Comment Log Display

GHG 6. Industry
Cement and AB 32 Scoping Comments
West Valley Citizens Air Watch Comments:

a. Reduction of Green House Gases (GHG) need to be linked in
tandem to reductions in toxic air contaminants (TAC) and other
harmful air pollutants. We ask that California Air Resources Board
(CARB) remain clear at all times not to trade off one for the
other. While in many cases, reduction in one category will achieve
reduction in the other, this is not so across the board.

b. Cement plants are major CO2 generators. They emit a double dose
of CO2 into the atmosphere: one huge dose from the high amounts of
predominantly fossil and other fuels they burn to heat the kilns
to approximately 3000º F; and the other huge dose from the Carbon
which is released from heating the limestone. The released carbon
combines with oxygen in the atmosphere producing CO2. 

It is estimated that worldwide around 3-6% of human made CO2
emissions come from this single stationary source -- cement
plants. From the Appendices, page C-104, "total emissions
associated with cement used in the State (in 2006), 40 percent of
which is imported, were estimated to be 15.3 [Million Metric Tons
CO2] MMTCO2E.” 

Cement plants are also the largest source of air emissions of
mercury in the state. "Hanson Permanente Cement in Cupertino. The
plant, which released about 500 pounds of mercury compounds in
2006, is listed in the [Environmental Protection Agency (EPA)]
report the third-worst kiln in the country"
http://www.sfgate.com/cgi-bin/article.cgi?f=/c/a/2008/07/24/BA4511U0D7.DTL&hw=cupertino+cement&sn=001&sc=1000


Both CO2 and the mercury, as well as the other dangerous
emissions, need to be greatly and quickly reduced. This can be
done.

The Hanson Cement plant is owned by Heidelberg Cement which
generated billions of dollars in profit last year. It is way past
time for adequate pollution controls. Cement plants have gotten a
pass on any reasonable amount of pollution controls for scores of
years. 

Meanwhile, the Hanson plant alone emits approximately 1.6 million
metric tons of CO2 into the atmosphere yearly (based on their
permitted production of 1.6 million tons of clinker per year for
cement production)as well as mercury, dioxin, hexavalent chromium,
tons of small particulates and other highly toxic air
contaminants.

c. WVCAW recently learned, despite no public notice by the Bay
Area Air Quality Management District, that the Hanson Cement Plant
had switched from burning mainly coal to petroleum coke in May,
2007. According to CARB’s CO2 chart in the handout entitled, 
"Stationary Combustion Default Emission Factors: Cement Plants in
California Handout for Cement Technical Team Discussion: May 9,
2007," petroleum coke emits even more CO2 than coal (and
apparently more mercury also). Thus the BAAQMD has recently
allowed the Hanson Cement plant to increase its CO2 emissions!

d. Natural Gas: In the short term, many if not most of the cement
plants in California could substitute natural gas for the much
higher CO2 and toxic air contaminant producing fossil fuels such
as coal and petroleum coke.

In a meeting with the BAAQMD and in subsequent written
correspondence, the BAAQMD confirmed to WVCAW that Hanson Cement
is equipped today to switch immediately from using petroleum coke
to natural gas. It already has all the natural gas lines in place
in the kiln and in fact currently uses a small amount of natural
gas. This would greatly reduce in the short term both the CO2
emissions (see CARB CO2 chart) and the toxic air contaminants and
small particulates. 

e. If the cement is later blended with supplementary cementicious
material (SCMs) then there will be no decrease in GHG, only an
increase in the amount of cement produced.  In order for CARB to
decrease GHG releases, it is imperative that cement production not
be allowed to increase (including imports). 

f. Even if the carbon intensity factor (CIF) for cement
decreases overall due to transportation, it will not help if
cement production increases. Increased demand for this type of
product is likely given increases in population estimates for
2020.

"ARB has not quantified these (cement)  exports." (p C-104) 
ARB must quantify exports of California produced cement to
better understand how exported California cement increases
greenhouse gas emissions.  It is counterproductive to export
California produced cement to far away places such as Guam and
then have Asian cement imported to California.  In order "to
minimize leakage" it is crucial that exports of California cement
be quantified and accounted for.
 
http://jgpo-guam-cmtf.blogspot.com/2008/06/port-authority-finalizes-deal-with.html

The Hanson Cement Plant has said that they will import limestone
when they run out at their operation.  Yet there are no other
significant reserves of limestone near Cupertino.  When
calculating the carbon intensity factor, transportation of
limestone must also be included.

g. Fly ash and slag are not produced in California and
emissions from transporting these materials need to be
quantified.  Fly ash is a product of coal combustion.  Coal
combustion should not be promoted if we want to decrease
greenhouse gas (GHG) emissions. It should begin to be decreased.
http://www.redorbit.com/news/science/1086106/utility_fined_over_fly_ash_constellation_energy_arundel_dump_owner/index.html

Fly ash is also highly toxic. It has high concentrations of heavy
metals. Also see below.

h. Solutions and Alternatives. It is therefore imperative that
CARB fund the study of alternative processes for producing cement
and alternative materials to substitute for concrete. 

	1) Alternative Process: Many of us have walked or driven on two
millennia old Roman Roads in Europe. How was the cement & concrete
produced that made these roads and buildings that still exist two
thousand years later? Think Mt. Vesuvius. Think volcanic ash. The
volcano heated the ash to thousands of degrees just as the cement
kilns do to limestone today. 

The Romans used this ready made volcanic clinker to make cement
which they then made into their concrete. Instead of having to
blast into the Earth with huge mining operations  for limestone,
it appears the Romans used the ready made volcanic clinker --
known today as volcanic pozzolans.

The Western Climate Initiative (WCI) is a perfect place to partner
on this. Remember Mt. St. Helens in Washington State? There is a
gigantic mountain of volcanic pozzolans just waiting to be tested
to be used as clinker to make cement! No burning necessary. No
fossil fuel necessary. The clinker is already heated and burned by
Mt. St. Helens and ready to be ground into the appropriate size for
clinker.

True, there would be transportation costs -- but that would pale
in comparison to the 20 tons per hour! of petroleum coke (which is
also transported) now used by Hanson cement to heat up the kiln to
produce limestone clinker 24 hours a day, 7 days a week and --
except for 2 or 3 weeks down time -- all year round. 

On the other hand, the use of volcanic pozzolans instead means no
CO2 production through elimination of the need to heat limestone
to high temperatures; thus eliminating air toxins and CO2 and
other GHG emissions. 

According to the article cited below, it appears that volcanic
silica could be used instead of fly ash. We certainly do not want
to burn coal in order to get fly ash after all.

A better understanding of "Roman concrete" might help
significantly reduce GHG emissions by perhaps completely
eliminating the need to heat up kilns. We urge you to read this
paper which also discusses recent applications:  

http://www.romanconcrete.com/docs/spillway/spillway.htm

It appears that volcanic ash as clinker might be all that is
needed as the major component to produce cement in a new (and
perhaps also ancient) process eliminating the huge amounts of
energy to produce heated limestone clinker and eliminating the
huge amounts of CO2 and toxic air contaminants!

Right there approximately 15 MMT of CO2 in California and 3-6% of
worldwide CO2 production would be reduced in one fell swoop along
with the horrible consequences of asthma, cancer, and other
diseases caused by the current methods of cement production.

	2) Alternative materials: Just to mention a couple. There is a
multimillion dollar mansion just north of silicon valley built of
straw bale. This is upscale recycling. It is easy to build with,
highly insulating, safe, sound and dry when covered with plaster
and of course roofing and stabilized with rebar or other methods
and esthetically pleasing -- impossible to tell it is made with
straw bale. This can also be seen at Real Goods in Hopland, CA,
and many other locations in CA.

There is also an upsurge in building with cob. Actually a
traditional method of building in Europe where there are centuries
old multiple storied buildings still occupied in Germany, for
example. Again, one would not know what material they were made of
unless told. Examples of both straw bale and cob buildings can be
seen at Hidden Villa Ranch in Los Altos, CA, which is open to the
public for tours.

Concrete is used in many applications where its structural value
is not needed, for example in non-weight bearing fencing. Other
materials much less CO2 and polluting intensive can and should be
used. Building codes should not allow concrete made from kilns to
be used for such non-weight bearing uses.

i. West Valley Citizens Air Watch asks to be included as a
Stakeholder for purposes of AB 32 regulation development and
related regulations and issues. We ask to be included in any
meetings, discussions, rule making and regulation development
regarding cement kilns, cement production, uses of concrete and
alternatives to limestone clinker, cement, and concrete.