### ATTACHMENT F

SOUTH COAST AIR QUALIT Y MANAGEMENT DISTRICT

Final Staff Report

Proposed Amended Rule 1112.1 – Emissions of Particulate Matter and Carbon Monoxide from Cement Kilns

December 2009

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

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

Author: Robert R. Pease, P.E. Program Supervisor Henry Pourzand Air Quality Specialist

Reviewed by: Barbara Baird District Counsel John Olvera Principal Deputy District Counsel

Contributors Tom Chico Program SupervisorSOUTH COAST AIR QUALIT Y MANAGEMENT DISTRICT

GOVERNING BOARD

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

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

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

MARION ASHLEY Supervisor, 5 th District Riverside County Representative

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

BILL CAMPBELL Supervisor, Third District Orange County Representative

JANE W. CARNEY Senate Rules Committee Appointee

JOSIE GONZALEZ Supervisor, Fifth District San Bernardino County Representative

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

JOSEPH K. LYOU, PH.D. Governor’s Appointee

JAN PERRY Councilmember, 9 th District Cities Representative, Los Angeles County, Western Region

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

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

EXECUTIVE OFFICER: BARRY R. WALLERSTEIN, D.Env.TABLE OF CONTENTS

EXECUTIVE SUMMARY .......................................................................................................... 1

BACKGROUND ..................................................................................................................... ...... 1

P URPOSE

............................................................................................................................... ..........................1

P ORTLAND C EMENT M ANUFACTURING ..........................................................................................................6

C ARBON M ONOXIDE F ORMATION IN C EMENT K ILNS .....................................................................................6

R ELATIONSHIP B ETWEEN NO X AND CO ........................................................................................................7

CO EMISSIONS DATA AND ANALYSIS ................................................................................ 8

S PECIFIC F ACTORS

............................................................................................................................... ..........8

K ILN D ATA AND A NALYSIS .............................................................................................................................9

A MBIENT A IR Q UALITY AND D ISPERSION M ODELING ..................................................................................11

PROPOSED AMENDMENT..................................................................................................... 13

CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA)........................................... 14

SOCIO-ECONOMIC ISSUES................................................................................................... 14

LEGISLATIVE AUTHORITY ................................................................................................. 14

DRAFT FINDINGS ................................................................................................................. ... 15

AQMP AND LEGAL MANDATES...................................................................................... 16 15

COMMENTS AND RESPONSE TO COMMENTS............................................................... 16Final Staff Report Proposed Amended Rule 1112.1

1 

### EXECUTIVE SUMMARY Currently, California Portland Cement Company (CPCC), is the only company in the SCAQMD that manufactures Gray Portland Cement (cement ). The company is located in Colton, in San Bernardino County. Cement is used primarily as a construction material in the industrial sector due to the strength and durability of the product. It is currently being manufactured in two kiln s at Colton, Kiln #1 and Kiln #2. The production process results in a variety of k iln emissions including CO and NOx. CPCC uses an emissions control strategy for mitig ating NOx which involve s injection of used tires directly into th e kiln. Tires introduc ed into the kiln redu ce the kiln oxygen concentration and hence the fo rmation of NOx while still main taining the required kiln combustion dynamics for cement production. While the process modifications at CPCC have had a beneficial impact in reducing NOx emissions, there are occasional spikes in the concentration of CO emissi ons, exceeding the Rule 407 CO emissions limit of 2,000 ppm averaged over 15 consecutiv e minutes. The air basin does not meet the air quality standards for either ozone or particulate matter. However, the air basin has recently been redesignated as attainment for the federal ambient CO standard by U.S. EPA. There have been no violations of the CO sta ndard in the AQMD since 2002. The area of CO non-attainment was a sma ll upwind portion of south Los Angeles County, far from the f acility in San Bernardino County, which occasionally exceeded the CO standard. Also, CO co ncentrations are localized ne ar the source of emissions and do not have regional impa cts as do some other air cont aminants, such as ozone. Conversely, the area surrounding CPCC is in non-attainment for both ozone and PM10. Since NOx is a precursor of both PM-10 a nd ozone, the reduction of NOx emissions remains the priority. The proposed rule amendment seeks to acknowledge the air quality benefit provided by CPCC in reducing NOx emissions by establishing an alternative emission limit fo r cement kilns while still main taining compliance with the ambient CO air quality standard. Based on da ta from CO certified continuous emissions monitors and subsequent analysis provided by CPCC and its contractor Mangan, Inc., the appropriate revised CO emissions thre shold would be 1,900 ppm averaged over eight hours. Air quality modeling at CPCC indi cates that ambient CO levels will not be affected by this revised CO emissions standard.


### BACKGROUND
Purpose CPCC is currently the only facility manuf acturing cement in the SCAQMD. The facility is a RECLAIM source and has unde rtaken a program to reduce NOx from two on-site kilns. The process in volves injection of used tires into the cement kiln. A consequence of this strategy is an increas e in CO emissions over very brief periods, exceeding the current Ru le 407(a)(1) CO threshold which reads:Final Staff Report Proposed Amended Rule 1112.1

2 “(a) A person shall not discharge into the atmosphere from any equipment : (1) Carbon monoxide (CO) exceedin g 2,000 ppm by volu me measured on a dry basis, averaged ove r 15 consecutive minutes.”

CPCC is currently operating under an Order for Abatement because of the occasional violation of Rule 407(a)(1). In su pport of the NOx reduction strategy

, CPCC has asked the District for assistance in structuring a compliance strate gy for CO specific to cement kiln operations. Staff has examined an a rray of options includ ing a combination of lowering the emissions threshold in conjunc tion with an increased averaging period. Staff is recommending amendments that w ill not have a measurable impact on local ambient air quality nor contribut e to exceedences of either the one or eight hour state standards for CO based on air quality mo deling conducted by SC AQMD staff. In addition

, the standard, compliance procedures, a nd test methods for CO will be more precisely defined. The reduction of NOx is emphasized over CO as NOx is a precursor to both ozone and PM10. Fi gures 1 through 4 show hist orical ambient air quality within the SCAQMD for ozon e, PM10 and PM2.5, respec tively, and highlight NOx reduction as the priority.

Figure 1. Number of days the 1-hour fe deral OZONE standard (> 0.12 ppm) was exceeded in 2005

XFinal Staff Report Proposed Amended Rule 1112.1

3 Figure 2. Number of days the 8-hour fe deral OZONE standard (> 0.08 ppm) was exceeded in 2005

Figure 3. 2005 PM10 A nnual Arithmetic Mean ( μ g/m3) compared to 50 μg/m3 federal standard X

X

XFinal Staff Report Proposed Amended Rule 1112.1

4 Figure 4. 2005 PM2.5 A nnual Arithmetic Mean ( μ g/m3) compared to 15 μg/m3 federal standard

Exceedences for ozone, PM10 and PM2.5 were recorded throughout the basin with the highest concentrations occurring in the general area where the CPCC facility is located (as indicated by the symbol X). Figure 5 illustrates that in contrast, the localized exceedance of CO has historica lly been confined to a limite d area in south Los Angeles County. In 2008, for the fift h consecutive year since 2 003, no areas in the Basin exceeded the CO air quality sta ndards. The Basin has been officially designated as being in attainment with federal CO standards by U.S. EPA. The highest concentrations of CO continue to be recorded in the area s of Los Angeles County where vehicular traffic is most de nse with the highest concentr ation continuing to be south central Los Angeles County, far upwind of CPCC. The highes t 8-hour average CO concentration recorded for 20 05 was 5.9 ppm, in the South Central Los Angeles County area, and was 62% of the federal CO standard. XFinal Staff Report Proposed Amended Rule 1112.1

5 Figure 5. Ambient Carbon Monoxide (CO) concentration in the SCAQMD

In contrast, for 2005 the Ba sin exceeded federal and state standards for ozone, PM10 and PM2.5. For ozone, the maximum 1-ho ur average (0.182 ppm) and maximum 8- hour average (0.145 ppm) concentrations were both recorded in the central San Bernardino Mountains area to the north-east of CPCC and were 146% and 171% of the federal standard, respectively. The Centra l San Bernardino Mountains area recorded the greatest number of excede nces (80 days) of both the st ate and federal 1-hour (18 days) and 8-hour (69 days) standards in additi on to 7 days for the he alth advisory level (Figures 1 and 2).

For PM10, the maximum annual average concentration (52 μ g/m3) occurred in the Metropolitan Riverside County area, in the general vicinity of CPCC (Figure 3). For PM2.5 the maximum 24-hour average (132.7 μ g/m3) and annual average (21.0 μ g/m3) concentrations were recorded in the East San Gabriel Valley area and the Metropolitan Riverside County area, both in the general vicinity of CPCC, and were 203% and 139% of the federal standard, respectively. Figure 4 shows the 2005 PM2.5 Annual Arithmetic Mean concentration as comp ared to 15 μg/m3 federal standard. XFinal Staff Report Proposed Amended Rule 1112.1

6 Furthermore, about 13% (154 tons/day) of the total annual total NOx inventory in the Basin is from stationary sources in contrast to only 1.4% (99 to ns/day) from CO. The data indicates that efforts to mitigate oz one, PM10 and PM2.5, by controlling NOx and particulate emissions, remain th e highest priority at CPCC. 

### Portland Cement Manufacturing The name Portland Cement (cement) refers to a process that was patented in 1824 and is not associated with any particular locatio n or person. The process of manufacturing cement begins with the quarrying of “Raw Mix” which is pre dominantly limestone rock. Raw Mix is then refined through a series of mechanical grinding and crushing operations which not only segregate but si gnificantly reduce the diameter of the component quarried materials. The segregated mate rials as well as other materials brought to the facility and used in the manufa cturing process are stored in silo bins. From here, limestone, shale, iron ore and silic a in proprietary proportions, or kiln mix, are pneumatically fed into the feed end of ea ch kiln. It takes approximately 1.56 parts of this kiln feed to manufacture 1 part of Po rtland cement. Each kiln is basically a huge rotating cylinder lined with refractory fire br ick that is several hundred feet long. A slight incline from the horizontal causes the spinning material in the kiln to travel down the length of the kiln from the feed end to the discharge end. A large burner located at the discharge end of the kiln fires the transitory kiln feed. Reaction zones are established towards the center and in towards th e horizontal axis of the kiln as the feed mix is oxidized and the resulting reactions produce an intermediate product called clinker that is collected at the discharge end. Clinker is a harder material than any of the quarried rock that comprises the feed mix. In the final phase, the clinker is milled and packaged with gyp sum to produce cement. Cement when mixed in the correct proportion with water sets to form concrete.


### Carbon Monoxide Formation in Cement Kilns Quarried limestone is not a homogenous materi al but is composed mostly of limestone which is also the principl e ingredient for manufacturing cement. Limestone is predominantly Calcium Carbonate (CaCO3 ). The production of cement involves chemical reactions in which the feed mix in the kiln is heated to high temperatures and oxidation of the feed mix occurs. The oxida tion of carbon compo unds results in the formation of carbon monoxide (CO) and carbon dioxide (CO2 ). Both are present to an extent in the kiln during c linker production. In the k iln, two factors influence the proportions of CO to CO2. First, the amount of oxygen pres ent and second, the temperature in the reaction zone of the kiln. In general, the more oxygen available the more carbon monoxide is reduced to carbon di oxide. Figure 5 shows that higher kiln temperatures tend to increase the oxidation of CO to CO2.Final Staff Report Proposed Amended Rule 1112.1

7 Figure 5. Cement Kiln CO2 Formation With Temperature Increase



### Relationship Between NOx and CO The production of cement also results in oxides of nitrogen (NOx) emissions. NOx emissions from kiln reactions are a byproduct of using air (which is comprised mostly of nitrogen) to feed the kiln , the fuel used, and the nature of the combustion process. Conditions that favor the mitig ation of NOx, namely limiti ng the presence of air and reducing peak combustion temperatures lead to increased CO emissions while the presence of excess air (containing oxygen) a nd higher kiln temperatures increase the proportion of kiln NOx emissions, while reduc ing CO by increasing oxidation of CO to CO2. The tire injection NOx control st rategy developed specifically for CPCC minimizes the presence of air while mainta ining kiln temperatures by providing a packet of energy when the tire is burned in the kiln in an exothermic reaction, however the absence of “excess air” causes occasiona l CO spikes. There are also practical limitations on the amount of excess air that could be intr oduced into the kiln process to address CO emissions. Too much air would be inefficient both in terms of the extra energy needed to driv e the increased volume flow throu gh the kiln and also because of the increased fuel need ed to maintain optimal kiln temperatures. 0 500 1,000 1,500 2,000 2,500 1 x 10 3

1 x 10 -3

1 x 10 -6 1 x 10 0 1 x 10 6

1 x 10 -12 1 x 10 -9

Temperature (Degrees Kelvin) Rate Constant (c.c. per mol)Final Staff Report Proposed Amended Rule 1112.1

8 

### CO EMISSIONS DATA and ANALYSIS
Specific Factors
Both Kiln #1 and Kiln #2 are analogous to extremely immense crucibles where a myriad of chemical reactions are continuously taking place. In addition, because of the design and enormous di mensions of each kiln, different reactions are taking place at the same time in different areas or zones of the kiln. Kiln feed composition and temperature can vary unpredictably within the kilns. Temperature while tending to increase towards the core of the kiln does so in a non- uniform manner. The variability in kiln feed mix composition and temperat ures necessitate continuous oversight. Because of the sheer size of each kiln much can happen , due to the chemistry and temperature environment, in the formation process of Clinker from the time feed mix enters the kiln at the feed end until it exits the kiln at th e discharge end as Clinker.

A kiln operator monitors th e kiln processes in real ti me from a remote location and makes adjustments to burner flame temperat ure and the other reaction variables as necessary. Even though the process is monitored in real time, the effect of any operator action can take several minutes to produce re sults inside the kiln. Variations in temperature and kiln feed mix composition so metimes lead to the formation of both “dams” and “fronts”. A dam is formed when molten feed mix cools enough to solidify, creating a dam like barrier behind which molten feed mix accumulates. In order to reestablish the flow of kiln feed material towards the discharge end of the kiln the operator must generally increase temperatures in the kiln. Even measured corrections deviate from anticipated outcomes because of the size, complexity and uncertainty of kiln operations. Eliminati ng a dam by increasing kiln te mperatures may release an accumulation of liquefied feed mix from behi nd the dam. This can rush towards the discharge end creating a front or wave. A front results in the reacting kiln mixture moving faster than the desired residency time for an optimal reaction. Waves and fronts are a major concern in stabilizing kiln reactions. The experi enced operator’s job is more anticipating how the kiln will be reac ting some time in the fu ture, in real time, and working to maintain optimal kiln co nditions. In empirical observations made during site visits to CPCC and in discussions with operati onal and management staff the following factors were found to a ffect CO emissions from kilns:
1. The non-homogenous chemical composition of raw mix and hence the feed mix,
2. The varying temperatures in various reaction zones within the kilns,
3. The heterogeneous chemical composition of tires used in the injection system, and
4. The uncertain distribution of reaction zo nes within the kiln s leading to the formation of “dams” and “fronts”. While each kiln normally operates within a known range of settings, uncertainty about the above factors results in uncertainty about CO emissi ons, with resulting occasional spikes of the kiln CO emissions concen tration above the current limit (2,000 ppm averaged over 15 minutes).Final Staff Report Proposed Amended Rule 1112.1

9 

### Kiln Data and Analysis In calendar year 2008, CPCC began opera tion of CO certified Continuous Emissions Monitoring Systems (CEMS) installed on its tw o kilns. In August 2009, data captured by the CEMS was provided by CPCC to it s contractor, Mangan, Inc. (Mangan), for further analysis to determin e kiln CO emissions concen trations under various time period averaging scenarios. The raw data set provided to Mangan was comprised of captured one minute CEMS CO concentration observations fo r each of the two kilns at CPCC. The CEMS certified em issions data provided by CP CC spanned the months of July 2008 thr ough July 2009 for Kiln #1 and Augu st 2008 through Ma rch 2009 for Kiln #2, there were however, periods for which no emissions value was reported. Typically, missing values were due to either a later operational start of the certified CEMS on the particular kiln, equipment being taken offl ine for maintenance and other issues, or invalid data.

Maximum CEMS CO concentrations furn ished to AQMD for different averaging periods are summarized in Tables 1 and 2 for Kilns 1 and 2, respecti vely. Based on the analysis of over 840,0 00 CO concentration data values, the results suggest that neither of the two kilns at CPCC would have exc eeded a CO threshold limit of 1,900 ppm averaged over eight (8) hours.Final Staff ReportProposed Amended Rule 1112.110Table 1. CPCC Kiln #1 Maximum Reported CO Emissions (ppm) Values (provided by Mangan, Inc., August 26, 2009)Month1-Minute1Hr Average2Hr Average3Hr Average4Hr Average8Hr AverageJuly 2008 4,667 1,894 1,777 1,6651,597 964August 4,982 2,823 1,654 1,3371,313 1,050September 4,990 2,226 1,949 1,9571,895 1,591October 5,026 2,939 2,229 1,9481,760 1,322November 5,068 4,2983,377 2,9132,708 1,836December 4,933 784 532 459418 368January 2009 4,552 1,780 1,748 1,7211,697 1,115February 4,990 1,616 1,109 902800 597March 4,997 3,0841,637 1,159921 564April 4,988 1,992 1,220 921774 567May 4,984 1,015 761 584533 484June 3,106 1,037 1,030 1,0231,023 1,014July 4,600 860 713 678679 624Range Maximum5,0684,2983,3772,9132,7081,836Table 2. CPCC Kiln #2 Maximum Reported CO Emissions (ppm) Values (provided by Mangan, Inc., August 26, 2009)Month1-Minute1Hr Average2Hr Average3Hr Average4Hr Average8Hr AverageJuly 2008 0 0 0 0 0 0August 5,023 2,410 2,314 2,2342,199 1,606September 4,996 1,816 1,173 955840 687October 5,030 4,012 2,735 2,1661,847 1,416November 4,824 2,6371,574 1,133907 579December 4,967 1,721 1,116 866823 674January 2009 4,957 971 721 565571 490February 5,010 3,051 2,444 2,2512,146 1,373March 4,986 4,1413,352 2,3762,320 1,494April 0 0 0 0 0 0May 0 0 0 0 0 0June 0 0 0 0 0 0July 0 0 0 0 0 0Range Maximum5,0304,1413,3522,3762,3201,606* Current Rule 407 threshold CO limit is 2,000ppm per 15 minute periodFinal Staff Report Proposed Amended Rule 1112.1

11 

### Ambient Air Quality and Dispersion Modeling Currently, the existing rule specifies a 2,000ppm limit over a 15-minute averaging time. The proposed amendment will allow a limit of 1,900ppm over an 8-hour averaging time. Three emission scenarios were mode led – 2000ppm (existing rule limits, which represents the baseline conditions for bot h 1-hour and 8-hour averaging times), 1,900ppm (PAR1112.1 for the 1-hour and 8-hour av eraging times) and 6000ppm (facility’s maximum 1-hou r emissions, used to ensure a worse-case analysis for the 1- hour averaging time under PAR1112.1).

Dispersion modeling was performed to assess th e impacts of the proposed change to the 1-hour and 8-hour CO concentrations. Th e U.S. EPA model, called AERMOD, was used with regulatory default options, URBA N option using the San Bernardino County population of 2,015,355, and fenceline receptors and a Cart esian receptor grid, based on the modeling performed for the submitted health risk assessme nt. Meteorological data at the AQMD’s San Bernardino meteorological site was used as in put to the dispersion model. The worst-case CO air quality ov er the period 2005 to 2007 at the San Bernardino monitoring site (Station No. 52 03) was assumed to represent background CO air quality. The assumed stack paramete rs for the modeling are summarized in Table 1 and were obtained from the HRA, except for the stack temperatures and actual flow rates which were provided by Gary Thornberry (Environmental/Plant Services Manager, CPCC) in an email dated 9/24/09. Th e emission rates were provided by Gary Thornberry in an email dated 9/16/09. Plea se note that for each scenario, both kilns were assumed to be operating at the ma ximum emissions, i.e., for the 6,000ppm scenario, both k ilns were assumed to be emitting 6, 000ppm of CO simultaneously.

Table 1. Emissions and Stack Data Used in the Dispersion Modeling.

Stack Parameters Kiln Stack #1 Kiln Stack #2
Stack height (ft) 97 97

Stack diameter (ft) 10 10

Stack temperature (degrees F) 281 263

Stack gas exit flow rate (actual cubi c feet per second) 2,599.27 2,084.79

CO emission rate (lb/hr) – 1900ppm scenario 881.4 731.3

CO emission rate (lb/hr) – 2000ppm scenario 927.8 769.8

CO emission rate (lb/hr) – 6 000ppm scenario 2,783.3 2,309.5Final Staff Report Proposed Amended Rule 1112.1

12 The modeling results are shown in Table 2. Since the project im pact area is in attainment of all state and federal CO am bient air quality standards, the project increment is added to the worst-case backgr ound concentrations and the sum compared to relevant CO standards. As shown in Tabl e 2, the total impacts from all scenarios are below all state and federal ambient air quality standards.

Table 2. Dispersion Modeling Results.

Averaging T

ime Project Increment

(μg/m3) Background Air Quality

(μg/m3) Total Concentration (μg/m3) NAAQS (μg/m3) CAAQS (μg/m3)
2000ppm scenario (Existing conditions)

1

- hour 4,045 4,600 8,645 40,000 23,000

8

- hour 1,434 2,760 4,194 10,000 10,000

1900ppm scenario (Proposed Rule)

1

- hour 3,843 4,600 8,443 40,000 23,000

8

- hour 1,362 2,760 4,122 10,000 10,000

6000ppm scenario (Pro posed Rule, maximum 1

- hour emissions)

1

- hour 12,134 4,600 16,734 40,000 23,000

NAAQS = national ambient air quality standards CAAQS = California ambien t air quality standardsFinal Staff Report Proposed Amended Rule 1112.1

13 Table 2. Dispersion Modeling Results.

Averaging time Project Increment

(μg/m 3 ) Background Air Quality (μg/m 3 ) Total Concentration (μg/m 3 ) NAAQS (μg/m 3 ) CAAQS (μg/m 3 )

2000ppm scenario (Existing Rule)

1-hour 1,260 4,600 5,860 40,000 23,000

8-hour 358 2,760 3,118 10,000 10,000

1900ppm scenario (Proposed Rule, maximum 8-hour emissions)

1-hour 1,197 4,600 5,797 40,000 23,000

8-hour 340 2,760 3,100 10,000 10,000

6000ppm scenario (Proposed Rule, maximum 1-hour emissions)

1-hour 3,779 4,600 8,379 40,000 23,000

NAAQS = national ambient air quality standards CAAQS = California ambient air quality standards



### PROPOSED AMENDMENT Staff is recommending that Rule 1112.1 be amended to incl ude CO limits in addition to the current particulate limits. For CO two alternatives are offered: comp ly with the current limit of Rule 407(a)(1); or as an alternative, comply with a new proposed standard of 1,900 ppm concen tration limit averaged over eight hours and a prohibition against exceeding a 6,000 ppm threshold du ring any consecutive 15 minute averaging period. Modeling shows no significant im pact on ambient CO concentrations even when the kilns operated at a 6,000ppm sustained emissions profile for a whole hour. The 6,000 ppm threshold aver aged over 15 minutes ther efore provides a more conservative standard and will ensure no si gnificant ambient air quality impacts from this compliance alternative. In addition, proposed amendments also incl ude text on updating co mpliance procedures requiring the source to comp ly with updated and more rigorous requirements as follows:

1. Measurement, monitoring and recordke eping of carbon monoxide (CO) emissions from the cement kiln shall be c onducted according to the provisions of District Rule 218 – Contin uous Emission Monitoring.
2. A District approved Continuous Emissi ons Monitoring System (CEMS) for carbon monoxide (CO) a nd oxygen (O2) must be installed no later than December 31, 2009, or prior to comme ncement of operation for sources beginning operation after December 4, 20 09, and operated according to theFinal Staff Report Proposed Amended Rule 1112.1

14 provisions of District Rule 218 – Continuous Emission Monitoring.
3. The CEMS certification tests and other samp ling, analysis, and reporting shall be conducted by a laboratory that has been approved unde r the District Laboratory Approval Program (LAP) for the cited Di strict reference test methods, where LAP approval is available. For Distri ct reference test methods for which no LAP program is available, the LAP appr oval requirement shall become effective one year after the date that th e LAP program becomes available.

Furthermore, proposed amendments also include text on updating test methods requiring the source to comp ly with updated and more rigorous requirements as follows:

1. Carbon Monoxide emission concentration sh all be determined according to the procedures in District Source Test Method 100.1 – Instru mental Analyzer Procedures for Continuous Gaseous Emission Sampling.
2. Particulate matter emissions shall be dete rmined according to the procedures in District Source Test Method 5.3 – De termination of Particulate Matter from Stationary Sources Using an In-Stack Filter.
3. Other test methods may be used as dete rmined to be equivalent and approved before the test in writing by the Executive Officer, th e California Air Resources Board, and the United States E nvironmental Protection Agency.



### CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA)
Pursuant to California Envi ronmental Quality Act (CEQA) Guidelines §15252 and SCAQMD Rule 110, the SCAQMD has prepared an Environmental Assessment (EA) for the adoption of proposed amended Rule 1112.1. The Draft EA concluded that implementation of the proposed project wo uld not result in significant adverse environmental impacts. The Draft EA was released for a 30-day public review and comment period from July 17, 2007 to Augus t 15, 2007. No comments were received relative to the Draft EA. The draft EA has be en revised such that it is now a Final EA which is included as an attachment to this Governing Board package. The AQMD will prepare appr opriate California Environm ental Quality Act (CEQA) documentation for the proposed am endments to Rule 1112.1. Upon comp letion, the CEQA document will be rel eased for public review a nd comment, and will be available at AQMD Headquarters, by calling the AQMD P ublic Information Center at (909) 396

- 3600, or by accessing AQMD’s CEQA website at: www.aqmd.gov/ceqa/aqmd.html

.



### SOCIO-ECONOMIC ISSUES The proposed amendments to Rule 1112.1 will not require CPCC to implement any operational changes at its Colton facility. As such, the proposed amendments will have no significant adverse socioeconomic impacts.



### LEGISLATIVE AUTHORITYFinal Staff Report Proposed Amended Rule 1112.1

15 The California Legislature created the AQMD in 1977 (The Lewis-Presley Air Quality Management Act, Health and Safety Code Section 40400 et seq.) as the agency responsible for developing and enforcing ai r pollution control rules and regulations in the Basin. By statute, the AQMD is requir ed to adopt an Air Quality Management Plan (AQMP) demonstrating compliance with a ll state and federal ambient air quality standards for the Basin [California Health and Safety Code Se ction 40460(a)]. Furthermore, the AQMD must adopt rules and regulations that carry out the AQMP [California Health and Safety Code Sec tion 40440(a)]. While PAR 1112.1 does not implement an AQMP control measur e, it helps meet AQMP objectives.



### DRAFT FINDINGS Before adopting, amending, or repealing a ru le, the California Health and Safety Code Section 40727 requires the AQMD to adop t written findings of necessity, authority, clarity, consistency, non-duplication, and reference based on relevant information presented at the public hearing and in the staff report.

Necessity - The AQMD Governing Board has determ ined that a need exists to amend Rule 1112.1 – Emissions of Particulate Matter and Carb on Monoxide form Cement Kilns, to allow an alterna tive CO concentration standard for grey cement kilns, recognizing the concurrent environmental bene fit of reducing NOx, a precursor to nonattainment pollutants of ozone and particulat es, while ensuring the CO emissions do not significantly impact air quality.

Authority - The AQMD Governing Board obtains its authority to adopt, amend, or repeal rules and regulations from the Califo rnia Health and Safe ty Code Sections 39002, 39650, 40000, 40001, 40440, 40702, 41508, and 41700, et seq.

Clarity - The AQMD Governing Board has dete rmined that the proposed amendment to Rule 1112.1 is written or displayed so th at its meaning can be easily understood by the persons directly affected by it.

Consistency - The AQMD Governing Board has determined that Proposed Amended Rule 1112.1 is in harmony wi th, and not in conflict with or contradictory to, existing statutes, court decisions, federal or state regulations.

Non-Duplication Rule 1112.1 does not impose the same requirements as any existing state or federal regulations, and the proposed amended rule is nece ssary and proper to execute the powers and duties grante d to, and imposed upon, the AQMD.

Reference - In adopting this regu lation, the AQMD Governing Board references the following statutes which the AQMD hereby im plements, interprets or makes specific: California Health and Safety Co de Sections 40440(a) (rules to carry out the Air Quality Management Plan), and 40440( c) (cost-effectiveness), 41508, 41700 (nuisance), and Federal Clean Air Act S ection 172(c)(1) (RACT).Final Staff Report Proposed Amended Rule 1112.1

16 

### AQMP AND LEGAL MANDATES The California Health and Safety Code requ ires the AQMD to adopt an Air Quality Management Plan (AQMP) to meet state a nd federal ambient air quality standards with the South Coast Air Basin. In addition, Californi a Health and Safety Code requires the AQMD to adopt rules and regulations that carry out the objectives of the AQMP. Although Rule 1112.1 does not implement control meas ures in the AQMP, the proposed amendments do not result in ad ditional emission reductions; however the amendments are consistent with AQMP objectives. California Health and Safety Code Section 40727.2, requires a comparative analysis with other federal and District rules. Th e NSPS for Portland cement plants (40CFR60 Subpart F) applies only to particulate matt er and not CO. Rule 407 is one of the compliance options for PAR 1112.1. The ot her option is a 1,90 0ppm concentration limit averaged over eight hours instead of fifteen minutes, verified by continuous emissions monitoring and updated measuremen t, monitoring, recordkeeping and test method procedures.



### COMMENTS and RESPONSE TO COMMENTS
Comment: Can staff provide confirmation of the latest version of the proposed required source test methods? Response: The text of the latest source te st methods being proposed as part of the amendments to the rule are availa ble at on the SCAQMD website at: http://www.aqmd.gov/tao/methods/stm.html . Staff will also be happy to provide any additional assistan ce regarding this issue.

Comment: Rule 218(f) requires that a su mmary of CEMS concentration and/or emission rate data, as well as any additional information required to evaluate the accuracy and precision of the measurements be furnished once every six months. What is th e procedure for submitting this data? Response: The source should consult with the SCAQMD Compliance division, through their assigned engineer/insp ector to determine the specific procedures for complying with this reporting requirement.