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CC 07-16-2013, Exhibit C, Item 1 CC Grace Schmidt f From: Rick Kitson I Sent: Monday, July 15, 2013 3:04 I'M To: Grace Schmidt Subject: FW: Reference: September 5th Workshop on Lehigh Cement Plant Attachments: letter to the City2.pdf;Andover Tech noIogies_Dr_Staudt_Report_on Lehigh.pdf; STAFF REPORT -0913_stfr_072012.zshx.pdf;chart document.pdf Dear Grace, Attached is a correspondence about the Lehigh study session. Best regards, Rick Kitson I Public& Environmental Affairs Director City of Cupertino 10300 Torre Avenue I Cupertino, CA 95014-3255 w: 408.777.3262 1 f: 408.777.3366 rickk(o)-cupertino.org ( www.cur)ertino.org From: Barbara Kelsey [loma.prieta.chapter @sierraclub.org] Sent: Monday, July 15, 2013 12:18 PM To: Cupertino City Manager's Office; Rick Kitson Cc: City Council; 'Gary Latshaw'; heywardmail(&gmail.com Subject: Reference: September 5th Workshop on Lehigh Cement Plant Dear Mr. Brandt and Mr. Kitson: There are several questions that we feel should be answered at the upcoming workshop about the air quality impacts from the Lehigh Cement Company.The answers to these questions have direct implications to the health of the residents in our community.We feel they should receive a full public discussion. Please find the attached letter with our comments and three additional informational attachments. If by some chance you are unable to read the informational attachments, here are the links to web document versions: https•//dl dropboxusercontent.com/u/25638928/STAFF%20REPORT%20-0913 stfr 072012.ashx.pdf https•//dl dropboxusercontent.com/u/25638928/chart%20document.pdf https://dl dropboxusercontent.com/u/25638928/Andover%2i)Technologies Dr Staudt Report on%20Lehigh.pdf We are also sending a hard copy to the City Manager's office. Best regards, Gary Latshaw, Ph.D. Chair of the Air Quality Committee Sierra Club, Loma Prieta Chapter 3921 E. Bayshore Rd, Suite 204 i Sierra Club Loma Prieta Chapter Celebrating 80 years of protecting the planet S 1 E RRA 3921 East Bayshore Road, Suite 204, Palo Alto, CA 94303 CLUB loma.pri eta.chapter@sierraclub.org, TEL - (650) 390-8411 I FAX - (650) 390-8497 City of Cupertino July 14, 2013 David Brandt, City Manager Rick Kitson, Public Information Officer 10300 Torre Avenue Cupertino, CA 95014 Cc Mayor and City Council Members Reference: September 5th Workshop on Lehigh Cement Plant Dear Mr. Brandt and Mr. Kitson: There are several questions that we feel should be answered at the upcoming workshop about the air quality impacts from the Lehigh Cement Company. The answers to these questions have direct implications to the health of the residents in our community. We feel they should receive a full public discussion. During the past year the Bay Area Air Quality Management District (Air District) has issued regulations[on the plant and those regulations have resulted in a lawsuit between Lehigh and the Air District. In parallel to those regulations being d.eveloped and adopted, the Cities of Los Altos and Los Altos Hills provided funds to Breathe California of the Bay Area to contract with an independent emission-control consultant. The consultant, Dr. Jim Staudt, principal at Andover Technologies Partners, has made several recommendations that could potentially reduce emissions at minimal costs below the current Air District Regulations. Several of the consultant's recommendations were unresolved among the parties. Therefore several of the questions involve requests for operational tests to determine the efficacy of the recommendations. Most of his recommendations did not involve additional capital equipment, but impacted operations. We have also included a graph of the monthly emissions of S02, NOx, and mercury based on the records available from the Air District.3 In view of this background, we suggest the following questions be answered at the Workshop: I BAAQMD Regulation 9, Rule 13: Nitrogen Oxides, Particulate Matter, and Toxic Air Contaminants from Portland Cement Manufacturing, Staff Report by Robert Cave, Senior Air Quality Specialist, July 2012 2 Emission Control Options for Lehigh Hanson Cement Plant, Report C-12-021, by Dr. Jim Staudt, Andover Technology Partners, January 22, 2013 3 Chart from data provided by the Air District's Public Records I. Will the Air District Regulations go into effect on September 9`h, 2013 as described in the Staff Report of July 20121 and approved by the Air Board? Note: The regulations are more stringent than the minimum legal requirement as set forth by the Federal EPA. However, the Air District does have the legal authority to impose stricter regulations. Since this is a very large plant near a large metropolitan area, the Air District utilized their authority in this manner. 2. Will a tall (250-300 foot) stack be put in place for all effluents? Such a stack was strongly indicated in the consultant's report and in public discussions at Air Board meetings, but an unambiguous statement on the stack has not been made. 3. Will there be engineering tests on the operation of the Lime Slurry Injection device to determine its maximum performance in reducing toxic pollutants such as hydrochloric acid and SO2? Note: The consultant suggested that the LSI could reduce sulfur dioxide emissions by as much as 50%. The current regulations do not address SO2 other than to call for monitoring and the statement"District staff will utilize this data (monitoring) in determining any future SO2 standard." Lehigh's emissions averaged 1.9 lb/ton of clinker in Jan 2012-May 2013. At full licensed clinker production, reducing emissions by 50% would result in a health savings of nearly 30 million dollars annually. 4. Will there be engineering tests on the operation of the Selective Non-catalytic Reduction (SNCR) device to determine its maximum performance in reducing toxic pollutants such as nitrogen oxides while maintaining other pollutants below the emission standards? The consultant suggested that the SNCR could be operated to reduce NOx emissions to 2.0 lb/ton of clinker rather than the 2.3 lb/ton of clinker in the current regulations. This relatively modest improvement would reduce health costs by about 2 million dollars annually. The consultant made other recommendations on reducing NOx as well. We sincerely hope these questions will be incorporated into the planning of the workshop. Moreover, we would like to distribute the questions to the Air Board and Lehigh Cement Company in advance of the workshop so their responses can be well thought out. Sincerely, � - G Gary Latshaw, Ph.D. Chair of the Air Quality Committee of the Loma Prieta Chapter of the Sierra Club Ab WARMS e % Emissions Control Options for Lehigh Hanson Cement Plant Report C-12-021 to: Breathe California of the Bay Area 1469 Park Avenue San Jose, CA 95126 On behalf of grantors: Town of Los Altos Hills City of Los Altos 26379 Fremont Road One North San Antonio Road Los Altos Hills, CA 94022 Los Altos, CA 94022 January 22, 2013 Andover Technology Partners 112 Tucker Farm Road, North Andover, MA 01845 phone: (978) 683-9599; e-mail: s,taudtC"?AndoverTechnology.com www. n over ec no ooy.com Andover Technology Partners 112 Tucker Farm Road, North Andover, MA 01 845 Confidentiality Notice This report was prepared for the use of the client identified on the cover and may be subject to confidentiality requirements. www.AndoverTechnology.com Contents Sections Page 1. Background 1 2. Objectives 3 3. Program Results 4 www.AndoverT,schnology.com Background Lehigh Cement operates a precalciner Portland cement kiln rated at 1,497,000 metric tons of clinker per year(4535 metric TPD) in Cupertino, CA. Actual operation is roughly 6897 hrs/yr and a total 1,399,692 tons of clinker per year. The kiln, shown in Figure 1, was placed into service in 1981. Its primary air pollution control device has been a reverse-air fabric filter for dust collection which has compartments vented to the atmosphere. Gaseous emissions (NOx, CO, SO2) and flow are monitored from some of the 32 vents on the fabric filter or in the ductwork. There is also a fabric filter on the clinker cooler. The kiln is subject to US EPA's National Emission Standards for Hazardous Air Pollutants (NESHAP), which requires installation of Maximum Achievable Control Technology (MALT)by August 2015 as well as Bay Air Quality Management District(BAQMD)rules. Recently proposed BAQMD Regulation 9, Rule 13 sets limits shown below along with monitoring requirements. • 2.3 pounds NOx per ton of clinker produced averaged over 30 days • 0.04 pounds PM per ton of clinker produced averaged over 3 source test runs • 10 ppmv ammonia above baseline, dry at 7% oxygen averaged over 24 hours. • 0.2 nanograms Dioxins/Furans (TEQ)per standard cubic meter, dry at 7% oxygen averaged over 24 hours • 55 pounds Mercury per million tons of clinker produced averaged over 30 days • 3 ppmv HCI, dry at 7% oxygen averaged over 30 days • 24 ppmv Total Hydrocarbons (THC), dry at 7%oxygen averaged over 30 days, or alternatively, 12 ppmv Total Organic HAP, dry at 7% oxygen averaged over 30 days. These limits have motivated Lehigh to install additional controls. Controls that have been installed or will soon be installed include: selective non-catalytic reduction(SNCR) for NOx control, activated carbon injection (ACI) for mercury and dioxin control, lime injection (LSI) for acid gas control, mercury monitoring, modifications to the dust collector and modifications to the vents to reduce the number of monitoring points and a 300 foot chimney. www.AndoverTechnology.com Figure y r [liJ G� www.AndoverTechn,:)Iogy.com Objectives The objectives of this effort are to provide the following: Evaluate the plant to see if lower emissions are possible for the following pollutants: • NOx • S02 • Mercury • Particulate Matter(PM) If additional reductions are likely to be possible, determine what methods would be used and their estimated cost. www.AndoverTechnology.com Program Results The Lehigh Cement plant is a 1981 vintage;precalciner cement plant that has baghouses as its sole pollution control devices. The kiln baghouse, which is integral to the Kiln Mill Dust Collector KMDC system, is used to collect kiln dust that is recycled back to the kiln pyro system. Recycling cement kiln dust in this manner reduces solid waste that might otherwise have to be disposed of and also more efficiently utilizes feed materials. The mill recently installed a KMDC shuttling system that bleeds some of the kiln dust from the pyro system, which has the benefit of reducing mercury emissions. Table 1 shows average 2010 emissions compared to the new BAAQMD limits that will take effect in September 2013 and the New or Modified Source NSPS and the New Source NESHAP limits. Another source of PM emissions is the clinker cooler baghouse, although this is not a source of other gaseous emissions. To meet the new emission limits, Lehigh plans to (or has recently) install(ed) the following: • One activated carbon injection system for mercury(Hg) control • A hydrated lime injection(LSI) system for HCl control • A selective non-catalytic reduction (SNCR) system for NOx control • A 300 foot chimney to improve dispersion of pollutant gases Table 1. Emissions Rates for Lehigh Cement, New BAAQMD limits, NSPS and New NESHAP Avg. 2010 New BAAQMD New or Modified Emissions) or Title V limits NSPS or NESHAP NOx 4.0 lb/ton clinker 2.3 lb/ton clinker 1.5 lb/ton clinker N S02 1.15 lb/ton clinker 481 lb/hr 0.40 lb/ton clinker S 2.3 lb/st** P PM 0.014 lb/ton clinker 0.04 lb/ton clinker 0.02 lb/ton clinker S Hg 305 lb/million ton 55 lb/million ton 21 lb/million ton clinker N clinker clinker E Dioxin/Furan 0.2 ng/dscm 0.2 ng/dscm Total HC 24 ppmv 24 ppmv S H Total Organic HAP 12 ppmv 12 ppmv PM 0.0141b/ton clinker 0.04 lb/ton clinker* 0.02 lb/ton clinker A P HCl 7.63 lb/ton clinker I 3 1►pmv 3 ppmv * The final Portland Cement NESHAP established a PM limit on existing kilns of 0.07 lb/ton clinker **estimated by dividing by 4535 metric tons per day and 1.1 short ton per metric ton and multiplying by 24 hrs per day BAAQMD,`Bay Area 2010 Clean Air Plan Stationary Source Control Measure SSM-9—BAAQMD Regulation 9, Rule 13,Nitrogen Oxides,Particulate Matter,and Toxic Air Contaminants from Portland Cement Manufacturing, Staff Report", July 2012 www.AndoverTechnology.com Executive Summary of Results In reading the results of this report it is important to consider that this was a high level study that did not perform detailed engineering analysis. The objective was to examine if there are any technical options for additional reductions that might be examined further or if there are emission reductions that could be had at low or no cost that may not yet be reflected in the permit. This is not intended to "second guess"the work that others have done so far,but to look for opportunities that may be available for additional reductions, and when additional reductions will require significantly more cost, to explain why. It is my opinion that improvements (reduction) in the emission limits for the Lehigh Cement plant might be possible for the following pollutants and at the following cost. NOx Some improvement in the NOx emission limit may be possible through the following means: • SNCR emission reduction will vary, but is roughly 50% on average for cement kilns. It may be possible to achieve slightly lower NOx emissions than 2.3 lb/ton clinker. This would not require any additional capital cost, but would entail modest additional operating cost. • Mixing Air Technology—This could potentially improve emissions somewhat at a capital cost of roughly$520,000. It can also improve CO and SO2 emissions. • Use of natural gas in the precalciner—It is not possible at this time to determine the capital cost,but it would likely be quite modest since gas is already fired for start up. The increase in operating cost would result from the differential cost in fuel. This would also contribute to a modest reduction in PM and SO2 emissions. For this reason I believe that there are a few options to examine that might offer low capital cost approaches to a reduction in NOx emission rate to perhaps about 2.0 lb/ton clinker or less. SO2 The use of lime injection for control of HCl will also reduce SO2 emissions. This is not currently captured in the emission limit of the plant. It would be reasonable to expect roughly 50%reduction in SO2 emissions with the roughly 75% reduction in HCl emissions. These emission reductions are available at no additional cost beyond what is committed to for compliance with the NESHAP limit for HCI. Mercury Current plans are to use activated carbon injection and a bleed of kiln dust to reduce mercury emissions. It is my opinion that achieving the new or modified source Hg emission rate of 21 lb/million ton clinker would likely require either an additional baghouse (at a substantial capital cost) or bleed of nearly all of the kiln dust. I do not know what the economic impact of bleeding 100% of the kiln dust would equate to,but it might make it necessary to landfill some of the kiln dust because there are limits to how much kiln dust may be used in the final cement product. For this reason significant additional reductions in emissions beyond the limit for existing kilns (55 lb/million ton clinker) cannot be achieved without a substantial additional capital investment. www.AndoverTechnology.com PM BAAQMD has established an emission limit of 0.04 lb/ton clinker, and this is being challenged by Lehigh Cement. The 2010 emissions rate was well below this limit(0.014 versus 0.04 lb/ton clinker) and therefore the limit appears to be achievable already. Although addition of lime injection and activated carbon injection will result in a slight increase in the solids loading to the kiln baghouse, these generally have negligible impacts on outlet emissions for a fabric filter. It is recommended that some form of continuous monitoring be used for PM emissions—either in the form of opacity monitoring or a PM CEMS. In the following sections, more detailed examination of each of these pollutants will be provided which will describe why these conclusions were reached. www.AndoverTechncilogy.com 1.0 NOx Emissions NOx emissions from cement kilns are primarily the result of the combustion of fuel in the kiln. To a lesser extent they are related to nitrogen compounds in the feed material. Feed materials may also play a role in impacting NOx through the pyroprocessing necessary for the particular feed materials. Figures 1 and 2 show NOx emissions (in lb/ton clinker) for precalciner kilns based upon year on line and annual clinker capacity, respectively. The data is based upon 2002 National Emissions Inventory(NEI) data and capacity data from the Portland Cement Association (PCA). As shown, there is significant scatter in the data with a handful of outliers;2 however, some trends can be observed. For precalciner kilns that commenced operation in the time frame of the Lehigh Cupertino kiln, emission rates average around 3.5 lb/ton clinker. For facilities in the size range of the Lehigh Cupertino plant, emission rates average around 2-3 lb/ton clinker. At roughly 4.0 lb/ton of clinker(the average for January—June 2012), the Lehigh Cupertino kiln is somewhat above average. The new BAAQMD limit will be 2.3 lb/ton of clinker, which is less than 50%reduction of NOx. Figure 1. NOx emissions (lb/ton clinker) Figure 2. NOx emissions (lb/ton clinker) versus year on line.3 versus capacity.3 __-� -- _.....................I 10.00 --------------------------------------------------- ............. ------------- .. i 10.00 9.00 1............_---....... 8.00 ._.................is----.-.................._................._..._..........._......... ._.....__..,__♦.._,..__.._. 9.00 — ♦-- - 8.00 ----------...._.............-------------...---........._...__..... -,-------------- _--__------------------ 7.00 ....................... ♦ NOx ----------------- son —Power(NOx} 7.00 ♦ NOx 6.00 - =14+1(,6x--- ♦ y- 9820x015' ♦ —Power(NOx) 6.00 5.00 ... --.. ♦------------------------------------------------------. - _.. Rt 0.1817 ♦ ♦ ♦ ♦ s 00 *__ _�_.____._...__....__........... a.00 ♦ ... ♦♦ ~♦ 4.00 3.00 .-. ♦ .. i. 100 ♦ ♦♦ M - - 2.00 .... ♦... ♦ 2.00 ±R-♦-' ! ! _----_. -_ +_� 1.00 .... ---- 1.00 0.00 - — ----r- n- 0.00 1950 1960 1970 1980 1990 2000 2010 500,000 1,000,000 3,500,000 2,00 0,000 2,500,000 year online 1 - ___......__._._.........................._...___. —__ -.---------___-� capacitytpy NOx emissions may be reduced in one of two ways— • Reducing the amount of NOx formed in the combustion process, or • Reduction of the NOx after it has been formed through post-combustion methods 2 As shown,some of these outliers have unreasonable emission rates(like zero)and generally should be ignored because they are likely the result of errors in the input data. 3 US EPA Industrial Sector Integrated Solutions model documentation, Memo from J. Staudt to R. Srivastava,S, Vijay and E.Torres,Re:NOx,SO2 and CO2 emissions from Cement Kilns(Emissions Memo)—revised from comments,March 10,2009 www.AndoverTechnology.com 1.1 Reducing the amount of NOx formed Combustion occurs in two places in a precalciner cement kiln: 1)the precalciner section; and 2) the rotary kiln. Roughly 60% of the fuel is burned in the precalciner of a modern precalciner cement kiln. For older kilns this amount may be less,perhaps in the range of 50%. Because the precalciner combustion is at a lower temperature, most of the NOx formed in the precalciner is fuel NOx. In the rotary kiln, thermal NOx plays a more significant role in total NOx formation because of the higher temperature. Methods to control NOx formation are described in more detail below: Rotary Kiln - Low NOx Burner with Indirect Firing The primary burner in the rotary kiln typically fires coal, petroleum coke, or natural gas. In some kilns (not in the Cupertino kiln) alternative fuels (such as tires, solvents, or other waste materials)may also be burned in the rotary kiln, but not through the primary burner. Because thermal NOx plays an important role in NOx forration in the rotary kiln, coal is actually preferred to natural gas from the perspective of NOx control. Natural gas requires firing to a higher gas temperature to heat the materials because the flame is not as luminous. As a result, a conversion to natural gas is unhelpful with respect:to NOx control. The primary burner utilizes an indirect firing system, where the pulverized fuel (coal or coke) is not sent directly from the fuel mill to the burner,but to an intermediate fuel bin and feeder system. The advantage of indirect firing for NOx control is that it permits lower primary air levels in the near burner field, which reduces the amount of NOx formed when using a burner that permits lower excess air for lower NOx (this :is also known as a low NOx burner with indirect firing). Based upon discussions with BAAQMD,4 the Lehigh kiln is equipped with indirect firing. So, further reductions by this method are not possible. Mid Kiln Firing(MKF) MKF is when fuel is introduced to the rotary kiln at the mid-point of the kiln. Although tires are commonly introduced in this manner,s coal, coke or other fuel may also be introduced at this point. MKF has been shown to reduce NOx emissions in the rotary kiln on the order of 30%, and sometimes more. This is possible because it reduces the amount of firing needed in the 4 Telephone call with Robert Cave and Thu Bui, 1/10/13 5 The advantage of tires are that they can be used to offset purchased fuel(coal)and a tipping fee may be received. www.AndoverTechnology.com primary burner, thereby reducing NOx formation at the hottest part of the kiln where thermal NOx formation is the highest. The Lehigh kiln does not employ MKF. Mixing Air Technology (MAT) MAT is the introduction of burnout air downstream of the primary burner or downstream of MKF. With MAT it is possible to operate the primary burner and MKF at lower excess oxygen levels, thereby reducing the formation of NOx. MAT also offers the potential for lower CO emissions and lower S02 emissions (through promotion of sulfate formation and the CaSO4 reaction)because it can promote a more oxidizing environment. MAT can reduce NOx emissions by roughly 30% and it can be used to enhance NOx reduction from other technologies such as a low NOx burner with indirect firing. The Lehigh kiln does not employ MAT. Figure 3. Mixing Air Technology 6 2600 r . �Aedive Gas Rotation` _ �.. u�,-Carbon ' , Mixing of all xi .,1550 ;a:i;,* c:1,'•'t n Gasses "r 1 Without mixing arc With mixing air 6 Hansen,E.,""Staged Combustion for NOx Reduction Using High Pressure Air Injection",IEEE/PCA Conference 2002 www.AndoverTechnolo�.com Figure 4. Staged Combustion Calciner? Precalciner— Preheater Staged Combustion Calciner Calciner(SCC) SCC reduces NOx through staged combustion in the precalciner, where a fuel-rich __ ii _ Tertiary air duct (oxygen deficient) zone is - (from clinker cooler) followed by a burnout zone as Ok{�5 p shown in Figure 3. This technology results in a reduction of Cooler NOx that will vary by application, but is on the order of 30%. On an existing kiln it is necessary to modify the precalciner to allow for both the fuel rich zone and the burnout zone. This apparently was considered at the Lehigh Cement plant but was ruled out due to cost, estimated at roughly$15-$20 million.' Table 2 summarizes experience with SCC on some U.S. kilns. Table 2. Summary of NOx Performance of SCC in U.S. Kilns Source/Location NOx Uncontrolled NOx Controlled Efficiency lb/t) (lb/t) 11 US kilns(from Table 7-2) NA 2.2-3.3 NA (avg. 2.7) Florida Rock 3.5 3.0-w/o tires 17%-w/o tires 1.5-2.5 (midpoint 2.0)-w/tires 43%-w/tires Suwannee American NA 2.2-2.6(range) NA 2.4(midpoint) Titan American NA 2.0 NA Lone Star 2.8 1.8 35% Cemex Santa Cruz 9 NA 2.5 (0%coal to reducing zone NA 1.7 (50%coal to reducing zone) 32% 1.4(100%coal to reducing zone) 44% 1.8(midpoint) 28% Alternative Control Techniques Document Update-NOx Emissions from New Cement Kilns,EPA-453/R-07- 006,November 2007 7 Alternative Control Techniques Document Update-NOx Emissions from New Cement Kilns,EPA-453/R-07-006, November 2007 8 BAAQMD,`Bay Area 2010 Clean Air Plan Stationary Source Control Measure SSM-9—BAAQMD Regulation 9, Rule 13,Nitrogen Oxides,Particulate Matter,and Toxic Air Contaminants from Portland Cement Manufacturing,Staff Report", July 2012,p 21 www.AndoverTechnc)logy.com Fuel Change in Precalciner Because most NOx formed in the precalciner is fuel NOx,NOx may be reduced though fuel changes to natural gas. The level of NOx reduction will depend upon a number of variables relating to how the facility is currently operated,but since up to 60% of the fuel is typically burned in the precalciner, a significant reduction may be possible. This will also reduce S02 and PM emissions. The capital cost would likely be fairly modest since the plant already burns natural gas. The operating cost will depend upon the difference in fuel cost between natural gas and coal or other fuel (pet coke)burned in the precalciner. 1.2 Post Combustion NOx Control Methods There are two methods of post combustion NOx control, Selective Catalytic Reduction (SCR) and Selective Non-Catalytic Reduction(SNCR) There is very little experience with SCR on cement kilns, and utilizing this technology at Lehigh Cement would be costly and will not be examined further. Lehigh Cement is planning to install an SNCR system. SNCR systems are capable of roughly 50%NOx reduction on cement kilns, although there may be some variation from kiln to kiln. 1.3 Options for NOx reduction at Lehigh Cement Cupertino The facility already has committed to reduce NOx emissions to 2.3 lb/ton clinker from roughly 4 lb/ton clinker.9 It may be possible that a lower emission limit could be justified,but it would not be dramatically lower since NOx reduction of 50%would be about 2.0 lb/ton clinker. This would not require any additional capital cost, but would require a modest amount of additional reagent. Assuming urea as a reagent, $600/ton of urea and 35% chemical utilization, the incremental cost is about $1,100/ton of NOx controlled. Other options for NOx reduction that are moderate in cost may include mixing air technology and perhaps burning natural gas in the precalciner. Mixing Air Technology equipment and installation is estimated to cost roughly$520,000 in 2008 dollars, or$521,000 if 9 A review of source test data showed a range of emission rates. 4 lb/ton clinker is the average for 2010. www.AndoverTechnology.com escalated to August 2012 using the Chemical Engineering Plant Cost Index (CEPCI). 10 In addition, there would be an allowance for down-time on the kiln necessary to install the equipment. Recent operating data shows 6897 hours per year of operation, which means that installation of mixing air technology would likely be possible without impact to kiln operation. Utilizing natural gas in the precalciner(but not in the rotary kiln, however) could possibly be performed with little or no capital expense, depending upon the current design of the precalciner burners and the natural gas supply to the kiln. A more expensive approach for reducing IJOx is perhaps Mid Kiln Firing(MKF). Using the cost estimating approach used in US EPA's ISIS model", the capital cost can be estimated as roughly$4.5 million (2005 dollars) or using the CEPCI to escalate to August 2012 dollars $5.6 million, to provide a roughly 30%reduction in NOx. The MKF system includes mixing air technology. Because of the cost and the fact that tires would not be burned to reduce fuel costs, MKF is not a technology that is likely to provide reductions at low cost. In summary, I believe it may be possible to find ways to achieve a somewhat lower NOx emissions, of perhaps 2.0 lb/ton of clinker or less., without a large capital outlay. But, large reductions in NOx emissions are not possible without a significant capital outlay. Although some of these methods, such as mixing air technology, are expected to provide 30%reduction on average, in those cases where other measures have already been taken to reduce NOx, the emission reduction may be less than 30%. So, from the perspective of establishing an emission limit we might not want to take the full 30%. It is unclear what the impact would be on fuel cost to burn natural gas in the precalciner and the level of NOx reduction is also unclear at this point. 10 US EPA Industrial Sector Integrated Solutions model documentation, Memo from J. Staudt to R. Srivastava,S, Vijay and E.Torres,Re: Costs and Performance of Controls—revised from comments s,March 10,2009,p 10 11 Ibid,p.7 www.AndoverTechn(3logy.com 2.0 S02 Emissions S02 emissions are primarily released by the raw materials as they are heated. Most of the sulfur in the fuel is captured in the product as the flue gas from the kiln comes in contact with free lime in the precalciner. For this reason the sulfur in the raw materials has a significant impact on the S02 emissions. The kiln type also has an impact. As a precalciner kiln, the S02 emissions are lower than for long kilns (kilns without a separate preheater) because the S02 released by the raw materials comes in good contact with the alkaline material in the preheater and calciner. As shown in Figure 5, which shows average Portland Cement kiln S02 emissions as a function of market location and kiln type, S02 emissions from Portland cement kilns in the San Francisco market as EPA has defined it in development of the NESHAP12 are generally lower than in other markets. This is no doubt a result of the sulfur content of the raw materials. Figure 5. Average S02 emissions (in lbs/ton clinker)by kiln type and location 13 25.00 ■ PC ■ PH 20.00 ------- -- ----- Dry ■Wet 15.00 10.00 5.00 0.00 r r T r_� 7 i T 7 i d O Sic C, a i� G� 0 d Since it is not practical to change raw materials, especially limestone, reducing S02 entails add-on controls. Tail-end S02 control systems include lime injection, which is already 12 The San Francisco market as it is used here is all of northern California—not just the Bay Area. 13 US EPA Industrial Sector Integrated Solutions model documentation, Memo from J. Staudt to R. Srivastava, S, Vijay and E.Torres,Re:NOx,S02 and CO2 emissions from Cement Kilns(Emissions Memo)—revised from comments,March 10,2009,pg. 15. www.AndoverTechnology.com planned for HCl control, and scrubbers. Because of the high capital cost of SO2 scrubbers, they will not be examined. Reduction of SO2 emissions is a cobenefit of the planned HCl control approach—lime injection. Experience with lime injection has demonstrated that it captures HCl somewhat more efficiently than SO2. This is because HCl is a more reactive acid. Thus, a 75% capture rate for HCl with lime injection14 will result in an SO2 capture rate that is somewhat lower than 75%. There are a number of factors that impact this, such as injection temperature and the relative concentrations of HCl to S02; however, an SO2 removal rate of 50% seems like a reasonable estimate of the likely SO2 emission reduction if the HCl emission reduction is in the range of 75%. The actual SO2 emission reduction can be verified once the lime injection system is installed. At this time this improvement in SO2 emissions is not captured in the plant's emission limit, and therefore, these reductions in SO2 emissions are at no cost since they are a cobenefit of the HCl reduction system. The ambient SO2 levels should also be improved by the new 300 foot chimney. So, between the reduction in SO2 emission rate and the impact of the chimney, ambient SO2 levels should see an improvement. SO2 is therefore an area where there will be some significant gains as a result of what is already planned for HCl control. For this reason a significantly lower SO2 limit could likely be implemented with little or no cost to the Lehigh Cupertino cement plant. My review of emissions tests since 2007 confirm that at the moment, SO2 emissions tend to be well below the current emission limit of 481 lb/hr. is 75%is roughly what is expected for HCl based upon past HCl levels and the required emission rate per the new Portland cement NESHAP. www.AndoverTechnolo-gy.com 3.0 Mercury Emissions Mercury that is emitted from the chimney comes from mercury contained in the fuel and mercury contained in raw materials. A simple mass balance will show that mercury that originates in the fuel or the raw materials must go into the product, become a solid waste, or go up the chimney,but the mass balance in the process is complicated by the fact that mercury at high temperatures is volatilized. Figure 6 demonstrates the complexity of the mercury mass balance. The high temperature pyroprocessing necessary to make clinker ensures that the mercury is in a vapor state and does not become part of the clinker. As a result, mercury captured in cement kiln dust that is returned to the kiln for pyroprocessing eventually goes up the chimney, and the mercury emissions to the air equals the mercury introduced by the fuel and raw materials.15 This returned mercury actually contributes to a concentrating mechanism that will result in more mercury actually being circulated through the kiln in any period of time than actually is input in that time. This concentrating mechanism is a function of the degree to which the mercury that enters the kiln dust collector(baghouse) passes through the kiln dust collector (and into the atmosphere) or gets returned to the kiln. If, for example, half of the mercury that enters the baghouse exits the baghouse with the exhaust gas and the other half ends up in the kiln dust, then the mercury returned to the kiln must equal the amount of mercury that is introduced from fuel and raw materials as well as the mercury that is released up the chimney. The mercury capture plan for the Lehigh Cement plant involves capturing the mercury that is in the cement kiln dust in the baghouse. Activated carbon injected upstream of the kiln dust collector will increase the proportion of mercury that ends up in the kiln dust. A portion of the cement kiln dust is then bled off from the kiln dust collector and not reintroduced to the kiln —it might be disposed in a landfill16 but it is preferably used in the concrete product.l7 This reduces the amount of mercury that is sent back to the kiln, as in Figure 7. If all of the kiln dust were reintroduced to the kiln, then the mercury entering the kiln dust collector would increase to the point where there would be no actual reduction in mercury emissions to the atmosphere. So, bleeding off some portion of the kiln dust is necessary to achieve a reduction in mercury emissions to the atmosphere. The percent reduction in mercury emissions to the atmosphere will 15 In fact,this is how the cement kiln NESHAP limit was developed—by measurement of mercury in the input materials rather than by stack tests because more and better data was available on the mercury inputs. This also assumes all kiln dust is readmitted to the kiln,which is a good assumption for most Portland cement kilns. 16 This is a safe way to dispose of it,because lots of testing has shown that the mercury is immobilized. 17 CALTRANS permits up to 5%limestone or kiln dust in the cement product www.AndoverTechnology.com therefore depend upon both the capture efficiency of the activated carbon system and the amount of kiln dust that is not reintroduced to the kiln. Figure 6. Mercury mass balance in a cement kiln with 100%kiln dust returned to the kiln Mercury out Mercury in kiln Kiln dust collector (baghouse) Li 1L chimney Mercury in kiln dust Figure 7. Mercury mass balance with activated carbon and bleed of kiln dust from existing kiln dust collector for mercury control Mercury out Activated carbon in Mercury in kiln Kiln dust collector (baghouse) chimney Mercury, carbon and Mercury in kiln dust kiln dust out Another option is to have a second dust collector(baghouse) downstream of the primary kiln dust collector, with an activated carbon injection system between the two dust collectors, as shown in Figure 8. The second dust collector does not need to be as large as the primary dust collector since it is only for capturing activated carbon. This would avoid the need to bleed off a portion of the kiln dust from the primary kiln dust collector and would also allow for higher www.AndoverTechnc)logy.com mercury capture rates. It would also likely result in lower PM emission rates since there are two dust collectors. The disadvantage of this approach is that it has a significantly higher capital cost and requires operation of two dust collectors—each of which has a pressure drop and requires a booster fan and the associated electrical load. But, a significant advantage to this approach is that there is no concern about mercury or activated carbon contamination in the product. Figure 8. Mercury mass balance using activated carbon and a second baghouse to control mercury emissions Mercury out Activated carbon in Second baghouse Mercury in P 4J kiln Kiln dust collector it L (baghouse) chimney Mercury in kiln dust Mercury and activated carbon out To disposal Reducing mercury emissions from the current rate of roughly 305 lb/million ton clinker to 55 lb/million ton of clinker is an 82%reduction in mercury. By my estimates, this could be achieved using the single kiln dust collector by • An 82% capture rate of mercury by activated carbon, and a bleed of 100% of the kiln dust from the kiln dust collector, or, • a 90% capture rate of mercury by activated carbon and a bleed of roughly 51% of the kiln dust, or • a 95% capture rate of mercury by activated carbon and a bleed of roughly 24% of the kiln dust, or • A 97% capture rate of mercury by activated carbon and a bleed of 14% of the kiln dust from the kiln dust collector, or • some other combination of capture efficiency and bleed of the kiln dust that will result in a net 82% capture efficiency www.AndoverTechnology.com On the other hand, reducing mercury emissions from the current rate of roughly 305 lb/million ton clinker to 21 lb/million ton of clinker is just over 93%reduction in mercury. By my estimates, this could be achieved using the single kiln dust collector by: • A 93% capture rate of mercury by activated carbon, and a bleed of 100% of the kiln dust from the kiln dust collector, or, • A 95% capture rate of mercury by activated carbon and a bleed of 70% of the kiln dust from the kiln dust collector, or • A 97% capture rate of mercury by activated carbon and a bleed of 41% of the kiln dust from the kiln dust collector, or • some other combination of capture efficiency and bleed of the kiln dust that will result in a net 93% capture efficiency So, higher activated carbon injection system capture efficiencies will result in lower bleed rates. Higher activated carbon injection system capture efficiencies are achieved through higher activated carbon injection rates; however, activated carbon injection systems have practical limitations to the level of emission reduction that is possible. There is no accepted industry-wide number for this. It is my opinion that something above 90% mercury capture with activated carbon can reliably be achieved, but it is less certain if capture efficiencies of 95% or greater can reliably be achieved day in and day out.18 Therefore, a mercury emission limit equal to the New Source limit of 21 lb/million tons of clinker would likely be possible only with a second baghouse or with bleeding nearly all of the kiln dust. As will be shown in the next section, a second,polishing baghouse would cost in the range of$20-$24 million. Lehigh Cement's current plans do not include another baghouse. They are modifying the structure of the kiln and clinker cooler baghouses and the vents to form a common exit location that will be ducted to a 300 foot chimney, and according to the BAAQMD Staff Summary Report, the estimated cost for this modification to the kiln mill dust collector and modifications to the clinker cooler dust collector is roughly$28.5 million.19 18 This is not to say that it can't be done;however,there simply is not a lot of published data available for long-term operation of activated carbon systems at such high capture efficiencies. Moreover,the measurement methods have been evolving as well. So,with tim.-there should be more information available to assess whether or not very high capture rates of over 950/)can reliably be achieved. 19 BAAQMD,`Bay Area 2010 Clean Air Plan Stationary Source Control Measure SSM-9—BAAQMD Regulation 9,Rule 13,Nitrogen Oxides,Particulate Matter,and Toxic Air Contaminants from Portland Cement Manufacturing,Staff Report", July 2012 www.AndoverTechnc-logy.com 4.0 Particulate Matter (PM) There are two sources of PM—the kiln baghouse and the clinker cooler baghouse. At this time the plant continues to operate the existing kiln baghouse(the primary fabric filter) and the clinker cooler baghouse. According to BAAQMD, the facility has been able to maintain PM emissions below the new rate of 0.04 lb/ton clinker and my review of several stack testing reports confirms that.20 I have not been able to determine the details of the filter media. Assuming that the fabric filter uses "state of the arts21 filter media, the only alternatives for further PM reductions are: 1) a polishing fabric filter(usually used to capture sorbent, such as activated carbon), or; 2) improved monitoring of the existing fabric filter to assure that periods of high PM emissions (such as from leaks in filter media) are quickly identified and corrected. 4.1 Polishing Fabric Filter This is really something what would be considered to gain other benefits, such as higher mercury removal,but the cost is shown in any event. The estimated cost of a polishing 22 pulse- jet fabric filter that could be used to capture the activated carbon as well as PM that escapes the primary fabric filter is shown in Table 3. Assumptions used in this estimate are: • 360,000 dscfin • 10%moisture • Net Air to cloth ratio of 6.0 23 • Gas temperature of 3207 • Duct runs of 50 feet each way(short ductwork) and 220 feet each way(long ductwork) As a result of the high cost of a new fabric filter shown in Table 3, this is not an attractive option for reducing PM emissions. 20 I reviewed stack test reports from 2007 to 2012 made available by BAAQMD through a Public Records request. 21 Based upon what BAAQMD reports they have been told by the plant. See Footnote 4 22 Used after the current,primary baghouse that removes most particulate matter and it therefore has a much higher air to cloth ratio than the primary baghouse. 23 This is net of compartments being out of service for cleaning www.AndoverTechnology.com Table 3. Estimated cost of a polishing fabric filter Short ductwork Long Ductwork ACFM 594,000 594,000 Baghouse(installed including steel) $9,099,016 $9,099,016 Ash Handling $1,099,741 $1,099,741 Booster Fans $462,692 $462,692 Electrical $805,076 $805,076 Ductwork short $674,830 Ductwork—long $3,619,482 Foundations $529,046 $529,046 TPC $12,670,400 $15,615,052 Gen Facil $633,520 $780,753 Eng.Constr Mgt $1,267,040 $1,561,505 Proj Contingency $2,185,644 $2,693,596 Total Plant Cost Estimate(2006$) $16,756,604 $20,650,906 Pre Production Costs $73,262 $80,623 Inventory Capital $253,408 $312,301 Total Capital Requirement(2006$) $17,083,273 $21,043,830 2012 Total Capital Requirement $19,719,623 $24,291,387 Maintenance(Fixed Operating Cost) $380,112 $468,452 Variable Operating Cost 1 $499,028 $499,028 Estimated using algorithms developed for US EPA's Clean Air Markets Division to estimate cost of polishing pulse-jet fabric filters.24 4.2 PM Monitoring Options PM emissions are currently measured with periodic stack tests rather than continuously, and the final EPA NESHAP for Portland Cement:kilns only requires periodic stack tests.25 Periods of high PM emissions may result from leaks in filter media or plant transients that cause unusually high PM excursions that are not captured during the periodic stack tests that are performed when the plant is generally well controlled. Continuous monitoring will enable plant personnel to quickly identify temporary periods of high PM emissions and address any problems that cause these temporary high PM emissions. Options for providing improved PM emissions assurance include: • Opacity monitors—these measure the:optical density or transparency of the flue gas typically in percent and provide a relative indication of PM emissions. They have been widely used for providing an indication of PM emissions. The output of these 24 Andover Technology Partners,"TOXECON Cost Estimates for Coal-Fired Boilers"DRAFT,December 2006 25 This is a revision from the proposed rule that required PM CEMS. The decision was based upon ability to correlate emissions against stack samples for very low emitting sources. www.AndoverTechnology.com devices are in terms of percentage of optical transmittance. Because they do not correlate as directly to the PM emission rate as PM CEMS, PM CEMS have become favored recently, at least for power plants. BAAQMD has recommended an opacity limit of 10%.26 Therefore, an opacity monitor should be required as a minimum measure for monitoring PM emissions. • PM CEMS—more recently, EPA has been requiring PM CEMS for power plants. These can provide an output that is directly correlated to PM emissions concentration (such as milligram per actual cubic meter) and are therefore favored for measuring PM emissions. The originally proposed Portland cement NESHAP required PM CEMS but the final rule did not. • Bag leak detectors—While not used for compliance reporting, these are used by facility owners to quickly identify leaking filter media. As a result, opacity monitoring should be required as a minimum, with PM CEMS to be examined further. Based upon conversations that I have had with some CEMS suppliers, a PM- CEMS is expected to cost in the range of$200,000 to cover equipment, installation, and start up testing/calibration. Opacity monitors will cost a fraction of that. 26 BAAQMD,`Bay Area 2010 Clean Air Plan Stationary Source Control Measure SSM-9—BAAQMD Regulation 9,Rule 13,Nitrogen Oxides,Particulate Matter,and Toxic Air Contaminants from Portland Cement Manufacturing, Staff Report", July 2012 www.AndoverTechnology.com Bay Area Air Quality Management District 939 Ellis Street San Francisco, CA 94109 Bay Area 2010 Clean Air Plan Stationary Source Control Measure SSM-9 BAAQMD Regulation 9, Rule 13: NITROGEN OXIDES, PARTICULATE MA'rTER, AND TOXIC AIR CONTAMINANTS FROM PORTLAND CEMENT MANUFACTURING Staff Report July 2012 Prepared by: Robert Cave Senior Air Quality Specialist Planning, Rules and Research Division ACKNOWLEDGEMENTS The following District staff members participated in the development of the proposed amendments to this rule, and deserve recognition for their important contributions: Brian Bateman — Compliance and Enforcement Scott Beaver— Planning, Rules and Research Thu Bui — Engineering Kristina Chu — Communications and Outreach Tony Gambardella — Compliance and Enforcement John Marvin — Compliance and Enforcement Dick Rodriguez— Compliance and Enforcement Adan Schwartz— Legal Eric Stevenson —Technical Tim Underwood —Technical 1 TABLE OF CONTENTS 1.0 EXECUTIVE SUMMARY..............................................................................................................3 2.0 BACKGROUND..................................................,..........................................................................4 3.0 TECHNICAL REVIEW................................................................................................................10 4.0 REGULATORY PROPOSAL......................................................................................................14 5.0 EMISSIONS REDUCTIONS.......................................................................................................18 6.0 ECONOMIC IMPACTS...............................................................................................................20 7.0 ENVIRONMENTAL IMPACTS...................................................................................................25 8.0 REGULATORY IMPACTS..........................................................................................................26 9.0 RULE DEVELOPMENT PROCESS...........................................................................................27 10.0 CONCLUSION............................................................................................................................35 11.0 REFERENCES............................................................................................................................36 APPENDICES A. Comments and Responses B. Socioeconomic Analysis C. March 29, 2011 Letter from Jack Broadbent, Executive Officer of the Air District, to Supervisor Liz Kniss, Santa Clara Board of Supervisors D. California Environmental Quality Act Analysis 21. 1.0 Executive Summary The Bay Area Air Quality Management District ("BAAQMD" or "District') is proposing adoption of Regulation 9, Rule 13: Nitrogen Oxides, Particulate Matter, and Toxic Air Contaminants from Portland Cement Manufacturing ("Regulation 9-13" or "the rule"). This source category was identified for potential emissions reductions of nitrogen oxides (NOx) and particulate matter (PM) in the Bay Area 2010 Clean Air Plan, Stationary Source Control Measure SSM-9. The proposed rule sets emissions standards for NOx, PM, and toxic air contaminants (TACs). The rule also proposes modifications to the emissions stack of the kiln based on analysis of health risk effects to the surrounding community, and would impose fugitive dust control and mitigation measures at the facility to further reduce particulate emissions. Portland cement manufacturing is a multi-billion dollar industry in the United States, with annual domestic consumption of over 500 pounds per person. One hundred plants across the country produce 85 to 90 percent of this total with imports accounting for the remaining portion. In August of 2010, the United States Environmental Protection Agency (EPA) issued final amendments to the National Emission Standards for Hazardous Air Pollutants (NESHAP) for the Portland Cement Manufacturing Industry. The revised NESHAP significantly reduces emissions of TACs from new and existing Portland cement kilns, but it has been challenged in Federal Court, and the effective date of the emissions standards may be delayed or the standards reduced in stringency, pending the final version to be issued in December of this year. In order to ensure that emissions of TACs from the manufacture of Portland cement are significantly reduced in the Bay Area, the 2013 effective date of the 2010 amended NESHAP has been retained in the proposed Regulation 9-13. The Lehigh Southwest Cement Plant (Lehigh) located in unincorporated Santa Clara County, west of Cupertino is the only Portland cement manufacturing facility located in the District. One of the few cement plants in the country located in an urbanized area, it has been in operation since 1939, and has undergone many changes as the surrounding community has developed around it. The cement kiln at Lehigh currently represents the largest single source of NOx emissions in the District without modern add-on controls, emitting an average of 1700 tons of NOx per year. Emissions of TACs and PM, along with others from the plant have generated significant concern from the surrounding community. The most recent renewal of the Title V permit for the facility included a public hearing and two separate public comment periods from which the District received oral comments from 30 individuals and 75 written comments from individuals and organizations. Adoption of the proposed rule would reduce emissions of NOx, PM, and TACs, and ensure environmental health protections for the surrounding community. The costs associated with the controls and other equipment modifications necessary to meet the standards and other provisions of the rule are not insignificant, but analysis shows the standards of the rule to be cost-effective and feasible considering their synthesis with impending federal standards. An independent analysis found the proposed rule to pose no adverse environmental impacts and a California Environmental Quality Act (CEQA)Negative Declaration is proposed. 3 2.0 Background Portland cement is combined with water, gravel, sand, or other aggregate to form concrete, which is used in road building and a variety of other construction projects. Portland cement manufacture is a $10 billion per year industry in the United States. In 2008, Americans consumed 104 million tons of cement nationally, or 675 pounds per person for the year. Between 85% and 90% of that is produced in the United States with the rest imported primarily from China, Canada, Colombia, Mexico and Korea. There are 108 Portland cement manufacturing plants operating in 36 states, with 11 in California, three in Northern California, and one in the Bay Area. Lehigh Southwest Cement Plant (Lehigh), located in unincorporated Santa Clara County, west of Cupertino, is the only cement manufacturing facility in the District. Consistent with national trends, Lehigh has reduced production annually since 2006. Their BAAQMD permit limits their production of clinker (a preliminary stage of cement) to 1.6 million tons per year, but in 2010 Lehigh produced 847 thousand tons of clinker, a little over half the permitted amount. Portland cement manufacturing is the third largest industrial source of emissions of NOx and sulfur dioxide (S02) in the nation at 180 thousand tons per year. Lehigh is the Bay Area's largest source of NOx emissions without modern NOx controls such as ultra-low NOx burners or add-on controls such as catalytic reduction. This facility emitted 1,798 tons of NOx and 181 tons of SO2 in 2008. The plant has been in operation since 1939, and is subject to a variety of District, State, and federal air quality rules and. regulations. District staff has evaluated more stringent standards for NOx, PM, and S02. In addition, U.S. EPA has adopted amendments to federal rules affecting this facility, initially with compliance due in September of 2013; however, in June of this year, EPA proposed revisions. to some of the emissions limits, monitoring methods, and compliance dates for the rules with final approval for these revisions set for December 20, 2012. Staff has evaluated the standards and compliance deadlines of these federal rules to ascertain their application to this facility and to determine what additional technologies and/or methodologies could be employed to reduce emissions of air pollutants in a cost effective manner. Portland Cement Kiln Overview Portland cement is a fundamental ingredient: of concrete, consisting of calcium, silicon, aluminum, and iron. These materials are combined in a number of steps requiring careful control to ensure that the final product meets specific chemical and physical specifications required for building and construction needs. Figure 1 shows a schematic diagram of Portland cement manufacturing. is Figure 1 —Schematic of Cement Manufacturing Process Packing Dust Collection Preheat Tower Row Cod mill B;Ak M' Cement Loading Was te Sr7os Fuel l Gypsum Q Un T - cernent Miffs ��ng Cooling Storage Citnker S SCHEMATIC DIAGRAM OF A CEMENT PLANT Manufacturing Steps Portland cement manufacturing is a series of steps which take place at a large industrial facility usually located adjacent to a source of raw materials. Raw materials consist of limestone, shells or chalk, clay, sand, alumina and iron ore. The bulk of these are mined at a quarry, blended, and ground to a powder. This blended material is subjected to intense heat in a kiln to cause a series of chemical reactions, transforming the powdered raw materials into something called cement clinker. Cement clinker consists of grayish-black pellets the size of marbles or golf balls, which is cooled, ground and mixed with gypsum and other additives to form powdered Portland cement. In the initial manufacturing step, limestone is mined from a quarry near the plant. At the quarry, the material is reduced to a manageable size (from chair or desk size to softball size) by a two- stage primary crusher before stockpiling and transport to the kiln. The limestone is crushed for a third time and then pre-blended to homogenize the quality of the limestone. It is then mixed with bauxite (a source of alumina) and iron ore before being ground inside a ball mill and further blended to create the required proportions necessary for the desired end product. In older cement manufacturing plants water is added to the raw materials to form a slurry, and grinding and mixing operations are completed in a slurry form. This aids in conveying the material, but the dry method is ultimately more energy efficient. The Lehigh facility converted from wet to dry process in 1981. In order to produce clinker the material must be heated to at 5 least 2400 degrees Fahrenheit and this is much easier when the raw materials are dry. At modern plants, the materials are preheated before entering the kiln and at many facilities the process of making cement is begun at this stage in a process called precalcining. A preheater/precalciner tower is utilized at the Lehigh facility to heat the material to approximately 1650 degrees F, and begin the cement manufacturing process prior to the material entering the rotary kiln. At the heart of the manufacturing process is the cement kiln. The blended mixture of raw material is fed from the preheater/precalciner into the upper end of a tilted rotating cylindrical kiln where it will reach temperatures of 2400 to 3000 degrees F. This intense heat causes the material to fuse and undergo chemical reactions to create cement clinker. The clinker is discharged from the lower end of the kiln where it is cooled and then ground into a fine powder. Some of this heat is recovered at this stage and routed to the preheater. The ground clinker is mixed with gypsum and ground one final time to make the final product. Emissions from Portland Cement Manufacturing The manufacturing of cement requires the movernent and processing of many tons of material as well as the combustion of large amounts of fuel in order to heat that material to extremely high temperatures. Emissions of pollutants are directly attributable to both the fuel combustion and materials processing. The formation of NOx during the manufacture of cement is due to the high temperature, oxidizing atmosphere necessary for clinker formation. Emissions of TACs arise from the presence of these compounds predominantly in the raw materials and to a lesser extent the fuel to fire the kiln. Predominant TACs emitted include mercury, hydrochloric acid (HCl), benzene, dioxins and furans, and dependent on the raw materials used, metals such as lead and hexavalent chrome. Particulate emissions arise from crushing, mixing and storage of raw materials, clinker production and cooling, finish grinding, packaging, and from vehicle traffic. NOx is linked with a number of adverse effects on the respiratory system. It is a major precursor to the formation of ground level ozone and also a precursor to secondary fine particulate formation. Ozone can worsen the effects of bronchitis, emphysema, and asthma, and is the primary component of photochemical smog. Exposure to fine particulate matter is by far the leading public health risk in the Bay Area, accounting for more than 90% of premature mortality related to air pollution. Coarse particulate can exacerbate respiratory ailments in addition to nuisance complaints. For the most part, emissions of metallic TACs are limited at Lehigh due to low levels in raw materials and fuel used at the plant, combined with the high level of control from fabric filtration systems in use at the plant. Mercury emissions are more significant than other metallic TACs due to relatively high mercury levels in the limestone quarried at the facility and because the metal is volatilized by the high temperatures of the kiln. Mercury can damage the central nervous system, kidneys, and liver. Short-term or acute exposure can cause skin rashes, diarrhea and respiratory distress. Chronic exposure can cause muscle tremors, irritability, personality changes, and nerve damage ranging from loss of sensitivity in hands and feet to difficulty in walking, slurred speech, and in severe cases paralysis and death. Mercuric chloride has caused increases in several types of tumors in rats and mice, and methyl mercury has caused kidney tumors in male mice. 6 Other TACs emitted from the kiln include hydrochloric acid (HCL), dioxins, furans, and benzene. HCI may cause eye, nose and respiratory tract irritation and inflammation at acute exposures and chronic exposure at lower concentrations may lead to gastritis, chronic bronchitis, and skin problems. Exposure to dioxins and furans can cause skin disorders, liver problems, impairment of the immune system and effects on the developing nervous system. Long term exposure to benzene causes harmful effects on bone marrow, a decrease in red blood cells, and can impair reproductive organ function in some women. Dioxin, furans, and benzene are all recognized to cause carcinogenic effects from long term exposure. Federal Regulations Two federal rules address air emissions from the manufacture of Portland cement: New Source Performance Standards (NSPS) and National Emission Standard for Hazardous Air Pollutants (NESHAP). EPA generally promulgates NSPS for specific industrial operations to address emissions of criteria pollutants from new, modified, and reconstructed sources. NESHAP addresses emissions of TACs (also known as hazardous air pollutants) from both new and existing sources, and may have separate standards for each case. The NSPS for Portland cement manufacture was originally promulgated in 1971, and has been amended many times. Clean Air Act amendments of 1977 require a quadrennial review of all NSPS and, if deemed appropriate, EPA revises the standard. The most recent amendments to the NSPS were proposed in June of 2008 and finalized in August of 2010. The previous standard remains in effect for all sources constructed after 1971. For facilities constructed, modified or reconstructed after June 6, 2008, emissions standards have been made more stringent, and the monitoring methodology has been modified. EPA is requiring continuous emission monitoring systems (CEMS) for each of the three pollutants covered under the NSPS (PM, NOx, and SO2). Because the Lehigh facility has not been modified or reconstructed after June 6, 2008, it is not subject to the new emissions standard (modifications to the kiln in 1981 make them subject to the 1979 standard). EPA initially issued the NESHAP for Portland cement manufacture in 1999 to limit emissions of PM as a surrogate for certain toxic metals contained in cement kiln and clinker cooler PM, to limit dioxin/furan emissions, and to set a hydrocarbon limit for new kilns. Several organizations filed petitions for judicial review of that rule. In 2000, the US Court of Appeals remanded parts of the 1999 standard and instructed EPA to consider standards for hydrochloric acid (HCL), mercury, total hydrocarbons, and metallic hazardous air pollutants. In December of 2006, EPA issued final amendments to the NESHAP to set limits for mercury and total hydrocarbons for kilns built after December 2, 2005 and to require that existing kilns meet "work practice" standards to reduce emissions of mercury and hydrocarbons. In a separate December 2006 action, EPA announced that it would reconsider the emission limits for mercury and total hydrocarbons for new cement kilns. Prior to that action, EPA had been sued by the cement industry, environmental groups, and state environmental agencies on the final amendments, and also received petitions to reconsider the existing source standards for mercury, hydrocarbons, and the decision not to regulate HCI. On April 21, 2009 EPA proposed to amend the NESHAP to reduce emissions of mercury, total hydrocarbons, HCI, and PM from both new and existing cement kilns. 7 On August 6, 2010, EPA issued final amendments to both rules. These were then appealed directly to EPA, and further challenged in Federal Court. On June 22, 2012, as part of a settlement agreement, EPA revised its proposed emissions limits for PM and Organic HAPs, and made changes to monitoring requirements and extended the compliance date to September 10, 2015. The revised NESHAP significantly reduces hazardous (toxic) emissions from new and existing Portland cement kilns, and the NSPS further limits criteria pollutant emissions from new and modified operations. Table 1 illustrates the standards in the federal NSPS for NOx, S02, and PM; and Table 2 shows the NESHAP limits. Table 1 —2012 New Source Performance Standards Pollutant Emission Limit Oxides of Nitrogen(NOx) 1.5 lb/ton of clinker, averaged over 30 days Sulfur Dioxide (S02) 0.4 lb/ton of clinker, averaged over 30 days Particulate Matter(PM)* 0.02 lb/ton of clinker, averaged over 30 days Table 2—2012 National Emission Standards for Hazardous Air Pollutants Pollutant Existing Facilities New and Modified Facilities Mercury 55 lbs/million tons of clinker, 21 lbs/million tons of clinker, averaged over 30 days averaged over 30 days Dioxins/Furans* 0.2 nanograms/dry standard 0.2 ng/dscm(TEQ)*, averaged cubic meter(ng/dscm)(TEQ), over 24 hours averaged over 24 hours Total Hydrocarbons 24 parts per million by volume 24 ppmv, averaged over 30 (ppmv), averaged over 30 days days Total Organic HAP* 12 parts per million by volume 12 ppmv, averaged over 30 (ppmv), averaged over 30 days days Particulate Matter(PM)* 0.07 lb/ton of clinker, averaged 0.02 lb/ton of clinker, averaged over 30 days over 30 days Hydrochloric Acid (HCL) 3 ppmv, averaged over 30 days 3 ppmv, averaged over 30 days *NOTES: The PM standards were raised from 0.01, and 0.04 to 0.02, and 0.07 in the June 2012 proposed revision. The Total Organic HAP standard was raised from 9 to 12 in the June 2012 proposed revision. The Total Organic HAP standard is an jilternative to the Total Hydrocarbon Standard. The Dioxin/Furan standard is unchanged from the previous NESHAP standard. Toxic Equivalent (TEQ) weighs the toxicity of less toxic compounds as fractions of the most toxic compound of the group. The amended NESHAP will reduce emissions of mercury, total hydrocarbons, HCI, and PM from both new and existing kilns. EPA estimates that by that date the NESHAP will result in national emissions reductions from cement kilns of 92% for mercury, 83% for total hydrocarbons, and 97% for HCl. The federal regulation would reduce emissions at the Lehigh facility by approximately the following amount,: 93% for mercury; 91% for total hydrocarbons; 13 and 70% for HCI. The Lehigh facility is not "new or modified" and so only the amended NESHAP limits would apply and not the amended NSPS limits. Legislation has been passed by the US House of Representatives and been introduced in the Senate to stay or rescind these federal regulations. As stated previously, the NESHAP was challenged in Federal Court, and a settlement agreement was reached in April of this year between EPA and the Portland Cement Association and several cement manufacturers. The agreement stayed the litigation and stipulated that EPA publish a notice of proposed rulemaking that addresses the concerns raised regarding the standards and will either propose a two year delay, or leave the NESHAP unchanged and solicit comments on potentially extending the compliance deadline to 2015. On June 22, 2012, EPA proposed revisions to the emissions standards for PM and Organic HAPs, the methods of determining compliance for PM, and the compliance date. The PM standards were changed from 0.01 pounds per ton of clinker for new kilns, and 0.04 pounds per ton of clinker for existing kilns, to 0.02 pounds per ton of clinker, and 0.07 pounds per ton of clinker. In addition, these limits are no longer averaged over 30 days, but rather over three source test runs, since the revised rules do not rely on a PM CEMS. The standard for Organic HAPs was raised from 9 ppmv to 12 ppmv, but the averaging period remains the same. The date of Compliance was changed from September 9, 2013 to September 10, 2015, to allow facilities more time to install emissions controls in order to comply with the rule requirements. California Regulations All cement kilns operating in California are subject to permitting by the local air district. Major sources of air pollution like the Lehigh facility are required to obtain Title V operating permits which incorporate the applicable NESHAP, NSPS and District regulations. There are currently no State rules that specifically regulate cement manufacture, other than greenhouse gas emissions reporting requirements and those rules governing the use of scrap tires as fuel. Several air districts (Antelope Valley, Amador, Kern, Mojave, and Monterey Bay Unified) with cement kilns operating within their jurisdiction have adopted regulations to address emissions of NOx and/or PM from these sources. South Coast Air Quality Management District has adopted several cement manufacturing regulations addressing emissions of NOx, PM, and CO, as well as hexavalent chromium and fugitive dust. At least two of these regulations were adopted to address specific conditions at individual cement manufacturing facilities. Applicable BAAQMD Regulations While there is currently no BAAQMD rule which specifically addresses cement manufacturing operations, these operations are subject to a number of District regulations that govern permitting (e.g., Regulation 2-1, 2-2), emissions of toxic or hazardous compounds (Reg. 2-5), and some general or miscellaneous regulations for individual pollutants (Reg. 6-1 for PM, Reg. 8-2 for Volatile Organic Compounds (VOCs), Reg. 9-1 for S02, and Reg. 11-1 for lead). Requirements of these rules are incorporated into the Title V permit for Lehigh along with the applicable federal requirements of the NESHAP and NSPS. 9 3.0 Technical Review Controlling Emissions from Cement Manufacturing The manufacturing of cement requires the movement and processing of many tons of material as well as the combustion of large amounts of fuel in order to heat that material to extremely high temperatures. Emissions of pollutants are directly attributable to both the fuel combustion and materials processing. Any improvements to the efficiency of the material handling processes as well as the delivery of heat can result in a reduction in emissions to the atmosphere. Over many years of operation Lehigh has implemented efficiency related modifications to their process as the state-of-the-art of cement manufacturing has developed. The facility has switched from a wet to a dry process, introduced heat recovery methods, and installed a precalcining tower. The driving force behind these modifications has been financial, but the improved efficiency has also reduced emissions. There do not appear to be any obvious additional modifications of this type that might be undertaken at this time. Add-on emissions control or improvements to existing emissions control devices hold far greater potential to reduce emissions in a cost effective manner. NOx Emissions Control The formation of NOx during the manufacture of cement is due to the high temperature, oxidizing atmosphere necessary for clinker formation. NOx is primarily formed by two mechanisms: the oxidation of molecular nitrogen in the combustion air or "thermal NOx"; and the oxidation of nitrogen compounds in the fuel or "fuel NOx". Although the contribution of fuel NOx cannot be discounted, in the high temperature zone of cement kilns, thermal NOx is the dominant contributor to NOx formation. Additionally, some NOx may be formed by oxidation of nitrogen compounds from the raw materials or "feed NOx", and a small amount of NOx is formed instantaneously at the flame surface or "prompt NOx." The predominant nitrogen species in cement kiln exhaust gas is NO, at typically up to 90-95%, with NO2 accounting for the remainder. A number of post-combustion or add-on control techniques have proven successful at removing NOx in exhaust streams from a variety of industrial combustion sources. These include scrubbing technology utilizing various chemical additives, oxidation technology utilizing hydrogen peroxide, and selective reduction technology utilizing ammonia or urea injection either with or without a catalyst present. The applicability of these add-on NOx controls to the exhaust from cement kilns is somewhat limited by high temperature, high flow rate, and high level of particulate in the exhaust. The cost, availability, and handling requirements of the chemical additives can further restrict their usefulness in this application. The two post-combustion techniques that present the greatest likelihood of successful NOx reduction from cement kiln exhaust are selective non-catalytic reduction (SNCR) and selective catalytic reduction (SCR). Both SNCR and SCR utilize a nitrogen based reducing agent (usually ammonia or urea) to convert NOx into molecular nitrogen (N2) and water vapor(H2O). 1D Use of either SNCR or SCR would require substantial equipment upgrades as well as operational modifications to any cement manufacturing plant. Operational plans and equipment are required for the delivery, storage, and mixing of the ammonia-based reagent. The complexity of this depends on the form of the reagent used. The performance of these systems is highly dependent on temperature, residence time, and concentration of the applied reagent. Control systems to monitor these variables as well as CEMS for NOx and ammonia are required to determine the optimum conditions to maximize NOx control and minimize emissions of unreacted ammonia. Emissions to the atmosphere of unreacted ammonia resulting from the use of SNCR and SCR are referred to as "ammonia slip" and can result in odor concerns, stack plume visibility problems and secondary PM formation. Additional issues associated with poorly managed SNCR systems at cement plants include the potential for increased emissions of carbon monoxide (CO), and N2O (more likely when using urea as a reagent). SNCR has proven an effective means of NOx control at a number of cement kilns across Europe, Japan, and the United States. The first trial use of this technology in cement manufacturing occurred in Europe in 1979, with further trials carried out at cement plants in Europe and Japan throughout the 1980s. As of 2007, over 60 cement plants across Europe utilized SNCR for the control of NOx emissions achieving control efficiencies in excess of 50%. Higher NOx reduction efficiencies are possible when SNCR is paired with staged combustion or some other combustion modification. In the United States, the application of SNCR to cement kilns is more recent and initially only proved successful on preheater/precalciner kilns. However, there are currently several cement plants across the country utilizing SNCR including wet kilns, long kilns and those using waste derived fuels. Reported NOx control efficiencies for the US applications run from 12%to 65%. Higher efficiencies are generally associated with higher concentrations of ammonia added to the flue gas, and this often results in greater ammonia slip (emissions of unreacted ammonia). SCR has proven an effective means of NOx control for a variety of combustion sources, from gas turbines at power plants to industrial boilers to diesel locomotives and even automobiles. The application of this technology to cement kilns is much more limited. Primarily, this is due to the high levels of dust in cement kiln gas at the temperature favorable for SCR use. In determining emissions levels for the NSPS, EPA considered lower NOx levels based on performance of SCR, but determined that SCR was not "sufficiently demonstrated technology for this industry." PM Emissions Control Particulate emissions arise from a variety of activities at cement manufacturing facilities, some of which are amenable to collection and control by add-on systems and some of which are fugitive in nature (i.e., not emitted from a stack) but which may be nevertheless reduced by mitigation methods. Dust sources amenable to collection and control include crushing, mixing and storage of raw materials, clinker production and cooling, finish grinding, and packaging. Of these sources, the largest single point of emissions are the stack emissions from the kiln including the feed system, fuel firing, and clinker cooling and handling systems. Fugitive 11 emission come from quarrying and primary crushing of raw materials, storage and handling of raw materials, fuel, clinker, and finished product, and from vehicle traffic. Fugitive dust emissions are best controlled by efficient site design and lay-out as well as proper maintenance and operation of equipment to reduce spillage and air leakage from collection systems. These can be addressed appropriately in a dust mitigation plan and operation and maintenance plan. Fugitive dust control and mitigation measures may include open pile wind protection, use of water spray or chemical dust suppressors, paving, road wetting, and housekeeping requirements, and humidification of stockpiles. Additional measures may include enclosing or encapsulating dusty operations such as grinding, screening and mixing, covering conveyors and elevators, vacuum systems to prevent formation of diffuse dust from spillage during maintenance operations, and flexible filling pipes for dispatch and loading processes. Particularly dusty operations may require ventilation and collection by a control device similar to that for stack emissions. Various systems have been employed in the cement industry to control point source or stack emissions in the past, but the predominant means, of add-on particulate control currently in use are either fabric filtration (bag houses), electrostatic precipitation (ESP) or a combination of the two (hybrid filters). Hybrid filters are often ESP systems that have been modified to include a bag house in order to extend the useful life of the control device. In some cases a cyclonic separator may be used to remove larger particulate matter upstream of these fine particulate control devices. Fabric filters are very efficient at dust collection, with the basic principle of a fabric membrane that allows the gas to pass but retains particulate. The most common large scale systems use hanging bags arranged geometrically across the top of a box or chamber, hence the name "bag house." Dust is deposited both on the surface and within the fabric, and in time the dust itself becomes the dominant filtering medium. Periodic cleaning of the fabric membrane is required as dust builds up and resistance to gas flow increases. The most common cleaning methods are compressed air pulsing, reverse airflow, mechanical shaking or vibration. Usually baghouses have multiple chambers that can be isolated in ease of bag failure, and to maintain efficiency during the cleaning cycle. Filter bags are available in a variety of woven and nonwoven fabrics with some synthetic fabrics that can operate effectively at temperatures above 500°F. Monitoring systems such as bag leak detectors can ensure continuous efficient operation of the control equipment and often detect failures in advance of emissions excesses. TACs Emissions Control The TACs addressed in the proposed regulation as well as the federal NESHAP come in a variety of forms, so that control thereof is equally varied. The addition of adsorptive materials to the production process can be utilized to adsorb organic compounds, ammonia and ammonium compounds, HCl and mercury. The removal of toxic compounds that are emitted in solid form such as lead, beryllium and chrome is also increased slightly by the use of activated carbon. Acidic compounds can be removed through use of scrubbers which either spray caustic liquid 12 into the kiln itself or into a separate reaction chamber downstream of the kiln. Alternatively, dry lime can be utilized in place of the caustic solution. Dioxins and furans are controlled by activated carbon or through operational controls such as maintaining a lower inlet temperature to the baghouse or other particulate abatement device. Adsorption addition refers to adding lime or activated carbon to the cement manufacturing process in either a wet or dry form when raw materials are mixed prior to entering the kiln, or directly incorporated into the clinker formation process. The lime may be calcium oxide (CaO) or any of the various chemical and physical forms of quicklime, hydrated lime, or hydraulic lime. Dry scrubbing is another term for the addition of dry CaO and this has already been implemented to a degree at Lehigh. Two raw mills are situated immediately prior to final mixing of the raw materials and test results show a decrease in emissions when these are operating due to the increased addition of pulverized limestone into the flue gas. A suspension of hydrated lime in water may be sprayed into the cement kiln flue gas to reduce emissions and is called lime slurry injection (LSI). Lehigh obtained a permit from the District in 2010 to add LSI to their process (injection point at the last stage of the preheater/precalciner) and the system has been installed and used on a trial testing basis. The facility is awaiting county approval before beginning full scale operation. Organic compounds, ammonia and ammonium compounds, HCI, mercury, S02, and to a lesser extent, residual dust can be removed by adsorption by activated carbon. As stated above, activated carbon can be injected into the cement manufacturing process (ACI), or alternatively the kiln gases can be routed to packed beds or filters. In both cases, the saturated carbon is then added to the fuel mix in the kiln. Lehigh applied for a permit from the District to install ACI primarily to reduce emissions of mercury. The installation was completed and ACI was fully operational beginning in May 2011. 13 4.0 Regulatory Proposal Requirements The District is considering adoption of Regulation 9, Rule 13 to achieve the maximum feasible, cost effective emissions reductions of NOx and PM in concert with efforts to bring the Lehigh facility into compliance with limits for TACs consistent with the federal NESHAP. As an existing facility, Lehigh is not subject to the criteria pollutant emissions standards of the amended NSPS. Significant modifications will be required to reduce TAC emissions, including additional controls such as LSI and ACI, as well as enhanced monitoring requirements. The emission limits proposed in Regulation 9, Rule 13 represent the maximum feasible NOx and PM controls as applied to an existing unmodified source. The equipment modifications necessary to meet the proposed NOx emission limit may result in some excess ammonia emissions. Ammonia is a TAC and a precursor to secondarrf particulate matter formation; for this reason an ammonia emission limit is included in the proposed rule. Additional requirements of the proposed rule address concerns over the present configuration of the emission point from the kiln, and the need for enforceable fugitive dust control and mitigation measures. The proposed effective date of September 9, 2013 corresponds with that of the 2010 amended NESHAP and NSPS. Criteria Pollutant Emissions Limits Pursuant to the authority granted by Health & Safety Code Section 40001 to adopt rules to achieve state and federal ambient air standards, the District proposes the following emission limits for Portland cement manufacturing kilns: ➢ 2.3 pounds NOx per ton of clinker produced averaged over 30 days ➢ 0.04 pounds PM per ton of clinker produced averaged over 3 source test runs ➢ 10 ppmv ammonia above baseline, dry at 7% oxygen averaged over 24 hours. Where possible, limits and averaging times are- expressed so as to maintain consistency with federal standards and represent the most stringent limits that Lehigh can achieve for these pollutants in a cost-effective manner. Staff has evaluated the controls required by the federal standards and has proposed these standards based on reasonably achievable emission rates for this facility. These emission limits will require the use of a continuous emission monitoring system (CEMS) or parametric monitors, as well as a means of monitoring and recording the production rates. CEMS, parametric monitors, and production monitoring requirements are detailed in the monitoring and records section of the rule. There is currently no commercially available CEMS for PM, and since the compliance date for the Federal rules has be delayed until 2015, there is no longer a reasonable expectation that this parametric monitoring equipment will become available by September 9, 2013. District staff has proposed a standard that relies on 14 source testing to determine compliance for PM. In order to ensure the operational integrity of the PM control equipment, the rule specifies parametric monitoring that may take the form of PM CEMS when they become available, or bag leak detection systems in the interim. Lehigh has already installed a parametric monitor to measure ammonia and is currently calibrating and testing this equipment for quality assurance of the measurements. All CEMS and parametric monitors are required to comply with the provisions of the District Manual of Procedures, federal requirements, and to maintain records as provided in District Regulation 1. An initial demonstration of compliance with these emission limits must be performed within 90 operating days of the effective date of the rule and repeated annually thereafter. TAC Emissions Limits Pursuant to the authority granted by Health & Safety Code Section 39659 to regulate TACs, the following emission limits are proposed: ➢ 0.2 nanograms Dioxins/Furans (TEQ) per standard cubic meter, dry at 7% oxygen averaged over 24 hours ➢ 55 pounds Mercury per million tons of clinker produced averaged over 30 days ➢ 3 ppmv HCI, dry at 7% oxygen averaged over 30 days ➢ 24 ppmv Total Hydrocarbons (THC), dry at 7% oxygen averaged over 30 days, or alternatively, 12 ppmv Total Organic HAP, dry at 7% oxygen averaged over 30 days. The proposed emissions limits are consistent with the revised 2012 NESHAP standards but with compliance deadlines consistent with that of the previous 2010 NESHAP, September 9, 2013. These proposed standards will provide protection to nearby communities should the federal rules be further delayed or overturned either through legislative efforts or pending litigation. Lehigh has already installed control equipment (LSI and ACI) and monitoring equipment (CEMS and parametric monitors) in order to meet the compliance date of the federal rules. Opacity Standard and Dust Control District staff proposes an opacity limit of 10 percent opacity lasting for no more than three minutes in any one hour period from any emission point or miscellaneous operation. Compliance with this standard will be facilitated through the following dust mitigation control measures: ➢ Mitigation measures to minimize fugitive dust emissions from disturbed soil, open areas and unpaved roads 15 ➢ Surface stabilization methods for material storage piles and dust suppression methods for material transfer processes, material handling equipment, housekeeping, and material cleanup ➢ Track-out prevention and control provisions to minimize dust emissions from paved roads ➢ Vehicle traffic speed limits ➢ Provisions to minimize emissions from material transfer and blasting at rock quarries ➢ Personnel training procedures. These fugitive dust mitigation measures were derived from the Fugitive Dust Control Plan (FDCP)that Lehigh developed in cooperation with the District, as part of Lehigh's recent Title V permit renewal. To provide clarity and improve enforceability, additional definitions and test methods were derived from the California Air Resources Board Asbestos Airborne Toxic Control Measure for Construction, Grading, Quanying, and Surface Mining Operations. Emission Point Requirements District staff has proposed that emissions from the kiln be monitored continuously, and enter the atmosphere from a point, or points, that have been demonstrated to not cause an unacceptable health risk to the community surrounding the facility. Lehigh anticipates making several modifications to the facility necessary for compliance with NESHAP provisions. The proposed regulation will require anyone operating a Portland cement manufacturing facility to demonstrate that emissions from the kiln, when combined with other facility emissions and operating at maximum permitted throughput, will not trigger the notification requirements of the Air Toxics "Hot Spots" Information and Assessment Act as codified in California Health and Safety Code Section 44300 et.al. As part of the Air Toxics Hot Spots (ATHS) program, the District required Lehigh to prepare a comprehensive Health Risk Assessment (HRA) based on recently updated California Office of Environmental Health Hazard Assessment (OEHHA) guidelines. After District staff noted several discrepancies and./or errors and requested revisions to the HRA submitted by Lehigh in September 2010, a revised HRA was submitted in March 2011. The HRA included several emissions scenarios covering operation before and after implementation of the sorbent (lime and activated carbon) injection systems, as well as a projected future 2013 scenario considering additional risk reduction measures necessary to comply with NESHAP requirements (e.g. a modified kiln dust collector with higher single exhaust stack, and more stringent emissions standards for toxic air contaminants) and based on maximum permitted capacity (1.6 million tons of clinker). The HRA indicated that health risk levels associated with operation of the facility are below the significance thresholds which would trigger public notification under provisions of the ATHS program. District staff found the HRA to be completed in accordance 16 with ATHS program guidelines and OEHHA staff reviewed the HRA document and provided comments,but did not note any significant issues. After initially proposing a single 300 foot stack for their kiln, Lehigh has requested greater flexibility to accommodate other potential stack locations, configurations, and number of emissions points. Structural constraints, dynamic back pressure on the plume, as well as aesthetics and compliance with local building codes place constraints on the actual height of the stack. The number of emissions points is constrained by the continuous monitoring requirement on all emission points, due to the costs associated with installing and operating monitoring equipment. The proposed regulation is written to accommodate these alternatives while ensuring that the reductions in health risk to the surrounding community is maintained. Sulfur Dioxide On June 2, 2010, EPA established a new one-hour SO2 ambient air quality standard which became effective on August 23, 2010. The new national standard, 0.075 ppmv, is considerably more stringent than the existing California ambient air quality standard, 0.25 ppmv. District staff is examining whether existing sources of S02, including Lehigh, have emissions sufficient to result in SO2 concentrations above the new ambient standard. Based on preliminary dispersion modeling according to EPA specified methodology, Lehigh's SO2 emissions may result in modeled concentrations above the standard; however, monitoring data for several other facilities indicate that modeling may significantly over-estimate ambient concentrations. This is likely due to the complex terrain surrounding the Lehigh facility, which is not adequately accommodated by the AERMOD model. In such instances, the model greatly over-predicts the likely downwind concentration (between 5 and 10 times the monitored data for complex terrain versus twice the monitored data for flat terrain). District staff is evaluating the potential of other models to more closely correlate with existing monitoring and improve the accuracy of the modeled results. Currently Lehigh is limited by permit condition to SO2 emissions of 481 pounds per hour. As mentioned previously, the LSI and ACI systems recently installed at Lehigh will reduce SO2 emissions and the elevated stack will greatly reduce ground level concentrations of this pollutant. No SO2 emissions standard is being proposed in this rule at this time; however, should future modeling or monitoring results indicate the need for SO2 reductions from the facility, an emissions standard will be proposed that ensures that Lehigh does not cause an exceedance of the new standard. The facility is required to operate a CEMS to continuously monitor emissions Of SO2 and provide monthly summary reports as part of its Title V permit. District staff will utilize this data in determining any future SO2 emissions standard. 17 5.0 Emissions Reductions Emissions to the atmosphere from the manufacture of cement primarily come from combustion of fuel to heat the kiln, with additional point source particulate emissions from the kiln, grinding and mixing operations, and fugitive particulate emissions from transport of materials. Choice of fuel can impact combustion emissions, whether it is natural gas, coal, petroleum coke, or tires. Currently no cement kiln in the US is fired by natural gas due to substantially higher cost and availability concerns. For other source categories, natural gas presents a cleaner burning fuel option; however, cement kilns have dramatically higher NOx emissions when fired by natural gas as opposed to coal or petroleum coke. Lehigh currently uses 100% petroleum coke, having switched from a mixture of coal and petroleum coke in 2007. Generally, emissions of concern from cement manufacture are the criteria pollutants (NOx, PM, S02, and precursor organic compounds) and toxic air contaminants (TACs) from combustion. TACs include benzene, hydrochloric acid, dioxins and furans, as well as trace metals such as mercury, cadmium, arsenic, nickel, chromium, and manganese. In addition, cement kilns generate large amounts of greenhouse gases,primarily carbon dioxide(CO;>). Emissions Inventory Table 3 shows the average daily emissions From the cement kiln at Lehigh according to BAAQMD records for 2010. These values are determined by emission factors assigned by District permit engineers, stack testing, mass balance estimates, and the annual throughput of fuel used and clinker produced as reported by the facility. Lehigh reported that they produced 847 thousand tons of clinker in 2010, a little over half the permitted amount of 1.6 million tons per year. Table 3—Lehigh Southwest Cement Company Kiln Emissions (2010) Pollutant Average emissions in pounds Average emissions in per day pounds per ton of clinker Particulate Matter(PM) 32.62 1.40E-02 Precursor Organics (POC) 59.2 2.55E-02 Oxides of Nitrogen(NOx) 9,:?90 4.00E+00 Sulfur Dioxide(S02) 2,665 1.15E+00 Carbon Monoxide (CO) 5,435 2.34E+00 Benzene 16.1 6.84E-03 Hydrochloric Acid (HCL) 1.79 7.63E-02 Mercury 0.72 3.05E-04 Total Equivalent CO2 4.08E+06 1.76E+03* *NOTE. Total equivalent CO2 value calculated based on 2008 inventory scaled by the ratio of reported clinker produced for 2010 and 2008. 18 Emissions Reductions The proposed rule would limit emissions of NOx to 2.3 pounds per ton of clinker produced. This translates to a reduction in NOx emissions from the kiln of 2 tons per day or a 42% reduction over current levels. Lehigh is subject to the NESHAP emission limits and has already taken steps to meet these limits through application of the LSI and ACI systems detailed in the Technical Review section of this report. Operation of this equipment will have a side-benefit of reducing emissions of S02 over previous levels, although it would be difficult to estimate the exact reduction in S02 emissions. Reductions in particulate matter emissions are more difficult to quantify than the NOx reductions. The Lehigh kiln currently emits at a rate only slightly above the proposed standard for PM which is consistent with the 2010 NESHAP standard for existing sources. Compliance with the fugitive dust control and mitigation provisions of the rule will also help to ensure the continued minimization of fugitive dust emissions. The proposed limit for NOx will decrease the potential for secondary particulate formation, and the proposed standard for ammonia emissions will limit potential secondary particulate formed by increased ammonia emissions resulting from NOx control. As part of the 2010 Clean Air Plan, District staff developed a multi-pollutant evaluation method (MPEM) to evaluate the benefits of the proposed control measures contained in the plan. The MPEM can be used to calculate the reductions in PM2.5 from its precursors, NOx, S02, and ammonia, based on air quality modeling. The emissions reduction of NOx combined with the proposed ammonia emission standard would be equivalent to a PM2.5 emission reduction of 8.7 tons per year. This number would be slightly increased by the side-benefit reduction in S02 emissions mentioned previously. Emissions from the kiln and the expected reduction resulting from the proposed rule are provided in Table 4: Table 4—Lehigh Kiln Emissions and Emissions Reductions from proposed Reg. 9-13 Pollutant Average emissions in pounds Average emissions reduction per day(2010) in pounds per day Oxides of Nitrogen (NOx) 9,290 3,900 Particulate Matter(PM) 32.62 3.3* Precursor Organics (POC) 59.2 54 Benzene 16.1 14.5 Hydrochloric Acid (HCL) 179 125 Mercury 0.72 0.67 *NOTE:Does not include reductions of secondary PM or fugitive dust from miscellaneous sources. 19 6.0 Economic Impacts Cost of Controls Lehigh is undergoing major modifications at their facility to meet the federally-imposed NESHAP requirements. Regulation 9, Rule 13 is being proposed at this time to integrate controls to reduce NOx into Lehigh's planning process, as well as provide a backstop in the event that amendments to the NESHAP are delayed or rescinded. Some of the cost impacts are a result of the EPA mandates and some are the result of the District proposal. Costs attributable to federal compliance include capital and operational costs for TAC control and monitoring equipment, as well as costs for maintenance and reporting of that equipment. Costs associated with the proposed District rule include capital and operational costs for NOx control equipment, stack modifications, and possibly operation and maintenance costs for TAC control and monitoring if the NESHAP compliance deadline is delayed two years. EPA evaluated the cost impacts of the final amendments to the NESHAP and NSPS in documents issued at the same time as those final rules. The costs are nationwide estimates, based on 140 existing and 16 new kilns, and actual costs may vary at individual facilities. Lehigh has provided estimates of costs anticipated for modifications necessary to comply with both the NESHAP and the proposed District rule. Staff verified these estimates through comparison to EPA studies and other sources of information on the Portland cement industry. In order to meet the emission limits and monitoring provisions of the NESHAP, Lehigh will need to install control equipment as well as CEMS or parametric monitors for each emission point from the kiln and clinker cooler. The ba.ghouses at Lehigh are compartmentalized and have multiple emission points, so Lehigh representatives have told District staff they plan to manifold these to reduce the number of individual monitoring points. This will allow consolidation of monitoring equipment that would be required at each emission point, saving the cost of multiple monitors. Capital costs for modifications to the kiln mill dust collector(KMDC) and clinker cooler dust collector are $28.5 million. In addition Lehigh anticipates it will need to modify the clinker withdraw building at a cost of$1 million. Lehigh has installed a hydrated lime injection system (LSI) as well as activated carbon injection (ACI) in order to meet the NESHAP emission limits; these cost $700 thousand and $735 thousand respectively. Continuous monitoring equipment for THC, HG, mercury, and PM are estimated to cost $1.5 million to install. Total capital expenditure for equipment necessary to comply with the federal NESHAP is then $32.4 million. There are costs associated with the operation of this equipment including power generation, delivery and handling of the activated carbon and hydrated lime, and operation, maintenance and reporting for monitoring equipment. Some of these costs are dependent on the cement production rate at the facility. ACI operation will cost $1.10 per ton of clinker produced or $1.2 million per year based on average production over the last 10 years of operation ($1.7 million at maximum permitted capacity). LSI operation will cost slightly higher per ton of clinker at $1.26 million per year based on the same 10 year average ($1.8 million at max capacity). Operation, 21) maintenance and reporting costs for the CEMs are estimated at $360 thousand per year. Total operating costs for compliance with the NESHAP are then $2.84 million per year. The total annualized costs for compliance with the NESHAP is found by annualizing the capital expenditures and adding them to the yearly operating costs. The equipment costs capitalized over a 20 year period using a levelized cash flow method come to $5.52 million per year. Adding this to the annual operating cost provided in the previous paragraphs yields total annual costs due to compliance with the NESHAP of$8.36 million. Using the EPA estimates for a similarly sized and configured kiln as exists at Lehigh, NOx control utilizing SNCR would have a capital cost of$2.3 million, and an annual operating cost of $922 thousand. Similar to the adsorbent injection systems for control of TAC's, the SNCR operational costs are dependent on cement production levels. Lehigh has provided an estimated capital cost resulting from the District proposal that is consistent with this estimate. The emissions standard for NOx contained in the NSPS is based on control using SNCR combined with a well-designed preheater/precalciner utilizing staged combustion. The estimated costs of modifying Lehigh's facility to include staged combustion in the preheater/precalciner would be $15-20 million. SCR, while well-established as a means of NOx control for other source categories was not considered by EPA as it is relatively unproven as applied to cement kilns (see the Technical Review section of this report). CEM measurement of NOx emissions is already required by District permit conditions so monitoring costs are not attributed to the proposed rule. Lehigh has provided estimates for the cost to construct a 300 foot stack based on the updated HRA 2013 emissions scenario as well as the draft rule proposed at workshop. The final configuration of the emissions stack may change but this estimated capital cost of$2.5 million remains a reasonable estimate of the costs associated with compliance with the emissions point provisions of the proposed rule. Lehigh will have to provide an HRA demonstration of the final configuration, which may entail some costs, but the impetus for the 300 foot stack came from the updated HRA and ATHS notification provisions. Whatever the final configuration of the emissions stack, an updated HRA would be required as part of the ATHS program. The total annualized costs for compliance with the proposed District rule may be found by annualizing the capital expenditures and adding them to the yearly operating costs. The SNCR equipment costs capitalized over a 20 year period using a levelized cash flow method come to $392 thousand per year. The cost for the modified emissions point capitalized over 20 years by the same method comes to $426 thousand per year. Adding this to the annual operating cost for the SNCR provided above yields total annual costs due to compliance with the proposed rule of $1.74 million. Costs for implementation of the Fugitive Dust Control Measures are considered to be minimal. These provisions are already in place as a condition of Lehigh's Title V permit. The inclusion of these measures as requirements of the proposed rule is meant to codify the FDCP and improve enforceability of the provisions contained therein. 21 Cost Effectiveness The cost effectiveness of a rule is the sum of compliance costs divided by the expected emissions reduction. This analysis will be limited to NOx, since the TAC emissions reductions comprise several compounds of varying toxicity, and the costs are attributable to compliance with requirements of the federal NESHAP. The costs for modification of the emissions stack are included as these may largely be attributable to the proposed regulation, although, as previously mentioned, manifolding of stacks allows Lehigh to consolidate monitoring equipment that would be required at each emission point, saving the cost of multiple monitors. Total annualized costs for compliance with the rule amounts to $1.74 million. The average NOx emissions rate prior to implementation of controls was 4.0 pounds per ton of clinker produced, and the proposed emissions standard is 2.3 pounds per ton of clinker produced. Taking the difference and assuming the same 10 year average of production levels as for the cost analysis above, yields a cost effectiveness (C.E.) of- C.E. _ $1.74 million/ {(4.0-2.3) *(pounds NOx/ton clinker) *(70%) *(1.6 million tons clinker)}. Or: C.E. _ $0.91 / {pounds NOx reduced *(1 ton/2,000 pounds)) _ $1,828 per ton NOx reduced. $1,828 per ton NOx reduced is among the most cost effective NOx rules considered by the District. Incremental Cost Analysis Section 40920.6 of the California Health and Safety Code requires an air district to perform an incremental cost analysis for any proposed Best Available Retrofit Control Technology rule or feasible measure. The air district must: (1) identify one or more control options achieving the emission reduction objectives for the proposed rule, (2) determine the cost effectiveness for each option, and (3) calculate the incremental cost effectiveness for each option. To determine incremental costs, the air district must "calculate the difference in the dollar costs divided by the difference in the emission reduction potentials between each progressively more stringent potential control option as compared to the next less expensive control option." To evaluate the incremental cost effectiveness of compliance with a more stringent option, staff compared the NOx standard of the proposed rule (2.3 lbs NOx/ton of clinker produced) with the NSPS standard (1.5 lbs NOx/ton of clinker produced). Compliance with the NSPS NOx standard would require redesign and construction of the preheater/precalciner. These costs were provided in the preceding Cost of Controls section ($15-20 million). The annualized capital costs using the same 20 year levelized cash flow method would come to $3.4 million (using the high estimate for reconstruction). Using this increment of increased compliance costs for the rule and inserting the difference between the proposed standard and that of the NSPS into the cost effectiveness equation above yields and incremental cost effectiveness (I.C.E) of- 22'. I.C.E. _ $3.4 million/ {(2.3-1.5) *(pounds NOx/ton clinker) .(70%) _(1.6 million tons clinker)}. Or: I.C.E. _ $3.8 / {pounds NOx reduced *(1 ton/2,000 pounds)) _ $7,573 per ton NOx reduced. Meeting the more stringent NSPS emissions level would come at a cost of more than four times the cost of meeting the proposed standard in terms of dollars per ton of additional NOx reduced. The proposed rule appears to be extremely cost effective, as District rules to reduce NOx typically range between 7 to 20 thousand dollars per ton of NOx reduced; however, the socioeconomic analysis shows that the cost of District and NESHAP controls is a significant economic impact. Socioeconomic Analysis Section 40728.5 of the California Health and Safety Code requires an air district to assess the socioeconomic impacts of the adoption, amendment or repeal of a rule if the rule is one that"will significantly affect air quality or emissions limitations." BAE Urban Economics of Emeryville, California has prepared a socioeconomic analysis of the proposed rule and it is attached to this report as Appendix A.* The analysis concludes that the proposed regulation would have a significant economic impact to the affected industry. BAE Urban Economics found an average profit margin for the Portland cement manufacturing sector of 6.5% of total revenue. The annual profit for Lehigh was estimated to be $6.6 million. Compliance with the rule would result in an 18% reduction in established profit, which is above the California ARB 10% threshold used to determine cost burden. The cost burden for compliance with emissions standards in the federal rules is even higher. If the District were to impose the NSPS limit of 1.5 pounds NOx per ton of clinker, compliance would result in a 30% reduction in profit. As this is three times the ARB threshold, it is easier to see the infeasibility of such a requirement even given the seemingly low incremental cost- effectiveness of this more stringent standard. Compliance with the requirements of the NESHAP already imposes compliance costs representing 43% of Lehigh's annual profit. The Portland cement manufacturing industry may be able to pass these compliance costs on to consumers. An industry's ability to pass through costs is more likely when a product is demand- " NOTE: The Socioeconomic Analysis conducted by BAE Urban Economics uses a straight line depreciation method for calculating costs. This divides total costs by time period considered. Capital costs are annualized over 20 years. For the purposes of calculating cost effectiveness and incremental cost effectiveness, staff used the levelized cash-flow method typical of District regulatory economic analyses. The levelized cash flow method incorporates an interest rate into the capital recovery factor for annualized costs, in this case 5%. 23 inelastic, but in the case of this industry that ability is somewhat unknown. The United States imports about 20% of cement to meet construction needs, so the impact on one facility, or the nation's facilities in the case of the NESHAP, may not be able to be passed through to customers without increasing imports. For Lehigh to reduce the costs of compliance with the proposed District rule to the 10% threshold, the cost of cement would have to increase by 0.72% or 72 cents per ton. The NESHAP costs are 43% of Lehigh's annual profit, and to pass these costs onto consumers, the price of cement would need to increase by $3.18 per ton (3.18%). Combining the costs of compliance with the proposed rule and the NESHAP, Lehigh would need to increase the cost of cement by $4.48 per ton to completely offset the costs of both rules, and by $3.53 to reduce the cost impact to the 10% threshold. As part of the analysis of their amendments to the NESHAP, EPA examined the economic impacts in the report, "Regulatory Impact Analysis: Amendments to the National Emissions Standards for Hazardous Air Pollutants and New Source Performance Standards (NSPS) for the Portland Cement Manufacturing Industry, Final Report" issued August 2010. EPA estimated that compliance with the NESHAP standards could raise the price of cement $4.50 to $5.00 per ton (2005 prices). They further estimated that cement imports could rise by 10% to offset reduction in domestic production and price increases. On June 22, 2012, EPA proposed revisions to the NESHAP as a response to a settlement agreement signed by EPA and the cement manufacturing industry. Among the proposed revisions was that of the effective date from September 9, 2013 to September 10, 2015. As a result, if the federal proposal is finalized without change, the proposed District rule would result in two years costs of compliance and monitoring of the TACs addressed in the NESHAP. After which, all Portland cement facilities in the US would be subject to the same standards. 24 7.0 Environmental Impacts California Environmental Quality Act Pursuant to the California Environmental Quality Act, the District has had an initial study for the proposed rule prepared by Environmental Audit, Inc. of Placentia, California. The initial study concludes that there are no potential significant adverse environmental impacts associated with the proposed rule. A negative declaration is proposed for approval by the District Board of Directors. A copy of the negative declaration and initial study is attached to this report as Appendix B and has been made available for public comment. Greenhouse Gas Emissions In June, 2005, the District's Board of Directors adopted a resolution recognizing the link between global climate change and localized air pollution impacts. Climate change, or global warming, is the process whereby emissions of anthropogenic pollutants, together with other naturally-occurring gases, absorb infrared radiation in the atmosphere, leading to increases in the overall average global temperature. While carbon dioxide (CO2) is the largest contributor to global climate change, methane, halogenated carbon compounds, nitrous oxide, and other species also contribute to climate change. Gases in the atmosphere can contribute to the greenhouse effect both directly and indirectly. Direct effects occur when the gas itself is a greenhouse gas (GHG). While there is relative agreement on how to account for these direct effects of GHG emissions, accounting for indirect effects is more problematic. Indirect effects occur when chemical transformations of the original compound produce other GHGs, when a gas influences the atmospheric lifetimes of methane, and/or when a gas affects atmospheric processes that alter the radiative balance of the earth (e.g., affect cloud formation). Adoption of Regulation 9, Rule 13 will not result in any adverse impact on the emissions of GHGs. The regulation includes an emissions standard for total hydrocarbons that may result in a reduction of methane emissions, although consistent with the NESHAP, the rule contains an alternative standard for total Organic HAP emissions which would exclude methane emissions. Operation of the controls necessary to meet the other emissions standards may result in a minimal increase in energy demand, but is unlikely to increase emissions of GHGs from the kiln itself. 25 8.0 Regulatory Impacts Section 40727.2 of the Health and Safety Code requires an air district, in adopting, amending, or repealing an air district regulation, to identify existing federal and district air pollution control requirements for the equipment or source type affected by the proposed change in air district rules. The air district must then note any difference between these existing requirements and the requirements imposed by the proposed change. As stated in the Background section of this report, there are two federal rules which govern air emissions from the manufacture of Portland cement. The NSPS provides emissions standards for NOx, S02, and PM from new or modified Portland cement kilns and the NESHAP provides emissions standards for TACs from all Portland cement kilns with one set of standards for existing kilns, and one for new or modified kilns. The kiln at Lehigh has not undergone sufficient modification to be deemed new or modified after the effective dates of either rule, so is subject to only the existing source emissions standards contained in the NESHAP. All of these standards for TACs are included in the District's proposed rule. The proposed rule has an effective date of September 9, 2013 which is consistent with the 2010 version of the NESHAP, but this date has been proposed to be delayed two years pending EPA's final decision due in December of 2012. In addition, the proposed federal PM standard has been raised to 0.07 pounds per ton of clinker. The District's proposed 0.04 pounds per ton of clinker standard for PM would be more stringent. The proposed rule contains a NOx standard that is less stringent than that contained in the NSPS, but since the Lehigh facility is not new or modified, this proposed standard is in effect more stringent than what is required by federal rules. Additionally, the proposed rule contains an emissions standard for ammonia, dust mitigation measures, and a HRA demonstration for emissions points. These are not addressed in the federal rules, so these elements may be considered more stringent than federal requirements. There are currently no State rules that specifically regulate cement manufacture, other than greenhouse gas emissions cap and trade (AB 32)., and those rules governing the use of scrap tires as fuel. Several air districts (Antelope Valley, Amador, Kern, Mojave, and Monterey Bay Unified) with cement kilns operating within their jurisdiction have adopted regulations to address emissions of NOx and/or PM from these sources. South Coast Air Quality Management District has adopted several cement manufacturing regulations addressing emissions of NOx, PM, CO, as well as hexavalent chromium and fugitive dust. At least two of these regulations were adopted to address specific conditions at individual cement manufacturing facilities. These regulations are different in format, and include provisions tailored to the facilities in their jurisdiction. Staff believes that the proposed rule is no less stringent than any of the regulations governing cement manufacture from other air district in California, and is more stringent in terms of actual emissions standards for NOx, and TACs. 26 9.0 Rule Development Process The District has developed rule language and provided a basis for its provisions in this staff report. The proposal is based in part on proposed federal regulations and in consideration of existing regulations in other air districts in California, as well as those of other jurisdictions in the United States and Europe. Elements of the proposed rule have been tailored to meet considerations specific to the Lehigh facility. Staff has consulted with officials from Lehigh Southwest Cement Company, Portland cement industry experts, elected local government officials, concerned members of the public and environmental organizations, California Air Resources Board staff, and EPA staff during the preparation of this document. A public workshop was held December 12th, 2011 in the City of Cupertino to provide pertinent background information and present elements of the draft rule provisions. Rule Development staff was supported by staff from Compliance & Enforcement, Communications & Outreach, and Technical Divisions, with exhibits on air monitoring and health risk assessment efforts in the local community. The workshop was attended by members of the public, Cupertino City Councilmembers, staff from Lehigh Southwest Cement Company, representatives of local environmental organizations, and the local press. Verbal comments and questions were addressed at the meeting, and the District received several written comments and continued to accept comments well after the initial comment period ending date. Written comments were provided by members of the public, Bay Area for Clean Environment, Citizens Against Pollution, QuarryNo, San Francisco Baykeeper, the Loma Prieta Chapter of the Sierra Club, West Valley Citizens Air Watch, and Lehigh Hansen, Inc., the parent company of Lehigh Southwest Cement Company, LLC. Issues raised and staffs proposed resolutions are discussed below. Proposed Standards versus Federal Standards Several comments requested that emissions standards in the rule be as stringent as those applied to "new or modified" sources under the NSPS and NESHAP regulations. Some proposed that Lehigh should be considered a "new or modified" facility due to facility modifications dating back decades (but after the initial promulgation of the NSPS in 1971), more recent changes in fuel use and emissions control methods installed in anticipation of the proposed NESHAP, or due to modifications of their Title V permit. Others suggested that Lehigh be subject to "new or modified" standards due to its proximity to a large, urbanized population. Additionally, some commenters requested inclusion of an SO2 emissions standard in the rule. Lehigh requested that the proposed rule mirror the EPA's final NESHAP rule, as they contended that any differences between the District and federal rules would pose a competitive disadvantage to the Lehigh Southwest Cement Company as compared with facilities operating outside of the District. Since their initial adoption, the NSPS (1971) and NESHAP (1999) have undergone several amendments with standards generally becoming more stringent at each revision. Dates are provided with each amendment to indicate the applicable sets of standards for facilities modified or commencing operation before or after said date. The pertinent dates for the most recent 27 amendments to the federal rules are June 16th, x!008 for the NSPS, and May 6th, 2009 for the NESHAP. In the code of federal regulations (40 C.F.R. Section 60.14(a)), "Modification" is defined as "any physical or operational change to an existing facility which results in an increase in the emission rate to the atmosphere of any pollutant to which a standard applies...Upon modification, an existing facility shall become an affected facility for each pollutant to which a standard applies and for which there is an increase in the emission rate to the atmosphere." The code goes on to exclude from consideration routine maintenance, repair, and replacement. Also excluded are increases in production rate or emissions increases that do not involve a capital expenditure in excess of 50% of the fixed capital costs required to construct an entirely new comparable facility. Furthermore, modifications to permit conditions that do not result in an increase in emissions do not trigger new or modified standards. Neither do modifications undertaken to bring a facility into compliance with newly adopted regulations. The District does not have information establishing that Lehigh has undertaken any changes in operation or equipment after the effective dates that could be deemed as "modifications" per the definitions contained in the appropriate sections of the code of federal regulations. The standards contained in the proposed District regulation represent reasonably achievable cost- effective emission standards for the facility, and in fact represent more stringent standards than the applicable federal rules since as an existing facility Lehigh is not subject to the amended NSPS or NESHAP standards for"new or modified" facilities. Some commenters suggested that these federal standards have been proven to be feasible and cost effective by the EPA for all cement manufacturing facilities. However, if this were the case, the more stringent standards would be applied all kilns, including those at existing facilities, rather than only for those at "new or modified" facilities. As stated earlier in this report, the issue of attainment of the recently revised national one-hour ambient air quality standard for SO2 is currently in flux and as yet undetermined. Should the District determine a need for SO2 reductions fronn the facility, staff may propose that the rule be amended to include a standard that ensures emissions from the Lehigh facility do not cause an exceedance of the new one-hour ambient air quality standard for S02. The District has authority under California law to adopt emission limits more stringent than those required under federal regulations; however, any emission standard adopted by the District must be evaluated for cost-effectiveness and socio-economic impact. These analyses are part of this report, and staff believes that the proposed rule balances costs with necessary emissions reductions. The proposed regulation contains e-missions standards that are as stringent as or more stringent than the applicable standards contained in the federal rules. Emissions Monitoring Several members of the public expressed concerns over emissions monitoring equipment, methodology, and averaging methods, with some commenters requesting that emissions monitoring data be made more readily available to the public. Some suggested that emissions be posted on the internet in real time similar to that provided by weather monitoring stations (and 28 District ambient air measurements) and others felt that the community at large could provide a resource to analyze the raw data on the District's behalf. Some commenters questioned the use of rolling averages, the distinctions between parametric monitors and continuous emissions monitors, and whether all 32 stacks of the existing kiln dust collection system would be monitored. The District is committed to accurate measurement of emissions from all regulated sources and to providing emissions monitoring data to the public to the extent feasible. Obtaining CEM data from an active cement kiln is far more complex than ambient monitoring, and measurements need to be verified for accuracy before they can be made available to the public. Furthermore, emissions standards are tied to the production rate, and averaged over a 30 day period, so providing emissions data at or near real time would do little to enable the public to determine compliance of the facility. Nevertheless, CEM data reported to the District is currently available for public review, through Public Records Requests by calling (415) 749-4761, or by visiting: http://www.baagmd_gov/Divisions/Legal/Public-Records-Request.aspx. The District is working on developing increased accessibility to CEM data by posting these reports on-line for major facilities, but believes a District-wide approach to this effort to be more appropriate than one specific to a single facility. The District currently provides real time on-line access to data from its ambient air monitoring network including the station located in Monta Vista Park in Cupertino, one mile east of the Lehigh Facility (see: http://gatel.baagmd.jzov/aqmet/aq.aspx). Unlike CEM data, air monitoring data is a direct measurement of the quality of air typical of what the surrounding population breathes every day. Staff believes that this data is far more useful in making judgments about the health effects of the air in the Cupertino area. The proposed regulation is worded to ensure consistency with federal standards where appropriate. Rolling averages are commonly used with data measured at uniform time intervals to smooth out short-term fluctuations and highlight longer-term trends or cycles. A longer averaging period allows for the standard to be a lower number as compared to a shorter compliance interval and 30-days was chosen by EPA to allow for variations in Portland cement production cycles. District Manual of Procedures Volume V (Continuous Emission Monitoring Policy and Procedures) addresses the requirements which must be met by CEM installations for those persons subject to District Regulations. Volume V currently only addresses measurement of opacity, sulfur dioxide, nitrogen dioxide, oxygen, and carbon dioxide. For this reason, the proposed regulation differs from federal regulations in calling for "parametric monitoring" for continuous monitoring of ammonia, mercury, total hydrocarbons, and hydrochloric acid. Federal test methods and performance specifications are cited for these pollutants rather than District test methods, and in all intents, the parametric monitoring shall consist of a CEM. The CEM equipment for these latter pollutants has only recently become available, at least in their application to cement manufacture, and in the case of PM, is not yet commercially available. As the use of this equipment becomes more commonplace, the District may consider amendments to the Manual of Procedures for their inclusion in Volume V. 29 The proposed regulation requires emissions monitoring of each emission point from the kiln and clinker cooler. Lehigh has indicated that they will be modifying their dust control system to duct all the 32 stacks to either a single elevated stack, or possibly several stacks (though far less than 32). The multiple stacks from the clinker cooler are also expected to be combined together to eliminate the need for multiple banks of CEMS. Nevertheless, the regulation is worded so that continuous emissions monitoring is required on each emissions point regardless of the number. This presents a strong economic incentive to minimize the number of emission points due to the expense of duplicative emissions monitoring equi]?ment. Mercury Emissions Of all the pollutants emitted from the kiln, mercury is of particular concern for many community members surrounding the Lehigh facility, along with local environmental organizations concerned with water quality. Comments pertaining to mercury emissions included requests for an annual cap rather than an emissions standard tied to production levels, and questions regarding the potential for increased mercury levels in nearby waterways, as well as increased mercury content in finished cement resulting from operations of the Kiln Mill Dust Collector (KMDC) recycling and ACI systems. Additionally, one commenter was concerned that increased mercury levels in finished cement could impact do-it-yourself consumers, and another commenter suggested that it could result in elevated mercury emissions from concrete recycling efforts at nearby Stevens Creek Quarry. The health impacts from emissions of mercury E-om Lehigh have been addressed in a recently updated Health Risk Assessment. Lehigh's Title V air permit already contains limits on annual and hourly emissions of mercury for compliance with the Air Toxics Hot Spots Program. The emissions standards in the proposed rule are consistent with the federal NESHAP and ensure efficient operation because emissions levels are tied to the production rate. Compliance with this standard ensures that mercury emissions would bi-, lower than the Title V cap should production be lower than the maximum permitted operating limit. Mercury contamination in San Francisco Bay and other water ways is being addressed by the California Regional Water Quality Control Board and is beyond the scope of this rule making effort. Regarding the potential for increased mercury levels in finished concrete, EPA has authorized KMDC dust shuttle systems at several facilities as a method to reduce mercury emissions and meet pending NESHAP standards. The levels of mercury in the finished cement will be very low, and unlikely to cause a noticeable effect at concrete recycling facilities. Lehigh is responsible for complying with all relevant product warning requirements for the finished product. Dispersion Modeling Some commenters questioned the veracity of the updated HRA, given that the workshop report stated that for the purposes of determining compliance with the federal one-hour SO2 standard, the AERMOD model does not adequately accommodate the complex terrain surrounding the 30 Lehigh Facility. Others questioned the HRA in more general terms based on the emissions inventory, risk factors assigned to various compounds, and possible synergistic interactions for the various toxic compounds. AERMOD is the most validated model that EPA has ever approved for use (17 field study validations); however, for short term concentrations, the model always over-predicts the measured concentration at a monitor. For flat terrain, this is usually within a factor of 2 and for complex terrain it can be 5 to 10 times higher than monitored values. The application of AERMOD to model 1-hour SO2 concentrations is very different from using it to assess the health impacts due to a lifetime exposure. Modeling short term impacts such as the 1-hour SO2 concentration is inherently difficult because of short term turbulent nature of the atmosphere. Comparisons to actual monitoring data are almost always better for long term averages. For an HRA, any over-prediction of actual concentrations actually serves to be health protective, since the calculated health risk is proportional to the modeled concentrations. That is why health risks are always reported as an upper bound on health impact such"no more than 1 case in a million." The District believes that the ATHS program is a health protective risk management program. The HRA is required to be completed in accordance with OEHHA guidelines and these consider the effects of different compounds additively but not synergistically. For more information regarding the District's position on synergistic toxicity, please see the March 29, 2011 letter from Jack Broadbent to Supervisor Liz Kniss found in Appendix C at the end of this report. Alternative Fuels The use of natural gas to fire the cement kiln was suggested as a means of lowering emissions by some commenters, while others expressed their desire to be notified should Lehigh seek to fire the kiln by fuels other than those currently in use according to their permit. Some commenters drew comparisons to natural gas fired power plants in California that have reduced emissions as compared to coal fired power plants in the Eastern United States. As applied to power generation, natural gas does result in more efficient burning and less greenhouse gas emissions; however it results in significantly higher NOx emissions when used to fire cement kilns. SCR is a proven technology for controlling NOx emissions from power generation, but is relatively unproven for cement manufacturing due to the dust entrained in the flue gasses. In order to adequately control the increased NOx emissions, Lehigh would need to use more ammonia in their SNCR system, and this would likely result in greater ammonia emissions which would offset any gains in reducing secondary particulate emissions. Natural gas is also generally much more expensive than either coal or petroleum coke (approximately 10 times the cost per BTU), the costs are much more variable, and delivery in the amounts necessary to fire the kiln would pose economic and logistical burdens inconsistent with any possible emissions reduction likely to be gained from its use. Should Lehigh seek to utilize a new fuel other than what is currently allowed by permit, it would require modification of their Title V operating permit, and this would entail the notification and comment provisions of that program. 31 Opacity Standard Some commenters raised objections to the use of a Ringlemann smoke chart for determining opacity readings as insufficient, and others suggested utilizing a "high quality monitor" in place and use comparisons to the Ringlemann chart as an adjunct. The opacity standard to be met by miscellaneous sources at the facility are stated in both Ringelmann number (for dark plumes) and percent opacity (for white plumes), but these are meant to indicate a set standard to be met, rather than the means of measurement. District staff is trained and certified to read opacity using the Ringelmann chart, and these readings are more appropriate for the many sources, such as mining operations, conveyor belts, and roads that do not lend themselves to in-stack monitors. All emission points from the kiln and clinker cooler are required by the proposed rule to be measured by periodic source testing. This is consistent with Federal rules that exempt kilns and clinker coolers from opacity standards since particulate matter is more accurately monitored by direct measurement. Both the kiln and clinker cooler are still subject to a 20% opacity limit as per District Regulation 6, Rule 1. Compliance Dates and Penalties Some commenters were concerned that the source testing provisions of the proposed rule allow for up to 30 operating days before an initial demonstration of compliance must be performed. Other commenters asked for interim deadlines for the installation of specific control equipment as a means of ensuring progress toward meeting the standards. Several others requested that the rule contain punitive measures for noncompliance along with other provisions of the proposed rule. Compliance with the emissions standards begins on the effective date specified in the rule. This will be predominately determined by emissions monitors that measure emissions continuously. The source testing requirement is a duplicative verification of compliance. In either case, if the results show noncompliance with the standards, the violation begins on the date of effectiveness, not one month after. The standards are stated as a monthly average to be consistent with federal rules, so compliance with the standard cannot be made until 30 days have elapsed. EPA staff has indicated that this is consistent with their views regarding initial determination of compliance. District staff believes that interim deadlines are unnecessary, and compliance with the standards on the effective date is required regardless of the means of control to meet those standards. The control equipment for toxic emissions has already been installed. Modifications to the stack, and installation of NOx control equipment has not yet begun, but Lehigh must comply with the proposed rule on the effective date or be subject: to enforcement action. Noncompliance with any District rule is subject to enforcement procedures that may include punitive measures. There is no need to add provisions to the proposed rule i:or additional punitive measures. It is the view of District staff that adoption of this rule furthers enforcement powers. 32 Workshop Comment Process Some commenters expressed concerns regarding the comment process itself with calls for an extension of the comment period deadline, and requests for point by point responses posted on- line. The timing of the workshop in early December may have contributed to these concerns, as some pointed to the holidays as a basis for requests to extend the comment period. Some commenters may have been frustrated due to the extended review period for comments related to Lehigh's Title V permit renewal. The District has continued to accept comments well after the stated January 3, 2012 comment period deadline, and made this known to all parties requesting extensions. All comments have been considered and responses are provided in this document. Responses to Title V comments were posted on the District website February 16, 2012, along with all other documents provided to EPA for their review. Miscellaneous Comments The district received several comments related to issues beyond the scope of this rule making effort. Several commenters brought up the Spare the Air program; either requesting that the facility shut down on Spare the Air days or proposing that emissions from Lehigh were the cause of the increased number Spare the Air days of this last winter. Some commenters requested that truck traffic to and from the facility be included in the measures considered in the proposed rule. Additionally some requested an analysis of the use of urea versus aqueous ammonia for use in the NOx control system. Cement manufacturing is not a process that can be run intermittently. The kiln in which reactions take place is 16 feet in diameter and 250 feet long, and it must be heated to temperatures in excess of 2,500 degrees Fahrenheit. Shutting down the kiln can take up to 24 hours, and start-up can take up to 36 hours to bring the kiln to operating temperatures. District Regulation 4, Air Pollution Episode Plans does require major facilities to prepare plans to curtail operations during advisories, alerts, warnings and emergencies as defined by the regulation; however, the air pollution concentrations at which a facility must follow its curtailment plan are much higher than those generally found in the District even on Spare the Air days. The Spare the Air program was established by the District to educate people about air pollution and to encourage them to change their behavior to improve air quality. This voluntary outreach campaign has been operated for nearly two decades with alerts in summer when ground-level ozone or "smog" becomes a pollution problem and in winter when particulate matter concentrations are expected to be unhealthy. District meteorologists evaluate the air pollution levels and meteorological conditions in order to forecast which days may have unhealthy air quality. Winter Spare the Air alerts are generally called on cold still winter days with stagnant air. With the passage of the District's Wood Smoke rule (Regulation 6, Rule 3) in 2008, Winter Spare the Air includes a mandatory curtailment of wood burning on days forecast to exceed the 24-hour National Ambient Air Quality Standard for PM2.5. At this time, the Spare the Air 33 program provides a means of curtailing sources of particulate emissions that are otherwise not regulated or controlled through District permitting;of prohibitory regulations. Emissions from trucks do not fall within the category of stationary sources and are therefore outside the authority of the District. The California Air Resources Board regulates truck emissions. Truck traffic to and from the facility is beyond the scope of this regulation, but the fugitive dust control measures included in the proposed regulation will help control dust emissions from trucks through on-site speed limits, truck washing, and other track-out minimization provisions. The proposed regulation provides emissions standards but does not specify the control equipment to meet those standards; however the proposed standards do include a limit on ammonia emissions to ensure that NOx control equipment does not result excess secondary particulate formations. Aqueous ammonia is a preferred agent for NOx reduction because urea is hazardous to transport and store. This is addressed in the CEQA analysis. Comments Received at the May 21, 2012 Board Meeting On May 21, 2012, the Board of Directors conducted an informational meeting at the Quinlan Community Center in Cupertino, CA followed by a visit to the periphery of the Lehigh facility. At the meeting, ten members of the public commented. Most comments echoed those previously made. One commenter, Gary Latshaw, Ph.D., provided a written comment, "Citizen's Report on Cement Plant Regulation in the San Francisco Bay Area," describing the health costs and benefits of alternative scenarios based on the District's Multi-Pollutant Evaluation Method (MPEM) described in the 2010 Clean Air Plan. Dr. Latshaw's report took the monetized value of various pollutants and calculated the "health costs" associated with various levels of emissions from Lehigh, including the proposal, the NSPS and a newly permitted plant in Florida. However, the MPEM is not meant to be used to calculate the monetized health effects of emissions from a single source. The monetized values in the MPEM are based on ambient concentrations which accrue from all sources, both natural and anthropogenic, and are applied across the entire region. Staff believe that the proposed limits will reduce emissions and benefit public health, and are the most stringent that are economically feasible. 34 10.0 Conclusion Pursuant to Section 40727 of the California Health and Safety Code, the proposed rule amendments must meet findings of necessity, authority, clarity, consistency, non-duplication, and reference before the Board of Directors adopt, amend, or repeal a rule. The proposed Rule is: • Necessary to protect public health by ensuring reduction in toxic air contaminants to nearby residents and by reducing ozone and PM precursors to meet the commitment of Control Measure SSM-9 of the Bay Area 2010 Clean Air Plan; • Authorized by California Health and Safety Code Sections 40000, 40001, 40702, and 40725 through 40728; • Clear, in that the rule specifically delineates the affected industry, compliance options, and administrative requirements for industry subject to this rule, so that its meaning can be easily understood by the persons directly affected by it; • Consistent with other California air district rules, and not in conflict with state or federal law; • Non-duplicative of other statutes, rules, or regulations; and, • Implementing, interpreting and making specific and the provisions of the California Health and Safety sections 40000 and 40702. A socioeconomic analysis prepared by Bay Area Economics has found that the proposed regulation could have a significant economic impact or cause regional job loss; however, staff believes that the costs are necessary to protect public health and make progress towards attainment of air quality standards and that the proposed rule is cost effective. A California Environmental Quality Act (CEQA) analysis prepared by Environmental Audit, Inc., concludes that the proposed amendments would not result in adverse environmental impacts. District staff have reviewed and accepted this analysis as well. The CEQA document will be available for public comments prior to the public hearing. The proposed Rule has met all legal noticing requirements, has been discussed with the regulated community and other interested parties, and reflects the input and comments of many affected and interested parties. District staff recommends adoption of proposed Regulation 9, Rule 13: Nitrogen Oxides, Particulate Matter, and Toxic Air Contaminants from Portland Cement Manufacturing; and adoption of the CEQA Negative Declaration. 35 11.0 Refewences 1. Bay Area Air Quality Management District;Bay Area 2010 Clean Air Plan, "SSM 9— Cement Kilns", Volume 2, September 15, 2010. 2. Portland Cement Association; Overview of the Cement Industry, Economics of the U.S Cement Industry, December 2009; www.cement.or 3. National Association of Clean Air Agencies, Andrew Ginsburg, and Ursula Kramer Co- Presidents of Board of Directors;NACAA comment on Portland Cement NSPS and attachments; September 30, 2008. 4. Pete Grannis, Commissioner of the New York State Department of Environmental Conservation, "Grannis Hails Clean Air Settlement with Cement Manufacturer", Envirommnet DEC Newsletter; February 2010. 5. BAAQMD Emission Inventory,base year 2009. 6. Lehigh Southwest Cement, Permanente Plant; www.lehighpermanente.com 7. US EPA;National Emission Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing Industry and Standards of Performance for Portland Cement Plants; Federal Register/Vol. 75,No. 174/ September 9, 2010. 8. US EPA;FACT SHEET for Final Amendment:, to National Air Toxics Emission Standards and New Source Performance Standards for Portland Cement Manufacturing; August 9, 2010. 9. Keith Barnett, US EPA;Final Portland Cement MA CT and NSPS Standards Webinar; November 17, 2010. 10. Consultation with Mr. Henrik Wesseling, Plant Manager of Lehigh Southwest Cement Company; July 2010. 11. Zephyr Environmental Corporation; Summary of Control Techniques for Nitrogen Oxide, SN3049, Portland Cement Association; 2008. 12. US EPA, Office of Air Quality Planning and Standards;Alternative Control Techniques Document Update -NOx Emissions from New Cement Kilns, EPA-453/R-07-006; November 2007. 13. European Commission Joint Research Centre, Institute for Prospective Technological Studies, Integrated Pollution Prevention and Control,Draft Reference Document on Best Available Techniques in the Cement, Lime and Magnesium Oxide Manufacturing Industries; May 2009; http://eippcb.irc.ec.europa.eu. 36 14. Al Armendariz, Ph. D; The Costs and Benefits of Selective Catalytic Reduction on Cement Kilns for Multi-Pollutant Control; Department of Environmental and Civil Engineering, Southern Methodist University; February 11, 2008. 15. US EPA; United States Announces Two Major Clean Air Act New Source Review Settlements at 28 Industrial Plants Nationwide; January 21, 2010 16. US EPA; Summary of Environmental and Cost Impacts of Final Amendments to Portland Cement NESHAP(40 CFR Part 63, Subpart LLL); Docket Number EPA-HQ-OAR-2002- 0051; August 6, 2010. 17. US EPA; Summary of Environmental and Cost Impacts of Final Revisions to Portland Cement New Source Performance Standards (40 CFR PART 60, subpart F); Docket Number EPA-HQ-OAR-2007-0877; August 6, 2010. 18. US EPA, Office of Air Quality Planning and Standards;Regulatory Impact Analysis: Amendments to the National Emissions Standards for Hazardous Air Pollutants and New Source Performance Standards (NSPS)for the Portland Cement Manufacturing Industry Final Report; August 2010 19. Consultation with Mr. Henrik Wesseling and Mr. Scott Renfrew of Lehigh Southwest Cement Company, Mr. Timothy Matz of Lehigh Hanson, and Mr. Shane Alesi of Heidelberg Cement Group; October 12, 2010. 20. Bay Area Air Quality Management District;Multi-Pollutant Evaluation Method Technical Document, April 2010. 21. Bay Area Air Quality Management District;BACT/TBACT Handbook, 2002. 22. US EPA;National Emission Standards for Hazardous Air Pollutants for the Portland Cement Manufacturing Industry and Standards of Performance for Portland Cement Plants; 40 CFR Parts 60 and 63[EPA-HQ-OAR-2011-0817; FRL-9629-9] RlN 2060-AQ93; June 25, 2012. 23. US EPA;Proposed Amendments to Air Toxics Standards and New Source Performance Standards for Portland Cement Manufacturing FACT SHEET; June 25, 2012. 24. US EPA, Office of Air Quality Planning and Standards;Fabric Filter Bag Leak Detection Guidance, EPA-454/R-98-015;September 1997 37 Jan 2012-Apr 2013 Emissions: Hg,502, &NOx Chart Area 2000 1800 17.9E -4-(Hgib/10)/Mton Solid Lines are Air District 1600 - -S021b/ton M16 Regulations "—NOx lb/ton 14.91 Dashed Lines are 16.16 14 OD Dr. Staudt's 12.76 Recommendations 1200 1219 _ 11.09 02 1L30 10.17 a� l i l V66 Soo 7.69 600 400 1 4.1D 5 03 3.61 '.' „"'"**"l�lY�o t : 3 00 =x 3.09 2 DO r. +n a...+� �. s 2!• _ ' !!� •l!� 1 . 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