# SANDERS ENGINEERING &. 

# ANALYTICAL SERVICES, INC. 

## HYDROGEN CHLORIDE EMISSIONS TESTREPORT (VOLUME I) 

## FOR
NATIONAL CEMENT KOPPERSMAINSTACK Ragland, Alabama

May 21 

### through 24,2002

1568 LEROY STEVENS ROAD MOBILE. ALABAMA 36695 (251) 633-4120 FAX: (251) 633-2285 E-MAlL: sanders @sandersengineering.com

### Sanders Engineering &

### AnalyticalServices, 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. Furtherdiscussions ofthe test methods are included laterin the report. The purpose ofthe testing was to determine plant status pertaining to the Portland CementMACT ofthe U. S. Environmental ProtectionAgency, and to meet the necessary requirements contained in the permit to operate issued by the Alabama Department ofEnvironmental Management. The tests were conductedby 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 EnvironmentalManagementwas also presentto observe the testing.



# I 

# I 

# I I 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 briefdescription ofthese types oftests.

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 ofwhich

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 inAppendix C. 

### Mobile, AL

Ragland, AL 2 2. DESCRIPTIONOF SAMPUNG PROGRAM 

### Sanders Engineering &

### AnalyticalServices, Inc.



### 2.1. VolumetricFlowRate Testing The quantitative determination offlow 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 ofa pitot tube into the stack at points representing an equal
cross sectional area ofthe duct. The data from the pitot tube was recorded on the field data sheet. The diameter ofthe 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 ofthe sampling train is presentedin Section 6.



### National Cement

### SandersEngineering &

### AnalyticalServices, Inc.

3. SUMMARYAND DISCUSSIONOFRESULTS Mobile, AL

There were no unusual problems experienced during the performance ofthe testing during the mill on condition. Three runs were performed during the mill on condition on May 21, 2002. The results ofthis 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 ofthis 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 ofthe 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 perhour. The hydrogenchloride 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 ofRun 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 ofthe results during mill offcondition are presentedin Table VI. The hydrogen chloride emission rate during the mill offcondition was 8.99 poundsperhour. 

# I 

# I 

# I I I 

# • National Cement 3 

### Ragland, ALFACILITYNAME: 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
FLOWRATE 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 stackdia 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

HCIEMISSIONRATES 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/yrFACILITY 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 stackdia 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/yrFACILITY 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 NotConducted 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 stackdia 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 NotConducted 12.47 4.21 NotConducted 54.62 18.44 NotConducted AVO 8.29 ppmd 8.34 #/HR 36.53 Tons/yrStackTest 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 <' "

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__**~_.** _ Observation Information Test Methods: M18, M316, M321 Test Company: Sanders EMS Observer: COO ESB Observer: TLP

## Date:~2.--

Initial Test?: No Activity: STACKTEST Testing with Mill on and with Mill off



## vac; b"M**/lI~/ a~**  Evaluation Information Report Received byADEM:

Report Submitted to EMS: 8/8/02 Evaluator: 8/21/02 Date Evaluation Finished

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



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# Signatur~ Date: ADEM Form 175 6/02