### Commonwealth of Kentucky Division for Air Quality 

# P ERMIT 

# S TATEMENT 

# O F 

# B ASIS

(DRAFT) Title V, Operating Permit: V-09-016 Dal-Tile Corporation Lewisport, KY 42351 August 15, 2009 Durga Patil, Reviewer

SOURCE ID : 21-091-00001 AGENCY INTEREST: 1623 ACTIVITY : APE20090002



### S OURCE 

### D ESCRIPTION 

### :

Dal-Tile Corporation applied for a permit ame ndment to its State origin S-99-088 permit in September 2005. Preliminary review of the applica tion showed that the permit currently held by the facility was S-05-050 and so the Kentucky Divisi on for Air Quality (Division) requested an explanation on this issue and comp leted application forms for every significant emission point at the facility. From the application and past correspondence, it was also evident that the facility could be major source and needed a Conditional Major or T itle V permit. Also the emissions inventory system did not match the current permit for the facility. Based on these recommendations by the Division, on April 11, 2008 Dal-Tile provided an application with the DEP 7007AI, DEP 7007 N and DEP7007V forms. On July 24, 2008 the facility decided to withdraw the forms submitted on April 11, 2008 in response to a Division letter da ted March 18, 2008 requesting these forms. The facility had plans to conduct stack tests and develop new emission factors and then resubmit the forms. The present application incorporates the re sults of the stack testi ng conducted on July 15, 2008 and November 15, 2008 and was submitted as a re vision to the State Origin permit on January 29, 2009. Review of the applicati on showed that the potential to emit of a single hazardous air pollutant (hydrogen fluoride) was greater than 10 tons/year. As a result, the facility has applied for a Title V permit on April 20, 2009.

The facility is considered a Title V major sour ce based on its uncontrolled potential emissions (PTE) of Hydrogen Fluoride (HF). The emissions of all other regulated air pollutants are below major source thresholds.

The Lewisport plant manufactures quarry tile from clay, shale, sand and various color and binder additives. Clay, shale, sand, wast e fired tile and additives are put into the feed hopper. The ratios vary according to the product being manufactured. The hopper feeds a pan crusher. The output of the crusher is screened by size with the oversized ma terial being returned to the crusher. The sized material is sent to storage. There are 3 pr oduction lines – Lines 23, 24 and 25. For Lines 23 and 24, the sized mixture of raw materials is mixed w ith water in a pugmill/extruder. The mixture is extruded and the output is cut into green tiles of various shapes and sizes. For Line 25, the sized material is sent to presses and pressed into green tiles of various shapes and sizes.Permit Statement of Basis Page 2 of 6 Permit: V-09-016

The green tiles from Lines 23 and 24 go to a Natu ral Gas-Fired Dryer 027. After drying, nearly 90% of the tiles are sent directly to the kilns wit hout any coating; 7.5% of the tiles receive water and manganese chloride coating; and 2.3% of the tiles receive water, manganese chloride, cobalt chloride and sodium acetate coating prior to preh eating. The green tiles from Line 25 are dried in Dryer 025. Approximately 4% of the tiles receive a glaze coating prior to firing.

Dried green tiles from Lines 23 a nd 24 are sent to preheat chambers 23 and 24 and then to Tunnel Kilns 23 and 24 for firing. The final product is quarry tile. The preheat chambers use waste heat to preheat the tile, but also have a natural gas burner to supplement the waste heat if needed. Dried green tile from Line 25 goes to Roller Kiln 25 for firing, the final product being the pavers.

Fired tiles from Kilns 23 and 24 undergo a grinding operation to smooth the edges and corners.

Table 1: Historical Dal-Tile (Lewis port Mfg.) Emissions Inventory Sources

KyEIS Number Description Classification Date Permitted by

001 Material Preparation Line 23 (listed as 21 and 22) After July 2, 1975 9/22/05 amendment application

003* Kiln 21 Prior to July 2, 1975 Permit O-73-187 004* Kiln 22 Prior to July 2, 1975 Permit O-73-187

005 Material Preparation Line 25 After July 2, 1975 Permit S-05-050

006 Material Preparation Line 24 Prior to July 2, 1975 Permit O-73-187 007 Kiln 23 Prior to July 2, 1975 Permit O-73-187 008 Kiln 24 Prior to July 2, 1975 Permit O-73-187

009 Finished Tile Edge Grinding Prior to July 2, 1975 1/05/05 amendment application 025 Dryer 25 After July 2, 1975 Permit S-05-050 026 Kiln 25 After July 2, 1975 Permit S-05-050

027 Tile Dryer for Kilns 23, 24 After July 2, 1975 1/05/05 amendment application submitted, determined by Division in 2005 to be insignificant and would not be added in the permit or in the emissions inventory

029 Line 25 press baghouse After July 2, 1975 1/05/05 amendment application submitted, determined by Division in 2005 to be insignificant and would not be added in the permit or in the emissions inventory * decommissioned in 2005 and salvaged for partsPermit Statement of Basis Page 3 of 6 Permit: V-09-016

History:

• December 28, 1973, this location under the name ofAmerican Olean, was issued Air Permit O73-187 to manufacture quarry tile. Kentucky Emi ssions Inventory System (KEIS) numbers 001, 002, 003, 004, 006, 007 and 008 were in existence at this time.

• December 4, 1988, The Permit Review Branch of th e Division conducted a review and issued a letter ID 077-1580-0001, indicating this plant did not need any additional air permits to operate.

• December 19, 1994 American Olean was purchased by Dal-Tile.

• September 17, 1999 Air Permit S-99- 088 to construct and operate additional sources was issued. The application was submitted to install a new line consisting of a new dryer and kiln. The application included: Raw Material Receiving; Truck load out, stockpiles, haul road and yard area; Raw Material Preparation KYEIS 005 (Line 25); Feed hoppers, screening, crushing – baghouse; Natural Gas Fired Dryer/Kiln 25; Dryer KYEIS 025; and Kiln KYEIS 026.

• August 11, 2004 an application to renew Permit S-99-088 was submitted.

• January 5, 2005, an amendment application for Permit S-99-088 was submitted. It included: One new dryer (KYEIS 027) to replace 4 existing dryers (KYEIS 002); A new baghouse (KYEIS 009) to replace an exis ting Finished Tile Edge Grinding baghouse (KYEIS 009); and Relocation of the existing grinder baghouse to be a baghouse (KYEIS 029) for an existing operating Line 25 tile pressing.

• April 11, 2005 Air Permit S-99-088 was renewed a nd the Permit Number changed to S-05-050.

• September 22, 2005 an amendment application was submitted. It included: Dust collector (KYEIS 001) added to the Raw Ma terial Preparation Line 23. This application referred to the old Permit Number S-99-088 by mistake.

Table 2 below lists the emission points and the maximum process rates presently at the facility.Permit Statement of Basis Page 4 of 6 Permit: V-09-016

Table 2: Emissions points/process rates at the facility
Emission

Point Process Name Basis for PTE Construction Date 01 (01) Raw Material Preparation for Line 23 5.6 tons per hour July 1969 05 (05) Raw Material Preparation for Li ne 25 7.5 tons per hour before July 1975 06 (06) Raw Material Preparation for Line 24 7.5 tons per hour July 1969
07 (07) Natural Gas-Fired Tunnel Kiln 23 - 2.6mmBtu/hr 1.98 tons/hr fired tile July 1969

08 (08) Natural Gas-Fired Tunnel Kiln 24 - 2.6 mmBtu/hr 1.98 tons/hr fired tile July 1969

09 (09) Finished Tile Edge Grinding 4.7 tons fired tile /hour July1,1969; new baghouse installed March 2005
025 (025) Natural Gas-Fired Dryer for Kiln 25 - 1.8 mmBtu/hr 1.75 tons/hour of fired tile July 1999

026 (026) Natural Gas-Fired Roller Kiln 25 - 7.3 mmBtu/hr 1.75 tons/hr fired tile September 1999

027 (027) Natural Gas-Fired Dryer for Kilns 23, 24 - 9.5 mmBtu/hr 3.96 tons/hour of fired tile March 2005

029 (029) Tile Press baghouse 2.5 tons/hour of blended raw material July 1969

Table 3: Operating and emission limits for the emission points

Emission

Point Affected Facility Maximum allowable emission rate (lb/hr) Maximum Throu g hput (lbs/hr) Overall Control Efficiency Maximum Controlled Emissions

(lb/hr)
01 (01) Raw Material Preparation for Line 23 13.0 11,200 99% 0.48

05 (05) Raw Material Preparation for Line 25 15.82 15,000 99% 0.64

06 (06) Raw Material Preparation for Line 24 15.82 15,000 99% 0.64

07 (07) Natural Gas-Fired Tunnel Kiln 23 6.48 3960 0% 0.88

08 (08) Natural Gas-Fired Tunnel Kiln 24 6.48 3960 0% 1.56

09 (09) Finished Tile Edge Grinding 9.37 9,400 99% 0.40

025 (025) Natural Gas-Fired Dryer for Kiln 25 5.08 3500 0% 0.33

026 (026) Natural Gas-Fired Roller Kiln 25 5.08 3500 0% 0.91

027 (027) Natural Gas-Fired Dryer for Kilns 23, 24 8.43 7920 0% 0.49

029 (029) Tile Press baghouse 7.58 5,000 99% 0.065Permit Statement of Basis Page 5 of 6 Permit: V-09-016



### H AZARDOUS 

### /T OXIC AIR POLLUTANTS AND ANALYSIS 

### :

The Division has performed air dispersion model sc reening of potentially hazardous substances that may be emitted by the facility based upon the process ra tes, material formulations, stack heights and other pertinent information provided by the applican t. Based upon this info rmation, the Division has determined that the conditions outlined in this permit will assure compliance with the requirements of 401 KAR 63:020.

The facility is major for hydrogen fluoride (HF) emissions, upon which screening was performed. HF is emitted from the stacks associated with k ilns 23, 24 and 25; so a merged stack parameter was calculated and the lowest merged stack paramete r was used as the input to SCREEN3 modeling. Table 4 summarizes the modeled worst case impacts, and the level of con cern (LOC) that would have triggered additional review and/or more de tailed modeling. Since only worst case screening modeling was performed, these results do not, nor ar e they intended to, portray actual risk. The results of the SCREEN3 air modeling performed indi cate that modeled concentrations of HF do not pose an undue risk or hazard towards human health and the environment.

Table 4: Screen Modeling Results

Substance Modeled Impact μg/m 3 Level of Concern μg/m 3 Analysis Hydrogen fluoride 0.75 (annual, max. at 392m) 14 No further review

In order to show compliance for ambient air quality standards, the 1-hour average impact obtained from SCREEN3 modeling was converted to a 12 hour and 24 hour basis. The HF surface reactivity reduction factor was calculated to be 0.68 for this application based on an internal memo. The Division has calculated a reduction coefficient of 32% based on the distance from the merged emission point to the maximum concentration. The 12 hour and 24 standards as per ambient air quality standards and the calculated impact from the facility are shown in Table 5 below.

Table 5: Comparison of 12 hour and 24 hour HF emissions with ambient air quality standards
Ambient Air Quality Standard Primary Modeled Concentration Primary

μg/m 3 Secondary μg/m 3 w/o reduction factor μg/m 3 with reduction factor μg/m 3

Annual arithmetic mean 400 ***** 0.768 0.52 Maximum 24 hr average 800 2.86 3.84 2.61 Maximum 12 hr average ***** 3.68 5.28 3.59

The results show that the source is in co mpliance with 401 KAR 63: 020 and 401 KAR 53:010 based on the rates of emissions of airborne toxics provi ded in the application submitted by the source. If the source alters processes, process rates, material formulations, or any other factor that would result in increased emissions of these previously evalua ted airborne toxics, or the emission of airborne toxics not previously evaluated by the Division, th e source shall submit the appropriate application forms pursuant to 401 KAR 52:020, Section 3(1)(a).Permit Statement of Basis Page 6 of 6 Permit: V-09-016



### C OMMENTS 

### :
Particulate Matter (PM) emission factor for Material Preparation Lines and the Finished Tile Edge Grinding has been obtained from AP-42 11.3. Emi ssion factors for pollutants from Kilns 23, 24 and 25 are based on the stack tests of December 2000 and August 2008 (worst case emission factor used). Emission factors for emissions from Drye rs are based on the stack test of December 2000. The emission factor for PM emissions from pre ssing baghouse is based on stack test results from similar equipment at another Dal-Tile facility.

Compliance Assurance Monitoring (CAM) for PM control using a bag house is applicable to Emission Point 09, the Finished Tile Edge Gri nding. Two monitoring approaches using visual opacity and pressure drop have been submitted in the CAM plan.

Applicable regulations:

401 KAR 61:020, Existing process operations, applicab le to an emission unit commenced prior to July 2, 1975 is applicable to Raw Material Prepar ation Line Emission Points 01, 05, 06; the Natural Gas-Fired Tunnel Kiln Emission Points 07 and 08; Finished Tile Edge Gr inding Emission Point 09; and Tile Press Baghouse Emission Point 029.

401 KAR 59:010, New process operations, applicable to an emission unit commenced on or after July 2, 1975 is applicable to Natural Gas-Fired Tunnel Kiln, Emission Point 026; Tunnel Dryers, Emission Points 025 and 027.

401 KAR 53:010, Ambient air quality standards , is applicable to all emission points which emit hydrogen fluoride; Emission Points 07, 08, 025, 026 and 027.

401 KAR 63:002, Section 3(b), which references 40 CFR 63, Subpart B, “Requirements for Control Technology Determinations for Major Sources in A ccordance with Clean Air Act Sections, Sections 112(g) and 112(j),” which applies to existing, new, or reconstructed kilns at a clay ceramics manufacturing facility is applicable to the Kilns, Emission Points 07, 08 and 026.

40 CFR Part 64, CAM for PM control using a bag house is applicable to Emission Point 09.

401 KAR 63:020, Potentially hazardous matter or toxic substances , applies to each affected facility which emits or may emit potentially hazardous matter or toxic substances, provided such emissions are not elsewhere subject to the provisions of the administrative regulations of the Division.



### E MISSION AND 

### O PERATING 

### C APS DESCRIPTION 

### : N ONE



### P ERIODIC 

### M ONITORING 

### :

Air pollution control equipment shall be main tained and operated in accordance with the manufacturer's specifications. Monitoring and record keeping specified under Sections B.4, B.5, and B.7 shall be performed as prescribed.



### O PERATIONAL 

### F LEXIBILITY 

### : N ONE