From: Cassidy Mike [ mailto:MICHAEL.CASSIDY@kohler.com ]

Sent: Saturday, March 07, 2015 1:49 PM

To: Nizich, Sharon

Subject: FW: EPA Proposed Clay MACT Rul e

Hi Sharon

, Some follow

- up to last Thursday’s conference call. The attached email below shows some temperature and ware throughput rate relationships. As shown, this is a summary for tunnel kiln 10 at our Spartanburg SC facility. This is the kiln we installed in 20 05 under the old Clay

MACT. This kiln was tested under the Clay MACT ICR in August 2010, and this is the kiln on which EPA made us restart the shutdown wet scrubber for ICR emissions testing. This summary shows that over the 6 year period from 2005 throu gh 2010, the kiln ran as fast as a 6

- hr cycle time,

and as slow as a 12

- hr cycle time. It also shows the peak temperature was 165 o F lower on the slowest cycle. This is our second newest kiln, it is also our smallest kiln with respect to ware capacity. I t’s possible that because this kiln holds less ware mass that it is subject to wider temperature variations from cycle rate changes. I understand that our other tunnel kilns, which are all larger than TK 10, will experience a temperature variation of 50

- 7 5 o F from fast to slow cycles. I’m still trying to obtain documentation of such, but these are not records typically kept for kiln operation.

This is normal, representative tunnel kiln operation because kilns are operated based on the “heat

work” neede d. This is a time and temperature relationship. Simply, for all kilns, more time equals lower temperature and less time equals higher temperature to achieve the same heat work. We make A1 ware regardless of the cycle time. I will likely include in my c omment letter a request for a temperature variance for ongoing operation and compliance demonstration to the effect of whatever the average temperature was per the performance test minus 150 o F, to account for this

normal variation. Might this be an accept able approach to EPA to address this need for operational flexibility ?

I will also include two additional comments related to an operational temperature limitation for the

kilns. 1) When a facility has a temporary production shutdown, say for 2

- 8 days, su ch as around Christmas, the fuel is throttled back as “dummy ware” is cycled into the kiln. This “dummy” ware is comprised of previously fired ware and refractory material, not greenware. There are no HAP emissions from use of this “dummy” ware, and the tunnel kiln can be throttled back several hundred degrees as a stand

- by condition, saving significant quantities of fuel,

and associated GHG emission reduction. In this standby condition, the kiln temperature will certainly drop below the temperature limi t established per the performance test, but there is no reason this should constitute a permit violation, as certainly no emission limit will be

exceeded. Your thoughts on how to address this in the Clay MACT ? 2) It is not uncommon for power outages to affec t a facility, and so affect tunnel kiln operation by shutting down the natural gas fuel train. It can take a few hours to get kilns relit and operating, and as a result, the kiln temperature can drop a few hundred degrees in response to the outage, and so may fall below the operating limit for temperature. Will such a power outage event be classified as a non

- compliance event or a deviation? Your thoughts on how these types of events should addressed in the Clay MACT?

Thanks

. Mik eMichael J. Cass id y EHS Specialis t

Kohler Co

. 444 Highland Driv e Mail Stop 00 9
Kohler, WI 5304 4

p. (920) 457

- 4441, x 7726 3

f. (920) 459

- 168 2 mike.cassidy@kohler.com

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From: Clark Gene

Sent: Friday, March 06, 2015 9:09 AM

To: Cassidy Mike; Weber Andy (Spartanburg)

Subject: RE: EPA Proposed Clay MACT Rul e

Mike

,

Period 2005 to 201 0

On Kiln 10 History >

Gen e