MEMORANDIJM

TO: Portland Cement NESHAP Docket

FROM: Keith Barnett, USEPA

SUBJECT: Correspondence with ESSROC Concerning their Response to Request for

information under Authority of Section 114

âoo?

DATE: August 5,1+lt

Attached-to this cover page in reverse chorological order is a series if emails between the

USEPA and Essroc relating to EPA's request for information on mercury, THC, and HCI

emissions..
Fw: Questions on Essroc's Response to EPA Section 114 Request

Keith Barnett to: Keith Barnett

*-- Fonruarded by Keith BarneIURTP/USEPA/US on 08/05/2008 10:38 AM -----

'CHADBOURNE John"

<John.Chadbourne@essroc.c

om>

lOtOgl2OOT 01:54 PM

q.í To

cc

Subject

08/05/2008 10:39 AM

"Laney, Michael N." <mnl@rti.org>

"YBANEZ Hector" <HECTOR.YBANEZ@essroc.com>, Keith

BarnetVRTP/USEPA/US@EPA

RE: Questions on Essroc's Response to EPA Section 114

Request

Mike,

You are correct.

The CKD removed from kiln 1 at Speed is the same as the APCD Dust Returned to kiln L

APCD dust from kiln 1 is stored in a bin and used to manufacture masonry cements.

lf more APCD dust is generated than can be used for finished cement, the dust is returned to kiln 1.

A separate feed system is used to return APCD dust to kíln 1.

It is not mixed with the feed produced in the in-line mill producing kiln feed for both kilns.

No APCD dust is returned to kiln 2.

Mercury is removed and returned to kiln 1 with APCD dust.

This represents an internal recirculating stream rather than a raw material input.

That is the reason that only cKD removed appears in the kiln 1 mass balance.

The distribution of 30 daily composite samples of APCD dust returned to kiln 1 (also CKD removed)

ranged îrom 79.2 ppb to 1 99.9. Either a normal or a log-normal distribution adequately describes these

data.

Using a normal distribution, the mean value was 124.g ppb.

The arithmetic average is also 124.9, The standard deviation is 2S.4 ppb.

For mass balance purposes, we have selected 124.9 ppb.

The mean is estimated to be 122.5 if a log-normal fit of the data is used.

John

From: Laney, Michael N. [mailto:mnl@rti.org]

Sent: Tuesday, October 09,2007 11:05 AM

To: CHADBOURNE John

Cc: barnett.keith@epa.gov

Subject: RE: Questíons on Essroc's Response to EpA Section 114 Request

John,
Thank you for your response. As a follow-up, is the mercury content of the CKD Removed for Kiln 1 at

Speed (Mass Throughput table) what is being reported in the "APCD Dust Returned" table for Speed Kiln

1?

Mike

Mìchael Laney

Envi ronme ntal Engi neering

Environmental Health & Safety Division

RTI lnternational

rEL: 91 9-31 6-341 3

FAx: 919-316-3420

EMATL: mnl@rti.org

-----Original Message-----

From: CHADBOURNE John [maílto:John.Chadbourne@essroc.com]

Sent: Monday, October 08,2007 6:17 PM

To: Laney, Michael N.

Cc: barnett.keith@epa.gov; YBANEZ Hector

Subject: RE: Questions on Essroc's Response to EPA Section 114 Request

Laney,

At Speed kiln 1 produces all of the material called "CKD Removed".

Kiln 2 produces a much smaller amount of "CKD" that is called "Bypass Dusf'.

They are not the same material. The bypass system at Speed was installed

during 2006. That is the reason the mass of CKD (Bypass dust) at Speed is

reported to be 0 tons in 2006. Samples of bypass dust from Speed kiln 2 are

being generated in 2007 and will need to include this material in future mass

balance calculations.

All of the feed at Speed is produced in one in-line mill associated with kiln 2.

The raw mill for kiln 2 is designed to produce the feed for bolh kilns 1 and 2.

The amount of mercury from raw material components, such as flyash, is

apportioned to each kiln based on the totalfeed to the kilns.

At Logansport both the LWDF and the coke were samples and analyzed separately.

The coke samples from kiln 1 contained an average of 3.0 ppb mercury. Coke samples

for kiln 2 averaged 3.3 ppb mercury. These values were estimated from the censored

distribution statistics fit to a normal variate for the values above 5 ppb, recognizing the

total number of samples collected.

LWDF at Logansport during the sampling period in 2007 contained 341 ppb mercury.

The analytical results for 2007 samples were applied to the mass throughput for 2006.

APCD Dust Returned at Logansport is materialcollected in the ESPs that is "promptly"

returned to the kilns after a very short duration in a holding bin. lt is not the same

material as the Reclaimed CKD. Reclaimed CKD is dust that has been placed in an

on-site landfill at a previous time that is now being reclaimed as a raw material component.

One reason that Reclaimed CKD is used at Logansport is to add potassium and sodium

to the mix for cement strength.
To clarify these results, I have attached a worksheet that illustrates the mass balance

calculations.

Only the Speed and Logansport mass balance data have been provided, although we do have

these

data for all of the Essroc kilns. ln the case of Speed, there ís no practical way to sample the feed

to the in-line mill because the "chunks" of raw materials are extremely heterogeneous. The

expected

concentration of the feed to the raw mill has been estimated to be 19.6 ppb based on an input

balance

with the sum of raw material components. At Logansport, both the raw components and the feed

to

the kiln were sampled. The difference between the sum of raw components and the kiln feed

mercury

was 7.5 % during the sampling program.

Please feel free to call me at 610 837 3336 to discuss any further concerns or clarifications.

I would enjoy meeting with you and Steve in the near future to review findings and to explain how

values below detection thresholds (censored values) can be correctly treated with statistical

techniques.

You should also be aware that a number of mercury distributions proved to be log-normal rather

than

normally distributed.

John

From: Laney, Michael N. [mailto:mnl@fti.org]

Sent: Thursday, October 04,2007 B:25 AM

TO: CHADBOURNE John

Cc: barnett.keith@epa.gov

Subject: Questions on Essroc's Response to EPA Section 114 Request

Dear Dr. Chadbourne,

I am the contractor working with Keith Barnett of the EPA to review data your company and others

provided in response to a Section 114 request for information about portland cement

manufacturing. I have reviewed the information on mercury content of raw materials and fuel that

was submitted for several Essroc facilities. After reviewing the information, I have a few questions

and/or need clarifícation regarding some of the information supplied for the facilities in Speed, lN

and Logansport, lN. My questions are listed below. lf you have any questions, please feel free to

contact me or Keith Barnett.

Speed

ln the "CKD Removed" table, mercury content data are reported for "Kiln 2 By-Pass Dust". ls this

the same dust as "CKD Removed" reported in the "Mass Throughputs" table?

A mercury content for "Fly Ash Kiln 2" is reported but no mercury content for fly ash for Kíln 1 is

reported even though, according to the "Mass Throughputs" table, both Kiln 1 and 2 appear to

use Fly Ash. ls the mercury content of fly ash the same for Kilns 1 and 2? lf not, is there fly ash

content data for Kiln 1?

Logansport

ls the Fuel Mercury content data for Logansport Kilns 1 and 2 the combined mercury content of

coke and LWDF? The Mass Throughputs table includes data for both coke and LWDF.
Does the mercury content data in the "APCD Dust Returned" table for Logansport correspond to

the "Reclaimed CKD" for Logansport in the "Mass Throughputs" table?

Thank you for your assistance.

MichaelLaney

Env i ron me ntal Engineeri ng

Environmental Health & Safety Division

RTI lnternational

rEL: 91 9-31 6-341 3

FAx: 91 9-31 6-3420

EMATL: mnl@ñi.org

Essroc Cement Corp.

CONFIDENTIALITY NOTE: This message is intended exclusively for the party or

parties to whom it is addressed. This communication may contain information that is

proprietary, privileged or confidential or otherwise legally exempt from disclosure. If you

are not one of the named addressees, you are not authorized to read, print, retain, copy or

disseminate this message or any part of it. If you have received this message in eror,

please notify the sender immediately by email and delete/destroy all copies of the

message. Any views or opinions presented in this email are solely those of the author and

might not represent those of Essroc Cement Corp.

WARNING: Although Essroc Cement Corp. has taken reasonable precautions to ensure

no viruses are present in this e-mail, the company cannot accept responsibility for any

loss or damage arising from the use of this email or attachments.

Essroc Cement Corp.

CONFIDENTIALITY NOTE: This message is intended exclusively for the party or parties to

whom it is addressed. This communication may contain information that is proprietary,

privileged or confidential or otherwise legally exempt from disclosure. If you are not one of the

named addressees, you are not authori zed to read, print, retain, copy or disseminate this message

or any part of it. If you have received this message in error, please notify the sender immediately

by e-mail and delete/destroy all copies of the message. Any views or opinions presented in this

email are solely those of the author and might not represent those of Essroc Cement Corp.

WARNING: Although Essroc Cement Corp. has taken reasonable precautions to ensure no

viruses are present in this e-mail, the company cannot accept responsibility for any loss or

damage arising from the use of this email or attachments.
Fw: Questions on Essroc's Response to EPA Section 114 Request

Keith Barnett to: Keith Barnett o8/os/200810:39AM

--- Fon¡varded by Keith BarneIURTP/USEPA/US on 08/05/2008 10:38 AM -----

"Laney, Míchael N."

ñ¡úr <mnl@rti.org> To "CHADBOuRNE John" <John.chadbourne@essroc.com> qñ. 

d, 1otogt2oo711:04 AM cc Keirh BarnetuRTp/usEpA/us@EpA

Subject RE: Questions on Essroc's Response to EPA Section 114

Request

John,

Thank you for your response. As a follow-up, is the mercury content of the CKD Removed for Kiln 1 at

Speed (Mass Throughput table) what is being reported in the "APCD Dust Returned" table for Speed Kiln

1?

Mike

Michael Laney

E nvi ron me ntal Enginee ring

Environmental Health & Safety Division

RTI lnternational

rEL: 919-31 6-341 3

FAx: 91 9-31 6-3420

EMATL: mnl@rti.org

----Original Message-----

From: CHADBOURNE John [mailto:John.Chadbourne@essroc.com]

Sent: Monday, October 08,2007 6:17 PM

To: Laney, Michael N.

Cc: barnett.keith@epa.gov; YBANEZ Hector

Subject: RE: Questions on Essroc's Response to EPA Section 114 Request

Laney,

At Speed kiln 1 produces all of the material called "CKD Removed".

Kiln 2 produces a much smaller amount of 'CKD'that is called "Bypass Dusf'.

They are not the same material. The bypass system at Speed was installed

during 2006. That is the reason the mass of CKD (Bypass dust) at Speed is

reported to be 0 tons in 2006. Samples of bypass dust from Speed kiln 2 are

being generated in 2007 and will need to include this material in future mass

balance calculations.

All of the feed at Speed is produced in one in-line mill associated with kiln 2.

The raw mill for kiln 2 is designed to produce the feed for both kilns 1 and 2.

The amount of mercury from raw material components, such as flyash, is

apportioned to each kiln based on the total feed to the kilns.
At Logansport both the LWDF and the coke were samples and analyzed separately.

The coke samples from kiln 1 contained an average of 3.0 ppb mercury. Coke samples

for kiln 2 averaged 3.3 ppb mercury. These values were estimated from the censored

distribution statistics fit to a normal variate for the values above 5 ppb, recognizing the

total number of samples collected.

LWDF at Logansport during the sampling period in 2007 contained 341 ppb mercury.

The analytical results for 2007 samples were applied to the mass throughput for 2006.

APCD Dust Returned at Logansport is material collected in the ESPs that is "promptly"

returned to the kilns after a very short duration in a holding bin. lt is not the same

material as the Reclaimed CKD. Reclaimed CKD is dust that has been placed in an

on-site landfill at a previous time that is now being reclaimed as a raw material component.

One reason that Reclaimed CKD is used at Logansport is to add potassium and sodium

to the mix for cement strength.

To clarify these results, I have attached a worksheet that illustrates the mass balance

calculations.

Only the Speed and Logansport mass balance data have been provided, although we do have

these

data for all of the Essroc kilns. ln the case of Speed, there is no practical way to sample the feed

to the in-line mill because the "chunks" of raw materials are extremely heterogeneous. The

expected

concentration of the feed to the raw mill has been estimated to be 19.6 ppb based on an input

balance

with the sum of raw material components. At Logansport, both the raw components and the feed

to

the kiln were sampled. The difference between the sum of raw components and the kiln feed

mercury

was 7.5 % during the sampling program.

Please feel free to call me at 610 837 3336 to discuss any further concerns or clarifications.

I would enjoy meeting with you and Steve in the near future to review findings and to explain how

values below detection thresholds (censored values) can be correctly treated with statistical

techniques.

You should also be aware that a number of mercury distributions proved to be log-normal rather

than

normally distributed.

John

From: Laney, Michael N. fmailto:mnl@rti.org]

Sent: Thursday, October 04,2007 B:25 AM

To: CHADBOURNE John

Cc: barnett.keith@epa.gov

Subject: Questions on Essroc's Response to EPA Section 114 Request

Dear Dr. Chadbourne,

I am the contractor working with Keith Barnett of the EPA to review data your company and others

provided in response to a Section 114 request for information about portland cement

manufacturing. I have reviewed the information on mercury content of raw materials and fuel that
was submitted for several Essroc facilities. After reviewing the information, I have a few questions

and/or need clarification regarding some of the information supplied for the facilities in Speed, lN

and Logansport, lN. My questions are listed below. lf you have any questions, please feel free to

contact me or Keith Barnett.

Speed

ln the "CKD Removed" table, mercury content data are reported for "Kiln 2 By-Pass Dust". ls this

the same dust as "CKD Removed" reported in the "Mass Throughputs" table?

A mercury content for "Fly Ash Kiln 2" is reported but no mercury content for fly ash for Kiln 1 is

reported even though, according to the "Mass Throughputs" table, both Kiln 1 and2 appear to

use Fly Ash. ls the mercury content of fly ash the same for Kilns I and 2? lf not, is there fly ash

content data for Kiln 1?

Logansport

ls the Fuel Mercury content data for Logansport Kilns 1 and 2 the combined mercury content of

coke and LWDF? The Mass Throughputs table includes data for both coke and LWDF.

Does the mercury content data in the "APCD Dust Returned" table for Logansport correspond to

the "Reclaimed CKD" for Logansport in the "Mass Throughputs" table?

Thank you for your assistance.

MichaelLaney

Envi ron me ntal Engi nee rin g

Environmental Health & Safety Division

RTI lnternational

rEL: 91 9-31 6-341 3

FAX: 919-31 6-3420

EMATL: mnl@rti.org

Essroc Cement Co.p.

CONFIDENTIALITY NOTE: This message is intended exclusively for the party or

parties to whom it is addressed. This communication may contain information that is

proprietary, privileged or confidential or otherwise legally exempt from disclosure. If you

are not one of the named addressees, you are not authorizedto read, print, retain, copy or

disseminate this message or any part of it. If you have received this message in eror,

please notify the sender immediately by email and delete/destroy all copies of the

message. Any views or opinions presented in this email are solely those of the author and

might not represent those of Essroc Cement Corp.

WARNING: Although Essroc Cement Corp. has taken reasonable precautions to ensure

no viruses are present in this e-mail, the company cannot accept responsibility for any

loss or damage arising from the use of this emailor attachments.
Fw: Questions on Essroc's Response to EPA Section 114 Request

Keith Barneü to: Keith Barnett

--- Fon¡¡arded by Keith BarneIURTP/USEPA/US on 08/05/2008 10:38 AM -----

"CHADBOURNE John"

<John.Chadbourne@essroc.c

'l.f' ., om> Í

10/0812007 06:16 PM

"Laney, Michael N." <mnl@rti.org>

Keith BarnetURTP/USEPA/US@EPA, "yBANEZ Hector',

<H ECTOR.YBAN EZ@essroc.com>

RE: Questions on Essroc's Response to EPA Section 114

Reguest

08/05/2008 10:39 AM

To

cc

Subject

Laney,

At Speed kiln 1 produces all of the material called "CKD Removed".

Kiln 2 produces a much smaller amount of "cKD" that is called "Bypass Dust".

They are not the same material. The bypass system at speed was installed

during 2006. That is the reason the mass of cKD (Bypass dust) at speed is

reported to be 0 tons in 2006. samples of bypass dust from speed kiln 2 are

being generated in 2007 and will need to include this material in future mass

balance calculations.

All of the feed at speed is produced in one in-line mill associated with kiln 2.

The raw mill for kiln 2 is designed to produce the feed for both kilns 1 and 2.

The amount of mercury from raw material components, such as flyash, is

apportioned to each kiln based on the totalfeed to the kilns.

At Logansport both the LWDF and the coke were samples and analyzed separately.

The coke samples from kiln 1 contained an average of 3.0 ppb mercury. Coke samples

for kiln 2 averaged 3.3 ppb mercury. These values were estimated from the censored

distribution statistics fit to a normal.variate for the values above 5 ppb, recognizing the

total number of samples collected.

LWDF at Logansport during the sampling period in 200T contained 341 ppb mercury. Ïhe analytical results for 20Q7 samples were applied to the mass throughput for 20Ó6.

APCD Dust Returned at Logansport is material collected in the ESPs that is "prompfly,,

returned to the kilns after a very short duration in a holding bin. lt is not the same

material as the Reclaimed CKD. Reclaimed CKD is dust that has been placed in an

on-site landfill at a previous time that is now being reclaimed as a raw material component.

One reason that Reclaimed CKD is used at Logansport is to add potassium and sodium

to the mix for cement strength.

To clarify these results, I have attached a worksheet that illustrates the mass balance calculations.

Only the Speed and Logansport mass balance data have been provided, although we do have these

data for all of the Essroc kilns. ln the case of Speed, there is no practical way to sample the feed

to the in-line míll because the "chunks" of raw materials are extremely heterogeneous. The expected

concentration of the feed to the raw mill has been estimated to be 19.6 ppb based on an input balance

with the sum of raw material components. At Logansport, both the raw components and tlre feed to
the kiln were sampled. The difference between the sum of raw components and the kiln feed mercury

was 7.5 % during the sampling program.

Please feelfree to call me at 610 837 3336 to discuss any further concerns or clarifications.

I would enjoy meeting with you and Steve in the near future to review findings and to explain how

values below detection thresholds (censored values) can be correctly treated with statistical techniques.

You should also be aware that a number of mercury distributions proved to be log-normal rather than

normally distributed.

John

From: Laney, Michael N. [maílto:mnl@di.org]

Sent: Thursday, October 04,2007 B:25 AM

To: CHADBOURNE John

Cc: ba rnett. keith@epa.gov

Subject: Questions on Essroc's Response to EPA Section 114 Request

Dear Dr. Chadbourne,

I am the contractor working with Keith Barnett of the EPA to review data your company and others

provided in response to a Section 1 14 request for information about portland cement manufacturing. I

have reviewed the information on mercury content of raw materials and fuel that was submitted for several

Essroc facilities. After reviewing the information, I have a few questions and/or need clarification regarding

some of the information supplied for the facilities in Speed, lN and Logansport, lN. My questions are listed

below. lf you have any questions, please feel free to contact me or Keith Barnett.

Speed

ln the "CKD Removed" table, mercury content data are reported for "Kiln 2 By-Pass Dust". ls this the

same dust as "CKD Removed" reported in the "Mass Throughputs" table?

A mercury content for "Fly Ash Kiln 2" is reported but no mercury content for fly ash for Kiln 1 is reported

even though, according to the "Mass Throughputs" table, both Kiln 1 and 2 appear to use Fly Ash. ls the

mercury content of fly ash the same for Kilns I and 2? lf not, is there fly ash content data for Kiln 1?

Logansport

ls the Fuel Mercury content data for Logansport Kilns 1 and 2 the combined mercury content of coke and

LWDF? The Mass Throughputs table includes data for both coke and LWDF.

Does the mercury content data in the "APCD Dust Returned" table for Logansport correspond to the

"Reclaimed CKD" for Logansport in the "Mass Throughputs" table?

Thank you for your assistance.

MichaelLaney

E nviron me ntal E ngi neering

Environmental Health & Safety Division

RTI International

rEL. 91 9-31 6-341 3

FAx: 91 9-31 6-3420

EMATL: mnl@rti.org
Essroc Cement Corp.

CONFIDENTIALITY NOTE This message is intended exclusively for the party or parties to

whom it is addressed. This communication may contain information that is proprietary

privileged or confidential or otherwise legally exempt from disclosure. If you are not one of the

named addressees, you are not authorizedto read, print, retain, copy or disseminate this message

or any part of it. If you have received this message in error, please notify the sender immediately

by e-mail and delete/destroy all copies of the message. Any views or opinions presented in this

email are solely those of the author and might not represent those of Essroc Cement Corp.

WARNING: Although Essroc Cement Corp. has taken reasonable precautions to ensure no

viruses are present in this e-mail, the company cannot accept responsibility for any loss or Åì .Jl

damage arising from the use of this email or attachmenfs. Losan-Speed-EPA.xls
Speed Kiln I Mercury 2006 Froduction

Samples Collected June 20A7 îor BPA I l4

Maærial Tonnes ppb Hg Contributes Totals IN

Feed 514,794 18.0 9266294

Limestone 4l:2688 2.6 I l¿[3980 Clay 55163 55.7 3074753

Bottom Ash 16925 234.2 3964ßA

Iron 4498 2.4 l08iî7

Flyash 5656 l7l.l 968064 9162103

Fuel 58,154 63.7 3703849 13.0 Clinker 292,128 0.0 0 OUT

CKD Removed 52,698 124.9 6580309 6.580309

Stack 6285643

SRE Sl.la/o

Fuel Hg 28.80/o

Emission Factor

mg Hg/MT Clinker

kdyr

TotalHg 65.4lblyr

lb/yr

Stack

CKD

21.5

6.4

r3.8

14.5

Stack Test grams/hr

2006 Hrs 7745 lb/yr Stack No Stack Tests
Speed Kiln 2 Mercury 2006 Production

Samples Collected June 2007 for EPA I 14

Material

Feed

Limestone

Clay

Bottom Ash

lron

Flyash

Fuel

Clinker

CKD Removed

Emission Factor

mg HglMT Clinker

kglyr

lblyr

lblyr

Stack Test gramdhr

2006 Hrs

lb/yr

Tonnes ppb Hg

86r t55 t8.0

72361s 2.6

92253 55.7 2$A4 234.2

7522 2.4 9460 r7r.r

83,753 96.7

57A,233 0.0

0 4.6

Contributes Totals IN

15500790

r9r3r59

5142102

6629962

18t90

1619025 t5322437

8t00226 23,6

O OUT

00

23422663

0.0o/o

34.60/s

Stack

CKD

Stack

Stack

SRE

Fuel Hg

4t.l

23.6

51.5

0.0

8t43

No Stack Tests
Logansport Kiln I Mercury 2006 Production

Samples Collected June 2007 for EPA I 14

Matorial

Feed

Limestone

Fly Ash

Bottom Ash I

Bottom Ash 2

Alumina

Reclaimed CKD

Clay

Coke

LWDF

Clinker

CKD Removed

Hg Difference %

Emission Factor

mg HglMT Clinker

kúw

49.3lblyr

lb/yr

Stack Test gramVhr

2006 Hrs

lblyr

Tonnes

Stack

62.0

11.0

24.1

12.0

7655

Hrdt/F Kilns

ppb Hc

303,657

254,276

17,470

I1,659

229

1,145

737

8,693

14,994

30,524

176,983

25,751

-7.5o/o Stack

SRE

Fuel Hg

Contributes Totals IN

19.6 5957213

t.9 474523

257.3 4495004

ts.t t76214

213.6 48846

6.5 7386

232j 17t370

t9.4 168749 554209t

3.0 4M9l

.ì4r.0 t0408708 I6.4t0 0.0 0 ouT

2n.l 5436538 s.437

10973873

33.1o/o

63.7o/o

ToralHg Stack

CKD
Logansport Kiln 2 Mercury Tests Nov 2006

Samples Collected June 2007 for EPA I 14

Material Tonnes ppb Hg Contributes Totals IN

Feed 295,779 19.6 5802660

Limestone 247,679 1.9 462212

Fly Ash 17,016 257 .3 4378386

Bottom Ash I 11,355 l5.l 171642

Bottom Ash 2 223 213.6 475X9

Alumina l,l 15 6.5 7194

Reclaimed CKD 718 232.5 166924

Clay 8,467 19.4 164371 5398309 Coke 13,666 3.3 44537

LWDF 32,233 J41.0 t0ggl4l7 t6.839 Clinker 172,851 0.0 0 OUT

CKD Removed 24,042 225.5 5422465 5r''22

Stack 11416149

sRE 32.20À

FuelHg 65.5%

Emission Factor

mg HglMT Clinker 66.0

kdw I1.4 lb/yr Stack 25.1

lbty CKD I1.9

Stack Test grams/hr

7782

HWF Kilns
t;

Fw: Questions on EssroCs Response to EPA Section 114 Request

Keith Barnett to¡ Keit|t larnett 0B/05/200810:39AM

--- Forwarded by Keith BameIURTP/USEPA/US on 08/05/2008 10:38 AM ---

'Laney, Michael N."

<mnl@rt¡.org>

1010412007 08:31 AM

Dr. Chadbourne,

I have one other question that I did not include in my previous e-mail. ln the "Mass Throughputs" table for

Martinsburg, the amount of limestone used is reported, but there are no mercury content data for

limestone in the "Raw Material Components" table for Martinsburg. Are that data available?

Thank you.

Michael Laney

Envi ronmental Engi neering

Environmental Health & Safety Division

RTI lnternational

rEL: 919-316-3413

FAX: 919-316-3420

EMATL: mnl@rti.org

To <John.Chadbourne@essroc.com>

cc Keirh BarneruRTP/usEPA/us@EpA

Subject Questions on Essroc's Response to EPA Section 114

Request
Fw: Essroc Mercury Concentrations and Mass throughputs

Keith Barnett to: Keith Barnett

---- Fonryarded by Keith BarneIURTP/USEPA/US on 08/05/2008 10:37 AM ---

'CHADBOURNE John"

<John.Chadbourne@essroc.c

om>

0812712007 06:46 PM

q.t/

08/05/2008 10:39 AM

To Keith BarnetURTp/USEpA/US@EpA

cc "YBANEZ Hector" <HECTOR.YBANEZ@essroc.com>

Subject Essroc Mercury Concentrations and Mass throughputs

Keith,

I have attached the mercury analyses results for all seven of the Essroc plants and the material

throughputs for 2006 at each plant.

I understand that you received the mercury results and mass throughputs by email earlier this month.

This email provides provides all of the mercury results in a single email.

As mentioned in my previous email, lwillsend you the completed General Facility lnformation forms later

this week.

John

Essroc Cement Corp.

CONFIDENTIALITY NOTE: This message is intended exclusively for the party or parties to

whom it is addressed. This communication may contain information that is proprietary,

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damage arising from the use of this email or attachme¡fs. Mercury Results EPA-Aus¡2o.xls

irr'1 l-l

2006 Essroc Mass Throughputs.xls
-0005467.x1s

Essroc Fuel Mercury - Wet Kilns

Bessemer Frederick Loqansport Martinsburq

uay No. Kiln 4 Kiln 5 Kiln 1 Kiln 2 Kiln 1 K¡ln 2 Kiln 7 Kiln I K¡ln 9

1

2

3

4

5

6

7

I

I

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

J4U.3

317.8

300.3

301.8

331.9

266.3

284.0

310.5

274.1

237.1

292.0

267.8

302.4

292.1

383.7

288.1

198.8

34'1.3

248.4

270.3

214.3

240.7

350.9

362.8

292.3

359.5

394.5

320.0

302.4

266.8

280.0

250.9

235.6

284.2

233.4

282.3

257.1

254.1

242.2

207.6

227.3

223.9

243.3

246.3

299.3

253.5

192.2

219.3

285.0

236_2

178.4

216.4

243.1

256.7

254.2

229.2

231.0

215.0

211.0

280.1

81.7

87.1

89.0

86.0

NS

NS

NS

NS

NS

66.4

64.0

65.4

68.2

75.8

59.3

76.3

73.8

91.9

78,0

NS

70.4

68.0

52.1

58.6

66.5

66.6

83.2

97.7

84.1

89-4

70.2

77.2

76.6

114.1

81.0

NS

NS

136.4

65.6

62.9

68.7

63.8

58.3

67.9

62.0

74.2

71.8

63.7

67.8

65.9

62.2

61.6

54.6

68.6

NS

72.4

94.0

82.3

64.9

83.2

6.3

5.7

<5.0

<5.0

<5.0

7.1

5.1

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

NS

NS

NS

NS

.<5.0

<5.0

<5.0

<5.0

<5.0

NS

<5.0

7.7

5.7

<5.0

6.0

<5.0

6.0

5.1

<5.0

5.5

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

1 29.4

124.0

1't6.1

1 08.1

112.s

111.2

103.9

138.'l

132.3

108.4

111.2

119.7

124.9

129.1

133.9

146.5

149.1

139.5

156.0

't 65,6

200.1

171.2

150.3

167.5

138.8

123.7

130.3

109.3

119.4

135.3

149.3

151.6

200.9

159.2

KD

KD

KD

KD

KD

KD

KD

140.7

124.1

133.2

157.8

150.4

157.3

140.5

263.9

199.7

172.7

189.9

148.3

164.7

180.0

145.0

147.4

124.5

133.9

148.3

KD

156.3

'ts8.5

150.5

128.8

1 30.1

115.1

116.7

142.7

't42.9

13't.7

144.6

154.0

124.7

162.3

KD

't48.4

174.2

166.1

210.6

166.8

148.3

181.4

167.2

KD

KD

KD

KD

KD

KD

Data Codes

KD Kiln Down

NU Not Used

NS No Sample <5.0 Not Detected
-0005467.x1s

Essroc Fuel Mercury - Dry Kilns

Nazareth San Juan Speed

Dav No. Kiln 1 Primarv Kiln'1 Riser Kiln I Kiln 1 Kiln 2

1 215.4 237.2 118.3 79.3 98.5

2 232.6 290.3 143.9 77.5 103.8

3 221.8 239.3 121.0 51.6 88.7

4 215.3 296.1 125.2 70.1 85.0

5 231.2 262.9 113.5 84.9 114.5

6 243.7 279.1 1'16.0 il.ô 101.7

7 245.4 290.8 125.5 68.0 107.9 I 248.4 283.3 59.4 63.8 99.0

9 335.s 278.9 NS 64.1 87.9

10 314.1 311.6 60.8 60.8 87.3

11 292.9 461.0 65.9 60.6 99.3

12 388.2 466.1 59.6 u.4 87.2

13 360.5 424.0 102.7 60.7 94.4

14 414 0 369.1 59.5 92.0 949

15 429.0 461.2 58.2 64.9 111.7

16 324.2 421.3 50.8 55.2 99.3

17 335.1 NS 56.9 61.8 105.3

18 335.6 431.4 58.6 64.5 110.4

19 329.0 385.0 50.9 60.6 105.5

20 339.1 503.8 56.6 53.5 86.0

21 40s.3 450.1 60.2 54.5 86.3

22 341.4 355.8 KD 55.2 104.9

23 288 0 322.8 KD 59.1 81.4

24 320.0 389.7 KD 58.9 80.4

25 332.8 u7.7 KD 54.9 93.1

26 358.0 460.9 KD 53_'1 88.4

27 3/'6.2 312.1 KD 62.0 99.1

28 194.3 358.1 KD 68.6 101.1

29 274.3 334.0 KD 66.8 104.8

30 269.6 301.'1 KD il.9 93.8

l

mData Codes

NU Not Used

NS No Sample

<5.0 Not Detected
Essroc Mercury - ln-Line Rawmill Discharge

\azareth San Juan SDeed

Day No. Kiln 1 Kiln 1 Kilnl&2

2

3

4

5

6

7

I

o

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

1 872.1

2187.2

1928.0

1660.8

1733.3

1700.1

1537.0

1320.6

1876.2

1054.5

2596.3

1508.9

2317.5

26U.1

3252.7

6302.6

3844.4

3838.1

4717.7

4398.8

4378.8

3955.2

2224.4

2865.1

2566.0

2438.9

2308.s

1951.7

960.2

4659.2

137.0

139.7

221.6

161.5

130.2

115.1

209.1

172.8

KD

142.9

166.5

248.3

223.6

113.9

89.2

74.8

104.5

u.1

111.4

116.3

108.5

KD

KD

KD

KD

KD

KD

KD

KD

KD

59.9

77.5

63.0

s7.2

s3.0

64.5

57.1

58.4

56.2

72.6

55.9

61.0

47.1

48.1

71.1

57.0

52.2

53.2

44.5

42.5

41.5

66.9

51.7

43.4

51.0

51.9

59.5

48.7

64.9

55.0

Data Codes

KD

NU

NS

<5.0

Kiln Down

Not Used

No Sample

Not Detected
Essroc Mercury - lndirect Mill Feed

Bessemer Frederick Loqansport Martinsburg

Dav No. Kiln4&KilnSSlurrv Kilnl&Kiln2Slurrv Kiln 1& Kiln 2 Slurrv Kiln7,8&9Slurrv

1 20.3 6.9 55.9 19.3

2 22.7 7.2 14.9 14.3

3 31.2 6.0 22.O 18.9

4 37.4 6.9 18.8 19.4

5 38.0 6.6 16.1 22.9

b 48.9 NS 26.6 22.4

7 58.3 NS 12.O 20.9

8 44.5 <5.0 22.1 17.0 I 40.8 5.3 19.4 19.5

10 35,0 <5.0 18.3 19.4

11 38.6 10.4 16.2 20.2

12 40.4 <5.0 13.5 19.0

't3 37.5 <5.0 15.2 17.3

14 3s.8 <5.0 19.9 14.5

15 33.3 <5.0 19.5 13.9

16 31.9 5.4 17.4 14.2

17 30.2 5.4 15.5 14.7

18 31.8 5.1 16.3 14.4

l9 30.6 6.6 15.0 13.7

20 30.4 5.3 16.7 13.4

21 29.1 <5.0 16.6 13.3

22 30.4 10.8 '19.5 14.7

23 32.1 6.0 22.5 170

24 37.0 6.0 17.5 15.9

25 33.0 7.8 20.1 15.5

26 29.7 6.4 18.7 16.8

27 27.5 5.5 '17.7 16.4

28 26.O <5.0 24.7 16.2

29 26.1 <5.0 21.0 17.2

30 26.3 6.3 '19.0 15.7

Data Codes

KD Kiln Down

NU I Not Used

Nq No Sample <5.0 Not Detected
Essroc Mercury - CKD Removed

Bessemer Frederick Loqansporl Martinsburq Speed

Day No. Kiln 4 Kiln 5

K1 &K2

ESP

K1&K2

Cvclone Kiln 1 Kiln2 Kiln 7 Kiln 8 Kiln 9

1\iln z

By-Pass

Dust

1

2

3

4

5

b

7

I

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

132.O

278.7

329.9

251.7

276.',|

565.1

176.7

147.1

164.7

124.8

231.1

347.2

142.4

98.7

51.0

324.7

1072.4

369.5

122.2

388.3

111.2

378.7

741.5

679.8

410.2

585.3

682.0

460.3

217.7

25.O

22.7

18.7

't7.9

16.0

41.2

20.6

42.4

26.7

31.6

69.7

107.7

17.8

17.9

18.7

18.6

15,1

13.2

16.9

22.7

25.4

13.0

80.4

26.6

29.5

13.5

21.2

16.7

19.0

13.0

11.0

8.1

10.4

9.6

68.3

NS

NS

NS

NS

9.9

85.3

9s.9

105.6

92.9

6.3

90.3

5.6

98.7

102.4

98.9

90.4

89.8

67.4

34.9

49.3

9.7

60.9

56.2

64.1

69.0

49.3

5ö.2

100.3

't27.4

111.9

91.4

NS

NS

11.6

NS

6.4

6.0

<5.0

5.0

127.6

7.5

75.6

12.O

12.1

12.1

20.1

22.4

13.0

10.7

7.2

54.6

8.8

9.1

'10.8

6.5

10.1

266.7

230.7

299.8

232.7

215.0

225.3

236.2

189.9

215.9

198.6

149.0

165.1

212.9

121.5

1U.5

213.2

211.1

208.5

186.0

NS

NS

NS

NS

204.4

159.5

240.2

267.5

219.8

'183.7

251.3

283.7

267.8

217.7

237.1

194.6

196.0

170.2

168.9

199.2

206.s

187.8

150.3

192.7

146.0

184.5

215.2

216.6

218.6

187.5

240.3

334.8

360.4

380.5

261.2

207.9

221.9

262.0

191.4

193.0

271.9

244.7

83.4

385.4

206.9

281.4

329.3

178.5

129.9

291.2

139.3

126.8

126.7

117.5

231.5

367.4

170.0

'176.1

268.9

171.8

252.6

193.6

320.6

246.2

267_9

<5.0

<5_0

6.2

240.8

253.6

187.1

z5ri. I

66.3

356.2

220.7

272.7

329.1

180.2

128.8

285.1

134.4

134.1

124.5

116.1

225.3

u3.7

157.7

157.4

247.0

166.8

233.8

183.4

334.7

226.7

1U.4

<5.0

5.2

6.8

247.3

265.9

174.3

226.2

92.4

360.3

235.1

269.6

3U.7

170.9

131.1

272.7

146.5

120.9

124.3

111.1

231.6

u5.4

163.0

148.2

248.9

165.1

247.1

184.8

323.4

249.7

277.8

181.2

<5.0

7.4

243.4

256.9

175.1

NS

5.7

<5.0

6.4

<5.0

<5.0

NS

<5.0

NS

<5.0

<5.0

<5.0

<5-0

<5.0

<5.0

<5.0

<5.0

6.1

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

Data Codes

KD

NU

NS

<5.0

Kiln Down

Not Used

No Sample

Not Detected
Essroc Mercury - APCD Dust Returned

Bessemer Looansoort Nazareth San Juan Speed

Dav No. Kiln 4 Kiln 5 Kiln 1 Kiln 2 Kiln 1 Kiln I Kiln'1

1

2

3

4

5

6

7

I

I

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

79.3

65.3

65.7

52.0

105.0

75.3

90.4

58.0

40.8

38.2

104.6

66.2

38.7

30.8

31.8

67.8

48.6

16.3

42.5

33.9

32.O

43.9

42.9

43.0

32.9

49.8

50.3

47.2

22.3

'106 I

14.0

17.8

22.5

22.8

23.6

23.6

37.6

34.4

31.7

25.1

24.9

26.4

24.6

55.4

22.4

21.7

16.4

14.O

19.6

20.8

'13.8

16.5

19.2

16.9

17.3

16.5

15.3

18.3

14.7

23.0

1 77 4

163.1

186.3

146.9

150.3

145.8

146.1

159.2

121.7

173.8

95.2

110.2

125.2

128.5

104.6

163.5

141.6

123.1

140.7

NS

NS

NS

NS

NS

176.1

1s9.9

204.1

149.2

126.1

'116.6

197.3

r 33.6

192.3

149.0

160.4

127.2

1U.1

NS

160.3

183.0

135.7

96.0

93.0

99.9

148.2

166.9

150.4

133.3

189.6

268.5

213.1

268.2

NS

172.6

125.4

'116.6

148.0

118.5

93.9

144.9

101U.1

6650.6

6344.0

6129.1

11474.5

9519.5

9361.2

8758.1

u04.2

7732.5

7286.7

6240 6

10668.9

18808.5

22043.9

24169 3

NS

27384.8

32131.1

30529.8

25423.9

23788.0

22431.1

21649.7

24659.2

22097.4

11955.3

16333.8

1081 1 .0

10771.O

1760.3

916.3

876.4

1174.2

959.3

876.4

1090.5

1198.6

KD

965.8

827.7

1200.2

1708.1

1335.6

1225.O

1946.8

1136.5

503.1

483.1

514.8

421.5

KD

KD

KD

KD

KD

KD

KD

KD

KD

1 29.3

110.9

180.9

121.1

160.2

113.9

108.6

131.7

140.6

199.9

138.5

132.9

145.8

83.7

107.5

79.2

100.8

109.3

140.3

113.2

140.0

110.7

110.8

115.9

122.8

136.4

122.3

101.2

99.4

138.4

Data Codes

KD

NU

NS

<5.0

Kiln Down

Not Used

No Sample

Not Detected
Essroc Mercury - Dry Kiln Feed (Mixed)

1

2

3

4

5

6

7

8

I

10

11

12

13

1837.3

2004.1

2239.5

2163.5

1692.1

1571.4

1391.1

1365.1

1227.O

912.6

1275.8

1965.7

1U7.9

3159.7

6778.0

5633.5

4il5.5

4939.1

5574.3

4796.5

4026.2

3445.7

2682.0

3381.1

3056.2

2699.5

2801.0

1867.6

2620.5

241.3

235.2

253.8

220.8

171.1

189.1

174.0

KD

232.4

191.5

343.5

u7.6

262.8

120.O

88.2

82.5

103.8

119.4

139.2

119.5

KD

KD

KD

KD

KD

KD

KD

KD

KD

il.6

72.5

60.1

52.7

53.4

53.4

61.9

61.9

92.4

55.2

51.6

il.8

47.7

70.8

55.2

54.3

50.0

57.0

44.2

57.1

80.6

56.6

51.6

53.2

59.5

78.2

51.7

46.8

58.0

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

Data Codes

KD

NU

NS

<5.0

Kiln Down

Not Used

No Sample

Not Detected
Essroc Mercury - Raw Material Components

Bessemer Kiln 4 & Kiln 5

Day No. Slurry Limestone MillScale Shale Sand

1

2

3

4

5

6

7

I

o

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

20.3

22.7

31.2

37.4

38.0

48.9

58.3

44.5

40.8

35.0

38.ô

40.4

37.5

35.8

33.3

31.9

30.2

31.8

30.6

30.4

29.1

30.4

32.1

37.O

33.0

29.7

27.5

26.0

26.1

26.3

18.3

25.2

44.1

48.5

42.5

59.8

59.0

36.6

41.6

42.3

54.3

38.4

37.7

50.3

31.1

29.O

32.2

41.0

47.6

28.8

33.6

46.5

47.4

32.7

54.0

32.2

29.3

36.2

25.0

24.7

NU

NU

NU

NU

NU

NU

NU

NU

NU

NU

NU

NU

NU

NU

NU

115.2

151.3

148.2

80.1

84.9

112.6

NU

NU

NU

NU

NU

NU

NU

NU

NU

10.7

15.1

15.8

21.4

17.1

14.3

16.1

18.7

13.0

16.6

16.6

17.4

18.5

13.9

19.7

16.2

42.9

21.2

22.5

13.9

13.5

16.1

16.1

13.5

12.9

15.1

17.3

17.2

24.4

16.6

<5

5.1

5.8

<5

5.8

<5

<5

6.3

8.1

5.9

8.1

6.6

6.7

<5.0

<5.0

5.9

5.9

27.1

14.0

5.3

<5.0

6.1

5.1

7.6

6.0

10.0

6.4

7.9

6.7

8.1

Data Codes

KD

NU

NS

<5.0

Kiln Down

Not Used

No Sample

Not Detected
Essroc Mercury - Raw Material Components

Frederick- Kiln 1 & Kiln 2

Dav No. Slurry

Frederick

Limestone

Martinsburg

Limestone MillScale Sand

1

2

3

4

5

6

7

I

I

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

6.9

7.2

6.0

6.9

6.6

NS

NS

<5.0

5.3

<5.0

10.4

<5.0

<5.0

<5.0

<5.0

5.4

5.4

5.1

6.6

5.3

<5.0

10.8

6.0

6.0

7.8

6.4

5.5

<5.0

<5.0

6.3

<5.0

<5.0

<5.0

<5.0

<5.0

NS

<5.0

<5.0

5.4

5.4

<5.0

<5.0

5.5

<5.0

<5.0

<5.0

5.6

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

5.5

<5.0

<5.0

8.0

<5.0

8.7

<5.0

6.7

<5.0

<5.0

<5.0

<5.0

NS

<5.0

<5.0

5.9

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

6.7

5.3

<5.0

<5.0

<5.0

6.0

<5.0

7.3

7.9

<5.0

<5.0

8.4

17.1

8.4

<5.0

6.0

5.7

6.9

7.7

NS

<5.0

5.7

6.3

7.4

<5.0

<5.0

<5.0

<5.0

<5.0

6.1

<5.0

<5.0

<5.0

7.3

<5.0

5.9

<5.0

6.1

<5.0

5.1

<5.0

<5.0

6.5

<5.0

11.8

20.0

10.3

9.5

10.6

NS

8.3.

9.8

10.2

10.1

7.8

9.9

5.2

<5.0

7.3

7.7

9.6

10.'1

9.7

9.8

10.4

9.7

7.3

7.5

NS

7.9

6.8

8.8

9.1

6.0

Data Codes

KD

NU

NS

<5.0

Kiln Down

Not'Used

No Sample

Not Detected
Essroc Mercury - Raw Material Components

Logansport - Kiln I & Kiln 

2

Dav No. Slurry Limestone

Low C3S

Limestone Fly Ash

Reclaimed

CKD

Bottom Ash 1

Bottom

Ash 2 AlumiNS Clay

1234567I9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

55.9

14.9

22.0

18.8

16.1

26.6

12.0

22.1

19.4

18.3

16.2

13.5

15.2

19.9

19.5

17.4

15.5

16.3

15.0

16.7

16.6

195

22.5

17.5

20.1

18.7

17.7

24.7

21.0

19.0

5.3

<5.0

<5.0

12.0

NS

<5.0

<5.0

<5.0

<5.0

5.6

NS

NS

<5.0

5.0

<5.0

<5.0

<5.0

NS

NS

<5.0

<5.0

<5.0

<5.0

<5.0

NS

NS

<5.0

<5.0

97.8

116.7

78.0

146.4

206.0

110.0

2U.O

276.4

362.8

281.4

309.2

314.3

329.8

333.4

325 1

344.5

241.5

339.1

251.4

245.0

266.8

262.6

NS

292.8

286.6

82.1

72.1

297.0

279.1

285.6

276.0

302.9

215.3

207.1

228.6

226.2

228.6

193.1

NS

241.1

233.3

222.3

218.3

240.0

229.6

222.5

247.3

243.9

251.9

290.2

283.7

NS

NS

275.3

281.4

'188.8

215.5

213.4

NS

NS

217.4

197.6

15.0

10.6

34.6

16.1

oo

10.8

NS

51.0

5.5

6.0

7.1

5.3

NS

NS

19.8

5.7

14.2

295.7

303.6

NS

NS

308.1

295.0

119.9

171.8

152.6

NS

NS

126.7

148.8

5.7

50.8

<5

6.6

20.0

19.9

NS

8.9

NS

<5.0

5.4

11.4

NS

NS

<5.0

<5.0

7.2

8.0

5.4

NS

NS

7.1

<5.0

14.8

14.3

<5.0

NS

NS

7.8

6.4

1 6.7

16.2

17,9

25.6

19.0

20.3

NS

41.8

17.6

to.l

16.5

18.1

NS

NS

12.9

19.7

17.8

18.1

18.7

NS

NS

15.1

15.3

17.O

24.O

16.5

NS

NS

28.6

17.0

Data Codes

KD Kiln Down

NU Not Used

NS No Sample
<5.0 Not Detected
Essroc Mercury - Raw Material Components

Martinsburq - Kiln 7, 8 & 9 and San Juan - Kiln 1

Martinsbur( -Kiln7.8&9 San Juan - Kiln 1

Dav No. Slurry Shale Limestone MillScale

1

2

3

4

5

Þ

7

I

I

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

1 9.3

14.3

18.9

19.4

22.9

22.4

20.9

17.O

19.5

19.4

20.2

19.0

17.3

14.5

13.9

14.2

14.7

14.4

13.7

13.4

13.3

14.7

17.O

15.9

15.5

16.8

16.4

16.2

17.2

15.7

NS

123.3

105.2

108.9

NU

147.5

164.8

NU

190.0

136.3

112.7

NU

34.8

72.8

NU

NU

82.5

80.2

NU

87.2

89.8

53.5

NU

u.7

NU

NU

63.8

54.8

93.4

70.2

23.0

24.8

20.4

18.4

14.6

18.7

16.2

10.6

KD

19.3

22.0

13.8

20.4

11.5

11.3

14.2

8.7

9.5

15.8

26.0

20.2

KD

KD

KD

KD

KD

KD

KD

KD

KD

72.4

53.0

68.9

56.7

85.4

107.0

47.3

41.3

KD

85.9

90.0

84.0

89.5

104.5

104.5

100.2

111.4

81.4

89.0

105.3

119.5

108.8

KD

KD

KD

KD

KD

KD

KD

KD

Data Codes

KD

NU

NS

<5.0

Kiln Down

Not Used

No Sample

Not Detected
Essroc Mercury - Raw Material Components

Nazareth - Kiln 1

Day No. Hioh Limestone Low Limestone lower stone lron Sand

1

2

3

4

5

6

7

I

I

10

't1

12

13

14

15

16

17

18

19

20

21

22

23

24

2

26

27

28

29

30

14.8

7.4

8.2

6.6

9.2

7.4

10.6

11.2

11.0

7.1

15.3

11.7

10.9

10.3

11.5

10.7

11.2

9.6

11.4

9.1

9.4

10.0

8.8

't0.4

11.3

11.5

9.6

12.3

8.5

13.9

9.7

12.2

11.5

8.7

10.8

oo

13.0

8.9

8.9

7.9

10.8

15.1

10.5

13.1

r3.9

11.8

10.5

11.2

12.8

10.6

10.1

11.2

11.3

10.1

33.9

32.8

279.O

111.8

77.4

82.7

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

5.7

9.3

18.9

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

NU

NU

NU

<5.0

<5.0

<5.0

<5.0

NU

NU

5.1

5.9

5.4

<5.0

NU

NU

5.9

NU

<5.0

NU

5.2

<5.0

NU

NU

NU

NU

NU

NU

NU

NU

NU

Data Codes

KD

NU

NS

<5.0

Kiln Down

Not Used

No Sample

Not Detected
Essroc Mercury - Raw Material Components

Speed -Kiln1&Kiln2

Dav No Limestone Clav Bottom Ash lron Flv Ash Kiln 2

1

2

3

4

5

6

7

I

I

10

11

12

13

14

15

16

17

18

r9

20

21

22

23

24

25

26

27

28

29

30

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

5.0

7.1

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

5.6

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

9.8

5.4

6.2

<5.0

<5.0

3.3

<5.0

5.5

3.5

49.3

52.2

54.0

47.5

60.3

52.2

u.7

70.6

77.0

66.5

69.1

71.4

69.2

50.4

54.9

57.7

46.1

34.5

51.7

53.6

53.1

54.4

53.6

s2.6

51.3

55.3

51.1

48.6

50.3

48.9

176.6

267.5

177.4

241.6

382.1

200.3

198.3

161.5

29.7

240.2

269.0

4'18.4

278.9

149.9

180.2

257.3

191.6

282.5

348.0

2U.6

215.9

151.8

272.4

325.8

221.3

209.1

367.6

222.4

162.6

172.8

9.2

10.0

8.0

7.8

7.4

8.1

6.1

16.3

<5.0

<5.0

6.3

7.5

5.2

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

3.4

3.1

<5.0

<5.0

<5.0

<5.0

<5.0

2.8

2.5

206.9

294.5

240.6

204.3

243.8

218.7

190.8

172.8

152.3

148.8

170.6

209.1

123.8

125.4

132.2

131.0

138.6

128.9

190.6

150.8

165.1

183.1

157.3

155.0

178.7

156.4

130.4

169.8

128.2

136.0

Data Codes

KD

NU

NS

<5,0

Kiln Down

Not Used

No Sample

Not Detected
Essrôc Cement Corp

2006 Mass Throughputs by Kiln - Metric Tonnes Dry Basis

Bessemer

Kiln 4

Frederick

Kiln I

Logansport

Kiln I

Martinsburg

Kiln 7

Nazareth

Kiln I

421654 Kiln 5

360726

251

4395 r

9904

56708

251258

34607

172458 Kiln2

t46492

2585 I

I 998

543 I

24906

t02064

7502

7502

303657 Kiln2

254276

t7470

I t658

229

ll45

737

8693

t4994

30524

t76983

25751

353334 Kiln 8

317361

t7320

45413

I 9785 I

35218

1675205

3s2208

r320019

1373

26t5

rr08t8

40987

6 r 8849

529426

369

64505

I 4536

85r30

37076t

5079t

t93626

164473

2902s

2243

6098

29523

I t6289

8547

8547

295779

247679

170 t6

r r355

223

llt5

718

8467

r 3666

32233

t7285t

24042

320743

288087

15722

42681

t78697

3t808

Feed

Limestone

Mill Scale lron

Shale

Sand

Coal

Clinker

CKD Removed

Feed

Fred Limestone

Martin Limestone

Mill Scale lron

Sand

Fuel

Clinker

CKD Removed (ESP)

CKD Removed (Cyclone)

Feed

Limestone

Fly Ash

Bottom Ash I

Bottom Ash 2

Alumina

Reclaimed CKD

Clay

Coke

LWDF

Clinker

CKD Removed

Feed

Limestone

Shale

Fuel

Clinker

CKD Removed

Feed

High Limestone

Low Limestone

lron

Sand

Primary Fuel

Riser Fuel

Feed

Limestone

Mill Scale lron

Shale

Sand

Coal

Clinker

CKD Remove

Feed

Fred Limestone

Martin Limestone

Mill Scale lron

Sand

Fuel

Clinker

CKD Removed (ESP)

CKD Removed (Cyclone)

Feed

Limestone

Fly Ash

Bottom Ash I

Bottom Ash 2

Alumina

Reclaimed CKD

Clay

Coke

LWDF

Clinker

CKD Removed

Feed

Limestone

Shale

Fuel

Clinker

CKD Removed
Clinker 1076085

San Juan

Kiln I Feed 866479

Mixed Limestone 854201

Mill Scale lron I 1088

Fuel 81963

Clinker 562663

Spced

Kiln I Feed

Limestone

ClaY

Bottom Ash

Iron

Flyash

Fuel

Clinker

CKD Removed

514794 Kiln 2 Feed

432688 Limestone

55163 Clay

16925 Bottom Ash

4498 lron

5656 Flyash

58 I 54 Fuel

292128 Clinker

52698 CKD Removed

86r r55

7236t5

92253

28304

7522

9460

81753

5702330
Kiln 9 Feed

Limestone

Shale

Fuel

Clinker

CKD Removed

424484

381267

20807

52852

238997

42541
To: Keith BarneIVRTP/USEPA/US@EPA,

Cc:

Bcc:

Subject: Responses to Questions of section 114 Submittal - lN DOCKET

From: Keith BarneIVRTP/USEPA/US - Tuesday 08/05/2008 10:36 AM

---- Fon¡yarded by Keith BarneIVRTP/USEPA/US on 08/05/2008 '10:35 AM -----

"YBANEZ Hector"

<HECTOR.YBANEZ@essroc. To Ke¡ttr BarnetURTp/USEpA/US@EpA oi. 

"t 

com> 

cc ' 07t19t2007 04:40 PM

Subject

I agree that a conference call would be good.

Does Friday at I l:00 suit your schedule?

In answer to your first question about "CKD Removed" and "CKD Returned", there are differences at

each plant that need to be explained. When we have the rest of the mercury data Essroc will provide you

with mass balance calculations that will make clear the amounts and concentrations of mercury entering

and leaving the kilns.

I'm sure that you can appreciate that Essroc moved quickly to begin sampling

Names selected are in some cases not as clear as we would like, but sample bottles were sent and chain of

custody worksheets prepared using the names initially selected. We have reached a point where

changing some sample names is appropriate to clarify for the agency what these samples represent,

Thank you for raising these issues now, so that we can make these changes to limit confusion in the

future.

I have provided a brief description for each of the plants that you mentioned.

Bessemer - Both kilns control particulate matter (PM) using electrostatic precipitators (ESPs). Dust

fi'om the first and sometimes the second field is conveyed to a bin for temporary storage This is CKD

Returned. At Bessemer, CKD retumed contains the larger size fraction. At Bessemer CKD returned is

blown directly into the burning zone like coal dust. This is called insufflation and is a requirernent of the

Bessemer air permit to control nitrogen oxide emissions. Kilns that insufflate CKD may be a separate

category for MACT purposes. The CKD removed at Bessemer comes from the last fields of the EPS.

This represents the smallest dust fraction. The CKD returned is not a raw material component. The

amount of dust recirculating from insufflation to recapture in the first fields of the ESP is difficult to

determine.

There is no system to directly measure the insufflated dust so estimates of returned dust must be made

indirectly. The mercury In CKD returned has already been counted in the mass balance as mercury led

into the kiln with slurry. Double counting the mercury In CKD returned would result in a mass balance

erÏor.

Logansport - PM emissions are currently controlled using an ESP at Logansport but a fabric filter is

under construction. CKD removed comes from the last fields of the ESP, as it does at Bessemer.
The CKD retumed from the first fields is fed directly into the kilns using a vortex feeder separate from

the slurry. As at Bessemer, it is difficult to measure the CKD retumed. The mercury has already been

counted through analysis of the slurry feed. Recirculating mercury in CKD returned to the kiln is not a

feed component.

Nazareth - No CKD is removed from the kiln at the Nazareth plant. In fact, it is unclear that there is any

material that can properly be called CKD that is generated at Nazareth. Raw materials ground in the

Loesche (raw) mill are conveyed using hot stack gases to dry the feed. The feed from the raw mill

adsorbs mercury from the stack gases. The raw mill discharge is blown pneumatically into the

homogenizing silo bins where it is mixed with other materials.

The other materials include the dust collected in the baghouse controlling PM emissions from the

Loesche mill. This material is collected in hoppers under the baghouse and conveyed by screw

conveyors and enclosed elevators into the homogenizing silo. A second baghouse controls PM emissions

from a kiln exhaust stream that does not pass through the Loesche mill. Dust collected in this fabric filter

is also conveyed to the homogenizing silo using screw conveyors and elevators The material from the

homogenizing silo, containing all of the materials described above is called kiln feed and entrees the kiln

near the top of The preheater tower. Mercury from stack gases condenses onto the smallest particles in

the kiln feed recirculating and accumulating in the dust from the two baghouses as well as the raw mill

discharge. There is a significant increase in mercury emissions when the Loesche mill is taken out of

service. This typically occurs for about 8 hours every ten days to perform maintenance on the mill.

There is no regular schedule of milloutages. The material collected in the fabric filters goes directly to

the homogenizing silo. There is no way to measure the amount of this materialrecirculating within the

system. As in the case of Bessemer and Logansport, the baghouse dusts are not raw material

components. Counting the mercury recirculating in this fabric filter dusts would be double counting the

lllercury.

Essroc will change the name from CKD returned to Baghouse dust to limit confusion on this point. A

separate tab for baghouse dust returned as feed will be created to clarify that this material should not be

named "CKD retumed".

San Juan - The kiln system at San Juan is similar to Nazareth with no CKD removed from the Kiln and

fabric filter dust returned to the homogenizing silo where it is mixed with the material discharged from

the Loesche (raw) mill. The raw mill adsorbs mercury from stack Gases and includes recirculating

mercury. The baghouse dust also contains adsorbed mercury.

These are not raw material components and including them as raw materials would double count

Mercury entering the kiln. As in the example of Nazareth, "raw mill discharge" is a more Appropriate

term than raw mill feed. The two components entering the raw mill are limestone And mill scale. We

will remove raw mill discharge from the raw material component(RMC) tab.

The data is duplicated in the tab named "In Ln RM Feed" and should better be named "ln Ln RM

Dischg". These changes will be made and an improved worksheet sent on Thursday in Preparation for

the conference call on Friday.

Speed - Speed is similar to Nazareth and San Juan, except that some CKD is removed fi'om kiln I and a

single Loesche mill is used to prepare kiln feed for both kiln I and kiln 2. The dust collected in the kihi I

baghouse is transferred to a temporary storage bin. This dust is used to manufacture masonry cements.

Some of this dust is sold directly to customers. Any kiln I fabric filter dust that is not used to make

masonry cement or sold directly is returned to kiln I in a system separate from the kiln 1 Loesche mill

feed system. The CKD removed (sold directly or as masonry cements) is the same as CKD returned at

Speed. The amount of CKD removed or sold is accurately known because these materials are weighed.

However, the recirculating CKD retumed is not measured and is not a raw material component.

Including the mercury from CKD retumed would result in a mass balance error because the mercury in
this material has already been counted in the feed components. Changes to the Speed raw mill discharge

and RMC information that duplicate these data will be made to clarify the mass balance calculations.

In short, materials collected in the fabric filters and ESPs are returned to the kilns in Different Ways

including insufflation, vortex feeders, mixing in a homogenizing silo and a separate kiln feed stream

When CKD is returned it is not a raw material component and Treating it as a raw material would result

in double counting of mercury in recirculating Materials. It is not part of the slurry at Bessemer or

Logansport and it is not part of the Raw mill discharge at Nazaretb San Juan or Speed. It is returned as

described above.

We agree that raw mill feed should not be equated with raw mill discharge. To clarify this Point, we will

create a tab for raw mill discharge and delete the duplicated data from the Raw material components tab.

At Nazareth what is fed to the kiln is a combination of raw mill discharge that has absorbed mercury

from stack gases plus dust from two fabric filters that have collected dust that has also adsorbed mercury

from stack gases and recirculated this mercury increasing the mercury concentration in the recirculating

materials. The raw material components are analyzed individually including limestong flyash, bottom

ash, alumina, iron, clay, and CKD landfilled and subsequently reclaimed as a ra'w material. For wet kilns

with indirect raw mills it is possible to analyze the sluny in addition to the raw material components to

compare the Mercury in each component with the mercury in the kiln feed. In the case of preheater kilns,

where mercury in stack gases is adsorbed onto feed materials in the Loesche mill and the dust collected

in the ESP or fabric filter, much of the mercury recirculates within the kiln and Must not be double

counted âs mercury entering the kiln with feed.

I hope that this clarifìes the mercury mass balance issues for these preliminary data

As I said, Essroc will provide you with a complete mass balance estimate for mercury for each Of our

kilns when we are prepared to provide the rest of the mercury analyses.

Hector

Essroc Cement Corp.

CONFIDENTIALITY NOTE: This message is intended exclusively for the party or parties to

whom it is addressed. This communication may contain information that is proprietary,

privileged or confidential or otherwise legally exempt from disclosure. If you are not one of the

named addressees, you are not authorizedto read, print, retain, copy or disseminate this message

or any part of it. If you have received this message in error, please notify the sender immediately

by e-mail and delete/destroy all copies of the message. Any views or opinions presented in this

email are solely those of the author and might not represent those of Essroc Cement Corp.

WARNING: Although Essroc Cement Corp. has taken reasonable precautions to ensure no

viruses are present in this e-mail, the company cannot accept responsibility for any loss or

damage arising from the use of this email or attachments.

Essroc Cement Corp.
Fw: Questions on the ESSROC Data submittal

Keith Barnett to: Keith Barnett

--- Fonr¡arded by Keith BarneIURTP/USEPA/US on 08/05/2008 10:34 AM -----

Keith BarnetURTP/USEPA/US

08/05/2008 10:36 AM

0711712007 02:54 PM

To "YBANEZ Hector" <HECTOR.YBANEZ@essroc.com>

cc "Michael Laney" <mnl@rti.org>, green@rti.org

Subject Questions on the ESSROC Data submittal

Dear Hector:

We have some additional question on your data submittal. Once you have had time to look over the

questions, why don't we set up a call, just in case more questions come up from your answers.

-You report Hg content of "CKD removed" and "CKD returned. " I assume

CKD returned is what is put back into kiLn. How is it retuned? ft is not

reported as a "raw material componenttr for any of the kil-ns that return it

( Bessemer,

Logansport, Nazareth, San Juan, Speed). So is it part of the slurry at

Bessemer and Logansport? And for the dry kilns, is the CKD part of the

"raw mill discharge" at Nazareth and Speed? Or is it returned by another

method?

-In the "Inline raw mill feed" tabJ-e, the reported Hg for Nazareth and

Speed is the same as "Raw Mill Discharge" in the 2 tabLes of "Raw MateriaL Components" for Nazareth and Speed. This is a litt.le confusj-ng

to me because I would not have equated raw mill feed with raw miLl

discharge

-In the t'Raw Material Components" tabl-es for Nazareth and Speed, what is

being fed to the kilns: raw mill discharge only, or raw mill discharge, limestone, clay, iron, etc.

- Similar to the previous question, the Hg content of slurry in the "Raw Material Components" tabLes for Bessemer, Logansport, and Martinsburg is the same as that in the "indirect mill feed" table. Ílhat is the total- Hg going into the wet kilns - the Hg in the slurry only or the Hg reported for the slurry, limestone, mill scale, etc.?

Keith W. Barnett

USEPA/OAQPS/SPPD/MMG

MailCode D243-02

Research Triangle Park, NC 27711

91 9-541 -5605

ba rnett. keith@epa. gov
Fw: Essroc Sampling and Analysis - EPA request for mercury and TOC information

Keith Barnett to: barnett.keith 08/05/2008'10:254M

--- Fonvarded by Keith Barnett/RTP/USEPA/US on 08/05/200810:24 AM -----

'CHADBOURNE John"

<John.Chadbourne@essroc.c

Yl. 3r om>

. 05/1812007 06:01 PM

To

cc

Subject

Keith BarnetURTP/USEPA/US@EPA

"Anderson, William" <wcanderson@stl-inc.com>, "YBAN EZ

Hector" <H ECTOR.YBAN EZ@essroc.com>

Essroc Sampling and Analysis - EPA request for mercury

and TOC information

Keith,

Essroc will begin sampling next Monday, May 21,2007 to comply with the May 8 letter from Peter

Tsirigotis.

I have been assigned responsibility for ensuring the success of the Essroc sampling and analysis

program.

Hector Ybanez asked that I prepare this note to you clarifying issues that may have the potential to cause

concerns.

I have attached an email distributed yesterday to plant environmental engineers and quality control

chemists concerning sampling requirements.

Please review that document and let us know if you have a different view on any of the issues raised for

sample collection.

The methods referenced in Mr. Tsirigotis' letter are essentially "SWB46" methods. Essroc has retained

Severen Trent Laboratories (STL) to provide

guidance and analytical capabilities to accomplish the sampling and analysis required. Dr. William

Anderson of STL and I have discussed a number

of issues raised on review of the methods to be applied to determine the mercury and Total Organic

Carbon (TOC) concentration in the thousands of

samples that will be taken. Dr. Anderson has pointed out that SWB46 methods are guidelines to which

professionaljudgment must be applied to

produce practical, accurate results. This is explained in various chapters of SWB46 where it becomes

clear that the quality of the results is the

responsibility of the analytical laboratories, even when difficulties arise in the application of the SW846

methods.

Essroc intends to use a direct mercury analysis method that is in accord with Method 7473 and capable of

detecting concentrations as low as 20

parts per billion (ppb). Depending on results, some samples willalso be analyzed using HF total digestion

procedures to compare results with the

direct mercury analysis. The laboratory Essroc has selected will follow the quality control guidelines for

duplicate, spiked and calibration samples

as specified in the method. Analytical reports will include the time the samples were received and

analyzed in addition to sample identification

parameters. The samples will be retained on site at the analytical laboratory through at least September,

2007 so that confirmatory analyses can

be provided as needed. Since the all of the samples have been exposed to ambient or high temperatures,
there will be no need to refrigerate any

of the samples. ln addition, the usual 28 day holding time for mercury samples will not apply. No change

in the mercury concentrations for these

samples is expected under long{erm (six month or greater) storage. Given the huge number of samples,

the nature of the samples and the ability

to confirm previous results with reanalysis and comparative analytical methods, the guidelines for

refrigeration and holding time shall not apply.

Analysis for TOC will be conducted usíng the Lloyd Kahn modification of Methods 9060 and 9060a. One

of the laboratories selected to do these

analyses employs a Shimadzu SSM-50004 TOC analyzer. We understand that phosphoric acid is

substituted for hydrochloric or sulfuric acids

where samples high in carbonates are to be analyzed. As explained above, no refrigeration or holding

times are required to provide accurate analyses

of these samples. For some materials, TOC results will be lower than the quantification limit of 500 ppm.

It would be unreasonable to run hundreds

of "non-detect" samples, when this information can be obtained by analyzing composite samples plus

randomly selected daily samples. ln order to

determine which daily samples need to be analyzed for TOC, the laboratory will prepare composite

samples representing two week or longer intervals

from the daíly composite samples. lf all of the long-term composite samples and selected daily composite

samples of a particular material (for example, Bessemer Kiln 1 slurry feed) are below 500 ppm, no further

analyses for TOC for that material will be conducted. The TOC concentration will be reported

as less than 500 ppm. For materials which demonstrate the presence of measurable levels of TOC,

multiple analyses of daily composite samples will be

run to determine the average and variability of TOC results. The requirement for quadruplicate analyses

specified in methods 9060 and 9060a will not

apply. Rather, the laboratory analyst will determine the number of additional samples to be analyzed

based on the results for each sample analyzed.

I feel sure you will appreciate the need to focus resources on the most important questions as we

undertake this voluminous sampling and analysis program.

lf you have any questions or comments, please call me at 610 837 3336 or send an email.

Dr. John F Chadbourne

Senior Environmental Engineer

Essroc Cement Corp.

3251 Bath Pike

Nazareth, PA 18064

Essroc Cement Corp.

CONFIDENTIALITY NOTE: This message is intended exclusively for the party or parties to

whom it is addressed. This communication may contain information that is proprietary

privileged or confidential or otherwise legally exempt from disclosure. If you are not one of the

named addressees, you are not authorized to read, print, retain, copy or disseminate this message

or any part of it. If you have received this message in error, please notify the sender immediately

by e-mail and delete/destroy all copies of the message. Any views or opinions presented in this

email are solely those of the author and might not represent those of Essroc Cement Corp.
WARNING: Although Essroc Cement Corp. has taken reasonable precautions to ensure no

viruses are present in this e-mail, the company cannot accept responsibility for any loss or

damage arising from the use of this email or attachments.

Essroc Cement Corp.

--- Message from "CHADBOURNE John" <John.Chadbourne@essroc.com> on Thu, 17 May 2007

18:24:10 -0400 -----

"ANDREWS Mark" <Mark.Andrews@essroc.com>, "AYALA MELENDEZ Nivia"

<Nivia.Ayala@essroc.coln), "CAWTHRAY Mike" <Mike.Cawthray@essroc.com>,

"CONN Corey" <Corey.Conn@essroc.colrt), "CONSTANT David"

-^. <David.Constant@essroc.com>, "DUETTA Dale" <Dale.Duetta@essroc.com), "HARP

^ "' Allen" <Allen.Harp@essroc.com), "HITT David" <David.Hitt@essroc.com>, "LUNGU

Radu" <Radu.Lungu@essroc.corn), "RIVERA Beatriz" <Beatriz.Rivera@essroc.com>,

" S HAV/ Derek" <Derek. Shaw@essroc. cotl't), " YBANEZ Hector"

<HECTOR.YBANEZ@essroc.com>

"AYALA MELENDEZ Nivia" <Nivia.Ayala@essroc.coÍr), "CORDER Rebecca"

<Rebecca.CoRDER@essroc.com>, "COSTELLO James" <James.Costello@essroc.con'ì),

"DUBCHAK Patricia" <Patricia.Dubchak@essroc.com>, "EATON Melissa"

<Melissa.Eaton@essroc.com>, "EMMERT Allen" <Allen.Emmert@essroc.com>,

" FARMER Kelly" <Kel ly. Farmer@essroc.colr), " GROTHEER Kevin"

<Kevin.Grotheer@essroc.coûl), "KLEMICK William" <William.Klemick@essroc.com>,

tt t "LEGATE Haroldl' <harold. legate@essroc.com>, " STOFFICK Thomas"

<Thomas.Stoffick@essroc.com), "WILT Larry''<Larry.Wilt@essroc.com>, "JANY Lou"

<LOU.JANY@essroc.com), "CORDER Rebecca" <Rebecca.CoRDER@essroc.com>,

"RIZZI Fabio" <Fabio.Rizzi@essroc.coÍr), "DIDION Josh" <Josh.Didion@essroc.com),

"Anderson, William" (wcanderson@stl-inc.cotrl], "Carswell, Patti"

<pcarswell@stl-inc.com>, <GCL abZ@comcast.net>

Slj,| Su*nle Preparation for Shipment to Analytical Laboratories

Folks,

As we agreed in the conference call last Friday, the samples to be taken to comply with the EPA Section

114 letter that Essroc received last week need to be collected with rigorous quality assurance protocols.

Representatives of Severen Trent Laboratories (STL) have assisted us by preparing master sample logs,

daily sample collection sheets and request for analysis/chain of custody forms.

All samples sent to the laboratories must be homogeneous dry powder. The laboratories will remove a

sample (<1 gram) from each container. The sample you send must be a sample from which a

representative aliquot can be removed with no further preparation. For samples of fuel taken from the

burner pipe, CKD and ground feed to sent to the kiln, fine dry powders are collected directly at the

sampling locations. For clinker samples, please grind the samples finer than -200 mesh before preparing

split samples. For slurry from wet-process kilns, please dry the samples as you normally do and retain

excess dried feed material to prepare your daily composite samples. For raw material components,

minimal drying is recommended, so long as a homogeneous "dry" powder is produced for sample splitting.

A clay or other material with high water affinity can be dried at 105 C as necessary to produce a dry

powder. Excessive drying must be avoided.

Sample splitting into thirds is accomplished'by thoroughly shaking the container of dry powder to achieve

a homogeneous mixture. Remove approximately 200 grams of material from the thoroughly-shaken

composite sample mixture and place it on a clean sheet of paper. Carefully divide the pile of dry powder
into "sixths" using a clean spatula to divide the pile. Remove two "opposite" sixths into one of the sample

containers to prepare the first split sample. The two remaining "opposite sixths" to prepare the second

split sample. The remaining sample is placed into a third sample container. One of the samples will be

analyzed for mercury, another for TOC and the third will be archived for repeat or subsequent analysis.

The sample containers shipped from STL will be packaged with five cases (24 count) per shipping box.

The packaging materials must be saved so that the samples can be shipped to the laboratories in the

same shipping materials. This procedure will minimize breakage. Collect mercury samples in one set of

sample cases until 5 cases have been accumulated. A plant collecting 10 mercury samples per day will fill

the sample shippíng box in 12 days of sampling.

(10 samples per day X 12 days of sampling = 120 samples = 5 cases X 24 samples per case). There is

no need to refrigerate samples. The materials used to manufacture cement are stored at ambient

temperatures and exposed to high temperatures in the pyroprocess. Mercury present in feed to the raw

mills will be stable as complex mercury minerals.

Since the only constituents to be measured are mercury and TOC, you may use grinding equipment which

contains chromium metal to prepare these samples. The amount of chromium contamination possible

from chromium grinding equipment in this instance is acceptably low.

Please complete the daily sample collection log that describes the time when each component of the

composite sample was collected. The initials of the individual should be entered in addition to the time

when the sample was collected. At least three samples are needed for each daily composite sample,

unless an equipment failure prevents collection of a "shift" sample. ln the case where equipment outages

result in a "short sample" it is best to start preparation of another complete composite sample. lf a "short"

composite sample is submitted for analysis, it is essentialthat notes on the sample collection sheet

describe the reason for collecting that sample.

When a shipment of samples has been collected, split and packaged for delivery to the laboratories, a

request for Analysis/Chain of Custody sheet will need to be prepared and sent with the samples.

All mercury analyses for the first round of samples will be completed by:

G & C CoalAnalysis Lab., lnc.

Attn: Michael J. Chestnut

1341 Hoffman Hollow Rd

Summerville, PA 15864

(814) 849-7301 .

lnformation on TOC analysis will be distributed soon.

Please call me or send email if there are any questions or concerns.

John

Essroc Cement Corp.

CONFIDENTIALITY NOTE: This message is intended exclusively for the party or parlies to

whom it is addressed. This communication may contain information that is proprietary

privileged or confidential or otherwise legally exempt from disclosure. If you are not one of the

named addressees, you are not authorizedto read, print, retain, copy or disseminate this message

or any part of it. If you have received this message in error, please notify the sender immediately

by e-mail and delete/destroy all copies of the message. Any views or opinions presented in this

email are solely those of the author and might not represent those of Essroc Cement Corp.
WARNING: Although Essroc Cement Corp. has taken reasonable precautions to ensure no

viruses are present in this e-mail, the company cannot accept responsibility for any loss or

damage arising from the use of this email or attachments.

Essroc Cement Corp.