MEMORANDUM TO: Docket EPA

- HQ

- OAR

- 2013

- 0290

FROM: Sharon Nizich, US EPA

SUBJECT: Discussion with Kohler Company

DATE: March 5 , 2015

A discussion was held today with Kohler Company to provide clarifications on the proposed Clay

Ceramics Rule. Discussion items are attached.

Attending:

Research Triangle Institute:

Kristi n Sroka

Gabrielle Raymond

Tom Holloway

US EPA:

Sharon Nizich

Keith Barnett

Kohler:
Mike Cassidy, Ko hler Wisconsin

AttachmentFrom: Nizich, Sharon

Sent: Thursday, March 05, 2015 8:46 AM

To: MICHAEL.CASSIDY@kohler.com

Cc: Tom H

Subject: FW: Clarifications for Kohler

Hello Mike

– Here are answers to most of your questions.

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: Wednesday, March 04, 2015 11:50 AM

To: Nizich, Sharon

Subject: RE: Your phone call

Hi Sharon, tomorrow morning at 9am EST is fine for me for a phone call. My follow

- up questions

are below.

Mike

· 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 consid erations, 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 opt ions to spray more glaze than done in the performance test considering there’s little indication the limitation could be exceeded?

Response : There is no throughput limit for spray booths in the proposed rule. However, the operating limits for spray boo ths (Table 2 to Subpart KKKKK of Part 63) would be established during the initial performance test, so you would have to meet the operating limits established at the throughput used during that test. If the operating conditions change and the previous cond itions are no longer representative (e.g., change in throughput from 175 to 250 lb/hr), you could always retest to establish new operating limits at the higher throughput. However, it is advisable to go ahead and conduct the initial test at the highest

rep resentative throughput, to avoid additional testing and account for production scenarios when higher throughput is needed. Since there is no throughput limit in the proposed rule, you could spray more glaze, as long as the operating limits are not exceeded on anongoing basis (as applicable) and the emissions limit is not exceeded during the next performance test.

[ CASSIDY: Since the MACT rule does not impose a throughput limitation on glaze spray operations, if the performance test results on a spray bo oth show compliance with the Table 1 emission limits, whether 175 lbs/hr or 250 lbs/hr glaze is sprayed (per example above), the booth is considered to be in compliance with the MACT rule and the only on

- going operating conditions for a source are from Tab le 2, items 8 and 9, which require routine visual inspections of spray booths, but no tracking of glaze use against the quantity of glaze sprayed during the performance test. Is this correct? If this is not correct, more information
is needed, such as mu st glaze use be tracked for each booth on a 3

- hour block average basis?]

Response : Yes, this is correct. You would only need to know the quantity of glaze sprayed during the performance test in order to compare emissions to the emission limit (lb/ton of glaze sprayed).

· 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 greenwar e/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

el ement 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

li ne. 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 p rocess rate changes.

Response : There is a throughput operating limit in the proposed rule for uncontrolled tunnel kilns (item 5b in Table 2 to Subpart KKKKK of Part 63) that would be established during the initial performance test that you would be req uired to meet on an ongoing basis (e.g., 2 tons/hr). There are also other operating limits that you would have to meet, which would be established at the throughput used during the initial test. If the operating conditions change and the previous condition s are no longer representative (e.g., change in throughput from 2 to 3 tons/hr), you could always retest to establish a new operating limit for throughput and new operating limits for the other parameters at the higher throughput. However, it is

advisable to go ahead and conduct the initial test at the highest representative throughput, to avoid additional testing, account for production scenarios when higher throughput is needed, and provide a compliance cushion. For controlled tunnel kilns (no throughput operating limit), you could increase throughput, as long as the operating limits are not exceeded on an ongoing basis (as applicable) and the emissions limit is not exceeded during the next performance test. For uncontrolled tunnel kilns (required throughp ut operating limit), you could not exceed that throughput operating limit.

[ CASSIDY: It appears the only throughput operating limit that will apply to a kiln is per item

5b in Table 2. I understand this condition applies to acid gas (HCL

- equivalent) co mplianceonly, and if performance testing shows the maximum potential HCL

- equivalent emissions are not capable of exceeding the HCL

- equivalent limit in Table 1, then no on

- going process rate monitoring (ware throughput) is required as no operating limit ap plies. Is this

correct? Performance testing for PM, Hg, and D/F is used to assess compliance with the
Table 1 limits, but no on

- going process rate monitoring is required for these HAP; is this

correct? If not, then please explain what process rate moni toring applies as a different process rate will likely be determined for each different HAP emissions test, and it’s unclear which process rate would apply for compliance demonstration. Also, if process rate monitoring will apply, is it to be based on som e 3

- hour block average from the performance

test? If no on

- going process rate monitoring or limitations apply, the only other operating limit I see in Table 2 is for kiln temperature monitoring, with the minimum limit established during the D/F performanc e test. Is this correct? I find the wording in condition §63.8595 and in Tables 1 and 2 to be somewhat confusing and my concern is that the performance test results will be used to significantly limit kiln and spray booth operational flexibility going

fo rward.]

Response : Yes, this is correct. Process rate monitoring would only apply if your HCl

equivalent emissions exceed the limit in Table 1. It is not required for any other pollutants or if your HCl

- equivalent emissions are below the limit i n Table 1. You would need to conduct process rate monitoring during the performance test if you are planning to comply with a lb/ton of fired product emission limit and would need to compare emissions to that limit. The only other operating limits for unco ntrolled kilns are VE (to demonstrate compliance with

non

- Hg metal standard) and kiln peak temperature (to demonstrate compliance with D/F standard). We can discuss specific wording concerns in §63.8595 and Tables 1 and 2 during the call.

On a new topic, why did EPA not evaluate health

- based standards for the other HAP, like Hg and D/F? The preamble identifies that 99.3% of all HAP emitted from kilns are acid

gases. So very little of any other HAP are emitted and EPA’s background information

shows that <3 lbs Hg are emitted per kiln per year, and less than 30 mg D/F are emitted per kiln per year. These rates are so small, that it seems a health

- based compliance option would be appropriate, but I don’t see any information on why or whether this was evalu ated

or not.

Response : CAA section 112(d)(4) provides that for HAP with established health thresholds, the EPA has the discretionary authority to consider such health thresholds when establishing emission standards under CAA section 112(d). HF and HC l were determined to be threshold pollutants (79 FR 75639

- 41). It is unlikely that D/F and Hg would be considered threshold pollutants. D/F is a probable human carcinogen, and some forms of Hg (e.g., methylmercury) are considered possible human carcinogens ( www.epa.gov/iris ), and EPA presumptively concludes that known, probable and possible carcinogens (Group A, B and C pollutants) should not be categorized as threshold pollutants (79 FR 75639).

All of our kilns are uncontrolled. I can envision a scenario where a performance test shows emissions might exceed the Hg or D/F limitations in Table 1. I can further envision that the technical solution might be for add

- on controls to reduce emissions below the Table 1 thr esholds, so a source would be looking at a control device to remove a mg or 2 of D/F per year, or a fraction of a lb of Hg per year. This becomes an outrageously expensive proposition for a source, especially when emissions are so small that do not / may not pose a health or environmental

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

Sent: Wednesday, March 04, 2015 9:29 AM

To: Cassidy Mike

Subject: Your phone call

Hello Mike

I got your voice mail and tried to call but you were not at your desk.

Please email me the question so we can be prepared to discuss. Tomorrow is better for me so let me know if you are available around 9 am eastern time

– thanks.

Sharon Nizich

US EPA

O ffice of Air Quality Planning and Standards Sector Policies and Programs Division/SPPD

RTP NC 27711 (919) 541 2825