From: "Cassidy Mike" <MICHAEL.CASSIDY@kohler.com>

To: Jeff Telander/RTP/USEPA/US@EPA

Sent: 05/29/2009 11:57 AM

Cc:

Subject: RE: Emission Test Data for Kohler Company

Jeff,

Some of the follow-up items from our discussion last Friday (May 22) are:

1) Alternatives and options for glaze spray booth emission limitations

2) Options for if and how shuttle kilns (periodic kilns) should be addressed

3) Options for if and how refire (2-fire) kilns should be addressed

This e-mail presents some thoughts I have on item 2) above.

Tunnel kilns are continuously operated, and based on our testing experience, HF, HCl, and PM emissions 

can usually be characterized with three standard 1-hour test runs. The cost for this type of test, 

including sample analysis, is $5,000 - $6,000, and can be completed in a 10 to 12 hour day (exclusive of 

sample analysis). With the proper process data, this type of test will yield results in the "lbs HAP/ton 

ware fired" unit of measurement.

Shuttle kilns are periodic kilns that are batch operated, meaning a batch starts cold and ends cold. 

Kohler Co. operates shuttle kilns on batch cycle times of 18 - 38 hours, with the most common cycle 

times between 22 and 30 hours. As shuttle kilns operate through a heating cycle, temperatures are 

either in ramp-up or cool-down mode. HF, HCl, and PM emission rates vary over the batch cycle due in 

large part to the temperature cycle of the kiln. To determine emissions on a "lb HAP/ton ware fired" 

basis, emissions from the entire cycle period must be tested.

Conducting a shuttle kiln test on even the shortest cycle time will require a test crew to be on site for at 

least 24 hours, and would require the test team to have at least a dozen or more sampling train set-ups, 

or additional manpower on site to recover samples and turn-around sampling trains for subsequent use 

during the test. The test of a single shuttle kiln firing cycle with analysis would likely cost upwards of 

$20,000. As a single firing cycle would likely constitute only a single test run, two additional cycles 

would need to be tested to collect three test runs of data, bringing the cost to $60,000 or more to 

emissions test a single shuttle kiln.

While it is technically feasible to test a shut kiln, I believe it is economically and logistically infeasible. I 

believe it's economically infeasible based just on cost; even in a good economy, $60,000 to test a single 

shuttle kiln is a massive economic burden, especially in the current economic climate, and especially 

when facilities have three or more kiln each. I believe it's logistically infeasible based on cycle time. It 

not practical nor safe to expect a test team to conduct an emissions test for 24 hours, and likely longer. 

It's also not practical to have to use two test teams to complete a single test run as this would 

complicate sample recovery and chain-of-custody issues, not to mention the extra cost.

I'm not sure what information EPA had available when the Clay MACT was originally developed, but the 

decision to exclude shuttle kilns from the rule at that time seems like a very appropriate decision that 

should still be applicable today. The information this decision was based on should still be in EPA's file 

for this MACT. Kohler Co. encourages EPA to revisit this topic so it's familiar with the information 

already provided.
I look forward to hearing your thoughts on the ideas expressed above for this topic, and let me know if 

any questions. Thanks.

Michael J. Cassidy

EHS Specialist

Kohler Co.

444 Highland Drive

Mail Stop 009

Kohler, WI 53044

p. (920) 457-4441, x 77263

f. (920) 208-4744

mike.cassidy@kohler.com

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