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: 

350

 42’ 18.27” N 

 95 0 23’ 05.48” W 

The following apply to startup and shutdown 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 included on this CD-Rom identified as 2007, 2008, and 2009 Excess 

Emissions Forms and Demonstration of Cause Forms 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 event 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 4 
Further, on February 20, 2009 Dal Italia submitted a Title V Air Permit amendment to include 

emissions during shutdown events in the permit. The ODEQ had previously issued a policy 

statement that if a complete and approvable application to permit these “excess” emissions was 

submitted prior to January 2010, the applicant would be allowed to operate under the limits 

requested in the permit until such time that the 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 technical 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 continued to track the emissions during the periods of shutdown and all 

such events are included in the 2009 Excess Emissions 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 information requested in Sections A through J. 

2.A. Every event listed in the 2007, 2008, and 2009 files was a shutdown event. In our Title V 

Air Permit, Wet Scrubber 1 is listed as the source, 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 events 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 included 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 contingency 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 individual Demonstration of Cause Reports. 

2.G. The excess emissions during each event are listed in the individual Excess Emission 

Forms. 

Startup/Shutdown Information: Dal Italia Contact bob.hurt@daltile.com 214.309.4891 Page 2 of 4 
2.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 during periods of time 

when the wet scrubber is shut down. 

2.I. Dal Italia does have performance test data during periods 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 results of those tests are included in the files 

identified <WS Downtime Exhaust Emissions Sampling_042105> and <WS Downtime 

Exhaust Emissions Sampling_051905>. 

The data on April 21, 2005 was from stack tests of emissions from Tile Kiln 1 and Tile 

Kiln 2 during a shutdown event of Wet Scrubber 1. The tests were conducted during 

normal operations, but with the Wet Scrubber shut down. The data from May 19, 2005 

was from a stack test on the inlet of Wet Scrubber 1, which would be representative kiln 

emissions during a shutdown event. This test 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 the 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 Information because it is over 5 years old. 

The above tests were used to develop emissions 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 the Wet Scrubber operating parameters during WS 

shutdown events. 

3. Startup and shut down plan 

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

4. Recommended Standard during APCD Shutdown Events 

Dal Italia is currently working with the other tile manufacturing companies that also received an 

ICR for their major source facilities. Dal Italia believes that a separate MACT Standard is 

needed because the emissions rates are significantly different during periods of shutdown of the 

control device. The intent is to develop a joint 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 4 
Startup/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 Quality (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 Quality (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