&EPA
           United States
           Environmental Protection
           Agency
          Office of Air Quality
          Planning and Standards
          Research Triangle Park NC 27711
EMB Report 80-LWA-3
           Air
Lightweight Aggregate
Industry
(Clay, Shale, and Slate)

Emission Test Report
Texas Industries, Inc.
Clodine, Texas

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            0 EMISSION TEST REPORT °

       METHOD DEVELOPMENT AND TESTING FOR
   CLAY, SHALE, AND SLATE AGGREGATE INDUSTRY:
             Texas Industries, Inc.
                 Clodine, Texas
                   ESED 80/12
                     By
          PEDCo Environmental, Inc.
             11499 Chester Road
           Cincinnati, Ohio  45246
           Contract No. 68-02-3546
            Work Assignment No. 1
                   PN 3530-1
              EPA Task Manager

                 Frank Clay
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
         EMISSION MEASUREMENT BRANCH
 EMISSION STANDARDS AND ENGINEERING DIVISION
RESEARCH TRIANGLE PARK, NORTH CAROLINA  27711


                  May 1981

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                           CONTENTS
Figures                                                       iv
Tables                                                         v
Quality Assurance Element Finder
 1.  Introduction                                           1-1

 2.  Process Operation                                      2-1

 3.  Summary of Results                                     3-1

          Rotary kiln exhaust-scrubber                      3-1
          Clinker cooler exhaust-fabric filter              3-14
          Process samples                                   3-29
          Fugitive emissions from the kiln                  3-31

 4.  Sample Locations and Test Methods Used                 4-1

          Kiln exhaust scrubber outlet                      4-1
          Clinker cooler fabric filter inlet                4-4
          Clinker cooler fabric filter outlet               4-4
          Velocity and gas temperature                      4-7
          Molecular weight                                  4-7
          Particulate                                       4-7
          Sulfur dioxide                                    4-8
          Nitrogen oxides                                   4-9
          Particle size distribution                        4-9
          Process samples                                   4-n
          Volatile organic carbon sampling        '          4-11

 5.  Quality Assurance                                      5-1

 6.  Discussion of Results                                  6-1

 References                                                 R-l
                               11

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Appendix A




Appendix B




Appendix C




Appendix D




Appendix E




Appendix F




Appendix G
      CONTENTS (continued)






                                             Page



Computer printout and example calculation    A-l



Raw field data                               B-l



Raw laboratory data                          C-l



Sampling and analytical procedures           D-l



Calibration procedures and results           E-l



Quality assurance summary                    F-l




Project participants and sampling log        G-l
                                111

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                             FIGURES

Number                                                      Paqe
3.1-1     Particle Size Distribution - Kiln Exhaust
           Scrubber Outlet                                  3-7

3.2-1     Particle Size Distribution - Clinker Cooler
           Exhaust - Fabric Filter Inlet                    3-21

3.2-2     Particle Size Distribution - Clinker Cooler
           Exhaust - Fabric Filter Outlet                   3-22

 4-1      Process Flow Sheet                                4-2

4.1-1     Kiln Exhaust Scrubber Outlet                      4-3

4.2-1     Clinker Cooler Fabric Filter Inlet                4-5

4.3-1     Clinker Cooler Fabric Filter Outlet               4-6

4.9-1     Particle Size Sampling Points for Circular
           Stack                                            4-10

 5-1      Example Meter Box Audit Calculation               5-5

 5-2      Example Meter Box Audit Calculation               5-6

 5-3      Example Meter Box Audit Calculation               5-7
                               IV

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                             TABLES

Number                                                      Page

3.1-1     Summary of Flue Gas Conditions - Kiln Exhaust     3-3

3.1-2     Summary of Particulate Emission Data - Kiln
           Exhaust                                          3-4

3.1-3     Summary of Sulfur Dioxide Results- Kiln
           Exhaust                                          3-9

3.1-4     Summary of Nitrogen Oxide Emission Data - Kiln
           Exhaust                                          3-11

3.1-5     Summary of Visible Emissions Data - Kiln
           Exhaust                                          3-13

3.2-1     Summary of Flue Gas Conditions - Clinker Cooler
           Fabric Filter Inlet                              3-15

3.2-2     Summary of Flue Gas Conditions - Fabric Filter
           Outlet                                           3-16

3.2-3     Summary of Particulate Emission Data - Fabric
           Filter Inlet                                     3-17

3.2-4     Summary of Particulate Emission Data - Fabric
           Filter Outlet                                    3-18

3.2-5     Summary of Visible Emissions Data - Clinker
           Cooler Exhaust                                   3-24

3.2-6     Summary of Sulfur Dioxide Results - Fabric
           Filter Inlet                                     3-25

3.2-7     Summary of Nitrogen Oxide Results - Fabric
           Filter Outlet                                    3-27

3.2-8     VOC Monitoring Data - Fabric Filter Outlet.        3-28

3.3-1     Summary of Process Sample Analysis                3-30

3.3-2     Summary of Trace Metal Analysis                   3-32
                                v

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                       TABLES (continued)



Number                                                      Page



5-1       Particulate Equipment Calibration Summary          5-3



5-2       Example Blank Filter and Reagent Analysis          5-8



5-3       Audit Report - S02 Analysis                        5-9



5-4       Audit Report - NO  Analysis                        5-10
                           JC
                               VI

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                QUALITY ASSURANCE ELEMENT FINDER
Title page

Table of contents

Project description

QA objective for measurement of data in
terms of precision, accuracy, completeness,
representativeness, and comparability

Sampling procedures

Sample custody

Calibration procedures and frequency

Analytical procedures

Data reduction, validation, and
reporting

Internal quality control checks and
frequency

Performance and system audits and
frequency

Preventive maintenance procedures and
schedules

Specific routine procedures used to
assess data precision, accuracy, and
completeness of specific measurement
parameters involved

Corrective action

Quality assurance reports to management
                                                       Location
                                                  Section    Page
             11

    1       1-1



Appendix F  F-2

Appendix D  D-l

Appendix C  C-l

Appendix E  E-l

Appendix D  D-l


Appendix F  F-2


Appendix F  F-5


Appendix F  F-3


Appendix F  F-6
Appendix F  F-4

Appendix F  F-5

Appendix F  F-6
                               VII

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                            SECTION 1

                          INTRODUCTION


     During the week of February 22, 1981, PEDCo Environmental

personnel conducted an emission sampling program at Texas Indus-

tries, Inc., (TXI)  lightweight aggregate facility located in

Clodine, Texas.  The purpose of this test program was to provide

data to assess the need for New Source Performance Standards

(NSPS) emission limits for selected processes in the lightweight

aggregate industry and, if warranted, to develop such limits.

     This plant was selected for testing for the following rea-

sons :

     1.   The plant is one of the best controlled coal-fired
          lightweight aggregate plants that use wet scrubbers,
          dry cyclones, and fabric filters for emissions control;
          and

     2.   The arrangement of pollution control devices on process
          equipment appears to be representative of future plants,

     Comprehensive testing was conducted on two specific sources

detailed below:

     0    Coal-fired rotary kiln (No. 3) whose emissions are
          controlled by a medium-energy wet scrubber and,

     0    Reciprocating grate clinker cooler whose emissions are
          controlled by a dry multicyclone and a fabric filter.

     Particulate concentrations and mass emission rates were

measured at the final exit stack serving the kiln and at the

inlet to and outlet from the fabric filter serving the clinker

                               1-1

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cooler by U.S. Environmental Protection Agency (EPA) Method 5.*



Flue gas flow rates, temperature, moisture content, and composi-



tion [oxygen  (0-), carbon dioxide (CO-)/ and carbon monoxide



(CO)] were measured in conjunction with the particulate tests.



Sulfur dioxide (SO-) concentrations and mass emission rates were



measured at the inlet to and outlet from the wet scrubber serving



the kiln and at the inlet to the fabric filter serving the



clinker cooler by EPA Method 6.*  Nitrogen oxides  (NO ) concen-
                                                     J\


tration in the flue gas exiting the scrubber and the fabric



filter was also determined by EPA Method 7.*  In addition, the



particle size distribution of particulate matter exiting the kiln



scrubber and the clinker cooler was determined.  Volatile organic



carbon (VOC) content of the exit gas from the kiln and clinker



cooler control devices was determined using a continuous hydro-



carbon monitor with a flame ionization detector  (FID).  Visible



emission observations were made on each exit stack during the



particulate tests by EPA Method 9.*  Additionally, a visible



determination of fugitive dust emissions from the kiln seals  (raw



charge and product charge) was made during each particulate test



by proposed EPA Method 22.**



     Representative samples of the kiln feed material  (clay) and



coal used to fire the kiln were collected during each particulate



test for determination of sulfur content, moisture, density, and



ash content (coal only).  In addition, composite samples of the
 *

  40 CFR 60, Appendix A, Reference Methods 5, 6, 7, and 9, July 1,

  1980.

**

  45 FR, pp. 76426-9.



                               1-2

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coal and clay were analyzed for trace metal content.  Samples of



the scrubber water effluent and final aggregate product were also



collected for trace metal and sulfate analyses.



     Messrs. Jeff Shuler, Rick Cooper, and Lalit Banker [Midwest



Research Insitute (MRI)] monitored process operation and col-



lected process samples throughout the test period.  Mr. Jay



Lindholm, TXI, observed the test program and assisted in process



sample collection.
                              1-3

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                            SECTION 2



                        PROCESS OPERATION






     The TXI plant in Clodine, Texas, operates three kiln lines



for clay aggregate production.  Testing was conducted on the



newest process line, Kiln No. 3, and its associated pollution



control equipment.



     The kiln process is continuous and operates 24 hours per



day, 7 days per week, except for required maintenance periods.



The kiln can be fired with either natural gas or pulverized coal.



All tests were conducted while the kiln was burning coal.



     Exhaust gases from the feed end of the kiln are treated in a



low energy wet scrubber (W.W. Sly Impinjet) to remove particu-



late.



     The other major process equipment on this line is a recipro-



cating grate clinker cooler.  Clinker cooler emissions are con-



trolled by a multicyclone dust collector followed by a fabric



filter.



     Specific production data and coal consumption figures are



maintained in a confidential file in the office of the Emission



Standards and Engineering Division, U.S. EPA.  Process data were



collected by personnel from MRI.
                               2-1

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                            SECTION 3



                       SUMMARY OF RESULTS






     This section details results obtained from the emission



sampling program.  All emission samples and plume observation



(visible emission) data were collected simultaneously from the



kiln and clinker cooler sources.  Results are reported separately



for each source.



     Example calculations are contained in Appendix A.  Raw field



and laboratory data sheets are contained in Appendices B and C.



Appendix D details the sampling and analytical procedures used



during this test program.  Equipment calibration procedures and



results are contained in Appendix E.  Appendix F addresses



quality assurance considerations pertinent to this test project.



A list of project participants is given in Appendix G.






3.1  ROTARY KILN EXHAUST



     Particulate and particle size tests were conducted on the



kiln exhaust scrubber exit stack.  Visible emission observations



were also performed during each particulate test.  In addition,



S02 tests were simultaneously conducted before and after the wet



scrubber.  NO  tests were conducted concurrently with the SO-
             ji                                              &



tests on the scrubber exit stack.  Tests were also conducted to




determine the VOC content of the exit gas stream.





                               3-1

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     Particulate sampling and analytical procedures followed



those described in EPA Method 5 of the Federal Register* except



that an ether-chloroform extraction was performed on the impinger



contents to determine condensible organic and inorganic frac-



tions.  Particle size sampling and analytical procedures followed



those described in "Procedures Manual for Inhalable Particulate



Sampler Operation" recently developed for EPA by Southern Re-



search Institute.   S02 sampling and analytical procedures



followed those described in EPA Method 6* except that large



impingers were used instead of the midget impingers described in



Method 6.  NO  sampling and analytical procedures followed those
             A.


described in EPA Method 7.*  Visible emission observations were



conducted using procedures described in EPA Method 9 of the



Federal Register.*  VOC content was determined using an FID.



3.1.1  Flue Gas Conditions and Particulate Emissions



     Summaries of the measured flue gas and particulate emission



data are presented in Tables 3.1-1 and 3.1-2.  Volumetric flow



rates are expressed in actual cubic meters per hour (acmh) and



actual cubic feet per hour (acfh) at stack conditions.  Flow



rates corrected to standard conditions [20°C and 760 mm Hg  (68°F



and 29.92 in.Hg) and 0% moisture] are expressed as dry standard



cubic meters per hour (dscmh) and dry standard cubic feet per



hour  (dscfh).  Particulate concentrations are reported in milli-



grams per dry standard cubic meter (mg/dscm) and grains per dry



standard cubic foot (gr/dscf).  Emission rates are expressed in



kilograms per hour (kg/h) and pounds per hour (Ib/h).  The
 40 CFR 60, Appendix A, Reference Methods 5, 6, 7, and 9, July 1,

 1980.

                               3-2

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                                  TABLE 3.1-1.  SUMMARY OF FLUE GAS CONDITIONS
                                          KILN EXHAUST SCRUBBER OUTLET
Run
No.
SOM5-1
SOM5-2
SOM5-3
Date
(1981)
2/23
2/23
2/24
Average
Volumetric flow rate
Actual3
acmh
51 ,487
52,212
52,262
51 ,987
acfh
1,818,251
1,843,829
1,845,611
1,835,897
Standard
dscmh
35,873
37,296
35,222
36,130
dscfh
V, 266, 836
1,317,104
1,243,849
1,275,930
Temperature
°C
78
78
81
79
°F
172
173
178
174
Moisture
%
17.5
15.2
19.3
17.3
°2'
%^
15.2
15.8
15.2
15.4
co7,
5T
4.0
3.8
4.0
3.9
CO,
%
0.0
0.0
0.0
0.0
tJ
I
        Volumetric flow rate in actual cubic meters per hour (acmh)  and actual  cubic  feet per hour (acfh)  at
        stack conditions.

        Volumetric flow rate in dry standard cubic meters  per hour (dscmh)  and  dry standard  cubic  feet per hour
        (dscfh):   Standard conditions = 20°C and 760 mm Hg (68°F and 29.92  in.  Hg.)  and 0% moisture.

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                           TABLE  3.1-2.   SUMMARY  OF  PARTICULATE EMISSIONS DATA
                                      KILN  EXHAUST SCRUBBER OUTLET
Run
No.
SOM5-1
SOM5-2
SOM5-3
Date
(1981)
2/23
2/23
2/24
Average
Concentration
Filterable
mg/dscm
90.3
90.2
108.3
96.3
gr/dscf
0.0395
0.0394
0.0473
0.0421
Condensible
Organic
mg/dscm
1.8
1.9
1.2
1.6
gr/dscf
0.0008
0.0008
0.0005
0.0007
Inorganic
mg/dscm
30.7
28.5
33.9
31.0
gr/dscf
0.0134
0.0124
0.0148
0.0135
Mass emission rate
Filterable
kg/h
3.2
3.4
3.8
3.5
Ib/h
7.1
7.4
8.4
7.6
Condensible
Organic
kg/h
.06
.07
.04
.06
Ib/h
.14
.16
.09
.13
Inorganic
kg/h
1.1
1.1
1.2
1.1
Ib/h
2.4
2.3
2.6
2.4
 Concentration  in  milligrams  per  dry  standard  cubic meter  (mg/dscm) and grains per dry standard cubic
 foot (gr/dscf).

DMass emission  rate  in  kilograms  per  hour  (kg/h) and  pounds per hour  (Ib/h).

-------
product of the concentration and the volumetric flow rate is the




mass emission rate.  The filterable particulate data in Table



3.1-2 represents material collected in the sample probe and on



the filter, both of which were heated to approximately 121°C



(250°F).   The condensible organic and inorganic fractions repre-



sent material that condensed out or was trapped in the impinger



section of the sample train at a temperature of approximately



20°C (68°F).



     The volumetric flow rate averaged 36,100 dscmh  (1,276,000



dscfh)  with an average temperature of 79 °C (174°F).  The moisture



content averaged 17.3 percent; and the oxygen, carbon dioxide,



and carbon monoxide contents average 15.4, 3.9, and  0.0 percent,



respectively.



     Filterable particulate concentration averaged 96 mg/dscm



(0.04 gr/dscf) with a corresponding average mass emission rate of



3.5 kg/h (7.6 Ib/h).  The organic and inorganic concentrations



averaged 1.6 mg/dscm (0.0007 gr/dscf) and 31 mg/dscm  (0.0135 gr/



dscf) with corresponding average mass emission rates of 0.06 kg/h



(0.13 Ib/h) and 1.1 kg/h (2.4 Ib/h).



     It should be noted that there was a longitudinal crack in



the stack wall approximately 0.9 m (3 ft) in length, located



approximately 2m  (6 to 8 ft) upstream of the sampling ports.



Duct tape was used to seal the crack prior to testing.  This



crack probably caused some in-leakage of ambient air.  However,



it is felt that this caused no bias in the emission  results.
                                3-5

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3.1.2  Particle Size Distribution


     A total of five particle size samples were collected from


the scrubber outlet during the particulate test runs.  The first


test was a preliminary run and is not considered representative;


therefore, it is not included in the overall data averages.


Sampling and analytical procedures followed those described in


"Procedures Manual for Inhalable Particulate Sampler Operation,"


developed by Southern Research Institute  (SRI) for EPA.   Data


obtained from the particulate test runs were combined with


sampling data to obtain the moisture content and gas composition


in order to determine the flow rate of the stack gas through the


impactor.


     Data were reduced by computer programs in "A Computer-Based


Cascade Impactor Data Reduction System," developed by SRI for

    2
EPA.   Individual computer printouts for each test are contained


in Appendix A of this report.


     Figure 3.1-1 presents the average distribution curve for the


set of four samples collected.  Individual data points for each


test were plotted manually.  The distribution curve was plotted


manually and represents the best-fit average curve for the speci-


fied number of test runs.  All particle size results are based on


aerodynamic diameters and unit density (1 g/cm^).  The data point


distribution for these runs indicate that 50 percent of the


particles by weight  (cut size) were less than 2.1 microns in


diameter.  The calculated mass grain loading averaged 106 mg/dscm


(0.046 gr/dscf) which compares favorably with the mass loading


obtained from the particulate tests.


                              3-6

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                                                                         SOPS-2 •
                                                                         SOPS-3 o
                                                                         SOPS-4 *
                                                                         SOPS-5 •
                                PARTICLE SIZE, microns
Figure  3.1-1.  Particle size distribution,  kiln exhaust  scrubber outlet.

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3.1.3  Sulfur Dioxide



     Table 3.1-3 presents a summary of results for S02 tests con-



ducted simultaneously before and after the wet scrubber.  Concen-



trations are reported in parts per million by volume  (ppm), mil-



ligrams per dry standard cubic meter  (mg/dscm), and pounds per



dry standard cubic foot  (Ib/dscf).  Mass emission rates are



reported in kilograms per hour (kg/h) and pounds per hour (Ib/h).



The outlet mass emission rates were calculated from the measured



concentrations and the average outlet flow rate measured during



the particulate test runs [36,130 dscmh  ( 1,275,930 dscfh)].



The inlet mass emission rates were calculated from the measured



concentrations and the average outlet flow rate corrected for



excess air for each individual SO2 test run.  Analysis was con-



ducted on site by EPA Method 6.*



     Sulfur dioxide concentration at the inlet to the wet scrub-



ber averaged 724 mg/dscm (275 ppm; 4.52 x 10   Ib/dscf) with a



corresponding average mass emission rate of 21.0 kg/h  (46.3



Ib/h).  Run SIM6-6 is considered an outlier and is not included



in the overall data averages.  Flue gas temperature averaged



338°C (640°F) with an average oxygen content of 15.1 percent.



     Sulfur dioxide concentrations at the scrubber exit stack



averaged 511 mg/dscm (194 ppm; 3.19 x 10   Ib/dscf) with a cor-



responding average mass emission rate of 18.5 kg/h  (40.7 Ib/h).



Flue gas temperature averaged 77°C (170°F).  Oxygen content aver-



aged 16.2 percent.
 40 CFR 60, Appendix A, Reference Method 6, July 1, 1980.





                               3-8

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                                  TABLE 3.1-3.  SUMMARY OF SULFUR DIOXIDE DATA
Run
No.
SIM6-1
SIM6-2
Date
(1981)
2/26
2/26
Sample
location
Kiln exhaust scrubber
inlet
Average
SIM6-3
SIM6-4
2/26
2/26
Kiln exhaust scrubber
inlet
Average
SIM6-5
SIM6-6
2/26
2/26
Kiln exhaust scrubber
inlet
Average
SOM6-1
SOM6-2
2/26
2/26
Kiln exhaust scrubber
outlet3
Average
SOM6-3
SOM6-4
2/26
2/26
Kiln exhaust scrubber
out! eta
Average
SOM6-5
SOM6-6
2/26
2/26
Kiln exhaust scrubber
outlets
Average
Concentration
ppm
273
286
280
299
267
283
251
88*
251
183
194
189
214
185
200
186
204
195
mg/dscm
718
753
736
785
702
744
660
231*
660
481
509
495
562
485
524
.489
537
513
Ib/dscf x 10-^5
4.48
4.70
4.59
4.90
4.38
4.64
4.12
1.44*
4.12
3.00
3.18
3.09
3.51
3.03
3.27
3.05
3.35
3.20
Mass
emission rate
kg/h
19.9
19.8
19.9
24.3
21.7
23.0
19.2
6.7*
19.2
17.4
18.4
17.9
20.3
17.5
18.9
17.7
19.4
18.6
Ib/h
43.9
43.7
43.8
53.6
48.0
50.8
42.2
14.7*
42.2
38.3
40.5
39.4
44.8
38.7
41.8
38.9
42.8
40.9
0?,
%
15.3
15.0
15.2
15.3
15.3
15.3
14.8
14.8
14.8
16.6
16.6
16.6
16.1
16.1
16.1
16.0
16.0
16.0
Temperature
°C
338
338
338
338
338
338
338
338
338
77
77
77
77
77
77
77
77
77
°F
640
640
640
640
640
640
640
640
640
170
170
170
170
170
170
170
170
170
CO
 I
10
     Mass  emission  rates  in  kilograms  per  hour  (kg/h)  and  pounds  per  hour  (Ib/h)  calculated  using average
     measured  flow  obtained  from  the particulate  tests [36,130 dscmh  (1,275,930 dscfh)].


    *0utlier - not  included  in averages.

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3.1.4  Nitrogen Oxides



     Table 3.1-4 summarizes nitrogen oxides emission data.  Three



tests, each consisting of four grab samples collected at fifteen



minute intervals, were conducted on the kiln exhaust scrubber



outlet.  Concentrations are reported in milligrams per dry



standard cubic meter  (mg/dscm), parts per million by volume



(ppm), and pounds per dry standard cubic foot (Ib/dscf).  Emis-



sion rates are reported in kilograms per hour (kg/h) and pounds



per hour (Ib/h), and were calculated from the average flue gas



flow rate measured during the particulate tests and corrected to



standard conditions [36,130 dscmh (1,275,930 dscfh)].



     Nitrogen oxides concentrations averaged 287 mg/dscm (150


              -4
ppm; 0.18 x 10   Ib/dscf) with a corresponding mass emission rate



of 10.4 kg/h (23 Ib/h).



3.1.5  Volatile Organic Carbon (VOC)



     Hydrocarbon monitoring was conducted at the kiln scrubber



outlet from 13:06 to 14:00 on February 26, 1981.  The detection



range on the continuous FID was set at 0 to 1000 parts per mil-



lion (ppm)  by volume throughout the monitoring period.  Gas



standards of 399.9 ppm and 891 ppm methane were used to calibrate



the monitor.  Zero air containing less than 0.1 ppm total hydro-



carbon was used to set the instrument baseline.



     Some problems occurred during the sampling due to high mois-



ture content of the scrubber outlet system.  Though the sample



line and probe were heated sufficiently to prevent moisture con-



densation,  the internal temperature of the monitor was not high



                               3-10

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            TABLE 3.1-4.   SUMMARY  OF  NITROGEN  OXIDES  EMISSIONS DATA
                         KILN  EXHAUST SCRUBBER OUTLET

Run
No.
1




Date
(1981)
2/26




Sample
No.
SON1A
SON1B
SONIC
SON1D
Average
2



2/26



SON2A
SON2B
SON2C
SON2D
Average
3



2/26



SON3A
SON3B
SON3C
SON3D
Average

Concentration a
ppm
147
172
170
139
157
140
141
151
157
147
158
121
153
150
146
mg/dscm
282
330
325
266
301
268
270
289
300
282
302
231
294
287
279
Ib/dscf x 10-*
0.1758
0.2058
0.2031
0.1661
0.1877
0.1674
0.1683
0.1803
0.1870
0.1758
0.1886
0.1441
0.1832
0.1791
0.1738
Mass u
emission rate
kg/h
10.2
11.9
11.8
9.6
10.9
9.7
9.7
10.4
10.8
10.2
10.9
8.3
10.6
10.4
10.1
Ib/h
22.4
26.3
25.9
21.2
24.0
21.4
21.5
23.0
23.9
22.5
24.1
18.4
23.4
22.9
22.2
 Concentrations  of  NO/  as  N02  in parts per million  (ppm) by volume, milligrams
 per dry standard cubic meter  (mg/dscm), and pounds per dry standard cubic
 foot (Ib/dscf).

3Mass emission rate in  kilograms per  hour (kg/h) and pounds per hour (Ib/h)
 calculated  using average  measured flow obtained from the particulate tests
 [36,130 dscmh  (1,275,930  dscfh)].
                                     3-11

-------
enough to prevent a moisture buildup in the sample rotameter.



This created problems with the hydrogen flame and, subsequently,



only one hour of hydrocarbon monitoring data was obtained.



     During the hour of continuous monitoring, the hydrocarbon



concentrations varied from 140 ppm to 220 ppm with an average



concentration of 175 ppm as methane.  This average concentration



corresponds to an emission rate of 4.2 kg/h (9.3 Ib/h) base:d on



the measured flow rate of 36,130 dscmh (1,275,930 dscfh) and the



molecular weight of methane (16 Ib/lb mole).  As the methane



content was not measured separately, this concentration may



include some methane.  A copy of the strip chart printout for



this test is in Appendix B.



3.1.6  Visible Emissions



     Visible emissions surveys were conducted at the kiln scrub-



ber outlet during each particulate test.   Visible emissions were



read in 6-minute sets throughout each particulate test.  Table



3.1-5 contains a summary of visible emissions for the scrubber



outlet.  Opacities during Test 1 ranged from 0 to 15 percent,



with an average of 5 percent for all sets.  During Test 2,



opacities ranged from 5 to 10 percent, with an average of 8



percent for all sets.  Opacities observed during Test 3 ranged



from 0 to 15 percent, with an average of 3 percent for all sets.



During the fabric filter repeat test opacities ranged from 0



to 10 percent, with an average of 6 percent for all sets.
                               3-12

-------
                TABLE 3.1-5.
SUMMARY OF VISIBLE EMISSIONS DATA
- SCRUBBER OUTLET -
                              February 23,  1981
              Test 1
                         Test 2
Set No.
SOVE-1-1
SOVE-1-2
SOVE-1-3
SOVE-1-4
SOVE-1-5
SOVE-1-6
SOVE-1-7
Time
1030-1035
1049-1054
1107-1112
1124-1129
1144-1149
1206-1211
1225-1230
Average
% opacity
3
5
4
5
5
7
9
Range
0-5
0-10
0-5
5-10
5-10
5-10
5-15
Set No.
SOVE-2-1
SOVE-2-2
SOVE-2-3
SOVE-2-4
SOVE-2-5
SOVE-2-6
SOVE-2-7
Time
1512-1517
1535-1540
1552-1557
1612-1617
1630-1635
1647-1652
1703-1708
Average
% opacity
8
9
9
7
8
10
8
Range
5-10
5-10
5-10
5-10
5-10
10
5-10
              Test 3
                              February 24,  1981
                  Test 4  (Repeat  test)*
SOVE-3-1
SOVE-3-2
SOVE-3-3
SOVE-3-4
SOVE-3-5
SOVE-3-6
SOVE-3-7
0912-0917
0931-0936
0947-0952
1004-1009
1024-1029
1040-1045
1100-1105
0
0
0
2
3
5
10
0
0
0-5
0-5
0-5
0-10
5-15
SOVE-4-1
SOVE-4-2
SOVE-4-3
SOVE-4-4
SOVE-4-5
SOVE-4-6

1345-1350
1402-1407
1421-1426
1440-1445
1500-1505
1520-1525

4
9
9
9
1
1

0-5
5-10
5-10
5-10
0-5
0-5

*Tests repeated on fabric filter after completion  of tests  at scrubber.
 observations continued on scrubber exit stack.
                                           VE
                                     3-13

-------
3.2  CLINKER COOLER EXHAUST



     Particulate and particle size distribution tests were con-



ducted simultaneously at the inlet to and outlet from the Aero-



pulse fabric filter serving the clinker cooler.  Visible emission



observations were made at the fabric filter outlet during each



particulate test.  In addition, sulfur dioxide  (SO,,) tests were



conducted at the fabric filter inlet while nitrogen oxides (NO )
                                                              X


and volatile organic carbon (VOC)  concentrations were measured at



the fabric filter outlet to quantify these emissions.  It should



be noted that during the first day of testing  (2/23), two sets of



particulate tests were run simultaneously at each location.  The



initial outlet test was voided due to an excessive post-test leak



rate while the initial inlet test was acceptable.  The second



inlet test was voided due to an excessive post-test leak rate



while the second outlet test was acceptable.  Therefore, the



initial inlet test and the second outlet test, though not run



simultaneously, are shown as such for data reporting purposes.



     The sample procedures used to perform these tests are



described in Section 3.1 of this report.  Concentration and mass



emission rate data are expressed in units identical to those used



in Section 3.1.



3.2.1  Flue Gas Conditions and Particulate Emissions



     Tables 3.2-1 and 3.2-2 summarize the flue gas conditions



monitored in conjunction with the particulate tests at the fabric



filter inlet and outlet test locations, respectively.  Tables



3.2-3 and 3.2-4 present the particulate emissions data for each



location.

                               3-14

-------
                               TABLE 3.2-1.   SUMMARY OF FLUE GAS  CONDITIONS
                                    CLINKER  COOLER FABRIC FILTER  INLET
Run
No.
BIM5-1
BIM5-3
BIM5-4
Date
(1981)
2/23
2/24
2/24
Average
Volumetric flow rate
Actual9
acmh
37,678
38,627
38,756
38,354
acfh
1,330,578
1,364,079
1,368,664
1,354,440
Standardb
dscmh
29,705
29,383
28,106
29,065
dscfh
1,049,024
1,037,659
992,545
1,026,409
Temperature
°C
98
109
128
112
°F
209
228
263
234
Moisture,
%
<1.0
1.1
1.1
1.0
o2,
r
19.6
20.2
20.3
20.0
co?,
IT
0.0
0.3
0.0
0.1
CO,
%
0.0
0.0
0.0
0.0
Ul
      Volumetric  flow rate  in  actual  cubic meters per hour  (acmh) and actual cubic feet per hour (acfh) at
      stack  conditions.

      Volumetric  flow rate  in  dry standard cubic meters per hour (dscmh) and dry standard cubic feet per hour
      (dscfh):  Standard  conditions  = 20°C and  760 mm Hg  (68°F and 29.92 in.Hg) and 0% moisture.

-------
                                   TABLE 3.2-2.   SUMMARY OF FLUE  GAS CONDITIONS
                                        CLINKER  COOLER FABRIC FILTER OUTLET
Run
No.
BOM5-2
BOMS -3
BOM5-4
Date
(1981)
2/23
2/24
2/24
Average
Volumetric flow rate
Actual3
acmh
46,108
45,895
45,559
45,854
acfh
1,628,217
1,620,754
1,608,881
1,619,284
Standard
dscmh
37,537
36,981
35,693
36,737
dscfh
1,325,599
1,305,979
1,260,476
1,297,351
Temperature
°C
85
90
100
92
°F
185
194
212
197
Moisture,
%
1.1
<1.0
<1.0
<1.0
S"
19.6
20.2
20.3
20.0
C02,
%
0.0
0.3
0.0
0.1
CO,
%
0.0
0.0
0.0
0.0
OJ
      Volumetric flow rate in  actual  cubic  meters  per hour  (acmh)  and  actual  cubic  feet  per  hour  (acfh)  at
      stack conditions.

     'Volumetric flow rate in  dry standard  cubic meters  per hour  (dscmh)  and  dry  standard  cubic feet  per hour
      (dscfh):   Standard  conditions  = 20°C  and  760 mm Hg (68°F and 29.92  in.Hg).

-------
                                  TABLE  3.2-3.   SUMMARY OF  PARTICULATE EMISSIONS
                                        CLINKER  COOLER FABRIC  FILTER INLET
Run
No.
BIM5-1
BIM5-3
BIM5-4
Date
(1981)
2/23
2/24
2/24
Average
Concentration
Filterable
mg/dscm
193.8
172.8
195.2
187.3
gr/dscf
0.0847
0.0755
0.0853
0.0818'
Condensible
Organic
mg/dscm
0.64
0.16
1.50
0.77
gr/dscf
0.0003
0.0001
0.0007
0.0004
Inorganic
mg/dscm
1.17
0.16
0.37
0.57
gr/dscf
0.0005
0.0001
0.0002
0.0003
Mass emission rate
Filterable
kg/h
5.8
5.1
5.5
5.5
Ib/h
12.7
11.2
12.1
12.0
Condensible
Organic
kg/h
0.020
0.005
0.040
0,022
Ib/h
0.04
0.01
0.09
0.05
Inorganic
kg/h
0.030
0.005
0.010
0.015
Ib/h
0.08
0.01
0.02
0.04
CJ


H
-J
    Concentration in milligrams per dry standard cubic meter (mg/dscm) and grains per dry standard cubic foot
     (gr/dscf).

     Mass emission rate in kilograms per hour (kg/h) and pounds per hour (Ib/h).

-------
                                  TABLE 3.2-4.  SUMMARY OF PARTICULATE EMISSIONS
                                        CLINKER COOLER FABRIC FILTER OUTLET
Run
No.
BOM5-2
BOM5-3
BOM5-4
Date
(1981)
2/23
2/24
2/24
Average
Concentration a
Filterable
mg/dscm
6.3
5.7
8.2
6.7
gr/dscf
0.0027
0.0025
0.0036
0.0029
Condensible
Organic
mg/dscm
0.82
2.33
3.40
2.18
gr/dscf
0.0004
0.001
0.0015
0.001
Inorganic
mg/dscm
0.49
0.11
4.87
1.82
gr/dscf
0.0002
<0.0001
0.0021
0.0008
Mass emission rate
Filterable
kg/h
0.23
0.21
0.29
0.24
Ib/h
0.52
0.47
0.64
0.54
Condensible
Orqanic
kg/h
0.03
0.09
0.12
0.08
Ib/h
0.07
0.19
0.27
1.77
Inoraanic
kg/h
0.020
0.004
0.170
0.065
Ib/h
0.040
0.009
0.383
0.144
00
     Concentration in milligrams per dry standard cubic meter (mg/dscm) and grains per dry standard cubic foot
      (gr/dscf).

      Mass emission rate in kilograms per hour (kg/h) and pounds per hour (Ib/h).

-------
     At the fabric filter inlet, the volumetric flow rate aver-



aged 29,100 dscmh (1,026,000 dscfh) with temperature and moisture



contents averaging 112°C (234°F) and 1.0 percent, respectively.



Oxygen and carbon dioxide contents averaged 20.0 and 0.1 percent,



respectively.  Filterable particulate concentration averaged 187



mg/dscm (0.082 gr/dscf)  with a corresponding mass emission rate



of 5.5 kg/h  (12 Ib/h).  The condensible organic and inorganic



concentrations averaged 0.77 mg/dscm (0.0004 gr/dscf) and 0.57



mg/dscm (0.0003 gr/dscf), respectively.  The corresponding mass



emission rates averaged 0.02 kg/h  (0.05 Ib/h) for each fraction.



     At the fabric filter outlet, the volumetric flow rate aver-



aged 36,700 dscmh (1,297,000 dscfh) with temperature and moisture



contents averaging 92°C  (197°F) and less than 1 percent, respec-



tively.  Oxygen and carbon dioxide contents averaged 20.0 a,nd 0.1



percent.  Prior to conducting tests at this location, measure-



ments were obtained to determine the degree of turbulent flow in



the stack as detailed in Method 2 of the Federal Register.*



Each traverse point was checked by aligning the face openings of



the pitot tube perpendicular to the stack cross-sectional plane;



designated "0° reference."  Null (zero) pitot readings obtained



at 0° reference indicated an acceptable flow condition at a given



point.  Several traverse points exhibited unacceptable  (>10°



angular rotation to obtain null reading) flow characteristics.



However, the overall average for all points was less than 10°



indicating an acceptable flow condition existed in the stack.



Turbulent flow conditions of this type would tend to bias the
 40 CFR 60, Appendix A, Reference Method 2, July 1, 1980.



                               3-19

-------
velocity measurements high thus explaining the approximately 20



percent discrepancy in inlet and outlet flow measurements.



Filterable particulate concentration averaged 6.7 mg/dscm (0.003



gr/dscf) with a corresponding mass emission rate of 0.24 kg/h



(0.54 Ib/h).   The condensible organic and inorganic concentra-



tions averaged 2.2 mg/dscm (0.001 gr/dscf) and 1.8 mg/dscm



(0.0008 gr/dscf), respectively.  Organic and inorganic mass



emission rates averaged 0.08 kg/h (1.8 Ib/h) and 0.07 kg/h  (0.14



Ib/h).



     The particulate removal efficiency of the fabric filter



averaged 96.4 percent based on the average inlet and outlet, par-



ticulate concentrations on a mg/dscm basis.



3.2.2  Particle Size Distribution



     A total of five samples each were collected from the fabric



filter inlet and outlet test locations.  The first test at each



site was a preliminary run and is not considered representative;



therefore, it is not included in the overall data averages.  The



sampling and analytical procedures as well as the data reduction



technique are described in Section 3.1.2 and Appendix A of this



report.



     Figures 3.2-1 and 3.2-2 present the distribution curvess for



each set of four samples collected at the inlet and outlet test



locations.  Individual data points for each test were plotted



manually.  The distribution curve was plotted manually and repre-



sents the best-fit average curve for the specified number of test



runs.  All particle size results are based on aerodynamic diam-



eters and unit density (1 g/cm ).



                              3-20

-------
ro
•M

•M


W.I
40

M

to


10


 s


 t

 1




•.1
                    -tt
                                           ill
                                                          i
                                                            tli?
                                                            m
                                                          ia
                                                                          !  i-
                                                                            iU

                                                                                          II
i in
                                                                                                  tBIPS-2  •
                                                                                                  ±BIPS-3  o
                                                                                                  EBIPS-4  •
                                                                                                  ^IPS-5  •
                                                                                                  ^Extrapolate —
                                                                                                                   -*t
                                                 1.0
                                                                 10.0
     Jf~»
     100
                                                          PARTICLE SIZE, microns
                                    Figure  3.2-1.   Particle size distribution, fabric filter  inlet.

-------
I
N)
to
                                                                                                        -: = _+1
                                                                                                           -+t
                                                                                                           	1
                                                                                                       SJ--»
                                                                                                          100
                                                      PARTICLE SIZE, microns
                                Figure 3.2-2.  Particle size distribution,  fabric filter  outlet.

-------
     Samples BIPS-2 through 5 were collected at the fabric filter



inlet.  The data point distribution for these runs indicate most



of the particles were less than 15 microns in diameter.  Samples



BOPS-2 through 5 were collected at the fabric filter outlet.  The



data point distribution for these runs is somewhat distorted due



to the extremely low particulate grain loading encountered at



this site.  Tests were conducted for ninety minutes with an



average impactor catch of approximately 3-5 mg total.  Approxi-



mately 80 percent of the total catch was recovered from the



acetone rinse of the nozzle and the remaining fraction was dis-



tributed primarily between the third and sixth stages of the



impactor.  The cut points for these stages range from 6 microns



for stage 3 to 1 micron for stage 6.  The results from this



particle size data are misleading due to the very low catches on



the individual stages of the impactor.  The distribution shown



in Figure 3.2-2 indicate that the typical descriptor of means



diameter is inappropriate.  Most of the particles at the outlet



of the fabric filter were less than 6 microns.



3.2.3  Fabric Filter Visible Emissions



     Visible emissions surveys were conducted at the fabric fil-



ter outlet during each particulate test.  Visible emissions were



read in six-minute sets throughout each test.  Table 3.2-5 con-



tains a summary of visible emissions data.  No visible emissions



could be detected by the observer during the testing period.



3.2.4  Sulfur Dioxide



     Table 3.2-6 presents a summary of results for SO? tests con-




ducted at the fabric filter inlet.  For each test, the SO~



                              3-23

-------
               TABLE 3.2-5.   SUMMARY OF VISIBLE EMISSIONS DATA
                   - CLINKER COOLER FABRIC FILTER OUTLET -
                             February 23,  1981
             Test 1
      Test  2
Set No.
BOVE-1-1
BOVE-1-2
BOVE-1-3
BOVE-1-4
BOVE-1-5
BOVE-1-6
BOVE-1-7
BOVE-1-8
Time
1019-1024
1040-1045
1058-1103
1115-1120
1134-1139
1156-1201
1215-1220
1234-1239
Average
% opacity
0*
0
0
0
0
0
0
0
Range
0*
0
0
0
0
0
0
0
Set No.
BOVE-2-1
BOVE-2-2
BOVE-2-3
BOVE-2-4
BOVE-2-5
BOVE-2-6


Time
1525-1530
1544-1549
1601-1606
1621-1626
1639-1644
1655-1700


Average
% opacity
0*
0
0
0
0
0


Range
0*
0
0
0
0
0


             Test 3
                             February 24,  1981
Test 4 (Repeat test)
BOVE-3-1
BOVE-3-2
BOVE-3-3
BOVE-3-4
BOVE-3-5
BOVE-3-6
BOVE-3-7
0921-1026
0939-0944
0955-1000
1013-1018
1037-1042
1050-1055
1109-1114
0*
0
0
0
0
0
0
0*
0
0
0
0
0
0
BOVE-4-1
BOVE-4-2
BOVE-4-3
BOVE-4-4
BOVE-4-5
BOVE-4-6

1335-1340
1352-1357
1411-1416
1430-1435
1450-1455
1509-1514

0*
0
0
0
0
0

0*
0
0
0
0
0

The zero percent opacity indicates that no visible emissions were observed
by the certified observer.
                                   3-24

-------
               TABLE 3.2-6.   SUMMARY  OF  SULFUR DIOXIDE RESULTS
                     CLINKER COOLER FABRIC  FILTER  INLET
Run
No.
BIM6-1
BIM6-2
Average
BIM6-3
BIM6-4
Average
BIM6-5
BIM6-6
Date
(1981)
2/26
2/26

2/26
2/26

2/26
2/26
Average
Concentration *
ppm
<1
<1
<1
<1
<1
<1
<1
<1
<1
mg/dscm
0.0
0.0
0.0
0.0
0.0
0,0
0.0
0.0
0.0
Ib/dscf x TO-5
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
Mass
emission rate
kg/h
0.0
0.0
0,0
0.0
0.0
0.0
0.0
0.0
0.0
Ib/h
0-0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
02,
%
20.5
20.5
20.5
20.5
20.5
20.5
20.5
20.5
20.5
Temperature
°C
99
99
99
99
99
99
99
99
99
°F
210
210
210
210
210
210
210
210
210
Below minimum detectable limit.
                                     3-25

-------
concentration averaged less than 1 part per million by volume




which is below the minimum detectable limit of the analytical



method.*



3.2.5  Nitrogen Oxides



     Table 3.2-7 summarizes the NO  emission data collected from
                                  J\.


the fabric filter outlet.  A total of four grab samples were col-



lected to quantify these emissions.  The NO  concentration aver-
                                           JC


aged 2.5 ppm (4.8 mg/dscm) with a corresponding average mass



emission rate of 1.8 kg/h (0.4 Ib/h) based on the measured



concentrations and average volumetric flow rate monitored during



the particulate tests  [36,737 dscmh  (1,297,351 dscfh)].



3.2.6  Volatile Organic Carbon (VOC)



     Hydrocarbon monitoring was conducted at the baghouse outlet



from 12:03 to 15:58 on February 24, 1981.  The detection range on



the monitor was set at 0 to 50 parts per million throughout the



monitoring period.  A gas standard of 40.4 ppm methane in hydro-



carbon-free air was used to set the instrument span and zero air



containing less than 0.1 ppm total hydrocarbon was used to estab-



lish the instrument base line.  Span and zero settings were



checked before and after the four-hour sampling period and no



calibration drift was noted.



     Table 3.2-8 presents the hourly and overall average concen-



trations measured.  The overall average concentration was 3.9 ppm



as methane.  The highest concentration measured was 7.8 ppm and



the lowest concentration measured was 1.5 ppm.
 40 CFR 60, Appendix A, Reference Method 6, July 1, 1980.



                               3-26

-------
                TABLE  3.2-7.   SUMMARY  OF  NITROGEN  OXIDES  RESULTS
                      CLINKER COOLER FABRIC  FILTER OUTLET

Run
No.
1




Date
(1981)
2/26




Sample
No.
BON1A
BON1B
BON1C
BON1D
Average

Concentration
ppm
2.0
2.2
2.1
3.7
2.5
mg/dscm
3.9
4.3
4.0
7.1
4.8
Ib/dscf x 10-"
0.2431
0.2679
0.2531
0.4432
0.3018
Mass; .
emission rate
kg/h
0.14
0.16
0.15
0.26
0.18
Ib/h
0.32
0.35
0.33
0.58
0.40
 Concentrations  of  NOX  as  N02  in  parts  per million  (ppm) by volume, milligrams
 per dry standard cubic meter  (mg/dscm), and pounds per dry standard cubic
 foot (Ib/dscf).

"'Mass emission rate in  kilograms  per  hour (kg/h) and pounds per hour (Ib/h)
 calculated  using average  measured  flow obtained from the particulate tests
 [36,737 dscmh  (1,297,351  dscfh)].
                                     3-27

-------
      TABLE 3.2-8.   VOC  MONITORING DATA, CLINKER COOLER FABRIC FILTER OUTLET
Monitoring period
(24 h time)
12:03 to 13:03
13:03 to 14:03
14:03 to 15:03
15:03 to 15:58
Average
Date
(1981)
2/24
2/24
2/24
2/24
2/24
Average VOC concentrations
ppm as methane3
4.9
3.0
4.0
3.8
3.9
Emission rate
lb/hb
0.3
0.2
0.2
0.2
0.2
 ppm as  methane -  part  per million  by  volume measured by comparison to
 methane response.

DBasis:   average measured flow  rate of 1,297,351 dscfh and molecular weight
         of 16 Ib/lb  mole (methane).
                                    3-28

-------
     The average concentration of 3.9 ppm corresponds to a mass



emission rate of 0.2 Ib/h as methane based on a measured gas flow



rate of 36,737 dscmh (1,297,351 dscfh).   As the methane content



was not measured separately, this concentration may include some



methane.



     Copies of the strip chart printouts for this test are in



Appendix B.






3 . 3  -PROCESS SAMPLES



     Table 3.3-1 summarizes results from analysis of process



samples collected during each particulate test.  Clciy and coal



samples were collected at approximately 20 minute intervals.



Clay samples were collected from the kiln feed conveyor and coal



samples after the pulverizer prior to entering the kiln.  In ad-



dition, samples of the final aggregate product and scrubber water



influent and effluent were collected in order to determine total



sulfate content.



     The clay analytical data was characterized by an avera.ge



sulfur content of less than 0.02 percent and a moisture content



averaging 3.85 percent.  The coal analytical data was character-



ized by an average sulfur content of 1.59 percent and an average



ash content of 11.8 percent.  The sulfur content of the final



product averaged less than 0.02 percent.  The sulfate concentra-



tion of the scrubber effluent averaged 900 milligrams per liter



(mg/1).  Though not specified in the NSPS test request, a compos-



ite influent sample was analyzed for sulfates.  The recirculated



scrubber water influent showed an average sulfate concentration



of 760 mg/1.                   3_29

-------
               TABLE  3.3-1.  SUMMARY OF PROCESS SAMPLE ANALYSIS
Particulate
Run No.
1

2-3

1-3







Date
(1981)
2/23

2/24

2/23-24




2/24


Sample
type
Coal
Clay
Coal
Clay
Final
product
Scrubber
efflu-
ent
Scrub-
ber in-
fluent
Density,
g/ml
1.15
2.40
1.15
2.54
_

-


_


Moisture,
%
1.94
3.75
1.90
3.68
_

-


_


Ash, %
dry basis
11.30
-
12.27
-
_

-


_


Sulfur, %
dry basis
1.56*
<.02b
1.61?
<.02b
<.02b

900 mg/lc


760 mg/lc


JASTM D3177.
3ASTM D2234.
'Method  C-427.   Standard  Methods for the Examination of Water and Wastewater,
 Nth Edition.
                                     3-30

-------
     Table 3.3-2 sumarizes results from the trace metal analysis



performed on process samples collected during the particulate



tests.  All results are reported in micrograms per gram (yg/g)



except where noted.






3.4  FUGITIVE EMISSIONS FROM THE KILN



     Fugitive emissions surveys were conducted to determine the



magnitude of any leaks around the kiln seals.  These surveys were



conducted during each particulate test using the procedure of



Draft EPA Method 22.*



     Three fugitive surveys were conducted for 15 minutes at



each end of the kiln during each particulate test.  During each



of the three particulte tests, no fugitive emissions were ob-



served from either end of the rotary kiln.






*45 FR, pp 76426-9.
                                3-31

-------
                TABLE 3.3-2.   SUMMARY OF TRACE  METAL  ANALYSIS
Element
Ca
Mg
K
Na
Si
Ba
Mn
AT
Cr
Cu
Zn
Ti
Sr
V
Li
Y
Fe





Coal3
3.1%
0. 384%
0. 568%
0.480%
9.6%
630
470
4.2%
46
100
540
0.244%
250
73
7.5
19
4.0%





Clay3
0.65%
0.71%
0.53%
0.40%
28%
370
700
6.6%
62
19
77
0.38%
66
92
40
23
3.2%





Final
product3
0.82%
0.79%
0.58%
0.46%
34%
360
430
7.4%
70
24
94
0.490%
80
110
52
25
3.9%





Scrubber
effluent3
320
33
10
62
12
0.080
2.2
<0.05
<0.001
<0.001
0.058
<0.005
1.1
0.008*
0.18
<0.002
0.040*





Elements not
detected
P
W
Pt
B
Hg
Tl
Mo
Sb
Au
Te
Ni
Bi
Be
As
In
Se
Ag
Pb
Cd
Co
Sn
U
 Composite samples per category.
*Indicates values less than five  times  the detection  limit.
                                    3-32

-------
                            SECTION 4



             SAMPLE LOCATIONS AND TEST METHODS USED






     Figure 4-1 presents a simplified process flow sheet depict-



ing the sample locations and type of testing conducted at each



site.



     The following is a description of the sample locations used



to conduct sampling for particulate, sulfur dioxide, nitrogen



oxide, and particle size distribution.






4.1  KILN EXHAUST WET SCRUBBER OUTLET



     Particulate, sulfur dioxide, nitrogen oxides, particle size



distribution, and volatile organic carbon contents were measured



at the wet scrubber outlet as shown in Figure 4.1-1.  Two sample



ports, 90° off-center, were located 10.3 duct diameters down-



stream and 2.4 duct diameters upstream from the nearest flow



disturbances in the 1.2 meter (3.94 ft) I.D. round stack.  Twelve



traverse points, six per port, were used to traverse the cross-



sectional area of the stack for the particulate test runs.  Each



point was sampled for 10 minutes yielding a total test time of



120 minutes.  Sulfur dioxide, nitrogen oxides, and volatile



organic carbon sampling was conducted using constant rate sample




techniques by placing the respective probe tips near the center



of the stack.





                               4-.1

-------

Ornfll 	 -to


COOLING 	 „
AIR


?) SAMPLE POINT
— » SOLIDS FLOW
--»• AIR/GAS FLOW

CD
CLAY
I
ROTARY
KII N
NO. 3
1
1
1
t '
CLINKER
COOLER
I
i
DRY
CYCLONE
I©
i
FABRIC
FILTER
*
STACK
STACK
|0
>^ 	 WET r. nrv.-
• SCRUBBER *JLUDC

	 •• PRODUCT

®
	 ^CAPTURED PARTICULATE

©
	 * CAPTURED PARTICULATE

Sample type
Particulate
so2
Particle size
Opacity
Fugitive dust
N0x
Raw material
VOC
Trace metals
Sample points
4,9,11
3,4,9
4,9,11
4,11
Kiln seals
4,11
1,2,5,6
4,11
1,2.5,6
No. of samples
3
6
4
4
4
12,4
Composite
Continuous
Composite
Test method
EPA 5
EPA 6
Impactor
EPA 9
EPA 22
EPA 7
a
FID
b
aCoal  samples:  sulfur content; density, percent moisture; and percent ash.
 Clay  samples:  sulfur content; density and percent moisture.
 Sulfur analysis by Method:  ASTM D3177 and ASTM D2234.

 I-CAP- Induction Capture Plasma and  Atomic Absorption Spectrophotometry.


   Figure  4-1.   Process  flow  sheet and samples  collected.
                                4-2

-------
    I.D.
    1.2 m
  (3.94 ft)
     O
   NIPPLE
   LENGTH
15 cm(6 in.)
   FLOW
  T
  UPSTREAM
2.9 m, 2.4 dd
  (9.5 ft)
              DOWNSTREAM
            12.3 m,  10.3 dd
               (40.4 ft)
TRAVERSE POINT
NO.
1
2
3
4
5
6
DISTANCE*
in.
2.1
6.9
13.9
33,1
40.1
44.9
cm
5.33
17.53
35.30
84.10
101.85
114.05
                              2 TRAVERSES
                              6 SAMPLING POINTS

                              *Distance  not  including
                               nipple  length.
                                                 CROSS
                                                SECTION
                        ROTARY
                       KILN NO.3
                                   I.D.
                             in.    1.2 m
                                 (3.94 ft)
        Figure 4.1-1.  Wet scrubber outlet.
                     4-3

-------
4.2  CLINKER COOLER FABRIC FILTER INLET

     Particulate and sulfur dioxide concentrations as well as

particle size distribution were measured at the clinker cooler

fabric filter inlet as shown in Figure 4.2-1.  Two sample ports,

90° off-center, were located 2.0 duct diameters downstream and

1.3 duct diameters upstream from the nearest flow disturbances

in the 1.0 meter (3.28 ft) I.D. round stack.  Forty-eight t3:averse

points, twenty-four per port, were used to traverse the cross-

sectional area of the stack for the particulate test runs.  Each

point was sampled for 2.5 minutes yielding a total test time of

120 minutes.

     Sulfur dioxide sampling was conducted at a constant sampling

rate by placing the probe tip near the center of the duct.



4.3  CLINKER COOLER FABRIC FILTER OUTLET

     Particulate and particle size distribution were measured at

the clinker cooler fabric filter outlet as shown in Figure 4.3-1.

Six sample ports were located 3.8 duct diameters downstream and

0.8 duct diameters upstream from the nearest flow disturbances in

the 0.7 x 0.96 m (2.3 x 3.15 ft) rectangular stack.  Thirty-six

traverse points, six per port, were used to traverse the cross-

sectional area of the stack for the particulate test runs.  It

should be noted that the sample points as depicted in Figure

4.3-1 were not located according to procedures described in EPA

Method 1* for rectangular ducts.  However, no significant bias in

the particulate measurements occurred, based on comparisons with
it
 40 CFR 60, Appendix A, Reference Method 1, July 1, 1980.

                               4-4

-------
 FROM
  DRY
CYCLONEI


1 ,
NIPPLE
LENGTH
10.2 cm (4 in.)_



UPSTREAM
l^ 1.3 m (4.27
— »-n
\|
1 m (3.28 ft)
I.D.
1
— »l
ft) -I
N
>
i.
TO BAGHOUSE
•>
i
               2.0 m (6.56 ft)
                 DOWNSTREAM
           10.2 cm
           (4  in.)
VERTICAL
  PORT
        CROSS
       SECTION
                                  PORT
                       I.D.
                   1  m (3.28  ft)
       *Distance not including
        nipple length.
TRAVERSE POINT
NO.
1
2
3
4
5 '
6
TAL 7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
DISTANCE*
in.
1.0
1.3
2.1
3.1
4.1
5.3
6.4
7.6
9.1
10.8
12.8
15.8
23.8
26.8
28.8
30.4
31.9
33.1
34.3
35.4
36.4
37.4
38.2
38.5
cm
2.54
3.30
5.33
7.87
10.41
13.46
16.26
19.30
23.11
27.43
32.51
40.13
60.45
68.07
73.15
77.22
81.03
84.07
87.12
89.92
92.46
95.0
97.03
97.79
                                       2  TRAVERSES
                                       48 SAMPLING POINTS
           Figure  4.2-1.   Clinker cooler fabric filter inlet.
                                 4-5

-------

'»
UPSTREAM
-.68 m
(2.2
i
i


3 ft)



DOWNSTREAM
-3.2 m
(10.5 ft)



1





*
/ .BACKSIDE /
/ PORTS /
r X^C"
1 'S ^i/
1
FRONTSIDE ,
PORTS '
1
1
l.D.

(2.30 ft)
I
1
I
1
1
1
1
L
*Vj



-.96 m
(3.15 ft)
V
r





• *
TRAVERSE POINT
NO.
1
2
3
4
5
6
DISTANCE*
In.
1.7
5.6
11.3
26.8
32.5
36.3
cm
4.32
14.22
26.70
68.07
82:. 55
92!. 20
                                      6 TRAVERSES
                                     36 SAMPLING POINTS


                                      *Distance from  inside nipple.
      CROSS  SECTION
                             EQUIVALENT ROUND
1

-.9
(3.1

i

i

> m
? ft)



•1 »6 »1 »6 »1 ,6



•6«1 »6 »1 »6 »1
1 — 1 1 — 1 L_l
                              2LW
                                  =  .84 m (2.74 ft)
Figure  4.3-1.  Clinker cooler fabric filter outlet.
                        4-6

-------
the calculated particle size mass loading [0.0029 gr/dscf (par-

ticulate) versus 0.0023 gr/dscf (particle size)] and plume

observation data.  Each point was sampled for 3.3 minutes yield-

ing a total test time of 118.8 minutes.  The test and analytical

procedures used at each site are described briefly below.


4.4  VELOCITY AND GAS TEMPERATURE

     A type S pitot tube and an inclined draft gauge manometer

were used to measure the gas velocity pressure  (AP).  Velocity

pressures were measured at each sampling point across the duct to

determine an average value according to the procedures outlined

in Method 2 of the Federal Register.*  The temperature at each

sampling point was measured using a thermocouple and potentiom-

eter.


4.5  MOLECULAR WEIGHT

     Flue gas composition was determined utilizing procedures

described in Method 3 of the Federal Register.*  A bag sample was

collected during each particulate, sulfur dioxide, and nitrogen

oxides test run.  The bag contents were analyzed using an Orsat

Gas Analyzer.


4.6  PARTICULATE

     Method 5, as described in the Federal Register,* was used to

measure particulate grain loading at each test location.  All

tests were conducted isokinetically by traversing the cross-sec-

tional area of the stack and regulating the sample flow rate
 40 CFR 60, Appendix A, Reference Methods 2, 3, and 5, July 1,
 1980.
                                4-7

-------
relative to the flue gas flow rate as measured by the pitot tube



attached to the sample probe.  A sampling train consisting of a



heated, glass-lined probe, a heated 87 mm (3.4 in.) diameter



glass fiber filter  (Reeve Angel 934 AH),  and a series of Greenburg-



Smith impingers was employed for each test.   An acetone rinse of



the nozzle, probe, and filter holder portions of the sample train



was made at the end of each test.  The acetone rinse and the



particulate caught on the filter media were dried at room temper-



ature, desiccated to a constant weight, and weighed on an ana-



lytical balance.  Total filterable particulate matter was deter-



mined by adding these two values.  The contents of the impinger



section of the sampling train were recovered and analyzed for



organic and inorganic content by ether-chloroform extraction.





4.7  SULFUR DIOXIDE



     The test procedure used was as described in Method 6 of the



Federal Register* except for the replacement of the midget im-



pingers with a series of Greenburg-Smith impingers.  A heated



glass-lined probe preceded the series of impingers.  A plug of



glass wool was placed in the tip of the probe as well as in the



connecting glassware between the first and second impingers.



Each inlet and outlet test consisted of two 30 minute runs.  Each



sampling train was purged with ambient air for 15 minutes after



the completion of each test.  Contents of the second and third



impingers  (3% hydrogen peroxide) were measured and analyzed for
 40 CFR 60, Appendix A, Reference Method 6, July 1, 1980.




                               4-8

-------
sulfate content onsite using the barium-thorin titration


method.



4.8  NITROGEN OXIDES


     Sampling and analytical procedures used followed those


described in EPA Method 7 of the Federal Register.*  A total of


three tests, each consisting of four grab samples taken at


approximately 15 minute intervals, were conducted on the scrubber


exit stack.  Four samples were collected at the fabric filter


outlet test location.  Samples were obtained and shipped to the


laboratory for analysis.



4.9  PARTICLE SIZE DISTRIBUTION


     Particle size samples were obtained using an Andersen 2000


Mark III Source Cascade Impactor.  This is an in-stack, multi-


stage cascade impactor which has a total of eight stages with


particle size cut-offs ranging nominally from 0.5 to 15 microns,


followed by a back-up filter stage.  Substrates for the Andersen


were 64 mm glass fiber filters.  A constant sampling rate was


maintained through the test period.  Sampling rates were set for


isokinetic sampling as long as the sample rate did not exceed the


recommended flow rate for the impactor  (0.70 acfm).


     A total of five impactor runs were conducted at each sam-


pling site.  Sampling point locations for the circular stacks


were located as shown in Figure 4.9-1.  At least one impactor run


was conducted at each sampling point.  In the rectangular stack


of the clinker cooler fabric filter outlet, a point of average
*
 40 CFR 60, Appendix A, Reference Method 7, July 1, 1980.


                               4-9

-------
Figure 4.9-1.   Particle  size sampling points for circular stack.
                               4-10

-------
velocity was sampled.  The procedures used followed those recom-



mended in the "Procedures Manual for Inhalable Particulate



Sampler Operation" recently developed for EPA by the Southern



Research Institute.






4.10  PROCESS SAMPLES



     Samples of the coal and clay fed to the kiln were collected



at approximately twenty minute intervals during the particulate



sampling.  Coal samples were collected after the pulverizer just



prior to entering the kiln.  Clay samples were collected from the



kiln feed conveyor belt.  Coal samples were analyzed for sulfur



content, density, moisture content and percent ash.  Clay samples



were analyzed for sulfur content, density, and percent moisture.



     In addition to the coal and clay, composite samples of the



influent and effluent from the kiln wet scrubber and final



aggregate product were collected and analyzed for trace metals



and sulfur content.






4.11  VOC SAMPLING



     Sampling for volatile organic compounds was performed using



a Malloy FID hydrocarbon analyzer.  With this system, samples



were drawn from the stack through heat-traced teflon sample line,



maintained at 120°C  (250°F), and injected directly to an FID.  A



five point calibration of the system was performed before and



after each monitoring period using gas standards of methane in



air.  Zero and span checks were performed at the mid-point of the



monitoring period.  Approximately one-half day of continuous VOC



monitoring was performed at the designated sites.



                               4-11

-------
                            SECTION 5
                        QUALITY ASSURANCE

     Quality assurance is one of the main facets of stack sam-
pling since the end product of testing is to produce representa-
tive emission results.  Quality assurance guidelines provide:
detailed procedures and actions necessary for defining and pro-
ducing acceptable data.  Four documents were used in this test
program to provide the required guidance to help insure the
collection of acceptable data and define when data quality is
unacceptable.  These documents are the source specific test plan
prepared by PEDCo and reviewed by the Emissions Measurement
Branch, the EPA Quality Assurance Handbook Volume III, EPA-600/4-
77-027b, the draft PEDCo Environmental Emission Test Quality
Assurance Plan and the PEDCo Environmental Laboratory Quality
Assurance Plan.  The last two quality assurance plans are PEDCo's
general guideline manuals that define the company's standard
operating procedures followed by the emission testing groups and
the laboratory groups.
     More detail on the Quality Assurance procedures are provided
in Appendix F.  This includes QA objective; data reduction;
quality control checks; performance and system audits; preventive
maintenance; precision, accuracy and completeness; corrective
action; and quality assurance reports to management.
                               5-1

-------
     Relative to this specific test program, outlined below are



steps taken to insure quality data for the testing and analytical



procedure used.



     0    Calibration of field sampling equipment.  Calibration

          guidelines are described in more detail in Appendix E.



     0    Train configuration and calculation checks.



     0    Onsite quality assurance checks such as:sample train,

          pitot tube, and orsat line leak checks.



     0    Use of designated analytical equipment and sampling

          reagents.



     Sampling equipment used to conduct particulate, S0_, and NO
                                                       4b        J^.


testing are listed in Table 5-1 along with calibration guidelines



and limits.  In addition to the pre- and post-test calibration, a



field audit was performed on the meter boxes used for particulate



and SO,, sampling.  An EPA supplied critical orifice was used for



this audit.  Figures 5-1 through 5-3 show an example audit run for



each dry gas meter.



     To check the reliability of the analytical method used to



analyze the filters used for particulate and particle size tests,



sets of filters, preweighed in the lab, were resubmitted for



replicate analysis.  Table 5-2 summarizes the results of the



blank filter and reagent analysis.



     Audit solutions prepared by the EPA were used to check the



analytical procedures and reagents used for SO, and NO  sample
                                              £•       a


analysis.  The results of the analytical audit are presented



in Tables 5-3 and 5-4.  Sulfur dioxide and NO  audit tests show
                                             H


good analytical technique.
                               5-2

-------
                                TABLE 5-1.  PARTICULATE EQUIPMENT CALIBRATION SUMMARY
in
I
10
Equipment
Meter box
P1tot tube
Digital
Indicator
Thermocoupl es
and stack
thermometers
Orsat
analyzer
Implnger
thermometer
Trip balance
Barometer
Dry gas
thermometer
1.0.
No.
FB-1
FB-2
FB-5
RAC-4
038
179
184
180
208
125
124/219
203
204
128
127
142
143
Many
197
226
FB-1
FB-2
FB-5
RAC-4
Participate sampling
Calibrated
against
Wet test meter
Standard pi tot
tube
Millivolt
signals
ASTM-2F or 3F
Standard gas
ASTM-2F or 3F
Type S weights
NBS traceable
barometer
ASTM-2F or 3F
Allowable
error
Y +0.02 Y
AY £ +0.15
(Y +0.05 Y post-test)
Cp +0.01
0.5*
1.5S
(+2°F saturated)
+0.5X
+Z°F
+0.5 g
+0.10 In.Hg
(0.20 post-test)
+5°F
Actual
error
0.012
0.015
0.041
0.029
0.00
0.01
0.00
0.00
0.00
0.21
0.11/0.10
0.976
1.030
1.082
1.113
0.04
0.02
Avg. 1°F
0.1 g
0.04
2.8°F
1.7°F
2.2°F
1.1-F
Hlthln
allowable
limits
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes/Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
w 	
ies
Comments
See Appendix E for
full calibration
data








                   (continued)

-------
            TABLE 5-1  (continued)
en
I
Equipment
Probe nozzle
Meter box
Rotameter*
Dry gas meter
thermometer
Implnger
thermometer

Collection
flask
Thermometer
Barometer
I.D.
No.

RAC-4
FB-8
FB-3

Many
Many


N-1
226
Sulfur dioxide sampling
Calibrated
against
Call per
Wet test meter
Bubble buret
ASTM-2F or 3F
ASTM-2F or 3F

500 ml Class A
grad. cycllnder
ASTM-2F or 3F
NBS traceable
barometer
Allowable
error
On +0.004 In.
Y +0.02 Y
(Y +0.05 Y post-test)
+5*
(+10S post-test)
+5°F
+2°F
Nitrogen oxides samp
+10 ml
+2°F
+0.10 In.Hg
(0.20 post-test)
Within
Actual allowable
error limits

0.029 Yes
0.024 Yes
0.019
Yes
1 Yes
1°F Yes
1°F Yes
Avg. 1"F Yes
ling
Yes
0.5°F Yes
0.04 Yes
Conments

See Appendix F for
full calibration







             •Not used.

-------
                                               AUDIT REPORT GAMPLF. MF.TEU
      Date
                                 Client
                   f   I
      Barometerlc pressure (P.   » in Hg )


      Orifice number
      Orifice K factor
                                 Meter box number


                                 Pretest Y	


                                 Auditor
Orifice
reading
AH
in H20
*>
Dry gas
meter
reading
v}/vf
ft3
ff/.f
m.i
Try gas
meter
volume
V
,*>
Temperatures
"Snib'icht
T /T
a. af
°F
(r»
fr*
Average
T
a
°F
I.*
Inlet
T .
mi
°F
£*
^
Outlet
T
mo
°F
t,(*
i,
-------
                                               AUDIT REPORT SAMPLE MFTEn BOX
      Date
                                                            Client
      Barometeric  pressure (P.   »  in Hg )


      Orifice  number
Orifice K factor
                                       X./&
                                    Meter box number


                                    Pretest Y	^


                                    Auditor     faA^
Orifice
manometer
reading
AH
in H20
,.i
Dry gas
meter
reading
vj/vf
MfO
fro,<*
Dry gas
meter
volume
V
tf-H
Temperatures
Tfiriblcnt
T /T
a. af
°F
?i




      m ( 1203 )(   l£.i\-
           = (  v.
                 m
                  std
                - V
                   m
)( 100 )/( V
                    act
                                          m
100
             act
                                     Figure 5-2.   Audit  report  sample meter  box.

-------
                                         AUDIT REPORT SAMPLE METEf! COX
Date
                                                            Client
Barometer ic pressure (P.   » in Hg )

Orifice number
                                          ' t 7
Orifice K factor
                           X * *>
Meter box number

Pretest Y

Auditor
                                                                             '")'
Orifice
manometer
reading
AH
in H20
J.V
Dry gas
meter
reading
v,/vf
ftJ
Wti
t*&
Try gas
meter
volume
V
£
,a.H
Temperatures
Ambient
T /T
a af
°F
tf
(*<*
Average
T
a
°r
^
Inlet
Trni
°F
^
^
Outlet
T
mo
°F
tf
^
Average
T
m
°F
(^^
Sampling
time

min
Ifjf
V
rastd
ft3
,a>*
V
mact
ft3
/a.«{
Percent
error
-AT^_
 m
  std

V
 mact

V
 mstd

V
 mact

error
= ( 17.647 )( Vm )( Y )(


= ( 1203 )( 0 )( K )(


  ; 17.647 )(  /5-/


  ; 1203 )(   i£i{
                                    + AH/13. 6 )/(
                                 )/( T  + 460

                                                       460 )
  < Vm    - Vm    >< 10° >/( Vm    > = ("
      std     act              act
                                                    )( 100
                               Figure 5-3.   Audit report  sample meter box.

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TABLE 5-2.   EXAMPLE BLANK FILTER AND  REAGENT ANALYSIS

Sample type
Particulate - 87
mm Reeve Anqel
934 AH #0002079
Particle size
64 mm Reeve
Angel 934 AH
L-69
N-28
L-95
N-26
T-29
N-36
P-29
N-34
B-465
Acetone
blank
H20 blank
Original tare
weight, mg

354.9




131.8
134.3
142.4
135.8
148.6
136.2
146.2
135.8
206.6

109239.7
99827.9
Blank weight,
mg

355.2




132.0
134.8
142.6
135.9
148.9
136.4
146.5
136.0
207.0

109241.9
99828.4
Net weight,
mg

+0.3




+0.2
+0.5
+0.2
+0.1
+0.3
+0.2
+0.3
+0.2
+0.4

+2.1
+0.3
                         5-8

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                        TABLE 5-S.  AUDIT REPORT S02 ANALYSIS
      Plant    #5 £.7* A.
                                      PN Number
Date samples received	
Samples  analyzed by	£/
Reviewed by
                                            Date analyzed
ijfj
 It •'''/
Jiff:±t:i-
                                            Date of Review   3 ••}"*•
Sample
Number
E?A
#3Jt(*
&PA
^3}H




mg S02/dscm
Determined
^^-^ ^
///7.X ^




Source of
Sample
-rvtyjG.
*nJjj/wL




Accepted
Value
*7/.&
//*$. 11




%
Difference
- A.o '/'
- 1.3%




It
                                       5-9

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                 TABLE 5-4.   AUDIT REPORT NOY ANALYSIS
                                         rt
Plant
        USE PA
PN Number
Date samples received
                                    Date analyzed "3> - ^4- "
Samples analyzed  by     (j(J . *5 -\-etO qrci.


Reviewed byJ~.Qi/i/ictt _ 7" / ^.
                                    Date of Review
Sample
Number
55 C 1^15
5SC 3^4.2




mg N02/dscm
Determined
loW. 63-
/
5>oH,<2^7
; /




Source of
Sample
T. l<0aq/vu^
T. (JUa^mir t




Accepted
Value
67^3
372.7



•
%
Difference
y-^,^%
+ *.!%




                              5-10

-------
     Sampling equipment, reagents, and analytical procedures for


this test series followed and met all necessary guidelines set


forth for accurate test results as described in Volume III of the


Quality Assurance Handbook.*
*
 Quality Assurance Handbook for Air Pollution Measurement Systems,
 Volume III, EPA-600/4-77-027b, August 1977.
                               5-11

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                            SECTION 6



                      DISCUSSION OF RESULTS






     Overall, the sampling program was executed as planned and no



major problems occurred with either test equipment or sampling



activities.  In addition, the process operation was characterized



as normal throughout the test period by personnel from MRI.



     The measured particulate emissions appear to be representa-



tive based on between-test data reproducibility and comparisons



with the plume observation and particle size distribution data



collected concurrent with the particulate tests.



     The measured particulate concentration at the inlet to the



fabric filter (186 mg/dscm) is within 5 percent of the results



obtained from the equivalent site at the first plant evaluated



(176 mg/dscm).  The addition of the fabric filter control device



on the clinker cooler line reduces particulate emissions by at



least 96 percent based on test data.



     Particulate emission results obtained from the kiln exhaust



scrubber outlet indicated that the control device operated



efficiently throughout the test period.



     The process sample analysis shows the clay material used at



this plant processes a low sulfur  (<.02 percent) content.  There-



fore, it is reasonable to conclude SO,, emissions are generated







                                6-1

-------
primarily from the combustion of coal (1.59 percent sulfur) in



the kiln.  Likewise, NO  and VOC emissions are probably generated
                       X


by coal combustion.
                                6-2

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                           REFERENCES
1.    Southern Research Institute.   Procedures Manual for Inhalable
     Particulate Sampler Operation.  Prepared for EPA under Con-
     tract No.  68-02-2118.   November 1979.

2.    Southern Research Institute.   A Computer-Based Cascade Im-
     pactor Data Reduction  System.   Prepared for EPA under Con-
     tract No.  68-02-2131.   March 1978.
                                R-l

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