MOJAVE DESERT AIR QUALITY MANAGEMENT DISTRICT

RULE 1161
Portland Cement Kilns

(Adopted: 06/28/95 )

(A) General

  1. Purpose:
    1. The purpose of this Rule is to limit emissions of oxides of nitrogen (NOx) resulting from the operation of existing Portland cement kilns.
  2. Applicability:
    1. The provisions of this Rule shall apply to all existing Portland cement kilns operated within the Federal Ozone Non-Attainment Area of the Mojave Desert Air Quality Management District.
  3. Applicability of Other District Rules:
    1. Compliance with this Rule does not exempt a person from complying with any other applicable State, federal or local law, statute, code, ordinance, rule or regulation.

(B) Definitions
For the purposes of this Rule, the following definitions shall apply:

  1. "Aggregate Emissions Limit" - A facility-wide sum of NOx emission limits (expressed in lbs/ton of clinker) from all of a facility's Portland cement kilns.

  2. "Baseline Emission Rate" - Emissions under normal operating conditions, prior to control, determined by an emissions compliance test conducted in accordance with the requirements specified in Section (H).

  3. "Clinker" - The product of a cement kiln from which finished cement is manufactured by milling and grinding.

  4. "Combustion Control(s)" - A process, equipment or device used to achieve changes in the combustion process that results in a reduction of oxides of nitrogen emissions; emphasis is on reducing the formation of NOx.

  5. "Continuous Emissions Monitoring System (CEMS)" - The total equipment necessary for the continuous determination and recordkeeping of process gas NOx concentrations and NOx emission rates. Such equipment shall comply with the requirements set forth in Section (F)(1).

  6. "Emissions" - The quantitative rate of releases of air contaminants to the atmosphere from an emission point, as measured by the Continuous Emission Monitoring System, source tests, or as calculated by the methods specified in an applicable rule, regulation or Permit to Operate.

  7. "Facility" - Any permit unit or grouping of permit units or other air emission activities which are located on one or more contiguous properties within the District, in actual physical contact, or separated solely by a public roadway or other public right of way, and which are owned or operated by the same person (or by persons under common control).

  8. "Federal Ozone Non-Attainment Area" - That portion of San Bernardino County that lies within the lines which begin at:
    1. the San Bernardino/Riverside County boundary, running north along the range line common to Range 3 East and Range 2 East;
    2. then west along the township line common to Township 2 North and Township 3 North;
    3. then north along the San Bernardino/Los Angeles County boundary and the San Bernardino/Kern County Boundary;
    4. then east along latitude 35 degrees, 10 minutes north;
    5. then south along longitude 115 degrees, 45 minutes west and westward along the San Bernardino/Riverside County Boundary (see Map 1).
  9. "Heat Input" - The chemical heat released due to fuel combustion in a permit unit, using the higher heating value of the fuel. Does not include the sensible heat of incoming combustion air.

  10. "Higher Heating Value" - The total heat liberated per mass of fuel burned (Btu per pound), when fuel and dry air at standard conditions undergo complete combustion and all resultant products are brought to standard conditions.

  11. "Maximum Rated Capacity" - The maximum design heat input of a unit at the highest heating value of the fuel used.

  12. "Oxides of Nitrogen (NOx)" - The sum of the molecular forms of nitrogen oxide and nitrogen dioxide. When measured or calculated, the total of the two molecular forms is collectively expressed as nitrogen dioxide (NO2).

  13. "Parts per Million (by Volume)" (ppmv) - The number of gas molecules of a given species, or group, in one million total gas molecules.

  14. "Permit Unit" - Any Portland cement kiln required to have a Permit to Operate pursuant to District Rule 203.

  15. "Portland Cement" - A hydraulic cement produced by pulverizing clinker consisting essentially of hydraulic calcium silicates, usually containing one or more of the forms of calcium sulfate as an interground addition.

  16. "Portland Cement Kiln" (Kiln) - A system, including any solid, gaseous or liquid fuel combustion equipment, used to calcine and fuse raw materials, including limestone and clay, to produce Portland cement clinker. For the purposes of this Rule, three types of Portland cement kilns are described:
    1. "Preheater-Precalciner Kiln" - A high-production, large diameter, short kiln where much of the feed to the kiln system is preheated in cyclone chambers prior to the final fusion which constitutes the formation of clinker.
    2. "Long Dry Kiln" - A kiln 14' or larger in diameter, 400' or greater in length, which employs no preheating of the dry feed.
    3. "Short Dry Kiln" - A kiln less than 14' in diameter, less than 400' in length, which employs no preheating of the dry feed.
  17. "Reasonably Available Control Technology" (RACT) - The lowest emission limitation that a particular source is capable of meeting by the application of control technology that is reasonably available, considering technological and economic feasibility. RACT for this source category may consist of a process change and/or equipment modification.

  18. "Start-up" - Period of time after non-production of clinker during which a cement kiln is heated to operating temperature from a lower temperature and feed rate is increased to normal production level.

  19. "Shut-down" - Period of time cement kiln is allowed to cool from operating temperature to a lower temperature in preparation for a period of non-production of clinker.

  20. "Waste Heat" - Excess heat generated as a result of a combustion process within a kiln.

(C) Requirements

  1. NOx Reduction Technologies
    1. Each owner or operator of a kiln subject to this Rule shall operate such equipment with NOx RACT. RACT shall be specific to the type of kiln being operated, and can include - but is not limited to - any one, or a combination of, the following:
      1. Combustion Controls
      2. Low NOx burners
      3. Staged combustion
      4. NOx-reducing fuels or substances (includes tire-derived fuels).
  2. NOx RACT Emission Limits
    1. Any owner or operator of a kiln subject to this Rule shall not exceed the following NOx emission limits, calculated pursuant to Section (E)(1)(b):
      1. For Preheater-Precalciner Kilns: 6.4 lbs/ton of clinker produced when averaged over any 30 consecutive day period;
      2. For Long Dry Kilns: 6.4 lbs/ton of clinker produced when averaged over any 30 consecutive day period;
      3. For Short Dry Kilns: 7.2 lbs/ton of clinker produced when averaged over any 30 consecutive day period.
    2. For kiln systems which recover waste heat and convert it into electricity, the NOx emission limit shall be adjusted using the following equation:



(D) Alternative Compliance Strategy

  1. As an alternative to complying with the limits specified in Section (C)(2) on a permit unit basis, the owner or operator of a kiln subject to this Rule may be allowed to aggregate NOx emissions from all cement kilns at a single facility, subject to the following conditions:
    1. The owner or operator must request, in writing, to aggregate emissions pursuant to the compliance schedule set forth in Section (I).
    2. Aggregating of emissions must be approved in writing by the District.
    3. Aggregating of emissions shall be allowed only between kiln types with the same emission limits, as set forth in Section (C)(2)(a).
    4. The aggregated emissions limit for NOx shall be less than or equal to the sum of the total NOx emissions from all kilns at a facility, as allowed pursuant to Section (C)(2).
    5. The aggregate emissions per ton of clinker shall be calculated as the aggregate emissions divided by the facility clinker production sum for the same period. When this option is approved, the aggregated NOx emissions per clinker ton will be used to comply with the NOx RACT Emission Limit.
    6. Regardless of method of compliance employed (permit unit limit or aggregate emission limit), and prior to implementation, the applicable emission limits and method of compliance shall be incorporated into the District Permit to Operate (PTO) for each kiln.

(E) Compliance Determination

  1. Any owner or operator of a kiln subject to this Rule shall make the following determinations, as set forth herein:
    1. Compliance determinations shall not be established from data obtained during the periods specified in Section (G).
    2. Emission Calculation Method
      1. Emissions shall be calculated by dividing the sum of all hourly lbs of NOx for the current operating day and the preceding 29 operating days by the tons of clinker produced over the same period of time. Such calculations shall exclude any emissions and clinker produced during those time periods specified in Section (G).
    3. Any owner or operator of a kiln subject to this Rule shall observe and convert uncorrected observed NOx concentration in ppmv to lbs per hour, using the following formula:
      lbs/hr = 7.1497 x 106 (ppmv)(dscfm)
      Standard conditions of 68oF and gas pressure of 29.92 inches of mercury:
    4. For the purposes of this Rule, oxides of nitrogen shall be calculated as NO2 on a dry basis.

(F) Monitoring and Recordkeeping

  1. Continuous Emissions Monitoring
    1. Any owner or operator of a kiln subject to this Rule shall not operate such equipment unless it is equipped with one of the following:
      1. A CEMS monitoring system which meets the requirements of 40 CFR Part 60, Subpart A, and Appendix B, and complies with the quality assurance procedures specified in 40 CFR Part 60, Appendix F. The CEMS shall be used to demonstrate compliance with the applicable emission limit, specified pursuant to Section (C)(2), or the aggregate emission limit, as set forth in Section (D), by measuring NOx emissions; or
      2. If an owner or operator can demonstrate, by preponderance of the evidence, that installation of a CEMS conforming to the requirements of Section (F)(1)(a)(i) above is technologically and economically unfeasible, the owner or operator may provide an alternate calculational and recordkeeping procedure based upon actual emission testing and correlations with operating parameters (such as kiln loading, fuel-type, percent excess oxygen, etc.). The installation, implementation and use of such an alternate calculational and recordkeeping procedure must be approved by the District, CARB and USEPA, in writing, prior to implementation.
    2. The CEMS or approved alternate recordkeeping procedure shall be operated and maintained in strict accordance with the manufacturer's/supplier's specifications and in continual compliance with the provisions of this Rule.
  2. Recordkeeping Requirements
    1. Any owner or operator of a kiln subject to this Rule shall produce and maintain CEMS records, or alternate records pursuant to Section (F)(1)(a)(ii) above, for each affected kiln on a daily basis. Such records shall include, but are not limited to:
      1. The emissions, in pounds, of NOx from each cement kiln if complying with the limit specified in (C)(2) on a permit unit basis; or
      2. The aggregate emissions, in pounds, of NOx from all cement kilns at a facility, if complying with the limit specified in (C)(2) on an aggregate basis, as approved by the District.
      3. The date, time and duration of any start-up, shutdown or malfunction in the operation of any of the kiln systems or the emissions monitoring equipment;
      4. The results of performance testing, evaluation, calibration checks, adjustments and maintenance of the CEMS or approved alternate recordkeeping procedure employed, pursuant to the requirements of Section (F)(1)(a)(ii) .
    2. Any owner or operator of a kiln subject to this Rule shall produce and maintain daily records of calculations for conversion of uncorrected observed NOx concentration in ppmv to tons per day, as required by Section (E)(1)(c).
    3. Any owner or operator of a kiln subject to this Rule shall produce and maintain daily clinker production records.
    4. Any owner or operator of a kiln subject to this Rule shall produce and maintain daily records of the type and quantity of fuel used.
    5. All records required to be produced or maintained shall be retained on site for a minimum of two years and be made available to the APCO or his designee upon request.
  3. Emission Reporting
    1. Daily NOx emission data for the calendar quarter compiled pursuant to Section (F)(2)(a)(i) or (ii) shall be submitted to the District. All quarterly reports must be received within 30 days after the end of each quarter.

(G) Exemptions

  1. The requirements of Section (C), (D) and (E) and (F)(1) shall not apply to the following periods of operation:
    1. Start-up and shut-down periods, not to exceed 36 hours;
    2. Regularly scheduled maintenance activities;
    3. Breakdown conditions qualifying under District Rule 430, as amended December 21, 1994; and
    4. Periods during which any gaseous/liquid fuel is used, and the applicable emission limit is consequently exceeded. This exemption shall be subject to the following conditions:
      1. The total allowable exceedance period shall be limited to an aggregate total of 14 calendar days per calendar year.
      2. Operating pursuant to this exemption shall not relieve the owner or operator from the requirements of District Regulations II, XII or XIII.

(H) Test Methods

  1. The following tests shall be used in conducting compliance testing, Relative Accuracy Test Audits (RATA) and other testing required for compliance with this Rule:
    1. Compliance testing shall be subject to the protocols prescribed in the District's Compliance Procedural Manual.
    2. Certification Testing shall be subject to the protocols prescribed in the District's Compliance Procedural Manual and 40 CFR 60, Appendix B.
    3. Quality Assurance Testing shall be subject to the protocols prescribed in the District's Compliance Manual and 40 CFR Part 60, Appendix F.
    4. Oxides of nitrogen stack testing for purposes of this Rule shall be conducted pursuant to EPA Method 7E, "Determination of Nitrogen Oxides Emissions from Stationary Sources (Instrumental Analyzer Procedure)" or CARB Method 100, "Procedures for Continuous Gaseous Emission Stack Sampling (Stack Gas NOx)."
    5. Stack gas flow rate testing shall be conducted pursuant to EPA Method 2, "Determination of Stack Gas Velocity and Volumetric Flow Rate (Type S Pitot Tube)."
    6. Oxygen concentration stack testing shall be conducted pursuant to EPA Method 3A, "Determination of 02 and CO2 Concentrations in Emissions from Stationary Sources (Instrumental Analyzer Procedure)" or CARB Method 100.

(I) Compliance Schedule

  1. Any owner or operator of a permit unit subject to this Rule shall comply with the following requirements, as applicable, by the latter of May 31, 1995 or 60 days following the adoption of this Rule:
    1. Submit proof of compliance with the provisions of this Rule, including installation of required NOx reduction technology and CEMS equipment, and compliance with the applicable emission limit, specified pursuant to Section (C)(2); and
    2. Submit a written request to aggregate NOx emissions from all kilns at a facility, pursuant to the provisions outlined in Section (D), if this option is desired; or
    3. Submit a request to be covered by the alternate compliance schedule outlined in Section (I)(2) below. At a minimum, the request shall include the following information for each affected kiln:
      1. An explanation of why installation of NOx reduction technology by the latter of May 31, 1995 or 60 days following adoption of this Rule is not technologically and economically feasible;
      2. A written request to aggregate NOx emissions from all kilns at a facility, pursuant to the provisions outlined in Section (D), if this option is desired;
      3. A list of kilns subject to this Rule, including District PTO Number(s), burner and manufacturer, applicable model numbers, maximum rated capacity for each kiln, and the feed and product materials;
      4. A description of the process control equipment and/or selected NOx Control Technology(ies) from Section (C)(1) to be used to achieve compliance with the applicable emission limit, as set forth in Section (C)(2);
      5. A description of the CEMS proposed to meet the requirements of this Rule, including actual or proposed CEMS equipment, proposed location of sample ports, proposed schedule and description of scheduled maintenance, zero and span checks, calibration activities and certification protocols.
        1. If the installation of CEMS is demonstrated to be technologically and economically unfeasible, the use of an alternate recordkeeping procedure shall be subject to the provisions outlined in Section (F)(1)(a)(ii).

  2. Alternate Compliance Schedule
    1. Any request to comply with the alternate compliance schedule outlined below shall be approved or disapproved by the District, in writing, no later than 60 days following receipt.
    2. Following approval, the owner or operator shall fulfill the following increments of progress, which shall be incorporated into the Authority to Construct (ATC) and/or PTO:
      1. On or before November 31, 1995, the owner or operator shall submit initial compliance testing data sufficient to establish a baseline emission rate for each kiln at the facility; and
      2. On or before December 31, 1995, the owner or operator shall submit a complete application to the District for an ATC; and
      3. On or before March 31, 1996, the owner or operator shall provide evidence that equipment has been ordered; and
      4. On or before September 30, 1996, the owner or operator shall take delivery of equipment; and
      5. The owner or operator shall install actual emissions control equipment or devices as soon as possible, but no later than February 28, 1997; and
      6. The owner or operator shall demonstrate final compliance with all applicable standards and requirements of this Rule by December 31, 1997.

(J) Violations

  1. The occurrence of any of the following shall constitute a violation of this Rule:
    1. Exceedance of the applicable emission limit specified pursuant to Section (C)(2), unless the facility has an approved aggregate emissions limit, as set forth in Section (D);
    2. For facilities which have been approved to aggregate emissions, exceedance of the sum of the total NOx emissions from all kilns at a facility, as set forth in Section (D)(1)(d), shall constitute a violation of this Rule for every permitted unit operating during the exceedance period in the averaging group;
      1. A violation of the aggregate limit shall also be considered a violation of the 30-day average for the facility. Such exceedances shall be determined by using the emission calculation method set forth in Section (E)(1)(b)(i), and considered on a daily basis.
    3. Failure to comply with any limits contained in this Rule, as determined by any one of the test methods in Section (H), or by any other previously-approved test method, as set forth in a valid PTO pursuant to Regulation II or Regulation XII;
    4. Exceedance of the 14 day exemption period for gaseous/liquid fuel use, as set forth in Section (G)(1)(d);
    5. Lack of data collection and/or reporting, pursuant to the requirements of Section (F)(2) and (F)(3);
    6. Deviations from the information provided as part of the request to observe the alternate compliance schedule, as outlined in Section (I)(1)(c) or from the increments of progress dates specified in Section (I)(2)(b), unless the owner or operator has petitioned for such changes in writing, and has received District approval prior to implementation. In the interim, a petition shall not exempt an owner or operator from complying with existing applicable permit conditions; and
    7. Failure to comply with any of the requirements set forth in this Rule.



[SIP: Limited Approval/Disapproval 5/11/00 65 FR 30355, 40 CFR 52.220(c)(274)(i)(A)(1)]