UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

for EPA’s Direct Final Rulemaking

for the California State Implementation Plan South Coast Air Quality Management District, Rule 1156, Further Reductions of Particulate Emissions from Cement Manufacturing Facilities

Prepared by: David Grounds Reviewed by: Andrew Steckel

Christine Vineyard March 20, 20122

RULE IDENTIFICATION Agency: South Coast Air Quality Management District (SCAQMD)

SIP Approved Rule : Rule 1156

– Further Reductions of Particulate Emissions from Cement Manufacturing Facilities Adopted

– November 4, 2005

Submitted

– December 29, 2006 EPA Approved

– March 10, 2008 (72 FR 12639)

Subject of this TSD : Rule 1156

– Further Reduction of Particulate Emissions from Cement Manufacturing Facilities

Amended

– March 6, 2009

Submitted

– April 29, 2009

RULE SUMMARY

– SC AQMD Rule 1156 , Further Reduction of Particulate Emissions from Cement Manufacturing Facilities, is designe d to ensure further reductions of particulate matter emissions from cement manufacturing facilities, in order to aid in progress towards attainment of the federal and state standards, and health protection from the emissions of fine particulates

. The South Coast Air Basin is not in

attainment with the 24

- hour or annual average NAAQS for PM2.5, and is designated

serious non

- attainment for PM10 NAAQS.

Rule 1156 would strengthen the requirements for clinker storage and handling at cement manufacturing facilities, and would require ambient monitoring for hexavalent

chromium

. The current amended Rule 1156 would require total enclosure of clinker storage and handling conducted wi t hin 1000 feet from, and inside, a facility’s property
line. Rule 1156 would allow the use of alternatives, such as a three

- sided barrier covered

with a roof and wind fence for active barn

- type storage, tarp and barrier/wind fence for other active piles, and tarp for inactive pi les. The 1000 foot level is selected because most fugitive dust emissions deposit within 1000 feet from the source.

There are two Portland cement manufacturing facilities in the Basin, Californian Portland Cement Company (CPCC) and TXI Riverside Cement Company (TXI). According to SCAQMD’s staff report, TXI was the primary source of the elevated hexavalent

chromium conc entrations in the area

– particularly due to the handling and transport of clinker material. Since TXI no longer stores and handles clinker material in the open, it

would be subject largely to the monitoring requirements of Rule 1156 . CPCC currently

does n ot store and handle clinker material within 1000 feet from, and inside, its property line and CPCC would likely elect to comply with the alternative requirements in subparagraph (d)(5)(C), in addition to being subject to the monitoring provisions. These

re quirements would affect primarily CPCC and any new operation in the future.3

Changes from the approved SIP rule include:

 In Section (d) (2)(B), Loading, Unloading, and Transferring, during conveying activities, the enclosed transfer points and enclosed conveying systems shall be vented to a permitted air pollution control device.

 In Section (d) (10)(A), Compliance Monitoring Plan, operator shall submit t o the Executive Officer a complete compliance plan for wind monitoring and the monitoring, sampling and analysis of hexavalent chromium.

 In Section (d) (10)(B)(iv), Compliance Monitoring Plan, sampling analysis protocols that comply with EPA and CARB’s appro priate guidance and/or protocols for hexavalent chromium. All samples shall be analyzed at a District

approved laboratory which can be audited at any time.

 In Section (d) (11)(C), any concentration exceedance will require enclosure of all

clinker material s storage and handling.

EPA EVALUATION CRITERIA

– The following criteria were used to evaluate the

submitted Rule 1156:

1. Enforceability

– Section 110(a)(2)(A) of the CAA requires that regulations submitted to EPA for incorporation into th e SIP must be cl ear and legally

enforceable.

2. Stringency

– PM

- 10 Guideline Document (EPA

- 452/R

- 93

- 008, 4/93); Available Fugitive Dust Control Measures (57 FR 18072, 4/28/92) ; Standards of Performance for Portland Cement Plants (40 CF R § 60.60) for this category were

used to help evaluate the BACM requirements of CAA § 18 9 ( b ). We are not aware of more stringent analogous rules in other areas.

3. SIP Relaxation

– Where previous versions of rules have been SIP approved, new submittals must comply with CAA § 110(l) and § 193 regarding SIP relaxations.

EPA EVALUTION

– The current SIP submittal generally contains sufficient testing and recordkeeping requirements to sati s fy enforcement requirements. The stringency of requirements in submitted Rule 1156 is also generally consist ent with the relevant guidance mentioned above that help define BACM /BACT

. We propose to determine that our approval of the submittal would comply with CAA section s 110(l) and 193 because

the submitted SIP revision is more stringent than the rule previousl y approved into the

SIP and would e nsure equivalent or greater emission reductions of PM10 and PM2.5.

RULE DEFICIENCIES

– We have identified no deficiencies with Rule 1156 sufficient for EPA to propose less than full approval.4

RECOMMENDATIONS

– The f ollowing revisions are not currently the basis for rule disapproval, but are recommended for the next time the rule is amended.

 Please insert a definition or reference f or “haul road” in order to ensure that the requirements in (d)(7)(A)(i) and (d)(7)(A)(ii) are enforceable.

 In Section (d)(7)(A)(ii), we recommend including the additional requirements for gravel pads that can be found in Section (d)(1)(E) of District Rule 1157 for a geotextile lining unde rneath the washed gravel and for the gravel pad to be flushed with water or completely replaced as necessary to comply with the track

out threshold set forth in Rule 403.

 In Section (d)(8)(B), in addition to having opacity limits with which sources must

c omply , District Rule 1157 requires that facilities install and utilize a rumble grate, truck washer, or wheel washer. Moreover, S s ections (d)(8)(C) and (d)(8)(D) o f Rule 1157 have more specific requirements, including where rumble grates and wheel wa shers should be located, and for a sign to be posted near the rumble grate, wheel washer, or truck washer to designate the speed limit to be 5 mph for using such control equipment. We recommend inserting similar requirements into Section (d ) ( 8)(B) of 1156 in order to further strengthen the

rule.

 Section e is missing between Section d (Requirements) and Section f (Reporting and Recordkeeping).

EPA ACTION

– The rule fulfills the relevant CAA 110 and part D requirements. EPA staff recommends approval of Rul e 1156 pursuant to CAA 110(k)(3) and 301(a).

REFERENCES

– 1. Rule 1156, Further Reductions of Particulate Emissions from Cement Manufacturing Facilities, Adopted November 4, 2005.

2. Rule 1156, Further Reductions of Particulate Emissions from Cement

Manufactu ring Facilities, Amended March 6, 2009

. 3. Rule 1156, Final Staff Report, March 2009

.