Memorandum to File
Subject:  Meeting with CalPortland on Proposed Reasonable Progress FIP
From:      Colleen McKaughan, Associate Director, Air Division
To:  File
Date:  March 26, 2014
Participants:   
 CalPortland: Jay Grady Director, Environmental Affairs, CalPortland
                        Bruce Shafer, Senior VP Cement Operations, CalPortland
                        Wayne Nastri, Co-President, E4 Strategic Solutions, Inc. 
                        Howard Berman, Co-President, E4 Strategic Solutions, Inc.

EPA:              Deborah Jordan, Director, Air Division, EPA Region 9 
                       Colleen McKaughan, Associate Director, Air Division                    
                        Eugene Chen, Engineer, Permits Office
                        Shaheerah Kelly, Engineer, Permits Office
                        Thomas Webb, Project Lead, Planning Office
                        Charlotte Withey, Attorney-Advisor, Office of Regional Counsel
        
Summary:  Representatives of CalPortland went over their comments on the proposed FIP in advance of submittal. They went over several areas in EPA's technical analysis where they asserted that EPA had made errors. Their overall position was that no controls should be required at CalPortland because the visibility benefits are minimal. Their major points were:
   * They did not want the option of an annual tonnage limit (cap) because it would limit production.
   * They believed EPA had made errors in its modeling.  CalPortland redid the modeling with revised inputs and planned to submit that as part of its comments.
   * CalPortland asserted that a 50% control efficiency number was too high and EPA should use a 35% control efficiency number because the kiln was a retrofit design.
   * CalPortland planned to submit revised cost information with its formal comments


 

