November 4 , 2009



## Subject : Meet ing with with Po rtl

and Cement Associat

ion (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 anal ys is . PCA representatives presented an overview of their plans to collect at least an additional 30 days, more in some cases, o f THC CEMS data at approximately 38 sites . These sites were selected on the basis of representing different kiln ty pes (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 b y kiln ty pe, commingling of coal mill or raw material dryer exhaust with kiln exhaust, and the ty pes 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 anal ys is for organic content. Samples of aggregate kiln feed raw materials will be collected for 30 days and composited for anal ys is. In addition, samples of limestone will likewise be collected and anal yz ed 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 TH C 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 propo sed 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 b y P CA.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 use d in the anal ys is.

- 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

Participant s in November 3, 2009 Meeting with the Portland Cement Association P ortland C ement A ssociation Andy O’Hare, PCA Hector Ybanez, Holcim John Holmes, Curtis L eslie , Ash Grove Mike Pelan, Lafarge Satish Sheth, Cemex Bill _________, Holcim Dave _______ (b y t e lephone) Nancy Garnett, TXI (by

telephone) Meg Garakani, Holcim (by telephone) US EPA Keith Barnett Elineth Torres Steve Silverman (b y telephone) RTI International Mike Laney Marvin Branscome (b y telephone)