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, 2012
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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 – SCAQMD Rule 1156, Further Reduction of Particulate 

Emissions from Cement Manufacturing Facilities, is designed 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 within 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 piles. 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 concentrations 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 not 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 

requirements would affect primarily CPCC and any new operation in the future.
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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 to 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 appropriate guidance and/or 

protocols for hexavalent chromium. All samples shall be analyzed at a Districtapproved laboratory which can be audited at any time.

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

clinker materials 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 the SIP must be clear 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 CFR § 60.60) for this category were 

used to help evaluate the BACM requirements of CAA § 189(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 satisfy enforcement requirements. The stringency of 

requirements in submitted Rule 1156 is also generally consistent 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 sections 110(l) and 193 because 

the submitted SIP revision is more stringent than the rule previously approved into the 

SIP and would ensure 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.
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RECOMMENDATIONS – The following 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 for “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 underneath 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 

comply , District Rule 1157 requires that facilities install and utilize a rumble 

grate, truck washer, or wheel washer. Moreover, Ssections (d)(8)(C) and 

(d)(8)(D) of Rule 1157 have more specific requirements, including where rumble 

grates and wheel washers 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 Rule 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 

Manufacturing Facilities, Amended March 6, 2009.

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