Prepared for: Prepared by: CalPortland Company AECOM Rillito, AZ Chelmsford, MA 60282724 May 2013 

### Environment



# Reasonable Progress Analysis for CalPortland Company Rillito Cement Plant KilnsPrepared for: Prepared by: CalPortland Company AECOM Rillito, AZ Chelmsford, MA 60282724 May 2013 

### Environment



# Reasonable Progress Analysis for CalPortland Company Rillito Cement Plant Kilns

_________________________________ Prepared By: Robert R. Hall

_________________________________ Prepared By: Robert J. Paine

_________________________________ Reviewed By: Steven L. HeislerAECOM Environment

Reasonable Progress Analysis – CalPortland’s Rillito Kilns May 2013 i



## Contents

Executive Summary ............................................................................................... ES-1

1.0 Introduction ............................................................................................................... 1-1

2.0 Facility Description and Baseline Emissions ........................................................... 2-1

2.1 Facility Description ......................................................................................................2-1

2.2 Kiln NOx Emissions .....................................................................................................2-2



### 3.0 Reasonable Progress Analysis (Steps 1-3) .............................................................. 3-1

3.1 Identification of Technologies (Step 1) and Technical Feasibility (Step 2) ......................3-1
3.1.1 Low NOx Burners with Indirect Firing Systems ...............................................3-1
3.1.2 Mid-Kiln Firing ...............................................................................................3-1
3.1.3 Mixing Air Technologies.................................................................................3-1
3.1.4 Preheater Riser Duct Firing............................................................................3-2
3.1.5 Low NOx Calciner .........................................................................................3-2
3.1.6 Selective Non-Catalytic Reduction .................................................................3-2
3.1.7 Selective Catalytic Reduction .........................................................................3-3
3.1.8 Conclusion ....................................................................................................3-3

3.2 Emission Control Effectiveness (Step 3) .......................................................................3-3
3.2.1 Kilns 1, 2, and 3 ............................................................................................3-3
3.2.2 Kiln 4 ............................................................................................................3-4



### 4.0 Four Factor Impact Analysis (Step 4) ....................................................................... 4-1

4.1 Factor One: Costs of Compliance ...............................................................................4-1
4.1.1 Kilns 1-3 .......................................................................................................4-1
4.1.2 Kiln 4 ............................................................................................................4-1

4.2 Cost of Compliance Summary (Factor 1) .................................................................... 4-11

4.3 Time Necessary for Compliance (Factor 2) ................................................................ 4-11

4.4 Energy and Non-Air Quality Environmental Impacts (Factor 3) .................................... 4-11

4.5 Remaining Useful Life (Factor 4) ................................................................................ 4-11

4.6 Preliminary Conclusions for Step 4 ............................................................................ 4-12



### 5.0 CALPUFF Modeling Procedures ............................................................................... 5-1

5.1 CALMET Processing ...................................................................................................5-1

5.2 CALPUFF Model Formulation for Predicting Visibility Impairment ..................................5-3

5.3 Ammonia Background Concentrations .........................................................................5-3AECOM Environment

Reasonable Progress Analysis – CalPortland’s Rillito Kilns May 2013 ii

5.4 CALPUFF Modeling Procedures ..................................................................................5-6

5.5 Modeled Control Scenarios .........................................................................................5-8

5.6 POSTUTIL Post-Processing ...................................................................................... 5-11

5.7 CALPOST Post-Processing ....................................................................................... 5-11



### 6.0 CALPUFF Modeling Results ..................................................................................... 6-1

7.0 Conclusions for Visibility Improvement Analysis .................................................... 7-1

Appendix A CALMET/CALPUFF Processing Refinements



## List of Tables

Table 2-1: CalPortland Cement Plant Kiln Descriptions................................................................2-1

Table 2-2: Kilns 1, 2, and 3 NOx Emissions* ...............................................................................2-2

Table 2-3: Kiln 4 NOx Emissions ................................................................................................2-2

Table 3-1: NOx Control Technologies and Potential Application for Rillito Cement Kilns ................3-3

Table 4-1: Low NOx Burner with Indirect Firing System Kiln 1, 2, or 3 ..........................................4-3

Table 4-2: Mid-Kiln Firing for Kiln 1, 2, or 3 ..................................................................................4-5

Table 4-3: SNCR with Mixing Air Technologies for Kiln 1, 2, or 3 ..................................................4-7

Table 4-4: SNCR for Kiln 4 .........................................................................................................4-9

Table 4-5: Cost of Compliance ................................................................................................. 4-11

Table 5-1: Background Monthly Ammonia Concentrations Used in the Modeling (ppb) .................5-5

Table 5-2: Modeled Stack Parameters for Kilns 1-3 and Kiln 4 .....................................................5-8

Table 5-3: Emissions Modeled for Base Case and Three Control Scenarios for Kilns 1-3 ............ 5-10

Table 5-4: Emissions Modeled for Base Case and Three Control Scenarios for Kiln 4 ................ 5-10

Table 6-1: 98 th Percentile Visibility Impairment for Base Case Scenario and Three RP Control

Case Scenarios (delta-dv) ..........................................................................................6-1

Table 6-2: Visibility Improvement for the Three RP Control Case Scenarios Relative to the Base

Case Scenario (deciviews) .........................................................................................6-2



## List of Figures

Figure 2-1: CalPortland Company – Rillito Plant ...........................................................................2-1
Figure 5-1: Rillito Kiln Modeling Domain .......................................................................................5-2AECOM Environment

Reasonable Progress Analysis – CalPortland’s Rillito Kilns May 2013 iii

Figure 5-2: IMPROVE NHx Concentrations from April 2011 to January 2012 .................................5-5
Figure 5-3: 2009 IMPROVE Composition Data for Saguaro East National Park .............................5-5
Figure 5-4: Class I Areas Within 300 km of the Rillito Facility ........................................................5-7
Figure 6-1: 22 nd Highest Visibility Impacts Averaged Over 3 Years for the Base Case Scenario and

Three RP Control Case Scenarios (delta-dv) ..............................................................6-3
Figure 6-2: Visibility Improvements of the Three RP Control Case Scenarios Relative to the Base

Case Scenario (deciviews) .........................................................................................6-4AECOM Environment

Reasonable Progress Analysis – CalPortland’s Rillito Kilns May 2013 ES-1



## Executive Summary

A Reasonable Progress (RP) Analysis has been conducted for the Rillito cement plant, located in Rillito, Arizona, which is owned and operated by CalPortland Company (CPC). The cement plant has four kilns. Kilns 1-3, which are long dry kilns, are not BART-eligible. Kiln 4 is a preheater/precalciner kiln that ADEQ has determined, and EPA has proposed to concur, is BART-exempt because it does not contribute to visibility impacts. The key pollutant at issue is nitrogen oxides (NOx) emissions. The RP analysis presented in this report was conducted using a similar analytical framework used by EPA in its RP analysis for its Regional Haze Federal Implementation Plan for Montana (Federal Register, Volume 77, No. 96, Page 23988, April 20, 2012) 1 .. The steps considered were as follows: Step 1 – Identify all available retrofit control technologies with a practical potential for application to the emissions unit and pollutant under evaluation. Step 2 – Eliminate technically infeasible options considering whether or not they have been installed and operated successfully on the type of source under review, could be applied to the source under review and the commercial availability of the technology. Step 3 – Evaluate the control effectiveness of the remaining technologies. Step 4 – Evaluate impacts: of total annual and incremental costs, time necessary for compliance, energy and non-air quality environmental impacts, remaining useful life and visibility, as needed. Step 5 – Select Reasonable Progress controls based upon the analysis of the Step 4 factors. The available NOx emission controls, their expected performance, and costs are summarized in Table ES-1. Table ES-2 presents a summary of the Step 4 four-factor RP Analysis for Kilns 1, 2, and 3. The results of the RP Analysis for Kiln 4 are presented in Table ES-3.

As part of the Reasonable Progress analysis, a visibility improvement modeling review was conducted for all Prevention of Significant Deterioration Class I areas within 300 km of the plant, using the CALPUFF model. The modeling overstates visibility benefits because it does not account for excess ammonia emissions that would be associated with SNCR controls.

The results of this analysis indicate that all candidate controls result in levels of visibility improvement that are far too low to be measured by the available technology for particulate monitors (much less than 0.3 delta-deciview) and less than 12 percent of the perceptible levels that can be visually detected (1 deciview). The visibility improvement associated with SNCR controls on the active Kiln 4, which is BART-exempt due to its low impacts, is about 0.1 delta-deciview, a level which is mentioned in the 1999 Regional Haze Rule as being associated with “no degradation” of visibility. Accordingly, we conclude that none of these Reasonable Progress options is sufficiently effective to replace the current NOx emission controls on the CalPortland kilns in Rillito, AZ.

1 Like EPA’s RP analysis for Montana, CalPortland’s RP analysis follows the analytical framework for determining case-by-case BART set forth in 40 CFR Part 51, Appendix Y.AECOM Environment

Reasonable Progress Analysis – CalPortland’s Rillito Kilns May 2013 ES-2

Table ES- 1: Available NOx Emission Controls, Performance, and Cost

Table ES- 2: NOx Reasonable Progress Analysis for Rillito Kilns 1, 2, and 3

Cost of Compliance Kilns 1, 2, and 3 are very small, long dry kilns with good combustion practices used for NOx control. The effectiveness of available NOx controls is low and the cost effectiveness is high, in the $7,137 to $7,988 per ton range. Time Necessary for Compliance Several years would be required to design, permit and then construct any control equipment.
Energy and Non-Air Quality Environmental Impacts of Compliance All technically feasible controls (low NO x burners, mid-kiln firing, mixing air technologies, and SNCR) would increase energy usage. With respect to SNCR, the storage, transport, and use of urea or ammonia create the potential for hazardous spills and ammonia slip.

Remaining useful life The remaining useful life is unknown and unknowable at this time. CalPortland has an application pending to modernize its facility and permanently shutdown these kilns. Whether CalPortland moves forward with this modernization once the application is processed will depend on the state of the economy at that time. For the purposes of this analysis, we conservatively assumed a 20 year useful life

Conclusion Given that the cost effectiveness for NOx emission reductions at these non-BART, units which have not operated for several years, is greater than $7,000/ton and that the visibility benefits of emissions reductions would be imperceptible and insignificant, CalPortland proposes no new NOx emission controls for these kilns.AECOM Environment

Reasonable Progress Analysis – CalPortland’s Rillito Kilns May 2013 ES-3

Table ES- 3: NOx Reasonable Progress Analysis for Rillito Kiln 4

Cost of Compliance Kiln 4 is a preheater/precalciner unit with NOx emissions already controlled by low NOx burners and preheater riser duct firing. The effectiveness of additional available NOx controls is low and the cost effectiveness is $2,464/ton. Time Necessary for Compliance Several years would be required to design, permit, and then construct SNCR.NOx emission controls could be installed by 2018. Energy and Non-Air Quality Environmental Impacts of Compliance SNCR would increase energy usage. Storage, transport, and use of urea or ammonia create the potential for hazardous spills and ammonia slip. Remaining useful life The remaining useful life may be in excess of 20 years.

Conclusion Given that the cost effectiveness for NOx emission reductions at this non-BART unit is $2,464/ton and that the visibility benefits of emissions reductions would be very small, CalPortland proposes no additional NOx emission controls for this kiln.AECOM Environment

Reasonable Progress Analysis – CalPortland’s Rillito Kilns May 2013 1-1



## 1.0 Introduction

A Reasonable Progress (RP) Analysis has been conducted for the Rillito cement plant, located in Rillito, Arizona, which is owned and operated by CalPortland Company (CPC). This document describes the procedures by which a Reasonable Progress engineering review and visibility improvement analysis has been conducted.

The focus of this analysis is limited to nitrogen oxides (NOx) emissions for two reasons. First, particulate matter (PM) and sulfur dioxide (SO 2 ) emissions are very low. Second, emissions of PM and acid gases are subject to the Portland Cement MACT rule (40 CFR Part 63 Subpart LLL) which was finalized on February 12, 2013 with a September 15, 2015 compliance date. As the name indicates, this rule requires the use of maximum achievable control technology to control emissions of PM and acid gases. Because compliance with MACT requirements is generally considered sufficient for BART 2 , it is sufficient for RP as well. The RP analysis presented in this report follows the procedures used by US EPA in its Regional Haze Federal Implementation Plan for Montana (Federal Register, Volume 77, No. 96, Page 23988, April 20, 2012). US EPA’s RP analysis includes four specific steps as listed below:

x Step 1: Identify all available technologies

x Step 2: Eliminate technically infeasible options

x Step 3: Evaluate control effectiveness of the feasible control technologies

x Step 4: Evaluate impacts and document results

The factors considered by US EPA in the Montana analysis for the Step 4 RP analysis were:

x Factor 1: Costs of compliance

x Factor 2: Time necessary for compliance

x Factor 3: Energy and non-air quality environmental impacts of compliance

x Factor 4: Remaining useful life

x Factor 5: Modeled visibility impacts

Before any RP controls are proposed, “the projected visibility benefit of the controls should be taken into account when determining if the controls are needed to make reasonable progress.” See EPA’s proposed action on Arizona’s SIP (Federal Register, Volume 77, No. 246, Page 75704, December 21, 2012). Accordingly, CalPortland has elected to provide such an analysis, using the EPA-approved CALPUFF model.

2 The US Environmental Protection Agency’s (EPA) July 6, 2005 Best Available Retrofit Technology (BART) Guideline (Federal Register Volume 70, No. 128) states: “Unless there are new technologies subsequent to the MACT standards which would lead to cost effective increases in the level of control, you may rely on the MACT standards for purposes of BART.”AECOM Environment

Reasonable Progress Analysis – CalPortland’s Rillito Kilns May 2013 1-2

This report documents the RP analysis conducted for NOx emissions from the Rillito cement kilns. Section 2 provides a description of the kilns and their baseline emissions. Section 3 provides Steps 1- 3. Section 4 provides a discussion of four of the RP analysis factors, focusing upon conclusions based upon the engineering analysis (not including the visibility benefit analysis, which is described in later sections). Section 5 provides an explanation of the CALPUFF visibility modeling. Section 6 provides the results of the CALPUFF visibility modeling. Further Reasonable Progress conclusions based upon the visibility improvement analysis are presented in Section 7.AECOM Environment

Reasonable Progress Analysis – CalPortland’s Rillito Kilns May 2013 2-1



## 2.0 Facility Description and Baseline Emissions

2.1 Facility Description
The CalPortland facility, shown in Figure 2-1 has three long dry kilns and one preheater/precalciner kiln. The years that the kilns came on-line and the rated production capacities are shown in Table 2-1. The three long dry kilns, Kilns 1-3, are very small, non-BART kilns that are more than 50 years old and have not been operated since January 2008. Kiln 4 is BART-exempt due to its lack of visibility impacts. All four kilns have baghouses for control of particulate emissions.

Figure 2-1: CalPortland Company – Rillito Plant

Table 2-1: CalPortland Cement Plant Kiln Descriptions



### Year on Line Primary Fuel Type Capacity, ton/day 1949 Coal Long DRY 415 1951 Coal Long DRY 4 15 1955 Coal Long DRY 4 15 2002 Coal Precalciner 3233AECOM Environment

Reasonable Progress Analysis – CalPortland’s Rillito Kilns May 2013 2-2



### 2.2 Kiln NOx Emissions
Kilns 1, 2, and 3 do rely on good combustion practices to control NOx emissions. NOx emissions from Kiln 4 are controlled by low NOx burners with indirect firing and preheater riser duct firing. Table 2-2 summarizes NOx emissions data for Kilns 1, 2, and 3, while Table 2-3 summarizes NOx emissions for Kiln 4. The recent relatively high pounds per ton (lb/ton) of clinker emission rates for Kiln 4 are attributable to operation at low clinker production rates.

Table 2-2: Kilns 1, 2, and 3 NOx Emissions*

*Note that 2003 data is for a partial year of operation

Table 2-3: Kiln 4 NOx Emissions

Clinker Produced Clinker /day

Average Clinker

Produced Clinker /day

Average Clinker

Produced Clinker /day Clinker Produced Clinker /day

Average NOx

Produced NOx /

Clinker Tons Tons Tons Tons Tons Tons Tons Tons Tons lb/Ton
2003 63,949 328 64,790 339 70,705 361 199,443 987 956 9.65 2004 105,410 313 117,571 334 133,483 378 356,464 977 1,836 10.36 2005 102,311 308 121,411 355 119,278 360 342,999 945 1,939 11.35 2006 116,483 322 118,053 345 133,779 367 368,314 1,009 1,933 10.58 2007 127,867 374 116,576 354 113,428 349 357,871 994 1,758 10.04

2008 6,836 263 17,210 366 6,475 341 30,521 649 148 9.54

2009 - - - - - - - - - - 2010 - - - - - - - - - - 2011 - - - - - - - - - -

2012 - - - - - - - - - - Year Kiln 1 Kiln 2 Kiln 3 Kilns 1, 2, 3



### Clinker Produced Clinker /day

Average NOx

Produced NOx /

Clinker Tons Tons Tons lb/Ton 2003 585,813 2,914 1,311 4.51 Last 1/2 of the year
2004 1,062,124 3,009 2,128 3.99 2005 991,769 2,875 1,714 3.47 2006 1,025,652 3,034 1,862 3.65 2007 1,033,261 3,021 1,748 3.57

2008 1,031,530 3,043 1,932 3.76 Kilns 1, 2, 3 shutdown after first 2 months 2009 466,445 2,549 1,085 4.73 2010 681,963 2,024 1,947 5.75 2011 606,935 2,003 1,630 5.44

2012 652,774 2,382 1,586 5.86 First 10 months of the
year Kiln 4

Comments YearAECOM Environment

Reasonable Progress Analysis – CalPortland’s Rillito Kilns May 2013 3-1



## 3.0 Reasonable Progress Analysis (Steps 1-3)

3.1 Identification of Technologies (Step 1) and Technical Feasibility (Step 2)
The following options have been identified as possible retrofit NOx emission control technologies for cement kilns:

x Low NOx burner with an indirect firing system;

x Mid kiln firing;

x Mixing air technologies;

x Preheater riser duct firing;

x Low NOx calciner;

x Selective non-catalytic reduction; and

x Selective catalytic reduction.



### 3.1.1 Low NOx Burners with Indirect Firing Systems
Low NOx burner designs reduce NOx emissions by reducing the peak burner flame temperaturethough the use of staged combustion. Typically, these burners introduce primary air at substoichiometric or near-stoichiometric ratios at the primary burner inlet, creating an oxygen starved flame resulting in a longer, less intense flame and a lower peak flame temperature. Secondary air inlets are used to complete the combustion process. In order to be reasonably effective, an indirect firing system is required. This technology is technically feasible for Kilns 1, 2, and 3 which are long dry kilns. Kiln 4 already uses low NOx burner technology with indirect firing.



### 3.1.2 Mid-Kiln Firing
Mid-kiln firing reduces NOx emissions by allowing less intense firing at the primary burner. Typically, whole tires, which burn at a relatively slow rate, are introduced at a mid-kiln location. This technology is technically feasible for Kilns 1, 2, and 3, which are long dry kilns. This specific technology cannot be applied to Kiln 4, because Kiln 4, like all preheater/precalciner kilns, uses a form of mid-kiln firing by adding supplemental fuel to the calciner (see riser duct firing).



### 3.1.3 Mixing Air Technologies
In long dry kilns, higher temperature oxygen-rich gases tend to travel along the top of the kiln while cooler, carbon dioxide-rich gases tend to travel along the bottom. When Mixing Air Technology is added, stratified kiln gases begin to rotate and mix. This technology is technically feasible for Kilns 1, 2, and 3 which are long dry kilns. In preheater/precalciner kilns the stratified air can occur in the calciner after the riser duct firing. This results in areas of incomplete combustion. Mixing Air Technology is typically applied to the calciner with the goal to improve combustion air mixing and therefore reducing emissions. CPC has tried this technology on the Kiln 4 calciner using compressed air and nozzles as is typically done. However, the technology was found ineffective at reducing emissions from Kiln 4.AECOM Environment

Reasonable Progress Analysis – CalPortland’s Rillito Kilns May 2013 3-2



### 3.1.4 Preheater Riser Duct Firing
Preheater riser duct firing is applicable to preheater/pre-calciner kilns. NOx formation occurs in the rotary kiln under oxidizing conditions. Fuel is then added to the kiln exhaust gas, in the kiln inlet, or in the kiln riser duct so that a reducing zone (a zone where less air is available than would be required for complete combustion) is created. This promotes the reduction of NOx to molecular oxygen. Finally, air is added in the upper part of the calciner, which completes fuel combustion. This technology is not technically feasible for Kilns 1, 2, and 3, which are long dry kilns. This technology is already applied to Kiln 4, which is a pre-calciner.



### 3.1.5 Low NOx Calciner
In a low NOx calciner, the fuel is injected into the kiln riser below where the tertiary air enters at the base of the calciner. This so-called reduction zone, sized for a particular gas retention time, has an oxygen deficient atmosphere that promotes NOx reduction. The optimum temperature in the zone is controlled by a material split from the second lowest stage between the calciner and the kiln riser. Above the reduction zone is the main calciner vessel, which is divided into two or more sections separated by a notch. The changes in cross-sectional areas create turbulence that ensures effective mixing of fuel, raw meal and gas, improving heat transfer and combustion. This technology is not technically feasible for Kilns 1, 2, and 3, which are long dry kilns. The application of this technology to Kiln 4 would require a complete rebuild of the calciner due in part to the height requirement of this technology and local seismic requirements that would be equivalent to redesigning the source. US EPA’s July 6, 2005 BART Guidelines (Federal Register, July 6, 2005, Volume 70, No. 128, Page 39164) states that EPA does not consider BART as a requirement to re-design the source when considering available control alternatives. Therefore, this technology is not an available technology for Kiln 4.



### 3.1.6 Selective Non-Catalytic Reduction
Selective non-catalytic reduction (SNCR) is an add-on control technology that involves injection of aqueous or anhydrous ammonia (NH 3 ), or urea, into a hot flue gas stream. The optimum temperature range for this reaction is 1,600oF to 1,900oF. Above 1,900oF, the amount of NH 3 that oxidizes to NOx increases, and, in turn, the NOx reduction performance deteriorates. At temperatures at or below 1,600oF, unreacted NH 3 emissions may rapidly increase. The following factors influence the control effectiveness of SNCR:

x Temperature and oxygen availability (i.e., the NH 3 injection location);

x The baseline, or uncontrolled NOx concentration;

x Mixing;

x Reagent Ratio (i.e., the NH 3 to NOx molar ratio at the injection point);

x NH 3 accumulation;

x Excess ammonia emissions; and

x Ammonium salt formation.

For SNCR to work effectively, the gas stream being treated must have a relatively high concentration of NOx as opposed to other potential reactants with which NOx would compete to react with NH 3 . The presence of competing reactants in the gas stream may result in less NH 3to convert NOx to its nonpolluting forms. This would reduce the effectiveness of the SNCR process. SNCR requires an oxidizing, or fuel-lean, atmosphere to effectively reduce NOx emissions. In a fuel-rich, or reducing environment, partially oxidized fuel (e.g., CO) competes with NH 3 for OH* radicals, thus reducing NOx control effectiveness. SNCR is technically feasible for Kilns 1, 2, 3, and 4.AECOM Environment

Reasonable Progress Analysis – CalPortland’s Rillito Kilns May 2013 3-3



### 3.1.7 Selective Catalytic Reduction
Like SNCR, Selective Catalytic Reduction (SCR) systems use NH 3 to chemically convert NOx to molecular nitrogen (N 2 ). SCR uses a catalyst to promote the selective reaction of NOx and ammonia. Ammonia injected into the gas stream reacts with NOx, and the SCR catalyst enables these reactions to occur at lower temperatures than are possible with SNCR and at nearly 100% ammonia utilization. While catalysts can operate over a range of temperatures, the optimal temperature range for SCR applications is between 570o to 750oF, well below the 1,600oF to 1,900oF temperature range for SNCR reactions discussed previously. SCR has been widely applied to gas turbines and boilers, but not to cement plants. The only known application of SCR to cement kilns is in Europe. Experience has shown SCR operating problems primarily due to dust poisoning of the catalysts and did not demonstrate that SCR was more effective than SNCR. 3 Therefore, SCR is not considered to be technically feasible for Kilns 1, 2, 3, or 4.



### 3.1.8 Conclusion
Table 3-1 summarizes the available control technologies and their potential application for CalPortland’s cement kilns:

Table 3-1: NOx Control Technologies and Potential Application for Rillito Cement Kilns Control Technology Kilns 1 through 3 Kiln 4

Low NOx burner with an indirect firing system Technically Feasible In Use

Mid-kiln firing Technically Feasible Infeasible

Mixing air technologies Technically Feasible Ineffective

Preheater riser duct firing Not Applicable In Use

Low NOx calciner Not Applicable Infeasible

Selective non-catalytic reduction Technically Feasible Technically Feasible

Selective catalytic reduction Infeasible Infeasible



### 3.2 Emission Control Effectiveness (Step 3)
3.2.1 Kilns 1, 2, and 3
Performance estimates for emission control options were based on CPC experience at implementing these controls on the two long dry kilns at its Colton plant and site-specific details for Kilns 1, 2, and 3. The estimated NOx control efficiencies are:

x 20 percent for low NOx burner with indirect firing for Kilns 1, 2, and 3;

3 Schreiber, R. J., The Experience of SCR at Solnhofen and its Applicability to US Cement Plants, June 6, 2006.AECOM Environment

Reasonable Progress Analysis – CalPortland’s Rillito Kilns May 2013 3-4

x 20 percent for mid-kiln firing with mixing air technologies for Kilns 1, 2, and 3;

x 25 percent for SNCR with mixing air technologies for Kilns 1, 2, and 3;



### 3.2.2 Kiln 4
CalPortland estimates 30 percent NOx emission control based on its experience implementing SNCR for its similar preheater/precalciner kiln in Mohave, California.AECOM Environment

Reasonable Progress Analysis – CalPortland’s Rillito Kilns May 2013 4-1



## 4.0 Four Factor Impact Analysis (Step 4)

This section discusses the four factors (other than the visibility impact analysis) considered in the Reasonable Progress impact (Step 4) analysis. 

### 4.1 Factor One: Costs of Compliance

4.1.1 Kilns 1-3
Capital costs were based on CPC’s experience at its other facilities, adjusted for Kiln 1, 2, and 3 capacities and complexity, and factors from US EPA’s Air Pollution Control Cost Manual, Sixth Edition EPA/452/B-02-001, and January 2002. Total capital costs were estimated to be:

x $2.4 million for low NOx burner with indirect firing for each kiln,

x $1.4 million for mid-kiln firing with mixing air technologies for each kiln, and

x $1.1 million for SNCR with mixing air technologies for each kiln.

Direct operating costs and annual maintenance costs were based on CPC’s experience at its other facilities, adjusted for site specific factors. Electricity requirements were based on power for increased exhaust flow from the kilns as well as SNCR heating and pumping requirements. Electricity cost at Rillito is approximately $100/MWh. The reagent for SNCR was assumed to be 19 percent aqueous ammonia for safety reasons and because ammonia has been shown to be the most effective reagent. The delivered cost to Rillito of 19 percent aqueous ammonia was based on current pricing in the Los Angeles area, taxes, and freight charges.

Indirect operating costs were based on the EPA Air Pollution Control Cost Manual.

Total annualized costs were conservatively based on a 7 percent interest rate and 20 years as cited in the EPA Air Pollution Control Cost. For Kilns 1, 2, and 3, no limitation on the remaining useful life was assumed.

The estimated cost effectiveness results are:

x $7,137 per ton of NOx controlled for low NOx burner with indirect firing for each kiln;

x $7,988 per ton of NOx controlled for mid-kiln firing with mixing air technologies for each kiln;

x $7,946 per ton of NOx controlled for SNCR with mixing air technologies for each kiln.

Detailed cost analyses are presented in Tables 4-1a, 4-1b, 4-2a, 4-2b, 4-3a, and 4-3b.



### 4.1.2 Kiln 4
The methodologies that were used for Kilns 1, 2, and 3 were also applied to Kiln 4. Specifically, CalPortland relied on its experience at its Mohave Facility, adjusted to reflect site-specific factors associated with Kiln 4. For the application of SNCR to Kiln 4, the results are:AECOM Environment

Reasonable Progress Analysis – CalPortland’s Rillito Kilns May 2013 4-2

x 30 percent NOx emission control;

x $1.34 million capital cost;

x $2,464 per ton of NOx controlled.

A detailed cost analysis is presented in Tables 4-4a and 4-4b.AECOM Environment

Reasonable Progress Analysis – CalPortland’s Rillito Kilns May 2013 4-3
Table 4-1: Low NOx Burner with Indirect Firing System Kiln 1, 2, or 3

Table 4-1a: Capital Cost Basis

DIRECT COSTS:

PURCHASED EQUIPMENT

(a) Basic Equipment (BE) $1,533,333 Includes indirect firing modifications and burner upgrade. Based on CalPortland Company’s Colton system escalated to 2013$ and adjusted for coal system capacity and complexity. (b) Instrumentation & Controls $153,333 10% of BE, EPA Cost Control Manual
€ Sales Tax $46,000 3% of BE, EPA Cost Control Manual (d) Freight $76,667 5% of BE, EPA Cost Control Manual TOTAL PURCHASED EQUIPMENT (PE): $1,809,300
DIRECT INSTALLATION (a) Foundations and Support $144,744 8% of PE, EPA Cost Control Manual (b) Handling and Erection $253,302 14% of PE, EPA Cost Control Manual
€ Electrical $72,372 4% of PE, EPA Cost Control Manual (d) Piping $36,186 2% of PE, EPA Cost Control Manual € Insulation for Piping $18,093 1% of PE, EPA Cost Control Manual (f) Painting $18,093 1% of PE, EPA Cost Control Manual TOTAL DIRECT INSTALLATION (DI): $542,790 Site Preparation $0 none required Buildings $0 none required TOTAL DIRECT COST (TDC): $2,352,100 PE + DI + site preparation + buildings
INDIRECT COSTS:

INDIRECT INSTALLATION (a) Engineering and Project Management $235,210 10% of TDC, EPA Cost Control Manual (b) Construction & Field Expenses $117,605 5% of TDC, EPA Cost Control Manual
€ Contractor Fees $235,210 10% of TDC, EPA Cost Control Manual (d) Startup & Performance Tests $47,042 2% of TDC, EPA Cost Control Manual
€ Downtime $0 (f) Contingencies $235,210 10% of TDC, CalPortland Company engineering judgment based on experience
OTHER INDIRECT COSTS
TOTAL INDIRECT COST: $870,300

TOTAL CAPITAL COST: $3,222,400AECOM Environment

Reasonable Progress Analysis – CalPortland’s Rillito Kilns May 2013 4-4

Table 4-1b: Annualized Cost and Cost Effectiveness

Low NOx Burner with Indirect Firing System Basis

TOTAL CAPITAL COST: $3,222,400 DIRECT OPERATING COSTS: Operating Labor $43,800 1.0 hr/shift at $40 per hour, CalPortland Company
Maintenance Labor $64,400 2% of total capital cost, CalPortland Company
Maintenance Materials $64,400 2% of total capital cost, CalPortland Company
Electricity $300 kW for increased coal system exhaust & primary air power, CalPortland Company Electricity Annual Cost $236,520 $100/MWh, CalPortland Company

Indirect Operating Costs
Overhead $77,280 60% of Total Maintenance and Labor, EPA Cost Control Manual Property Tax $32,200 1% of Total Capital Cost, EPA Cost Control Manual
Insurance $32,200 1% of Total Capital Cost, EPA Cost Control Manual
Administration $64,400 2% of Total Capital Cost, EPA Cost Control Manual Capital Recovery $304,200 20 yr life, 7% interest rate, EPA Cost Control Manual

TOTAL ANNUALIZED COST: $919,400 Capacity, ton/day 415 Annual Capacity Factor 90% NOx Emission Rate, lb/ton 9.45 Maximum NOx Emissions before Control, ton/yr 644 Control Efficiency, % 20% Controlled NOx Emission Rate, lb/ton 7.56 NOx Emissions after Control, ton/yr 515 NOx Emission Reduction, ton/yr 129 COST EFFECTIVENESS ($/ton): $7,137AECOM Environment

Reasonable Progress Analysis – CalPortland’s Rillito Kilns May 2013 4-5
Table 4-2: Mid-Kiln Firing for Kiln 1, 2, or 3

Table 4-2a: Capital Cost Basis

DIRECT COSTS: PURCHASED EQUIPMENT

(a) Basic Equipment (BE) $666,667 Includes tire infeed and firing system and mixing air system. Based on CalPortland Company’s Colton system escalated to 2013$ and adjusted for tire system capacity and complexity. (b) Instrumentation & Controls $66,667 10% of BE, EPA Cost Control Manual (c) Sales Tax $20,000 3% of BE, EPA Cost Control Manual (d) Freight $33,333 5% of BE, EPA Cost Control Manual TOTAL PURCHASED EQUIPMENT (PE): $786,700 DIRECT INSTALLATION (a) Foundations and Support $62,936 8% of PE, EPA Cost Control Manual (b) Handling and Erection $110,138 14% of PE, EPA Cost Control Manual (c) Electrical $31,468 4% of PE, EPA Cost Control Manual (d) Piping $15,734 2% of PE, EPA Cost Control Manual (e) Insulation for Piping $7,867 1% of PE, EPA Cost Control Manual (f) Painting $7,867 1% of PE, EPA Cost Control Manual

TOTAL DIRECT INSTALLATION (DI): $236,010 Site Preparation $0 none required Buildings $0 none required

TOTAL DIRECT COST (TDC): $1,022,700 PE + DI + site preparation + buildings INDIRECT COSTS:
INDIRECT INSTALLATION (a) Engineering and Project Management $102,270 10% of TDC, EPA Cost Control Manual (b) Construction & Field Expenses $51,135 5% of TDC, EPA Cost Control Manual (c) Contractor Fees $102,270 10% of TDC, EPA Cost Control Manual (d) Startup & Performance Tests $20,454 2% of TDC, EPA Cost Control Manual (e) Downtime $0 (f) Contingencies $102,270 10% OTHER INDIRECT COSTS TOTAL INDIRECT COST: $378,400
TOTAL CAPITAL COST: $1,401,100AECOM Environment

Reasonable Progress Analysis – CalPortland’s Rillito Kilns May 2013 4-6

Table 4-2b: Annualized Cost and Cost Effectiveness

Mid-Kiln Firing for Kiln 1, 2, or 3 Basis

TOTAL CAPITAL COST: $1,401,100 DIRECT OPERATING COSTS: Operating Labor $43,800 1.0 hr/shift at $40 per hour, CalPortland Company
Maintenance Labor $140,100 10% of total capital cost, CalPortland Company Maintenance Materials $210,200 15% of total capital cost, CalPortland Company
Electricity 300 kW for increased coal system exhaust & primary air power, CalPortland Company Electricity Annual Cost $236,520 $100/MWh, CalPortland Company

Indirect Operating Costs

Overhead $210,180 60% of Total Maintenance and Labor, EPA Cost Control Manual

Property Tax $14,000 1% of Total Capital Cost, EPA Cost Control Manual
Insurance $14,000 1% of Total Capital Cost, EPA Cost Control Manual
Administration $28,000 2% of Total Capital Cost, EPA Cost Control Manual Capital Recovery $132,300 20 yr life, 7% interest rate, EPA Cost Control Manual

TOTAL ANNUALIZED COST: $1,029,100 Capacity, ton/day 415 Annual Capacity Factor 90% NOx Emission Rate, lb/ton 9.45 Current NOx Emissions, ton/yr 644 Control Efficiency, % 20% Controlled NOx Emission Rate, lb/ton 7.56 NOx Emissions after Control, ton/yr 515 NOx Emission Reduction, ton/yr 129

COST EFFECTIVENESS ($/ton): $7,988AECOM Environment

Reasonable Progress Analysis – CalPortland’s Rillito Kilns May 2013 4-7

Table 4-3: SNCR with Mixing Air Technologies for Kiln 1, 2, or 3

Table 4-3a: Capital Cost Basis

DIRECT COSTS: PURCHASED EQUIPMENT

(a) Basic Equipment (BE) $500,000 Includes mixing air system, plenum heater ammonia evaporation system, and injection system. Based on CalPortland Company’s Colton system escalated to 2013$. (b) Instrumentation & Controls $50,000 10% of BE, EPA Cost Control Manual (c) Sales Tax $15,000 3% of BE, EPA Cost Control Manual (d) Freight $25,000 5% of BE, EPA Cost Control Manual TOTAL PURCHASED EQUIPMENT (PE): $590,000 DIRECT INSTALLATION (a) Foundations and Support $47,200 8% of PE, EPA Cost Control Manual (b) Handling and Erection $82,600 14% of PE, EPA Cost Control Manual (c) Electrical $23,600 4% of PE, EPA Cost Control Manual (d) Piping $11,800 2% of PE, EPA Cost Control Manual (e) Insulation for Piping $5,900 1% of PE, EPA Cost Control Manual (f) Painting $5,900 1% of PE, EPA Cost Control Manual

TOTAL DIRECT INSTALLATION (DI): $177,000 Site Preparation $0 none required Buildings $0 none required

TOTAL DIRECT COST (TDC): $767,000 PE + DI + site preparation + buildings INDIRECT COSTS:
INDIRECT INSTALLATION (a) Engineering and Project Management $76,700 10% of TDC, EPA Cost Control Manual (b) Construction & Field Expenses $38,350 5% of TDC, EPA Cost Control Manual (c) Contractor Fees $76,700 10% of TDC, EPA Cost Control Manual (d) Startup & Performance Tests $15,340 2% of TDC, EPA Cost Control Manual (e) Downtime $0 (f) Contingencies $76,700 10% OTHER INDIRECT COSTS TOTAL INDIRECT COST: $283,800
TOTAL CAPITAL COST: $1,050,800AECOM Environment

Reasonable Progress Analysis – CalPortland’s Rillito Kilns May 2013 4-8

Table 4-3b: Annualized Cost and Cost Effectiveness
SNCR with Mixing Air Technologies for Kilns 1, 2, or 3 Basis

TOTAL CAPITAL COST: $1,050,800 DIRECT OPERATING COSTS: Operating Labor $43,800 1.0 hr/shift at $40 per hour, CalPortland Company
Maintenance Labor $105,100 10% of total capital cost, CalPortland Company Maintenance Materials $157,600 15% of total capital cost, CalPortland Company
Ammonia 238.1 1.00 mole NH3/mole NOx emissions, CalPortland Company
Ammonia Annual Cost $390,409 $1640/ton, CalPortland Company Electricity 360 kW for increased exhaust gas volume, heaters and pumping Electricity Annual Cost $283,824 $100/MWh, CalPortland Company

Indirect Operating Costs

Overhead $157,620 60% of Total Maintenance and Labor, EPA Cost Control Manual

Property Tax $10,500 1% of Total Capital Cost, EPA Cost Control Manual
Insurance $10,500 1% of Total Capital Cost, EPA Cost Control Manual
Administration $21,000 2% of Total Capital Cost, EPA Cost Control Manual Capital Recovery $99,200 20 yr life, 7% interest rate, EPA Cost Control Manual

TOTAL ANNUALIZED COST: $1,279,600 Capacity, ton/day 415 Annual Capacity Factor 90% NOx Emission Rate, lb/ton 9.45 Current NOx Emissions, ton/yr 644 Control Efficiency, % 25% Controlled NOx Emission Rate, lb/ton 7.09 NOx Emissions after Control, ton/yr 483 NOx Emission Reduction, ton/yr 161

COST EFFECTIVENESS ($/ton): $7,946AECOM Environment

Reasonable Progress Analysis – CalPortland’s Rillito Kilns May 2013 4-9

Table 4-4: SNCR for Kiln 4

Table 4-4a: Capital Cost Basis

DIRECT COSTS: PURCHASED EQUIPMENT

(a) Basic Equipment (BE) $650,000 Based on CalPortland’s Mojave system escalated to 2013$ and adjusted for Rillito site conditions. (b) Instrumentation & Controls $65,000 10% of BE, EPA Cost Control Manual (c) Sales Tax $19,500 3% of BE, EPA Cost Control Manual (d) Freight $32,500 5% of BE, EPA Cost Control Manual TOTAL PURCHASED EQUIPMENT (PE): $767,000 DIRECT INSTALLATION (a) Foundations and Support $61,360 8% of PE, EPA Cost Control Manual (b) Handling and Erection $107,380 14% of PE, EPA Cost Control Manual (c) Electrical $30,680 4% of PE, EPA Cost Control Manual (d) Piping $15,340 2% of PE, EPA Cost Control Manual (e) Insulation for Piping $7,670 1% of PE, EPA Cost Control Manual (f) Painting $7,670 1% of PE, EPA Cost Control Manual

TOTAL DIRECT INSTALLATION (DI): $230,100 Site Preparation $0 none required Buildings $0 none required

TOTAL DIRECT COST (TDC): $997,100 PE + DI + site preparation + buildings INDIRECT COSTS:
INDIRECT INSTALLATION (a) Engineering and Project Management $99,710 10% of TDC, EPA Cost Control Manual (b) Construction & Field Expenses $49,855 5% of TDC, EPA Cost Control Manual (c) Contractor Fees $99,710 10% of TDC, EPA Cost Control Manual (d) Startup & Performance Tests $19,942 2% of TDC, EPA Cost Control Manual (e) Downtime $0 (f) Contingencies $99,710 10% OTHER INDIRECT COSTS TOTAL INDIRECT COST: $368,900
TOTAL CAPITAL COST: $1,366,000AECOM Environment

Reasonable Progress Analysis – CalPortland’s Rillito Kilns May 2013 4-10

Table 4-4b: Annualized Cost and Cost Effectiveness

SNCR for Kiln 4 Basis

TOTAL CAPITAL COST: $1,366,000 DIRECT OPERATING COSTS: Operating Labor $43,800
Maintenance Labor $27,300 2% of total capital cost, CalPortland Company Maintenance Materials $27,300 2%, CalPortland Company Ammonia 786.9 1.00 mole NH3/mole NOx emissions, CalPortland Company Ammonia Annual Cost $1,290,596 $1640/ton, CalPortland Company
Electricity 15.00 kW for increased exhaust gas volume, heaters and pumping, CalPortland Company Electricity Annual Cost $11,826 $100/MWh, CalPortland Company

Indirect Operating Costs
Overhead $32,760 60% of Total Maintenance and Labor Property Tax $13,700 1% of Total Capital Cost Insurance $13,700 1% of Total Capital Cost Administration $27,300 2% of Total Capital Cost Capital Recovery $128,900 20 yr life, 7% interest rate

TOTAL ANNUALIZED COST: $1,574,200 Capacity, ton/day 3,233 Annual Capacity Factor 90% NOx Emission Rate, lb/ton 4.01 Current NOx Emissions, ton/yr 2,129 Control Efficiency, % 30% Controlled NOx Emission Rate, lb/ton 2.81 NOx Emissions after Control, ton/yr 1,491 NOx Emission Reduction, ton/yr 639

COST EFFECTIVENESS ($/ton): $2,464AECOM Environment

Reasonable Progress Analysis – CalPortland’s Rillito Kilns May 2013 4-11



### 4.2 Cost of Compliance Summary (Factor 1)
Detailed information on the cost of compliance was presented in Section 4.1. Compliance costs are summarized in Table 4-5.

Table 4-5: Cost of Compliance



### 4.3 Time Necessary for Compliance (Factor 2)
Several years would be required to design, permit and then construct any control equipment

The time needed to install emission controls is approximately 3 years.


### 4.4 Energy and Non-Air Quality Environmental Impacts (Factor 3)
Increased energy use for Kilns 1, 2, and 3 would be approximately 2,838 MWh per year per kiln at a 90 percent capacity factor. Increased energy use for Kiln 4 would be approximately 118 MWh per year at a 90 percent capacity factor. The use of SNCR at the specified emission control efficiencies would result in a modest increase of ammonia emissions. However, it should be noted that higher SNCR control efficiencies may result in higher ammonia emissions and significant adverse environmental air quality impacts. These increased ammonia emissions were not accounted for in the visibility improvement modeling discussion in Sections 5 and 6, so the modeling results overstate the visibility benefits of SNCR controls. Ammonia transport to the site will create the potential for accidents and spills and will cause increased air emissions. Storage of ammonia creates potential risks for spills.


### 4.5 Remaining Useful Life (Factor 4)
The remaining useful life of the kilns is unknown and unknowable at this time. CalPortland has an application pending to modernize its facility and permanently shutdown these kilns. Whether CalPortland moves forward with this modernization once the application is processed will depend on the state of the economy at that time. For the purposes of this analysis, we conservatively assumed a 20 year useful life Capital Cost Annual Cost Cost

Effectiveness

% ton/yr $ $/yr $ per ton NOx Controlled Low NOx burner with indirect firing for Kilns 1, 2, and 3 (total for 3 kilns) 20% 386.5 $9,667,200 $2,758,200 $7,137

Mid-kiln firing with mixing air technologies for Kilns 1, 2, and 3 (total for 3 kilns) 20% 386.5 $4,203,300 $3,087,300 $7,988

SNCR with mixing air technologies for Kilns 1, 2, and 3 (total for 3 kilns) 25% 483.1 $3,152,400 $3,838,800 $7,946

SNCR for Kiln 4. 30% 638.8 $1,366,000 $1,574,200 $2,464 Emission Control Option NOx Emission ReductionAECOM Environment

Reasonable Progress Analysis – CalPortland’s Rillito Kilns May 2013 4-12



### 4.6 Preliminary Conclusions for Step 4
Given the nearby Class I area is on track to demonstrate a uniform rate of progress without any additional controls on the kilns, the relatively low NOx emissions (especially from Kilns 1 through 3, which have been inactive for several years), the high costs of compliance associated with the technically feasible control measures, and the uncertain future of the existing kilns, it is reasonable to not require additional NOx controls for this planning period for the Rillito kilns. Further consideration of impacts due to the expected visibility improvement from these controls, if they were to be implemented, is provided in the following sections.AECOM Environment

Reasonable Progress Analysis – CalPortland’s Rillito Kilns May 2013 5-1



## 5.0 CALPUFF Modeling Procedures

The CALPUFF visibility modeling analysis portion of RP Step 4 followed the Western Regional Air Partnership (WRAP) common BART modeling protocol with the exception of the model version and a few refinements to CALMET settings. These differences are discussed in the sections below and in Appendix A.


### 5.1 CALMET Processing
The WRAP has developed six 4-km CALMET meteorological databases for three years (2001-2003). The CALMET modeling domains are strategically designed to cover all potential BART eligible sources within WRAP states and all PSD Class I areas within 300 km of those sources. The boundaries of the six domains are shown in Figure 3-a through Figure 3-1f of the WRAP common BART modeling protocol, available at http://pah.cert.ucr.edu/aqm/308/bart/WRAP_RMC_BART_Protocol_Aug15_2006.pdf . The RP CALPUFF modeling for the Rillito kilns was done using the Arizona 4-km domain, as shown in Figure 5-1. The WRAP CALMET meteorological inputs, technical options, and processing steps are described in Sections 2 and 3 of the WRAP protocol.

USGS 3 arc-second Digital Elevation Model (DEM) files were used by WRAP to generate the terrain data at 4-km resolution for input to the six CALMET runs. Likewise, the Composite Theme Grid format (CTG) files using Level I USGS land use categories were used by WRAP to generate the land use data at 4-km resolution for input to the six CALMET runs. See Sections 3.1.1.3 and 3.1.1.4 of the WRAP common BART modeling protocol for more details on the data processing.

Three years of 36-km MM5 data (2001-2003) were used by WRAP to generate the 4-km subregional meteorological data sets. Section 2 of the WRAP protocol discusses MM5 data extraction. Application-specific modifications approved by EPA for the CALPUFF modeling are described in Appendix A.AECOM Environment

Reasonable Progress Analysis – CalPortland’s Rillito Kilns May 2013 5-2

Figure 5-1: Rillito Kiln Modeling DomainAECOM Environment

Reasonable Progress Analysis – CalPortland’s Rillito Kilns May 2013 5-3



### 5.2 CALPUFF Model Formulation for Predicting Visibility Impairment
In July 2005, EPA issued BART Guidelines that provide guidance to the States in making BART determinations for large power plants and other BART-eligible sources 4 . The BART Guideline states that modeling may be necessary to support a decision by the States about which BART-eligible sources “cause or contribute” to visibility impairment and are subject to BART.

EPA guidance recommends CALPUFF for modeling single source visibility impacts at Class I areas. The model developer website describes CALPUFF as “...an advanced non-steady-state meteorological and air quality modeling system... It is maintained by the model developers and distributed by TRC. The model has been adopted by the U.S. Environmental Protection Agency (U.S. EPA) in its Guideline on Air Quality Models as the preferred model for assessing long range transport of pollutants and their impacts on Federal Class I areas and on a case-by-case basis for certain near-field applications involving complex meteorological conditions. The modeling system consists of three main components and a set of pre-processing and post-processing programs. The main components of the modeling system are CALMET (a diagnostic 3-dimensional meteorological model), CALPUFF (an air quality dispersion model), and CALPOST (a post-processing package)”.

CALPUFF offers three options for dealing with chemical transformations:

x A pseudo-first-order chemical reaction mechanism for the conversion of SO 2 to sulfate (SO 4 ) and NOx to nitrate (NO 3 ). This mechanism is based on the chemical transformation scheme used in the MESOPUFF-II 5 model and incorporates the most significant dependencies of spatially and temporally varying environmental conditions of the transformation rates.

x The RIVAD/ARM3 scheme 6 , which treats nitric oxide (NO) and nitrogen dioxide (NO 2 ) conversion processes in addition to the NO 2 to NO 3 and SO 2 to SO 4 conversions, with equilibrium between gaseous nitric acid (HNO 3 ) and ammonium nitrate aerosol.

x User-specified 24-hour cycles of transformation rates. The Interagency Workgroup on Air Quality Modeling (IWAQM) recommends using the MESOPUFF-II system with CALPUFF. The MESOPUFF-II chemistry option is also the model default recommended by EPA.


### 5.3 Ammonia Background Concentrations

In the CALPUFF model, the oxidation of NOx to HNO 3 depends on the NOx concentration, ambient ozone concentration, and atmospheric stability. Some of the nitric acid is then combined with available ammonia in the atmosphere to form ammonium nitrate. The ambient ammonia concentration is a critical input to the CALPUFF model for nitrate formation, especially with the use of the MESOPUFF II chemistry. It is important to note that that only particulate nitrate will impact visibility; nitric acid would not.

4 US EPA, 2005. BART guidelines, Federal Register update: June 24, 2005.

5 Scire et. al.,1984. User’s Guide to the MESOPUFF II Model and Related Processor Programs, 1984. EPA-600 S8-84-013. May 1984.

6 Morris et. al.,1988. Rocky Mountain Acid Deposition Model Assessment: Acid Rain Mountain Mesoscale Model (ARM3), EPA 1988.AECOM Environment

Reasonable Progress Analysis – CalPortland’s Rillito Kilns May 2013 5-4

Morris et al. 7 reported that the EPA-approved version of CALPUFF with the MESOPUFF II chemistry (Version 5.8) was developed from field data limited to ambient temperatures no lower than 50°F. Therefore, the use of CALPUFF for much lower temperatures for the critical winter season represents an extension of the model to untested conditions. Morris et al. found that the limitations of the ambient temperatures in the field data used in development of the model could result in overestimating sulfate and nitrate formation in colder conditions. These investigators found that CALPUFF (version 5.8) tended to over-predict nitrate concentrations during winter by a factor of about 3 with high ammonia background concentrations.

Recently, the IMPROVE monitoring network began to incorporate routine measurements of gaseous ammonia at specific sites. A recently issued technical paper 8 on this subject showed monthly ammonia measurements at these sites, including one in southern Arizona (Chiricahua) that was modeled for this study. A review of the measurements taken to date at these sites (see Figure 5-2) indicates that ammonia concentrations less than 1 part-per-billion (ppb) (e.g., 0.5 ppb) are present at this site in winter. Note that EPA used a constant value ammonia background level of 1 ppb for all 12 months, but without the benefit of the recent IMPROVE measurements.

In an independent analysis, the Colorado Department of Public Health and Environment (CDPHE) performed a sensitivity modeling analysis to explore the effect of the ammonia concentration input to CALPUFF on the predicted visibility impacts for a source with high NO X emissions relative to SO 2 emissions. 9 It is noteworthy that the largest sensitivity occurs for ammonia input values between 1 and 0.1 ppb. In that range, the difference in the peak visibility impacts predicted by CALPUFF is slightly more than a factor of 3 between ammonia concentration input values of 1 and 0.1 ppb. This sensitivity analysis shows that the choice of background ammonia is very important in terms of the magnitude of visibility impacts predicted by CALPUFF, and that the assumption of 1 ppb for winter likely introduces another level of over-predictive conservatism in the modeling results for NOx effects upon haze.

The visibility composition plots depicted in Figure 5-3 from two IMPROVE monitors located in Saguaro East National Monument show that the majority of nitrate (shown by the red portions of the composition columns) forms during cold temperature (in the modeled predictions and in the real world) and, therefore, the model is not sensitive to the selected ammonia values in summer, but would be highly sensitive to values in winter months.

Based upon this newly available ammonia measurement information (which conservatively includes both gaseous and particulate form concentration contributions), AECOM has developed a set of monthly-varying ammonia background concentrations (see Table 5-1) that correspond to the actual measured values noted above. Consistent with the EPA values, an ammonia background of 1 ppb is used for many of the non-winter months.

7 Morris, R., Steven Lau and Bonyoung Koo, 2005. Evaluation of the CALPUFF Chemistry Algorithms. Presented at A&WMA 98 th Annual Conference and Exhibition, June 21-25, 2005 Minneapolis, Minnesota.

8 Chen, X., D. Day, B. Schichtel, W. Malm, J. Mojica, C. McDade, E. Hardison, S. Kreidenweis, and J. Collett, 2012. A Pilot Monitoring Study of Atmospheric NHx at Selected IMPROVE Sites. Extended Abstract # 19. Presented at the 2012 Aerosol and Atmospheric Optics: Visibility & Air Pollution Specialty Conference, held September 25-28 th , 2012 in Whitefish, MT. Air & Waste Management Association, Pittsburgh, PA.
9 Supplemental BART Analysis: CALPUFF Protocol for Class I Federal Area Visibility Improvement Modeling Analysis(DRAFT), revised June 25, 2010, available at http://www.colorado.gov/airquality/documents/DraftColoradoSupplementalBARTAnalysisCALPUFFProtocol-25June2010.pdf.AECOM Environment

Reasonable Progress Analysis – CalPortland’s Rillito Kilns May 2013 5-5

Figure 5-2: IMPROVE NHx Concentrations from April 2011 to January 2012

Figure 5-3: 2009 IMPROVE Composition Data for Saguaro East National Park

Table 5-1: Background Monthly Ammonia Concentrations Used in the Modeling (ppb)

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

0.5 0.5 0.6 0.7 1.0 1.0 1.0 1.0 1.0 1.0 1.0 0.8AECOM Environment

Reasonable Progress Analysis – CalPortland’s Rillito Kilns May 2013 5-6



### 5.4 CALPUFF Modeling Procedures
AECOM used the EPA-approved version of CALPUFF (Version 5.8, Level 070623) that has been posted at http://www.src.com/calpuff/download/download.htm#EPA_VERSION . Although the WRAP BART protocol mentions the use of CALPUFF version 6, EPA’s Office of Air Quality Planning and Standards indicates that this use is a non-guideline application requiring EPA approval on a case-by-case basis. It is clear from the discussion provided in Appendix A that CALPUFF version 6 is not approvable by EPA at this time without a significant effort to show that it is technically superior. To avoid the need for the justification and documentation required to use a non-guideline version of the model, AECOM used the official EPA version 5.8.

The area considered in the modeling is shown in Figure 5-3. The Reasonable Progress CALPUFF modeling for the Rillito kilns was conducted using a computational grid that included the entire domain. This domain includes 12 Class I areas within 300 km of the source, plus a 50-km buffer around each Class I area and a 100-km buffer around the source to assure puffs recirculation. The receptors used for each of the Class I areas are based on the National Park Service database of Class I receptors. The Class I areas included in the modeling are:

1. Chiricahua National Monument

2. Chiricahua Wilderness

3. Galiuro Wilderness

4. Gila Wilderness

5. Mazatzal Wilderness 6. Mount Baldy Wilderness

7. Petrified Forest National Park

8. Pine Mountain Wilderness 9. Saguaro National Park (Eastern Portion)

10. Sierra Ancha Wilderness 11. Superstition Wilderness 12. Sycamore Canyon Wilderness The Saguaro West area was not modeled by EPA or AECOM because it is too close to the source to have regional haze effects. This list of Class I areas modeled is consistent with the modeling conducted by the EPA for its Task 9 report.

For CALPUFF model technical options, inputs, and processing steps, AECOM followed the WRAP common BART protocol, except for the model version, as discussed above. Due to the long distance to the nearest Class I area, building downwash effects were not included in the CALPUFF modeling.

WRAP has developed hourly ozone measurement files for three years (2001-2003), available at http://pah.cert.ucr.edu/aqm/308/bart/calpuff/ozone_dat/ . Data collection and processing are described in Section 3.1.2.7 of the WRAP protocol. The ozone data was used as input to CALPUFF.

The stack parameters modeled were taken from EPA’s Task 9 report, Table 30. Kilns 1-3 were modeled together and Kiln 4 was modeled separately. The stack parameters are listed in Table 5-2. Section 5.5 discusses the emissions modeled for the base case and the three control scenarios.AECOM Environment

Reasonable Progress Analysis – CalPortland’s Rillito Kilns May 2013 5-7

Figure 5-4: Class I Areas Within 300 km of the Rillito FacilityAECOM Environment

Reasonable Progress Analysis – CalPortland’s Rillito Kilns May 2013 5-8

Table 5-2: Modeled Stack Parameters for Kilns 1-3 and Kiln 4

Units Kilns 1-3 Kiln 4

Latitude Deg 32.4077 32.4076 Longitude Deg -111.1497 -111.1498 Stack Height Ft 75.00 75.00

Base Elevation Ft 2060.00 2060.00

Diameter Ft 10.00 16.00 Gas Exit Velocity ft/s 52.70 47.83 Stack Gas Exit Temperature Deg F 425.00 400.00

Lambert Conformal X (1) Km -1324.2247 -1324.2374
Lambert Conformal Y (1) Km -737.8118 -737.8177 Stack Height M 22.86 39.62

Base Elevation M 627.89 627.89

Diameter M 3.05 4.88 Gas Exit Velocity m/s 16.06 14.58 Stack Gas Exit Temperature Deg K 491.48 477.59

Lambert Conformal coordinate system is based on 40 deg N/97 degW projection origin, 33 deg N/45 deg N standard parallels and NWS84 datum.



### 5.5 Modeled Control Scenarios
The emissions rates for Kilns 1-3 for the baseline case and the three control cases are presented in Table 5-3. The emissions rates for Kiln 4 for the baseline case and the three control cases are presented in Table 5-4. The SO 2 emission rates were taken from EPA’s Task 9 report. The speciated PM emission rates were also taken from Task 9 report, but corrected (reduced by a factor of 3) for each stack due to an error in the Task 9 report’s calculations of the PM emissions. NOx emission rates were calculated by AECOM based on the NOx control options discussed in Section 3. A description of the cases modeled is as follows:

x Base Case: No control options are implemented for any of the kilns.

x Control Case 1: LNB and indirect firing or mid-kiln firing is implemented on Kilns 1-3. No controls are implemented for Kiln 4.

x Control Case 2: SNCR is implemented on Kilns 1-3. No control options are implemented for Kiln 4.AECOM Environment

Reasonable Progress Analysis – CalPortland’s Rillito Kilns May 2013 5-9

x Control Case 3: SNCR is implemented on Kiln 4. No control options are implemented for Kilns 1-3.

It is noteworthy to consider that excess ammonia emissions due to SNCR operation were not considered in the modeling. Such emissions can combine with gaseous SO 2 or NOx emissions that are not visibility impairing and result in formation of secondary particulate (ammonium sulfate or ammonium nitrate). Therefore, the stated visibility benefits for all SNCR controls are overestimates of their actual benefits.AECOM Environment

Reasonable Progress Analysis – CalPortland’s Rillito Kilns May 2013 5-10

Table 5-3: Emissions Modeled for Base Case and Three Control Scenarios for Kilns 1-3

Table 5-4: Emissions Modeled for Base Case and Three Control Scenarios for Kiln 4 SO2 SO4 NOx PMF PMC EC SOA SO2 SO4 NOx PMF PMC EC SOA

Base Case - No Controls 10.643 22.619 490.200 0.772 0.669 0.000 1.029 1.341 2.850 61.765 0.097 0.084 0.000 0.130
Case 1 - LNB and Indirect firing or Mid-Kiln Firing Kilns 1, 2, 3; Kiln 4 is at Baseline 10.643 22.619 392.200 0.772 0.669 0.000 1.029 1.341 2.850 49.417 0.097 0.084 0.000 0.130

Case 2 - SNCR Kilns 1, 2, 3; Kiln 4 is at Baseline 10.643 22.619 367.700 0.772 0.669 0.000 1.029 1.341 2.850 46.330 0.097 0.084 0.000 0.130

Case 3 - SNCR Kiln 4; Kilns 1,2,3 are at Baseline 10.643 22.619 490.200 0.772 0.669 0.000 1.029 1.341 2.850 61.765 0.097 0.084 0.000 0.130

Case Emissions (lb/hr) for Kilns 1-3 Emissions (g/s) for Kilns 1-3

SO2 SO4 NOx PMF PMC EC SOA SO2 SO4 NOx PMF PMC EC SOA

Base Case - No Controls 2.643 4.246 540.200 2.444 2.198 0.095 0.579 0.333 0.535 68.065 0.308 0.277 0.012 0.073
Case 1 - LNB and Indirect firing or Mid-Kiln Firing Kilns 1, 2, 3; Kiln 4 is at Baseline 2.643 4.246 540.200 2.444 2.198 0.095 0.579 0.333 0.535 68.065 0.308 0.277 0.012 0.073

Case 2 - SNCR Kilns 1, 2, 3; Kiln 4 is at Baseline 2.643 4.246 540.200 2.444 2.198 0.095 0.579 0.333 0.535 68.065 0.308 0.277 0.012 0.073

Case 3 - SNCR Kiln 4; Kilns 1,2,3 are at Baseline 2.643 4.246 378.100 2.444 2.198 0.095 0.579 0.333 0.535 47.641 0.308 0.277 0.012 0.073

Case Emissions (lb/hr) for Kiln 4 Emissions (g/s) for Kiln 4AECOM Environment

Reasonable Progress Analysis – CalPortland’s Rillito Kilns May 2013 5-11



### 5.6 POSTUTIL Post-Processing
The EPA-approved version of POSTUTIL was used to repartition the nitrate concentrations between the gas and particle phases and CALPOST was used to process the regional haze impacts with Method 6. POSTUTIL Version 1.56, Level 070627, and CALPOST Version 6.221, Level 080724, were used. To be consistent with the EPA Task 9 report, AECOM used the APPEND program (Version 2.33, Level 040623) to append the POSTUTIL binary output for the three years modeled into one continuous file prior to running CALPOST.

These programs are available for download from the TRC website http://www.src.com/calpuff/calpuff1.htm

. 

### 5.7 CALPOST Post-Processing
CALPUFF uses predictions of various particulate species to compute the visibility extinction using the Interagency Monitoring of Protected Visual Environments (IMPROVE) equation (both original 10 and “new” 11 versions as documented in the Federal Land Managers’ Air Quality Related Values Workgroup (FLAG) reports. The update to the IMPROVE equation, adopted in the FLAG 2010 version, is based upon a re-evaluation of the comparison between particulate species concentrations, relative humidity, and directly-observed light scattering. During most of the BART analysis period between 2005 and 2010, EPA has relied upon the original IMPROVE equation.

The model user provides specific inputs for the CALPOST post-processor as noted in FLAG reports regarding the use of the original and new IMPROVE equations. In addition to the choice between these equations, the CALPOST user needs to define the natural background particulate concentrations. The BART Rule specifies that the visibility improvement for various emission cases needs to be referenced to “clean” natural conditions, which can be defined in two alternate ways: the annual average natural conditions (referred to as option “a”) and the conditions associated with the 20% best days (referred to as option “b”).

EPA guidance provides each state the option to choose between the two definitions of natural conditions. As EPA noted in its July 20, 2012 proposed rule, Arizona selected the annual average natural background and the original IMPROVE equation (also termed “Method 6”) for use in the State’s BART analyses. These selections correspond to “Method 6a” in the terminology adopted in EPA’s proposed rule.

The modeling results presented in this document were based on Method 6a.

10 Federal Land Managers, 2001. Federal Land Managers’ Air Quality Related Values Workgroup (FLAG) Phase I Report

. http://www2.nature.nps.gov/ard/flagfree/index.htm

.

11 Federal Land Managers, 2010. Federal Land Managers’ Air Quality Related Values Work Group (FLAG) Phase I Report— Revised (2010). Natural Resource Report NPS/NRPC/NRR—2010/232. http://nature.nps.gov/air/pubs/pdf/flag/FLAG_2010.pdf

.AECOM Environment

Reasonable Progress Analysis – CalPortland’s Rillito Kilns May 2013 6-1



## 6.0 CALPUFF Modeling Results

The results of the RP control options visibility modeling are presented in Tables 6-1 and 6-2 and are graphically plotted in Figure 6-1. Results presented in Table 6-1 are the 3-year average of the 98 th percentile delta-deciviews (delta-dv) predicted impacts for each Class I area due to installation of the candidate RP controls on the Rillito kilns, which is represented by the 22 nd highest modeled delta-dv value. Table 6-2 shows the improvements in the visibility impairment for each of the RP control options relative to the base case for each modeled Class I areas. Figure 6-1 compares the total visibility impairment (expressed in deciviews) for the modeled results with output from the three modeled years averaged for each case and Class I area. Figure 6-2 compares the improvements in the visibility impairment for the RP control cases relative to the base case.

Table 6-1: 98 th Percentile Visibility Impairment for Base Case Scenario and Three RP Control Case Scenarios

(delta-dv)

Baseline Control Case 1 Control Case 2 Control Case 3

No Controls LNB and Indirect

Firing or Mid-Kiln Firing on Kilns 1-3; No controls on Kiln 4 SNCR on Kilns 1-3; No control on Kiln 4 SNCR on Kiln 4; No controls on Kilns 1-3

Chiricahua NM 0.201 0.184 0.180 0.173

Chiricahua W 0.218 0.200 0.195 0.189

Galiuro 0.856 0.797 0.784 0.759

Gila 0.902 0.846 0.832 0.786

Mazatzal 0.102 0.095 0.094 0.090
Mount Baldy 0.073 0.067 0.066 0.063

Petrified Forest 0.080 0.073 0.071 0.068

Pine Mountain 0.091 0.084 0.081 0.077
Saguaro (East Only) 1.067 1.001 0.985 0.955

Sierra Ancha 0.102 0.095 0.093 0.089
Superstition 0.251 0.235 0.230 0.232
Sycamore Canyon 0.072 0.067 0.066 0.063 Class I AreasAECOM Environment

Reasonable Progress Analysis – CalPortland’s Rillito Kilns May 2013 6-2

Table 6-2: Visibility Improvement for the Three RP Control Case Scenarios Relative to the Base Case Scenario

(deciviews)

Control Case 1 Control Case 2 Control Case 3

LNB and Indirect Firing or Mid-Kiln Firing on Kilns 1-3; No controls on Kiln 4 SNCR on Kilns 1-3; No control on Kiln 4 SNCR on Kiln 4; No controls on Kilns 1-3

Chiricahua NM 0.017 0.021 0.028

Chiricahua W 0.018 0.023 0.029

Galiuro 0.059 0.072 0.097

Gila 0.056 0.070 0.116

Mazatzal 0.007 0.008 0.012

Mount Baldy 0.006 0.007 0.010

Petrified Forest 0.007 0.009 0.012

Pine Mountain 0.007 0.010 0.014

Saguaro (East Only) 0.066 0.082 0.112

Sierra Ancha 0.007 0.009 0.013

Superstition 0.016 0.021 0.019

Sycamore Canyon 0.005 0.006 0.009

Max 0.066 0.082 0.116 Class I AreasAECOM Environment

Reasonable Progress Analysis – CalPortland’s Rillito Kilns May 2013 6-3

Figure 6-1: 22 nd Highest Visibility Impacts Averaged Over 3 Years for the Base Case Scenario and Three RP Control

Case Scenarios (delta-dv)

0.0 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.9 1.0 1.1 1.2

Chiricahua

NM Chiricahua

W Galiuro Gila Mazatzal Mount Baldy Petrified Forest Pine

Mountain Saguaro

(East Only) Sierra

Ancha Superstition Sycamore Canyon22ndHighest(delta-deciview)

Class I Area Baseline - No Controls
Control Case 1 - Kilns 1-3: LNB; Kiln 4: No Controls
Control Case 2 - Kilns 1-3: SNCR; Kiln 4: No Controls
Control Case 3 - Kilns 1-3: No Controls; Kiln 4: SNCRAECOM Environment

Reasonable Progress Analysis – CalPortland’s Rillito Kilns May 2013 6-4

Figure 6-2: Visibility Improvements of the Three RP Control Case Scenarios Relative to the Base Case Scenario

(deciviews)

0.00 0.02 0.04 0.06 0.08 0.10 0.12 0.14

Chiricahua

NM Chiricahua

W Galiuro Gila Mazatzal Mount Baldy Petrified Forest Pine

Mountain Saguaro

(East Only) Sierra

Ancha Superstition Sycamore CanyonVisibilityImprovement(deciview)

Class I Area Control Case 1 - Kilns 1-3: LNB; Kiln 4: No Controls

Control Case 2 - Kilns 1-3: SNCR; Kiln 4: No Controls

Control Case 3

- Kilns 1

- 3: No Controls; Kiln 4: SNCRAECOM Environment

Reasonable Progress Analysis – CalPortland’s Rillito Kilns May 2013 7-1



## 7.0 Conclusions for Visibility Improvement Analysis

One aspect of the 4 th Reasonable Progress factor is the expected visibility improvement from candidate control options. Several cases were evaluated with the EPA-approved CALPUFF model at Class I areas within 300 km of the Rillito plant.

x Base Case: No control options are implemented for any of the kilns.

x Control Case 1: LNB and indirect firing or mid-kiln firing is implemented on Kilns 1-3. No controls are implemented for Kiln 4.

x Control Case 2: SNCR is implemented on Kilns 1-3. No control options are implemented for Kiln 4.

x Control Case 3: SNCR is implemented on Kiln 4. No control options are implemented for Kilns 1-3.

The results of this analysis indicate that all candidate controls result in levels of visibility improvement that are too low to be detected by the available technology for particulate monitors (much less than 0.3 delta-deciview) and less than 12 percent of the perceptible levels that can be visually detected (1 deciview). The visibility improvement associated with SNCR controls on the active Kiln 4 is about 0.1 delta-deciview, a level which is mentioned in the 1999 Regional Haze Rule as being associated with “no degradation” of visibility. Accordingly, we conclude that none of these Reasonable Progress options is sufficiently effective to replace the current NOx emission controls on the CalPortland kilns in Rillito, AZ.AECOM Environment

Reasonable Progress Analysis – CalPortland’s Rillito Kilns May 2013 

## Appendix A

CALMET/CALPUFF Processing RefinementsAECOM Environment

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### Enhancements to the WRAP CALMET Database

AECOM suggested two modifications/enhancements to the 4-km Arizona CALMET WRAP database. They are as follows:

The 4-km Arizona CALMET database has been produced by AECOM using the downloaded CALMET inputs from the WRAP website http://pah.cert.ucr.edu/aqm/308/bart/calpuff/calmet_inputs/az/ . AECOM initially ran CALMET with the setting suggested in the WRAP BART modeling protocol. As part of AECOM’s internal quality assurance procedure, we displayed and examined the 4-km Arizona WRAP CALMET wind fields in the visualization software CALDESK. Figure A-1 graphically shows wind fields with the WRAP settings for a typical hour. Arrows represent wind direction and wind speed for that hour at 10 meter height. Circular areas in these figures with common winds and abrupt transitions at the edge of the circles indicate a radius of influence of surface stations, R1, which was set to 100 km, as suggested in the WRAP BART protocol. The R1 value was coupled with R1MAX = 50 km so that the influence of the surface stations is established out to 50 km and then it abruptly ends beyond that distance. Setting R1 and R1MAX to such high values is not recommended by the model developer and Federal Land Managers, especially with MM5 data resolution of 36 km with areas of complex terrain. Typically, R1 is set to a fairly small value, generally not exceeding half of the MM5 data resolution (18 km), according to recent guidance on multiple PSD projects involving CALPUFF modeling in the WRAP region from John Notar of the National Park Service (personal correspondence between John Notar of the NPS and Bob Paine of AECOM). A large R1 value results in wind fields surrounding surface stations that overwrite the MM5 wind fields, which do have terrain influences incorporated into them. In many instances, the extended extrapolation of the surface station data with an abrupt transition at 50 km produces opposing wind directions in adjacent grid squares at the 50 km distance.

To avoid this problematic wind field result, AECOM used a smaller R1 value of 18 km and R1MAX value of 30 km. The resulting wind fields for the same hour and height are depicted in Figure A-2. The adjusted R1 and R1MAX values blend the surface observations into the MM5 observations much better, creating a more uniform wind field throughout the domain. Therefore, AECOM used the smaller R1 and R1MAX values to be more consistent with FLM guidance and due to the better performance in the wind field depiction associated with the smaller values.

When rerunning CALMET, AECOM used the "official" EPA-approved version of CALPUFF modeling system CALMET Version 5.8 instead of Version 6.211 that was used by WRAP, available at http://www.src.com/calpuff/download/download.htm#EPA_VERSION

. In accordance with recent CALPUFF modeling guidance from the EPA Region IX and National Park Service, AECOM used the technical options listed below.

x Included upper air soundings in a Step 2 analysis; the WRAP BART protocol does not include these observations. Figure A-3 shows upper air and surface station locations.

x Set NOOBS = 0, to use both surface and upper air observations.

x Set IEXTRP = -4, to extrapolate surface wind observations to the upper layers using similarity theory, and ignore layer 1 from the upper air soundings.

x Set ITPROG = 1, to use surface station temperature and the MM5 for upper air temperature interpolation.AECOM Environment

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A summary of the specific CALMET options selected by AECOM are listed in Table A-1.

Table A-1 CALMET Options Comparison

Variable Description WRAP Value ENSR Value

RMAX1 Maximum radius of influence over land

in the surface layer 50 30

R1 Relative weighting of the first-guess

field and observations in the surface layer 100 18

R2 Relative weighting of the first-guess

field and observations in the layers aloft 200 20AECOM Environment

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Figure A-1 CALMET Windfields with WRAP SettingsAECOM Environment

Reasonable Progress Analysis – CalPortland’s Rillito Kilns May 2013 4

Figure A-2 CALMET Windfields with AECOM SettingsAECOM Environment

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Figure A-3 Location of Surface and Upper Air Stations used for Arizona CALMET Domain