.f* ~?
r&r*
United States
Environmental Protection
Agency
                       Office of Air Quality
                       Planning and Standards
                       Research Triangle Park NC 27711
EMB Report 83-CDR 10
April 1 984
Air
Emission Test
Report

American Cyanamid
Company
Savannah, Georgia

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                 NSPS DEVELOPMENT

PARTICULATE AND PARTICLE SIZING EMISSIONS TESTING
                 TITANIUM DIOXIDE
         SPRAY DRYER AND CALCINER SYSTEMS
            AMERICAN CYANAMID COMPANY
                SAVANNAH, GEORGIA
               FEBRUARY 9-16, 1984
                   Compiled by:

                     ENTROPY
              Post Office Box 12291
       Research Triangle Park, N. C. 27709
                    68-02-3852
              Work Assignment No. 2
             EMB Project No. 81 REG 8
                   Task Manager

                    Dan Bivins
           Emission Measurement Branch
   Emissions Standards and Engineering Division
   OFFICE OF AIR QUALITY PLANNING AND STANDARDS
       OFFICE OF AIR, NOISE, AND RADIATION
      U. S. ENVIRONMENTAL PROTECTION AGENCY
       RESEARCH TRIANGLE PARK, N. C., 27711

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                                  DISCLAIMER









     Although the research described in this report has been funded wholly or




in part by the United States Environmental Protection Agency through



Contract 68-02-3852 to Entropy, it has not been subject to the Agency's peer




and administrative review and therefore does not necessarily reflect the




views of the Agency, and no official endorsement should be inferred.

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                              TABLE OF CONTENTS

LIST OF TABLES	     v
LIST OF FIGURES	   vii
1.  INTRODUCTION	   1-1
    1.1    Background	   1-1
    1.2    Scope of the Project	   1-1
    1.3    American Cyanamid Testing Program   	   1-1
    1.3.1     Source Applicability  	   1-1
    1.3.2     Outline of Testing Program  	   1-2
    1.4    Report  Organization	   1-2

2.  SUMMARY AND  DISCUSSION OF RESULTS	   2-1
    2.1    Introduction	   2-1
    2.2    Chloride Process   	   2-1
    2.2.1     General	   2-1
    2.2.2     #312 Baghouse Inlet	   2-1
    2.2.3     #312 Baghouse Outlet	   2-2
    2.2.4     #322 Baghouse Outlet	   2-2
    2.2.5     Spray Dryers Stack  	   2-2
    2.3    Sulfate Process	.  .   2-18
    2.3.1     General	   2-18
    2.3.2     East and West I.D. Fan Outlets	   2-18
    2.3.3     East and West ESP Outlets	   2-19
    2.3.4     #2 Calciner Exhaust Stack 	   2-19
    2.3.5     #2 Calciner Product Outlet  	   2-19

3.  PROCESS DESCRIPTION AND OPERATION 	   3-1
    3.1    Introduction	   3-1
    3.2    Pollutants/Sampling Points 	   3-1
    3.2.1     Spray Dryers	   3-1
    3.2.1.1    .  Particulate Mass and Particle Sizing  	   3-1
    3.2.1.2      Visible Emissions  	   3-1
    3.2.1.3      Feed and Product Samplers   	   3-1
    3.2.2     Rotary Calciner #2	   3-4
    3.2.2.1      Particulate Mass and Particulate Sizing  	   3-4
    3.2.2.2      Visible Emissions  	   3-4
                               (continued next page)

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                                      ii

                                TABLE OP CONTENTS
                                   (continued)
    3.3    Process Description	    3-4
    3.3.1     Spray Dryers	    3-4
    3.3.2     Rotary Calclner #2	    3-8
    3.4    Process Conditions During Testing. .  .  	    3-8
    3.4.1     Spray Dryers	    3-8
    3.4.2     Rotary Calciner #2	    3-10
4.  SAMPLING LOCATIONS	   4-1
    4.1    Applicability of Sampling Sites  	   4-1
    4.2    Chloride Process Sampling Locations  	   4-1
    4.2.1     #312 Spray Dryer Inlet	   4-1
    4.2.2     #312 Settling Chamber Product Outlet  .	   4-1
    4.2.3     #312 Baghouse Inlet	   4-1
    4.2.4     #312 Baghouse Product Outlet  	   4-4
    4.2.5     #312 Baghouse Outlet	   4-4
    4.2.6     #322 Spray Dryer Inlet	   4-4
    4.2.7     #322 Baghouse Product Outlet  	 .....   4-4
    4.2.8     #322 Baghouse Outlet	   4-6
    4.2.9     #312 and #322 Exhaust Stack, Particulate Sampling ....   4-6
    4.2.10    #312 and #322 Exhaust Stack, Visible Emissions  	   4-6
    4.3    Sulfate Process #2 Calciner Sampling Locations 	   4-9
    4.3.1     #2 Calciner Inlet	   4-9
    4.3.2     Water Spray Cooler Outlet  	   4-9
    4.3.3     East Side I.D. Fan Outlet	   4-9
    4.3.4     East Side I.D. Fan Inlet	   4-9
    4.3.5     West Side I.D. Fan Outlet	   4-9
    4.3.6     West Side I.D. Fan Inlet	   4-13
    4.3.7     East and West Sides ESP Outlets	   4-13
    4.3.8     #2 Calciner Exhaust Stack, Particulate Sampling 	   4-13
    4.3.9     #2 Calciner Exhaust Stack, Visible Emissions   	   4-17
    4.3.10    #2 Calciner Product Outlet   	   4-17
                              (continued next  page)

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                                       Ill
                               TABLE OF  CONTENTS
                                  (continued)

5.  SAMPLING AND ANALYTICAL METHODS	   5-1
    5.1    Sampling Objectives	   5-1
    5.2    Particulate Emissions Testing  	   5-1
    5.2.1     #312 Baghouse Inlet	   5-1
    5.2.2     #312 Baghouse Outlet	   5-1
    5.2.3     #322 Baghouse Outlet	   5-1
    5.2.4     East and West I.D. Fans  Outlets	   5-2
    5.2.5     East and West I.D. Fans  Inlets	   5-2
    5.2.6     East and West ESP Outlets	   5-2
    5.3    Sulfuric Acid Mist	   5-2
    5.4    Trace Metals Analysis  	   5-2
    5.5    Sieve Analysis and Moisture Content  	   5-2
    5.6    Plume Opacity	   5-3
    5.7    Fugitive Emissions	   5-3
    5.8    Particle Size Testing	   5-3
6.  QUALITY ASSURANCE 	   6-1
    6.1    Introduction	   6-1
    6.2    Sampling Train Components   	   6-1
    6.3    Preseparator and Cascade Impactors  	  .   6-1
    6.4    Sample Collection Substrates  	   6-1
    6.5    Substrate Weighing 	   6-2
    6.6    Sample Analysis	   6-2
    6.7    EPA Method 3	   6-2
    6.8    EPA Method 9	   6-2

7.  APPENDICES	   7-1
    7.1    Chloride Process Test Results and Example  Calculations  ...   1
    7.1.1    #312 Spray Dryer Baghouse Inlet   	   2
    7.1.2    #312 Spray Dryer Baghouse Outlet  	   25
    7.1.3    #322 Spray Dryer Baghouse Outlet  	   39
    7.1.4    #312 and #322 Spray Dryers Stack	   59
                              (continued next  page)

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                                   IV
                            TABLE OF CONTENTS
                               (continued)
7.2    Sulfate Process #2  Calciner Test Results
         and Example Calculations  	   63
7.2.1     #2 Calciner I.D. Fan Outlet  (East)   	   64
7.2.2     #2 Calciner I.D. Fan Outlet  (West)   	   84
7.2.3     #2 Calciner ESP  Outlet (East)	   105
7.2.4     #2 Calciner ESP  Outlet (West)	   108
7.2.5     #2 Calciner Stack	   Ill
7.3    Chloride Process Field Data   	   119
7.3.1    #312 Spray Dryer Baghouse Inlet   	   120
7.3.2    #312 Spray Dryer Baghouse Outlet	   146
7.3.3    #322 Spray Dryer Baghouse Outlet	   167
7.3.4    #312 and #322 Spray Dryers  Stack	   191
7.3.5     Visible Emissions, Method  9  	   205
7.4    Sulfate Process #2  Calciner Field Data  	   213
7.4.1     East I.D. Fan Inlet and Outlet   .  .  .	   214
7.4.2     West I.D. Fan Inlet and Outlet	   235
7.4.3     #2 Calciner ESP Outlet (East)	   255
7.4.4     #2 Calciner ESP Outlet (West)	   264
7.4.5     #2 Calciner Stack	   273
7.4.6     Visible Emissions	  .  .  .   287
7.5    Feed and Product Analytical Data	   291
7.6    Sampling and Analytical Procedures  	   353
7.7    Calibration Data 	   407
7.8    Test Participants	   480
7.9    Testing Protocol and Run/Sample Numbering
         Cross-Reference   	   481

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                              List of Tables
Number                              Title                          Page

  1-1       Test Schedule, Planned Vs. Actual                       1-3
  1-2       Test Log                                                1-4

            Chloride Process
  2-1          Particulate Emissions & Concentrations Summary       2-3
  2-2          Collection Efficiencies Of Control Devices           2-4
               Particulate Tests Summary of Results
  2-3             #312 Spray Dryer Baghouse Inlet                   2-5
  2-4             #312 Spray Dryer Baghouse Outlet                  2-6
  2-5             #322 Spray Dryer Baghouse Outlet                  2-7
  2-6             Spray Dryers Stack                                2-8
               Summary of Particle Sizing Test Results
  2-7             #312 Baghouse Inlet                               2-9
  2-8             #312 Baghouse Outlet                             2-11
  2-9             #322 Baghouse Outlet                             2-13
               Summary of Visible Emissions Observations
 2-10             Spray Dryers Stack                               2-15
 2-11             Spray Dryers Stack                               2-16
 2-12             Spray Dryers Stack                               2-17

            Sulfate Process
 2-13          Particulate Emissions and Concentrations Summary    2-20
 2-14          Collection Efficiencies Of Control Devices          2-21
               Particulate Tests Summary of Results
 2-15             #2 Calciner, East I.D. Fan Outlet                2-22
 2-16             #2 Calciner, West I.D. Fan Outlet                2-23
 2-17             #2 Calciner, East ESP Outlet                     2-24
 2-18             #2 Calciner, West ESP Outlet                     2-25
 2-19             #2 Calciner Stack                                2-26

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                                    vi
                              List of Tables
                               (continued)

Number                              Title
                                                                   Page
               Summary of Particle Sizing Test Results
 2-20             East I.i). Fan Outlet                             2-27
 2-21             West I.D. Fan Outlet                             2-29
               Summary of Visible Emissions Observations
 2-22             #2 Calciner Stack                                2-31
 2-23             #2 Calciner Stack                                2-32
 2-24             #2 Calciner Stack .                               2-33
               Nitrogen Oxides (as N0ฃ) Testing Summary
 2-25             #2 Calciner Stack                                2-34

   1           Emission Tests Conducted at American
                  Cyanamid Company                                  3-2

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                                   vii
                             List of Figures
Number         •                    Title                           Page
   1        Simplified Flow Diagram of Chloride Process             3-5
   2        Simplified Flow Diagram of Sulfate Process              3-6
   3        Flow Diagram for Emission Control System for
               Spray Dryers                                         3-7
   4        Flow Diagram for Emission Control System for
               Rotary Calciner                                      3-9

  4-1       Chloride Process and Sampling Points                    4-2
  4-2       #312 Baghouse Inlet Dimensions                          4-3
  4-3       #312 Baghouse Outlet Dimensions                         4-5
  4-4       #322 Baghouse Outlet Dimensions                         4-7
  4-5       Spray Dryers #312 and #322 Stack Dimensions             4-8
  4-6       Sulfate Process and Sampling Points                    4-10
  4-7       #2 Calciner East and West Side I.D. Fan
               Outlets Dimensions                                  4-11
  4-8       #2 Calciner East I.D. Fan Inlet Dimensions             4-12
  4-9       #2 Calciner West I.D. Fan Inlet Dimensions             4-14
 4-10       #2 Calciner East and West ESP Outlet Dimensions        4-15
 4-11       #2 Calciner Exhaust Stack Dimensions                   4-16

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                                      1-1
1.   INTRODUCTION

     1.1  Background.  The Emission Measurement Branch (EMB) of the U.S. EPA
is directing a project designed to generate support data for a possible New
Source Performance Standards (NSPS) for calciners and dryers in the mineral
industries.  Process-related emission factors are being determined from the
testing of controlled sources (for the various industries).

     1.2  Scope of the Project.  EMB is responsible for coordinating the
efforts of Entropy to achieve the goals of the testing program.  Entropy has
been retained under EMB Contract No. 68-02-3852, Work Assignment No. 2 to
conduct testing programs at designated industrial facilities.  Entropy is to
perform emission measurements at the recommended sampling locations, obtain
process feed and product samples, and, in conjunction with Research Triangle
Institute (RTI), conduct sample analyses as directed by the Industrial Studies
Branch of EPA (ISB).  As directed by the Industrial Studies Branch of EPA
(ISB), Midwest Research Institute (MRI) will monitor process and operating
conditions in order to designate suitable testing conditions for the
respective processes and to provide a record of process and operational data
during the testing.

     1.3  American Cyanamld Testing Program.  This report covers stationary
source sampling performed at the American Cyanamid Company manufacturing plant
in Savannah, Georgia on February 9-16, 1984.  Bill Trees, Chris Gingrich, and
Bill Roberts of American Cyanamid and Dan Bivins of EPA/EMB were present to
coordinate the testing.  Yogesh N. Doshi and Lynda D. Carney of MRI monitored
the plant process and recorded operational data during the testing.

     1.3.1  Source Applicability.  American Cyanamid operates  a titanium
dioxide (T102) production facility which is representative of  the TiOo
pigment industry.  The plant uses spray dryers and rotary calciners which are
the two most difficult processes within the industry to control.  In addition,
T102 is believed to have the finest particle size distribution of materials
in the  industry and, consequently, would represent "worst  case" conditions.
     Spray dryers are used  in  the chloride process to produce  rutile pigment

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                                     1-2
(used primarily in paints), while rotary calciners are used in the sulfate
process to generate rutile pigment and anatase pigment (used in the paper
industries).
     Emissions from the processes are controlled by two or more types of
equipment in series.  Settling chambers and baghouses are used primarily for
product recovery, while cyclones, wet electrostatic precipitators, and
scrubbers provide the additional emission control needed to meet state
requirements.

     1.3.2  Outline of Testing Program.  Emission measurements were performed
at the spray dryer system within the chloride process and at the calciner
system within the sulfate process.  Table 1-1 provides a comparison of the
original testing plan and the actual tests performed; the testing program as
performed is outlined in Table 1-2,  which provides test dates, sampling
locations, and test methods.

     1.4  Report Organization.  Immediately following is the "Summary of
Results" section.  Appendices 7.1 and 7.2 present the complete results of
testing at the chloride and sulfate processes; field data can be found in
Appendices 7.3 and 7.4.  The two processes are described in the "Process
Description and Operation" section, while Appendix 7.5 presents feed and
product analytical data.  The next section, "Sampling Locations," provides a
comprehensive description and illustration for each location; "Sampling and
Analytical Procedures" follows, describing the sampling strategy used.
Descriptions of the equipment and procedures can be found in Appendix 7.6.
The final section, "Quality Assurance," notes the procedures used to ensure
the Integrity of the sampling program; Appendix 7.7 provides pertinent
calibration data.  Appendix 7.8 contains a listing of the Entropy test
participants and their roles in the testing program.

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                                     1-3
                                 TABLE  1-1

                               TEST  SCHEDULE
                             Planned  Vs.  Actual
                                    Type of Sample
                 Number of  Samples Taken
                    Planned    Actual
Chloride Process
Spray Dryers System

#312 Spray Dryer
   Spray Dryer Inlet
   Settling Chamber Product Outlet
   Baghouse Product Outlet
   Baghouse Inlet

   Baghouse Outlet

#322 Spray Dryer
   Spray Dryer Inlet
   Baghouse Product Outlet
   Baghouse Outlet

Exhaust Stack
      feed             3
     product           3
     product           3
   particulate         3
  particle size        6
   particulate         3
  particle size        6

      feed             3
     product           3
   particulate         3
  particle size        6
   particulate         3
  particle size        6
visible emissions      3
4
4
4
4
8
4
4

4
4
4
6
4
0
3
Sulfate Process
#2 Calciner System

   Water Spray Cooler Outlet
   #2 Rotary Calciner Inlet
   East ID Fan Inlet
   East ID Fan Outlet

   West ID Fan Inlet
   West ID Fan Outlet

   East ESP Outlet

   West ESP Outlet

   #2 Calciner Exhaust Stack
     product           3
      feed             3
    velocity           0
   particulate         3
  particle size        6
    velocity           0
   particulate         3
  particle size        6
   particulate         3
  particle size        6
   particulate         3
  particle size        6
   particulate         3
  particle size        6
 nitrogen oxides       3
visible emissions      3
3
3
2
3
6
2
3
6
3
0
3
0
3
0
3
3

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                                    1-4
                                 TABLE 1-2

                                  TEST LOG
     	 CHLORIDE PROCESS 	
     Test 1, February 9,  1984

        1312 Baghouse Inlet
           Particulate
           Particle Size
        #312 Baghouse Outlet
           Particulate
           Particle Size


        #322 Baghouse Outlet
           Particulate
           Particle Size
        Spray Dryer Stack
           Particulate
           Visible Emissions
  Run
Number

   1
 S-l-A
 S-l-B
S-1-B2*
   4
 S-4-A
 S-4-B
11:23
16:40
17:45
15:56
09:35
14:03
16:15
Finish
 Time

 13:31
 16:41
 17:46
 15:57
 11:44
 15:12
 17:00
7**
S-7-A
S-7-B
09:35
15:45
15:21
10:58
15:46
15:22
  10
  10
09:40
09:35
 11:46
 11:35
     Test 2, February 11,  1984
        #312 Baghouse Inlet
           Particulate
           Particle Size


        #312 Baghouse Outlet
           Particulate
           Particle Size

        #322 Baghouse Outlet
           Particulate
           Particle Size


        Spray Dryer Stack
           Particulate
           Visible Emissions
   2
 S-2-A
 S-2-B
   5
  S-5
   8
 S-8-A
 S-8-B
  11
  11
09:05
12:40
13:19
09:05
09:30
09:00
10:50
11:55
09:00
09:02
 10:40
 12:41
 13:20
 12:26
 13:00
 10:08
 10:51
 11:56
 12:31
 11:02
* S-l-B was overloaded;  S-1-B2  was  performed on February 13 for replacement

** Run 7 consists of component  runs 7A & 7B; refer to summary of results for
      details

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                                    1-5
                                 TABLE 1-2
                                (continued)

                                  TEST LOG
    - - CHLORIDE PROCESS - -
    Test 3, February 11, 1984

       #312 Baghouse Inlet
          Particulate
          Particle  Size
       #312 Baghouse Outlet
          Particulate
          Particle  Size
          Particle  Size QC

       //322 Baghouse Outlet
          Particulate
          Particle  Size
        Spray Dryer Stack
           Particulate
           Visible Emissions
Run
Number
3
S-3-A*
S-3-A2*
S-3-B
6
S-6**
Bl, Rl***
9
S-9-A**
S-9-B
12
12
Start
Time
13:54
16:22
14:52
16:49
14:02
14:12
14:45
13:51
15:44
16:10
14:00
14:00
Finish
Time
15:14
16:23
14:53
16:50
16:14
17:19
15:45
14:58
15:45
16:11
16:10
14:10
     Test 4,  February 16,  1984

        #312  Baghouse Inlet
           Particulate

        #312  Baghouse Outlet
           Particulate

        #322  Baghouse Outlet
           Particulate

        Spray Dryer Stack
           Particulate
           Visible Emissions
28       09:45     11:47
29       09:45     11:49
30       09:46     10:52
31       09:50     12:02
31       10:05     12:06
  * S-3-A was overloaded;  S-3-A2 was  performed on February 13 for replacement.

 ** S-6 catch weights were negligible;  S-9-A catch was overloaded; neither run
    is tabulated in the results.

*** Quality Control Reactivity Run Rl  and  Blank Run Bl performed February 13.

                                             (continued next page)

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                                 1-6
                             TABLE  1-2
                             (continued)

                              TEST  LOG

 	  SULFATE PROCESS  	
 Test 1,  February 14, 1984               Run      Start    Finish
 	            Number     Time     Time
    92 Calciner East I.D.  Fan Outlet
       Particulate                       13        15:55    17:04
       Particle Size                  S-13-A*     18:01    18:06
                                      S-13-B     18:37    18:42

    #2 Calciner West I.D.  Fan Outlet
       Particulate                       16        15:55    16:39
       Particle Size                  S-16-A     18:34    18:39
                                      S-16-B     19:00    19:05

    #2 Calciner East ESP Outlet
       Particulate                       19        15:50    16:58

    #2 Calciner West ESP Outlet
       Particulate                       22        15:50    16:54

    92 Calciner Stack
       Particulate                       25        15:54    17:00
       Visible Emissions                 25        15:49    16:49
       Nitrogen Oxides                25 A-D     15:56    16:56

 Test 2,  February 15, 1984

    #2 Calciner East I.D.  Fan Outlet
       Particulate                       14        09:35    12:04
       Particle Size                   S-14-A     16:14    16:29
                                      S-14-B     17:00    17:15

    #2 Calciner East I.D.  Fan Inlet
       Velocity Traverse                V-14      13:05    13:45

    #2 Calciner West I.D.  Fan Outlet
       Particulate                       17        11:15    12:00
       Particle Size                  S-17-A     16:00    16:15
                                      S-17-B     16:55    17:20

    $2 Calciner West I.D.  Fan Inlet
       Velocity Traverse                V-17      12:30    13:00

* S-13-A was overloaded; therefore no results were tabulated.

                                          (continued next page)

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                                1-7


                             TABLE 1-2
                            (continued)

                              TEST LOG

	  SULFATE PROCESS  	
Test 2, February 15, 1984               Run      Start    Finish
	             Number     Time      Time
   #2 Calciner East ESP Outlet
      Participate                       20       09:40     10:48

   #2 Calciner West ESP Outlet
      Particulate                       23       09:39     10:42

   #2 Calciner Stack
      Particulate                       26       09:39     10:56
      Visible Emissions                 26       09:35     10:35
      Nitrogen Oxides                 26 A-D     09:41     10:45

Test 3, February 15, 1984
   //2 Calciner East I.D. Fan Outlet
      Particulate                       15       14:13     14:50
      Particle Size                   S-15-A     17:40     17:55
                                      S-15-B     18:25     18:40
   #2 Calciner East I.D. Fan Inlet
      Velocity Traverse                V-15      16:00     16:30

   #2 Calciner West I.D. Fan Outlet
      Particulate                       18       14:14     15:15
      Particle Size                   S-18-A     17:51     18:16
                                      S-18-B     18:40     19:05
   #2 Calciner West I.D. Fan Inlet
      Velocity Traverse                V-18      16:40     17:15

   #2 Calciner East ESP Outlet
      Particulate                       21       14:15     15:33

   #2 Calciner West ESP Outlet
      Particulate                       24       14:14     16:22

   #2 Calciner Stack
      Particulate                       27       14:17     15:34
      Visible Emission                  27       14:16     15:16
      Nitrogen Oxides                 27 A-D     14:20     15:22

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                                     2-1
2.   SUMMARY AND DISCUSSION OF RESULTS

     2.1  Introduction.  The testing of the two TiOฃ production systems are
treated as two distinct sets of data.  Chloride process-spray dryers system
test results are discussed in Section 2.2, while the sulfate process-
it 2 calciner system testing is discussed in Section 2.3.

     2.2  Chloride Process.  A summary of the parciculate emissions and
concentrations at the chloride process sampling locations is presented in
Table 2-1; efficiencies of the control devices are summarized in Table 2-2.
Run-by-run data summaries of the particulate testing are provided by location
in Tables 2-3 to 2-6; particle sizing data is tabulated in Tables 2-7
to 2-9.  The average plume opacity was 9% (results for tests 1, 2, and 4 were
6%, 15%, and 5%, respectively); refer to Tables 2-10 to 2-12 for the
tabulated results.

     2.2.1  General.  The results presented in Table 2-2 are reasonably
consistent considering  the nature of the process and the control equipment.
Some of the variability in the data is probably due to variations in the
production loads on the two spray dryers.  It is recommended that the
production data presented in Section 3 be reviewed in conjunction with the
test results.
     The original test  plan scheduled three test sets.  However, a fourth
test was performed because the production load during the first test set was
slightly below the minimum desired load.  Only particulate and opacity
measurements were taken during the fourth test set; no particle size tests
were performed.  Because initial inspection of the test site revealed that
there were no fugitive  emissions, EMB and Entropy made a joint decision to
cancel  the scheduled Method 22 observations.
     When comparing flue gas flow rates between locations, it is important to
note the increase in excess air due to leakage through the system.  Due to
leakage of excess air into the system, the flow rates increase significantly
as the  flue gases approach the stack.

     2.2.2  #312 Baghouse Inlet.  At the #312 Baghouse Inlet, each 24-minute
test was performed such that the 24 minutes were distributed over the 120
minute  outlet sampling  period.  The efficiency calculation therefore assumes

-------
                                     2-2
that the 24-minute inlet tests are representative of the 120 minute testing
Interval.  The same Is true of the efficiency data presented for the Peterson
Scrubber, I.e., the tests at the Spray Dryers Stack and at the #312 Baghouse
Outlet lasted 120 minutes, whereas the tests at the #322 Baghouse outlet
lasted 60 minutes.
     The original test plan scheduled three sets of particle size runs (three
runs per set) at each location.  During the sampling at the #312 Baghouse
Inlet, It was observed that runs S-l-B and S-3-A were overloaded.  Two
additional runs, S-1-B2 and S-3-A2, were performed as replacements two days
after the completion of the third test set.

     2.2.3  #312 Baghouse Outlet.  At the #312 Baghouse Outlet, four particle
size runs were performed*  Very small quantities of particulate were captured
in the impactor during those runs because the flue gas particulate
concentration was low; the catch for particle size run S-6 was negligible and
is not tabulated at all in the results.  Due to the limited catch and time
constraints imposed by the plant and process operations, it appeared
impractical, if not impossible, to secure a catch which would satisfy EMB
requirements.  Therefore, a joint decision was made by EMB and Entropy to
discontinue particle size testing at this location.

     2.2.4  #322 Baghouse Outlet.  Due to the heavy particulate loading
encountered at this location during Test 1, particulate run 7 was divided
into two components which were performed, processed, and analyzed as two
separate runs.  Component run 7A was performed on 25% of the duct cross
section (one port), while component run 7B was performed on 75% of the cross
section (three ports); an equivalent run 7 was calculated from component data
using appropriate weighting parameters for averaging selected parameters,
particulate concentrations, etc.  Since only the sampled duct areas of each
component run are used in the emission rates and air flow rates calculations,
the sum of component runs 7A and 7B represents the emissions and flows of the
total cross section.
     Six particle size runs were performed at the #322 Baghouse Outlet;
however, run S-9-A was overloaded and is not tabulated.

     2.2.5  Spray Dryers Stack.  No particle size runs were performed in the

-------
                                      2-3
                                  TABLE 2-1

                 PARTIGULATE EMISSIONS  & CONCENTRATIONS  SUMMARY

                                Chloride Process
                                            Test  Set
                                            2        3
Emission Rates, Ib/hr:
  #312 Spray Dryer Baghouse
    Inlet, Runs 1-3 & 28
    Outlet, Runs 4-6 & 29

  #322 Spray Dryer Baghouse
    Outlet, Runs 7Eq-9 & 30

 •Spray Dryer Stack
    Runs 10-12 & 31
 1,412    1,818    2,041     2,024
  0.22     0.11     0.79      0.89
 507.5    506.5    480.3     357.2
  8.06     8.11      8.87      5.26
                                    Average
                              1,824
                               0.50
                              462.9
                               7.58
Concentration, Gr/DSCF:
  #312 Spray Dryer Baghouse
    Inlet, Runs 1-3 & 28
    Outlet, Runs 4-6 & 29

  #322 Spray Dryer Baghouse
    Outlet, Runs 7Eq-9 & 30

  Spray Dryer Stack
    Runs 10-12 & 31
  20.7
0.0024
  24.7
0.0011
  28.1
0.0077
  28.8
0.0091
  4.19     4.09     3.86     2.91
 0.023    0.027    0.029    0.020
  25.6
0.0051
                               3.76
                              0.025
Emission Rates, kg/hr;
  #312 Spray Dryer Baghouse
    Inlet, Runs 1-3 & 28
    Outlet, Runs 4-6 & 29

  #322 Spray Dryer Baghouse
    Outlet, Runs 7Eq-9 & 30

  Spray Dryer Stack
    Runs 10-12 & 31
 640.7    824.6    925.7    918.1       827.3
  0.10    0.052     0.36     0.40        0.23
 230.3    229.8    217.8    162.0      210.0
  3.65     3.68     4.02     2.38       3.43
Concentration, mg/DSCM;
  #312 Spray Dryer Baghouse
    Inlet, Runs 1-3 & 28
    Outlet, Runs 4-6 & 29

  #322 Spray Dryer Baghouse
    Outlet, Runs 7Eq-9 & 30

  Spray Dryer Stack
    Runs 10-12 & 31
47,336   56,437   64,202   65,855     58,458
  5.59     2.54     17.7     20.7      11.63
 9,583    9,350    8,822    6,662      8,604
  53.1     60.7     67.0     45.6       56.6

-------
                                2-4
                             TABLE 2-2
             COLLECTION EFFICIENCIES OF CONTROL DEVICES
                          Chloride Process
                               1        2       3        4      Average
//312 Spray Dryer Baghouse
   Emissions Elate, Ib/hr
      Inlet                  1,412   1,818   2,041   2,024     1,824
      Outlet                  0.22    0.11    0.79    0.89      0.50
   Collection Efficency,     99.98   99.99   99.96   99.96     99.97
         Percent
Peterson Scrubber
   Emissions Rate, Ib/hr
      Inlet*                 507.7   506.6   481.1   358.1      463.4
      Outlet                  8.06    8.11    8.87    5.26       7.58
   Collection Efficiency,    98.41   98.40   98.16   98.53      98.36
         Percent
    * "Inlet" emissions are the sum of the #312 and #322 Baghouse Outlet
      emissions rates; "Outlet" emissions are those measured at the
      Spray Dryer Stack.

-------
                               2-5
                            TABLE  2-3

                PARTICULATE TESTS SUMMARY  OF  RESULTS

                         Chloride  Process

                  #312 Spray Dryer  Baghouse Inlet
                                                                 28
Run Date                      02/09/84    02/11/84    02/11/84    02/16/84

Test Train Parameters;
  Volume of Dry Gas             16.345      11.408      10.849      10.469
    Sampled, SCF*

  Percent Isokinetic              96.2       106.7       102.9       103.8

Stack Parameters;
  Temperature, Deg. F              298         299         299        302

  Air Flow Rates
    SCFM*, Dry                   7,966       8,599       8,485       8,205

    ACFM, Wet                   14,342      15,938      15,846      15,403

Method 5 Test Results;
  Catch, Milligrams           21,911.2    18,233.2    19,725.8    19,524.9

  Concentration,
    Grains Per DSCF*             20.69       24.67       28.06       28.78

    Milligrams Per DSCM         47,336      56,437      64,202      65,855

  Emission Rate,
    Pounds Per Hour            1,412.5     1,818.0     2,040.8     2,024.1

    Kilograms Per Hour           640.7       824.6       925.7       918.1
* 68 Deg. F. - 29.92 in. Hg.

-------
                                2-6
                             TABLE 2-4




               PARTICULATE TESTS  SUMMARY OF RESULTS




                         Chloride Process




                  #312  Spray  Dryer Baghouse Outlet
                                                                 29
Run Date
Test Train Parameters:
Volume of Dry Gas
Sampled, SCF*
Percent Isokinetic
Stack Parameters:
Temperature, Deg. F
Air Flow Rates
SCFM*, Dry
ACFM, Wet
Method 5 Test Results:
Catch, Milligrams
Concentration,
Grains Per DSCF*
Milligrams Per DSCM
Emission Rate,
Pounds Per Hour
Kilograms Per Hour
02/09/84

83.379
106.7

260

10,711
17,985

13.2

0.0024
5.59

0.22
0.10
02/11/84

95.903
109.4

269

12,017
20,286

6.9

0.0011
2.54

0.11
0.052
02/11/84

96.103
110.4

271

11,936
20,282

48.2

0.0079
17.7

0.79
0.36
02/16/84

82.161
97.9

270

11,504
19,089

48.2

0.0091
20.7

0.89
0.40
* 68 Deg. F. - 29.92 in. Hg.

-------
                                 2-7
                              TABLE 2-5

                PARTICULATE TESTS SUMMARY OF RESULTS

                          Chloride Process

                  #322 Spray Dryer Baghouse Outlet
Run Date

Test Train Parameters;
  Volume of Dry Gas
    Sampled, SCF*

  Percent Isoklnetic

Stack Parameters;
  Temperature, Deg. F

  Air Flow Rates
    SCFM*, Dry

    ACFM, Wet

Method 5 Test Results;
  Catch, Milligrams

  Concentration,
    Grains Per DSCF*

    Milligrams Per DSCM

  Emission Rate,
    Pounds Per Hour

    Kilograms Per Hour
                                7Eq
               8
106.
    2060)
              103.8
              218
95.3
 218
                                 30
02/09/84   02/11/84   02/11/84   02/16/84
 23.327(D    23.346    21.521     23.182
104.2
  222
 14,140(1)    14,462    14,532     14,311

 21,848(1)    22,971    22,199     21,971


      NA    6,181.6    5,376.9    4,373.7


   4.19(3)     4.09       3.86       2.91

  9,583(3)    9,350      8,822      6,662


  507.5(1)    506.5      480.3      357.2

  230.3(1)    229.8      217.8      162.0
  * 68 Deg. F. - 29.92 in. Hg.
  (D Sum of 7A and 7B
  (2) Average of 7A and 7B
  (3) Average weighted by flow rate (7A & 7B)

-------
                                2-8
                             TABLE 2-6




               PARTICULATE TESTS SUMMARY OF RESULTS



                         Chloride Process




                        Spray Dryers Stack
                                10         11         12         31
Run Date
Test Train Parameters:
Volume of Dry Gas
Sampled, SCF*
Percent Isokinetic
Stack Parameters:
Temperature, Deg. F
Air Flow Rates
SCFM*. Dry
ACFM, Wet
Method 5 Test Results:
Catch, Milligrams
Concentration,
Grains Per DSCF*
Milligrams Per DSCM
Emission Rate,
Pounds Per Hour
Kilograms Per Hour
02/09/84

115.727
106.8

124

40,507
. 51,013

174.0

0.023
53.1

8.1
3.65
02/11/84

95.630
100.3

136

35,636
47,515

164.5

0.027
60.7

8.1
3.68
02/11/84

96.121
101.8

124

35,317
44,659

182.5

0.029
67.0

8.9
4.02
02/16/84
-
86.013
105.6

135

30,773
41,778

111.1

0.020
45.6

5.3
2.38
* 68 Deg. F. - 29.92 in. Hg.

-------
                                    2-9
                                 TABLE 2-7

                   SUMMARY OF PARTICLE SIZING TEST RESULTS

                             #312 Baghouse Inlet
SAMPLING DATA

  Dace

  Stare Time
  Finish Time

  Total Run Time, minutes

  Impactor Flow Rate (1pm)

  Isokinetic Ratio (%)


STACK DATA

  Temperature (ฐC)

  Moisture (Z)

  Velocity (m/mln)


EMISSION DATA

  Concentration (mg/dsm3)

  Percent Recovery (PS cone./
      M-5 cone.)

  Cumulative X Mass less than
      10 microns

  Concentration less than 10 microns:
    From PS runs, mg/dsrn^

    From M-5 runs, mg/dsm^

  Emission Rate less than 10
      microns (kg/hr, from M-5  runs)
PS Run 1*
2/09,13/84
1556, 1640
1557, 1641
2
21.9
106.0
148
21.4
1,238
37,385
79.0
14.57
ins:
5,070
6,897
93.3
PS Run 2*
2/11/84
1240, 1319
1241, 1320
2
24.4
108.7
149
22.2
1,337
20,970
37.2
33.91
7,840
19,138
279.6
PS Run 3*
2/11,13/84
1452, 1649
1452, 1650
2
24.2
107.0
150
22.8
1,355
20,455
31.9
29.65
6,160
19,036
274.5
Average
	
	
	
	
___
149
22.1
1,310
26,270
49.4
26.04
6,357
15,024
215.8
 PS: Particle Size Run
M-5: Method 5 Participate Run
  *: Represents two component runs,  A &  B.

-------
                               2-10

                   PARTICLE  SIZE DISTRIBUTION



COMPANY NAME  American Cyanamid Company


ADDRESS   Savannah.  Georgia	
AVERAGE OF RUNS   1.  2.  3
SAMPLING LOCATION  #312 Baghouse  Inlet

DATE(sJ   02/09/84,,02/-11/8VW  _   	
                             DENSITY = J GM/CM
     100
  I
  I
   o

   ID
  K

  0)


  13
  u

30 *
70 5

50 =
rtft.. -
30- =


3 :
8—:
7—;
s—:
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7 -

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               I T II ^  ^ I '^'^i^1'' I'lTI III1I1ITT lilllllirilll il!l III) III! IIIIIMII ITI I I I IT. 1 I 1 I  I  I  I





            2     5    10   IS 20   30  40 50  60  70  80 85 90    95    98
                     PERCENT OF PARTICLES LESS THAN INDICATED  SIZE

-------
                                       2-11
                                    TABLE 2-8

                     SUMMARY OF PARTICLE SIZING TEST  RESULTS

                               #312 Baghouse Outlet
SAMPLING DATA
PS Run 4*
PS Run 5
                                                                       Average
Date
Start Time
Finish Time
Total Run Time, minutes
Impactor Flow Rate (1pm)
Isokinetic Ratio (Z)
STACK DATA
Temperature (ฐC)
Moisture (%)
Velocity (m/min)
EMISSION DATA
Concentration (mg/dsm^)
Percent Recovery (PS cone./
M-5 cone.)
Cumulative Z Mass less than
10 microns
Concentration less than 10 microns
From PS runs, mg/dsm^
From M-5 runs, mg/dsm^
Emission Rate less than 10
2/09/84
1403, 1615
1512, 1700
110
24.1
109.1

127
18.7
585

9.92
177.46**
83.63

•
•
8.21
4.67
0.0836
2/11/84
0930
1300
210
25.8
113.6

134
19.1
481

1.24
48.82
95.20

1.18
2.42
0.0495
	
	
	
	
	

131
18.9
533

5.58
113.2
89.42

4.70
3.55
0.0666
      microns (kg/hr, from M-5 runs)
 PS: Particle Size Run
M-5: Method 5 Particulate Run
  *: Represents two component runs, A & B
 **: Excessive preseparator catch

-------
                              2-12
                  PARTICLE SIZE DISTRIBUTION

COMPANY NAME  American Cyanamid Company
ADDRESS Savannah,. Georgia	
SAMPLING LOCATION  #312 Baghouse Outlet
DATE(s) 02/Q9/84, 02/11/84	
AVERAGE OF RUNS.
               4,  5
                           DENSITY =  I GM/CM
 I
 u
 s
   o
   in
  K
  0)
  u
  u


70 -

50 :
no -
3O , :

f ft
9 :




j



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ft _=
7 =


A. S

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IS 9
                   PERCENT OF PARTICLES LESS THAN INDICATED SIZE

-------
                                      2-13
                                   TABLE 2-9

                    SUMMARY OF PARTICLE SIZING TEST RESULTS

                              #322 Baghouse Outlet
SAMPLING DATA

  Date

  Start Time
  Finish Time

  Total Run Time, minutes

  Impactor Flow Rate (1pm)

  Isokinetic Ratio (Z)


STACK DATA

  Temperature (ฐC)

  Moisture (Z)

  Velocity (m/min)


EMISSION DATA

  Concentration (mg/dsm^)

  Percent Recovery (PS  cone./
      M-5 cone.)

  Cumulative Z Mass less than
      10 microns

  Concentration less than 10 microns:
    From PS runs, mg/dsm^

    From M-5 runs, mg/dsm3

  Emission Rate less than 10
      microns (kg/hr, from M-5  runs)
PS Run 7*
2/09/84
521, 1545
522, 1546
2
17.9
76.3
99
15.7
1,757
5,020
52.4
66.64
is:
3,270
6,386
153.5
PS Run 8*
2/11/84
1050, 1155
1051, 1156
2
13.7
81.2
104
16.8
1,031
5,860
62.7
63.67
3,650
5,953
146.3
PS Run 9*
2/11/84
1610
1611
1
12.8
93.7
104
13.6
1,017
4,838
54.8
68.76
3,326
6,066
149.8
Average
	
	
	
— —
102
15.4
1,268
5,239
56.6
66.40
3,415
6,135
149.9
 PS: Particle Size Run
M-5: Method 5 Particulate Run
  *: Represents two component runs,  A &  B.

-------
                              2^14
                 PARTICLE SIZE DISTRIBUTION
COMPANY NAME  American Cyanamid Company
ADDRESS Savannah,,  Georgia _
SAMPLING
                 #322 Baghouse Outlet
         027(19784..  02/11/84
AVERAGE OF RUNS.
                1,  8, 9
                           DENSITY = 1 GM/CM
  u
  i
  o
  in
  U
  N
  yj
  u
  u
on . a

70..,,.,.=

go...- .. =
40 ^
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IS 9
                   PERCENT OF PARTICLES LESS THAN  INDICATED SIZE

-------
                                     2-15
                                  TABLE 2-10




                           AMERICAN CYANAMID COMPANY




                   SUMMARY OF VISIBLE EMISSIONS OBSERVATIONS




                              SPRAY DRYERS STACK
Date: 2/09/84




Run Number: 10




Highest 6 Minute Average Opacity, Z:  7.50




Highest Single Opacity Reading, Z: 10
Set
No.
1
2
3
4
5
6
7
8
9
10
Time
Start
0935
0941
0947
0953
0959
1005
1011
1017
1023
1029
End
0941
0947
0953
0959
1005
1011
1017
1023
1029
1035
Avg. %
Opacity
5.00
5.21
5.63
5.00
5.42
5.21
4.58
6.04
6.67
5.63
Set
No.
11
12
13
14
15
16
17
18
19
20
Time
Start
1035
1041
1047
1053
1059
1105
1111
1117
1123
1129
End
1041
1047
1053
1059
1105
1111
1117
1123
1129
1135
Avg. %
Opacity
5.00
5.63
6.04
5.21
5.63
4.58
6.67
5.63
7.50
5.00

-------
                                     2-16
                                  TABLE 2-11




                          AMERICAN CYANAMID COMPANY




                  SUMMARY OF VISIBLE EMISSIONS  OBSERVATIONS




                              SPRAY DRYERS STACK
Date: 2/11/84




Run Number: 11




Highest 6 Minute Average Opacity, %:  19.4




Highest Single Opacity Reading, %:  25
Set
No.
1
2
3
4
5
6
7
8
9
10
Time
Start
0902
0908
0914
0920
0926
0932
0938
0944
0950
0956
End
0908
0914
0920
0926
0932
0938
0944
0950
0956
1002
Avg. %
Opacity
12.3
12.3
13.3
16.7
14.8
17.9
18.3
19.4
19.4
17.1
Set
No.
11
12
13
14
15
16
17
18
19
20
Time
Start
1002
1008
1014
1020
1026
1032
1038
1044
1050
1056
End
1008
1014
1020
1026
1032
1038
1044
1050
1056
1062
Avg. %
Opacity
16.9
14.8
15.2
15.0
14.0
12.9
14.2
12.5
11.9
13.5

-------
                                     2-17
                                  TABLE 2-12




                          AMERICAN CYANAMID COMPANY




                  SUMMARY OF VISIBLE EMISSIONS OBSERVATIONS




                              SPRAY DRYERS STACK
Date: 2/16/84




Run Number: 31




Highest 6 Minute Average Opacity, %:  6.46




Highest Single Opacity Reading, %: 15
Set
No.
1
2
3
4
5
6
7
8
9
10
Time
Start
1005
1011
1017
1023
1029
1035
1041
1047
1053
1059
End
1011
1017
1023
1029
1035
1041
1047
1053
1059
1105
Avg. %
Opacity
6.46
6.04
10.0
4.17
4.38
1.46
2.08
2.92
5.00
4.17
Set
No.
11
12
13
14
15
16
17
18
19
20
Time
Start
1105
1111
1117
1123
1129
1135
1141
1147
1153
1159
End
1111
1117
1123
1129
1135
1141
1147
1153
1159
1205
Avg. Z
Opacity
5.00
5.00
4.58
4.79
3.75
3.54
3.13
2.92
2.71
3.54

-------
                                     2-18
Spray Dryers Stack due to the presence of water droplets in the flue gas.
Method 9 was not performed because of cloudy weather conditions.

     2.3  Sulfate Process.  A summary of the particulate emissions and
concentrations at the sulfate process sampling locations is presented in
Table 2-13; efficiencies of the control devices are summarized in Table 2-14.
Run-by-run data summaries of the particulate and  sulfate testing are provided
by location in Tables 2-15 to 2-19; particle sizing data is tabulated in
Tables 2-20 and 2-21.  Nitrogen oxides as NC>2 concentrations at the #2
Calciner Stack, although essentially zero, averaged 2.3 ppm dry for the three
runs.  Nitrogen oxides results for each run are included in Table 2-21.
Average plume opacity readings during the three tests were zero; refer to
Appendix 7.4.6 for the field data.
             \

     2.3.1  General.  As shown in Table 2-13 there is some variability in  the
test results from one test set to the next.  Uncontrolled variables which
could have affected  the testing and influenced the test results include
changes in the process operations during the testing, fluctuations in the
performance of the control equipment, and particulate and gas  flow pattern
oscillations resulting from the lack of straight  run at the sampling locations
(only the stack had  enough straight run to satisfy Method 1 requirements).
Due to  the potential  for variability, the average results of the three runs  at
a given location is  more reliable and should be used wherever  possible.
     When comparing  flue gas flow rates between locations, it  is important to
note the increase in excess air due to leakage through  the system.  There  is,
in  fact, an ambient  air vent between the precipitator outlets  and the scrubber
which is designed to allow excess air into the gas stream.  Due to the
introduction  of excess air into the system, the flow rates increase
significantly as the flue gases approach the stack.
     Plans to perform Method 22 were abandoned when initial observation
revealed that emissions were steam rather than product.  Consequently, no
Method 22 results are presented.

     2.3.2  East and West I.D. Fan Outlets.  At both the East  and West I.D.
Fan Outlets,  extremely poor flue gas flow patterns were encountered.  Of
the 24  points in each duct, 12 showed a positive  flow,  and 12  showed  a

-------
                                     2-19
negative flow.  For this reason, after the first test set (runs 13 and 16),
additional flue gas velocities and flow rates were measured upstream of the
1.0. fans (East and West I.D. Fan Inlets) at locations which provided more
stable flow patterns; the flow rates measured upstream of the fans were used
to calculate the particulate emissions rate.  The participate concentrations
were still measured at the I.D. Fan Outlets by sampling only the positive
flow points.  The decision to continue sampling at the I.D. fan outlets was
justified by assuming that the majority of the particles were less than ten
microns in size and that the minute particles would tend to behave like
gases, minimizing the importance of isoklnetics and stable flow patterns.
Particle size distribution data from these locations does indicate mass
median diameters of less than ten microns.
     Six particle size runs were performed at each of the I.D. Fan Outlets.
Run S-13-A, performed on the East Side, was underloaded and therefore was not
presented in the summary of results section.  All six particle size runs
performed at the West Side I.D. Fan Outlet are presented.

     2.3.3  East and West ESP Outlets.  No major problems were encountered at
the ESP outlets although the flow patterns were somewhat erratic.  Particle
sizing was not performed at the ESP outlets because of the presence of water
droplets in the flue gas.
     Method 3 was not performed for particulate runs 19 and 22 at the East
and West ESP outlets, respectively.  Flue gas composition data from
subsequent runs at the respective locations was used for calculation
purposes:  data from run 20 was used for run 19, while data from run 23 was
used for run 22.

     2.3.4  #2 Calciner Exhaust Stack.  Particle sizing was not performed at
the #2 Calciner Exhaust Stack because of the presence of water droplets in
the flue gas.

     2.3.5  #2 Calciner Product Outlet.  The performance of Method 22 was
abandoned when the observers determined that the fugitive emissions were
steam rather than product.

-------
                                     2-20
                                 TABLE 2-13

                PARTICIPATE EMISSIONS & CONCENTRATIONS  SUMMARY

                               Sulfate Process
Emission Rates, Ib/hr;
  #2 Calciner Stack
    Runs 25-27
                                   	 Test  Set
                                    1         2
                           Average
I.D. Fan Outlet
East, Runs 13-15
West, Runs 16-18
ESP Outlet
East, Runs 19-21
West, Runs 22-24
#2 Calciner Stack
Runs 25-27
Emission Rates, kg/hi:
I.D. Fan Outlet
East, Runs 13-15
West, Runs 16-18
ESP Outlet
East, Runs 19-21
West, Runs 22-24
#2 Calciner Stack
Runs 25-27
Concentration, Gr/DSCF:
I.D. Fan Outlet
East, Runs 13-15
West, Runs 16-18
ESP Outlet
East, Runs 19-21
West, Runs 22-24
#2 Calciner Stack
Runs 25-27
Concentration, mg/DSCM:
I.D. Fan Outlet
East, Runs 13-15
West, Runs 16-18
ESP Outlet
East, Runs 19-2.1
West, Runs 22-24
181.2
98.5
4.80
3.82
2.13
146.7
33.2
2.18
1.73
0.87
1.956
1.504
0.0411
0.0402
0.0057
4,474.5
3,440.2
94.1
92.0
283.8
113.1
9.42
3.73
0.43
239.6
33.7
4.27
1.69
0.19
2.989
1.810
0.0739
0.0405
0.0011
6,839.8
4,141.9
169.0
92.7
270.4
144.7
4.28
4.20
1.01
206.2
39.1
1.94
1.90
0.46
2.993
2.112
0.0451
0.0448
0.0026
6,847.7
4,832.7
103.1
102.5
245.1
118.8
6.17
3.92
1.19
197.5
35.3
2.80
1.77
0.51
2.646
1.809
0.0534
0.0418
0.0031
6,720.6
4,138.3
122.1
95.7
0.87
0.19
0.46
0.51

-------
                               2-21
                            TABLE 2-14
            COLLECTION EFFICIENCIES OF CONTROL DEVICES
                          Sulfate Process
                             	  Test Set  	
                               1         2         3       Average
Peterson Scrubber
   Emissions Rate, Ib/hr
      Inlet*                  8.62     13.15      8.48       10.08
      Stack                   2.13      0.43      1.01        1.19
   Collection Efficiency,    75.29     96.73     88.09        86.7
         Percent
      "Inlet" emissions are the sum of the East and West ESP Outlet
      emissions; "Stack" emissions are .the #2 Calciner Stack emissions.

-------
                                2-22
                                                  \
                             TABLE 2-15

                PARTICOLATE TESTS SUMMARY OF RESULTS

                           Sulfate Process

                  //2 Calciner, East I.D. Fan Outlet
   13
   14
                                                               15
Run Date

Test Train Parameters;
  Volume of Dry Gas
    Sampled, SCF*

  Percent Isokinetic

Stack Parameters;
  Temperature, Deg. F

  Air Flow Rates**
    SCFM*, Dry

    ACFM, Wet

Method 5 Test Results;
  Catch, Milligrams

  Concentration,
    Grains Per DSCF*

    Milligrams Per DSCM

  Emission Rate,
    Pounds Per Hour

    Kilograms Per Hour
                                 02/14/84     02/14/84     02/14/84
 19.512


   95.7


    603


 10,809

 30,684


2,472.5
  181.2

  146.7
 20.785


   95.4


    598


 11,078

 31,517


4,026.1
  283.8

  139.6
                                                             11.396


                                                               87.4


                                                                560


                                                             10,539

                                                             29,850


                                                             2,210.0
                                     1.956         2.989        2.993

                                   4,474.5       6,839.8      6,847.7
                                                              270.4

                                                              206.2
 * 68 Deg. F. - 29.92 in. Hg.

** Air flow rates are taken from velocity traverses performed  at  the #2
   Calciner East I.D. Fan Inlet after Run 14  and Run 15;  the average of
   the air flows from Run 14 and Run 15 were  used for Run 13.

-------
                                2-23
                             TABLE 2-16

                 PARTICULATE TESTS SUMMARY OF RESULTS

                           Sulfate Process

                   ฃ2  Calciner, West  I.D. Fan Outlet
                                     16
                 17
                18
 Run Date

 Test Train Parameters;
   Volume of Dry Gas
     Sampled, SCF*

   Percent Isokinetic

 Stack Parameters;
   Temperature, Deg. F

   Air Flow Rates**
     SCFM*, Dry

     ACFM, Wet

 Method 5 Test Results;
   Catch, Milligrams

   Concentration,
     Grains Per DSCF*

     Milligrams Per DSCM

   Emission Rate,
     Pounds Per Hour

     Kilograms Per Hour
02/14/84     02/15/84     02/15/84
  14.415
    93.1
     523
 1,404.4
    98.5

    33.2
 12.470
   95.5
    480
1,462.7
  113.1

   33.7
 12.748
   98.2
    482
7,641
20,219
7,289
19,295
7,992
21,143
1,744.7
   1.504        1.810        2.112

 3,440.2      4,141.9      4,832.7
  144.7

   39.1
 * 68 Deg. F. - 29.92 in. Hg.

** Air flow rates are taken from velocity  traverses  performed at  the #2
   Calciner West I.D. Fan Inlet after Run  17  and Run 18; the average of
   the air flows from Run 17 and Run 18 were  used  for Run 16.

-------
                                2-24
                             TABLE 2-17

                PARTIGULATE TESTS SUMMARY OF RESULTS

                           Sulfate Process

                    #2 Calciner, East ESP Outlet
Run Date

Test Train Parameters;
  Volume of Dry Gas
    Sampled, SCF*

  Percent Isoklnetlc

Stack Parameters;
  Temperature, Deg. F

  Air Flow Rates
                                     19
                 20
  39.407
   100.4
     150
44.150
 103.0
   150
               21
02/14/84     02/15/84     02/15/84
32.909
 103.0
   148
SCFM*, Dry
ACFM, Wet
Method 5 Test Results:
Catch, Milligrams
Concentration,
Grains Per DSCF*
Milligrams Per DSCM
Emission Rate,
Pounds Per Hour
Kilograms Per Hour
13,623
20,282
105.0
0.0411
94.1
4.80
2.18
14,873
22,934
211.3
0.0739
169.0
9.42
4.27
11,081
16,742
96.1
0.0451
103.1
4.28
1.94
* 68 Deg. F. - 29.92 in. Hg.

-------
                                2-25
                             TABLE 2-18

                PARTICULATE TESTS SUMMARY OP RESULTS

                           Sulfate Process

                    #2 Calciner,  West ESP Outlet
Run Date

Test Train Parameters;
  Volume of Dry Gas
    Sampled, SCF*

  Percent Isokinetic

Stack Parameters;
  Temperature, Deg. F

  Air Flow Rates
                                     22
                 23
  53.241
    99.2
     137
52.246
 100.4
   131
               24
02/14/84     02/15/84      02/15/84
52.063

  98.3


   130
SCFM*, Dry
ACFM, Wet
Method 5 Test Results:
Catch, Milligrams
Concentration,
Grains Per DSCF*
Milligrams Per DSCM
Emission Rate,
Pounds Per Hour
Kilograms Per Hour
11,071
14,949
138.7
0.0402
92.0
3.82
1.73
10,740
14,200
137.1
0.0405
92.7
3.73
1.69
10,932
14,362
151.1
0.0448
102.5
4.20
1.90
* 68 Deg. F. - 29.92 in. Hg,

-------
                                2-26


                             TABLE 2-19

                PARTICULATE TESTS SUMMARY OF RESULTS

                           Sulfate Process

                          #2 Calciner Stack
                                     25

Run Date                         02/14/84

Test Train Parameters;
  Volume of Dry Gas                71.033
    Sampled, SCF*

  Percent Isokinetic                105.4

Stack Parameters;
  Temperature,, Deg. F                 132

  Air Flow Rates
    SCFM*, Dry                     43,650

    ACFM, Wet                      55,030

Method 5 Test Results;
  Catch, Milligrams                  26.2

  Concentration,
    Grains Per DSCF*

    Milligrams Per DSCM

  Emission Rate,
    Pounds Per Hour

    Kilograms Pe:r Hour

Total Sulfates as H2S04;
  Catch, Micrograms                 5,121

  Concentration,
    Grains Per DSCF*              0.00111
    Milligrams Per DSCM              2.55

  Emission Rate,
    Pounds Peir E!our                 0.416

    Kilograms Per Hour              0.189

* 68 Deg. F. - 29.9.2  in. Hg.
    26
02/14/84


  91.275

   108.7


     128

  43,421

  55,066

     6.8
   6,248

  0.0011
    2.41

   0.393
   0.178
    27

02/14/84


  91.218

   105.5


     132

  44,748

  55,426

    15.6
0.0057
11.7
2.13
0.87
0.0011
2.63
0.43
0.19
0.0026
6.04
1.01
0.46
   4,902

0.000829

    1.90

   0.318
   0.144

-------
                                       2-27
                                    TABLE 2-20

                      SUMMARY OF  PARTICLE SIZING TEST RESULTS

                               East I.D. Fan Outlet
SAMPLING DATA

  Date

  Start Time
  Finish Time

  Total Run Time, minutes

  Impactor Flow Rate (1pm)

  Isokinetic Ratio (Z)


STACK DATA

  Temperature (ฐC)

  Moisture (Z)

  Velocity (m/min)


EMISSION DATA

  Concentration (mg/dsm^)

  Percent Recovery (PS cone./
      M-5 cone.)

  Cumulative Z Mass less than
      10 microns

  Concentration less than 10 microns:
    From PS runs, mg/dsm^

    From M-5 runs, mg/dsm^

  Emission Rate less than 10
      microns (kg/hr, from M-5 runs)
 PS: Particle Size Run
M-5: Method 5 Particulate Run
  *: Represents two component runs,  A & B.
PS Run 13
2/14/84
1837
1842
5
20.5
97.6
319
22.2
1,293
952.1
21.3
55.46
is:
528.9
2,482
81.4
PS Run 14*
2/15/84
1614, 1700
1629, 1715
30
21.5
97.2
311
24.2
1,017
1,060
15.5
57.64
553.0
3,943
80.5
PS Run 15*
2/15/84
1740, 1825
1755, 1840
30
20.9
94.3
312
23.3
1,015
1,795
26.2
80.08
1,440
5,484
165.1
Average
	
	
	
	
	
314
23.2
1,108
1,269
21.0
64.39
840.6
3,970
109.0

-------
                               2-28

                  PARTICLE SIZE  DISTRIBUTION
COMPANY NAME _ American  Cyanamid Company

ADDRESS   Savannah, Georgia _

SAMPLING LQgATioisi  #2 Calciner East  I. 'P. Fan Outlet

PATE(S>   02/14/84, 02/15/84  _
AVERAGE OF RUNS.
                 , 14,  15
                           DENSITY = I  CM/CM
  ง

  8
  u
  o
  in
  3
  (0

  u

  u


70.,.. =

50.. '
1


I o




5 — "

3s
A "

9 a
a ... a
7 5



3™
2

. I —













































































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V-


















































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                I     I   I   I    I   I    I   I   I    I  I   I     I   '
                5   10  15 20   30  40 50 60 70  80 85  90    95   98
                   PERCENT OF PARTICLES LESS THAN INDICATED SIZE

-------
                                       2-29
                                    TABLE 2-21

                      SUMMARY OF PARTICLE SIZING TEST RESULTS

                               West I.D. Fan Outlet
SAMPLING DATA

  Date

  Start Time
  Finish Time

  Total Run Time, minutes

  Impactor Flow Rate (1pm)

  Isokinetic Ratio (Z)


STACK DATA

  Temperature (ฐC)

  Moisture (Z)

  Velocity (m/min)


EMISSION DATA

  Concentration (mg/dsm^)

  Percent Recovery (PS cone./
      M-5 cone.)

  Cumulative Z Mass less than
      10 microns

  Concentration less than 10 microns:
    From PS runs, mg/dsm^

    From M-5 runs, mg/dsm^

  Emission Rate less than 10
      microns (kg/hr, from M-5 runs)
 PS: Particle Size Run
M-5: Method 5 Particulate Run
  *: Represents two component runs,  A & B.
PS Run 16*
2/14/84
1834, 1900
1839, 1905
10
16.8
96.3
273
18.3
279.8
598.1
17.4
60.88
>ns:
370
2,094
20.2
PS Run 17*
2/15/84
1600, 1655
1615, 1720
40
10.6
87.9
260
18.1
246.9
321.5
7.76
72.08
231
2,986
24.3
PS Run 18*
2/15/84
1751, 1840
1816, 1905
50
11.4
94.6
259
20.2
248.7
656.4
13.6
71.29
492
3,445
27.9
Average
	
	
	
	
_—
264
18.9
258.5
525.3
12.9
68.08
364
2,842
24.1

-------
                             2-30

                 PARTICLE SIZE DISTRIBUTION


COMPANY NAME  American Cyanamid Company

ADDRESS  Savannah Georgia	

SAMPLING LOCATION  #2 Calclner West I.D. Fan  Outlet

DATE( s)  02/J4/84.  02/15/84  	



                           DENSITY = I GM/CM3
AVERAGE OF RUNS.
               16,  17, 18


70- -;

50— -:
40 '


CO *
S :
o
5 10 "
9 l
~ 9 !
S ! i

H g :
5 3 i
ฐ 4 ^
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in :
Q 3 :
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                I     riii "i"""11
                5    10  15  20   30  40  50  60  70   80 85 90    95   98
                   PERCENT OF PARTICLES LESS THAN INDICATED SIZE

-------
                   2-31
               TABLE 2-22




        AMERICAN  CYANAMID COMPANY




SUMMARY OF VISIBLE EMISSIONS OBSERVATIONS




            If 2 CALCINER STACK








  Date: 2/14/84




  Run Number:  25




  Highest 6 Minute Average Opacity, Z:  0




  Highest Single  Opacity Reading, %: 0
Set
No.
1
2
3
4
5
6
7
8
9
10
Time
Start
1549
1555
1601
1607
1613
1619
1625
1631
1637
1643

End
1555
1601
1607
1613
1619
1625
1631
1637
1643
1649
Avg. I
Opacity
0
0
0
0
0
0
0
0
0
0

-------
                   2-32
                TABLE 2-23




        AMERICAN CYANAMID COMPANY




SUMMARY OF VISIBLE EMISSIONS OBSERVATIONS




            #2 CALCINER STACK









  Date: 2/15/84




  Run Number: 26




  Highest 6 Minute Average Opacity, %:  0




  Highest Single Opacity Reading, %:  0
Set
No.
1
2
3
4
5
6
7
8
9
10
Time
Start
0935
0941
0947
0953
0959
1005
1011
1017
1023
1029

End
0941
0947
0953
0959
1005
1011
1017
1023
1029
1035
Avg. %
Opacity
0
0
0
0
0
0
0
0
0
0

-------
                   2-33
                TABLE 2-24




        AMERICAN CYANAMID COMPANY




SUMMARY OF VISIBLE EMISSIONS OBSERVATIONS




            #2 CALCINER STACK








  Date: 2/15/84




  Run Number: 27




  Highest 6 Minute Average Opacity, %:  0.42




  Highest Single Opacity Reading, %: 5
Set
No.
1
2
3
4
5
6
7
8
9
10
Time
Start
1416
1422
1428
1434
1440
1446
1452
1458
1504
1510

End
1422
1428
1434
1440
1446
1452
1458
1504
1510
1516
Avg. Z
Opacity
0
0
0
0
0
0
0
0
0.42
0

-------
                             2-34
                          TABLE 2-25




            NITROGEN OXIDES  (AS N02) TESTING SUMMARY



                         Sulfate Process




                        #2 Calciner Stack

Run Date
Sample Numbers
Sampling Period
Nitrogen Oxides
1
02/14/84
25A-25D
1556-1656
(as N02) Results:
&un numoers
2
02/15/84
26A-26D
0941-1045

3
02/15/84
27A-27D
1420-1522

Concentration, ppm, dry
2.1
1.9
2.9

-------
                                     3-1
3. PROCESS DESCRIPTION AND OPERATION                                       /

     3.1  Introduction.  Source emission tests were conducted on Spray
Dryer #312, Spray Dryer #322, and Rotary Calciner #2 at the American Cyanamid
Company, Savannah, Georgia from February 8 through 16, 1984; Table 1
tabulates the tests performed.  The tests were conducted by Entropy
Environmentalists, Inc. (Entropy) test crew, headed by Mr. Frank Phoenix.
The process was monitored by Mr. Yogesh Doshi and Ms. Lynda Carney of Midwest
Research Institute (MRI).  Mr. William Trees of American Cyanamid coordinated
testing with plant personnel and provided process information.  Mr. Dan
Blvins of EPA's Emissions Measurement Branch (EMB) was present during testing
to observe emission testing procedures.

     3.2  Pollutants/Sampling Points.

     3.2.1   Spray Dryers.  Four tests on Spray Dryer #312 and Spray Dryer
#322 were completed at the following locations:

     3.2.1.1  Particulate Mass and Particle Size.  Particulate mass
determinations were performed at the inlet and outlet of the #312 Baghouse,
the outlet of the #322 Baghouse, and at the Peterson Scrubber Stack.
Particle size determinations were performed at the inlet and outlet of the
#312 Baghouse and the outlet of the #322 Baghouse during runs 1,2, and 3.
Particle size determinations were not performed at the Peterson Scrubber
Stack because of the: large amount of water vapor in the gas stream.  Entropy
and EMB personnel decided not to perform particle size runs simultaneously
with mass runs because of the complexity of the test program.

     3.2.1.2  Visible Emissions.  Visible emission observations were made at
the Peterson Scrubber Exhaust Stack throughout runs 1 and 4.  Opacity
readings could not be made during runs 2 and 3 because of overcast sky
conditions.  Because: the spray dryer process inlet and outlet were totally
enclosed, no process fugitive emission observations were taken.

     3.2.1.3  Feed and Product Samples.  Feed  samples were  collected at  the
inlets  to both spray dryers  for particle size  and moisture  analysis.  Product
samples from the settling chamber of the #312  Spray Dryer and from the

-------
                                    3-2
      TABLE 1.  EMISSION TESTS CONDUCTED AT AMERICAN CYANAMID COMPANY
Sampling point
Test type
Test method
Spray Dryers
No. 312 spray dryer feed inlet
No. 312 settling chamber product
  oulet

No. 312 baghouse inlet
No. 312 baghouse outlet



No. 312 baghouse product outlet


No. 322 spray dryer feed inlet


No. 322 baghouse outlet



No. 322 baghouse product outlet


Petersen scrubber exhaust stack


Rotary Calciner No. 2
Rotary calciner feed inlet


Rotary calciner product outlet


East conditioning tower inlet



West conditioning tower inlet
Moisture content
Particle size sieve

Moisture content
Particle size sieve

Particulate concentration
Particle size
Particulate concentration
Particle size
Moisture content
Particle size sieve

Moisture content
Particle size sieve

Particulate concentration
Particle size
Moisture content
Particle size sieve

Visible emissions
Particulate concentration
Moisture content
Particle size sieve

Moisture content
Particle size sieve

Particulate concentrations
Particle size
Particulate concentration
Particle size
 ASTM-D422
 ASTM-02216

 ASTM-D422
 ASTM-D2216

 EPA-5
 EPA Draft
 Method

 EPA-5
 EPA Draft
 Method

 ASTM-0422
 ASTM-02216

 ASTM-0422
 ASTM-D2216

 EPA-5
 EPA Draft
 Method

 ASTM-D422
 ASTM-02216

 EPA-9
 EPA-5
 ASTM-0422
 ASTM-02216

 ASTM-D422
 ASTM-02216

 EPA-5
 EPA Draft
 Method

 EPA-5
 EPA Draft
 Method
                                                               (continued)

-------
                                       3-3
                           TABLE 1.  (continued)
Sampling point
Test type
Test method
East wet ESP outlet

West wet ESP outlet

Peterson scrubber exhaust stack
Particulate concentration

Particulate concentration

Visible emissions
Particulate concentration
Acid mist
NO
Rotary Direct Dryer'  (Chloride.ore dryer)
Rotary direct dryer feed inlet


Rotary direct dryer outlet
Moisture content
Particle size sieve

Moisture content
Particle size sieve
Steam-Tube Rotary Dryer (Sulfate ore dryer)
Steam-tube rotary dryer feed
  inlet

Steam-tube rotary dryer
  outlet

Tunnel Dryer (Sulfate process)

Rotary direct dryer feed inlet


Rotary direct dryer outlet
Moisture content
Particle size sieve

Moisture content
Particle size sieve
Moisture content
Particle size sieve

Moisture content
Particle size sieve
 EPA-5

 EPA-5

 EPA-9
 EPA-5
 EPA-8
 EPA-7
 ASTM-D422
 ASTM-D2216

 ASTM-0422
 ASTM-02216
 ASTM-0422
 ASTM-D2216

 ASTM-0422
 ASTM-D2216
 ASTM-0422
 ASTM-02216

 ASTM-0422
 ASTM-02216
 Grab samples were not collected because the unit was not operating.
 American Cyanamid will send the samples by mail when the unit resumes
 operation.

-------
                                     3-4
product hoppers of Che #312 and #322 Baghouses were also collected for
particle size and moisture analysis.

     3.2.2  Rotary Calciner No. 2.  Tests on Rotary Calciner 92 were
completed at the following locations:

     3.2.2.1  Participate Mass and Particle Size.  Particulate mass and
particle size determinations were performed at the inlets to the two
conditioning towers.  Entropy and EMB personnel decided not to perform
particle size runs simultaneously with mass runs because of the complexity of
the test program.  Only particulate mass determinations were performed at the
outlets of the two ESP's and the outlet of the Peterson Scrubber; particle
size determinations were not possible because of the large amount of water
vapor in the gas stream.  Acid mist and NOX tests were conducted at the
Peterson Scrubber Exhaust Stack.  Feed and product samples were collected for
particle size and moisture analysis.
     3.2.2.2  Visible Emissions.  Visible emission observations were made at
the Peterson Scrubber Exhaust Stack for the duration of all three test runs.
Because feed to the calclner is In a slurry form and feed discharge point is
totally enclosed, visible emission observations were not made.  Similarly,
visible emission observations were not made at the calciner discharge and
because it was totally enclosed.  Only steam emissions were noticed from the
cooler.

     3.3  Process Description.  This plant operates continuously, except for
breakdowns, 24 hours per day and 7 days per week.  Titanium dioxide (T102
pigment is produced by both the chloride process, shown in Figure 1, and the
sulfate process, shown in Figure 2.  The chloride process uses two spray
dryers and one rotary direct dryer, and the sulfate process uses two rotary
calclners, two steam-tube rotary dryers, and two tunnel dryers.

     3.3.1  Spray Dryers.  Figure 3 is a simplified flow diagram that shows
the emission control systems for both spray dryers.  The two spray dryers are
used in the chloride process.  Spray Dryer #312 was manufactured by Proctor

-------
HIHEHAL
 (ml lit
1(01 All If UllltCI
  OIIYEli ())
                     SCIlEENINti
                   COAIINU Ullll
                       S OXIDES
                                                CUKE      CI2
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AEHOUAL
                                                                                    OIL
                                   1
                                                CI2 HttVClt
                                          MULING
                                                        HAU
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                                             SOllttS PRECIPITATION
                                                                                             OX I DAI ION

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                                                                                       1
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                                                                                                                 I
                                                                                                                U1
                              1.   Simplified  flow diagram of  chloride  process--
                             American  Cyanamid  Company,  Savannah,  Georgia.

-------
TITANIUM ^

SIAG
  STEAM- TUBE-ORE
  UK VI It (2)
   ROTARY
   CALCINER (2)
RAW
   COOLEttS  (2)
   GRINDING
K SALTS. PHOSPHATES.
 CONDITIONING AGENTS
                        	i.
  CONDITIONING
  PULVERIZING,
  MILLING, AND
  SCREENING
                                  STEAM
                         II^SO,,   INJECTION
  OltiESTEK
FILTRATION.
UASH1NG. AND
DEMATERING
COATING WITH
HYDROUS OXIDES
                                                   T
                                             SODIUM ALUtilNATE
                                                                       FLUCCUEANT
                                                                            .1
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                                                                             2n Oil Al Oft
                                                                             TI2(SOJ3
                                                    LEACHING
 flETKATlON
                                                    REAGENTS
                                                    (SOMETIMES)
                                                     •i NUCLEA
PRECIPITATION
                       FILTRATION,
                       WASHING, AND
                       DEUATEIUNG
STEAM-TUBE
BELT DRYER (2)
                                                                             .V
                                                                                                FLUID I-IIERGY
                                                                                                MILLING
                        Flyure 2.  Simplified flow diayraiu of sulfate urocess--
                             Aiuerlcan Cyanaiuld Company,  Savannah, Georgia.
                                                                                                PACKAGING

-------
AMBIENT
AIR
r
FEED '
" SPRAY DRYER SETTLING BAGHOUSE 1
AIR NO. 312 CHAMBER 	 * Bftt>mju:>t *
- - - > '
V
J 1 !
i
1 - - t
i i
i i






PETERSON
SCRUBBER






- ->
\
1





S
T
A
C
K
                                                                  I    <
FEED
AIR
SPRAY DRYER
NO.  322
                                                 BAGIIOUSE
                                                          1   '      BY-PASS
                                                                                                                  U)
I	I
                                                 PRODUCT
                                                                                PROCESS FLOW

                                                                                AIR FLOW
               Fiyure 3.  Flow diagram for emission control system for spray dryers at
                            American Cyanamid Company, Savannah, Georgia.

-------
                                     3-8
and Schwartz (P&S) and Installed in 1965, and #322 was manufactured by Bowen
and installed in 1970.  The dryers have separate combustion chambers and are
fired by natural gas.  The process material is dried by a cocurrent flow of
hot air.
     Material entering the spray dryers is in the form of a slurry.  During
the tests the dryers were processing futile titanium dioxide.  Most of the
product from Spray Dryer #312 settles out in a settling chamber.  The exhaust
gas from the settling chamber then goes to a baghouse.  The baghouse collects
most of the remaining dried product.  All of the product from Spray Dryer
#322 is collected in a baghouse.  The exhaust gas from both spray dryer
baghouses is manifolded to one high energy Peterson Scrubber.
     There is a fresh air inlet in the Spray Dryer #312 system duct going to
the Peterson Scrubber.  This duct also contains water sprays to improve the
particulate collection efficiency of the Peterson Scrubber.

     3.3.2  Rotary Calciner No. 2.  A simplified flow diagram that shows the
emission control systems for the rotary calciner is shown in Figure 4.
Rotary Calciner #2 was manufactured by Vulcan.  The calciner has a separate
combustion chamber and is fired -by natural gas.  The feed material is
titanium hydrosylate slurry, which is calcined by a counter-current stream of
hot air to form titanium dioxide crystals.
     Particulate emissions from the calciner are controlled by two
conditioning towers (low-energy packed towers) in parallel, two wet ESP's in
parallel, and a Peterson Scrubber (high energy scrubber).  The primary
purpose of the conditioning towers is to keep the wet ESP inlet gas
temperature less than 71 degrees Celsius (160 degrees Fahrenheit).  The two
wet ESP's are used is the primarily for the control of acid mist emissions.
The Peterson Scrubber is the secondary control device for particulate
emissions and operates at a pressure drop of 5.5 kPA (22 to 30 in. w.c.).

     3.4  Process Conditions During Testing

     3.4.1  Spray Dryers.  The operation of Spray Dryer #312 and Spray
Dryer #322 was monitored from a control panel that regulated the feed rates
and inlet and outlet air temperatures of the dryers.  Fuel consumption for

-------
                                     CONDITIONING
                                     TOWER
                         WET ESP
PRODUCT
TO COOLER
                                 4

"AIR *"
ROTARY
CALCINER
/
i 	
j ~ "
1 '
i
1=1—  FEED
  CONDITIONING
  TOWER

                                                            WET  ESP
                                                                         \
PETERSON
SCRUBBER
                                                                S
                                                                T
                                                                A
                                                                C
                                                                K
                                                                                                               OJ

                                                                                                               vo
            Figure 4.   Flow diagram for  emission  control  system  for  rotary calciner  at
                          American Cyanamid Company,  Savannah, Georgia.

-------
                                     3-10
both dryers was monitored by natural gas meters.  MR I recorded the process
data during the spray dryer tests.  Air temperature and fuel usage were
consistent and Indicated steady state process operations during the test
runs.  The baghouse compartment pressure drops for Spray Dryer #312 were
monitored from a control panel, and pressure drops for the baghouse on Spray
Dryer #322 were monitored from outside gauges.  The Peterson Scrubber was
monitored by reading both the pressure drop across the scrubber and candle
column (similar to venturl scrubber throat) and the recirculation pump
pressure (only one of two pressure gauges was working).  The Peterson
Scrubber and baghouse pressure drops were within normal plant operating
ranges.  Water flow rates and pressure drops were constant.  The packaging
rates provided by American Cyanamld will not be used as exact production
rates, since they are estimates.  Exact production rates will be calculated
from feed analysis data.  Percent capacity utilization will also be
calculated.  The exact production rates and precent capacity utilization is
considered confidential by American Cyanamld.
     Soon after run 1 was completed, Spray Dryer #322 was shut down to repair
a squeaking bearing in the fan.  It was found that the feed meter for Spray
Dryer #322 was not functioning as the feed meter reading was the same after
the dryer stopped operating as it had been during normal operation.  Also,
the natural gas consumption rate was 20 percent less than that during runs
2 and 3.  Because of these observations, it was decided to conduct an
additional test run.  The problem with the feed meter was corrected prior to
test runs 2, 3, and 4.
     During run 2, the feed mechanism of the #312 Spray Dryer automatically
shut down for no apparent reason.  At this point, testing was discontinued.
Plant personnel started the unit up again in 10 minutes, and within 1 hour,
the process achieved a steady state.  Testing was then resumed.  During run
4, particle sizing was not done because it was decided that the three
particle size runs completed earlier were sufficient.

     3.4.2  Rotary Calciner No. 2.  The calclner parameters that were
monitored include time per calciner revolution, fuel consumption, and gas and
feed material temperatures at 6 ft., 30 ft., and 85 ft. from the discharge
end.

-------
                                    3-11
Feed tank level was measured and recorded by a plant operator.  Rotary
calciner feed rates, temperatures, revolution rates, and natural gas usage
were consistent throughout the test runs, indicating steady state process
conditions.  The process parameters monitored for the conditioning towers
were pressured drop and fresh water make up and recirculation rate.  The ESP
parameters that were monitored included gas inlet temperatures, primary
voltage, and primary and secondary current.  The make-up water rate, inlet
temperature, pressure drop, and pump pressure were monitored for the Peterson
scrubber.  Control equipment, including the two conditioning towers, two
ESP's, and Peterson scrubber, displayed normal operating parameters.
     The east conditioning tower was partially plugged, causing an uneven
distribution in the volume of exhaust gas coming from the  rotary calciner to
each of the two conditioning towers.  The product quality, uncontrolled
emission level, and overall control process were not affected by this uneven
distribution.  The conditioning towers maintained the inlet gas temperature
to  the ESP's at less than 71 degrees Celsius (160 degrees  Fahrenheit) during
all three test runs.
     During runs 2 and 3, the west conditioning tower flow meter was not
functioning properly,.  Between runs 2 and 3, the natural gas to the  rotary
calciner was shut off for approximately 10 minutes because several bricks
from the calciner lining plugged the discharge end of the  calciner.  The
problem was immediately corrected, and run 3 was started when the kiln
achieved normal operation.
     Plant processes were operated at or near normal operation capacity
during all three calciner test runs and during test  runs 2, 3, and 4 of both
spray dryers.  Process conditions were normal.  Collected  data are
representative of normal process conditions.  Because of the broken  feed
meter on Spray Dryer #322, the data gathered during  the first run of the
spray dryer test may not be useful.

-------
                                     4-1
4.   SAMPLING LOCATIONS

     4.1  Applicability of Sampling Sites.  The primary goal of the testing
program was to characterize emissions from the spray dryer system (chloride
process) pollution control equipment and from the calciner system (sulfate
process) control equipment.  In addition, moisture and sieving analyses were
performed on feed and product samples.  Sampling sites appropriate to these
objectives were approved prior to testing.

     4.2  Chloride Process Sampling Locations.  Figure 4-1 illustrates
schematically the chloride process which incorporates two spray dryer
systems, i.e., spray dryers #312 and #322.  The location of each sampling
site is indicated in Figure 4-1.  Each of the sampling locations is
individually discussed and illustrated.

     4.2.1  #312 Spray Dryer Inlet (Sampling Location A).  Grab samples of
the feed to the spray dryer were collected during each Method 5 run for
moisture content determination.  The tacky consistency of the feed made sieve
analysis inappropriate.

     4.2.2  #312 Settling Chamber Product Outlet (Sampling Location B).  Grab
samples of the product: from the settling chamber were collected during each
Method 5 run for sieve analysis and moisture content determination.

     4.2.3  #312 Baghouse Inlet (Sampling Location C).  Particulate emissions
and particle size distribution determinations were made in the 26-inch
diameter horizontal duct accessed through two sampling ports spaced 90
degrees apart.  The sampling ports were located 61 inches (i.e., two duct
diameters) downstream from the spray dryer settling chamber and 15 inches
(i.e., one-half duct diameter) upstream from a 17 degree upward bend in the
duct.  Figure 4-2 illustrates the inlet sampling location.
     The original test: plan was to sample 24 points for five minutes each
(giving a total test time of 120 minutes), but the high particulate loading
in the duct made this plan impractical.  EPA EMB and Entropy jointly approved
a revised particulate sampling plan in which 12 points (six points on each of
two traverse axes labeled A and B) were sampled for two minutes each,

-------
                                                                       I.D.  FANS
           SPRAY DRYER
              #312
        SETTLING
         CHAMBER
 C
-o-
                            iB
                      90% PRODUCT
                     SPRAY  DRYER
                        #322
     o
PROCESS FLOW
AIR FLOW
GRAB SAMPLE
SAMPLING LOCATION
BAGHOUSE
                              B1
                        10% PRODUCT
                                        I.D. FAN
                                            T
                                             I
                                                                PETERSON
                                                                SCRUBBER
                                                                               i
                                                              	BY-PASS	I
                                                  s
                                                  T
                                                  A
                                                  C
                                                  K
                          BAGHOUSE
               	I
                                       100% PRODUCT
                   A,B,B',b,b'
                        C,D,E
                            F
                            G
                           ASTM METHOD
                           METHOD 5, IMPACTOR
                           METHOD 5
                           METHOD 9
FIGURE 4-1.  CHLORIDE PROCESS AND SAMPLING POINTS AT AMERICAN CYANAMID, SAVANNAH, GEORGIA

-------
                      TO
                      BAGHOUSE
        TO
        BAGHOUSE
                                          EXTERIOR
                                          WALL
          2 AXES, EACH
          WITH 6 'POINTS
          (TOTAL  12 POINTS)
      FROM SPRAY DRYER
N  AND SETTLING CHAMBER
                INSIDE BUILDING
                                                                                   26" INSIDE
                                                                                   DIAMETER
                                                                                      	 ' ' ' I -Q
                                                                             SECTION N-N
                                                                                               •4"
FIGURE 4-2. #312 BAGHOUSE  INLET DIMENSIONS WITH SAMPLING PORT AND POINT  LOCATIONS

-------
                                     4-4
resulting in a total sampling time of 24 minutes.  Sampling was periodically
interrupted and resumed in order to distribute the 24 minutes of sampling
over the two-hour period of particulate sampling at the #312 Baghouse Outlet.
     Two particle size runs were performed after each of the particulate runs
(runs 1,2, and 3) for a total of six particle size runs.  For each run,
either points A-2 and A-5 or points B-2 and B-5 were sampled; sampling times
ranged from 20 seconds to one minute depending on the particulate loading
encountered.

     4.2.4  #312 Baghouse Product Outlet (Sampling Location B').  Grab
samples of the product from the baghouse were collected during each Method 5
run for sieve analysis and moisture content determination.

     4.2.5  #312 Baghouse Outlet (Sampling Location D).  Sampling was
performed in a 48-inch diameter vertical duct accessed through two sampling
ports spaced 90 degrees apart.  The ports were located 12 inches (0.3 stack
diameters) upstream and 42 inches (0.8 stack diameters) downstream from the
nearest flow disturbances, as shown in Figure 4-3.
     A total of 24 sampling points were used for the particulate tests (12
sampling points on each of two traverse axes labeled A and B).  Each point:
was sampled for five minutes resulting in a total test time of 120 minutes.
     Four particle size runs were performed.  The first two runs (performed
after particulate run 4) lasted for 45 and 60 minutes, respectively.  A third
particle size run lasting 120 minutes was done simultaneous with particulate
run 5; the fourth particle size run lasted 176 minutes and was performed
simultaneous with particulate run 6.

     4.2.6  #322 Spray Dryer Inlet (Sampling Location b).  Grab samples of
the feed to the spray dryer were collected during each Method 5 run for
moisture content determination.  The tacky consistency of the feed made sieve
analysis inappropriate.

     4.2.7  #322 Baghouse Product Outlet (Sampling Location b').  Grab
samples of the product from the baghouse were collected during each Method 5
run for sieve analysis and moisture content determination.

-------
                              4-5
  2 AXES, EACH WITH
  12 POINTS (TOTAL
  24 POINTS)
                     B p—
                                           48" DIAMETER
                          SECTION M-M
            TO  PETERSON
            SCRUBBER
   2  SAMPLING	
   PORTS
                                    FLANGE
                                   BUNION
                                    I.D.  FAN
FIGURE 4-3.  #312 BAGHOUSE OUTLET DIMENSIONS WITH SAMPLING
             PORT AND POINT  LOCATIONS

-------
                                     4-6
     4.2.8  #322 Baghouse Outlet (Sampling Location E).  Sampling was
performed in a 50-inch by 21-inch tapered duct positioned approximately 15
degrees from vertical.  The duct was accessed through four sampling ports
located 100 inches downstream and 42 inches downstream from the nearest bend;
due to the taper of the duct, no straight run was available.
     A total of 24 sampling points were used for the particulate tests, i.e.,
six sampling points on each of four traverse axes labeled A through D, as
shown in Figure 4-4.  The original sampling time per point was five minutes;
however, after 21.77 minutes of testing in port A during the first run (1.77
minutes into point A-5), the sampling protocol was reevaluated and a joint
decision was made to sample the remaining points for two minutes in order to
shorten the net run time.  The 21.77-minute sample of port A was designated
run 7A; the 36-mlnute sample was designated run 7B.   For runs 8 and 9,
all 24 points were sampled for 2.5 minutes, resulting in a total run time
of 60 minutes.
     Two particle size runs were performed after each of the three
particulate runs (runs 7, 8 and 9) for a total of six particle size runs.
During each run, a single point (either point A-4 or point C-4) was sampled
for 30, 45, or 60 seconds.

     4.2.9  #312 and #322 Spray Dryers Exhaust Stack (Sampling Location F).
Sampling was performed in a 78-inch diameter vertical stack.  Two sampling
ports (labeled A and B) spaced 90 degrees apart were located 78 inches (one
stack diameter) upstream from the stack outlet and 432 Inches (5.5 stack
diameters) downstream from the nearest flow disturbance.
     A total of 24 sampling points were used for particulate testing (12
points on each of two traverse axes labeled A and B) as shown in Figure 4-5.
Each point was sampled for five minutes for a total test time of 120 minutes.

     4.2.10  #312 and #322 Spray Dryers Exhaust Stack (Sampling Location G).
Plume opacity observations were performed at the exhaust stack according to
procedures outlined in EPA Reference Method 9.  Cloudy weather conditions
prohibited the completion of opacity observations for test 3 (run 12) and
limited the observer's confidence in the reliability of test 4 (run 31).

-------
                               4-7
  24 SAMPLING
  POINTS
  4  SAMPLING
  PORTS

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•
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21
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t
4"
1
                          SECTION  L-L
                                                FROM #322
                                                BAGHOUSE
        TO I.D. FAN
FIGURE 4-4.  #322 BAGHOUSE OUTLET DIMENSIONS WITH SAMPLING
             PORT AND POINT LOCATIONS

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                                     4-8
                         78"  DIAMETER
 2  SAMPLING
 PORTS
                      2 AXES, EACH
                      WITH 12 POINTS
                      (TOTAL 24 POINTS)
                                                        •6"
                                                 	=]B
                                         SECTION M-M
                                        BYPASS
FIGURE 4-5.  SPRAY DRYERS #312 AND #322 STACK DIMENSIONS  WITH
             PORT AND POINT LOCATIONS

-------
                                     4-9
     4.3  Sulfate Process Sampling Locations.  Figure 4-6 provides a
schematic Illustration of the sulfate process (which incorporates a rotary
calciner kiln) and gives the location of each sampling site. Each of the
sampling locations is Individually discussed and illustrated.

     4.3.1  #2 Calciner Inlet (Sampling Location H).  Grab Samples of the
feed to the rotary calciner were collected during each Method 5 run for
moisture content determination.  Sieve analysis was inappropriate due to the
tacky consistency of the feed samples.

     4.3.2  Water Spray Cooler Outlet (Sampling Location 1).  Grab Samples of
the product exiting the water spray cooler were collected during each
Method 5 run  for sieve analysis and moisture content determination.

     4.3.3  East Side Calciner I.D. Fan Outlet (Sampling Location K).
Sampling was  performed in a 72-inch diameter vertical duct which was accessed
by two sampling ports (labeled A and B) spaced 90 degrees apart.  The ports
were located  36 Inches (0.5 duct diameters) upstream and 12 inches (0.2 duct
diameters) downstream from the nearest flow disturbances, as shown in
Figure 4-7.
     A total  of 24 sampling points (i.e., 12 points on each of two traverse
axes labeled  A and B) were sampled for particulate.  Each point was sampled
for 2.5 minutes, resulting in a net run time of 60 minutes.
     Two particle size runs were performed after each particulate run, one at
point A-9 and one at point B-4.  Runs S-13-A and S-13-B were each run for
five minutes; the other four runs were each performed for 15 minutes.

     4.3.4  East Side I.D. Fan Inlet (Sampling Location K').  Velocity
traverses were performed in the 65-inch diameter duct which angled downward
in the direction of the gas stream flow, as shown in Figure 4-8.  Access was
provided by a single port (labeled A) which was positioned 35 feet (6.5 duct
diameters) downstream from the nearest disturbance and four feet (0.7 duct
diameters) upstream from the nearest disturbance.  Two twelve-point velocity
traverses were made along the single axis for each velocity run.

     4.3.5  West Side I.D. Fan Outlet (Sampling Location L).  Sampling was
performed in  a 72-inch diameter vertical duct which was accessed by two

-------
                                                EAST
  ฎ	*
           ROTARY
          CALCINER
          KILN #2
    O
PROCESS FLOW

AIR FLOW

GRAB SAMPLE

SAMPLE POINT
OBSERVATION POINT
I                                  CONDITIONING
                                     TOWER
WET
ESP
                                                                  M
                                                                 \
                                      NO
  \ PETERSON   I
  ,  SCRUBBER ~~U—



O M1      ^-I.D.  I
                                            s
                                            T
                                            A
                                            C
                                            K
                                                                            -I.D. FAN
                                               WEST
                                  CONDITIONING
                                     TOWER
         WET ESP
K',L' - METHOD 2
  H,I - ASTM METHOD
  K,L - METHOD 5, IMPACTOR
 M,M' - METHOD 5
    N f METHODS 5,7
    O - METHOD 9
    J - METHOD 22
FIGURE 4-6.  SULFATE PROCESS AND SAMPLING POINTS AT AMERICAN CYANAMID, SAVANNAH, GEORGIA

-------
                              4-11
                 2  AXES,  EACH WITH
                 12 POINTS,  (TOTAL
                 24 POINTS)
                   TO  CONDITIONING
                   TOWER
                                         72" DIA.
   FLANGE
   UNION

2 SAMPLING
PORTS
 FLANGE
 UNION
                                                  -~ —6.5"
                                        SECTION N-N
                                FLANGE
                                UNION
         •I.D.  FAN
          (FROM CALCINER #2)
FIGURE 4-7.
#2 CALCINER EAST AND WEST  SIDE  I.D.  FAN OUTLET
DIMENSIONS WITH SAMPLING PORT AND  POINT LOCATIONS

-------
                 65"  DIA.
TO
I.D. FAN
                                  AXES:  1
                                  POINTS/AXIS:  12
                                  TOTAL  POINTS:  12
                SECTION P-P
          1 SAMPLING PORT
                                                                                       FROM
                                                                                       CALCINER
                                                                                                  I
                                                                                                 I-1
                                                                                                 IV)
FIGURE 4-8.  #2 CALCINER EAST I.D. FAN  INLET  DIMENSIONS  WITH SAMPLING PORT AND POINT LOCATIONS

-------
                                     4-13
sampling ports (labeled A and B) spaced 90 degrees apart.  The ports were
located 36 inches (0.5 duct diameters) upstream and 12 inches (0.2 duct
diameters) downstream from the nearest flow disturbances, as shown in
Figure 4-7.
     A total of 24 sampling points (12 points on each of two traverse axes
labeled A and B) were sampled for particulate.  Each point was sampled
for 2.5 minutes, resulting in a net run time of 60 minutes.
     Two particle size runs were performed after each particulate run, one at
point A-4 and one at point B-4.  Runs S-16-A and S-16-B were performed for
five minutes; the other four runs were 25 minutes in duration.

     4.3.6  West Side I.D. Fan Inlet (Sampling Location L')ซ  The west side
fan inlet duct was a 73-inch diameter duct which was identical to the east
side fan inlet duct in all other pertinent respects, as shown in Figure 4-9.
Velocity measurements proceeded in the manner described in paragraph 4.3.4.

     4.3.7  East and West Side ESP Outlets (Sampling Locations M and M').
The east and west side ESP outlets were identical, and the same testing
procedures were used at both locations.  Sampling was performed in a 54-inch
diameter vertical duct accessed through two ports (labeled A and B) spaced 90
degrees apart, as shown in Figure 4-10.  The ports were located 45 inches
(0.2 duct diameters) downstream and 12 inches (0.8 duct diameters) upstream
of the nearest flow disturbances.
     For particulate testing, 24 points (12 points on each of two traverse
axes labeled A and B) were sampled for 2.5 minutes each, resulting in a total
run time of 60 minutes.

     4.3.8  #2 Calciner Exhaust Stack (Sampling Location N).  Sampling was
performed in the 73-inch diameter exhaust stack of the sulfate process.  Two
sampling ports 90 degrees apart were located 44 feet (7.2 stack diameters)
downstream of the by-pass duct from the Peterson scrubber, and 50 feet (8.2
stack diameters) upstream from the top of the stack, as shown in Figure 4-11.
     For the particulate tests, a total of 12 points (six sampling points on
each of two  traverse .axes labeled A and B) were sampled.  For run 25, each
point was sampled for five minutes with a total test time of 60 minutes.  For
runs 26 and 27, the total test time was increased to 72 minutes (six minutes

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                 73"  DIA.
 TO
 I.D.  FAN
                                 AXES:  1
                                 POINTS/AXIS:  12
                                 TOTAL  POINTS:  12
                SECTION Q-Q
           1 SAMPLING PORT
                                                                                      FROM
                                                                                      CALCINER
FIGURE 4-9.  #2 CALCINER WEST I.D..FAN INLET DIMENSIONS WITH SAMPLING PORT AND POINT LOOATIONS

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      54" DIA.
                                   AXES:  2
                                   POINTS/AXIS:  12
                                   TOTAL  POINTS:  24
                                                                         54" DIA.
                                                    6"
               SECTION  R-R
                                                           SECTION S-S
    AMBIENT
    AIR
    INTAKE
                EAST SIDE
                      TO
                      SCRUBBER
                                                                                                 I
                                                                                                M
                                                                                                U1


1
R







/

B

ESP
A
( 1
12"
A 1 j
1 45- !
R - S
' \



A


f /
o
B

ESP
A.
/

1
, s


WEST SIDE
FIGURE 4-10. #2 CALCINER EAST AND WEST ESP OUTLET DIMENSIONS WITH  SAMPLING PORT AND POINT
             LOCATIONS

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                                        4-16
             50'
             44'
           BYPASS
                             73"
                             AIR
                             FLOW
                              -o—
                                                   73"  DIAMETER
                                                       —1 I	5.5"
                                2 AXES, EACH WITH
                                6 POINTS (TOTAL,
                                12 POINTS)

                                SECTION L-L
                                      2 SAMPLING  PORTS
                            FROM'
                          SCRUBBER
FIGURE 4-11.
jฑ2 CALCINER  EXHAUST STACK DIMENSIONS WITH
PORT AND  POINT LOCATIONS

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                                     4-17
per point) in order to increase the total sample volume and particulate
catch.  For the nitrogen oxides tests, a single point sample was taken.

     4.3.9  #2 Calciner Exhaust Stack (Sampling Location 0).  Plume opacity
observations were performed at the exhaust stack outlet in accordance with
the procedures outlined in EPA Reference Method 9.

     4.3.10  #2 Calciner Product Outlet (Sampling Location J).  Fugitive
emissions readings (according to EPA Reference Method 22) were abandoned when
judgement was made that steam, rather than product emissions, was being
observed.

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                                     5-1
5.   SAMPLING AND ANALYTICAL METHODS

     5.1  Sampling Objectives.  This section describes the sampling and
analytical procedures which were employed at the American Cyanamid Company
manufacturing plant: in order to gather data concerning emissions from  the
pollution control equipment associated with the sulfate and chloride
processes used to produce titanium dioxide.  In addition, moisture and
sieving analyses were performed on feed and product samples.  The sampling
program included outlet tests for particulate emissions, nitrogen oxides,
particle sizing, and plume opacity.

     5.2  Particulate Emissions Testing.  Where appropriate, particulate
emissions sampling conformed to the standards and procedures set forth by EPA
Reference Methods 1-5 and described in 40 CFR Part 60, Appendix 7.3.   It was
necessary at several locations to modify the test procedures in order  to cope
with either heavy particulate loading or turbulent flow patterns.
     5.2.1  #312 Baghouse  Inlet.  Due  to heavy particulate  loading,  the
run times were  reduced by  changing  the number of  sampling points  from 24
to 12 and the sampling time  per point  to two minutes, resulting in  run times
of 24 minutes.  This  protocol was approved on site by EPA EMB and Entropy.

     5.2.2  #312 Baghouse  Outlet.   The total amount  of  available  straight  run
did not  allow the  placement  of the  sampling ports to meet the Method 1
criteria for minimum  upstream and downstream distances.

     5.2.3  #322 Baghouse  Outlet.   Because the duct  was  tapered with no
available straight run,  the  placement  of the sampling ports did not  meet  the
Method 1 criteria  for minimum upstream and downstream distances.
     Due to the heavy particulate loading encountered at this location during
Test 1 ,  particulate run  7  was divided  into two components which were
performed, processed, and  analyzed  as  two separate runs. The particulate
catch from each component  run was analyzed separately.   Moisture  content  and
flue gas composition  were  determined on  a total  run  basis,  with the same
values used in  the calculations for each component run  (run 7 A and  7B).

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                                     5-2
     5.2.4  East and West I.D. Fans Outlets.  The total amount of available
straight run did not allow the placement of the sampling ports to meet the
Method 1 criteria for minimum upstream and downstream distances.  Due to the
turbulent flow patterns present, the air flow rates measured were used only
for the isokinetic sampling rate calculations; air flow rates as measured at
the East and West 1.0. Fan Inlets were used for emission rates calculations.

     5.2.5  East and West I.D. Fans Inlets.  Because only one port was
available for the velocity traversing, each velocity run consisted of two
traverses of the same port.  Due to the large amount of straight run,
however, no significant error in the air flow data is expected.

     5.2.6  East and West ESP Outlets.  The total amount of available
straight run did not allow the placement of the sampling ports to meet the
Method 1 criteria for minimum upstream and downstream distances.

     5.3  Sulfuric Acid Mist.  Sulfuric acid mist emissions from the #2
Calciner Stack were determined by analyzing the particulate catch for total
3ulfates and calculating the results as 112804.

     5.4  Trace Metals Analysis.  For one  run at each location, the Method 5
particulate catch and the distilled water  reagent from the impingers were
analyzed for trace metals by using atomic  absorption spectrometry or by
inductively coupled plasma spectrometry.  These metals are zinc, nickel,
iron, manganese, vanadium, calcium, silicon, aluminum, magnesium, fluorine,
beryllium, uranium, lead, and mercury.

     5.5  Sieve Analysis and Moisture Content.  Sieve analysis and moisture
content determinations were performed on the product samples.  ASTM Method
D 2216 was used to analyze the samples for moisture content, while ASTM
Method D 422 was used for sieve analysis.  Samples which could not be sieved
due to moisture content were analyzed using only the second portion of Method
D 422 (the hydrometer procedure).

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                                     5-3
     5.6  Plume Opacity.  Visible emissions observations were performed in
accordance with EPA Reference Method 9 as described in 40 CFR Part 60.
However, cloudy atmospheric conditions prevented some of the scheduled
opacity readings.

     5.7  Fugitive Emissions.  Fugitive emissions were determined in
accordance with EPA Reference Method 22 as described in 40 CFR Part 60.

     5.8  Particle Size Tests.  Particle size determinations were made using
a right angle inlet preseparator, followed by an Andersen or Flow Sensor
Mark III cascade impactor.  The test procedures were based upon the
publication, "Procedures for Cascade Impactor Calibration and Operation in
Process Streams - Revised 1979," developed by the Industrial Environmental
Research Laboratory (IERL) and Southern Research Institute.  Particle size
testing was not performed at locations where water droplets were observed in
the duct.

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                                      6-1
6.  QUALITY ASSURANCE

     6.1  Introduction.  The goal of quality assurance for the project was to
ensure the accuracy of all data collected.  The procedures used are contained
in Entropy's "Quality Assurance Program Plan," which was approved by the U.S.
EPA EMB in the contract agreement governing the project.
     In order to ensure continuity among field testing personnel, daily
meetings were held before each day of the field testing.  At the meetings,
results from the testing conducted on the previous day were reviewed.
Responsibilities were clearly delineated for each member of the testing team,
and questions were addressed and resolved immediately.  In situations where
more than one person was performing similar activities, consistency was
ensured through communication at the meetings.
     In addition to the general quality assurance measures, specific quality
assurance activities were conducted for several of the individual test
methods performed.

     6.2  Sampling Train Components.  Entropy's sampling equipment, including
nozzles, pitot tubes, dry gas meters, orifices, and thermocouples, was
uniquely identified and calibrated in accordance with documented procedures
and acceptance criteria prior to and at the completion of the field testing
program.  All sampling equipment was manufactured by Nutech Corporation,
Andersen 2000, Flow Sensor, or by Entropy.  Calibration data for the sampling
equipment are contained in Appendix 7.7.

     6.3  Preseparator and Cascade Impactors.  All internal components and
surfaces of the impactors were cleaned in an ultrasonic bath to ensure that
all surface impurities were removed, and visual inspections for cleanliness
were made prior to shipment to the field.  After each sample recovery, the
preseparator, the impactor body, and the plates were rinsed with acetone to
ensure that all organic residuals and/or particulate matter were removed.

     6.4  Sample Collection Substrates.  Schleicker & Schuell #30 glass fiber
sample collection substrates were used for particle size testing.  To prevent
contamination of the substrate surface, all filters were handled with
laboratory tweezers.  This procedure was used during impactor assembly,
sample recovery, and weighing of the substrates.

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                                     6-2
     6.5  Substrate Weighing.  An analytical balance capable of weighing to
the nearest 0.01 milligram (mg) was used.  To ensure that no weight bias was
produced from the preparation, transportation, recovery, or weighing
procedures, two control samples were obtained during the test program.
     A reactivity run was performed to ensure that the flue gases did not
interact with the substrate to produce extraneous results.  For the
reactivity run, a solid filter was placed in the front section of the
impactor, and the impactor was introduced into the #312 Baghouse Outlet duct,
and a sample was pulled through the head using the parameters outlined for a
normal particle sizing run.  The average difference between the pre- and
post-test weights, as shown in Appendix 7.3.2, was 0.14 milligrams, based
upon weight differences ranging from 0.00 to 0.34 milligrams.
     A blank run was also performed to demonstrate that the impactor could be
assembled and disassembled without affecting the weight of the substrate.
The average difference between the pre- and post-assembly weights was 0.14
milligrams, based upon a difference ranging from 0.02 to 0.34 milligrams.

     6.6  Sample Analysis.  In order to reduce the probability of errors or
inconsistent results, one member of the field crew had sole responsibility
for the sample analysis procedure.  Sample analysis was performed in a room
dedicated exclusively to filter weighing.

     6.7  EPA Method 3.  All Method 3 analyses were performed in triplicate.
Each analyzer was checked for leaks prior to any analysis as specified in the
method.  Samples were analyzed within four hours of collection.

     6.8  EPA Method 9.  The visible emissions observers held current
certifications issued within the last 6 months.  Documentation verifying the
observer's certifications are provided in Appendix 7.5.

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