From:   "Nugent, Daniel" <Daniel.Nugent@Buzziunicemusa.com>      

To:  Keith Barnett/RTP/USEPA/US@EPA    

Date:   03/23/2010 06:13 PM   

Subject:   Lone Star Industries ‐ Test Results for EPA Sec 114 ICR for HCl Emission  

Testing     

Keith,

Attached is the M321 XL file completed for the HCl Method 321 emission testing  

we completed on Kiln Number 3 at the Lone Star Industries Inc.

facility in Pryor Oklahoma.  We are finalizing the full test report to support  

the attached results and should have that submitted to you within the next two  

weeks.

As we discussed several weeks ago, Lone Star Industries Inc. has not had  

another qualifying kiln available to conduct testing that would produce  

results by the March 31, 2010 deadline of the ICR.  Further, we do not expect  

that status to change.  We do expect our Kiln Number 1 at the Pryor facility  

to be restarted within the next week and reach normal production within two  

weeks.  However, this would not present an opportunity for testing until at  

least April 5 (assuming testing services are available, which they were not  

last we checked).  In addition, as we discussed, since Kiln Number 1 is also a  

long‐dry kiln and would be processing the same fuels and raw materials as  

those used during the Kiln Number 3 testing, testing an additional kiln at the  

Pryor facility is not expected to produce HCl results significantly different  

than those reflected in the attached.

As a result, it is our understanding that the Kiln Number 3 testing at the  

Pryor facility will satisfy our obligation to provide the information required  

by Sec 114 ICR.  If this is incorrect, please let me know.

Regards,

Dan Nugent

Vice President, Environmental Affairs

Lone Star Industries Inc.

(See attached file: M321 Spreadsheet ‐ Lone Star Industries Inc ‐ Pryor

OK.xlsx)
TABLE 1.2 EPA REPORTING SPREADSHEET

Company Name:

Facility Name: PRYOR CEMENT PLANT

Address: 5 Mi E on 20 2 Mi S Co Rd 

City: PRYOR 

State: Oklahoma

Kiln ID:

Kiln Type: Long Dry

In-line Raw Mill: No

Control Device Configuration: 

Parameter

Sample #1Sample #2Sample #3

Avg.

Units Test Method Used Test Location Note

Select appropriate unit 

from list. If other is 

selected please describe 

units in column H at right. Enter the name of the Test Method used.

Indicate whether the test 

occurred upstream or 

downstream of a control 

device(s); list the control 

device(s)

If kiln has an in-line raw mill, 

indicate raw mill status during tests 

(i.e., raw mill on or raw mill off). 

Provide any other information 

supporting information you think is 

necessary about this test report. 

Sample Date (mm/dd/yyyy) 2/24/2010 2/24/2010 2/24/2010

HCl Concentration - as measured - Wet Basis 7.8 6.5 5.9 6.7 ppmv Wet M321 Downstream of Baghouse Off Line Raw Mill 

HCl Concentration Dry Basis 8.2 6.8 6.2 7.1 ppm v Dry M321 Downstream of Baghouse Off Line Raw Mill 

Oxygen Concentration - dry basis 12.1 12.7 12.4 12.4 % M3A Downstream of Baghouse Off Line Raw Mill 

CO2 Concentration - dry basis 13.7 12.6 13.2 13.2 % M3A Downstream of Baghouse Off Line Raw Mill 

HCl Concentration - dry corrected to 7% oxygen 13.0 11.5 10.1 11.5 ppm v dry at 7% O2 M321 Downstream of Baghouse Off Line Raw Mill 

Exhaust Stream %Moisture 4.9 4.6 4.6 4.7 % M320 and M4 Downstream of Baghouse Off Line Raw Mill 

Exhaust Flowrate 77,800 82,400 77,200 79133 dscfm M1, 2, 3A and 4 Downstream of Baghouse Off Line Raw Mill 

Exhaust Temperature 372 370 389 377 F T/C Downstream of Baghouse Off Line Raw Mill 

Notes:

Lone Star Industries Inc.

Kiln Number 3

Baghouse

Enter HCl concentration value in dry 

parts per million volume (ppmvd) 

corrected to 7% oxygen. If the test 

results are below detection limit, please 

note the detection limit in brackets 

(e.g., [< 0.010]). 

Method 320 data used for moisture results reporting.