Bill:

Condensation inside the OTM 27 cyclone or on the filter should not be a problem if you preheat the cyclones as specified in Section 8.6.9. You should not have a conde nstaion situation at the end of the sampling period since the cyclones and filter assembly will be above the dew po int until they reach ambient temperature and if the air is super saturated with moisture (your in a fog). At 530 F there should be no water droplets and therefore the situation where the sampling can not be performed woul d not exist. There may be a situation with the stack temperature that you will need to address. At about 5 00 F there may be galling of the threads of the cyclone and other metal parts. Up to a point you can address this wi th the sparing use of anti-sieze compound and use of metal gasket materials. You should contact the supplier of the cyclones for their recommendations. If they do n ot have a solution for the high temperature condition, t hen the use of EPA Method 5 as an alternative for OTM 27 is the only resolution that we have at this time. In that situation, we would consider that all of the material collected

on the Method 5 filter is less than 2.5 uM.

_________________________________ Ron Myers U.S. Environmental Protection Agency Office of Air Quality Planning and Standards Sector Policy and Programs Division Monitoring Policy Group, D243-05 RTP NC 27711
Tel. 919.541.5407 Fax 919.541.1039 E-mail myers.ron@epa.gov

Ron:

Please respond to this question about filter temperatur e and high moisture relative to using OTM 27.

Thanks,

Peter From: Peter Westlin/RTP/USEPA/US

To: Ron Myers/RTP/USEPA/US@EPA

Cc: "Jill Merrill" <jmerrill@air-comp.com>, "Michael Ma tvey" <mmatvey@air-comp.com>, "Rob Frey" <rfrey@air -comp.com>, "William

Ondriezek" <wondriez@air-comp.com>, "William Cowell " <wcowell@air-comp.com>, Jason Dewees/RTP/USEPA/US @EPA, Robin Segall

Date: 07/14/2009 06:09 PM

Subject: Re: Stack Testing Question on a Cement Kiln

From: "William Cowell" <wcowell@air-comp.com>

To: Peter Westlin/RTP/USEPA/US@EPA

Cc: "Jill Merrill" <jmerrill@air-comp.com>, "William On driezek" <wondriez@air-comp.com>, "Michael Matvey" <mmatvey@air-comp.com>, "Rob

Frey" <rfrey@air-comp.com>

Date: 07/14/2009 10:11 AM

Subject: Stack Testing Question on a Cement Kiln Page 1 of 2

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...Peter,

We are a stack testing firm representing a cement kiln cl ient that was notified of its requirement to test PM 2.5 under the Section 114 CISWI program. Now, the recom mended test method for measuring PM 2.5 is OTM27/OTM-28.

However, in reading guidance document 51A http://www.epa.gov/ttn/emc/guidlnd/gd

- 051A.pdf Q21/A21 and Q27/A27 seem to suggest that for wet stacks (entrained moi sture droplets), EPA Method 5, followed by an OTM28 backhalf is the preferred alternate.

The source we are testing has an average moisture content between 30 and 35%. Now, the stack air temperature is 530+ deg. F, so the moisture is probabl y not in droplet form in stack, but we feel it likely t hat the filter in the OTM-27 sampling head is prone to get som e moisture on it due to the high moisture when remov ing the probe from the stack, thus making the removing/cleanu p of the filter and subsequent weighing of the filte r suspect.

I have pasted a previous stack test program results below t o show you the stack properties, and we were looking to propose doing a 4-hour Method 5/OTM-28 test instead of OTM-27/OTM-28 for reporting PM 2.5 and wanted your thoughts on this approach for this source. You were th e designated test contact for testing methods, so I dir ected this question to you first.

William Cowell Senior Engineer, QSTI (412) 826-3636 Start Time 2:00 PM 7:10 AM 1:55 PM

End Time 6:05 PM 11:15 AM 6:05 PM

Flow Rate (ACFM) 136,694 142,627 145,387 141,570

Flow Rate (SCFM) 71,843 73,893 76,096 73,944

Flow Rate (DSCFM) 48,705 49,670 50,762 49,712

Carbon Dioxide (dry volume %) 16.00 16.00 15.50 15.83

Oxygen (dry volume %) 9.50 9.50 9.00 9.33

Water Vapor (volume %) 32.21 32.78 33.29 32.76
Stack Temperature (°F) 537.1 546.5 539.6 541.1
Percent of Isokinetic Sampling (%) 97.9 99.9 101.1 99.6 Page 2 of 2

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