From: "Higgins, Cortney" <Cortney_Higgins@omb.eop.gov>

To: Sharon Nizich/RTP/USEPA/US@EPA

Cc: Keith Barnett/RTP/USEPA/US@EPA, Charlotte Bertrand/DC/USEPA/US@EPA

Date: 06/15/2012 09:55 AM

Subject: RE: EO 12866 review - NESHAP Portland Cement Interagency Review response

I think a parenthetical is fine – something along the lines of “assuming a 25% to 50% compliance 

margin.”

From: Sharon Nizich [mailto:Nizich.Sharon@epamail.epa.gov] 

Sent: Friday, June 15, 2012 7:44 AM

To: Higgins, Cortney

Cc: Keith Barnett; Charlotte Bertrand

Subject: RE: EO 12866 review - NESHAP Portland Cement Interagency Review response

Hello CortneyThis is not a new requirement - it's just an assumption of how the plants operate. We were trying to add 

additional discussion on how the PM CEMS is problematic since facilities operate at even lower levels 

than the actual limit, thereby having even more issues with using the PM CEMS. So, are you saying you 

would prefer we put this in parentheses, or do you want to have the call today to discuss?

In addition, to stay in compliance, sources would be required to operate at average levels of .02 to .03 

lb/ton clinker, which equates to 3 to 5 mg/dscm.

Sharon V. Nizich

Minerals and Manufacturing Group (MMG)

Sector Policies and Programs Division

OAQPS - US EPA

RTP NC 27711

919/541-2825
From: "Higgins, Cortney" <Cortney_Higgins@omb.eop.gov>

To: Sharon Nizich/RTP/USEPA/US@EPA

Cc: Keith Barnett/RTP/USEPA/US@EPA, Charlotte Bertrand/DC/USEPA/US@EPA

Date: 06/14/2012 05:16 PM

Subject: RE: EO 12866 review - NESHAP Portland Cement Interagency Review response

Sharon – to clarify, the inserted text is highlighting the point that in order to comply with the prior 

standard of 0.04, sources would need to on average be at 0.02 to 0.03? It might be helpful to add a 

parenthetical explaining the compliance margin assumption.

Thanks,

Cortney

From: Higgins, Cortney 

Sent: Thursday, June 14, 2012 5:10 PM

To: Sharon Nizich

Cc: Barnett.Keith@epamail.epa.gov; Charlotte Bertrand 

(Bertrand.Charlotte@epamail.epa.gov)

Subject: RE: EO 12866 review - NESHAP Portland Cement Interagency Review response

HI Sharon,

This seems like a new requirement –can we have a conversation tomorrow (I’m free from 10-2 and 3-5) 

to talk about the insert on page 47 :

In addition, to stay in compliance, sources would be required to operate at average levels of .02 to .03 

lb/ton clinker, which equates to 3 to 5 mg/dscm.

Thanks,

Cortney
From: Sharon Nizich [mailto:Nizich.Sharon@epamail.epa.gov]

Sent: Thursday, June 14, 2012 11:02 AM

To: Higgins, Cortney

Cc: Tom Walton; Amy Lamson; Steven Silverman; Laney, Michael N.; Keith Barnett; 

Charlotte Bertrand; Beth Wittig; Wendy Blake

Subject: EO 12866 review - NESHAP Portland Cement Interagency Review response

Hello CortneyPlease find attached revisions to subject package. Sending you the redline version so you can track your 

comments. Note we have added additional discussion on 1) soliciting comments on SS work practices 

(page 91), and 2) oxygen correction factors for raw material dryers (page 119).

(See attached file: EO12866_NESHAP FOR Portland Cement S 2060 AQ93 06112012_version 

_w_OMB_comments_MASTER Jun 14 2012 1100 am.docx)

Sharon V. Nizich

Minerals and Manufacturing Group (MMG)

Sector Policies and Programs Division

OAQPS - US EPA

RTP NC 27711

919/541-2825