

minerals from one location to another. Movable vehicles incl ude but are not limited to: Tr ucks, front end loaders, skip hoists, and railcars.

Vent means an opening through which there is mechanically i nduced air flow for the purpose of exhausting from a building air carrying particulate matter emissions from one or more affected facilities.

Wet material processing operation(s) means any of the following:

(1) Wet screening operations (as defined in this section) and subsequent screening operations, bucket elevators and belt conveyors in the production line that process saturated materials (as define d in this section) up to the first crusher, grinding mill or storage bin in the production line; or

(2) Screening operations, bucket elevators and belt conveyor s in the production line downstream of wet mining operations (as defined in this section) that process saturate d materials (as defined in this section) up to the first crusher, grinding mill or stora ge bin in the production line.

Wet mining operation means a mining or dredging operation design ed and operated to extract any nonmetallic mineral regulated under this subpart from deposits existing at or below the water table, where the nonmetallic mineral

is saturated with water.

Wet screening operation means a screening operation at a nonmetallic mineral processing plant which removes unwanted material or which separates marketable fines from the product by a washing process which is designed and operated at all times such that t he product is saturated with water.

§ 60.672 Standard for particulate matter (PM).

(a) Affected facilities must meet the stack emission limits and compliance requirements in Table 2 of this subpart within 60 days after achieving the maximum production rate at which the affected facility will be operated, but not later than 180 days after initial startup as required under §60.8. The requirements in Table 2 of this subpart apply for affected facilities with capture systems used to captur e and transport particulate matter to a control device.

(b) Affected facilities must meet the fugitive emission limi ts and compliance requirements in Table 3 of this subpart within 60 days after achieving the maximum production rate at which the affected facility will be operated, but not later than 180 days after initial startup as required under §60.11. The requirements in Table 3 of this subpart apply for fugitive emissions from affected facilities without capt ure systems and for fugitive emissions escaping capture
systems.

(c) [Reserved]

(d) Truck dumping of nonmetallic minerals into any screening operation, feed hopper, or cr usher is exempt from the requirements of this section.

(e) If any transfer point on a conveyor belt or any other affe cted facility is enclosed in a building, then each enclosed affected facility must comply with the emission limits in paragraphs (a) and (b) of this section, or the building enclosing the affected facility or facilities must comply with the following emission limits:

(1) Fugitive emissions from the building openings (except fo r vents as defined in §60.671) must not exceed 7 percent opacity; and

(2) Vents (as defined in §60.671) in the building must meet the applicable stack emission limits and compliance requirements in Table 2 of this subpart.

(f) Any baghouse that controls emissions from only an indi vidual, enclosed storage bin is exempt from the applicable stack PM concentration limit (and associated performance te sting) in Table 2 of this subpart but must meet the applicable stack opacity limit and compliance requirements in Table 2 of this subpart. This exemption from the stack PM concentration limit does not apply for multip le storage bins with combined stack emissions.

§ 60.673 Reconstruction.

(a) The cost of replacement of ore-c ontact surfaces on processing equipment shall not be considered in calculating either the “fixed capital cost of the ne w components” or the “fixed capital cost that would be required to construct aBrickcraft, LLC Attachment B Page 5 of 12 Center Point, Indiana 40 CFR 60, Subpart OOO T021-23323-00054 Permit Reviewer: John Haney

comparable new facility” under §60.15. Or e-contact surfaces are crushing surf aces; screen meshes, bars, and plates; conveyor belts; and elevator buckets.

(b) Under §60.15, the “fixed capital cost of the new components” includes the fixed capital cost of all depreciable components (except components specified in paragraph (a) of this section) which are or will be replaced pursuant to all continuous programs of component re placement commenced within any 2-year period following August 31, 1983.

§ 60.674 Monitoring of operations.

(a) The owner or operator of any affected facility subject to the provisions of this subpart which uses a wet scrubber to control emissions shall install, calibrate, ma intain and operate the following monitoring devices:

(1) A device for the continuous measur ement of the pressure loss of the gas stream through the scrubber. The monitoring device must be certified by the manufacturer to be accurate within ±250 pascals ±1 inch water gauge pressure and must be calibrated on an annual basis in accordance with manufacturer's instructions.

(2) A device for the continuous measurem ent of the scrubbing liquid flow rate to the wet scrubber. The monitoring device must be certified by the manufacturer to be accurate within ±5 percent of design scrubbing liquid flow rate and

must be calibrated on an annual basis in accordance with manufacturer's instructions.

(b) The owner or operator of any affected facility for whic h construction, modification, or reconstruction commenced on or after April 22, 2008, that uses wet suppression to control emissions from the affected facility must perform monthly periodic inspections to check that water is flowi ng to discharge spray nozzles in the wet suppression system. The owner or operator must initiate corrective action within 24 hours and complete corrective action as expediently as practical if the owner or operator finds that water is not flowing properly during an inspection of the water spray nozzles. The owner or operator must record each inspection of the water spray nozzles, including the date of each inspection and any corrective actions taken, in the logbook required under §60.676(b).

(1) If an affected facility relies on water carryover from upstream water sprays to control fugitive emissions, then that affected facility is exempt from the 5-year repeat testing requirement specified in Table 3 of this subpart provided that the affected facility meets the criteria in pa ragraphs (b)(1)(i) and (ii) of this section:

(i) The owner or operator of the affected facility conducts per iodic inspections of the upstream water spray(s) that are responsible for controlling fugitive emissions from the affe cted facility. These inspections are conducted according to paragraph (b) of this section and §60.676(b), and

(ii) The owner or operator of the affected facility desi gnates which upstream water spray(s) will be periodically inspected at the time of the initial performance test r equired under §60.11 of this part and §60.675 of this subpart.

(2) If an affected facility that routinely uses wet suppression water sprays ceases operation of the water sprays or is using a control mechanism to reduce fugitive emissions ot her than water sprays during the monthly inspection (for example, water from recent rainfall), the logbook entry re quired under §60.676(b) must specify the control mechanism being used instead of the water sprays.

(c) Except as specified in paragraph (d) or (e) of this sect ion, the owner or operator of any affected facility for which construction, modification, or reconstruction commenced on or after April 22, 2008, that uses a baghouse to control emissions must conduct quarterly 30-minute visible emi ssions inspections using EPA Method 22 (40 CFR part 60, Appendix A–7). The Method 22 (40 CFR part 60, Appendix A–7) test shall be conducted while the baghouse is operating. The test is successful if no visible emissions are observed. If any visible emissions are observed, the owner or operator of the affected facility must initiate corrective action within 24 hours to return the baghouse to normal operation. The owner or operator must record each Method 22 (40 CFR part 60, Appendix A–7) test, including the date and any corrective actions taken, in the logbook required under §60.67 6(b). The owner or operator of the affected facility may establish a different baghouse-specific success level for the visible emissions test (other than no visible emissions) by conducting a PM performance test ac cording to §60.675(b) simultaneously with a Method 22 (40 CFR part 60, Appendix A–7) to determine what constitute s normal visible emissions from that affected facility's baghouse when it is in compliance with the applicable PM concentration limit in Table 2 of this subpart. The revised visible emissions success level must be incorporat ed into the permit for the affected facility.

(d) As an alternative to the periodic Method 22 (40 CFR part 60, Appendix A–7) visible emissions inspections specified in paragraph (c) of this sect ion, the owner or operator of any a ffected facility for which construction, modification, or reconstruction commenced on or after April 22, 2008, that uses a baghou se to control emissions mayBrickcraft, LLC Attachment B Page 6 of 12 Center Point, Indiana 40 CFR 60, Subpart OOO T021-23323-00054 Permit Reviewer: John Haney

use a bag leak detection system. The owner or operator mu st install, operate, and mainta in the bag leak detection system according to paragraphs (d)(1) through (3) of this section.

(1) Each bag leak detection system mu st meet the specifications and requir ements in paragraphs (d)(1)(i) through (viii) of this section.

(i) The bag leak detection system must be certified by the manufacturer to be capable of detecting PM emissions at concentrations of 1 milligram per dry standard cubic me ter (0.00044 grains per actual cubic foot) or less.

(ii) The bag leak detection system sensor must provide output of relative PM loadings. The owner or operator shall continuously record the output from the bag leak detection system using electronic or other means ( e.g. , using a strip chart recorder or a data logger).

(iii) The bag leak detection system must be equipped with an alarm system that will so und when the system detects an increase in relative particulate loading over the alarm se t point established according to paragraph (d)(1)(iv) of this
section, and the alarm must be located such that it can be heard by the ap propriate plant personnel.

(iv) In the initial adjustment of the bag leak detection system, the owner or operat or must establish, at a minimum, the baseline output by adjusting the sensitivity (range) and the averaging period of the devic e, the alarm set points, and the alarm delay time.

(v) Following initial adjustment, the owner or operator shall not adjust the averaging period, alarm set point, or alarm delay time without approval from the Administrator or delega ted authority except as provi ded in paragraph (d)(1)(vi) of

this section.

(vi) Once per quarter, the owner or operator may adjust the sensitivity of the bag leak detection system to account for seasonal effects, including temperature and humidity, ac cording to the procedures identified in the site-specific monitoring plan required by paragraph (d)(2) of this section.

(vii) The owner or operator must in stall the bag leak detection sensor downstream of the fabric filter.

(viii) Where multiple detectors are requ ired, the system's instrumentation and alarm may be shared among detectors.

(2) The owner or operator of the affected facility must deve lop and submit to the Administrator or delegated authority for approval of a site-specific monitoring plan for each b ag leak detection system. The owner or operator must operate and maintain the bag leak detection system according to the site-specific monitoring plan at all times. Each monitoring plan must describe the items in paragr aphs (d)(2)(i) through (vi) of this section.

(i) Installation of the bag leak detection system;

(ii) Initial and periodic adjustment of the bag leak detection system, incl uding how the alarm set-point will be established;

(iii) Operation of the bag leak detection system, including quality assurance procedures;

(iv) How the bag leak detection system will be maintained , including a routine maintenance schedule and spare parts inventory list;

(v) How the bag leak detection system output will be recorded and stored; and

(vi) Corrective action procedures as specified in paragraph (d)(3) of this section. In approving the site-specific monitoring plan, the Administrator or delegated authority may allow owners and operators more than 3 hours to alleviate a specific condition that c auses an alarm if the owner or operator identifies in the monitoring plan this specific condition as one that could lead to an alarm, ade quately explains why it is not feasible to alleviate this condition within 3 hours of the time the alarm occurs, and dem onstrates that the requested time will ensure alleviation of this condition as expeditiously as practicable.

(3) For each bag leak detection system, the owner or operat or must initiate procedures to determine the cause of every alarm within 1 hour of the alarm. Except as provid ed in paragraph (d)(2)(vi) of this section, the owner or operator must alleviate the cause of the alarm within 3 hour s of the alarm by taking whatever corrective action(s) are necessary. Corrective actions may include, but are not limited to the following:Brickcraft, LLC Attachment B Page 7 of 12 Center Point, Indiana 40 CFR 60, Subpart OOO T021-23323-00054 Permit Reviewer: John Haney

(i) Inspecting the fabric filter for air leaks, torn or broken bags or filter media, or any other condition that may cause an increase in PM emissions;

(ii) Sealing off defective bags or filter media;

(iii) Replacing defective bags or filter m edia or otherwise repairing the control device;

(iv) Sealing off a defective fabric filter compartment;

(v) Cleaning the bag leak detection system probe or ot herwise repairing the bag leak detection system; or

(vi) Shutting down the process producing the PM emissions.

(e) As an alternative to the periodic Method 22 (40 CFR part 60, Appendix A–7) visible emissions inspections specified in paragraph (c) of this sect ion, the owner or operator of any a ffected facility that is subject to the requirements for processed stone handling operations in the Lime Manufacturing NESHAP (40 CFR part 63, subpart AAAAA) may follow the continuous compliance requirements in row 1 items (i) through (iii) of Table 6 to Subpart AAAAA of 40 CFR part 63.

§ 60.675 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 appendices A–1 throu gh A–7 of this part or other methods and procedures as specified in this section, except as provided in §60.8(b). Acceptable alternativ e methods and procedures are given in paragraph (e) of this section.

(b) The owner or operator shall determine compliance wi th the PM standards in §60.672(a) as follows:

(1) Except as specified in paragraphs (e)(3) and (4) of this section, Method 5 of Appendi x A–3 of this part or Method 17 of Appendix A–6 of this part shall be used to determine the particulate matter concentration. The sample volume shall be at least 1.70 dscm (60 dscf). For Method 5 (40 CFR part 60, Appendix A–3), if the gas stream being sampled is at ambient temperature, the sampli ng probe and filter may be operated withou t heaters. If the gas stream is above ambient temperature, the sampling pro be and filter may be operated at a tem perature high enough, but no higher than 121 °C (250 °F), to prevent water condensation on the filter.

(2) Method 9 of Appendix A–4 of this part and the proc edures in §60.11 shall be used to determine opacity.

(c)(1) In determining compliance with the particulate matter standards in §60.672(b) or § 60.672(e)(1), the owner or operator shall use Method 9 of Appendix A–4 of this part and the procedures in §60.11, with the following additions:

(i) The minimum distance between the observer and the emission source shall be 4.57 meters (15 feet).

(ii) The observer shall, when possible, select a position that minimizes interference from other fugitive emission sources ( e.g., road dust). The required observer position relative to the sun (Method 9 of Appendix A–4 of this part, Section 2.1) must be followed.

(iii) For affected facilities using wet dust suppression for pa rticulate matter control, a visible mist is sometimes generated by the spray. The water mist must not be conf used with particulate matter emissions and is not to be

considered a visible emission. When a water mist of this nature is present, the observation of emissions is to be made at a point in the plume where the mist is no longer visible.

(2)(i) In determining compliance with the opacity of stack emissions from any baghouse t hat controls emissions only from an individual enclosed storage bin under §60.672(f) of this subpart, using Method 9 (40 CFR part 60, Appendix A–4), the duration of the Method 9 (40 CFR part 60, Appendix A–4) observations shall be 1 hour (ten 6-minute averages).

(ii) The duration of the Method 9 ( 40 CFR part 60, Appendix A–4) observati ons may be reduced to the duration the affected facility operates (but not less than 30 minutes) for baghouses that control storage bins or enclosed truck or railcar loading stations that oper ate for less than 1 hour at a time.

(3) When determining compliance with the fugitive em issions standard for any affected facility described under §60.672(b) or §60.672(e)(1) of this subpart, the duration of the Met hod 9 (40 CFR part 60, Appendix A–4)Brickcraft, LLC Attachment B Page 8 of 12 Center Point, Indiana 40 CFR 60, Subpart OOO T021-23323-00054 Permit Reviewer: John Haney

observations must be 30 minutes (five 6-minute averages). Co mpliance with the applicable fugitive emission limits in Table 3 of this subpart must be based on th e average of the five 6-minute averages.

(d) To demonstrate compliance with the fugitive emission limi ts for buildings specified in §60.672(e)(1), the owner or operator must complete the testing specified in paragraph (d )(1) and (2) of this section. Performance tests must be conducted while all affected facilities inside the building are operating.

(1) If the building encloses any affected facility that comme nces construction, modification, or reconstruction on or after April 22, 2008, the owner or operat or of the affected facility must con duct an initial Method 9 (40 CFR part 60, Appendix A–4) performance test according to this section and §60.11.

(2) If the building encloses only affected facilities that co mmenced construction, modification, or reconstruction before April 22, 2008, and the owner or operator has previously conducted an initial Method 22 (40 CFR part 60, Appendix A–7) performance test showing zero visible emissions, th en the owner or operator has demonstrated compliance with the opacity limit in §60.672(e)(1). If t he owner or operator has not conducte d an initial performance test for the building before April 22, 2008, then the owner or operat or must conduct an initial Method 9 (40 CFR part 60, Appendix A–4) performance test according to this section and §60.11 to show compliance with the opacity limit in §60.672(e)(1).

(e) The owner or operator may use the following as alternat ives to the reference methods and procedures specified in

this section:

(1) For the method and procedure of paragraph (c) of this section, if emissions from two or more facilities continuously interfere so that the op acity of fugitive emissions from an i ndividual affected facility cannot be read, either of the following procedures may be used:

(i) Use for the combined emission stream the highest fugiti ve opacity standard applicable to any of the individual affected facilities contributing to the emissions stream.

(ii) Separate the emissions so that the opacity of emissions from each affected facility can be read.

(2) A single visible emission observer may conduct visible emission observations for up to three fugitive, stack, or vent emission points within a 15-second inte rval if the following conditions are met:

(i) No more than three emission points may be read concurrently.

(ii) All three emission points must be within a 70 degree viewi ng sector or angle in front of the observer such that the proper sun position can be maintained for all three points.

(iii) If an opacity reading for any one of the three emission points equals or exceeds the applicable standard, then the observer must stop taking readings for the other two points and continue reading just that single point.

(3) Method 5I of Appendix A–3 of this part may be used to determine the PM concentration as an alternative to the methods specified in paragraph (b)(1) of this section. Me thod 5I (40 CFR part 60, Appendix A–3) may be useful for affected facilities that operate for less than 1 hour at a time such as (but not lim ited to) storage bins or enclosed truck or railcar loading stations.

(4) In some cases, velocities of ex haust gases from building vents may be too low to measure accurately with the type S pitot tube specified in EPA Method 2 of Appendix A–1 of this part [ i.e., velocity head <1.3 mm H 2 O (0.05 in.

H 2 O)] and referred to in EPA Method 5 of Appendix A–3 of this part. For these conditions, the owner or operator may determine the average gas flow rate produced by the power fans ( e.g., from vendor-supplied fan curves) to the building vent. The owner or operator may calculate the aver age gas velocity at the building vent measurement site using Equation 1 of this section and use this average ve locity in determining and maintaining isokinetic sampling

rates.Brickcraft, LLC Attachment B Page 9 of 12 Center Point, Indiana 40 CFR 60, Subpart OOO T021-23323-00054 Permit Reviewer: John Haney

Where:

V e = average building vent velocity (feet per minute);
Q f = average fan flow rate (cubic feet per minute); and

A e = area of building vent and measur ement location (square feet).

(f) To comply with §60.676(d), the owner or operator sha ll record the measurements as required in §60.676(c) using the monitoring devices in §60.674 (a)(1) and (2) during each particulate matter run and shall determine the averages.

(g) For performance tests involving only Method 9 (40 CFR par t 60 Appendix A–4) testing, the owner or operator may reduce the 30-day advance notification of performance test in §60.7(a)(6) and 60.8 (d) to a 7-day advance notification.

(h) [Reserved]

(i) If the initial performance test date for an affected facili ty falls during a seasonal shut down (as defined in §60.671 of this subpart) of the affected facility, then with approv al from the permitting authority, the owner or operator may postpone the initial performance test until no later than 60 calendar days afte r resuming operation of the affected facility.

§ 60.676 Reporting and recordkeeping.

(a) Each owner or operator seeking to comply with §60. 670(d) shall submit to the Administrator the following information about the existing facility being r eplaced and the replacement piece of equipment.

(1) For a crusher, grinding mill, bucket elevator, bagging op eration, or enclosed truck or railcar loading station:

(i) The rated capacity in megagrams or tons per hour of the existing facility being replaced and

(ii) The rated capacity in tons per hour of the replacement equipment.

(2) For a screening operation:

(i) The total surface area of the top screen of t he existing screening operation being replaced and

(ii) The total surface area of the top scr een of the replacement screening operation.

(3) For a conveyor belt:

(i) The width of the existing belt being replaced and

(ii) The width of the replacement conveyor belt.

(4) For a storage bin:

(i) The rated capacity in megagrams or tons of the existing storage bin being replaced and

(ii) The rated capacity in megagrams or tons of replacement storage bins.

(b)(1) Owners or operators of affected facilities (as def ined in §§60.670 and 60.671) for which construction, modification, or reconstruction commenced on or after Apr il 22, 2008, must record each periodic inspection required under §60.674(b) or (c), including dates and any correctiv e actions taken, in a logbook (in written or electronic format). The owner or operator must keep the logbook ons ite and make hard or electronic copies (whichever is requested) of the logbook available to the Administrator upon request.

(2) For each bag leak detection system installed and operat ed according to §60.674(d), the owner or operator must keep the records specified in paragraphs (b )(2)(i) through (iii) of this section.

(i) Records of the bag leak detection system output;Brickcraft, LLC Attachment B Page 10 of 12 Center Point, Indiana 40 CFR 60, Subpart OOO T021-23323-00054 Permit Reviewer: John Haney

(ii) Records of bag leak detection syst em adjustments, including the date and time of the adjustment, the initial bag leak detection system settings, and the fina l bag leak detection system settings; and

(iii) The date and time of all bag leak detection system alarms, the time that pr ocedures to determine the cause of the
alarm were initiated, the caus e of the alarm, an explanation of the actions taken, the da te and time the cause of the alarm was alleviated, and whether t he cause of the alarm was alleviated within 3 hours of the alarm.

(3) The owner or operator of each affected facility demonstr ating compliance according to §60.674(e) by following the requirements for processed stone handling operations in the Lime Manufacturing NESHAP (40 CFR part 63, subpart AAAAA) must maintain records of visible emissions obser vations required by §63.7132(a)(3) and (b) of 40 CFR part 63, subpart AAAAA.

(c) During the initial performance test of a wet scrubber, and daily thereafter, the owner or operator shall record the measurements of both the change in pr essure of the gas stream across th e scrubber and the scrubbing liquid flow

rate.

(d) After the initial performance test of a wet scrubber, the ow ner or operator shall submit semiannual reports to the

Administrator of occurrences when the measurements of t he scrubber pressure loss and liquid flow rate decrease by more than 30 percent from the average determi ned during the most recent performance test.

(e) The reports required under paragraph (d) of this sect ion shall be postmarked within 30 days following end of the second and fourth calendar quarters.

(f) The owner or operator of any affected facility shall submit written reports of the results of all performance tests conducted to demonstrate compliance wi th the standards set forth in §60.672 of this subpart, including reports of opacity observations made using Method 9 (40 CFR part 60, Appendix A–4) to demonstrate compliance with §60.672(b), (e) and (f).

(g) The owner or operator of any wet material processi ng operation that processe s saturated and subsequently processes unsaturated materials, shall s ubmit a report of this change within 30 days following such change. At the time of such change, this screening operation, bucket elev ator, or belt conveyor becomes subject to the applicable opacity limit in §60.672(b) and the em ission test requirements of §60.11.

(h) The subpart A requirement under §60.7(a)(1) for notific ation of the date construction or reconstruction commenced is waived for affected facilities under this subpart.

(i) A notification of the actual date of initial st artup of each affected facility shall be submitted to the Administrator.

(1) For a combination of affected facilities in a production line that begin actual initia l startup on the same day, a single notification of star tup may be submitted by the owner or operator to the Administrator. The notification shall be postmarked within 15 days after such date and shall incl ude a description of each affected facility, equipment manufacturer, and serial number of the equipment, if available.

(2) For portable aggregate processing plants, the notification of the actual date of initial startup shall include both the

home office and the current address or location of the portable plant.

(j) The requirements of this section remain in force until and unless the Agency, in delegating enforcement authority to a State under section 111(c) of the Act, approves reporting requirements or an alternative means of compliance surveillance adopted by such States. In that event, affected facilities within the State will be relieved of the obligation to comply with the reporting requirements of this section, pr ovided that they comply with requirements established by

the State.

(k) Notifications and reports required under this subpart an d under subpart A of this part to demonstrate compliance with this subpart need only to be sent to the EPA Region or the State which has been de legated authority according to §60.4(b).Brickcraft, LLC Attachment B Page 11 of 12 Center Point, Indiana 40 CFR 60, Subpart OOO T021-23323-00054 Permit Reviewer: John Haney

Table 1 to Subpart OOO—Exceptions to App licability of Subpart A to Subpart OOO

Subpart A reference Applies

to subpart

OOO Explanation

60.4, Address Yes Except in §60.4(a) and (b ) submittals need not be submitted to both the EPA Region and delegated Stat e authority (§60.676(k)).

60.7, Notification and recordkeeping Yes Except in (a)(1) notification of the date construction or reconstruction commenced (§60.676(h)).

Also, except in (a)(6) performan ce tests involving only Method 9 (40 CFR part 60, Appendix A–4) require a 7-day advance notification instead of 30 days (§60.675(g)).

60.8, Performance tests Yes Except in (d) perfo rmance tests involving only Method 9 (40 CFR part 60, Appendix A–4) require a 7-da y advance notification instead of 30 days (§60.675(g)).

60.11, Compliance with

standards and maintenance requirements Yes Except in (b) under certain conditions (§§60.675(c)), Method 9 (40 CFR part 60, Appendix A–4) observation is reduced from 3 hours to 30 minutes for fugitive emissions.

60.18, General control device No Flares will not be used to comply with the emission limits.

Table 2 to Subpart OOO—Stack Emission Limits fo r Affected Facilities With Capture Systems

For * * * The owner or
operator must

meet a PM limit

of * * * A nd the owner or
operator must meet an opacity limit of

* * * The owner or operator must demonstrate compliance with these limits by

conducting * * *

Affected facilities (as defined in §§60.670 and 60.671) that commenced construction, modification, or reconstruction after August 31, 1983 but before April 22, 2008 0.05 g/dscm (0.022 gr/dscf) a 7 percent for dry

control devices b An initial performance test according to §60.8 of this part and §60.675 of this subpart;

and Monitoring of wet scrubber parameters according to §60.674(a) and §60.676(c), (d), and (e).

Affected facilities (as defined in §§60.670 and 60.671) that commence construction, modification, or reconstruction on or after April 22, 2008 0.032 g/dscm (0.014 gr/dscf) a Not applicable (except for individual enclosed storage bins) 7 percent for dry

control devices on

individual enclosed storage bins An initial performance test according to §60.8 of this part and §60.675 of this subpart;

and Monitoring of wet scrubber parameters according to §60.674(a) and §60.676(c), (d), and (e); and

Monitoring of baghouses according to §60.674(c), (d), or (e) and §60.676(b).

a Exceptions to the PM limit apply for individual enclose d storage bins and other equipment. See §60.672(d) through (f).

b The stack opacity limit and associated opacity testing requirements do not apply for affected facilities using wet

scrubbers.Brickcraft, LLC Attachment B Page 12 of 12 Center Point, Indiana 40 CFR 60, Subpart OOO T021-23323-00054 Permit Reviewer: John Haney

Table 3 to Subpart OOO—Fugitive Emission Limits

For * * * The owner or operator must meet the following fugitive emissions limit for grinding mills, screening operations,

bucket elevators, transfer points on belt conveyors, bagging operations, storage bins, enclosed truck or railcar loading stations or from any

other affected facility (as defined in §§60.670 and 60.671) * * * The owner or
operator must

meet the following fugitive

emissions limit

for crushers at which a capture

system is not

used * * * The owner or operator must demonstrate compliance with these limits by conducting * * *

Affected facilities (as defined in §§60.670 and 60.671) that

commenced construction, modification, or

reconstruction after August 31, 1983 but before April 22, 2008 10 percent opacity 15 percent opacity An initial performance test according to §60.11 of this part and §60.675 of this subpart.

Affected facilities (as defined in §§60.670 and 60.671) that

commence construction, modification, or

reconstruction on or after April 22, 2008 7 percent opacity 12 percent opacity An in itial performance test according to §60.11 of this part and §60.675 of this subpart; and Periodic inspections of water sprays according to §60.674(b) and §60.676(b);

and

A repeat performance test according to §60.11 of this part and §60.675 of this subpart within 5 years from the previous performance test for fugitive emissions

from affected facilities without water sprays. Affected facilities controlled by water carryover from upstream water sprays that are inspected according to the requirements in §60.674(b) and §60.676(b) are exempt from this 5-year repeat testing requirement.

## Indiana Department of Environmental Management Office of Air Quality

Addendum to the Technical Support Document (ATSD) for a

Significant Source Modification to a Part 70 Source and a Part 70 Operating Permit

Source Background and Description

Source Name: Brickcraft, LLC Source Location: 200 North SR 59, Center Point, IN 47840 County: Clay

SIC Code: 3251 Minor Source Operation Permit (MSOP) No.: M021-18273-00054 MSOP Issuance Date: March 1, 2004 Significant Source Modification No.: 021-30024-00054 Part 70 Operation Permit No.: T021-23323-00054 Permit Reviewer: John Haney

On April 13, 2011, the Office of Air Quality (OAQ) had a notice published in the Brazil Times, Brazil, Indiana, stating that Brickcraft, LLC had applied for a significant source modification and Part 70 operating permit in order to transition from its MSOP to a Part 70 Operating Permit. The notice also stated that the OAQ proposed to issue a significant source modifi cation and Part 70 operating permit for this operation and provided information on how the public could revi ew the proposed permit and other documentation. Finally, the notice informed interested parties that t here was a period of thirty (30) days to provide comments on whether or not this permit should be issued as proposed.

Comments and Responses

On May 12, 2011, Brickcraft, LLC submitted comments to IDEM, OAQ on the significant source modification and Part 70 operating permit.

The Technical Support Document (TSD) is used by ID EM, OAQ for historical purposes. IDEM, OAQ does not make any changes to the original TSD, but the Permit will have the updated changes. The comments and revised permit language are provided bel ow with deleted language as strikeouts and new language

bolded

.

Comment 1:

The descriptive information in Sections A.2(b) and D.1(b) should be changed to reflect three outdoor aggregate storage piles as opposed to one pile.Brickcraft, LLC Page 2 of 4 Center Point, Indiana ATSD for Significant Source Modification No. 021-30024-00054 Permit Reviewer: John Haney ATSD for Part 70 Operating Permit No. T021-23323-00054

Response to Comment 1:

IDEM agrees with the recommended changes, since the potential throughput of the piles and all fugitive emission control requirements do not change. The permit has been revised as follows:

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 follo wing emission units and pollution control devices:

(a) One (1) quarry, constructed in 2004, with a capacity of 125 tons of shale per hour;

(b) One ( 1) Three (3) outdoor aggregate storage pile s , with a combined capacity of 125 tons of shale per hour.

* * *

SECTION D.1 EMISSIONS UNIT OPERATION CONDITIONS

Emissions Unit Description: Fugitive Emissions

(a) One (1) quarry, constructed in 2004, with a capacity of 125 tons of shale per hour;

(b) One (1) Three (3) outdoor aggregate storage pile s , with a combined capacity of 125 tons of shale per hour.

* * *

Comment 2:

When used to calculate actual emissions based on ma ss balance, it is incorrect to use capacity as a unit of measurement. The correct unit of measurement should be actual throughput. Therefore, Brickcraft, LLC requests that the definition of “C” in Conditions D.3.7 and D.3.8 be changed to “average hourly throughput of the tunnel kiln for the month defined by H DIFF and

H NON-DIFF ”.

Comment 3:

It is not clearly worded that the mass balance calculations in the Condition D.3.7 and D.3.8 formulas will be used only when the CEMS is not being used. Brickcraft, LLC requests that this be clarified by changing the definition of H DIFF and H NON-DIFF to state that this is the total number of hours per month the tunnel was controlled by or bypassed the DIFF when the CEMS is not used to measure the pollutant.

Comment 4:

There is an error in the definition of EF NON-DIFF in Conditions D.3.7 and D.3.8. The definition should state that it is when the pollutant is not controlled by the DIFF.

Response to Comments 2, 3, and 4:

IDEM agrees with the requested changes to Condi tions D.3.7 and D.3.8 since they are for clarification purposes. The permit has been revised as follows:Brickcraft, LLC Page 3 of 4 Center Point, Indiana ATSD for Significant Source Modification No. 021-30024-00054 Permit Reviewer: John Haney ATSD for Part 70 Operating Permit No. T021-23323-00054

D.3.7 Sulfur Dioxide (SO 2 )

* * *

where:

E TOTAL = combined total tons of SO 2 emissions per month

E

CEMS = total tons of SO 2 emissions per month from the tunnel kiln, as determined with the CEMS output C = capacity of the tunnel kiln, which equals 10 tons/hr average hourly throughput of the tunnel kiln for the month defined by H DIFF and H NON-DIFF EF DIFF = SO 2 emission factor from the tunnel kiln when controlled by the DIFF, which equals 5.41 lb/ton or the most recent valid compliance

demonstration

H

DIFF = total number of hours per month the tunnel kiln was controlled by the

DIFF when the CEMS is not used to measure SO 2 2000 = lb/ton

EF NON-DIFF = SO 2 emission factor from the tunnel kiln when controlled by bypassing the DIFF, which equals 25.0 lb/ton or the most recent valid compliance demonstration

H

NON-DIFF = total number of hours per month the tunnel kiln bypassed the DIFF

when the CEMS is not used to measure SO 2

D.3.8 Hydrogen Fluoride/Hydrofluoric Acid (HF)

* * *

where:

E TOTAL = combined total tons of HF emissions per month

E

CEMS = total tons of HF emissions per month from the tunnel kiln, as determined with the CEMS output C = capacity of the tunnel kiln, which equals 10 tons/hr average hourly throughput of the tunnel kiln for the month defined by H DIFF and H NON-DIFF EF DIFF = HF emission factor from the tunnel kiln when controlled by the DIFF, which equals 0.22 lb/ton or the most recent valid compliance

demonstration

H

DIFF = total number of hours per month the tunnel kiln was controlled by the

DIFF when the CEMS is not used to measure HF

2000 = lb/ton

EF NON-DIFF = HF emission factor from the tunnel kiln when co ntrolled by bypassing the DIFF, which equals 0.37 lb/ton or the most recent valid compliance demonstration

H

NON-DIFF = total number of hours per month the tunnel kiln bypassed the DIFF

when the CEMS is not used to measure HFBrickcraft, LLC Page 4 of 4 Center Point, Indiana ATSD for Significant Source Modification No. 021-30024-00054 Permit Reviewer: John Haney ATSD for Part 70 Operating Permit No. T021-23323-00054

Additional Changes

IDEM, OAQ has decided to make additional revisions to the permit as described below, with deleted language as strikeouts and new language bolded

.

(a) The headers of the calculations have been revi sed to clarify that they are part of the documentation for Operating Permit No.: T021-23323-00054 as well as Significant Source

Modification No.: 021-30024-00054. See Attachment A to the TSD Addendum for a detailed copy of the revisions.

The permit and its support documentation have been revised as follows:

Appendix A: Emission Calculations

* * * * *

Company Name: Brickcraft, LLC Address City IN Zip: 200 North SR 59, Center Point, IN 47840 Significant Source Modification No.: 021-30024-00054 Title V Operating Permit No.: T021-23323-00054

Plant ID: 021

- 00054 Reviewer: John Haney Date: March 29, 2011

IDEM Contact

(a) Questions regarding this proposed significant source modification and Part 70 operating permit can be directed to John Haney at the Indiana Department Environmental Management, Office of Air Quality, Permits Branch, 100 North Senate Avenue, MC 61-53 IGCN 1003, Indianapolis, Indiana 46204-2251 or by telephone at (317) 234-5328 or toll free at 1-800-451-6027 extension 4-

5328.

(b) A copy of the permit is available on the Internet at: http://www.in.gov/ai/appfiles/idem-caats/

(c) For additional information about air permits and how the public and interested parties can participate, refer to the IDEM’s Guide for Citizen Participation and Permit Guide on the Internet at: www.idem.in.govPage 1 of 13ATSD - Appendix AAppendix A: Emission CalculationsEmissions SummaryCompany Name:Brickcraft, LLCAddress City IN Zip:200 North SR 59, Center Point, IN 47840Significan Source Modification No:021-30024-00054Title V Operating Permit No:T021-23323-00054Reviewer:John HaneyDate:Uncontrolled Emissions (tons/year)PMPM10SO2NOxVOC COTotalFluoridesHF HClTotalHAPs1.31 0.65 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.0013.69 1.26 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.002.46 0.90 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.001.16 0.52 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.001.45 0.53 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.007.67 2.67 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.002.76 1.01 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.007.88 2.89 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.002.37 0.87 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00142.96 35.22 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.001.89 1.89 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.003.37 8.19 1.3116.21 38.11 1.05343.83 120.45 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.000.01 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00343.83 120.45 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.000.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Additive Feeder 0.08 0.03 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Surge Bin 0.26 0.10 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Texture Feeder 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Packaging 0.50 0.18 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Space Heaters 0.04 0.17 0.01 2.19 0.12 1.84 0.00 0.00 0.00 0.04Total Total 893.73 336.08 1095.01 17.52 2.49 54.40 25.84 16.21 7.45 24.13Limited Emissions (tons/year) with the Use of CEMSPMPM10SO2NOxVOC COTotalFluoridesHF HClTotalHAPs1.31 0.65 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.0013.69 1.26 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.002.46 0.90 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.001.16 0.52 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.001.45 0.53 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.007.67 2.67 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.002.76 1.01 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.007.88 2.89 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.002.37 0.87 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00142.96 35.22 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.001.89 1.89 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.003.37 8.19 1.3116.21 38.11 1.0521.90 77.09 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.000.01 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.0021.90 77.09 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.000.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Additive Feeder 0.08 0.03 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Surge Bin 0.26 0.10 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Texture Feeder 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Packaging 0.50 0.18 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Space Heaters 0.04 0.17 0.01 2.19 0.12 1.84 0.00 0.00 0.00 0.04Total Total 249.87 249.36 < 250 17.52 2.49 54.40 25.84 < 10 7.45 24.13Limited Emissions (tons/year) without the Use of CEMSPMPM10SO2NOxVOC COTotalFluoridesHF HClTotalHAPs1.31 0.65 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.0013.69 1.26 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.002.46 0.90 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.001.16 0.52 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.001.45 0.53 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.007.67 2.67 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.002.76 1.01 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.007.88 2.89 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.002.37 0.87 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00142.96 35.22 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.001.89 1.89 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.003.37 8.19 1.3116.21 38.11 1.0521.90 77.09 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.000.01 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.0021.90 77.09 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.000.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Additive Feeder 0.08 0.03 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Surge Bin 0.26 0.10 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Texture Feeder 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Packaging 0.50 0.18 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Space Heaters 0.04 0.17 0.01 2.19 0.12 1.84 0.00 0.00 0.00 0.04Total Total 249.87 249.36 249.21 17.52 2.49 54.40 25.84 9.73 7.45 24.13InsignificantActivitiesStorage BinsTransfer Conveyors (60-ton)PugmillExtrusionBrick DryerFinishing ScreenTransfer Conveyors (70-ton)Lime Silo - ReceivingLime Silo - DispensingBicarbonate Silo - ReceivingBicarbonate Silo - DispensingBicarbonate Silo - ReceivingBicarbonate Silo - DispensingInsignificantActivitiesEmission UnitsPrimary CrusherNatural Gas-Fired KilnGrinding/Scalping ScreenTransfer Conveyors (125-ton)Secondary CrusherTransfer Conveyor (110-ton)PugmillExtrusionBrick DryerNatural Gas-Fired KilnLime Silo - ReceivingLime Silo - DispensingSecondary CrusherTransfer Conveyor (110-ton)Finishing ScreenTransfer Conveyors (70-ton)Storage BinsTransfer Conveyors (60-ton)Bicarbonate Silo - DispensingEmission UnitsPrimary CrusherGrinding/Scalping ScreenInsignificantActivitiesTransfer Conveyors (125-ton)ExtrusionBrick DryerNatural Gas-Fired KilnLime Silo - ReceivingLime Silo - DispensingBicarbonate Silo - ReceivingEmission UnitsTransfer Conveyors (125-ton)Secondary CrusherTransfer Conveyor (110-ton)Transfer Conveyors (60-ton)Pugmill7.45 24.0924.091095.00 15.33 52.56 25.8452.56 25.84March 29, 2011< 24916.2115.33 < 10Finishing ScreenTransfer Conveyors (70-ton)Storage BinsPrimary CrusherGrinding/Scalping Screen7.45 24.097.45249.20 15.33 52.56 25.84 9.73Page 2 of 13ATSD - Appendix AAppendix A: Emission CalculationsAggregate Processing (125 TPH) Particulate EmissionsCompany Name:Brickcraft, LLCAddress City IN Zip:200 North SR 59, Center Point, IN 47840Significan Source Modification No:021-30024-00054Title V Operating Permit No:T021-23323-00054Reviewer:John HaneyDate:Process: Rate (tons/hr) PollutantControlledEmissionFactor(lb/ton)ControlledEmissions(tons/yr)Type of ControlControl Eff.(%)UncontrolledEmissions(tons/yr)Primary Crusher125 PM 0.0012 0.66 Baghouse 50.0 1.311.31 tons/yr * 2000 lb/ton÷8760 hr/yr = 0.300 lb/hrPM100.00059 0.32 Baghouse 50.0 0.65Source of Criteria Pollutant Factors:PM2.50.00059 0.32 Baghouse 50.0 0.65SCC# 3-05-020-03**, AP-42, Ch. 11.19, Table 11.19.2-2SCC# 3-05-003-40, AP-42, Ch. 11.3, Table 11.3-2** ControlledBH-1Methodology:Controlled Emissions (tons/yr) = Rate (tons/hr) x Controlled Emission Factor (lbs/ton) x 8760 hrs/yr÷2000 lbs/tonUncontrolled Emissions (tons/yr) = Controlled Emissions (tons/yr)÷(1 - Control Efficiency/100)Process: Rate (tons/hr) PollutantUncontrolledEmissionFactor(lb/ton)UncontrolledEmissions(tons/yr)Type of ControlControl Eff.(%)ControlledEmissions(tons/yr)Grinding and Screening125 PM 0.025 13.69 Baghouse 50.0 6.84P= 125 tons/hrPM100.0023 1.26 Baghouse 50.0 0.63limit = 55.0 x ( 125 ^0.11 )-= 53.5 lb/hr (allowable)Source of Criteria Pollutant Factors:PM2.50.0023 1.26 Baghouse 50.0 0.63SCC# 3-05-003-02**, AP-42, Ch. 11.3, Table 11.3-2with uncontrolled potential:13.69 tons/yr x 2000 lb/ton / 8760 hr/yr = 3.13 lb/hr (capable of complying)** Processing wet materialBH-1Methodology:Uncontrolled Emissions (tons/yr) = Rate (tons/hr) x Uncontrolled Emission Factor (lbs/ton) x 8760 hrs/yr÷2000 lbs/tonControlled Emissions (tons/yr) = Uncontrolled Emissions (tons/yr) x (1 - Control Efficiency/100)Process: Rate (tons/hr) PollutantUncontrolledEmissionFactor(lb/ton)UncontrolledEmissions(tons/yr)Number ofConveyorsTotalUncontrolledEmissions(tons/yr)Type of ControlControl Eff.(%)ControlledEmissions(tons/yr)Transfer Conveyors125 PM 0.003 1.64 3 4.93 Baghouse 50.0 2.46125 tons/hr * 0.003 lb/ton = 0.375 lb/hrPM100.0011 0.60 3 1.81 Baghouse 50.0 0.90Source of Criteria Pollutant Factors:PM2.50.0011 0.60 3 1.81 Baghouse 50.0 0.90SCC# 3-05-020-06**, AP-42, Ch. 11.19, Table 11.19.2-2** UncontrolledBH-1Methodology:Uncontrolled Emissions (tons/yr) = Rate (tons/hr) x Uncontrolled Emission Factor (lbs/ton) x 8760 hrs/yr÷2000 lbs/tonTotal Uncontrolled Emissions (tons/yr) = Uncontrolled Emissions (tons/yr) x Number of ConveyorsControlled Emissions = Total Uncontrolled Emissions (tons/yr) x (1 - Control Efficiency/100)Allowable Emissions:The primary crusher is exempt from 326 IAC 6-3-2 because the crusher has potential emissionsless than 0.551 lb/hr.Allowable Emissions:The following calculations determine PM compliance with 326 IAC 6-3-2 for process weight rates greater than 30 tons per hour:Allowable Emissions:Each conveyor is exempt from 326 IAC 6-3-2 because each conveyor has potentialemissions less than 0.551 lb/hr.March 29, 2011Page 3 of 13ATSD - Appendix AAppendix A: Emission CalculationsAggregate Processing (110 TPH) Particulate EmissionsCompany Name:Brickcraft, LLCAddress City IN Zip:200 North SR 59, Center Point, IN 47840Significan Source Modification No021-30024-00054Title V Operating Permit No:T021-23323-00054Reviewer:John HaneyDate:Process: Rate (tons/hr) PollutantControlledEmission Factor(lb/ton)ControlledEmissions(tons/yr)Type of ControlControl Eff.(%)UncontrolledEmissions(tons/yr)Secondary Crusher110 PM 0.0012 0.58 Baghouse 50.0 1.161.16 tons/yr * 2000 lb/ton÷8760 hr/yr = 0.264 lb/hrPM100.00054 0.26 Baghouse 50.0 0.52Source of Criteria Pollutant Factors:PM2.50.00054 0.26 Baghouse 50.0 0.52SCC# 3-05-020-03**, AP-42, Ch. 11.19, Table 11.19.2-2**Use tertiary crushing emission factorsBH-1Methodology:Controlled Emissions (tons/yr) = Rate (tons/hr) x Controlled Emission Factor (lbs/ton) x 8760 hrs/yr÷2000 lbs/tonUncontrolled Emissions (tons/yr) = Controlled Emissions (tons/yr)÷(1 - Control Efficiency/100)Process: Rate (tons/hr) PollutantUncontrolledEmission Factor(lb/ton)UncontrolledEmissions(tons/yr)Number ofConveyorsTotalUncontrolledEmissions(tons/yr)Type of ControlControl Eff.(%)ControlledEmissions(tons/yr)Transfer Conveyor110 PM 0.003 1.45 1 1.45 Baghouse 50.0 0.72110 tons/hr * 0.003 lb/ton = 0.330 lb/hrPM100.0011 0.53 1 0.53 Baghouse 50.0 0.26Source of Criteria Pollutant Factors:PM2.50.0011 0.53 1 0.53 Baghouse 50.0 0.26SCC# 3-05-020-06**, AP-42, Ch. 11.19, Table 11.19.2-2** UncontrolledBH-1Methodology:Uncontrolled Emissions (tons/yr) = Rate (tons/hr) x Uncontrolled Emission Factor (lbs/ton) x 8760 hrs/yr÷2000 lbs/tonTotal Uncontrolled Emissions (tons/yr) = Uncontrolled Emissions (tons/yr) x Number of ConveyorsControlled Emissions (tons/yr) = Total Uncontrolled Emissions (tons/yr) x (1 - Control Efficiency/100)Allowable Emissions:The secondary crusher is exempt from 326 IAC 6-3-2 because the crusher has potentialemissions less than 0.551 lb/hr.Allowable Emissions:Each conveyor is exempt from 326 IAC 6-3-2 because each conveyor has potentialemissions less than 0.551 lb/hr.March 29, 2011Page 4 of 13ATSD - Appendix AAppendix A: Emission CalculationsAggregate Processing (70 TPH) Particulate EmissionsCompany Name:Brickcraft, LLCAddress City IN Zip:200 North SR 59, Center Point, IN 47840Significan Source Modification No:021-30024-00054Title V Operating Permit No:T021-23323-00054Reviewer:John HaneyDate:Process: Rate (tons/hr) PollutantUncontrolledEmissionFactor(lb/ton)UncontrolledEmissions(tons/yr)Type of ControlControl Eff.(%)ControlledEmissions(tons/yr)Screening70 PM 0.025 7.67 Baghouse 50.0 3.83P= 70 tons/hrPM100.0087 2.67 Baghouse 50.0 1.33limit = 55.0 x ( 70 ^0.11 )-= 47.8 lb/hr (allowable)Source of Criteria Pollutant Factors:PM2.50.0087 2.67 Baghouse 50.0 1.33SCC# 3-05-020-03**, AP-42, Ch. 11.19, Table 11.19.2-2with uncontrolled potential:7.67 tons/yr x 2000 lb/ton / 8760 hr/yr = 1.75 lb/hr (capable of complying)** UncontrolledBH-1Methodology:Uncontrolled Emissions (tons/yr) = Rate (tons/hr) x Uncontrolled Emission Factor (lbs/ton) x 8760 hrs/yr÷2000 lbs/tonControlled Emissions (tons/yr) = Uncontrolled Emissions (tons/yr) x (1 - Control Efficiency/100)Process: Rate (tons/hr) PollutantUncontrolledEmissionFactor(lb/ton)UncontrolledEmissions(tons/yr)Number ofConveyorsTotalUncontrolledEmissions(tons/yr)Type of ControlControl Eff.(%)ControlledEmissions(tons/yr)Transfer Conveyors70 PM 0.003 0.92 3 2.76 Baghouse 50.0 1.3870 tons/hr * 0.003 lb/ton = 0.210 lb/hrPM100.0011 0.34 3 1.01 Baghouse 50.0 0.51Source of Criteria Pollutant Factors:PM2.50.0011 0.34 3 1.01 Baghouse 50.0 0.51SCC# 3-05-020-06**, AP-42, Ch. 11.19, Table 11.19.2-2** UncontrolledBH-1Methodology:Uncontrolled Emissions (tons/yr) = Rate (tons/hr) x Uncontrolled Emission Factor (lbs/ton) x 8760 hrs/yr÷2000 lbs/tonTotal Uncontrolled Emissions (tons/yr) = Uncontrolled Emissions (tons/yr) x Number of ConveyorsControlled Emissions (tons/yr) = Total Uncontrolled Emissions (tons/yr) x (1 - Control Efficiency/100)Allowable Emissions:Each conveyor is exempt from 326 IAC 6-3-2 because each conveyor has potentialemissions less than 0.551 lb/hr.Allowable Emissions:The following calculations determine PM compliance with 326 IAC 6-3-2 for process weight rates greater than 30 tons per hour:March 29, 2011Page 5 of 13ATSD - Appendix AAppendix A: Emission CalculationsAggregate Processing (100 TPH) Particulate EmissionsCompany Name:Brickcraft, LLCAddress City IN Zip:200 North SR 59, Center Point, IN 47840Significan Source Modification No:021-30024-00054Title V Operating Permit No:T021-23323-00054Reviewer:John HaneyDate:Process: Rate (tons/hr) PollutantUncontrolledEmission Factor(lb/ton)UncontrolledEmissions(tons/yr)Number of BinsTotalUncontrolledEmissions(tons/yr)Type of ControlControl Eff.(%)ControlledEmissions(tons/yr)Crushed Material Storage Bin100 PM 0.003 1.31 6 7.88 Baghouse 50.0 3.94PM100.0011 0.48 6 2.89 Baghouse 50.0 1.45Source of Criteria Pollutant Factors:PM2.50.0011 0.48 6 2.89 Baghouse 50.0 1.45SCC# 3-05-020-06**, AP-42, Ch. 11.19, Table 11.19.2-2**Use uncontrolled conveyor transfer point emission factorsBH-1Methodology:Uncontrolled Emissions (tons/yr) = Rate (tons/hr) x Uncontrolled Emission Factor (lbs/ton) x 8760 hrs/yr÷2000 lbs/tonTotal Uncontrolled Emissions (tons/yr) = Uncontrolled Emissions (tons/yr) x Number of BinsControlled Emissions (tons/yr) = Total Uncontrolled Emissions (tons/yr) x (1 - Control Efficiency/100)Allowable Emissions:The storage bins are exempt from 326 IAC 6-3-2 because each bin has potential emissions less than 0.551 lb/hr.100 tons/hr x 0.003 lb/ton = 0.300 lb/hrMarch 29, 2011Page 6 of 13ATSD - Appendix AAppendix A: Emission CalculationsAggregate Processing (60 TPH) Particulate EmissionsCompany Name:Brickcraft, LLCAddress City IN Zip:200 North SR 59, Center Point, IN 47840Significan Source Modification No:021-30024-00054Title V Operating Permit No:T021-23323-00054Reviewer:John HaneyDate:Process: Rate (tons/hr) PollutantUncontrolledEmissionFactor(lb/ton)UncontrolledEmissions(tons/yr)Number ofConveyorsTotalUncontrolledEmissions(tons/yr)Type of ControlControl Eff.(%)ControlledEmissions(tons/yr)Transfer Conveyors60 PM 0.003 0.79 3 2.37 Baghouse 50.0 1.1860 tons/hr * 0.003 lb/ton = 0.180 lb/hrPM100.0011 0.29 3 0.87 Baghouse 50.0 0.43Source of Criteria Pollutant Factors:PM2.50.0011 0.29 3 0.87 Baghouse 50.0 0.43SCC# 3-05-020-06**, AP-42, Ch. 11.19, Table 11.19.2-2** UncontrolledBH-1Methodology:Uncontrolled Emissions (tons/yr) = Rate (tons/hr) x Uncontrolled Emission Factor (lbs/ton) x 8760 hrs/yr÷2000 lbs/tonTotal Uncontrolled Emissions (tons/yr) = Uncontrolled Emissions (tons/yr) x Number of ConveyorsControlled Emissions (tons/yr) = Total Uncontrolled Emissions (tons/yr) x (1 - Control Efficiency/100)Process: Rate (tons/hr) PollutantUncontrolledEmissionFactor(lb/ton)UncontrolledEmissions(tons/yr)Type of ControlControl Eff.(%)ControlledEmissions(tons/yr)Additive Feeder6 PM 0.003 0.08 Baghouse 50.0 0.046 tons/hr * 0.003 lb/ton = 0.018 lb/hrPM100.0011 0.03 Baghouse 50.0 0.01Source of Criteria Pollutant Factors:PM2.50.0011 0.03 Baghouse 50.0 0.01SCC# 3-05-020-06**, AP-42, Ch. 11.19, Table 11.19.2-2**Use uncontrolled conveyor transfer point emission factorsBH-1Methodology:Uncontrolled Emissions (tons/yr) = Rate (tons/hr) x Uncontrolled Emission Factor (lbs/ton) x 8760 hrs/yr÷2000 lbs/tonControlled Emissions (tons/yr) = Uncontrolled Emissions (tons/yr) x (1 - Control Efficiency/100)Process: Rate (tons/hr) PollutantUncontrolledEmissionFactor(lb/ton)UncontrolledEmissions(tons/yr)Type of ControlControl Eff.(%)ControlledEmissions(tons/yr)Surge Bin20 PM 0.003 0.26 Baghouse 50.0 0.1320 tons/hr * 0.003 lb/ton = 0.060 lb/hrPM100.0011 0.10 Baghouse 50.0 0.05Source of Criteria Pollutant Factors:PM2.50.0011 0.10 Baghouse 50.0 0.05SCC# 3-05-020-06**, AP-42, Ch. 11.19, Table 11.19.2-2**Use uncontrolled conveyor transfer point emission factorsBH-1Methodology:Uncontrolled Emissions (tons/yr) = Rate (tons/hr) x Uncontrolled Emission Factor (lbs/ton) x 8760 hrs/yr÷2000 lbs/tonControlled Emissions = Uncontrolled Emissions (tons/yr) x (1 - Control Efficiency/100)Process: Rate (tons/hr) PollutantUncontrolledEmissionFactor(lb/ton)UncontrolledEmissions(tons/yr)Type of ControlControl Eff.(%)ControlledEmissions(tons/yr)Pugmill60 PM 0.544 142.96 Baghouse 50.0 71.48P= 60 tons/hrPM100.134 35.22 Baghouse 50.0 17.61limit = 55.0 x ( 60 ^0.11 ) = 46.3 lb/hr (allowable)Source of Criteria Pollutant Factors:PM2.50.134 35.22 Baghouse 50.0 17.61SCC# 3-05-011-09**, AP-42, Ch. 11.12, Table 11.12-2with uncontrolled potential:142.96 tons/yr x 2000 lb/ton / 8760 hr/yr = 32.64 lb/hr (capable of complying)**Use uncontrolled mixer loading (central mix) emission factorsBH-2Methodology:Uncontrolled Emissions (tons/yr) = Rate (tons/hr) x Uncontrolled Emission Factor (lbs/ton) x 8760 hrs/yr÷2000 lbs/tonControlled Emissions = Uncontrolled Emissions (tons/yr) x (1 - Control Efficiency/100)Process: Rate (tons/hr) PollutantControlledEmissionFactor(lb/ton)ControlledEmissions(tons/yr)Type of ControlControl Eff.(%)UncontrolledEmissions(tons/yr)Extrusion Operation60 PM 0.0036 0.95 see note** 50.0 1.891.89 tons/yr * 2000 lb/ton÷8760 hr/yr = 0.432 lb/hrPM100.0036 0.95 see note** 50.0 1.89Source of Criteria Pollutant Factors:PM2.50.0036 0.95 see note** 50.0 1.89SCC# 3-05-003-42**, AP-42, Ch. 11.3, Table 11.3-2**Emission factor includes the use of a fabric filter control deviceMethodology:Controlled Emissions (tons/yr) = Rate (tons/hr) x Controlled Emission Factor (lbs/ton) x 8760 hrs/yr÷2000 lbs/tonUncontrolled Emissions = Controlled Emissions (tons/yr)÷(1 - Control Efficiency/100)Process: Rate (tons/hr) PollutantUncontrolledEmissionFactor(lb/ton)UncontrolledEmissions(tons/yr)Type of ControlControl Eff.(%)ControlledEmissions(tons/yr)Texture Feeder0.25 PM 0.003 0.0033 Baghouse 50.0 0.000.25 tons/hr * 0.003 lb/ton = 0.001 lb/hrPM100.0011 0.0012 Baghouse 50.0 0.00Source of Criteria Pollutant Factors:PM2.50.0011 0.0012 Baghouse 50.0 0.00SCC# 3-05-020-06**, AP-42, Ch. 11.19, Table 11.19.2-2**Use uncontrolled conveyor transfer point emission factorsBH-2Methodology:Uncontrolled Emissions (tons/yr) = Rate (tons/hr) x Uncontrolled Emission Factor (lbs/ton) x 8760 hrs/yr÷2000 lbs/tonControlled Emissions = Uncontrolled Emissions (tons/yr) x (1 - Control Efficiency/100)Process: Rate (tons/hr) PollutantUncontrolledEmissionFactor(lb/ton)UncontrolledEmissions(tons/yr)Type of ControlControl Eff.(%)ControlledEmissions(tons/yr)Packaging38 PM 0.003 0.50 Baghouse 50.0 0.2538.00 tons/hr * 0.003 lb/ton = 0.114 lb/hrPM100.0011 0.18 Baghouse 50.0 0.09Source of Criteria Pollutant Factors:PM2.50.0011 0.18 Baghouse 50.0 0.09SCC# 3-05-020-06**, AP-42, Ch. 11.19, Table 11.19.2-2**Use uncontrolled conveyor transfer point emission factorsBH-2Methodology:Uncontrolled Emissions (tons/yr) = Rate (tons/hr) x Uncontrolled Emission Factor (lbs/ton) x 8760 hrs/yr÷2000 lbs/tonControlled Emissions = Uncontrolled Emissions (tons/yr) x (1 - Control Efficiency/100)Allowable Emissions:The packaging operation is exempt from 326 IAC 6-3-2 because it has potential emissionsless than 0.551 lb/hr.Allowable Emissions:The texture feeder is exempt from 326 IAC 6-3-2 because each conveyor has potentialemissions less than 0.551 lb/hr.March 29, 2011Allowable Emissions:Each conveyor is exempt from 326 IAC 6-3-2 because each conveyor has potentialemissions less than 0.551 lb/hr.Allowable Emissions:The additive feeder is exempt from 326 IAC 6-3-2 because the feeder has potential emissionsless than 0.551 lb/hr.Allowable Emissions:The surge bin is exempt from 326 IAC 6-3-2 because each conveyor has potential emissionsless than 0.551 lb/hr.Allowable Emissions:The following calculations determine PM compliance with 326 IAC 6-3-2 for process weight rates greater than 30 tons per hour:Allowable Emissions:The extrusion operation is exempt from 326 IAC 6-3-2 because the operation has potentialemissions less than 0.551 lb/hr.Page 7 of 13
ATSD - Appendix A

Appendix A: Emission Calculations Brick Dryer

Company Name: Brickcraft, LLC Address City IN Zip: 200 North SR 59, Center Point, IN 47840 Significan Source Modification No: 021-30024-00054 Title V Operating Permit No: T021-23323-00054

Reviewer: John Haney

Date:

Process: Rate (tons/hr) Pollutant Emission

Factor (lb/ton) Uncontrolled

Emissions (tons/yr) Type of Control Control Eff. (%) Controlled

Emissions (tons/yr)

Brick Dryer 10.00 PM 0.077 3.37 none 0.0 3.37

PM 10 0.187 8.19 none 0.0 8.19

Source of Criteria PM 2.5 0.187 8.19 none 0.0 8.19

Pollutant Factors: SO 2 *see note 0.00 none 0.0 0.00

SCC# 3-05-003-50 NO

x *see note 0.00 none 0.0 0.00

AP-42 Ch. 11.3 VOC 0.03 1.31 none 0.0 1.31

CO *see note 0.00 none 0.0 0.00

fluorides *see note 0.00 none 0.0 0.00

HF *see note 0.00 none 0.0 0.00

HCl *see note 0.00 none 0.0 0.00

total HAPs *see note 0.00 none 0.0 0.00

* These emissions have been included with the kiln.

Allowable Emissions:

The following calculations determine PM compliance with 326 IAC 6-3-2 for process weight rates less than 30 tons per hour:

P= 10.00 tons/hr limit = 4.1 x ( 10.00 ^0.67 ) = 19.18 lb/hr (allowable)

with uncontrolled potential: 3.37 tons/yr x 2000 lb/ton / 8760 hr/yr = 0.77 lb/hr (capable of complying)

Methodology: Uncontrolled Emissions (tons/yr) = Rate (tons/hr) x Factor (lbs/ton) x 8760 hrs/yr ÷ 2000 lbs/ton Controlled Emissions (tons/yr) = Uncontrolled Emissions (tons/yr) x (1 - Control Efficiency/100) March 29, 2011Page 8 of 13 ATSD - Appendix A

Appendix A: Emission Calculations

Natural Gas-Fired Kiln

Company Name: Brickcraft, LLC Address City IN Zip: 200 North SR 59, Center Point, IN 47840 Significan Source Modification No: 021-30024-00054 Title V Operating Permit No: T021-23323-00054

Reviewer: John Haney

Date:

Process: Rate (tons/hr) Pollutant Emission

Factor (lb/ton) Uncontrolled

Emissions (tons/yr) Type of

Control Control Eff.
(%) Controlled

Emissions (tons/yr)

Natural Gas-Fired Kiln 10.00 PM 0.37 16.21 DIFF 50.0 8.10

(with no back-up fuel) PM 10 0.87 38.11 DIFF 50.0 19.05

PM 2.5 0.87 38.11 DIFF 50.0 19.05

Source of Criteria SO 2 25.00 1095.00 DIFF * see below 249.20

Pollutant Factors: NO

x 0.35 15.33 none 0.0 15.33

SCC# 3-05-003-11 VOC 0.024 1.05 none 0.0 1.05

AP-42 Ch. 11.3 CO 1.2 52.56 none 0.0 52.56

fluorides 0.59 25.84 DIFF 40.0 15.52

HF 0.37 16.21 DIFF * see below 9.73

HCl 0.17 7.45 DIFF 40.0 4.47

total HAPs 0.55 24.09 DIFF 40.0 14.46

SO 2 emissions when bypassing the dry injection fabric filter (DIFF):

( 10.00 tons/hr ) x ( 25.00 lb/ton ) x ( 125 hr/yr ) x ( 1 ton/2000 lb ) = 15.63 tpy

SO 2 emissions controlled by the dry injection fabric filter (DIFF):

( 10.00 tons/hr ) x ( 5.41 lb/ton ) x ( 8635 hr/yr ) x ( 1 ton/2000 lb ) = 233.58 tpy
249.20 tpy

HF emissions when bypassing the dry injection fabric filter (DIFF):
( 10.00 tons/hr ) x ( 0.37 lb/ton ) x ( 125 hr/yr ) x ( 1 ton/2000 lb ) = 0.23 tpy HF emissions controlled by the dry injection fabric filter (DIFF):
( 10.00 tons/hr ) x ( 0.22 lb/ton ) x ( 8635 hr/yr ) x ( 1 ton/2000 lb ) = 9.50 tpy
9.73 tpy

( 16.21 - 9.73 ) ÷ 16.21 x 100 = 40.0 % CE

Allowable Emissions:

P= 10.00 tons/hr limit = 4.1 x ( 10.00 ^0.67 ) = 19.18 lb/hr (allowable)

with uncontrolled potential: 16.21 tons/yr x 2000 lb/ton / 8760 hr/yr = 3.70 lb/hr (capable of complying)

Methodology:

Emission factor for SO 2 is from mass balance using worse case material while keeping the source below 250 tpy after control.

Uncontrolled Emissions (tons/yr) = Rate (tons/hr) x Factor (lbs/ton) x 8760 hrs/yr ÷ 2000 lbs/ton Controlled Emissions (tons/yr) = Uncontrolled Emissions (tons/yr) x (1 - Control Efficiency/100) March 29, 2011

The following calculations determine PM compliance with 326 IAC 6-3-2 for process weight rates less than 30 tons per hour:Page 9 of 13
ATSD - Appendix A

Appendix A: Emission Calculations One (1) Storage Silo - Powdered Lime - Receiving

Company Name: Brickcraft, LLC Address City IN Zip: 200 North SR 59, Center Point, IN 47840 Significan Source Modification No: 021-30024-00054 Title V Operating Permit No: T021-23323-00054

Reviewer: John Haney

Date:

1. Process Descriptions:

The lime is delivered via tank trucks, and the silo is filled pneumatically. The DIFF is used to equalize the pressure and to prevent material from being emitted to the atmosphere.

Max Throughput: 25.0 tons/hr

Uncontrolled Emission Factors Controlled Emission Factors

PM Emission Factor: 3.14 lbs/ton PM Emission Factor: 0.0089 lbs/ton

PM 10 Emission Factor: 1.10 lbs/ton PM 10 Emission Factor: 0.0049 lbs/ton

PM 2.5 Emission Factor: 1.10 lbs/ton PM 2.5 Emission Factor: 0.0049 lbs/ton

Emission Factors are from AP-42, Tables 11.12-2, SCC #3-05-011-17 (Cement supplement unloading to elevated storage silo (pneumatic), AP-42, 06/06).

PM 2.5 has been assumed equal to PM 10

. There is no emission factor for lime loading in AP-42.

2. Potential Uncontrolled Emissions:

Throughput Emissions Emissions Emissions

(tons/hr) PM (tons/yr) PM 10 ( tons/ y r ) PM 2.5 ( tons/ y r )

1 Silo 25.0 343.83 120.45 120.45

3. Controlled Emissions:

Throughput Emissions Emissions Emissions

(tons/hr) PM (tons/yr) PM 10 ( tons/ y r ) PM 2.5 ( tons/ y r )

1 Silo 25.0 0.97 0.54 0.54

4. Limited Emissions:

PM emissions controlled by the dry injection fabric filter (DIFF): ( 25.0 tons/hr ) x ( 0.200 lb/ton ) x ( 8760 hr/yr ) x ( 1 ton/2000 lb ) = 21.90 tpy ( 25.0 tons/hr ) x ( 0.200 lb/ton ) = 5.00 lb/hr

PM 10 emissions controlled by the dry injection fabric filter (DIFF):

( 25.0 tons/hr ) x ( 0.704 lb/ton ) x ( 8760 hr/yr ) x ( 1 ton/2000 lb ) = 77.09 tpy ( 25.0 tons/hr ) x ( 0.704 lb/ton ) = 17.60 lb/hr

5. Allowable Emissions:

P= 25 tons/hr limit = 4.1 x ( 25 ^0.67 ) = 35.4 lb/hr (allowable)

with uncontrolled potential:

343.83 tons/yr x 2000 lb/ton / 8760 hr/yr = 78.50 lb/hr (will not comply)

with controlled potential: 0.97 tons/yr x 2000 lb/ton / 8760 hr/yr = 0.22 lb/hr (capable of complying)

Methodology Emissions (tons/yr) = Throughput (tons/hr) * Emission Factor (lb/ton) * 8760 hr/yr ÷ 2000 lb/ton Unit Unit March 29, 2011

The following calculations determine PM compliance with 326 IAC 6-3-2 for process weight rates less than 30 tons per hour:Page 10 of 13ATSD - Appendix AAppendix A: Emission CalculationsOne (1) Storage Silo - Powdered Lime - DispensingCompany Name:Brickcraft, LLCAddress City IN Zip:200 North SR 59, Center Point, IN 47840Significan Source Modification No:021-30024-00054Title V Operating Permit No:T021-23323-00054Reviewer:John HaneyDate:Max Throughput: 1042 lb/hrProcess: Rate (tons/hr) PollutantUncontrolledEmission Factor(lb/ton)UncontrolledEmissions(tons/yr)Type of ControlControl Eff.(%)ControlledEmissions(tons/yr)Lime Dispensing/Injecting0.521 PM 0.003 0.01 DIFF 50.0 0.00PM100.0011 0.00 DIFF 50.0 0.00Source of Criteria Pollutant Factors:PM2.50.0011 0.00 DIFF 50.0 0.00SCC# 3-05-020-06**, AP-42, Ch. 11.19, Table 11.19.2-2**Use uncontrolled conveyor transfer point emission factorsMethodology:Maximum Throughput (125 lb/hr using 12% motor output) = 125 lb/hr÷0.12 = 1042 lb/hrUncontrolled Emissions (tons/yr) = Rate (tons/hr) x Uncontrolled Emission Factor (lbs/ton) x 8760 hrs/yr÷2000 lbs/tonControlled Emissions (tons/yr) = Uncontrolled Emissions (tons/yr) x (1 - Control Efficiency/100)Allowable Emissions:The lime dispensing system is exempt from 326 IAC 6-3-2 because the system has potential emissions less than 0.551 lb/hr.0.521 tons/hr x 0.003 lb/ton = 0.002 lb/hrMarch 29, 2011Page 11 of 13
ATSD - Appendix A

Appendix A: Emission Calculations One (1) Storage Silo - Sodium Bicarbonate - Receiving

Company Name: Brickcraft, LLC Address City IN Zip: 200 North SR 59, Center Point, IN 47840 Significan Source Modification No: 021-30024-00054 Title V Operating Permit No: T021-23323-00054

Reviewer: John Haney

Date:

1. Process Descriptions:

The sodium bicarbonate is delivered via tank trucks, and the silo is filled pneumatically. The DIFF is used to equalize the pressure and to prevent material from being emitted to the atmosphere.

Max Throughput: 25.0 tons/hr

Uncontrolled Emission Factors Controlled Emission Factors

PM Emission Factor: 3.14 lbs/ton PM Emission Factor: 0.0089 lbs/ton

PM 10 Emission Factor: 1.10 lbs/ton PM 10 Emission Factor: 0.0049 lbs/ton

PM 2.5 Emission Factor: 1.10 lbs/ton PM 2.5 Emission Factor: 0.0049 lbs/ton

Emission Factors are from AP-42, Tables 11.12-2, SCC #3-05-011-17 (Cement supplement unloading to elevated storage silo (pneumatic), AP-42, 06/06).

PM 2.5 has been assumed equal to PM 10

. There is no emission factor for sodium bicarbonate loading in AP-42.

2. Potential Uncontrolled Emissions:

Throughput Emissions Emissions Emissions

(tons/hr) PM (tons/yr) PM 10 ( tons/ y r ) PM 2.5 ( tons/ y r )

1 Silo 25 343.83 120.45 120.45

3. Controlled Emissions:

Throughput Emissions Emissions Emissions

(tons/hr) PM (tons/yr) PM 10 ( tons/ y r ) PM 2.5 ( tons/ y r )

1 Silo 25 0.97 0.54 0.54

4. Limited Emissions:

PM emissions controlled by the dry injection fabric filter (DIFF): ( 25.0 tons/hr ) x ( 0.200 lb/ton ) x ( 8760 hr/yr ) x ( 1 ton/2000 lb ) = 21.90 tpy ( 25.0 tons/hr ) x ( 0.200 lb/ton ) = 5.00 lb/hr

PM 10 emissions controlled by the dry injection fabric filter (DIFF):

( 25.0 tons/hr ) x ( 0.704 lb/ton ) x ( 8760 hr/yr ) x ( 1 ton/2000 lb ) = 77.09 tpy ( 25.0 tons/hr ) x ( 0.704 lb/ton ) = 17.60 lb/hr

5. Allowable Emissions:

P= 25 tons/hr limit = 4.1 x ( 25 ^0.67 ) = 35.4 lb/hr (allowable)

with uncontrolled potential:

343.83 tons/yr x 2000 lb/ton / 8760 hr/yr = 78.50 lb/hr (will not comply)

with controlled potential: 0.97 tons/yr x 2000 lb/ton / 8760 hr/yr = 0.22 lb/hr (capable of complying)

Methodology Emissions (tons/yr) = Throughput (tons/hr) * Emission Factor (lb/ton) * 8760 hr/yr ÷ 2000 lb/ton Unit Unit March 29, 2011

The following calculations determine PM compliance with 326 IAC 6-3-2 for process weight rates less than 30 tons per hour:Page 12 of 13ATSD - Appendix AAppendix A: Emission CalculationsOne (1) Injection System - Sodium Bicarbonate - DispensingCompany Name:Brickcraft, LLCAddress City IN Zip:200 North SR 59, Center Point, IN 47840Significan Source Modification No:021-30024-00054Title V Operating Permit No:T021-23323-00054Reviewer:John HaneyDate:Max Throughput: 545 lb/hrProcess: Rate (tons/hr) PollutantUncontrolledEmission Factor(lb/ton)UncontrolledEmissions(tons/yr)Type of ControlControl Eff.(%)ControlledEmissions(tons/yr)Sodium Bicarbonate Dispensing/Injecting0.273 PM 0.003 0.00 DIFF 50.0 0.00PM100.0011 0.00 DIFF 50.0 0.00Source of Criteria Pollutant Factors:PM2.50.0011 0.00 DIFF 50.0 0.00SCC# 3-05-020-06**, AP-42, Ch. 11.19, Table 11.19.2-2**Use uncontrolled conveyor transfer point emission factorsMethodology:Maximum Throughput (60 lb/hr using 11% motor output) = 60 lb/hr÷0.11 = 545 lb/hrUncontrolled Emissions (tons/yr) = Rate (tons/hr) x Uncontrolled Emission Factor (lbs/ton) x 8760 hrs/yr÷2000 lbs/tonControlled Emissions (tons/yr) = Uncontrolled Emissions (tons/yr) x (1 - Control Efficiency/100)Allowable Emissions:The bicarbonate dispensing system is exempt from 326 IAC 6-3-2 because the system has potential emissions less than 0.551 lb/hr.0.273 tons/hr x 0.003 lb/ton = 0.001 lb/hrMarch 29, 2011Page 13 of 13ATSD - Appendix AAppendix A: Emissions CalculationsNatural Gas Combustion Only (MMBtu/hr <100)Company Name:Brickcraft, LLCAddress City IN Zip:200 North SR 59, Center Point, IN 47840Significan Source Modification No:021-30024-00054Title V Operating Permit No:T021-23323-00054Reviewer:John HaneyDate:Combined Heat Input Capacity Potential ThroughputMMBtu/hr MMcf/yr5.1 43.8PM*PM10* PM2.5* SO2NOxVOC COEmission Factor in lb/MMcf 1.9 7.6 7.6 0.6 100.0 5.5 84.0**see belowPotential Emissions in tons/yr 0.04 0.17 0.17 0.01 2.19 0.12 1.84Benzene Dichlorobenzene Formaldehyde Hexane TolueneEmission Factor in lb/MMcf 2.1E-03 1.2E-03 7.5E-02 1.8E+00 3.4E-03Potential Emissions in tons/yr 4.599E-05 2.628E-05 1.643E-03 3.942E-02 7.446E-05Lead Cadmium Chromium Manganese NickelEmission Factor in lb/MMcf 5.0E-04 1.1E-03 1.4E-03 3.8E-04 2.1E-03Potential Emissions in tons/yr 1.095E-05 2.409E-05 3.066E-05 8.322E-06 4.599E-05Methodology:All emission factors are based on normal firing.MMBtu = 1,000,000 BtuMMcf = 1,000,000 cubic feet of gasEmission 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 (Supplement D 3/98).Potential Throughput (MMcf/yr) = Heat Input Capacity (MMBtu/hr) x 8,760 hrs/yr x 1 MMcf/1,020 MMBtuPotential Emissions(tons/yr)= Throughput(MMcf/yr)x Emission Factor(lb/MMcf)÷2,000 lb/tonPollutant* PM emission factor is filterable PM only. PM10emission factor is filterable and condensable PM10combined.HAPs - Metals** Emission Factors for NOx: Uncontrolled = 100, Low NOxBurner = 50, Low NOxBurners/Flue gas recirculation = 32HAPs - OrganicsMarch 29, 2011

### Indiana Department of Environmental Management Office of Air Quality

Technical Support Document (TSD) for a Significant Source Modification And Part 70 Operating Permit

Source Background and Description

Source Name: Brickcraft, LLC Source Location: 200 North SR 59, Center Point, Indiana 47840 County: Clay

SIC Code: 3251 Significant Source Modification No.: 021-30024-00054 Part 70 Operating Permit No.: T021-23323-00054 Permit Reviewer: John Haney

The Office of Air Quality (OAQ) has reviewed the operating permit application from Brickcraft, LLC relating to the operation of a stationary brick manufacturing plan t. On July 3, 2006, Brickcraft, LLC submitted an application to the OAQ requesting to transition from its MSOP to a Part 70 Operating Permit. Brickcraft, LLC was issued MSOP No. M021-18273-00054 on March 1, 2004.

Permitted Emission Units and Pollution Control Equipment

The source consists of the following permitted emission units:

(a) One (1) quarry, constructed in 2004, with a capacity of 125 tons of shale per hour;

(b) One (1) outdoor aggregate storage pile, with a capacity of 125 tons of shale per hour.

(c) One (1) pre-kiln clay/shale/fireclay/sand processing operation, identified as EU-02, installed in 2004, with a maximum capacity of 125 tons of raw material (including clay, fireclay, shale, and sand) per hour, consisting of the following equipment:

(1) One (1) primary crusher, with a maximum capacity of 125 tons of raw material per hour, using baghouse BH-1 as partic ulate control, exhausting internally. Under NSPS Subpart OOO, this is an affe cted facility enclosed in a building;

(2) One (1) transfer conveyor, with a maximum capacity of 125 tons of raw material per hour, using a hood venting to baghouse BH-1 as particulate control, exhausting internally. Under NSPS Sub part OOO, this is an affected facility enclosed in a building;

(3) One (1) grinding and scalping screen oper ation, with a maximum capacity of 125 tons of raw material per hour, using a hood venting to baghouse BH-1 as particulate control, exhaust ing internally. Under NSPS Subpart OOO, this is an affected facility enclosed in a building;

(4) One (1) coarse material return conveyor , with a maximum capacity of 125 tons of raw material per hour, using a hood venting to baghouse BH-1 as particulate control, exhausting intern ally. Under NSPS Subpart OOO, this is an affected facility enclosed in a building;Brickcraft, LLC Page 2 of 24 Center Point, Indiana TSD for Significant Source Modification No.: 021-30024-00054 Permit Reviewer: John Haney TSD for Part 70 Operating Permit No.: T021-23323-00054

(5) One (1) transfer conveyor, with a maximum capacity of 125 tons of raw material per hour, using a hood venting to baghouse BH-1 as particulate control, exhausting internally. Under NSPS Sub part OOO, this is an affected facility enclosed in a building;

(6) One (1) secondary crusher, with a maximum capacity of 110 tons of raw material per hour, using a hood venting to baghouse BH-1 as particulate control, exhausting internally. Under NSPS Sub part OOO, this is an affected facility enclosed in a building;

(7) One (1) transfer conveyor, with a maximum capacity of 110 tons of raw material per hour, using a hood venting to baghouse BH-1 as particulate control, exhausting internally. Under NSPS Sub part OOO, this is an affected facility enclosed in a building;

(8) One (1) finishing screen operation, with a maximum capacity of 70 tons of raw material per hour, using a hood venting to baghouse BH-1 as particulate control, exhausting internally. Under NSPS Sub part OOO, this is an affected facility enclosed in a building;

(9) One (1) coarse material return conveyor , with a maximum capacity of 70 tons of raw material per hour, using a hood venting to baghouse BH-1 as particulate control, exhausting intern ally. Under NSPS Subpart OOO, this is an affected facility enclosed in a building;

(10) Two (2) transfer conveyors, each wi th a maximum capacity of 70 tons of raw material per hour, each using a hood venting to baghouse BH-1 as particulate control, exhausting inte rnally. Under NSPS Subpar t OOO, these are affected facilities enclosed in a building;

(11) Six (6) crushed material storage bins, each having a capacity of 100 tons, each using a hood venting to baghouse BH-1 as particulate control, exhausting internally. Under NSPS Subpart OOO, thes e are affected facilities enclosed in a building;

(12) Two (2) transfer conveyors, each wi th a maximum capacity of 60 tons of raw material per hour, each using a hood venting to baghouse BH-1 as particulate control, exhausting internally;

(13) One (1) enclosed mixi ng pugmill, with a maximum capacity of 60 tons per hour, using baghouse BH-2 as particulate control, exhausting internally;

(14) One (1) transfer conveyor, with a maxi mum capacity of 60 tons of milled material per hour, using a hood venting to baghouse BH-1 as particulate control, exhausting internally; and

(15) One (1) extrusion operation, with a maximum capacity of 60 tons of milled material per hour, with emissions uncontrolled.

(d) One (1) brick manufacturing line, identified as EU-01, installed in 2004, with a maximum capacity of 10 tons of bricks per hour, consisting of:

(1) One (1) brick dryer, with a maximum capacity of 10 tons of bricks per hour, using recycled hot air from the gas-fired kiln, exhausting through stacks D-1 and CZ-1;Brickcraft, LLC Page 3 of 24 Center Point, Indiana TSD for Significant Source Modification No.: 021-30024-00054 Permit Reviewer: John Haney TSD for Part 70 Operating Permit No.: T021-23323-00054

(2) One (1) natural gas-fired tunnel kiln, ra ted at 56 million British thermal units per hour, with a maximum capacity of 10 tons of bricks per hour, using a dry injection fabric filter (DIFF) as a control devic e for both hydrogen fluoride and sulfur dioxide, exhausting through stacks POC-1 and UCC-1;

(e) One (1) outdoor spent injection material st orage pile, with a capacity of 185 pounds of lime/sodium bicarbonate mixture per hour.

Emission Units and Pollution Control Equipment Constructed and Operated without a Permit

The source consists of the following emission units that were constructed and are operating without a permit:

(d) One (1) brick manufacturing line, identified as EU-01, installed in 2004, with a maximum capacity of 10 tons of bricks per hour, consisting of:

(3) One (1) lime storage silo, identified as Lime Silo, constructed in 2009, permitted in 2011, with a maximum capacity of 50 tons and a maximum throughput of 25 tons per hour, exhausting to the dry in jection fabric filter (DIFF); and

(4) One (1) sodium bicarbonate storage silo, identified as Bicarb Silo, constructed in 2004, permitted in 2011, with a maximum capacity of 50 tons and a maximum throughput of 25 tons per hour, exhausting to the dry injection fabric filter (DIFF).

Insignificant Activities

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

(a) Natural gas-fired combustion sources with heat input equal to or less than ten million (10,000,000) British thermal units per hour:

Three (3) torpedo heaters, with no unit identific ation, each with a heat input capacity of 1.70 MMBtu per hour.

(b) Combustion source flame safety purging on start-up.

(c) Petroleum fuel (other than gasoline) dispen sing facilities, having st orage capacity of less than or equal to 10,500 gallons and dispensing less than or equal to 230,000 gallons per

month:

(1) One (1) storage tank, constructed in 2004, identified as Main, for storage of diesel fuel, with a maximum volume of 1,000 gallons; and

(2) One (1) storage tank, constructed in 20 04, identified as Quarry, for storage of diesel fuel, with a maximum volume of 2,000 gallons.

(d) VOC and HAP storage tanks with capacity less than or equal to 1,000 gallons and annual throughputs less than 12,000 gallons.

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

(f) Replacement or repair of electrostatic prec ipitators, bags in baghouses, and filters in other air filtration equipment.

(g) Paved and unpaved roads. [ 326 IAC 6-4] [326 IAC 6-5]Brickcraft, LLC Page 4 of 24 Center Point, Indiana TSD for Significant Source Modification No.: 021-30024-00054 Permit Reviewer: John Haney TSD for Part 70 Operating Permit No.: T021-23323-00054

(h) A laboratory as defined in 326 IAC 2-7-1(21)(H).

(i) Activities with potential emissions within any of the following thresholds: equal to or less than 5 pounds per hour or 25 pounds per day PM 10 , SO 2 , or NO

x ; equal to or less than 3 pounds per hour or 15 pounds per day VOC; equal to or less than 25 pounds per day CO; equal to or less than 0.6 tons per year or 3.29 pounds per day Pb; or greater than 1 pound per day but less than 5 pounds per day or 1 ton per year single HAP (and not regulated by a NESHAP):

(1) One (1) additive feeder, with a maximum capacity of six (6) tons per hour, using baghouse BH-1 as particulate control, exhausting internally;

(2) One (1) enclosed surge bin, with a maximum capacity of 20 tons, using baghouse BH-1 as particulate control, exhausting internally;

(3) One (1) texture feeder, with a maximu m capacity of 0.25 tons per hour, using baghouse BH-2 as particulate control, exhausting internally; and

(4) One (1) packaging area, with a maximum capacity of 38 tons per hour, using baghouse BH-2 as particulate control, exhausting internally.

Existing Approvals

Since the issuance of the New Source Construc tion Permit and Minor Source Operating Permit (MSOP) No. M021-18273-00054 on March 1, 2004, the source has constructed or has been operating under the followi ng additional approvals:

(a) First Notice Only Change No. 021-23685-00054, issued on October 24, 2006.

All terms and conditions of previous permits is sued pursuant to permitting programs approved into the State Implementation Plan have been either in corporated as originally stated, revised, or deleted by this permit. All previous registrati ons and permits are superseded by this permit.

Enforcement Issue

(a) IDEM is aware that equipment has been cons tructed and operated prior to receipt of the proper permit. The subject equipment is lis ted in this Technical Support Document under the section entitled “Emission Units and Pollution Control Equipment Constructed and Operated without a Permit”.

IDEM is reviewing this matter and will take appr opriate action. This proposed permit is intended to satisfy the requirements of the construction permit rules.

(b) IDEM is aware that the kiln has not been in compliance with the following emission

limitation:

(1) 326 IAC 2-2 (PSD) Pursuant to Permit No. 021-18273-00054, Condition D.1.1, the sulfur dioxide (SO 2 ) emissions from the kiln shall be controlled to less than 249 tons per year in order to make 326 IAC 2-2 not applicable.

IDEM is reviewing this matter and will take appr opriate action. This proposed permit will satisfy the requirements under 326 IAC 2-2.Brickcraft, LLC Page 5 of 24 Center Point, Indiana TSD for Significant Source Modification No.: 021-30024-00054 Permit Reviewer: John Haney TSD for Part 70 Operating Permit No.: T021-23323-00054

Stack Summary

Stack ID Operation Height (ft) Diameter (ft) Flow Rate (acfm) Temperature ( 0 F)

D-1 Dryer 44 4.0 45,000 105

CZ-1 Dryer 44 3.0 20,000 350

POC-1 Kiln 44 3.0 25,000 350

UCC-1 Kiln 44 2.0 10,000 300

Emission Calculations

See Appendix A of this document for detailed emission calculations.

County Attainment Status

The source is located in Clay County.

Pollutant Designation

SO 2 Better than national standards.
CO Unclassifiable or attainment effective November 15, 1990.

O 3 Unclassifiable or attainment effective June 15, 2004, for the 8-hour ozone standard. 1

PM 10 Unclassifiable effective November 15, 1990.

NO 2 Cannot be classified or be tter than national standards.
Pb Not designated.

1 Unclassifiable or attainment effective October 18, 2000, for the 1-hour ozone standard which was revoked effective June 15, 2005. Unclassifiable or attainment effective April 5, 2005, for PM 2.5

.

(a) Ozone Standards Volatile organic compounds (VOC) and Nitrogen Oxides (NO

x ) are regulated under the Clean Air Act (CAA) for the purposes of attaining and maintaining the National Ambient Air Quality Standards (NAAQS) for ozone. Therefore, VOC and NO

x emissions are considered when evaluating the rule applicability relating to ozone. Clay County has been designated as attainment or unclassifiable for ozone. Therefore, VOC and NO

x emissions were reviewed pursuant to the requirements for Prevention of Significant Deterioration (PSD), 326 IAC 2-2.

(b) PM 2.5 Clay County has been classified as attainment for PM 2.5 . On May 8, 2008, U.S. EPA promulgated the requirements for Prevention of Significant Deterioration (PSD) for PM 2.5 emissions. These rules became effective on July 15, 2008. Indiana has three years from the publication of these rules to revise it s PSD rules, 326 IAC 2-2, to include those requirements. The May 8, 2008 rule revisions require IDEM to regulate PM 10 emissions as a surrogate for PM 2.5 emissions until 326 IAC 2-2 is revised. Because this source is accepting PM 10 limits to be minor for PSD and because PM 2.5 is a subset of PM 10 , PM 10 is an adequate surrogate for PM 2.5

.

(c) Other Criteria Pollutants Clay County has been classified as attainment or unclassifiable in Indiana for all regulated pollutants

. Therefore, these emissions were reviewed pursuant to the requirements for Prevention of Significant Deterioration (PSD), 326 IAC 2-2.Brickcraft, LLC Page 6 of 24 Center Point, Indiana TSD for Significant Source Modification No.: 021-30024-00054 Permit Reviewer: John Haney TSD for Part 70 Operating Permit No.: T021-23323-00054

Fugitive Emissions

Since this type of operation is not one of the twent y-eight (28) listed source categories under 326 IAC 2-2 or 326 IAC 2-7, and there is no applic able New Source Performa nce Standard that was in effect on August 7, 1980, fugitive emissions are not counted toward the determination of PSD and Part 70 Permit applicability.

Source Status

(a) On February 1, 2008, the sour ce performed a stack test of the tunnel kiln. These results were reviewed and approved by IDEM on March 13, 2008. These results indicated SO 2 was emitted at a rate of 250 tons per y ear or more, and the source would have been a major stationary source, under PSD (326 IAC 2-2). The source has decided to limit its emissions below the major source thresholds. Therefore, this existing source is not a major stationary source, under PSD (326 IAC 2-2), because no regulated pollutant is emitted at a rate of 250 tons per year or mo re, and it is not one of the twenty-eight (28) listed source categories, as sp ecified in 326 IAC 2-2-1(gg)(1).

(b) Emissions based upon the Technical Support Document (TSD) for New Source Construction Permit and Minor Source Operating Permit (MSOP) No. M021-18273-00054 indicated HAP emissions were greater than t en (10) tons per year for a single HAP and greater than twenty-five (25) tons per year for a combination of HAPs, and the source would have been a major stationary source, under Section 112 of the Clean Air Act (CAA). The source has decided to limit its em issions below the major source thresholds. Therefore, this existing source is not a majo r stationary source, under Section 112 of the Clean Air Act (CAA).

Description of Proposed Modification

The Office of Air Quality (OAQ) has reviewed a modification application, submitted by Brickcraft, LLC on July 3, 2006, requesting to transition from its MSOP to a Part 70 Operating Permit. During the review of this application, IDEM became aware that equipment had been constructed and operated prior to receipt of the proper permit. The following is a list of the proposed emission

units:

(d) One (1) brick manufacturing line, identified as EU-01, installed in 2004, with a maximum capacity of 10 tons of bricks per hour, consisting of:

(3) One (1) lime storage silo, identified as Lime Silo, constructed in 2009, permitted in 2011, with a maximum capacity of 50 tons and a maximum throughput of 25 tons per hour, exhausting to the dry in jection fabric filter (DIFF); and

(4) One (1) sodium bicarbonate storage silo, identified as Bicarb Silo, constructed in 2004, permitted in 2011, with a maximum capacity of 50 tons and a maximum throughput of 25 tons per hour, exhausting to the dry injection fabric filter (DIFF).Brickcraft, LLC Page 7 of 24 Center Point, Indiana TSD for Significant Source Modification No.: 021-30024-00054 Permit Reviewer: John Haney TSD for Part 70 Operating Permit No.: T021-23323-00054

Unrestricted Potential Emissions

Appendix A of this TSD reflects the unrest ricted potential emissions of the source.

(a) The potential to emit (as defined in 326 IAC 2-7-1(29)) of PM, PM 10 , and SO 2 are each equal to or greater than 100 tons per year. Therefore, the source is subject to the provisions of 326 IAC 2-7 and will be is sued a Part 70 Operating Permit.

(b) The potential to emit (as defined in 326 IAC 2-7-1(29)) of any single HAP is equal to or greater than ten (10) tons per year. Therefore, the source is subject to the provisions of

326 IAC 2-7.

Permit Level Determination - Part 70

Pursuant to 326 IAC 2-1.1-1(16), Potential to Emit is defined as “the maximum capacity of a stationary source or emission unit to emit any air pollutant under its physical and operational design. Any physical or operational limitation on t he capacity of a source to emit an air pollutant, including air pollution control equipment and restrict ions on hours of operation or type or amount of material combusted, stored, or processed shall be treated as part of its design if the limitation is enforceable by the U. S. EPA, IDEM, or the appropriate local air pollution control agency.”

The following table is used to determine the appr opriate permit level under 326 IAC 2-7-10.5. This

table reflects the PTE before controls. Contro l equipment is not considered federally enforceable until it has been required in a federally enforceable permit.

Increase in PTE Before Controls of the Modification

Pollutant Potential To Emit (tons/yr)

PM 687.67

PM 10 240.90

SO 2 0

VOC 0

CO 0

NO X 0
Single HAPs 0

Total HAPs 0

Table note: The emission units described by this tabl e are only for equipment that has not received prior construction approval. See Description of Proposed Modification Section above.

Appendix A of this TSD reflects the unrestrict ed potential emissions of the modification.

This source modification is subject to 326 IAC 2-7-10.5(f)(4) because the potential to emit particulate matter (PM) and particu late matter with an aerodynamic diameter less than or equal to ten micrometers (PM 10 ) is greater than twenty-five (25) t ons per year before control, each. Additionally, the modification will be incorporated in to a Part 70 Operating Permit since Brickcraft, LLC is transitioning from its MSOP.Brickcraft, LLC Page 8 of 24 Center Point, Indiana TSD for Significant Source Modification No.: 021-30024-00054 Permit Reviewer: John Haney TSD for Part 70 Operating Permit No.: T021-23323-00054

Part 70 Permit Conditions

This source is subject to the requirements of 326 IAC 2-7, because the source met the following:

(a) Emission limitations and standards, including those operational requirements and limitations that assure compliance with all app licable 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 co ntinuous compliance with the applicable requirements.

Potential to Emit After Issuance

The table below summarizes the potential to emit, re flecting all limits, of the emission units. Any control equipment is considered federally enforce able only after issuance of this Part 70 permit renewal, and only to the extent that the effe ct of the control equipment is made practically enforceable in the permit.Brickcraft, LLC Page 9 of 24 Center Point, Indiana TSD for Significant Source Modification No.: 021-30024-00054 Permit Reviewer: John Haney TSD for Part 70 Operating Permit No.: T021-23323-00054

Process/

Emission Unit Potential To Emit of the Entire Source After Issuance (tons/year)

PM PM 10 * SO 2 NO

x VOC CO Total

Fluorides Total

HAPs Worst Single HAP

Primary Crusher 1.31 0.65 - - - - - - -

Grinding/Scalping

Screen 13.69 1.26 - - - - - - -

Transfer Conveyors (125-ton) 2.46 0.90 - - - - - - -

Secondary Crusher 1.16 0.52 - - - - - - -

Transfer Conveyor (110-ton) 1.45 0.53 - - - - - - -

Finishing Screen 7.67 2.67 - - - - - - -

Transfer Conveyors (70-ton) 2.76 1.01 - - - - - - -

Storage Bins 7.88 2.89 - - - - - - -

Transfer Conveyors (60-ton) 2.37 0.87 - - - - - - -

Pugmill 142.96 35.22 - - - - - - -

Extrusion 1.89 1.89 - - - - - - -

Brick Dryer 3.37 8.19

< 249 15.33 1.31

52.56 25.84 24.09 < 10 (HF) Kiln 16.21 38.11 1.05

Lime Silo - Receiving 21.90 77.09 - - - - - - -

Lime Silo - Dispensing 0.01 0.00 - - - - - - -

Bicarb Silo - Receiving 21.90 77.09 - - - - - - -

Bicarb Silo - Dispensing 0.00 0.00 - - - - - - -

Insignificant

Activities 0.88 0.48 0.01 2.19 0.12 1.84 negl. 0.04 0.04 (hexane)

Total PTE of

Entire Source 249.87 249.36 < 250 17.52 2.49 54.40 25.84 24.13 < 10 (HF)

Title V Major

Source Thresholds N/A 100 100 100 100 100 100 25 10

PSD Major Source

Thresholds 250 250 250 250 250 250 250 N/A N/A

negl. = negligible *Under the Part 70 Permit program (40 CFR 70), partic ulate matter with an aerodynamic diameter less than or equal to a nominal 10 micrometers (PM 10 ), not particulate matter (PM), is considered as a "regulated air pollutant".Brickcraft, LLC Page 10 of 24 Center Point, Indiana TSD for Significant Source Modification No.: 021-30024-00054 Permit Reviewer: John Haney TSD for Part 70 Operating Permit No.: T021-23323-00054

The operation of this source has the potential to emit greater than 250 tons per year of PM and

PM 10 , each. Therefore, 326 IAC 2- 2 would have applied to these facilities. The source has decided to limit their PM, PM 10 , and SO 2 emissions below the major source threshold as follows:

(a) The PM emissions from the lime silo and sodium bicarbonate silo shall not exceed 5.0 pounds per hour, each.

(b) The PM 10 emissions from the lime silo and sodium bicarbonate silo shall not exceed 17.6 pounds per hour, each.

(c) The SO 2 emissions from the dry injection fabric filter (DIFF) controlling the tunnel kiln shall not exceed 249 tons per twelve (12) co nsecutive month period, with compliance

determined at the end of each month.

(d) The dry injection fabric filter (DIFF) for PM and PM 10 control shall be in operation and

control emissions from the lime silo and sodium bicarbonate silo at all times that either of the silos are being loaded.

(e) The dry injection fabric filter (DIFF) for SO 2 control shall be in operation and control

emissions from the tunnel kiln at all times that the tunnel kiln is in operation, except for a maximum of 125 hours per twelve (12) cons ecutive month period during which the DIFF may be bypassed (for routine maintenance).

Compliance with the above limits, combined with the unrestricted potential to emit PM and PM 10 from other emission units at the source, shall limit the PM, PM 10 , and SO 2 emissions from the entire source to less than 250 tons per twelve (1 2) consecutive month period, each. This shall render the requirements of 326 IAC 2-2 (PSD) not applicable for PM, PM 10 , and SO 2

.

This existing stationary source is not major for PSD because the emissions of each regulated pollutant are less than two hundred fifty (<250) to ns per year, and it is not in one of the twentyeight (28) listed source categories.

Federal Rule Applicability

CAM: (a) Pursuant to 40 CFR 64.2, Compliance Assura nce Monitoring (CAM) is applicable to each existing pollutant-specific emission uni t that meets 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.Brickcraft, LLC Page 11 of 24 Center Point, Indiana TSD for Significant Source Modification No.: 021-30024-00054 Permit Reviewer: John Haney TSD for Part 70 Operating Permit No.: T021-23323-00054

The following table is used to identify the applicab ility of each of the criteria, under 40 CFR 64.1, to each existing emission unit and specif ied pollutant subject to CAM:

Emission Unit /

Pollutant Control

Device Used Emission

Limitation (Y/N) Uncontrolled

PTE (tons/year) Controlled

PTE (tons/year) Part 70 Major

Source

Threshold (tons/year) CAM Applicable (Y/N) Large

Unit (Y/N)

Primary Crusher (PM) Baghouse

BH-1 Y 1.31 0.66 100 N ---

Grinding/Scalping Screen (PM) Baghouse

BH-1 Y 13.69 6.84 100 N ---

Secondary Crusher (PM) Baghouse

BH-1 Y 1.16 0.58 100 N ---

Finishing Screen (PM) Baghouse

BH-1 Y 7.67 3.83 100 N ---

Pugmill (PM) Baghouse

BH-2 Y 142.96 71.48 100 Y N

Transfer Conveyor (PM) Baghouse

BH-1 Y < 2.00 < 2.00 100 N ---

Tunnel Kiln (PM) Dry Injection

Fabric Filter (DIFF) Y 16.21 1.37 100 N N

Tunnel Kiln (PM 10 ) Dry Injection

Fabric Filter (DIFF) Y 38.11 3.23 100 N N

Tunnel Kiln (SO 2 ) Dry Injection

Fabric Filter (DIFF) Y 990.98 > 100 100 Y Y

Tunnel Kiln (HF) Dry Injection

Fabric Filter (DIFF) Y 16.21 < 10 10 Y N

Tunnel Kiln (HCl) Dry Injection

Fabric Filter (DIFF) N 7.45 --- 10 N ---

Lime Silo (PM) Dry Injection

Fabric Filter (DIFF) Y 343.83 0.97 100 Y N

Lime Silo (PM 10 ) Dry Injection

Fabric Filter (DIFF) Y 120.45 0.54 100 Y N

Bicarb Silo (PM) Dry Injection

Fabric Filter (DIFF) Y 343.83 0.97 100 Y N

Bicarb Silo (PM 10 ) Dry Injection

Fabric Filter (DIFF) Y 120.45 0.54 100 Y N

(b) Based upon this evaluation, the requirements of 40 CFR Part 64, CAM are applicable to

the tunnel kiln for SO 2 . The Compliance Determination and Monitoring Requirements

section includes a detailed descr iption of the CAM requirements.Brickcraft, LLC Page 12 of 24 Center Point, Indiana TSD for Significant Source Modification No.: 021-30024-00054 Permit Reviewer: John Haney TSD for Part 70 Operating Permit No.: T021-23323-00054

(c) Based upon this evaluation, the requirement s of 40 CFR Part 64, CAM are applicable to the following emission units upon issuance of the Title V Renewal:

 The pugmill for PM;

 The tunnel kiln for HF;

 The lime silo for PM/PM 10 ; and

 The sodium bicarbonate silo for PM/PM 10

.

These CAM plans will be incorporated into this Pa rt 70 permit at the time of its renewal.

NSPS: (b) Brickcraft, LLC is not subject to the requirements of the NSPS for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced After July 23, 1984, 40 CFR 60.110b, Subpart Kb, because each of the storage tanks has an individual volume less than the Subpart Kb applicability limit of 75 cubic meters (19,800 gallons).

(c) Brickcraft, LLC is not subject to the requirements of the Standards of Performance for Metallic Mineral Processing Plants, 40 CFR 60.380, Subpart LL, because the source does not produce metallic mineral concentrates from ore.

(d) According to the Technical Support Docum ent (TSD) for the New Source Construction Permit and Minor Source Operating Permit M021-18273-00054, issued March 1, 2004, the one (1) pre-kiln clay/shale/fireclay/sand processing operation (EU-02) which exhausts inside the building was not subject to 40 CFR 60, Subpart OOO. However, pursuant to 40 CFR 60.672, "no owner or operator subject to the provisions of this subpart shall cause to be discharged into the atmosphere fr om any transfer point on belt conveyors or from any other affected facility and stack emissions". Therefore, the pre-kiln clay/shale/fireclay/sand processing operati on (EU-02) is subject to the Standards of

Performance for Nonmetallic Mineral Proc essing Plants, 40 CFR 60.670, Subpart OOO, which is incorporated by reference as 326 IAC 12, and has been included as follows:

(1) Truck dumping (with the use of front end loaders) into the primary crusher is not subject to the requirements of the St andards of Performance for Nonmetallic Mineral Processing Plants, 40 CFR 60.670, Subpart OOO, because, pursuant to 40 CFR 60.672(d), the process is exempt fr om the requirements of this section.

(2) The following facilities are not subjec t to the requirements of the Standards of

Performance for Nonmetallic Mineral Pr ocessing Plants, 40 CFR 60.670, Subpart

OOO:

(c) One (1) pre-kiln clay/shale/firecla y/sand processing operation, identified as EU-02, installed in 2004, with a maximum capacity of 125 tons of raw material (including clay, fireclay, sh ale, and sand) per hour, consisting of the following equipment:

(12) Two (2) transfer conveyors, each with a maximum capacity of 60 tons of raw material per hour, each using a hood venting to baghouse BH-1 as particulate control, exhausting internally;

(13) One (1) enclosed mixing pugmill, with a maximum capacity of 60
tons per hour, using baghouse BH-2 as particulate control, exhausting internally;Brickcraft, LLC Page 13 of 24 Center Point, Indiana TSD for Significant Source Modification No.: 021-30024-00054 Permit Reviewer: John Haney TSD for Part 70 Operating Permit No.: T021-23323-00054

(14) One (1) transfer conveyor, with a maximum capacity of 60 tons of milled material per hour, using a hood venting to baghouse BH-1 as particulate control, exhausting internally; and

(15) One (1) extrusion operation, wi th a maximum capacity of 60 tons of milled material per hour, with emissions uncontrolled.

(d) One (1) brick manufacturing line, i dentified as EU-01, installed in 2004, with a maximum capacity of 10 tons of bricks per hour, consisting of:

(1) One (1) brick dryer, with a maximum capacity of 10 tons of bricks per hour, using recycled hot air from the gas-fired kiln, exhausting through stacks D-1 and CZ-1;

(2) One (1) natural gas-fired tunnel kiln, rated at 56 million British thermal units per hour, with a maximum capacity of 10 tons of bricks per hour, using a dry inject ion fabric filter (DIFF) as a control device for both hydrogen fluoride and sulfur dioxide, exhausting through stacks POC-1 and UCC-1;

(3) One (1) lime storage silo, identified as Lime Silo, constructed in 2009, permitted in 2011, with a maximum capacity of 50 tons and a maximum throughput of 25 tons per hour, exhausting to the dry injection fabric filter (DIFF); and

(4) One (1) sodium bicarbonate st orage silo, identified as Bicarb Silo, constructed in 2004, permitted in 2011, with a maximum capacity of 50 tons and a maximum throughput of 25 tons per hour, exhausting to the dry lime in jection fabric filter (DIFF).

Insignificant Activities

(i) Activities with potential emissions within any of the following thresholds: equal to or less than 5 pounds per hour or 25 pounds per day PM 10 , SO 2 , or NO

x ; equal to or less than 3 pounds per hour or 15 pounds per day VOC; equal to or less than 25 pounds per day CO; equal to or less than 0.6 tons per year or 3.29 pounds per day Pb; or greater than 1 pound per day but less than 5 pounds per day or 1 ton per year single HAP (and not regulated by a NESHAP):

(1) One (1) additive feeder, with a maximum capacity of six (6) tons per hour, using baghouse BH-1 as particulate control, exhausting internally;

(2) One (1) enclosed surge bin, with a maximum capacity of 20 tons, using baghouse BH-1 as particulate control, exhausting internally;

(3) One (1) texture feeder, with a maximum capacity of 0.25 tons per hour, using baghouse BH-2 as particulate control, exhausting internally; and

(4) One (1) packaging area, with a maximum capacity of 38 tons per hour, using baghouse BH-2 as particulate control, exhausting internally.Brickcraft, LLC Page 14 of 24 Center Point, Indiana TSD for Significant Source Modification No.: 021-30024-00054 Permit Reviewer: John Haney TSD for Part 70 Operating Permit No.: T021-23323-00054

According to to EPA's Applicability Determination Inde x (ADI) database (http://www.epa.gov/complianc e/monitoring/programs/caa/adi.html) posting dated August 15, 2002 (Control Number: 0200088), since the aggregate coming from the crushed material storage bins is used in the manufacture of brick rather than being crushed or ground, all emission un its following the storage bins are not affected facilities in a production line at a nonmetallic mineral processing plant. Therefore, the facilities listed above are not subject to the requirements of the

Standards of Performance for Nonmetal lic Mineral Processing Plants, 40 CFR 60.670, Subpart OOO.

(3) Pursuant to 40 CFR 60.670(a)(1), the provisions of Subpart OOO are applicable to the following affected facilities in fixed or portable nonmetallic mineral processing plants: each crusher, gr inding mill, screening operation, bucket elevator, belt conveyor, bagging operation, storage bin, enclosed truck, or railcar loading station. The specific facilities include the following:

(c) One (1) pre-kiln clay/shale/firecla y/sand processing operation, identified as EU-02, installed in 2004, with a maximum capacity of 125 tons of raw material (including clay, fireclay, sh ale, and sand) per hour, consisting of the following equipment:

(1) One (1) primary crusher, with a maximum capacity of 125 tons of raw material per hour, using baghouse BH-1 as particulate control, exhausting in ternally. Under NSPS Subpart OOO, this is an affected facility enclo sed in a building;

(2) One (1) transfer conveyor, with a maximum capacity of 125 tons of raw material per hour, using a hood venting to baghouse BH-1 as particulate control, exha usting internally. Under NSPS Subpart OOO, this is an affected facility enclosed in a building;

(3) One (1) grinding and scalping screen operation, with a maximum capacity of 125 tons of raw material per hour, using a hood venting to baghouse BH-1 as pa rticulate control, exhausting internally. Under NSPS Subpart OOO, this is an affected facility enclosed in a building;

(4) One (1) coarse material return conveyor, with a maximum capacity of 125 tons of raw material per hour, using a hood venting to baghouse BH-1 as pa rticulate control, exhausting internally. Under NSPS Subpart OOO, this is an affected facility enclosed in a building;

(5) One (1) transfer conveyor, with a maximum capacity of 125 tons of raw material per hour, using a hood venting to baghouse BH-1 as particulate control, exha usting internally. Under NSPS Subpart OOO, this is an affected facility enclosed in a building;

(6) One (1) secondary crusher, with a maximum capacity of 110 tons of raw material per hour, using a hood venting to baghouse BH-1 as particulate control, exhausting internally. Under NSPS Subpart OOO, this is an affected facility enclosed in a building;Brickcraft, LLC Page 15 of 24 Center Point, Indiana TSD for Significant Source Modification No.: 021-30024-00054 Permit Reviewer: John Haney TSD for Part 70 Operating Permit No.: T021-23323-00054

(7) One (1) transfer conveyor, with a maximum capacity of 110 tons of raw material per hour, using a hood venting to baghouse BH-1 as particulate control, exha usting internally. Under NSPS Subpart OOO, this is an affected facility enclosed in a building;

(8) One (1) finishing screen operation, with a maximum capacity of 70 tons of raw material per hour, using a hood venting to baghouse BH-1 as particulate control, exhausting internally. Under NSPS Subpart OOO, this is an affected facility enclosed in a building;

(9) One (1) coarse material return conveyor, with a maximum capacity of 70 tons of raw material per hour, using a hood venting to baghouse BH-1 as pa rticulate control, exhausting internally. Under NSPS Subpart OOO, this is an affected facility enclosed in a building;

(10) Two (2) transfer conveyors, each with a maximum capacity of 70 tons of raw material per hour, each using a hood venting to baghouse BH-1 as particulate control, exhausting internally. Under NSPS Subpart OOO, these ar e affected facilities enclosed in a building;

(11) Six (6) crushed material storage bins, each having a capacity of 100 tons, each using a hood venting to baghouse BH-1 as particulate control, exhausting internally. Under NSPS Subpart OOO, these are affected facilities enclosed in a building;

Pursuant to 40 CFR 60.670(e), the Permittee shall comply with the requirements of 40 CFR 60, Subpart OOO upon the issuance of this permit.

The entire rule has been included as Attachment B to the permit. The facilities of the prekiln clay/shale/fireclay/sand processing operat ion (EU-02) listed above are subject to the following portions of 40 CFR 60, Subpart OOO:

(1) 40 CFR 60.670(a), (d), (e), (f); (2) 40 CFR 60.671; (3) 40 CFR 60.672(b), (d), (e)(1), (f); (4) 40 CFR 60.673; (5) 40 CFR 60.675(a), (c)(1)(i), (c)(1)(ii), (c)(2), (c)(3), (d)(2), (e), (g), (i); (6) 40 CFR 60.676(a), (f), (h), (i)(1), (j), (k); (7) Table 1 to 40 CFR 63, Subpart OOO; and (8) Table 3 to 40 CFR 63, Subpart OOO.

(e) Brickcraft, LLC is not subject to the requirements of the Standards of Performance for Calciners and Dryers in Mineral Industries , 40 CFR 60.730, Subpart UUU, because only the calcining and drying of raw materials prior to firing of the brick are covered under this subpart. The brick dryer and kiln operations are for drying bricks and not drying raw

materials.

NESHAP: (f) Brickcraft, LLC is not subject to the NESHAP for Halogenated Solvent Cleaning, 40 CFR Part 63.460, Subpart T, because the sour ce does not utilize degreasing operations.Brickcraft, LLC Page 16 of 24 Center Point, Indiana TSD for Significant Source Modification No.: 021-30024-00054 Permit Reviewer: John Haney TSD for Part 70 Operating Permit No.: T021-23323-00054

(g) Brickcraft, LLC is not subject to the requirements of the National Emission Standards for

Hazardous Air Pollutants From the Portl and Cement Manufacturing Industry, 40 CFR 63.1340, Subpart LLL, because this source does not manufacture Portland cement.

(h) Brickcraft, LLC is not subject to the NESHAP for Stationary Reciprocating Internal Combustion Engines, 40 CFR 63.6580, S ubpart ZZZZ, because the source does not utilize emergency generators or stationary fire pumps.

(i) Brickcraft, LLC is not subject to the requirements of the National Emission Standards for

Hazardous Air Pollutants For Lime Manufa cturing Plants, 40 CFR 63.7080, Subpart
AAAAA, because this source do es not manufacture lime.

(j) The requirements of the following NESH APs under 40 CFR Part 63 are not included in the permit:

 NESHAP for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR 63.7480, Subpart DDDDD);

 NESHAP for Brick and Structural Clay Products Manufacturing (40 CFR 63.8380, Subpart JJJJJ);

 NESHAP for Clay Ceramics Manufactu ring (40 CFR 63.8530, Subpart KKKKK); and

 NESHAP for Refractory Pr oducts Manufacturing (40 CFR 63.9780, Subpart SSSSS).

These NESHAPs apply only to major sources of hazardous air pollutants. Since the limited potential to emit of any single HAP is less than 10 tons per year and the potential

to emit of all combined HAPs is le ss than 25 tons per year, Brickcraft, LLC is an area source of HAPs; therefore, Brickcraft, LLC is not subject to these NESHAPs.

(k) Brickcraft, LLC is not subject to the requirements of the National Emission Standards for Hazardous Air Pollutants for Source Categor y: Gasoline Dispensing Facilities, 40 CFR 63.11110, Subpart CCCCCC, because the source dispenses diesel fuel, not gasoline.

(l) Brickcraft, LLC is not subject to the requirements of the National Emission Standards for

Hazardous Air Pollutants for Area Sources: Industrial, Commercial, and Institutional Boilers, 40 CFR 63.11193, Subpart JJJJJJ, beca use the source does not utilize boilers.

(m) Brickcraft, LLC is not subject to the requirements of the National Emission Standards for Hazardous Air Pollutants for Clay Cera mics Manufacturing Area Sources, 40 CFR 63.11435, Subpart RRRRRR, because the source does not meet the definition of a clay ceramics manufacturing facility, as defined in 40 CFR 63.11444.

State Rule Applicability - Entire Source

326 IAC 1-6-3 (Preventive Maintenance Plan) The source is subject to 326 IAC 1-6-3.

326 IAC 2-2 (PSD) The source’s unrestricted PTE of PM, PM 10 , and SO 2 is greater than the PSD major threshold of 250 tons per year, each. However, the source ha s elected to accept limits making this a minor source. The limitations are more fully discussed in the Potential to Emit After Issuance section of the permit.Brickcraft, LLC Page 17 of 24 Center Point, Indiana TSD for Significant Source Modification No.: 021-30024-00054 Permit Reviewer: John Haney TSD for Part 70 Operating Permit No.: T021-23323-00054

326 IAC 2-6 (Emission Reporting)
This source, not located in Lake, Porter, or LaP orte County, is subject to 326 IAC 2-6 (Emission Reporting) because it is required to have an ope rating permit pursuant to 326 IAC 2-7 (Part 70). The potential to emit of VOC and PM 10 is less than 250 tons per year each; and the potential to emit of CO, NO

x , and SO 2 is less than 2,500 tons per year each. Therefore, pursuant to 326 IAC 2-6-3(a)(2), triennial reporting is required. An emission statement shall be submitted in accordance with the compliance schedule in 326 IAC 2-6-3 by July 1, 2012, and every three (3) years thereafter. The emission statement shall c ontain, at a minimum, the information specified

in 326 IAC 2-6-4.

326 IAC 5-1 (Opacity Limitations) This source is subject to the opacity lim itations specified in 326 IAC 5-1-2(1).

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

326 IAC 6-5 (Fugitive Particulat e Matter Emission Limitations) Pursuant to 326 IAC 6-5-1(b), 326 IAC 6-5 applies to any new source of fugitive particulate matter emissions, located anywhere in the state, requi ring a permit as set forth in 326 IAC 2, which has not received all the necessary preconstructi on approvals before December 13, 1985. MSOP

M021-18273-00054 was issued for Brickcraft, LLC on March 1, 2004. Brickcraft, LLC has fugitive emissions greater than 25 tons; therefor e, 326 IAC 6-5 applies to the source.

Pursuant to 326 IAC 6-5 (Fugitive Particulate Matte r Emissions Limitations), fugitive particulate matter emissions shall be controlled according to the attached Fugitive Dust Control Plan in

Attachment A.

326 IAC 8-1-6 (New Facilities; General Reduction Requirements) 326 IAC 8-1-6 does not apply since the potential VOC emissions from the entire source are less than twenty-five (25) tons per year.

326 IAC 8-4-6 (Gasoline Dispensing Facilities) The two (2) insignificant petroleum fuel dispensing facilities, known as Main and Quarry, do not meet the definition of a "gasoline dispensing fa cility" because, pursuant to 326 IAC 8-4-6(a)(8),

diesel fuel is not considered to be a motor vehi cle fuel. Therefore, the requirements of 326 IAC 8- 4-6 are not applicable.

326 IAC 8-9 (Volatile Organic Liquid Storage Vessels) This source is located in Clay County. Ther efore, the requirements of 326 IAC 8-9 are not applicable.

326 IAC 9-1 (Carbon Monoxide Emission Limits) Although this is a stationary source of CO emissions commencing operation after March 21, 1972, there are no applicable CO emission limits fo r this type of source pursuant to 326 IAC 9-1- 2. Therefore, 326 IAC 9-1 does not apply.

326 IAC 10-1 (Nitrogen Oxid e Emission Limitations) The plant is not subject to the requirem ents of 326 IAC 10-1 (Nitrogen Oxide Emission Limitations) because the plant is not loca ted in Clark County or Floyd County.Brickcraft, LLC Page 18 of 24 Center Point, Indiana TSD for Significant Source Modification No.: 021-30024-00054 Permit Reviewer: John Haney TSD for Part 70 Operating Permit No.: T021-23323-00054

State Rule Applicability – Individual Facilities

326 IAC 2-4.1 (Major Sources of Hazardous Air Pollutants (HAP)) (a) The operation of each of the following facilit ies will emit less than 10 tons per year for a single HAP and less than 25 tons per year for a combination of HAPs:

(1) One (1) brick dryer, and

(2) Three (3) torpedo heaters.

Therefore, 326 IAC 2-4.1 does not apply to these facilities.

(b) The operation of the tunnel kiln has the potent ial to emit greater than 10 tons per year of HF. Therefore, 326 IAC 2-4.1 would have applied to this facility. The source has decided to limit its HF emissions below the major source threshold as follows:

(1) The HF emissions from the dry injection fabric filter (DIFF) controlling the tunnel kiln shall not exceed 10 tons per twelve (12) consecutive month period, with compliance determined at the end of each month.

(2) The dry injection fabric filter (DIFF) for HF control shall be in operation and

control emissions from the tunnel kiln at all times that the tunnel kiln is in operation, except for a maximum of 125 hours per twelve (12) consecutive month period during which the DIFF may be by passed (for routine maintenance).

Compliance with the above limits, combined with the potential to emit HF from other
emission units at the source, shall limit the HF emissions from the entire source to less than 10 tons per twelve (12) consecutive mont h period for HF. This shall render the requirements of 326 IAC 2-4.1 (Major Sources of Hazardous Air Pollutants) not applicable

for HF.

326 IAC 6-3-2 (Particulate Emission Li mitations for Manufacturing Processes) (a) Pursuant to 326 IAC 6-3-1(b)(14), the foll owing facilities are exempt from 326 IAC 6-3-2 (Particulate Emission Limitations for Ma nufacturing Processes) because potential emissions from each of these facilities are less than 0.551 pound per hour:

(c) One (1) pre-kiln clay/shale/fireclay/s and processing operation, identified as EU02, installed in 2004, with a maximum c apacity of 125 tons of raw material (including clay, fireclay, shale, and sand) per hour, consisting of the following equipment:

(1) One (1) primary crusher, with a maximum capacity of 125 tons of raw material per hour, using baghouse BH-1 as particulate control, exhausting internally. Under NSPS Subpart OOO, this is an affected facility enclosed in a building;

(2) One (1) transfer conveyor, with a maximum capacity of 125 tons of raw material per hour, using a hood venting to baghouse BH-1 as particulate control, exhausting internally. Under NSPS Subpart OOO, this is an affected facility enclosed in a building;

(3) One (1) grinding and scalping screen operation, with a maximum capacity of 125 tons of raw material per hour, using a hood venting to baghouse BH-1 as particulate control, exhausting internally. Under NSPS Subpart OOO, this is an affected facility enclosed in a building;Brickcraft, LLC Page 19 of 24 Center Point, Indiana TSD for Significant Source Modification No.: 021-30024-00054 Permit Reviewer: John Haney TSD for Part 70 Operating Permit No.: T021-23323-00054

(4) One (1) coarse material return conveyor, with a maximum capacity of125 tons of raw material per hour, using a hood venting to baghouse BH1 as particulate contro l, exhausting internally . Under NSPS Subpart OOO, this is an affected facility enclosed in a building;

(5) One (1) transfer conveyor, with a maximum capacity of 125 tons of raw material per hour, using a hood venting to baghouse BH-1 as particulate control, exhausting internally. Under NSPS Subpart OOO, this is an affected facility enclosed in a building;

(6) One (1) secondary crusher, with a maximum capacity of 110 tons of raw material per hour, using a hood venting to baghouse BH-1 as particulate control, exhausting internally. Under NSPS Subpart OOO, this is an affected facility enclosed in a building;

(7) One (1) transfer conveyor, with a maximum capacity of 110 tons of raw material per hour, using a hood venting to baghouse BH-1 as particulate control, exhausting internally. Under NSPS Subpart OOO, this is an affected facility enclosed in a building;

(8) One (1) finishing screen operation, with a maximum capacity of 70 tons of raw material per hour, using a hood venting to baghouse BH-1 as particulate control, exhausting in ternally. Under NSPS Subpart OOO, this is an affected facility enclosed in a building;

(9) One (1) coarse material return conveyor, with a maximum capacity of 70 tons of raw material per hour, using a hood venting to baghouse BH-1 as particulate control, exhausting in ternally. Under NSPS Subpart OOO, this is an affected facility enclosed in a building;

(10) Two (2) transfer conveyors, each with a maximum capacity of 70 tons of raw material per hour, each using a hood venting to baghouse BH-1 as particulate control, exhausting in ternally. Under NSPS Subpart OOO, these are affected facilities enclosed in a building;

(11) Six (6) crushed material storage bins, each having a capacity of 100 tons, each using a hood venting to bagh ouse BH-1 as particulate control, exhausting internally. Under NSPS Subpart OOO, these are affected facilities enclosed in a building;

(12) Two (2) transfer conveyors, each with a maximum capacity of 60 tons of raw material per hour, each using a hood venting to baghouse BH-1 as particulate control, exhausting internally;

(13) One (1) enclosed mixing pugmill, with a maximum capacity of 60 tons

per hour, using baghouse BH-2 as particulate control, exhausting internally;

(14) One (1) transfer conveyor, with a maximum capacity of 60 tons of milled material per hour, using a hood venting to baghouse BH-1 as particulate control, exhausting internally; and

(15) One (1) extrusion operation, with a maximum capacity of 60 tons of milled material per hour, with emissions uncontrolled.Brickcraft, LLC Page 20 of 24 Center Point, Indiana TSD for Significant Source Modification No.: 021-30024-00054 Permit Reviewer: John Haney TSD for Part 70 Operating Permit No.: T021-23323-00054

Insignificant Activities

(i) Activities with potential emissions within any of the following thresholds: equal to or less than 5 pounds per hour or 25 pounds per day PM 10 , SO 2 , or NO

x ; equal to or less than 3 pounds per hour or 15 pounds per day VOC; equal to or less than 25 pounds per day CO; equal to or less than 0.6 tons per year or 3.29 pounds per day Pb; or greater than 1 pound per day but less than 5 pounds per day or 1 ton per year single HAP (and not regulated by a NESHAP):

(1) One (1) additive feeder, with a maximum capacity of six (6) tons per hour, using baghouse BH-1 as particul ate control, exhausting internally;

(2) One (1) enclosed surge bin, with a maximum capacity of 20 tons, using baghouse BH-1 as particulate control, exhausting internally;

(3) One (1) texture feeder, with a maximum capacity of 0.25 tons per hour, using baghouse BH-2 as particulate control, exhausting internally; and

(4) One (1) packaging area, with a maximum capacity of 38 tons per hour, using baghouse BH-2 as particulate control, exhausting internally.

The dispensing of material from both of the storage silos is also exempt from 326 IAC 6- 3-2 (Particulate Emission Limitations for Manufacturing Processes) because potential emissions from silo dispensing are less than 0.551 pound per hour, each.

(b) 326 IAC 6-3-2 does not apply to the pre-kiln clay/shale/fireclay/sand processing operation (EU-02) if the limitation estab lished in the rule is not consistent with applicable limitations in 40 CFR 60, Subpart OOO pursuant to 326 IAC 12. Since EU-02 is enclosed in a building and its emissions do not pass through a vent (as defined in 40 CFR 60.671), there are no applicable PM limits established by Subpart OOO. Therefore, EU-02 is subject to the requirements of 326 IAC 6-3-2.

(c) Pursuant to 326 IAC 6-3-2, the Permittee s hall comply with the PM limits, when operating at the associated process weight rates, as shown in the table below:

Unit Process Weight Rate

(tons/hr) PM Limit (lb/hr)

Grinding and Scalping Screen Operation 125 53.5 Finishing Screen Operation 70 47.8 Pugmill 60 46.3 Brick Dryer 9.05 17.9

Tunnel Kiln 9.05 17.9 Lime Storage Silo - Receiving 25 35.4 Bicarbonate Storage Silo - Receiving 25 35.4

The pounds per hour limitations were calc ulated with the following equation:

Interpolation of the data for the process weight rate up to sixty thousand (60,000) pounds per hour shall be accomplis hed by use of the equation:

E = 4.10 P 0.67 where E = rate of emission in pounds per hour, and P = process weight rate in tons per hour.Brickcraft, LLC Page 21 of 24 Center Point, Indiana TSD for Significant Source Modification No.: 021-30024-00054 Permit Reviewer: John Haney TSD for Part 70 Operating Permit No.: T021-23323-00054

Interpolation and extrapolation of the data for t he process weight rate in excess of sixty thousand (60,000) pounds per hour shall be accomplished by use of the equation:

E = 55.0 P 0.11 - 40 where E = rate of emission in pounds per hour, and P = process weight rate in tons per hour.

The following facilities are cap able of complying with these particulate limits without the use of control devices: grinding and scal ping screen operation, finishing screen operation, pugmill, brick dryer, and tunnel kiln.

The dry injection fabric filter (DIFF) shall be in operation at all times the lime storage silo and/or the sodium bicarbonate storage silo are being loaded, in order to comply with these particulate limits.

326 IAC 7-1.1 Sulfur Dioxide Emission Limitations This rule requires all facilities wi th a potential to emit twenty-five (25) tons per year or ten (10) pounds per hour of sulfur dioxide to comply wi th the emission limitations and test compliance methods stated in the rule. The kiln has the potent ial to emit twenty-five (25) tons per year and ten (10) pounds per hour of sulfur dioxide; how ever, natural gas is the only fuel used at the source. There are no limits under this rule for natural gas combustion or for non-combustion

sources of sulfur dioxide. Theref ore, 326 IAC 7-1.1 does not apply.

Compliance Determination and Monitoring Requirements

Permits issued under 326 IAC 2-7 are required to ensure that sources can demonstrate compliance with all applicable state and federal ru les on a continuous basis. All state and federal rules contain compliance provisions; however, these prov isions do not always fulfill the requirement for a continuous demonstration. When this occurs, IDEM, OAQ, in conjunction with the source, must develop specific conditions to satisfy 326 IAC 2-7-5. As a result, Compliance Determination Requirements are included in the permit. The Compliance Determination Requirements in Section D of the permit are those conditions that are found directly within state

and federal rules and the violation of which se rves as grounds for enforcement action.

If the Compliance Determination Requirements ar e not sufficient to demonstrate continuous compliance, they will be supplemented with Co mpliance 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 appropri ate corrective actions within a specific time period.

The compliance determination requirements appl icable to Brickcraft, LLC are as follows:

(a) Testing Requirements

Emission Unit(s) Control Device Timeframe for Testing Pollutant Frequency

of Testing Limit or Requirement

Tunnel Kiln Dry injection fabric filter (DIFF) Within 5 years of previous test SO 2 Once every 5 years 5.41 lb/ton of fired product, when determining compliance without a CEMS

Tunnel Kiln Dry injection fabric filter (DIFF) Within 5 years of previous test HF Once every 5 years 0.22 lb/ton of fired product, when determining compliance without a CEMSBrickcraft, LLC Page 22 of 24 Center Point, Indiana TSD for Significant Source Modification No.: 021-30024-00054 Permit Reviewer: John Haney TSD for Part 70 Operating Permit No.: T021-23323-00054

Compliance with the PSD minor limits for PM and PM 10 in Conditions D.3.1(a) and D.3.1(b) does not need to be determined by a performance stack test at this time because the minor limits greatly exceed t he calculated emissi ons at 8,760 hours of loading per year, and the emission units are projected to require fewer than 30 hours of loading per year, each. However, IDEM, OAQ may require stack testing at any time to assure compliance with all applicable requirements by issuing an order under

326 IAC 2-1.1-11.

(b) Emission Controls Operation

(1) The dry injection fabric filter (DIFF) for PM and PM 10 control shall be in operation

and control emissions from the lime silo and sodium bicarbonate silo at all times that either of the silos are being loaded.

(2) When determining compliance with Condit ions D.3.1(c) and D.3.2(a) without the use of a CEMS, the dry injection fabric filter (DIFF) for SO 2 and HF control shall be in operation and control emissions from the tunnel kiln at all times that the tunnel kiln is in operation, except for a maximum of 125 hours per twelve (12) consecutive month period during which the DIFF may be bypassed (for routine maintenance).

(c) Emission Calculations

SO 2 and HF emissions shall be calculated using the given formulas in Conditions D.3.7

and D.3.8.

(d) Sulfur Content Determination The sulfur content of the aggregate feedst ock shall be determined using methods in

Condition D.3.9.

(e) Continuous Emissions Monitoring

(1) In order to determine compliance with Conditions D.3.1(c) and D.3.2(a), the
Permittee shall install, calibrate, main tain, operate, and certify a continuous emission monitoring system (CEMS) and related equipment for measuring SO 2 and HF emissions from the tunnel kiln in accordance with 326 IAC 3-5.

(2) The SO 2 and HF CEMS shall be operated at all times the tunnel kiln is in operation except for system breakdowns, repairs, calibration checks, and zero and span adjustments.

These requirements are required to ensure comp liance with 326 IAC 6-3-2 (Particulate Emission Limitations for Manufacturing Processes) and 40 CFR 64 (CAM) and to render 326 IAC 2-2 (PSD) and 326 IAC 2-4.1 (Major Sources of Ha zardous Air Pollutants) not applicable.

The compliance monitoring requirements applic able to Brickcraft, LLC are as follows:

(a) Emissions Monitoring When determining compliance with Conditions D.3.1(c) and D.3.2(a) with the use of a CEMS, whenever the CEMS is down for more than twenty-four (24) hours, a calibrated backup CEMS shall be brought online within tw enty-four (24) hours of shutdown of the primary CEMS, if possible. If this is not pos sible, the requirements in Condition D.3.14(b) shall be conducted to allow for determination of compliance with the SO 2 and HF

emission limits.Brickcraft, LLC Page 23 of 24 Center Point, Indiana TSD for Significant Source Modification No.: 021-30024-00054 Permit Reviewer: John Haney TSD for Part 70 Operating Permit No.: T021-23323-00054

(b) Visible Emissions Notations

The Permittee shall perform daily visible emission notations of the dry injection fabric filter (DIFF) exhaust.

(c) Baghouse Parametric Monitoring

The Permittee shall record the pressure drop acro ss the dry injection fabric filter (DIFF) at least once per day when the tunnel kiln, lime silo, and/or sodium bicarbonate silo are in operation.

(d) SO 2 Compliance Assurance Monitoring

(1) When determining compliance with the use of a CEMS, the Permittee shall operate a CEMS.

(2) When determining compliance without the use of a CEMS:

(A) The Permittee shall monitor the dry lime feed rate from the lime silo to the dry injection fabric f ilter (DIFF) continuously.

(B) The Permittee shall monitor the dry sodium bicarbonate feed rate from the sodium bicarbonate silo to the dry injection fabric filter (DIFF) continuously.

(C) The Permittee shall inspect the dry lime feed system and the feed quantity on the lime silo once per day.

(D) The Permittee shall inspect the dry sodium bicarbonate feed system and the feed quantity on the sodium bicarbonate silo once per day.

(e) HF Compliance Assurance Monitoring

(1) When determining compliance with the use of a CEMS, the Permittee shall operate a CEMS.

(2) When determining compliance without the use of a CEMS:

(A) The Permittee shall monitor the dry lime feed rate from the lime silo to the dry injection fabric filter (DIFF) once per day.

(B) The Permittee shall monitor the dry sodium bicarbonate feed rate from the sodium bicarbonate silo to the dry injection fabric filter (DIFF) once per day.

(C) The Permittee shall inspect the dry lime feed system and the feed quantity on the lime silo once per day.

(D) The Permittee shall inspect the dry sodium bicarbonate feed system and the feed quantity on the sodium bicarbonate silo once per day.Brickcraft, LLC Page 24 of 24 Center Point, Indiana TSD for Significant Source Modification No.: 021-30024-00054 Permit Reviewer: John Haney TSD for Part 70 Operating Permit No.: T021-23323-00054

(f) Broken or Failed Bag Detection

The Permittee shall maintain the dry injection fabric filter (DIFF) and shall replace broken or failed bags as needed.

These monitoring conditions are necessary because the control devices for the facility must operate properly to ensure compliance with 326 IAC 6-3-2 (Particulate Emission Limitations for Manufacturing Processes), 40 CFR 64 (CAM), 326 IAC 2-2 (PSD), and 326 IAC 2-7 (Part 70).

Recommendation

The staff recommends to the Commissioner that the Part 70 Significant Source Modification and Part 70 Operating 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 application for the purposes of this review was received on July 3, 2006. Additional information was received on March 26, 2007; April 3, 2007; De cember 11, 2008; July 29, 2009; August 7, 2009; September 9, 2009; December 21, 2009; Fe bruary 2, 2010; June 3, 2010; September 8, 2010; October 6, 2010; October 21, 2010; February 7, 2011; and March 11, 2011.

Conclusion

The construction and operation of this stationary br ick manufacturing plant shall be subject to the conditions of the attached proposed Part 70 Significant Source Modification No. 021-30024-00054 and Part 70 Operating Permit No. T021-23323-00054.

IDEM Contact

(a) Questions regarding this proposed permit can be directed to John Haney at the Indiana Department Environmental Management, Office of Air Quality, Permits Branch, 100 North Senate Avenue, MC 61-53 IGCN 1003, Indianapolis, Indiana 46204-2251 or by telephone at (317) 234-

5328 or toll free at 1-800-451-6027 extension 4-5328.

(b) A copy of the findings is available on the Internet at: http://www.in.gov/ai/appfiles/idem-caats/

(c) For additional information about air perm its and how the public and interested parties can participate, refer to the IDEM’s Guide for Citizen Participation and Permit Guide on the Internet at: www.idem.in.govPage 1 of 13TSD - Appendix AAppendix A: Emission CalculationsEmissions SummaryCompany Name:Brickcraft, LLCAddress City IN Zip:200 North SR 59, Center Point, IN 47840Permit No:T021-23323-00054Plant ID:021-00054Reviewer:John HaneyDate:Uncontrolled Emissions (tons/year)PMPM10SO2NOxVOC COTotalFluoridesHF HClTotalHAPs1.31 0.65 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.0013.69 1.26 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.002.46 0.90 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.001.16 0.52 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.001.45 0.53 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.007.67 2.67 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.002.76 1.01 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.007.88 2.89 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.002.37 0.87 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00142.96 35.22 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.001.89 1.89 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.003.37 8.19 1.3116.21 38.11 1.05343.83 120.45 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.000.01 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00343.83 120.45 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.000.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Additive Feeder 0.08 0.03 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Surge Bin 0.26 0.10 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Texture Feeder 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Packaging 0.50 0.18 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Space Heaters 0.04 0.17 0.01 2.19 0.12 1.84 0.00 0.00 0.00 0.04Total Total 893.73 336.08 1095.01 17.52 2.49 54.40 25.84 16.21 7.45 24.13Limited Emissions (tons/year) with the Use of CEMSPMPM10SO2NOxVOC COTotalFluoridesHF HClTotalHAPs1.31 0.65 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.0013.69 1.26 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.002.46 0.90 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.001.16 0.52 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.001.45 0.53 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.007.67 2.67 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.002.76 1.01 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.007.88 2.89 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.002.37 0.87 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00142.96 35.22 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.001.89 1.89 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.003.37 8.19 1.3116.21 38.11 1.0521.90 77.09 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.000.01 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.0021.90 77.09 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.000.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Additive Feeder 0.08 0.03 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Surge Bin 0.26 0.10 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Texture Feeder 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Packaging 0.50 0.18 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Space Heaters 0.04 0.17 0.01 2.19 0.12 1.84 0.00 0.00 0.00 0.04Total Total 249.87 249.36 < 250 17.52 2.49 54.40 25.84 < 10 7.45 24.13Limited Emissions (tons/year) without the Use of CEMSPMPM10SO2NOxVOC COTotalFluoridesHF HClTotalHAPs1.31 0.65 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.0013.69 1.26 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.002.46 0.90 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.001.16 0.52 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.001.45 0.53 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.007.67 2.67 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.002.76 1.01 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.007.88 2.89 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.002.37 0.87 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00142.96 35.22 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.001.89 1.89 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.003.37 8.19 1.3116.21 38.11 1.0521.90 77.09 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.000.01 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.0021.90 77.09 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.000.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Additive Feeder 0.08 0.03 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Surge Bin 0.26 0.10 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Texture Feeder 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Packaging 0.50 0.18 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Space Heaters 0.04 0.17 0.01 2.19 0.12 1.84 0.00 0.00 0.00 0.04Total Total 249.87 249.36 249.21 17.52 2.49 54.40 25.84 9.73 7.45 24.137.45 24.097.45249.20 15.33 52.56 25.84 9.73March 29, 2011< 24916.2115.33 < 10Finishing ScreenTransfer Conveyors (70-ton)Storage BinsPrimary CrusherGrinding/Scalping Screen7.45 24.0924.091095.00 15.33 52.56 25.8452.56 25.84Emission UnitsTransfer Conveyors (125-ton)Secondary CrusherTransfer Conveyor (110-ton)Transfer Conveyors (60-ton)PugmillExtrusionBrick DryerNatural Gas-Fired KilnLime Silo - ReceivingLime Silo - DispensingBicarbonate Silo - ReceivingBicarbonate Silo - DispensingEmission UnitsPrimary CrusherGrinding/Scalping ScreenInsignificantActivitiesTransfer Conveyors (125-ton)Secondary CrusherTransfer Conveyor (110-ton)Finishing ScreenTransfer Conveyors (70-ton)Storage BinsTransfer Conveyors (60-ton)PugmillExtrusionBrick DryerNatural Gas-Fired KilnLime Silo - ReceivingLime Silo - DispensingBicarbonate Silo - ReceivingBicarbonate Silo - DispensingInsignificantActivitiesEmission UnitsPrimary CrusherNatural Gas-Fired KilnGrinding/Scalping ScreenTransfer Conveyors (125-ton)Secondary CrusherTransfer Conveyor (110-ton)Finishing ScreenTransfer Conveyors (70-ton)Lime Silo - ReceivingLime Silo - DispensingBicarbonate Silo - ReceivingBicarbonate Silo - DispensingInsignificantActivitiesStorage BinsTransfer Conveyors (60-ton)PugmillExtrusionBrick DryerPage 2 of 13TSD - Appendix AAppendix A: Emission CalculationsAggregate Processing (125 TPH) Particulate EmissionsCompany Name:Brickcraft, LLCAddress City IN Zip:200 North SR 59, Center Point, IN 47840Permit No:T021-23323-00054Plant ID:021-00054Reviewer:John HaneyDate:Process: Rate (tons/hr) PollutantControlledEmissionFactor(lb/ton)ControlledEmissions(tons/yr)Type of ControlControl Eff.(%)UncontrolledEmissions(tons/yr)Primary Crusher125 PM 0.0012 0.66 Baghouse 50.0 1.311.31 tons/yr * 2000 lb/ton÷8760 hr/yr = 0.300 lb/hrPM100.00059 0.32 Baghouse 50.0 0.65Source of Criteria Pollutant Factors:PM2.50.00059 0.32 Baghouse 50.0 0.65SCC# 3-05-020-03**, AP-42, Ch. 11.19, Table 11.19.2-2SCC# 3-05-003-40, AP-42, Ch. 11.3, Table 11.3-2** ControlledBH-1Methodology:Controlled Emissions (tons/yr) = Rate (tons/hr) x Controlled Emission Factor (lbs/ton) x 8760 hrs/yr÷2000 lbs/tonUncontrolled Emissions (tons/yr) = Controlled Emissions (tons/yr)÷(1 - Control Efficiency/100)Process: Rate (tons/hr) PollutantUncontrolledEmissionFactor(lb/ton)UncontrolledEmissions(tons/yr)Type of ControlControl Eff.(%)ControlledEmissions(tons/yr)Grinding and Screening125 PM 0.025 13.69 Baghouse 50.0 6.84P= 125 tons/hrPM100.0023 1.26 Baghouse 50.0 0.63limit = 55.0 x ( 125 ^0.11 )-= 53.5 lb/hr (allowable)Source of Criteria Pollutant Factors:PM2.50.0023 1.26 Baghouse 50.0 0.63SCC# 3-05-003-02**, AP-42, Ch. 11.3, Table 11.3-2with uncontrolled potential:13.69 tons/yr x 2000 lb/ton / 8760 hr/yr = 3.13 lb/hr (capable of complying)** Processing wet materialBH-1Methodology:Uncontrolled Emissions (tons/yr) = Rate (tons/hr) x Uncontrolled Emission Factor (lbs/ton) x 8760 hrs/yr÷2000 lbs/tonControlled Emissions (tons/yr) = Uncontrolled Emissions (tons/yr) x (1 - Control Efficiency/100)Process: Rate (tons/hr) PollutantUncontrolledEmissionFactor(lb/ton)UncontrolledEmissions(tons/yr)Number ofConveyorsTotalUncontrolledEmissions(tons/yr)Type of ControlControl Eff.(%)ControlledEmissions(tons/yr)Transfer Conveyors125 PM 0.003 1.64 3 4.93 Baghouse 50.0 2.46125 tons/hr * 0.003 lb/ton = 0.375 lb/hrPM100.0011 0.60 3 1.81 Baghouse 50.0 0.90Source of Criteria Pollutant Factors:PM2.50.0011 0.60 3 1.81 Baghouse 50.0 0.90SCC# 3-05-020-06**, AP-42, Ch. 11.19, Table 11.19.2-2** UncontrolledBH-1Methodology:Uncontrolled Emissions (tons/yr) = Rate (tons/hr) x Uncontrolled Emission Factor (lbs/ton) x 8760 hrs/yr÷2000 lbs/tonTotal Uncontrolled Emissions (tons/yr) = Uncontrolled Emissions (tons/yr) x Number of ConveyorsControlled Emissions = Total Uncontrolled Emissions (tons/yr) x (1 - Control Efficiency/100)Allowable Emissions:The primary crusher is exempt from 326 IAC 6-3-2 because the crusher has potential emissionsless than 0.551 lb/hr.Allowable Emissions:The following calculations determine PM compliance with 326 IAC 6-3-2 for process weight rates greater than 30 tons per hour:Allowable Emissions:Each conveyor is exempt from 326 IAC 6-3-2 because each conveyor has potentialemissions less than 0.551 lb/hr.March 29, 2011Page 3 of 13TSD - Appendix AAppendix A: Emission CalculationsAggregate Processing (110 TPH) Particulate EmissionsCompany Name:Brickcraft, LLCAddress City IN Zip:200 North SR 59, Center Point, IN 47840Permit No:T021-23323-00054Plant ID:021-00054Reviewer:John HaneyDate:Process: Rate (tons/hr) PollutantControlledEmission Factor(lb/ton)ControlledEmissions(tons/yr)Type of ControlControl Eff.(%)UncontrolledEmissions(tons/yr)Secondary Crusher110 PM 0.0012 0.58 Baghouse 50.0 1.161.16 tons/yr * 2000 lb/ton÷8760 hr/yr = 0.264 lb/hrPM100.00054 0.26 Baghouse 50.0 0.52Source of Criteria Pollutant Factors:PM2.50.00054 0.26 Baghouse 50.0 0.52SCC# 3-05-020-03**, AP-42, Ch. 11.19, Table 11.19.2-2**Use tertiary crushing emission factorsBH-1Methodology:Controlled Emissions (tons/yr) = Rate (tons/hr) x Controlled Emission Factor (lbs/ton) x 8760 hrs/yr÷2000 lbs/tonUncontrolled Emissions (tons/yr) = Controlled Emissions (tons/yr)÷(1 - Control Efficiency/100)Process: Rate (tons/hr) PollutantUncontrolledEmission Factor(lb/ton)UncontrolledEmissions(tons/yr)Number ofConveyorsTotalUncontrolledEmissions(tons/yr)Type of ControlControl Eff.(%)ControlledEmissions(tons/yr)Transfer Conveyor110 PM 0.003 1.45 1 1.45 Baghouse 50.0 0.72110 tons/hr * 0.003 lb/ton = 0.330 lb/hrPM100.0011 0.53 1 0.53 Baghouse 50.0 0.26Source of Criteria Pollutant Factors:PM2.50.0011 0.53 1 0.53 Baghouse 50.0 0.26SCC# 3-05-020-06**, AP-42, Ch. 11.19, Table 11.19.2-2** UncontrolledBH-1Methodology:Uncontrolled Emissions (tons/yr) = Rate (tons/hr) x Uncontrolled Emission Factor (lbs/ton) x 8760 hrs/yr÷2000 lbs/tonTotal Uncontrolled Emissions (tons/yr) = Uncontrolled Emissions (tons/yr) x Number of ConveyorsControlled Emissions (tons/yr) = Total Uncontrolled Emissions (tons/yr) x (1 - Control Efficiency/100)Allowable Emissions:The secondary crusher is exempt from 326 IAC 6-3-2 because the crusher has potentialemissions less than 0.551 lb/hr.Allowable Emissions:Each conveyor is exempt from 326 IAC 6-3-2 because each conveyor has potentialemissions less than 0.551 lb/hr.March 29, 2011Page 4 of 13TSD - Appendix AAppendix A: Emission CalculationsAggregate Processing (70 TPH) Particulate EmissionsCompany Name:Brickcraft, LLCAddress City IN Zip:200 North SR 59, Center Point, IN 47840Permit No:T021-23323-00054Plant ID:021-00054Reviewer:John HaneyDate:Process: Rate (tons/hr) PollutantUncontrolledEmissionFactor(lb/ton)UncontrolledEmissions(tons/yr)Type of ControlControl Eff.(%)ControlledEmissions(tons/yr)Screening70 PM 0.025 7.67 Baghouse 50.0 3.83P= 70 tons/hrPM100.0087 2.67 Baghouse 50.0 1.33limit = 55.0 x ( 70 ^0.11 )-= 47.8 lb/hr (allowable)Source of Criteria Pollutant Factors:PM2.50.0087 2.67 Baghouse 50.0 1.33SCC# 3-05-020-03**, AP-42, Ch. 11.19, Table 11.19.2-2with uncontrolled potential:7.67 tons/yr x 2000 lb/ton / 8760 hr/yr = 1.75 lb/hr (capable of complying)** UncontrolledBH-1Methodology:Uncontrolled Emissions (tons/yr) = Rate (tons/hr) x Uncontrolled Emission Factor (lbs/ton) x 8760 hrs/yr÷2000 lbs/tonControlled Emissions (tons/yr) = Uncontrolled Emissions (tons/yr) x (1 - Control Efficiency/100)Process: Rate (tons/hr) PollutantUncontrolledEmissionFactor(lb/ton)UncontrolledEmissions(tons/yr)Number ofConveyorsTotalUncontrolledEmissions(tons/yr)Type of ControlControl Eff.(%)ControlledEmissions(tons/yr)Transfer Conveyors70 PM 0.003 0.92 3 2.76 Baghouse 50.0 1.3870 tons/hr * 0.003 lb/ton = 0.210 lb/hrPM100.0011 0.34 3 1.01 Baghouse 50.0 0.51Source of Criteria Pollutant Factors:PM2.50.0011 0.34 3 1.01 Baghouse 50.0 0.51SCC# 3-05-020-06**, AP-42, Ch. 11.19, Table 11.19.2-2** UncontrolledBH-1Methodology:Uncontrolled Emissions (tons/yr) = Rate (tons/hr) x Uncontrolled Emission Factor (lbs/ton) x 8760 hrs/yr÷2000 lbs/tonTotal Uncontrolled Emissions (tons/yr) = Uncontrolled Emissions (tons/yr) x Number of ConveyorsControlled Emissions (tons/yr) = Total Uncontrolled Emissions (tons/yr) x (1 - Control Efficiency/100)Allowable Emissions:Each conveyor is exempt from 326 IAC 6-3-2 because each conveyor has potentialemissions less than 0.551 lb/hr.Allowable Emissions:The following calculations determine PM compliance with 326 IAC 6-3-2 for process weight rates greater than 30 tons per hour:March 29, 2011Page 5 of 13TSD - Appendix AAppendix A: Emission CalculationsAggregate Processing (100 TPH) Particulate EmissionsCompany Name:Brickcraft, LLCAddress City IN Zip:200 North SR 59, Center Point, IN 47840Permit No:T021-23323-00054Plant ID:021-00054Reviewer:John HaneyDate:Process: Rate (tons/hr) PollutantUncontrolledEmission Factor(lb/ton)UncontrolledEmissions(tons/yr)Number of BinsTotalUncontrolledEmissions(tons/yr)Type of ControlControl Eff.(%)ControlledEmissions(tons/yr)Crushed Material Storage Bin100 PM 0.003 1.31 6 7.88 Baghouse 50.0 3.94PM100.0011 0.48 6 2.89 Baghouse 50.0 1.45Source of Criteria Pollutant Factors:PM2.50.0011 0.48 6 2.89 Baghouse 50.0 1.45SCC# 3-05-020-06**, AP-42, Ch. 11.19, Table 11.19.2-2**Use uncontrolled conveyor transfer point emission factorsBH-1Methodology:Uncontrolled Emissions (tons/yr) = Rate (tons/hr) x Uncontrolled Emission Factor (lbs/ton) x 8760 hrs/yr÷2000 lbs/tonTotal Uncontrolled Emissions (tons/yr) = Uncontrolled Emissions (tons/yr) x Number of BinsControlled Emissions (tons/yr) = Total Uncontrolled Emissions (tons/yr) x (1 - Control Efficiency/100)Allowable Emissions:The storage bins are exempt from 326 IAC 6-3-2 because each bin has potential emissions less than 0.551 lb/hr.100 tons/hr x 0.003 lb/ton = 0.300 lb/hrMarch 29, 2011Page 6 of 13TSD - Appendix AAppendix A: Emission CalculationsAggregate Processing (60 TPH) Particulate EmissionsCompany Name:Brickcraft, LLCAddress City IN Zip:200 North SR 59, Center Point, IN 47840Permit No:T021-23323-00054Plant ID:021-00054Reviewer:John HaneyDate:Process: Rate (tons/hr) PollutantUncontrolledEmissionFactor(lb/ton)UncontrolledEmissions(tons/yr)Number ofConveyorsTotalUncontrolledEmissions(tons/yr)Type of ControlControl Eff.(%)ControlledEmissions(tons/yr)Transfer Conveyors60 PM 0.003 0.79 3 2.37 Baghouse 50.0 1.1860 tons/hr * 0.003 lb/ton = 0.180 lb/hrPM100.0011 0.29 3 0.87 Baghouse 50.0 0.43Source of Criteria Pollutant Factors:PM2.50.0011 0.29 3 0.87 Baghouse 50.0 0.43SCC# 3-05-020-06**, AP-42, Ch. 11.19, Table 11.19.2-2** UncontrolledBH-1Methodology:Uncontrolled Emissions (tons/yr) = Rate (tons/hr) x Uncontrolled Emission Factor (lbs/ton) x 8760 hrs/yr÷2000 lbs/tonTotal Uncontrolled Emissions (tons/yr) = Uncontrolled Emissions (tons/yr) x Number of ConveyorsControlled Emissions (tons/yr) = Total Uncontrolled Emissions (tons/yr) x (1 - Control Efficiency/100)Process: Rate (tons/hr) PollutantUncontrolledEmissionFactor(lb/ton)UncontrolledEmissions(tons/yr)Type of ControlControl Eff.(%)ControlledEmissions(tons/yr)Additive Feeder6 PM 0.003 0.08 Baghouse 50.0 0.046 tons/hr * 0.003 lb/ton = 0.018 lb/hrPM100.0011 0.03 Baghouse 50.0 0.01Source of Criteria Pollutant Factors:PM2.50.0011 0.03 Baghouse 50.0 0.01SCC# 3-05-020-06**, AP-42, Ch. 11.19, Table 11.19.2-2**Use uncontrolled conveyor transfer point emission factorsBH-1Methodology:Uncontrolled Emissions (tons/yr) = Rate (tons/hr) x Uncontrolled Emission Factor (lbs/ton) x 8760 hrs/yr÷2000 lbs/tonControlled Emissions (tons/yr) = Uncontrolled Emissions (tons/yr) x (1 - Control Efficiency/100)Process: Rate (tons/hr) PollutantUncontrolledEmissionFactor(lb/ton)UncontrolledEmissions(tons/yr)Type of ControlControl Eff.(%)ControlledEmissions(tons/yr)Surge Bin20 PM 0.003 0.26 Baghouse 50.0 0.1320 tons/hr * 0.003 lb/ton = 0.060 lb/hrPM100.0011 0.10 Baghouse 50.0 0.05Source of Criteria Pollutant Factors:PM2.50.0011 0.10 Baghouse 50.0 0.05SCC# 3-05-020-06**, AP-42, Ch. 11.19, Table 11.19.2-2**Use uncontrolled conveyor transfer point emission factorsBH-1Methodology:Uncontrolled Emissions (tons/yr) = Rate (tons/hr) x Uncontrolled Emission Factor (lbs/ton) x 8760 hrs/yr÷2000 lbs/tonControlled Emissions = Uncontrolled Emissions (tons/yr) x (1 - Control Efficiency/100)Process: Rate (tons/hr) PollutantUncontrolledEmissionFactor(lb/ton)UncontrolledEmissions(tons/yr)Type of ControlControl Eff.(%)ControlledEmissions(tons/yr)Pugmill60 PM 0.544 142.96 Baghouse 50.0 71.48P= 60 tons/hrPM100.134 35.22 Baghouse 50.0 17.61limit = 55.0 x ( 60 ^0.11 ) = 46.3 lb/hr (allowable)Source of Criteria Pollutant Factors:PM2.50.134 35.22 Baghouse 50.0 17.61SCC# 3-05-011-09**, AP-42, Ch. 11.12, Table 11.12-2with uncontrolled potential:142.96 tons/yr x 2000 lb/ton / 8760 hr/yr = 32.64 lb/hr (capable of complying)**Use uncontrolled mixer loading (central mix) emission factorsBH-2Methodology:Uncontrolled Emissions (tons/yr) = Rate (tons/hr) x Uncontrolled Emission Factor (lbs/ton) x 8760 hrs/yr÷2000 lbs/tonControlled Emissions = Uncontrolled Emissions (tons/yr) x (1 - Control Efficiency/100)Process: Rate (tons/hr) PollutantControlledEmissionFactor(lb/ton)ControlledEmissions(tons/yr)Type of ControlControl Eff.(%)UncontrolledEmissions(tons/yr)Extrusion Operation60 PM 0.0036 0.95 see note** 50.0 1.891.89 tons/yr * 2000 lb/ton÷8760 hr/yr = 0.432 lb/hrPM100.0036 0.95 see note** 50.0 1.89Source of Criteria Pollutant Factors:PM2.50.0036 0.95 see note** 50.0 1.89SCC# 3-05-003-42**, AP-42, Ch. 11.3, Table 11.3-2**Emission factor includes the use of a fabric filter control deviceMethodology:Controlled Emissions (tons/yr) = Rate (tons/hr) x Controlled Emission Factor (lbs/ton) x 8760 hrs/yr÷2000 lbs/tonUncontrolled Emissions = Controlled Emissions (tons/yr)÷(1 - Control Efficiency/100)Process: Rate (tons/hr) PollutantUncontrolledEmissionFactor(lb/ton)UncontrolledEmissions(tons/yr)Type of ControlControl Eff.(%)ControlledEmissions(tons/yr)Texture Feeder0.25 PM 0.003 0.0033 Baghouse 50.0 0.000.25 tons/hr * 0.003 lb/ton = 0.001 lb/hrPM100.0011 0.0012 Baghouse 50.0 0.00Source of Criteria Pollutant Factors:PM2.50.0011 0.0012 Baghouse 50.0 0.00SCC# 3-05-020-06**, AP-42, Ch. 11.19, Table 11.19.2-2**Use uncontrolled conveyor transfer point emission factorsBH-2Methodology:Uncontrolled Emissions (tons/yr) = Rate (tons/hr) x Uncontrolled Emission Factor (lbs/ton) x 8760 hrs/yr÷2000 lbs/tonControlled Emissions = Uncontrolled Emissions (tons/yr) x (1 - Control Efficiency/100)Process: Rate (tons/hr) PollutantUncontrolledEmissionFactor(lb/ton)UncontrolledEmissions(tons/yr)Type of ControlControl Eff.(%)ControlledEmissions(tons/yr)Packaging38 PM 0.003 0.50 Baghouse 50.0 0.2538.00 tons/hr * 0.003 lb/ton = 0.114 lb/hrPM100.0011 0.18 Baghouse 50.0 0.09Source of Criteria Pollutant Factors:PM2.50.0011 0.18 Baghouse 50.0 0.09SCC# 3-05-020-06**, AP-42, Ch. 11.19, Table 11.19.2-2**Use uncontrolled conveyor transfer point emission factorsBH-2Methodology:Uncontrolled Emissions (tons/yr) = Rate (tons/hr) x Uncontrolled Emission Factor (lbs/ton) x 8760 hrs/yr÷2000 lbs/tonControlled Emissions = Uncontrolled Emissions (tons/yr) x (1 - Control Efficiency/100)Allowable Emissions:The packaging operation is exempt from 326 IAC 6-3-2 because it has potential emissionsless than 0.551 lb/hr.Allowable Emissions:The texture feeder is exempt from 326 IAC 6-3-2 because each conveyor has potentialemissions less than 0.551 lb/hr.March 29, 2011Allowable Emissions:Each conveyor is exempt from 326 IAC 6-3-2 because each conveyor has potentialemissions less than 0.551 lb/hr.Allowable Emissions:The additive feeder is exempt from 326 IAC 6-3-2 because the feeder has potential emissionsless than 0.551 lb/hr.Allowable Emissions:The surge bin is exempt from 326 IAC 6-3-2 because each conveyor has potential emissionsless than 0.551 lb/hr.Allowable Emissions:The following calculations determine PM compliance with 326 IAC 6-3-2 for process weight rates greater than 30 tons per hour:Allowable Emissions:The extrusion operation is exempt from 326 IAC 6-3-2 because the operation has potentialemissions less than 0.551 lb/hr.Page 7 of 13
TSD - Appendix A

Appendix A: Emission Calculations Brick Dryer

Company Name: Brickcraft, LLC Address City IN Zip: 200 North SR 59, Center Point, IN 47840

Permit No: T021-23323-00054

Plant ID: 021-00054

Reviewer: John Haney

Date:

Process: Rate (tons/hr) Pollutant Emission

Factor (lb/ton) Uncontrolled

Emissions (tons/yr) Type of Control Control Eff. (%) Controlled

Emissions (tons/yr)

Brick Dryer 10.00 PM 0.077 3.37 none 0.0 3.37

PM 10 0.187 8.19 none 0.0 8.19

Source of Criteria PM 2.5 0.187 8.19 none 0.0 8.19

Pollutant Factors: SO 2 *see note 0.00 none 0.0 0.00

SCC# 3-05-003-50 NO

x *see note 0.00 none 0.0 0.00

AP-42 Ch. 11.3 VOC 0.03 1.31 none 0.0 1.31

CO *see note 0.00 none 0.0 0.00

fluorides *see note 0.00 none 0.0 0.00

HF *see note 0.00 none 0.0 0.00

HCl *see note 0.00 none 0.0 0.00

total HAPs *see note 0.00 none 0.0 0.00

* These emissions have been included with the kiln.

Allowable Emissions:

The following calculations determine PM compliance with 326 IAC 6-3-2 for process weight rates less than 30 tons per hour:

P= 10.00 tons/hr limit = 4.1 x ( 10.00 ^0.67 ) = 19.18 lb/hr (allowable)

with uncontrolled potential: 3.37 tons/yr x 2000 lb/ton / 8760 hr/yr = 0.77 lb/hr (capable of complying)

Methodology: Uncontrolled Emissions (tons/yr) = Rate (tons/hr) x Factor (lbs/ton) x 8760 hrs/yr ÷ 2000 lbs/ton Controlled Emissions (tons/yr) = Uncontrolled Emissions (tons/yr) x (1 - Control Efficiency/100) March 29, 2011Page 8 of 13 TSD - Appendix A

Appendix A: Emission Calculations

Natural Gas-Fired Kiln

Company Name: Brickcraft, LLC Address City IN Zip: 200 North SR 59, Center Point, IN 47840

Permit No: T021-23323-00054

Plant ID: 021-00054

Reviewer: John Haney

Date:

Process: Rate (tons/hr) Pollutant Emission

Factor (lb/ton) Uncontrolled

Emissions (tons/yr) Type of

Control Control Eff.
(%) Controlled

Emissions (tons/yr)

Natural Gas-Fired Kiln 10.00 PM 0.37 16.21 DIFF 50.0 8.10

(with no back-up fuel) PM 10 0.87 38.11 DIFF 50.0 19.05

PM 2.5 0.87 38.11 DIFF 50.0 19.05

Source of Criteria SO 2 25.00 1095.00 DIFF * see below 249.20

Pollutant Factors: NO

x 0.35 15.33 none 0.0 15.33

SCC# 3-05-003-11 VOC 0.024 1.05 none 0.0 1.05

AP-42 Ch. 11.3 CO 1.2 52.56 none 0.0 52.56

fluorides 0.59 25.84 DIFF 40.0 15.52

HF 0.37 16.21 DIFF * see below 9.73

HCl 0.17 7.45 DIFF 40.0 4.47

total HAPs 0.55 24.09 DIFF 40.0 14.46

SO 2 emissions when bypassing the dry injection fabric filter (DIFF):

( 10.00 tons/hr ) x ( 25.00 lb/ton ) x ( 125 hr/yr ) x ( 1 ton/2000 lb ) = 15.63 tpy

SO 2 emissions controlled by the dry injection fabric filter (DIFF):

( 10.00 tons/hr ) x ( 5.41 lb/ton ) x ( 8635 hr/yr ) x ( 1 ton/2000 lb ) = 233.58 tpy
249.20 tpy

HF emissions when bypassing the dry injection fabric filter (DIFF):
( 10.00 tons/hr ) x ( 0.37 lb/ton ) x ( 125 hr/yr ) x ( 1 ton/2000 lb ) = 0.23 tpy HF emissions controlled by the dry injection fabric filter (DIFF):
( 10.00 tons/hr ) x ( 0.22 lb/ton ) x ( 8635 hr/yr ) x ( 1 ton/2000 lb ) = 9.50 tpy
9.73 tpy

( 16.21 - 9.73 ) ÷ 16.21 x 100 = 40.0 % CE

Allowable Emissions:

P= 10.00 tons/hr limit = 4.1 x ( 10.00 ^0.67 ) = 19.18 lb/hr (allowable)

with uncontrolled potential: 16.21 tons/yr x 2000 lb/ton / 8760 hr/yr = 3.70 lb/hr (capable of complying)

Methodology:

Emission factor for SO 2 is from mass balance using worse case material while keeping the source below 250 tpy after control.

Uncontrolled Emissions (tons/yr) = Rate (tons/hr) x Factor (lbs/ton) x 8760 hrs/yr ÷ 2000 lbs/ton Controlled Emissions (tons/yr) = Uncontrolled Emissions (tons/yr) x (1 - Control Efficiency/100) March 29, 2011

The following calculations determine PM compliance with 326 IAC 6-3-2 for process weight rates less than 30 tons per hour:Page 9 of 13 TSD - Appendix A

Appendix A: Emission Calculations One (1) Storage Silo - Powdered Lime - Receiving

Company Name: Brickcraft, LLC Address City IN Zip: 200 North SR 59, Center Point, IN 47840

Permit No: T021-23323-00054

Plant ID: 021-00054

Reviewer: John Haney

Date:

1. Process Descriptions:

The lime is delivered via tank trucks, and the silo is filled pneumatically. The DIFF is used to equalize the pressure and to prevent material from being emitted to the atmosphere.

Max Throughput: 25.0 tons/hr

Uncontrolled Emission Factors Controlled Emission Factors

PM Emission Factor: 3.14 lbs/ton PM Emission Factor: 0.0089 lbs/ton

PM 10 Emission Factor: 1.10 lbs/ton PM 10 Emission Factor: 0.0049 lbs/ton

PM 2.5 Emission Factor: 1.10 lbs/ton PM 2.5 Emission Factor: 0.0049 lbs/ton

Emission Factors are from AP-42, Tables 11.12-2, SCC #3-05-011-17 (Cement supplement unloading to elevated storage silo (pneumatic), AP-42, 06/06).

PM 2.5 has been assumed equal to PM 10

. There is no emission factor for lime loading in AP-42.

2. Potential Uncontrolled Emissions:

Throughput Emissions Emissions Emissions

(tons/hr) PM (tons/yr) PM 10 ( tons/ y r ) PM 2.5 ( tons/ y r )

1 Silo 25.0 343.83 120.45 120.45

3. Controlled Emissions:

Throughput Emissions Emissions Emissions

(tons/hr) PM (tons/yr) PM 10 ( tons/ y r ) PM 2.5 ( tons/ y r )

1 Silo 25.0 0.97 0.54 0.54

4. Limited Emissions:

PM emissions controlled by the dry injection fabric filter (DIFF): ( 25.0 tons/hr ) x ( 0.200 lb/ton ) x ( 8760 hr/yr ) x ( 1 ton/2000 lb ) = 21.90 tpy ( 25.0 tons/hr ) x ( 0.200 lb/ton ) = 5.00 lb/hr

PM 10 emissions controlled by the dry injection fabric filter (DIFF):

( 25.0 tons/hr ) x ( 0.704 lb/ton ) x ( 8760 hr/yr ) x ( 1 ton/2000 lb ) = 77.09 tpy ( 25.0 tons/hr ) x ( 0.704 lb/ton ) = 17.60 lb/hr

5. Allowable Emissions:

P= 25 tons/hr limit = 4.1 x ( 25 ^0.67 ) = 35.4 lb/hr (allowable)

with uncontrolled potential:

343.83 tons/yr x 2000 lb/ton / 8760 hr/yr = 78.50 lb/hr (will not comply)

with controlled potential: 0.97 tons/yr x 2000 lb/ton / 8760 hr/yr = 0.22 lb/hr (capable of complying)

Methodology Emissions (tons/yr) = Throughput (tons/hr) * Emission Factor (lb/ton) * 8760 hr/yr ÷ 2000 lb/ton Unit Unit March 29, 2011

The following calculations determine PM compliance with 326 IAC 6-3-2 for process weight rates less than 30 tons per hour:Page 10 of 13TSD - Appendix AAppendix A: Emission CalculationsOne (1) Storage Silo - Powdered Lime - DispensingCompany Name:Brickcraft, LLCAddress City IN Zip:200 North SR 59, Center Point, IN 47840Permit No:T021-23323-00054Plant ID:021-00054Reviewer:John HaneyDate:Max Throughput: 1042 lb/hrProcess: Rate (tons/hr) PollutantUncontrolledEmission Factor(lb/ton)UncontrolledEmissions(tons/yr)Type of ControlControl Eff.(%)ControlledEmissions(tons/yr)Lime Dispensing/Injecting0.521 PM 0.003 0.01 DIFF 50.0 0.00PM100.0011 0.00 DIFF 50.0 0.00Source of Criteria Pollutant Factors:PM2.50.0011 0.00 DIFF 50.0 0.00SCC# 3-05-020-06**, AP-42, Ch. 11.19, Table 11.19.2-2**Use uncontrolled conveyor transfer point emission factorsMethodology:Maximum Throughput (125 lb/hr using 12% motor output) = 125 lb/hr÷0.12 = 1042 lb/hrUncontrolled Emissions (tons/yr) = Rate (tons/hr) x Uncontrolled Emission Factor (lbs/ton) x 8760 hrs/yr÷2000 lbs/tonControlled Emissions (tons/yr) = Uncontrolled Emissions (tons/yr) x (1 - Control Efficiency/100)Allowable Emissions:The lime dispensing system is exempt from 326 IAC 6-3-2 because the system has potential emissions less than 0.551 lb/hr.0.521 tons/hr x 0.003 lb/ton = 0.002 lb/hrMarch 29, 2011Page 11 of 13
TSD - Appendix A

Appendix A: Emission Calculations One (1) Storage Silo - Sodium Bicarbonate - Receiving

Company Name: Brickcraft, LLC Address City IN Zip: 200 North SR 59, Center Point, IN 47840

Permit No: T021-23323-00054

Plant ID: 021-00054

Reviewer: John Haney

Date:

1. Process Descriptions:

The sodium bicarbonate is delivered via tank trucks, and the silo is filled pneumatically. The DIFF is used to equalize the pressure and to prevent material from being emitted to the atmosphere.

Max Throughput: 25.0 tons/hr

Uncontrolled Emission Factors Controlled Emission Factors

PM Emission Factor: 3.14 lbs/ton PM Emission Factor: 0.0089 lbs/ton

PM 10 Emission Factor: 1.10 lbs/ton PM 10 Emission Factor: 0.0049 lbs/ton

PM 2.5 Emission Factor: 1.10 lbs/ton PM 2.5 Emission Factor: 0.0049 lbs/ton

Emission Factors are from AP-42, Tables 11.12-2, SCC #3-05-011-17 (Cement supplement unloading to elevated storage silo (pneumatic), AP-42, 06/06).

PM 2.5 has been assumed equal to PM 10

. There is no emission factor for sodium bicarbonate loading in AP-42.

2. Potential Uncontrolled Emissions:

Throughput Emissions Emissions Emissions

(tons/hr) PM (tons/yr) PM 10 ( tons/ y r ) PM 2.5 ( tons/ y r )

1 Silo 25 343.83 120.45 120.45

3. Controlled Emissions:

Throughput Emissions Emissions Emissions

(tons/hr) PM (tons/yr) PM 10 ( tons/ y r ) PM 2.5 ( tons/ y r )

1 Silo 25 0.97 0.54 0.54

4. Limited Emissions:

PM emissions controlled by the dry injection fabric filter (DIFF): ( 25.0 tons/hr ) x ( 0.200 lb/ton ) x ( 8760 hr/yr ) x ( 1 ton/2000 lb ) = 21.90 tpy ( 25.0 tons/hr ) x ( 0.200 lb/ton ) = 5.00 lb/hr

PM 10 emissions controlled by the dry injection fabric filter (DIFF):

( 25.0 tons/hr ) x ( 0.704 lb/ton ) x ( 8760 hr/yr ) x ( 1 ton/2000 lb ) = 77.09 tpy ( 25.0 tons/hr ) x ( 0.704 lb/ton ) = 17.60 lb/hr

5. Allowable Emissions:

P= 25 tons/hr limit = 4.1 x ( 25 ^0.67 ) = 35.4 lb/hr (allowable)

with uncontrolled potential:

343.83 tons/yr x 2000 lb/ton / 8760 hr/yr = 78.50 lb/hr (will not comply)

with controlled potential: 0.97 tons/yr x 2000 lb/ton / 8760 hr/yr = 0.22 lb/hr (capable of complying)

Methodology Emissions (tons/yr) = Throughput (tons/hr) * Emission Factor (lb/ton) * 8760 hr/yr ÷ 2000 lb/ton Unit Unit March 29, 2011

The following calculations determine PM compliance with 326 IAC 6-3-2 for process weight rates less than 30 tons per hour:Page 12 of 13TSD - Appendix AAppendix A: Emission CalculationsOne (1) Injection System - Sodium Bicarbonate - DispensingCompany Name:Brickcraft, LLCAddress City IN Zip:200 North SR 59, Center Point, IN 47840Permit No:T021-23323-00054Plant ID:021-00054Reviewer:John HaneyDate:Max Throughput: 545 lb/hrProcess: Rate (tons/hr) PollutantUncontrolledEmission Factor(lb/ton)UncontrolledEmissions(tons/yr)Type of ControlControl Eff.(%)ControlledEmissions(tons/yr)Sodium Bicarbonate Dispensing/Injecting0.273 PM 0.003 0.00 DIFF 50.0 0.00PM100.0011 0.00 DIFF 50.0 0.00Source of Criteria Pollutant Factors:PM2.50.0011 0.00 DIFF 50.0 0.00SCC# 3-05-020-06**, AP-42, Ch. 11.19, Table 11.19.2-2**Use uncontrolled conveyor transfer point emission factorsMethodology:Maximum Throughput (60 lb/hr using 11% motor output) = 60 lb/hr÷0.11 = 545 lb/hrUncontrolled Emissions (tons/yr) = Rate (tons/hr) x Uncontrolled Emission Factor (lbs/ton) x 8760 hrs/yr÷2000 lbs/tonControlled Emissions (tons/yr) = Uncontrolled Emissions (tons/yr) x (1 - Control Efficiency/100)Allowable Emissions:The bicarbonate dispensing system is exempt from 326 IAC 6-3-2 because the system has potential emissions less than 0.551 lb/hr.0.273 tons/hr x 0.003 lb/ton = 0.001 lb/hrMarch 29, 2011Page 13 of 13TSD - Appendix AAppendix A: Emissions CalculationsNatural Gas Combustion Only (MMBtu/hr <100)Company Name:Brickcraft, LLCAddress City IN Zip:200 North SR 59, Center Point, IN 47840Permit No:T021-23323-00054Plant ID:021-00054Reviewer:John HaneyDate:Combined Heat Input Capacity Potential ThroughputMMBtu/hr MMcf/yr5.1 43.8PM*PM10* PM2.5* SO2NOxVOC COEmission Factor in lb/MMcf 1.9 7.6 7.6 0.6 100.0 5.5 84.0**see belowPotential Emissions in tons/yr 0.04 0.17 0.17 0.01 2.19 0.12 1.84Benzene Dichlorobenzene Formaldehyde Hexane TolueneEmission Factor in lb/MMcf 2.1E-03 1.2E-03 7.5E-02 1.8E+00 3.4E-03Potential Emissions in tons/yr 4.599E-05 2.628E-05 1.643E-03 3.942E-02 7.446E-05Lead Cadmium Chromium Manganese NickelEmission Factor in lb/MMcf 5.0E-04 1.1E-03 1.4E-03 3.8E-04 2.1E-03Potential Emissions in tons/yr 1.095E-05 2.409E-05 3.066E-05 8.322E-06 4.599E-05Methodology:All emission factors are based on normal firing.MMBtu = 1,000,000 BtuMMcf = 1,000,000 cubic feet of gasEmission 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 (Supplement D 3/98).Potential Throughput (MMcf/yr) = Heat Input Capacity (MMBtu/hr) x 8,760 hrs/yr x 1 MMcf/1,020 MMBtuPotential Emissions(tons/yr)= Throughput(MMcf/yr)x Emission Factor(lb/MMcf)÷2,000 lb/tonPollutant* PM emission factor is filterable PM only. PM10emission factor is filterable and condensable PM10combined.HAPs - Metals** Emission Factors for NOx: Uncontrolled = 100, Low NOxBurner = 50, Low NOxBurners/Flue gas recirculation = 32HAPs - OrganicsMarch 29, 2011

## I NDIANA 

## D EPARTMENT OF 

## E NVIRONMENTAL 

## M ANAGEMENT

We Protect Hoosiers and Our Environment.

Mitchell E. Daniels Jr. 100 North Senate Avenue

Governor Indianapolis, Indiana 46204 (317) 232-8603
Thomas W. Easterly Toll Free (800) 451-6027

Commissioner www.idem.IN.gov

Recycled Paper An Equal Opportunity Employer Please Recycle SENT VIA U.S. MAIL: CONFIRMED DELIVERY AND SIGNATURE REQUESTED

TO: Roy Lamar Brickcraft, LLC

200 North SR 59 Center Point, IN 47840

DATE: June 21, 2011

FROM: Matt Stuckey, Branch Chief

Permits Branch Office of Air Quality

SUBJECT: Final Decision

Title V - Transition from MSOP

021 - 23323 - 00054

Enclosed is the final decision and supporting material s for the air permit application referenced above. Please note that this packet contains the original, signed, permit documents.

The final decision is being sent to you because our reco rds indicate that you are the contact person for this application. However, if you are no t the appropriate person within your company to receive this document, please forward it to the correct person.

A copy of the final decision and supporting mate rials has also been sent via standard mail to:

Bill Mast President Brickcraft

Jim Heim Bruce Carter Associates
OAQ Permits Branch Interested Parties List

If you have technical questions regarding the enclosed doc uments, please contact the Office of Air Quality, Permits Branch at (317) 233-0178, or toll-free at 1-800-451-6027 (ext. 3-0178), and ask to speak to the permit reviewer who prepared the permit. If you thin k you have received this do cument in error, please contact Joanne Smiddie-Brush of my staff at 1-800-451-6027 (ext 3-0185), or via e-mail at jbrush@idem.IN.gov

.

Final Applicant Cover letter.dot 11/30/07

## I NDIANA 

## D EPARTMENT OF 

## E NVIRONMENTAL 

## M ANAGEMENT

We Protect Hoosiers and Our Environment.

Mitchell E. Daniels Jr. 100 North Senate Avenue

Governor Indianapolis, Indiana 46204 (317) 232-8603
Thomas W. Easterly Toll Free (800) 451-6027

Commissioner www.idem.IN.gov

Recycled Paper An Equal Opportunity Employer Please Recycle 

### June 21, 2011

TO: Clay County Genealogy Library

From: Matthew Stuckey, Branch Chief

Permits Branch Office of Air Quality

Subject: Important Information for Display Regarding a Final Determination

Applicant Name: Brickcraft, LLC

Permit Number: 021 - 23323 - 00054

You previously received information to make av ailable to the public during the public comment period of a draft permit. Enclosed is a copy of the final decision and supporting materials for the same project. Please place the enclosed information along with the information you previously received. To ensure that your patrons have am ple opportunity to review the enclosed permit, we ask that you retain this document for at least 60 days.

The applicant is responsible for placing a copy of the application in your library. If the permit application is not on file, or if you have any questions concerning this public review process, please contact Joanne Smiddie-Brush, OAQ Permits Administration Section at 1-800-451-6027,

extension 3-0185.

Enclosures Final Library.dot 11/30/07FACSIMILIE OF PS Form 3877Mail Code 61-53IDEM Staff LPOGOST 6/21/2011Brickcraft,LLC 021 - 23323 - 00054/final)AFFIX STAMPHERE IFUSED ASCERTIFICATEOF MAILINGName andaddress ofSender►Indiana Department of EnvironmentalManagementOffice of Air Quality – Permits Branch100 N. SenateIndianapolis, IN 46204Type of Mail:CERTIFICATE OFMAILING ONLYLine ArticleNumberName, Address, Street and Post Office Address Postage HandingChargesAct. Value(If Registered)InsuredValueDue Send ifCODR.R.FeeS.D. Fee S.H.FeeRest.Del. FeeRemarks1Roy Lamar Brickcraft, LLC 200 North SR 59 CenterPoint IN 47840 (Source CAATS) Via confirmed delivery2Bill Mast President Brickcraft, LLC 1946 Turner Ave. NW Grand Rapids MI 49504(RO CAATS)3Clay County Health Department 1214 E National Ave #B110 Brazil IN 47834-2718(Health Department)4Center Point Town Council P.O. Box 177 Center Point IN 47840(Local Official)5Clay County Board of Commissioners 609 E. National St. Brazil IN 47834(Local Official)6James & Margaret Butt 087 E SR 46 Center Point IN 47840(Affected Party)7Ephrian Edwards 340 E Private Road 10 Center Point IN 47840(Affected Party)8Mr. Leroy Sutton 422 E Ashboro Road Center Point IN 47840(Affected Party)9Clay County Highway Department 409 N SR 59 Center Point IN 47840(Affected State)10Jim Heim Bruce Carter Associates 616 South 4th Street Elkhart IN 46516(Consultant)11Clay County Genealogy Library 309 East Main Street Center Point IN 47840(Library)12131415Total number of piecesListed by SenderTotal number of PiecesReceived at Post OfficePostmaster, Per (Name ofReceiving employee)The full declaration of value is required on all domestic and international registered mail. Themaximum indemnity payable for the reconstruction of nonnegotiable documents under ExpressMail document reconstructing insurance is $50,000 perpiece subject to a limit of $50, 000 peroccurrence. The maximum indemnity payable onExpress mil merchandise insurance is $500.The maximum indemnity payable is $25,000 for registered mail, sent with optional postalinsurance. SeeDomestic Mail ManualR900, S913, andS921for limitations of coverage oninured and COD mail. SeeInternational Mail Manualfor limitations o coverage on internationalmail. Special handling charges apply only to Standard Mail (A) and Standard Mail (B) parcels.