MEMORANDUM

TO:  Portland Cement Rulemaking Docket

SUBJECT:	Meeting with Portland Cement Association and Cement Industry
Representatives to discuss their concerns on the Final Portland Cement
NESHAP and NSPS

LOCATION:	 Offices of the Portland Cement Association, 500 New Jersey,
Avenue, NW,    

                          Washington, DC 20001

DATE OF MEETING:  August 17, 2010

Participants:	

Portland Cement Association (PCA) 

And Cement Industry

Andy O’Hare, PCA

Hector Ybanez, Holcim

Jason Morin, Holcim

Curtis Lesslie, Ash Grove 

Tim Matz, Lehigh

Mike Pelan, Lafarge

Satish Sheth, CEMEX

Bryan Brendle, PCA 

Ty Wilson, PCA

Craig Campbell, Lafarge 	U.S. Environmental Protection Agency (EPA)

Peter Tsirigotis

Steve Silverman

Keith Barnett (by phone)

Elineth Torres (by phone)

Susan Fairchild (By Phone)

RTI International (contractor to EPA)

Mike Laney

Breda Munoz





The Portland Cement Association (PCA) met with EPA and presented a list
of issues (attached) and concerns on the final NESHAP and NSPS. Each of
the items listed were discussed briefly. PCA also provided additional
information (attached) on the assessment of variability associated with
the standards for mercury.

Some of the specific item discussed were:   

Conflicts between standards.  Mainly the issue that wet scrubbers for
HCl control may result in situation where the facility cannot meet the
PM emissions limit due to carryover from the wet scrubber.

The levels of the standards, especially the new source standards for PM.

Concerns about the startup and shutdown limits.

Regulations for open clinker piles.

EPA agreed that we would continue a dialogue on some of these issues. 
Four areas EPA specifically agreed to continue to discuss were:

The NSPS modification emissions limits

HCl/PM conflicts noted above

Modification relating to kiln subject to the Commercial and Industrial
Solid Waste incinerator (CISWI) rule

The UPL calculation for mercury.

The conversion used to calculate the concentration limits for startup
and shutdown.

The industry also discussed concerns about the overlap of the CISWI and
NESHAP rules.  EPA recommended they start a dialogue specifically on
this issue as soon as possible.

Attachment 1

List of Issues provided by the Portland Cement association

Preliminary List of Issues/Concerns with the Portland Cement NESHAP

Issue	Concern	Recommendation

Emission Standards

CISWI Sources in NESHAP Floor Calculations	Some facilities in NESHAP
floor pools for are CISWI units, Nullifying the floor calculations	Stay
NESHAP Rule until CISWI rule finalized; Exempt portland cement industry
from CISWI rule through tailored definition of solid waste

Mercury Standard	Improper use of Boiler MACT equation to set standard;
Lack of subcategorization	Reconsider application of the Boiler MACT
equation in standard setting; Creation of subcategory for high emitters
is necessary

THC Standard	Compliance with standard will require widespread
application of RTOs	Some type of subcategorization approach is necessary
to avoid this result

HCl Standard	Unachievable for many facilities; Could compel use of
scrubbers where there is no water; Industry did not have an opportunity
to comment on how EPA computed the standard; Improper review of the
finding/implications of PCA’s 112(d)(4) assessment	Risk-based
exemption for HCl still desired; Perceived shortcomings of analysis may
be addressed; Other regulatory tools available to reduce SOx and PM2.5
emissions, if that is the ultimate EPA objective 

PM Standards	Existing and new source standards unachievable by many
facilities; Industry did not have an opportunity to comment on how EPA
computed the standards	Reconsider application of Boiler MACT equation;
Data is lognormal; Variability needs to be computed using reflecting
multiple stack tests, not among runs within tests 

Dioxin/Furan Standard	Standard lacking “TEQ” in rule language; Most
likely typos	Standard is 0.2 ng TEQ/dscm, not 0.2 ng/dscm (other errors
in some footnotes)

Start-up and Shutdown Standards	No opportunity to comment on these
standards; Difficult to determine whether they are achievable	Need to
assess their efficacy; Will recommend alternatives, as appropriate

Malfunctions	No opportunity to comment on “affirmative defense”
criteria; May be cumbersome	Will review and recommend modifications to
the criteria or another approach 

Other Issues 

Open Clinker Piles	Requirements as crafted are unworkable; no industry
opportunity to comment on the details	Recommend removal or delay in
implementation to consider a workable alternative

30-Month Frequency for Compliance Testing for D/F, Hg, Organic HAP and
HCl	This is too frequent 	Apply a consistent 5 year interval for
facilities without CEMs 

Requirement for PM  and HCl CEMs	Standard based on stack tests;
Compliance based on CEMs	Provide plants with the option of alternative
monitoring approaches

Synthetic Minor HAP Source	New NESHAP considerably different from old
NESHAP; Can sources pursue synthetic minor HAP status before 2013	New
NESHAP with new effective and compliance dates should re-open the
opportunity for facilities to pursue synthetic minor HAP status



Preliminary List of Issues/Concerns with Portland Cement NSPS

Issue 	Concern 	Recommendation

Scope	Apparent inclusion of modifications that don’t result in the
construction of a “new” kiln	Rule should apply only to brand new
kiln lines, whether at existing facilities or greenfield facilities



Emission Standards

NOx Standard	Too low	A subcategorization approach may be necessary if
“modifications” include simple plant upgrades (and not a new kiln
line) 

SOx Standard	Too low	Need to review basis of standard; A
subcategorization approach may be necessary if “modifications”
include simple plant upgrades (and not a new kiln line)  

PM Standard	Too low	See above under NESHAP



Attachment 2

Mercury Variability Calculations

