EMISSION TESTING REPORT

           ETB TEST NUMBER  71-MM-03
                Emissions From

            Wet Process Cement Kiln

             And Clinker Cooler

                      at
  IDEAL   CEMENT   COMPANY

            SEATTLE. WASHINGTON
               Project Officer
               Clyde E. Rlley
       ENVIRONMENTAL PROTECTION AGENCY
           Office of A1r Programs
Research Triangle Park, North Carolina 27711

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                             PREFACE

    The work reported herein was conducted by the Roy F. Weston Company,
pursuant to a task order issued by the Environmental Protection Agency (EPA),
under the terms of EPA Contract Number CPA 70-132 Task Order 1.  Mr. G. E.
Benson served as the Project Engineer and directed the Weston field team con-
sisting of Messrs. H. F. Schiff, B. W. Cowan, and L. W. Johnson.  Mr. Schiff
and Mr. Cowan performed the pollutant analyses at the Weston laboratories.
Roy F. Weston submitted to EPA a draft document from which EPA personnel
prepared the final report (Test No. 71-MM-03)
Approved:
Environmental Protection Agency
GeTie W. Smith
Chief, Metallurgical and Mechanical  Section
Emission Testing Branch
March 29, 1972
                                    11

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                             TABLE OF CONTENTS
                                                               Page
Acknowledgments                                                 1v
List of Tables                                                   v
List of Figures                                                  v
Summary                                                         V1
Introduction                                                     1
Process Description                                              2
Discussion of testing and Results                                6
Abstract                                                        12
Appendix A - Schematics of Test Locations                       13
Appendix B - Sampling Procedures                                16
Appendix C - Field Data and Notes                               19
Appendix D - Laboratory Procedures                              35
Appendix E - Sample Calculations                                41
Appendix F - Test Log                                           43
                                       111

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                        ACKNOWLEDGMENTS

    The Office of Air Programs of the Environmental  Protection Agency
gratefully wishes to acknowledge the valuable assistance of the follow-
ing members of the staff of Roy F. Weston, Inc., who made meaningful
contributions to the preparation of this report:
    E.  F.  Gilardi,              Concept Technology Division
    Senior Project Manager
    F.  L.  Cross,                Concept Technology Division
    Air Pollution Consultant
    G.  E.  Benson,               Concept Technology Division
    Project Engineer
    H.  F.  Schiff,               Concept Technology Division
    Assistant Project Scientist
    B.  W.  Cowan,                Concept Technology Division
    Technician
    L.  W.  Johnson,              Concept Technology Division
    Technician
    We also wish to acknowledge the following personnel  of the Ideal  Cement
Company, Seattle, Washington, for their cooperation and  assistance in the
preparation of this report:
    F.  Bauer,
    Plant Manager
    R.  Owens,                   Quality Control
    Supervisor
    R.  J.  Castelli,             Denver Office
    Environmental Specialist
    The following staff members of EPA-OAP have  participated in the planning
and execution of this project and/or preparation of this report:
    C.  E.  Riley,                Emission Testing Branch
    Technician
    p- K. York,                 Source Control Branch
    Chemical  Engineer
    J-  Bazes,                   Emission Testing Branch
    Chemical  Engineer
                                       1v

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                             LIST OF TABLES

 Table No.                        Title                                Page

   1         Summary of Particulate Data for Clinker Cooler             vt1
   2         Summary of Particulate Data for Kiln  Stack                  Vt11
   3         Particulate Emissions Data for Clinker Cooler               8
   4         Particulate Emissions Data for Kiln Stack                   11
 D-l         Results of Sample Recovery Procedure                        38
 D-2         Results of Emission  Spectroscopy Analysis                   40
 F-2         Sampling Log                                               43
                                  OF FIGURES
Figure No.                        U1U
   1        Diagram of Baghouse Collector on Clinker Cooler             3
   2        Diagram of Electrostatic Precipitator on Kiln               4
 A-l        Schematic of Clinker Cooler Exhaust Duct                   14
 A-2        Schematic of Kiln Stack Cross Section                      15
 B-l        EPA-OAP Particulate Train                                  18

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                                SUMMARY

    The Office of Air Programs of the Environmental  Protection Agency
contracted with Roy F.  Weston, Inc.  to conduct OAP participate sampling
tests in the duct from  the clinker cooler and in the kiln stack at the
Seattle, Washington plant of the Ideal Cement Company.   Three sampling
runs were conducted at the clinker cooler duct and two  simultaneous runs
were conducted at the kiln stack.
    The clinker cooler particulate emissions, which were controlled by a
baghouse dust collector, were 42, 46, and 56 Ibs/hr.  The measured particu-
late concentrations were 0.0513, 0.0571,  and 0.0698 gr/scf, respectively
(particulate emission catch of front half of train).
    The kiln emissions, which were controlled by an electrostatic precipitator,
were 85.9 and 94.0 Ibs/hr.  The particulate concentrations were 0.0935 and
.1064   gr/scf (particulate emission catch of front half of train).
    The isokinetic sampling ratios were between 89.9 and 105.7 percent.
    A summary of the particulate emissions data is presented in the follow-
ing Tables 1 and 2.  The complete summary results of the test may be found
in Tables 3 and 4.
                                     v1

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                                TABLE 1

            SUMMARY OF PARTICIPATE DATA FOR CLINKER COOLER
Run number
Date
Percent Excess Air
Percent Isokinetic
Stack Flow Rate-SCFM* dry
Stack Flow Rate-ACFM wet
Volume of Dry Gas Sampled
SCF*
Feed Rate - tons/hr
Parti culates
Probe, Cyclone, & Filter
mg
gr/SCF* dry
gr/CF @Stack Conditions
Ibs/hr
Ibs/ton feed
Total Catch
mg
gr/SCF* dry
gr/CF (PStack Conditions
Ibs/hr
Ibs/ton feed
% Impinger Catch
1
3-18-71
NA
105.7
95,699
108,307
105.39
103.4
Catch
351.0
0.0513
0.0453
42.0
0.406
374.3
0.0547
0.0483
44.8
0.433
6.22
2
3-19-71
NA
105.3
94,971
105,121
104.21
102.8
386.0
0.0571
0.0516
46.4
0.452
400.6
0.0592
0.0534
48.2
0.468
3.49
3
3-19-71
NA
101.9
94,100
104,555
100.03
104.9
453.3
0.0698
0.0628
56.3
0.536
462.7
0.0712
0.0641
57.4
0.547
2.03
*  70°F, 29.92" Hg
NA--Not Applicable.

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                                TABLE  2



             SUMMARY OF  PARTICULATE  DATA FOR KILN  STACK
Run Number
Date
Percent Excess Air
Percent Isokinetic
*
Stack Flow Rate - SCFM dry
Stack Flow Rate - ACFM wet
*
Volume of Dry Gas Sampled - SCF
Feed Rate - tons/hr
Particulates
Probe, Cyclone, & Filter Catch
mg
gr/SCF dry
gr/CF PStack Conditions
Ibs/hr
Ibs/ton feed
Total Catch
mg
*
gr/SCF dry
gr/CF @Stack Conditions
Ibs/hr
Ibs/ton feed
% Impinger Catch
1
3-24-71
67.8
93.5

107,179
286,431

39.69
101.7


241
0.0935
0.0350
85.9
0.844

262

0.1016
0.0380
93.4
0.918
8.01
2
3-24-71
67.8
89.9

103,085
288,505

36.68
101.7

•
253.5
0.1064
0.0380
94.0
0.924

281.8

0.1183
0.0422
104.4
1.027
10.04
*  70°F, 29.92" Hg                    v111

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                             INTRODUCTION

    Under the Clean Air Act, as amended, the Environmental  Protection
Agency is charged with the establishment of performance standards for
new installations or modifications of existing installations in stationary
source categories which may contribute significantly to air pollution.  A
performance standard is a standard for emissions of air pollutants which
reflects the best emission reduction systems that have been adequately
demonstrated (taking into account economic considerations).
    The development of realistic performance standards requires accurate
data on pollutant emissions within the various source categories.  In the
cement industry, eight plants exhibiting well controlled operation have
been selected for the emissions testing program.  This report presents the
particulate emissions data for the Seattle, Washington plant of the Ideal
Cement Company.
    Between March 15 and March 25, 1971, Roy F.  Weston, Inc. conducted
particulate source sampling at the following locations within the plant:
    1.  Outlet duct from the clinker cooler baghouse collector.
    2.  Stack from the kiln electrostatic precipitator.
    The clinker cooler performs the function described by its name; i.e.,
cools the clinker (the main constituent of cement) which is discharged from
the kiln.  The kiln acts to calcine the raw materials (which are fed to the
kiln in the form of a slurry) in a wet process operation.
    The following sections of this report include (1) a process description,
(2) a discussion of the testing procedure and results, (3)  an abstract of
the report, (4) analytical procedures and results, and (5)  sample calculations.

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                            PROCESS DESCRIPTION

    Clay, crushed limestone and silica sand are brought to the plant by
barge from British Columbia and Post Angles, Washington.   These materials
are ground and blended in a rotating ball mill  to a slurry.
    The blended slurry is fed into the upper end of a sloping (3/8 inch
per foot), slowly revolving (one revolution per minute) kiln.  This gas-
fired kiln is 500 ft. long, 15 1/2 ft. in diameter at the feed end and
tapered to 14 ft. at the discharge end with refractory lining encased in
a steel cylinder.  Fuel consumption is approximately 1,240 cu. ft. of gas
per barrel of cement produced.  During passage  through the kiln, the raw
materials are heated to a temperature of about  2800°F to produce the element
hydraulic calcium silicates, known in the trade as "clinker". This marble-
sized clinker material is then discharged from  the lower end of the kiln at
temperatures exceeding 2000°F and fed immediately into air-quenching cooler
units which reduce the temperature of the material to about T50°F.  From
these coolers, the newly-formed clinker material is conveyed to a storage
silo.
    A small amount of gypsum (4.45% by weight)  is added to the clinker
material and this mixture is fed into the finish grinding mill.  The mixture
leaving the grinding mill is fed to an air separator or classifier where the
coarse material is returned to the mill and the finished cement (90% through
325 mesh screen) is pneumatically pumped to storage silos.  Present plant
production is approximately 2,500,000 barrels of cement per year.
    The control equipment of interest in this report consists of two Mikro-
Pulsaire baghouse collectors (parallel) on the  clinker cooler and a Buell
electrostatic precipitator on the kiln (see Figures 1 and 2).

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        FIGURE I   DIAGRAM OF BAGHOU5E  COLLECTOR  ON

                            CLINKER  COOLER
                                                               KEY
•*	VACLAUM
—	EXHAUST^'
	-SOLID

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        EXPANSION
         JOIMT
                                           EXPANSION
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FIGURE  2  DIAGRAM OF ELECTROSTATIC  PRECIPITATOR  ON  KILN

                                                  KEY
                                                          ••	VACUUM
                                                          ^	EXHAUST
                                                          —	SOLID
                                                                              STACK

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    The baghouse collectors consist primarily of a series of cylindrical
filter elements enclosed in a dust-tight housing.  The felted filter media
is "Nomex" which is heat resistant for temperatures as high as 425°F and
is supported on a stainless steel  wire frame.  Dust laden air is admitted
to the housing and clean air withdrawn from inside the filter cylinders.
As dust particles accumulate on the filter elements, periodic cleaning is
accomplished by introduction of a  momentary jet of high pressure air through
a venturi mounted above each filter cylinder.  A continuous flow of air
through the collector is maintained, since only a fraction of the total
filter area is cleaned at one time.  The particulate matter falls during
the cleaning cycle to the hopper below where the material is removed by a
screw conveyor.
    These Mikro-Pulsaire collectors are designed to operate with a pressure
drop of 7 in. of water and have 864 filter bags per unit that are 4 1/2 in.
in diameter x 8 ft. long.  Each collector has six compartments and is 16 ft.
tall x 36 ft. long x 13 ft. wide with a 60° hopper below.  Each collector is
designed for a performance of 99.99+ percent efficiency with a gas volume of
62,500 ACF at 350°F.  The collection surface area is 8,040 square feet, which
                                            2
gives an air to surface ratio of 7.79 CFM/ft .  The approximate installed
cost of both baghouses was $425,000 in 1966.  Annual bag usage is about 50 bags
($12.00 each) and labor and maintenance is approximately $600.00.
    The electrostatic precipitator is of the horizontal flow type and consists
of two sections with three treatment stages in each  section   This unit is
designed for a performance of 99.83 percent efficiency with an inlet loading
of 12 gr/ACF at 700°F and an outlet loading of 0.02 gr/ACF and a gas volume

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to the predpltatori of 400,000 ACFM  containing 30-40 percent water.   The
collection surface area is 151,200 square feet which gives  an air-to-surface
ratio of 2.64 CFM/ft2.  The linear gas velocity is  5.28 feet per second  and
the residence time is 8.5 seconds.  The particle drift velocity is  0.281 feet
per.second.  There are 35 gas passages per section  and each passage is 9 inches
wide, 24 feet high, and 45 feet long.   The precipitator contains a  total of
3,990 emitting electrodes constructed  of stainless  steel.   The approximate
cost of installation in 1966 was $2,325,000.00 and  the annual  operating  cost
is about $10,400.00.
                    DISCUSSION OF TESTING AND RESULTS

    Schematic drawings of the sampling locations are shown  in Appendix A.  The
clinker cooler duct was not an ideal  sampling location, however, it was  the
only available location.  A temperature-controlled  damper was located approxi-
mately four feet in front of the sampling ducts.  Immediately preceding  the
damper was the fan.  Three sampling runs of 144 minutes duration were conducted
in the duct from the clinker cooler baghouse.
    Sampling was conducted at a total  of 36 points--12 points at each of three
sampling ports.   No sampling problems  occurred.  The isokinetic sampling rates
were 105.7, 105.3 and 101.9 percent for the three runs.
    Sampling was conducted in the kiln stack 150 feet above grade.   Two  simul-
taneous particulate runs were conducted.  Sampling  was done at 12 points—three
points at each of four ports located 90° apart.  The sampling trains were operated
at ports 180° apart.
    Tests at the kiln stack were begun on March 16  but discontinued due  to
sampling equipment difficulties.   OAP  type unitized trains  were obtained and

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sampling at the kiln stack was begun again on March 23.  Heavy rainfall made
sampling difficult.  The sampling platform and equipment were electrified
and several members of the sampling crew received shocks.  The electrical
shocks and the rain forced abortion of the sampling after five minutes of
the tests.  With the concurrence of the GAP observer, the tests were con-
tinued on March 24 at the point where they had been discontinued.
    Two simultaneous one-hour duration runs were completed between 11:30 a.m.
and 5:30 p.m.  The sampling was extremely difficult to complete.  The sampling
ports were below the stack platform top railing, and two ports were further
blocked by vertical members of the stack platform railing.  The port locations
made necessary the use of two different lengths of probe to sample the three
points at each port.  Operating two trains simultaneously caused further
problems due to coordination.  Anything that delayed the sampling with one
train also delayed the other.  The stack platform width was approximately
30 inches around the stack.  The sampling equipment and the four sampling
platforms erected at ports cluttered the platform and made movement around
the stack difficult.  Winds with velocities of 40 and 50 mph made it difficult
to retain heat in the sampling boxes.
    When changing probes and moving the sampling boxes inside and outside the
railing and from port to port, the box temperatures decreased quickly.  Fifteen
to twenty minutes were necessary to reheat the boxes after the sampling at
almost every point.  After completion of the two simultaneous particulate
sampling runs, no further sampling was conducted at the kiln stack.  For de-
tails of the sampling procedure see Appendix B.  Data sheets and notes
recorded in the field are presented in Appendix C.
                                      7

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    The kiln stack emissions which were controlled by an electrostatic
precipitator were 93.4 and 104.4 Ibs/hr.   The participate concentrations
were 0.1016 and 0.1183 gr/scf.   The isokinetic sampling rates were 93.5 and
89.9 percent.
    A complete summary of all participate testing data is presented in
Tables 3 and 4.  According to the Federal Register, "Standards of Per-
formance for New Stationary Sources V         (December 23, 1971), the
standards for particulate emissions, in terms of Ibs. per ton of feed to
the kiln, for cement plants are based upon measurement of the weight of
particulate matter collected in the probe, cyclone and filter section.  At
the time of testing the Ideal,  Seattle Plant (March 1971), these standards
had not been officially established.  Thus, emissions data were obtained
measuring  (a) the weight of particulates collected by the probe, cyclone
and filter alone and (b) measuring the total weight of particulates collected
(to include the impinger catch).  These are reported for both schemes in
Tables 3 and 4.  A sample calculation is  presented in Appendix E in which
the data for run No. 1 of the clinker cooler are utilized.
    Particulate samples were recovered from the sampling train and analyzed
for the elements Sb, As, Be, Cd, Cr, Cu,  Fe, Pb, Mn, Ni, Sr, V, and Zn.  Details
of the sample recovery procedure as well  as the results of the subsequent
analyses are presented in Appendix D.
    Nitrogen oxides and carbon  monoxide grab sampling was to be conducted
simultaneously with the particulate sampling.  During trial runs of NO
                                                                      X
sampling, a stream of water was pulled into the sample flask with the stack
gas stream.  This and other equipment difficulties, together with a test
crew member's illness, made NO   and CO sampling impossible.
                              A
                                       8

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                                   TABLE 3
                 PARTICULATE EMISSIONS DATA FOR CLINKER COOLER
Run No.
Test Date
Dn
\
Pb
U
P

V
m
Tffl
Vm
mstd
Vw
W
V
wgas
% M

Md
% co2
el f>
'•' C2
% to
% N2
% EA
MHd
U
m

r
P
s
Ts
"p
Pst
ps

%J
A
s
<>s
^
a
2 T


Sampling nozzle diameter, in.
Net time of test, min.
Barometric pressure, in.
. H*v absolute
Average Orifice pressure
drop, in. H,,0
Voluge of dry gas sampled,
ft at meter conditions
Average gas meter temperature, °F
Volume of dry gas sarnn'ied at
standard conditions*, SCF
Total ILO collected in irr.pingers
and sfl ica gel , ml
Volume of water vapor collected
at standard conditions*, SCF
% Moisture in the stack gas by
volume
Mole fraction of dry gas




Excess Air Percent
Molecular weight of stack gas,
dry basis
Molecular weight of stack gas,
wet basis
Pitot tube coefficient
Average velocity head of stack qas,
in. H20
Average stack temperature, °F ,
Net sampling points •
Static pressure of stack gas in. Ho
Stack gas pressure in. Hg absolute ;
Stack gas velocity at stack conditions
2 '
Stack area, in. i
Dry stack gas volumetric flow rate at
ii^vi,;' •" " ''."•in!".' ' r \'~.' ''-,•'' i'-'v,'^ .-'-C stCiCK
conditions, ACFM
Pprcpnt. isnkinetic
1
3-18-71
0.189
144
30.23

1.30

103.81

68.7
105.39

12

0.57

0.54

0.99
0.03
20.95
^
78.0
-
29.0

28.9

0.85
1.23

141
36
0.05
30.28
fpm 4012
3888
95,699
103,307

105.7
2
3-19-71
0.189
144
29.88

1.29

104.06

69.8
104.21

10

0.47

0.45

0.99
0.03
20.95
*1
78.0
-
29.0

28.9

0.85
1.19

121
36
0.05
29.93
3894
3888
94,971
105,121

105.3
3_
3-19-71
0.189
144
29.92

1.27

101.92

81.2
100.03

8

0.38

0.38

0.99
0.03
20.95
*1
78.0
-
29.0

28.9

0.85
1.17

124
36
0.05
29.97
3873
3888
94,100
104,555

101.9
* 70°F, 29.92 in. Hg

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I Feed P.ate-
1
103.4
2
102.8
3.
104.9
                          TABLE  3  (Concluded)
               PARTICULATE EMISSIONS DATA FOR CLINKER COOLER

Run Mo.
T          Uni
 c         Tons/hr                                  	
mf         Particulate - probe, cyclone         351.0         386.6      453.3
           and filter, ing
mt         Particulate - total, mg              374.3         400.6      462.7
I          % impinger catch                      6.22          3.49       2.03
C          Particulate - probe, cyclone,       0.0513        0.0571     0.0698
 an        and filter, gr/SCF*
C          Particulate-total.gr/SCF*        0.0547        0.0592     0.0712
 90
C .        Particulate - probe, cyclone,       0.0453        0.0516     0.0628
           and filter, gr/cf at stack
           conditions
Cau        Particulate •• total, gr/cf at       0.0483        0.0534     0.0641
           stack conditions
C          Particulate - probe, cyclone,         *2.0          46.4      56.3
 aw        and filter, Ib/hr.
C          Particulate - total, Ib/hr.           44.3          48.2      57.4
 C* X>
           rcu"i.'i\.uiciLcj - ijfouc, v-ycionc:,       0.406         0.0452     0.536
           and filter, Ib/ton feed
           Particulate - total, Ib/ton  feed    Q.433         0.468      0.547
*70°F, 29.92  in. Hg, dry basis
                                        10

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                                   TABLE
                   PARTICIPATE  EMISSIONS DATA FOR BIN STACK
SL^lJto-
', e:>t: Date
Dn
Tt
A
U
Pm
111
Vm
HI
Tm
Vm
mstd
Vw
W
V,
. wgas
% M

Hd
s co2
% °2
% CO
% Up
% EA
HWd
u •
Mil

cp
AP

TS
NP
Pst
ps
V
s
A
"*

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;d Rate--
ate - nrobe, cyclone
1
101.1
241
2
101.7
253.5
                              TABLE 4 (Concluded)
                    PARTICULATE EMISSIONS DATA FOR KILN STACK
 Run No.
 T          Unit Fei
  c         Torts/hr
 mf         Particu
            and filter, mg
 mt         Particulate - total, mg                     262             281.8
 I          % ircpinger catch                            8.01            10.04
 C          Particulate - probe, cvclone,             0.0935            0.1064
  an        and filter, gr/SCF*
 Cao        Particulate - total, gr/SCF*              0.1016           0.1183
 C .         Particulate - probe, cyclone,             0.0350           0.0380
  aL        and filter, gr/cf at stack
            conditions
 Cau        Particulate - total, gr/cf at.             0.0380           0.0422
            stack conditions
 C          Particulate - probe,• eyeIC;-,L,               85.9             94.0
  aw        and filter, Ib/hr.
 C          Particulate - total, Ib/hr.                 93«*            104.4
  ax
  •t-P        i-dk uitiilalt1 - uiobe, cyclone,             0.844            0.924
            and filter, Ib/ton feed
 Ptt        Particulate - total, Ib/ton  feed          °«918            1»027
 *70°F, 29.92  in. Ha, dry basis
                                   ABSTRACT
     This source sampling report 1s  one of nine  studies concerning partlculate
and gaseous emissions from selected  cement plants  at vartous toctttons.  The
objectives of this study were to evaluate air  pollution*control equipment per-
formance and efficiencies and to determine emission constituents typical of the
cement Industry.  Schematics of test locations,  field and processed data, and
descriptions of sampling and laboratory analytical procedures have been Included
as part of the evaluation.
                                          12

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         APPENDIX A
SCHEMATICS OF TEST LOCATIONS
               13

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                                   FIGURE A-l
                           IDEAL  CEMENT COMPANY
                             SEATTLE, WASHINGTON
                     SCHEMATIC OF  CLINKER COOLER EXHAUST DUCT
EXHAUST-
1




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X 63*
X 571
X 51'
X 45'
X 39'
X 33*
X 27'
X 21 '
X 15'
X 9" /
X 3'
| |
1 K





DISTANCE TO
SAMPLING POINTS






D

A

M
P
E

R




                                    •3"SAMPLING PORT
FLOW FROM
BAGHOUSE DUST
COLLECTOR
                           TOP VIEW
                           SIDE VIES

-------
                                         FIGURE  A-2
                                 IDEAL CEMENT COMPANY
                                  SEATTLE,  WASHINGTON
                            SCHEMATIC OF KILN STACK CROSS-SECTION
       (71
3"  SAMPLING PORTS
                                                                              3" SAMPLING PORTS
                                                                 NOTE: INCHES,  INSIDE STACK,DENOTE
                                                                      THE DISTANCE FROM THE INSIDE
                                                                      OF THE WALL TO THE SAMPLING
                                                                      POINT.

-------
                                  APPENDIX B
                              SAMPLING PROCEDURES
     The participate sampling train used by Roy F. Weston, Inc. 1s shown
1n Figure B-l.  A glass or nonreactlve metal probe with button hook nozzles
(whose size depended on the velocity of the gases) headed the train.  The
equipment following the probe consisted of a glass cyclone and flash, (for
certain runs a glass cyclone by-pass was used), a pre-weighed glass fiber
filter, and four Greenberg-Snrith Implngers.  The Implngers were placed 1n
an 1ce bath, while the preceding glass pieces were contained In a hot box
maintained at a temperature of 240°F.  The first Implnger was modified by break-
Ing off the glass tip, the second was unmodified, and the third and fourth w@re
modified.  The first two Implngers each contained 100 ml of distilled watGt%
the third was empty, and the fourth contained a pre-welghed quantity of silica
gel.  A leakless vacuum pump, a dry gas meter, and a calibrated orifice measured
with an Inclined manometer completed the train.
     During sampling, gas stream velocities were measured by Insertion of a
calibrated type "S" pltot tube Into the stack beside the participate sampling
probe.  A type "K" thermocouple and a direct reading pyrometer measured gas
temperatures within the gas flow Itself.  Temperature measurements were made at
the heated cyclone, after the silica gel Implnger, and at the Inlet and outlet
of the dry gas meter.  Immediately after positioning on each traverse point,
readings were made and sampling were adjusted.
     Each sampling location was divided Into equal cross-sectional area.  The
centrold of each area was chosen as a sampling point.  The number of sampling
points was determined by the configuration of the sampling location (e.g.
circular, square, or rectangular) and Its distance from bends, constrictions,
                                          16

-------
fans, etc.  In general, the closer a sampling location was to a  bend  con-
striction, fan, etc., the greater was the number of sampling points  used.
     After the completion of sampling, the cleanup of the train  proceeded as
follows:  The filter was placed 1n a Petrl dish.  The probe, cyclone,  flask,
and the front half of the filter holder were washed with acetone Into  a sam-
ple bottle.  The volume of the first three 1mp1ngers was measured, and these
1mp1ngers, the back half of the filter holder, and all connectors were washed
first with distilled water and then with acetone.  The silica gel was  weighed
to the nearest tenth of a gram.
                                         17

-------
                                           FIGURE
B-l
                                     EPA-OAP PARTICULATE TRAIN
oo
                             PITOT  TUBE
                             AND
                             MANOMETER
                       GLASS
                       FIBER
                       FILTER
                   CYCLONE
                                  MPINGERS  IN  ICE BATH
                                                                          DRY TEST  METER
                                            ORIFICE
                                            AND
                                            MANOMETER

-------
     APPENDIX C
FIELD DATA AND NOTES
            19

-------




r^xl
•I
i
.5
PMB
\
<
-4"

f
r
t

t
*7"
\

I
45"
\f

* -
rs.
       2;
                           T
                           n"
                 / fl-
-------
                             PRELIMINARY FIELD DATA
                                SUek Geometry
                                        punt dJU  (L
                                        Test No.
                                        location
                                 A.  Dtst. from Instde of far wall to outside of
                                    near wall. In., . 	sb  	
                                 B.  Nail thickness. In.. •      2  "	
                                    Inside 4tav*M>-of stack • A-B
                                                      .1 **.
                                 Consents:
   Sketch of stack cross-section
   showing sampling holes
   Calculations:
   Calculator
         (12/07)
Point
/
i
3
t.
$
i
7
8
?
10
If
11-
&*^^^&£fo€k












01st. from outside
of samnle port. In.
2'V
9"
1^"
ll"
7"- 5"*
= D"
= />'

27" •= 79"
>V
V"

-S"/"
= 3J>"

r 47"

5^" _ ^5-9"
^j" _ ^5"
i^L_L_2C-^
^
   i±L.
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02
3
30.23
i«?jT
if.72.
                                 163. 367
                          IlL
&S.7
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                                                      1 .37
                                              le> s;  3?
  Mo;
       to
        -8
                Vr.#   .  ^g
                                 .377
                                                       990
                                                              A*ca
                                                                23.87
                                                                za.i?
ts±i
       3, fit
              30.22
         'VI
         I 21
              itc.n
                                                                                       Plant
                                                                                                                            • Date   'Z-St,
                                                                     Sailing location
                                                                                       &L.JL .
                                                                     STACK DATA FOR NOMOGRAPH:
                                                                     1. Metar tH    /, ^  £)
                                                                                                   1n
                                                                     2. Avg. nter teupt (ambient + ?0"     "7

                                                                     3. Moisture (volume) _ J   3
                                                                     4.  Avg.  static press. O   > XS" 1n. HjOX.073 « *  , OJ?      In. Hg.
                                                                     5.  Bar.  press sampling point30,2^	In.Hg +
                                                                             	In. Hg.
                                                                                                                                        (static press In.Hq)
                                                                     6.  Bar press of nater

                                                                             .  5.
                                                                                                             t  2..~\   In. Hg.

                                                                                                              1,  Hg
                                                                                                  57"
                                                                                                              In.  Ha

                                                                                       8.  Avg. stick temperature
                                                               ./'^
                                                                                       9.  Avg. stack velocity UP)    /  /  Z.     In
                                                                                               C factor (1)   .,*$	(?)
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< DISTANCE
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DISTANCE
FROM WALL
INCHES








                                                                                                                                    Area Square ft.
                                                                                                                                    Effluent
                                                                                                                                    Flow Rite, CFH
                                                                                                                                    Effluent
                                                                                                                                    Flow Rate, SCFH
                                                                                                                  Operator^
                                                                                                                                    •1}
                                                                                                                                    1.1
                                                                                                                                     Lll
                                                                       21

-------
   VEIHf IK'ORTABT -  fill  IN All 6LAHKS
Fin Mo.    /
location (&JL.
CpiMtor
i   PATHOtCGiCAt. INCIURArORS-
I   read and record evsry  5 ra1mitss.
        Trr|) *f  ^5"^	
Bar. Press.  "85	3f3- 2"3  '
Asswra Hotsttn;  ii	_^	'_	
Hc-ter Box Setting.  'F
?rrbc Tip D1a.. In. _
Probe length _
                                       ,_      in H«i>	j	°r  	    : lyvig
                                        7,?p
-------

-------
               Yzc
                               /"
 y
 2.
3


 1
3
                        c,
       / 0
             .37?
FJ/
                              y
                              / / •
                                         5-;  3-7
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                                                   101,
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         ,  «^
                    24

-------
                             PREL1M1KART FIELD DAT*
                                SUcli QtoMtry
                                          runt
                                          Test No.
                                          location
                                          Date
                                  A.  01ft.  frag Inside of far will  to outside of
                                      mir mil. In.. .       2. Q  g _
                                  B.  Nail thickness. In., •      / 3  " _
                                                                                       Mtnt
                                                                                                                                    Date     "3 -
                                                                                       Sampling location
                                                                                                                                       '3n*u~.M)
                                                                                 STACK DATA FOR NOMOGRAPH:
                                                                                 1.  Meter aH     /.
                                      Inside diameter of stack - A-B  t <)£"
                                      Stack Area • 	
                                  Cements: A -
Sketch of stack cross-section
showing sampling holes
Calculations:
                                                                                 2.  Avg. meter tempt  (ambient t 20'    ~^~ &     °F

                                                                                •J.  Moisture (volume)       3 6	i

                                                                                 4.  Ayg. static press. £	
                                                                                                                                                           In. Ho.
Calculator
Point
)
L-
3
i,
5
I





t Dia. for
circular stack
Ll.U
It,. 7
ll.Z
•7?:-S
K.^.3
t-5. (,





01st. from outside
of samnle port, 1n.
2.6 +/J-S.I
2S.7 = *>
S'7f5' = ?&
/57.S = ITt
fUJ =• />?
l8Lb - 111-





r 6
?
r
4 ,
3
\ 8'
9.
                                                                                       5.  Bar. press sampling point !??.?&   In.Hg *  29. '/>Z-(static  press  tn.l! 2-	In. Hg.

                                   |^	1n.Hg(& ,  c<-  (static press  In.Hg)
                  t 7. ? i. in. Hg.
6.  Bar press of meter   f

          .  5-
                                          1n. Hg.
                   6\
      8.  Avg. stack temperature
                                                       *F.
      9.  Avg. stack velocity  UP)     .  £7/      In HjO.
                C factor (D__i_^ _ (2)
                                                                              25

-------
        *n   &aJA
                                  Ta/
            21.71
                      3 8,
                                                   3 ?.(,?
.5*
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                             26
                                         Jt

-------
  fun No.   ''  !—
  location
  tut*   .?4-7> _ >/
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  rtfeter 'lox No.	^^
      * H	£-£j2	
I  VERY iH?QrlTANT - Fill 1H Ai.i. SimS  -   A/nigs* ',-jsf °f   4*-3*
                               B»r. Cross. "Hg  J0. j V

                               Muter 8i.< Setting. «F
                               Probe Tip D:».. In. _
                               Probe Ler.;t?i 	
                               Prciie Heater Setting	"^7 Q
                   i I "iPetd tr.d retort.' »< the st«rt of
                   j  V«Mti tm point.
                   i I  'MMbsiCM. iNClliERATORS-
                  -*   md told record en-.ry 5 minutes.
                               	            __	.   ..
                             I   0-tflcc »H    Dry C«s Tirrii.  IvacuLnlcox !  jjir^.gcr !j-..-c- I ;f
                                                            -|X*S-

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S^^|: ^F^^-§?f£S^^fS^^'
                                          In.-^^iVsirV ;!,;.-;

-------
                   .
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                               23
                                                    /

-------
        L
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3/,
-------
                   PRF.SURVEY - PROCESS INDUSTRY & POWER PLANTS
                            DATE OF PRESURVEY
NAME OF COMPANY  C
ADDRESS
NAME OF CONTACT
PROVIDE FLOW DIAGRAM OF EACH PROCESS TO BE  SAMPLED,  INCLUDING FEED COMPOSITIONS AND
RATES, OPERATING TEMPERATURES AND PRESSURES, PRODUCT RATES, AND PROPOSED SAMPLING SITES:
xibfi
                '/*
*'
                         3-
                  /£$*'*>
                                        30

-------
PROVIDE  DIAGRAM OF EACH SAMPLING SITE.   INCLUDE THE FOLLOWING  INFORMATION:

      DIMENSIONS TO NEAREST OBSTRUCTION IN ALL DIRECTIONS FROM SAMPLING
      PORT.

      COMPLETE DESCRIPTION OF ALL PORTS INCLUDING ALL DIMENSIONS.  DESCRIPTION
      OF ANY UNUSUAL FEATURES ABOUT ENVIRONMENT; HEIGHT,  ODORS, TOXIC CONDITIONS,
      TEMPERATURE, DUST, ETC.          ,           ,   t                       .
                                                       , j*kj_
      Hldff^h
                                          31

-------


/jro

                                O
                               32
                                                   4
                                                   t
                                                    i.

-------
OPERATING" HOURS OF PLANT PERSONNEL
OPERATING SCHEDULE FOR EACH PROCESS TO BE SAMPLED
ARE PROCESSES BATCH OR CONTINUOUS?
LIST FEED RATES AND COMPOSITION FOR EACH PROCESS
LIST ANY CONTROL EQUIPMENT, INCLUDING SIZE
LIST EXPECTED CONSTITUENTS OF STACK GAS FOR EACH SAMPLING SITE
STACK DATA:  HEIGHT
                                ,   WIDTH /?  ^ /5 '
	O.D.  AMOUNT OF INSULATION
MATERIAL OF CONSTRUCTION,
PRESSURE 4/-~£ *h.#ri<>
                             WET BULB TEMPERATURE
AVERAGE PITOT TUBE READING
DISTANCE TO NEAREST UPSTREAM, RESTRICTION     6
DISTANCE TO NEAREST DOWNSTREAM RESTRICTION^
ARE PORTS EXISTING?  """ ^
                                            /t
                   H
                            . SIZE  jfW
                         fin. H"ft MTliL_Dpnt"ni:
                                                              DIAMETER
                                                        WALL THICKNESS  2 f
                                                                             "
                                                        GAS TEMPERATURE
                                                       TYPE OF RESTRICTION
                                                       TYPE OF RESTRICTION
                                            33

-------
SCAFFOLDING OR OTHER MEANS OF SUPPORT PRESENT?
              ), WHO WILL PROVIDE IT?_
SOURCE OF ELECTRICITY AVAILABLE?  /Z^YES, MAXIMUM AMPERAGE PER CIRCUIT^
                                  [J  NO
DISTANCE fS*" 20*  WHO WILL PROVIDE EXTENSION CORDS?_
LOCATION OF FUSE BOX
PARKING FACILITIES AVAILABLE FOR TRAILER OR VAN?
SIGNATURE REQUIRED ON PASSES?_
NEARBY RESTAURANTS AND MOTELS

                                                             WAIVERS?
/L
                                                            £s**Jlj>? )

LIST ANY SPECIAL SAFETY EQUIPMENT OR RULES
COMMENTS:
                                             34

-------
                                  APPENDIX D
                            LABORATORY PROCEDURES

     The following 1s a detailed outline of the laboratory procedure used
1n determining the weights of particulates and water collected In the various
segments of the EPA-OAP sampling train.
     All glassware used for evaporation and residue determinations In the
following steps was prepared for use by the following procedure.   The
beakers were first soaked 1n 40% nitric add for several  hours.   They were
then washed and rinsed with distilled water followed by oven-drying.  After
drying, the beakers were desiccated to constant weight and kept 1n a desiccator
until used.  Beakers were weighed to + 0.1 mg.
     A.  Filter
          1.)  Preparation
                    The filters are oven-dried e 105*C for a minimum of four
               hours, and then desiccated to constant weight.  Filters are
               weighed to + 0.1 mg.  After weighing, the filters  are placed
               1n plastic petrl dishes until used.
          2.)  Partlculate weight determination
                    Filter and any loose partlculate matter are transferred to
               a tared glass weighing dish, and desiccated to constant weight.
               The weight gain 1s then recorded.
     B.  Acetone washings prior to filter
          1.)  The acetone washings are received 1n glass bottles and their
              volume 1s measured.  They are then transferred to the tared
              beakers prepared as described above.
                                         35

-------
     2.)     The acetone washings are allowed to evaporate to dryness
          at ambient temperature and pressure.  The beakers are covered
          with ribbed cover glasses to facilitate evaporation without
          allowing dust or other foreign matter Into the beakers.   When
          dry, the beakers are desiccated to constant weight.  Beakers
          are weighed to nearest 0.1 mg.
     3.)     A blank of the acetone (measured amount) 1s evaporated also
          as described above.   Any residue resulting from this blank 1s
          used to correct for the amount of acetone used 1n the washings.
          The net weight 1s the required participate residue.
C.  Implnger water plus water rinsings
     1.)     The volume of Implnger water has been measured 1n the field
          and recorded.  Final volumes of these samples are measured 1n
          the laboratory 1n order to determine the volume of washings used
          and to correct for this water using a blank (by the same proce-
          dure used 1n part B-3 above).
     2.)     At this point an organic extraction of the Implnger water 1s
          1n order.  However, this step was omitted since no organic material
          was considered present.
D.  Acetone washings - back
     1.)     The volume of acetone washings 1s first measured and then the
          liquid 1s transferred to tared beakers (prepared as above) and
          allowed to evaporate to dryness at ambient temperature and pres-
          sure.  Upon drying, the beakers are desiccated to constant weight.
          A blank of the acetone used 1s also evaporated any corrections due
                                   36

-------
               to the acetone are made 1f necessary.  Beakers are weighed to
               nearest 0.1 mg.
     E.  Silica gel
         1.)  Preparation
                   The silica gel 1s placed In a wide mouth plastic bottle
              and capped.  The bottle plus silica gel 1s then weighed to the
              nearest 0.1 gm.
         2.)       After sampling, the bottle plus used silica gel 1s weighed
              to the nearest 0.1 gm and the weight of water collected Is deter-
              mined.
     Results of the sample recovery procedure are presented 1n Table D-l wherein
total partlculate weights are reported for each run.  These values were obtained
by adding the weights of the probe, cyclone, filter and 1mp1nger catches.
     An emission spectroscopy analysis was conducted on the partlculate samples
collected  from each stack to determine the concentrations (vg/g) of the follow-
ing elements: Sb, As, Be, Cd, Cr, Cu, Fe, Pb, Mn, N1, Sr, V, and Zn.  The results
of these tests are presented In Table D - 2.  In general, of the components
tested for, Iron was present 1n  the highest proportion (reaching concentrations
as high as 3.32), followed by zinc, strontium and lead.
                                        37

-------
                                      TABLE D - 1

                         RESULTS OF SAMPLE RECOVERY PROCEDURE
Clinker Cooler
Description of Sample

1.

2.




Filter

Probe, Flask
Cyclone Acetone
Front half Wash
Filter holder
RPW #
Filter
Net wt.
RFW #
Beaker
Net wt.


#
gm.

#
gm

Total
3.






H







Implnger HpO + H20 wash
Imp, conn.
back 1/2 filter holder




, Implngers, Connectors
hart 1/9 f 4 1 ^ov
l/Q^^ If. III WCI A«*A^j%nA
holder ^,*.-h
wash
Blanks H,0
z


RFW #
Beaker



Net wt.
gms.
RFW #
Beaker
Net wt.

RFW 1
Beaker
Net wt.
Sample

#



Run 1
1419
F56
0.0077
1417
117
0.3433

351.0
1416




Run 2
1423
F65
0.0297
1422
122
.3569

386.0
1420




Run 3
1427
F67
0.0197
1426
119
0.4336

453.3
1424




K1ln Stack
Run 1
....
....
0.159
....
....
0.082

241
....




* Run 2
1430
....
0.1643
1429
no
0.0892

253.5
Note: Implnger
water lost 1n
transit. Value
assumed to be
that forRun# 1
fblank)


#
gm.


#
gm.
Volume
0.0153
1418
124
0.0080

1414
121
0.0024
420
0.0047
1421
104
0.0093

1415
120
0.0025
435
0.0031
1425
105
0.0063



....

0.021

....
..._

....
....
0.0023
500
0.021
1428
111
0.0073





                             ml.
Total Partlculates, mg
(obtained by adding weights
374.3
400.6
462.7
262
281.8
* See TABLE D - 1 (Continued)
                                            38

-------
                                 TABLE  D  -  1  '(Continued)
                           ENVIRONMENTAL PROTECTION AGENCY
Reply to
•Attnof-. ETB, DAT                 .H. ,                                 Date:  April  20,  1971
 Subject: Participate Analysis of Samples Collected at Ideal  Cement,  Seattle,  Washington.

     TO: Gene Riley

        Sample _ _ Participate, Mg  _ Location
Impinger water
Probe, cyclone, flask
21
82
Kiln stack
        & filter holder

        Filter                                159

        Total                                 262

        Water blank (Seattle)          2.3 Mg/500 ml

        Water blank (Tijeris)          2.1 Mg/500 ml
        The sample results reflect correction for the blank.   The above sample
        was one of a pair of samples collected simultaneously by Roy Weston
        Company.  They are analyzing the companion sample for comparison with
        the above results.
        Howard L. Crist
        Chemist
        Emission Testing Branch
        Division of Applied Technology
                                                 39

-------
                                 TABLE D - 2
                  RESULTS OF EMISSION SPECTROSCOPY ANALYSIS
Sample type
Sample location
  and run No.
Sample weight, mg
Volume of gas
  sampled, scf
Part 1cul ate
Clinker Cooler
Run f 1
374.3
105.39
Partlcula
K1ln
Run # 1
262.0
39.69

Sb
As
Be
Cd
Cr
Cu
Fe
Pb
Mn
N1
Sr
V
Zn
Concentration, yg/g
100
< 192
2
40
850
500
33,000
300
400
500
2,000
< 4
4,000

< no
< 276
2
170
100
200
15,000
4,000
200
200
< 276
60
8,000
                                      40

-------
                              APPENDIX E

                           SAMPLE CALCULATIONS

Example: Run No. 1 on Clinker Cooker (for data, see Table 3, page   )

1.  Volume of dry gas sampled at standard conditions:   70°F,  29.92 in.  Hg, SCF


              17.7 x V  (P.+  Pm )  17.7 x 103.81(30.23+1.30 )
                      III   D  •\~-7~f-             '     • - in * '
       V     - _ _.  „. _ Jiii -, ___ , _____ .  ..  -   ' u»6« ins  ™
        mstd       V'm +nj53^           (68.7*46077^         105'39



2.  Volume of water vapor at 70°F and 29.92  in. Hg, SCF


       V     - 0.0474 x V  = O.n-174 x 12  - 0.57    SCF
        'gas
3.  Percent roisture in stack cjas:
               100 x V
               V     + V    105.39*0.57
                                          o.54
                l!1std    "gas
4.   Hole fraction of dry gas
       M. »  IT:: - %'.  =  TOO -0.54
        d        _.._ --   -- 1_
5.  Average molecular weight of dry stack  gas


                                                             3l
       (0.03  x  TUO" ^ + (20.95X TtJO  ^ +  <  78   x TW ^  "29.0
6.  Molecular woiqht of stack gas


       MH - !';l,'d x Fld + 18  (1 - Md) - 29.0  x 0.99  +   18  (1  -  .99  )  •-••  28.9
                                                1
7..  Stack qas velocity at stack conditions, fpn


       V  " d *3 {"' P x'«  - ''  ^' * ^"  "^" '''' '')
        <-    >'   *  v^'*''v''-i



            4,3GO x27.f	^_	J]='-

                       L.30.28    28.9.'
                                                      1/2
                                          41

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              SAMPLE  CALCULATIONS. RUN HO. 1. CLINKER COOLER (Continued)

 8.   Stack gas volumetric  flow  rate at standard conditions*, SCFM
              0.123 x Vs x As x Md x  PS   0.123 X4012  x  3888  XQ.9ix30.28
        °  ---      +-~ — ^ = — : —        ss — - - -95.699
         S
 9.   Stack gas  volumetric  flow  rate at stack, conditions, ACFM

        n     .05645  x  PC  x  (T.; * 460) .  .05645 x 95.699 x( 141 + 4FO) _.108
        Q  B - j - r*Ti - 5 - -- - - - -- IUO,
                       x  fd                30.28 x  0.99
                                                                              ACFM
10.   Percent isokinetic
             1,032 x (T   + 460)  x  V
                                    stii  B   1.C32  x  (W + 460) X105.39  = 105>7%
             Vs x Tt x Ps  x  Md  x  (Dn)f     4012 x 144x30.28x0.99x(0.189)2

11.  Particulate:  probe,  cyclone  and  ^iHer\  gr/SCF*  Dry Basis
                         f
        C   = 0.0154  x -V— -  O.OU:  SfJSAo.0513 3r/SCF
                         mstd

12.   Particular.? total, nr/Sf.F*  Pry  Basis
                         m.
        cao = °'0154  x V    " =  °'0154  x   374>3-0.0547qr/SCF
                        mstd           105.39
13.   Particulote:  probe, cyclone  and filter. ar/CF at stack conditions
              17.7 x  C   x P  x  M .    17.7 xO.051 3x30.28x0.99
            = __ _!"...* _ 2. = __-__«____«._____--__.»,
                                                         -
        r     __ _
        Sit        (Ts
14.  Particulate:  total, gr/CF at stack conditions
              17>? X Cao x Ps x Hd    17.7 x Q.Q547 x 30.28 x 0.99
        Cau =     (Ts + 460)        =     ( 141  +  460)        *     " 0.0483    gr/CF

15.  Particulate:  probe, cyclone, and filter, Ib/hr
        C,,, = 0.00857 x Can x Q  = 0.00857  x0.0513'x  95,699  =42.0   Ib/hr
         a Vi              an    b
16.  Particulate: total, Ib/hr                    i
        Cax = 0.00857 x Cao x Qs = 0.00857  XQ.0547 .x  95.699  = 44.8
17.  Particulate:c probe, cyclono, and filter, Ib/ton feed
          Ptf r ,-r'lvl-   -      -- 0.406      Ib/ton feed
18.  Parciculace:  tucdl, lu/tuii
                 C,v    44.8
          p   = _ax__ =lW^-=  .            lb/ton  feed
                  c                       42
* 70°F, 29.92 in. Hg

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                                APPENDIX F
                                TEST LOG
Table F - 1 presents the actual time during which sampling was conducted.
                                Table F - 1
                               Sampling Log
(Clinker Cooler)
Run Date
1 3-18-71


2 3-19-72


3 3-19-71



1 3-23-71
l(cont.)3-24-71






Sampling Port
A
B
C
C
B
A
A
B
C
(K1ln
E
E
N
N
W
W
S
s
Began
13:20
14:19
15:16
09:14
10:10
11:14
14:22
15:16
16:13
Stack)
10:25
10:50
12:30
12:50
14:00
14:15
16:00
16:20
Ended
14:08
15:07
16:04
10:02
10:58
12:02
15:10
16:04
17:01

10:30
11:00
12:40
12:55
14:05
14:25
16:10
16:25
Elapsed Time (ro1n)
48
48
48
48
48
48
48
48
48

5
10
10
5
5
10
10
5
                                      43

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                         TABLE  F - 1  (Continued)
Run      Date      Sampling  Port      Began      Ended      Elapsed Time (nrin)
 2      3-23-71           W            10:25      10:30             5
 2(cont.)3-24-71          W            10:50      11:00            10
                         S            12:30      12:40            10
                         S            12:50      12:55             5
                         E            14:00      14:05             5
                         E            14:15      14:25            10
                         N            16:00      16:10            10
                         N            16:20      16:25             5
                                       44

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