Kohler Co. 444 Highland Drive Kohler, Wisconsin 53044 920-457-4441 kohler.com REGISTERED MAIL RETURN RECEIPT REQUESTED June 10,2010 Mr. JeffTelander US. EPA Mailroom (D243-02) USEPA- Office of Air Quality Planning and Standards Research Triangle Park, NC 27711 

# KOHLER. 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.

# Mr. JeffTelander June 10, 2010 Page Two 

# Kohler Co. installed the wet scrubber

in good faith at great expense, even though litigation was then pending challenging the Clay MAC! rule. Even after the Clay MACT rule was vacated

in its entirety
in that litigation, Kohler Co. acted in good faith yet again, by obtaining state approval before shutting down the wet scrubber. The wet scrubber has not been operative now for over 15 months. The impermissible 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.Mr. JeffTelander June -10.2010 Page Three Brownwood,
TX Tunnel Kilns: The POC stacks from Tunnel kilns TK-6 and TK-12 exhaust through

a combined stack. This stack has ports and will be tested, but significant scaffolding must be erected
to access the sampling ports. Tunnel kiln TK-6 has three cooling exhaust stacks, but as oxygen levels were not depressed

at any of these stacks, 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.Mr. JeffTelander June l0.20l0 Page Four Ware Dryers: Ware dryer WD-2
is identical
to WDcJ but no longer operates due to low production requirements
and will not be tested. WD-1
is exhausted
by a single stack and will be tested. Its emissions are representative

of WD-2. Sampling ports need to be installed on the dryer stack for testing. Spray Booths: 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 byemail (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 

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# 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 ExhallS! Stack

FE: Fume Exhaust Stack RCE: Rapid Cool Exhaust Stack

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**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 of5 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 Tcsted (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 CI04 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

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# ;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 Tcstcd: 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