United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park NC 27711
EMB Report 80-BRK-1
April 1980
Air
Building Brick and
Structural Clay Industry
Emission Test Report
Lee Brick and Tile
Company
Sanford, North Carolina
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BUILDING BRICK AND STRUCTURAL CLAY INDUSTRY
Lee Brick and Tile Company
Sanford, North Carolina
Prepared for the
U.S. Environmental Protection Agency
Emission Measurement Branch
Research Triangle Park, North Carolina 27711
Prepared by
Clayton Environmental Consultants, Inc.
25711 Southfield Road
Southfield, Michigan 48075
EMB REPORT NO. 80-BRK-l
Work Assignment 22
Contract No. 68-02-2817
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TABLE OF CONTENTS
Page
1.0 Introduction 1
2.0 Summary and Discussion of Results 4
3.0 Process Description and Operation 21
4.0 Location of Sampling Points 30
5.0 Sampling and Analytical Procedures 36
APPENDICES
A. Project Participants
B. Field Data Sheets
B-l. Particulate
Sulfur Oxides
Nitrogen Oxides
Particle Size
Visible Emissions
B-2. Sampling Summary Data
B-3. Summary of Visible Emissions
C. Particle Size Distribution Tables
C-l. Particle Size Distribution
- North Kiln (Condition 1)
C-2. Particle Size Distribution
- North Kiln (Condition 2)
C-3. Particle Size Distribution
- South Kiln (Condition 1)
C-4. Particle Size Distribution
- South Kiln (Condition 2)
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TABLE OF CONTENTS (CONTINUED)
D. Example Calculations
E. Calibration Data
F. Process Conditions
G. Particulate Weight by Fraction
H. Surface Analysis and Research, Inc,
Analytical Report
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LIST OF FIGURES
Figure Page
1.1. Plant Roof and Source Layout 3
(plan view)
.2.1. Particle Size Distribution - North 15
Kiln, Condition 1
2.2. Particle Size Distribution - North 16
Kiln, Condition 2
2.3. Particle Size Distribution - South 18
Kiln, Conditions 1 and 2
3.1. Lee Brick and Tile Co., Process Flow 22
Diagram
4.1. North Kiln Stack Cross-Section 32
and Sampling Point Locations
4.2. South Kiln Stack Cross-Section 33
and Sampling Point Locations
4.3. Bottom Kiln Stack Cross-Section 34
and Sampling Point Locations
4.4. Dryer Stack Cross-Section and 35
Sampling Point Locations
5.1. Particulate Sampling Train 38
5.2. Sulfur Oxides Sampling Train 43
5.3. Nitrogen Oxides Sampling Train 45
5.4. Particle Sizing Sampling Train 48
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LIST OF TABLES
Table Page
1.1. Testing Program Protocol 2
2.1. Particulate Concentrations and 5
Emission Rates
2.2. Exhaust Gas Composition 10
2.3. Sulfur Oxides Concentrations and 11
Emission Rates
2.4. Nitrogen Oxides Concentrations and 14
Emission Rates
2.5. Coal and Clay Samples, Ash and Sulfur 20
Analyses
4.1. Physical Parameters of Sources 31
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1.0 INTRODUCTION
The U.S. Environmental Protection Agency (EPA)
retained Clayton Environmental Consultants, Inc. to
conduct an emission study at Lee Brick and Tile
Company, in Sanford, North Carolina. The purpose
of the study was to determine various emission data
from the kiln/dryer exhausts (four locations) under
two operating conditions. The results of this study
will be used in research and development efforts for
supporting New Source Performance Standards for
the Building Brick and Structural Clay Industry.
This study was commissioned as EMB Project No. 80-BRK-
1, Contract No. 68-02-2817, Work Assignment No. 22.
Testing was conducted under two kiln firing
conditions: low ash coal (Condition 1), and high ash
coal (Condition 2). Table 1.1 presents the distribu-
tion of the various tests conducted.
Auxiliary data gathered for each source included
exhaust gas compositions, moistures, temperatures, and
flowrates. Figure 1.1 presents a plan view of the
four sampling locations. A list of the project partic-
ipants is presented in Appendix A.
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TABLE 1.1. TESTING PROGRAM PROTOCOL
Test Type1
Particulate
Nitrogen Oxides
Sulfur Oxides
Particle Size
Coal Sample
(Sulfur and ash content)
Opacities
North Kiln
Cond. 1 Cond. 2
3 1
1 0
1 0
1 1
3 1
South Kiln
Cond. 1 Cond. 2
3 1
1 0
1 0
1 1
3 1
Recorded for the duration of each
particulate run.
Bottom Kiln
Cond. 1 Cond. 2
3 1
1 0
1 0
1 0
3 1
Dryer
Cond. 1 Cond. 2
3 1
1 0
1 0
1 0
3 1
I
NJ
I
Clay samples were acquired from each brick car which was in the kiln during sulfur oxide sampling,
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I
us
r
Penthouse
Brick
dryer
Dryer
exhaus t
Bottom
kiln
Coal
handling
Elevator
N
Railroad
tracks
Kiln
South
North kiln
Jciln
I
I
I
Pulverized
coal
transport
Coal storage
and processing
Figure 1.1. Plant roof and source layout (plan view).
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2.0 SUMMARY AND DISCUSSION OF RESULTS
For all particulate, sulfur oxide, nitrogen oxide,
and gas composition results discussed in this section,
Sample Nos. 1, 2, and 3 were collected during Condition
1 (low ash coal) and Sample No. 4 during Condition 2
(high ash coal). Field data sheets are presented in
Appendix B.
PARTICULATE EMISSIONS
Table 2.1 presents a summary of the particulate
concentrations and emission rates for each of the four
sampling locations. All results from Sample Nos. 1, 2,
and 3 representing Condition 1 are averaged for each
location, and results from Sample No. 4, representing
Condition 2, are shown separately. Concentrations are
presented in grains per dry standard c.ubic foot (gr/dscf)
and milligrams per dry standard cubic meter (mg/dscm).
Emission rates are presented in pounds per hour (Ib/hr)
and kilograms per hour (kg/hr).
North Kiln
Filterable particulate concentrations for Sample
Nos. 1, 2, and 3 ranged from 0.133 to 0.151 gr/dscf
(305 to 346 mg/dscm) and averaged 0.143 gr/dscf (328
mg/dscm). Total particulate concentrations ranged
from 0.144 to 0.161 gr/dscf (329 to 368 mg/dscm) and
averaged 0.155 gr/dscf (355 mg/dscm). The filterable
- 4 -
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TABLE 2.1. PARTICIPATE CONCENTRATIONS AND EMISSION RATES
Sampling
Location
Sample
Number3
1980
Data
Stack Gas
Parameters
Flowrate
dscfm
Temp
F
Concentration
Filterable
gr/dscf
mg/dscm
Total
gr/dscf
mg/dscm
Emission Rate
Filterable
Ib/hr
kg/hr
Total .
Ib/hr
kg/hr
1
2
North 3
Kiln
4
1
2
South 3
Kiln
4
1
2
3
Bottom
Kiln
4
1
2
3
Dryer
4
1-9
1-10
1-11
Average
1-12
1-9
1-10
1-11
Average
1-12
1-9
1-10
1-11
Average
1-12
1-9
1-10
1-11
Average
1-12
6,840
6,8&0
6,860
6,830
7,280
10,600
10,500
10,100
10,400
10,500
4,200
4,230
3,970
4,130
4,230
45,800
47,000
45,800
46,200
45,700
520
520
489
510
496
184
192
197
191
192
136
130
144
137
144
84.1
82.1
81.9
82.7
83.9
0.133
0.146
0.151
0.143
0.190
0.035
0.036
0.035
0.035
0.053
0.004
0.004
0.003
0.004
0.006
0.001
0.002
0.001
0.001
0.001
305
334
346
328
434
80.1
82.4
80.8
81.1
120
8.96
9.80
7U08
8.61
13.6
2.13
3.58
2.71
2.81
2.52
0.144
0.161
0.161
0.155
0.190
0.037
0.037
0.037
0.037
0.057
0.007
0.006
0.005
0.006
0.007
0.004
0.003
0.003
0.003
0.004
329
368
367
355
436
85.4
84.7
84.9
85.0
131
15.8
13.1
11.3
13.4
16.5
8.14
7.92
7.20
7.75
8.07
7.81
8.51
8.89
8.40
11.8
3.19
3.24
3.05
3.16
4.74
0.141
0.155
0.105
0.134
0.215
0.366
0.630
0.466
0.487
0.430
3.54
3.86
4.03
3.81
5.36
1.45
1.47
1.38
1.43
2.15
0.064
0.070
0.048
0.061
0.098
0.166
0.286
0.211
0.221
0.195
8.43
9.36
9.44
9.08
11.9
3.40
3.33
3.20
3.31
5.16
0.248
0.208
0.168
0.208
0. 2«1
1.40
1.39
1.23
1.34
1.38
3.82
4.25
4.28
4.12
5.39
1.54
1.51
1.45
1,50
2.34
0.113
0.094
0.076
0.094
0.118
0.633
0.632
0.560
0.608
0.626
'Sample Nos. 1, 2, and 3 were
sampling locations.
collected during Condition 1 with Sample No. 4 collected during Condition 2f for all
- 5 -
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emission rate ranged from 7.81 to 8.89 Ib/hr (3.54
to 4.03 kg/hr) and averaged 8.40 Ib/hr (3.81 kg/hr).
The total emission rate ranged from 8.43 to 9.44 Ib/hr
(3.82 to 4.28 kg/hr) and averaged 9.08 Ib/hr (4.12
kg/hr). The filterable concentration for Sample No.
4 was 0.190 gr/dscf (434 mg/dscm). Total partic-
ulate concentration was 0.190 gr/dscf (436 mg/dscm).
The filterable and total emission rates were 11.8 Ib/hr
(5.36 kg/hr) and 11.9 Ib/hr (5.39 kg/hr), respectively.
South Kiln
During Condition 1, filterable particulate concentra-
tions ranged from 0.035 to 0.036 gr/dscf (80.1 to 82.4
mg/dscm) and averaged 0.035 gr/dscf (81.1 mg/dscm).
Total particulate concentrations were 0.037 gr/dscf for
each sample (ranging from 84.7 to 85.4 mg/dscm, averaging
85.0 mg/dscm). The filterable and total emission rates
ranged from 3.05 to 3.24 Ib/hr (1.38 to 1.47 'kg/hr)3
and 3.20 to 3.40 Ib/hr (1.45 to 1.54 kg/hr), respectively,
averaging 3.16 Ib/hr (1.43 kg/hr) and 3.31 Ib/hr (1.50
kg/hr), respectively. The concentrations of filterable
and total particulate for Sample No. 4 were 0.053 gr/dscf
(120 mg/dscm) and 0.057 gr/dscf (131 mg/dscm), respectively.
The filterable and total emission rates were 4.74 Ib/hr
(2.15 kg/hr) and 5.16 Ib/hr (2.34 kg/hr), respectively.
- 6 -
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Bottom Kiln
Filterable particulate concentrations for Sample
Nos. 1, 2, and 3 ranged from 0.003 to 0.004 gr/dscf
(7.08 to 9.80 mg/dscm) and averaged 0.004 gr/dscf
(8.61 mg/dscm). Total particulate concentrations
ranged from 0.005 to 0.007 gr/dscf (11.3 to 15.8
mg/dscm) averaging 0.006 gr/dscf (13.4 mg/dscm).
The emission rates of filterable and total particulate
ranged from 0.105 to 0.155 Ib/hr (0.048 to 0.070
kg/hr) and 0.168 to 0.248 Ib/hr (0.076 to 0.113 kg/hr)
respectively, averaging 0.134 Ib/hr (0.061 kg/hr) and
0.208 Ib/hr (0.094 kg/hr), respectively, For Sample
No. 4 the filterable and total particulate concentrations
were 0.006 gr/dscf (13.6 mg/dscra) and 0.007 gr/dscf
(16.5 mg/dscm), respectively. The emission rates of
filterable and total particulate were 0.215 Ib/hr
(0.098 kg/hr) and 0.261 Ib/hr (0.118 kg/hr), respectively.
Dryer Stack
Filterable particulate concentrations for Sample
Nos. 1, 2, and 3 ranged from 0.001 to 0.002 gr/dscf
(2.13 to 3.58 mg/dscm) and averaged 0.001 gr/dscf (2.81
mg/dscm). Total particulate concentrations ranged from
0.003 to 0.004 gr/dscf (7.20 to 8.14 mg/dscm) and
averaged 0.003 gr/dscf (7.75 mg/dscm). The emission
rates for filterable and total particulate ranged from
0.366 to 0.630 Ib/hr (0.166 to 0.286 kg/hr) and 1.23
-------
to 1.40 Ib/hr (0.560 to 0.633 kg/hr) respectively,
averaging 0.487 Ib/hr (0.221 kg/hr) and 1.34 Ib/hr
(0.608 kg/hr), respectively. The filterable and
total particulate concentrations for Sample No. 4
were 0.001 gr/dscf (2.52 mg/dscm) and 0.004 gr/dscf
(8.07 mg/dscm), respectively. Filterable and total
particulate emission rates were 0.430 Ib/hr (0.195
kg/hr) and 1.38 Ib/hr (0.626 kg/hr)f respectively.
Examination of the data reveals a high degree of
reproducibility for concentrations and emission rates
at each sampling location. Additionally, flowrates
are quite consistent at each location, even between
the two conditions.
The single run under Condition 2 shows higher total
concentrations and emission rates than the average of
the three runs under Condition 1 for each location.
The increase in total particulate concentrations from
Condition 1 to Condition 2 ranges from 16.7-percent
at the bottom kiln location to 54.1-percent at
the south kiln location. Total particulate emission
rates increased in Condition 2 from Condition 1
from 2.8-percent at the dryer stack to 56-percent at
the south kiln stack.
- 8 -
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EXHAUST GAS COMPOSITION
Table 2.2 displays the exhaust gas composition
and moisture content results for each sampling
location. Initially, four determinations of carbon
dioxide, oxygen, and carbon monoxide were made,
one for each sampling location^ The Orsat analyses
at the bottom kiln and dryer locations failed to
detect either carbon dioxide or carbon monoxide in the
integrated bag sample acquired simultaneously with
the first particulate run. Following this analysis,
no subsequent samples were collected at these locations,
The values obtained from the first sample were used
for all remaining tests. Samples were taken for gas
composition and analyzed simultaneously with each
particulate run at the north and south kilns.
SULFUR OXIDES
Table 2.3 presents the sulfur oxides results.
Concentrations of sulfur dioxide are presented in parts
per million (ppm) and emission rates in pounds per
hour (Ib/hr) and kilograms per hour (kg/hr). Concentra-
tions ranged from less than 3.65 ppm at the bottom
kiln to 36.5 ppm at the north kiln. Emission rates
ranged from less than 0.151 Ib/hr (0,068 kg/hr) at
the bottom kiln to 6.10 Ib/hr (2.77 kg/hr) at the dryer
stack.
9 -
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TABLE 2.2. EXHAUST GAS COMPOSITION
Sampling
Location
Sample
Number
Moisture
Content,
Percent
Exhaust Gas Composition, Dry Basis, Percent
Carbon
Dioxide
Oxygen
Carbon
Monoxide
Nitrogen and
Other Inerts
North
Kiln
South
Kiln
Bottom
Kiln
Dryer
1
2
3
Average
4
1
2
3
Average
4
1
2a
3a
Average
4a
1
2a
3a
Average
4a
5.95
5.69
6.59
6.08
5.31
2.45
2.57
3.27
2.76
1.99
0.747
0.654
1.476
0.959
0.402
2.94
2.79
3.49
3.07
2.19
3.3 16.1 <0.1
3.4 16.4 <0.1
3.2 16.3 <0.1
3.3 16.3 <0.1
3.5 16.2 <0.1
0.7 19.5 <0.1
1.0 19.0 <0.1
1.1 18.7 <0.1
0.93 19.1 <0.1
1.0 18.8 <0.1
<0. 1 20. 2 <0. 1
<0.1 20.2 <0.1
<0. 1 20. 2 <0. 1
<0. 1 20. 2 <0. 1
<0.1 20.2 <0.1
<0.1 20.4 <0,1
<0. 1 20.4 <0. 1
<0.1 20.4 <0.1
<0.1 20.4 <0.1
<0.1 20.4 <0.1
80.6
80.2
80.5
80.4
80.3
79.8
80.0
80.2
80.0
80.2
79.8
79.8
79.8
79.8
79.8
79.6
79.6
79.6
79.6
79.6
aSince the initial Orsat analyses indicated no combustion gases at this
location, samples were not collected during Runs 2, 3, and 4. Therefore,
values from the first test were'used for the remaining tests.
- 10 -
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TABLE 2.3. SULFUR OXIDES CONCENTRATIONS. AND EMISSION RATES
Sampl ing
Location
Sample
Number
1980
Date
Stack Gas Flowrate
d scf m
Sulfur Dioxide
Concentration
ppm
Emission Rate
Ib/hr kg/hr
North
Kiln
South
Kiln
Bottom
Kiln
Dryer
1
1
1
1
1-10
1-10
1-10
1-10
6,830a
10,400a
4,130a
46,200a
36.5
7.52
<3. 65
13.2
2.49
0.781
< 0 . 1 5 1
6. 10
1.13
0. 354
<0.068
2.77
An average of the three particulate runs conducted during Condition 1.
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Although the reproducibility of these values is
uncertain due to taking only single samples at each
location, the relative magnitude of sulfur dioxide
concentrations for each location is logical. Sulfur
dioxide in the dryer stack originates primarily from
the waste heat exhaust of the kiln. The waste heat
is withdrawn from the cooling zone, just downline
from the kiln firing zone. Although particulate
could possibly settle out in the kiln and ductwork
leading to the dryer, sulfur dioxide,being a gas,
would be carried over. Therefore, everything else being
equal, the sulfur dioxide concentrations could probably
be expected to be about the same at the waste heat
intake in the dryer as in the firing zone. However,
when the addition of dilution air is considered, it is
logical that the dryer emitted lower sulfur dioxide
concentrations than measured in the north kiln stack.
Given that the flowrate in the dryer stack was much
higher than any of the other stacks, the mass emission
of sulfur dioxide was highest at the dryer. The sulfur
dioxide found at the north and south kiln is from a
combination of the sulfur in the clay and combustion
gases from the coal. As expected, more sulfur dioxide
was detected at the north kiln than the south kiln
because the north kiln stack exhausts the actual burning
zone of the kiln,whereas the south kiln stack exhausts
- 12 -
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the entrance to the burning zone in the tunnel.
NITROGEN OXIDES
A summary of nitrogen oxides results is
presented in Table 2.4. Concentrations are given
in parts per million (ppm) and emission rates are in
pounds per hour (Ib/hr) and kilograms per hour (kg/hr).
Single nitrogen oxides samples were taken at each
location. Concentrations ranged from 14.5 ppm at
the dryer stack to 134 ppm at the north kiln. Emission
rates ranged from 2.12 Ib/hr (0.963 kg/hr) at the bottom
kiln to 6.58 Ib/hr (2.99 kg/hr) at the north kiln.
Since nitrogen oxides formation is proportional to
temperature, it was expected that the highest levels
of nitrogen oxides would be found at the north kiln,
which had the highest stack gas temperatures of the
four locations. Similarly, the lowest concentration
of nitrogen oxides was found at the dryer stack,
which was also the coolest of the four locations.
PARTICLE SIZE
Tables C-l and C-2 in Appendix C display the particle
size distribution at the north kiln under Conditions 1
and 2, respectively. Both distributions are graphically
displayed in Figures 2.1 and 2.2, respectively. The
particle size distribution is nearly the same for both
conditions. During Condition 1, approximately 50-
percent of the particles were 7.7 microns or less,
- 13 -
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TABLE 2.4. NITROGEN OXIDES CONCENTRATIONS AND EMISSION RATES
Sampling
Loca t ion
Sample
Number
1980
Date
Stack Gas Flowrate
d sc f m
Nitrogen Oxides (as N02)
Concentration
ppm
Emission Rate
Ib/hr kg/hr
North 1 1-10
Kiln
South 1 1-10
Kiln
Bottom 1 1-10
Kiln
Dryer 1 1-10
6,830*
10,400a
4,130a
46 ,200a
134. 6.58 ' 2.99
40.2 3.00 1.36'
71.7 2.12 0.963.
14.5 4.81 2.18
An average of the three particulate tests conducted during Condition 1.
-------
Effective
par ti cle
d iamet er
(microns'
Ui
i
0.3
0.2.
O.L
Condition
: 1
Figure 2.1. Particle
size distribution -
north kiln
0.01 0.05 0.1 0.2 0.5 1
10
20
30 40 !30 60 70 80
90
95
93
-------
Effective
particle 2 • °-
d iameter
(microns)
0.3
0.2
0.1
Condition
2
Figure 2.2. Particle ijrr:
size distribution -
north kiln
0.01 0.05 0.1 0.2 0.5 1 2 5 10 20 30 40 50 60 70 80 90 95 98
Cumulative Percentage Less Than Indicated Diameter, by Weight
-------
whereas in Condition 2, 50-percent of the particles
were 9.0 microns or less.
Tables C-3 and C-4 in Appendix C display the
particle size distributions at the south kiln under
Conditions 1 and 2, respectively. These distributions
are graphically displayed in Figure 2.3. In comparing
these two conditions at this location, it is found
that Condition 1 resulted in particle sizes which
were somewhat evenly balanced over the distribution
spectrum. Particle sizes for Condition 2 were relatively
large in diameter. During Condition 1, approximately
50-percent of the particles were 7.0 microns or less,
while during Condition 2, approximately 76-percent
were 7.7 microns or larger.
Particle sizing runs were conducted at the bottom
kiln and dryer locations, but due to extremely low
particulate levels for these two locations, an accurate
determination of the size distribution was not possible.
VISIBLE EMISSIONS
A summary of visible emissions is found in Appendix
B-3. At the north kiln during Condition 1, opacities
ranged from 5 to 23-percent, based on 6-minute averages.
For Condition 2, opacities range from 16 to 43-percent,
also based on 6-minute averages. For the south kiln
during Condition 1, opacities ranged from 0 to 13-percent,
- 17 -
-------
Ef f ec t i ve
Particle
Diameters
fe
oo
0.2-
0.1
Condition
2
Figure 2.3. Particle
size distribution -
south kiln
0.01 0.05 0.1 0.2 0.5 1 2 5 10 20 30 40 50 60 70 80 90 95
Cumulative Percentage Less Than Indicated Diameter, by Weight.
98 99
S9.8
-------
while Condition 2 opacities ranged from 7 to 20-percent,
both based on 6-minute averages.
CLAY AND COAL SAMPLES
Table 2.5 displays the results of the analyses
for percent sulfur and ash in the coal samples and
percent sulfur in the clay sample. During Condition
1, the percent ash in the coal samples ranged from
4.1 to 4.4-percent, and averaged 4.3-percent. During
Condition 2, the ash content was 6.9-percent. The
sulfur content of the coal samples acquired during
Condition 1 ranged from 0.70 to 0.82-percent, and
averaged 0.76-percent. The sulfur content was 0.64-
percent during Condition 2. The sulfur content of
the clay sample was 0.04-percent.
The ash content of the coal was 38-percent higher
for Condition 2 than the average of the three samples
acquired during Condition 1. The sulfur analysis revealed
a 19-percent decrease from Condition 1 to Condition 2.
Since the clay sample was acquired from brick
cars which had passed through the dryer, the sulfur
content of the "raw" clay is unknown. However, the
sulfur content of dried bricks is insignificant with
respect to the sulfur content of the coal.
An example of calculations and calibration data
used for all data reduction are presented in Appendix
D and E, respectively.
- 19 -
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TABLE 2.5. COAL AND CLAY SAMPLES, ASH AND SULFUR ANALYSES
Sample Type
Analysis
Percent Ash
Percent Sulfur
Coal
Run 1
Run 2
Run 3
4.4
4.3
4.1
0.75
9.70
0.82
Average
4.3
0.76
Coal Run 4
Clay
6.9
0.64
0.04
- 20 -
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3.0 PROCESS DESCRIPTION AND OPERATION
(Provided by Energy and Environmental Analysis, Inc.)
Lee Brick and Tile started operation in 1946.
The new fully automated plant was built in 1976; this
facility utilizes one tunnel kiln and one dryer.
The plant operates 24 hours per day, seven days
per week, with a two to six week shutdown for plant
maintenance. This shutdown period each year will
vary in length depending upon market conditions.
The building brick process is a very steady opera-
tion without any typical variations in production.
The normal production rate for Lee Brick is 96,768
brick per day; the design maximum capacity is 116,928
brick per day, but this production rate is seldomly
used .
The processes of interest in the building brick
industry are the drying and firing operations used to
"cure" the brick. These two sources are being studied
as a single unit process. There are no controls utilized
at Lee Brick, but this facility will provide data for
baseline emissions resulting from firing coals with
different ash content.
PROCESS DESCRIPTION
Figure 3.1. demonstrates the basic steps utilized
in the production of building brick at Lee Brick and
also shows locations of the various emission tests
- 21 -
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Common Clay
Stockpile
(Odd-size Brick)
Particulate Emissions
SO Emissions
NOX Emissions
Visible Emissions
Particle Size
Dry Brick Samples
for Sulfur Content
Pulverized Coal Samples
for Sulfur, Ash, etc.
Dehacker
4-
Packaging
4-
Outside Storage
Figure 3.1. Lee Brick and Tile Co., Process Flow Diagram.
- 22 -
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administered during the source test program.
The clay is brought from the stockpile to the
pug mill on a belt conveyor. Water is added to the
raw material and then mixed in the pug mill until
the proper consistency is reached. The material is
then moved through the deaerating section of the pug
mill to remove any bubbles or air holes. This
mixture is extruded in a continuous column onto a
conveyor which passes the clay column through the
cutting machine. Odd-sized brick are returned to
the pug mill by another conveyor, where they are
reworked into the raw material.
The unfired (green) brick continues on the conveyor
and may or may not be glazed (during the testing program
no glazing was done). The bricks are then stacked
on the kiln cars in two stacks by an automatic hacker.
Each kiln car (ware) holds 8,064 bricks (3 1/2" x 8"
x 2 1/4").
From the loading area, kiln cars are moved to a
holding station, where they sit until they are moved
into the dryer. There are always cars in the holding
station so that the drying and firing processes can
continue to operate during the night when the production
line is down or in case of a malfunction in the production
line during the day.
- 23 -
-------
The tunnel dryer can hold up to 24 cars. The
brick remain in the dryer for 48-hours before
entering the kiln. Waste heat is drawn from the
rapid cooling zone of the kiln and used to dry the
brick.
The tunnel kiln can accommodate 21 cars. The
movement of the cars throughout the kiln is not
continuous; they are moved intermittently, or
indexed. Each car is indexed one-half its length
every hour. This allows the heat from the burners
to be directed between the cars and between the
stacks of brick on each car.
The kiln is fired by a total of 47 burners.
Lee Brick uses a side-firing configuration. The
kiln can use natural gas, No. 2 fuel oil or coal
as its primary fuel. Several crown burners ensure
even heating throughout the top of the kiln and
always fire gas, independent of the primary fuel.
The burners used for oil and gas are the same;
however, the burner nozzles are different for the
two types of fuel. Different burners, however, are
needed for coal-firing. When firing with coal,
only half the number of side burners are needed because
they fire across the entire width of the kiln as
opposed to gas/oil firing. The burners in the latter
case fire just half-way across the kiln, thus,
- 24 -
-------
necessitating opposing burners on each side of the
kiln. During coal-firing, the first pair of side
burners are fired with gas to produce an effective
environment for coal combustion. Currently, normal
coal-firing procedures call for the first five
burner pairs to use gas. This procedure was estab-
lished due to earlier particulate source tests
accomplished during the burning of 8 1/2-percent ash
coal. These early tests showed that five burner
pairs had to fire gas to enable the kiln's partic-
ulate emission rate to conform with state regulations.
As the cars move through the firing zone, the
temperature is gradually increased, reaching a max-
imum of approximately 2000F. After the firing zone,
the brick move into the cooling zone of the kiln.
Ambient air is drawn into the kiln, passed over the
hot bricks, and then this heated air is passed to the
dryer.
When the fired brick come from the kiln, they are
moved to an automatic dehacker, which takes the brick
from the kiln cars and restacks them to marketable
bundles. They are then packaged and taken to an
outside storage area.
PROCESS OPERATIONS
The purpose of this test program was to measure
emission levels from a coal-fired kiln. There are
- 25 -
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three exhaust stacks from the kiln; the north and
south kiln stacks exhaust waste gases from inside
the kiln, while the bottom kiln stack pulls exhaust
gases from underneath the kiln. In addition to the
sampling of the three kiln stacks, measurements
were also taken from the dryer exhaust stack. A
stack extension with portholes had to be added to
the exhaust stack from the dryer. .
Process conditions were carefully observed and
testing was performed during normal operating condi-
tions (7.26 tons/hr of brick + 0.42 tons/hr of coal);
the process was very steady with no interruptions in
production. During the test, operating conditions
were monitored and recorded on process data sheets.
These data sheets are included in Appendix F.
The following process parameters were monitored:
(1) Relative humidity in the dryer exhaust gas;
(2) Temperature of the dryer exhaust gas;
(3) Temperature of kiln waste heat entering the
dryer;
(4) Maximum kiln temperature which controls the
coal feeding rate;
(5) Internal kiln pressure; and,
(6) Natural gas flowrate.
The natural gas flowrate was determined by taking
gas meter readings at the beginning and end of the
- 26 -
-------
day and averaging the total amount of gas over the
length of the day. Relative changes in .the flowrate
could be observed on the gas flow recorder (also shown
on process data sheets); however, this instrument does
not give a good indication of the absolute flowrates.
Process monitoring began approximately six hours
before the start of emission testing on January 9, 1980.
Simultaneous particulate emissions testing on the three
kiln stacks and dryer stack began around 3:00 pm and
were concluded by 7:30 pm. Low ash coal (4.3-percent ash)
was burned during this test period and no irregularities,
process changes, or malfunctions occurred during this
tim.e. The coal feeding rate was estimated to be 0.42
tons/hr.
On January 10, 1980, process monitoring began at
8:00 am; testing began at 11:00 am and ended at 6:30 pm.
The tests occurring this day included simultaneous
particulate emission testing on all four stacks, nitrogen
oxides emission testing on all four stacks, sulfur
oxides emission testing on all four stacks, and a
particle size test on the north kiln stack. The
absolute coal feeding rate was constant throughout
testing and had not been changed from the previous day.
There was a slight change in the distribution of the
coal (2-percent increase in Zone 1 of the kiln) through-
out the day due to a malfunction of one of the burners.
- 27 -
-------
The coal used this day was the same as the day before
(4.3-percent ash).
Process monitoring began at 8:00 am on January
11, 1980. Once again, the coal being fired was low
ash coal. Simultaneous particulate emissions testing
on all four stacks began around 11:00 am. The only
other tests performed on this day were particle sizing
tests on the dryer, bottom kiln,and south kiln stacks.
After the testing was completed, high ash coal
(6.9-percent ash) was fired to stabilize the system
for the following day's tests during high ash coal-
firing. The coal feeding rate was increased by S^percent
in Zone 1 of the kiln once the 6.9-percent coal reached
the burne rs. .
During testing on January 12, 1980, high ash coal
was fired. Process monitoring began at 9:00 am,while
testing began at 9:30 am. At 10:30 am the coal feeding
rate had to be increased by 2-percent in Zone 1 because
the maximum temperature in the kiln had dropped. The
temperature dropped again at 2:30 pm, thus, the flow -
rate was increased by another 2-percent. As the
temperature continued to drop, the flowrate was
further increased. Additional problems in maintaining
temperature were encountered at the end of the tests
so the operation was shut down after source testing
was completed at 5:00 pm. Simultaneous particulate
- 28 -
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emission tests on all four kilns began around 10:00
am. The only other tests accomplished this day were
particle size tests on the south kiln stack and the
north kiln stack.
Lee's head fireman stated that the minor increases
in the coal feed rate and the partial malfunction
of one burner are relatively insignificant process
upsets. These problems should not cause any noticeable
changes in the stack emissions. The continuing temper-
ature drops during January 12 were not a problem by the
time the testing was finished, but if the trend had
continued, production variations would have occurred.
Since Lee was operating its kiln on only high ash coal
solely for EPA testing purposes, Lee shut down the opera-
tion once the testing was completed instead of trying to
correct the problem.
- 29 -
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4.0 LOCATION OF SAMPLING POINTS
All four sampling locations were at roof level.
Each stack was accessed through two ports which were
90-degrees apart. Additional physical parameters
for each stack are provided in Table 4.1. Sampling
locations and each of the traverse points with their
respective distances from the duct wall for the north
kiln, south kiln, bottom kiln, and dryer stack are
presented in Figures 4.1, 4.2, 4.3 and 4.4, respectively.
All sampling locations were considered adequate
in their original configuration, with the exception
of the dryer stack. An extension to the stack was
needed since the original stack height did not allow for
sampling port placement which would meet the minimum
upstream and downstream.distances from disturbances
as required by EPA Method 1. Originally, the traverse
at the dryer stack was to consist of 24 sampling
points per port. Since Point 24 was too close to the
stack wall, Point 23 was sampled for twice the
normal duration. Also, Points 1 and 2 could not be
sampled because the port nipples were not flush with
the stack wall and extended into the stack by 1.75-
inches. Therefore, Point 3 was sampled for three times
the normal duration.
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TABLE 4.1. PHYSICAL PARAMETERS OF SOURCES
Parameters
North Kiln
South Kiln
Bottom Kiln
Dryer
Stack
Diameter (I.D.)
Diameters
Downs tream
(disturbances)
Diameters
Ups tream
(disturbances)
No. of sampling
points per
traverse
35.8 in(90.9cm)
3.4
(fan coupling)
1.3
(top of stack)
20
35.9 in(91.2cm)
3.4
(fan coupling)
1.2
(top of stack)
20
22.8 in(57.9cm)
5.0
(bend in duct)
1.0
(top of stack)
20
,72.1 in(183cm)
2.4
(reducing coupler)
.0.5
(top of stack)
24
-------
Elevation view
I
tjO
Point
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Distance
(Inche s )
0.5
1.4
2.4
3.5
4.6
5.9
7.3
8.9
10.9
13.9
21.9
24.9
26.9
28.5
29. 9
31.2
32.3
33.4
34.4
35.3
Cross-sectional
view
N
t
35 3/4" ..
44 1/2"
Sampling
port
35 1/2"
Roof
84" to fan
Jcoupling
Figure 4.1. North kiln stack cross-section and sampling point locations (not to scale).
-------
Elevation view
CO
Point
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Distance
(Inches)
0.5
1.4
2.4
3.5
4.6'
5.9
7.3
9.0
11.0
13.9
22.0
24.9
26.9
28.6
30.0
31.3
32.4
33.5
34.5
35.4
Cross-sectional
view
N
t
-35 7/8'i.
43"
Sampling
• r port
37"
\
84" to fan
coupling
Figure 4.2. South kiln stack cross-section and sampling point locations (not to scale).
-------
-p-
I
Point
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Distance
(Inches )
0.3
0.9
1.5
2.3
2.9
3.8
4.6
5.7
7.0
8.9
13.9
15.8
17.1
18.2
19.0
19.9
20.5
21.3
21.9
22.5
Elevation view
3.8 3/4"
Cross-sectional
view
•B-
22 3/4"-
24"
Sampling
port
55"
Roof
TT
Figure 4.3. Bottom kiln stack
locations (not to scale).
cross-section and sampling point
60" to
Imanifold
-------
Cross-sectional view
Elevation view
Point
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
Distance
(Inches )
0.8
2.3
4.0
5.7
7.6
9.5
11.6
14.0
16.6
19.6
23.3
28.7
43.4
48.8
52.5
55.5
58.1
60.5
62.6
64.5
66.4
68.1
69.8
71.3
18"
39"
133 1/2
u
72 1/8"-
1 3/4"
62"
Sampli]
port
Figure 4.4. Dryer stack cross-
section and sampling point locations
(not to scale).
36
- 35 -
Reducer coupling
Roof
-------
5.0 SAMPLING AND ANALYTICAL PROCEDURES
Exhaust gas sampling was conducted in accordance
with the procedures outlined in the U.S. Environmental
Protection Agency's (EPA) Standards of Performance for
New S'tationary Sources Methods 1-7 (Federal Register,
40CFR60, December 23, 1971, as amended through August,18
1977). An EPA Method 5 particulate sampling train was
used at each location with the following modification:
/R)
flexible Teflon^ tubing was used in the dryer and
bottom kiln sampling train to connect the filter
holder to the impinger series.
During a preliminary velocity traverse conducted
prior to testing, each stack was divided into equal
annular areas at whose midpoints exhaust gas veloc-
ities and temperatures were measured, in accordance
with EPA Methods 1 and 2. Velocity pressures were
measured at each sampling point using an S-type Pitot
tube and inclined 0 to 10-inch water gauge manometer.
Temperatures were measured with an iron constantan
(Type-J)thermocouple attached to the Pitot tube and
to a calibrated Omega Engineering, Model 199, digital
pyrometer. Exhaust gas flowrates and a nozzle size
required to maintain isokinetic sampling rates were
calculated from the preliminary velocity traverse
data. Stack gas moisture content was determined
using the volumetric condensate procedure outlined
in EPA Method 4.
- 36 -
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PARTICULATE EMISSIONS
Four particulate samples were extracted
simultaneously and isokinetically from each of
the four stack locations. The tunnel dryer stack
was sampled for 192 minutes at three minutes per
point while the three kiln locations were each
sampled for 200 minutes at four minutes per point.
Each sampling train (Figure 5.1) consisted of a
sharp, tapered, stainless steel sampling nozzle; a
heated glass probe; a heated, preweighed 110-mm Type
A glass-fiber filter; flexible Teflon® tubing at the
tunnel dryer and bottom kiln only; two Greenburg-Smith
impingers, the first modified, the second standard, each
containing 100-ml of distilled water; an empty modified
Greenburg-Smith, impinger serving as a dry trap; a modifi-
ed Greenburg-Smith impinger containing approximately 300
grams of silica gel; a leakless pump with vacuum gauge;
a calibrated dry gas meter equipped with bimetallic
inlet and outlet thermometers; and, a calibrated orifice-
type flowmeter connected to an inclined 0 to 10-inch
water gauge manometer.
The impinger trains were immersed in ice baths to
maintain the temperature in the last impinger at 70F or
less. All sampling train glassware was connected by
ground joints, sealed with stopcock grease, and clamped
to prevent leakage.
- 37 -
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00
i
>1
Iron/constantan thermocoup.
fr
p—-,
Heated
glass
probe
S-type Pitot
tube
Inclined
manometer
Inclined
manometer
-Heated 110-mm glass-fiber filter
•Thermometer
y Refer to figure caption I
i ^. below I
100-ml
distilled
water
Thermometers
Dry 200-300 grams
trap silica gel
valve
Vacuum
gauge
Vacuum
pump
Figure 5,1. Particulate sampling train. A Teflon*5' extension was used, for
the bottom and dryer stack sampling locations.
-------
The sampling train was checked for leaks before
each sample run in accordance with the requirement
that the initial leak rate shall not exceed 0.02 cubic
feet per minute at 15-inches of mercury vacuum.
During the course of testing, the probe, thermo-
couple, and pitot tube assembly was moved to each sampling
point, the velocity pressures and stack gas temperature
were measured, and isokinetic sampling rates were
adjusted accordingly, using an orifice meter to indicate
instantaneous flowrates. Throughout the test, the filter
temperature was maintained at 250+25F.
Upon the conclusion of each particulate run, the
sampling train was again leak tested in accordance with
the requirement that the leak rate cannot exceed 0.02
cubic feet per minute at the greatest vacuum incurred
during the run.
Following the leak check, each sampling train was
transferred to a clean-up area. The volumes of the
itnpinger contents were measured and volume increases
recorded. The solutions were placed in glass (or
polyethylene) sample bottles with Teflon^-lined caps.
The silica gel was weighed to determine the weight gain
(as condensate). The glass fiber filter was returned
to its original plastic petri dish and sealed. The probe,
nozzle, and front-half of the glass-filter holder were
rinsed and brushed with acetone. These rinsings were
- 39 -
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collected in separate glass sample bottles with Teflon®-
lined caps. The Teflon® tubing, the back-half of the
glass—filter holder, and the impinger assembly were
initially rinsed with water, and placed in the same
sample bottle as the impinger contents. These same
components were then rinsed with acetone and placed in
separate glass sample bottles with Teflon®-lined caps.
Thus, four fractions were collected for each particulate
sample:
(1) acetone rinsings of probe, nozzle, and
front-half of the glass-filter holder;
(2) 110-mm type A glass-fiber filter;
(3) impinger contents and distilled water
rinsings; and,
(4) acetone rinsings of the Teflon®
extension, back-half of the glass-
filter holder, impingers, and inter-
connecting glassware.
Filterable particulate was the sum of Fractions 1 and 2,
and total particulate the sum of Fractions 1, 2, 3, and 4,
The particulate weights, by fraction, are presented in
Appendix G.
In the laboratory, the liquid fractions were
measured volumetrically and transferred to tared
beakers. Fraction 3 was then evaporated to residue at
105C and the particulate weight determined. Fractions
1 and 4 were evaporated at room temperature and weighed
until constant. Fraction 2 was desiccated at room
- 40 -
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temperature and weighed until constant. All weight
determinations were performed on an analytical balance
having a sensitivity of 0.1 milligrams.
ORSAT ANALYSIS
Simultaneously with each particulate sample run
at the north and south kiln locations,integrated exhaust
gas samples were withdrawn in accordance with EPA Method
3. The gas sample was extracted by a pump through a
probe, tubing, and condenser to a three-cubic-foot
Tedlar®bag. Exhaust gas gradually filled the bag at a
controlled flowrate during the run. At the end of each
run, an aliquot of the gas in the bag was passed through
an Orsat apparatus which measured the concentrations of
carbon dioxide, oxygen, and carbon monoxide. Volume
decreases were noted after each gaseous component was
selectively absorbed from the aliquot sample. These
results were used to calculate the specific gravity of
the exhaust gas relative to dry air.
VISIBLE EMISSIONS
Visible emissions were recorded for the duration of
each sample run on the north and south kiln stacks.
Each of these observations was performed in accordance
with EPA Method 9 by a certified observer of visible
emissions. Visible emissions were not recorded for the
- 41 -
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bottom kiln and dryer stacks since neither source
involved combustion. In addition, the dryer exhaust
plume was mostly steam.
SULFUR OXIDES
Sulfur oxides emissions were measured at each
location in accordance with EPA Method 6. The sampling
train (Figure 5.2) consisted of a heated stainless steel
probe; Teflon® tubing; four midget impingers connected in
series and immersed in an ice bath, the first impinger
containing 15-ml of 80-percent isopropanol, the second
and third each containing 15-ml of 3-percent hydrogen
peroxide, and the fourth, dry; a limiting orifice; a
vacuum pump; and a dry gas meter. A glass wool plug
inserted in the glass impinger connector separated the
first and second impingers.
Sampling was conducted at approximately one-liter
per minute for 20-minutes. A leak check was performed
before and after each test as per procedures outlined
in "An Alternative Method for Stack Gas Moisture
Determination", US EPA, August, 1978. Following the -
leak test, the sampling train was purged with ambient
air for 15-minutes. After the purge, the hydrogen
peroxide was transferred along with distilled water
rinses to polyethylene sample bottles.
- 42 -
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Stack wall
Glass wool
Heated stainless plug
_J steel probe
Thermometer
Glass
woo 1
80% 37° hydrogen
isopropanol peroxide
Dry
trap
Inclined
manometer
Fine
valve
Vacuum
pump
Vacuum
gauge
Coarse
valve
Figure 5.2. Sulfur oxides sampling train..
-------
In the laboratory, the hydrogen peroxide solution
was diluted to 100-ml with distilled water. A 20-ml
aliquot was then combined with 80-ml of 100-percent
isopropanol and two to four drops of thorin indicator
This solution was then titrated with barium perchlorate
to a pink endpoint and the results reported as sulfur
dioxide.
NITROGEN OXIDES
Nitrogen oxides were measured at each location in
accordance with EPA Method 7. The sampling train
(Figure 5.3.) consisted of a stainless steel probe,
polyvinyl chloride tubing, a three-way stopcock, and a
gas collection flask. A 25-ml quantity of 0.02-percent
hydrogen peroxide and 0.03-percent sulfuric acid reagent
was added to each flask.
The glass collection flask was then evacuated with
a vacuum pump capable of drawing a vacuum to within
3-inches of absolute barometric pressure. The three-way
stopcock was opened until a vacuum gauge, placed in-line
between the stopcocks, indicated a vacuum of approximately
27-inches of mercury within the flask. The stopcock was
closed, the pump was turned off, the vacuum was observed
for one minute to assure there was no leakage into the
flask, and the flask vacuum was recorded. The stopcock
was then closed and the evacuated flask was connected
via tubing to the probe located in the gas stream.
- 44 -
-------
Stack
wa 11
Stainless
steel
probe
PVC
tubing
Pump
va Ive
Flask
Glass wool plug
Sample flask
Flask shield
ab so rbing
solution
Vacuum
pump
Figure 5.3. Nitrogen oxides sampling train.
-------
After the sampling line was purged with stack gas,
the stopcock was opened to allow the exhaust gas to
fill the evacuated flask. Upon reaching equilibrium,
the stopcock was closed. After the exhaust gas sample
was collected, the flask was shaken for five minutes and
the reagent was allowed to remain in contact with the gas
sample for approximately 24-hours to absorb the desired
gas fractions.
At the end of the absorbing period, the flask was
again shaken and the pressure of the gas sample was
measured by connecting a U-tube mercury manometer to the
stoppered flask. After recording the final flask pressure
and temperature, the sample solution was rinsed from the
flask with two 5-ml portions of distilled water and
transferred to a polyethylene bottle. This solution was
then made basic with 1.0 N sodium hydroxide and sealed
for transport to the laboratory.
In the laboratory, the sample solution was trans-
ferred to a tared beaker and evaporated to dryness in
an oven at 105 C. The dried residue was treated
successively with phenoldisulfonic acid solution,
distilled water, and sulfuric acid. The resulting
solution was made basic by the dropwise addition of
ammonium hydroxide, transferred to a volumetric flask,
and diluted to volume with distilled water. The
absorbance of the solution at 420 nanometers was measured,
and the concentration of nitrogen oxides, expressed as
- 46 -
-------
nitrogen dioxide, was determined by reference to a
calibration curve prepared from potassium nitrate
s tandards.
PARTICLE SIZE
Particle sizing tests were conducted at all four
sampling locations. A single 60-minute isokinetic
cascade impactor sample was obtained from the dryer and
bottom kiln stacks during Condition 1. One 30-minute
sample, during each of Conditions 1 and 2, was obtained
from the north and south kiln stacks; Figure 5.4 depicts
the particle sizing sampling train. The sample was with-
drawn from a single point which represented the average gas
velocity profile of the stack. The impactor was calibrated
by the manufacturer for unit particle densities of 1 g/cc
with constant shape and size.
During the test, particles with equivalent aero-
dynamic diameters were collected on each stage of the
impactor at an optimal flowrate of approximately 0.75
acfm. The impactor system was leak checked before the
sample run at 5-inches of mercury vacuum to insure a
leak rate less then 0.02 cfm.
Each stage of the impactor was transferred
with acetone or distilled water rinses into
glass sample bottles. Additionally, glass-fiber filters
associated with stages 1-7, plus the back-up stage were
transferred to their original petri dishes.
- 47 -
-------
co
Stack
wall
Heated probe
3DO
Heated
particle
sizing
impactor
S-type Pitot tube
Inclined
^manometer
Thermometers
Inclined
manometer
Silica
gel
Fine
valve
vacuum
'pump
Coarse
valve
Figure 5.4. Particle sizing sampling train,
-------
In the laboratory, gravimetric analysis was
determined for each fraction in an identical manner
as corresponding fractions from the particulate runs.
The percentage of the total weight gain was determined
for each stage.
CLAY SAMPLES
In conjunction with the Energy and Environmental
Analysis Inc. Project Manager, samples of the extruded
clay brick were obtained at the exit of the dryer, before
entering the kiln, for sulfur content determination. One
brick was removed from each car as it left the dryer
to represent those contained within the kiln during
the sulfur oxides tests. Chips of approximately
equal size were acquired from each brick to form a com-
posite sample.
The brick composite was analyzed by Surface Analysis
and Research, Inc. for percent sulfur by weight.
Sulfur was determined by the quantitative energy
dispersion X-ray spectrographic method. In this
procedure, the brick material was bombarded with
electrons to induce X-ray emissions. These X-rays
were measured with an X-ray spectrometer and compared
to the spectra generated by sulfur standards to
quantitate the sulfur in the sample.
COAL SAMPLES
At the beginning, middle, and end of each particulate
run, pulverized coal grab samples were obtained to form a
- 49 -
-------
composite sample from a Swindell air slide coal distributor
above the kiln. The coal samples were collected in plastic
containers. These coal samples were analyzed for
percent ash and sulfur by weight. Ash content
was determined in accordance with ASTM Method D3174.
Sulfur content was determined by Surface Analysis and
Research, Inc. in accordance with the quantitative energy
dispersion X-ray spectrographic method. Appendix H
contains the analytical results reported by Surface
Analysis and Research, Inc.
- 50 -
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