DAQ-2024-012132

1
DAQC-CI114620001-24
Site ID 11462 (B1)

MEMORANDUM

TO: FILE – LISBON VALLEY MINING COMPANY, LLC – Lisbon Valley Open Pit
Copper Mine

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Jared James, Environmental Scientist

DATE: December 17, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, San Juan County

INSPECTION DATE: July 10, 2024

SOURCE LOCATION: 920 South County Road 313
La Sal, UT 84530

DIRECTIONS: 18 miles southeast of La Sal, San Juan County. Take Highway 191
south from Moab. 15.7 miles from the San Juan County line on
Highway 191 is the La Sal Junction to Highway 46. Take Highway
46 east approximately 6.5 miles to Lisbon Valley Road. Take Lisbon
Valley Road south approximately 5.7 miles and take the left
(southeast) split in the road. Travel 9 miles southeast on this road
(pavement will end at about 5.7 miles) to the mine site. These back
roads are posted at 50 mph and patrolled.

SOURCE CONTACTS: Alysen Tarrant, Environmental Manager
435-686-9950 ext. 126, [e-mail]

OPERATING STATUS: Operating normally.

PROCESS DESCRIPTION: Lisbon Valley Mining Company, LLC (LVMC) operates a copper
mining and solvent extraction facility. Waste rock and overburden
are removed from ore deposits by scooping the material in a front-end
loader and shipping off to a waste rock pile by haul trucks. Ore
deposits are fragmented by explosives in various pits. LVMC has
tightened the blasting pattern and has been able to remove the primary
and secondary crushers as well as the associated baghouse and
conveyors as they are no longer needed. The smaller fragmented
deposits are now loaded directly into the heap leach processing
facility. The material is deposited onto the leach pad, and dilute
sulfuric acid leachate is applied by drip lines. This solution dissolves
the copper from the ore. The resultant pregnant solution is routed to
the solvent extraction circuit where it is further processed to extract
the copper and plate it in the electro-winning process. A heater is
used to heat the solution, but the fuel used is now liquid natural gas
instead of the permitted diesel or propane. Fugitive dust is controlled
by three water trucks on the haul roads and operational areas.

0 0
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APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN114620015-21, dated
April 15, 2021

NSPS (Part 60) Dc: Standards of Performance for Small
Industrial-Commercial-Institutional Steam Generating Units,
NSPS (Part 60) IIII: Standards of Performance for Stationary
Compression Ignition Internal Combustion Engines,
NESHAP (Part 63) ZZZZ: National Emissions Standards for
Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines.

SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Lisbon Valley Mining Company, LLC
Lisbon Valley Open Pit Copper Mine

P.O. Box 400 920 South County Road 313
Moab, UT 84532 La Sal, UT 84530

SIC Code: 1021: (Copper Ores)

Section I: GENERAL PROVISIONS

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the
UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to
those rules. [R307-101]

I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions
covered by this AO must be reviewed and approved. [R307-401-1]

I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request. Unless
otherwise specified in this AO or in other applicable state and federal rules, records shall be kept
for a minimum of two (2) years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall,
to the extent practicable, maintain and operate any equipment approved under this AO, including
associated air pollution control equipment, in a manner consistent with good air pollution control
practice for minimizing emissions. Determination of whether acceptable operating and
maintenance procedures are being used will be based on information available to the Director
which may include, but is not limited to, monitoring results, opacity observations, review of
operating and maintenance procedures, and inspection of the source. All maintenance performed
on equipment authorized by this AO shall be recorded. [R307-401-4]

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]
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I.8 The owner/operator shall submit documentation of the status of construction or modification to
the Director within 18 months from the date of this AO. This AO may become invalid if
construction is not commenced within 18 months from the date of this AO or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director, send
the documentation to the Director, attn.: NSR Section. [R307-401-18]

Status: Out of Compliance. The source exceeded limits concerning acid use and explosives.
The source was operating an unapproved generator and mobile crusher, as well as two
boilers that had been on previous AOs but were not included in the current AO. Records
are maintained. Equipment is regularly maintained. The source submitted a 2023 emission
inventory. All equipment in the equipment list was existing when the AO was issued so
notification of installation is not necessary.

Section II: SPECIAL PROVISIONS

II.A The approved installations shall consist of the following equipment:

II.A.1 Copper Mine
Plant Wide

II.A.2 Boiler
One (1) Boiler
Capacities: 24.5 MMBtu/hr
Fuel: natural gas

NSPS Subpart Dc

II.A.3 Various Emergency Generator Engines
Two (2) emergency generator engines
Capacity: 1,119 kW (1,500 hp) each
Manufacture dates: 2001
Fuel: diesel

One (1) emergency generator engine
Capacity: 750 kW (1,006 hp)
Manufacture date: 1999
Fuel: diesel

One (1) emergency generator engine
Capacity: 600 kW (805 hp)
Manufacture date: 2006
Fuel: diesel

Three(3) emergency generator engines
Capacity: 22.4 kW (30 hp) each
Manufacture dates: 2009 & two (2) 2010
Fuel: diesel
II.A.4 Various Pump Engines One (1) pump engine Capacity: 60 kW (80 hp) Manufacture date: 1999 Fuel: diesel
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One (1) pump engine Capacity: 46 kW (61 hp) Manufacture date: 2011 Fuel: diesel One (1) pump engine Capacity: 20 kW (27 hp) Manufacture date: 1999 Fuel: diesel One (1) pump engine Capacity: 14 kW (19 hp) Manufacture date: 2005 Fuel: diesel Three (3) pump engines Capacity: 13 kW (17 hp) each Manufacture date: 2001 Fuel: diesel
II.A.5 Crusher
One (1) Jaw Crusher
Manufactured: 2017
Capacity: 250 tons/hr
Attached equipment: 168 kW (225 hp) generator
Fuel: diesel

NSPS Subpart LL
NSPS Subpart IIII
MACT Subpart ZZZZ

II.A.6 Heap leach facilities
Heap leach facilities and solution processing system.

II.A.7 Solvent extraction system

II.A.8 Electrowinning system

II.A.9 Copper cathode loadout facilities

II.A.10 Miscellaneous support facilities
Fuel storage
Fuel: diesel
Capacity: 160 gallons

Laboratory Operations
Chemical storage
Stored: H2SO4

Status: Out of Compliance. The equipment list was on site, however, the source was
operating an unapproved Godwin 130 kW generator and two secondary boilers (the
boilers may have been included on previous AO but were left off the current).

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II.B Requirements and Limitations

II.B.1 Plantwide Conditions

II.B.1.a The owner/operator shall not deliver more than 3,000,000 tons of copper ore to the heap leaching
pads per rolling 12-month period. The owner/operator shall not mine more than 10,000,000 tons
of waste material per 12-month rolling period. The owner/operator shall not use more than
15,000 tons of acid per 12-month period. [R307-401-8]

II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new
12-month total by the 20th day of each month using data from the previous 12 months. Sulfuric
acid usage shall be determined by purchase records of the sulfuric acid delivered to the plant.
The waste material mined in the mining area and the copper ore delivered to the heap leaching
pad shall be determined by scale house records, in-truck scales, or vendor receipts. The records
of waste material sent back to the mining area and the copper ore delivered to the heap leaching
pads shall be kept on a daily basis. [R307-401-8]

Status: Out of Compliance. The source delivered 959,830 tons of copper to the heap
leaching pads, mined 7,319,340 tons of waste material, but exceeded the acid limit by using
20,615 tons during the 12-month period.

II.B.1.b The owner/operator shall not exceed visible emissions from the following sources:

A. All solvent extraction facilities and electrowinning systems fugitive emissions - 10% opacity.

B. Crusher and other plant points - 10% opacity. [R307-401-8]

II.B.1.b.1 Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9. [R307-401-8]

Status: In Compliance. No emissions were observed from these processes during the
inspection.

II.B.2 Fugitive Dust Requirements

II.B.2.a Within 30 days of the date of this AO, the owner/operator shall submit a FDCP in electronic or
written format. An electronic FDCP can be completed through the Utah DEQ Fugitive Dust Plan
Permit Application Website. If a written FDCP is completed, it shall be submitted to the
Director, attention: Compliance Branch, for approval. The owner/operator shall comply with the
FDCP for control of all fugitive dust sources associated with this source. [R307-401-8]

Status: In Compliance. The source maintains a copy of the FDCP onsite and appear to
follow proper control practices.

II.B.2.b The owner/operator shall use water application, chemical stabilization, or other control options
contained in R307-205-5 to minimize emissions from fugitive dust and fugitive emissions
sources, including haul roads, storage piles, conveyor drop points, feed hopper, and disturbed
areas. Controls shall be applied to ensure the opacity limits.in this AO are not exceeded. Records
of treatment shall be kept on a daily basis. [R307-205]

II.B.2.b.1 Records of water application shall be kept for all periods when the plant is in operation. The
records shall include the following items:

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A. Date and time treatments were made
B. Number of treatments made and quantity of water applied
C. Rainfall amount received, if any
D. Records of temperature, if the temperature was above freezing. [R307-401-8]

Status: In Compliance. Water is applied as needed. Water records were provided for
review during the inspection.

II.B.2.c The total unpaved haul road lengths shall not exceed:

A. 2.97 miles for copper ore haulage from the Centennial ore pit to the heap leaching station
B. 2.74 miles for the GTO copper ore haulage from GTO ore pit to the heap leaching station
C. 2.55 miles for waste material haulage from the Centennial ore pit to the main waste dump
D. 0.97 miles for the GTO waste material haulage from the GTO ore pit to the waste dump.

All the mileages are one way. The total distance is from four different roadways. [R307-401-8]

II.B.2.c.1 Compliance shall be determined through GPS measurements or aerial photographs.
[R307-401-8]

Status: In Compliance. The source provided aerial photographs for review at the time of
inspection which indicated 2.14 miles for copper ore, 2.44 miles for the GTO, 0.43 miles for
waste material, and 0.90 miles for GTO waste.

II.B.2.d The owner/operator shall not exceed the following limits:
A. 52 blasting episodes per rolling 12-month period
B. 510 tons of ANFO used per rolling 12-month period. [R307-401-8]

II.B.2.d.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new
12-month total by the 20th day of each month using data from the previous 12 months. The
number of blasting episodes and the amount of ANFO per blasting episode shall be determined
by supervisor monitoring of the operation and recorded in a log book. [R307-401-8]

Status: Out of Compliance. The source exceeded their explosive limits with 153 blasts and
2,176.6 tons of ANFO during the 12-month period.

II.B.2.e Visible fugitive dust emissions from haul-road traffic and mobile equipment in operational areas
shall not exceed 20% opacity at any point. [R307-205]

II.B.2.e.1 Visible emission determinations shall use procedures similar to Method 9. The normal
requirement for observations to be made at 15-second intervals over a six-minute period,
however, shall not apply. Visible emissions shall be measured at the densest point of the plume
but at a point not less than 1/2 vehicle length behind the vehicle and not less than 1/2 the height
of the vehicle. [R307-401-8]

Status: In Compliance. Only minimal visible emissions were observed from haul traffic. A
water truck was making rounds during the inspection.

II.B.3 Fuel Requirements

II.B.3.a The owner/operator shall only use natural gas as fuel in the boiler. [R307-401-8]

Status: In Compliance. Only natural gas is used as fuel in the boiler.
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II.B.3.b The owner/operator shall not consume more than 164.25 million scf natural gas in the boiler per
rolling 12-month period. [R307-401-8]

II.B.3.b.1 Compliance with the limitation shall be determined on a rolling 12-month total. Based on the
20th day of each month, a new 12-month total shall be calculated using data from the previous 12
months. Records of consumption shall be kept for all periods when the plant is in operation.
Purchase records shall determine consumption. The records shall be kept on a monthly basis.
[R307-401-8]

Status: In Compliance. The source used 131.13 million scf of natural gas during the
12-month period.

II.B.3.c The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as
fuel in the crusher engine, emergency generators engines, and the pump generator engines onsite.
[R307-401-8]

Status: In Compliance. Only diesel fuel is used to operate the listed equipment.

II.B.3.d The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur
diesel (ULSD), which has a sulfur content of 15 ppm or less. [R307-401-8]

II.B.3.d.1 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain
records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel
fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the
ULSD requirements. [R307-401-8]

Status: In Compliance. Ultra-low sulfur diesel fuel is purchased from Keller Straus, Inc.

II.B.4 Engine Requirements

II.B.4.a The owner/operator shall not exceed visible emissions from all boilers and heaters of 10%
opacity and all diesel engines of 20% opacity. [R307-401-8]

II.B.4.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9. [R307-401-8]

Status: In Compliance. No visible emissions were observed from the boiler or heaters.

II.B.4.b The owner/operator shall install a diesel crusher engine; diesel well pump 1 generator engine;
and diesel pump 3 generator engine that is certified to meet a NOx emission rate of 0.40 g/hp-hr
or less. [R307-401-8]

II.B.4.b.1 To demonstrate compliance with the emission rate, the owner/operator shall keep a record of the
manufacturer's certification of the emission rate. The record shall be kept for the life of the
equipment. [R307-401-8]

Status: Out of Compliance. The two generator engines have not operated in over two
years. The source was not able to provide emission certification for the crusher engine.

II.B.4.c The owner/operator of the diesel-fired pump engines shall not exceed the following hours per
rolling 12-month period:

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Storm pump 200
Back-up for heap pump 3 200
Heap pump 1 500
Heap pump 2 500
Heap pump 3 500
Spare back-up 500
Well pump 1 1,000
Well pump 2 1,500
Well pump 3 1,500 . [R307-401-8]

II.B.4.c.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new
12-month total by the 20th day of each month using data from the previous 12 months. Records
documenting the operation of the engine shall be kept in a log and shall include the following:

A. The date the engine was used

B. The duration of operation in hours. [40 CFR 63 Subpart ZZZZ]

II.B.4.c.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour
meter for each emergency generator engine and each generator engine. [R307-401-8]

Status: Out of Compliance. The listed generators have not operated in the 12-month
period. However, an unapproved 130 kW Godwin generator has operated but hours were
not tracked.

II.B.4.d The owner/operator shall not operate each emergency engine on site for more than 100 hours per
rolling 12-month period during non-emergency situations. There is no time limit on the use of
the engines during emergencies. [R307-401-8, 40 CFR 63 Subpart ZZZZ]

II.B.4.d.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new
12-month total by the 20th day of each month using data from the previous 12 months. Records
documenting the operation of each emergency engine shall be kept in a log and shall include the
following:

A. The date the emergency engine was used

B. The duration of operation in hours

C. The reason for the emergency engine usage. [40 CFR 60 Subpart ZZZZ, R307-401-8]

II.B.4.d.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour
meter for each emergency engine. [R307-401-8]

Status: In Compliance. The emergency generators have not operated in the 12-month
period. The engines are equipped with hour meters.

II.B.5 Crusher Requirements

II.B.5.a The owner/operator shall not operate the jaw crusher more than 4,200 hours per rolling 12-month
period. [R307-401-8]

II.B.5.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new
12-month total by the 20th day of each month using data from the previous 12 months. Crusher
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hours of operation shall be measured every day the crusher is in operation. The hours of
operation shall be determined by supervisor monitoring and recorded in a log book.
[R307-401-8]

Status: In Compliance. The crusher operated 222.5 hours during the 12-month period.

II.B.5.b The owner/operator shall not operate the crusher engine before 6:00 am and after 6:00 pm each
day. [R307-401-8]

II.B.5.b.1 The owner/operator shall keep and maintain the following records of operation for all periods the
crusher engine is in operation:

A. Time operations begin each day
B. Time operations end each day. [R307-401-8]

Status: In Compliance. The crusher operates within the set time parameters.

Section III: APPLICABLE FEDERAL REQUIREMENTS

In addition to the requirements of this AO, all applicable provisions of the following federal programs have
been found to apply to this installation. This AO in no way releases the owner or operator from any liability
for compliance with all other applicable federal, state, and local regulations including UAC R307.

NSPS (Part 60) Dc: Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating
Units

Status: In Compliance. The boiler operates solely on natural gas. Natural gas records are maintained
by the source.

NSPS (Part 60) IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion
Engines

Status: In Compliance. IIII applies to the 600 kW and three (3) 22.4 kW emergency generators, the 46
kW pump engine, and the crusher generator. The emergency generators and pump engine have not
operated in the 12-month period. The crusher operated 222.5 hours and is maintained regularly.

NESHAP (Part 63) ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary
Reciprocating Internal Combustion Engines.

Status: In Compliance. Only the two 1,119 kW emergency generators have operated in the 12-month
period. Each was tested quarterly for 30 minutes for a total of two hours each. All generators have hour
meters. Regular maintenance is performed on generators that are in use.

AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

Emission Standards: Sulfur Content of Fuels [R307-203]

Status: In Compliance. This condition is met by compliance with condition II.B.3.d.

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Emission Standards: Fugitive Emissions and Fugitive Dust [R307-205]

Status: In Compliance. Only minimal emissions from haul road traffic was observed during the
inspection.

Stationary Sources [R307-210]

Status: In Compliance. This condition is met by compliance with IIII.

National Emission Standards for Hazardous Air Pollutants [R307-214]

Status: In Compliance. This condition is met by compliance with ZZZZ.

EMISSION INVENTORY:
Listed below are the Actual Emissions Inventory provided from Lisbon Valley Mining Company, LLC –
Lisbon Valley Open Pit Copper Mine. A comparison of the estimated total potential emissions (PTE) on AO:
DAQE-AN114620015-21, dated April 15, 2021, is provided. PTE are supplied for supplemental purposes
only.

Criteria Pollutant PTE tons/yr Actuals tons/yr
CO2 Equivalent 10399.00
Carbon Monoxide 36.51
Nitrogen Oxides 23.50 49.2022
Particulate Matter - PM10 353.76 455.0693
Particulate Matter - PM10 (Fugitives) 352.57
Particulate Matter - PM2.5 59.75 44.1662
Particulate Matter - PM2.5 (Fugitives) 58.56
Sulfur Dioxide 0.56 0.6294
Volatile Organic Compounds 0.44 3.5842

Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr
Formaldehyde (CAS #50000) 12
Generic HAPs (CAS #GHAPS) 680
Hexane (CAS #110543) 290
Toluene (CAS #108883) 14

PREVIOUS ENFORCEMENT
ACTIONS: None in the past five years.

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN114620015-21, dated
April 15, 2021, the overall status is: Out of Compliance. Out of
compliance with conditions I.2, I.3, II.B.1.a, II.B.2.d, and II.B.4.c for
operating an unapproved generator, portable crusher, and two boilers,
and for exceeding limits for acid use, explosive blasts, and ANFO
tonnage. In compliance with the remainder of conditions. The source
appears to be adequately maintained and otherwise operated properly.
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A compliance advisory was issued (DAQC-859-24) and an early
settlement agreement (DAQC-1125-24). Payment of the ESA was
received December 9, 2024.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Inspect at an increased frequency. Look for new AO. May want to
contact Alysen Tarrant prior to inspection to verify she will be on-
site. PPE required for the site include steel-toed boots, reflective vest,
safety glasses, and hearing protection.

NSR RECOMMENDATIONS: Include 130 kW generator, second crusher, and the two boilers in the
next AO. May want to include language which allows the source to
change out generators of equal size and tier.

ATTACHMENTS: VEO Form, Operation Records, Emails
Metso Crusher hours Rental Crusher WESCO shots/Month ANFO #s used
Jul-23 138.5 13 385441
Aug-23 165.5 13 357459
Sep-23 157 312 10 333916
Oct-23 65.5 165.5 11 335729
Nov-23 45.5 11 359468
Dec-23 7 11 315034
Jan-24 52.5 9 393457
Feb-24 0 10 430462
Mar-24 0 13 321524
Apr-24 153.5 13 338865
May-24 106.5 13 329455
Jun-24 75.5 13 284260
Jul-24 0 13 168043
Jared James <[e-mail]>
FW: Air Quality Totals - Requested Information
2 messages
Alysen Tarrant <[e-mail]>Mon, Jul 22, 2024 at 2:05 PM
To: Jared James <[e-mail]>
This message was sent securely using Zix®
Hi Jared,

Please see the attached totals for crusher hours, number of blasts, and ANFO used.

Please let me know if there is anything else you need.

Thanks,

Alysen D. Tarrant, CWP
Environmental Manager
Lisbon Valley Mining Company, LLC
920 South County Road 313
La Sal Utah 84530
Cell: [phone]
Email: [e-mail]

From: Chris Torres <[e-mail]>
Sent: Thursday, July 18, 2024 1:49 PM
To: Alysen Tarrant <[e-mail]>; Audren Adams <[e-mail]>
Subject: RE: Air Quality Totals - Requested Informaon

Aly,

Here you go.
12/17/24, 9:45 AM State of Utah Mail - FW: Air Quality Totals - Requested Information
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-f:1805310985843494081&simpl=msg-f:180531098584349408…1/2

Thanks,
Chris

From: Alysen Tarrant <[e-mail]>
Sent: Thursday, July 18, 2024 7:08 AM
To: Chris Torres <[e-mail]>; Audren Adams <[e-mail]>
Subject: Air Quality Totals - Requested Informaon

Hi Chris and Audren,

I’m trying to get the Air Quality Inspection wrapped up today. Can you please let me know where on the L drive I can find:
1. Crusher hours (summarized by month) for July 2023 – June 2024
2. Total number of blasts (summarized by month) for July 2023 – June 2024
3. Total amount of ANFO used (summarized by month) for July 2023 – June 2024

Thanks,
-Aly
This message was secured by Zix®.
Book1.xlsx
10K
Jared James <[e-mail]>Tue, Jul 23, 2024 at 3:52 PM
To: Alysen Tarrant <[e-mail]>
Aly
Thanks for getting those to me. I will send the Compliance Advisory the first part of August.
[Quoted text hidden]
--
Jared James | Environmental Scientist | Minor Source Compliance
Phone:[phone] email: [e-mail]
195 North 1950 West, Salt Lake City, UT 84116
12/17/24, 9:45 AM State of Utah Mail - FW: Air Quality Totals - Requested Information
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-f:1805310985843494081&simpl=msg-f:180531098584349408…2/2
LVMC Response Re: Letter Dated August 22, 2024 P a g e | 1

29 August 2024

SUBJECT: Response to Compliance Advisory (CA) – Lisbon Valley Open Pit Copper Mine – Utah
Administrative Code (UAC) R307-401, Approval Order (AO) DAQE-AN114620015-21, San Juan County

Attn: Jared James, DELIVERY: Electronic
Environmental Scientist – Minor Source Compliance
Utah Division of Air Quality
PO Box 144820
Salt Lake City, UT 84114-4820

Dear Mr. James,

Please see this response to the CA that was received by Lisbon Valley Mining Company (Company) on August
22, 2024. This response is being provided to: a) ensure the Company has a thorough understanding of the
CA; b) propose a timeline for modification of the AO; and c) request a meeting to discuss the timeline for the
modification, and ensure such timeline/actions are agreeable with the Division.

Understanding of the CA
It is the Company’s understanding that during the 2023 year, which year occurs from July 2022 until the end
of June 2023, the Company exceeded the following permit conditions:

Permit Condition: II.A.2: Boilers
Violation: The Company operates three boilers; one primary and two secondary (see 2014 AO). It appears
that the two secondary boilers were erroneously removed from the 2021 AO.
Company-proposed solution: The Company would like to be provided with the opportunity to modify its AO
to re-add the two secondary boilers that were erroneously removed during the 2021 AO Modification
process, as well as add a fourth boiler that is anticipated to be installed within 12 months of this letter.

Permit Condition: II.A.4: Various Pump Engines
Violation: The Company has a rental pump engine (Godwin) that is used during summertime.
Company-proposed solution: The Company anticipates the continued seasonal use of up to two (2) additional
pump engines. Therefore, the Company would like to be provided with the opportunity to modify its AO to
add spare or backup pump engines that the Company can operate on a seasonal basis.

Permit Condition: II.A.5: Crusher
Violation: The Company has a rental crusher onsite that was not covered under a Temporary Relocation
Permit.
LVMC Response Re: Letter Dated August 22, 2024 P a g e | 2
Company-proposed solution: The Company is expecting to replace the presently-permitted Jaw Crusher with
a similar-sized Impact Crusher. The Company is also expecting to need to bring onsite a second crusher during
construction operations. Therefore, the Company would like to be provided with the opportunity to modify
its AO to replace the current Jaw Crusher with an Impact Crusher of similar size, as well as provide a second
mobile crusher to the AO to allow flexibility for the Company to use during construction operations.

Permit Condition: II.B.1.a: The owner/operator shall not use more than 15,000 tons of acid per 12-month
period.
Violation: The Company used over 15,000 tons of acid during the 12-month period defined herein. There was
no stated limit for the acid usage in the 2014 AO. The Company, while working with DAQ during the 2021
Modification, underestimated the increased acid consumption during the ramp-up back to full production
that occurred over the past three years.
Company-proposed solution: The Company has stabilized its mining rates and acid application rates.
Therefore, the Company would like to be provided with the opportunity to modify its AO to increase the acid-
usage rates based upon updated forecasts for the operation.

Permit Condition: II.B.2.d: The owner/operator shall not exceed the following limits: 52 blasting episodes per
rolling 12-month period; 510 tons of ANFO used per rolling 12-month period.
Violation: The Company exceeded its total number of blasts as well as the total tons of ANFO for the rolling
12-month period as defined herein. There were no stated blast totals or ANFO limits in the 2014 AO. It
appears that this estimate was based on a less aggressive mine plan than what was enacted by the Company.
Company-proposed solution: The Company has solidified its near-term mine plan, including mining rates,
blasting rates, and ANFO usage. Therefore, the Company will need to modify its AO to increase blasting and
ANFO usage based on the projected mine plan.

Proposed Timeline for Modification
The Company would like to propose that the proposed modifications set forth herein be made in the form
of a Notice of Intent to Modify, that will be submitted to the Division within 90 days of the date of this
letter.

Request to Meet with DAQ Representatives
The Company is requesting to meet with DAQ Representatives within 30 days of the date of this letter to
discuss any further areas in question regarding the operation, and to ensure the Division is amenable to the
proposed modification and timeline of such.

I look forward to hearing from you.

Best Regards,

Alysen Tarrant
Environmental Manager
Jared James <[e-mail]>
DAQE-AN114620015-21 - Response to August 22, 2024 Compliance Advisory
10 messages
Alysen Tarrant <[e-mail]>Thu, Aug 29, 2024 at 1:30 PM
To: Jared James <[e-mail]>, "[e-mail]" <[e-mail]>, Alan Humpherys <[e-mail]>
Cc: George Shaw <[e-mail]>, Larry Giegerich <[e-mail]>
This message was sent securely using Zix®
Hi,

Please see the attached response. I look forward to working with you to overcome these compliance issues.

Best Regards,

Alysen D. Tarrant, CWP
Environmental Manager
Lisbon Valley Mining Company, LLC
920 South County Road 313
La Sal Utah 84530
Cell: [phone]
Email: [e-mail]

This message was secured by Zix®.
2024_August_LVMC Response-11462(rev2).pdf
184K
Jared James <[e-mail]>Thu, Aug 29, 2024 at 3:10 PM
To: Chad Gilgen <[e-mail]>
Hi Chad
Here is Lisbon Valley Mining Company's response to their CA.
[Quoted text hidden]
12/17/24, 9:47 AM State of Utah Mail - DAQE-AN114620015-21 - Response to August 22, 2024 Compliance Advisory
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-f:1808751490201360871&simpl=msg-f:180875149020136087…1/5
--
Jared James | Environmental Scientist | Minor Source Compliance
Phone:[phone] email: [e-mail]
195 North 1950 West, Salt Lake City, UT 84116
2024_August_LVMC Response-11462(rev2).pdf
184K
Jared James <[e-mail]>Thu, Aug 29, 2024 at 3:11 PM
To: Alysen Tarrant <[e-mail]>
Thanks Alysen
I will speak to my manager about a meeting date.
[Quoted text hidden]
[Quoted text hidden]
Chad Gilgen <[e-mail]>Tue, Sep 10, 2024 at 8:19 AM
To: Jared James <[e-mail]>
Hi Jared,
Have you responded to let Alysen know you received this response? The letter is addressed to you and it looks like she
wants to have a meeting with compliance and permitting to get a new NOI and seek our approval for the proposed
timeline.
Chad
Chad Gilgen | Manager | Minor Source Compliance
385-306-6500 (cell)
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
[Quoted text hidden]
Jared James <[e-mail]>Tue, Sep 10, 2024 at 9:16 AM
To: Chad Gilgen <[e-mail]>
Yes, I told her I would speak to you about setting up a meeting time.
[Quoted text hidden]
Jared James <[e-mail]>Tue, Sep 10, 2024 at 11:45 AM
To: Alysen Tarrant <[e-mail]>
Cc: "[e-mail]" <[e-mail]>, Alan Humpherys <[e-mail]>, George Shaw
<[e-mail]>, Larry Giegerich <[e-mail]>
Hi Alysen,
12/17/24, 9:47 AM State of Utah Mail - DAQE-AN114620015-21 - Response to August 22, 2024 Compliance Advisory
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-f:1808751490201360871&simpl=msg-f:180875149020136087…2/5
I spoke with Chad Gilgen (Minor Source Compliance Manager) and he has reviewed your Compliance Advisory response.
He said it looks like you probably just need to set up a pre-NOI meeting with Alan Humphreys to make those modifications
to your AO. If you would like someone from compliance to be at that meeting we could do that as well. But contact Alan to
set up that meeting. Thanks!
On Thu, Aug 29, 2024 at 1:30 PM Alysen Tarrant <[e-mail]> wrote:
[Quoted text hidden]
[Quoted text hidden]
Alysen Tarrant <[e-mail]>Tue, Sep 10, 2024 at 12:45 PM
To: Jared James <[e-mail]>
Cc: "[e-mail]" <[e-mail]>, Alan Humpherys <[e-mail]>, George Shaw
<[e-mail]>, Larry Giegerich <[e-mail]>
This message was sent securely using Zix®
Thank you, Jared!

Alan: do you have time next week for a virtual pre-NOI meeting?

Thanks,
[Quoted text hidden]
[Quoted text hidden]
195 North 1950 West, Salt Lake City, UT 84116
[Quoted text hidden]
Alan Humpherys <[e-mail]>Tue, Sep 10, 2024 at 12:53 PM
To: Alysen Tarrant <[e-mail]>
Cc: Jared James <[e-mail]>, "[e-mail]" <[e-mail]>, George Shaw
<[e-mail]>, Larry Giegerich <[e-mail]>
Alysen,
Yes, I have time next week. Right now, Monday and Wednesday are my best days. Is there a time of the day that works
best for you?
Thanks,
Alan
[Quoted text hidden]
--
12/17/24, 9:47 AM State of Utah Mail - DAQE-AN114620015-21 - Response to August 22, 2024 Compliance Advisory
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-f:1808751490201360871&simpl=msg-f:180875149020136087…3/5
Alan Humpherys
Manager | Minor NSR Section
P: [phone]
F: [phone]
airquality.utah.gov
[Quoted text hidden]
Alysen Tarrant <[e-mail]>Tue, Sep 10, 2024 at 1:16 PM
To: Alan Humpherys <[e-mail]>
Cc: Jared James <[e-mail]>, "[e-mail]" <[e-mail]>, George Shaw
<[e-mail]>, Larry Giegerich <[e-mail]>
This message was sent securely using Zix®
Hi Alan,

How about Wednesday at 10:00 AM? If this works I will send out a Teams invite.
[Quoted text hidden]
[Quoted text hidden]
Alan Humpherys
Manager | Minor NSR Section
P: [phone]
F: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

[Quoted text hidden]
Alan Humpherys <[e-mail]>Tue, Sep 10, 2024 at 1:27 PM
To: Alysen Tarrant <[e-mail]>
12/17/24, 9:47 AM State of Utah Mail - DAQE-AN114620015-21 - Response to August 22, 2024 Compliance Advisory
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-f:1808751490201360871&simpl=msg-f:180875149020136087…4/5
Cc: Jared James <[e-mail]>, "[e-mail]" <[e-mail]>, George Shaw
<[e-mail]>, Larry Giegerich <[e-mail]>
Yes, Wednesday, September 18th, at 10:00 works for me. I'll keep an eye out for the appointment invite.
[Quoted text hidden]
--
Alan Humpherys
Manager | Minor NSR Section
P: [phone]
F: [phone]
airquality.utah.gov
[Quoted text hidden]
12/17/24, 9:47 AM State of Utah Mail - DAQE-AN114620015-21 - Response to August 22, 2024 Compliance Advisory
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-f:1808751490201360871&simpl=msg-f:180875149020136087…5/5