From: "Cassidy Mik e" <MICHAEL.CASSIDY@kohler.com> To : Je ff Telander/RTP/USEPA/US@EPA Sent: 05/29/2009 11:57 AM C c : Subject : RE: Emission Test Data for Kohler C ompany
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 o n 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 eit her 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 t ested.

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 r ecover 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 logistic ally 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 o r 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 f rom 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 famili ar 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, W I 53044 p. (920) 457

- 4441, x 77263 f. (920) 208

- 4744 mike.cassidy@kohler.com

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