From:  Hector.Ybanez@holcim.com  

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

Date:  06/29/2009 01:05 PM  

Subject:  DRAFT SCRUBBER SUMMARY REPORT.pdf

it is my understanding that you all did not have the Hg scrubber summary  

report ‐ PCA report.  Here is a copy for your review.  

  

_____________________  

  

Hector Ybanez  

Corporate Manager, Environmental  

122 West Carpenter Freeway  

Suite 485  

Irving, Texas 75039  

Phone (214) 524 ‐ 2814  

Cell (972) 268‐1139  

Hector.Ybanez@holcim.com  

hybanez@gmail.com  

www.holcim.com/us  

This e‐mail is confidential and intended only for the use of the above  

named addressee. If you have received this e‐mail in error, please delete  

it immediately and notify us by e‐mail or telephone.  

(See attached file: DRAFT SCRUBBER SUMMARY REPORT.pdf)
PORTLAND CEMENT ASSOCIATION

SCRUBBER TESTING PROGRAM

TO DETERMINE

MERCURY CONCENTRATION

AND REMOVAL

SUMMARY REPORT

October 2008

Emission Monitoring Inc.

8901 Glenwood Ave.

Raleigh NC

27617

919.781.3824
ii

Key Words

Elemental Mercury, Flue Gas Adsorbent Mercury (FAMS) Sampling, Limestone Scrubber, 

Method 30B, National Emission Standards for Hazardous Air Pollutants (NESHAP), Oxidized 

Mercury, Percent Removal, Sulfur Dioxide, Total Mercury

Abstract

The Portland Cement Association (PCA) sponsored a test program of five scrubber controlled 

kilns located at four Portland cement plants. The scrubbers were installed downstream of

particulate matter removal device (i.e., fabric filter baghouses and/or ESPs) to control sulfur 

dioxide and other acid gases. These five scrubber controlled kilns were identified by EPA as 

potential maximum controlled sources for mercury in their review 2006 of the Portland cement 

NESHAP.

Testing for mercury compounds in the flue gas was conducted simultaneously upstream and 

downstream of the limestone scrubbers to determine the effects on the mercury compounds.

Concentration testing using EPA Method 30B and the “FAMS” method were performed

concurrently along with diluent oxygen measurements. Mercury results are reported as μg/m3

normalized to 7% oxygen. A percent removal for the individual mercury compounds (as well as 

total mercury) was calculated using the average inlet and outlet normalized concentrations.

The results were analyzed using a bias correction combined with the standard deviation of the 

paired results to determine the significance of the percent removal calculation.
iii

TABLE OF CONTENTS

1.0 INTRODUCTION 1

2.0 EXECUTIVE SUMMARY 3

3.0 DISCUSSION OF FINDINGS 4

3.1 Method Comparisons 4

3.2 Effect of Raw Mill Operation 4

3.3 Effect of Limestone Scrubber 5

4.0 METHOD 30B RESULTS AND RANGE OF Hg REMOVAL 5

Table 4-1 Method 30B Tabulated Results 6

5.0 FAMS RESULTS 7

Table 5-1 FAMS Speciated Results 7

6.0 PROJECT CONCLUSIONS 8

APPENDIX A Analyses of Mill On Results – Bias Correction and 

Statistics

APPENDIX B EXAMPLE CHARTS 
1

1.0 INTRODUCTION

The U.S. EPA (EPA) published a Federal Register Notice on December 20, 2006 (Vol. 71, No. 

244, Pg.76553) that directly affected the Portland cement industry. In this Federal Register 

Notice, the EPA requested speciated mercury (Hg) testing on scrubber equipped cement kilns to 

understand more fully Hg speciation and emissions at Portland cement plants. Data from this 

testing program were expected to be used by EPA, in part, to determine what (if any) mercury 

standard would apply to the Industry during a subsequent rulemaking.

In response to EPA’s Notice of Reconsideration identified in the December 20, 2006 Federal 

Register Notice, the Portland Cement Association (PCA) and its member companies sponsored a 

test program to quantify mercury concentrations upstream and downstream of limestone 

scrubbers.

Many rounds of discussions were held between PCA, Emission Monitoring Inc. (EMI) and EPA 

regarding which test method would be employed. Final negotiations resulted in the selection of 

two methods to be used simultaneously to provide the requisite information; Method 30B, and a 

method referred to as “FAMS”. Both methods employ adsorbent media to collect mercury. 

Method 30B produces a total mercury result and the FAMS method produces results for 

particulate, oxidized and elemental mercury species. (PM bound Hg was quantified by FAMS, 

but not really of concern to the overall project.) 

Four individual plants having a total of five scrubber controlled kilns were tested from July 

through December 2007. Air Sampling Associated Inc. (ASA - Lewisville, TX) performed the 

testing under the direction of Dr. Laura Kinner of EMI. 

The facilities, and geographic locations presented in the order of testing are as follows: 

• Lehigh North (1-kiln, SNCR, ESP, Scrubber) Mason City, Iowa, July 2007

• Holcim US (1-kiln, FF, Scrubber), Florence, Colorado, July 2007

• Holcim Texas LP (2-kilns, SNCR, FF, Scrubber) Midlothian, Texas, October 2007

• Texas Industries (1-kiln, FF, Scrubber, RTO*) Midlothian, Texas, December 2007

o Testing did not involve RTO

All of the plants were contemporary pre-heater/precalciner pyroprocessing systems having inline raw mills. All facilities used a fabric filter system for PM removal upstream of the scrubber 

with the exception of Lehigh North which uses an ESP. The scrubbers were installed by the 

facilities to control sulfur dioxide and other acid gases. The Lehigh and the Holcim Midlothian 

facilities also employed SNCR for NOx abatement during these tests. 

Testing was conducted during two distinct process operating conditions; with the in-line raw mill 

operating and while not operating. Testing using EPA Method 30B and the FAMS method for 
2

speciated mercury compounds was conducted simultaneously upstream and downstream of the

scrubbers. 

Complete reports including descriptions of the sampling locations, results of all quality assurance 

activities and supporting data for each plant were prepared by ASA and reviewed by EMI. 

These reports were submitted to the PCA as they became finalized, and entire report package 

was submitted in February 2008 to Keith Barnett of the US EPA. 

This document presents an overall summary of the results and provides conclusions from the 

testing program that are not provided in the ASA reports.
3

2.0 EXECUTIVE SUMMARY

Testing was performed to determine the total mercury and speciated mercury concentrations 

upstream and downstream of the limestone scrubbers, and to determine the scrubber’s affect on 

the mercury speciation and removal. Two distinct modes of process operation were tested; inline raw mill on and off. 

During raw mill on operation, four of the five kilns tested had total Hg concentration levels of 

less than 10ug/m3 at the stack or scrubber outlet. Raw mill off operation always produced higher 

stack concentration levels which ranged from 15 ug/m3 to 50 ug/m3 for the facilities tested.

The following presents the pertinent results and observations from this testing program.

1. During raw mill on operation, 

a. the Lehigh North facility and the Holcim Portland facility exhibited negative HgT

removal across the scrubber indicating oxidized mercury conversion to elemental 

mercury with subsequent re-emission of elemental mercury,

b. the Holcim Midlothian Kiln #2 exhibited minimal HgT removal in the range of 4-

11%,

c. the Holcim Midlothian Kiln #1 and the TXI kiln had HgT removal efficiencies of 

from 22-38%,

d. The cement plants operate with raw mill on approximately 80-90% of the time, 

and the scrubbers were observed to have minimal effect on mercury control 

during this process condition.

2. During raw mill off operation,

a. All kilns exhibit some amount of Hg removal which is directly proportional to the 

inlet Hg+2 concentration levels.

b. The amount of removal ranged from 58% (TXI) to 93% (Holcim Portland) 

reflective of corresponding inlet Hg+2 concentration levels.

c. The cement plants operate with raw mill off approximately 10-20% of the time, 

and oxidized mercury captured during this process condition is gradually 

reconverted back to elemental mercury and released back to the atmosphere 

during raw mill on operation.
4

3.0 Discussion of Findings

3.1 Method Comparison

Comparisons between EPA Method 30B and the FAMS method based on total mercury catch 

were comparable for inlet locations. 

Because of the design of the FAMS probes, the method was found to be better suited for dry 

stack sampling. 

Inlet sample results for the FAMS are not in question except for TXI (which was a “wet” sample 

location due to its proximity to the scrubber itself), but some of the outlet FAMS results for the 

kilns tested are in question either because of water droplets entering the probe, or because the 

probes had to be operated at elevated temperature to prevent water droplet entrainment which 

caused problems with mercury capture on the appropriate section of the trap. 

3.2 Effect of Raw Mill Operation

Overall, oxidized mercury was observed to be captured by the scrubbers during raw mill off 

operation (positive removal), and elemental mercury was observed to be released during raw mill 

on operation (in some cases negative removal for total Hg was observed across the scrubber). In 

most cases, elemental Hg was higher at the scrubber outlet than scrubber inlet during raw mill on 

testing.

The in-line raw mill has a tremendous affect on both mercury speciation and concentration. The 

in-line raw mill acts as a dry scrubber for oxidized mercury much as it does for sulfur dioxide 

and certain other compounds. When the raw mill is operating, the kiln feed materials adsorb the 

oxidized mercury and thus reduce mercury levels at the stack exit. When the raw mill is not 

operating (i.e., periods of routine maintenance or malfunction), the natural scrubbing does not 

occur. Additionally, previously silo’d material is used for kiln feed thus releasing previously 

sequestered mercury. 

Scrubber inlet concentrations for raw mill off versus raw mill on were observed to be 40-50 

times greater in some circumstances. The in-line raw mill and silo system sequester the 

oxidized mercury and subsequently release it back to the effluent during raw mill off 

conditions.
5

3.3 Effect of Scrubbers

The scrubbers were observed to reduce the amount of oxidized mercury during raw mill off 

operation since this compound is water soluble. In most cases, re-emission was observed across 

the scrubbers during raw mill on operation as observed by higher elemental mercury at the outlet 

than at the inlet to the scrubber. Re-emission is a phenomena encountered in the utility industry 

as well1

 1

 Ghorishi, B., Downs, B., & Renninger, S., “Role of Sulfides in Sequestration of Mercury by Wet Scrubbers,” 

EPRI/DOE/EPA/AWMA Combined Symposium on Power Plant Air Pollution Control, Baltimore, MD. August 28-31, 

2006. 

. It occurs when oxidized mercury captured by the scrubber is reduced back to elemental 

mercury in the alkaline conditions encountered in the scrubber liquor. The elemental mercury is 

not water soluble and thus it is stripped out of the scrubber liquor and released back into the 

effluent. The scrubber system sequesters the oxidized mercury, with release of elemental 

mercury back to the stack effluent. This is particularly evident during mill on conditions. 

Together the two competing phenomena create a dynamic equilibrium between capture and 

release of mercury compounds. 

4.0 SUMMARY OF TOTAL MERCURY RESULTS – METHOD 30B

Table 4-1 presents the results for each facility in terms of total mercury, and range of calculated 

mercury removal. These results are derived from Method 30B results only, FAMS speciated 

results are presented in Section 5.

For raw mill on operation the results have been: 1) corrected for spike recovery and, 2) the 

precision of the paired results were used to present the range of possible percent Hg removal. 

The apparent removal during mill on operation was either a negative number of a very low 

percentage removal. 

The correction of raw mill on results for bias based on spike recovery is possible and plausible

since the spike levels were very close to the actual effluent concentrations. Appendix A 

presents the application of spike correction, and the statistical analyses employed. Note that in 

some cases the precision was excellent and therefore contributed little in the error analyses 

presentation.

Raw mill off operation did not employ a spike correction or statistical analyses of the data for 

two reasons. First the spike correction for bias could not be determined at the stack 

concentrations encountered during mill off (spike levels were simply too low to employ for this 

purpose), and secondly, there appears to be actual Hg removal during raw mill off operation due 

to the elevated Hg+2 observed during this process condition.
6

TABLE 4-1 PCA-Hg Scrubber Project Results Summary

MILL ON

Method 30 B Results

Inlet 

HgT

Outlet 

HgT % Removal % Removal Range

Facility ug/m3 ug/m3 ug/m3 2-SIGMA

Lehigh North 16.7 18.8 -13%

Spike Corrected 17.5 21.1 -20% - 56% to 9%

Holcim Portland 1.2 2.8 -133%

Spike Corrected 1.2 2.7 -120% - 188% to -72%

Holcim Midlothian - K#1 4.2 2.9 31%

Spike Corrected 4.1 2.6 38% 31% to 38%

Holcim Midlothian - K#2 7.3 6.5 11%

Spike Corrected 6.6 6.4 4% 4% to 11%

TXI 4.9 3.6 27%

Spike Corrected 4.8 3.6 26% 23% to 29%

MILL OFF

Method 30 B Results

Inlet 

HgT

Outlet 

HgT % Removal 

Facility ug/m3 ug/m3 ug/m3

Holcim Portland 193.0 14.0 93%

Holcim Midlothian - K#1 182.0 22.0 88%

Holcim Midlothian - K#2 180.0 50.0 72%

TXI 96.0 40.0 58%

Note that all concentration results are normalized to 7% oxygen
7

5.0 FAMS Results

Table 5-1 presents the FAMS testing results for speciated mercury on a plant-by-plant basis. 

Suspect data are highlighted in yellow. 

Some of the FAMS outlet data were questionable for two reasons; 1) liquid water droplets 

solublized oxidized mercury from the potassium chloride (KCl) media and transported it through 

the trap as was noted in the Lehigh North scrubber outlet data, and 2) elevated temperatures 

employed to eliminate water droplet collection resulted in oxidized mercury being transported 

through the trap. This phenomenon was noted in the Holcim Midlothian and TXI scrubber outlet 

data where there is an apparent reduction of elemental mercury as indicated by the FAMS data. 

This occurs when the mercury originally captured on the KCl section (designed to capture 

oxidized mercury) of the FAMS trap is desorbed at elevated temperature and then carried 

through to the carbon (section of the trap for elemental Hg) and thus counted as inappropriately 

counted elemental mercury. 

Questionable FAMS data are flagged in yellow.

Table 5-1 Results Summary

Mill On

ug/m3 at 7% O2 Inlet Results Outlet Results Removal

Facility Hg p Hg +2 Hg 0 Hg p Hg +2 Hg 0 Hg p Hg +2 Hg 0

Lehigh North 0.06 0.61 11.60 0.50 5.51 20.17 -804%

-

800% -74%

Holcim Portland 0.03 0.48 0.48 0.05 0.13 1.74 -61% 74% -258%

Holcim Midlothian - K#1 0.04 1.31 2.94 0.05 0.02 3.06 -20% 99% -4%

Holcim Midlothian - K#2 0.05 4.06 1.85 0.01 0.04 3.90 83% 99% -111%

TXI 0.05 0.42 3.49 0.02 0.05 2.25 67% 88% 36%

Mill Off

ug/m3 at 7% O2 Inlet Results Outlet Results Removal

Facility Hg p Hg +2 Hg 0 Hg p Hg +2 Hg 0 Hg p Hg +2 Hg 0

Holcim Portland 2.74 165.52 0.67 0.50 2.20 6.51 82% 99% -865%

Holcim Midlothian - K#1 0.29 59.22 93.27 0.02 0.01 17.80 94% 100% 81%

Holcim Midlothian - K#2 0.78 73.16 33.26 0.05 0.08 38.81 93% 100% -17%

TXI 0.03 0.33 84.68 0.11 0.18 27.24 -229% 46% 68%

Yellow at inlet indicates a suspect error in speciated results. Likely that it is mostly oxidized 

based on the percent removal indicated.
8

6.0 CONCLUSIONS

• The in-line raw mill acts as a dry scrubber for oxidized mercury,

• During raw mill off operation, oxidized mercury is not captured in the raw mill, but is 

removed by the limestone scrubber,

• During raw mill on operation, mercury (captured by the scrubber during mill off 

operation) is released back to the atmosphere because of mercury reduction (Hg+2 Hg0) 

and re-emission,

• Together, the in-line raw mill, raw feed storage system, and limestone scrubbers 

sequester and release mercury from the process in a complex equilibrium.

• Method 30B and the FAMS test methods provided comparable results where good FAMS 

data were available for comparison,

• Some simple modifications to the FAMS method could improve its function in wet stack 

applications,
A

APPENDIX A

Analyses of Mill On Results – Bias Correction and Statistics
PCA Scrubber Test Program - Accuracy and Precision Results

MILL ON 

Facility Lehigh North Holcim PD Holcim TX #1 Holcim TX #2 TXI

Avg. Stack Concentration ug/m 3 ug/m 3 ug/m 3 ug/m 3 ug/m 3

Inlet 16.7 1.2 4.2 7.3 4.9

Outlet 18.8 2.8 2.9 6.5 3.6

Apparent % Removal -13% -133% 31% 11% 27%

Spike Accuracy Percentage Percentage Percentage Percentage Percentage

Inlet % Recovery 95 97 102 109 102

Outlet % Recovery 88 103 112 102 101

Spike Levels (conc. Eq.) ug/m 3 ug/m 3 ug/m 3 ug/m 3 ug/m 3

Inlet 32 5 13 13 6.7

Outlet 13 5 13 13 6.7

Precision

Average of Paired Differences ug/m 3 ug/m 3 ug/m 3 ug/m 3 ug/m 3

Inlet 1.6 0.0 0.0 0.0 0.1

Outlet 2.0 0.0 0.2 0.0 0.1

Stdev of Pair Differences ug/m 3 ug/m 3 ug/m 3 ug/m 3 ug/m 3

Inlet 1.0 0.1 0.0 0.0 0.0

Outlet 1.6 0.1 0.0 0.0 0.1

Standard Error of Pair Differences ug/m 3 ug/m 3 ug/m 3 ug/m 3 ug/m 3

Inlet 0.45 0.05 0.00 0.00 0.01

Outlet 0.72 0.05 0.00 0.00 0.02

2 Sigma (95% coverage)

Inlet 2.00 0.22 0.00 0.00 0.04

Outlet 3.20 0.22 0.00 0.00 0.11

Analyses done with duplicates analyses ("Pairs") from five trains (10 samples)

Pair difference is absolute amount each results differs from pair average = abs(X-Y)/Avg.

Note - all concentration results are normalized to 7% oxygen
LEHIGH NORTH - MILL ON - Error Analyses of Results Error Bars Error Bars Worst Case Best Case

Lehigh North Corrected for Spike SE 2 Sigma Range of Possible Results

Avg. Stack Concentration ug/m 3 ug/m 3 ug/m 3 ug/m 3 ug/m 3 ug/m 3

Inlet 16.7 17.5 0.45 2.00 15.5 19.5

Outlet 18.8 21.1 0.72 3.20 24.3 17.9

Apparent % Removal -13% -20% -56% 9%

Spike Accuracy Percentage

Inlet % Recovery 95

Outlet % Recovery 88

Spike Levels (conc. Eq.) ug/m 3

Inlet 32

Outlet 13

Precision

Average of Paired Differences ug/m 3

Inlet 1.6

Outlet 2.0

Stdev of Pair Differences ug/m 3

Inlet 1.0

Outlet 1.6

Error Bars

Standard Error of Pair Differences ug/m 3

Inlet 0.45

Outlet 0.72

2 Sigma (95% coverage)

Inlet 2.00

Outlet 3.20
Holcim Portland - MILL ON - Error Analyses of Results

Error Bars Error Bars Worst Case Best Case

Holcim PD Corrected for Spike SE 2 Sigma Range of Possible Results

Avg. Stack Concentration ug/m 3 ug/m 3 ug/m 3 ug/m 3 ug/m 3 ug/m 3

Inlet 1.2 1.2 0.04 0.22 1.0 1.5

Outlet 2.8 2.7 0.04 0.22 2.9 2.5

Apparent % Removal -133% -120% -188% -72%

Spike Accuracy Percentage

Inlet % Recovery 97

Outlet % Recovery 103

Spike Levels (conc. Eq.) ug/m 3

Inlet 5

Outlet 5

Precision

Paired Results Difference from Avg. ug/m 3

Inlet 0.0

Outlet 0.1

Stdev of Pair Differences ug/m 3

Inlet 0.1

Outlet 0.1

Standard Error of Pair Differences ug/m 3

Inlet 0.04

Outlet 0.04

2 Sigma (95% coverage)

Inlet 0.22

Outlet 0.22

Analyses done with paired run results from six trains (12 samples)

Difference from average is the difference between results of each pair (n = 6 pairs)

Variance is the square of the standard deviation and is a value that can be added and subtracted

Subtracting the variance of the paired sample results from the variance of the paired differences allows 
Holcim Midlothian #1 - MILL ON - Error Analyses of Results

Error Bars Error Bars Worst Case Best Case

Facility Holcim TX #1 Corrected for Spike SE 2 Sigma Range of Possible Results

Avg. Stack Concentration ug/m 3 ug/m 3 ug/m 3 ug/m 3 ug/m 3 ug/m 3

Inlet 4.2 4.1 0.00 0.00 4.1 4.1

Outlet 2.9 2.6 0.00 0.00 2.6 2.6

Apparent % Removal 31% 38% 38% 38%

Spike Accuracy Percentage

Inlet % Recovery 102

Outlet % Recovery 112

Spike Levels (conc. Eq.) ug/m 3

Inlet 13

Outlet 13

Precision

Paired Results Difference from Avg. ug/m 3

Inlet 0.0

Outlet 0.2

Stdev of Pair Differences ug/m 3

Inlet 0.0

Outlet 0.0

Standard Error of Pair Differences ug/m 3

Inlet 0.00

Outlet 0.00

2 Sigma (95% coverage)

Inlet 0.00

Outlet 0.00

Analyses done with paired run results from five trains (10 samples)

Difference from average is the difference between results of each pair (n = 5 pairs)

Variance is the square of the standard deviation and is a value that can be added and subtracted

Subtracting the variance of the paired sample results from the variance of the paired differences allows 
Holcim Midlothian #2 - MILL ON - Error Analyses of Results

Error Bars Error Bars Worst Case Best Case

Facility Holcim TX #2 Corrected for Spike SE 2 Sigma Range of Possible Results

Avg. Stack Concentration ug/m 3 ug/m 3 ug/m 3 ug/m 3 ug/m 3 ug/m 3

Inlet 7.3 6.6 0.00 0.00 6.6 6.6

Outlet 6.5 6.4 0.00 0.00 6.4 6.4

Apparent % Removal 11% 4% 4% 4%

Spike Accuracy Percentage

Inlet % Recovery 109

Outlet % Recovery 102

Spike Levels (conc. Eq.) ug/m 3

Inlet 13

Outlet 13

Precision

Paired Results Difference from Avg. ug/m 3

Inlet 0.0

Outlet 0.0

Stdev of Pair Differences ug/m 3

Inlet 0.0

Outlet 0.0

Standard Error of Pair Differences ug/m 3

Inlet 0.00

Outlet 0.00

2 Sigma (95% coverage)

Inlet 0.00

Outlet 0.00

Analyses done with paired run results from five trains (10 samples)

Difference from average is the difference between results of each pair (n = 5 pairs)

Variance is the square of the standard deviation and is a value that can be added and subtracted

Subtracting the variance of the paired sample results from the variance of the paired differences allows 
TXI - MILL ON - Error Analyses of Results

Error Bars Error Bars Worst Case Best Case

Facility TXI Corrected for Spike SE 2 Sigma Range of Possible Results

Avg. Stack Concentration ug/m 3 ug/m 3 ug/m 3 ug/m 3 ug/m 3 ug/m 3

Inlet 4.9 4.8 0.01 0.04 4.8 4.8

Outlet 3.6 3.6 0.02 0.11 3.7 3.5

Apparent % Removal 27% 26% 23% 29%

Spike Accuracy Percentage

Inlet % Recovery 102

Outlet % Recovery 101

Spike Levels (conc. Eq.) ug/m 3

Inlet 6.7

Outlet 6.7

Precision

Paired Results Difference from Avg. ug/m 3

Inlet 0.1

Outlet 0.1

Stdev of Pair Differences ug/m 3

Inlet 0.0

Outlet 0.1

Standard Error of Pair Differences ug/m 3

Inlet 0.01

Outlet 0.02

2 Sigma (95% coverage)

Inlet 0.04

Outlet 0.11

Analyses done with paired run results from five trains (10 samples)

Difference from average is the difference between results of each pair (n = 5 pairs)

Variance is the square of the standard deviation and is a value that can be added and subtracted

Subtracting the variance of the paired sample results from the variance of the paired differences allows 
B

APPENDIX B

Select Charts
0

5

10

15

20

25

30

Lehigh North Holcim Portland Holcim Midlothian - K#1 Holcim Midlothian - K#2 TXI

ug/m3@7% O2

Facility

Mill On Comparisons

Total Hg Concentrations

30B INLET

FAMS INLET

30B OUTLET

FAMS OUTLET
0

20

40

60

80

100

120

140

160

180

200

Holcim Portland Holcim Midlothian - K#1 Holcim Midlothian - K#2 TXI

ug/m3 @ 7% O2

Facility

Mill Off Comparisons

Total Hg Concentrations

30B INLET

30B OUTLET

FAMS INLET

FAMS OUTLET
0.00

2.00

4.00

6.00

8.00

10.00

12.00

Lehigh North Holcim Portland Holcim Midlothian - K#1 Holcim Midlothian - K#2 TXI

ug/m3 @ 7% O2

Facility

Inlet Speciated FAMS Results

Hg p

Hg 0

Hg +2
0.00

2.00

4.00

6.00

8.00

10.00

12.00

14.00

16.00

18.00

20.00

Lehigh North Holcim Portland Holcim Midlothian - K#1 Holcim Midlothian - K#2 TXI

ug/m3 @ 7% O2

Facility

Speciated Outlet Mill On

Hg p

Hg 0

Hg +2

Suspect due to water droplets
0.00

20.00

40.00

60.00

80.00

100.00

120.00

140.00

160.00

Holcim Portland Holcim Midlothian - K#1 Holcim Midlothian - K#2 TXI

ug/m3 @ 7% O2

Facility

Speciated Inlet Mill Off

Hg p

Hg 0

Hg +2
0.00

5.00

10.00

15.00

20.00

25.00

30.00

35.00

40.00

Holcim Portland Holcim Midlothian - K#1 Holcim Midlothian - K#2 TXI

ug/m3 @ 7% O2

Facility

Speciated Outlet Mill Off

Hg p

Hg 0

Hg +2