From: Telander, Jeff [mailto:Telander.Jeff@epa.gov]

Sent: Tuesday, December 02, 2014 5:33 PM

To: Cassidy Mike

Cc: Nizich, Sharon

Subject: RE: Link to proposed NESHAP for Brick and Structural Clay Products 

Manufacturing; and NESHAP for Clay Ceramics Manufacturing is enclosed

Hi Mike,

I’ve summarized your questions and our responses below. 

In the MACT floor memo, Appendix A, run status is shown as DLL (detection level limited) or 

ADL. What does ADL stand for? Above detection level?

Response: ADL stands for Above Detection Limit

I see no status shown as BDL (below detection level).

Response: For Table A-12 (Sanitaryware TK Hg) the “Run Status” (i.e. the overall status of that 

kiln) was determined by first identifying the status of each of the five mercury fractions for each 

run. If all five Hg fractions were ADL, then the status of that particular run was ADL. If all five Hg 

fractions were BDL, then the status of that run was BDL. If there was a mix of ADL and BDL 

within the five Hg fractions, then the status of that run was DLL. Next, the status of all test runs 

for each kiln was compared. If the status of all test runs was ADL, then the overall status of that 

kiln was ADL. If the status of all test runs was BDL, then the overall status of that kiln was BDL. 

If there was a mix of ADL and BDL within all test runs, then the overall status of that kiln was 

DLL. For sanitaryware tunnel kilns, there were no runs where all five Hg fractions of all test runs 

were BDL. 

Similarly, for Table A-14 (Sanitaryware TK D/F TEQ), the status of each individual D/F TEQ 

congener for each run was first evaluated, then each run status to get the final overall “Run 

Status.” 

Also, I see no wet scrubber (kiln no 9) data in table A-12, but do see it listed in tables A-13 and 

A-14. Why was it omitted as a source for A-12 (Hg)?

Response: Table A-12: Proposed Standards for First-fire Sanitaryware Tunnel Kilns – Hg lb/ton 

Ranking for Hg did omit kiln no. 9 (TK#10 POC + RCE stacks, Kohler Co., Spartanburg, SC). 

The Method 29 results were not used for this kiln because of a mix-up during the analytical 

procedures, specifically the digestion process (see Section 4.1: Analytical discrepancy of the 

Test Report “Kohler Co., Spartanburg, SC: Tunnel Kilns and Glaze Spray Booths 08/11-17/2010 

Stack Test,” pdf page 32). The Run 3 POC stack sample was compromised, and the Run 1 and 

Run 2 RCE stack samples were compromised. Since there was not one combined POC+RCE 

stack run where either the POC or RCE stack sample was not compromised, the Method 29 

data for kiln no 9 were omitted. 

Run TK#10 POC 

stack

TK#10 RCE stack

1 Compromised

2 Compromised

3 Compromised
Also, the wet scrubber kiln is ranked as 6th in table A-13 (PM), does this mean it was omitted 

from the floor evaluation? 

Response: That is correct. For the sanitaryware tunnel kiln category, there are <30 sources 

nationwide. CAA Section 112(d)(3) states that for categories with <30 sources nationwide, the 

best performing 5 sources with data are to be used for the MACT floor evaluation. Table A-13 

shows that Kiln No. 9 is the 6th ranked kiln and is, therefore, not included in the MACT floor 

evaluation. 

Finally, is there a cross-reference for the sanitaryware kilns so I can know which kiln number in 

your analysis corresponds to which kiln at my facilities?

Response: Appendix B: Final Run-by-Run Values to the memorandum "Test Data Used in Clay 

Ceramics Proposed Rule" contains both the Kiln No. and Kohler’s Kiln IDs, which can be used 

as a cross-reference.

Kiln 

No Parent Co. City State Kiln ID APCD Type Stack/APCD_ID

2 Kohler Co. Spartanburg SC 02 -

TK-2

None CO1S (POC), EE, FE, 

RCE, WCE (5 stacks)

3 Kohler Co. Spartanburg SC TK-3 None CO1S

7 Kohler Co. Spartanburg SC 18 -

TK-8

None AO8S (POC), RCE, 

EXE (3 stacks)

9 Kohler Co. Spartanburg SC 38 -

TK-10

Wet 

Scrubber 

(since 

removed)

POC, RCE (2 stacks)

19 Kohler Co. Brownwood TX TK-6 None E247A (combined POC 

stack), CE1-3 (4 

stacks)

20 Kohler Co. Brownwood TX TK-12 None E247A (combined POC 

stack), CE (2 stacks)

21 Kohler Co. Kohler WI TK-2 None S24

22 Kohler Co. Kohler WI TK-3 None S24

23 Kohler Co. Kohler WI TK-4 None S24

26 Kohler Co. Kohler WI TK-7 None S24

33 Kohler Co. Kohler WI TK-19 None S24 (POC), RCE, EE 

(3 stacks)
From: Cassidy Mike [mailto:MICHAEL.CASSIDY@kohler.com]

Sent: Tuesday, December 02, 2014 1:43 PM

To: Telander, Jeff

Subject: RE: Link to proposed NESHAP for Brick and Structural Clay Products 

Manufacturing; and NESHAP for Clay Ceramics Manufacturing is enclosed

Jeff,

In the MACT floor memo, Appendix A, run status is shown as DLL (detection level limited) or 

ADL. What does ADL stand for? Above detection level? I see no status shown as BDL (below 

detection level).

Also, I see no wet scrubber (kiln no 9) data in table A-12, but do see it listed in tables A-13 and 

A-14. Why was it omitted as a source for A-12 (Hg)? Also, the wet scrubber kiln is ranked as 

6th in table A-13 (PM), does this mean it was omitted from the floor evaluation?

Finally, is there a cross-reference for the sanitaryware kilns so I can know which kiln number in 

your analysis corresponds to which kiln at my facilities? Thanks.

Mike