Keith Barnett/RTP/USEPA/US 
04/17/2006 10:14 AM	To
keladwig@epri.com, Andy O'Hare" <aohare@cement.org/
cc

bcc

Subject
Stakeholder List for the issue of the use of Coal Flyash as a Feedstock to 
Cement Kilns and Notice of a future Stakeholder Meeting
	
		
		If  you are receiving this email you are on my stakeholders list 
concerning the issue of the use of coal flyash as a feedstock to cement 
kilns.   The issue raised is as follows:
		
		(Excerpt for the preamble of the proposed amendments to the Portland 
Cement NESHAP)
		
		We are also aware that some cement kilns purchase fly ash from utility 
boilers as an additive feedstock.  There is concern that as a result of 
controlling mercury in utility boilers, the purchased fly ash may now have 
a higher mercury content than is the current norm.  The result would be 
that mercury emissions reductions achieved by controlling utility boilers 
would be offset by the release of this previously controlled mercury in a 
cement kiln when the fly ash is used as an additive.  At this time, we are 
uncertain if the use of fly ash from utility boilers that are controlling 
their mercury emissions will be significant.  One possible solution would 
be to ban the use of fly ash from a utility boiler that is controlling 
mercury as an additive to cement kiln feed.  We are specifically 
soliciting comment on a potential ban, or any other methods to address 
this issue. 
		
		Since we originally raised this issue we have been informed that even in 
the absence of mercury controls, coal flyash can have substantial amounts 
of mercury and can be a significant contributor to total mercury emissions 
from a cement kiln. 
		
		Note that we are not concerned with the addition of flyash to cement , we 
are only concerned when the flyash passes through the cement kiln.
		
		Based on  discussions with commenters on this issue and other EPA offices 
I have developed a stakeholder list of persons who have an interest and 
knowledge to offer on this issue.  The list is as follows:
		
		Keith Barnett - EPA, Office of Air Quality Planning and Standards, Project 
Lead for the Portland Cement NESHAP
		Ken Ladwig - Electrical Power Research Institute
Andy O'Hare - Portland Cement Association
Steven Silverman - EPA, Office of General Counsel
Brian Gasiorowski - Lafarge North America
Carl Koch - EPA, Office of Policy, Economics, and Innovation, Sectors 
Strategy Group
John Sager - EPA, Office of Solid Waste
Susan Thorneloe - EPA, Office of Research and Development
Bill Maxwell - EPA, Office of Air Quality Planning and Standards
Steve Fruh - EPA, Office of Air Quality Planning and Standards
Julie Gevrenov - EPA, Region 5
Dave Goss - American Coal Ash Association
Tom Feeley - DOE
Alexander Livnat - EPA, Office of Solid Waste
		Leonard Lazarus - EPA, Office of Enforcement and Compliance Assurance
		
		If anyone has other names they believe should be on  this list please 
contact me.  
		
		I am tentatively planning a stakeholder meeting, probably the week of May 
8 in DC. I am going to hold off until the information being gathered by 
DOE is available.  When we meet on this issue I want to be able to look at 
the data the has already been complied.
		
		I have developed a list of questions that I think we need to answer before 
EPA can make an informed decision on any regulations on the use of flyash 
as a feedstock to a cement kiln.  These questions,and my thoughts on data 
available to answer them, are as follows:
		
		What are the mercury contents of fly ash?   DOE is compiling data and the 
Agency has also done studies.  I think by the end of April we will have a 
lot of data on this.  
		What specific raw materials does the fly ash replace? My understanding is 
that fly ash is used to replace shale or clay.
		What are the typical mercury contents of the replaced raw materials? I am 
not sure if there are data to answer this question - there may be USGS 
information - I haven't checked yet.
		What other impacts does the addition of fly ash have on the kiln, if any?  
Does it affect fuel use, does it affect other emissions?  Are there any 
data to quantify these impacts?  If not, can the impacts be estimated 
based on some type of combustion calculations?  I have heard qualitative 
answers to these questions - but have no quantitative data.  However, 
cement plants are already using flyash.  I have to assume  that they did 
some type of analysis on what the impacts were because they would have to 
insure that the substitution did not adversely affect product quality.  To 
the extent that these data are already available,  we could discuss these 
impacts at the stakeholders meeting.
		If anyone can think of something I have missed let me know.  
		I have not developed a detailed agenda for the first meeting, but my 
thinking is the meeting would begin in mid-morning and last through the 
afternoon.  We would ask participants with data to provide to send us the 
data prior to the meeting and we would discuss the available data in the 
order of the questions above.  Again. if anyone has suggestion on agenda 
topics, contact me.
		Keith W. Barnett
US/EPA OAQPS, SPPD/MMG
Mail Code D243-02
Research Triangle Park, NC  27711
919-541-5605
barnett.keith@epa.gov