Keith Barnett/RTP/USEPA/US 

06/03/2008 12:20 PM To 

 curtis.lesslie@ashgrove.com, leslie.white@cemex.com, 

lillianf.deprimo@cemex.com, gina.henry@cemex.com, 

ruksana.mirza@holcim.com, meg.garakani@holcim.com, 

hector.ybanez@holcim.com, Michelle.Ferguson@holcim.com, 

craig.campbell@lafarge-na.com, michael.pelan@lafarge-na.com, 

tmatz@htcnam.com, daniel.nugent@buzziunicemusa.com, gknapp@txi.com, 

ngarnett@txi.com, lfaciane@txi.com, sisaacson@calportland.com, "Farr, 

Jerry" <jfarr@calportland.com>, "CHADBOURNE John" 

<John.Chadbourne@essroc.com>, gary.molchan@essroc.com 

 cc 

 "Andrew O'Hare" <aohare@cement.org>, Steven 

Silverman/DC/USEPA/US@EPA, 

"Michael Laney" <mnl@rti.org> 

 bcc 

 

 Subject 

 Long versus short term variability of mercury in cement kiln inputs 

(resent with clarification) 

 

 

This email is a follow up information request to the letter mailed May 7, 

2007 under section 114 of the Clean Air Act (CAA) where we requested 

information on mercury and total organic carbon (TOC) content of portland 

cement kiln feed materials (including fly ash), fuels, cement kiln dust 

and (for facilities with continuous monitors) total hydrocarbon 

emissions. 

Background 

As you are aware, EPA is currently in the process of reconsidering 

mercury 

and total hydrocarbon standards for Portland Cement kilns regulated under 

the Portland Cement NESHAP. As part as part of a recent information 

collection, we received information on daily mercury inputs for about 91 

kilns in the industry. We plan to use that information to develop 

mercury 

emission estimates for those kilns. These estimates will then be used to 

determine maximum achievable technology (MACT) floors for mercury 

emissions, and to evaluate any beyond-the-floor control options. 

One issue that has been raised by the cement industry is how well does 30 

days of data represent long term variability (such as over the course of 

a 

year). One suggestion made to us was to poll the cement industry to 

determine if any companies had long term data on mercury kiln inputs. 

Kilns that burn hazardous waste collect information (I think daily) on 

the 

mercury in their hazardous waste. My understanding is that at least some 

facilities may have collected data on all the mercury inputs to the kiln 

What data are we asking for? 
If you have long term data on mercury inputs for any type of kiln we 

would 

ask you to submit this information to us. We do not want any data on 

hazardous waste fuels - but if you have data on the other fuels and raw 

materials inputs for a hazardous waste kiln we would be interested in 

that 

data. We would use this information to assist in the effort of 

evaluating 

long term variability of mercury inputs. Attached below is an example of 

the type of data we are looking for. (Note it is not necessary that you 

have at least a year of data). The attached example came from a cement 

kiln in Florida that has a permit requirement to submit information on 

mercury inputs to demonstrate compliance with a mercury limit in their 

title V permit. In this case the facility takes daily samples and 

composites and analyzes the samples monthly. (We have received some 

additional data from the State of Florida. However, we are not certain 

that the variability of the raw materials and fuels in Florida are 

necessarily representative of other areas). 

If you have any data of the type we are looking for , please contact me 

(my phone number and email are below) so we can discuss what data you 

have. 

Keith W. Barnett 

USEPA/OAQPS/SPPD/MMG 

Mail Code D243-02 

Research Triangle Park, NC 27711 

919-541-5605 

barnett.keith@epa.gov