3801 Dal-Tile Rd. Muskogee, OK 74401 918 683-4152 (Fax) 918 683-0043 (Voice) 

### DAL-TILE

El Paso Ceramic Wall Tile Plant

VIA FEDERAL EXPRESS

August 24, 2012



### Mr. Jeffery Telander U.S. EPA Mailroom (D243-02) U.S. Environmental Protection Agency

Office of 

### Air Quality Planning and Standards

109 T.W. Alexander Drive Research Triangle Park, NC 27711

Re: Dal-Tile Corporation, El Paso Wall Tile Plant Response 

### to Information Collection Request dated March 12, 2010

Dear 

### Mr. Telander:

This correspondence provides additional Dal-Tile responses to the Information Collection Request dated March 12, 2010 (ICR) from Mr. Peter Tsirigo tis, Director – Sector Policies and Programs Division. As requested in the ICR, all response ar e provided in electronic format and included on the CD-Rom disc enclosed with this letter. For reference purposes, a copy of this cover letter is also
included on the CD-Rom in the folder labeled as “1_Cover Letter – Dal-Tile/El Paso”.

Request #1

• Startup and shutdown events at all of your clay ceramics manufacturing facilities, as

described in Enclosure 1.

The Dal-Tile/El Paso facility does not have control equipment on the emissions from the kilns. Therefore, none of the information requested is available.

With regard to Request 4 of Enclosure #1, Dal Italia LLC is not providing recommended language for a Startup-Shutdown MACT Standard at this time. We are currently working with other tile companies that received a similar ICR in an effort to develop an Industry position for the proposed language for such a Standard. When completed, the recommended Standard will be provided to EPA by Mr. Howard Gilberg, counsel to the Tile Council of North America (TCNA).

Request # 2

• Emissions test data for

 hydrogen fluoride, hydrochloric acid, metals, dioxins/furans, and particulate matter (PM) from

the kilns listed in Enclosure 2.

 metals and PM from the kilns listed in Enclosure 2.

 dioxins/furans from the tile dryers and spray dryers listed in Enclosure 2.Mr. Jeff Telander August 24, 2012 Page 2 of 2

The emissions sam pling and reporting of results for testing at the Dal-Tile/El Paso plant was completed by ENTEC Services Inc. ENTEC submitted the results using the Electronic Reporting Tool, as specified by the ICR, on 08/10/12. As sp ecified in Enclosure #3 of the ICR, electronic copies of the reports of emissions testing results are also provided on the enclosed CD-Rom disc.

<1_Dal-Tile_El Paso_ERT_Test Plan & Results_signed 082312> provides a PDF copy of the ERT submission for the results of Methods 5, 23, and 29. Since the ERT does not support Test Method 320, those results are provided separately (see below).

<2_Dal-Tile_ELP_ENTEC Final Report> provides a PDF copy of the entire ENTEC written report covering both testing events. The Spray Dryer was tested separately at a later date due to identification of cyclonic flow on the first test date.

<3_Dal-Tile_ELP_WESTERN Final Report Oct-2003> provides a PDF copy of the written report of sampling of the El Paso kilns emissions using Test Method 320. This historical data is deemed representative because there have been no changes in the raw materials or the process operations.

<4_Dal-Tile_ELP_WESTERN Final Report Dec-2003> provides a PDF copy of the written report of sampling of the El Paso kilns emissions using Test Method 320 simultaneous with Test Method 26A. This historical data is deemed representative because there have been no changes in the raw materials or the process operations.

Since the ERT does not support TM 320, the ICR states that the HF and HCl results should be reported in a Microsoft Excel Emission Test Template that can be downloaded from the website: http//icr2010.rti.org . However, following links at that address to the Clay Ceramics page returned only the message “Welcome to the Clay Ceramics page!” and did not provide any templates. If the results of the Method 320 & 26A testing are desired in another format besides these PDF files, please provide the appropriate files/templates.

The production and operating data during the time of these tests is considered to be Confidential Business Information and therefore is being submitted under separate cover to Mr. Roberto Morales, Document Control Officer for the EPA-OAQPS.

Should you have questions concerning any of this in formation, please feel free to contact me at any time (214.309.4891 or bob.hurt@daltile.com ).

Regards,

Robert Hurt Director – Environmental, Health & Safety

Enclosure (CD-Rom)

3801 Dal-Tile Rd. Muskogee, OK 74401 918 683-4152 (Fax) 918 683-0043 (Voice)