
 From:
Steven Silverman/DC/USEPA/US
 To:
Keith Barnett/RTP/USEPA/US@EPA
 Date:
06/20/2009 03:21 PM
 Subject:
memo to docket


Keith,

Could you please docket the following note?  thks!


MEMORANDUM  

TO  Cement NESHAP docket
FROM  Steven SIlverman, Attorney OGC
RE:  Conversations at Los Angeles public hearing

At the July 16 public hearing on the proposed portland cement kiln NESHAP, I had a number of sidebar conversations relevant to the rule which conversations are summarized here.  I spoke with Tracy Goss of the California South Coast Air Quality Management District about the Cr +6 issue mentioned in the preamble.  He stated that most of the fugitive emissions from the plant in question were the result of moving clinker around, rather than being from static piles.  he also said that these fugitive emissions were in violation of State rules, and viewed the situation as a compliance issue.  

I also spoke with a cement industry consultant who was monitoring the hearing.  I did not accurately catch his name.  however, he said that the industry is especially concerned with achieving the proposed standards for THC and HCl, more so than the proposed mercury standards.

