Dal Italia Response to EPA 03/12/10 ICR

Enclosure 1 - Startup and shutdown events

1. Facility Information

A. Facility ID:
DALT-1

B. Facility Name: Dal Italia Muskogee Manufacturing

C. Facility Address:
3801 Daltile Road Muskogee, Oklahoma 74401

D. Mailing Address:
Same

E. Latitude and longitude coordinates:
35 0 42’ 18.27” N
95 0 23’ 05.48” W

The following apply to startup and shutdow n that resulted in exceedances of permit
conditions at the source or portion of the source.

2. Startup and shutdown events over the past three years 2007-2009

The three (3) files includ ed on this CD-Rom identified as 2007, 2008, and 2009 Excess
Emissions Forms and Demonstration of Cause Fo rms contain the periodic and immediate startup and shutdown reports required by and submitted to the Oklahoma Department of Environmental Quality (ODEQ) for the years 2007, 2008, and 2009. The information included in these forms reported to the ODEQ contain the detailed information that is requested in Sections A though G
of Item 2 of Enclosure 1 of the ICR.

As a point of clarification, in 2008 the ODEQ changed the reporting requirements for excess emissions. Starting with the excess emission even t that occurred at Dal Italia on 02/098/08, a Demonstration of Cause form was also submitted in addition to the Excess Emission Report
Form.

Startup/Shutdown Information: Dal Italia Contact bob.hurt@daltile.com 214.309.4891 Page 1 of 4Further, on February 20, 2009 Dal Italia submitte d a Title V Air Permit amendment to include emissions during shutdown events in the perm it. The ODEQ had previously issued a policy statement that if a complete and approvable appl ication to permit these “excess” emissions was submitted prior to January 2010, the applicant w ould be allowed to operate under the limits requested in the permit until such time that th e DEQ makes a final determination regarding the proposed limits and amended the permit. Dal Italia’s application was deemed complete and approvable when the ODEQ completed their tec hnical review of the permit application on 07/01/09 and thus was allowed to stop submitting excess emissions reports at that time. Nevertheless, Dal Italia continue d to track the emissions during the periods of shutdown and all
such events are included in the 2009 Excess Emissi ons and D of C Forms files. Those forms for events after 07/01/09 were not submitted to the ODEQ per the Agencies policy.

In addition to the details provided in the Excess Emissions and D of C Forms, Dal Italia also provides the following specific responses to the in formation requested in Sections A through J.

2.A. Every event listed in the 2007, 2008, and 2009 fi les was a shutdown event. In our Title V Air Permit, Wet Scrubber 1 is listed as the so urce, EPN 20, and is associated with Tile
Kiln 1 and Tile Kiln 2. The Wet Scrubber 1 is sometimes referred to as Phase 1 on the
Excess Emissions forms. Wet Scrubber 2 is listed as the source, EPN 29, and is
associated with Tile Kiln 3 and Tile Kiln 4. It is sometimes referred to as Phase 2 on the
Excess Emissions forms.

In each event, one or both of the wet scrubbers ceased to operate, resulting in an exceedance of a permit condition, i.e., the emissions limit for that specific EPN.

Some Excess Emissions forms include two even ts for two sources on the same form, as the occurred on the same day.

2.B. A description of each event, including the sources associated with the shutdown, is provided in the Excess Emission Forms in cluded in the 2007, 2008, and 2009 files. The sources are generally identified as Wet Scrubber 1 or Wet Scrubber 2..

2.C. The permit condition that was exceeded is listed in each individual Excess Emission Form. In every case, it is “Specific Condition 1, EUG 5”.

2.D. None of the events were covered by a conti ngency plan. No such plan is required by the ODEQ

2.E. The duration of each event is provided in the individual Excess Emission Forms.

. 2.F. The actions taken to minimize emissions during the events are documented in the
individual Excess Emissions forms and indi vidual Demonstration of Cause Reports.

2.G. The excess emissions during each event ar e listed in the individual Excess Emission
Forms.

Startup/Shutdown Information: Dal Italia Contact bob.hurt@daltile.com 214.309.4891 Page 2 of 42.H. The emission profile of each unit (source) is very different during shutdown of the wet scrubber than it is during normal operations . The rate of emissions hydrogen fluoride, hydrogen chloride and free chlorine are all significantly higher dur ing periods of time
when the wet scrubber is shut down.

2.I. Dal Italia does have perf ormance test data during peri ods of shut down of the wet scrubbers. Results of sampling conducted in April and May of 2005 are representative of emissions during periods of shutdown. The result s of those tests are included in the files
identified <WS Downtime Exhaust Em issions Sampling_042105> and <WS Downtime Exhaust Emissions Sampling_051905>.

The data on April 21, 2005 was fr om stack tests of emissions from Tile Kiln 1 and Tile Kiln 2 during a shutdown event of Wet Sc rubber 1. The tests were conducted during normal operations, but with the Wet Scrubbe r shut down. The data from May 19, 2005
was from a stack test on the inlet of Wet Sc rubber 1, which would be representative kiln emissions during a shutdown event. This te st was conducted on the combined emissions
from Tile Kiln 1 and Tile Kiln 2. The test was conducted during normal operations of the kilns. Production data during th e both of these stack test is included the file identified as (WS Downtime Sampling 2005_Production Data>. This production information is not being claimed as Confidential Business Info rmation because it is over 5 years old.

The above tests were used to develop emissi ons factors that were (and are) used to
calculate the amount of excess emissions during wet scrubber shutdown events.

2.J. No monitoring data is maintained for th e Wet Scrubber operating parameters during WS
shutdown events.

3. Startup and shut down plan

Dal Italia is not required to de velop a startup and shutdown plan.

4. Recommended Standard dur ing APCD Shutdown Events

Dal Italia is currently working w ith the other tile manufacturing companies that also received an ICR for their major source facilities. Dal Italia believes that a separa te MACT Standard is needed because the emissions rates are significan tly different during peri ods of shutdown of the control device. The intent is to develop a jo int industry position for proposed language for such
a Standard. In the event that a joint proposal is not established, Dal Italia reserves the right to
submit a recommendation at a later date.

Startup/Shutdown Information: Dal Italia Contact bob.hurt@daltile.com 214.309.4891 Page 3 of 4Startup/Shutdown Information: Dal Italia Contact bob.hurt@daltile.com 214.309.4891 Page 4 of 4 Dal Italia EPA ICR Response
Enclosure 1 Files

<2007 Excess Emission Forms_Dal Italia.pdf>

Excess Emissions forms submitted to the Oklahoma Department of Environmental Quality (ODEQ) during the year of 2007

71 Excess Emissions Forms
75 events

<2008 Excess Emission and D of C Forms_Dal Italia.pdf>

Excess Emission forms and Demonstration of Cause forms submitted to the Oklahoma Department of Environmental Qua lity (ODEQ) during the year of 2008

76 Excess Emissions Forms
71 Demonstration of Cause Forms
82 events

<2009 Excess Emission and D of C Forms_Dal Italia.pdf>

Excess Emission forms and Demonstration of Cause forms submitted to the Oklahoma Department of Environmental Qua lity (ODEQ) during the year of 2009

70 Excess Emissions Forms
35 Demonstration of Cause Forms
73 events

<WS Downtime Exhaust Emissions Sampling_042105.pdf>

Sampling of Kiln 1 and sampling of Kiln 2 during a period when Wet Scrubber 1 was
shut down.

<WS Downtime Exhaust Emissions Sampling_051905.pdf>

Test results from sampling of the inlet of Wet Scrubber 1. Kiln 1 and Kiln 2 were operating normally and at full production during this test.

<WS Downtime Sampling 2005_Production Data.pdf>

Kiln 1 Production Record April; 21, 2005 Kiln 2 Production Record April; 21, 2005 Kiln 1 Production Record May 19, 2005 Kiln 2 Production Record May 19, 2005