MEMORANDUM

TO:  Cement Kiln MACT Docket

FROM: Steven Silverman, Attorney

RE:  Telephone Conversation with Jim Pew, Earthjustice

		On February 25, Keith Barnett and I spoke with Jim Pew of Earthjustice
regarding our data base for each of the pollutants for which we
contemplate proposing MACT standards.  Mr. Pew asked certain questions
regarding potential technical bases for subcategorizing kilns with
respect to THC emissions.  He also was adamant about not having a
standard recognizing HCl as a threshold pollutant.

