Environmental Sampling 

Stack Sampling and Analysis 

Mobile Laboratory

Route 2, Box 33-B,

(304) 755-1077 Fax (304) 755-1099

www. testincorp.com

Poca, West Virginia 25159

TEST, Inc.

 EVIRONMENTAL PROTECTION AGENCY 

 INFORMATION COLLECTION RULE 

STACK TEST PROTOCOL 

 FELMAN PRODUCTION, LLC

LETART, WEST VIRGINIA 

 FURNACE #2 BAGHOUSE (ID#001-01) 

 FURNACE #5 BAGHOUSE (ID#001-02) 

 WVDEP DAQ PERMIT # R30-05300004-2007

PLANT ID# 03-54-05300004

MARCH 1, 2013 

 

 

TEST, INCORPORATED

Technical Environmental Services Team 

 Route 2, Box 33-B, Poca, West Virginia 25159 Ph: (304) 755-1077 Fx: (304) 755-1099
Environmental Sampling 

Stack Sampling and Analysis 

Mobile Laboratory

Route 2, Box 33-B,

(304) 755-1077 Fax (304) 755-1099

www. testincorp.com

Poca, West Virginia 25159

TEST, Inc.

Table of Contents 

Statement of Verification 

Stack Test Protocol Summary 

Introduction 

Description of Process 

Variances/Exemptions 

Sampling and Analytical Procedures 

Sampling Location 

Safety 

 Example Calculations and Data Sheets 

Equipment Calibration 

Attachments 

Environmental Sampling 

Stack Sampling and Analysis 

Mobile Laboratory

Route 2, Box 33-B,

(304) 755-1077 Fax (304) 755-1099

www. testincorp.com

Poca, West Virginia 25159

TEST, Inc.

STACK TEST PROTOCOL SUMMARY 

I. Source Information: 

 A. Name: Felman Production, LLC

 B. Address: 4442 Graham Station Rd. 

 Letart, West Virginia 25253 

 C. Person to Contact: John Konrady 

 D. Title: Plant Manager 

 E. Telephone: (304) 882-1401 

 E. Name of Sources: Furnace #2 Baghouse (ID#001- 01) 

 Furnace #5 Baghouse (ID#001- 02) 

 F. Permit Number: WV DAQ R30-05300004-2007 

 G. Facility ID: 03-54-05300004 

 

II. Testing Firm Information: 

 A. Name: TEST, Inc. 

 B. Address: Route 2, Box 33-B, 

 Poca, West Virginia, 25159 

 C. Person to Contact: Paul Chinuntdet, President 

 D. Telephone: (304) 755-1077 

III. Tentative Test Date: 

 A. Date: March 13-March 22, 2013 

 B. Time: 8:00-20:00 

IV. Sampling Information 

 A. Pollutants to be sampled: PM, HCl, PCB’s, D/F, PAH’s, As, Cd, Cr, 

Hg, Mn, Ni, and Pb

 B. EPA Methods: EPA 1, 2, 3A, 4, 5D, 9, 26A, 29, and 30B; 

CARB 428 and 429 

 C. Number of sample runs: 3 per method 

 D. Number of sample points: 12 

 E. Minimum Sample Time: see table 

F. Minimum Sample Volume: see table 

V. Sampling Locations: 

 A. Stack height: see attachment 

 B. Inside diameter: see attachment 

 C. Sampling ports height above ground: see attachment 

 D. Port to upstream distance: see attachment 

 E. Port to downstream distance: see attachment 

 
Environmental Sampling 

Stack Sampling and Analysis 

Mobile Laboratory

Route 2, Box 33-B,

(304) 755-1077 Fax (304) 755-1099

www. testincorp.com

Poca, West Virginia 25159

TEST, Inc.

Felman Production, LLC

Letart, West Virginia 

Furnace #2 Baghouse (ID#001 - 01) 

Furnace #5 Baghouse (ID#001 - 02) 

 

WVDEP DAQ Permit # R30-05300004-2007

Plant ID# 03-54-05300004

 

INTRODUCTION

Stack emission testing is to be performed at Felman Production, LLC located in Letart, West 

Virginia, by TEST, Incorporated, of Charleston, West Virginia. The purpose of the testing is to 

provide emissions data to substantiate the actual emissions from the three baghouses. The 

testing will be performed to determine the concentrations of particulate matter, hydrogen 

chloride, multiple metals (arsenic, cadmium, chromium, manganese, nickel, and lead), 

dioxins/furans, poly chlorinated biphenyls (PCBs), mercury, and polycyclic aromatic 

hydrocarbons, being emitted into the atmosphere via the Furnace #2 Baghouse and Furnace #5 

Baghouse. The testing will be performed according to the Appendix to the Code of Federal 

Regulations, Title 40, Chapter 1, Part 60, Methods 1, 2, 3A, 4, 5D, 26A, 29, 30B, and California 

Air Resources Board Methods 428 and 429. 

DESCRIPTION OF PROCESS

Felman Production, LLC manufactures manganese and silicon based ferroalloys and is covered 

by Standard Industrial Classification (SIC) codes 3313 and 3341. The facility consists of three 

electric submerged arc furnaces, associated sizing equipment and environmental controls. 

REQUESTED VARIANCES/EXEMPTIONS

There are no requests for variances to the proposed methods. 
Environmental Sampling 

Stack Sampling and Analysis 

Mobile Laboratory

Route 2, Box 33-B,

(304) 755-1077 Fax (304) 755-1099

www. testincorp.com

Poca, West Virginia 25159

TEST, Inc.

PROPOSED SCHEDULE

The following schedule will be used for the test program at Felman Production, LLC

March 13 – 3 one hour runs each Hg and PAH 

March 14 – 3 four hour runs PM/Multiple metals 

March 15 – 3 two hour runs each HCl and D/F – PCB’s

 Move to Baghouse #2 

March 18 – 3 one hour runs each Hg and PAH 

March 19 – 3 two hour runs each HCl and D/F – PCB’s

March 20 – 3 four hour runs PM/Multiple Metals 
Environmental Sampling 

Stack Sampling and Analysis 

Mobile Laboratory

Route 2, Box 33-B,

(304) 755-1077 Fax (304) 755-1099

www. testincorp.com

Poca, West Virginia 25159

TEST, Inc.

SAMPLING AND ANALYTICAL PROCEDURES

The testing will follow the procedures in the Appendix to the Code of Federal Regulations, Title 

40, Chapter 1, Part 60, Methods 1, 2, 3A, 4, 5D, 26A, 29, and 30B; and CARB 428 and 429. 

 Number Minimum Minimum 

Baghouse Of runs per Sample Vol. Run Time 

 Parameter Number Baghouse (DSCF) (Mins)

 Particulate matter 2 and 5 3 142 240 

 Multiple metals 2 and 5 3 142 240 

 PAHs 2 and 5 3 36 60 

 Mercury 2 and 5 3 1.70 60 

 Dioxin/Furans/PCBs 2 and 5 3 72 120 

 Hydrogen chloride 2 and 5 3 72 120 

Leak checks will be performed on the sampling trains before and after each run to prevent 

contamination. All components of the sampling train will be cleaned prior to each run. 

 

Velocity

The velocity and stack temperature will be measured according to EPA Methods 1 and 2 at the 

inlet ducts of each baghouse. Twelve traverse points will be used to measure the velocity at 

each of two ports for a total of twenty four traverse points. A Type-S Pitot tube and oil gauge 

manometer will be used to measure the velocity pressure in the inlet duct. The stack 

temperature will be measured using a type-K thermocouple and digital temperature indicator. 

Moisture

The flue gas moisture will be determined according to EPA Method 4. The moisture will be 

determined by measuring the “back-half” of the particulate matter sampling train.
Environmental Sampling 

Stack Sampling and Analysis 

Mobile Laboratory

Route 2, Box 33-B,

(304) 755-1077 Fax (304) 755-1099

www. testincorp.com

Poca, West Virginia 25159

TEST, Inc.

Hydrogen chloride

The hydrogen chloride samples will be taken according to EPA Method 5D and 26A. For each 

run, samples of ten minute duration will be taken isokinetically from each of the twelve traverse 

points for a total sampling time of 120 minutes. The minimum sample volume will be at least 72

dscf. Data will be recorded in five minute intervals. Blank samples will be collected for each 

reagent used during sampling and analyzed for contamination. 

The "front-half" of the sampling train will consist of a glass nozzle, heated glass probe (248oF), 

and heated teflon filter support with a quartz fiber filter (248oF). The "back-half" of the sampling 

train will contain the following impingers: 

Impinger Contents Amount Parameter

 1 0.1 N H2SO4 100 ml. HCl 

 2 0.1 N H2SO4 100 ml. HCl 

 3 Empty ----- Moisture 

 4 Silica Gel 400 g Moisture 

The “front-half” of the sampling train will be rinsed with acetone and recovered into an amber 

glass sample container. The filter will be recovered and placed into container. The “back-half” of 

the sampling train, Impingers 1, 2, and 3, will be measured to determine moisture content, rinsed 

using de-ionized water, and recovered in amber glass sample jars. Impinger 4 will be measured to 

determine moisture content. 

The hydrogen chloride samples will analyzed according to EPA Method 26A using ion 

chromatography by Resolution Analytics, Inc. located in Sanford, North Carolina. 
Environmental Sampling 

Stack Sampling and Analysis 

Mobile Laboratory

Route 2, Box 33-B,

(304) 755-1077 Fax (304) 755-1099

www. testincorp.com

Poca, West Virginia 25159

TEST, Inc.

Particulate Matter/Multiple Metals

The multiple metals samples will be taken according to EPA Methods 5D and 29. For each run, 

samples of twenty-minute duration will be taken isokinetically from each of the twelve traverse 

points for a total sampling time of 240 minutes. Data will be recorded at five-minute intervals. 

The minimum sample volume will be at least 142 dscf. Blank samples will be collected for each 

reagent used during sampling and analyzed for contamination. 

The "front-half" of the sampling train will consist of a glass nozzle, heated glass probe (248oF +

25oF), and heated Teflon filter support with a quartz fiber filter (248oF + 25oF). 

The "back-half" of the sampling train will contain the following impingers: 

Impinger Contents Amount Parameter

 1 5% HNO3/10% H2O2 100 ml Multiple Metals 

 2 5% HNO3/10% H2O2 100 ml Multiple Metals 

 3 Empty --------- Multiple Metals 

 4 Silica Gel 400 g Moisture 

The "front-half" of the sampling train (nozzle, probe, and front-half of filter holder) will be 

rinsed with 0.1 N HNO3 and collected in a leak-free glass sample bottle. The "back-half" 

collections of the sampling train (back-half of filter holder, impingers 1, 2, 3, and 4, and 

connectors) will be measured to determine the moisture content and recovered and rinsed using 

0.1 N HNO3. 

The particulate matter emissions will be determined by gravimetric analysis of the filter and 

acetone front wash. The particulate matter will be determined by TEST, Inc. The metals 

samples will be analyzed for antimony by inductively coupled argon plasma emission 

spectroscopy. The analysis will be performed by Maxxam Laboratories located in Hamilton, 

New Jersey. 
Environmental Sampling 

Stack Sampling and Analysis 

Mobile Laboratory

Route 2, Box 33-B,

(304) 755-1077 Fax (304) 755-1099

www. testincorp.com

Poca, West Virginia 25159

TEST, Inc.

Mercury

The mercury samples will be taken according to EPA Method 30B. For each run, paired samples 

of 120 minute duration will be taken from the center of the baghouse. Data will be recorded at 

five-minute intervals. The minimum sample volume will be at least 1.70 dscf. A field recovery 

test and blank samples will be collected for each reagent used during sampling and analyzed for 

contamination. 

The "front-half" of the sampling train will consist of paired sorbent traps and leak free heated 

probe. The sorbent traps will be recovered after each run and sealed on both ends. The samples 

will be analyzed for mercury by UV AA cold vapor analyzers. The analysis will be performed 

by Ohio Lumex located in Twinsburg, Ohio. 

Dioxins/Furans and Polycyclic Biphenyls

The Dioxins/Furans and PCB’s samples will be taken according to California Air Resources 

Board 428. For each run, samples of ten-minute duration will be taken isokinetically from each of 

the twelve traverse points for a total sampling time of 120 minutes. Data will be recorded at fiveminute intervals. Blank samples will be collected for each reagent used during sampling and 

analyzed for contamination. All glassware, condensers, adsorbing tubes, and filters will be cleaned 

and prepared according to the method. 

The "front-half" of the sampling train will consist of a glass nozzle, heated glass probe (248oF), 

and heated teflon filter support with a glass fiber filter (248oF). 
Environmental Sampling 

Stack Sampling and Analysis 

Mobile Laboratory

Route 2, Box 33-B,

(304) 755-1077 Fax (304) 755-1099

www. testincorp.com

Poca, West Virginia 25159

TEST, Inc.

The "back-half" of the sampling train will contain the following impingers: 

Impinger Contents Amount Parameter

 Condenser Tube 

XAD-2 Trap 

 1 Empty --------- D/F, PCB’s

 2 De-ionized water 100 ml D/F, PCB’s

 3 Empty --------- D/F, PCB’s

 4 Silica Gel 400 g Moisture 

The "front-half" of the sampling train (nozzle, probe, and front-half of filter holder) will be 

rinsed and brushed three times and rinsed with acetone, hexane, and methylene chloride and 

collected in Container 1. The filter will be recovered and placed in Container 2. The “backhalf” of the filter holder, connecting glassware before the condenser, and the condenser will be 

rinsed with acetone, hexane and methylene chloride, and collected in Container 3. The XAD-2 

trap will be recovered and replaced. The impinger collections of the sampling train will be 

measured to determine the moisture content, recovered, and rinsed with acetone, hexane, and 

methylene chloride. 

The samples will be extracted by high-resolution gas chromatography and measured by highresolution mass spectrometry. The analysis will be performed by Maxxam Laboratories in 

Hamilton, New Jersey. 

Polycyclic Aromatic Hydrocarbons

The PAHs samples will be taken according to California Air Resources Board 429. For each 

run, samples of five-minute duration will be taken isokinetically from each of the twelve traverse 

points for a total sampling time of 60 minutes. Data will be recorded at five-minute intervals. 

Blank samples will be collected for each reagent used during sampling and analyzed for 

contamination. All glassware, condensers, adsorbing tubes, and filters will be cleaned and 

prepared according to the method. 
Environmental Sampling 

Stack Sampling and Analysis 

Mobile Laboratory

Route 2, Box 33-B,

(304) 755-1077 Fax (304) 755-1099

www. testincorp.com

Poca, West Virginia 25159

TEST, Inc.

The "front-half" of the sampling train will consist of a glass nozzle, heated glass probe (248oF), 

and heated teflon filter support with a glass fiber filter (248oF). 

The "back-half" of the sampling train will contain the following impingers: 

Impinger Contents Amount Parameter

 Condenser Tube 

XAD-2 Trap 

 1 Empty --------- PAH 

 2 NaHCO3/Na2CO3 100 ml PAH 

 3 NaHCO3/Na2CO3 100 ml PAH 

 4 Empty --------- PAH 

 5 Silica Gel 400 g Moisture 

The "front-half" of the sampling train (nozzle, probe, and front-half of filter holder) will be 

rinsed and brushed three times and rinsed with acetone, hexane, and methylene chloride and 

collected in Container 1. The filter will be recovered and placed in Container 2. The “backhalf” of the filter holder, connecting glassware before the condenser, and the condenser will be 

rinsed with acetone, hexane and methylene chloride, and collected in Container 3. The XAD-2 

trap will be recovered and replaced. The impinger collections of the sampling train will be 

measured to determine the moisture content, recovered, and rinsed with acetone, hexane, and 

methylene chloride. 

The samples will be extracted by high-resolution gas chromatography and measured by highresolution mass spectrometry. The analysis will be performed by Maxxam Laboratories in 

Hamilton, New Jersey. 
Environmental Sampling 

Stack Sampling and Analysis 

Mobile Laboratory

Route 2, Box 33-B,

(304) 755-1077 Fax (304) 755-1099

www. testincorp.com

Poca, West Virginia 25159

TEST, Inc.

SAMPLING LOCATION

Measurements and distances will be determined on-site. 

SAFETY REQUIREMENTS

All personnel entering the plant must follow all rules and regulations set by Felman Production, 

LLC general safety rules should be followed which includes protective eyewear, hardhat, and 

work boots throughout the plant and ear protection in specified areas. Protective covering 

should be worn when specified. The protective eyewear should be either ANSI approved safety 

glasses or goggles. Other safety concerns include fall protection, mechanized traffic, and 

excessive heat from the furnaces. All safety concerns are inherent with an industrial 

environment and are not unusual or extreme. 

EXAMPLE CALCULATIONS AND FIELD DATA SHEETS

See following attachments 
Environmental Sampling 

Stack Sampling and Analysis 

Mobile Laboratory

Route 2, Box 33-B,

(304) 755-1077 Fax (304) 755-1099

www. testincorp.com

Poca, West Virginia 25159

TEST, Inc.

EQUIPMENT CALIBRATION

Item Description

Probe Nozzle

By micrometer per EPA Method 5. Three 

separate measurements using different 

diameters each time, and obtain the average of 

the measurements.

Pitot Tube Per EPA Method 2 type pitot tube construction. 

Default 0.84 will be used.

Dry Gas Meter Orifice Manometer Per EPA Method 5 using a wet test meter. Five

(5) point calibration before and after test.

Thermocouple Per EPA Method 2.






Area of measurement site Ao = 6308 ft2

Temp. at measurement site To = 200 (F) 660 ( R )

Ambient temp. Tamb = 86 (F) 546 ( R )

Inlet temp. Ti = 406.5 (F) 866.5 ( R )

Inlet gas volume flow rate Qi = 186,393 (DSCFM) 3106.55 (DSCFS)

Eq. 5D-3 Dilution Air Flow Rate

Qi (Ti-To)

To-Tamb

Eq. 5D-2 Volumetric Flow Rate

Qo = Qi + Qd

Qo = 8733.766 (DSCFS)

Eq. 5D-1 Average Gas Velocity

Qo

Ao

v = 1.384554 (FPS)

v =

(DSCFS)

Method 5D Velocity Calculation

Qd =

Qd = 5627.216



mg 1 gr 60 min 1 lb

Vmstd 64.8 mg 1 hr 7,000 gr

DSCFM* = Stack Flow Rate

Vmstd* = Volume of dry gas sampled at standard

conditions dry standard cubic feet

 * 29.92 "Hg, 68 degrees F (760 mm Hg, 20 degrees C)

DSCFM x

EXAMPLE CALCULATIONS

x x

DIOXINS/FURANS AND PCB'S

lbs/hr = x
mg 1 gr 60 min 1 lb

Vmstd 64.8 mg 1 hr 7,000 gr

DSCFM* = Stack Flow Rate

Vmstd* = Volume of dry gas sampled at standard

conditions dry standard cubic feet

 * 29.92 "Hg, 68 degrees F (760 mm Hg, 20 degrees C)

EXAMPLE CALCULATIONS

PAH'S

lbs/hr = x x DSCFM x x


M428 Page 102
M428 Page 100