Subject:	Meeting with Portland Cement Association (PCA) and Holcim

Location:	U.S. Environmental Protection Agency, RTP, NC

Date: 		August 31, 2010

Participants:	

Industry

Andy O’Hare, PCA*

Hector Ybanez, Holcim

Curtis Lesslie, Ash Grove* 

Mike Pelan, Lafarge*

Dan Nugent, Buzzi*

Robert Crawford, Consultant to PCA*	U.S. Environmental Protection Agency
(EPA)

Steve Silverman*

Keith Barnett

RTI International

Mike Laney

Breda Munoz

*By telephone

The Portland Cement Association (PCA) met with EPA and presented
information on a statistical analysis of the mercury emissions data
using the 30-day averages instead of the daily emission values. They
also discussed the use of PM compliance test data that has been
collected for all portland cement kilns. Handouts were provided
including a meeting agenda and tables illustrating the results of their
statistical analysis.  They are attached to these meeting notes.

Following the meeting with PCA, Hector Ybanez of Holcim presented issues
associated with the final rule that were of concern to Holcim. They
included:

-Determination of clinker production

-Alternate PM limit for kilns with an alkali bypass

-Operation and Maintenance Plan submission

-Use of scrubbers for SO2 and HCl control

-Use of Affirmative Defense

-Data acquisition systems

-Use of CEMS for THC

-PM CEMS requirements in NESHAP and NSPS

-Use of consecutive days for startup and shutdowns

-Modifications under NSPS

-Use of CEMS for 90% SO2 option 

