AIR QUALITY CLASS I PERMIT 

COMPANY: Freeport-McMoRan Corporation 

FACILITY: Freeport-McMoRan Miami, Incorporated 

PERMIT #: 53592 

DATE ISSUED: November 26, 2012 

EXPIRY DATE: November 25, 2017 

SUMMARY 

This Title V permit is issued to Freeport-McMoRan Miami, Inc., the Permittee, for the continued operation of 

their smelter located off of Hwy 60 in Claypool, Arizona. This permit renews and supersedes Permit No. 

1000046 (as revised by Significant Permit Revision No. 29622). 

Freeport-McMoRan Miami, Inc. operates a copper smelting facility in Claypool, AZ. The facility consists of an 

IsaSmelt Furnace, Electric Furnace, Five (5) Converters (Four Hoboken and one Inspiration), Anode Furnace and 

Utility Vessels, Electrolytic Refinery, Rod Plant, Acid Plant, and other support equipment. 

The facility is classified as a Major Source pursuant to A.A.C. R18-2-101.61. The potential emission rates of the 

following pollutants are greater than major source thresholds: (i) particulate matter with an aerodynamic diameter 

less than 10 microns, (ii) sulfur dioxide, (iii) nitrogen oxides, (iv) carbon monoxide, and (v) hazardous air 

pollutants. 

This permit is issued in accordance with Title 49, Chapter 3 of the Arizona Revised Statutes. All definitions, 

terms, and conditions used in this permit conform to those in the Arizona Administrative Code R18-2-101 

(A.A.C) and 40 Code of Federal Regulations (CFR). All terms and conditions of this permit are enforceable by 

the Administrator of the USEPA.

Permit No. 53592 Page 1 of 97 November 26, 2012 
TABLE OF CONTENTS 

ATTACHMENT “A”: GENERAL PROVISIONS................................................... ...........................4 

I. PERMIT EXPIRATION AND RENEWAL................................................................................4 

II. COMPLIANCE WITH PERMIT CONDITIONS .........................................................................4 

III. PERMIT REVISION, REOPENING, REVOCATION ANR REISSUANCE, OR 

 TERMINATION FOR CAUSE..............................................................................................4 

IV. POSTING OF PERMIT.......................................................................................................5 

V. FEE PAYMENT................................................................................................................5 

VI. ANNUAL EMISSION INVENTORY QUESTIONNAIRE.................................... .........................5 

VII. COMPLINACE CERTIFICATION ................................................................ .........................5 

VIII. CERTIFICATION OF TRUTH, ACCURACY, AND COMPLETENESS................... .........................6 

IX. INSPECTION AND ENTRY........................................................................ .........................6 

X. PERMIT REVISION PURSUANT TO FEDERAL HAZARDOUS AIR POLLUTANT

 STANDARD....................................................................................................................6 

XI. ACCIDENTAL RELEASE PROGRAM....................................................................................7 

XII. EXCESS EMISSIONS, PERMIT DEVIATIONS, AND EMERGENCY REPORTING............................7 

XIII. RECORD KEEPING REQUIREMENTS......................................................... ........................11 

XIV. REPORTING REQUIREMENTS.................................................................. ........................11 

XV. DUTY TO PROVIDE INFORMATION..................................................................................12 

XVI. PERMIT AMENDMENT OR REVISION................................................................................12 

XVII. FACILITY CHANGE WITHOUR REVISION................................................. ........................12 

XVIII. TESTING REQUIREMENTS..............................................................................................13 

XIX. PROPERTY RIGHTS........................................................................................................14 

XX. SEVERABILITY CLAUSE......................................................................... ........................14 

XXI. PERMIT SHIELD.............................................................................................................15 

XXII. PROTECTION OF STRATSPHERIC ZONE............................................................................15 

ATTACHMENT “B” FACILITY WIDE REQUIREMENTS..................................... ..........................16 

I. GENERAL REQUIREMENTS ...................................................................................................16 

II. FEED LIMITATIONS ........... .................................................................................................................23 

III. MATERIAL HANDLING AND BEDDING PLANT.............................................................................23 

IV. PROCESS GASES FROM ACID PLANT TAIL STACK...................................... .......................25 

V. CAPTURED FUGITIVES-VENT FUME STACK...................................... ..................................30 

VI. SMELTER FUGITIVES...................................... ...........................................................................37 

VII. MULTIPOINT ROLLBACK RULE...............................................................................................45 

VIII. GENERAL PROVISIONS FOR CEM SYSTEMS.........................................................................49 

IX. CONVERTERS ARSENIC CHARGING RATE...................................... .....................................52 

X. ANODE FURNCES AND UTILITY VESSEL ...................................... .......................................53 

Permit No. 53592 Page 2 of 97 November 26, 2012 
XI. BOILERS/HEATERS IN SMELTER ....................................................... ...............................54 

XII. SCREENING MACHINE ....................................................... .................................................55 

XIII. ELECTROLYTIC REFINERY ....................................................... .........................................57 

XIIV. ROD PLANT ............................................................................................................................59 

XV. MISC. STORAGE TANKS ......................................................................................................62 

XVI. GASOLINE STORAGE TANK ...............................................................................................63 

XVII. DIESEL ENGINES....................................................... ............................................................64 

XVIII. COOLING TOWERS..................................................................................................................................72 

XIX. FUGITIVE DUST SOURCES............. .......................................................................................................73 

XX. MOBILE SOURCE REQUIREMENTS............. ........................................................................................75 

XXI. OTHER PERIODIC ACTIVITY REQUIREMENTS.................................................................................76 

XXII. AMBIENT MONITORING REQUIREMENTS............................................ ..............................79 

ATTACHMENT “C”............. ................................................................................................................................85 

ATTACHMENT “D”: SULFUR BALANCE METHODOLOGY............. .......................................................86 

ATTACHMENT “E”: DUST CONTROL PLAN............. ..................................................................................90 

ATTACHMENT “F”: OPERATION & MAINT. PLAN............ .......................................................................91 

ATTACHMENT “G”: EQUIPMENT LIST........................................................................................................93 

Permit No. 53592 Page 3 of 97 November 26, 2012 
ATTACHMENT “A”: GENERAL PROVISIONS 

AIR QUALITY CONTROL PERMIT NO. 53592 

FOR 

FREEPORT-MCMORAN MIAMI, INC. 

I. PERMIT EXPIRATION AND RENEWAL [ARS § 49-426.F, A.A.C. R18-2-304.C.2, and -306.A.1] 

A. This permit is valid for a period of five years from the date of issuance. 

B. The Permittee shall submit an application for renewal of this permit at least 6 months, but not 

more than 18 months, prior to the date of permit expiration. 

II. COMPLIANCE WITH PERMIT CONDITIONS [A.A.C. R18-2-306.A.8.a and b]

A. The Permittee shall comply with all conditions of this permit including all applicable 

requirements of the Arizona air quality statutes and air quality rules. Any permit noncompliance 

constitutes a violation of the Arizona Revised Statutes and is grounds for enforcement action; for 

permit termination, revocation and reissuance, or revision; or for denial of a permit renewal 

application. In addition, noncompliance with any federally enforceable requirement constitutes a 

violation of the Clean Air Act. 

B. 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. 

III. PERMIT REVISION, REOPENING, REVOCATION AND REISSUANCE, OR TERMINATION 

FOR CAUSE [A.A.C. R18-2-306.A.8.c, -321.A.1, and -321.A.2]

A. The permit may be revised, reopened, revoked and reissued, or terminated for cause. The filing 

of a request by the Permittee for a permit revision, revocation and reissuance, termination, or of a 

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

B. The permit shall be reopened and revised under any of the following circumstances: 

1. Additional applicable requirements under the Clean Air Act become applicable to the 

Class I source. Such a reopening shall only occur if there are three or more years 

remaining in the permit term. The reopening shall be completed no later than 18 months 

after promulgation of the applicable requirement. No such reopening is required if the 

effective date of the requirement is later than the date on which the permit is due to 

expire, unless an application for renewal has been submitted pursuant to A.A.C. R18-2-

322.B. Any permit revision required pursuant to this subparagraph shall comply with the 

provisions in A.A.C. R18-2-322 for permit renewal and shall reset the five-year permit 

term. 

2. Additional requirements, including excess emissions requirements, become applicable to 

an affected source under the acid rain program. Upon approval by the Administrator, 

excess emissions offset plans shall be deemed to be incorporated into the Class I permit. 

3. The Director or the Administrator determines that the permit contains a material mistake 

or that inaccurate statements were made in establishing the emissions standards or other 

terms or conditions of the permit. 

4. The Director or the Administrator determines that the permit needs to be revised or 

revoked to assure compliance with the applicable requirements. 

Permit No. 53592 Page 4 of 97 November 26, 2012 
C. Proceedings to reopen and reissue a permit, including appeal of any final action relating to a 

permit reopening, shall follow the same procedures as apply to initial permit issuance and shall, 

except for reopenings under Condition III.B.1 above, affect only those parts of the permit for 

which cause to reopen exists. Such reopenings shall be made as expeditiously as practicable. 

Permit reopenings for reasons other than those stated in Condition III.B.1 above shall not result in 

a resetting of the five-year permit term. 

IV. POSTING OF PERMIT [A.A.C. R18-2-315]

A. The Permittee shall post this permit or a certificate of permit issuance where the facility is located 

in such a manner as to be clearly visible and accessible. All equipment covered by this permit 

shall be clearly marked with one of the following: 

1. Current permit number; or 

2. Serial number or other equipment ID number that is also listed in the permit to identify 

that piece of equipment. 

B. A copy of the complete permit shall be kept on site. 

V. FEE PAYMENT [A.A.C. R18-2-306.A.9 and -326]

The Permittee shall pay fees to the Director pursuant to ARS § 49-426(E) and A.A.C. R18-2-326. 

VI. ANNUAL EMISSION INVENTORY QUESTIONNAIRE [A.A.C. R18-2-327.A and B]

A. The Permittee shall complete and submit to the Director an annual emissions inventory 

questionnaire. The questionnaire is due by March 31st or ninety days after the Director makes 

the inventory form available each year, whichever occurs later, and shall include emission 

information for the previous calendar year. 

B. The questionnaire shall be on a form provided by the Director and shall include the information 

required by A.A.C. R18-2-327. 

VII. COMPLIANCE CERTIFICATION [A.A.C. R18-2-309.2.a, -309.2.c-d, and -309.5.d]

A. The Permittee shall submit a compliance certification to the Director twice each year, which 

describes the compliance status of the source with respect to each permit condition. The first 

certification shall be submitted no later than April 15th, and shall report the compliance status of 

the source during the period between September 1st of the previous year, and February 28th or 29th

of the current year. The second certification shall be submitted no later than October 15th, and 

shall report the compliance status of the source during the period between March 1st and August 

31st of the current year. 

The compliance certifications shall include the following: 

1. Identification of each term or condition of the permit that is the basis of the certification; 

2. Identification of the methods or other means used by the Permittee for determining the 

compliance status with each term and condition during the certification period; 

3. The status of compliance with the terms and conditions of the permit for the period 

covered by the certification, including whether compliance during the period was 

continuous or intermittent. The certification shall be based on the methods or means 

Permit No. 53592 Page 5 of 97 November 26, 2012 
designated in Condition VII.A.2 above. The certifications shall identify each deviation 

and take it into account for consideration in the compliance certification; 

4. For emission units subject to 40 CFR Part 64, the certification shall also identify as 

possible exceptions to compliance any period during which compliance is required and in 

which an excursion or exceedance defined under 40 CFR Part 64 occurred; 

5. All instances of deviations from permit requirements reported pursuant to Condition 

XII.B of this Attachment; and 

6. Other facts the Director may require to determine the compliance status of the source. 

B. A copy of all compliance certifications shall also be submitted to the EPA Administrator. 

C. If any outstanding compliance schedule exists, a progress report shall be submitted with the semiannual compliance certifications required in Condition VII.A above. 

VIII. CERTIFICATION OF TRUTH, ACCURACY AND COMPLETENESS [A.A.C. R18-2-309.3]

Any document required to be submitted by this permit, including reports, shall contain a certification by a 

responsible official of truth, accuracy, and completeness. This certification shall state that, based on 

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

are true, accurate, and complete. 

IX. INSPECTION AND ENTRY [A.A.C. R18-2-309.4]

Upon presentation of proper credentials, the Permittee shall allow the Director or the authorized 

representative of the Director to: 

A. Enter upon the Permittee’s premises where a source is located, emissions-related activity is 

conducted, or where records are required to be kept under the conditions of the permit; 

B. Have access to and copy, at reasonable times, any records that are required to be kept under the 

conditions of the permit; 

C. Inspect, at reasonable times, any facilities, equipment (including monitoring and air pollution 

control equipment), practices, or operations regulated or required under the permit; 

D. Sample or monitor, at reasonable times, substances or parameters for the purpose of assuring 

compliance with the permit or other applicable requirements; and 

E. Record any inspection by use of written, electronic, magnetic and photographic media. 

X. PERMIT REVISION PURSUANT TO FEDERAL HAZARDOUS AIR POLLUTANT 

STANDARD [A.A.C. R18-2-304.C.4]

If this source becomes subject to a standard promulgated by the Administrator pursuant to Section 112(d) 

of the Act, then the Permittee shall, within twelve months of the date on which the standard is 

promulgated, submit an application for a permit revision demonstrating how the source will comply with 

the standard. 

Permit No. 53592 Page 6 of 97 November 26, 2012 
XI. ACCIDENTAL RELEASE PROGRAM [40 CFR Part 68]

If this source becomes subject to the provisions of 40 CFR Part 68, then the Permittee shall comply with 

these provisions according to the time line specified in 40 CFR Part 68. 

XII. EXCESS EMISSIONS, PERMIT DEVIATIONS, AND EMERGENCY REPORTING 

A. Excess Emissions Reporting [A.A.C. R18-2-310.01.A and -310.01.B] 

1. Excess emissions shall be reported as follows: 

a. The Permittee shall report to the Director any emissions in excess of the limits 

established by this permit. Such report shall be in two parts as specified below: 

i. Notification by telephone or facsimile within 24 hours of the time when 

the Permittee first learned of the occurrence of excess emissions 

including all available information from Condition XII.A.1.b below. 

ii. Detailed written notification by submission of an excess emissions report 

within 72 hours of the notification pursuant to Condition XII.A.1.a.i. 

above. 

b. The report shall contain the following information: 

i. Identity of each stack or other emission point where the excess emissions 

occurred; 

ii. Magnitude of the excess emissions expressed in the units of the 

applicable emission limitation and the operating data and calculations 

used in determining the magnitude of the excess emissions; 

iii. Date, time and duration, or expected duration, of the excess emissions; 

iv. Identity of the equipment from which the excess emissions emanated; 

v. 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; and 

vii. Steps taken to limit the excess emissions. If the excess emissions 

resulted from start-up or malfunction, the report shall contain a list of the 

steps taken to comply with the permit procedures. 

2. In the case of continuous or recurring excess emissions, the notification requirements of 

this section shall be satisfied if the source provides the required notification after excess 

emissions are first detected and includes in such notification an estimate of the time the 

excess emissions will continue. Excess emissions occurring after the estimated time 

period, or changes in the nature of the emissions as originally reported, shall require 

additional notification pursuant to Condition XII.A.1 above. 

[A.A.C. R18-2-310.01.C] 

Permit No. 53592 Page 7 of 97 November 26, 2012 
B. Permit Deviations Reporting 

1. The Permittee shall promptly report deviations from permit requirements, including those 

attributable to upset conditions as defined in the permit, the probable cause of such 

deviations, and any corrective actions or preventive measures taken. Except as specified 

in Conditions I.C.8.d and XVII.C.1.d(1)(b) of Attachment “B”, prompt reporting shall 

mean that the report was submitted to the Director by certified mail, facsimile, or hand 

delivery within two working days of the time when emission limitations were exceeded 

due to an emergency or within two working days of the time when the owner or operator 

first learned of the occurrence of a deviation from a permit requirement. 

 [A.A.C. R18-2-306.A.5.b]

2. All instances of deviations from permit requirements shall be clearly identified in the 

required semiannual monitoring report specified in Condition I.B of Attachment “B” and 

shall be certified by the responsible official. [A.A.C. R18-2-306.A.5.a]

C. Emergency Provision [A.A.C. R18-2-306.E]

1. An “emergency” means any situation arising from sudden and reasonable unforeseeable 

events beyond the control of the source, including acts of God, that require 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. 

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

with such technology-based emission limitations if Condition XII.C.3 is met. 

3. 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 being properly operated at the time; 

c. During the period of the 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 Director by certified 

mail, facsimile, or hand delivery within two working days of the time when 

emission limitations were exceeded due to the emergency. This notice shall 

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

and corrective action taken. 

4. In any enforcement proceeding, the Permittee seeking to establish the occurrence of an 

emergency has the burden of proof. 

5. This provision is in addition to any emergency or upset provision contained in any 

applicable requirement. 

Permit No. 53592 Page 8 of 97 November 26, 2012 
D. Compliance Schedule [ARS § 49-426.I.5]

For any excess emission or permit deviation that cannot be corrected within 72 hours, the 

Permittee is required to submit a compliance schedule to the Director within 21 days of such 

occurrence. The compliance schedule shall include a schedule of remedial measures, including 

an enforceable sequence of actions with milestones, leading to compliance with the permit terms 

or conditions that have been violated. 

E. Affirmative Defenses for Excess Emissions Due to Malfunctions, Startup, and Shutdown 

[A.A.C. R18-2-310] 

1. Applicability 

This rule establishes affirmative defenses for certain emissions in excess of an emission 

standard or limitation and applies to all emission standards or limitations except for 

standards or limitations: 

a. Promulgated pursuant to Sections 111 or 112 of the Act; 

b. Promulgated pursuant to Titles IV or VI of the Clean Air Act; 

c. Contained in any Prevention of Significant Deterioration (PSD) or New Source 

Review (NSR) permit issued by the U.S. EPA; 

d. Contained in A.A.C. R18-2-715.F; or 

e. Included in a permit to meet the requirements of A.A.C. R18-2-406.A.5. 

2. Affirmative Defense for Malfunctions 

Emissions in excess of an applicable emission limitation due to malfunction shall 

constitute a violation. When emissions in excess of an applicable emission limitation are 

due to a malfunction, the Permittee has an affirmative defense to a civil or administrative 

enforcement proceeding based on that violation, other than a judicial action seeking 

injunctive relief, if the Permittee has complied with the reporting requirements of A.A.C. 

R18-2-310.01 and has demonstrated all of the following: 

a. The excess emissions resulted from a sudden and unavoidable breakdown of 

process equipment or air pollution control equipment beyond the reasonable 

control of the Permittee; 

b. The air pollution control equipment, process equipment, or processes were at all 

times maintained and operated in a manner consistent with good practice for 

minimizing emissions; 

c. If repairs were required, the repairs were made in an expeditious fashion when 

the applicable emission limitations were being exceeded. Off-shift labor and 

overtime were utilized where practicable to ensure that the repairs were made as 

expeditiously as possible. If off-shift labor and overtime were not utilized, the 

Permittee satisfactorily demonstrated that the measures were impracticable; 

d. The amount and duration of the excess emissions (including any bypass 

operation) were minimized to the maximum extent practicable during periods of 

such emissions; 

Permit No. 53592 Page 9 of 97 November 26, 2012 
e. All reasonable steps were taken to minimize the impact of the excess emissions 

on ambient air quality; 

f. The excess emissions were not part of a recurring pattern indicative of inadequate 

design, operation, or maintenance; 

g. During the period of excess emissions there were no exceedances of the relevant 

ambient air quality standards established in Title 18, Chapter 2, Article 2 of the 

Arizona Administrative Code that could be attributed to the emitting source; 

h. The excess emissions did not stem from any activity or event that could have 

been foreseen and avoided, or planned, and could not have been avoided by 

better operations and maintenance practices; 

i. All emissions monitoring systems were kept in operation if at all practicable; and 

j. The Permittee's actions in response to the excess emissions were documented by 

contemporaneous records. 

3. Affirmative Defense for Startup and Shutdown 

a. Except as provided in Condition XII.E.3.b below, and unless otherwise provided

for in the applicable requirement, emissions in excess of an applicable emission 

limitation due to startup and shutdown shall constitute a violation. When 

emissions in excess of an applicable emission limitation are due to startup and 

shutdown, the Permittee has an affirmative defense to a civil or administrative 

enforcement proceeding based on that violation, other than a judicial action 

seeking injunctive relief, if the Permittee has complied with the reporting 

requirements of A.A.C. R18-2-310.01 and has demonstrated all of the following: 

i. The excess emissions could not have been prevented through careful and 

prudent planning and design; 

ii. If the excess emissions were the result of a bypass of control equipment, 

the bypass was unavoidable to prevent loss of life, personal injury, or 

severe damage to air pollution control equipment, production equipment, 

or other property; 

iii. The air pollution control equipment, process equipment, or processes 

were at all times maintained and operated in a manner consistent with 

good practice for minimizing emissions; 

iv. The amount and duration of the excess emissions (including any bypass 

operation) were minimized to the maximum extent practicable during 

periods of such emissions; 

v. All reasonable steps were taken to minimize the impact of the excess 

emissions on ambient air quality; 

vi. During the period of excess emissions there were no exceedances of the 

relevant ambient air quality standards established in Title 18, Chapter 2, 

Article 2 of the Arizona Administrative Code that could be attributed to 

the emitting source; 

Permit No. 53592 Page 10 of 97 November 26, 2012 
vii. All emissions monitoring systems were kept in operation if at all 

practicable; and 

viii. Contemporaneous records documented the Permittee’s actions in 

response to the excess emissions. 

b. If excess emissions occur due to a malfunction during routine startup and 

shutdown, then those instances shall be treated as other malfunctions subject to

Condition XII.E.2 above. 

4. Affirmative Defense for Malfunctions during Scheduled Maintenance 

If excess emissions occur due to a malfunction during scheduled maintenance, then those 

instances will be treated as other malfunctions subject to Condition XII.E.2 above. 

5. Demonstration of Reasonable and Practicable Measures 

For an affirmative defense under Condition XII.E.2 or XII.E.3 above, the Permittee shall 

demonstrate, through submission of the data and information required by Condition XII.E 

and A.A.C. R18-2-310.01, that all reasonable and practicable measures within the 

Permittee’s control were implemented to prevent the occurrence of the excess emissions. 

XIII. RECORD KEEPING REQUIREMENTS [A.A.C. R18-2-306.A.4]

A. The Permittee shall keep records of all required monitoring information including, but not limited 

to, the following: 

1. The date, place as defined in the permit, and time of sampling or measurements; 

2. The date(s) analyses were performed; 

3. The name of the company or entity that performed the analyses; 

4. A description of the analytical techniques or methods used; 

5. The results of such analyses; and 

6. The operating conditions as existing at the time of sampling or measurement. 

B. The Permittee shall retain records of all required monitoring data and support information for a 

period of at least 5 years from the date of the monitoring sample, measurement, report, or 

application. Support information includes all calibration and maintenance records and all original 

strip-chart recordings or other data recordings for continuous monitoring instrumentation, and 

copies of all reports required by the permit. 

C. All required records shall be maintained either in an unchangeable electronic format or in a 

handwritten logbook utilizing indelible ink. 

XIV. REPORTING REQUIREMENTS [A.A.C. R18-2-306.A.5.a]

The Permittee shall submit the following reports:

A. Compliance certifications in accordance with Section VII of Attachment “A”. 

Permit No. 53592 Page 11 of 97 November 26, 2012 
B. Excess emission; permit deviation, and emergency reports in accordance with Section XII of 

Attachment “A”. 

C. Other reports required by any condition of Attachment “B”. 

XV. DUTY TO PROVIDE INFORMATION 

A. The Permittee shall furnish to the Director, within a reasonable time, any information that the 

Director 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. Upon request, 

the Permittee shall also furnish to the Director copies of records required to be kept by the permit. 

For information claimed to be confidential, the Permittee shall furnish an additional copy of such 

records directly to the Administrator along with a claim of confidentiality. [A.A.C. R18-2-306.A.8.e]

B. If the Permittee has failed to submit any relevant facts or has submitted incorrect information in 

the permit application, the Permittee shall, upon becoming aware of such failure or incorrect 

submittal, promptly submit such supplementary facts or corrected information. [A.A.C. R18-2-304.G]

XVI. PERMIT AMENDMENT OR REVISION [A.A.C. R18-2-318, -319, and -320]

The Permittee shall apply for a permit amendment or revision for changes to the facility which do not 

qualify for a facility change without revision under Section XVII, as follows: 

A. Administrative Permit Amendment (A.A.C. R18-2-318); 

B. Minor Permit Revision (A.A.C. R18-2-319); and 

C. Significant Permit Revision (A.A.C. R18-2-320). 

The applicability and requirements for such action are defined in the above referenced regulations. 

XVII. FACILITY CHANGE WITHOUT A PERMIT REVISION [A.A.C. R18-2-317]

A. The Permittee may make changes at the permitted source without a permit revision if all of the 

following apply: 

1. The changes are not modifications under any provision of Title I of the Act or under ARS 

§ 49-401.01(24); 

2. The changes do not exceed the emissions allowable under the permit whether expressed 

therein as a rate of emissions or in terms of total emissions; 

3. The changes do not violate any applicable requirements or trigger any additional 

applicable requirements; 

4. The changes satisfy all requirements for a minor permit revision under A.A.C. R18-2-

319.A; and 

5. The changes do not contravene federally enforceable permit terms and conditions that are 

monitoring (including test methods), record keeping, reporting, or compliance 

certification requirements. 

B. The substitution of an item of process or pollution control equipment for an identical or 

substantially similar item of process or pollution control equipment shall qualify as a change that 

Permit No. 53592 Page 12 of 97 November 26, 2012 
does not require a permit revision, if it meets all of the requirements of Conditions XVII.A and 

XVII.C of this Attachment. 

C. For each change under Conditions XVII.A and XVII.B above, a written notice by certified mail 

or hand delivery shall be received by the Director and the Administrator a minimum of 7 working 

days in advance of the change. Notifications of changes associated with emergency conditions, 

such as malfunctions necessitating the replacement of equipment, may be provided less than 7 

working days in advance of the change, but must be provided as far in advance of the change as 

possible or, if advance notification is not practicable, as soon after the change as possible. 

D. Each notification shall include: 

1. When the proposed change will occur; 

2. A description of the change; 

3. Any change in emissions of regulated air pollutants; and 

4. Any permit term or condition that is no longer applicable as a result of the change. 

E. The permit shield described in A.A.C. R18-2-325 shall not apply to any change made under this 

Section. 

F. Except as otherwise provided for in the permit, making a change from one alternative operating

scenario to another as provided under A.A.C. R18-2-306.A.11 shall not require any prior notice 

under this Section. 

G. Notwithstanding any other part of this Section, the Director may require a permit to be revised for 

any change that, when considered together with any other changes submitted by the same source 

under this Section over the term of the permit, do not satisfy Condition XVII.A above. 

XVIII. TESTING REQUIREMENTS [A.A.C. R18-2-312]

A. The Permittee shall conduct performance tests as specified in the permit and at such other times 

as may be required by the Director. 

B. Operational Conditions during Testing 

Tests shall be conducted during operation at the maximum possible capacity of each unit under 

representative operational conditions unless other conditions are required by the applicable test 

method or in this permit. With prior written approval from the Director, testing may be 

performed at a lower rate. Operations during periods of start-up, shutdown, and malfunction (as 

defined in A.A.C. R18-2-101) shall not constitute representative operational conditions unless 

otherwise specified in the applicable standard. 

C. Tests shall be conducted and data reduced in accordance with the test methods and procedures 

contained in the Arizona Testing Manual unless modified by the Director pursuant to A.A.C. 

R18-2-312.B. 

D. Test Plan 

Unless specified otherwise in the permit, , the Permittee shall submit a test plan to the Director in 

accordance with A.A.C. R18-2-312.B and the Arizona Testing Manual at least 14 calendar days 

prior to performing a test. This test plan must include the following: 

Permit No. 53592 Page 13 of 97 November 26, 2012 
1. Test duration; 

2. Test location(s); 

3. Test method(s); and 

4. Source operation and other parameters that may affect test results. 

E. Stack Sampling Facilities 

The Permittee shall provide, or cause to be provided, performance testing facilities as follows: 

1. Sampling ports adequate for test methods applicable to the facility; 

2. Safe sampling platform(s); 

3. Safe access to sampling platform(s); and 

4. Utilities for sampling and testing equipment. 

F. Interpretation of Final Results 

Each performance test shall consist of three separate runs using the applicable test method. Each 

run shall be conducted for the time and under the conditions specified in the applicable standard. 

For the purpose of determining compliance with an applicable standard, the arithmetic mean of 

the results of the three runs shall apply. In the event that a sample is accidentally lost or 

conditions occur in which one of the three runs is required to be discontinued because of forced 

shutdown, failure of an irreplaceable portion of the sample train, extreme meteorological 

conditions, or other circumstances beyond the Permittee’s control, compliance may, upon the 

Director’s approval, be determined using the arithmetic mean of the results of the other two runs. 

If the Director or the Director’s designee is present, tests may only be stopped with the Director’s 

or such designee’s approval. If the Director or the Director’s designee is not present, tests may 

only be stopped for good cause. Good cause includes: forced shutdown, failure of an 

irreplaceable portion of the sample train, extreme meteorological conditions, or other 

circumstances beyond the Permittee’s control. Termination of any test without good cause after 

the first run is commenced shall constitute a failure of the test. Supporting documentation, which 

demonstrates good cause, must be submitted. 

G. Report of Final Test Results 

A written report of the results of all performance tests shall be submitted to the Director within 30 

days after the test is performed. The report shall be submitted in accordance with the Arizona 

Testing Manual and A.A.C. R18-2-312.A. 

XIX. PROPERTY RIGHTS [A.A.C. R18-2-306.A.8.d]

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

XX. SEVERABILITY CLAUSE [A.A.C. R18-2-306.A.7]

The provisions of this permit are severable. In the event of a challenge to any portion of this permit, or if 

any portion of this permit is held invalid, the remaining permit conditions remain valid and in force. 

Permit No. 53592 Page 14 of 97 November 26, 2012 
XXI. PERMIT SHIELD [A.A.C. R18-2-325]

Compliance with the conditions of this permit shall be deemed compliance with all applicable 

requirements identified in the portions of this permit subtitled “Permit Shield”. The permit shield shall 

not apply to minor revisions pursuant to Condition XVI.B of this Attachment and any facility changes 

without a permit revision pursuant to Section XVII of this Attachment. 

XXII. PROTECTION OF STRATOSPHERIC OZONE [40 CFR Part 82]

If this source becomes subject to the provisions of 40 CFR Part 82, then the Permittee shall comply with 

these provisions accordingly. 

. 

Permit No. 53592 Page 15 of 97 November 26, 2012 
ATTACHMENT “B”: SPECIFIC CONDITIONS 

AIR QUALITY CONTROL PERMIT NO. 53592 

FOR 

FREEPORT-MCMORAN MIAMI, INC.

I. GENERAL REQUIREMENTS 

A. The Permittee shall have on site or on call a person that is certified in EPA Reference Method 9. 

 [A.A.C. R18-2-306.A.2]

B. At the time the compliance certifications required by Section VII of Attachment "A" are 

submitted, the Permittee shall submit reports of all monitoring activities required by this 

Attachment performed in the same six month period as applies to the compliance certification 

period. [A.A.C. R18-2-306.A.5.a]

C. 40 CFR Part 63 Subpart QQQ General Requirements 

In addition to specific requirements in this Attachment, the following general requirements shall 

be applicable to all National Emission Standards for Hazardous Air Pollutants (NESHAP) 40 

CFR Part 63 Subpart QQQ affected sources. 

1. The Permittee shall comply with the following general provisions of 40 CFR Part 63, 

Subpart “A”: [40 CFR 63.1457] 

40 CFR 63.1, 63.2, 63.3, 63.4, 63.5, 63.6 (a)-(g), 63.6 (i)-(j), 63.7 (a)(3) and (b)-(h), 63.8 

excluding 63.8(a)(4), (c)(4), and (f)(6), 63.9, 63.10 excluding 63.10(b)(2)(xiii) and (c)(7)-

(8), 63.12, and 63.13-63.15. 

2. The Permittee shall control particulate matter emissions from fugitive dust sources at the 

primary copper smelter by operating according to a written fugitive dust control plan that 

has been approved by the Director. For the purposes of complying with this requirement, 

the Permittee may use an existing fugitive dust control plan provided that the plan 

complies with the requirements detailed in Attachment “E”. [40 CFR 63.1445] 

3. The Permittee shall develop and implement a written startup, shutdown, and malfunction 

plan according to the provisions in 40 CFR63.6(e)(3). [40 CFR 63.1448(c)] 

4. Air Pollution Control Equipment 

a. The Permittee shall always operate and maintain all equipment subject to 40

CFR 63 Subpart QQQ, including the associated air pollution control and 

monitoring equipment, in a manner consistent with good air pollution control 

practices for minimizing emissions at least to the levels required by 40 CFR 63 

Subpart QQQ. [40 CFR 63.1447(a) and A.A.C. R18-2-331] 

[Material Permit Condition identified by underline] 

b. The Permittee shall prepare and operate at all times according to a written 

operation and maintenance plan for each capture system and control device as 

detailed in Attachment “F”. [40 CFR 63.1447(b)] 

5. Compliance Requirements 

a. The Permittee shall be in compliance with the emission limitations, work practice 

Permit No. 53592 Page 16 of 97 November 26, 2012 
standards, and operation and maintenance requirements at all times, except 

during periods of startup, shutdown, and malfunction as defined in 40 CFR 63.2. [40 CFR 63.1448(a)]

b. The Permittee shall demonstrate continuous compliance by implementing the 

fugitive dust control measures specified for the sources in the written fugitive 

dust control plan as prepared in accordance with Attachment “E”. 

 [40 CFR 63.1453(f)]

6. Monitoring Requirements 

a. Except for monitoring malfunctions, associated repairs, and required quality 

assurance or control activities (including as applicable, calibration checks and 

required zero and span adjustments), the Permittee shall monitor continuously (or 

collect data at all required intervals) at all times an affected source is operating. [40 CFR 63.1452(e)]

b. The Permittee shall not use data recorded during monitoring malfunctions, 

associated repairs, and required quality assurance or control activities in data 

averages and calculations used to report emission or operating levels or to fulfill 

a minimum data available requirement, if applicable. The Permittee shall use all 

the data collected during all other periods in assessing compliance. 

 [40 CFR 63.1452(f)]

c. A monitoring malfunction is any sudden, infrequent, not reasonably preventable 

failure of the monitor to provide valid data. Monitoring failures that are caused 

in part by poor maintenance or careless operation are not malfunctions. [40 CFR 63.1452(g)] 

7. Notification Requirements 

a. The Permittee shall submit all of the notifications in 40 CFR 63.7(b) and (c), 

63.8(f)(4), and 63.9(b) through (h) by the specified dates. [40 CFR 63.1454(a)]

b. The Permittee shall submit a notification of intent to conduct a performance test 

at least 60 calendar days before the performance test is scheduled to begin as 

required in 40 CFR 63.7(b)(1). [40 CFR 63.1454(d)] 

8. Reporting Requirements [40 CFR 63.1455]

a. The Permittee shall submit each of the following reports as applicable: 

 

(1) The Permittee shall submit a compliance report semiannually according 

to the requirements in Condition I.C.8.b below and containing the 

information in Condition I.C.8.c below.

(2) The Permittee shall submit an immediate startup, shutdown, and 

malfunction report if there was a startup, shutdown, or malfunction 

during the reporting period that is not consistent with the startup, 

shutdown, and malfunction plan. The Permittee shall report the actions 

taken for the event by fax or telephone within 2 working days after 

starting actions inconsistent with the plan. The Permittee shall submit 

the information in 40 CFR § 63.10(d)(5)(ii) by letter within 7 working 

days after the end of the event unless alternate arrangements have been 

made with the Director. 

 

Permit No. 53592 Page 17 of 97 November 26, 2012 
Timely reporting and submittal of information regarding deviation from 

startup, shutdown, and malfunction plan, as specified above, shall be 

considered as compliance with permit conditions, and such deviation will 

not be reportable as a “Permit Deviation Reporting” as specified in 

Condition XII.B of Attachment A. 

b. The Permittee shall submit each compliance report required in Condition I.C.8.a 

above in accordance with Condition VII in Attachment “A”. 

c. Each compliance report shall contain the following information in Conditions 

I.C.8.c(1) through (3) below and, as applicable, Conditions I.C.8.c(4) through 

(8). 

 

(1) Company name and address. 

(2) Statement by a responsible official, as defined in 40 CFR 63.2, with that 

official’s name, title, and signature, certifying the accuracy and 

completeness of the content of the report. 

(3) Date of report and beginning and ending dates of the reporting period. 

(4) If there was a startup, shutdown or malfunction during the reporting 

period and actions were taken consistent with the startup, shutdown, and 

malfunction plan, the compliance report shall include the information in 

40 CFR 63.10(d)(5)(i). 

(5) If there are no deviations from any emission limitations (emission limit, 

operating limit, opacity limit) that apply to this source and there are no 

deviations from the requirements for work practice standards in 40 CFR 

63, Subpart QQQ, a statement that there were no deviations from the 

emission limitations, work practice standards, or operation and 

maintenance requirements during the reporting period. 

(6) If there were no periods during which an operating parameter monitoring 

system was out-of-control as specified in 40 CFR 63.8(c)(7), a statement 

that there were no periods during which the monitoring system was outof-control during the reporting period. 

(7) For each deviation from an emission limitation (emission limit, operating 

limit, opacity limit) and for each deviation from the requirements for 

work practice standards that occurs at an affected source where the 

Permittee is not using a continuous monitoring system to comply with 

the emission limitations or work practice standards in Subpart QQQ, the 

compliance report shall contain the information in Conditions I.C.8.c(1) 

through (4) above and the information in Conditions I.C.8.c(7)(a) and 

(7)(b) below. This includes periods of startup, shutdown, and 

malfunction. 

(a) The total operating time of each affected source during the 

reporting period. 

(b) Information on the number, duration, and cause of deviations 

(including unknown cause, if applicable), as applicable, and the 

corrective action taken. 

Permit No. 53592 Page 18 of 97 November 26, 2012 
(8) For each deviation from an emission limitation (emission limit, operating 

limit, opacity limit, and visible emission limit) occurring at an affected 

source where the Permittee is using an operating parameter monitoring 

system to comply with the emission limitation in Subpart QQQ, the 

Permittee shall include the information in Conditions I.C.8.c(1) through 

(4) of this Section and the information in Conditions I.C.8.c(8)(a) 

through (k) below. This includes periods of startup, shutdown, and 

malfunction. 

(a) The date and time that each malfunction started and stopped. 

(b) The date and time that each monitoring system was inoperative, 

except for zero (low-level) and high-level checks. 

(c) The date, time and duration that each monitoring system was 

out-of-control, including the information in § 63.8(c)(8). 

(d) The date and time that each deviation started and stopped, and 

whether each deviation occurred during a period of startup, 

shutdown, or malfunction or during another period. 

(e) A summary of the total duration of the deviation during the 

reporting period and the total duration as a percent of the total 

source operating time during that reporting period. 

(f) A breakdown of the total duration of the deviations during the 

reporting period into those that are due to startup, shutdown, 

control equipment problems, process problems, other known 

causes, and other unknown causes. 

(g) A summary of the total duration of monitoring system downtime 

during the reporting period and the total duration of monitoring 

system downtime as a percent of the total source operating time 

during that reporting period. 

(h) A brief description of the process units. 

 

(i) A brief description of the monitoring system. 

(j) The date of the latest monitoring system certification or audit. 

(k) A description of any changes in continuous monitoring systems, 

processes, or controls since the last reporting period. 

d. The Permittee shall report all deviations from the applicable requirements of 40 

CFR 63, Subpart QQQ in the semiannual monitoring report required pursuant to 

Condition I.C.8.a of this Attachment. If the semiannual compliance report 

includes all required information concerning deviations from any emission 

limitation (including any operating limit), or work practice requirement in 

Subpart QQQ, submission of the compliance report is deemed to satisfy the 

obligation to report the same deviations in the semiannual monitoring report 

specified in Condition I.B of this Attachment. For the purpose of permit 

deviation reporting in Condition XII.B of Attachment “A”, prompt reporting of 

Permit No. 53592 Page 19 of 97 November 26, 2012 
deviations from applicable Subpart QQQ requirements shall mean that the 

Permittee report these deviations in the semiannual compliance report pursuant to 

Condition I.C.8.a of this Attachment. 

9. Recordkeeping Requirements [40 CFR 63.1456] 

a. The Permittee shall keep the following records: 

(1) A copy of each notification and report submitted to comply with 40 CFR 

63, Subpart QQQ, including all documentation supporting any initial 

notification or notification of compliance status submitted according to 

the requirements in 40 CFR 63.10(b)(2)(xiv). 

(2) The records in 40 CFR 63.6(e)(3)(iii) through (v) related to startup, 

shutdown, and malfunction. 

(3) Records or performance tests and performance evaluations as required in 

40 CFR 63.10(b)(2)(viii). 

(4) For each monitoring system, the Permittee shall keep records specified 

below: 

(a) Records described in 40 CFR 63.10(b)(2)(vi) through (xi). 

(b) Previous (i.e., superseded) versions of the performance 

evaluation plan as required in 40 CFR 63.8(d)(3). 

(c) Records of the date and time that each deviation started and 

stopped, and whether the deviation occurred during a period of 

startup, shutdown, or malfunction or during another period. 

(5) For each performance test conducted to demonstrate compliance with a 

opacity limit according to Condition VI.A.5 of this Attachment, the 

Permittee shall keep the records specified in Conditions I.C.9.a(5)(a) 

through (i) below. 

(a) Dates and time intervals of all opacity observation period 

segments; 

(b) Description of overall smelter operating conditions during each 

observation period. Identify, if any, the smelter copper 

production process equipment that was out-of-service during the 

performance test and explain why this equipment was not in 

operation; 

(c) Name, affiliation, and copy of current visible emission reading 

certification for each visible emission observer participating in 

performance test; 

(d) Name, title, and affiliation for each indoor process monitor 

participating in the performance test; 

(e) Copies of all visible emission observer opacity field data sheets; 

Permit No. 53592 Page 20 of 97 November 26, 2012 
(f) Copies of all indoor process monitor operating log sheets; 

(g) Copies of all data summary sheets used for data reduction; 

(h) Copy of calculation sheets of the average opacity value used to 

demonstrate compliance with the opacity limit; and 

(i) Documentation according to the requirements in Condition 

VI.A.5.i(4) of this Attachment to support the selection of the 

site-specific capture system operating limits used for each batch 

copper converter capture system when blowing. 

b. Records shall be in a form suitable and readily available for expeditious review, 

according to 40 CFR 63.10(b)(1). 

c. As specified in 40 CFR 63.10(b)(1), the Permittee shall keep each record for 5 

years following the date of each occurrence, measurement, maintenance, 

corrective action, report, or record. 

d. The Permittee shall keep each record on site for at least 2 years after the date of 

each occurrence, measurement, maintenance, corrective action, report, or record, 

according to 40 CFR 63.10(b)(1). The Permittee may keep the records off site 

for the remaining 3 years. 

10. Permit Shield 

Compliance with the conditions of this Part shall be deemed compliance with 40 CFR 

63.1444(a), 40 CFR 63.1445, 40 CFR 63.1447(a) and (b), 40 CFR 63.1448(a) and (c), 40 

CFR 63.1451(i), 40 CFR 63.1452(e), (f) and (g), 40 CFR 63.1453, 40 CFR 63.1454, 40 

CFR 63.1455, 40 CFR 63.1456, 40 CFR 63.14. 

D. Periodic Opacity Monitoring Requirements [A.A.C. R18-2-306.A.3.c] 

1. A certified Method 9 observer shall conduct surveys of visible emissions from the 

emission units as per the frequency specified in specific permit conditions in this 

Attachment in accordance with Conditions I.D.2 and I.D.3 below. 

2. For Stack Emissions with Baseline Opacity Monitoring Approach 

a. If the observer, during the visual survey, does not see visible emissions that on an 

instantaneous basis appear to exceed the baseline level previously established, 

then the observer shall keep a record of the name of the observer, the date on 

which the observation was made, and the results of the observation. 

b. If the observer sees visible emissions that on an instantaneous basis appear to 

exceed the baseline level, then the observer shall if practicable take a six-minute 

Method 9 observation of the plume. 

c. If the six-minute opacity of the plume is less than the baseline, the observer shall 

make a record of the following: 

(1) Location, date, and time of the test; and 

(2) The results of the Method 9 observation. 

Permit No. 53592 Page 21 of 97 November 26, 2012 
d. If the six-minute opacity of the plume exceeds the baseline level but is less than 

the opacity standard, the Permittee shall initiate corrective action, as necessary, to 

reduce opacity to or below the baseline level. The Permittee shall make a record 

of the following: 

 (1) Location, date, and time of the test; 

(2) The results of the Method 9 observation: and 

(3) Record of any corrective actions taken. 

e. If the six-minute opacity of the plume exceeds the opacity standard, then the 

Permittee shall do the following: 

(1) Adjust or repair the controls or equipment to reduce opacity to or below 

the baseline level; 

(2) Document the results of the Method 9 observation and all corrective 

action taken; and 

(3) Report the event as an excess emission for opacity in accordance with 

Condition XII.A.1 of Attachment “A”.

f. If necessitated by the results of the opacity monitoring, the Permittee may 

reestablish the baseline opacity level. Reestablishment of the baseline shall be 

performed by conducting 3 six-minute certified Method 9 observations, and 

determining the average of the 3 observations. Within 30 days of reestablishing 

the baseline opacity, the Permittee shall report the results to the Director. The 

report shall also contain a description of the need for re-establishing the 

baseline(s). 

3. For Fugitive Emissions and Stack Emissions without Baseline Monitoring Approach 

 

a. If the observer, during the visual survey, does not observe any plume that on an 

instantaneous basis appears to exceed the opacity standard, then the observer 

shall keep a record of the name of the observer, the date on which the observation 

was made, and the results of the observation. 

b. If the observer sees visible emissions that on an instantaneous basis appear to 

exceed the opacity standard, then the observer shall, if practicable, take a sixminute Method 9 observation of the plume. 

c. If the six-minute opacity of the plume exceeds the opacity standard, then the 

Permittee shall do the following: 

(1) Adjust or repair the controls or equipment to reduce opacity to or below 

the baseline level; 

(2) Document the results of the Method 9 observation and all corrective 

action taken; and 

(3) Report the event as an excess emission for opacity in accordance with 

Condition XII.A.1 of Attachment “A”. 

Permit No. 53592 Page 22 of 97 November 26, 2012 
d. If the six-minute opacity of the plume is less than the opacity standard, the 

observer shall make a record of the following: 

(1) Location, date, and time of the test; and 

(2) The results of the Method 9 observation. 

II. FEED LIMITATIONS 

A. Throughput Restrictions 

The maximum feed rate of new metal bearing material shall be limited to 850,000 dry tons per 

year concentrate to the furnaces (Isa and Electric), calculated as a twelve month rolling sum.

 [Condition VIII.A of Attachment B of Installation Permit #1232 and A.A.C. R18-2-331.A.3.a] 

 [Material permit conditions are identified by italics and underline]

B. Monitoring, Recordkeeping, and Reporting Requirements 

1. The Permittee shall log and maintain daily records of the amounts of concentrate fed to 

the furnace. At the end of every month, the Permittee shall update monthly and rolling 

twelve month totals of concentrate feed and recyclable hazardous waste feedstock. [A.A.C. R18-2-306.A.3.c] 

2. The Permittee shall report on a monthly basis, the totals of concentrate feed for the 

relevant 12-month rolling periods. [A.A.C. R18-2-306.A.5.a]

C. Permit Shield 

Compliance with the conditions of this Section shall be deemed compliance with Condition 

VIII.A of Attachment B of Installation Permit #1232. [A.A.C. R18-2-325] 

III. MATERIAL HANDLING AND BEDDING PLANT 

A. Emission Limitations and Standards 

1. The Permittee shall not exceed the emission rate limits specified in Attachment “C” for 

particulate matter emissions from the flux bin, revert bin, coal bin and concentrate bins. [Condition II.E of Att. B of Installation Permit #1232 and A.A.C. R18-2-331.A.3.a] 

 [Material permit conditions are identified by italics and underline] 

2. The Permittee shall not cause, allow or permit the discharge of particulate matter into the 

atmosphere from the affected stacks in total quantities in excess of the amount calculated 

by one of the following equations: [A.A.C. R18-2-715.A] 

a. For process sources having a process weight rate of 60,000 pounds per hour (30 

tons per hour) or less, the maximum allowable emissions shall be determined by 

the following equation: 

E = 4.10P 0.67 

Where 

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

Permit No. 53592 Page 23 of 97 November 26, 2012 
P = the process weight rate in tons-mass per hour. 

b. For process sources having a process weight rate greater than 60,000 pounds per 

hour (30 tons per hour), the maximum allowable emissions shall be determined 

by the following equation: 

E = 55.0P 0.11 - 40 

Where "E" and "P" are defined as indicated in Condition III.A.1.a above. 

2. The Permittee shall not cause, allow or permit to be emitted into the atmosphere, any

plume or effluent from any point source that exceeds 20% opacity as measured by EPA 

Reference Method 9. [A.A.C. R18-2-702.B.3] 

B. Air Pollution Control Requirements 

1. The Permittee shall maintain and operate the baghouses associated with the flux, coal, 

revert, and concentrate bins for minimizing particulate matter emissions. [A.A.C. R18-2-306.A.2 & A.A.C. R18-2-331.A.3.e] 

 [Material permit conditions are identified by italics and underline]

 

2. The Permittee shall maintain and operate the water sprays associated with revert 

separation device, flux, coal, revert, and concentrate bins for minimizing particulate 

matter emissions. [A.A.C. R18-2-306.A.2 & A.A.C. R18-2-331.A.3.e] 

[Material permit conditions are identified by italics and underline] 

C. Monitoring, Recordkeeping, and Reporting Requirements 

1. Opacity 

A certified Method 9 observer shall conduct a bi-weekly (once in two weeks) visual 

survey of visible emissions from the stacks associated with the material handling and 

bedding plant, when in operation, as per the procedure in Condition I.D.3 of this 

Attachment. [A.A.C. R18-2-306.A.3.c] 

2. Particulate Matter Emissions 

 

a. At the end of every calendar month, the Permittee shall calculate monthly 

emissions of particulate matter for the concentrate, flux, revert, and coal bins by 

multiplying the average hourly emission rate from the most recent performance 

test by the hours of operation of the material handling and bedding plant during 

the calendar month. The Permittee shall calculate rolling 12-month emissions 

(sum of the current month and prior eleven (11) most recent months). 

 [A.A.C. R18-2-306.A.3.c] 

b. The Permittee shall maintain records of the monthly hours of operation, and 

rolling 12-month hours of operation for the material handling and bedding plant. 

 [A.A.C. R18-2-306.A.3.c] 

c. The Permittee shall maintain records of the monthly and rolling 12-month total of 

particulate matter emissions from the concentrate, flux, coal, and revert bins from 

the material handling and bedding plant (sum of the current month and prior 

eleven (11) most recent months). [A.A.C. R18-2-306.A.3.c] 

Permit No. 53592 Page 24 of 97 November 26, 2012 
d. If the performance tests in Condition III.D below show a particulate matter 

emission rate of 0.073 lb/hour or lower, the Permittee will not be required to 

perform the monitoring stipulated in Conditions III.C.2.a through c above. 

 [A.A.C. R18-2-306.A.3.c] 

 

D. Performance Testing Requirements 

The Permittee shall conduct or cause to be conducted, performance tests on two representative 

stacks from the concentrate, flux, revert, and coal bins in the first year of the permit term to show 

compliance with the emission limits specified in Attachment C. EPA Reference Method 5 from 

40 CFR 60 shall be used to determine the emissions of PM. 

[A.A.C. R18-2-312 and A.A.C. R18-2-306.A.3.c] 

E. Permit Shield 

Compliance with the conditions of this Section shall be deemed compliance with Condition II.E 

of Att. B of Installation Permit #1232, A.A.C. R18-2-702.B and A.A.C. R18-2-715.A. [A.A.C. R18-2-325] 

IV. PROCESS GASES FROM ISASMELT FURNACE, ELECTRIC FURNACE AND CONVERTERS 

(Vented from the Acid Plant Tail Stack) 

A. Particulate Matter and Opacity 

1. Emission Limitations and Standards

a. The Permittee shall not exceed the emission rate limit specified for the acid plant 

tail gas stack in Attachment C for particulate matter. [Condition II.E of Att. B of Installation Permit #1232 and A.A.C. R18-2-331.A.3.a] 

 [Material permit conditions are identified by italics and underline] 

b. In any one hour period, the Permittee shall not cause, allow or permit the 

discharge of particulate matter into the atmosphere in excess of the amounts 

calculated by one of the following equations: [A.A.C. R18-2-715.A]

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

hour (30 tons per hour) or less, the maximum allowable emissions shall 

be determined by the following equation: 

E= 4.10P0.67 

Where: 

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

per hour. 

P = the process weight rate in tons-mass per hour of all materials 

introduced into a process source, including fuels, where these contribute 

to pollution generated by the source. 

(2) For process sources having a process weight rate greater than 60,000 

pounds per hour (30 tons per hour), the maximum allowable emissions 

shall be determined by the following equation: 

Permit No. 53592 Page 25 of 97 November 26, 2012 
E = 55P0.11 – 40 

Where "E" and "P" are defined as indicated in Condition V.A.1.b(1) 

above.

c. The Permittee shall not discharge or cause to be discharged to the atmosphere 

any process off-gas that contains non-sulfuric acid particulate matter in excess of 

6.2 mg/dscm as measured using the test methods specified in Condition IV.A.3.c. [40 CFR 63.1444(b)(1)] 

d. The Permittee shall not cause to be discharged from the acid plant tail stack, any 

visible emissions which exhibit greater than 20 percent opacity. [40 CFR 60.164(b)]

2. Monitoring, Recordkeeping, and Reporting Requirements

a. Opacity 

A certified Method 9 observer shall conduct a bi-weekly (once in two weeks) 

visual survey of visible emissions from the acid plant tail gas stack to monitor for 

the established baseline opacity as per the procedure in Condition I.D.2 of this 

Attachment. [A.A.C. R18-2-306.A.3.c]

b. Particulate Matter Emissions 

 

1. At the end of every calendar month, the Permittee shall calculate 

monthly emissions of particulate matter from the acid plant tail stack by 

multiplying the average hourly emission rate from the most recent 

performance test under Condition IV.A.3.a by the number of hours of 

operation of the acid plant during the calendar month. The Permittee 

shall calculate rolling 12-month emissions (sum of the current month and 

prior eleven (11) most recent months). [A.A.C. R18-2-306.A.3.c]

2. The Permittee shall maintain records of the monthly hours of operation 

of the acid plant and the year-to-date total, i.e., the sum of the current 

month and the eleven (11) previous months. [A.A.C. R18-2-306.A.3.c] 

3. The Permittee shall maintain records of the monthly and rolling 12-

month particulate matter emissions (sum of the current month and prior 

eleven (11) most recent months). [A.A.C. R18-2-306.A.3.c]

3. Performance Testing Requirements

a. The Permittee shall conduct or cause to be conducted, semi-annual performance 

tests on the acid plant tail stack for Particulate Matter (PM) to show compliance 

with the emission limits specified in Condition IV.A.1.a. Arizona Method A1 

shall be used to determine the emissions of PM. 

 [A.A.C. R18-2-312 and A.A.C. R18-2-306.A.3.c]

b. The Permittee shall conduct an annual EPA Reference Method 9 opacity 

observation for the acid plant tail stack. 

 [A.A.C. R18-2-312 and A.A.C. R18-2-306.A.3.c] 

Permit No. 53592 Page 26 of 97 November 26, 2012 
c. To demonstrate continuous compliance with the emission limitation in Condition 

IV.A.1.c, the Permittee shall conduct performance tests no less frequently than 

once per year according to the test methods specified below. [40 CFR 63.1453(a)(2)] 

(1) The Permittee shall determine the concentration of non-sulfuric acid 

particulate matter emissions according to the following test methods in 

Appendix “A” of 40 CFR 60: [40 CFR 63.1450(b)(1)]

(a) Method 1 to select sampling port locations and the number of 

traverse points. Sampling ports shall be located at the outlet of 

the control device and prior to any releases to the atmosphere. 

(b) Method 2, 2F, or 2G to determine the volumetric flow rate of the 

stack gas. 

(c) Method 3, 3A, or 3B to determine the dry molecular weight of 

the stack gas. 

(d) Method 4 to determine the moisture content of the stack gas. 

(e) Method 5B to determine the non-sulfuric acid particulate matter 

emissions. 

(2) The Permittee shall conduct three separate test runs for each performance 

test. Each test run shall have a minimum sampling time of 240 minutes 

and a minimum sampling volume of 3.4 dscm. For the purpose of 

determining compliance with the non-sulfuric acid particulate matter 

emission limit, the arithmetic mean of the results for the three separate 

test runs shall be used. [40 CFR 63.1450(b)(2)] 

 

4. Permit Shield

Compliance with the conditions of this Part shall be deemed compliance with Condition 

II.E of Att B of Installation Permit #1232, A.A.C. R18-2-715.A, 40 CFR 60.164(b), 40 

CFR 63.1444(b)(1), 40 CFR 63.1450(b) and 40 CFR 63.1453(a)(2). [A.A.C. R18-2-325] 

B. Lead 

 1. Emission Limitations 

The Permittee shall not exceed the emission limit for Lead specified in Attachment “C”.

[Condition I.A of Minor Revision #1232R1 to Installation Permit1232 and A.A.C. R18-2-331.A.3.a] 

 [Material permit conditions are identified by italics and underline]

2. Monitoring, Recordkeeping, and Reporting Requirements

 

a. At the end of every calendar month, the Permittee shall calculate monthly 

emissions of lead from the acid plant tail by multiplying the average hourly 

emission rate from the most recent performance test by the number of hours of 

operation of the acid plant during the calendar month. The Permittee shall 

calculate rolling 12-month emissions (sum of the current month and prior eleven 

(11) most recent months). [A.A.C. R18-2-306.A.3.c]

Permit No. 53592 Page 27 of 97 November 26, 2012 
b. The Permittee shall maintain records of the monthly hours of operation of the 

acid plant and the year-to-date total, i.e., the sum of the current month and the 

eleven (11) previous months. [A.A.C. R18-2-306.A.3.c]

c. The Permittee shall maintain records of the monthly and rolling 12-month lead 

emissions (sum of the current month and prior eleven (11) most recent months). [A.A.C. R18-2-306.A.3.c] 

3. Performance Testing Requirements 

To demonstrate compliance with the emission limit specified in Attachment “C”, the 

Permittee shall conduct semi-annual performance tests on the acid plant tail stack for 

emissions of Lead using EPA Reference Method 29 [A.A.C. R18-2-312 and A.A.C. R18-2-306.A.3.c]

4. Permit Shield

Compliance with the conditions of this Part shall be deemed compliance with Condition 

I.A of Minor Revision #1232R1 to Installation Permit1232. [A.A.C. R18-2-325]

C. Sulfur Dioxide (SO2) 

1. Emission Limitations and Standards 

a. The Permittee shall not exceed the emission limit for sulfur dioxide specified in

Attachment “C” for the acid plant tail stack. [Condition II.E of Att B of Installation Permit #1232 & A.A.C. R18-2-331.A.3.a] 

 [Material permit conditions are identified by italics and underline] 

b. The Permittee shall not cause to be discharged into the atmospheres from the acid 

plant any gases that contain sulfur dioxide in excess of 0.065 percent by volume. [40 CFR 60.163(a)] 

2. Air Pollution Control Requirements 

a. At all times, including periods of startup, shutdown, and malfunction, the

Permittee shall, to the extent practicable, maintain and operate the acid plant in 

a manner consistent with good air pollution control practice for minimizing 

sulfur dioxide emissions from the process gases associated with the IsaSmelt 

furnace, electric furnace, and the converters. [40 CFR 60.11(d) and A.A.C. R18-2-331.A.3.e] 

 [Material permit conditions are identified by italics and underline] 

b. The Permittee shall, to the extent practicable, maintain and operate the chemical 

scrubber, when in use, in a manner consistent with good air pollution control 

practice for minimizing sulfur dioxide emissions from the process gases 

associated with the IsaSmelt furnace, electric furnace, and the converters. [40 CFR 60.11(d) and A.A.C. R18-2-331.A.3.e] 

 [Material permit conditions are identified by italics and underline] 

3. Monitoring, Recordkeeping and Reporting Requirements 

a. Except during periods of system breakdowns, repairs, calibration checks and zero 

and span adjustments, the Permittee shall continue to operate a continuous 

emission monitoring system (CEMS) to monitor and record sulfur dioxide 

Permit No. 53592 Page 28 of 97 November 26, 2012 
emissions from the acid plant tail stack. The span of this system shall be set at a 

sulfur dioxide concentration of 0.2 percent by volume. [40 CFR 60.13(e), 40 CFR 60.165(b)(2)] 

b. Six-hour average sulfur dioxide concentrations shall be calculated and recorded 

daily for the four consecutive 6-hour periods of each operating day. Each sixhour average shall be determined as the arithmetic mean of the appropriate six 

contiguous one-hour average sulfur dioxide concentrations provided by the 

continuous monitoring system. [40 CFR 60.165(c)]

c. For reporting purposes, periods of excess emissions that shall be reported are 

defined as all six-hour periods during which the average emissions of sulfur 

dioxide, as measured by the continuous monitoring system, exceed the standard 

(0.065 percent by volume). The Administrator will not consider emissions in 

excess of the level of the standard for less than or equal to 1.5 percent of the sixhour period during the quarter as indicative of a potential violation of 60.11(d), 

provided the acid plant is maintained and operated in a manner consistent with 

good air pollution control practice for minimizing emissions during these 

periods. Emissions in excess of the level of the standard during periods of 

startup, shutdown, and malfunction are not to be included within the 1.5 percent. [40 CFR 60.165(d)(2)] 

d. SO2 CEMS shall comply with the requirements for Continuous Monitoring 

Systems under Section VIII of this Attachment. [A.A.C. R18-2-306.A.3.c] 

e. During the periods of system breakdown, repairs, calibration checks, and zero 

and span adjustments, the Permittee shall maintain records of acid plant blower 

operation and data from the Jones Ranch SO2 ambient monitors operated by the 

Permittee for a representative period prior to and subsequent to the time the 

CEMS was inoperable. [A.A.C. R18-2-306.A.3.c]

f. The data recorded in the Condition IV.C.3.a above shall also be used to track 

compliance with the sulfur dioxide emission limits specified in Attachment “C” 

of the permit. [A.A.C. R18-2-306.A.3.c] 

4. Permit Shield 

Compliance with the conditions of this Part shall be deemed compliance with Condition 

II.E of Att. B of Installation Permit #1232, 40 CFR 60.163(a), 40 CFR 60.165(b)(2), 40 

CFR 60.165(c), and 40 CFR 60.165(d)(2). [A.A.C. R18-2-325] 

D. Nitrogen Oxides 

1. Emission Limitations/Standards 

The Permittee shall limit the nitrogen oxide emissions from the tail gas stack of the acid 

plant to not more than 425 tons per year. The average hourly nitrogen oxides emission 

rate shall be no greater than 97.5 pounds per hour. 

[Condition II.A.1 of Att. B of Significant Revision #1000266 

to Installation Permit #1232, A.A.C. R18-2-406.A.4] 

Permit No. 53592 Page 29 of 97 November 26, 2012 
2. Monitoring, Recordkeeping, and Reporting Requirements 

a. At the end of every calendar month, the monthly emissions of nitrogen oxides 

shall be calculated by multiplying the average hourly emission rate from the most 

recent performance test by the hours of operation of the acid plant during the 

calendar month. The annual emissions shall be calculated as the rolling sum of 

that calendar month and prior eleven (11) most recent months. 

 [A.A.C. R18-2-306.A.3.c] 

b. The Permittee shall maintain records of the monthly hours of operation of the 

acid plant and the year-to-date total, i.e., the sum of the current month and the 

eleven (11) previous months. [A.A.C. R18-2-306.A.3.c]

c. The Permittee shall maintain records of the monthly emissions of nitrogen oxides 

from the acid plant and the year-to-date total, i.e., the sum of the current month 

and the eleven (11) previous months. [A.A.C. R18-2-306.A.3.c]

3. Performance Testing Requirements 

The Permittee shall conduct or cause to be conducted, semi-annual performance tests on 

the acid plant tail stack for nitrogen oxides to show compliance with the emission limits 

specified in Condition IV.D.1. EPA Reference Method 7E shall be used to determine the 

emissions of NOx. The performance test will consist of three runs, each lasting 4 hours. [A.A.C. R18-2-312 and A.A.C. R18-2-306.A.3.c] 

4. Permit Shield 

Compliance with the conditions of this Part shall be deemed compliance with Condition 

II.A.1 of Att. B of Significant Revision #1000266 to Installation Permit #1232. [A.A.C. R18-2-325] 

V. CAPTURED FUGITIVES FROM THE ISASMELT FURNACE LAUNDER AND THE 

ELECTRIC FURNACE (VENT FUME STACK) 

A. Particulate Matter and Opacity 

1. Emission Limitations/Standards 

a. The Permittee shall not exceed the emission rate limit specified for the Vent 

Fume Stack in Attachment “C” for particulate matter. [Condition II.E of Att B of Installation Permit #1232 and A.A.C. R18-2-331.A.3.a] 

 [Material permit conditions are identified by italics and underline] 

b. In any one hour period, the Permittee shall not cause, allow or permit the 

discharge of particulate matter from the vent fume stack into the atmosphere in 

excess of the amounts calculated by one of the following equations: 

 [A.A.C. R18-2-715.A]

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

hour (30 tons per hour) or less, the maximum allowable emissions shall 

be determined by the following equation: 

E= 4.10P 0.67 

Where: 

Permit No. 53592 Page 30 of 97 November 26, 2012 
E = the maximum allowable particulate emissions rate in pounds-mass 

per hour. 

P = the process weight rate in tons-mass per hour of all materials 

introduced into a process source, including fuels, where these contribute 

to pollution generated by the source. 

(2) For process sources having a process weight rate greater than 60,000 

pounds per hour (30 tons per hour), the maximum allowable emissions 

shall be determined by the following equation: 

E = 55P0.11 – 40 

Where "E" and "P" are defined as indicated in Condition V.A.1.b(1) 

above. 

c. The Permittee shall not discharge to the atmosphere from the capture system used 

to comply with Condition V.A.2.b below any gases that contain total particulate 

matter in excess of 23 mg/dscm as measured using the test methods specified in 

Condition V.A.4.b of this Attachment. [40 CFR 63.1444(b)(2)(ii)] 

 

d. The Permittee shall not cause to be discharged into the atmosphere from the vent 

fume stack any visible emissions which exhibit greater than 20 percent opacity. 

 [A.A.C. R18-2-715.D] 

2. Air Pollution Control Requirements 

a. The Permittee shall maintain and operate the scrubber and wet electrostatic 

precipitator (WESP) system associated with the vent fume stack for minimizing 

particulate matter emissions. [A.A.C. R18-2-306.A.2 and A.A.C. R18-2-331.A.3.e] 

 [Material permit conditions are identified by italics and underline] 

b. The Permittee shall operate a capture system that collects the gases and fumes 

released from the tapping port in use at all times when copper matte or slag is 

tapped from the smelting furnace. The design and placement of the capture 

system required in shall be such that the tapping port opening, launder, and 

receiving vessel (e.g., ladle, slag pot) are positioned within the confines or 

influence of the capture system’s ventilation draft during those times when the 

copper matte or slag is flowing from the tapping port opening. 

 [40 CFR 63.1444(b)(2)(i), A.A.C. R18-2-331.A.3.e] 

 [Material permit conditions are identified by italics and underline]

c. The Permittee shall maintain the hourly average water flow rate at or above the 

minimum levels established during the most recent performance test for the wet 

scrubber applied to meet total particulate matter emission limit in Condition 

V.A.1.c. [40 CFR 63.1444(h)] 

d. The Permittee shall maintain the hourly average values for primary and 

secondary voltage, amperage and power for the ESPs within the limits 

established during the most recent performance test. [40 CFR 63.1444(h)] 

Permit No. 53592 Page 31 of 97 November 26, 2012 
e. The Permittee shall install, maintain and operate a bypass duct on the Electric 

Furnace in accordance with good air pollution control practices to allow the 

gases to be directed to the vent fume system during periods of startup and shut 

down when the hot gas fans are not operational. The Permittee shall not vent 

any gases directly to atmosphere at the electric furnace. [A.A.C. R18-2-306.A.2 and A.A.C. R18-2-331.A.3.d and e] 

 [Material permit conditions are identified by italics and underline] 

3. Monitoring, Recordkeeping, and Reporting Requirements 

a. Opacity Monitoring for the Vent Fume Stack 

A certified Method 9 observer shall conduct a bi-weekly (once in two weeks) 

visual survey of visible emissions from the vent fume stack as per the procedure 

in Condition I.D.3 of this Attachment. [A.A.C. R18-2-306.A.3.c] 

b. Emissions monitoring for the Vent Fume Stack 

 

(1) At the end of every calendar month, the Permittee shall calculate the 

monthly emissions of particulate matter from the vent fume stack by 

multiplying the average hourly emission rate determined from the most 

recent performance test by the hours of operation of the process 

equipment associated with the vent fume stack during the calendar 

month. The Permittee shall calculate rolling 12-month emissions (sum 

of the current month and prior eleven (11) most recent months). 

 [A.A.C. R18-2-306.A.3.c]

(2) The Permittee shall maintain records of the monthly and rolling 12-

month (sum of the current month and prior eleven (11) most recent 

months) hours of operation of the process equipment associated with the 

vent fume stack. [A.A.C. R18-2-306.A.3.c] 

(3) The Permittee shall maintain records of the monthly and rolling 12-

month (sum of the current month and prior eleven (11) most recent 

months) emissions of particulate matter from the vent fume stack. 

 [A.A.C. R18-2-306.A.3.c] 

(4) The Permittee shall maintain records of the monthly average stack flow 

rate on a 12-month rolling basis. [A.A.C. R18-2-306.A.3.c] 

c. Wet Scrubber 

For each wet scrubber subject to Condition V.A.2.c above, the Permittee shall 

monitor the hourly average water flow rate using a CPMS. The Permittee shall 

install, operate and maintain each CPMS according to the following 

requirements: [40 CFR 63.1452(d), A.A.C. R18-2-331.A.3.c] 

 [Material permit conditions are indicated by italics and underline]

 

(1) Locate the flow sensor and other necessary equipment in a position that 

provides a representative flow and that reduces swirling flow or 

abnormal velocity distributions due to upstream and downstream 

disturbances. 

(2) Use a flow sensor with a minimum measurement sensitivity of 2 percent 

of the flow rate. 

Permit No. 53592 Page 32 of 97 November 26, 2012 
(3) Conduct a flow sensor calibration check at least semiannually according 

to the manufacturer’s instructions. 

(4) At least monthly, inspect all components for integrity, all electrical 

connections for continuity, and all mechanical connections for leakage.

d. ESPs 

The Permittee shall install, operate, and maintain the continuous parameter 

monitoring system (CPMS) to monitor primary and secondary voltage, amperage 

and power for the Wet Electrostatic Precipitators (WESP) according to the 

equipment manufacturer's specifications and the following requirements: [40 CFR 63.1452(d), A.A.C. R18-2-331.A.3.c] 

 [Material permit conditions are indicated by italics and underline] 

(1) Locate the sensor(s) used for monitoring in or as close to a position that 

provides a representative measurement of the parameter being 

monitored. 

(2) Determine the hourly average of all recorded readings. 

(3) Conduct calibration and validation checks any time the sensor exceeds 

the manufacturer's specifications or a new sensor is installed. 

(4) At least monthly, inspect all components for integrity, all electrical 

connections for continuity, and all mechanical connections for leakage. 

(5) Record the results of each inspection, calibration, and validation check. 

4. Performance Testing Requirements 

a. If the stack flow rate exceeds 500,000 scfm in a rolling 12-month period, the 

Permittee shall conduct or cause to be conducted, semi-annual performance tests 

on the vent fume stack for Particulate Matter (PM) to show compliance with the 

emission limits specified in Conditions V.A.1.a and 1.b of this Attachment. 

Arizona Method A1 shall be used to determine the emissions of PM. 

 [A.A.C. R18-2-312 and A.A.C. R18-2-306.A.3.c]

b. The Permittee shall conduct annual performance test according to the following 

performance test procedures to demonstrate compliance with emission standard 

in Condition V.A.1.c of this Attachment. 

 [40 CFR 63.1450(a) and 40 CFR 63.1453(a)(1)(ii)]

(1) Determine the concentration of total particulate matter according to the 

test methods in Appendix A to 40 CFR Part 60 as specified in paragraphs 

(a) through (e) below: 

(a) Method 1 to select sampling port locations and the number of 

traverse points. Sampling ports shall be located at the outlet of 

the control device and prior to any releases to the atmosphere. 

(b) Method 2, 2F, or 2G to determine the volumetric flow rate of the 

stack gas. 

Permit No. 53592 Page 33 of 97 November 26, 2012 
(c) Method 3, 3A, or 3B to determine the dry molecular weight of 

the stack gas. 

(d) Method 4 to determine the moisture content of the stack gas. 

(e) Method 5, 5D, or 17, as applicable, to determine the 

concentration of total particulate matter. The Permittee can also 

use ASTM D4536-96 incorporated by reference in §63.14 as an 

alternative to the sampling equipment and operating procedures 

in Method 5 or 17 when testing a positive pressure baghouse, but 

the Permittee shall use the sample traverse location and number 

of sampling points described in Method 5D. 

(2) As an alternative to using the applicable method specified in Condition 

V.A.4.b(1)(e) above, the Permittee may determine total particulate matter 

emissions from the control device using Method 29 in Appendix A of 40 

CFR Part 60 of this chapter provided that the Permittee follows the 

procedures and precautions prescribed in Method 29. If the control 

device is a positive pressure baghouse, the Permittee shall also follow the 

measurement specified in sections 4.1 through 4.3 of Method 5D. 

(3) The Permittee shall conduct three separate test runs for each performance 

test. Each test run shall have a minimum sampling time of 60 minutes 

and a minimum sampling volume of 0.85 dscm. For the purpose of 

determining compliance with the applicable total particulate matter 

emission limit, the arithmetic mean of the results for the three separate 

test runs is used. 

 

c. For the ESPs subject to operating limitation under Condition V.A.2.d of this 

Attachment, the Permittee shall establish site-specific operating limit(s) for the 

operating parameters according to the following procedures: [40 CFR 63.1450(a)(5)] 

 (1) Using the CPMS in Condition V.A.3.d, the Permittee shall measure and 

record the selected operating parameters for the ESP during each run of 

the total particulate matter performance test. 

(2) Compute and record the hourly average value for each of the selected 

operating parameters for each individual test run. The operating limits 

are the lowest value or the highest value, as appropriate for the selected 

operating parameter, measured in any of the three runs that meet the 

applicable emission limit. 

 

(3) The Permittee shall prepare and keep records of written documentation to 

support the selection of the operating parameters used for the ESPs. This 

documentation shall include a description of each selected parameter, a 

rationale for why the Permittee chose the parameter, a description of the 

method used to monitor the parameter, and the data recorded during the 

performance test and used to set the operating limit(s). 

d. For wet scrubber applied to emissions from an affected source and subject to 

operating limits in Condition V.A.2.c for the scrubber water flow rate, the 

Permittee shall establish site-specific operating limits according to the following: [40 CFR 63.1450(a)(5)] 

(1) Using the continuous parameter monitoring system (CPMS) required in 

Permit No. 53592 Page 34 of 97 November 26, 2012 
Condition V.A.3.c, shall measure and record the scrubber water flow rate 

during each run of the particulate matter performance test.

(2) Compute and record the hourly average scrubber water flow rate for each 

individual test run. The operating limit is the lowest average scrubber 

water flow rate value in any of the three runs that meet the applicable 

emission limit. 

5. Continuous Compliance Demonstration 

a. The Permittee shall demonstrate continuous compliance with the particulate 

matter emission limit in Condition V.A.1.c by maintaining the average 

concentration of total particulate matter in the gases discharged from the affected 

sources at or below the applicable emission limit, and by conducting performance 

tests no less frequently than once per year. [40 CFR 63.1453(a)(1)] 

b. The Permittee shall demonstrate continuous compliance for the scrubbers by 

meeting the following requirements: [40 CFR 63.1453(e)] 

a. Maintain the hourly average scrubber water flow rate at levels no lower 

than those established under Condition V.A.4.d during the most recent 

performance test; 

b. Collect and reduce monitoring data for scrubber water flow rate 

according to Condition I.C.6 of this Attachment and record all 

information needed to document conformance with these requirements.

c. The Permittee shall demonstrate continuous compliance for Electrostatic 

Precipitators by meeting the following requirements: [40 CFR 63.1453(e)]

a. Maintain the hourly average of the parameter(s) selected in Condition 

V.A.4.c within the levels established during the most recent performance 

test; 

b. Collect and reduce monitoring data for selected parameters according to 

Condition I.C.6 of this Attachment and record all information needed to 

document conformance with these requirements. 

6. Permit Shield 

Compliance with the conditions of this Part shall be deemed compliance with Conditions 

II.E of Att. B of Installation Permit #1232, A.A.C. R18-2-715.A, A.A.C. R18-2-715.D, 

40 CFR 63.1444(b)(2)(i), 40 CFR 63.1444(b)(2)(ii), 40 CFR 63.1444(h), 40 CFR 

63.1450(a)(1), 40 CFR 63.1450(a)(5), 40 CFR 63.1452(d), 40 CFR 63.1453(a)(1)(ii) and 

40 CFR 63.1453(e). [A.A.C. R18-2-325]

B. Sulfur Dioxide 

1. Emission Limitations/Standards 

The Permittee shall not exceed the emission limit for sulfur dioxide specified in 

Attachment “C” for the vent fume stack. [Condition II.E of Att. B of Installation Permit #1232 and A.A.C. R18-2-331.A.3.a] 

 [Material permit conditions are identified by italics and underline] 

Permit No. 53592 Page 35 of 97 November 26, 2012 
2. Air Pollution Control Requirements 

 

The Permittee shall maintain and operate the scrubber associated with the vent fume 

stack for minimizing sulfur dioxide emissions. [A.A.C. R18-2-306.A.2 and A.A.C. R18-2-331.A.3.e] 

 [Material permit conditions are identified by italics and underline] 

3. Monitoring, Recordkeeping and Reporting Requirements 

a. The Permittee shall continue to operate Continuous Emission Monitoring 

Systems (CEMS) to monitor and record sulfur dioxide emissions from the vent 

fume stack. This data shall be used to track compliance with the sulfur dioxide 

emission limits specified in Attachment “C” of the permit. 

 [A.A.C. R18-2-306.A.3.c]

b. SO2 CEMS shall comply with the requirements for Continuous Monitoring 

Systems under Section VIII of this Attachment. [A.A.C. R18-2-306.A.3.c]

4. Permit Shield 

Compliance with the conditions of this Part shall be deemed compliance with Conditions 

II.E of Att. B of Installation Permit #1232. [A.A.C. R18-2-325]

 C. Lead 

 1. Emissions Limitation and Standard 

The Permittee shall not exceed the emission limit for Lead specified in Attachment “C”

for the vent fume stack. [Condition II.F.2 of Att. B of Installation Permit #1232 and A.A.C. R18-2-331.A.3.a] 

 [Material permit conditions are identified by italics and underline] 

2. Performance Testing Requirements 

Performance tests shall be conducted on a semi-annual basis on the vent fume stack for 

emissions of Lead using EPA Reference Method 29 to show compliance with the 

emission limit specified in Attachment “C”. [A.A.C. R18-2-312 and A.A.C. R18-2-306.A.3.c]

3. Lead Emissions monitoring from the Vent Fume Stack 

 

(1) At the end of every calendar month, the Permittee shall calculate the monthly 

emissions of lead from the vent fume stack by multiplying the average hourly 

emission rate determined from the most recent performance test by the hours of 

operation of the process equipment associated with the vent fume stack during 

the calendar month. The Permittee shall calculate rolling 12-month emissions 

(sum of the current month and prior eleven (11) most recent months). 

 [A.A.C. R18-2-306.A.3.c]

(2) The Permittee shall maintain records of the monthly and rolling 12-month (sum 

of the current month and prior eleven (11) most recent months) hours of 

operation of the process equipment associated with the vent fume stack. [A.A.C. R18-2-306.A.3.c] 

(3) The Permittee shall maintain records of the monthly and rolling 12-month (sum 

of the current month and prior eleven (11) most recent months) emissions of lead 

from the vent fume stack. [A.A.C. R18-2-306.A.3.c] 

Permit No. 53592 Page 36 of 97 November 26, 2012 
4. Permit Shield 

Compliance with the conditions of this Part shall be deemed compliance with Conditions 

II.F.2 of Att. B of Installation Permit #1232. [A.A.C. R18-2-325] 

VI. SMELTER FUGITIVES 

A. Particulate Matter and Opacity 

1. Emission Limitations and Standards 

a. Except as provided in Conditions VI.A.1.a.(1) and (2), the Permittee shall not 

cause, allow or permit to be emitted into the atmosphere, any plume or effluent 

from the smelter building which exceeds 20% opacity as measured by EPA 

Reference Method 9. [A.A.C. R18-2-702.B] 

(1) The Permittee shall not cause, allow or permit to be emitted into the 

atmosphere, any plume or effluent from the smelter building during the 

periods of white metal transfer between converters which exceeds 39% 

opacity as measured by EPA Reference Method 9. [A.A.C. R18-2-702.E] 

(2) The Permittee shall not cause, allow or permit to be emitted into the 

atmosphere, any plume or effluent during periods of matte additions to 

converter prior to first blow which exceeds 30% opacity as measured by 

EPA Reference Method 9. [A.A.C. R18-2-702.E]

 

b. The opacity of any visible emissions exiting the roof monitors on the building 

housing the copper converter department shall not exceed 4% as determined by a 

performance test conducted in accordance with Condition VI.A.5 below. This 

opacity limit applies only at those times when a performance test is conducted 

according to Condition VI.A.5 below. The requirements for compliance with 

opacity and visible emission standards specified in 40 CFR §63.6(h) do not apply 

to this opacity limit. [40 CFR 63.1444(d)(4)] 

2. Air Pollution Control Requirements 

a. At all times when one or more batch converter is blowing, the Permittee shall 

operate the capture system to collect the process off gases vented from each 

batch copper converter according to the written operation and maintenance plan 

that has been prepared according to the requirements in Condition I.C.4.b of this 

Attachment. [40 CFR 63.1444(d)(1)] 

a. The capture system shall collect process off-gas vented during blowing through 

the side-flue intake on each converter vessel. [40 CFR 63.1444(d)(3)]

3. Monitoring, Recordkeeping, and Reporting Requirements 

a. Bi-weekly monitoring for fugitive emissions 

A certified Method 9 observer shall conduct a bi-weekly (once in two weeks) 

visual survey of visible emissions from the smelter building when in operation as 

per the procedure in Condition I.D.3 of this Attachment. [A.A.C. R18-2-306.A.3.c]

Permit No. 53592 Page 37 of 97 November 26, 2012 
b. Copper Converter Department Capture System Monitoring

For each operating limit established under the capture system operation and 

maintenance plan, the Permittee shall install, operate, and maintain an 

appropriate monitoring device according to the requirements in Conditions 

VI.A.3.b(1) through (6) below to measure and record the operating limit value or 

setting at all times the copper converter department capture system is operating 

during batch copper converter blowing. Dampers that are manually set and 

remain in the same position at all times the capture system is operating are 

exempted from these requirements. [40 CFR 63.1452(a)] 

(1) Install the monitoring device, associated sensor(s), and recording 

equipment according to the manufacturer’s specifications. Locate the 

sensor(s) used for monitoring in or as close to a position that provides a 

representative measurement of the parameter being monitored. 

(2) If a flow measurement device is used to monitor the operating limit 

parameter, the Permittee shall meet the following: 

(a) Locate the flow sensor and other necessary equipment such as 

straightening vanes in a position that provides a representative 

flow. 

(b) Use a flow sensor with a minimum tolerance of 2 percent of the 

flow rate. 

(c) Reduce swirling flow or abnormal velocity distributions due to 

upstream and downstream disturbances. 

(d) Conduct a flow sensor calibration check at least semiannually. 

(3) If a pressure measurement device is used to monitor the operating limit 

parameter, the Permittee shall meet the following requirements: 

(a) Locate the pressure sensor(s) in or as close to a position that 

provides a representative measurement of the pressure. 

(b) Minimize or eliminate pulsating pressure, vibration, and internal 

and external corrosion. 

(c) Using a gauge with a minimum tolerance of 0.5 inch of water or 

a transducer with a minimum tolerance of 1 percent of the 

pressure range. 

(d) Check pressure tap pluggage daily. 

(e) Using a manometer, check gauge calibration quarterly and 

transducer calibration monthly. 

(4) Conduct calibration and validation checks any time the sensor exceeds 

the manufacturer’s specifications or if a new sensor is installed. 

(5) At least monthly, inspect all components for integrity, all electrical 

connections for continuity, and all mechanical connections for leakage. 

Permit No. 53592 Page 38 of 97 November 26, 2012 
(6) Record the results for each inspection, calibration, and validation check. 

4. 40 CFR 63, Subpart QQQ Continuous Compliance Demonstration of the Copper 

Converter Department Capture Systems [40 CFR 63.1453(b)]

The Permittee shall demonstrate continuous compliance of the copper converter 

department capture system by meeting the following requirements: 

a. Operate the copper converter department capture system at all times during 

blowing within the values or setting established for the operating limits and 

demonstrated to achieve the opacity limit; 

b. Inspect and maintain the copper converter department capture system according 

to the applicable requirements in Condition I.C.4.b of this Attachment, and 

record all information needed to document conformance with these requirements; 

c. Monitor the copper converter department capture system according to the 

requirements in Condition VI.A.3.b of this Attachment and collect, reduce, and 

record the monitoring data for each of the operating limit parameters; and 

d. Conduct performance tests no less frequently than once per year to demonstrate 

that the opacity of any visible emissions exiting the roof monitors or roof exhaust 

fans on the building housing the copper converter department does not exceed 4 

percent opacity. The performance test shall be performed as per the procedure in 

Condition VI.A.5 below. 

5. Performance Testing Requirements 

The Permittee shall conduct each performance test to determine compliance with the 

opacity limit in Condition VI.A.1.b of this Attachment using the following test methods 

and procedures: [40 CFR 63.1450(c)]

a. The performance test shall be conducted during the period when the primary 

copper smelter is operating under conditions representative of the smelter’s 

normal blister copper production rate. A performance test may not be conducted 

during periods of startup, shutdown, or malfunction. Before conducting the 

performance test, a written test plan shall be prepared specifying the copper 

production conditions to be maintained throughout the opacity observation 

period. This plan shall include a copy of the written documentation prepared 

according to Condition I.C in Attachment “F” to support the established 

operating limits for the copper converter department capture system. A copy of 

the test plan shall be submitted for review and approval by the Director. During 

the observation period, the Permittee shall conduct appropriate process 

information and copper converter department capture system operating 

information to prepare documentation sufficient to verify that all opacity 

observations were made during the copper production and capture system 

operating conditions specified in the approved test plan. 

b. The Permittee shall notify the Director before conducting the opacity 

observations to allow the Director the opportunity to have an authorized 

representative attend the test. Written notification of the location and scheduled 

date for conducting the opacity observation shall be received by the Director on 

or before 30 calendar days before the scheduled test date. 

Permit No. 53592 Page 39 of 97 November 26, 2012 
c. The Permittee shall gather the data needed for determining compliance with the 

opacity limit using qualified visible emission observers and process monitors as 

follows: 

(1) Opacity observations shall be performed by a sufficient number of 

qualified visible emission observers to obtain two complete concurrent 

sets of opacity readings for the required observation period. Each visible 

emission observer shall be certified as a qualified observer by the 

procedure specified in Section 3 of Method 9 in Appendix “A” of 40 

CFR 60. The entire set of readings during the required observation 

period does not need to be made by the same two observers. More than 

two observers may be used to allow for substitutions and provide for 

observer rest breaks. The Permittee shall obtain proof of current visible 

emission reading certification for each observer. 

(2) A person (or persons) familiar with the copper production operations 

conducted at the smelter shall serve as the indoor process monitor. The 

indoor process monitor is stationed at a location inside the building 

housing the batch copper converters such that he or she can visually 

observe and record operations that occur in the batch copper converter 

aisle during the times that the visible emission observers are making 

opacity readings. More than one indoor process monitor may be used to 

allow for substitutions and provide for rest breaks. 

d. The Permittee shall make all opacity observations using EPA Reference Method 

9 and follow the procedures detailed below: 

(1) Each visible emission observer shall make his or her readings at a 

position from the outside of the building that houses the copper converter 

department such that the observer’s line-of-sight is approximately 

perpendicular to the longer axis of the converter building, and the 

observer has an unobstructed view of the building roof monitor sections 

or roof exhaust fan outlets that are positioned over each of the batch 

copper converters inside the building. Opacity readings can only be 

made during those times when the observer’s position meets the sun 

orientation and other conditions specified in section 2.1 or Method 9. 

(2) At 15-second intervals, each visible emission observer views the building 

roof monitor sections or roof exhaust fan outlets that are positioned over 

each of the batch copper converters inside the building and reads the 

opacity of the visible plumes. If no plume is visible, the observer records 

zero as the opacity value for the 15-second interval. In situations when it 

is possible for an observer to distinguish two or more visible emission 

plumes from the building roof monitor sections or roof exhaust fan 

outlets, the observer shall identify, to the extent feasible, the plume 

having the highest opacity and record his or her opacity reading for the 

plume as the opacity value for the 15-second interval. 

e. The Permittee shall make opacity observations for a period of sufficient duration 

to obtain a minimum of 120 1-minute intervals during which at least one copper 

converter is blowing and no interferences have occurred from other copper 

production events, as specified in Condition VI.A.5.g of this Attachment, which 

generate visible emissions inside the building that potentially can interfere with 

Permit No. 53592 Page 40 of 97 November 26, 2012 
the visible emissions from the converter capture systems as seen by the outside 

observers. To obtain the required number of 1-minute intervals, the observation 

period may be divided into two or more segments performed on the same day or 

on different days if conditions prevent the required number of opacity readings 

from being obtained during one continuous time period. Examples of these 

conditions include, but are not limited to, changes in the sun’s orientation relative 

to visible emission observers’ positions such that the Method 9 conditions are no 

longer met or weather conditions that interfere with the observers’ ability to 

record acceptable opacity readings. If the total observation period is divided into 

two or more segments, all opacity observations shall be made during the same set 

of copper production conditions described in your approved test plan as required 

by Condition VI.A.5.a of this Attachment. 

f. The Permittee shall gather indoor process information during all times that the 

visible emission observers are making opacity readings outside the building 

housing the copper converter department. The indoor process monitor shall 

continually observe the operations occurring in the copper converter department 

and prepare a written record of his or her observations using the procedure 

specified below: 

(1) At the beginning of each observation period or segment, the clock time 

setting on the watch or clock to be used by the indoor process monitor 

shall be synchronized with the clock time settings for the timepieces to 

be used by the outdoor opacity observers. 

(2) During each period or segment when opacity readings are being made by 

the visible emission observers, the indoor process monitor shall 

continuously observe the operations occurring in the copper converter 

department and record his or her observations in a log book, on data 

sheets, or other type or permanent written format. 

(3) When a batch copper converter is blowing, a record shall be prepared for 

the converter that includes, but is not limited to, the clock times for when 

blowing begins and when blowing ends and the converter blowing rate. 

This information may be recorded by the indoor process monitor or by a 

separate, automated computer data system. 

(4) The process monitor shall record each event other than converter 

blowing that occurs in or nearby the converter aisle that he or she 

observes to generate visible emissions inside the building. The recorded 

entry for each event shall include, but is not limited to, a description of 

the event and the clock times when the event begins and when the event 

ends. 

g. The Permittee shall prepare a summary of the data for the entire observation 

period using the information recorded during the observation period by the 

outdoor visible emission observers and the indoor process monitor and the 

procedure specified below: 

(1) Using the field data sheets, identify the 1-minute clock times for which a 

total of eight opacity readings were made and recorded by both observers 

at 15-second intervals according to the test procedures (i.e., a total of 

four opacity values have been recorded for the 1-minute interval by each 

of the two observers). Calculate the average of the eight 15-second 

Permit No. 53592 Page 41 of 97 November 26, 2012 
interval readings recorded on the field data sheets by the two observers 

during the clock time minute interval (add the four consecutive 15-

second interval opacity readings made by observer A during the specified 

clock time minute, plus the four consecutive 15-second interval opacity 

readings made by observer B during the same clock time minute, and 

divide the resulting total by eight). Record the clock time and the 

opacity average for the 1-minute interval on a data summary sheet. 

(2) Using the data summary sheets prepared according to Condition 

VI.A.5.g(1) above and the process information recorded according to 

Condition VI.A.5.f(3) of this section, identify those 1-minute intervals 

for which at least one of the batch copper converters was blowing. 

(3) Using the data summary sheet prepared according to Condition 

VI.A.5.g(2) above and the process information recorded according to 

Condition VI.A.5.f(4) of this Section, identify the 1-minute intervals 

during which at least one copper converter was blowing but none of the 

interference events listed in Condition VI.A.5.g(3)(a) through (f) below 

occurred. Other ancillary activities not listed but conducted in or 

adjacent to the converter aisle during the opacity observations are not 

considered to be interference events (e.g., converter aisle cleaning, 

placement of smoking ladles or skulls on the converter aisle floor). 

(a) Charging of copper matte, reverts, or other materials to a batch 

copper converter; 

(b) Skimming slag or other molten materials from a batch copper 

converter; 

(c) Pouring of blister copper or other molten materials from a batch 

copper converter; 

(d) Return of slag or other molten materials to the smelting furnace 

or slag cleaning vessels; 

(e) Roll-out or roll-in of the batch copper converter; or 

(f) Smoke and fumes generated inside the converter building by 

operation of the smelting furnace, the slag cleaning vessel (if 

used), anode refining and casting processes that drift into the 

copper converter department. 

(4) Using the data summary sheets prepared according to Condition 

VI.A.5.g(3) above up to five 1-minute intervals following an interference 

event may be eliminated from data used for the compliance 

determination calculation specified in Condition VI.A.5.h below by 

applying a time delay factor. The delay factor shall be a constant number 

of minutes not to exceed 5 minutes that is added to the clock time 

recorded when cessation of the interference event occurs. The same time 

delay factor shall be used for all interference events (i.e., a constant time 

delay factor for the smelter of 1 minute, 2 minutes, 3 minutes, 4 minutes, 

or 5 minutes). The number of minutes to be used for the time delay 

factor is determined based on the site-specific equipment and converter 

building configuration. An explanation of the rationale for selecting the 

Permit No. 53592 Page 42 of 97 November 26, 2012 
value used for the time delay factor shall be prepared and included in the 

test report. 

h. The Permittee shall use the date summary prepared in Condition VI.A.5.g above 

to calculate the average opacity value for a minimum of 120 1-minute intervals 

during which at least one copper converter was blowing with no interference 

events as determined according to Conditions VI.A.5.g(3) and (4) above. 

Average opacity is calculated using the equation below: 

 

 n 

VEave = 1/n Σ VEi 

 i=1 

Where 

 VEave = Average opacity to be used for compliance determination 

(percent); 

n = Total number of 1-minute intervals during which at least one copper 

converter was blowing with no interference events as determined 

according to Conditions VI.A.5.g(3) and (4) above (at least 120 1-minute 

intervals); 

i = 1-minute interval “i” during which at least one copper converter was 

blowing with no interference events as determined according to 

Conditions VI.A.5.g(3) and (4) above; and 

VEi = Average opacity value calculated for the eight opacity readings 

recorded during 1-minute interval “i” (percent). 

 

i. The Permittee shall certify that the copper converter department capture system 

operated during the performance test at the operating limits established in the 

capture system operation and maintenance plan using the procedure specified 

below: 

(1) Concurrent with all opacity observations, measure and record values for 

each of the operating limit parameters in the capture system operation 

and maintenance plan according to the monitoring requirements specified 

in Condition VI.A.3.b of this Attachment. 

(2) For any dampers that are manually set and remain in the same position at 

all times the capture system is operating, the damper position shall be 

visually checked and recorded at the beginning and end of each opacity 

observation period segment. 

(3) Review the recorded monitoring data. Identify and explain any times 

during batch copper converter blowing when the capture system operated 

outside the applicable operating limits. 

(4) Certify in the performance test report that during all observation period 

segments, the copper converter department capture system was operating 

at the values or settings established in the capture system operation and 

maintenance plan. 

Permit No. 53592 Page 43 of 97 November 26, 2012 
7. Permit Shield 

Compliance with the conditions of this Part shall be deemed compliance with A.A.C. 

R18-2-702.B, A.A.C. R18-2-702.E, 40 CFR 63.1444(d)(1), (3) and (4), 40 CFR 

63.1450(c), 40 CFR 63.1452(a), and 40 CFR 63.1453(b). [A.A.C. R18-2-325] 

B. Sulfur Dioxide 

1. Emission Limitations/Standards 

The Permittee shall not exceed the overall emission limit for sulfur dioxide specified in 

Attachment “C”. [Condition II.E of Att. B of Installation Permit #1232 and A.A.C. R18-2-331.A.3.a] 

 [Material permit conditions are identified by italics and underline] 

2. Monitoring, Recordkeeping, and Reporting Requirements 

As a means of determining smelter fugitive emissions, the Permittee shall perform 

monthly material balances for sulfur in accordance with the sulfur balance procedures 

prescribed in Attachment “D” of this permit. [A.A.C. R18-2-306.A.3.c] 

3. Permit Shield 

Compliance with the conditions of this Part shall be deemed compliance with Condition 

II.E of Att. B of Installation Permit #1232. [A.A.C. R18-2-325] 

C. Lead 

 

1. Emission Limitations/Standards 

a. The Permittee shall not exceed the emission limit for Lead specified in 

Attachment “C” for the smelter fugitives. 

 [Condition II.F.2 of Att. B of Installation Permit #1232 and A.A.C. R18-2-331.A.3.a] 

 [Material permit conditions are identified by italics and underline] 

b. The quantity of lead in the total feed to all smelting furnaces shall not exceed 

3102 tons in any rolling twelve month period. 

 [A.A.C. R18-2-306.01 and A.A.C. R18-2-331.A.3.a] 

 [Material permit conditions are identified by italics and underline] 

2. Monitoring, Recordkeeping, and Reporting Requirements 

Compliance with the feed limitations of lead in Condition VI.C.1.b above shall be 

determined by using the results of monthly tests of composite feed samples to calculate, 

on a monthly basis, the quantity of lead in the total feed to the furnaces. A 12-month 

rolling total shall be calculated at the end of each month. [A.A.C. R18-2-306.A.3.c] 

3. Permit Shield 

Compliance with the conditions of this part shall be deemed compliance with Condition 

II.F.2 of Att. B of Installation Permit #1232. [A.A.C. R18-2-325] 

Permit No. 53592 Page 44 of 97 November 26, 2012 
VII. FACILITYWIDE REQUIREMENTS (MULTI POINT ROLLBACK RULE) 

A. General Provisions 

1. Applicability 

The requirements of this Section are applicable to the total of sulfur dioxide emissions 

from smelter processing units and sulfur dioxide control and removal equipment, but not 

to uncaptured fugitive emissions or emission due solely to the use of fuel for space 

heating or steam generation. [A.A.C. R18-2-715.01.A]

2. Definitions 

a. An “operating day”, for the purpose of this section, means any day in which 

sulfur containing feed is introduced into the smelting process. 

 [A.A.C. R18-2-715.01(J)] 

b. “Compliance period”, for the purposes of this section, means the 365 calendar 

days immediately preceding the end of each day of the month being reported 

unless that period includes less than 300 operating days. In such case the number 

of days preceding the last day of the compliance period shall be increased until 

the compliance period contains 300 operating days. [A.A.C. R18-2-715.01(J)] 

B. Emission Limitations and Standards 

1. Annual average SO2 emissions from the stacks as calculated under Condition VII.C.4.a of 

this Attachment shall not exceed 604 pounds per hour. [A.A.C. R18-2-715.F.2.a]

2. The number of three-hour average emissions as calculated under Condition VII.C.4.b of 

this Attachment shall not exceed n cumulative occurrences in excess of E, the emission 

level, shown below in any compliance period: [A.A.C. R18-2-715.F.2.b] 

Allowable SO2 emissions profile 

Occurrences, n Emission Level, E (lbs/hr) Occurrences, n Emission Level, E (lbs/hr)

0 8678 180 1145

1 7158 245 1064

2 5903 330 1015

4 4575 435 968

7 4074 560 933

12 3479 710 896

20 3017 890 862

32 2573 1100 828

48 2111 1340 797

68 1703 1610 765

94 1461 1910 739

130 1274 2240 712

Permit No. 53592 Page 45 of 97 November 26, 2012 
3. In addition to the limits in Conditions VII.B.1 and 2 above, the Permittee shall not 

discharge or cause the discharge of sulfur dioxide into the atmosphere from combined 

stack and fugitive emissions units in excess of the 2420 pounds per hour annual average 

calculated under R18-2-715.01(U). [A.A.C. R18-2-715.H]

C. Monitoring, Recordkeeping and Reporting Requirements 

1. Sulfur Balance 

As a means of determining total overall emissions, the Permittee shall perform monthly 

material balances for sulfur in accordance with the procedures prescribed in the 

Attachment “D” of this permit. [A.A.C. R18-2-715.01.O]

2. For purposes of determining compliance with the cumulative occurrence and emission 

limits contained in Conditions VII.B.1 and 2 of this Attachment, the Permittee shall 

continue to calibrate, maintain, and operate a measurement system for continuously 

monitoring sulfur dioxide concentrations and stack gas volumetric flow rates of the 

following: [A.A.C. R18-2-715.01.K, K.1 and K.2, A.A.C. R-18-2-331.A.3.c] 

 [Material permit conditions are indicated by italics and underline]

a. Acid Plant Tailgas Stack 

b. Vent Fume Stack 

3. All the SO2 CEMS and stack gas volumetric flow rate measurement systems shall comply 

with the requirements for continuous emission monitoring systems in Section VIII of this 

Attachment. [A.A.C. R18-2-306.A.3.c]

4. For purposes of determining compliance with the cumulative occurrence and emission 

limits contained in Conditions VII.B.1 and 2 of this Section, the annual average 

emissions and three-hour emissions shall be determined as follows: 

a. The Permittee shall, at the end of each day, calculate annual average SO2 

emissions by averaging the SO2 emissions for all hours measured during the 

compliance period ending on that day. [A.A.C. R18-2-715.01.C.1] 

b. The Permittee shall, at the end of each clock hour, calculate three-hour SO2

emissions averages by averaging the hourly SO2 emissions for the preceding 

three consecutive hours provided each such hour was measured in accordance 

with the requirements of Condition VII.C.2 above. [A.A.C. R18-2-715.01.C.2]

c. The actual cumulative occurrence and emission level shall be determined using 

the sum total of sulfur dioxide emissions from the smelter processing units and 

sulfur dioxide control and removal equipment. The captured fugitive emissions 

shall be included as part of the total plant emissions, but not the uncaptured 

fugitive emissions and those emissions due solely to the use of fuel for space 

heating or steam generation. [A.A.C. R18-2-715.01.A and 715.01.K.2] 

5. The Permittee shall determine compliance with the emission limit contained in Condition 

VII.B.3 as follows: 

a. The Permittee shall calculate annual average stack emissions at the end of the last 

day of each month by averaging the emissions for all hours measured during the 

Permit No. 53592 Page 46 of 97 November 26, 2012 
previous 12-month period ending on that day according to the requirements 

contained in this Section. [A.A.C. R18-2-715.01.U.1]

b. The Permittee shall calculate annual average fugitive emissions at the end of the 

last day of each month by averaging the monthly emissions for the previous 12-

month period ending on that day. To determine monthly fugitive emissions, the 

Permittee shall perform material balances for sulfur according to the sulfur 

balance procedures prescribed Attachment “D” of this permit. 

 [A.A.C. R18-2-715.01.U.2]

6. Periods of malfunction, startup, shutdown or other upset conditions shall be included in 

the determining compliance with the cumulative occurrence or annual average emission 

limits under Conditions VII.B.1, 2 and 3. [A.A.C. R18-2-715.01.B]

7. Violation Determination 

For purposes of this section, the following scenarios shall be considered violations of the 

cumulative occurrence and/or emission limits contained in Conditions VII.B.1, 2 and 3 of 

this Section: 

a. An annual emissions average in excess of the allowable annual average emission 

limit in Condition VII.B.1 of this Section shall be considered a violation if either: 

(1) The annual average is larger than the annual average computed for the 

preceding day; or [A.A.C. R18-2-715.01.C.1.a] 

(2) The annual averages computed for the five preceding days all exceed the 

allowable annual average emission limit. [A.A.C. R18-2-715.01.C.1.b]

b. A three-hour emissions average in excess of an emission level (E) will be 

considered to violate the associated cumulative occurrence limit (n) listed in 

Condition VII.B.2 of this Section if both: 

(1) The number of all three-hour emissions averages measured during the 

compliance period in excess of that emission level exceeds the 

cumulative occurrence limit associated with the emission level; and [A.A.C. R18-2-715.01.E.1]

(2) The average was measured during the last operating day of the 

compliance period being reported. [A.A.C. R18-2-715.01.E.2]

 

c. A three-hour emissions average can only violate the cumulative occurrence limit 

(n) of an emission level (E) in the day containing the last hour in the average. [A.A.C. R18-2-715.01.F]

 

d. Multiple violations of a cumulative occurrence limit in the same day and 

violations of different cumulative limits in the same day shall constitute a single 

violation. [A.A.C. R18-2-715.01.G]

 

e. The violation of any cumulative occurrence limit and an annual average emission 

limit in the same day shall constitute only a single violation. 

 [A.A.C. R18-2-715.01.H] 

 

Permit No. 53592 Page 47 of 97 November 26, 2012 
f. Multiple violations of a cumulative occurrence limit by different three-hour 

emissions averages containing any common hour shall constitute a single 

violation. [A.A.C. R18-2-715.01.I] 

g. An annual emissions average in excess of the allowable annual average emission 

limit in Condition VII.B.3 shall be considered a violation if the total of the stack 

and fugitive annual averages computed at the end of each month exceeds the 

allowable annual average emission limit. ` [A.A.C. R18-2-715.01.U.3] 

8. Recordkeeping and Reporting Requirements 

a. The Permittee shall maintain a record of all average hourly emissions 

measurements and calculated average monthly emissions required by this 

Section. [A.A.C. R18-2-715.01.P]

b. All of the following measurement results and calculated average monthly 

emissions shall be expressed as pounds per hour of sulfur dioxide and shall be 

summarized monthly and submitted to the Director within 20 days after the end 

of each month: [A.A.C. R18-2-715.01.P]

(1) For all periods described in Condition VII.C.4 of this Section, the annual 

average emissions as calculated at the end of each day of the month; 

(2) The total number of hourly periods during the month in which 

measurements were not taken and the reason for loss of measurement for 

each period; 

(3) The number of three-hour emissions averages which exceeded each of 

the applicable emissions levels listed in Condition VII.B.2 for the 

compliance periods ending on each day of the month being reported; 

(4) The date on which a cumulative occurrence limit listed in Condition 

VII.B.2 was exceeded if such exceedance occurred during the month 

being reported. 

(5) For all periods described in Condition VII.C.5 of this Section, the annual 

average emissions as calculated at the end of the last day of each month. 

c. Along with the monthly reports above, the Permittee shall submit the following 

reports: [A.A.C. R18-2-306.A.5.a]

(1) Reports of sulfur dioxide emissions (stack and total) in tons per year for 

the preceding twelve months to demonstrate compliance with the limits 

specified in Attachment “C”. 

(2) Reports to demonstrate compliance with Condition I.C of Attachment 

“D”. 

(3) Reports of monthly sulfur balance broken down into the major process 

streams that constitute the sulfur balance. 

Permit No. 53592 Page 48 of 97 November 26, 2012 
d. Bypass reporting requirements 

At each point in the permitted smelter facility where a means exists to bypass the 

sulfur removal equipment, such bypass shall be instrumented and monitored to 

detect and record all periods that the bypass is in operation. The Permittee shall 

report to the Director, not later than the 15th day of each month, the information 

required to be recorded by this Section. Such report shall include an explanation 

for the necessity of the use of the bypass. [A.A.C. R18-2-715.01.Q]

D. Permit Shield 

Compliance with the conditions of this Section shall be deemed compliance with A.A.C. R18-2-

715.F.2, A.A.C. R18-2-715.H, A.A.C. R18-2-715.01.A, A.A.C. R18-2-715.01.B, A.A.C. R18-2-

715.01.C, A.A.C. R18-2-715.01.E, A.A.C. R18-2-715.01.F, A.A.C. R18-2-715.01.G, A.A.C. 

R18-2-715.01.H, A.A.C. R18-2-715.01.I, A.A.C. R18-2-715.01.J, A.A.C. R18-2-715.01.K, 

A.A.C. R18-2-715.01.O, A.A.C. R18-2-715.01.P, A.A.C. R18-2-715.01.Q, and A.A.C. R18-2-

715.01.U. [A.A.C. R18-2-325] 

VIII. GENERAL PROVISIONS FOR CONTINUOUS MONITORING SYSTEMS 

A. General Requirements 

1. The SO2 CEMS shall meet 40 CFR Part 60, Appendix B, "Performance Specification 6 -

Specifications and Test Procedures for SO2 and NOx Continuous Emission Monitoring 

Systems in Stationary Sources". The CEMS shall follow a quality assurance procedure 

equivalent to 40 CFR 60 Appendix F. [40 CFR 60.13(a), A.A.C. R18-2-715.01.K.5.a, A.A.C. R18-2-331.A.3.c] [Material permit conditions are indicated by italics and underline] 

2. All the stack gas volumetric flow rate measurement systems shall meet 40 CFR Part 60, 

Appendix B, “Performance Specification 6 - Specifications and Test Procedures for 

Continuous Emission Rate Monitoring Systems in Stationary Sources”. [A.A.C. R18-2-715.01.K.5.a and b] 

 

3. For the purpose of the CEMS performance evaluation, the reference method for Relative 

Accuracy Test procedure under Performance Specification 2, Appendix B shall be 

Method 6, each concentration measurement shall be of one hour duration, and the 

pollutant gas for preparing calibration gas mixture and calibration checks shall be sulfur 

dioxide. [40 CFR 60.13(c), 40 CFR 60.165(b)(2)(ii), A.A.C. R18-2-331.A.3.c] 

 [Material permit conditions are indicated by italics and underline] 

4. The Permittee shall notify the Director in writing at least 30 days in advance of the start 

of relative accuracy test audit (RATA) procedures performed on the continuous 

monitoring system. [A.A.C. R18-2-715.01.K.5.c]

5. Location change of all sampling points for monitoring sulfur dioxide concentrations and 

stack gas volumetric flow rates shall be approved in writing by the Director. 

 [A.A.C. R18-2-715.01.K.5.d] 

6. The measurement system installed and used is subject to the manufacturer's 

recommended zero adjustment and calibration procedures at least once per 24-hour 

operating period unless the manufacturer specifies or recommends calibration at shorter 

intervals, in which case specifications or recommendations shall be followed. The 

Permit No. 53592 Page 49 of 97 November 26, 2012 
Permittee shall make available a record of these procedures that clearly shows instrument 

readings before and after zero adjustment and calibration. [A.A.C. R18-2-715.01.K.5.e] 

7. The Permittee shall measure at least 95 percent of the hours during which emissions 

occurred in any month, using the continuous monitoring systems. [A.A.C. R18-2-715.01.L] 

 

8. Failure to measure any 12 consecutive hours of emissions in accordance with the 

requirements in this Section shall constitute a violation. [A.A.C. R18-2-715.01.M] 

9. The Permittee shall maintain on hand and ready for immediate installation sufficient 

spare parts or duplicate systems for the continuous monitoring equipment required by this 

subsection to allow for the replacement within six hours of any monitoring equipment 

part which fails or malfunctions during operation. [A.A.C. R18-2-715.01.N] 

B. Calibration drift checks 

1. The Permittee shall check the zero (or low-level value between 0 and 20% of span value) 

and span (50 to 100 percent of span value) calibration drifts (CD) at least once daily in 

accordance with a written procedure prescribed by the manufacturer. [40 CFR 60.13(d)(1)] 

2. Zero and span drift adjustments [40 CFR 60.13(d)(1)] 

a. The zero and span shall, as a minimum, be adjusted whenever the 24-hr zero drift 

or 24-hr span drift exceeds + 5% of the span value. 

b. The CEMS shall allow for the amount of excess zero and span drift measured at 

the 24-hour interval checks to be recorded and quantified. 

C. Minimum frequency of operation 

1. Except during periods of system breakdowns, repairs, calibration checks, and zero and 

span adjustments, the SO2 CEMS shall be in continuous operation. [40 CFR 60.13(e)(2)] 

2. For purposes above, continuous monitoring means the taking and recording of at least 

one measurement of sulfur dioxide concentration and stack gas flow rate reading from the 

effluent of each affected stack, outlet or other approved measurement location in each 15-

minute period. Fifteen-minute periods start at the beginning of each clock hour, and run 

consecutively. An hour of smelter emissions is continuously monitored if the emissions 

from all monitored stacks, outlets, or other approved measurement locations are 

measured for at least 45 minutes of any hour. [A.A.C. R18-2-715.01.K.4]

3. If Permittee can demonstrate to the Director that measurement of stack gas volumetric 

flow in the outlet of any particular piece of sulfur dioxide control equipment would yield 

inaccurate results or would be technologically infeasible, then the Director may allow 

measurement of the flow rate at an alternative sampling point. [A.A.C. R18-2-715.01.K.3] 

D. Data reduction procedures [40 CFR 60.13(h)]

1. The Permittee shall reduce all data from the CEMS to 1-hour averages. The 1-hour 

averages shall be computed from four or more data points equally spaced over each 1-

hour period. 

2. Data recorded during periods of system breakdowns, repairs, calibration checks, and zero 

and span adjustments shall not be included in the data averages computed under the 

Permit No. 53592 Page 50 of 97 November 26, 2012 
previous paragraph. An arithmetic or integrated average of all data may be used. The 

data may be recorded in reduced or non-reduced form. 

E. Recordkeeping and Reporting Requirements 

1. The Permittee shall maintain records of the occurrence and duration of any startup, 

shutdown, or malfunction in the operation of an affected facility under this Section; any 

malfunction of the air pollution control equipment; or any periods during which a 

continuous monitoring system or monitoring device is in operative. [40 CFR 60.7(b)] 

2. The Permittee shall maintain a file of all measurements, including continuous monitoring 

system, monitoring device, and performance testing measurements; all continuous 

monitoring system performance evaluations; all continuous monitoring system or 

monitoring device calibration checks; adjustments and maintenance performed on these 

systems or devices; and all other information required by this section recorded in a 

permanent form suitable for inspection. The file shall be retained for at least five years 

following the date of such measurements, maintenance, reports and records. [40 CFR 60.7(f) and A.A.C. R18-2-306(A)(4)(b)] 

3. Quarterly excess emissions and monitoring systems performance reports 

a. The Permittee shall submit an excess emissions and monitoring systems 

performance (MSP) report and/or a summary report form to the Department for 

every calendar quarter, unless the total duration of excess emissions for the 

reporting period is less than 1 percent of the total operating time for the reporting 

period and the continuous monitoring system downtime for the reporting period 

is less than 5 percent of the total operating time for the reporting period, in which 

case only the summary report form shall be submitted and the excess emissions 

report need not be submitted unless requested by the Department. All quarterly 

reports shall be postmarked by the 30th day following the end of each calendar 

quarter. [40 CFR 60.7(c) and (d)] 

b. The summary report form submission required in the Condition VIII.E.3.a above 

shall be in the format specified in 40 CFR 60.7(d). Each excess emission and 

MSP report shall include the following information: [40 CFR 60.7(c)] 

(1) The magnitude of excess emissions computed, any conversion factor(s) 

used, and the date and time of commencement and completion of each 

time period of excess emissions. The process operating time during the 

reporting period. 

(2) Specific identification of each period of excess emissions that occurs 

during startups, shutdowns, and malfunctions of the affected facility. 

The nature and cause of any malfunction (if known), the corrective 

action taken or preventative measures adopted. 

(3) The date and time identifying each period during which the continuous 

monitoring system was inoperative except for zero and span checks and 

the nature of the system repairs or adjustments. 

(4) When no excess emissions have occurred or the continuous monitoring 

system(s) have not been inoperative, repaired, or adjusted, such 

information shall be stated in the report. 

Permit No. 53592 Page 51 of 97 November 26, 2012 
F. Permit Shield 

Compliance with the conditions of this Section shall be deemed compliance with A.A.C. R18-2-

715.01.K.3, A.A.C. R18-2-715.01.K.4, A.A.C. R18-2-715.01.K.5.a, A.A.C. R18-2-715.01.K.5.b, 

A.A.C. R18-2-715.01.K.5.c, A.A.C. R18-2-715.01.K.5.d, A.A.C. R18-2-715.01.K.5.e, A.A.C. 

R18-2-715.01.L, A.A.C. R18-2-715.01.M, and A.A.C. R18-2-715.01.N. [A.A.C. R18-2-325] 

IX. CONVERTER ARSENIC CHARGING RATE 

A. Arsenic Charging Rate Determination 

1. The Permittee shall determine the converter arsenic charging rate as follows: [40 CFR 61.174(f)]

a. Collect daily grab samples of copper matte charged to the copper converters. 

b. Each calendar month, from the daily grab samples collected, put together a 

composite copper matte sample. Analyze the composite sample individually 

using Method 108A, 108B, or 108C to determine the weight percent of inorganic 

arsenic contained in each sample. 

c. Calculate the converter arsenic charging rate once per month using the following 

equation: 

 

 

 Rc= Converter arsenic charging rate (kg/hour or pounds/hour). 

Rc = ∑ (i=1 to n) :{(Ac · Wci) + (Al · Wli)} 

 {100 Hc} 

Ac= Monthly average weight percent of arsenic in the copper matte charged 

during the month (%) as determined under Condition IX.A.1.b above. 

Ac= Monthly average weight percent of arsenic in the copper matte charged 

during the month (%) 

Wci= Total weight of copper matte charged to a copper converter during the 

month (kg). 

Hc= Total number of hours the copper converter department was in operation 

during the month (h). 

n= Number of copper converters in operation during the month. 

d. Determine an annual arsenic charging rate for the copper converter department 

once per month by computing the arithmetic average of the 12 monthly converter 

arsenic charging rate values (Rc) for the preceding 12-month period. 

2. If the total arsenic charging rate for the copper converter department averaged over a 1-

year period is less than 75 kg/hr (165 lb/hr), the Permittee shall comply with the 

recordkeeping and reporting requirements in Condition IX.B below. If the charging rate 

is greater than 75 kg/hr (165 lb/hr), the Permittee shall comply with the additional 

requirements under 40 CFR 61.172(b) through (f), 40 CFR 61.173, 40 CFR 61.174(a) 

through (e), 40 CFR 61.175, 40 CFR 61.176(a) and (b), and 40 CFR 61.177(a) through 

(e). [40 CFR 61.172(a)] 

Permit No. 53592 Page 52 of 97 November 26, 2012 
B. Recordkeeping and Reporting Requirements 

1. The Permittee shall maintain at the source for a period of at least 2 years and make 

available to the Director upon request the following records: 

a. For each copper converter, a daily record of the amount of copper matte charged 

to the copper converter and the total hours of operation. [40 CFR 61.176(c)(1)]

b. For each copper converter department, a monthly record of the weight percent of 

arsenic contained in the copper matte as determined under Condition XI.A.1 of 

this Section. [40 CFR 61.176(c)(2)]

c. For each copper converter department, the monthly calculations of the average 

annual arsenic charging rate for the preceding 12-month period as determined 

under Condition XI.A.1 of this Section. [40 CFR 61.176(c)(3)]

2. The Permittee shall submit annually a written report to the Director that includes the 

monthly computations of the average annual converter arsenic charging rate as calculated 

under Condition XI.A.1.d of this Section. The annual report shall be postmarked by the 

30th day following the end of each calendar year. [40 CFR 61.177(f)] 

C. Permit Shield 

Compliance with the conditions of this Section shall be deemed compliance with 40 CFR 

61.172(a), 40 CFR 61.174(f), 40 CFR 61.176(c)(1), 40 CFR 61.176(c)(2), 40 CFR 61.176(c)(3), 

and 40 CFR 61.177(f) [A.A.C. R18-2-325] 

X. ANODE FURNCES AND UTILITY VESSEL 

A. Emission Limitations/Standards 

Except as provided in Conditions X.A.1 and 2 below, the Permittee shall not cause, allow or 

permit to be emitted into the atmosphere, any plume or effluent from the anode furnaces and 

utility vessel which exceeds 20% opacity as measured by EPA Reference Method 9. [A.A.C. R18-2-702.B] 

1. The Permittee shall not cause, allow or permit to be emitted into the atmosphere, any 

plume or effluent from the anode furnaces and utility vessel during periods when low 

blister copper is present which exceeds 33% opacity as measured by EPA Reference 

Method 9. [A.A.C. R18-2-702.E]

2. The Permittee shall not cause, allow or permit to be emitted into the atmosphere, any 

plume or effluent from the anode furnaces and utility vessel during periods when poling 

takes place in the anode vessel which exceeds 33% opacity as measured by EPA 

Reference Method 9. [A.A.C. R18-2-702.E]

B. Air Pollution Control Requirements 

The Permittee shall maintain and operate the steam injection system associated with each of the

anode furnaces and utility vessels to minimize particulate matter emissions when natural gas is 

being used for reducing. [A.A.C. R18-2-306.A.2 and A.A.C. R18-2-331.A.3.e] 

 [Material permit conditions are identified by italics underline] 

Permit No. 53592 Page 53 of 97 November 26, 2012 
C. Monitoring, Recordkeeping, and Reporting Requirements 

A certified Method 9 observer shall conduct a bi-weekly (once in two weeks) visual survey of 

visible emissions from the anode furnaces and utility vessels building, when in operation, as per 

the procedure in Condition I.D.3 of this Attachment. [A.A.C. R18-2-306.A.3.c] 

D. Permit Shield 

Compliance with the conditions of this Section shall be deemed compliance with A.A.C. R18-2-

702.B and A.A.C. R18-2-702.E. [A.A.C. R18-2-325]

XI. BOILERS/HEATERS IN SMELTER 

 A. IsaSmelt Auxiliary Boiler 

 

1. Fuel Limitation

a. The Permittee shall burn only natural gas in the IsaSmelt auxiliary boiler. [A.A.C.R18-2-306.A.2] 

b. Monitoring, Recordkeeping and Reporting Requirements 

(1) The Permittee shall maintain records of the amounts of fuel combusted 

during each calendar month. [40 CFR §60.48c(g)(2)]

(2) All records of monthly fuel combusted shall be maintained by the 

Permittee for a period of two years following the date of such record.

 [40 CFR §60.48c(i)]

 

c. Permit Shield 

Compliance with the conditions of this Part shall be deemed compliance with the 

40 CFR §60.48c(g) and (i). [A.A.C. R18-2-325] 

2. Nitrogen Oxides (NOX) 

a. Emission Limitations and Standards 

The Permittee shall not discharge or cause to be discharged from the IsaSmelt

auxiliary boiler NOX emissions in excess of 1.8 lb/hr. [A.A.C. R18-2-406.A.4]

b. Performance Testing Requirements 

The Permittee shall conduct or cause to be conducted, a performance test on the 

IsaSmelt auxiliary boiler in the first year of the permit term for NOX to 

demonstrate compliance with the emission limits specified in Condition XI.A.2.a 

above. EPA Reference Method 7E shall be used to determine the emissions of 

NOX. [A.A.C. R18-2-312 and A.A.C. R18-2-306.A.3.c] 

 

Permit No. 53592 Page 54 of 97 November 26, 2012 
B. Change Room Water Heater and Acid Plant Preheater 

1. Fuel Limitations 

The Permittee shall only burn natural gas in the change room water heater and the acid 

plant preheater. [A.A.C. R18-2-306.A.2]

 2. Particulate Matter and Opacity 

a. Emission Limitations and Standards 

(1) The Permittee shall not cause, allow or permit the emission of particulate 

matter, caused by the combustion of fuel in the change room water heater 

and the acid plant preheater in excess of the amount calculated by the 

following equation: [A.A.C. R18-2-724.C.1]

E = 1.02Q0.769 

Where: 

E = the maximum allowable particulate emissions rate in pounds mass 

per hour. 

Q = the heat input in million Btu per hour. 

(2) The Permittee shall not cause, allow or permit to be emitted to the 

atmosphere from the change room water heater and the acid plant 

preheater any plume or effluent which exceeds 15% opacity. 

 [A.A.C. R18-2-724.J] 

b. Monitoring, Reporting, and Recordkeeping Requirements 

(1) A certified Method 9 observer shall conduct a monthly visual survey of 

visible emissions from the stacks of the change room water heater and 

the acid plant preheater as per the procedure in Condition I.D.3 of this 

Attachment. [A.A.C. R18-2-306.A.3.c] 

(2) The Permittee shall report all 6-minute periods during which the visible 

emissions from the change room water heater and the acid plant 

preheater exceeds 15% opacity. [A.A.C. R18-2-724.J] 

 

3. Permit Shield 

Compliance with the conditions of this Part shall be deemed compliance with A.A.C. 

R18-2-724.C.1 and A.A.C.R18-2-724.J. [A.A.C. R18-2-325] 

XII. SCREENING MACHINE 

A. Applicability 

This Section applies to the Screening Machine used for screening copper-containing material as 

well as non-copper containing material 

Permit No. 53592 Page 55 of 97 November 26, 2012 
B. Particulate Matter and Opacity 

1. Emission Limitations and Standards 

 

a. The Permittee shall not cause, allow or permit the discharge of particulate matter 

into the atmosphere in any one hour from the Screening Machine subject to the 

provisions of this Section in total quantities in excess of the amounts calculated 

by one of the following equations: [A.A.C.R18-2-721.B and A.A.C. R18-2-722.B] 

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

hour (30 tons per hour) or less, the maximum allowable emissions shall 

be determined by the following equation: 

 E = 4.10P0.67 

 where: 

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

per hour. 

 

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

 

 (2) For process sources having a process weight rate greater than 60,000 

pounds per hour (30 tons per hour), the maximum allowable emissions 

shall be determined by the following equation: 

E = 55P 0.11 - 40 

Where E and P are defined as indicated in Condition XII.B.1.a(1) above. 

 

b. The opacity of any plume or effluent from any process source subject to the 

provisions of this Section shall not be greater than 20% as measured by EPA 

Reference Method 9. [A.A.C. R18-2-702.B.3]

c. If the presence of uncombined water is the only reason for an exceedance of the 

visible emissions requirements in Condition XII.B.1.b above, the exceedance 

shall not constitute a violation of the applicable opacity limit. [A.A.C. R18-2-702.C] 

C. Air Pollution Control Requirements 

 

1. The Permittee shall operate Spray bar pollution controls in accordance with “EPA 

Control of Air Emissions From Process Operations In The Rock Crushing Industry”(EPA 

340/1-79-002), “Wet Suppression System” (pages 15-34, amended as of January 1979 

(and no future amendments or editions)), as incorporated herein by reference and on file 

with the Office of the Secretary of State, with placement of spray bars and nozzles as 

required by the Director to minimize air pollution. [A.A.C.R18-2-722.D] 

2. The fugitive emissions from the screening plant shall be controlled in accordance with 

Section XIX of this Attachment. [A.A.C.R18-2-722.E]

D. Monitoring, Recordkeeping, and Reporting Requirements 

1. A certified Method 9 observer shall conduct a bi-weekly (once in two weeks) visual 

survey of visible emissions emanating from the screening machine, when in operation, as 

Permit No. 53592 Page 56 of 97 November 26, 2012 
per the procedure in Condition I.D.3 of this Attachment. [A.A.C.R18-2-722.G] 

2 The Permittee shall maintain a record of daily production rates of material processed by 

the Screening Machine. [A.A.C.R18-2-722.G] 

E. Permit Shield 

Compliance with the conditions of this Section shall be deemed compliance with A.A.C.R18-2-

721.B, A.A.C. R18-2-722.B, A.A.C. R18-2-702.B.3, A.A.C. R18-2-702.C, A.A.C.R18-2-722.D, 

A.A.C.R18-2-722.E and A.A.C.R18-2-722.G. [A.A.C. R18-2-325] 

XIII. ELECTROLYTIC REFINERY OPERATIONS 

 

A. Boiler 

1. Fuel Limitation

The Permittee shall burn only natural gas in the boiler. [A.A.C.R18-2-306.02] 

2. Monitoring, Recordkeeping and Reporting Requirements 

a. The Permittee shall maintain records of the amounts of fuel combusted during 

each calendar month. [40 CFR §60.48c(g)(2)] 

b. All records monthly fuel combusted shall be maintained by the Permittee for a 

period of two years following the date of such record. [40 CFR §60.48c(i)]

 

3. Permit Shield 

Compliance with the conditions of this Part shall be deemed compliance with the 40 CFR 

§60.48c(g) and (i). [A.A.C. R18-2-325] 

B. Electrolytic Refinery 

1. Particulate Matter and Opacity 

a. Emission Limitations and Standards 

(1) In any one hour period, the Permittee shall not cause, allow or permit the 

discharge of particulate matter from the stacks associated with the 

refinery into the atmosphere in excess of the amounts calculated by one 

of the following equations: [A.A.C. R18-2-730.A.1]

 

(a) For process sources having a process weight rate of 60,000 

pounds per hour (30 tons per hour) or less, the maximum 

allowable emissions shall be determined by the following 

equation: 

 E= 4.1P0.67

 

 Where: 

E = the maximum allowable particulate emissions rate in 

pounds-mass per hour. 

Permit No. 53592 Page 57 of 97 November 26, 2012 
 P = the process weight rate in tons-mass per hour 

(b) For process sources having a process weight rate greater than 

60,000 pounds per hour (30 tons per hour), the maximum 

allowable emissions shall be determined by the following 

equation: 

 E = 55P0.11 - 40 

Where “E” and “P” are defined as indicated in Condition 

XIII.B.1.a(1) above. 

 

(2) Opacity 

The Permittee shall not cause to be discharged into the atmosphere, any 

visible emissions from stacks associated with refinery which exhibit 

greater than 20 percent opacity. [A.A.C. R18-2-702.B] 

b. Air Pollution Control Requirements 

The Permittee shall maintain and operate the baghouse associated with the 

anode slimes dryer for minimizing emissions of particulate matter. [A.A.C. R18-2-306.A.2 & A.A.C. R18-2-331.A.3.d] 

 [Material permit conditions are identified by underline and italics] 

c. Monitoring, Recordkeeping, and Reporting Requirements 

A certified Method 9 observer shall conduct a bi-weekly (once in two weeks) 

visual survey of visible emissions from the stacks associated with refinery, when 

they are in operation, as per the procedure in Condition I.D.3 of this Attachment. [A.A.C. R18-2-306.A.3.c]

5. Permit Shield 

Compliance with the conditions of this part shall be deemed compliance with 

A.A.C. R18-2-702.B and A.A.C. R18-2-730.A.1. [A.A.C. R18-2-325] 

2. Sulfuric Acid Mist and Volatile Organic Compounds 

a. Emission Limitations and Standards 

(1) The Permittee shall not cause the emission of gaseous or odorous 

materials from equipment and operations associated with the refinery 

process in such quantities or concentrations as to cause air pollution. [A.A.C. R18-2-730.D] 

(2) Materials including solvents or other volatile compounds, acids, and 

alkalis utilized in the refinery process 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. [A.A.C. R18-2-730.F] 

Permit No. 53592 Page 58 of 97 November 26, 2012 
(3) 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 

is discharged to adjoining property, the Director may require the 

installation of abatement equipment or the alteration of such stack, vent 

or other outlet by the Permittee thereof to a degree that will adequately 

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

property. [A.A.C. R18-2-730.G] 

b. Air Pollution Control Requirements 

(1) The Permittee shall maintain and operate the demisters associated with 

the cathode stripping and washing area in the electrolytic refinery for 

minimizing emissions of sulfuric acid mist. [A.A.C. R18-2-306.A.2 & A.A.C. R18-2-331.A.3.d] 

 [Material permit conditions are identified by underline and italics]

 

(2) The Permittee shall maintain and operate the two scrubbers associated 

with the electrolyte circulation tanks and electrolyte decant/storage tanks 

in the electrolytic refinery for minimizing emissions of sulfuric acid mist. [A.A.C. R18-2-306.A.2 & A.A.C. R18-2-331.A.3.d] 

 [Material permit conditions are identified by underline and italics]

(3) The Permittee shall maintain and operate the scrubber associated with 

the slimes autoclave in the electrolytic refinery for minimizing emissions 

of sulfuric acid mist. [A.A.C. R18-2-306.A.2 & A.A.C. R18-2-331.A.3.d] 

 [Material permit conditions are identified by underline and italics]

 

c. Monitoring, Recordkeeping, and Reporting Requirements 

The Permittee shall maintain a record of the control measures used at the 

refinery. [A.A.C. R18-2-306.A.3.c] 

d. Permit Shield 

Compliance with the conditions of this part shall be deemed compliance with 

A.A.C. R18-2-730.D, F, and G. [A.A.C. R18-2-325] 

XIV. ROD PLANT 

A. Thermal breaker Heater 

 

1. Fuel Limitations 

The Permittee shall only burn natural gas in the rod plant thermal breaker heater. [A.A.C. R18-2-306.A.2]

 2. Particulate Matter and Opacity 

a. Emission Limitations/Standards 

(1) The Permittee shall not cause, allow or permit the emission of particulate 

matter, caused by the combustion of fuel in excess of the amount 

calculated by the following equation: [A.A.C. R18-2-724.C.1]

E = 1.02 Q 0.769 

Permit No. 53592 Page 59 of 97 November 26, 2012 
Where: 

E = the maximum allowable particulate emissions rate in pounds mass 

per hour. 

Q = the heat input in million Btu per hour. 

(2) The Permittee shall not cause, allow or permit to be emitted to the 

atmosphere from the rod plant thermal breaker heater any effluent which 

exceeds 15% opacity. [A.A.C. R18-2-724.J] 

b. Monitoring, Reporting, and Recordkeeping Requirements 

(1) A certified Method 9 observer shall conduct a monthly visual survey of 

visible emissions from rod plant thermal breaker heater as per the 

procedure in Condition I.D.3 of this Attachment. [A.A.C. R18-2-306.A.3.c] 

(2) The Permittee shall report all 6-minute periods during which the visible 

emissions from any affected equipment exceeds 15% opacity. 

 [A.A.C. R18-2-724.J] 

4. Permit Shield 

Compliance with the conditions of this part shall be deemed compliance with 

A.A.C.R18-2-724.C.1 and A.A.C.R18-2-724.J. [A.A.C. R18-2-325]

B. Rod Plant Shaft Furnace 

1. Fuel Limitations 

The Permittee shall only burn natural gas as fuel in the rod plant shaft furnace. [A.A.C. R18-2-306.A2] 

2. Particulate Matter and Opacity 

a. Emission Limitations and Standards 

(1) In any one hour period, the Permittee shall not cause, allow or permit the 

discharge of particulate matter from the the rod plant shaft furnace into 

the atmosphere in excess of the amounts calculated by one of the 

following equations: [A.A.C. R18-2-730.A.1]

(a) For process sources having a process weight rate of 60,000 

pounds per hour (30 tons per hour) or less, the maximum 

allowable emissions shall be determined by the following 

equation: 

 E= 4.1P 0.67

 

 Where: 

E = the maximum allowable particulate emissions rate in 

pounds-mass per hour. 

Permit No. 53592 Page 60 of 97 November 26, 2012 
 P = the process weight rate in tons-mass per hour 

(b) For process sources having a process weight rate greater than 

60,000 pounds per hour (30 tons per hour), the maximum 

allowable emissions shall be determined by the following 

equation: 

 E = 55P0.11 - 40 

Where “E” and “P” are defined as indicated in Condition 

XIV.B.2.a(1)(a) above. 

 

(2) The Permittee shall not cause to be discharged into the atmosphere, any 

visible emissions from the affected units which exhibit greater than 20 

percent opacity. [A.A.C. R18-2-702.B] 

b. Monitoring, Recordkeeping, and Reporting Requirements 

A certified Method 9 observer shall conduct a bi-weekly (once in two weeks) 

visual survey of visible emissions from the rod plant shaft furnace, when in 

operation, as per the procedure in Condition I.D.3 of this Attachment. 

 [A.A.C. R18-2-306.A.3.c]

c. Permit Shield 

Compliance with the conditions of this part shall be deemed compliance with 

A.A.C. R18-2-702.B and A.A.C. R18-2-730.A.1. [A.A.C. R18-2-325] 

3. Sulfur Dioxide 

a. Emission Limitation and Standards 

The Permittee shall not cause, allow, or permit the discharge of sulfur dioxide 

from the rod plant shaft furnace into the atmosphere in excess of 600 parts per 

million. [A.A.C. R18-2-730.A.2]

 

b. Permit Shield 

Compliance with the conditions of this Part shall be deemed compliance with 

A.A.C. R18-2-730.A.2. [A.A.C. R18-2-325] 

4. Nitrogen Oxides 

a. Emission Limitations/Standards 

The Permittee shall not cause, allow, or permit the discharge of nitrogen oxides 

from the rod plant shaft furnace into the atmosphere in excess of 500 parts per 

million. [A.A.C. R18-2-730.A.3] 

 

b. Permit Shield 

Compliance with the conditions of this Part shall be deemed compliance with 

A.A.C. R18-2-730.A.3. [A.A.C. R18-2-325] 

Permit No. 53592 Page 61 of 97 November 26, 2012 
5. Volatile Organic Compounds (VOCs) 

a. Emission Limitations and Standards 

(1) The Permittee shall not cause the emission of gaseous or odorous 

materials in such quantities or concentrations as to cause air pollution. [A.A.C. R18-2-730.D]

(2) Materials including solvents or other volatile compounds, acids, and 

alkalis 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. [A.A.C. R18-2-730.F]

(3) 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 

is discharged to adjoining property, the Director may require the 

installation of abatement equipment or the alteration of such stack, vent 

or other outlet by the Permittee thereof to a degree that will adequately 

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

property. [A.A.C. R18-2-730.G] 

b. Permit Shield 

Compliance with the conditions of this Section shall be deemed compliance with 

A.A.C. R18-2-730.D, A.A.C. R18-2-730.F, and A.A.C R18-2-730.G. 

 [A.A.C. R18-2-325] 

XV. MISCELLANEOUS STORAGE TANKS 

A. Applicability 

This Section is applicable to the following tanks at the facility: 

1. Sulfuric acid tanks 

2. Used oil tanks 

3. Alcohol tanks 

B. Emission Limitations/Standards 

1. The Permittee shall not cause the emission of gaseous or odorous materials in such 

quantities or concentrations as to cause air pollution. [A.A.C. R18-2-730.D]

2. Materials including solvents or other volatile compounds, acids, and alkalis 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. 

 [A.A.C. R18-2-730.F]

Permit No. 53592 Page 62 of 97 November 26, 2012 
Permit No. 53592 Page 63 of 97 November 26, 2012 

3. 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 is discharged to adjoining 

property, the Director may require the installation of abatement equipment or the 

alteration of such stack, vent or other outlet by the Permittee thereof to a degree that will 

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

property. [A.A.C. R18-2-730.G]

C. Permit Shield 

Compliance with the conditions of this Section shall be deemed compliance with A.A.C. R18-2-

730.D, A.A.C. R18-2-730.F, and A.A.C R18-2-730.G. [A.A.C. R18-2-325] 

XVI. GASOLINE STORAGE TANKS 

A. Operating Limitations 

1. Each gasoline storage tank shall be equipped with a submerged filling device or 

acceptable equivalent, for control of hydrocarbon emissions. [A.A.C. R18-2-710.B] 

2. All pumps and compressors that handle gasoline shall be equipped with mechanical seals 

or other equipment of equal efficiency to prevent release of organic contaminants into the 

atmosphere. [A.A.C. R18-2-710.D] 

B. Monitoring and Recordkeeping Requirements 

 

1. The Permittee shall maintain a file, of the typical Reid vapor pressure of gasoline stored 

and of the dates of storage. Records of the dates on which any storage vessel is empty 

shall also be maintained. [A.A.C. R18-2-710.E.1] 

2. The Permittee shall record the average monthly temperature and true vapor pressure of 

gasoline at such temperature if the true vapor pressure is greater than 470 mm Hg (9.1 

psia) and the gasoline is stored in a storage vessel other than one equipped with a vapor 

recovery system or its equivalent. [A.A.C. R18-2-710.E.2.b]

3. The average monthly storage temperature shall be an arithmetic average calculated for 

each calendar month, or portion thereof, if storage is for less than a month, from bulk 

liquid storage temperatures determined at least once every seven days. 

 [A.A.C. R18-2-710.E.3]

4. The true vapor pressure shall be determined by the procedures in American Petroleum 

Institute Bulletin 2517, amended as of February 1980 (and no future editions), which is 

incorporated herein by reference and on file with the Office of the Secretary of State. 

This procedure is dependent upon determination of the storage temperature and the Reid 

vapor pressure, which requires sampling of the petroleum liquids in the storage vessels. 

Unless the Director requires in specific cases that the stored petroleum liquid be sampled, 

the true vapor pressure may be determined by using the average monthly storage 

temperature and the typical Reid vapor pressure. For those liquids for which certified 

specifications limiting the Reid vapor pressure exist, the Reid vapor pressure may be 

used. For other liquids, supporting analytical data must be made available upon request to 

the Director when typical Reid vapor pressure is used. [A.A.C. R18-2-710.E.4] 
C. Permit Shield 

Compliance with the conditions of this Section shall be deemed compliance with A.A.C. R18-2-

710.B, A.A.C. R18-2-710.D, A.A.C. R18-2-710.E.1, A.A.C. R18-2-710.E.2.b, A.A.C. R18-2-

710.E.3 and A.A.C. R18-2-710.E.4. [A.A.C. R18-2-325] 

XVII. DIESEL ENGINES 

A. Engines subject to Existing Source Requirements 

1. Applicability 

The requirements in this Section are applicable to the following stationary diesel-fired 

engines: 

a. 1100-hp Converters genset 

b. 750-hp Isa genset 

c. 335-hp stem plant pump 

d. 63-hp Finlay screen engine 

 

2. Fuel Limitations 

The Permittee shall only fire diesel in the internal combustion engines. [A.A.C. R18-2-306.A.2] 

3. Particulate Matter and Opacity 

a. Emissions Limitations and Standards 

 

(1) The Permittee shall not cause, allow or permit the emission of particulate 

matter, caused by combustion of fuel, from any stationary rotating 

machinery into the atmosphere in excess of the amounts calculated by 

the following equation: [A.A.C. R18-2-719.C.1] 

 E = 1.02Q0.769

 Where 

E = the maximum allowable particulate emission rate in poundsmass per hour 

 Q = the heat input in million Btu per hour 

(2) The Permittee shall not 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. [A.A.C. R18-2-719.E] 

Permit No. 53592 Page 64 of 97 November 26, 2012 
b. Monitoring, Reporting, and Recordkeeping Requirements 

 

(1) The Permittee shall conduct a monthly monitoring of visible emissions 

from the generators when in operation as per the periodic opacity 

monitoring requirements specified in Condition I.D.3 of this Attachment. 

 [A.A.C. R18-2-306.A.3.c] 

(2) The Permittee shall keep records of fuel supplier certifications or other 

documentation containing information regarding lower heating value of 

the fuel. These records shall be made available to ADEQ upon request. [A.A.C. R18-2-306.A.3.c and A.A.C. R18-2-719.I]

c. Permit Shield 

 

Compliance with this Part shall be deemed compliance with A.A.C. R18-2-

719.B, A.A.C. R18-2-719.C.1, A.A.C. R18-2-719.E, and A.A.C. R18-2-719.I. 

 [A.A.C. R18-2-325] 

4. Sulfur Dioxide 

a. Emission Limitations and Standards 

(1) The Permittee shall not emit or cause to emit more than 1.0 pound of 

sulfur dioxide per million Btu heat input. [A.A.C. R18-2-719.F] 

(2) The Permittee shall not burn high sulfur diesel fuel (sulfur content 

greater than 0.9 % by weight) in the engine. [A.A.C. R18-2-719.H] 

b. Monitoring, Recordkeeping, and Reporting Requirements 

(1) The Permittee shall keep records of fuel supplier certifications or other 

documentation to demonstrate compliance with the sulfur content limit 

specified in Condition XVII.A.4.a(2) above. The certification shall 

contain the sulfur content of the fuel. These records shall be made 

available to ADEQ upon request. 

 [A.A.C. R18-2-306.A.3.c and A.A.C. R18-2-719.I]

(2) The Permittee shall report to the Director any daily period during which 

the sulfur content of the fuel being fired in the engine exceeds 0.8%. 

 [A.A.C. R18-2-719.J]

c. Permit Shield 

Compliance with the conditions of this Part shall be deemed compliance with 

A.A.C. R18-2-719.F, A.A.C. R18-2-719.H, A.A.C. R18-2-719.I, and A.A.C. 

R18-2-719.J. [A.A.C. R18-2-325] 

5. Nitrogen Oxides (NOx) 

a. Emission Limitations and Standards 

The Permittee shall not discharge or cause to be discharged from the IsaSmelt 

standby generator nitrogen oxide emissions in excess of 29 pounds per hour. [A.A.C. R18-2-406.A.4] 

 

Permit No. 53592 Page 65 of 97 November 26, 2012 
b. Performance Test Requirements 

 The Permittee shall conduct a performance test on the Issamelt standby generator 

in the first year of the permit term in accordance with EPA Reference Method 7E 

to demonstrate compliance with nitrogen oxide emission standard in Condition 

XVII.A.5.a above. [A.A.C. R18-2-312 and A.A.C. R18-2-306.A.3.c] 

B. Engines subject to New Source Performance Requirements 

1. Applicability 

This Section is applicable to the following diesel-fired emergency generators: 

a. 100 kw genset 

b. 20 kw genset 

c. 35 kw genset 

d. 50 kw genset 

c. 540 HP air compressor engines (2 Nos.) 

2. Installation Requirements 

 The Permittee shall not install a stationary compression ignition internal combustion 

engine that does not meet the applicable requirements for 2007 model year engines. 

 [40 CFR 60.4208(a)]

3. Operating Requirements 

a. The Permittee shall limit the use of diesel-fired generators to only emergency 

situations and required testing and maintenance such as to produce power for 

critical networks or equipment (including power supplied to portions of a 

facility) when electric power from the local utility is interrupted. [40 CFR 60.4219] 

b. The Permittee shall operate and maintain the diesel-fired generators over the 

entire life of the engine according to the manufacturer’s emission-related written 

instructions. A copy of the instructions shall be kept onsite and made available 

to ADEQ upon request. [40 CFR 60.4211(a)(1), 60.4206 and A.A.C. R18-2-306.A.3] 

c. The Permittee shall only change those emission-related settings that are permitted 

by the manufacturer. [40 CFR 60.4211(a)(2)]

d. The Permittee shall meet the applicable requirements of 40 CFR Part 89, 94 

and/or 1068. [40 CFR 60.4211(a)(3)] 

e. The Permittee shall install a non-resettable hour meter prior to startup of the 

engines. [R18-2-306.A.3.c, R18-2-331.A.3.c] 

 [Material Permit Conditions are indicated by underline and italics] 

f. The Permittee may operate the emergency generators for the purpose of 

maintenance checks and readiness testing, provided that the tests are 

recommended by Federal, State, or local government, the manufacturer, the 

vendor, or the insurance company associated with the engine. [40 CFR 60.4211(f)] 

Permit No. 53592 Page 66 of 97 November 26, 2012 
 

g. Maintenance checks and readiness testing of such units is limited to 100 hours 

per year. The Permittee may petition the Administrator and the Director for 

approval of additional hours to be used for maintenance checks and readiness 

testing, but a petition is not required if the Permittee maintains records indicating 

that Federal, State, or local standards require maintenance and testing these 

generators beyond 100 hours per year. The Permittee may operate the 

emergency stationary ICE for up to 50 hours per year in non-emergency 

situations, but those 50 hours are counted towards the 100 hours per year 

provided for maintenance and testing. [40 CFR 60.4211(f)]

h. Operation of the diesel-fired generators for any operation other than emergency 

operation, maintenance and testing, and operation in non-emergency situations 

for 50 hours per year, is prohibited. [40 CFR 60.4211(f); R18-2-331.A.3.a] 

 [Material Permit Conditions are indicated by underline and italics] 

4. Fuel Requirements 

The Permittee shall use diesel fuel that meets the requirements of non-road diesel fuel 

specified in 40 CFR 80.510(b) and listed below: [40 CFR 60.4207(b)]

a. Sulfur content: 15 ppm maximum; and 

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

percent. 

 

5. Emission Limitations and Standards 

The Permittee shall comply with the emission standards for new non-road engines 

specified in 40 CFR 60.4202. [40 CFR 60.4205(b)] 

6. Compliance Requirements 

a. The Permittee shall comply by purchasing engines certified to the emission 

standards in 40 CFR 60.4205(b). Each engine must be installed and configured 

according to the manufacturer's specifications. [40 CFR 60.4211 (c)]

b. If the Permittee does not install, configure, operate, and maintain the diesel-fired 

generators according to the manufacturer’s emission-related written instructions, 

or if the Permittee changes the emission-related setting in a way that is not 

permitted by the manufacturer, the Permittee shall demonstrate compliance by 

keeping a maintenance plan and records of maintenance conducted and shall, to 

the extent practicable, maintain and operate each engine in a manner consistent 

with good air pollution control practice for minimizing emissions. In addition, 

the Permittee shall conduct an initial performance test to demonstrate compliance 

with the applicable emission standards within 1 year of such action. 

 [40 CFR 60.4211 (g)]

7. Recordkeeping Requirements [40 CFR 60.4214(b)] 

a. If the emergency generator does not meet the standards applicable to nonemergency engines in the applicable model year, the Permittee shall keep records 

of emergency and non-emergency operation as recorded through the nonresettable hour meter. 

Permit No. 53592 Page 67 of 97 November 26, 2012 
b. The Permittee shall maintain monthly records of the generator operations. The 

records shall include the reason of operation and the duration of time the 

generator was operated. 

C. National Emission Standards for Hazardous Air Pollutants (NESHAP) Requirements 

 

 1. Requirements for 335 HP feed water pump and 63 HP Finlay screening machine engines 

 a. The Permittee shall comply with the terms of this Part no later than May 3, 2013. [40 CFR 63.6595(a)]

b. General Operating Limitations/Requirements 

(1) At all times, the Permittee shall operate and maintain the engines, 

including associated air pollution control equipment and monitoring 

equipment, in a manner consistent with safety and good air pollution 

control practices for minimizing emissions. The general duty to 

minimize emissions does not require the Permittee to make any further 

efforts to reduce emissions if levels required by this standard have been 

achieved. Determination of whether such operation and maintenance 

procedures are being used will be based on information available to the 

Administrator and the Director which may include, but is not limited to, 

monitoring results, review of operation and maintenance procedures, 

review of operation and maintenance records, and inspection of the 

source. [40 CFR 63.6605(b)] 

(2) The Permittee shall operate and maintain the engines and after control 

device, if any, in accordance with manufacturer’s emission-related 

written instructions or develop a maintenance plan which must provide to 

the extent practicable for the maintenance and operation of the engine in 

a manner consistent with good air pollution control practice for 

minimizing emissions. [40 CFR 63.6625(e)] 

(3) The Permittee shall perform the following on each of the engines: 

 

(a) For the emergency engine, [40 CFR 63.6602, Table 2c, Item 1] 

(i) The Permittee shall change the oil and filter every 500 

hours of operation or annually, whichever comes first. 

 

(ii) The Permittee shall inspect the air cleaner every 1,000 

hours of operation or annually, whichever comes first. 

 

(iii) The Permittee shall inspect all hoses and belts every 500 

hours of operation or annually, whichever comes first, 

and replace as necessary. 

(b) For the non-emergency engine associated with Finlay screen. [40 CFR §63.6602-Table 2c Item 2] 

(i) The Permittee shall change oil and filter every 1,000 

hours of operation or annually, whichever comes first; 

(ii) The Permittee shall inspect air cleaner every 1,000 hours 

of operation or annually, whichever comes first; and 

Permit No. 53592 Page 68 of 97 November 26, 2012 
(iii) The Permittee shall inspect all hoses and belts every 500 

hours of operation or annually, whichever comes first, 

and replace as necessary. 

(c) The Permittee has the option of utilizing an oil analysis program 

in order to extend the specified oil change requirements in 

Conditions XVII.C.1.b(3)(a)(i) and (b)(i) above. The oil analysis 

shall be performed at the same frequency specified for changing 

the oil. The analysis program must at a minimum analyze total 

Base Number, viscosity; and percent water content. The 

condemning limits for these parameters are as follows: 

 [40 CFR §63.6625(i)] 

(i) Total Base Number is less than 30 percent of the Total 

Base Number of the oil when new; 

(ii) Viscosity of the oil has changed by more than 20 percent 

from the viscosity of the oil when new; or 

(iii) Percent water content (by volume) is greater than 0.5. 

If all of the above limits are not exceeded, the Permittee is not 

required to change the oil. . If any of the limits are exceeded, the 

Permittee must change the oil within 2 days of receiving the 

results of the analysis, or before commencing operation, 

whichever is later. The analysis program shall be part of the 

maintenance plan for the engine. 

(4) The Permittee shall minimize the engine’s time at idle during startup and 

minimize the engine’s startup time to a period needed for appropriate and 

safe loading of the engine, not to exceed 30 minutes. [40 CFR 63.6625(h)] 

(5) Additional Requirements for Emergency Engines 

(a) If the emergency engines are operating during an emergency and 

it is not possible to shut down the engines in order to perform the 

management practice requirements required in Condition 

Conditions XVII.C.1.b(3) above, or if performing the 

management practice on the required schedule would otherwise 

pose an unacceptable risk under federal, state, or local law, the 

management practice can be delayed until the emergency is over 

or the unacceptable risk under federal, state, or local law has 

abated. The management practice should be performed as soon 

as practicable after the emergency has ended or the unacceptable 

risk under federal, state, or local law has abated. The Permittee 

must report any failure to perform the management practice on 

the schedule required and the federal, state or local law under 

which the risk was deemed unacceptable. 

 [40 CFR 63.6603(a), Table 2d, Item 4, Footnote 2] 

(b) The Permittee shall install a non-resettable hour meter on the 

emergency engines if one is not already installed. [40 CFR 63.6625(f), A.A.C. R-18-2-331.A.3.c] 

 [Material Permit Condition identified by underline and italics] 

Permit No. 53592 Page 69 of 97 November 26, 2012 
(c) The Permittee shall not operate the engines for more than 50 

hours per year except during emergency situations or for 

maintenance and testing purposes. There is no time limit on the 

use of emergency engines in emergency situations. 

 [40 CFR 63.6640(f)(1)] 

(d) The Permittee may operate the engines for the purpose of 

maintenance checks and readiness testing, provided that the tests 

are recommended by federal, state or local government, the 

manufacturer, the vendor, or the insurance company associated 

with the engine. Maintenance checks and readiness testing of 

such units is limited to 100 hours per year. The Permittee may 

petition the Administrator for approval of additional hours to be 

used for maintenance checks and readiness testing, but a petition 

is not required if the Permittee maintains records indicating that 

federal, state, or local standards require maintenance and testing 

of the engine beyond 100 hours per year. [40 CFR 63.6640(f)(1)(ii)] 

(e) The Permittee may operate the engines up to 50 hours per year in 

non-emergency situations, but those 50 hours are counted 

towards the 100 hours per year provided for maintenance and 

testing. [40 CFR 63.6640(f)(1)(iii)]

c. Compliance Demonstration 

The Permittee shall demonstrate continuous compliance by operating and 

maintaining the engines according to the manufacturer's emission-related 

operation and maintenance instructions; or by developing and following own 

maintenance plan which must provide to the extent practicable for the 

maintenance and operation of the engine in a manner consistent with good air 

pollution control practice for minimizing emissions. 

 [40 CFR 63.6640(a), 40 CFR 63 Subpart ZZZZ-Table 6, Item 9] 

d. Reporting and Recordkeeping requirements 

(1) Reporting 

(a) The Permittee shall report each instance in which the Permittee 

did not meet each operating limitation in Condition 

XVII.C.1.b(3) of this Attachment. If a deviation from an 

operating limitation occurs during the reporting period, the 

following additional information shall be provided: 

 [40 CFR 63.6640(b), 40 CFR 63.6650 (d)] 

(i) The total operating time of the engine at which the 

deviation occurred during the reporting period. 

(ii) Information on the number, duration, and cause of 

deviations (including unknown cause, if applicable), as 

applicable, and the corrective action taken 

 

(b) The Permittee shall report all deviations from the applicable 

requirements of 40 CFR 63, Subpart ZZZZ in a Compliance 

Report along with the semiannual monitoring report required 

pursuant to Condition I.B of this Attachment. If the Compliance 

Permit No. 53592 Page 70 of 97 November 26, 2012 
report includes all required information concerning deviations 

from any emission or operating limitation in 40 CFR 63 Subpart 

ZZZZ, submission of the Compliance report shall be deemed to 

satisfy any obligation to report the same deviations in the 

semiannual monitoring report. For the purpose of permit 

deviation reporting in Condition XII.B of Attachment “A”, 

prompt reporting of deviations from applicable Subpart ZZZZ 

requirements shall mean that the Permittee report these 

deviations in the Compliance report along with the semiannual 

monitoring report required pursuant to Condition I.B. of this 

Attachment [40 CFR 63.6650 (f)] 

(2) The Permittee shall keep records of the following: 

 

(a) Records of the occurrence and duration of each malfunction of 

operation and monitoring equipment. [40 CFR 63.6655(a)(2)] 

(b) Records of actions taken during periods of malfunction, 

including corrective actions to restore malfunctioning process 

and monitoring equipment to its normal or usual manner of 

operation. [40 CFR 63.6655(a)(5)]

(c) Records required in Condition XVII.C.1.c above demonstrating 

continuous compliance with each operating limitation. 

 [40 CFR 63.6655(d)] 

(d) Records of the maintenance conducted on the engines in order to 

demonstrate that the facility operated and maintained the engine 

and after-treatment control device (if any) according to the 

Permittee’s own maintenance plan. [40 CFR 63.6655(e)] 

(e) Records of the hours of operation of the emergency engines 

recorded through the non-resettable hour meters. The Permittee 

shall document how many hours are spent for emergency 

operation; including what classified the operation as emergency 

and how many hours are spent for non-emergency operation. 

 [40 CFR 63.6655(f)]

 (f) Records of the parameters that are analyzed under the oil 

analysis program in Conditions XVII.C.1.b(3)(c) of this 

Attachment, the results of the analysis, the oil changes for the 

engine, and replacement of hoses and belts. [40 CFR 63.6625(i)]

2. Requirements for New Emergency Engines (Less than 500 HP) 

These engines shall meet the requirements of this Part by complying with the 

requirements under Condition XVII.B above. [40 CFR 63.6590(c)] 

3. Requirements for New Emergency Engines (More than 500 HP) 

These conditions are applicable to engines more than 500 HP and constructed after 

December 19, 2002. 

a. The Permittee shall not operate the engines for more than 50 hours per year 

except during emergency situations or for maintenance and testing purposes. 

Permit No. 53592 Page 71 of 97 November 26, 2012 
There is no time limit on the use of emergency engines in emergency situations. [40 CFR 63.6640(f)(1)] 

b. The Permittee may operate the engines for the purpose of maintenance checks 

and readiness testing, provided that the tests are recommended by federal, state or 

local government, the manufacturer, the vendor, or the insurance company 

associated with the engine. Maintenance checks and readiness testing of such 

units is limited to 100 hours per year. The Permittee may petition the 

Administrator for approval of additional hours to be used for maintenance checks 

and readiness testing, but a petition is not required if the Permittee maintains 

records indicating that federal, state, or local standards require maintenance and 

testing of the engine beyond 100 hours per year. [40 CFR 63.6640(f)(1)(ii)] 

c. The Permittee may operate the engines up to 50 hours per year in non-emergency 

situations, but those 50 hours are counted towards the 100 hours per year 

provided for maintenance and testing. [40 CFR 63.6640(f)(1)(iii)]

 

4. Permit Shield 

Compliance with the conditions in this Part shall be deemed compliance with 40 CFR 63: 

6595(a), 6603(a), 6605(a) and (b), 6625(e), (i) and (h), (f)(1), (f)(3), (f)(4), (i) and (h), 

63.6640(a), (b), and (f), 6650(d), and 6655(a), (d), (e) and (f). [A.A.C. R-18-2-325] 

XVIII. COOLING TOWERS 

A. General Operational Requirements 

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

premises in such quantities or concentrations so as to cause air pollution. [A.A.C. R18-2-730.D]

2. 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 is discharged to adjoining 

property, the Director may require the installation of abatement equipment or the 

alteration of such stack, vent, or other outlet by the Permittee thereof to a degree that will 

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

property. [A.A.C.R18-2-730.G] 

B. Particulate Matter and Opacity 

 

1. Emission Limitations/Standards 

a. The Permittee shall not cause or permit the emissions of particulate matter 

discharged into the atmosphere in any one hour from cooling towers in total 

quantities in excess of the amounts calculated by one of the following equations: 

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

hour (30 tons per hour) or less, the maximum allowable emissions shall 

be determined by the following equation: [A.A.C. R18-2-730.A.1]

E = 4.10P0.67 

Where: 

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

Permit No. 53592 Page 72 of 97 November 26, 2012 
per hour. 

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

(2) For process weight rate greater than 60,000 pounds per hour (30 tons per 

hour), the maximum allowable emissions shall be determined by the 

following equation: 

E = 55.0P 0.11 – 40 

Where "E" and "P" are defined as indicated in (1) above. 

 b. The Permittee shall not cause or allow to be discharged into the atmosphere any 

plume or effluent from the cooling towers which exhibits opacity greater than 

20%, measured in accordance with EPA Reference Method 9. Where the 

presence of uncombined water is the only reason for the exceedance of this 

opacity standard, such exceedance shall not constitute a violation. [A.A.C. R18-2-702.B and -702.C]

2. Air Pollution Control Requirements 

At all times, including periods of startup, shutdown, and malfunction, the Permittee shall, 

to the extent practicable, maintain and operate the cooling towers in a manner consistent 

with good air pollution control practice for minimizing particulate matter emissions. 

 [A.A.C. R18-2-306.A.2 and A.A.C. R18-2-331.A.3.e] 

 [Material Permit Condition are defined by double underline and italics] 

3. Monitoring, Record keeping and Reporting Requirements 

A certified Method 9 observer shall conduct a quarterly (once in 3 months) visual survey 

of visible emissions from cooling towers as per the procedure in Condition I.D.3 of this 

Attachment. [A.A.C. R18-2-306.A.3.c]

 

C. Permit Shield 

Compliance with the conditions in this Section shall be deemed compliance with A.A.C.R18-2-

730.D and A.A.C.R18-2-730.G. [A.A.C. R18-2-325] 

XIX. FUGITIVE DUST SOURCES 

A. Applicability 

This Section applies to all fugitive dust sources at the facility. 

B. Particulate Matter and Opacity 

Open Areas, Roadways & Streets, Storage Piles, and Material Handling 

1. Emission Limitations/Standards 

a. Opacity of emissions from any non-point dust source shall not be greater than 

40% measured in accordance with the Arizona Testing Manual, Reference 

Method 9. [A.A.C. R18-2-614]

Permit No. 53592 Page 73 of 97 November 26, 2012 
b. The Permittee shall not cause, allow or permit visible emissions from any point 

source, in excess of 20 percent opacity. [A.A.C-R18-2-702.B] 

c. The Permittee shall employ the following reasonable precautions to prevent 

excessive amounts of particulate matter from becoming airborne: 

(1) Keep dust and other types of air contaminants to a minimum in an open 

area where construction operations, repair operations, demolition 

activities, clearing operations, leveling operations, or any earth moving 

or excavating activities are taking place, by good modern practices such 

as using an approved dust suppressant or adhesive soil stabilizer, paving, 

covering, landscaping, continuous wetting, detouring, barring access, or 

other acceptable means; [A.A.C. R18-2-604.A]

(2) Keep dust to a minimum from driveways, parking areas, and vacant lots 

where motor vehicular activity occurs by using an approved dust 

suppressant, or adhesive soil stabilizer, or by paving, or by barring access 

to the property, or by other acceptable means; [A.A.C. R18-2-604.B] 

(3) Keep dust and other particulates to a minimum by employing dust 

suppressants, temporary paving, detouring, wetting down or by other 

reasonable means when a roadway is repaired, constructed, or 

reconstructed; [A.A.C. R18-2-605.A] 

(4) Take reasonable precautions, such as wetting, applying dust 

suppressants, or covering the load when transporting material likely to 

give rise to airborne dust; [A.A.C. R18-2-605.B] 

(5) Take reasonable precautions, such as the use of spray bars, wetting 

agents, dust suppressants, covering the load, and hoods when crushing, 

handling, or conveying material likely to give rise to airborne dust; 

 [A.A.C. R18-2-606]

(6) Take reasonable precautions such as chemical stabilization, wetting, or 

covering when organic or inorganic dust producing material is being 

stacked, piled, or otherwise stored; [A.A.C. R18-2-607.A]

(7) Operate stacking and reclaiming machinery utilized at storage piles at 

all times with a minimum fall of material, or with the use of spray bars 

and wetting agents; [A.A.C. R18-2-607.B] 

(8) Take reasonable precautions such as wetting, chemical stabilization, 

and revegetation to prevent excessive amounts of particulate matter 

from becoming airborne from mineral tailing piles. [A.A.C. R18-2-608] 

(9) Any other method as proposed by the Permittee and approved by the 

Director. [A.A.C. R18-2-306.A.3.c] 

b. Air Pollution Control Requirements 

Haul Roads and Storage Piles 

Water, or an equivalent control, shall be used to control visible emissions from haul 

roads and storage piles. [A.A.C. R-18-2-306.A.2 and -331.A.3.d] 

 [Material Permit Condition is indicated by underline and italics] 

Permit No. 53592 Page 74 of 97 November 26, 2012 
c. Monitoring and Recordkeeping Requirements 

(1) The Permittee shall maintain records of the dates on which any of the activities 

listed in Conditions XIX.B.1.c(1) through XIX.B.1.c(9) above were performed 

and the control measures that were adopted. [A.A.C. R18-2-306.A.3.c] 

(2). Opacity Monitoring Requirements 

The Permittee shall conduct a bi-weekly (once every two weeks) monitoring of 

visible emissions from the fugitive dust sources, when in operation, in 

accordance with the visual observation plan. The observation plan shall identify 

a central lookout station or multiple observation points, as appropriate, from 

where the fugitive dust sources shall be monitored. When multiple observation 

points are used, all the non point sources associated with each observation point 

shall be specifically identified within the observation plan. The observation shall 

be performed as per the periodic opacity monitoring requirements specified in 

Condition I.D.3 of this Attachment. [A.A.C. R18-2-306.A.3.c] 

d. Permit Shield 

Compliance with the conditions of this Section shall be deemed compliance with A.A.C. 

R18-2-604.A, A.A.C. R18-2-604.B, A.A.C. R18-2-605, A.A.C. R18-2-606, A.A.C. R18-

2-607, A.A.C. R18-2-608, A.A.C. R18-2-614 and A.A.C-R18-2-702.B. 

 [A.A.C. R18-2-325] 

XX. MOBILE SOURCES 

A. Applicability 

The requirements of this Section are applicable to mobile sources which either move while 

emitting air contaminants or are frequently moved during the course of their utilization but are 

not classified as motor vehicles, agricultural vehicles, or are agricultural equipment used in 

normal farm operations. Mobile sources shall not include portable sources as defined in A.A.C. 

R18-2-101.90. [A.A.C.R18-2-801.A]

B. Particulate Matter and Opacity 

1. Emission Limitations/Standards 

a. Off-Road Machinery 

The Permittee shall not cause, allow, or permit to be emitted into the atmosphere 

from any off-road machinery, smoke for any period greater than ten consecutive 

seconds, the opacity of which exceeds 40%. Visible emissions when starting 

cold equipment shall be exempt from this requirement for the first ten minutes. 

Off-road machinery shall include trucks, graders, scrapers, rollers, locomotives 

and other construction and mining machinery not normally driven on a 

completed public roadway. [A.A.C.R18-2-802]

b. Roadway and Site Cleaning Machinery 

(1) The Permittee shall not cause, allow or permit to be emitted into the 

atmosphere from any roadway and site cleaning machinery smoke or 

Permit No. 53592 Page 75 of 97 November 26, 2012 
dust for any period greater than ten consecutive seconds, the opacity of 

which exceeds 40%. Visible emissions when starting cold equipment 

shall be exempt from this requirement for the first ten minutes. 

 [A.A.C.R18-2-804.A]

(2) The Permittee shall take reasonable precautions, such as the use of dust 

suppressants, before the cleaning of a site, roadway, or alley. Earth or 

other material shall be removed from paved streets onto which earth or 

other material has been transported by trucking or earth moving 

equipment, erosion by water or by other means. [A.A.C. R18-2-804.B] 

c. Unless otherwise specified, no mobile source shall emit smoke or dust the 

opacity of which exceeds 40%. [A.A.C.R18-2-801.B]

 2. Recordkeeping Requirement 

The Permittee shall keep a record of all emissions related maintenance activities 

performed on the Permittee's mobile sources stationed at the facility as per manufacturer's 

specifications. [A.A.C.R18-2-306.A.5.a] 

C. Permit Shield 

Compliance with the conditions of this Section shall be deemed compliance with A.A.C. R18-2-

801, A.A.C. R18-2-802, A.A.C. R18-2-804.A and A.A.C. R18-2-804.B. [A.A.C.R18-2-325]

XXI. OTHER PERIODIC ACTIVITIES 

A. Abrasive Blasting 

Particulate Matter and Opacity 

1. Emission Limitations/Standards 

a. The Permittee shall not cause or allow sandblasting or other abrasive blasting 

without minimizing dust emissions to the atmosphere through the use of good 

modern practices. Good modern practices include: [A.A.C. R18-2-726]

(1) Wet blasting; 

(2) Effective enclosures with necessary dust collecting equipment; or 

(3) Slag-based abrasive material; or 

(4) Any other method approved by the Director. 

b. Opacity 

The Permittee shall not cause, allow or permit visible emissions from 

sandblasting or other abrasive blasting operations in excess of 20% opacity, as 

measured by EPA Reference Method 9. [A.A.C. R18-2-702.B] 

2. Monitoring and Recordkeeping Requirement 

Each time an abrasive blasting project is conducted, the Permittee shall log in ink or in an 

Permit No. 53592 Page 76 of 97 November 26, 2012 
electronic format, a record of the following: 

a. The date the project was conducted; 

b. The duration of the project; and 

c. Type of control measures employed. 

[A.A.C. R18-2-306.A.3.c] 

3. Permit Shield 

Compliance with the conditions of this Part shall be deemed compliance with A.A.C. 

R18-2-726, A.A.C. R18-2-702.B. [A.A.C.R18-2-325] 

B. Use of Paints 

1. Volatile Organic Compounds 

a. Emission Limitations/Standards 

While performing spray painting operations, the Permittee shall comply with the 

following requirements:

(1) The Permittee shall not conduct or cause to be conducted any spray 

painting operation without minimizing organic solvent emissions. Such 

operations, other than architectural coating and spot painting, shall be 

conducted in an enclosed area equipped with controls containing no less 

than 96 percent of the overspray. 

[A.A.C.R18-2-727.A] 

(2) The Permittee shall not either: 

(a) Employ, apply, evaporate, or dry any architectural coating 

containing photochemically reactive solvents for industrial or 

commercial purposes; or 

(b) Thin or dilute any architectural coating with a photochemically 

reactive solvent. 

[A.A.C.R18-2-727.B] 

(3) For the purposes of Conditions XXI.B.1.a(2) above, a photochemically 

reactive solvent shall be any solvent with an aggregate of more than 20 

percent of its total volume composed of the chemical compounds 

classified in Conditions XXI.B.1.a(3)(a) through XXI.B.1.a(3)(c) below, 

or which exceeds any of the following percentage composition 

limitations, referred to the total volume of solvent: 

(a) A combination of the following types of compounds having an 

olefinic or cyclo-olefinic type of unsaturation-hydrocarbons, 

alcohols, aldehydes, esters, ethers, or ketones: 5 percent. 

(b) A combination of aromatic compounds with eight or more 

carbon atoms to the molecule except ethylbenzene: 8 percent. 

Permit No. 53592 Page 77 of 97 November 26, 2012 
(c) A combination of ethylbenzene, ketones having branched 

hydrocarbon structures, trichloroethylene or toluene: 20 percent. [A.A.C.R18-2-727.C] 

(4) Whenever any organic solvent or any constituent of an organic solvent 

may be classified from its chemical structure into more than one of the 

groups of organic compounds described in Conditions XXI.B.1.a(3)(a) 

through XXI.B.1.a(3)(c) above, it shall be considered to be a member of 

the group having the least allowable percent of the total volume of 

solvents. [A.A.C.R18-2-727.D] 

b. Monitoring and Recordkeeping Requirements [A.A.C. R18-2-306.A.3.c]

(1) Each time a spray painting project is conducted, the Permittee shall 

record of the following: 

(a) The date the project was conducted; 

(b) The duration of the project; 

(c) Type of control measures employed; 

(d) Material Safety Data Sheets for all paints and solvents used in 

the project; and 

(e) The amount of paint consumed during the project. 

(2) Architectural coating and spot painting projects shall be exempt from the 

recordkeeping requirements of Condition XXI.B.1.b(1) above. 

c. Permit Shield 

Compliance with the conditions of this Part shall be deemed compliance with 

A.A.C.R18-2-727. [A.A.C.R18-2-325] 

2. Opacity 

a. Emission Limitation/Standard 

The Permittee shall not cause, allow or permit visible emissions from painting 

operations in excess of 20% opacity, as measured by EPA Reference Method 9. 

 [A.A.C. R18-2-702.B] 

b. Permit Shield 

Compliance with the conditions of this Part shall be deemed compliance with 

A.A.C.R18-2-702.B. [A.A.C. R18-2-325] 

C. Asbestos Requirements 

1. Emission Limitation/Standard 

The Permittee shall comply with all of the requirements of 40 CFR 61 Subpart M 

(National Emissions Standards for Hazardous Air Pollutants - Asbestos). 

Permit No. 53592 Page 78 of 97 November 26, 2012 
[A.A.C. R18-2-1101.A.8] 

2. Monitoring and Recordkeeping Requirement 

The Permittee shall keep all required records in a file. The required records shall include 

the “NESHAP Notification for Renovation and Demolition Activities” form and all 

supporting documents. [A.A.C. R18-2-306.A.3.c] 

3. Permit Shield 

Compliance with the conditions of this Part shall be deemed compliance with A.A.C. 

R18-2-1101.A.8. [A.A.C. R18-2-325] 

D. Nonvehicle Air Conditioner Maintenance and/or Services 

1. The Permittee shall comply with the applicable requirements of 40 CFR 82 - Subpart F 

(Protection of Stratospheric Ozone - Recycling and Emissions Reduction). 

[40 CFR 82, Subpart F]

2. As a means of demonstrating compliance with Condition XXI.D.1 above, the Permittee 

shall keep a record of all relevant paperwork to the applicable requirements of 40 CFR 82 

- Subpart F on file. [A.A.C. R18-2-306.A.3.c] 

3. Permit Shield 

Compliance with the conditions of this Part shall be deemed compliance with 40 CFR 52, 

Subpart F. [A.A.C. R18-2-325] 

XXII. AMBIENT MONITORING REQUIREMENTS [A.A.C. R18-2-715.02.E, A.A.C. R18-2-306.A.2] 

A. General Monitoring Requirements: 

1. Only those methods which have been either designated by EPA as reference or equivalent 

methods or approved by the Director shall be used to monitor ambient air. 

 [A.A.C. R18-2-215.A]

2. Quality assurance, monitor siting, and sample probe installation procedures shall be in 

accordance with procedures described in the Appendices to 40 CFR 58. 

 [A.A.C. R18-2-215.B]

3. The Director may approve other procedures upon a finding that the proposed procedures 

are substantially equivalent or superior to procedures in the Appendices to 40 CFR 58. [A.A.C. R18-2-215.C] 

4. Unless otherwise specified, interpretation of all ambient air quality standards contained in 

this Section shall be in accordance with 40 CFR 50. [A.A.C. R18-2-216] 

5. All ambient air quality monitoring shall be conducted in accordance with the regulations 

and guidance listed below as applicable: [A.A.C. R18-2-715.02.E]

a. National Primary and Secondary Ambient Air Quality Standards, 40 CFR Part 50 

and Appendices; 

b. Ambient Air Quality Surveillance, 40 CFR Part 58 and Appendices; and 

Permit No. 53592 Page 79 of 97 November 26, 2012 
c. Quality Assurance Handbook for Air Pollution Measurement Systems: “Volume 

I: A Field Guide to Environmental Quality Assurance”, EPA 600/R-94/038a, 

April 1994

d. Quality Assurance Handbook for Air Pollution Measurement Systems: “Volume 

II: Ambient Air Quality Monitoring Program”, EPA 454/B-08-003, December 

2008 

e. Meteorological Monitoring Guidance for Regulatory Modeling Applications, 

EPA 454/R-99-005, February 2000 

f. Quality Assurance Handbook for Air Pollution Measurement Systems: “Volume 

IV: Meteorological Measurement Version 2”, EPA 454/B-08-002, March 2008 

6. The Permittee shall conduct performance audits of the monitoring equipment in 

accordance with the requirements pertaining to sampler accuracy as specified in 40 CFR 

Part 58. The performance audits shall be conducted by a qualified independent auditor at 

least once every six months for particulate samplers and at least annually for gas 

analyzers and meteorological equipment. 

7. The Permittee shall participate in technical systems audits or performance audits 

conducted by the Department. The Department shall provide a minimum of 30 days 

notice of a technical systems audit and a minimum of 48 hours notice of a performance 

audit. 

8. After the ADEQ monitors are installed and fully operational, and upon getting written 

communication from ADEQ, the Permittee may discontinue submitting monitoring data 

from the Freeport McMoRan operated monitors. 

B. General Reporting Requirements 

1. The Permittee shall submit quarterly report summarizing the monitoring data 

measurements collected pursuant to this section before the 90th day of the following 

quarter. An annual report summarizing the quality assurance data for the calendar year 

shall be submitted before April 1st of the following year. 

2. Summary statistics must be calculated in accordance with procedures in 40 CFR Part 50 

and appendices. 

3. Valid data recovery shall meet the EPA minimum data completeness requirement of 75 

percent or the percentage specified in the applicable sections of 40 CFR Part 50 and 

appendices. Valid data are all observations collected for the specific monitoring purpose 

that have not been deemed invalid. Data collected during precision, audit, flow checks, 

and during servicing shall not be considered valid for data completeness purposes. For 

continuous analyzers there must be at least 18 or more valid hourly measurements per 

day to calculate a valid daily average for those pollutants requiring daily averaging. For 

filter-based (non-continuous) measurements, data completeness is based on quarterly data 

recovery. 

4. All data submitted to ADEQ shall be reviewed, quality assured, and certified by the 

Permittee. 

5. The sample data shall be submitted to ADEQ in electronic format. The required format is 

the Air Assessment Ambient Database (AAAD) format. The summary data may be 

Permit No. 53592 Page 80 of 97 November 26, 2012 
reported electronically in CSV file or spreadsheet format. These data are to be submitted 

by CD or DVD; submittal of files via e-mail or file transfer protocol (FTP) requires prior 

approval by ADEQ. 

6. AAAD parameter names and flags shall be used. The Permittee shall work with ADEQ 

assessment Section for approved AAAD format and flags. Adequate supporting 

information shall be provided to enable ADEQ to concur with the flags. In addition to 

any other reporting requirements specified in the permit, the ADEQ Air Assessment 

Section shall be notified within 30 days of any event that is expected to be or will be used 

as the basis for a flag requiring EPA concurrence (e.g., a ‘natural or an exceptional 

event’). 

7. One electronic and one hard copy of the quarterly and annual reports shall be mailed to 

the Air Assessment Section and the report’s cover letter without attachments shall be 

carbon copied to the Air Compliance Section of the Air Quality Division of the 

Department. 

8. The quarterly reports must include the following information: 

a. Data summaries for each monitor or parameter based on EPA data rules

b. Any field service activities including any maintenance and repair performed 

c. Identification of NAAQS exceedances 

d. Data recovery statistics for each monitor or parameter; 

e. CD or DVD containing the AAAD formatted data along with the electronic 

formatted QC data 

f. Copies (either hard copies or scanned copies included on CD or DVD) of all 

appropriate supporting documentation, including, but not limited to: 

(1) Copies of laboratory reports, if applicable; 

(2) Copies of all applicable quality control and field reports (e.g., precision 

checks, flow checks, calibrations, and audit reports); and 

(3) Documentation of problems and corrective actions, and explanations for 

discrepancies. 

9. The annual summary report must include the following information: 

a. Data summaries for each monitor or parameter based on EPA data rules; 

b. Compliance statistics (e.g. most recent three-year design value) based on 40 CFR 

Part 50 and appendices or ADEQ permit specific metrics; 

c. Identification of NAAQS exceedances 

d. Data recovery statistics for each monitor or parameter; 

e. QA/QC annual summary statistics as calculated in accordance with procedures in 

40 CFR Part 58 Appendix A. 

Permit No. 53592 Page 81 of 97 November 26, 2012 
f. If any changes to previously submitted data, a discussion of the reason for the 

changes and a CD or DVD containing the updated AAAD formatted data along 

with the electronic formatted QC data. 

C. Particulate Matter (PM)/Metals Monitoring-Specific Requirements 

1. The Permittee shall operate, maintain, and calibrate ambient PM10 sampling network 

consisting of two sampling sites located at the Miami Golf Course and the Miami 

Ridgeline. [A.A.C. R18-2-306.A.3.c, A.A.C. R18-2-331.A.3.c] 

 [Material Permit Condition indicated by underline and italics] 

 

2. Should the ADEQ request relocation of monitoring sites to alternate locations, the 

monitors shall be operating at those locations within 120 days of receipt of written 

notification provided the Permittee can secure the necessary utilities and approvals. 

3. Sample size to be measured: 

 0-10 microns 

 4. Sampling Frequency: 

The collection of PM samples with filter-based monitors shall follow the national EPA 

Monitoring Schedule posted on the EPA Ambient Monitoring Technology Information 

Center (AMTIC) website unless otherwise specified in the permit. 

5. Sample Laboratory Analysis: 

Each sample in shall be weighed and concentrations calculated and reported as twentyfour hour average concentrations in μg/m3. 

6. Reporting 

The Quarterly and Annual Summary Reports for each monitor must include: 

(a) Date of each measurement 

(b) Number of possible observations for the quarter; 

(c) Number of actual valid observations for the quarter; 

(d) Percent data completeness (number of actual valid observations divided by 

number of possible observations and multiplied by 100); 

(e) Total PM10 mass concentration for each measurement 

(f) Average PM10 concentration for the quarter calculated from valid 24-hour block 

daily averages 

(g) Highest and second highest 24-hour concentration values for PM10 for the quarter 

with dates of occurrence 

(h) Number of exceedances and number of expected exceedances, based on 40 CFR 

Part 50 Appendix K; 

(i) Precision and accuracy data as per 40 CFR 58; 

Permit No. 53592 Page 82 of 97 November 26, 2012 
(j) Supporting documentation 

(k) Each 24-hour sample value must be included in the report; each missing sample 

must have a missing value code (list provided by ADEQ) indicating the reason 

the sample is missing

(l) The results of laboratory analysis performed for the elemental mass 

concentrations required above. 

(m) Copies of the original laboratory data from the speciation analysis of filter 

samples must be provided to ADEQ. This may include electronic data or hardcopy reports. In addition, lead results shall be provided in AAAD format. 

D. Sulfur Dioxide Monitoring-Specific Requirements 

1. The Permittee shall operate, maintain, and calibrate an ambient monitoring network 

consisting of two continuous ambient sulfur dioxide monitors located at Townsite and 

Jones Ranch. [A.A.C. R18-2-715.E.02, A.A.C. R18-2-331.A.3.c] 

 [Material Permit Condition indicated by underline and italics] 

2. All samplers shall be operated, calibrated, and maintained in accordance with the 

procedures set forth in the respective manufacturer’s instruction manuals and in 

accordance with applicable sections and appendices of 40 CFR Parts 50 and 58 and the 

Quality Assurance Handbook for Air Pollution Measurement Systems, Volume II, U.S. 

Environmental Protection Agency. The Permittee shall use EPA approved SO2 samplers. 

3. Reporting Requirements 

a. The Permittee shall provide an electronic file of the monitoring data from all sites 

in the Department’s Data Collection System (DCS) format. 

These files shall contain the following: 

(1) Date and time of each measurement at each site; 

(2) The maximum 5-minute block average of SO2 concentrations for each 

hour in parts per million (ppm) or parts per billion (ppb), or all twelve 5-

minute block averages of SO2 concentrations for each hour. 

(3) Hourly average values of SO2 concentrations in ppm or ppb. 

 

b. The quarterly and annual reports shall also contain the following information, as 

appropriate. All concentration data must be presented in parts ppm or ppb. 

(1) Sample date, time, location and duration of sample time; 

(2) Individual sample data that include every sample scheduled to be 

collected during the reporting period or the reason why the sample is 

missing; 

(3) Hourly SO2 concentration data in AAAD format quality assured and 

validated by the Permittee, including appropriate AAAD flags. These 

data should be made available on CD or DVD

Permit No. 53592 Page 83 of 97 November 26, 2012 
(4) Data summaries based on EPA data rules, including the following: 

(i) Valid hours of data expressed as the percentage obtained by 

dividing the actual monthly valid data hours by the number of 

hours in that month; 

(ii) Average daily SO2 concentration for the quarter calculated from 

valid daily averages (per 40 CFR 50.4); 

(iii) Maximum and second highest 3-hour block average 

concentration of SO2 (per 40 CFR 50.5); 

(iv) Number of exceedances of the 1-hour, 24-hour or 3-hour 

standards; 

(v) The Annual Report must include an annual average of 24-hour 

SO2 quarterly averages (per 40 CFR 50.4), the annual 99th

percentile of the daily maximum 1-hour averages, and the most 

recent 3 year average of the annual 99th percentiles; 

(vi) Precision and accuracy data as per 40 CFR 58. 

c. In addition, to confirm data validation by the Permittee, all data reports should 

include copies of all appropriate supporting documentation including, but not 

limited to, the following: 

(1) Copies of all applicable quality control and field reports (e.g., precision 

checks, flow checks, and calibrations, audit reports); and 

(2) Documentation of problems and corrective actions, and explanations for 

discrepancies. 

(3) Documentation of exceedance 

 

d. All data submitted to the Director shall be reviewed, quality assured, and 

certified by the Permittee.

Permit No. 53592 Page 84 of 97 November 26, 2012 
ATTACHMENT “C” 

AIR QUALITY CONTROL PERMIT NO. 53592 

FOR 

FREEPORT-MCMORAN MIAMI, INC.

EMISSION SOURCES – MAXIMUM ALLOWABLE EMISSION RATES 

Emission Sulfur Dioxide Particulate Matter Lead

Point No.

Emission Source

Pounds 

per hour

Tons per 

year

Pounds 

per hour

Tons per 

year

Pounds 

per hour

Tons per 

year

001 Acid Plant Tail Gas 

Stack 

820.00 3515 20.40 87.67 0.10 0.44 

002 Vent Fume Stack 312.00 1336 46.30** 198.70 24.80 105.30 

003 Concentrate Bin Vent 0.08 0.32 

004 Concentrate Bin Vent 0.08 0.32 

005 Revert Bin 0.08 0.32 

006 Coal Bin 0.08 0.32 

007 Flux Bin 0.08 0.32 

Fugitives * 1288 5517 10.38 44.45 

Totals 2420 10368 

* Fugitive emissions will not be subject to an individual emission limit. They will be regulated by the 

emission cap identified in the table. 

** Alternatively, the Permittee must maintain a maximum 12-month rolling average stack flow rate of 

500,000 scfm. 

Permit No. 53592 Page 85 of 97 November 26, 2012 
ATTACHMENT “D”: SULFUR BALANCE METHODOLOGY 

AIR QUALITY CONTROL PERMIT NO. 53592 

FOR 

FREEPORT-MCMORAN MIAMI, INC. 

PROCEDURES FOR UTILIZING THE SULFUR BALANCE METHOD FOR DETERMINING 

SULFUR EMISSIONS 

I. DETERMINATION OF SULFUR EMISSIONS FOR THE SMELTER AS A WHOLE SHALL BE 

SUBJECT TO THE FOLLOWING CONDITIONS: 

A. The emission sum shall apply to all process sulfur emitted into the ambient air from smelter 

processing units and sulfur control and removal equipment associated with the smelting process. 

The total monthly amount of sulfur emissions is equal to the weight of the total sulfur introduced 

into the smelting process in any calendar month minus the weight of all sulfur removed from the 

smelting process streams in that month in any physical form, plus or minus the weight of the 

sulfur contained in any month-month decrease or increase necessary to indicate materials in 

process. Removed sulfur shall include but not be limited to sulfur contained in slag, blister 

copper, sulfuric acid, liquefied sulfur dioxide, elemental sulfur, flue dust, precipitator dust, acid 

plant sludge, scrubber effluent and absorption plant purge. All unremoved sulfur, including 

fugitive sulfur emissions, shall be considered as emissions to the ambient air. 

B. Material balances for sulfur described in I.A. above shall be obtained in accordance with the 

procedures listed in this Appendix which are equivalent to Appendix 8 to A.A.C. Title 18, 

Chapter 2. 

C. Average daily emissions are to be determined by dividing the total monthly emissions by the 

number of operating days in the particular month. 

II. CALCULATING INPUT SULFUR 

Total sulfur input is the sum of the product of the weight of each sulfur bearing material introduced into 

the smelting process as calculated in A.1 below multiplied by the fraction of sulfur contained in that 

material as calculated in A.2 below plus the amount of sulfur contained in fuel utilized in the smelting 

process as calculated in A.3 below. 

A. Material Weight 

All sulfur bearing materials, other than fuels, introduced into the smelting process shall be 

weighed. Such weighing shall be subject to the following conditions: 

1. Weight shall be determined on a belt scale, rail or truck scales, or other weighing device. 

 

2. Weight shall be determined within an accuracy of ±5 percent. 

3. All devices or scales used for weighing are to be calibrated to manufacturer’s 

specifications. Scales will be calibrated at least quarterly. The weight of the railroad 

weight car shall be recorded following calibration of the railroad weight scale. Records 

of the quarterly truck scale calibrations and weekly railroad weight scale checks shall be 

retained and made available to regulatory personnel when requested. 

4. Sulfur bearing materials subject to being weighed shall include but not be limited to 

concentrate, cement copper, reverts which are discarded and not part of the internal 

circulating load, and precipitates. Materials such as limestone and silica flux which are 

Permit No. 53592 Page 86 of 97 November 26, 2012 
mixed with a charge of sulfur bearing materials shall be weighed and reported. 

B. Sulfur Content 

The sulfur content of all sulfur bearing materials introduced into the smelting process shall be 

calculated using the following steps: 

1. Sampling – The procedure to be followed in sampling is dependent upon the input 

vehicles for the sulfur bearing material. 

a. Railcar – The smelter operator shall collect a sample using the auger method. 

Two holes per car will be taken and combined with the total sample not 

exceeding 20 pounds. Ten cars or less from the same source will be combined 

into one lot. 

b. Truck – The smelter operator shall collect a sample using the auger method. 

Samples are to be taken from at least two points using the auger method and shall 

be representative of the contents of the truck. Shipments from other Freeport 

McMoRan mines may be sampled at the mine site provided each truckload is 

sampled. Samples will be combined at Miami into lots from trucks delivering 

material from the same source. For fluxes from Freeport McMoRan controlled 

mines, one truckload per day will be sampled. 

2. Sample Preparation – Each total sample shall be prepared for analysis in the following 

manner: 

a. If necessary, the sample shall be crushed to minus quarter inch particles. 

b. Each sample is to be thoroughly blended in a roto-cone blender or similar device. 

c. A blended composite sample is to be prepared based on individual sample weight 

and moisture. Material to be used in the composite sample is to be cut with a 

sample scoop or knife and used to make a 2400 gram composite sample for each 

lot. 

d. Each composite sample is to be dried and then pulverized to minus 80 mesh 

using a roto-disc pulverizer or similar equipment and then blended in a roto-cone 

blender or similar equipment. 

e. A 200 gram portion is to be cut from the composite sample for analysis. 

3. Sample Analysis. 

 

a. The sample shall be analyzed to determine sulfur content using any of the 

following methods: 

(1) X-ray Fluorescence Spectroscopy (XRF). The XRF shall be calibrated 

using the Empirical Calibration method discussed in SW846 Method 

6200 Section 10.3. 

(2) Inductively Coupled Plasma Spectroscopy (ICP) 

(3) Barium sulfate gravimetric test method (provided in Standard Methods 

of Chemical analysis, Volume One, The Elements, sixth edition, N. 

Permit No. 53592 Page 87 of 97 November 26, 2012 
Howell Furman (ed.), D. Van Nostrand Company, Princeton, new Jersey, 

1962, pages 410-411, 1006-1011, and 1342-1343 and no future editions 

or amendments). 

b. The accuracy of sulfur analysis shall be within a range of ±1 percent 

4. Sulfur Determination 

The sulfur content of all feed material treated per month will be determined by month end 

physical inventories in conjunction with certified scales for bed contents. Physical 

inventory determines beginning and ending bed for each month and all beds processed 

during the month, together with inventory changes for secondaries. Based upon 

individual lot numbers for each material processed (i.e. concentrates, reverts, purchased 

secondaries, Resource Recycling material, and fluxes) the composite analysis will be 

used to determine sulfur input. 

C. Fuel Sulfur Content 

Sulfur in fuels shall be calculated by multiplying the amount of fuel delivered to the process by 

the fraction of sulfur in the fuel as reported to the smelter operator by the fuel’s supplier. The 

sulfur content determination shall be accurate to within ±5 percent. The sulfur content of 

“pipeline quality natural gas” meeting the definition in 40 CFR 72.2 does not have to be 

accounted for due to its low concentration. The Permittee shall maintain documentation of the 

total sulfur content of the natural gas from its supplier. The sulfur content of other fuels, such as 

coal or diesel fuel shall continue to be determined as required by this paragraph. 

III. CALCULATING REMOVED SULFUR 

Total removed sulfur is the sum of the sulfur removed in each of the following products as determined by 

each process set forth below. 

A. Electric Furnace Slags 

1. The weight of the slag shall be determined using a count of furnace slag ladles. The 

weight used for slag in slag ladles will be checked on a semi-annual basis by taking 

samples from 5 ladles determining the average density of the slag using a method which 

has an accuracy within 5%. 

2. Each slag pot will be sampled and a portion of each crushed sample will be used to form 

a monthly composite sample which will be analyzed for sulfur using ICP. 

B. Scrubber Sludge 

1. For sludge that is collected (as a slurry), clarified, and filtered before transportation to a 

solar drying pad as a sludge, a truck payload weight will be determined. The sludge will 

be sampled each time a truck is filled. The sample will be prepared and analyzed for 

sulfur using the procedures in II.B.2 and II.B.3 of this Attachment. 

2. If sludge is to be recycled back to the smelter, the sludge will be sampled each time a 

truck is filled. The sample will be prepared and analyzed for sulfur using the procedures 

in II.B.2 and II.B.3 of this Attachment. 

. 

Permit No. 53592 Page 88 of 97 November 26, 2012 
C. Strong Acids 

1. The daily production of acid shall be determined by using either a flowmeter which 

measures all acid added to the storage tanks from which trucks or rail cars are loaded, or 

a daily inventory increased by the amounts of acid shipped or otherwise transferred 

during that day. 

2. The meter reading or daily inventory will be accurate to within ±5 percent. 

3. Strong acid samples will be analyzed for sulfuric acid using specific gravity methods 

corrected for temperature. Sulfuric acid analyses will be converted to grams per liter of 

sulfur. 

4. The acid stream will be sampled twice per shift and specific gravity will be measured by 

hydrometer in accordance with Freeport McMoRan SOP-45-0012 to check sensor 

accuracy. If the sensor reading differs from the hydrometer reading by more than 5%, the 

instrument will be recalibrated if possible or replaced. 

5. All flow meters, density gauges, sonic sensors, pressure sensors, etc., used in determining 

the sulfur balance will be calibrated according to manufacturer’s specifications at least 

quarterly. 

D. Weak Acids 

1. The amount of weak acid discharged from the acid plant and scrubber systems is to be 

determined through flow meters. 

2. Flow meters will be calibrated as in C.5 above. The accuracy is to be within +/- 20%. 

3. A 100 ml sample of weak acid shall be collected and analyzed daily for sulfur content 

using Inductively Coupled Plasma Spectroscopy or the Barium Sulfate Gravimetric 

Method specified in A.A.C. R18-2 Appendix 8.

E. Materials in Process 

1. Total tonnage of materials in process shall be determined by physical inventory on the 

first day of each month. 

2. A monthly change of in-process inventory shall be calculated for each material in process 

by taking the difference between the inventories from each material in process on the first 

day of the preceding month and multiplying that difference by the monthly composite 

sulfur assay for that material. 

3. The change of monthly in-process inventory must be accurate to within ±50 percent. 

Permit No. 53592 Page 89 of 97 November 26, 2012 
ATTACHMENT “E”: FUGITIVE DUST CONTROL PLAN 

AIR QUALITY CONTROL PERMIT NO. 53592 

FOR 

FREEPORT-MCMORAN MIAMI, INC. 

I. The Permittee shall operate as per the approved fugitive dust control plan. An existing fugitive dust 

control plan is considered to be approved if the plan has been incorporated in the applicable State 

Implementation Plan, and the document addresses the fugitive dust sources specified in Condition II.A of 

this Attachment and includes the information specified in Condition II.B below. 

II. Fugitive Dust Sources 

A. The fugitive dust control plan shall address each of the fugitive dust emission sources listed 

below that are located at the facility: 

1. On-site roadways used by trucks or other motor vehicles (e.g., front-end loaders) when 

transporting quantities of fugitive dust materials. Paved roads and parking areas that are 

not used by these vehicles do not need to be included in the plan (e.g., employee and 

visitor parking lots). 

a. Unloading of fugitive dust materials from trucks or railcars. 

b. Outdoor piles used for storage of fugitive dust materials. 

c. Bedding areas used for blending copper concentrate and other feed constituents. 

d. Each transfer point in conveying systems used to transport fugitive dust 

materials. These points include, but are not limited to, transfer of material from 

one conveyor belt to another and transfer of material to a hopper or bin. 

e. Other site-specific sources of fugitive dust emissions that the Administrator or 

the Director designate to be included in your fugitive dust control plan. 

B. The fugitive dust control plan shall describe the control measures used to control fugitive dust 

emissions from each source addressed in the plan, as applicable and appropriate for the 

Permittee’s site conditions. Examples of control measures include, but are not limited to, locating 

the source inside a building or other enclosure, installing and operating a local hood capture 

system over the source and venting the captured gas stream to a control device, placing material 

stockpiles below grade, installing wind screens or wind fences around the source, spraying water 

on the source as weather conditions require, applying appropriate dust suppression agents on the 

source, or combinations of these control measures. 

Permit No. 53592 Page 90 of 97 November 26, 2012 
ATTACHMENT “F”: OPERATION AND MAINTENANCE REQUIREMENTS 

AIR QUALITY CONTROL PERMIT NO. 53592 

FOR 

FREEPORT-MCMORAN MIAMI, INC.

The operation and maintenance plan shall address the requirements in this Attachment, as applicable to the 

capture system or control device. 

A. Preventative Maintenance 

The Permittee shall perform preventative maintenance for each capture system and control device 

according to written procedures specified in the Operation and Maintenance Plan. The procedures shall 

include a preventative maintenance schedule that is consistent with the manufacturer’s instructions for 

routine and long term maintenance. 

B. Capture System Inspections 

The Permittee shall conduct monthly inspections of the equipment components of the capture system that 

can affect the performance of the system to collect the gases and fumes emitted from the affected source 

(e.g., hoods, exposed ductwork, dampers, fans) according to written procedures specified in the Operation 

and Maintenance Plan. The inspection procedure shall include the requirements in paragraphs 1 through 

3 below as applicable to the capture system or control device. 

1. Observations of the physical appearance of the equipment to confirm the physical integrity of the 

equipment (e.g., verify by visual inspection no holes in ductwork or hoods, no flow constrictions 

caused by dents, or accumulated dust in ductwork). 

2. Inspection, and if necessary, testing of equipment components to confirm that the component is 

operating as intended (e.g., verify by appropriate measures that flow or pressure sensors, damper 

plates, automated damper switches and motors are operating according to manufacture of 

engineering design specifications). 

3. In the event that a defective or damaged component is detected during an inspection, the 

Permittee shall initiate corrective action according to written procedures specified in the 

Operation and Maintenance Plan to correct the defect or deficiency as soon as practicable.

C. Copper Converter Department Capture System Operating Limits 

The Permittee shall establish, according to the requirements in paragraphs 1 through 3 below, operating 

limits for the capture system that are representative and reliable indicators of the performance of capture 

system when it is used to collect the process off-gas vented from batch copper converters during blowing. 

1. Select operating limit parameters appropriate for the capture system design that are representative 

and reliable indicators of the performance of the capture system when it is used to collect the 

process off-gas vented from batch copper converters during blowing. At a minimum, the 

Permittee shall use appropriate operating limit parameters that indicate the level of the ventilation 

draft and the damper position settings for the capture system when operating to collect the 

process off-gas from the batch copper converters during blowing. Appropriate operating limit 

parameters for ventilation draft include, but are not limited to, volumetric flow rate through each 

separately ducted hood, total volumetric flow rate at the inlet to control device to which the 

capture system is vented, fan motor amperage, or static pressure. Any parameter for damper 

position setting may be used that indicates the duct damper position relative to the fully open 

setting. 

Permit No. 53592 Page 91 of 97 November 26, 2012 
Permit No. 53592 Page 92 of 97 November 26, 2012 

2. For each operating limit parameter selected in paragraph 1 above, designate the value or setting 

for the parameter at which the capture system operates during batch copper converter blowing. If 

the blister copper production operations allow for more than one batch copper converter to be 

operating simultaneously in the blowing mode, designate the value or setting for the parameter at 

which the capture system operates during each possible batch copper converter blowing 

configuration that is operated at the smelter (i.e., the operating limits with one converter blowing, 

with two converters blowing, with three converters blowing, as applicable to the smelter). 

3. Include documentation in the plan to support the selection of the operating limits established for 

the capture system. This documentation shall include a description of the capture system design, 

a description of the capture system operation during blister copper production, a description of 

each selected operating limit parameter, a rationale for why the parameter was chosen, a 

description of the method used to monitor the parameter according to the requirements in 

Condition VI.A.3.b of Attachment B of this permit, and the data used to set the value or setting 

for the parameter for each of the batch copper converter configurations. 
ATTACHMENT “G”: EQUIPMENT LIST 

AIR QUALITY CONTROL PERMIT NO. 53592 

FOR 

FREEPORT-MCMORAN MIAMI, INC. 

Description Capacity Manufacturer Model/ 

Serial Number 

Equipment # 

Miami 

Plan

ROD PLANTShaft Furnace 15-burners 24 tons per Hr Asarco N/A 12254 MIR1030 Holding Furnace  1-burner 

10 tons capacity 

Lindberg N/A 12291 MIR1050 

Casting Structure (SCR) 84-inch wheel Southwire N/A 12350 MIR1060 Roughing Mill 24 ton/hr Morgan Mills N/A N/A MIR134 Finish Mill 24 ton/hr Morgan Mills N/A N/A MIR133 Pickling System 24 ton/hr Southwire N/A 12459 MIR3010 Coiler 24 ton/hr Morgan mills N/A 12348 MIR1097 Thermal Breaker 0.82 

MMBtu/hr 

Fulton Thermal Corp. 

FT-0080-C 12690 MIR8567 

Rod Plant Cooling Tower 2500 gpm Flour Counter Flow 

1F60H-126-2424 

12472 MIR3500 

Alcohol Tank #1 8000 gallons Unknown N/A 12456 MIR3007 Alcohol Tank #2 8000 gallons Unknown N/A 12465 MIR3016 Used Oil Tank #3 8000 gallons Unknown N/A 12458 MIR3009 Used Oil Tank #4 8000 gallons Unknown N/A 12461 MIR3012 ELECTROLYTIC REFINERY (685 Cells)Natural-gas fired Steam Boiler 16.7 

MMBtu/hr 

Johnston Boiler Co. PFTA 400-4G150S S/N 

916301-01 

10243 MIE10BR0

Permit No. 53592 Page 93 of 97 
Permit No. 53592 Page 94 of 97 

Description Capacity Manufacturer Model/ 

Serial Number 

Equipment # 

Miami 

Plan

Natural-gas fired Steam Boiler 16.7 

MMBtu/hr 

Johnston Boiler Co. PFTA 400-4G150S S/N 

916301-02 

10244 MIE10BR0

Anode Wash Machine Demister 13,600 scfm AISCO 94-1065 10469 MIE20SK0Cathode Wash Machine Demister 

2000 scfm TM Engineers 9123 10470 MIE20SK0

Decant Scrubber System #1 5300 scfm Carbotech HRP43-48 10533 MIE20SK0Decant Scrubber System #2 5300 scfm Carbotech HRP43-48 10544 MIE20SK0Autoclave Scrubber 3500 scfm Carbotech HRP43-48 10705 MIE20SK0Slimes Dryer Baghouse 175 scfm Flex-Kleen 36BVBC9 10685 MIE30BH0Prep Machine Cyclone Hoffman 

Centrifugal Exhauster 

MT2B06 TVAC200 

10468 MIE20MA0

Sulfuric Acid Tank 6000 Gallons N/A N/A 10402 MIE10TK0SMELTERIsaSmelt Furnace 1.1 MMTPY Mt. Isa N/A 14023 MISISA300Start up/holding burner for Isa Vessel 

30 MMBtu/hr North American MISIVB 14032 MISISA300

Natural-gas fired Isa Auxiliary Boiler 

10.4 MMBtu/hr 

Vapor Corp. HS2-H8500-

VHK300 HS2H85 

13959 MISISA003

Natural-gas fired Change Room Boiler 

0.745 MMBtu/hr 

Lochinvar KO8H00214490 NA NA 

Diesel Emergency Generator (Isa) 

750 HP Detroit 12V-92 

572R2l5040BP104W 

14261 MISV0111 

Electric furnace 3100 tons Elkem N/A 10309 MISELEFU
Permit No. 53592 Page 95 of 97 

Description Capacity Manufacturer Model/ 

Serial Number 

Equipment # 

Miami 

Plan

#1 (Inspiration)  converter 

200 Tons Inspiration N/A 10277 MISCONV

Hoboken Converter #2 130 tons Hoboken N/A 10278 MISCONVHoboken Converter #3 130 tons Hoboken N/A 10279 MISCONVHoboken Converter #4 130 tons Hoboken N/A 10280 MISCONVHoboken Converter #5 130 tons Hoboken N/A 10281 MISCONVAnode Vessel #1 150 TPY Pierce-Smith N/A 13292 MISC0555Anode Vessel #2 150 TPY Pierce-Smith N/A 13293 MISC0555Remelt/Mold pouring furnace 250 Tons Pierce-Smith N/A 13357 MISC0610Acid Plant Pre-heater 34 MMBtu/hr North American MIC201 12790 MISAC201 Diesel Feed Water Pump 335 HP Cummins NT855 P280 14262 MISV0112 Diesel Emergency Generator 1,100 HP Caterpillar D398TH 14260 MISV0110 Acid Plant 3000 TPD N/A N/A 12967 MISACIDPDust Collector, Flux Bin 1,000 acfm Donaldson 16PJD6 14016 MISISA20Dust Collector, Coal Bin 1,000 acfm Donaldson 16PJD6 14017 MISISA20Dust Collector, Reverts Bin 1,000 acfm Donaldson 16PJD6 14018 MISISA20Dust Collector, Conc. Bin 040 3,000 acfm Donaldson 16PJD8 14019 MISISA20Dust collector, Conc. Bin 3,000 acfm Donaldson 16PJD8 14020 MISISA20
Permit No. 53592 Page 96 of 97 

Description Capacity Manufacturer Model/ 

Serial Number 

Equipment # 

Miami 

Plan

Vent Fume Scrubber 300 KSCFM Airpol N/A 13884 MISF45032 Vent Fume Wet Electrostatic Precipitator #1 

100 KSCFM Beltran BTP-10x17.5 826254 MISFWESP

Vent Fume Wet Electrostatic Precipitator #2* 

100 KSCFM Beltran BTP-10x17.5 826258 MISFWESP

Vent Fume Wet Electrostatic Precipitator #3* 

100 KSCFM Beltran BTP-10x17.5 826259 MISFWESP

Dust Collector Mag. Oxide Bin 3000 scfm Griffin 

Environmental 

N/A 13889 MISF45045 

Acid Plant Tail Stack Scrubber 140 KSCFM Airpol N/A 13086 MISA6005Dust Collector Mag. Oxide Bin 3000 SCFM Griffin 

Environmental 

N/A 13087 MISA6005

Sulfuric Acid Tank #1 2,000 Gallons N/A N/A 13025 MISAT301Sulfuric Acid Tank #2 2,000 Gallons N/A N/A 13024 MISAT301Sulfuric Acid Tank #3 2,000 Gallons N/A N/A 13022 MISAT301Sulfuric Acid Tank #4 2,000 Gallons N/A N/A 13023 MISAT301Sulfuric Acid Tank 10,000 

Gallons 

N/A 10,000 tons 837208 707SAT301

Sulfuric Acid Tank 10,000 

Gallons 

N/A

10,000 tons 837209 707SAT301

“A” Cooling Tower 4,500 gpm Ecodyne N/A 13026 MISAT401“B” Cooling Tower 6,500 gpm Ecodyne E60-12076 13027 MISAT401“C” Cooling Tower 16,500 gpm Ecodyne N/A 13035 MISA0075“E” Cooling Tower 5,600 gpm Ecodyne 2- 24x24 cells 31200 MISF210 
Permit No. 53592 Page 97 of 97 

Description Capacity Manufacturer Model/ 

Serial Number 

Equipment # 

Miami 

Plan

“D” Cooling Tower (Not in service) 

Unknown N/A 13016 MISAT100

“F” Cooling Tower 9500 gpm Midwest Towers NA 707SAF310 NA Screening Machine with Diesel Engine 

63 HP Finlay 59B FD480322 N/A 

Mastermag Electromagnetic Head Pulley 

100 TPH KAFKA Model # 24 EPH 

6, Serial # M.16112C 

839969 707S1003 

Gasoline Storage tank 12,000 galons N/A N/A N/A 100000905Diesel Fired Genset 100 KW 

(134 HP) 

Cummins 100 SGAA TBD F11022576

Diesel Fired Genset 20 KW 

(27 HP) 

Cummins 20 DSKBA TBD F11022518

Diesel Fired Genset 50 KW Cummins 50DSFAC TBA TBD Diesel Fired Genset 35 KW Cummins 35DGGD TBA TBD Air Compressor engine 540 HP SullAir 1600HAFDTQ 707S1274 201111100Air Compressor engine 540 HP SullAir 1600HAFDTQ 707S1275 201111100

Note: The prefix “707” may be also be used in place of “MI” for the entries in the column titled “Plant #” in the above tabN/A: Not available TBD: To be decided