## ATTACHMENT H

October 30, 2007 r

otary 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

Preparedby: Phillip Juneau Air ControlTechniques, P.C. 301 East DurhamRoad Cary, North Carolina27513

Prepared for: Karl Everett, PE O-N Minerals (Chemstone) Company 1696OrandaRoad Strasburg, Virginia 22657

ATPC Job No. 1405 

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### I=MISSION TEST REPORT CERTIFICATION

The sampling and analytical procedures describedin this report were carried outunder my direct supervision. The information contained in this report is, to the best ofmy knowledge andbelief, true, accurate, aua-oomDlete.

I have reviewed this test report. The information containedin this report is, to the best ofmy knowledge andbelief, true, accurate, and complete.

ohn Richards, Ph.D., P.E. President, Air Control Techniques, P.C. 

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## bJ...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 fornitrogen oxides (NOx), and sulfur dioxide (S02)' The testing was conductedprovide additional data for the facility's emission inventory and to evaluate the ability ofthe unit to meet the proposed emission limits in draft Air Permit Number 80252. The test program was conducted on October 30, 2007. A testplan to measure NOx and S02 emissions at the baghouse inlet for a 24-hourtest (three 8-hourtest runs) was submitted to the Virginia Department ofEnvironmental Quality (DEQ) on October 15,2007. Subsequently, atest plan was submitted on October 28,2007 to conduct S02 testingonly at the baghouse outlet. Just prior to the start oftesting on October 30,2007, O-NMinerals personnel decided to conduct NOx emission testing with the S02 emission testing. Copies ofthe testplans and e-mail communications with Virginia DEQ are included in Appendix E ofthis report. This test report has been prepared in accordancewith the recommendations included in the EPA publication titled, "Guidebook, Preparation and Review of Site-Specific Test Plans," revised March 1999 and available on the EnvironmentalProtection Agency (EPA) Technical Transfer Center (TTN) electronic bulletin board. This report provides a detailed description ofthe test program. The test program conducted on the RotaryKiln Baghouse (ID U5) included EPA Methods 1,2, and 4 for volumetric flow rate and moisture content andEP A Methods 3A, 6C, and 7E for concentrations of O2,C02, S02, and NOx. Sampling was conducted atthe baghouse inlet duct and from a sampling array at the baghouse outlet. The samplingarray was constructed to meet the requirements ofEP A 

### 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 ofEnvironmentalQuality. Air emission testing was performedby Air Control Techniques, P.C. Mr. PhillipJuneau was the project manager for this testing project. Onsite personnel for Air Control Techniques, P.C. includedMr. Juneau and Mr. TomHolder. Mr. Barry F. Brandon from the Virginia DepartmentofEnvironmental Quality observed the emission testing onsite. Contactnames, addresses, andphonenumbers 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 2007O-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 forthe Rotary Kiln. Table 2-1 also includes the required process parameter data.

"Emissionlimit for NOx ITom draftair permit number 80252. ~mission limit for SO~from draft airpe!!!'itnumber 80252 based on a limitof38 tonsiyear assuming 365 days ofoperation

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 InletFlue 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/AO-N Minerals (Chemstone) Company Strasburg, Virginia

2.2 Discussion of Results
The average emissionresults for NOx were within the proposed emission limit specified in the draft air permit, however, the S02 emissionresults were much higher than the proposed limit in the draft permit. A description ofhow the process operationalparameters wererecorded during the test is provided in Section 3.2 ofthis report. The draft airpermit lists the production capacity ofthe Rotary Kiln as 25 tons per hour oflime. During this testprogram, the average limeproduction rate was 25.0 tons per hour. Example calculations and calculation summariesfor each testrun are provided in Appendix A ofthis report. Appendix B contains the field data sheets for the flow and instrumental reference method testing. Plant process parameter data areprovided in Appendix C. Appendix D contains the test equipment calibration documentation andcalibration gas certification sheets. Appendix E contains copies ofthe Test Plans and e-mail correspondencewith Virginia DEQ.



### 2.3 Test Anomalies and Deviationsfrom Test Plan
All ofthe emission testing procedures inthe Site-Specific Test Plan were followed except for the following:



# . Emission testing was based ontwo testplans that were submitted to Virginia DEQ, however, the NOx emissiontesting was conducted using three one-hour runs instead of three eight-hourruns. The test program was conducted on October30, 2007. A testplan to measure NOx and S02 emissions at the baghouse inlet for a 24-hourtest (three 8-hourtest runs) was submitted to the Virginia Department ofEnvironmental 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 oftesting on October 30, 2007, O-NMinerals personnel decided to conductNOx emission testing with the S02 emissiontesting. Copies ofthe testplans and e-mail communications with Virginia DEQ
are included in Appendix E ofthis report.

Air Control Techniques, P.C. 3 November 2007