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

919.781.3824ii 

### 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 C ement Association (PCA) sponsored a test program of five scrubber controlled kilns located at four Portland cement plants . T he scrubbers were installed downstream of particulate matter removal device (i.e., fabric filter baghous es 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” meth od were performed concurrently along with diluent oxygen measurements. Mercury r esults are reported as μg/m 3 

### 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 concentration s.
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 R ESULTS 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 CHARTS1 

## 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, t he EPA request ed speciated mercury (Hg) testing on scrubber equ ipped cement kilns to understand more fully Hg speciation and emissions at Portland cemen t plants. D ata 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 c ompanies sponsored a test program to quantify mercury concen trations upstream and downstream of limestone
scrubber s

. 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 t he 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 part iculate, oxidized and e lemental 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 s crubber 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 K inner 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 in

line 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 conduct ed 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 for2 

### 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 becam e finalized, and entire report package
was submitted in February 2008 to Keith Barnett of the US EPA

. This document presents an overall s ummary of the results and provides conclu sions 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 c oncentrations 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; in

line 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/m 3 

### at the stack or scrubber outlet. Raw mill off operation always produc ed higher
stack concentrat ion levels which ranged from 15 ug/m 3 

### to 50 ug/m 3 

### 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 Hg T 

### 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 Hg T 

### removal in the range of 4

- 11%,

c. the Holcim Midlothian Kiln #1 and the TXI kiln had Hg T 

### removal efficiencies of from 22

- 38%, d. The cement plants operate with raw mill on a pproximately 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 Comp arison

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 FA MS 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

m ost 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 m ercury 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. Additiona lly, previously silo’d material is used for kiln feed thus releasing previously

s equestered mercury

.

Scrubber inlet concentrations for raw mi ll 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 scrubber s 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 well 1

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 stri pped out of the scrubber liquor and released back into the
effl uent. 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 30 B

Table 4

- 1 prese nts the results for each fa cility in terms of total mercury, and range of calculated mercury removal

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

resu lts 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 percent a ge 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

. A ppendix 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 r easons. 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 Hg T 

### Outlet Hg T 

### % Removal % Removal Range
Facility ug/m 3 

### ug/m 3 

### ug/m 3 

### 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 Hg T 

### Outlet Hg T 

### % Removal
Facility ug/m 3 

### ug/m 3 

### ug/m 3



### 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% oxygen7 

## 5 .0 FAMS Results

Table 5

- 1 present s the FAMS testing results for speciated mercury on a plan t

- 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 th e 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 i n 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 t o 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 S ummary

Mill O n ug/m 3 at 7% O 2 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/m 3 at 7% O 2 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%

**Yello w 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, oxidize d 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 

###  Hg 0 

### ) 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 we re 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% oxygenLEHIGH 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 3.20Holcim 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

S elect Charts0 5 10 15 20 25 30

Lehigh North Holcim Portland Holcim Midlothian

- K#1 Holcim Midlothian

- K#2 TXIug/m3@7% O2

Facility 

### Mill On Comparisons Total Hg Concentrations

30B INLET

FAMS INLET

30B OUTLET

FAMS OUTLET0 20 40 60 80 100 120 140 160 180 200

Holcim Portland Holcim Midlothian

- K#1 Holcim Midlothian

- K#2 TXIug/m3 @ 7% O2

Facility 

### Mill Off Comparisons Total Hg Concentrations

30B INLET

30B OUTLET

FAMS INLET

FAMS OUTLET0.00 2.00 4.00 6.00 8.00 10.00 12.00

Lehigh North Holcim Portland Holcim Midlothian

- K#1 Holcim Midlothian

- K#2 TXIug/m3 @ 7% O2

Facility 

### Inlet Speciated FAMS Results

Hg p
Hg 0
Hg +20.00 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 TXIug/m3 @ 7% O2

Facility 

### Speciated Outlet Mill On

Hg p
Hg 0
Hg +2

Suspect due to water droplets0.00 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 TXIug/m3 @ 7% O2

Facility 

### Speciated Inlet Mill Off

Hg p
Hg 0
Hg +20.00 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 TXIug/m3 @ 7% O2

Facility 

### Speciated Outlet Mill Off

Hg p
Hg 0
Hg +2