                                 May 23, 2016
Memorandum

Subject:	Summary of Conference Call with National Lime Association Representatives

From:		Matt Hakos and David Green, RTI

To: 		Sharon Nizich, EPA/OAQPS

I.	Purpose

	The purpose of the call was to start discussions with industry regarding the Lime Manufacturing NESHAP and RTR. EPA also asked industry representatives about availability of emissions data, location of sources, and small businesses issues. 

II.	Date and Time

	The call was held May 19[th], 2016 between 9:30a.m. and 10:30 a.m.

III.	Attendees

	Keith Barnett, EPA/OAQPS
	Sharon Nizich, EPA/OAQPS
	David Green, RTI
	Matt Hakos, RTI
	William C. Herz, National Lime Association
	Hunter Prillaman, National Lime Association
	Jon De'ath, National Lime Association
	Joe Freundenberg, Carmeuse Lime and Stone
      Scott Kisner, Greer Lime Company

IV.	Summary

 Introduction
      
      EPA explained the upcoming Lime Manufacturing NESHAP Residual Risk and Technology Review (RTR). EPA indicated that they would likely be proceeding with data collection from industry with a nine company information collection request (ICR). EPA discussed the current RTR program.
   
 Discussion of NLA Member Companies and Data

      The NLA estimated that there are approximately 16 companies represented by their association.  Of these, approximately 6 are small businesses. NLA stated that they believe 2 of the small businesses are major sources.  NLA noted 3 known lime manufacturers that are not members, as noted: 
 Specialty Minerals, MA
 Valley Minerals, MO
 CEMEX de Puerto Rico, Inc., PR
      
In addition, NLA noted that Arcelor Mittal Steel in Indiana operated a captive lime plant.

      The NLA estimated that their current facility membership is approximately 48 facilities, with 30 major sources and 18 area sources.  
      
      EPA explained to the NLA that they are interested in obtaining data for the following:
 Particulate Matter (PM)
 Hazardous Air Pollutant (HAP) Metals from PM
 Mercury (Hg) from PM
 Hydrogen Chloride (HCL)
 Organics
 Total Hydrocarbons (THC)
 Polycyclic Aromatic Hydrocarbons (PAH)
 Dioxins and Furans
      The NLA conveyed that some area sources may have 2006 test data that supported area source determinations from 2006.  No definitive source of test data or pollutants was provided. 
      EPA also discussed the current issues faced with startup and shut down.  The NLA indicated that they were familiar with these current issues. 
      
 Technology Review. 
   
      The NLA approximated that 99% of the existing lime kilns are rotary kilns and that most have pre-heaters. EPA asked the NLA if they were aware of any new kiln design or other technological advances.  NLA stated that they were unaware of any new technologies and stated that the industry has been largely static in terms of technologies used over the last decade. NLA indicated that they are unaware of any CEMS at member companies. 
      The NLA noted that one facility may be using a newer technology (Specialty Minerals, MA).  NLA was not sure what the exact technology was (possibly fluidized bed or Calcimatic), as they are not a member facility. They stated that the technology may be needed for a specific product application. 
      EPA indicated that they intend to visit a facility for informational purposes related to the forthcoming technology review. NLA stated that this would not be an issue, but that they needed to consult with members regarding the best facility for such a visit. 
      NLA stated that wet scrubbers are still used, but not as much as when the rule was promulgated. No specific information was provided. NLA stated that the industry does not combust any hazardous waste.  The primary fuels combusted by members are coal, coke, and natural gas. 
      
 Small Business Issues

      The NLA inquired what the general steps were in regards to small business and the small business panel. EPA indicated that they cannot currently state whether or not a small business panel will be needed, or whether or not it will be required.  The need for a panel cannot be determined at this stage in the rule making process.  EPA will first need to determine whether or not there will be significant impacts prior to making any decisions regarding a panel.  EPA indicate that the Small Business Advocacy Office would be involved with this rule making process. 
      
      E.  Production Data
      
      The NLA indicated that while annual sales are reported to the U.S. Geological Service, annual production is typically confidential business information.
