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Diane Am8t

From: Diane Amet

Sent: Wednesday, September 28, 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 at A.2. Identified a different8tandard

•for such facilities In “Gus, Maricopa, Pima, Pinal and Santa Cruz counties.” Balaji V., our Perniits

Section Managerjust confirmed that there are only two existing lime facilities subject to R18-2-Z~0 In

ArIzona: (1) Cóchlse County—Douglas-Paul Spur (2) Mohave County—Peach Springs. Perhaps that

is the reason that the 1993 revisions deleted A.2, because it did not apply to any facility In the state.

It did not relax anything for any tactility subject to the rule in any part of the state. That seems to

resolve the issue, and that history could be explained in the approval. if a new lime facility locatOd in

the state in the future, it would be subject to whatever new stahdards (NSPS or MACT) apply.át that

time. That is not relevant to this particular planning area.

In the alternative RI 8-2-720 could be approved only Into the Douglas-Paul Spur portion of the

Arizona SIP at Issue right now, becaUse the emlasionstandars for Cochlse County have been

identical in the 1982, 1993 and 2009 versIons of this rule.

Diane L. Arnat, Attorney at Law

Mzona Department of Envirenmental Quality

Air Quality Division Planning Seclion Manager

1110 West Washington Street

Phoenix, AZ a5007

(602) 771-2375
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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 current edition of the nile are Identical to what they have been

since 1982 for sources In the Douglas-Paul Spurplanning area In Cochise County.

The Notice of Final Rulemaking effective March 7, 2009, shows that the only revisions were to delete

the sentences in C. and replace them with the underlined sentence, which is more stringent. The

underlined language In H. 1. was added to provide certainty as to which edition of the CFR had been

incorporated by reference. -

RI 8-2-720. Standards of Performance for Existing Lime Manufactünng Plants

A. The provisions of this 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

applicable to limestone

crushing equipment which exists apart from other lime manufacturing facilities.

B. No person shall cause, allow or permit the discharge of particulate matter into the atmosphere in

any one hour from any

lime manufacturing or limestone crushing facility in total quantities in excess of the amounts

calculated by one of the following

equations;

1. For process sources having a process weight rate of 60,000 pounds per hour (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 per hour.

P = the process weight rate in tons-mass per hour.

2. For process sources having a process weight rate greater than 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).

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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 correct for the heat input rates shown. However, the actual Actual values

• shall be calculated from the aoollcable eciuations and rounded off to two decimal places.

D. For purposes of this Section, the total process weight from all similar units employing a simliar type 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 or operator subject to the provisions of this. Section shall install, calibrate, maintain, and operate a

continuous

monitoring system, except as provided in subsection (G), to monitor and record the opacityof the gases discharged

Into

the atmosphere from any rotary lime kiln. The span of this system shall be set at 70% opacity.

G. The owner or operator of any rotary lime kiln using a wet scrubbing emission control device subject to the

provisions of

this Section shall not be required to monitor the opacity of the 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, Appendix A. as incorporated by reference in Acoendix 2of this Chapter.

shall

be used to determine compliance with this Section as follows:

a. Method 5 for the measurement of 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 for visible emissions.

2. For Method 5, the sampling time for each run shall be at least 60 minutes and the sampling rate shall be at least

0.85

dscmlhr (0.53 dscf/min), except that shorter sampling times, when necessitated by process variables or other factors,

may be approved by the Director.

3. Because of the high moisture content of the exhaust gases from the hydrators, in the range of 40 to 85% by

volume,

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the Method 5 sample trahi may be modified to include a calibrated orifice immediately following the sample nozzle

when testing lime hydrators. In this configuration, the sampling rate necessary for maintaining Isokinetic conditions

cafl be directly related to exhaust gas velocity without a correction for moisture content.

Diane L Arnst~ Attorney at Law

Mzojia Department 01’ EnvIronmental Quality

Air Quafity Division Planning Section Manager

ff10 West Washington Street

Phoenix, AZ 86007

(602) 771-2375

9/27/2011