From: Cassidy Mike < MICHAEL.CASSIDY@kohler.com > To: Jeff Telander/RTP/USEPA/US@EPA Cc: Keith Barnett/RTP/USEPA/US@EPA, "Sroka, Kristin" < ksroka@rti.org > Date: 01/29/2013 05:00 PM Subject: RE: Glaze spray booth PM emissions

Jeff, Following our conversation from yesterday on glaze spray booth emissions, attached is an EXCEL file that shows photos of the 10 glaze spray booths in the file you provided. I hope thi s helps you to understand the differences among spray booths and spray machines. In your file:

• SC BBM, SC NTM, and TX 014 are spray machines, meaning the booth has multiple fixed reciprocating spray guns that are automatically controlled as ware is autom atically indexed through the machine. The machine’s use ‘chain

- on

- edge’ conveyor systems to move ware through the machines. These machines are used for high volume ware that is typically all the same color. These machines have higher glaze application rate s, as shown in your table.

• SC Robot 3, TX SR1, TX SR5, and WI Q24 are robot spray booths. They have a single robot fixed with a single spray gun for automatic application of glaze.

• SC LBM, TX 013, and TX SR3

- SR4 are manually operated spray booths. SC LBM does not use baffles, but has a water curtain, and has a single spray gun. This arrangement is typical for low volume use and often is used for when multiple glaze color changes are necessary, making glaze reclaim impractical. The other two manual boot hs each have two spray stations, with single spray guns. Most manual spray booths have a single gun and a single operator.

As the pictures show, most of our spray booths utilize baffles in front of a water curtain or water weir overspray control device. These baffles serve two purposes: 1) The first is for product recovery as the baffles are easy to scrap collected glaze from for reuse. 2) The second is to lengthen the life of the water curtain/water weir device by knocking out most of the overspray soli ds, which prolongs the time the water can be used, and helps minimize water use for the control device, and so minimizes waste water generation.

Glaze application rates are very similar between robot booths and manual booths. The spray booth arrangements depicted in the photos represent all arrangements that Kohler Co. uses for glaze application. Most manual booths do not have baffles. Kohler Co. does not use any non

- atomizing arrangements, like flow coaters used in tile manufacturing, due to the variatio n in ware size and shape.

Please contact me if you have any questions on this information.

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.comFrom: Telander.Jeff@epamail.epa.gov [ mailto:Telander.Jeff@epamail.epa.gov ] Sent: Tuesday, January 22, 2013 10:00 AM To: Cassidy Mike Cc: Barnett. Keith@epamail.epa.gov ; Sroka, Kristin Subject: Glaze spray booth PM emissions

Mike,

We have questions about the attached PM data for Kohler glaze spray booths and would like to schedule a phone call to discuss the data with you.

The three glaze spray booths in question are: (1) Glaze No. 2

– KOHL

- SC, 06

- LBM (1F); (2) Glaze No. 8

– KOHL

- SC, 12

- NTM (1F); and (3) Glaze No. 14

– KOHL

- TX, EPN013

- Manual SB. These rows are highlighted light yellow in the attached spreadsheet.

We want to better understand why the PM data from those booths are higher than the others.

We also have a couple of clarifying questions:

1. The ICR response for Kohler SC says that Glaze No. 2

– KOHL

- SC, 06

- LBM (1F) has baffles, but the description of the operation during the 2010 tes ting does not mention baffles. The operating descriptions for the other nine tests do mention baffles, so it seems inconsistent that the description does not state that the baffles were present during the test. Does the control system on this booth have ba ffles or not?
2. The ICR only gave the option to note whether the water curtain was equipped with baffles or a mist eliminator (or both). Do any of the water curtain systems on the Kohler glaze spray booths in the attached file include additional filtrati on between the water curtain and the baffles to remove large PM?

Please let me know when you are available to discuss the data with us. I look forward to hearing from you.

Thanks,

Jeff

(See attached file: Question_for_Kohler.xlsx)

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

- 02109 TW Alexander Drive RTP, NC 27709 (See attached file: Spray Booth D escriptions for EPA Jan 2013.xlsx)