SANDERS ENGINEERING &. ANALYTICAL SERVICES, INC.

HYDROGEN CHLORIDE EMISSIONS

TEST REPORT

(VOLUME I)

FOR

NATIONAL CEMENT

KOPPERS MAIN STACK

Ragland, Alabama

May 21 through 24,2002

1568 LEROY STEVENS ROAD

MOBILE. ALABAMA 36695

(251) 633-4120

FAX: (251) 633-2285

E-MAl L: sanders @sandersengineering.com
Sanders Engineering & Analytical Services, Inc.

1. INTRODUCTION

Mobile, AL

Sanders Engineering & Analytical Services, Inc. (SEAS) performed hydrogen

chloride emissions testing for National Cement on the Main Kiln Stack located at

the Ragland, Alabama facility. The testing was conducted with the mill on and

with the mill off on May 21 through 24, 2002. The testing was performed in

accordance with the applicable U.S. EPA procedures specified at 40 CFR, Part 60,

Appendix A, Methods 1, 2, 3a, 4, and 40 CFR, Part 63, Appendix A, Method 321.

Further discussions of the test methods are included later in the report.

The purpose of the testing was to determine plant status pertaining to the

Portland Cement MACT of the U. S. Environmental Protection Agency, and to meet

the necessary requirements contained in the permit to operate issued by the

Alabama Department of Environmental Management. The tests were conducted by

Mr. Spencer Edwards, Mr. Isaac Smith, and Mr. John Wilson of Sanders

Engineering & Analytical Services, Inc., and were coordinated with Mr. Robert

Gunn of National Cement. Mr. Corey Ohme of the Alabama Department of

Environmental Management was also present to observe the testing.

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I National Cement 1 Ragland,AL
2.2. Hydrogen Chloride Testing

The sampling program consisted of volumetric flow rate and hydrogen

chloride emissions testing in compliance with US EPA methods. The following is a

brief description of these types of tests.

The hydrogen chloride sample was extracted from the stack through a glass

probe into a glass fiber filter and transferred to the Fourier Transform Infrared

Spectrometer analyzer through heated teflon sample line and pump, all of which

were maintained at 200 degrees Celsius. A detailed description of the testing

procedures and schematic of the sampling train is presented in Section 7. The

calibrations and dynamic spiking are presented in Appendix C.

Mobile, AL

2 Ragland, AL

2. DESCRIPTION OF SAMPUNG PROGRAM

Sanders Engineering & Analytical Services, Inc.

2.1. Volumetric Flow Rate Testing

The quantitative determination of flow rate was made in accordance with 40

CFR, Part 60, Appendix A, Methods 1, 2, 3a, and 4. This test procedure generally

requires the insertion of a pitot tube into the stack at points representing an equal

cross sectional area of the duct. The data from the pitot tube was recorded on the

field data sheet. The diameter of the stack at the test ports was measured, the area

calculated, and the product of area times velocity gave flow rate (cubic feet per

minute or other denominations). Calibrations of the volumetric flow rate testing

equipment are included in Appendix A. The completed field data sheets are

presented in Appendix B. A detailed description of the testing procedures and

schematic of the sampling train is presented in Section 6.

National Cement
Sanders Engineering & Analytical Services, Inc.

3. SUMMARY AND DISCUSSION OF RESULTS

Mobile, AL

There were no unusual problems experienced during the performance of the

testing during the mill on condition. Three runs were performed during the mill on

condition on May 21, 2002. The results of this testing during the mill on condition

is presented in Table I. One run was performed on May 22, 2002 during mill on

condition at a different fuel rate with no tire derived fuels and no carbon. The

results of this run are presented in Table II. Graphical representations of these

results are presented in Figures 1 and 2. The volumetric flow rate results used in

the calculation of the results during the mill on condition are presented in Tables

III and IV. The hydrogen chloride emission rate during the mill on condition

performed May 21,2002 was 5.81 pounds per hour. The hydrogen chloride emission

rate during the mill on condition performed May 22, 2002 was 3.41 pounds per

hour.

There were no unusual problems experienced during the performance of Run

1 during the mill off condition. During the performance of Run 2, the plant

experienced operational disruptions approximately half way through the testing

and had to resume the mill on condition. The results of the mill off testing is

presented in Table V. Graphical representation of the results are presented in

Figure 3. The volumetric flow rate results used in the calculation of the results

during mill off condition are presented in Table VI. The hydrogen chloride emission

rate during the mill off condition was 8.99 pounds per hour.

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• National Cement 3 Ragland, AL
FACILITY NAME: National Cement - Ragland

FACILITY NUMBER: 410-0002-X003

EVALUATION BY: CDO

TEST DATE: OS/21-2412002

TESTED BY: SEAS

EVAL. DATE: 0113112003

SOURCE: KOPPERS MAIN STACK (MILL - ON)

METHOD 321: HYDROGEN CHLORIDE EMISSIONS

FLOW RATE DETERMINATIONS

RUN # 1(05/21) 2 (05/21) 3 (05/21)

AH("H20) 1.500 1.500 1.500

SQRT /\p 0.7050 0.7157 0.7087

tIn 83.1 85.2 85.6

ts 242.64 242.2 240.7

Pb 29.90 29.90 29.90

Pg -0.40 -0.40 -0.40

Vm 43.186 44.320 43.278

Y 0.918 0.918 0.918

%C02 18.0 18.0 17.0

%02 10.0 10.0 10.0

VIc (ml) 144.0 156.0 150.0

HC1 (ppmw) 5.420 3.790 3.440

Cp 0.84 0.84 0.84

stack dia 147.0 147.0 147.0

time 60.0 60.0 60.0

As (sqft) 117.859 117.859 117.859

Pm 30.01 30.01 30.01

Ps 29.87 29.87 29.87 29.87

Md 36.88 36.88 36.72

Vwstd 6.78 7.34 7.06

Vmstd 38.640 39.505 38.548

Bws 14.92 15.67 15.48

BwsTHEO 100 100 100

Bwsmeas. 14.92 15.67 15.48 15.36 %

Ms 34.06 33.92 33.82

Vs 42.07 42.79 42.38

Qa 297512 302561 299720

Qstd 189812 191453 190494 190587 dscf

HCI EMISSION RATES

RUN

HCl (Cs,ppmd)

(EMR)HCl

(EMR)HCl

1(05/21) 2(05/21)

6.37 4.49

6.87 4.89

30.07 21.40

3(05/21)

4.07

4.40

19.28

AVG(05/21)

4.98 ppmd

5.385 #/HR

23.584 Tons/yr
FACILITY NAME: National Cement - Ragland

FACILITY NUMBER: 410-0002-X003

EVALUATION BY: CDO

TEST DATE: OS/21-2412002

TESTED BY: SEAS

EVAL. DATE: 0113112003

SOURCE: KOPPER:S MAIN STACK (MILL - ON)

METHOD 321: HYDROGEN CHLORIDE EMISSIONS

FLOW RATE DETERMINATIONS

RUN # I (05/22)

AH("H20) 1.500

SQRT "p 0.7162

tm 83.7

ts 242.3

Pb 29.95

Pg -0040

Vm 26.100

y 0.918

%C02 0.0

%02 0.0

VIc (ml) 92.0

HCI (ppmw) 2.38

Cp 0.84

stack dia 147.0

time 35.0

As (sqft) 117.859

Pm 30.06

Ps 29.92 29.92

Md 28.00

Vwstd 4.33

Vmstd 23.368

Bws 15.63

BwsTHEO 100

Bwsmeas. 15.63 15.63 %

Ms 26.44

Vs 48.46

Qa 342712

Qstd 217278 217278 dscf

HCI EMISSION RATES

RUN

HCI (Cs,ppmd)

(EMR)HCl

(ENfR) Hel

I (05/22)

2.82 ppmd

3.48 #/HR

15.24 Tons/yr
FACILITY NAME: National Cement - Ragland

FACILITY NUMBER: 410-0002-X003

EVALUATlON BY: CDO

TEST DATE: 05121-2412002

TESTED BY: SEAS

EVAL. DATE: 01/31/2003

SOURCE: KOPPERS MAIN STACK (MILL - OFF)

METHOD 321: HYDROGEN CHLORIDE EMISSIONS

FLOW RATE DETERMINATIONS

RUN # 1 2 3

I\H("H20) 1.500 1.500 Not Conducted

SQRT "p 0.6760 0.7214

tm 74.9 105.2

ts 332.9 300.5

Pb 30.15 30.15

Pg 0.40 0.40

Vm 43.060 42.462

Y 0.900 0.900

%C02 19.0 20.0

%02 9.0 8.0

VIc (ml) 137.0 151.0

HC1 (ppmw) 10.810 3.310

Cp 0.84 0.84

stack dia 147.000 147.000

time 60 60

As (sqft) 117.859 117.859

Pm 30.26 30.26

Ps 30.18 30.18

Md 36.44 36.00

Vwstd 6.45 7.11

Vmstd 38.672 36.091

Bws 14.29 16.45 15.4 %

BwsTHEO 100 100

Bwsmeas. 14.29 16.45 15.4 %

Ms 33.80 33.04

Vs 42.80 45.24 44.0

Qa 302641 319941 311291 acfm

Qstd 174152 187116 180634 sdcfm

HCI EMISSION RATES

RUN

HCI (Cs,ppmd)

(EMR)HCI

(EMR)HC1

1(05/24) 2(05/24) 3(05/24)

12.61 3.96 Not Conducted

12.47 4.21 Not Conducted

54.62 18.44 Not Conducted

AVO

8.29 ppmd

8.34 #/HR

36.53 Tons/yr
Stack Test Report 10019 Report generated on 8/21/02

Facility Name: NATIONAL CEMENT

Source Name: KILN

Source Information

Facility Number: 410-0002 X003

Title V?: Yes Test Date: 5/21/02

Subpart/Chapter

F

Allowables Regulations ---- ._..-._.. _._._----------_..__._.----_..__._-_ _... . _.._ _.. _ _ _ - _.._..__.._----~-

0.3 LBITON KILN FEED NSPS

Pollutants

ESB inspector: TLP Signatur~a <' "

__,_~ __~~~__ __ _ ~__~__ __ _~_m"_" u___ uu__u_u __~_. _

Observation Information

Test Methods: M18, M316, M321

Test Company: Sanders

EMS Observer: COO ESB Observer: TLP

Date:~2.--

Initial Test?: No

Activity: STACK TEST

Testing with Mill on and with Mill off

vac; b"M /lI~/ a~

Evaluation Information

Report Received by ADEM:

Report Submitted to EMS:

8/8/02 Evaluator:

8/21/02 Date Evaluation Finished

Pollutant Run #1 Run #2 Run #3 Average Units

He I {f'1.;t.)t< (J'N)

fie/ ~t,~ - d~f1

Signatur~ Date:

ADEM Form 175 6/02