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>
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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