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.

