# South Coast r Quality Management District

Copley Drive , Diamond Bar, CA 91765-4178 • ._ .. ,: ·(•"'"'"'' " """''"'-L.'"""""' • www . aqmd

. gov



### Mining Association Malcolm C
. Weiss, Esq
. Jeffer, Mangels, Butler 

### & Marrnaro , LLP 1900 Avenue of the Stars Seventh Floor Los Angeles, California 90067 Office of the Executive Officer 909-396-2100


### December 15 , 2006

Subject: Rule 1157- PM10 Emission Reductions from Aggregate and Related Operations Dear 

### Mr
. Weiss : Pursuant to the settlement agreement between CMA and AQMD, 

### the Rule 1157 emissions inventory has been re-examined
. On December l, 2006, 

### the AQMD Governing Board ratified a revised emissions inventory after an open and public review process (Attachment 1)
. The revised emission factors and asswnptions used as the basis for the new inventory (Attachment 2) will be employed for all future purposes until a new emissions inventory is approved by the Governing Board
. These future purposes include internal and external commUnications, CEQA review and permitting analyses, as well as the 

### Air Quality Management
· Plan and the Annual Emissions Reporting program .



### Ifyou have any questions, please contact me at (909) 3 96-3131 or 

### Laki Tisopulos, Assistant Deputy Executive Officer, at (909) 396-3123
.

cc : Elaine Chang Carol Coy Mohsen 

### Nazemi Laki 

### Tisopulos 

### Kurt Wiese BRW:LT:LL :TG Sincerely,
Barry R. rstein, D
. Env
. Executive Officer

# Attachment 1

# Soutl1- Coast Air 

# Quality Management District 21865 Copley Drive, Diamond Bar, CA 91765-4178 

### (909) 396-2000 · 

### http://www.aqmd.gov


### BOARD MEETING DATE: December 1, 2006 AGENDA NO. 15 PROPOSAL:

SYNOPSIS:



### COMMITIEE: Ratify Revised Emissions Inventory for Adopted Rule 1157

- PM10 Emission Reductions from 

### Aggregate and Related Operations Rule 1157 was adopted by the Board in January 2005. The Board directed staff to work with industry to re-examine the emissions inventory for the adopted rule. 

### Although still significantly higher (eleven fold) than the inventory used for the 2003 AQMP control measure (BCM-08), the revised inventory reflects an approximate 50 

### percent decrease from the pre- and post-rule calculated emissions inventories, 

## as included in 

### the staff 

### report for Rule 1157. The revised assumptions and methodologies will be used in all 

### future emission calculations for permitting, CEQA, and annual emissions reporting purposes. Stationary Source, November 17, 2006, Reviewed 

### RECOMMENDED ACTION: Receive and ratify" the attached revised emissions inventory and authorize the Executive Officer 

### to provide a letter to the California 

### Mining Association acknowledging this revision.

# ~-~ Barry R. Wallerstein, 

### D .Env. Executive Officer
EC: LT:U:TG 

### Introduction Rule 1157 was adopted on January 7, 2005 to 

### further reduce particulate (PMlO)



### . emissions from aggregate and related operations as part 

### of the 2003 AQMP Control Measure BCM-08 -Further Emission Reductions from Aggregate and Cement ManUfacturing Operations. During the public hearing for adoption of Rule 1157, some

### members of the aggregate industry raised concerns regarding. the methodology for estimating the PMIO emissions inventory presented in 

### the staffreport, particularly as related to emission factors and assumptions (e.g., throughput). West Coast Environmental and 

### Engineering (WCE) 

### submitted a written report on behalf of the Southern California Rock Products Association (SCRPA) analyzing the emissions inventory developed by AQMD staff and expressing their strong disagreement with staff's analysis. In 

### the 'adopting resolution,
. the Board directed staff to "include a review of the emissions inventory for Proposed Rule 1157
... in 

### the development work for the AQMP and 

### that any necessary revisions be incorporated into the baseline emissions inventory for the AQMP." On February 10,2005, the California Mining Association (CMA) 

### filed a lawsuit against the AQMD alleging, among other claims, that the rule was based on a ''flawed emissions inventory." On September 

## 2, 2005, 

## CMA and the AQMD executed a formal settlement agreement. As 

### part of the settlement agreement, the AQMD acknowledged, in 

### conjunction with the aforementioned Board direction, 

## that a review of the data and methodologies used 

### to derive the inventory was warranted. Since that time, staff and indllitly have met on numerous occasions to arrive at a mutually acceptable inventory. Background 

### Following the 

## Board directiou to review the**enrissio~** 

### inventory, staff carefully evaluated WCE' 

## s report, and began working with SCRP A 

### and WCE representatives to review issues related to 

### the emissions inventory development · AQMD staff met with representatives of SCRP A and WCE on more than 

### a dozen occasiol).S to reexamine the development of the emissions inventory. This includes
. assumptions used and ·survey data provided by industry during rule development that staff used for developing the PM1 0 emissions inventory. As a result of these meetings, staff made 

### adjustments to the · PMl0 emissions inventory based on best 

### available scientific and supportive docwnentation that 

### staff gathered
. Not all areas**unde~** 

### dispute were mutually resolved; however, sufficient progress was made such that an adjusted emissions inventory was eventually completed
. Methodology for Developing the 

### Initial PMIO EmisSionS Inventory 

### During the development of Rule 

### 1157, AQMD staff conducted a survey of**~gate** 

### and related facilities using survey forms that were developed with approval from 

### industry including 

## SCRP A/SCRMA (Southern Califoinia Ready Mixed 

### Concrete Associatiol).). The purpose of 

# the survey was to refine the emissions**~vent:Qry** 

### listed in fPe 1997
.AQMP for these SOUrce 

### categories
. Data collected from the survey 

# was useQ 

### for the following: , · · · ·

'l.

### • identify and characterize facilities subject to the proposed rule; • estimate PMIO emissions generated by these facilities; and • establish the baseline PMIO emissions for this industry in the air 

### basin. Staff used the information provided by the SCRP A and SCRMA, data obtained from the AQMD permit system and the 2001

- 02 Annual Emissions Reporting (AER) database to identify 395 potential survey respondents
. The survey forms were distributed in March 2004
. Based on the survey results and additional input from the industry, staff estimated the number of aggregate and related facilities in the air 

### basin by category, summarized as follows: Aggregate and Related Facilities in the South Coast Basin


### Aggregate 

## 29 Concrete Batching 100 

### Concrete Product 152 

### Crushed Miscellaneous Base 

## 25 Hot Mix Asphalt 45 

### "Other" 38 Total 

## 389 Additionally, staff estimated PM10 emissions for each facility and category based on inputs provided by the facilities participating in the survey. Emissions for each facility are classified into three 

### main emission sources: process equipment, stockpiles, and road

· (paved/unpaved) emissions
. PM10 emissions from process equipment include emissions generated from loading and unloading activity, hoppers and surge bins, conveyor transfer points, crushers, screens, milling equipment, and truck load..auts. The survey-based average PMlO 

### emissions generated for each category were then scaled up to estimate the baseline emissions fuvento.ry for the entire aggregate industry and related operations
. Staff used only data 

### from dry 

### aggregate materials to calculate PMIO emissions for each applicable activity, equipment, and/or emission source (i.e., loading/unloading, hopper/surge bin, conveyor transfer point, crushing, screening,

- 3-

### milling, silo, cement truck loading, HMA load-<>ut, open storage pile, unpaved roads, and track-out). The pre- and post-rule emis s ions inventories were calculated to be 

### approximately 29 and 11 

# tOns per day, respectively, for an overall rule effectiveness of62%. The pre-rule emissions inventory is in 

### significant contrast to that used in the 2003 AQMP 

### control measure, which set the inventory for aggregate processing at 1.2 tons per day
. Findings 

### As mentioned earlier, staff met with 

### the 

### SCRPA and 

### WCE representatives on numerous occasions to discuss the methodologies and assumptions used in developing the PM1 0 

### emissions inventory
. All 

### aspects of the emissions inventory, such 

## as development of the assumptions, interpretation of the survey data
. , selection of the emission factors, and formulas used 

### for estimating emissions have been carefully re-evaluated by industry representatives and staff. The following summarizes the key issues
. pertaining to the development of the ·PMl

### 0 emissions inventory
. 

### Areas of Agreement/Resolved Issues • Proper use of throughput for calculating process emissions.

• : Post

- rule control efficiency of water at 95%. 

### •

_ No crushing of fine materials
. • Fly ash 

### and cement throughput were used to calculate cement truck loading emissions. • Haul truck capacity of 75 

### tons used to determine roadway emissions. • Silt loading for uncontrolled paved roads. • Use of 80% 

### control efficiency for unpaved roads 

## treated with chemical dust suppressants . • · Credit 

### given in calculations for pre-rule compliance with Rule 403 and appropriate federal New Source Performance Standards 

## (NSPS) provisions
. • Fines 

### screening of 20%. • Facility-specific data only relea8ed for facilities waiVitig 

### confidentiality of data.



### . Areas of Disagreement/Unresolved Issues • Basis fot**~** 

### general pre-rule 

## controJ efficiency of water 

### of 50%, 

### supported by compliance hi$00ry 

### of issued Notices of Violation. • Moisture
. content used 

## as a proportional measurement to control efficiency. • Calculation method of stockpile emissions (tons throughput vs . acre-day emissions factors). • Confidentiality of individual survey fonns for all. reSponding facilities (non-CMA
. members). ·

A 

# (

### Revised PMlO Emissions Inventories and Assumptions
7 

### A. Pre-Rule As stated earlier, baseline (pre-rule) PM10 emissions for the aggregate and related operations were estimated to be 29 tons per day (Rule 1157 Staff Report, December 3,
· 2004 ). It 

### should be noted that industry representatives provided valuable additional information that assisted in refining certain key asswnptions. The revised PMIO baseline emissions inventory is now estimated to be 13
. 7 tons per day, which representS a 53% decline f:rom the adopted Rule 1157 emissions inventory. The increase in the current level of pre-rule control from 20% to 50% and other revised assumptions resulted in lower PM10 baseline emissions for process equipment, open piles/storage, and unpaved roads. However, baseline emissions from paved roads increased because it was agreed that emissions from these roads have been essentially uncontrolled up to the time that the rule was adopted. B. Post-Rule For PMIO emission reduction calculations (post-rule), staff has agreed to assign a 95% control efficiency to water application based on the assumption that the industry will 

### strictly adhere to the PMIO control requirements of Rule 1157. Using the revised PMIO baseline emissions, staff recalculated the PMIO emission reductions for each PM10 emission source. The revised total PMlO emission reduction is now 5
.7 tons per day 

### based on the revised baseline versus 18 tons per day reduction as reported in the Staff Report for Ru1e 1157. The remaining inventory with full implementation of Rule 1157 is 

### now 5.3 tons per day (versus II tons per day as reported in the Staff Report for Rule 1I57).

· The final revised pre-and post-Rule 1157 emissions inventories were sent to CMA

representatives on October 6, 2006. A letter of response from CMA dated October 17, 2006 indicated that CMA has agreed to · the revised pre-and**pos~rule** 

### emissions inventories presented by staff, notwithstanding the remaining areas of disagreement. CMA recognized the significant progress in refining the emissions inventory and the <:fevelopment of a better working relationship as both parties continue to work on other areas of the settlement agreement. It 

### should be noted that CMA' s calculations put the pre- and post-rule emissions for the industry at less than half that of staff's calculations. Figure A 

### provides a summary of the emissions from this industry assumed in the 2003 · AQMP, the baseline and post-rule implementation remaining emissions included in the December 2004 

### Staff Report, and the revised baseline and remaining emissions, which will 

### be incorporated into the 2007 AQMP.

-5-i -



### 35 

## >- as 30 

# a 25 

# ... 

# :. 20 (I) 

### 15 c:: 0 

### 1- 

### 10 

### 5 0 Figure A: Rule 1157 Revised Inventory 

### Comparison

2003AQMP 2004 Staff

(BCM-08) 

### Report Revised Inventory •Pre-Rule • Post-Rule



### Appendix A shows a comparison of the revised PMIO baseline emissions and remaining PMl0 emissions by category wi th 

### those presented in 

### the December 2004 Staff Report. Attachments 

### A

- 1. Comparison of PMlO Baseline Emissions (Pre-Rule 1157 Inventory) A-2
. Comparison of PMlO Remaining Enussions (Post

- Rule 1157Inventory)

- 6 -

### Appendi x A Table A-1 Compari s on of PM 10 

### Ba se line E mi ss ion s (Pre-Rul e 1157 In v ento ry)

gg g 

# I 6.40 

# I 1.25 

# I 1.70 

# I 0.95 

### I 8.33 

### I 3.97 

### I 0
. 27 

### I 1
.43 

### I 16.70 

### I 7.60 Concrete Batching 

# I 2.90 

# I 0.35 

# I 0.10 

# I 0.05 

# I o.12 

# I 0.06 

# I o.o8 

# I 0.24 

# I 3
. 2o 

# I 0.70 Hot Mix Asphalt 

# 1 1
. 20 

# I 0.93 

# I 0
. 90 

# I 0
. 58 

# I o.25 

# I 0.12 

# I 0
. 25 

# I 1.27 

# I 2
. 60 

### I 2
. 90 Concrete Products 

# I 3
. 50 

# I 0.64 

# I 0
. 52 

# I 0.32 

# I o.o3 

# I 0.01 

# I 0.07 

# I 0.13 

# I 4.12 

# I 1
. 10 Crushed Misc

. Base 

### 0.20 0
. 05 0.20 0
. 12 0
. 03 0.01 0.01 0
. 05 0.44 0
. 24 Other 

### 0.03 0.02 1.90 1.08 0.00 0.00 0.03 0.05 1
. 96 1.15 TOTAL 

# I 14.23 3.24 5.32 3.10 8.76 4.17 0.71 3.17 29.02 13.68

Note : Some lin e- ite m total s may not sum exactly due to numerical rounding.

A- 

### 1

### A pp e ndi x A ( continu e d ) Tabl e A-2 Co mp a r iso n o f PM 10 

### R e m a in i n g E m iss i o n s (Post- Rul e 1 157 I n ve nto ry)

99 9 1 

### 1
. 69 I 

### 0
. 16 I 

### 0.84 I 

### 0 .1 0 I 

### 2.16 I 

### 2
. 33 

### I 0
. 07 

### I 0
. 57 

### I 4.76 

### I 3
. 16 Concrete Batchin9 

# I 2
. 57 

# I 0.25 

# I 0
. 03 

# I 0
. 02 

# I 0.02 

# I 0
. 02 

# I o.o2 

# I 0
. 10 

# I 2.64 

# I 0
. 39 Hot Mix Asphalt 

# I 

# o . 18 I 0
. 75 

# I o . 47 

# I 0.06 

# I 

# o . o1 I 0
. 05 

# I o . o6 

# I 0
. 51 

# I 1
. 38 

# I 1
. 37 Concrete Products 

# I o.81 

# I 0
. 10 

# I o.28 

# I 0.05 

# I o . o1 

# I 0
. 00 

# I o.o2 

# I 0.05 

# I 1.12 

# I 0.20 Crushed Misc

. Base 

### 0.05 0.01 0
. 10 0
. 01 0.01 0
. 00 0.00 0
. 02 0.16 0
. 04 O t her 

### 0.02 0.00 0
. 87 0
. 11 0.00 0.00 0.01 0
. 02 0.90 0
. 13 TOTAL 

### 5
. 92 1.27 2
. 59 0.34 2
. 27 2.41 0.18 1. 27 10
. 96 5
. 29

No te: So me line -i te m total s m ay not s u m ex actl y du e to numerica l roundin g.

A 

### -2

# Attachment 2

### Comparison of Assumptions for PM 10 

### Baseline Emissions



# .....**""""""*****~~ --~** **~'~** 

### - -**..- J!.** **~** ::c:; c;ousen; . ; _ QCA!;J44 .......--**...,.~f'.__. 'F** **~** '""'**~** ·

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. .•. . ._ .**<l nl** **u~..:** Ac uv ny 

### lrrr .... d

## ~~:•**:·** '"r o11phr11 t d<1 ta (sur-.·r:') For Aggregate/CMB : E = (Annual throughput x 2 x EF I 2000) x CF For CBIHMA/CP/Others: E = (Annual throughput x EF 12000) x CF
where : E = PM 10 emissions, tons/yr EF = PM 10 emission factor , lbs/ton CF = control factor 

### = 1-control efficiency (CE)

Note: For Aggregate/CMBIHMA : • EF aggr .==0
.0011 lb/ton (AP-42) For CB / CP /Others: • Staff assumed throughput composition of 50% aggregate l\lld 50% sand (from San Diego APCD) • EF aggr.==0
. 0033 lb s/ ton (AP-42) EF sand=0
. 00099 lb s/ ton (AP-42)

CE wllte1(cutTent level) r:: 20% based on the following: • 75% of aggregate facilities use water for control (survey data) • assume water is used <30% of time based on field observations

Post Rule 1157 CE water= 60 % U sr d**nn ~IJ** **l** t hr ough put from survey. Ad just e d thro ughpu t acco rdingly to composition. For Aggregate/CMBIHMA: • EF aggr, uncontrolled.=O.OOll lb/ton ( AP-42 ) ForCB : • Throughput compos iti on : assumed 41 o/o dry aggregate ( 1 12 of82% total aggr.) • EF aggr . , uncontrolled=0.0033 lb/to n (AP -4 2) For CP / Others : • Throughput composition: assumed 50 % aggregate and 50 % sand (San Diego APCD ) • EF aggr. , uncontrolled=0
.0033 lb /ton (AP-42) • EF sand, uncontrolled=0
. 00099 lb /ton (AP-42) ForHMA : • Throughput composition: assumed 92% aggregate CE w.m- (current level)

- SO% based on the following assumptions: • 75% of aggr. fac
. use water for contro l (survey data ) • Water is used 65% of the time (survey data , permit conditions, NOVs/NCs , & field observations)
Post Rule 1157 CE water-= 95 % · (AP-42 and AOMD**Emtineerin~)** Aggr
. = Aggregate CB ""' Concrete Batching 

### HMA 

### = Hot Mix Asphalt CMB 

### =Crushed Miscellaneous Base CP = Concrete Product


### Page 1

### Comparison of Assumptions for PM 10 

### Baseline Emissions

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### x annual operating hrs X EF/2000) X CF 

### where : E = PM 10 e!l1issions, tons/yr EF = PM 1 0 emission factor, lbs/ton CF = control factor = 1- control effic iency (CE)

Note : Used hourly throughput data (survey)

Same emission factors and assumptions as in Loading/Unloading activity Used hourly throughput data from survey Annual operating hours = annual throughput I plant capacity Used same pre -rule and post-rule CE as in Loading/Unloading activity For Aggr /CMBIHMA: • Used same emission factor as in Loading/Unloading activity (0.0011 lb /t) ForCB: • EF uaconii'Oikd = 0
.0024 lb/ton (AP-42) For CP/Others: • Used same assumptions and EFs as in Loading/Unloading activity.

Aggr. 

## = Aggregate CB : Concrete Batching HMA ==Hot Mix Asphalt CMB = Crushed Miscellaneous Base CP 

## = Concrete Product



### Page2**Com~arison** 

### of Assumptions for 

### PM1o Baseline Emissions

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..... .-.;-**,, <Tol;**  E = (Hourly throughput x annual operating hrs X EF /2000) X CF X N where : E = PM 10 emissions, tonslyr EF = PM 10 emission factor, Ibslton CF = control factor = I

- control efficiency (CE) N =number oftransfer points

Note: Used hourly throughput data (survey)

For AggrJ CMBIHMA/CP /Others : • Same emission factors and assumptions as in Loading/Unloading activity ForCB: • EF=0
. 0024 lb /ton (AP-42) Used hourly throughput data ( survey). Adjusted throughput accordingly to composition. Annual operating hours = annual throughput I plant capacity Used same pre-rule and post-rule CE as in Loading/Unloading activity For Aggr .ICMB/HMA : • Same emission factor (0
.001 1 lb / t) as in LoadinEitJnloading activity ForCB: • Assumed throughput composition of 50% aggregate & only aggregates are transported by conveyors • EF a&v. · · UIICOIIUOilcd= 0.0033 lb s/to n (AP-42) For CP /Others : • Used same assumptions and EFs as in Loading/Unloading activity
.

Aggr
. =Aggregate CB = Concrete Batching HMA =Hot Mix Asphalt CMB = Crushed Miscellaneous Base CP

- Concrete Product



### Page 3

### Comparison of Assumptions for PM 10 

### Baseline Emissions

E = (Hourly throughput x annual operating hrs X EF/2000) X CF where : E = PM 10 emissions , tonslyr EF = PM 10: emission factor, lbslton CF = control factor = 1 -control**efficiency~CE)**

Note : Used hourly throughput data (survey)

For Aggregate/CMB/HMA : • Assume 50% tertiary crushing and 50% fines crushing • Assume BACT requirements are met (baghou s e) • EF reniory,conuoued=0.00054 lbs/ ton (AP-42) • EF rllles,cODrrolled=O.OOl2 lbslton (AP-42)

ForCP: • Assumed that crushers meet BACT requirements EF**autber.con~rollc.t=0.00059** lbslton (AP-42 Used hourly throughput data (survey). Adjusted throughput accordingly to composition
. Annual operating hours 

### = annual throughput I plant capacity Based on industry input, only 20% oftotal material throughput is processed by primary crushers ; the rest is either processed by secondary and/or tertiary crushers For Aggr ./ CMBIHMA : • No fine crushing ( industry input) • EF terti"!)'. unconrrolled = 0 .00 24 lb /ton (AP-42 ) • 30% ot facilitie s use water at 65 % of the time & 70% use baghouse for control (survey data) • CE..aser= 95% •**CEba~=99%** • Pre-rule overall CE: (30% X 95 % X 65%) + (70% X 99%) 

### = 87.8% (This is higher than the 77.5% CE for tertiary crushing in AP-42) • PosHule CE : (30% X 95%) + (70% X 99%) = 97. 8% ForCP : • Same assumption and emission factor as in staff report EFcrushet ,concrolled = 0
. 00059 lbslton (AP-42)
Aggr
. =Aggregate CB = Concrete Batching HMA = Hot Mix Asphalt CMB = Crushed Miscellaneous Base CP • Concrete Product 

### Page4

### Comparison of Assumptions for PM to 

### Baseline Emissions
EMISSION SOURCE STAFF RiPORT REVISED STAFF REPORT Screening Equipment E = (Hourly throughput x annual operating Used hourly throughput data (survey) Used hourly throughput data (survey)
. Adjusted throughput accordingly to composition
. hrs X EF/2000) X CF where : Annual operating hours = annual throughput I plant capacity E = PM1o emissions, tons/yr EF -= PM1o emission factor, lbs/ton For Aggr ./ CMB : For Aggr ./ CMB: CF ==control factor 

## • assume 50% fine screening and SO% coarse 

### • Assumed 20% fme screening and 80% coarse == 1

- control efficiency (CE) screening screening (industry input) 

## • EF coarse,WICO"tronect=0.0087 lbslton (AP-42 

## • EF coartC, uncontrolled= 0
. 0087 lb/ton (AP-42 

## • EF**fines.un ~ontron** **ect=0 072**  lbs/ton (AP-42) 

## • I:;F**r~nu .**  uncontrolled= 0
. 072 lb/ ton (AP-42) 

## • CE : assume SO% based on current level of 

## • 7S% of facilities us e water at 6S% of the time watering/misting observed & 2S% use baghouse for**c~mtrol** (survey data ) 

## • CE-tcr=9S% 

## • CEI>aaho-=99% 

## • Pre-rule overall CE : 

## • (75% X 95% X 65%) + (25% X 99%) = 71.1% Post-rule CE : (75% X 95%) 

### + (25% X 990/o) = ·96.1%
ForCP : ForCP: 

## • EF-ne.r=O.S3 lb/ton (AP-42) 

## • EFuncoDUO\Ie<l= ().53 lb/ ton (AP-42 

### • CE: assume SO% based on current level of watering/misting observed 

## • Same pre-rule (71.1%) and post-rule (96
. 1%) CEs as Aggr./CMB
ForHMA : ForHMA : Assume 100% controlled 

## • Assumed that only RAP (recycled ·aggregates) EF-11ecf"0.0098 lb/ton (AP-42) are screened with this equipment 

## • EF c.ovK. .-o11e4- 0.0087 lb/ton (AP-42 

## • Same pre-rule (71.1%) and post-rule (96.1%) CEs as Aggr JCMB Aggr. 

## =Aggregate CB = Concrete Batching CMB 

## =Crushed Miscellaneous Base CP "' Concrete Product HMA = Hot Mix Asphalt


### Page5

### Comparison o

_ f Assumptions for PM 10 

### Baseline Emissions

E = Hourly throughput x annual operating hrs X EF /2000 where: E = PM 10 emissions, tons/yr EF = PM 10 emission factor , lbslton • Assume all milling equipment are controlled • EFcontrotled 

### = 0.0032 lb / ton (AP-42) Used hourly throughput data (survey) Annual operating hours = annual throughput I plant capacity Same assumption/emission factor as i n staff report

E = Silo annual throughput x EF I 2000 where: • Assume 85% ofthroughput is cement and 15 % is fly ash Used silo throughput from survey E = PM 1o emissions, tons/yr EF = PM 10 emission factor , lbs/ton

E = Annual throughput 

### x EF I 2000 where : E 

## =PMto emissions, tons/yr EF = PM 10 emission factor, lbs/ton

Note : • Assume all silos are controlled (baghouse) •**EFcemen~> ~lllrolled=**  0.00034lb / ton (AP-42) • EFo yuh.coatroUed= 0
. 00491b/ ton (AP-42)

• EFcontro1te.t = 0.051 lb/ ton (AP-42

Aggr. =Aggregate CB = Concrete Batching CMB = Crushed Miscellaneous Base



### Page6 Adjusted throughput accordingly to same composition assumptions as in staff report. Used same**emissio~** factors as in staff report
Used annual throughput from surve y. Adjusted throughput accordingly to compo sition. ForCB: • Assumed throughput composition of 12% cement + 2% admixture Same emission factor as in staffreport

CP = Concrete Product HMA 

### = Hot Mix Asphalt

### Comparison of Assumptions for PMto 

### Baseline Emissions**A~!)llall** L vli U

- UU ( E =( Annua l throughput x EF ) /2000 where: E = PM 10 emissions, tons/yr EF = PM 10 emission factor, lbs/ton

where : E = PM 10 emissions, tons/ yr EF = PM 10 emission factor, lbs/ton CF = control factor 

### = 1-control efficiency (CE)

E = Hourly throughput X annual operating hrs xEF / 2000 where: E = PM 1o emissions, tons/yr EF'"' PM 10 emission factor, lbs/ton

Note: • EFPM
. cootrolled = 0
. 0003 lb/ ton (AP-42) • EFPMIO, conlrolled = 0
. 5 X EFPM.COIIIrOlled

• EFPM. IIIIControlle<f = 0
. 33 lb /ton (AP- 42) • EFPMIO, IUICOIUrolled = 0
. 5 X EFPM. unc:ont • CE water (current level)= 20% • CE water (post 1157) = 60%

Did not separate amount of aggregates to be screened by different equipment Used annual throughput from survey Used same emission factor as in staff report

• Same emissions factors as in staffreport • CE water (current level)= 50% • CE water (post 1157) = 95% Note: AP-42 allows the use of either surface area EF or material weight EF

ForHMA : • Used hourly rate in the survey • Annual operating hours 

## = annual throughput I plant capacity • Assumed that all aggregates are processed by this equipment • EF PMIO , COftiiOtleC 0
. 027 lb / t (AP-42)

Aggr. = Aggregate CB 

## = Concrete Batching CMB = Crushed Miscellaneous Base CP = Concrete Product HMA 

### = Hot Mix Asphalt. 

### Page7E 

### = VMT X k X (S / 12) 1 X (W / 3)b where: E = PMao emissions, tonslyr VMT = annual vehicle miles traveled k , a,b = constants k = 1
. 5 lbs/VMT (AP-42) a= 0.9 (AP-42) b = 0.45 (AP-42) S = surface material silt content in% W = 

### mean vehicle weight in tons

Note : 

### Comparison of Assumptions for PM 1 

### o 

### Baseline Emissions

VMT =(road length (ft) x #truck trip s/ da y x # days/yr) x l mile I 5280 ft

Assumed that W unla.cled btu! cruck
.. 1 OOt, W**a-~ed** baultru<Jc = 150 t, W W\lo..scd**~truck=** 5 t, and W lo.ded 110ft-haul cruck = 30 t (industry's input). Assumed that 50% of the vehicles were loaded and 50% were unloaded For aggregate facilities : • SHaul roed = 8
. 3% (AP-42) • SNoo-haulroad = 10% (AP-42) For other facilities: • SIUul-.t = 7.1% (AP-42) • SNOftolwalroed = 4.8% (AP-42) Assumed CE for chemical stabilizer = 80% VMT = (road le ngth (ft) 

### x # truck trip s/ yr 

### x l mile / 5280 ft • # truck trip/yr = annual throughput I truck capacity • Assumed truck capacity : 75 tons Assumed that W unloaded haul cruck= 45 t, W loaded
...... cruck=120 t, based on most popular size truck Assumed same weights of non -haul trucks as in staff report Assumed that 50% of the vehicles were loaded and 50% were unloaded Assumed same silt content values as in staff report

Pre-rule CE for water = 50% Assumed pre & post-rule CE for chemical stabilizer = 80%

Aggr
. 

### =**Aggregat~** · CB = Concrete Batching CMB = Crushed Miscellaneous Base CP = Concrete Product HMA c Hot Mix Asphalt



### Page 8

# .- Inte rn a l Pave d Roa d E = VMT x k x (sUl2) 0

·63 x (W/3)1.s where : E = PM 10**emissions~** ton slyr VMT ,.. annual vehicle miles traveled k == 0
. 016 lbs!VMT (AP-42) sL == road surface silt loading value in gjm 1 W == mean vehicle weight in tons

Note : Aggr
. ==Aggregate CP 

### = Concrete Product 

### Comparison of Assumptions for PM 10 

### Baseline Emissions

_...__ .._. __ -' : , .. ··. ' '-· - l'**pr ~-** **,..- ,,-** **.** ·'5··**·:~ ,..** **....::-** ...**.,Jfl'" ~l** **Jf, f'•Jo**  .,..,!-ief VMT =(road l en gth (ft) x #truck tri p s/ d ay x # days lyr) x lmile 15280 ft

sL= 1.45 gj m 2 (Catalina Pacific Concrete source te s t data ; Staff later determined that this value is for controlled environment) Assumed**ooc~ed=30t** and W lllllooded==5t (industry input)

Assumed that 50% of the vehicles were loaded and 50% were unloaded Assumed CE=SOo/o for chemical stabilizer VM T 

### = ( r oa d le ngth (ft) x # truck trlp s/ yr x 1 mile I 5280 ft
• # truck trip/yr 

### =annual throughput I truck capacity • Assumed tnlck capacity: 25 tons
Same data and assumptions as in staff report except for sL values as follows : • . sL •ap-eam.cMa= 53 glm2 • sL CB ,CP,Oihcn= 1 1 gjm 2 • SL H M

A= 76 g/m 2 ( The above sL values are the lowest sL from AP-42) Pre-rule CE for water = 50% Assumed pre & post-rule CE for chemical stabilizer = 80%

CB = Concrete Batching HMA == Hot Mix Asphalt CMB = Crushed Miscellaneous Base



### Page9