MEMORANDUM

FROM: Steven Silverman, Attorney OGC

TO:  Portland Cement NESHAP Clarification notice Docket

RE:  Conversation with Jim Pew, Esq.

On the afternoon of October 21, Keith Barnett and I called Jim pew,
counsel to EarthJustice and main author of their comments during the
rulemaking, to give him advance notice of four clarifying changes we are
contemplating for the portland cement NESHAP rule language.  These are: 
restoring the pre-2009 standards during the period before compliance
with the newly adopted standards, adding open clinker piles and opacity
to the list of standards with a November 2013 compliance date, fixing a
cross reference, and adding words dropped from a table in the rule.

