MEMORANDUM
SUBJECT: February 24, 2016, meeting with Portland Cement Association (PCA) to discuss status of risk and technology review (RTR) of portland cement NESHAP
FROM: Mike Laney, RTI
TO: Sharon Nizich, US EPA
DATE: March 8, 2016
ATTENDEES:	
                                      PCA
                                      EPA
                                      RTI
                                Curtis Lesslie
                                   Tim Matz
                                Michael Schoen
                                 Sharon Nizich
                                 Keith Barnett
                                  Teresa Lowe
                                  Mike Laney
                                       

SUMMARY:
EPA presented an overview of the risk and technology (RTR) process.  This is a two part process: risk assessment and technology review.
For the risk review, EPA uses emissions data and site specific source data to model emissions to assess chronic and acute health risks remaining after implementation of the portland cement NESHAP. Because of the recent rulemakings for the portland cement industry, EPA plans to use existing data on emissions and emission sources to populate the emissions modeling files rather than collecting all new data using an information collection request (ICR) survey of the industry. Where gaps are found in the information needed for modeling emissions, EPA may request such information from industry. For the speciation of metal HAP and organic HAP, which is not available for all facilities, EPA will use averages of available existing data to extrapolate to the entire portland cement industry.
For the technology review, the EPA reviews the latest technology available to further reduce emissions.  These new developments may have been put into service since the rule was promulgated. The technology review will consist primarily of a site visit to a newer portland cement plant, review of industry trade publications, and internet searches.
