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Memorandum

Subject:	Summary of Meeting with National Lime Association (NLA)
From:		Matt Hakos, RTI
To: 		Brian Storey, EPA
Date:		November 12, 2021

I.	Purpose
	
The purpose of this meeting was for industry representatives to discuss the current rulemaking effort underway for the Lime Manufacturing Plant NESHAP and notify the EPA of their intent to provide additional data.

II.	Date and Time

The meeting was held virtually on November 10, 2021 between 1:00 p.m. and 2:30 p.m.

III.	Attendees

Brian Storey, EPA
Kevin McGinn, EPA
Keith Barnett, EPA
Tiffany Moore, RTI
Matt Hakos, RTI
William C Herz, NLA
Bradford Frisby, NLA
Hunter Prillaman, NLA
Jonathan De'Ath, NLA
Tim Byrne, NLA
Deborah Maffet, NLA
Joe Freudenberg, Carmeuse and NLA

IV.	Summary of Meeting

The meeting started with introductions of all staff from the EPA, RTI, and the NLA. The NLA then presented a general overview of the lime industry in a power point presentation. This presentation summarized the current state of the industry, including information regarding operations, kiln configurations, feedstocks, fuels consumed, geographical distribution, and pollutants emitted. Next, the 
NLA summarized the original and existing NESHAP's, focusing on the 2020 rule making and residual risk and technology review (RTR). The NLA inquired about the LEAN decision and its impact on future rule makings. The meeting then moved into a discussion of the following pollutants (currently unregulated): hydrogen chloride (HCl), mercury (Hg), organic hazardous air pollutants (o-HAP), and dioxin furans (D/F). 

A summary of the main talking points is provided. 

 The NLA expressed an interest in the EPA setting a health-based standard for HCl. The NLA summarized their position regarding HCl and stated that they will provide cost estimates for control of HCl. The NLA also expressed interest in EPA looking at subcategorization based on kiln type.
 The NLA indicated that for Hg, a variability factor should be applied to any potential standards, using intra-quarry data from floor sources. The NLA stated that they would provide data supporting this position. The NLA also noted that they would prefer the unit of measure for any potential Hg standard to be in units of pounds (lb) per million (MM) tons of lime produced. The NLA also indicated that they have Hg feedstock content information that they will provide to support any potential geographical sub-categorization. 
 The NLA indicated that an aggregated o-HAP standard is most appropriate for their industry, noting that carbon monoxide (CO) and total hydrocarbons (THC) are not appropriate surrogates for their industry. The NLA stated that they will be providing more data for o-HAP. 
 The NLA indicated that work practice standards are most appropriate for D/F due to very low emissions / non-detects. 

Next, the EPA discussed a general timeline for the proposal, noting that February 2022 was a soft target deadline. The meeting ended with the NLA summarizing the data that they intend to provide to EPA to support the current rule making, including:

 Cost estimates to install controls for HCl.
 Hg data to support any potential intra-quarry variability factor.
 Hg feedstock content data to support any potential subcategorization.
 o-HAP data. 
 The NLA committed to reviewing existing D/F test reports and to see if additional data is available. 



