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 Lesslie, 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 (by telephone)

RTI International (by 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.
8-13-10 

Preliminary List of Issues/Concerns with the Portland Cement 

NESHAP

Issue Concern Recommendation

Emission Standards

CISWI Sources in 

NESHAP Floor 

Calculations

Some facilities 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 application 

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 

computed 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 PM2.5

emissions, 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; Data is 

lognormal; Variability 

needs to be computed 

using reflecting 
comment 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 errors 

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 the 

details

Recommend removal 

or delay in 

implementation to 

consider a workable 

alternative

30-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 

Requirement 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 

synthetic 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 Recommendation

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 subcategorization 

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 plant upgrades 

(and not a new kiln 

line) 

PM Standard Too low See above under 

NESHAP