Kohler Co., P.O. Box 1987, Spartanburg, SC 29304 864-582-3401 Fax 864-585-5463 kohler.corn 

0 KOHLER® 

April 4, 2007 

Dear Ms. Thompson: 

Subject: Comaliance Status Notification for a Source Subiect to Reouirements under 40CFR63 Subnart KK[QQK, 

National Enussions Standard for Hazardous Air Pollutants, CIaV Ceranvcs Manufacturine 

Kahler Co.- Vitreous Plant 

Spartanburg,SC 

Air Pernrit No. TV-2060-0361 

On May 16, 2003, EPA promulgated a MACT standazd (Subpart KKKKK) under section 112 of the Clean Air Act for 

certain sources engaged in manufacturing clay ceramic products. Sections 63.8630 and Table 8 require the owner of every 

new source to complete a perfomnance test within 180 days of initial start-up, and to give notice of compliance status to the 

Adminishator within 60 days of the perfonnance test. This notification fulfills these requirements. Note that the Initial 

Compliance Status Notification for the facility was submitted to SCDHEC and USEPA on June 7, 2006. 

Kohler Co. installed a new tunnel kiln in 2005 under DHEC construction permit no. 2060-0361-CG (12/15/2004). Ware was 

first fired in this new kiln on August 17, 2005, but ware throughput in the kiln never approached 75% of design capacity 

during the first year of operation, so as defined in Section 63.8665, initial start-up was August 17, 2006. The performance test 

on the kiln and wet scmbber was done on Febmary 7, 2007 by Environmental Source Samplers, fnc. (ESS) within the 180- 

day window from initial start-up. 

~ PERFORMANCE TEST RESULTS SUMMARY 

Attached to this notification is a copy of the ESS stack test report. Also attached are printouts from the scmbber's parametric 

monitoring system and production rate data for the test period. All of these data are summarized in the table below. 

Test Test Test Test MACT ^/a of 

Run 1 Run 2 Run 3 Avg. Limit MACT 

HF (Ibs/hr) 0.0155 0.0179 0.0152 0.016 

HCI (Ibs/hr) 0.0323 0.0150 0.0136 0.020 

PM (Ibs/hr) 0.110 0.110 0.131 0.117 

Average Ware 

Throughput (Ibs/hr) 1470 1470 1470 1470 

HF (Ibs/ton) 0.0211 0.0244 0.0207 0.022 0.057 38.7 

HCI (Ibs/ton) 0.0439 0.0204 0.0185 0.028 0.26 10.6 

PM (Ibs/ton) 0.1497 0.1497 0.1782 0.159 0.42 37.9 

Avg. Delta P 

(inches w.c.) 4.17 4.17 4.14 4.16 

Avg. pH 5.62 5.62 5.62 5.62 

Avg. Chemical Feed 

Rate (ml/min) 2.98 2.98 2.98 2.98 

Avg. Make-up Water 

Flow Rate (gals/min) 2.22 2.22 2.22 2.22 
^ Rhonda Banks 

~ / Jl April4, 2007 

Page Two 

As the stack test data show, emissions from the kiln are substantially below the MACT limitations. With this in mind, 

Kohler Co. proposes the following monitoring parameter limitations: 

• Pressure drop (delta P— inches w.c.): 4.00 (3-hr block average lower limit) 

• pH: 5.25 (3-hr block average lower limit) 

• Ware Throughput Rate (tons ware/hr): 1.5 (3-hr block average upper limit) 

Kohler Co. does not propose any monitoring for chemical addition feed rate and make-up water flow rate for the reasons 

presented in the altemate monitoring requests subnutted to SCDHEC and USEPA in January 2007. The fast request was 

submitted January 8, 2007 and addressed scmbber hquid flow rate. Kohler Co. uses an orifice plate scmbber design and 

water is not actively pumped or recirculated, so this parameter can not be monitored in any meaningful way. The second 

request was submitted on January 18, 2007 and addressed chemical addition feed rate. While this parameter was monitored 

during the perfom ance test, it is not conelated to scrubber performance in any meaningful way, and so setting a parameter 

lower linvt for compliance is not useful. Monitoring of the scrubber liquid pH is the important parameter for perfom ance. 

A response from EPA and DHEC on these two requests is pending. 

COOLING EXIIAUST STACK 

The tunnel kiln has two exhaust stacks, one in the heated section of the kiln and one in the cooling section. The exhaust 

from the heated section consists primarily of products of natural gas combustion combined with very small amounts of 

~ volatile gases (i.e. HF, HCI, SO Z) released from the ware being fired. This is the exhaust that is routed to the scrubber for 

removal of these minor volatile constituents. Based on the design and operation of the kiln, the volatile constituents from 

the ware are excluded from the cooling secfion and so are not present in the cooling exhaust. The cooling exhaust is vented 

d'uectly to atmosphere. 

During the perfom ance test on Febn ary 7, 2007, DHEC staff on site to witness the testing asked why the cooling exhaust 

was also not routed to the scmbber for removal of HAP constituents. While it was explained that the exhaust does not emit 

any HAP constituents, further information on kiln operation and justification as to why there are no HAPs expected in the 

cooling exhaust was requested by DHEC staff. To satisfy DHEC's request, prior to leaving the site on Febmary 7, staff 

were provided with the following infommtion: 

A thermogravimetric analysis of ware in the firing cycle that essentially shows that once the ware reaches about 

1,000°C, that it achieves a stable weight and no further n aterials are emitted ffom the ware during the fning 

process. 

Stack test results from 1993 on tunnel kiln 3 at the Kohler Co. Spartanburg facility which showed that the four 

cooling exhausts stacks on that kiln had no measurable HF in any of the four cooling exhausts. Tunnel kiln 3 is a 

slightly different design because the exhaust from the heated section is routed to a waste heat boiler for energy 

recovery. Note that emissions testing in 1993 of the waste heat boiler exhaust stack showed measurable quantities 

of HF. The cooling portion of tunnel kiln 3 vents through four separate stacks, and each of these was tested back 

in 1993 to get a complete picture of HF emissions from the kiln. 

These data aze resubmitted here for reference. Additionally, also attached are an explanation of kiln operation prcpazed by 

the kiln designer (Ralph Ruark of Ruark Engineering, Inc.) with explanation as to why HAPs are not to be expected in the 

cooling section exhaust and supplemental infonnation by Kohler Co. staff of kiln 10 operation. 
^ RhondaBanks 

~J\ Apri14,2007 

Page Three 

RECENT COURT RULING 

While not directly relevant to this specific compliance notification, I understand the DC Circuit Court of Appeals vacated 

EPA's Clay Ceranric MACT and Brick and Stmctural Clay MACT on March 13 (Sierra Club vs. EPA, no. 03-1202A, 

Mareh 13, 2007). My understanding is that EPA will likely need to start fromscratch with a new nile development forboth 

of these MACTs. The official date for vacating the rule is expected to be May 4, 2007. At that time, if neither EPA 

nor Sierra Club ask for a stay, meaning the old mles will be in place until new rules are fmalized, Subpart KKKKK 

will no longer exist and all references to KKKKK in our air pemrit will be null and void, and any and all requirements of 

KKKKIC that we were subject to will be no longer applicable. 

As required by Slate regulation 61-62.70.5(d), by signing this compliance notification as the responstble official for this 

manufacturing operation, I certify the following statement: 

"I certify under penalty of law that, based on infoxmation and belief formed after reasonable inquiry, the 

statements and infomlation contained in this compliance status notification are tnte, accurate, and coniplete: " 

If you have any questions on this information, please contact Mike Cassidy at (920) 457-0441, x77263 or at 

mike.cassidy acohler.com 

Re ctfully submi ed, 

g~i~~~C~~~~7ryll~\ O Brian J. Benson 

Plant Manager 

Ms. Rhonda Thompson 

Manager, AfrTmdcs Section 

SCDHEC— Bureau of Air Quality 

2600 Bull Street 

Columbia, SC 29201 

Enclosures: CopyofFebmary7,2007stacktestreportfmmESS 

Copy ofparunehic monitoring summary forscrubber for test day 

Copy ofware pmduction datha for Kiln 10 forthe testday 

 Copyofthennogravimetricanalysisgraphofwarefiring 

Copy of tunnel kitn 3 cooling exhaust stsck HF emissions test data 

Copy of Kiln 10 desiggi and operntlon informztion fiom Ruadc Engineedng 

Copy of Supplement to Ruark Fngineering infometion 

cc: Ms. Beverly Banister, USEPA -Air Enforcement Brznch, 61 Forsylh Street, Atlanha GA 30303 (w/ enclosures) 

Mr. Jake Frick, SCDHEC - BAQ, Technical Management Section, 2600 Bull Street, Columbia SC 29201 

C. Kcehn 

M. Cassidy 

J