MEMORANDUM
FROM:
Steven
Silverman,
Attorney
TO:
Portland
Cement
Administrative
Record
RE:
Meeting
of
May
26,
2006
between
EPA
and
Portland
Cement
Ass'n
(
PCA)

On
May
26,
representatives
of
the
PCA
(
including
Tom
Gibson
and
Andy
O'Hare)
met
with
General
Counsel
Ann
Klee,
Assistant
Administrator
Bill
Wehrum
and
various
EPA
staff
(
Patricia
Embrey,
Peter
Tsirigotis,
Keith
Barnett
and
myself)
to
discuss
their
concerns
about
reopening
the
comment
period
for
the
portland
cement
MACT
proposed
rule.
They
were
especially
concerned
about
reopening
the
comment
period
generally,
rather
than
on
discrete
issues
(
such
as
possible
contribution
to
Hg
emissions
from
use
of
utility
fly
ash).
Regarding
the
issue
of
Hg
contribution
from
fly
ash,
they
stated
that
40
kilns
are
presently
using
fly
ash
as
a
feedstock,
and
that
the
levels
of
Hg
in
the
fly
ash
varies
(
and
noted
that
there
could
be
a
tradeoff
in
levels
of
Hg
and
VOC).
They
wondered
if
this
issue
could
be
severed
from
the
current
rulemaking
and
dealt
with
on
a
longer­
term
basis.
They
are
also
generally
concerned
about
stigmatizing
other
secondary
materials
(
tires,
other
byproducts)
that
are
used
as
a
feed
or
alternative
fuel
by
cement
kilns.
