                                       
MEMORANDUM

Date:		June 6, 2013

Subject:	Report of May 30, 2013 Site Visit to Essroc, Logansport, IN

From:		Tanya Parise, EC/R Incorporated
		
To:		Mary Tom Kissell, U.S. Environmental Protection Agency



      This memo summarizes the site visit to the Essroc facility in Logansport, IN, which was conducted on May 30, 2013.  The purposes of this visit were to:
      
          * Enhance understanding of current processes and emission controls for the off-site waste and recovery operations (OSWRO) at the facility. 
          * Gain an understanding of the other applicable Clean Air Act regulations for the facility, including 40 CFR 264, 265, 279 and 40 CFR Parts 60, 61 and 63.
          * Clarify any questions the U.S. EPA has regarding the response received from the recent information collection request for this facility.

	The participants in the site visit included the following:

      Essroc.
      David A. Constant  -  Senior Environmental Engineer 
      Sara Leeman  -  Environmental Manager
      
      US EPA
      Mary Tom Kissell
      
      EC/R Incorporated 
      Lesley Stobert
      Tanya Parise
      
This memo includes a brief overview of this project, an overview of the Essroc facility, and is followed by a description of the specific information gathered during the visit.  

BACKGROUND
      
      Section 112 of the Clean Air Act (CAA) establishes a two-stage regulatory process to address emissions of hazardous air pollutants (HAP) from stationary sources. In the first stage, CAA section 112(d) requires us to promulgate technology-based national emission standards for each major source category listed under section 112(c).  These technology-based standards are often referred to as maximum achievable control technology, or MACT, standards.  The National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Off- Site Waste and Recovery Operations were promulgated on July 1, 1996 (61 FR 34140), and codified at 40 CFR part 63, subpart DD. The final rule was amended on July 20, 1999 (64 FR 38950).  
      
      In the second stage of the regulatory process, the EPA is then required under CAA section 112(d)(6) to review these technology-based standards and revise them "as necessary (taking into account developments in practices, processes, and control technologies)" no less frequently than every eight years. In addition, within 8 years after promulgation of the MACT standards, CAA section 112(f)(2) requires the EPA to promulgate standards, if required, to provide an ample margin of safety to protect public health or to prevent, taking into consideration costs, energy, safety, and other relevant factors, an adverse environmental effect.
This second stage in standard setting is referred to as the residual risk and technology review (RTR) for the standards.

      The EPA is in the process of conducting the RTR for the OSWRO MACT standards. As part of the RTR process, this Essroc production facility was selected for a site visit for three primary reasons: (1) it is one of several OSWRO facilities in or near the Chicago, IL area, which would enable the EPA to see several facilities in one trip, (2) based on available emissions data in the EPA's National Emissions Inventory (NEI), this facility had one of the higher emission rates of the OSWRO facilities identified in that database, and (3) visiting this facility would allow the EPA to view a facility that handles waste, but whose primary line of business is not waste management, and to learn how waste is utilized in the cement production industry.

PLANT SITE OVERVIEW
      
      The Essroc Cement Corporation facility is located at 3084 West County Road 225 South, Logansport, IN. The Logansport Essroc facility is a cement production company that has been in business for 75 years. This cement manufacturing facility acquires limestone on site, which is then crushed in various steps. The raw materials are then mixed and ground with water (i.e., wet process) to generate a slurry mixture which is then fed to a kiln. The kiln heats the material to extremely high temperatures and moves the material through the kiln. During the process some material separates out as gases and the remaining material develops into the product called clinker. The clinker is then ground and cooled and subsequently mixed with gypsum to produce Portland cement.   
      
      The plant handles and integrates waste received from off-site sources into facility operations as a fuel source for the kiln. The kiln itself is the primary control device at the Essroc facility and the goal is to have the kiln running 90 percent of the time. According to Essroc representatives, the inside of the kiln is lined with a refractory shell to protect the metal from the high temperatures, and the kiln has to be shut down sometimes to protect the kiln shell. In the event the kiln is non-operational, the facility uses carbon beds as the backup control device for the non-kiln operations, including the OSWRO storage tanks. According to Essroc representatives, operations at Essroc are profitable and there are no plans to modernize the facility from the wet process to a dry process in the next 5-10 years.
      
      The operations are continuous, with operations occurring 24 hours a day, 7 days a week. The facility receives waste from several businesses (more than 80). This facility is subject to the OSWRO MACT (subpart DD), the Hazardous Waste Combustor MACT (subpart EEE), the Portland Cement MACT (subpart LLL), and also the Resource Conservation and Recovery Act (RCRA) regulations. 

INFORMATION GATHERED DURING VISIT

	The following section describes the information gathered in relation to the three stated purposes of the visit. 

   1. Enhance understanding of current processes and emission controls for the off-site waste and recovery operations (OSWRO) at the facility. 

         * The facility uses diesel fuel to start up the kiln, but then switches to burning waste fuel in the kiln. 
         * The facility receives waste in containers by trailer trucks, tanker trucks and by railcar.
         * Essroc receives waste in liquid, solid, and sludge form. The liquid waste is primarily waste solvents containing mostly organic liquids.
         * The solid and sludge waste the facility receives consists of gelled resins, paint pigments, rubber-based materials, wood, silica, clay, and solid still bottoms (i.e., tar).
         * Prior to being burned in the kiln, the facility tests the waste fuel for various properties. The fuel is analyzed to ensure it complies with the kiln fuel specifications. 
         * The waste fuel heating value is the primary concern. 
         * There are limits on the properties that cannot be fed to the kiln (e.g., high concentrations of metals).
         * The rotary kiln is the primary control device at the facility, with carbon beds as the backup. 

   2. Gain an understanding of the other applicable Clean Air Act regulations for the facility, including 40 CFR 264, 265, 279 and 40 CFR Parts 60, 61 and 63.
            
         * The facility complies with the OSWRO MACT (subpart DD), the Hazardous Waste Combustor MACT (subpart EEE), the Portland Cement MACT (subpart LLL), and also the Resource Conservation and Recovery Act (RCRA) regulations.

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