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I'm going to take a chance here. Maybe someone can come up with an exception.
It is always legal for any player to touch a grounded ball.
Below are examples of plays where players touch the ball and the foul associated with the play.
It is illegal touching for an offensive lineman to be the first to touch a forward pass behind the neutral zone. It is kick catch interference for K to catch or touch a free-kick in the air or for K to catch or touch a scrimmage kick with an R player in the area.
It is illegal participation for an A or K player to come from OOB on their own. It doesn't matter if they touch the ball or not.
A planned loose-ball play at the snap uses S19 for planned loose-ball infraction.
So it is legal for K to touch a grounded scrimmage kick. If there is a foul there is a flag and a penalty. There is a list of legal plays where there are results similar to penalty enforcements under 2-16-6. If these weren't similar to fouls and not fouls then they would be listed under a different area.
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