Exhibit CC 12-07-2010 Oral Communications XHI -IT
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.BAY AREA
AI Q UALITY .
ANAGEMENT 60.
D I S T R I C T
Health Risk Assessment
Evaluation of Toxic Air Contaminant Impacts
AB2588 Air Toxics Hot Spots Program
for
Lehigh Southwest Cement Company, Plant #17
Precalciner Kiln, S -154
Facility Address:
24001 Stevens Creek Blvd.
Cupertino, CA 95014
Director of Engineering: Brian Bateman
Toxics Section Engineering Manager: Scott Lutz
Toxics Evaluation Engineer: Ted Hull
November 2008
Health Risk Assessment:
Lehigh Southwest Cement Company (Plant #17)
A. BACKGROUND:
This Health Risk Assessment (HRA) has been prepared by the Bay Area Air Quality
Management District (BAAQMD) for the Lehigh Southwest Cement Company (LSCC), which
operates a cement manufacturing plant in Cupertino CA, in order to determine the current status
of the company for the Air Toxics Hot Spots (ATHS) Program.
The BAAQMD routinely conducts or reviews HRAs for new and modified sources of toxic air
contaminants (TAC) in conformance with Regulation 2, Rule 5: New Source Review of Toxic
Air Contaminants. In addition, the BAAQMD periodically reviews toxic emission reports from
existing facilities under the Air Toxics Hot Spots (ATHS) Program to assess the potential for
these facilities to pose significant risk to the public. If toxic emissions are above thresholds
established by the BAAQMD, a refined HRA is required (see Appendix A, ATHS Overview).
LSCC and /or the BAAQMD had prepared HRAs for the ATHS program and for Toxic NSR
(proposed modifications to the cement plant); albeit, these analyses had focused on the
precalciner kiln (S -154) because no other significant sources of TACs had previously been
identified at LSCC. These HRAs had indicated that the company meets the health protective risk
standards for Toxic NSR and for the ATHS program. However, recent information about other
California cement plants (in Riverside and Davenport) and mercury emissions from LSCC have
generated concern regarding the risk associated with LSCC; accordingly, the BAAQMD has
prepared an updated HRA for the kiln at LSCC. In addition, considering the recent news about
fugitive emissions of hexavalent chromium from Riverside and Davenport plants, the BAAQMD
has required that LSCC prepare a comprehensive update to their toxic emissions inventory,
including potential fugitive emissions from various material handling sources. The BAAQMD
will review the updated emission inventory and assess the need for a new HRA.
B: SUMMARY:
The following is a summary of the health risk results for the operation of the precalciner kiln at
Lehigh Southwest Cement Company.
Maximum Cancer Risk: 4.2 in a million
Maximum Chronic Hazard Index: 0.26
Maximum Acute Hazard Index: 0.13
Risks are less than BAAQMD action levels for public notification (cancer risk of 10 in a million
and hazard indexes of one).
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C. EMISSIONS SUMMARY:
Emissions of toxic air contaminants (TAC) from the cement kiln are based on the results of
numerous source tests conducted over a number of years (kiln was last tested in December of
2007). A summary of the estimated TAC emissions from S -154 is given below in Table 1.
Table 1: Modeled Emission Rates
TACs Mill On Mill Off Modeled Emissions Modeled Emissions
(lb/hr) (lb/hr) (lb/hr) (1b /yr)
Acetaldehyde 1.43E -01 9.81E +02
Antimony 5.40E -05 3.70E -01
Arsenic' 5.55E -05 3.81E -01
Benzene 2.53E +00 9.67E+03
Benzyl Chloride 6.07E -03 4.16E +01
Beryllium 5.57E -05 5.40E -05 5.57E -05 3.78E -01
1,3 Butadiene 5.29E -03 3.63E +01
Cadmium' 2.79E -05 1.91E-01
Carbon tetrachloride 3.67E -03 2.52E +01
Chloroform 1.72E -03 1.18E +01
Chromium VI 4.80E -05 5.04E -05 5.04E -05 3.34E -01
Copper 5.83E -04 6.89E -04 6.89E -04 4.22E +00
Dichlorobenzene 3.52E -03 2.41E +01
1,1 Dichloroethylene 1.90E -03 1.30E +01
Ethylene dichloride 1.42E -03 9.74E +00
Ethylene dibromide 3.60E -03 2.47E +01
Formaldehyde 8.17E -03 5.60E +01
Lead 1.43E -04 9.42E -05 1.43E -04 8.80E -01
Manganese 6.27E -04 4.67E -04 6.27E -04 3.97E +00
Mercury 2.24E -02 5.43E -02 5.43E -02 2.19E+02
Methylene chloride 1.53E -02 1.05E +02
Nickel 1.03E -03 7.55E -04 1.03E -03 6.50E +00
PCBs (high risk) 1.03E -06 7.06E -03
PCDDs/PCDFs (TEQs) 1.41E -08 4.78E -08 4.78E -08 1.66E -04
Perchloroethylene 3.18E -03 2.18E +01
Phosphorus 1.10E -02 7.54E +01
Selenium 5.79E -04 7.03E -04 7.03E -04 4.23E +00
1,1,2,2 Tetrachloroethane 2.41E -03 1.65E +01
1,1,2 Trichloroethane 3.20E -03 2.19E +01
Trichloroethylene 2.52E -03 1.73E +01
Vanadium 2.79E -04 1.91E +00
Vinyl chloride 1.71E -02 1.17E +02
Zinc 7.56E -03 7.22E -03 7.56E -03 5.11E +01
Notes:
1. Emissions below the detection limit. Emission rate is based on 1/2 the detection limit.
Emission rates are based on 6,857.3 hours of operation per year. Where specific data is available,
annual emissions assume the feed mill is operating (Mill On) 70% of the time and not operating
(Mill Off) 30% of the time.
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D. DISPERSION MODELING:
The AERMOD air dispersion computer model was used to estimate annual average and
maximum 1 -hour average ambient air concentrations for receptors in the area of the source.
Model runs were made with onsite surface meteorological data and local land use data for 2
separate years, 1999 and 2006. Cloud cover data for the same time period was were taken from
the San Jose International Airport ASOS station. Upper air data for the same time period was
taken from the closest representative NWS radiosonde station that met the USEAPA required
90% data recovery rate, the Oakland International Airport radiosonde station. Land use at the
facility was divided into 5 sectors: 347 ° -50 °, 50° -230 °, 230 ° -273 °, 273 ° -312 °, and 312 ° -347 °.
The modeler assumed rural land use.
Modeling results in terms of unit ground level concentrations were applied to TAC specific
emission rates and unit risk factors for residential receptors to determine the Cancer Risk and the
Chronic and Acute Hazard Quotients for each compound at a given receptor location. Thirty-day
average lead concentrations were modeled separately using the highest estimated hourly
emission rate.
E. HEALTH RISK ASSESSMENT:
The maximum health risks were estimated using guideline procedures adopted for use in the Air
Toxics Hot Spots Program. The general ATHS approach involves using air emission estimates
and dispersion modeling to estimate the facilities impact on ambient air concentrations of toxic
air contaminants (TACs), and then using these concentrations to estimate an individual's
maximum exposure and health risk based on exposure factors and toxicity values adopted by the
Cal/EPA Office of Environmental Health Hazard Assessment (OEHHA).
Estimates of residential cancer risk (probability of contracting cancer in terms of chances in a
million) assume that potential exposure to annual average TAC concentrations occur 24 hours
per day, 350 days per year, for a 70 -year lifetime; the concentrations for the 1999 and 2006
modeled years were averaged. The sum of the lifetime cancer risks for each compound provides
the overall cancer risk. Unit risk factors for each compound were obtained from the California
Air Resources Board's "Hotspots Analysis and Reporting Program" Version 1.4a (HARP). In
addition to the inhalation exposure pathway, several of the TACs emitted have additional
pathways related to oral ingestion and dermal exposure. Cancer unit risk values were determined
using the Derived Adjusted analysis method.
A Reference Exposure Level (REL) is an indicator of potential noncancer health impacts and is
defined as the concentration at which no adverse noncancer health effects are anticipated.
Noncancer chronic inhalation risk is calculated by dividing the substance - specific annual average
concentration by the REL for that substance. This ratio is called a hazard quotient (HQ).
Chronic hazard quotients can also be calculated for noninhalation pathways by dividing the
noninhalation exposure (dose) by the oral REL for that substance. The sum of the inhalation HQ
and the oral HQ for a substance is the overall chronic HQ. Hazard quotients are summed for
substances that affect a particular organ system to yield a hazard index for that organ system.
The highest hazard index value is the overall hazard index. Chronic hazard indexes were
determined using the Derived OEHHA analysis method.
Acute hazard quotients are calculated by dividing the maximum 1 -hr average concentrations for
a substance by its acute REL; and summing HQs by affected organ systems to calculate the
hazard index. Noninhalation pathways are not considered for acute risk.
4
The summary of health risks for S -154, precalciner kiln, at selected receptor locations are
presented in the Table 2 below; receptor locations are indicated on the map in Figure 1.
Table 2: Summa of Im s acts
Total Impacts from Highest Risk Components
Receptor Impacts at and Other Compounds of Interest
Receptor Benzene Mercury I Chromium VI Dioxins/Furans
Residential MEI 1
Cancer Risk (in a million) 4.2 2.8 N/A 0.49 0.56
Chronic Hazard Index 0.26 0.002 0.25 0.00002 0.0005
Acute Hazard Index 0.13 0.008 0.12 N/A N/A
Residential (Typical)
Cancer Risk (in a million) 2.1 1.4 N/A 0.25 0.28
Chronic Hazard Index 0.13 0.001 0.13 0.00001 0.0003
Acute Hazard Index 0.08 0.004 0.07 N/A N/A
Monta Vista Park Area
Cancer Risk (in a million) 0.3 0.2 N/A 0.04 0.04
Chronic Hazard Index 0.02 0.0001 0.02 0.000001 0.00004
Acute Hazard Index 0.01 _ 0.0008 0.01 N/A N/A
Notes:
1. MEI (Maximally Exposed Individual) is a residential receptor that is located at the top of San Jacinto Road,
Cupertino.
2. A residential receptor point in the impacted area that represents more typical risk. The chosen receptor is
located at the junction of Stevens Canyon Road and San Juan Road, Cupertino.
3. Cancer risk is the average value from 2 years of modeled concentrations based on meteorological data from
1999 and 2006.
Benzene:
As shown above, a majority of the cancer risk associated with operation of the cement kiln is due
to potential exposure to benzene, which is a known carcinogen, shown to cause leukemia. The
majority of benzene emissions are from naturally occurring kerogens that are released by heating
limestone in the kiln.
Mercury:
As shown above, Mercury makes up the overwhelming majority of the non - cancer chronic and
acute risk associated with the cement kiln operation. T el..maximum chronic non - cancer risk for
LSCC is due to potential exposure to mercury via the ingestion pathways [consumption of home
grown produce (43 %), dermal absorption (48 %), and soil ingestion (9 %)], wtich has been shown
to h va e a rcii f mune effects in the kidney. Mercury is also known to have neurological effects
(via inhalation pathway); however the chronic H Q for the nervous system is 0.03 at the MEI.
HRA guidelines include two default exposure factors for consumption of home grown produce:
urban (assumes 5.2% of consumed produce is grown at residence) and nonurban (assumes 15%
of consumed produce is grown at residence); based on the nature of the impacted area, urban
consumption was assumed for this HRA. If a targeted receptor consumes little or no produce
grown in the impacted area, actual risk would be less than the chronic HI reported in Table 2.
The acute risks are based on reproductive /developmental effects caused by inhalation.
Adverse health effects are not expected to occur, even for sensitive members of the population,
for hazard indexes less than one. RELs are derived using uncertainty (safety) factors; therefore,
a hazard index that exceeds one does not indicate that adverse effects will occur, rather, it is an
indication of the erosion of the margin of safety and that the likelihood of adverse health effects
is increased.
5
Lead:
Lead emissions from Lehigh are subject to the following ground level concentration standards in
micrograms per cubic meter Cg /m
• < 0.30 _g /m (30 -day average): Hot Spots screening level for areas with average lead
exposure *; from "Risk Management Guidelines for New, Modified, and Existing Sources of
Lead" (California Air Resources Board, March 2001) The guidelines are based on the
statistical probability of children having blood lead levels (BLLs) greater than the baseline
level of 10 micrograms per deciliter (_g/dL) due to facility emissions.
• < 0.15 _g /m (3 -month average): National Ambient Air Quality Standard (NAAQS),
Revised October 2008.
* Background lead exposure is classified as either "average" or "high ". High exposure areas are areas where the
mean BLLs will be higher as a result of exposure to higher levels in dust and soil (typically from the use of lead in
paint). High exposure is assumed for areas where the moan age of housing is 1960, or older, and more than 30
percent of persons for whom poverty status is determined have a ratio of income to poverty level less than 1.25. In
a high exposure area, the approvable lead concentration is reduced to < 0.12 _g /m (30 -day average). Ambient air
concentrations in the Bay Area are typically measured as 0.01 _g/m
Table 3: Lead Impacts
NAD 27 UTM Coordinates
Highest Modeled Lead Concentrations:
Receptor Type Easting (x) Northing (y) .'.0 -Day Average (.tg/m
(meters) (meters)
Highest Offsite 581,791 4,129,924 0.00004
Residential (Maximum) 582,021 4,129,753 0.00003
Residential (Typical) 582,561 4,129,603 0.00002
Monta Vista Park Area 582,531 4,130,353 < 0.00001
As apparent in Table 3, ambient lead concentrations from facility emissions are well below the
Hot Spots screening value and would not significantly impact the NAAQS for lead.
F. CONCLUSIONS / NEXT STEPS:
The findings of this HRA are that the health risks from Lehigh Southwest Cement Company are
below the action levels that the BAAQMD has adopted for the public notification under the Air
Toxics Hot Spots Program: (Cancer Risk >10 in a million, Chronic & Acute Hazard Indexes >
1.0, and 30 -day average lead concentration > 0.30 _g /m Mandatory risk reduction levels are
higher and are not triggered.
The BAAQMD will reevaluate the status of Lehigh Southwest Cement Company for the Air
Toxics Hot Spots Program upon receipt of LSCC's updated toxic inventory report and will
determine if an updated HRA is necessary.
6
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Figure 1. Receptor map (Cupertino) for Health Risk Assessment, Lehigh Sotrthwest Cement Company
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APPENDIX A
•p
Air Toxics Hot Spots Program Overview
The Air Toxics "Hot Spots" Information and Assessment Act (AB 2588, Connelly, 1987)
established a formal regulatory program for site - specific air toxics emissions inventory and
health risk quantification that is managed by California air districts. Under this program, a wide
variety of industrial, commercial, and public facilities are required to report the types and
quantities of toxic substances their facilities routinely release into the air. The goals of the Air
Toxics Hot Spots Program are to collect emissions data, to identify facilities with potential for
localized health impacts, to ascertain health risks, to notify nearby residents of risks that are
determined to warrant such notification, and to reduce significant risks.
There are five steps to implementing the ATHS program. Guidelines have been developed for
all five steps to establish a consistent, science - based, methodology for implementing the
program. The five steps are briefly described as follows:
• Air Toxics Emissions Inventory: Subject facilities are required to prepare and submit a
comprehensive emissions inventory plan followe 'by a toxics emissions inventory report.
Each facility's emissions inventory must be updated on a periodic basis (in order to reflect
changes in equipment, materials, and production levels at the facility).
• Prioritization: Each facility is prioritized for potentially significant health impacts based on
the quantity and toxicity of emissions, and the proximity of nearby residents and workers.
• Health Risk Assessment: Facilities that are determined to be "high priority" are required to
prepare a comprehensive HRA. The air district and Cal /EPA's Office of Environmental
Health Hazard Assessment (OEHHA) review the HRA.
• Public Notification: If the health risks result from the facility's emissions exceed action
levels established by the air district, the facility is required to perform notification to all
exposed persons regarding the results of the HRA. The BAAQMD has established a cancer
risk of 10 in a million and a noncancer Hazard Index of 1.0 as ATHS public notification
levels.
• Risk Reduction: If the health risks resulting from the facility's emissions exceed significance
levels established by the air district, the facility is xtquired to conduct an airborne toxic risk
reduction audit and develop a plan to implement measures that will reduce emissions from
the facility to a level below the significance level within five years. The BAAQMD has
established a cancer risk of 100 in a million and a noncancer Hazard Index of 10 as ATHS
mandatory risk reduction levels.
•A
A