&EPA
            United States
            Environmental Protecnon
            Agency
           Office of Air Quality
           Planning and Standards
           Research Trianale Park NC 27711
EMB Report 83-CDR-8
September 1983
            Air
Calciners and
Dryers

Emission Test
Report
Black Hills
Bentonite
Company
Mills, Wyoming

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DCN 84-222-078-06-01
                         Contract No.  68-02-3545

                           Work Assignment #13

                       EMB - File Number 83-CDR-8

                           EPA PROJECT OFFICER

                             D.  P.  Holzschuh


                          BENTONITE DRYER TEST

                      BLACK HILLS BENTONITE COMPANY

                             MILLS, WYOMING
                               CONTRACTOR

                      TRW Environmental  Operations
                 Progress Center, Post Office Box 13000
              Research Triangle Park, North Carolina  27709
                           TRW PROJECT MANAGER
                              J.  B.  Homolya
                               PREPARED BY

                J.  McReynolds, M.  Meech, and A.  Blackard
                      TRW Environmental Operations
                              PREPARED FOR

                       Emission Measurement Branch
               Emission Standards and Engineering Division
                  U.  S. Environmental Protection Agency
              Research Triangle Park, North Carolina  27711

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                            TABLE OF CONTENTS

Number
  1       INTRODUCTION 	   1-1
  2       SUMMARY AND DISCUSSION OF RESULTS  	   2-1
          2.1  Summary of Results	2-1
          2.2  Discussion of Results	2-14
          2.3  Particulate Data Reduction System (PADRE) 	   2-15
  3       PROCESS DESCRIPTION AND CONDITION DURING TESTING ....   3-1
          3.1  Process Description 	   3-1
          3.2  Process Conditions During Testing 	   3-6
  4       SAMPLING LOCATIONS 	   4-1
  5       SAMPLING AND ANALYTICAL PROCEDURES 	   5-1
          5.1  Sampling Procedures 	   5-1
          5.2  Analytical Procedures	5-4
  6       QUALITY ASSURANCE PROCEDURES AND RESULTS 	   6-1
APPENDICES
  A       CALCULATIONS AND RESULTS 	   A-l
          A-l  Definition of Terms and Sample Calculations ....   A-2
          A-2  Complete Method 5 Particulate Matter Results  .  .  .   A-6
          A-3  Complete SASS Particulate Matter Results
               Computed as Method 5 Results  	   A-25
          A-4  Complete Andersen Cascade Impactor Particulate
               Matter Results Calculated as Method 5 Results .  .  .   A-42
          A-5  PADRE Computer Printouts  	   A-90

                               (continued)

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                      TABLE OF CONTENTS (Concluded)

Number                                                              Page
 B        FIELD DATA SHEETS	B-l
          B-l  Traverse Point Locations  	   B-2
          B-2  EPA Method 5 - Stack Field Data Sheets	B-5
          B-3  EPA Method 5 - Sample Train Recovery  Sheets  ....   B-16
          B-4  SASS Field Data Sheets	B-23
          B-5  SASS Sample Train Recovery Sheets 	   B-27
          B-6  Andersen Particle Sizing Field Data Sheets   ....   B-32
 C        SAMPLING AND ANALYTICAL PROCEDURES 	   C-l
          C-l  Detailed SASS Operating Procedures
               (ORP Program Modification)  	   C-2
          C-2  General Procedures for Operation of
               Inertia! Cascade Impactors  	   C-15
          C-3  General Procedures for Operation of
               EPA Method 5 Train	C-27
 D        FIELD ANALYTICAL RESULTS 	   D-l
          D-l  EPA Method 5, SASS, and Andersen Field
               Gravimetric Results 	   D-2
          D-2  Alternate EPA Method 3 Results GC/TCD 	   D-15
          D-3  Visible Emission Data Method 9	D-18
          D-4  Fugitive Emission Data Method 22  	   D-35
          D-5  PADRE Results Comparison Data 	   D-68
 E        PARTICIPANTS 	   E-l
 F        SAMPLING LOG	F-l
 G        CALIBRATIONS, ANDERSEN, METHOD 5 	   G-l
 H        PROCESS FEED AND PRODUCT AS ANALYZED BY ASTM-D422  ...   H-l
                                   iii

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                             LIST OF FIGURES
Figure                                                              Page

 3-1      Process schematic - Black Hills Bentonite Co.,
          Mills,  Wyoming 	   3-2

 3-2      Process schematic - Black Hills Bentonite Co.,
          Mills,  Wyoming 	   3-3

 4-1      Outlet sampling site and traverse points  -
          Black Hills Bentonite Co., Mills, Wyoming  	   4-2

 4-2      Inlet sampling site and traverse points -
          Black Hills Bentonite Co., Mills, Wyoming  	   4-3

 4-3      Method 22 observation location for feed belt
          discharge point  	   4-4

 5-1      Method 5 - sampling train	5-2

 5-2      Andersen sampling train with right angle  pre-impactor  .   5-3

 5-3      SASS sampling train for particulate sizing and
          mass emissions determination 	   5-5

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                             LIST OF TABLES


Table                                                               Page

 2-1      Summary of Test Results	2-2

 2-2      Summary of Visible Emissions 	   2-3

 2-3      Summary Comparison of Method 5, Andersen,
          and SASS Test Results	2-4

 2-4      Summary of Cumulative Mass Less than the
          Stated Size at the Inlet and Outlet Locations with
          Collection Efficiencies  	   2-5

 2-5      Andersen Weights Per Stage and Cumulative Percent
          Mass Less than D50 at Standard Diameters	2-6

 2-6      SASS Compared to Andersen for Cumulative Mass
          as Percent Less than Stated Size	2-7

 2-7      Summary of Test Parameters for Test #1:   9/20/83 ....   2-8

 2-8      Summary of Test Parameters for Test #2:   9/21/83 ....   2-10

 2-9      Summary of Test Parameters for Test #3:   9/22/83 ....   2-12

 3-1      Data for Rotary Dryer at Black Hills Bentonite
          Company Plant at Mills, Wyoming  	   3-4

 3-2      Data for Baghouse Control Equipment for Rotary Dryer at
          Black Hills Bentonite Company Plant at Mills, Wyoming  .   3-5

 3-3      Operating Conditions - Run No.  1 - 9/20/83	3-7

 3-4      Operating Conditions - Run No.  2 - 9/21/83	3-8

 3-5      Operating Conditions - Run No.  3 - 9/22/83	3-9

 6-1      Mettler H20T Balance Checks  	   6-2

 6-2      Plugged Instack Impactor Blank Results 	   6-3

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                            1.  INTRODUCTION

     This report provides emission test data and process information for
the dryer and emission control equipment used in the processing of
bentonite at the Black Hills Bentonite Company in Mills, Wyoming.   The
report was prepared as part of the U.S. Environmental Protection Agency
Industry Studies Program conducted by the Emission Standards and
Engineering Division, Emission Measurement Branch (EMB).  The purpose of
the program is to develop new source performance standards for calciners
and dryers in the mineral industries.
     TRW Environmental Operations, Research Triangle Park, North Carolina,
was contracted to do the field sampling and provide analytical results.
The field sampling was conducted September 20-22, 1983.   The data obtained
during the emission tests consisted of:  (a) particulate matter (PM)
concentrations, (b) PM mass emission rates, (c) particle size distri-
butions (PS) for the PM, (d) visible emission (VE) measurements, and
(e) feed and product size and moisture content.  The New Source Performance
Standards (NSPS) contractor responsible for regulatory and engineering
analysis of the emissions data is Midwest Research Institute (MRI).
     The processing of bentonite commences with the transportation of
bentonite by truck to the facility and stockpiling in designated open
areas.  Bentonite is transferred into a hopper from which it is conveyed
into a slicer.  The resultant particles (fines - 1.0 in) of bentonite
are fed to a direct-fired rotary dryer at about thirty tons per hour (TPH).
The dryer, which uses natural gas for initial start-up,  was fired with a
low sulfur coal at 37 pounds of coal per ton of product to provide
proper process heating during the tests.  The presence of montmorillonite
(Al2Si4010(OH)2  XH20) gives bentonite water-absorptive properties
which necessitate drying the bentonite prior to pulverization, air-
classification, and storage in hoppers.

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     During the pre-test survey it was determined that the proximity of
the product cyclone to the baghouse required the inlet testing location
for determination of emission control to be the inlet duct to the cyclone
rather than at the baghouse inlet.  This inlet data is required for
emission control modeling purposes.  The control device outlet test
location was an eight-foot extension installed on the baghouse exhaust
stack.  In addition to modeling purposes, this outlet data will be used
to determine the mass emission rate and the particulate sized 10 microns
or less (PM10) mass emission rate to the environment.  The results of
these tests revealed an average of 7732 pounds per hour (Ibs/hr) going
to the cyclone of which 461 Ibs/hr (6 percent) were 10 micron or less in
size.  The outlet averaged 2.69 Ibs/hr of which 2.00 Ibs/hr (74 percent)
were 10 microns or less.  This indicates a removal efficiency for the
cyclone and baghouse of 99.96 percent for all particles and 99.56 percent
removal for particles 10 microns and less.
     The average mass concentration at the inlet location was 113.08 grains
per dry standard cubic foot and 0.0204 grains per dry standard cubic
foot at the outlet.  The gas stream is diluted in the baghouse by a bag
heating system which heats ambient air, taken from inside the plant, and
blows the heated air around the bags.  This is done to prevent condensation
of moisture in the bags.  This heated plant air is not filtered.  The
heated air input volume is about 7378 dscfm.  This value is estimated
using the inlet location flue gas flow rate which averaged 7979 dscfm
and the outlet location flow rate which averaged 15357 dscfm.
     Visible emissions data taken at the baghouse exhaust stack during
the tests averaged 2.2 percent opacity for the three tests.  Visible
emissions were also taken at the feed discharge point where no visible
emissions were observed.
     The results of ASTM D422 analysis of bentonite process samples by
Law Engineering Testing Company are summarized.  Feed (before the dryer)
and product (after the dryer) samples showed the feed to average 0.0209 mm
in size and 20.1 percent moisture, while the product averages 0.0207 mm
in size and 9.2 percent moisture.  The specific gravity of both feed and
product was 2.75.
                                 1-2

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     The firebox temperature and stack temperatures were monitored
throughout the testing as was the feed system.   The process operated at
a constant rate and was in its normal operation mode throughout the
emission tests.
                                 1-3

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                  2.  SUMMARY AND DISCUSSION OF RESULTS

2.1  SUMMARY OF RESULTS
     The data reported for each of the three test runs include:
raw material feed rates, mass concentrations, mass emission rates, mass
removal efficiency, and visible emissions.  Table 2-1 presents a summary
of results for each test run and average values for the entire test
series.  The Andersen impactor values were obtained through use of the
PADRE program to determine the particle size distribution for each
impactor run.  The Method 5 tests were used to determine mass emission
rates and concentrations.  The PADRE value of percentage by weight for
particles less than 10 microns when multiplied by the Method 5 mass
emission rate yields the mass emission rate by weight of particles less
than 10 microns in size.  A summary of visible emissions during each
test period is reported in Table 2-2 for each of the two sampling
locations.
     In Table 2-3, SASS and Andersen emission rates are compared to the
emission rates as determined by Method 5 testing.  The SASS and Andersen
values are reported in pounds per hour and also as a percentage of the
Method 5 mass rate value.  The percent isokinetic rate is also reported
for each test.
     Andersen impactor data and the values as calculated by the PADRE
program are shown in Tables 2-4 and 2-5.  Andersen size distributions
are calculated by PADRE based on Mercer's definition of aerodynamic
impaction.  Data relating SASS test data to Andersen impactor test data
are found in Table 2-6.  Table 2-6 relates the four size categories, as
calculated by weight, for each of the SASS tests to the values as
calculated by PADRE for the comparable Andersen runs.
     A detailed summary of the test parameters for each of the three tests
is given in Tables 2-7 through 2-9.  Parameters for test #1 are found in
Table 2-7; parameters for test #2 in Table 2-8, and for test #3, parameters
are found in Table 2-9.

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                         Table 2-1.   SUMMARY OF TEST RESULTS

Date
Tine
Feed Rate
Wet feed rate (tons/hr)
Mass Concentrations
Inlet (gr/dscf)
Inlet 
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                 Table 2-2.   SUMMARY OF VISIBLE EMISSIONS
      Location                         Time                 Opacity (%)
Test #1 (9-20-83)
Baghouse Exhaust Stack


Average3 Test #1
Feed Belt Discharge



Test #2 (9-21-83)
Baghouse Exhaust Stack
Feed Belt Discharge



Test #3 (9-22-83)
Baghouse Exhaust Stack
Feed Belt Discharge




1300-1353
1527-1556
1600-1629

1250-1410
1425-1455
1520-1600
1600-1620

1545-1915
1545-1630
1640-1725
1735-1825
1835-1915

1030-1355
1030-1115
1125-1210
1220-1305
1320-1345

1.40
0.54
1.10
1.09
0.00
0.00
0.00
0.00

3.09
0.00
0.00
0.00
0.00

2.54
0.00
0.00
0.00
0.00
aTime weighted.
                                   2-3

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           Table 2-3.   SUMMARY  COMPARISON OF METHOD  5, ANDERSEN,  AND  SASS TEST RESULTS
Percentage of mass

Inlet Test 11
Method 5 test
SASS test
Andersen average
of 4 runs
Outlet Test #1
Method 5 test
Andersen test
Inlet Test 12
Method 5 test
SASS test
Andersen average
of 4 runs
Outlet Test *2
Method 5 test
Andersen test
Inlet Test 13
Huthod 5 test
SASS test
Andersen average
of 4 runs
Outlet Test #3
Method 5 test
Andersen test
Mass emissions
total catch
(Ib/hr)
8192C
4604C
10,261C
1.74C
1.56a
7821C
7531C
6475C
2.68C
1.74C
7183a
 7366C
5143C
3.6SC
2.07C
Mas* emissions
10 microns and
less (Ib/hr)
471a
645d
505.8a'c
1.28a
1.15a'c
413.7*
909.3d
345.3a'c
2.05a
1.33a'c
497. la
843. 6d
350.1a'c
2.66a
1.51a'c
Mass emissions
greater than 10
microns (Ib/hr)
7662a
3959d
9755a>c
0.46a
0.41a'c
7407a
6622d
6130a>c
0.63a
0.41a>c
6685a
6522d
4793a>c
.99"
.56a'C
Total macs
measured compared
to Method 5 (X)
100
56.2
125.2
100
89.6
100
96.3
82.8
100
64.9
100
102.5
71.6
100
56.7
10 microns
and less
(X)
5.75a
14.01d
5.75b
73.62a
73.62b
5.29a
12.0d
5.29b
76. 52a
76.52b
6.92a
11.45d
6.92b
72.76a
72.76b
Greater
than 10
microns
(X)
94.25a
85.99d
94.25b
26.38a
26.3Bb
94.718
87.93d
94.71b
23.48a
23.48b
93.088
88. 55d
93.08b
27.24a
27.24b
Percent
UoMnetlc
103. 6C
120. 4C
118. 4b
102. 6C
97. 4b
101. 7C
73. 4C
120. 6b
104. 5a
95. 3b
103. 4C
78. 7C
122. 8b
104. 6C
101. Ob
 Based on Andersen/PADRE results.
b8ased on PADRE results.
Calculated as a Method 5.
dBased on weight of the SASS size fractions calculated as a Method 5.

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ro
or
                         Table 2-4.   SUMMARY  OF CUMULATIVE MASS LESS THAN THE STATED SHE AT THE
                                 INLET AND OUTLET LOCATIONS WITH COLLECTION EFFICIENCIES
Andersen
standard
diameters
(microns)
.63
1.00
1.25
2.bO
3.00
6.00
10.00
J5.00
20.00
Averagi
Average of
3 outlets
(0 <50)
1.21
2.15
2.99
12.46

43.6'J
74.30
91.98
97.67
9 of the test
Average of
12 Inlets
(0 <50)
(X)

0.22
0.31
0.95
1.24
2.58
5.99
11.24
22.17
series
Removal a
efficiency
(X)
99.906
99.897
99.834
99.835

99.815
99.929
99. 989
99.997

Outlet
(D <50)
(X)
2.25
3.40
3.98
10.94

42.06
73.62
92.27
98.06
Average test
Average of
4 Inlets
(D <50)
(X)
0.16
0.24
0.31
0.90
1.14
2.16
5.75
11.00
21.97
n
Removal8
efficiency
(X)
99.899
99.901
99.935
99.918

99.887
99.958
99.993
99.999

Outlet
(0 <50)
(X)
0.56
1.47
2.49
14.92

47.11
76.52
93.53
98.52
Average test
Average of
4 Inlets
CD <50)
(X)
0.20
0.28
0.35
0.94
1.26
2.59
5.29
9.76
20.45
2
Removal8
efficiency
(X)
99.925
99.874
99.671
99.767

99.743
99.898
99.98G
99.997

Outlet
(D <50)
(X)
0.81
1.58
2.49
11.51

41.90
72.76
90.15
96.42
Average test
Average of
4 Inlets
(0 <50)

0.15
0,27
0.99
1.31
2.99
6.92
12.96
24.07
13
Removal8
efficiency
(X)
99.904
99.907
99.7R9
99.774

90.753
99.902
99.901
99.994
                  by the PADRE program and based on Mercer's definition of aerodynamic impact ton.

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                              Table 2-5.   ANDERSEN WEIGHTS  PER STAGE AND CUMULATIVE PERCENT MASS

                                                 LESS THAN D50 AT STANDARD DIAMETERS
 ro
 i
-en
Weights per
Test #
PAOKE 0
Weight gains
(nig)'
Pre-cutter
Stage 1
Stage 2
Stage 3
Stage 4
Stage 5
Stage 6
Stage 7
Stage 8
Filter
Outlet
1
3
9.51
4.25
3.46
8.93
6.30
4.72
2.05
0.43
O.bO
0.49
Inlet
1-A
4
130.62
7.42
2.49
3.37
2.21
.99
1.53
0.40
0.41
0.41
Inlet
1-D
5
557.90
13.21
3.63
3.28
2.35
2.66
1.51
.21
.22
.15
Inlet
1-C
6
208. 37
7.91
0.55
1.88
1.52
1.78
0.96
0.01
0.03
0.16
Inlet
1-0
7
279.12
8.95
1.95
4.14
2.16
3.39
1.48
0.30
0.12
0.32
Outlet
2
2
14.51
6.03
5.69
13.52
9.43
11.29
5.56
0.66
0.09
0.30
Cumulative percent
Test I
PADRE *
Standard
diameters
(microns)
.63
1.00
1.25
2.50
3.00
6.00
10.00
15.00
20.00
Outlet
1
3
2.25
3.40
3.98
10.94
N/A
42.06
73.62
92.27
98.06
Inlet
1-A
4

.64
.81
1.83
2.04
3.36
8.44
16.12
27.03
Inlet
1-B
5

0.07
0.10
0.37
0.50
1.05
3.44
7.13
17.87
Inlet
1-C
6

0.09
0.10
0.58
O.B1
1.85
5.21
10.10
21.35
Inlet
1-0
7

0.18
0.25
0.82
1.19
2.39
5.93
10.67
21.64
Outlet
2
2
0.56
1.47
2.49
14.92
N/A
47.11
76.52
93.53
98.52
Inlet
2-A
8
200.96
10.19
2.06
3.28
2.46
3.73
1.87
0.67
0.20
0.35
mass
Inlet
2-A
8

0.40
0.56
1.53
2.07
3.92
7.42
14.20
25.02
Inlet
2-B
9
327.66
4.82
2.51
2.51
1.81
1.73
1.20
0.00
0.30
0.37
less than
Inlet
2-B
9

0.20
0.21
0.58
0.71
1.48
3.50
6.97
17.73
stage
Inlet
2-C
10
289.28
5.64
2.36
3.09
2.63
2.06
1.02
0.19
0.00
0.22

Inlet
2-0
11
332.64
6.58
1.87
S.40
3.30
4.92
2.03
0.43
0.07
1.26

Outlet
3
1
25.55
6.06
7.80
15.89
11.55
10.63
5.40
0.70
0.00
0.68

Inlet
3- A
12
19B.77
17.49
4.15
5.25
3.55
2.83
2.15
0.77
0.23
0.24

Inlet
3-B
13
232.57
0.93
0.79
1.06
0.97
1.93
1.39
0.21
0.00
o.oo

Inlet
3-C
14
244.72
10.64
8.52
4.55
4.12
3.65
1.75
0.42
0.07
0.00

Inlet
3-D
15
263.76
4.95
2.22
4.02
3.18
3.38
1.53
0.42
0.01
0.03
D50 at standard diameters3
Inlet
2-C
10

0.09
0.13
0.47
0.62
1.74
4.24
7.59
17.87
Inlet
2-D
11

0.42
0.49
1.18
1.62
3.21
6.00
10.28
21.19
Outlet
3
1
0.81
1.58
2.49
11.51
N/A
41.90
72.76
90.15
96.42
Inlet
3-A
12

0.39
0.59
1.53
1.84
4.00
11.46
20.63
32.15
Inlet
3-8
13

0.03
0.12
0.78
1.05
1.85
2.70
5.94
17.07
Inlet
3-C
14

0.08
0.18
0.85
1.17
3.18
7.74
15.05
25.77
Inlet
3-0
15

0.09
0.17
0.8?
1.17
2.93
5.79
10. 23
21. 21?
             al mm PADRE program and based on Mercer's definition of aerodynamic Impactlon.

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IS)
                                   Table 2-6.   SASS  COMPARED TO ANDERSEN FOR CUMULATIVE MASS
                                                 AS PERCENT  LESS THAN STATED SIZE3
SASS
as compared to
hy percent
weight less than
standard size
1.0 micron
3.0 micron
10.0 micron
Greater than
10 microns
Average for
SASS
Inlet
(X)
0.20
2.49
12.51

87.49
Andersen
Inlet
(X)
0.22
1.25
5.99

94.01
test terlti

SASS/Andersen
(X)
90.9
199.2
208.8

93.1
Average for test #1
SASS
Inlet
(X)
0.18
2.15
14.01

85.99
Andersen
Inlet
(X)
0.24
1.19
5.75

94.25

SASS/Andersen
(X)
75.0
180.7
243.6

91.2
Average for test #2
SASS
Inlet
(X)
0.22
2.35
12.07

87.93
Andersen
Inlet
(X)
0.28
1.26
5.29

94.71

SASS/Andersen
(X)
78.6
186.5
228.2

92.8
Average for test #3
SASS
Inlet
(X)
0.21
2.96
11.45

88.55
Andersen
Inlet
(X)
0.15
1.31
6.92

93.08

SASS/Andersen
(%)
140.0
225.9
165.5

95.1
           Anderson values based on Mercer's definition of aerodynamic Inpactlon.

-------
                             Table 2-7.  SUMMARY OF TEST PARAMETERS FOR TEST #1:  9/20/83
-co
Sample Train
Run *
Sample location
Start time (HST)
Sampling point
Sampling time (mln)
Meter volume (OSCF)
Nozzle flow (ACFH)
SASS cyclone flow (ACFH)
Stack flow (ACFH)
Stack flow (OSC1H)
Stack temperature (F)
% Isoklnetlc
X opacity
X moisture
% CO,8
*v n 0
V U Q
Concentration (gr/DSCF)
Total parttculate
emissions (Ib/hr)
Method 5
#1 Inlet
Inlet
1330-1702
Trav.
60
28. 974
	
	
15701
8620
176
103.6
1.09
22.5
3.39
18.3
78.31
110.849
8192
SASSd
#1 Inlet
Inlet
1830-1855
Trav.
20
73.246
6.15
8.56
15912
9001
158
120.4
NA
22.5
3.39
18.3
78.31
59.647
4604
Andersen*
1-A
Inlet
1250
B-2
0.083
0.030
0.482
	
12841
7074
177
120.2
1.5
22.5
3.39
18.3
78.31
77.29
4688
Andersen
1-B
Inlet
1400
B-5
0.083
0.033
0.506
	
14354
7917
177
112.8
1.0
22.5
3.39
18.3
78.31
271.60
18438
Andersen*
1-C
Inlet
1500
A- 2
0.083
0.024
0.535
	
14385
7907
180
119.2
NA
22.5
3.39
18.3
78.31
142.09
9633
Andersen
1-0
Inlet
1637
A-5
0.083
0.036
0.526
	
13890
7585
177
121.4
1.9
22.5
3.39
18.3
78.31
127.40
8286
Andersen
Inlet
average
Inlet
NA
NA
NA
NA
NA
	
13868
7621
NA
NA
22.5
3.39
18.3
78.31
	
10261
Method 5
11 Outlet
Outlet
1252-1633
Trav.
108
69.415
	
	
23395
15094
148
102.6
1.09
13.2
1.68
19.8
78.52
0.0134
1.74
Andersen
#1 Outlet
Outlet
1842-2044
Trav.
120
55.290
0.703
	
24746
15984
148
97.4
NA
13.2
1.68
19.8
78.52
0.0114
1.56
                                                        (continued)

-------
                                                                         Table 2-7.   Concluded
UJ

Sample Train

Run f
Emissions above
10 Microns (ll)/hr)
X above 10 microns
Emissions below
10 Microns (Ib/hr)
X less than 10 microns
Emissions below
3 Microns (Ib/hr)
X less than 3 microns
Emissions below
1 Micron (Ib/hr)
X less than 1 micron
Method 5

#1 Inlet

7662a
94.25a

471.0s
5.75"

93.38a
1.14a

19.66a
.24a
SASSd

#1 Inlet

3959
85.99

645
14.01

99.03
2.15

8.20
0.18
Andersen*

1-A

4292
91.56

395.7
8.44

95.64
2.04

30.00
0.64
Andersen6

1-0

17804
96.56

634.3
3.44

92.19
0.50

12.91
0.07
Andentn*

1-C

9131
94.79

501.9
5.21

78.03
0.81

8.67
0.09
Andersen6

1-D

7795
94.07

491.4
5.93

98.60
1.19

14.91
0.18
Andersen
Inlet b
average

9755
94.24

505.8
5.75

91.11
1.14

16.62
0.24
Method S

#1 Outlet

0.46C
26.38C

1.28C
73.62C

	
	

0.06C
3.40C
Andersen

11 Outlet

0.41
26.38

1.15
73.62

	
	

0.04
3.40
                       Based on PADRE/ANDERSEN values for the four Andersen Inlet samples.
                       Average for the four Andersen Inlet samples.
                      cDased on PADRE/ANDERSEN value for the Andersen outlet sample.
                       The  SASS Train was run after the Method 5 run using the Method 5 pttote readings, moisture and gas composition.
                       The  SASS Train sample was taken for five Minutes at each of the four points  from which the Andersen samples  were  taken.
                      6The  mass emission rate Is calculated as a Method 5 test while the flow through  the  Impactor is based on the  meter box orifice value.
                       The  mass emission rate Is calculated as a Method 5 test as are the other values which were Imputed to the PADRE program.
                      gBag  sample was taken during the Method 5 test.
                       Suspiciously large precutter catch.
                       Moisture  from Method 5 test.

-------
                              Table 2-8.   SUMMARY OF TEST PARAMETERS FOR TEST #2:   9/21/83
 I
M
O

Sample Train
Run 1
Sample location
Start time (HST)
Sampling point
Sampling time (mfn)
Meter volume (OSCF)
Nozzle flow (ACFH)
SASS cyclone flow (ACFH)
Stack flow (ACFH)
Stack flow (OSCFH)
Stack temperature (F)
X (sok)netlc
X opacity
X moisture
xcofl
X 02
X N29
Concentration (gr/DSCF)
Total particulate
emissions (Ib/hr)
Method 5
#2 Inlet
Inlet
1558-1910
Trav.
60
25.653
	
	
14287
7775
171
101.7
3.09
23.9
2.76
18.33
78.91
117.316
7821
SASSd
12 Inlet
Inlet
2100-2129
Trav.
20
57.298
4.96
6.70
15131
8265
172
73.4
NA
23.9
2.76
18.33
78.91
106.279
7531
Andersen8
2-A
Inlet
1545
A-2
0.167
0.032
0.526
	
14235
7880
160
118.3
5.0
23.9
2.76
18.33
78.91
108.47
7329
Andersen6
2-B
Inlet
1625
A- 5
0.167
0.051
0.520
	
13765
7604
161
121.0
2.7
23.9
2.76
18.33
78.91
103.01
6716
Anderten*
2-C
Inlet
1706
B-2
0.167
0.046
0.485
	
12845
6987
171
120.7
5.0
23.9
2.76
18.33
78.91
103.30
6188
Andersen6
2-0
Inlet
1845
8-5
0.167
0.063
0.533
	
13939
7514
177
122.4
1.0
23.9
2.76
18.33
78.91
87.98
5668
Andersen
Inlet
Average
Inlet
NA
NA
NA
NA
NA
	
13696
7496
NA
NA
NA
23.9
2.76
18.33
78.91
	
6475
Method 5
HZ Outlet
Outlet
1545-1915
Trav.
180
123. 784
	
	
24860
15794
153
104.5
3.09
13.8
1.33
19.85
78.82
0.0198
2.68
Andersen
#2 Outlet
Outlet
1545-1915
Trav.
180
83.004
0.717
	
25690
16279
156
95.3
3.09
13.8
1.33
19.85
78.82
0.0124
1.74
                                                       (continued)

-------
                                                                            Table 2-8.   Concluded
ro
 i
Sample Train
Run f
Emissions above
10 1crons (Ib/hr)
X griater than 10 microns
Emissions below
10 microns (Ib/hr)
% less than 10 microns
Emissions below
3 microns (Ib/hr)
X less than 3 microns
Emissions below
1 microns < Ib/hr)
X less than 1 micron
Method 5
12 Inlet
7407a
94.71a
413.73*
5.29*
98.54*
1.26a
21.90a
0.28a
SASSd
12 Inlet
6622
87.93
909.30
12.07
177.12
2.35
17.29
0.22
Andersen*
2-A
6785
92.58
543.81
7.42
151.71
2.07
29.32
0.40
Andersen*
2-B
6481
96.50
235.06
3.50
47.68
0.71
13.43
0.20
Andersen'
2-C
5925
95.76
262.37
4.24
38.36
0.62
5.57
0.09
Andersen6
2-0
5328
94.0
340.08
6.00
91.82
1.62
23.80
0.42
Andersen
Inlet .
Average
6130
94.71
345.3
5.29
82.42
1.26
18.03
0.26
Hethod 5
2 Outlet
0.63C
23.48C
2.05
76.52C
NA
NA
0.04C
1.47
Andersen
12 Outlet
0.41
23.48
1.33
76.52
NA
NA
0.03
1.47
                        *Based on PADRE/ANDERSEN values for the four Andersen Inlet  samples.
                         Average far the four Andersen Inlet samples.
                        C8ased on PADRE/ANDERSEN value for the Andersen outlet sample.
                         The SASS Train was  run after the Hethod 5 run using the  Method 5 pitote readings, mostture  and gas composition.
                         The SASS Train sample was taken for five minutes at each of the four points from which the  Andersen samples were taken.
                        'The mass emission rate is calculated as a Method 5 test  while the flow through the Impactor 1s based on the meter box orifice value.
                         The mass emission rate Is calculated as a Method 5 test  as  are the other values which were  Imputed to the PAORE program.
                        "Bag sample was taken during the Method 5 test.
                         Suspiciously large  pre-cutter catch.
                        'Moisture from Method 5 test.

-------
                                Table 2-9.  SUMMARY OF TEST PARAMETERS  FOR TEST #3:   9/22/83
ro

i-*
ro
Sample Train
Run *
Sample location
Start time (HST)
Sampling point
Sampling time (m1n)
Meter volume (DSCF)
Nozzle flow (ACFM)
SASS cyclone flow (ACFH)
Stack flow (ACFH)
Stack flow (OSCFM)
Stack temperature (F)
X ttoklnetlc
% opacity
X moisture
x co"
XO,"
XNa8
Concentration (gr/OSCF)
Total partlculate
emissions (Ib/lir)
Method S
13 Inlet
Inlet
1037-1343
Trav.
60
25.296
	
	
14397
7542
168
103.4
2.54
27.1
3.12
17.99
78.89
111.079
7183
SASSd
#3 Inlet
Inlet
1704-1730
Trav.
20
56.664
5.08
6.87
14769
7618
176
78.7
NA
27.1
3.12
17.99
78.89
112.767
7366
Andersen*
3-A
Inlet
1030
A- 2
0.167
0.056
0.538
	
14310
7647
161
120.5
3.1
27.1
3.12
17.99
78.89
65.45
4292
Andersen8
3-B
Inlet
1058
A-5
0.167
0.056
0.536
	
13894
7322
166
123.5
3.1
27.1
3.12
17.99
78.89
66.15
4153
Andersen*
3-C
Inlet
1200
B-2
0.167
0.051
0.500
	
12983
6700
177
123.4
5.2
27.1
3.12
17.99
78.89
83.94
4822
Anderien*
3-0
Inlet
1314
8-5
0.167
0.040
0.542
	
13980
7Z55
173
124.0
0.0
27.1
3.12
17.99
78.89
117.46
7306
Andersen
Inlet .
Average
Inlet
NA
NA
NA
MA
NA
	
13792
7231
NA
NA
NA
27.1
3.12
17.99
78.89
	
5143
Method S
*3 Outlet
Outlet
1030-1355
Trav.
180
118.694
	
	
24254
15184
154
104.6
2.54
14.9
1.50
20.07
78.43
0.0280
3.65
Andersen
#3 Outlet
Outlet
1031-1345
Trav.
180
84.707
0.736
	
25063
15732
156
101.0
2.54
14.9
1.50
20.07
78.43
0.0153
2.07
                                                        (continued)

-------
                                                                             Table  2-9.    Concluded
ro
 t
CO

Sample Train
Run #
Emissions above
10 microns (Ib/hr)
X greater than 10 microns
Emissions below
10 microns (Ib/hr)
X less than 10 microns
Emissions below
3 microns (Ib/hr)
X less than 3 microns
Emissions below
1 microns (Ib/hr)
X less than 1 micron
Method 5
#3 Inlet
6685s
93.088
497.06*
6.92a
94.10*
1.31a
10.77*
0.15a
SASSd
#3 Inlet
6522
88.55
843.64
11.45
217.89 .
2.96
15.82
0.21
Andersen*
3-A
3800
88.54
491.86
11.46
78.97
1.84
16.74
0.39
Andersen*
3-B
4041
97.30
112.13
2.70
43.61
1.05
1.24
0.03
Andersen*
3-C
4449
92.26
373.22
7.74
56.42
1.17
3.86
0.08
Andersen*
3-D
6883
94.21
423.02
5.79
85.48
1.17
6.58
0.09
Andersen
Inlet .
Average
4793
93.08
350.06
6.92
66.12
1.31
7.10
0.15
Method 5
3 Outlet
0.99C
27.24C
2.66C
72.76C
NA
NA
0.06
1.58C
Andersen
#3 Outlet
0.56
27.24
1.51
72.76
NA
NA
0.03
1.58
                      *0ased on PADRE/ANDERSEN values for the four Andersen Inlet  samples.
                       Average for the four Andersen Inlet samples.
                      C0ased on PADRE/ANDERSEN value for the Andersen outlet sample.
                      dThe SASS Train was  run after the Method 5 run using the Method 5 pltote readings, moisture and gas composition.
                       The SASS Train sample was taken for five minutes at each of the four points from which the Andersen samples were taken.
                      *The mass emission rate 1s calculated as a Method 5 test while the  flow through the Impactor 1s based on the meter box orifice  value.
                      flhe mass emission rate Is calculated as a Method 5 test as  are the other values which were Imputed to the PAORE program.
                      "Bag sample was taken during the Method 5 test.
                       Suspiciously large  precutter catch.
                      1Moisture taken from the Method 5 test.

-------
2.2  DISCUSSION OF RESULTS
     The data presented in Table 2-1 indicate that the mass rates  and
concentrations were relatively consistent at the inlet location with the
concentration averaging 113.081 gr/dscf with a range of 110.849 gr/dscf
to 117.316 gr/dscf.  The inlet mass rate averaged 7732 Ibs/hr with a
range of 7183 Ibs/hr to 8192 Ibs/hr.  The inlet mass rate for participate
matter less than 10 microns in size averaged 461 Ibs/hr with a range of
414 Ibs/hr to 497 Ibs/hr.
     The outlet location was more variable with a concentration averaging
0.0204 gr/dscf with a range of 0.0134 gr/dscf to 0.0280 gr/dscf.  The
mass emission rate averaged 2.69 Ibs/hr with a range of 1.74 Ibs/hr to
3.65 Ibs/hr.   The mass emission rate for participate matter less than
10 microns in size averaged 2.00 Ibs/hr with a range of 1.28 Ibs/hr to
2.66 Ibs/hr.   The variability of the participate matter at the outlet
may have been caused by differences in the baghouse operation or
differences in the unfiltered room air used to heat the bags.  The
(cyclone/baghouse) mass removal efficiencies were relatively consistent
for each run, yielding averages of 99.96% total mass removal and 99.56%
at 10 micron and less.
     Tables 2-7, 2-8, and 2-9 show the flue gas flow rates to be fairly
consistent between the tests for each location based on the Method 5
pitot tube traverses.  The inlet location averaged 14795 acfm with a
range of 14287 acfm to 15701 acfm, or in alternate units, an average of
7979 dscfm with a range of 7542 dscfm to 8620 dscfm.  The outlet location
averaged 24170 acfm with a range of 23395 acfm to 24860 acfm, or on a
dry basis, an average of 15998 dscfm with a range of 15732 dscfm to
16279 dscfm.
     The exhaust stack opacity during test #1 was considerably lower
than during tests #2 and #3.  During the first test, the visible emissions
observer was required to assist elsewhere for a period of time.  It is
not expected that these periods affected the overall visible emissions
results.   The average for the three runs were 2.24 percent.  No visible
emissions were observed being emitted from the feed belt discharge.
     Table 2-3 shows inlet Andersen values for the inlet tests, which
because of the heavy grain loading, were run for only 5 or 10 seconds.
The brief sampling period was a result of the low sample loading design
                                 2-14

-------
of this impactor.  A maximum of 10 milligrams per any one stage is best
for valid sizing results.   It is difficult to evaluate the representability
of results covering such a short period, but results indicate that the
values, when averaged, are reasonably consistent for the four runs which
are consolidated as one test.
     The particulate mass rate determinations at the inlet location for
the SASS and the Method 5 test runs 2 and 3 are fairly comparable.  At
less than 1 micron and greater than 10 microns, the SASS and Andersen
values are also reasonably comparable.  It is possible that the Andersen
data are biased towards indicating more particles in the larger size
ranges because of the low impactor start-up flow rates and such a short
run period.  Mass emissions for SASS during test #1 were low (although
the cut off points were satisfactory).  The reason for this is not fully
understood, but appears to be a function of the operation of the SASS
train.
     The isokinetic ranges reported in Table 2-3 reveal Andersen runs to
range between 95.3 to 122.8 percent and the range for Method 5 tests to
be between 101.7 and 104.6 percent of isokinetic.  These isokinetic
sampling rates are within the allowed limits, meaning that there are no
major experimental measurement errors attributable to non-representative
sampling in this respect.
2.3  PARTICULATE DATA REDUCTION SYSTEM (PADRE)
     The PADRE program, which was used to calculate the Andersen impactor
results, is described in "Particulate Data Reduction System (PADRE)
Terminal Users Guide" by W. M. Yeager and C. E. Tatsch of the Research
Triangle Institute for the Industrial Environmental Protection Agency (EPA).
The abstract and introduction of this manual are duplicated below.
2.3.1  Abstract
     The Particulate Data Reduction (PADRE) system is an interactive
computer program which facilitates the entry, reduction, and analysis of
cascade impactor data for particle size distributions.  PADRE was developed
to assure the quality of data included in the Fine Particle Emissions
Information System (FPEIS), which is a component of the Environmental
Assessment Data System (EADS).  PADRE users control the logical flow
through the system in response to prompts from the program.  Data may be
entered, stored, reviewed, edited, and analyzed.  A variety of data

                                 2-15

-------
checks is employed by PADRE to warn users about invalid or suspect data.
Cut points of the impactor stages are calculated.   Cumulative and
differential mass concentrations are determined and interpolated to
standard diameters.   This document describes how to access and use
PADRE.  It includes a summary of the logic and capabilities of the
system.   It is intended as a reference for users who are at a computer
terminal.
2.3.2  Introduction
     The purpose of the Particulate Data Reduction (PADRE) system  is to
facilitate entry of qualified, field-observable cascade impactor data
for particle-size distributions into the Fine Particle Emissions
Information System (FPEIS).  This data base is a major component of the
Environmental Assessment Data Systems (EADS) and is described in the
FPEIS User Guide.  Reduction of the data to determine the cut diameters
for each impactor stage, as well as the mass and number distributions at
standard diameters, may be performed to facilitate rapid evaluation of
these data.  This reduction is based on the Cascade Impactor Data  Reduction
System (CIDRS) computer programs developed by Southern Research Institute
under contract to EPA.
     The data organization and terminology are consistent with EADS/FPEIS,
insofar as possible.   Thus, several impactor runs (samples) are logically
connected to one test,  with specification of the stream and operating
levels embedded within the run data records.  In particular, all runs
for a given test share a common site and particle density and begin on
or after the date of the test of which they are a part.  PADRE uses the
site and date to access all stored data as a means of minimizing user
effort while providing multikey security for users' data.  Three types
of data may be entered by PADRE users:
         Weight data:    Substrates description; number of weights,
                         pre-weights, and post-weights.
         Test data:      Site, starting date, particle density, and test
                         comments.
         Run data:      Comments, impactor identification and operating
                         parameter, and pointer to the corresponding
                         weight data.
In order to facilitate data entry and correction, data are entered and
stored in the units in which they are commonly observed.
                                 2-16

-------
          3.  PROCESS DESCRIPTION AND CONDITION DURING TESTING

3.1  PROCESS DESCRIPTION
     The process unit tested is a rotary dryer processing 24 Mg (27 tons)
of high-swelling Wyoming bentonite clay per hour.  This plant operates
continuously, except for breakdowns, 24 hours per day and 6 or 7 days
per week.  Figures 3-1 and 3-2 present a simplified process schematic.
Bentonite is received by trucks and stockpiled in the open.  From the
stockpile, the bentonite is loaded into a hopper from which it is conveyed
to a slicer.  The slicer produces fines to 2.5-cm (1-in.) chunks of
bentonite which are fed to a direct-fired rotary dryer.  The dried
bentonite is elevated to a Raymond mill, pulverized, and air-classified
before being conveyed to finished product bins.  Product is shipped out
in bulk by either rail or truck or is bagged (50- to 100-1b bags) for
shipment.
     The rotary dryer was manufactured by Stearn-Rogers.  It is 20 m
(65 ft) long and is 2.4 m (8 ft) in diameter.  Bentonite is fed to the
dryer by a conveyor belt.  The dryer has a heat input rate of about
10 million Btu per hour (2.9 x 108 Joules per second).  The dryer can be
fired with either coal or natural gas.  Usually, the dryer is fired with
low sulfur (about 0.6 percent) coal.  The exhaust gas temperature prior
to the cyclone, as indicated by the control panel monitor, is 66 to 82C
(150 to 180F).  The dryer is insulated to reduce heat loss.  The dryer
has a retention time of 20 minutes and dries the bentonite from 15 to
18 percent moisture down to 6 to 8 percent.  Table 3-1 presents the
design and operating parameters for the dryer.
     Particulate emissions from the dryer exhaust are controlled by a
baghouse.  Data for the baghouse are shown in Table 3-2.  The baghouse
was manufactured by W. W. Sly Manufacturing Company (Model No. JM 2698).
It has only one compartment and is equipped with polyester bags which
have a total cloth area of 1,277 m2 (13,750 ft2).  The design air-to-cloth

-------
VISIBLE
EMISSIONS
AND FEED
SAMPLE
01
         cLi
                                               TOP VIEW
             Rotary Dryer   
             PRODUCT  SAMPLE
                            Inlet Test
                            Location
                                                                             Outlet Test
                                                                             Location
                                                          17"    Baghouse
                                                                                 Fan and
                                                                                 Exhaust
                                                                                 Stack
                               Product
                               Storage
            Figure 3-1.  Process schematic -  Black Hills Benonite Co., Mills,  Wyoming.

-------
                                         SIDE  VIEW
             Roof
    PRODUCT SAMPLE
             Inlet Test
             Location
    Rotary Dryer
 VISIBLE
 EMISSIONS
'AND FEED
 SAMPLE
                                            t
                                        Cyclone
Roof
                                                                   Baghouse
                                Outlet Test
                                Location
                                                                                       Fan
        Figure 3-2.   Process  schematic  -  Black  Hills  Bentonite Co., Mills, Wyoming.

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            Table 3-1.   DATA FOR ROTARY DRYER AT BLACK HILLS
                BENTONITE COMPANY PLANT AT MILLS, WYOMING
                                                          Rotary dryer

Manufacturer                                             Stearn-Rogers
Date of installation                                          1964
Design of production rate, tph                                31.0
Actual production rate, tph                                   27.0
Hours of operation
  hours/day                                                    24
  days/week                                                   6-7
Retention time, min.                                           20
Maximum drying temperature (gas), F                          1800
Fuel used                                              Coal;  natural gas
                                                          (alternate)
Feed moisture content, %                                     15-18
Feed particle size, in.                                       ^1.5
Feed density, lb/ft3                                           60
Product moisture content, %                                   6-8
Product density, lb/ft3                                        60
                                 3-4

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   Table 3-2.  DATA FOR BAGHOUSE CONTROL EQUIPMENT FOR ROTARY DRYER AT
          BLACK HILLS BENTONITE COMPANY PLANT AT MILLS, WYOMING
Manufacturer
Model no.
Design gas flow rate, acfm
Bag material
Bag life, months
Total cloth area, ft2
Design air/cloth ratio, ft./min.
Cleaning mechanism
Frequency of cleaning, per hour
Pressure drop, in. w.c.
No. of compartments
W.W. Sly Mfg. Co.
     JM 2698
      20,000
    Polyester
       x.12
      13,750
      1.45:1
   Reverse air
        40
     Unknown
        1
                                 3-5

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ratio is 0.0074:1 m/s (1.45:1 ft/min).   The temperature of the  inlet gas
is 66 to 82C (150 to 180F).   The collected material from the baghouse
is returned to the process.   The baghouse is equipped with a natural-gas-
fired heater to prevent condensation.   Plant air is drawn into  the
heater and is used as reverse cleaning air for the baghouse.  The heated
air is exhausted through the baghouse stack.
3.2  PROCESS CONDITIONS DURING TESTING
     All processes were operated normally during the emission testing.
The dryer operation is monitored from a control panel that contains
gauges for both the fire box temperature and the stack temperature and a
television monitor of the feed conveyor belt.   All process units in the
plant operate at a constant fixed rate of 24 Mg (27 tons) per hour (dry
product rate).  The design capacity of the dryer is 27 Mg (30 tons) per
hour.  Based on the inlet and outlet moisture contents of the clay and
the dryer product rate of 24 Mg (27 tons) per hour, the dryer had a wet
feed rate of 26.6, 26.8, and 27,3 Mg (29.3, 29.6, and 30.1 tons) per
hour during the tests.  Because the operational speed of the dryer feed
system (slicer and conveyor) is fixed, the feed and production  rates are
constant.  The dryer rotational speed is also fixed; therefore, retention
time is constant at approximately 20 minutes.   The rheostat for the coal
feed system is set manually to keep the dryer fire box temperature
between 820 and 980C (1500 and 1800F).  Once the rheostat is set,
the coal feed rate is constant.  Tables 3-3, 3-4, and 3-5 present the
fire box and stack temperatures monitored during the test and show that
the feed system was operating normally throughout testing.  No  feed or
product weight scales for the dryer exist at the facility.  However, all
process units operate at a constant fixed rate.  Therefore, monitoring
of fire box and stack temperatures and the operation of the feed system
was sufficient to document normal operation.
     During the testing, the dryer was fired on coal at an average rate
of 18.5 kg/Mg (37 Ibs/ton).   The coal used during the test, as  specified
by the supplier, has a heating value of 26.7 Mj/kg (11,600 Btu/lb), a
sulfur content of 0.62 percent, and a moisture and ash content of 10.5 and
5.6 percent, respectively.
     Some fluctuation in the dryer fire box temperature was observed
throughout testing of the dryer.  The fluctuations are normal and are
                                 3-6

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   Table 3-3.   OPERATING CONDITIONS - RUN NO.  1 -  9/20/83

Time
12:50
1:00
1:10
1:20
1:30
1:40
1:50
2:00
2:10
2:20
2:30
2:40
2:50
3:00
3:10
3:20
3:30
3:40
3:50
4:00
4:10
4:20
4:30
4:40
4:50
5:00
Firebox
temperature
1450
1500
1550
1575
1600
1650
1625
1625
1625
1650
1675
1650
1675
1700
1650
1650
1625
1650
1625
1650
1650
1650
1650
1625
1650
1650
Stack
temperature
160
160
170
170
180
175
175
170
170
175
180
175
175
180
175
170
170
185
_a
_a
185
180
180
_a
-a
_a
Feed
system
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Stack temperature gauge required reset.
                           3-7

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    Table 3-4.   OPERATING CONDITIONS -  RUN NO.  2 -  9/21/83

Time
3:40
3:50
4:00
4:10
4:20
4:30
4:40
4:50
5:00
5:10
5:20
5:30
5:40
5:50
6:00
6:10
6:20
6:30
6:40
6:50
7:00
7:10
7:20
Firebox
temperature
1550
1450
1375
1400
1475
1500
_b
1550
1575
1625
1600
1600
1625
1650
1625
1650
1675
1650
1625
1650
1675
1650
1650
Stack
temperature
175
185
175
165
_a
160
_b
175
170
175
180
_a
_a
170
165
170
180
180
180
180
180
175
Feed
system
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
3Stack temperature gauge required reset.
5No reading taken.
                            3-8

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    Table  3-5.   OPERATING CONDITIONS  -  RUN  NO.  3  -  9/22/83

Time
10:30
10:40
10:50
11:00
11:10
11:20
11:30
11:40
11:50
12:00
12:10
12:20
12:30
12:40
12:50
1:00
1:10
1:20
1:30
1:40
Firebox
temperature
1775
1700
1675
_b
_b
_b
1700
1700
1700
1725
1750
1750
1750
1725
1725
1725
1725
1725
1725
1725
Stack
temperature
_a
170
170
_b
180
180
180
180
180
180
180
180
180
180
185
180
180
180
Feed
system
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
aStack temperature gauge required reset.
 No reading taken.
                            3-9

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caused by variations in the coal and feed moisture content and amount of
fines in the coal.  Manual changes in the coal  feed rate were made
whenever the fire box temperature dropped below 820C (1500F).   Because
of the heat retained in the fire box brick, the stack gas temperature
showed no significant corresponding temperature variation.   Throughout
the test, the stack gas temperature, as indicated by the control  panel
gauge, was between 71 and 85C (160 and 185F).  Because of this
limited stack gas temperature variation, stack gas flow rates would be
expected to vary by no more than four percent during the test.  Any
impacts resulting from these variations can be assessed after the test
results are analyzed.
     The plant processes four grades (based on gelling qualities) of
bentonite from 10 different pits.  These clays are blended before drying.
The blend is almost always constant except when a customer requests a
specific high gel product.  Any variations in dust loadings or particle
size distributions among the four clays are unknown.  Plant personnel
indicated that there were no noticeable variations in dust levels or
controllability of dust among the four grades.   The normal blend was
processed during the emission tests.
     The test crew noted that standard condition gas volumes were higher
at the exhaust stack outlet than at the cyclone inlet during the test.
This increase in volume is due to the additional air added to the baghouse
by the baghouse heating system.  Plant personnel were unable to provide
the gas flow rate for the heater; however, gas flow rates from the inlet
and outlet tests should provide enough data to accurately estimate the
incremental volume increase from the heater.  It should be noted that
this air bypasses the filtering sytera and enters the exhaust stack.  As
a result, process fugitive dust emissions inside the plant could have
some impact on outlet particulate levels.  Any impacts are expected to
be insignificant except during extremely dusty periods resulting from
process upsets in the plant.
                                 3-10

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                         4.   SAMPLING LOCATIONS

     The outlet sampling location is depicted in Figure 4-1.   The  sample
ports were located eleven feet downstream of the blower and four feet
below the top of the stack extension.   The stack extension was a
29.25 x 32.75 inch rectangle, eight feet long, fitted over the stub
stack which only slightly protruded from the roof.   Thirty-six points on
a six-by-six matrix were sampled for each Method 5  test.   The Andersen
sample was taken from four (4) points located at eight and twenty-four inches
into the second and fifth port.
     The inlet location is shown in Figure 4-2.  The circular duct had
an inside diameter of 34 inches with the ports located 165 inches  after
a 90 degree bend and 65 inches before a 90 degree bend.  The SASS  and
Andersen samples were taken at the second and fifth point on each  traverse.
The Method 5 train was traversed over 12 points, six on each traverse,
for each test.
     The bentonite feed belt discharge point, where visible emissions
were taken using Methods 22/9, is shown in Figure 4-3.

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                        BAGHOUSE EXHAUST
                          LOCATION C
               29.25-
            STWXEXTEimON
               rosrs
           o o o o  o o
            A  B  C  0 E F
                            18"
                             ROOF
       11'
               KOO
                                                        29.25'
                                              32.75'
                                                      
                                                             t!
                                                P01HTI
                                      * B C 0 E f
                                       METHOD 5 POINTS

                                      D15TMCE 1H IHCHE5
                                            T7
                                            8.2
                                           13.6
                                           19.1
                                           24.6
                                           30.0
                                                 0 WOERSEH POINTS
Figure 4-1.
Outlet sampling site and  traverse points -
Black Hills  Bentonite Co.,  Mills, Wyoming.
                           4-2

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                     CYCLONE  INLET
                      LOCATION A
T
65'
     A

     0
US'
                                          CrOOHE
                                        KTW05 nnrs
                                      n:m
OlSTMg  1HCHES
     ITS
     s.o
    10.0
    24.0
    29.0
    32.5
                                       0 MOQSEN MOTS

                                       oSWSPOWTS
   Figure 4-2.   Inlet  sampling site  and traverse points',-
                 Black  Hills Bentonite Co., Mills, Wyoming.
                             4-3

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                         (D  O Q)   Flourescent Light Fixture
Feed Belt
Q)
                                                                       Observation Area
            Figure 4-3.  Method 22 observation location for the feed belt discharge  point.

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                 5.   SAMPLING AND ANALYTICAL PROCEDURES

5.1  SAMPLING PROCEDURES
5.1.1  Reference Method 5 Sampling Procedures
          Figure 5-1 depicts the Method 5 train which was used for these
tests.   Standard Method 5 procedures were used with the  following
exceptions.
     1.    The inlet was sampled at fewer than the normal  points.   Since
          it was actually a product stream rather than the inlet to the
          actual control device (baghouse) it was felt that
          twelve (12) points would be adequate and allow simultaneous
          sampling with the outlet.
     2.    A gas chromatograph, rather than an Orsat, was used to determine
          the carbon dioxide and oxygen composition of the stack gas.
          The volumetric percentage of nitrogen in the stack was determined
          by subtracting the above from 100 percent.
5.1.2  Andersen Sampling Procedures
     Figure 5-2 is a diagram of the Andersen particle sizing train as
used in this test series, including a right angle pre-impactor.  The
testing procedures used were based on the draft manual "Guidelines for
Source Testing for Size Specific Particulate Emissions", Section 5.  The
testing procedure was as follows:
     1.    take a pitot reading at the point to be sampled;
     2.    determine and install the desired nozzle;
     3.    leak-check the sampling train;
     4.    put the impactor at the sampling point with the nozzle facing
          at 180 degrees from the flow;
     5.    wait until the impactor internal temperature is within 5F of
          the stack temperature, or heat the impactor above the stack
          temperature to prevent condensation in the impactor;

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                                                     THERMOCOUPLE
                       PROBE
01
I
ro
                     WOT
                  MANOMETER
                                                               THERMOCOUPLE
                                                                                   THERMOMETER
                                                                  BY-PASS   MAIN
                                                                   VALVE   VALVE  /
                               ORIFICE
                              MANOMETER
                                                   DRV TEST
                                                    METER
                                          Figure 5-1.   Method  5  -  Sampling Train

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Ol

CO
                      Andersen
                     Right Angle
                     Pre-Impactor
                            Andersen
                            Impactor
Thermocouple
                                                                                         uj Thermometer
                                                                                         ^H
SlUca Gel
                                 THERMONntRS

                                 ORIFICE
                         IT-PASS  MAIN
                          YAIVE   VALVE
                            ORIFICE
                           MMOCTER
                                               DRY TEST
                                                METER
                                    TIGHT
                                  PUMP
                            Figure  5-2.  Andersen Sampling  Train WHh Right Angle  Pre-Impactor

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     6.   turn the impactor's nozzle into the flow;
     7.   start sampling at the predetermined isokinetic sampling rate;
     8.   at the end of the predetermined sampling time, turn off the
          sampling train;
     9.   withdraw the impactor unit from the stack (being careful  not
          to jar or shake it);
    10.   draw 0.5 cubic foot, at 0.1 actual cubic foot per minute, of
          clean ambient air through the train;
    11.   take the sampling head off the probe; and
    12.   keep the sampling head upright after removing from sampling
          probe until after sample recovery.
Andersen flow rates and the validity of a run were determined by visual
inspection of the impactor substrates and inputting the test parameters
to the PADRE program.
5.1.3  SASS Sampling Procedures
     Figure 5-3 depicts the SASS train as it was used to determine
particulate mass and size distribution.  The conceptual approach was to
use the SASS cyclones and filter in high grain-loading situations as
approach to using the Andersen impactors with the required very short
run duration.  The SASS was operated at the Andersen sampling points
while using the Method 5 moisture and pitot values for the calculations
of the particulate mass emission rates.  The SASS train was leak-checked
and the probe and oven were heated to 400F.  The SASS was run as
isokinetically as possible (restricted by the limited selection of
nozzle sizes) as opposed to the optimal flow rate through the cyclones
(as required to produce the exact calibrated cut points in each cyclone).
This approach was taken to obtain the most representative measures of
particulate msss rates, although sacrificing some of the accuracy of the
SASS particle size measurements.
5.2  ANALYTICAL PROCEDURES
5.2.1  Method 5 Analytical Procedures
     The analytical procedures used were per the method with one exception.
The acetone washings were heated at 100-120F to facilitate overnight
drying to allow next day weighings, as opposed to the standard method of
allowing the acetone to evaporate at ambient conditions.
                                 5-4

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tn
en
                        STACK T.C,
                                   HEATER
                                    CON-
                                   TROLLER
CONVICTION
OVtN
FILTER
                             DRY GAS METER/ORIFICE METER
                              CENTRALIZED TEMPERATURE
                                AND PRESSURE READOUT
                                   CONTROL MODULE
                                                                       TWO t(Ht3/min VACUUM PUMPS
            Figure 5-3.  SASS - SAMPLING TRAIN  FOR  PARTICIPATE SIZING AND MASS EMISSIONS DETERMINATION

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5.2.2  Andersen Analytical Procedures
     The Reeves Angel filters, Reeves Angel substrates,  and foil  packets
were desiccated overnight.  Each filter or substrate was then preweighed
with its foil packet and placed in a petri dish.   The petri dishes were
placed in the correct order to load the Andersen impactor and taped
together.  After carefully loading the filter and substrates, the impactor
was ready for sampling.  At the completion of sampling,  the impactor was
allowed to cool, taken to a clean recovery area,  disassembled, and the
sample recovered.  The various portions were placed in their assigned
petri dishes and desiccated overnight.  The samples were weighed the
following day.
5.2.3  SASS Analytical Procedures
     The SASS recovery procedure was to dry-brush the nozzle and probe
into the 10-micron cyclone catch.  The 3-micron cyclone catch, 1-micron
cyclone catch, and filter catch were recovered as separate samples.  The
probe and nozzle were acetone-rinsed and the rinse dried overnight on a
(100-120F) hot plate.  The samples were placed in a desiccator and
subsequently weighed.
                                 5-6

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              6.  QUALITY ASSURANCE PROCEDURES AND RESULTS

     The following list of procedures were used to assure the validity
of the test program.
     1.   The pitots were leak-checked.
     2.   A leak check was made after each Method 5 test.
     3.   A leak check was conducted before each Andersen run.
     4.   Dry gas meter calibrations were performed before the test
          series.
     5.   Thermocouples and thermometers were checked to read ambient
          temperature each day.
     6.   Reeves Angel filters and substrates were used to prevent
          weight gain from S02.
     7.   Visual observation of the Andersen filters and substrates was
          performed during sample recovery.
     8.   The balance was checked each day against known weights.
     9.   PADRE results were compared to the other PADRE and Method 5
          results.
    10.   Percent isokinetic was calculated as soon as possible following
          each test.
    11.   An impactor blank was run to check for SQ2-caused weight gain.
    12.   An impactor was sealed and put in the stack for 45 minutes to
          provide a check on handling and recovery procedures.
    13.   Acetone and filter blanks were taken and checked.
    14.   Impactor holes and nozzles were checked for size.
The balance checks as shown in Table 6-1 show the weighing method to be
accurate and repeatable, while Table 6-2 shows the results of the handling
and recovery blank procedure.
     Tables 6-1 and 6-2 show that the weighing methods were reasonably
accurate and repeatable, considering the motel room environment where
the weighings were conducted.

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           Table 6-1.   METTLER H20T BALANCE  CHECKS
                                        Balance weight  shown
  Date         Calibration weight             (grams)
9-19-83              1 gram                    0.99985
9-21-83              1 gram                    0.99978
                     100 mg                    0.09995
                     100 mg                    0.1000
9-22-83              1 gram                    0.99982
                     100 mg                    0.09994
                     1 gram                    1.00018
9-23-83              1 gram                    0.99982
                     100 mg                    0.10000
                           6-2

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   Table 6-2.   PLUGGED INSTACK IMPACTOR BLANK RESULTS
Tare
 Weight gain
after 3 hours
in desiccator
 Weight gain
after overnight
 in desiccator
421.60 mg
639.54
665.70
648.29
557.81
598.32
611.77
624.84 <
652.95
681.63
Total
0.03 mg
0.00
0.07
0.04
0.04
0.16
0.00
0.15
0.01
0.01
+ 0.51
0.08 mg
0.09
0.06
0.03
0.06
0.14
0.04
0.21
0.11
0.02
+ 0.84
                         6-3

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