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
S:\Word\PERMITS\Permit.b\B31219.AJ_KGW.doc PERMIT #B31219.000
2
(12/11/17) FLORENCE COPPER PROJECT - FLORENCE
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
S:\Word\PERMITS\Permit.b\B31219.AJ_KGW.doc PERMIT #B31219.000
3
(12/11/17) FLORENCE COPPER PROJECT - FLORENCE
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.
S:\Word\PERMITS\Permit.b\B31219.AJ_KGW.doc PERMIT #B31219.000
4
(12/11/17) FLORENCE COPPER PROJECT - FLORENCE
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
S:\Word\PERMITS\Permit.b\B31219.AJ_KGW.doc PERMIT #B31219.000
5
(12/11/17) FLORENCE COPPER PROJECT - FLORENCE
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
S:\Word\PERMITS\Permit.b\B31219.AJ_KGW.doc PERMIT #B31219.000
6
(12/11/17) FLORENCE COPPER PROJECT - FLORENCE
[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)]
S:\Word\PERMITS\Permit.b\B31219.AJ_KGW.doc PERMIT #B31219.000
7
(12/11/17) FLORENCE COPPER PROJECT - FLORENCE
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.
S:\Word\PERMITS\Permit.b\B31219.AJ_KGW.doc PERMIT #B31219.000
8
(12/11/17) FLORENCE COPPER PROJECT - FLORENCE
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.
S:\Word\PERMITS\Permit.b\B31219.AJ_KGW.doc PERMIT #B31219.000
9
(12/11/17) FLORENCE COPPER PROJECT - FLORENCE
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
S:\Word\PERMITS\Permit.b\B31219.AJ_KGW.doc PERMIT #B31219.000
10
(12/11/17) FLORENCE COPPER PROJECT - FLORENCE
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:
S:\Word\PERMITS\Permit.b\B31219.AJ_KGW.doc PERMIT #B31219.000
11
(12/11/17) FLORENCE COPPER PROJECT - FLORENCE
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
maximum allowable emissions shall be determined by the following equation:
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
maximum allowable emissions shall be determined by the following equation:
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
S:\Word\PERMITS\Permit.b\B31219.AJ_KGW.doc PERMIT #B31219.000
12
(12/11/17) FLORENCE COPPER PROJECT - FLORENCE
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
maximum allowable emissions shall be determined by the following equation:
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)
S:\Word\PERMITS\Permit.b\B31219.AJ_KGW.doc PERMIT #B31219.000
13
(12/11/17) FLORENCE COPPER PROJECT - FLORENCE
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
precautions to effectively prevent fugitive dust from becoming airborne.
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
precautions to effectively prevent fugitive dust from becoming airborne.
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.
S:\Word\PERMITS\Permit.b\B31219.AJ_KGW.doc PERMIT #B31219.000
14
(12/11/17) FLORENCE COPPER PROJECT - FLORENCE
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
S:\Word\PERMITS\Permit.b\B31219.AJ_KGW.doc PERMIT #B31219.000
15
(12/11/17) FLORENCE COPPER PROJECT - FLORENCE
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:
S:\Word\PERMITS\Permit.b\B31219.AJ_KGW.doc PERMIT #B31219.000
16
(12/11/17) FLORENCE COPPER PROJECT - FLORENCE
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
S:\Word\PERMITS\Permit.b\B31219.AJ_KGW.doc PERMIT #B31219.000
17
(12/11/17) FLORENCE COPPER PROJECT - FLORENCE
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)]
S:\Word\PERMITS\Permit.b\B31219.AJ_KGW.doc PERMIT #B31219.000
18
(12/11/17) FLORENCE COPPER PROJECT - FLORENCE
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
[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 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
[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)]
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.
S:\Word\PERMITS\Permit.b\B31219.AJ_KGW.doc PERMIT #B31219.000
19
(12/11/17) FLORENCE COPPER PROJECT - FLORENCE
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
S:\Word\PERMITS\Permit.b\B31219.AJ_KGW.doc PERMIT #B31219.000
20
(12/11/17) FLORENCE COPPER PROJECT - FLORENCE
[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
S:\Word\PERMITS\Permit.b\B31219.AJ_KGW.doc PERMIT #B31219.000
21
(12/11/17) FLORENCE COPPER PROJECT - FLORENCE
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.)
S:\Word\PERMITS\Permit.b\B31219.AJ_KGW.doc PERMIT #B31219.000
22
(12/11/17) FLORENCE COPPER PROJECT - FLORENCE
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
S:\Word\PERMITS\Permit.b\B31219.AJ_KGW.doc PERMIT #B31219.000
23
(12/11/17) FLORENCE COPPER PROJECT - FLORENCE
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:
S:\Word\PERMITS\Permit.b\B31219.AJ_KGW.doc PERMIT #B31219.000
24
(12/11/17) FLORENCE COPPER PROJECT - FLORENCE
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.
S:\Word\PERMITS\Permit.b\B31219.AJ_KGW.doc PERMIT #B31219.000
25
(12/11/17) FLORENCE COPPER PROJECT - FLORENCE
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.
S:\Word\PERMITS\Permit.b\B31219.AJ_KGW.doc PERMIT #B31219.000
26
(12/11/17) FLORENCE COPPER PROJECT - FLORENCE
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
S:\Word\PERMITS\Permit.b\B31219.AJ_KGW.doc PERMIT #B31219.000
27
(12/11/17) FLORENCE COPPER PROJECT - FLORENCE
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
Carbon Monoxide (CO) 0.2
Volatile Organic Compounds (VOCs) 1.1
5 Fire Pump Engines Nitrogen Oxides (NOX) 3.8
Carbon Monoxide (CO) 0.8
Particulate Matter (PM10) 0.3
Sulfur Oxides (SOX) 0.3
Volatile Organic Compounds (VOCs) 0.3
6 Roads Particulate Matter (PM10) 3.8
S:\Word\PERMITS\Permit.b\B31219.AJ_KGW.doc PERMIT #B31219.000
28
(12/11/17) FLORENCE COPPER PROJECT - FLORENCE
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_______
S:\Word\PERMITS\Permit.b\B31219.AJ_KGW.doc PERMIT #B31219.000
29
(12/11/17) FLORENCE COPPER PROJECT - FLORENCE
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_____
If yes, please list the most recent test date__________________________
Was the testing on the settler tanks conducted as required under Section §5.A.3 of this permit?
Yes_____ No_____
If yes, please list the most recent test date__________________________
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