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 fiv e 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 sanitaryw are 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 CompromisedAlso, the wet scrubber kiln is ranked as 6 th 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 6 th ranked kiln and is, there fore, 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 ta ble 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

6 th 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