July 16, 2007

Keith Barnett

U. S. Environmental Protection Agency

Office of Air Quality Planning and Standards

Mail Code D234-02

Research Triangle Park, North Carolina 27711

Re:  Essroc Sampling Program

        Preliminary Mercury  Results in Essroc Cement Manufacturing
Materials

Dear Mr. Barnett:

	Essroc began sampling on Monday, May 21, 2007 to comply with the May 8
letter from Peter Tsirigotis.  Most of the Essroc plants have completed
sampling, except where kiln outages prevented continued sampling. 
Laboratory results have been received for some materials, but analysis
continues.  I am providing the mercury results that we have received to
date rather than waiting for all of the results to become available. 
You will receive additional results when they become available but we
would prefer to send a complete summary rather than sending piecemeal
results.

	The laboratory selected to complete these analyses has encountered a
number of difficulties that have caused delays.  For example, G&C
ordered a second direct mercury analyzer from Milestone (the
manufacturer mentioned in EPA correspondence on mercury Method 7473). 
The analyzer proved to be unable to perform adequately.  After three
weeks of diligent effort working with the manufacturer, the instrument
was returned to Milestone.  A second LECO direct mercury analyzer was
put into service, but significant time was lost due to the failure of
the Milestone unit.

Analysis for TOC using the Lloyd Kahn modification of Methods 9060 and
9060a. on the Shimadzu SSM-5000A TOC analyzer has produced unusual
results that appear to indicate carbonate interference due to addition
of too little acid.  We are investigating this problem using an ASTM TOC
method.  Results for TOC in Essroc materials will be provided when we
are confident that the results are correct and meaningful.

	Information on the amount of each raw material component consumed
during 2006 and data from previous stack tests for mercury will be
provided shortly.  We wanted you to have these preliminary results on
the 75th day stipulated in Mr. Tsirigotis’ letter so that you may
begin your analysis of the preliminary results.

If you have any questions or comments, please contact Dr. John
Chadbourne at 610-837-3336 or me at 610 837 3329 or send an email to
either of us. 

Very Truly Yours

Hector Ybanez

Director Environmental Affairs

NOTE:  The attached mercury information are contained in a follow up
response and are part of the file set of docket item 1934.

Tel	610-837-3336

Fax	610-837-9614

3251 Bath Pike

Nazareth, PA 18064

Essroc

Italcementi Group

