Subject:	Meeting with with Portland Cement Association (DRAFT)

Location:	U.S. Environmental Protection Agency, Research Triangle Park,
NC

Date: 		November 3, 2009

Participants:	See attached list

THC Test Plan Discussion

This primary purpose of this meeting was to discuss industry plans to
conduct additional testing for THC to supplement existing data as part
of the MACT floor analysis. PCA representatives presented an overview of
their plans to collect at least an additional 30 days, more in some
cases, of THC CEMS data at approximately 38 sites. These sites were
selected on the basis of representing different kiln types (long wet or
dry kilns, preheater kilns, and preheater/precalciner kilns), presence
or absence of commingled coal mill or raw material dryer exhaust, and 
high (over 50 ppm) or low (under 50ppm) THC emissions. With this test
plan, the PCA plans to address whether THC emissions are affected by
kiln type, commingling of coal mill or raw material dryer exhaust with
kiln exhaust, and the types of organic materials within the limestone.
At least 30-days of THC CEMS testing are to be completed by March 31,
2010.

To run simultaneously with the THC CEM testing, PCA plans to conduct raw
material sampling and analysis for organic content. Samples of aggregate
kiln feed raw materials will be collected for 30 days and composited for
analysis. In addition, samples of limestone will likewise be collected
and analyzed for organic content.

Test by one cement company has indicated that raw mill grinding may
result in low temperature off-gassing from the raw mill. If during the
THC testing phase, THC emissions are higher during raw mill on
conditions, PCA will conduct test using an FLS method to measure low
temperature off-gassing from raw mill grinding.

As part of the same test plan, the PCA will conduct stack test for THC
and organic HAP from standalone raw material dryers to determine their
emission characteristics. The test for organic HAP will measure those
listed in the THC limit alternative compliance method in the proposed
rule.

EPA stated that it agreed with PCA’s proposed approach and would issue
an e-mail to that effect to the PCA for distribution to its members. EPA
asked that they be kept informed of the progress, as well as problems,
with the THC testing. PCA stated that they will get letters of
commitment from the participating companies and provide copies to EPA. 

Portland Cement NESHAP Comments

In response to a request from PCA to EPA to share its impressions of the
PCA comments on the proposed cement NESHAP, EPA provided the following
comments:

Mercury - any recommendations to revise emissions limits will have to be
based on new emissions and other objective data provided by PCA.

EPA is assessing the EPA comments on the statistical variability used in
developing the proposed emission limits.

HCl – EPA agreed with the PCA that true area source cannot be used as
part of the MACT floor determination. PCA and EPA discussed the issue of
data quality for the major sources used in the analysis.

PM – EPA described its view on the need to revise the existing PM
limits.

EPA described its preference for a production based standard over an
input based standard.

EPA described its view on the use of CKD shuttling to reduce mercury
emissions. 

Participants in November 3, 2009 Meeting with the Portland Cement
Association

Portland Cement Association

Andy O’Hare, PCA

Hector Ybanez, Holcim

John Holmes, 

Curtis Leslie, Ash Grove

Mike Pelan, Lafarge

Satish Sheth, Cemex

Bill _________, Holcim

Dave _______ (by telephone)

Nancy Garnett, TXI (by telephone)

Meg Garakani, Holcim (by telephone)

US EPA

Keith Barnett

Elineth Torres

Steve Silverman (by telephone)

RTI International

Mike Laney

Marvin Branscome (by telephone)

November 4, 2009

