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

Sent: Wednesday, January 19, 2011 4:02 PM

To: Telander.Jeff@epamail.epa.gov

Cc: Marinshaw, Richard; Holloway, Thomas C. (Tom); Raymond, Gabrielle

Subject: RE: Missing Control Device Parameter Data

Jeff,

In reviewing the test reports, it appears we only provided operating data for the wet scrubber on Tunnel 

Kiln 10 at Spartanburg, and I apologize for this oversight on my part. Summarized below is the operating 

data that we were able to collect for each applicable source tested. Please contact me with any

questions, or if you need further explanation. Thanks.

Mike

SPARTANBURG, SC:

Tunnel Kiln 10: This kiln has two stacks which we tested, the POC (products of combustion) stack and 

the RCE (rapid cool exhaust) stack. There is a caustic wet scrubber on the POC stack; there is no control 

device on the RCE stack. The wet scrubber is an orifice design, which means there are no pumps used to 

circulate the scrubbing liquid. The only operating parameters monitored on this type of scrubber are pH 

and pressure drop (delta P). 0.1N NaOH is used for pH control, and a make-up water supply is used for 

delta P control. Page D-3 of Appendix D for the Spartanburg test report shows the scrubber liquid pH 

and delta P values recorded during the ICR tests. The scrubber has a feedback loop from each 

monitoring device to add caustic (pH) and add make-up water (delta P). When the pH gets near the low 

set point, it triggers a pump to add the caustic solution, but there is no monitoring of caustic addition 

rate. Caustic is added until the scrubber liquid is increased to a certain pH, and then it's trimmed back. 

When the pressure drop gets near the low set point, it triggers a valve to open to add fresh water to the 

scrubber. As the water level in the scrubber increases, so does the pressure drop, and make-up water is 

trimmed back as the pressure drop nears the upper setpoint. There is no monitoring of make-up water 

flow rate. pH and delta P are the only critical parameters and the only parameters monitored, and these 

values are shown in App D of the report.

Spray Booth LBM: The booth has a manually-operated spray gun with a water curtain for overspray 

control. The only operating parameter for the water curtain is a visual inspection of the flow and 

coverage of the curtain. There is no delta P monitoring, water flow rate monitoring, or any other 

monitoring device on the booth. The visual inspection of the water curtain, combined with PM 

(preventive maintenance) procedures, is how spray booth operation is verified. During the ICR test, the 

water curtain was operating normally.

Spray Booth BBM: The booth has several automatically actuated reciprocating spray guns with baffles 

and a water curtain for overspray control. The only operating parameter for the booth is visual 

inspection of the baffles and the water curtain to confirm the baffles are in place and the flow and

coverage of the curtain is adequate (normal). There is no delta P monitoring, water flow rate 

monitoring, or any other monitoring device on the booth. The visual inspection of the baffles and water 

curtain, combined with PM (preventive maintenance) procedures, is how spray booth operation is 

verified. During the ICR test, the baffles were in place and the water curtain was operating normally.
Spray Booth NTM: The booth has several automatically actuated reciprocating spray guns with baffles 

and a water curtain for overspray control. The only operating parameter for the booth is visual 

inspection of the baffles and the water curtain to confirm the baffles are in place and the flow and 

coverage of the curtain is adequate (normal). There is no delta P monitoring, water flow rate 

monitoring, or any other monitoring device on the booth. The visual inspection of the baffles and water 

curtain, combined with PM (preventive maintenance) procedures, is how spray booth operation is 

verified. During the ICR test, the baffles were in place and the water curtain was operating normally.

Spray Booth Robot 3: The booth has a robotically-operated spray gun with baffles and a water curtain 

for overspray control. The only operating parameter for the booth is visual inspection of the baffles and 

the water curtain to confirm the baffles are in place and the flow and coverage of the curtain is 

adequate (normal). There is no delta P monitoring, water flow rate monitoring, or any other monitoring 

device on the booth. The visual inspection of the baffles and water curtain, combined with PM 

(preventive maintenance) procedures, is how spray booth operation is verified. During the 

ICR test, the baffles were in place and the water curtain was operating normally.

KOHLER, WI:

Spray Booth Q24: The booth has a robotically-operated spray gun with baffles and a water curtain for 

overspray control. The only operating parameter for the booth is visual inspection of the baffles and the 

water curtain to confirm the baffles are in place and the flow and coverage of the curtain is adequate 

(normal). There is no delta P monitoring, water flow rate monitoring, or any other monitoring device on 

the booth. The visual inspection of the baffles and water curtain, combined with PM (preventive 

maintenance) procedures, is how spray booth operation is verified. During the ICR test, the baffles were 

in place and the water curtain was operating normally.

BROWNWOOD, TX:

Spray Booth E13: The booth has two manually-operated spray guns with baffles and a water curtain for 

overspray control. The only operating parameter for the booth is visual inspection of the baffles and the 

water curtain to confirm the baffles are in place and the flow and coverage of the curtain is adequate 

(normal). There is no delta P monitoring, water flow rate monitoring, or any other monitoring device on 

the booth. The visual inspection of the baffles and water curtain, combined with PM (preventive 

maintenance) procedures, is how spray booth operation is verified. During the ICR test, the baffles were 

in place and the water curtain was operating normally. 

Spray Booth E14: The booth has several automatically actuated reciprocating spray guns with baffles 

and a water curtain for overspray control. The only operating parameter for the booth is visual 

inspection of the baffles and the water curtain to confirm the baffles are in place and the flow and 

coverage of the curtain is adequate (normal). There is no delta P monitoring, water flow rate 

monitoring, or any other monitoring device on the booth. The visual inspection of the baffles and water 

curtain, combined with PM (preventive maintenance) procedures, is how spray booth operation is 

verified. During the ICR test, the baffles were in place and the water curtain was operating normally.

Spray Booth S03/S04: The booth has two manually-operated spray guns with baffles and a water curtain 

for overspray control. The only operating parameter for the booth is visual inspection of the baffles and 

the water curtain to confirm the baffles are in place and the flow and coverage of the curtain is 

adequate (normal). There is no delta P monitoring, water flow rate monitoring, or any other monitoring 
device on the booth. The visual inspection of the baffles and water curtain, combined with PM 

(preventive maintenance) procedures, is how spray booth operation is verified. During the 

ICR test, the baffles were in place and the water curtain was operating normally. 

Spray Booth SR1: The booth has a robotically-operated spray gun with baffles and a water curtain for 

overspray control. The only operating parameter for the booth is visual inspection of the baffles and the 

water curtain to confirm the baffles are in place and the flow and coverage of the curtain is adequate 

(normal). There is no delta P monitoring, water flow rate monitoring, or any other monitoring device on 

the booth. The visual inspection of the baffles and water curtain, combined with PM (preventive 

maintenance) procedures, is how spray booth operation is verified. During the ICR test, the baffles were 

in place and the water curtain was operating normally.

Spray Booth SR5: The booth has a robotically-operated spray gun with baffles and a water curtain for 

overspray control. The only operating parameter for the booth is visual inspection of the baffles and the 

water curtain to confirm the baffles are in place and the flow and coverage of the curtain is adequate 

(normal). There is no delta P monitoring, water flow rate monitoring, or any other monitoring device on 

the booth. The visual inspection of the baffles and water curtain, combined with PM (preventive 

maintenance) procedures, is how spray booth operation is verified. During the ICR test, the baffles were 

in place and the water curtain was operating normally. 

Michael J. Cassidy

EHS Specialist

Kohler Co.

444 Highland Drive

Mail Stop 009

Kohler, WI 53044

p. (920) 457-4441, x 77263

f. (920) 459-1682

mike.cassidy@kohler.com

Save money. Save water. Support Habitat for Humanity. Visit 

www.SaveWaterAmerica.com
-----Original Message-----

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

Sent: Wednesday, January 19, 2011 11:30 AM

To: Cassidy Mike

Cc: rjmarinshaw@rti.org; tcholloway@rti.org; graymond@rti.org

Subject: Missing Control Device Parameter Data

Mike,

We are reviewing the information and data that Kohler provided in response to our 4/23/2010 letter to 

you.

It appears that no control device operating data was provided for any of the sources at any of the plants.

Enclosure 3 to the letter requested the following control device parameters:

 Wet scrubbers: Pressure drop, liquid flow rate, sorbent type and feed rate

 Water curtains: Visual continuity of water curtain and water flow rate per width of curtain

 Fabric filter: No monitoring required

I would appreciate it if you would forward this information to me as soon as possible.

Thanks,

Jeff

Jeff Telander

Sector Policies and Programs Division

Office of Air Quality Planning and Standards

(D243-02)

RTP, NC 27711

919 - 541-5427

919 - 541-5450 (FAX)

Overnight mail address:

US EPA

Mail Code D243-02

109 TW Alexander Drive

RTP, NC 27709