Subject:	Discussion with Holcim Inc. – Reconsideration Issues

Location:	U.S. Environmental Protection Agency, Research Triangle Park,
NC

Date: 		December 6, 2011

Participants:	

Holcim (US), Inc.

Hector Ybanez

RTI International

Matt Hakos

Mike Laney	U.S. Environmental Protection Agency (EPA)

Keith Barnett

Sharon Nizich





The purpose of the meeting was to discuss technical issues relating to
the NSPS and NESHAP reconsideration and other issues.  The following
issues were discussed:

Reconsideration issues for the NESHAP, specifically the definition of
clinker piles, definition of clean fuels, Hg and THC requirements for
coal mills, and start up and shut down definitions.

UPL estimation process – Holcim (US), Inc. presented data supporting
their position that using hourly test runs with the UPL to develop the
30 day average does not adequately allow for variability and, therefore,
underestimates what the limit should be.

Hg CEM trials – Holcim (US), Inc. presented preliminary results from
multiple Hg CEM vendors tested at their facilities.

NSPS issues – Holcim (US), Inc. suggested a definition for “an
increase in emission rate” to be used for determining a plant
modification, and raw material dryer and finish mill issues. 

In line coal mills – Holcim (US), Inc. explained the various different
coal mill configurations and explained that indirect coal mills
generally utilize approximately 5% of total kiln flue gas to dry and
move coal in indirect mills. The volume of kiln flue gas is diluted with
ambient air to quench the stream prior to contact with the coal for
safety reasons.

Holcim (US), Inc. presented a general overview of the various cement
manufacturing processes in the US and explained the various components
of the processes.

Action Items:

No actions items were indentified in the meeting. 

