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 Tsirigotis, Director – Sector Policies and Programs 

Division. As requested in the ICR, all response are 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 sampling 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 specified 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 information, 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)