"CHADBOURNE John" <John.Chadbourne@essroc.com> 
05/18/2007 06:01 PM	To
Keith Barnett/RTP/USEPA/US@EPA
cc
"Anderson, William" <wcanderson@stl-inc.com>, "YBANEZ Hector" 
<HECTOR.YBANEZ@essroc.com>
bcc

Subject
Essroc Sampling and Analysis - EPA request for mercury and TOC information
	
	
	History:	
This message has been forwarded.


Keith,
 
Essroc will begin sampling next Monday, May 21, 2007 to comply with the 
May 8 letter from Peter Tsirigotis.
I have been assigned responsibility for ensuring the success of the Essroc 
sampling and analysis program.
Hector Ybanez asked that I prepare this note to you clarifying issues that 
may have the potential to cause concerns.
 
I have attached an email distributed yesterday to plant environmental 
engineers and quality control chemists concerning sampling requirements.
Please review that document and let us know if you have a different view 
on any of the issues raised for sample collection.
 
The methods referenced in Mr. Tsirigotis' letter are essentially "SW846" 
methods.  Essroc has retained Severen Trent Laboratories (STL) to provide
guidance and analytical capabilities to accomplish the sampling and 
analysis required.  Dr. William Anderson of STL and I have discussed a 
number
of issues raised on review of the methods to be applied to determine the 
mercury and Total Organic Carbon (TOC) concentration in the thousands of 
samples that will be taken.  Dr. Anderson has pointed out that SW846 
methods are guidelines to which professional judgment must be applied to
produce practical, accurate results.  This is explained in various 
chapters of SW846 where it becomes clear that the quality of the results 
is the 
responsibility of the analytical laboratories, even when difficulties 
arise in the application of the SW846 methods.
 
Essroc intends to use a direct mercury analysis method that is in accord 
with Method 7473 and capable of detecting concentrations as low as 20 
parts per billion (ppb).  Depending on results, some samples will also be 
analyzed using HF total digestion procedures to compare results with the
direct mercury analysis.  The laboratory Essroc has selected will follow 
the quality control guidelines for duplicate, spiked and calibration 
samples 
as specified in the method.  Analytical reports will include the time the 
samples were received and analyzed in addition to sample identification 
parameters.  The samples will be retained on site at the analytical 
laboratory through at least September, 2007 so that confirmatory analyses 
can 
be provided as needed.  Since the all of the samples have been exposed to 
ambient or high temperatures, there will be no need to refrigerate any
of the samples.  In addition, the usual 28 day holding time for mercury 
samples will not apply.  No change in the mercury concentrations for these 
samples is expected under long-term (six month or greater) storage.  Given 
the huge number of samples, the nature of the samples and the ability
to confirm previous results with reanalysis and comparative analytical 
methods, the guidelines for refrigeration and holding time shall not apply.
 
Analysis for TOC will be conducted using the Lloyd Kahn modification of 
Methods 9060 and 9060a.  One of the laboratories selected to do these 
analyses employs a Shimadzu SSM-5000A TOC analyzer.  We understand that 
phosphoric acid is substituted for hydrochloric or sulfuric acids 
where samples high in carbonates are to be analyzed.  As explained above, 
no refrigeration or holding times are required to provide accurate analyses
of these samples.  For some materials, TOC results will be lower than the 
quantification limit of 500 ppm.  It would be unreasonable to run hundreds
of "non-detect" samples, when this information can be obtained by 
analyzing composite samples plus randomly selected daily samples.  In 
order to 
determine which daily samples need to be analyzed for TOC, the laboratory 
will prepare composite samples representing two week or longer intervals
from the daily composite samples.  If all of the long-term composite 
samples and selected daily composite samples of a particular material (for 
example, Bessemer Kiln 1 slurry feed) are below 500 ppm, no further 
analyses for TOC for that material will be conducted.  The TOC 
concentration will be reported 
as less than 500 ppm. For materials which demonstrate the presence of 
measurable levels of TOC, multiple analyses of daily composite samples 
will be
run to determine the average and variability of TOC results.  The 
requirement for quadruplicate analyses specified in methods 9060 and 9060a 
will not
apply.  Rather, the laboratory analyst will determine the number of 
additional samples to be analyzed based on the results for each sample 
analyzed.
 
I feel sure you will appreciate the need to focus resources on the most 
important questions as we undertake this voluminous sampling and analysis 
program.
 
If you have any questions or comments, please call me at 610 837 3336 or 
send an email.
 
Dr. John F Chadbourne
Senior Environmental Engineer
Essroc Cement Corp.
3251 Bath Pike
Nazareth, PA 18064
 
 
Essroc Cement Corp.

CONFIDENTIALITY NOTE: This message is intended exclusively for the party 
or parties to whom it is addressed. This communication may contain 
information that is proprietary, privileged or confidential or otherwise 
legally exempt from disclosure. If you are not one of the named 
addressees, you are not authorized to read, print, retain, copy or 
disseminate this message or any part of it. If you have received this 
message in error, please notify the sender immediately by e-mail and 
delete/destroy all copies of the message. Any views or opinions presented 
in this email are solely those of the author and might not represent those 
of Essroc Cement Corp. 
WARNING: Although Essroc Cement Corp. has taken reasonable precautions to 
ensure no viruses are present in this e-mail, the company cannot accept 
responsibility for any loss or damage arising from the use of this email 
or attachments.
Essroc Cement Corp.
----- Message from "CHADBOURNE John" <John.Chadbourne@essroc.com> on Thu, 
17 May 2007 18:24:10 -0400 -----
To:	"ANDREWS Mark" <Mark.Andrews@essroc.com>, "AYALA MELENDEZ Nivia" 
<Nivia.Ayala@essroc.com>, "CAWTHRAY Mike" <Mike.Cawthray@essroc.com>, 
"CONN Corey" <Corey.Conn@essroc.com>, "CONSTANT David" 
<David.Constant@essroc.com>, "DUETTA Dale" <Dale.Duetta@essroc.com>, "HARP 
Allen" <Allen.Harp@essroc.com>, "HITT David" <David.Hitt@essroc.com>, 
"LUNGU Radu" <Radu.Lungu@essroc.com>, "RIVERA Beatriz" 
<Beatriz.Rivera@essroc.com>, "SHAW Derek" <Derek.Shaw@essroc.com>, "YBANEZ 
Hector" <HECTOR.YBANEZ@essroc.com>
cc:	"AYALA MELENDEZ Nivia" <Nivia.Ayala@essroc.com>, "CORDER Rebecca" 
<Rebecca.CORDER@essroc.com>, "COSTELLO James" <James.Costello@essroc.com>, 
"DUBCHAK Patricia" <Patricia.Dubchak@essroc.com>, "EATON Melissa" 
<Melissa.Eaton@essroc.com>, "EMMERT Allen" <Allen.Emmert@essroc.com>, 
"FARMER Kelly" <Kelly.Farmer@essroc.com>, "GROTHEER Kevin" 
<Kevin.Grotheer@essroc.com>, "KLEMICK William" 
<William.Klemick@essroc.com>, "LEGATE Harold" <harold.legate@essroc.com>, 
"STOFFICK Thomas" <Thomas.Stoffick@essroc.com>, "WILT Larry" 
<Larry.Wilt@essroc.com>, "JANY Lou" <LOU.JANY@essroc.com>, "CORDER 
Rebecca" <Rebecca.CORDER@essroc.com>, "RIZZI Fabio" 
<Fabio.Rizzi@essroc.com>, "DIDION Josh" <Josh.Didion@essroc.com>, 
"Anderson, William" <wcanderson@stl-inc.com>, "Carswell, Patti" 
<pcarswell@stl-inc.com>, <GCLab2@comcast.net>
Subject:	Sample Preparation for Shipment to Analytical Laboratories
Folks,
 
As we agreed in the conference call last Friday, the samples to be taken 
to comply with the EPA Section 114 letter that Essroc received last week 
need to be collected with rigorous quality assurance protocols.  
Representatives of Severen Trent Laboratories (STL) have assisted us by 
preparing master sample logs, daily sample collection sheets and request 
for analysis/chain of custody forms.
 
All samples sent to the laboratories must be homogeneous dry powder.  The 
laboratories will remove a sample (<1 gram) from each container.  The 
sample you send must be a sample from which a representative aliquot can 
be removed with no further preparation.  For samples of fuel taken from 
the burner pipe, CKD and ground feed to sent to the kiln, fine dry powders 
are collected directly at the sampling locations.  For clinker samples, 
please grind the samples finer than ~200 mesh before preparing split 
samples.  For slurry from wet-process kilns, please dry the samples as you 
normally do and retain excess dried feed material to prepare your daily 
composite samples.  For raw material components, minimal drying is 
recommended, so long as a homogeneous "dry" powder is produced for sample 
splitting.  A clay or other material with high water affinity can be dried 
at 105 C as necessary to produce a dry powder.  Excessive drying must be 
avoided.
 
Sample splitting into thirds is accomplished by thoroughly shaking the 
container of dry powder to achieve a homogeneous mixture.  Remove 
approximately 200 grams of material from the thoroughly-shaken composite 
sample mixture and place it on a clean sheet of paper.  Carefully divide 
the pile of dry powder into "sixths" using a clean spatula to divide the 
pile.  Remove two "opposite" sixths into one of the sample containers to 
prepare the first split sample.  The two remaining "opposite sixths" to 
prepare the second split sample.  The remaining sample is placed into a 
third sample container.  One of the samples will be analyzed for mercury, 
another for TOC and the third will be archived for repeat or subsequent 
analysis.
 
The sample containers shipped from STL will be packaged with five cases 
(24 count) per shipping box.  The packaging materials must be saved so 
that the samples can be shipped to the laboratories in the same shipping 
materials.  This procedure will minimize breakage.  Collect mercury 
samples in one set of sample cases until 5 cases have been accumulated.  A 
plant collecting 10 mercury samples per day will fill the sample shipping 
box in 12 days of sampling.
(10 samples per day X 12 days of sampling = 120 samples = 5 cases X 24 
samples per case).  There is no need to refrigerate samples.  The 
materials used to manufacture cement are stored at ambient temperatures 
and exposed to high temperatures in the pyroprocess.  Mercury present in 
feed to the raw mills will be stable as complex mercury minerals.  
 
Since the only constituents to be measured are mercury and TOC, you may 
use grinding equipment which contains chromium metal to prepare these 
samples.  The amount of chromium contamination possible from chromium 
grinding equipment in this instance is acceptably low.
 
Please complete the daily sample collection log that describes the time 
when each component of the composite sample was collected.  The initials 
of the individual should be entered in addition to the time when the 
sample was collected.  At least three samples are needed for each daily 
composite sample, unless an equipment failure prevents collection of a 
"shift" sample.  In the case where equipment outages result in a "short 
sample" it is best to start preparation of another complete composite 
sample.  If a "short" composite sample is submitted for analysis, it is 
essential that notes on the sample collection sheet describe the reason 
for collecting that sample.
 
When a shipment of samples has been collected, split and packaged for 
delivery to the laboratories, a request for Analysis/Chain of Custody 
sheet will need to be prepared and sent with the samples.
 
All mercury analyses for the first round of samples will be completed by:
G & C Coal Analysis Lab., Inc. 
Attn: Michael J. Chestnut
1341 Hoffman Hollow Rd
Summerville, PA 15864 
(814) 849-7301. 
 
Information on TOC analysis will be distributed soon.
 
Please call me or send email if there are any questions or concerns.
 
John
Essroc Cement Corp.

CONFIDENTIALITY NOTE: This message is intended exclusively for the party 
or parties to whom it is addressed. This communication may contain 
information that is proprietary, privileged or confidential or otherwise 
legally exempt from disclosure. If you are not one of the named 
addressees, you are not authorized to read, print, retain, copy or 
disseminate this message or any part of it. If you have received this 
message in error, please notify the sender immediately by e-mail and 
delete/destroy all copies of the message. Any views or opinions presented 
in this email are solely those of the author and might not represent those 
of Essroc Cement Corp. 
WARNING: Although Essroc Cement Corp. has taken reasonable precautions to 
ensure no viruses are present in this e-mail, the company cannot accept 
responsibility for any loss or damage arising from the use of this email 
or attachments.
Essroc Cement Corp.