From: Cassidy Mike

Sent: Tuesday, May 19, 2009 3:59 PM

To: Telander.Jeff@epamail.epa.gov

Subject: RE: Emission Test Data for Kohler Company

Jeff,

Thanks for forwarding RTI's e-mail to me. I have some comments and questions in response. Thanks for 

your help with these.

Mike

1) RTI PROCEDURE DOCUMENT FOR DEVELOPING MACT FLOOR DATA:

A) If emissions test data do not have corresponding production data, the emissions data are 

really useless for your purpose. While you can apply a design value or assumed value for production

rate, this approach only adds to the uncertainty already inherent to the results determined by stack test 

methodology accuracy.

B) The approach used when multiple sources exhaust through a common stack appears 

reasonable, but needs some interpretation. For our instance at the Spartanburg facility, where tunnel 

kilns 1 through 4 exhaust to atmosphere through a single stack, our emissions data from this stack are 

based on three 1-fire kilns and one refire kiln. The RTI approach will allocate measured emissions 

equally based on ware throughput rate per kiln. This doesn't seem appropriate for most pollutants. For 

some pollutants, like PM10 or NOx, which are fuel based, the emission rate is more reasonably 

correlated to heat input, not ware throughput. For other pollutants, like fluorides and chlorides, which 

are ware based, treating emissions from 1-fire and 2-fire ware equally results in calculated emission 

factors that are too low because refire ware has already been vitrified and emits little to no fluorides 

and chlorides. In this case, any refire ware throughput should be ignored and all measured pollutants 

should be based on 1-fire ware throughput during the test only.

C) I understand that correlating spray booth emissions to spray booth operation is a challenge. 

Even so, using a PM concentration to set a floor for glaze application seems inappropriate. If the intent 

of the MACT is to minimize emissions, optimizing spray gun transfer efficiency and optimizing spray 

booth overspray control are how this is done. Optimizing these practices is not reflected in PM

concentrations. The variety of shapes and sizes of sanitaryware lends to various rates of transfer 

efficiency, and optimized efficiency can not be correlated to a concentration. Concentration just reflects

dilution, and does not promote best practices with respect to spray gun or spray booth overspray 

control operation. I understand EPA wants to set a specific emission limit for glaze spray operations, it

just doesn't seem like an appropriate approach at this time.

2) RTI's (RICK MARINSHAW) REPLY TO MY QUESTIONS:

A) I assume Rick is responding to the questions I submitted to him on April 20 via e-mail. If 

other than this, please identify.

B) I agree with Rick's assessment that explanation of the 1992 tunnel kiln testing in the report 

was inadequate. To confirm, the '92 stack tests were done on the combined stack for all 4 tunnel kilns, 

with TKs 1-3 running 1-fire ware, and TK4 running refire ware. The three runs on 8/11/02 were for PM; 

the three runs on 8/12/92 were for fluorides (Method 13B). Two of the three fluoride samples were
broken in route to the analytical lab, so only one result was determined. As Rick has pointed out, the 

"pieces/day" process data reported for the August 92 tests is inadequate for emission factor 

determination. Even though the PM emissions test data on 8/11/92 appears valid, it is not useful as the 

production data are not useful.

C) In addition to the Aug 92 test data submitted with the original ICR, we also provided test data 

from April 93 and July 93 with that ICR. The April 93 data was useful for us to prove to DHEC that HAP

emissions only came from the combined tunnel kiln exhaust stack and not from the other natural draft 

exhaust stacks on the tunnel kilns. The April 93 test also included a test on a shuttle kiln in 1-Fire

service. That data is not particularly useful as it doesn't confirm that the test period covered the entire 

fluoride emission period. Also, as the shuttle kilns at Spartanburg haven't run 1-Fire ware in a very long 

time, retesting a shuttle kiln is not an option. The July 93 data set also includes results further 

confirming that HAPs are not emitted from stacks other than the combined TK exhaust stack. The RM 

13B test on the combined stack appears to be complete, with corresponding process data. If using this 

process data, the fluoride emissions should be correlated to the TK 1-3 production rates only; the TK4 

production data should not be included as it processed refire ware.

3) OTHER ISSUES ADDRESSED IN MY MAY 4 E-MAIL TO YOU:

A) I identified at the Spartanburg facility that TKs 3 and 4 have been permanently shut down. 

While they haven't been operated in several years, they are technically not shut down (abandoned-inplace) and the total kiln count at Spartanburg is 9 (4 first fire and 5 refire), not 7, and the total kiln count 

is 27 (8 1-fire and 19 refire), not 25.

B) Have you given any thought as to whether a 1-Fire shuttle kiln must be tested? At this point I 

do not plan to test one.

C) Have you given any thought to the handling of spray operations that do not apply any HAPcontaining glazes and an approach of averaging glazes over all facility booths for compliance 

demonstration?

4) STATUS

A) I am still evaluating kiln operation, raw material, and test location information to be able to 

propose a test plan for EPA review. It will likely be early June until I've finished with this evaluation. 

Once EPA approves the test plan, I will go out for bid for the testing. I'd like to get a contractor hired by 

the end of June so testing can occur in July and results can be available in August. Depending on the 

scope of the testing, this may be quite expensive. Does EPA have access to any Recovery Act stimulus 

funds that could be utilized for this project?

B) When we started discussions on this last month, you mentioned that you might send Kohler 

a Sec 114 letter requiring that we do some testing and report results to EPA. What is the status of letter 

issuance?