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 101
Website: 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.)

Enclosure
Bryan 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 and Preventing 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 of tbe 

conditions and maximum allowable emission rates table (MAERT) of tbe 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 permit face to replace tbose currently attached to your permit. Please attach 

tbese to your permit. 

Your cooperation in tbis matter is appreciated. If you 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 of Air, 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 on recycled paper 
Mr. Steve Willis PE 

Page2 

March 20, 2014 

Re: Permit Number: 26080 

This action is taken under authority delegated by the Executive Director of the Texas 

Commission on Environmental Quality. 

Sincerely, 

Michael Wilson, P.E., Director 

Air Permits Division 

Office of Air 

Texas Commission on Environmental Quality 

MPW/js 

Enclosure 

cc: Air Quality Manager, Environmental Services Department, City of El 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 

Ceramic Wall and Floor Tile Manufacturing 

Located at El Paso, El Paso County, Texas 

Latitude 31° 57' 10" Longitude -106" 21' 19" 

Permit: 26080 

Revision 

Renewal Date: 

Date : 

--~D~ec,e"'m"'b"""erL2"'9~.~2,o""1"'5L_ 

__ _.M,.. ,.ar.,c""h'-'2"'0"'.~2.,0,!J1.,4t--___ 

__ 

_ 

~A-·~ 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 of Permit. A permit or permit amendment is automatically void if the holder fails to 

begin construction within 18 months of the date of issuance, 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 of up to 18 

months may be granted if the permit holder demonstrates that emissions from the facility will 

comply with all rules and regulations of the commission, the intent of the Texas Clean Air Act 

(TCAA), including protection of the public's health and physical property; and (b)(l)the permit 

holder is a party to litigation not of the permit holder's initiation regarding the issuance of the 

permit; or (b)(2) the permit holder has spent, or committed to spend, at least 10 percent of the 

estimated total cost of the project up to a maximum of $5 million. A permit holder granted an 

extension under subsection (b )(1) of this section may receive one subsequent extension if the permit 

holder meets the conditions of subsection (b)(2) of this section. [30 TAC 116.12o(a), (b) and (c)] 

3. Construction Progress. Start of construction, construction interruptions exceeding 45 days, and 

completion of construction shall be reported to the appropriate regional office of the commission 

not later than 15 working days after occurrence of the 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 of operations of the facilities authorized by the permit in such a manner that a 

representative of the commission may be present. The permit holder shall provide a separate 

notification for the commencement of operations for each unit of phased construction, which may 

involve a series of units commencing operations at different times. Prior to operation of the 

facilities authorized by the permit, the permit holder shall identify the source or sources of 

allowances to be utilized for compliance with Chapter 101, Subchapter H, Division 3 of this title 

(relating to Mass Emissions Cap and Trade Program). [30 TAC u6.115(b)(2)(B)(iii)] 

5. Sampling Requirements. If sampling 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 must be approved by the executive 

director and coordinated with the regional representatives of the 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 of Methods. The permit holder must demonstrate or otherwise justify the 

equivalency of emission control methods, sampling or other emission testing methods, and 

monitoring methods proposed as alternatives to methods indicated in the conditions of the permit. 

Alternative methods shall be applied for in writing and must be reviewed and approved by the 

executive director prior to their use in fulfilling any requirements of the permit. [30 TAC 

116.115(b)(2)(D)] 

7· Recordkeeping. The permit holder shall maintain a copy of the 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 of personnel from the commission or any air pollution control program having jurisdiction; 

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. Maximum Allowable Emission Rates. The total emissions of air contaminants from any of the 

sources of emissions 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 of Emission Control The permitted facilities shall not be 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 of this 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 of a permit by an applicant constitutes an acknowledgment 

and agreement that the permit holder will comply with all rules, regulations, and orders of the 

commission issued in conformity with the TCAA and the conditions precedent to the granting of the 

permit. If more than one state or federal rule or regulation or permit condition is applicable, the 

most stringent limit or condition shall govern and be the standard by which compliance shall be 

demonstrated. Acceptance includes consent to the entrance of commission 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 not be transferred, assigned, or conveyed by the 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 may be more restrictive than the requirements of Title 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) or violate THSC 382.085. If the 

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 or violation. 

14. The permit holder shall comply with all the requirements of this permit. Emissions that exceed the 

limits of this permit are not authorized and are violations of this permit. 

Revised (to/12) 2 
Emission Standards 

Special Conditions 

Permit Number 26o8o 

1. This permit authorizes those sources of emissions 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 of the Executive Director of the 

Texas Commission on Environmental Quality (TCEQ). (12j05) 

3. Upon request by the Executive Director ofthe TCEQ or any local air pollution control 

program having jurisdiction, the holder of this permit shall provide a sample and/ or an 

analysis of the 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 of the 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 of the U.S. EPA Regulations on 

Standards of Performance 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 of no visible emissions exceeding 30 seconds in duration in any 

six-minute period as determined using the U.S. EPA Test Method 22 or equivalent. If this 

condition is violated, additional controls or process changes may be required to limit 

visible particulate matter emissions. (o5j09) 

7· Opacity of particulate matter emissions from each Emission Point Number (EPN) listed on 

the MAERT shall not exceed 5 percent. Determination of compliance 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 from 
Special Conditions 

Permit Number 26o8o 

Page2 

the emission point. If visible 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. If the 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 of compliance with this requirement shall 

be performed and the 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 having jurisdiction, 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 of not 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/ or 
Special Conditions 

Permit Number 26o8o 

Page3 

environmentally sensitive chemicals upon detection of visible 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 

of on 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 of Compliance 

16. To demonstrate compliance with the MAERT and with emission performance levels as 

specified in the special conditions, the holder of this permit shall perform stack sampling 

and/ or other testing as required to establish the actual pattern and quantities of air 

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 of achieving maximum production but not later than 180 

days after the installation of Wet Scrubber 2 (EPN 32). Sampling must be conducted in 

accordance with the TCEQ Sampling Procedures Manual and in accordance with the 

applicable EPA 40 CFR procedures. Any deviations from those procedures must be 

approved by the TCEQ Executive Director prior to sampling. (03/14) 

Continuous Determination of Compliance 

17. Upon being informed by the TCEQ Executive Director that the staff has 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 of this 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 of this 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 of the 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 with jurisdiction. (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 of S02; 

C. Test Method 26, 26A, or 320 for the concentrations of HCl and HF; 

20. A pretest meeting shall be held with personnel from the TCEQ before the required tests are 

performed. The TCEQ Regional Office with jurisdiction 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 of firm conducting sampling; 

E. Type of sampling equipment to be used; and 

F. Method or procedure to be used in sampling. 

The purpose of the 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 by the 

permit holder. A written proposed description of any 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 must be 

approved by the TCEQ Regional Office with jurisdiction 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 of Air, Air Permits Division in Austin. (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 stack test. These parameters 

are to be determined at the pretest meeting. 

24. If the kilns are unable to operate at maximum rates during testing, then future production 

rates and other parameters may be 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 with jurisdiction. Additional time to comply with the applicable federal 

requirements requires EPA approval, and requests shall be submitted to the TCEQ 

Regional Office with jurisdiction. (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 of natural gas (fuel flow rate scf/minute or lb/hr); 

C. Outlet gas temperature (degrees Fahrenheit); 

D. Velocity of the exhaust gas (exit flow rate scfjminute or lb/hr); and, 

E. Temperature of the exhaust gas (degrees Fahrenheit). 

27. Copies of the 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 of the TCEQ Sampling Procedures Manual. The reports shall be distributed as 

follows: (03/14) 

One copy to the TCEQ Regional Office with jurisdiction. 

One copy to the TCEQ Office of Air, Air Permits Division in Austin. 

One copy to each appropriate local air pollution control program with jurisdiction. 

28. If, as a result of stack sampling, compliance with the permitted emission rates cannot be 

demonstrated, the holder of this permit shall adjust any operating parameters so as to 

comply with Special Condition No. 1 and the permitted emission rates. ( 03/14) 

29. If the holder of this permit is required to adjust any operating parameters for compliance, 

then beginning no later than 6o days after the date of the test conducted, the holder of this 

permit shall submit to the TCEQ, on a monthly basis, a record of adjusted operating 

parameters and records of production sufficient to demonstrate compliance with the 

permitted emission rates. Records of production and operating parameters shall be 

distributed as follows: (03/14) 
Special Conditions 

Permit Number 26080 

Page6 

One copy to the TCEQ Regional Office with jurisdiction. 

One copy to the TCEQ Office of Air, Air Permits Division in Austin. 

Recordkeeping Requirements 

30. The following records shall be maintained at this facility and made available at the request 

of personnel from the TCEQ, TCEQ El Paso Regional Office or any other air pollution 

control program having jurisdiction. These records shall be totaled for each calendar 

month, retained for a rolling 6o-month period, and include the following: (05/09) 

A. Records of individual daily production rates for each of the 12 kilns (in tons); 

(12/05) 

B. Monthly records of total 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 of total throughput for all dryers (in tons). From these records, an 

annual total shall be calculated on a rolling 12-month basis; (12/05) 

D. Quarterly observations for visible emissions and/or opacity determinations from 

stacks; (03/14) 

E. Records of scheduled cleaning and maintenance of the 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. 2014 
Emission 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 of the 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 of the 

facilities covered by this permit. 

Air Contaminants Data 

1 Raw Material PM 0.77 3·39 Unloading and 

Storage Baghouse PM10 0.77 3·39 Stack 

2 Scrap Tile Processing 

and Material 

PM 1.86 8.15 

Weigh/Feed 

Baghouse Stack PMw 1.86 8.15 

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: 206549 
Permit 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 <0.01 
Permit 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 3.26 
Permit 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 4·53 
Permit 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 of nitrogen 

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) of the Federal Clean Air Act or Title 40 Code of Federal 

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