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 co ol 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 paramet ers 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

a nd 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. Ther e 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 wat er 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 boo th. 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 autom atically 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 wate r 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 t he 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 devi ce 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 d evice 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 operat ing 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 a nd 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 manua lly

- 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 c urtain is adequate (normal). There is no delta P monitoring, water flow rate monitoring, or any other monitoringdevice 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 operati on 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 par ameter 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 curtai n 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

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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: Vis ual 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