From: Howard L. Gilberg [mailto:Gilberg@guidaslavichflores.com] 

Sent: Friday, December 27, 2013 3:33 PM

To: Telander, Jeff; Barnett, Keith

Cc: Eric Astrachan; Connie O'Neal; Robert Hurt; Steve Willis; Steven T. Wiederwax

Subject: Florim Synthetic Minor Air Permit

Gentlemen:

Attached is the referenced permit. We now have provided the evidence you requested confirming 

all four formerly MACT major source floor tile plants are now synthetic minor sources.

I renew our request that EPA decline to propose MACT major source regulations for ceramic tile 

floor plants (what we describe as an administrative carve out).Such regulations would regulate 

no entity and are a waste of resources. The Consent Decree can be satisfied by issuing 

regulations for the Category that do not include these plants. Case by case MACT addresses any 

future concerns you may continue to have.

Please advise. Thank you.

Sent from my iPhone

Begin forwarded message:

From: "Pervenia P. Brown" <Brown@guidaslavichflores.com>

To: "Howard L. Gilberg" <Gilberg@guidaslavichflores.com>

Subject: Permit

Please see attached.

Thank you,

Pear

Pervenia P. Brown

Legal Secretary to Howard L. Gilberg,

Tonya L. Meier, Michael R. Goldman

and David E. Whitten

Guida, Slavich & Flores, P.C.

750 North St. Paul Street, Suite 200

Dallas, TX 75201

(ofc): 214.692.0009 Ext. 157

(fax): 214.692.6610

brown@gsfpc.com<mailto:brown@gsfpc.com>

www.gsfpc.com<http://www.gsfpc.com/>

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an intention to make an agreement by electronic means.
CN-0754(Rev. 2-13) RDA-1298

STATE OF TENNESSEE 

AIR POLLUTION CONTROL BOARD 

DEPARTMENT OF ENVIRONMENT AND CONSERVATION

NASHVILLE, TENNESSEE 37243-1531

Permit to Construct or Modify an Air Contaminant Source Issued Pursuant to Tennessee Air Quality Act

Date Issued: December 26, 2013 Permit Number:

967768P

Date Expires: January 1, 2015

Issued To: Installation Address:

Florim USA, Inc. 300 International Blvd.

Clarksville

Installation Description: Emission Source Reference No.

09: Tile Kilns #6, 7, 8, 9 63-0135

30: Tile Kiln #1

The holder of this permit shall comply with the conditions contained in this permit as well as all applicable provisions of 

the Tennessee Air Pollution Control Regulations.

CONDITIONS:

1. The application that was utilized in the preparation of this permit is dated September 16, 2013, and is signed by 

Giovanni Grossi, President and CEO for the permitted facility. In a letter dated November 20, 2013, Arrigo 

Zapparoli, President was designated as the new responsible official. If this person terminates employment or is 

reassigned different duties and is no longer the responsible person to represent and bind the facility in 

environmental permitting affairs, the owner or operator of this air contaminant source shall notify the Technical

Secretary of the change. Said notification shall be in writing and submitted within thirty (30) days of the change. 

The notification shall include the name and title of the new person assigned by the source owner or operator to 

represent and bind the facility in environmental permitting affairs. All representations, agreement to terms and 

conditions and covenants made by the former responsible person that were used in the establishment of limiting 

permit conditions on this permit will continue to be binding on the facility until such time that a revision to this 

permit is obtained that would change said representations, agreements and covenants.

(conditions continued on next page)

_______________________________________

TECHNICAL SECRETARY

No Authority is Granted by this Permit to Operate, Construct, or Maintain any Installation in Violation of any Law, 

Statute, Code, Ordinance, Rule, or Regulation of the State of Tennessee or any of its Political Subdivisions.

NON-TRANSFERABLE POST AT INSTALLATION ADDRESS
CN-0754(Rev. 2-13) RDA-1298

967768P page 2 of 9

SECTION I: The following conditions shall apply to the entire facility. Conditions 2–5.

2. The maximum emission rate from the entire facility for any single hazardous air pollutant (HAP), listed pursuant 

to Section 112(b) of the Federal Act, shall not exceed 9.9 tons per year. Total emissions of all HAPs from the 

entire facility shall not exceed 24.9 tons per year. In the event that the emission rates from the entire facility 

exceed these limits, the permittee shall provide written notification of the exceedance(s) to the Technical 

Secretary within fifteen (15) days from the date of discovery.

TAPCR 1200-03-07-.01(5); Letter of agreement dated September 17, 2013

3. This facility (63-0135) is subject to the National Emission Standards for Hazardous Air Pollutants for Clay 

Ceramics Manufacturing Area Sources (40 CFR Part 63, Subpart RRRRRR).

4. This permit (regardless of the expiration date) shall serve as a temporary operating permit from permit issuance to

the receipt of a Major Source Operating Permit Modification, provided the Permit Modification is applied for in 

accordance with TAPCR 1200-03-09-.02(11)(f)5., and provided the conditions of this permit and any applicable 

emission standards are met. The permittee shall apply for a Permit Modification within 30 days of issuance of this 

permit.

5. This source shall operate in accordance with the terms of this permit and the information submitted in the 

approved permit application.

SECTION II: SOURCE SPECIFIC CONDITIONS

63-0135-09 Tile Kilns #6, #7, #8 and #9. This source fires greenware in 4 tile kilns. There are two baghouses 

with sorbent-injection used for pollution control. Baghouse A49 controls Tile Kilns #6 and #7,and 

Baghouse A48 controls Tile Kilns #8 and #9.

Conditions 6 through 18 apply to source 63-0135-09

6. The maximum material input rate for this source shall not exceed 53,620 pounds per hour of glazed ceramic tile 

greenware in total (dry basis).

Permit Number 951238P, Condition 2

Compliance Method: The permittee shall assure compliance with this limitation by calculating the daily average 

material input rate. The permittee shall maintain a log of the daily material input, operating hours, and daily 

average material input rate.

Daily Average Material Input Rate

Date Material 

Input (lb)

Operating 

Hours 

(hours)

Daily Average 

Material Input 

Rate (lb/hr)

1

2

Etc.

31

The following equation shall be used to calculate the daily average material input rate:

Daily Average Material Input Rate (lb/hr) = Material Input (lb/day)

Operating Hours (hours/day)

(conditions continued on next page)
CN-0754(Rev. 2-13) RDA-1298

967768P page 3 of 9

7. The stated design heat input capacity for this source is 31.2 million British Thermal Units per hour (MMBtu/hr). 

The Technical Secretary may require the permittee to prove compliance with this rate.

8. Only natural gas and propane shall be used as a fuels for this source.

9. Particulate matter (PM) emitted from each kiln shall not exceed 0.2 pounds per hour (0.8 pounds per hour total for 

all four kilns).

TAPCR 1200-03-26-.02; Letter of agreement dated October 1, 1999 

Baghouse A49 controlling Kilns #6 and 7

Compliance Method: The permittee shall assure compliance with this emission limitation by maintaining a 

baghouse pressure drop equal to or above 4.0 inches of water across the baghouse (A49). The pressure drop for 

the baghouse shall be recorded once daily when the source is in operation. Days when the source is not operating 

shall be noted.

Baghouse A48 controlling Kilns #8 and 9

Compliance Method: The permittee shall assure compliance with this emission limitation by maintaining a 

baghouse pressure drop equal to or above 4.0 inches of water across the baghouse (A48). The pressure drop for 

the baghouse shall be recorded once daily when the source is in operation. Days when the source is not operating 

shall be noted.

For lower pressure drop reading(s) resulting from replacement of bags, the permittee shall record the deviation(s) 

as such in their daily records. Due allowance will be made for lower pressure drop reading(s) which follow 

replacement of bags provided the permittee establishes to the satisfaction of the Technical Secretary that these 

lower readings resulted from the replacement of bags.

Compliance with the above specified particulate emission limit shall be assured by maintaining the required 

minimum pressure drop for the baghouse. The pressure drop for the baghouse shall be recorded once daily when the 

source is in operation. Days when the source is not operating shall be noted.

10. Sulfur dioxide emitted from this source (63-0135-09) shall not exceed 16.0 pounds per hour.

TAPCR 1200-03-26-.02; Letter of agreement dated October 1, 1999 

Compliance Method: The permittee shall assure compliance with this limitation by maintaining the hydrated 

lime feed rate to each baghouse equal to or above 8.6 pounds per hour and by maintaining the sodium bicarbonate 

feed rate to each baghouse equal to or above 50.5 pounds per hour. The permittee shall manually check the

hydrated lime and sodium bicarbonate feed rates to each baghouse once per day and record the values in a log. 

Days when the source is not operating shall be noted.

The permittee shall maintain free-flowing hydrated lime and sodium bicarbonate in the feed hopper or silo and to 

each baghouse at all times. The permittee shall maintain the feeder setting at or above the levels listed above. 

The permittee shall inspect the sorbent injection system once daily and record the results of the inspection in a 

log. The permittee shall promptly correct any problems with the sorbent injection system.

11. Volatile Organic Compounds (VOC) emitted from this source (63-0135-09) shall not exceed 11.5 pounds per hour.

TAPCR 1200-03-07-.07(2) 

Compliance Method: Compliance with this condition is assured based on compliance with Condition 6, and an 

emission factor of 0.43 pounds of VOC per ton of ceramic product produced (from AP-42, Table 11.7-2, published 

July 1996).

(conditions continued on next page)
CN-0754(Rev. 2-13) RDA-1298

967768P page 4 of 9

12. Nitrogen oxides (NOx) emitted from this source (63-0135-09) shall not exceed 8.6 pounds per hour.

TAPCR 1200-03-07-.07(2) 

Compliance Method: Compliance with this condition is assured based on compliance with Condition 6, and a 

source test performed on a kiln in November 1998 referenced in the Title V permit application.

13. Carbon monoxide (CO) emitted from this source (63-0135-09) shall not exceed 71.0 pounds per hour.

TAPCR 1200-03-07-.07(2)

Compliance Method: Compliance with this condition is assured based on compliance with Condition 6, and a 

source test performed on a kiln in November 1998 referenced in the Title V permit application.

14. Hydrogen fluoride (HF) emitted from this source (63-0135-09) shall not exceed 0.62 pounds per hour.

TAPCR 1200-03-07-.07(2)

Compliance Method: The permittee shall assure compliance with this limitation by the compliance method 

specified in Condition 10.

15. Hydrogen chloride (HCl) emitted from this source (63-0135-09) shall not exceed 1.6 pounds per hour.

TAPCR 1200-03-07-.01(5); Application dated September 16, 2013

Compliance Method: The permittee shall assure compliance with this limitation by the compliance method 

specified in Condition 10.

16. Sulfuric acid (H2SO4) emitted from this source (63-0135-09) shall not exceed 0.85 pounds per hour.

TAPCR 1200-03-07-.07(2)

Compliance Method: Compliance with this condition is assured based on compliance with Condition 6, and a 

source test performed on a kiln in November 1998 referenced in the Title V permit application.

17. Visible emissions from this source (63-0135-09) shall not exceed ten (10) percent opacity. Visible emissions from 

this source shall be determined by EPA Method 9, as published in the current 40 CFR 60, Appendix A (sixminute average).

TAPCR 1200-03-05-.01(3) – Letter of agreement dated October 1, 1999

Compliance Method: The permittee shall assure compliance with the opacity standard by utilizing the opacity 

matrix dated June 18, 1996 that is enclosed as Attachment 2 of Permit #562538.

(conditions continued on next page)
CN-0754(Rev. 2-13) RDA-1298

967768P page 5 of 9

18. This source (63-0135-09) is subject to 40 CFR Part 64-Compliance Assurance Monitoring (CAM) for hydrogen 

flouride, hydrogen chloride, and sulfur dioxide. The following table summarizes the CAM requirements:

Monitoring Element Indicator Indicator

Indicator Sorbent (hydrated lime and sodium 

bicarbonate) feed rate

Baghouse pressure drop.

Measurement 

Approach

The permittee will determine the feed rates by 

noting feeder setting and measuring the output 

of the feeder system by disconnecting the feeder 

hose from the pump and discharging material to 

a pre-weighted container over a predetermined 

duration. The permittee will then measure the 

weight of the resultant material and extrapolate 

the dry sorbent feed rate over time.

The permittee shall measure the 

pressure drop across each baghouse 

once daily

Indicator Range The permittee shall maintain the hydrated lime 

feed rate to each baghouse equal to or above 

8.6 pounds per hour and by maintaining the 

sodium bicarbonate feed rate to each baghouse 

equal to or above 50.5 pounds per hour.

The permittee shall maintain the 

pressure drop across each baghouse 

equal to or above 4.0 inches of water.

Data 

Representativeness

The permittee will measure the hydrated lime 

and sodium bicarbonate feed rates to each

baghouse unit at the junction of the auger and 

pneumatic suction feed hose.

Magnahelic gauges positioned at inlet 

and outlet of baghouse, installed by 

authorized equipment representative.

Verification of 

Operational Status

The permittee shall inspect the hydrated lime 

and sodium bicarbonate injection systems once 

daily and record the results of the inspection in 

a log. The permittee shall promptly correct any 

problems with the sorbent injection system.

Not applicable.

QA/QC Practices and 

Criteria

Sorbent feed equipment is calibrated, 

maintained, and operated in accordance with 

manufacturer’s instructions. All equipment is 

inspected per facility preventive maintenance

practices.

Instrumentation is calibrated, 

maintained, and operated in 

accordance with manufacturer’s 

instructions. All equipment is 

inspected per facility preventive 

maintenance practices.

Monitoring 

Frequency and Data 

Collection Procedures

The hydrated lime and sodium bicarbonate feed 

rates to each baghouse shall be measured once 

per day and recorded in a suitable format (log) 

that shall be maintained on-site, and made 

available for inspection.

Pressure drop shall be measured once 

per day and recorded in a suitable 

format (log) that shall be maintained 

on-site, and made available for 

review.

Averaging Period No average is taken. No average is taken.

Minimum Data 

Availability 

Requirement

Not applicable. Not applicable.

(conditions continued on next page)
CN-0754(Rev. 2-13) RDA-1298

967768P page 6 of 9

63-0135-30 Green Tile Roller Kiln #1. This source fires greenware. Sorbent-Injected Baghouse Control.

Conditions 19 through 33 apply to source 63-0135-30

19. The maximum material input rate for this source shall not exceed 17,371 pounds per hour of glazed ceramic tile 

greenware in total (dry basis).

Permit Number 958314P, Condition 2

Compliance Method: The permittee shall assure compliance with this limitation by calculating the daily average 

material input rate. The permittee shall maintain a log of the daily material input, operating hours, and daily 

average material input rate.

Daily Average Material Input Rate

Date Material 

Input (lb)

Operating 

Hours 

(hours)

Daily Average 

Material Input 

Rate (lb/hr)

1

2

3

Etc.

30

31

The following equation shall be used to calculate the daily average material input rate:

Daily Average Material Input Rate (lb/hr) = Material Input (lb/day)

Operating Hours (hours/day)

20. The stated design heat input capacity for this source is 23.0 million British Thermal Units per hour (MMBtu/hr). 

The Technical Secretary may require the permittee to prove compliance with this rate.

21. Only natural gas and propane shall be used as a fuels for this source.

22. Operating time shall not exceed 8160 hours during all intervals of twelve consecutive months. 

Compliance Method: The permittee shall assure compliance with this limitation by keeping a log (similar to the 

one below) of the monthly and yearly operating time.

Month, Year

Hours of 

Operation 

(hours)

Hours of Operation 

(hours/12 consecutive 

months)

January

February

Etc.

December

The Hours per 12 consecutive month value is the sum of the 

Hours of Operation (in hours) in the 11 months preceding the 

month just completed + the Hours of Operation (in hours) in the 

month just completed.

(conditions continued on next page)
CN-0754(Rev. 2-13) RDA-1298

967768P page 7 of 9

23. Particulate matter (PM) emitted from this source (63-0135-30) shall not exceed 0.2 pounds per hour. 

TAPCR 1200-03-07-.01(5) – Letter of agreement dated June 6, 2005

Compliance Method: The permittee shall assure compliance with this emission limitation by maintaining a 

baghouse pressure drop equal to or above 2.5 inches of water across the baghouse. The pressure drop for the 

baghouse shall be recorded once daily when the source is in operation. Days when the source is not operating shall 

be noted.

For lower pressure drop reading(s) resulting from replacement of bags, the permittee shall record the deviation(s) 

as such in their daily records. Due allowance will be made for lower pressure drop reading(s) which follow 

replacement of bags provided the permittee establishes to the satisfaction of the Technical Secretary that these 

lower readings resulted from the replacement of bags.

24. Sulfur dioxide emitted from this source (63-0135-30) shall not exceed 8.72 pounds per hour and 35.6 tons during all 

intervals of twelve consecutive months.

TAPCR 1200-03-14-.01(3); Letter of agreement dated June 6, 2005

Compliance Method: The permittee shall assure compliance with this limitation by maintaining the sodium

bicarbonate feed rate to the baghouse equal to or above 69.1 pounds per hour. The permittee shall manually 

check the sodium bicarbonate feed rate to the baghouse once per day and record the value in a log. Days when the 

source is not operating shall be noted.

The permittee shall maintain free-flowing sodium bicarbonate in the feed hopper or silo and to the baghouse at all 

times. The permittee shall maintain the feeder setting at or above the level listed above. The permittee shall 

inspect the sorbent injection system once daily and record the results of the inspection in a log. The permittee 

shall promptly correct any problems with the sorbent injection system.

25. Nitrogen oxides (NOx) emitted from this source(63-0135-30), when burning natural gas shall not exceed 2.78 

pounds per hour. This consists of a contribution of no more than 1.15 pounds per hour of NOx from natural gas 

combustion and a contribution of no more than 1.63 pounds per hour of NOx emissions from clay. The natural gas 

NOx emission limitation is based on the AP-42 emission factor of 50 pounds of NOx per million cubic feet of 

natural gas combustion, found at AP-42 Table 1.4-1. Emission Factors for Nitrogen Oxides (NOx) and Carbon

Monoxide (CO) from Natural Gas Combustion. This emission factor is equivalent to a NOx emission rate of 0.05 

lbs per million Btu of heat input for natural gas combustion.

In order to stay below the threshold for applicability of low-NOx requirements for fuel combustion sources, the 

permittee has agreed that propane will not be burned for more than 1000 hours over any calendar year. 

TAPCR 1200-03-07-.07(2) for hourly limits

TAPCR 1200-03-07-.01(5) – Letter of agreement dated June 13, 2007 for annual propane usage limit.

Compliance Method: The permittee shall maintain records on site, available for inspection by a representative of 

the Division, which show compliance with the natural gas NOx emission limit. The permittee must keep a monthly 

log of the hours of operation while burning any amount of propane, and this value must be summed for all 12 

months at the end of each calendar year. Additionally, the permittee must comply with the maximum heat input 

limit specified in Condition E20 of this permit in order to comply with the above emission limits. Compliance with 

the emission limit for NOx from clay is based upon the permittee’s emission factor of 0.32 pounds of NOx per ton of 

clay and the process weigth rate limit of 8.69 tons (17,371 pounds) of clay per hour, found at Condition 19. The 

permittee shall keep documentation available for inspection by a representative of the Division to show 

compliance with this limit.

(conditions continued on next page)
CN-0754(Rev. 2-13) RDA-1298

967768P page 8 of 9

26. Volatile organic compounds (VOC) emitted from this source (63-0135-30) shall not exceed 3.73 pounds per hour 

and 15.3 tons during all intervals of twelve consecutive months.

TAPCR 1200-03-07-.07(2) 

Compliance Method: Compliance with this condition is assured based on compliance with Condition 19, and an

emission factor of 0.43 pounds of VOC per ton of ceramic product produced (from AP-42, Table 11.7-2, published 

July 1996).

27. Carbon monoxide (CO) emitted from this source (63-0135-30) shall not exceed 23.0 pounds per hour and 93.9 tons 

during all intervals of twelve consecutive months.

TAPCR 1200-03-07-.07(2); Hourly limitation

TAPCR 1200-03-07-.01(5); Annual limitation established pursuant to agreement letter dated June 6, 2005 and 

taken to avoid PSD review

Compliance Method: Compliance with this condition is assured based on compliance with Condition 19 and a

source test performed on a kiln in November 1998 referenced in the Title V permit application.

28. Hydrogen fluoride (HF) emitted from this source (63-0135-30) shall not exceed 0.2 pounds per hour and 0.82 tons 

during all intervals of twelve consecutive months.

TAPCR 1200-03-07-.07(2)

Compliance Method: The permittee shall assure compliance with this limitation by the compliance method 

specified in Condition 24.

29. Hydrogen chloride (HCl) emitted from this source (63-0135-30) shall not exceed 0.5 pounds per hour and 2.04 tons 

during all intervals of twelve consecutive months.

TAPCR 1200-03-07-.01(5); Application dated September 16, 2013.

Compliance Method: The permittee shall assure compliance with this limitation by the compliance method 

specified in Condition 24.

30. Sulfuric acid mist (H2SO4) emitted from this source (63-0135-30) shall not exceed 0.55 pounds per hour.

TAPCR 1200-03-07-.07(2) 

Compliance Method: Compliance with this condition is assured based on compliance with Condition 19, and a 

source test performed on a kiln in November 1998 referenced in the Title V permit application.

31. Visible emissions from this source shall not exhibit greater than ten percent (10%) opacity, except for one (1) sixminute period in any one (1) hour period, and for no more than four (4) six-minute periods in any twenty-four 

(24) hour period. Visible emissions from this source shall be determined by EPA Method 9, as published in the 

current 40 CFR 60, Appendix A (six-minute average).

TAPCR 1200-03-05-.01(3) – Letter of agreement of June 6, 2005.

Compliance Method: The permittee shall assure compliance with the opacity standard by utilizing the opacity 

matrix dated June 18, 1996 that is enclosed as Attachment 1 of Permit #562538.

If the magnitude and frequency of excursions reported by the permittee in the periodic monitoring for 

emissions is unsatisfactory to the Technical Secretary, this permit may be reopened to impose additional 

opacity monitoring requirements.

(conditions continued on next page)
CN-0754(Rev. 2-13) RDA-1298

967768P page 9 of 9

32. The Technical Secretary may require the permittee to determine the Chlorine and Fluorine content of the material 

input to the process.

33. The exhaust gases from this source (roller kiln #1) shall be discharged unobstructed vertically upwards to the 

ambient air from a stack with an exit diameter of 42 inches not less than 49.2 feet above ground level. Should this 

source in the future increase its emission of HF or revise its stack parameters, the source shall be remodeled for 

ambient air quality.

(end of conditions)