'YBANEZ Hector"

<HECTOR.YBAN EZ@essroc .com> 0711912007 04:40 PM 

## To .Keith BarnetURTP/USEPA/US@EPA

cc bcc Subject



### I agree

### that a conference 

### call would be good. Does 

### Friday 

### at l1:00 suit 

### your schedule?


### In answer 

### toyour

### first question 

### about 

### "CKD Removed" and 

### "CKD Returned", there are differences at each plant that need 

### to be 

### explained. When we have the restof the 

### mercury data Essroc 

### will provide you

### with
mass balance calculations that

### will makeclearthe amounts and concentrations 

### of mercury entering and leaving the kilns.


### I'm surethat 

### you can appreciate

### that Essroc moved 

### quicklyto begin sampling. Names selected are 

### in some cases not as clear aswe

### would like, but sample bottles were sent and chain

## of custody worksheets prepared using the names 

### initially selected. We have reached a 

### point where changing some sample names is appropriate 

### to 

### clarify for the ùgency what these samples represent. Thank 

### you

### for raising these issues 

### now, sothat we can make these changes

### to 

### limit confusion inthe future.


### I have provided a

### brief description 

### for each of the plants that you mentioned.

Bessemer

# - Both kilns control particulate matter 

### (PM) using electrostatic 

### precipitators (ESPs). Dust 

### from the 

### first and sometimes the second 

### field is conveyed 

### to a bin 

### for temporary 

### storage. This is 

### CKD Returned. 

### At Bessemer, 

### CKI) returned contains the larger size

### fraction. 

### At Bessemer 

### CKD retumed is 

### blown directly into the 

### burning zone 

### like coal 

### dust. This is called 

### insufflation and 

### is a requirement of the Bessemer 

### air permit 

### to control nitrogen oxide 

### emissions. 

### Kilnsthat insufflate 

### CKD may be a separate category

### for 

### MACT purposes. The 

### CKD removed at Bessemer comes

### from the last

### fields of the 

### EPS. This represents the smallest dust

### fraction. The 

### CKD retumed is not a raw material 

### component. The amount 

### of dust 

### recirculating from insufflation to recapture in the

### first fields of the ESP 

### is

### difñcult to determine. There is no system 

### to directly measure the 

### insufflated dust so estimates 

### of returned dust must be made 

### indirectly. The mercury 

### In CKD returned has already beencounted in the mass balance as mercury fed into the 

### kiln with

### slurry. Double counting the mercury 

### In CKD returned

### would result 

### in a mass balance error. Logansport - 

### PM emissions are 

### currently controlled using an ESP at Logansport 

### but a

### fabric 

### filter is under 

### construction. 

### CKD removed comes 

### from the last 

### fields of the ESP, as 

### it does at Bessemer. The 

### CKD returned

### from the 

### first fields is fed

### directly into the 

### kilns using a

### vortex feeder separate 

### from the 

### slurry. As at Bessemer, 

### it is

### difñcult to measure the

### CKD returned. The mercury has already been counted 

### through analysis of the 

### slurry 

### feed. Recirculating mercury 

### in 

### CKD returnedto the 

### kiln is not afeed component.

Nazareth -

### No CKD is removed

### from the 

### kiln at the Nazareth 

### plant. In fact, 

### it is unclear that there isany material 

### that can 

### properly be called 

### CKDthat is generated at

### Nazareth. Raw materials ground in the Loesche 

### (raw) 

### mill are conveyed using hot stack gases 

### to dry the 

### feed. The feed 

### from the 

### raw 

### mill adsorbs mercury 

### from the stack gases. The 

### raw 

### mill discharge is blown 

### pneumatically into the homogenizing silo bins where 

### it is mixed 

### with other materials. The other materials include the dust collected 

### inthe baghouse 

### controlling 

### PM emissions 

### from the Loesche

## mill. This material is collected 

### in hoppers under the baghouse and conveyed 

### by screw conveyors and

enclosed elevators 

### into the homogenizing 

### silo. A second baghouse controls 

### PM emissions 

### from a

### kiln exhaust stream 

### that does not passthrough the Loesche 

## mill. Dust collected in

### this fabric 

### filter is also conveyed to the homogenizing silo using screw conveyors and 

### elevators. The material 

### from the homogenizing 

### silo, containirg 

### all of the materials described above is called 

### kiln feed and entrees the 

### kiln
near the

### top of The preheater 

### tower. Mercury from stack gases condenses onto the smallest particles in the 

### kiln feed 

### recirculating and 

### accumulatngnthe dust

### from the

### two baghouses as

### well asthe raw 

### mill discharge. There 

### is a

### significant increase 

### in mercury emissions when the Loesche 

### mill istaken 

### out

### of service. This

### typically occurs

### for about 8 hours every ten days

### to perfbrm maintenance on the 

## mill. There is no regular schedule 

### of 

### mill outages. The material collected in the 

### fabric filters goes

### directlyto the homogenizing 

### silo. There is no 

### way to measurethe amount of

### this material 

### recirculating within the system. 

### As inthe case 

### of Bessemer and Logansport, the baghouse dusts are not 

### raw material components. Counting the 

### mercury recirculating inthis fabric 

### filter dusts 

### would be double counting the mercury. Essroc

### will change the name 

### from 

### CKD returned 

### to Baghouse dust 

### to 

### limit conftsion onthis 

### point.

### A separate

### tab for baghouse dust returned as feed

### will be created 

### to clarify that 

### this material should not be named 

### "CKD returned".

San Juan -The

### kiln system 

### at SanJuan 

### issimilarto Nazareth 

### with no 

### CKD removed 

### from the 

### Kiln and 

### fabric 

### filter dust returned

### to the 

### homogenizng silo where 

### it is mixed 

### with the material discharged 

### from the Loesche 

### (raw)

## mill The 

### raw

## mill adsorbs mercury 

### from stack Gases and includes recirculating mercury. The baghouse dust also contains adsorbed mercury. These are not 

### raw material components and including them as raw materials 

### would double count 

### Mercury entering the 

## kiln. As inthe example of Nazareth, 

### "raw 

### mill discharge" is a more

### Appropriate term than raw 

### mill feed. The

### two components entering the raw 

### mill are limestone

### And

### mill scale. We

### will remove 

### raw 

### mill discharge

### from the 

### raw material component 

### (RMC)tab. The data is duplicated 

### inthe tab named 

### "In Ln 

### RM Feed" and should better be named 

### "In 

### Ln RM Dischg". These changes

### will be made and an improved worksheet sent on Thursday 

### in Preparation 

### for the conference 

### call on 

### Friday.
Speed

### - Speed 

### issimilar to Nazareth and San Juan, except 

### that some

### CKD is removed 

### from 

### kiln 

## I and a single Loesche 

### mill is used

### to prepare 

### kiln feed 

### for both 

### kiln 

## I and 

### kiln

## 2. The dust collected in the 

### kiln 

## I baghouse istransferred 

### to a

### temporary storage 

### bin. This dust is used 

### to manufacture 

### masoffy cements. Some of

### this dust 

### is sold

### directly to customers. Any 

### kiln 

## I fabric 

### filter dust 

### that is not used 

### to make masonry cement 

### or sold 

### directly is returnedto 

### kiln 

## I in a system separate

### from the 

### kiln 

## I Loesche 

### mill feed 

### system. The 

### CKD removed (sold 

### directly or as masonry cements) isthe same as

### CKD returned at Speed. The amount 

### of CKD removed

### or sold isaccurately known because these materials are

### weighed. However, the 

### recirculating 

### CKD returned is not measured and is not a 

### raw material 

### component. Including the mercury 

### from CKD returned 

### would result 

### in a mass balance error because the mercury in

### this material has already been counted 

### inthe feed 

### components. Changes to the Speed 

### raw

### mill discharge and 

### RMC information that duplicate these data

### will be made

### to 

### clarifi' the mass balance calculations.



### In short, materials collected inthe

### fabric filters and ESPs are returned to the 

### kilns in Different Ways 

### including insufflation, vortex feeders, 

### mixing in a homogenizing silo and a separate 

### kiln feed 

### stream. When 

### CKD is retumed 

### it is not a 

### raw material component and

### Treating 

### it as a 

### raw material 

### would result 

### in double counting 

### of mercury in recirculating 

### Materials. 

### It is not 

### part of the

### slurry at Bessemer 

### or Logansport and 

### it is not 

### parl of the 

### Raw 

### mill discharge at Nazareth, San Juan 

### or Speed. 

### It is returned as described above.We agree 

### that raw 

### mill feed should not be equated

### with raw 

### mill discharge. To 

### clarify this Poing we

### will

create atab 

### for raw 

### mill discharge and delete the

### duplicated data 

### from the 

### Raw material components tab.


### At Nazareth 

### what is fed to the 

### kiln is acombination 

### of raw

### mill discharge that has absorbed mercury 

### from stack gases 

### plus dust

### from two fabric filters that have collected dust that has also adsorbed mercury 

### from stack gases and recirculated 

### this mercury increasing the mercury concentration inthe 

### recirculating materials. The 

### raw material components are 

### analyzedindividually including limestone,

### flyash, bottom ash, alumina, 

### iron, clay, and

### CKD landfilled and subsequently reclaimed as a 

### raw 

### material. For wet 

### kilns

### with indirect raw 

### mills 

### it is possible Toanalyze the

### slurry in addition to the raw 

### material components 

### to compare the 

### Mercury in each component

### with the mercury inthe 

### kiln feed. In the caseof preheater 

### kilns, where mercury 

### in stack gases is adsorbed onto feed materials inthe Loesche 

### mill andthe dustcollected in the ESP
or

### fabric 

### filter, much 

### ofthe mercury recirculates 

### within the 

### kiln and 

### Must not bedouble counted as mercury entering the 

### kilnwith feed.


### I hope that 

### this clarifies the mercury mass balance issues

### for these 

### preliminary data. 

### As 

### I said, Essroc

### will provide 

### you

### with a complete mass balance estimate 

### for mercury 

### for each

### Of our 

### kilns when we are prepared

### to provide the restof the mercury analyses.


### Hector



### Essroc Cement 

### Corp.


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### Corp.


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### Corp. has

### taken reasonable 

### precautions

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### EssrocCement Corp.-Keith BarnettlRTP/USEPAlUS 07/17/200702:54 PM



### DearHector: To "YBANEZ Hector" <HECTOR.YBANEZ@essroc.com>

cc "Michael Laney" <mnl@rtLorg>, green@rtLorg bcc Subject Questions on the ESSROC Data submittal



### We have some additional question on yourdata submittal. Onceyou have had timeto lookoverthe questions, why don'twe set up acall, just in case more questions come upfrom youranswers.
-You report Hg content of "CKD removed" and "CKD returned." I assume CKD returned is what is put back into kiln. How is it retuned? It is not reported as a "raw material component" for any of the kilns that return it (Bessemer, Logansport, Nazareth, San Juan, Speed). So is it part of the slurry at Bessemer and Logansport? And for the dry kilns, is the CKD part of the "raw mill discharge" at Nazareth and Speed? Or is it returned by another method?
-In the "Inline raw mill feed" table, the reported Hg.for Nazareth and Speed is the same as "Raw Mill Discharge" in the 2 tables of "Raw Material Components" for Nazareth and Speed. This is a little confusing to me because I would not have equated raw mill feed with raw mill discharge.
-In the "Raw Material Components" tables for Nazareth and Speed, what is being fed to the kilns: raw mill discharge only, or raw mill discharge, limestone, clay, iron, etc.

- Similar to the previous question, the Hg content of slurry in the "Raw Material Components" tables for Bessemer, Logansport, and Martinsburg is the same as that in the "indirect mill feed" table. What is the total Hg going into the wet kilns

- the Hg in the slurry only or the Hg reported for the slurry, limestone, mill scale, etc.?



### Keith W. Barnett USEPAlOAQPS/SPPD/MMG Mail Code 0243-02 Research Triangle Park, NC 27711 919-541-5605 barnett.keith@epa.gov