# From: Hector.Ybanez@holcim.com

To: Keith Barnett/RTP/USEPA/US@EPA

Date: 04/23/2010 05:17 PM Subject: CATSKILL HCL report

Keith

here is the HCL report for Catskill

the Portland report had some errors and it was sent back to the stack test

company to correct

(See attached file: HOLCIM

_ Enclosure 6 M321 Spreadsheet.xls)(See attached

file: HCl ICR Draft Test Report for Catskill 042110.pdf)

_____________________

Hector Ybanez

Corporate Manager, Environmental

122 West Carpenter Freeway

Suite 485
Irving, Texas 75039

Phone (214) 524 ‐ 2814

Cell (972) 268

‐ 1139
Hector.Ybanez@holcim.com
hybanez@gmail.com www.holcim.com/us

This e

‐ mail is confidential and intended only for the use of the above named

addressee. If you have received this e

‐ mail in error, please delete it
immediately and notify us by e

‐ mail or telephone.(See attached file:

HOLCIM

_ Enclosure 6 M321 Spreadsheet.xls)(See attached file: HCl ICR Draft

Test Report for Catskill 042110.pdf)

## DEECO Inc.

**3404 Lake Woodard Road Raleigh, NC 27604**  **(919) 250-0285 (ph); (919) 250-1835 (Fax) www.deeco.com** 



# REPORT NO: **042110-2525**

PROJECT: **10-2525**

DATE: **April 21, 2010**

TYPE: 

# Emission Test Report

U.S. EPA Information Collection Request

for Hydrogen Chloride Emissions

from Portland Cement Manufacturing Facilities

Holcim (US) Inc. Catskill, NY

AUTHOR: **Scott Steinsberger, Ph.D.**

TEST DATE: **April 9, 2010**

FIELD TEAM: **Josh Fox, Kevin McEnaney, and Scott Steinsberger**

PREPARED FOR: **Holcim (US), Inc.**

**201 Jones Road Waltham, Massachusetts 02451** 

# i TABLE OF CONTENTS

**Section Page** 

**1. INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1** 

**2. SUMMARY OF RESULTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4** 

**3. SAMPLING AND ANALYTICAL PROCEDURES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6** 

**3.1 EPA Method 1 and 2 - Stack Gas Volumetric Flow Rate Determination . . . . . . . 6**

**3.2 EPA Method 4 - Stack Gas Moisture . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6**  **3.3 EPA Method 3A - Stack Gas Oxygen and Carbon Dioxide . . . . . . . . . . . . . . . . . 8 3.3.1 Gas Sampling System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .**  **. . . . . . 8 3.3.2 Oxygen and Carbon Dioxide Monitor . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8**  **3.3.3 Data Acquisition System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9** 

**3.3.4 Calibration Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9**  **3.4 EPA Method 321 - Stack Gas Hydrogen Chloride . . . . . . . . . . . . . . . . . . . . . . . 10**

**4. QA/QC PROCEDURES AND RESULTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13**  **4.1 Sampling Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13**  **4.1.1 Manual Sampling Equipment Calibrations . . . . . . . . . . . . . . . . . . . . . . . 13**  **4.2 Analytical QA/QC Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14** 

**Appendix A - Emission Summary Sheets Appendix B - Field Sampling Data Sheets**  **Appendix C - Continuous Emission Monitoring Results Appendix D - FTIR Data**  **Appendix E - Equipment Calibration Data Sheets and Calibration Gas Certifi cates of** 

**Analysis Appendix F - Test Participants** 

# ii LIST OF TABLES

**Table No. Page**  **TABLE 1.1 SUMMARY OF HYDROGEN CHLORIDE EMISSIONS; HOLCIM (US)**

**CATSKILL, NY FACILITY; APRIL 9, 2010 . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2** 

**TABLE 1.2 SUMMARY OF SAMPLING AND ANALYTICAL PROTOCOLS FOR**

**HOLCIM (US) CATSKILL, NY FACILITY . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3**  **TABLE 2.1 HYDROGEN CHLORIDE EMISSION TEST RESULTS, HOLCIM (US)**

**CATSKILL, NY FACILITY; APRIL 9, 2010 . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5**  **TABLE 3.1 HYDROGEN CHLORIDE ANALYTE SPIKING TEST RESULTS, HOLC IM** 

**(US) CATSKILL, NY FACILITY; APRIL 9, 2010 . . . . . . . . . . . . . . . . . . . . . . 12** 

LIST OF FIGURES **Figure No. Page** 

**Figure 4.1 Schematic of the Kiln Stack sampling location . . . . . . . . . . . . . . . . . . . . . . . . . . . 7** 

# 1 

# 1. INTRODUCTION

**The U.S. Environmental Protection Agency (EPA), Office of Air Qual ity Planning and**  **Standards (OAQPS) issued an Information Collection Request (ICR) t o Holcim (US), Inc (Holcim).**  **Under the authority of Section 114 of the Clean Air Act (CAA), the E PA requested information on**  **hydrogen chloride (HCl) emissions from nonhazardous waste-burning kilns at Portland cement**  **manufacturing facilities. The request was in response to comment s from Portland cement industry**  **members and its trade association to EPA’s proposal to amend t he national emission standards for**  **hazardous air pollutants for Portland cement manufacturing (74 FR 21136 (May 6, 2009)).**

**Holcim retained DEECO Inc. (DEECO) to conduct the required emissi ons testing. Testing** 

**for HCl was conducted in accordance with EPA Method 321 - Measurement of Gaseous Hydrogen**  **Chloride Emissions At Portland Cement Kilns by Fourier Transform Infrared (FTIR) Spectroscopy.** 

**The Holcim facility in Catskill, NY (6446 Route 9W, Catskill, NY 12414) has been one of**  **the Portland cement manufacturing facilities selected as part of the ICR. Holcim operates one wet**  **process kiln system at this facility that discharge through a single main stack. The kiln is fueled by**  **a variety of fuels including, but not limited to, coal, coke, or other non-ha zardous fuels. Combustion**  **gases exit the kiln and pass through an electrostatic precipitator, then to a n induced draft fan prior**  **to entering a stand-alone stack.**

**Testing was performed at the stack under one condition on April 9 th**  

# , 2010

**Sampling was conducted by personnel from DEECO, Inc. of Raleig h, North Carolina.**  **Emission measurements were conducted simultaneously at the Main K iln Stack for temperature,**  **volumetric flow rate, dry gas molecular weight, moisture, and hydroge n chloride. A summary of the**  **sampling and analytical methods are presented in Table 1.2.**

**All questions regarding sampling and analytical data should be dire cted to Dr. Scott**  **Steinsberger of DEECO at (800) 733-3261. The field sampling was com pleted by Josh Fox, Kevin**  **McEnaney, and Scott Steinsberger of DEECO.**

**The remainder of this document summarizes the results, procedures a nd quality control**  **measures followed for this program. Section 2 contains tabulated a ir emission results for each**  **parameter of interest. Section 3 summarizes the air emiss ion sampling and analytical procedures**  **performed by DEECO, with a brief description and/or reference to the applicable methodologies.**  **Section 4 discusses the basic quality control elements in place for this program to assure the**  **collection of representative, accurate air emission data.**

**The appendices provided in this document contain all of the necessary i nformation to verify**  **the reported results. Included as Appendices are: A - Emission S ummary Sheets; B - Field Sampling**  **Data Sheets; C - Continuous Emission Monitoring Results; D - FTIR Data; E - Equipment**  **Calibration Data Sheets and Calibration Gas Certificates of Analysis ; F - Test Participants.** 

# 2

TABLE 1.1 SUMMARY OF HYDROGEN CHLORIDE EMISSIONS; HOLCI M (US)

CATSKILL, NY FACILITY; APRIL 9, 2010

Test Parameter Average Emission

Result

**Hydrogen Chloride Emissions (ppm dry**  

# at 7% oxygen) **9.11**

# 3TABLE 1.2 SUMMARY OF SAMPLING AND ANALYTICAL PROTOCOLSFOR HOLCIM (US)CATSKILL, NYFACILITYLocation and Frequency Test Parameter Sampling MethodSampling Procedure Analysis Method Analysis Procedure**Kiln Main Stack Volumetric Flow Rate EPA Method 1 and 2** **with s-type pitot Velocity traverse with** **pitot for delta p EPA Method 2 Manometer and thermocouple** **readout Oxygen and** **Carbon Dioxide EPA Method 3A Continuous;** **extractive sample EPA Method 3A Paramagnetic for O** **2 and NDIR** **for CO 2** **Stack Gas Moisture EPA Method 4 Integrated sampling w ith** **condensation EPA Method 4 Gravimetric** **Hydrogen Chloride EPA Method 321 Continuous; extractive sample** **EPA Method 321 Fourier Transform Infrared (FTIR) Spectroscopy** 

# 4 

# 2. SUMMARY OF RESULTS

**Emissions sampling was conducted at the Holcim (US) Inc. facil ity located in Catskill, New**  **York. Sampling was conducted for stack gas HCl according to EPA Me thod 321. Concurrently,**  **sampling was conducted for stack gas volumetric flow (EPA Method 1 and 2), stack gas oxygen and**  **carbon dioxide (EPA Method 3A) and stack gas moisture (EPA Method 4). Testing was conducted**  **under one condition on April 9, 2010.**

**The emissions results for Runs 1, 2, and 3 are summarized in Table 3.1.**

# 5

TABLE 2.1 HYDROGEN CHLORIDE EMISSION TEST RESULTS, HOLC IM (US)

CATSKILL, NY FACILITY; APRIL 9, 2010

Test Parameter Run 1 Run 2 Run 3 **Average**

**Time 09:30-10:30 11:30-12:30 13:40-14:40 ----** 

**Stack Gas Temperature (** E **F) 284 295 294 291**

**Stack Gas Moisture 24.2% 26.7% 22.7% 24.5%**

**Volumetric Flowrate**

**actual cfm dry standard cfm**  **336,300**
**182,000 387,100** 

**199,500 395,700** 

**215,500 373,000** 

**199,000**

**Oxygen Content 10.9% 11.0% 10.9% 11.0%**

**Hydrogen Chloride Emissions Concentration, ppm**  **by volume, wet basis** 

# Concentration, ppm **by volume, dry basis** 

# Concentration, ppm at 7% oxygen **4.85**

**6.40**

**8.92 3.46** 

**4.73**

**6.65 6.53** 

**8.45**

**11.77 4.95** 

**6.53**

**9.11**

# 6 

# 3. SAMPLING AND ANALYTICAL PROCEDURES

**Table 1.2 presents a summary of the overall sampling and analytica l protocols used for the**  **Information Collection Request (ICR) test program for the Main K iln stack at Holcim (US), Inc.’s**  **Catskill, NY facility. All sampling and analytical methods employed for this test program were**  **performed in accordance with the procedures outlined in the Reference Test Methods contained in**  **the Code of Federal Regulations , Title 40, Part 60, Appendix A (40 CFR 60, Appendix A) and 40**  **CFR 63, Appendix A.**

3.1 EPA Method 1 and 2 - Stack Gas Volumetric Flow Rate Determination

**The flue gas sampling ports on the main stack were located appr oximately 47 feet (~3.5 duct**  **diameters) above the junction of the ID fan outlet beaching, and approx imately 25 feet (~1.9 duct**  **diameters) below the discharge point of the stack. The main sta ck had a measured inside diameter**  **of 162 inches. This location met the minimum specifications for sel ection of a measurement site as**  **outlined in EPA Method 1. A schematic of the Kiln Stack location is shown in Figure 3.1.**

**A 8-point velocity traverse in each of two perpendicular direct ions was made at each**  **sampling location using a type-S pitot tube in accordance with EPA Method 2. Gas temperatures**  **were measured using calibrated Type K thermocouples and digital readout devic es.** 

**Dry gas molecular weight was determined using the oxygen and ca rbon dioxide**  **measurements following EPA Method 3A employing oxygen and carbon dioxi de monitors. Stack**  **gas moisture was measured in accordance with EPA Method 4 procedures.**

3.2 EPA Method 4 - Stack Gas Moisture

**The moisture content of the flue gas was determined using the met hodology described in**  **EPA Method 4. Based on this method, a known volume of particulate-free g as was pulled through**  **a chilled impinger train. The weight of each impinger was determined g ravimetrically before and**  **after sampling. The weight increase in each impinger was t hen related to the volume of gas sampled** 

**to calculate the moisture content.**

**During this test, the moisture content of the flue gas was determ ined simultaneously with the**  **Methods 3A and 321 sampling.**

# 7 **Figure 4.1 Schematic of the Kiln Stack sampling location.**

# 8

3.3 EPA Method 3A - Stack Gas Oxygen and Carbon Dioxide

**A CEM system was used for determining the flue gas molecular weight and stack gas oxygen** 

**content on the Main Kiln stack.**

**The extractive monitors require that the effluent gas sample b e filtered and maintained above**  **condensation temperature, or conditioned to eliminate any possible i nterference (i.e., water vapor**  **and particulate matter), before being transported and delivered t o each analyzer. All components of**  **the sampling system which contact the sample are either of g lass, stainless steel, or Teflon. A heated**  **sampling probe with heated out-of-stack particulate filter, he ated sample lines, an ice water-cooled**  **condenser, a sample pump, and a gas distribution manifold are used to deliver a representative**  **sample of flue gas to each of the analyzers. Details of the major components of the measurement**  **system are presented below.**

3.3.1 Gas Sampling System

**The gas sample was extracted from the stack through a glass lined probe and filter heated to** 

**at least 356** E 

# F in an enclosure custom built for these test procedures. This **heated enclosure was equipped with heated glass-lined probe that allowed three traver**  **se points on the line at 0.4, 1.2, and 2.0 meters from the stack wall be sampled equally during each**  **test. The glass filter holder had a teflon frit supporting a quartz fiber filter. Outflow of gas**  **from the heated filter enclosure was conveyed using a heat-traced Teflon sample line also maintained at**  **least at 356** E 

# F. The heated line **was connected directly to the FTIR sample cell. A sample pump i n a DEECO proprietary chiller**  **type gas conditioner system was used to pull the gas sample t hrough the system. The gas conditioner**  **system was also used to remove moisture from the gas sample p rior to introduction to the**  **oxygen/carbon dioxide analyzer.**

3.3.2 Oxygen and Carbon Dioxide Monitor

**A CAI Model 200 O 2**  

# /CO **2** 

# analyzer was used to measure the oxygen and carbon dioxide **concentrations. The oxygen concentrations are were measured using the paramagnetic technique.**  **Because of its sp3 electron orbital distribution, an oxygen mole cule has an unpaired electron and**  **hence displays a magnetic orientation. Since other elements that display this magnetic phenomenon**  **are not common gasses at normal temperatures, the paramagnet ic measurement technique is virtually**  **specific for oxygen. The sample gas flows through a detection ce ll located in a very strong magnetic**  **field. The magnetic nature of the oxygen causes the oxygen to move to one side of the detection cell,**  **inducing a pressure differential proportional to the oxygen concentration in the detector cell. The**  **analyzer measures this pressure differential, converts the pre ssure differential to an electrical signal,**  **and sends the results as output.**

**The carbon dioxide concentrations were measured using a single-beam photometr ic system** 

**with a micro flow sensor detector. The micro flow detector is a sealed unit filled with carbon dioxide.**  **The instrument consists of an infrared light source, a chopper, a me asuring cell and a micro flow**  **detector filled with carbon dioxide. The infrared light emitted b ackward is reflected by a reflecting**  **surface and is added to the infrared light emitted forward. Arrang ed between the infrared light source** 

# 9

**and the measuring cell is a chopper blade which rotates to modulat e the infrared light beam at regular**  **frequency. The modulated infrared light beam thus formed passes thr ough the measuring cell filled**  **with a sample gas where the light energy is partially ab sorbed or attenuated before it reaches the front** 

**chamber of the detector. Both the front and rear chambers of the detector are filled with the gas**  **component to be measured. The infrared light energy is partiall y absorbed in the front chamber and**  **residual light is absorbed in the rear chamber, thereby incr easing the pressure in both chambers.**  **Since the detector is designed to produce a pressure difference b etween the front and rear chambers,**  **a slight gas flow is produced through a path connecting these chambe rs with each other. This slight**  **flow is converted into an AC electrical signal by a micro flow sensor.**

3.3.3 Data Acquisition System

**Data were recorded on two separate devices. A hard copy was o btained using a Molytek 2702**  **strip chart recorder. Data was also recorded to the hard disk of an IBM compatible computer utilizing**  **the serial output of the Molytek recorder in conjunction with custom s oftware developed by DEECO**  **Engineers. Data for each of the analyzers was sampled each t wo seconds with a one minute average**  **being written to disk. Data was further averaged over the te st period and corrected for calibration**  **error and drift using a spreadsheet program.**

3.3.4 Calibration Procedures

**Calibration procedures were performed in accordance with EPA me thodology. Analyzers** 

**were calibrated before and after each test and a calibration check was done between each test run.** 

**The pretest calibrations consisted of the following steps:**

C **Internal (direct) calibration of each analyzer to adjust calibrati on and**  **check linearity.**

C **External (through the entire sampling system) calibration to c heck the**  **system bias on zero and span gases.**

**The post test calibration consisted of an external system bias calibr ation check** 

**Each analyzer was calibrated using a certified zero and span (mid or high range) gas. Zero**  **and span gases were directed to each analyzer through the appropr iate plumbing, the calibration gas**  **flow rates were adjusted to the correct flow rate and the analyzer w as adjusted with the appropriate** 

**span pot.**

**After the analyzer was properly adjusted the linearity wa s checked using a low and high range**  **calibration gas. The maximum allowable limit for linearity is 2% of the analyzer range. All analyzers** 

**were shown to be linear within these limits.**

**The external calibration bias check was performed by placing the CEM system in sampling**  **mode and injecting a zero and span gas into the sample line at the probe exit. This check shows if** 

# 10

**there is any sampling system related bias, and also serves a s a check of the integrity of the sample** 

**line.**

**DEECO used EPA Protocol and/or ±2% NIST Traceable gases for c alibration as required by the**  **various reference methods employed in this test program. Cali bration gases were selected from**  **previous experience with similar sources and/or from information o btained from the facility engineer**  **prior to sampling. In some cases if the gases that were s elected were out of the optimum range of**  **operation then no significant impact of data quality is expecte d due to the linear nature of the**  **analyzers that were used.**

**No audit gases were available from federal or state agency.**

**At the completion of the pretest calibration routine, the CEM sy stem was ready for operation.**  **No further adjustments of sample flow rates, analyzer zero or span adjustments, or other critical CEM**  **operating parameters were made until testing and post test calibra tion were complete.** 

**At the completion for each test run, calibration gases were used to check betwe en test runs.**  **A zero and the upscale calibration gas closest to the actual emission concentrations were used for the**  **pretest and post test calibrations.**

3.4 EPA Method 321 - Stack Gas Hydrogen Chloride

**The sampling system described above was used to convey the gas s ample to the FTIR sample**  **cells. The FTIR sample cell was maintained at 356** E 

# F. The sample cell was connected to a MIDAC **Corporation I-series Fourier Transform Infrared Spectrometer and Detect or.** 

**The FTIR spectrometer measures vapor phase organic or inorganic compounds which absorb**  **energy in the mid-infrared spectral region, about 400 to 4000 cm -1**  

# (25 to 2.5 μm). Continuous **measurement is made by matching sample absorbance bands wi th bands in reference spectra, and**  **comparing sample band intensities with reference band intensities.**

**The principle limitation to FTIR spectroscopy are the pres ence of interfering compounds that**  **also absorb energy in the mid-infrared spectral region. In a c ement kiln stack gas matrix, water vapor**  **(H 2**  

# O) and carbon dioxide (CO **2** 

# ) are the primary interferents that must be incorporated **into the identification and quantitation method.** 

**The FTIR software performs the computation for a single comp ound by subtracting all the**  **other compounds (interferants and target) from the absorbance spe ctra and quantifies the single**  **compound based on the remain absorbance. The FTIR software provides a Standard Error**  **Calculation (SEC) value that is an indication of how well the identi fication and quantitation has been**  **performed. A high SEC indicates that other interferants have not b een accounted for in the analysis**  **method, and a low SEC is indicative of greater confidence measurement.**

**The instrument was operated with a resolution of 0.5 cm -1**  

# with 4x zero filling. Beer-Norton **Medium apodization was used with amplitude phase correction. The following analytical regions** 

# 11

**were used for HCl;, 2748.85 - 2754.20 cm -1**  

# , 2772.80 - 2776.80 cm **-1** 

# , 2795.85 - 2800.20 cm **-1**



# , **2962.50 - 2964.00 cm -1**  

# , and 2998.60 - 2997.00 cm **-1** 

# . These regions were found to provide the lowest **SEC values for this stack gas matrix.**

**With this system at the 0.2 ppm detection limit required in the ICR, a Ma ximum Analytical**  **Uncertainty (MAU) of 0.15 ppm at cell conditions was calculated. The ICR request that the detection**  **limit be calculated according to Method 321. However, Method 321 does not have provisions for**  **calculating a detection limit. The method has the analyst speci fy the detection limit and then**  **determine if the data quality of the analytical system meets calculated criteria based on the desired**  **detection limit. The MAU of 0.15 ppm is less than the 0.2 ppm required detection limit, indicating**  **that the FTIR system is suitable for measurement at this level.**

**Analyte spiking was conducted before and after each sampling run a ccording to Method 321.**  **The results are summarized in Table 3.1. All analyte spike r ecoveries were within the required 70-**  **130% and the pre and post test CTS calibration checks were within the 5% required .**

# 12

TABLE 3.1 HYDROGEN CHLORIDE ANALYTE SPIKING TEST RESU LTS, HOLCIM

(US) CATSKILL, NY FACILITY; APRIL 9, 2010

Test Parameter Pre Run 1 Post Run 1 Post Run 2 Post Run 3

**Time 08:39-09:06 10:48-11:19 12:23-13:08 14:42-15:19**

**HCl Spike Direct (ppm) 20.28** 

**SF6 Tracer Direct (ppm) 10.11** 

**Total HCl (spike plus native ppm) 5.245 8.112 8.681 7.6 76** 

**Average Native HCl (ppm) 4.099 6.392 7.432 6.741**

**SF6 Tracer Diluted (ppm) 0.937 0.956 0.966 0.989**

**HCl Analyte Spike Recovery 81.2% 121.2% 101.1% 80.4%**

**Ethylene CTS Error -0.20% -0.18% -0.53% 0.21%**

# 13 

# 4. QA/QC PROCEDURES AND RESULTS

**The objective of a quality assurance/quality control (QA/QC) prog ram is to assure that the**  **precision and accuracy of all environmental data generated by DEE CO for clients are commensurate**  **with data quality objectives (DQO's). DQO's are based on a c ommon understanding of the intended**  **end use(s) of the data, the measurement process, and the availabili ty of resources. Once DQO's are**  **established, formally or informally, QC protocol can be defined for the measur ements.** 

**In this project, the final data user will be Holcim. The data quality objec tives in this project**  **are to generate scientifically sound data to be used for compliance purposes**

**.**

4.1 Sampling Equipment

**All of the sampling equipment used was calibrated according to t he procedures outlined in the**  **Quality Assurance Handbook for Air Pollution Measurement Systems , Volume III, EPA-600/4-77-** 

**027b.**

4.1.1 Manual Sampling Equipment Calibrations

**For sampling Methods 1, 2, and 4 the procedures and equipment used to measure st ack gas**  **velocity and temperature measurements and the metering system used to maintain constant rate**  **sampling conditions and to determine the sample gas volume were su bjected to pretest and posttest**  **calibrations and/or inspections as required by the appropriate EPA methods**

**.**

Barometer **- Barometric pressure values were obtained from a calibra ted barometer, verified by**  **phone call to a local airport, and corrected for elevation to sampl e port level (0.01 inches Hg per 10**  **ft. elevation).**

Pitot Tubes **- Each pitot tube used in sampling meets the design specifi cations for type-S pitot tubes**  **in EPA Method 2. Therefore, a maximum value baseline coefficient (C** 

**p** 

# ) of 0.84 is assigned to each **pitot tube. Calibration by the manufacturer for pitot face-o pening alignment included measuring the**  **external tubing diameter (dimension D**

**t** 

# ), the base-to-opening plane distance (dimensions P

**a** 

# and P **b** 

# ), **and the face opening misalignment angles, with all terms as de scribed in EPA Method 2. Pitot tubes**  **were visually inspected for structural integrity at the completion of each test. Inspection sheets for**  **pitot tubes are included in Appendix E.**

Calibration Meter and Metering System **- The secondary reference meter equipment arrangement for calibration is shown in Figure 5.7 of EPA Method 5. The prescrib**  **ed procedures were followed.**

**A wet test meter with a 1 ft 3**  

# /rev capacity and + **1 percent accuracy is used as the primary calibrant. The dry gas meter's pump is run for a minimum of 5 minutes at a**  **flow rate of 0.35 cfm to condition**

**the interior surface of the wet test meter. Leak checks are performed and if satisfactory, triplicate runs** 

**at each of no less than five different flow rates are done. A calibration curve is prepared and the**  **meter is recalibrated after 200 hours of operation or annually, whichever comes fi rst.** 

# 14

**The calibration set-up for the dry gas metering system usi ng the secondary reference meter**  **in lieu of the wet test meter is given in Figure 5.5 of EPA Method 5. A leak che ck of the metering**  **system before calibration was performed as shown in Figure 5.4 of EPA Method 5. The metering**  **systems's pump is operated for 5 minutes at an orifice manom eter setting of 0.5 inches H**  **2** 

# 0 to heat **up the pump and system to stabilize the meter inlet and outlet temperatures. Values for the orifice**  **setting (delta H), wet test meter volume (V**

**w** 

# ), corresponding dry test meter volume (V **d** 

# ), dry test **meter inlet and outlet gas temperatures (t di**  

# and t **dn** 

# ), and time are recorded for the initial calibration. **Then the ratio of the wet test meter to the dry test meter ( gamma) and the orifice pressure differential**  **that equates to 0.75 cfm at standard conditions (delta H@) are calculated.**

**A post-test meter calibration was made on the dry gas meter used during the test to check its**  **accuracy against the pre-test calibration. This post-test calibration check was made using the average**  **orifice setting obtained during each test run and setting the vacuum at the maximum value obtained**  **during each test run. These test runs were made against DEECO' s secondary reference dry gas meter**  **which was calibrated against a wet test meter. The calib ration data sheets for the dry gas meters are**  **included in Appendix E.**

Thermocouples and Digital Indicators **- Thermocouples were calibrated by comparing them agai nst**  **an ASTM-3F mercury-in-glass thermometer at approximately 32** E **F (ice water), ambient temperature, and at approximately 220**  E **F. Each thermocouple was calibrated against temperature ra nges to which**  **it is typically exposed during test conditions, and they agreed within 1.5 percent (expressed in**  E **R) of the reference thermometer throughout the entire calibration ra**  **nge. Also, thermocouples were checked at ambient temperature at the test site to verify calibration. T**  **he calibration data sheets for the thermocouples are included in Appendix E.** 

Pretest and Posttest Leak Checks of Sampling Trains **- Each Method 4 sampling train was subjected to pretest leak checks and posttest leak checks. For a**  **ll sampling runs the posttest leak checks were acceptable (less than 4% of the sampling rate a**  **t the highest vacuum recorded during the test run).** 

4.2 Analytical QA/QC Results

**Analytical measurements of precision and accuracy were made on stack gas samples, and are**  **summarized in a separate report.**e in drymvd)e testmit, pleaseacketsWorksheet Title:HCl Emission Test Results Template Using Method 321Who Should Complete this Spreadsheet?Facilities that use Method 321 to test for HClCompany Name:Holcim (US), Inc.Facility Name:Catskill PlantAddress:6446 Route 9W, Catskill, NY 12414City:CatskillState:NYKiln ID:Long Wet KilnKiln Type:Indicate whether the kiln is wet, long dry, PH, PH/PCIn-line Raw Mill:NoControl Device Configuration:ESPParameter Sample #1 Sample #2 Sample #3 Test AverageUnits Units Other DescriptionTest Method UsedTest LocationNoteEnter HCl concentration valuparts per million volume (ppcorrected to 7% oxygen. If thresults are below detection linote the detection limit in br(e.g., [< 0.010]).Select appropriate unifrom list. If other isselected please descriunits in column H at rtbeight.Enter the name of the TestMethod used.Indicate whether the testoccurred upstream ordownstream of a controldevice(s); list the controldevice(s)If kiln has an in-line raw mill, indicateraw mill status during tests (i.e., rawmill on or raw mill off). Provide anyother information supportinginformation you think is necessaryabout this test report.Sample Date (mm/dd/yyyy)4/9/2010 4/9/2010 4/9/2010HCl Concentration8.926.6511.779.11 ppmvd @ 7% O2DownstreamNOExhaust Stream %Moisture24.226.7 22.7%Exhaust Flowrate182,000199,500 215.5DSCFMExhaust Temperature284295 294degree FSample Date(mm/dd/yyyy)HCl Concentration@ppmvd7% O2Exhaust Stream %Moisture%Exhaust Flowrate(select flowrate units)Exhaust Temperature(select temperature units)Notes:Peach shaded cells indicate areas where the user will enter a responselue in drypmvd)the testlimit,it inWorksheet Title:HCl Emission Test Results Template Using Method 321Who Should Complete this Spreadsheet?Facilities that use Method 321 to test for HClCompany Name:Facility Name:Address:City:State:Kiln ID:Kiln Type:Indicate whether the kiln is wet, long dry, PH, PH/PCIn-line Raw Mill:Yes or NoControl Device Configuration:Enter all installed air pollution control devices hereParameter Sample #1 Sample #2 Sample #3 Test AverageUnits Units Other DescriptionTest MethodUsedTest LocationNoteEnter HCl concentration vaparts per million volume (pcorrected to 7% oxygen. Ifresults are below detectionplease note the detection limbrackets(e.g., [< 0.010]).Select appropriate unitfrom list. If other isselected please describeunits in column H at right.Enter the name of the Test Method used.Inocdodededicate whether the testcurred upstream orwnstream of a controlvice(s); list the controlvice(s)If kiln has an in-line raw mill, indicateraw mill status during tests (i.e., rawmill on or raw mill off). Provide anyother information supportinginformation you think is necessaryabout this test report.Sample Date (mm/dd/yyyy)HCl Concentrationppmvd @ 7% O2Exhaust Stream %Moisture%Exhaust Flowrate(select flowrate units)Exhaust Temperature(select temperature units)Sample Date(mm/dd/yyyy)HCl Concentration@ppmvd7% O2Exhaust Stream %Moisture%Exhaust Flowrate(select flowrate units)Exhaust Temperature(select temperature units)Notes:Peach shaded cells indicate areas where the user will enter a responsein dry partorrected tore belowdetectionWorksheet Title:HCl Emission Test Results Template Using Method 321Who Should Complete this Spreadsheet?Facilities that use Method 321 to test for HClCompany Name:Holcim (US), Inc.Facility Name:AdaAddress:1100 West 18th StreetCity:AdaState:OKKiln ID:Long WetKiln Type:Indicate whether the kiln is wet, long dry, PH, PH/PCIn-line Raw Mill:Yes or No NOControl Device Configuration:ESPParameter Sample #1 Sample #2 Sample #3 Test AverageUnits Units Other DescriptionTest Method UsedTest LocationNoteEnter HCl concentration valueper million volume (ppmvd) c7% oxygen. If the test results adetection limit, please note thelimit in brackets(e.g., [< 0.010]).Select appropriate ufrom list. If other isselected please descunits in column H asnitribet right.Enter the name of the Test Method used.Indicate whether the testoccurred upstream ordownstream of a controldevice(s); list the controldevice(s)If kiln has an in-line raw mill, indicateraw mill status during tests (i.e., rawmill on or raw mill off). Provide anyother information supportinginformation you think is necessaryabout this test report.Sample Date (mm/dd/yyyy)3/12/2010 3/12/2010 3/12/2010HCl Concentration1.661.341.25 1.42 ppmvd @ 7% O2EPA Method 321DownExhaust Stream %Moisture26.725.9 26.1%Exhaust Flowrate161400164100 166000dscfmExhaust Temperature331331 328Degree FSample Date(mm/dd/yyyy)HCl Concentration@ppmvd7% O2Exhaust Stream %Moisture%Exhaust Flowrate(select flowrate units)Exhaust Temperature(select temperature units)Notes:Peach shaded cells indicate areas where the user will enter a responsein dry partsrrected to 7lowdetectionFWorksheet Title:HCl Emission Test Results Template Using Method 321Who Should Complete this Spreadsheet?Facilities that use Method 321 to test for HClCompany Name:Holcim (US), Inc.Facility Name:Devils SlideAddress:6055 East Croydon RoadCity:MorganState:UtahKiln ID:Precalciner KilnKiln Type:Indicate whether the kiln is wet, long dry, PH, PH/PCIn-line Raw Mill:Yes or No YESControl Device Configuration:Fabric FilterParameter Sample #1 Sample #2 Sample #3 Test AverageUnits Units Other DescriptionTest Method UsedTest LocationNoteEnter HCl concentration valueper million volume (ppmvd) cooxygen. If the test results are bedetection limit, please note thelimit in brackets(e.g., [< 0.010]).Select appropriatefrom list. If other iselected please desunits in column H%unitscribeat right.Enter the name of the Test Method used.Indicate whether the testoccurred upstream ordownstream of a controldevice(s); list the controldevice(s)If kiln has an in-line raw mill, indicateraw mill status during tests (i.e., rawmill on or raw mill off). Provide anyother information supportinginformation you think is necessaryabout this test report.Sample Date (mm/dd/yyyy)2/24/2010 2/24/2010 2/24/2010HCl Concentration2.814.112.73 3.21 ppmvd @ 7% O2EPA Method 321DownMILL ONExhaust Stream %Moisture12.310.2 10.6%MILL ONExhaust Flowrate184800187100 188600dscfmMILL ONExhaust Temperature255253 253Degree FMILL ONSample Date(mm/dd/yyyy)2/25/2010 2/25/2010 2/25/2010HCl Concentration7.598.225.@44 7.08ppmvd7% O2h dEPA Method 321MILLFDownOFExhaust Stream %Moisture6.88.9 12.4%MILL OFFExhaust Flowrate189900187400 179500dscfmMILL OFFExhaust Temperature302304 302Degree FMILL OFFNotes:Peach shaded cells indicate areas where the user will enter a responsee in dryvd)e testit, pleasecketsWorksheet Title:HCl Emission Test Results Template Using Method 321Who Should Complete this Spreadsheet?Facilities that use Method 321 to test for HClCompany Name:Holcim (US), Inc.Facility Name:Saint GenevieveAddress:2942 US Highway 61City:BloomsdaleState:MOKiln ID:PrecalcinerKiln Type:Indicate whether the kiln is wet, long dry, PH, PH/PCIn-line Raw Mill:Yes or No YESControl Device Configuration:Fabric Filter and Lime InjectionParameter Sample #1 Sample #2 Sample #3 Test AverageUnits Units Other DescriptionTest Method UsedTest LocationNoteEnter HCl concentration valuparts per million volume (ppmcorrected to 7% oxygen. If thresults are below detection limnote the detection limit in bra(e.g., [< 0.010]).Select appropriate unfrom list. If other isselected please descrunits in column H atitiberight.Enter the name of the Test Method used.Indicate whether the testoccurred upstream ordownstream of a controldevice(s); list the controldevice(s)If kiln has an in-line raw mill, indicateraw mill status during tests (i.e., rawmill on or raw mill off). Provide anyother information supportinginformation you think is necessaryabout this test report.Sample Date (mm/dd/yyyy)2/14/2010 2/14/2010 2/14/2010HCl Concentration[<0.23] [<0.21] [<0.23][<0.22] ppmvd @ 7% O2EPA Method 321DownBOTH MILL ONExhaust Stream %Moisture12.712.9 12.8%BOTH MILL ONExhaust Flowrate440300423500 411900dscfmBOTH MILL ONExhaust Temperature197194 192Degree FBOTH MILL ONBOTH MILL ONSample Date(mm/dd/yyyy)2/15/2010 2/15/2010 2/15/2010HCl Concentration2.384.143.62@3.38ppmvd7% O2h dEPA Method 321BOTHMILLOFFMILL OFFExhaust Stream %Moisture7.48.1 7.3%BOTH MILL OFFExhaust Flowrate428300429600 434800dscfmBOTH MILL OFFExhaust Temperature355367 364(select temperature units)BOTH MILL OFFSample Date(mm/dd/yyyy)2/15/2010 2/15/2010 2/15/2010HCl Concentration0.781.121.241.04ppmvd@7% O2EPA Method 321One MILL ON and One MILL OFFExhaust Stream %Moisture10.911.1 10.5%One MILL ON and One MILL OFFExhaust Flowrate413900404300 419100(select flowrate units)One MILL ON and One MILL OFFExhaust Temperature270272 276(select temperature units)One MILL ON and One MILL OFFNotes:Peach shaded cells indicate areas where the user will enter a responselue in drypmvd)the testlimit,it inWorksheet Title:HCl Emission Test Results Template Using Method 321Who Should Complete this Spreadsheet?Facilities that use Method 321 to test for HClCompany Name:Facility Name:Address:City:State:Kiln ID:Kiln Type:Indicate whether the kiln is wet, long dry, PH, PH/PCIn-line Raw Mill:Yes or NoControl Device Configuration:Enter all installed air pollution control devices hereParameter Sample #1 Sample #2 Sample #3 Test AverageUnits Units Other DescriptionTest MethodUsedTest LocationNoteEnter HCl concentration vaparts per million volume (pcorrected to 7% oxygen. Ifresults are below detectionplease note the detection limbrackets(e.g., [< 0.010]).Select appropriate unitfrom list. If other isselected please describeunits in column H at right.Enter the name of the Test Method used.Inocdodededicate whether the testcurred upstream orwnstream of a controlvice(s); list the controlvice(s)If kiln has an in-line raw mill, indicateraw mill status during tests (i.e., rawmill on or raw mill off). Provide anyother information supportinginformation you think is necessaryabout this test report.Sample Date (mm/dd/yyyy)HCl Concentrationppmvd @ 7% O2Exhaust Stream %Moisture%Exhaust Flowrate(select flowrate units)Exhaust Temperature(select temperature units)Sample Date(mm/dd/yyyy)HCl Concentration@ppmvd7% O2Exhaust Stream %Moisture%Exhaust Flowrate(select flowrate units)Exhaust Temperature(select temperature units)Notes:Peach shaded cells indicate areas where the user will enter a responselue in drypmvd)the testlimit,it inWorksheet Title:HCl Emission Test Results Template Using Method 321Who Should Complete this Spreadsheet?Facilities that use Method 321 to test for HClCompany Name:Facility Name:Address:City:State:Kiln ID:Kiln Type:Indicate whether the kiln is wet, long dry, PH, PH/PCIn-line Raw Mill:Yes or NoControl Device Configuration:Enter all installed air pollution control devices hereParameter Sample #1 Sample #2 Sample #3 Test AverageUnits Units Other DescriptionTest MethodUsedTest LocationNoteEnter HCl concentration vaparts per million volume (pcorrected to 7% oxygen. Ifresults are below detectionplease note the detection limbrackets(e.g., [< 0.010]).Select appropriate unitfrom list. If other isselected please describeunits in column H at right.Enter the name of the Test Method used.Inocdodededicate whether the testcurred upstream orwnstream of a controlvice(s); list the controlvice(s)If kiln has an in-line raw mill, indicateraw mill status during tests (i.e., rawmill on or raw mill off). Provide anyother information supportinginformation you think is necessaryabout this test report.Sample Date (mm/dd/yyyy)HCl Concentrationppmvd @ 7% O2Exhaust Stream %Moisture%Exhaust Flowrate(select flowrate units)Exhaust Temperature(select temperature units)Sample Date(mm/dd/yyyy)HCl Concentration@ppmvd7% O2Exhaust Stream %Moisture%Exhaust Flowrate(select flowrate units)Exhaust Temperature(select temperature units)Notes:Peach shaded cells indicate areas where the user will enter a response