ites

Agen
andards
 -ark NC 2
EMB Report S3-CDR-11
April 1984

Calciners and
Dryers Emission
Test Report
     •

C.E. Minerals
Muicoa Plant
Andersonville,
Georgia


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                     NSPS DEVELOPMENT
PARTICULATE, SULFUR DIOXIDE, AND NITOGEN OXIDES EMISSIONS
               AND PARTICLE SIZING TESTING
                    #4 ROTARY CALCINER
                C.E. MINERALS MULCOA PLANT
                  ANDERSONVILLE, GEORGIA
                   APRIL 17 & 18, 1984
                       Compiled by:

                         Entropy
                   Post Office Box 12291
           Research Triangle Park, N. C. 27709
                        68-02-3852
                  Work Assignment No. 8
                  EMB Project No. 81/08
                 EMB Report No. 83-CDR-ll
                       Task Manager

                     Dennis Holzschuh
               Emission Measurement Branch
       Emissions  Standards and Engineering Division
           Research Triangle Park, N. C., 27711
       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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                             TABLE OF CONTENTS

 SECTION                                                                PAGE
1.   INTRODUCTION	   1-1
     1.1    Background	   1-1
     1.2    Scope of the Project	   1-1
     1.3    C.E. Minerals  Mulcoa Plant Testing Program   	   1-1
     1.3.1     Source Applicability  	   1-1
     1.3.2     Outline  of  Testing  Program 	   1-2
     1.4    Report Organization 	   1-4

2.   SUMMARY AND DISCUSSION OF  RESULTS	   2-1
     2.1    Summary	   2-1
     2.2    Discussion	   2-1

3.   PROCESS DESCRIPTION AND OPERATION   	   3-2
     3.1    Production  of  Calciner Feed	   3-2
     3.1.1     Raw Material	   3-2
     3.1.2     Fuel	   3-2
     3.1.3     Pellet Formation 	   3-2
     3.1.4     Pellet: Drying	  .   3-2
     3.1.5     Pellets  as  Feed	   3-4
     3.2    Calcining; Process	   3-4
     3.2.1     Kilns	   3-4
     3.2.2     Calcine	   3-4
     3.2.3     Exhaust  Emissions  	   3-6
     3.2.4     Control Equipment  	   3-6

4.   SAMPLING LOCATIONS 	   4-1
     4.1    Suitability of Sampling Sites 	   4-1
     4.2    Rotary Calciner Feed Inlet (Sample Loc. A)	   4-1
     4.3    Vibrating Grate Cooler Product Outlet (Sample Loc.  B)  .  .  .   4-1
     4.4    Vibrating; Grate Cooler Multiclone Outlet (Sample Loc.  G).  .   4-1
     4.5    Multiclone Inlet (Sample Loc. C)	   4-1
     4.6    I.D.  Fan Inlet East & West (Sample Loc. D & E)	   4-4
     4.7    Scrubber Exhaust Stack (Sample Loc. F & Observation Loc.  G)   4-2
                            (continued next page)

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                                      ii
                              TABLE OF CONTENTS
                                 (continued)

 SECTION                                                                PAGE
5.   SAMPLING AND ANALYTICAL METHODS	   5-1
     5.1    Sampling Objectives   	   5-1
     5.2    Particulate and Sulfur Dioxide Emissions Testing  	   5-1
     5.3    Trace Metals Analysis 	   5-1
     5.4    Sieve and Moisture Content Analysis  	   5-1
     5.5    Plume Opacity	   5-1
     5.6    Particle Size Testing	   5-1
     5.7    Nitrogen Oxides Testing 	   5-1
6.   QUALITY ASSURANCE  	   6-1
     6.1    Introduction	   6-1
     6.2    Sampling Train Components 	   6-1
     i6.3    Preseparator and Cascade Impactors   	   6-1
     6.4    Sample Collection Substrates  	   6-2
     6.5    Substrate Weighting 	   6-2
     6.6    Sample Analysis	   6-2
     6.7    EPA Method 3	   6-2
     6.8    EPA Method 9	   6-2

7.   APPENDICES	     1
     7.1    Test Results and Example Calculations  	     2
     7.1.1     Particulate and Sulfur Dioxide 	     2
     7.1.1.1      Multiclone Inlet  	     2
     7.1.1.2      I.D. Fan Inlet East & West	     5
     7.1.1.3      Scrubber Exhaust Stack and  Example Calculations  ...    10
     7.1.2     Particle Sizing	    16
     7.1.2.1      Multiclone Inlet  	    17
     7.1.2.2      I.D. Fan Inlet East & West	    33
     7.1.3     Nitrogen Oxides, Scrubber Exhaust Stack   	    62
     7.2    Field and Analytical Data	    66
     7.2.1     Particulate and Sulfur Dioxide	    66

                            ( continued next page)

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                                    ill
                            TABLE OF  CONTENTS
                                (continued)
SECTION
    APPENDICES
    7.2.1.1
    7.2.1.2
    7.2.1.3
    7.2.2
    7.2.2.1
    7.2.2.3
    7.2.3
    7.2.4
    7.2.5
    7.3
    7.4
    7.5
    7.6
 66
 76
 90
100
100
   Multiclone Inlet 	
   l.D. Fan Inlet East & West  	
   Scrubber Exhaust Stack 	
Particle Sizing	
   Multiclone Inlet 	  .  	
   l.D. Fan Inlet East & West	112
Visible Emissions, Scrubber Exhaust  Stack  	  130
Nitrogen Oxides, Scrubber Exhaust  Stack  	  145
Trace Metals Analytical Results 	  150
Sampling and Analytical Procedures  	  153
Feed and Product Analytical Data	  239
Entropy Test Participants .	259
Calibration Data	260

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                                   iv
                             LIST OF TABLES
Number      Title                                                 Page
  1-1       Testing Protocol and Run/Sample Numbering  	   1-3
               Cross-Reference
  2-1       ParticulLate Emissions and Concentrations,  Summary  .  .   2-2
              and Control Equipment Efficiencies
            Particulate Tests Summary of Results
  2-2            Multiclone Inlet 	   2-3
  2-3            I.I). Fan Inlet, East	   2-4
  2-4            I.I). Fan Inlet, West	   2-5
            Particulate and Sulfur Dioxide Summary  of  Results
  2-5            Scrubber Stack	   2-6
            Summary of Particle Sizing Test Results
  2-6            Multiclone Inlet 	   2-8
  2-7            I.D. Fan Inlet, East	2-10
  2-8            I.D. Fan Inlet, West	2-12
            Nitrogen Oxides Emissions Rates and Concentrations
  2-9            Scrubber Stack	2-14
            Summary of Visible Emissions
 2-10            Run 1   	2-15
 2-11            Run 2	2-16
 2-12            Run 3	2-17
  3-1       Data For Rotary Kilns	   3-5

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                           LIST  OF  FIGURES









Number      Title                                                 Page




  3-1       Simplified Process Flow  Diagram  	   3-3




  4-1       Process Flow Schematic Showing Sampling Locations . .   4-2




  4-2       Multiclone Inlet   	   4-3




  4-3       I.D. Fan Inlet East & West	   4-5




  4-4       Scrubber Exhaust  Stack  	   4-6

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                                     1-1
1.   INTRODUCTION

     1.1  Background.  'Che Emission Measurement Branch (EMB)  of the United
States Environmental Protection Agency (EPA) is directing a project designed
to generate support data for New Source Performance Standards (NSPS)  for
calciners and dryers in the mineral industries.  Emission standards for the
various industries may be developed based upon process-related emission
factors determined from the testing of controlled sources.

     1.2  Scope of the Project.  The EMB is  responsible for coordinating  the
efforts of Entropy and Midwest Research Institute (MRI) to achieve the goals
of the testing program.  Entropy has been retained under the EMB Contract No.
68-02-3852, Work Assignment No. 8  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.  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  C.E. Minerals Mulcoa Plant Testing Program.  The present report
covers stationary source sampling  performed  at the C.E. Minerals #3 Plant in
Andersonville, Georgia on April 17  and 18, 1984 to characterize emissions
from the #4 rotary calciner and associated air pollution control equipment.
Dilip Jain and Siva Soora of C.E.  Minerals and Dennis Holzschuh of EPA EMB
were present  to  coordinate the testing.  Amy J. Kowalski of MRI monitored the
plant process and recorded operational data  during the testing.

     1.3.1  Source Applicability.   The C.E.  Minerals Mulcoa plant uses rotary
 calciners for the drying of pulverized or extruded clay.  The plant's use of
 coal-fired  rotary calciners  represents the most difficult emissions control
 situation in  the  clay  refining industry.  The plant is considered to be well
 operated and  well maintained, as  well as  providing feasible opportunities for
 inlet testing.

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                                     1-2
     1.3.2  Outline of Testing Program.  Emission measurements  were  performed
at the multiclone inlet, at the I.D.  fan inlets (east & west) and  at the
scrubber exhaust stack.  Table 1-1 outlines the testing program, giving test
dates, sampling locations, test methods, and run numbers.

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                                   TABLE  1-1

                             TESTING PROTOCOL AND

                     RUN/SAMPLE NUMBERING CROSS-REFERENCE
------- Sampling
Objective       Method
Particulate    '  EPA 5
Participate/   EPA 5 & 8
Sulfur Dioxide
Particle
Sizing
Nitrogen
Oxides

Sieving/
Moisture
Opacity
 Cascade
Irapactor
  EPA 7
  Grab
 Sample
  EPA 9'
              Location*
4/17
Test Set 	

 4/17       4/18
MI
IE
IW
SE
MI
IE
IW
SE
CI
VP
VM
SE
1
4
7
10
S1A&B
S4A&B
S7A&B**
10
1
1
1
1
2tm
5tm
8tm
lltm
S2A&B
S5A&B
S8A&B
11
2
2
2
2
3
6
9
12
S3A&B
S6A&B
S9A&B**
12
. 3
3
3
3
   tm Method 5  particulate  catch and distilled water from  impingers analyzed
     for  trace metals

    * Sampling  Location Legend:
       MI - Multiclone Inlet
       IE - I.D.  Fan Inlet East
       IW - I.D.  Fan Inlet West
       SE - Scrubber Exhaust  Stack
       CI - Calciner Inlet
       VM - Vibrating Grate Cooler Multiclone Outlet
       VP - Vibrating Grate Cooler Product Outlet

   ** The  results  of  runs S7B  and S9B are not tabulated in this  report.
     Run  S7B  was  underloaded;  run S9B was overloaded.

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                                     1-4
     1.4  Report Organization.  Immediately following is the "Summary  of
Results"  section.  Appendix 7.1 presents  the  complete results of each run;
 field  data  can be  found  in Appendix 7.2.  The source and the process are
 described in the "Process  Description and Operation" section.  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 7.3,  while Appendix 7.4 presents
 analytical  documentation.   The final  section, "Quality Assurance," notes the
 procedures  used to ensure  the integrity of  the sampling program; Appendix 7.6
 provides  pertinent calibration data.   Appendix 7.5 contains a listing of the
 Entropy test participants  and their  roles in  the  testing program.

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                                    2-1
2.   SUMMARY AND DISCUSSION OF  RESULTS

     2.1  Summary.  Table 2-1 presents  a summary of  the particulate and
sulfur dioxide emissions and concentrations  at  the sampled  locations,  as  well
as particulate collection efficiencies  for the  multiclone.   Run-by-run
summaries of the particulate testing are provided for the multiclone inlet
and for the I.D. fans east and  west in  Tables 2-2 through 2-4,  respectively.
Table 2-5 summarizes the results of particulate and  sulfur  dioxide testing
performed at the scrubber exhaust stack.  Detailed results  of  all  particulate
and sulfur dioxide testing appear in Appendix 7.1.1.
     Tables 2-6 through 2-8 present the particle sizing test results for each
of the sampled locations; particle sizing was  not performed at the scrubber
exhaust stack due to moisture in the flue gas.   Appendix 7.1.2  presents  the
detailed results of particle size testing.
     Nitrogen oxides (as M^)  results are summarized in Table  2-9; complete
results are given in Appendix 7.1.3.
     Opacity observations (runs 1-3) are reported in Tables 2-10,  2-11,  and
2-12.  No visible emissions were observed throughout the testing;  field  data
is presented in Appendix 7.2.3.
     The results of trace metals analyses are  reported in Appendix 7.2.5.

     2.2  Discussion of Results.  At the I.D.  fan inlet west location,
particle sizing runs 7B and 9B  were not tabulated in the results  due to  an
extremely low catch (underloaded), and  extremely large catch (overloaded),
respectively.
     In order to calculate particulate  removal  efficiencies of the multiclone
and scrubbers, a particulate concentration representing a combined inlets
value is necessary.  A technique for eliminating any bias due to  uneven  air
flow distribution through the two fans  was used in calculating the
equivalent, weighted average concentrations as follows:

          Sum of A-!>ide & B-Side Emissions, Ib/hr   7,000 gr/lb
     Ceq=	*	= gr/DSCF for
          Sum of A-Side & B-Side Flow Rates, SCFM    60 min/hr     combined
                                                                  inlets
                   554.15 + 463.07  7,000
                 =	*	= A'°278  Sr/DSCF

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                     2-2
                  TABLE 2-1
PARTICULATE EMISSIONS & CONCENTRATIONS SUMMARY
      AND CONTROL EQUIPMENT EFFICIENCIES

Emission Rates, Ib/Hr:
Multiclone Inlet
I.D. Fan Inlet, East
I.D. Fan Inlet, West
Scrubber Stack
Concentration, Gr/DSCF:
Multiclone Inlet
I.D. Fan Inlet, East
I.D. Fan Inlet, West
Equivalent I.D. Fan Inlet
Scrubber Stack
Collection Efficiency, %:
Multiclone
Scrubber
Emission Rates, Kg/Hr:
Multiclone Inlet
I.D. Fan Inlet, East
I.D. Fan Inlet, West
Scrubber Stack
Concentration, mg/DSCM:
Multiclone Inlet
I.D. Fan Inlet, East
I.D. Fan Inlet, West
Scrubber Stack
1

2,192.95
554.15
463.07
8.37

7.5227
4.3930
3.6634
4.0278
0.0336

46.46
99.16

994.7
251.4
210.0
3.80

17,212
10,051
8,382
76.89
- iest aec
2

2,361.38
564.37
471.38
8.08

8.2405
4.3858
3.7308
4.0614
0.0315

50.72
99.21

1,071.1
256.0
213.8
3.67

18,855
10,035
8,537
72.12
3

1,947.90
553.04
458.11
8.98

7.1672
4.1514
3.7454
3.9570
0.0344

44.79
99.14

883.5
250.9
207.0
4.07

16,399
9,499
8,570
78.77
Average

2,167.41
557.18
464.18
8.48

7.6434
4.31
3.7132
4.0154
0.0331

47.32
99.17

983.1
252.7
210.0
3.85

17,489
9,862
8,496
75.93

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                               2-3
                            TABLE 2-2

                PARTICULATE TESTS SUMMARY OF RESULTS

                         Multiclone Inlet



                                    1            2            3

Run Date                        04/17/84     04/17/84     04/18/84

Test Train Parameters:
  Volume of Dry Gas                31.526       29.831       30.040
    Sampled, SCF*

  Percent Isokinetic                107.5         103.5         109.9

Stack Parameters:

  Temperature, Deg. F                 593          601          602

  Air Flow Rates
SCFM*, Dry
ACFM, Wet
Method 5 Results (English):
Catch, milligrams
Concen. , grains/DSCF*
Emissions, pounds/hour
Method 5 Results (Metric):
Concen., milligrams/DSCM*
Emissions, kilograms/ hour
34,010
78,921

15,367.5
7.5227
2,192.95

17,212.4
994.7
33,432
78,066

15,929.3
8.2405
2,361.38

18,855.4
1071.1
31,708
73,375

13,951.5
7.1672
1,947.90

16,399.4
883.5
* 68 Deg. F. - 29.92 in.  Hg.

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                                 2-4
                              TABLE 2-3

                PARTICIPATE TESTS SUMMARY  OF  RESULTS

                      I.D.  Fan Inlet,  East Side



                                    456

Run Date                         04/17/84     04/17/84     04/18/84

Test Train Parameters:
  Volume of Dry Gas                25.334        26.926       27.172
    Sampled, SCF*

  Percent Isokinetic                102.4         106.7        104.0

Stack Parameters:

  Temperature, Deg. F                 549           545          555

  Air Flow Rates
SCFM*. Dry
ACFM, Wet
Method 5 Results (English):
Catch, milligrams
Concen. , grains/DSCF*
Emissions, pounds/hour
Method 5 Results (Metric):
Concen., milligrams/DSCM*
Emissions, kilograms/ hour
14,717
33,312

7,211.5
4.3930
554.15

10,051.4
251.4
15,013
33,970

7,652.4
4.3858
564.37

10,035.4
256.0
15,542
34,752

7,309.4
4.1514
553.04

9,498.8
250.9
* 68 Deg. F. - 29.92 in. Hg.

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                                2-5
                             TABLE 2-4

                PARTICULATE TESTS  SUMMARY OF RESULTS

                     I.D. Fan Inlet, West  Side
Run Date

Test Train Parameters:

  Volume of Dry Gas
    Sampled, SCF*

  Percent Isokinetic

Stack Parameters:

  Temperature, Deg. F

  Air Flow Rates
    7            8

04/17/84     04/17/84
  27.582
   105.6
     543
26.633
 102.0
   539
           04/18/84
25.955
 102.7
   545
SCFM*, Dry
ACFM, Wet
Method 5 Results (English):
Catch, milligrams '
Concen. , grains/DSCF*
Emissions, pounds/hour
Method 5 Results (Metric):
Concen., milligrams/DSCM*
Emissions, kilograms/hour
14,747
33,246

6,547.5
3.6634
463.07

8,382.2
210.0
14,740
33,331

6,438.7
3.7308
471.38

8,536.6
213.8
14,270
32,223

6,299.2
3.7454
458.11

8,569.8
207.0
* 68 Deg. F. - 29.92 in. Hg.

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                                 2-6
                              TABLE 2-5

       PARTICULATE AND SULFUR DIOXIDE TESTS SUMMARY OF RESULTS

                           Scrubber Stack



                                     10           11           12

Run Date                         04/17/84     04/17/84     04/18/84

Test Train Parameters:
  Volume of Dry Gas                88.220       91.896       91.630
    Sampled, SCF*

  Percent Isokinetic                 99.0        100.2         98.2

Stack Parameters:

  Temperature, Deg. F                 140          140          141

  Air Flow Rates
    SCFM*, Dry                     29,064       29,915       30,432

    ACFM, Wet                      41,994       43,217       43,558

Method 5 Results (English):

  Catch, milligrams                 192.1        187.7        204.4

  Concen., grains/DSCF*            0.0336       0.0315       0.0344

  Emissions, pounds/hour             8.37         8.08         8.98

Method 5 Results (Metric):

  Concen., milligrams/DSCM*       76.8895      72.1231       78.768

  Emissions, kilograms/hour          3.80         3.66         4.07

Method 8 Sulfur Dioxide (English):

  Catch, Milligrams               2,871.8      3,006.8      2,772.0

  Concen., ppmbyvol., dry        432.06       434.27       401.52

  Emission, pounds/hour            125.15       129.48       121.78

                                         (continued on next page)

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                                 2-7
                             TABLE  2-5




       PARTICULATE AND SULFUR DIOXIDE  TESTS  SUMMARY  OF  RESULTS




                           Scrubber  Stack




                             (continued)






                                     10            11           12




Run Date                         04/17/84     04/17/84      04/18/84




Method 8 Sulfur Dioxide (Metric):




  Concen., milligrams/DSCM*      1,149.46     1,155.35      1,068.22




  Emissions, kilograms/hour         56.77        58.73         55.24






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

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                                     2-8
                                  TABLE 2-6

                    SUMMARY OF PARTICLE SIZING TEST RESULTS

                              Multiclone Inlet
SAMPLING DATA

  Date

  Start Time
  Finish Time

  Impactor Flow Rate (1/min)

  Isokinetic Ratio (%)


STACK DATA

  Temperature (degrees  C)

  Moisture (%)

  Velocity (m/min)


EMISSION DATA

  Concentration (mg/dscra)

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

  Cumulative % Mass less than
      10 microns

  Concentration < 10 microns:
    From PS runs, rag/dscra

    .From M-5 runs, mg/dscm

  Emission Rate < 10 microns
      (kg/hr, from M-5  runs)
PS Run 1
4/17/84
1323,1412
1325,1413
21.90
108.5
309
12.3
643.4
13,297
62.0
42.0
5,670
8,996
418
PS Run 2
4/17/84
1751,1846
1753,1847
21.90
105.3
322
12.2
650.1
6,655
32.0
58.0
3,850
12,116
621
PS Run 3
4/18/84
1401,1434
1403,1436
15.30
103.9
320
11.6
471.1
8,019
44.0
34.0
2,600
6,164
300
Av e raj
	
	
	
	
317
12.0
588.2
9,324
46.0
45.0
4,040
9,091
446
 PS: Particle Size Run
M-5: Method 5 Particulate Run

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                              2-9
COMPANY NAME
ADDRESS.
                   PARTICLE SIZE DISTRIBUTION
             CE Mineirals Mulcoa Plant
         Andersonville, Georgia
AVERAGE OF RUNS la,lb,2a,2b,
               3a,3b
SAMPLING LOCATION Multiclone  Inlet
DATE!s)  4/17/84 , 4/18/84	
                             DENSITY = 1  GM/CM
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                                     2-10
                                  TABLE 2-7

                    SUMMARY OF PARTICLE SIZING TEST RESULTS

                          I.D. Fan Inlet, East Side
SAMPLING DATA

  Date

  Start Time
  Finish Time

  Impactor Flow Rate (1/min)

  Isokinetic Ratio (%)


STACK DATA

  Temperature (degrees  C)

  Moisture (%)

  Velocity (m/min)


EMISSION DATA

  Concentration (mg/dson)

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

  Cumulative % Mass less than
      10 microns

  Concentration < 10 microns:
    From PS runs, mg/dscm

    From M-5 runs, mg/dscm

  Emission Rate < 10 microns
      (kg/hr, from M-5  runs)
PS Run 4
4/17/84
1243,1258
1247,1302
17.70
103.8
289
13.1
538.4
8,777
87.0
47.0
4,120
4,724
118
PS Run 5
4/17/84
1745,1755
1747,1757
17.10
105.9
281
13.4
528.5
9,406
94.0
47.0
4,400
4,716
120
PS Run 6
4/18/84
1414,1424
1416,1426
17.60
110.7
294
11.8
661.5
8,884
93.0
32.0
2,770
2,944
78
Averaj
	
	
	
	
288
12.8
576.1
9,022
91.0
42.0
3,763
4,121
105
 PS: Particle Size Run
M-5: Method 5 Particulate Run

-------
COMPANY NAME
               2-11




     PARTICLE SIZE DISTRIBUTION



CE Minerals Mulcoa Plant
                                               AVERAGE OF
                                                                    , 5b,
ADDRESS  Andersonville, Georgia
SAMPLING LOCATION


DATE! s )  4/17/84. 4/18/84
                 1-D- Fan Inlet East- side
                           DENSITY = I  CM/CM
                                                6a,6b
ft n '
on =
70.. -

50 - -:
£
40 	 :
30 • :

1 i
u
IT
i -
I 0
i . *
H 8—|
26 =
6 --
$ 5-i
U i
A -. . =
O =
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                 i    rm	i	r	n""r"i
                 5    10  IS 20    30  40 SO  60  70   SO  85 90   95   98
                   PERCENT OF PARTICLES LESS THAN  INDICATED SIZE

-------
                                             2-12
                                          TABLE 2-8

                           SUMMARY OF PARTICLE SIZING TEST  RESULTS

                                  I.D. Fan Inlet,  West Side
      SAMPLING DATA

       Date

       Start Time
        Finish Time

        Impactor Flow Rate (1/min)

        Isokinetic Ratio (%)


      STACK DATA

        Temperature (degrees  C)

        Moisture (%)

        Velocity (m/min)


      EMISSION DATA

        Concentration (mg/dscm)

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

        Cumulative % Mass less than
            10 microns

        Concentration < 10 microns:
          From PS runs, mg/dscm

          From M-5 runs, mg/dscm

        Emission Rate < 10 microns
            (kg/hr, from M-5  runs)
PS Run 7
4/17/84
1350
1352
30.00
109.3
293
13.3
852.4
6,191
74.0
72.0
4,429
5,951
149
PS Run 8
4/17/84
1833,1857
1835,1859
23.80
109.9
286
13.9
682.9
6,241
73.0
55.0
3,430
4,695
118
PS Run 9
4/18/84
1454
1456
14.80
108.4
279
13.6
423.2
5,273
62.0
46.0
2,425
3,942
96
Averag
	
	
	
	
286
13.6
652.8
5,902
70.0
57.0
3,428
4,862
121
       PS: Particle Size Run
      M-5: Method 5 Particulate Run
\

-------
                            2-13
COMPANY NAME
ADDRESS _.
                 PARTICLE SIZE DISTRIBUTION



            CE Minerals Mulcoa Plant             AVERAGE OF RUNS^a .83,813,93
        Andersonville, Georgia
SAMPLING LOCATION I.D. Fan Inlet West-side	


DATE!s)  4/17/84. 4/18/84	






                           DENSITY = I GM/CM3
ft n a

70 , -

50- :
40 =
30 "
? n
i -
1 O _ «-
9 *


26 ''
^
3 1
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                i     riii   i
                5    10 IS 20   30  40  50 60 70  SO 85  90    95   98
                   PERCENT OF PARTICLES LESS THAN INDICATED SIZE

-------
                           2-14
                        TABLE 2-9




NITROGEN OXIDES (AS N02) EMISSION RATES & CONCENTRATIONS




                    SUMMARY OF RESULTS




                      Scrubber Stack
-
Run Date
Sample Number
Parameters per Run:
Air Flow Rate, dry SCFM
Nitrogen Oxides (as N02 ) Results:
Concentration, ppm, dry
Emissions, Lb/Hr
10
04/17/84
10A-10D
29,060
265.5
55.2
- K.un numoers -
11
04/17/84
11A-11D
29,920
311.4
66.7
12
04/18/84
12A-12D
30,430
321.0
69.9

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

                         SUMMARY OF VISIBLE EMISSIONS

                                    Run  1
Date: 4/17/84
Type of Discharge: Stack
Height of Point of Discharge:  120'
Wind Direction; West-North-West
Color of Plume:_White	
Observer No.:
Distance from Observer to Discharge Point:
Direction of Observer from Point:  South
                                   Type  of Plant: Clay
                                   Location of  Pischarge:Multiclone
                                   Description  of  Sky;Partly Cloudy
                                   Wind Velocity;  8-12	
                                   Detached Plume: No
                                   Duration of  Observation; 197 min.
                                 950 '
Height of Observation Point;  Ground level
Description of Background; Partly Cloudy
Set         Time

Number   Start  End
                 SUMMARY  OF  AVERAGE OPACITY
                Opacity        Set         Time

              Sum  Average    Number    Start  End
                                                 Opacity

                                               Sum Average
  1
  2
  3
  4
  5
  6
  7
  8
  9
 10
 11
 12
0958
1004
1010
1016
1022
1028
1034
1040
1046
1152
1158
1204
1004
1010
1016
1022
1028
1034
1040
1046
1152
1158
1204
1210
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
13
14
15
16
17
18
19
20
21
22
23
1210
1216
1222
1228
1234
1240
1246
1252
1258
1304
1310
1216
1222
1228
1234
1240
1246
1252
1258
1304
1310
1315
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
        - 3
        O
        2
        o
        U 2
                            1 HR
                                     30

                                     TIME

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

                         SUMMARY OF  VISIBLE EMISSIONS

                                    Run  2
Date: 4/17/84
Type of Discharge: Stack
Height of Point of Discharge:  120*
Wind Direction; West-North-West
Color of Plume; White	
Observer No.:
Distance from Observer to Discharge Point:
Direction of Observer from Point:  South
                    Type of Plant; Clay
                    Location of Discharge;Multiclone
                    Description of Sky:Partly Cloudy
                    Wind Velocity: 12-15	
                    Detached Plume: No
                    Duration of Observation: 150  min.
                   800'
Height of Observation Point;  Ground level
Description of Background:  Partly Cloudy
Set         Time

Number   Start  End
   SUMMARY OF  AVERAGE OPACITY
  Opacity        Set         Time
Sum  Average
Number
Start  End
  Opacity

Sum  Average
  1
  2
  3
  4
  5
  6
  7
  8
  9
 10
 11
 12
 13
 14
1500
1506
L512
1518
1524
1530
1536
1542
1548
1554
1600
1606
1612
1618
1506
1512
1518
1524
1530
1536
1542
1548
1554
1600
1606
1612
1618 .
1624
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
15
.16
17
18
19
20
21
22
23
24
25
26


1624
1630
1636
1642
1646
1652
1658
1704
1710
1716
1722
1728


1630
1636
1642
1646
1652
1658
1704
1710
1716
1722
1728
1730







                                        0
                                        0
                                        0
                                        0
                                        0
                                        0
                                        0
                                        0
                                        0
                                        0
                                        0
                                        0
                              0
                              0
                              0
                              0
                              0
                              0
                              0
                              0
                              0
                              0
                              0
                              0
                          I HR
                                    30

                                   TIME

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

                         SUMMARY OF VISIBLE EMISSIONS

                                    Run 3
Date: A/18/84
Type of Discharge; Stack
Height of Point of Discharge: 120'
Wind Direction; West-North-West
Color of Plume: White	
Observer No.:
                                  Type  of Plant: Clay
                                  Location  of Discharge;Multiclone
                                  Description of Sky: Clear	
                                  Wind Velocity; 8-10	
                                  Detached  Plume: No
Distance from Obseiver to Discharge Point:
Direction of Observer from Point: South
                                   Duration of Observation; 150 min.
                                  800 '
Height of Observation Point; Ground level
Description of Background; Clear
Set

Number
   Time

Start  End
           SUMMARY OF AVERAGE  OPACITY
          Opacity        Set         Time
        Sum  Average    Number    Start  End
                                      Opacity

                                     Sum  Average
  1
  2
  3
  4
  5
  6
  7
  8
  9
 10
 11
 12
1203
1209
1215
1221
1227
1233
1239
1245
1251
1257
1303
1309
1209
1215
1221
1227
1233
1239
1245
1251
1257
1303
1309
1315
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
13
14
15
16
17
18
19
20
21
22
23
24
1315
1321
1327
1333
1339
1345
1357
1403
1409
1415
1421
1427
1321
1327
1333
1339
1345
1351
1403
1409
1415
1421
1427
1433
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
        O
                            I HR
                                      30

                                     TIME

-------
                                     3-1
                         STATEMENT OF CONFIDENTIALITY
    All information referenced in the Process Description as (Confidential
Addendum No. 1 through No. 7) have been deemed confidential by the C.E.
Minerals Mulcoa Plant officials.  Due to this fact, this information has been
deleted from the final report and put under separate cover.  Pending
determination by the Environmental Protection Agency of the confidentiality
of this information., they have been submitted as described to us for official
entry into our confidential files.

-------
                                        I
                                     3-2
3.   PROCESS DESCRIPTION AND OPERATION

     3.1  Production of Calciner Feed.

     3.1.1  Raw Material.   A simplified  process  flow diagram representative of
plant operations is shown  in Figure 3-1.  Kaolinitic clays  are obtained  from
nearby mining operations,  transported  to the plant by truck, and deposited in
outside storage piles. Various clays  are withdrawn from storage piles and
mixed in predetermined proportions  to  obtain the desired product composition
and properties.  (See Confidential  Addendum, No. 1,  for a description of
processing methods).

     3.1.2  Fuel.  The fuel used in this operation is natural gas.   No.  2  fuel
oil is a standby fuel.

     3.1.3  Pellet Formation.   The  clay  is  pulverized (see Confidential
Addendum, No. 2, for particle  size  information)  in a roller mill swept with
heated air.  The pulverized clay produced by the roller mill is mixed with
water in a pug mill, and  the mixture is  extruded to form 1.3 to 2.5 cm (0.5 to
1 in.) diameter pellets (referred to as  "noodles") of varying lengths up to
about 0.6 m (2 ft.).
     Some of the raw material  bypasses the mills and is only processed through
the pug mill and extruder before being calcined.  Mulcoa 47 (and Mulcoa 44, a
product very similar to Mulcoa 47 in composition) are produced using the bypass
method.  C.E. Minerals personnel believe these bypass materials generate the
most difficult to  control emissions.  (Mulcoa 44 was being processed during the
testing).

     3.1.4  Pellet Drying.  Pellets produced by the extruder are dried on a
moving  pan dryer (natural gas  is used as fuel).  This pellet dryer dries only
the surface of  the  pellets so that they do  not  stick together and their
handling  properties are improved.  The moisture content of  the dried pellets is
20 to 22  percent,  and  they have a loose fill density of 1,600 to 1,760 kg/m3
(100 to  110 Ib/ft3) . The average water evaporation  rate for  the pellet dryer
is about  1,810 kg/h (4,000 Ib/h).

-------
           Outside
           Storage
           Piles
Truck
Tiamporl
                                                 Vent
                                 Vent
                                                                                       Collected  .
                                                                                       Dust
                                                                                                   Water
                    Vent
  Wot Cyclone
  Scruljljor  •
                                                           Pallet Dryer
                                                           (Moving Pan)
                                                                            1/2 - 1 In.
                                                                            Diameter
                                                                            Pellets
                    To Bulk Loading
                                  To Bugged
                                  Shipping
Figure  3-1.   Simplified process  flov;  diagram for C-G Minerals plant at Andcrsonvllle,  Georgia,

-------
                                     3-4
     3.1.5  Pellets as Feed.  As  shown  in Figure  3-1,  dried  pellets  are  used  as
feed material for the rotary  calciner (kiln)  and  vibrating-grate cooler
system.  The operations described above for mixing,  fine grinding, and
extruding the clay are all  designed  to  effect intimate contact  of the clay
particles and to promote a  chemical  reaction  that produces mullite during
calcining.  All moisture and  other volatile matter are removed  during
calcining.  The chemical reactions are  as follows:
                                       Heat
                       ~ 2H20  	>  A1203 - 2Si02  + 2H20

                                   Heat
         3 (A12(>3 - 2Si02)  	>  3A1203 - 2Si02 +  4Si02
                                           Mullite

         Pellets produced using the bypass method contain particles that are
less uniform in size than those produced  with the additional milling.  This
causes  them to break apart more during  calcining, thus making emissions from
bypass  materials more difficult to control than the emissions from other
mullite products.

     3.2  Calcining Process.

     3.2.1  Kilns.  C.E. Minerals operates seven identical rotary kilns in
Andersonville, and each kiln is operated  at its design capacity.  Data for the
rotary  kiln equipment is shown in Table 3-1.  The kilns are operated
continously throughout the year except for occasions when a shutdown is
necessary to repair equipment.  The maximum kiln temperature is 1540° to
1760°C  (2800°  to 3200°F) and the heat application method is counterflow.
The  pulverized coal used as fuel has a heating value of about 30,260 kj/kg
(13,000 Btu/lb) and contains 5 to 6 percent ash and less than 1 percent sulfur.

     3.2.2  Calcine.  The hot  calcine discharged from the  rotary kiln is fed to
a  vibrating-grate  cooler (see Confidential Addendum, No. 3, for cooler

-------
                                   3-5
             TABLE  3-1.   DATA FOR ROTARY KILNS USED AT
           C-E MINERALS MULCOA PLANTS AT ANDERSONVILLE, GEORGIA
Equipment dimensions
Design production capacity
Method of determining actual
  production rate
Hours of operation
  Hours/day
  Hours/week
  Hours/year
Retention time (min)
Maximum kiln temperature (°F)
Heat application method
Fuel used
Fuel to product ratio (ton/ton)
Feed moisture content (%)
Feed particle size
Feed density, loose fill (lb/ft3)
Product moisture content (%)
Effect of over-calcining
Heat recovery system

Normal life of rotary kiln (yr)
Maintenance and repair practices
 8  ft  dia. by 150 ft long
 (See  Confidential Addendum, No. 5)
 Electronic scale on conveyor  .
   feed  belt

 24
 168
 8,760
 120
 2,800 to 3,200
 Counterflow
 Coal  (pulverized)
("See Confidential Addendum, No. 6} j
 20-22
 \  to  1  in. dia. pellets
 100-110
 0
 Reduces quality
 ~  80% of exhaust air from cooler
   used  as secondary air for kiln
 50
 Good  preventive maintenance;
   scheduled shutdowns for repairs
   as  necessary.  Patching of
   refractory lining is
   infrequently required.

-------
                                      3-6
dimensions).  The clay pellets are moved through the cooler by the horizontal
vibration of the bed along the longitudinal axis.  (See Confidential Addendum,
No. 4, for a description of cooler operation).

     3.2.3  Exhaust Emissions.  Air passes upward through the grate and  the
vibrating bed of calcine.  About 80 percent of the air leaving the cooler is
sent to the discharge end of the rotary kiln as secondary air for that unit.
The remainder of the air from the cooler is ducted through a multiclone
collector, an induced draft fan, and a vent stack.  Exhaust gases from the
rotary kiln are ducted through a multiclone collector (manufactured by Zurn
Industries) , an exhaust fan, a venturi scrubber, and a vent stack to the
atmosphere.  (See Confidential Addendum, No. 7, for vent stack dimensions).

     3.2.4  Control Equipment.  At the inlet to the scrubber the gas
temperature is about 2H6°C (600°F).  This scrubber is constructed of 316
low-carbon stainless steel.  Sulfur in the clay and coal results in acid
buildup in the scrubber water and causes corrosion problems.  A system for
adding calcium oxide (CaO) to the scrubber water has recently been installed.
The water flow rate to the scrubber is 1,363 1/min (360 gpm).  The pressure
drop across the scrubber is 4.5 kPa (18 in. w.c.).  The design efficiency of
the wet scrubber is greater than 90 percent.

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

     4.1  Suitability of Sampling Sites.   The primary goal  of  the testing
program was to characterize emissions  from the #4  rotary calciner dryer.
Additionally, physical properties of  the  process  feed stock and  the product
were investigated.  Sampling sites appropriate to  these objectives were
approved prior to testing.   Each sampling location is discussed  individually,
and the position of each site within  the  system is illustrated in Figure 4-1.

     4.2  Rotary Calciner Feed Inlet  (Sampling Location A). Grab samples  of
the feed to the rotary calciner were  collected for sieve analysis and
moisture content determination.  Samples  were taken during  each set of
simultaneous Method 5 runs.

     4.3  Vibrating Grate Cooler Product  Outlet (Sample Location B).  Grab
samples of the product were collected for sieve analysis and moisture content
determination.  Samples were taken during each set of simultaneous Method  5
runs.

     4.4  Vibrating Grate Cooler Multiclone Outlet (Sample Location G). Grab
samples of the product were collected for sieve analysis and moisture content
determination.  Samples were taken during each set of simultaneous Method  5
runs.

     4.5  Multiclone Inlet (Sampling  Location C).   Particulate emissions  and
particle size distribution testing was conducted in the 55-inch by 95-inch
expansion flume.  Four sampling ports were positioned 40 feet  from the
ground, 7.6 feet from the nearest upstream disturbance and 4.7 feet from  the
nearest downstream disturbance.  A schematic of the sampling location is
shown in Figure 4-2.
     Particulate sampling was done using  24 points (i.e. six points located
on four traverse axes); each point was sampled for 2.5 minutes, resulting  in
a total test  time of 60 minutes.
     Particle size runs were performed for either 1.5 or 2  minutes.  During
each run, two points were sampled for equal lengths of time.

-------
                               4-2
              ATMOSPHERE
                  u
               .  STACK
                   I
                 WET
               CYCLONE
              SCRUBBER
                     OBSERVATION POINT-I


                       SAMPLING POINT-F
                                            ATMOSPHERE
                                     STACK
SAMPLING
POINT-D
                 FAN
     T    4
EAST 'CD    (£>" WEST
SAMPLING
POINT-E
SAMPLING
POINT-C
SAMPLING
POINT-A
             MULTICLONE
                   SAMPLING
                   POINT-G
                                     FAN
                                  MULTICLONE
      I	
      PRODUCT IN
ROTARY
CALCINER


VIBRATING
GRATE
COOLER
                                         	AMBIENT AIR
                                                        -*—TO  BULK
                                                          LOAD
                                     SAMPLING	/TO SCREENING,
                                     POINT-B  CRUSHING & BAGGING
                       A  METHODS  5&8,7
                      <-—* TRACE METALS
                       •  METHOD 9
                                    ® GRAB  SAMPLE

                                    O METHOD  5,  IMPACTOR,
                                      TRACE METALS
 FIGURE 4-1.  ROTARY CALCINER PROCESS SCHEMATIC SHOWING SAMPLING
              LOCATIONS

-------
                    95"
                              4-3
                               55'
                            I.I
                                      P B
                                           24 SAMPLING  POINTS
                          SECTION M-M
    TO
MULTICLONE
                                                        FROM
                                                        CALCINER
                                       .4  SAMPLING PORTS
 FIGURE 4-2.  MULTICLONE INLET  DIMENSIONS WITH SAMPLING PORT
              AND POINT LOCATIONS

-------
                                     4-4
     4.6  I.D. Fan Inlet East & West (Sampling Locations D & E).   Particulate
emissions and particle size tests were performed in a 104.5-inch  by 24.5-inch
rectangular duct.  Five sampling ports were located 164 inches  upstream  and
120 inches downstream from the nearest flow disturbance, as shown in
Figure 4-3.
     For particulate tests, each of the I.D. fan inlet cross sections  (east
and west) was divided into 25 equal areas (i.e. five sampling points along
each of five traverse axes).  Of the 25 possible points, only 20  points  were
sampled; the first point along each traverse axis was not sampled due  to the
disruption of air flow along the air duct wall caused by high negative
pressure.  Each of the 20 points was sampled for three minutes, resulting in
a total run time of 60 minutes.
     Particle size runs ranged in length from 1.5 to 4 minutes.  During  each
run, two points were sampled for equal lengths of time.

     4.7  Scrubber Exhaust Stack (Sample Location F, Observation  Point I).
The particulate and particle size tests were performed in a 60-inch diameter
round duct.  Two sampling ports spaced 90° apart are located approximately
26 feet downstream from the nearest flow disturbance (straightening vanes)
and 48 feet upstream from the stack gas exit point.  A schematic  of the
sampling location is provided in Figure 4-4.
     The stack cross section was divided into 24 equal areas (i.e., two
traverse axes with 12 points each) for particulate and sulfur dioxide
emissions sampling.  Each point was sampled for five minutes, resulting  in a
total run time of 120 minutes.
     Visible emissions observations and nitrogen oxides testing were also
performed at the scrubber exhaust stack.
     Particle size testing was not performed at this location due to the
presence of moisture in the flue gas.

-------
4-5
5 AXES
4 POINTS/AXIS
20 TOTAL POINTS
4"~1_
1

1


^



_^ 	 l_i_ ' 	 !— ' 	 — '_t_-
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A
U U U U
B C D E

1
T
24.5"
~T
SECTION M-M
TO SCRUBBER







WEST
A


-







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-24.5»_
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FAN



	 	



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X

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1







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/





























EAST
A





M •















FIGURE 4-3. I.D. FAN
INLET
POINT LOCATIONS




















>1
V
,. FRC
1
- 1
MULTICLONE

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i



00
A B

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(TYPICAL FOR EAST AND WEST INLETS)

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                                               2 AXES
                                              12 POINTS/AXIS
                                              24 TOTAL POINTS
                                                          60" DIA.
                                             SECTION L-L
                            2  SAMPLING PORTS
                             STRAIGHTENING VANES
FIGURE 4-4.   SCRUBBER EXHAUST STACK DIMENSIONS WITH SAMPLING
              PORT AND POINT LOCATIONS

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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 C.E. Minerals Mulcoa plant
in order to gather data concerning emissions from the #4  rotary calciner and
associated air pollution control equipment and to investigate physical
properties of the process feed  stock  and the product.   The sampling  program
included tests for particulate  and sulfur dioxide,  trace  metals,  and nitrogen
oxides emissions, sieve and moisture  analysis on feed and product samples,
plume opacity, and particle size distribution.  The sampling methods used are
fully described in Appendix 7.3, portions of which are  extracted  from 40 CFR
Part 60.

     5.2  Particulate and Sufur Dioxide Emissions Testing.  Where
appropriate, particulate emissions sampling conformed  to  the standards and
procedures set forth by EPA Reference Method 5.  Method 8 was combined with
Method 5 testing at the scrubber exhaust stack for the  determination of
sulfur dioxide.  It was necessary at  some locations to  modify the test
procedures in order to cope with heavy particulate loading and/or high
negative pressure,,

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

     5.4  Sieve Analysis and Moisture Content.  Sieve analysis and moisture
content determinations were performed on all feed and 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.
                     f
     5.5  Plume Opacity.  Plume opacity observations were performed in
accordance with EPA Reference Method 9 as described in 40 CFR Part 60.

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                                     5-2
     5.6  Particle Size Testing.  Particle size determinations  were  made
using a right angle inlet preseparator, followed by an Andersen 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.

     5.7  Nitrogen Oxides Testing.  Nitrogen oxides emissions were determined
by utilizing the sampling and analytical procedures outlined  in EPA  Method 7.
Each Method 7 run consisted of four samples taken concurrently  with  the
Method 5 sampling.

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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 sind 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 or by Entropy.  Calibration data for the sampling equipment are
contained in Appendix 7.9.

     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 and a blank run.
     The 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 stack, 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 Section 7.6, was 0.01 milligrams, based upon weight differences
ranging from 0.00 to 0.02 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 0.05 milligrams, based upon a difference
ranging from 0.01 to 0.10 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 7.2.3.

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