From: HolmesAems@aol.com

To: HolmesAems@aol.com, Keith Barnett/RTP/USEPA/US@EPA

Cc: AOhare@cement.org

Date: 04/08/2010 07:58 AM Subject: Re: Analysis of Kiln 1594

I now see that I left off the mass balance summaries. Here they are as well.

John Holmes

In a message dated 4/6/2010 9:09:57 A.M. Eastern Daylight Time, HolmesAems@aol.com writes: Keith,

I know there was a deadline of yesterday for receiving this work. We have

still not resolved the difference in the EPA base case interpretation of the

30 days of data and what I rec'd from PCA.
However, in the interest of moving forward, I have attached our current analysis and back up. If we are able to resolve the differences in the base

case 30 days, I will revise this accordingly. However you will see that we

use other information for feed mercury and coal mercury and those aspects
will not change. Please let me know if you have any additional questions
about this analysis or the rest of the mercury variability work.

John Holmes AEMS, LLC(See attached file: EssrocMartinsburgAnalysis_040510.xlsx)Raw Material and Fuel Annual Consumption (short tons) High

Hg Conc. (ppm) Low

Hg Conc. (ppm) Average

Hg Conc. (ppm) Standard

Deviation of Hg Conc. (ppm) Avg. Hg

Loading to

Kiln (lbs/yr) Hg

Loading to

Kiln** (lbs/yr)

Limestone* 420,271 0.0229 0.0133 0.0169 0.0027 14.23 18.80
Shale 22,936 0.1900 0.0348 0.0968 0.0398 4.44 8.10
Fuel 58,259 0.2639 0.1039 0.1468 0.0275 17.11 23.52

Total Feed*** 443,207 35.78 50.42

Annual

Removed (short tons) High

Hg Conc. (ppm) Low

Hg Conc. (ppm) Average

Hg Conc. (ppm) Standard

Deviation of Hg Conc. (ppm) Avg. Hg

in Wasted
CKD (lbs/yr) Hg

Loading to

Kiln** (lbs/yr)

CKD Removed 46,893 0.3854 0.0050 0.1976 0.0000 18.53 18.53

Estimated Emissions

17.25

31.88

38.91

71.93

* No analytical data for limestone - data for slurry used instead

*** "Total Feed" includes raw material used High Hg Emissions (lbs/year) Avg. Lbs Hg/Million Tons Total Feed
High Lbs Hg/Million Tons Total Feed

** High-End Hg loading assumes normality & 95th percentile. Formula used: "Loading = Annual Consumption x (mean Hg Conc. + (2 x std))" ESSROC CEMENT CORPORATION Martinsburg Plant

Base Case Plant Code GB

Avg. Hg Emissions (lbs/year)Raw Material and Fuel Est. Annual Consumption (short tons) Mean Hg

Concentration (ppm) Standard

Deviation of Hg Conc. (ppm) Avg. Hg Mass

Loading to Atmosphere (lbs/yr) High Hg

Loading to

Kiln* (lbs/yr)

Limestone 420,271
Shale 22,936
Total Kiln Feed 443,207 0.0231 0.0167 20.48 50.08

Fuel 58,259 0.1468 0.0023 17.11 17.65

Total Feed** 443,207 37.58 67.73

CKD Removed Est. Annual Consumption (short tons) Mean Hg

Concentration (ppm) Standard

Deviation of Hg Conc. (ppm) Avg. Hg Mass

Loading to Atmosphere (lbs/yr) High Hg

Loading to

Kiln* (lbs/yr)

CKD Removed 46,893 0.1976 0.0000 18.53 18.53

Estimated Emissions

19.05

49.20

42.98

111.01

** "Total Feed" includes raw material used High Lbs Hg/Million Tons Total Feed

1 Case A: Uses supplemental data on usage and Hg content of kiln feed for 20 month period (Nov. 2004 to Jan. 2007). Plant Code GB

* High-End Hg loading assumes normality & 95th percentile. Formula used: "Loading = Annual Consumption x (mean Hg Conc. + (2 x std))" ESSROC CEMENT CORPORATION Martinsburg Plant

Case A 1

Avg. Hg Emissions (lbs/year) High Hg Emissions (lbs/year) Avg. Lbs Hg/Million Tons Total FeedRaw Material Est. Annual Consumption (short tons) Mean Hg

Concentration (ppm) Standard

Deviation of Hg Conc. (ppm) Avg. Hg Mass

Loading to Atmosphere (lbs/yr) High Hg

Loading to

Kiln* (lbs/yr)

Limestone 420,271
Shale 22,936
Total Kiln Feed 443,207 0.0231 0.0167 20.48 50.08

Fuel 58,259 0.2700 0.0000 31.46 31.46
Total Feed** 443,207 51.94 81.54

CKD Removed Est. Annual Consumption (short tons) Mean Hg

Concentration (ppm) Standard

Deviation of Hg Conc. (ppm) Avg. Hg Mass

Loading to Atmosphere (lbs/yr) High Hg

Loading to

Kiln* (lbs/yr)

CKD Removed 46,893 0.1976 0.0000 18.53 18.53

Estimated Emissions

33.40

63.01
75.36

142.16

** "Total Feed" includes raw material used plus fuel * High-End Hg loading assumes normality & 95th percentile. Formula used: "Loading = Annual Consumption x (mean Hg Conc. + (2 x std))" ESSROC CEMENT CORPORATION Martinsburg Plant

Case B 1

Avg. Hg Emissions (lbs/year)

1 Case B: Uses supplemental data on usage and Hg content of kiln feed for 20 month period (Nov. 2004 to Jan. 2007). Also, no change in raw materials used; uses higher mercury content for coal (95th percentile; WV coal) and no standard
deviation Plant Code GB

High Hg Emissions (lbs/year) Avg. Lbs Hg/Million Tons Total Feed
High Lbs Hg/Million Tons Total Feed