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

Sent: Monday, January 05, 2015 1:56 PM

To: Cassidy Mike

Cc: Barnett, Keith; Holloway, Thomas C. (Tom)

Subject: RE: Link to proposed NESHAP for Brick and Structural Clay Products Manufacturing; 

and NESHAP for Clay Ceramics Manufacturing is enclosed

Hello Mike. I should be able to get some general answers back to you by next week on your 

questions below, but please send them to the docket anyway so that we have a record for the RTC 

and any associated clarifications we make in the final rule. Thanks!

Sharon Nizich

US EPA

Office of Air Quality Planning and Standards

Sector Policies and Programs Division/SPPD

RTP NC 27711

(919) 541 2825

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

Sent: Monday, January 05, 2015 9:14 AM

To: Nizich, Sharon

Cc: Barnett, Keith

Subject: RE: Link to proposed NESHAP for Brick and Structural Clay Products Manufacturing; 

and NESHAP for Clay Ceramics Manufacturing is enclosed

Alright, though it would help me to be more specific in my comments if I could get answers to these 

more basic questions beforehand.

Mike

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

Sent: Monday, January 05, 2015 8:00 AM

To: Cassidy Mike

Cc: Barnett, Keith

Subject: RE: Link to proposed NESHAP for Brick and Structural Clay Products Manufacturing; 

and NESHAP for Clay Ceramics Manufacturing is enclosed

Please send in your comments to the docket and we will address in the final rulemaking. Thanks!

Sharon Nizich

US EPA

Office of Air Quality Planning and Standards

Sector Policies and Programs Division/SPPD
RTP NC 27711

(919) 541 2825

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

Sent: Monday, January 05, 2015 7:56 AM

To: Nizich, Sharon

Cc: Barnett, Keith

Subject: RE: Link to proposed NESHAP for Brick and Structural Clay Products Manufacturing; 

and NESHAP for Clay Ceramics Manufacturing is enclosed

Sharon,

Will EPA address my questions during the comment period, or am I just to submit questions to EPA 

as part of my formal comments on the proposal?

Mike

From: Cassidy Mike

Sent: Tuesday, December 16, 2014 6:27 AM

To: Barnett, Keith

Cc: Nizich, Sharon

Subject: RE: Link to proposed NESHAP for Brick and Structural Clay Products Manufacturing; 

and NESHAP for Clay Ceramics Manufacturing is enclosed

Keith and Sharon, 

It would help to inform my comments on the proposed rule to have answers to the questions below, 

as well as answers to other questions that may arise during my review. Will EPA be able to address 

my questions during the comment period in such a manner as will leave me enough time to draft my 

comments based on EPA’s answers?

Also Keith, I will submit to you a written request to extend the comment period for the proposal by 60 

days as soon as it’s published. Thanks.

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: Telander, Jeff [mailto:Telander.Jeff@epa.gov]

Sent: Friday, December 12, 2014 9:39 AM

To: Cassidy Mike <MICHAEL.CASSIDY@kohler.com>

Cc: Nizich, Sharon <Nizich.Sharon@epa.gov>; Barnett, Keith <Barnett.Keith@epa.gov>

Subject: RE: Link to proposed NESHAP for Brick and Structural Clay Products Manufacturing; 

and NESHAP for Clay Ceramics Manufacturing is enclosed

Mike,

The questions you have asked are good and it would be best for you to include them when you 

comment on the proposed rule.

With regard to your question concerning the procedure for requesting an extension of the comment 

period, I recommend that you send the request in a letter to:

Keith Barnett

Minerals and Manufacturing Group Leader

Sector Policies and Programs Division

Office of Air Quality Planning and Standards

(D243-04)

RTP, NC 27711

Barnett.Keith@epa.gov

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

Sent: Thursday, December 11, 2014 4:07 PM

To: Telander, Jeff

Cc: Nizich, Sharon

Subject: RE: Link to proposed NESHAP for Brick and Structural Clay Products Manufacturing; 

and NESHAP for Clay Ceramics Manufacturing is enclosed

Jeff,

Below are a few more questions/issues I’d like your take on. Thanks.

Mike

• Spray booth emission limits: Proposed limits apply only to 1 fire glaze booths? It’s clear this 

is the intent from the information in the 11/6/14 memo “MACT Floor Analysis for Clay 

Ceramics” from RTI to EPA, but this intent is not so clear in the proposed MACT. 

• Spray booth emission limits: Proposed limits are based on tons glaze sprayed. Is per ton of 

glaze sprayed on a dry basis or wet basis? I believe we reported all of ICR test results as 

dry basis glaze sprayed.

• Spray booth emission limits: Proposed limits apply to spray booths using only 1F glaze 

containing >0.1% metal HAP. Is this an average of glaze used in a booth or does it apply to 

any color? For instance, most of our glazes are <0.1% HAP. If due to equipment 

breakdown or other reason a facility needs to spray some glaze color that contains >0.1% in 

a booth for 1 work shift, say once per year, does this make this booth subject to the MACT 

rule and the emission limitation? 
• Spray booth emission limits: Does the process throughput during the performance test 

become the defacto throughput limitation going forward? For instance, if a spray booth is 

permitted to apply 250 dry lbs/hr glaze, but due to production considerations, is able to only 

spray 175 lbs/hr during the performance test, is 175 lbs/hr the new spray limit? If so, what if 

emissions measured 40% of the limitation (though throughput was 70% of capacity) in a 

performance test, would the source have any options to spray more glaze than done in the 

performance test considering there’s little indication the limitation could be exceeded?

• 1F Tunnel kiln emission limits: Does the process throughput during the performance test 

become the defacto throughput limitation going forward? For instance, if a tunnel kiln is 

permitted to process 3 tons greenware/hr, but due to production considerations, only fires 2 

tons/hr during the performance test, is 2 tons/hr the new kiln throughput limit? If so, what if 

emissions measured 40% of the limitation (though throughput was 67% of capacity) in a 

performance test, would the source have any options to spray more glaze than done in the 

performance test considering there’s little indication the limitation could be exceeded? This 

same question applies to kiln process parameters like temperature. Variability is an element 

of performance and source operators need some flexibility for source operation when there’s 

no indication that an emission limit can be exceeded. Vitreous plants are highly integrated 

and totally dependent on the processes up and down the process line. You cannot just flip a 

switch to make a tunnel kiln process more ware for a few days of testing, then flip the switch 

back off. Increasing production requires an increase at every process step along the way, 

and it takes considerable time to effect process rate changes.

• 1F Tunnel kiln emission limits: Do the limits apply to all kiln stacks combined or just to the 

POC stack? Tunnel kilns by design have a POC stack as the primary kiln chamber exhaust 

point, and then an additional 2 or 3 stacks for cooling air exhaust. Virtually all of the 

regulated pollutants are emitted from the POC stack. Performance testing the cooling stacks 

is expensive with no benefit. 

• 1F Tunnel kiln emission limits: What is the compliance assurance achieved by requiring 

daily VE reading on tunnel kiln stacks. All of our 1F tunnel kilns are NG fired (propane as 

backup). There is no processing of materials in kilns. Sprayed greenware is carefully placed 

on kiln cars, and kiln cars are carefully transported from the kiln entrance to the kiln 

exit. Nothing about the process generates any particulate emissions. VE readings do not 

provide any indication of kiln operation and so add no value to compliance assurance.

• Shuttle Kilns: We use shuttle kilns to refire ware. That said, many of our shuttle kilns are 

permitted to first fire ware as a contingency measure should we need the flexibility to do so, 

such as might be needed with a tunnel kiln breakdown. If a shuttle kiln does not, and has 

not, processed 1F ware, even though it is permitted to, is it subject to the MACT?

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

Sent: Monday, December 08, 2014 2:50 PM

To: Telander, Jeff

Cc: Nizich, Sharon

Subject: RE: Link to proposed NESHAP for Brick and Structural Clay Products Manufacturing; 

and NESHAP for Clay Ceramics Manufacturing is enclosed

Thank you for the response Jeff. A few more questions below.

• In the same document, in Table A-14, Kiln #2 is not listed. Why was it omitted as a source 

for D/F. 
• Also, the analyses presented in these tables (A-12 through A-14) show kilns 19 and 20 as 

separate sources with the exact same average emission rate and variance. As these two 

kilns exhaust through the same stack, they were tested simultaneously. Should they be 

treated as a single kiln since a single exhaust was tested? Does treating them as two 

distinct kilns, with identical emission rates and variability, minimize the variability calculated 

via the UPL approach, resulting in a lower emission limit for sanitaryware kilns than would be 

the case otherwise?

• In Table 2 of the proposal, item 4 proposes to limit the averaging kiln operating temperature 

at or above the temperature established during the D/F performance test, while item 5 

proposes to limit the averaging kiln operating temperature at or below the temperature 

established during the D/F performance test. These proposals for D/F seem contradictory; is 

one a typographical error? Also, is the “average kiln operating temperature” the temperature 

in the soak zone (peak temperature zone) of the TK? I assume this requirement doesn’t 

make the kiln operator calculate an average temperature across all kiln zones, and then 

average these averages. I think the TK temperature requirement needs to be clarified as to 

intent.

• Once the proposal is published, how do I request an extension to the 60-day comment 

period? I assume I wouldn’t submit it to the docket, so would it be sent directly to Sharon 

Nizich? What is the Agency’s turn-around time on extension requests?

Thanks.

Mike