SOURCE TEST REPORT 

2010 EPA ICR HCl TESTS 

LEHIGH SOUTHWEST CEMENT COMPANY 

RAW MILL CEMENT KILN 

REDDING, CALIFORNIA 

Prepared For: 

Lehigh Southwest Cement Company 

15390 Wonderland Blvd. 

Redding, CA 96003 

For Submittal To: 

United States Environmental Protection Agency 

Research Triangle Park, NC 

Prepared By: 

Mark Stanfield 

The Avogadro Group, LLC 

2825 Verne Roberts Circle 401 Pech Road 

Antioch, California 94509 Central Point, Oregon 97502 

(925) 680-4300 (541) 665-0170 

March 31, 2010 

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SUMMARY INFORMATION 

Source Information

Source Location: Lehigh Southwest Cement Company 

15390 Wonderland Blvd. 

Redding, CA 95017 

Plant Contacts: Mr. Kent Stringham 

Title: Environmental Engineer 

Telephone: (530) 275-1581, Ext. 3337 

Facsimile: (530) 275-2525 

Regulatory Agency: United States Environmental Protection Agency 

Contact: Mr. Keith Barnett 

Unit: Pre-Heat In-Line Raw Mill Cement Kiln 

Purpose: Determination of HCl concentrations and emission rates 

Procedures: EPA Methods 1, 2, 3A, 4 and 321 

Testing Company Information

Testing Firm: The Avogadro Group, LLC 

 401 Pech Road 2825 Verne Roberts Circle 

 Central Point, OR 97502 Antioch, CA 94509 

Contacts: Mr. Mark Stanfield Mr. Erick M. Mirabella 

 Project Manager General Manager 

Telephone: (541) 665-0170 (925) 680-0935 

Facsimile: (541) 665-0802 (925) 680-4416 

Test Dates: March 16 and 17, 2010 
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TABLE OF CONTENTS 

SECTION PAGE

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

2.0 TEST CONTRACTOR .........................................................................................4

3.0 FACILITY DESCRIPTION .................................................................................5 

3.1 UNIT DESCRIPTION .................................................................................5 

 3.1.1 Raw Mill Feed System .....................................................................5 

 3.1.2 Raw Mill System..............................................................................6 

 3.1.3 Raw Feed Blending and Storage System .........................................6 

 3.1.4 Rotary Kiln and Pre-heater ..............................................................6 

3.2 KILN FUELS ...............................................................................................6 

 3.2.1 Coal and Coke ..................................................................................6 

 3.2.2 Natural Gas ......................................................................................7 

 3.2.3 Tire Derived Fuel (TDF) ..................................................................7 

 3.2.4 Medium Density Fiberboard (MDF) ................................................7 

3.3 EMISSION CONTROL EQUIPMENT .......................................................7 

3.4 SAMPLING LOCATION ............................................................................7 

4.0 PROGRAM DESCRIPTION ................................................................................9 

4.1 PROGRAM OBJECTIVES .........................................................................9 

4.2 TEST MATRIX ...........................................................................................9 

4.3 TEST CONDITIONS .................................................................................10 

 4.4 PROGRAM TEST SCHEDULE ...............................................................11 

5.0 TEST PROCEDURES .........................................................................................13 

 5.1 PRIMARY EMISSIONS TESTS ..............................................................13 

 5.1.1 Hydrogen Chloride (HCl) ..............................................................14 

 5.2 ANCILLARY TESTS ................................................................................21 

 5.2.1 Gaseous Emissions.........................................................................22 

 5.2.2 Volumetric Flow Rates and Moisture Content ..............................23 

6.0 QUALITY ASSURANCE AND REPORTING .................................................24 

 6.1 SAMPLING AND ANALYTICAL QA/QC .............................................24 

 6.2 QUALITY CONTROL REQUIREMENTS ..............................................24 

 6.3 DATA REDUCTION PROCEDURES .....................................................24 

7.0 DISCUSSION OF RESULTS .............................................................................26 
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TABLE OF CONTENTS (Continued) 

SECTION PAGE

APPENDICES 

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

B QUALITY ASSURANCE PROCEDURES ........................................................ B 

 B.1 QUALITY ASSURANCE PROGRAM SUMMARY 

 B.2 ARB TEST METHOD CERTIFICATIONS 

 B.3 CEMS PERFORMANCE AND EQUIPMENT CALIBRATION 

DOCUMENTATION 

C SUPPORTING DATA .......................................................................................... C 

 C.1 SAMPLE LOCATION 

 C.2 PLANT PROCESS DATA 

 C.3 AVOGADRO CEMS DATA 

D FIELD DATA SHEETS ....................................................................................... D 

E EMISSION CALCULATIONS ........................................................................... E 

 E.1 GENERAL EMISSIONS CALCULATIONS 

 E.2 EMISSION CALCULATION SPREADSHEETS 

 E.3 EXAMPLE HAND-WRITTEN CALCULATIONS 
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SECTION 1.0 

INTRODUCTION

The Avogadro Group, LLC (Avogadro) was contracted by Lehigh Southwest Cement 

Company (Lehigh) to perform a series of HCl emission tests at their facility in Redding, 

California. The tests were conducted according to the United States Environmental 

Protection Agency (EPA) Information Collection Request (ICR) letter dated February 3, 

2010. Testing was performed on March 16 and 17, 2010 by Mark Stanfield, Robert 

Odell and Charles Hidde of Avogadro. Mr. Ross Bell of the Shasta County Air Quality 

Management District (SCAQMD) was present to observe portions of the test program. 

Emission measurements were made during two testing scenarios under normal operating 

conditions: 1) With the roller mill on; and 2) while the roller mill was off. 

The results of the testing program are presented in this report and are intended for the end 

users (Lehigh and EPA). This report includes descriptions of the scope of work for 

measurement of air emissions, the testing methods and analysis procedures, the sampling 

and traverse point locations, the field data and calculation spreadsheets, the test results, 

and the quality assurance procedures. The results of the testing program are summarized 

in Tables 1-1 and 1-2. Section 7.0 presents detailed results for individual test runs. 

Avogadro provided the test personnel and equipment to measure emissions as described 

in this report. Lehigh personnel coordinated the unit operating conditions and provided 

the process data included in this report. 
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TABLE 1-1 

SUMMARY OF AVERAGE HCl TEST RESULTS 

LEHIGH SOUTHWEST CEMENT COMPANY 

TESTS CONDUCTED WITH THE ROLLER MILL ON 

MARCH 16, 2010

Parameters Average 

Stack Gas 

O2, % volume dry 11.13 

CO2, % volume dry 16.57 

Moisture content, % by volume 14.8 

Stack gas temperature, °F 224.8 

Stack flow rate, dscfm 134,382 

Process Data 

Kiln feed rate, ton/hr 147.45 

HCl 

ppmvd 2.08 

ppmvd @ 7% O2 2.96 

lb/hr 1.58 
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TABLE 1-2 

SUMMARY OF AVERAGE HCl TEST RESULTS 

LEHIGH SOUTHWEST CEMENT COMPANY 

TESTS CONDUCTED WITH THE ROLLER MILL OFF 

MARCH 17, 2010

Parameters Average 

Stack Gas 

O2, % volume dry 9.039 

CO2, % volume dry 20.06 

Moisture content, % by volume 14.9 

Stack gas temperature, °F 282.0 

Stack flow rate, dscfm 111,803 

Process Data 

Kiln feed rate, ton/hr 145.71 

HCl 

ppmvd 22.73 

ppmvd @ 7% O2 26.76 

lb/hr 14.50 
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SECTION 2.0 

TESTING CONTRACTOR

The emission tests were conducted by Avogadro, 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 provided a professional source test team to conduct the 

testing as described in this report. The Avogadro personnel who participated in this 

project are listed in Table 2-1. The test team members are experienced and well versed 

with the test methods and field procedures used for the testing program. 

TABLE 2-1 

AVOGADRO TEST PROGRAM PERSONNEL 

LEHIGH SOUTHWEST CEMENT COMPANY 

Personnel Title Assignment Experience 

Mark Stanfield Scientist I Project Manager 9 years 

Dan Duncan IT/Lab Director QA Officer 23 years 

Robert Odell Senior Technician FTIR Technician 3 years 

Charles Hidde Senior Technician Field Technician 9 years 
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SECTION 3.0 

FACILITY DESCRIPTION

Lehigh Southwest Cement Company operates a Portland cement plant in Redding, 

California using a pre-heat inline raw mill cement kiln to provide raw cement to ready 

mix companies throughout the area. The plant was constructed in 1961 as a long dry 

process kiln and later modernized in 1981. 

The manufacturing process involves combining crushed limestone, shale, silica and other 

materials containing alumina, silica, calcium and iron in the proper proportions and 

subjecting a milled blend to extreme temperatures in the kiln. Chemical reactions occur 

that create a new mineral compound, known as clinker. The clinker is ground to a prespecified fineness and combined with calcium sulfate to increase the setting time of the 

cement. The plant manufactures several cement products and markets them in bulk and 

in sacks. 

3.1 UNIT DESCRIPTION 

Crushed shale, limestone, siliceous material and other necessary raw materials from the 

quarries and crushing department are combined in the raw mill feeding system and 

ground in the raw mill system. The crushed and blended kiln feed is managed in the raw 

feed blending and storage system. The kiln feed is routed to the rotary kiln and preheater system for cement clinker production. The kiln fuels are managed and processed 

in the kiln fuels processing system. Clinker is milled in the finish grinding department. 

3.1.1 Raw Mill Feed System

The raw mill feed system consists of raw material storage silos, weigh feeders for each 

silo and a belt conveyor that feeds the roller mill. The different raw materials enter 

storage silos via belt conveyors from the quarries and crushing department. Weigh 

feeders at each silo are set to achieve satisfactory raw material chemistry. If necessary, 

iron ore or other raw material additives can be added onto the conveyor that feeds the 

roller mill. 

Dust collection for the belt and transfer into the raw material storage silos is provided by 

dust collector C172. Dust collection for the belt transfer from the silos onto the roller 

mill feed belt is provided by dust collector S210. 
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3.1.2 Raw Mill System

The raw mill system receives a prescribed feed from the raw mill feed system. A roller 

mill crushes and grinds the feed to prescribed fineness. Exhaust gas from the kiln is 

swept through the mill and carries the crushed product into cyclones. The overhead 

cyclone discharge recombines with kiln gases, discussed in the rotary kiln and pre-heater 

section below. Cyclone bottoms are routed to the raw feed blending and storage system, 

which is described below. 

3.1.3 Raw Feed Blending and Storage System

Blending silos are filled with raw mill system product. Kiln feed storage silos are filled 

from the blending silos. Material is transferred from either silo to the rotary kiln and preheater section. Dust collectors S253, F185 and F173 service this system. 

3.1.4 Rotary Kiln and Pre-heater

The rotary kiln is fed from the raw feed blending and storage system. Feed is preheated 

in a four stage cyclonic pre-heater using kiln exhaust gases. The kiln is heated by the 

combustion of fossil, agricultural waste and rubber fuels and is described in Section 2.2. 

Mineral formation occurs in the kiln to produce clinker, which is managed by the clinker 

transport and storage system section described below. Dust collector F350 services the 

equipment necessary for the introduction of raw feed into the clinker handling system. 

The exhaust gases from the pre-heater are cooled in a spray tower and routed to the 

plant’s main baghouse, S260. A portion of the gas may be swept through the roller mill 

and recovered prior to S260. The cement kiln dust is recovered and re-introduced as kiln 

feed. The baghouse exhaust is routed through a 277 ft. stack to the atmosphere. 

3.2 KILN FUELS 

The kiln is heated by the combustion of various solid fuel materials. Mill processing and 

associated storage/delivery systems exist to prepare solid organic fossil and petroleum 

based fuels (e.g., coal, coke, etc.). Conveying systems provide delivery of TDF (whole 

rubber tires) and MDF (medium density fiberboard sawdust). Each is described below. 

3.2.1 Coal and Coke

The raw solid fuel, primarily coal and coke, is delivered by rail or truck and conveyed to 

a storage silo or deposited onto the ground as a pile. Dust collection for the silo is 

provided by G206. The raw fuel is conveyed from the silo at a specified rate to a roller 

type mill. A portion of the kiln inlet gas is swept through the mill and carries the crushed 

product to dust collector G465. The recovered crushed product is routed to feed bins. 
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The crushed fuel is pneumatically conveyed from the bins to either the kiln burner pipe 

or the kiln pre-heater. 

3.2.2 Natural Gas

The kiln is capable of firing gas as one of the various fuels used at the facility. The 

metered gas is conveyed via pipeline into the plant and used on rare occasions during 

start-up procedures or upset conditions (e.g., interruption of tire fuel feed). 

3.2.3 Tire Derived Fuel (TDF)

Scrap whole and chipped tires can be delivered to the kiln pre-heater using conventional 

conveyor belt and conveyor chain techniques. The delivery rate is prescribed and 

controlled by the process operators. Dust collection is not necessary for this operation. 

3.2.4 Medium Density Fiberboard Sawdust (MDF)

A byproduct of the local engineered wood products industry, MDF sawdust is delivered 

to the plant by truck. The sawdust is used to augment the primary fuels used to heat the 

kiln. The delivery rate is prescribed and controlled by the process operators. 

3.3 EMISSION CONTROL EQUIPMENT 

Combustion emissions from the kiln burning operation are minimized by skilled 

operation and computer control of the process. The plant utilizes dust collection control 

equipment (baghouse) to minimize particulate emissions from point sources. The kiln 

also includes a continuous emission monitoring system (CEMS) that monitors emissions 

of CO, NOX and SO2 as well as flue gas opacity. 

3.4 SAMPLING LOCATION 

Emissions from the kiln travel through a vertical, cylindrical stack measuring 83.5 inches 

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

same horizontal plane. The ports are located more than two stack diameters upstream 

and eight stack diameters downstream from the nearest flow disturbances. Because of 

Avogadro’s many years of experience testing this unit, it has been well established that 

the stack gas exhaust stream meets the criteria for single point sampling for gaseous 

pollutants. As such, a single sampling point was used for this test. The Method 321 

sample probe was co-located with Avogadro’s CEM probe in the center of the stack for 

all test runs. Access to the sampling location is by stairway or elevator to a permanent 
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testing platform approximately 120 feet above ground level (the ports are five feet above 

the platform). 

Avogadro personnel verified the dimensional measurements of the stack prior to testing. 

A diagram of the sampling and traverse point locations is included in Appendix C.1. 
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SECTION 4.0 

PROGRAM DESCRIPTION

4.1 PROGRAM OBJECTIVES 

The objective of the program was to provide test results to be used in EPA’s proposal to 

amend the national emission standards for hazardous air pollutants for Portland cement 

manufacturing. The results are presented in units consistent with those outlined in the 

EPA ICR letter dated February 3, 2010. 

4.2 TEST MATRIX 

Table 4-1 presents the sampling and analytical matrix including all of the measurements 

performed. 

TABLE 4-1 

TEST MATRIX 

LEHIGH SOUTHWEST CEMENT COMPANY 

RAW MILL CEMENT KILN 

2010 HCl TESTS 

Emission 

Parameter 

Reference 

Method 

Sample 

Runs 

Test 

Condition 

Sample 

Time 

Analytical 

Method 

Analytical 

Laboratory 

O2 EPA 3A 1, 2, 3 

1, 2, 3 

Mill on 

Mill off 

With 

each run Paramagnetism Mobile lab 

CEMS 

CO2 EPA 3A 1, 2, 3 

1, 2, 3 

Mill on 

Mill off 

With 

each run 

Non-dispersive 

infrared 

Mobile lab 

CEMS 

HCl EPA 321 1, 2, 3 

1, 2, 3 

Mill on 

Mill off 

60 

minutes FTIR Mobile lab 

FTIR 

Volumetric 

flow rate EPA 1, 2 1, 2, 3 

1, 2, 3 

Mill on 

Mill off 

With 

each run 

Pitot tube 

traverse N/A 

Moisture 

content 

EPA 4 1, 2, 3 

1, 2, 3 

Mill on 

Mill off 

With 

each run 

Impinger 

weight gain N/A 
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4.3 TEST CONDITIONS 

The tests were conducted while the kiln was operating at representative feed rates of 

approximately 141-152 tons/hr. The tests were performed at each of two process 

conditions: 1) With the roller mill on; and 2) with the roller mill off. Lehigh personnel 

established and controlled the process conditions. 

The unit one-minute average operating data collected by Lehigh personnel are presented 

in Appendix C.2. A summary of the process data are presented in Tables 4-2 and 4-3. 

TABLE 4-2 

SUMMARY OF PROCESS DATA 

HCl EMISSION TESTS 

LEHIGH SOUTHWEST CEMENT COMPANY 

TESTS CONDUCTED WITH THE ROLLER MILL ON 

Test No.: 1-HCl-On 2-HCl-On 3-HCl-On Average 

Date: 3/16/10 3/16/10 3/16/10 -- 

Time: 0925-1025 1150-1250 1401-1501 --

Stack Gas 

O2, % volume dry 11.07 10.72 11.60 11.13 

CO2, % volume dry 16.62 17.18 15.92 16.57 

Moisture cont., % vol. 13.5 15.3 15.5 14.8 

Stack gas temp., °F 228.4 227.9 218.0 224.8 

Stack flow rate, dscfm 133,557 135,639 133,951 134,382 

Process Data 

Kiln feed rate, ton/hr 151.55 149.19 141.62 147.45 
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TABLE 4-3 

SUMMARY OF PROCESS DATA 

HCl EMISSION TESTS 

LEHIGH SOUTHWEST CEMENT COMPANY 

TESTS CONDUCTED WITH THE ROLLER MILL OFF 

Test No.: 1-HCl-Off 2-HCl-Off 3-HCl-Off Average 

Date: 3/17/10 3/17/10 3/17/10 -- 

Time: 0843-0943 1116-1216 1322-1422 -- 

Stack Gas 

O2, % volume dry 9.236 8.914 8.966 9.039 

CO2, % volume dry 19.74 20.16 20.29 20.06 

Moisture cont., % vol. 14.8 14.5 15.5 14.9 

Stack gas temp., °F 280.0 281.7 284.3 282.0 

Stack flow rate, dscfm 115,358 111,530 108,519 111,803 

Process Data 

Kiln feed rate, ton/hr 145.45 147.48 144.19 145.71 

4.4 PROGRAM TEST SCHEDULE 

Avogadro measured the emissions of the air contaminants, acquired the process data from 

Lehigh, and reported the results. The program schedule is presented in Table 4-4. 
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TABLE 4-4 

PROGRAM SCHEDULE 

HCl TEST PROGRAM 

DATE ACTIVITY SAMPLE RUNS

SAMPLE 

DURATION

March 15, 2010 Travel, set-up -- -- 

March 16, 2010 

(roller mill on)

Emissions testing

HCl 

O2, CO2

Vol. flow and moisture 

1, 2, 3 

1, 2, 3 

1, 2, 3 

60 min. ea. 

60 min. ea. 

120 min. ea. 

March 17, 2010 

(roller mill off)

Emissions testing

HCl 

O2, CO2

Vol. flow and moisture 

1, 2, 3 

1, 2, 3 

1, 2, 3 

60 min. ea. 

60 min. ea. 

120 min. ea. 

March 18, 2010 Tear down, travel -- 
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SECTION 5.0 

TEST PROCEDURES

5.1 PRIMARY EMISSIONS TESTS 

The tests for emissions of air contaminants were conducted according to the reference 

methods. Each method was used as a laboratory and field reference. A source test 

protocol, dated February 17, 2010 was submitted to the SCAQMD and subsequently 

approved. 

The test methods and procedures used in this program are listed in Table 5-1. Generic 

descriptions of the test methods are included in Appendix A. The site-specific 

applications and/or modifications to the methods are described in the sections that follow. 

Each description lists the version of the test method used as a reference, and the sections 

of the method for which choices were made, or for which specific modifications were 

planned. Where conflicts exist in the descriptions, the version here in Section 5.0 will 

take precedence. 

TABLE 5-1 

EMISSION TEST PARAMETERS AND METHODS 

LEHIGH SOUTHWEST CEMENT COMPANY 

TEST 

PARAMETER

REFERENCE 

METHOD

ANALYTICAL

APPROACH

DETECTION 

LIMIT

O2 EPA 3A Paramagnetism 2% of full scale 

CO2 EPA 3A Non-dispersive infrared 2% of full scale 

HCl EPA 321 FTIR ≤ 0.23 ppm 

Vol. flow rate EPA 1, 2 Pitot / temperature traverse -- 

Moisture content EPA 4 Impinger weight gain -- 
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5.1.1 Hydrogen chloride (HCl)

Method: EPA 321 

Deviations: Single point sampling 

End Users: Lehigh, EPA 

Tester: The Avogadro Group, LLC 

Contact: Mark Stanfield (541) 665-0170, fax (541) 665-0179 

Analyst: The Avogadro Group, LLC 

Contact: Michele Hoffman (925) 680-4300, fax (925) 680-4416 

Test Description: 

Extractive Fourier Transform infrared (FTIR) spectroscopic testing for hydrogen chloride 

was performed on an exhaust vent of a cement kiln at the Lehigh Southwest Cement 

Company facility in Redding, CA. Three test runs, each 60 minutes in duration, were 

conducted at the kiln stack during each of two conditions (with the raw mill on and the 

raw mill off). 

FTIR spectrophotomer:

The FTIR spectrometer used for this test was equipped with a (nominal) 10-meter 

absorption cell. The spectrometer operated at 0.5 cm-1 spectral resolution. It employed a 

Michelson interferometer, mercury-cadmium-telluride (MCT) detector cooled to liquid 

nitrogen temperature (77 K), beam splitter, and cell windows of zinc selenide (ZnSe), 

hot-wire infrared radiation source, and front-surface optical transfer mirrors. 

The 10-meter pathlength “White” absorption cell used gold-surface internal mirrors. The 

interior cell walls were made of polished stainless steel and minimize potential chemical 

interactions between the sample and the cell. Transducers and thermocouples (Type J) 

connected directly to the insulated sample cells provided the pressures and temperatures 

of the sample streams. During testing, the temperature was 121  ̊C at all times. This 

elevated temperature prevented gas condensation within the cell and minimized analyte 

adhesion to the cell walls and mirrors. The volume of the 10-meter absorption cell was 

approximately 2.0 L, so the sampling response times was approximately 60 seconds with 

a sample flow rate of 10 liters per minute. 

Gas Sampling and Spectral Collection:

For each test period, sample gas continuously passed through the sampling system at a 

sample flow rate of 10 liters per minute. Sample spectra were recorded (based on 56 coadded interferograms). At least one 128-scan background spectrum was recorded using 
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compressed continuous emission monitoring zero grade nitrogen every 4-6 hours. 

AutoQuant ProTM (Version 4.0.0.130) was used to collect and analyze all the infrared 

field data. The program allows the development and storage of analytical methods for 

analysis of spectral data (absorbance) files.

Quality Assurance:

Calibration Transfer Standards and Absorption Path Lengths 

Before sampling, a calibration transfer standard (CTS) gas was introduced to the FTIR 

system to determine the effective absorption pathlengths by comparing the field CTS 

spectra to a fundamental CTS spectrum recorded in a well-known, physically measured 

absorption path. A cylinder of ethylene in nitrogen (20.1 ppm) served as the CTS. All 

the pre- and post-test absorption pathlengths varied by less than 1.75 percent. The 

pathlength results are presented in Tables 5-2A and 5-2B. The overall average 

pathlength was 10.49 m. 

TABLE 5-2A 

EFFECTIVE PATHLENGTHS 

LEHIGH SOUTHWEST CEMENT COMPANY 

REDDING, CALIFORNIA 

Date Pathlength (m) Averages (m) 

3/16/2010 10:31 10.50 

3/16/2010 10:32 10.47 

3/16/2010 10:33 10.49 

3/16/2010 10:34 10.42 

3/16/2010 10:35 10.54 10.49 

3/16/2010 12:55 10.50 

3/16/2010 12:56 10.49 

3/16/2010 12:57 10.46 

3/16/2010 12:58 10.53 

3/16/2010 12:59 10.55 10.51 

3/16/2010 15:06 10.55 

3/16/2010 15:07 10.59 

3/16/2010 15:08 10.63 

3/16/2010 15:09 10.53 

3/16/2010 15:10 10.54 10.57 
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TABLE 5-2B 

EFFECTIVE PATHLENGTHS 

LEHIGH SOUTHWEST CEMENT COMPANY 

REDDING, CALIFORNIA 

Date Pathlength (m) Averages (m) 

3/16/2010 16:49 10.44 

3/16/2010 16:50 10.45 

3/16/2010 16:51 10.49 

3/16/2010 16:52 10.55 

3/16/2010 16:53 10.54 10.49 

3/17/2010 6:51 10.56 

3/17/2010 6:52 10.59 

3/17/2010 6:53 10.57 

3/17/2010 6:54 10.60 

3/17/2010 6:55 10.63 

3/17/2010 6:51 10.56 10.59 

3/17/2010 9:51 10.41 

3/17/2010 9:52 10.46 

3/17/2010 9:53 10.48 

3/17/2010 9:54 10.40 

3/17/2010 9:55 10.38 10.43 

 

3/17/2010 11:09 10.52 

3/17/2010 11:10 10.54 

3/17/2010 11:11 10.39 

3/17/2010 11:12 10.46 

3/17/2010 11:13 10.44 10.47 

3/17/2010 12:20 10.39 

3/17/2010 12:21 10.45 

3/17/2010 12:22 10.42 10.41 

3/17/2010 12:23 10.38 

3/17/2010 14:27 10.51 

3/17/2010 14:28 10.50 

3/17/2010 14:29 10.50 

3/17/2010 14:30 10.46 10.51 

3/17/2010 14:31 10.55 

 Overall Average 10.49 
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Reference Spectra 

The concentration of the analytes of the extracted samples where determined by 

comparing the samples’ absorbance spectra to a set of single-component reference 

spectra representing the analytes at similar, well-known concentrations. 

Leak Checks 

On-site test personnel performed leak checks. The leak check procedure was to 1) plug 

the probe tip, 2) evacuate the entire sampling system, including the FTIR absorption cell 

to a total (absolute) pressure of approximately 5 psi, 3) isolate the sampling system from 

the pump, and 4) observe the pressure in the sampling system over approximately one 

minute. In all cases, the pressure of the evacuated isolated sampling systems changed by 

less than 0.1 psi per minute. 

Data Storage 

A dedicated computer controlled the FTIR spectrometer; the hard drives of the computers 

served as the primary data storage media. During testing, on-site staff created and 

maintained backup and archive copies of the spectral data (interferograms, single beam 

spectra, and absorbance spectra) on CD-ROM discs and USB memory devices. 

Minimum Analytical Uncertainties (MAU) 

EPA Method 320 specifies a number of analytical uncertainty parameters that the analyst 

may calculate to characterize the FTIR system performance. Presented in Table 5-3 are 

the uncertainty results for hydrogen chloride. 

TABLE 5-3 

MINIMUM ANALYTICAL UNCERTAINTIES 

LEHIGH SOUTHWEST CEMENT COMPANY 

REDDING, CALIFORNIA 

Compound Hydrogen Chloride 

Reference Optical Density, ppm-m 423.3 

Upper Analytical Range Endpoint (FU, cm-1) 2950.31 

Lower Analytical Range Endpoint (FL, cm-1) 2645.76 

RMSD Noise Level (RMSSm, abs) 4.955 x 10-5

Noise Absorbance Area (abs, cm-1) 0.029 

Reference Absorbance Area (abs, cm-1) 5.191 

Sample Absorbance Pathlength (L, m) 10.49 

MAU (ppm) 0.227 
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Data Reviews 

The spectroscopic data and analytical results have been subject to several levels of 

review. First, the field instrument operators inspect the instruments’ outputs to ensure 

their appropriate performance during the sampling runs. Second, our laboratory manager 

examines the sample spectra and the quantitative analytical results, and also spot-checks 

the analysis results by hand; these examinations include visual comparisons of the sample 

and reference spectra. Examples of the reference and sample spectra are illustrated in 

Figure 5-1. 

2850 2800 2750 2700 2650 

Sample

HCl

H2O

Wavenumber (cm‐1) 

Figure 5-1. Selected Spectra. 

Red: Sample spectrum, Green: Hydrogen Chloride reference spectrum, 

Blue: Water reference spectrum 

Test Method Validation:

EPA Method 321, Measurement of Gaseous Hydrogen Chloride Emissions at Portland 

Cement Kilns by Fourier Transform Infrared (FTIR) Spectroscopy, U.S. Code of Federal 

Regulations (40 CFR 61, Appendix B) allows validation of FTIR-based measurements by 

a pair-wise comparison between the results of a single FTIR system. A single FTIR is 

used to measure “native” (or “un-spiked”) then spiked concentrations of the target 

analyte (hydrogen chloride) in two independent samples collected before and after each 

run. After establishing a steady-state, un-spiked concentration at each test location, the 
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2010 HCl Emissions Tests 

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sampling system is dynamically “spiked” with to provide a calculable change in the 

analyte concentrations. The results of the method validation are presented below. 

Spike gas was introduced into the sampling system by injecting gas from cylinder 

standard of 204.7 ppm hydrogen chloride and 10.2 ppm sulfur hexafluoride (tracer gas) 

before the heated filter. The spike gas flow rate was controlled using a NIST certified 0-

500 mL per minute mass flow controller so that the spike gas represented approximately 

10% of the total instrument sample flow rate. Using sulfur hexafluoride as a tracer gas, 

the dilution factors ranged from 0.085 ppm to 0.100 ppm. The differences between the 

spiked and native concentrations ranged from 15.54 to 19.00 ppmv HCl when the mill 

was in the on condition. So, the bias in the proposed method is more than B = -2.9 ppm. 

This yielded percent recoveries that were above 84%. Therefore, the test method is valid 

for hydrogen chloride since the percent recoveries were in the range of 70% ≤ %R ≤

130%. Results of the method validation are presented in Tables 5-4 and 5-5. No 

correction factors were applied to the method. 

The same dynamic spiking process was used to validate the method for hydrogen 

chloride using the same certified cylinder when the mill was in the off condition. The 

differences between the spiked and native concentrations ranged from 13.34 to 21.69 

ppmv HCl when the mill was in the off condition. So, the bias in the proposed method is 

more than B = -3.5 ppm. This yielded percent recoveries that were above 82%. 

Therefore, the test method is valid for hydrogen chloride since the percent recoveries 

were in the range of 70% ≤ %R ≤ 130%. Results of the method validation are presented 

in Tables 5-4 and 5-5. No correction factors were applied to the method. 
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2010 HCl Emissions Tests 

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TABLE 5-4 

TEST METHOD VALIDATION – HYDROGEN CHLORIDE 

LEHIGH SOUTHWEST CEMENT COMPANY 

REDDING, CALIFORNIA

Measured Analyte Concentrations 

 Concentrations (ppm) 

Sample Unspiked Spiked SF6 (spk) Difference 

Mill On 

Run #1 3.249 19.31 0.827 16.06 

 3.503 19.34 0.850 15.84 

 

Run #2 1.926 17.47 0.843 15.54 

 2.019 18.29 0.863 16.27 

 

Run #3 1.103 18.61 0.919 17.50 

 1.728 15.45 0.879 13.72 

 

Post-Run 3.596 19.92 0.984 16.33 

 3.251 22.25 1.002 19.00 

Mill Off 

Run #4 26.10 40.45 0.966 14.35 

 28.38 43.02 0.966 14.64 

 

Run #5 12.73 26.07 0.940 13.34 

 7.458 24.68 0.970 17.22 

 

Run #6 22.93 41.18 1.003 18.25 

 18.26 33.12 0.976 14.86 

 

Post-Run 14.21 32.22 0.983 18.01 

 14.90 36.59 0.998 21.69 

 where: 

Unspiked Measured concentration of the analyte in the native (unspiked) samples 

(ppm) 

Spiked Measured concentration of the analyte in the spiked samples (ppm) 

SF6 (spk) Measured concentration of the tracer gas in the spiked samples (ppm) 

TABLE 5-5 
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2010 HCl Emissions Tests 

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TEST METHOD VALIDATION – HYDROGEN CHLORIDE 

LEHIGH SOUTHWEST CEMENT COMPANY 

REDDING, CALIFORNIA 

Dilution Factor (DF), Expected Concentration (Ce), Bias (B), and Percent Recovery 

(%R)

 Su Sm DF Cs Ce B %R 

Mill On 

 Run #1 3.376 19.33 0.0846 204.7 20.41 -1.087 93.7% 

 Run #2 1.973 17.88 0.0861 204.7 19.42 -1.547 91.2% 

 Run #3 1.416 17.03 0.0907 204.7 19.86 -2.833 84.7% 

 Post-Run 3.424 21.08 0.1002 204.7 23.59 -2.510 87.8% 

 

Mill Off 

 Run #4 27.241 41.73 0.0975 204.7 44.54 -2.807 85.9% 

 Run #5 10.096 25.38 0.0964 204.7 28.85 -3.475 82.4% 

 Run #6 20.594 37.15 0.0999 204.7 38.98 -1.829 91.1% 

 Post-Run 14.556 34.40 0.1000 204.7 33.56 0.838 104% 

 

 where: 

Sm Observed mean concentration of the analyte spiked effluent samples (ppm) 

Su Native concentration of analytes in unspiked samples (ppm) 

DF Dilution factor where DF = SF6 (spk) / SF6 (dir) (ppm) 

SF6(dir) SF6 concentration measured directly 

Cs Cylinder concentration of the spike gas (ppm) 

Ce Expected Concentration of the spiked samples (ppm) where Ce = DF x Cs + Su

(1 – DF) 

B Bias at spike level (ppm) where B = Sm - Ce

%R Percent recovery where %R = 100 x [Sm-Su(1-DF)]/(DF x Cs) 

Reporting: The results are presented in units consistent with those requested in the EPA 

ICR letter dated February 3, 2010. 

5.2 ANCILLARY TESTS 

The testing program included measurements that provided data used in calculation of 

pollutant emission rates. These ancillary or supplementary tests are either included in the 

reference methods, or were run concurrently with the reference methods to provide the 

necessary data. 
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5.2.1 Gaseous Emissions

Method: EPA 3A, Amended June 13, 1990 

Deviations: None 

Concentrations of O2 and CO2 were quantified by means of a dry extractive continuous 

emission monitoring (CEM) system maintained in a mobile laboratory. The results were 

used for molecular weight and dilution calculations. 

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 CEM system is 

comprised of six basic subsystems: 

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 

includes software for controlling the collection of calibration and emission monitoring 
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2010 HCl Emissions Tests 

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

results were provided on site. 

5.2.2 Volumetric Flow Rates and Moisture Content

Methods: EPA 1 (Amended March 28, 1986) 

 EPA 2, 4 (Adopted June 29, 1983) 

Deviations: None 

Volumetric flow rates were measured according to EPA Methods 1 and 2. Moisture 

content was measured according to EPA Method 4. The concentrations of diluent gases 

(O2 and CO2) were measured using EPA Method 3A during each test run. Emission rates 

were calculated in units of lb/hr or other mass flow units from the measured 

concentrations and volumetric flow rates. 
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2010 HCl Emissions Tests 

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SECTION 6.0 

QUALITY ASSURANCE AND REPORTING

6.1 SAMPLING AND ANALYTICAL QA/QC 

Avogadro has instituted a rigorous QA/QC program for all of its air pollution testing. 

The program ensures that the emission data reported are accurate and the procedures 

included in the cited reference methods were followed for all steps of preparation, 

sampling, calibration, and analysis. Avogadro was responsible for preparation, 

calibration and cleaning of the sampling apparatus and conducted the sampling, recovery, 

storage and shipping. 

6.2 QUALITY CONTROL REQUIREMENTS 

Our Quality Assurance Program Summary, located in Appendix B, provides our 

equipment maintenance and calibration schedule, quality control acceptance limits, and 

any corrective action that may be needed. For additional quality control, Avogadro 

followed the procedures outlined below: 

 Preliminary stack flow and temperature measurements were taken to assure 

correct isokinetic sampling. 

 All field equipment was visually inspected prior to testing and included pretest calibration checks. 

 Glassware was visually inspected prior to testing. 

6.3 DATA REDUCTION PROCEDURES 

The raw data collected during the sampling and analysis procedures were used to 

calculate the results of the testing program. The analysis and reduction of the data to the 

final results followed these steps where appropriate to the test method: 

1. Check field-sampling data for accuracy and calculate appropriate data 

averages (e.g., temperatures, pressures, volumes, etc.). 

2. Double-check calculation of the data averages. 

3. Review in-house and contract laboratory reports and ensure that 

appropriate and/or required QA/QC steps were followed. 

4. Input field and laboratory data to established, verified computer 

spreadsheets for calculation of volumetric flow rates, mass emission rates 
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2010 HCl Emissions Tests 

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or other appropriate results. 

5. To verify results, perform example calculations by hand on a single test 

run for each emission result reported. 

6. Compile summary tables of results and review all inputs. 

The report includes copies of spreadsheet printouts (data input and results output) and 

example calculation checks. The field data sheets with average data calculations are also 

included. Standard conditions used for data reduction were 29.92 inches of mercury and 

70 oF. 
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2010 HCl Emissions Tests 

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SECTION 7.0 

DISCUSSION OF RESULTS

The results of the air source emission tests are presented in Tables 7-1 and 7-2. The 

supporting data is contained in the appendices and includes the information listed below: 

1. Appendix A presents generic descriptions of the standard test methods. 

2. Appendix B contains quality assurance information, our California ARB 

certification, and calibration data. 

3. Appendix C contains supporting data including a sketch of the sampling 

location, the plant process data, and Avogadro CEMS data. 

4. Appendix D includes the field data sheets for all the sampling activities. 

5. Appendix E presents the equations used for the general calculations, 

printouts of the emission calculation spreadsheets and the hand written 

example calculations. 
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2010 HCl Emissions Tests 

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TABLE 7-1 

SUMMARY OF RESULTS 

HCl EMISSION TESTS 

LEHIGH SOUTHWEST CEMENT COMPANY 

TESTS CONDUCTED WITH THE ROLLER MILL ON 

Test No.: 1-HCl-On 2-HCl-On 3-HCl-On Average 

Date: 3/16/10 3/16/10 3/16/10 -- 

Time: 0925-1025 1150-1250 1401-1501 --

Stack Gas 

O2, % volume dry 11.07 10.72 11.60 11.13 

CO2, % volume dry 16.62 17.18 15.92 16.57 

Moisture cont., % vol. 13.5 15.3 15.5 14.8 

Stack gas temp., °F 228.4 227.9 218.0 224.8 

Stack flow rate, dscfm 133,557 135,639 133,951 134,382 

Process Data 

Kiln feed rate, ton/hr 151.55 149.19 141.62 147.45 

HCl 

ppmvd 2.98 1.67 1.60 2.08 

ppmvd @ 7% O2 4.21 2.29 2.39 2.96 

lb/hr 2.25 1.29 1.21 1.58 
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2010 HCl Emissions Tests 

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TABLE 7-2 

RESULT SUMMARY 

HCl EMISSION TESTS 

LEHIGH SOUTHWEST CEMENT COMPANY 

TESTS CONDUCTED WITH THE ROLLER MILL OFF 

Test No.: 1-HCl-Off 2-HCl-Off 3-HCl-Off Average 

Date: 3/17/10 3/17/10 3/17/10 -- 

Time: 0843-0943 1116-1216 1322-1422 -- 

Stack Gas 

O2, % volume dry 9.236 8.914 8.966 9.039 

CO2, % volume dry 19.74 20.16 20.29 20.06 

Moisture cont., % vol. 14.8 14.5 15.5 14.9 

Stack gas temp., °F 280.0 281.7 284.3 282.0 

Stack flow rate, dscfm 115,358 111,530 108,519 111,803 

Process Data 

Kiln feed rate, ton/hr 145.45 147.48 144.19 145.71 

HCl 

ppmvd 35.29 16.98 15.91 22.73 

ppmvd @ 7% O2 42.05 19.69 18.53 26.76 

lb/hr 23.03 10.72 9.77 14.50