EPA 340/1-75-001
SEPTEMBER 1975
Stationary Source Enforcement Series
INSPECTION MANUAL FOR ENFORCEMENT OF
NEW SOURCE PERFORMANCE STANDARDS
PORTLAND CEMENT PLANTS
ft
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Enforcement
Office of General Enforcement
Washington, D.C. 20460
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INSPECTION MANUAL FOR THE
ENFORCEMENT OF NEW SOURCE
PERFORMANCE STANDARDS:
PORTLAND CEMENT PLANTS
Prepared by
Norman J. Kulujian
Contract No. 68-02-1355
Task No. 4
EPA Project Officer
Michael J. Merrick
Prepared for
U. S. ENVIRONMENTAL PROTECTION AGENCY
Division of Stationary Source Enforcement
Washington, D. C.
January 1975
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This report was furnished to the U.S. Environmental Pro-
tection Agency by PEDCo-Environmental Specialists, Inc.,
Cincinnati, Ohio, in fulfillment of Contract No. 68-02-1073
The contents of this report are reproduced herein as re-.
ceived from the contractor. The opinions, findings, and
conclusions expressed are those of the author and not nec-
essarily those of the U.S. Environmental Protection Agency.
The Enforcement Technical Guideline series of reports is issued by the
Office of Enforcement, Environmental Protection Agency, to assist the
Regional Offices in activities related to enforcement of implementation
plans, new source emission standards, and hazardous emission standards
to be developed under the Clean Air Act. Copies of Enforcement Technical
Guideline reports are available - as supplies permit - from Air Pollution
Technical Information Center, Environmental Protection Agency, Research
Triangle Park, North Carolina 27711, or may be obtained, for a nominal
cost, from the National Technical Information Service, 5285 Port Royal
Road, Springfield, Virginia 22161.
11
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ACKNOWLEDGMENT
Mr. Norman J. Kulujian was the Project Manager and
principal author of this report. Project Officer for the
Environmental Protection Agency was Mr. Michael J. Merrick.
The author appreciates the many contributions made by
Mr. R. G. Patterson, California Portland Cement Company, Mr.
J. L. Gilliland, Ideal Cement Company, and Mr. R. E. Doherty,
Lehigh Valley Air Pollution Control District. These gentle-
men escorted the author through portland cement facilities,
and provided many helpful suggestions as they reviewed the
report.
Ms. Anne Cassel and Mr. Chuck Fleming were responsible
for the editorial review. Mr. George Fleming prepared the
graphics.
111
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TABLE OF CONTENTS
Page
ACKNOWLEDGMENT iii
LIST OF FIGURES vii
LIST OF TABLES vii
1.0 INTRODUCTION 1-1
2.0 SUMMARY OF NEW SOURCE PERFORMANCE STANDARDS 2-1
2.1 Summary of NSPS 2-1
2.1.1 Emission Standards 2-1
2.1.2 Monitoring and Reporting 2-2
2.1.3 Performance Testing 2-2
2.2 Applicability of Standards 2-3
3.0 PROCESS DESCRIPTION; ATMOSPHERIC EMISSIONS 3-1
AND CONTROL METHODS
3.1 Process Description 3-1
3.1.1 Quarrying 3-1
3.1.2 Crushing and Grinding 3-1
3.1.3 Grinding, Blending, and Raw 3-4
Material Storage
3.1.4 Calcination and Clinker Production 3-4
3.2 Atmospheric Emissions 3-6
3.3 Control Device Applications 3-11
4.0 PROCESS, CONTROL DEVICE, AND EMISSION MONITORING 4-1
INSTRUMENTATION: RECORDS AND REPORTS
4.1 Instrumentation 4-1
4.2 Records and Reports 4-2
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TABLE OF CONTENTS (Continued)
Page
5.0 START-UP/SHUTDOWN/MALFUNCTIONS 5-1
5.1 Start-up 5-1
5.2 Shutdown 5-1
5.3 Malfunctions 5-2
5.4 Responsibilities During Malfunctions 5-3
6.0 PERFORMANCE TEST 6-1
6.1 Pretest Procedures 6-1
6.2 Process Operating Conditions 6-1
6.3 Process Observations 6-2
6.4 Emission Test Observations 6-3
6.5 Performance Test Checklist 6-5
7.0 PROCEDURES FOR PERIODIC INSPECTION 7-1
7.1 Conduct of Inspections 7-1
7.2 Inspection Checklist 7-2
7.3 Inspection Follow-Up Procedures 7-2
APPENDIX A STANDARDS OF PERFORMANCE FOR NEW A-l
STATIONARY SOURCES CODE OF FEDERAL
REGULATIONS
APPENDIX B SUGGESTED CONTENTS OF STACK TEST B-l
REPORTS
APPENDIX C VISIBLE EMISSION OBSERVATION FORM . C-l
VI
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LIST OF FIGURES
Figure
3.1 Portland Cement Process Flow Diagram
3.2 Gyratory and Roll Crushers Used for
Grinding Raw Materials
3.3 Typical Portland Cement Rotary Kiln
3.4 Dry Process Suspension Preheater »
3.5 Traveling-Grate Preheater System
3.6 Potential Emission Sources from Portland
Cement Plants
3.7 Feed Conveyor Transfer Point with Control
Device
3.8 Horizontal-Grate Clinker Cooler
Page
3-2
3-3
3-5
3-7
3-8
3-9
3-12
3-13
Table
3.1
4.1
6.1
7.1
7.2
LIST OF TABLES
Advantages/Disadvantages of Control
Devices for Various Cement Operations
Records Recommended for Portland Cement
Facilities
NSPS Inspection Checklist: Performance
Test of Portland Cement Plants
NSPS Inspection Checklist: Periodic
Check of Portland Cement Plant
Guidelines for Comparative Evaluation
of Compliance Status
Page
3-15
4-3
6-6
7-3
7-7
VII
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1.0 INTRODUCTION
Pursuant to Section 111 of the Clean Air Act, the
Administrator of the Environmental Protection Agency promul-
gated standards of performance for new and modified portland
cement plants on December 23, 1971. These standards are
applicable to portland cement manufacturing facilities whose
construction or modification was commenced after August 17,
1.971.
Each state may develop a program for enforcing new
source performance standards (NSPS) applicable to sources
within its boundaries. If the program is adequate, EPA will
delegate to the state the authority for implementation and
enforcement. Coordination of activities of the state agency
and the EPA Regional Office is essential for effective
operation of the NSPS program.
Long-term success of the NSPS program depends largely
upon the adoption of an effective plant inspection program,
primarily for monitoring of the NSPS performance tests and
for maintaining routine surveillance. This manual provides
guidelines for conducting such field inspections. The basic
inspection procedures presented herein should also be of use
in enforcing emission regulations affecting portland cement
plants contained in state air quality implementation plans.
1-1
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2.0 SUMMARY OF NEW SOURCE PERFORMANCE STANDARDS
Standards of air pollution control performance for new
and modified portland cement plants were originally proposed
on August 17, 1971. The standards promulgated on December
23, 1971, altered the particulate sampling method but held
constant the allowable emission rate from cement kilns and
clinker coolers, resulting in a slight relaxation of the
emission standards. New source performance standards are
subject to Federal regulation code 40 CFR 60. The title 40
designates "Protection of Environment"; part 60 classifies
new sources. On March 21, 1972, EPA issued a "Supplemental
Statement" noting that the change in the sampling method
without a change in the allowable emission rate permits
electrostatic precipitators as well as fabric filters to
meet the emission standard.
An amendment on May 2, 1973, recognized that start-ups,
shutdowns, and malfunctions are not representative conditions
of performance tests unless otherwise specified. In addition,
the amendment simplified reporting requirements. Section
60.62 was revised on November 12, 19,74, changing the opacity
limit for kilns from 10 percent to 20 percent.
The standards are summarized in Section 2.1. Several
conditions needing further interpretation are discussed in
Section 2.2.
2.1 SUMMARY OF NSPS
The emission standards for new or modified cement
plants are summarized below. The regulations, with revi-
sions through November 12, 1974, are given in Appendix A.
2.1.1 Emission Standards
Allowable limits for particulate matter and opacity are
presented below.
2-1
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Operation Particulate Opacity
Kiln 0.15 kg/metric ton
0.3 Ib/ton
of kiln feed
<20%
Clinker 0.05 kg/metric ton") _ . .. ,. , <10%
0.1 Ib/ton j of klln feed
All others None <10%
2.1.2 Monitoring and Reporting
Portland cement plant owners are responsible for main-
taining records of daily production rates, kiln feed rates,
malfunction episodes and quarterly reports of excess emissions.
2.1.3 Performance Testing
Testing of new or modified sources must be performed no
later than 60 days after achieving maximum production rate,
but no longer than 180 days after initial start-up. The
tests must be conducted at representative performance using
fuels and raw materials representative of those used during
normal operation.
The owner or operator has the following responsibilities:
0 To give a minimum of 30 days notification of scheduled
tests.
0 To give a minimum of 30 days notice of anticipated
start-up. EPA must be notified of the actual start-up
date within 15 days after such date.
0 To provide adequate sampling ports, safe sampling plat-
forms, safe access to the platforms, and utilities for
sampling and testing equipment.
0 To perform emission tests and furnish a written report
of test results to the Administrator.
The particulate testing method is specified in 40 CFR
60. Each test consists of three runs of the applicable
test method. Results of the repetitive tests are averaged
to determine compliance. EPA personnel may perform additional
tests at any reasonable time at any representative load condition.
2-2
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2.2 APPLICABILITY OF STANDARDS
Certain aspects of cement manufacture may present
difficulty in application of the performance standards. The
enforcement officer may wish to consult with his superiors
concerning circumstances not specifically covered in the
NSPS.
Compliance Test Deadlines
Although the standards require emission tests no longer
than 180 days after initial start-up, several manufacturers
indicate that under some circumstances, the period required
for adequate shakedown of kiln operations may exceed the
time alloted to perform the tests.
Preheater Status
Rising fuel costs will influence cement manufacturers
who design new plants to incorporate preheating systems for
partial calcination of the raw feed. Preheaters are an
integral part of the kiln system. Therefore, the kiln stan-
dards apply to the combined kiln-preheater system.
Combined Exhaust Gases
Particulate standards for kilns are 0.3 Ib/ton of dry,
raw feed to the kiln and for clinker coolers, 0.1 Ib/ton of
dry, raw feed to the kiln. Some existing facilities vent
exhaust gases from both units through the same control
device and stack.
Venting Systems
Some baghouses are on the pressure side of the kiln
draft fan. They may vent the clean gas through stacks, or
through openings in the sides and top of the baghouse.
Since the standards require an exhaust system which is
acceptable for conducting emission tests, the agency re-
viewing the permit to construct should inform the cement
facility that a closed control system may be economically
advantageous over an open baghouse.
2-3
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3.0 PROCESS DESCRIPTION; ATMOSPHERIC
EMISSIONS AND CONTROL METHODS
Portland cement is a powdered material which, with
water, forms a paste that hardens slowly, bonding rock,
gravel, and sand into concrete. Portland cement is defined
by ASTM C150 as, "a hydraulic cement produced by pulverizing
clinker consisting essentially of hydraulic calcium silicates,
usually containing one or more of the forms of calcium
sulfate as an interground addition."
3.1 PROCESS DESCRIPTION
Portland cement production involves quarrying and
crushing, grinding and blending, clinker production, and
finish grinding and packaging. Flow charts depicting .the
various steps are shown in Figure 3.1. Portland cement
production requires two types of raw materials and two
separate grinding operations.
3.1.1 Quarrying
The raw materials for producing Portland cement contain
calcium and silica as principal components, and alumina and
ferric oxide as fluxing components. Calcium sources are
limestone, marble, marl, oyster shells, and waste sludge
from lime plants. The other materials are obtained from
clay, shale, bauxite, silica sand, iron ore, and waste from
other industries.
The most common combination of raw materials is lime-
stone and clay or shale, carefully blended to yield the
final chemical proportions required in the cement. Limestone
and shale are blasted from quarries, usually close to the
cement facility. The raw material is transported to the
primary crusher by dump trucks loaded by power shovels, by
narrow-gage railroads with hopper cars, and by conveyor
belts.
3.1.2 Crushing and Grinding
The primary crusher reduces rock as large as 4 to 5
-feet across to fragments 6 to 10 inches across. The most
common types of primary crushers, are the gyratory, jaw, and
roll crushers. Figure 3.2 illustrates the gyratory and roll
3-1
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SLURHY PIMPS SLUWHf IS MIXED AND BLENDED . SLURRY STORAGE BASIMS
Hff
IU.lt StORAOE K '&»
Figure 3.1 Portland cement process flow diagram.
(Courtesy of Portland Cement Association
Old Orchard Road, Skokie, Illinois)
3-2
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hfFh '*
L*f , . • :c
m]
1 '^:.!
i' i pfe^a •- •• •
-
g .-•
..... ; / ... •
'
i
, ' •' *> , ,-
. -t ! ^.V>r
:,••; '..• .,!-
yffl
- j- -.. •
,-.X,''/>v
LI.
'
;'( -^
•
\ m m
u;^-'-,-
I1
if - h~*> -;.--.
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'
- •
. ^,, ... , , .
! f ^ :'@ :| ; .
• « -•- •• '.' •« -;i"
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:
;
Figure 3.2 Gyratory (a) and roll crushers (b)
used for grinding raw materials.
3-3
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crushers. A steel cone in the center of a gyratory crusher
presses material against an outside steel wall. A "jaw"
crusher employs steel rolls studded with teeth. As the
rolls rotate, the teeth crush the rock against steel plates.
After the rock is broken by the primary crushers, it is
carried by conveyors to the secondary crushers, usually of
the "hammer mill" type. Rock crushed by the hammer mill is
usually less than 3/4 inch across.
3.1.3 Grinding, Blending, and Raw Material Storage
The crushed raw material undergoes a fine grinding
process, which further reduces the rock size in preparation
for processing in the kiln. The fine grinding technique
depends upon whether cement is produced by the wet or dry
process. Ball and rod mills, used in both processes, work
on essentially the same principle. Cylindrical shells with
protruding ridges carry the balls or rods part way up the
side of the drum as it rotates. They then cascade back down
into the raw material and grind it to a fine consistency.
Balls and rods must be periodically replaced due to abrasion.
Wet Process
Raw feed, fed in the grinding mills, is combined with
water to form a slurry. The slurry, consisting of more than
one-third water, is discharged from the mill and stored in
huge open tanks where additional homogenation takes place.
The "wet process" slurry is usually pumped directly to
the kilns. In some instances, moisture is removed by vacuum
filters, thickeners, or hot kiln exhaust gases.
Dry Process
Hot gases for drying are provided by direct firing of
separate furnaces or by flow of exit gases from the kiln.
Ground raw materials are proportioned as they enter the
mills. The milled rock must be finely ground and thoroughly
mixed to produce uniform clinker composition. In closed-
circuit grinding, air separators return the coarse fraction
to the mill for further grinding, while the fine fraction
goes to a series of silos, bins, or storage buildings-
3.1.4 Calcination and Clinker Production
Dry feed or wet slurry is "burned" in a kiln to form
Portland cement clinker. The rotary kiln shown in Figure
3.3 is a steel cylinder with a refractory lining, slightly
inclined downward from the intake to the discharge end. Raw
materials are fed into the high end through a kiln feeder.
Fuel in the form of pulverized coal or coke, oil, or natural
gas is blown in with hot air, which is heated by passing
through clinker in the coolers at the discharge end of the
kiln. •
3-4 ,
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Figure 3.3 Typical portland cement rotary kiln.
(Courtesy of Allis-Chalmers Cement and Mining
Systems Division, Milwaukee, Wisconsin)
As the kiln revolves, the raw materials roll and slide
downward toward the lower end, gradually becoming exposed to
more and more heat. Water is first evaporated in the upper
part of the kiln. A chain system within the kiln promotes
the heat transfer. In the middle of the kiln, carbon dioxide
and combined water are driven from the raw materials, and
the original limestone, silica, iron ore and clay are changed
into new compounds, such as calcium silicates, aluminates,
and ferrites. The lower third of the kiln is the burning
zone, maintained at temperatures of approximately 2700°F,
where the material becomes incandescent. The clinker appears
in the form of round, marble-size, glass-hard balls.
Some kilns have a uniform diameter throughout their
length, others have either or both the feed end and the
discharge end enlarged. The feed end is enlarged to reduce
gas velocities and thus reduce dust loadings to the control
equipment. The discharge end is enlarged to accomodate the
higher gas volumes due to the high temperatures, and to
provide more surface exposure to the flame.
Operation of new or modified kilns is controlled by
instrumentation, direct digital control, or by computers.
Kiln rotation speed, material feed rate, burning temperature
profile, exhaust gas composition, draft, and fuel usage are
closely monitored and adjusted as required to produce good
clinker.
3-5
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Planners of new cement operations are considering new
techniques for clinker production to combat rising fuel
costs. Alternatives to using conventional kilns include
longer kilns, suspension preheaters, and traveling-grate
preheaters.
In a suspension preheater, shown in Figure 3.4, dry,
raw feed is fed downward through a series of cyclones
against an upward gas flow, resulting in an effective counter-
current heat exchange. The gas, supplied by the kiln exhaust,
does not require an additional heat input, although some
flash preheating systems are now being introduced.
A traveling-grate preheater system is shown in Figure
3.5. Ground raw meal is pelletized and discharged to a
hopper at the feed end of the traveling grate. A uniform
bed of pellets is spread across the full width of the
traveling grate. The pellets are heated and partially
calcined before entering the rotary kiln.
The clinker drops from the lower end of the kiln into
some form of cooler where its temperature is quickly reduced.
New or modified designs carry the clinker on a perforated
grate through which air is forced. A portion of hot over-
grate air is used as combustion air for the kiln.* From the
cooler, the clinker is either stockpiled or transferred
immediately to the finish mills.
Finish Grinding and Packaging
Gypsum, required to regulate the cement setting time,
is mixed with the clinker before it enters the grinding
mills. Clinker and gypsum are usually ground in a compart-
ment mill close-circuited with an air separator. The clinker
may be crushed before entering the mill, but there are
probably few two-mill systems in modern plants. The finished
cement is shipped either in bulk or in bags. Bulk cement is
carried by barges, tanker trucks, or hopper bottom cars
filled from large silos. Automatic packaging machines are
used to bag the cement. One bag of portland cement weighs
94 pounds; a barrel consists of four bags, or 376 pounds.
3.2 ATMOSPHERIC EMISSIONS
The potential sources of emissions from portland cement
plants are illustrated in Figure 3.6. All sources are
subject to NSPS (40 CFR 60, Section 60.62), except fugitive
dust emissions (points 1, 8, 16, 26). Many facilities
minimize fugitive dusts by using vacuum trucks to clean the
plant grounds.
* The amount of air recycled to the kiln is governed by the kiln
excess air; 1 to 2 percent ©2 eliminates potential explosions
without lowering kiln temperatures.
3-6
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Figure 3.4 Dry process suspension preheater.
(Courtesy of Allis-Chalmers Cement and Mining
Systems Division, Milwaukee, Wisconsin)
3-7
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U)
I
oo
Figure 3.5 Traveling-grate preheater system.
(Courtesy of Allis-Chalmers Cement and. Mining
Systems Division, Milwaukee, Wisconsin)
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RW MATERIAL! CONSIST OF
COMINATIOHS OF LIWSTQHE,
CEMENT ROCK. KARL OR OYSTER SHELL!.
AKO SHALE, CLAY, SAKO OR IRON ORE
TO UIUIM KILLl
Figure 3.6 Potential emission sources
from portland cement plants.
3-9
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Potential Emission Sources from Portland Cement Plants
(Key for Figure 3.6)
1 fugitive emissions from rock quarry
2 transfer emissions from feed entry to primary crusher
3 transfer point to conveyor
4 transfer point to secondary crusher
+5 transfer point to rock handling elevator
6 transfer point to conveyor
7 transfer point to material storage areas
+8 fugitive emissions from coal pile
+9 emissions from coal transfer to kiln
10D transfer point to conveyor; 10W transfer point to
conveyor
11D transfer point to rock handling elevator
11D transfer point to conveyor
13D transfer point to grinding mill feeder
14D grinding mill vent
*15 kiln exhaust
16 fugitive emissions from cement facility
*17 clinker cooler exhaust
18 . transfer point to clinker elevator
19 transfer point to clinker conveyor
20 transfer point to gypsum conveyor
21 transfer point for proportioned material
•22 transfer point to separator elevator
•23 transfer point to air separator conveyor
•24 transfer point to air separator
•25 grinding mill exhaust
26 loading operation fugitive emissions
+ Sources not applicable to all portland cement operations,
* Quantitative allowable limits.
• Closed-circuit mill systems do not emit particulate to
the atmosphere.
3-10
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Many of the emission areas are at the ends of material
conveying devices, called "transfer points." Uncontrolled
emissions at transfer points are reduced by lightly spraying
the feed with water or an aqueous chemical solution.
Exhaust gases from kilns, clinker coolers and dry
milling systems constitute the larger emission sources. In
the wet process plants, raw materials are not dried but are
ground with water to form a slurry; therefore, the only dust
is liberated from the transfer point at which rock is fed
into the grinding mill (10W).
Seal rings minimize the gap between stationary and
rotating components on both ends of the kiln. The kiln
draft is always negative at the feed end. The pressure at
the discharge end hood may go temporarily positive, which
results in "puffing," and the discharge of clinker dust.
The amount of particulate emitted to the atmosphere is
minimal.
3.3 CONTROL DEVICE APPLICATIONS
Particulate matter is the primary pollutant from the
manufacture of portland cement. The cement industry uses
mechanical collectors, electrostatic precipitators, gravel
beds, and fabric filter (baghouse) collectors or combinations
thereof, depending upon the operation and exhaust gas tempera-
tures. Although high-energy wet collectors (venturi scrubbers)
are used in several plants, they are not generally used in
the portland cement industry.
At the numerous transfer points in the cement plant,
cloth filters are used extensively to recover the dust. A
2000-acfm low-temperature baghouse, collecting dust from a
primary feed conveyor is shown in Figure 3.7. Properly
designed hoods, used with 1000-4000 cfm fans, effectively
control emissions. Increasing fan capacity only results in
drawing excess raw material off the conveyor; dust control
depends strongly upon design of the entire control system.
Raw and finish milling processes are usually controlled
by fabric filters, although precipitators effectively clean
exhaust streams from finish mills. The control devices,
connected in a closed loop with air separators, transport
the collected material back to the process for cement production,
Control of dust from the kiln, the largest dust source
in a cement plant, requires a baghouse or electrostatic
precipitator. Baghouses have a history of more reliable
operation than precipitators, although precipitators require
less energy and operate at lower costs.
3-11
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Many kiln operations equipped with precleaning mechanical
collectors recycle dust back to the kiln. Fine kiln dust,
however, contains more alkali than normal kiln feed. Portland
cement containing in excess of 0.6 percent alkali is not
recommended for use with certain aggregates which are classified
as reactive. As a consequence, only a portion of dust
collected from baghouses and precipitators is used for kiln
feed, depending on portland cement specifications. The dust
collected from precipitators can be separated into fractions
with variable alkali content.
Figure 3.7 Feed conveyor transfer point
with control device.
(Courtesy of California Portland Cement
Company, Los Angeles, California)
Kiln exhaust gases must be cooled to at least 600°F
before entering fabric filters. Glass and Nomex fabrics,
which withstand 550°F and 450°F respectively, are the most
commonly used in bags. Higher temperatures accelerate the
aging of bag fabrics.
When baghouses control dry-process kilns, gas tempera-
tures are of primary concern. When precipitators are used
on dry kilns, water cooling and conditioning can overcome
problems of resistivity and sulfate buildup.
3-12
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When either precipitators or fabric filters are used on
wet-process kilns, extensive thermal insulation must be
provided to prevent condensation of water vapor within the
device. Although some precipitators are specified to with-
stand a maximum temperature of 700°F, the usual operating
range is 300 to 500°F. Wet-process kiln gases exhibit the
proper moisture and temperature characteristics for effective
electrostatic precipitation. Water conditioning improves
particle resistivity in dry kilns, and reduces the tempera-
ture. Several preheater installations utilize the kiln
exhaust gases to dry the raw material. This increases the
moisture content of the gas and reduces its temperature.
The relatively small particle size of clinker cooler
dust requires high-energy control devices to meet NSPS. A
horizontal-grate clinker cooler equipped with a 16-compartment
baghouse is shown in Figure 3.8. Although precipitators are
not generally used for clinker cooler control, there are
several successful installations in use. If the unit is
properly designed, it may not be necessary to achieve collec-
tion efficiencies by adding water, except on an emergency
basis to prevent overheating.
Figure 3.8 Horizontal-grate clinker cooler,
(Courtesy of California Portland Cement
Company, Los Angeles, California)
3-13
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Gravel-bed filters are achieving some popularity to
clinker coolers. The filter media consists of silica gravel
which is insensitive to temperature. These collectors
handle operating temperatures to 1000°F with no gas cooling
or conditioning required.
A common practice is to reclaim heat by using exhaust
gases as preheated air in other operations, (e.g., kiln
exhaust serving as preheater air, clinker cooler gases used
for kiln combustion air). For conventional long wet- or
dry-process kiln systems, fans are positioned either ahead
of or after the collector, fabric filter or precipitator,
due to the low pressure drop of the system. However, for a
preheater kiln, the collector, due to the extr'emely high
pressure drop, must be located after the main kiln draft fan
to alleviate ambient air infiltration into the gas stream.
Table 3.1 summarizes the various types of control
equipment used throughout the portland cement facility.
3-14
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Table 3.1 ADVANTAGES/DISADVANTAGES OF CONTROL DEVICES FOR VARIOUS CEMENT OPERATIONS
Operation
Mechanical collectors
Fabric filters
Electrostatic precipitators
GJ
M
ui
Quarrying
Crushing and
grinding
Raw material
storage
Integral
preheater
and kiln
Kiln
Clinker
cooler
Finish
grinding
Finished
material
storage
Packaging and
shipping
Not applicable
Not applicable
Not applicable
Integral part of preheater
countercurrent gas and
material flow; high energy
controls necessary to
meet opacity requirements
Used as precleaners for
high energy devices
Used as precleaners for
high energy devices
Cannot meet opacity
requirements
Cannot meet opacity
requirements
Cannot meet opacity
requirements
Not applicable
Very good
Very good
Very good; must contend
with temperature reduc-
tion, dewpoint
Very good; must contend
with temperature reduc-
tion, dewpoint
Very good; must contend
with abrasive particulate.
Gravel-bed filters have
been recently introduced
Very good
Very good
Very good
Not applicable
Not economically feasible;
low flow volumes
Not economically feasible
Very good, if gas stream is
properly conditioned
Very good; must contend with
dewpoint particle resistivity,
and explosion potential problems
Precipitator design must contend
with combination of clinker dust
and moisture, possibly coating
ESP interior with cement
Very good on large mills
Not economically feasible; low
air flow volumes
Not economically feasible; low
air flow volumes
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4.0 PROCESS, CONTROL DEVICE, AND EMISSION
MONITORING INSTRUMENTATION: RECORDS AND REPORTS
Central control facilities incorporated on many of the
new portland cement plants handle the various phases of
cement production automatically. Daily production rates,
kiln feed rates, and any particulate emission measurements,
as required by NSPS, are either recorded on charts or logged
by hand. Monitoring of process variables, discussed in
Section 4.1, will aid the inspector in determining whether
the cement facility complies with regulations.
The reporting requirements, summarized in 40 CFR 60^
appear in Appendix A. The present reporting requirements
are discussed in Section 4.2.
4.1 INSTRUMENTATION
Process Instrumentation
Of interest to the enforcement officer are instruments
indicating process feed and production rates. The facility
must be operating at representative performance during
performance tests. Feed rates to the kiln recorded during
the performance test serve as reference values for future
inspections.
Control Device Instrumentation
Although a theoretical relationship between pressure
drop through a control device and efficiency of the collector
can be cited, many process changes (e.g. frequency of bag
cleaning, kiln ring formations), also cause pressure dif-
ferential to fluctuate and thus interfere with pressure
drop/efficiency relationships. Therefore, change in pressure
across the control device is not a valid indicator of emis-
sions from kiln and clinker cooler; the pressure changes "may
be attributable to other factors.
For kilns equipped with electrostatic precipitators,
efficiency depends on input power. A significant variation
in voltage or current changes the collection characteristics,
resulting in higher or lower emissions. Precipitator instru-
mentation, defined in Sections 6 and 7, will enable the
enforcement officer to determine whether precipitator
performance has significantly deteriorated.
4-1
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Emission Monitoring Instrumentation
Emission monitors are not required on portland cement
operations. If plant officials elect to install particulate
monitors, however, the results are to be recorded and filed
each day. Many companies prefer transmissometers, which
both monitor and record stack opacities. Opacity detectors
are only installed on wet kiln stacks if the temperature is
above the dewpoint, because the high moisture content of the
exhaust gases can interfere with opacity readings.
4.2 RECORDS AND REPORTS
Recordkeeping enables control officials to review the
Portland cement operation without frequent visits to the
facility. During periodic visits the inspector reviews the
plant records and notes any deviations from conditions at
the time of the performance test. Such comparisons should
reveal whether the source complies with particulate standards,
Recordkeeping and reporting requirements for portland
cement facilities are summarized in Parts 60.7, 60.8, and
60.63 in 40 CFR 60. The NSPS specify that the portland
cement facility only maintain records of production and
kiln feed rates, but other important parameters are listed
in Table 4.1.
Although records of daily production rates are required
by 40 CPR 60, variations in output are detected from finish
milling rates, not production from the kiln or clinker
cooler. Operating hours and control device parameters,
shown in Table 4.1, are records the inspector can review
during subsequent visits.
Some opacity monitors are equipped with lens protective
shutters which close when a malfunction occurs. In these
instances, there will be no opacity readings during the
malfunction.
The only reporting requirement is that plants submit a
quarterly report of any estimated or measured emissions
greater than those during the performance tests.
4-2
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Table 4.1 RECORDS RECOMMENDED FOR PORTLAND CEMENT FACILITIES
Parameter
Units
Comments
Production rates
Kiln feed rates
Hours of operation
Performance testing
*Precipitator power
for each section
*Fabric filter
maintenance
Particulate
measurements
Start-ups, shut-
downs, malfunctions
tons/day
tons/day
hours/day
KV and ma
% trans-
mittance
Record daily production
rates.
Note moisture content of
feed, if possible.
Record daily hours of
operation. Log process
start-up and shutdown
times.
File report of test results.
Note appreciable deviations
from values during perform-
ance tests.
When replacing original
bags with different types,
identify new fabric.
*Record calibration dates.
Date graphs when recorder
charts are used.
Record any process mal-
function that directly or
indirectly increases par-
ticulate emissions.
* Not required by 40 CFR 60.
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5.0 START-UP/SHUTDOWN/MALFUNCTIONS
Start-up, shutdown, and malfunctions of a portland
cement operation are not defined as "normal operating con-
ditions." These conditions may, and in most instances do,
cause emissions to exceed the opacity limits specified in
NSPS. Accordingly, the standards will not apply in such
cases. The effects of start-ups and shutdowns of the major
processes (kilns and clinker coolers) are discussed in
Sections 5.1 and 5.2; Section 5.3 reviews the malfunctions
that contribute to increased emissions. Responsibilities of
plant officials with respect to malfunctions are outlined in
Section 5.4.
5.1 START-UP
During start-up of a completely cold kiln, the firing
temperature is gradually raised over a period of time, which
is a function of the last refractory installation. Start-up
usually requires from 4 to 6 hours, but some kilns may need
as much as 48 hours.* Once feed is introduced to the kiln,
the flame is increased to preheat and "burn" the load,
resulting in clinker production. Although the gases do not
bypass the precipitator, the unit is not energized until the
fire is stabilized. Particulate emissions are above normal
until a stable fire is attained. Kiln baghouses are not
affected during start-up.
5.2 SHUTDOWN
Shutdowns do not affect emissions from operations
equipped with fabric filters. Emissions through kiln pre-
cipitators, however, are higher than normal during shutdown.
Although the process and conditioning water is shut off, the
kiln must be intermittantly turned to prevent warping.
Generally, emissions will only occur during and immediately
after rotation.
* Since the start-up time for each kiln varies, values in
this range should not be generalized as standard operating
practice. Several kilns minimize start-up emissions by
using auxiliary preheat burners.
5-1
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5.3 MALFUNCTIONS
Common malfunctions of control devices, such as mechani-
cal failures of cleaning systems or fabric deterioration,
are adequately described by the control device manufacturers.
These problems, together with malfunctions of the kiln that
have no effect on air contaminants (e.g. refractory deteriora-
tion, cylinder warpage) are not discussed here. The following
paragraphs briefly describe malfunctions of the kiln and
clinker cooler that can cause increased emissions.
Kiln "rings"* result from a layer of clinker progressively
building up inside the kiln and decreasing the cross-sectional
area at one or several points; these rings either break down
naturally or must be blasted off with shotgun shells. When
this happens, clinker rolls down the kiln, creating a high
particulate emission potential. Emissions from baghouses
are increased by variations in pressure brought about by the
ring; particulate emissions from precipitator-controlled
kilns increase considerably during ring breakdowns.
Feed systems contribute to emissions by feeding raw
materials in a non-uniform manner. Transport equipment,
delivering an abundance of feed, can raise uncontrolled
emissions. Plugged fuel feed systems can cause loss of
flame in the kiln; the resulting incomplete fuel oxidation
can cause explosions in precipitators and rarely in bag-
houses.
Exhaust gas leakage ahead of the control device allows
emission of portions of uncleaned gas streams to the atmos-
phere. Fan casings and ducting splice points should be
included in routine inspections.
Precipitator spray nozzles, used to precondition flue
gases, plug occasionally. Removal and replacement of a
nozzle requires 6 to 8 hours.
Precipitator rapping systems can freeze or rap improperly.
A buildup of dust reduces the operating voltage and may
eventually short out one or more precipitator sections.
Repair of hammer and rapper assemblies requires a minimum of
4 hours.
Precipitator collection electrodes warp under high
temperatures. Efficiencies are reduced if the distance
between the collecting and discharge electrodes varies.
* Ring formations cannot be defined as malfunctions, but they
do not represent normal kiln operation. Ring formation re-,
suits in an "upset" condition, and an unstable kiln flame.
5-2
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Bag failures are the major cause of excessive emissions
from a baghouse. Replacement bags will bleed until a filter
cake builds up on the fabric.
Baghouse preconditioning exhausr nozzles reduce gas
temperatures prior to contacting the fabric. Improperly
operating cooling systems increase volumes or reduce bag
life.
Control device mechanical equipment such as timers,
solenoids, and valves, malfunctions occasionally. Moving
parts stick, short, or wear out. Isolating improperly
working sections is sometimes difficult. .
Screw conveyors transporting collected dust from control
device hoppers can become inoperable. At such times, par-
ticulate matter is re-entrained from overloaded hopper bins.
5.4 RESPONSIBILITIES DURING MALFUNCTIONS
The Federal Register defines malfunctions as follows:
"Malfunctions are sudden and unavoidable failures of control
or process equipment, or processes that do not operate in a
normal or usual manner. Failures that are caused entirely
or in part by poor maintenance, careless operation, or any
other preventable condition shall not be considered malfunc-
tions."*
Ring breakdowns, although not representing- normal kiln
operation, are predictable and unavoidable steps in the
production of clinker. Therefore, ring breakdowns are not
classified as malfunctions, and no record of their history
is required.
The other incidents just described are considered
malfunctions. Records of these and any other incidents
leading to increased emissions must be logged. In addition
to describing the malfunction, plant personnel should identify
time of occurrence, duration, and steps taken to rectify it.
A quarterly report of malfunctions causing emissions
higher than those at the time of the performance test is to
be submitted to control agencies. If the same malfunction
occurs repeatedly, the agency may request the portland
cement facility to submit- a plan to eliminate the malfunction
or may initiate an enforcement action.
Periodic inspections will minimize the chance of break-
downs resulting in higher emissions. Upon detecting worn or
faulty equipment, plant personnel should replace the defec-
tive parts as soon as possible. It is important, therefore,
that each plant maintain 'an adequate inventory of spare
parts.
* Federal Register, Vol. 38, No. 84.
5-3
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6.0 PERFORMANCE TEST
This section describes the performance testing of a
Portland cement plant for compliance with NSPS. Section 6.1
covers the inspector's responsibilities in preparing for the
performance test. Section 6.2 discusses the operating
conditions under which the process should be tested, and
Section 6.3 outlines key operating parameters to be checked.
Section 6.4 describes the required emissions data and the
inspector's role in observation of emissions testing. An
inspection checklist in Section 6.5 summarizes all process
and test parameters to be recorded during the performance
test.
6.1 PRETEST PROCEDURES
Although the new source performance standards stipulate
exact procedures for compliance, facility personnel may
misunderstand or not be aware of parts of the regulations.
The inspector should therefore arrange a meeting with plant
personnel to review details of the standards and the testing
procedures prior to the actual perfdrmance test. The
inspector provides copies of the performance standards at
the meeting.
The inspector must ensure that management understands
that performance tests are valid only if performed while the
facility is operating at representative performance. At
this time, the parties should agree on the production rates
constituting "representative performance." The inspector
should also determine which testing firm is to perform the
tests and, if no representative of the firm attends the
meeting, contact the firm to ensure that tests are run in
accordance with procedures outlined in 40 CFR 60. The chief
purpose of the pretest meeting is to outline clearly for all
concerned parties the purpose of the tests and the required
test procedures.
The inspector must also survey the ductwork for test
port locations. If satisfactory sites are unavailable, he
should suggest modifications (e.g. stack extensions, flow
straighteners) needed to obtain accurate test results. The
location of a clean-up area should be agreed upon by all
parties prior to the test data. During a tour of the cement
plant, the inspector should determine whether additional
inspection personnel are required to monitor the process,
sampling site, and exhaust stack.
6-1
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6.2 PROCESS OPERATING CONDITIONS
In order for a cement facility to comply with new
source standards, compliance tests must be run under the
most severe conditions that would be expected under
representative conditions.
Milling,, storage, and loading systems
The throughput of raw and finished products must be
representative of normal or above-normal operating capacity.
Moisture content of raw feed should not be greater than that
anticipated for future operation. All transfer points are
evaluated at each point whether or not a control device is
operating.
Preheater, kiln, and clinker cooler operation
The major cement-producing processes must operate in
the usual manner during the particulate tests and opacity
reading periods. Many preheaters and kilns are designed to
heat material with exhaust gases from other processes. The
amounts of introduced air should be consistent with future
operation.
Baghouse cleaning cycles must not deviate from regular
operating practice. Power input to a precipitator must be
within the normal ranges specified by the manufacturer. The
kiln and clinker cooler should be running at the desired
load for at least one hour before emission tests are started.
Process data must be recorded during the stabilization
period to ensure that the process is in equilibrium during
the performance runs.
6.3 PROCESS OBSERVATIONS
The inspector should observe the process operating
conditions just discussed for future reference. These
observations will provide a baseline for comparison with '
operating conditions during later inspections. Also, the
observations may'indicate reasons for excessive particulate
emissions if the source fails to meet the NSPS.
The inspector must check several operating parameters
during the performance test. These include kiln feed rate,
fabric filter cleaning cycles, and precipitator power input.
For dry process operations, fresh feed is mixed with small
quantities of recycled material and conveyed to the kiln. Many
Portland cement facilities only monitor the fresh feed weight.
Kiln compliance, based on the total weight of feed to the kiln>
requires an estimate of the percentage of recycled material in*
the total feed system. These values should be agreed upon by
the inspector and cement plant management prior to the
performance tests.
6-2
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Kiln feed rate
Records of kiln feed rates are required to calculate
emissions and to compare with standards for kiln and clinker
cooler operation. The raw feed supplied to the kiln is
monitored in the control room. These monitors must be
calibrated prior to the performance test to assure correct
kiln feed rates. The inspector must be informed by plant
operators when the emission tests commence and finish so
that feed rate during the test can be calculated.
For wet process operations, the moisture content of the
fuel is required to convert the feed rate to a dry basis. A
500 to 1000 ml grab sample taken every 15 minutes during
each run is sufficient to calculate the moisture content of
the dry feed.
Fabric filter cleaning cycles
Prolonging the time between successive cleaning cycles
increases particulate collection efficiency and reduces
controlled emissions. The frequency and duration of reverse
air flow, noted during the performance test, is checked with
frequencies and cleaning times during subsequent inspections.
Some baghouses have automatic reverse air flow which is
triggered by the pressure drop.
Precipitator power input
The amounts of current and voltage supplied to the
precipitator indicate gas cleaning performance. Many pre-
cipitators are equipped with automatic voltage controls, but
amperage variations can change ESP performance characteristics.
Unfortunately, undetectable parameters (e.g. plate misalignment)
can reduce collection efficiencies.
During the production of portland cement, energy is
saved by regenerating hot exhaust gases (e.g. clinker cooler
exhaust back through the kiln, kiln exhaust recycled to the
preheater). Since the regenerated air flow remains constant
at all times, emissions are independent of recycled exhaust
gases.
6.4 EMISSION TEST OBSERVATIONS
Particulate tests and opacity determinations are con-
ducted by qualified emission testing personnel. The inspector
is responsible for ensuring that all pertinent data are
collected, that the field procedures and equipment meets
CFR, and that the cement operations are run at representative
performance during all sampling operations. A qualified EPA
technician or engineer reads visible emissions, as described
in Part 60.11(b).
6-3
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The new source standards require emission tests comprised
of three particulate runs performed while the kiln and
clinker cooler operate at representative performance. The
facility should attempt to run the process at a constant
rate during the three runs. Each test must cover at least
a 1-hour sampling period and process volume of at least 0.85
dscm (30.0 dscf) and 1.15 dscm (40.6 dscf) respectively, for
the kiln and clinker cooler. Sampling sites requiring more
than 40 traverse points may require longer sampling times,
if the meter technician has difficulty recording data for
the individual sampling points due to time limitations.
Since constant surveillance of a qualified stack sampling
team is not appropriate, the inspector should limit his
observations to a few major items:
0 Record duct dimensions (both inside and outside) and
location of sample ports.
0 Check the number of ports at the sampling site and
examine the ducting for the nearest upstream and
downstream obstructions. Ask the crew leader how many
total points will be traversed and check with Figure
1.1 in 40 CFR 60 to determine whether the stream will
be properly sampled.
0 Note whether the crew runs a preliminary traverse, and
if so, inquire what nozzle diameter is selected.
(Isokinetic sampling is a function of nozzle size).
0 Check to ensure that the moisture content of the gas
stream is determined by Method 4 or an equivalent
method such as drying tubes or volumetric condensers;
assumption of the moisture content is not allowed.
0 Observe the leak test of the sampling train. The
allowable leak rate is given in Method 5. Leakage
results in lower concentrations than are actually
present. Be next to the dry gas meter during the
leak check, note whether the meter hand is moving.
(The more the hand is moving, the greater the air
leakage.) Leak checks must also be made if the train
is disassembled during the run to change a filter or to
replace any component.
0 Record dry gas meter readings before and after test.
0 Record average velocity head and temperatures in ducts
during tests.
0 If impingers are used during test, observe whether they
are bubbling. If they are not, the sampling train is
either plugged or disconnected from the pump.
6-4
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0 Check the cleaning procedures for the front half of the
train. Careless removal of filters or cleaning of
probes will result in lower calculated emissions. Look
for broken glass from probes or connectors. Test is
void if glass probe was broken during test. If glass
connectors are broken in transport from sampling site
to clean-up area, test is still valid. Be sure identifi-
cation labels are properly attached to collection containers.
The probe should be brushed and rinsed with acetone
thoroughly to remove all particulates. The probe .should
be visually inspected after cleaning to ascertain that all
particulates have been removed.
0 Observe gas analysis procedure for determining C02.
Technician should take at least three samples before
averaging readings. Variations greater than 0.5 percent
(grab sample) or 0.2 percent (integrated sample) indicate
gas mixture was not thoroughly bubbled in reagents. Ask
technician or crew leader when new reagents were added to
apparatus.
0 Check percent isokinetic.
0 Determine calibration dates and procedures used to
calibrate pitot tube, thermometer, dry gas meter, and
manometer orifice.
0 Record process parameters during emission tests and
opacity readings.
6.5 PERFORMANCE TEST CHECKLIST
The inspector must observe kiln operation and emission
tests simultaneously to ensure that valid data are used in
determining plant performance. The performance test checklist
in Table 6.1 is based upon the observations described earlier.
If the inspector observes any additional parameters the plant
records that are directly related to emissions, they should also
be recorded.
In the event of a malfunction or upset, the enforcement
officer must inform the test crew leader that the sampling trains
are to be shut-off and removed from the ducts as quickly as
possible. If process changes or deviations occur, the inspector
is responsible for instructing the sampling personnel whether to
proceed with the run or temporarily stop the test.
The enforcement officer keeps a log of any abnormal operation,
time of occurance, and return to representative conditions.
After reviewing emission test results, he can decide whether
the run is valid.
According to 60.8(a) of 40 CFR 60, cement plant manage-
ment is responsible for furnishing the Environmental Protec-
tion Agency a written report of the results of the emission
tests. Appendix B provides a suggested format for the
report. These reports should be carefully checked and the
data compared with values on the inspection checklist.
6-5
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Table 6.1 NSPS INSPECTION CHECKLIST: PERFORMANCE TEST OF
PORTLAND CEMENT PLANTS
Facility name
Facility address
Name of plant contact
Source code number (indicate CDS, NEDS, etc.)
Unit identification (To be tested)
Finish grinding rate
Kiln input capacity
Initial start-up date
Test date
tons/hour
tons/hour
A. FACILITY DATA
EH Wet
Dry
Kiln
Major Emission Points
Kiln
Separate Stack
Clinker Cooler II Separate Stack
Combined
with
Combined
with
6-6
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B. PORTLAND CEMENT PARAMETERS
Record the following data every 3Q minutes during perform-
ance test.
Parameter
Time
Kiln feed rate, tons/hr
Kiln precipitator current, a
kv
Kiln baghouse cleaning
interval, min.
Clinker cooler baghouse
cleaning interval, min.
Note for each section.
C. PRETEST DATA (OBTAIN FROM TEST TEAM LEADER)
Test company
Field leader
Duct dimensions
in.x
Nearest upstream obstruction
Nearest downstream obstruction
No. of sampling ports
No. of sampling points
No. of sampling points required
from Figure 1.1 in 40 CFR 60
in.; Area
_ft'
ft
ft
6-7
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PARTICULATE PERFORMANCE TEST
Test No. Start time
Finish time
Preliminary traverse run (Method 1)
Chosen nozzle diameter in.
Train leak check
Moisture determination (Method 4)
Percent moisture
Yes
D
No
D
D
ml collected gas volume
(or wet/dry bulb readings)
Combustion gas analysis
ml
ft"
0,
CO,
Dry gas meter reading before test
Dry gas meter reading after test
Volume sampled
Test duration
Average of meter orifice
pressure drop
Average duct temperature
_ft3 at
ft3 at
(time)
(time)
ft"
jninutes
inches of water
[ I Acceptable I I Unacceptable
Velocity Head at Sampling Point
Meter AH@*
Repetition State Time
Repetition Finish Time
CLEAN UP PROCEDURE
Filter condition L
Probes
Glass connectors
Clean up sample spillage
inches H-O
Dry
Unbroken
Unbroken
None LJ Slight
LJ Wet
I I Broken
Broken
I Major
Sample bottle identification
D
Acetone blank taken
Yes
Yes
LJ No
LJ No
6-8
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F. OPACITY MEASUREMENTS DURING PERFORMANCE TESTS
Yes No Remarks
a
Transfer points CD CH
Crushers CD [U
Raw feed mills []] Q
Raw feed silos [^ D
Preheater Q Q
Kiln D D
Clinker cooler Q [U
Clinker cooler silos Q Q
Finish grinding mills Q Q
Cement storage silos [U CH
Loading points [D n
Enforcement officer is responsible for seeing that all transfer
points are monitored.
6-9
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7.0 PROCEDURES FOR PERIODIC INSPECTION
Periodic inspections of a portland cement facility are
made to determine whether emissions during routine operation
are in compliance with the new source performance standards.
Section 7.1 discusses conduct of following the performance
test; Section 7.2 provides an inspection checklist. Section
7.3 describes follow-up procedures after completion of an
inspection.
7.1 CONDUCT OF INSPECTIONS
Frequency of inspections is governed by agency policy
and EPA guidelines. A quarterly inspection is recommended
unless complaints dictate more frequent inspections.
Major emphasis of the inspection is upon visual observa-
tion of the stack and other emission sources and checking of
records and instrumentation. Visible emissions are stressed
because enforceable standards can be applied and because
they are indicative of control system operation. The inspec-
tor also checks operating records, comparing operating hours
and kiln feed rates recorded during the performance test
with current values. Unfortunately so many process variables
affect the efficiency of kilns and clinker coolers equipped
with baghouses that pressure drop across the fabric is an
unreliable indicator of collection performance. In kilns
controlled with precipitators, a power loss (decrease in
voltage or current) indicates a possible rise in dust emission.
The inspection procedures noted below should be followed
in the order given whenever possible. Any questionable
matters can be investigated later by examining records and
consulting with facility personnel.
Visible Emissions
0 Note opacities of emissions from all processes. Follow
established procedures as described by the CFR (Reference
Method 9). An observation form is presented in Appendix C,
Control Equipment
0 Make a general inspection of all control equipment,
with main emphasis on kiln and clinker cooler.
7-1
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0 Inspect interior of kiln and clinker cooler positive
pressure baghouses for broken or removed bags. (Nega-
tive pressure baghouses cannot readily be internally
inspected with the kiln in operation.)
0 Check manometers for bag cleaning cycle. Manometer
will indicate reverse flow during cleaning. If bags
are being cleaned more frequently than during the
performance tests, emissions may be higher.
0 Record current and voltage inputs to precipitators. If
the unit is equipped with a spark rate meter, record
the sparks per minute.
Process
0 Inspect kiln exterior for warped surfaces or bulges.
This can result in refractory damage, causing increased
uncontrolled emissions.
Records
0 Review feed rates to the kiln and clinker cooler.
Increases in feed rate tend to raise particulate emis-
sions, unless additional control devices are added. If
feed rates are consistently higher than those at the
time of the performance test, another emission test is
warranted.
0 When opacity-measuring instruments are installed on
kiln exhaust systems, examine the printout graphs fpr
steady-state opacity values and frequency of malfunc-
tions.
7.2 INSPECTION CHECKLIST
The inspection checklist in Table 7.1 is derived from
the procedures just described.
7.3 INSPECTION FOLLOW-UP PROCEDURES
The inspector should be affiliated with either a federal,
state, or local agency. In any event he should be aware of
the importance of interagency communications among all -
groups concerned with the current status of new or modified
Portland cement plants.
Some inspectors may have responsibility for monitoring
of air pollutants in addition to those covered by the NSPS,
such as odors and fugitive dust emissions. The inspector's
supervisor or other agency official will determine whether
monitoring of the additional pollutants is handled separately
or in combination with those covered by the NSPS.
7-2
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Table 7.1 NSPS INSPECTION CHECKLIST:
PERIODIC CHECK OF PORTLAND CEMENT PLANT
Facility name
Facility address
Name of plant contact
Source code number
Inspection date
A. VISIBLE EMISSIONS
Opacity Compliance
IN OUT Remarks
Transfer points I—I I—I
Crushers LJ I—'
Raw feed mills LJ LJ
Raw Feed silos I—I I—I .
Kiln D D
Clinker cooler LJ LJ
Clinker cooler silos LJ LJ
Finish grinding mills LJ LJ
Cement storage silos LJ LJ
Loading points LJ LJ
aNote opacities from all transfer points
7-3
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B. CONTROL EQUIPMENT
Control
Preheater
Kiln
Clinker cooler
Baghouse: filter
cleaning interval,
min.
Precipitator:
power input -
voltage, kv
current, ma
Note any processes with improper operation, (e.g. inoperative
fan, missing or broken bags, exhaust bypass, dirty hoppers,
inadequate hoods.)
Operation
Description of malfunction
C. PROCESS
Exterior condition of kiln;
I—I Cylindrical
\—\ Warped
7-4
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D. RECORDS
Records kept
Parameter Yes No
Kiln feed rate D D
Cement production ratea LJ LJ
Particulate emission measurements I—I I—I
Malfunction episodes I—I I—I
Emissions are independent of daily cement production,
but 40 CFR 60 requires the records be kept.
7-5
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The sequence for any required enforcement action is as
follows. Using the inspection checklist (Table 7.1), the
inspector prepares a report of-the status of the portland
cement facility. Legal and technical authorities review the
report to determine whether a citation or another performance
test is in order. In cases requiring court action, the
inspector may be called on to testify and will have need for
accurate, dated records of his observations.
The inspector should also compare the current inspection
data with data from earlier inspections or from the performance
test. Although compliance with particulate emission standards
cannot be determined without a source test, the checklists
should provide sufficient information to indicate whether
the facility may be generating excessive particulate emissions,
and whether the facility is adhering to good maintenance
practices. Table 7.2 provides a comparison guideline by
which the inspector can determine when to recommend enforcement
action, such as issuance of a citation or conduct of compliance
tests.
7-6
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Table 7.2 GUIDELINES FOR COMPARATIVE EVALUATION
OF COMPLIANCE STATUS
Parameter
Indicators for enforcement action
Visible emissions
Kiln feed rate
Control equipment
When opacity readings are
greater than allowable values,
allow reasonable time for control
(24 hours to 30 days, depending on
task and availability of parts)
before recommending citation.
A 1-hour average greater than 120%
of kiln feed rate over rate recorded
during performance test occurring
more than once per week.warrants
request for emission tests of kiln and
clinker cooler.
Kiln precipitator: Power decrease of
20% or more warrants emission tests at
that rating. Kiln and clinker cooler
baghouse: When intervals between
cleaning decrease by more than 50%
(based on performance test), request
emission tests.
7-7
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APPENDIX A
STANDARDS OF PERFORMANCE FOR NEW
STATIONARY SOURCES
CODE OF FEDERAL REGULATIONS
(See 40 CFR 60 for complete
sampling procedures)
A-l
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CFR Title 40-PROTECTION OF ENVIRONMENT
Chapter 1 - Environmental Protection Agency
SUBCHAPTER C - AIR PROGRAMS
PART 60 - STANDARDS OF PERFORMANCE
FOR NEW STATIONARY SOURCES
Subpart A - General Provisions
§ 60.1 Applicability.
The^provisions of this part apply to the owner or
operator of any stationary source which contains an affected
facility the construction or modification of which is com-
menced after the date of publication in this part of any
standard (or, if earlier, the date of publication of any
proposed standard) applicable to such facility.
§ 60.2 Definitions.
As used in this part, all terms not defined herein
shall have the meaning given them in the Act:
(a) "Act" means the Clean Air Act (42 U.S.C. 1857 et
seq., as amended by Public Law 91-604, 84 Stat. 1676).
(b) "Administrator" means the Administrator of the
Environmental Protection Agency or his authorized represen-
tative .
(c) "Standard" means a standard of performance proposed
or promulgated under this .part..
(d) "Stationary source" means any building, structure,
facility, or installation which emits or may emit any air
pollutant.
(e) "Affected facility" means, with reference to a
stationary source, any apparatus to which a standard is
applicable.
(f) "Owner or operator" means any person who owns,
leases, operates, controls, or supervises an affected facil-
ity or a stationary source of which an affected facility is
a part.
(g) "Construction" means fabrication, erection, or' '"'
installation of an affected facility. '']
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(h) "Modification" means any physical change in, or
change in the method of operation of, an affected facility
which increases the amount of any air pollutant (to which a
standard applies) emitted by such facility or which results
in the emission of any air pollutant (to which a standard
applies) not previously emitted, except that:
(1)'Routine maintenance, repair, and replacement shall •
not be considered physical changes, and
(2) The following shall not be considered a change in
the method of operation:
(i) An increase in the production rate, if such
increase does not exceed the operating design capacity of
the affected facility;
(ii) An increase in hours of operation;
(iii) Use of an alternative fuel or raw material if,
prior to the date any standard under this part becomes
applicable to such facility, as provided by § 60.1, the
affected facility is designed to accomodate such alternative
use.
(i) "Commenced" means, with respect to the definition
of "new source" in section 111(a)(2) of the Act, that an
owner or operator has undertaken a continuous program of
construction or modification or that an owner or operator
has entered into a contractual obligation to undertake and
complete, within a reasonable time, a continuous program of
construction or modification.
(j) "Opacity" means the degree to which emissions
reduce the transmission of light and obscure the view of an
object in the background.
(k) "Nitrogen oxides" means all oxides of nitrogen
except nitrous oxide, as measured by test methods set forth
in this part.
(1) "Standard conditions" means a temperature of 20°C
(68°F) and a pressure of 760 mm of Hg (29.92 in. of Hg).
(m) "Proportional sampling" means sampling at a rate
that produces a constant ratio of sampling rate to stack gas
flow rate.
(n) "Isokinetic sampling" means sampling in which the
linear velocity of the gas entering the sampling nozzle is
equal to that of the undisturbed gas stream at the smaple
point.
(o) "Start-up" means the setting in operation of an
affected facility for any prupose.
(p) "Shutdown" means the cessation of operation of an
affected facility for any purpose.
(q) "Malfunction" means any sudden and unavoidable
failure of air pollution control equipment or process
equipment or of a process to operate in a normal or usual
manner'. Failures that are caused entirely or in part by
poor maintenance, careless operation, or any other preventable
upset cbncfition or preventable equipment breakdown shall not
be considered malfunctions.
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(r) "Hourly period" means any 60 minute period com-
mencing on the hour.
(s) "Reference method" means any method of sampling
and analyzing for an air pollutant as described in Appendix
A to this part.
(t) "Equivalent method" means any method of sampling
and analyzing for an air pollutant which have been demon-
strated to the Administrator's satisfaction to have a con-
sistent and quantitatively known relationship to the refer-
ence methods, under specified conditions.
(u) "Alternative method" means any method of sampling
and analyzing for an air pollutant which is not a reference
or equivalent method but which has been demonstrated to the
Administrator's satisfaction to, in specific cases, produce
results adequate for his determination of compliance.
(v) "Particulate matter" means any finely divided
solid or liquid material, other than uncombined water, as
measured by Method 5 of Appendix A to this part or an equiva-
lent or alternative method.
(w) "Run" means the net period of time during which an
emission sample is collected. Unless otherwise specified, a
run may be either intermittent or continuous within the
limits of good engineering practice.
§ 60.4 Address.
All requests, applications, submittals, and other
communications to the Administrator pursuant to this part
shall be submitted in duplicate and addressed to the appro-
priate Regional Office of the Environmental Protection
Agency, to the attention of the Director, Enforcement
Division.
§ 60.5 Determination of construction or modification.
When requested to do so by an owner or operator, the
Administrator will make a determination of whether actions
taken or intended to be taken by such owner or operator
constitute construction or modification or the commencement
thereof within the meaning of this part.
§ 60.6 Review of plans.
(a) When requested to do so by an owner or operator,
the Administrator will review plans for construction or
modification for the purpose of providing technical advice
to the owner or operator.
(b)(1) A separate request shall be submitted for each
construction or modification project.
(2) Each request shall identify the location of such
project, and be accompanied by technical information describ-.
ing the proposed nature, size, design, and method of opera-"
tion of each affected facility involved in such project,
including information on any equipment to be used for measure-
ment or control of emissions.
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(c) Neither a request for plans review nor advice
furnished by the Administrator in response to such request
shall (1) relieve an owner or operator of legal respon-
sibility for compliance with any provision of this part or
of any applicable State or local requirement, or (2) prevent
the Administrator from implementing or enforcing any provi-
sion of this part or taking any other action authorized by
the Act.
§ 60.7 Notification and record keeping.
(a) Any owner or operator subject to the provisions of
this part shall furnish the Administrator written notifica-
tion as follows:
(1) A notification of the anticipated date of initial
start-up of an affected facility not more than 60 days or
less than 30 days prior to such date.
(2) A notification of the actual date of initial start-
up of an affected facility within 15 days after such date.
(b) Any owner or operator subject to the provisions of
this part shall maintain for a period of 2 years a record of
the occurrence and duration of any start-up, shutdown, or
malfunction in operation of any affected facility.
(c) A written report of .excess emissions as defined in
applicable subparts shall be submitted to the Administrator
by each owner or operator for each calendar quarter. The
report shall include the magnitude of excess emissions as
measured by the required monitoring equipment reduced to the
units of the applicable standard, the date, and time of
commencement and completion of each period of excess emis-
sions. Periods of excess emissions due to start-up, shutdown,
and malfunction shall be specifically identified. The
nature and cause of any malfunction (if known), the correc-
tive action taken, or preventive measures adopted shall be
reported. Each quarterly report is due by the 30th day
following the end of the calendar quarter. Reports are not
required for any quarter unless there have been periods of
excess emissions.
(d) Any owner or operator subject to the provisions of
this part shall maintain a file of all measurements, including
monitoring and performance testing measurements, and all
other reports and records required by all applicable sub-
parts. Any such instruments, reports and records shall be
retained for at least 2 years following the date of such
measurements, reports, and records.
§ 60.8 Performance tests.
(a) Within 60 days after achieving the maximum production
rate at which the affected facility will be operated, but
noJ.,Xater than 180 days after initial start-up of such
facility-and at such other times as may be required by the
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Administrator under section 114 of the Act, the owner or
operator of such facility shall conduct performance test(s)
and furnish the Administrator with a written report of the
results of such performance test(s).
(b) Performance tests shall be conducted and data
reduced in accordance with the test methods and procedures
contained in each applicable subpart unless the Administrator
(1) specifies or approves, in specific cases, the use of a
reference method with minor changes in methodology, (2)
approves the use of an equivalent method, (3) approves the
use of an alternative method the results of which he has
determined to be adequate for indicating whether a specific
source is in compliance, or (4) waives the requirement for
performance tests because the owner or operator of a source
has demonstrated by other means to the Administrator's
satisfaction that the affected facility is in compliance
with the standard. Nothing in this paragraph shall be
construed to abrogate the Administrator's authority to
require testing under section 114 of the Act.
(c) Performance tests shall be conducted under such
conditions as the Administrator shall specify to the plant
operator based on representative performance of the affected
facility. The owner or operator shall make available to the
Administrator such records as may be necessary to determine
the conditions of the performance tests. Operations during
periods of start-up, shutdown, and malfunction shall not
constitute representative conditions of performance tests
unless otherwise specified in the applicable standard.
(d) The owner and operator of an affected facility
shall provide the Administrator 30 days prior notice of the
performance test to afford the Administrator the opportunity
to have an observer present.
(e) The owner or operator of an affected facility shall
provide or cause to be provided, performance testing facilities
as follows:
(1) Sampling ports adequate for test methods applicable
to such facility.
(2) Safe sampling platform(s).
(3) Safe access to sampling platform(s).
(4) Utilities for sampling and testing equipment.
'(f) Each performance test shall consist of three
separate runs using the applicable test method. Each run
shall be conducted for the time and under the conditions
specified in the applicable standard. For the purpose of
determining compliance with an applicable standard, the
arithmetic means of results of the three runs shall apply.
In the event that a sample is accidentally lost or condi-
tions occur in which one of the three runs must be discon-
tinued because of forced shutdown, failure of an irreplac.ab.le
portion of the sample train, extreme meteorological condition's!.,
or other circumstances, beyond the owner or operator's „ "-HO"
control, compliance may, upon the Administrator's approval,
be determined using the arithmetic mean of the results of
the two other runs.
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§ 60.9 Availability of information.
(a) Emission data provided to, or otherwise obtained
by, the Administrator in accordance with the provisions of
this part shall be available to the public.
(b) Except as provided in paragraph (a) of this section,
any records, reports, or information provided to, or other-
wise obtained by, the Administrator in accordance with the
provisions of this part shall be available to the public,
except that (1) upon a showing satisfactorily to the Adminis-
trator by any person that such records, reports, or informa-
tion, or particular part thereof (other than emission
data), if made public, would divulge methods or processes
entitled to protection as trade secrets of such person, the
Administrator shall consider such records, reports, or
information, or particular part thereof, confidential in
accordance with the purposes of section 1905 of title 18 of
the United States Code, except that such records, reports,
or information, or particular part thereof, may be disclosed
to other officers, employees, or authorized representatives
of the United States concerned with carrying out the provi-
sions of the Act or when relevant in any proceeding under
the Act; and (2) information received by the Administrator
solely for the purposes of § 60.5 and 60.8 shall not be
disclosed if it so identified by the owner or operator as
being a trade secret or commercial or financial information
which such owner or operator considers confidential.
§ 60.10 State authority.
The provisions of this part shall not be construed in
any manner to preclude any State or political subdivision
thereof from:
. (a) Adopting and enforcing any emission standard or
limitation applicable to an affected facility, provided that
such emission standard or limitation is not less stringent
than the standard applicable to such facility.
(b) Requiring the owner or operator of an affected
facility to obtain permits, licenses, or approvals prior to
initiating construction, modification, or operation of such
facility.
§ 60.11 Compliance with standards and maintenance requirements.
(a) Compliance with standards in this part, other than
opacity standards, shall be determined only by performance
tests established by § 60.8.
(b) Compliance with opacity standards in this part shall
be determined by conducting observations in accordance with
Reference Method 9 in Appendix A of this part. Opacity
reading's of portions of plumes which contain condensed, uncom-
bxrieif^water vapor shall not be used for purposes of determining
compliance with opacity standards. The results of continuous
monitoring by transmissometer which indicate that the opacity
at the time visual observations were made was not in excess
A-7
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of the standard are probative but not conclusive evidence
of the actual opacity of an emission, provided that the source
shall meet the burden of proving that the instrument used meets
(at the time of the alleged violation) Performance Specification 1
in Appendix B of this part, has been properly maintained and
(at the time of the alleged violation) calibrated, and that the
resulting data have not been tampered with in any way.
(c) The opacity standards set forth in this part shall
apply at all times except during periods of start-up, shut-
down, or malfunction, and as otherwise provided in the
applicable standard.
(d) At all times, including periods of start-up, shutdown,
and malfunction, owners and operators shall, to the extent
practicable, maintain and operate any affected facility
including associated air pollution control equipment in a
manner consistent with good air pollution control practice
for minimizing emissions. Determination of whether acceptable
operating and maintenance procedures are being used will be
based on information available to the Administrator which
may include, but is not limited to, monitoring results,
opacity observations, review of operating and maintenance
procedures, and inspection of the source.
(e)(1) An owner or operator of an affected facility may
request the Administrator to determine opacity of emissions from
the affected facility during the initial performance tests
required by § 60.8.
(2) Upon receipt from such owner or operator of the written
report of the results of the performance tests required by § 60.
8, the Administrator will make a finding concerning compliance
with opacity and other applicable, standards. If the Administrator
finds that an affected facility is in compliance with all applicable
standards for which performance tests are conducted in accordance
with § 60.8 of this part but during the time such performance
tests are being conducted fails to meet any applicable opacity
standard, he shall notify the owner or operator and advise him
that he may petition the Administrator within 10 days of receipt
of notification to make appropriate adjustment to the opacity
standard for the affected facility.
(3) The Administrator will grant such a petition upon a
demonstration by the owner or operator that the affected facility
and associated air pollution control equipment was operated and
maintained in a manner to minimize the opacity of emissions during
the performance tests; that the performance tests were performed
under the conditions established by the Administrator; and that the
affected facility and associated air pollution control equipment
were incapable of being adjusted or operated to meet the applicable
opacity standard.
(4) The Administrator will establish an opacity standard
for the affected facility meeting the above requirements at a
level at which the source will be able, as indicated by the per-
formance and opacity tests, to meet the opacity standard at all
times during which the source is meeting the mass or concentra-
tion emission standard. The Administrator will promulgate the
new opacity standard in the Federal Register.
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§ 60.12 Circumvention.
No owner or operator subject to the provisions of this
part shall build, erect, install, or use any article, machine,
equipment or process, the use of which conceals an emission
which would otherwise constitute a violation of an applicable
standard. Such concealment includes, not is not limited to,
the use of gaseous diluents to achieve compliance with an
opacity standard or with a standard which is based on the
concentration of a pollutant in the gases discharged to the
atmosphere.
Subpart F - Standards of Performance
for Portland Cement Plants
§ 60.60 Applicability and designation of affected facility.
The provisions of the subpart are applicable to the
following affected facilities in portland cement plants;
kiln, clinker cooler, raw mill dryer, raw material storage,
clinker storage, finished product storage, conveyor transfer
points, bagging and bulk loading and unloading systems.
§ 60.61 Definitions.
As used in this subpart, all terms not defined herein
shall have the meaning given them in the Act and in Subpart
A of this part.
(a) "Portland cement plant" means any facility manu-
facturing portland cement by either the wet or dry process.
§ 60.62 Standard for particulate matter.
(a) On and after the date on which the performance test
required to be conducted by § 60.8 is completed, no owner or
operator subject to the provisions of this subpart shall
cause to be discharged into the atmosphere from any kiln any
gases which:
(1) Contain particulate matter in excess of 0.15 kg per
metric ton of feed (dry basis) to the kiln (0.30 Ib per ton).
(2) Exhibit greater than 20 percent opacity.
(b) On and after the date on which the performance test
is required to be conducted by § 60.8 is completed, no owner
or operator subject to the provisions of this subpart shall
cause to be discharged into the atmosphere from any clinker
cooler any gases which: •• •
(1) Contain particulate matter in excess of 0.050 kg
per metric ton of feed (dry basis) to the kiln (0.10 Ib per
ton) .
(2) Exhibit 10 percent opacity, or greater.
(c) On and after the date on which the performance test
required to be conducted by § 60.8 is completed, no owner or
operator subject to the provisions of this subpart shall cause
A-9
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to be discharged into the atmosphere from any affected facility
other than the kiln and clinker cooler any gases which exhibit
10 percent opacity, or greater.
§ 60.63 Monitoring of operations.
(a) The owner or operator of any portland cement plant
subject to the provisions of this part shall record the
daily production rates and kiln feed rates.
§ 60.64 Test methods and procedures.
(a) The reference methods in Appendix A to this part,
except as provided for in § 60.8(b), shall be used to deter-
mine compliance with the standards prescribed in § 60.62 as
follows:
(1) Method 5 for the concentration of particulate matter
and the associated moisture content;
(2) Method 1 for sample and velocity traverses;
(3) Method 2 for velocity and volumetric flow rate; and
(4) Method 3 for gas analysis.
(b) For Method 5, the minimum sampling time and minimum
sample volume for each run, except when process variables or
other factors justify otherwise to the satisfaction of the '
Administrator, shall be as follows:
(1) 60 minutes and 0.85 dscm (30.0 dscf) for the kiln.
(2) 60 minutes and 1.15 dscm (40.6 dscf) for the clinker
cooler.
(c) Total kiln feed rate (except fuels), expressed in
metric tons per hour on a dry basis, shall be determined
during each testing period by suitable methods; and shall be
confirmed by a material balance over the production system.
(d) For each run, particulate matter emissions, expressed
in g/metric ton of kiln feed, shall be determined by dividing
the emission rate in g/hr by the kiln feed rate. The emission
rate shall be determined by the equation, g/hr=Q x c, where
Qs equals the volumetric flow rate of the total Iffluent in
dscm/hr as determined in accordance with paragraph (a)(3) of
this section, and c equals particulate concentration in
g/dscm as determined in accordance with paragraph (a)(1) of
this section.
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APPENDIX - TEST METHODS
Method 1 - Sample and Velocity Traverses
For Stationary Sources
1. Principle and Applicability
1.1 Principle. A sampling site and the number of
traverse points are selected to air in the extraction of a
representative sample.
1.2 Applicability. This method should be applied only
when specified by the test procedures for determining
compliance with the New Source Performance Standards.
Unless otherwise specified, this method is not intended to
apply to gas streams other than those emitted directly to
the atmosphere without further processing.
2. Procedure
2.1 Selection of a sampling site and minimum number of
traverse points.
2.1.1 Select a sampling site that is at least eight
stack or duct diameters downstream and two diameters upstream
from any flow disturbance such as a bend, expansion, contraction,
or visible flame. For rectangular'-crdss section, determine
an equivalent diameter from the following equation:
equivalent diameter - 2 jffl equation M
2.1.2 When the above sampling site criteria can be
met, the minimum number of traverse points is twelve (12).
2.1.3 Some sampling situations render the above sampling
site criteria impractical. When this is the case, choose a
convenient sampling location and use Figure 1-1 to determine
the minimum number of traverse points. Under no conditions
should a sampling point be selected within 1 inch of the
stack wall. To obtain the number of traverse points for
stacks or ducts with a diameter less than 2 feet, multiply
the number of points- obtained from Figure 1-1 by 0.67.
2.1.4 To use Figure 1-1 first measure the distance
from the chosen sampling location to the nearest upstream
and downstream disturbances. Determine the corresponding
number of traverse points for each distance from Figure 1-1.
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NUMBER OF DUCT DIAMETERS UPSTREAM"
(DISTANCE A)
FROM POINT OF ANY TYPE OF
DISTURBANCE IBEND. EXPANSION, CONTRACTION. ETC.)
NUMBER OF DUCTD1AHETERS DOWNSTREAM'
(DISTANCES)
Figure 1-1. Minimum number of traverse points.
Select the higher of the two numbers of traverse points, or
a greater value, such that for circular stacks the number is
a.multiple of 4, and for rectangular stacks the number
follows the criteria of section 2.2.2.
2.2 Cross-sectional layout and location of traverse
points.
2.2.1 For circular stacks Locate the traverse points
on at least two diameters .according to Figure 1-2 and Table
1-1. The traverse axes shall divide the stack cross section
into equal parts.
Figure 1-2. Cross section of circular stack divided into
12 equal areas, showing location of traverse points at
centroid of each area.
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Table 1-1. Location of traverse points in circular stacks
(Percent of stack diameter from inside wall to traverse point)
Traverse
point
number
on a
diameter
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
Number of traverse points on a diameter
2
'14.6
85.4
4
6.7
25.0
75.0
93.3
6
4.4
14.7
29.5
70.5
85.3
95.6
8
3.3
10.5
19.4
32.3
67.7
80.6
89.5
96.7
10
2.5
8.2
14.6
22.6
34.2
65.8
77.4
85.4
91.8
97.5
12
2.1
6.7
11.8
17.7
25.0
35.5
64.5
65.0
82.3
88.2
93.3
97.9
14
1.8
5.7
9.9
14.6
20.1
26.9
36.6
63.4
73.1
79.9
85.4
90.1
94,3
98.2
16
T.6
4.9
8.5
12.5
16.9
22.0
23.3
37.5
62.5
71.7'
78.0
83.1
87.5
91.5
95.1
98.4
18
1.4
4.4
7,5
10.9
14.6
18.8
23.6
29.6
38.2
61.8
70.4
76.4
81.2
85.4
89.1
92.5
95.6
98.6
20
1.3
3.9
6.7
9.7
12.9
16.5
20.4
25.0
30.6
38.8
61.2
69.4
75.0
79.6
83.5
87.1
90.3
93.3
96.1
98.7
22
1.1
3.5
6.0
8.7
11.6
14.6
18.0
21.8
26.1
31.5
39.3
60.7
68.5
73.9
78.2
82.0
85.4
83.4
91.3
94.0
96.5
93.9
24
1.1
3.2
5.5
7.9
10.5
13.2
16.1
19.4
23.0
27.2
32.3
39.3
60.2
67.7
72.8
77.0
80.6
83.9
86.8
89.5
92.1
94.5
S6.8
98.9
2.2.2 For rectangular stacks divide the cross section
into as many equal rectangular areas as traverse points,
such that the ratio of the length to the width of the elemental
areas is between one and two. Locate the traverse points at
the centroid of each equal area according to Figure 1-3.
(0
J
o
o
•
o
L J
0
o
0
c
0
_ _____
o
o
Figure 1-3. Cross section of rectangular stack divided into
12 equal areas, with traverse points at eentroid of each area,
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3. References
Determining Dust Concentration in a Gas Stream, ASME
Performance Test Code #27, New York, N.Y., 1957.
Devorkin, Howard, et al., Air Pollution Source Testing
Manual, Air Pollution Control District, Los Angeles, Cali-
fornia, November 1963.
Methods for Determination of Velocity, Volume, Dust .and
Mist Content of Gases, Western Precipitation Division of Joy
Manufacturing Co., Los Angeles, California, Bulletin WP-50,
1968.
Standard Method for Sampling Stacks for Particulate
Matter, In: 1971 Book of ASTM Standards, Part 23, Philadelphia,
Pennsylvania, 1971, ASTM Designation D-2928-71.
Method 2 - Determination of Stack Gas Velocity
and Volumetric Flow Rate (Type S Pitot Tube)
1. Principle and applicability
1.1 Principle. Stack gas velocity is determined from
the gas density and from measurement of the velocity head
using a Type S (Stauscheibe or reverse type) pitot tube.
1.2 Applicability. This method should be applied only
when specified.by the test procedures for determining
compliance with the New Source Performance Standards.
2. Apparatus . .
2.1 Pitot tube - Type S (Figure 2-1), or equivalent,
with a coefficient within +5% over the working range.
2.2 Differential pressure gauge - Inclined manometer,
or equivalent, to measure velocity head to within 10% of the
minimum value.
2.3 Temperature gauge - Thermocouple or equivalent
attached to the pitot tube to measure stack temperature to
within 1.5% of the minimum absolute stack temperature.
2.4 Pressure gauge - Mercury-filled U-tube manometer,
or equivalent, to measure stack pressure to within 0.1 in.
Hg.
2.5 Barometer - To measure atmospheric pressure to
within 0.1 in. Hg.
2.6 Gas analyzer - To analyze gas composition for
determining molecular weight.
2.7 Pitot tube - Standard type, to calibrate Type S
pitot tube.
3. Procedure
3.1 Set up the apparatus as shown in Figure 2-1. Make
sure all connections are tight and leak free. Measure the
velocity head and temperature at the traverse points specified
by Method 1.
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PIPE COUPLING
TUBING ADAPTER
Figure 2-1. Pitot tube-manometer assembly.
3.2 Measure the static pressure in the stack.
3.3 Determine the stack gas molecular weight by gas
analysis and appropriate calculations as indicated in Method
3.
4.
Calibration
4.1 To calibrate the pitot tube, measure the velocity
heat at some point in a flowing gas stream with both a Type
S pitot tube and a standard type pitot tube with known
coefficient. Calibration should be done in the laboratory
and the velocity of the flowing gas stream should be varied
over the normal working range. It is recommended that the
calibration be repeated after use at each field site.
4.2 Calculate the pitot tube coefficient using equation
2-1.
where:
C
equation 2-1
test
std
= Pitot tube coefficient of Type S pitot tube.
= Pitot tube coefficient of standard type pitot
tube (if unknown, use 0.99)
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A = Velocity head measured by standard type pitot
"std tube.
A = Velocity head measured by Type S pitot tube.
ptest
4.3 Compare the coefficients of the Type S pitot tube
determined first with one leg and then the other pointed
downstream. Use the pitot tube only if the two coefficients
differ by no more than 0.01.
5. Calculations
Use equation 2-2 to calculate the stack gas velocity.
> 0_| 1//2when these units are used.
p sec. lib. mole- R/
C = Pitot tube coefficient, dimensionless.
(T ) = Average absolute stack gas temperature, °R.
s avg .
(/Ap) = Average velocity head of stack gas, inches
avg' H20 (see Figure 2-2).
P = Absolute velocity head of stack gas (wet basis) ,
Ib/lb-mole.
M = Molecular weight of stack gas (wet basis), lb./lb.-
s mole M, (1-B )+18B
d wo wo
M, = Dry molecular weight of stack gas (from Method 3).
B = Proportion by volume of water vapor in the gas
w stream (from Method 4) .
Figure 2-2 shows a sample recording sheet for velocity
traverse data. Use the averages in the last two columns of
Figure 2-2 to determine the average stack gas velocity from
Equation 2-2.
A-16
-------
PLANT
DATE
RUN NO.
STACK DIAMETER, in.
BAROMETRIC PRESSURE, in. Hg.
STATIC PRESSURE IN.STACK (P ), in. Hg.
y • «•
OPERATORS
SCHEMATIC OF STACK
CROSS SECTION
Traverse point
number
Velocity head,
in. H20
Stack Temperature
AVERAGE:
Figure 2-2. Velocity traverse data,
A-17
-------
Use Equation 2-3 to calculate the stack gas volumetric
flow rate.
= 3600(1-B)VA
WOS
where:
T,
std
(T.)
s'avy.
P,
s
equation 2-3
std i
Q = Volumetric flow rate, dry basis,' standard conditions,
S ft.3/hr.
2
A = Cross-sectional area of stack, ft
T . , = Absolute temperature at standard conditions,
Std 530°R.
P , = Absolute pressure at standard conditions,
29.92 inches Hg.
6. References
Mark, L. S., Mechanical Engineers' Handbook, McGraw-
Hill Book Co., Inc., New York, N.Y., 1951.
Perry, J. H., Chemical Engineers' Handbook, McGraw-Hill
Book Co., Inc., New York, N.Y., 1960.
Shigehara, R. T. , W. F. Todd, and W. S. Smith, Significance
of Errors in Stack Sampling Measurements. Paper presented
at the Annual Meeting of the Air Pollution Control Associa-
tion, St. Louis, Missouri, June 14-19, 1970.
Standard Method for Sampling Stacks for Particulate
Matter, In: 1971 Book of ASTM Standards, Part 23, Philadelphia,
Pennsylvania, 1971, ASTM Designation D-2928-71.
Vennard J. D., Elementary Fluid Mechanics, John Wiley &
Sons, Inc., New York, N.Y., 1947.
Method 3 - Gas Anaylsis for Carbon Dioxide,
Excess Air, and Dry Molecular Weight
1. Principle and applicability
1.1 Principle. An integrated or grab gas sample is
extracted from a sampling point and.analyzed for its components
using an Orsat analyzer.
1.2 Applicability. This method should be applied only
when specified by the test procedures for determining
compliance with the New Source Performance Standards. The
test procedure will indicate whether a grab sample or an
integrated sample is to be used.
2. Apparatus
2.1 Grab sample (Figure 3-1).
A-18
-------
PROBE
PR'
FLEXIBLE TUBING
TO ANALYZER
FILTER (GLASS WOOL)
SQUEEZE BULB
Figure 3-1. Grab-sampling train.
2.1.1 Probe - Stainless steel or Pyrex glass, equipped
with a filter to remove particulate matter.
2.1.2 Pump - One-way squeeze bulb, or equivalent, to
transport gas sample to analyzer.
2.2 Integrated sample (Figure 3-2).
RATE METER
VALVE
AIR-COOLED CONDENSER / PUMP
PROBE
FILTER (GLASS WOOL)
QUICK DISCONNECT
RIGID CONTAINER'
Figure 3-2. Integrated gas - sampling train.
2.2.1 Probe - Stainless steel or Pyrex glass, equipped
with a -filter to remove particulate matter.
2.2.2 Air-cooled condenser or equivalent - To remove
any excess moisture.
2.2.3 Needle valve - To adjust flow rate.
2.2.4 Pump - Leak-free, diaphragm type, or equivalent,
to pull gas.
2.2.5 Rate meter - To measure a flow range from 0 to
0.035 cfm.
Trade name.
A-19
-------
2.2.6 Flexible bag - Tedlar, or equivalent, with a
capacity of 2 to 3 cu. ft. Leak test the bag in the laboratory
before using. >
2.2.7 Pitot tube - Type S, or equivalent, attached to
the probe so that the sampling flow rate can be regulated
proportional to the stack gas velocity when velocity is
varying with time or a sample traverse is conducted.
2 . 3 Analysis
2.3.1 Orsat analyzer, or equivalent.
3. Procedure
3.1 Grab sampling
3.1.1 Set up the equipment as shown in Figure 3-1,
making sure all connections are leak-free. Place the probe
in the stack at a sampling point and purge the sampling.
line.
3.1.2 Draw sample into the analyzer.
3.2 Integrated Sampling
3.2.1 Evacuate the flexible bag. Set up the equipment
as shown in Figure 3-2 with the bag disconnected. Place the
probe in the stack and purge the sampling line. Connect the
bag, making sure that all connections are tight and that
there are no leaks.
3.2.2 Sample at a rate proportional to the stack
velocity.
3. 3 Analysis
3.3.1 Determine the CO', O_ , and CO concentrations as
soon as possible. Make as many passes as are necessary to
give constant readings. If more than ten passes are necessary,
replace the absorbing solution.
3.3.2 For grab sampling, repeat the sampling and
analysis until three consecutive samples vary no more than
0.5 percent by volume for each component being analyzed.
3.3.3 For integrated sampling, repeat the analyses of
the sample until three consecutive analyses vary no more
than 0.2 percent by volume for each component being analyzed.
4. Calculations
4.1 Carbon dioxide. Average the three consecutive-
runs and report the results to the nearest 0.1% C02-
4.2 Excess air. Use Equation 3-1 to calculate excess
air, and average the runs. Report the result to the nearest
0.1% excess air.
(%0o) - 0.5(%CO)
X 100 equation 3-I
0.264(%N9) - (%07) + 0.5(%CO)
Trade name.
A-20
-------
where:
%EA = Percent excess air.
%0_ = Percent oxygen by volume, dry basis.
%N~ = Percent nitrogen by volume, dry basis.
%CO•= Percent carbon monoxide by volume, dry basis.
0.264 = Ratio of oxygen to nitrogen in air by volume.
4.3 Dry molecular weight. Use Equation 3-2 to calculate
dry molecular weight and average the runs. Report the
result to the nearest tenth.
Md = 0.44(%C02) + 0.32(%02) + 0.28(%N2 + % CO) equation 3-2
where:
M, = Dry molecular weight, Ib./lb-mole.
%CO« = Percent carbon dioxide by volume, dry basis.
%O,j =. Percent oxygen by volume, dry basis.
%Np = Percent nitrogen by volume, dry basis.
0.44 = Molecular weight of carbon dioxide divided by
100.
0.32 = Molecular weight of oxygen divided by 100.
0.28 = Molecular weight of nitrogen and CO divided by
100.
5. References
Altshuller, A. P., et al., Storage of Gases and Vapors
in Plastic Bags, Int. J. Air & Water Pollution, 6:75-81,
1963.
Conner, William D., and J. S. Nader, Air Sampling with
Plastic Bags, Journal of the American Industrial Hygiene
Association, 25:291-297, May-June 1964.
Devorkin, Howard, et al. , Air Pollution Source Testing
Manual, Air Pollution Control District, Los Angeles, Cali-
fornia, November 1963.
A-21
-------
• - Method-4 - Determination of Moisture in-Stack Gases •-
1. Principle and applicability
1.1 Principle. Moisture is removed from the gas
stream, condensed, and determined volumetrically.
1.2 Applicability. This method is applicable for the
determination of moisture in stack gas only when specified
by test procedures for determining compliance with New
Source Performance Standards. This method does not apply
when liquid droplets are present in the gas stream^ and the
moisture is subsequently used in the determination of stack
gas molecular weight.
Other methods such as drying tubes, wet bulb-dry bulb
techniques, and volumetric condensation techniques may be
used.
2. Apparatus
2.1 Probe - Stainless steel or Pyrex glass sufficiently
heated to prevent condensation and equipped with a filter to
remove particulate matter.
2.2 impingers - Two midget impingers, each with 30 ml.
capacity, or equivalent.
2.3 Ice bath container - To condense moisture in
impingers.
2.4 Silica gel tube (optional) - To protect pump and
dry gas meter.
2.5 Needle valve - To regulate 'gas flow rate.
2.6 Pump - Leak-free, diaphragm .type, or equivalent,
to pull gas through train.
2.7 Dry gas meter - To measure to within 1% of the
total sample volume.
2.8 Rotameter - To measure a flow range from 0 to 0.1
c.f.m.
2.9 Graduated cylinder - 25 ml.
2.10 Barometer - Sufficient to read to within 0.1 inch
Hg.
2.11 Pitot tube - Type S, or equivalent, attached to
probe so that the sampling flow rate can be regulated
proportional to the stack ga's velocity when velocity "is* " '
varying with time or a sample traverse is conducted.
If liquid droplets are present in the gas stream, assume
the stream to be saturated, determine the average stack
gas temperature by traversing according to Method 1,
and use a psychrometric chart to obtain an approximation
of the moisture percentage.
2
Trade name.
A-22
-------
3.
Procedure
3.1 Place exactly 5 ml. distilled water in each impinger.
Assemble the apparatus without the probe as shown in Figure
4-1. Leak check by plugging the inlet to the first impinger
and drawing a vacuum. Insure that flow through the dry gas
meter is less than 1% of the sampling rate.
HEATED PROBi
FILTER '(GLASS WOOL)
SILICA GEL TUBE
VALVE
ROTAMETER
ICE BATH
rflDGET IMPINGERS
PUMP
DRY G'AS METER
Figure 4-1. Moisture-sampling train.
3.2 Connect the probe and sample at a constant rate of
0.075 c.f".m. or at a rate proportional to the stack gas
velocity. Continue sampling until the dry gas meter registers
1 cubic foot or until visible liquid droplets are carried
over from the first impinger to the second. Record temperature,
pressure, and dry gas meter readings as required by Figure 4-2.
LOCATION.
TEST
DATE
OPERATOR
COMMENTS
BAROMETRIC PRESSURE
CLOCK TIME
GAS VOLUME THROUGH
METER, (Vm),
ft3
ROTAMETER SETTING
1t3/min
METER TEMPERATURE.
•f
Figure 4-2. Field moisture determination,
A-23
-------
3.3 After collecting the sample, measure the volume
increase to the nearest 0.5 ml.
4 . Calculations
4.1 Volume of water vapor collected.
Vwc » 2 - 0,0474 (Vf - Vj> aquation 4-,
where: '«* H2°
V = Volume of water vapor collected (standard)
conditions), cu.ft.
Vf = Final volume of impinger contents, ml.
V. = Initial volume of impinger contents, ml.
R = Ideal gas constant, 21.83 inches Hg - cu. ft . /Ib.mole
p.. _ = Density of water, 1 g./ml.
n«U
T . , = Absolute temperature at standard conditions,
Std 530°R.
P , = Absolute pressure at standard conditions, 29.92
sta inches Hg.
MH _. •= Molecular weight of water, 18 Ib./lb.-mole.
4.2 Gas volume.
V = V
me m
m
std
T.
std
T
where:
m
o
= 17.71
R
in. Hg
m m
T
m
equation 4-2
V = Dry gas volume through meter at standard conditions,
mc cu.ft.
V = Dry gas volume measured by meter, cu.ft.
P = Barometric pressure at the dry gas meter, inches
m Hg.
P , = Pressure at standard conditions, 29.92 inches
T . , = Absolute temperature at standard conditions,
Std 530°R.
T .= Absolute temperature at meter (°F+460), °R.
m
A-24
-------
4.3 Moisture content.
- + (0'025)
vwc vmc vwc me
where :
B = Proportion by volume of water vapor in the gas
stream, dimensibnless.
V = Volume of water vapor collected (standard conditions) ,
wc cu.ft.
V = Dry gas volume through meter (standard conditions) ,
me J _;• 3
cu. f t .
B = Approximate volumetric proportion of water vapor
in the gas stream leaving the impingers, 0.025.
5. References
Air Pollution Engineering Manual, Danielspn, J. A.
(ed.), U.S. DHEW, P.HS , National Center for Air Pollution
Control, Cincinnati, Ohio, PHS Publication No. 999-AP-40,
1967.
Devorkin, Howard, et al . , Air Pollution Source Testing
Manual, Air Pollution Control District, Los Angeles, Cali-
fornia, November 1963.
Methods for Determination of Velocity, Volume, Dust and
Mist Content of Gases, Western Precipitation Division of Joy
Manufacturing Co., Los Angeles, California, Bulletin WP-50,
1968.
Method 5 - Determination of Particulate
Emissions From Stationary Sources
1. Principle and applicability
1.1 Principle. Particulate matter is withdrawn
isokinetically from the source and its weight is determined
gravimetrically after removal of uncombined water.
1.2 Applicability. This method is applicable for the
determination of particulate emissions from stationary
sources only when specified by the test procedures for
determining compliance with New Source Performance Standards.
2 . Apparatus
2.1 Sampling train. The design specifications of the
particulate sampling train used by EPA (Figure 5-1) are
described in APTD-0581. Commercial models of this train are
available.
A-25
-------
IMPWGER TRAIN OPTIONAL. MAY BE REPLACED
BY AN EQUIVALENT CONDENSER
HEATED ARE A T-ILTER HOLDER / THERMOMETER CHECK
PROBE "fT" STACK
\Jh_WALL
fcr =
^ 7l._,
REVERSE-TYPE
PITOT TUBE
IMPINGERS ICE BATH
BY-PASS VALVE
VALVE
,VACUUM
LINE
THERMOMETERS
VACUUM
GAUGE
MAIN VALVE
DRY TEST METER AIR-TIGHT
PUMP
Figure 5-1. Particulate-sampling train.
2.1.1 Nozzle - Stainless steel (316) with sharp,
tapered leading edge. ,
2.1.2 Probe - Pyrex glass with a heating system
capable of maintaining a minimum gas temperature of 250°F at
the exit end during sampling to prevent condensation from
occurring. When length limitations (greater than about 8
ft.) are encountered at temperatures less than 600°F, Incoloy
825 , or equivalent, may be used. Probes for sampling gas
streams at temperatures in excess of 600°F must have been
approved by the Administrator.
2.1.3 Pitot tube - Type S, or equivalent, attached to
probe to monitor stack gas velocity.
2.1.4 Filter holder - Pyrex^ glass with heating system
capable of maintaining minimum temperature of 225°F.
2.1.5 Impingers/Condenser - Four impingers connected
in series with glass ball joint fittings. The first, third,
and fourth impingers are of the Greenburg-Smith design,
modified by replacing the tip with a 1/2-inch ID glass tube
extending to one-half inch from the bottom of the flask.
The second impinger is of the Greenburg-Smith design with
the standard tip. A condenser may be used in place of the
impingers provided that the moisture content of the stack
gas can still be determined.
2.1.6 Metering system - Vacuum gauge, leak-free pump,
thermometers capable of measuring temperature to within 5°F,
dry gas meter with 2% accuracy, and related equipment, or
equivalent, as required to maintain an isokinetic sampling
rate and to determine sample volume.
2.1.7 Barometer - To measure atmospheric pressure to
+0.1 inches Hg.
Trade name.
A-26
-------
2.2 Sample recovery.
2.2.1 Probe brush - At least as long as probe.
2.2.2 Glass wash bottles - Two.
2.2.3 Glass sample storage containers.
2.2.4 Graduated cylinder - 250 ml.
2.3 Analysis.
2.3.1 Glass weighing dishes.
2.3.2 Desiccator.
2.3.3 Analytical balance - To measure to j^O.l mg.
3. Reagents
3.1 Sampling ,
3.1.1 Filters - Glass fiber, MSA 1106 BH , or equivalent,
numbered for identification and preweighed.
3.1.2 Silica gel - Indicating type, 6-16 mesh, dried
at 175°C (350°F) for 2 hours.
3.1.3 Water.
3.1.4 Crushed ice.
3.2 Sample recovery.-
3.2.1 Acetone - Reagent grade.
3.3 Analysis
3.3.1 Water. ,
3.3.2 Desiccant - Drierite, indicating.
4. Procedure
4.1 Sampling
.4.1.1 After selecting the sampling site and the minimum
number of sampling points, determine the stack pressure,
temperature, moisture, and range of velocity head.
4.1.2 Preparation of collection train. Weigh to the
nearest gram approximately 200 g. of silica gel.. Label a
filter of proper diameter, desiccate for at least 24 hours
and weigh to the nearest 0.5 mg. in a room where the relative
humidity is less than 50%. Place 100 ml. of water in each
of the first two impingers, leave the third impinger empty,
and place approximately 200 g. of preweighed silica gel in
the fourth impinger. Set up the train without the probe as
in Figure 5-1. Leak check the sampling train at the sampling
site by plugging up the inlet to the filter holder and pulling
a 15 in. Hg vacuum. A leakage rate not in excess of 0.02
c.f.m. at a vacuum of 15 in. Hg is acceptable. Attach the
probe and adjust the heater to provide a gas temperature of
about 250°F at the probe outlet. Turn on the filter heating
system. Place crushed ice around the impingers. Add more
ice during the run to keep the temperature of the gases
leaving the last impinger as low'as possible and preferably
at 70°F or less. Temperatures above 70°F may result in
damage to the dry gas meter from either moisture condensation
or excessive heat.
Trade name.
Dry using Drierite1 at 70°F +10°F.
A-27
-------
4.1.3 Particulate train operation. For each run,
record the data required on the example sheet shown in
Figure 5-2. Take readings at each sampling point, at least
every 5 minutes, and when significant changes in stack
conditions necessitate additional adjustments in flow rate.
To begin sampling, position the nozzle at the first traverse
point with the tip pointing directly into, the gas stream.
Immediately start the pump and adjust the flow to isokinetic
conditions. Sample for at least 5 minutes at each traverse
point; sampling time must be the same for each point.
Maintain isokinetic sampling throughout the sampling period.
Nomographs are available which aid in the rapid adjustment
of the sampling rate without other computations. APTD-0576
details the procedure for using these nomographs. Turn off
the pump at the conclusion of each run and record the final
readings. Remove the probe and nozzle from the stack and
handle in accordance with the sampling recovery process
described in section 4.2.
flAMT
IOCATICM
orcum
DAIT
KM no.
UTTWBOXHO.
KTUUH
AMBIENT TEMMHATURE_
UUO4CTJUC MttBU*X_
ABUXO vasTua.«_
HtATEB BOt SCTTINO
PSOK LENGTH. •*
NO2O.E DIAWTEIL I*.—
EATfR SETTING.
SCHIMATIC Of STAC* CROSS SECTION
THAvtra four
Nuuea
TOTAL
SAunna
tn<
M.ri*.
AVERAGE
STATIC
mssuc
(Tsl. b. >«.
STACt
TIUPtMTUK
Wr
wiccm
HUC
i«'si.
mssLn«
OlfTIHtNIlAi
ACROSS
cm ice
WTI»
I* ID.
wiV)
1
GASSAIVU
va.(Mt
(Vml. fr1
CAS SAlUt ttl»!«ATUW
AT Dm GAS MfTEA
ITACT
"• !•.'••'-
|_A,.i.
ouaii
"•«,'••'
A.,.
AVI,.
SAUF\E BOX
TlWERAFVRt.
•F
TIWEPITUBE
OF Cfci
LEIVINC
CCmOE«E«OB
LAST UVINCtR
•F
Figure 5-2. Particulate field data.
4.2 Sample recovery. Exercise care in moving the
collection train from the test site to the sample recovery
area to minimize the loss of collected sample or the gain of
extraneous particulate matter. Set aside a portion of the
acetone used in the sample recovery as a blank for analysis.
Measure the volume of water from the first three impingers,
then discard. Place the samples in containers as follows:
Container No. 1. Remove the filter from its holder,
place in this container, and seal.
A-28
-------
Container No. 2. Place loose particulate matter and
acetone washings from all sample-exposed surfaces prior to
the filter in this container and seal. Use a razor blade,
brush, or rubber policeman to lose adhering particles.
Container No. 3. Transfer the silica gel from the
fourth impinger to the original container and seal. Use a
rubber policeman as an aid in removing silica gel from the
impinger.
4.3 Analysis. Record the data required on the example
sheet shown in'Figure 5-3. Handle each sample container as
follows:
PLANT.
DATE_
RUN N0._
CONTAINER
NUMBER
1
2
TOTAL
WEIGHT OF PARTICULATE COLLECTED.
mg
FINAL WEIGHT
I>*<^1
TARE WEIGHT
ZxCl
WEIGHT GAIN
FINAL
INITIAL
LIQUID COLLECTED
TOTAL VOLUME COLLECTED
VOLUME OF LIQUID
WATER COLLECTED
IMPINGER
VOLUME,
ml
SILICA GEL
WEIGHT,
g
9" ml
CONVERT WEIGHT OF WATER TO VOLUME BY DIVIDING TOTAL WEIGHT
INCREASE BY DENSITY OF WATER. (1 g. ml):
(1 g/ml)
Figure 5-3. Analytical data.
A-29
-------
Container No. 1. Transfer the filter and any loose
particulate matter from the sample container to a tared
.glass weighed dish, desiccate, and dry to a constant weight.
Report results to the nearest 0.5 mg. ••
Container No. 2. Transfer the acetone .washings to a
tared beaker and evaporate to dryness at ambient temperature
and pressure. Desiccate and dry to a constant weight.
Report results to the nearest 0.5 mg.
Container No. 3. Weigh the spent silica gel and report
to the nearest gram.
5. Calibration
Use methods and equipment which have been approved by
the Administrator to calibrate the orifice meter, pitot
tube, dry gas meter, and probe heater. Recalibrate after
each test series.
6. Calculations
6.1 Average dry gas meter temperature and average
orifice pressure drop. See data sheet (Figure 5-2).
6.2 Dry gas volume. Correct the sample volume measured
by the dry gas meter to standard conditions (70°F, 29.92
inches Hg) by using Equation 5-1.
V
where:
mstd
m
T
std
T
m
rbar'
AH
13.6
P,
std
17.71
>R
in.Hg
V
m
rbar
AH
13.6
T
m
equation 5-1
V = Volume of gas sample through the dry .gas meter
std (standard conditions), cu. ft.
V = Volume of gas sample through the dry gas meter
(meter conditions), cu. ft.
T , , = Absolute temperature at standard conditions;
sta 530°R. " -
T = Average dry gas meter temperature, °R.
P, = Barometric pressure at the orifice meter,
inches Hg. ....
AH = Average pressure drop across the orifice meter,
inches H-O.
13.6 - Specific gravity of mercury.
P , = Absolute pressure at'standard conditions, 29.92
inches Hg.
A-30
-------
6.3 Volume of water vapor.
/wstd = Vlc 1MH,0
std
0.
cu. ft.
V1
equation 5-2
where:
V
w
= Volume of water vapor in the gas sample (standard
std conditions), cu. ft.
V, = Total volume of liquid collected in impingers and
c silica gel (see Figure 5-3) , ml.
u _
H~U
= Density of water, 1 g./ml.
Mu _. = Molecular weight of water, 18 Ib. /Ib.-mole.
rl « U
R = Ideal gas constant, 21.83 inches Hg-cu. ft./lb.-
mole-°R.
T . , = Absolute temperature at standard conditions,
st 530°R.
P , = Absolute pressure at standard conditions, 29.92
inches Hg.
6.4 Moisture content.
V.,
w,
B,
std
where:
wo v + v
mstd wstd
equation 5-3
B = Proportion by volume of water vapor in the gas
wo
V.
w
V
m
stream, dimensionless.
= Volume of water in the gas sample (standard
std conditions), cu. ft.
= Volume of gas sample through the dry gas meter
std (standard conditions), cu. ft.
6.5 Total particulate weight. Determine the total
particulate catch from the sum of the weights on the analysis
data sheet (Figure 5-3).
6.6 Concentration.
6.6.1 Concentration in gr./s.c.f.
V
mstd,
equation 5-4
A-31
-------
where:
c' '.= Concentration of particulate matter in stack gas,
gr./s.c.f., dry basis.
M = Total amount of particulate matter collected, mg.
V = Volume of gas sample through dry gas meter
std (standard conditions), cu. ft.
6.6.2 Concentration in Ib./cu. ft.
/ 1
- M.
1453,600 mg. " R M
; = ^~v = 2.205 XIO'6 ^-JL-
mstd mstd
equation 5-5
where:
C := Concentration of particulate matter in stack
gas, Ib./s.c.f., dry basis.
453,600 = Mg/lb.
M = Total amount of particulate matter collected,
mg,
V = Volume of gas sample through dry gas meter
mstd (standard conditions), cu. ft.
6.7 Isokinetic variation.
c 2 _Vj
WIu n T.
m
13.6
0VsPsAn
X100
1.667
mm.
sec.
where:
M
v
m
H
AH
equation 5-6
I = Percent of isokinetic sampling.
= Total volume of liquid collected in.impingers
"c and silica gel (See Fig. 5-3), ml.
_ = Density of water, 1 g./ml.
R = Ideal gas constant, 21.83 inches Hg-cu. ft./
Ib. mole-°R.
A-32
-------
M0 n = Molecular weight of water, 18 Ib./lb.-mole.
H « U
V = Volume of gas sample through the gas meter
m (meter conditions), cu. ft.
T = Absolute average dry gas meter temperature
m (See Figure 5-2), °R.
P, = Barometric pressure at sampling site,
inches Hg.
AH = Average pressure drop across the orifice •
(see Fig. 5-2), inches HO.
T = Absolute average stack gas temperature
5 (see Fig. 5-2), °R.
0 = Total sampling time, min.
V = Stack gas velocity calculated by Method 2,
Equation 2.2, ft./sec.
P = Absolute stack gas pressure, inches Hg.
o
A = Cross-sectional area of nozzle, sq. ft.
6.8 Acceptable results. The following range sets the
limit on acceptable isokinetic sampling results:
If 90% <_! £110%, the results are acceptable, otherwise,
reject the results and repeat the test.
7. Reference.
Addendum to Specifications for Incinerator Testing at
Federal Facilities, PHS, NCAPC, Dec. 6, 1967.
Martin, Robert M., Construction Details of Isokinetic
Source Sampling Equipment, Environmental Protection Agency,
APTD-0581.
Rom, Jerome J., Maintenance/ Calibration, and Operation
of Isokinetic Source Sampling Equipment, Environmental
Protection Agency, APTD-0576.
Smith, W. S., R.T. Shigehara, and W. F. Todd, A Method
of Interpreting Stack Sampling Data, Paper presented at the
63rd Annual Meeting of the Air Pollution Control Associa-
tion, St. Louis, Mo., June 14-19, 1970.
Smith, W. S., et.al., Stack Gas Sampling Improved and
Simplified with New Equipment, APCA paper .No. 67-119, 1967.
Specifications for Incinerator Testing at Federal
Facilities, PHS, NCAPC, 1967.
A-33
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APPENDIX B
SUGGESTED CONTENTS OF STACK TEST REPORTS
B-l
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CONTENTS OF STACK TEST REPORTS
In order to adequately assess the accuracy of any test
report the basic information listed in the following suggested
outline is necessary:
1. Introduction. Background information pertinent to the
test is presented in this section. This information
shall include, but not be limited to, the following:
a. Manufacturer's name and address.
b. Name and address of testing organization.
c. Names of persons present, dates and location of
test.
d. Schematic drawings of the process being tested
,showing emission points, sampling sites, and stack
cross section with the sampling points labeled and
dimensions indicated.
2. Summary. This section shall present a summary of test
findings pertinent to the evaluation of the process
with respect to the applicable emission standard. The
information shall include, but not be limited to, the
following:
a. A summary of emission rates found.
b. Isokinetic sampling rates achieved if applicable.
c. The operating level of the process while the tests
were conducted.
3. Procedure. This section shall describe the procedures
used and the operation of the sampling train and process
during the tests. The information shall include, but
not be limited to, the following:
a. A schematic drawing of the sampling devices used
with each component designated and explained in a
legend.
b. A brief description of the method used to operate
the sampling train and procedure used to recover
samples.
B-2
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4. Analytical Technique. This section shall contain a
brief description of all analytical techniques used to
determine the emissions from the source.
5. Data and Calculations. This section shall include all
data collected and calculations. As a minimum, this
section shall contain the following information:
a. All field data collected on raw data sheets.
b. A log of process and sampling train operations.
c. Laboratory data including blanks, tare weights,
and results of analysis.
d. All emission calculations.
6. Chain of Custody. A listing of the chain of custody of
the emission test samples.
7. Appendix:
a. Calibration work sheets for sampling equipment.
b. Calibration or process logs of process parameters.
B-3
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APPENDIX C
VISIBLE EMISSION OBSERVATION FORM
C-l
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FIGURE 9-1
RECORD Of VISUAL DETERMINATION.OF OPACITY
PAGE of
COMPANY
LOCATION
TEST NUMBER.
DATE
TYPE FACILITY^
CONTROL DEVICE
HOURS OF OBSERVATION,
OBSERVER
OBSERVER CERTIFICATION DATE_
OBSERVER AFFILIATION
POINT OF EMISSIONS
HEIGHT OF DISCHARGE POINT
n
i
CLOCK TIME
OBSERVER LOCATION
Distance to Discharge
Direction from Discharge
Height of Observation Point
BACKGROUND DESCRIPTION
WEATHER CONDITIONS
Wind Direction
Wind Speed
Ambient Temperature
SKY CONDITIONS (clear,
overcast, % clouds, etc.)
PLUME DESCRIPTION
Color
Distance Visible
OTHER IJJFOOTIOI!
Initial
-
•;
Final
F
T
t
SUMMARY OF AVERAGE OPACITY
Set
Number
"Hmp
Start-End
Opaciti
Sum
eadlngs ranged from to % opac
'he source was/was not in compliance wit
he time evaluation was made.
"verage
11-y
h .at
-------
COMPANY
LOCATION
TEST NUMBER"
DATE
FIGURE 9-2 OBSERVATION RECORD
OBSERVER
PAGE
TYPE FACILITY ~
POINT OF EHISSMT
O
I
Hr.
.
Min.
0
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28 -
29
0
Seconds
15
JO
4b
STEAM PLUME
(check 1f applicable)
Attached
'
Detached
COMMENTS
v
FIGURE 9-2 0
(Con
COMPANY
LOCATION
TEST
DATE
Hr.
NUMBER
Mln.
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
"59
Seconds
0
Ib
30
rw
4b
>
(cli
A1
n TVv>74
OBSERVATION RECORD
PAGE OF
OBSERVER
TYPE FACILITY ""
POINT OF EMISSlOlir
(FB Doc.74-26150 Filed 11-11-74:8:46 am]
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA 340/1-75-001
3. RECIPIENT'S ACCESSION>NO.
4. TITLE AND SUBTITLE
Inspection Manual for the Enforcement of
New Source Performance Standards: Portland
Cement Plants
5. REPORT DATE
Issuer Februarjy 1 975
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
N. J. Kulujian
9. PERFORMING ORG \NIZATION NAME AND ADDRESS
PEDGo-Environmental Specialists, Inc.
Suite 13, Atkinson Square
Cincinnati, Ohio 45246
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-02-1355
12. SPONSORING AGENCY NAME AND ADDRESS
Environmetnal Protection Agency
Office of Air and Water Programs
Research Triangle Park, North Carolina 27711
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
One of a series of NSPS Enforcement Inspection Manuals
16. ABSTRACT •
This document presents guidelines to enable enforcement personnel
to determine whether new or modified portland cement plants comply
with New Source Performance Standards (NSPS). Key parameters
identified during subsequent inspections to determine the facility's
compliance status. The portland cement process, atmospheric emis-
sions from these processes, and emission control methods are
described. The inspection methods and types of records to be kept
are discussed in detail.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Portland cement
Air pollution control
Verification inspection
Performance tests
New Source Perform-
ance Standards
Enforcement
Emission testing
13 B
14 D
18. DISTRIBUTION STATEMENT
Release unlimited
19. SECURITY CLASS (ThisReport)'
Unclassified
21. NO. OF PAGES
100
20. SECURITY CLASS (This page)
Unclassifi gd
22. PRICE
EPA Form 2220-1 (9-73)
U.S. GOVERNMENT PRINTING OFFICE: 1975-210-810:40
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