Mr. JeffTelander 

US. EPA Mailroom (D243-02) 

USEPA- Office of Air Quality Planning and Standards 

Research Triangle Park, NC 27711 

Subject: Kohler Co. Proposal for Emissions Testine at Three US Vitreous Sanitaryware 

Manufacturing Facilities for Response to Clav Ceramics Manufacturing lCR 

Dear Mr. T elander: 

Kohler Co. received a.CAA section 114ICR from Mr. Steve Fruh, dated April23, 2010. The ICR requests 

emissions data from a list of sources in Enclosure 2 of the lCR It requests that we inform EPA of any 

relevant updates to the Enclosure 2 list It also allows Kohler Co. to make a proposal for representative 

testing of the sources in question. Per the ICR cover letter, any proposal must be approved in writing by 

EPA This letter updates the source listing in Enclosure 2 and proposes emissions testing on representative 

sources in the listing. Please provide written approval of this proposal at your earliest convenience. 

Enclosed with this letter is an updated version of!CR Enclosure 2 for each of Kohler Co.'s three 

sanitaryware facilities. The updates and changes to Enclosure 2 are discussed below. For tunnel kilns with 

multiple stacks, oxygen levels were measured to determine if the stack needs to be tested. According to 

Ralph Ruark, a kiln technology expert', a survey of oxygen levels in kilns stacks is sufficient to determine 

whether a stack gas might contain ware off-gases. ff oxygen levels in a stack are depressed (20.5% 0 2 or 

lower), this is a suitable indicator that the stack should be tested for the pollutants listed in the !CR. If 

oxygen levels are not depressed (20.6% 0 2 or higher), this indicates that the stack gas essentially contains 

cooling air (ambient air) and need not be tested. 

* Mr. Ruark is President of Ruark Engineering. a ceramic industry engineering firm. 'He has 36 years experience in 

the ceramic industry, including Director of Engineering for Lennox China. VP of Manufacturing for 

Bickly/Reidhammer Kilns, Technical Diiector for Freeport Brick and Refractories Co .. Senior Technical ·Editor of 

"Ceramic Industry" magazine. and author of The ~"ethnical Kiln Book. 

Spartanburg, SC 

We understand from your April23 ICR letter that EPA is requesting testing of tunnel kiln TK-10 under 

operating conditions that include the wet scrubber. However, as we set forth in detail in a letter to Attorney 

Scott Jordan dated November23, 2009, any emissions data including use of a wet scrubber is not 

representative of the actual unit performance or operational configuration of the existing tunnel kiln. This 

is because the kiln has not operated with a wet scrubber since March 2009, when the wet scrubber was shut 

down with state approval following litigation which vacated the Clay MACT rule. Because testing under 

conditions including a wet scrubber Would result in an impermissible MACT -on~MACT rule, we believe it 

is entirely improper as set forth in our November 23 letter. We never received a response to our letter, and 

therefore were surprised to see that EPA is requesting testing under non-representative conditions including 

the wet scrubber. 
the wet scrubber. 

p

testing that EPA has now requested from Kohler Co. would require Kohler Co. to inctlr unreasonable recommissioning costs for the scrubber and the testing would not ultimately produce any benefit since the 

results would not show normal operating conditions for the kiln. 

For all of these reasons, and those set forth in our November 23 letter, Kohler Co. intends to perform testing 

oftunnel kiln TK-10 at our Sparta.rlburg, SC facility under representative operating conditions, meaning the 

wet scrubber will not be recommissioned and restarted on this kiln for ICR testing. We are enclosing for 

your convenience another copy of our November 23 letter setting forth our analysis on that issue. 

Tunnel Kilns: 

Tunnel Kiln TK-2 (ID 02) is a late 1950's muffle-style tunnel kiln with five exhaust stacks. The first three 

stacks (POC (products of combustion) exhaust, entrance exhaust, and fume exhaust) had depressed oxygen 

levels and will be tested. The last two stacks (rapid cool and ware cool) did not show depressed oxygen 

levels and will not be tested. Sampling ports need to be installed on the POC stack for testing. Per your 

May 4, 2010 e-mail, all stacks will only be tested for PM filterable (Reference Method 5 front-half) and 

this is so indicated in the attached revised Enclosure 2 (for this stack and all stacks). 

Tunnel Kiln TK-8 (ID 18) is a direct-fire tunnel kiln with three stacks. The first stack (POC exhaust) will 

be tested. The second and third stacks (rapid cool exhaust and exit exhaust) showed no depressed oxygen 

values and will not be tested. Sampling ports need to be installed on the POC stack for testing. 

Tunnel Kiln TK-1 0 (ID 38) is a direct-fire tunnel kiln with two exhaust stacks and both stacks will be 

tested. 

Ware Drvers: 

BT WD #2 through #7 were never installed, though permitted, and do not exist. HT WD #I (ID 20), HT 

WD #8 (ID 40), and HT Tank Dryer (ID 22) are all manufactured by Ceramic Drying Systems and are all 

very similar in design, operating temperature, and capacity. The ware enters each dryer at 1 0%-12% 

moisture, and exits each dryer at about 0.5% moisture. Emissions from any one of these dryers are 

representative of the others. We will test HT WD #I as the representative dryer. This dryer has two stacks, 

but since the dryer is open internally and the air is well mixed throughout, We will only test one dryer stack 

for dioxins/furans as it will be representative of the other stack. Sampling ports need to be installed on the 

dryer stack for testing. 

Spray Booths: 

All spray booths will be tested for filterable PM (RM 5 front half) only, as shown in the revised Enclosure 

2, and HAP metals emissions will be derived based on glaze composition. Spray booths BBM (lD 07) and 

NTM (ID 12) will be tested, as will booths LBM (ID 06) and Robot 3 (ID 09). Due to low production 

levels, Spray Booth OTM (ID 05) is not currently in use. LBM and Hand 3 (lD 1 0) are very similar in 

design, operation, and throughput and emissions from LBM are representative ofHand 3. Robot booths 2, 

3, and 4 are all very similar in design, operation, and throughput, and emissions from Robot 3 are 

representative ofRobot booths 2 and 4. Sampling ports need to be installed on the NTM and Robot 3 

stacks for testing. 
g 

they will not be tested. Tunnel kiln TK-12 has one cooling exhaust stack, but as the oxygen level was not 

depressed at this stack, it will not be tested. 

Ware Dryers: 

Batch ware dryer E 117 and Tunnel dryer E238 are different in design, operation, and ware moisture content 

and each will be tested. Note that ware dryer E505 is not located at this facility and will not be tested. 

Ware enters batch ware dryer EII7 at about 5% moisture and exits the dryer at about 0.5% moisture. This 

dryer has two stacks, but only one stack will be sampled as it's representative of the other dryer stack. 

Sampling ports need to be installed on the dryer stack for testing. 

Ware enters tunnel dryer E238 at 14%-16% moisture and exits the dryer and <I% moisture. There are four 

gas-fired heat zones along the length of the dryer, each with its own exhaust stack. There's a fifth stack at 

the entrance of the dryer that essentially exhausts air from the cast shop. There is no heat source associated 

with the entrance exhaust stack and it will not be tested, but the other four stacks from the heated zones will 

be tested. Sampling ports need to be installed on each of the tunnel dryer stacks for testing. 

Spray Booths: 

Spray booths E074 (Lab) and EI63 (Brilliance) are not production spray booths and not in regular use. lt is 

not possible to collect a representative sample from either booth because of the low and infrequent use, and 

these will not be tested. 

A section of the spray department wasupgraded last year. This section had 6 spray booths with six stacks 

(El03-EI06, EI66, and E251). The upgrade involved replacing manual booths with robot booths and 

resulted in the process having seven booths with 8 stacks. These booths are identified in Enclosure 2 as 

SRI-SR5 and SOO-S04. SOO, SO!-S02, and S03-S04 are the three existing manual spray booths. Also, SR5 

is the existing robot spray booth. Two existing manual spray booths were replaced by three robot booths, 

SRI, SR2, and SR3-SR4. The three robots are identical. Spray booths SRI and SR2 are identical. Spray 

booth SR3-SR4 is nearly identical to SRI and SR2 except that it has two spray stations, each with its own 

exhaust stack. One robot in booth SR3-SR4 serves both spray stations, and so each spray station (SR3 and 

SR4) has lower glaze throughput than either SRI or SR2. As shown in Enclosure 2, only booth SRI will 

be tested as it's representative of SR2 and SR3-SR4. Old robot booth SR5 will also be tested. Manual SB 

S03-S04 will only be tested as it's representative of the other two manual spray booths. Sampling ports 

need to be installed on each spray booth to be tested (SRI, SR5, and S03-S04). 

Spray booths E014 and E015 are identical, so booth E014 will be tested as the representative source as 

sampling ports are already installed on the stack. Spray booth E013 is similar to booth S03-S04, but has 

some differences and it will be tested. Sampling ports need to be installed on this booth stack for testing. 

Kohler, WI 

Tunnel Kilns: 

Tunnel kiln TK-19 is a direct-fire tunnel kiln installed in 2008 that has three stacks. The first stack (POC 

exhaust) will be tested. The second and third stacks (rapid cool exhaust and exit exhaust) do not have 

depressed oxygen values and will not be tested. 
Spray booths Q35, Q08, and Q09 are essentially not in use due to low production requirements and will not 

be tested. Q08 has not been operated for over two years, and its stack is just a 2-foot stub above the 

roofline, and no stack sample can be collected. Q09 and Q35 operated for one shift and 3 shifts, 

respectively, in the entire month ofMay. Due to the infrequent nature of their operation, representative 

samples cannot be collected. Additionally, the Q35 stack is just a 2-foot stub above the roofline, and no 

stack sample can be collected. The stacks on spray booths Q02/Q03 and Q07 are just stubs that are 2 feet 

above the roofline and cannot be tested. Spray Booth QO! is a refire spray booth and will not be tested. 

Spray booth Q13 is used infrequently for Artists ware, and is essentially a spot spray refire booth as all 

Artists ware is previously fired before any Artists decorations are applied. Due to its infrequent operating 

schedule, it is not possible to collect a representative sample from QI3, and it will not be tested. 

Additionally, the stack on Q13 is just a stub that's 2 feet above the roofline, and no stack sample can be 

collected. Spray booths Q04 and Q05 cannot be tested as there is no suitable location on the wet scrubber 

horizontal exhaust. Finally, Spray booth Q24 is a robot booth and it will be tested. 

Photographs of stacks and associated ductwork for any source discussed above are available upon request. 

Test results will be reported to EPA within 180 calendar days of written approval ofthis proposal for 

representative sampling based on the following schedule: 

• Prepare RFP (request for proposal), solicit bids, review bids, and select test contractor: 30 days 

• Prepare stacks, get testing on selected contractor's calendar, and prepare site specific test plans : 

30 days 

• Complete all sampling at all three facilities: 45 days 

• Receive lab results and prepare test reports: 45 days 

• Input data into EPA's ERT: 30 days 

Total calendar days: 180 

We will not notifY any state air regulatory agencies about this testing as it does not fall under their 

jurisdiction. Any agency notification will be EPA's responsibility. 

Please contact me at the letterhead address (Mail Stop 009) or telephone number (extension 77263) or by email (mike.cassidy@kohler.com) with any questions on the scope of work for this proposal. Please provide 

written approval of this proposal at your earliest convenience. 

, 

0JWt~1 

~h:el J. Cas y 

EHS Specialist 

Att: Revised ICR Enclosure 2 

November 23,2009 Kohler Co. letter to Scott Jordan, EPA-OGC 

cc: Scott Jordan. USEPA- OGC. Washington, DC 

file 
Enclosure 2 

Kil D dGI s Booth b ~-·-~· . '~·-- ~- -· ~ ····- ~···~-....,. ,... ~-~··- ·- -- ~ ................ I: ' . 

. '··i' 

··· ...... .... ··.:.·. :_ .. I:F '._,_, ';······,.,: ,': :_.- , .. ,.. · .. //-'• ..... ._ ·, ,, :.'•'•' .. .\ ... ' ,• '._ I,-.-.. ·-_, '"1' :'•."'·" ,- .,..__ ·, ·. -·.· ..... ·-.::'.' .-... ·- .. ",'. ·'. ·---·,' :_::.>,'- "·" ·•· .. · .... · ·.·, •· ·.·· ·.·. ··· .. • .·· · <I! Gycie • Design· ' ·· ·.· ··· ·· · ... ·· ·. \ ·. < .·· · ..... · ·· ···. ,) ,· ' 

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1· .. ·/····.E.T:J• ririe>; ··>:•·L····. •:JJ,:i~;i•J,·'...~·',II .• (hi:;):•.:··: :.,,· •·(tPh)··.• " ••€'olltro!Devlce•:li .••. Stack,m•·•·li··. · >.• ',.. ··.•·:·PoUuta)lts.to'l'est~·":":• ,;. ' ., .. ; 

Kohler Com PAll\'- Sbarfanburg,SC 

Tunnel Kiln 02- TK-2 !A None J'OC. EE, HF, HCI, metals, dioxins/furans, PM _ __. -1 Formatted: Font color: Auto ) 

FE (filterable) 

Tunnel Kiln .lli.::._TK-8 3.35 None A08S HF, HCI, metals, dioxins/furans, PM 

O'OCl (filterable) 

Tunnel Kiln 38- TK-10', 0.75 None POC. RCE· HF, HCI, metals, dioxins/funms, PM 

(filterable) 

Ware Dryer 20-HTWD#l None C09S Dioxins/furans_LTcst 1 of2 stacks) 

Ware Dryer HTWD#2 Does Nol Exist 

WareDrver HTWD#3 Does Not Exist 

WareDrver HTWD#4 D~)~S No! E:dsl 

Ware Dryer HTWD#5 Does Not Exjst 

Ware Dryer HTWD#6 Does Not Exist 

WareDrver HTWD#7 Does Not Exist 

Ware Dryer 40-HTWD #8 None Not Tested (seeHTWD#l 

Tank Dryer 22-HT Tank Dryer None Cl!S Not tested lseeHTWD#l 

Glaze Spray Booth 07-BBM(IF) Water Curtain W02C PM (filterable) 

Glaze Spray Booth 06-LBM (IF) Water Curtain W02B PM (filterable) 

Glaze Spray Booth 05-0TM(IF) Water Curtain W02A Not tested- NQl in Use 

Glaze Spray Booth 08-Robot 2 (IF) Water Curtain W02D Not Tested (see Robot 3) 

Glaze Soray Booth 09-Robot 3 (IF) Water Curtain W02E PM (filterable) 

Glaze Spray Booth 10-Hand 3 (IF) Water Curtain W02F Not Tested (see LBM) 

Glaze Sorav Booth 37-Robot 4 (If) Water Curtain Not Tested (sec Robot 3) 

Glaze Spray Booth 12-NTM (IF) Water Curtain W02H PM (filterable) 

POC: Products of Combustion Stack 

I EE: Entrance Ex hallS! Stack 

FE: Fume Exhaust Stack 

RCE: Rapid Cool Exhaust Stack 
'i: '\':2,[''i;: (,l:;g::,',••lf.·,,.:,;,:., .:. ·"'• •::·.!;,',:,::: ''"""'T .,. ,, D , . , . . ·: ...... ,. •: . ·'· ''"· .·:.·· .. ,. " ,., . : .. , , ;:·· )\~:.:<• ' '· : ·•'. ' ' 

. , •• ,, .. ,,. ·:~ .~ •• '.) , ·.··''.'·.·.·'-'.··' .. ~ •.• ~.;,:,.; •.•·· ..•. ".';·.·· .•. es. .. • ~·.·g.· .. ' .. .. ' ·.··.i·.··.·· .. · .. · .•. ;;•.·.··.;: .. ·.·.·.·.·.'.·.··.·.·'.' .. '.·'.·.·.·.··:.··.·.· •. ·:··.·• .. ·•.·· ·••· .. '" ... •·••••.•.· '·.''··.' •. :,·;..·:,:. 1

,,, •• , '.'.<' . . . .. , ...... ,i,;.. • .:,:.· .. ·:. , ... ,. , .•... ;''''.,..''"'.:' · .· _: ,, • :time'· · CapaCity f · ·:· . : .· · · ·Control/ 1 : ·•. , · '.:.. ,<: L • ' : ,:.· . :· .. ~,, ,: ... ·• .. · ,. r. . .·:.· .. ,:.(Ji,'sl· 1 

.. ·dilh)·., .contioiDe~ice .... stackiD • ·.. · '· "'- ., ... ·. · ·•: . · ·• KohlerCompanv~Bro,vmvood, TX ·· • · 

Tunnel Kiln TK'6 (E247A) 2.2 None E247A HF, HCl, metals, dioxins/furans, PM 

Tunnel Kiln TK-12 (E247A) 4.9 (combined (filterable) 

POCstack) 

Batch Ware Dryer E117A-B None E117A-B Dioxins/furans (test one of2 stacks) 

(2 stacks) 

Tunnel Ware E238 None £238 Dioxins/furans (test 4 of 5 stacks) 

Dryer (5 stacks) 

Ware Dry~r E505A-C None E505A-C NA CDrvcr not located at this facilitv) 

(3 stacks) 

Glaze Spray Booth EPN013-Manual SB Water Curtain C013 PM (filterable) 

Glaze Soray Booth EPN014-Bowl SM I Water Curtain COI4 PM (filterable) 

Glaze Spray Booth EPN015-Bown SM Water Curtain COI5 Not Tested (sec EPN014) 

2 

Glaze Spray Booth EPN074-Lab SB Other C074 Not Tested (not a nrnduction Sill 

Glaze Sprny Booth Robot Booth SR3- Water Curt<~ in Not T csted (see SB SRI) 

SR4 

Glaze Spray Booth Robot Booth SR2 Water Curtain CI03 Not Tested (see SB SRI 

Glaze Spray Booth Robot Booth SRI Water Curtain CI 04 PM filterable) 

Glaze Spray Booth Manual SB SOO Water Curtain Cl05 Not Tested see SB S03-S04l 

Glaze Spray Booth Manual SB SOI-S02 Water Curtain Cl06 Not Tested see SB S03-S04) 

Glaze Spray Booth EPN163-Brilliance Fabric Filter CI63 Not Tcste·d (not a nroduction SB 

Glaze Spray Booth Manual SB-S03-S04 Water Curtain CI66 PM (filterable) 

Glaze Spray Booth EPN251-Robot SR5 Water Curtain C251 PM (filterable) 

2 
'·a~~l~i~' .:·.J'· · .• ··•·•·.c···':·.'" ;i~b£;):i~.'· h · ·· "CQntr<iiDevice · · ... stnck'rri: ·· 

Tunnel Kiln TK-19 

North Ware Dryer WD-1 

South Ware 12!:Y_er WD-2 

Glaze Spray Booth Pll-Q02/Q03 

Glaze .fuorav Booth P12-Q35 

· Glaze Spray Booth PB-007 

Glaze Spray Booth P14-Q08 

Glaze Spray Booth P15:_009 

Glaze Spray Booth P16A-Q04 

Glaze Spray Booth Pl6B-Q05 

Glaze Spray Booth I P17-Q01 

Glaze Spray Booth I PlS:Q24 

Glaze Spray Booth I Pl9-Q13 

' HF =hydrogen fluoride, HCl =hydrochloric acid, PM 

that value as PM filterable. 

.1\..0mer \...umpully- Kohler~ WI 

None I POC: 

None 

None 

Water Curtain 

Water Curtain 

Water Cm1ain 

Water Cm1ain 

Water Curtain 

Wet Scrubber 

Sll 

S12 

Sl3 

S14 

Sl5 

S16 

(combined 

I stack) 

HF, HCl, metals, dioxins/furans, PM 

(filterable) 

Dioxins/furans 

Not in use 

Stack Not Suitable 

Not in usc: Stack Not Suitable 

Stack Not Suitable 

Not inus_e_:_Stack Not Suitable 

Not in use 

No suitable location on stack for testiiH! 

Water Curtain I S17 I Not T cstcd: Refire Snrav Booth 

Water Curtain I SIS I PM (filterabl~ 

Fabric Filter I S19 I Artists Booth: Stack Not Suitable 

particulate matter_,_ Note: Metals analysis requires weighing the filter and reporting 

3