FLORENCE COPPER INC. - FLORENCE Copper... · (12/11/17) FLORENCE COPPER PROJECT - FLORENCE FLORENCE COPPER INC. - FLORENCE 1. ... machine. The stripping ...

S:\Word\PERMITS\Permit.b\B31219.AJ_KGW.doc PERMIT #B31219.000

1

(12/11/17) FLORENCE COPPER PROJECT - FLORENCE

FLORENCE COPPER INC. - FLORENCE

1. INTRODUCTION ........................................................................................................................................ 335

2. AUTHORITY TO CONSTRUCT AND OPERATE .............................................................................................. 557

3. LISTING OF (CURRENTLY FEDERALLY ENFORCEABLE) APPLICABLE REQUIREMENTS ................................... 668

4. EMISSION LIMITATIONS AND CONTROLS .................................................................................................. 668

A. APPLICABLE LIMITATIONS ................................................................................................................................... 668 C. LIMITATIONS AND PROCESS CONTROLS - SX AND EW PLANTS ................................................................................... 779 D. VOLUNTARILY ACCEPTED EMISSIONS LIMITATIONS - SULFURIC ACID ......................................................................... 8810 E. STATIONARY COMPRESSION IGNITION INTERNAL COMBUSTION ENGINES NSPS .......................................................... 8810

1. Emission Standards ............................................................................................................................... 8810 2. Fuel Use Limitations .............................................................................................................................. 9911 3. Monitoring Requirements ..................................................................................................................... 9911 4. Compliance Requirements .................................................................................................................... 9911

F. STATIONARY RECIPROCATING INTERNAL COMBUSTION ENGINES (RICE) NESHAP .................................................. 101012 G. FUEL USE LIMITATIONS ................................................................................................................................ 101012

1. Primary Fuel ...................................................................................................................................... 101012 2. Other Fuel ......................................................................................................................................... 101012 3. Sulfur content ................................................................................................................................... 101012

H. FOSSIL FUEL FIRED INDUSTRIAL AND COMMERCIAL EQUIPMENT PARTICULATE EMISSION STANDARD (BOILERS) ............ 101012 I. STANDARDS OF PERFORMANCE FOR STATIONARY ROTATING MACHINERY (EMERGENCY GENERATOR AND FIRE PUMP) .... 111113 J. PARTICULATE EMISSIONS - OPACITY LIMITS ..................................................................................................... 121214

1. SIP Limitation .................................................................................................................................... 121214 2. Visible Limiting Standard .................................................................................................................. 121214

K. PARTICULATE MATTER REASONABLE PRECAUTIONS........................................................................................... 121214 L. SURFACE STABILIZATION STANDARDS ............................................................................................................. 131315 M. GENERAL MAINTENANCE OBLIGATION............................................................................................................ 161618

5. COMPLIANCE DEMONSTRATION......................................................................................................... 161618

A. TESTING REQUIREMENTS ............................................................................................................................. 161618 1. Wet Scrubbers................................................................................................................................... 161618 2. Evaporation Pond / Process Solution Impoundments ....................................................................... 161618 3. Settler Tanks ..................................................................................................................................... 171719 4. Test Protocol ..................................................................................................................................... 171719 5. Test Notice ........................................................................................................................................ 171719 6. Test Report ....................................................................................................................................... 171719 7. Recurring Testing .............................................................................................................................. 171719

B. COMPLIANCE DEMONSTRATION FOR ICE ENGINES ............................................................................................ 171719 C. REGULAR EMISSIONS MONITORING ............................................................................................................... 181820

1. Non-instrumental Emissions Monitoring - Fuel Burning Equipment, Emergency Generator and Fire Pump Engines. ...................................................................................................................................................... 181820 2. Non-instrumental Emissions Monitoring - Volatile Organic Compounds and Hazardous Air Pollutants 181820 3. Non-instrumental Emissions Monitoring - Sulfuric Acid ................................................................... 181820 4. Non-instrumental Emissions Monitoring – Particulate Matter ........................................................ 181820

D. RECORDKEEPING ........................................................................................................................................ 191921 E. COMPLIANCE REPORTING............................................................................................................................. 191921


2


F. ANNUAL REGULAR COMPLIANCE/COMPLIANCE PROGRESS CERTIFICATION ............................................................ 191921

6. OTHER REPORTING OBLIGATIONS ...................................................................................................... 191921

A. DEVIATIONS FROM PERMIT REQUIREMENTS .................................................................................................... 191921 B. ANNUAL EMISSIONS INVENTORY ................................................................................................................... 202022

7. FEE PAYMENT ..................................................................................................................................... 202022

8. GENERAL CONDITIONS ....................................................................................................................... 202022

A. TERM ....................................................................................................................................................... 202022 B. BASIC OBLIGATION ..................................................................................................................................... 202022 C. DUTY TO SUPPLEMENT APPLICATION .............................................................................................................. 202022 D. RIGHT TO ENTER ........................................................................................................................................ 212123 E. TRANSFER OF OWNERSHIP ........................................................................................................................... 212123 F. POSTING OF PERMIT ................................................................................................................................... 212123 G. PERMIT REVOCATION FOR CAUSE .................................................................................................................. 212123 H. CERTIFICATION OF TRUTH, ACCURACY, AND COMPLETENESS ............................................................................... 212123 I. RENEWAL OF PERMIT .................................................................................................................................. 222224 J. SEVERABILITY ............................................................................................................................................. 222224 K. PERMIT SHIELD .......................................................................................................................................... 222224 L. PERMIT REVISIONS ..................................................................................................................................... 222224 M. PERMIT RE-OPENING .................................................................................................................................. 232325 N. RECORD RETENTION ................................................................................................................................... 232325 O. SCOPE OF LICENSE CONFERRED ..................................................................................................................... 232325 P. EXCESS EMISSION REPORTS; EMERGENCY PROVISION ........................................................................................ 232325

9. FACILITY SPECIFIC DATA ...................................................................................................................... 262628

A. EQUIPMENT .............................................................................................................................................. 262628 1. Production Testing Facility (PTF) ...................................................................................................... 262628 2. Commercial Plant ............................................................................................................................. 262628

B. EMISSION INVENTORY TABLE – POTENTIAL CONTROLLED EMISSIONS .................................................................... 272729

APPENDIX A: SEMI -ANNUAL REPORT .......................................................................................................... 282830


3


1. Introduction

This permit renewal pertains to an existing copper production project, operated by Florence Copper Inc., an

Arizona Corporation. The SIC Code is 1021. The facility is located at 1575 West Hunt Highway, Florence,

Arizona, upon parcels also identified by Pinal County Assessor's Parcel #'s 200-31-019E, 200-31-019F,

200-31-019G, 200-31-054A, 200-31-0550, 200-31-0200, 200-31-054A, 200-38-001A, 200-38-001B, 200-

31-019C and 200-38-0020. The source is situated in an area classified as non-attainment for PM10.

This renewal updates the currently permitted equipment, chemicals, and also authorizes the installation and

operation of the following equipment:

Production Testing Facility (PTF)

-Solvent Extraction Plant (SX Plant)

-Electrowinning Plant (EW Plant)

-Wet Scrubber

-FC-1100 acid mist suppressant

-Demisting balls

-157 HP fire pump engine

Commercial Facility

-Solvent Extraction Plant (SX Plant)

-Electrowinning Plant (EW Plant)

-Boilers (2)

-Wet Scrubbers (2)

-FC-1100 acid mist suppressant

-Demisting balls

-327 HP fire pump engine

-500 kW emergency generator

In-Situ Copper Recovery Process Description (ISCR)

The ISCR well field involves the recovery of copper from the subsurface ore, which is accomplished by

delivering a lixiviant consisting of a weak solution of sulfuric acid and recovering PLS (Pregnant Leach

Solution) using a series of wells. The lixiviant will be pumped to injection wells from the raffinate pond

for the commercial operation, or raffinate tanks for the PTF, via a network of high density polyethylene

piping. The PLS will be extracted from recovery wells by variable speed electric submersible well pumps,

collected in a piping network, and delivered to the PLS pond for the commercial operation, or PLS tanks

for the PTF. Injection and recovery flow rates will be balanced to maintain the hydraulic gradients in the

well field.

Process Ponds Description

The commercial operation includes double-lined, high-density polyethylene (HDPE) ponds for PLS and

raffinate that are designed to provide retention time necessary to provide operational flexibility for both the

SX plant and the ISCR well field. The raffinate pond will be equipped with a pumping system to deliver

lixiviant to the well field, and the PLS pond will be equipped with a pumping system to feed PLS to the SX

plant.

For the PTF, this same functionality is provided by two PLS tanks and two raffinate tanks.


4


Double-lined, HDPE process solution impoundments will be utilized to manage and evaporate excess water

generated by PTF and commercial operations; these impoundments will supplement the capacity of the

existing evaporation pond. At first, a small water neutralization plant will process excess hydraulic control

flows and process solution; the treated water will be evaporated from a process solution impoundment.

Later, a water treatment plant consisting of high density solids treatment with lime neutralization, followed

by low pressure microfiltration and reverse osmosis will commence operations. The flow to the water

treatment plant will be comprised of three primary solution streams. The largest stream will be the rinse

solutions used in the ISCR well field to restore the groundwater to aquifer quality standards after copper

recovery has been completed. The remaining streams will consist of excess water from hydraulic control

pumping around the active well field and low volumes of excess process solutions.

Solvent Extraction Process Description – PTF and Commercial Plant

The commercial SX plant consists of four (4) stages of reverse-flow mixer-settlers. The SX plant is

designed to handle a nominal PLS flow rate of 11,000 gallons per minute (gpm) with a PLS grade of 2

grams of copper per liter (g/L). Three of the SX mixer-settlers are used to extract copper from the PLS in a

series-parallel configuration. These extraction stages selectively transfer the copper from the PLS into an

organic solution containing a copper-specific extractant. In a series-parallel configuration, half of the PLS

passes through two mixer-settlers in series and the other half of the PLS passes through one mixer-settler.

Each set of extraction mixer-settlers is designed with primary, secondary, and tertiary mix tanks to

thoroughly contact the barren organic solution and PLS. The mixing and contact time facilitates transfer of

copper from the PLS solution to the extractant in the organic solution. After the solutions have been

contacted, the mixed solutions are directed to the settlers where the organic and aqueous solutions are

separated. The resulting aqueous solution is adjusted to 10 g/L free acid and transferred to the raffinate

pond for recycling as lixiviant to the ISCR well field.

The fourth SX mixer-settler strips the copper from the loaded organic solution produced in the extraction

stages and transfers the copper to the electrolyte solution. The strip mixer-settler is designed with primary

and secondary mix tanks to contact the lean electrolyte and loaded organic solution. The loaded organic

solution is stripped of its copper by the strongly acidic lean electrolyte. The mixed solutions are then

separated in the settler. The stripped organic solution is re-circulated to the extraction stages to collect more

copper, and the enriched electrolyte solution is routed through the EW filters in the tank farm. The rich

electrolyte solution produced in the strip stage is the feed for the EW plant. Two natural-gas fired boilers

provide process heat to the electrolyte.

The SX plant process for the PTF is similar to that used in the commercial operation, but the scale of the

PTF SX plant is much smaller. The nominal throughput rate for the PTF SX plant is 240 gpm of PLS.

Electrowinning Process Description – PTF and Commercial Plant

The commercial EW plant consists of two parallel banks of fifty (50) EW cells using permanent cathode

blank technology. The filtered and heated electrolyte from the tank farm is pumped through the cells in

parallel. Two rectifiers produce direct electrical current which is passed through the cells in series. The

current flows from the rectifiers through the electrolyte solution in each cell causing the copper from the

electrolyte to plate onto the stainless-steel cathode blank.

As a result of the electrochemical reaction in the EW cells, oxygen gas evolves from the electrolyte,

generating a fine aerosol acid mist as the oxygen gas bubbles break the electrolyte surface. To minimize

acid mist emissions, the EW cells are covered and connected through a ventilation system to two wet

scrubbers. A surfactant and/or demisting balls will be added to the electrolyte to further minimize the


5


amount of mist produced. Additional reagents are also added to the electrolyte to passivate the anode

plates and as a surface modifier for the cathode.

Copper is plated onto the cathode blanks over a cycle of approximately 1 week. When the cathodes are

ready for harvest, they are extracted and carried by crane from the EW cells to an automatic stripping

machine. The stripping machine washes and mechanically removes the copper sheets from each side of the

stainless-steel cathode blank. The cathode blanks are then returned to service and the copper sheets are

weighed, sampled, and bundled for sale.

The process for the PTF EW plant is similar to that used for the commercial operation, but the scale of the

PTF EW plant is much smaller, consisting of four EW cells.

Fire Pump Engines, Boilers, and Emergency Generator

The PTF and commercial operation will each be equipped with a fire suppression water pump that is

powered by a diesel-fueled fire pump engine. Fire suppression water will be available from an onsite

firewater storage tank. Electrolyte at the commercial operation EW plant will be heated by two boilers

fueled by natural gas. Under normal conditions, both boilers will operate at 50 percent capacity, or only

one boiler will be operational at any given time. Both boilers may be operated at full capacity upon cold

start-ups or anytime the electrolyte is below specified temperature. An electric water heater will be used to

heat the PTF electrolyte. A 500 kilowatt (kW), diesel-fueled emergency generator will be acquired for the

commercial operation, to provide emergency backup electrical power.

The source includes equipment to recover copper from ore using the in-situ method. Other equipment

include natural gas fired boilers, fire pump engines, and an emergency generator. A complete list of

equipment from which emissions are allowed by this permit is given in Section §9 of this permit. As an

informational disclosure, emissions listed in the last section of this permit entitled "Emission Inventory

Table” constitute good-faith estimates of emissions subject to regulation, as set forth in the application for

permit.

Since the emergency generator, and the fire pump engines are manufactured after 2006, they are subject to

the Standards of Performance for Stationary Compression Ignition Internal Combustion Engines, 40 CFR

Part 60, Subpart IIII, and National Emission Standard for Hazardous Air Pollutants for Stationary

Reciprocating Internal Combustion Engines, 40 CFR, Part 63, Subpart ZZZZ. The compliance

requirements of Subpart ZZZZ are met by complying with the requirements of Subpart IIII.

The plant has an expected production rate of 85,000,000 pounds of copper per year. The plant’s maximum

capacity is 94,000,000 pounds of copper per year, limited by the electrowinning plant.

Emissions from the facility consists of evaporative losses from the liquid organic phase solution, products

of combustion from the boilers, fire pump engine, and diesel driven emergency generator, sulfuric acid mist

emissions from the electrowinning process, and fugitive dust from access roads. The surfactant used to

minimize sulfuric acid emissions contains volatile organic compounds. The sulfuric acid mist emissions

result from agitation in the electrowinning tanks; in keeping with prevailing standard practice, the operator

will use floating balls, acid suppressant, and wet scrubbers to both retain process heat and to control

emissions.

The process descriptions set forth in this introduction are not enforceable provisions, and are for

informational purposes only.

2. Authority to Construct and Operate


6


[Federally enforceable pursuant to PCAQCD Code §§3-1-010, 3-1-040 (10/12/95) approved as a SIP

element at 65 FR 79742 (12/20/00)]

Emissions from this facility, specifically the equipment described in "Equipment Schedule" Section 9 of

this permitbelow, and the operating configuration more fully described in the application for permit,

already fall are subject to applicable requirements, including the independent Federally Enforceable

limitations identified elsewhere in this permit. Therefore, bBased on the regulations in effect upon the date

of issuance of this permit and a finding that allowable emissions from the equipment described in Section 9

of this permit the Equipment Schedule will not interfere with attainment or maintenance of a national

ambient air quality standard neither cause nor contribute to a violation of any ambient air quality standard

even without any additional limitations, and a further finding that this does not constitute a "major source"

within the meaning of Code §3-3-203, this permit constitutes authority to construct and operate such

equipment.

3. Listing of (Currently Federally Enforceable) Applicable Requirements

A. Those specific provisions of the Pinal-Gila Counties Air Quality Control District ("PGAQCD")

Regulations, as adopted by the Pinal County Board of Supervisors on March 31, 1975, and

approved by the Administrator as elements of the Arizona State Implementation Plan ("SIP") at 43

FR 50531, 50532 (11/15/78), and specifically the following rules are applicable to the various

sections in the permit..

7-3-1.2 Emission Standards - Particulate Emissions - Fugitive Dust

7-3-1.7.A Particulate Emissions - Fuel Burning Equipment

7-3-1.7.B Particulate Emissions - Fuel Burning Equipment

7-3-1.7.C Particulate Emissions - Fuel Burning Equipment

7-3-1.7.D Particulate Emissions - Fuel Burning Equipment

7-3-1.7.E Particulate Emissions - Fuel Burning Equipment

7-3-1.8 Particulate Emissions - Process Industries

B. Those specific provisions of the Pinal-Gila Counties Air Quality Control District Regulations, as

last amended by the Pinal County Board of Supervisors on June 16, 1980, and approved by the

Administrator as elements of the Arizona SIP at 47 FR 15579 (4/12/82), specifically, the

following rules:

7-3-1.1 Visible Emissions; General

7-3-1.7.F Fuel Burning Equipment

4. Emission Limitations and Controls

A. Applicable Limitations

[Federally enforceable pursuant to PCAQCD Code § 3-1-082 (11/3/93) approved as SIP

Elements at 65 FR 79742 (12/20/00)]

Where different standards or limitations apply under this permit, the most stringent combination

shall prevail and be enforceable.

B. Allowable Emissions

[Federally enforceable pursuant to PCAQCD Code § 3-1-040 (10/12/95) approved as SIP

Elements at 65 FR 79742 (12/20/00)]


7


The owner/operator ("Permittee") is authorized to discharge or cause to discharge into the

atmosphere those emissions of air contaminants as set forth in this permit. Unless exempted under

Code §3-2-180, Permittee shall not use any material, process, or equipment not identified in this

permit which will cause emissions of any regulated air pollutant in excess of the 5.5 pound-per-

day de minimis amount, unless authorized by a permit revision as allowed under this permit, or by

a separate permit issued by the District or other competent authority.

C. Limitations and Process Controls - SX and EW Plants

[PCAQCD Code §5-24-1030.A-G (10/13/10); PCAQCD Code §5-24-1032 (2/22/95) approved as

SIP element at 77 FR 22676 (4/17/12); and PGCAQCD §7-3-1.8 (3/31/75) approved as a SIP

element at 43 FR 53034 (11/15/78; and PCAQCD Code §3-1-081.A.2 (9/5/01) approved as SIP

Elements at 66 FR 63166 (12/05/01)]

1. Permittee shall capture, to the maximum practical extent, all particulate matter resulting

from operation of individual equipment comprising the complete process. Permittee not

cause, suffer, allow or permit the discharge of particulate matter into the atmosphere in

any one hour from any existing process source whatsoever, except fuel-burning

equipment, in total quantities in excess of the amount calculated by whichever of the

following equations may be applicable:

a. For any process operating at a production process weight rate ("P") up to 30

tons-per-hour, allowable emissions ("E") shall not exceed:

E = 4.10 P0.67 pounds-per-hour.

b. For any process operating at a production process weight rates ("P") equal to or

greater than 30 tons-per-hour, allowable emissions ("E") shall not exceed:

E = (55.0 P0.11 - 40.0) pounds-per-hour.

c. For purposes of Condition 4.C.1, the total process weight from all similar units

employing a similar type process shall be used in determining the maximum

allowable emission of particulate matter. Emission limit values calculated from

the applicable equations shall be rounded off to two decimal places.

2. Permittee shall, to the maximum practical extent, capture all particulate matter resulting

from operation of individual equipment comprising the complete process. Failure to

control these “Fugitive” emissions in a manner satisfactory to the Control Office, or

which exceed the opacity requirements of Chapter 2, Article 8, will result in a non-

compliance status even though the requirements of Condition 4.C.1 above have been

complied with.

3. Permittee shall not emit gaseous or odorous materials from equipment, operations or

premises under Permittee’s control in such quantities or concentrations as to cause air

pollution.

4. Materials including solvents or other volatile compounds, acids, or alkalies shall be

processed, stored, used and transported in such a manner and by such means that they

will not evaporate, leak, escape or be otherwise discharged into the ambient air so as to

cause or contribute to air pollution. Where means are available to reduce effectively the

contribution to air pollution from evaporation, leakage, or discharge, the installation and

use of such control methods, devices, or equipment shall be mandatory.


8


5. Where a stack, vent or other outlet is at such a level that fumes, gas mist, odor, smoke,

vapor or any combination thereof constituting air pollution are discharged to adjoining

property, the Control Officer may require the installation of abatement equipment or the

alteration of such stack, vent or other outlet by the owner or operator thereof to a degree

that will adequately dilute, reduce or eliminate the discharge of air pollution to adjoining

property.

6. Permittee shall install and maintain covers inherent to the design of the SX plant settler

tanks in the closed position whenever the SX plant is in operation, except as necessary to

conduct inspections, maintenance, and repairs.

7. Permittee shall install and operate wet scrubbers in accordance with good air pollution

control practices whenever the EW plant is in operation.

D. Voluntarily Accepted Emissions Limitations - Sulfuric Acid

[Federally enforceable provision, pursuant to Code §3-1-084 (8/11/94) approved as SIP

Elements at 61 FR 15717 (4/9/96)] (Code §3-1-081.A)

1. Emission Cap

Permittee shall limit emissions, in any consecutive twelve-month period, such that

emissions of sulfuric acid are less than 100 tons.

2. Sulfuric Acid Emissions - Process Controls

Permittee shall use a combination of surfactants, and a full-surface layer of demisting

balls, to suppress sulfuric acid mist emissions from the electrowinning tanks.

3. Potential Emissions

The controls specified in Section §4.C.7 and Section §4.D.2 of this permit the emission

will limit the potential emissions of sulfuric acid mist to 1 40 percent of the emission cap

defined above [For informational purposes only, not an enforceable limit].

E. Stationary Compression Ignition Internal Combustion Engines NSPS

[Federally enforceable provision, pursuant to 40 CFR Part 60 Subpart IIII]

1. Emission Standards

[Federally enforceable provision, pursuant to 40 CFR §§ 60.4202(a)(2), 60.4205(c) and

(c), 60.4206, 60.4211(c)]

a. Permittee shall comply with the following emissions standards of 40

CFR § 89.112(a) and the smoke emission standards of 40 CFR 89.113

for the 500 kW emergency generator:

NMHC+NOx CO PM

4.0 3.5 0.20

All emissions standards are in units of grams/kW-hour.


9


Smoke emission standards:

Exhaust opacity as measured by the manufacturer must not exceed

20 percent during acceleration mode

15 percent during lugging mode; and

50 percent during the peaks in either acceleration or lugging modes

b. Permittee shall complypurchase a unit that complies with the following

emissions standards of 40 CFR Part 60 Subpart III Table 4 for the fire

pump engines:

Maximum

Engine Power NMHC + NOx CO PM

157 BHP 3.0 3.7 0.22

327 BHP 3.0 2.6 0.15

All emissions standards are in units of grams/HP-hour.

c. Permittee shall comply with the emission standards listed in this

Condition E.1 over the entire life of the engine.

2. Fuel Use Limitations

[Federally enforceable provision, pursuant to 40 CFR § 60.4207(b)]

Permittee shall only use diesel fuel for the 500 kW emergency generator and fire pump

engines meeting the requirements of 40 CFR §80.510(b), which requires that diesel fuel

shall:

a. Have a maximum sulfur content of 15 parts per million (ppm);

b. Either a minimum cetane index of 40 or a maximum aromatic content of 35

volume percent.

3. Monitoring Requirements

[Federally enforceable provision, pursuant to 40 CFR § 60.4209]

Install a non-resettable hour meter for each emergency stationary compression ignition

internal combustion engine (ICE) if one is not already installed.

4. Compliance Requirements

[Federally enforceable provision, pursuant to 40 CFR § 60.4211(a) and (f)]

a. Permittee shall operate and maintain each stationary compression ignition ICE

and control device according to the manufacturer's emission-related written

instructions.

b. Permittee shall change only those emission-related settings that are permitted by

the manufacturer.

c. There is no time limit on the use of emergency stationary ICE in emergency

situations.

d. Emergency stationary ICE may be operated for a maximum of 100 hours per

calendar year for maintenance checks and readiness testing, provided that the


10


tests are recommended by federal, state or local government, the manufacturer,

the vendor, the regional transmission organization or equivalent balancing

authority and transmission operator, or the insurance company associated with

the engine.

e. Emergency stationary ICE may be operated for up to 50 hours per calendar year

in non-emergency situations. The 50 hours of operation in non-emergency

situations are counted as part of the 100 hours per calendar year for maintenance

and testing.

f. The 50 hours per calendar year for non-emergency situations cannot be used for

peak shaving or non-emergency demand response, or to generate income for a

facility to an electric grid or otherwise supply power as part of a financial

arrangement with another entity.

F. Stationary Reciprocating Internal Combustion Engines (RICE) NESHAP

[Federally enforceable provision, pursuant to 40 CFR 63 Subpart ZZZZ]

As specified by 40 CFR § 63.6590(c)(1), the 500 kW emergency generator and fire pump engines

must meet the requirements of 40 CFR 63 Subpart ZZZZ by meeting the requirements of 40 CFR

Part 60 Subpart IIII.

G. Fuel Use Limitations

1. Primary Fuel

(Code §3-1-081.A.2)

The Permittee is allowed to burn natural gas in the boiler and diesel fuel in the emergency

generator and the fire pump engines.

2. Other Fuel

(Code §3-1-081.A.2)

Permittee shall not use hazardous waste and hazardous waste fuel as defined in Codes

§§3-1-081.G, 5-23-1010.F without first obtaining a separate permit or an appropriate

permit revision.

3. Sulfur content

(Code §5-23-1010.F)

Permittee shall not burn diesel fuel containing 0.90 percent or more sulfur by weight.

H. Fossil Fuel Fired Industrial and Commercial Equipment Particulate Emission Standard (boilers)

1. Permittee shall not cause, allow or permit the emission of particulate matter, caused by

combustion of fuel in the boilers, in excess of the amounts calculated by one of the

following equations:

(Code §5-21-930)

a. For equipment having a heat input rate of 4200 million Btu/hr or less, the

maximum allowable emissions shall be determined by the following equation:


11


E = 1.02Q0.769

where:

E = the maximum allowable particulate emissions rate in pounds-mass per hour.

Q = the total heat input of all operating fuel-burning units on a plant or premises

in million Btu/hr.

b. For equipment having a heat input rate greater than 4200 million Btu/hr, the


E = 17.0Q0.432

Where “E” and “Q” have the same meaning as in paragraph (a) of this condition.

c. For purposes of Condition 4.K.1, the heat input shall be the aggregate heat

content of all fuel whose products of combustion pass through a stack or other

outlet. The heat input value used shall be the equipment manufacturer or

designer’s guaranteed maximum input, whichever is greater. The total heat

input of all fuel-burning units on a plant or premises shall be used for

determining the maximum allowable amount of particulate matter which may be

emitted.

2. Permittee shall not cause, suffer, allow or permit the emission of particulate matter,

caused by combustion of fuel, from any fuel-burning operation in excess of the amounts

calculated by one of the following equations:

[Federally enforceable provision, pursuant to PGCAQCD Code §7-3-1.7 (8/7/80)

approved as SIP Elements at 47 FR 15580 (4/12/82)]

a. For equipment having a heat input greater than 10 but less than 4,000 million

BTUs per hour, the maximum allowable emissions shall be determined by the

following equation:

Y = 1.02X-0.231

where:

X = maximum equipment capacity rate in million BTUs per hour.

Y = allowable rate of emission in pounds per million BTUs.

b. For equipment having a heat input greater than 4,000 million BTUs per hour, the


Y = 17.0X0.568

Where “X” and “Y” have the same meaning as in paragraph (a) of this

condition.

I. Standards of Performance for Stationary Rotating Machinery (emergency generator and fire

pump)

(Code §5-23-1010 and Code §5-23-1015)

1. For equipment having a heat input rate of 4200 million Btu/hr. or less, the maximum

allowable emissions shall be determined by the following equation:

E = 1.02*Q0.769

Where: E = the maximum allowable particulate emissions rate in pounds-mass per hour


12


Q = the total heat input of all operating fuel burning units on a plant premises in million

btu/hr

2. For equipment having a heat input rate greater than 4200 million Btu/hr or less, the


E = 17.0*Q0.432

Where: E = the maximum allowable particulate emissions rate in pounds-mass per hour

Q = the total heat input of all operating fuel burning units on a plant premises in million

btu/hr

3. For references purposes only, the actual values shall be calculated from the

applicable equations and rounded off to two decimal places.

4. No person shall cause, allow or permit to be emitted into the atmosphere from any

stationary rotating machinery, smoke for any period greater than 10 consecutive seconds

which exceeds 40% opacity. Visible emissions when starting cold equipment shall be

exempt from this requirement for the first 10 minutes.

5. When low sulfur oil is fired, stationary rotating machinery installations shall burn fuel

which limits the emission of sulfur dioxide to 1.0 pound per million Btu heat input.

6. Engines which are used for emergency power generator or for fire-suppression water

pumps shall be exempt from the requirements of Code §5-23-1010 if they are no larger

than 325 horsepower and are used less than 72 hours per year.

J. Particulate Emissions - Opacity Limits

1. SIP Limitation

[Federally enforceable pursuant to PGAQCD Reg. 7-3-1.1 (8/7/80) approved as a SIP

element at 47 FR 15580 (4/12/82)]

The opacity of any plume or effluent shall not be greater than 40 percent as determined

by Reference Method 9 in the Arizona Testing Manual (ADEQ, 1992). Nothing in this

limitation shall be interpreted to prevent the discharge or emission of uncontaminated

aqueous steam, or uncombined water vapor, to the open air.

2. Visible Limiting Standard

[Federally enforceable pursuant to Code §2-8-300 (5/18/05) approved as a SIP element

at 71 FR 15043 (3/27/06)]

The opacity of any plume or effluent from any point source not subject to a New Source

Performance Standard adopted under Chapter 6 of the Code, and not subject to an opacity

standard in Chapter 5 of the Code, shall not be greater than 20% as determined in Method

9 in 40 CFR Part 60, Appendix A.

K. Particulate Matter Reasonable Precautions

[Currently federally enforceable pursuant to Code §4-2-040 (6/29/93) approved as a SIP

element at 72 FR 41896 (8/1/07) and PGAQD Reg. 7-3-1.2 approved as a SIP element at 43 FR

53034 (11/15/78)


13


1. Permittee shall not cause, suffer, allow, or permit a building or its appurtenances,

subdivision site, driveway, parking area, vacant lot or sales lot, or an urban or suburban

open area to be constructed, used, altered, repaired, demolished, cleared, or leveled, or

the earth to be moved or excavated, or fill dirt to be deposited, without taking reasonable

precautions to effectively prevent fugitive dust from becoming airborne.

2. Permittee shall not cause, suffer, allow, or permit a vacant lot, or an urban or suburban

open area, to be driven over or used by motor vehicles, such as but not limited to all-

terrain vehicles, trucks, cars, cycles, bikes, or buggies, without taking reasonable


3. Permittee shall not disturb or remove soil or natural cover from any area without taking

reasonable precautions to effectively prevent fugitive dust from becoming airborne.

4. Permittee shall not crush, screen, handle or convey materials or cause, suffer, allow or

permit material to be stacked, piled or otherwise stored without taking reasonable


5. Stacking and reclaiming machinery utilized at storage piles shall be operated at all times

with a minimum fall of material and in such a manner, or with the use of spray bars and

wetting agents, as to prevent excessive amounts of particulate matter from becoming

airborne. Other reasonable precautions shall be taken, as necessary, to effectively

prevent fugitive dust from becoming airborne.

6. Permittee shall not cause, suffer, allow or permit transportation of materials likely to give

rise to fugitive dust without taking reasonable precautions to prevent fugitive dust from

becoming airborne. Earth and other material that is tracked out or transported by

trucking and earth moving equipment on paved streets shall be removed by the party or

person responsible for such deposits.

L. Surface Stabilization Standards

[Federally enforceable pursuant to Code §4-1-030 (10/28/15) approved as a SIP element at 82

FR 20267 (5/1/17)

1. Open Areas/Vacant Lots

a. Visible Emissions and Stabilization Requirements: The owner and/or operator of

open areas/vacant lots shall not cause, suffer, allow, or permit fugitive dust

emissions which result in opacity of the dust to exceed twenty percent (20%) as

measured using an opacity method, as determined by the applicable test method

in §4-9-340 or an equivalent test method approved in writing by the Control

Officer and the EPA Administrator.

b. Upon evidence of trespass in open areas/vacant lots, an owner and/or operator

shall install and maintain one of the following:

i. No trespassing signs

ii. Physical barriers such as curbs, fences, gates, posts, shrubs, trees, or

other effective control measures to effectively prevent access to the

open areas/vacant lots.


14


a.c. Owners and/or operators of open areas/vacant lots 1.0 acre (43,560 square feet)

or larger and have a cumulative of 0.5 acre (21,780 square feet) or more

disturbed surface area shall implement at least one control measure described

below on the disturbed surface area in order to stabilize:

i. Apply and maintain water or dust suppressants; or

ii. Establish vegetation; or

iii. Install and maintain pavement; or

iv. Apply and maintain gravel uniformly; or

v. Apply and maintain chemical/organic stabilizers/suppressants; or

vi. Apply and maintain an alternative control measure approved in writing

by the Control Officer and the EPA Administrator.

d. For open areas/vacant lots 1.0 acre (43,560 square feet) or larger and have a

cumulative of 0.5 acre (21,780 square feet) or more disturbed surface area,

within 30 calendar days following the initial discovery of the disturbed surface

area on the open areas/vacant lots, the owner and/or operator shall sign up to

receive the Pinal County dust control forecast. The owner and/or operator shall

ensure the open areas/vacant lots is stabilized the day leading up to and the day

that is forecast to be high risk for dust emissions, as noticed by the Pinal County

dust control forecast.

e. No person shall remove vegetation from any open areas/vacant lots by blading,

disking, plowing under or any other means without implementing all of the

following control measures to prevent or minimize fugitive dust.

i. Apply a dust suppressant(s) to the total surface area subject to the

disturbance immediately prior to or during the weed abatement.

ii. Prevent or eliminate material track out onto paved surfaces and access

points adjoining paved surfaces through one of the control measures in

4-1-030.5.A.i.

iii. Apply a dust suppressant(s), gravel, compaction or an alternative

control measure immediately following weed abatement to the entire

disturbed surface area such that the surface is stabilized.

a.f. Compliance with the stabilization requirement in paragraphs C, D and E shall be

determined by one of the following:

i. Observation of a visible crust as determined by the drop ball test in

Article 9 (§4- 9-320.B.1); or

ii. A Threshold Friction Velocity (TFV), corrected for non-erodible

elements of 100 cm/second or higher as determined by the test method

in Article 9 (§4-9-320.B.2); or


15


iii. Flat vegetation cover equal to at least 50 percent as determined by the

test method in Article 9 (§4-9-320.B.3); or

iv. Standing vegetation cover equal to or greater than 30 percent as

determined by the test method in Article 9 (§4-9-320.B.4); or

v. Standing vegetation cover equal to or greater than 10 percent as

determined by the test method in Article 9 (§4-9-320.B.4) where

threshold friction velocity, corrected for non-erodible elements, is equal

to or greater than 43 cm/second.

2. Unpaved Lots

a. The owner and/or operator of an unpaved lot greater than 5,000 square feet in

size shall be subject to the requirements described in 4-1-030.3.A.i and shall

comply with at least one of the control measures described in 4-1-030.3.A.ii:

i. Visible Emissions Requirements and Stabilization Requirements: The

owner and/or operator of an unpaved lot shall not cause or allow visible

fugitive dust emissions to exceed 20% opacity as measured using an

opacity method, as determined by the applicable test method in §4-9-

340 or an equivalent test method approved in writing by the Control

Officer and the EPA Administrator, and shall not allow silt loading

equal to or greater than 0.33 oz/ft2 as determined by the applicable test

method in §4-9-320.A.1. However, if silt loading is equal to or greater

than 0.33 oz/ft2 , then the owner and/or operator shall not allow the silt

content to exceed 8% ;

ii. Control Measures:

a. Pave; or

b. Apply dust suppressant in sufficient quantity and frequency to

maintain a stabilized surface; or

c. Apply and maintain surface gravel uniformly such that the

surface is stabilized; or d. Apply and maintain an alternative

control measure approved in writing by the Control Officer

and the EPA Administrator.

b. Control measure(s) in 4-1-030.3.A.ii shall be considered effectively

implemented when the unpaved lot meets the requirements of 4-1-030.3.A.i.

3. Paved Public Roadway

a. Clean up of trackout, Erosion-Caused Deposition of Bulk Materials on paved

public roadway: the owner and/or operator of the property from which the track

out or erosion caused deposition came from shall upon discovery of mud/dirt

that extends 50 feet or more from the nearest unpaved surface exit onto the

paved public roadway shall:


16


i. Within 24 hours of discovery, remove the mud/dirt from paved public

roadway with one of the following control measures. (If needed, restrict

vehicles from traveling over said mud/dirt until such time as the

material can be removed from the travel lanes of the paved public

roadway)

a. Manually sweeping and picking up; or

b. Operating a rotary brush or broom accompanied or preceded

by sufficient wetting to limit opacity to 20% or less; or

c. Operating a PM10 efficient street sweeper; or

d. Flushing with water, if curb and gutters are not present and

where the use of water will not result as a source of track out

material or result in adverse impacts on storm water drainage

systems or violate any National Pollutant Discharge

Elimination System permit program.

ii. During removal of mud/dirt, do so in a manner that does not cause

another source of fugitive dust.

iii. In the event unsafe travel conditions would result from restricting

traffic pursuant to section A.i and removal of such material isn’t

possible within 72 hours due to a weekend or holiday condition, the

provisions of section A.i can be extended upon notification to and

approval by the Control Officer.

M. General Maintenance Obligation

(Code §§3-1-081.A.2)

At all times, including periods of start-up, shutdown, and malfunction, owners and operators shall,

to the extent practicable, maintain and operate the permitted facility including associated air

pollution control equipment in a manner consistent with good air pollution control practice for

minimizing emissions.

5. Compliance Demonstration

A. Testing Requirements

[Federally enforceable pursuant to Code §6-1-030.43 and 40 CFR §§60.380-386 Codes §3-1-

083.A.1.b (2/22/95) and §3-1-170 (11/3/93) approved as a SIP element at 65 FR 79742

(12/20/00)]

1. Wet Scrubbers

Within 60 days after achieving the maximum production rate at which the facility

will be operated, but not later than 180 days after initial startup of the Production Test

Facility and the Commercial Facility, Permittee shall conduct a performance test on each

wet scrubber using standard EPA Test Method 8 to quantify emissions of the sulfuric acid

mist. Test shall be performed at the maximum practical production rate.

2. Evaporation Pond / Process Solution Impoundments


17


Within 60 days after achieving the maximum production rate at which the facility will be

operated, but not later than 180 days after initial startup of the Production Test Facility

and the Commercial Facility, an analysis of the organic compounds content of filtered

samples of the evaporation pond and Process Solution Impoundments water shall be

conducted using standard EPA test methods to determine VOC concentration. Results

from this analysis shall be used to calculate emissions from all the other process solution

impoundments.

3. Settler Tanks

Within 60 days after achieving the maximum production rate at which the facility will be

operated, but not later than 180 days after initial startup of the Production Test Facility

and the Commercial Facility, Permittee shall use the following methods to quantify

VOCs and HAPs emissions from the settler tanks:

a. EPA Method 320 (FTIR) shall be used to determine concentration HAP

concentration data above the settler tanks.

b. EPA Methods 18, 25, 25A or 25B (option 1) or Method TO-15 (option 2) shall

be used to determine VOC concentration data above the settler tanks.

c. The Diffusive Flux calculation technique may then be used to quantify VOC and

HAP emissions from the settler tanks.

d. As allowed by PCAQCD Code 3-1-160.D alternative o equivalent test methods

may be approved by the Control Officer.

e. Results from this analysis shall be used to calculate emissions.

4. Test Protocol

A test plan protocol for the tests shall be submitted to the District at least sixty (60) days

before the testing.

5. Test Notice

Notice of the tests required by this permit shall be submitted to the District at least 14

days prior to running the test.

6. Test Report

A copy of the test reports shall be submitted to the District for approval within forty-five

days after the tests.

7. Recurring Testing

Permittee shall conduct performance tests within five years of the previous performance

tests as listed in Section §5.A.1 and §5.A.2 of this permit.

B. Compliance Demonstration for ICE Engines

[Federally enforceable provision, pursuant to 40 CFR § 60.4211(c)]


18


Permittee shall comply with the emission standards set forth in Condition 4.E by purchasing an

engine certified by the manufacturer to the referenced emission standards. The engine must be

installed and configured according to the manufacturer's emission-related specifications.

C. Regular Emissions Monitoring

1. Non-instrumental Emissions Monitoring - Fuel Burning Equipment, Emergency

Generator and Fire Pump Engines.

[Federally Enforceable pursuant to Code §3-1-083.A.1.b (2/22/95) approved as a SIP

element at 65 FR 79742 (12/20/00)] (Code §3-1-083.A.1.b)

Permittee shall maintain records of:

a. Natural gas purchased for the boiler;

b. Verification from the fuel supplier that diesel fuel for the engine does not

contain more than 15 ppm sulfur by weight; and

c. The number of emergency and non-emergency hours the emergency generator

and the fire pump engines operate.

2. Non-instrumental Emissions Monitoring - Volatile Organic Compounds and Hazardous

Air Pollutants


element at 65 FR 79742 (12/20/00)] (Code §3-1-083.A.1.b)

Permittee shall maintain a logbook, updated at least monthly, clearly showing records of:

a. Amount of organic extractants used during the extraction process;

b. Amount of surfactants used during the extraction process; and

c. Amount of demisting balls used during the electrowinning process.

3. Non-instrumental Emissions Monitoring - Sulfuric Acid

[Federally enforceable provision, pursuant to Code §3-1-084 (8/11/94) approved as SIP

Elements at 61 FR 15717 (4/9/96)] [[Federally enforceable provision, pursuant to Code

§3-1-084.3 (8/11/94)]

a. Permittee shall calculate and maintain records of sulfuric acid emissions

monthly, based on the sulfuric acid emission rate as determined by the

performance testing.

4. Non-instrumental Emissions Monitoring – Particulate Matter


element at 65 FR 79742 (12/20/00)]

a. Within 90 days of the issuance of this permit, Permittee shall prepare an

Operation and Maintenance Plan (O&M) Plan for the wet scrubbers. Permittee

shall operate and maintain the scrubbers in accordance with the O&M Plan.


19


D. Recordkeeping

[Federally enforceable provision, pursuant to Code §3-1-084 (8/11/94)] (Code §3-1-

083)[Federally Enforceable pursuant to Code §3-1-084 (8/11/94) approved as a SIP element at

6165 FR 15717 (4/9/96)]

Permittee shall maintain records of:

All information required pursuant to any federally enforceable provision of this permit, recorded

in a permanent form suitable for inspection.

E. Compliance Reporting

[Federally enforceable provision, pursuant to Code §3-1-084 (8/11/94)] (Code §3-1-

083.A)[Federally Enforceable pursuant to Code §3-1-083.A.3 (2/22/95) approved as a SIP

element at 65 FR 79742 (12/20/00)] [Federally enforceable provision, pursuant to Code §3-1-

084 (8/11/94) approved as SIP Elements at 61 FR 15717 (4/9/96)]

In order to demonstrate compliance with the provisions of this permit, the permittee shall submit a

semi-annual report containing a summary of the information required to be recorded pursuant to

this permit, which summary shall clearly show that permittee has complied with the operational

and emissions limitations under this permit. All instances of deviations from permit requirements

shall be clearly identified in such reports. For brevity, such deviation reports may incorporate by

reference any written supplemental upset reports filed by Permittee during the reporting period.

The report shall be submitted to the District within 30 days after the end of each calendar half.

Appendix A of this permit is a form which may be used for the report.

F. Annual Regular Compliance/Compliance Progress Certification

[Federally Enforceable pursuant to Code §3-1-083.A.4 (2/22/95) approved as a SIP element at

65 FR 79742 (12/20/00)](Code §3-1-083.A.4.)

Permittee shall annually submit a certification of compliance with the provisions of this permit.

The certification shall:

1. Be signed by a responsible official, namely the proprietor, a general partner, the

president, secretary, treasurer or vice-president of the corporation, or such other person as

may be approved by the Control Officer as an administrative amendment to this permit;

2. Identify each term or condition of the permit that is the basis of the certification;

3. Verify the compliance status with respect to each such term or condition;

4. Verify whether compliance with respect to each such term or condition has been

continuous or intermittent;

5. Identify the permit provision, or other, compliance mechanism upon which the

certification is based; and

6. Be postmarked within thirty (30) days of the start of each calendar year.

6. Other Reporting Obligations

A. Deviations from Permit Requirements


20


[Federally Enforceable pursuant to Code §3-1-081.A.5.b (9/5/01) approved as a SIP element at

66 FR 63166 (12/5/01) and Code §3-1-083.A.3.b (2/22/95) approved as a SIP element at 65 FR

79742 (12/20/00)](Code §3-1-081.A.5.b.)

Permittee shall report any deviation from the requirements of this permit along with the probable

cause for such deviation, and any corrective actions or preventative measures taken to the District

within ten days of the earlier of date the Permittee learned, or should have learned, of the deviation

unless earlier notification is required by the provisions of this permit.

B. Annual Emissions Inventory

[Federally Enforceable pursuant to Code §3-1-103 (2/22/95) approved as a SIP element at 65

FR 79742 (12/2/00)] [Code §3-1-103. (Nov. '93)]

Permittee shall complete and submit to the District an annual emissions inventory, disclosing

actual emissions for the preceding calendar year. Submittal of the form set forth in Appendix A of

this permit by January 30th of each year fulfills this requirement.

7. Fee Payment

(Code 3-7-600)

As an essential obligation under this permit, a permit fee shall be assessed by the District and paid by

Permittee in accord with the provisions of Code Chapter 3, Article 7, as they may exist at the time the fee is

due. The permit fee shall be due annually on or before the anniversary date of the issuance of an individual

permit, or formal grant of approval to operate under a general permit, or at such other time as may be

designated now or hereafter by rule. The District will notify the Permittee of the amount to be due, as well

as the specific date on which the fee is due.

8. General Conditions

A. Term

(Code §3-1-089)

This permit shall have a term of five (5) years, measured from the date of issuance.

B. Basic Obligation

(Code §3-1-081.)

Permittee shall operate in compliance with all conditions of this permit, the Pinal County Air

Quality Control District ("the District") Code of Regulations ("Code"), and all State and Federal

laws, statutes, and codes relating to air quality that apply to these facilities. Any permit

noncompliance is grounds for enforcement action; for a permit termination, revocation and

reissuance, or revision; or for denial of a permit renewal application and may additionally

constitute a violation of the CAA.

C. Duty to Supplement Application

(Code §§3-1-050.H., 3-1-081.A.8.e., 3-1-087.A.1.c., 3-1-110.)

Even after the issuance of this permit, a Permittee, who as an applicant who failed to include all

relevant facts, or who submitted incorrect information in an application, shall, upon becoming

aware of such failure or incorrect submittal, promptly submit a supplement to the application,

correcting such failure or incorrect submittal. In addition, Permittee shall furnish to the District

within thirty days any information that the Control Officer may request in writing to determine


21


whether cause exists for modifying, revoking and reissuing, or terminating this permit or to

determine compliance with this permit and/or the Code.

D. Right to Enter

(Code §§ 3-1-132, 8-1-050)

Authorized representatives of the District shall, upon presentation of proper credentials and a

showing that the District representative is equipped with certain safety equipment, namely a hard

hat, be allowed:

1. To enter upon the premises where the source is located or in which any records are

required to be kept under the terms and conditions of this permit;

2. To inspect any equipment, operation, or method required in this permit; and

3. To sample emissions from the source.

E. Transfer of Ownership

(Code §3-1-090)

This permit may be transferred from one person to another by notifying the District at least 30

days in advance of the transfer. The notice shall contain all the information and items required by

Code § 3-1-090. The transfer may take place if not denied by the District within 10 days of the

receipt of the transfer notification.

F. Posting of Permit

(Code §3-1-100)

Permittee shall firmly affix the permit, an approved facsimile of the permit, or other approved

identification bearing the permit number, upon such building, structure, facility or installation for

which the permit was issued. In the event that such building, structure, facility or installation is so

constructed or operated that the permit cannot be so placed, the permit shall be mounted so as to

be clearly visible in an accessible place within a reasonable distance of the equipment or

maintained readily available at all times on the operating premises.

G. Permit Revocation for Cause

(Code §3-1-140)

The Director of the District ("Director") may revoke this permit for cause, which cause shall

include occurrence of any of the following:

1. The Director has reasonable cause to believe that the permit was obtained by fraud or

material misrepresentation;

2. Permittee failed to disclose a material fact required by the permit application form or a

regulation applicable to the permit;

3. The terms and conditions of the permit have been or are being violated.

H. Certification of Truth, Accuracy, and Completeness

(Code § 3-1-175.)


22


Any application form, report, or compliance certification submitted pursuant to the Code shall

contain certification by a responsible official of truth, accuracy, and completeness. This

certification and any other certification required under Chapter 3 of the Code shall state that, based

on information and belief formed after reasonable inquiry, the statements and information in the

document are true, accurate, and complete.

I. Renewal of Permit

(Code §3-1-089)

Expiration of this permit will terminate the facility’s right to operate unless either a timely

application for renewal has been submitted in accordance with §§3-1-050, 3-1-055 and 3-1-060, or

a substitute application for a general permit under §3-5-490. For Class I permit renewals, a timely

application is one that is submitted at least 6 months, but not greater than 18 months prior to the

date of the permit expiration. For Class II or Class III permit renewals, a timely application is one

that is submitted at least 3 months, but not greater than 12 months prior to the date of permit

expiration.

J. Severability

(Code §3-1-081.A.7)

The provisions of this permit are severable, and if any provision of this permit is held invalid the

remainder of this permit shall not be affected thereby.

K. Permit Shield

(Code §§3-1-081.A.8.b, 3-1-102)(Code § 3-1-102.)

1. Compliance with the terms of this permit shall be deemed compliance with any

applicable requirement identified in this permit.

2. It shall not be a defense for a permittee in an enforcement action that it would have been

necessary to halt or reduce the permitted activity in order to maintain compliance with the

conditions of this permit.

L. Permit Revisions

(Code Chapter 3, Article 2)

1. This permit may be revised, reopened, revoked and reissued, or terminated for cause.

Other than as expressly provided in Code Chapter 3, Article 2, the filing of a request by

the permittee for a permit revision, revocation and reissuance, or termination, or of a

notification of planned changes or anticipated noncompliance does not stay any permit

condition.

2. The permittee shall furnish to the Control Officer, within a reasonable time, any

information that the Control officer may request in writing to determine whether cause

exists for revising, revoking and reissuing, or terminating the permit or to determine

compliance with the permit.

3. Permit amendments, permit revisions, and changes made without a permit revision shall

conform to the requirements in Article 2, Chapter 3, of the Code.

4. Should this source become subject to a standard promulgated by the Administrator

pursuant to CAA §112(d), then Permittee shall, within twelve months of the date on


23


which the standard is promulgated, submit an application for a permit revision

demonstrating how the source will comply with the standard. (Code §3-1-050.C.5)

5. Revision to Permit Provisions Designated as Federally Enforceable Pursuant to Code §3-

1-084 [Federally enforceable provision, pursuant to Code §3-1-084 (8/11/94)]

As an express condition of preserving the federal enforceability of any provision of this

permit designated "federally enforceable" pursuant to Code §3-1-084, Permittee shall not

make any facility allowed change that would contravene such provision, until thirty (30)

days after the Permittee has previously furnished notice of the proposed change to the

District and to the Administrator, to thereby allow the Administrator opportunity to

comment upon the continued "federal enforceability" of the subject provision after the

proposed change.

M. Permit Re-opening

(Code §3-1-087.)

1. This permit shall be reopened if either:

a. The Control Officer determines that it contains a material mistake or

that inaccurate statements were made in establishing the emissions

standards or other terms or conditions of it;

b. The Control Officer determines that it needs to be revised or revoked to

assure compliance with the applicable requirements; or

c. The EPA makes a material objection to any of those federally

enforceable designations under Code §3-1-084 after the normal EPA

review period is ended.

2. If this permit must be reopened or revised, the District will notify the permittee

in accord with Code §3-1-087.A.3.

N. Record Retention

(Code §3-1-083.A.2.b)

Permittee shall retain for a period of five (5) years all documents required under this permit,

including reports, monitoring data, support information, calibration and maintenance records, and

all original recordings or physical records of required continuous monitoring instrumentation.

O. Scope of License Conferred

(Code §3-1-081.A.8.d)

This permit does not convey any property rights of any sort, or any exclusive privilege.

P. Excess Emission Reports; Emergency Provision

(Code §3-1-081.E, Code §8-1-030)

1. To the extent Permittee may wish to offer a showing in mitigation of any potential

penalty, underlying upset events resulting in excess emissions shall reported as follows:


24


a. The permittee shall report to the Control Officer any emissions in excess of the

limits established by this permit. Such report shall be in two parts:

i. Notifications by telephone or facsimile within 24 hours or the next

business day, whichever is later, of the time when the owner or

operator first learned of the occurrence of excess emissions, including

all available information required under subparagraph b. below.

ii. Detailed written notification within 3 working days of the initial

occurrence containing the information required under subparagraph b.

below.

b. The excess emissions report shall contain the following information:

i. The identity of each stack or other emission point where the excess

emissions occurred.

ii. The magnitude of the excess emissions expressed in the units of the

applicable limitation.

iii. The time and duration or expected duration of the excess emissions.

iv. The identity of the equipment from which the excess emissions

occurred.

v. The nature and cause of such emissions.

vi. If the excess emissions were the result of a malfunction, steps taken to

remedy the malfunction and the steps taken or planned to prevent the

recurrence of such malfunctions.

vii. The steps that were or are being taken to limit the excess emissions. To

the extent this permit defines procedures governing operations during

periods of start-up or malfunction, the report shall contain a list of steps

taken to comply with this permit.

viii. To the extent excess emissions are continuous or recurring, the initial

notification shall include an estimate of the time the excess emissions

will continue. Continued excess emissions beyond the estimated date

will require an additional notification.

2. An "emergency" means any situation arising from sudden and reasonably unforeseeable

events beyond the control of the source, including acts of God, which situation requires

immediate corrective action to restore normal operation, and that causes the source to

exceed a technology-based emission limitation under the permit, due to unavoidable

increases in emissions attributable to the emergency. An emergency shall not include

noncompliance to the extent caused by improperly designed equipment, lack of

preventative maintenance, careless or improper operation, or operator error.

3. An emergency constitutes an affirmative defense to an action brought for noncompliance

with such technology-based emission limitations if the conditions of the following

subparagraph are met.


25


4. The affirmative defense of emergency shall be demonstrated through properly signed,

contemporaneous operating logs, or other relevant evidence that:

a. An emergency occurred and that the permittee can identify the cause(s) of the

emergency;

b. The permitted facility was at the time being properly operated;

c. During the period of emergency the permittee took all reasonable steps to

minimize levels of emissions that exceeded the emissions standards or other

requirements in the permit; and

d. The permittee submitted notice of the emergency to the Control Officer by

certified mail or hand delivery within 2 working days of the time when

emissions limitations were exceeded due to emergency. The notice shall contain

a description of the emergency, any steps taken to mitigate emissions, and

corrective action taken.


26


9. Facility Specific Data

A. Equipment

Equipment for which emissions are allowed by this permit are as follows:

1. Production Testing Facility (PTF)

Equipment Equipment ID Make/Mfg. Date Maximum Capacity

SX Plant PTF-SX-1 N/A 300 gpm PLS

EW Plant PTF-EW-1 N/A 1.8 million lbs./yr.

copper

Fire Pump Engine FBE-1 2016 157 BHP

SX Plant - settle

covers

EW Plant - wet

scrubber

PTF-EWS-1 Viron VVS-14

FRP-0.5-60-S-1-B-

460-3-60,

500 cfm

EW Plant – acid mist

suppressant

3M FC-1100

EW Plant – demisting

balls

TBD

2. Commercial Plant

Equipment Equipment ID Make/Mfg. Date Maximum Capacity

SX Plant C-SX-1 N/A 13,000 gpm PLS

EW Plant C-EW-1 N/A 94 million lbs./yr.

copper

Boiler #1 (natural gas) FBE-2 Parker T6800 or equivalent 6.87 mm btu/hr

Boiler #2 (natural gas) FBE-3 Parker T6800 or equivalent 6.87 mm btu/hr

Fire Pump Engine

(diesel)

FBE-4 Clarke JW6H-UFADF0 (or

equivalent)

327 BHP

Emergency Generator

(diesel)

FBE-5 2007 or later 500 kW

SX Plant - settle covers

EW Plant - wet

scrubber

C-EWS-1 TBD 15,000 cfm

EW Plant - wet

scrubber

C-EWS-2 TBD 15,000 cfm

EW Plant – acid mist

suppressant

3M FC-1100

EW Plant – demisting

balls

TBD


27


B. Emission Inventory Table – Potential Controlled Emissions

(For information only, not enforceable limits)

ID Source Pollutants Emission Rate

(Tons/Yr.)

1 Electrowinning Sulfuric Acid (H2SO4 – a subset of

PM10) 0.3

Hazardous Air Pollutants (HAPs) <0.1

2 Solvent Extraction Volatile Organic Compounds (VOCs) 6.2

Hazardous Air Pollutants (HAPs) 3.1

3 Boilers Nitrogen Oxides (NOX) 8.6

Carbon Monoxide (CO) 9.8

Particulate Matter (PM10) 0.7

Sulfur Oxides (SOX) 0.1

Volatile Organic Compounds (VOCs) 0.3

4 Emergency Generator Nitrogen Oxides (NOX) 0.8



5 Fire Pump Engines Nitrogen Oxides (NOX) 3.8


Particulate Matter (PM10) 0.3

Sulfur Oxides (SOX) 0.3


6 Roads Particulate Matter (PM10) 3.8


28


Appendix A: Semi -annual Report

Permit B31219.000

Abstract

This constitutes a semi-annual report, documenting emissions and use of emission-generating materials during

the subject reporting period.

Facility - Florence Copper Inc.

1575 West Hunt Hwy, Florence, AZ

Reporting Period - January-June Or July-December Year___________

Material Report

Organic extractants & diluents used - gallons

Surfactant used - gallons

De-misting balls used - ________ pounds

Sulfuric acid emissions - lb/ft2-hr

Scrubbers Report

Were the scrubbers operated in accordance with the O&M Plan as listed in Section §5.C.3.b of this permit?

Yes______ No_______

Fuel Report

Natural gas purchased - therms (from the bills)

Diesel fuel used - ____________ gallons

Generator and Fire Pump Engines Report

Operational hours of the 500 kW generator - ____________ hours

Operational hours of the 327 BHP fire pump engine - ____________ hours

Operational hours of the 157 BHP fire pump engine - ____________ hours

ICE Compliance Report

Did the purchased generator and the fire pump engines meet the requirements of emission standards as specified

in Section §4.E of this permit? Yes_______ No______

Were the fuel requirements for the affected generator and the fire pump engines met as specified in Sections

§4.JE.2.3 and §4.G of this permit? Yes_______ No_______


29


Were the records of hours of operation for the generator and the fire pump engines under the limits

listedmaintained as required under Section §4.E.45.C.1.c of this permit maintained?

(100 hours maintenance / 50 hours non-emergency)

Yes________ No______

Were the generators used for non-emergency situations? Yes______ No______

If yes, how many hours_____________________

Fuel Report

Were fuel verifications from the supplier maintained as required under Section §5.C.1.b of this permit?

Yes_______ No______

Testing Report

Was the performance testing of the wet scrubbers performed as required under Section §5.A.1 of this permit?

(Within 180 days of startup of the PTF or commercial facility or within the last 5 years)

Yes______ No______

If yes, please list the most recent test date__________________________

Was the testing on the evaporation ponds analysis conducted as required under Section §5.A.2 of this permit?

(Within 180 days of startup of the PTF or commercial facility or within the last 5 years)

Yes_____ No_____


Was the testing on the settler tanks conducted as required under Section §5.A.3 of this permit?

Yes_____ No_____


Certification by Responsible Official I certify that, based on information and belief formed after reasonable inquiry, that the statements and

information in this report are true, accurate and complete.

Signed_____________________________

Printed Name________________________

Title________________________________

Date Contact Phone Number________________

Mail to - Pinal County Air Quality Control District

P.O. Box 987

Florence, AZ 85132

FLORENCE COPPER INC. - FLORENCE Copper... · (12/11/17) FLORENCE COPPER PROJECT - FLORENCE FLORENCE COPPER INC. - FLORENCE 1. ... machine. The stripping ...

Documents