BOARD MEETING DATE: December 4, 2009
AGENDA NO. 37

PROPOSAL:

Amend Rule 1112.1 – Emissions of Particulate Matter and Carbon Monoxide from Cement Kilns 

SYNOPSIS:

The proposed amendment addresses the occasional concentration spikes of CO, an attainment pollutant, resulting from the mandated reduction in NOx emissions from cement kilns. The proposal will provide compliance flexibility by recognizing the environmental benefit of reducing NOx, a precursor to non-attainment pollutants of ozone and particulates, while ensuring the CO emissions do not significantly impact air quality.

COMMITTEE:

Stationary Source, September 25, 2009 and October 16, 2009, Reviewed

RECOMMENDED ACTIONS:

Adopt the attached resolution:

1. Certifying the Final Environmental Assessment (EA) for Proposed Amended Rule 1112.1 – Emissions of Particulate Matter and Carbon Monoxide from Cement Kilns.
   
2. Amending Rule 1112.1 - Emissions of Particulate Matter and Carbon Monoxide from Cement Kilns – to provide for an optional standard for carbon monoxide emissions.

 

Barry R. Wallerstein, D.Env.
Executive Officer

Background

Staff is proposing amendments to Rule 1112.1 – Emissions of Particulate Matter and Carbon Monoxide from Cement Kilns to provide an alternative CO emissions limit for facilities manufacturing grey Portland cement. California Portland Cement Company (CPCC) is the only facility in the SCAQMD that manufactures grey Portland cement and has modified their operations to reduce emissions of NOx. CPCC is a RECLAIM source and subject to mandatory reductions of NOx. There is often an inverse relationship between emissions of NOx and CO and the efforts by CPCC to reduce their NOx emissions has caused occasional spikes in CO concentrations in excess of the current limit applicable to the operation – Rule 407 which caps CO emissions to no more 2,000 ppm (dry, corrected to 3% O2) averaged over 15 minutes.

Control of NOx is a priority for the SCAQMD, as it is a precursor to the non-attainment pollutants ozone, PM10, and PM2.5. By contrast, the Basin is in attainment for CO which historically has been primarily associated with mobile sources. Air quality monitoring shows that the area adjacent to CPCC has some of the lower CO concentrations in the Basin.

CPCC has installed controls to reduce NOx emissions including a scrap tire injection system and a selective non-catalytic reduction system. CPCC has also installed additional controls to reduce CO emissions such as an air injection system.

To recognize the efforts of CPCC in reducing NOx that have resulted in occasional CO spikes, staff is proposing an alternative CO emission level that comports with air quality requirements and ensures the area adjacent to CPCC remains below the health-based ambient standards for CO.

Proposed Amendments

The purpose of the proposed rule amendment is to acknowledge the air quality benefit of reducing NOx emissions by establishing an alternative optional emission limit for cement kilns allowing for the continued reduction of NOx emissions from the kilns while ensuring air quality standards and local ambient air quality are not compromised.

The proposal provides for an alternative to the Rule 407 CO limit of 2,000 ppm (corrected to 3% O₂, dry) averaged over 15 minutes. The optional requirement for CO emissions is not to exceed 1,900 ppm averaged over 8 hours and not to exceed 6,000 ppm averaged over 15 minutes (corrected to 3% O₂, dry). These optional requirements ensure that occasional CO spikes are minimized and the overall CO emissions are reduced.

The amendments also include new requirements for CO monitoring and recordkeeping and incorporate the current test methods for CO and PM. Installation and operation of a certified continuous emissions monitor for CO is now a requirement for the kilns.

AQMP and Legal Mandates

Proposed Amended Rule 1112.1 does not implement a measure in the AQMP; however, the amendments are consistent with AQMP objectives. 

Socioeconomic Analysis

Since CPCC will not be required to implement any operational changes at their Colton facility, the proposed amendment will have no anticipated socio-economic impacts.

California Environmental Quality Act

Pursuant to California Environmental Quality Act (CEQA) Guidelines §15252 and SCAQMD Rule 110, the SCAQMD has prepared an Environmental Assessment (EA) for the adoption of proposed amended Rule 1112.1. The Draft EA concluded that implementation of the proposed project would not result in significant adverse environmental impacts. The Draft EA was released for a 30-day public review and comment period from July 17, 2007 to August 15, 2007. No comments were received relative to the Draft EA. The draft EA has been revised such that it is now a Final EA which is included as an attachment to this Governing Board package. 

Resource Impacts

Proposed Amended Rule 1112.1 requirements can be implemented within the current resources. 

Attachments (EXE, 1.3m)

A. Summary of Proposal

B. Rule Development Process

C. Key Contacts

D. Resolution

E. Proposed Rule Language

F. Staff Report

G. Environmental Assessment