ATTACHMENT H

 October 30, 2007 rotary kiln emissions test summary report

(letter dated 11/12/07)
EMISSION TEST REPORT

FOR NOx AND S02 EMISSIONS FROM ROTARY KILN

O-N Minerals (Chemstone) Company

Strasburg, Virginia

November 2007

Prepared by:

Phillip Juneau

Air Control Techniques, P.C.

301 East Durham Road

Cary, North Carolina 27513

Prepared for:

Karl Everett, PE

O-N Minerals (Chemstone) Company

1696 Oranda Road

Strasburg, Virginia 22657

ATPC Job No. 1405

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__r-,~.' ~T = Control TechniQuesl P.C.
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I=MISSION TEST REPORT CERTIFICATION

The sampling and analytical procedures described in this report were carried out under my direct

supervision. The information contained in this report is, to the best of my knowledge and belief,

true, accurate, aua-oomDlete.

I have reviewed this test report. The information contained in this report is, to the best of my

knowledge and belief, true, accurate, and complete.

ohn Richards, Ph.D., P.E.

President, Air Control Techniques, P.C.

/IbJ...o-r

Date
1. INTRODUCTION

1.1 SUMMARY OF TEST PROGRAM

Air Control Techniques, P.c. conducted an emission evaluation for O-N Minerals (Chemstone)

Company in Strasburg, Virginia. Testing was conducted for nitrogen oxides (NOx), and sulfur

dioxide (S02)' The testing was conducted provide additional data for the facility's emission inventory

and to evaluate the ability of the unit to meet the proposed emission limits in draft Air Permit Number

80252. The test program was conducted on October 30, 2007. A test plan to measure NOx and S02

emissions at the baghouse inlet for a 24-hourtest (three 8-hour test runs) was submitted to the Virginia

Department of Environmental Quality (DEQ) on October 15,2007. Subsequently, a test plan was

submitted on October 28,2007 to conduct S02 testing only at the baghouse outlet. Just prior to the

start of testing on October 30,2007, O-NMinerals personnel decided to conduct NOx emission testing

with the S02 emission testing. Copies of the test plans and e-mail communications with Virginia DEQ

are included in Appendix E of this report.

This test report has been prepared in accordance with the recommendations included in the EPA

publication titled, "Guidebook, Preparation and Review of Site-Specific Test Plans," revised March

1999 and available on the Environmental Protection Agency (EPA) Technical Transfer Center (TTN)

electronic bulletin board. This report provides a detailed description of the test program.

The test program conducted on the Rotary Kiln Baghouse (ID U5) included EPA Methods 1,2, and 4

for volumetric flow rate and moisture content and EPA Methods 3A, 6C, and 7E for concentrations of

O2,C02, S02, and NOx. Sampling was conducted at the baghouse inlet duct and from a sampling

array at the baghouse outlet. The sampling array was constructed to meet the requirements of EPA

Method5D.

1.2 KEY PERSONNEL

The O-N Minerals contact for this test project is Mr. Karl Everett. Mr. Everett serves as the point of

contact for the Virginia Department of EnvironmentalQuality. Air emission testing was performed by

Air Control Techniques, P.C. Mr. Phillip Juneau wasthe project manager for this testing project. Onsite personnel for Air Control Techniques, P.C. included Mr. Juneau and Mr. Tom Holder. Mr. Barry

F. Brandon from the Virginia Department of Environmental Quality observed the emission testing onsite. Contact names, addresses, and phone numbers are provided below:

Mr. Karl D. Everett, PE

Senior Environmental Health & Safety Manager

O-N Minerals Chemstone Operation

1696 Oranda Road

Strasburg, Virginia 22657

Tel: 540-465-6822

Mr. Phillip Juneau

Project Manager

Air Control Techniques, P.C.

301 E. Durham Road

Cary, North Carolina, 27513

Tel: (919) 460-7811

Air Control Techniques, P.c. 1 November 2007
O-N Minerals (Chemstone) Company Strasburg, Virginia

2. SUMMARY AND DISCUSSION OF RESULTS

2.1 SUMMARY OF RESULTS

Table 2-1 presents the results from the sampling for the Rotary Kiln. Table 2-1 also includes the

required process parameter data.

"Emission limit for NOx ITomdraft air permit number 80252.

~mission limit for SO~from draft air pe!!!'it number 80252 based on a limit of 38 tonsiyear assuming 365 days of operation

at 24 hours per day.

Air Control Techniques, P.C. 2 November 2007

Table 2-1. NOx and S02 Emissions

Rotal"J Kiln Ba2house

Proposed

Parameter Run 1 Run 2 Run 3 Average Limit

Test date 10/30/07 10/30/07 10/30/07

Test time 15:52-16:52 17:51-18:51 19:38-20:38

Gaseous Emissions

NOx (lb/hr) 82.8 65.7 68.6 72.4 < 87.0.

S02 (lb/hr) 65.4 77.1 55.6 66.1 < 8.68D

Process Data

Coal Feed, Ibs/hr 9135 9067 9168 9112 N/A

Limestone Feed, Tons/hr 52.6 48.9 48.6 50.0 N/A

Kiln Strokes, Strokes/hr 212 197 196 202 N/A

Lime Production, TonslHr 26.29 24.43 24.30 25.01 N/A

Baghouse Pressure Drop N/A

Module 1,In. H2O 0.5 0.5 0.5 0.5 N/A

Module 2, In. H2O 1 1 1 1.0 N/A

Module 3, In. H2O 5 4 4.5 4.5 N/A

Module 4, In. H2O 2.5 2 2 2.2 N/A

Module 5, In. H2O 4 4 3 3.7 N/A

Module 6, In. H2O 2 1.5 1 1.5 N/A

Module 7, In. H2O 7 5 6.5 6.2 N/A

Module 8, In. H2O 5.5 4.5 4 4.7 N/A

Additional Emission Test Parameters

Inlet Flue Gas Flow, 70,469 69,923 69,483 69,958 N/A DSCFM

Inlet Oxygen, % 11.4 11.4 11.5 11.4 N/A

Inlet Moisture, % 4.0 4.0 3.5 3.77 N/A

Inlet Temperature, of 469 470 472 470 N/A

Outlet Oxygen, % 13.5 13.4 13.6 13.5 N/A

Outlet Flue Gas Flow, 90,128 88,550 89,860 89,513 N/A DSCFM

Outlet Temperature, of 192 194 195 194 N/A
O-N Minerals (Chemstone) Company Strasburg, Virginia

2.2 Discussion of Results

The average emission results for NOx were within the proposed emission limit specified in the draft

air permit, however, the S02 emission results were much higher than the proposed limit in the draft

permit.

A description of how the process operational parameters were recorded during the test is provided in

Section 3.2 of this report. The draft air permit lists the production capacity of the Rotary Kiln as 25

tons per hour of lime. During this test program, the average lime production rate was 25.0 tons per

hour.

Example calculations and calculation summariesfor each test run are provided in Appendix A of this

report. Appendix B contains the field data sheets for the flow and instrumental reference method

testing. Plant process parameter data are provided in Appendix C. Appendix D contains the test

equipment calibration documentation and calibration gas certification sheets. Appendix E contains

copies of the Test Plans and e-mail correspondencewith Virginia DEQ.

2.3 Test Anomalies and Deviationsfrom Test Plan

All of the emission testing procedures in the Site-Specific Test Plan were followed except for the

following:

. Emission testing was based on two test plans that were submitted to Virginia DEQ,

however, the NOx emission testing was conducted using three one-hour runs instead of

three eight-hour runs.

The test program was conducted on October 30, 2007. A test plan to measure NOx and S02 emissions

at the baghouse inlet for a 24-hour test (three 8-hour test runs) was submitted to the Virginia

Department of Environmental Quality (DEQ) on October 15,2007. Subsequently, a test plan was

submitted on October 28, 2007 to conduct S02 testing only at the baghouse outlet. Just prior to the

start of testing on October 30, 2007, O-NMinerals personnel decided to conduct NOx emission testing

with the S02 emission testing. Copies ofthe test plans and e-mail communications with Virginia DEQ

are included in Appendix E of this report.

Air Control Techniques, P.C. 3 November 2007