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Home My WebLink AboutDAQ-2024-0081191/23/24, 11:40 AM State of Utah Mail - Kennecott - Ozone Serious SIP RACT submittal https://mail.google.com/mail/u/0/?ik=539c285453&view=pt&search=all&permmsgid=msg-f:1786635242078936498&simpl=msg-f:1786635242078936…1/1 Ana Williams <anawilliams@utah.gov> Kennecott - Ozone Serious SIP RACT submittal Esker, Jenny (RTKC) <Jenny.Esker@riotinto.com>Fri, Dec 29, 2023 at 9:42 AM To: "anawilliams@utah.gov" <anawilliams@utah.gov>, Sarah Foran <sforan@utah.gov>, Jon Black <jlblack@utah.gov> Cc: "Keough, Austin (RTKC)" <Austin.Keough@riotinto.com>, "Daly, Sean 3 (RTKC)" <Sean.Daly3@riotinto.com> Hello Ana, Attached is the submittal requested in the UDAQ letter (DAQP-042-23) sent on May 31, 2023. Please let us know if you have any questions. Regards, Jenny Jenny Esker (she / her / hers) Principal Advisor, HSES Air Quality 4700 Daybreak Parkway, South Jordan, UT 84009 (mailing) Central Lab, 2500 South 9180 West, Magna, UT 84044 T +1 801 569 6494 M +1 801 201 4137 Rio Tinto Plc Registered office 6 St James’s Square, London, SW1Y 4AD, United Kingdom. Registered in England No.460473 This email is confidential and may also be privileged. If you are not the intended recipient, please notify us immediately and delete this message from your system without first printing or copying it. Any personal data in this email (including any attachments) must be handled in accordance with the Rio Tinto Group Data Protection Policy and all applicable data protection laws. Kennecott-SeriousSIP-RACTsubmittal-20231229.pdf 873K Rio Tinto Kennecott, 4700 Daybreak Parkway, South Jordan, Utah, 84009 December 29, 2023 Mr. Bryce Bird – Director Utah Division of Air Quality 195 N 1950 W Salt Lake City, UT 84116 Attn: Ms. Ana Williams Subject: Rio Tinto Kennecott Utah Copper LLC Serious Ozone Nonattainment Area RACT analysis Dear Director Bird, On May 31, 2023, the Utah Division of Air Quality (UDAQ) sent two letters (DAQP- 042 -23) to Rio Tinto Kennecott Utah Copper LLC (Kennecott) outlining specific actions related to the redesignation of the Northern Wasatch Front from moderate to serious. This submittal satisfies the actions outlined in the UDAQ letter. Smelter & Refinery The S melter & Refinery are existing major sources. A Reasonable Available Control Technology (RACT) analysis was provided for the moderate state implementation plan (SIP). The previous RACT analysis was discussed with UDAQ in a meeting on July 20, 2023. Comments from that discussion have been incorporated and the updated RACT is provided with this submittal. Bingham Canyon Mine & Copperton Concentrator As discussed in the letter to UDAQ dated December 27, 2023, the Bingham Canyon Mine and Copperton Concentrator are single sources under separate Approval Orders. Both sources are currently minor sources and will continue to be minor sources under the redesignation. However, Kennecott will continue to participate in the SIP process. The Kennecott RACT analysis provided for the moderate SIP was discussed with UDAQ in a meeting on July 20, 2023. Comments from that discussion have been incorporated and the updated RACT is provided with this submittal. If you have questions, please contact me at jenny.esker@riotinto.com. Yours sincerely, Jenny Esker Evans Principal Advisor, Air Quality Rio Tinto Kennecott 4700 Daybreak Parkway South Jordan, Utah 84009 Tel: 801-204-2000 Ozone State Implementation Plan: Reasonably Available Control Technology Determinations for Kennecott Utah Copper Revision: Final Submitted to: Utah Division of Air Quality December 20, 2023 Ozone State Implementation Plan: Reasonably Available Control Technology Determinations for Kennecott Utah Copper 231005163008_7a16d74e i Contents Acronyms and Abbreviations .......................................................................................................................................... ii 1. Overview of Kennecott Facilities .................................................................................................................... 1-1 1.1 Bingham Canyon Mine and Copperton Concentrator ............................................................................ 1-1 1.2 Smelter and Refinery ........................................................................................................................................... 1-1 1.3 Reasonably Available Control Technology Analysis ............................................................................... 1-2 2. RACT Determinations for Bingham Canyon Mine and Copperton Concentrator ............................... 2-1 2.1 Bingham Canyon Mine ........................................................................................................................................ 2-4 2.2 Copperton Concentrator .................................................................................................................................... 2-6 3. Smelter and Refinery ........................................................................................................................................ 3-1 3.1 Smelter ...................................................................................................................................................................... 3-2 3.2 Refinery .................................................................................................................................................................. 3-12 Appendixes A Cost Information B RBLC and CARB Search Documentation C Evaluation of KUC’s Applicability to U.S. Environmental Protection Agency Control Techniques Guidelines D Information on Utah Power Plant, Tailings, Bonneville Borrow Area, and Central Laboratory Tables 1-1 PTE Emissions for Bingham Canyon Mine and Copperton Concentrator ................................................. 1-1 1-2 PTE Emissions for Smelter and Refinery ............................................................................................................... 1-2 2-1 Bingham Canyon Mine and Copperton Concentrator Emission Sources .................................................. 2-1 3-1 Smelter and Refinery Emission Sources ................................................................................................................ 3-1 3-2 Equipment with Emissions Routed Through Main Stack ................................................................................. 3-4 3-3 Emission Rates for Technically Feasible Control Technologies ................................................................... 3-4 3-4 Estimated Total Annualized Costs of NOx Removal .......................................................................................... 3-5 Ozone State Implementation Plan: Reasonably Available Control Technology Determinations for Kennecott Utah Copper 231005163008_7a16d74e ii Acronyms and Abbreviations AO Approval Order BACT best available control technology BCM Bingham Canyon Mine CARB California Environmental Protection Agency – Air Resource Board BACT Clearinghouse CFR Code of Federal Regulations CHP combined heat and power CTG Control Techniques Guidelines EPA U.S. Environmental Protection Agency FC flash converting FGR flue gas recirculation HP horsepower KUC Kennecott Utah Copper LNB low-NOx burner MACT maximum achievable control technology MMBtu/hr million British thermal units per hour NAAQS National Ambient Air Quality Standard NG natural gas NOx nitrogen oxide PM2.5 particulate matter less than or equal to 2.5 microns in aerodynamic diameter ppm parts per million ppmvd parts per million by volume, dry PTE potential to emit RACT reasonably available control technology RBLC RACT/BACT/LAER Clearinghouse Refinery Kennecott Utah Copper Refinery SCR selective catalytic reduction SIP State Implementation Plan Ozone State Implementation Plan: Reasonably Available Control Technology Determinations for Kennecott Utah Copper 231005163008_7a16d74e iii Smelter Kennecott Utah Copper Smelter SO2 sulfur dioxide tpy ton(s) per year UDAQ Utah Division of Air Quality UPP Utah Power Plant VOC volatile organic compound Ozone State Implementation Plan: Reasonably Available Control Technology Determinations for Kennecott Utah Copper 231005163008_7a16d74e 1-1 1. Overview of Kennecott Facilities In May 2023, the Utah Division of Air Quality (UDAQ) issued communications to Kennecott Utah Copper (KUC) detailing potential impacts that could be caused by reclassification of the Northern Wasatch Front Nonattainment Area from moderate to serious in 2025. With this change in nonattainment status, sources that emit or have a potential to emit (PTE) emissions of 50 tons per year or more of nitrogen oxide (NOX) or volatile organic compounds (VOCs) will be considered major stationary sources. Detailed within these communications, UDAQ also asked all major stationary sources to prepare and submit a Reasonably Available Control Technology (RACT) analysis for the emission units at the Bingham Canyon Mine, Copperton Concentrator, Smelter, and Refinery. KUC has prepared this analysis in accordance with this request. 1.1 Bingham Canyon Mine and Copperton Concentrator Current operations at the Bingham Canyon Mine (BCM) are permitted under Approval Order (AO) DAQE- AN105710047-21, issued on May 10, 2021. Current operations at the Copperton Concentrator are permitted under AO DAQE-AN105710044-18, issued on August 21, 2018. PTE emissions for the Copperton Concentrator are a very small percentage of combined emissions from the mine and concentrator facilities. PTE emissions in tons per year (tpy) for the BCM and Copperton Concentrator are shown in Table 1-1. Table 1-1. PTE Emissions for Bingham Canyon Mine and Copperton Concentrator Notes: NOx = nitrogen oxide VOC = volatile organic compound 1.2 Smelter and Refinery Operations at the KUC Smelter (Smelter) are permitted under AO DAQE-AN103460061-22, issued on June 23, 2022. The U.S. Environmental Protection Agency (EPA) performed extensive technology reviews of Smelter emissions in support of the 2002 primary copper smelting major source maximum achievable control technology (MACT) standard (40 Code of Federal Regulations [CFR] 63 Subpart QQQ) and the 2007 primary copper smelting area source MACT standard (40 CFR 63 Subpart EEEEEE). Specific discussion of the unique aspects of pollution controls at the Smelter are included in the Federal Register notices associated with the draft and final promulgation of both rules. Both standards establish a separate category for only the Smelter due to its unique design and emission performance not achievable by conventional technology. The primary copper smelting area source MACT standard specifically identifies the Smelter main stack emission performance as MACT for copper smelters (existing sources, not using batch copper converters). Smelter process and emission-controlling technologies that contributed to EPA’s designation of the modernized smelter as a separate MACT category for hazardous air pollutant emissions, including off- gases from furnaces, also contribute to the control of fine particulate and precursor emissions. No new major developments in technologies or costs have occurred after promulgation of the MACT standards. NOx PTEs (tpy) VOC PTEs (tpy) Bingham Canyon Mine 5,842.11 314.13 Copperton Concentrator 10.66 4.04 Ozone State Implementation Plan: Reasonably Available Control Technology Determinations for Kennecott Utah Copper 231005163008_7a16d74e 1-2 Current operations at the KUC Refinery (Refinery) are permitted under AO DAQE-AN103460058-20, issued on November 12, 2020. The Smelter and Refinery facilities operate under a single Title V Operating Permit. PTE emissions in tons per year for the Smelter and Refinery are shown in Table 1-2. Table 1-2. PTE Emissions for Smelter and Refinery NOx PTEs (tpy) VOC PTEs (tpy) Smelter 161.25 14.86 Refinery 36.88 5.61 1.3 Reasonably Available Control Technology Analysis The Clean Air Act requires that stationary sources implement RACT to demonstrate attainment as expeditiously as possible and meet any reasonable further progress requirements. As requested by UDAQ, the RACT analysis should identify and evaluate reasonable and available control technologies for each relevant pollutant. The technical and economic feasibility of each potential technology are components of the RACT analysis that help to show whether a control technology is reasonable. The RACT analysis presented in this document was developed in accordance with the guidance established by EPA and the Clean Air Act. A RACT analysis was developed for NOx and VOC emissions. For each emission source, the RACT analysis followed a four-step process:  Step 1—Identify all control technologies listed in the RACT/BACT/LAER Clearinghouse (RBLC) and/or California Environmental Protection Agency – Air Resource Board BACT Clearinghouse (CARB).  Step 2—Eliminate technically infeasible options.  Step 3—Eliminate economically/chronologically infeasible options.  Step 4—Identify RACT. KUC understands that additional controls beyond RACT may be required by UDAQ to demonstrate attainment of the ozone National Ambient Air Quality Standard (NAAQS). However, a beyond-RACT analysis is a separate and distinct review process from the RACT analysis and requires that a modeling analysis be performed to demonstrate that implementation of additional controls beyond RACT would advance the attainment of the standard. It is important that these steps be implemented discretely and sequentially. KUC contends that RACT is determined and then modeled to determine attainment as part of the SIP preparation. Cost information for add-on controls evaluated within this RACT analysis is provided in Appendix A. Results from the review of the EPA RBLC and CARB search results are included in Appendix B. As requested by UDAQ, KUC has reviewed EPA’s Control Techniques Guidelines (CTGs), which are used to evaluate VOC RACT. KUC’s applicability to these CTGs are included in Appendix C. PTE information on other small KUC sources, including the Utah Power Plant, Tailings, Bonneville Borrow Area, and Central Laboratory, is included in Appendix D for informational purposes. Ozone State Implementation Plan: Reasonably Available Control Technology Determinations for Kennecott Utah Copper 231005163008_7a16d74e 2-1 2. RACT Determinations for Bingham Canyon Mine and Copperton Concentrator This section provides RACT determinations for emission sources deemed significant at the BCM and the Copperton Concentrator. Sources at the BCM and Copperton Concentrator are listed in Table 2-1, with actual NOx and VOC emissions from 2017. Sources that emit NOx or VOC emissions are included in this RACT analysis. Table 2-1. BCM and Copperton Concentrator Emission Sources Source Description Source ID VOC (tons per year) NOx (tons per year) Included in RACT Analysis? BCM Emission Sources Main In-Pit Crusher BCM01 0 0 No C6/C7 Conveyor Transfer Point BCM02 0 0 No C7/C8 Conveyor Transfer Point BCM03 0 0 No Lime Bin BCM04 0 0 No Lime Bin BCM05 0 0 No Sample Preparation BCM07 0 0 No Truck Offloading Ore Main In-Pit Crusher BCM1.1 0 0 No Cold Solvent Degreasing Parts BCM1.11 1.69E+00 0.00E+00 Yes (Sec 2.1.3) Haul Roads - In-Pit Suppressant BCM1.12 0 0 No Haul Roads - In-Pit Water BCM1.12 0 0 No Haul Roads - Out of Pit BCM1.12 0 0 No Copper Ore Storage Pile BCM1.13 0 0 No Front End Loaders - In-Pit BCM1.16 0 0 No Front End Loaders - Out of Pit BCM1.16 0 0 No Truck Loading BCM1.17 0 0 No Haul Trucks & Support Equipment BCM1.18 2.06E+02 4.20E+03 Yes (Sec 2.1.1) Truck Offloading Waste Rock BCM1.19 0 0 No Main In-Pit Enclosed Transfer Points 1,2 & 3 BCM1.2 0 0 No Graders - In-Pit BCM1.20 0 0 No Graders - Out of Pit BCM1.20 0 0 No Bulldozers (Track Type) - In-Pit BCM1.21 0 0 No Bulldozers (Track Type) - Out of Pit BCM1.21 0 0 No Wheeled Dozers BCM1.22 0 0 No Drilling with Water Injection BCM1.23 0 0 No Blasting with Minimized Area BCM1.24 0 0 No SXEW Copper Extractiona BCM1.25 0 0 No Conveyor-Stacker Transfer Point BCM1.3 0 0 No Ozone State Implementation Plan: Reasonably Available Control Technology Determinations for Kennecott Utah Copper 231005163008_7a16d74e 2-2 Source Description Source ID VOC (tons per year) NOx (tons per year) Included in RACT Analysis? Coarse Ore Stacker BCM1.4 0 0 No Reclaim Tunnels BCM1.5 0 0 No Disturbed Areas - In-Pit BCM1.9 0 0 No Disturbed Areas - Out of Pit BCM1.9 0 0 No Gasoline Fueling BCM1.A 1.12E+00 0.00E+00 Yes (Sec 2.1.2) Diesel Fueling BCM1.B 6.05E-01 0.00E+00 Yes (Sec 2.1.2) Tertiary Crushing BCM100 0 0 No Screening BCM101 0 0 No Transfer Points BCM102 0 0 No Process Transfer Points BCM103 0 0 No Crushers BCM104 0 0 No Grizzly Screen(s) BCM105 0 0 No In-Pit Enclosed Transfer Point 4 BCM203 0 0 No Truck Offloading Ore Stockpile BCM205 0 0 No Dinkyville Hill BCMGENDinkyville 2.45E-03 7.32E-03 Yes (Sec 2.1.4) Galena Gulch BCMGENGalena 3.16E-03 2.22E-02 Yes (Sec 2.1.4) EmResp EG at Lark Gate BCMGENLark 7.24E-04 2.69E-03 Yes (Sec 2.1.4) Communications EG at 6190 BCMGENOffice 0 0 No Truck Dispatch EG @ 6690 BCMGENTruck 7.38E-03 2.31E-02 Yes (Sec 2.1.4) Zelnora BCMGENZelnora 0 0 No Lark Node #2 BCMLarkNode 7.14E-04 2.14E-03 Yes (Sec 2.1.4) Main Sub BCMMainSub 2.59E-03 7.76E-03 Yes (Sec 2.1.4) NRS Generator #1 BCMNRS1 2.09E-01 2.24E+00 Yes (Sec 2.1.6) NRS Generator #2 BCMNRS2 0 0 No NRS Generator #3 BCMNRS3 0 0 No SAM Site BCMSAM 9.85E-05 2.96E-04 Yes (Sec 2.1.4) Copperton Concentrator Emission Sources Product Molly Dryer CPT05 0 0 No Molly Storage Bins CPT06 0 0 No Prd Dryer Heater CPT09 8.60E-02 1.56E+00 Yes (Sec 2.2.4) Gasoline Fueling CPT1.1 1.39E-01 0.00E+00 Yes (Sec 2.2.3) Cold Solv. Degrease. Washers CPT1.2 8.30E-02 0.00E+00 Yes (Sec 2.2.2) Lgr Product Molly Dryer CPT13 0 0 No Prod Dryer Heater CPT14 4.00E-02 7.28E-01 Yes (Sec 2.2.4) Molly Vacuum CPT15 0 0 No Molly Loading (Bags) CPT16 0 0 No Ozone State Implementation Plan: Reasonably Available Control Technology Determinations for Kennecott Utah Copper 231005163008_7a16d74e 2-3 Source Description Source ID VOC (tons per year) NOx (tons per year) Included in RACT Analysis? Transfer from CNV CV-04 onto CNV CV-05 CPTFS-01 0 0 No Transfer from CNV CV-05 into Crushed Pebble Surge Bin BN-02 CPTFS-02 0 0 No Transfer from SAG No. 1 Belt Feeder FE-03 onto CNV CV-06 and CNV CV-11 CPTFS-03, CPTFS-04 0 0 No Transfer from CNV CV-11 to SAG 1 Feed Chute CPTFS-05 0 0 No Transfer from SAG No. 2 Belt Feeder FE_04 onto CNV CV-10 CPTFS-06 0 0 No Transfer from CNV CV-10 to SAG 2 Feed Chute CPTFS-07 0 0 No Transfer from SAG No. 3 Belt Feeder FE_05 onto CNV CV-09 CPTFS-08 0 0 No Transfer from CNV CV-09 to SAG 3 Feed Chute CPTFS-09 0 0 No Transfer from SAG No. 4 Belt Feeder FE_06 onto CNV CV-07 and CNV CV-08 CPTFS-10, CPTFS-11 0 0 No Transfer from CNV CV-08 to SAG 4 Feed Chute CPTFS-12 0 0 No Transfer onto CNV CV-02 CPTFS-13 0 0 No Transfer from CNV CV-02 onto CNV CV-03 CPTFS-14 0 0 No Transfer from CNV CV-03 into the Surge Bin BN-01 CPTFS-15 0 0 No Transfer from Belt Feeders FE-02 and FE-01 into crushers CR-01 and CR-02 CPTFS-16, CPTFS-17 0 0 No Transfer from bottom of crushers CR-01 and CR-02 onto CNV CV-04 CPTFS-18, CPTFS-19 0 0 No Transfer from CNV CV-03 into the Surge Bin BN-03 CPTFS-20 0 0 No Transfer from Belt Feeders FE-07 onto CNV CV-04 CPTFS-21 0 0 No Pebble Crushing in Crusher CR-01 CPTFS-22 0 0 No Pebble Crushing in Crusher CR-02 CPTFS-23 0 0 No CPT Tioga Space Heaters CPTTiogaSpcHtr 3.45E-02 5.90E-01 Yes (Sec 2.2.1) CPT - Sodium Cyanide Storage Tanks #N/A 0 0 No Notes: a VOC emissions have been permitted for SXEW; however, no emissions occurred in 2017. Ozone State Implementation Plan: Reasonably Available Control Technology Determinations for Kennecott Utah Copper 231005163008_7a16d74e 2-4 2.1 Bingham Canyon Mine This section presents the RACT analysis of NOx and VOC emissions for the BCM sources listed in Table 2-1. 2.1.1 Tailpipe Emissions from Mobile Sources Source Description: Tailpipe emissions are from diesel combustion generated by haul trucks and support equipment such as graders and dozers. Emissions from the haul trucks and support equipment meet the required EPA standards for NONROAD equipment.  Step 1—Identify All Control Technologies. The RBLC and CARB databases identify no add-on control technologies for tailpipe emissions from haul trucks and support equipment of the size used at the BCM.  Step 2—Eliminate Technically Infeasible Options. Not applicable.  Step 3—Eliminate Economically/Chronologically Infeasible Options. Not applicable.  Step 4—Identify RACT. Haul trucks and support equipment used at the facility meet the required EPA standards for nonroad equipment. The facility uses on-road specification diesel fuel in its off-road equipment. Additionally, the facility periodically upgrades its haul truck fleet to also take advantage of available higher-tier-level, lower-emitting engines. In recent years, KUC has purchased newer haul trucks with higher capacity where possible, which has led to a decrease in round trips and truck operating hours, thereby reducing emissions. 2.1.2 Fueling Stations Source Description: Adding gasoline and diesel to storage tanks and dispensing from the storage tanks into vehicles results in VOC emissions. The fueling operation is equipped with Stage 1 and Stage 2 vapor recovery systems.  Step 1—Identify All Control Technologies. The RBLC and CARB databases identify two control techniques for controlling VOC emissions from gasoline and diesel fueling operations. They are Stage 1 and Stage 2 vapor recovery systems.  Step 2—Eliminate Technically Infeasible Options. Not applicable as all identified control technologies are technically feasible.  Step 3—Eliminate Economically/Chronologically Infeasible Options. Not applicable because all potential technologies identified in Step 1 are selected as RACT.  Step 4—Identify RACT. Stage 1 and 2 vapor recovery constitutes RACT for these sources. 2.1.3 Cold Solvent Degreasers Source Description: Cold solvents are used to degrease and clean equipment parts. The degreaser lids are kept closed when the unit is not in use to minimize solvent loss and emissions.  Step 1—Identify All Control Technologies. The RBLC and CARB databases identify operating practices such as closing the degreaser lids a method to control/minimize VOC emissions.  Step 2—Eliminate Technically Infeasible Options. Not applicable as the identified control technology is technically feasible.  Step 3—Eliminate Economically/Chronologically Infeasible Options. Not applicable because all potential technologies identified in Step 1 are selected as RACT. Ozone State Implementation Plan: Reasonably Available Control Technology Determinations for Kennecott Utah Copper 231005163008_7a16d74e 2-5  Step 4—Identify RACT. When not in use, the lids on the degreasers are always kept closed to minimize emissions. The solvent is recycled frequently, and no significant loss in volume is observed, implying minimal losses as emissions. These practices constitute RACT for degreasers. 2.1.4 Propane Communications Generators Source Description: The mine operates six (6) propane-fired communications generators. These generators are used to support mine communication systems during emergencies or loss of power in the mine. Emissions are controlled with good combustion practices while operating the generators.  Step 1—Identify All Control Technologies. The RBLC and CARB databases identify good combustion practices as the primary control technology for emergency generators between 70 horsepower (HP) and 150 HP operated on propane. The emergency generators must also comply with the applicable New Source Performance Standards established by EPA.  Step 2—Eliminate Technically Infeasible Options. Not applicable as all identified control technologies are technically feasible.  Step 3—Eliminate Economically/Chronologically Infeasible Options. Not applicable because all potential technologies are feasible.  Step 4—Identify RACT. Good combustion practices are identified as RACT for the propane-fired emergency generators. The emergency generators also comply with applicable New Source Performance Standards. 2.1.5 Solvent Extraction and Electrowinning Process Source Description: Tanks, mixers, and settlers are used in the solvent extraction and electrowinning process. Covers are used to minimize emissions from these sources.  Step 1—Identify All Control Technologies. The RBLC and CARB databases do not identify specific controls for solvent extraction and electrowinning process. Based on the mining experience, KUC identifies covers on process equipment to minimize emissions.  Step 2—Eliminate Technically Infeasible Options. Not applicable as all identified control technologies are technically feasible.  Step 3—Eliminate Economically/Chronologically Infeasible Options. Not applicable because all potential technologies are feasible.  Step 4—Identify RACT. Use of covers is identified as RACT for the solvent extraction and electrowinning process. 2.1.6 Diesel Emergency Generators Source Description: Diesel-fired emergency generators are operated to support various underground mining equipment during emergencies. The emergency generators comply with applicable New Source Performance Standards to minimize emissions.  Step 1—Identify All Control Technologies. Potential emission control technologies identified in the RBLC and CARB for similar-sized diesel generators include turbo charger and after cooling, good combustion practices and limiting the sulfur content of fuel to 0.0015 percent. Certification and compliance with applicable New Source Performance Standards are acceptable means of demonstrating RACT for emergency generators.  Step 2—Eliminate Technically Infeasible Options. Not applicable as all identified control technologies are technically feasible.  Step 3—Eliminate Economically/Chronologically Infeasible Options. Not applicable because all potential technologies identified in Step 1 are selected as RACT. Ozone State Implementation Plan: Reasonably Available Control Technology Determinations for Kennecott Utah Copper 231005163008_7a16d74e 2-6 Step 4—Identify RACT. Turbo charger and after cooling if needed, good combustion practices, limiting the sulfur content of fuel to 0.0015 percent and complying with applicable New Source Performance Standards requirements are identified as RACT for all pollutants emitted from the emergency generators. 2.2 Copperton Concentrator This section presents the RACT analysis of NOx and VOC emissions for the Copperton Concentrator sources listed in Table 2-1. 2.2.1 Tioga Heaters Source Description: Natural gas-fired heaters are used throughout the Copperton Concentrator. The heaters are rated at less than 5 million British thermal units per hour (MMBtu/hr) each. Specifically, the facility includes seven (7) 4.2-MMBtu/hr natural gas-fired heaters and one (1) 2.4-MMBtu/hr natural gas-fired heater. The heaters are regularly inspected for optimum combustion performance. 2.2.1.1 NOx RACT  Step 1—Identify All Control Technologies. The RBLC and CARB identify good combustion practices, use of pipeline-quality natural gas, and regular inspections as control technologies for minimizing NOx emissions from heaters less than 5 MMBtu/hr.  Step 2—Eliminate Technically Infeasible Options. Not applicable as all identified control technologies are technically feasible.  Step 3—Eliminate Economically/Chronologically Infeasible Options. Not applicable because all potential technologies identified in Step 1 are selected as RACT.  Step 4—Identify RACT. The technologies identified in the RBLC for controlling NOx emissions from heaters, namely good combustion practices, use of pipeline-quality natural gas, and regular inspections, are already in use and constitute RACT. KUC contacted vendors regarding the feasibility of replacement of the eight Tioga heaters at the Copperton Concentrator. Based on the data provided by the vendors, the total installed cost of the eight new heaters is estimated to be $1,415,817. The cost estimate assumes the installation costs to be 35 percent of the equipment costs. These heaters will be equipped with the latest burner technology. Assuming a 90 percent reduction in NOx emissions, the new heaters will reduce the annual NOx emissions from the Tioga heaters from 0.63 tpy (2017 actual emissions) to 0.06 tpy. The vendor-provided information is included in Appendix A. Based on the costs for the new heaters, the cost of new heaters per ton of NOx removed is $328,699. Therefore, replacing the Tioga heaters is not cost effective for RACT. 2.2.1.2 VOC RACT  Step 1—Identify All Control Technologies. The RBLC and CARB identify the use of pipeline-quality natural gas, good combustion practices, and regular inspections as control technology for minimizing VOC emissions from heaters.  Step 2—Eliminate Technically Infeasible Options. Not applicable as all identified control technologies are technically feasible.  Step 3—Eliminate Economically/Chronologically Infeasible Options. Not applicable because all potential technologies identified in Step 1 are selected as RACT. Ozone State Implementation Plan: Reasonably Available Control Technology Determinations for Kennecott Utah Copper 231005163008_7a16d74e 2-7  Step 4—Identify RACT. The RBLC identifies use of pipeline-quality natural gas, good combustion practices, and regular inspections as a means of controlling VOC emissions from heaters and these control technologies constitute RACT. 2.2.2 Cold Solvent Degreasers Source Description: Cold solvents are used to degrease and clean equipment parts. The degreaser lids are kept closed when the unit is not in use to minimize solvent loss and emissions.  Step 1—Identify All Control Technologies. The RBLC and CARB databases identify operating practices such as closing the degreaser lids a method to control/minimize VOC emissions.  Step 2—Eliminate Technically Infeasible Options. Not applicable as the identified control technology is technically feasible.  Step 3—Eliminate Economically/Chronologically Infeasible Options. Not applicable because all potential technologies identified in Step 1 are selected as RACT.  Step 4—Identify RACT. When not in use, the lids on the degreasers are kept closed always to minimize emissions. The solvent is recycled frequently, and no significant loss in volume is observed, implying minimal losses as emissions. These practices constitute RACT for degreasers. 2.2.3 Gasoline Fueling Stations Source Description: Adding gasoline to storage tanks and dispensing from the storage tanks into vehicles. The fueling operation is equipped with Stage 1 and Stage 2 vapor recovery systems.  Step 1—Identify All Control Technologies. The RBLC and CARB databases identify two control techniques for controlling VOC emissions from gasoline fueling operations. They are Stage 1 and Stage 2 vapor recovery systems.  Step 2—Eliminate Technically Infeasible Options. Not applicable as all identified control technologies are technically feasible.  Step 3—Eliminate Economically/Chronologically Infeasible Options. Not applicable because all potential technologies identified in Step 1 are selected as RACT.  Step 4—Identify RACT. Stage 1 and 2 vapor recovery constitutes RACT for these sources. 2.2.4 Feed and Product Dryer Oil Heaters Source Description: Natural gas-fired heaters provide heat to the feed and product dryers that are used in molybdenum process at the Copperton Concentrator. The heaters are rated at 5.7 MMBtu/hr and 2.2 MMBtu/hr each. The heaters are regularly inspected for optimum combustion performance. 2.2.4.1 NOx RACT  Step 1—Identify All Control Technologies. The RBLC and CARB databases identify low-NOX burners (LNBs), use of pipeline-quality natural gas, and good combustion practices as control technologies for minimizing NOx emissions from heaters less than 10 MMBtu/hr.  Step 2—Eliminate Technically Infeasible Options. Not applicable as all identified control technologies are technically feasible.  Step 3—Eliminate Economically/Chronologically Infeasible Options. Not applicable because all potential technologies identified in Step 1 are selected as RACT.  Step 4—Identify RACT. The technologies identified in the RBLC and CARB for controlling NOx emissions from heaters of LNBs, use of pipeline-quality natural gas, and good combustion practices are already in use and constitute RACT. Ozone State Implementation Plan: Reasonably Available Control Technology Determinations for Kennecott Utah Copper 231005163008_7a16d74e 2-8 2.2.4.2 VOC RACT  Step 1—Identify All Control Technologies. The RBLC and CARB databases identify use of pipeline- quality natural gas and good combustion practices as control technologies for minimizing VOC emissions from heaters.  Step 2—Eliminate Technically Infeasible Options. Not applicable as all identified control technologies are technically feasible.  Step 3—Eliminate Economically/Chronologically Infeasible Options. Not applicable because all potential technologies identified in Step 1 are selected as RACT.  Step 4—Identify RACT. The RBLC and CARB databases identify use of pipeline-quality natural gas and good combustion practices as a means of controlling VOC emissions from heaters and these control technologies constitute RACT. Ozone State Implementation Plan: Reasonably Available Control Technology Determinations for Kennecott Utah Copper 231005163008_7a16d74e 3-1 3. Smelter and Refinery This section provides RACT determinations for emission sources at the Smelter and Refinery. The sources at the Smelter and Refinery are listed in Table 3-1, with actual NOx and VOC emissions from 2018. Emissions from 2017 were not used, as that was a major Smelter shutdown year and emissions were not representative of normal operations. Those sources that emit NOx or VOC emissions are included in this RACT analysis. Table 3-1. Smelter and Refinery Emission Sources Source Description Source ID VOC (tons per year) NOx (tons per year) Included in RACT Analysis? Smelter Emission Sources Slag granulation scrubber exhaust SME010b 0 0 No Smelter Comm. Generator SME Com GEN 2.76E-03 1.66E-02 Yes (Sec 3.1.4) Feed Strg Xfer Belt BH SME001 0 0 No Feed Strg Bldg BH SME002 0 0 No Feed Xfer Belt BH SME003 0 0 No Wet Feed BH SME004 0 0 No Dry Feed BH SME005 0 0 No Limestone Silo BH SME006 0 0 No Acid Plant Preheater SME008 1.64E-02 1.49E-01 Yes (Sec 3.1.10) Main Stack SME011 4.80E+00 1.18E+02 Yes (Sec 3.1.1) Diesel Generator SME011b1 6.26E-02 2.13E+00 Yes (Sec 3.1.7) Ground Matte Silo BH SME013 0 0 No Mold Coating Silo BH SME015 0 0 No Vacuum Cleaning System SME017a 0 0 No Vacuum Cleaning System SME017b 0 0 No Vacuum Cleaning System SME017c 0 0 No Hydromet Plt Limestone Silo BH SME019 0 0 No Hydromet Plt Lime Silo BH SME020 0 0 No Lab BH SME022 0 0 No Holman Boiler (Propane) SME026 0 0 No Powerhouse Holman Boiler SME026 1.60E+00 1.13E+01 Yes (Sec 3.1.2) Recycle and Crushing Building SME027 0 0 No Anode Area Lime Silo SME028 0 0 No Secondary Gas System Lime Silo SME029 0 0 No Anode Furnace Scrubber Fugitives SMEAF 2.12E-02 4.80E-01 Yes (Sec 3.1.1.1) Acid Plant Fugitive Leaks SMEAP 0 0 No Acid Plant Cooling Tower SMECT311 0 0 No Power House Cooling Tower SMECT316 0 0 No Granulator Cooling Tower SMECT321 0 0 No Smelter Fugitives SMEF 0 0 No Ozone State Implementation Plan: Reasonably Available Control Technology Determinations for Kennecott Utah Copper 231005163008_7a16d74e 3-2 Source Description Source ID VOC (tons per year) NOx (tons per year) Included in RACT Analysis? Emergency backup power generator SMEgen1 2.36E-02 8.05E-01 Yes (Sec 3.1.7) Emergency backup power generator SMEgen2 2.55E-02 8.69E-01 Yes (Sec 3.1.7) Degreasing SMEi210 2.26E-03 0.00E+00 Yes (Sec 3.1.5) Loading to Storage Pile on Patio SMEiCONC 0 0 No Slag Concentrator SMEiSLAG 0 0 No Fueling SME-SA-1 9.09E-02 0.00E+00 Yes (Sec 3.1.6) Building heating SMESH 5.97E-02 3.35E-01 Yes (Sec 3.1.8) Misc. Storage Piles & Loadout SMESTRG 0 0 No Water heaters SMEWH 2.96E-02 5.38E-01 Yes (Sec 3.1.9) Rentech Boilera SME030 1.09E+01 1.14E+01 Yes (Sec 3.1.3) Refinery Emission Sources LPG Generator REF Backup 2.95E-03 1.77E-02 Yes (Sec 3.2.3) Solar, Inc NG Turbine and generator REF CHP 3.33E+00 6.35E+00 Yes (Sec 3.2.2) Liberator REF001 0 0 No Refinery Boilers - Diesel Fuel REF002/003 0 0 No Refinery Boilers - Natural Gas REF002/003 5.47E-01 9.05E+00 Yes (Sec 3.2.1) Cathode Wash REF004 0 0 No Anode Scrap REF005 0 0 No Hydrometallurgical Precious Metals Recovery Scrubber REF006 0 0 No Hydrometallurgical Silver Production Scrubber REF007 0 0 No Se Crushing/Packing Baghouse REF009 0 0 No Au/Ag Baghouse REF010 0 0 No Soda Ash Filter REF011 0 0 No Cooling Tower #1 REFCT001 0 0 No Cooling Tower #2 REFCT002 0 0 No Degreasing REFi201 0 0 No Paint REFi202 2.65E-02 0.00E+00 Yes (Sec 3.2.7) Primer REFi202 3.55E-02 0.00E+00 Yes (Sec 3.2.7) Space Heaters REFi204 1.67E-02 2.85E-01 Yes (Sec 3.2.5) Diesel Generator REFi210 2.87E-02 3.54E-01 Yes (Sec 3.2.6) Gasoline Fueling REF-SA-1 2.72E-02 0.00E+00 Yes (Sec 3.2.4) Notes: a Rentech boiler was installed in 2020. Actual emissions provided for 2021 representing a full year of operation. BH = Baghouse; CHP = combined heat and power 3.1 Smelter The EPA performed extensive technology reviews of Smelter emissions in support of the 2002 primary copper smelting major source MACT standard (40 CFR 63 Subpart QQQ) and the 2007 primary copper smelting area source MACT standard (40 CFR 63 Subpart EEEEEE). Specific discussion of the unique Ozone State Implementation Plan: Reasonably Available Control Technology Determinations for Kennecott Utah Copper 231005163008_7a16d74e 3-3 aspects of pollution controls at the KUC Smelter are included in the Federal Register notices associated with the draft and final promulgation of both rules (e.g., the design of the Smelter is based on the furnace technology). Typical smelting operations require batch processing which intermittently produces high concentrations of sulfur dioxide (SO2) and particulate in a manner that can reduce the efficiency of the acid plant as a control device. By employing the flash smelting and flash converting (FC) technologies, KUC can eliminate many of the problems inherent with batch-type smelter operations. These improvements include continuous flow of off-gases to the acid plant during the FC process as well as reduced total volume of off-gases. Additionally, the furnaces are stationary. This improves the ability to capture off-gases as well as the ability to capture any fugitive emissions with the secondary capture system, which cleans the gases with baghouses and scrubbers before venting to the main stack. As a result, both MACT standards go as far as to establish a separate category for only the Smelter due to its unique design and emission performance not achievable by conventional technology. The primary copper smelting area source MACT standard specifically identifies the Smelter main stack emission performance as MACT for copper smelters (existing sources not using batch copper converters). The Smelter employs several technologies to minimize the smelting emissions that report to the main stack.  The concentrate dryer burns natural gas to heat/dry concentrate for use in the flash smelting furnace. Operation with LNBs along with lower dryer temperatures minimizes the formation of NOx while also preventing the formation of SO2. KUC operates both a baghouse and a scrubber as controls for the concentrate dryer.  The matte grinding circuit crushes and dries granulated matte for use in the FC furnace. The particulate from the ground matte is collected in a baghouse and pneumatically conveyed to the FC furnace feed bin. NOx emissions from natural gas combustion are minimized with LNB and low temperature firing.  In the anodes area, blister copper from the FC furnace is refined in two available refining furnaces to remove the final traces of sulfur. Copper production can be supplemented with copper scrap, which can be added to the refining furnaces for re-melt. The anodes refining furnaces are natural gas-fired with oxy-fuel burners. Off-gas is vented (in series) to a quench tower, lime injection, baghouse, and scrubber and vented to the main stack. NOx reduction activities also include maintaining furnaces to prevent ingress of air.  The shaft furnace and holding furnace are used to re-melt anode scrap and other copper scrap to incorporate into copper production. LNBs are used to reduce NOx from the natural gas combustion. The shaft furnace is in the anodes area, but vents separately to the main stack. 3.1.1 Main Stack Source Description. Multiple process equipment emissions are routed through the main stack. Such equipment includes the matte granulators, acid plant, anode building, powerhouse, furnaces, dryers, and grinding circuits. Many of these sources of emissions have their own primary control devices (for example, baghouse and scrubbers). Some are then routed to the secondary gas system and then through the main stack. Equipment with NOx and VOC emissions routed through the main stack at the Smelter are listed and described in Table 3-2. Ozone State Implementation Plan: Reasonably Available Control Technology Determinations for Kennecott Utah Copper 231005163008_7a16d74e 3-4 Table 3-2. Equipment with Emissions Routed Through Main Stack Equipment Pollutant Emissions Primary Emissions Control Powerhouse superheater NOX, VOC Ultra-low-NOx burner, flue gas recirculation (FGR), fuel throughput limits, and good operational practices Dryer NOx, VOC LNB and good operational practices Matte grinding NOx, VOC LNB and good operational practices Anode refining furnaces NOX, VOC Oxy-fuel burners and good operational practices Anode shaft furnace NOX, VOC LNB and good operational practices Anode holding furnace NOX, VOC LNB and good operational practices 3.1.1.1 Anode Furnaces In the anodes area, blister copper from the FC furnace is refined in two available refining furnaces to remove the final traces of sulfur. The shaft furnace and holding furnace are used to re-melt anode scrap and other copper scrap to incorporate into copper production. Operated on natural gas and oxy-fuel, emissions from the furnaces are vented through baghouses and scrubbers before being vented through the main stack. 3.1.1.1.1 NOx RACT  Step 1—Identify All Control Technologies. The RBLC and CARB databases and technical studies identify the following control technologies: - Oxy-fuel burners with operational controls and work practices - Selective catalytic reduction (SCR) - Low temperature SCR - Low temperature oxidation system - Wet scrubber  Step 2—Eliminate Technically Infeasible Options. Not applicable as all identified control technologies are technically feasible.  Step 3—Eliminate Economically/Chronologically Infeasible Options. The emission rates for each of the technically feasible controls are listed in Table 3-3. Table 3-3. Emission Rates for Technically Feasible Control Technologies Control Technology Typical NOx Emission Rate Oxy-fuel burners with operational controls and work practices 30 ppm SCR 5 ppm Low temperature SCR 5 ppm Low temperature oxidation system 5 ppm Wet scrubber 5 ppm Note: ppm = parts per million The anode area is equipped with oxy-fuel burners. Costs for the control technologies were developed as part of a study for the anodes area. The preliminary study evaluated the control efficiency of each option based on a hypothetical emission rate of 60 ppm instead of an actual emission rate of approximately 30 ppm. Operations in the anodes area are continuously optimized to ensure high-efficiency operation, Ozone State Implementation Plan: Reasonably Available Control Technology Determinations for Kennecott Utah Copper 231005163008_7a16d74e 3-5 including evaluation of logic controls and work practices. By implementing standard operating procedures in the anodes area, actual emissions are estimated to be approximately 30 ppm of NOx. KUC has used the cost information from the study and the actual emissions rate to determine the economic feasibility of the above-mentioned control technologies. The estimated total annualized costs and cost per ton of NOX removed are summarized in Table 3-4. Table 3-4. Estimated Total Annualized Costs of NOx Removal Alternative Total Annualized Costs Costs per Ton of NOx Removed Determination Oxy-fuel Burners with Operational controls and work practices 0 0 Cost Effective SCR $2,304,810 $50,907 Not Cost Effective Low Temperature SCR $2,022,099 $44,663 Not Cost Effective Low Temperature Oxidation System $3,841,328 $84,844 Not Cost Effective Wet Scrubber $5,165,495 $114,092 Not Cost Effective  Step 4—Identify RACT. Oxy-fuel burners with proper operation and work practices constitute RACT for this source. The anodes area off-gas is vented to the main stack where NOx emissions are continuously monitored by a continuous emissions monitoring system. 3.1.1.1.2 VOC RACT  Step 1—Identify All Control Technologies. The RBLC and CARB databases identify use of pipeline- quality natural gas and good combustion practices as control technologies for minimizing VOC emissions from furnaces.  Step 2—Eliminate Technically Infeasible Options. Not applicable as all identified control technologies are technically feasible.  Step 3—Eliminate Economically/Chronologically Infeasible Options. Not applicable because all potential technologies identified in Step 1 are selected as RACT.  Step 4—Identify RACT. The RBLC and CARB databases identify use of pipeline-quality natural gas and good combustion practices as a means of controlling VOC emissions and these control technologies constitute RACT. 3.1.1.2 Powerhouse Superheater The powerhouse superheater is rated at 45 MMBtu/hr and operates on pipeline-quality natural gas. 3.1.1.2.1 NOx RACT  Step 1—Identify All Control Technologies. The RBLC and CARB identify use of pipeline-quality natural gas and good combustion practices as control technologies for minimizing NOx emissions from heaters.  Step 2—Eliminate Technically Infeasible Options. Not applicable as all identified control technologies are technically feasible.  Step 3—Eliminate Economically/Chronologically Infeasible Options. Not applicable because all potential technologies identified in Step 1 are selected as RACT.  Step 4—Identify RACT. The technologies identified in the RBLC for controlling NOx emissions from heaters of use of pipeline-quality natural gas and good combustion practices are already in use and constitute RACT. Ozone State Implementation Plan: Reasonably Available Control Technology Determinations for Kennecott Utah Copper 231005163008_7a16d74e 3-6 3.1.1.2.2 VOC RACT  Step 1—Identify All Control Technologies. The RBLC and CARB identify the use of pipeline-quality natural gas and good combustion practices as control technology for minimizing VOC emissions from heaters.  Step 2—Eliminate Technically Infeasible Options. Not applicable as all identified control technologies are technically feasible.  Step 3—Eliminate Economically/Chronologically Infeasible Options. Not applicable because all potential technologies identified in Step 1 are selected as RACT.  Step 4—Identify RACT. The RBLC identifies use of pipeline-quality natural gas and good combustion practices as a means of controlling VOC emissions from heaters and these control technologies constitute RACT. 3.1.1.3 Concentrate Dryer The concentrate dryer burns natural gas to heat/dry concentrate for use in the flash smelting furnace. 3.1.1.3.1 NOx RACT  Step 1—Identify All Control Technologies. The RBLC and CARB identify use of pipeline-quality natural gas and good combustion practices as control technologies for minimizing NOx emissions from dryers used in smelters.  Step 2—Eliminate Technically Infeasible Options. Not applicable as all identified control technologies are technically feasible.  Step 3—Eliminate Economically/Chronologically Infeasible Options. Not applicable because all potential technologies identified in Step 1 are selected as RACT.  Step 4—Identify RACT. The technologies identified in the RBLC for controlling NOx emissions from dryers of use of pipeline-quality natural gas and good combustion practices are already in use and constitute RACT. 3.1.1.3.2 VOC RACT  Step 1—Identify All Control Technologies. The RBLC and CARB identify the use of pipeline-quality natural gas and good combustion practices as control technology for minimizing VOC emissions from dryers used in smelters.  Step 2—Eliminate Technically Infeasible Options. Not applicable as all identified control technologies are technically feasible.  Step 3—Eliminate Economically/Chronologically Infeasible Options. Not applicable because all potential technologies identified in Step 1 are selected as RACT.  Step 4—Identify RACT. The RBLC identifies use of pipeline-quality natural gas and good combustion practices as a means of controlling VOC emissions from dryers and these control technologies constitute RACT. 3.1.1.4 Matte Grinding The matte grinding circuit crushes and dries granulated matte for use in the FC furnace. Ozone State Implementation Plan: Reasonably Available Control Technology Determinations for Kennecott Utah Copper 231005163008_7a16d74e 3-7 3.1.1.4.1 NOx RACT  Step 1—Identify All Control Technologies. The RBLC and CARB identify use of pipeline-quality natural gas and good combustion practices as control technologies for minimizing NOx emissions from dryers used in smelters.  Step 2—Eliminate Technically Infeasible Options. Not applicable as all identified control technologies are technically feasible.  Step 3—Eliminate Economically/Chronologically Infeasible Options. Not applicable because all potential technologies identified in Step 1 are selected as RACT.  Step 4—Identify RACT. The technologies identified in the RBLC for controlling NOx emissions from dryers of use of pipeline-quality natural gas and good combustion practices are already in use and constitute RACT. 3.1.1.4.2 VOC RACT  Step 1—Identify All Control Technologies. The RBLC and CARB identify the use of pipeline-quality natural gas and good combustion practices as control technology for minimizing VOC emissions from dryers used in smelters.  Step 2—Eliminate Technically Infeasible Options. Not applicable as all identified control technologies are technically feasible.  Step 3—Eliminate Economically/Chronologically Infeasible Options. Not applicable because all potential technologies identified in Step 1 are selected as RACT. Step 4—Identify RACT. The RBLC identifies use of pipeline-quality natural gas and good combustion practices as a means of controlling VOC emissions from dryers and these control technologies constitute RACT. 3.1.2 Powerhouse Holman Boiler Source Description: The boiler is used to provide process steam at the Smelter. Emissions of NOx are limited with FGR, LNB, opacity limits, an alternative monitoring plan that requires continuous monitoring of operational parameters (fuel use, stack oxygen, steam output), and operational controls with good combustion practices. Emissions of VOC are limited with use of pipeline-quality natural gas, good combustion practices, gas consumption limit, good design, opacity limits, and proper operation of the boiler. 3.1.2.1 NOx RACT  Step 1—Identify All Control Technologies. The RBLC and CARB identifies the following as possible control technologies for NOx for natural gas-fired boilers: - SCR - FGR - LNBs with good combustion practices - Good design and proper operation  Step 2—Eliminate Technically Infeasible Options. All control technologies except SCR are technically feasible. Due to the design of the boiler and existing footprint, SCR have not been deemed technically feasible.  Step 3—Eliminate Economically/Chronologically Infeasible Options. The Holman boiler is equipped with FGR and LNB to reduce NOx emissions. As part of a permitting action in 2019, KUC and UDAQ reviewed operation of the Holman boiler and feasibility of above-mentioned NOx control technologies. UDAQ concluded that the existing NOx emissions control and operational constraints meet BACT Ozone State Implementation Plan: Reasonably Available Control Technology Determinations for Kennecott Utah Copper 231005163008_7a16d74e 3-8 requirements. Therefore, the above-mentioned add-on control technologies are not further considered.  Step 4—Identify RACT. FGR, LNBs with good combustion practices, limited gas consumption, good design, and proper operation constitute RACT for this source. KUC continuously monitors operational parameters to predict NOx emissions and ensure proper boiler operation. The parameters monitored are fuel use (to predict NOx emissions in pounds per hour), stack oxygen (to monitor proper boiler operation and compliance with NOx pounds per MMBtu emission limit), and steam output (used to estimate heat input if fuel use is unavailable). The ranges for these parameters were developed during a 30-day monitoring campaign where data from a certified NOx analyzer were used to develop predictive equations with the operation parameters. The monitoring plan has been reviewed and approved by UDAQ. 3.1.2.2 VOC RACT  Step 1—Identify All Control Technologies. The RBLC and CARB identifies the following as possible control technologies for boilers: - Use of pipeline-quality natural gas and good combustion practices - Good design and proper operation  Step 2—Eliminate Technically Infeasible Options. Not applicable as all identified control technologies are technically feasible.  Step 3—Eliminate Economically/Chronologically Infeasible Options. Not applicable because all potential technologies identified in Step 1 are selected as RACT.  Step 4—Identify RACT. Use of pipeline-quality natural gas, good combustion practices, opacity limits, good design, and proper operation of the boiler constitute RACT for this emission source. 3.1.3 Rentech Boiler (Formerly Powerhouse Foster Wheeler Boiler) Source Description: This boiler is used to produce superheated steam to start the Smelter, drive acid plant compressors, and generate standby power. The Foster Wheeler boiler was replaced with a new Rentech boiler that no longer vents through the main stack. The new Rentech boiler was operational in 2021. Emissions of NOx are limited with FGR and LNB with good combustion practices. Emissions of VOCs are limited with good combustion practices and use of pipeline-quality natural gas. 3.1.3.1 NOx RACT  Step 1—Identify All Control Technologies. The RBLC and CARB identify the following as possible control technologies for NOx for natural gas-fired boilers: - SCR - FGR - LNB with good combustion practices - Good design and proper operation  Step 2—Eliminate Technically Infeasible Options. Not applicable as all identified control technologies are technically feasible.  Step 3—Eliminate Economically/Chronologically Infeasible Options. Because the boiler produces superheated as opposed to saturated steam, combustion dynamics differ and NOx emission rates for a superheated steam boiler exceed that of a saturated steam boiler using the same controls. During the permitting of this boiler in 2019, a white paper was developed to document the combustion dynamics between the two boiler styles and why a superheated steam boiler has a higher emission rate. The permitting analysis also included an analysis demonstrating SCR to be economically infeasible. UDAQ determined that LNB and FGR with a maximum emission rate of 15 parts per million by volume, dry (ppmvd) NOx emissions are the BACT for the new Rentech boiler. Ozone State Implementation Plan: Reasonably Available Control Technology Determinations for Kennecott Utah Copper 231005163008_7a16d74e 3-9  Step 4—Identify RACT. FGR, LNB constitute RACT for this emission source. 3.1.3.2 VOC RACT  Step 1—Identify All Control Technologies. The RBLC and CARB identify pipeline-quality natural gas and good combustion practices as possible control technologies for boilers.  Step 2—Eliminate Technically Infeasible Options. Not applicable as all identified control technologies are technically feasible.  Step 3—Eliminate Economically/Chronologically Infeasible Options. Not applicable because all potential technologies identified in Step 1 are selected as RACT.  Step 4—Identify RACT. Good combustion practices constitute RACT for this emission source. 3.1.4 Propane Communication Generator Source Description: The Smelter operates a propane-fired communication generator. This generator is used to support communication systems during emergencies or loss of power at the Smelter. Emissions are controlled with good combustion practices while operating the generator.  Step 1—Identify All Control Technologies. The RBLC and CARB identify good combustion practices as the primary control technology for emergency generators around 75 HP operated on propane. The emergency generators must also comply with the applicable New Source Performance Standards established by EPA.  Step 2—Eliminate Technically Infeasible Options. Not applicable as all identified control technologies are technically feasible.  Step 3—Eliminate Economically/Chronologically Infeasible Options. Not applicable because all potential technologies are feasible.  Step 4—Identify RACT. Good combustion practices are identified as RACT for the propane-fired emergency generator. The emergency generator also complies with applicable New Source Performance Standards. 3.1.5 Cold Solvent Degreaser Source Description: Cold solvents are used to degrease and clean equipment parts. The degreaser lids are kept closed when the unit is not in use to minimize solvent loss and emissions.  Step 1—Identify All Control Technologies. The RBLC and CARB identifies operating practices such as closing the degreaser lids a method to control/minimize VOC emissions.  Step 2—Eliminate Technically Infeasible Options. Not applicable as the identified control technology is technically feasible.  Step 3—Eliminate Economically/Chronologically Infeasible Options. Not applicable because all potential technologies identified in Step 1 are selected as RACT.  Step 4—Identify RACT. When not in use, the lids on the degreasers are kept closed at all times to minimize emissions. The solvent is recycled frequently, and no significant loss in volume is observed, implying minimal losses as emissions. These practices constitute RACT for the degreaser. 3.1.6 Gasoline Fueling Stations Source Description: Adding gasoline to storage tanks and dispensing from the storage tanks into vehicles. The fueling operation is equipped with Stage 1 and Stage 2 vapor recovery systems. Ozone State Implementation Plan: Reasonably Available Control Technology Determinations for Kennecott Utah Copper 231005163008_7a16d74e 3-10  Step 1—Identify All Control Technologies. The RBLC and CARB identify two control techniques for controlling VOC emissions from gasoline fueling operations. They are Stage 1 and Stage 2 vapor recovery systems.  Step 2—Eliminate Technically Infeasible Options. Not applicable as all identified control technologies are technically feasible.  Step 3—Eliminate Economically/Chronologically Infeasible Options. Not applicable because all potential technologies identified in Step 1 are selected as RACT.  Step 4—Identify RACT. Stage 1 and 2 vapor recovery constitutes RACT for these sources. 3.1.7 Diesel Emergency Generators Source Description: The Smelter operates diesel-fired emergency generators to support the processes during emergencies. The emergency generators comply with applicable New Source Performance Standards to minimize emissions.  Step 1—Identify All Control Technologies. Potential emission control technologies identified in the RBLC and CARB for similar-sized diesel generators include turbo charger and after cooling, good combustion practices and limiting the sulfur content of fuel to 0.0015 percent. Certification and compliance with applicable New Source Performance Standards are acceptable means of demonstrating RACT for emergency generators.  Step 2—Eliminate Technically Infeasible Options. Not applicable as all identified control technologies are technically feasible.  Step 3—Eliminate Economically/Chronologically Infeasible Options. Not applicable because all potential technologies identified in Step 1 are selected as RACT.  Step 4—Identify RACT. Turbo charger and after cooling if applicable, good combustion practices, limiting the sulfur content of fuel to 0.0015 percent and complying with applicable New Source Performance Standards requirements are identified as RACT for all pollutants emitted from the emergency generators. 3.1.8 Space Heaters Source Description: Natural gas-fired heaters are used throughout the Smelter. The individual heaters are rated at less than 5 MMBtu/hr each. The heaters are regularly inspected for optimum combustion performance. 3.1.8.1 NOx RACT  Step 1—Identify All Control Technologies. The RBLC and CARB identify good combustion practices and use of pipeline-quality natural gas as control technologies for minimizing NOx emissions from heaters less than 5 MMBtu/hr.  Step 2—Eliminate Technically Infeasible Options. Not applicable as all identified control technologies are technically feasible.  Step 3—Eliminate Economically/Chronologically Infeasible Options. Not applicable because all potential technologies identified in Step 1 are selected as RACT. As discussed in the RACT analysis for other KUC facilities, replacing the existing space heaters with new heaters is not cost effective for the RACT analysis.  Step 4—Identify RACT. The technologies identified in the RBLC for controlling NOx emissions from heaters through good combustion practices and pipeline-quality natural gas are already in use and constitute RACT. Ozone State Implementation Plan: Reasonably Available Control Technology Determinations for Kennecott Utah Copper 231005163008_7a16d74e 3-11 3.1.8.2 VOC RACT  Step 1—Identify All Control Technologies. The RBLC and CARB identify use of pipeline-quality natural gas and good combustion practices as a control technology for minimizing VOC emissions from heaters.  Step 2—Eliminate Technically Infeasible Options. Not applicable as all identified control technologies are technically feasible.  Step 3—Eliminate Economically/Chronologically Infeasible Options. Not applicable because all potential technologies identified in Step 1 are selected as RACT.  Step 4—Identify RACT. The RBLC and CARB identifies use of pipeline-quality natural gas and good combustion practices as a means of controlling VOC emissions from heaters and these control technologies constitute RACT. The 2014 actual emissions from the heaters for particulate matter less than or equal to 2.5 microns in aerodynamic diameter (PM2.5) and precursors were 0.48 tpy. The use of pipeline-quality natural gas and good combustion practices also represent the most stringent control measures for the space heaters. As discussed in the RACT analysis for other KUC facilities, replacing the existing space heaters with new heaters is not cost effective for the RACT analysis. 3.1.9 Hot Water Heaters Source Description: Natural gas-fired water heaters are used for water heating throughout the Smelter. The water heaters use LNBs and regular inspections are done to the units to ensure optimum combustion performance. The water heaters are rated at less than 10 MMBtu/hr. 3.1.9.1 NOx RACT  Step 1—Identify All Control Technologies. The RBLC and CARB identify LNB, use of pipeline-quality natural gas, and good combustion practices as control technologies for minimizing NOx emissions from boilers less than 10 MMBtu/hr.  Step 2—Eliminate Technically Infeasible Options. Not applicable as all identified control technologies are technically feasible.  Step 3—Eliminate Economically/Chronologically Infeasible Options. Not applicable because all potential technologies identified in Step 1 are selected as RACT.  Step 4—Identify RACT. The technologies identified in the RBLC and CARB for controlling NOx emissions from the boilers of LNBs, use of pipeline-quality natural gas, and good combustion practices are already in use and constitute RACT. 3.1.9.2 VOC RACT  Step 1—Identify All Control Technologies. The RBLC and CARB identify use of pipeline-quality natural gas and good combustion practices as a control technology for minimizing VOC emissions from the boilers.  Step 2—Eliminate Technically Infeasible Options. Not applicable as all identified control technologies are technically feasible.  Step 3—Eliminate Economically/Chronologically Infeasible Options. Not applicable because all potential technologies identified in Step 1 are selected as RACT.  Step 4—Identify RACT. The RBLC identifies use of pipeline-quality natural gas and good combustion practices as a means of controlling VOC emissions from the boilers and these control technologies constitute RACT. Ozone State Implementation Plan: Reasonably Available Control Technology Determinations for Kennecott Utah Copper 231005163008_7a16d74e 3-12 3.1.10 Acid Plant Preheater The acid plant preheater burner is rated at 70 MMBtu/hr and operates on pipeline-quality natural gas. 3.1.10.1 NOx RACT  Step 1—Identify All Control Technologies. The RBLC and CARB identify use of pipeline-quality natural gas and good combustion practices as control technologies for minimizing NOx emissions from heaters.  Step 2—Eliminate Technically Infeasible Options. Not applicable as all identified control technologies are technically feasible.  Step 3—Eliminate Economically/Chronologically Infeasible Options. Not applicable because all potential technologies identified in Step 1 are selected as RACT.  Step 4—Identify RACT. The technologies identified in the RBLC for controlling NOx emissions from heaters of use of pipeline-quality natural gas and good combustion practices are already in use and constitute RACT. 3.1.10.2 VOC RACT  Step 1—Identify All Control Technologies. The RBLC and CARB identify the use of pipeline-quality natural gas and good combustion practices as control technology for minimizing VOC emissions from heaters.  Step 2—Eliminate Technically Infeasible Options. Not applicable as all identified control technologies are technically feasible.  Step 3—Eliminate Economically/Chronologically Infeasible Options. Not applicable because all potential technologies identified in Step 1 are selected as RACT. Step 4—Identify RACT. The RBLC identifies use of pipeline-quality natural gas and good combustion practices as a means of controlling VOC emissions from heaters and these control technologies constitute RACT. 3.2 Refinery 3.2.1 Tankhouse Boiler Source Description: Historically, the Refinery had two boilers rated at 82 MMBtu/hr (gas) and 79 MMBtu/hr (oil) each to operate on natural gas and meet the steam demand at the Refinery. In 2020, one of the boilers was decommissioned. The second boiler was upgraded with new generation LNBs, capable of meeting a NOx emission rate of 9 ppmvd at 3 percent oxygen. Emissions of VOCs are limited with good combustion practices and primary use of pipeline-quality natural gas. 3.2.1.1 NOx RACT  Step 1—Identify All Control Technologies. The RBLC and CARB identifies the following as possible control technologies for NOx for natural gas-fired boilers: - SCR - FGR - LNB with good combustion practices - Good design and proper operation  Step 2—Eliminate Technically Infeasible Options. Not applicable because all control technologies are technically feasible. Ozone State Implementation Plan: Reasonably Available Control Technology Determinations for Kennecott Utah Copper 231005163008_7a16d74e 3-13  Step 3—Eliminate Economically/Chronologically Infeasible Options. The Refinery boiler is equipped with LNB to reduce NOx emissions and is capable of achieving a NOx emission rate of 9 ppmvd at 3 percent oxygen. UDAQ recently proposed UAC R307-316 that establishes NOx emission limit of 9 ppmvd for boilers. Because UDAQ considers this proposed rule to be reflective of the BACT, an economical and chronological review of above-mentioned control technologies is not required.  Step 4—Identify RACT. LNB, good combustion practices, and primary use of pipeline-quality natural gas constitute RACT for this source. 3.2.1.2 VOC RACT  Step 1—Identify All Control Technologies. The RBLC and CARB identifies the use of pipeline- quality natural gas and good combustion practices as possible control technologies for natural gas- fired boilers.  Step 2—Eliminate Technically Infeasible Options. Not applicable as all identified control technologies are technically feasible.  Step 3—Eliminate Economically/Chronologically Infeasible Options. Not applicable because all potential technologies identified in Step 1 are selected as RACT.  Step 4—Identify RACT. Use of pipeline-quality natural gas and good combustion practices constitute RACT for this emission source. 3.2.2 CHP Unit Source Description: The CHP unit generates power and steam to support Refinery operations. The CHP unit uses a low-NOx duct burner and the turbine has SoLoNOx burners. Emissions of PM2.5, SO2, and VOC are limited with good design and proper operation. 3.2.2.1 NOx RACT  Step 1—Identify All Control Technologies. The RBLC and CARB databases identify the following as possible control technologies for NOx for natural gas-fired turbines and duct burners: - SCR - LNB with good combustion practices - Good design and proper operation  Step 2—Eliminate Technically Infeasible Options. Not applicable as all identified control technologies are technically feasible.  Step 3—Eliminate Economically/Chronologically Infeasible Options. The CHP unit is equipped with LNB (SoLoNOx technology burners on turbine) to reduce NOx emissions. The addition of the SCR will reduce emissions by 90 percent. Solar Turbines, Inc. developed an estimation spreadsheet for the Taurus 70 combustion turbine and duct burner arrangement, which utilized vendor quotations for the installation of an SCR system. From the Solar calculations, the annualized capital and operating costs were estimated to be $932,100 per year in 2013. Based on the annualized costs for the SCR and the 2018 actual emissions for the emission source, the cost of additional control per ton of NOx removed is $165,707 for the CHP unit and is therefore not cost effective for RACT.  Step 4—Identify RACT. LNBs with good combustion practices, good design, and proper operation of the CHP Unit constitute RACT for this source. Ozone State Implementation Plan: Reasonably Available Control Technology Determinations for Kennecott Utah Copper 231005163008_7a16d74e 3-14 3.2.2.2 VOC RACT  Step 1—Identify All Control Technologies. The RBLC and CARB databases identify the use of pipeline- quality natural gas and good combustion practices as possible control technologies for small turbines and duct burners  Step 2—Eliminate Technically Infeasible Options. Not applicable as all identified control technologies are technically feasible.  Step 3—Eliminate Economically/Chronologically Infeasible Options. Not applicable because all potential technologies identified in Step 1 are selected as RACT.  Step 4—Identify RACT. Use of pipeline-quality natural gas and good combustion practices constitute RACT for this emission source. LNB with good combustion practices, good design, and proper operation on pipeline-quality natural gas also represent the most stringent measure for the CHP unit. 3.2.3 Propane Communication Generator Source Description: The Refinery operates a propane-fired communication generator. This generator is used to support communication systems during emergencies or loss of power at the Refinery. Emissions are controlled with good combustion practices while operating the generator.  Step 1—Identify All Control Technologies. The RBLC and CARB identify good combustion practices as the primary control technology for emergency generators around 75 HP operated on propane. The emergency generators must also comply with the applicable New Source Performance Standards established by EPA.  Step 2—Eliminate Technically Infeasible Options. Not applicable as all identified control technologies are technically feasible.  Step 3—Eliminate Economically/Chronologically Infeasible Options. Not applicable because all potential technologies are feasible.  Step 4—Identify RACT. Good combustion practices are identified as RACT for the propane-fired emergency generator. The emergency generator also complies with applicable New Source Performance Standards. 3.2.4 Gasoline Fueling Stations Source Description: Adding gasoline to storage tanks and dispensing from the storage tanks into vehicles. The fueling operation is equipped with Stage 1 and Stage 2 vapor recovery systems.  Step 1—Identify All Control Technologies. The RBLC and CARB identify two control techniques for controlling VOC emissions from gasoline fueling operations. They are Stage 1 and Stage 2 vapor recovery systems.  Step 2—Eliminate Technically Infeasible Options. Not applicable as all identified control technologies are technically feasible.  Step 3—Eliminate Economically/Chronologically Infeasible Options. Not applicable because all potential technologies identified in Step 1 are selected as RACT.  Step 4—Identify RACT. Stage 1 and 2 vapor recovery constitutes RACT for these sources. 3.2.5 Space Heaters Source Description: Natural gas-fired heaters are used throughout the Refinery. The individual heaters are rated at less than 5 MMBtu/hr each. The heaters are regularly inspected for optimum combustion performance. Ozone State Implementation Plan: Reasonably Available Control Technology Determinations for Kennecott Utah Copper 231005163008_7a16d74e 3-15 3.2.5.1 NOx RACT  Step 1—Identify All Control Technologies. The RBLC and CARB identify good combustion practices and use of pipeline-quality natural gas as control technologies for minimizing NOx emissions from heaters less than 5 MMBtu/hr.  Step 2—Eliminate Technically Infeasible Options. Not applicable as all identified control technologies are technically feasible.  Step 3—Eliminate Economically/Chronologically Infeasible Options. Not applicable because all potential technologies identified in Step 1 are selected as RACT. As discussed in the RACT analysis for other KUC facilities, replacing the existing space heaters with new heaters is not cost effective for the RACT analysis.  Step 4—Identify RACT. The technologies identified in the RBLC and CARB for controlling NOx emissions from heaters of good combustion practices and use of pipeline-quality natural gas are already in use and constitute RACT. 3.2.5.2 VOC RACT  Step 1—Identify All Control Technologies. The RBLC and CARB identify use of pipeline-quality natural gas and good combustion practices as a control technology for minimizing VOC emissions from heaters.  Step 2—Eliminate Technically Infeasible Options. Not applicable as all identified control technologies are technically feasible.  Step 3—Eliminate Economically/Chronologically Infeasible Options. Not applicable because all potential technologies identified in Step 1 are selected as RACT.  Step 4—Identify RACT. The RBLC and CARB identifies use of pipeline-quality natural gas and good combustion practices as a means of controlling VOC emissions from heaters and these control technologies constitute RACT. 3.2.6 Diesel Emergency Generator Source Description: The Refinery operates one 487-HP diesel-fired emergency generator to support the precious metals plant at the Refinery during emergencies. The emergency generator complies with applicable New Source Performance Standards to minimize emissions.  Step 1—Identify All Control Technologies. Potential emission control technologies identified in the RBLC and CARB for similar-sized diesel generators include good combustion practices and limiting the sulfur content of fuel to 0.0015 percent. Certification and compliance with applicable New Source Performance Standards are acceptable means of demonstrating RACT for emergency generators.  Step 2—Eliminate Technically Infeasible Options. Not applicable as all identified control technologies are technically feasible.  Step 3—Eliminate Economically/Chronologically Infeasible Options. Not applicable because all potential technologies identified in Step 1 are selected as RACT.  Step 4—Identify RACT. Good combustion practices, limiting the sulfur content of fuel to 0.0015 percent and complying with applicable New Source Performance Standards requirements, are identified as RACT for all pollutants emitted from the emergency generator. 3.2.7 Paint and Primer Use Source Description: Small quantities of paints and primers are used at the Refinery to support miscellaneous building and architectural work. Good housekeeping practices are implemented to minimize emissions. Ozone State Implementation Plan: Reasonably Available Control Technology Determinations for Kennecott Utah Copper 231005163008_7a16d74e 3-16  Step 1—Identify All Control Technologies. The RBLC and CARB identifies use of low-VOC-content paints and primers and good housekeeping practices (for example, closing the container lids, minimizing spills, storing in closed containers) as methods to control/minimize VOC emissions.  Step 2—Eliminate Technically Infeasible Options. Not applicable as the identified control technologies are technically feasible.  Step 3—Eliminate Economically/Chronologically Infeasible Options. Not applicable because all potential technologies identified in Step 1 are selected as RACT. Step 4—Identify RACT. Good housekeeping practices such as closing the container lids, minimizing spills, and storing paints and primers in closed containers are implemented to control/minimize VOC emissions. Additionally, KUC uses low-VOC-content paints and primers. These practices constitute RACT for the emission source. Appendix A Cost Information Cost Effectiveness Calculations - Tioga Heaters 1/13/2023 Pollutant: NOx Table 1. Capital Cost Estimate Cost Reference Purchased Equipment Total Purchased Equipment Cost B $842,748 Vendor Direct Installation Cost Foundation and supports .08B $67,420 EPA Erection and handling .14B $117,985 EPA Electrical .04B $33,710 EPA Piping .02B $16,855 EPA Painting .01B $8,427 EPA Insulation .01B $8,427 EPA Building and site preparation not included Total Direct Installation Cost $252,824 Total Direct Cost $1,095,572 Indirect Cost Engineering 0.10B $84,275 EPA Construction and field expenses 0.05B $42,137 EPA Construction fee 0.10B $84,275 EPA Start-up 0.02B $16,855 EPA Performance test 0.01B $8,427 EPA Contingency 0.10B $84,275 KUC Total Indirect Cost $320,244 Total Capital Cost $1,415,817 Table 2. Annual Cost Annual Cost Reference Direct Costs Annual Operating Costs $50,000 Estimate Total Direct Cost $50,000 Indirect Costs Other Included in Annual Operating Costs Total Annual Costs Excluding Capital Recovery $50,000 Capital recovery $166,301 Interest 10.0%KUC Lifetime 20 years UDAQ Total Annual Cost $216,301 Table 3. Cost Effectiveness 2017 Actual Emissions 0.63 Control Efficiency 90%Estimate Emission Reduction 0.57 tons/year Cost Effectiveness $382,699 $/ton Notes: Applied inflation increase from 2017 to Dec 2022 (https://www.bls.gov/data/inflation_calculator.htm). Cost Information for BACT Analysis Annualized Cost PTE NOX Control efficiency tons removed Cost/ton Refinery CHP Unit 932,100$ 6.25 90 5.625 165,707$ Notes: (1) Cost information obtained from CHP vendor. (2) Control efficiency for SCR estimated to be 90%. (3) Economic analysis based on PTE emissions Cost Effectiveness Calculations - SCR for Anode Furnace and Shaft Furnace 1/27/2023 Table 1. Capital Cost Estimate Cost Reference Purchased Equipment Total Purchased Equipment Cost B Direct Installation Cost Foundation and supports .08B Included in capital costs Erection and handling .14B Included in capital costs Electrical .04B Included in capital costs Piping .02B Included in capital costs Painting .01B Included in capital costs Insulation .01B Included in capital costs Spare Parts .07B Included in capital costs Sales Taxes .07B Included in capital costs Building and site preparation not included Total Direct Installation Cost $0 Total Direct Cost $0 Indirect Cost Engineering 0.10B Included in capital costs Construction and field expenses 0.05B Included in capital costs Construction fee 0.10B Included in capital costs Start-up 0.02B Included in capital costs Performance test 0.01B Included in capital costs Contingency 0.10B $0 Total Indirect Cost $0 2009 Capital Cost $6,548,000 2009 CH2M HILL Study Total Capital Cost $9,204,316 Adjusted for cumulative inflation from 2009 to 2022 (https://www.bls.gov/data/inflation_calculat or.htm) Table 2. Annual Cost Annual Cost Reference Direct Costs Annual Operating Costs $806,850 2009 CH2M HILL Study Total Direct Cost $806,850 Indirect Costs Other Included in Annual Operating Costs Total Annual Costs Excluding Capital Recovery $806,850 Capital recovery $1,497,960 Interest 10.0%KUC Lifetime 10 years UDAQ Total Annual Cost $2,304,810 Table 3. Cost Effectiveness Current NOX Emissions 30 ppm Estimated based on monitoring data Expected NOX Emissions 5 ppm 2009 CH2M HILL Study Reduction In NOX Emissions 83%Calculated 2018 Emissions 54.33 tons/year Estimated based on monitoring data Control Efficiency 83%Calculated Emission Reduction 45.28 tons/year Calculated Cost Effectiveness $50,907 $/ton Cost Effectiveness Calculations - Low Temperature SCR for Anode Furnace and Shaft Furnace 1/27/2023 Table 1. Capital Cost Estimate Cost Reference Purchased Equipment Total Purchased Equipment Cost B Direct Installation Cost Foundation and supports .08B Included in capital costs Erection and handling .14B Included in capital costs Electrical .04B Included in capital costs Piping .02B Included in capital costs Painting .01B Included in capital costs Insulation .01B Included in capital costs Spare Parts .07B Included in capital costs Sales Taxes .07B Included in capital costs Building and site preparation not included Total Direct Installation Cost $0 Total Direct Cost $0 Indirect Cost Engineering 0.10B Included in capital costs Construction and field expenses 0.05B Included in capital costs Construction fee 0.10B Included in capital costs Start-up 0.02B Included in capital costs Performance test 0.01B Included in capital costs Contingency 0.10B $0 Total Indirect Cost $0 2009 Capital Cost $6,985,000 2009 CH2M HILL Study Total Capital Cost $9,818,592 Adjusted for cumulative inflation from 2009 to 2022 (https://www.bls.gov/data/inflation_calculat or.htm) Table 2. Annual Cost Annual Cost Reference Direct Costs Annual Operating Costs $424,168 2009 CH2M HILL Study Total Direct Cost $424,168 Indirect Costs Other Included in Annual Operating Costs Total Annual Costs Excluding Capital Recovery $424,168 Capital recovery $1,597,931 Interest 10.0%KUC Lifetime 10 years UDAQ Total Annual Cost $2,022,099 Table 3. Cost Effectiveness Current NOX Emissions 30 ppm Estimated based on monitoring data Expected NOX Emissions 5 ppm 2009 CH2M HILL Study Reduction In NOX Emissions 83%Calculated 2018 Emissions 54.33 tons/year Estimated based on monitoring data Control Efficiency 83%Calculated Emission Reduction 45.28 tons/year Calculated Cost Effectiveness $44,663 $/ton Cost Effectiveness Calculations - Low Temperature Oxidation System for Anode Furnace and Shaft Furnace 1/27/2023 Table 1. Capital Cost Estimate Cost Reference Purchased Equipment Total Purchased Equipment Cost B Direct Installation Cost Foundation and supports .08B Included in capital costs Erection and handling .14B Included in capital costs Electrical .04B Included in capital costs Piping .02B Included in capital costs Painting .01B Included in capital costs Insulation .01B Included in capital costs Spare Parts .07B Included in capital costs Sales Taxes .07B Included in capital costs Building and site preparation not included Total Direct Installation Cost $0 Total Direct Cost $0 Indirect Cost Engineering 0.10B Included in capital costs Construction and field expenses 0.05B Included in capital costs Construction fee 0.10B Included in capital costs Start-up 0.02B Included in capital costs Performance test 0.01B Included in capital costs Contingency 0.10B $0 Total Indirect Cost $0 2009 Capital Cost $11,158,000 2009 CH2M HILL Study Total Capital Cost $15,732,780 Adjusted for cumulative inflation from 2009 to 2022 (https://www.bls.gov/data/inflation_calculat or.htm) Table 2. Annual Cost Annual Cost Reference Direct Costs Annual Operating Costs $1,280,891 2009 CH2M HILL Study Total Direct Cost $1,280,891 Indirect Costs Other Included in Annual Operating Costs Total Annual Costs Excluding Capital Recovery $1,280,891 Capital recovery $2,560,437 Interest 10.0%KUC Lifetime 10 years UDAQ Total Annual Cost $3,841,328 Table 3. Cost Effectiveness Current NOX Emissions 30 ppm Estimated based on monitoring data Expected NOX Emissions 5 ppm 2009 CH2M HILL Study Reduction In NOX Emissions 83%Calculated 2018 Emissions 54.33 tons/year Estimated based on monitoring data Control Efficiency 83%Calculated Emission Reduction 45.28 tons/year Calculated Cost Effectiveness $84,844 $/ton Cost Effectiveness Calculations - Wet Scrubber System for Anode Furnace and Shaft Furnace 1/27/2023 Table 1. Capital Cost Estimate Cost Reference Purchased Equipment Total Purchased Equipment Cost B Direct Installation Cost Foundation and supports .08B Included in capital costs Erection and handling .14B Included in capital costs Electrical .04B Included in capital costs Piping .02B Included in capital costs Painting .01B Included in capital costs Insulation .01B Included in capital costs Spare Parts .07B Included in capital costs Sales Taxes .07B Included in capital costs Building and site preparation not included Total Direct Installation Cost $0 Total Direct Cost $0 Indirect Cost Engineering 0.10B Included in capital costs Construction and field expenses 0.05B Included in capital costs Construction fee 0.10B Included in capital costs Start-up 0.02B Included in capital costs Performance test 0.01B Included in capital costs Contingency 0.10B $0 Total Indirect Cost $0 2009 Capital Cost $11,211,000 2009 CH2M HILL Study Total Capital Cost $15,807,510 Adjusted for cumulative inflation from 2009 to 2022 (https://www.bls.gov/data/inflation_calculat or.htm) Table 2. Annual Cost Annual Cost Reference Direct Costs Annual Operating Costs $2,592,896 2009 CH2M HILL Study Total Direct Cost $2,592,896 Indirect Costs Other Included in Annual Operating Costs Total Annual Costs Excluding Capital Recovery $2,592,896 Capital recovery $2,572,599 Interest 10.0%KUC Lifetime 10 years UDAQ Total Annual Cost $5,165,495 Table 3. Cost Effectiveness Current NOX Emissions 30 ppm Estimated based on monitoring data Expected NOX Emissions 5 ppm 2009 CH2M HILL Study Reduction In NOX Emissions 83%Calculated 2018 Emissions 54.33 tons/year Estimated based on monitoring data Control Efficiency 83%Calculated Emission Reduction 45.28 tons/year Calculated Cost Effectiveness $114,092 $/ton Appendix B RBLC and CARB Search Documentation Ozone State Implementation Plan: Reasonably Available Control Technology Determinations for Kennecott Utah Copper 231005163008_7a16d74e B-1 RBLC and CARB Search Documentation KUC Smelter, Refinery, Copperton Concentrator, and Bingham Canyon Mine Search Terms Search Results Relevance to KUC Sources Permit Date KUC Unit Description Start Date End Date Process Type (#) Pollutant Name Like (if applicable) RBLC or CARB? RBLC/CARB ID Process Desc Permit # Permit Date Emission Limit, Throughput, Control Information Basis (RACT, BACT, LAER) Comments Boilers/Heaters 10-100 MMBtu 1/1/2013 8/7/2023 13.310 NOx RBLC IN-0359 Boiler (CC-Boil) 107-45480- 0038 3/30/2023 0.0350 lb/MMBtu, 50 MMBtu/hr, low-NOx burner BACT All boilers and heaters at KUC use LNBs with good combustion practices (GCP), good design, proper operation, and pipeline-quality natural gas (NG); the Holman and Rentech boilers use FGR as well to control NOx emissions Boilers/Heaters 10-100 MMBtu 1/1/2013 8/7/2023 13.310 NOx RBLC MI-0451 EUAUXBOILER (North Plant) 167-17B 6/23/2022 0.0400 lb/MMBtu (30 day roll), 61.5 MMBtu/hr, LNB/FGR/GCP BACT Boilers/Heaters 10-100 MMBtu 1/1/2013 8/7/2023 13.310 NOx RBLC MI-0454 EUAUXBOILER 74-18D 12/20/2022 30 ppm @ 3% O2 hourly, 50 MMBtu/hr, LNB/FGR BACT Boilers/Heaters 10-100 MMBtu 1/1/2013 8/7/2023 13.310 NOx RBLC OH-0387 29.4 MMBtu/hr Natural Gas-Fired Boilers:B001 through B028 PO132323 9/20/2022 0.0110 lb/MMBtu (9.74 tpy), 29.4 MMBtu/hr, ULNB/GCP/Nat gas BACT Boilers/Heaters 10-100 MMBtu 1/1/2013 8/7/2023 13.310 VOC RBLC OH-0387 29.4 MMBtu/hr Natural Gas-Fired Boilers:B001 through B028 PO132323 9/20/2022 0.0050 lb/MMBtu (4.86 tpy), 29.4 MMBtu/hr, GCP/Nat gas BACT All boilers and heaters at KUC use LNBs with good combustion practices and pipeline-quality NG to control VOC emissions Boilers/Heaters 10-100 MMBtu 1/1/2013 8/7/2023 13.310 VOC RBLC TX-0939 Water Bath Heater 166032 PSDTX1598 3/13/2023 0.0050 lb/MMBtu, 16.80 MMBtu/hr, GCP BACT Boilers/Heaters 10-100 MMBtu 1/1/2013 8/7/2023 13.310 VOC RBLC MI-0451 EUAUXBOILER (North Plant) 167-17B 6/23/2022 0.0040 lb/MMBtu, 61.5 MMBtu/hr, LNB, FGR, GCP BACT Boilers/Heaters 10-100 MMBtu 1/1/2013 8/7/2023 13.310 VOC RBLC IN-0359 Boiler (CC-Boil) 107-45480- 0038 3/30/2023 0.0054 lb/MMBtu, 50 MMBtu/hr, GCP and nat gas BACT Boilers/Heaters 10-100 MMBtu 1/1/2013 2/5/2021 Boiler NOx CARB **887 39.9 MMBtu watertube boiler 6/18/2015 5 ppmvd @3% O2, low-NOx burner/SCR BACT District ID 552449 Boilers/Heaters <10 MMBtu 1/1/2013 8/7/2023 13.310 NOx RBLC IN-0359 Hot Water Circuit Burner for Sheet Metal Coating Line 107-45480- 0038 3/30/2023 50 lb/mmscf, 5.12 MMBtu/hr, low-NOx burner/GCP/nat Gas BACT Water heaters and small heaters at KUC are <10 MMBtu and use LNBs, GCP, NG, and regular inspections to control NOx emissions Boilers/Heaters <10 MMBtu 1/1/2013 8/7/2023 13.310 NOx RBLC AL-0329 Three Gas Heaters 701-0010 9/21/2021 0.0110 lb/MMBtu, 10 MMBtu/hr, GCP/Nat Gas BACT Boilers/Heaters <10 MMBtu 1/1/2013 8/7/2023 13.310 NOx RBLC MI-0442 FGPRHEAT 210-18 8/21/2019 0.036 lb/MMBtu, 7.0 MMBtu/hr, low-NOx / GCP BACT Boilers/Heaters <10 MMBtu 1/1/2013 8/7/2023 13.310 NOx RBLC MI-0435 EUFUELHTR2 19-18 7/16/2018 0.140 lb/hr, 3.8 MMBtu/hr, low-NOx burner BACT Boilers/Heaters <10 MMBtu 1/1/2013 8/7/2023 13.310 VOC RBLC IN-0359 Hot Water Circuit Burner for Sheet Metal Coating Line 107-45480- 0038 3/30/2023 5.5 lb/mmscf, 5.12 MMBtu/hr, low-NOx burner/GCP/nat Gas BACT Water heaters at KUC are <10 MMBtu and use pipeline-quality NG, GCP, and regular inspections to control VOC emissions Boilers/Heaters <10 MMBtu 1/1/2013 8/7/2023 13.310 VOC RBLC WI-0297 Natural gas-fired space heaters 19-DMM-129 12/10/2019 0.0055 lb/MMBtu, <8.5 MMBtu/hr, GCP/Nat Gas BACT Boilers/Heaters <10 MMBtu 1/1/2013 8/7/2023 13.310 VOC RBLC MI-0442 FGPRHEAT 210-18 8/21/2019 0.025 lb/MMBtu, 7.0 MMBtu/hr, GCP BACT Boilers/Heaters <10 MMBtu 1/1/2013 8/7/2023 13.310 VOC RBLC MI-0435 EUFUELHTR2 19-18 7/16/2018 0.030 lb/hr, 3.8 MMBtu/hr, GCP BACT Refinery CHP Unit 1/1/2013 8/7/2023 16.210 NOx RBLC AK-0086 5 Nat Gas-Fired Combustion Turbines AQ0083CPT07 3/26/2021 5.0 PPMV @ 15% O2, 102.1 MMBtu/hr, SCR/SoLoNOx BACT The KUC CHP unit uses a low-NOx duct burner and the turbine has SoLoNOx burners; this, coupled with good design and proper operation limit NOx emissions Refinery CHP Unit 1/1/2013 8/7/2023 16.210 NOx RBLC LA-0375 Generator Turbines PSD-LA-703 (M8) 9/17/2020 150 PPM @ 15% O2 and < 75% load, dry low-NOx /GCP BACT Refinery CHP Unit 1/1/2013 8/7/2023 16.210 NOx RBLC MA-0043 Combustion Turbine with Duct Burner NE-15-018 6/21/2021 2.0000 PPMVD@15%O2(1 hr block nat gas)/6.8000PPMVD@15%O2(1hr block ULSD), dry low- NOx /SCR BACT CT w/ HRSG and Duct firing Ozone State Implementation Plan: Reasonably Available Control Technology Determinations for Kennecott Utah Copper 231005163008_7a16d74e B-2 Search Terms Search Results Relevance to KUC Sources Permit Date KUC Unit Description Start Date End Date Process Type (#) Pollutant Name Like (if applicable) RBLC or CARB? RBLC/CARB ID Process Desc Permit # Permit Date Emission Limit, Throughput, Control Information Basis (RACT, BACT, LAER) Comments Refinery CHP Unit 1/1/2013 8/7/2023 16.210 NOx RBLC LA-0295 Solar Titan 130 Gas Turbine with Unfired HRSG PSD-LA-806 7/12/2016 14.250 lb/hr/15.0000 PPMVD@15%O2 (annual avg), 159.46 MMBtu/hr/14.117MW, dry low-NOx /GCP BACT Refinery CHP Unit 1/1/2013 8/7/2023 16.210 VOC RBLC AK-0086 5 Nat Gas-Fired Combustion Turbines AQ0083CPT07 3/26/2021 0.0036 lb/MMBtu (3hr avg), 102.1 MMBtu/hr, GCP BACT The KUC CHP unit uses a low- NOx duct burner, coupled with good design and proper operation on pipeline-quality natural gas limit VOC emissions Refinery CHP Unit 1/1/2013 8/7/2023 16.210 VOC RBLC MA-0043 Combustion Turbine with Duct Burner NE-15-018 6/21/2021 1.7000 PPMVD@15%O2(1hr block nat gas)/6.5000PPMVD@15%O2(1hr block ULSD), Oxidation Catalyst BACT CT w/ HRSG and Duct firing Refinery CHP Unit 1/1/2013 8/7/2023 16.210 VOC RBLC LA-0295 Solar Titan 130 Gas Turbine with Unfired HRSG PSD-LA-806 7/12/2016 1.6400 lb/hr/2.5000 PPMVD@15%O2 (annual avg), 159.46 MMBtu/hr/14.117MW, GCP BACT Refinery CHP Unit 1/1/2013 8/7/2023 16.210 VOC RBLC TX-0704 cogeneration turbine 108819 PSDTX1354 12/2/2014 4.0000PPMVD@15%O2 (24 hr roll), 49.0 MW, oxidation catalyst BACT Propane Generators 1/1/2013 8/22/2023 17.230 NOx RBLC VA-0325 PROPANE-FIRED EMERGENCY GENERATORS 150 kW (2) 52525 6/17/2016 2 G/HP-HR; Good combustion practices, maintenance BACT 70-150 HP propane-fired emergency generators use GCP as RACT for NOx and VOC, along with compliance with NSPS standards. Propane Generators 1/1/2013 8/7/2023 17.230 NOx RBLC LA-0389 2P-18E - Emergency Combustion Equipment E PSD-LA-817 10/20/2022 10.52 lb/hr/6.4 g/kw-hr, 268 HP, IIII compliance w/ NMHC+ NOx BACT Propane Generators 1/1/2013 8/7/2023 17.230 NOx RBLC IL-0132 Emergency Engine Generators 19120024 1/25/2021 1.0 g/hp-hr, complaint with JJJJ BACT Propane Generators 1/1/2013 8/7/2023 17.230 NOx RBLC IN-0312 spark ignition engine 093-40198- 00002 6/27/2019 2.000 g/hp-hr, 750 kW, GCP BACT Propane Generators 1/1/2013 8/22/2023 17.230 VOC RBLC VA-0325 PROPANE-FIRED EMERGENCY GENERATORS 150 kW (2) 52525 6/17/2016 1 G/HP-HR; Good combustion practices BACT Propane Generators 1/1/2013 8/7/2023 17.230 VOC RBLC LA-0389 2P-18E - Emergency Combustion Equipment E PSD-LA-817 10/20/2022 0.75 lb/hr/6.4 g/kw-hr, 268 HP, IIII compliance w/ NMHC + NOx BACT Propane Generators 1/1/2013 8/7/2023 17.230 VOC RBLC IL-0132 Emergency Engine Generators 19120024 1/25/2021 0.7000 g/hp-hr, compliant with JJJJ BACT Propane Generators 1/1/2013 8/7/2023 17.230 VOC RBLC IN-0312 spark ignition engine 093-40198- 00002 6/27/2019 1.000 g/hp-hr, 750 kW, GCP BACT Diesel Generators 1/1/2013 8/7/2023 17.110 NOx RBLC IN-0359 Emergency Generator (CC-GEN1) 107-45480- 00038 3/30/2023 4.8000 g/hp-hr, 3000 HP, NSPS certified engine BACT 1000 HP diesel-fired emergency generator equipped with turbo-charger, after cooling; Both diesel emergency generators use GCP, sulfur content of fuel limited to no more than 15ppm, and compliance with NSPS standard to constitute RACT for NOx and VOCs Diesel Generators 1/1/2013 8/7/2023 17.110 NOx RBLC AR-0177 SN-230 Galv Lin No, 2 Emergency Generator 1139-AOP-R27 11/21/2022 5.6 g/kw-hr, 3634 HP, NSPS BACT Diesel Generators 1/1/2013 8/7/2023 17.110 NOx RBLC TX-0955 TIER III Engine 136130, N250M2 3/14/2023 3.9 g/hp-hr, Tier III NSPS LAER Diesel Generators 1/1/2013 8/7/2023 17.110 NOx RBLC MI-0454 EUEMGD 74-18D 12/20/2022 6.4000 g/kw-h, 2206 HP, GCP/NSPS compliant BACT Diesel Generators 1/1/2013 8/7/2023 17.110 VOC RBLC IN-0359 Emergency Generator (CC-GEN1) 107-45480- 00038 3/30/2023 0.3200 g/hp-hr, 3000 HP, certified engine BACT Diesel Generators 1/1/2013 8/7/2023 17.110 VOC RBLC AR-0177 SN-230 Galv Lin No, 2 Emergency Generator 1139-AOP-R27 11/21/2022 0.8000 g/kw-hr, 3634 HP BACT Diesel Generators 1/1/2013 8/7/2023 17.110 VOC RBLC TX-0939 EMERGENCY GENERATOR 166032 PSDTX1598 0./13/2023 0.0010 lb/hp-hr, 18.70 MMBtu/hr, GCP/limited to 100 hr/yr BACT Diesel Generators 1/1/2013 8/7/2023 17.110 VOC RBLC OH-0387 5,051 bhp Diesel-Fired Emergency Generator P0132323 9/20/2022 0.400 g/kw-hr/0.300 lb/hr, 5051 HP, certified tier 2/GCP BACT Diesel Generators 7/23/2004 2/5/2021 IC Engine - Stationary NOx CARB **13 IC Engine - Stationary: Backup/Emergency 5/16/2006 4.5 gr/bhp-hr, 2937 HP, Tier II Diesel Engine BACT Ozone State Implementation Plan: Reasonably Available Control Technology Determinations for Kennecott Utah Copper 231005163008_7a16d74e B-3 Search Terms Search Results Relevance to KUC Sources Permit Date KUC Unit Description Start Date End Date Process Type (#) Pollutant Name Like (if applicable) RBLC or CARB? RBLC/CARB ID Process Desc Permit # Permit Date Emission Limit, Throughput, Control Information Basis (RACT, BACT, LAER) Comments Diesel Generators 7/23/2004 2/5/2021 IC Engine - Stationary NOx CARB **164 IC Engine - Stationary: Limited Use 7/23/2004 50 ppmvd @ 15% O2, 2835 HP, Diesel Particulate Filters, Selective Catalytic Reduction (SCR) BACT Diesel Generators 7/23/2004 2/5/2021 IC Engine - Stationary VOC CARB **164 IC Engine - Stationary: Limited Use 7/23/2004 0.15 gr/bhp-hr, 2835 HP, Diesel Particulate Filters, Selective Catalytic Reduction (SCR) BACT Diesel Generators 7/23/2004 2/5/2021 IC Engine - Stationary VOC CARB **164 IC Engine - Stationary: Limited Use 7/23/2004 39 ppmvd @ 15% O2, 2835 HP, Diesel Particulate Filters, Selective Catalytic Reduction (SCR) BACT Diesel Generators 7/23/2004 2/5/2021 IC Engine - Stationary NOx+VOC CARB **210 IC Engine - Stationary: Backup/Emergency 6/29/2011 3 gr/bhp/hr, 374 HP, Diesel Particulate Filters BACT Diesel Generators 7/23/2004 2/5/2021 IC Engine - Stationary NOx+VOC CARB **211 IC Engine - Stationary: Backup/Emergency 11/15/2011 4.8 gr/bhp-hr, 2220 HP, Diesel Particulate Filters BACT Diesel Generators 7/23/2004 2/5/2021 IC Engine - Stationary NOx+VOC CARB **212 IC Engine - Stationary: Backup/Emergency 3/21/2014 4.8 gr/bhp-hr, 755 HP, Diesel Particulate Filters BACT Diesel Generators 7/23/2004 2/5/2021 IC Engine - Stationary NOx CARB **883 IC Engine - Stationary: Backup/Emergency 9/29/2010 3 gr/bhp-hr, 183 HP, Tier III Diesel Engine BACT Degreasers 1/1/2013 8/7/2023 49.008 VOC MI-0449 EUPURGECLEANWEST 13-19B 6/23/2021 69.3 tpy (12-month roll), High-efficiency application, low-VOC materials, RTO (95% destruction efficiency), solvent recovery system LEAR At KUC, lids are kept closed to minimize emissions when not in use Degreasers 1/1/2013 8/7/2023 49.008 VOC KY-0115 Cold Mill Complex Cleaning Tank V-20-015 4/19/2021 0.032 TYP (12-month roll), cover, operational requirements to minimize evap losses BACT Degreasers 1/1/2013 8/7/2023 49.008 VOC IL-0127 Plate Making System, Parts Cleaner, Solvent Recovery System 14040006 10/5/2018 98% control efficiency rolling 3-hour avg, Permanent total enclosure, RTO, Work Practices BACT Degreasers 1/1/2013 8/7/2023 49.008 VOC IN-0337 Solvent Cleaning/ Purge Capture System 051-39315- 00037 7/12/2018 27.9 ton 12-month period, good operating practices BACT Smelter Processes 1/1/2010 8/7/2023 82.420 VOC IN-0125 REVERBERATORY FURNACE 003-30250- 00384 9/30/2011 1.0 lb/ton copper entire process operating cycle, RTO Other Case-by- case KUC's Smelter is a MACT source Smelter Processes 1/1/2010 8/7/2023 82.410 NOx: No RBLC entries found. Fueling 1/1/2013 8/7/2023 42.002 VOC IN-0244 LOADING RACK 103-35351- 00011 12/3/2016 35.0 mg/L/0.014 lb/kgal diesel/0.16 lb/kgal kerosene, relief stack/vapor knockout box/flare vapor control unit Other Case-by- case (BACT) At KUC, Stage I and Stage 2 vapor recovery are used to control emissions from these sources Fueling 1/1/2013 8/7/2023 42.002 VOC IN-0243 LOADING RACK 129-34987- 00005 8/14/2015 0.159 lb/gal, vapor recovery unit (carbon adsorption) Other Case-by- case (BACT) Fueling 1/1/2013 8/7/2023 42.002 VOC IN-0231 TRUCK LOADING RACK 055-35558- 00003 6/30/2015 35.0 mg/L/0.014 lb/kgal diesel/0.16 lb/kgal kerosine Other Case-by- case Fueling 1/1/2013 8/7/2023 42.002 VOC NJ-0083 Light Products Loading Rack 18046/BOP1300 02 3/11/2014 0.420 lb/hr, vapor recovery unit LEAR Fueling 1/1/2013 8/7/2023 42.005 VOC KY-0116 EU 044-Diesel Fuel Storage and Refueling Station V-22-011 7/25/2022 Spill & Overfill protection, submerged fill pipes, good work practice plan BACT Paint/Primer Coating 1/1/2013 8/7/2023 41.013 VOC KY-109 Paint Booth #4 (EU71) V-16-022 R1 10/24/2016 3.5 lb/gal coating less water or exempt solvent or both, closed container storage, minimize risk of spills BACT At KUC, good housekeeping practices such as closing lids and minimizing spills are employed to minimize VOC emissions, along with the use of low VOC paints and primers Paint/Primer Coating 1/1/2013 8/7/2023 41.999 VOC WV-0030 Rockfon Glue and Paint Application R14-0037 4/30/2018 Low-VOC materials and utilization of GWP BACT Furnaces <100 MMBtu 1/1/2013 8/7/2023 13.310 NOx TX-0863 Furnace 153106 & N268 9/3/2019 0.034 lb/MMBtu (hourly)/0.020 lb/MMBtu (annual), 84.27 MMBtu/hr, ULNB/effluent gas recirculation BACT The furnaces have been specifically designed for the KUC Smelter and are Ozone State Implementation Plan: Reasonably Available Control Technology Determinations for Kennecott Utah Copper 231005163008_7a16d74e B-4 Search Terms Search Results Relevance to KUC Sources Permit Date KUC Unit Description Start Date End Date Process Type (#) Pollutant Name Like (if applicable) RBLC or CARB? RBLC/CARB ID Process Desc Permit # Permit Date Emission Limit, Throughput, Control Information Basis (RACT, BACT, LAER) Comments Furnaces <100 MMBtu 1/1/2013 8/7/2023 13.310 VOC TX-0863 Furnace 153106 & N268 9/3/2019 84.27 MMBtu/hr, control of VOC in vent gas from pellet hoppers, blenders, and silos monitored with FID LAER equipped with LNBs to minimize emissions. Furnaces referenced in the RBLC do not reflect those used in Smelting operations. Furnaces <100 MMBtu 1/1/2013 8/7/2023 13.310 NOx AR-0173 Hydrogen Plant #2 Reformer Furnace 2445-AOP-R0 1/31/2022 0.10 lb/MMBtu, 75 MMBtu/hr, LNB of clean fuel/GCP BACT Furnaces <100 MMBtu 1/1/2013 8/7/2023 13.310 VOC AR-0173 Hydrogen Plant #2 Reformer Furnace 2445-AOP-R0 1/31/2022 0.0054 lb/MMBtu, 75 MMBtu/hr, Nat Gas/GCP BACT Furnaces <100 MMBtu 1/1/2013 8/7/2023 13.310 NOx KY-0115 Galv Line #2 Preheat Furnace V-20-015 4/19/2021 7.5 lb/MMSCF (3-hr avg)/3.03 tpy (12-month roll), 94 MMBtu/hr, LNB/good combustion and operating practices/SCR BACT Furnaces <100 MMBtu 1/1/2013 8/7/2023 13.310 VOC KY-0115 Galv Line #2 Preheat Furnace V-20-015 4/19/2021 5.50 lb/MMSCF/2.22 tpy (12-month roll), 94 MMBtu/hr, GCP BACT Furnaces <50 MMBtu 1/1/2013 8/7/2023 13.310 NOx KY-0115 Galv Line #2 Radiant Tube Furnace V-20-015 4/19/2021 7.5 lb/MMSCF (3hr avg)/1.16 tpy, 36.0 MMBtu/hr, GCP/low- NOx/SCR or SNCR BACT Furnaces <50 MMBtu 1/1/2013 8/7/2023 13.310 VOC KY-0115 Galv Line #2 Radiant Tube Furnace V-20-015 4/19/2021 5.5 lb/MMSCF/0.85 tpy, 36.0 MMBtu/hr, GCP BACT Furnaces <50 MMBtu 1/1/2013 8/7/2023 13.310 NOx AR-0168 Decarburizing Line Furnace Section 2305-AOP-R7 3/17/2021 0.1 lb/MMBtu, 36MMBtu/hr and 22MMBtu/hr, low- NOx/SCR/GCP BACT Furnaces <50 MMBtu 1/1/2013 8/7/2023 13.310 VOC AR-0168 Decarburizing Line Furnace Section 2305-AOP-R7 3/17/2021 0.0054 lb/MMBtu, 36 MMBtu/hr and 22MMBtu/hr, Nat gas/GCP BACT Furnaces <50 MMBtu 1/1/2013 8/7/2023 13.310 NOx KY-0110 Tempering Furnace V-20-001 7/23/2020 70.0 lb/MMSCF/14.3 tpy, 48 MMBtu/hr, LNB/GCP BACT Other < 50 MMBtu furnaces in this entry, but this is the lowest NOx rate of under 50 MMBtu/ furnaces in this permit Furnaces <50 MMBtu 1/1/2013 8/7/2023 13.310 VOC KY-0110 Tempering Furnace V-20-001 7/23/2020 5.5 lb/MMSCF/1.13 tpy, 48 MMBtu/hr, GCP BACT Furnaces <50 MMBtu 7/23/2004 2/5/2021 NOx CARB Aluminum forging Furnace **560283 5/27/2014 30 ppmv @ 3% O2, 5.0 MMBtu/hr, low-NOx burner BACT CARB Appendix C Evaluation of KUC’s Applicability to U.S. Environmental Protection Agency Control Techniques Guidelines Ozone State Implementation Plan: Reasonably Available Control Technology Determinations for Kennecott Utah Copper 231005163008_7a16d74e C-1 Evaluation of KUC’s Applicability to U.S. Environmental Protection Agency Control Techniques Guidelines Pollutant Reference Description EPA Note Applicable Comment VOC EPA-450/R-75-102 Design Criteria for Stage I Vapor Control Systems – Gasoline Service Stations (PDF 15 pp, 766KB). Note – This document is regarded as a CTG although it was never published with an EPA document number. No While KUC does have a 10,000-gallon gasoline fuel tank at the Smelter, it does not have a commercial service station and therefore this is not applicable. VOC EPA-450/2-76-028 Control of Volatile Organic Emissions from Existing Stationary Sources – Volume I: Control Methods for Surface Coating Operations (PDF 174 pp, 4.6MB). Note – Although often listed with the CTGs for historical reasons, this document does not define RACT for any source. It is a compilation of control techniques. No Do not conduct this activity. VOC EPA-450/2-77-008 Control of Volatile Organic Emissions from Existing Stationary Sources – Volume II: Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles, and Light-Duty Trucks (PDF 232 pp, 2.7MB) No Do not conduct this activity. VOC EPA-450/2-77-022 Control of Volatile Organic Emissions from Solvent Metal Cleaning (PDF 229 pp, 7.0MB) No Do not conduct this activity. VOC EPA-450/2-77-025 Control of Refinery Vacuum Producing Systems, Wastewater Separators, and Process Unit Turnarounds (PDF 50 pp, 1.3MB) No Do not conduct this activity. VOC EPA-450/2-77-026 Control of Hydrocarbons from Tank Truck Gasoline Loading Terminals (PDF 62 pp, 1.6MB) No Do not conduct this activity. VOC EPA-450/2-77-032 Control of Volatile Organic Emissions from Existing Stationary Sources – Volume III: Surface Coating of Metal Furniture (PDF 66 pp, 1.9MB) No Do not conduct this activity. VOC EPA-450/2-77-033 Control of Volatile Organic Emissions from Existing Stationary Sources – Volume IV: Surface Coating of Insulation of Magnet Wire (PDF 44 pp, 1.1MB) No Do not conduct this activity. VOC EPA-450/2-77-034 Control of Volatile Organic Emissions from Existing Stationary Sources – Volume V: Surface Coating of Large Appliances (PDF 70 pp, 2.1MB) No Do not conduct this activity. VOC EPA-450/2-77-035 Control of Volatile Organic Emissions from Bulk Gasoline Plants (PDF 49 pp, 1.3MB) No Do not conduct this activity. VOC EPA-450/2-77-036 Control of Volatile Organic Emissions from Storage of Petroleum Liquids in Fixed-Roof Tanks (PDF 43 pp, 1.1MB) No Do not conduct this activity. VOC EPA-450/2-77-037 Control of Volatile Organic Emissions from Use of Cutback Asphalt (PDF 18 pp, 481KB) No Do not conduct this activity. VOC EPA-450/2-78-022 Control Techniques for Volatile Organic Emissions from Stationary Sources (PDF 580 pp, 21.9MB) Note – This document is often listed with CTGs, but it does not define RACT for any particular source Yes, however, KUC goes above and beyond cited CTGs This document covers control technologies for a wide variety of sources. However, only the incorporation of process changes to minimize emissions is relevant to KUC, and associated control technologies referenced include proper PM and good operating and housekeeping practices for ICE and external combustion units (boilers). Many boilers at KUC are also subject to NSPS. It is important to note that all ICE units at KUC are EPA certified under NSPS and ICE units at the BCM, Refinery, and Smelter are regulated under a NESHAP (40 CFR 63 ZZZZ). VOC EPA-450/2-78-015 Control of Volatile Organic Emissions from Existing Stationary Sources – Volume VI: Surface Coating of Miscellaneous Metal Parts and Products (PDF 82 pp, 2.6MB) No Do not conduct this activity. VOC EPA-450/2-78-032 Control of Volatile Organic Emissions from Existing Stationary Sources – Volume VII: Factory Surface Coating of Flat Wood Paneling (PDF 66 pp, 2.0MB) No Do not conduct this activity. VOC EPA-450/2-78-036 Control of Volatile Organic Compound Leaks from Petroleum Refinery Equipment (PDF 78 pp, 6.0MB) No Do not conduct this activity. VOC EPA-450/2-78-029 Control of Volatile Organic Emissions from Manufacture of Synthesized Pharmaceutical Products (PDF 134 pp, 3.8MB) No Do not conduct this activity. Ozone State Implementation Plan: Reasonably Available Control Technology Determinations for Kennecott Utah Copper 231005163008_7a16d74e C-2 Pollutant Reference Description EPA Note Applicable Comment VOC EPA-450/2-78-030 Control of Volatile Organic Emissions from Manufacture of Pneumatic Rubber Tires (PDF 72 pp, 1.6MB) No Do not conduct this activity. VOC EPA-450/2-78-033 Control of Volatile Organic Emissions from Existing Stationary Sources – Volume VIII: Graphic Arts-Rotogravure and Flexography (PDF 64 pp, 1.9MB) No Do not conduct this activity. VOC EPA-450/2-78-047 Control of Volatile Organic Emissions from Petroleum Liquid Storage in External Floating Roof Tanks (PDF 66 pp, 2.0MB) No Do not conduct this activity. VOC EPA-450/2-78-050 Control of Volatile Organic Emissions from Perchloroethylene Dry Cleaning Systems (PDF 76 pp, 2.5MB) Note – Perchloroethylene has been exempted as a VOC, so this CTG is no longer relevant. However, there is a MACT standard for perchloroethylene dry cleaners. No Do not conduct this activity. VOC EPA-450/2-78-051 Control of Volatile Organic Compound Leaks from Gasoline Tank Trucks and Vapor Collection Systems (PDF 32 pp, 887KB) No Do not conduct this activity. VOC EPA-450/3-82-009 Control of Volatile Organic Compound Emissions from Large Petroleum Dry Cleaners (PDF 174 pp, 5.0MB) No Do not conduct this activity. VOC EPA-450/3-83-008 Control of Volatile Organic Compound Emissions from Manufacture of High-Density Polyethylene, Polypropylene, and Polystyrene Resins (PDF 308 pp, 14.0MB) No Do not conduct this activity. VOC EPA-450/3-83-007 Control of Volatile Organic Compound Equipment Leaks from Natural Gas/Gasoline Processing Plants (PDF 194 pp, 6.3MB) No Do not conduct this activity. VOC EPA-450/3-83-006 Control of Volatile Organic Compound Leaks from Synthetic Organic Chemical Polymer and Resin Manufacturing Equipment (PDF 148 pp, 6.2MB) No Do not conduct this activity. VOC EPA-450/3-84-015 Control of Volatile Organic Compound Emissions from Air Oxidation Processes in Synthetic Organic Chemical Manufacturing Industry (PDF 259 pp, 9.4MB) No Do not conduct this activity. VOC EPA-450/4-91-031 Control of Volatile Organic Compound Emissions from Reactor Processes and Distillation Operations in Synthetic Organic Chemical Manufacturing Industry (PDF 277 pp, 8.7MB) No Do not conduct this activity. VOC EPA-453/R-96-007 Control of Volatile Organic Compound Emissions from Wood Furniture Manufacturing Operations (PDF 288 pp, 13.8MB) Note – Wood Furniture (CTG-MACT) – Draft MACT out 5-1994; Final CTG issued 4-1996. See also 61 FR-25223, May 20, 1996 and 61 FR-50823, September 27, 1996. No Do not conduct this activity. VOC EPA-453/R-94-032 Alternative Control Technology Document – Surface Coating Operations at Shipbuilding and Ship Repair Facilities (PDF 217 pp, 9.8MB) Note – For CTG, see 61 FR-44050, August 27,1996 No Do not conduct this activity. VOC 61 FR-44050 8/27/96 Control Techniques Guidelines for Shipbuilding and Ship Repair Operations (Surface Coating) (PDF 30 pp, 4.0MB) Note – See also EPA-453/R-94-032. No Do not conduct this activity. VOC 59 FR-29216 6/06/94 Aerospace MACT (PDF 37 pp, 6MB) Note – See also EPA-453/R-97-004. No Do not conduct this activity. VOC EPA-453/R-97-004 Aerospace (CTG & MACT) (PDF 62 pp, 288KB) Note – See also 59 FR-29216, June 6, 1994. No Do not conduct this activity. VOC EPA-453/R-06-001 Control Techniques Guidelines for Industrial Cleaning Solvents (PDF 290 pp, 7.6MB) No Do not conduct this activity. VOC EPA-453/R-06-002 Control Techniques Guidelines for Offset Lithographic Printing and Letterpress Printing (PDF 52 pp, 349KB) No Do not conduct this activity. VOC EPA-453/R-06-003 Control Techniques Guidelines for Flexible Package Printing (PDF 33 pp, 216KB) No Do not conduct this activity. VOC EPA-453/R-06-004 Control Techniques Guidelines for Flat Wood Paneling Coatings (PDF 27 pp, 212KB) No Do not conduct this activity. VOC EPA 453/R-07-003 Control Techniques Guidelines for Paper, Film, and Foil Coatings (PDF 102 pp, 488KB) No Do not conduct this activity. Ozone State Implementation Plan: Reasonably Available Control Technology Determinations for Kennecott Utah Copper 231005163008_7a16d74e C-3 Pollutant Reference Description EPA Note Applicable Comment VOC EPA 453/R-07-004 Control Techniques Guidelines for Large Appliance Coatings (PDF 44 pp, 374KB) No Do not conduct this activity. VOC EPA 453/R-07-005 Control Techniques Guidelines for Metal Furniture Coatings (PDF 100 pp, 293KB) No Do not conduct this activity. VOC EPA 453/R-08-003 Control Techniques Guidelines for Miscellaneous Metal and Plastic Parts Coatings (PDF 143 pp, 897KB) No Do not conduct this activity. VOC EPA 453/R-08-004 Control Techniques Guidelines for Fiberglass Boat Manufacturing Materials (PDF 41 pp, 336KB) No Do not conduct this activity. VOC EPA 453/R-08-005 Control Techniques Guidelines for Miscellaneous Industrial Adhesives (PDF 47 pp, 350KB) No Do not conduct this activity. VOC EPA 453/R-08-006 Control Techniques Guidelines for Automobile and Light-Duty Truck Assembly Coatings (PDF 44 pp, 2.64MB) Note – See also EPA-453/R-08-002. No Do not conduct this activity. VOC EPA 453/R-08-002 Protocol for Determining the Daily Volatile Organic Compound Emission Rate of Automobile and Light-Duty Truck Primer-Surfacer and Topcoat Operations (PDF 129 pp, 450KB) Note – See also EPA-453/R-08-006. No Do not conduct this activity. VOC EPA-453/B-16-001 Control Techniques Guidelines for the Oil and Natural Gas Industry (343 pp, 1.6 MB) No Do not conduct this activity. Alternative Control Technology VOC EPA-450/3-83-012 Control Techniques for Organic Emissions from Plywood Veneer Dryers (PDF 113 pp, 3.4MB) Note – This document is labeled as a control technique document (CTD) rather than an ACT. However, the information is similar to that in an ACT. No Do not conduct this activity. VOC EPA-450/3-88-007 Reduction of Volatile Organic Compound Emissions from the Application of Traffic Markings (PDF 52 pp, 1.6MB) Note – The Architectural and Industrial Maintenance coatings (AIM) national rule issued in 1998 includes limits for traffic coatings and superseded the ACT. No Do not conduct this activity. VOC EPA-450/3-89-007 Alternative Control Technology Document – Ethylene Oxide Sterilization / Fumigation Operations (PDF 102 pp, 3.2MB) No Do not conduct this activity. VOC EPA-450/3-89-030 Alternative Control Technology Document – Halogenated Solvent Cleaners (PDF 239 pp, 6.7MB) No Do not conduct this activity. VOC EPA-450/3-91-007 Alternative Control Technology Document – Organic Waste Process Vents (PDF 192 pp, 6.9MB) No Do not conduct this activity. VOC EPA-450/3-90-020 Control of VOC Emissions from Polystyrene Foam Manufacturing (PDF 113 pp, 3.5MB) No Do not conduct this activity. VOC EPA-453/R-92-017 Alternative Control Technology Document – Bakery Ovens (PDF 126 pp, 1.2MB) No Do not conduct this activity. VOC EPA-453/R-92-018 Control Techniques for Volatile Organic Compound Emissions from Stationary Sources (PDF 287 pp, 9.2MB) Yes, however, KUC goes above and beyond cited CTGs This document covers control technologies for a wide variety of sources. However, the only sources relevant to KUC are stationary fuel combustion sources. Many of the boilers at KUC are equipped with FGB and/or are subject to NSPS. Good PMs and operating practices are utilized for all sources. All ICE units at KUC are EPA certified under NSPS and ICE units at the BCM, Refinery, and Smelter are regulated under a NESHAP (40 CFR 63 ZZZZ). VOC EPA-453/D-93-056 Control of Volatile Organic Compound Emissions from Industrial Wastewater CTG (draft) (PDF 234 pp, 9.4MB). Note – ACT consists of cover memo with option tables + CTG (draft) EPA-453/D-93-056. Note – CTG not finalized but issued as ACT in 1994. No KUC is not one of the six industries listed. VOC (No Report ID) Industrial Wastewater Alternative Control Technology (PDF 266 pp, 9MB) Note – ACT consists of cover memo with option tables + CTG (draft) EPA-453/D-93-056. No KUC is not one of the six industries listed. VOC EPA-453/R-92-011 Control of VOC Emissions from the Application of Agricultural Pesticides (PDF 250 pp, 9.8MB) No Do not conduct this activity. Ozone State Implementation Plan: Reasonably Available Control Technology Determinations for Kennecott Utah Copper 231005163008_7a16d74e C-4 Pollutant Reference Description EPA Note Applicable Comment VOC EPA-453/R-94-001 Alternative Control Techniques Document – Volatile Organic Liquid Storage In Floating and Fixed Roof Tanks (PDF 202 pp, 8.6MB) No Do not conduct this activity. VOC EPA-453/R-93-020 Control of Volatile Organic Compound Emissions from Batch Processes ACT (PDF 377 pp, 11.9MB) Note – Document also released under the Report ID of EPA- 453/R-93-017. No Do not conduct this activity. VOC EPA-453/R-94-015 Alternative Control Techniques Document – Industrial Cleaning Solvents (PDF 234 pp, 10.6MB) No Do not conduct this activity. VOC EPA-453/R-94-017 Alternative Control Techniques Document – Surface Coating of Automotive/Transportation and Business Machine Plastic Parts (PDF 207 pp, 6.3MB) No Do not conduct this activity. VOC EPA-453/R-94-031 Alternative Control Techniques Document – Automobile Refinishing (PDF 90 pp, 3.6MB) Note – A national rule for autobody refinishing was issued in 1998 after the ACT. No Do not conduct this activity. VOC/PM EPA-453/R-94-032 Alternative Control Techniques Document – Surface Coating Operations at Shipbuilding and Ship Repair Facilities (PDF 217 pp, 9.0MB) Note – This was superseded by the Ship Building CTG which was issued in August 1996. No Do not conduct this activity. VOC EPA-453/D-95-001 Control of Volatile Organic Compound Emissions from Offset Lithographic Printing (PDF 246 pp, 8.6MB) Note – Draft CTG predecessor to the ACT released under the Report ID of EPA-453/R-94-054. No Do not conduct this activity. VOC EPA-453/R-94-054 Alternative Control Techniques Document: Offset Lithographic Printing – Supplemental Information Based on Public Comment on Draft Control Techniques Guidance announced in Federal Register November 8, 1993 (PDF 25 pp, 57KB) Note – See draft CTG (EPA-453/D-95-001) September 1993. No Do not conduct this activity. NOx EPA-453/3-91-026 NOx Emissions from Nitric and Adipic Acid Manufacturing Plants (PDF 146 pp, 312KB) No Do not conduct this activity. NOx EPA-453/R-93-007 NOx Emissions from Stationary Combustion Turbines (PDF 399 pp, 1.2MB) No KUC does have a stationary turbine associated with the Refinery CHP. However, this CTG is not applicable as the CHP turbine is less than the 1MW size detailed in the CTG. The CHP is also subject to NSPS KKKK. NOx EPA-453/R-93-034 NOx Emissions from Process Heaters (PDF 216 pp, 8.5MB) Note – Revised September 1993. No Do not conduct this activity. NOx EPA-453/R-93-032 ACT for NOx Emissions from Stationary Internal Combustion Engines (PDF 340 pp, 13.3MB) Note – Updated September 2000. Yes, however, KUC goes above and beyond cited CTGs All diesel ICE at KUC are EPA certified (NSPS) and many are subject to NESHAP ZZZZ. NOx EPA-453/R-94-004 NOx Emissions from Cement Manufacturing (PDF 198 pp, 624KB) Note – Updated September 2000. See document EPA-457/R-00- 002. No Do not conduct this activity. NOx EPA-457/R-00-002 NOx Control Technologies for the Cement Industry: Final Report (PDF 123 pp, 1.09MB) Note – Update to March 1994 ACT document EPA-453/R-94- 004. No Do not conduct this activity. NOx EPA-453/R-94-022 ACT for NOx Emissions from Industrial, Commercial & Institutional Boilers (PDF 479 pp, 18.8MB) Yes, however, KUC goes above and beyond cited CTGs KUC does have these sources, however most sources are subject to NSPS or are equipped with means to control NOx. The refinery boiler (used as backup only if needed) are subject to NSPS Dc. Smelter boilers are equipped with LNB and FGR or ULNB (Powerhouse superheater). NOx EPA-453/R-94-023 Alternative Control Techniques Document – NOx Emissions from Utility Boilers (PDF 538 pp, 18.8MB) No Do not conduct this activity. NOx EPA-453/R-94-037 Alternative Control Techniques Document – NOx Emissions from Glass Manufacturing (PDF 161 pp, 4.2MB) No Do not conduct this activity. NOx EPA 453/R-94-065 Alternative Control Techniques Document – NOx Emissions from Iron and Steel Mills (PDF 170 pp, 7.9MB) No Do not conduct this activity. VOC EPA-450/3-88-009 Reduction of Volatile Organic Compound Emissions from Automobile Refinishing (PDF 112 pp, 896KB) No Do not conduct this activity. Other Control Technology Documents SOx EPA-450/2-77-019 Final Guideline Document: Control of Sulfuric Acid Mist Emissions from Existing Sulfuric Acid Production Units (PDF 188 pp, 5.3MB) No Do not conduct this activity. Ozone State Implementation Plan: Reasonably Available Control Technology Determinations for Kennecott Utah Copper 231005163008_7a16d74e C-5 Pollutant Reference Description EPA Note Applicable Comment NOx EPA-450/1-78-001 Control Techniques for Nitrogen Oxides Emissions from Stationary Sources – Second Edition (PDF 396 pp, 14.0MB) Note – This document is the second edition of the EPA document entitled: Control Techniques for Nitrogen Oxides Emissions from Stationary Sources. This document was first published in 1970 as National Air Pollution Control Administration Publication No. AP- 67. Yes, however, KUC goes above and beyond cited CTGs Yes, KUC does have numerous ICI boilers and ICE present; however, the equipment at KUC is equipped with LNB (or ULNB), FGR in many instances, and equipment is subject to NSPS and some NESHAP requirements, going above what is outlined in this document. VOC EPA-453/R-95-010 Beyond Volatile Organic Compound-Reasonably Available Control Technology – Control Technology Guidelines Requirements (PDF 442 pp, 10.6MB) No Do not conduct this activity. VOC EPA-453/R-97-002 A Guide to the Wood Furniture CTG and NESHAP (PDF 177 pp, 8.5 MB) No Do not conduct this activity. VOC EPA-453/R-00-004 Preliminary Industry Characterization: Wood Building Products Surface Coating (PDF 50 pp, 1.8 MB) No Do not conduct this activity. Appendix D Information on Utah Power Plant, Tailings, Bonneville Borrow Area, and Central Laboratory Ozone State Implementation Plan: Reasonably Available Control Technology Determinations for Kennecott Utah Copper 231005163008_7a16d74e C-1 Information on Utah Power Plant, Tailings, Bonneville Borrow Area, and Central Laboratory Kennecott Utah Copper (KUC) owns and operates the Utah Power Plant (UPP). Issued on February 4, 2020, Approval Order (AO) DAQE – AN105720040-20 permits miscellaneous activities at the UPP. UPP Boilers 1 through 3 permanently ceased operation in 2017. UPP Boiler 4 permanently ceased operation in 2019. Tailings operations are permitted under AO DAQE-AN0572018-06 issued on April 6, 2006. AO DAQE-AN160350001-21 was issued on March 18, 2021, to authorize the operation of the Bonneville Borrow Area plant, a crushing and screening plant in Magna. This plant is used to supply building and reclamation materials to other Kennecott facilities. KUC operates a central laboratory permitted under AO AN105720043-23 issued on July 11, 2023. Potential to emit (PTE) emissions in tons per year for the UPP, Tailings, Bonneville Borrow Area, and Central Laboratory are shown in Table D-1. These KUC facilities are a minor source of emissions, and a RACT analysis was not requested by the Utah Division of Air Quality; however, PTE emissions are documented here for informational purposes. Table D-1. PTE Emissions for Utah Power Plant, Tailings, Bonneville Borrow Area, and Central Laboratory NOx PTEs (tpy) VOC PTEs (tpy) Utah Power Plant 0.47 1.58 Tailings 0.26 0.04 Bonneville Borrow Area 1.26 0.15 Central Laboratory 2.88 0.26 Notes: NOx = nitrogen oxide tpy = ton(s) per year VOC =volatile organic compound