                                  Memorandum
                                       
TO:  Rulemaking Docket

FROM:  Keith Barnett

SUBJECT:  Communications with the Cement Industry on the issue of the impact of the solid waste definition rule and the Commercial and Industrial Solid Waste Incineration (CISWI)  rulemaking on the Portland Cement NESHAP Floors.

DATE:  April 21, 2011

As part of EPA's response to a petition for reconsideration received from the Portland cement industry on the Portland Cement NESHAP, we evaluated the impacts of recent EPA rulemakings concerning definition of solid waste and CISWI.  Attached to this cover memorandum are the following items:

1.  A memorandum dated March 21, 2011, entitled Revised Portland Cement NESHAP Floors with CISWI kilns removed. This memorandum was transmitted to the Portland Cement Association on approximately March 25, 2011.

2.  Four excel spreadsheets that present revised floor calculations for particulate matter, Mercury, total hydrocarbons, and hydrochloric acid that were included as attachments to the revised floor memorandum.

3.  A letter from PCA to Gina McCarthy dated April 8, 2011 responding to the EPA memorandum and requesting a meeting.

4.  The PCA response to the EPA memo listed in item 1 above.



                                       
