Commonwealth of Kentucky 

Division for Air Quality

PERMIT STATEMENT OF BASIS

(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 

SOURCE DESCRIPTION:

Dal-Tile Corporation applied for a permit amendment to its State origin S-99-088 permit in 

September 2005. Preliminary review of the application showed that the permit currently held by the 

facility was S-05-050 and so the Kentucky Division for Air Quality (Division) requested an 

explanation on this issue and completed 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 Title 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 dated 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 results of the stack testing conducted on July 15, 

2008 and November 15, 2008 and was submitted as a revision to the State Origin permit on January 

29, 2009. Review of the application 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 source 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, waste 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 material being returned to the crusher. The sized 

material is sent to storage. There are 3 production lines – Lines 23, 24 and 25. For Lines 23 and 24, 

the sized mixture of raw materials is mixed with 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 Natural Gas-Fired Dryer 027. After drying, nearly 

90% of the tiles are sent directly to the kilns without 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 preheating. 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 and 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 (Lewisport 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 parts 
Permit Statement of Basis Page 3 of 6 

Permit: V-09-016 

History: 

• December 28, 1973, this location under the name of American Olean, was issued Air Permit O73-187 to manufacture quarry tile. Kentucky Emissions 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 the 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 existing 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 and 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 Material 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 Line 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 

Throughput 

(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% 0.065 
Permit Statement of Basis Page 5 of 6 

Permit: V-09-016 

HAZARDOUS /TOXIC AIR POLLUTANTS AND ANALYSIS: 

The Division has performed air dispersion model screening of potentially hazardous substances that 

may be emitted by the facility based upon the process rates, material formulations, stack heights and 

other pertinent information provided by the applicant. Based upon this information, 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 kilns 23, 24 and 25; so a merged stack parameter was 

calculated and the lowest merged stack parameter was used as the input to SCREEN3 modeling. 

Table 4 summarizes the modeled worst case impacts, and the level of concern (LOC) that would 

have triggered additional review and/or more detailed modeling. Since only worst case screening 

modeling was performed, these results do not, nor are they intended to, portray actual risk. The 

results of the SCREEN3 air modeling performed indicate 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/m3

Level of Concern 

μg/m3 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/m3

Secondary 

μg/m3

w/o reduction 

factor μg/m3

with reduction 

factor μg/m3

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 compliance with 401 KAR 63:020 and 401 KAR 53:010 based 

on the rates of emissions of airborne toxics provided 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 evaluated airborne toxics, or the emission of airborne 

toxics not previously evaluated by the Division, the 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 

COMMENTS:

Particulate Matter (PM) emission factor for Material Preparation Lines and the Finished Tile Edge 

Grinding has been obtained from AP-42 11.3. Emission 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 Dryers are based on the stack test of December 2000. 

The emission factor for PM emissions from pressing 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 Grinding. 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, applicable to an emission unit commenced prior to 

July 2, 1975 is applicable to Raw Material Preparation Line Emission Points 01, 05, 06; the Natural 

Gas-Fired Tunnel Kiln Emission Points 07 and 08; Finished Tile Edge Grinding 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 Accordance 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. 

EMISSION AND OPERATING CAPS DESCRIPTION: NONE

PERIODIC MONITORING:

Air pollution control equipment shall be maintained 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.

OPERATIONAL FLEXIBILITY: NONE