### Blank Page 1 of 1 Diane Am8t From: Diane Amet Sent: Wednesday, September28, 201112:52 PM To: ~Namsiéy.Jerty©epamail.epa.goV’; WehlIngJefferson~epamall.epa.gOV

~

The 1982 edition of R9-3-520 [since renumbered to RI 8-2-720J atA.2. Identified a different8tandard •for such facilities In “Gus, 

### Maricopa, Pima, Pinal and Santa Cruz 

### counties.” Balaji V., our Perniits Section Managerjust confirmed thatthere 

### are only

### two existing lime 

### facilities subjectto R18-2-Z~0 In ArIzona: (1) Cóchlse County—Douglas-Paul Spur (2) Mohave County—Peach Springs. Perhapsthat is the reason that

### the 1993 revisions deleted A.2, because it did not applyto any facility In the 

### state. It did not relax anything for any 

### tactility subjecttothe rule in any part ofthe

### state. That seems to resolve the issue, and that 

### history could be explained in the approval. ifa new lime facility locatOd in the state in the future, itwould be subject towhatever 

### new stahdards (NSPS or MACT) apply.átthat time. That is not relevantto this particular planning area. In the alternative RI 8-2-720 could be approved only Into the Douglas-Paul Spur portion ofthe Arizona SIP at Issue right now, 

### becaUse the emlasionstandars 

### for Cochlse County have been identical in the 1982, 1993 and 2009 versIons ofthis rule.
Diane L. Arnat, Attorney at Law Mzona Department ofEnvirenmental Quality AirQuality Division Planning Seclion Manager 1110WestWashington Street Phoenix, AZ a5007 (602) 771-2375Blank. Page 1 of3



### Diane Amet From: Diane Amst Sent: Tuesday, September27, 2011 3:12 PM To~ ‘Wamsley.Jeriy@epamail.epa.gov’ cc: Trevor Bagglore; Balaji Valdyanathan; James Wagner

Jim said you had concerns about revisions to this rule after 1982. I do not understand your concern. The standards In the currentedition ofthe nile 

### are Identicalto whattheyhave been since 1982 forsources In the Douglas-Paul Spurplanning 

### area In Cochise County. The Notice of Final Rulemaking effective March 7, 2009, shows thatthe only revisions were to delete the sentences in C. and replacethem with the underlined sentence, which is 

### more stringent. The underlined language In H. 1. was added to provide certainty as to which edition ofthe CFR had been incorporated by reference.

- RI 8-2-720. Standards of Performance for Existing Lime Manufactünng Plants A. The provisions ofthis Section are applicable to the following affected facilities used In the manufacture of lime: rotary lime kilns, vertical lime kilns, lime hydrators, and limestone crushing facilities. This Section is also applicableto limestone crushing equipmentwhich exists apartfrom other lime manufacturing facilities. B. No person shall cause, allow or permitthe discharge of particulate matter into the atmosphere in any one hourfrom any lime manufacturing or limestone crushing facility in total quantities in excess ofthe amounts calculated by one ofthe following equations; 1. For process sources having a process weight rate of60,000 pounds perhour (30 tons per hour) or less, the maximum allowable emissions shall be determined by the following equation:

= 4.lOPo.67 where: E = the maximum allowable particulate emissions rate in pounds-mass perhour. P = the process weight rate in tons-mass per hour. 2. For process sources having a process weight rate greaterthan 60,000 pounds per hour (30 tons per hour), the maximum allowable emissions shall be determined by the following equation: E = 55.OPo.ii-40 where “En and “P” are defined as indicated In subsection (B)(I). 

### 9/27/2011

### •Blank- Page 2 of3

C. For reference purposes only, the two equations In subsection (C) are plotted in Appendix II, Figure 1. The emission values obtained from the graph are approximately correctforthe heat input rates shown. However, the actual Actual values

•shall be calculated from the aoollcable eciuations and rounded offto two decimal places. D. For purposes ofthis Section, the total processweightfrom all similar units employing a simliartype process shall be used in determining the maximum allowable emission of particulate matter. E. Fugitive emissions from lime plants shall be cohtrolled In accordance wTh RI 8-2-604 through RI 8-2-607. F. The owner oroperator subject to the provisions ofthis. Section shall install, calibrate, maintain, and operate a continuous monitoring system, except as provided in subsection (G), to monitorand record the opacityof the gases discharged Into the atmosphere from any rotary lime kiln. The span ofthissystem shall beset at 70% opacity. G. The owneroroperatorof any rotary lime kiln using a wet scrubbing emission control device subject to the provisions of this Section shall not be required to monitorthe opacity ofthe gases discharged as required in subsection (F). H. The test methods and procedures required by this Section are as follows: I. The reference methods in 40 CFR 60, AppendixA. as incorporated by reference in Acoendix2ofthis Chapter. shall be used to determine compliance with this Section as follows:
a. Method 5 forthe measurementof particulate matter; b. Method I for sample and velocity traverses;
c. Method 2 for velocity and volumetric flow rate; d. Method 3 for gas analysis;
a. Method 4 for stack gas moisture; f..Method 9 forvisible emissions. 2. For Method 5, the sampling time foreach run shall be at least60 minutes and the sampling rate shall be at least 0.85 dscmlhr (0.53 dscf/min), exceptthat shortersampling times, when necessitated by process variables or otherfactors, may be approved by the Director. 3. Because ofthe high moisture content ofthe exhaust gases from the hydrators, in the range of40 to 85% by volume,
9/27/9fl1 1B1ank~ Page3of3

the Method 5 sample trahi may be modified to include a calibrated orifice immediatelyfollowing the sample nozzle when testing lime hydrators. In this configuration, the sampling rate necessary for maintaining Isokineticconditions cafl be directly related to exhaustgasvelocity without a correction for moisture content.
Diane L Arnst~ Attorneyat Law Mzojia Department 01’ EnvIronmental Quality AirQuafity Division Planning Section Manager ff10WestWashington Street Phoenix, AZ 86007 (602) 771-2375

9/27/2011