**Subject:** Meeting with Portland Cement Association (PCA)

**Location:** U.S. Environmental Protection Agency

, Washington, DC

**Date:** August 17 , 2010

**Participants:**

Industry Andy O’Hare, PCA Hector Ybanez, Holcim Jason _______, Holcim Curtis Les s lie, Ash Grove Mike Pelan, Lafarge John Holmes, Lafarge Craig Campbell, Lafarge Dan Nugent, Buzzi Satish Sheth, Cemex U.S. Environmental Protection Agency (EPA) Peter Tsirigotis Steve Silverman Keith Barnett (b y telephone)

RTIInternational (b y telephone) Mike Laney Breda Munoz

The Portland Cement Association (PCA) met with EPA and presented a list of issues (attached) and concerns on the final NESHAP and NSPS. Each of the items listed were discussed briefly. PCA also provided additional information (attached) on the assessment of variability

associated with the standards for mercury

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**Preliminary List of Issues/Concerns with the Portland Cement NESHAP**  **Issue Concern**  **Recommendation Emission Standards**  CISWI Sources in NESHAP Floor Calculations Some fa cilities in

NESHAP floor pools for are CISWI units, Nullifying the floor calculations Stay NESHAP Rule until CISWI rule finalized; Exempt portland cement industry from CISWI rule through tailored definition of solid waste Mercury Standard Improper use of Boiler MACT equation to set standard; Lack of subcategorization Reconsider application of the Boiler MACT equation in standard setting; Creation of subcategory for high emitters is necessary THC Standard Compliance with standard will require widespread ap plication of RTOs Some type of subcategorization approach is necessary to avoid this result HCl Standard Unachievable for many

facilities; Could compel use of scrubbers where there is no water; Industry did not have an opportunity to comment on how EPA

co mputed the standard; Improper review of the finding/implications of PCA’s 112(d)(4) assessment Risk

- based exemption for HCl still desired; Perceived shortcomings of analysis may be addressed; Other regulatory tools available to reduce SOx and PM 2.5 emissio ns, if that is the ultimate EPA objective

PM Standards Existing and new source standards unachievable by many facilities; Industry did not have an opportunity to Reconsider application of Boiler MACT equation; Da ta is lognormal; Variability needs to be computed using reflectingcomment on how EPA computed the standards multiple stack tests,

not among runs within

tests Dioxin/Furan Standard Standard lacking “TEQ” in rule language; Most likely typos Standard is 0.2 ng

TEQ/dscm, not 0.2 ng/dscm (other erro rs in some footnotes) Start

- up and Shutdown Standards No opportunity to comment on these standards; Difficult to determine whether they are achievable Need to assess their efficacy; Will recommend alternatives, as appropriate Malfunctions No opportunity to comment on “affirmative defense” criteria; May be cumbersome Will review and recommend modifications to the criteria or another approach **Other Issues** Open Clinker Piles Requirements as crafted are unworkable; no industry opportunity to comment on th e details Recommend removal or delay in implementation to consider a workable alternative

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- Month Frequency for Compliance Testing for D/F, Hg, Organic HAP and HCl This is too frequent Apply a consistent 5 year interval for facilities without CEMs

Req uirement for PM and HCl CEMs Standard based on stack tests; Compliance based on

CEMs Provide plants with the

option of alternative monitoring approaches

Synthetic Minor HAP Source New NESHAP

considerably different from old NESHAP; Can
sources pursue synt hetic minor HAP status before 2013 New NESHAP with new effective and compliance dates should re

- open the opportunity for facilities to pursue synthetic minor HAP status**Preliminary List of Issues /Concerns**  **with Portland Cement NSPS**  **Issue Concern**  **Recomm endation**  Scope Apparent inclusion of

modifications that don’t result in the construction of a “new” kiln Rule should apply only

to brand new kiln lines, whether at existing facilities or greenfield facilities

**Emission Standards** NOx Standard Too low A s ubcategorization approach may be necessary if “modifications” include simple plant upgrades (and not a new kiln line) SOx Standard Too low Need to review basis of standard; A subcategorization approach may be necessary if “modifications” include simple p lant upgrades (and not a new kiln line) PM Standard Too low See above under NESHAP