From: Eric Astrachan <EAstrachan@tileusa.com> Sent: Friday, August 29, 2014 6:31 PM To: Tsirigotis, Peter; Fruh, Steve; Barnett, Keith; Telander, Jeff Cc: Jordan, Scott; Gianni Mattioli (gianni_mattioli@mohawkind.com); Jim Fanning; Barbara Goetz (Barbara_Goetz@mohawkind.com); Bob Hurt; AZapparoli@FlorimUSA.com; dhaynes@florimusa.com; Bruce.Pasfield@alston.com; 'Howard L. Gilberg (Gilberg@guidaslavichflores.com)'; Spooner, David (David.Spooner@btlaw.com) Subject: TCNA Letter

- No MACT Major Sources in Ceramic Tile Industry Segment 

### Dear Mr. Tsirigotis, Please find my letter attached advising that, as of August 27, 2014, there are no MACT major sources in the ceramic tile industry segment of the Clay Ceramics Manufacturing NESHAPs Category. TCNA renews its request, as detailed in the attached letter, that EPA exclude any MACT major source regulations for the ceramic tile manufacturing industry segment from its regulatory package that will be sent to OMB, and that it not otherwise propose or finalize such regulations. In advance of our Labor Day weekend, I hope you will have an enjoyable holiday. Best regards, Eric Astrachan Executive Director Tel: 864

-646

-8453 Extension 101Website: www.tileusa.com

. Literature: literature@tileusa.com

TILE COUNCIL OF NORTH AMERICA, INC. 100 Clemson Research Boulevard . Anderson, South Carolina 29625 . Phone: 864

-646

-8453 . Fax: 864

-646

-2821

Testing Services: testing@tileusa.com

. Literature Orders: literature@tileusa.com 

### August 29, 2014 By Email Mr. Peter Tsirigotis U.S. Environmental Protection Agency Office of Air Quality Planning and Standards Mail Code D205

-01 109 TW Alexander Drive Research Triangle Park, NC 27709 Dear Mr. Tsirigotis: This letter is written as previously promised, to advise that, as of August 27, 2014, there are no MACT major sources in the ceramic tile industry segment of the Clay Ceramics Manufacturing NESHAPs Category. The last of the five formerly MACT

-major facilities in this industry segment, the Dal

-Tile El Paso, Texas ceramic tile manufacturing plant, has now voluntarily achieved Area Source status (also commonly described as Synthetic Minor source status) at its substantial expense. A copy of its federally

-enforceable permit dated March 2014 is attached. The plant has now completed the required air emissions control equipment construction. EPA has previously confirmed to us that the other four formerly MACT

-major sources in this industry segment had already achieved Area Source status, so this work completes our industry effort. TCNA renews its request that EPA exclude any MACT major source regulations for the ceramic tile manufacturing industry segment from its regulatory package that will be sent to OMB, and that it not otherwise propose or finalize such regulations. EPA’s position, albeit oversimplified herein, has been that EPA is required to propose and finalize a MACT major source standard for ceramic tile manufacturers, because the industry segment had a MACT major source. We did not agree. However, EPA’s position based on the existence of a major source in the industry no longer applies, and we are therefore renewing our request. We see no reason to include MACT major source regulations for the ceramic tile manufacturing industry segment in the regulation package to be sent to OMB. We have previously presented our reasoning to you, your staff, and others.Letter to Mr. Peter Tsirigotis August 29, 2014 Page 2

TILE COUNCIL OF NORTH AMERICA, INC. 100 Clemson Research Boulevard . Anderson, South Carolina 29625 . Phone: 864

-646

-8453 . Fax: 864

-646

-2821

Testing Services: testing@tileusa.com

. Literature Orders: literature@tileusa.com 

### We acknowledge that EPA is legally required to satisfy the requirements of the Sierra Club v. EPA Consent Decree. EPA can do so while declining to propose or to finalize MACT major source regulations for ceramic tile manufacturing

. Thank you for your consideration of our renewed request.
Very truly yours, Tile Council of North America, Inc.

Eric Astrachan Executive Director

cc: Mr. Steve Fruh (w/encl.) Mr. Keith Barnett (w/encl.) Mr. Jeff Telander (w/encl.) Mr. Scott Jordan (w/encl.) Mr. Gianni Mattioli (w/encl.) Mr. Jim Fanning (w/encl.) Mr. Barbara Goetz (w/encl.) Mr. Bob Hurt (w/encl.) Mr. Arrigo Zapparoli (w/encl.) Mr. Don Haynes (w/encl.) Mr. Bruce Pasfield (w/encl.) Mr. Howard Gilberg (w/encl.) Mr. David Spooner (w/encl.)

EnclosureBryan W. Shaw, Ph.D., P.E., Chairman Toby Baker, Commissioner Zak Covar, Commissioner Richard A. Hyde, P.E., Executive Director



### TEXAS COMMISSION ON ENVIRONMENTAL QUALITY Protecting Texas by Reducing andPreventing Pollution

MR STEVE WILLIS PE SENIOR ENGINEER ENVIRONMENTAL HEALTH & SAFETY DAL-TILE CORPORATION 7834 C FHA WN FWY DALLAS TX 75217-6529

Re: Permit Alteration Permit Number: 26o8o Ceramic Wall and F1oor Tile Manufacturing El Paso, El Paso County Regulated Entity Number: RN100542976 Customer Reference Number: CN6oo128797 AccountNumber: EE-1471-Q Dear Mr. Willis: March 20, 2014

This is in response to your letter received February 24, 2014, requesting alteration oftbe conditions and maximum allowable emission rates table (MAERT) oftbe above-referenced permit. We understand that you plan to install two wet scrubbers on the kilns. We also understand that you request tbe Special Conditions be updated to better reflect the use of an existing wet scrubber to control spray dryer particulate matter emissions. Per Title 30 Texas Administrative Code§ n6.n6(c) [30 TAC § n6.n6(c)] and based on our review, Permit Number 26o8o is altered. Enclosed are the altered special conditions, altered MAERT, and new permitface to replace tbose currently attached to your permit. Please attach tbese to your permit. Your cooperation in tbis matter is appreciated. Ifyou need further information or have any questions, please contact Mr. Joel Stanford at (512) 239-0270 or write to tbe Texas Commission on Environmental Quality, Office ofAir, Air Permits Division, MC-163, P.O. Box 13087, Austin, Texas 78711-3087.

P.O. Box 13087 • Austin, Texas 78711-3087 • 512-239·1000 • tceq.texas.gov How is our customer service? tceq.texas.govjcustomersurvey printed onrecycled paperMr. Steve Willis PE Page2 March 20, 2014 Re: Permit Number: 26080

This action is taken under authority delegated by the Executive Director ofthe Texas Commission on Environmental Quality. Sincerely,

Michael Wilson, P.E., Director Air Permits Division Office ofAir Texas Commission on Environmental Quality MPW/js Enclosure

cc: Air Quality Manager, Environmental Services Department, City ofEl Paso, El Paso Air Section Manager, Region 6 - El Paso Project Number: 206549

### TEXAS COMMISSION ON ENVIRONMENTAL QUALITY AIR QUALITY PERMIT A Permit Is Hereby Issued To Dal-Tile Corporation 

### Authorizing the Construction and Operation of CeramicWall and Floor Tile Manufacturing 

### Located at El Paso, El Paso County, Texas Latitude 31° 57' 10" Longitude -106" 21' 19" Permit: 26080

# ~A-·~ Revision Date : __ _.M,..**,.ar.,c""h'-'2"'0"'.~2.,0,!J1.,4t--** ___ _ Renewal Date:**--~D~ec,e"'m"'b"""erL2"'9~.~2,o""1"'5L_**__ For the Commission 1. 

### Facilities covered by this permit shall be constructed and operated as specified in the application for the permit. All representations regarding construction plans and operation procedures contained in the permit application shall be conditions upon which the permit is issued. Variations from these representations shall be unlawful unless the permit holder first makes application to the Texas Commission on Environmental Quality (commission) Executive Director to amend this permit in that regard and such amendment is approved. [Title 30 Texas Administrative Code 116.116 (30 TAC 116.116)] 2. 

### Voiding ofPermit. A permit or permit amendment is automatically void ifthe holder fails to begin construction within 18 months ofthe date ofissuance, discontinues construction for more than 18 months prior to completion, or fails to complete construction within a reasonable time. Upon request, the executive director may grant an 18-month extension. Before the extension is granted the permit may be subject to revision based on best available control technology, lowest achievable emission rate, and netting or offsets as applicable. One additional extension ofup to 18 months may be granted ifthe permit holder demonstrates that emissions from the facility will comply with all rules and regulations ofthe commission, the intent ofthe Texas Clean Air Act (TCAA), including protection ofthe public's health and physical property; and (b)(l)the permit holder is a partyto litigation not ofthe permit holder's initiation regarding the issuance ofthe permit; or (b)(2) the permit holder has spent, or committed to spend, at least 10 percent ofthe estimatedtotal cost ofthe project up to a maximum of $5 million. A permit holder granted an extension under subsection (b)(1) ofthis section may receive one subsequent extension ifthe permit holder meets the conditions ofsubsection (b)(2) ofthis section. [30 TAC 116.12o(a), (b) and (c)] 3. 

### Construction Progress. Start ofconstruction, construction interruptions exceeding 45 days, and completion ofconstruction shall be reported to the appropriate regional office ofthe commission not later than 15 working days after occurrence ofthe event. [30 TAC 116.115(b)(2)(A)] 

### 4. Start-up Notification. The appropriate air program regional office shall be notified prior to the commencement ofoperations ofthe facilities authorized bythe permit in such a manner that a representative ofthe commission may be present. The permit holder shall provide a separate notification for the commencement ofoperations for each unit ofphased construction, which may involve a series ofunits commencing operations at different times. Prior to operation ofthe facilities authorized bythe permit, the permit holder shall identify the source or sources of allowances to be utilized for compliance with Chapter 101, Subchapter H, Division 3 ofthis title (relating to Mass Emissions Cap and Trade Program). [30 TAC u6.115(b)(2)(B)(iii)] 5. 

### Sampling Requirements. Ifsampling is required, the permit holder shall contact the commission's Office of Compliance and Enforcement prior to sampling to obtain the proper data forms and procedures. All sampling and testing procedures mustbe approved bythe executive director and coordinated with the regional representatives ofthe commission. The permit holder is also responsible for providing sampling facilities and conducting the sampling operations or contracting with an independent sampling consultant. [30 TAC 116.115(b)(2)(C)]

Revised (1oj12)6. 

### Equivalency ofMethods. The permitholder must demonstrate or otherwisejustify the equivalency ofemission control methods, sampling or other emission testing methods, and monitoring methods proposed as alternatives to methods indicated in the conditions ofthe permit. Alternative methods shall be applied for in writing and mustbe reviewed and approved bythe executive director prior to their use in fulfilling any requirements ofthe permit. [30 TAC 116.115(b)(2)(D)] 7· 

### Recordkeeping. The permit holder shall maintain a copy ofthe permit along with records containing the information and data sufficient to demonstrate compliance with the permit, including production records and operating hours; keep all required records in a file at the plant site. If, however, the facility normally operates unattended, records shall be maintained at the nearest staffed location within Texas specified in the application; make the records available at the request ofpersonnel from the commission or any air pollution control program havingjurisdiction; comply with any additional recordkeeping requirements specified in special conditions attached to the permit; and retain information in the file for at least two years following the date that the information or data is obtained. [30 TAC n6.115(b)(2)(E)] 8. 

### MaximumAllowable Emission Rates. The total emissions of air contaminants from any ofthe sources ofemissions must not exceed the values stated on the table attached to the permit entitled "Emission Sources--Maximum Allowable Emission Rates." [30 TAC 116.115(b)(2)(F)] 9. 

### Maintenance ofEmission Control The permitted facilities shall notbe operated unless all air pollution emission capture and abatement equipment is maintained in good working order and operating properly during normal facility operations. The permit holder shall provide notification for upsets and maintenance in accordance with 30 TAC 101.201, 101.211, and 101.221 ofthis title (relating to Emissions Event Reporting and Recordkeeping Requirements; Scheduled Maintenance, Startup, and Shutdown Reporting and Recordkeeping Requirements; and Operational Requirements). [30 TAC u6.115(b)(2)(G)] 10. 

### Compliance with Rules. Acceptance ofa permit by an applicant constitutes an acknowledgment and agreement that the permit holder will comply with all rules, regulations, and orders ofthe commission issued in conformity with the TCAA and the conditions precedent to the granting ofthe permit. 

### Ifmore than one state or federal rule or regulation or permit condition is applicable, the most stringent limit or condition shall govern andbe the standardbywhich compliance shall be demonstrated. Acceptance includes consent to the entrance ofcommission employees and agents into the permitted premises at reasonable times to investigate conditions relating to the emission or concentration of air contaminants, including compliance with the permit. [30 TAC u6.us(b)(2)(H)] 11. 

### This permit may notbe transferred, assigned, or conveyed bythe holder except as provided by rule. [30 TAC u6.uo(e)] 12. 

### There may be additional special conditions attached to a permit upon issuance or modification of the permit. Such conditions in a permit maybe more restrictive than the requirements ofTitle 30 of the Texas Administrative Code. [30 TAC 116.115(c)] 13. 

### Emissions from this facility must not cause or contribute to a condition of "air pollution" as defined in Texas Health and Safety Code (THSC) 382.003(3) orviolate THSC 382.085. Ifthe executive director determines that such a condition or violation occurs, the holder shall implement additional abatement measures as necessary to control or prevent the condition orviolation. 14. 

### The permit holder shall comply with all the requirements ofthis permit. Emissions that exceed the limits ofthis permit are not authorized and are violations ofthis permit.

Revised (to/12) 2

### Emission Standards Special Conditions Permit Number 26o8o

1. This permit authorizes those sources ofemissions listed in the attached table entitled "Emission Sources -Maximum Allowable Emission Rates," and those sources are limited to the emission rates and other conditions specified in the table. In addition, this permit authorizes all emissions from planned startup and shutdown activities associated with facilities or groups offacilities that are authorized by this permit. (o1j14) 

### Fuel Specifications 2. Fuel for the kilns, tile dryers, and spray dryers shall be pipeline-quality sweet natural gas. Use of any other fuel shall require prior written approval ofthe Executive Director ofthe Texas Commission on Environmental Quality (TCEQ). (12j05) 3. Upon request by the Executive Director ofthe TCEQ or any local air pollution control program havingjurisdiction, the holder ofthis permit shall provide a sample and/or an analysis ofthe fuel(s) utilized in these facilities or shall allow air pollution control program representatives to obtain a sample for analysis. (12/05) 

### Federal Applicability 4. These facilities shall comply with applicable requirements ofthe U.S. Environmental Protection Agency (EPA) Regulations on National Emission Standards for Hazardous Air Pollutants in Title 40 Code of Federal Regulations (40 CFR) Part 63 promulgated for Clay Ceramics Manufacturing, Subparts A and KKKKK. (12/05) 5. These facilities shall comply with applicable requirements ofthe U.S. EPA Regulations on Standards ofPerformance for New Stationary Sources in 40 CFR Part 60 promulgated for Nonmetallic Mineral Processing Plants, Subparts A and 

### 000. Opacity /Visible Emission Limitations 6. No visible emissions shall leave the plant property boundary. Visible emissions shall be determined by a standard ofno visible emissions exceeding 30 seconds in duration in any six-minute period as determined using the U.S. EPA Test Method 22 or equivalent. 

### Ifthis condition is violated, additional controls or process changes may be required to limit visible particulate matter emissions. (o5j09) 7· Opacity ofparticulate matter emissions from each Emission Point Number (EPN) listed on the MAERT shall not exceed 5 percent. Determination ofcompliance with this requirement shall be made by first observing for visible emissions during normal plant operations. Observations shall be made at least 15 feet and no more than 0.25 mile fromSpecial Conditions Permit Number 26o8o Page2

the emission point. Ifvisible emissions are observed from the emission point, the owner or operator shall: (03/14) A. Assume the 5 percent opacity limit is exceeded, take immediate action to eliminate visible emissions, record the corrective action within 24 hours, and comply with any applicable requirements in 30 Texas Administrative Code (TAC) § 101.201, Emissions Event Reporting and Record Keeping Requirements; or B. Determine opacity using 40 CFR Part 6o, Appendix A, Test Method 9. Ifthe 5 percent opacity limit is exceeded, take immediate action to eliminate visible emissions, record the corrective action within 24 hours, and comply with applicable requirements in 30 TAC § 101.201, Emissions Event Reporting and Record Keeping Requirements. Contributions from uncombined water vapor shall not be included in determining compliance with this condition. Determination ofcompliance with this requirement shall be performed andthe results recorded quarterly. Operational Limitations, Work Practices, and Plant Design 8. Glaze and other raw materials used or stored at this facility shall not contain lead other than in trace amounts. Upon request by the TCEQ Executive Director or any local air pollution control program havingjurisdiction, documehtation from an independent thirdparty testing laboratory must be provided to verify the lead content in the glazes and other raw materials. (11/07) 9· Fabric filter baghouses, designed to meet an outlet grain loading ofnot more than o.o1 grains/dry standard cubic feet (gr/dscf), properly installed and in good working order, shall control particulate matter emissions from Raw Material Unloading and Storage, Scrap Tile Processing and Material Weigh/Feed, Screening/Pressing, Glaze Prep/Tile Glazing, Body Material Storage, Crusher and Screening, and Tile Glazing operations (EPNs 1-4, 13, 23, 27, and 28). (11/07) 10. A wet scrubber (EPN 11), properly installed and in good working order, shall control particulate matter emissions from the spray dryer when this equipment is in operation. (03/14) 11. A wet scrubber (EPN 31), properly installed and in good working order, shall control hydrogen fluoride, hydrogen chloride, and sulfur dioxide emissions from the Kilns 1-6 when this equipment is in operation. (03/14) 12. A wet scrubber (EPN 32), properly installed and in good working order, shall control hydrogen fluoride, hydrogen chloride, and sulfur dioxide emissions from the Kilns 7-12 when this equipment is in operation. (03/14) 13. All in-plant roads shall be paved with a cohesive hard surface which can be cleaned by sweeping or washing. All other roads and stockpiles shall be sprinkled with water and/orSpecial Conditions Permit Number 26o8o Page3 environmentally sensitive chemicals upon detection ofvisible particulate emissions to maintain compliance with all TCEQ rules and regulations. (12j05) 14. Spillage of any raw products or waste products shall be cleaned up and properly disposed ofon a daily basis. (12/05) 15. Emission limits for the facility are based on and the facility is limited to the following: (11/07)



### Source Name Maximum Hourly Maximum Annual Clay/Tile Throughput Clay/Tile Throughput (Tons/Hour) (Tons/Year) Bisque Kiln (combined; Kiln 13-36 

### ---- Nos. 1-6) Gloss Kiln (combined; Kiln 13.80


### ---- Nos. 7-12) Total Annual Kiln



### ---- 237.922 Spray Dryer 19-30 169,068 Tile Dryers (combined; Tile 15.00 131,400 Dryer Nos 1-6) 

### Initial Determination ofCompliance 16. To demonstrate compliance with the MAERT and with emission performance levels as specified in the special conditions, the holder ofthis permit shall perform stack sampling and/or other testing as required to establish the actual pattern and quantities ofair contaminants being emitted into the atmosphere from the Wet Scrubber 2 (Kilns 7-12) (EPN 32). Air contaminants to be tested for include (but are not limited to) hydrogen chloride (HCI), hydrogen fluoride HF, and sulfur dioxide (S02). Sampling shall be accomplished within 6o days ofachieving maximum productionbut not later than 180 days after the installation ofWet Scrubber 2 (EPN 32). Sampling must be conducted in accordance with the TCEQ 

### SamplingProceduresManual and in accordance with the applicable EPA 40 CFR procedures. Any deviations from those procedures mustbe approved by the TCEQ Executive Director prior to sampling. (03/14) 

### Continuous Determination ofCompliance 17. Upon being informed by the TCEQ Executive Director that the staffhas documented visible emissions from the tile dryers, the roller kilns, the kiln scrubber stacks, all baghouse stacks, or the scrubber stacks exceeding 5 percent opacity, when adjusted for uncombined water vapor, averaged over six consecutive minutes, the holder ofthis permit may be required to conduct stack sampling analyses or other tests to prove satisfactory equipment performance and demonstrate compliance with this permit. (03/14)

### Special Conditions Permit Number 26080 Page4 Sampling Requirements 18. The holder ofthis permit is responsible for providing sampling and testing facilities and conducting the sampling and testing operations at their own expense. Sampling ports and platforms shall be incorporated into the design ofthe stack(s) according to the specifications set forth in the attachment entitled "Chapter 2, Stack Sampling Facilities" prior to stack sampling. Alternate sampling facility designs may be submitted for approval by the TCEQ Regional Office withjurisdiction. (12j05) 

### 19. Sampling shall be conducted in accordance with the TCEQ Sampling Procedures Manual and EPA Test Methods in 40 CFR Part 6o, Appendix A, and 40 CFR Part 51, Appendix M, as follows: (03/14) A. 

### Test Methods 1 through 4, as appropriate, for exhaust flow, diluent, and moisture concentration; B. Test Method 6c or 320 for the concentration ofS02; C. Test Method 26, 26A, or 320 for the concentrations ofHCl and HF; 20. A pretest meeting shall be held with personnel from the TCEQ before the required tests are performed. The TCEQ Regional Office withjurisdiction shall be notified not less than 45 days prior to sampling to schedule a pretest meeting. The notice shall include: (11/13) A. 

### Date for pretest meeting; B. Date sampling will occur; C. Points or sources to be sampled; D. Name offirm conducting sampling; E. 

### Type of sampling equipment to be used; and F. Method or procedure to be used in sampling. The purpose ofthe pretest meeting is to review the necessary sampling and testing procedures, to provide the proper data forms for recording pertinent data, and to review the format procedures for submitting the test reports. 21. Alternate sampling methods and representative unit testing may be proposed bythe permit holder. A written proposed description ofany deviation from sampling procedures or emission sources specified in permit conditions or TCEQ or EPA sampling procedures shall be made available to the TCEQ prior to the pretest meeting. Such a proposal mustbe approved by the TCEQ Regional Office withjurisdiction at least two weeks prior to sampling. (03/14) 

### 22. Requests to waive testing for any pollutant specified shall be submitted, in writing, for approval to the TCEQ Office ofAir, Air Permits Division inAustin. (12/05)Special Conditions Permit Number 26080 Pages

23. During stack sampling emission testing, the facilities shall operate at maximum represented production rates. Primary operating parameters that enable determination of production rates shall be monitored and recorded during the stacktest. These parameters are to be determined at the pretest meeting. 24. Ifthe kilns are unable to operate at maximum rates during testing, then future production rates and other parameters maybe limited to the rates established during testing. Without exceeding permitted maximum production rates, additional stack testing shall be required when production rates exceed by 10 percent those rates previously achieved for testing. (12/05) 25. Requests for additional time to perform sampling shall be submitted to the TCEQ Regional Office withjurisdiction. Additional time to comply with the applicable federal requirements requires EPA approval, and requests shall be submitted to the TCEQ Regional Office withjurisdiction. (12j05) 26. The sampling report shall include (but is not limited to) the following: (03/14) A. Kiln production rates during tests (ton/hour); B. Consumption rates ofnatural gas (fuel flow rate scf/minute or lb/hr); C. Outlet gas temperature (degrees Fahrenheit); D. Velocity ofthe exhaust gas (exit flow rate scfjminute or lb/hr); and, E. Temperature ofthe exhaust gas (degrees Fahrenheit). 27. Copies ofthe final sampling report shall be forwarded to the TCEQ within 6o days after sampling is completed. Sampling reports shall comply with the attached provisions of Chapter 14 ofthe TCEQ 

### Sampling Procedures Manual. The reports shall be distributed as follows: (03/14) One copy to the TCEQ Regional Office withjurisdiction. One copy to the TCEQ Office ofAir, Air Permits Division inAustin. One copy to each appropriate local air pollution control program withjurisdiction. 28. If, as a result of stack sampling, compliance with the permitted emission rates cannotbe demonstrated, the holder ofthis permit shall adjust any operating parameters so as to comply with Special Condition No. 1and the permitted emission rates. (03/14) 29. Ifthe holder ofthis permit is required to adjust any operating parameters for compliance, then beginning no later than 6o days after the date ofthe test conducted, the holder ofthis permit shall submit to the TCEQ, on a monthly basis, a record of adjusted operating parameters and records ofproduction sufficient to demonstrate compliance with the permitted emission rates. Records ofproduction and operating parameters shall be distributed as follows: (03/14)Special Conditions Permit Number 26080 Page6

One copy to the TCEQ Regional Office withjurisdiction. One copy to the TCEQ Office ofAir, Air Permits Division in Austin. Recordkeeping Requirements 30. The following records shall be maintained at this facility and made available at the request ofpersonnel from the TCEQ, TCEQ El Paso Regional Office or any other air pollution control program havingjurisdiction. These records shall be totaled for each calendar month, retained for a rolling 6o-month period, and include the following: (05/09) A. Records ofindividual daily production rates for each ofthe 12 kilns (in tons); (12/05) B. Monthly records oftotal throughput for the spray dryer associated with the wet scrubber (EPN 11). From these records, an annual total shall be calculated on a rolling 12-month basis (in tons); (12/05) C. Monthly records oftotal throughput for all dryers (in tons). From these records, an annual total shall be calculated on a rolling 12-monthbasis; (12/05) D. Quarterly observations for visible emissions and/or opacity determinations from stacks; (03/14) E. Records ofscheduled cleaning and maintenance ofthe abatement equipment; and (12/05) F. Safety Data Sheets required by Occupational Safety and Health Administration for all raw materials including clays, fillers, and glazing materials. (05/09)

Date: March 20. 2014Emission Sources- Maximum Allowable Emission Rates Permit Number 26080 This table lists the maximum allowable emission rates and all sources of air contaminants on the applicant's property covered by this permit. The emission rates shown are those derived from information submitted as part ofthe application for permit and are the maximum rates allowed for these facilities, sources, and related activities. Any proposed increase in emission rates may require an application for a modification ofthe facilities covered by this permit. Air Contaminants Data

1 Raw Material PM 0.77 3·39 Unloading and Storage Baghouse PM 10 0.77 3·39 Stack 2 Scrap Tile Processing and Material PM 1.86 8.15 Weigh/Feed 

### PMw 1.86 8.15 Baghouse Stack 3 Screening/Pressing Baghouse Stack PM 2.06 9·04 

### PMw 2.06 9·04 4 Glaze Prep/Tile PM 0.57 2.51 Glazing Baghouse Stack 

### PMw 0.57 2.51 5 Tile Dryer Line No. 2 Stack PM 0.08 0.33 

### PMw 0.08 0.33 VOC 0.15 o.65 NOx 0.05 0.22 

# co 0.75 3.26 

# so2 <0.01 <0.01 HF(5) <0.01 <0.01 HCl (5) <0.01 <0.01 6 Dryer Line No. 1 Stack PM 0.08 0.33 

### PMw 0.08 0.33 VOC 0.15 o.65

Project Number: 206549Permit Number 26080 Page2

6

11

13

14

Project Number: 206549 Emission Sources- Maximum Allowable Emission Rates

Tile Dryer Line No. 1 Stack NOx 

# co so2 HF(5) HCl (5) Spray Dryer Scrubber PM Stack 

### PMw 

# voc NOx 

# co so2 HF(5) HCl (5) Body Material PM Storage Baghouse Stack 

### PMw Tile Dryer Line No. 4 PM Stack 

### PMw 

# voc NOx 

# co so2 HF(5) HCl (5) 0.05 0.22 0.75 3.26 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

5-97 26.14 5-97 26.14 0.29 1.26 2.30 10.05 0.39 1.69 0.01 0.03 0.58 2.53 0.04 0.17 0.63 2.75 0.63 2-75 0.08 0.33 0.08 0.33 0.15 o.65 0.05 0.22 0.75 3.26 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01Permit Number 26080 Page3

15

20

23

24

Project Number: 206549 Emission Sources

- Maximum Allowable Emission Rates

Tile Dryer Line No. 3 Stack

NOx 

# co so2 HF(5) HCl (5) Tile Dryer Line No. 5 PM Stack 

### PMw 

# voc NO, 

# co so2 HF(5) HCl (5) Screening/Pressing PM Baghouse Stack 

### PMw Tile Dryer Line No. 6 PM Stack 

### PMw 

# voc NO, 

# co 0.08 0.33 0.08 0.33 0.15 o.65 0.05 0.22 0.75 3.26 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

0.08 0.33 0.08 0.33 0.15 o.65 0.05 0.22 0.75 3.26 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

0.68 2.96 0.68 2.96 0.07 0.33 0.07 0-33 0.15 o.65 0.05 0.22 0.74 3.26Permit Number 26o8o Page4

24

27

28

31

32

Project Number: 206549 Emission Sources

- Maximum Allowable Emission Rates

Tile Dryer Line No. 6 

# so2 Stack HF(5) HCl (5) Crusher and PM Screening Baghouse Stack 

### PMw PM 

### PMw Scrubber 1 Stack PM (Kilns 1-6) 

### PMw

NOx 

# co so2 HF(5) HCl (5) Wet Scrubber 2 Stack PM (Kilns 7-12) 

### PMw

NOx 

# co so2 HF(5)
HCl (5) <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

1.63 7·17 1.63 7·17 0.13 0.57 0.13 0.57 3·94 17.26 3·94 17.26 0.31 1.38 6.90 30.23 5·33 23.34 10.02 43.89 12.16 2.58 3·74 4·39 2.64 11.54 2.64 11.54 0-40 1.75 4-48 19.68 1.93 8-46 10.35 45·33 12.15 2.66

3·74 4·53Permit Number 26080 Pages Emission Sources

- Maximum Allowable Emission Rates

(1) Emission point identification- either specific equipment designation or emission point number from plot plan. (2) Specific point source name. For fugitive sources, use area name or fugitive source name. (3) VOC

- volatile organic compounds as defined in Title 30 Texas Administrative Code§ 101.1 NO,

- total oxides ofnitrogen S02

- sulfur dioxide PM

- total particulate matter, suspended in the atmosphere, including 

### PMw and PM2. 5 , as represented 

### PMw

- total particulate matter equal to or less than 10 microns in diameter, including PM2. 5, as represented CO

- carbon monoxide HF

- hydrogen fluoride HCl

- hydrogen chloride (4) Compliance with annual emission limits (tons per year) is based on a 12 month rolling period. (5) Hazardous Air Pollutant as listed in § 112(b) ofthe Federal Clean Air Act or Title 40 Code ofFederal Regulations Part 63, Subpart C. (6) Planned startup and shutdown emissions are included. Maintenance activities are not authorized by this permit.

Date: March 20, 2014

Project Number: 206549