Subject: HCl Test Results‐Lehigh, Redding plant  

From:    Stringham, Kent R. (Redding) NAM  

To:    Keith Barnett  

Date: 03/30/2010 06:00 PM  

Cc:     "Ellison, Jim", "Sterner, Richard", "Matz, Tim"    

Keith,

Lehigh Southwest Cement Company accomplished HCl testing at their Redding, CA  

plant this month.

The completed M321 spreadsheet, the M321 emission test report used to populate  

the M321 spreadsheet, and the site specific test plan are attached.

Kent Stringham

Environmental Engineer

Lehigh Southwest Cement Company

Redding, CA 96003

530.275.1581 ext 3317

(See attached file: M321 Spreadsheet‐Lehigh.xls)(See attached file:

10087 1 Lehigh Cement HCl Results.pdf)(See attached file: 10087 1 Test Plan  

with Appendices.pdf)








SOURCE TEST PROTOCOL 

2010 EMISSIONS COMPLIANCE TESTS, 

RELATIVE ACCURACY TEST AUDIT & 

EPA ICR HCl TESTS 

LEHIGH SOUTHWEST CEMENT COMPANY 

REDDING, CALIFORNIA 

Prepared For: 

LEHIGH SOUTHWEST CEMENT COMPANY 

Redding, California 

For Submittal To: 

SHASTA COUNTY AIR QUALITY MANAGEMENT DISTRICT 

Redding, California 

Prepared By: 

Mark L. Stanfield 

THE AVOGADRO GROUP, LLC 

401 Pech Road 

Medford, Oregon 97502 

(541) 665-0170 

February 17, 2010 
Lehigh Southwest Cement Company February 17, 2010 

2010 Source Test Protocol 

10087.1 ii 

SUMMARY INFORMATION 

Source Information

Source Location: Lehigh Southwest Cement Company 

Address: 15390 Wonderland Blvd. 

Redding, CA 96003 

Contact: Mr. Kent Stringham 

Telephone: (530) 275-1581, Ext. 3317 

Facsimile: (530) 275-2525 

Regulatory Agency: Shasta County Air Quality Management District 

Unit: Cement kiln 

Purposes: 1) Determination of particulate matter emissions and relative 

accuracy test audit (RATA) of the Continuous Emission Rate 

Monitoring System (CERMS) to satisfy SCAQMD permit 

requirements 

 2) Determination of HCl emissions to satisfy the EPA 

Information Collection Request (ICR). 

Procedures: EPA Methods: 1, 2, 3A, 4, 5, 6C, 7E, 10 and 321 

Permit to Operate: No. 85-PO-14k and EPA 40 CFR Part 60, Appendix B 

Testing Company Information

Testing Firm: The Avogadro Group, LLC 

 401 Pech Road 

 Medford, Oregon 97502 

Contacts: Mr. Mark Stanfield Mr. Erick Mirabella 

 Project Manager General Manager 

Telephone: (541) 665-0802 (925) 680-0935 

Facsimile: (541) 665-0179 (925) 680-4416 

Certification: ARB Independent Tester 

Test Dates: March 23 & 24, 2010 
Lehigh Southwest Cement Company February 17, 2010 

2010 Source Test Protocol 

10087.1 iii 

TABLE OF CONTENTS 

SECTION PAGE

1.0 INTRODUCTION ..................................................................................................1 

2.0 SOURCE LOCATION INFORMATION ...........................................................2 

 2.1 FACILITY DESCRIPTION ........................................................................2 

 2.2 SAMPLING LOCATION ............................................................................2 

3.0 PROGRAM DESCRIPTION ................................................................................3 

3.1 TESTING CONTRACTOR .........................................................................3 

 3.2 PROGRAM OBJECTIVES .........................................................................3 

 3.3 TEST CONDITIONS ...................................................................................4 

 3.4 TEST SCHEDULE ......................................................................................5 

4.0 SOURCE TESTING PROCEDURES ..................................................................6 

 4.1 TEST PROCEDURES .................................................................................6 

 4.1.1 Gaseous Emissions...........................................................................7 

 4.1.2 Particulate Matter (PM) ...................................................................8 

 4.1.3 Relative Accuracy Test Audit (RATA) ...........................................9 

 4.1.4 Hydrogen Chloride (HCl) ................................................................9 

 4.1.5 Volumetric Flow Rates and Moisture Content ..............................11 

 4.1.6 Process Data ...................................................................................11 

5.0 SOURCE TEST REPORT ..................................................................................12 

APPENDICES 

A MEASUREMENT PROCEDURES .................................................................... A 

B QUALITY ASSURANCE AND ARB CERTIFICATION ................................ B 

C OPERATING PERMIT ....................................................................................... C 

D FIELD WORK SAFETY PLAN .......................................................................... D 
Lehigh Southwest Cement Company February 17, 2010 

2010 Source Test Protocol 

10087.1 1 

SECTION 1.0 

INTRODUCTION

The Avogadro Group, LLC (Avogadro) has been contracted by Lehigh Southwest 

Cement Company (Lehigh) to perform a series of emission tests at their facility in 

Redding, California. The tests are scheduled for March 23-24, 2010 with start times of 

approximately 8:00 A.M. each day. 

The purpose of the testing is two fold. First, determine the compliance status of the 

source for particulate matter emissions and audit the performance of the CERMS in 

accordance with EPA 40 CFR, Part 60, Appendix B and the Permit to Operate (PTO) 85-

PO-14k issued by the Shasta County Air Quality Management District (SCAQMD). 

Second, determine HCl concentrations and emission rates to satisfy the EPA ICR. The 

following emission parameters will be determined: 

 Compliance Tests 

 PM - gr/dscf, gr/dscf @ 7% O2, lb/hr, lb/ton of feed 

 Relative Accuracy Test Audit (RATA) 

 O2 - % volume dry 

 CO - lb/hr 

 NOX - lb/hr 

 SO2 - lb/hr 

 Flow monitor - kdscfm 

 EPA ICR Tests 

 HCl – ppmvd @ 7% O2

 Supporting Data 

 CO2 - % volume dry 

 Stack gas volumetric flow rate - dscfm 

 Moisture content - % by volume 

Avogadro will provide the test personnel and all necessary equipment to measure 

emissions as required by the regulations and permit conditions. Lehigh personnel will 

provide the plant process data to be included in the final report. The results of the tests 

will be presented in a report and delivered to Lehigh within 30 days after completion of 

the field tests. This test protocol provides descriptions of the facility and test location, 

descriptions of the testing program, the test methods and procedures, the program 

schedule, and a summary of our quality assurance program. 
Lehigh Southwest Cement Company February 17, 2010 

2010 Source Test Protocol 

10087.1 2 

SECTION 2.0 

SOURCE LOCATION INFORMATION

2.1 FACILITY DESCRIPTION 

Lehigh Cement is located in Redding, California and operates a cement kiln to provide 

raw cement to ready mix companies throughout the area. The kiln includes a baghouse to 

control particulate emissions and a CERMS to monitor O2, CO, NOX and SO2. The 

facility also monitors stack gas flow rate and flue gas opacity. 

2.2 SAMPLING LOCATION 

Emissions from the kiln exhaust through a vertical, cylindrical stack that measures 83.5 

inches in diameter. There are four sampling ports, located 90 degrees from each other in 

the same horizontal plane, which provide access to traverse points for sampling. The 

ports are located approximately 100 feet (14 stack diameters) downstream and 80 feet (11 

diameters) upstream from flow disturbances. Access to the sampling location is by 

elevator to a permanent testing platform approximately 120 feet above ground level. 

Avogadro personnel will verify the dimensional measurements of the stack prior to 

testing. A diagram of the sampling location and traverse point locations will be included 

in the final report. The estimated stack gas conditions are presented in Table 2-1. 

TABLE 2-1 

ESTIMATED STACK GAS CONDITIONS 

CEMENT KILN 

LEHIGH SOUTHWEST CEMENT COMPANY 

Stack Parameter Value

Temperature of flue gas, °F 230 - 260 

Volumetric flow rate, kdscfm @ 70 °F 124 - 130 

Moisture content, % volume 16 - 18 

Oxygen, % volume dry 10 - 11 

Carbon dioxide, % volume dry 16.5 - 17.5 

Carbon monoxide, ppm volume dry 200 - 500 

Nitrogen oxide, ppm volume dry 100 - 300 

Sulfur dioxide, ppm volume dry 1 - 5 
Lehigh Southwest Cement Company February 17, 2010 

2010 Source Test Protocol 

10087.1 3 

SECTION 3.0 

PROGRAM DESCRIPTION

A series of measurements will be made to determine emissions from the cement kiln at 

Lehigh Cement. The scope includes the performance of three particulate matter and three 

HCl test runs at each of two operating conditions (mill on and mill off). In addition, at 

least nine O2, CO, NOX, SO2 and stack flow test runs (mill on) will be performed to 

complete a RATA of the facility’s CERMS. 

3.1 TESTING CONTRACTOR 

The test program will be conducted by Avogadro. The contact persons for the project 

will be: 

 The Avogadro Group: Mark Stanfield (541) 665-0802 

 Lehigh Cement: Kent Stringham (530) 275-1581 

 Shasta County AQMD: Ross Bell (530) 225-5674 

Avogadro is a recognized independent contractor that has been approved to conduct 

emission source testing on behalf of the California Air Resources Board (CARB), 

pursuant to Section 91200-21220, Title 17, of the California Code of Regulations. 

Avogadro is a full service source testing and combustion engineering consulting firm 

with extensive experience in pollution control. Avogadro will provide a professional 

source test team to conduct the testing as described in this test plan. 

The test team members assigned to this project are familiar with the testing of cement 

kilns and have successfully conducted these emissions tests at this facility in the past. 

Mark Stanfield has been assigned as project manager. Up to three experienced 

technicians will provide on-site support. 

3.2 PROGRAM OBJECTIVES 

The test program has two objectives. First, tests will be performed to determine the 

particulate matter emission compliance status of the unit as well as to audit the 

performance of the CERMS in accordance with the current permit to operate and EPA 40 

CFR, Part 60, Appendices B and F. Second, tests will be performed to measure and 

report HCl concentrations to satisfy the EPA ICR dated February 3, 2010. The final 

report will present the results of the emission tests and will compare them to the 

applicable standards outlined in Table 3-1. 
Lehigh Southwest Cement Company February 17, 2010 

2010 Source Test Protocol 

10087.1 4 

TABLE 3-1 

SUMMARY OF EMISSION AND PERFORMANCE STANDARDS 

CEMENT KILN 

LEHIGH SOUTHWEST CEMENT COMPANY 

Parameter: Reference Standard 

O2 analyzer: 

% relative accuracy, % volume dry 40 CFR, Part 60, App. B, 

PS 3, Section 13.2 1.00 a

CO analyzer: 

% relative accuracy, lb/hr 40 CFR, Part 60, App. B, 

PS 6, Section 13.2 10.0 / 20.0 b

NOX analyzer: 

% relative accuracy, lb/hr 40 CFR, Part 60, App. B, 

PS 6, Section 13.2 10 / 20.0 b

SO2 analyzer: 

% relative accuracy, lb/hr 40 CFR, Part 60, App. B, 

PS 6, Section 13.2 10 / 20.0 b

Flow monitor: 

% relative accuracy, kdscfm 40 CFR, Part 60, App. B, 

PS 6, Section 13.2 20.0 c 

Particulate matter: 

lb/ton of feed PTO 85-PO-14K 0.3 

HCl: 

ppmvd @ 7% O2 February 3, 2010 EPA ICR -- 

a

 No greater than 1% O2 based on the absolute difference between the RM and CERMS data. b

 No greater than 20% of the mean value of the RM’s test data in terms of the units of the emission standard, or 10% 

of the applicable standard, whichever is greater. c

 No greater than 20% of the mean value of the RM's test data. 

3.3 TEST CONDITIONS 

The tests will be conducted while the kiln is operating at a feed rate of approximately 135 

to 145 tons/hr (or 95%-105% of maximum production). Lehigh personnel will establish 

the process conditions within the requirements of the PTO. Unit operating data including 

CERMS data will be collected by Lehigh personnel, and will be provided to Avogadro 

for documentation of the process conditions and for comparison with the relative 

accuracy test audit results. 
Lehigh Southwest Cement Company February 17, 2010 

2010 Source Test Protocol 

10087.1 5 

3.4 TEST SCHEDULE 

The test program will be performed over two days. Table 3-2 presents the sampling 

schedule. 

TABLE 3-2 

TEST SCHEDULE 

CEMENT KILN 

LEHIGH SOUTHWEST CEMENT COMPANY 

Day Activity Sample Runs Run Duration 

March 22, 2010 Mobilize and set-up -- ~ 4 hours

March 23, 2010 

(Mill off) 

Emission Tests

O2, CO2

PM 

HCl 

Various 

1, 2, 3 

1, 2, 3 

40 min. ea. 

60 min. ea. 

60 min. ea. 

March 24, 2010 

(Mill on) 

Emission Tests

O2, CO2, CO, NOX, SO2, Flows 

PM 

HCl 

1-9 (up to 12) 

1, 2, 3 

1, 2, 3 

21 min. ea. 

60 min. ea. 

60 min. ea. 

April 22, 2010 Final report submittal -- -- 

Notes: A minimum of 9 test runs and a maximum of 12 test runs will be performed. The relative accuracy of each 

monitor will be determined based on data collected during nine of the test runs. 

.
Lehigh Southwest Cement Company February 17, 2010 

2010 Source Test Protocol 

10087.1 6 

SECTION 4.0 

SOURCE TESTING PROCEDURES

4.1 TEST PROCEDURES 

Descriptions of the test methods are included in Appendix A. Brief descriptions, 

including any site-specific applications or modifications, are included in the subsections, 

which follow here. Where any conflicts exist in the descriptions, the site-specific 

description here in Section 4.1 will take precedence. The EPA Method 29 pre-test 

calculations are presented in Appendix E. A list of sampling procedures is outlined in 

Table 4-1. 

TABLE 4-1 

TEST PROCEDURES 

CEMENT KILN 

LEHIGH SOUTHWEST CEMENT COMPANY 

Parameter Reference 

Method Measurement Principle Method Detection Limit 

O2 EPA 3A Paramagnetism 2% of instrument 

full scale 

CO2 EPA 3A Non-dispersive infrared 2% of instrument 

full scale 

CO EPA 10 Gas filter correlation 2% of instrument 

full scale 

NOX EPA 7E Chemiluminescence 2% of instrument 

full scale 

SO2 EPA 6C Ultraviolet absorption 2% of instrument 

full scale 

PM EPA 5 Gravimetry 0.0005 gr/dscf 

HCl EPA 321 Fourier transform infrared ~ 0.5 ppmv 

Stack flow rate EPA 1, 2 Pitot tube / temp. traverse -- 

Moisture cont. EPA 4 Gravimetry -- 
Lehigh Southwest Cement Company February 17, 2010 

2010 Source Test Protocol 

10087.1 7 

4.1.1 Gaseous Emissions

Concentrations of the gaseous constituents of the stack gas (CO, NOX, SO2, O2 and CO2) 

will be measured using Avogadro’s dry extractive continuous emissions monitor system 

(CEMS) described in Appendix A. This system meets the requirements of EPA and 

CARB methods for gaseous species. A heated Teflon line and chilled knockout system 

will be used to prevent loss of NO2 and SO2 in the sampling system. The NOX analyzer 

will be operated in the NOX mode to measure NO plus NO2. A molybdenum catalyst 

converter is used to convert NO2 to NO for measurement of total NOX. 

The sample conditioning and delivery system includes components to extract a 

representative sample from the source, remove the moisture and particulate matter from 

the sample stream, and transport the sample to the analyzers. The primary components of 

this subsystem are: 

1) A quartz, titanium, stainless steel or glass probe - heated or insulated as 

necessary to avoid condensation, 

2) Sample filtration – filters located on the probe, pump, and prior to all of 

the analyzers for removal of particulate matter, 

3) Teflon tubing - connecting the probe to the sample conditioner and the 

sample conditioner to the analyzer manifold - heated or insulated as 

necessary to avoid condensation, 

4) Sample conditioner - glass or stainless steel flasks immersed in an ice bath 

to remove the moisture from the sample gas stream, 

5) Vacuum pump - a leak-free pump with Teflon diaphragm to transport the 

sample gas through the system, 

6) Sample manifold - a distribution system, constructed of stainless steel and 

Teflon tubing, to direct sample gas to the analyzers, and 

7) Sample flow rate control - a series of rotameters, vacuum gauges and 

pressure gauges connected to the manifold used to maintain the 

appropriate sample flow rates. 

The calibration gas system utilizes only EPA Protocol gases to verify the operation, 

linearity, and range settings of the electronic analyzers. The sample gas system allows 

for the introduction of the protocol gases to the analyzers either directly through the 

manifold (calibration error check - performed once daily) or through the sampling system 

(system bias check - performed with each run). 

The electronic analyzers are rack-mounted and are maintained in the mobile lab. The 

data recording and acquisition system is based on a digital system known as STRATA. It 
Lehigh Southwest Cement Company February 17, 2010 

2010 Source Test Protocol 

10087.1 8 

includes software for controlling the collection of calibration and emission monitoring 

data, and hardware for connection of the analyzer outputs to the recording system. 

Test results can be provided in three forms: on-site printouts of the digitized data, 

diskette recordings of the digitized data, and printouts of strip charts from the monitoring 

data. For this test program, on-site printouts of the one-minute averages will be provided 

in the final report. 

4.1.2 Particulate Matter (PM)

Particulate matter emissions will be measured according to EPA Method 5. 

A metered flue gas sample is collected isokinetically and particulates are collected on a 

heated filter followed by a series of water impingers. 

The sample is drawn through a nozzle, a stainless steel or glass probe and a filter in a 

250oF temperature-controlled oven. This is followed by two Greenburg-Smith impingers 

which contain 100 ml of distilled water, an empty impinger as a knock-out and an 

impinger containing silica gel to protect the leak-free vacuum pump and calibrated dry 

gas meter from moisture. The impingers collect condensible particulate species while the 

filter collects any existing as particulate at 250oF. 

EPA Method 4 (moisture) and Methods 1 and 2 (velocity) are performed in conjunction 

with the test. Stack velocity is measured during the test to maintain isokinetic sampling 

and to measure stack flow rate. Moisture concentration is determined by weighing the 

impingers before and after sampling to determine the amount of moisture collected. 

Following testing, the impingers are weighed for moisture determination and the 

following sample fractions are recovered: 

1. Probe, nozzle and front-half glassware – acetone wash and brushing 

2. Filter 

The probe, nozzle and front-half glassware wash is evaporated at low temperatures, 

baked at 105oC then desiccated and weighed to a constant weight. The filter is baked at 

105oC, desiccated and weighed to a constant weight. 

Particulate concentration is determined by dividing the mass of particulate collected by 

the sample gas volume. 
Lehigh Southwest Cement Company February 17, 2010 

2010 Source Test Protocol 

10087.1 9 

4.1.3 Relative Accuracy Test Audit (RATA)

The test results will be used to calculate relative accuracy (RA) in units of lb/hr for the 

CO, NOX and SO2 analyzers. The relative accuracy of the O2 analyzer will be 

determined in percent by volume (dry basis) units. The relative accuracy of the flow 

monitor will be determined in units of thousand dry standard cubic feet per minute 

(kdscfm). 

For each reference method (RM) determination, the flue gas will be sampled at three 

traverse points along the “measurement line” that will be determined prior to testing 

using EPA Method 1 procedures. The differences between the RM sample and the 

pollutant monitor's readings will be evaluated from a minimum of nine sets of paired 

monitor and RM test data. From these differences, the 95% confidence coefficient will 

be calculated, and the relative accuracy determined. Any tests not included in the 

calculations for the determination of relative accuracy (maximum of three) will still be 

included in the final test report. 

The relative accuracy of the O2 analyzer will be determined in accordance with 40 CFR 

Part 60, Appendix B, Specification 3. The RATA results are acceptable if the mean 

difference of the O2 monitors’ measurements and the corresponding RM measurements 

are within ±1.0% O2. 

In accordance with 40 CFR Part 60, Appendix B (Specification 6), CO, NOX and SO2

relative accuracy test results are acceptable if the CO, NOX and SO2 relative accuracy 

does not exceed 20% of the mean value of the RM test data in terms of units of the 

emission standard or 10% of the applicable standard, whichever is greater. 

In accordance with Performance Specification 6, Section 13.2, flow rate relative accuracy 

test results are acceptable if the results do not exceed 20% of the mean value of the RM 

test data, when expressed in the reporting units. 

4.1.4 Hydrogen Chloride (HCl)

Hydrogen chloride (HCl) concentrations will be measured using a Fourier transform 

infrared spectrometer (FTIR). 

A flue gas sample is extracted from the exhaust stack and delivered to the FTIR 

monitoring system. The FTIR scans approximately once per minute to measure 

concentrations of individual compounds based on the IR absorption spectra. 

An exhaust gas sample will be collected continuously from a single point near the center 

of the exhaust stack. The gas sample will be drawn directly from the stack to the sample 

cell of the FTIR spectrometer through a probe of stainless steel tubing and a length of 

heated Teflon tubing sample line, maintained at 250F (120o

C) or greater. A diaphragm-
Lehigh Southwest Cement Company February 17, 2010 

2010 Source Test Protocol 

10087.1 10 

type pump will be used to induce sample flow of approximately 2 to 10 liters per minute. 

The FTIR cell will be heated and wrapped in an insulating blanket, and its temperature will 

be monitored with a digital Type K or J thermocouple. All target compound concentrations 

will be adjusted for differences in temperature and pressure from the reference calibration 

spectra. 

EPA Methods 1 through 4 will be performed in conjunction with the test to provide stack 

gas flow rate, molecular weight, and moisture content data. The FTIR measures 

concentrations on a wet basis in units of ppm volume wet. 

MIDAC Corporation developed the FTIR system, an extractive-type system. The system 

consists of a medium-resolution Michaelson interferometer; a heated infrared 10-meter 

folded “White” absorption cell design; and a liquid nitrogen-cooled mercury cadmium 

telluride (MCT) broadband infrared detector. The system is equipped with a dedicated 

computer for data collection, reduction, and storage. 

The nominal spectral resolution of the system is one-half wave number (0.5 cm-1). The 

inside walls and mirror housing of the cell are polished nickel to minimize interaction of the 

sample with the cell walls. The cell will be maintained at 120oC or an adequate 

temperature to prevent condensation in the cell or polymerization of any of the target 

compounds while not degrading them. As described in EPA Method 320, the absorption 

path length of the cell will be checked before and after each test run to ensure that the path 

length between runs has not differed by more than 5% from their mean value. 

An FTIR spectrum of the flue gas is obtained by continuously flowing gas through the 

sample cell with sample gas and recording the spectrum. Averaging individual scans 

produces the spectrum. A minimum of 32 scans will be used for sample collection. Each 

sequential spectrum will be recorded continuously. A total of 12 sample readings will be 

taken per run as per EPA Method 320. The system will be checked for proper operation 

and path length. It will be calibrated with a calibration gas, referred to as a calibration 

transfer standard (CTS) gas, before and after each set of three test runs. In addition, 

calibration gases for one of the target compounds will be used on-site to perform one 

dynamic matrix spike. A minimum of 10% of the stack gas matrix will be replaced with 

spike material at approximately 50% of the target compound concentration found in the 

stack gas or 3 times the minimum detection limit. Recovery must be between 70 and 130% 

of the spiked compound. 

Prior to field mobilization, an analytical software quantification method, performed on 

MIDAC’s AutoquantPro 4.0 software, will be developed to provide on-site results for the 

majority of the target analytes. In addition to the target compounds, this method will 

include spectra for water, carbon monoxide, carbon dioxide, and methane to account for 

any interference. The method will be optimized to minimize interferences by selecting 

regions that do not significantly overlap and are unique to the target analytes or by 

overlaying interfering species absorbance bands and allowing the software to discriminate 
Lehigh Southwest Cement Company February 17, 2010 

2010 Source Test Protocol 

10087.1 11 

by means of a Classical Least Squares (CLS) algorithm. After sample collection, this 

method may be modified, sometimes resulting in significantly different results than those 

presented on-site. All supporting data and documentation will be presented in the report. 

Sample spectra collected at the test site will be compared manually and visually with the 

target compound reference spectra. This allows the analyst to determine instrumental 

differences, and to account for spectral differences that are not concentration related. The 

sample and calibration spectra will be analyzed using AutoquantPro 4.0 software for gas 

phase infrared spectral analysis. The output will consist of calculated concentrations (in 

parts per million by volume, wet basis) and error calculations for each of the target 

analytes. 

4.1.5 Volumetric Flow Rates and Moisture Content

Stack gas volumetric flow rates and moisture content will be determined by using EPA 

Methods 2 and 4. Flow traverses will be performed (one traverse per gaseous test run) to 

provide data for the flow monitor RATA determination. The moisture content will be 

determined with the concurrent PM test runs. 

4.1.6 Process Data

Lehigh personnel will establish the process conditions within the requirements of the 

PTO. Unit operating data, including CERMS data will be collected by Lehigh Cement 

personnel, and will be provided to Avogadro for documentation of the process conditions 

and for comparison with the relative accuracy test audit results. 
Lehigh Southwest Cement Company February 17, 2010 

2010 Source Test Protocol 

10087.1 12 

SECTION 5.0 

SOURCE TEST REPORT

Avogadro will prepare a thorough, clear report summarizing the test descriptions and 

results. Included in the appendices will be copies of the field data sheets, equipment 

calibration data, and example calculations. Avogadro uses computer spreadsheets to 

calculate results from field data sheets and laboratory results. One run of every method 

performed is also hand calculated. The hand calculations are checked against the 

spreadsheet results and included in the example calculation appendix of the final report. 

Avogadro understands the “Standard Condition(s)” that are to be used in the SCAQMD 

are 29.92 inches of mercury and 70 oF. 

Prior to release by Avogadro, the report will be reviewed and certified by Mark Stanfield 

and either his supervisor or a peer. The report will be issued within 30 days after 

completion of the field testing. 





















































alue in dry

ppmvd). I

ction limit

imit in 

Enclosure 5c‐‐ERT Spreadshee Spreadsheet

C Co ce t o co pp @ % 

Worksheet Title: HCl Emission Test Results Template Using Method 321Who Should Complete this Spreadsheet? Facilities that use Method 321 to test for HClCompany Name: Lehigh Southwest Cement Company

Facility Name: ReddingAddress: 15390 Wonderland BlvdCity: ReddingState: CA

Kiln ID: 1Kiln Type: PHIn-line Raw Mill: YesControl Device Configuration: In line Raw Mill/Kiln Baghouse (S260)

Parameter

Sample #1

Sample #2

Sample #3

Test AverageUnits

Units Other 

DescriptionTest Method Used Test Location 

Enter HCl concentration vparts per million volume (test results are below deteplease note the detection lbrackets (e.g., [< 0.010]). 

Select approprifrom list. If othselected pleaseunits in column

f the 

, ate unit 

er is 

 describe 

 H at right. Enter the name of the Test Method used.

Indicate whether the toccurred upstream or downstream of a contrdevice(s); list the contdevice(s)

Sample Date (mm/dd/yyyy) 3/16/2010 3/16/2010 3/16/2010HCl Concentration - as measured - dry 3.00 1.67 1.60 ppmvd Oxygen Concentration - dry basis 11.07 10.72 11.60 %CO2 Concentration - dry basis 16.62 17.18 15.92 %

HCl Concentration - corrected to 7% at ected to 7% 4.24 2.29 2.39 2.97 ppmvd @ 7% O2 Method 321 Downstream; Baghou

; g

Exhaust Stream %Moisture 14.0 15.3 15.5 % Exhaust Flowrate 133,025 135,639 133,951 dscfm Exhaust Temperature 228.4 227.9 218.0 degrees F Sample Date (mm/dd/yyyy) 3/17/2010 3/17/2010 3/17/2010

HCl Concentration - as measured - dry 35.29 16.98 15.91 ppmvd 

Oxygen Concentration - dry basis 9.236 8.914 8.966 %CO2 Concentration - dry basis 19.74 20.16 20.29 %HCl Concentration 42.05 19.69 18.53 26.76 ppmvd @ 7% O2 Mthod 321 Downstream; Baghou

Exhaust Stream %Moisture 14.8 14.5 5.5 % Exhaust Flowrate 115,358 111,530 108,519 dscfm Exhaust Temperature 280.0 281.7 284.3 degrees F Notes:Peach shaded cells indicate areas where the user will enter a response