MEMORANDUM

TO:  Portland Cement Docket

SUBJECT:  Meeting with the Portland Cement Association and cement
industry representatives, July 13, 2006

FROM:  Keith Barnett, USEPA/OAQPS/SPPD/MMG

DATE:  July 14, 2006

	On the afternoon of July 13, 2006, representatives of the portland
cement industry met with representatives of EPA at the Lehigh Cement
Plant in Union Bridge, Maryland.  The attendees were as follows:

Portland Cement Association:  

Andy O’Hare

Cement Industry:

Kurt Deery, Lehigh Cement Company

Kent Martin, Lehigh Cement Company 

Tim Matz, Heidelberg Cement Group

Fran Streitman, Ash Grove Cement Company

Meg Garakani, Holcim (US) Inc.

U. S. Environmental Agency:

	Keith Barnett

	Steve Fruh

	Ted Palma (by phone during discussion of HCl study)

Environ International Corporation

	Alan Kao ((by phone during discussion of HCl study)

The agenda items for the meeting were as follows:

Introduction (Tim Matz, Lehigh)

Discuss THC Standard for Existing Kilns 

Review of HCl Modeling Evaluation (Alan Kao, Environ)

Discuss Mercury/Fly Ash issue

Comment Period Extension

Other Business

Discussion of THC Standard for Existing Kilns

The PCA and industry representatives discussed the background of the THC
standards and voiced their concerns that the standards cannot be met by
all kilns using good combustion practices, which was the basis of the
proposed floor.  (This discussion tracked the group’s earlier
presentation at a meeting with Assistant Administrator Wehrum during the
public comment period.)  The EPA representatives asked if there were
other methods to demonstrate that a kiln was employing good combustion
practices, such as temperature monitoring.  The industry representative
noted that each kiln may have different temperatures that represent best
combustion.  The industry representatives agreed to further consider
alternative parameter monitoring and provide a response to EPA.  (This
same request was put to the group at the end of the earlier meeting with
the Assistant Administrator.)

Review of HCl Modeling Evaluation

Alan Kao of Environ presented the results of a modeling exercise for HCL
emissions from cement kilns.  The draft analysis is included as
Attachment 1.  The presentation is included as Attachment 2.

Discussion of Mercury/Fly Ash Issue

The EPA and industry representative discussed the status of this issue
and what data were available.  The Lehigh facility where the meeting
took place uses fly ash as a cement kiln feed.  The plant personnel
provided data on the mercury content of their fly ash.  They did not
have data on the mercury content of the shale that the fly ash replaced,
but stated they would investigate if the data could be obtained.  Fly
ash makes up about 10 percent by weight of the kiln feed at this
facility.  According to the industry representatives it can be up to 15
percent in some kilns.  The mercury contents of the fly ash, coal, and
mill scale used at this facility are shown below:

Date of Sample	Fly ash	Coal	Mill Scale

	Total Mercury Result (mg/kg)	Total Mercury Result (mg/kg)	Total Mercury
Result (mg/kg)

Apr-05	< 1.0	1.83	< 1.0

3-Mar-06	1.4	1.6	No Sample

10-Mar-06	0.27	0.82	No Sample

24-Mar-06	0.27	1.5	0.23

31-Mar-06	0.28	0.49	0.23



  

