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TECHNICAL REVIEW AND EVALUATION 

OF APPLICATION FOR 

AIR QUALITY PERMIT NUMBER 42782 

CHEMICAL LIME COMPANY - NELSON LIME PLANT

I. INTRODUCTION 

This permit is the Title V Air Quality Permit renewal for the operation of a Lime Manufacturing 

Plant and a Limestone Processing Plant near Peach Springs, Arizona. This is a renewal of Air 

Quality Permit No. 1000045. 

A. Company Information 

Mailing Address: P.O. Box 370, Peach Springs, Arizona 86434 

Facility Address: 2.5 Miles South of US 66, Mile Marker 112, Peach Springs, AZ 

86434 (Approximately six miles east of Peach Springs, Arizona in 

Yavapai County) 

B. Attainment Classification 

The Peach Springs area is designated as Attainment or unclassifiable for all criteria 

pollutants. 

II. PROCESS DESCRIPTION 

A. Limestone Processing 

This facility manufactures lime from limestone. The principal process and equipment of the 

facility are as follows: a quarry mining operation, a limestone crushing and screening 

operation, a limestone kiln feed system, a solid fuel handling system, two rotary lime kilns, 

front and back lime handling systems, a lime hydrator, diesel electric generators, fuel storage 

tanks, and other support operations and equipment. The basic processes in the production of 

lime are: (1) quarrying raw limestone; (2) preparing limestone for the kilns by crushing and 

sizing; (3) calcining the limestone; (4) processing the lime further by hydrating; and (5) 

miscellaneous transfer, storage, and handling operations. The principal air emissions from 

this facility are particulate matter, carbon monoxide, nitrogen oxides, and sulfur dioxide. 

Major air pollution control equipment to capture particulates includes negative pressure 

baghouses for Kiln 1 and Kiln 2, and a number of baghouses at other material drop points. 

The limestone processing operations consist of two quarries, a crushing and screening plant, 

and auxiliary operations. The limestone processing operations produce (a) crushed and sized 

limestone for the adjacent lime manufacturing operations, and (b) crushed and sized 

limestone products for aggregate sales. 

1. Quarry Operations 

Quarry operations include (a) drilling and blasting to fracture the overburden and 

stone; (b) loading the limestone, waste rock and overburden to haul trucks; (c) 

hauling limestone to the primary crusher, the plaza (limestone stockpile area located 
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next to the primary crusher), or to the secondary blasting (for large rocks); (d) 

hauling overburden and waste rock to in-pit storage areas and the gravitational piles; 

and (e) hauling and transferring kiln dust and off-spec lime/hydrate from the lime 

manufacturing facility to in-pit storage areas. 

Some overburden and waste rock is hauled to the gravitational piles. In the 

gravitational piles, dirt and other fine particles settle out in the upper sections of the 

pile, while the larger size stones accumulate at the edges of the lower sections. 

Small stones of acceptable limestone quality are collected as needed at the bottom of 

the gravitational piles, loaded into haul trucks, and transported to the crushing and 

screening plant. 

2. Crushing and Screening 

Limestone from the quarry is hauled to the crushing and screening plant where it is 

unloaded to either the dump hopper or on the plaza located to the northeast of the 

crusher. Limestone from the plaza is subsequently reclaimed via front-end loader 

and loaded into the dump hopper. The crushing and screening plant processes the 

limestone through a series of crushers and screens in order to reduce the size of the 

rock, and to separate out the very fine material (chat) and remove it from the system. 

 The chat is conveyed from four different screens in the crushing and screening plant 

to the chat silo. The chat is then either loaded onto trucks or stockpiled. The 

crushed limestone is conveyed to a kiln feed stockpile for use by the adjacent lime 

manufacturing operations. Kiln feed material and chat are also sold to various 

customers as needed, or used internally for gravel or road fill material. On occasion, 

off-spec limestone is processed through the crushing and screening plant. 

B. Lime Manufacturing 

The lime manufacturing equipment consists of two lime kilns and auxiliary equipment 

necessary for receiving crushed limestone, processing it through the lime kilns, and 

processing the lime kiln product. Operations include pre-kiln limestone handling, two lime 

kilns, post-kiln handling, a hydrator, two peak demand generators, truck and rail loadout 

facilities, and solid fuel handling. The lime kilns are used to convert crushed limestone 

(CaCO3) into quicklime (CaO). 

III. EMISSIONS 

The facility is classified as a Major Source under the Title V program, pursuant to Arizona 

Administrative Code (A.A.C.) R18-2-101.64. The potential emission rates for PM10, NOx, SO2, and 

CO are greater than the major source thresholds. Table 1 below shows the facility’s potential 

emissions for criteria pollutants: 

Table 1: Facility Wide Potential Emissions – Criteria Pollutants 

Pollutant Maximum Emissions (tpy) 

PM 2,331 

PM10 924 
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PM2.5 360 

NOx 1,379 

SO2 4,535 

CO 674 

VOC 9.9 

Emissions of a single hazardous air pollutant (HAP), hydrogen chloride (HCl), exceed the major 

source threshold of 10 tons per year. Therefore, the facility is classified as a major source of HAPs. 

Estimated HCl emissions are 13.3 tons per year and total HAP emissions are estimated to be 16.3 

tons per year. 

IV. APPLICABLE REGULATIONS 

Table 1. Listing of Applicable Requirements 

Emission Units Applicable 

Requirements 

Comments 

Limestone Crushing & Screening: A.A.C. R18-2-702(B), 

A.A.C. R18-2-720(B) 

Except for Belt Conveyor 

226 which is subject to 

40 CFR 60.672(a)(1) and 

(2) and 672(b) 

Subpart OOO applies to 

equipment manufactured after 

August 31, 1983. 

Limestone Kiln Feed System: 

Limestone Kiln Feed System 

. 

A.A.C. R18-2-702(B) and 

720 with the exception of 

Vibrating Screen 328 

which is subject to OOO. 

These equipment process 

limestone. They were all 

manufactured prior to August 

31, 1983 (trigger date for NSPS 

Subpart OOO). Therefore, they 

are subject to Article 7 

standards. 

Rotary Kiln 1, Rotary Kiln 2, Contact Cooler 

2-310, Contact cooler 1-310, Belt Conveyor 

329, Weigh Belt Conveyor 303A, and Stone 

Bin 1-304. 

40 CFR 63 Subpart 

AAAAA, A.A.C. R18-2-

702(B) and 720. 

This subpart applies to lime 

manufacturing facilities that 

are a major source of 

hazardous air pollutants. 

Chemical Lime Nelson is a 

major source of HAPs for 

HCL. The Subpart applies to 

each kiln and their associated 

coolers, and processed stone 

handling facilities. This 

Subpart applies in addition to 

A.A.C. R18-2-702(B) and 

720. 
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Emission Units Applicable 

Requirements 

Comments 

Solid Fuel Handling System A.A.C. R18-2-702(B) 

and A.A.C. R18-2-

716(B) and 40 CFR 

§60.252(c) for equipment 

built after October 24, 

1974. 

These units were built prior to 

October 24, 1974 (trigger date 

for NSPS Subpart Y). They 

are subject to Article 7 

standards. 

Kiln 1 System/Kiln 2 System: 

Kiln 1 and Kiln 2 System equipment not 

subject to A.A.C. R18-2-720. 

A.A.C. R18-2-702(B) 

and 730(A)(1) 

These are unclassified existing 

sources. 

Front Lime Handling System (FLHS) and 

Back Lime Handling System (BLHS): 

A.A.C. R18-2-702(B) 

and A.A.C. R18-2-

730(A)(1) 

Both lime handling systems 

process lime. NSPS Subpart 

OOO, A.A.C. R18-2-720, and 

A.A.C. R18-2-722 are 

applicable only to material 

sizing, conveying, and storing 

operations that process 

limestone. 

BLHS Truck and Rail Loadout controlled by 

Baghouse DC 414. 

40 CFR 64 This unit is subject to Title 40 

Part 64: Compliance 

Assurance Monitoring 

(CAM). Applicability: 1) 

This unit is subject to the PM 

emission limit identified in 

Condition VII.B.1.b in 

Attachment “B” of the permit. 

2) Unit uses a control device 

(DC 414) to achieve 

compliance with the PM 

emission limit. 3) The unit has 

pre-control emissions greater 

than 100 tons per year. 

Hydrate System: 

Hydrate System A.A.C. R18-2-702(B) 

and 720(B) 

A.A.C. R18-2-720, Standards 

of Performance for Existing 

Lime Manufacturing Plants, 

stipulate the applicability to 

lime hydrators. 

North Electric Generator, South Electric 

Generator, and Canyon Well Generator 

A.A.C. R18-2-719(C)(1), 

719(E), 719(F), 719(H), 

719(I), 719(J), 40 CFR 

60 Subpart IIII, 40 CFR 

63 Subpart ZZZZ 

Standards of Performance for 

Existing Stationary Rotating 

Machinery. 

NSPS for Compression 

Ignition Engines. 
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Emission Units Applicable 

Requirements 

Comments 

NESHAP Subpart ZZZZ 

applies to all engines. 

Gasoline Storage Tank 11, Diesel Storage 

Tank 12, and Diesel Storage Tank for 

alternate operation 

A.A.C. R18-2-710 

Fugitive Dust A.A.C. R18-2-604, 

A.A.C. R18-2-605, 

A.A.C. R18-2-606, 

A.A.C. R18-2-607, 

A.A.C. R18-2-612 

All of these operations are 

non-point sources, and are 

subject to the requirements of 

Article 6. 

The Permit also requires the 

facility to have a dust control 

plan which specifies what 

specific areas need to be 

cleaned and the control 

methods to be employed. 

VI. PREVIOUS PERMITS AND CONDITIONS 

Table 4 below outlines the permits that have been issued to the source. Table 5 cross references the 

previous permit conditions to determine if they are to be revised, kept, deleted or streamlined in the 

permit renewal. If a condition from the previous permit is deleted or if a new standard becomes 

applicable, comments are provided explaining the reasoning for the change. 

Table 4. Previous Permits 

Permit Issuance Date Permit Number Application Basis

6/28/2002 1000045 Operating Renewal Permit 

Table 5: Previous Permit conditions 

Permit 

condition 

Number

Determination

Delete Kept Revise Streamline 

Comments

Att A X Revised to reflect the most recent 

permitting language. 

Att B: 

Section I 

X Revised to reflect the most recent 

permitting language. 

Att B: 

Section II 

X X This section has been revised to 

reflect the most recent permitting 

language. 
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Permit 

condition 

Number

Determination

Delete Kept Revise Streamline 

Comments

Att B: 

Section III 

X This Section has been revised to 

more accurately cover all emission 

sources. 

Att B: 

Section IV 

X X This Section has been revised to 

more accurately cover all emission 

sources. 

Att B: 

Section V 

X X This Section has been revised to 

more accurately cover all emission 

sources. 

Att B: 

Section VI 

X X Kiln 1 System/Kiln 2 System: this 

Section has been revised to more 

accurately cover all emission 

sources. 

Att B: 

Section VII 

X X Front and Back Lime Handling 

Section has been revised to more 

accurately cover all emission 

sources. 

Att B: 

Section VIII 

X X Hydrator Section has been revised to 

more accurately cover all emission 

sources. 

Att B: 

Section IX 

X Miscellaneous Drop Points From 

Dust Bins and Conveyors Section 

has been deleted. 

Att B: 

Section X 

X X Diesel Generators Section has been 

revised to more accurately cover all 

emission sources. 

Att B: 

Section XI 

X X Fuel Storage Tanks Section has been 

revised to more accurately cover all 

emission sources. 

VII. MONITORING AND RECORDKEEPING REQUIREMENTS 

The following monitoring approaches have been prescribed in the permit: 

A. Fugitive Dust Sources 

Non-point sources are subject to the 40% opacity standard and other Article 6 requirements. 

Periodic monitoring for opacity entails a biweekly visible emissions survey in accordance 

with an ADEQ - approved observation plan, by a certified Method 9 observer. If the visible 

emissions survey indicates that the opacity may exceed the standard, the observer shall 

conduct a Method 9 observation and maintain records of the results. Any observed 
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exceedance of the opacity standard must be reported appropriately. This approach, termed 

the Visible Emission Observation Procedure, is defined in Condition I.H of Attachment B. 

B. Kilns 1 and 2 

Opacity is monitored by a Continuous Opacity Monitor (COM). One monitor has to be 

maintained on each stack. Kiln 1 and Kiln 2 are required to comply with a particulate 

emission standard. This permit requires CLC to perform a stack test every 5 years combined 

with monitoring stack gas opacity to fulfill the periodic monitoring requirements for 

particulate matter emissions. 

C. Point Sources other than Kilns 1 and 2 

The Control Device Monitoring and Maintenance Procedure is used as periodic monitoring 

for dust collectors. Proper maintenance of dust collectors is critical to ensure compliance 

with the particulate and opacity standards applicable to these point sources. CLC is required 

to implement the maintenance program on a monthly basis. 

D. Compliance Assurance Monitoring (CAM) 

This facility is subject to the requirements of 40 CFR 64 referred to as Compliance 

Assurance Monitoring (CAM). The plan requires the source to provide reasonable assurance 

of compliance with emission limits or standards for the anticipated range of operations at a 

pollutant specific emissions unit. CAM is not required for Kiln 1 or Kiln 2 since the kilns are 

subject to the MACT standard 40 CFR 63 Subpart AAAAA. 

Quicklime Truck and Rail Loadout Facilities of the Back Lime Handling System 

The CAM Plan for particulate matter for the truck and rail load out, which is controlled by a 

baghouse, is based on the following monitoring approach: 

Primary Indicators 

i. Baghouse differential pressure. 

ii. Control device maintenance procedure. 

iii. Visible emissions observation procedure. 

VIII. TESTING REQUIREMENTS 

Performance tests for opacity and particulate matter (PM) are required at the stacks for Kilns 1 and 2 

are required every 5 years. The stack testing must be conducted while combusting solid fuel. In 

addition, once during the permit term, CLC is required to test the the North and South Diesel 

Generators for nitrogen oxides. 

Performance tests must be conducted at maximum possible capacity of each unit. However, based 

upon operational conditions, the company can request that the test be conducted at a lower rate. This 

request must be submitted to the Department as part of the Test Plan required in Condition XVIII of 

Attachment “A” and is subject to Department approval. 
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IX. LIST OF ABBREVIATIONS 

 A.A.C. ................................................................................................. Arizona Administrative Code 

 ADEQ ......................................................................Arizona Department of Environmental Quality 

CO......................................................................................................................... Carbon Monoxide 

COMs................................................................................................... Continuous Opacity Monitor 

 EPA .............................................................................................Environmental Protection Agency 

 HAPs..........................................................................................................Hazardous Air Pollutants 

IP...........................................................................................................................Installation Permit 

NAA.................................................................................................................Non Attainment Area 

 NO2 ........................................................................................................................... Nitrogen Oxide 

NSR................................................................................................................... New Source Review 

OP ...........................................................................................................................Operating Permit 

 PM..........................................................................................................................Particulate Matter 

 PM10 ..................................................................................Particulate Matter Less Than 10 Microns 

PTE ......................................................................................................................... Potential to Emit 

 SO2 ............................................................................................................................. Sulfur Dioxide 

 tph ...............................................................................................................................Tons per Hour 

 VOC ......................................................................................................Volatile Organic Compound 
X. Plant Schematics 

Figure 1: Process Flow Diagram for the Crushing and Screening Plant 

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Figure 2: Process Flow Diagram for the Solid Fuel Handling System 
Figure 3: Process Flow Diagram for the Kiln 1 System 

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Figure 4: Process Flow Diagram for the Kiln 2 System 

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Figure 5: Process Flow Diagram for the Front Lime Handling System 
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Figure 6: Process Flow Diagram for the Back Lime Handling System 
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Figure 7: Process Flow Diagram for the Hydrator System