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 A1

Avg. Hg Emissions (lbs/year)

High Hg Emissions (lbs/year)

Avg. Lbs Hg/Million Tons Total Feed
Raw 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 B1

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