### SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

Final Draft Staff Report

Proposed Amended Rule 1156 – Further Reductions of Particulate Emissions from Cement Manufacturing Facilities

March February 2009

Deputy Executive Officer Planning, Rule Development and Area Sources Elaine Chang, DrPH

Assistant Deputy Executive Officer Planning, Rule Development and Area Sources Laki Tisopulos, Ph.D., P.E.

Director of Strategic Initiatives Planning, Rule Development and Area Sources Jill Whynot

AUTHOR:

Tuyet-Le Pham - Air Quality Specialist

TECHNICAL ASSISTANCE:

Rudy Eden – Senior Enforcement Manager

Philip Fine, Ph.D. – Atmospheric Measurements Manager
Greg Hunter, Ph.D. – Air Quality Specialist

REVIEWED BY:

Barbara Baird – District Counsel

Ruby Fernandez – Deputy District Counsel I

Tracy A. Goss, P.E. - Program SupervisorSOUTH COAST AIR QUALIT Y MANAGEMENT DISTRICT

GOVERNING BOARD

Chairman: WILLIAM A. BURKE, Ed.D. Speaker of the Assembly Appointee

Vice Chairman: S. ROY WILSON, Ed.D. Supervisor, Fourth District Riverside County Representative
MEMBERS:

MICHAEL D. ANTONOVICH Supervisor, Fifth District Los Angeles County Representative

MICHAEL A. CACCIOTTI Councilmember, City of South Pasadena Cities Representative, Los Angeles County, Eastern Region

BILL CAMPBELL Supervisor, Third District Orange County Representative

JANE W. CARNEY Senate Rules Committee Appointee

JOSIE GONZALES Supervisor, Fifth District San Bernardino County Representative

RONALD O. LOVERIDGE Mayor, City of Riverside Cities Representative, Riverside County

JOSEPH K. LYOU, Ph.D. Governor's Appointee

JAN PERRY Councilmember, 9 th District 

### City of Los Angeles Representative

MIGUEL PULIDO Mayor, City of Santa Ana Cities Representative, Orange County

TONIA REYES URANGA Councilmember, City of Long Beach Cities Representative, Los Angeles County, Western Region

DENNIS YATES Mayor, City of Chino Cities of San Bernardino County Representative

EXECUTIVE OFFICER: BARRY R. WALLERSTEIN, D.Env.Table of Contents

i March February 2009 

### TABLE OF CONTENTS

Executive Summary ...............................................................................................1

Portland Cement Manufacturing Process ...........................................................6

Regulatory Background ........................................................................................8

Public Process .......................................................................................................10

Air Quality Standards .........................................................................................10

Health Effects from Fine Particulate Matter ....................................................11

Health Effects from Hexavalent Chromium ....................................................11

Purpose and Applicability ...................................................................................12

Legal Authority ....................................................................................................12

Affected Industry .................................................................................................12

Summary of Proposed Rule ................................................................................13

Emissions and Emission Reductions ..................................................................20

Costs and Cost-Effectiveness .............................................................................20

California Environmental Quality Act ..............................................................22

Socioeconomic Assessment ..................................................................................23

Draft Findings .....................................................................................................23

Alternative Control Measures ...........................................................................23

Comparative Analysis .........................................................................................24

Conclusion ...........................................................................................................24

References ............................................................................................................24

List of Figures

Figure 1 - Cement Plants and Air Monitoring Station ............................................1

Figure 2 - Hexavalent Chromium in Western Riverside

and San Bernadino County ................................................................................2

Figure 3 - Hexavalent Chromium Sampling Locations in Western Riverside

and San Bernadino County ................................................................................9

Figure 4 - All MATES III Fixed-Site Data Excluding Rubidoux .........................16

List of Tables

Table 1 - Particulate Matter Concentrations .........................................................11

Table 2 - Lognormal St atistical Results.................................................................17Table of Contents

ii March February 2009 Table 3 – Estimated Costs .....................................................................................21

Appendices

Appendix A – Response to Comments for the Public Review Period

Ending December 12, 2008

Appendix B – Response to Comments for the Public Review Period

Ending July 20, 2008

Appendix C - Comparison of PR1156 and Other Requirements for

Cement ManufacturingFinal Draft Staff Report for Proposed Amended Rule 1156

South Coast Air Quality Management District 1 March February 2009 

### EXECUTIVE SUMMARY

Rule 1156 - Further Reductions of Particul ate Emissions from Cement Manufacturing Facilities was adopted by the AQMD Govern ing Board in November 2005. Rule 1156 requires cement manufacturing facilities to comply with specific requirements applicable to various operations, as well as materials handling and transport at the facilities.

Elevated ambient air concentrations of th e carcinogen hexavalent chromium as fine particulate matter in Rubidoux were discovered through sampling efforts of the Multiple Air Toxics Emissions Study (MATES III). Extens ive additional sampling and modeling traced these emissions to loading, unloading, and transfe rring of clinker material stored in the open at TXI Riverside Cement (TXI) located in Rivers ide. Clinker material is a product from the kiln pyro-processing and is used as feedstoc k to make cement. TXI is one of the two facilities in the AQMD’s jurisdiction subject to Rule 1156; the other being California Portland Cement Company (CPCC) located in Colton (Figure 1). Figure 1 also shows the

location of the Western Riverside Air Monito ring Station and arrows indicating prevailing

wind directions.

Western

Riverside Air Monitoring

Station TXI

Riverside

Cement California

Portland
Cement

p r e

v

a i l i n g w i n d

Figure 1 - Cement Plants and Air Monitoring Station

Currently, TXI no longer stores or handles clinker material in the open. As a result of a settlement agreement with the AQMD, as of August 2008, TXI has removed all clinker piles from the open storage areas, and is not allowed to have open storage and handling of clinker material in the future. Further, any clinker handling or storage will occur in an enclosed setting, controlling all emissions from clinker material processing to the extent feasible.Final Draft Staff Report for Proposed Amended Rule 1156

South Coast Air Quality Management District 2 March February 2009 In addition, TXI also shut down its white cem ent kilns and finish mills with an unknown restart date, although these actions were due to the economic climate and not part of the settlement agreement or any other AQMD enfo rcement actions. At cement manufacturing facilities, although dust from clinker material handling has been identified as the main

contributor to ambient hexavalent chromium le vels, kilns and finish mills at these facilities

can influence the formation and emissions of hexavalent chromium.

Since implementation of the settlement agreement, the 24-hour hexavalent chromium concentrations measured in the vicinity of TXI and at the Rubidoux monitoring station as part of the AQMD’s on-going air quality monitori ng effort depict an overall downward trend. However, some recent measurements revealed elevated ambient concentrations of hexavalent chromium (Figure 2). Review of the data indi cates this to be, at least in part, a seasonal effect due to low ambient air mixing height and Santa Ana wind conditions. Staff has been conducting further investigation. Site 7 is roughly located between the two cement plants.

0 1 2 3 4 5 6 75-Feb-086-Mar-085-Apr-085-May-084-Jun-084-Jul-083-Aug-082-Sep-082-Oct-081-Nov-08

Date of SampleCr6 (ng/m3) TXI

Rubidoux

Cal Portland

Site 7

TXI Removal of all open clinker piles – 7/23/08

Figure 2

– Hexavalent Chromium in Western Riverside and San Bernardino County

In addition to hexavalent chromium, other toxi cs such as lead, arsenic, cadmium, and cobalt may also be contained within the clinker ma terial; however, hexavalent chromium is the primary toxic of concern based on AQMD staff’s analysis of raw materials, and ambient as well as fall-out samples collected. Chromium is a component of the primary raw material ofFinal Draft Staff Report for Proposed Amended Rule 1156

South Coast Air Quality Management District 3 March February 2009 the cement manufacturing process, limestone, and as discussed later, is converted to hexavalent chromium in the pyro-processing stage.

To further reduce particulates and to address the issue of hexavalent chromium as fine particulate matter from cement manufacturing facilities, AQMD staff released its initial proposed amendments to Rule 1156 and conduc ted a public workshop on July 2, 2008. That proposal called for total enclosure of all cli nker storage and handling, regardless of size. However, during the public comment period, sta ff received comments citing intense financial hardship, including potential facility shut down relative to the high cost of the enclosure proposal.

With the intent to ensure reductions of particulates from cement manufacturing facilities, and to limit exposure to PM10 and hexavalent chromium while addressing the issue of financial hardship, AQMD staff revised the proposal a nd held a subsequent Public Consultation meeting on November 20, 2008 and a Town Hall meeting on December 3, 2008.

Following the second public review and comment period, staff made additional modifications to the proposal. The curre nt Proposed Amended Rule (PAR) 1156 would require total enclosure of clinker storage a nd handling conducted within 1,000 feet from, and inside, a facility’s property line. For clinker storage and handling activities that occur more than 1,000 feet from, and inside, a facility’s property line, PAR 1156 would allow the use of alternatives, such as a three-sided barrier cove red with a roof and wind fence for active, barntype storage; tarp and barrier/wind fence for other active piles; and tarp for inactive piles.

The proposal would also require ambient monito ring to measure hexavalent chromium at the property fence line. Any hexavalent chromi um concentration from either a 30-day or a 90- day rolling average that is based on a one -in-three-day or one-in-six-day sampling, respectively, in exceedance of 0.7 nanograms per cubic meter (ng/m 3 ), excluding background level, if valid would trigger total enclosure w ithin 24 months from date of exceedance, or an incremental enclosure over a four-year period, for all clinker storage and handling.

For any exceedance of the PM10 level as specified in Rule 403 – Fugitive Dust, the proposal would require actions to reduce clinker dust, as well as application of dust suppressant on all openly stored non-clinker material, unpaved road s, and unpaved areas within the facility. The proposal would also require a continuous PM10 ambient monitoring network if this PM10 level is violated three times within a 36-month period.

The present value of control costs of PA R 1156 would be $2.6 to $3.6 million, and the costeffectiveness would be $9,000 to $12,000 per ton of PM10 reduced, providing that ambient air monitoring for PM10 is not needed. Incl uding PM10 monitoring, the control cost would
be $3. 6 9 to $4.9 million, and the cost-effectiven ess would be $13,000 to $17,000 per ton of PM10 reduced. If total enclosure is required, these costs would be substantially higher ($9.5
to $12 million to over $20 million ). The latter cost figures in the aforementioned ranges are

CPCC estimates.Final Draft Staff Report for Proposed Amended Rule 1156

South Coast Air Quality Management District 4 March February 2009 PAR 1156 contains five main elements, as summarized below:

Material Storage In the current adopted Rule 1156, operators of a cement manufacturing facility are required to enclose their open storage of clinker if the storage piles exceed 4 acres or 80,000 tons/month throughput. To minimize particulate emissions from storage piles that are not fully enclosed, the rule requires the use of ch emical dust suppression, tarps, or barriers/wind

fences.

Given the finding of AQMD’s recent monitoring e fforts regarding hexavalent chromium and public complaints about fine particulates, the current proposed amendment would require total enclosure of clinker storage and handli ng conducted within 1,000 feet from, and inside, a facility’s property line, no later than six mont hs from date of rule adoption, and allow the use of the following in the meantime: (1) ch emical dust suppressants; (2) a three-sided barrier/wind fence with or without a roof; or (3) tarp.

For the storage and handling of clinker piles lo cated more than 1,000-feet from, and inside, a facility’s property line, PAR 1156 would allow th e use of: (1) a three-sided barrier covered with a roof and wind fence for active, barn-type storage; (2) tarp and barrier/wind fence for other active piles; and (3) tarp for inactive piles.

Given the settlement agreement with TXI, these requirements would affect primarily CPCC and any new operations in the future. Si nce CPCC does not store and handle clinker materials in the open area within 1,000 feet from its property line, it is expected that CPCC would comply with the latter option.

Ambient Monitoring The proposed amendments include hexavalent chromium monitoring, PM monitoring if repeated violations occur, and wind monito ring. AQMD staff has b een working with CPCC and extended an invitation to TXI, to help answ er technical questions to ensure that this process proceeds smoothly.

PAR 1156 would require 24-hour ambient air m onitoring for hexavalent chromium once every third day. Any confirmed 30-day rolling average hexavalent chromium concentration in exceedance of 0.7 nanograms per cubic meter (ng/m 3 ), excluding background level, would trigger a total enclosure within 24 months fr om date of exceedance, or an incremental enclosure over a four-year period, for a ll clinker storage and handling. 0.70 ng/m 3 represents 100-in-1-million cancer risk based on a 70-year exposure.

The operator(s) would be able to conduct less frequent sampling (once every six days) if there is no hexavalent chromium exceedance during the first twelve (12) continuous months of monitoring. Under this schedule, any confirmed 90-day rolling average hexavalent chromium concentration in exceedance of 0.70 ng/m 3 , excluding background, would also trigger the aforementioned enclosure requirementand a reversion back to the once-in-threeday sampling schedule.Final Draft Staff Report for Proposed Amended Rule 1156

South Coast Air Quality Management District 5 March February 2009 In the event of a hexavalent chromium exceed ance when there is no openly stored clinker material, the AQMD will conduct necessary studi es to identify the source(s) and pursue

further corrective actions.

Any exceedance of PM10 upwind/ downwind level of 50 microgram per cubic meter (μg/m 3 ) as specified in Rule 403 – Fugitive Dust, would require the operator(s) to take steps to reduce clinker dust emissions, as well as apply dust suppressant on their openly stored non-clinker materials, unpaved roads, and unpaved areas. If the aforementioned PM10 level is exceeded three or more times within a 36-month period, PAR 1156 would require amended compliance monitoring plan and on-site continuous, real- time ambient air monitoring for PM10 within six months from the date of amended plan appr oval or one year from the date of the third approved notice of violation, whichever occurs first.

Compliance Monitoring Plan PAR 1156 would require a compliance monitori ng plan for the monitoring, sampling, and analysis of hexavalent chromium, and fees pursuant to Rule 306 no later than three months from date of rule adoption. The plan will be approved or disapproved by the AQMD within 60 days from the plan submittal date. The operator(s) must resubmit an approvable plan within 30 days from date of plan disapproval; failure to do so is a violation of the rule. The approved plan can be updated as additional site-specific data becomes available.

In the event where continuous, real time ambien t monitoring for PM10 is required as a result of three violations of Rule 403, the operator(s ) must amend their compliance monitoring plan to include appropriate plan elements relative to PM10 monitoring.

Wind Monitoring PAR 1156 would require the operator(s) to install equipment and conduct hourly wind monitoring according to an AQMD-approved-protocol no later than six months from date of rule adoption. In addition, the proposed amendm ent would also call for a halt to all clinker handling activities in the open for two hours if instantaneous wind speeds exceed 25 miles per hour (mph) at any given time. During th is two-hour period, the operator(s) would be exempt from the 100-feet visible dust plum e limit, providing that the open handling of clinker material is ceased, dust controls as required by the AQMD are applied, and unpaved roads within the facility are stabilized in a dvance of any high wind occurrence as currently required elsewhere in the rule or other rules. If instantaneous wind speeds exceeding 25 mph subsequently occur, a new two-hour period would begin.

Exemptions: During days in which high wind events occur, cement manufacturing operator(s) can be exempt from the hexavalent chromium a nd PM10 averaging provisions in the proposal, provided that all handling of clinker materials in the open is ceased and dust controls are applied. However, in the event the Executiv e Officer determines there is a significant hexavalent chromium dust re-entrainment potential, the operator(s) would be required to implement an approved Mitigation Monitoring Plan to minimize exposure to the surrounding

areas.Final Draft Staff Report for Proposed Amended Rule 1156

South Coast Air Quality Management District 6 March February 2009 Cement manufacturing operator(s) are also exem pt from the wind fence requirement during periodic maintenance of the clinker crane or st orage barn, provided that clinker crane is not operated.

Currently, operator(s) of a cement manufacturing facility can be exempt from storage piles requirement of enclosure or three-sided ba rrier, or from using the AQMD Rule 403 test methods for the demonstration of a pile’s surf ace stabilization if the materials contained in 90% of the pile’s volume are larger than 1⁄2 inc h. Under the proposal, this would change to a

mass basis and would exclude clinker material. Therefore, operator(s) who have open piles containing only materials other than clinker would be exempt from the above mentioned requirements if the materials contained in 90% of the pile’s mass are larger than 1⁄2 inch. The mass basis would make testing and enforcement easier.

Other An amendment is also proposed to the definiti on of Cement Manufacturing Facility to clarify that even though TXI is not currently manufactur ing cement products, they are subject to the monitoring requirements (wind, hexavalent ch romium, and PM10, as applicable) of the proposal.

In addition, the proposed amended rule also contains other minor amendments and

clarifications to better demonstrate the rule’s intent and to respond to US EPA comments on

other elements of the rule.



### PORTLAND CEMENT MANUFACTURING PROCESS

There are two Portland cement manufacturing facilities in the Basin, California Portland Cement Company (CPCC) and TXI Riverside Cement Company (TXI). CPCC manufactures gray cement, and TXI manufactures white cemen t and produces gray cement from clinker delivered to the facility from outside the Basi n. The production of Portland cement is a four step process which includes:

1) Raw materials acquisition; 2) Preparation of raw materials into raw mix; 3) Pyroprocessing of raw mix to make clinker; and 4) Grinding and milling of clinker into cement.

Raw Materials Acquisition Raw materials for manufacturing cement include calcium, silica, alumina and iron. Calcium is the element of highest concentration, and iron is raw material for gray cement but not used

for white cement. These raw materials are obt ained from minerals such as limestone for calcium; sand for silica; shale and clay for alum ina and silica. CPCC obtains limestone from the quarry located on site. Other raw material s are delivered to CPCC by truck or rail car. All raw materials are delivered to TXI by truck or rail car.

Preparation of Raw Materials into Raw Mix Preparing the raw mix includes crushing, milling, blending and storage. Primary, secondary and tertiary crushers are used to crush the raw materials until they are about 3⁄4 inch orFinal Draft Staff Report for Proposed Amended Rule 1156

South Coast Air Quality Management District 7 March February 2009 smaller in size. Raw materials are then conveyed to rock storage silos. Belt conveyors are typically used for this transport. From the ro ck storage silos, the raw materials are conveyed to roller mills or ball mills where they are blended and pulverized into a very fine powder. Pneumatic conveyors are typically used to tran sport the fine raw mix to homogenizing silos where they are again thoroughly blended and stored until it is fed to the kilns.

Pyroprocessing of Raw Mix Pyroprocessing is the chemical and physical pr ocess of transforming the fine raw mix into clinker. Pyroprocessing occurs in a rotary kiln and includes three steps:

― Evaporating free water and dehydrating to form oxides of silicon, aluminum, and iron. This process occurs in a drying and preheating z one of the rotary kiln at temperatures of

about 212 o F – 800 o F;

― Calcining of calcium carbonates (CaCO 3 ) to form calcium oxides (CaO) and carbon dioxide (CO 2 ). This process occurs in the cal cining zone of the rotary kiln at temperatures of about 1,100 o F – 1,800 o F; and

― Chemical reacting, melting and restructuring of materials occur between calcium oxides (CaO), silica, alumina and iron to form clinke r, which is a solid material ranging in size

from 1 – 2 inch diameter. Clinker contai ns four major compounds tricalcium silicate (~50% by weight), dicalcium silicate (~25% by weight), tricalcium aluminate (~10% by weight) and tetracalcium aluminoferrite (~ 10% by weight). The process of forming clinker occurs in the “burning” zone of th e rotary kiln at temperatures of about 2,200 o F – 2,700 o F.

The pyroprocessing process at CPCC and TXI is called a “long dry process” consisting solely of a simple long rotary kiln. CPCC opera tes two rotary kilns in parallel; each is about

18 ft in diameter and 500 ft in length. TXI has two rotary kilns in parallel; each is about 12 ft in diameter and 200 ft in length. The kilns are slightly inclined and rotate on its longitudinal axis. Raw materials are fed into the upper end of the kiln while fuels are burned in the lower end. As the kiln rotates, the raw materials move slowly from the upper end to the lower end, and the combustion gases move in counter-cu rrent direction. The residence time of raw materials in a gray cement kiln is about 2 – 3 hours, whereas for white cement, it is about 8 hours. The hot clinker, which exits at about 2,000 o F from the kiln, is quickly cooled in the clinker cooler and is conveyed to storage.

Clinker is water reactive and must be stored such that it is protected from moisture. If clinker gets wet, it will hydrate and set into c oncrete. Heat used in the kiln is supplied through the combustion of different fuels such as coal, coke, oil, natural gas, and tires. The combustion gases are vented to baghouse where dusts are collected. Dust is returned to the process or recycled if they meet certain criteria, or is discarded to landfills.

Grinding and Milling Clinker into Cement Grinding and milling clinker into cement is the last step of the manufacturing process. Up to 5% of gypsum is added to the clinker during grinding to control the setting time of cement. Other specialty chemicals are also added at this stage. After grinding and milling into fineFinal Draft Staff Report for Proposed Amended Rule 1156

South Coast Air Quality Management District 8 March February 2009 powder, the cement is pneumatically conveyed to the product silos. The product is either sold in bulk or is bagged.



### REGULATORY BACKGROUND

Rule 1156 - Further Reductions of Particul ate Emissions from Cement Manufacturing Facilities was adopted by the AQMD’s Govern ing Board in November 2005. The rule implemented the 2003 Air Quality Management Plan (AQMP) Control Measure BCM-08 – Further Emission Reductions from Aggregate a nd Cement Manufacturing Operations. Rule 1156 requires cement manufacturing facilities to comply with specific requirements applicable to various operations, as well as mate rials handling and transport at the facilities. Rule 1156 was approved by EPA into the SIP in March 2008.

As AQMD staff completed their data anal ysis for MATES III, they observed clear, unexpected elevated levels of hexavalent chromium, a potent, known carcinogen, at the Rubidoux monitoring station in Western Rivers ide County, over two miles to the southwest of TXI. The AQMD’s rigorous regulatory and enforcement program should have resulted in

a decrease of ambient hexavalent chromium concentration.

AQMD staff thoroughly investigated the potentia l sources of the elevated hexavalent chromium level. Staff has conducted air, ma terial, and soil sampling, permit reviews, areawide surveys and surveillance, and air quality modeling. After five months of rigorous research and sampling, results indicated that TXI was the primary source of the elevated

hexavalent chromium concentrations in the ar ea. Specifically, the handling and transport of clinker material, a product from the kiln pyro-pr ocessing, which is used as feedstock to make cement, has been determined to be the primary source of hexavalent chromium emissions. In addition to hexavalent chromium, other toxics such as lead, arsenic, cadmium, cobalt may also be contained within the clinker material; however, hexavalent chromium is the primary toxic of concern based on AQMD staff’s analysis of raw materials (e.g., limestone), as well as ambient and fall-out samples collected.

As a result of a settlement agreement with th e AQMD after issuance of numerous Notices of Violation, TXI has removed all clinker piles from the open storage areas (as of August 2008), and is not allowed to have ope n storage and handling of clinker materials in the future. Further, any clinker handling or storage will occur in an enclosed setting, controlling all emissions from clinker material processing to the extent feasible. In addition, TXI also shut down its white cement kilns and finish mills with an unknown restart date, although these

actions were due to the economic climate and not part of the settlement agreement or any other AQMD enforcement actions. At cemen t manufacturing facilities, although dust from clinker material handling has been identified as the main contributor to ambient hexavalent chromium levels, kilns and finish mills at these facilities can influence the formation and

emissions of hexavalent chromium.Final Draft Staff Report for Proposed Amended Rule 1156

South Coast Air Quality Management District 9 March February 2009 Figure 3 – Hexavalent Chromium Sampling Lo cations in Western Riverside and San Bernadino County

Since implementation of the settlement agreement, the 24-hour hexavalent chromium concentrations measured in the vicinity of TXI and at the Rubidoux monitoring station depict an overall downward trend (see Figure 2), except for some recent incidents where elevated

ambient concentrations of hexavalent chromi um were detected. As a result, staff is continuing its monitoring efforts. In addition to the seasonal trend of hexavalent chromium as PM10 dust emissions, staff believes there is a potential contribution to the elevated ambient levels by cement plants in the vicinity of the monitoring sites.

To address the issues of hexavalent chromium as fine particulate, and to reduce health risks to the surrounding community while preserving th e original intent of previously adopted Rule 1156, staff released its initial proposed amendment to Rule 1156 and conducted a public workshop on July 2, 2008. That proposal called for total enclosure of all clinker storage and handling, regardless of size. However, dur ing the public comment period, staff received comments citing intense financial hardship, in cluding potential facility shut down relative to the enclosure proposal.

With the intent to ensure reductions of particulates from cement manufacturing facilities, and to limit exposure to PM10 and hexavalent chromium while addressing the issue of financial hardship, AQMD staff has revised its initial proposal.Final Draft Staff Report for Proposed Amended Rule 1156

South Coast Air Quality Management District 10 March February 2009 

### PUBLIC PROCESS

Staff released the initial proposed amendment to Rule 1156 for the Public Workshop held on July 2, 2008 in the community near the two cem ent manufacturing facilities. Approximately 1,000 notices were mailed, including to attendees of the two Town Hall meetings held in the area regarding the ambient air monitoring e fforts that were begun due to the MATES III findings. Comments received reflecting public support for the rule amendments, and concerns from industry regarding the total encl osure requirement were considered by staff. Staff has been working closely with the cement manufacturing industry on key technical elements of the rule amendment proposal, such as additional controls on clinker material handling and monitoring issues, as well as techni cal and financial constraints. Staff also contacted representatives from various dome manufacturing companies, as well as tarp and wind fence manufacturers/distributors, to gather information regarding costs and feasibility.

Staff released a revised amendment pr oposal and held a November 20, 2008 public consultation meeting. Staff also organized a Town Hall meeting on December 3, 2008 to provide the communities near TXI and CPCC with an update regarding cement plant issues, including ambient monitoring, and to intr oduce a summary of the revised proposed

amendments to Rule 1156. Staff worked with industry on their various concerns, such as rule applicability, compliance monitoring plan development, monitoring systems as well as guidelines and/or protocols, and laboratory cer tification process for hexavalent chromium analysis. Staff also addressed all public comments received by November 20, 2008 during the rule amendment process in this Staff Report (see appendices A and B).

In addition, the AQMD Governing Board will ha ve a community “meet and greet” scheduled

for March 5 th , prior to the scheduled March 6, 2009 P ublic Hearing. Readers may refer to www.aqmd.gov/calendar/calev.html for information regarding these meetings.



### AIR QUALITY STANDARDS

The District monitors ambient air quality for criteria pollutants (ozone, carbon monoxide, particulate matter, NO 2 , lead, SO 2 , and sulfate) at 32 locations within the District. The following table presents a summary of the federal National Ambient Air Quality Standards (NAAQS) and State of California air quality sta ndards for particulate matter. These air quality standards are set to protect public health. The Basin is not in attainment with the 24- hour or annual average NAAQS for PM2.5. The Basi n is also not in attainment with State annual average air quality standards for PM2.5.

Table 1 shows the air quality standards and th e annual average air quality data for Rubidoux. This illustrates the magnitude of the particulat e matter air quality in the area near these two cement manufacturing facilities.Final Draft Staff Report for Proposed Amended Rule 1156

South Coast Air Quality Management District 11 March February 2009 Table 1 Particulate Matter Concentrations (μg/m 3 )

Jurisdiction PM10 PM2.5

Annual 24-Hour Annual 24-Hour

Annual Average Ambient
Concentrations at Rubidoux (Riverside County, 2007) 54.7 -- 19.1 --

Federal Standards -- 150 15 35

California Standards 20 50 12 --



### HEALTH EFFECTS FROM FINE PARTICULATE MATTER

The following is an excerpt from Chapter 2, Ai r Quality and Health Effects, from the 2007 Air Quality Management Plan:

A consistent correlation between elevated ambient fine particulate matter (PM10 and PM2.5) levels and an increase in mortality rates, respiratory infections, number and severity of asthma attacks and the number of hospital admissions has been observed in different parts of the United States and vari ous areas around the world. In recent years, studies have reported an association between long-term exposure to air pollution dominated by fine particles (PM2.5) and incr eased mortality, reduction in life-span, and an increased mortality from lung cancer.

Daily fluctuations in fine particulate matter concentration levels have also been related to hospital admissions for acute respiratory cond itions, to school and kindergarten absences, to a decrease in respiratory function in norma l children and to increased medication use in

children and adults with asthma. Recent studi es show lung function growth in children is reduced with long-term exposure to particul ate matter. The elderly, people with preexisting respiratory and/or cardiovascular di sease, and children appear to be more susceptible to the effects of PM10 and PM2.5.



### HEALTH EFFECTS FROM HEXAVALENT CHROMIUM

Hexavalent chromium compounds are used in many industries, mainly in chrome plating, and chromate and chromate pigment productions. Hexavalent chromium can also be emitted from cement manufacturing facilities. Studies indicate that exposure to hexavalent chromium could result in the following:

• Lung cancer;

• Irritation and damage to the skin, eyes, nos e, throat, and lung, if exposed to high concentrations;Final Draft Staff Report for Proposed Amended Rule 1156

South Coast Air Quality Management District 12 March February 2009 • Asthma symptoms; or

• Allergic skin reaction such as a red, itchy rash.

Hexavalent chromium compounds are classified as Toxic Air Contaminants by the CARB. The California EPA’s (CalEPA) Office of Environment Health Hazard Assessment has established a cancer risk potency factor from breathing in hexavalent chromium. Hexavalent chromium is a potent, known carcinogen. This pot ency factor can be used to assess cancer risk over a lifetime exposure.

Based on monitoring data, the cancer risk associat ed with hexavalent chromium from TXI is estimated at 300 to 500 in a million, which is similar to the risk found next to a busy freeway, a rail yard, or a large chrome plating facilit y. In addition to the requirements in the settlement agreement, TXI was required to c onduct a facility-wide health risk assessment under the Air Toxics Hotspot Information a nd Assessment Act, AB 2588. That assessment has been received and is undergoing staff review.



### PURPOSE AND APPLICABILITY

The proposed amendments are designed to ensu re further reductions of particulate matter emissions from cement manufacturing facilities, in order to aid in progress towards attainment of the federal and state standards, a nd health protection from the emissions of fine particulates (including hexavalent chromium).

PAR 1156 would strengthen the requirements fo r clinker storage and handling at cement manufacturing facilities, and would require ambi ent monitoring for hexavalent chromium in addition to wind monitoring. PM10 monitoring w ould be required in the event of recurring Rule 403 violations of the upwind/downwind fugitive dust limit (50 μg/m 3 ).



### LEGAL AUTHORITY

The AQMD obtains authority to adopt, amend, or repeal rules and regulations which control air pollution from Health and Safety Code Sections 39002, 40000, 40001, and 40440.



### AFFECTED INDUSTRY

There are two existing facilities subject to PAR 1156: CPCC located in Colton (southwestern San Bernardino County), and TXI located in Riverside (north-western Riverside County). Rule amendments would make ex isting requirements more stringent and add ambient and wind monitoring requirements. Since TXI no longer stores and handles clinker material in the open, it would only be subject to the monitoring requirements (i.e., hexavalent chromium and wind monitoring, and PM10 monito ring as applicable). CPCC currently does not store and handle clinker material within 1,000 ft from, and inside, its property line, hence CPCC would likely elect to comply with th e alternative requirements in subparagraph (d)(5)(C), in addition to being subject to the monitoring provisions.



### SUMMARY OF PROPOSED RULE

PAR 1156 is summarized below.Final Draft Staff Report for Proposed Amended Rule 1156

South Coast Air Quality Management District 13 March February 2009 

### Subdivision (d) – Requirements

Material Storage Current proposed amendments to Rule 1156 would require total enclosure of clinker storage and handling conducted within 1,000 feet from, a nd inside, a facility’s property line, no later than six months from date of rule adoption. Prior to the completion and operation of the enclosure, PAR 1156 would allow use one of th e following: (1) chemical dust suppressants; (2) a three-sided barrier/wind fence with or w ithout a roof, in addition to maintaining the pile’s surface stabilization; or (3) tarp.

For the storage and handling of clinker piles lo cated more than 1,000-feet from, and inside, a facility’s property line, PAR 1156 would allow us e of: (1) a three-sided barrier covered with

a roof and wind fence of a maxi mum 20% porosity for active, barn-type storage; (2) tarp and extended wind fence with at least 5-foot freeboard for active piles that are immediately adjacent to the above mentioned covered barrier; and (3) tarp and barrier/wind fence with at

least a 5-foot freeboard and extended at leas t 20 feet beyond the active portion of a pile for other active piles. The 1,000 foot level is se lected because most fugitive dust emissions deposit within 1,000 feet from the source.

The removable wind fence for vehicle access at the barn-type storage can be removed only during minor or routine maintenance activities, th e creation or reclamation of outside storage piles, the importation of clinker from outside the facility, and reclamation of plant clean-up materials, provided that appropriate record s required in the proposal are kept. The removable opening shall be less than 50% of th e total surface area of the wind fence and the

amount of time shall be minimized to the extent feasible.

For inactive clinker storage, PAR 1156 would a lternatively allow tarping only, provided that

records of inactive status are maintained. Inac tive clinker piles are piles of clinker materials that have not been disturbed, removed, and/or added to as a result of loading, unloading, and/or transferring activities for a minimum of 30 consecutive days.

Language in subparagraph (d)(2)(B) has been re vised to clarify that during all conveying activities, the enclosed transfer points and encl osed conveying systems must be vented to a permitted and operated air pollution control device that meet the required standards.

Hexavalent Chromium Ambient Monitoring PAR 1156 would require the operator(s), no later than six months from compliance plan approval or March 1, 2010, whichever occurs first, to conduct 24-hour ambient air monitoring for hexavalent chromium once ever y third day according to the EPA 1-in-3-day sampling calendar. The sample may be co llected on the following business day if the collection occurs on a weekend or a facility-obs erved national and/or state holiday. The 30- day rolling average hexavalent chromium concen tration at each monitoring station shall not exceed 0.70 ng/m 3 , excluding background level of 0.16 ng/m 3 . This background inherently includes trip blanks of 0.08 to 0.10 ng/m 3

.

Any 30-day rolling average hexavalent chro mium concentration in exceedance of 0.70 ng/m 3 , excluding background level of 0.16 ng/m 3 , if deemed valid by examining wind monitoring data, would trigger a total enclosur e within 24 months from date of exceedance,Final Draft Staff Report for Proposed Amended Rule 1156

South Coast Air Quality Management District 14 March February 2009 or an incremental enclosure requirement over a four year period, for all clinker storage and handling. If an incremental enclosure is c hosen, 25% of the facility’s five-year annual average clinker material stored, by weight, must be enclosed no later than 12 months from date of exceedance, and an incremental 25% per subsequent year until all material is enclosed. It is important to note that hexa valent chromium monitoring according to this schedule shall be maintained, and that control measures such as chemical dust suppressants, wind fences/barriers, or tarps shall be us ed until the completion and operation of the

enclosure.

The operator(s) would be able to conduct 24-hour hexavalent chromium sampling once every six days if there is no exceedance of the 0.70 ng/m 3 level , excluding background of 0.16 ng/m 3 , during the first twelve (12) continuous months of monitoring. While on the less frequent compliance schedule, a 90-day rolling average would be used. The operator(s) may continue this less frequent monitoring sche dule if there is no exceedance of the 0.70 ng/m 3

level . Otherwise, the operator(s) shall incremen tally enclose their open clinker storage and handling at 25% per year until completion pursuant to the schedule explained earlier, or totally enclose those operations/activities within 24 months of exceedance, and immediately revert back to the previous once-in-three-days monitoring schedule while maintaining control measures until completion and operation of the enclosure.

In the event of a hexavalent chromium exceed ance when there is no openly stored clinker material, the AQMD will conduct necessary studi es to identify the source(s) and take necessary mitigative actions.

Derivation of Hexavalent Chromium Level Following is a summary of why the 0.7 ng/m 3 level is proposed and how it was derived:

The 0.70 ng/m 3 represents a concentration level at the receptor, that if exposed continuously for 70 years would pose a 100-in-1-million cancer risk. Staff selected 100-in-1-million as

the cancer risk level in PAR 1156 for the nearest sensitive receptor as it is the significant risk level under Rule 1402 – Control of Toxic Air Contaminants from Existing Sources.

The 0.7 ng/m 3 level was based on analysis of the nearest receptors to the two cement manufacturing facilities as described below. Th is value has a greater than 99% statistical confidence level in that there would be a signi ficantly less than 1% chance that the risk due

to hexavalent chromium would come from a source other than a cement manufacturing facility.

In deriving this level, staff first identified an emission point, which is the finish mills area at TXI and open clinker storage area in front of th e clinker barn at CPCC; then, staff conducted a model with site-specific information to the n earest receptors. Staff evaluated the decay in concentrations for TXI and CPCC, using SCR EEN3, an USEPA dispersion model. Staff selected the 0.7 ng/m 3 to represent a 100-in-1-million can cer risk at fence line to be protective of the nearest receptors. Sensitiv ity modeling demonstrated that source type (volume vs. area source of which clinker materi al storage and handling could be considered)

has little effect on the rate at which the con centrations decrease downwind. Therefore, to ensure public health protection, staff proposes to establish a fence-line hexavalent chromiumFinal Draft Staff Report for Proposed Amended Rule 1156

South Coast Air Quality Management District 15 March February 2009 level of 0.7 ng/m 3 . This level represents exposure due to the facility and excludes background levels.

Hexavalent Chromium Background Staff believes the proper background deduction should be based on the two-year sampling effort (from 2004 to 2006) of the most curre nt multiple air toxics study (MATES III) in which the Basin-wide average level of hexa valent chromium, excluding readings from Rubidoux, is 0.16 ng/m 3

.

The 0.16 ng/m 3 level was derived from the 30-day rolling average ambient air concentrations

of hexavalent chromium from the monitori ng stations across the Basin (excluding the Rubidoux station) as depicted in Figure 4. Rubidoux station was excluded from the

derivation as its hexavalent chromium r eadings are likely influenced by the cement manufacturing facilities.

MATES III samples were collected and analyzed on a one-in three-day basis, and thirty-day rolling averages were calculated on a site-by-site basis. A minimum requirement of 7 days of valid data (70%) was used to produce valid 30-day averages. Data from nine of the ten

fixed-sites in MATES III were combined in the analysis. There are no known stationary

sources of hexavalent chromium in the imme diate vicinity of the two cement manufacturing facilities. Therefore, the data represent a robust data set of typical basin-wide background hexavalent chromium levels, as well as the expected variability in those levels.Final Draft Staff Report for Proposed Amended Rule 1156

South Coast Air Quality Management District 16 March February 2009 0 50 100 150 200 250 300 350

0 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8

30-Day Rolling Average Cr6+ ConcentrationsFrequency of Occurance

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Frequency

Cumulative %

Figure 4 - All MATES III Fixed-Site Data Excluding Rubidoux (Nine Sites, 2004-2006)

Statistical Analysis A greater than 99% statistical confidence leve l means a significantly less than 1% chance

that the risk due to hexavalent chromium would come from a source other than a cement manufacturing facility.

The methodology for this statistical analysis follows:

The data used for the statistical analysis were based on the two-year sampling effort of MATES III, excluding readings from the Rubidoux station. The data used to measure the background levels of hexavalent chromium in the basin are a 30-day moving average of the

levels recorded at each of nine MATES III monitoring stations. Each 30-day average is recorded as a single data point and taken to be an accurate reflection of the background emission level over that 30-day period. This analysis of MATES III data generated a sample size of approximately 2,300 measurements towards background level. The minimum background level in the sample is 0.027 ng/m 3 and the maximum level is 0.62 ng/m 3 . The data approximate a lognormal density func tion, which is the starting point for the

calculations that followed.Final Draft Staff Report for Proposed Amended Rule 1156

South Coast Air Quality Management District 17 March February 2009 The estimates in Table 2, below, were calcu lated using the described methodology: The emissions data were transformed using the l og function, the resulting transformed data were used to calculate the sample mean and sample standard deviation, the mean and standard

deviation were used to calculate the Z-score fo r the specific log-transformed level level, and the resulting Z-score was used to calculate the probability (P-value) that a level greater than

the level level would be observed.

Table 2 Lognormal Statistical Results

Level (ng/m 3 ) Log (Level) Zscore P-value

0.40 -0.916 1.945 0.026

0.50 -0.693 2.360 0.009

0.60 -0.511 2.699 0.004

0.70 -0.357 2.985 0.001

0.80 -0.223 3.234 0.0006

0.90 -0.105 3.453 0.0003

Interpreting the results of the statistical anal ysis from Table 2, the likelihood that a rolling average would exceed 0.7 ng/m 3 and come from a source other than the cement plant would be one-tenth of one percent.

PM10 Monitoring Any exceedance of PM10 upwind/ downwind level of 50 μg/m 3 as measured by specified sampling requirements in Rule 403 – Fugitive Du st, would require the operator(s) to take steps to reduce clinker dust emissions, as we ll as apply dust suppressant on their openly stored non-clinker materials, unpaved roads, and unpaved areas.

If the aforementioned PM10 level is violated three or more times within a 36-month period, PAR 1156 would require an amended complian ce monitoring plan, and on-site continuous, real-time ambient air monitoring for PM10 within six months from the date of amended plan approval or one year from the date of the third approved notice of violation, whichever

occurs first.

Compliance Monitoring Plan PAR 1156 would require the operator(s) to s ubmit a compliance monitoring plan for the monitoring and sampling analysis of hexava lent chromium and wind monitoring, and pay fees pursuant to Rule 306 no later than three months from date of rule adoption. The plan will be approved or disapproved by the AQMD with in 60 days from the plan submittal date. The operator is responsible to resubmit an approva ble plan within 30 days from date of plan disapproval; otherwise, the operator is deemed in violation of the rule. Hexavalent chromium monitoring would be required no later than six months from compliance plan approval or March 1, 2010, whichever occurs firs t. Wind monitoring is required six months from date of adoption.Final Draft Staff Report for Proposed Amended Rule 1156

South Coast Air Quality Management District 18 March February 2009 In addition to any relevant data and inform ation required by the AQMD, at a minimum, the plan shall contain the following:

• Siting and monitoring protocols that comply with EPA’s and CARB’s guidance and/or protocols for measurement of hexavalent chromium, wind direction, and wind speed. PAR 1156 would require a minimum set of th ree fence-line monitors for hexavalent chromium: one upwind and one downwind of the facility under the common prevailing wind directions, and one subject to a pproval by the AQMD to ensure maximum effectiveness of the monitoring to the most potentially affected receptor, such as nearest residential or business receptors relative to clinker storage areas or potential hexavalent chromium emitting sources.

• Breakdown provisions which include: (1) a policy for breakdown notification for monitors to the AQMD within 24 hours of its occurrence; (2) a repair schedule; and (3) an action plan with detailed measures to be taken by the operator(s) to ensure there will be at least 70% data capture at each site by each monitoring system. In the event the breakdown occurs on a Friday, holiday, or weekend, such breakdown should be reported on the following business day.

• Operator’s consent allowing the AQMD to conduct any co-located and audit sampling at any time. The operator(s) of a cement manufacturing facility are also required to

allow District staff unlimited access to the f acility’s monitoring sites at any time, and provide District staff with su fficient power so that co-located PM10 and/or hexavalent chromium monitors can be set-up and sampling and/or auditing can be conducted as

necessary.

• Sampling analysis protocols that comply with EPA and/or CARB’s appropriate guidance and/or protocols for hexavalent chromium. PAR 1156 would require that all samples are analyzed at an AQMD-approve d laboratory, which can be audited any

time. If there is no approved laboratory, the AQMD may grant approval of the testing procedures currently used by the labor atory on a case-by-case basis, based on appropriate AQMD protocols and procedures. If such an approval does not occur, the AQMD will provide the sample analysis for hexavalent chromium.

• Other relevant data and information required by the AQMD.

The operator may file for a Compliance Monitori ng Plan amendment in the future relative to monitor siting or other elements of the plan as more site-specific data becomes available.

In the event where continuous, real time ambien t monitoring for PM10 is required as a result of three violations of Rule 403 upwind/downw ind limit, the operator(s) must amend their Compliance Monitoring Plan to include appr opriate plan elements relative to PM10 monitoring. The amendment must be filed within 90 days of the date of the third approved notice of violation. The monitoring equipmen t must be installed and operated within 6 months from the date of plan approval, or one year from the date of the third approved notice of violation, whichever occurs first.Final Draft Staff Report for Proposed Amended Rule 1156

South Coast Air Quality Management District 19 March February 2009 Wind Monitoring Wind monitoring is required six months from date of adoption. PAR 1156 would require the operator(s) to install equipment and conduct hourly wind monitoring according to an AQMD approved protocol no later than six months from date of rule adoption. In addition, the proposed amendment would also call for a two-hour halt to all clinker handling activities in the open if instantaneous wind speeds exceed 25 miles per hour (mph). If instantaneous wind speeds subsequently exceed 25 mph, a ne w two-hour period shall begin. During the aforementioned two-hour period, the facility woul d be exempt from the 100-feet visible dust plume limit, provided that the open handling of clinker material is ceased, dust controls as required by the AQMD are applied, and unpaved roads within the facility are stabilized.



### Subdivision (h) - Exemptions

Operators who have open piles containing material s other than clinker would be exempt from the requirement of enclosure or three-sided barrier, or from using the AQMD Rule 403 test methods for the demonstration of pile’s surf ace stabilization, if the materials contained in 90% of the piles’ mass (instead of volume) are larger than 1⁄2 inch (paragraph (h)(1)). Applicability of this exemption must be determined through the measurement of any composite sample of at least 10 pounds taken at a minimum depth of 12 inches below the pile surface, from various locations on the pile, but not from within 12 inches from the base of the pile, to ensure adequate sampling. This cha nge is being proposed to better provide guidance on sampling and to improve the effectiveness of the exemption.

In high wind days, cement manufacturing operato r(s) can be exempt from the hexavalent chromium and PM10 averaging provisions in the proposal, provided that all handling of clinker materials in the open is ceased and dust controls are applied. As a result, the operator(s) can exclude hexavalent chromium and PM10 ambient air concentrations detected during high wind days from their 30-day or 90- day rolling average. Appropriate records required by PAR 1156 must be kept . However, in the event the Executive Officer determines there is a significant hexavalent chromium dust re-entrainment potential, the operator(s) would be required to implement a Mitigation Mon itoring Plan that is approved by the District to minimize exposure to the surrounding areas and to ensure implementation of all applicable

dust controls (e.g., piles, road, and soil stabilization pursuant to Rule 403)

. If it is determined that a significant hexavalent chromium dust re-entrainment exists, the Executive Officer will conduct a management review prio r to requiring a plan submittal. Such a

determination will be , in part, based on wind data, and ambient as well as soil samples.

Cement manufacturing operator(s) can be exem pt from the wind fence requirement during periodic maintenance of the clinker crane or st orage barn, provided that clinker crane is not operated except for post maintenance equipment testing.



### Other

Relative to this provision, an amendment is also proposed to the definition of Cement Manufacturing Facility to clarify that even though TXI is not currently manufacturing cement products, they are not immune from th e monitoring requirements (wind, hexavalent chromium, and PM10, as applicable) of the proposal.Final Draft Staff Report for Proposed Amended Rule 1156

South Coast Air Quality Management District 20 March February 2009 In addition, the proposed amended rule also contains other minor amendments and

clarifications to better demonstrate the rule ’s intent and to respond to USEPA comments on

other elements of the rule.



### EMISSIONS AND EMISSION REDUCTIONS

Since TXI no longer stores and handles clinker material in the open, the emissions inventory and reduction estimated herein are only for CPCC.

According to staff estimates, emissions from clinker storage and handling activities are 0.08 tpd for PM10 and 0.16 tpd for PM. This emissi ons inventory is consistent with CPCC’s estimates. The majority of existing emissions are from the storage and handling of clinker

material. The current control for these activitie s is a 3-sided barrier with a roof at 75% control efficiency (CE). Low emissions come from wind erosion and traffic around the piles because most of these emissions are controlled with chemical dust suppressants (at 80% CE) and tarping (at 60% CE).

Based on the current proposed amendment for c linker material storage and handling, and the assumptions that the existing barn enclosed w ith wind fencing would achieve an 85% CE and that wind fencing in addition to tarping woul d result in an 80% CE, staff has estimated reductions of 0.04 tpd for PM10 and 0.09 tpd for PM . If total enclosure is required due to monitoring violations, the reductions would be 0.07 tpd for PM10 and 0.16 tpd for PM.



### COSTS AND COST-EFFECTIVENESS

The present value of control cost for PAR 1156 as originally proposed in July 2008, which included total enclosure of all clinker storag e and handling, was estimated to be between $9.5
to $12 million. This cost include d the cost of domes at $38/ft 2 to $46/ft 2

, the annual operating and maintenance (O/M) costs, and th e savings from not applying chemical dust suppressant and tarp required by current Rule 1156. The estimated cost-effectiveness based

on Discounted Cash Flow method for the to tal enclosure would be $8,000 to $10,000 per ton of PM reduced and $18,000 to $22,000 per ton of PM10 reduced, assuming a 20-year equipment life. CPCC estimated that it w ould cost approximately $21 to $24 million to comply with the proposed amendments introduced in July 2008 that required total enclosure. The proposal at this time did not include a monitoring component, which was added when the proposal was revised and as discussed below.

Based on the current proposed amendments to Rule 1156, which allows alternative control options for clinker material storage and hand ling located at more than 1,000 feet from the property line, staff has estimated the present value of control cost of PAR 1156 to be $2.6 million, and the cost-effectiveness to be $9,000 per ton of PM10 reduced, providing that ambient air monitoring for PM10 is not need ed. Including PM10 monitoring, the control
cost would be $3. 6 9 million, and the cost-effectivene ss would be $13,000 per ton of PM10

reduced. The control costs account for the di scounted present value capital costs assuming a 20-year life equipment, O/M costs, and the savings from not using dusts suppressants to reduce traffic emissions around the clinker piles. The capital cost includes: (1) wind fence at
$15/ft 2 ; (2) tarp at $0.12/ ft 2 ; (3) continuous monitoring system for PM10 at $23,000 each, if required; (4) multi-chamber hexavalent ch romium monitoring system at $21,000 each; andFinal Draft Staff Report for Proposed Amended Rule 1156

South Coast Air Quality Management District 21 March February 2009 (5) wind monitoring systems at $10,000 each. The O/M costs include: (1) hexavalent chromium analysis at $100 per sample; (2) O/ M costs for the clinker barn due to wind fencing, assuming that the O/M costs are 5% of the wind fence costs; and (3) O/M costs for the monitoring systems, including sample collection. The monitoring O/M costs range from $82,000 (if PM10 monitoring is not needed) to $164,000 (if PM10 monitoring is required). In addition to the aforementioned costs, mon itoring plan submittal and review costs pursuant to Rule 306 - Plan Fees - includes a minimum of approximately $500 plus additional cost for staff time, if needed to evaluate the plan.

CPCC provided information that estimates th e control costs to be $3.6 million and the resulting cost-effectiveness would be a pproximately $12,000 per ton of PM10 reduced, providing that ambient air monitoring for PM 10 is not needed. Including PM10 monitoring, CPCC estimated control costs to be upwards of $4.9 million, and the cost-effectiveness to be $17,000 per ton of PM10 reduced.

The following table summarizes the estimated capital and O/M costs of each major rule provision that one or both of the facilities are e xpected to follow. These costs are compared to data/information provided by the primarily affected facility (CPCC).

Table 3

Estimated Costs

Staff Estimated Costs ($) Industry Estimated Costs ($) Alternative Control Options (More than 1,000 feet from property line) Wind fences & tarps 548,000 1,049,000

Hexavalent chromium monitors (three for each facility) 126,000 ---

PM10 monitors (three for each facility and if applicable) 138,000 ---

Wind monitors (for both facilities) 20,000 ---

Dust suppressants (as savings) 10,000 ---

Hexavalent chromium analysis (for both facilities at $100/sample) 24,000 24,000

O/M costs at clinker barn 4,000 15,000

O/M costs for PM10 and hexavalent chromium monitors (for both facilities and if applicable) 84,000 (without PM10) and 164,000 (with PM10) ---

Plan fees (for both facilities) 1,000 1,000



### CALIFORNIA ENVIRONMENTAL QUALITY ACTFinal Draft Staff Report for Proposed Amended Rule 1156

South Coast Air Quality Management District 22 March February 2009 In accordance with the California Environmenta l Quality Act (CEQA), the South Coast Air Quality Management District (SCAQMD) is the Lead Agency for PAR 1156 pursuant to its certified regulatory program (SCAQMD Rule 110). A Final Environmental Assessment (EA) (SCAQMD No. 050307JK, dated October 13, 2005) was previously prepared pursuant to CEQA, which identified “air quality” as th e only environmental topic that might be adversely affected by the current rule. Since the currently proposed project would be within the scope of what was analyzed in the previ ous Final EA that was circulated for public review and comment and subsequently certified, SCAQMD will rely on that previously certified Final EA for the currently proposed project pursuant to CEQA Guidelines §15153, because the circumstances of the projects ar e essentially the same. Greenhouse gases and PM2.5 analyses were not prepared as part of the Final EA, but were evaluated and found not to be significant in an Initial Study (IS) prepar ed for the proposed project (CEQA Guidelines §15153(c)). Since the circumstances of the cu rrently proposed project are essentially the same as those analyses in the October 13, 2005 Final EA, and the greenhouse gases and PM2.5 impacts were concluded to be less than significant, no additional reasonable alternatives or mitigations are required. A Notice to Rely on the October 13, 2005 Final EA was circulated pursuant to CEQA Guidelin es §15087 and the October 13, 2005 Final EA was made available for public review and comment on the environmental analysis for a 45-day period from July 1 5, 2008 to August 28, 2008 and no comments were received. A single comment was received on the IS asking for clarification on the PM2.5 analysis. The comment and response to comment is included as an appendix to the IS.

Two comment letters were received from CPCC on PAR 1156. In these letters, the CPCC representative stated that the CEQA analysis of PAR 1156 should have included an analysis of the closure of cement manufacturing operation and its conversion to a storage and transfer facility for cement manufactured at other f acilities. However, PAR 1156 is designed to control PM emissions from cement manufacturing facilities, not to permanently stop cement manufacturing operations at any affected facilit y. Modifications have been made to PAR 1156 to address CPCC’s concerns. In addition, a socioeconomic analysis has been prepared that concludes that the cost of PAR 1156 requirements is reasonable. Since, PAR 1156 is not intended or designed to stop cement manufacturi ng operations, the alternative to permanently stop cement manufacturing operations was not analyzed.

Staff has reviewed the modifications made to PAR 1156 since the circulation of the Notice to Rely and the October 13, 2005 Final EA for public review and concluded that they would not generate environmental impacts that w ould exceed those evaluated in the October 13, 2005 Final EA. The proposed project in the October 13, 2005 Final EA included the construction of three-sided enclosures, wind fe nces and the use of tarping. The proposed project assumed that one full enclosure woul d be constructed at both the TXI and CPCC sites. No clinker enclosures would be require d at TXI, since TXI no longer stores clinker per a memorandum of understanding with SCAQMD.

The adverse impacts from the construction of one full enclosure at each facility would be the same as two full enclosures at a single aff ected facility. Since no more than two full enclosures at CPCC would be expected b ecause of PAR 1156, the proposed full enclosure requirements would have adverse environmenta l effects similar to the proposed project evaluated in the October 13, 2005 Final EA.Final Draft Staff Report for Proposed Amended Rule 1156

South Coast Air Quality Management District 23 March February 2009 Since no comments were received that change d any conclusions from the October 13, 2005 Final EA or the IS prepared for PAR 1156, SCAQMD staff will continue to rely on the October 13, 2005 Final EA as the CEQA document for the proposed project.



### SOCIOECONOMIC ASSESSMENT

Staff has conducted a socioeconomic assessmen t on the final proposal for public review, which was made available 30 days prior to the public hearing.



### DRAFT FINDINGS

Health and Safety Code Section 40727 requi res the AQMD to adopt written findings of necessity, authority, clarity, consistency, non-duplication and reference.

Necessity
A need exists to amend Rule 1156 to ensure that fugitive dust and hexavalent chromium emissions from the storage and handling of cli nker and non-clinker materials are minimized.

Authority The AQMD Governing Board obtains its author ity to adopt, amend, or repeal rules and regulations from California Health & Safety Code Sections 39002, 40000, 40001, 40702, and 40725 through 40728, and 41700, inclusive.

Clarity The proposed amended rule has been written or displayed so that its meaning can be easily understood by persons directly affected by it.

Consistency The proposed amended rule is in harmony with and not in conflict with or contrary to, existing statutes, court decisions or state or federal regulations.

Non-Duplication The proposed amended rule does not impose the same requirements as any state or federal regulations. The amendment is necessary and proper to execute the powers and duties granted to, and imposed upon, AQMD.

Reference By adopting the proposed amended rule, the AQMD Governing Board will be implementing, interpreting, and making specific the provisions of the California Health & Safety Code Sections 40000 (authority over non-vehicular s ources), 40001 (rules to achieve ambient air quality standards), and 41700 (public nuisance).



### ALTERNATIVE CONTROL MEASURES

Health and Safety Code Section 40440.5, subsection (c)(3) requires an analysis of alternative

control measures. Staff conducted such an anal ysis for public review. Staff did not pursue their original proposal (July 2008) of total en closure due to comments of severe economic hardship. The revised proposals herein were developed.Final Draft Staff Report for Proposed Amended Rule 1156

South Coast Air Quality Management District 24 March February 2009 

### COMPARATIVE ANALYSIS

Health and Safety Code §§40727.2 requires a writte n analysis comparing a proposed rule or amendment with existing federal, State and Dist rict regulations. Health and Safety Code §§40727.2, subsection (c) and (d) further require the analysis to review averaging provisions, operating parameters, work practice requi rements, and monitoring, reporting and recordkeeping requirements associated with existing applicable rules and proposed regulations. A comparative analysis for the adoption of Rule 1156 in 2005 was conducted and is included in Appendix C. The comparative analysis contains italicized text to reflect the current staff proposal.



### CONCLUSION

The current proposed amendments would reduce pa rticulate as well as hexavalent chromium fugitive dust emissions generated from the storage and handling of clinker material.

PAR 1156 would achieve reductions of 0.04 tpd for PM10 and 0.09 tpd for PM at a cost estimated to be in the range of $2. 5 6 to $3. 5 6 million, providing that ambient air monitoring for PM10 is not needed. Including PM10 monitoring, the cost would be $ 2.7 3.9 to $ 3.7 4.9 million. Without PM10 monitoring, the cost-effectiveness would be $ 8, 5 00 9,000 to 12,000 per ton of PM10 reduced. If PM10 monitoring is triggered, the cost-effectiveness would be
$ 9 13 ,000 to 17 13 ,000 per ton of PM10 reduced.

PAR 1156 would increase public health protec tion through additional fugitive dust control measures and ambient monitoring efforts.



### REFERENCES

AQMD, 2005. Final Staff Report on Proposed Ru le 1156 - Further Reductions of Particulate Emissions from Cement Manufacturing Facilities. November 2005.

AQMD, 2005. Final Environmental Assessment, Proposed Rule 1156 - Further Reductions

of Particulate Emissions from Cement Manufacturing Facilities. SCAQMD No. 050307JK, dated October 13, 2005.

AQMD, 2008. Attachment 1 from Dr. Barry W. Wallerstein’s letter to the public dated May 6, 2008.Final Draft Staff Report for Proposed Amended Rule 1156

South Coast Air Quality Management District A-1 March February 2009 APPENDIX A

RESPONSE TO COMMENTS

Response to Comment for the Public Review Period Ending December 12, 2008

___________________________________________________________________________Final Draft Staff Report for Proposed Amended Rule 1156

South Coast Air Quality Management District A-2 March February 2009 The following are comments and responses on the revised amendment to Rule 1156 that was released for public review in November 2008 a nd for which a Public Consultation meeting was held on November 20, 1008. The public review and comment period ended on December 12, 2008. These responses are relative to the curre nt proposal. Comments from US EPA and CARB are included below. (Note: at the end of each co mment, in parenthesis, is the originator of the comment).

Agency Comments

Comment #1: We support the District’s efforts to reduce exposure to particulate matter and hexavalent chromium from cement manufacturing facilities. We encourage the District to speak with other Calif ornia agencies (e.g., the Monterey Bay Unified APCD) that are also trying to address hexavalent chromium emissions

from similar sources. We do not curren tly believe there are any approvability issues with the rule. (US EPA)

Response #1: Staff appreciates the support of U.S. EP A, Region IX. Staff has been engaged with other air districts regarding re gulatory efforts at cement manufacturing plants under their jurisdiction. The collaboration has been helpful.

Comment #2: For haul roads, clause (d)(7)(A)(i ) requires that chemical dust suppressants be applied twice a year, that signs be poste d at the two ends stating that haul trucks use these roads unless traveling to maintenance areas, and that a speed limit of 35 mph or less be enforced. For other unpaved roadways and areas, clause (d)(7)(A)(ii) requires that chemi cal dust suppressants be applied twice a year or that a gravel pad be applied, and that a speed limit of 15 mph or less be enforced. However, haul roads do not seem to be defined in Rule 1156.

Please insert a definition for haul road in order to ensure that the requirements in (d)(7)(A)(i) and (d)(7)(A)(ii) are enforceable. (US EPA)

Response #2: A clarification has been added in clause (d)(7)(A)(ii), consistent with the definition in Rule 1157, for moving mate rial from the quarry to different locations within the facility. Staff w ill consider a specific definition in a

future amendment.

Comment #3: In addition to meeting other require ments, clause (d)(7)(A)(ii) allows sources to comply by applying a “gravel pad c ontaining 1-inch or larger washed gravel to a depth of six inches.” We recommend including the additional requirements for gravel pads that can be found in subparagraph (d)(1)(E) of District Rule 1157 for a geotextile lining underneath the washed gravel and for the gravel pad to be flushed with water or completely replaced as necessary to comply with the track out level set forth in Rule 403. (US EPA)

Additionally, subparagraph (d)(8)(B) states that “If necessary to comply with the opacity limits in paragraph (d)(1), th e operator shall install a rumble grate, truck washer, or wheel washer; and en sure that all trucks go through the rumble grate, truck washer, or wheel washer such that the entire

circumference of each wheel or truck is cleaned before leaving the facility.”Final Draft Staff Report for Proposed Amended Rule 1156

South Coast Air Quality Management District A-3 March February 2009 In addition to having opacity limits that sources must comply with, District Rule 1157 requires that facilities insta ll and utilize a rumble grate, truck washer, or wheel washer. Moreover, subparagraphs (d)(8)(C) and (d)(8)(D) of Rule 1157 have more specific require ments, including where rumble grates and wheel washers should be located, and for a sign to be posted near the rumble grate, wheel washer, or truck wa sher to designate the speed limit to be 5 mph for using such control equipmen t. We recommend inserting similar requirements into subparagraph (d)(8 )(B) of 1156 in order to further strengthen the rule. (US EPA)

Response #3: Given the requirement that a minimum of 0.25 mile of internal roads must be paved pursuant to subparagraph (d )(8)(A) at both cement manufacturing facilities prior to accessing any public roadway, staff does not believe the additional requirements are necessary at this time. Staff will, however, consider these additional requirements in a future amendments to Rule 1156. In addition, were the language to be added, it would likely constitute new

information that was not taken into consideration and through the public review process.

Comment #4: Section (h)(4) exempts the operator from the use of chemical dust suppressants in clause (d)(7)(A)(ii) where a road is used less than a monthly average of twice a day by a designated vehicle at a speed limit less than 15 miles per hour. Please add corresponding recordkeep ing requirements to the rule to ensure that this provision is enforceable. (US EPA)

Response #4: The recordkeeping requirement has been added to subparagraph (f)(2)(J).

Comment #5: Subparagraph (d)(5)(c)(ii) allows for cli nker to be stored outside a three-sided barrier if there are space limitations inside the structure caused by “operational constraints”. This latter term is not defined in the rule, nor is any further clarification of this term provide d in the rule. We suggest that this

issue be addressed at least for the bene fit of enforcement staff and affected facility operators in an advisory notice if not defined in the rule. (CARB)

Response #5: As the key element of this subparagr aph for requiring wind fencing and tarps

on clinker material stored outside of th e three-sided relative is due to “space limitations”, the clarifier of “caused by operational constraints” is not necessary in the rule. It has been deleted, although for clarification purposes it remains in the staff report descriptive text regarding the explanation of the proposed added rule language. That is, the excess clinker due to production may require storage of clinker outside of the structure.

Comment #6: Subparagraph (d)(5)(c)(iii) requires one side of the three-sided enclosure to face the prevailing wind. An operator may be able to interpret this to allow for the open side to face the wind, which is contrary to the intent of this design. We recommend the District rewr ite the section to require that theFinal Draft Staff Report for Proposed Amended Rule 1156

South Coast Air Quality Management District A-4 March February 2009 open side not face the prevailing wind direction to eliminate this erroneous interpretation. (CARB)

Response #6: Clarifying language has been added to the rule to state that one side “of the wind fence” shall face the prevailing wind direction.

Comments on Proposed Amended Rule Language

Comment #7: The rule applicability should be revise d to exclude the aggregate operations and equipment subject to 40 CFR Pa rt 60 Subpart OOO, and include only operations and equipment subject to 40 CFR Part 63 Subpart LLL and 40 CFR Part 60 Subpart F. As a result, amended rule 1156 should only apply to equipment/operations starting from the su rge bin immediately prior to the raw milling. (CPCC)

Response #7: An amendment to the rule is unnecessary. To clarify, however, Rule 1156 begins at CPCC upon the transfer of mate rials into the blending silos, which are either proportioned into the feed bin for the raw mills, or directly to the finish mills. As stated in exemption paragraph (h)(6), “With the exception of primary crushing, open material storag e piles, and covers and existing enclosures for conveying systems...”, th e provisions of this rule shall not apply to equipment or operations that are subject to Rule 1157 or Rule 1158. Therefore, with consideration of thos e exemptions, Rule 1156 begins at the blending silos and its associated contro l devices, and thereafter in the cement manufacturing process.

Comment #8: Staff cost estimates are low. Facility ’s new cost data will be submitted. (CPCC)

Response #8: Staff is confident that their estimates are reasonable since they are based on current cost information provided by ma nufacturers and distributors; however, staff has also included the facility provided cost data in their analysis. Therefore, the cost and cost-effectiven ess associated with this rule are represented as a range.

Comment #9: Amended Rule 1156 should allow for the removal of the wind fence from the clinker barn to accommodate the equipment maintenance. (CPCC)

Response #9: The rule language has been modified to allow such maintenance activities.

Comment #10: The deadline to submit the Compliance Monitoring Plan should be revised to 6 months instead of 2 months from date of adoption. (CPCC)

Response #10: Staff is committed to working with both facilities to help facilitate preparation of the compliance monitoring plan. Staff revised the plan submittal deadline

to 3 months from date of rule a doption, and extended installation of the monitoring network to 6 months fr om compliance plan approval or 03/01/2010, which ever occurs first.Final Draft Staff Report for Proposed Amended Rule 1156

South Coast Air Quality Management District A-5 March February 2009 Comment #11: CPCC opposes the proposal that they w ill be subject to an interim plan if their submitted compliance plan is re jected and an approvable plan is not resubmitted. (CPCC)

Response #11: Staff revised the rule language so that a violation would occur if an approvable plan is not resubmitted within 30 days from plan disapproval.

Comment #12: Breakdown provisions should be revised to allow facilities 72 hours from discovery (instead of “24 hours of its occurrence”) to report a breakdown of the ambient monitoring equipment. (CPCC)

Response #12: Staff revised the rule language so that if a breakdown occurs on a Friday, over a weekend, or on a facility-observed national and/or state holiday, the breakdown may be reported on the following business day.

Comment #13: CPCC raised concerns regarding AQMD lab certification process and the availability of an AQMD-approved lab for hexavalent chromium analysis. (CPCC)

Response #13: Staff is working with the facility to id entify acceptable laboratory and is confident that the certification process will be completed well in advance of the rule compliance date. If that does not occur, the AQMD lab can provide

that service.

Comment #14: Trip blanks should be subtracted fr om hexavalent chromium sampling and analysis, and background concentra tions should be deducted from upwind/downwind concentration levels. (CPCC)

Response #14: The proposed rule language has been revised to reflect the 0.70 ng/m 3 level, excluding background. Since trip blanks are inherently included in the background, subtracting trip blanks would be double counting. The background for the purposes of Rule 1156 will be 0.16 ng/m 3 hexavalent chromium, based on the 2-year MATES III monitoring efforts. As described in the staff report, this data is from 9 fixed sites, excluding Rubidoux, and is comprised of approximately 2,300 data points evaluated on a 30-day average as in the proposed rule amendment.

Comment #15: If monitoring shows hexavalent chromi um levels above the rule level, a toxic reduction plan should be implemented instead of enclosure, particularly in the

event hexavalent chromium is not from clinker. (CPCC)

Response #15: A toxic risk reduction plan would take a long time to develop, review, approve, and be implemented. Since exte nsive sampling indicates that clinker dust contributes to ambient hexavalent chromium concentrations, enclosure would be an appropriate control strategy in the event the hexavalent

chromium level established in the rule is exceeded.Final Draft Staff Report for Proposed Amended Rule 1156

South Coast Air Quality Management District A-6 March February 2009 Comment #16: The requirement of incremental enclos ure (in the events of hexavalent chromium exceedance) is not feasible or cost-effective, and total enclosure would result in facility shut down. (CPCC)

Response #16: The facility must take all necessary pr eventive steps and at a minimum, those established in the rule, to ensure that the hexavalent chromium level is not exceeded and the public is not exposed to undue risk. Staff added an alternative so that facility may select total enclosure within 24-months or incremental enclosure over 4 years.

Comment #17: PM10 monitoring is not justified and should only be required in the event of recurrent Notices of Violation on a 12-month rolling average. (CPCC)

Response #17: PAR 1156 has been revised to require such monitoring in the event of three

verified violations of the Ru le 403 upwind/downwind ambient air concentration level (50 μg/m 3 ) over a 36-month period. Upon the third verified violation, the facility would have 90 days to file for a modification to their Compliance Monitoring Plan. The monitoring equipment would be required to be installed and operated with in 6 months from the date of plan approval or one year from the date of the third approved notice of violation,

whichever occurs first.

Comment #18: The method of PM10 measurement and PM10 upwind/downwind

concentration levels should be ba sed upon the results of the AQMD’s ongoing study. (CPCC)

Response #18: The method of PM10 measurement is c onsistent with EPA and CARB’s guidance, including use of continuous and real-time monitors. As mentioned in the response to the previous comment, PAR 1156 has been modified.

Comment #19: A sunset date should be include d in PAR 1156 in the events that no

hexavalent chromium exceedance of the level specified in the proposed rule occurs in a 3-year period. (CPCC)

Response #19: It is important to continue hexavalent chromium monitoring to ensure continued public health protection. PAR 1156 contains a provision to reduce the 1-in-3-day monitoring to 1-in-6-d ay monitoring schedule if there is no single exceedance of the 0.70 ng/m 3 level at any station (excluding background and based on a 30-day rolling average) during the first 24 months of monitoring, which was revised to the first 12 continuous months of monitoring in the most recent revised rule proposal. Nevertheless, a

resolution commitment will be has been drafted directing staff to report annually to the Stationary Source Committee regarding all monitoring

activities , including a reevaluation of the need for continued hexavalent chromium monitoring in the fifth year report

. Additionally, staff will provide biannual reports to the full Board.Final Draft Staff Report for Proposed Amended Rule 1156

South Coast Air Quality Management District A-7 March February 2009 Comment #20: The sampling schedule for hexavalent chromium should be changed to twice per week to reduce the need for pers onnel on weekends and holidays. Our facility has minimal operation on weekends or holidays. (CPCC)

Response #20: The one-in-three day sampling schedule is consistent with EPA sampling schedules and helps cover all days of the week, on a rotating schedule to characterize emissions more thoroughl y. The amended rule language has

been modified to reflect that the m onitoring schedule may change to 1-in-6 days in the event no exceedance of the 0.70 ng/m 3 level occur within the first twelve (12) continuous months. Also, sample collection that would have occurred on a weekend or a facility observed-and/or state holiday may take place the following business day. Studies have shown that sample collection one to three days after the 24-hour monitoring period would not result in any additional sample loss.

Comment #21: Wind monitoring provisions should be revised to allow for the resumption of clinker handling in the open after 2 hour s of a high winds event greater than 25 mph (instead of 24 hours). (CPCC)

Response #21: Staff has revised rule language to re quire a two-hour operation halt during a high wind event. If another wind gust gr eater than 25 mph occurs subsequent to the initiation of the first 2-hour halt, a new 2-hour period would begin.

Comment #22: Facilities should be exempt from vi sible emission standards in the event of high winds greater than 25 mph (similar to Rule 403) when clinker handling in the open is ceased. (CPCC)

Response #22: Staff has revised the rule language so th at the facility would be exempt from the requirement of 100-feet visible dus t plume limit, provided that the open handling of clinker material is ceased, so long as dust controls are applied, and unpaved roads within the facility ar e stabilized prior to the time of the high wind occurrence as required by this and other AQMD rules.

Comments on the Revised Preliminary Draft Staff Report

Comment #23: There is no justification that hexavale nt chromium monitoring is needed and evidence suggests that with the TXI se ttlement agreement, the concentration levels have dropped to background levels. (CPCC)

Response #23: The ongoing monitoring program ar ound the two cement manufacturing facilities has demonstrated, even recentl y, that the ambient levels have on occasion exceeded 1 ng/m 3 . Evaluation of wind data indicates that the reentrainment of hexavalent chromium lade n dust is originating from one of the two facilities. Therefore, due diligence to evaluate the source of the emissions and continued monitoring is warranted.Final Draft Staff Report for Proposed Amended Rule 1156

South Coast Air Quality Management District A-8 March February 2009 Comment #24: There is no discussion as to why a 24- hour sampling period at a frequency of 1 in three days is appropriate or releva nt. Why is such data better than once a week or once a month? (CPCC)

Response #24: The reader is referred to the response to Comment #20. In addition, the hexavalent chromium sampling timeframe and frequency is not only consistent with EPA sampling protocols, it has been used extensively by the District, such as in conjunction with the ambient monitoring efforts of MATES III. The frequency and sche dule of monitoring will provide information that is reflective of fluctuations in operating parameters and

conditions in and around the area. If 12 months of data is collected and the 30-day average of fence line monitoring is not exceeded, a one in six day schedule would be required.

Comment #25: There needs to be more discussion as to the derivation of the hexavalent chromium level of 0.7 ng/ m 3 and how it was determined that this level was appropriate. Specifically, what authority does the District have to set such a standard and what levels of safety were built into its development? Further,

who reviewed this standard and how does it relate to the state standard of 200 ng/m 3 , and how does it relate to the industrial occupational standard of OSHA? This standard appears arbitr ary and has not gone through a formal peer review process and the District does not have the authority to establish an ambient standard. (CPCC)

Response #25: The reader is referred to the additional write-up and information provided in the Staff report as to the derivati on and appropriateness of the 0.7 ng/m 3 level. The District does indeed have authority granted to it to derive and utilize such rule-based standard for local purposes to protect the public from undue risk. In the derivation, safe guards were used in that the level was derived in the absence of background and would account only for emissions from the facility contributing to such a concentration. In addition, the risk factors used are consistent with those established by th e state Office of Environmental Health Hazard Assessment (OEHHA) and adopted by the Scientific Review Panel. The standards referenced by the comme nter are workplace standards and not directly related to 0.7 ng/m 3 level, as it is a public health exposure level over a 70-year lifetime, not a short-term exposure level.

Comment #26: How is to be determined that the he xavalent chromium concentrations are coming from the facilities, particular ly if there is no recognition of background. The levels could be comi ng from other sources, such as a railway or freeway. Making the facility responsible for background concentrations and tying additional contro l measures to a standard is arbitrary and illegal. (CPCC)

Response #26: The proposal has been modified to re flect that the monitoring level excludes background and is discussed in detail in the staff report. If there were an exceedance, staff would conduct an eval uation using meteorological data toFinal Draft Staff Report for Proposed Amended Rule 1156

South Coast Air Quality Management District A-9 March February 2009 firmly establish if a facility was the source of the emissions resulting in the elevated concentrations. Only upon that determination would the facility be required to pursue enclosure of clinker material storage and handling.

Comment #27: The consequence of exceeding the hexava lent chromium level is too high, that is to spend millions of dollars for enclosures when the District’s monitoring data demonstrates that the problem has been solved. (CPCC)

Response #27: The modifications made to the propos ed rule amendment allow sufficient alternatives that would not require enclos ures unless all of the clinker material handling occurred within 1,000 feet of, and inside, the facility property line. Staff fully expects that both facilities will be able to demonstrate compliance with the newly established rule requirements using the alternative provisions, and does not expect that enclosure would be required up front for rule compliance. As discussed earlier recent monitoring data demonstrates the continued need for ongoing hexavalent chromium monitoring.

Comment #28: The staff report states that if the hexa valent chromium level is exceeded and no openly stored clinker material exis ts, then the District would conduct a study and implement mitigation measures. This is not in the rule and assumes clinker to be the only source, which is not the case. (CPCC)

Response #28: The commenter is correct that the s ource of hexavalent chromium monitored, although believed to primarily be from clinker material handling, may not specifically be from clinker material handling. It may come from unpaved roads or re-entrained fugitive dust from accumulated material. Case in point is the TXI facility, which no longer by settlement agreement, openly handles clinker material. Therefore, were the m onitor(s) at that facility’s fence line to detect elevated hexavalent chromium levels exceeding the 0.7 ng/m 3 , a study would be required to derive the source of the emissions and take mitigative action. This is explained in more detail in the staff report.

Comment #29: There is no justification as to why PM 10 monitoring is needed. It is neither practical nor workable. (CPCC)

Response #29: The rule has been modified to only require PM10 monitoring if the District

finds that on at least three occas ions the facility violates the upwind/downwind level level of 50 μg/ m3 established in Rule 403. The reader is referred to the response to Comment #17.

Comment #30: The efficacy of continuous ambient PM10 monitors has not been

demonstrated and there is no basis fo r using this as a compliance tool. (CPCC)

Response #30: The use of such continuous monitors for measuring PM10 has been occurring for years and they are a key tool us ed by air districts to demonstrate compliance with the federal ambient air standards and justify its status ofFinal Draft Staff Report for Proposed Amended Rule 1156

South Coast Air Quality Management District A-10 March February 2009 attainment status. Protocols for the us e of these continually operating devices have been developed and are being used by EPA, CARB, as well as numerous air districts throughout the state.

Comment #31: Continuous ambient monitors are not allowed under Rule 403 for evaluating upwind/downwind concentrations and should not be designated for use relative to the Rule 403 level of 50 μg/m3. (CPCC)

Response #31: The use of continuous PM10 monitors are indeed allowed under Rule 403 criteria; however, in evaluating the upwind/downwind concentration differentials, the District has histori cally used high-volume samplers. The Rule 403 methodology is currently under re view and changes to the rule or procedures may be made in the future.

Comment #32: It is not fair to require hexava lent chromium monitoring from cement manufacturing facilities and not of other higher polluting facilities, such as plating facilities. (CPCC)

Response #32: As specific industries have been identif ied that pose significant risks to the surrounding the community, it is not atypical to require specific ambient monitoring. For example, District Rule 1420 applicable to lead emitting sources. Monitoring is required under that rule, including submission of a compliance plan. In addition, other rules exist to specifically control air toxics from those sources (i.e., plating operations).

Comment #33: A statement by Dr. John Morgan, Professor of Epidemiology, and Biostatistics, School of Public Health, Loma Linda University that there are

no cancer clusters or increases in can cer detected in the areas around the plants have not been taken into account. This review of significant historic data should be considered as both plan ts have been around for years and one would think that if there were any can cer cases, these would have manifested themselves by now. (CPCC)

Response #33: It is very difficult to correlate cancer incidence with specific facilities. Given

the monitored levels from the MA TES III study and the recent localized monitoring efforts in the areas around the cement manufacturing facilities, future and continued exposures must be considered. From a public health standpoint, it is prudent to move forwar d to ensure these exposures are limited

to the extent feasible and future ri sks are avoided, even if the facilities

shutdown.

Comment #34: The definition of cement manufacturing within the rule would preclude TXI from being subject to the new rule requirements, as they do not manufacture cement anymore. Based on their current operations, they are only a cement transfer facility, subject to other requirements. (CPCC)Final Draft Staff Report for Proposed Amended Rule 1156

South Coast Air Quality Management District A-11 March February 2009 Response #34: The definition has been modified in the current rule amendment proposal to clarify that the monitoring requirements of the rule are intended to apply to both facilities. Specifically, any facility manufacturing cement prior to November 2005 is subject to the requirements of Rule 1156. In addition, even though the facility has currently ceased such cement manufacturing operations, they retain their permits fo r such processes and the potential to emit, therefore, remains.

Comment #35: The costs associated with monitori ng are not sufficient and need to be updated, such as filter sample analysis , construction of monitoring sites, maintenance, and personnel costs. (CPCC)

Response #35: These costs have been updated and the r eader is referred to the discussion of compliance costs and cost-effectiveness in the staff report.

Comment #36: Clarification is needed as to how monitoring data is to be submitted. (CPCC)

Response #36: The proposed amended rule language has been modified to reflect that the data be submitted electronically on a monthly basis. Staff will work with the facility operators.

Comment #37: Relative to monitoring and quantification of emissions, why is PM2.5 not also measured? (Public)

Response #37: The hexavalent chromium measured is a component of the total fugitive from the cement manufacturing operations. Fug itive dust is typically measured in terms of PM10, which is inclusive of the PM2.5 fraction. So, it is included relative to evaluating the hexavalent chro mium contribution in the larger sized

material.

Comment #38: A socioeconomic impact report should be completed as required by the state Health and Safety Code and include an analysis of impacts to the cement plants and the surrounding communities, including lost revenues to local governments and closure of at least one plant (e.g., CPCC). (CPCC)

Response #38: A socioeconomic analysis has been prepared for the proposed amendments.

Comment #39: The CEQA document should evaluate the possibility of plant shutdowns as a result of the amendments. The previous EA was written specifically to avoid imposing control measures that could shut down clinker manufacturing. As a result of the closure, the EA should addr ess the potential increase in air toxics associated with rail, ship, or truck import of cement materials. (CPCC)

Response #39: Staff has evaluated the currently proposed amendments to Rule 1156 and determined that potential impacts from the proposed project are within the scope of the analysis contained in the 2005 Final EA for Rule 1156. Consequently, SCAQMD is relying on the 2005 Final EA as the CEQAFinal Draft Staff Report for Proposed Amended Rule 1156

South Coast Air Quality Management District A-12 March February 2009 document for proposed amended Rule 1156 pursuant to CEQA Guidelines §15153 because impacts from the currently proposed amendments are essentially the same as impacts analy zed in the 2005 Final EA, in particular the analysis of Alternative C – Full Enclosures. Pursuant to §15153(b)(2), staff notified the public that the SCAQMD would be relying on the 2005 Final EA for Rule 1156 as the CEQA document for the currently propose amendments and would accept comments regarding potential impacts from the currently proposed amendments.

In the 2005 Final EA it is clearly stated that the Governing Board may adopt all, or portions of any of the project a lternatives, including Alternative C. No

comment letters were submitted on the 2005 Draft EA for Rule 1156. Consequently, the issue of affected facilities shutting down as a result of implementing Rule 1156 or any of the proj ect alternatives was not raised at

that time.

With regard to recently received comme nts about the possibility of affected facilities shutting down, as noted in re sponse #34, the Socioeconomic Impact Analysis prepared for the currently proposed amendments to Rule 1156 did not indicate that the proposed amendments would result in the closure of any affected facilities. Further, subseque nt to the start of the CEQA comment period, proposed amended Rule 1156 was modified based on comments received to provide more flexibility in complying with the proposed amendments by allowing alternative compliance options to total clinker storage requirements. Based on these conclusions, staff did not evaluate facility closures and any associated imp acts from facility closures because this is not a “reasonably foreseeable” effect of the currently proposed

amendments.

Information regarding the CEQA analysis is included in the Staff Report for proposed amended Rule 1156.

Comment #40: The focus of these efforts really co mes down to protection of public health, which needs to remain in the forefront. Staff’s efforts are supported. What are the penalties for non-compliance with the new rule provisions? (Public)

Response #40: Penalties for non-compliance are administered on a case-by-case basis as required in the California Health and Safety Code.Final Draft Staff Report for Proposed Amended Rule 1156

South Coast Air Quality Management District B-1 March February 2009 APPENDIX B

RESPONSE TO COMMENTS

Response to Comment s for the Public Review Period Ending July 20, 2008

___________________________________________________________________________Final Draft Staff Report for Proposed Amended Rule 1156

South Coast Air Quality Management District B-2 March February 2009 Response to Comments

The following are comments and responses on the initial proposed amendment to Rule 1156 that was released for public review June 2008 and for which the public workshop was held on July 2, 2008. The public review and comment period ended in July 20, 2008. These responses are relative to the revised staff proposal that was re leased to the public for review in November

2008.

Comment # 1 : California Portland Cement Company (C PCC) is the only facility that would be significantly, unfairly, and unnece ssarily impacted by the proposed amended rule (PAR) 1156, although none of the AQMD’s studies identify

levels of concern of hexavalent chromi um in the vicinity of CPCC in Colton.

TXI has been identified as the source of the elevated hexavalent chromium and has received associated violations for PM. (CPCC)

Response # 1 : On the average, hexavalent chromium content in samples taken adjacent and downwind of CPCC in spring 2008 are lower than TXI (0.35 ng/m 3 and 1.58 ng/m 3 , respectively), and hexavalent chro mium content of CPCC clinker is about 20% lower than TXI. However, in 9 ambient samples taken between 2/12/08 and 4/3/08, the 24-hour hexava lent chromium concentrations

measured near the facilities were close to or exceeded 1 ng/m 3 . Similar hexavalent chromium concentrations occurred again in July and September

2008.

Hexavalent chromium is a potent, known human carcinogen. PAR 1156 will ensure reductions of particulate emissions from cement manufacturing facilities and limit exposure to PM10, as well as hexavalent chromium. To

address the issue of financial hard ship raised by CPCC, AQMD staff has significantly revised their proposal.

The current proposed amendment would require total enclosure of clinker storage and handling conducted within 1,000 feet from, and inside, a facility’s property line. For clinker storage and handling activities that occur more than 1,000 feet from, and inside, a facility’s property line, PAR 1156 would allow the use of alternatives, such as a three-sided barrier covered with a roof and wind fence for active, barn-type storage; tarp and barrier/wind fence for other active piles; and tarp for inactive p iles. The proposal would also require ambient monitoring to measure hexavalent chromium at fence-lines and includes corrective actions should the monitoring indicate elevated levels of hexavalent chromium. PM10 monitoring is no longer required unless upwind/downwind level of 50 microgram per cubic meter (μg/m 3 ) as specified in Rule 403 – Fugitive Dust, is violated three or more times within a 36-month period. The revised proposal will significantly reduce costs to CPCC compared to the initial proposal, while still reducing particulate emissions and being public health protective.Final Draft Staff Report for Proposed Amended Rule 1156

South Coast Air Quality Management District B-3 March February 2009 Comment # 2 : CPCC proposes language that “the ru le does not apply to operations and materials handling and transporting that are regulated by Rules 1157 and 1158” and that facilities subject to Rules 1156, 1157, and 1158 shall be

consistent with the definition of affected facilities as defined in 40 CFR Part 63 and Part 60. (CPCC)

Response # 2: Rule 1156 was specifically developed to reduce particulate emissions from cement manufacturing facilities. Sin ce Rule 1156 only focuses on equipment and operations that are typical for cem ent manufacturing facilities, it is not necessary to exclude other types of industries from the rule.

Comment # 3 : CPCC suggests the deletion of “equal to ” in the opacity limits set forth in (d)(1)(A) and (d)(1)(B) because the a dded language actually makes the requirements more stringent instead of clarifying them. (CPCC)

Response # 3: Staff has revised the language to maintain the opacity levels in previously adopted Rule 1156.

Comment # 4: CPCC suggests the added terms “on-road” before “trucks” and “commercial” before “modes of material transporta tion” in (d)(2)(A) for clarification purposes. (CPCC)

Response # 4: During the initial Rule 1156 development pr ocess, staff worked closely with the cement manufacturing facilities to de velop such language, which is very specific to the facility’s activities and operations; therefore, the language will

not be revised.

Comment # 5: CPCC suggests that clinker storage piles located within 1,000 ft inside of the fence line of a cement manufacturing facility be enclosed, and that the alternatives, such as tarping, 3-way ba rrier, wind fence, or stabilizing can be applied to clinker storage piles located 1,000 ft or more from the fence line. (CPCC)

Response # 5: After further consideration, staff has revised the proposed amendment. To reduce PM and hexavalent chromium fugitive dust emissions from the storage and handling of clinker material that occur further than 1,000 feet from, and inside, a facility’s property line, the cu rrent proposal would allow the use of: (1) a three-sided barrier covered with a roof and wind fence of a maximum 20% porosity for active, barn-type stor age; (2) tarp and extended wind fence

with at least 5-foot freeboard for active piles that are immediately adjacent to the above mentioned covered barrier; and (3) tarp and barrier/wind fence with

at least 5-foot freeboard and exte nded at least 20 feet beyond the active portion of a pile for other active piles.

For inactive clinker storage, PAR 1156 would alternatively allow tarping only, provided that records of inactive status are maintained.Final Draft Staff Report for Proposed Amended Rule 1156

South Coast Air Quality Management District B-4 March February 2009 The majority of emissions would be reduced at a significant cost reduction compared to the initial staff proposal. This will minimize adverse economic impacts on cement manufacturing facilities. The addition of ambient monitoring and required corrective actions if certain emission levels are exceeded will provide public health protection.

Comment # 6: CPCC proposes a change in (d)(5)(B) fr om a prohibition on the open clinker storage piles to a set of stringent control measures that would achieve nearly the same dust control at a significantly reduced cost. CPCC believes that its existing dust control measures are sufficient to reduce health risks to the surrounding community, and that the pr oposed enclosure requirement would

be infeasible to CPCC since it has onl y 20 years left of identified quarry reserves. In addition, CPCC also belie ves that the elimination of outdoor clinker piles would increase NOx emissions. (CPCC)

Response # 6: Please see response to comment # 5.

Comment # 7: CEQA and socioeconomic assessment s hould be conducted to analyze the impacts of PAR 1156. (CPCC)

Response # 7: CEQA relies on the previous document prepared relative to the initial adoption of Rule 1156 in November 2005. Cost and cost-effectiveness are included in the staff report. Socioeconom ic analysis will be available 30 days prior to the public hearing.

Comment # 8: The current PAR 1156 is strongly suppor ted. Natural Resources Defense Council (NRDC) and the communities also believe that further investigation and control of other sources of PM emissions from cement manufacturing facilities are needed to protect the su rrounding communities. Steps should be taken to remediate past pollution of land and water from cement deposition. (NRDC)

Response # 8: Public health protection, cost, techni cal feasibility, impacts on industry, and

emission reductions have been considered and have resulted in the current staff proposal. The proposed wind and hexavalent chromium monitoring will provide additional information to ensure continued public health protection.

Comment #9: Further reduction in both criteria and toxics pollutants, as well as greenhouse gases emissions, can be attained thr ough the adoption of cleaner fuels and limited clinker production. (NRDC)

Response #9: PAR 1156 will reduce PM and hexavale nt chromium fugitive dust from cement manufacturing facilities. Othe r reductions through clean fuel or limiting clinker production are beyond the scope of this amendment.

Comment #10: We strongly support the enclosure requi rement of all clinker storage and handling since it will promote a healthful local environment. (Public)Final Draft Staff Report for Proposed Amended Rule 1156

South Coast Air Quality Management District B-5 March February 2009 Response #10: As noted in the response to comment #5, the initial staff proposal may have resulted in the early closure of one of the cement manufacturing facilities.

CPCC, under the revised proposal would not be subject to full enclosure, unless hexavalent chromium monitoring levels are exceeded. Staff believes the revised proposal is a good balance. It will achieve the majority of the particulate and hexavalent chromium reductions at significantly less cost by adding several control techniques to reduce fugitive dust, including monitoring and corrective actions.Final Draft Staff Report for Proposed Amended Rule 1156

South Coast Air Quality Management District C- 1 March February 2009 APPENDIX C

COMPARATIVE ANALYSIS

Comparison of PAR 1156 and Other Requirements for Cement Manufacturing

___________________________________________________________________________FinalDraftStaff Report for Proposed Amended Rule 1156South Coast Air Quality Management District C-2MarchFebruary2009Appendix C - Comparison Between PR1156 and Other Requirements for Cement ManufacturingNote: For comparison purposes, Rule 1156 proposed amendments are reflected initalicsformat.RULE 1156 AQMD RULE 1112.1NSPS -- 40CFR PART 60SUBPART FNESHAP -- 40 CFR PART 63SUBPART LLLCOMPLIANCE ASSURANCEMONITORING 40CFR PART 64APPLICABILITYEquipment/Operation:Kiln, clinker cooler, rawmill system, finish millsystem, raw mill dryer, rawmaterial storage, clinkerstorage, conveyor transferpoints, bagging, bulkloading and unloadingsystems; and operations thatgenerate fugitive dusts.Equipment/Operation:Cement kiln and clinkercooler for dry-processmanufacturing of graycement.Equipment/Operation:Kiln, clinker cooler, raw millsystem, finish mill system,raw mill dryer, raw materialstorage, clinker storage,conveyor transfer points,bagging and bulk loading andunloading systems•Equipment constructedor modified after7/17/1971.Facility is a major source or areasource of air toxics;Equipment/Operation:Kiln, clinker cooler, raw millsystem, finish mill system, rawmill dryer, raw material storage,clinker storage, conveyor transferpoints, bagging and bulk loadingand unloading systems•Existing equipment orequipment constructed orreconstructed after9/11/1998.Equipment that:•is subject to emission standard(e.g. SIP approved rules but not40 CFR Part 60 or Part 63rules);•uses a control device, and•3) has pre-control emissionsthat are equal to or more thanthe major source level (e.g. 70tpy PM10)COMPLIANCE DATEBy December 2006.Facility EmissionsReduce 2003 baselineemissions by 50% by 2006.Clinker Material StorageEnclosure or alternatives:6 months from date ofadoptionMonitoring RequirementsWind: 6 months from dateof adoption.Cr+6: 6 months from dateOn and after February1986.On or after completion of theinitial performance test.•For existing equipment:6/14/2002•For new or modifiedequipment: Upon startupIf the Title V application iscomplete before 4/20/1998, a CAMplan is due as part of the applicationfor the Title V permit renewal, or aspart of the application for asignificant permit revision.FinalDraftStaff Report for Proposed Amended Rule 1156South Coast Air Quality Management District C-3MarchFebruary2009RULE 1156 AQMD RULE 1112.1NSPS -- 40CFR PART 60SUBPART FNESHAP -- 40 CFR PART 63SUBPART LLLCOMPLIANCE ASSURANCEMONITORING 40CFR PART 64plan approval or 3/1/10,whichever occurs earlier.PM10 (if applicable):6 months from date planor 12 months from date ofthird confirmed violation,whichever occurs first.PERFORMANCE STANDARDSAll EquipmentOpacity≤10%Kilns and Clinker CoolersPM10≤0.05 lb/ton clinkerAll BaghousesOutlet concentration≤0.005 grain/dscf ; or 99.5%capture efficiency and99.5% collecting efficiencyOther Equipment•Opacity≤10% processequipment via method 9•Opacity < 20% openpiles & roadways viamethod 9B•Visible emissions not toexceed 100 ft. plume inany directionOther Requirements•Enclosed storage piles,crushers, screens, mills,conveying systems, andother equipment.Kilns and Clinker CoolersCombined•PM≤0.4 lb/ton feedwhen kiln feed rates<75 ton/hr•PM≤30 lb/hr whenkiln feed rates >75ton/hrKilns•PM≤0.3 lb/ton feed drybasis•Opacity≤20%Clinker Coolers•PM≤0.1 lb/ton feed drybasis•Opacity≤10%Other EquipmentOpacity≤10%Kilns:•PM≤0.3 lb/ton feed drybasis•Opacity≤20%Clinker Coolers•PM≤0.3 lb/ton feed drybasis•Opacity≤10%Other EquipmentOpacity≤10%Other RequirementsTHC < 50 ppmvd as propanecorrected to 7% oxygenD/F <8.7 x 10-11grain/dscfcorrected to 7% oxygenNot specified performancestandards.FinalDraftStaff Report for Proposed Amended Rule 1156South Coast Air Quality Management District C-4MarchFebruary2009RULE 1156 AQMD RULE 1112.1NSPS -- 40CFR PART 60SUBPART FNESHAP -- 40 CFR PART 63SUBPART LLLCOMPLIANCE ASSURANCEMONITORING 40CFR PART 64•Pave roads, usechemical dustsuppressants, limitvehicle speed, streetsweeping, and facilitycleanup.•Enclose clinkermaterial storage andhandling; alternatively,tarp/wind fence if>1,000 feet fromproperty line.Monitoring•Wind gusts >25 mph:shutdown of materialhandling.•Cr+630-day or 90-dayrolling average, asapplicable, shall notexceed 0.7 ng/m3.•PM10 monitoring, ifapplicable, shallrequire dust controlactivities if 3 NOVs forupwind/downwindconcentrationexceeding 50 μg/m3.MONITORING, RECORDKEEPING AND REPORTING REQUIREMENTS•Annual source testingfor kilns and clinkercoolers•Source test at least 10equipment vented tobaghouses which are inthe top 20% PM10Not specify.•Continuous opacitymonitoring for kilns andclinker coolers and anybypass•Record visible emissionsat least three 6-minute•Initial performance test isrequired to determinecompliance with the emissionlimitation and to establish theoperating limits•Performance test is requiredA CAM plan accompanying a TitleV permit must:•Describe indicators to bemonitored;•Describe indicators' ranges;•Describe performance criteriafor monitoring;FinalDraftStaff Report for Proposed Amended Rule 1156South Coast Air Quality Management District C-5MarchFebruary2009RULE 1156 AQMD RULE 1112.1NSPS -- 40CFR PART 60SUBPART FNESHAP -- 40 CFR PART 63SUBPART LLLCOMPLIANCE ASSURANCEMONITORING 40CFR PART 64emitters at the facility.•Monitor operatingparameters ofbaghouses such as fluegas flow rates andpressure drop acrossfilters.•Keep all records todemonstratecompliance for at least5 years.•Report annualemissions for allprocess equipment,open storage piles andvehicle traffic.•Source Test Methods:AQMD Method 5.1,5.2, 5.3 or EPA Method5 modified; or EPAMethod 201A and 202for PM10.•Submit compliance plan3-months from date ofadoption.•Keep records relative tomonitoring and use ofexemptions.•Report monitoring datamonthly.periods each day, andrecords maintained for 2years.•Record daily productionrates and kiln feed rates•Initial performance testis required to beconducted.•Excess emissions mustbe reported semi –annually.•Malfunctions must bereported.•Semiannual report ofexcess emissions andmalfunctions•Source Test Methods:EPA Method 5 for PMand Method 9 foropacity.every 30 months – 5years•Source Test Methods: EPAMethod 5 for PM andMethod 9 for opacity.•Provide justification for the useof the indicators, ranges, andmonitoring approach;•Provide emission test data, ifnecessary; and•Provide an implementationplan.A Title V permit must:•Include approved monitoringapproach,•Have specific definitions ofexceedence or excursion;•Include reporting andrecordkeeping requirements;and•Indicate if source testing isrequired.Source Test Methods: Notspecified.