From: Cassidy Mike [ mailto:MICHAEL.CASSIDY@kohler.com ]

Sent: Thursday, June 20, 2013 11:56 AM

To: Nizich, Sharon

Cc: Sroka, Kristin; Telander, Jeff

Subject: RE: chain on edge vs. robot spray booths

Sharon,

The chain

- on

- edge machines can be used for glaze application for any sanitaryware fixture, but we only

use them for high volume ware. These machines typically have 10

- 20 fixed reciprocating spray guns,

and it can take a while to set up the machine for each different ware piece. For that reason only high

volume are run on the spray machines. Lower volume pieces are sprayed in a conventional booth using

either a robot or a person. The choice of whether robot spray or manual spray used for a ware piece is

based on the shape of the piece and volume to be sprayed.

The emission profiles from any spray booth are a function of glaze spray transfer efficiency (overspray)

and overspray control device efficiency. In theory, we try to apply a set amount of glaze to a fixture for

proper glaze coverage when fired, regardless of where/how the ware piece is sprayed. Depending on

which booth (machine, robot, manual) the ware is sprayed in, the transfer efficiency and overspray

control efficiency will vary as all booths are somewhat different. From a manufacturing point

- of

- view,

we try to minimize overspray for all pieces to minimize our costs of production, we also try to maximize

glaze recovery as we want to reuse as much overspray as possible. The more eff iciently we collect OS,

the more we can reuse, and the less gets emitted from the booth spray. At this time we recover and

reuse white, biscuit, and almond color glazes. Other color glazes are not currently reclaimed due to cost

of reclaim and the low vo lume of these colors. White, biscuit, and almond represent more than 90% of

all glaze sprayed at any of our three sanitaryware plants.

The stack test data collected per the ICR in 2010 represent a snapshot in time of ware being sprayed,

transfer efficien cy, and overspray control. There is certainly variability in these aspects of production,

and I’d attribute that to any variability you see in the emissions from the spray booths tested. Let me

know if I’ve missed the mark on your questions.

Mike

From: Nizich, Sharon [ mailto:Nizich.Sharon@epa.gov ]

Sent: Thursday, June 20, 2013 8:46 AM

To: Cassidy Mike

Cc: Sroka, Kristin; Telander, Jeff

Subject: RE: chain on edge vs. robot spray booths

Hello Mike

Ju st wanted to clarify the differences between the chain on edge and robot spray booths. I believe you

said that for certain pieces, the chain on edge won’t work because of the shapes (i.e. a pedestal sink)

such that the spray can’t get enough coverage or u niform coverage, due to the shape, and a manual

application, or robotic arm that is specifically programmed for covering that shape is needed. (??)

Also, there is more volume per unit of time of course, in the chain on edge booth. However, relative to

emissions, we don’t have test data that shows a distinct difference between the robotic and the chain

on edge

– both have values that are high or low (depending on the product being sprayed (?)), so do you

know of any reason there would be differences in t he emission profiles?Thanks.

From: Cassidy Mike [ mailto:MICHAEL.CASSIDY@kohler.com ]

Sent: Wednesday, May 29, 2013 9:40 PM

To: Nizich, Sharon

Subject: RE: chain on edge vs. robot spray booths

Ms. Nizich

, The chain

- on

- edge spray booths are spray machines that have multiple reciprocating spray guns, as you

mentioned. These spray machines can spray most any piece that Kohler Co. manufactures, but they are

only used for the highest volume product lines. A spray machine can spray 6 or 7 ware pieces in the

time it takes to spray a single ware piece in a robot or manual spray booth.

We operate two spray machines at our Spartanburg SC facility, which is closest to you, if you’d like to

see first

- hand how the various spray operations work. Let me know if any further questions.

Mike

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.com

From: Nizich, Sharon [ mailto:Nizich.Sharon@epa.gov ]

Sent: Wednesday, May 29, 2013 10:51 AM

To: Cassidy Mike

Subject: chain on edge vs robot spray booths



### Hello Mr. Cassidy

I have taken the lead on the sanitary ware subcategory, wit h RTI continuing to be the

contractor. We are looking at the possibility of subcategorizing the chain on edge and robot

spray booths, but need more information. Other than what you have provided, do you have

any additional information, such as why the em ission profiles would be different for each, or

whether they operate differently and how they operate differently? I understand the chain on

edge have multiple guns, but does that make any difference relative to whether you need this

type of booth for a distinct type of product over the other type of booth?

Thank you!Sharon Nizich

Minerals and Manufacturing Group

OAQPS Sector Policies and Programs Division

US EPA

Research Triangle Park, NC

919 541 2825