,   /,->,.  V     United States        Air Pollution Training Institute  EPA 450/2-80-076
' '' f-   4 "i;   f' '   Environmental Protection    MD 20            March 1980
               Agency           Environmental Research Center
                             Research Triangle Park NC 27711

               Air	



  SEPA      APTI


               Course 444


               Air  Pollution


               Field Enforcement





               Student Workbook

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United States
Environmental Protection
Agency
Air Pollution Training Institute
MD20
Environmental Research Center
Research Triangle Park NC 27711
EPA 450/2-80-076
March 1980
Air
APTI
Course 444
Air  Pollution
Field  Enforcement

Student  Workbook
Exercises 1—5 prepared by:

Charles W. Gruber
Cincinnati, Ohio
with
Pamela M. Giblin
Attorney at Law
Austin, Texas

Under Contract No.
68-02-3014
EPA Project Officer
James 0. Dealy

Exercise 6 prepared by:

Applied Science Associates, Inc.
Valencia, Pennsylvania

Under Contract No.
68-02-1315
EPA Project Officer
Michael C. Osborne

United States Environmental Protection Agency
Office of Air, Noise, and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, NC 27711
                               U.S.  Environmental Protection Agency
                               Region V, Library
                               230  South Dearborn Street
                               Chicago, Illinois  60604

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                                   Notice

This is not an official policy and standards document. The opinions, findings, and
conclusions are those of the authors and not necessarily those of the Environmental
Protection Agency. Every attempt has been made to represent the present state of
the art as well as subject areas still under evaluation. Any mention of products or
organizations does not constitute endorsement by the United States Environmental
Protection Agency.
                Availability of Copies of This Document

This document is issued by the Manpower and Technical Information Branch, Con-
trol Programs Development Division, Office of Air Quality Planning and Standards,
USEPA.  It was developed for use in training courses presented by the EPA Air Pollu-
tion Training Institute and others receiving contractual or grant support from the
Institute. Other organizations are welcome to use the document for training purposes.

Schools or governmental air pollution control agencies establishing training programs
may receive single copies  of this document,  free of charge, from the Air Pollution
Training Institute, USEPA, MD-20, Research Triangle Park, NC 27711. Others may
obtain copies, for a fee, from the National Technical Information Service,  5825 Port
Royal Road, Springfield, VA 22161.
                   U,S.  Environmental Protection Agency

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        *              AIR POLLUTION TRAINING INSTITUTE
        
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                                TABLE OF CONTENTS
EXERCISE NO. 1
Section 1, Off-site Surveillance
(Opacity Violation of Incinerator)

Section 2, On-site Inspection
(Follow up of Section 1)
Page
 1-4


 1-9
EXERCISE NO. 2
Inspection of a Cement Plant
 2-1
EXERCISE NO. 3
Trial of Opacity and TSP
Violations
 3-1
EXERCISE NO. 4
Complaint Handling — Odor Complaint
Case Study
 4-1
EXERCISE NO. 5
Complaint Inspection of an Asphalt
Concrete Batching Plant
 5-1
EXERCISE NO. 6
Inspection of Combustion Sources
 6-1
                                        lv

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STUDENT EXERCISE NO. 1
   OPACITY VIOLATION

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                             STUDENT EXERCISE NO.  1

                        HENDERSON COUNTY, STATE OF OHIO

     SECTION I (LESSON 4) - OPACITY  VIOLATION, OFF-SITE SURVEILLANCE

     SECTION II (LESSON 5) - ON-SITE INSPECTION, FOLLOWING OPACITY OBSERVATION
GOAL.         Practice in the application of principles taught during
              the day.
OBJECTIVES.   At the end of this exercise, the student should have
              demonstrated his ability to:

              1.  Read and apply rules and regulations which are not
                  familiar to the student.

              2.  Objectively determine, from given data on a series of
                  opacity readings, that a violation, in fact, has
                  occurred and relate such observation to the Rules and
                  Regulations violated.

              3-  Write a notice of violation of a visible emission rule.

              4.  Determine the information to be obtained during the
                  on-site inspection.
              5.  Identify errors in a poorly conducted on-site
                  inspection.

              6.  Identify all potential violations discovered during
                  the on-site inspection.

              ?.  Write a report documenting the on-site inspection.
 INSTRUCTIONS. The Exercise has two sections:
              Section I follows Lesson 4 and Section II follows Lesson 5.

              Because of  the time limitations, carefully abide by  the
              following instructions:

              1.    Work as a team of two or three to be assigned.

              2.    Read the case history and do the work called for in
                    the case study.
                                    1-2

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3-  Only one completed answer sheet is required for each
    Team.  All members should sign to record their
    participation.

4.  following each Lesson (4 and 5), forty (40) minutes
    will be allotted to complete the answer sheets.

5-  After 40 minutes, the instructor will call for reports -
    question by question - at random from the various Teams.
    The spokesman will respond.

6.  Each point will be discussed.

?.  At the completion of Section I and Section II, an
    answer sheet will be available to each student to
    compare against the work of his team.

8.  Collection of the reports for review by the instructor
    is optional.   If collected,  the Team Reports should be
    returned the next day.
                         1-3

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                           STUDENT EXERCISE NO.  1
                           SECTION I - (LESSON 4)
                             OPACITY VIOLATION
                           HENDERSON COUNTY, OHIO.
                           OFF-SITE SURVEILLANCE
This case study of a multiple-chamber incinerator smoke violation describes
the observation of the emissions,  entry of the facility,  and inspection
of the equipment.  Carefully read the following material.   Do the assignment
required for each lesson.  Use Section II,  Rules and Regulations,  as
applying to this source.

Inspector John Hubbard, who has been with his agency for six months,  is
patrolling Sector 2, the southeastern part of Henderson County,  Ohio  on
July 15, 1978.  At 8:10 A.M. he observes a plume of black smoke located
approximately one mile to the east of his vehicle.  Traveling east,  he is
soon able to park his car approximately 75 feet west of the source of the
plume.  Hubbard notes a large sign painted on the side of the building
reading "Johnson Storage Co".  The source turns out to be a small multiple-
chamber incinerator having an approximately 1 ft. diameter x 12 ft.  high
steel stack equipped with a spark arrester.  The incinerator is located in
the rear of a three-story brick building that appears to be a warehouse.
The wind is from the south at approximately five miles per hour.

The inspector gets out of his car and stands alongside of it.  Using his
own watch and a stop watch, he begins to record his observations of the
emissions as of 8:15 on the agency observation form.  The results of the
observation axe shown on the following page.

The incinerator is unattended during the entire observation.  In fact,
no one  is present in the yard, and the premises appear to be abandoned.
He notices two 50-gallon oil drums near the incinerator, but from his
vantage point, he cannot see the contents.
                                   1-4

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At this point begin the exercise for Lesson 4.  Except for the reference to
the appropriate regulations, do not read the case beyond this point as time
is limited and the actions and reactions to the questions will lose their
realism if such is done.
Each team is required to submit one copy of the following assignments,
completed and signed by each member of the team.

1.  Complete the Visible Emission Observation Form using the data given
    in the case narrative report.  If any necessary information was
    omitted 3n the description of Hubbard1s actions, make reasonable
    assumptions which would validate the visible emission observation
    results.  Circle or underline assumed data.

2.  Enter on the front of the "Notice of Violation" form only that data
    which is valid to this point.

J.  State the Rule violated and duration of the violation.

4.  Decide on the on-site inspection strategy.
    On the answer sheet write the three most Important pieces of information
    to be obtained during the inspection.
4.  State three important pieces of Information which are necessary to
    complete the documentation of this opacity violation to be obtained
    during the on-site  inspection.

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                             STUDENT EXERCISE NO.  1
                               SECTION I  (LESSON 4)

                                  ANSWER SHEET

TEAM      	           MEMBERS SIGN:
1.  Completed Visible Emission Observation Form.  Do not turn in.

2.  Enter on the Notice of Violation Form that information Which is valid
    to this point in time.
3.  The rule violated was            	
    Aggregate (length) of violation  	  ._ minutes

4.  The on-site inspection should produce the following information to
    complete the documentation of this violation.
          1.
          2.
                                   1-7

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     Henderson County Air Pollution Control
               Henderson, Ohio
          NOTICE  OF VIOLATION
TNSTAIUNQ'CONTRACTOR
                                          CITY"
 YOU ARE HEREBY NOTIFIED THAT PURSUANT TO SECTION
 	OF THE HEALTH AND SAFETY CODE OF THE
 STATE OF  OHIO    A MISDEMEANOR HA2i BEEN COM-
 MITTED THROUGH THE          	
 POINT OP OlSERVATIONi
WEATHER:
ARRlVALt JJ
• DEPARTURIt JJ
V.AS SOURCE EMIHING
VISIILE DISCHARGE AT
END OF OISERVATION?
_ns u NO n
M. N* OH
OPACITY
EMISSION JJJJ;to.
FROM! ^ONUOl
OPEN FIRE
P.rmlt
N«. _
WIND N JS W
VISIILi EMISSIONS OlSEftVED
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                       1-8

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                          STUDENT EXERCISE NO. 1  (CONT'D)
                             SECTION II  (LESSON  5)

                               OPACITY VIOLATION
                             HENDERSON COUNTY,  OHIO

                               ON-SITE INSPECTION

            CONTINUATION OF HENDERSON COUNTY  OPACITY VIOLATION

After completing his pre-entry surveillance,  Hubbard drives to  the  front
of the plant and parks his car and enters the premises.

Inside, he meets a receptionist, identifies himself and his agency,  and
asks to see the owner of the company.  She replies that the owners  are not
present, as the headquarters office of the company is located in Chicago,
Illinois, and asks what it is he wants.  Hubbard replies that the incinerator
appears to be in violation.  Thereupon, the receptionist directs him to
see the bookkeeper, Mr. Peterson.

She rings Mr. Peterson who presently arrives.  After a quick introduction,
the inspector informs Mr. Peterson that he has observed smoke in excess of
allowable limits and that he is in violation of Henderson County APCD Rule
50.  He then asks to see the incinerator.  Mr.  Peterson replies, "I didn't
know we are in any kind of violation.  I don't see how that could be —
we have the necessary permit to operate.  As I understand it, that's
supposed to be a smokeless incinerator."

As they walk through the plant  to the rear, the first floor is comparatively
empty  except for some apparently new equipment in the rear of the plant.
There  appear to be a degreasing unit and five tanks (two of which have
buss bars, drains, etc., suitable for plating use).  The inspector also
notices that part of the cement flooring is broken  up as if to make way for
new plumbing, and that unassembled ventilation system parts, including
hooding, a blower motor and fan, are located near the tanks.
                                  1-9

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The inspector asks Mr. Peterson What business the company is engaged in.
Mr. Peterson replies, "Hard chrome plating —we're the Hartley Division,
Compton Metals Company."  In further conversation, the inspector learns
that the company moved to this location just three months ago.

They arrive at the incinerator at 9:09 A.M.  No visible emissions are
observed.  Mr. Peterson exclaims, "See, it's not smoking!"  The inspector
explains that he observed a violation before he entered the plant, and asks
who lit the incinerator.  Peterson replies, "I did.  Mr. Allan, the Plant
Manager, asked that I clean out the debris left from the previous tenant.
I've been doing this sort of thing since we are still short of custodial
help."  On further questioning, Mr. Peterson disclosed that he had charged
                                    *.
two 50-gallon drums of paint cans, styrofoam packing materials, creosoted
wood timbers, rubber and plastic materials, cardboard and paper wastes,
and rubber and plastic gasket materials in the incinerator.

Hubbard inspects the interior of the incinerator and observes evidence
of paint cans and rubber and plastic residue.  The interior appears to be
in good condition.  He notes a slightly smouldering burning pile, 2 ft. in
diameter x 1 ft. high.  The inspector also observes the following:

          -  A permit posted on the side of the incinerator made
             out to "Johnson Storage Co.", 5678 S. Main St.,
             Henderson, Ohio,       Permit No. P-593^, dated
             Sept. 15, 1977 authorises the operation of one (l)
             ACME Multiple-Chamber retort type incinerator rated
             at 75 Ibs./hour,  equipped with 1-Larkin manual
             secondary gas burner rated at 150 x 103 Btu/hour.
             Incinerator to be used for Type 0" waste only.  Secondary
             burner must be in operation through all burning periods.
          -  Secondary burner not in operation.
          -  All air port doors were closed.
          -  Refractories and stack appear to be in good condition.
          -  Two sampling ports are noted in the stack.

 The case study ends here, but not necessarily' the inspection.
 At this point begin the exercise for Lesson  5«
                                   1-10

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                         EXERCISE TOR LESSON 5
1.  List at least five (5) important errors pertaining to different
    principles of good on-site inspection and investigative practice.

2.  List the number of potential violations and specify the Rule which
    has "been violated.

3.  Complete the Notice of Visible Emission Violation form, "both
    front and back.  Again make assumptions and circle or underline
    where assumptions were necessary to complete the notice and report.

4.  If so instructed, each Team is to turn in one answer sheet with the
    completed Observation Form and Notice of Violation Form, signed
    by all members of the Team.
                                1-11

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                            STUDENT EXERCISE NO. 1

                                 SECTION II

                                  LESSON 5


                                ANSWER SHEET


TEAM    	               MEMBERS SIW
1.  List at least five important errors pertaining to different principles
    of good on-site inspection and investigative practice.

    1.
    2.
    3-
    6.
                                    li-12

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                           STUDENT EXERCISE NO. 1

                                LESSON 5

                              ANSWER SHEET     (OONT'D)
2.  List the num"ber of potential violations and specify the Rule tdiich
    has "been violated.

                    No. of
       Rule        Violations                      Description
3.  Complete the notice of Violation Pbrm, front and "back.
4.  If so instructed, each Team is to turn in one completed Answer Sheet,
    signed "by all memters of the Team and one completed Notice of Violation
    Form, front and "back.
                                   1-13

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OPERATOR
Name & Address
HIS REMARKS
WAS MANAGEMENT CONTACTED    YES
NO
 NAME
                                     TITLE
 HIS REMARKS
          (INCLUDING INSPECTOR'S FULL EXPLANATION OF VIOLATION)
  CORPORATE OFFICER  '
  DRIVER'S LICENSE NO.
  VACATION FROM
   TO
  REQUEST FOR COMPLAINT SIGNED
            DATE

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    CLASSIFICATION OF WASTES TO BE INCINERATED
Clarification of Waste*
 Type   Oaehption   Principal Component*
                        Approximate
                        Composition
                        * by Weight
  •0   Trash
  •1   Rubbish
•2   Refuse


•3   Garbage
       Animal
       solids and
       organ ie
       waste*
   5   Gaseous,
       liquid or
       Mmi-Uquid
       Semi-solid
       aad«olid
 Highly combujcible
 MM, paper, wood,
 carboard cartons,
 including up to 10%
 treated papers,
 plastic or rubber
 scraps; commercial
 and industrial
 sources

 Combustible waste,
 paper, canons, rags,
 wood scraps, combustible
 door sweepings;
 domestic, commercial,
 and industrial sources

 Rubbish and garbage;
 residential sources

 Animal and vegetable
 wastes, restaurants,
 hotels, markets;
 institutional,
 commercial, and
 club sources
•
 Circuses, organs,
 solid organic wastes;
 hospital, laboratory,
 abattoirs, animal
 pounds, and similar
 sources

 Industrial
 process wastes
 Combustibles requiring
 hearth, retort, or grate
 burning equipment
                                           Trash 100%
                                           Rubbish 80%
                                           Garbage 20%
                                             Rubbish $0%
                                             Garbage 50%

                                             Garbage 65%
                                             Rubbish 35%
                                           100% Animal
                                           and Human
                                           Tissue
                                           Variable
                                           Variable
   RELATIONSHIP BETWEEN  R AND OPACITY
        •R" NO.
          OPACITY
           0
           1
           2
           3
           4
           5
               0
             20
             40
             60
             80
            100
                  1-15

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                     SPECIMENS OF RULES AND REGULATIONS

              HENDERSON COUNTY AIR POLLUTION CONTROL DISTRICT



                            REGULATION II PERMITS


Rule 1.   DECLARATION OF POLICY AND THE PURPOSE

          It is hereby declared to be the public policy of this

          Henderson County Air Pollution Control District and the purpose

          of this regulation to achieve and maintain such levels of air

          quality as will protect human health, life, and safety or comfort.


Rule 2.   DEFINITION OF TERMS

          (a)  Air Contaminant.  Any smoke, soot, fly ash, dust, cinders,'
               cinders, dirt, fumes, gases, vapors, mists, liquid, particu-
               late or odorous matter, not including uncombined water vapors.

          (b)  Air Pollution.  The presence in the ambient air of one or
               more air contaminants or any combination thereof in such
               quantity and of such characteristics and duration as to injure
               or tend to injure human health or welfare, plant or animal
               life, or property, or which would interfere with the enjoy-
               ment of life or use of property.

          (c)  Effective Date of Regulation.  This date shall be July 1, 1975,
               notwithstanding any amendment, rescission, or renumbering of
               of any of these regulations.

          (d)  Emission.  Act of releasing or discharging any air pollutant
               into the ambient air from any source.

          (e)  Opacity.  A state which renders material partially or riiolly
               impervious to rays of light and causes obstruction of an
               observer's view.

          (f)  Person.  Any individual, firm, public or private corporation,
               association, business, trust, company, partnership, contractor,
               supplier, installer, user, operator, or owner, or any political
               subdivision or employee thereof, or any other entity.

          (g)  RJAgelmann Chart.  The chart published and described in the
               United States Bureau of Mines Information Circular 8333
               (May, 196?).

          (h)  Source.  Any operation, or real or personal property, or
               person which emits or may emit any air pollutant.

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Specimens of Rules and Regulations  (Cont'd)
Henderson County Air Pollution Control District
Rule 10.   PERMITS RETIRED

           (a)  Authority to Construct.  Any person "building, erecting,
                altering or replacing any article, machine, equipment or
                other contrivance, the use of which may cause the issuance
                of air contaminants or the use of which may eliminate or
                reduce or control the issuance of air contaminants, shall
                first obtain authorisation for such construction from the
                Air Pollution Control Officer.  An Authority to Construct
                shall remain in effect until the permit to operate the
                equipment for which the application was filed is granted
                or denied or the application is canceled.

           (b)  Permit to Operate.  Before any article, machine, equipment
                or other contrivance descri"bed in Rule 10(a) may "be operated
                or used, a written permit shall "be obtained from the Air
                Pollution Control Officer.  No permit to operate or use shall
                "be granted either "by the Air Pollution Control Officer or the
                Hearing Board for any article, machine, equipment or contri-
                vance described in Rile 10(a), constructed, or installed
                without authorization as required by Rule 10(a), until the
                information required is presented to the Air Pollution Control
                Officer and such article, machine, equipment or contrivance is
                altered, if necessary, and made to conform to the standards set
                forth in Rule 20 and elsewhere in these Rules and Regulations.

           (c)  Posting of Permit to Operate.  A person who has been granted
                under Rule 10 a permit to operate any article, machine, equipment,
                or other contrivance described in Rule 10(b), shall firmly affix
                such permit to operate, an approved facsimile, or other approved
                identification bearing the permit number upon the article, machine,
                equipment, or other contrivance in such a manner as to be clearly
                visible and accessible.  In the event that the article, machine,
                equipment, or other contrivance is so constructed or operated
                that the permit to operate cannot be so placed, the permit to
                operate shall be mounted so as to be clearly visible in an
                accessible place within 25 feet of the article, machine, equip-
                ment, or.other contrivance, or maintained readily available at
                all times on the operating premises.

           (d)  A person shall not willfully deface, alter, forge, counterfeit,
                or falsify a permit to operate any article, machine, equipment,
                or other contrivance,,
                                    1-18

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Specimens of Rules and Regulations  (Cont'd)
Henderson County Air Pollution Control District
Rule 12.   TRANSFER
           An authority to construct, permit to operate or permit to sell
           or rent shall not "be transferable, Aether by operation of law
           or otherwise, either from one location to another, from one piece
           of equipment to another, or from one person or corporation to
           another.
Rule 19.   PRO VISION OF SAMPLING AND TESTING FACILITIES

           A person operating or using any article, machine, equipment or
           other contrivance for which these rules require a permit shall
           provide and maintain such sampling and testing facilities as
           specified in the authority to construct or permit to operate.


                       REGULATION IV.   PROHIBITIONS


Rule 50.   CONTROL OF VISIBLE AIR CONTAMINANTS FROM STATIONARY SOURCES

           (a)  Emission Limitations

                1.  No person shall discharge into the atmosphere from any
                    single stationary source of emission whatsoever, any
                    air contaminant of a shade or density equal to or darker
                    than that designated as No. 1 on the Ringelmann Chart or
                    20 percent opacity, except as set forth in subsection
                    (a) (2) and section (b) of Rule 50.

                2.  A person may discharge into the atmosphere from any
                    single stationary source of emission for a period or
                    periods aggregating not more than three (3) minutes in
                    any sixty (60) minutes, air contaminants of a shade or
                    density not darker than No. 3 on the Ringelmann Chart or
                    60 percent opacity.

           (b)  Uncombined Water

                It shall "be deemed not to be a violation of Rule 50 (a)•
                where the presence of uncombined water is the only reason
                for failure of an emission to meet the requirements of
                Rule 50 (a).
                                   1-19

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Specimens of Bales and Regulations  (Cont'd)
Henderson County Air Pollution Control District
Rule 5L.   NUISANCE

           A person shall not discharge from any source tihatsoever such
           quantities of air contaminants or other material which cause
           injury, detriment, nuisance or annoyance to any considerable
           number of persons or to the public or which endanger the
           comfort, repose, health or safety of any such persons or the
           public or which cause or have a natural tendency to cause
           injury or damage to business or property.
Rule 52.   PARTICULATE MATTER.

           Except as otherwise provided in Rules 53 and 54,  a person shall
           not discharge into the atmosphere from any source particulate
           matter in excess of 0.2 grain per cubic foot of gas at standard
           conditions.
Rule 53.   SPECIFIC CONTAMINANTS.

           A person shall not discharge into the atmosphere from any single
           source of emission whatsoever any one or more of the following
           contaminants, in any state or combination thereof,  exceeding
           in concentration at the point of discharge:

           (a)  Sulphur Compounds calculated as sulphur dioxide (802):
                0.1 per cent, by volume.

           (b)  Combustion Contaminants:  0.2 grain per cubic foot of gas
                calculated to 12 per cent of carbon diox3.de (002) at
                standard conditions.  In measuring the combustion contaminants
                from incinerators used to dispose of combustible refuse by
                burning, the carbon dioxide (002) produced by combustion of
                any liquid or gaseous fuels shall be excluded from the
                calculation to 12 per cent of carbon dio3d.de (002).


Rule 54.   DUST AND FUMES

           A person shall not discharge in any one hour from any source
           whatsoever dust or fumes in total quantities 3n excess of the
           amount shown in the following tables  (see next page)

           To use the following table, take the process weight per hour as
           such is defined in Rule 2(j).  Then find this figure on the table,
           opposite which is the maximum number of pounds of contaminants which
           may be discharged into the atmosphere in any one hour.  As an
                                   1-20

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Specimens of Rules and Regulations  (Cont'd)
Henderson County Air Pollution Control District
           example, if A has a process which emits contaminants into the
           atmosphere and which process takes 3 hours to complete, he will
           divide the weight of all materials in the specific process, in
           this example, 1,500 Ibs. by 3 giving a process weight per hour
           of 500 rbs.  The table shows that A may not discharge more than
           1.77 Its. in any one hour during the process.  Where the process
           weight per hour falls "between figures in the left hand column,
           the exact weight of permitted discharge may be interpolated.


Rule 57.   OPEN FIRES

           A person shall not turn any combustible refuse in any open outdoor
           fire within Henderson County, except:

           (a)  When such fire is set or permission for such fire is given in
                the performance of the official duty of any public officer,
                and such fire in the opinion of such officer is necessary:

                1.  Pbr the purpose of the prevention of a fire hazard rtiich
                    cannot be abated by any other means, or

                2.  The instruction of public employees in the methods of
                    fighting fire.

           (b)  When such fire is set pursuant to permit on property used
                for industrial purposes for the purpose of instruction of
                employees in methods of fighting fire.

           (c)  When such fire is set in the course of any agricultural
                operation in the growing of crops, or raising of fowls or
                animals.

           These exceptions shall not be effective any any calendar day on
           which the Air Pollution Control Officer determines that:

                1.  The inversion base at 4:00 A.M., Eastern Standard Time,
                    will be lower than 1,500 ft. above mean sea level, and

                2.  The maximum mixing height will not be above 3,500, and

                3>  The average surface wind speed between 6:00 A.M. and
                    12:00 noon, Eastern Standard Time, will not exceed
                    five miles per hour.
                                  1-22

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Specimens of Rules and Regulations  (Cont'd)
Henderson County Air Pollution Control District
Rule 58.   INCINERATOR BURNING
           A person shall not "bum any combustible refuse in any incinerator
           within the Henderson County, except in a multiple-chamber
           incinerator as described in Rule 2(p), or in equipment found by
           the Air Pollution Control Officer in advance or such use to "be
           equally effective for the purpose of air pollution control as an
           approved multiple-chamber incinerator.
Rule 60.   CIRCUMVENTION
           A person shall not "build, erect, install, or use any article,
           machine, equipment or other contrivance, the use of which,
           without resulting in a reduction in the total release of air
           contaminants to the atmosphere,, reduces or conceals an emission
           which would otherwise constitute a violation of Division 20,
           Chapter 2 of the Health and Safety Code or of these Rules and
           Regulations.  This Rule shall not apply to cases in which the
           only violation involved is of the Health and Safety Code, or
           of Rule 51 of these Rules and Regulations.
                                  1-23

-------
   STUDENT EXERCISE NO. 2
INSPECTION OF A CEMENT PLANT

-------
                         INSPECTION OF A CEMENT PLANT
                                  (FILM)
GOAL.          To demonstrate off-site and on-site Inspection procedures
               by depicting on film a permit status inspection of a
               cement plant.  The student's proficiency is tested by
               completing inspection report forms to record conditions
               shown in the film.
OBJECTIVES.    At the end of this exercise,  the  student  should be able  to:


               1.  List the elements included in a facility inspection.

               2.  Describe the basic process of manufacturing
                   Portland cement (dry process).

               3.  Use existing agency data to prepare for an
                   inspection.

               4.  Properly obtain entry to a facility for the
                   purpose of conducting an inspection.

               5.  Interface effectively with plant management and
                   personnel so as to elicit their help and
                   cooperation.

               6.  List inspection points for cement plants.

               7.  Examine the appropriate inspection points for
                   permit compliance.
SELECTED READING:  Inspection Manual for Enforcement of New Source
                   Performance Standards.  Portland Cement Plants.
                   Reference 7.1
                                  2-2

-------
                         INSTRUCTIONS FOR EXERCISE NO. 2



This unit centers around a film showing an FEO conducting a routine inspection

of a dry type cement plant.  The student observes the movement of the FEO and the

results of his inspection.  After the film is shown, the student is required to

complete his own inspection findings using the data gathering form starting on

page 2-4.  When all students are finished, your completed findings will be com-

pared to those of the instructors, and the session ends with a discussion of the

lesson and student work.
NOTE:  Most of the data you need to complete the form can be determined from
       viewing the film, but some information you may need can be found in
       this section.
                                       2-3

-------
              SUGGESTED INSPECTION POINTS AND DATA GATHERING QUESTIONS

                        CEMENT PLANT  KILN AND CLINKER COOLER*




            The plant perimeter
             Control room instrument readings* (Points 1A, IB, & 1C! on flow diagram)
            Delivery end of Kiln  (Point 2B)
             Clinker cooler enclosure (Point 3A)
             Dust return spout and conveyor  (Point
             Clinker cooler "ba^iouse (Point 4)
             *Refer  to the drawings at the end  of this form,  for a
             plant flow diagram  indicating inspection points  and for
             actual  control room instrument  readings.
-v
                                          2-4

-------
Bag cleaning compressor (Point 4)
Clinker cooler baghouse fan and motor  (Point 4)
Clinker cooler "baghouse  stack  (Point 4)
Itilti-cyclone pre-heater (Shown  in  film - not shown on film diagram)
Kiln "baghouse  enclosure  and stack (Point 5)
Area "below kiln  "baghouse (Point 5A)
Kiln  "baghouse manometers*
*Refer to the drawings at the end of this form.






                                  2-5

-------
Kiln baghouse hoppers and screw conveyor  (Point 5A)
Kiln baghouse dust return system (Point 5A)
Kiln baghouse fan and motor (Point 5)
Plant Yard
                               2-6

-------An error occurred while trying to OCR this image.

-------An error occurred while trying to OCR this image.

-------


Illllilill
0 ,10 20
JLLUJ'MJJ




i ) | 2

tfjT
,
COOLER
DUST COLL INL!
TEMPERATURE

Illllllllll
3O 4O SO
J1 UK Mill

Si " °
III ' I'l °
'Ttij.ln! o
TT • r 1
|= SO
-EM i °
0

ET



    Clinker Cooler Gas
    Inlet Temperature
   in Degrees Farenheit
  (Temp. « chart number x 10)

    (Recorder located in Control Room)
       tCHES OF W^TER

         10    15
      BAGHOUSE
      PRESSURE
Kiln Baghouse System Pressure

• (Overall baghouse pressure)
2-9

-------An error occurred while trying to OCR this image.

-------
Cement Plant Pile Information

    Permit Application
    Kiln Data
    Kiln Baghouse Data
    Clinker Cooler Data
    Clinker Cooler Baghouse Data
-   Summary of Source Operation - Kiln
    Summary of Pitot Traverse Data - Kiln
    Summary of Particulate Sampling Data -
    Kiln
                              •
    Summary of Source Operation - Clinker
    Cooler
    Summary of Pitot Traverse Data - Clinker
    Cooler
    Summary of Particulate Sampling Data -
    Clinker Cooler
                 2-11

-------
                                                      STATE  OF  ILLINOIS
                                                ENVIRONMENTAL PROTECTION AGENCY
                                              DIVISION OF AIR POLLUTION CONTROL
                                                     2200 CHURCHILL ROAD
                                                 SPRINGFIELD, ILLINOIS (2706
MKE OF EQUIPMENT TO BE
CONSTRUCTED OR OPERATED
APPLICATION FOR A PERMIT,., . „
r-i r-i "'
U CONSTRUCT QU OPERATE memi,
PERM]
QAYF
Cement Plant r*}
FOR AGENCY USE ONLY .,
T H.



1,,
„
1C.
in.
NAME OF OWNER:
Ajax Cement Corporation
STREET ADDRESS OF OWNER:
100 Park AVenue
CITY OF OWNER:
New York
STATE OF OWNER:
New York




It. ZIP CODE:
10101
a. KAMI OF OPERATOR:
Ajax Cement Corporation
2b. STREET ADDRESS OF
. 123 River
OPERATOR:
Street
2c. CITY OF OPERATOR:
Clearview
2d. STATE OF OPERATOR
Illinois
2*. ZIP CODE:
60000
•.
3i. NAME OF CORPORATE DIVISION OR PLANT:
Riverview Plant
3c. CITY OF EMISSION SOURCE:
Clearview

4,
i.
ALL CORRESPONDENCE TO:
Donald Carson
3d. LOCATED WITHIN CITY
LIMITS:,-, r,
B YES U NO
3t>. STREET ADDRESS OF
123 River
3«. TOWNSHIP:
Smith

(NAME OF INDIVIDUAL)
ADDRESS FOR CORRESPONDENCE: (CHECK ONLY
Downr R : K! OPE RATOR
ONE)
TlmiSSION SttJSCF
EMISSION SOURCE:
Street
3f. COUNTY: 3g. ZIP CODE:
Jones 600,00
j*.
S. TELEPHONE NUMBER FOR ACiENCY TO CALL:
800/555-4567
7. YOUR ID NUMBER FOR THIS APPLICATION:,,,
RP2973 (c)
THE UNDERSIGNED HEREBY HAKES APPLICATION  FOR A PERMIT AND CERTIFIES THAT THE STATEMENTS CONTAINED HEREIN ARE TRUE AND CORRECT, AND
FURTHER CERTIFIES THAT ALL PREVIOUSLY SUBMITTED  INFORMATION REFERENCED IN THIS APPLICATION REMAINS TRUE, CORRECT AND CURRENT.
BY AFFIXING HIS SIGNATURE HERETO HE FURTHER CERTIFIES  THAT  DIE tS AUTHORIZED T» EXECUTE THIS APPLICATION.
AUTHORISED SIGNATURE^):
                        ,-)
BY A.'fi+si.LJ C CL WC'TL
SIGNATURi
Donald Carson
YVPlfc bft TAINTED NAME OF SIGNER
2/9/73
DATE

                                                                       BY
                                                                          SIGNATURE
                                                                                                                        DATE
                                                                          TYPED OR PRINTED Hint Or SIGNER
   TITLE OF SIGNER
                                                                          TITLE OF SIGNER
                                                                                                                THIS FORM MAY
(A)  THIS FORM IS TO PROVIDE THE AGENCY WTTH GENERAL INFORMATION ABOUT THE  EQUIPMENT TO BE CONSTRUCTED OR OPERATED.
    ONLY BE USED TO REQUEST ONE TYPE OF PERMIT - CONSTRUCTION OR OPERATION - AND NOT BOTH.

IB)  CLEARLY IDENTIFY THE GENERIC NAME OF THE EQUIPMENT TO BE CONSTRUCTED OR OPERATED.  SUCH  IDENTIFICATION  WILL  APPEAR ON  THE
    PERMIT WHICH NAY BE ISSUED PURSUANT TO THIS APPLICATION.  THIS FORM MUST BE ACCOMPANIED  BY THE APPLICABLE ADDENDA.

(C)  PROVIDE A NX1BER M HEM 7 ABOVE WHICH YOU WOULD LIKE THE AGENCY TO USE FOR  IDENTIFICATION OF TOUR  EQUIPMENT.   YOUR  IDENTIFICATION
    NUMBER WILL BE REFERENCED IN ALL CORRESPONDECE. RELATIVE TO THIS APPLICATION. FROM  THIS A6EMCY.  TOUR  IDENTIFICATION  NUMBER MUST
    IIOT EXCEED TEN (10) CHARACTERS.                .

(0)  THIS APPLICATION MUST BE SIGNED IN ACCORDANCE WTTH PCB REGS.. CHAPTER  2. PART  1. RULE  103UH4) OR  103(b)(5) WHICH STATES:
    •ALL APPLICATIONS AND SUPPLEMENTS THERETO SHALL BE SIGNED BY THE OWNER AND OPERATOR  OF THE MISSION SOURCE OR AIR  POLLUTION
    CONTROL EQUIPMENT, OR THEIR AUTHORIZED AGENT. AND SHALL BE ACCOMPANIED BY  EVIDENCE OF AUTHORITY TO  SIGN THE  APPLICATION.*

    IF THE OWNER OR OPERATOR IS A CORPORATION. SUCH CORPORATION MUST HAVE  OK FILE  WITH THE AGENCV A CERTIFIED COPY  OF  A  RESOLUTION
    OF THE CORPORATION'S BOARD OF DIRECTORS AUTHORIZING THE PERSONS SIGNING THIS APPLICATION TO  (WISE OR ALLOW THE  COKSTRUCTION OR
    OPERATION OF THE EQUIPMENT TO BE COVERED BY THE PERMIT.      2-12

-------
                                                                      OUTSIDE OF THE CWPORATE UMITS OF CHICAGO «T BE
               In QUADRUPLICATE.
A CONSTRUCTION
                    PERMIT APPLICATION M ALL OTHER LOCATIONS NET BE SUBMITTED  III TRIPLICATE.
10.
THE APPLICANT SHALL SUBMIT A PLOT PLAN AND MAP SMOKING DISTANCES TO THE NEAREST BOUNDARY OF THE PROPERTY  ON MUCH THE OPERATION IS
LOCATED AND DISTANCES TO THE NEAREST RESIDENCES. LODGINGS. URSINE HOMES. HOSPITALS. SCHOOLS AND COMMERCIAL AND MANUFACTURING   .
ESTABLISHMENTS.  IF SUCH A PLOT PLAN AND NAP HAS ALREADY BEEN SUBMITTED, INDICATE THE ASSOCIATED AfiENCY 1.0.  VtBER AND  PEWIT
APPLICATION NUMBER.  AfiENCY I J>. NO.                                 APPLICATION NO.
 11.   THE APPLICANT SHALL  SUBMIT A PROCESS FLOW DIAGRAM DEPICTING ALL EMISSION SOURCES AND ALL AIR POLLUTION CONTROL EQUIPMENT COVERED
      BY THIS PERMIT APPLICATION.  THE DIAGRAM SHALL INCLUDE LABELS FOR EACH EMISSION SOURCE  AND EACH  ITEM OF AIR POLLUTION CONTROL
      EQUIPMENT. AND SHALL SET FORTH MAXIMUM FLOW RATES FOR (1) ALL PROCESSING EQUIPMENT. (2) ALL AIR  POLLUTION CONTROL EQUIPMENT. (1)
      ALL EMISSION SOURCES. AW  (4) ALL  STACKS AND VENTS.  NUMBER OF SHEETS:        •>          DRAWING  NUMBER(S):   1  ft  2

 12-   FOR EACH EMISSION SOURCE AND EACH ITEM OF AIR POLLUTION CONTROL EQUIPMENT  IDENTIFIED ON THE PROCESS FLOW DIAGRAM. THE APPLICANT
      SHALLCOMPLETE ANDSUBMIT THE APPLICABLE PEWIT APPLICATION FORMS.   THE  FLOV DIAGRAM SHALL INDICATE THROUGH *!» STACK OR VENT
      JBrEHlSSION SOURCE OR ITS RELATED AIR POLLUTION CONTROL EQUIPMENT IS EXHAUSTED.   IF irTTtXHAUSTED HITHIN A BUILDING. SO INDICATE.



 „	IF THU  IS AN APPLICATION FOR AN OPERATING PERMIT. AND THE APPLICANT IS INCORPORATING BY REFERENCE PREVIOUSLY GRANTED INSTALLATION
      OR CONSTRUCTION PERMITS.  HE SHALL tOMPLETE FORM  APC-210, ENTITLED 'DATA  AND  INFORMATION - INCORPORATION |Y REFERENCE.*       —
      IF THIS IS AN APPLICATION FOR AN OPERATING PERMIT. AND THE STARTUP OF ANY EMISSION SOURCE DESCRIBED BY  THIS APPLICATION PRODUCES
      AN AIR CONTAMINANT IN EXCESS OF APPLICABLE STANDARDS, THE APPLICANT MAY REQUEST PERMISSION TO EXCEED SUCH STANDARDS  BY COMPLETING
      FORM APC-203.  ENTITLED -OPERATION DURING  STARTUP.*
 15.   IF THIS IS AN APPLICATION FOR AN OPERATING  PERMIT. AND THE APPLICANT IS APPLYING FOR PERMISSION TO ^RATE AN  EMISSION SOURCE
      DURING MALFUNCTIONS OR BREAKDOWNS PURSUANT  TO  PCB REGS.. CHAPTER 2. RULE 105. THE APPLICANT NAY REQUEST SUCH PERMISSION BY
      COMPLETING FORM APC-204, ENTITLED •OPERATION DURING MALFUNCTION AND BREAKDOWN.*
 16.
 IF  THIS  IS AN APPLICATION FOR AN OPERATING PERMIT AND ALL OR ANY PART OF THE  PROCESS MUST BE CONTROLLED OR MODIFIED TO COMPLY
 KITH APPLICABLE REGULATIONS. THE APPLICANT SHALL COMPLETE FORM APC-202. ENTITLED  •COMPLIANCE PROGRAM I PROJECT COMPLETION SCHEDULE.
117.   IF THIS IS AN APPLICATION FOR AN OPERATING PERMIT. DOES THE OPERATION COVERED BY THIS APPLICATION REQUIRE AN EPISODE ACTION
      **"      El*5   	D*	_____	:	
I IS.   MS EACH EMISSION SOURCE COVERED BY  THIS APPLICATION. AS OF APRIL 14. 1972. IN COMPLIANCE WITH THE 'RULES AND REGULATIONS  -.
      GOVERNING THE CONTROL OF AIR POLLUTION/ ADOPTED 8f THE FORMER} IR POLLUTION CONTROL BOARD AND CONTINUED EFFECTIVE  PURSUANT
      TO SECTION 49{e) OF THE ENVIRONMENTAL PROTECTION ACT?        [gj TES            Q NO                                       C\
119.   IF THIS IS AN APPLICATION FOR AN OPERATING PERMIT. HAS THE OPERATION THE SUBJECT OF A VARIANCE-.PETITION FILED WITH THE  ILLINOIS
      POLLUTION CONTROL BOARD ON OR BEFORE JUNE 13.  1972?         Q TES           Q  "°

      IF 'YES/ CITE PCB NUMBER(S): 	 DATE OF BOARD ORDER: 	_j	

      MAD THE APPLICANT ON OR BEFORE APRIL 14. 1972. COMMENCED CONSTRUCTION OF EQUIPMENT OR MODIFICATIONS SUFFICIENT TO ACHIEVE COMPLIANC
      WITH THE APPLICABLE LIMITATIONS OF THE tULES  AND REGULATIONS GOVERNING THE CONTROL OF AIR POLLUTION.* ADOPTED 1LTHE FORMER  AIR
      POLLUTION CONTROL BOARD AND CONTINUED EFFECTIVE  PURSUANT TO SECTION 49(e) OF THE ENVIRONMENTAL PROTECTION ACT? QYES    Q NO

      IF IB.* EXPLAIN IN DETAIL AND NARK TOUR EXPLANATION AS EXHIBIT 0.

      TOTAL NUMBER OF PACES IN EXHIBIT 0: 	
 20.    IF THIS  IS AN APPLICATION FOR AN OPERATING PERHIT, THE APPLICANT SHALL SUBMIT AN ESTIMATE OF THE MAXIMUM ONE-HOUR AMOUNTS OF
       PARTICU.ATE MATTER. SULFUR DIOXIDE. CARBON MONOXIDE. OXIDES OF NITROGEN. AND ORGANIC MATERIAL EMITTED FROM ALL SOURCES LOCATED
       ON THE PLANT OR PREMISES.  THIS ESTIMATE SHALL INCLUDE ALL EMISSION SOURCES LOCATED ON TM6 APPLICANT'S PREMISES ANO NOT JUST
       THE  EMISSION SOURCES DESCRIBED IN THIS APPLICATION.
       MATERIAL
                     MAXIMUM ONE-HOUR
                          AMOUNTS
MATERIAL
                                                                           MAXIMUM ONE-HOUR
                                                                              AMOUNTS
HATER. ML
                                                                                                                         MAXIMUM ONE-HO
 MRTICULATE
 HATTER
                                           SULFUR
                                           DIOXIDE
                                           NITROGEN
                                           OXIDES
                                      30    IB
                                                                               450
                                                                                                                                 270
  OftUNIC
  MTER1AL- .
                                           CARBON
                                           VMOXIDE
                                    4.6
                                             IB
                                                                                 15
                                                                                              LB
       MAT IS THE SIZE (IN ACRES) OF APPLICANT'S PRBUSES?
                                                                 500
       LIST AND .IDENTIFY ALL  FORKS. EXHIBITS. AND OTHER INFORMATION SUMITTD AS PART OF THIS APPLICATION.   PLEASE NUMBER EVERY PAGE
       AND STATE  THE TOTAL NUMBER OF PAGES IR THIS APPLICATION.                                                              	
                                                                 2-13 .11

-------
                                                           STATE OF  ILLINOIS
                                                     ENVIRONMENTAL PROTECTION ACINCY
                                                    DIVISION OF AIR  POLLUTION CONTROL
                                                          *ZOO CHURCHILL ROAD
                                                      SPRINGFIELD. ILLINOIS   CZ706
FOR AGENCY USE ONLY
DATA AND INFORMATION
PROCESS EMISSION SOURCE/*)
Cement Kiln



Ajax Cement Corporation
123 River Street
2. NAME OF CORPORATE DIVISION OR PLANT (IF DIFFERENT FROM Ok
4. CITY OF EMISSION SOURCE:
Clearview

GENERAL INFORMATION

1



Portland Cement Mfg.
Fuller/Gatx
6. NAME OF EMISSION SOURCE EQUIPMENT:
Rotary Kiln
8. WKL kUMMR: 	 	 8. SEMAi kUMtEfc: 	
PT-50 • F.G.1329
101 IfwlSftKPIo}):1*1™0" S°URCES KSCR18EO °" THIS '«*<««« TO -KNERAL- INSTRUCTIONS FOR OOPPUTIONOF rcmT
"• ^^^W&^fJSSS SJfiK&S^^ WJI l6™ |Y 'Hls m (1F UCH "^ m cwmb |Y «".**
2. AVERAGE OPERATION TIME OF EMISSION SOURCE: 	
24 HRS/OAY 7 DAYS/HK 52 IKS/YR
13. KWENTW^dATTHiroTPDT! 	
DEC/FEB 25 1 MAR/MAY 2 5 J JUN/AUG 25 j SEP/NOV 2!
                                                           RAW MATERIAL INFORMATION
1 '4*
NAMES OF RAH NATERIALS(B)
l.
Limestone
t.
Cement Rock
c.
Clay
t.
Iron Ore
t.
f.
C0?^
•
MAXIMUM RATE PCR
IDENTICAL Snu»CE
66,300 a/HR
20,000 u/HR
3'000 L./HR
. « r 000 IB/HR
Lt/HR
15,000 LB/HR
. AVERAGE RATE PER
IDENTICAL SOURCE
66,300
20,000
3,000
10,000 .

15,000
•
   (A)  THIS DATA AND INFORMATION  FORM  IS TO IE COMPLETED FOR MY STATIONARY EMISSION SOURCE CITHER THAN A FUEL COMBUSTION EMISSION SOU&C
       AN INCINERATOR.   A FUEL  COMBUSTION EMISSION SOURCE IS MY FURNACE. IOILER, OR SIMILAR EOUIPMENT USED FOR THE PRIMARY PURPOSE OF I
       OUCINC HEAT  OR POWER BY  INDIRECT HEAT TRANSFER.  FOR SUCH AN EMISSION SOURCE. COMPLETE 'DATA MO INFORMATION ..FUEL COMBUSTION El
       SOURCE.' FORM APC-?40.   M INCINERATOR IS A COMBUSTION APPARATUS IN WHICH REFUSE IS BURNED.  FOR SUCH M EMISSION SOURCE. COMPLC
       •DATA MD INFORMATION - INCINERATOR.* FORM APC-2SO.

   U)  COMPOSITIONS OF RAH MATERIALS HJST BE DETAILED 70 THE CXTENT NECESSARY TO DETERMINE T»E NATURE MD 0UANTITV OF POTENTIAL EMISS10
I
                                                                    2-14

-------
 FOR AGENCY USE ONLY
 IS.
                     MANES OF PRODUCTS
                                                     'PRODUCT INFORMATION
                                          MAXIMUM RATE UK
                                          IDENTICAL SflURCE
                                                            AVERAGE RATE P[R
                                                            IDENTICAL SOURCE
   Portland  Cement  Clinker
                                        106,000
                                                                                       LI/HR
                                                             91,250
                                                                                       "/HR
                                                                                       LB/HR
                                                                                       LB/HR
16.
                  HAKES OF WASTE MATERIALS
                                                  HASTE MATERIAL INFORMATION
                                          MAXIMUM RATE PER
                                          IDENTICAL SOURCE
                                                            AVERAGE RATE PER
                                                            IDENTICAL SOURCE
   None  -  All  returned to system
                                                                                      LB/HR
                                                                                      LB/HR
                                                                                      LB/HR
                                                                                      LB/HR
   CONTAMINANT

W.  ^ARTICULATE
    MATTER

IB.  CARBON
    MONOXIDE
19.  NITROGEN
    OXIDES
                                          MAXIMUM EMISSIONS FROM EACH IDENTICAL SOURCE*
CONCENTRATION OR EMISSION RATE
      GR/SCF
        i^BBMBI

         PPM
        (VOL)
                                   (VOL)
              D.
D.
 LB/HR
••••MM^HB


 LB/HR
              b.
                                                        LB/HR
                                          METHOD USED TO DETERMINE CONCENTRATION OR EMISSION RATE
                                    c.
                     c.
                                    c.
    ORGANIC
    MATERIAL
         Pf«
        (VOL)
                                   C.
                                                        LB/HR
    DIOXIDE
                                                              C.
                                   (VOL)
                             LB/HR
               5HWU9K-8?J«IL ASCRIBED IN THIS SECTION
                               27.  EIIT MEI6HT WOVE GRADE:
mow
r AfPLi-
IADE:
FT
24. 6AS FLOW RATE THROUGH EACH
ttIT: M
28. MAXIMUM HEIGHT OF NEARBY
WILDINGS: „
25. EXIT GAS TENPERATU
29. EXIT DISTANCE FROK
FtANT BOUNDARY:
  E=  OmnE THESE SECTIONS ONLY IF EMISSIONS ARE EXHAUSTED WtNOUJ CflNTROL EQUIPMENT.

                                                          2-15  •

-------
                                                      STATE OF  ILLINOIS
                                                ENVIRONMENTAL PROTECTION AGENCY
                                               DIVISION OF AIR POLLUTION CONTROL
                                                      2200 CHURCHILL ROAD
                                                 SPRINGFIELD. ILLINOIS   (2706
                           DATA AND INFORMATION
                                             *


                      AIR POLLUTION CONTROL EQUIPMENT

                        Kiln Baghouse
                                                                                              AGENCY USE ONLY
1.  NAHC OF OWNER:
   Ajax  Cement  Corporation
3.  STREET ADl)R£SS OF EMISSION SOURCE:
                                                               2.  NAME OF CORPORATE DIVISION OR PLANT (IF OIFFERENT FROM
    123  River  Street
                                                               4.  CITY OF EMISSION SOUItCE:
                                                                  Clearview
                                                     ADSORPTION STSTEM
''  AP*IM?10NS.^roK"lo?):ADSORI>TIWl
                                             ««R1BED '" THIS SECTION  (REFER TO 'GENERAL  INSTRUCTIONS FOR COMPLETION OF PERMIT
                                                               3.  MODEL NAME AND NUMBEIt:
?.  METHOD OF REGENERATION:

      D REPLACEMENT
                                          5.  NUMBER OF BEDS PER SYSTEM
                                                                                   6.  ADSORBANT HEIGHT  Kft KB:
                                                                                                                     L6
                                   STEAM
                                                   D OTHER (SPECIFY
   TIME ON LINE BEFORE  REGENERATION:
                                                      HIN/BED
                                                               9.  EFFICIENCY OF CONTROL (ATTACH TEST REPORT OR tlPLAIN ESTIMATE)
                                                         AFTERBURNER


"«• «i: z: jz
LJ GAS LJ OIL ( I SULFUR!
i. INLET CAS TEMPERATURE:
•F

3. MODEL NAME AND NUHBEK:
5.
BURNERS PER AFTEBURHER •
7. OPERATING TEMPERATURE OF COMBUSTION CHAMBER:
LENGTH IN; CROSS SECTION IN x IN; OR
U YES LJ NO
10. EFFICIENCY OF CONTROL (ATTACH TEST REPORT OR EIPLAIN
PART I CU. ATE I CASEOUS
BTU/H
EACH
•F
I** OIA
ESTIMATE)
1
                                                          2-16

-------
m IGWY CSE WILT (

. . coNOENsm . • .
, ftOW DIAGRAM DESIGNATIONS OF CONDENSERS DESCRIBED IN IMIS SECTION (REFER TO 'CENERAL INSTRUCTIONS FOR COMPLETION Of PEWIT
tWLlCATlOHS.* F0«* APC-W1):
; NMUFACTURER:
3. MODEL NAME AND NUMBER:
D HATER (_ CPM) D'»I« ( SCFM)D OTHER (TYPE now HATE 1
INLET «F OUTLET »F
"MEAT EXCHANGE AREA PER CONDENSER:
FT*
6. CAS TEMPERATURES:
INLET »F OUTLET T
S. EFFICIENCY OF CONTROL (ATTACH TEST REPORT OR EXPLAIN ESTIMATE):

CYCLONE
Of rtWtlT APPLICATIONS t FDRn ArC'ZOl / • •
. MHUFACTURER:
Fuller
. MWER OF CYCLONES IN EACH MULTIPLE CYCLONE:
One unit of 3 cyclones
3. MODEL NAME AND NUMBER:
Z5600
S. EFFICIENCY OF CONTROL (ATTACH TEST REPORT OR EXPLAIN ESTIMATE):
. 95% bv wt. i
. BUCKS ION THE APPROPRIATE SKETCH (IN INCHES) OR PROVIDE A DRAWING WTH EQUIVALENT INFORMATION:
•nC£bnT
l\ 	 , At
:" L\7^
r— — • I
— «
* ••
n-r
:
*• «j
•
ELECTRICAL PRECIPITATOf)
or%wa^wnSJs/SFORME»"5oih '"tclPIUTO(ts K5C"IBEC » THIS """* «KFEI1 TO '««RAL iioTRuaiONs FOR COMPLHIOK

COLLECTING ELECTRODE AKA PER CONTROL DEVICE:
FT*
3. MODEL NAME AKD NUMBER:
5. EFFICIENCY OF%CONTROL (ATTACH TEST REPORT OR EXPLAIN RESULTS):
^

• FILTER
«* APC^O?)*4'6"*710"4 °f niHK aSWI»t0 '" THIS ««•«" «K«R TO -SENERAL INSTRUCTIONS T0« COWLETION Of PERMIT APPLICATIONS.'
NANUfACTURER: " 	 """ 	 " 	
Fuller/Gatx
FIIHRINS AREA PER CONTROL DEVICE:
8.500 n?
3. PnOEL NAME AND NUMBER:
PP50
S. FILTERING MATERIAL:
Glass Fiber
&ISSING: ,-, __ __ ' ' 	 II 	
U»AttR Q REVERSE AIR D PULSE AIR U PULSE JET UOTHEWSPrcirv . >
DKCEO-WMK SCFP>) DWTER SPRAY ( . .en
IRLET CAS: 	 '
n»nRATuR£ 325 T; Kurcm 3.30 -r
B oua(LENCTH_20 rr: D,,72x4e];.) DoTnrt|Wr,r,j
*• trr'&'|"CQ2! cwr'ot 'm*w TK* *f"*: «* EFPLAIM ESTi»-t:c):
'•» " • • • - 2-17 - :tv j v ,

-------
 ro* AGEMCY use ONLY
                                                                SCRUBBER
1.   FLOW  DIAGRAM OESISMAJ10NS OF SCRUBBERS DESCRIBED IN THIS  SECTION  (REFER TO -CENERAL INSTRUCTIONS FOR COMPLETION OF PERMIT  APR
    FORM  APC-201):
2.  MANUFACTURES:
4.   SCRUBBER TYPE":


   D HIW ENERGY (6AS STREAM PRESSURE DROP	


   O PACKED (PACKING TYPE               ;   MCKINC .SIZE


   D SPRAY (NUCER OF ROZ2LES	


   O .OTHER (SPECIFY 	
                         J.  MODEL NAME AM NUMBER:
                 	 IN HjO)
; NOZZLE PRESSURE
. IN;    PACKED HE1SHT  __


         PS161
                                                                 IN)
  ATTACH KSCtlPTION AMD SKETCH KITH OIMENSIONEO DETAILS)
5.  SCRUBBER 6EOMETRY:
      .LENGTH  IN DIRECTION OF CAS
 IN;   CROSS-SECTION
                                                                      IN X
                                      IN  OR
                         IN 01A i
O CROSS
                                                                                                                  FLOW
                                                                                                                            COUNTER F:
i.  LIQUID FLOU RATE INTO SCRUBBER:
                                                           CPU!
                                                                     7.  CHEMICAL COMPOSITION OF SCRUBBANT:
8.   INLET GAS TEHPERATUKi:
                                                                     J.  EFFICIENCY OF CONTROL (ATTACH TEST REPORT OR EXPLAIN ESTIMT.
                                                                         PARTI CULATE	I  CASEOUS 2	
                                                    OTHER TYPES OF CONTROL EQUIPMENT
    APPLICATIONS
                                       EQUIPHMT ««"•« >" TH« SECTION (REFER TO "SWERAL HBTRUCTIOHS. FOR COMPLETION OF PEWIT
2.  GENERIC
                OF CONTROL EQUIPMENT:
   3.   MANUFACTURER:
                                                                                            4.  MODEL B«ME AND NUMBER:
S.  ATTACH  DESCRIPTION AND SKETCH OF CONTROL EQUIPMENT KITH
    DIMENSIONED DETAILS AND FLOW RATES.
                         6.  EFFICIENCY OF. CONTROL (ATTACH TEST  REPORT OR EXPLAIN ESTIMAT
                             PARTICULATE	   *	S  CASEOUS	
MAXIMUM EMISSIONS FROM EACH IDENTICAL EXIT
CONTAMINANT
1. PARTICULATE
MATTER
12. CARBON
MONOXIDE
1. NITROGEN
OXIDES
<• ORGANIC
MATERIAL
i. SULFUR
DIOXIDE
i. OTHER
(SPECIFt)
CONCENTRATION JB EMISSION RATE
• .
6R/SCF
•• PPM
(VOL)
•• PPM
(VOL)
*. PPM
(VOL)
*• PPM
(VOL)
•• PPM
(VOL)
14.8
6.
7.5
b.
1351
b. 1
2.3
b.
225
t>.
3 LB/10HTU
S . "/HR
3 LB/10*8TU
2 U/HR
D
B
d
0
•
^
•
LB/10*BTU
IB/MR
LB/10*BTU
U/HR
LB/IO&BTU
LB/HR
LB/)0«BTU
U/HR
METHOD USED TO DnEIMINE CONCENTRATION OR EMISSION RATE
C' EPA - Method. - 5 .
c.
Coal Combustion Emission Factors A<
e.
Coal Combustion Emission Factors A<
Coal Combustion Emission Factors A'
c.
Coal Combustion Emission Factors A<
c.

EWAUST DATA
1. FLOW wIAGMPI KSIGISTum OF EXITS KSCMBlb l» THIS SECTION(REFCR
jo •a:;™*. iaTtacTio-5 n» CO^LETIT; v PEPMM APPL i CAT ions;"
FO»M APC-701):
«. EXIT oiAnu»: $. nn MEierr ABOVE CAAOC:
— 5 « » -1B "
2. CAS FLOW RATE THROUGH (EACH
|I1T: 63,000 *»"
1. MAXIIMi HEICHT OF NEAHY
fUILOINCJ: 5Q „

3.' CUT CAS TEMPERATURU
285
7. CUT DISTANCE FRO? NtAR
PUWTMUNOARY: 700

-------
                                                          STATE OF ILLINOIS
                                                    ENVIRONMENTAL PROTECTION AGENCY
                                                   DIVISION OF AIR POLLUTION CONTROL
                                                         2200 CHURCHILL ROAD
>i!gg2£3»< ' SWINSFULD, ILLINOIS K706
DATA MO MFOWAnON
PROCESS EMISSION SOURCE(A)
Cement Clinker Cooler

Ajax Cement Corporation
). STREET ADDRESS Of EMISSION SOURCE:
123 River Street
FOR AGENCY USE ONLY

2. NAME OF CORPORATE DIVISION OR PLANT (IF DIFFERENT FROM Orf.r»
«. CITY OF EMLSSION SOURCE:
Clearview
GENERAL INFORMATION
Clinker Cooling
7. EMISSION SOURCE EQUIPMENT MANUFACTURE: " ' ~
Fuller/Gatx
1C- IftlSffi.^^fr WSSI°" S°UR"S """"" W TH* F<
6. NAME OF, EMISSION SOURCE EQUIPMENT:
Clinker Cooler
~b. MODEL NUMBER: '"J. JEfelAL NUMBER:
770S/925H N/A
»« (REFER TO -6ENERAI' INSTRUCTIONS FOR COMPLETION OF PERMIT
1 ' IN WH«lgRiaTio«:iSSoli5SI?SK ^T^ScS!?*5 NOT CuvtRtu 8T 1H1! ™" "F **" WUKL" wt OWBI" BT FOW*™1A
U. AVERAGE OPERATION TIME OF EMISSION SOURtE: 	 -•••.- 	
*4 MRS/DAY 7 OAYS/WK ^^ MICS/YR
-
13. PERCENT OP ANNUAL iHRduWuT: 	 ~
DEC/FEE- 2 5 J MAR/MAY 2 5 JJUN/nuc25 j SEP/NOV
••
RAW MATERIAL INFORMATION

NAMES OF RAW MATERIALS(B)
Portland Cement Clinker
b. 	





MAXIMUM RATE PER
IDENTICAL SOU»CF
100,000 J/WR
LB/HR
J
LB/HR
LB/HR
LB/HR


AVERAGE RATE PER
IDENTICAL SOURCE
90,000 L


i
L


     AM  INCINERATOR
                  '
FOR ANY STATIONARY EMISSION  SOURCE OTHER THAN A FUEL COMBUSTION EMISSION SOURCC
 " ANY FURNACE.  BOILER.  OR  SIMILAR EQUIPMENT USED FOR THE PRIMARY PURPOSE OF  Pf
   SUCH AN EMISSION SOURCE.  COMPLETE  "DATA AND INFORMATION —FUEL COMBUSTION f
     APPARATUS IN WHCH REFUSE  IS IURNED.  FOR SUCH AN	  	
          «0 INFORMATION - INCINERATOR/ FORM

U)  MFOSmONSOF MX MATERIALS.MUST IE DETAILED TO THE EXTENT KCQSARY TO DETERMINE THE NATURE MO OU4KTITT Of WTENTHL  EMI.   .,

""                                                             2-19     ———————^————

-------
C

FDR AGENCY USE ONLY

PRODUCT INFORMATION
DAMES OF PRODUCTS
«.
Cooled Cement Clinkers
6.
c. •

MAXIMUM RATE PER
IDENTICAL SOURCE
100,000 LB/HR
LB/HR
LB/HR
LB/HR
AVERAGE DATE PER
IDENTICAL SOURCE
90,000 L

L
I
fe
HASTE MATERIAL INFORMATION
16.
NAMES OF HASTE MATERIALS
None - Returned to System
b.
c.
0.
— — ^— _____ 	 _ 	
MAXIMUM RATE PER
IDENTICAL SOURCE
LB/HR
LB/HR
LB/HR
LB/HR
AVERAGE RATE PER
IDENTICAL SOURCE
L
•S
I
I
'•'. I
MAXIMUM EMISSIONS FROM EACH IDENTICAL SOURCE*
CONTAMINANT
1). PARTICULATE
MATTER
1 18. CARBON
I MONOXIDE
19. NITROGEN
OXIDES
20. ORGANIC
MATERIAL
21. SULFUR
DIOXIDE
22. OTHER
(SPICIFY)
CONCENTRATION OR EMISSION RATE
*.
6R/SCF
PPM
(VOL)
•' PPM
(VOL)
PPM
(VOL)
•' PPM
(VOL)
PPM
(VOL)
6. .
LB/HR
b.
LB/HR
b.
LB/HR
b.
LB/HR
b.
LB/HR
b.
LB/HR
METHOD USED TO DETERMINE CONCENTRATION OR EMISSION RATE
C.
C.
C.
e.
c.
c.

EXHAUST DATA*
23.
FLOW DIAGRAM DESIGNATIONS OF EXITS DESCRIBED IN THIS SECTION
REFER TO -GENERAL INSTRUCTIONS FOR COMPLETION OF PERMIT APPLl-
AT10HS, roW1 APC-ZOu:
16. EXIT DIAMETER: 27. EXIT HEIGHT ABOVE GRADE:
n FT
24. SAS FLOW BATE THROUGH EACH 25. EXIT CAS TEMPERATURE:
EX": ACFH
28. MAXIMUM HEIGHT OF NEARBY ' 29. EXIT DISTANCE FKH f
BUILDINGS: FT "•*"* BOUNDARY:

1IOTE

COMPLETE THESE SECTIONS ONLY IF EHISSIOKS AK EXHAUSTED WITHOUT CONTROL EQUIPMENT.


-------
                                                        STATE Of ILLINOIS
                                                 ENVIRONMENTAL PROTECTION AGCNCT
                                                DIVISION Or AIR POLLUTION CONTROL
                                                       MOO CHURCHILL ROAD
                                                  JPRINGMEIO. ILLINOIS   K706
                           DATA MO INFORMATION


                       AIR POLLUTION CONTROL EQUIPMENT

                  Clinker  Cooler  Baghouse
                                                                                             FDR «6£NCr USE ONLr
1.  NAME OF OWNER:
   Ajax Cement  Corp.
                                                    2.  NAHE Or CORPORATE OIVISION OR PLANT (IF 01FFERCHT FROM
3.  STREET ADDRESS OF EMISSION SOURCE:
   123  River  Street
                                                    4.  CITT or EMISSION SOURCE:
                                                       Clearview
                                                       MBORPTION STSTEM
               "ri£!*T.l?1,^ WSORPTION SYSTEMS DESCRIBED IN THIS SECTION (REFER TO 'SENERAL INSTRUCTIONS FOR COMPLETION OF
                rUKW APC*ZU1 :
2.  MANUFACTURER:
                                                                3.  MODEL NAME AND NUMBER:
1.  METHOD OF REGENERATION:

         REPLACEMENT            Q
                                           S.  NUMBER OF IEDS PER STSTEM
                                                                        6.  WSORBANT HEIGHT P» IED:
                                                                                                                       LI
                       STEAM
                 D
                                                       OTHER
   TIME ON LINE BEFORE RtGENERATItiN:
                                                       MIN/BED
                                                                ».  EFFICIENCY Or CONTROL (ATTACH TEST REPORT OR EXPLAIN ESTIKAU, .
                                         °"ClllBtD '" TH»S ACTION (REKR TO 'CtNERAi  INSTRUCTIONS FOR COMPLETION OF  PERMIT
                                                                I.  MODEL MME AND MMBER:
   FUEL:
DGAS      D
                            OIL
                                                    t SULFUR)
                                                                S.
                                                       •MNERS PER AFTERBURNER
                                                                                    BTU/HF
                                                                                    EACH
              PERATURE:
                                                                7.  OPERATING TEMPERATURE  OF COMBUSTION CHAMBER:
   COMBUSTION CHAMBER DIMENSIONS
                      LENGTH ,
   CAum:  USED?
                                   IN;   CROSS SECTION
                                         IN X
                                                                                                         11  DIA
                   D
           TES
DNO
10.  EFTICIENCT Of CONTROL (ATTACH TEST REPORT OR EXPLAIN ESTIMATE).
    MRTICULATE 	I   CASEOUS	    z
                                                              2-21
                                                                                                                     MCE  1 01

-------
.  MEAT EXCHANGE AREA PER CONDENSER:
                                                               8.   EFFICIENCY OF CONTROL  (ATTACK TEST REPORT OR EXPLAIN ESTIMATE}"
                                                                                    TO -«««* INS.RUCTIONS FOR COMPLETION
  me or COOLANT AND COOLANT FLOW  PER CONDENSER:
 D WATER (	CPU)   DAIR {
                                                          3.  MODEL NAME AND NUMBER:

                                                         1 "    »—•••••••.


                                                  .SCFM)  D OTHER (TYPE
 MANUFACTURER:
 »f«ER OF CTCLONES IN EACH MULTIPLE CYCLONE:
                                                              3.  MODEL NAME AND NUMBER:
                                                              5.  EFFICIENCY OF CONTROL (ATTACH TEST REPORT OR EXPLAIN ESTIMATE):
 DIMENSION THE APPROPRIATE SKETCH (IN  INCHES) OR PROVIDE A DRAWING KITH EQUIVALENT INFORMATION'
                 r
 MANUFACTURER:
 COLLECTING ELECTRODE AREA PER CONTROL  DEVICE:
                                                         FT?
                                                              3.  MODEL MMf AND NUMBER:
                                                              S.  EFFICIENCY OF CONTROL (ATTACH TEST REPORT OR EXPLAIN RESULTS):
                                                          FILTER
                          'UIHS KS"'Bl°  '" THIS «««»" ««•
                                                                          INSTRUCTIONS FOR COMPLETION OF KRMIT AW.ICATIOMS.
MNUTACTURI
Fuller/GATX
FILTERING AREA n» OWTROL DEVICE:

"&
                                                        3.  MODEL NAME AND NUMBER:

                                                           Plenum Pulse -  156-10-1625
                                                                      ITERIAL:
             U«EVERSEAIR
                                        PULSE JIT       LJoTHE«( SPECIFY
    COOLING:
     BLEED-IN A1R(_
INLET MS:
                                    STRAY (
                                                              BDUO(LtNCTH_25r;  0>t  24   ,..,
TEH-ERATURE   35Q    >f;  2-22  HEW
                                                  120
                                                             I. CFFICIENCY OF
                                                             	99.9%  -f
                                                                                     («H«CH TEST

-------
 FOR AGENCY USE DM'
                                                              SCRUBBER
I.  FLOW DIAGRAM DESIGNATIONS Of SCRUBBERS DESCRIBED  IK THIS SECTION (REFER TO 'GENERAL IHSTRUCTIONS FOR COMPLETION OF PERMIT APPUUm
   FORM APC-Z01):                                                                                                                '
2.  MANUFACTURER:
                             1.  MODEL MK  AND NUMBER:
«.  SCRUBBER TYPE:


   D HIGH ENERGY  (CAS STREAM PRESSURE  DROP 	


   D PAOCED (PACKING TYPE	;   PACKING SIZE	


   LJ SPRAY (NUMBER OF NOZZLES	  ; IIOZZLE PRESSURE"


   D OTHER (SPECIFY 	
                          IN HjO)
                               . IN;    PACKED HEIGHT


                               	WIG)
                                                             IN)
      ATTACH DESCRIPTION AND SKETCH UITH DIMENSIONED DETAILS)
5.  SCRUBBER GEOMETRY:
      LENGTH IN DIRECTION OF GAS FLOW
    .IN;  CROSS-SECTION	IN X	IN  OR	IH DIA;  D CROSS FLOW  D COUNTER FLOW
6  LIQUID FLOW RATE  INTO SCRUBBER;
                                                          6PM
                                                                    7.  CHEMICAL COMPOSITION OF SCRUBBAM:
B.  INLET GAS TEMPERATURE:
                                                                   9.  miCIENCY OF CONTROL (ATTACH TEST REPORT OR EXPLAIN ESTIMATE):
                                                                       PART I Cut ATE 	I   CASEOUS	    I
                                                   OTHER TYPES  OF  CONTROL EQUIPMENT
                        C'Zwl ) I
                                               ASCRIBED IN THIS SECTION (REFER TO 'GENERAL INSTRUCTIONS TOR COMPLETION OF PEWIT
2.  GENERIC NAME  OF CONTROL EQUIPMENT:
                                             3.  MANUFACTURER:
                                                                                         4.  MORI NAME  AND NUMBER:
5.  ATTACH DESCRIPTION AND SKETCH OF CONTROL EQUIPMENT KITH
   DIMENSIONED DETAILS AND FLOW RATES.
                             6.   EFFICIENCY OF CONTROL (ATTACH TEST REPORT OR EXPLAIN  ESTIMATE):
                                 PART ICUL ATE 	I   SASEOUS 	t
                                              MAXIMUM EMISSIONS FROM EACH IDENTICAL EXIT
    CONTAMINANT
                              CONCENTRATION £R EMISSION KATE
                                   METHOD USCO TO DETERMINE CONCENTRATION OR EMISSION RATE
1.  PART ICULATE
   MATTER
                                     SR/SCF
        >•        D LI/10&BTU
        .30    g)     LI/HR
                            Source  Test -  EPA  Method  5
2.  CARBON
   N3NOXIOE
 PW
(»OL)
b.
 7.5
                                                             «-B/HR
3.  NITROGEN
   OXIDES
 PPM
(WL)
         D U/106BTU
 135   Q     "/HR
   MATERIAL
 PPM
(TOL)
b.
 2.3
            U/106BTU

                U/H(1
   SW.FUR
   DIOtlK
                                      (WU
       b.
       225
            1»/>0*BTU
                LI/HR
   OTHER
   (SPECIFY)
                                      (VOL)
       b.
            LI/10*BTU
                LI/HR
                                                            tIMAUST DATA
I   FLOW i,IAGB*'i OtS«C.14TIO-(S OF EXITS DESCRIBED IU THIS  SECTIONlREFrR
   T--             T: OF P£PMIT  APPLICATIONS."
                             Z.  CAS FLOW RATE THROUGH EACH
                                 UIT:  57,200        «ew
                                                         3.   EXIT CAS TEMPERATURE:
                                                               290
   ElIT
                                 s.  EXIT HEIGHT Aeon GRADE:
                                                51
                             i.  MAXIMUM HEIGHT OF MEARBY
                                 WILDINGS:        c
                                                           FT
                                                                2-23
                                                         7.   EXIT  DISTANCE FROM NEAREST
                                                             PUNT MUNDARY:  gQQ    r

-------
                        SUMMARY OF SOURCE OPERATION

PLANT:   Ajax Cement Corporation/ Clearview Plant
LOCATION:   123 River Stree, Clearview, Illinois
DATE OF TEST:  June 6, 1977
TYPE OF PROCESS/EQUIPMENT:    Portland Cement Kiln
Material Processed or Produced:   Portland Cement Clinker
Operating Schedule:     24	Hr./Day       	^£5*	payAear
Maximum Operating Capacity (Include Units):  	53 T/hr	
Normal  Operating Capacity: 	45 T/hr	
Operating  Capacity During Test:  Test 1 SOT;  Test 2 43T;  Test  3  47T
Fuel  Type: Crushed Coal    % Ash:         	 % Sulfur:    1>5
Amount of  Fuel Consumed During Test:    22.5 T	
Pollution  Control  System Description:   Primary multicyclone;
  secondary positive pressure, reverse air cleaned baghouse with
  collected dust returned to system
Pressure Drop Across  Collector:
Additional Information:
       * less normal down-time
                                    2-24

-------
                       SUMMARY OF PITOT TRAVERSE DATA            SHEET 1 o:

         Ajax Cement Corp, Clearview    SOURCE:   Kiln _ _ DATE:/<
 A.  Stack Dimensions
 B.  Area of Stack, Sq.  Pt.                                   19.6 ft.2
 C.  Barometric Pressure,  *Hg                                 29.75
 D.  Gage Static Pressure  in Stack,  "H2O                      0.15
 E.  Stack Gas Temperature, Dry Bulb, °F                      285°
F
 F.  Percent Moisture                                         12%
 G.  Dry Gas Composition:  %02                                8.7%
                          *C02                              i2.6%
                          *CO                               o.2%
                                                            78.5%
                          % other
 H.  Density of Dry Stack Gas, 9 STP, Lbs./Cu. Ft.           0.079
 I.  Density of Moist Stack Gas, 9 STP, Lbs./Cu. Ft.         0.075
J.  Density of Moist Stack Gas, 9 Stack Conditions,
    Lbs./Cu. Ft.                                            0.053
    Total Number of Traverse Points                         12
    Pitot Tube Calibration Factor                           0.82
    Average Square Root Velocity Head of all
    Traverse Points                                         0.80
    Average Gas  Velocity,  Feet/Min.                          3200
0.   Stack Gas  Flow Rate:
    1.  ® Stack Conditions, Wet, ACFM                       63,000
   2.  ® Standard Conditions, Wet, SCFM                     44,750
   3.  9 Standard Conditions, Dry, DSCFM                    39,500
5TP - 70°F, 29.92 "Hg.
"Wet" or "Moist- - Refers to the condition of the gas with actual water
                  content.

                                   2-25

-------
                   SUMMARY OF PARTICULATE SAMPLING DATA        SHEET 1 of 2
 PLANT;   Ajax Cement Corporation   SOURCE:  Kiln           DATE:    6/6/77
A.  Sample Number
B.  Number of Points Sampled                 12      12	12
C.  Total Duration of Sample,  Min.            60      60	60
D.  Nozzle Diameter, In.                    .260    ,,260    .260
E.  Nozzle Area,  Sg.  Ft.                   .000369 .000369 .000369
F.  Calibration Factors
    1.  Probe Pitot Tube                      .82     .82	.82
    2.  Gas Meter                            2.07    2.07    2.07
G.  Barometric Pressure,  "Hg.                 29.75   29.75   29.75
H.  Gage Static Pressure in Stack,  "H20      .16	.15     .14
I.  Stack Gas Temperature,  °F  (Ave)           275     285     295
J.  Average Square Root Velocity Head
    of Points Sampled                     	  	
K.  Average Gas Meter Temperature,  °F        88.2    91.8    89.6
L.  Average Gas Meter Pressure,  "H2O         .716	.743	.785
M.  Gas Meter Volume, Actual,  Cu.  Ft.        63.2    63.9    62.9
JN.  Gas Meter Volume, @> STP,  Cu. Ft.         62.3    62.5    61.9
0.  Liquid Volume of Water Condensed, ML.     171	190	160
P.  Vapor Volume of Water Condensed at
    STP, Cu. Ft.                             8.5     8.9     7.8
Q.  Total Gas Sampled Through Nozzle,
    e STP, Cu. Ft.                           70.8    71.4    69.7
R.  Percent Moisture in Stack
                                    2-26

-------
                   SUMMARY OP PARTICIPATE SAMPLING DATA     SHEET  2  of 2
S.   Particulate  Concentration

    1.   Grains/Dry Standard Cubic Feet       0.04    0.05    0.04

    2.   Lbs./Hr.                             14.0    16.0    15.0

T.   Percent  Isokinetic                       IQI     102      98
STP  «  70°F,  29.92  "Hg.
"Wet"  or  "Moist"  -  Refers  to the  condition of the gas with actual
                   water content.
                                   2-27

-------
I
                         SUMMARY OF SOURCE OPERATION

  PIANT:  Ajax Cement Corporation, Clearview Plant
  LOCATION: 123 River Street/ Clearview,  Illinois
  DATE OF TEST:  June 6, 1977
  TYPE OF PROCESS/EQUIPMENT:  Portland  Cement  Clinker Cooler
 Material Processed or Produced:   Portland  Cement Clinker	
 Operating Schedule:     24	Hi'./Day       	365*	DayAear
 Maximum Operating Capacity  (Include Units) : 	50 T/hr.	
 Normal Operating Capacity:    45 T/hr.	
  Operating Capacity During Test:  Test 1 40T;  Test 2 47T;  Test 3 44T
   el Type:    Coal	% Ash:     8.0%	 % Sulfur:  1.5%
  Amount of Fuel Consumed During Test;   15,000 Ib/hr.	
  'Dilution Control System Description:   Negative pressure, pulse cleaned
    baghouse with collected dust returned to system
  »ressure Drop Across Collector:     B"
 Additional Information:
    * less normal down-time
                                     2-28

-------
                     SUMMARY OF PITOP TRAVERSE DATA
                                                                SHEET 1 Of
PLANT:
        Ajax Cement Corp.,  Clearview  SOURCE:  Clinker Cooler  pAT£: 6/6/7'>
A.  Stack Dimensions
B.  Area of Stack, Sq. Ft.
C.  Barometric  Pressure,  "Hg
D.  Cage Static Pressure  in Stack,  MH20
E.  Stack Gas Temperature, Dry Bulb,  °F
F.  Percent Moisture
G.  Dry Gas Composition:  %02
                         *C02
                         %CO
                            other
                                                              diameter
                                                          15.9  ft.
                                                          29.80
                                                          0.22"  W.C.
                                                          290
                                                          11%
                                                          9.2%
                                                          12.1%
                                                          0.2%
                                                          78.5%
                                                          0.079
                                                          0.075
                                                          0.053
                                                          12
                                                          0.82
                                                          0.81
    Density of Dry Stack Gas,  ® STP*  Lbs./Cu.  Ft.
|l.  Density of Moist Stack Gas, €> STP,  Lbs./Cu.  Ft.
    Density of Moist Stack Gas, 9 Stack Conditions,
    Lbs./Cu. Ft.
 K.  Total Number of Traverse. Points
    Pitot Tube Calibration Factor
    Average Square Root Velocity Bead of all
    Traverse Points
    Average Gas Velocity, Feet/Min.
    Stack Gas Flow Rate:
    1.  9 Stack Conditions, Wet, ACFM
    2.  e Standard Conditions, Wet, SCFM
    3.  9 Standard Conditions, Dry, DSCFM
  TP « 70°F, 29.92 "Hg.
  Wet" or "Moist" - Refers to the condition of the gas with actual water
                   content.
                                                          3600
                                                           57,200
                                                           40,100
                                                           35,700
                                    2-29

-------
      SUMMARY OF  PARTICULATE SAMPLING DATA
                            SHEET 1 of
Cement
SOURCE;   Clinker Cooler
                                               DATE:
f r
r
 D.
 E.
 F.
Sample Number
Number of Points Sampled
Total Duration of Sample, Min.
Nozzle Diameter, In.
Nozzle Area, Sq. Ft.
Calibration Factors
1.  Probe Pitot Tube
2.  Gas Meter
Barometric .Pressure,  "Hg.
Gage Static Pressure  in Stack,
Stack Gas Temperature, °F  (Ave)
Average Square  Root Velocity Head
of  Points Sampled
Average Gas Meter  Temperature, °F
Average Gas Meter  Pressure,  "H2O
Gas Meter Volume,  Actual,  Cu. Ft.
Gas Meter Volume,  @ STP, Cu. Ft.
Liquid Volume of Water Condensed,  ML.
Vapor  Volume  of Water Condensed at
.STP, Cu. Ft.
Total  Gas  Sampled  Through  Nozzle,
@ STP, Cu.  Ft.
 Percent  Moisture in Stack
                                12
                                60
                                .260
                                .82
                  12
12
                   60
60
                   .260
.260
                               ,000369  .000369 .000369
                   .82
.82
2.07
29.80
.11
280
.80
88.2
.716
51.6
49.7
130
6.1
55.8
2.07
29.80
.12
290
.81
91.8
.743
51.9
50.0
138
6.2
56.2
2,07
29,80
.12
300
.82
89.6
.785
53,3
51.4
141
6.4
57.8

                         2-30

-------
j
SUMMARY OF PARTICULATE SAMPLING DATA
SHEET 2 Of 2
                                              .09
                                   .08
 .09
                                              30
                                   25
 32
                                              105.6    102.6   105.9
S.  Particulate Concentration
   1.  Grains/Dry Standard Cubic Feet
   2.  Lbs./Hr.
T.  Percent Isokinetic

STP « 70°F, 29.92 MHg.
  "Wet"  or  "Moist"  - Refers  to the  condition  of the gas with actual
                     water content.
                                      2-31

-------
      STUDENT EXERCISE NO. 3





        CASE STUDY EXERCISE





TRIAL OF OPACITY AND TSP VIOLATIONS

-------
                             LESSON 11

                            CASE STUDY

                 TRIAL OF OPACITY MI) TSP VIOLATIONS
GOAL.            This lesson (exercise) is intended to provide  a
                 "background against which the students may tesl
                 their own ability to develop a trial strategy,
                 "both for prosecution and defense, and to provide-
                 court room testimony.

OBJECTIVES,      At the end of this lesson, the student  should  "be
                 able toj
                 1.  Differentiate between good and poor trial
                     strategy.
                 2.  Differentiate between testimony well given
                     and poorly given.
                                  3-2

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                          CASE STUDY EXERCISE
                  TRIAL OP OPACITY AND TSP VIOLATION

I.   CASE HISTORY

     The Columbia Smelting Company, a large corporation engaged in
     metals refining, smelting, and production has "been sued by
     the State of Columbia for violations of the state's rules
                                      ^                         y \
     and regulations governing opacity and suspended particulate
     matter.  You are a field enforcement officer assisting in
     preparing the case for trial.  The attached investigator's
     report is one of the violations alleged in your plaintiff's
     original petition in State v. Columbia Smelting Company.

     The effective and successful prosecution of this case will
     mostly depend on how thoroughly both the attorney and the
     witnesses prepare the trial.  Thorough preparation requires
     a trial outline containing the following:

         1.  A thorough analysis of your case.
         2.  Your trial strategy plan  detailing the facts and
             points of law you want to establish, the evidence
             and witnesses you want to introduce, and the order
             and manner of introducing them.
         3.  Anticipation of  the defense attorney's possible
             strategies and efforts to undermine your  case and
             deciding how to  block or  neutralize his defense.

    * Rule 103.1   Assume plant built prior to Jan. 31, 1972.
   *» Rule 105.2
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II.   BAGKGBDUND ON STATE VS.  COLUMBIA SMELTING GO.

      Prior to the initiation  of action against Columbia Smelting Co.
      (COSMO), the State Air Centre 1 Board had been  conducting routine
      investigations of the plant suid had reviewed the emissions
      inventory data submitted by the company.  Most of the investiga-
      tions revealed violations of the State's suspended, particulate
      and opacity regulations.  In fact, during the  year immediately
      preceding the filing of  the suit, GOSMD had received five notices
      of violation from the State Air Control Board.

      After the second notice  of violation, COSMD was called in for a
      conference to determine  when compliance could  be achieved.
      COSMD's general manager  insisted that the company was doing
      everything it could and  that the State's tests were probably
      defective.  After the third notice of violation was issued,
      COSMD said it would look into the matter.  When compliance was
      not forthcoming after the fifth violation, the State decided to
      file suit.
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III.   INSTRUCTIONS

       The objective of the exercise is to give each student team
       an opportunity to develop strategy for prosecution and defense
       and then to test the strategy by mock trial method.  Only one
       witness will be heard,  the FED.

       The students will work  in groups of three to  six depending on
       the number of students  in the class.   Each Team will  be assigned,
       by lot,  to prosecute or defend the violation.   A Team will be
       assigned either opacity or TSP.

       After receiving the above assignment,  each Team will  organize
       into roles and select one member for each of  the following:

             Prosecution                        Defense
         1 Chief Prosecutor              1 Defense Attorney
         1 TOD                            I Technical Advisor
         1  Chief of Enforcement         1 Assistant Defense Attorney

       If more  persons are added,  they  are assigned by  the team leader
       to any appropriate  role.

IV   CASE PREPARATION

     Each  team is to  study the  investigator's report, the background
     of  the  case, the history of the violations, and the applicable
     regulations.  Each team will then plan the prosecution or the
     defense strategy for either the opacity or the TSP violation as
     assigned.  Each team will then organize their strategy into a
     series of five questions to be asked on direct examination by
     the prosecution and five questions to be asked by the defense on
     cross-examination.  Extra questions should be prepared in case the
     opposition objects and the objection is sustained.  The FED is to
     be the only witness heard during the demonstration.
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      In  addition  to  the  questions,  the prosecution and defense  should
      each prepare a  one  minute opening statement,

      In  order  to  save  time,  it is  assumed that five questions establish-
      ing the identity  and qualifications of the FED have 'been asked with
      the responses as  shown:
         1.    Q.  Please state your name and address.
               A.  Viy name is George Plohm.  I live at
                   1269  Elm  St., Kingsman, Columbia.
         2.    Q.  What  is your position of employment?
               A.  I am  a field enforcement officer for the
                   Columbia  Air Control Board.
         3-    Q.  How long have you been employed in your present
                   capacity?
               A.  5 years and 6 months.
         4.    Q.  What  are your duties as a field enforcement
                   officer?
               A.  Plohm recites his duties as an FID.)
         5-    Q.  Please describe your educational background,
                   your  training and qualifications as a field
                   enforcement officer.
               A.  Graduation, Columbia Two year Technical College
                   Associate degree in Environmental Studies.
                   Inservice Training Program, Columbia. Air Control
                   Board, three months at beginning of employment.
                   Two years as assistant FED.
                   Three and one-hs.lf years as senior FED.
                   Certified Smoke Reader.   Date of last
                   certification 9/20/78.

V.   DEMONSTRATION

     After sixty  minutes of preparation,  the opacity team, chosen by lot,
     begins with the FED as the prosecuting witness taking the stand.
     It is to be assumed that the FED has been sworn as a  witness.  The
     prosecution begins with an opening statement, no longer than one
     minute duration.
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     After this opening statement, it is assumed that the witness (the FED)
     will have been asked the five stated questions and that he gave the
     indicated answers.
     Now the prosecuting attorney will begin to interrogate his witness
     (the FED) and he will be permitted to ask five questions not counting
     questions objected to and sustained.  Because of time constraints, a
     maximum of eight minutes will be allowed for direct examination.
     At the-end of-the five-prosecution-questions,-^the-defense will begin
     his five questions of cross-examination.  Same rules regarding
     objections and time will apply.
     While objections are allowed, each side is asked to make restrained
     use of this  privilege to conserve  time.
     The judge will be the legal instructor who will rule on the objections.
     At the end of the cross-examination, the following takes place:

         (a)  The prosecutor sums up his  case in two minutes.
         (b)  The defense attorney sums up his case in two minutes.
         (c)  The prosecutor has a rebuttal, if he wishes, for one minute.
     TSP violation.  Repeat  the  procedure for opacity.
     After both  cases are "heard", the  teams who were not put on the  stand
     will have their "chief attorneys"  give their  strategy stressing  where
      it differed from that  taken by  the demonstrating teams.

 V.  DISTRIBUTION OF ACTUAL CASE HISTORY AND INJUNCTION

     After  this  presentation of the  actual  trial questions,  the  instructor
      (judge)  calls for open  student  discussion or  questions.

VI.  DISCUSSION  AND SUMMARY

     When discussion  is  exhausted or time begins to run  out,  the instructor
     "critiques"  the mock testimony  and summarizes the lesson.
                                   3-7

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                                      Case Study   (
         Trial of an Opacity and
Suspended Particulate Matter Violation
          The City of Kingsman
          and State of Columbia

               Plaintiffs
                  v.
 The Columbia Smelting Company (COSMO)

              Defendant
              3-8

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                     SECTION II - INVESTIGATOR'S REPORT
                     STATE OF COLUMBIA AIR CONTROL BOARD

NAME:  COLUMBIA SMELTING COMPANY       DATE OF INVESTIGATION    1/15/79
    (company or person occupying permises)  TIME:  1110  to   1430

ADDRESS: 5300 N. Sylvania	CITY:  Kingsman, Columbia

PREMISES USED FOR:  Iron Casting and Foundry            	
REASON FOR REPORT:  Request to investigate for compliance
TYPE OF POLLUTANT:  Particulate 5 Smoke TYPE OF AIR SAMPLE TAKEN: Hi-Vol.
                                                                (sheltered)
PERSON CONTACTED AT
PREMISES INVESTIGATED:  Mr. Norris Gallo  TITLE:  Chief Engineer  	
STATEMENT OF PERSON CONTACTED:  Mr. Norris Gallo stated that afterburners are
being used to control emissions from the cupola stacks.  Mr. Gallo said that
a wet scrubber for the shake-out system is being installed.  Consideration is
being given to installation of bag-houses on the new shotblast machines and
to elimination of sand blasting.
INVESTIGATOR'S FINDINGS:  At the time of this investigation, the sky was
clear with variable wind bearing 160° to 190° at 4-10 mph.  A grayish white
smoke with an average opacity of 80% was emanating from the cupola stacks.
The primary source of emissions appeared to be coming from the cupola stack;
however, some emission was observed emanating from open doors of buildings
located adjacent to the cupola stacks.
High volume sampling results are as follows:
              1/15/79       Downwind        698 ug/M3
              1/15/79       Upwind           52 ug/M-*
RECOMMENDATIONS:  Recommend that COSM install, operate, and maintain
abatement controls in such a manner so as to comply with the regulations of
the State Air Control Board.
BY:     ^-^^-^   9* .^asScs^c^    TITLE  F.H.S.       DATE   1/16/79
          George P*ohn
                                 3-9

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                           STATE AIR CONTROL BOARD
                        PLUME OBSERVATION RECORD FORM
Date:
1/15/79
Observer:  George Plohn

Start time:     1340
Observation point:  33rd Street

Distance from stack:  900 feet

Wind speed:  8 mph  direction:  190'

Type of background:  Cloudy Sky

Color of Emission:  Grayish White

Type of installation:  Cupola

Observation ended:  1346
 Remarks
                                       Name of s;ource:  Columbia Smelting Co.
                                       Add re s s:  3300 N. Sylvania
                                                 Kingsman, Columbia
                                               Smoke Density Tabulation
                                            No. Units X Equiv. No. 1 Units
                                           24
JLJnits No.   0
JJnits No.   %~
 Units No.   l"
JJnits No.  1%
 Units No.   2
"Units No.  2h
"Units No.   3"
"Units No.  3%~
JJnits No.   4~
"Units No.  4%~
"Units No.   5"
"Total Units "
                                                        96.0
                                             Total Equiv. No. 1 Units
                                              Average Smoke Density
                                             Equiv. No. 1   Units x 20%
                                                    Total Units
                                                    80%
                                       Signed:
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                           STATE AIR CONTROL BOARD


                 SAMPLING DATA AND PLANT OPERATIONAL STATUS


                                                 Date:    1/13/79

Firm name:  Columbia Smelting Company _ _

Location of plant:  3300 N. Sylvania  _ _

Type of operation:  Manufacturing Plant _ _


SAMPLING DATA: *
Type of Sample
                                  Location                Duration
Hi-Vol.  (Sheltered)       '        Upwind                  From:  1130 to 1430
Hi-Vol.  (Sheltered)               Downwind                From:  mp_ to 1410
Special conditions:  Sky clear with variable wind bearing 160° to 190'
at 4  - 10 mph.			
 I  certify  that  the  above  sample(s)  is  (are) representative of conditions at
 the  time of the investigation:

                                Signature:
                                 Title:   Environmental Health  Specialist
 PLANT OPERATIONAL STATUS (During the sampling period)**

 process                       Per Cent Capacity          Abatement  Controls

 Foundry	                   100%	          Afterburners	
 Special Conditions:
 I certify that the above statement is true to the best of my knowledge
 and belief:
                                        Signature:
                                        Title:  Chief Engineer
 *  To be completed and acknowledged by Air Control Program representative.
 ** To be completed and acknowledged by plant representative.  It is
    understood that all the above information will be considered confidential
                                  3-13

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7                               SECTION  III - RULES AND REGULATIONS
                                         STATE OF COLUMBIA
                                       RULES AND REGULATIONS

                                              FOR THE

                                   CONTROL OF AIR POLLUTION FROM
                          SMOKE, VISIBLE EMISSIONS, AND PARTICULATE MATTER
            Rule  103.   Visible  Emissions.

                 103.1  No person may  cause,  suffer, allow, or permit visible emissions
                       from  any stationary flue to exceed an opacity of 30% averaged
                       over  a 5-minute period.  No person may cause, suffer, allow, or
                       permit visible emissions from any stationary flue beginning
                       construction after January 31, 1972, to exceed an opacity of
                       20% averaged over a 5-minute period.  Visible emissions during
                       the cleaning of a firebox or the building of a new fire, soot-
                       blowing, equipment changes, ash removal and rapping of pre-
                       cipitators may exceed the limits set forth in Rule 103.1 for a
                       period aggregating not more than five minutes in any sixty
                       consecutive minutes,  nor more than six hours in any ten-day
                       period.

                 103.2  No person may  cause,  suffer, allow, or permit visible emissions
                       from  a waste gas flare for more than five minutes in any
                       2-hour period  except  as provided in Rule 12.1 of the General
                       Rules.

                 103.3  No person may  cause,  suffer, allow or permit excessive visible
                       emissions from any building or enclosed facility.

                 103.4  No person may  cause,  suffer, allow, or permit excessive visible
                       emissions from motor  vehicles for more than ten consecutive
                       seconds.
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     103.5  No person may cause,  suffer,  allow,  or permit excessive visible
            emissions from any railroad locomotive,  ship, or any  other
            vessel,  except during reasonable periods of engine  start-up.

     103.6  No person may cause,  suffer,  allow,  or permit visible emissions
            from any stationary flue having a total  flow rate of  100,000  acfm
            or more  to exceed an opacity of 15%  averaged over a 5-minute
            period unless an optical instrument  capable of measuring  the
            opacity  of emissions is installed in the flue.  Records of  all
            such measurements shall be retained  as provided for in Rule 9 of
            the General Rules.  The provision shall  not apply to  flues
            having gas streams containing moisture which interferes with
            proper instrument operation,  if so determined by the  Executive
            Secretary.

     103.7  Contributions from uncombined water  shall not be included in
            determining compliance with Rule 103. The burden of  proof
            which establishes the applicability  of Rule 103.7 shall be  upon
            the person seeking to come within its provisions.


Rule 104.   Particulate Matter From Materials Handling, Construction, and
            Roads.

     104.1  Rule 104 shall apply only in Standard Metropolitan  Statistical
            Areas where the Federal air quality standards  for particulate
            matter are exceeded.

     104.2  No person may cause, suffer, allow,  or permit  any fine material
            to be handled, transported, or stored without  taking at least
            the following precautions to prevent particulate matter from
            becoming airborne:

            104.21     Application of water or suitable chemicals or some
                       other  covering on materials stockpiles,  and other
                       surfaces which can create airborne dusts under
                       normal conditions.

            104.22     Installation and use of hoods,  fans and filters to
                       enclose, collect, and clean the emissions of dusty
                       materials.

            104.23     Covering or wetting at all times when in motion,  of
                       open-bodied trucks, trailers, or railroad  cars
                       transporting materials in areas where the  general
                       public has access which can  create airborne parti-
                       culate matter.

     104.3  No person may cause,  suffer, allow or permit a building  struct-
            ure to be used,  constructed, altered, repaired or  demolished
            without  taking at least the  following precautions  to prevent
                                 3-15

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            particulate matter from becoming airborne:

            104.31     Use of water or chemicals where feasible for control
                       of dust in the demolition of buildings or structures,
                       in construction operations, or in the clearing of
                       land.

            104.32     Use of adequate methods to prevent airborne parti-
                       culate matter during sandblasting of buildings or
                       other similar operations.

     104.4  No person may cause, suffer, allow, or permit a road to be used,
            constructed, altered, or repaired without talking at least the
            following precautions to prevent particulate matter from
            becoming airborne:

            104.41     Application of asphalt, oil, water or suitable
                       chemicals on heavily traveled dirt streets as
                       necessary.

            104.42     Paving of public or commercial parking surfaces
                       having more than five parking spaces.

            104.43     Removal as necessary from paved street and parking
                       surfaces of earth or other material which have a
                       tendency to become airborne.

     104.5  Alternate means of control may be approved by the Executive
            Secretary of the State Air Control Board.


Rule 105.   Particulate Matter

     105.1  No person may cause, suffer, allow, or permit emissions of
            particulate matter from any source to exceed  the allowable
            rates specified in Table 1 and/or Figure 1.

            105.11     If a source has an effective stack height less than
                       the standard effective stack height as determined
                       from Table 2 and/or Figure 2, the allowable emission
                       level must be reduced by multiplying it by

                            	    Effective Stack Height
                              Standard Effective Stack Height
            105.12     Effective stack height shall be calculated by the
                       following equation:
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                       h  - h + 0.083vD
1.5 i- 0.82
                        e             «• «•                  i  *•        *  n
                                                                          e
                                              u               ift

                       Where:
                       he * Effective stack height in feet
                       h *  Physical stack height above ground level in feet
                       ve*  Stack exit velocity in feet per second
                       De * Stack exit inside diameter in feet
                       Te • Stack exit temperature in degrees Rankin

     105.2  No person may cause, suffer, allow or permit emissions of
            particulate matter from a source or sources operated on a pro-
            perty or from multiple sources operated on contiguous properties
            to exceed any of the following net ground level concentrations:

            105.21     One hundred (100) micrograms per cubic meter (ug/m3)
                       of air sampled, averaged over any five consecutive
                       hours.

            105.22     Two hundred (200) micrograms per cubic meter (ug/m3)
                       of air sampled, averaged over any three consecutive
                       hours.

            105.23     Four hundred (400) micrograms per cubic meter (ug/m )
                       of air sampled, averaged over any one hour period.

     105.3  Rules 105.1 and 105.2 shall not apply to solid fossil fuel fired
            steam generators.

            105.31     No person may cause, suffer, allow, or permit emissions
                       of particulate matter from any solid fossil fuel fired
                       steam generator to exceed 0.3 Ib. per million B.T.U.
                       heat input.


Rule 106.   Transient Operations.

     106.1  Rules 103 and 105 shall not apply to portable hot-mix asphaltic
            concrete plants, portable rock-crushers, and other transient
            operations engaged in public works projects which are not
            operated at the same premise for more than six months if all the
            following conditions are met:

            106.11     The plant is located at least one mile outside the
                       nearest corporate limits of any city or town.

            106.12     The plant is located at least one mile from any
                       occupied facility or recreational area other than that
                       located on the same property as the plant.
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            106.13     The plant is equipped with cyclones, or wet scrubbers,
                       or water sprays at the material transfer points open
                       to the atmosphere, or other equipment or systems ap-
                       proved by the Executive Secretary, properly installed,
                       in good working order and in operation.

     106.2  The time requirement for Rule 106.1 may be extended by the
            Executive Secretary upon written request.

     106.3  All emissions from sources operating under provisions of Rule
            106 shall be controlled so as not to permit: or create a nuisance.

     106.4  Rule 106 shall not apply to portable hot-mix asphaltic concrete
            plants after December 31, 1974.


Rule 107.   Agricultural Process.

     107,1  Rules 103, 104, 105 and 108 shall not apply to any person
            affected by Section 3.10 (e) of the State Clean Air Act.

     107.2  No person affected by Section 3.10 (e) of the State Clean Air Act
            may cause, suffer, allow, or permit emissions of particulate
            matter from any or all sources associated with a specific process
            to exceed the allowable levels specified in Table 3 and/or
            Figure 3, excep't as provided by Rule 107.3.

     107.3  Any person affected by Section 3.10 (e)  of the State Clean Air
            Act who does not wish to be controlled by the process weight
            method, established by Rule 107.2,  may select an alternate method
            of control which the Executive Secretary finds will provide
            emission control efficiency and measurement to achieve the same
            goal as Rule 107.2.

     107.4  Any person affected by Section 3.10 (e)  of the State Clean Air
            Act who does not select an alternate method and notify the
            Executive Secretary, in writing, prior to any plant investigation
            by the staff of the State Air Control Board,  shall be controlled
            by the process weight method established by Rule 107.2, unless
            the Executive Secretary, at his discretion, chooses to accept
            proposals for an alternate method at that time.

     107.5  Nothing herein is intended to affect the limitations on burning
            set out in Rule 101.

     107.6  Persons affected by Rule 107 shall  be in compliance with  the
            provisions set forth herein by February 15, 1973.
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Rule 108.   Persons affected by this regulation shall be in compliance with
            the provisions contained herein no later than December 31, 1973.
            Not later than six months after the effective date of this
            regulation, any person affected by this regulation shall submit
            to the State Air Control Board a written report on his compliance
            status, including but not limited to, the minimum time required
            to design, procure, install and test abatement equipment or
            procedures.  Progress reports shall be submitted to the Board
            every four months commencing in July of 1972 until compliance is
            achieved.

            All persons shall continue to be governed by the provisions of
            Regulation I, which became effective on March 16, 1967, and
            amended on January 23, 1968, September 12, 1969, and May 18,
            1971, and Regulation  II, which became effective February 22,
            1968, and amended on  September 12, 1969, until December 31, 1973,
            at which time this regulation shall supersede the previous
            Regulations I and II.
                                 3-19

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 STUDENT EXERCISE NO. 4





   COMPLAINT HANDLING





ODOR COMPLAINT CASE STUDY

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                                LESSON 13

                            COMPLAINT HANDLING

                        ODOR COMPLAINT CASE STUDY
GOAL.         To teach the principles of processing nuisance complaints
              with emphasis on the field investigation process.


OBJECTIVES.   At the end of this exercise,  the student should be able to:

              1.  Differentiate between good and poor complaint  investiga-
                  tion procedures.

              2.  Document the procedure for investigeition and case
                  development.

              3«  Design an odor surveillance plan for a suspected source.

              4.  Differentiate between a public and a private nuisance.

              5.  Define the various steps  in getting action from the
                  source management to abate the cause of the complaint.


INSTRUCTIONS!  No formal lecture on Complaint Handling will be given.   The
              conduct of this lesson is a self-study of an actual odor
              complaint case by each student and then developing the
              answers to the questions at the end of the case narrative.

              For reference,  Chapter 13,  Complaint Haindling is included in
              the Student Manual for a reference to be used during the
              self-study exercise.

              The case is to be read and notes made the evening  of the
              second day of the course.

              On the  third day of the course,  during the period following
              Test No. 1,  the instructor will call on students at random
              to respond to the questions posed at the end of the case
              narrative.   Thus, each point  will be discussed.

              At the end of the discussion,  a summary of complaint handling
              will be presented to the lecturer.

              After all points are discussed,  an Answer Key,  describing the
              "Collection of Data" and "Analysis of Data and Establishment
              of the Case" will be passed out to the students.   Also
              distributed will be the "Disposition of the Case"  giving the
              record of the State Agency  with respect to the case.
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                               LESSON  13
                       ODOR COMPLAINT  CASE STUDY


                       SECTION I  -  CASE  HISTORY
The following narrative is a case history of an odor complaint from the
inception of the  complaint to the final resolution of the problem.  Odor
complaints are usually challenging in that there are few, if any, agencies
that have good objective standards upon which the existence of a violation
can be based.

We will preface this exercise by stating that the only legal mechanism
available to this agency is an ordinance that forbids air pollution and
defines it as "The presence in the outdoor atmosphere of any air contaminant
which is or may be inimical to health, safety or welfare; or which is or
may be injurious  to human, plant or animal life or property; or which
unreasonably interferes with the comfortable enjoyment of life or property".

As in any air pollution problem, it is necessary that the inspector be
observant, thorough, and particularly that he be capable of exercising
"common sense".   Although there may necessarily not be a "right"  or a
"wrong" way for handling odor complaints,  a preferred set of procedures
has evolved from  experience.

Review the following information and determine to your satisfaction whether
the inspector handled this complaint properly.   Note both what was properly
done and what,  if anything,  was improperly handled.
                                   4-3

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                           THE COMPLAINT INVESTIGATION
Field Enforcement Officer, Harry Prank,  has been with the agency  just over
four months.  He has completed his basic orientation and has had  several
training courses.  He has had, however,  little practical field experience.
Due to the rapid expansion of the program and a shortage of personnel,
Harry has been shoved into the field and told to do the best that he can.

On July 6, Mr. Rust of Orangeland called the regional office and  complained
that he and his wife had nearly become ill on the previous evening as a
result of malodorous emissions from a paint plant (ALcoat Company) located
near their home.  Harry was assigned to  the investigation.

Harry immediately went to the agency's files to determine whether or not
there had been any previous complaints concerning operations of the Alcoat
Company,  His search of the records indicated that a similar complaint from
a resident in the Orangeland area had been received approximately one week
earlier.  However, due to a shortage of  personnel, no one had yet investi-
gated that complaint.

The agency's files also showed that the  Alcoat Company had received a permit
to construct a coating plant in the complaint area approximately  eighteen
months previously.  The permit file indicated that the company would utilize
catalytic combustion units to control the emission of solvent vapors from
their paint coating and baking lines. The plant construction had been
completed and the plant had been operating for approximately four months.
Another inspector checked the plant prior to the beginning of operation:
his report had indicated that the plant  was operating satisfactorily and
that there were no malodors apparent in  the vicinity of the plant at that
time.  The inspector had noted, nevertheless, that a faint solvent odor
could be detected outside of the plant.

Harry next visited the complainant at his home.  He observed that the
Orangeland development consisted of approximately one hundred homes located
on a 130 to 140 acre tract.  Adjacent to the development was a small
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(            industrial park which apparently  contained several manufacturing plants.
 -           As he approached the Rust residence, Harry was not able to detect any
             malodors.   In his conversation  with Mrs. Rust, Harry was told that the
             Rusts first became aware of the malodors approximately two weeks earlier
             and that the odor episodes had  occurred frequently since that time.
             Mrs.  Rust  further stated that several of her neighbors had also complained
             about the  malodors to her.   She offered to supply their names and addresses.
             Mrs.  Rust  pointed out the Alcoat plant to  Harry.  He noted that the plant was
             located  approximately six hundred yards away from the residential Orangeland
             area.

             After leaving Mrs.  Rust's residence, Harry drove directly to the Alcoat
             plant.   As he approached the plant, he noted that it had five stacks.  Three
             of the stacks had no  visible emissions but two were emitting white vapor
             plumes.  He  parked and entered  the plant.

             Inside he  was greeted by  the receptionist.   He identified himself and asked
             to see the plant  manager.  The receptionist placed a call and then told Harry
             that  the plant manager was not available but that the plant engineer,
             Mr. Erb, would see him.  Harry met Mr. Erb, again identified himself,
             recorded Mr.  Erb's full name and position title,  and advised Mr.  Erb of
             the nature of the problem and of his agency rules and regulations pertaining
             to such a problem.

            Mr. Erb told Harry that,  to the best of his knowledge,  the plant  and its
            associated air pollution  control equipment  was operating satisfactorily
            and that there was no problem.   He did indicate,  however,  that he, himself,
            had noted a slight odor as he drove by a metal-plating company approximately
            one mile south of his plant. He also  stated that some of his workmen had
            informed him that several of the Orangeland residents were  having  trouble
            with their septic tanks and that might be the source  of the odor.

            Mr. Erb offered to show Harry the  plant and took  him  through  the manufac-
            turing facility.   Harry observed that  the company coated strips of metal
            with paint.  The paint was baked on the strips and then quenched, after
                                                4-5

-------
C            which the metal was recoiled for  shipment to fabricating plants.  The
             baking ovens were each  vented  to  separate catalytic combustion units
             and the quenching operations each had a separate stack; there was also
             a small oil-fired boiler.

             Harry could detect strong paint solvent odor in the plant, but Mr. Erb
             informed him that this  was to  be  expected in the immediate vicinity of
             so much fresh paint.

             After the plant inspection and a  further brief conversation with Mr. Erb,
             Harry left.   On his way back to his office, Harry passed the metal-plating
             plant mentioned by Mr.  Erb.  He could not detect any malodors as he drove
             by the plant.

             Upon returning  to his office,  Harry prepared a report which detailed his
             investigation.   He concluded that, possibly, the Rusts were mistaken and
             could discover  no problem that would warrant further action by the agency.
             Harry thought that that would  be  the end of the case, but it wasn't.
(            Over the next several days,  fourteen additional complaints concerning
             malodorous emissions in the  Orangeland area were received.  The complaints
             were brought to the attention  of  Harry's supervisor who reviewed Harry's
             investigative report.   He noted various errors in the investigative
             technique and discussed these  with Harry.
                                               4-6

-------
                                           EXERCISE
             1.   Assuming that Harry neither did not saw anything more than that
                 stated  in the preceding material, prepare a critique of his
                 investigative technique.  Indicate all errors and deficiencies
                 in his  technique.

             2.   Assuming that the investigation indicated that the Alcoat Company
                 was indeed the source of the odors, explain how you would go about
                 establishing a bona fide air pollution case.  Remember that there
                 are no  specific odor control regulations and that the burden of proof
                 in establishing air pollution as defined in the agency's ordinance
                 rests with the agency.  An odor problem of this type is effectively
                 a public nuisance and the manner of establishing the existence of
/                the problem would be similar to that used to establish the existence
                 of a public nuisance.
                                        AIR POLLUTION REGULATIONS
                                          APPLYING TO THIS AREA

                            USE THE RULES AND REGULATIONS OP HENDERSON COUNTY,
                            OHIO     AS APPLYING TO THE AREA OF THIS CASE STUDY.

                                          SEE EXERCISE NO.  1
                                                4-7

-------An error occurred while trying to OCR this image.

-------
    STUDENT EXERCISE NO. 5
  COMPLAINT INSPECTION OF AN
ASPHALT CONCRETE BATCHING PLANT
        FILM & WORKBOOK

-------
r
                  LESSON 15
                                      COMPLAINT  INSPECTION OF AN
                                            ASPHALT PLANT

                                          FILM  & WORKBOOK
             GOAL.
To demonstrate a complaint inspection of an asphalt concrete
"batch plant.  The student's proficiency is tested "by completing
inspection report forms to record conditions demonstrated in
the film.
            OBJECTIVES.    At the  end of this lesson, the  student  should be able to:

                           1.   Describe  the process of manufacturing asphalt  concrete
                               in  a batch plant.

                           2.   Use existing agency data to prepare for an inspection.

                           3.   Properly  obtain  entry to a  facility for the purpose
                               of  conducting an inspection.

                           4.   List inspection  points for  asphalt  plants.

                           5.   Interface effectively with plant management and
                               personnel so as  to elicit their help and cooperation.

                               List the  information which must be  obtained from a
                               complainant.
6.


7.

8.
                               Interview complainants  so as to obtain necessary
                               information and maintain good will.

                               Prepare  inspection report forms and other appropriate
                               notices.
             SELECTED READING:
     Inspection Manual for Enforcement of New Source
     Performance Standards.
     Asphalt Concrete Plants,  Reference 27.
             INSTRUCTIONS. Use the  same format  as Lesson 6.

                          The film portrays a  response to a  citizen complaint and/
                          an inspection of the suspected source.

                          As in  Exercise No. 2, there are various documents  to be reviewed
                          and a  Data Gathering Form to be filled out as the  film
                          progresses.

                          At the conclusion of the film, the instructor will call on
                          students at random for their "Response Data" and lead a
                          discussion of the various inspection points.

                          Proceed  to review documents in preparation for viewing the
                          film.
                                                5-2

-------
    SUGGESTED INSPECTION POINTS AND DATA GATHERING QUESTIONS


                 ASPHALT CONCRETE BATCH PLANT*
Entering plant premises
Interviewing plant  manager
Reviewing .data provided
 The  plant yard
 General plant survey
 The cold feed conveyor/bucket  elevator transfer point
   *Refer  to  the  flow diagram at the end of this form for
   indicated  inspection points.
                            5-3

-------
 The rotary dryer
 The hot elevator
 The nixing tower
The  underside of  the  baghouse
The baghouse exterior
The interview with the complainant
                          5-4

-------An error occurred while trying to OCR this image.

-------
Asphalt Plant Pile Information
    Permit Application
- .  Parmetric Evaluation Form
    Summary of Source Operations
    Summary of Pitot Traverse Data
    Summary of Particulate Sampling Data
    Production Record - October
                5-6

-------
                                                    STATE Of ILLINOIS
                                              OWUWWEKTAL PROTECTION AGEHCY
                                             Binsio* OF AIR POLLUTION CONTROL
                                                   tWO CHURCHILL ROAD
                                                                  C2706
APPLICATION FOR A WCT^j
D CONSTRUCT B OPERATE .
HA* OF EQUIPMENT TO BE - . ,
CONSTRUCTED OR OPERATED Asphalt Batch Plant
fOR A6ENCY USE ONLY ,
PTRMIT HO. ,„_.,_
	 ft)

Scenic Valley Asphalt Corp.
100 Main Street
Clearview
Id. STATE OF OWNER: ],. ZIP aK:
Illinois 60000

Scenic Vallev Asphalt Corp.
Clearview 	 	 	 L """"EYES DNO
a. NAME Of OPERATOR:
Same *~~
2b. STREET ADDRESS OF OPERATOR:
Same
Same
2d. STATE OF OPERATOR: 2«. ZIP CODE:
•;
Jb. STREH ADDRESS OF EMISSION SOURCE:
loo Mair> Street 	
3«. TOHNSHIP: Jf. COUNTY: 39. ZIP CODE:
Smith Jones 60000
4.   ALL CORRESPONDENCE TO:  (NAME OF INDIVIDUAL)
  Gary Johnson	.
«.   ADDRESS FOR CORRESPONDEN£L:  (CHECK ONLY ONE)
                 »:
                           OPERATOR
                                             EMISSION SOURCE
                                                           S.   TELEPHONE NUMBER FOR ACENCY TO CALL:
7.   YOUR ID NUMBER fOR THIS APPLICATION:/,,
       100M1977                (c)
"
   AUTHORIZED SICNATURE(S)
                                           6/2/77
                                              wu
     IY
       Gary
                                                                                                          DATE
      TVPED Oft PR1NTLD hAHE Of SICNEK
       General Manager
       mm UK
                                                                                 NIHL u>
(I) CLEARLY IDENTIFY
   PERMIT WICH MAT

-------
 9.   AN OPERATING PERMIT APPLICATION HUST BE SUBMITTED  IN DUPLICATE.
     A COWR5!TTON PERMIT APPLICATION FOR CONSTRUCTION INTBoTTSuNTY OUTSIDE OF THE CORPORATE LIHITS OF CHICAGO MUST K
     SUBMITTED IN QUADRUPLICATE.
     A CONSTRUCTION PERMIT APPLICATION ID AU OTHER LOCATIONS MUST BE SUBMITTED IN TRIPLICATE.
     THE APPLICANT SHALL SUBMIT A PLOT PLAN AMD MAP SHOVING  DISTANCES TO THE NEAREST KUNDMY OF THE PROPERTY OH WICH THE OPERATION IS
     LOCATED AC DISTANCES TO THE NEAREST RESIDENCES.  LODGINGS. NURSING HOMES. HOSPITALS. SCHOOLS Ad COMMERCIAL AND MANUFACTURING
     ESTABLISHES.  IF SUCH A PLOT PLAN AMD NAP HAS  ALREADY BEEN SUBMITTED. INDICATE THE ASfOTIATED AGENCY 1.0. WOER AND PEWIT
     APPLICATION NUMBER.  AGENCY I.D. MO.                                 APPLICATION HO.
11.    THE  APPLICANT  SHALL SUBMIT A PROCESS FLOW DIAGRAM DEPICTING ALL EMISSION SOURCES  AND ALL AIR POLLUTION CONTROL EQUIPMENT COVEKiU
      BY THIS  PERMIT APPLICATION.  THE DIAGRAM SHALL INCLUDE LABELS FOR EACH EMISSION SOURCE AW EACH  ITEM OF AIR POLLUTION CONTROL
      EQUIPMENT. AND SHALL SET FORTH MAXIMUM FLOW RATES FOR (1) ALL PROCESSING EQUIPMENT. (2) ALL AIR  POLLUTION CONTROL EQUIPMENT. (3)
      ALL  EMISSION SOURCES. AND (4) AU STACKS AND VENTS.  NUMBER OF SHEETS:        1           DRAWING NUMBER(S):         1
     FOR EACH EMISSION SOURCE AND EACH ITEM OF AIR POLLUTION  CONTROL EQUIPMENT IDENTIFIED ON THE PROCESS FLOW DIAGRAM. THE APPL1CAM
     SHALL COMPLETE AND SUBMIT THt APPLICABLE PERMIT  APPLICATION  FORMS.  THE FLOW DIAGRAM SHALL INDICATE THROUGH WHICH STACK OR VENT
                 SOURCE OR ITS BELATED AIR POLLUTION  CONTROL  EQUIPMENT is EXHAUSTED.  IF ][T"Tr~EXHAusT£D WITHIN A BUILDING, so INDICATE
1 3"  IF THlS IS AN APPLICATION FOR AN OPERATING PERMIT, AND THE  APPLICANT IS INCORPORATING Tf REFERENCE PREVIOUSLY GRANTED INSTALLATION
  '  OR CONSTRUCTION PERMITS.  HE SHALL COMPLETE FORM  APC-210, DfTHLED *OATA AND INFORMATION - INCORPORATION BY REFERENCE.*       —
14.    IF THIS IS AN APPLICATION FOR AN OPERATING PERMIT. AKO THE STARTUP OF ANY EMISSION SOURCE DESCRIBES  BY THIS APPLICATION PRODUCES
      AN AIR  CONTAMINANT  IN EXCESS OF APPLICABLE STANDARDS. THE APPLICANT HAY REQUEST  PERMISSION  TO  EXCEED SUCH STANDARDS  BY COUPLET IN;
      FORM APC-203.  ENTITLED  "OPERATION DURING STARTUP.*
15.    IF THIS  IS  AN  APPLICATION  FOR AN OPERATING PERMIT, AND THE APPLICANT IS APPLYING FOR PERMISSION TO OPERATE  AN  EMISSION  SOURCE
      DURING MALFUNCTIONS  OR BREAKDOWNS PURSUANT TO PCB REGS.. CHAPTER 2. RULE 105.  THE APPLICANT MAY REQUEST SUCH PERMISSION BY
      COMPLETING  FORM  APC-204, ENTITLED 'OPERATION DURING MALFUNCTION AND BREAKDOWN.*



~6.    IF THIS  IS  AN  APPLICATION FOR AN OPERATING PERMIT AMD ALL OR ANY PART  OF THE PROCESS MltST BE CONTROLLED OR  MODIFIED TO  COMPLY
      WITH  APPLICABLE  REGULATIONS, THE APPLICANT SHALL COMPLETE FORM APC-202, ENTITLED "COMPLIANCE PROGRAM t PROJECT COMPLETION SCHEDUU
17.   IF  THIS  IS AN APPLICATION FOR AM OPERATING PERMIT, DOES THE OPERATION COVERED  BY THIS APPLICATION REQUIRE AN  EPISODE ACTION
IE.   WAS EACH EMISSION SOURCE COVERED BY THIS APPLICATION, AS OF APRIL 1*.  »72,  IN  COMPLIANCE WITH THE  'RULES AND REGULATIONS   •
      GOVERNING THE CONTROL OF AIR POLLUTION.* ADOPTED BY THE FORMER AIR POLLUTION CONTROL BOARD AND CONTINUED EFFECTIVE PURSUANT
      TO SECTION 49(c) OF THE ENVIRONMENTAL. PROTECT ION ACT?        [£] YES           PI MO
 15.
IF THIS IS AN APPLICATION FOR AN OPERATING PERMIT. MAS THE OPERATION THE SUBJECT OF A VARIANCE PETITION FILED WITH THE ILLINOIS
POLLUTION CONTROL BOARD ON OR BEFORE JUNE 13, 1972?        TH  YES           g  NO

IF "YES." CITE PCB NUMBER(S): 	 BATE OF BOARD ORDER: 	

HAD THE APPLICANT ON OR BEFORE APRIL 14. 1172. COMMENCED CONSTRUCTION OF EQUIPMENT Oft MODIFICATIONS SUFFICIENT TO ACHIEVE COMPLIA
WITH THE APPLICABLE LIMITATIONS OF THE  "RULES AND REGULATIONS GOVERNING THE CONTROL OF AIR POLLUTION." ADOPTED BY THE FORMER AIR
POLLUTION CONTROL BOARD AND CONTINUED EFFECTIVE PURSUANT TO SECTION 49(c) OF THE ENVIRONMENTAL PROTECTION ACT? QYES    [_] NO

IF *NO," EXPLAIN IN DETAIL AND MARK TOUR EXPLANATION AS EXHIBIT 0.

TOTAL WMBER OF PAGES IN EXHIBIT 0: 	
 20.   IF THIS IS AN APPLICATION FOR AN OPERATING PERMIT. THE APPLICANT SHALL SUBMIT AN ESTIMATE OF THE MAXIMUM ONE-HOUR AMOUNTS OF
      PARTICIPATE MATTER. SULFUR DIOXIDE.  CARBON MONOXIDE. OXIDES OF NITROGEN. AND ORGANIC MATERIAL EMITTED FROM ALL SOURCES LOCATED
      ON THE PLANT OR PREMISES.  THIS ESTIMATE  SHALL  INCLUDE ALL EMISSION SOURCES LOCATED ON THE APPLICANT'S PREMISES AND NOT JUST
      THE EMISSION SOURCES DESCRIBED IN THIS APPLICATION.
       MATERIAL
                     MAXIMUM ONE-HOUR
                         AMOUNTS
                                               MATERIAL
MAXIMUM ONE-HOUR
   AMOUNTS
HftTBML
                                                                                                                         MAXIMUM ONE-t
 'ARTICULATE
 UTTER
                                          SULFUR
                                          DIOXIDE
                      NITROGEN
                      OXIDES
                            ^JL
                                             LB
                  -t!
                          J*£
 WTERIAL- .
                                          CARBON
                                          KONOXIDE
                                       03
                                                                              • 17
                                                                                              U
  21.   WHAT  IS THE SIZE  (IN ACRES) OF APPLICANT'S PREMISES?
                                                                50
       LIST AND  IDENTIFY ALL FORMS, EXHIBITS. AND OTHER INFORMATION SHMITTED AS PART OF THIS APPLICATION.   PUASE  NUMBER EVERY PAGE
       AND STATE THE TOTAL HHBER OF PAGES IN THIS APPLICATION.                             *                   	
                	5-8	     •                 •   -

-------
r
      STATE OF ILLINOIS
 tWURONMENTAL PROTECTION AGENCY
DIVISION OF AIR POLLUTION CONTROL
     2200 CHURCHILL ROAD
  SPRINGFIELD. ILLINOIS   (2706
DATA AND INFORMATION
PROCESS EMISSION SOURCE (A)
ft* ACENCT USE OKU •
             or PLANT OWNER:
         Scenic Valley Asphalt  Corp.
                                                              2.  NAME OF CORPORATE DIVISION OR PLANT  (IF OlFFERtNT FROM
         100  Main  Street
                4.  CITY OF EMISSION SOURCE:
                  Clearview	
                                                    CENERAL INFORMATION
                 XESS:
         Asphalt  Paving Material Batching
                6.  NAME OF EMISSION SOURCE EQUIPMENT:
                 Asphalt  Batching
                 "'"UJlRn  i^mfc^r "" •     "	•<«•
                6.
                                                                     NUMBER:
         Cedar  Rapids
H
                                            9.  SERIAL NUMBER:

                                              C254171
                                            D""JBED °" ™" FORM <«"« TO -6ENERAL' INSTRUQIONS FOR COMPLETION OF'PERMIT
             10    HRS/DAY     6  DAY5/WK      "30
                                                    WO/YK
               13.  HKW1 U AMIAL

                   OCC/FEB  0   I MAR/MAY 15  t JUN/AUC 60 I 5EP/NDV  25
                                                  RAW MATERIAL INFORMATION
     U.
                     NAMES OF RAW MATERIALS(B)
                     NAXinUM RATE PER
                     IDENTICAL SOU°CF
                           AVERAGE RATE PER
                           IDENTICAL SOURCE
         Aggregate  -  Various sizes  depending
        —	on  mix  desired	
                      >00.000
               U/HR
937
        Asphalt
                       30.000
                                                                                                  15,000
                                                                                   LB/HR
                                                                                  .,LB/HR
                                                                                                              LB/HP
                 E«SSION SOURCE OTHER THAN A .UU  .,::•_, I |-n IHISSION SOURCE OR
              ' WIL"' °* SIMILM fW">«'" KEO «• THf. MtlHAI-^ »uM-aU  OF PRO-
                      ' ttH>Lm *WT* *"° '"FORMATION -Full CW^TION EMISSION
                          l$ •**'•  «« SUCH *"
         * WHKMTW
         8UC NG HEAT OR
         SOuicE ^FWW A
         ^WTi AND

     »)  CONPOsmONS OF ^ HATERIAIS MUST BE DHAILfO TO THE EXTENT KO3SAKT TO DnERniNE THE fATUtt MO OWMCTm OF POTENTWi W1SSIOKS.

           .                                               5-9    -

-------
                                                                     MAXIMUM KATE PIS
                                                                     IDENTICAL SOURCE
                      NAMES OF PRODUCTS
                                                                                                     AVERAGE RATE PER
                                                                                                     IDENTICAL SOURCE
    Hot-Mix Asphalt Paving Cement
                                                  HASTE MATERIAL INFORMATION
                                                                    MAXIMUM RATE PER
                                                                    IDENTICAL SOURCE
                  "AMES OF HASTE MATERIALS
                                                                                                    AVERAGE RATE PER
                                                                                                    IDENTICAL SOURCE
   Water  Vapor
                                                                        25,000     LB/HR
                                         .MAXIMUM EMISSIONS  FROM EACH IDENTICAL SOURCE*
   CONTAMINANT

I?.  PARTICULATE
    MATTER
IS.  CARBON
    MONOXIDE
19.  NITROGEN
    OXIDES
20.  ORGANIC
    MATERIAL
    DIOXIDE
    OTHER
    (SPECIFY)
                           CONCENTRATION OR EMISSION RATE
                                 6R/SCF
                    t.
                                   PPM
                                   (VOL)
                                   PPM
                                   (VOL)
                    *.
                                   PPM

                                  (VOL)
                                 •^HB^BH

                                   PPM

                                  (VOL)
                                                        LI/HR
                                         b.
                                         b.
                                                       U/KR
                                                      ^••••IMM


                                                       LB/HR
                                                      "••—^™™


                                                       LI/HR
                                         b.
                                                       U/KR
                                                      •••••MMI


                                                       LB/HR
                                                                    METHOD USED TO DETERMINE CONCENTRATION OR EMISSION RATE
                                                              c.
                                                              c.
                                                              c.
                                                              c.
c.
                                                      EXHAUST DATA*
23•  ?IP>' DIAGRAM DESIGNATI
    cK&yg ai
    EXIT DIAMETER:
                               27.  EXIT HEIGHT ABOVE MADE:
RATE THROUGH EACH
ACFM
EIGHT OF NEARBY
: FT
25. EXIT CAS TEMPERATURE:
1
29. EXIT DISTANCE FROM NEA
PLANT BOUNDARY: . |
      COMPLHE THESE SECTIONS ONLY IF EMISSIONS ARE EXHAUSTED WTHOUT CWTKOl EQUIPMENT.

      "~~~~^~™"~"~1^"™^™111™~"llto~~^"~"  5-10   ———

-------
                                                       STATE OF ILLINOIS
                                                ENVIRONMENTAL PROTECTION AGENCY
                                                DIVISION OF AIR POLLUTION CONTROL
                                                      2200 CHURCHILL ROAD
                                                 SPRINGFIELD. ILLINOIS   C2706
DATA AND INFORMATION
AIR POLLUTION CONTROL EQUIPMENT
FOR AGENCY USE ONLT •
1. NAPE OF OWNER:

   Scenic Valley  Asphalt  Corp.
                                                            2.  NAME OF CORPORATE DIVISION Oft PLANT (IF DIFFERENT FROH
3.  STREET ADDRESS OF EMISSION SOURCE:

   100 Main   Street
                                                            4.  CITY OF EMISSION SOURCE:

                                                           	Clearview
                                                     ADSORPTION SYSTEM
AP*iw*?Si5s."Fo»JAAPc.1o?):*KORPT10N $YSTWS ttSMIB" IH THIS
                                                                    <*F» T0 '««•*•• INSTRUCTIONS  FOR COMPLETION or PERMIT
                                                               3.  MODEL NAME AND NUMBER:
7.  METHOD OF REGENERATION:

      O REPLACEMENT
                                          S.  NUMBER OF BEDS PER SYSTEM
                                                                               t. ADSORBANT HEIGHT KR (ED:
                                                                                                                    IB
                                   STEAM
                                               O OTHER (SPECIFY
B.  TIME ON LINE BEFORE REGENERATION:
                                                      M1N/BED
                                                               9.  EFFICIENCY OF CONTROL (ATTACH TEST REPORT OR EXPLAIN ESTIMATE)
                                                         AFTERBURNER
                                                 '" ™IS UCTI0" <""" T° "ttNtRAL  «KT«UOIOW FOR COMPLETION OF PERK1T

U GAS Q OIL ( 	 _ 	 J SULFUR)
6. INLET GAS TEMPERATURE: 	
3.
S.
7.
LENGTH _^ U,; CROSS SECTION
U ns U NO
10.


BURNERS PER AFTERBURNER «
OPERATING TEMPERATURE
IN I
EFFICIENCY OF CONTROL
PARTICIPATE
OF COMBUSTION CHAMBER:
IN; OR
(ATTACH TEST REPORT OR
S CASEOUS

BTU/KF
EACH


EXPLAIN ESTIMATE):
I
                                                          5-11
                                                                                                                  MCE 1 0

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1
1

FOR MENCY US.E ONLY



CONDENSER
'" ^ICMIO^.^FO^APc'-M?):0*'1*""5 KSCR1BE° '" ™IS $£CTIW . l«TRUCT10flS FOR COMPLETION OF PERMIT

D WATER ( CPM) Q'AIR (
INLET -F OUTLET
FT*

1

SCFM) D OTHER (TYPE FLOW RATE ,
	 ^"F INLET . «F OUTLET 't
8. EFFICIENCY OF CONTROL (ATTACH TEST REPORT OR Em.A!tl ESTIMATE):
.
eraow Prittarv Control
LI IONS. RM APC-ZOl :
Iowa Manufacturino Corn.


4. NUMBER OF CYCLONES IN EACH MULTIPLE CYCLONE:
6. DIMENSION THE APPROPRIATE SKETCH (IN INCHES) OR PROVIDE A 0
- ^^
r — 60—1
3. MODEL NAME AND NUMBER:
Sinqle Stage 24 OH
S. EFFICIENCY OF CONTROL (ATTACH TEST REPORT OR EIPLAIN ESTIMATE):
AP-42 	 65
RAWING WITH EQUIVALENT INFORMATION:
nT
J :

ELECTRICAL PREC1PITATOR
'' OF^EWT^PUCATIONS^So^APC-ZO^ "ttC">IUTORS «CRIBED IN THIS SECTION (REFER TO '6ENERAI INSTRUCTIONS FOR COMPLETION
'.. MANUFACTURER:
I. COLLECTING ELECTRODE AREA PER CONTROL DEVICE:

3. MODEL NAME AND NUMBER:
5. EFFICIENCY Of .CONTROL (ATTACH TEST REPORT OR EIPLAIN RESULTS):
FT* »

FILTER Secondary Control
' row SpMOl)*""1*"0* °f FILT£K KSC">BtB Jlt THli ««»0" <«"» « -SENERAL INSTRUaiONS FOR COMPLETION OF PERMIT APPLICATIONS."
• MANUFACTURER :
Western
FILTERING AREA PER CONTROL DEVICE:
1 3200
IT COAMING: __
U SHAKER Q REVERSE AIR U PULSE AIR B PULSE JTT
D BLEED- IN A|R( 5CTV) D MATER SPRAY (
INLET 6AS: 	
TEMPERATURE 300 'f; OfV PTIKT 16
n-ito
3. MODEL NAME AND NUMBER:
S1132
S. FILTERING MATERIAL:
"2 Fiber Glass
DoTHER(SPECIFY , ) .
__ 36x24
«••«) H DUCTUCNGTH 70 FT: 01* M D OTNTifwrC |t»)
_ ». EFFICIENCY OF CWTPOL ('HACM nST «£»)»: OP E»P' (IN ESTIMTCi-
5-12 flv t ^

-------
          rot AGENCY ust OM.»
                                                                   SCRUBBER
         4  SCRUBBER TYPE:


            CD  HIGH ENERGY (us  STREAM PRESSURE DROP


            D  wctto (PACUNC TYPE


           1—I  SPRAV (NUMBER Of  NOZZLES


           D EITHER (SPECIFY
                                                             IN H20)
                                       ;   PACKING SIZE
                                         ; NCIZIE PRESSURE
    IN;    PACKED HEIGHT


   	 PSIC)
                                                                                                    IN)
                                                  ATTACH DESCRIPTION AND SKETCH WITH DIMENSIONED DETAILS)
         5   SCRUBBER GEOMETRY

              LENGTH Id DIRECTION Of GAS FLOW
            LIOUIC FLOW RATE INTO SCRUBBER
                                                                           CHEMICAL  COHPOSITIOh OF SCRUBBAM
                                                       OTHER TTPES OF COKTWL EpUIPMENT
        2.  6ENERIC NAME OF OSKTRO.
                                                  3.  HUtUFACTURER:
                                                                                           4.  WDEL NAME AND NITCER
i.  ATTACn DESCRIPTION AND SnETCh OF CONTROL EQUIPMENT
   DIMENSIONED DETAILS AND FLOW RATEsT    tOUIP"«T
                                                                      *•  fr"««CT OF CONTRA  (ATTACH TEST REPORT OR EXPLAIN ESTIKATE)
                                                                          PARTJCU.ATE	        j   6AS£0US                    ,
5-13
                                                          EMISSIONS  FHW EACH IDENTICAL EXIT
                                   CONCENTRATION JJR EMISSION RATE
                                                                            »CTHOD USED TO  DCTEM1NE CONCENTRATION OR EMISSION  RATE
                                                                         EPA Method  -  5
                                                                      e-  Emission  Factors  for  Natural  Gas
                                                                         Combustion  (AP-42)
                                         EXIT HEIGHT ABOVC MADE
                                                30
                                                         fT
                                                              *•  **.^FL* UTE THROUGH EACH
                                                                        28,000
6.  MAIJMUK HEIGHT OF NEARBY
   •UIL01NGS:  ,.          „
                                3.  EXIT  GAS TEMPERATURE:
                                        250
'•  EXIT DISTANCE F«0« NEAREST
   PLANT IDUNDARY:

-------An error occurred while trying to OCR this image.

-------An error occurred while trying to OCR this image.

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                        SUMMARY OF  SOURCE  OPERATION
 PLANT:     Scenic Valley Asphalt Corp.
 LOCATION:    100 Main Street, Clearview. Illinois
 DATE OF TEST:     July 7, 1977
 TYPE OF PROCESS/EQUIPMENT:    Permanent Asphalt Plant
 Material Processed or Produced:   Asphalt paving material	
[Operating Schedule:     10	Hr./bay       	180     Dav/Year
(Maximum Operating Capacity  (Include Units) •
|Hormal Operating Capacity:     120 T/hr.
              2.52.5 T/hr.
 Operating Capacity During Test:  Test 1 118T;  Test 2 13QT: Test 3 123T
[Fuel.Type:  Natural  Gas    % Ash:      N/A	 % Sulfur:     N/A
 Amount of Fuel Consumed During Test:    Not measured.	
pollution Control System Description:  Primary cyclone;  secondary positive
   pressure,  pulse-cleaned  baghouse with dust return to fines storage bin.
 Pressure Drop Across Collector:
 Additional Information :
6" W.C.
                                   5-16

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                      SUMMARY OP PITOI TRAVERSE DATA            SHEET 1 of

PLANT:  Scenic Valley Asphalt Corp.    SOURCE:  Baahouse StacV	 DATE:  7/7/7
A.  Stack Dimensions                                          2' x 4'
B.  Area of Stack,  Sq. Ft.                                	8	
C.  Barometric Pressure,  "Kg                             	29.65	
D.  Gage Static Pressure in Stack, "i^O                          0.18"	
E.  Stack Gas Temperature,  Dry Bulb,  °F                   	280	
F.  Percent Moisture                                     	10%	
G.  Dry Gas Composition:  %C>2                                   17.1	
                         %C02                           	2.1	
                         %CO                                  < 0.1	
                         90*2                            	80.8	
                         % other	           	-
H.  Density of Dry Stack Gas,  @ STP,  Lbs./Cu.  Ft.         	0.08
I.  Density of Moist Stack Gas, @ STP,  Lbs./Cu.  Ft.       	0.07
J.  Density of Moist Stack Gas, @ Stack Conditions,
    Lbs./Cu. Ft.          •                               	0.054
K.  Total Number of Traverse Points                              12
L.  Pitot Tube Calibration Factor                               0.82
M.  Average Square Root Velocity Head of all
    Traverse Points                                       	0.77
N.  Average Gas Velocity, Feet/Min.                       	3500
0.  Stack Gas Flow Rate:
    1.  @ Stack Conditions, Wet. ACFM                         28,200
                         *   '                              ^^**«W™«i«^^^^B«*"^^^«^^^**™^^^™
    2.  @ Standard Conditions, Wet, SCFM                      20,300
    3.  @ Standard Conditions, Dry. DSCFM                     18,250
STP * 70°F, 29.92 "Hg.
"Wet" or "Moist" - Refers to the condition of the gas with actual water
                   content.
                                     5-17

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                      SUMMARY OF PARTICULATE SAMPLING DATA
          SHEET 1 of
r
    PLANT; Scenic Valley Asphalt Corp. SOURCE:  Baahouse Outlet  DATE:   7/7/71
A.  Sample Number

B.  Number of Points Sampled

C.  Total Duration of Sample, Min.

D.  Nozzle Diameter, In.

E.  Nozzle Area, Sq. Ft.

F.  Calibration Factors

   1.   Probe Pitot Tube

   2.   Gas  Meter                       B@

G.  Barometric Pressure,  "Hg.

H.  Gage Static Pressure  in Stack,  "H20

I.  Stack Gas Temperature,  °F  (Ave)

J.  Average  Square Root Velocity Head
   of Points Sampled

K.  Average  Gas Meter  Temperature,  °F

L.  Average  Gas Meter  Pressure,  "H20

M.   Gas Meter Volume,  Actual,  Cu. Ft.

N.  Gas Meter Volume,  €> STP, Cu. Ft.

0.  Liquid Volume of Water Condensed, ML.

P.  Vapor Volume of Water Condensed at
    STP, Cu. Ft.

Q.  Total Gas Sampled Through Nozzle,
    @ STP, Cu.  Ft.

R.  Percent Moisture in Stack
                                                12
 12
 12
                                                60
 60
 60
                                               .260
,260
.260
                                               ,000369 .000369 .000369
                                                .82
                                               2.07
                                                 .18
                                                270
                                                 .76
                                               88.2
                                                .716
 .82
 .82
2.07
2.07
                                              29.80   29.80   29.80
 .18
 .18
 280
 290
 .77
 .78
91.8
89.6
 .743
 .785
                                              44.80   45.74   47.09

                                              44.00   45.04   46.57

                                              102.1   105.6   108.3
                                                4.77    5.06     5.23
                                               48.75   50.10   51.80

                                                 9.8    10.1    10.1
                                          5-18

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                   SUMMARY OP PARTICULATE SAMPLING DATA      SHEET 2 of 2
                                                                    i
5,  Particulate Concentration
    1.   Grains/Dry Standard Cubic Feet      .05	.04	.05
    2.   Lbs./Hr.                            8.0	6.3     6.0
T.  Percent Isokinetic                     105.6   108.6    107.9
STP = 70°F,  29.92  "Hg.
"Wet"  or "Moist" - Refers  to the condition of the gas with actual
                   water content.
                                    5-19

-------An error occurred while trying to OCR this image.

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     STUDENT EXERCISE NO. 6
INSPECTION OF COMBUSTION SOURCES
        LECTURE AND FILM

-------
United States
Environmental Protection Agency
Contract No. 68-02-1315
Applied Science Associates, Inc.
Box 158 Valencia, Pennsylvania  16059
INSPECTION OF COMBUSTION SOURCES
        a training module
for fuel burning equipment inspectors

        TRAINEE'S WORKBOOK
 Zita Glasgow, Project Manager
 Applied  Science Associates,  Inc. Box  158
 Valencia,  Pennsylvania   16059
 and
 Michael  C.  Osborne,  Project  Officer,  U.S.  EPA
Prepared for the
United States Environmental Protection Agency
Control Programs Development Division
Air Pollution Training  Institute
Research Triangle Park, North Carolina   27711
March 1974

-------
us
EPA
This is not an official policy and standards document.
The opinions, findings, and conclusions are those of the authors
and not necessarily those of the Environmental Protection Agency.
Every attempt has been made to represent the present state of the art
as well as subject areas still under evaluation.
Any mention of products or organizations does not constitute endorsement
by the United States Environmental Protection Agency.
                                     6-11

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                           ACKNOWLEDGEMENTS


     The project reported in this volume was developed under a contract
from the Environmental Protection Agency, Contract No. 68-02-1315.
Mr. George Purifoy, Program Scientist, served as principal investigator.
Ms. Zita Glasgow, Staff Scientist, served as project director.
Mr. Joseph Cherico of the Allegheny County Health Department's Bureau
of Air Pollution Control, and Mr. Richard W. Gerstle, Vice President  of
PEDCO-Environmental Specialists, Inc., served as technical consultants.
     The author is indebted to numerous people for their cooperation
and participation in the project.  Silvermine-Films, Inc.  provided  the
film making expertise for the project.  Mr. Joseph Cherico played the
role of the Field Enforcement Officer in the film and assisted in obtain-
ing permission from industries to film at their facilities.  The roles
of the plant Representatives  were played by Mr.  D. E. Kordes,  Mr. G.  Edward
Scutt, and Mr. Al Taylor.  The New Jersey State Bureau of  Air Pollution
Control and the Pennsylvania  Bureau of Air Quality and Noise Control
assisted in the field test of this material.
                               6-iii

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                    AIR POLLUTION TRAINING INSTITUTE
             MANPOWER AND TECHNICAL INFORMATION BRANCH
                CONTROL PROGRAMS DEVELOPMENT DIVISION
             OFFICE OF AIR QUALITY PLANNING AND STANDARDS
The  Air Pollution Training Institute (11 conducts  training for personnel working on
the development and improvement of state, and local governmental, and  EPA  air
pollution control programs, as well as for personnel in industry and academic insti-
tutions;  (2)  provides  consultation and other  training assistance  to governmental
agencies,  educational institutions,  industrial organizations,  and  others  engaged in
air  pollution  training  activities,-  and (3)  promotes  the development and improve-
ment of air pollution training programs in educational institutions and state, regional,
and  local governmental air pollution control agencies.  Much of the program is now
conducted by an on-site contractor, Northrop Services, Inc.

One of the principal mechanisms  utilized to  meet the Institute's goals is the intensive
short term technical training  course.  A  full-time professional staff  is responsible  for
the design, development, and presentation of these courses.   In addition the services
of  scientists,  engineers,  and  specialists  from   other  EPA  programs, governmental
agencies,  industries, and universities are used to augment  and reinforce the Institute
staff in the development and presentation of technical material.

Individual course objectives and  desired learning  outcomes are delineated to  meet
specific program needs through   training.   Subject matter areas covered include air
pollution source studies,  atmospheric  dispersion, and air quality management.  These
courses are presented  in  the  Institute's resident classrooms and laboratories and at
various field locations.                  , r
                                              Q&tsllJ&z&t&tte'*'
Robert G. Wilder                                 A       ifcan j. Schueneman
Program Manager                                "      KChief. Manpower & Technical
Northrop Services, Inc.                                       Information Branch

                                      6-iv

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                      TABLE OF CONTENTS
OVERVIEW OF THE COURSE	    1

CHAPTER 1.  ELEMENTS NECESSARY FOR GOOD COMBUSTION  .    3

   Introduction 	    3
   The Composition of Fuels	    3
   Air Supply for Combustion  	    4
   Elements of a Good Combustion System	    7
   Definitions of Some Components in the
      Combustion System and Their Functions 	    9

CHAPTER 2.  OPERATION OF EQUIPMENT TO BE INSPECTED  .   11

   Introduction 	   11
   The Spreader Stoker	11
   Pulverized Fuel Firing Units 	   15
   Cyclone Furnace   	   18
   Oil Burning Furnaces 	   22
   Air Pollution Control Equipment  	   26

SELF-EVALUATION QUESTIONNAIRE I 	   30

CHAPTER 3.  INSPECTION POINTS AND OBSERVATIONS WHICH
   SHOULD BE MADE	   35

   Introduction 	   35
   Observe Plume Before Entering the Plant  	   36
   Inspect Fuel Preparation System  	   36
   Inspect Furnace Interior 	   38
   Inspect Control Panel Instrumentation   	   39
   Inspect Fans and  Duct Work	46
   Inspect Ash Disposal Systems 	   46
   Inspect Air Pollution Control Systems   	   46

SELF-EVALUATION QUESTIONNAIRE II  	   48

CHAPTER 4.  SOURCES  INSPECTED IN THE FILM	   51

   Introduction 	   51
   Your Job While Viewing the Film	   51
   Information About the Sources to be Inspected
      in  the Film	  53

REFERENCES	  78
                          6-v

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Table
                          LIST OF TABLES
                                                               Page
 1.1     BTU Values When the Three Important Combustibles
            in Fuel Unite With Oxygen at the Combustion
            Temperature	     5

 2.1     National Bureau of Standards Grades for Fuel  Oil  .  .    23

 3.1     Plume Characteristics and Operating Parameters ...    37

 3.2     Guides for C02 Concentration in Flue Gas Leaving
            Furnace	    42

 3.3     Guides for ©2 Levels in Combustion ..,..,....    42
                                  6-vi

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LIST OF FIGURES
Figure
1.1

2.1

2.2

2.3
2.4
2.5
2.6


2.7
2.8
2.9

2.10
3.1
3.2
3.3
3.4

3.5
3.6
4.1
4.2

Diagram of the basic elements of a combustion

Traveling grate Spreader Stoker with front ash

Spreader Stoker installation with gravity
fly-ash return 	
Circular burners for firing pulverized coal ....
Direct-firing system for pulverized coal 	
Cyclone Furnace operation 	
Bin, direct-firing, and direct-firing pre-drying
bypass systems for coal preparation and feeding
to the Cyclone Furnace (schematic) 	
Firing arrangements used with Cyclone Furnaces . . .
Circular register burner for oil burning 	
Cell burner for pulverized coal, oil and

Air pollution control equipment 	
Opacity chart 	
Opacity chart 	
Steam-flow/air-flow pens calibrated to coincide . .
Steam-flow/air-flow pens modified to show parallel
traces 	
C02 concentration recorded continuously 	

The control room 	
C©2 concentration 	
Pag

8

12

13
16
17
19


20
21
25

25
27
41
41
43

43
45
45
56
56
                   (Continued, next page)
  6-vii

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LIST OF FIGURES (cont.)
Figure
4.3
4.4
4.5
4.6

4.7
4.8

4.9
4.10
4.11
4.12
4.13
4.14
4.15
4.16
4.17
> 4.18
4.19

4.20

4.21

4.22
4.23

Condition of steam-f low/air-flow 	 .
Emissions as shown by opacity chart ... V ...

Readings on "bus .section" of electrostatic


Equipment associated. with the forced air fan




A portion of the Spreader Stoker grate '.''.'.






Pressure drop gauge for air pollution control

The oxygen recorder, the opacity recorder and the
steam-flow/air-flow recorder .... 	
Gauges showing conditions of the fuel delivery



.pass.
57
57
1 58

58
59

59
59
60
65
65
66
67
67
68
68
69

• 69

74

75
76
77
            6-viii

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                        OVERVIEW OF THE COURSE

     This course is intended for personnel  in air pollution control
agencies who are responsible for inspecting fuel-burning equipment.
Fuel-burning equipment, as treated in this  course, consists of equip-
ment designed to burn fossil fuels in order to generate heat.   The
heat generated is then used in various thermal processes such as steam
generation and electric power generation.  At the end of this course
you will be able to distinguish between good operating practices which
will result in reduced air pollution and poor operating practices which
may result in an increase in air pollution.
     The course has two interdependent components—the Workbook and a
Film.  The Workbook contains information about the:
        Elements necessary for good combustion (Chapter 1).
        Operation of equipment to be inspected (Chapter 2).
        Inspection points and observations  which should be
        made (Chapter 3).
        Sources inspected in the film (Chapter 4).
The Film shows the inspection process as it would actually be carried
out by an experienced Field Enforcement Officer (FEO).  As you view the
Film you will make the same visual inspection points asKthe FEO in the
Film.  You will see what he sees and then for some points decide whether
or not satisfactory or unsatisfactory operating practices are evident.
The Film is divided into three parts:
        Part I:     Inspecting a plant which has a pulverized coal
                    burner.  This part of the film contains a
                    sequence about the Cyclone Furnace.
        Part II:    Inspecting a plant which has a spreader stoker
                    furnace.
        Part III:   Inspecting a plant which has an oil burner for
                    residual or distillate oils.

PA.C.pm.112.5.74
                                6-1

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          CHAPTER 1. ELEMENTS NECESSARY FOR GOOD COMBUSTION

                                Introduction
     Combustion is the chemical combination of oxygen with the combus-
tible elements of a fuel.  It can take place rapidly, as for example in
a fireplace or a boiler furnace.   Or it can take place very slowly, taking
years in the process.  A discussion of combustion which takes place over
a long period of time may be helpful in understanding what goes on during
the process.  Vegetation, left to rot, will after a while disappear be-
cause it will have gone through the process of decay.  During this process,
a chemical action takes place.  The matter which forms the waste is oxi-
dized.  In other words, it forms various compounds which pass away mostly
in the form of gases.  During this process some heat is given off, but be-
cause the process is so slow, it goes unnoticed.  Assume this heat is given
off in a confined space where the gases cannot escape, as for example with
hay in a barn.  The increase in temperature might cause an increase in the
temperature of the hay, until perhaps the gases given off ignite and the
hay and barn catches fire.  Essentially the same process occurs in large
combustion systems, such as boiler plants.  The combustion system feeds
fuel which mixes with air and ignites when the temperature is high enough.
The fuel then burns at rates necessary to generate the amount of thermal
energy needed.


                           The Composition of Fuels
     There are just three combustible chemical elements of significance—
carbon, hydrogen, and sulfur.  The most important combustible in all fuels
is carbon.  Carbon is present in fuels in varying quantities.  Coal, coke,
and oil are valuable and useful as fuel because of their high carbon
content.
     Next to  carbon, hydrogen, a gas, is the most important constituent
of fuels and  plays an important part in the combustion process.  It is
                                 6-3

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 foujd  in small quantities  in most  fuels, hut  it  is  important because  of
 the high heat output from  its  combustion.
     Sulfur  is present in  most fuels in small quantities.  Sulfur  is  usually
 of minor significance as a source  of heat, but it can be of major  signifi-
 cance  in pollution problems.

                            Air Supply for Combustion
     Oxygen  necessary for  combustion is found in air.  Air is  composed of
 largely two  gases, oxygen  and  nitrogen.  There is approximately  four  times
 the volume of nitrogen to  that of  oxygen.  Nitrogen is an inert  gas and
 has no direct value as an  aid  to combustion,  but it is a source  of pollu-
 tion.  At extremely high temperatures the nitrogen molecules and the  atmos-
 pheric oxygen molecules combine to form oxides of nitrogen. (NOX).  NOx
 emissions from large plants may produce a brownish haze or cloud in the
 vicinity of  the plant.
     When oxygen unites with the carbon in a  fuel,  two important gases re-
 sult from this chemical action.  One is carbon monoxide (CO) and the  other
 is carbon dioxide (C02).   If sufficient air is at hand when this chemical
 action takes place then C02 is formed.  If there is an insufficient supply
 of air, CO is formed.  The heat output from C02 is nearly three and one
 half times greater than that from CO.  It is  obvious that to obtain the
 greatest heat output when  carbon is going through the combustion process,
 a sufficient supply of air must be available.  Hydrogen, the next most
 important combustible, unites with oxygen and forms water vapor or
 steam  (H20).
     The heat value of sulfur is small but the oxidation of sulfur forms
 sulfur oxides (SOX).   Sulfur oxides are produced in significant quantity
by the combustion of most coals and fuel-oils and are a serious cause of
 pollution.   Sulfur oxides  can be controlled by using low sulfur fuels in
 the combustion process.

     In the  combustion process, the uniting of carbon, hydrogen, and  sul-
 fur can take place only at what is known as "the temperature of  combus-
 tion"  or the "ignition temperature".  This temperature varies with each
                                         6-4

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constituent of any given fuel.  Ignition temperature is the temperature
which must be attained or exceeded in the presence of oxygen to cause
combustion.  The important point is that combustion cannot take place
completely below this temperature.
     The heat of combustion is measured as  the quantity of heat evolved
by burning a standard unit of fuel  (BTU/kilogram  for coal and  BTU/liter
for oil).  Heat contents of fuel differ because of variations  in percent-
ages of carbon, hydrogen, and sulfur.  Table  1. 1  shows the heat produced
for 1 kilogram  (kg)  of carbon, 1 kg of hydrogen,  and 1 kg of sulfur.
            Table 1.1  BTU Values When the Three Important Combustibles
            in Fuel Unite with Oxygen at the Combustion Temperature

             1 kg  carbon (complete combustion
                forming C02)                      =  32,288 BTU
             1 kg  carbon (incomplete combustion
                forming CO)                      =  14,207 BTU
             1 kg  hydrogen                       - 136,868 BTU
             1 kg  sulfur                         "   8,882 BTU
            Source:  Cotton, J. C.  Combustion and modern coal-
                     burning equipment.   London:  Pitman & Sons,
                     1946.
      As we said earlier,  the oxygen required for combustion is largely
 drawn from the air supply.   However, oxygen is only one of several gases
 in air.  It contains 23.2 percent of oxygen by weight.   About 2-2/3 kg of
 oxygen are needed to complete the combustion of 1 kg of carbon, while 8 kg
 of oxygen are required to completely burn 1 kg of hydrogen.  It is obvious
 that a great deal of air  is needed in order to provide  the required amount
 of oxygen for combustion.
                                  6-5

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     For complete  combustion  to  take  placr,  it  is  necessary that  ea-.:rs pat-
 tide of the substance being  burned be  ir,  intimate contact  with the oxygen.
 With solid  fuels this is a problem because of the  small  surface of the fuel
 exposed to  the air.
     If sufficient air reaches the combustion chamber  and the  firebed and
 is intimately mixed with the  fuel, complete  combustion will take  place.   If
 the air supply is  in any way  restricted  in quantity then there will be in-
 complete combustion.  Uuburned particles of  carbon in  the form of hydro-
 carbons will pass  out through the stack  as visible emissions.   There will
 also be a considerable waste  in heat  generated  due to  the formation of CO
 instead of  C02-
     In order to ensure that  sufficient  air  has reached  the  combustion
 chamber, several types of combustion  air are of interest.   Primary air is
 air which is introduced with  the fuel at the burner or over the fuel bed.
 Secondary air is introduced through specifically arranged inlets.
     In order to ensure that  sufficient  air  reaches the  combustion ;;iaa.bv,,
 it is usual to supply air in  quantity in excess of what  is  theoreti .ally
 required.  The actual amount  of excess air necessary varies with  each
 installation.
     Increasing the excess air decreases the amount of unburned coabusti.xle
matter and increases the combustion efficiency.  At the  same time  excess
 air dilutes and cools the combustion gases.  Each  kilogram  of  excess  air
 introduced into the chamber absorbs useful heat.   Because excess  air  is a
 factor in the emission of all air contaminants optimum excess  air  require-
ments should be established for each installation.
     In summary,  there are three main requirements  for complete com".uec,ii,»tt,
They are:
        1.   Air from which the correct amount of oxygen  can be drawn.
        2.   An intimate mixture of fuel and  air.
        3.   A sufficient temperature at  the  point where  combustion
            is taking place.
     It can be seen that efficient combustion can  take place only under
certain conditions.
                                        6-6

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                     Elements of a Good Combustion System
     A combustion system feeds fuel, intimately mixes the fuel with air
and ignites and burns the fuel in a firebox at rates necessary to gen-
erate the amount of thermal energy required.,  Figure 1.1 presents a dia-
gram of a simplified combustion system.  The fuel may consist of liquids,
solids or gases.  The combustion systems discussed in this course use
coal and oil.  In some systems the fuel cannot be used in the same con-
dition it is when it arrives at the plant.  For example, some liquid fuels
have to be preheated before they can be used in combustion.  Solid fuels
may have to be crushed, ground, classified, washed or otherwise conditioned
before combustion.  The fuel must also be mixed with air in the proper
ratio in order to provide for complete combustion.  Depending on the type
of equipment, the air-fuel mix may occur prior to feeding the fuel into
the firebox, as the fuel is fed into the firebox or in the firebox itself.
Whichever process is used, sufficient turbulence must be permitted to allow
thorough mixing of fuel particles with combustion air.
     During this combustion process a definite amount of heat is given
out and this heat is used, in the case of a boiler, to heat the water which
surrounds the combustion chamber.  In all solid fuels there is a residue
which is unburnable, and it is therefore a useless part of the fuel known
as ash.  Ash remains as a waste product after combustion and is periodi-
cally or continuously removed from the firebox for disposal.  The gaseous
products of combustion and any light pieces of fly ash entrained in the
gases are carried out the stack.  The draft which draws the products of
combustion into the flue may be natural or mechanical.  In large opera-
tions fans are used.  To meet the objective of a clear stack, some form
of particulate removal equipment is used to remove the fly ash from the
flue gases.  In some cases, devices called scrubbers which also control
sulfur oxides (SOX) are used.
     The entire combustion system is typically monitored from a control
board.  The conditions which show up on the control panel vary from plant
to plant.  Control panel instrumentation is discussed later in this Workbook.
                                 6-7

-------An error occurred while trying to OCR this image.

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      Definitions of Some Components in the Combustion System and Their Functions

AIR HEATERS:  Air heaters reclaim some heat from  the flue gases  to heat
the air required for  fuel combustion.  -«,,
BOILERS:  Shells, drums or tubes which contact hot  gases on  one  side and
water on the other.   Heat is transferred from the hot gases  through the
boiler walls to the water on the other side.
ECONOMIZER:  In large units, the economizer absorbs  heat from the flue
gases.  The heat is in turn used to heat the feedwater before the water
enters the boiler.  Economizers allow for economic use of the heat gen-
erated from fuels and thus warrant their name.
FANS:  Move air or gas through the combustion system.  The fan usually
consists of a bladed  rotor or impeller and a housing.  The draft created
by the fan may be either forced or induced.  Forced  draft fans "push"
air and induced draft fans "pull" air.
FEEDWATER:  Water supplied to the heat exchanger  units for heating or
steam production.
FURNACE:  Firebox where combustion takes place.   Usually of refractory
cement, water tube or firebrick construction.  Furnaces are rated in terms
of million BTU/hour of capacity, or when combined with a boiler, in kilo-
grams of steam generated/hour, or boiler horsepower.  Since the furnace
and boiler are usually built as an integrated unit, no sharp distinction
is usually made.
REHEATERS AND SUPERHEATERS:  Heat steam to higher temperatures to effect
higher thermodynamic gain and improve turbine efficiency.  Units are essen-
tially banks of tubes exposed to the hot gas stream.
SOOT BLOWERS:   Jets of high pressure steam or air which are blown across
the surfaces of the furnace to remove soot deposits.  Soot blowing sched-
ules vary depending upon the fuel burned and the  size of the operation.
Frequencies of soot blowing varies from every 2 hours to every 24 hours.
                                6-9

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            CHAPTER 2. OPERATION OF EQUIPMENT TO BE INSPECTED

                                 Introduction
     This chapter describes systems for coal and oil burning and air pol-
lution control equipment associated with these systems.   You will read
about the spreader stoker system of firing coal, about the systems which
burn coal in pulverized form, and the Cyclone Furnace firing of coal.
You will also read about equipment which burns residual and distillate oils,
Air pollution control equipment covered in this chapter include electro-
static precipitators, inertial separators and wet scrubbers.

                              The Spreader Stoker
     Mechanical stokers were developed early  in the history of the steam
boiler as an improvement over hand firing.  Today several types of stokers
are available.  Among these several types, the spreader stoker is the most
generally used in  the capacity from 34,000 to 181,000 kilograms (75,000
to 400,000 pounds) of steam per hour.  It responds  rapidly to load swings
and can burn a wide  range of fuels with low maintenance, high daily  effi-
ciency and simplicity of operation.
     As the name implies, the spreader stoker projects coal into  the
furnace over the fire with a uniform spreading action.  Fine fuel parti-
cles are burned in suspension, and the larger pieces  fall and burn on a
grate.  Figure 2.1 illustrates this method of firing.
     The spreader  stoker combines suspension  and fuel bed firing.  The
coal is fed from the hopper onto a rotating flipper mechanism, which
throws the  fuel into the furnace.  The modern spreader stoker installa-
tion consists of a coal hopper, a feeder  distributor  unit that regulates
the flow of coal in  proportion to the load, and a distributor rotor  that
throws the  coal into the furnace and distributes it on the  grate.  The
grate  is specifically designed to meter the flow of air  into the  furnace.
Air ports cast in  the grate provide uniform air flow to  the entire active
                                 6-11

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grate, and forced draft fans provide both undergrate  (primary) air and
overfire (secondary) air.  The fuel introduced into the furnace ignites
rapidly, starting to release hydrocarbons the instant the fuel enters
the high temperature zone.  Because partial suspension burning results
in a great carry-over of particulate matter in the flue gas, dust col-
lectors are frequently, required.  Large coarse particles in these dust
collectors may be skimmed off and reinjected into the furnace for fur-
ther burning.  The overfire-air may be adapted to return fly carbon  to
the high temperature zone just above the fuel bed.  Figure 2.2 shows a
spreader stoker installation with a gravity fly-ash return.
              Coal Hopper
              Feeder
             Stoker
             Chain
    Figure 2.1  Traveling-grate Spreader Stoker with front ash discharge.
                                    6-12

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APES OF SPREADERS
     There are various types of spreader stokers.   The main difference
among them is in the grate design and operation.  The stoker grates may
b,; of the stationary, dumping, and continuous discharge type.
     With stationary grates, the ash is removed manually by a hoe or rake
through doors at the grate level.  This limits application to boilers of
 ;,000 to 13,690 kilograms (20,000 to 30,000 pounds) of steam per hour
capacity.
     Dumping-grate designs have grate sections for each feeder and the
undergrate air plenum chambers are correspondingly divided.  These models
are constructed in individual sections to allow .temporary shut-off of fuel
from the feeder mechanism, and of air from the undergrate air plenum cham-
bers on the particular section to be cleaned.  The remaining grate section
or sections can remain in operation.  The frequency of ash removal depends
on the burning rate and the percent of ash in the fuel.  The ash is depos-
 it .id into a basement ash pit or a shallow ash pit'if the grate is 3.65
meters  (12 feet) or less.
     The advantage of continuous ash discharge  is that there are no
 interruptions for ash removal.  Also, because of the thin fast burning
 fuel bed, burning rates are approximately 70% greater than with stationary
 and dumping grates.  Continuous discharge grates may be as large as
 48,77 square meters  (525 square feet) of grate, and corresponding to steam
 capacity, somewhat over 181,000 kilograms (400,000 pounds) of steam per
 hour.   Above this size the  spreader  stoker is not effective.
     There are  three  types  of  continuous cleaning grate stokers, namely,
 continuously reciprocating, intermittently vibrating, and  traveling grate.
 The  reciprocating grate  consists  of  alternate rows of continuously recip-
 rocating  grates imparting a forward  movement of the ash for automatic  dis-
 charge  at the  front  or feeder end of the stoker.  The vibrating grate
 stoker  has a vibration generator  on  the grate frame.  It  is periodically
 energized to  remove  the  accumulated  ash to the  ash pit.   The  traveling
 grate  stoker  consists of  an endless  chain of grates  slowly moving  through
 the  furnace  permitting the  ash to reach a depth of several centimeters
 (inches)  before being automatically discharged  into  the ash pit.   The
                                       6-14

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depth of ash accumulating on the grate can be controlled by speeding up
or slowing down the rate at which the grate travels.
     The grate types described above can be placed in two categories,
agitating and non-agitating.  The agitating types are the reciprocating
and vibrating.  The non-agitating are the stationary, intermittent dump-
ing, and the continuously traveling  grate.

FUELS  AND FUEL BED
     As we  stated earlier,  an outstanding characteristic of the spreader
 stoker is  its  ability to burn a wide range of fuels.  Except for anthra-
 cite  it  can handle everything from semianthracite to lignite.  Even
 though the spreader stoker can burn a wide variety of coals, fuel sizing
 is critical to good operation.  Ideally the coal should range in size
 from 1.90 centimeters  (3/4 inches) or less to about 5 centimeters (2 inches)
 If the coal is too coarse, the large lumps will not be completely oxidized
 on the grate.  As a result clinkers will tend to form in the  areas  contain-
 ing the large sizes.   If there are  too many  fines  in the coal,  the  fly  ash
 carry-over will  be excessive creating an increase  in emissions  from the
 stack.
       The  ideal  fuel  and ash  bed for the coal-fired spreader stoker  is
  evenly distributed and from 5 to 10 centimeters (  2 to 4 inches)  thick.
  There should  be an absence of clinkers in the bed so that there is a uni-
  form air flow through all portions of the grate.  The ash discharged into
  the ash pit should be about popcorn size.  Any ash as large as a man's
  fist is too large.

                            Pulverized Fuel Firing Units
        in this system,  coal is pulverized to  particles,  at  least 70  percent
   of which pass  through a 200-mesh sieve  and  is  fired in burners similar to
   those used for liquid fuel. The pulverized coal  method  permits  continuous
   use  of  raw coal directly  from bunkers  where it is stored in the  condition
   received  at  the plant. Any size  coal  may be used.  Raw coal is  dried and
   pulverized simultaneously in a mill and is fed to the burners as required
                                     6-15

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by the furnace load.  A small portion of the air required for combustion
(15% to 20%) is used to transport coal to the burner.  This is known as
primary air.  A predetermined air-coal ratio is maintained for any given
load.  Secondary air, the remainder of the combustion air (80% to 85%)
is introduced at the burner.  (See Figure 2.3)  The pulverized coal ejected
into the furnace then burns in suspension.
         PULVERIZED COAL
         AND PRIMARY AIR
     PRIMARY AIR
        VANES
   FUEL OIL
                                                                 o
         Figure 2.3  Circular burners for firing pulverized coal

      There are two basic systems of pulverized fuel preparation and firing,
 the bin system and the direct-firing system.  The direct-firing system  is
 the one being installed almost exclusively today.
      The basic equipment components of  a direct-firing pulverized  coal
 system are the pulverizer  and the burner.  The pulverizer  grinds  the  coal
 to the fineness  required.   The burner accomplishes  the mixing of  pulver-
 ized coal and primary air  with secondary air  in  the right  proportion  and
 delivers  the mixture  to  the furnace  for suspension  burning.   Other neces-
 sary components  are  the  raw-coal feeder which controls  the rate of coal fed
 to each pulverizer;  the  primary  air  fan which supplies  air for drying and
 conveying the  coal-air mixture  to the burner; and the coal and air
                                        6-16

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conveying lines.  Figure  2.4 illustrates these components and  their rela-
tionship.  Completeness of combustion is a function of  the uniform distri-
bution of fuel and  air, turbulence imparted to the fuel and  air mixture,
type of firing used,  and  the fineness of pulverization.
                          Cold (Tempering) Air _
                          from forced Draft Fan
 Hot Air from
Boiler Air Heater
                                                   _ Boiler
                                                  ^" Front Wall
                                Pulverized Fuel
                                and Air Piping A
               Pulverizer
            Figure  2.4   Direct-firing system for pulverized  coal

 PRIMARY AIR SYSTEM
      The rate  of fuel  feed in the direct-firing method  is automatically
 controlled by  the  boiler load demand.  Air flow to  the  pulverizer is pro-
 portioned to fuel  rate to provide the air for drying  the coal.   In order
 to pulverize and circulate fuel pneumatically within  a  pulverizer, some
 moisture must  be removed leaving the coal dry and dusty.  Preheat air to
 the pulverizer is  usually required for drying.  The use of  preheat air
 also permits control of the temperature of the fuel-air mixture to the
 burners for  the most stable ignition.  In addition  to acting as a drying
 agent,  the air flow provides the velocity required  for transporting the
 fuel to the burners.  The velocity in the conveyor  lines  must be suffi-
 ciently high  to prevent settling and drifting of  coal.  At the burners
                                  6-17

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the air-coal mixture must be uniform and the velocity suitable  so as to
prevent flashing back of the flame,  and to allow stable ignition at all
times.  To meet these conditions velocity must be varied with changes in
ratio of air to coal in the mixture.
BURNERS
     Pulverized fuel burners are installed in three different planes, de-
pending on the type of boiler, the available combustion space and the kind
of burner.  The direction of firing may be classified as either horizontal,
vertical, or tangential.  One manufacturer uses an adjustable burner which
is tilted upward or downward to control the furnace outlet temperatures.
In many instances, burners are of the combination type, and are designed to
burn either pulverized fuel, oil, or gas, or all three.  The most fre-
quently used burners are the circular and cell types..
FURNACE TYPES
     Pulverized-coal fired units are usually one of two basic types, wet-
bottom or dry-bottom.  The temperature in a wet-bottom furnace  is main-
tained above the ash fusion  temperature, thus the  slag is melted so  that
it  can be removed from the bottom as a liquid.  The liquid  is quenched and
accumulates in  storage tanks under  the furnace.  The dry-bottom furnace
maintains a temperature below  this  point so that the ash will not fuse and
is  removed as dry ash.  Whether a furnace is dry-bottom or  wet-bottom af-
fects emissions.  About 80%  of the  ash otiginally  in the c'oal leaves a
dry-bottom furnace  entrained in the flue :gases.  In wet-bottom  or -slag-tap
furnaces, as much as  50%  of  the ash may be retained in the  furnace.


                               Cyclone Furnace

      In  pulverized  coal fired  units discussed  above, the furnace has a
double  function.   It  must maintain  the high  temperatures necessary  for
complete combustion and at the same time  cool  gases resulting  from  com-
bustion  so  that when they enter  the heat  exchangers they are below  the
                                         6-18

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temperatures at which  slagging occurs.  Excessive slag on surfaces re-
duces the transfer  of  heat to produce steam.  The furnace consequently
has to be relatively large to allow these conflicting functions  to occur.
The Cyclone Furnace was  developed to obtain more efficient  combustion by
separating these  functions.   The idea was to provide a small  combustion
chamber where high  turbulence and temperature may be maintained  and to
use the main boiler furnace primarily to cool the combustion  gases.
     The Cyclone  Furnace (Figure 2.5) is a water-cooled  horizontal cylin-
der in which fuel is  fired and heat is released at  an extremely  high rate
for the volume of the furnace.  Coal is crushed in  a simple crusher so
that approximately 90 percent passes through a 4-mesh screen. The fuel
is introduced  at the burner end of  the Cyclone, and air for combustion is
admitted tangentially.  Combustion  occurs at heat-release  rates  of
14,000 to  25,200  BTU per cubic meter  (500,000 to 900,000 BTU  per cubic
foot) per  hour at gas temperatures  sufficiently high to melt  a high per-
centage of the ash into a liquid slag.  The slag is discharged from the
bottom of  the  furnace through a slag  tap opening.
               Emergency Standby
               Oil Burner
               Secondary Air
              Crushed Coal Inlet
               Tertiary Air
               Primary Air
               Radial Burner
               Oil Burner
               Replaceable
               Wear Liners
  urners
                                     Re-entrant
                                     Throat
Slag Top Opening
                   Figure  2.5   Cyclone Furnace operation
                                       6-19

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COAL PREPARATION
     The Cyclone Furnace is capable of  successfully burning  a wide  range
of coals varying in rank from low volatile bituminous  to  lignite.   The
Cyclone is able to use any size of fuel available.  Fuel  oils and gases
are also suitable for firing.
     There are  two types of coal preparation and feeding, (See  Figure 2.6)
the bin or storage system, and  the direct-firing system.   With  the  bin
system coal  is  crushed  in  a central  preparation plant  to  a size suitable
for  firing and  delivered  to the bunker.  Because the  crushed coal is rela-
tively large in particle  size,  the hazards associated with pulverized-
coal systems do not  exist.
      The direct-firing system has a separate crusher located between the
 feeder and the burner of each Cyclone Furnace.  The crusher is swept by
 hot air which helps to dry the coal.  This improves crusher performance
 and ignition with high moisture coals.
      The pre-drying bypass system is a  variation of the  direct-firing
 system.  It incorporates a mechanical  dust  collector between the crusher
 and the Cyclone Furnace.  The dust collector is vented to the  boiler fur-
 nace.  This system is used when firing extremely high moisture coals be-
 cause the moisture is removed  from  the coal during crushing and then vented
 to  the boiler  furnace instead  of the  Cyclone Furnace.
       The two general firing arrangements used for  the Cyclone  Furnace are
 one-wall firing and  opposed  firing.   These are shown  in  Figure 2.7.
                           One-Wall Firing    Opposed Firing
         Figure 2.7   Firing arrangements used with Cyclone Furnaces"
                                  6-21

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EXCESS AIR
     The excess air required for satisfactory combustion is less than
10 percent.  However, when there are several Cyclones and where auto-
matic controls are used, excess air is usually maintained between 10%
and 15% to assure no individual Cyclone is operating with insufficient
air.

ASH REMOVAL
     By the Cyclone Furnace method of combustion the fuel is burned
quickly in suspension.  Most of the ash is retained as a liquid slag
and tapped into the slag tank under the boiler furnace.  Up to 70% to
80% of the total ash is retained and only 20% to 30% leaves the furnace
as dry ash in the flue gas.  Air pollution control equipment is placed
ahead of the stack to prevent the ejection of large quantities of this
ash to the atmosphere.

                             Oil Burning Furnaces

     The chief advantages of fuel-oil over coal in the generation of
steam are that it can be easily moved from the storage tank to the place
of use, the burning equipment is simple and easy to operate, and it has
very little ash content compared to coal.  The important properties of
oil are:  (1) specific gravity, (2) heating value, (3) viscosity, (4) flash
point, (5) fire point, (6) sulfur content, (7) ash content, and (8) pour
point.
     Specific gravity is the ratio of the weight of a volume of oil to
the weight of the same volume of water at 60F.  Heating value is expres-
sed in BTU per liter (gallon) or per kilogram (pound) at 60F.  Viscosity
is defined as the measure of resistance to flow.  Flash point is the tem-
perature at which sufficient vapor is given off to form a momentary flash
when flame is brought near the oil surface.  The sulfur and ash are, of
course, undesirable elements in fuel oil.  Pour point represents the
lowest temperature at which oil flows under standard conditions.
                                        6-22

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     The National Bureau of Standards has established specifications for
five grades of fuel oil.  The descriptions of these grades are given in
Table 2,1.  The grades are numbered from light to heavy.  Distillates are
lighter oils and residuals are heavier oils.  Generally, grade., of oil
heavier than No. 2 must be heated to reduce viscosity.
              Table 2.1. National Bureau of Standards Grades for Fuel Oil
         NUMBER
                               DESCRIPTION OF FUEL OIL
          1.
          2.
          3.
          5.
          6.
Distillate oil for use in burners requiring
volatile fuel.
Distillate oil for use in burners requiring
a moderately volatile fuel.
Distillate oil for use in burners requiring
a low-viscosity fuel.
Residual oil for use in burners requiring a
medium viscosity fuel.
Residual oil fqr use in burners equipped
with pre-heaters, permitting a high
viscosity fuel.
      Fuel-oils of No. 1 and No. 2 grades, the distillate fuels, are usually
 used to heat homes and domestic hot water.  No. 2 fuel-oil is used in small
 apartment houses and in industrial processes.  The firing rate is usually
 not more than 75 to 95 liters  (20 to 25 gallons) per hour.
      Distillate oils of No. 2  and 3 grades are fired in large apartments,
 small industrial plants, and other commercial establishments up to 189
 liters  (50 gallons) per hour.  Fuel-oils No. 5, light and heavy, are used
 in installations burning more  than 189 to 378 liters (50 to 100 gallons)
 per hour respectively.  Fuel-oil No. 5 possesses greater heating value.
 Fuel-oil grade No. 6 is used in power generating stations, marine vessels,
 and other large installations, and is fired  at rates greater  than 189 liters
 (50 gallons) per hour.  The sulfur content of No.  1 distillate will vary
 from  .04 -.124%, and of No. 2  distillate  from  .104 -.307%.  The sulfur
 content in grade 6, residual oils, will range from 0.9  - 3.2% by weight.
                                6-23

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     '.Jhen oil viscosity is not satisfactory,  preheaters must  be  used,
particularly with grades 5 and 6 oil.   Oil preheaters are used to
improve viscosity, and may be mounted  directly on the burner, at the
supply tank or any place in between.  Preheaters operate with either
electricity or steam.  Typical oil preheat temperatures necessary to
obtain a suitable viscosity for atomization are usually between 150°
and 200°F.
     The principal air contaminants affected by burner design and
 operation are oxidizable materials:  carbon, carbon monoxide, alde-
 hydes,  organic acids, unburned hydrocarbons, soot, and other partic-
 ulates.  The principal causes of  smoke  and  incomplete combustion are:
         1.  Burner and fuel not compatible.
         2.  Burner not properly adjusted or operated.
         3.  Burner  improperly maintained.
 OIL BURNERS
      The burner is the principle equipment component for the firing of
 oil.  Burners are normally located in the vertical walls of the furnace,
 but may be  installed in the horizontal wall.  The types of burners most
 frequently  used are circular and cell burners similar to those used in
 pulverized  coal burning systems.   (See Figures  2.8 and 2.9.)
       In order to burn  fuel-oil at  high rates  it is necessary for  the  oil
  to be "atomized",  or dispersed into  the  furnace as a fine  mist.   Atomi-
  zation allows an intimate mixture  of air and  fuel.   It  exposes  a  large
  amount of oil particle surface for contact with the  air to assure prompt
  ignition and rapid combustion.
       Burners are classified according to the method used for securing
  atomization:  (1) air-atomizing burners, (2)  steam-atomizing burners,
  and  (3) mechanical-atomizing burners.  The cost of supplying compressed
  air has limited the use  of air-atomizing burners in industrial installs-
  tions.
                                        6-24

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     Steam atomizers,  as a class,  possess the  ability to  burn almost  any
fuel oil, of any viscosity at almost any temperature.  These burners  may
be sub-divided into two groups:   (1) internal-mixing or premixing oil and
steam inside the body or tip of  the burner before being sprayed into  the
furnace, and (2) external-mixing in which oil  emerging from the burner is
caught by a jet of steam or air.
     In the mechanical atomizer  the pressure of the fuel  itself is used
as the means for atomization.  Good atomization results when oil, under
high pressure is discharged through a small orifice, often aided by a
slotted disk.  The disk gives the oil a whirling motion before it passes
on through the hole in the nozzle where atomization occurs.  Finally,
because oil fuels are low in ash, scheduled cleanouts may be a couple
of times a year.

                        Air Pollution Control Equipment

     To meet the objective  of a clear stack,  some form of  particulate-
removal  equipment  is  required to  remove  fly ash  from flue  gases  from
units where  fuel is burned  in suspension.
     Air pollution control  equipment may be classified into  two  groups,
equipment controlling particulate matter,  and equipment  controlling
gaseous  emissions.  Because oil fuels are low in ash and sulfur,  plants
using  oil typically do not  have associated air pollution control equip-
ment.   In this Workbook devices for the  control  of  particulate matter
on the equipment just presented have been grouped into three classes:
inertial separators,  wet  collection devices,  and electrical precipi-
 tators.   Figure 2.10  shows  illustrations of each type.   Fabric filters
 (baghouses)  are not  discussed because  they are not currently being used
 to control emissions  from fossil fuel  fired combustion sources.

 INERTIAL SEPARATORS
      Inertial separators are the most  widely  used devices  for collecting
medium and coarse-sized particulates,  above 10 to 20 microns.  Collection
 efficiency is usually not high, although suitable for medium-sized par-
 ticulates.  Ordinary inertial separators are generally unsuitable for
                                      6-26

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Electrostatic Precipitator
Inertial Separator
                                  Wet Scrubber
      Figure 2.10  Air pollution control equipment
                        6-27

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for fjne dusts ranging from 5 to  10  microns.   Below 10 microns  the
efficiency drops below 90 percent.
     Inertial separators operate  by  the principle of imparting  centrifugal
force to the particle to be removed  from the flue gas.   This force  is pro-
duced by directing the gases in a circular path.  The spiral of the circu-
lar motion of the gases force the particulates toward the outlet where
they drop into a dust-tight bin and  are removed by mechanical conveyors,
pneumatic or steam ejection systems.  The single cyclone separator is an
inertial separator without moving parts.  It separates particulate matter
from a carrier gas by spiraling the entering gas downward at the outside
and upward at the inside of the cyclone outlet.  The particulates, because
of their inertia, tend  to move toward  the outside wall.  A multiple-cyclone
separator consists of  small-diameter cyclones operating in parallel, having
a  common gas  inlet and  outlet.  Another type  of  inertial separator supplies
the  centrifugal  force  by a  rotating vane.
     A  common cause  of poor cyclone performance is leakage  of  air  into  the
dust outlet.   A small  air  leak at this point  can result  in  a substantial
decrease  in collection efficiency.

WET COLLECTION DEVICES
      Wet collection devices use  a variety of  methods to wet the contaminant
 particles in order to remove them from the gas stream.   A good wet scrubber
 is one that can effect the most  intimate contact between the gas stream and
 the liquid for the purpose of transferring the suspended particle from the
 gas to the liquid.
      Because the wet scrubber employs a liquid stream to collect particu-
 late matter, it can usually perform additional process functions besides
 dust collecting.  Simultaneous removal of dust and gaseous pollutants  such
 as  sulfur oxides by use of a  suitable scrubbing liquid can be accomplished
 with a wet  scrubber.
      There are a  variety  of different types  of wet collection devices.
  The simplest type of  scrubber is a chamber in which spray  nozzels are
  placed.   Gases are sprayed with a  liquid as  they pass  through the
                                        6-28

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chambers.  In some types of scrubbers the water spray is generated by a
rotating element such as a drum or disk.  The collection efficiency of a
scrubber varies according to the type and size of particulate nrtter.

ELECTRICAL PRECIPITATORS
     The electrical precipitators work on the principle that substances
with the opposite electric charge attract each other.  The particles
entrained in the flue gases are given a negative charge.  The negatively
charged  particles in the presence of positively charged collecting plates
are attracted  to the plates.  The collected dust accumulates on the plates
and is discharged by rappers.  The rapping of  the plates discharges  the
collected dust into storage hoppers.
     The use of electrical precipitators has grown because of the many
inherent advantages in  the method.   High efficiency  can be attained
because  very small particles  can be  collected.  There is no  theoretical
lower  limit to the size of the  particle that can be  collected.  Precipi-
tators are  easy to maintain over  long periods  of  time because  they have
no moving parts.  They  can be used  in extremely high temperatures and will
 collect a variety of  types of particulate matter.
                                 6-29

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                     SELF-EVALUATION QUESTIONNAIRE I


     Below are statements which describe the basic parameters and  the
proper operating practices of the fuel-burning systems covered  in  Chapter
Two.  Read each statement and check the system or systems  it best  describes.

Some statements are descriptive of more than one system.   First, try to

answer each without referring back to the text.  Then, for those you are

uncertain about or cannot answer, you may refer back to  the text.
     Basic Design Parameters and
     Proper Operating Practices
Cyclone
Furnace
Spreader
 Stoker
Pulverized
Zoal Burner
 Oil
Burner
1.  An important  advantage  is
    its ability to burn  fuels
    with a wide range  of burn-
    ing characteristics.

2.  Permits  continuous use  of
    raw coal directly  from
    bunkers  where coal is stored
    in condition  received at the
    plant.

 3.  Permits  suspension burning
    of fuel  in the furnace.

 4.  Able  to  use coal of  any size
    available.

 5.  Requires the fuel to be
    atomized.

 6.   Can  burn either coal or oil.

 7.   Uses circular burners and
     cell burners

 8.  All  ash particles are formed
     in suspension.

 9.   Three systems of  fuel
     preparation  and feed are
     bin, direct-firing,  and
     direct-firing pre-drying
     bypass.
                                         6-30

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10.


11.



12.





13.


14.


15.


16.


17.
18.


19.





20.



Basic Design Parameters and
Proper Operating Practices
Requires coal in a fine
powder form (70% will pass
a 200-mesh screen) .
The proper size coal ranges
from 1.90 centimeters (3/4
inches) and under to 5 centi-
meters (2 inches) .
Moves coal from the supply
hopper over an adjustable
spill plate to fall onto a
rotor equipped with curved
blades for distributing the
coal over the furnace area.
Requires hot primary air to
dry the coal and convey it
to the furnace.
Two basic types of furnaces
are wet or slag-bottom and
dry-bottom.
Requires that certain grades
of fuel be heated before
they can be used.
Burners may be arranged
vertically, horizontally,
and tangent ially.
Requires few ash cleanouts.
About 70-80% of total ash
is retained and only 20-30%
leaves as dry ash in flue.
Molten ash drains toward
furnace bottom and is re-
moved through tap holes,
quenched and is accumulated
in storage tanks under the
furnace .
Ash discharged in pits is
fairly large; ranging from
popcorn size to the size of
a man's fist.
Cyclone
Furnace

*





































Spreader
Stoker


































•V*




Pulverized
Coal Burner







































Oil
Burner







































6-31

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     Basic Design Parameters and
     uood Operating Practices
Cyclone
Furnav.'
Spreader
 Stoker
 Pulvt ri/c
-------
     Answer the following questionr.


29.  The three types of grates which may be used on a spreader stoker

     are		


     Identify the type of grate described by each statement.


30.  a.  Requires manual ash removal and is limited
         to boilers of 9,000 to 13,690 kg (20,000 to
         30,000 Ibs.) of steam per hour capacity.    	
31.  b.  Has grate sections for each feeder and
         the undergrate air plenum chambers are
         correspondingly divided permitting tem-
         porary discontinuance of fuel air supply
         to a grate  section for ash removal with-
         out affecting other  sections of  the
         stoker.


 32.   c.  No interruptions  for removing ashes.
         Its maximum size  is  usually up  to
         about  48.77 square meters  (525  square
         feet)  of grate  and produces over
         181,000  kg  (400,000  Ibs.)  of steam
         per hour.
                                   6-33

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     Eelow are statements which describe  the  basic  theory,  collection

and associated disposal system of  the  air pollution control equipment

covered in Chapter Two.  Read each statement  and check the equipment

it describes.  There should be only one  check mark for each statement.

First try to answer without referring  back.   Then if necessary, refer

back.
        Basic Theory and Associated
        Disposal Systems
Electrostatic
Precipitators
 Inertial
Separators
  Wet
Scrubbers
    33.  Collects particles by
         contact with  a liquid
         droplet.

    34.  Executes centrifugal
         force  on the  particles
         to be  separated.

    35.  Most efficient for large
         particles  (above 10 to
         20 microns).

    36.  No  theoretical lower
         limit  to  the  size of
         the  particle  that can
         be  collected.

    37.  Collection efficiency
         varies according to size
         and type  of particulate
         matter.

     38.   Charged particles are
          attracted to collecting
          plates.
                                        6-34

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 CHAPTER 3. INSPECTION POINTS AND OBSERVATIONS WHICH SHOULD BE MADE

                                Introduction
     The purpose of an inspection  by you,  the Field  Enforcement Officer
(FEO),  is to determine whether a source is operating in compliance with
acceptable emission regulations.  The initial decision regarding compli-
ance is usually made by an experienced engineer.   He makes his decision
by considering process design and operating characteristics, and by con-
ducting emission stack tests under various furnace operating conditions
considered representative of the range of normal operation.  This review
by the engineer is crucial because it is the foundation for future enforce-
ment actions.  Thus, once these initial evaluations have been made, your
major responsibility as the FEO is to check that the source is still opera-
ting either as specified in the permit application, or under the same con-
ditions as when the source satisfactorily passed the emission source tests.
The  purpose of a source inspection is to make the following determinations:
        Determine  whether the source meets equivalent  opacity
        regulations.
        Determine  whether the source is operating in accordance
        with  permit conditions.
         Determine  whether operating  and maintenance procedures
         conform with  good practice.
         Determine  whether  good  operating  and maintenance pro-
         cedures are used  regularly based  on  a spot  check of
         operations since  the last inspection.
         Determine  whether the air pollution control equipment
         is operating properly.
      The above determinations about a source are made on the basis of an
 analyses of plant operating records and on the basis of visual observations
 made during inspection.  This  chapter covers the visual inspection points
 and observations  which should be made during the inspection tour.  It tells
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you what to look for and provides guidelines for deciding whether or not
the conditions you observe on the spot are satisfactory or unsatisfactory.
The following inspection points are covered:
        Observe plume before entering the plant.
        Inspect fuel preparation system.
        Inspect furnace interior.
        Inspect control panel instrumentation.
        Inspect fans and ductwork.
        Inspect ash disposal system.
        Inspect air pollution control systems.


                      Observe Plume Before Entering the Plant

     The first task in the inspection process is to determine the plume's
equivalent opacity.  Opacity standards will vary according to local regu-
lations, but generally satisfactory conditions are a clear stack or emis-
sions equivalent to less than 20 percent.
     In order to "read" the plume for smoke density, you, of course, must
be a qualified smoke reader.  Because the judgment about opacity is being
made by a human, it is subject to a certain amount of error in measurement.
A standard error of measurement  for qualified smoke readers is 15 percent.
Thus, if a reading of 30 percent is reported, the actual opacity level may
range from 15 percent to 45 percent.
     Also, note the plume color.  When  the opacity is high, the. color may
be a clue to factors to investigate.  Table 3.1 presents factors to investi-
gate when opacity is unsatisfactory.

                         Inspect Fuel Preparation System
COAL FIRED BOILERS
     Check the outside coal pile for evidence of windblown dust.  Satisfac-
tory conditions exist if no windblown emissions are visible when a  small
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amount of coal is filtered through the fingers and falls to the ground.
Check with plant representative to determine if additives are used to
suppress windblown dust.
Table 3.1 Plume Characteristics and Operating Parameters
PLUME COLOR
White
Gray
Black
Reddish
Brown
Bluish
White
POSSIBLE OPERATING FACTORS TO INVESTIGATE
Excessive combustion air; loss of burner
flame in oil fired furnace.
Inadequate air supply or distribution.
Lack of air; clogged or dirty burners,
or insufficient atomizing pressure;
improper oil preheat; improper size or
type of coal.
Excessive furnace temperature, burner
configuration, or excess air.
High sulfur content in fuel: Fuel
should be sampled.
      Check the delivery procedure to determine if excessive fines are
 stirred up as coal is transferred onto the conveyor system.  Conditions
 are unsatisfactory if the dust blows beyond the plant boundaries into the
 surrounding neighborhood.  Windblown emissions which do not go beyond the
 plant boundaries are not considered a violation.
      Check the conveyor system as the source of windblown dust emissions.
 Satisfactory conditions exist if the system is covered.  Unsatisfactory
 conditions exist when the conveyor is uncovered or when it vibrates to
 the point that it creates fugitive dust emissions.
      For spreader stoker operations check the coal size.  A satisfactory
 range  is from 1.9 centimeters to 5 centimeters  (3/4 inches to 2  inches).

 OIL FIRED BURNERS
      Check the oil preheat  and atomization pressure gauge  for each nozzle,
 These  readings should  later be compared with  those on  the  original permit,
 A sample of  the  oil  may be  taken to analyze for sulfur content.
                               6-37

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                            Inspect Furnace Interior
     When inspecting the furnace interior,  use specially design filters
for eye protection.   In addition, never open furnace doors, manipulate
controls, change valve settings, or in any way interfere with boiler opera-
tion.  During the inspection process, plant personnel should open the door
for inspection purposes.

SPREADER STOKER GRATE CONDITIONS
     Check the evenness of the coal distribution on the bed.  The coal
should be evenly distributed across the width of the grate.  The fuel bed
thickness should be about 5 centimeters to 10 centimeters  (2 inches  to
4  inches).
     Check the  grate  to determine  if  it is unbroken and  in good condition.
The entire grate may  not be observed  while the  furnace  is  in operation.
If your  inspection  coincides with  the time that a  section  is down,  then
of course you can check the grate.   However,  during  operation  a small
portion of  the grate  may be visible and you  can make some  judgments about
 the entire  grate based on  the  visible portion.   If the  portion you see is
 about 30 centimeters  square (2 feet square)  in size,  you may assume the
 entire grate is in  the same concition as  the visible section.

 SPREADER STOKER BOTTOM ASH
      On spreader stokers you should also check the bottom ash in the ash
 pits.  The cooled ash  should be about popcorn size, with no pieces larger
 than a man's hand.   It should be white to brown in color with no blackness
 or clinkers.

 FLAME CHARACTERISTICS
      The most  important indication of good  combustion  is  a clear,  steady
 flame.   The  flame  should look clean.  There should be  no  black tips to
 the  flame and  no evidence of  smoke or haze.  Any  streaks  or unevenness  of
 the flame  indicates  unsatisfactory conditions.
       Color  of the  flame is a  secondary indication of the  adequacy of com-
  bustion.  Good flame color varies with type of equipment  arid type of fuel
                                        6-38

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used.  For grate systems, such as the spreader stoker, you should note
whether the flame is clear and steady.  The flame should be yellowish-
orange with no dark smoke.  Dark smoke means soot and particulate emissions
are high.  Do not mistake the coals falling onto the live fire bed for
unsatisfactory conditons.
     For burner systems, such as pulverized coal and oil, a mixture of
yellow and blue flames attached to ports indicates correct proportion of
air  and  fuel.  Some pulsing of the flame is normal, but a totally blue
flame lifting off the ports indicates  too much air.  Dazzling or bright
white flame  indicates that the flame  temperatures may be  sufficiently high
to create  excessive NOX  emissions.
     The presence of black spots  indicates poor  atomization.  Clogged or
dirty burners may cause  improper  atomization.  You  should check the  fre-
quency  of cleaning  burners to be sure it  is  the  same  as on the  original
permit.   In addition,  the flame  should not  impinge  on walls and arches  of
 the  firebox.

 FIREBOX WALLS
      From a visual  inspection of the furnace interior through observation
 "peep" holes,  firing doors or access doors,  recognize that a smooth clean
 wall indicates a satisfactory condition.   Heavy accumulations of ash on
 the walls is undesirable because it may build up to the extent that it
 interferes with heat transfer.  Ash may also build up to the extent that
 it  interferes with turbulence.

                        Inspect Control Panel Instrumentation
      There  is usually a control  panel where instruments provide data on
 such elements as the stack opacity,  the air-flow/steam-flow relationship,
 C02 concentration  and 02 levels.  Instrumentation varies  from  plant to
 plant,  but  opacity and  steam-flow/air-flow meters are  included in most
 boiler  installations.

 THE OPACITY CHART
       The chart  on  which a record of  the  density of  emissions  from the  stack
  is  recorded may be called a  smoke chart,  a  density chart,  or  an opacity
                                 6-39

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chart.  A single opacity chart is capable of displaying the opacity per-
centages for a 24-hour period.  Figure 3.1 shows an opacity chart.  The
24 hours, with 15-minute intervals, are marked off around the outer rim of
the circular chart.  The numbers radiating from the center indicate percent-
ages.  A pen continuously records the percent of opacity.  By studying the
chart you can determine the percentage of opacity for any point in a dav.
For example, at 2:00 a.m.  and at 5:15 A.M.  the opacity  percentage  in   »
Figure 3.1 rose above 20 percent opacity.   But,  from 6:00 a.m.  until 10:00
a.m.  the stack was satisfactory.  What was  the stack reading at 2:00 p.m.?
     Not all opacity charts are round.  Figure 3.2 shows a meter which
records opacity on a horizontal chart.  It too, is marked off in 15-minute
intervals.  The heavier lines indicate 30-minute intervals with the lighter
line showing the 15-minute point in between.  Only about an hour is visible
through the window.  In order to see the entire 24-hour period, the chart
must be removed from the meter.
     An opacity chart shows unsatisfactory conditions if there are any
deviations above 20 percent for more than 3 minutes.  Deviations above
20 percent for less than 3 minutes in any one hour are usually allowable.
For example, soot blowing schedules, which are allowable, may account for
deviations.  When soot blowers are in operation particulate matter con-
centrations in exit gases increase markedly.  The frequency of soot blowing
schedules varies depending upon,the fuel burned and the size of the opera-
tion.  Soot blowing once every shift for a duration of 30 minutes, if per-
formed sequentially is usually allowed.  Large plants may have continuous
systems.  By increasing the frequency of schedules or by lengthening the
total operation, a plant can be technically in compliance.

STEAM-FLOW/AIR-FLOW RECORDERS
     The amount of total combustion air used in a boiler can be established
by metering the flow of air through the unit.  A given total air-flow,
measured by a meter, has a straight line relationship to the steam output.
The steam-flow/air-flow meter is one of the most widely used flow meters.
It measures not only steam-flow from the boiler, but also the relative rate
of combustion air-flow to the furnace.  Some boilers have maximum design
rates, and you should compare the steam-flow rate for the individual boilers
                                      6-40

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wicl  the maximum design value listed on the permit.  Rates above the max-
imum design values will lead to excessive emission.  Low loads may cause
smoking if the correct amount of combustion air is not maintained.
     The steam-flow and air-flow pens are adjusted on the basis of actual
                                            •
tests, and are set so that calibrated, they both coincide.  That is, they
follow the same path around the dial, one on top of the other,  (See
Figure 3.3) or are modified to follow parallel paths.  Figure 3.4 shows a
steam-flow/air-flow chart calibrated to record measurement about 1 inch
apart.  The air-flow and steam-flow are usually recorded in different
color inks.
     Ask the operator when the steam-flow/air-flow meter was last calibra-
ted.  Also, inquire if the pens read "true" values or if the pen trace has
been modified.  Modified instrumentation may include a scale factor.  If ]
                                                                         t1
more than  a year has passed since calibration, or if there is doubt about
the accuracy of the reading, request that it be calibrated.
     For steam-flow/air-flow recorders, compare chart values with the
following  guides:
        Air-flow  should read between 10 and 25 percent higheJ^
        than steam-flow for coal fired operations.
        Air-flow  and  steam-flow should read approximately  the
        same value  for oil operations.
     Air-flow  above steam-flow shows  too much  air  or  too  little fuel.   Air-
 flow below steam-flow shows  too little air  or  too  much  fuel.   In other  words,
 the air to fuel  ratio is  incorrect  and combustion  is  less  efficient.
     However,  because calibrations  differ  from plant  to plant,  you  can  make
 some  determination  of conditions by looking at the relationship of  the  two
 pens.   From a  visual inspection, you can tell  whether conditions are satis-
 factory or not.   If the  steam-flow and air-flow pens trace essentially  the
 same  paths, conditions are ideal.   That  is, if the air-flow trace goes  up,
 the steam-flow trace should follow it and vice versa.   However, ideal situ-
 ations rarely exist and  some deviation is allowable.   From an air pollution
 standpoint, it is better to err in the direction of too much air.  While
 this  reduces combustion efficiency, it does not critically affect air pol-
 lution.  However, when steam-flow is above air-flow, this does indicate an
                                        6-42

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Figure 3.3 Steam flow/air flow pens calibrated
          to coincide
Figure 3.4  Steam flow/air flow pens modified
           to show parallel traces
                      6-43

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air pollution problem.   Instantaneous peaking of steam-flow above air-flow
is allowable.  Figure 3.3 shows instantaneous spikes of steam-flow at about
2:15 p.m. and 2:30 p.m.  Of course, any extended period of steam-flow above
air-flow is undesirable.  An extended period is defined as three minutes.
If you study Figure 3.3 carefully you will note that steam-flow rises above
air-flow on several occasions.  The traces may coincide or parallel each
other.  Do the pen traces in Figure 3.3 show satisfactory or unsatisfactory
conditions?  How about Figure 3.4?

C02 MEASUREMENTS
     C02 measurements may be on the control panel board or may be taken
manually.  Figure 3.5  shows an automatic (X>2 recorder.  Rate C02 measure-
ments according to the guides in Table 3.2.  These values are onlyvguides
and individual boilers may depart  somewhat from these  guides depending on
the original design.
Table 3.2 Guides for CC»2 Concentration
in Flue Gas Leaving Furnace
Spreader stoker:
Pulverized coal
burner :
Cyclone furnaces:
Residual oil:
Distillate oil:
10 to 12 percent
12 to 14 percent
12 to 14 percent
12 to 14 percent
10 to 12 percent
 OXYGEN MEASUREMENTS
      02 measurements are sometimes on the control panel.   Rate 02 measure-
 ments according to the guides in Table 3.3.  Again, these values are only
 guides and individual boilers may depart somewhat from these guides.
Table 3.3 Guides for 62 Levels in Combustion
Spreader stoker:
Pulverized coal
burner:
Cyclone furnace:
Residual oil:
Distillate oil:
3 to 9 percent
3 to 6 percent
3 to 6 percent
3 to 6 percent
3 to 6 percent
                                         6-44

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                           Inspect Fans and Duct Work
     Inspect breechings and air ducts through air heaters, economizers and
super heaters for cracks and holes.  Check the fan to be sure it is opera-
ting properly; that no obstructions are impeding the air flow, that all
blades are intact, that vibration is not excessive and that there are no
holes or cracks in connections to duct work.
                          Inspect Ash Disposal Systems
     Check both furnace bottom ash and control equipment ash hoppers for
correct ash handling procedures.  Ash from hoppers should not drop signifi-
cant distances into trucks used for transfer of ash.  Visible dust emis-
sions should not be present during loading of ash into trucks.  Ash should
be moistened before transport to minimize  fugitive dust emissions.  Trucks
which convey ash to disposal area should be covered or sufficiently wetted
to prevent windblown emissions beyond the  plant boundary,


                       Inspect Air Pollution Control Systems
INERTIAL  SEPARATORS
     Inertial  separators  and electrostatic precipitators are  the  devices
most commonly  used for particulate  emission control.  The most  important
guide-  to  their performance  is the condition of  the plume.   If the plume
opacity is greater than it  was under  similar boiler  load conditions at an
earlier time,  either the  collection efficiency  of the controls  has decreased
or  the fuel  quality has decreased.
     Visual  checks should include checking the  pressure  drop  gauge and check-
ing the exterior of  the air pollution control  device for cracks or air
leaks.  Be  sure  to check  around doors or other  openings  used  for cleaning
out collected  fly-ash.  Air leaks  caused by holes will  change the air flow
pattern and  decrease  the  device's  efficiency.
     A simple  U-shaped  tube half  filled  with water may  be  used  as a  pres-
 sure-drop-gauge.   One  leg is  connected to a duct in  which  the pressure is to
be  measured.  The  other leg is  open to the atmospheric  pressure outside the
 duct.   The  gauge then  shows the difference between  the  pressure within the
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duct and atmospheric pressure.  The pressure in the duct could be more or
less than atmospheric pressure.  The difference in levels is measured in
centimeters (inches) of water.  What is the pressure drop in centimeters
(inches) on the pressure-drop-gauge in Figure 3.6?
     Inertial separators commonly operate with pressure drops of 5 to
15.24 centimeters (2 to 6 inches) of water depending on design.  Greater
pressure drops indicate plugged cones or hoppers; lesser pressure drop
may be due to erosion of internal components which would substantially
reduce the collection efficiency.

ELECTROSTATIC PRECIPITATORS
     Your  task in inspecting  the electrostatic precipitator  is  to record
data from  each section  to compare with  data on the  original  permit.   You
should  check  the spark-rate meter  for each section.  The meter  should read
approximately 100 sparks/minute for the most  efficient  operation.  This
value,  however, varies  significantly from one installation to another.
You should also read and note the  secondary  or precipitator  current  and
voltage for each  section and  compare with original  permit  data.
     As part  of your inspection,  you should also (1)  check to determine
 if new sources  are  being vented through the precipitator;  (2) check main-
 tenance records  regarding  wire breakage; and (3) check frequency of  ash
 removal to determine if schedule complies with original permit.

 WET SCRUBBERS
      Wet scrubbers are used to a limited extent in combustion processes,
 primarily for controlling S02-  Inspection procedures include recording
 scrubber liquid-to-gas ratio, recording pressure drop rate and obtaining
 records of the acidity levels of liquid to compare with original permit.
                               6-47

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                    SELF-EVALUATION QUESTIONNAIRE II

     Below are statements describing conditions you might  find  during a

fuel-burning equipment inspection.  Read each statement  and  check whether

or not it describes a satisfactory or unsatisfactory condition.  Try  to

answer each question without referring back to the text.   Then,  refer back
for guidance if needed or to confirm your answers.
       Conditions Found During a
   Fuel-Burning Equipment Inspection
                                                   Rate Conditions
Satisfactory
                                                             Unsatisfactory
1.  The opacity of  the plume  is
    30 percent and  the color  is
    white.

2.  The opacity of  the plume  is
    10 percent and  the color  is
    gray.

3.  On the smoke chart, you note
    at 2:00 p.m. that opacity was
    at 70 percent for about a
    minute.

4.  You are inspecting a spreader
    stoker and find a C02
    concentration of 15 percent.

5.  During ash disposal the ash
    is wetted down as it is dumped
    into trucks.

6.  The pressure drop on an inertial
    separator is seven inches.

7.  On an electrostatic precipitator
    bus section the voltage meter
    reads zero.

8.  The fuel bed thickness in a
    spreader stoker is about 5 to
    10 centimeters  (2 to 4 inches).
                                        6-48

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       Conditions Found During a
   Fuel-Burning Equipment Inspection
                                                  Rate Conditions
Satisfactory
Unsatisfactory
 9.  Flames from a pulverized
     coal burner are impinging on
     the wall.

10.  The flame in the spreader
     stoker has black tips.

11.  The coal for a cyclone furnace
     arrives at the plant in pieces
     about 12.70 centimeters
     (5 inches) in diameter.

12.  Soot blowing is performed
     sequentially once every shift
     for a duration of 30 minutes.

13.  During dumping onto the con-
     veyor system, a small amount
     of fines are stirred up and
     they blow beyond the plant
     boundary.

14.  The flame in the spreader
     stoker is a clear yellow-
     orange.

15.  Looking  through the flame of
     a spreader stoker, the larger
     pieces of fuel are seen fall-
     ing onto the fuel bed.

16.  The oxygen level for a resi-
     dual oil fired boiler is
     8 percent.

17.  Steam-flow pen traces are
     above air-flow traces for
     three minutes in an hour.
                               6-49

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                CHAPTER 4. SOURCES INSPECTED IN THE FILM

                                Introduction
     The Film you will see as part of this module simulates the inspection
of fuel-burning equipment sources typical of those you will be inspecting
on the job.  The Film is divided into three parts:
        Part I:    Inspecting a plant which has a pulverized
                   coal burner.  This part also includes infor-
                   mation on the inspection of a Cyclone Furnace.
        Part II:   Inspecting a plant which has a spreader
                   stoker.
        Part III:  Inspecting a plant which has an oil burner
                   for  residual or distillate oils.


                         Your Job While Viewing the Film
      While you are watching the  Film, you will be required to  make  decisions
 about the adequacy of conditions  at  the plants depicted  in the Film.   That
 is,  you will have to rate some  of the  conditions  shown in  the  Film  and re-
 cord your decision on a form which will be provided  for  that purpose.   The
 Data Collection Forms for each  part  of  the Film  are  included in this  chapter.
 These are completed  while viewing the  Film.  The Film will show a FEO in-
 specting  some  component of a plant operation.  Then  the  narrator will ask
 you to make an evaluation about what you have just  seen.  You will  record
 your evaluation on the Data Collection Form.   For example, as the FEO is
 checking the ash disposal method, you will also  watch the  method of ash dis-
 posal used at  the plant being inspected.  The narrator will explain the pro-
 cedure as you watch it.  Then he will ask you to rate the ash disposal method
 as being satisfactory or unsatisfactory.  A statement directing you to record
 your decision will appear on the screen for several seconds to allow you
 enough time to enter your decision on the form.   At the completion of each
 part of the Film the projector will be stopped to allow you to make some
 additional decisions and to check your decisions against  the  decisions made
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by the "seasoned" FF.O in the Film.   You will not be required to make a
decision on each and every inspection point shown in the Film.  Some data
gathered during inspection has to be compared to the original permit after
the inspection has been completed.   The Steps below outline your task while
watching the Film.
        Step 1.  Before viewing Part I of the Film, read the
                 information about the plant to be inspected
                 and look at the photographs of the plant.  By
                 studying these photographs you will get a pre-
                 view of the inspection points covered in the
                 Film.
        Step 2.  Review the  "Data  Collection Form:   Pulverized
                 Coal Burner" to see which inspection points
                 you will have to  make decisions  about.
        Step 3.  View Part I of the  Film  and record your
                 decisions on the Data Collection Form.
        Step 4.  The projector will  stop  after Part I is  com-
                 pleted.  After viewing Part I,  review the photo-
                 graphs  of the  plant for  additional information
                 on any  inspection  point  you are uncertain about.
        Step 5.  Check your  decisions against  those of the
                 "seasoned"  FEO.  The course Instructor will pro-
                 vide  you with  the  FEO's  results.
        Step  6.  Follow  Steps 1 through  5 for  Part II of  the Film.
        Step  7.  Follow  Steps 1 through  5 for  Part III of the  Film.
                 Film.
                                       6-52

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              Information About the Sources to be Inspected in the Film
PART I:  PULVERIZED COAL BURNING FURNACE
     The plant in Part I of  the Film is the Riverdale plant of a large
power  company.  The plant  uses a pulverized coal burner system.   The air
pollution control equipment  are electrostatic precipitators.   This plant
has been issued an operating permit.
     During the course of  the Film you will be directed  to  perform the
following ten inspection tasks:
        1.  Record opacity percentage.
        2.  Rate condition of steam-flow/air-flow as  satisfactory
            or unsatisfactory.
        3.  Rate condition of emissions  as  shown by opacity chart.
        4.  Rate the C02 concentration  as satisfactory  or
            unsatisfactory.  (A CC>2 concentration guide  is pre-
            sented opposite  the Data  Collection  Form.)
        5.  Rate condition of flame.
        6.  Rate condition of furnace walls.
        7.  Rate condition of fan.
        8.  Rate adequacy  of ash disposal.
        9.  Rate adequacy  of conveyor system.
        10.  Rate extent of windblown emissions.
     In addition to the above, you will observe  the  inspector recording
data from the  electrostatic  precipitator for comparison with the original
permit.
     The Data  Collection Form to be  used while viewing the  Film is on
page 55.  Photographs  of some of the inspection  points follow the Data
Collection  Form.  You  may  want to refer back to  chapter 3  to review some
of  the guidelines  for  deciding whether or not the conditions you will
observe are satisfactory.
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    CHECK THIS TABLE BEFORE RATING CO2 CONCENTRATION

SPREADER STOKER:    10  TO 12 PERCENT
PULVERIZED COAL
  BURNER:
12 TO 14 PERCENT
CYCLONE FURNACES:  12 TO 14 PERCENT
RESIDUAL OIL        12 TO 14 PERCENT
DISTILLATE OIL      10 TO 12 PERCENT
                    6-54

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~  DATA COLLECTION FORM: PULVERIZED COAL BURNER
_   1. RECORD  PERCENT  OF OPACITY  HERE:
RATE CONDITION OF:
2. STEAM FLOW
3. OPACITY CHART
4. C02 CONCENTRATION
5. FLAME CONDITION
6. FURNACE WALLS
7. FANS AND DUCT WORK
8. ASH DISPOSAL
9. CONVEYOR SYSTEM
10. WINDBLOWN EMISSIONS
CHECK ONE
SATISFACTORY




























UNSATISFACTORY




























                           6-55

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  Figure 4.3 Condition of steam flow/air flow
Figure 4.4 Emissions as shown by opacity chart
                      6-57

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            Figure 4.5 Slag deposits on furnace walls
Figure 4.6  Readings on "bus section" of electrostatic precipitator
                                6-58

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Figure 4.10 The system for coal delivery
               6-60

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View Part I of the Film and Complete
the Data Collection Form: Pulverized
Coal Burner Before Proceeding to the
Next Section of this Workbook.
         6-61

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PART II:   SPREADER STOKER FURNACE
     ihe plant in Part II of the Film is a food processing plant.   It uses
a spr-.ader stoker to generate heat for producing steam.  The spreader stoker
is  responsive to rapid changes in loca, a condition required for food pro-
cessing.  The air pollution control equipment are inertial separators.
Multi-cyclones are the type of inertial separator used.
     During  the  course of the Film you will be directed to perform the
following inspection  tasks:
         1.   Record opacity  percentage.
         2.   Rate condition  of flame  and  rate  condition of  fuel  bed.
         3.   Rate condition  of grates.
         4.   Rate condition  of furnace walls.
         5.   Rate adequacy of fuel delivery and rate adequacy of
             coal size.
         6.   Rate condition of emissions as shown by opacity chart.
         7.   Rate condition of steam-flow/air-flow.
         8.   Rate condition of cyclone exterior.
         9.  Rate condition of bottom ash.
       In addition, you will also observe  the  FEO  taking a manual C02  reading,
  recording  the  percent of oxygen in  the  combustion  air, and  reading  a pres-
  sure-drop-gauge on  an inertial  separator.  You will  rate  these conditions
  immediately after viewing  Part  II of the Film:
         10.   Rate the C02 concentration.
         11.   Rate the 02 level.
         12.  Rate pressure drop differential.
       The Data  Collection Form  to be used while viewing the Film, and the
  guides for C02, 02, and pressure drop are on the next two pages.  Photo-
  graphs of  some of the  inspection points follow  the Data Collection  Form.
  You  may want  to refer  back to  chapter 3 to  review some of  the guidelines  for
  deciding whether or not the conditions  you  will observe are satisfactory.
                                        6-62

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    CHECK THIS TABLE BEFORE RATING CO2 CONCENTRATION
SPREADER STOKER:    10 TO 12  PERCENT
PULVERIZED COAL
  BURNER:           12 TO 14  PERCENT
CYCLONE FURNACES:  12 TO 14  PERCENT
RESIDUAL OIL        12 TO 14  PERCENT
DISTILLATE OIL      10 TO 12  PERCENT
        CHECK THIS TABLE BEFORE RATING O2 LEVEL
SPREADER STOKER:      3 TO 9 PERCENT
PULVERIZED COAL
  BURNER:             3 TO 6  PERCENT
CYCLONE FURNACES:    3 TO 6  PERCENT
RESIDUAL OIL          3 TO 6  PERCENT
DISTILLATE OIL	3 TO 6  PERCENT

      CHECK THIS GUIDE BEFORE RATING PRESSURE DROP
  INERTIAL SEPARATOR-2 TO  6 INCHES
                6-63

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DATA COLLECTION FORM: SPREADER STOKER
 1.  RECORD PERCENT OF OPACITY  HERE:
RATE CONDITION OF:
2. FLAME AND
FUEL BED
3. GRATES
4. FURNACE WALLS
5. FUEL DELIVERY AND
COAL SIZE
6. OPACITY CHART
7. STEAM-FLOW/AIR-FLOW
8. CYCLONE EXTERIOR
9. BOTTOM ASH
CHECK ONE
SATISFACTORY






























UNSATISFACTORY































RATE CONDITIONS AFTER VIEWING FILM
10. C02 =10.5%
11. OXYGEN=6.7%
12. PRESSURE DROP=2 IN.


















                          6-64

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Figure 4.13  Slag deposits on furnace walls
                   6-66

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    Figure 4.14 The coal delivery system
Figure 4.15 The doors to the basement ash pit
                    6-67

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Figure 4.18  Percent of oxygen in combustion air
    Figure 4.19 Pressure drop gauge for air
               pollution control cyclones
                    6-69

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View Part II of the Film and Complete
the Data Collection Form: Spreader
Stoker Before Proceedine to the Next
Section of this Workbook.
                  6-70

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PART III:  OIL BURNING FURNACE
     The plant in Part III of the Film is the Mid-town Station which pro-
vides steam heat to buildings in a mid-city area.  The plant uses No. 6
residual oil.  The plant has no air pollution control equipment.
     There are two boilers at this plant and the oxygen and opacity record-
ers  show readings from both.  Look at Figure 4.20.  You will note that oxy-
gen  levels are being  recorded for two boilers.  You will also note that
opacity  levels for both boilers are being recorded on the same  chart.  The
numbers  up the side from  1 through 5 are Ringlemann numbers.  A number 1
corresponds  to 20 percent opacity.  The air-flow/steam-flow recorder pre-
sents  data for boiler number 1.  The two bottom traces are the  air-flow
and  steam-flow lines.
      During  the  course  of the Film you will be  directed  to perform  the
 following five  inspection tasks:
         1.   Record  opacity percentage.
         2.   Rate condition of emissions  as shown by opacity chart.
         3.   Rate condition of steam-flow/air-flow.
         4.   Rate condition of firebox interior.
         5.  Rate condition of fan.
      In addition to  the above, the FEO will observe several readings on the
  control panel which  he will later compare with the original permit.  After
  viewing the Film you will:
         6.  Rate the oxygen level for boiler No.  1.
          7.  Rate the oxygen level for boiler No.  2.
       The Data Collection Form to be used while viewing  the Film  is  on
  page  73.  Photographs  of some of the inspection  points  follow  the Data
  Collection  Form.  You  may want  to refer back to  chapter 3 to review the
  guidelines  for  deciding  whether or not  the conditions you will observe
  are satisfactory.
                                  6-71

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        CHECK THIS TABLE BEFORE RATING O2 LEVEL
SPREADER STOKER:
PULVERIZED-COAL
  BURNER:
CYCLONE FURNACES:
RESIDUAL OIL
DISTILLATE OIL
3 TO 9 PERCENT

3 TO 6  PERCENT
3 TO 6  PERCENT
3 TO 6  PERCENT
3 TO 6  PERCENT
                   6-72

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DATA COLLECTION FORM: OIL BURNING EQUIPMENT
 1. RECORD PERCENT OF OPACITY HERE.-
RATE CONDITION OF:
2. OPACITY CHART
3. STEAM-FLOW/AIR-FLOW
4. FIREBOX INTERIOR
5. FORCED DRAFT FANS
AND DUCT WORK
CHECK ONE
SATISFACTORY















UNSATISFACTORY















RATE CONDITIONS AFTER VIEWING FILM
6. BOILER #1:02 =11%
7. BOILER #2= 02 =7%














                        6-73

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Figure 4.23  Firebox interior
              6-77

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                       REFERENCES
1'.  Danielson, J. A.  Air pollution engineering manual:
     Air pollution control district, County of Los Angeles.
     DREW, Cincinnati, 0:  Public Health Service Bulletin
     No. 999-AP-40, 1967.

2.  de Lorenzi, 0.  Combustion engineering.   New York,  NY:
     Combustion Engineering—Superheater,  Inc., 1947.

3.  Devitt, J. W., Gerstle, R. W., and Kulujian, N.  J.
     Field surveillance and enforcement guide:   Combustion
     and incinerator sources.  Research Triangle Park,"NC:
     Environmental Protection Agency,  Publication No.
     APTD-1449.  June 1973.

4.  Devitt, J. W., Gerstle, R. W., and Kulujian, N.  J.
     Field operations and enforcement manual for air
     pollution control. Research Triangle  Park, NC:
     Environmental Protection Agency, Publication No.
     APTD-1102.

5.  Steam;  Its generation and use.  New York,  NY:
     Babcock and Wilcox Company, 38th Edition,  1972.

6.  Perry, R. H.  Perry's chemical engineers handbook.
     New York, NY:  McGraw Hill, Fourth Edition.
                             6-78

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                                   TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse before completing)
1 REPORT NO.
     EPA 450/2-80-076
                                                           3. RECIPIENT'S ACCESSION-NO.
4. TITLE ANDSUBTITLE
     APTI Course  444
     Air Pollution Field Enforcement
     Student Workbook
             5. REPORT DATE
                March 1980
             6. PERFORMING ORGANIZATION CODE
7 AUTHOR(S)
                                                           8. PERFORMING ORGANIZATION REPORT NO.
     C. W. Gruber,  P.  M.  Giblin
9. PERFORMING ORGANIZATION NAME AND ADDRESS
             10. PROGRAM ELEMENT NO.
                B18A2C
                                                           11. CONTRACT/GRANT NO.

                                                               68-02-3014
 12. SPONSORING AGENCY NAME AND ADDRESS
     U.S.  Environmental Protection Agency
     Manpower  and Technical Information Branch
     Air  Pollution Training Institute
     Research  Triangle Park, NC   27711	
             13. TYPE OF REPORT AND PERIOD COVERED
                Student  Workbook
             14. SPONSORING AGENCY CODE
                EPA-OANR-OAQPS
15. SUPPLEMENTARY NOTES
     EPA Project Officer for this manual is J. 0. Dealy, EPA-ERC,  MD-17, RTF, NC  27711
16. ABSTRACT
     This document is part of an  overall package of training  materials to be
     used in presenting the Air Pollution Training Institute  Course 444.  The
     course is designed for governmental air pollution control personnel who
     do  field inspection and enforcement work.  The workbook  contains printed
     materials needed to do classroom exercises recording visible emission
     violations and preparation of  a notice of violation thereon; conducting
     inspections of industrial facilities; preparation of cases for prosecution
     in  court and acting as a witness in a court case; and  handling public
     complaints about air pollution.

     This student workbook is used  in conjunction with the  Instructor's Guide
      (EPA 450/2-80-077) and the Student Manual  (EPA 450/2-80-075).
17.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                              b.IDENTIFIERS/OPEN ENDED TERMS  C. COSATI Field/Group
      Education
      Manuals
      Air Pollution
   Training  course
   Student Workbook
    13  B
    5  I
    68  A
13. DISTRIBUTION STATEMENT  Unlimited
Available from National  Technical Infor-
mation Service, 5285  Port  Royal Rd.,
              VA  22161	
19. SECURITY CLASS (This Report)
   Unclassified
21. NO. OF PAGES
    204
20. SECURITY CLASS (Thispage)
   Unclassified
                           22. PRICE
EPA Form 2220-1 (9-73)
                                            6-79

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