### 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 Miam i, Inc., the Permittee, for the continued operation of their smelter located off of Hwy 60 in Claypool, Ariz ona. 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) nitr ogen oxides, (iv) carbon monoxide, and (v) hazardous air pollutants.

This permit is issued in accordance wi th 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 Federa l Regulations (CFR). All terms and conditi ons of this permit are enforceable by

the Administrator of the USEPA.

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

ATTACHMENT “A”: GENERAL PR OVISIONS................................................... ...........................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 INVENTOR Y QUESTIONNAIRE.................................... .........................5

VII. COMPLINACE CERTIFIC ATION ................................................................ .........................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 PR OGRAM....................................................................................7

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

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

XIV. REPORTING REQUIREMEN TS.................................................................. ........................11

XV. DUTY TO PROVIDE INFORM ATION..................................................................................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 STRATSPHER IC 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, 2012XI. BOILERS/HEATERS IN SM ELTER ....................................................... ...............................54

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

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

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

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

XVI. GASOLINE STORAGE T ANK ...............................................................................................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 BA LANCE METHODOLOGY............. .......................................................86

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

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

ATTACHMENT “G”: EQ UIPM ENT 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. R 18-2-304.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 p ermit including all applicable requirements of the Arizona air quality statutes a nd air quality rules. Any permit noncompliance

constitutes a violation of the Arizona Revised Stat utes and is grounds for enforcement action; for permit termination, revocation a nd 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 en forcement 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 C AUSE [A.A.C. R18-2-306.A.8.c, -321.A.1, and -321.A.2]

A. The permit may be revised, reopene d, revoked and reissued, or term inated 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 un der any of the following circumstances:

1. Additional applicable requirements under the Clean Air Act beco me 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 requireme nt. 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 h as 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 re newal 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 progr am. 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 th at 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 determin es 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, 2012C. Proceedings to reopen and reissue a permit, including appeal of any final action relating to a

perm it reopening, shall follow the same procedur es 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 sh all 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 perm it issuance where the facility is located in such a manner as to be clearly visible and acce ssible. 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 th at is also listed in the perm it to identify that piece of equipment.

B. A copy of the complete perm it 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 pur suant 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 em issions inventory questionnaire. The questionnaire is due by March 31st or ninety days after the Director makes the inventory form available each year, whicheve r 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 certificat ion 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 15 th , and shall report the compliance status of the source during the period between September 1 st of the previous year, and February 28 th or 29 th
of the current year. The second certification shall be submitted no later than October 15 th , and shall report the compliance status of the source during the period between March 1 st and August

31 st 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 c ondition during the certification period;

3. The status of compliance with the terms a nd conditions of the perm it for the period covered by the certification, including whether compliance during the period was

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

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

and take it into account for considera tion 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 dete r mine the compliance status of the source.

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

C. If any outstanding compliance schedule exists, a pr ogress report shall be subm itted with the semiannual compliance certifications re quired 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 complete ness. This certification shall state that, based on

information and belief formed afte r 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 sour ce 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 equi pment), practices, or operations regulated or required under the permit;

D. Sample or monitor, at reasonable times, substa nces 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

STAND ARD [A.A.C. R18-2-304.C.4]

If this source becomes subject to a standard promulga ted by the Administrator pursuant to Section 112(d) of the Act, then the Permittee shall, within twel ve months of the date on which the standard is promulgated, submit an application for a permit re vision demonstrating how the source will comply with

the standard.

Permit No. 53592 Page 6 of 97 November 26, 2012XI. 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 a nd -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 Per mittee first learned of the occurrence of excess emissions including all available informati on from Condition XII.A.1.b below.

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

within 72 hours of the notificati on 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 lim itation and the operating data and calculations used in determining the magnitude of the excess emissions;

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

iv. Identity of the equipment from which the exces s emissions emanated;

v. Nature and cause of such emissions;

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

rem edy 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 fro m 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 emission s, 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, 2012B. Permit Deviations Reporting

1. The Permittee shall promptly report deviati ons 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 prev entive 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 Dire ctor by certified mail, facsimile, or hand delivery within two working days of the ti me 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 re quirements 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 aris ing from su dden and reasonable unforeseeable events beyond the control of the source, in cluding 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 desi gned equipment, lack of preventative maintenance, careless or imprope r operation, or operator error.

2. An emergency constitutes an affirmative defe nse to an action brought for noncom pliance with such technology-based emission limita tions if Condition XII.C.3 is met.

3. The affirmative defense of emergency sha ll be demonstrated through properly signed, contemporaneous operating logs, or other relevant evidence that:

a. An emergency occurred and that the Perm ittee 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

mini mize 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, facsi mile, 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 Permitt ee seeking to establish the occurrence of an emergency has the burden of proof.

5. This provision is in addition to any emer gency or upset provision contained in any applicable requirement.

Permit No. 53592 Page 8 of 97 November 26, 2012D. 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 schedul e 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 mileston es, 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 defen ses fo r 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 Significan t 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 re quirements of A.A.C. R18-2-4 06.A.5.

2. Affirmative Defense for Malfunctions

E missions 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 viola tion, 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 unavoi dable breakdown of process equipment or air pollution co ntrol equipment beyond the reasonable control of the Permittee;

b. The air pollution control equipment, pro cess equip ment, or processes were at all times maintained and operated in a manne r 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 th at the measures were impracticable;

d. The amount and duration of the excess emissions (including any bypass operation) were minimized to the maximu m extent practicable during periods of such emissions;

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

on am bient air quality;

f. The excess emissions were not part of a recurring pattern indicative of inadequate design, opera tion, or maintenance;

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

am bient 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 t he 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, emissi ons 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 viol ation, other than a judicial action seeking injunctive relief, if the Perm ittee 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 throug h careful and prudent planning and design;

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

em issions on ambient air quality;

vi. During the period of excess emissions there were no exceedance s 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, 2012vii. All emissions monitoring system s were kept in operation if at all practicable; and

viii. Contemporaneous records documented the Permittee’s actions in response to the exces s 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 Malfuncti ons 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 X II.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 reasona ble and practicable measures within the Permittee’s control were implemented to pr event 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 m onitoring 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 entit y 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 require d m onitoring data and support information for a period of at least 5 years from the date of th e 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 utiliz ing 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, 2012B. Excess emission; permit deviation, and emergency reports in accordance with Section XII of

Attach ment “A”.

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

XV

. DUTY TO PROVIDE INFORMATION

A. The Permittee shall furnish to the Director, with in 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 de termine 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 Pe rmittee 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 fact s 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 re vision 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 applicabilit y and requirements for such action ar e 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 perm it revision if all of the following apply:

1. The changes are not modifications under any prov ision of Title I of the Act or un der ARS § 49-401.01(24);

2. The changes do not exceed the emissions a llowable under the per mit whether expressed therein as a rate of emissions or in terms of total emissions;

3. The changes do not violate any applicable requirem ents 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 enfo rceable perm it 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 po lluti on 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, 2012does 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 prac ticable, 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 l onger applicable as a result of the chang e.

E. The permit shield described in A.A.C. R18-2-325 shall not appl y 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 re quire 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 pe rmit, do not satisfy Condition XVII.A above.

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

A. The Permittee shall conduct performance tests as speci fied in the perm it and at such other times as may be required by the Director.

B. Operational Conditions during Testing

Tests shall b e conducted during operation at the maximum possible capacity of each unit under representative operational conditions unless other c onditions 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 pe riods of start-up, shutdown, and malfunction (as defined in A.A.C. R18-2-101) shall not cons titute representative opera tional conditions unless otherwise specified in the applicable standard.

C. Tests shall be conducted and data reduced in acco r dance with the test methods and procedures contained in the Arizona Testing Manual unless m odified by the Director pursuant to A.A.C.

R18-2-312.B.

D. Test Plan

Unless spe cified otherwise in the permit, , the Perm ittee 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, 20121. Test duration;

2. Test location(s);

3. Test method(s); and

4. Source operation and other parameters th at may affect test results.

E. Stack Sampling Facilities

The Perm ittee shall provide, or cause to be pr ovided, 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 th ree separate runs using the applicable test method. Each

run shall be conducted for the time and under the c onditions 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 th e 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 arithme tic mean of the results of the other two runs. If the Director or the Director’s designee is presen t, 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 an y test without good cause after

the first run is commenced shall constitute a failu re of the test. Supporting documentation, which demonstrates good cause, must be submitted.

G. Report of Final Test Results

A written report of the res ults of all performance te sts 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 even t of a challenge to any portion of this permit, or if any portion of this permit is held invalid, the rema ining permit conditions remain valid and in force.

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

Compliance with the conditions of this permit sh all 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, 2012ATTACHMENT “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 pers on 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 pe riod 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 A ttachment, the following general requirements shall be applicable to all National Emission Sta ndards for Hazardous Air Pollutants (NESHAP) 40 CFR Part 63 Subpart QQQ affected sources.

1. The Permittee shall comply with the follo wing 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 ma tter emissions from fugitive dust sources at the primary copper smelter by ope rating 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 wi th the emission limitations, work practice

Permit No. 53592 Page 16 of 97 November 26, 2012standards, and operation and maintenan ce requirements at all times, except during periods of startup, shutdown, an d 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, asso ciated repairs, and required quality assurance or control activities (includi ng 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 re corded 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 sudde n, 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 no tifications 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 notificati on 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 complia nce 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. Th e Permittee shall report the actions taken for the event by fax or tele phone 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, 2012Timely reporting and submittal of in formation 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 complian ce 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 a pplicable, 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 ta ken 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 a pply 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 practi ce 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 statementthat 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 m onitoring 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 usi ng an operating parameter monitoring system to comply with the emissi on 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 mon itoring 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 de viation 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, 2012deviations 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 Pe rmittee 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 malfunc tion 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 spec ified 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 th e 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 an d readily available for expeditious review, according to 40 CFR 63.10(b)(1).

c. As specified in 40 CFR 63.10(b)(1), th e Permittee shall keep each record for 5 years following the date of each occu rrence, 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 Pe rmittee 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 th e 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, 2012d. If the six-minute opacity of the plume exceeds the baseline level but is less than the opacity standard, the Permittee shall in itiate corrective action, as necessary, to reduce opacity to or below the baseline le vel. 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 plum e 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 th e 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 re port 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 Emissi ons without Baseline Monitoring Approach

a. If the observer, during the visual surv ey, 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 plum e 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, 2012d. 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 basi s, 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 Secti on 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 ra te limi ts 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 conditi ons 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 wei ght rate of 60,000 pounds per hour (30 tons per hour) or less, the maximum allowa ble 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, 2012P = 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 a llowable 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 pe rmit 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 associat ed 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 as sociated 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 id entified 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, 2012d. 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 c onducted, performance tests on two representative stacks from the concentrate, flux, revert, and coal bi ns 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= 4.10P 0.67

Where:

E = the maximum allowable particul ate 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, 2012E = 55P 0.11 – 40

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

above.

c. The Permittee shall not discharge or cau se 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 me thods specified in Condition IV.A.3.c.
[40 CFR 63.1444(b)(1)]

d. The Permittee shall not cause to be di scharged 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 th e 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 emissi ons (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 (s um 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 Par ticulate 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 a nnual 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, 2012c. 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 determ ine 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 sep arate 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 perm it 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, 2012b. 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 pr ior 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 Referenc e 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 (SO 2 )

1. Emission Limitations and Standards

a. The Permittee shall not exceed the emissi on 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 disc harged into the atmospheres from the acid plant any gases that contain sulfur dioxi de 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 pro cess 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 ar e 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, 2012emissions 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 concentr ations shall be calculated and recordeddaily 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 dioxi de 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 m onitoring system, exceed the standard (0.065 percent by volume). The Administ rator 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 leve l 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. SO 2 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 SO 2 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 em issions 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, 20122. 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 av erage 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 to tal, 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 Revi sion #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 emissi on rate li mit 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, 2012E = the maximum allowable particul ate 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 = 55P 0.11 – 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 w ith 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 ar e 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 id entified 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 particul ate matter emission limit in Condition

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

d. The Permittee shall maintain the hour ly 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, 2012e. The Permittee shall install

, maintain and operate a bypass duct on the Electric Furnace in accordance with good air po llution control practices to allow the gases to be directed to the vent fume syst em 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 ma tter from the vent fume stack by multiplying the average hourly emission rate determined from the most recent performance test by the hour s 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 Cond ition 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] [Mat erial 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 minimu m 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 Preci pitators (WESP) according to the equipment manufacturer's specificati ons and the following requirements:
[40 CFR 63.1452(d), A.A.C. R18-2-331.A.3.c] [Mat erial permit conditions are indicated by italics and underline]

(1) Locate the sensor(s) used for monito ring 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 inspec tion, 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 Ma tter (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 condu ct 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 tota l 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 determ ine 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 a pplicable, 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 a pplicable method specified in Condition V.A.4.b(1)(e) above, the Permittee may determine total pa rticulate matter

emissions from the control device us ing 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 sep arate 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 a pplicable 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 lim itation under Condition V.A.2.d of this Attachment, the Permittee shall establish s ite-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 paramete rs 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 individua l test run. The operating limits are the lowest value or the highest va lue, 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 k eep records of written documentation to support the selection of the operating parameters used for the ESPs. This documentation shall include a descrip tion of each selected parameter, a rationale for why the Permittee chose th e 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 fo r the scrubber water flow rate, the Permittee shall establish site-specific opera ting limits according to the following:
[40 CFR 63.1450(a)( 5) ]

(1) Using the continuous parameter m onitoring system (CPMS) required in

Permit No. 53592 Page 34 of 97 November 26, 2012Condition 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 con tinuous 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 c onformance 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 th e parameter(s) selected in Condition

V.A.4.c within the levels establishe d during the most recent performance

test;

b. Collect and reduce monitoring data for selected parameters according to

Condition I.C.6 of this Attachment a nd 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 emissi on 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 c onditions are identified by italics and underline]

Permit No. 53592 Page 35 of 97 November 26, 20122. Air Pollution Control Requirements

The Permittee shall maintain and operate the scrubber associat e d 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. SO 2 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 Limita tion 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 pe rmit conditions are identified by italics and underline]

2. Performance Testing Requirements

Performance tests shall be conducted on a sem i-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 associ ated 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 sh all not exceed 4% as determined by a performance test conducted in accordance w ith 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 th e 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 pro cess 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, 2012b. 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 de partment 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 mini mum tolerance of 2 percent of the

flow rate.

(c) Reduce swirling flow or abnorma l 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 to lerance 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 inspecti on, 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 demonstr ate continuous compliance of the copper converter department capture system by meeting the following requirements:

a. Operate the copper converter departme nt 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 convert er 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 depart ment 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 lim it 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 c onverter department does not exceed 4 percent opacity. The performance test sha ll 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 conduc ted during the period when the primary copper smelter is operating under cond itions 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 sha ll 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 Attachme nt “F” to support the established operating limits for the copper converter de partment capture system. A copy of the test plan shall be submitted for review and approval by the Director. During the observation period, the Permitt ee shall conduct appropriate process information and copper converter de partment 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 notif ication of the location and scheduled date for conducting the opacity observati on 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, 2012c. The Permittee shall gather the data ne eded for determining compliance with the opacity limit using qualified visible emissi on 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 allo w 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 exhaus t 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 interfere nces have occurred from other copper production events, as specified in Condition VI.A.5.g of this Attachment, which generate visible emissions inside the bu ilding that potentially can interfere with

Permit No. 53592 Page 40 of 97 November 26, 2012the 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 su ch that the Method 9 conditions are no longer met or weather conditions that in terfere with the observers’ ability to record acceptable opacity readings. If the total observation period is divided into two or more segments, all opacity observa tions 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 pro cess 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 occurri ng 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 th e 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, 2012interval readings recorded on the fi eld 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 sheet s 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 conve rter was blowing but none of the interference events listed in Condition VI.A.5.g(3)(a) through (f) below occurred. Other ancillary activitie s 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, revert s, 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 insi de 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 sheet s 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 dela y 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 interfe rence event occurs. The same time delay factor shall be used for all in terference 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 explana tion of the rationale for selecting the

Permit No. 53592 Page 42 of 97 November 26, 2012value used for the time delay factor shall be prepared and included in the

test report.

h. The Permittee shall use the date summa ry 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 conver ter was blowing with no interference events as determined according to Cond itions VI.A.5.g(3) and (4) above. Average opacity is calculated using the equation below:

n

VE

ave = 1/n 

## Σ VE i i=1

Where

VE

ave = Average opacity to be used for compliance determination (percent);

n = Total number of 1-minute interv als 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 whic h 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

VE i = Average opacity value calculated for the eight opacity readings recorded during 1-minute interval “i” (percent).

i. The Permittee shall certify that the c opper 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 obser vations, 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 ope rating, the damper position shall be visually checked and reco rded at the beginning and end of each opacity observation period segment.

(3) Review the recorded monitoring da ta. 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, 20127. 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 Installatio n Permit #1232 and A.A.C. R18-2-331.A.3.a] [Material permit c onditions 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 acco rdance 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 Installa tion Permit #1232 and A.A.C. R18-2-331.A.3.a] [Material pe rmit 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 conditi ons 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 t ests 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, 2012VII. 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 SO 2 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 SO 2 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, 20123. 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 em issions, 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 conditi ons are indicated by italics and underline]

a. Acid Plant Tailgas Stack

b. Vent Fume Stack

3. All the SO 2 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 SO 2 emissions by averaging the SO 2 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 SO 2 emissions averages by averaging the hourly SO 2 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 emissi ons 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 w ith the emission limit contained in Condition

VII.B.3 as follows:

a. The Permittee shall calculate annual averag e 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, 2012previous 12-month period e nding 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 av erage 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 dete rmine monthly fugitive emissions, the Permittee shall perform material balan ces 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 cumula tive 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 scenario s shall be considered violations of the

cumulative occurrence and/or em ission limits contained in C onditions 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 sha ll 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 th e 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 cu mulative 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 associat ed 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 occurre nce 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, 2012f. 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 reco rd 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 r esults 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 ta ken 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 da y of the month being reported;

(4) The date on which a cumulative occurrence limit listed in Condition

VII.B.2 was exceeded if such ex ceedance 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 (s tack 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 su lfur balance broken dow n into the major process

streams that constitute the sulfur balance.

Permit No. 53592 Page 48 of 97 November 26, 2012d. Bypass reporting requirements

At each point in the permitted smelter fa cility where a means exists to bypass the sulfur removal equipment, such bypass sh all 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, Appendi x 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 indi cated 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 performa nce evaluation, the reference method for Relative Accuracy Test procedure und er 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] [Materia l 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 specif ies 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, 2012Permittee shall make available a record of th ese procedures that clearly shows instrument readings before and after ze ro 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 hour s 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 mainta in on hand and ready for immediate installation sufficient spare parts or duplicate systems for the contin uous 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) ca libration 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 SO 2 CEMS shall be in continuous operation. [40 CFR 60.13(e)(2)]

2. For purposes above, continuous monitoring m eans the taking and recording of at least

one measurement of sulfur dioxide concentra tion 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 th e 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, 2012previous 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 e quipment; or any periods during which a continuous monitoring system or monitoring de vice is in operative. [40 CFR 60.7(b)]

2. The Permittee shall maintain a file of a ll 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; adjust ments 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 tota l 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 re quired 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 co mmencement and completion of each time period of excess emissions. The process operating time during the reporting period.

(2) Specific identification of each pe riod of excess emissions that occurs during startups, shutdowns, and malfun ctions of the affected facility. The nature and cause of any malf unction (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 inoperativ e, repaired, or adjusted, such information shall be stated in the report.

Permit No. 53592 Page 51 of 97 November 26, 2012F. 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 conve rter 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. Analy ze 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 chargi ng rate once per month using the following equation:

R

c = Converter arsenic charging rate (kg/hour or pounds/hour). R

c = ∑ (i=1 to n) :{ (A

c · W ci ) + (A l · W li ) } {100 H

c }

A

c = 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 ch arged to a copper converter during the month (kg).

Hc= Total number of hours the copper c onverter 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 C ondition IX.B below. If the charging rate is greater than 75 kg/hr (165 lb/hr), the Pe rmittee shall comply with the additional requirements under 40 CFR 61.172(b) throu gh (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, 2012B. 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 c onverter 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 Secti on 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 belo w, 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 meas ured by EPA Reference Method 9.

[A.A.C. R18-2-702.B]

1. The Permittee shall not cause, allow or pe rmit 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 pe rmit 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 condi tions are identified by italics underline]

Permit No. 53592 Page 53 of 97 November 26, 2012C. 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 u tility 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 record s 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 Pa rt shall be deemed compliance with the 40 CFR §60.48c(g) and (i). [A.A.C. R18-2-325]

2. Nitrogen Oxides (NO X )

a. Emission Limitations and Standards

The Permittee shall not discharge or cau se to be discharged from the IsaSmelt auxiliary boiler NO X 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 NO X 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

NO X

. [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, 2012B. Change Room Water Heater and Acid Plant Preheater

1. Fuel Limitations

The Permittee shall only burn natural gas in th e 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 = 1.02Q 0.769

Where:

E = the maximum allowable particul ate emissions rate in pounds mass per hour.

Q = the heat input in million Btu per hour.

(2) The Permittee shall not cause, a llow 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 Machin e used for screening copper-containing material as well as non-copper containing material

Permit No. 53592 Page 55 of 97 November 26, 2012B. 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 fro m the Screening Machine subject to the provisions of this Section in total quan tities 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 = 4.10P 0.67

where:

E = the maximum allowable particul ate 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 efflue nt 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 Oper ations In The Rock Crushing Industry”(EPA 340/1-79-002), “Wet Suppression System” (pag es 15-34, amended as of January 1979 (and no future amendments or editions)), as inco rporated 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 pl ant 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 th e screening machine, when in operation, as

Permit No. 53592 Page 56 of 97 November 26, 2012per 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 dail y 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 sh all 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= 4.1P 0.67

Where:

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

Permit No. 53592 Page 57 of 97 November 26, 2012P = 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 = 55P 0.11 - 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 procedur e 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 operati ons associated with the refinery process in such quantities or concen trations 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 pr ocess shall be processed, stored, used, and transported in such a manner and by such means that they will not evaporate, leak, escape or be otherwi se discharged into the ambient air so as to cause or contribute to air pollu tion. 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 thereo f to a degree that will adequately dilute, reduce or eliminate the dischar ge 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 a rea 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 conditi ons 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 minimi zing emissions of sulfuric acid mist

. [A.A.C. R18-2-306.A.2 & A. A.C. R18-2-331.A.3.d] [Material permit conditi ons 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 conditi ons 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, 2012Where:

E = the maximum allowable particul ate emissions rate in pounds mass per hour.

Q = the heat input in million Btu per hour.

(2) The Permittee shall not cause, a llow 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 ga s 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, 2012P = 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 = 55P 0.11 - 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 fro m 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 th e 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 th e 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, 20125. 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 con centrations 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 av ailable 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 thereo f to a degree that will adequately dilute, reduce or eliminate the dischar ge of air pollution to the adjoining

property. [A.A.C. R18-2-730.G]

b. Permit Shield

Compliance with the conditions of this S ection 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 vol atile compounds, acids, and alkalis shall be processed, stored, used, and transported in su ch 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 m eans 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, 2012Permit 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 constituti ng air pollution is discharged to adjoining property, the Director may require the in stallation 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 e quipped 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 gaso line 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 ty pical Reid vapor pressure of gasoline stored and of the dates of storage. Records of th e 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 mont hly temperature and true vapor pressure of gasoline at such temperature if the true va por 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 sh all 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 determin ed by the procedures in American Petroleum Institute Bulletin 2517, amended as of Februa ry 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 th at 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 da ta 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 applicab le 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 = 1.02Q 0.769

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 consecutiv e 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, 2012b. 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 Di rector 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 (NO

x )

a. Emission Limitations and Standards

The Perm ittee shall not discharge or cau se to be discharged from the IsaSmelt standby generator nitrogen oxide emis sions in excess of 29 pounds per hour.

[A.A.C. R18-2-406.A.4]

Permit No. 53592 Page 65 of 97 November 26, 2012b. Performance Test Requirements

The Permittee shall conduct a performan ce 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 fo llowing 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 stationa ry 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 ma intenance such as to produce power for critical networks or equipment (incl uding 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 main tain 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 em ission-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 emer gency generators for the purpose of

maintenance checks and readiness tes ting, 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, 2012g. 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 standard s 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 emergenc y 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 meet s 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 emi ssion 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 engi ne must be installed and configured according to the manufacturer's specifications. [40 CFR 60.4211 (c)]

b. If the Permittee does not install, config ure, 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 Perm ittee shall demonstrate compliance by keeping a maintenance plan and records of maintenance conducted and shall, to the extent practicable, maintain and oper ate each engine in a manner consistent with good air pollution control practice fo r minimizing emissions. In addition, the Permittee shall conduct an initial perfo rmance 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 mode l year, the Permittee shall keep recordsof emergency and non-emergency operation as recorded through the nonresettable hour meter.

Permit No. 53592 Page 67 of 97 November 26, 2012b. The Permittee shall maintain monthly r ecords 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 te rms of this Part no la ter than May 3, 2013.
[40 CFR 63.6595(a)] b. General Operating Li mitations/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 main tain the engines and after control device, if any, in accordance with manufacturer’s emission-related written instructions or develop a main tenance 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 th e engines in order to perform the management practice requireme nts required in Condition Conditions XVII.C.1.b(3) a bove, or if performing the management practice on the requi red 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 emergenc y has ended or the unacceptable risk under federal, state, or lo cal law has abated. The Permittee must report any failure to perform the management practice on the schedule required and the fede ral, 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 t esting, provided that the tests are recommended by federal, st ate 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 a nd readiness testing, but a petition is not required if the Permittee maintains records indicating that federal, state, or local standard s 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 con tinuous 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, 2012report 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 th at are analyzed under the oil analysis program in Conditions XVII.C.1.b(3)(c) of this Attachment, the results of the an alysis, 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 engi nes 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, 2012There is no time limit on the use of emer gency engines in emergency situations.
[40 CFR 63.6640(f)(1)]

b. The Permittee may operate the engin es 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 concentra tions 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 constituti ng air pollution is discharged to adjoining property, the Director may require the in stallation 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 th e 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 = 4.10P 0.67

Where:

E = the maximum allowable particul ate emissions rate in pounds-mass

Permit No. 53592 Page 72 of 97 November 26, 2012per hour.

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

(2) For process weight rate greater th an 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 exceed ance 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 Pe rmit Condition are defined by double underline and italics]

3. Monitoring, Record keeping and Reporting Requirements

A certified Method 9 observer shall conduct a quart erly (once in 3 months) visual survey of visible emissions from cooling towers as pe r 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, 2012b. 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, levelin g 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 we tting, 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 o ccurs 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, deto uring, 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 mach inery 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, 2012c. 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) thro ugh 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 (o nce every two weeks) monitoring of visible emissions from the fugitive dust sources, when in operation, in accordance with the visual observation pl an. 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 Secti on 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 move d 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 pe rmit 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 ma chinery 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, 2012dust 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 ma intenance 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 m inimizing 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 ope rations 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 conduc ted, t he Permittee shall log in ink or in an

Permit No. 53592 Page 76 of 97 November 26, 2012electronic 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 requirem ents:

(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 co ating and spot painting, shall be conducted in an enclosed area equippe d 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 p hotochemically reactiv e solvents for industrial or commercial purposes; or

(b) Thin or dilute any architectur al coating with a photoche mically

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 w ith 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 m olecule except ethylbenzene: 8 percent.

Permit No. 53592 Page 77 of 97 November 26, 2012(c) A combination of ethylbenzen e, 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 pai nts and solvents used in the project; and

(e) The amount of paint consumed during the project.

(2) Architectural coating and spot pain ting 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 Haza rdous Air Pol lutants - 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 Renovati on and D emolition 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 Ma intenance and/or Services

1. The Permittee shall comply with the app licable 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 re levant paperwork to the appli cable requirements of 40 CFR 82 - Subpart F on file. [A.A.C. R18-2-306.A.3.c]

3. Permit Shield

Co mpliance with the conditions of this Part shall be deemed compliance with 40 CFR 52, Subpart F. [A.A.C. R18-2-325]

XXII. AMBIENT MONITORI NG 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 samp le 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 procedur es upon a finding that the proposed procedures are substantially equivalent or s uperior 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, 2012c. Quality Assurance Handbook for Air Pollu tion 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 Po llution 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 c onducted by a qualified i ndependent 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 techni cal systems audits or performance audits conducted by the Department. The Departme nt 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 a nd 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 90 th day of the following quarter. An annual report summarizing the quality assurance data for the calendar year shall be submitted before April 1 st 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 th e applicable sections of 40 CFR Part 50 and appendices. Valid data are all observations co llected for the specific monitoring purpose

that have not been deemed invalid. Data co llected 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 t hose 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 revi ewed, 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, 2012reported 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 ev ent 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 an y 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 forma tted 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 documentati on, including, but not limited to 

### :

(1 ) Copies of laboratory reports, if applicable;

(2) Copies of all applicable quality cont rol and field reports (e.g., precision checks, flow checks, calibrations, and audit reports); and

(3) Documentation of problems and corre ctive 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 calculat ed in accordance with procedures in 40 CFR Part 58 Appendix A.

Permit No. 53592 Page 81 of 97 November 26, 2012f. 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 PM 10 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 Conditio n indicated by underline and italics]

2. Should the ADEQ request relocation of monitoring sites to alternate locations, the monitors shall be operating at those locati ons within 120 days of receipt of written notification provided the Permittee can s ecure 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 Ambi ent 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 Re ports 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 PM 10 mass concentration for each measurement

(f) Average PM 10 concentration for the quarter calculated from valid 24-hour block daily averages

(g) Highest and second highest 24-hour concentration values for PM 10 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 filtersamples must be provided to ADEQ. This may include electronic data or hardcopy reports. In addition, lead r esults 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 Conditio n indicated by underline and italics]

2. All samplers shall be operated, calibrate d, and maintained in accordance with the procedures set forth in the respective ma nufacturer’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 M easurement Systems, Volume II, U.S. Environmental Protection Agency. The Permittee shall use EPA approved SO 2 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 SO 2 concentrations for each hour in parts per million (ppm) or part s per billion (ppb), or all twelve 5- minute block averages of SO 2 concentrations for each hour.

(3) Hourly average values of SO 2 concentrations in ppm or ppb.

b. The quarterly and annual reports shall al so contain the following information, as appropriate. All concentration data mu st 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 repor ting period or the reason why the sample is missing;

(3) Hourly SO 2 concentration data in AAAD format quality assured and validated by the Permittee, includi ng 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 SO 2 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 SO 2 (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

SO 2 quarterly averages (per 40 CFR 50.4), the annual 99 th
percentile of the daily maximum 1-hour averages, and the most recent 3 year average of the annual 99 th percentiles;

(vi) Precision and accuracy data as per 40 CFR 58.

c. In addition, to confirm data validation b y the Permittee, all data reports should include copies of all appropriate s upporting documentation including, but not limited to, the following:

(1) Copies of all applicable quality cont rol and field reports (e.g., precision checks, flow checks, and calibrations, audit reports); and

(2) Documentation of problems and corre ctive 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

Sulfur Dioxide Particulate Matter Lead Emission

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 indivi dual emission limit. They will be regulated by the emission cap identified in the table. ** Alternatively, the Permittee must maintain a ma ximum 12-month rolling average stack flow rate of 500,000 scfm.

Permit No. 53592 Page 85 of 97 November 26, 2012ATTACHMENT “D”: SULFUR BALANCE METHODOLOGY AIR QUALITY CONTROL PERMIT NO. 53592

FOR FREEPORT-MCMORAN MIAMI, INC.

PROCEDURES FOR UTILIZING THE SULF UR 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 sulf ur emitted into the ambient air from smelter processing units and sulfur control and removal e quipment associated with the smelting process. The total monthly amount of sulfur emissions is equa l to the weight of the total sulfur introduced into the smelting process in any calendar month mi nus the weight of all sulfur removed from the smelting process streams in that month in any phys ical 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 consid ered 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 e quivalent 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 we ight of each sulfur bearing material introduced into the smelting process as calculated in A.1 below multiplie d 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 with in 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 calib ration 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. Material s such as limestone and silica flux which are

Permit No. 53592 Page 86 of 97 November 26, 2012mixed with a charge of sulfur bearing materials shall be weighed and reported.

B. Sulfur Content

The sulfur content of all sulfur bearing materi als 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 coll ect a sample using the auger method. Samples are to be taken from at least tw o 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 sh all 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 blende d 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 th e 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 dr ied and then pulverized to minus 80 mesh using a roto-disc pulverizer or similar e quipment 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 de termine sulfur content using any of the following methods:

(1) X-ray Fluorescence Spectroscopy (X RF). 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, 2012Howell 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 sh all be within a range of ±1 percent

4. Sulfur Determination

The sulfur content of all feed material treat ed per month will be determined by month end physical inventories in conjunction with certified scales for bed contents. Physical inventory determines beginni ng and ending bed for each month and all beds processed during the month, together with invent ory changes for secondaries. Based upon individual lot numbers for each material pro cessed (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 de finition in 40 CFR 72.2 does not have to be

accounted for due to its low concentration. Th e Permittee shall maintain documentation of the total sulfur content of the natural gas from its supp lier. 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 rem oved 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 determin ed 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 averag e 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), clar ified, and filtered befo re 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. Th e 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 sm elter, 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, 2012C. Strong Acids

1. The daily production of acid shall be dete rmined 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 da ily 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 an alyses 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 a bove. 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 Spectrosc opy 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 inventor ies from each material in process on the first day of the preceding month and multiplying th at 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 fug itive dust control plan. An existing fugitive dust control plan is considered to be approved if the pl an 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 inform ation 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 material s. 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 ma terials 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 sy stems 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 contro l measures include, but are not limited to, locating the source inside a building or other enclosur e, 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, appl ying appropriate dust suppression agents on the source, or combinations of these control measures.

Permit No. 53592 Page 90 of 97 November 26, 2012AT TACHMENT “F”: OPERATION AND MAINTENANCE REQUIREMENTS AIR QUALITY CONTROL PERMIT NO. 53592

FOR FREEPORT-MCMORAN MIAMI, INC.

The operation and maintenance plan shall address the requi rements in this Attachment, as applicable to the capture system or control device.

A. Preventative Maintenance

The Permittee shall perform preventative maintena nce for each capture system and control device according to written procedures specified in the Oper ation and Maintenance Plan. The procedures shall include a preventative maintenance schedule that is c onsistent 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 sha ll 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 e quipment 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 com ponent is detected during an inspection, the

Permittee shall initiate corrective action accord ing to written procedures specified in the Operation and Maintenance Plan to correct th e defect or deficiency as soon as practicable



### .

C. Copper Converter Department Ca pture System Operating Limits

The Permittee shall establish, according to the requi rements in paragraphs 1 through 3 below, operating limits for the capture system that are representative a nd reliable indicators of the performance of capture system when it is used to collect the process off-g as 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 cap ture 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 parame ters 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 dur ing 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, 2012Permit No. 53592 Page 92 of 97 November 26, 2012 2. For each operating limit parameter selected in pa ragraph 1 above, designate the value or setting for the parameter at which the capture system ope rates 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, desi gnate 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 conve rters 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 incl ude a description of the capture system design, a description of the capture system operation during blister copper produc tion, 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 ba tch copper converter configurations.ATTACHMENT “G”: EQUIPMENT LISTAIR QUALITY CONTROL PERMIT NO. 53592FORFREEPORT-MCMORAN MIAMI, INC.DescriptionCapacityManufacturerModel/Serial NumberEquipment #MiamiPlant #InstalledROD PLANTShaft Furnace 15-burners24 tons perHrAsarcoN/A12254MIR1030Pre-1970Holding Furnace1-burner10 tonscapacityLindbergN/A12291MIR1050Pre-1970Casting Structure (SCR)84-inch wheelSouthwireN/A12350MIR1060Pre-1970Roughing Mill24 ton/hrMorgan MillsN/AN/AMIR134Pre-1970Finish Mill24 ton/hrMorgan MillsN/AN/AMIR133Pre-1970Pickling System24 ton/hrSouthwireN/A12459MIR3010Pre-1970Coiler24 ton/hrMorgan millsN/A12348MIR1097Pre-1970Thermal Breaker0.82MMBtu/hrFulton ThermalCorp.FT-0080-C12690MIR85671984Rod Plant Cooling Tower2500 gpmFlourCounter Flow1F60H-126-242412472MIR3500Pre-1970Alcohol Tank #18000 gallonsUnknownN/A12456MIR30071984Alcohol Tank #28000 gallonsUnknownN/A12465MIR30161984Used Oil Tank #38000 gallonsUnknownN/A12458MIR30091984Used Oil Tank #48000 gallonsUnknownN/A12461MIR30121984ELECTROLYTIC REFINERY (685 Cells)Natural-gas fired Steam Boiler16.7MMBtu/hrJohnston Boiler Co.PFTA 400-4G150S S/N916301-0110243MIE10BR001A1994Permit No. 53592Page 93 of 97November 26, 2012Permit No. 53592Page 94 of 97November 26, 2012DescriptionCapacityManufacturerModel/Serial NumberEquipment #MiamiPlant #InstalledNatural-gas fired Steam Boiler16.7MMBtu/hrJohnston Boiler Co.PFTA 400-4G150S S/N916301-0210244MIE10BR001B1994Anode Wash Machine Demister13,600 scfmAISCO94-106510469MIE20SK0031994Cathode Wash MachineDemister2000 scfmTM Engineers912310470MIE20SK0051994Decant Scrubber System #15300 scfmCarbotechHRP43-4810533MIE20SK0061994Decant Scrubber System #25300 scfmCarbotechHRP43-4810544MIE20SK0071994Autoclave Scrubber3500 scfmCarbotechHRP43-4810705MIE20SK0011994Slimes Dryer Baghouse175 scfmFlex-Kleen36BVBC910685MIE30BH0011994Prep Machine CycloneHoffmanCentrifugalExhausterMT2B06TVAC20010468MIE20MA0011994Sulfuric Acid Tank6000 GallonsN/AN/A10402MIE10TK0421994SMELTERIsaSmelt Furnace1.1 MMTPYMt. IsaN/A14023MISISA300101991Start up/holding burner for IsaVessel30 MMBtu/hrNorth AmericanMISIVB14032MISISA300401991Natural-gas fired Isa AuxiliaryBoiler10.4MMBtu/hrVapor Corp.HS2-H8500-VHK300HS2H8513959MISISA003851991Natural-gas fired Change RoomBoiler0.745MMBtu/hrLochinvarKO8H00214490NANA1997Diesel Emergency Generator(Isa)750 HPDetroit12V-92572R2l5040BP104W14261MISV01111991Electric furnace3100 tonsElkemN/A10309MISELEFURNACE1974Permit No. 53592Page 95 of 97November 26, 2012DescriptionCapacityManufacturerModel/Serial NumberEquipment #MiamiPlant #Installed#1 (Inspiration)converter200 TonsInspirationN/A10277MISCONVETER11981Hoboken Converter #2130 tonsHobokenN/A10278MISCONVETER21974Hoboken Converter #3130 tonsHobokenN/A10279MISCONVETER31974Hoboken Converter #4130 tonsHobokenN/A10280MISCONVETER41974Hoboken Converter #5130 tonsHobokenN/A10281MISCONVETER51974Anode Vessel #1150 TPYPierce-SmithN/A13292MISC0555.11987Anode Vessel #2150 TPYPierce-SmithN/A13293MISC0555.21987Remelt/Mold pouring furnace250 TonsPierce-SmithN/A13357MISC0610.18Pre-1974Acid Plant Pre-heater34 MMBtu/hrNorth AmericanMIC20112790MISAC2011997Diesel Feed Water Pump335 HPCumminsNT855 P28014262MISV01121988Diesel Emergency Generator1,100HPCaterpillarD398TH14260MISV01101973Acid Plant3000 TPDN/AN/A12967MISACIDPLANT1974Dust Collector, Flux Bin1,000 acfmDonaldson16PJD614016MISISA201301991Dust Collector, Coal Bin1,000 acfmDonaldson16PJD614017MISISA201311991Dust Collector, Reverts Bin1,000acfmDonaldson16PJD614018MISISA201321991Dust Collector, Conc. Bin 0403,000 acfmDonaldson16PJD814019MISISA201331991Dust collector, Conc. Bin3,000 acfmDonaldson16PJD814020MISISA201341991Permit No. 53592Page 96 of 97November 26, 2012DescriptionCapacityManufacturerModel/Serial NumberEquipment #MiamiPlant #InstalledVent Fume Scrubber300 KSCFMAirpolN/A13884MISF450321991Vent Fume Wet ElectrostaticPrecipitator #1100 KSCFMBeltranBTP-10x17.5826254MISFWESP.012003Vent Fume Wet ElectrostaticPrecipitator #2*100 KSCFMBeltranBTP-10x17.5826258MISFWESP.022003Vent Fume Wet ElectrostaticPrecipitator #3*100 KSCFMBeltranBTP-10x17.5826259MISFWESP.032003Dust Collector Mag. Oxide Bin3000 scfmGriffinEnvironmentalN/A13889MISF450451991Acid Plant Tail Stack Scrubber140 KSCFMAirpolN/A13086MISA600501991Dust Collector Mag. Oxide Bin3000 SCFMGriffinEnvironmentalN/A13087MISA600551991Sulfuric Acid Tank #12,000 GallonsN/AN/A13025MISAT30111974Sulfuric Acid Tank #22,000 GallonsN/AN/A13024MISAT30122005Sulfuric Acid Tank #32,000 GallonsN/AN/A13022MISAT30131974Sulfuric Acid Tank #42,000 GallonsN/AN/A13023MISAT30141974Sulfuric Acid Tank10,000GallonsN/A10,000 tons837208707SAT30152005Sulfuric Acid Tank10,000GallonsN/A10,000 tons837209707SAT30162005“A” Cooling Tower4,500 gpmEcodyneN/A13026MISAT401A1974“B” Cooling Tower6,500 gpmEcodyneE60-1207613027MISAT401B1970modified in1985“C” Cooling Tower16,500 gpmEcodyneN/A13035MISA007501992“E” Cooling Tower5,600 gpmEcodyne2- 24x24 cells31200MISF2101997Permit No. 53592Page 97 of 97November 26, 2012DescriptionCapacityManufacturerModel/Serial NumberEquipment #MiamiPlant #Installed“D” Cooling Tower(Not in service)UnknownN/A13016MISAT10051978“F” Cooling Tower9500 gpmMidwest TowersNA707SAF310NA2008Screening Machine with DieselEngine63 HPFinlay59BFD480322N/APost 1998Mastermag ElectromagneticHead Pulley100 TPHKAFKAModel # 24 EPH6, Serial #M.16112C839969707S1003June 2005Gasoline Storage tank12,000 galonsN/AN/AN/A100000905478Pre-1986Diesel Fired Genset100 KW(134 HP)Cummins100 SGAATBDF1102257612011Diesel Fired Genset20 KW(27 HP)Cummins20 DSKBATBDF1102251822011Diesel Fired Genset50 KWCummins50DSFACTBATBD2011Diesel Fired Genset35 KWCummins35DGGDTBATBD2011Air Compressor engine540 HPSullAir1600HAFDTQ707S12742011111000092011Air Compressor engine540 HPSullAir1600HAFDTQ707S12752011111000862011Note: The prefix “707” may be also be used in place of “MI” for the entries in the column titled “Plant #” in the above table.N/A: Not availableTBD: To be decided