November 4, 2009

Subject: Meeting with with Portland Cement Association

(DRAFT)

Location: U.S. Environmental Protection Agency, Research Triangle Park, NC

Date: November 3, 2009

Participants: See attached list

I. THC Test Plan Discussion

This primary purpose of this meeting was to discuss industry plans to conduct additional testing 

for THC to supplement existing data as part of the MACT floor analysis. PCA representatives 

presented an overview of their plans to collect at least an additional 30 days, more in some cases, 

of THC CEMS data at approximately 38 sites. These sites were selected on the basis of

representing different kiln types (long wet or dry kilns, preheater kilns, and preheater/precalciner 

kilns), presence or absence of commingled coal mill or raw material dryer exhaust, and high 

(over 50 ppm) or low (under 50ppm) THC emissions. With this test plan, the PCA plans to 

address whether THC emissions are affected by kiln type, commingling of coal mill or raw 

material dryer exhaust with kiln exhaust, and the types of organic materials within the limestone. 

At least 30-days of THC CEMS testing are to be completed by March 31, 2010.

To run simultaneously with the THC CEM testing, PCA plans to conduct raw material sampling 

and analysis for organic content. Samples of aggregate kiln feed raw materials will be collected 

for 30 days and composited for analysis. In addition, samples of limestone will likewise be 

collected and analyzed for organic content.

Test by one cement company has indicated that raw mill grinding may result in low temperature 

off-gassing from the raw mill. If during the THC testing phase, THC emissions are higher during 

raw mill on conditions, PCA will conduct test using an FLS method to measure low temperature 

off-gassing from raw mill grinding.

As part of the same test plan, the PCA will conduct stack test for THC and organic HAP from 

standalone raw material dryers to determine their emission characteristics. The test for organic 

HAP will measure those listed in the THC limit alternative compliance method in the proposed 

rule.

EPA stated that it agreed with PCA’s proposed approach and would issue an e-mail to that effect 

to the PCA for distribution to its members. EPA asked that they be kept informed of the 

progress, as well as problems, with the THC testing. PCA stated that they will get letters of 

commitment from the participating companies and provide copies to EPA. 

II. Portland Cement NESHAP Comments

In response to a request from PCA to EPA to share its impressions of the PCA comments on the 

proposed cement NESHAP, EPA provided the following comments:

- Mercury - any recommendations to revise emissions limits will have to be based on new 

emissions and other objective data provided by PCA.
November 4, 2009

- EPA is assessing the EPA comments on the statistical variability used in developing the 

proposed emission limits.

- HCl – EPA agreed with the PCA that true area source cannot be used as part of the 

MACT floor determination. PCA and EPA discussed the issue of data quality for the 

major sources used in the analysis.

- PM – EPA described its view on the need to revise the existing PM limits.

- EPA described its preference for a production based standard over an input based 

standard.

- EPA described its view on the use of CKD shuttling to reduce mercury emissions. 
November 4, 2009

Participants in November 3, 2009 Meeting with the Portland Cement Association

Portland Cement Association

Andy O’Hare, PCA

Hector Ybanez, Holcim

John Holmes, 

Curtis Leslie, Ash Grove

Mike Pelan, Lafarge

Satish Sheth, Cemex

Bill _________, Holcim

Dave _______ (by telephone)

Nancy Garnett, TXI (by telephone)

Meg Garakani, Holcim (by telephone)

US EPA

Keith Barnett

Elineth Torres

Steve Silverman (by telephone)

RTI International

Mike Laney

Marvin Branscome (by telephone)