MEMORANDUM

FROM:  Keith Barnett, EPA/OAR/OAQPS/SPPD MMG

TO: Portland Cement Administrative Record

RE:  Meetings of November 3 and November 8, 2006 between EPA and
Portland Cement Association (PCA)

	On November 3, EPA staff (Keith Barnett and Steve Fruh) contacted the
PCA to discuss potential regulatory alternatives for mercury and total
hydrocarbons. The discussion centered on the one cement kiln with a
continuously operated regenerative thermal oxidizer, and the five cement
kilns with wet scrubbers.

In addition, the number of new kilns was discussed.  The list sent by
PCA would imply 24 new kilns (any expansion over a few hundred is
probably a new kiln).  Andy O’Hare stated the actual number of new
kilns will be 15 – 20.  Some of the expansions on the information he
sent won’t happen.  

The PCA representative stated that some kilns had wet scrubbers
installed due to SO2 nonattainment issues.  He could not provide a
definitive answer on the level of SO2 emission that would typically
trigger a BACT determination that required a wet scrubber.

A subsequent meeting was held on November 8 for the PCA to provide
additional feedback.  Their recommendations were as follows:

Limit the new source mercury requirements to greenfield sites

Set the mercury limit at 120 ug/dscm (This is the same as the mercury
limit for kilns that burn hazardous waste).

Limit to Greenfield sites and keep the level at 50 ppmv.  This is the
current standard.  

Set an alternative risk-based standard for THC based on national
exposure standards determined by EPA to ensure protection of public
health with an ample margin of safety. 

Create a risk-based subcategory and delist all sources meeting the risk
levels (as in plywood MACT).  

