notice of decision: approval -effective immediatelypermits.air.idem.in.gov/35908f.pdf(2) one (1) fly...

Indiana Department of Environmental Management We Protect Hoosiers and Our Environment.

100 N. Senate Avenue • Indianapolis, IN 46204

(800) 451-6027 • (317) 232-8603 • www.idem.IN.gov

Michael R. Pence Carol S. Comer Governor Commissioner

An Equal Opportunity Employer

Recycled Paper

To: Interested Parties Date: August 30, 2016 From: Matthew Stuckey, Chief Permits Branch Office of Air Quality Source Name: New NGC d/b/a National Gypsum Co. Permit Level: FESOP – Significant Permit Revision Permit Number: 165-35908-00081 Source Location: 75 Ivy Lane Clinton, Indiana 47842 Type of Action Taken: Revisions to permit requirements

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 matter referenced above. The final decision is available on the IDEM website at: http://www.in.gov/apps/idem/caats/ To view the document, select Search option 3, then enter permit 35908. If you would like to request a paper copy of the permit document, please contact IDEM’s central file room:

Indiana Government Center North, Room 1201 100 North Senate Avenue, MC 50-07 Indianapolis, IN 46204 Phone: 1-800-451-6027 (ext. 4-0965) Fax (317) 232-8659

Pursuant to IC 13-15-5-3, this permit is effective immediately, unless a petition for stay of effectiveness is filed and granted according to IC 13-15-6-3, and may be revoked or modified in accordance with the provisions of IC 13-15-7-1.

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If you wish to challenge this decision, IC 4-21.5-3 and IC 13-15-6-1 require that you file a petition for administrative review. This petition may include a request for stay of effectiveness and must be submitted to the Office of Environmental Adjudication, 100 North Senate Avenue, Government Center North, Suite N 501E, Indianapolis, IN 46204, within eighteen (18) calendar days of the mailing of this notice. The filing of a petition for administrative review is complete on the earliest of the following dates that apply to the filing: (1) the date the document is delivered to the Office of Environmental Adjudication (OEA); (2) the date of the postmark on the envelope containing the document, if the document is mailed to

OEA by U.S. mail; or (3) The date on which the document is deposited with a private carrier, as shown by receipt issued

by the carrier, if the document is sent to the OEA by private carrier. The petition must include facts demonstrating that you are either the applicant, a person aggrieved or adversely affected by the decision or otherwise entitled to review by law. Please identify the permit, decision, or other order for which you seek review by permit number, name of the applicant, location, date of this notice and all of the following: (1) the name and address of the person making the request; (2) the interest of the person making the request; (3) identification of any persons represented by the person making the request; (4) the reasons, with particularity, for the request; (5) the issues, with particularity, proposed for considerations at any hearing; and (6) identification of the terms and conditions which, in the judgment of the person making the

request, would be appropriate in the case in question to satisfy the requirements of the law governing documents of the type issued by the Commissioner.

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

Enclosures Final-Permit 2/17/16

http://www.in.gov/ai/appfiles/idem-caats/

http://www.in.gov/idem/5881.htm


New NGC d/b/a National Gypsum Co. Significant Permit Revision 165-35908-00081 Page 2 of 33 Clinton, Indiana Revised By: Brian Wright F165-27682-00081 Permit Reviewer: Swarna Prabha

TABLE OF CONTENTS

SECTION A SOURCE SUMMARY ......................................................................................................... 4

A.1 General Information [326 IAC 2-8-3(b)] A.2 Emission Units and Pollution Control Equipment Summary [326 IAC 2-8-3(c)(3)] A.3 Insignificant Activities [326 IAC 2-7-1(21)][326 IAC 2-8-3(c)(3)(I)] A.4 FESOP Applicability [326 IAC 2-8-2]

SECTION B GENERAL CONDITIONS ................................................................................................... 6

B.1 Definitions [326 IAC 2-8-1] B.2 Permit Term [326 IAC 2-8-4(2)][326 IAC 2-1.1-9.5][IC 13-15-3-6(a)] B.3 Term of Conditions [326 IAC 2-1.1-9.5] B.4 Enforceability [326 IAC 2-8-6] [IC 13-17-12] B.5 Severability [326 IAC 2-8-4(4)] B.6 Property Rights or Exclusive Privilege [326 IAC 2-8-4(5)(D)] B.7 Duty to Provide Information [326 IAC 2-8-4(5)(E)] B.9 Annual Compliance Certification [326 IAC 2-8-5(a)(1)] B.10 Compliance Order Issuance [326 IAC 2-8-5(b)] B.11 Preventive Maintenance Plan [326 IAC 1-6-3][326 IAC 2-8-4(9)] B.12 Emergency Provisions [326 IAC 2-8-12] B.13 Prior Permits Superseded [326 IAC 2-1.1-9.5] B.14 Termination of Right to Operate [326 IAC 2-8-9][326 IAC 2-8-3(h)] B.15 Permit Modification, Reopening, Revocation and Reissuance, or Termination

[326 IAC 2-8-4(5)(C)][326 IAC 2-8-7(a)][326 IAC 2-8-8] B.16 Permit Renewal [326 IAC 2-8-3(h)] B.17 Permit Amendment or Revision [326 IAC 2-8-10][326 IAC 2-8-11.1] B.18 Operational Flexibility [326 IAC 2-8-15][326 IAC 2-8-11.1] B.19 Source Modification Requirement [326 IAC 2-8-11.1] B.20 Inspection and Entry [326 IAC 2-8-5(a)(2)][IC 13-14-2-2][IC 13-17-3-2][IC 13-30-3-1] B.21 Transfer of Ownership or Operational Control [326 IAC 2-8-10] B.22 Annual Fee Payment [326 IAC 2-7-19] [326 IAC 2-8-4(6)]

[326 IAC 2-8-16][326 IAC 2-1.1-7] B.23 Credible Evidence [326 IAC 2-8-4(3)][326 IAC 2-8-5][62 FR 8314] [326 IAC 1-1-6]

SECTION C SOURCE OPERATION CONDITIONS ............................................................................. 15

Emission Limitations and Standards [326 IAC 2-8-4(1)] ......................................................... 15 C.1 Particulate Emission Limitations For Processes with Process Weight Rates Less

Than One Hundred (100) Pounds per Hour [326 IAC 6-3-2] C.2 Overall Source Limit [326 IAC 2-8] C.3 Opacity [326 IAC 5-1] C.4 Open Burning [326 IAC 4-1] [IC 13-17-9] C.5 Incineration [326 IAC 4-2] [326 IAC 9-1-2] C.6 Fugitive Dust Emissions [326 IAC 6-4] C.7 Asbestos Abatement Projects [326 IAC 14-10] [326 IAC 18] [40 CFR 61, Subpart M] C.8 Performance Testing [326 IAC 3-6] C.9 Compliance Requirements [326 IAC 2-1.1-11] C.10 Compliance Monitoring [326 IAC 2-8-4(3)][326 IAC 2-8-5(a)(1)] C.11 Instrument Specifications [326 IAC 2-1.1-11] [326 IAC 2-8-4(3)][326 IAC 2-8-5(1)] Corrective Actions and Response Steps [326 IAC 2-8-4][326 IAC 2-8-5(a)(1)] ..................... 18 C.12 Risk Management Plan [326 IAC 2-8-4] [40 CFR 68] C.13 Response to Excursions or Exceedances [326 IAC 2-8-4] [326 IAC 2-8-5] C.14 Actions Related to Noncompliance Demonstrated by a Stack Test

[326 IAC 2-8-4][326 IAC 2-8-5] Record Keeping and Reporting Requirements [326 IAC 2-8-4(3)] ......................................... 19 C.15 General Record Keeping Requirements [326 IAC 2-8-4(3)] [326 IAC 2-8-5]


C.16 General Reporting Requirements [326 IAC 2-8-4(3)(C)] [326 IAC 2-1.1-11] Stratospheric Ozone Protection ................................................................................................. 21 C.17 Compliance with 40 CFR 82 and 326 IAC 22-1

SECTION D.1 EMISSIONS UNIT OPERATION CONDITIONS .............................................................. 22

Emission Limitations and Standards [326 IAC 2-8-4(1)] ......................................................... 23 D.1.1 Particulate [326 IAC 6-3-2] D.1.2 Particulate Matter (PM) [326 IAC 2-2] D.1.3 Particulate Matter (PM10), (PM2.5) [326 IAC 2-8-4] [326 IAC 2-2] D.1.4 VOC [326 IAC 8-1-6] [326 IAC 2-8-4] D.1.5 Preventive Maintenance Plan [326 IAC 2-8-4(9)] D.1.6 Particulate Control D.1.7 Volatile Organic Compounds (VOC) [326 IAC 8-1-2] [326 IAC 8-1-4] D.1.8 Visible Emissions Notations D.1.9 Broken or Failed Cartridge Detection D.1.10 Record Keeping Requirements D.1.11 Reporting Requirements

SECTION D.2 FACILITY OPERATION CONDITIONS ........................................................................... 27

D.2.1 Particulate [326 IAC 6-2-4] CERTIFICATION ........................................................................................................................................ 28 EMERGENCY OCCURRENCE REPORT .................................................................................................. 29

FESOP Quarterly Report .......................................................................................................................... 31

QUARTERLY DEVIATION AND COMPLIANCE MONITORING REPORT .............................................. 32


SECTION A SOURCE SUMMARY

This permit is based on information requested by the Indiana Department of Environmental Management (IDEM), Office of Air Quality (OAQ). The information describing the source contained in conditions A.1 through A.3 is descriptive information and does not constitute enforceable conditions. However, the Permittee should be aware that a physical change or a change in the method of operation that may render this descriptive information obsolete or inaccurate may trigger requirements for the Permittee to obtain additional permits or seek modification of this permit pursuant to 326 IAC 2, or change other applicable requirements presented in the permit application. A.1 General Information [326 IAC 2-8-3(b)]

The Permittee owns and operates a stationary Concrete Backerboard Plant.

Source Address: 75 Ivy Lane, Clinton, Indiana 47842 Mailing Address: 75 Ivy Lane, Clinton, Indiana 47842 General Source Phone Number: 765-828-0898 SIC Code: 3272 County Location: Vermillion Source Location Status: Attainment for all criteria pollutants Source Status: Federally Enforceable State Operating Permit Program Minor Source, under PSD and Emission Offset Rules

Minor Source, Section 112 of the Clean Air Act Not 1 of 28 Source Categories

A.2 Emission Units and Pollution Control Equipment Summary [326 IAC 2-8-3(c)(3)]

This stationary source consists of the following emission units and pollution control devices:

(a) Raw Material Silos: (1) Two (2) Portland Cement Storage Silos, identified as U1 and U2, constructed in

2005, with a combined maximum capacity of 11,400 lbs/hr; each equipped with one (1) of two (2) cartridge filters for particulate control identified as CE1 and CE2; and each exhausting to stacks identified as S1 and S2, respectively.

(2) Two (2) Fly Ash Storage Silos, identified as U3 and U4, constructed in 2005 with

a combined maximum capacity of 9,800 lbs/hr, equipped with two (2) cartridge filters for particulate control identified as CE3 and CE4, and exhausting to stacks identified as S3 and S4, respectively.

(3) Two (2) Aluminate Storage Silos, identified as U5 and U6, constructed in 2005

with a combined maximum capacity of 1,760 lbs/hour, each equipped with one (1) of two (2) cartridge filters for particulate control identified as CE5 and CE6, each exhausting to stacks identified as S5 and S6, respectively.

(b) Raw Material Storage Bins:

(1) One (1) Portland Cement Bin, identified as U7, constructed in 2005 with a

maximum capacity of 11,400 lbs/hr, equipped with a baghouse for particulate control identified as CE7, exhausting to a stack identified as S7.

(2) One (1) Fly Ash Bin, identified as U8, constructed in 2005 with a maximum

capacity of 9,800 lbs/hr, equipped with a baghouse for particulate control identified as CE8, exhausting to a stack identified as S8.

(3) One (1) Aluminate Bin, identified as U9, constructed in 2005 with maximum



(c) One (1) Wet End Operations Unit, identified as U10, constructed in 2005, consisting of conveying raw material and mixing it with water to form a slurry to spread and dry into the sheet, with a maximum capacity of 21,000 lbs of board per hour, equipped with a baghouse for particulate control identified as CE10, located inside the sand storage room and exhausting through an outside vent, identified as S12.

(d) One Board Sawing Unit, identified as U11, constructed in 2005 with a maximum capacity

of 52 square foot of board sawn per hour, equipped with cartridge filters for particulate control identified as CE11, exhausting to stack identified as S10.

(e) One (1) Polystyrene Expansion, Aging, and Drying System operating in batch mode,

identified as U12, constructed in 2005 with a maximum capacity of 2,205 lbs of polystyrene beads per batch and a batch time of 5 hours, exhausting to stack identified as S11 with no control.

(f) One (1) Indoor Sand Storage and Handling System with high moisture content, identified

as U13, constructed in 2005 with a maximum capacity of 14,860 lbs/hr with no control and exhausting inside.

A.3 Insignificant Activities [326 IAC 2-7-1(21)][326 IAC 2-8-3(c)(3)(I)]

The source also consists of the following insignificant activities, as defined in 326 IAC 2-7-1(21): (a) Natural gas-fired combustion sources with maximum capacity of heat input equal to or

less than ten million (10,000,000) British thermal units per hour. (1) One (1) natural gas-fired boiler, identified as Boiler #1, constructed in 2005, rated

at 3.188 MMBtu/hr. (2) Eleven (11) natural gas-fired space heaters, identified as Large Space Heaters,

combined capacity of 5.3 MMBtu/hr. (3) Five (5) natural gas-fired space heaters, identified as Small Space Heaters, with

combined capacity of 0.5 MMBtu/hr. (4) One (1) natural gas-fired water heater, identified as Water Heater, with maximum

capacity of 0.2 MMBtu/hr.

A.4 FESOP Applicability [326 IAC 2-8-2] This stationary source otherwise required to have a Part 70 permit as described in 326 IAC 2-7-2(a), has applied to the Indiana Department of Environmental Management (IDEM), Office of Air Quality (OAQ) to renew a Federally Enforceable State Operating Permit (FESOP).


SECTION B GENERAL CONDITIONS

B.1 Definitions [326 IAC 2-8-1] 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 2-8-4(2)][326 IAC 2-1.1-9.5][IC 13-15-3-6(a)]

(a) This permit, F165-27682-00081, is issued for a fixed term of ten (10) years from the issuance date of this permit, as determined in accordance with IC 4-21.5-3-5(f) and IC 13-15-5-3. Subsequent revisions, modifications, or amendments of this permit do not affect the expiration date of this permit.

(b) If IDEM, OAQ, upon receiving a timely and complete renewal permit application, fails to

issue or deny the permit renewal prior to the expiration date of this permit, this existing permit shall not expire and all terms and conditions shall continue in effect, until the renewal permit has been issued or denied.

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

Notwithstanding the permit term of a permit to construct, a permit to operate, or a permit modification, any condition established in a permit issued pursuant to a permitting program approved in the state implementation plan shall remain in effect until:

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

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

B.4 Enforceability [326 IAC 2-8-6] [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 enforceable by IDEM, the United States Environmental Protection Agency (U.S. EPA) and by citizens in accordance with the Clean Air Act.

B.5 Severability [326 IAC 2-8-4(4)] 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 2-8-4(5)(D)]

This permit does not convey any property rights of any sort or any exclusive privilege. B.7 Duty to Provide Information [326 IAC 2-8-4(5)(E)]

(a) The Permittee shall furnish to IDEM, OAQ, within a reasonable time, any information that IDEM, OAQ may request in writing to determine whether cause exists for modifying, revoking and reissuing, or terminating this permit, or to determine compliance with this permit. Upon request, the Permittee shall also furnish to IDEM, OAQ copies of records required to be kept by this permit.

(b) For information furnished by the Permittee to IDEM, OAQ, the Permittee may include a claim of confidentiality in accordance with 326 IAC 17.1. When furnishing copies of requested records directly to U. S. EPA, the Permittee may assert a claim of confidentiality in accordance with 40 CFR 2, Subpart B.

B.8 Certification [326 IAC 2-8-3(d)][326 IAC 2-8-4(3)(C)(i)][326 IAC 2-8-5(1)]

(a) A certification required by this permit meets the requirements of 326 IAC 2-8-5(a)(1) if:

(1) it contains a certification by an "authorized individual", as defined by 326 IAC 2-1.1-1(1), and


(2) the certification states that, based on information and belief formed after reasonable inquiry, the statements and information 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) certification may cover multiple forms in one (1) submittal.

(c) An "authorized individual" is defined at 326 IAC 2-1.1-1(1).

B.9 Annual Compliance Certification [326 IAC 2-8-5(a)(1)]

(a) The Permittee shall annually submit a compliance certification report which addresses the status of the source’s compliance with the terms and conditions contained in this permit, including emission limitations, standards, or work practices. All certifications shall cover the time period from January 1 to December 31 of the previous year, and shall be submitted no later than July 1 of each year to: Indiana Department of Environmental Management Compliance and Enforcement Branch, Office of Air Quality 100 North Senate Avenue MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251

(b) The annual compliance certification report required by this permit shall be considered timely if the date postmarked on the envelope or certified mail receipt, or affixed by the shipper on the private shipping receipt, is on or before the date it is due. If the document is submitted by any other means, it shall be considered timely if received by IDEM, OAQ on or before the date it is due.

(c) The annual compliance certification report shall include the following:

(1) The appropriate identification of each term or condition of this permit that is the basis of the certification;

(2) The compliance status; (3) Whether compliance was continuous or intermittent; (4) The methods used for determining the compliance status of the source, currently

and over the reporting period consistent with 326 IAC 2-8-4(3); and (5) Such other facts, as specified in Sections D of this permit, as IDEM, OAQ may

require to determine the compliance status of the source. The submittal by the Permittee does require a certification that meets the requirements of 326 IAC 2-8-5(a)(1) by an "authorized individual" as defined by 326 IAC 2-1.1-1(1).

B.10 Compliance Order Issuance [326 IAC 2-8-5(b)]

IDEM, OAQ may issue a compliance order to this Permittee upon discovery that this permit is in nonconformance with an applicable requirement. The order may require immediate compliance or contain a schedule for expeditious compliance with the applicable requirement.

B.11 Preventive Maintenance Plan [326 IAC 1-6-3][326 IAC 2-8-4(9)]

(a) A Preventive Maintenance Plan meets the requirements of 326 IAC 1-6-3 if it includes, at a minimum:


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

repairing emission control devices;

(2) A description of the items or conditions that will be inspected and the inspection schedule for said items or conditions; and

(3) Identification and quantification of the replacement parts that will be maintained

in inventory for quick replacement.

The Permittee shall implement the PMPs.

(b) If required by specific condition(s) in Section D of this permit where no PMP was previously required, 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) responsible for inspecting, maintaining, and

repairing emission control devices; (2) A description of the items or conditions that will be inspected and the inspection

schedule for said items or conditions; and (3) Identification and quantification of the replacement parts that will be maintained

in inventory for quick replacement. If, due to circumstances beyond the Permittee’s control, the PMPs cannot be prepared and maintained within the above time frame, the Permittee may extend the date an additional ninety (90) days provided the Permittee notifies: Indiana Department of Environmental Management Compliance 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 require a certification that meets the requirements of 326 IAC 2-8-5(a)(1) by an "authorized individual" as defined by 326 IAC 2-1.1-1(1). The Permittee shall implement the PMPs.

(c) A copy of the PMPs shall be submitted to IDEM, OAQ upon request and within a

reasonable time, and shall be subject to review and approval by IDEM, OAQ. IDEM, OAQ may require the Permittee to revise its PMPs whenever lack of proper maintenance causes or is the primary contributor to an exceedance of any limitation on emissions. The PMPs and their submittal do not require a certification that meets the requirements of 326 IAC 2-8-5(a)(1) by an "authorized individual" as defined by 326 IAC 2-1.1-1(1).

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

Maintenance, and Monitoring (OMM) Plan for a unit, such Plan is deemed to satisfy the PMP requirements of 326 IAC 1-6-3 for that unit.

B.12 Emergency Provisions [326 IAC 2-8-12]

(a) An emergency, as defined in 326 IAC 2-7-1(12), is not an affirmative defense for an action brought for noncompliance with a federal or state health-based emission limitation except as provided in 326 IAC 2-8-12.


(b) An emergency, as defined in 326 IAC 2-7-1(12), constitutes an affirmative defense to an action brought for noncompliance with a health-based or technology-based emission limitation if the affirmative defense of an emergency is demonstrated through properly signed, contemporaneous operating logs or other relevant evidence that describe the following: (1) An emergency occurred and the Permittee can, to the extent possible, identify

the causes of the emergency; (2) The permitted facility was at the time being properly operated; (3) During the period of an emergency, the Permittee took all reasonable steps to

minimize levels of emissions that exceeded the emission standards or other requirements in this permit;

(4) For each emergency lasting one (1) hour or more, the Permittee notified IDEM,

OAQ, within four (4) daytime business hours after the beginning of the emergency, or after the emergency was discovered or reasonably should have been discovered; Telephone Number: 1-800-451-6027 (ask for Office of Air Quality, Compliance and Enforcement Branch), or Telephone Number: 317-233-0178 (ask for 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 IAC 2-8-4(3)(C)(ii) and must contain the following: (A) A description of the emergency;

(B) Any steps taken to mitigate the emissions; and

(C) Corrective actions taken.

The notification which shall be submitted by the Permittee does not require the certification by an "authorized individual" as defined by 326 IAC 2-1.1-1(1).

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

(c) In any enforcement proceeding, the Permittee seeking to establish the occurrence of an emergency has the burden of proof.


(d) This emergency provision supersedes 326 IAC 1-6 (Malfunctions). This permit condition

is in addition to any emergency or upset provision contained in any applicable requirement.

(e) The Permittee seeking to establish the occurrence of an emergency shall make records available upon request to ensure that failure to implement a PMP did not cause or contribute to an exceedance of any limitations on emissions. However, IDEM, OAQ may require that the Preventive Maintenance Plans required under 326 IAC 2-8-3(c)(6) 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 2-8 and any other applicable rules.

(g) Operations may continue during an emergency only if the following conditions are met:

(1) If the emergency situation causes a deviation from a technology-based limit, the

Permittee may continue to operate the affected emitting facilities during the emergency provided the Permittee immediately takes all reasonable steps to correct the emergency and minimize emissions.

(2) If an emergency situation causes a deviation from a health-based limit, the

Permittee may not continue to operate the affected emissions facilities unless:

(A) The Permittee immediately takes all reasonable steps to correct the emergency situation and to minimize emissions; and

(B) Continued operation of the facilities is necessary to prevent imminent

injury to persons, severe damage to equipment, substantial loss of capital investment, or loss of product or raw material of substantial economic value.

Any operations shall continue no longer than the minimum time required to prevent the situations identified in (g)(2)(B) of this condition.

(h) The Permittee shall include all emergencies in the Quarterly Deviation and Compliance

Monitoring Report. B.13 Prior Permits Superseded [326 IAC 2-1.1-9.5]

(a) All terms and conditions of permits established prior to F165-27682-00081 and issued pursuant to permitting programs approved into the state implementation plan have been either: (1) incorporated as originally stated, (2) revised, or (3) deleted.

(b) All previous registrations and permits are superseded by this permit.

B.14 Termination of Right to Operate [326 IAC 2-8-9][326 IAC 2-8-3(h)] The Permittee's right to operate this source terminates with the expiration of this permit unless a timely and complete renewal application is submitted at least nine (9) months prior to the date of expiration of the source’s existing permit, consistent with 326 IAC 2-8-3(h) and 326 IAC 2-8-9.


B.15 Permit Modification, Reopening, Revocation and Reissuance, or Termination

[326 IAC 2-8-4(5)(C)][326 IAC 2-8-7(a)][326 IAC 2-8-8] (a) This permit may be modified, reopened, revoked and reissued, or terminated for cause.

The filing of a request by the Permittee for a Federally Enforceable State Operating Permit modification, revocation and reissuance, or termination, or of a notification of planned changes or anticipated noncompliance does not stay any condition of this permit. [326 IAC 2-8-4(5)(C)] The notification by the Permittee does require a certification that meets the requirements of 326 IAC 2-8-5(a)(1) by an "authorized individual" as defined by 326 IAC 2-1.1-1(1).

(b) This permit shall be reopened and revised under any of the circumstances listed in IC 13-15-7-2 or if IDEM, OAQ determines any of the following: (1) That this permit contains a material mistake. (2) That inaccurate statements were made in establishing the emissions standards

or other terms or conditions. (3) That this permit must be revised or revoked to assure compliance with an

applicable requirement. [326 IAC 2-8-8(a)]

(c) Proceedings by IDEM, OAQ to reopen and revise this permit shall follow the same procedures as apply to initial permit issuance and shall affect only those parts of this permit for which cause to reopen exists. Such reopening and revision shall be made as expeditiously as practicable. [326 IAC 2-8-8(b)]

(d) The reopening and revision of this permit, under 326 IAC 2-8-8(a), shall not be initiated before notice of such intent is provided to the Permittee by IDEM, OAQ at least thirty (30) days in advance of the date this permit is to be reopened, except that IDEM, OAQ may provide a shorter time period in the case of an emergency. [326 IAC 2-8-8(c)]

B.16 Permit Renewal [326 IAC 2-8-3(h)]

(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 2-8-3. Such information shall be included in the application for each emission unit at this source, except those emission units included on the trivial or insignificant activities list contained in 326 IAC 2-7-1(21) and 326 IAC 2-7-1(42). The renewal application does require a certification that meets the requirements of 326 IAC 2-8-5(a)(1) by an "authorized individual" as defined by 326 IAC 2-1.1-1(1). Request for renewal shall be submitted to: Indiana Department of Environmental Management Permit Administration and Support Section, Office of Air Quality 100 North Senate Avenue MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251

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

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

(2) If the date postmarked on the envelope or certified mail receipt, or affixed by the

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


(c) If the Permittee submits a timely and complete application for renewal of this permit, the source’s failure to have a permit is not a violation of 326 IAC 2-8 until IDEM, OAQ takes final action on the renewal application, except that this protection shall cease to apply if, subsequent to the completeness determination, the Permittee fails to submit by the deadline specified, pursuant to 326 IAC 2-8-3(g), in writing by IDEM, OAQ any additional information identified as being needed to process the application.

B.17 Permit Amendment or Revision [326 IAC 2-8-10][326 IAC 2-8-11.1] (a) Permit amendments and revisions are governed by the requirements of 326 IAC 2-8-10

or 326 IAC 2-8-11.1 whenever the Permittee seeks to amend or modify this permit.

(b) Any application requesting an amendment or modification of this permit shall be submitted to: Indiana Department of Environmental Management 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 certification that meets the requirements of 326 IAC 2-8-5(a)(1) by an "authorized individual" as defined by 326 IAC 2-1.1-1(1).

(c) The Permittee may implement administrative amendment changes addressed in the request for an administrative amendment immediately upon submittal of the request. [326 IAC 2-8-10(b)(3)]

B.18 Operational Flexibility [326 IAC 2-8-15][326 IAC 2-8-11.1] (a) The Permittee may make any change or changes at the source that are described in

326 IAC 2-8-15(b) and (c) 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 approval required by 326 IAC 2-8-11.1 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 and United States Environmental Protection Agency, Region V Air and Radiation Division, Regulation Development Branch - Indiana (AR-18J) 77 West Jackson Boulevard Chicago, Illinois 60604-3590


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

(5) The Permittee maintains records on-site, on a rolling five (5) year basis, which

document all such changes and emission trades that are subject to 326 IAC 2-8-15(b)(1) and (c). The Permittee shall make such records available, upon reasonable request, for public review.

Such records shall consist of all information required to be submitted to IDEM, OAQ in the notices specified in 326 IAC 2-8-15(b)(1) and (c).

(b) Emission Trades [326 IAC 2-8-15(b)]

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 2-8-15(c).

(c) Alternative Operating Scenarios [326 IAC 2-8-15(c)] The Permittee may make changes at the source within the range of alternative operating scenarios that are described in the terms and conditions of this permit in accordance with 326 IAC 2-8-4(7). No prior notification of IDEM, OAQ, or U.S. EPA is required.

(d) Backup fuel switches specifically addressed in, and limited under, Section D of this permit shall not be considered alternative operating scenarios. Therefore, the notification requirements of part (a) of this condition do not apply.

B.19 Source Modification Requirement [326 IAC 2-8-11.1]

A modification, construction, or reconstruction is governed by the requirements of 326 IAC 2.

B.20 Inspection and Entry [326 IAC 2-8-5(a)(2)][IC 13-14-2-2][IC 13-17-3-2][IC 13-30-3-1] Upon presentation of proper identification cards, credentials, and other documents as may be required by law, and subject to the Permittee’s right under all applicable laws and regulations to assert that the information collected by the agency is confidential and entitled to be treated as such, the Permittee shall allow IDEM, OAQ, U.S. EPA, or an authorized representative to perform the following:

(a) Enter upon the Permittee's premises where a FESOP source is located, or emissions

related activity is conducted, or where records must be kept under the conditions of this permit;

(b) As authorized by the Clean Air Act, IC 13-14-2-2, IC 13-17-3-2, and IC 13-30-3-1, have access to and copy, at reasonable times, 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, at reasonable times, any facilities, equipment (including monitoring and air pollution control equipment), practices, or operations regulated or required under this permit;

(d) As authorized by the Clean Air Act, IC 13-14-2-2, IC 13-17-3-2, and IC 13-30-3-1, sample or monitor, at reasonable times, substances or parameters for the purpose of assuring compliance with this permit or applicable requirements; and

(e) As authorized by the Clean Air Act, IC 13-14-2-2, IC 13-17-3-2, and IC 13-30-3-1, utilize any photographic, recording, testing, monitoring, or other equipment for the purpose of assuring compliance with this permit or applicable requirements.


B.21 Transfer of Ownership or Operational Control [326 IAC 2-8-10]

(a) The Permittee must comply with the requirements of 326 IAC 2-8-10 whenever the Permittee seeks to change the ownership or operational control of the source and no other change in the permit is necessary.

(b) Any application requesting a change in the ownership or operational control of the source shall contain a written agreement containing a specific date for transfer of permit responsibility, coverage and liability between the current and new Permittee. The application shall be submitted to: Indiana Department of Environmental Management Permit Administration and Support Section, Office of Air Quality 100 North Senate Avenue MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251 Any such application does require a certification that meets the requirements of 326 IAC 2-8-5(a)(1) by an "authorized individual" as defined by 326 IAC 2-1.1-1(1).

(c) The Permittee may implement administrative amendment changes addressed in the request for an administrative amendment immediately upon submittal of the request. [326 IAC 2-8-10(b)(3)]

B.22 Annual Fee Payment [326 IAC 2-7-19] [326 IAC 2-8-4(6)] [326 IAC 2-8-16][326 IAC 2-1.1-7]

(a) The Permittee shall pay annual fees to IDEM, OAQ no later than 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) Failure to pay may result in administrative enforcement action or revocation of this permit. (c) The Permittee may call the following telephone numbers: 1-800-451-6027 or

317-233-4230 (ask for OAQ, Billing, Licensing, and Training Section), to determine the appropriate permit fee.

B.23 Credible Evidence [326 IAC 2-8-4(3)][326 IAC 2-8-5][62 FR 8314] [326 IAC 1-1-6]

For the purpose of submitting compliance certifications or establishing whether or not the Permittee has violated or is in violation of any condition of this permit, nothing in this permit shall preclude the use, including the exclusive use, of any credible evidence or information relevant to whether the Permittee would have been in compliance with the condition of this permit if the appropriate performance or compliance test or procedure had been performed.


SECTION C SOURCE OPERATION CONDITIONS

Entire Source

Emission Limitations and Standards [326 IAC 2-8-4(1)]

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

C.2 Overall Source Limit [326 IAC 2-8] The purpose of this permit is to limit this source’s potential to emit to less than major source levels for the purpose of Section 502(a) of the Clean Air Act. (a) Pursuant to 326 IAC 2-8:

(1) The potential to emit any regulated pollutant, except particulate matter (PM), from

the entire source shall be limited to less than one hundred (100) tons per twelve (12) consecutive month period.

(2) The potential to emit any individual hazardous air pollutant (HAP) from the entire

source shall be limited to less than ten (10) tons per twelve (12) consecutive month period; and

(3) The potential to emit any combination of HAPs from the entire source shall be

limited to less than twenty-five (25) tons per twelve (12) consecutive month period.

(b) Pursuant to 326 IAC 2-2 (PSD), potential to emit particulate matter (PM) from the entire

source shall be limited to less than two hundred fifty (250) tons per twelve (12) consecutive month period.

(c) This condition shall include all emission points at this source including those that are

insignificant as defined in 326 IAC 2-7-1(21). The source shall be allowed to add insignificant activities not already listed in this permit, provided that the source’s potential to emit does not exceed the above specified limits.

(d) Section D of this permit contains independently enforceable provisions to satisfy this requirement.

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

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

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

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


C.4 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.5 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 incinerator or refuse burning equipment except as provided in 326 IAC 9-1-2 or in this permit.

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

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

C.7 Asbestos Abatement Projects [326 IAC 14-10] [326 IAC 18] [40 CFR 61, Subpart M] (a) Notification requirements apply to each owner or operator. If the combined amount of

regulated asbestos containing material (RACM) to be stripped, removed or disturbed is at least 260 linear feet on pipes or 160 square feet on other facility components, or at least thirty-five (35) cubic feet on all facility components, then the notification requirements of 326 IAC 14-10-3 are mandatory. All demolition projects require notification whether or not asbestos is present.

(b) The Permittee shall ensure that a written notification is sent on a form provided by the Commissioner at least ten (10) working days before asbestos stripping or removal work or before demolition begins, per 326 IAC 14-10-3, and shall update such notice as necessary, including, but not limited to the following: (1) When the amount of affected asbestos containing material increases or

decreases by at least twenty percent (20%); or (2) If there is a change in the following:

(A) Asbestos removal or demolition start date;

(B) Removal or demolition contractor; or

(C) Waste disposal site.

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

(d) The notice to be submitted shall include the information enumerated in 326 IAC 14-10-3(3). All required notifications shall be submitted to: Indiana Department of Environmental Management Compliance and Enforcement Branch, Office of Air Quality 100 North Senate Avenue MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251 The notice shall include a signed certification from the owner or operator that the information provided in this notification is correct and that only Indiana licensed workers and project supervisors will be used to implement the asbestos removal project. The


notifications do not require a certification by an "authorized individual" as defined by 326 IAC 2-1.1-1(1).

(e) Procedures for Asbestos Emission Control The Permittee shall comply with the applicable emission control procedures in 326 IAC 14-10-4 and 40 CFR 61.145(c). Per 326 IAC 14-10-1, emission control requirements are applicable for any removal or disturbance of RACM greater than three (3) linear feet on pipes or three (3) square feet on any other facility components or a total of at least 0.75 cubic feet on all facility components.

(f) Demolition and Renovation The Permittee shall thoroughly inspect the affected facility or part of the facility where the demolition or renovation will occur for the presence of asbestos pursuant to 40 CFR 61.145(a).

(g) Indiana 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 to thoroughly inspect the affected portion of the facility for the presence of asbestos.

Testing Requirements [326 IAC 2-8-4(3)]

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 certification that meets the requirements of 326 IAC 2-8-5(a)(1) by an "authorized individual" as defined by 326 IAC 2-1.1-1(1).

(b) The Permittee shall notify IDEM, OAQ of the actual test date at least fourteen (14) days prior to the actual test date. The notification submitted by the Permittee does not require a certification that meets the requirements of 326 IAC 2-8-5(a)(1) by an "authorized individual" as defined by 326 IAC 2-1.1-1(1).

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

Compliance Requirements [326 IAC 2-1.1-11]

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


Compliance Monitoring Requirements [326 IAC 2-8-4][326 IAC 2-8-5(a)(1)]

C.10 Compliance Monitoring [326 IAC 2-8-4(3)][326 IAC 2-8-5(a)(1)] (a) For new units:

Unless otherwise specified in the approval for the new emission unit(s), compliance monitoring for new emission units shall be implemented on and after the date of initial start-up.

(b) For existing units:

Unless otherwise specified in this permit, for all monitoring requirements not already legally required, the Permittee shall be allowed up to ninety (90) days from the date of permit issuance to begin such monitoring. If due to circumstances beyond the Permittee's control, any monitoring equipment required by this permit cannot be installed and operated no later than ninety (90) days after permit issuance, 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. The notification which shall be submitted by the Permittee does require a certification that meets the requirements of 326 IAC 2-8-5(a)(1) by an "authorized individual" as defined by 326 IAC 2-1.1-1(1).

C.11 Instrument Specifications [326 IAC 2-1.1-11] [326 IAC 2-8-4(3)][326 IAC 2-8-5(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. The analog instrument shall be capable of measuring values outside of the normal range.

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

does not meet the above specifications provided the Permittee can demonstrate that an alternative instrument specification will adequately ensure compliance with permit conditions requiring the measurement of the parameters.

Corrective Actions and Response Steps [326 IAC 2-8-4][326 IAC 2-8-5(a)(1)]

C.12 Risk Management Plan [326 IAC 2-8-4] [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.13 Response to Excursions or Exceedances [326 IAC 2-8-4] [326 IAC 2-8-5]

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 associated capture system) to its normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing 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 computerized distribution 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 exceedance will be based on information available, which may include, but is not limited to, the following: (1) monitoring results; (2) review of operation and maintenance procedures and records; and/or (3) inspection of the control device, associated capture system, and the process.

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

permit. (e) The Permittee shall record the reasonable response steps taken.

C.14 Actions Related to Noncompliance Demonstrated by a Stack Test [326 IAC 2-8-4][326 IAC 2-8-5] (a) When the results of a stack test performed in conformance with Section C - Performance

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

The response action documents submitted pursuant to this condition do require a certification that meets the requirements of 326 IAC 2-8-5(a)(1) by an "authorized individual" as defined by 326 IAC 2-1.1-1(1).

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

C.15 General Record Keeping Requirements [326 IAC 2-8-4(3)] [326 IAC 2-8-5] (a) Records of all required monitoring data, reports and support information required by this

permit shall be retained for a period of at least five (5) years from the date of monitoring sample, measurement, report, or application. Support information includes the following, where applicable:

(AA) All calibration and maintenance records. (BB) All original strip chart recordings for continuous monitoring

instrumentation. (CC) Copies of all reports required by the FESOP.


Records of required monitoring information include the following, where applicable:

(AA) The date, place, as defined in this permit, and time of sampling or measurements.

(BB) The dates analyses were performed. (CC) The company or entity that performed the analyses. (DD) The analytical techniques or methods used. (EE) The results of such analyses. (FF) The operating conditions as existing at the time of sampling or

measurement. These records shall be physically present or electronically accessible at the source location for a minimum of three (3) years. The records may be stored elsewhere for the remaining two (2) years as long as they are available upon request. If the Commissioner makes a request for records to the Permittee, the Permittee shall furnish the records to the Commissioner within a reasonable time

(b) Unless otherwise specified in this permit, for all record keeping requirements not already

legally required, the Permittee shall be allowed 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.16 General Reporting Requirements [326 IAC 2-8-4(3)(C)] [326 IAC 2-1.1-11] (a) The Permittee shall submit the attached Quarterly Deviation and Compliance Monitoring

Report or its equivalent. Proper notice submittal under Section B –Emergency Provisions satisfies the reporting requirements of this paragraph. 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 reported pursuant to an applicable requirement that exists independent of this permit, shall be reported according to the schedule stated in the applicable requirement and does not need to be included in this report. 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 2-8-5(a)(1) by an "authorized individual" as defined by 326 IAC 2-1.1-1(1). 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) Reporting periods are based on calendar years, unless otherwise specified in this permit.

For the purpose of this permit “calendar year” means the twelve (12) month period from January 1 to December 31 inclusive.


Stratospheric Ozone Protection

C.17 Compliance with 40 CFR 82 and 326 IAC 22-1 Pursuant to 40 CFR 82 (Protection of Stratospheric Ozone), Subpart F, except as provided for motor vehicle air conditioners in Subpart B, the Permittee shall comply with applicable standards for recycling and emissions reduction.


SECTION D.1 EMISSIONS UNIT OPERATION CONDITIONS

Emissions Unit Description: (a) Raw Material Silos:

(1) Two (2) Portland Cement Storage Silos, identified as U1 and U2, constructed in 2005,

with a combined maximum capacity of 11,400 lbs/hr; each equipped with one (1) of two (2) cartridge filters for particulate control identified as CE1 and CE2; and each exhausting to stacks identified as S1 and S2, respectively.

(2) Two (2) Fly Ash Storage Silos, identified as U3 and U4, constructed in 2005 with a

combined maximum capacity of 9,800 lbs/hr, equipped with two (2) cartridge filters for particulate control identified as CE3 and CE4, and exhausting to two (2) stacks identified as S3 and S4, respectively.

(3) Two (2) Aluminate Storage Silos, identified as U5 and U6, constructed in 2005 with a

combined maximum capacity of 1,760 lbs/hour, each equipped with one (1) of two (2) cartridge filters for particulate control identified as CE5 and CE6, each exhausting to stacks identified as S5 and S6, respectively.

(b) Raw Material Storage Bins:

(1) One (1) Portland Cement Bin, identified as U7, constructed in 2005 with a maximum


(2) One (1) Fly Ash Bin, identified as U8, constructed in 2005 with a maximum capacity of

9,800 lbs/hr, equipped with a baghouse for particulate control identified as CE8, exhausting to a stack identified as S8.

(3) One (1) Aluminate Bin, identified as U9, constructed in 2005 with maximum capacity of

1,760 lbs/hr, equipped with a baghouse for particulate control identified as CE9, exhausting to a stack identified as S9.

(c) One (1) Wet End Operations Unit, identified as U10, constructed in 2005, consisting of

conveying raw material and mixing it with water to form a slurry to spread and dry into the sheet, with a maximum capacity of 21,000 lbs of board per hour, equipped with a baghouse for particulate control identified as CE10, located inside the sand storage room and exhausting through an outside vent, identified as S12.

(d) One Board Sawing Unit, identified as U11, constructed in 2005 with a maximum capacity of 52

square foot of board sawn per hour, equipped with cartridge filters for particulate control identified as CE11, exhausting to stack identified as S10.

(e) One (1) Polystyrene Expansion, Aging, and Drying System operating in batch mode, identified

as U12, constructed in 2005 with a maximum capacity of 2,205 lbs of polystyrene beads per batch and a batch time of 5 hours, exhausting to stack identified as S11 with no control.

(f) One (1) Indoor Sand Storage and Handling System with high moisture content, identified as

U13, constructed in 2005 with a maximum capacity of 14,860 lbs/hr with no control and exhausting inside.

(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 2-8-4(1)] D.1.1 Particulate [326 IAC 6-3-2]

Pursuant to 326 IAC 6-3-2 (Particulate Emission Limitations for Manufacturing Processes) the particulate emissions from the source shall not exceed the pound per hour emission rate established as E in the following formula:

Interpolation of the data for the process weight rate up to sixty thousand (60,000) pounds per hour shall be accomplished by the use of the equation: E=4.10 P0.67 where: E = rate of emission in pounds per hour; and

P = process weight rate in tons per hour

The emissions rate E has been established for the units as follows:

Unit

Process Weight Rate (tons/hour)

Allowable PM Emissions (lbs/hour)

Portland Cement Storage Silo (U1) 2.85 8.27 Portland Cement Storage Silo (U2) 2.85 8.27 Fly Ash Storage Silo (U3) 2.45 7.47 Fly Ash Storage Silo (U4) 2.45 7.47 Aluminate Storage Silo (U5) 0.44 2.40 Aluminate Storage Silo (U6) 0.44 2.40 Portland Cement Bin (U7) 5.70 13.2 Fly Ash Bin (U8) 4.9 11.89 Aluminate Bin (U9) 0.88 3.80 Wet End Operations (U10) 10.5 19.8 Board Sawing Operations (U11) 10.5 19.8 Sand Storage Room (U13) 7.43 15.8

D.1.2 Particulate Matter (PM) [326 IAC 2-2]

In order to render the requirements of 326 IAC 2-2 (PSD) not applicable, the PM emissions shall not exceed the hourly rates expressed in the following table:

Unit ID

Hourly PM Limit (lbs/hr)

Control ID

Portland Cement Storage Silo (U1) 0.47 Cartridge Filter (CE1) Portland Cement Storage Silo (U2) 0.47 Cartridge Filter (CE2) Fly Ash Storage Silo (U3) 0.47 Cartridge Filter (CE3) Fly Ash Storage Silo (U4) 0.47 Cartridge Filter (CE4) Aluminate Storage Silo (U5) 0.47 Cartridge Filter (CE5) Aluminate Storage Silo (U6) 0.47 Cartridge Filter (CE6) Portland Cement Bin (U7) 0.47 Baghouse (CE7) Fly Ash Bin (U8) 0.47 Baghouse (CE8) Aluminate Bin (U9) 0.47 Baghouse (CE9) Wet End Operations (U10) 0.57 Baghouse (CE10) Board Sawing Operations (U11) 0.43 Cartridge Filter (CE11) Sand Storage Room (U13) 0.02 (High Moisture)

Total 5.26

Compliance with above conditions shall limit the source-wide PM emissions to less than 250 tons per twelve consecutive month period and shall render the requirements of 326 IAC 2-2 (PSD) not applicable.


D.1.3 Particulate Matter (PM10), (PM2.5) [326 IAC 2-8-4] [326 IAC 2-2]

Pursuant to 326 IAC 2-8-4 and in order to render the requirements of 326 IAC 2-7 (Part 70) and 326 IAC 2-2 (PSD) not applicable, the PM10 and PM2.5 emissions shall not exceed the hourly rates expressed in the following table:

Unit ID

Hourly PM10 Limit

(lbs/hr)

Hourly PM2.5 Limit

(lbs/hr)

Control ID

Portland Cement Storage Silo (U1) 0.47 0.47 Cartridge Filter (CE1) Portland Cement Storage Silo (U2) 0.47 0.47 Cartridge Filter (CE2) Fly Ash Storage Silo (U3) 0.47 0.47 Cartridge Filter (CE3) Fly Ash Storage Silo (U4) 0.47 0.47 Cartridge Filter (CE4) Aluminate Storage Silo (U5) 0.47 0.47 Cartridge Filter (CE5) Aluminate Storage Silo (U6) 0.47 0.47 Cartridge Filter (CE6) Portland Cement Bin (U7) 0.47 0.47 Baghouse (CE7) Fly Ash Bin (U8) 0.47 0.47 Baghouse (CE8) Aluminate Bin (U9) 0.47 0.47 Baghouse (CE9) Wet End Operations (U10) 0.57 0.57 Baghouse (CE10) Board Sawing Operations (U11) 0.43 0.43 Cartridge Filter (CE11) Sand Storage Room (U13) 0.02 0.02 (High Moisture)

Total 5.26 5.26 Compliance with above conditions shall limit the source-wide PM10, and PM2.5 emissions to less than 100 tons per twelve consecutive month period, each and shall render the requirements of 326 IAC 2-7 (Part 70) and 326 IAC 2-2 (PSD) not applicable.

D.1.4 VOC [326 IAC 8-1-6] [326 IAC 2-8-4] Pursuant to 326 IAC 8-1-6 (New Facilities; General Reduction Requirements), Significant Permit Revision No. 165-35908-00081, and 326 IAC 2-8-4, and in order to render the requirements of 326 IAC 2-7 (Part 70) not applicable, the Permittee shall control VOC emissions from the polystyrene expansion, aging, and drying system (U12) using Best Available Control Technology (BACT), which has been determined to be the following: (a) VOC content of polystyrene beads shall not exceed 7.5% by weight. (b) The total throughput of polystyrene beads shall not exceed 700 tons per twelve (12)

month consecutive period. Compliance with the above shall satisfy the requirements of 326 IAC 8-1-6 (New Facilities, General Reduction Requirements) for the polystyrene expansion, aging, and drying system (U12). Compliance with these limits, combined with the potential to emit VOC from all other emission units at this source, shall limit the source-wide total potential to emit of VOC to less than 100 tons per twelve (12) consecutive month period, and shall render the requirements of 326 IAC 2-7 (Part 70 Permits) not applicable.

D.1.5 Preventive Maintenance Plan [326 IAC 2-8-4(9)] A Preventive Maintenance Plan is required for the above units and 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 [326 IAC 2-8-4(1)] D.1.6 Particulate Control

In order to comply with Conditions D.1.1, D.1.2, and D.1.3 particulate from the storage, conveying and manufacturing processes shall be controlled by baghouses/cartridge filters at all times that the storage, conveying and manufacturing processes are in operation.

D.1.7 Volatile Organic Compounds (VOC) [326 IAC 8-1-2] [326 IAC 8-1-4]

Compliance with the VOC usage limitations contained in Condition D.1.4 shall be determined pursuant to 326 IAC 8-1-4(a)(3) and 326 IAC 8-1-2(a) by preparing or obtaining from the manufacturer the copies of the Certificate of Analyses VOC data sheets. IDEM, OAQ reserves the authority to determine compliance using Method 24 in conjunction with the analytical procedures specified in 326 IAC 8-1-4.

Compliance Monitoring Requirements [326 IAC 2-8-4] [326 IAC 2-8-5(a)(1)] D.1.8 Visible Emissions Notations

(a) Visible emission notations of the stack exhaust from Stacks S1 through S10 and S12 shall be performed once per day during normal daylight operations when exhausting to the atmosphere. A trained employee shall record whether emissions are normal or abnormal.

(b) For processes operated continuously, "normal" means those conditions prevailing, or

expected to prevail, eighty percent (80%) of the time the process is in operation, not counting startup or shut down time.

(c) A trained employee is an employee who has worked at the plant at least one (1) month

and has been trained in the appearance and characteristics of normal visible emissions for that specific process.

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

Section C - Response to Excursions and Exceedances contains the Permittee's obligations with regard to responding to the reasonable response steps required by this condition. Failure to take response steps shall be considered a deviation from this permit.

D.1.9 Broken or Failed Cartridge Detection

In the event that cartridge failure has been observed:

(a) For a single compartment baghouses/cartridge filters controlling emissions from a process operated continuously, a failed unit and the associated process shall be shut down immediately until the failed unit has been repaired or replaced. Operations may continue only if the event qualifies as an emergency and the Permittee satisfies the requirements of the emergency provisions of this permit (Section B - Emergency Provisions).

(b) For a single compartment baghouses/cartridge filters controlling emissions from a batch

process, the feed to the process shall be shut down immediately until the failed unit has been repaired or replaced. The emissions unit shall be shut down no later than the completion of the processing of the material in the emissions unit. Operations may continue only if the event qualifies as an emergency and the Permittee satisfies the requirements of the emergency provisions of this permit (Section B - Emergency Provisions).

Bag failure can be indicated by a significant drop in the baghouse's pressure reading with abnormal visible emissions, by an opacity violation, or by other means such as gas temperature, flow rate, air infiltration, leaks, dust traces or triboflows.


Record Keeping and Reporting Requirements [326 IAC 2-8-4(3)] [326 IAC 2-8-16] D.1.10 Record Keeping Requirements

(a) To document the compliance status with Conditions D.1.4(b) and D.1.7, the Permittee shall maintain the following records: (1) The VOC content of the Polystyrene beads used. Records shall include the

Certificate of Analyses VOC data sheets from the Polystyrene bead manufacturer for each shipment of the beads along with documentation of each shipment (e.g., purchase order).

(2) Total throughput of polystyrene beads each month and each compliance period.

(b) To document the compliance status with Condition D.1.8, the Permittee shall maintain records of visible emission notations of the stack exhaust from Stack S1 through S10 and S12 once per day. The Permittee shall include in its daily record when a visible emission notation is not taken and the reason for the lack of visible emission notation (e.g., the process did not operate that day).

(c) Section C - General Record Keeping Requirements of this permit contains the

Permittee's obligations with regard to the records required by this condition. D.1.11 Reporting Requirements

A quarterly summary of the information to document the compliance status with Condition D.1.4 shall be submitted to the address listed in Section C - General Reporting Requirements, of this permit, using the reporting form located at the end of this permit, or its equivalent, within thirty (30) days after the end of the quarter being reported. The report submitted by the Permittee does require the certification that meets the requirements of 326 IAC 2-8-5(a)(1) by an “authorized individual” as defined by 326 IAC 2-1.1-1(1).


SECTION D.2 FACILITY OPERATION CONDITIONS

Facility Description [326 IAC 2-8-4(10)]: Insignificant Activities (a) Natural gas-fired combustion sources with maximum capacity of heat input equal to or less than

ten million (10,000,000) British thermal units per hour. (1) One (1) natural gas-fired boiler, identified as Boiler #1, constructed in 2005, rated at

3.188 MMBtu/hr.

(The information describing the process contained in this facility description box is descriptive information and does not constitute enforceable conditions.) Emission Limitations and Standards [326 IAC 2-8-4(1)] D.2.1 Particulate [326 IAC 6-2-4]

Pursuant to 326 IAC 6-2-4 (Particulate Emission Limitations for Sources of Indirect Heating) the PM emissions from the 3.188 MMBtu per hour heat input boiler shall be limited to 0.6 pounds per million Btu heat input.


INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF AIR QUALITY

FEDERALLY ENFORCEABLE STATE OPERATING PERMIT (FESOP) CERTIFICATION

Source Name: New NGC d/b/a National Gypsum Co. Source Address: 75 Ivy Lane, Clinton, Indiana 47842 Mailing Address: 75 Ivy Lane, Clinton, Indiana 47842 FESOP Permit No.: F165-27682-00081

This certification shall be included when submitting monitoring, testing reports/results

or other documents as required by this permit.

Please check what document is being certified: Annual Compliance Certification Letter Test Result (specify)___________________________________________________ Report (specify)_______________________________________________________ Notification (specify)____________________________________________________ Affidavit (specify)_______________________________________________________ Other (specify)_________________________________________________________

I certify that, based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate, and complete. Signature: Printed Name: Title/Position: Date:



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

FEDERALLY ENFORCEABLE STATE OPERATING PERMIT (FESOP) EMERGENCY OCCURRENCE REPORT

Source Name: New NGC d/b/a National Gypsum Co. Source Address: 75 Ivy Lane, Clinton, Indiana 47842 Mailing Address: 75 Ivy Lane, Clinton, Indiana 47842 FESOP Permit No.: F165-27682-00081 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:


If any of the following are not applicable, mark N/A Page 2 of 2

Date/Time Emergency started: Date/Time Emergency was corrected: Was the facility being properly operated at the time of the emergency? Y N Describe: Type of Pollutants Emitted: TSP, PM-10, SO2, VOC, NOX, CO, Pb, other: Estimated amount of pollutant(s) emitted during emergency: Describe the steps taken to mitigate the problem: Describe the corrective actions/response steps taken: Describe the measures taken to minimize emissions: If applicable, describe the reasons why continued operation of the facilities are necessary to prevent imminent injury to persons, severe damage to equipment, substantial loss of capital investment, or loss of product or raw materials of substantial economic value:

Form Completed by: ________________________________________________

Title / Position: ____________________________________________________

Date: ____________________________________________________________

Phone: ___________________________________________________________




FESOP Quarterly Report

Source Name: New NGC d/b/a National Gypsum Co. Source Address: 75 Ivy Lane, Clinton, Indiana 47842 Mailing Address: 75 Ivy Lane, Clinton, Indiana 47842 FESOP Permit No.: F165-27682-00081 Facility: One (1) Polystyrene Expansion, Aging, and Drying System (U12) Parameter: Total polystyrene bead throughput Limit: The total throughput of polystyrene beads shall not exceed 700 tons per twelve

(12) month consecutive period.

QUARTER:_____________________ YEAR:_____________________

Month Column 1 Column 2 Column 1 + Column 2

This Month Previous 11 Months 12 Month Total

No deviation occurred in this quarter. Deviation/s occurred in this quarter.

Deviation has been reported on: ___________________

Submitted by: _____________________________________________________

Title / Position: ____________________________________________________

Signature: ________________________________________________________

Date: ____________________________________________________________

Phone: ___________________________________________________________

Attach a signed certification to complete this report.




FEDERALLY ENFORCEABLE STATE OPERATING PERMIT (FESOP) QUARTERLY DEVIATION AND COMPLIANCE MONITORING REPORT

Source Name: New NGC d/b/a National Gypsum Co. Source Address: 75 Ivy Lane, Clinton, Indiana 47842 Mailing Address: 75 Ivy Lane, Clinton, Indiana 47842 FESOP Permit No.: F165-27682-00081

Months: ___________ to ____________ Year: ______________

Page 1 of 2 This report shall be submitted quarterly based on a calendar year. Any deviation from the requirements, the date(s) of each deviation, the probable cause of the deviation, and the response steps taken must be reported. A deviation required to be reported pursuant to an applicable requirement that exists independent of the permit, shall be reported according to the schedule stated in the applicable requirement and does not need to be included in this report. Additional pages may be attached if necessary. If no deviations occurred, please specify in the box marked "No deviations occurred this reporting period". NO DEVIATIONS OCCURRED THIS REPORTING PERIOD. THE FOLLOWING DEVIATIONS OCCURRED THIS REPORTING PERIOD Permit Requirement (specify permit condition #) Date of Deviation:

Duration of Deviation:

Number of Deviations: Probable Cause of Deviation: Response Steps Taken: Permit Requirement (specify permit condition #) Date of Deviation:


Number of Deviations: Probable Cause of Deviation: Response Steps Taken:


Page 2 of 2

Permit Requirement (specify permit condition #) Date of Deviation:






Number of Deviations: Probable Cause of Deviation: Response Steps Taken:

Form Completed by: _______________________________________________________

Title / Position: ___________________________________________________________

Date: ___________________________________________________________________

Phone: _________________________________________________________________

Indiana Department of Environmental Management Office of Air Quality

Technical Support Document (TSD) for a Significant Permit Revision to a

Federally Enforceable State Operating Permit (FESOP)

Source Description and Location Source Name: New NGC, Inc., d/b/a National Gypsum Company Source Location: 75 Ivy Lane, Clinton, Indiana, 47842 County: Vermillion SIC Code: 3272 Operation Permit No.: F165-27682-00081 Operation Permit Issuance Date: July 14, 2009 Significant Permit Revision No.: 165-35908-00081 Permit Reviewer: Brian Wright On June 5, 2015, the Office of Air Quality (OAQ) received an application from New NGC, Inc., d/b/a National Gypsum Company requesting a correction to the potential to emit of the polystyrene expansion, aging, and drying system, identified as U12, at an existing concrete backerboard plant.

Existing Approvals The source was issued FESOP Renewal No. F165-27682-00081 on July 14, 2009. There have been no subsequent approvals issued.

County Attainment Status The source is located in Vermillion County.

Pollutant Designation SO2 Better than national standards. CO Unclassifiable or attainment effective November 15, 1990. O3 Unclassifiable or attainment effective July 20, 2012, for the 2008 8-hour ozone standard.1

PM2.5 Unclassifiable or attainment effective April 5, 2005, for the annual PM2.5 standard. PM2.5 Unclassifiable or attainment effective December 13, 2009, for the 24-hour PM2.5

standard. PM10 Attainment effective October 27, 1997, for the part of Clinton Township that includes

sections 15, 16, 21, 22, 27, 28, 33, and 34. Unclassifiable effective November 15, 1990, for the remainder of Vermillion County.

NO2 Cannot be classified or better than national standards. Pb Unclassifiable or attainment effective December 31, 2011.

1Unclassifiable or attainment effective October 18, 2000, for the 1-hour ozone standard which was revoked effective June 15, 2005.

(a) Ozone Standards

Volatile organic compounds (VOC) and Nitrogen Oxides (NOx) are regulated under the Clean Air Act (CAA) for the purposes of attaining and maintaining the National Ambient Air Quality Standards (NAAQS) for ozone. Therefore, VOC and NOx emissions are considered when evaluating the rule applicability relating to ozone. Vermillion County has been designated as attainment or unclassifiable for ozone. Therefore, VOC and NOx emissions were reviewed pursuant to the requirements for Prevention of Significant Deterioration (PSD), 326 IAC 2-2.

New NGC d/b/a National Gypsum Company Page 2 of 25 Clinton, Indiana TSD for FESOP SPR No. 165-35908-00081 Permit Reviewer: Brian Wright

(b) PM2.5 Vermillion County has been classified as attainment for PM2.5. Therefore, direct PM2.5, SO2, and NOx emissions were reviewed pursuant to the requirements for Prevention of Significant Deterioration (PSD), 326 IAC 2-2.

(c) Other Criteria Pollutants

Vermillion County has been classified as attainment or unclassifiable in Indiana for all other criteria pollutants. Therefore, these emissions were reviewed pursuant to the requirements for Prevention of Significant Deterioration (PSD), 326 IAC 2-2.

Fugitive Emissions

Since this type of operation is not one of the twenty-eight (28) listed source categories under 326 IAC 2-2, 326 IAC 2-3, or 326 IAC 2-7, and there is no applicable New Source Performance Standard that was in effect on August 7, 1980, fugitive emissions are not counted toward the determination of PSD, Emission Offset, and Part 70 Permit applicability.

Status of the Existing Source The table below summarizes the potential to emit of the entire source, prior to the proposed revision, after consideration of all enforceable limits established in the effective permits: This PTE table is from the TSD or Appendix A of F165-27682-00081, issued on July 14, 2009.

Process/ Emission Unit

Potential To Emit of the Entire Source Prior to Revision (tons/year)

PM PM10* PM2.5** SO2 NOx VOC CO Total HAPs

Worst Single HAP

(hexane) Sorage Silos and Bins- U1, U2, U3, U4, U5, U6, U7, U8, U9, Sand Storage Room-U13

18.63 18.63 18.63 − − − − − −

Conveying/Mixing (U10) 2.52 2.52 2.52 − − − − − − Board Sawing (U11) 1.88 1.88 1.88 − − − − − − Insignificant Activities-Boiler and Space Heaters 0.07 0.29 0.29 0.02 3.82 0.21 3.21 0.07 0.07

Polystyrene Expansion System (U12) − − − − − 24.50 − − −

Total PTE of Entire Source 23.10 23.31 23.31 0.02 3.82 24.71 3.21 0.07 0.07 Title V Major Source Thresholds - 100 100 100 100 100 100 25 10 PSD Major Source Thresholds 250 250 250 250 250 250 250 - - * Under the Part 70 Permit program (40 CFR 70), PM10 and PM2.5, not particulate matter (PM), are each considered as a "regulated air pollutant". **PM2.5 listed is direct PM2.5. (a) This existing source is not a major stationary source under PSD (326 IAC 2-2), because no PSD

regulated pollutant, excluding GHGs, is emitted at a rate of 250 tons per year or more, and it is not one of the twenty-eight (28) listed source categories as specified in 326 IAC 2-2-1(ff)(1).

(b) This existing source is not a major source of HAPs, as defined in 40 CFR 63.41, because the

unlimited potential to emit HAPs is less than ten (10) tons per year for any single HAP and less than twenty-five (25) tons per year of a combination of HAPs. Therefore, this source is an area source under Section 112 of the Clean Air Act (CAA).


Description of Proposed Revision The Office of Air Quality (OAQ) has reviewed an application, submitted by New NGC d/b/a National Gypsum Company on June 5, 2015, requesting a correction to the potential to emit (PTE) of the polystyrene expansion, aging, and drying system, identified as U12, at an existing concrete backerboard plant. The PTE of VOC from this system was originally calculated using a value of 3.5% for the weight percent VOC (pentane) in the polystyrene beads used in this system; however, the Material Data Safety Sheet (MSDS) provided by the manufacturer indicates a maximum value of 7.5% for the weight percent VOC (pentane) in the polystyrene beads used in this system. The corrected unlimited PTE VOC from this system is 144.87 tons per year (TPY). In order to meet the requirements of 326 IAC 8-1-6 Best Available Control Technology (BACT), the source is requesting to limit the VOC content of polystyrene beads to equal to or less than 7.5% and to limit the total throughput of polystyrene beads to equal to or less than 700 tons per twelve (12) month consecutive period (equivalent to 52.50 tons/year of VOC. Prior to this permit revision, the PTE VOC from this system was 67.61 TPY with the source taking an emission limitation of 24.50 to avoid 326 IAC 8-1-6 (BACT). The following is a description of the system: (a) One (1) Polystyrene Expansion, Aging, and Drying System operating in batch mode, identified as

U12, constructed in 2005 with a maximum capacity of 2,205 lbs of polystyrene beads per batch and a batch time of 5 hours, exhausting to stack identified as S11 with no control.

Enforcement Issues

IDEM is aware that the potential to emit of the polystyrene expansion, aging, and drying system is higher than initially specified in the original permit. IDEM is reviewing this matter and will take appropriate action. This draft permit type contains provisions to bring unpermitted equipment into compliance with the construction and operation permit rules and the requirements of 326 IAC 8-1-6 Best Available Control Technology (BACT).

Emission Calculations See Appendix A of this TSD for detailed emission calculations.

Permit Level Determination – FESOP Revision The following table is used to determine the appropriate permit level under 326 IAC 2-8-11.1 (Permit Revisions). This table reflects the PTE before controls of the proposed revision or amendment. Control equipment is not considered federally enforceable until it has been required in a federally enforceable permit.


Limited PTE of Proposed Revision (tons/year)

PM PM10 PM2.5 SO2 NOx VOC CO Total HAPs

Worst Single HAP

Polystyrene Expansion, Aging, and Drying System (U12)

− − − − − 52.50 − − −

Total Limited PTE of Proposed Revision − − − − − 52.50 − − −

Pursuant to 326 IAC 2-8-11.1(f)(1)(C), this FESOP is being revised through a FESOP Significant Permit Revision because the proposed revision is not an Administrative Amendment or Minor Permit revision and the proposed revision is subject to 326 IAC 8-1-6 (BACT).


PTE of the Entire Source After Issuance of the FESOP Revision The table below summarizes the potential to emit of the entire source reflecting adjustment of existing limits, with updated emissions shown as bold values and previous emissions shown as strikethrough values.


Potential To Emit of the Entire Source to accommodate the Proposed Revision (tons/year)


Worst Single HAP

Sorage Silos and Bins- U1, U2, U3, U4, U5, U6, U7, U8, U9, Sand Storage Room-U13

18.63 18.63 18.63 − − − − − −


Polystyrene Expansion, Aging, and Drying System (U12) − − − − − 24.50

52.50 − − −

Total PTE of Entire Source 23.10 23.32 23.32 0.02 3.94 24.71 52.72 3.21 0.07 0.07

Title V Major Source Thresholds - 100 100 100 100 100 100 25 10 PSD Major Source Thresholds 250 250 250 250 250 250 250 - - *Under the Part 70 Permit program (40 CFR 70), PM10 and PM2.5, not particulate matter (PM), are each considered as a "regulated air pollutant". ** PM2.5 listed is direct PM2.5. The table below summarizes the potential to emit of the entire source after issuance of this revision, reflecting all limits, of the emission units. (Note: the table below was generated from the above table, with bold text un-bolded and strikethrough text deleted).


Potential To Emit of the Entire Source After Issuance Proposed Revision (tons/year)


Worst Single HAP

Sorage Silos and Bins- U1, U2, U3, U4, U5, U6, U7, U8, U9, Sand Storage Room-U13

18.63 18.63 18.63 − − − − − −


Polystyrene Expansion, Aging, and Drying System (U12) − − − − − 52.50 − − −

Total PTE of Entire Source 23.10 23.31 23.31 0.02 3.82 52.72 3.21 0.07 0.07 Title V Major Source Thresholds - 100 100 100 100 100 100 25 10 PSD Major Source Thresholds 250 250 250 250 250 250 250 - - *Under the Part 70 Permit program (40 CFR 70), PM10 and PM2.5, not particulate matter (PM), are each considered as a "regulated air pollutant". ** PM2.5 listed is direct PM2.5. (a) FESOP and PSD Minor Status

This revision to an existing Title V minor stationary source will not change the minor status, because the potential to emit criteria pollutants and HAPs from the entire source will still be


limited to less than the Title V major source threshold levels. Therefore, the source will still be subject to the provisions of 326 IAC 2-8 (FESOP).

(1) VOC

Pursuant to 326 IAC 8-1-6 (New Facilities; General Reduction Requirements), Significant Permit Revision No. 165-35908-00081, and 326 IAC 2-8-4, and in order to render the requirements of 326 IAC 2-7 (Part 70) not applicable, the Permittee shall control VOC emissions from the polystyrene expansion, aging, and drying system (U12) using Best Available Control Technology (BACT), which has been determined to be the following: (a) VOC content of polystyrene beads shall not exceed 7.5% by weight. (b) The total throughput of polystyrene beads shall not exceed 700 tons per twelve

(12) month consecutive period. Compliance with the above shall satisfy the requirements of 326 IAC 8-1-6 (New Facilities, General Reduction Requirements) for the polystyrene expansion, aging, and drying system (U12). Compliance with these limits, combined with the potential to emit VOC from all other emission units at this source, shall limit the source-wide total potential to emit of VOC to less than 100 tons per twelve (12) consecutive month period, and shall render the requirements of 326 IAC 2-7 (Part 70 Permits) not applicable.

(2) PM


Unit ID

Hourly PM Limit (lbs/hr)

Control ID


Total 5.26

Compliance with above conditions shall limit the source-wide PM emissions to less than 250 tons per twelve consecutive month period and shall render the requirements of 326 IAC 2-2 (PDS) not applicable.

New NGC d/b/a National Gypsum Company Page 6 of 25 Clinton, Indiana TSD for FESOP SPR No. 165-35908-00081 Permit Reviewer: Brian Wright PM10 and PM2.5

Pursuant to 326 IAC 2-8-4 and in order to render the requirements of 326 IAC 2-7 (Part 70) and 326 IAC 2-2 (PSD) not applicable, the PM10 and PM2.5 emissions shall not exceed the hourly rates expressed in the following table:

Unit ID

Hourly PM10 Limit

(lbs/hr)

Hourly PM2.5 Limit

(lbs/hr)

Control ID

Portland Cement Storage Silo (U1) 0.47 0.47 Cartridge Filter (CE1) Portland Cement Storage Silo (U2) 0.47 0.47 Cartridge Filter (CE2) Fly Ash Storage Silo (U3) 0.47 0.47 Cartridge Filter (CE3) Fly Ash Storage Silo (U4) 0.47 0.47 Cartridge Filter (CE4) Aluminate Storage Silo (U5) 0.47 0.47 Cartridge Filter (CE5) Aluminate Storage Silo (U6) 0.47 0.47 Cartridge Filter (CE6) Portland Cement Bin (U7) 0.47 0.47 Baghouse (CE7) Fly Ash Bin (U8) 0.47 0.47 Baghouse (CE8) Aluminate Bin (U9) 0.47 0.47 Baghouse (CE9) Wet End Operations (U10) 0.57 0.57 Baghouse (CE10) Board Sawing Operations (U11) 0.43 0.43 Cartridge Filter (CE11) Sand Storage Room (U13) 0.02 0.02 (High Moisture)

Total 5.26 5.26 Compliance with above conditions shall limit the source-wide PM10, and PM2.5 emissions to less than 100 tons per twelve consecutive month period, each and shall render the requirements of 326 IAC 2-7 (Part 70) and 326 IAC 2-2 (PSD) not applicable.

Federal Rule Applicability Determination New Source Performance Standards (NSPS)

(a) The requirements of the New Source Performance Standard for Volatile Organic Compound (VOC) Emissions from the Polymer Manufacturing Industry, 40 CFR 60, Subpart DDDD (326 IAC 12), are not included in the permit, since this source does not manufacture polystyrene. The provisions of this subpart apply to affected facilities involved in the manufacture of polypropylene, polyethylene, polystyrene, or poly (ethylene terephthalate) as defined in §60.561. This source uses polystyrene beads that were not manufactured at the source.

(b) There are no New Source Performance Standards (40 CFR Part 60) and 326 IAC 12

included for this proposed revision. National Emission Standards for Hazardous Air Pollutants (NESHAP)

(a) The requirements of the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Group I Polymers and Resins, 40 CFR 63, Subpart U (326 IAC 20-19), are not included in the permit since this source does not manufacture an elastomer as defined in §63.482 and therefore does not have an elastomer product process unit (EPPU) as defined in §63.482. This source uses polystyrene beads and other materials (Portland cement, fly ash, plastics, additives, water, etc.) to manufacture concrete backer boards.

(b) The requirements of the National Emission Standards for Hazardous Air Pollutants

(NESHAP) for Epoxy Resins Production and Non-Nylon Polyamides Production, 40 CFR 63, Subpart W (326 IAC 20-20), are not included in the permit since this source does not


manufacture basic liquid epoxy resins (BLR) or wet strength resins (WSR) as defined in §63.522 and this source is not a major source of HAPs as defined in §63.2. This source uses polystyrene beads and other materials (Portland cement, fly ash, plastics, additives, water, etc.) to manufacture concrete backer boards.

(c) The requirements of the National Emission Standards for Hazardous Air Pollutants

(NESHAP) for Flexible Polyurethane Foam Production, 40 CFR 63, Subpart III (326 IAC 20-22), are not included in the permit since this source does not produce flexible polyurethane or rebond foam as defined in §63.1292, and this source is not a major source of HAPs as defined in §63.2. This source uses polystyrene beads and other materials (Portland cement, fly ash, plastics, additives, water, etc.) to manufacture concrete backer boards.

(d) The requirements of the National Emission Standards for Hazardous Air Pollutants

(NESHAP) for Group IV Polymers and Resins, 40 CFR 63, Subpart JJJ (326 IAC 20-21), are not included in the permit since the Polystyrene Expansion, Aging, and Drying System (U12) is not considered a thermoplastic product process unit (TPPU) as defined in §63.1312. Pursuant to §63.1310(f)(1)(iv), the primary product produced by U12 is not considered a thermoplastic product as defined in §63.1312. Although polystyrene resin from a batch process is considered a thermoplastic product as defined in §63.1312, this source does not produce polystyrene resin as their primary product, rather this source uses polystyrene beads and other materials (Portland cement, fly ash, plastics, additives, water, etc.) to manufacture concrete backer boards.

(e) The requirements of the National Emission Standards for Hazardous Air Pollutants

(NESHAP) for Reinforced Plastic Composites Production, 40 CFR 63, Subpart WWWW (326 IAC 20-56), are not included in the permit since this source is not a reinforced plastic composites production facility as defined in §63.5785, and this source is not a major source of HAPs as defined in §63.2. This source uses polystyrene beads and other materials (Portland cement, fly ash, plastics, additives, water, etc.) to manufacture concrete backer boards.

(f) The requirements of the National Emission Standards for Hazardous Air Pollutants

(NESHAP) for Flexible Polyurethane Foam Fabrication Operations, 40 CFR 63, Subpart MMMMM (326 IAC 20-66), are not included in the permit since this source does not own or operate a flexible polyurethane foam fabrication plant site, as defined in §63.8782, that operates a flame lamination affected source, as defined at §63.8784(b)(2), or operates a loop slitter affected source, as defined at §63.8784(b)(1), and this source is not a major source of HAPs as defined in §63.2. This source uses polystyrene beads and other materials (Portland cement, fly ash, plastics, additives, water, etc.) to manufacture concrete backer boards.

(g) The requirements of the National Emission Standards for Hazardous Air Pollutants

(NESHAP) for Polyvinyl Chloride and Copolymers Production, 40 CFR 63, Subpart HHHHHHH, are not included in the permit, since this source does not own or operate one or more polyvinyl chloride and copolymers production process units (PVCPU) as defined in §63.12005, and this source is not a major source of HAPs as defined in §63.2. This source uses polystyrene beads and other materials (Portland cement, fly ash, plastics, additives, water, etc.) to manufacture concrete backer boards.

(h) There are no National Emission Standards for Hazardous Air Pollutants (40 CFR Part

63), 326 IAC 14 and 326 IAC 20 included for this proposed revision.

New NGC d/b/a National Gypsum Company Page 8 of 25 Clinton, Indiana TSD for FESOP SPR No. 165-35908-00081 Permit Reviewer: Brian Wright Compliance Assurance Monitoring (CAM)

(a) Pursuant to 40 CFR 64.2, Compliance Assurance Monitoring (CAM) is not included in the permit, because the potential to emit of the source is limited to less than the Title V major source thresholds and the source is not required to obtain a Part 70 or Part 71 permit.

State Rule Applicability Determination

(a) 326 IAC 2-8-4 (FESOP)

This revision to an existing Title V minor stationary source will not change the minor status, because the potential to emit criteria pollutants from the entire source will still be limited to less than the Title V major source threshold levels. Therefore, the source will still be subject to the provisions of 326 IAC 2-8 (FESOP). See PTE of the Entire Source After Issuance of the FESOP Revision Section above.

(b) 326 IAC 2-2 (Prevention of Significant Deterioration (PSD))

This modification to an existing PSD minor stationary source will not change the PSD minor status, because the potential to emit of all attainment regulated pollutants from the entire source will continue to be less than the PSD major source threshold levels. Therefore, pursuant to 326 IAC 2-2, the PSD requirements do not apply. See PTE of the Entire Source After Issuance of the FESOP Revision Section above.

(c) 326 IAC 2-4.1 (Major Sources of Hazardous Air Pollutants (HAP)) The proposed revision is not subject to the requirements of 326 IAC 2-4.1, since the unlimited potential to emit of HAPs from the modified unit is less than ten (10) tons per year for any single HAP and less than twenty-five (25) tons per year of a combination of HAPs.

(d) 326 IAC 2-6 (Emission Reporting)

Pursuant to 326 IAC 2-6-1, this source is not subject to this rule, because it is not required to have an operating permit under 326 IAC 2-7 (Part 70), it is not located in Lake, Porter, or LaPorte County, and it does not emit lead into the ambient air at levels equal to or greater than 5 tons per year. Therefore, 326 IAC 2-6 does not apply.

(e) 326 IAC 5-1 (Opacity Limitations)

Pursuant to 326 IAC 5-1-2 (Opacity Limitations), except as provided in 326 IAC 5-1-3 (Temporary Alternative Opacity Limitations), opacity shall meet the following, unless otherwise stated in this permit:

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

averaging period as determined in 326 IAC 5-1-4. (2) 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.

(f) 326 IAC 6-4 (Fugitive Dust Emissions Limitations)

Pursuant to 326 IAC 6-4 (Fugitive Dust Emissions Limitations), the source 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.

(g) 326 IAC 12 (New Source Performance Standards)

See Federal Rule Applicability Section of this TSD. (h) 326 IAC 20 (Hazardous Air Pollutants)

See Federal Rule Applicability Section of this TSD.

New NGC d/b/a National Gypsum Company Page 9 of 25 Clinton, Indiana TSD for FESOP SPR No. 165-35908-00081 Permit Reviewer: Brian Wright Polystyrene Expansion, Aging, and Drying System (U12) (a) 326 IAC 8-1-6 (VOC Rules: General Reduction Requirements for New Facilities)

The Polystyrene Expansion, Aging, and Drying System (U12) is subject to the requirements of 326 IAC 8-1-6 since it has unlimited potential VOC emissions of greater than twenty-five (25) tons per year. Therefore, IDEM, OAQ has performed a BACT analysis, which was based on the Draft "Top Down Approach: BACT Guidance" by USEPA, Office of Air Quality Planning Standards, March 15, 1990 (see Appendix B of this TSD). Pursuant to 326 IAC 8-1-6, (New Facilities; General Reduction Requirements) and Significant Permit Revision No. 165-35908-00081, the Permittee shall control VOC emissions from the polystyrene expansion, aging, and drying system (U12) using Best Available Control Technology (BACT), which has been determined to be the following: (a) VOC content of polystyrene beads shall not exceed 7.5% by weight. (b) The total throughput of polystyrene beads shall not exceed 700 tons per twelve (12)

month consecutive period. Compliance with the above shall satisfy the requirements of 326 IAC 8-1-6 (New Facilities, General Reduction Requirements) for the polystyrene expansion, aging, and drying system (U12). See Appendix B of this Technical Support Document for the detailed BACT Analysis.

Compliance Determination, Monitoring and Testing Requirements

(a) The compliance determination and monitoring requirements applicable to this proposed revision

are as follows:

Emission Unit Control Operating

Parameters Frequency Portland Cement Storage Silo (U1) Cartridge Filter Visible Emissions Once per day Portland Cement Storage Silo (U2) Cartridge Filter Visible Emissions Once per day Fly Ash Storage Silo (U3) Cartridge Filter Visible Emissions Once per day Fly Ash Storage Silo (U4) Cartridge Filter Visible Emissions Once per day Aluminate Storage Silo (U5) Cartridge Filter Visible Emissions Once per day Aluminate Storage Silo (U6) Cartridge Filter Visible Emissions Once per day Portland Cement Bin (U7) Baghouse Visible Emissions Once per day Fly Ash Bin (U8) Baghouse Visible Emissions Once per day Aluminate Bin (U9) Baghouse Visible Emissions Once per day Wet End Operations (U10) Baghouse Visible Emissions Once per day Board Sawing Operations (U11) Cartridge Filter Visible Emissions Once per day

Sand Storage Room (U13) No Control Device

(High Moisture Content Material)

Visible Emissions Once per day

These monitoring conditions are necessary because the catridge filters, baghouses, and use of high moisture material for the units listed above must be operated/implented properly to ensure compliance with 326 IAC 6-3 (Particulate Emissions Limitations for Manufacturing Processes), 326 IAC 2-8 (FESOP), and 326 IAC 2-2 (PSD).


Proposed Changes The following changes listed below are due to the proposed revision. Deleted language appears as strikethrough text and new language appears as bold text: (1) Section D.1 has been amended as follows in order to incorporate the VOC limits required by the

BACT analysis findings. IDEM is also amending the compliance determination requirements in accordance with current IDEM policy of only requiring one type of compliance monitoring for each unit. The source requested that visible emissions be used. Other changes were made to clarify permit requirements:

******* D.1.2 Particulate Matter (PM) [326 IAC 2-2]


Unit ID Hourly PM Limit (lbs/hr) Control ID


Total 5.26

Compliance with above conditions shall limit the source-wide PM emissions to less than 250 tons per twelve consecutive month period and shall render 326 IAC 2-7 (Part 70), and the requirements of 326 IAC 2-2 (PSD) not applicable.

D.1.3 Particulate Matter (PM10), (PM2.5) [326 IAC 2-8-4] [326 IAC 2-2] Pursuant to 326 IAC 2-8-4 and in order to render the requirements of 326 IAC 2-7 (Part 70) and 326 IAC 2-2 (PSD) not applicable, the PM10 and PM2.5 emissions shall not exceed the hourly rates expressed in the following table:

Unit ID

Hourly PM10 Limit

(lbs/hr)

Hourly PM2.5 Limit

(lbs/hr)

Control ID

Portland Cement Storage Silo (U1) 0.47 0.47 Cartridge Filter (CE1) Portland Cement Storage Silo (U2) 0.47 0.47 Cartridge Filter (CE2) Fly Ash Storage Silo (U3) 0.47 0.47 Cartridge Filter (CE3) Fly Ash Storage Silo (U4) 0.47 0.47 Cartridge Filter (CE4) Aluminate Storage Silo (U5) 0.47 0.47 Cartridge Filter (CE5) Aluminate Storage Silo (U6) 0.47 0.47 Cartridge Filter (CE6) Portland Cement Bin (U7) 0.47 0.47 Baghouse (CE7) Fly Ash Bin (U8) 0.47 0.47 Baghouse (CE8) Aluminate Bin (U9) 0.47 0.47 Baghouse (CE9) Wet End Operations (U10) 0.57 0.57 Baghouse (CE10)


Unit ID

Hourly PM10 Limit

(lbs/hr)

Hourly PM2.5 Limit

(lbs/hr)

Control ID

Board Sawing Operations (U11) 0.43 0.43 Cartridge Filter (CE11) Sand Storage Room (U13) 0.02 0.02 (High Moisture)

Total 5.26 5.26 Compliance with above conditions shall limit the source-wide PM10, and PM2.5 emissions to less than 100 tons each per twelve consecutive month period, eachwith compliance determined at the end of each month, respectively. These limits will and shall render the requirements of 326 IAC 2-7 (Part 70) and 326 IAC 2-2 (PSD) not applicable.

D.1.4 VOC [326 IAC 8-1-6] [326 IAC 2-8-4]

The VOC emissions from one (1) Polystyrene Expansion System, identified as U12 shall not exceed 3.5 % by weight per ton of polystyrene throughput, and the total throughput shall not exceed 700 tons per twelve (12) consecutive month period, with compliance determined at the end of each month. This is equivalent to 24.5 tons of VOC per year. Compliance with above conditions shall limit the source-wide VOC emissions to less than 100 tons per twelve consecutive month period; and render the requirements of 326 IAC 8-1-6 not applicable. Pursuant to 326 IAC 8-1-6 (New Facilities; General Reduction Requirements), Significant Permit Revision No. 165-35908-00081, and 326 IAC 2-8-4, and in order to render the requirements of 326 IAC 2-7 (Part 70) not applicable, the Permittee shall control VOC emissions from the polystyrene expansion, aging, and drying system (U12) using Best Available Control Technology (BACT), which has been determined to be the following: (a) VOC content of polystyrene beads shall not exceed 7.5% by weight. (b) The total throughput of polystyrene beads shall not exceed 700 tons per twelve

(12) month consecutive period. Compliance with the above shall satisfy the requirements of 326 IAC 8-1-6 (New Facilities, General Reduction Requirements) for the polystyrene expansion, aging, and drying system (U12). Compliance with these limits, combined with the potential to emit VOC from all other emission units at this source, shall limit the source-wide total potential to emit of VOC to less than 100 tons per twelve (12) consecutive month period, and shall render the requirements of 326 IAC 2-7 (Part 70 Permits) not applicable.

D.1.5 Preventive Maintenance Plan [326 IAC 2-8-4(9)] A Preventive Maintenance Plan, in accordance with Section B - Preventive Maintenance Plan, of this permit, is required for this facility the above units and 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 [326 IAC 2-8-4(1)] D.1.6 Particulate Control

In order to comply with Conditions D.1.1, D.1.2, and D.1.3 particulate from the storage, conveying and manufacturing processes shall be controlled by baghouses/cartridge filters at all times that the storage, conveying and manufacturing processes are in operation. and the Permittee shall operate the control device in accordance with manufacturer’s specifications.

New NGC d/b/a National Gypsum Company Page 12 of 25 Clinton, Indiana TSD for FESOP SPR No. 165-35908-00081 Permit Reviewer: Brian Wright D.1.7 Visible Emissions Notations

(a) Visible emission notations of the stack exhaust from Stack S1 through S9 shall be performed once per day during normal daylight operations when exhausting to the atmosphere. A trained employee shall record whether emissions are normal or abnormal.

(b) For processes operated continuously, "normal" means those conditions prevailing, or

expected to prevail, eighty percent (80%) of the time the process is in operation, not counting startup or shut down time.

(c) A trained employee is an employee who has worked at the plant at least one (1) month

and has been trained in the appearance and characteristics of normal visible emissions for that specific process.

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

in accordance with Section C - Response to Excursions or Exceedances. Failure to take response steps in accordance with Section C - Response to Excursions or Exceedances shall be considered a deviation from this permit.

D.1.7 Volatile Organic Compounds (VOC) [326 IAC 8-1-2] [326 IAC 8-1-4]

Compliance with the VOC usage limitations contained in Condition D.1.4 shall be determined pursuant to 326 IAC 8-1-4(a)(3) and 326 IAC 8-1-2(a) by preparing or obtaining from the manufacturer the copies of the Certificate of Analyses VOC data sheets. IDEM, OAQ reserves the authority to determine compliance using Method 24 in conjunction with the analytical procedures specified in 326 IAC 8-1-4.

Compliance Monitoring Requirements [326 IAC 2-8-4] [326 IAC 2-8-5(a)(1)] D.1.8 Parametric Monitoring

The Permittee shall record the pressure drop across the cartridge filters and baghouse used in conjunction with the concrete backerboard manufacturing process, at least once per day when any of the processes are in operation. When for any one reading, the pressure drop across the dust collector is outside the normal range of 0.5 and 6.0 inches of water or a range established during the latest stack test, the Permittee shall take reasonable response steps in accordance with Section C- Response to Excursions or Exceedances. A pressure reading that is outside the above mentioned range is not a deviation from this permit. Failure to take response steps in accordance with Section C - Response to Excursions or Exceedances shall be considered a deviation from this permit. The instrument used for determining the pressure shall comply with Section C - Instrument Specifications, of this permit, shall be subject to approval by IDEM, OAQ, and shall be calibrated at least once every six (6) months.

D.1.8 Visible Emissions Notations

(a) Visible emission notations of the stack exhaust from Stack S1 through S10 and S12 shall be performed once per day during normal daylight operations when exhausting to the atmosphere. A trained employee shall record whether emissions are normal or abnormal.

(b) For processes operated continuously, "normal" means those conditions

prevailing, or expected to prevail, eighty percent (80%) of the time the process is in operation, not counting startup or shut down time.

(c) A trained employee is an employee who has worked at the plant at least one (1)

month and has been trained in the appearance and characteristics of normal visible emissions for that specific process.


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

steps. Section C - Response to Excursions and Exceedances contains the Permittee's obligations with regard to responding to the reasonable response steps required by this condition. Failure to take response steps shall be considered a deviation from this permit.

D.1.9 Broken or Failed Cartridge Detection ****** Record Keeping and Reporting Requirements [326 IAC 2-8-4(3)] [326 IAC 2-8-16] D.1.10 Record Keeping Requirements

(a) To document the compliance status with Conditions D.1.4(b) and D.1.7, the Permittee shall maintain the following records on a monthly basis:

(1) The VOC content of the Polystyrene beads used. Records shall include the

Certificate of Analyses VOC data sheets from the Polystyrene bead manufacturer for each shipment of the beads along with documentation of each shipment (e.g., purchase order).

(2) Total throughput rate of polystyrene beads each month and each

compliance period.

(b) To document the compliance status with Condition D.1.87, the Permittee shall maintain records of visible emission notations of the stack exhaust from Stack S1 through S10 and S12 once per day. The Permittee shall include in its daily record when a visible emission notation is not taken and the reason for the lack of visible emission notation (e.g., the process did not operate that day).

(c) To document compliance with Condition D.1.8, the Permittee shall maintain: The once per day records of the pressure drop during normal operation. The Permittee

shall include in its daily record when the pressure drop reading is not taken and the reason for the lack of a pressure drop reading (e.g. the process did not operate that day).

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

Requirements of this permit contains the Permittee's obligations with regard to the records required by this condition.

D.1.11 Reporting Requirements

A quarterly summary of the information to document the compliance status with Condition D.1.4 shall be submitted to the address listed in Section C - General Reporting Requirements, of this permit, using the reporting forms located at the end of this permit, or their its equivalent, within thirty (30) days after the end of the quarter being reported. The report submitted by the Permittee does require the certification that meets the requirements of 326 IAC 2-8-5(a)(1) by an “authorized individual” as defined by 326 IAC 2-1.1-1(1).

New NGC d/b/a National Gypsum Company Page 14 of 25 Clinton, Indiana TSD for FESOP SPR No. 165-35908-00081 Permit Reviewer: Brian Wright 2. The following reporting form has been added to incorporate the revision: FESOP Quarterly Report Form ****** Facility: One (1) Polystyrene Expansion, Aging, and Drying System (U12) Parameter: VOC content and Feed Total polystyrene bead throughput Limit: Less than 70 pounds per ton of throughput and less than 700 tons of beads throughput per 12 consecutive month period, with compliance determined at the end of each month.

The total throughput of polystyrene beads shall not exceed 700 tons per twelve (12) month consecutive period.

QUARTER:_____________________ YEAR:_____________________

Month Column 1 Column 2 Column 1 + Column 2

This Month Previous 11 Months 12 Month Total

No deviation occurred in this quarter. Deviation/s occurred in this quarter.

Deviation has been reported on: ___________________

Submitted by: _____________________________________________________

Title / Position: ____________________________________________________

Signature: ________________________________________________________

Date: ____________________________________________________________

Phone: ___________________________________________________________

Attach a signed certification to complete this report. 3. The emission unit description for the Board Sawing Unit has been revised to indicate that it

exhausts to stack S10: A.2 Emission Units and Pollution Control Equipment Summary [326 IAC 2-8-3(c)(3)]

This stationary source consists of the following emission units and pollution control devices: ****** (d) One Board Sawing Unit, identified as U11, constructed in 2005 with a maximum capacity

of 52 square foot of board sawn per hour, equipped with cartridge filters for particulate control identified as CE11, exhausting to either stack identified as S10 or into the building.

******

New NGC d/b/a National Gypsum Company Page 15 of 25 Clinton, Indiana TSD for FESOP SPR No. 165-35908-00081 Permit Reviewer: Brian Wright SECTION D.1 EMISSIONS UNIT OPERATION CONDITIONS

Emissions Unit Description: ****** (d) One Board Sawing Unit, identified as U11, constructed in 2005 with a maximum capacity of 52

square foot of board sawn per hour, equipped with cartridge filters for particulate control identified as CE11, exhausting to either stack identified as S10 or into the building.

******

Additional Changes IDEM, OAQ made additional revisions to the permit as described below in order to update the language to match the most current version of the applicable rule, to eliminate redundancy within the permit, and to provide clarification regarding the requirements of these conditions. (1) For clarity, IDEM has changed references to the general conditions: “in accordance with Section

B”, in accordance with Section C”, or other similar language to "Section C...contains the Permittee’s obligations with regard to the records required by this condition.”

(2) IDEM has decided that the phrases “no later than” and “not later than” are clearer than “within” in

relation to the end of a timeline. Therefore all timelines have been switched to “no later than” or “not later than” except when the underlying rule states “within.”

(3) IDEM has decided to clarify throughout the permit that a certification needs to meet the

requirements of 326 IAC 2-8-5(a)(1). In addition, IDEM has decided to remove the last sentence dealing with the need for certification from the forms because the conditions requiring the forms already addresses this issue.

(4) IDEM has decided to clarify the certification requirements in Section B - Duty to Provide

Information and Section B - Certification. (5) IDEM has decided to clarify the requirements of Section B – Preventive Maintenance Plan and to

add a new paragraph (b) to handle a future situation where the Permittee adds units that need preventive maintenance plans.

(6) IDEM has added 326 IAC 5-1-1 to the exception clause of Section C - Opacity, since 326 IAC 5-

1-1 does list exceptions. (7) IDEM has revised Section C - Incineration to more closely reflect the two underlying rules. (8) IDEM has revised the language of the Section C - Asbestos Abatement Projects to change the

terminology "Accredited" to "Licensed" in order to match the rule. In addition IDEM has revised the language of the Section C - Asbestos Abatement Projects to remove the statement that the requirement to use an Indiana Accredited Asbestos inspector is not federally enforceable, since all conditions and requirements in a FESOP are federally enforceable.

(9) IDEM has removed the first paragraph of Section C - Performance Testing as due to the fact that

specific testing conditions elsewhere in the permit will specify the timeline and procedures. (10) IDEM has revised Section C - Compliance Monitoring. The reference to recordkeeping has been

removed due to the fact that other conditions already address recordkeeping. The voice of the condition has been change to clearly indicate that it is the Permittee that must follow the requirements of the condition. In, addition, IDEM is changing the Section C Compliance


Monitoring Condition to clearly describe when new monitoring for new and existing units must begin.

(11) IDEM has removed Section C - Monitoring Methods. The conditions that require the monitoring

or testing, if required, state what methods shall be used. (12) IDEM has revised Section C - Instrument Specifications to indicate that the analog instrument

must be capable of measuring the parameters outside the normal range. (13) IDEM has revised Section C - Response to Excursions or Exceedances. The introduction

sentence has been added to clarify that it is only when an excursion or exceedance is detected that the requirements of this condition need to be followed. The word "excess" was added to the last sentence of paragraph (a) because the Permittee only has to minimize excess emissions. The middle of paragraph (b) has been deleted as it was duplicative of paragraph (a). The phrase "or are returning" was added to subparagraph (b)(2) as this is an acceptable response assuming the operation or emission unit does return to normal or its usual manner of operation. The phrase "within the indicator range, designated condition, or below the applicable emission limitation or standard, as applicable" was replaced with "normal or usual manner of operation" because the first phrase is just a limited list of the second phrase. The recordkeeping required by paragraph (e) was changed to require only records of the response because the previously listed items are required to be recorded elsewhere in the permit.

(14) IDEM has revised Section C - Actions Related to Noncompliance Demonstrated by a Stack Test.

The requirements to take response steps and minimize excess emissions have been removed because Section C - Response to Excursions or Exceedances already requires response steps related to exceedances and excess emissions minimization. The start of the timelines was switched from "the receipt of the test results" to "the date of the test." There was confusion if the "receipt" was by IDEM, the Permittee, or someone else. Since the start of the timelines has been moved up, the length of the timelines was increased. The new timelines require action within a comparable timeline; and the new timelines still ensure that the Permittee will return to compliance within a reasonable timeframe.

(15) IDEM, OAQ has clarified the Permittee's responsibility with regards to record keeping under

Section C - General Record Keeping. (16) IDEM, OAQ has clarified the interaction of the Quarterly Deviation and Compliance Monitoring

Report and the Emergency Provisions (17) IDEM has decided to simplify the referencing in Section C - Compliance with 40 CFR 82 and 326

IAC 22-1. B.7 Duty to Provide Information [326 IAC 2-8-4(5)(E)]

(a) The Permittee shall furnish to IDEM, OAQ, within a reasonable time, any information that IDEM, OAQ may request in writing to determine whether cause exists for modifying, revoking and reissuing, or terminating this permit, or to determine compliance with this permit. The submittal by the Permittee does require the certification by an "authorized individual" as defined by 326 IAC 2-1.1-1(1). Upon request, the Permittee shall also furnish to IDEM, OAQ copies of records required to be kept by this permit.

****** B.8 Certification [326 IAC 2-8-3(d)][326 IAC 2-8-4(3)(C)(i)][326 IAC 2-8-5(1)]

(a) Where specifically designated by this permit or required by an applicable requirement, any application form, report, or compliance certification submitted shall contain certification by an "authorized individual" of truth, accuracy, and completeness. This certification shall state that,A certification required by this permit meets the requirements of 326 IAC 2-8-5(a)(1) if:


(1) it contains a certification by an "authorized individual", as defined by 326 IAC 2-1.1-1(1), and

(2) the certification states that, based on information and belief formed after

reasonable inquiry, the statements and information in the document are true, accurate, and complete.

(b) One (1) certification shall be included, usingThe Permittee may use the attached

Certification Form, or its equivalent with each submittal requiring certification. One (1) certification may cover multiple forms in one (1) submittal.

****** B.9 Annual Compliance Certification [326 IAC 2-8-5(a)(1)] ******

(c) The annual compliance certification report shall include the following: ******

The submittal by the Permittee does require the a certification that meets the requirements of 326 IAC 2-8-5(a)(1) by an "authorized individual" as defined by 326 IAC 2-1.1-1(1).

****** B.11 Preventive Maintenance Plan [326 IAC 1-6-3][326 IAC 2-8-4(9)][326 IAC 2-8-5(a)(1)]

(a) If required by specific condition(s) in Section D of this permit, the Permittee shall maintain and implement Preventive Maintenance Plans (PMPs) including the following information on each facility:

(a) A Preventive Maintenance Plan meets the requirements of 326 IAC 1-6-3 if it

includes, at a minimum:

(1) Identification of the individual(s) responsible for inspecting, maintaining, and repairing emission control devices;

(2) A description of the items or conditions that will be inspected and the inspection

schedule for said items or conditions; and

(3) Identification and quantification of the replacement parts that will be maintained in inventory for quick replacement.

The Permittee shall implement the PMPs.

(b) If required by specific condition(s) in Section D of this permit where no PMP was

previously required, 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) responsible for inspecting, maintaining,

and repairing emission control devices; (2) A description of the items or conditions that will be inspected and the

inspection schedule for said items or conditions; and (3) Identification and quantification of the replacement parts that will be

maintained in inventory for quick replacement.


If, due to circumstances beyond the Permittee’s control, the PMPs cannot be prepared and maintained within the above time frame, the Permittee may extend the date an additional ninety (90) days provided the Permittee notifies: Indiana Department of Environmental Management Compliance 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 require a certification that meets the requirements of 326 IAC 2-8-5(a)(1) by an "authorized individual" as defined by 326 IAC 2-1.1-1(1). The Permittee shall implement the PMPs.

(bc) A copy of the PMPs shall be submitted to IDEM, OAQ upon request and within a

reasonable time, and shall be subject to review and approval by IDEM, OAQ. IDEM, OAQ may require the Permittee to revise its PMPs whenever lack of proper maintenance causes or is the primary contributor to an exceedance of any limitation on emissions or potential to emit. The PMPs and their submittal do not require the certification a certification that meets the requirements of 326 IAC 2-8-5(a)(1) by an "authorized individual" as defined by 326 IAC 2-1.1-1(1).

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

Maintenance, and Monitoring (OMM) Plan for a unit, such Plan is deemed to satisfy the PMP requirements of 326 IAC 1-6-3 for that unit.

****** B.15 Deviations from Permit Requirements and Conditions [326 IAC 2-8-4(3)(C)(ii)]

(a) Deviations from any permit requirements (for emergencies see Section B - Emergency Provisions), the probable cause of such deviations, and any response steps or preventive measures taken shall be reported to:

Indiana Department of Environmental Management Compliance Data Section, Office of Air Quality 100 North Senate Avenue MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251

using the attached Quarterly Deviation and Compliance Monitoring Report, or its equivalent. A deviation required to be reported pursuant to an applicable requirement that exists independent of this permit, shall be reported according to the schedule stated in the applicable requirement and does not need to be included in this report.

The Quarterly Deviation and Compliance Monitoring Report does require the certification by an "authorized individual" as defined by 326 IAC 2-1.1-1(1).

(b) A deviation is an exceedance of a permit limitation or a failure to comply with a

requirement of the permit. B.1516 Permit Modification, Reopening, Revocation and Reissuance, or Termination

[326 IAC 2-8-4(5)(C)][326 IAC 2-8-7(a)][326 IAC 2-8-8] (a) This permit may be modified, reopened, revoked and reissued, or terminated for cause.

The filing of a request by the Permittee for a Federally Enforceable State Operating Permit modification, revocation and reissuance, or termination, or of a notification of


planned changes or anticipated noncompliance does not stay any condition of this permit. [326 IAC 2-8-4(5)(C)] The notification by the Permittee does require the certificationa certification that meets the requirements of 326 IAC 2-8-5(a)(1) by an "authorized individual" as defined by 326 IAC 2-1.1-1(1).

****** B.1617 Permit Renewal [326 IAC 2-8-3(h)]

(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 2-8-3. Such information shall be included in the application for each emission unit at this source, except those emission units included on the trivial or insignificant activities list contained in 326 IAC 2-7-1(21) and 326 IAC 2-7-1(4042). The renewal application does require the a certification that meets the requirements of 326 IAC 2-8-5(a)(1) by an "authorized individual" as defined by 326 IAC 2-1.1-1(1).

******

(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 2-8 until IDEM, OAQ takes final action on the renewal application, except that this protection shall cease to apply if, subsequent to the completeness determination, the Permittee fails to submit by the deadline specified, pursuant to 326 IAC 2-8-3(g), in writing by IDEM, OAQ any additional information identified as being needed to process the application.

B.1718 Permit Amendment or Revision [326 IAC 2-8-10][326 IAC 2-8-11.1] ******

Any such application shall be certifieddoes require a certification that meets the requirements of 326 IAC 2-8-5(a)(1) by an "authorized individual" as defined by 326 IAC 2-1.1-1(1).

******* B.1819 Operational Flexibility [326 IAC 2-8-15][326 IAC 2-8-11.1]

(a) The Permittee may make any change or changes at the source that are described in 326 IAC 2-8-15(b) and (c) through (d)without a prior permit revision, if each of the following conditions is met:

****** (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 2-8-15(b)(2), (c)(1), and (d) (b)(1) and (c). The Permittee shall make such records available, upon reasonable request, for public review.

Such records shall consist of all information required to be submitted to IDEM, OAQ in the notices specified in 326 IAC 2-8-15(b)(2), (c)(1), and (d) (b)(1) and (c).

(b) Emission Trades [326 IAC 2-8-15(c)(b)]

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 2-8-15(c)(b).

(c) Alternative Operating Scenarios [326 IAC 2-8-15(d)(c)]

The Permittee may make changes at the source within the range of alternative operating scenarios that are described in the terms and conditions of this permit in accordance with 326 IAC 2-8-4(7). No prior notification of IDEM, OAQ, or U.S. EPA is required.

New NGC d/b/a National Gypsum Company Page 20 of 25 Clinton, Indiana TSD for FESOP SPR No. 165-35908-00081 Permit Reviewer: Brian Wright B.1920 Source Modification Requirement [326 IAC 2-8-11.1] ****** B.2021 Inspection and Entry [326 IAC 2-8-5(a)(2)][IC 13-14-2-2][IC 13-17-3-2][IC 13-30-3-1] ****** B.2122 Transfer of Ownership or Operational Control [326 IAC 2-8-10] ******

TheAny such application which shall be submitted by the Permittee does require the a certification that meets the requirements of 326 IAC 2-8-5(a)(1) by an "authorized individual" as defined by 326 IAC 2-1.1-1(1).

******

B.2223 Annual Fee Payment [326 IAC 2-7-19][326 IAC 2-8-4(6)][326 IAC 2-8-16][326 IAC 2-1.1-7] (a) The Permittee shall pay annual fees to IDEM, OAQ withinno later than 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.23 Advanced Source Modification Approval [326 IAC 2-8-4(11)] [326 IAC 2-1.1-9]

(a) The requirements to obtain a permit modification under 326 IAC 2-8-11.1 are satisfied by this permit for the proposed emission units, control equipment or insignificant activities in Sections A.2 and A.3.

(b) Pursuant to 326 IAC 2-1.1-9 any permit authorizing construction may be revoked if construction of the emission unit has not commenced within eighteen (18) months from the date of issuance of the permit, or if during the construction, work is suspended for a continuous period of one (1) year or more.

B.2325 Credible Evidence [326 IAC 2-8-4(3)][326 IAC 2-8-5][62 FR 8314][326 IAC 1-1-6] ******

C.2 Overall Source Limit [326 IAC 2-8] ******

(b) Pursuant to 326 IAC 2-2 (PSD), potential to emit particulate matter (PM) from the entire

source shall be limited to less than one hundred (100) two hundred fifty (250) tons per twelve (12) consecutive month period.

C.3 Opacity [326 IAC 5-1]

Pursuant to 326 IAC 5-1-2 (Opacity Limitations), except as provided in 326 IAC 5-1-1 (Applicability) and 326 IAC 5-1-3 (Temporary Alternative Opacity Limitations), opacity shall meet the following, unless otherwise stated in this permit:

****** C.5 Incineration [326 IAC 4-2][326 IAC 9-1-2]

The Permittee shall not operate an incinerator or incinerate any waste or refuse except as provided in 326 IAC 4-2 and 326 IAC 9-1-2or in this permit. The Permittee shall not operate a refuse incinerator or refuse burning equipment except as provided in 326 IAC 9-1-2 or in this permit.

******

New NGC d/b/a National Gypsum Company Page 21 of 25 Clinton, Indiana TSD for FESOP SPR No. 165-35908-00081 Permit Reviewer: Brian Wright C.8 Performance Testing [326 IAC 3-6]

(a) All testing shall be performed according to the provisions of 326 IAC 3-6 (Source Sampling Procedures), except as provided elsewhere in this permit, utilizing any applicable procedures and analysis methods specified in 40 CFR 51, 40 CFR 60, 40 CFR 61, 40 CFR 63, 40 CFR 75, or other procedures approved by IDEM, OAQ.

AFor performance testing required by this permit, a test protocol, except as provided

elsewhere in this permit, shall be submitted to: ******

no later than thirty-five (35) days prior to the intended test date. The protocol submitted by the Permittee does not require a certification that meets the requirements of 326 IAC 2-8-5(a)(1) by an "authorized individual" as defined by 326 IAC 2-1.1-1(1).

(b) The Permittee shall notify IDEM, OAQ of the actual test date at least fourteen (14) days

prior to the actual test date. The notification submitted by the Permittee does not require a certification that meets the requirements of 326 IAC 2-8-5(a)(1) by an "authorized individual" as defined by 326 IAC 2-1.1-1(1).

****** C.10 Compliance Monitoring [326 IAC 2-8-4(3)][326 IAC 2-8-5(a)(1)]

(a) For new units:

Unless otherwise specified in the approval for the new emission unit(s), compliance monitoring for new emission units shall be implemented on and after the date of initial start-up.

(b) For existing units:

Unless otherwise specified in this permit, for all monitoring and record keeping requirements not already legally required shall be implemented within ninety (90) days of permit issuance or ninety (90) days of initial start-up, whichever is later, the Permittee shall be allowed up to ninety (90) days from the date of permit issuance to begin such monitoring. If required by Section D, the Permittee shall be responsible for installing any necessary equipment and initiating any required monitoring related to that equipment. If due to circumstances beyond itsthe Permittee's control, thatany monitoring equipment required by this permit cannot be installed and operated withinno later than ninety (90) days after permit issuance, the Permittee may extend the compliance schedule related to the equipment for an additional ninety (90) days provided the Permittee notifies:

******

The notification which shall be submitted by the Permittee does require thea certification that meets the requirements of 326 IAC 2-8-5(a)(1) by an "authorized individual" as defined by 326 IAC 2-1.1-1(1).

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

****** C.11 Monitoring Methods [326 IAC 3] [40 CFR 60] [40 CFR 63]

Any monitoring or testing required by Section D of this permit shall be performed according to the provisions of 326 IAC 3, 40 CFR 60, Appendix A, 40 CFR 60 Appendix B, 40 CFR 63, or other approved methods as specified in this permit.

New NGC d/b/a National Gypsum Company Page 22 of 25 Clinton, Indiana TSD for FESOP SPR No. 165-35908-00081 Permit Reviewer: Brian Wright C.121 Instrument Specifications [326 IAC 2-1.1-11][326 IAC 2-8-4(3)][326 IAC 2-8-5(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. The analog instrument shall be capable of measuring values outside of the normal range.

****** C.132 Risk Management Plan [326 IAC 2-8-4][40 CFR 68] ****** C.143 Response to Excursions or Exceedances [326 IAC 2-8-4][326 IAC 2-8-5]

Upon detecting an excursion where a response step is required by the D Section or an exceedance of a limitation in this permit: (a) Upon detecting an excursion or exceedance, the The Permittee shall take reasonable

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

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

and taking any necessary corrective actions to restore normal operation and prevent the likely recurrence of the cause of an excursion or exceedance (other than those caused by excused startup or shutdown conditions). Corrective actions. The response may include, but areis 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 computerized distribution control system); or

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

designated condition, or below the applicable emission limitation or standard, as applicable normal or usual manner of operation.

****** (e) The Permittee shall record maintain the following records the reasonable response

steps taken.:

(1) monitoring data;

(2) monitor performance data, if applicable; and

(3) corrective actions taken. C.154 Actions Related to Noncompliance Demonstrated by a Stack Test [326 IAC 2-8-4][326 IAC 2-8-5]

(a) When the results of a stack test performed in conformance with Section C - Performance Testing, of this permit exceed the level specified in any condition of this permit, the Permittee shall take appropriate response actions. The Permittee shall submit a description of theseits response actions to IDEM, OAQ, within no later than thirty (30) days of receipt of the test resultsseventy-five (75) days after the date of the test. The Permittee shall take appropriate action to minimize excess emissions from the affected facility while the response actions are being implemented.


(b) A retest to demonstrate compliance shall be performed withinno later than one hundred and twenty (120) days of receipt of the original test results eighty (180) days after the date of the test. Should the Permittee demonstrate to IDEM, OAQ that retesting in one hundred twenty (120) 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.

The response action documents submitted pursuant to this condition do require the a certification that meets the requirements of 326 IAC 2-8-5(a)(1) by an "authorized individual" as defined by 326 IAC 2-1.1-1(1).

C.165 General Record Keeping Requirements [326 IAC 2-8-4(3)][326 IAC 2-8-5]

(a) Records of all required monitoring data, reports and support information required by this permit shall be retained for a period of at least five (5) years from the date of monitoring sample, measurement, report, or application. Support information includes the following, where applicable:

(AA) All calibration and maintenance records. (BB) All original strip chart recordings for continuous monitoring

instrumentation. (CC) Copies of all reports required by the FESOP.

Records of required monitoring information include the following, where applicable:

(AA) The date, place, as defined in this permit, and time of sampling or measurements.

(BB) The dates analyses were performed. (CC) The company or entity that performed the analyses. (DD) The analytical techniques or methods used. (EE) The results of such analyses. (FF) The operating conditions as existing at the time of sampling or

measurement. These records shall be physically present or electronically accessible at the source location for a minimum of three (3) years. The records may be stored elsewhere for the remaining two (2) years as long as they are available upon request. If the Commissioner makes a request for records to the Permittee, the Permittee shall furnish the records to the Commissioner within a reasonable time

(b) Unless otherwise specified in this permit, for all record keeping requirements not already

legally required, the Permittee shall be allowed up to shall be implemented within 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.176 General Reporting Requirements [326 IAC 2-8-4(3)(C)][326 IAC 2-1.1-11]

(a) The Permittee shall submit the attached Quarterly Deviation and Compliance Monitoring Report or its equivalent. Proper notice submittal under Section B –Emergency Provisions satisfies the reporting requirements of this paragraph. 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 reported pursuant to an applicable requirement that exists independent of this permit, shall be reported according to the schedule stated in the applicable requirement and does not need to be included in this report. This report shall be submitted withinnot later than thirty (30) days ofafter the end of the reporting period. The Quarterly Deviation and Compliance Monitoring Report shall include thea certification that meets the requirements of 326 IAC 2-8-5(a)(1) by an "authorized


individual" as defined by 326 IAC 2-1.1-1(1). A deviation is an exceedance of a permit limitation or a failure to comply with a requirement of the permit.

(b) The report required in (a) of this condition and reports required by conditions in Section D

of this permit shall be submitted toaddress 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

****** (d) Unless otherwise specified in this permit, all reports required in Section D of this permit

shall be submitted within thirty (30) days of the end of the reporting period. All reports do require the certification by an "authorized individual" as defined by 326 IAC 2-1.1-1(1).

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

For the purpose of this permit “calendar year” means the twelve (12) month period from January 1 to December 31 inclusive.

C.187 Compliance with 40 CFR 82 and 326 IAC 22-1

Pursuant to 40 CFR 82 (Protection of Stratospheric Ozone), Subpart F, except as provided for motor vehicle air conditioners in Subpart B, the Permittee shall comply with theapplicable standards for recycling and emissions reduction.:

(a) Persons opening appliances for maintenance, service, repair, or disposal must comply

with the required practices pursuant to 40 CFR 82.156.

(b) Equipment used during the maintenance, service, repair, or disposal of appliances must comply with the standards for recycling and recovery equipment pursuant to 40 CFR 82.158.

(c) Persons performing maintenance, service, repair, or disposal of appliances must be

certified by an approved technician certification program pursuant to 40 CFR 82.161.

Conclusion and Recommendation 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 June 5, 2015. The construction and operation of this proposed revision shall be subject to the conditions of the attached proposed FESOP Significant Permit Revision No. 165-35908-00081. The staff recommends to the Commissioner that this FESOP Significant Permit Revision be approved.

IDEM Contact (a) Questions regarding this proposed permit can be directed to Brian Wright 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) 234-6544 or toll free at 1-800-451-6027 extension 4-6544.

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

http://www.in.gov/ai/appfiles/idem-caats/

New NGC d/b/a National Gypsum Company Page 25 of 25 Clinton, Indiana TSD for FESOP SPR No. 165-35908-00081 Permit Reviewer: Brian Wright (c) For additional information about air permits and how the public and interested parties can

participate, refer to the IDEM Permit Guide on the Internet at: http://www.in.gov/idem/5881.htm; and the Citizens' Guide to IDEM on the Internet at: http://www.in.gov/idem/6900.htm.



Appendix A: Emissions Calculations TSD Appendix A: Page 1 of 4 Emission Summary

Company Name: New NGC, Inc. d/b/a National Gypsum CompanySource Address: 75 Ivy Lane, Clinton, Indiana 47842

FESOP Significant Permit Revision (SPR) No.: 165-35908-00081Reviewer: Brian Wright

Uncontrolled/Unlimited Potential to Emit (tons/year)

Emission Units PM PM10 PM2.5 SO2 NOx VOC CO Total HAPs Highest Single HAP (hexane)

Sorage Silos and Bins- U1, U2, U3, U4, U5, U6, U7, U8, U9, Sand Storage Room-U13 1,856.41 1,856.41 1,856.41 − − − − − −

Conveying/Mixing (U10) 251.54 251.54 251.54 − − − − − −Board Sawing (U11) 187.71 187.71 187.71 − − − − − −

Insignificant Activities-Boiler and Space Heaters 0.07 0.30 0.30 0.02 3.94 0.22 3.31 0.07 0.07Polystyrene Expansion, Aging, and Drying System

(U12) − − − − − 144.87 − − −

Total 2,295.74 2,295.96 2,295.96 0.02 3.94 145.09 3.31 0.07 0.07

Limited Potential to Emit (tons/year)

Emission Units PM* PM10* PM2.5* SO2 NOx VOC CO Total HAPs Highest Single HAP (hexane)

Sorage Silos and Bins- U1, U2, U3, U4, U5, U6, U7, U8, U9, Sand Storage Room-U13 18.63 18.63 18.63 − − − − − −

Conveying/Mixing (U10) 2.52 2.52 2.52 − − − − − −Board Sawing (U11) 1.88 1.88 1.88 − − − − − −

Insignificant Activities-Boiler and Space Heaters 0.07 0.30 0.30 0.02 3.94 0.22 3.31 0.07 0.07Polystyrene Expansion, Aging, and Drying System

(U12) − − − − − 52.50 − − −

Total 23.10 23.32 23.32 0.02 3.94 52.72 3.31 0.07 0.07

*Pursuant to 326 IAC 2-8-4 (FESOP) and in order render the requirements of 326 IAC 2-2 (PSD) and 326 IAC 2-7 (Part 70 Permits) not applicable, total particulate emissions from the sorage silos and bins, sand storage room, conveying/mixing operation, and board sawing shall be limited to no more than than 23.03 tons per twelve (12) month consecutive period of PM, PM10, and PM2.5.

Appendix A: Emissions Calculations TSD Appendix A: Page 2 of 4Particulate (PM/PM10/PM2.5)



Emission Unit / Description Annual Operating Hours

Operating Flow Rate (scfm)

Outlet Grain Loading (g/dscf)

Controlled PTE PM/PM10/PM2.5 Emissions (lb/hr)

Annual Material Stored (tons)

Controlled PTE PM/PM10/PM2.5

Emissions (tons/yr)

Uncontrolled PTE PM/PM10/PM2.5 Emissions (lb/hr)

Uncontrolled PTE PM/PM10/PM2.5

Emissions (tons/yr)

**PSD Minor Limited PTE

(tons/yr)U1 / Portland Cement Silo 1 8760 2747 0.02 0.47 2.06 47.09 206.26 2.06U2 / Portland Cement Silo 2 8760 2747 0.02 0.47 2.06 47.09 206.26 2.06U3 / Portland Cement Silo 3 8760 2747 0.02 0.47 2.06 47.09 206.26 2.06

U4 / Fly Ash Silo 8760 2747 0.02 0.47 25000 2.06 47.09 206.26 2.06U5 / Aluminate Silo #1 8760 2747 0.02 0.47 2.06 47.09 206.26 2.06U6 / Aluminate Silo #2 8760 2747 0.02 0.47 2.06 47.09 206.26 2.06

U7 / Portland Cement Bin 8760 2747 0.02 0.47 50000 2.06 47.09 206.26 2.06U8 / Fly Ash Bin 8760 2747 0.02 0.47 25000 2.06 47.09 206.26 2.06

U9 / Aluminate Bin 8760 2747 0.02 0.47 7800 2.06 47.09 206.26 2.06Totals 4.24 18.56 423.82 1856.34 18.56





Annual Material Mixed (tons)


Emissions (tons/yr)



Emissions (tons/yr)


(tons/yr)U10 / Conveying/Mixing 8760 3350 0.02 0.57 88200 2.52 57.43 251.54 2.52





Annual Material Sawn (sq. ft)


Emissions (tons/yr)



Emissions (tons/yr)


(tons/yr)U11 / Board Sawing 8760 2500 0.02 0.43 455520* 1.88 42.86 187.71 1.88


Operating Flow Rate (lb/hr) 1 Emission Factor


Annual Material Stored (tons)


Emissions (tons/yr)

**PSD Minor Limited PTE (tons/yr)

U13 / Sand Storage Room 8760 14,860 0.0021 0.02 65087 0.07 0.07



Emissions (tons/yr)



Emissions (tons/yr)

**PSD Minor Limited PTE (tons/yr)

Totals 524.12 2295.66 5.26 23.02 23.02

There is no emission factor for PM2.5 in AP42, PM10 = PM2.5PM-10 Emissions are equivalent to PM emissions1Emission Factors from AP 42, Chapter 11.12 Table 11.12-2, SCC #3-05-011-05,22,24* Area of the board per hour sawn is 52 sq foot. **PSD Minor Limits are taken directly from FESOP Renwal No. F165-27682-00081

MethodologyControlled PTE of PM , PM-10 Emissions (lb/hr) = Operating Flow Rate (scfm) * Grain Loading (g/dscf) * lb/7000 Grain * 60 min/hrControlled PTE of PM , PM-10 Emissions (tons/yr) = Controlled PTE of PM , PM-10 Emissions (lb/hr) * ton/2000 lbs * 8760 hrs/yr PTE of PM , PM-10 Emissions (lb/hr) = Controlled PTE of PM , PM-10 Emissions (lb/hr) / (1-efficiency), where control efficiency is equal to or greater then 99% PTE of PM , PM-10 Emissions (tons/yr) = Controlled PTE of PM , PM-10 Emissions (lb/hr) / (1-effeciency), where the control efficiency is equal to or greater then 99%

326 IAC 6-3-2 Particulate Emisssion Limitations for Manufacturing Processes

Emission Unit PTE PM before controls (lbs/hr)

Subject to 326 IAC 6-3?

Process Weight Rate (lbs/hr)

Process Weight Rate (tons/hr)

326 IAC 6-3-2 Allowable PM Limit

(lbs/hr)

PTE PM after controls (lbs/hr)

Able to Comply with326 IAC 6-3-2?

U1 / Portland Cement Silo 1 47.09 Yes, > 0.551 lbs/hr 5700 2.85 8.27 0.47 Yes, with controlU2 / Portland Cement Silo 2 47.09 Yes, > 0.551 lbs/hr 5700 2.85 8.27 0.47 Yes, with controlU3 / Portland Cement Silo 3 47.09 Yes, > 0.551 lbs/hr 4900 2.45 7.47 0.47 Yes, with controlU4 / Fly Ash Silo 47.09 Yes, > 0.551 lbs/hr 4900 2.45 7.47 0.47 Yes, with controlU5 / Aluminate Silo #1 47.09 Yes, > 0.551 lbs/hr 880 0.44 2.37 0.47 Yes, with controlU6 / Aluminate Silo #2 47.09 Yes, > 0.551 lbs/hr 880 0.44 2.37 0.47 Yes, with controlU7 / Portland Cement Bin 47.09 Yes, > 0.551 lbs/hr 11400 5.70 13.16 0.47 Yes, with controlU8 / Fly Ash Bin 47.09 Yes, > 0.551 lbs/hr 9800 4.90 11.89 0.47 Yes, with controlU9 / Aluminate Bin 47.09 Yes, > 0.551 lbs/hr 1760 0.88 3.76 0.47 Yes, with controlU10 / Conveying/Mixing 57.43 Yes, > 0.551 lbs/hr 21000 10.50 19.81 0.57 Yes, with controlU11 / Board Sawing 42.86 Yes, > 0.551 lbs/hr 21000 10.50 19.81 0.43 Yes, with controlU13 / Sand Storage Room 0.02 No, < 0.551 lbs/hr − − − − −

Methodologyprocess weight rates (tons/hour) taken directly from TSD from FESOP Renwal No. F165-27682-00081

326 IAC 6-3-2 Allowable PM Limit (lbs/hr)

Emission limitations for process weight rates up to sixty thousand pounds per hour shall be calculated with the following equation:E (lb/hr) = 4.10 P 0.67

Emission limitations for process weight rates greater than sixty thousand pounds per hour shall be calculated with the following equation:E (lb/hr) = 55.0 P 0.11 - 40

Where: E = Rate of emission in pounds per hourP = Process Weight Rate in tons per hour

When the process weight rate is less than one hundred (100) pounds per hour, the allowable rate of emission is five hundred fifty-one thousandths (0.551) pound

7800

50000

Appendix A: Emissions Calculations TSD Appendix A: Page 3 of 4One (1) Polystyrene Expansion, Aging, and Drying System



Unlimited PTE of VOC Limited PTE of VOCBatch size (lbs/batch) = 2,205Process time (hours/hour-batch) = 5.00Maximum Operating Hours (hours/year) = 8,760Maximum Throughput Rate (lbs/year) = 3,863,160 Limited Throughput Rate (tons/year) = 700VOC/Polystyrene Pentane Weight % = 7.50% VOC/Polystyrene Pentane Weight % = 7.50%Unlimited PTE of VOC/Pentane (tons/year) = 144.87 Limited PTE of VOC/Pentane (tons/year) = 52.50

Assume all VOC emissions are equal to Pentane emissionsThe Permittee operates the polystyrene expansion system in batch mode and it takes 5 hours of process time (utilizing 2,205 pounds per batch) from start of a batch to the start of the next batch.Weight % VOC per ton of Polystyrene material processed = 7.5 % based on MSDS sheet provided by the source.

METHODOLOGYUnlimited PTE of VOC:Maximum Throughput Rate (lbs/year) = Weight of Batch (lbs/batch) * 1 Batch/ 5 hours * 8760 hours/year Unlimited PTE of VOC/Pentane (tons/year) = Maximum Througput Rate (lbs/year) * Weight % VOC/Polystyrene Pentane * 1 ton/2000 lbs

Limited PTE of VOC:Limited PTE of VOC/Pentane (tons/year) = Limited Througput Rate (tons/year) * Weight % VOC/Polystyrene Pentane

Appendix A: Emissions Calculations TSD Appendix A: Page 4 of 4Natural Gas Combustion Only

Insignificant Activities-Boiler and Space Heaters MM BTU/HR <100



Total Heat Input CapacityHeat Input Capacity MMBtu/hrBoiler #1 3.188Large Space Heaters 5.28 HHVSmall Space Heaters 0.50 mmBtu Potential ThroughputWater Heater 0.20 mmscf MMCF/yrTotal 9.168 1020 78.7

Pollutant PM* PM10* direct PM2.5* SO2 NOx VOC COEmission Factor in lb/MMCF 1.9 7.6 7.6 0.6 100 5.5 84

**see belowPotential Emission in tons/yr 0.07 0.30 0.30 0.02 3.94 0.22 3.31*PM emission factor is filterable PM only. PM10 emission factor is filterable and condensable PM10 combined.PM2.5 emission factor is filterable and condensable PM2.5 combined.**Emission Factors for NOx: Uncontrolled = 100, Low NOx Burner = 50, Low NOx Burners/Flue gas recirculation = 32

MethodologyAll 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 1-03-006-03Potential Throughput (MMCF) = Heat Input Capacity (MMBtu/hr) x 8,760 hrs/yr x 1 MMCF/1,020 MMBtuEmission (tons/yr) = Throughput (MMCF/yr) x Emission Factor (lb/MMCF)/2,000 lb/ton

Hazardous Air Pollutants (HAPs)

Benzene Dichlorobenzene Formaldehyde Hexane Toluene Total - OrganicsEmission Factor in lb/MMcf 2.1E-03 1.2E-03 7.5E-02 1.8E+00 3.4E-03Potential Emission in tons/yr 8.3E-05 4.7E-05 3.0E-03 0.07 1.3E-04 0.07

Lead Cadmium Chromium Manganese Nickel Total - MetalsEmission Factor in lb/MMcf 5.0E-04 1.1E-03 1.4E-03 3.8E-04 2.1E-03Potential Emission in tons/yr 2.0E-05 4.3E-05 5.5E-05 1.5E-05 8.3E-05 2.2E-04Methodology is the same as above. Total HAPs 0.07The five highest organic and metal HAPs emission factors are provided above. Worst HAP 0.07Additional HAPs emission factors are available in AP-42, Chapter 1.4.

HAPs - Organics

HAPs - Metals

Indiana Department of Environmental Management Office of Air Quality

Appendix B

Best Available Control Technology (BACT) Analysis Determination

Technical Support Document (TSD) for a Significant Permit Revision to a Federally Enforceable State Operating Permit (FESOP) Renewal

Source Background and Description

Source Name: New NGC, Inc., d/b/a National Gypsum Company

Location: 75 Ivy Lane, Clinton, Indiana, 47842 County: Vermillion SIC Code: 3272 (Concrete Products, Except Block and Brick) Significant Permit Revision No.: 165-35908-00081 FESOP Renewal No.: F165-27682-00081 Permit Reviewer: Brian Wright

New NGC, Inc., d/b/a National Gypsum Company was issued a Federally Enforceable State Operating Permit (FESOP) Renewal No. F165-27682-00081 on July 14, 2009, for a stationary concrete backer board manufacturing facility located at 75 Ivy Lane, Clinton, Indiana, 47842. On June 5, 2015, New NGC, Inc., d/b/a National Gypsum Company submitted an application to IDEM OAQ to correct the potential to emit volatile organic compounds (VOC) from the polystyrene expansion, aging, and drying system (U12). Earlier permits for the facility made the assumption that the polystyrene beads used in the process had a maximum VOC content of 3.5 % by weight, the VOC emissions from the polystyrene were only generated during the expansion process, and that the VOC was bound (encapsulated) in the wallboard mixture during the drying process. During an inspection of the plant on 10/9/2014, IDEM OAQ determined that New NGC, Inc., d/b/a National Gypsum Company failed to maintain records of the Polystyrene beads VOC content to prove that the VOC emissions did not exceed 3.5% by weight (70 pounds of VOC per ton of polystyrene throughput), in violation of Conditions D.1.10(a)(1) and D.1.4 of the permit. The Safety Data Sheets (SDS) for the polystyrene beads used in the process indicate that the maximum VOC content the polystyrene beads can contain up to 7.5% pentane by weight. Therefore, IDEM OAQ requested that the source reevaluate the VOC emissions from the polystyrene expansion, aging and drying processes in order to verify the previous assumptions. NGC did informal testing to determine how much VOC was emitted from each of the three system processes (expansion, aging and drying). The testing revealed that there were VOC emissions from each of the three system processes (expansion, aging and drying) and that the actual VOC emissions from the entire system would exceed 25 tons per year based on a limited production of 700 tons per twelve (12) consecutive month period. As a result, a 326 IAC 8-1-6 VOC BACT analysis that evaluated the control of VOC from the entire the polystyrene expansion, aging, and drying system (U12) was submitted by New NGC, Inc., d/b/a National Gypsum Company. At the request of IDEM OAQ (on September 28, 2015), New NGC, Inc., d/b/a National Gypsum Company submitted a revised BACT analysis on January 19, 2016, that evaluated an additional control technology scenario for building a permanent enclosure around just the polystyrene expansion and aging processes, and controlling emissions from the enclosure. A BACT analysis is required under the provisions of 326 IAC 8-1-6 (Best Available Control Technology (BACT)) for the following process because the potential emissions are equal to or greater than twenty-five (25) tons per year of VOC:

New NGC Inc. d/b/a National Gypsum Company Page 2 of 14 Clinton, Indiana TSD Appendix B for FESOP SPR No. 165-35908-00081 Permit Reviewer: Brian Wright One (1) Polystyrene Expansion, Aging, and Drying System operating in batch mode, identified as U12, constructed in 2005 with a maximum capacity of 2,205 lbs of polystyrene beads per batch and a batch time of 5 hours, exhausting to stack identified as S11 with no control.

Polystyrene Expansion Process The backer board manufacturing process uses a variety of raw materials including portland cement, fly ash, plastics and other chemical additives. One of the raw material additives is polystyrene plastic beads, which, according to the Safety Data Sheets (SDS), can contain up to 7.5% by weight pentane. The raw beads arrive in 2203 pound bags that are opened on an unloading stand at the front of the expander. The beads go through a two-pass expansion process where the expanded beads are loaded into several large storage bags. The bags with the expanded beads are taken to a designated area in the facility for aging, where they are stored between 12 hours and 3 days. The expanded and aged polystyrene beads are fed into a mixer with other raw materials and water to form cement slurry that is applied to a moving process belt or conveyor. The cement mix is formed, vibrated and smoothed before going to the drying oven. The drying oven is 340 feet long with a break in the middle. The oven has a total of 16 “zones”, each with an individual 2.6 brake horsepower (bHP) blower that circulates steam-heated hot air to dry the concrete board. The maximum temperature in the ovens is 185 °F. The dried board is conveyed to the board end sawing area and is trimmed and bundled for shipment. The board pallets are covered with a shrink wrap bag and placed in the warehouse. Emissions Estimates This section provides emissions estimates from the polystyrene expansion, aging and drying processes at the facility. According to the SDS, the polystyrene beads used in the process have maximum VOC content of 7.5% by weight. This is comprised entirely of pentane. NGC did informal testing to determine how much VOC was emitted from each of the three system processes (expansion, aging and drying). The results of the testing indicate that approximately 53% of the pentane is released during the combined expansion and aging processes. The informal testing also indicated that a residual amount of VOC (approximately 0.5%) remained in the polystyrene after drying of the concreate board. However, in efforts to be conservative, it was assumed that 47% (all of the remaining VOC) was emitted during the drying process. These testing results were used to develop annual and hourly emissions estimates. The emissions were grouped into two process stages to mimic the testing results:

• Polystyrene bead expansion and aging; and

• Drying in the oven.

Limited annual emissions were based on a limited production of 700 tons per twelve (12) consecutive month period of polystyrene beads. Maximum hourly emissions from the polystyrene expansion and aging were based upon the duration of a batch. Maximum hourly emissions from drying were based upon the application rate of the polystyrene beads in the concrete board. Table 1 summarizes the emissions estimates for the process. Supporting calculations are provided in Appendix A.

New NGC Inc. d/b/a National Gypsum Company Page 3 of 14 Clinton, Indiana TSD Appendix B for FESOP SPR No. 165-35908-00081 Permit Reviewer: Brian Wright

Table 1 – Emissions Estimates from Polystyrene Beads

Emission Source % of VOC releasedA tons/yearB lbs/hour

Expansion 53% 27.6 17.4C

Aging

Drying 47% 24.9 8.29D

Total 100% 52.5 25.7

A. Based on informal testing results and assuming that all of the VOC in polystyrene beads are released during manufacturing.

B. Assumes a maximum VOC content of 7.5%by weight in polystyrene beads and an annual throughput of 700 tons.

C. Assumes that the bulk of the emissions occur during the batch expansion process which has a 5 hour duration.

D. Assumes a polystyrene bead application rate of 233 lb/hr.

Summary of the Best Available Control Technology (BACT) Process

BACT is an emissions limitation based on the maximum degree of pollution reduction of emissions, which is achievable on a case-by-case basis. BACT analysis takes into account the energy, environmental, and economic impacts on the source. These reductions may be determined through the application of available control techniques, process design, work practices, and operational limitations. Such reductions are necessary to demonstrate that the emissions remaining after application of BACT will not cause or contribute significantly to air pollution, thereby protecting public health and the environment. Federal guidance on BACT requires an evaluation that follows a “top down” process. In this approach, the applicant identifies the best-controlled similar source on the basis of controls required by regulation or permit, or controls achieved in practice. The highest level of control is then evaluated for technical feasibility. The five (5) basic steps of a top-down BACT analysis are listed below: Step 1: Identify Potential Control Options The first step is to identify potentially “available” control options for each emission unit and for each pollutant under review. Available options should consist of a comprehensive list of those technologies with a potentially practical application to the emissions unit in question. The list should include lowest achievable emission rate (LAER) technologies, innovative technologies, and controls applied to similar source categories. Step 2: Eliminate Technically Infeasible Options The second step is to eliminate technically infeasible options from further consideration. To be considered feasible, a technology must be both available and applicable. It is important in this step that any presentation of a technical argument for eliminating a technology from further consideration be clearly documented based on physical, chemical, engineering, and source-specific factors related to safe and successful use of the controls. Innovative control means a control that has not been demonstrated in a commercial application on similar units. Innovative controls are normally given a waiver from the BACT requirements due to the uncertainty of actual control efficiency. A control technology is considered available when there are sufficient data indicating that the technology results in a reduction in emissions of regulated pollutants.

New NGC Inc. d/b/a National Gypsum Company Page 4 of 14 Clinton, Indiana TSD Appendix B for FESOP SPR No. 165-35908-00081 Permit Reviewer: Brian Wright Step 3: Rank the Remaining Control Technologies by Control Effectiveness The third step is to rank the technologies not eliminated in Step 2 in order of descending control effectiveness for each pollutant of concern. The ranked alternatives are reviewed in terms of environmental, energy, and economic impacts specific to the proposed modification. If the analysis determines that the evaluated alternative is not appropriate as BACT due to any of the impacts, then the next most effective is evaluated. This process is repeated until a control alternative is chosen as BACT. If the highest ranked technology is proposed as BACT, it is not necessary to perform any further technical or economic evaluation, except for the environmental analyses. Step 4: Evaluate the Most Effective Controls and Document the Results The fourth step entails an evaluation of energy, environmental, and economic impacts for determining a final level of control. The evaluation begins with the most stringent control option and continues until a technology under consideration cannot be eliminated based on adverse energy, environmental, or economic impacts. For the technologies determined to be feasible, there may be several different limits that have been set as BACT for the same control technology. The permitting agency has to choose the most stringent limit as BACT unless the applicant demonstrates in a convincing manner why that limit is not feasible. BACT must, at a minimum, be no less stringent than the level of control required by any applicable New Source Performance Standard (NSPS) and National Emissions Standard for Hazardous Air Pollutants (NESHAP) or state regulatory standards applicable to the emission units included in the permits. Step 5: Select BACT The Indiana Department of Environmental Management (IDEM) Office of Air Quality (OAQ) makes final BACT determinations by following the five steps identified above

Volatile Organic Compounds (VOC) BACT Step 1 – Identify Potential Control Options The volatile organic compounds (VOC) emissions can be controlled by the following emission control systems: (1) Destruction Processes; (2) Reclamation Processes; and/or (3) Combination of Reclamation and Destruction Technologies. Destruction technologies reduce VOC concentration by high temperature oxidation into carbon dioxide and water vapor. Reclamation is the capture of VOCs for reuse or disposal. A further description of these types of control technologies follows: Destruction Control Methods The destruction of organic compounds usually requires temperatures ranging from 1,200oF to 2,000oF for direct thermal incinerators or 600oF to 1,200oF for catalytic systems. Combustion temperature depends on the chemical composition and the desired destruction efficiency. Carbon dioxide and water vapor are the typical products of complete combustion. Turbulent mixing and combustion chamber retention times of 0.5 to 1.0 seconds are needed to obtain high destruction efficiencies. Control technologies include direct incineration, recuperative thermal incineration, regenerative thermal incineration, recuperative catalytic incineration, regenerative catalytic incineration, and flares.

New NGC Inc. d/b/a National Gypsum Company Page 5 of 14 Clinton, Indiana TSD Appendix B for FESOP SPR No. 165-35908-00081 Permit Reviewer: Brian Wright Direct Incineration: Direct incineration is the most simple and direct form of incineration. It involves burning the VOC-laden fumes directly in a combustion chamber without reheating or post-combustion heat recover. Direct incineration typically requires supplemental fuel. Concentrated VOC streams with high heat contents obviously require less supplementary fuel than more dilute streams. VOC streams sometimes have a heat content high enough to be self-sustaining, but a supplemental fuel firing rate equal to about 5% of the total incinerator heat input is usually needed to stabilize the burner flame. Natural gas is the most common fuel for VOC incinerators, but fuel oil is an option in some circumstances. Recuperative Thermal Oxidation: Recuperative thermal incinerators are add-on control devices used to control VOC emissions by introducing solvent-laden fumes to the oxidizer. The stream is pre-heated by exiting flue gas from the same system in a heat exchanger or recuperator, a burner then heats the air to the required temperature. The air is then passed through an oxidation chamber where the solvent-laden air is converted to carbon dioxide and water. These are then passed through the heat exchanger where incoming fume is preheated by the heat of the exiting flue gas. Finally the clean flue gas is discharged to the atmosphere. The recuperative thermal oxidizer is appropriate for waste streams with a relatively high solvent content and/or consistent pollutant loading. Variation in pollutant loading will require a longer retention time in the oxidizer in order to properly destroy VOC emissions. Regenerative Thermal Oxidation: Regenerative thermal oxidizers (RTOs) are add-on control devices used to control VOC emissions by simple reaction of the harmful air pollutants with oxygen and heat. An RTO uses a direct contact heat exchanger. These direct contact heat exchangers consist of a bed of porous ceramic packing or other structured, high heat capacity media. These systems can handle variable and low concentration VOC waste streams. The inlet gas first passes through a hot ceramic bed thereby heating the stream (and cooling the bed) to its ignition temperature. The hot gases then react (releasing energy) in the combustion chamber and while passing through another ceramic bed, thereby heating it to the combustion chamber outlet temperature. The process flows are then switched, now feeding the inlet stream to the hot bed. This cyclic process affords very high energy recovery (up to 95%). The higher capital costs associated with these high performance heat exchangers and combustion chambers may be offset by the increased auxiliary fuel savings to make such a system economical. Recuperative and Regenerative Catalytic Oxidation: Catalytic incinerators are add-on control devices used to control VOC emissions by using a bed of catalyst that facilitates the oxidation of the combustible gases. The catalyst increases the reaction rate and allows the conversion of VOC at lower temperatures than thermal incinerators. Catalytic oxidation can be used for low-concentration VOC waste streams; however, certain compounds present in waste stream gas may foul the catalyst. It may also be necessary to remove particulate prior to catalytic oxidation as well. Flares: Flaring is used to control VOC emissions by piping VOCs to a remote, usually elevated location and burning them in an open flame in the open air using a specially designed burner tip, auxiliary fuel, and steam or air to promote mixing for nearly complete (> 98%) VOC destruction. While flares are designed to eliminate waste gas streams, they can cause safety and operational problems and the waste gas stream concentration must be high enough to sustain combustion. Reclamation Control Methods Organic compounds may be reclaimed by one of three possible methods; adsorption, absorption (scrubbing) or condensation. In general, the organic compounds are separated from the emission stream and reclaimed for reuse or disposal. Depending on the nature of the contaminant and the inlet concentration of the emission stream, recovery technologies can reach efficiencies of 98%. Adsorption: Adsorption is a surface phenomenon where attraction between activated carbon and VOC molecules binds the pollutants to the carbon surface. Both the activated carbon and VOC are chemically intact after adsorption. The VOCs may be removed, or desorbed, from the carbon bed reclaimed and destroyed. Adsorption can be used for relatively low VOC waste gas streams. Pollutants present in the gas streams can reduce adsorber efficiency, increase pressure drop and eventually plug the bed.

New NGC Inc. d/b/a National Gypsum Company Page 6 of 14 Clinton, Indiana TSD Appendix B for FESOP SPR No. 165-35908-00081 Permit Reviewer: Brian Wright Adsorption processes can be used to capture VOCs in low concentration waste gas streams; however, it is typically only used for a waste gas stream that does not contain other pollutants that can plug the bed. Absorption (Scrubber): Absorption is a unit operation where components of a gas phase mixture are selectively transferred to a relatively nonvolatile liquid, usually water. Sometimes, organic liquids, such as mineral oil or nonvolatile hydrocarbons, are suitable absorption solvents. The choice of solvent depends on cost and solubility of the pollutant in the solvent. Absorption is commonly used to recover products or purify gas streams that have high concentrations of organic compounds. Absorption processes are typically used to recover products or purify gas streams with high concentrations of organic compounds such as in the ethanol production and soybean oil refinery industries. Condensation: Condensation is the separation of VOCs from an emission stream through a phase change, by increasing the system pressure or, more commonly, lowering the system temperature below the dew point of the VOC vapor. When condensers are used for air pollution control, they usually operate at the pressure of the emission stream, and typically require a refrigeration unit to obtain the temperature necessary to condense the VOCs from the emission stream. These systems are frequently used prior to other control devices (e.g., oxidizers or absorbers) to remove components that may be corrosive or damaging to other parts of the system. Refrigerated condensers are used as air pollution control devices for treating emission streams with high VOC concentrations (usually > 5,000 ppmv). Condensers may be used to control VOC emissions with high VOC concentrations (usually greater than 5,000 ppmv). Concentration: VOC concentrators are not control devices in and of themselves. Instead, these devices concentrate VOC in high volume, low concentration streams prior to directing them to a control device, thereby reducing capital and operating costs associated with the control device. Concentrators use temperature swing adsorption where the VOCs are adsorbed from the high volume stream onto the concentrator media (e.g., zeolite) at close to ambient temperatures. The VOC are then desorbed from the media to a low volume air stream at high temperatures. This low volume, concentrated stream is then directed to the final control device. Combinations of Reclamation and Destruction Control Methods In some cases, a combination of control technologies offers the most efficient and cost effective VOC control. The combination of carbon adsorption with recuperative thermal incineration is available commercially. This system concentrates the VOC stream by using carbon adsorption to remove low concentration VOCs in an emission stream and then uses a lower volume of hot air, commonly one-tenth the original flow, to desorb the pollutants. A recuperative incinerator for destroying pollutants in the concentrated stream is much smaller and has lower supplemental fuel requirement than an incinerator sized for the full emission stream volume. Absorption systems can also be used to concentrate emission streams to reduce the size of destruction equipment. The concentration effect is not as extreme as with carbon adsorption, a concentrated waste gas stream one quarter the volume of the inlet stream seems to be the practical limit. Absorption concentrators are typically suited for batch processes or to equalize pollutant concentrations in a variable stream. The physical characteristics that drive the absorption of pollutants into a liquid also limit the opportunity to remove those pollutants from the liquid stream. Fume incinerators typically need supplemental fuel. Concentrated VOC streams with high heat contents require less supplementary fuel than more dilute streams. VOC streams sometimes have a heat content high enough to be self-sustaining, but a supplemental fuel firing rate equal to about 5% of the total incinerator heat input is usually needed to stabilize the burner flame. Natural gas is the most common fuel for VOC incinerators, but fuel oil is an option in some circumstances.

New NGC Inc. d/b/a National Gypsum Company Page 7 of 14 Clinton, Indiana TSD Appendix B for FESOP SPR No. 165-35908-00081 Permit Reviewer: Brian Wright Step 2: Eliminate Technically Infeasible Options

Table 2. VOC BACT Control Technology Feasibility Analysis

Technology BACT Evaluation Direct

Incineration Technically

Feasible – No

Based on the information reviewed for this BACT determination, IDEM, OAQ has determined that the use of direct incineration is not a technically feasible option for the polystyrene expansion, aging, and drying system at this source because direct incineration typically needs VOC inlet concentrations of at least 1500 to 3000 ppm to perform acceptably without requiring significant quantities of supplemental fuel to sustain temperatures.

Recuperative Thermal Oxidation

Technically Feasible – Yes

Recuperative Thermal Oxidation is technically feasible to control the VOC emissions from the polystyrene expansion, aging, and drying system.

Regenerative Thermal

Oxidation (RTO) Technically

Feasible – Yes

Regenerative Thermal Oxidation (RTO) is technically feasible to control the VOC emissions from the polystyrene expansion, aging, and drying system.

Recuperative and

Regenerative Catalytic Oxidation

Technically Feasible – Yes

Recuperative and Regenerative Catalytic Oxidation is technically feasible to control the VOC emissions from the polystyrene expansion, aging, and drying system.

Flares Technically

Feasible – No

While flares are designed to eliminate waste gas streams, they can cause safety and operational problems and the waste gas stream concentration must be high enough to sustain combustion. The VOC concentration from the polystyrene expansion, aging, and drying system is too low to sustain usage of a flare. Because the waste gas stream contains virtually no BTU content (0.0317 BTU/scf VOC average provided by the source), the 300 BTU/scf design value specified by EPA requirements would need to be met entirely by supplemental fuel. Based on this, as well as the safety issues associated with flares, IDEM, OAQ has determined that flaring is not a technically feasible option for the polystyrene expansion, aging, and drying system at this source.

Adsorption Technically

Feasible – Yes

Adsorption is technically feasible to control the VOC emissions from the polystyrene expansion, aging, and drying system, since pentane has a relatively intermediate (neither low nor high) molecular weight (72.15 g/mol), which makes it suitable for adsorption onto activated carbon.

Absorption Technically

Feasible – No

Based on the information reviewed for this BACT determination, IDEM, OAQ has determined that the use of gas absorption (scrubber) is not a technically feasible option for the polystyrene expansion, aging, and drying system at this source because pentane is not soluble in water.

Condensation Technically

Feasible - No

Based on the information reviewed for this BACT determination, IDEM, OAQ has determined that the use of condensation is not a technically feasible option for the polystyrene expansion, aging, and drying system at this source because condensation is not effective with relatively dilute waste streams. A low control efficiency would be expected given the VOC concentration of the waste stream at the site. The control efficiency could be improved with the installation of a cryogenic system to aid condensation, but this would result in a substantial increase in cost.


Table 2. VOC BACT Control Technology Feasibility Analysis

Technology BACT Evaluation Concentrator Technically Feasible:

Scenario 1 - No Scenario 2 - Yes

Scenario 1: Based on the information reviewed for this BACT determination, IDEM, OAQ has determined that the use of zeolite concentrator is not a technically feasible for control of VOC from the entire polystyrene expansion, aging, and drying system as described in Scenario 1 below, since the waste gas temperature is approximately 170 degrees Fahrenheit due to the high temperature of the curing oven exhaust. Zeolite concentrators do not operate efficiently if the waste gas temperature is greater than 120 degrees Fahrenheit. Scenario 2: Based on the information reviewed for this BACT determination, IDEM, OAQ has determined that the use of zeolite concentrator is technically feasible for control of VOC from just the polystyrene expansion and aging processes as described in Scenario 2 below. Under Scenario 2, the concentrator would only process waste gas from a permanent enclosure around the polystyrene expansion and aging processes, resulting in a significantly lower temperature exhaust as compared to Scenario 1 that also includes the exhaust from the curing oven.

Throughput Limit Technically

Feasible - Yes

Limiting the raw material throughput for the polystyrene expansion, aging, and drying system is a feasible option to reduce VOC emissions.

Step 3: Rank the Remaining Control Technologies by Control Effectiveness As shown in Steps 1 and 2, a recuperative thermal oxidizer, regenerative thermal oxidizer (RTO), catalytic oxidizer, a carbon adsorption system (CAS), and a concentrator (for Scenario 2 only) were determined to be the only add on controls that are technically feasible for the control of a pentane-laden waste gas stream. A throughput limit on the polystyrene beads is also technically feasible in reducing pentane emissions. The remaining control options are in order of descending control effectiveness: (a) Recuperative Thermal Oxidizer: 98% (b) Catalytic Oxidizer: 98% (c) Regenerative Thermal Oxidizer: 98% (d) Regenerative Thermal Oxidizer w/ Zeolite Concentrator: 98% (e) Carbon Adsorption Scenario 1: 98% (f) Carbon Adsorption Scenario 2: 98% IDEM is aware that that the above control technologies may be able to periodically achieve control efficiencies higher than indicated in the table above under certain operating conditions. However, BACT must be achievable on a consistent basis under normal operational conditions. BACT limitations do not necessarily reflect the highest possible control efficiency achievable by the technology on which the emission limitation is based. The permitting authority has the discretion to base the emission limitation on a control efficiency that is somewhat lower than the optimal level. There are several reasons why the permitting authority might choose to do this. One reason is that the control efficiency achievable through the use of the technology may fluctuate, so that it would not always achieve its optimal control efficiency. In that case, setting the emission limitation to reflect the highest control efficiency would make violations

New NGC Inc. d/b/a National Gypsum Company Page 9 of 14 Clinton, Indiana TSD Appendix B for FESOP SPR No. 165-35908-00081 Permit Reviewer: Brian Wright of the permit unavoidable. To account for this possibility, a permitting authority must be allowed a certain degree of discretion to set the emission limitation at a level that does not necessarily reflect the highest possible control efficiency, but will allow the Permittee to achieve compliance consistently.

Step 4 – Evaluate the Most Effective Controls and Document the Results In determining the economic feasibility of controlling the VOC emissions from the polystyrene expansion, aging, and drying system, guidance provided in the USEPA reference, “OAQPS Control Cost Manual”, Sixth Edition, EPA 452/B-02-001 (January, 2002) was utilized. The economic feasibility is generally expressed in terms of annualized dollars per ton of pollutant removed. By definition, cost effectiveness is the ratio of the total annualized cost of any control alternative to the annual quantity of pollutant the control alternative removes from the process. Capital Recovery Factor was based on the default annual interest rate of 7% mandated by the Office of Management and Budget (OMB). Detailed cost analyses were provided by the source and reviewed by IDEM OAQ (See TSD Appendix C and TSD Appendix D). The cost analyses were performed for the following scenarios for the capture and control of the pentane-laden waste gas stream from the polystyrene expansion, aging, and drying system: SCENARIO 1 - Control of the Entire Polystyrene Expansion, Aging, And Drying System The following table summarizes the costs of the technically feasible add-on control devices for controlling VOC emissions from the entire polystyrene expansion, aging, and drying system (see TSD Appendix C for detailed cost analyses for Scenario 1). Under this scenario, VOC emissions from the polystyrene expansion, aging, and drying system operations would be collected and combined into a single waste gas stream and controlled by a single control device.

Table 3. Cost Analysis Summary for Control of the Entire Polystyrene Expansion, Aging, And Drying System

Parameter

Recuperative Thermal Oxidizer

Catalytic Oxidizer

Regenerative Thermal Oxidizer

Carbon Adsorption

with On-Site Regeneration

Total Annual Cost ($/year) $6,957,071 $4,353,196 $2,014,708 $912,153 Control Efficiency of Equipment 98% 98% 98% 98% VOC Controlled (tons/year) 51.45 51.45 51.45 51.45 Cost Effectiveness ($ per ton controlled) $135,220 $84,610 $39,159 $17,729 Cost Effective? (Yes/No) No No No No

Based on the cost analysis summary presented in the table above, capture and control of the VOC emissions from the entire polystyrene expansion, aging, and drying system is considered impractical and not cost effective (i.e., cost prohibitive) for the recuperative thermal oxidizer, the catalytic oxidizer, the regenerative thermal oxidizer, and the carbon adsorption system, since it would require installation of a control device capable of capturing and controlling a large volume of VOC-laden air with low VOC concentration SCENARIO 2 - Control of the Polystyrene Expansion and Aging Processes The following table summarizes the costs of the technically feasible add-on control devices for controlling VOC emissions from just the polystyrene expansion and aging processes using a permanent enclosure around just the polystyrene expansion and aging processes (see TSD Appendix D for detailed cost analyses for Scenario 2). Under this scenario, a permanent enclosure would be constructed around the

New NGC Inc. d/b/a National Gypsum Company Page 10 of 14 Clinton, Indiana TSD Appendix B for FESOP SPR No. 165-35908-00081 Permit Reviewer: Brian Wright polystyrene expansion and aging processes and the combined VOC emissions from these operations would be collected a single waste gas stream and controlled by a control device(s). Under this scenario, the waste gas stream would have a significantly lower temperature as compared to Scenario 1, since this scenario will not include the exhaust from the curing oven. The cost of construction of the permanent enclosure is included in each of the cost analyses under this scenario. This scenario also includes a cost analysis for the use of a RTO with a zeolite concentrator. Due to a lower exhaust temperature, the concentrator is technically feasible under Scenario 2 but not Scenario 1.

Table 4. Cost Analysis Summary for Control of the Polystyrene Expansion and Aging Processes

Parameter

Recuperative Thermal Oxidizer

Catalytic Oxidizer

RTO w/rotary zeolite

concentrator Regenerative

Thermal Oxidizer

Carbon Adsorption

with On-Site Regeneration

Total Annual Cost ($/year) $1,046,423 $675,515 $267,873 $428,933 $382,258 Control Efficiency of Equipment 98% 98% 98% 98% 98% VOC Controlled (tons/year) 27.04 27.04 27.04 27.04 27.04 Cost Effectiveness ($ per ton controlled) $38,693 $24,978 $9,905 $15,861 $14,135 Cost Effective? (Yes/No) No No No No No

Based on the cost analysis summary presented in the table above, capture and control of the VOC emissions from the entire polystyrene expansion, aging, and drying system is considered impractical and not cost effective (i.e., cost prohibitive) for the recuperative thermal oxidizer, the catalytic oxidizer, the regenerative thermal oxidizer, the RTO w/rotary zeolite concentrator, and the carbon adsorption system. A review of EPA’s RACT/BACT/LAER Clearinghouse (RBLC) and Indiana Air Permits identified the following previous BACT determinations for sources that operate under process type codes 99.014 (Polystyrene Foam Products Manufacturing), 99.999 (Other Miscellaneous Sources), 49.011 (Consumer Products), 49.999 (Other Organic Evaporative Loss Sources), 63.031 (Polystyrene Production), and 90.012 - Concrete Batch Plants.

Plant/ Facility Description

RBLC ID or Permit #

Date Issued and State Emission Unit VOC Control Technology/VOC Emissions

Limit

Basis of Limit

or Control

New NGC Inc. d/b/a National Gypsum Company Concrete backer board manufacturing facility

FESOP SPR No. 165-35908-00081

Proposed Indiana

polystyrene expansion and aging processes

(1) VOC content of polystyrene beads shall

not exceed 7.5% by weight. (2) The total throughput of polystyrene

beads shall not exceed 700 tons per twelve (12) month consecutive period.

State BACT

Genpak, LLC Expandable Polystyrene (EPS) manufacturing

SSM No. 143-35401-00016

7/6/2015 Indiana

Food trays production line

When butane is used as blowing agent: (1) The butane blowing agent input to the

three (3) polystyrene foam extrusion operations (EPS-1, EPS-2, and EPS-3) shall be limited to 677.44 tons per 12 month consecutive period, with compliance determined at the end of each month.

(2) The combined uncontrolled VOC

emissions from the polystyrene foam extrusion operation identified as EPS-1, including extrusion, roll storage, and

State BACT



RBLC ID or Permit #


Limit

Basis of Limit

or Control

thermoforming shall not exceed 1.70 pounds of VOC per hour.


emissions from the polystyrene foam extrusion operation identified as EPS-2, including extrusion, roll storage, and thermoforming shall not exceed 1.70 pounds of VOC per hour.


emissions from the polystyrene foam extrusion operation identified as EPS-3, including extrusion, roll storage, and thermoforming shall not exceed 1.70 pounds of VOC per hour.


emissions from the fluff silos shall not exceed 25.62 pounds of VOC per hour.

(6) The controlled VOC emissions from the

repelletizer shall not exceed 0.64 pounds of VOC per hour.

(7) The VOC emissions from the polystyrene

foam scrap repelletizer (Repel-1), shall be controlled by the 1.0 MMBtu/hr RTO. The RTO shall have a minimum destruction efficiency of 98%.

(8) The capture system for the repelletizer

(Repel-1) shall utilize a permanent total enclosure to ensure 100% capture of VOC emissions.

(9) No control for the extruders, roll storage,

thermoformers, or fluff silos. ============================== When processing scrap foam made from butane and isopentane at the same time: (1) The controlled VOC emissions from the

repelletizer shall not exceed 0.64 pounds of VOC per hour.

(2) The VOC emissions from the polystyrene

foam scrap repelletizer (Repel-1), shall be controlled by the 1.0 MMBtu/hr RTO. The RTO shall have a minimum destruction efficiency of 98%.

(3) The capture system for the repelletizer

(Repel-1) shall utilize permanent total enclosure to ensure 100% capture of VOC emissions.

(4) No control for the extruders, roll storage,



RBLC ID or Permit #


Limit

Basis of Limit

or Control

thermoformers, or fluff silos. Fagerdala Packaging Inc. (Indiana) Polyethylene extruded foam manufacturing plant

063-34203-00071

06/12/2014 Indiana

Polyethylene sheet foam extruder and temporary storage area (SFE-01)

Permanent total enclosure and RTO Overall Control Efficiency - 98% Input of blowing agent (isobutane) shall not exceed 241.4 tons per year. 4.83 tons of VOC per year after control

State BACT

EFP, LLC Polystyrene foam products manufacturing source

039-29482-00099

12/17/2010 Indiana

EPS Pre-Expander

Average VOC content of EPS beads shall not exceed 6.0%. VOC content of EPE beads shall not exceed 12% Source shall continue to search for material with lower VOC content

State BACT

Genpak, LLC Expandable Polystyrene (EPS) cups molding

SSM No. 143-25032-00016

12/5/2007 Indiana

Food trays production line

When isopentane is used as blowing agent: Boiler or RTO Capture system Efficiency - 85% Destruction Efficiency - 95% Blowing agent (isopentane) usage shall be limited to 906.66 tons per twelve (12) month consecutive period.

State BACT

Dart Container Corporation Foam (expandable polystyrene) container manufacturing

MI-0384 03/08/2007 Michigan

EUCUP: Production of Foam Containers

Three (3) Steam Boilers for control of pentane from pre-expansion system Capture Efficiency - 30% Destruction Efficiency - 95% 75.33 pounds of VOC per hour 219.95 tons of VOC per year

LAER, State BACT

Dart Container Corporation EPS container manufacturing using steam pre-expander and steam chest molding processes

MS-0085 01/31/2007 Mississippi

Cup Manufacturing Process

Boiler for control of pentane emissions Destruction Efficiency - 95% 495 tons of VOC per year

PSD BACT

JELD-WEN Insulated fiberglass and steel door manufacturing facility.

113-22426-00047

04/21/2006 Indiana

Expandable polystyrene block molding operation

VOC capture by two (2) permanent total enclosures; VOC destruction by one (1) RTO, except in the months of November, December, January, February, and March when not actively molding polystyrene bead. Overall control efficiency of 78% is required

State BACT



RBLC ID or Permit #


Limit

Basis of Limit

or Control

Dart Container Corporation Expandable Polystyrene (EPS) cups and containers molding

KY-0080 04/26/2001 Kentucky

Foam Extrusion Lines

RTO Capture Efficiency - 100% Destruction Efficiency - 95% 1.45 tons of VOC per day 523.60 tons of VOC per year

State BACT

Polystyrene Container Manufacturing

Capture Hood and Boiler 203 tons of VOC per year

State BACT

Dart Container Corporation Expandable Polystyrene (EPS) cups

PA-0210 12/14/2001 Pennsylvania

EPS Container Manufacturer

Boiler Destruction Efficiency - 95% 313.97 tons of VOC per year for total facility

State BACT

Dart Container Corporation Expandable Polystyrene (EPS) cups and containers molding

PA-0210 12/14/2001 Pennsylvania

Polystyrene Extrusion

Boiler for pentane emissions Destruction Efficiency - 95% 3.67 lbs of pentane per 100 lbs of EPS 314 tons of VOC per year

LAER

Cryovac Rigid Packaging, Sealed Air Corporation Plastic extrusion and thermoforming facility producing polystyrene extruded foam products

CP 097-5348-00093

11/4/1997 Indiana

Reclaim Extruders

Flash Incinerator Destruction Efficiency - 90% Resin usage shall be limited to 28,546 tons of resin per year. Blowing agent limited to 1,316 tons per year. Equivalent to 805.3 tons of VOC per year after control.

PSD and State BACT

Tegrant Diversified Brands, Inc.

CP 091-4823-00079

03/29/1996 Indiana

Expandable polystyrene molding process

No controls required; Use of material with lowest-available pentane content required plus ongoing research and movement to materials with lower pentane/VOC content

State BACT

091-7666-00079

10/14/1999 Indiana

Pre-expanders

No controls required; Maximum average VOC (pentane) content of materials is 5.5%; Ongoing research for lowest VOC-containing materials and alternates required

091-14438-00079

11/02/2001 Indiana

Four (4) molding presses

No controls required; VOC usage limited to 155.22 tons/year; Molding compound shall not exceed 5.5% VOC (pentane) content; Ongoing research for lowest VOC-containing materials and alternates required

Dartco of Texas TX-0394 05/21/2001 Texas

ESP Mfg. Building

No add on controls 115 lbs of pentane per hour

PSD BACT



RBLC ID or Permit #


Limit

Basis of Limit

or Control

436 tons of pentane per year 0.22 lbs of VOC per hour 0.50 tons of VOC per year

Dart Container Corporation Expandable Polystyrene (EPS) cups

Mi-0273 10/13/2000 Michigan

Expandable Polystyrene Molding (Pre-Expansion, Storage, And Molding)

No Controls Required; Pentane Limit Of 5.75 Lb/ 100 Lb Of Beads 37.0 Lb/Hr Amount Of Blowing Agent Is Limited To 7% Weight Of Bead. Approximately 15% Retained In Shipped Product. Additional Limit: 82 tons/year

State BACT

Tenneco Packaging AVI Packaging sheets and plank foam

CP 099-9807-00028

10/29/1998 Indiana

Foam scrap lines

RTO Capture system - 98% Destruction Efficiency - 95%

State BACT

Based on the summary table above, no RBLC facilities were found that use polystyrene in wall board. Other facilities were found that use expanding polystyrene beads as raw material, but they use different production processes. These facilities utilized either destruction through RTO or onsite boiler or throughput limits in order to reduce VOC emissions. The construction of a permanent enclosure in order to improve capture of emissions from the polystyrene was utilized at multiple sites. The most stringent BACTs identified in the table above are the following:

• The use of permanent total enclosure with 100% capture and RTO with 98% destruction from Fagerdala Packaging Inc., Indiana, controlling for VOCs generated from the use of butane as the blowing agent in the EPS extrusion process.

• The use of permanent total enclosure with 100% capture and RTO with 98% destruction from Genpak, LLC, Indiana, controlling for VOC emissions from the polystyrene foam scrap repelletizer (Repel-1).

Based on these technical and cost analyses, the most stringent BACT for VOC emissions from the polystyrene expansion, aging, and drying system that is technically feasible and cost effective (and not cost prohibitive) is the use of a VOC content limit and polystyrene bead throughput limit to reduce VOC input. Step 5 – Select BACT Pursuant to 326 IAC 8-1-6, (New Facilities; General Reduction Requirements) and Significant Permit Revision No. 165-35908-00081, the Permittee shall control VOC emissions from the polystyrene expansion, aging, and drying system (U12) using Best Available Control Technology (BACT), which has been determined to be the following: (a) VOC content of polystyrene beads shall not exceed 7.5% by weight. (b) The total throughput of polystyrene beads shall not exceed 700 tons per twelve (12) month

consecutive period.

New NGC, Inc. d/b/a National Gypsum CompanySPR 165-35908-00081

TSD Appendix C Page 1 of 14

Indiana Department of Environmental ManagementOffice of Air Quality

Appendix C Best Available Control Technology (BACT) Analysis

SCENARIO 1 - Control of the Entire Polystyrene Expansion, Aging, And Drying System






Process Summary 8/30/2016

Polystyrene Expansion Process

Summary of Emissions Summary of Pentane Test ResultsNOTES

Maximum Annual Throuput 700 tons permit limit each averageBatch Size 2,205 lbs from permit Raw Bead (1) 6.82

Maximum VOC Content 7.5% from MSDS sheet Raw Bead (2) 6.65VOC Content after 2-Pass Expansion and Aging 3.56% from testing Raw Bead (3) 6.62

VOC Content after Drying Oven 0.00% assume all the VOC is emitted Entering Mixer (1) 3.04Application rate of polystyrene in cement board 233 lbs/hr from facility Entering Mixer (2) 3.37

Entering Mixer (3) 3.12Finished Product

Duration of Batch Event

Max Hourly Emissions

lb/batch lb/yr tpy hrs lb/hr2- pass expansion and aging 86.93 55191.64 27.60 5 17.4 assume duration is equivalent to time for expansion process since emissions during aging are minimaldrying oven 78.45 49808.36 24.90 NA 8.29TOTAL 165.38 52.50 25.7

Design of Capture Systems

Total Enclosure for Expansion and Aging Process

NOTESwidth of room (X) 26 ftlength of room (Y) 110 ftheight of room (Z) 40 ft

minimum exhaust for worker comfort 19066.67 scfm EPA-452-F-03-033 (Permanent Total Enclosures) (10 RAC/hr)minimum exhaust for worker comfort 1435.82 lb/min

temperature of exhaust 80 F estimatedexhaust rate 19426.4 acfm

costs for walls and ceilings 72,600.00$ cost of makeup air fan 4,884.30$ EPA/452/B-02-001, Equation 3.16 (assume 30 inch fan and adjust from 1997 dollars)

Total Enclosure for Drying Oven

NOTESwidth of oven (X) 7.42 ft from facilitylength of oven (Y) 170 ft from facility (340 ft total)height of oven (Z) 2.5 ft from facility

volume of oven 3152 ft3Total Surface Area of NDOs (each oven) 25 ft2 from facility

Net exhaust to maintain total capture (each oven) 5000.00 scfm EPA Method 204 (200 fpm at NDOs)Net exhaust to maintain total capture (both oven) 10000.00 scfm

Hot Air provided to dryers 93600.00 scfm 16 blowers each rated at 5850 scfm (from spec sheet)Gross exhaust to maintain total capture (both ovens) 103600.00 scfm

minimum exhaust for total capture (both ovens) 7801.61 lb/mintemperature of exhaust 185 F

exhaust rate 126079.2 acfm

Combined Flow NOTEScombined exhaust flow rate 122667 scfm expansion, aging and dryercombined exhaust flow rate 9237.4 lb/min expansion, aging and dryer

combined temperature 168.7 Fcombined exhaust flow rate 145505.7 acfm expansion, aging and dryer

PTE is designed to enclose the expansion process and the aging process. This makes sense due to proximity of the two processes at the plant

EPA-452-F-03-033 (Permanent Total Enclosures) ($10 per square foot) (assume a 110 ft x 40 ft wall and a 110 ft x 26 ft ceiling needs to be constructed )

VOC (Pentane) Emissions

6.70

3.18

% Pentane in sample % of Pentane Released During Process

53%

47%

assume all remaining VOC is released during drying

Y

X

Z

X Y

Z



Key Costing Inputs 8/30/2016

Exhaust Flowrate and Temperature - Line 2

(acfm) (scfm) (lb/min) (deg F) (deg K)expansion process 19,426 19,067 1,436 80 300drying ovens 126,079 103,600 7,802 185 358

TOTAL -- 122,667 9,237 169 349

VOC Exhaust Constituents

(lb/hr) (ton/yr) (ppm)

Pentane 109-66-0 25.67 52.50 18.70 72.15 19,451

Total VOC -- 25.67 52.50 18.70 72.15 19,451

Other Costing InputsParameter Value Units

Operating Labor Rate $18.98 $/hr

Electricity Price $0.066 $/kWh

Natural Gas Price $7.289 $/mscf

Catalyst Price $952 $/ft3

Carbon Price $1.4 $/lb

Steam price $8.79 $/1000 lb

Cooling water price $0.29 $/1000 gallon

Carbon system condensate transport and disposal

$0.60 $/gal

Carbon replacement labor

$0.07 $/lb

Annual Operating Time 8,760 hrs/yr

CEPCI1998 389.52007 525.4

Feb-15 570.5

Source

Gross Heat of Combustion

(Btu/lb)

Emission Rate

StackFlowrate Temperature

CASChemicalMW

(lb/lb-mol)

Moisture(lb/M lb)

Assumed

EPA's CO$T-AIR spreadsheets ($650/ft3) adjusted from 1998 to 2015 dollars based on Chemical Engineering Plant Cost Indices (CEPCI).

average industrial rate over previous year (http://www.eia.gov/dnav/ng/hist/n3035in3m.htm)

average industrial electricity rate in Clinton IN (http://www.electricitylocal.com/states/indiana/clinton/)

EPA's CO$T-AIR spreadsheets ($12.96/hr) adjusted from 1998 to 2015 dollars based on Chemical Engineering Plant Cost Indices (CEPCI).

Carbon vendor data

EPA's CO$T-AIR spreadsheets ($6/1000 lb) adjusted from 1998 to 2015 dollars based on Chemical Engineering Plant Cost Indices (CEPCI).

EPA's CO$T-AIR spreadsheets ($0.2/1000 gal) adjusted from 1998 to 2015 dollars based on Chemical Engineering Plant Cost Indices (CEPCI).

EPA's CO$T-AIR spreadsheets ($0.05/lb) adjusted from 1998 to 2015 dollars based on Chemical Engineering Plant Cost Indices (CEPCI).

Typical cost for midwest assuming hazardous liquid (pentane solution)



Summary of Cost Analysis 8/30/2016

Parameter Comments

Recuperative Thermal Oxidizera

Catalytic Oxidizera

Regenerative Thermal Oxidizera

Carbon Adsorptiom - On-

site Regenb

Carbon Adsorptiom -No Regenb

CAPITAL COSTSInput Assumptions Gas flow rate (scfm): 122,700 122,700 122,700 122,700 122,700 Reference temperature (oF): 70 70 70 70 70 Inlet VOC content (ppm) 18.7 18.7 18.7 18.7 18.7 Inlet gas temperature (oK): 349 349 349 349 349Total Capital Investment System($): $3,501,551 $4,805,947 $4,940,319 $3,190,031 $2,506,194Total Capital Investment PTE ($) $77,484 $77,484 $77,484 $77,484 $77,484Total Capital Investment($) $3,579,035 $4,883,431 $5,017,804 $3,267,516 $2,583,679

Annual Cost Inputs:Operating factor (hr/yr): 8,760 8760 8760 8760 8760Operating labor rate ($/hr): $18.98 $18.98 $18.98 $18.98 $18.98Maintenance labor rate ($/hr): $20.88 $20.88 $20.88 $20.88 $20.88Electricity price ($/kWhr): $0.07 $0.07 $0.07 $0.07 $0.07Natural gas price ($/mscf): $7.29 $7.29 $7.29 $7.29 $7.29Compressed air ($/1000scf) --- --- --- --- ---Carbon replacement labor ($/lb): --- --- --- $0.07 $0.07Steam price ($/1000 lb): $8.79 $8.79Cooling water price ($/1000 gal): $0.29 $0.29Carbon Price ($/lb) $1.40 $1.40Overhead rate (fraction): 0.6 0.6 0.6 0.6 0.6Annual interest rate (fraction): 0.07 0.07 0.07 0.07 0.07Control system life (years): 10 10 10 10 10Capital recovery factor (system): 0.1424 0.1424 0.1424 0.1424 0.1424Capital recovery factor (carbon): --- 0.55 --- 0.24 0.24Catalyst life (years): --- 2.00 --- --- ---Carbon life (years): --- --- --- 5.00 5.00Taxes, insurance, admin. factor: 0.04 0.04 0.04 0.04 0.04

ANNUAL COSTS:

Operating labor 0.5 hours/shift, 3 shifts per day $10,393 $10,393 $10,393 $10,393 $10,393

Supervisory labor 15% of operating labor $1,559 $1,559 $1,559 $1,559 $1,559

Maintenance labor 0.5 hours/shift, 3 shifts per day; RTO assumes 1 hr/wk. $11,432 $11,432 $11,432 $11,432 $11,432

On Site Vendor Suport 2 weeks per year --- ---Maintenance materials 100% of maintenance labor $11,432 $11,432 $11,432 $11,432 $11,432Electricity $266,128 $292,283 $277,045 $162,886 $73,509Natural Gas $5,985,601 $2,981,716 $769,922 $0 $0

Compressed airCompressed hydrogen and nitrogen --- --- --- --- ---

Zeolite replacement --- --- --- --- ---Catalyst Replacement --- $135,961 --- --- ---Steam --- --- --- $6,918 $0Cooling water --- --- --- $540 $0Carbon replacement --- --- --- $85,394 $5,033,612Condensate disposal --- --- --- $68,770 ---

Overhead

60% of operating, supervisor, and maintenance labor and maintenance materials

$20,890 $20,890 $20,890 $20,890 $20,890

Taxes, insurance, administrative 4% total capital investment $140,062 $192,238 $197,613 $127,601 $100,248Capital recovery $509,574 $695,291 $714,422 $404,337 $331,900

Total Annual Cost $6,957,071 $4,353,196 $2,014,708 $912,153 $5,594,974Control Efficiency of Equipment 98% 98% 98% 98% 98%VOC Controlled 51.45 51.45 51.45 51.45 51.45$ per ton controlled 135,220$ 84,610$ 39,159$ 17,729$ 108,746$

Notes:

.

b Costs developed based on EPA's CO$T-AIR spreadsheets updated from 1998 to 2015 costs based on Chemical Engineering Plant Cost Indices (CEPCIs). Carbon usage rates determined based on input from carbon adsorption system vendors. Carbon usage was scaled up from the expansion and aging mass emission rate to the total emission rate based on the following formula: UsageExp+Dry = UsageExp * (EmissionsExp+Dry/EmissionsExp)

0.6. For the on-site regeneration scenario, carbon is assumed to be regenerated via steam with pentane recovered through condensation. For the no regeneration scenario, carbon is assumed to be replaced with fresh material once depleted.

a Costs developed based on EPA's CO$T-AIR spreadhseets updated from 1998 to 2013 costs based on Chemical Engineering Plant Cost Indices (CEPCIs). These costs are expected to represent conservative estimates.

TOTAL ANNUAL COST SPREADSHEET PROGRAM-- New NGC, Inc. d/b/a National Gypsum CompanySPR 165-35908-00081


ThOx GMU Inputs 8/30/2016

Input ParametersTotal Gas Flow Rate 122,667 scfmCombustion Temperature 1,600 °F

Hours of Operation 8,760 hr/yrAnnual Emissions 52.50 tpyInlet Gas Temperature 169 FGross Heat of Combustion 19,451 BTU/lb VOC averageWaste Gas Heat Content 0.0317 BTU/scf VOC average

Operating Labor Rate 18.982 $/hrElectricity Price 0.066 $/kWhNatural Gas Price 7.289 $/mscf



RecupTO 8/30/2016

TOTAL ANNUAL COST SPREADSHEET PROGRAM--THERMAL INCINERATORS (Total flowrate > 50,000 scfm)

COST BASE DATE: April 1988 [1]

VAPCCI (Fourth Quarter 1999--FINAL): 110.5

INPUT PARAMETERS

-- Total gas flowrate (scfm): 122667-- Flowrate per unit (scfm): 40889-- Flowrate/unit, 2nd iter. (scfm): 40889-- Number of units: 3-- Reference temperature (oF): 77-- Inlet gas temperature (oF): 169-- Inlet gas density (lb/scf): 0.0739-- Primary heat recovery (fraction): 0.70-- Waste gas heat content (BTU/scf): 0.03-- Waste gas heat content (BTU/lb): 0.43-- Gas heat capacity (BTU/lb-oF): 0.255-- Combustion temperature (oF): 1600-- Preheat temperature (oF): 1171-- Fuel heat of combustion (BTU/lb): 21502-- Fuel density (lb/ft3): 0.0408

DESIGN PARAMETERS

-- Auxiliary Fuel Reqrmnt (lb/min): 63.745 (scfm): 1562.4

-- Total Gas Flowrate (scfm): 124229

CAPITAL COSTS

Equipment Costs ($):-- Incinerator:

@ 0 % heat recovery: 0@ 35 % heat recovery: 0@ 50 % heat recovery: 0@ 70 % heat recovery: 910,453

-- Other (auxiliary equipment, etc.): 0Total Equipment Cost--base: 910,453 ' ' ' --escalated: 1,258,358Purchased Equipment Cost ($): 1,484,863Total Capital Investment ($): 2,390,629 1998 dollarsTotal Capital Investment ($): 3,501,551 2015 dollars============ ============ ============ ============ ============

ANNUAL COST INPUTS

Operating factor (hr/yr): 8760Operating labor rate ($/hr): 18.98Maintenance labor rate ($/hr): 20.88Operating labor factor (hr/sh): 0.5Maintenance labor factor (hr/sh): 0.5Electricity price ($/kwh): 0.066Natural gas price ($/mscf): 7.29Annual interest rate (fraction): 0.07Control system life (years): 10Capital recovery factor: 0.1424Taxes, insurance, admin. factor: 0.04Pressure drop (in. w.c.): 19.0

ANNUAL COSTS

Item Cost ($/yr) Wt. Factor W.F.(cond.)---------------------------------------------------------------------------------------Operating labor 10,393 0.001 ----Supervisory labor 1,559 0.000 ----Maintenance labor 11,432 0.002 ----Maintenance materials 11,432 0.002 ----Natural gas 5,985,601 0.862 ----Electricity 266,128 0.038 ----Overhead 20,890 0.003 0.008Taxes, insurance, administrative 140,062 0.020 ----Capital recovery (*) 498,542 0.072 0.092-------------------------------------------------------------- ------------------------Total Annual Cost 6,946,039 1.000 1.000

* without PTE costs (see Summary of Cost Analysis)

[1] Original equipment costs reflect this date.[2] VAPCCI = Vatavuk Air Pollution Control Cost Index (for thermalincinerators) corresponding to year and quarter shown. Originalequipment cost, purchased equipment cost, and total capital investmenthave been escalated to this date via the VAPCCI and control equipmentvendor data.

CEPCI1998 389.52015 570.5

TOTAL ANNUAL COST SPREADSHEET PROGRAM-- New NGC, Inc. d/b/a National Gypsum CompanySPR 165-35908-00081


CatOx GMU Inputs 8/30/2016

Input ParametersTotal Gas Flow Rate 122,667 scfmCombustion Temperature 900 °FHours of Operation 8,760 hr/yrAnnual Emissions 52.50 tpyInlet Gas Temperature 169 FGross Heat of Combustion 19,451 BTU/lb VOC averageWaste Gas Heat Content 0.0317 BTU/scf VOC average

Operating Labor Rate 18.982 $/hrElectricity Price 0.066 $/kWhCatalyst price 952 $/ft3

Natural Gas Price 7.289 $/mscf



Catalytic Incineration 8/30/2016

TOTAL ANNUAL COST SPREADSHEET PROGRAM--CATALYTIC INCINERATORS (FIXED) (Total flowrate > 50,000 scfm)

COST REFERENCE DATE: April 1988 [1]

VAPCCI (Fourth Quarter 1998--Final): 104.3

INPUT PARAMETERS

-- Total gas flowrate (scfm): 122667-- Flowrate per unit (scfm): 40889-- Flowrate/unit, 2nd iter. (scfm): 40889-- Number of units: 3-- Reference temperature (oF): 77-- Inlet gas temperature (oF): 169-- Inlet gas density (lb/scf): 0.0739-- Primary heat recovery (fraction): 0.70-- Waste gas heat content (BTU/scf): 0.03-- Waste gas heat content (BTU/lb): 0.43-- Gas heat capacity (BTU/lb-oF): 0.248-- Combustion temperature (oF): 900-- Preheat temperature (oF): 681-- Fuel heat of combustion (BTU/lb): 21502-- Fuel density (lb/ft3): 0.0408

DESIGN PARAMETERS


-- Total Gas Flowrate (scfm): 123445-- Catalyst Volume (ft3): 239.1

CAPITAL COSTS


@ 0 % heat recovery: 0@ 35 % heat recovery: 0@ 50 % heat recovery: 0@ 70 % heat recovery: 1,531,870

-- Other (auxiliary equipment, etc.): 0Total Equipment Cost--base: 1,531,870 ' ' ' --escalated: 1,727,121Purchased Equipment Cost ($): 2,038,003Total Capital Investment ($): 3,281,185 1998 dollarsTotal Capital Investment ($): 4,805,947 2015 dollars============ ============ ============ ============= ============

ANNUAL COST INPUTS

Operating factor (hr/yr): 8760Operating labor rate ($/hr): 18.98Maintenance labor rate ($/hr): 20.88Operating labor factor (hr/sh): 0.5Maintenance labor factor (hr/sh): 0.5Electricity price ($/kwh): 0.066Catalyst price ($/ft3): 952Natural gas price ($/mscf): 7.29Annual interest rate (fraction): 0.07Control system life (years): 10Catalyst life (years): 2Capital recovery factor (system): 0.1424Capital recovery factor (catalyst): 0.5531Taxes, insurance, admin. factor: 0.04Pressure drop (in. w.c.): 21.0

ANNUAL COSTS

Item Cost ($/yr) Wt. Factor W.F.(cond.)----------------------------------------------------------------------------------------Operating labor 10,393 0.002 ----Supervisory labor 1,559 0.000 ----Maintenance labor 11,432 0.003 ----Maintenance materials 11,432 0.003 ----Natural gas 2,981,716 0.687 ----Electricity 292,283 0.067 ----Catalyst replacement 135,961 0.031 ----Overhead 20,890 0.005 0.013Taxes, insurance, administrative 192,238 0.044 ----Capital recovery (*) 684,259 0.158 0.202--------------------------------------------------- ------------ ------------------------Total Annual Cost 4,342,164 1.000 1.000


[1] Original equipment costs reflect this date.

CEPCI1998 389.52015 570.5

TOTAL ANNUAL COST SPREADSHEET-- New NGC, Inc. d/b/a National Gypsum CompanySPR 165-35908-00081


RTO GMU Inputs 8/30/2016


Hours of Operation 8,760 hr/yrAnnual Emissions 52.50 tpyInlet Gas Temperature 169 FGross Heat of Combustion 19,451 BTU/lb VOC averageWaste Gas Heat Content 0.0317 BTU/scf VOC averageInlet Gas Temperature 169 FOperating Labor Rate 18.982 $/hrElectricity Price 0.066 $/kWhNatural Gas Price 7.289 $/mscf



Regenerative Thermal Oxidizers 8/30/2016

TOTAL ANNUAL COST SPREADSHEET PROGRAM--REGENERATIVE THERMAL OXIDIZERS

COST BASE DATE: December 1988 [1]

VAPCCI (Fourth Quarter 1998--FINAL): [ 109.2

INPUT PARAMETERS

-- Gas flowrate (scfm): 122667-- Reference temperature (oF): 77-- Inlet gas temperature (oF): 169-- Inlet gas density (lb/scf): 0.0739-- Primary heat recovery (fraction): 0.95-- Waste gas heat content (BTU/scf): 0.03-- Waste gas heat content (BTU/lb): 0.43-- Gas heat capacity (BTU/lb-oF): 0.255-- Combustion temperature (oF): 1450-- Heat loss (fraction): 0.01-- Exit temperature (oF): 233-- Fuel heat of combustion (BTU/lb): 21502-- Fuel density (lb/ft3): 0.0408

DESIGN PARAMETERS

Auxiliary Fuel Requirement (lb/min): 8.199 (scfm): 201.0

Total Gas Flowrate (scfm): 122868

TOTAL CAPITAL INVESTMENT ($) [3](Cost correlations range: 5000 to 500,000 scfm)

@ 85 % heat recovery--base: 0 ' ' ' --escalated: 0@ 95 % heat recovery--base: 3,372,926 ' ' ' --escalated: 4,940,319 2015 Dollars

============ ============ ============ ============ ============

ANNUAL COST INPUTS

Operating factor (hr/yr): 8760Operating labor rate ($/hr): 18.98Maintenance labor rate ($/hr): 20.88Operating labor factor (hr/sh): 0.50Maintenance labor factor (hr/wk): 1.00Electricity price ($/kwh): 0.066Natural gas price ($/mscf): 7.29Annual interest rate (fraction): 0.07Control system life (years): 10Capital recovery factor: 0.1424Taxes, insurance, admin. factor: 0.04Pressure drop (in. w.c.): 20.0

ANNUAL COSTS

Item Cost ($/yr) Wt. Factor W.F.(cond.)----------------------------------------------------------------------------------------Operating labor 10,393 0.005 ----Supervisory labor 1,559 0.001 ----Maintenance labor 1,086 0.001 ----Maintenance materials 1,086 0.001 ----Natural gas 769,922 0.391 ----Electricity 277,045 0.141 ----Overhead 8,474 0.004 0.011Taxes, insurance, administrative 197,613 0.100 ----Capital recovery (*) 703,390 0.357 0.457----------------------------------------------------------------------------------------Total Annual Cost 1,970,568 1.000 1.000


[1] Base total capital investment reflects this date.[2] VAPCCI = Vatavuk Air Pollution Control Cost Index (for regenerativethermal oxidizers) corresponding to year and quarter shown. Basetotal capital investment has been escalated to this date via VAPCCI andcontrol equipment vendor data.[3] Source: Vatavuk, William M. ESTIMATING COSTS OF AIR POLLUTION CONTROL. Boca Raton, FL: Lewis Publishers, 1990.

CEPCI1998 389.52015 570.5



Carbon Regen 8/30/2016

TOTAL ANNUAL COST SPREADSHEET PROGRAM--CARBON ADSORBERS [1]

COST BASE DATE: Third Quarter 1989 [2]CEPCI

VAPCCI (Fourth Quarter 1998--FINAL): [3] 100.0 1998 389.52015 570.5

INPUT PARAMETERS:-- Inlet stream flowrate (acfm): 122667-- Inlet stream temperature (oF): 169-- Inlet stream pressure (atm): 1-- VOC to be condensed: Pentane-- Inlet VOC flowrate (lb/hr): 25.67-- VOC molecular weight (lb/lb-mole): 72.15-- VOC inlet volume fraction: 2.22E-05-- VOC inlet concentration (ppmv): 22-- VOC inlet partial pressure (psia): 0.0003-- Required VOC removal (fraction): 0.980-- Freundlich isotherm equation constants for VOC (see Table 1 below):

VOC number (enter Table 1 # or zero, if no data) 0 K: 0.000 M: 0.000

-- Yaws isotherm equation constants (see Table 2 below): VOC number (enter Table 2 #or zero, if no data): 213

0.03071 0.34304 -0.01596

-- Adsorption time (hr): 8.0-- Desorption time (hr): 4.0-- Number of adsorbing vessels: 13-- Superficial carbon bed velocity (ft/min): 75-- Carbon price ($/lb): 1.40-- Material of construction (see list below):[4] 1

DESIGN PARAMETERS:-- Carbon equilibrium capacity--Freundlich (lb VOC/lb carb): 0.0000 " " " -- Yaw 0.0291-- Carbon working capacity (lb VOC/lb carbon): 0.0145-- Number of desorbing vessels: 7-- Total number of vessels: 20-- Carbon requirement, total (lb): 220872 Based on vendor data escalated based on mass -- Carbon requirement per vessel (lb): 11044 emission rate with redundant capacity -- Gas flowrate per vessel (acfm): 9436 to allow for on-site regeneration-- Adsorber vessel diameter (ft): 12.657-- Adsorber vessel length (ft): 6.926-- Adsorber vessel surface area (ft2): 527.01-- Carbon bed thickness (ft): 2.926-- Carbon bed pressure drop (in. w.c.): [5] 9.895

CAPITAL COSTSEquipment Costs ($):-- Adsorber vessels 710,519-- Carbon 309,221-- Other equipment (condenser, decanter, etc.) 234,402

Total equipment cost ($)--base: 1,249,142 ' ' ' ' --escalated: 1,834,617 2015 $ Includes an additional $5000 for aPurchased Equipment Cost ($): 1,981,386 10,000-gal condensateTotal Capital Investment ($): 3,190,031 storage tank " " " ($/acfm): 26.0

ANNUAL COST INPUTS:Operating factor (hr/yr): 8760Operating labor rate ($/hr): 18.98Maintenance labor rate ($/hr): 20.88Operating labor factor (hr/sh): 0.5Maintenance labor factor (hr/sh): 0.5Electricity price ($/kWhr): 0.07Recovered VOC value ($/lb): 0.0000Steam price ($/1000 lb): 8.79Cooling water price ($/1000 gal): 0.29Carbon replacement labor ($/lb): 0.07Condensate transport & disposal cost ($/ga 0.60Overhead rate (fraction): 0.6Annual interest rate (fraction): 0.07Control system life (years): 10Capital recovery factor (system): 0.1424Carbon life (years): 5Capital recovery factor (carbon): 0.2439Taxes, insurance, admin. factor: 0.04

ANNUAL COSTS: Item Cost ($/yr) Wt. Factor W.F.(cond.)----------------------------------------------------------------------------------------------------Operating labor 10,393 0.011 ----Supervisory labor 1,559 0.002 ----Maintenance labor 11,432 0.013 ----Maintenance materials 11,432 0.013 ----Electricity 162,886 0.179 ----Steam 6,918 0.008 ----Cooling water 540 0.001 ----Carbon replacement 85,394 0.094 ----Condensate transport & disposal 68,770 0.075 94,501 gal water/yrOverhead 20,890 0.023 0.061 +Taxes, insurance, administrative 127,601 0.140 ---- 20,115 gal C5/yrCapital recovery 404,337 0.443 0.583---------------------------------------------------------------------------- ------------------------Total Annual Cost (without credits) 912,153 1.000 0.823Recovery credits 0Total Annual Cost (with credits) 912,153

Assumes n-butane as most similar to pentane




Notes:------[1] This program has been based on data and procedures in Chapter 4of the OAQPS CONTROL COST MANUAL (5th edition).

[2] Base equipment costs reflect this date.

[3] VAPCCI = Vatavuk Air Pollution Control Cost Index (for carbonadsorbers) corresponding to year and quarter shown. Base equipmentcost, purchased equipment cost, and total capital investment have beenescalated to this date via the VAPCCI and control equipment vendor data.

[4] Enter one of the following: carbon steel--'1'; 316 stainless steel--'1.3'; Carpenter 20 (CB-3)--'1.9'; Monel-400--'2.3'; Nickel-200--'3.2';titanium--'4.5'.

[5] This is the carbon bed pressure drop ONLY. There will be additional pressure dropthrough the ductwork . For estimating ductwork pressure losses, see Chapter 10 of the OAQPS CONTROL COST MANUAL (5th edition).

Table 1. Freundlich Constants for Selected Compounds [6] Correlation Range (psia)

VOC VOC number K M Temperatur Minimum Maximum-------------------------------------------------------------------------------------------------------------------------------Benzene 1001 0.597 0.176 77 0.0001 0.05Chlorobenzene 1002 1.05 0.188 77 0.0001 0.01Cyclohexane 1003 0.508 0.210 100 0.0001 0.05Dichloroethane 1004 0.976 0.281 77 0.0001 0.04Phenol 1005 0.855 0.153 104 0.0001 0.03Trichloroethane 1006 1.06 0.161 77 0.0001 0.04Vinyl chloride 1007 0.200 0.477 100 0.0001 0.05m-Xylene (low-pressure 1008 0.708 0.113 77 0.0001 0.001m-Xylene (high-pressure 1009 0.527 0.0703 77 0.001 0.05Acrylonitrile 1010 0.935 0.424 100 0.0001 0.015Acetone 1011 0.412 0.389 100 0.0001 0.05Toluene 1012 0.551 0.110 77 0.0001 0.05-------------------------------------------------------------------------------------------------------------------------------[6] These constants fit the following equation:

Q = K(P)^M

where: Q = equilibrium adsorption capacity (lb/lb carbon) P = VOC partial pressure (psia at 1 atm & listed temperature)

******************************************************************************************************************************* Table 2. Correlation Constants for Yaws Isoth Correlation Ranges (ppmv)============================================================================================================== VOC VOC number A B C Minimum Maximum-------------------------------------------------------------------------------------------------------------------------------Phosgene 6 -0.64469 0.60428 -0.02986 10 10000Carbon tetrachloride 9 1.07481 0.28186 -0.02273 10 10000Chloroform 11 0.67102 0.36148 -0.02288 10 10000Formaldehyde 18 -2.48524 0.69123 -0.00375 10 10000Methyl chloride 21 -1.91871 0.62053 -0.00549 10 10000Carbon disulfide 35 -0.18899 0.47093 -0.01481 10 10000Tetrachloroethylene 39 1.40596 0.20802 -0.02097 10 10000Vinyl chloride 55 -0.98889 0.66564 -0.04320 10 100001,1,2-Trichloroethane 59 1.17163 0.27791 -0.02746 10 10000Acetonitrile 60 -0.79666 0.63512 -0.02598 10 10000Methyl isocyanate 61 -1.07579 0.85881 -0.06876 10 10000Acetaldehyde 69 -1.17047 0.62766 -0.02475 10 10000Ethylene glycol 84 1.40474 0.18738 -0.02663 10 121Ethyl mercaptan 87 0.00552 0.40506 -0.01802 10 10000Acrylonitrile 93 0.07669 0.49986 -0.03500 10 10000Acrolein 97 -0.29632 0.49437 -0.02471 10 100001,3-Butadiene 168 -0.03359 0.34764 -0.01297 10 10000Methyl ethyl ketone 194 0.46525 0.37688 -0.02801 10 10000n-Butane 213 0.03071 0.34304 -0.01596 10 100001,2,4-Trichlorobenzene 331 1.68304 0.09456 -0.00998 10 566Chlorobenzene 336 1.02705 0.30619 -0.03353 10 10000Nitrobenzene 340 1.64859 0.06109 0 10 329Benzene 341 0.81119 0.28864 -0.02378 10 10000Phenol 345 1.45599 0.10349 -0.01086 10 10000Toluene 466 1.11466 0.20795 -0.02016 10 10000m-Cresol 469 1.61982 0.04926 0 10 149o-Toluidine 474 1.58104 0.05475 0 10 339Styrene 528 1.35701 0.13495 -0.01451 10 8044m-Xylene 533 1.31522 0.14019 -0.01457 10 10000o-Xylene 534 1.33404 0.13931 -0.01494 10 8722p-Xylene 535 1.31115 0.14069 -0.01458 10 10000

[7] Constants fit the following equation: Q = 0.01*10^{A + B(log[y]) + C(log[y])^2}where: Q = equilibrium adsorption capacity (lb/lb carbon) y = VOC concentration (ppmv at 77 F, 1 atm)

Source: Yaws, Carl L. et al., "Determining VOC Adsorption Capacity," Pollution Engineering, February 1995, pp. 34-37.



Carbon No Regen 8/30/2016




INPUT PARAMETERS:-- Inlet stream flowrate (acfm): 122667-- Inlet stream temperature (oF): 169-- Inlet stream pressure (atm): 1-- VOC to be condensed: Pentane-- Inlet VOC flowrate (lb/hr): 25.67-- VOC molecular weight (lb/lb-mole): 72.15-- VOC inlet volume fraction: 2.22E-05-- VOC inlet concentration (ppmv): 22-- VOC inlet partial pressure (psia): 0.0003-- Required VOC removal (fraction): 0.980-- Freundlich isotherm equation constants for VOC (see Table 1 below):


-- Yaws isotherm equation constants (see Table 2 below): VOC number (enter Table 2 #or zero, if no data): 213

0.03071 0.34304 -0.01596


DESIGN PARAMETERS:-- Carbon equilibrium capacity--Freundlich (lb VOC/lb carb): 0.0000 " " " -- Yaw 0.0291-- Carbon working capacity (lb VOC/lb carbon): 0.0145-- Number of desorbing vessels: 7-- Total number of vessels: 20-- Carbon requirement, total (lb): 110436 Based on vendor assuming no on-site regeneration-- Carbon requirement per vessel (lb): 5522 and that fresh carbon would be brought-- Gas flowrate per vessel (acfm): 9436 on-site-- Adsorber vessel diameter (ft): 12.657-- Adsorber vessel length (ft): 5.463-- Adsorber vessel surface area (ft2): 468.84-- Carbon bed thickness (ft): 1.463-- Carbon bed pressure drop (in. w.c.): [5] 4.948

CAPITAL COSTSEquipment Costs ($):-- Adsorber vessels 648,721-- Carbon 154,611-- Other equipment (condenser, decanter, etc.) 0 No on-site regeneration assumed

Total equipment cost ($)--base: 984,049 ' ' ' ' --escalated: 1,441,336 2015 $Purchased Equipment Cost ($): 1,556,643Total Capital Investment ($): 2,506,194 " " " ($/acfm): 20.4

ANNUAL COST INPUTS:Operating factor (hr/yr): 8760Operating labor rate ($/hr): 18.98Maintenance labor rate ($/hr): 20.88Operating labor factor (hr/sh): 0.5Maintenance labor factor (hr/sh): 0.5Electricity price ($/kWhr): 0.07Recovered VOC value ($/lb): 0.0000Steam price ($/1000 lb): 8.79Cooling water price ($/1000 gal): 0.29Carbon replacement labor ($/lb): 0.07Overhead rate (fraction): 0.6Annual interest rate (fraction): 0.07Control system life (years): 10Capital recovery factor (system): 0.1424Carbon life (years): 5Capital recovery factor (carbon): 0.2439Taxes, insurance, admin. factor: 0.04

ANNUAL COSTS: Item Cost ($/yr) Wt. Factor W.F.(cond.)----------------------------------------------------------------------------------------------------Operating labor 10,393 0.002 ----Supervisory labor 1,559 0.000 ----Maintenance labor 11,432 0.002 ----Maintenance materials 11,432 0.002 ----Electricity 73,509 0.013 ----Steam 0 0.000 ---- No on-site carbon regenerationCooling water 0 0.000 ---- No on-site carbon regenerationCarbon replacement 5,033,612 0.900 ---- Carbon replacement cost assumes noOverhead 20,890 0.004 0.010 regeneration and a carbonTaxes, insurance, administrative 100,248 0.018 ---- replacement rate of 3567.86Capital recovery 331,900 0.059 0.077 lb/day per vendor data---------------------------------------------------------------------------- --------------------- escalated based on massTotal Annual Cost (without credits) 5,594,974 1.000 0.100 emission rateRecovery credits 0Total Annual Cost (with credits) 5,594,974

Assumes n-butane as most similar to pentane










VOC VOC number K M Temperatur Minimum Maximum---------------------------------------------------------------------------------------------------------------------------------Benzene 1001 0.597 0.176 77 0.0001 0.05Chlorobenzene 1002 1.05 0.188 77 0.0001 0.01Cyclohexane 1003 0.508 0.210 100 0.0001 0.05Dichloroethane 1004 0.976 0.281 77 0.0001 0.04Phenol 1005 0.855 0.153 104 0.0001 0.03Trichloroethane 1006 1.06 0.161 77 0.0001 0.04Vinyl chloride 1007 0.200 0.477 100 0.0001 0.05m-Xylene (low-pressure 1008 0.708 0.113 77 0.0001 0.001m-Xylene (high-pressure 1009 0.527 0.0703 77 0.001 0.05Acrylonitrile 1010 0.935 0.424 100 0.0001 0.015Acetone 1011 0.412 0.389 100 0.0001 0.05Toluene 1012 0.551 0.110 77 0.0001 0.05---------------------------------------------------------------------------------------------------------------------------------[6] These constants fit the following equation:

Q = K(P)^M


********************************************************************************************************************************* Table 2. Correlation Constants for Yaws Isoth Correlation Ranges (ppmv)============================================================================================================== VOC VOC number A B C Minimum Maximum---------------------------------------------------------------------------------------------------------------------------------Phosgene 6 -0.64469 0.60428 -0.02986 10 10000Carbon tetrachloride 9 1.07481 0.28186 -0.02273 10 10000Chloroform 11 0.67102 0.36148 -0.02288 10 10000Formaldehyde 18 -2.48524 0.69123 -0.00375 10 10000Methyl chloride 21 -1.91871 0.62053 -0.00549 10 10000Carbon disulfide 35 -0.18899 0.47093 -0.01481 10 10000Tetrachloroethylene 39 1.40596 0.20802 -0.02097 10 10000Vinyl chloride 55 -0.98889 0.66564 -0.04320 10 100001,1,2-Trichloroethane 59 1.17163 0.27791 -0.02746 10 10000Acetonitrile 60 -0.79666 0.63512 -0.02598 10 10000Methyl isocyanate 61 -1.07579 0.85881 -0.06876 10 10000Acetaldehyde 69 -1.17047 0.62766 -0.02475 10 10000Ethylene glycol 84 1.40474 0.18738 -0.02663 10 121Ethyl mercaptan 87 0.00552 0.40506 -0.01802 10 10000Acrylonitrile 93 0.07669 0.49986 -0.03500 10 10000Acrolein 97 -0.29632 0.49437 -0.02471 10 100001,3-Butadiene 168 -0.03359 0.34764 -0.01297 10 10000Methyl ethyl ketone 194 0.46525 0.37688 -0.02801 10 10000n-Butane 213 0.03071 0.34304 -0.01596 10 100001,2,4-Trichlorobenzene 331 1.68304 0.09456 -0.00998 10 566Chlorobenzene 336 1.02705 0.30619 -0.03353 10 10000Nitrobenzene 340 1.64859 0.06109 0 10 329Benzene 341 0.81119 0.28864 -0.02378 10 10000Phenol 345 1.45599 0.10349 -0.01086 10 10000Toluene 466 1.11466 0.20795 -0.02016 10 10000m-Cresol 469 1.61982 0.04926 0 10 149o-Toluidine 474 1.58104 0.05475 0 10 339Styrene 528 1.35701 0.13495 -0.01451 10 8044m-Xylene 533 1.31522 0.14019 -0.01457 10 10000o-Xylene 534 1.33404 0.13931 -0.01494 10 8722p-Xylene 535 1.31115 0.14069 -0.01458 10 10000




TSD Appendix D Page 1 of 15

Indiana Department of Environmental ManagementOffice of Air Quality

Appendix D Best Available Control Technology (BACT) Analysis

SCENARIO 2 - Control of the Polystyrene Expansion and Aging Processes






Process Summary 8/30/2016

Polystyrene Expansion Process

Summary of Emissions Summary of Pentane Test ResultsNOTES

Maximum Annual Throuput 700 tons permit limit each averageBatch Size 2,205 lbs from permit Raw Bead (1) 6.82

Maximum VOC Content 7.5% from MSDS sheet Raw Bead (2) 6.65

VOC content after expansion 5.24% from testing Raw Bead (3) 6.62VOC content after aging 3.18% from testing After Expansion (1) 5.35

VOC Content after Drying Oven 0.00% assume all remaining VOC emitted After Expansion (2) 5.00

Application rate of polystyrene in cement board 233 lbs/hr from facility After Expansion (3) 5.36Entering Mixer (1) 3.04

Duration of Batch Event

Max Hourly Emissions

Entering Mixer (2) 3.37

lb/batch tpy hrs lb/hr Entering Mixer (3) 3.12

expansion 36.05 11.4 5 7.21 Finished Productaging -- 16.1 -- 3.69drying oven -- 24.9 -- 8.29TOTAL 52.5 19.19

Design of Capture Systems

Total Enclosure for Expansion and Aging Process

NOTESwidth of room (X) 26 ftlength of room (Y) 110 ftheight of room (Z) 40 ft

minimum exhaust for worker comfort 19066.67 scfm EPA-452-F-03-033 (Permanent Total Enclosures) (10 RAC/hr)minimum exhaust for worker comfort 1435.82 lb/min

temperature of exhaust 80 F estimatedexhaust rate 19426.4 acfm

costs for walls and ceilings 72,600.00$ cost of makeup air fan 4,884.30$ EPA/452/B-02-001, Equation 3.16 (assume 30 inch fan and adjust from 1997 dollars)

VOC (Pentane) Emissions

assume all remaining VOC is released during drying

Sample % of Pentane Released During Process

3.18

5.24

6.70 Expansion

% Pentane in sample

22%

PTE is designed to enclose the expansion process and the aging process. This makes sense due to proximity of the two processes at the plant

EPA-452-F-03-033 (Permanent Total Enclosures) ($10 per square foot) (assume a 110 ft x 40 ft wall and a 110 ft x 26 ft ceiling needs to be constructed )

Drying

Aging 31%

47%

Y

X

Z



Key Costing Inputs 8/30/2016

Exhaust Flowrate and Temperature - Line 2

(acfm) (scfm) (lb/min) (deg F) (deg K)expansion & aging 19,426 19,067 1,436 80 300

VOC Exhaust Constituents

(lb/hr) (ton/yr) (ppm)

Pentane (expansion & aging)

109-66-0 10.90 27.60 51.08 72.15 20,908

Total VOC -- 10.90 27.60 51.08 72.15 20,908

Other Costing InputsParameter Value Units

Operating Labor Rate $18.98 $/hr

Electricity Price $0.066 $/kWh

Natural Gas Price $6.255 $/mscf

Catalyst Price $952 $/ft3

Carbon Price $1.4 $/lb

Steam price $8.79 $/1000 lb

Cooling water price $0.29 $/1000 gallon

Carbon replacement labor

$0.07 $/lb

Carbon system condensate transport and disposal

$0.60 $/gal

Annual Operating Time 8,760 hrs/yr

CEPCI1998 389.52007 525.4

Feb-15 570.5

Source

Gross Heat of Combustion

(Btu/lb)

Emission Rate

StackFlowrate Temperature

CASChemicalMW

(lb/lb-mol)

Moisture(lb/M lb)

Assumed

EPA's CO$T-AIR spreadsheets ($650/ft3) adjusted from 1998 to 2015 dollars based on Chemical Engineering Plant Cost Indices (CEPCI).

average Jan - Sep 2015 industrial rate (https://www.eia.gov/dnav/ng/hist/n3035in3m.htm)

average industrial electricity rate in Clinton IN (http://www.electricitylocal.com/states/indiana/clinton/)

EPA's CO$T-AIR spreadsheets ($12.96/hr) adjusted from 1998 to 2015 dollars based on Chemical Engineering Plant Cost Indices (CEPCI).

Carbon vendor data

EPA's CO$T-AIR spreadsheets ($6/1000 lb) adjusted from 1998 to 2015 dollars based on Chemical Engineering Plant Cost Indices (CEPCI).

EPA's CO$T-AIR spreadsheets ($0.2/1000 gal) adjusted from 1998 to 2015 dollars based on Chemical Engineering Plant Cost Indices (CEPCI).

EPA's CO$T-AIR spreadsheets ($0.05/lb) adjusted from 1998 to 2015 dollars based on Chemical Engineering Plant Cost Indices (CEPCI).

Typical cost for midwest assuming hazardous liquid (pentane solution)



Summary 8/30/2016

Parameter Comments

Recuperative Thermal Oxidizera

Catalytic Oxidizera

RTO with Rotary Zeolite

Concentratorb

Regenerative Thermal Oxidizera

Carbon Adsorptiom - On-

site Regenc

Carbon Adsorptiom -No

Regenc

CAPITAL COSTSInput Assumptions Gas flow rate (scfm): 19,100 19,100 19,100 19,100 19,100 19,100 Reference temperature (oF): 70 70 70 70 70 70 Inlet VOC content (ppm) 51.1 51.1 51.1 51.1 51.1 51.1 Inlet gas temperature (oK): 300 300 300 300 300 300Total Capital Investment System($): $687,636 $749,526 $692,920 $1,456,677 $1,249,905 $895,005Total Capital Investment PTE ($) $77,484 $77,484 $77,484 $77,484 $77,484 $77,484Total Capital Investment($) $765,121 $827,010 $770,404 $1,534,161 $1,327,390 $972,489

Annual Cost Inputs:Operating factor (hr/yr): 8,760 8760 8760 8,760 8,760 8,760Operating labor rate ($/hr): $18.98 $18.98 $18.98 $18.98 $18.98 $18.98Maintenance labor rate ($/hr): $20.88 $20.88 $20.88 $20.88 $20.88 $20.88Electricity price ($/kWhr): $0.066 $0.066 $0.066 $0.066 $0.066 $0.066Natural gas price ($/mscf): $6.26 $6.26 $6.26 $6.26 $6.26 $6.26Media replacement labor ($/lb): --- --- --- --- $0.07 $0.07Steam price ($/1000 lb): --- --- --- --- $8.79 $8.79Cooling water price ($/1000 gal): --- --- --- --- $0.29 $0.29Carbon Price ($/lb) --- --- --- --- $1.40 $1.40Overhead rate (fraction): 0.6 0.6 0.6 0.6 0.6 0.6Annual interest rate (fraction): 0.07 0.07 0.07 0.07 0.07 0.07Control system life (years): 10 10 10 10 10 10Capital recovery factor (system): 0.1424 0.1424 0.1424 0.1424 0.1424 0.1424Media life (years): --- 2.00 20.00 --- 5.00 5.00Capital recovery factor (media): --- 0.5531 0.0944 --- 0.2439 0.2439Taxes, insurance, admin. factor: 0.04 0.04 0.04 0.04 0.04 0.04

ANNUAL COSTS:

Operating labor 0.5 hours/shift, 3 shifts per day $0 $0 $10,393 $0 $10,393 $10,393

Supervisory labor15% of operating labor, where applicable $0 $0 $1,559 $0 $1,559 $1,559

Maintenance labor 0.5 hours/shift, 3 shifts per day; RTO assumes 1 hr/wk. $11,432 $11,432 $11,432 $1,086 $11,432 $11,432

Maintenance materials 100% of maintenance labor $11,432 $11,432 $11,432 $1,086 $11,432 $11,432Electricity $41,386 $45,452 $17,247 $43,062 $52,147 $22,182Natural Gas $828,914 $426,951 $41,542 $102,600 --- ---Zeolite replacement --- --- $30,930 --- --- ---Catalyst Replacement --- $21,143 --- --- --- ---Steam --- --- --- --- $2,936 $0Cooling water --- --- --- --- $229 $0Carbon replacement --- --- --- --- $30,930 $1,823,176Condensate disposal --- --- --- --- $30,411 ---

Overhead

60% of operating, supervisor, and maintenance labor and maintenance materials

$13,719 $13,719 $20,890 $1,303 $20,890 $20,890

Taxes, insurance, administrative 4% total capital investment $30,605 $33,080 $30,816 $61,366 $49,996 $35,800Capital recovery $108,936 $112,305 $91,632 $218,430 $159,902 $118,400

Total Annual Cost $1,046,423 $675,515 $267,873 $428,933 $382,258 $2,055,265Control Efficiency of Equipment 98% 98% 98% 98% 98% 98%VOC Controlled 27.04 27.04 27.04 27.04 27.04 27.04$ per ton controlled 38,693$ 24,978$ 9,905$ 15,861$ 14,135$ 75,997$

Notes:

b Total capital investment based on 2007 vendor estimate for a 25,000 scfm system updated to 2015 dollars based on CEPCIs and scaled-down to 19,100 scfm based on the following formula: Cost19,100 = Cost25,000 * (19,100/25,000)0.6. Electricity and natural gas costs based on energy balance for system. Zeolite replacement costs assumed to be same as carbon replacement costs (replacement is less frequent than carbon systems but zeolite is significantly more expensive). Other annual costs are based on and EPA's CO$T-AIR spreadsheets updated from 1998 to 2015 costs based on CEPCI.

a Costs developed based on EPA's CO$T-AIR spreadhseets updated from 1998 to 2015 costs based on Chemical Engineering Plant Cost Indices (CEPCIs). These costs are expected to represent conservative estimates.

c Costs developed based on EPA's CO$T-AIR spreadsheets updated from 1998 to 2015 costs based on Chemical Engineering Plant Cost Indices (CEPCIs). Carbon usage rates determined based on input from carbon adsorption system vendors. For the on-site regeneration scenario, carbon is assumed to be regenerated via steam with pentane recovered through condensation. For the no regeneration scenario, carbon is assumed to be replaced with fresh material once depleted.



RTO Inputs 8/30/2016


Hours of Operation 8,760 hr/yrAnnual Emissions 27.60 tpyInlet Gas Temperature 80 FGross Heat of Combustion 20,908 BTU/lb VOC averageWaste Gas Heat Content 0.1151 BTU/scf VOC averageInlet Gas Temperature 80 FOperating Labor Rate 18.982 $/hrElectricity Price 0.066 $/kWhNatural Gas Price 6.255 $/mscf



Regenerative Thermal Oxidizers 8/30/2016

TOTAL ANNUAL COST SPREADSHEET PROGRAM--REGENERATIVE THERMAL OXIDIZERS

COST BASE DATE: December 1988 [1]

VAPCCI (Fourth Quarter 1998--FINAL): [ 109.2

INPUT PARAMETERS

-- Gas flowrate (scfm): 19067-- Reference temperature (oF): 77-- Inlet gas temperature (oF): 80-- Inlet gas density (lb/scf): 0.0739-- Primary heat recovery (fraction): 0.95-- Waste gas heat content (BTU/scf): 0.12-- Waste gas heat content (BTU/lb): 1.56-- Gas heat capacity (BTU/lb-oF): 0.255-- Combustion temperature (oF): 1450-- Heat loss (fraction): 0.01-- Exit temperature (oF): 149-- Fuel heat of combustion (BTU/lb): 21502-- Fuel density (lb/ft3): 0.0408

DESIGN PARAMETERS

Auxiliary Fuel Requirement (lb/min): 1.273 (scfm): 31.2

Total Gas Flowrate (scfm): 19098

TOTAL CAPITAL INVESTMENT ($) [3](Cost correlations range: 5000 to 500,000 scfm)

@ 85 % heat recovery--base: 0 ' ' ' --escalated: 0@ 95 % heat recovery--base: 994,523 ' ' ' --escalated: 1,456,677 2015 Dollars

============ ============ ============ ============ ============

ANNUAL COST INPUTS

Operating factor (hr/yr): 8760Operating labor rate ($/hr): 18.98Maintenance labor rate ($/hr): 20.88Operating labor factor (hr/sh): 0.00Maintenance labor factor (hr/wk): 1.00Electricity price ($/kwh): 0.066Natural gas price ($/mscf): 6.26Annual interest rate (fraction): 0.07Control system life (years): 10Capital recovery factor: 0.1424Taxes, insurance, admin. factor: 0.04Pressure drop (in. w.c.): 20.0

ANNUAL COSTS

Item Cost ($/yr) Wt. Factor W.F.(cond.)----------------------------------------------------------------------------------------Operating labor 0 0.000 ----Supervisory labor 0 0.000 ----Maintenance labor 1,086 0.003 ----Maintenance materials 1,086 0.003 ----Natural gas 102,600 0.247 ----Electricity 43,062 0.104 ----Overhead 1,303 0.003 0.008Taxes, insurance, administrative 58,267 0.140 ----Capital recovery (*) 207,398 0.500 0.640----------------------------------------------------------------------------------------Total Annual Cost 414,802 1.000 1.000


[1] Base total capital investment reflects this date.[2] VAPCCI = Vatavuk Air Pollution Control Cost Index (for regenerativethermal oxidizers) corresponding to year and quarter shown. Basetotal capital investment has been escalated to this date via VAPCCI andcontrol equipment vendor data.[3] Source: Vatavuk, William M. ESTIMATING COSTS OF AIR POLLUTION CONTROL. Boca Raton, FL: Lewis Publishers, 1990.

CEPCI1998 389.52015 570.5



CatOx Inputs 8/30/2016

Input ParametersTotal Gas Flow Rate 19,067 scfmCombustion Temperatur 900 °FHours of Operation 8,760 hr/yrAnnual Emissions 27.60 tpy

Gross Heat of Combustio 20,908 BTU/lb pentaneWaste Gas Heat Conten 0.1151 BTU/scfpentane

Operating Labor Rate 18.982 $/hrElectricity Price 0.066 $/kWhCatalyst price 952.05392 $/ft3

Natural Gas Price 6.255 $/mscf

Total Annual Cost 661,383 $/yrTotal Cost Per Ton 23,967 $/ton



CatOx 8/30/2016

TOTAL ANNUAL COST SPREADSHEET PROGRAM--CATALYTIC INCINERATORS (FIXED)

COST REFERENCE DATE: April 1988 [1]

VAPCCI (Fourth Quarter 1998--Final) 104.3

INPUT PARAMETERS

-- Gas flowrate (scfm): 19067-- Reference temperature (oF): 77-- Inlet gas temperature (oF): 80-- Inlet gas density (lb/scf): 0.0739-- Primary heat recovery (fraction) 0.70-- Waste gas heat content (BTU/scf) 0.12-- Waste gas heat content (BTU/lb): 1.56-- Gas heat capacity (BTU/lb-oF): 0.248-- Combustion temperature (oF): 900-- Preheat temperature (oF): 654-- Fuel heat of combustion (BTU/lb) 21502-- Fuel density (lb/ft3): 0.0408

DESIGN PARAMETERS


-- Total Gas Flowrate (scfm): 19197-- Catalyst Volume (ft3): 37.2

CAPITAL COSTS



-- Other (auxiliary equipment, etc. 0Total Equipment Cost--base: 336,205 ' ' ' --escalated: 555,204 2015 $Purchased Equipment Cost ($): 599,621Total Capital Investment ($): 749,526=========== =========== =========== =========== ===========

ANNUAL COST INPUTS

Operating factor (hr/yr): 8760Operating labor rate ($/hr): 18.98Maintenance labor rate ($/hr): 20.88Operating labor factor (hr/sh): 0.0Maintenance labor factor (hr/sh): 0.5Electricity price ($/kwh): 0.066Catalyst price ($/ft3): 952Natural gas price ($/mscf): 6.26Annual interest rate (fraction): 0.07Control system life (years): 10Catalyst life (years): 2Capital recovery factor (system): 0.1424Capital recovery factor (catalyst): 0.5531Taxes, insurance, admin. factor: 0.04Pressure drop (in. w.c.): 21.0

ANNUAL COSTS

Item Cost ($/yr) Wt. Factor W.F.(cond.)-----------------------------------------------------------------------------------Operating labor 0 0.000 ----Supervisory labor 0 0.000 ----Maintenance labor 11,432 0.017 ----Maintenance materials 11,432 0.017 ----Natural gas 426,951 0.646 ----Electricity 45,452 0.069 ----Catalyst replacement 21,143 0.032 ----Overhead 13,719 0.021 0.055Taxes, insurance, administrative 29,981 0.045 ----Capital recovery 101,273 0.153 0.198-----------------------------------------------------------------------------------Total Annual Cost 661,383 1.000 1.000

Annual Emissions (tpy) 28Total Cost Per Ton 23,967

[1] Original equipment costs reflect this date.

[2] VAPCCI = Vatavuk Air Pollution Control Cost Index (for catalyticincinerators) corresponding to year and quarter shown. Originalequipment cost, purchased equipment cost, and total capital investmenthave been escalated to this date via the VAPCCI and control equipmentvendor data.

CEPCI1998 389.52013 570.5



TOsm Inputs 8/30/2016

Input ParametersTotal Gas Flow Rate 19,067 scfmCombustion Temperatur 1,600 °F

Hours of Operation 8,760 hr/yrAnnual Emissions 27.60 tpy

Gross Heat of Combustio 20,908 BTU/lb pentaneWaste Gas Heat Conten 0.1151 BTU/scfpentane

Operating Labor Rate 18.982 $/hrElectricity Price 0.066 $/kWhNatural Gas Price 6.255 $/mscf

Total Annual Cost 1,032,291 $/yrTotal Cost Per Ton 37,408 $/ton



TOsm 8/30/2016

TOTAL ANNUAL COST SPREADSHEET PROGRAM--THERMAL INCINERATORS

COST BASE DATE: April 1988 [1]

VAPCCI (Fourth Quarter 1999--FINAL 110.5

INPUT PARAMETERS

-- Gas flowrate (scfm): 19067-- Reference temperature (oF): 77-- Inlet gas temperature (oF): 80-- Inlet gas density (lb/scf): 0.0739-- Primary heat recovery (fraction 0.70-- Waste gas heat content (BTU/scf 0.12-- Waste gas heat content (BTU/lb) 1.56-- Gas heat capacity (BTU/lb-oF): 0.255-- Combustion temperature (oF): 1600-- Preheat temperature (oF): 1144-- Fuel heat of combustion (BTU/lb 21502-- Fuel density (lb/ft3): 0.0408

DESIGN PARAMETERS

-- Auxiliary Fuel Reqrmnt (lb/min) 10.287 (scfm): 252.1

-- Total Gas Flowrate (scfm): 19319

CAPITAL COSTS



-- Other (auxiliary equipment, etc 0Total Equipment Cost--base: 251,611 ' ' ' --escalated: 509,360 2015 $Purchased Equipment Cost ($): 550,109Total Capital Investment ($): 687,636========== ========== ========== ========== ==========

ANNUAL COST INPUTS

Operating factor (hr/yr): 8760Operating labor rate ($/hr): 18.98Maintenance labor rate ($/hr): 20.88Operating labor factor (hr/sh): 0.0Maintenance labor factor (hr/sh): 0.5Electricity price ($/kwh): 0.066Natural gas price ($/mscf): 6.26Annual interest rate (fraction): 0.07Control system life (years): 10Capital recovery factor: 0.1424Taxes, insurance, admin. factor: 0.04Pressure drop (in. w.c.): 19.0

ANNUAL COSTS

Item Cost ($/yr Wt. Facto W.F.(cond.)---------------------------------------------------------------------------------Operating labor 0 0.000 ----Supervisory labor 0 0.000 ----Maintenance labor 11,432 0.011 ----Maintenance materials 11,432 0.011 ----Natural gas 828,914 0.803 ----Electricity 41,386 0.040 ----Overhead 13,719 0.013 0.035Taxes, insurance, administrative 27,505 0.027 ----Capital recovery 97,904 0.095 0.121--------------------------------------------------------- ------------------------Total Annual Cost 1,032,291 1.000 1.000

Annual Emissions (tpy) 28Total Cost Per Ton 37,408

[1] Original equipment costs reflect this date.[2] VAPCCI = Vatavuk Air Pollution Control Cost Index (for thermalincinerators) corresponding to year and quarter shown. Originalequipment cost, purchased equipment cost, and total capital investmenthave been escalated to this data via the VAPCCI and control equipment vendor data.

CEPCI1998 389.5

Feb-15 570.5







INPUT PARAMETERS:-- Inlet stream flowrate (acfm): 19426-- Inlet stream temperature (oF): 80-- Inlet stream pressure (atm): 1-- VOC to be condensed: PENTANE-- Inlet VOC flowrate (lb/hr): 10.9-- VOC molecular weight (lb/lb-mole): 72.15-- VOC inlet volume fraction: 5.108450E-05-- VOC inlet concentration (ppmv): 51-- VOC inlet partial pressure (psia): 0.0008-- Required VOC removal (fraction): 0.980-- Freundlich isotherm equation constants for VOC (see Table 1 below):

VOC number (enter Table 1 # or zero, if no data): 0 K: 0.000 M: 0.000

-- Yaws isotherm equation constants (see Table 2 below): VOC number (enter Table 2 #or zero, if no data): 213 Assumes n-butane as most similar to pentane

0.03071 0.34304 -0.01596


DESIGN PARAMETERS:-- Carbon equilibrium capacity--Freundlich (lb VOC/lb carb): 0.0000 " " " -- Yaws 0.0372-- Carbon working capacity (lb VOC/lb carbon): 0.0186-- Number of desorbing vessels: 2-- Total number of vessels: 4-- Carbon requirement, total (lb): 80000 Based on vendor data with redundant capacity-- Carbon requirement per vessel (lb): 20000 to allow for on-site regeneration-- Gas flowrate per vessel (acfm): 9713-- Adsorber vessel diameter (ft): 12.841-- Adsorber vessel length (ft): 9.148-- Adsorber vessel surface area (ft2): 628.05-- Carbon bed thickness (ft): 5.148-- Carbon bed pressure drop (in. w.c.): [5] 17.409

CAPITAL COSTSEquipment Costs ($):-- Adsorber vessels 162,881-- Carbon 112,000-- Other equipment (condenser, decanter, etc.) 155,359

Total equipment cost ($)--base: 430,240 ' ' ' ' --escalated: 718,832 2015 $ Includes an additional $2500 for Purchased Equipment Cost ($): 776,339 a 5,000-gal condensateTotal Capital Investment ($): 1,249,905 storage tank " " " ($/acfm): 64.3

ANNUAL COST INPUTS:Operating factor (hr/yr): 8760Operating labor rate ($/hr): 18.98Maintenance labor rate ($/hr): 20.88Operating labor factor (hr/sh): 0.5Maintenance labor factor (hr/sh): 0.5Electricity price ($/kWhr): 0.07Recovered VOC value ($/lb): 0.0000Steam price ($/1000 lb): 8.79Cooling water price ($/1000 gal): 0.29Carbon replacement labor ($/lb): 0.07Condensate transport & disposal cost ($/gal 0.60Overhead rate (fraction): 0.6Annual interest rate (fraction): 0.07Control system life (years): 10Capital recovery factor (system): 0.1424Carbon life (years): 5Capital recovery factor (carbon): 0.2439Taxes, insurance, admin. factor: 0.04

ANNUAL COSTS: Item Cost ($/yr) Wt. Factor W.F.(cond.)----------------------------------------------------------------------------- ------------------------Operating labor 10,393 0.027 ----Supervisory labor 1,559 0.004 ----Maintenance labor 11,432 0.030 ----Maintenance materials 11,432 0.030 ----Electricity 52,147 0.136 ----Steam 2,936 0.008 ----Cooling water 229 0.001 ----Carbon replacement 30,930 0.081 ----Condensate transport & disposal 30,411 0.080 40,113 gal water/yrOverhead 20,890 0.055 0.146 +Taxes, insurance, administrative 49,996 0.131 ---- 10,573 gal C5/yrCapital recovery 159,902 0.418 0.549----------------------------------------------------------------------------- ------------------------Total Annual Cost (without credits) 382,258 1.000 0.831Recovery credits 0Total Annual Cost (with credits) 382,258 " " " ($/milli 37.44










VOC VOC number K M Temperatur Minimum Maximum--------------------------------------------------------------------------------------------------------------------------Benzene 1001 0.597 0.176 77 0.0001 0.05Chlorobenzene 1002 1.05 0.188 77 0.0001 0.01Cyclohexane 1003 0.508 0.210 100 0.0001 0.05Dichloroethane 1004 0.976 0.281 77 0.0001 0.04Phenol 1005 0.855 0.153 104 0.0001 0.03Trichloroethane 1006 1.06 0.161 77 0.0001 0.04Vinyl chloride 1007 0.200 0.477 100 0.0001 0.05m-Xylene (low-pressure 1008 0.708 0.113 77 0.0001 0.001m-Xylene (high-pressure 1009 0.527 0.0703 77 0.001 0.05Acrylonitrile 1010 0.935 0.424 100 0.0001 0.015Acetone 1011 0.412 0.389 100 0.0001 0.05Toluene 1012 0.551 0.110 77 0.0001 0.05--------------------------------------------------------------------------------------------------------------------------[6] These constants fit the following equation:

Q = K(P)^M


************************************************************************************************************************** Table 2. Correlation Constants for Yaws Isother Correlation Ranges (ppmv)============================================================================================================== VOC VOC number A B C Minimum Maximum--------------------------------------------------------------------------------------------------------------------------Phosgene 6 -0.64469 0.60428 -0.02986 10 10000Carbon tetrachloride 9 1.07481 0.28186 -0.02273 10 10000Chloroform 11 0.67102 0.36148 -0.02288 10 10000Formaldehyde 18 -2.48524 0.69123 -0.00375 10 10000Methyl chloride 21 -1.91871 0.62053 -0.00549 10 10000Carbon disulfide 35 -0.18899 0.47093 -0.01481 10 10000Tetrachloroethylene 39 1.40596 0.20802 -0.02097 10 10000Vinyl chloride 55 -0.98889 0.66564 -0.04320 10 100001,1,2-Trichloroethane 59 1.17163 0.27791 -0.02746 10 10000Acetonitrile 60 -0.79666 0.63512 -0.02598 10 10000Methyl isocyanate 61 -1.07579 0.85881 -0.06876 10 10000Acetaldehyde 69 -1.17047 0.62766 -0.02475 10 10000Ethylene glycol 84 1.40474 0.18738 -0.02663 10 121Ethyl mercaptan 87 0.00552 0.40506 -0.01802 10 10000Acrylonitrile 93 0.07669 0.49986 -0.03500 10 10000Acrolein 97 -0.29632 0.49437 -0.02471 10 100001,3-Butadiene 168 -0.03359 0.34764 -0.01297 10 10000Methyl ethyl ketone 194 0.46525 0.37688 -0.02801 10 10000n-Butane 213 0.03071 0.34304 -0.01596 10 100001,2,4-Trichlorobenzene 331 1.68304 0.09456 -0.00998 10 566Chlorobenzene 336 1.02705 0.30619 -0.03353 10 10000Nitrobenzene 340 1.64859 0.06109 0 10 329Benzene 341 0.81119 0.28864 -0.02378 10 10000Phenol 345 1.45599 0.10349 -0.01086 10 10000Toluene 466 1.11466 0.20795 -0.02016 10 10000m-Cresol 469 1.61982 0.04926 0 10 149o-Toluidine 474 1.58104 0.05475 0 10 339Styrene 528 1.35701 0.13495 -0.01451 10 8044m-Xylene 533 1.31522 0.14019 -0.01457 10 10000o-Xylene 534 1.33404 0.13931 -0.01494 10 8722p-Xylene 535 1.31115 0.14069 -0.01458 10 10000







COST BASE DATE: Third Quarter 1989 [2]

VAPCCI (Fourth Quarter 1998--FINAL): [3] 102.5 CEPCI1998 389.5

INPUT PARAMETERS: 2015 570.5-- Inlet stream flowrate (acfm): 19426-- Inlet stream temperature (oF): 80-- Inlet stream pressure (atm): 1-- VOC to be condensed: PENTANE-- Inlet VOC flowrate (lb/hr): 10.9-- VOC molecular weight (lb/lb-mole): 72.15-- VOC inlet volume fraction: 5.108450E-05-- VOC inlet concentration (ppmv): 51-- VOC inlet partial pressure (psia): 0.0008-- Required VOC removal (fraction): 0.980-- Freundlich isotherm equation constants for VOC (see Table 1 below):


-- Yaws isotherm equation constants (see Table 2 below): VOC number (enter Table 2 #or zero, if no data): 213 Assumes n-butane as most similar to pentane

0.03071 0.34304 -0.01596


DESIGN PARAMETERS:-- Carbon equilibrium capacity--Freundlich (lb VOC/lb carb): 0.0000 " " " -- Yaw 0.0372-- Carbon working capacity (lb VOC/lb carbon): 0.0186-- Number of desorbing vessels: 2-- Total number of vessels: 4-- Carbon requirement, total (lb): 40000 Based on vendor assuming no on-site regeneration-- Carbon requirement per vessel (lb): 10000 and that fresh carbon would be brought-- Gas flowrate per vessel (acfm): 9713 on-site -- Adsorber vessel diameter (ft): 12.841-- Adsorber vessel length (ft): 6.574-- Adsorber vessel surface area (ft2): 524.22-- Carbon bed thickness (ft): 2.574-- Carbon bed pressure drop (in. w.c.): [5] 8.704

CAPITAL COSTSEquipment Costs ($):-- Adsorber vessels 141,517-- Carbon 56,000-- Other equipment (condenser, decanter, etc.) 0 No on-site regeneration assumed

Total equipment cost ($)--base: 309,152 ' ' ' ' --escalated: 514,726 2015 $Purchased Equipment Cost ($): 555,904Total Capital Investment ($): 895,005 " " " ($/acfm): 46.1

ANNUAL COST INPUTS:Operating factor (hr/yr): 8760Operating labor rate ($/hr): 18.98Maintenance labor rate ($/hr): 20.88Operating labor factor (hr/sh): 0.5Maintenance labor factor (hr/sh): 0.5Electricity price ($/kWhr): 0.07Recovered VOC value ($/lb): 0.0000Steam price ($/1000 lb): 8.79Cooling water price ($/1000 gal): 0.29Carbon replacement labor ($/lb): 0.07Overhead rate (fraction): 0.6Annual interest rate (fraction): 0.07Control system life (years): 10Capital recovery factor (system): 0.1424Carbon life (years): 5Capital recovery factor (carbon): 0.2439Taxes, insurance, admin. factor: 0.04

ANNUAL COSTS: Item Cost ($/yr) Wt. Factor W.F.(cond.)----------------------------------------------------------------------------------------------------Operating labor 10,393 0.005 ----Supervisory labor 1,559 0.001 ----Maintenance labor 11,432 0.006 ----Maintenance materials 11,432 0.006 ----Electricity 22,182 0.011 ----Steam 0 0.000 ---- No on-site carbon regenerationCooling water 0 0.000 ---- No on-site carbon regenerationCarbon replacement 1,823,176 0.887 ---- Carbon replacement cost assumes noOverhead 20,890 0.010 0.027 regeneration and a carbonTaxes, insurance, administrative 35,800 0.017 ---- replacement rate of 3567.86Capital recovery 118,400 0.058 0.075 lb/day per vendor data---------------------------------------------------------------------------- ------------------------Total Annual Cost (without credits) 2,055,265 1.000 0.113Recovery credits 0Total Annual Cost (with credits) 2,055,265 " " " ($/mill 201.29










VOC VOC number K M Temperature Minimum Maximum-----------------------------------------------------------------------------------------------------------------------------------------Benzene 1001 0.597 0.176 77 0.0001 0.05Chlorobenzene 1002 1.05 0.188 77 0.0001 0.01Cyclohexane 1003 0.508 0.210 100 0.0001 0.05Dichloroethane 1004 0.976 0.281 77 0.0001 0.04Phenol 1005 0.855 0.153 104 0.0001 0.03Trichloroethane 1006 1.06 0.161 77 0.0001 0.04Vinyl chloride 1007 0.200 0.477 100 0.0001 0.05m-Xylene (low-pressure 1008 0.708 0.113 77 0.0001 0.001m-Xylene (high-pressure 1009 0.527 0.0703 77 0.001 0.05Acrylonitrile 1010 0.935 0.424 100 0.0001 0.015Acetone 1011 0.412 0.389 100 0.0001 0.05Toluene 1012 0.551 0.110 77 0.0001 0.05-----------------------------------------------------------------------------------------------------------------------------------------[6] These constants fit the following equation:

Q = K(P)^M


***************************************************************************************************************************************** Table 2. Correlation Constants for Yaws Isothe Correlation Ranges (ppmv)============================================================================================================== VOC VOC number A B C Minimum Maximum----------------------------------------------------------------------------------------------------------------------------------------Phosgene 6 -0.64469 0.60428 -0.02986 10 10000Carbon tetrachloride 9 1.07481 0.28186 -0.02273 10 10000Chloroform 11 0.67102 0.36148 -0.02288 10 10000Formaldehyde 18 -2.48524 0.69123 -0.00375 10 10000Methyl chloride 21 -1.91871 0.62053 -0.00549 10 10000Carbon disulfide 35 -0.18899 0.47093 -0.01481 10 10000Tetrachloroethylene 39 1.40596 0.20802 -0.02097 10 10000Vinyl chloride 55 -0.98889 0.66564 -0.04320 10 100001,1,2-Trichloroethane 59 1.17163 0.27791 -0.02746 10 10000Acetonitrile 60 -0.79666 0.63512 -0.02598 10 10000Methyl isocyanate 61 -1.07579 0.85881 -0.06876 10 10000Acetaldehyde 69 -1.17047 0.62766 -0.02475 10 10000Ethylene glycol 84 1.40474 0.18738 -0.02663 10 121Ethyl mercaptan 87 0.00552 0.40506 -0.01802 10 10000Acrylonitrile 93 0.07669 0.49986 -0.03500 10 10000Acrolein 97 -0.29632 0.49437 -0.02471 10 100001,3-Butadiene 168 -0.03359 0.34764 -0.01297 10 10000Methyl ethyl ketone 194 0.46525 0.37688 -0.02801 10 10000n-Butane 213 0.03071 0.34304 -0.01596 10 100001,2,4-Trichlorobenzene 331 1.68304 0.09456 -0.00998 10 566Chlorobenzene 336 1.02705 0.30619 -0.03353 10 10000Nitrobenzene 340 1.64859 0.06109 0 10 329Benzene 341 0.81119 0.28864 -0.02378 10 10000Phenol 345 1.45599 0.10349 -0.01086 10 10000Toluene 466 1.11466 0.20795 -0.02016 10 10000m-Cresol 469 1.61982 0.04926 0 10 149o-Toluidine 474 1.58104 0.05475 0 10 339Styrene 528 1.35701 0.13495 -0.01451 10 8044m-Xylene 533 1.31522 0.14019 -0.01457 10 10000o-Xylene 534 1.33404 0.13931 -0.01494 10 8722p-Xylene 535 1.31115 0.14069 -0.01458 10 10000





RTO Conc Energy Balance 8/30/2016

Assumptions

Operating ScheduleDays/ Week 7 Concentrator Inlet Concentrator Exhaust

Weeks/ Year Operation 52 80 F 80 FDays/ Year Operation 365 days/yr 19,067 scfm 17,160 scfmHours/ Day Operation 24 hr/day 19,426 acfm 17,484 acfmTotal Operation Time 8,760 hr/yr 51 ppm THC 1.28 ppm THC

Days downtime 0 days/yr downtime 10.9 THC lb/hr 0.2 THC lb/hr

Utility CostsElectrical Cost $0.07 $/kWh - USD

Natural Gas Cost $6.26 $/1000 ft^3, USDBTU Content NG 920 LHV n.g., Btu/ft^3Compressed Air $0.37 $/1000 scf

Concentrator Inlet ConditionsAir Flow Rate 19,067 scfm Desorb Air

Air Temperature 80 deg F 80 FVOC Loading 10.9 lb/hr VOC 1,907 scfm

Calculated ppm 51.1 ppm based on lb/hr 1,943 acfmVOC Loading PPM Propane 3 ppm THC

Calculated lbVOC/hr 10.90 lb/hr VOC based on ppm 0.1 THC lb/hrAVG VOC Molecular Weight 72.15 mean VOC mw, g/mol RTO Thermal Balance

Energy Content of VOC's 20,908 mean VOC Btu/lb (T5-T6)/(T5-T1) = 90%DES Desorb Air - Heated T1 = 120

Rotary Concentrator Operating Conditions Air 400 F T5 = 1450 Oxidizer OutletConcentrator Pressure Drop 7 in wc Heater 1,907 scfm T6 = 253 253 F

Capture Efficiency 97.5% 3,094 acfm 1,907 scfmCombined Fan Efficiency 75% 3 ppm THC 2,565 acfmDesorber Fan Efficiency 75% 0.1 THC lb/hr 5 ppm THC

Desorber Heat Exchanger Eff 100% RegenrativeThermal Oxidizer 0.1 THC lb/hr

RTO Operating Conditions with Concentrator T1 1450 F T6RTO Thermal Effieciency 90% DES out 0.990 DE

RTO Pressure Drop 16 in wc 120 F Dp 16 in wcCombined Fan Efficiency 75% 1,907 scfm

Destruction Efficiency 99% System Operating Cost 2,087 acfmCombustion Temperature 1450 deg F 497 ppm THC

Burner Turndown Ratio 40 10.7 THC lb/hr

* All costs are in US dollars. RTO Fuel Requirement Q2 T6 T1 h Cp5 Oxidizer Burner Capacity Q2 T6 T1 Cp5Fn = (Q2Cp5*60*(T6-T1))-h Fn = (Q2Cp5*60*(T6-T1))Fn (calc) = 38,993 Btu/hr 1907 253 120 222,709 0.019271 Fn (calc) = 261,701 Btu/hr 1907 253 120 0.0192707Fn (Actual 38,993

DES Air Heater Q2 T5 T6 Cp5 System hydrocarbon removal efficiencyFn = (Q2Cp5*60*(T5-T6))/(Eff) SRE = (inlet lb/hr - outlet lb/hr)/inlet lb/hrFn = 658,501 Btu/hr 1907 400 80 0.017988 inlet lb/hr = 10.90

outlet lb/hr = 0.4Total = 697,494 Btu/hr SRE = 96.8%

Natural gasn.g. = (Btu/hr)(Btu/scf)($/1000scf)(hr operating/yr)n.g. = $41,542

ElectricityRTO = $3,713des = $1,230adsorb = $12,304Total = $17,247

Annual energy cost = USD$58,789

F

F

F Rotary

Concentrator



(800) 451-6027 • (317) 232-8603 • www.idem.IN.gov



Recycled Paper

SENT VIA U.S. MAIL: CONFIRMED DELIVERY AND SIGNATURE REQUESTED TO: Mr. George Schmalz New NGC, Inc. d/b/a National Gypsum Company 75 Ivy Lane Clinton, Indiana 47842 DATE: August 30, 2016 FROM: Matt Stuckey, Branch Chief Permits Branch Office of Air Quality SUBJECT: Final Decision FESOP – Significant Permit Revision 165-35908-00081 Enclosed is the final decision and supporting materials for the air permit application referenced above. Please note that this packet contains the original, signed, permit documents. The final decision is being sent to you because our records indicate that you are the contact person for this application. However, if you are not the appropriate person within your company to receive this document, please forward it to the correct person. A copy of the final decision and supporting materials has also been sent via standard mail to: Vasco Roma, ARCADIS OAQ Permits Branch Interested Parties List If you have technical questions regarding the enclosed documents, please contact the Office of Air Quality, Permits Branch at (317) 233-0178, or toll-free at 1-800-451-6027 (ext. 3-0178), and ask to speak to the permit reviewer who prepared the permit. If you think you have received this document in error, please contact Joanne Smiddie-Brush of my staff at 1-800-451-6027 (ext 3-0185), or via e-mail at [email protected].

Final Applicant Cover letter.dot 2/17/2016

mailto:[email protected]



(800) 451-6027 • (317) 232-8603 • www.idem.IN.gov



Recycled Paper

August 30, 2016 TO: Clinton Public Library From: Matthew Stuckey, Branch Chief Permits Branch Office of Air Quality Subject: Important Information for Display Regarding a Final Determination

Applicant Name: NGC, Inc. d/b/a National Gypsum Company Permit Number: 165-35908-00081 You previously received information to make available to the public during the public comment period of a draft permit. Enclosed is a copy of the final decision and supporting materials for the same project. Please place the enclosed information along with the information you previously received. To ensure that your patrons have ample opportunity to review the enclosed permit, we ask that you retain this document for at least 60 days. The applicant is responsible for placing a copy of the application in your library. If the permit application is not on file, or if you have any questions concerning this public review process, please contact Joanne Smiddie-Brush, OAQ Permits Administration Section at 1-800-451-6027, extension 3-0185.

Enclosures Final Library.dot 2/17/2016

FACSIMILIE OF PS Form 3877

Mail Code 61-53

IDEM Staff VBIDDLE 8/30/2016 New NGC Inc. d/b/a National Gypsum Company 165-35908-00081 FINAL

AFFIX STAMP HERE IF USED AS CERTIFICATE OF MAILING

Name and address of Sender ►

Indiana Department of Environmental Management Office of Air Quality – Permits Branch 100 N. Senate Indianapolis, IN 46204

Type of Mail:

CERTIFICATE OF MAILING ONLY

Line Article

Number Name, Address, Street and Post Office Address Postage Handing

Charges Act. Value (If Registered)

Insured Value

Due Send if COD

R.R. Fee

S.D. Fee S.H. Fee

Rest. Del. Fee Remarks

1 George Schmalz New NGC Inc. d/b/a National Gypsum Company 75 Ivy Lane Clinton IN 47842 (Source CAATS) VIA CERTIFIED MAIL USPS 2 Clinton City Council and Mayors Office 259 Vine Street Clinton IN 47842 (Local Official) 3 Vermillion County Health Department 257 Walnut Street Clinton IN 47842-2342 (Health Department) 4 Clinton Public Library 313 S 4th St Clinton IN 47842-2398 (Library) 5 Vermillion County Commissioners P.O. Box 190 Newport IN 47966 (Local Official) 6 J.P. Roehm PO Box 303 Clinton IN 47842 (Affected Party) 7 Vasco Roma ARCADIS U.S., Inc. 28550 Cabot Drive, Suite 500 Novi MI 48377 (Consultant) 8 9 10 11 12 13 14 15 Total number of pieces Listed by Sender

6 Total number of Pieces Received at Post Office

Postmaster, Per (Name of Receiving employee)

The full declaration of value is required on all domestic and international registered mail. The maximum indemnity payable for the reconstruction of nonnegotiable documents under Express Mail document reconstructing insurance is $50,000 per piece subject to a limit of $50, 000 per occurrence. The maximum indemnity payable on Express mil merchandise insurance is $500. The maximum indemnity payable is $25,000 for registered mail, sent with optional postal insurance. See Domestic Mail Manual R900, S913, and S921 for limitations of coverage on inured and COD mail. See International Mail Manual for limitations o coverage on international mail. Special handling charges apply only to Standard Mail (A) and Standard Mail (B) parcels.

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