ATTACHMENT F 

SOUTH COAST AIR QUALITY 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 Supervisor 
SOUTH COAST AIR QUALITY 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, 5th 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, 9th 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

PURPOSE.........................................................................................................................................................1

PORTLAND CEMENT MANUFACTURING..........................................................................................................6

CARBON MONOXIDE FORMATION IN CEMENT KILNS.....................................................................................6

RELATIONSHIP BETWEEN NOX AND CO........................................................................................................7

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

SPECIFIC FACTORS.........................................................................................................................................8

KILN DATA AND ANALYSIS .............................................................................................................................9

AMBIENT AIR QUALITY AND DISPERSION MODELING..................................................................................11

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

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

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

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

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

AQMP AND LEGAL MANDATES...................................................................................... 1615

COMMENTS AND RESPONSE TO COMMENTS............................................................... 16
Final 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 kilns at Colton, Kiln #1 and Kiln #2. The 

production process results in a variety of kiln emissions including CO and NOx. CPCC 

uses an emissions control strategy for mitigating NOx which involves injection of used 

tires directly into the kiln. Tires introduced into the kiln reduce the kiln oxygen 

concentration and hence the formation of NOx while still maintaining 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 emissions, exceeding the Rule 407 CO emissions 

limit of 2,000 ppm averaged over 15 consecutive 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 standard in the AQMD since 2002. 

The area of CO non-attainment was a small upwind portion of south Los Angeles 

County, far from the facility in San Bernardino County, which occasionally exceeded 

the CO standard. Also, CO concentrations are localized near the source of emissions 

and do not have regional impacts as do some other air contaminants, 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 and 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 for cement kilns while still maintaining compliance with the 

ambient CO air quality standard. Based on data from CO certified continuous emissions 

monitors and subsequent analysis provided by CPCC and its contractor Mangan, Inc., 

the appropriate revised CO emissions threshold would be 1,900 ppm averaged over 

eight hours. Air quality modeling at CPCC indicates that ambient CO levels will not be 

affected by this revised CO emissions standard. 

BACKGROUND 

Purpose 

CPCC is currently the only facility manufacturing cement in the SCAQMD. The 

facility is a RECLAIM source and has undertaken a program to reduce NOx from two 

on-site kilns. The process involves injection of used tires into the cement kiln. A 

consequence of this strategy is an increase in CO emissions over very brief periods, 

exceeding the current Rule 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) exceeding 2,000 ppm by volume measured on a 

 dry basis, averaged over 15 consecutive minutes.” 

CPCC is currently operating under an Order for Abatement because of the occasional 

violation of Rule 407(a)(1). In support of the NOx reduction strategy, CPCC has asked 

the District for assistance in structuring a compliance strategy for CO specific to cement 

kiln operations. Staff has examined an array of options including a combination of 

lowering the emissions threshold in conjunction with an increased averaging period. 

Staff is recommending amendments that will not have a measurable impact on local 

ambient air quality nor contribute to exceedences of either the one or eight hour state 

standards for CO based on air quality modeling conducted by SCAQMD staff. In 

addition, the standard, compliance procedures, and 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. Figures 1 through 4 show historical ambient air quality 

within the SCAQMD for ozone, PM10 and PM2.5, respectively, and highlight NOx 

reduction as the priority. 

Figure 1. Number of days the 1-hour federal OZONE standard (> 0.12 ppm) was 

exceeded in 2005

X
Final Staff Report Proposed Amended Rule 1112.1 

3

Figure 2. Number of days the 8-hour federal OZONE standard (> 0.08 ppm) was 

exceeded in 2005

Figure 3. 2005 PM10 Annual Arithmetic Mean (μg/m3) compared to 50 μg/m3 federal 

standard

X

X

X
Final Staff Report Proposed Amended Rule 1112.1 

4

Figure 4. 2005 PM2.5 Annual Arithmetic Mean (μg/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 historically been confined to a limited area in south Los Angeles 

County. In 2008, for the fifth consecutive year since 2003, no areas in the Basin 

exceeded the CO air quality standards. 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 areas of Los Angeles County where 

vehicular traffic is most dense with the highest concentration continuing to be south 

central Los Angeles County, far upwind of CPCC. The highest 8-hour average CO 

concentration recorded for 2005 was 5.9 ppm, in the South Central Los Angeles County 

area, and was 62% of the federal CO standard. 

X
Final Staff Report Proposed Amended Rule 1112.1 

5

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

In contrast, for 2005 the Basin exceeded federal and state standards for ozone, PM10 

and PM2.5. For ozone, the maximum 1-hour 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 Central San Bernardino Mountains area recorded 

the greatest number of excedences (80 days) of both the state and federal 1-hour (18 

days) and 8-hour (69 days) standards in addition to 7 days for the health advisory level 

(Figures 1 and 2). 

For PM10, the maximum annual average concentration (52 μg/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 μg/m3) and annual average (21.0 μg/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 compared to 15 μg/m3 federal standard. 

X
Final 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 tons/day) from CO. The 

data indicates that efforts to mitigate ozone, PM10 and PM2.5, by controlling NOx and 

particulate emissions, remain the 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 location or person. The process of manufacturing 

cement begins with the quarrying of “Raw Mix” which is predominantly limestone 

rock. Raw Mix is then refined through a series of mechanical grinding and crushing 

operations which not only segregate but significantly reduce the diameter of the 

component quarried materials. The segregated materials as well as other materials 

brought to the facility and used in the manufacturing process are stored in silo bins. 

From here, limestone, shale, iron ore and silica in proprietary proportions, or kiln mix, 

are pneumatically fed into the feed end of each kiln. It takes approximately 1.56 parts 

of this kiln feed to manufacture 1 part of Portland cement. Each kiln is basically a huge 

rotating cylinder lined with refractory fire brick 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 the 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 gypsum 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 material but is composed mostly of limestone 

which is also the principle 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 oxidation of carbon compounds results in the 

formation of carbon monoxide (CO) and carbon dioxide (CO2). Both are present to an 

extent in the kiln during clinker production. In the kiln, two factors influence the 

proportions of CO to CO2. First, the amount of oxygen present 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 dioxide. Figure 5 shows that higher kiln 

temperatures tend to increase the oxidation of CO to CO2. 
Final Staff Report Proposed Amended Rule 1112.1 

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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 mitigation of NOx, namely limiting the presence of air and 

reducing peak combustion temperatures lead to increased CO emissions while the 

presence of excess air (containing oxygen) and higher kiln temperatures increase the 

proportion of kiln NOx emissions, while reducing CO by increasing oxidation of CO to 

CO2. The tire injection NOx control strategy developed specifically for CPCC 

minimizes the presence of air while maintaining 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 occasional CO spikes. There are also practical 

limitations on the amount of excess air that could be introduced into the kiln process to 

address CO emissions. Too much air would be inefficient both in terms of the extra 

energy needed to drive the increased volume flow through the kiln and also because of 

the increased fuel needed to maintain optimal kiln temperatures. 

0 500 1,000 1,500 2,000 2,500

1 x 103

1 x 10-3

1 x 10-6

1 x 100

1 x 106

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 dimensions 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 temperatures 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 the discharge end as Clinker. 

A kiln operator monitors the kiln processes in real time from a remote location and 

makes adjustments to burner flame temperature 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 results inside the kiln. Variations in 

temperature and kiln feed mix composition sometimes 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. Eliminating a dam by increasing kiln temperatures may release an 

accumulation of liquefied feed mix from behind 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 experienced operator’s job 

is more anticipating how the kiln will be reacting some time in the future, in real time, 

and working to maintain optimal kiln conditions. In empirical observations made 

during site visits to CPCC and in discussions with operational and management staff the 

following factors were found to affect 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 zones within the kilns 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 emissions, with resulting occasional 

spikes of the kiln CO emissions concentration 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 operation of CO certified Continuous Emissions 

Monitoring Systems (CEMS) installed on its two kilns. In August 2009, data captured 

by the CEMS was provided by CPCC to its contractor, Mangan, Inc. (Mangan), for 

further analysis to determine kiln CO emissions concentrations under various time 

period averaging scenarios. The raw data set provided to Mangan was comprised of 

captured one minute CEMS CO concentration observations for each of the two kilns at 

CPCC. The CEMS certified emissions data provided by CPCC spanned the months of 

July 2008 through July 2009 for Kiln #1 and August 2008 through March 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 offline for maintenance and other issues, or 

invalid data. 

Maximum CEMS CO concentrations furnished to AQMD for different averaging 

periods are summarized in Tables 1 and 2 for Kilns 1 and 2, respectively. Based on the 

analysis of over 840,000 CO concentration data values, the results suggest that neither 

of the two kilns at CPCC would have exceeded a CO threshold limit of 1,900 ppm 

averaged over eight (8) hours. 
Final Staff Report Prop

10

Table 1. CPCC Kiln #1 Maximum Reported CO Emissions (ppm) Values (provided by Mangan, Inc., August 26, 2009) 

Month 1-Minute 1Hr Average 2Hr Average 3Hr Average 4Hr Aver

July 2008 4,667 1,894 1,777 1,665 August 4,982 2,823 1,654 1,337 September 4,990 2,226 1,949 1,957 October 5,026 2,939 2,229 1,948 November 5,068 4,298 3,377 2,913 

December 4,933 784 532 459 January 2009 4,552 1,780 1,748 1,721 February 4,990 1,616 1,109 902 March 4,997 3,084 1,637 1,159 

April 4,988 1,992 1,220 921 May 4,984 1,015 761 584 June 3,106 1,037 1,030 1,023 July 4,600 860 713 678 

 Range Maximum 5,068 4,298 3,377 2,913 

Table 2. CPCC Kiln #2 Maximum Reported CO Emissions (ppm) Values (provided by Mangan, Inc., August 26, 2009) 

Month 1-Minute 1Hr Average 2Hr Average 3Hr Average 4Hr Ave

July 2008 0 0 0 0 August 5,023 2,410 2,314 2,234 September 4,996 1,816 1,173 955 October 5,030 4,012 2,735 2,166 November 4,824 2,637 1,574 1,133 

December 4,967 1,721 1,116 866 January 2009 4,957 971 721 565 February 5,010 3,051 2,444 2,251 March 4,986 4,141 3,352 2,376 April 0 0 0 0 May 0 0 0 0 June 0 0 0 0 July 0 0 0 0 

 Range Maximum 5,030 4,141 3,352 2,376 

* Current Rule 407 threshold CO limit is 2,000ppm per 15 minute period
Final 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 modeled – 2000ppm (existing rule limits, which 

represents the baseline conditions for both 1-hour and 8-hour averaging times), 

1,900ppm (PAR1112.1 for the 1-hour and 8-hour averaging times) and 6000ppm 

(facility’s maximum 1-hour emissions, used to ensure a worse-case analysis for the 1-

hour averaging time under PAR1112.1). 

Dispersion modeling was performed to assess the impacts of the proposed change to the 

1-hour and 8-hour CO concentrations. The U.S. EPA model, called AERMOD, was 

used with regulatory default options, URBAN option using the San Bernardino County 

population of 2,015,355, and fenceline receptors and a Cartesian receptor grid, based on 

the modeling performed for the submitted health risk assessment. Meteorological data 

at the AQMD’s San Bernardino meteorological site was used as input to the dispersion 

model. The worst-case CO air quality over the period 2005 to 2007 at the San 

Bernardino monitoring site (Station No. 5203) was assumed to represent background 

CO air quality. The assumed stack parameters 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. The emission rates were provided by Gary 

Thornberry in an email dated 9/16/09. Please note that for each scenario, both kilns 

were assumed to be operating at the maximum emissions, i.e., for the 6,000ppm 

scenario, both kilns 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 cubic 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) – 6000ppm scenario 2,783.3 2,309.5 
Final Staff Report Proposed Amended Rule 1112.1 

12

The modeling results are shown in Table 2. Since the project impact area is in 

attainment of all state and federal CO ambient air quality standards, the project 

increment is added to the worst-case background concentrations and the sum compared 

to relevant CO standards. As shown in Table 2, the total impacts from all scenarios are 

below all state and federal ambient air quality standards. 

Table 2. Dispersion Modeling Results.

Averaging 

Time

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 (Proposed 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 ambient air quality standards
Final Staff Report Proposed Amended Rule 1112.1 

13

Table 2. Dispersion Modeling Results.

Averaging 

time

Project 

Increment 

(μg/m3)

Background

Air Quality

(μg/m3

)

Total 

Concentration 

(μg/m3)

NAAQS 

(μg/m3)

CAAQS 

(μg/m3)

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 include CO limits in addition to 

the current particulate limits. For CO two alternatives are offered: comply with the 

current limit of Rule 407(a)(1); or as an alternative, comply with a new proposed 

standard of 1,900 ppm concentration limit averaged over eight hours and a prohibition 

against exceeding a 6,000 ppm threshold during any consecutive 15 minute averaging 

period. Modeling shows no significant impact 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 averaged over 15 minutes therefore provides a more 

conservative standard and will ensure no significant ambient air quality impacts from 

this compliance alternative. 

In addition, proposed amendments also include text on updating compliance procedures 

requiring the source to comply with updated and more rigorous requirements as 

follows: 

1. Measurement, monitoring and recordkeeping of carbon monoxide (CO) 

emissions from the cement kiln shall be conducted according to the provisions of 

District Rule 218 – Continuous Emission Monitoring. 

2. A District approved Continuous Emissions Monitoring System (CEMS) for 

carbon monoxide (CO) and oxygen (O2) must be installed no later than 

December 31, 2009, or prior to commencement of operation for sources 

beginning operation after December 4, 2009, and operated according to the 
Final Staff Report Proposed Amended Rule 1112.1 

14

provisions of District Rule 218 – Continuous Emission Monitoring. 

3. The CEMS certification tests and other sampling, analysis, and reporting shall be 

conducted by a laboratory that has been approved under the District Laboratory 

Approval Program (LAP) for the cited District reference test methods, where 

LAP approval is available. For District reference test methods for which no 

LAP program is available, the LAP approval requirement shall become effective 

one year after the date that the LAP program becomes available. 

Furthermore, proposed amendments also include text on updating test methods 

requiring the source to comply with updated and more rigorous requirements as 

follows: 

1. Carbon Monoxide emission concentration shall be determined according to the 

procedures in District Source Test Method 100.1 – Instrumental Analyzer 

Procedures for Continuous Gaseous Emission Sampling. 

2. Particulate matter emissions shall be determined according to the procedures in 

District Source Test Method 5.3 – Determination of Particulate Matter from 

Stationary Sources Using an In-Stack Filter. 

3. Other test methods may be used as determined to be equivalent and approved 

before the test in writing by the Executive Officer, the California Air Resources 

Board, and the United States Environmental Protection Agency. 

CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA) 

Pursuant to California Environmental 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 would 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 August 15, 2007. No comments were received 

relative to the Draft EA. The draft EA has been revised such that it is now a Final EA 

which is included as an attachment to this Governing Board package.

The AQMD will prepare appropriate California Environmental Quality Act (CEQA) 

documentation for the proposed amendments to Rule 1112.1. Upon completion, the 

CEQA document will be released for public review and comment, and will be available 

at AQMD Headquarters, by calling the AQMD Public 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 AUTHORITY 
Final 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 air pollution control rules and regulations in 

the Basin. By statute, the AQMD is required to adopt an Air Quality Management Plan 

(AQMP) demonstrating compliance with all state and federal ambient air quality 

standards for the Basin [California Health and Safety Code Section 40460(a)]. 

Furthermore, the AQMD must adopt rules and regulations that carry out the AQMP 

[California Health and Safety Code Section 40440(a)]. While PAR 1112.1 does not 

implement an AQMP control measure, it helps meet AQMP objectives. 

DRAFT FINDINGS 

Before adopting, amending, or repealing a rule, the California Health and Safety Code 

Section 40727 requires the AQMD to adopt 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 determined that a need exists to amend 

Rule 1112.1 – Emissions of Particulate Matter and Carbon Monoxide form Cement 

Kilns, to allow an alternative CO concentration standard for grey cement kilns, 

recognizing the concurrent environmental benefit of reducing NOx, a precursor to nonattainment pollutants of ozone and particulates, 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 California Health and Safety Code Sections 

39002, 39650, 40000, 40001, 40440, 40702, 41508, and 41700, et seq. 

Clarity - The AQMD Governing Board has determined that the proposed amendment 

to Rule 1112.1 is written or displayed so that 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 with, 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 necessary and proper to 

execute the powers and duties granted to, and imposed upon, the AQMD. 

Reference - In adopting this regulation, the AQMD Governing Board references the 

following statutes which the AQMD hereby implements, interprets or makes specific: 

California Health and Safety Code 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 Section 172(c)(1) (RACT). 
Final Staff Report Proposed Amended Rule 1112.1 

16

AQMP AND LEGAL MANDATES 

The California Health and Safety Code requires the AQMD to adopt an Air Quality 

Management Plan (AQMP) to meet state and federal ambient air quality standards with 

the South Coast Air Basin. In addition, California 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 measures in the AQMP, the 

proposed amendments do not result in additional 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. The NSPS for Portland cement plants (40CFR60 

Subpart F) applies only to particulate matter and not CO. Rule 407 is one of the 

compliance options for PAR 1112.1. The other option is a 1,900ppm concentration 

limit averaged over eight hours instead of fifteen minutes, verified by continuous 

emissions monitoring and updated measurement, 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 test methods being proposed as part of the 

amendments to the rule are available at on the SCAQMD website at: 

http://www.aqmd.gov/tao/methods/stm.html. Staff will also be happy to 

provide any additional assistance regarding this issue. 

Comment: Rule 218(f) requires that a summary 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 the procedure for submitting this data? 

Response: The source should consult with the SCAQMD Compliance division, 

through their assigned engineer/inspector to determine the specific 

procedures for complying with this reporting requirement.