Arizona Administrative Code › Title 18 - ENVIRONMENTAL QUALITY › Chapter 2 - DEPARTMENT OF ENVIRONMENTAL - QUALITY AIR POLLUTION CONTROL › APPENDICES › Appendix 14 - Procedures for Sulfur Dioxide and Lead Fugitive Emissions Studies for the Hayden Smelter

Current through Register Vol. 30, No. 28, July 12, 2024
A14.1. Applicability This appendix applies to the owner or
				  operator of the primary copper smelter located in Hayden, Arizona at latitude
				  33º0'15"N and longitude 110º46'31"W.
A14.2. Study Objectives The owner or operator shall conduct
				  fugitive emissions studies to derive a measurement or accurate estimate of
				  total fugitive sulfur dioxide and lead emissions from the Hayden smelter during
				  operations, including planned and unplanned start-up and shutdown periods and
				  malfunctions, for the processes identified in A14.3 below. The studies shall
				  include uncaptured fugitive sulfur dioxide emissions from the smelter
				  processing units, but not emissions due solely to the use of fuel for space
				  heating or steam generation, burners at anode casting, or slag pouring at the
				  slag dump. The studies shall evaluate the extent to which correlations may
				  exist between fugitive sulfur dioxide, lead, and particulate matter (PM/PM10/
				  PM2.5) emissions, and shall develop such correlations as feasible.
The studies shall also be used to help validate that the
				  operating conditions or ranges specified in the capture and control device
				  maintenance and operations plans required in
				  R18-2-B1301(D)(2)
				  and R18-2-B1302(D)(2) are consistent with operating conditions demonstrating
				  attainment of the 2008 Lead National Ambient Air Quality Standards (NAAQS) in
				  the Hayden 2008 Lead NAAQS Nonattainment Area State Implementation Plan (SIP)
				  and the 2010 Sulfur Dioxide NAAQS in the Hayden 2010 Sulfur Dioxide NAAQS
				  Nonattainment Area SIP.
A14.3. Processes Evaluated
From the fugitive emissions studies, the owner or operator
				  shall develop an emission factor or accurate estimate of fugitive emissions for
				  sulfur dioxide and lead during operations, including planned and unplanned
				  start-up and shutdown periods and malfunctions, produced by each of the
				  following smelting processes:
i. Flash furnace building, including flash furnace and dryer
				  operations
ii. Converter aisle, including converter and related
				  operations
iii. Anode furnace aisle, including oxidizing, poling and
				  related operations
A14.4. Averaging Periods
The emission estimate shall include the average pounds per
				  hour emission factor for the fugitive lead and sulfur dioxide emissions from
				  each step in the smelting process identified in A14.3. The estimate shall
				  include all time periods, including planned and unplanned start-up and shutdown
				  periods and malfunctions.
A14.5. Methods and Study Protocols
The owner or operator shall submit to the Department and EPA
				  Region IX for review and approval study protocols at least six months prior to
				  conducting fugitive emission studies. Study protocols must be approved by the
				  Department and EPA Region IX prior to commencement of fugitive emissions
				  studies. Study protocols shall specify the method(s) used to meet the study
				  objectives as described in A14.2, including during all recurring operating
				  scenarios from all processes identified in A14.3.
Each fugitive emissions measurement system shall include
				  validation of adequate velocity for flow measurements (i.e., the expected
				  exhaust velocity is within the measurement range of the instrument), and have a
				  sufficient number of flow and temperature sensors to ensure calculation of
				  representative exhaust flows through each roof monitor vent. The number of such
				  sensors and their locations for each monitoring system shall account for the
				  physical configuration of the roof monitor vent, the locations of emitting
				  activities relative to the roof monitor vent, and heat generated by the
				  equipment served by the roof monitor vent.
The fugitive emissions studies shall include operation and
				  process information to help understand the emission impacts of startup,
				  shutdown, malfunctions, and significant changes in process operations. This
				  shall include, for example, dates, times and duration of these events, cause of
				  malfunctions, and descriptions of process changes.
After the completion of each fugitive emissions study, the
				  owner or operator shall modify study methods based on data and lessons learned
				  from previous studies, and submit such modified methods in the proceeding study
				  protocols prior to conducting future emissions studies.
A14.6. Study Duration, Frequency, and Submission Schedule The
				  first fugitive emissions study must commence not later than six months after
				  the completion of the Converter Retrofit Project authorized by Significant
				  Permit Revision No. 60647. The second study commencement date shall occur
				  within the same calendar quarter, but five years later from the date of
				  commencement of the first study. The owner or operator shall submit the results
				  of each fugitive emissions study in a report to the Department and EPA Region
				  IX for review and approval not later than six months after completing a study.
				  The data collection portion of the first and second fugitive emissions studies
				  shall be conducted for a period of 12 months to assess the content and quantity
				  of fugitive sulfur dioxide and lead emissions.
A14.7. Study Reports and Subsequent Studies At minimum,
				  fugitive emission study reports submitted pursuant to A14.6 must
				  include:
i. Resultant emission factors used to determine fugitive
				  emissions of sulfur dioxide and lead.
ii. Resultant average fugitive lead emissions for each
				  process identified in A14.3.
iii. Resultant peak one-hour fugitive sulfur dioxide
				  emissions for each process identified in A14.3.
iv. Seasonal differences, if any.
v. Comparisons of results from past studies, if any.
vi. Descriptions and identification of volumetric flow
				  monitoring provisions in
				  R18-2-B1301(D)(2)(a)
				  and
				  R18-2-B1302(D)(2)(a)
				  and operational limits
				  R18-2-B1301(D)(2)(b)
				  and
				  R18-2-B1302(D)(2)(b)
				  that are associated with fugitive emissions.
vii. An analysis of whether the results from a study
				  demonstrate that the volumetric flow monitoring provisions in
				  R18-2-B1301(D)(2)(a)
				  and
				  R18-2-B1302(D)(2)(a)
				  and the operational limits in
				  R18-2-B1301(D)(2)(b)
				  and
				  R18-2-B1302(D)(2)(b)
				  continuously ensure that actual fugitive sulfur dioxide and lead emissions are
				  consistent with the modeled emission rates used in the attainment
				  demonstrations in the Hayden 2008 Lead NAAQS Nonattainment Area SIP and the
				  Hayden 2010 Sulfur Dioxide NAAQS Nonattainment Area SIP. The analysis must also
				  identify subsequent fugitive emissions studies, if any, needed to remedy
				  inaccurate operational limits and volumetric flow monitoring provisions and to
				  ensure attainment of the 2008 Lead NAAQS and 2010 Sulfur Dioxide NAAQS. The
				  scope, duration, and frequency of any subsequent fugitive emissions studies
				  must also be identified. This provision and the report's conclusion neither
				  require nor prohibit future fugitive emission studies.
viii. An analysis of whether supplemental modeling is needed
				  to demonstrate that resultant fugitive emissions from a study provide
				  attainment of the 2008 Lead NAAQS and 2010 Sulfur Dioxide NAAQS.
ix. A summary of methods as followed per approved study
				  protocols.
A14.8. Revisions to Operations and Maintenance Plan
If an analysis conducted in accordance with A14.7(vi)
				  demonstrates that fugitive emissions associated with volumetric flow monitoring
				  provisions in
				  R18-2-B1301(D)(2)(a)
				  and
				  R18-2-B1302(D)(2)(a)
				  and operational limits in
				  R18-2-B1301(D)(2)(b)
				  and
				  R18-2-B1302(D)(2)(b)
				  may exceed the modeled emission rates used in the Hayden 2008 Lead NAAQS
				  Nonattainment Area SIP attainment demonstration and/or the Hayden 2010 Sulfur
				  Dioxide NAAQS Nonattainment Area SIP attainment demonstration, and result in an
				  increased likelihood of a NAAQS exceedance based on modeling required under
				  A14.9, then the owner or operator shall submit to the Department for approval,
				  not later than six months after completing a study, recommended changes to
				  operational limits and volumetric flow monitoring provisions as an operations
				  and maintenance plan revision pursuant to
				  R18-2-B1301(D)(2)(e)
				  and R18-2-B1302(D)(2)(e) that would achieve necessary fugitive emissions levels
				  to demonstrate attainment of the NAAQS at the same level of assurance as in the
				  attainment demonstrations. Until receiving approval of the plan revision, the
				  owner or operator shall operate and maintain the volumetric flow monitoring
				  provisions and the operational limits in accordance with the plan as initially
				  submitted pursuant to
				  R18-2-B1301(D)(2)(e)
				  and
				  R18-2-B1302(D)(2)(e).
				  Additionally, the owner and operator shall submit new attainment demonstrations
				  pursuant to A14.9, making appropriate demonstrations of attainment at adjusted
				  fugitive emissions levels.
Similarly, if an analysis conducted in accordance with
				  A14.7(vi) demonstrates that fugitive emissions associated with the volumetric
				  flow monitoring provisions in
				  R18-2-B1301(D)(2)(a)
				  and
				  R18-2-B1302(D)(2)(a)
				  and operational limits in
				  R18-2-B1301(D)(2)(b)
				  and
				  R18-2-B1302(D)(2)(b)
				  may exceed the modeled emission rates used in the Hayden 2008 Lead NAAQS
				  Nonattainment Area SIP attainment demonstration and/or the Hayden 2010 Sulfur
				  Dioxide NAAQS Nonattainment Area SIP attainment demonstration, and result in an
				  increased likelihood of a NAAQS exceedance based on modeling required under
				  A14.9, then the Department shall submit appropriate changes to the operational
				  limits and volumetric flow monitoring provisions, and any revised attainment
				  demonstration pursuant to A14.9, if applicable, to EPA Region IX as a SIP
				  revision not later than 12 months after completion of a fugitive emissions
				  study.
A14.9. Supplemental Modeling
If an analysis conducted in accordance with A14.7(vii)
				  demonstrates that fugitive emissions associated with volumetric flow monitoring
				  provisions in
				  R18-2-B1301(D)(2)(a)
				  and
				  R18-2-B1302(D)(2)(a)
				  and operational limits in
				  R18-2-B1301(D)(2)(b)
				  and
				  R18-2-B1302(D)(2)(b)
				  are greater than the modeled emission rates used in the Hayden 2008 Lead NAAQS
				  Nonattainment Area SIP attainment demonstration and/or the Hayden 2010 Sulfur
				  Dioxide NAAQS Nonattainment Area SIP attainment demonstration, the owner or
				  operator shall remodel to demonstrate whether the 2010 Sulfur Dioxide NAAQS
				  and/or 2008 Lead NAAQS will be attained as such higher rates. The owner or
				  operator shall submit such modeling to the Department and EPA Region IX for
				  review and approval not later than six months after completing a fugitive
				  emissions study.
If the revised modeling demonstrates that the 2010 Sulfur
				  Dioxide NAAQS and/or 2008 Lead NAAQS will be attained, the Department shall
				  submit such modeling demonstration and revised fugitive emissions assumptions
				  as a SIP revision to EPA Region IX not later than 12 months after completion of
				  a fugitive emissions study. Alternatively, the owner or operator shall propose
				  additional emission control requirements to revise the SIP, or any combination
				  of revised control measures and modeled attainment, to demonstrate attainment
				  of the 2010 Sulfur Dioxide NAAQS and/or 2008 Lead NAAQS.