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 so me 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 al locate 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 i s more reasonably correlated to heat input, not w are 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 emi ts 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 spra y 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 overspra y 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 concentra tion. 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 assessmen t 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 werebroken in route to the analytical lab, so only one result was determined. As Rick has pointed out, the "pieces/day" process data reported f or the August 92 tests is inadequate for emission factor d etermination. 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 ori ginal 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 f rom stacks other than the combined TK exhaust stack. The RM 13B te st 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 r efire 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

- in

place) 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

- fir e 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 HAP

containing g lazes 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 like ly 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 resul ts 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 Kohle r a Sec 114 letter requiring that we do some testing and report results to EPA. What is the status of letter issuance?