## 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, 2010Lehigh Southwest Cement Company March 31, 2010 2010 HCl Emissions Tests

10087.1m iii 

### 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, 2010Lehigh Southwest Cement Company March 31, 2010 2010 HCl Emissions Tests

10087.1m iv 

### 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 ANAL YTICAL QA/QC .............................................24 6.2 QUALITY CONTRO L REQUIREMENTS ..............................................24 6.3 DATA REDUCTION PROCEDURES .....................................................24

7.0 DISCUSSION OF RESULTS .............................................................................26Lehigh Southwest Cement Company March 31, 2010 2010 HCl Emissions Tests

10087.1m v 

### 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 CALCULATIONSLehigh Southwest Cement Company March 31, 2010 2010 HCl Emissions Tests

10087.1m 1 

### SECTION 1.0

INTRODUCTION

The Avogadro Group, LLC (Avogadro) was c ontracted by Lehigh Southwest Cement Company (Lehigh) to perform a series of HC l emission tests at their facility in Redding, California. The tests were conducted accord ing to the United States Environmental Protection Agency (EPA) Information Collec tion 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 presente d in this report and are intended for the end users (Lehigh and EPA). This report include s descriptions of the scope of work for measurement of air emissions, the testing me thods and analysis procedures, the sampling and traverse point locations, the field data and calculation spreadsheets, the test results, and the quality assurance procedures. The re sults 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 equi pment to measure emissions as described in this report. Lehigh personnel coordina ted the unit operating conditions and provided the process data included in this report.Lehigh Southwest Cement Company March 31, 2010 2010 HCl Emissions Tests

10087.1m 2 

### 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 O 2 , % volume dry 11.13 CO 2 , % 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% O 2 2.96 lb/hr 1.58Lehigh Southwest Cement Company March 31, 2010 2010 HCl Emissions Tests

10087.1m 3 

### 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 O 2 , % volume dry 9.039 CO 2 , % 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% O 2 26.76 lb/hr 14.50Lehigh Southwest Cement Company March 31, 2010 2010 HCl Emissions Tests

10087.1m 4 

### SECTION 2.0

TESTING CONTRACTOR

The emission tests were conducted by Avogadr o, a recognized independent contractor that has been approved to conduct emission s ource testing on behalf of the California Air Resources Board (CARB), pursuant to S ection 91200-21220, Title 17, of the California Code of Regulations. Avogadro provided a pr ofessional 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 t eam 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 yearsLehigh Southwest Cement Company March 31, 2010 2010 HCl Emissions Tests

10087.1m 5 

### SECTION 3.0

FACILITY DESCRIPTION

Lehigh Southwest Cement Company opera tes 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 pl ant 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, calci um and iron in the proper proportions and subjecting a milled blend to extreme temperatur es in the kiln. Chemical reactions occurthat 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 cem ent 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 ma terial 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 satisf actory 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.Lehigh Southwest Cement Company March 31, 2010 2010 HCl Emissions Tests

10087.1m 6 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 transferre d 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 bl ending 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 r ubber fuels and is described in Section 2.2. Mineral formation occurs in the kiln to pr oduce clinker, which is managed by the clinker transport and storage system section describe d 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 c ooled in a spray tower and routed to the plant’s main baghouse, S260. A portion of th e 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.). Conve ying 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 cr ushed product is routed to feed bins.Lehigh Southwest Cement Company March 31, 2010 2010 HCl Emissions Tests

10087.1m 7 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 th e 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 pr oducts 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, NO X and SO 2 as well as flue gas opacity.



### 3.4 SAMPLING LOCATION
Emissions from the kiln travel through a ver tical, 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 locat ed more than two stack diameters upstream and eight stack diameters downstream from th e nearest flow disturbances. Because of Avogadro’s many years of experience testing th is unit, it has been well established that the stack gas exhaust stream meets the cr iteria 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 permanentLehigh Southwest Cement Company March 31, 2010 2010 HCl Emissions Tests

10087.1m 8 testing platform approximately 120 feet above ground level (the ports are five feet above the platform).

Avogadro personnel verified the dimensional meas urements of the stack prior to testing. A diagram of the sampling and traverse point locations is included in Appendix C.1.Lehigh Southwest Cement Company March 31, 2010 2010 HCl Emissions Tests

10087.1m 9 

### 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 un its 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

O 2 EPA 3A 1, 2, 3 1, 2, 3 Mill on Mill off With each run Paramagnetism Mobile lab CEMS

CO 2 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/ALehigh Southwest Cement Company March 31, 2010 2010 HCl Emissions Tests

10087.1m 10 

### 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 O 2 , % volume dry 11.07 10.72 11.60 11.13 CO 2 , % 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 151.55 149.19 141.62 147.45Lehigh Southwest Cement Company March 31, 2010 2010 HCl Emissions Tests

10087.1m 11 

### 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 O 2 , % volume dry 9.236 8.914 8.966 9.039 CO 2 , % 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 c ontaminants, acquired the process data from Lehigh, and reported the results. The program schedule is presented in Table 4-4.Lehigh Southwest Cement Company March 31, 2010 2010 HCl Emissions Tests

10087.1m 12 

### TABLE 4-4 PROGRAM SCHEDULE

HCl TEST PROGRAM

D ATE A CTIVITY S AMPLE R UNS S AMPLE DURATION

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

March 16, 2010 (roller mill on ) Emissions testing HCl O 2 , CO 2 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 O 2 , CO 2 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 --Lehigh Southwest Cement Company March 31, 2010 2010 HCl Emissions Tests

10087.1m 13 

### 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 laborat ory and field reference. A source test protocol, dated February 17, 2010 was subm itted to the SCAQMD and subsequently approved.

The test methods and procedures used in th is program are listed in Table 5-1. Generic descriptions of the test methods are in cluded 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 descri ptions, the version here in Section 5.0 will take precedence.



### TABLE 5-1 EMISSION TEST PARAMETERS AND METHODS LEHIGH SOUTHWEST CEMENT COMPANY

T EST 

### P ARAMETER 

### R EFERENCE 

### M ETHOD 

### A NALYTICAL 

### A PPROACH 

### D ETECTION 

### L IMIT
O 2 EPA 3A Paramagnetism 2% of full scale
CO 2 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 --Lehigh Southwest Cement Company March 31, 2010 2010 HCl Emissions Tests

10087.1m 14 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 cem ent 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-te lluride (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 ce ll used gold-surface internal mirrors. The interior cell walls were made of polished st ainless 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 condensa tion within the cell and minimized analyte adhesion to the cell walls and mirrors. Th e volume of the 10-meter absorption cell was approximately 2.0 L, so the sampling respons e 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. Sa mple spectra were recorded (based on 56 coadded interferograms). At least one 128-s can background spectrum was recorded usingLehigh Southwest Cement Company March 31, 2010 2010 HCl Emissions Tests

10087.1m 15 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 standa rd (CTS) gas was introduced to the FTIR system to determine the effective absorp tion 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 pathlengt hs varied by less than 1.75 percent. The pathlength results are presented in Tabl es 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 10.57Lehigh Southwest Cement Company March 31, 2010 2010 HCl Emissions Tests

10087.1m 16 

### 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 10.49Lehigh Southwest Cement Company March 31, 2010 2010 HCl Emissions Tests

10087.1m 17 Reference Spectra The concentration of the analytes of th e 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 sampli ng 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 ev acuated isolated sampling systems changed by less than 0.1 psi per minute.

Data Storage A dedicated computer controlled the FTIR spect rometer; 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) 0.227Lehigh Southwest Cement Company March 31, 2010 2010 HCl Emissions Tests

10087.1m 18 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 sa mpling runs. Second, our laboratory manager examines the sample spectra and the quantitativ e 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

H 2 

### O



## 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”) th en 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, theLehigh Southwest Cement Company March 31, 2010 2010 HCl Emissions Tests

10087.1m 19 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 sampli ng 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 range d 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 a bove 84%. Therefore, the test method is valid for hydrogen chloride since the percent r ecoveries 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 nativ e concentrations ranged from 13.34 to 21.69 ppmv HCl when the mill was in the off conditi on. So, the bias in the proposed method is more than B = -3.5 ppm. This yielded pe rcent recoveries that were above 82%. Therefore, the test method is valid for hydr ogen 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.Lehigh Southwest Cement Company March 31, 2010 2010 HCl Emissions Tests

10087.1m 20 

### TABLE 5-4 TEST METHOD VALIDATION – HYDROGEN CHLORIDE LEHIGH SOUTHWEST CEMENT COMPANY REDDING, CALIFORNIA

Measured Analyte Concentrations Concentrations (ppm) Sample Unspiked Spiked SF 6 (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 th e analyte in the native (unspiked) samples (ppm) Spiked Measured concentration of the analyte in the spiked samples (ppm) SF 6 (spk) Measured concentration of the tracer gas in the spiked samples (ppm)



### TABLE 5-5Lehigh Southwest Cement Company March 31, 2010 2010 HCl Emissions Tests

10087.1m 21 

### TEST METHOD VALIDATION – HYDROGEN CHLORIDE LEHIGH SOUTHWEST CEMENT COMPANY REDDING, CALIFORNIA

Dilution Factor (DF), Expected Concentration (C e ), Bias (B), and Percent Recovery (%R)
S u S m DF C s C e 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: S

m Observed mean concentration of the analyte spiked effluent samples (ppm) S u Native concentration of analytes in unspiked samples (ppm) DF Dilution factor where DF = SF 6 (spk) / SF 6 (dir) (ppm) SF 6 (dir) SF 6 concentration measured directly C

s Cylinder concentration of the spike gas (ppm) C

e Expected Concentration of the spiked samples (ppm) where C e = DF x C s + S u (1 – DF) B Bias at spike level (ppm) where B = S m

- C e %R Percent recovery where %R = 100 x [S m -S u (1-DF)]/(DF x C s )

Reporting : The results are presented in units cons istent with those requested in the EPA ICR letter dated February 3, 2010.



### 5.2 ANCILLARY TESTS
The testing program included measurements th at 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.Lehigh Southwest Cement Company March 31, 2010 2010 HCl Emissions Tests

10087.1m 22 5.2.1 Gaseous Emissions

Method: EPA 3A, Amended June 13, 1990 Deviations: None

Concentrations of O 2 and CO 2 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 syst em 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 syst em, constructed of stainless steel and Teflon tubing, to direct sample gas to the analyzers, and
7) Sample flow rate control - a seri es 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 an alyzers. The sample gas system allows for the introduction of the protocol gases to the analyzers either directly through the manifold (calibration error check - performe d once daily) or through the sampling system (system bias check - performed with each run).

The electronic analyzers are rack mounted a nd are maintained in the mobile lab. The data recording and acquisition system is base d on a digital system known as STRATA. It includes software for controlling the collec tion of calibration and emission monitoringLehigh Southwest Cement Company March 31, 2010 2010 HCl Emissions Tests

10087.1m 23 data, and hardware for connection of the anal yzer 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 acco rding to EPA Methods 1 and 2. Moisture content was measured according to EPA Method 4. The concentrations of diluent gases (O 2 and CO 2 ) were measured using EPA Method 3A during each test run. Emission rates were calculated in units of lb/hr or ot her mass flow units from the measured concentrations and volumetric flow rates.Lehigh Southwest Cement Company March 31, 2010 2010 HCl Emissions Tests

10087.1m 24 

### SECTION 6.0

QUALITY ASSURANCE AND REPORTING

6.1 SAMPLING AND ANALYTICAL QA/QC
Avogadro has instituted a rigorous QA/QC progr am 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 we re 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 inspect ed 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 labor atory 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 volumet ric flow rates, mass emission ratesLehigh Southwest Cement Company March 31, 2010 2010 HCl Emissions Tests

10087.1m 25 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 pr intouts (data input and results output) and example calculation checks. The field data sh eets with average data calculations are also included. Standard conditions used for data reduction were 29.92 inches of mercury and 70 oF.Lehigh Southwest Cement Company March 31, 2010 2010 HCl Emissions Tests

10087.1m 26 

### 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.Lehigh Southwest Cement Company March 31, 2010 2010 HCl Emissions Tests

10087.1m 27 

### 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 O 2 , % volume dry 11.07 10.72 11.60 11.13 CO 2 , % 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% O 2 4.21 2.29 2.39 2.96 lb/hr 2.25 1.29 1.21 1.58Lehigh Southwest Cement Company March 31, 2010 2010 HCl Emissions Tests

10087.1m 28 

### 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 O 2 , % volume dry 9.236 8.914 8.966 9.039 CO 2 , % 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% O 2 42.05 19.69 18.53 26.76 lb/hr 23.03 10.72 9.77 14.50