74-LIM-3B
                              (REPORT NUMBER)
AIR  POLLUTION  EMISSION  TES
                     WOODVILLE  LIME  AND
                             (PLANT NAME;

                     CHEMICAL COMPANY
                     WOODVILLE,  OHIO
                           (PLANT ADDRESS)
           U. S. ENVIRONMENTAL PROTECTION AGENCY
                Office of Air and Water Programs
            Office of Air Quality Planning and Standards
            Emission Standards and Engineering Division
                 Emission Measurement Branch
               Research Triangle Park, N. C. 27711

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                  PEDCo-EN VI RON MENTAL
                       SUITE13  •  ATKINSON SQUARE
                             CINCINNATI, OHIO  45246
                                       513 1-7-7 1-433O
       EMISSION TESTING REPORT
        EPA REPORT 74-LIM-3-B
   WOODVILLE LIME AND CHEMICAL CO,
           WOODVILLE, OHIO
       Contract No. 68-02-0237
               Task 26
            Submitted by:


PEDCo-Environmental Specialists, Inc,
          13 Atkdnson Square
        Cincinnati, Ohio 45246
            Prepared by:

            W. G. DeWees
       Richard W. Gerstle, P. E,
         September 16, 1974

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                  1.  TABLE OF CONTENTS






                                                     Page




 II. 'INTRODUCTION                                      1




III.  SUMMARY OF RESULTS                                3




 IV.  PROCESS DESCRIPTION                               9




  V.  LOCATION OF SAMPLING POINTS                      12




 VI.  PROCESS OPERATION & TEST CONDITIONS              14




VII.  SAMPLING AND ANALYTICAL PROCEDURES               19




  A.  PARTICULATE RESULTS AND EXAMPLE CALCULATIONS




  B.  GASEOUS RESULTS AND EXAMPLE CALCULATIONS




  •C.  VISIBLE EMISSIONS RESULTS




  D.  OPERATING RESULTS




  •E.  FIELD DATA




  F.  SAMPLE IDENTIFICATION LOG




  G.  LABORATORY REPORT




  H.  SAMPLING EMTHODS




  I.  TEST LOG




  J.  RELATED REPORTS




  K.  PROJECT PARTICIPANTS




  L.  SUMMARY OF TESTING COSTS

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                      II.  INTRODUCTION






     Under the Clean Air Act of 1970, as amended, the Environ-



mental Protection Agency is charged with the establishment of



performance standards for stationary sources which may contri-



bute significantly to air pollution.  A performance standard is



based, on the best emission reduction systems which have been



shown to be technically and economically feasible.



     In order to set realistic performance standards, accurate



data on pollutant emissions must be gathered from the stationary



source category under consideration.



     Woodville Lime and Chemical Co. in Woodville, Ohio, was



designated as a possible representative well-controlled



stationary source in the lime production industry and therefore



was selected for an emission testing program.  The process under



investigation in this test series was operation of the No. 1 lime



kiln at the Woodville plant, from which emissions are controlled



by a cyclone in series with a Buell electrostatic precipitator.



     Preliminary tests were performed during the week of May 20,



1974, to ascertain composition and velocity of the gas stream



and to observe visible emissions.



     The emission test program was conducted from July 8 to 10,



1974; on three test runs.  Sampling was done at the kiln stack to



determine concentrations of filterable and total particulate,

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oxides of nitrogen, and sulfur dioxide.  Determinations of



moisture content and dry molecular weight were performed



simultaneously.  Samples of the kiln feed, kiln product,



kiln fuel, and effluent dust from the ESP unit were collected



for calculation of a sulfur balance.  In addition, visible



emissions were recorded by two certified observers during this



time.  Because of difficulties with process operation and



above-normal production rates, further tests were scheduled



for August 5, 1974.  In the interim between test periods the



kiln was shut down, at which time.the ESP was cleaned and



inspected.

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                   III.  SUMMARY OF RESULTS






     Data on particulate emissions from the lime kiln are



summarized in Table 1.  Emissions of filterable particulate,



as measured by the probe and filter catch, averaged 9.77



pounds per hour at a concentration of 0.041 grain per DSCF.



Total particulate emissions averaged 18.3 pounds per hour



at a concentration of 0.077 grain per DSCF.  Emissions of



filterable particulate were higher in the first two tests



than in the third.  This can probably be attributed to discon-



tinuity in process operations and to problems with control



equipment, described in Section IV, "Process Operation".



Because of these difficulties, the emissions data reported



in this report are considered questionable with respect to



being representative of a well-controlled lime-producing



process.     •



     Data on oxides of nitrogen emissions are summarized



in Table 2.  These data show an average concentration of



339 ppm by volume and an hourly emission rate of 67.7 pounds



per hour of N02.



     Data on sulfur dioxide emissions are summarized in Table



3.  These data show an average concentration of 44.5 ppm



by volume and an hourly emission rate of 12.0 pounds per

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               Table 1.  SUMMARY OF PARTICULATE DATA
Run Number

Date

Volume of Gas Sampled ,  DSCFa

Average Stack Temperature ,  °F

Percent Moisture by. Volume ,  %

Stack Volumetric Flow Rate,  DSCFM

Stack Volumetric Flow Rate ,  ACFMC

Percent Isokinetic

Unit Production Rate, ton/hr

Particulates - probe, bypass, and
               filter catch

mg

gr/DSCF

gr/ACF

Ib/hr

Ib/ton

Particulates - total

mg

gr/DSCF

gr/ACF

Ib/hr

Ib/ton
1
7/8/74
237.923
621
11.3
27619
64393
102.9
781.1
0.051 .
0.022
12.0

1704.6
0.111
0.047
26.2
3_
7/9/74
239.642
669
12.1
27390
67296
104.5
718.9
0.046
0.019
10.9

989.9
0.064
0.026
15.0
5_
7/10/74
248.641
674
11.4
28658
70330
103.6
417.0
0.026
0.011
6.4
Vs
889.3
0.055
0.022
13.6
Avg'.

242.07
655
11.6.
27889
67340
140
639
0.041
0.017
9.77
;
1194.6
0.077
0.032
18.3
  Dry standard cubic feet at 70°F, 29.92 in Hg.
b Dry standard cubic feet per minute at 70°F, 29.92 in. Hg.
  Actual.cubic feet per minute.

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                               Table 2.   SUMMARY OF  OXIDES OF  NITROGEN  DATA
NOx Test No.
Date, 1974
Time, 24 hour clock
Flow Rate, DSCFM3
Sample Volume , ml
Milligrams of NO-
NOX Concentration,
N0x Ib/hr
Average ppm
Ib/hr
A
7/8
1748
27619
1457
0.83
ppm 299
58.9

• B
7/8
1848
27619
1521
0.672
232
45.6

C
7/8
1951
27619
1519
0.953
329
64.8
299
D
7/8
2048
27619
1495
0.957
336
66.1

58.85
E
7/9
915
27390
1554
0.976
330
64.4


• F G
7/9 7/9
1015 1115.
27390 27390
1549 1487
0.934 1.034
316 364
61.8 . 71.3
339.75
66.45
H
7/9
1215
27390
1522
1.014
349
68.3


I
7/10
920
28658
1602
1.093
358 .
73.2


J K
7/10 7/10
1033 1130
28658 28658
1938 1616
1.169 1.349
316 438
64.7 89.5
380
77.67
L
7/10
1230
28658
1660
1.290
408
83.3


Average





339.58
67.66


(jt
       a)   Dry standard cubic feet per minute,  corrected to 70° and 29.92" Hg as obtained during particulate test  runs.

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           Table 3.  SUMMARY OF SULFUR DIOXIDE DATA
Test No.

Date, 1974

Flow rate,DSCFMa

Sample volume, DSCFa

S02 in sample, grams


SO- emissions, Ib/hr

S02 concentration, ppm
by volume
   2

  7/8

 27619

166.917

 0.867


  19.1

  70.-2
   4

  7/9

 27390

165.549

 0.130


  2.42

 10.6
   6     Avg.

  7/10

 28658

166.705

 0.649


  14.4   12.0

  52.6   44.5
a)   Dry standard cubic feet at 70°F 29.92 in. Hg.

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hour of sulfur dioxide.



     Visual determination o-f the opacity of emissions from



the lime kiln exit stack was performed independently by two



PEDCo personnel.  Data on opacity measurements are summarized



in Table 4.  The average opacity was less than 5 percent



in all tests.  A period of high emissions occurred, however,



for about 1 minute in the first test, during which opacity



levels exceeded 20 percent.  Failure of a field in the electro-



static precipitator caused the discontinuity,.with the result



that the opacity values are not considered typical of those



occuring with well-controlled lime-production operations.



     During sample recovery on test 1, the probe glass liner



tip was found to be broken.  This test was therefore not



representative of true emissions.  Because of the higher



than expected opacity and various process problems, this



test series was terminated before enough measurements were



obtained to provide representative results.

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    No.
Date
Table  4.  SUMMARY OF VISIBLE EMISSION DATA


            '        !          •       1


                  7/8/74      '      7/9/74


               Obs.  1  .  Obs. 2  .  Obs. 1 .  Obs.  2
Interval of Observations   start



                        •-.  -End


Duration of Observation,  min


Total No.  of Readings


No. of Readings  Unobservable


No. of Readings  @ 0% Opacity


                  5%


               .10%       '   •


                 15%


                 20%


                •25%.


                 30%


        •   ' .     35%


                 40%


                 45%


.  •               50%


Percent Readings Unobservable


Percent Readings @ 0%  Opacity


                   5%


                  10%


                  15%


                •20%


Percent Readings Exceeding 20%




      24-hour clock start and end times
     b
      Excluding  the time  that readings were not  recorded'for period of observation.
     c
      Readings recorded at 15-second intervals unless otherwise noted.

     Observer  1 - R. S. Amick

     Observer  2. - w. G. DeWees

                                     8
     5.


   7/10/74


Obs..1  ,  Obs. ?
1715
2124
247
988
0
986
2
^^
_
••»
^
—
• _
_
_
_
0
99.8
0.2
—
-
_
—
1713
• 2112
228
912
. 10
711
184
7
_
_
—
—
__
M

_
0.8
78.0
20.2
—
-
. _
—
840
1245
245
980
0 .
914
34
26
3
3
	
_
_
_
— .
—
0
93.3
3.5
2.6
0.3
0.3
— .
843
.1235
233
932
154
174
597
7
_
•»•
—»
^ ,
_
_
_
M
16 . 5
18.7
64.1
0.7
-
_
—
820
1252
272
1088
0
1061
21
5
1
•H
_
„
«.
_
—
—
0
97.5
1.9
0.5
0.1
_ •
—
838
1239
212.5
850
0
782
66
1
1
^ —
mu
, ^^
^
_
_
—
0
92.0
7.8
0.1
0.1
_
—

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                      .IV.  PROCESS DESCRIPTION






   .  Limestone consisting primarily of calcium carbonate or combina-



tions of calcium and magnesium carbonate with varying amounts of



impurities is quarried at the Woodville Plant.  The limestone is



calcined or burned to form lime, commonly divided into two basic pro-



ducts—quicklime and hydrated lime.  Calcination expels carbon



dioxide from the raw limestone, leaving calcium oxide (quicklime).



With the addition of water, calcium hydroxide (hydrated lime) is



formed.



     The basic processes in production are:   (1) quarrying the lime-



stone raw material, (2)  preparing the limestone for kilns by crushing



and sizing,  (3) calcining the limestone, and  (4) optionally processing



the quicklime further by additional crushing and sizing followed by



hydration.  The majority of lime is produced, in rotary kilns which



can be fired by coal, oil, or gas.  Rotary kilns have the advantage



of producing high production per man-hour and a more uniform product.



However, they do require higher capital investment and unit fuel



costs than most vertical kilns.




     The Woodville Lime and Chemical plant has two rotary kilns



each equipped with a Buell electrostatic precipitator.  The kilns



are almost identical.  The feed for both is a dolomitic stone,



quarried on  the site and  fed in sizes ranging from 1 inch to



2  1/4.inches at a rate of about 700 tons per  day.  There is no

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preheater.  Normally the kiln is fueled with a mixture of
95 percent Number 6 fuel oil .and 5 percent natural gas.  Both
kilns have two heat transfer sections, each 20 feet long.  The
product, about 350 tons per day, is,cooled in a Neims cooler before
storage.  There is no product crushing, but undersize material
is separated and returned to the kiln.  The majority of the
product.is used in the steel industry, mostly in basic oxygen
furnaces; none of the product is hydrated.
     The electrostatic precipitator on kiln Number 1 was put in
operation in July 1971.  In this kiln the main process fan is
located before the ESP, with a cyclone before the fan to reduce
fan blade erosion.  The precipitator on kiln Number 2 was put in
operation in December 1973.  The main process fan is after the
ESP and there is no cyclone.
     In both systems the inlet gas to the precipitators is cooled
to about 600°F with a combination of water injection and/or
tempering air.  Each precipitator has 28,800 square feet of
collecting surface area, which includes one cell and two fields;
design gas velocity is 1.5 feet per second and treatment time,
10.0 seconds.  The plant manager reported that an earlier
emission  test  showed exit  loadings of  less than  0.005  grain
per dry standard  cubic foot.
     At present the dust collected from the precipitators is
disposed  of  in the quarry...   It  is expected that  in the  future the
                               10

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dust will be granulated and used as a component of dry mix



fertilizers that are blended in another part of the complex.



     At the time of the initial plant inspection (February 8,



1974) the precipitators were working satisfactorily and had



been very well maintained.  The plant is representative of



modern design; raw materials and products are typical of those



in the industry.
                                11

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               V.  LOCATION OF SAMPLING POINTS






     Figure 1 shows the sampling ports and sampling points used



in the No. 1 lime kiln exit stack.  The sampling ports were



located in a 63.5-inch inside-diameter vertical stack, 4 feet



(0.75 diameter)  from the stack exit, and 12 feet (2.26 diameters)



from the nearest downstream disturbance.  In order to meet the



sampling requirements of Methods 1 and 5 of the Federal Register,



Vol. 36, No. 247, it was necessary to install a stack extension



on the ESP exhaust outlet.  Forty-eight traverse points (24



along each of two perpendicular diameters) were used as described



in the Federal Register Method 1.  Additional sampling points in



the existing stack at a lower site were used for some of the gas



sampling..
                              12

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            TOP  VIEW
           A.
                    45'
                             24'-



                       ScoffolcJing
                                      Edge ol roof
w'l
  1         1




 CROSS SECTION
I  S
                                        All Dimensions in Fool Aro Approximate
             ELEVATION
Figure  1.   Test Site-No. 1  Kiln Precipitator  Outlet.




                                13

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                VI.  PROCESS OPERATION & TEST CONDITIONS






     Before the test series began, EPA engineers had decided



to conduct tests at the Woodville plant only during periods



in. which opacity of visible emissions from the kiln stack



was in the range of 0 to 5 percent.  This range had been



described as typical of opacities during operation of the



No. 1 kiln and was judged to be typical of those occurring



in a well-controlled lime-producing plant.



     Although plant operations appeared to be normal and



preliminary readings indicated 0 to 5 percent opacity values,



several problems developed during the first day of testing,



July 8,1974.  After about 3 hours of testing, PEDCo's team



of opacity readers stopped the tests at 8:22 p.m. because



opacity values were exceeding the 5 percent limit.  Testing



was resumed at 8:27 p.m. and continued until 9:13 p.m.,



when the "A" field of the kiln's electrostatic precipitator



malfunctioned, probably because of overload.  Sampling was



resumed at 9:16 p.m., when the opacity values again dropped



to the 0 to 5 percent range.  The first test was completed



at 9:29 p.m.



     The second test was started on July 9 at 8:41 a.m.



Opacities of visible emissions ranged between 0 and 5 percent
                               14

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throughout the entire test sequence.  The test was completed
at 12:48 p.m., and because no problems were encountered
in sampling or process operation the emissions were considered
representative of those occurring normally.
     After completion of the second test, plant operators
performed a routine cleaning operation, shutting down a
fan on the inlet to the ESP for removal of adhering dust.
The fan was not re-started after cleaning, however, and
opacity readings during the afternoon ranged between 10
and 15 percent.  The third test, therefore, was not begun
until the following day.
     Testing was resumed at 8:24 a.m. on July 10.  Operations
appeared normal except for a heavy load in the kiln, as
evidenced by the .ampere meter on the kiln-drive motor..
Opacity readings ranged from 0 to 5 percent.  Sampling was
hampered, however, by blockage in the silica gel impinger,
which was replaced several times.  As testing progressed,
the opacity readers reported an increasing number of 5 percent
readings, with occasional 'puffs' as high as 10 percent.
Observations .of the plume were difficult because of cloudy
skies.  Test No. 3 was completed at 12:55 p.m.
     Operating variables for the three test runs are summarized
in Table 5,. and sulfur contents of the various process streams
are shown in Table 6.
     A  fourth test,  intended to provide values to replace
those obtained in Test No. 1, was started at  3:00 p.m. July
                              15

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         Table 5.  SUMMARY OF OPERATING VARIABLES
Date
Particulate Test No.
Stone Feed Rate,   ton/hra
Oil Rate, gal/hr
Firing Zone Temp,  °F
Mid Kiln, Temp, °F
Kiln Feed End Temp, °F
Before ESP Temp, °F
Stack Temp, °F

ELECTROSTATIC PRECIPITATOR DATA
    "A" Field
    Primary current, amps
    Primary voltage, volts
    Precipitator current, amps

    "B" Field
    Primary current, amps
    Primary voltage, volts
    Precipitator current, amps
  7/8/74
   322
2620-2650
1460-1465
1020-1040
 683-700
 660-675
  39-50
 250-275
0.20-0.30
  41-55
 240-260
0.27-0.35
   7/9/74
     3
   f     ' '• ^
   I
    356
2600-2650
1450-1475
10'00-1035
 685-700
 660-690
  37-46
 250-265
0.19-0.23
  50-54
 240-250
0.28-0.30
  7/10/74
    • 5

   375
2590-2620
1470-1520
1050-1080
 700-725
 670-700
  48-61
 250-270
0.20-0.32
  53-61
 240-250
0.32-0.37
a)  Obtained by multiplying indicated tonnage by
     (see Appendix D).
                              16

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Table 6.  SULFUR CONTENT OF KILN,  FUEL OIL,  FEED ROCK,  PRODUCT
          AND EFFLUENT. DUST.
Sample
#1 ESP Col. Dust
#1 ESP Col. Dust
#1 ESP Col. Dust
#2 ESP Col. Dust
#2 ESP Col. Dust
#2 ESP Col. Dust
#1 Stone Feed
#1 Rock Feed
#1 Rock Feed
#1 Rock Feed
#2 Stone Feed
#2 Rock Feed
#2 Rock Feed
#2 Kiln Product
#1 Lime Product
#1 Lime Product
#1 Lime Product
#2 Lime Product
#2 Lime Product
#1 Fuel Oil
#1 Fuel Oil
#2 Fuel Oil
#2 Fuel Oil
#2 Fuel Oil
#1 Fuel Oil
Date
7/8/74
7/9/74
7/10/74
7/8/74
7/9/74
7/10/74
7/8/74
7/9/74
7/10/74
7/10/74
7/8/74
7/9/74
7/10/74
7/9/74
7/8/74
7/9/74
7/10/74
7/8/74
7/10/74
7/9/74
7/8/74
7/9/74
7/10/74
7/8/74
7/10/74
Time
1830
1015
0800
2030
1255
1030
1750
1100
1700
1000
2036
1230
1300
1300
1720
0930
1000
2030
1230
0930
1900
1230
1230
2030
1100
Sulfur Content
% by weight
    0.9
    1.32
    1.28
    0.78
    1.16
    .1.64
    0.02
    0.07
    0.06
    0.07
    0.14
    0.04
    0.04
    0.01
    0.07
    0.04
    0.02
    0.06
    0.07
    1.75
    2.26
    1.7
    0.875
    3.22
    2.26
                              17

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10.  Except for the heavily loaded kiln, process operations



appeared normal.  Because opacity readings rose to the 15



to 20 percent.range, testing was stopped at 4:30 p.m.  Cleanup



operations later revealed that the sampling probe was broken.



The values obtained in this test were therefore discarded,



and further sampling was scheduled for the following day.



     On-the morning of July 11, however, stack opacity values



were again ranging between 5 and 10 percent.  Although plant



personnel tried several variations in kiln operation, the



high opacity readings persisted throughout the day and evening.



A reading at 10:30 p.m. gave values between 20 and 25 percent.



     At 6:00 a.m. on July 12, opacity readings still ranged



between 5 and 10 percent.  Personnel of the Woodville plant,



EPA, and PEDCo agreed that the kiln should be shutdown briefly



for inspection.  Examination of the ESP revealed that several



charge plates were covered with about 1 inch of a sticky



substance, which prevented the dust particles in the effluent



from receiving the positive charge and thus reduced collection



efficiency. • It was estimated that cleaning of the plates



would require shutdown of the kiln for a week or so.  A



shutdown was scheduled for the week of July 15 to allow



cleaning of the ESP, rebricking of certain kiln sections,



and routine periodic maintenance.  Further emissions testing



was to be conducted shortly after resumption of kiln operation.
                               18

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          VII. .SAMPLING AND ANALYTICAL PROCEDURES



     Sampling procedures were designated by EPA.   Analyses of


collected samples were performed by PEDCo.  Appendix H presents


detailed.sampling and analytical procedures.


Velocity and Gas Temperature


     Gas velocities were measured with a calibrated type S


pitot tube and inclined draft gage.  Velocities were measured


at each sampling point across the stack diameter to determine


an average value according to procedures described in the


Federal Register  - Method 2.  Temperatures were measured with


the use of a thermocouple.


Molecular Weight


     A 4-hour integrated sample of the stack gases was collected


during test 1 by pumping the gas into a Tedlar plastic bag at


the rate of approximately 0.005 CFM.  This bag sample was then


analyzed with an Orsat analyzer for C02, 02, and CO as described


in the Federal Register, Method 3.


Particulates
     Concentrations of particulate matter in stack gases were

                                                     2
measured by Method 5 as described in Federal Register.  A rigid


train consisting of a heated glass-lined probe, a 3-inch diameter
1)  Federal Register, Vol. 36, No. 247, December 23, 1971.

2)  Federal Register, Vol. 36,. No. 159, August 17,  1971.
                              19

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glass-fiber filter, and a series of Greenburg-Smith impingers



was used for particulate sampling, as shown in Figure 2.



     Sampling was conducted under isokinetic conditions by



monitoring stack-gas velocity with a pitot tube and adjusting



the sampling rate accordingly.



     The particulate sample was recovered by triple-rinsing



the nozzle, probe, cyclone by-pass, and front half of the filter



holder with acetone into a glass container.  The back half of the



filter holder, impingers, and connecting tubes were rinsed with



distilled water and the washings placed in a glass container with.



the impinger contents.   These components were then triple-rinsed



with acetone into another glass container.  The filter was



placed in a separate container.  Blank samples of water and



acetone were also taken.



     NO
     —x



     Nitrogen oxides were collected in evacuated 2-liter



flasks containing 25 ml of a dilute sulfuric acid/hydrogen



peroxide absorbing solution.  The sampling and analytical



procedure was as described in Method 7 of the Federal Register



except that the final flask vacuum was read immediately after



sampling.




S02


     Sulfur dioxide sampling procedures followed those described



in Method 6.  However,  due to the low expected concentrations,
1) Federal Register, Vol. 36, No. 247, December 23, 1971.
                              20

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                                         FILTER
NJ
       HEATED
       GLASS
       PROBE
                                                                                THERMOMETER
STACK WALL
                                         HEATED   I
                                         SECTION  •-
                        MANOMETER
                   I           | '               /    SILICA GEL-^I
                   |	I_LOO_FLL_ 0£_ WAT ER	j
                          THERMOMETERS •
                                                                                       UMBILICAL
                                                                                       CORD
               CALIBRATED ORIFICE
                                            CONTROL
                                            VALVES
                                                                                 VACUUM
                                                                                 GAUGE

                                                                                Hh
                   MANOMETER- I
                                Figure 2.   Particulate Sample Train

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larger sampling .equipment was used.  Flue gas was passed

through a set of Greenburg-Smith impingers at a rate of

approximately 0.8 cubic foot per minute.  The first impinger

contained 150 ml of 80 percent isopropanol; the second and

third impingers contained 100 ml each of 3 percent hydrogen


per6xide/water solution.  After sampling, ambient air was passed

through1the train for 10 to 15 minutes.  The isopropanol solution

was discarded,, and the peroxide solution rinsed into a glass

container.  The hydrogen peroxide  solution was titrated with

barium chloride, using a Thorin indicator as described in

Method 6.

Visible Emissions
                                                             <•»
     Visible emissions were determined according to procedure

in Method 9.  Readings were difficult to determine at times due -

to trucks loading and unloading ESP dust and quarry rock in the

vicinity of either the ESP unit or the observer and the light

colored plume against an overcast  and partly cloudy sky caused

poor distinction.  In addition, certain ESP rappers set up

a visible emission condition  (puffs) that read approximately

5 to 10 percent opacity for about  2 to 3 seconds every cycle.

Sulfur Analysis

     Solid samples were analyzed using Standard Methods of

Chemical Analysis of Limestone, Quicklime and Hydraded Lime,

C25-67, A.S.T.M. Standards, Part 9, Cement; Lime; Gypsum, 1972,

American Society for Testing and Materials, Philadelphia, Pa.
                               22

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     Fuel oil samples, were analyzed using Standard Method of Test



for Sulfur in Petroleum Products by the Bomb Method/ D 129-64,



A.S.T.M. Standards, Part '17, Petroleum Products - Fuels, Solvents,



Burner Fuel Oils, Lubricating Oils, Cutting Oils, Lubricating



Greases, Hydraulic Fluids, 1972, American Society for Testing



Materials, Philadelphia, Pa.
                              23

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