DAQ-2024-007588

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DAQC-380-24
Site ID 10346 (B1)

MEMORANDUM

TO: FILE – KENNECOTT UTAH COPPER – Smelter/Refinery

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Joseph Randolph, Environmental Scientist

DATE: April 24, 2024

SUBJECT: FULL COMPLIANCE EVAULATION, Major, Salt Lake County,
FRS ID #UT0000004903500030

INSPECTION DATE: March 4, and April 16, 2024. Records received April 18, 2024.

SOURCE LOCATION: 11500 West 2100 South, Magna, Salt Lake County
4700 Daybreak Parkway, South Jordan, Ut 84095 (mailing)

SOURCE CONTACTS: Sean Daly, Environmental Engineer - [phone]

OPERATING STATUS Operating normally

PROCESS DESCRIPTION:

Smelter: Copper concentrate is received from the Copperton Concentrator in slurry form by pipe and
stored in the smelter concentrate storage bins. The concentrate arrives with a minimum moisture content
of 10%. The concentrate is then sent through a rotary dryer and sent to the dried feed bins. The
concentrate is then fed into the flash smelting furnace where copper is separated from waste byproducts.
These wastes are removed in the form of slag. The slag is transported to the slag crushing operation
located west of the smelter. The copper portion enters the matte granulation process where molten copper
is dumped from the flash smelting furnace into water to form copper matte. The matte, when cooled,
becomes hardened into little granulated balls. This granulated material is then transported to the matte
stockpile. The granulated matte is transported from the stockpile to the matte grinding plant to be ground
into a fine powder. The ground matte is transported to the storage bin above the flash converting furnace
and is combined with flux, a limestone reagent that assists in the converting process. The flash converting
furnace further separates copper from any remaining waste, or slag. This slag is cooled in water and is
stored to be reground and re-smelted to draw out any remaining copper. The remaining molten copper is
drained from the flash converting furnace and poured into the anode refining furnaces. There the copper is
refined for the last time and is poured into anode molds. These anodes are the final product of the smelter
and are 99.8% pure copper. Any imperfect anodes, or those that do not mold properly, are stacked and
will be re-melted in the anode refining furnaces. Scrap copper anodes from the refinery are also recycled
in this manner.

Throughout the smelter, Kennecott has installed pollution control devices. Dust from the rotary dryer is
routed through an electrostatic precipitator and the off gases flow through the secondary scrubber system
before being emitted through the main stack.

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The smelting furnace and converting furnace are equipped with a waste heat boiler and electrostatic
precipitator. The off gases from the furnaces are routed to the acid plant where the off gases are converted
into low and high strength acids. Any remaining gases are emitted from the main stack. The acid
produced in the acid plant is shipped to market by rail cars. The acid sold is a 96% sulfuric acid. The low,
or 94% acid, is mixed with the higher strength acid, 98%, to balance the acids at 96% in order to keep the
acid plant operating. Any acid strength higher or lower than 96% causes problems in the operation of the
acid plant.

Refinery: Copper anodes produced at the smelter are transported by railroad to the refinery electro
refining circuit for further refining of the copper and precious metals recovery.

In the copper refining process, copper anodes are immersed in a heated H2SO4 solution contained in
polymer concrete tanks. The building where this occurs is called the “tank house”. An electric current is
applied to the anodes, which results in its dissolution and deposit onto stainless steel blanks (plating),
thereby producing high purity cathode copper. In this electrolytic process, metal impurities such as gold,
silver, and lead are separated from the copper and settle to the bottom of the electro-refinery cells into a
sludge called “slimes”. The slimes are sent to the precious metals recovery plant for further refining. A
small amount of the electrolyte containing dissolved impurities is continuously routed to the electrolyte
purification circuit to remove excess copper.

Spent anodes and saleable cathodes are transferred via automatic guided vehicles (AGV) to the machine
and product control building (MPC). The anodes and cathodes are washed in the scrap and cathode wash
machines. The mist produced during the wash process is vented through acid mist demister pads. Natural
gas fired boilers are utilized to produce steam, which is needed to keep the electrolyte at the required 60
degrees C (140 degrees F.). The boilers utilize excess air and low NOx burners to minimize emissions.

The electrolyte purification circuit serves to control the copper concentration in electrolyte by plating out
any excess copper. A small amount of electrolyte is collected in tanks from the tank house and fed into
electrowinning cells, called the “liberator” section. Dissolved copper in this electrolyte solution is plated
out into stainless steel cathodes. The recovered copper is either sold or recycled to the smelter for product
recovery. The sulfuric acid mist that is produced during the electrowinning process is exhausted by a
ventilation system through an acid demister.

The slimes from the electro refining tanks are pumped from the tank house to the precious metals (PM)
building for precious metals recovery. The precious metals process involves a series of
hydrometallurgical steps in which metals are selectively put into solution and then precipitated out and
isolated in filter presses. The hydrometallurgical steps are: decopperization, lead production, silver
production, gold production, and selenium production.

The decopperization step is a batch process involving a reaction between slimes, sulfuric acid, and
oxygen in a small autoclave. The autoclave steam is vented through the sodium-based scrubber.
Following decopperization, the autoclave liquid is passed through a column containing copper cuttings to
extract copper telluride impurities. The column is vented through the sodium-based scrubber.

An initial separation of metals from the decopperized slimes is made with an oxidation reaction. This is
followed by filtration and a hydrochloric acid wash to separate two process streams (solid and liquid) that
are carried from this process; the solid process stream goes to lead and silver recovery; the liquid process
stream goes to selenium and gold recovery. The gold is removed from the liquid by solvent extraction.
The oxidation reaction vessels are vented into the sodium-based scrubber.

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Lead sulfate is produced by sodium carbonate leaching of solids followed by nitric acid leach. Lead
sulfate is precipitated out of the leach liquid using sulfuric acid. Solids from the nitric acid leach are
further processed for silver recovery. Exhaust from the leach and precipitation steps is vented to the
sodium-based scrubber.

Ammonium hydroxide is used to leach silver from the de-leaded solids. Ammonia used in the leach is
recovered and regenerated in a closed loop system. The leach is followed by a precipitation step in which
acid is used to precipitate the silver chloride salt. Emissions from the silver process are vented through the
acidic scrubber.

Gold is recovered through solvent extraction using dibutylcarbitol (DBC). Gold is purified from the DBC
extraction through a series of reactions using oxalic acid, sodium hydroxide, sulfuric acid, ethanol, and
ferrous chloride. The purified gold powder is melted to produce bullion. The gold recovery process is
vented through the sodium-based scrubber.

Selenium is recovered in a hydrometallurgical process. Liquid from the gold recovery circuit is treated
with SO2 to precipitate crude selenium. The crude selenium is retorted (distilled) in an electric melting
furnace. Exhaust not captured through condensation is vented through the selenium production baghouse.
After retorting and condensation, the pure selenium is crushed, sized, and packaged for shipment. The
packaging system is hooded and ventilated to a baghouse.

APPLICABLE
REGULATIONS: Title V Operating Permit 3500030004, dated 9/18/2020, last revised 9/27/2022
40 CFR 60 Subpart A-General Provisions,
40 CFR 60 Subpart Db-Standards of Performance for Industrial-Commercial-
Institutional Steam Generating Units,
40 CFR 60 Subpart Dc-Standards of Performance for Small Industrial-
Commercial-Institutional Steam Generating Units,
40 CFR 60 Subpart P-Standards of Performance for Primary Copper Smelters,
40 CFR 60 Subpart OOO-Standards of Performance for Nonmetallic Mineral
Processing Plants,
40 CFR 60 Subpart IIII-Standards of Performance for Stationary Compression
Ignition Internal Combustion Engines,
40 CFR 60 Subpart KKKK-Standards of Performance for Stationary
Combustion Turbines,
40 CFR 63 Subpart A-General Provisions,
40 CFR 63 Subpart ZZZZ-National Emission Standards for Hazardous Air
Pollutants for Stationary Reciprocating Internal Combustion Engines,
40 CFR 63 Subpart CCCCCC-National Emission Standards for Hazardous Air
Pollutants for Source Category: Gasoline Dispensing Facilities,
40 CFR 63 Subpart EEEEEE-National Emission Standards for Hazardous Air
Pollutants for Primary Copper Smelting Area Sources,
40 CFR 82 Subpart B-Servicing of Motor Vehicle Air Conditioners,
40 CFR 82 Subpart F-Recycling and Emissions Reduction,
Utah State SIP: H.1 General Conditions,
Utah State SIP: H.2.g KUC specific conditions.

SOURCE INSPECTION
EVALUATION:

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SECTION I: GENERAL PROVISIONS

I.A Federal Enforcement.

All terms and conditions in this permit, including those provisions designed to limit the potential to emit,
are enforceable by the EPA and citizens under the Clean Air Act of 1990 (CAA) except those terms and
conditions that are specifically designated as "State Requirements". (R307-415-6b)

Status: Not evaluated. This is a statement of fact and not an inspection item.

I.B Permitted Activity(ies).

Except as provided in R307-415-7b(1), the permittee may not operate except in compliance with this
permit. (See also Provision I.E, Application Shield)

Status: The permittee appeared to be operating in compliance with this permit. See status of each condition
below for details. In compliance.

I.C Duty to Comply.

I.C.1 The permittee must comply with all conditions of the operating permit. Any permit noncompliance
constitutes a violation of the Air Conservation Act and is grounds for any of the following: enforcement
action; permit termination; revocation and reissuance; modification; or denial of a permit renewal
application. (R307-415-6a(6)(a))

I.C.2 It shall not be a defense for a permittee in an enforcement action that it would have been necessary to halt
or reduce the permitted activity in order to maintain compliance with the conditions of this permit.
(R307-415-6a(6)(b))

I.C.3 The permittee shall furnish to the Director, within a reasonable time, any information that the Director
may request in writing to determine whether cause exists for modifying, revoking and reissuing, or
terminating this permit or to determine compliance with this permit. Upon request, the permittee shall also
furnish to the Director copies of records required to be kept by this permit or, for information claimed to
be confidential, the permittee may furnish such records directly to the EPA along with a claim of
confidentiality. (R307-415-6a(6)(e))

I.C.4 This permit may be modified, revoked, reopened, and reissued, or terminated for cause. The filing of a
request by the permittee for a permit modification, revocation and reissuance, or termination, or of a
notification of planned changes or anticipated noncompliance shall not stay any permit condition, except
as provided under R307-415-7f(1) for minor permit modifications. (R307-415-6a(6)(c))

Status: This permit is not being modified, revoked, reopened, reissued, or terminated for cause at this time.
The permittee appeared to be operating in compliance with this permit. In compliance.

I.D Permit Expiration and Renewal.

I.D.1 This permit is issued for a fixed term of five years and expires on the date shown under "Enforceable
Dates and Timelines" at the front of this permit. (R307-415-6a(2))

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I.D.2 Application for renewal of this permit is due on or before the date shown under "Enforceable Dates and
Timelines" at the front of this permit. An application may be submitted early for any reason.
(R307-415-5a(1)(c))

I.D.3 An application for renewal submitted after the due date listed in I.D.2 above shall be accepted for
processing, but shall not be considered a timely application and shall not relieve the permittee of any
enforcement actions resulting from submitting a late application. (R307-415-5a(5))

I.D.4 Permit expiration terminates the permittee's right to operate unless a timely and complete renewal
application is submitted consistent with R307-415-7b (see also Provision I.E, Application Shield) and
R307-415-5a(1)(c) (see also Provision I.D.2). (R307-415-7c(2))

Status: This permit was issued September 18, 2020, and will expire September 18, 2025. Application is due
March 18, 2025.

I.E Application Shield.

If the permittee submits a timely and complete application for renewal, the permittee's failure to have an
operating permit will not be a violation of R307-415, until the Director takes final action on the permit
renewal application. In such case, the terms and conditions of this permit shall remain in force until permit
renewal or denial. This protection shall cease to apply if, subsequent to the completeness determination
required pursuant to R307-415-7a(3), and as required by R307-415-5a(2), the applicant fails to submit by
the deadline specified in writing by the Director any additional information identified as being needed to
process the application. (R307-415-7b(2))

Status: This permit was issued September 18, 2020, and will expire September 18, 2025. Application is due
March 18, 2025.

I.F Severability.

In the event of a challenge to any portion of this permit, or if any portion of this permit is held invalid, the
remaining permit conditions remain valid and in force. (R307-415-6a(5))

Status: Not evaluated. This is a statement of fact and not an inspection item.

I.G Permit Fee.

I.G.1 The permittee shall pay an annual emission fee to the Director consistent with R307-415-9.
(R307-415-6a(7))

I.G.2 The emission fee shall be due on October 1 of each calendar year or 45 days after the source receives
notice of the amount of the fee, whichever is later. (R307-415-9(4)(a))

Status: Permit fees have been paid as invoiced. In compliance.

I.H No Property Rights.

This permit does not convey any property rights of any sort, or any exclusive privilege.
(R307-415-6a(6)(d))

Status: Not evaluated. This is a statement of fact and not an inspection item.
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I.I Revision Exception.

No permit revision shall be required, under any approved economic incentives, marketable permits,
emissions trading and other similar programs or processes for changes that are provided for in this permit.
(R307-415-6a(8))

Status: Not evaluated. This is a statement of fact and not an inspection item.

I.J Inspection and Entry.

I.J.1 Upon presentation of credentials and other documents as may be required by law, the permittee shall allow
the Director or an authorized representative to perform any of the following:

I.J.1.a Enter upon the permittee's premises where the source is located or emissions related activity is conducted,
or where records are kept under the conditions of this permit. (R307-415-6c(2)(a))

I.J.1.b Have access to and copy, at reasonable times, any records that must be kept under the conditions of this
permit. (R307-415-6c(2)(b))

I.J.1.c Inspect at reasonable times any facilities, equipment (including monitoring and air pollution control
equipment), practice, or operation regulated or required under this permit. (R307-415-6c(2)(c))

I.J.1.d Sample or monitor at reasonable time’s substances or parameters for the purpose of assuring compliance
with this permit or applicable requirements. (R307-415-6c(2)(d))

I.J.2 Any claims of confidentiality made on the information obtained during an inspection shall be made
pursuant to Utah Code Ann. Section 19-1-306. (R307-415-6c(2)(e))

Status: Inspection of the facility and records was allowed. No samples were taken, and no claims of
confidentiality were made. In compliance.

I.K Certification.

Any application form, report, or compliance certification submitted pursuant to this permit shall contain
certification as to its truth, accuracy, and completeness, by a responsible official as defined in R307-415-3.
This certification shall state that, based on information and belief formed after reasonable inquiry, the
statements and information in the document are true, accurate, and complete. (R307-415-5d)

Status: It appears that all applicable submittals to DAQ have contained the required certification
statement. In compliance.

I.L Compliance Certification.

I.L.1 Permittee shall submit to the Director an annual compliance certification, certifying compliance with the
terms and conditions contained in this permit, including emission limitations, standards, or work practices.
This certification shall be submitted no later than the date shown under "Enforceable Dates and Timelines"
at the front of this permit, and that date each year following until this permit expires. The certification
shall include all the following (permittee may cross-reference this permit or previous reports):
(R307-415-6c(5))

I.L.1.a The identification of each term or condition of this permit that is the basis of the certification;
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I.L.1.b The identification of the methods or other means used by the permittee for determining the compliance
status with each term and condition during the certification period. Such methods and other means shall
include, at a minimum, the monitoring and related recordkeeping and reporting requirements in this
permit. If necessary, the permittee also shall identify any other material information that must be included
in the certification to comply with section 113(c)(2) of the Act, which prohibits knowingly making a false
certification or omitting material information;

I.L.1.c The status of compliance with the terms and conditions of the permit for the period covered by the
certification, including whether compliance during the period was continuous or intermittent. The
certification shall be based on the method or means designated in Provision I.L.1.b. The certification shall
identify each deviation and take it into account in the compliance certification. The certification shall also
identify as possible exceptions to compliance any periods during which compliance is required and in
which an excursion or exceedance as defined under 40 CFR Part 64 occurred; and

I.L.1.d Such other facts as the Director may require to determine the compliance status.

I.L.2 The permittee shall also submit all compliance certifications to the EPA, Region VIII, at the following
address or to such other address as may be required by the Director: (R307-415-6c(5)(d))

Environmental Protection Agency, Region VIII
Office of Enforcement, Compliance and Environmental Justice
(mail code 8ENF)
1595 Wynkoop Street
Denver, CO 80202-1129

Status: The most recent compliance certification was received by DAQ on December 15, 2023 (due
December 15, 2022). The next certification is due December 15, 2024. Annual certifications are
reviewed in separate reports and are in main source files. In compliance.

I.M Permit Shield.

I.M.1 Compliance with the provisions of this permit shall be deemed compliance with any applicable
requirements as of the date of this permit, provided that:

I.M.1.a Such applicable requirements are included and are specifically identified in this permit, or (R307-415-
6f(1)(a))

I.M.1.b Those requirements not applicable to the source are specifically identified and listed in this permit. (R307-
415-6f(1)(b))

I.M.2 Nothing in this permit shall alter or affect any of the following:

I.M.2.a The emergency provisions of Utah Code Ann. Section 19-1-202 and Section 19-2-112, and the provisions
of the CAA Section 303. (R307-415-6f(3)(a))

I.M.2.b The liability of the owner or operator of the source for any violation of applicable requirements under
Utah Code Ann. Section 19-2-107(2)(g) and Section 19-2-110 prior to or at the time of issuance of this
permit. (R307-415-6f(3)(b)

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I.M.2.c The applicable requirements of the Acid Rain Program, consistent with the CAA Section 408(a). (R307-
415-6f(3)(c))

I.M.2.d The ability of the Director to obtain information from the source under Utah Code Ann. Section 19-2-120,
and the ability of the EPA to obtain information from the source under the CAA Section 114. (R307-415-
6f(3)(d))

Status: Permit shields are listed in Section III of this permit.

I.N Emergency Provision.

I.N.1 An "emergency" is any situation arising from sudden and reasonably unforeseeable events beyond the
control of the source, including acts of God, which situation requires immediate corrective action to
restore normal operation, and that causes the source to exceed a technology-based emission limitation
under this permit, due to unavoidable increases in emissions attributable to the emergency. An emergency
shall not include noncompliance to the extent caused by improperly designed equipment, lack of
preventive maintenance, careless or improper operation, or operator error. (R307-415-6g(1))

I.N.2 An emergency constitutes an affirmative defense to an action brought for noncompliance with such
technology-based emission limitations if the affirmative defense is demonstrated through properly signed,
contemporaneous operating logs, or other relevant evidence that:

I.N.2.a An emergency occurred and the permittee can identify the causes of the emergency. (R307-415-6g(3)(a))

I.N.2.b The permitted facility was at the time being properly operated. (R307-415-6g(3)(b))

I.N.2.c During the period of the emergency the permittee took all reasonable steps to minimize levels of emissions
that exceeded the emission standards, or other requirements in this permit. (R307-415-6g(3)(c))

I.N.2.d The permittee submitted notice of the emergency to the Director within two working days of the time
when emission limitations were exceeded due to the emergency. This notice must contain a description of
the emergency, any steps taken to mitigate emissions, and corrective actions taken. This notice fulfills the
requirement of Provision I.S.2.c below. (R307-415-6g(3)(d))

I.N.3 In any enforcement proceeding, the permittee seeking to establish the occurrence of an emergency has the
burden of proof. (R307-415-6g(4))

I.N.4 This emergency provision is in addition to any emergency or upset provision contained in any other
section of this permit. (R307-415-6g(5))

Status: The permittee has reported emergency events and all reports and DAQ reviews are in the main
source files. In compliance.

I.O Operational Flexibility.

Operational flexibility is governed by R307-415-7d(1).

Status: Not evaluated. This is a statement of fact and not an inspection item.

I.P Off-permit Changes.

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Off-permit changes are governed by R307-415-7d(2).

Status: Not evaluated. This is a statement of fact and not an inspection item.

I.Q Administrative Permit Amendments.

Administrative permit amendments are governed by R307-415-7e.

Status: Not evaluated. This is a statement of fact and not an inspection item.

I.R Permit Modifications.

Permit modifications are governed by R307-415-7f.

Status: Not evaluated. This is a statement of fact and not an inspection item.

I.S Records and Reporting.

I.S.1 Records.

I.S.1.a The records of all required monitoring data and support information shall be retained by the permittee for
a period of at least five years from the date of the monitoring sample, measurement, report, or application.
Support information includes all calibration and maintenance records, all original strip-charts or
appropriate recordings for continuous monitoring instrumentation, and copies of all reports required by
this permit. (R307-415-6a(3)(b)(ii))

I.S.1.b For all monitoring requirements described in Section II, Special Provisions, the source shall record the
following information, where applicable: (R307-415-6a(3)(b)(i))

I.S.1.b.1 The date, place as defined in this permit, and time of sampling or measurement.

I.S.1.b.2 The date analyses were performed.

I.S.1.b.3 The company or entity that performed the analyses.

I.S.1.b.4 The analytical techniques or methods used.

I.S.1.b.5 The results of such analyses.

I.S.1.b.6 The operating conditions as existing at the time of sampling or measurement.

I.S.1.c Additional record keeping requirements, if any, are described in Section II, Special Provisions.

I.S.2 Reports.

I.S.2.a Monitoring reports shall be submitted to the Director every six months, or more frequently if specified in
Section II. All instances of deviation from permit requirements shall be clearly identified in the reports.
(R307-415-6a(3)(c)(i))

I.S.2.b All reports submitted pursuant to Provision I.S.2.a shall be certified by a responsible official in accordance
with Provision I.K of this permit. (R307-415-6a(3)(c)(i)
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I.S.2.c The Director shall be notified promptly of any deviations from permit requirements including those
attributable to upset conditions as defined in this permit, the probable cause of such deviations, and any
corrective actions or preventative measures taken. Prompt, as used in this condition, shall be defined as
written notification within the number of days shown under "Enforceable Dates and Timelines" at the
front of this permit. Deviations from permit requirements due to breakdowns shall be reported in
accordance with the provisions of R307-107. (R307-415-6a(3)(c)(ii))

I.S.3 Notification Addresses.

I.S.3.a All reports, notifications, or other submissions required by this permit to be submitted to the Director are
to be sent to the following address or to such other address as may be required by the Director:

Utah Division of Air Quality
P.O. Box 144820
Salt Lake City, UT 84114-4820
Phone: [phone]

I.S.3.b All reports, notifications or other submissions required by this permit to be submitted to the EPA should
be sent to one of the following addresses or to such other address as may be required by the Director:

For annual compliance certifications:

Environmental Protection Agency, Region VIII
Office of Enforcement, Compliance and Environmental Justice
(mail code 8ENF)
1595 Wynkoop Street
Denver, CO 80202-1129

For reports, notifications, or other correspondence related to permit modifications, applications, etc.:

Environmental Protection Agency, Region VIII
Air Permitting and Monitoring Branch (mail code 8ARD-PM)
1595 Wynkoop Street
Denver, CO 80202-1129
Phone: [phone]

Status: Records have been maintained as required by this condition. Monitoring reports have been
submitted to the Executive Secretary every six months. Deviations have been reported as required.
The company is required to submit multiple monthly records per multiple permit conditions.
Reports are in the main source files. In compliance.

I.T Reopening for Cause.

I.T.1 A permit shall be reopened and revised under any of the following circumstances:

I.T.1.a New applicable requirements become applicable to the permittee and there is a remaining permit term of
three or more years. No such reopening is required if the effective date of the requirement is later than the
date on which this permit is due to expire, unless the terms and conditions of this permit have been
extended pursuant to R307-415-7c(3), application shield. (R307-415-7g(1)(a))

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I.T.1.b The Director or EPA determines that this permit contains a material mistake or that inaccurate statements
were made in establishing the emissions standards or other terms or conditions of this permit. (R307-415-
7g(1)(c))

I.T.1.c EPA or the Director determines that this permit must be revised or revoked to assure compliance with
applicable requirements. (R307-415-7g(1)(d))

I.T.1.d Additional applicable requirements are to become effective before the renewal date of this permit and are
in conflict with existing permit conditions. (R307-415-7g(1)(e))

I.T.2 Additional requirements, including excess emissions requirements, become applicable to a Title IV
affected source under the Acid Rain Program. Upon approval by EPA, excess emissions offset plans shall
be deemed to be incorporated into this permit. (R307-415-7g(1)(b))

I.T.3 Proceedings to reopen and issue a permit shall follow the same procedures as apply to initial permit
issuance and shall affect only those parts of this permit for which cause to reopen exists. (R307-415-7g(2))

Status: Not evaluated. This is a statement of fact and not an inspection item.

I.U Inventory Requirements.

An emission inventory shall be submitted in accordance with the procedures of R307-150, Emission
Inventories. (R307-150)

Status: Emission inventories have been submitted as required. In compliance.

I.V Title IV and Other, More Stringent Requirements

Where an applicable requirement is more stringent than an applicable requirement of regulations
promulgated under Title IV of the Act, Acid Deposition Control, both provisions shall be incorporated
into this permit. (R307-415-6a(1)(b))

Status: Not evaluated. This is a statement of fact and not an inspection item.

SECTION II: SPECIAL PROVISIONS

II.A Emission Unit(s) Permitted to Discharge Air Contaminants.
(R307-415-4(3)(a) and R307-415-4(4))

II.A.1 Permitted Source
Source-wide

II.A.2 #Smelter:
Smelter Operations

II.A.3 #SME 001: Filter Plant Wet Feed Conveyor (Stack 1)
Wet copper concentrate filter cake is transferred from the filter plant along an enclosed conveyor system
directly to the feed storage building. The conveyor and transfer points are vented to a baghouse.

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II.A.4 #SME 002: Wet Feed Storage Building (Stack 2)
Wet copper concentrate feed is stored in the enclosed wet feed storage building. Particulate emissions
from loading materials into the feed storage building, from reclaiming materials, and from
conveyor/transfer point SME 002-A are vented to a baghouse. Also located adjacent to the building: one
hopper (vents to the atmosphere) and conveyors equipped with water sprays.

II.A.5 #SME 003: Wet Feed Conveyor Transfer Point (Stack 3)
Copper concentrate reclaimed from the storage building is delivered to a loading bin by two enclosed
conveyors. Particulate emissions from the transfer point of wet feed from one belt to the other are
controlled by a baghouse.

II.A.6 #SME 002-A: Partially Enclosed Wet Feed Hopper
Copper concentrate is loaded into a hopper located outside the wet feed storage building. The hopper is
partially enclosed by a roof and 3 sides. The enclosed conveyor and transfer point are ducted to the wet
feed storage building baghouse.

II.A.7 #SME 004: Wet Feed Bins (Stack 4)
Silica flux, concentrate, and converter slag are transferred directly to feed bins then conveyed to the dryer.
Particulate emissions from the loading of wet flux & concentrate and from transfer points of the conveyor
are vented to a baghouse. Also located within the building: two storage bins (each bin is equipped with a
bin vent that vents inside the building).

II.A.8 #SME 005: Flash Smelting Furnace Dry Feed Bin (Stack 5)
Product leaving the concentrate rotary dryer is delivered in an enclosed pneumatic transfer to the flash
smelting furnace (FSF) feed bin. Dry feed bin loading, bin discharge points, and chain conveyors are
vented to a baghouse.

II.A.9 #SME 011e: Rotary Dryer
Feed for the flash smelting furnace is dried in a natural gas fired rotary dryer. The dryer uses low NOx
burners. Dryer off gas is vented through a baghouse, an alkaline scrubber, and then vented to the main
stack.

II.A.10 #SME 011b1: Flash Smelting Furnace (FSF)
Copper concentrate & flux with oxygen are fed into the flash smelting furnace to produce molten
products. The process gas is exhausted to a waste heat boiler, ESP, wet scrubber, then to a wet ESP &
acid plant also used by FCF, & then vented to the main stack. One diesel-fired emergency generator with
a maximum rating of 998 Hp used for emergency powering of the waste heat boiler. The generator has a
displacement of less than 10 liters per cylinder and is equipped with a turbo charger and after cooling. 40
CFR 60 Subpart IIII applies to the emergency generator.

II.A.11 #SME SLAG: Slag Concentrator
Slag from the FSF or FCF is delivered to slag pots, cooled, crushed, and transferred to the slag mill or
stockpiled. Fugitive emissions from the crusher and conveyor transfer points are controlled by water
sprays. Unit also includes a crushing and screening operation for slag material and nonmetallic mineral
material that cannot be handled by the slag mill. This crushing and screening operation includes: 3
crushers (jaw, cone, fines), each crusher 600 tph max capacity, screens, and conveyors with partially
enclosed transfer points equipped with water sprays.

II.A.12 #SME 011g: Matte Drying and Grinding Plant
Grinds and dries wet granulated matte copper. Warmed air is blown through the mill to dry the matte.
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Ground matte is separated from the drying air by a baghouse. Cleaned air is discharged to the main stack
and matte conveyed to a bin.

II.A.13 #SME 006: Smelter Limestone Flux Bin (Stack 6)
Dry lime or limestone flux for use in the converting process is delivered to the smelter and pneumatically
conveyed from an enclosed delivery truck to the limestone storage bin. Displaced air from the loading of
the bin is vented to a baghouse.

II.A.14 #SME 013: Dry Matte Bin (Stack 13)
Dry ground matte is conveyed by pneumatic pipeline from the matte grinding plant to the dry matte bin.
Particulate emissions from the loading of the dry matte bin are controlled by a baghouse.

II.A.15 #SME 011b2: Flash Converting Furnace (FCF)
Ground copper matte & flux with oxygen are fed into the flash converting furnace to produce molten
product (blister). The process gas is exhausted to a waste heat boiler, ESP, wet scrubber, then to a wet
ESP & acid plant also used by FSF, & then vented to the main stack.

II.A.16 #SME FSF/FCF: Flash Smelting & Converting Combined
Identical conditions on Flash Smelting Furnace (SME 011b1) and Flash Converting Furnace (SME
011b2). Unit also includes a co-jet technology burner system (SME 011b3) consisting of three natural
gas/oxy-fuel fired co-jet injectors rated at 13 MMBtu/hr each. The burners remove copper slag or other
build-up that negatively impacts the integrity of the FSF or FCF.

II.A.17 #SME 011a: Secondary Gas System
Hoods over launders, slag pot filling stations, matte and slag granulation tanks, FSF & FCF tapholes, FSF
VCS, directed to secondary gas baghouse (w/ lime injection system), secondary gas scrubbers (reverse jet
scrubbers A, B), then to main stack. FSF & FCF gases may be directed to this system during shutdown.

II.A.18 #SME 011a1: Matte Granulation Exhaust Scrubbers
Molten matte from the FSF is granulated with water in two separate granulation tanks, the North and
South Matte Granulators. Each granulator is equipped with a three stage impingement plate scrubber and
demister pads. Emissions are directed to the scrubber and then to the secondary gas system.

II.A.19 #SME 010: Slag Granulation Exhaust Scrubber (Stack 10)
Converter slag from the FCF is granulated with water in a separate granulation tank. The granulator is
equipped with a three stage impingement plate scrubber. Emissions are either directed a) to the scrubber
and then to the atmosphere through the vent stack or b) to the scrubber and then to the secondary gas
system.

II.A.20 #SME 011a2: Slag Pot Filling Stations
Slag from the FSF and FCF is laundered into slag pots. Emissions are captured by hoods and directed to
the secondary gas system.

II.A.21 #SME 011h1: Anode Refining Furnaces (2)
Blister copper produced in the FCF is laundered to one of two anode furnaces. The anode furnaces are
natural gas fired with oxyfuel burners. Optional co-jet lances used for material heating and melting on a
non-continuous basis. Off-gas is vented (in series) to quench tower, lime injection, baghouse, & two
scrubbers, then to the main stack.

II.A.22 #SME 029: Secondary Gas System Lime Silo (Stack 29)
Secondary gas system lime silo with bin vent baghouse.
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II.A.23 #SME 011h4: Anode Casting Wheels
Anode copper is cast in one of two circular casting wheels. Casting wheel cooling is hooded to collect
steam. Casting wheel emissions are vented to a quench tower then to the main stack.

II.A.24 #SME 028: Anode Area Lime Silo (Stack 28)
Lime silo with bin vent baghouse.

II.A.25 #SME MOLD: Mold Casting Unit
A small natural gas fired mold casting unit is operated to support casting wheel maintenance. Any
emissions from this unit would be fugitive.

II.A.26 #SME 011h2: Anode Shaft Furnace
The shaft furnace melts rejected copper anodes and anode scrap from the refinery. The melted copper is
then recast into new anodes. Exhaust gases from the shaft furnace are quenched then cleaned in a
baghouse then discharged to the main stack. The baghouse also controls emissions from the anode
holding furnace.

II.A.27 #SME 011h3: Anode Holding Furnace
Molten copper from the shaft furnace is transferred to a holding furnace. Ventilation gases from the
holding furnace join the other anode gases before being ducted to a baghouse and then to the main stack.
The baghouse also controls emissions from the anode shaft furnace.

II.A.28 #SME 011h: Anode Area
The anode area consists of the two anode refining furnaces (SME 011h1), the shaft furnace (SME 011h2),
the anode holding furnace (SME 011h3), and the casting wheels (SME 011h4). Gases from these units are
ducted together then ducted to the main stack.

II.A.29 #SME ROOF: Hot Metals Building Roof Vents
Emissions not captured by the primary or secondary gas systems in the hot metals building, including the
dryer area, FSF & FCF area, and the anode area, are ventilated to the atmosphere through roof vents.

II.A.30 #SME 015: Mold Coating (Barite) Bin (Stack 15)
Barium sulfate (Barite) is delivered to the smelter in enclosed delivery trucks and pneumatically conveyed
to a storage bin. Displaced air from bin loading is vented to a baghouse.

II.A.31 #SME 008: Acid Plant Preheater (Stack 8)
The acid plant is brought up to proper temperature with a preheater. The preheater is natural gas fired and
equipped with a low NOx burner. Exhaust from the preheater is vented to the atmosphere through its own
stack.

II.A.32 #SME 011b: Acid Plant
Double contact acid plant for removal of sulfur dioxide from the off-gases of the FSF and FCF. Produced
sulfuric acid is sold. The system is equipped with tubular candle fiber mist eliminators and the tail gas
discharges to the main stack.

II.A.33 #SME GLCS: Acid Plant Process Gas Leak Collection System
Adjustable negative pressure ductwork and collection hoses placed as needed to control the opacity of
leaks of SO2, SO3, or other process gas emissions that do not pass through a stack at the acid plant.

15
II.A.34 #SME 019: Hydrometallurgical Plant Limestone Bin (Stack 19)
Limestone used in the hydrometallurgical plant is pneumatically conveyed from delivery trucks to a
storage bin. Displaced air from bin loading is vented to a baghouse.

II.A.35 #SME 020: Hydrometallurgical Plant Lime Bin (Stack 20)
Lime used in the hydrometallurgical plant is pneumatically conveyed from delivery trucks to a storage
bin. Displaced air from bin loading is vented to a baghouse.

II.A.36 #SME 011d: Hydrometallurgical Plant
ESP dust from FSF & FCF, discharge from wet scrubbers, and decopperized refinery solutions are
slurried to the hydromet plant for processing metals. The hydromet plant has 2 dedicated alkaline
scrubbers that discharge to the main stack.

II.A.37 #SME 030: Powerhouse Rentech Boiler
The natural gas-fired Rentech boiler (#SME 030), rated at 183 MMBtu/hr, is equipped with a low-NOx
burner and flue gas recirculation (FGR) and produces superheated steam to start the smelter, drive acid
plant compressors, and for standby power. Combustion emissions from the Rentech boiler are discharged
from the boiler stack. The Rentech boiler and Holman boiler operate in tandem to produce steam for
smelter operations.

II.A.38 #SME 026: Powerhouse Holman Boiler (Stack 26)
The natural gas-fired Holman boiler (#SME 026), rated at 187 MMBtu/hr, is equipped with low NOx
burners and flue gas recirculation and produces process steam for the smelter. Combustion emissions
from the Holman boiler are discharged from the boiler stack. The Rentech boiler and Holman boiler
operate in tandem to produce steam for smelter operations.

II.A.39 #SME 011: Main Stack (Stack 11)
Gases from the acid plant, secondary gas system, rotary dryer, powerhouse superheater, matte grinding
plant, anode area, and hydrometallurgical plant are vented to the smelter main stack.

II.A.40 #SME 027: Recycle Crushing and Storage Building (Stack 27)
Waste heat boiler & electrostatic precipitator dust, dry pond sediment, and other materials are crushed and
agglomerated in a pelletizer, then stored in a building for reprocessing through the smelter. A furnace dust
crusher system, 12 ton/hr capacity, is also included in this unit. The building and processes are vented to a
baghouse.

II.A.41 #SME PH: Powerhouse
The natural gas-fired superheater (#SME 011f) rated at 45 MMBtu/hr, is equipped with ultra low NOx
burners, heats steam from FSF & FCF waste heat boilers, and vents to the main stack. This unit also
includes the Rentech boiler (#SME 030) and the Holman boiler (#SME 026).

II.A.42 #SME NG: Pyrometallurgical Process Group
Natural gas consumption is limited for total combined consumption in the following units: anode area
(SME 011h), mold casting furnace (SME MOLD), launder heaters (SME 011b1-FSF, SME 011b2-FCF,
SME 011b3-Co-jet burner system), matte grinding plant (SME 011g), and rotary concentrate dryer (SME
011e).

II.A.43 #SME 022: Smelter Laboratory Sample Preparation (Stack 22)
Samples of concentrate, matte, slag, etc. are crushed in preparation for laboratory analysis. The
Laboratory crushers are vented through a baghouse.

16
II.A.44 #SME 017a, c: Vacuum Cleaning Systems (Stacks 17a, 17c)
3 vacuum cleaning systems (VCS) with remote pickups are used to vacuum up spilled concentrate, feed
mix, ground matte, etc. The matte handling VCS and FCF VCS (17a & 17c) vent through separate
baghouses & discharge through separate stacks. The FSF VCS ducts to the secondary gas system (SME
011a).

II.A.45 #SME SA-1: Smelter Unleaded Gasoline Storage Tank
10,000-gallon capacity above ground unleaded gasoline storage tank. The gasoline is delivered to the tank
by bulk truck and is dispensed to light duty vehicles as needed. Throughput is less than 10,000 gallons per
month.

II.A.46 #SMEi210: Smelter Cold Solvent Degreasers
Organic solvent is used in degreasing tanks for small parts washing. The cold solvent degreasers have a
total throughput of approximately 300 gallons solvent per year.

II.A.47 #SME GEN: Smelter Powerhouse Emergency Generators
Two #2 diesel fired emergency generators, rated at 2,847 hp each, capable of operating essential
equipment (such as pumps and fans) for preventing damage in the event of a power outage. 40 CFR 63
Subpart ZZZZ applies to these units.

II.A.48 #SME CT311, 316, 321: Smelter Cooling Towers
Three cooling towers serve the acid plant, powerhouse, and granulators, respectively. No unit-specific
applicable requirements.

II.A.49 #SME SH, WH: Space Heaters and Water Heaters
Numerous small natural gas fired space heaters and water heaters. No unit-specific applicable
requirements.

II.A.50 #SME STRG: Storage Piles
Concentrate, granulated matte, slag, and other materials are stored in outdoor storage piles on pads.

II.A.51 #SME COM GEN: Emergency Generator - Communications
One liquid propane fired emergency generator with a maximum rating of 75 horsepower used for
emergency powering of the smelter communication systems during primary power supply outages.

II.A.52 #Refinery:
Refinery Operations

II.A.53 #REF TH: Electrolytic Refining Tanks
Copper anodes produced at the smelter are immersed in heated electrolyte, a solution of sulfuric acid and
copper sulfate, in polymer concrete tanks in the tankhouse building. Copper cathodes are produced by an
electrolytic refining process.

II.A.54 #REF 001: Electrolyte Purification Liberator
A small amount of electrolyte is circulated from the electrolytic tanks to the liberator electrowinning
process, used to control concentration of copper in solution. The electrolyte purification demister pad
collects mist emitted from the liberator.

II.A.55 #REF 002/003: Refinery Boilers (Tankhouse)
Two boilers (north, south) capable of burning natural gas as primary fuel and #2 fuel oil as backup fuel
17
generate steam to heat electrolyte solution. The north boiler has been decommissioned. The south boiler is
rated at 85 MMBtu/hr on natural gas (82 MMBtu/hr on oil).

II.A.56 #REF 004: Cathode Wash
Cathodes are transported from the tankhouse by transfer cars to the machine and product control building
(MPC) where they are washed. Acid mist produced is collected through local hooding and passed through
demister pads.

II.A.57 #REF 005: Anode Scrap Wash
Spent anodes are transported from the tankhouse by transfer cars to the machine and product control
building (MPC) where they are washed. Acid mist produced is collected through local hooding and
passed through demister pads.

II.A.58 #REF 006: Hydrometallurgical Precious Metals Recovery
Gold, silver, selenium, copper telluride, and lead salts are recovered in a series of hydrometallurgical
processes. Acidic gases from the processes are collected, scrubbed with a soda ash solution, and
exhausted through the sodium based scrubber. No emissions are associated with the copper telluride
(tellurium) recovery process.

II.A.59 #REF 011: Soda Ash Silo
Soda ash for feeding sodium based scrubber is stored in a silo. Air displaced in the silo during soda ash
loading is passed through a baghouse.

II.A.60 #REF 007: Hydrometallurgical Silver Production
Ammonium hydroxide is used to leach silver from a solid mixture. Ammonia is recovered and
regenerated in a closed loop system. H2SO4 is used to precipitate the silver chloride salt. Ammonia vapor
from this process is ducted to an acidic scrubber.

II.A.61 #REF 008: Precious Metals Filter Presses
Product lead carbonate and crude selenium are dewatered in filter presses, which are vented during
emptying and cleaning through the precious metals filter press baghouse.

II.A.62 #REF 009: Selenium Crushing and Packaging
Either Purified (retorted and condensed) selenium is crushed, sized, and packaged for shipment or filtered
crude selenium is packaged for shipment. This system vents to a baghouse.

II.A.63 #REF 010: Gold/Silver Recovery
Following leaching and solvent extraction processes, gold and silver are melted in furnaces to produce
bullion. Emissions from drying of precious metals sands and from metals volatilized during melting
processes are vented to a baghouse.

II.A.64 Emergency Generators - Precious Metals
One #2 diesel fired emergency generator (#REFi 210), maximum rating of 487.5 hp, used for emergency
powering of the refinery precious metals plant. 40 CFR 63 Subpart ZZZZ applies to this engine. This unit
also includes one natural gas-fired emergency generator (#2), maximum rating of 150 kW (201 hp),
subject to the requirements in 40 CFR 60 Subpart JJJJ.

II.A.65 #REF PREP: Refinery Laboratory Sample Preparation
A laboratory induction furnace is hooded and vented inside the Machine and Product Control (MPC)
building. No unit-specific applicable requirements.

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II.A.66 #REF SA-1: Refinery Unleaded Gasoline Storage Tank
2,500-gallon capacity above ground unleaded gasoline storage tank with approximately 12,800 gallons
throughput per year. The gasoline is delivered to the storage tank by bulk truck and is dispensed to light
duty vehicles as required. Throughput is less than 10,000 gallons per month.

II.A.67 #REF VOL: Refinery Volatile Organic Liquid Storage Tanks
Two 37,000 gallon and one 500 gallon fuel oil storage tanks located in the refinery area. No unit-specific
applicable requirements.

II.A.68 #REFi 201: Refinery Cold Solvent Degreasers
Organic solvent is used in degreasing tanks for small parts washing. The cold solvent degreasers have a
total throughput of approximately 25 gallons solvent per year.

II.A.69 #REFi 202: Refinery Paint Shop
Paint shop surface coating with organic solvent evaporation from stripping. Annual usage equals
approximately 23 gallons per year of paint primer & 106 gallons per year of paint. No unit-specific
applicable requirements.

II.A.70 #REFi204, 205, 206, 207, 208: Miscellaneous Natural Gas-fired Equipment
Various natural gas-fired water heaters or comfort heaters that are each individually rated at less than 5
MMBTU/hr are located throughout the refinery. No unit-specific applicable requirements.

II.A.71 #REF CT 001, 002: Refinery Cooling Towers
Two water cooling towers are in operation at the refinery. No unit-specific applicable requirements.

II.A.72 #REF COM GEN: Emergency Generator - Communications
One liquefied petroleum gas (LPG) fired emergency generator with a maximum rating of 75 brake
horsepower used for emergency powering of the refinery communication systems during primary power
supply outages.

II.A.73 #REF CHP: Refinery Combined Heat and Power Unit
One natural gas fired axial turbine, with a turbine electric generator (TEG); one natural gas fired
supplemental duct burner, and one heat recovery steam generator. Operating Mode Ratings: 100
MMBtu/hr (LHV) and 110.3 MMBtu/hr (HHV) for TEG firing and 45 MMBtu/hr (LHV) and 49.9
MMBtu/hr (HHV) for fresh air firing. The natural gas firing the turbine and duct burner shall meet the
definition in 40 CFR 60.4420.

Status: No unapproved equipment was observed onsite. A13 removed from site, A18- vents to 2nd gas
system and main stack. A22 is inactive but will remain on permit. A44- none of the three units are
still operating due to changes in operations. In compliance.

II.B Requirements and Limitations

The following emission limitations, standards, and operational limitations apply to the permitted facility as
indicated:

II.B.1 Conditions on Smelter: Smelter Operations.

II.B.1.a Condition:

19
At all times, including periods of startup, shutdown, and malfunction, the permittee shall maintain and
operate any permitted plant equipment, including associated air pollution control equipment, and monitoring
equipment in a manner consistent with good air pollution control practices 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 installations
and facilities authorized by this permit shall be adequately and properly maintained. Maintenance records
shall be maintained while the plant is in operation. All pollution control equipment shall be installed,
maintained, and operated properly. Instructions from the vendor or established maintenance practices that
maximize pollution control shall be followed. All necessary equipment control and operating devices, such
as pressure gauges, amp meters, volt meters, flow rate indicators, temperature gauges, continuous emissions
monitoring systems, etc., shall be installed, operated properly and easily accessible to compliance inspectors.
A copy of all manufacturers' operating instructions for pollution control equipment and pollution emitting
equipment shall be kept on site. These instructions shall be available to all employees who operate the
equipment and shall be made available to compliance inspectors upon request. Maintenance records shall be
made available to the Director or Director's representative upon request. [Origin: DAQE-AN103460061-22,
SIP Section IX.H.2.i, SIP Section IX.H.12.j]. [40 CFR 63 Subpart EEEEEE, R307-401-8, SIP Section
IX.H.12.j, SIP Section IX.H.2.i]

II.B.1.a.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.a.2 Recordkeeping:

Permittee shall document activities performed to assure proper operation and maintenance of the air
pollution control equipment and monitoring systems or devices. Records shall be maintained in
accordance with Provision I.S.1 of this permit.

II.B.1.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: The facility appeared to be well maintained. Records are being kept showing operating and
maintenance procedures and logs. A preventative maintenance plan is in place and is tracked along
with as needed maintenance through work orders entered into an electronic “SAP” system. In
compliance.

II.B.1.b Condition:

The permittee shall comply with the applicable requirements for servicing of motor vehicle air conditioners
pursuant to 40 CFR 82, Subpart B - Servicing of Motor Vehicle Air Conditioners. [Origin: 40 CFR 82]. [40
CFR 82.30(b)]

II.B.1.b.1 Monitoring:

The permittee shall certify, in the annual compliance statement required in Section I of this permit,
its compliance status with the requirements of 40 CFR 82, Subpart B.

II.B.1.b.2 Recordkeeping:
20

All records required in 40 CFR 82, Subpart B shall be maintained consistent with the requirements
of Provision S.1 in Section I of this permit.

II.B.1.b.3 Reporting:

All reports required in 40 CFR 82, Subpart B shall be submitted as required. There are no additional
reporting requirements except as outlined in Section I of this permit.

Status: KUC certified compliance with this condition in the most recent annual compliance certification. This
is not a delegated subpart. In compliance.

II.B.1.c Condition:

The permittee shall comply with the applicable requirements for recycling and emission reduction for class I
and class II refrigerants pursuant to 40 CFR 82, Subpart F - Recycling and Emissions Reduction. [Origin: 40
CFR 82]. [40 CFR 82.150(b)]

II.B.1.c.1 Monitoring:

The permittee shall certify, in the annual compliance statement required in Section I of this permit,
its compliance status with the requirements of 40 CFR 82, Subpart F.

II.B.1.c.2 Recordkeeping:

All records required in 40 CFR 82, Subpart F shall be maintained consistent with the requirements
of Provision S.1 in Section I of this permit.

II.B.1.c.3 Reporting:

All reports required in 40 CFR 82, Subpart F shall be submitted as required. There are no additional
reporting requirements except as outlined in Section I of this permit.

Status: KUC certified compliance with this condition in the most recent annual compliance certification. This
is not a delegated subpart. In compliance.

II.B.1.d Condition:

Visible emissions shall be no greater than 20 percent opacity unless otherwise specified in this permit.
[Origin: R307-305-3, DAQE-AN103460061-22]. [R307-305-3, R307-401-8]

II.B.1.d.1 Monitoring:

A visual opacity survey of each affected emission unit shall be performed on a weekly basis by an
individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. The
individual is not required to be a certified visible emissions observer. If any visible emissions other
than steam are observed, an opacity determination of that emission unit shall be performed by a
certified visible emissions observer in accordance with 40 CFR 60, Appendix A, Method 9, or other
EPA-approved testing method, as acceptable to the Director, within 24 hours of the initial
observation. For each affected emission unit, if no visible emissions are observed for eight
consecutive weeks the observation frequency shall be reduced to a monthly basis. If visible
21
emissions are observed during any monthly observation the frequency shall revert to a weekly basis.

Minor natural gas combustion sources (<5 MMBtu/hr), cold solvent degreasers, organic liquid
storage tanks (<19,812 gallons), cooling towers, and units equipped with a continuous opacity
monitor are not affected emission units subject to this condition.

II.B.1.d.2 Recordkeeping:

A log of the visual opacity survey(s) shall be maintained in accordance with Provision I.S.1 of this
permit. If an opacity determination is indicated, a notation of the determination shall be made in the
log. All data required by 40 CFR 60, Appendix A, Method 9, or other EPA-approved testing
method, as acceptable to the Director, shall also be maintained in accordance with Provision I.S.1 of
this permit.

II.B.1.d.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: KUC maintains a logbook with all visible emission units and weekly surveys. This logbook was
reviewed during inspection and appeared to be complete. KUC uses the weekly-to-monthly skip
monitoring provision and enters all data into a spreadsheet to track whether a point source is on the
weekly or monthly schedule. The site has two forms each for Smelter and Refinery: 1 for specific
listed sources and one for other sources such as storage piles. No excess visible emissions were noted at
any point during either inspection or any stack tests. The initial readings are done by contractor
(Jacobs Engineering) and then submitted to be included on the compliance section spreadsheets. The
contractor is Method 9 certified and review of VEO sheets show proper method and annotation of
readings. Review of the tracking spreadsheets show all points are included. In Compliance.

II.B.1.e Condition:

The permittee shall only combust diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) that meets the
definition of ultra-low sulfur diesel (ULSD), which has a sulfur content of 15 ppm or less. [Origin: DAQE-
AN103460061-22]. [R307-203-1, R307-401-8]

II.B.1.e.1 Monitoring:

Compliance with this limitation shall be demonstrated either by testing each fuel delivery for the
sulfur content or by inspection of the fuel sulfur-content certifications provided by the diesel fuel
supplier in purchase records. Sulfur content in either instance shall be determined in accordance
with ASTM-4294, or equivalent. Records required for this permit condition will also serve as
monitoring.

II.B.1.e.2 Recordkeeping:

The permittee shall maintain records that demonstrate compliance with the limitation. Records of
diesel fuel purchase invoices that indicate the diesel fuel meets the ULSD requirements, fuel
supplier certifications of sulfur content, or records of sulfur content testing shall be maintained in
accordance with Provision I.S.1 of this permit.

II.B.1.e.3 Reporting:
22

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: KUC receives ultralow sulfur diesel from Sinclair. All fuel deliveries come out of the Pioneer Pipeline
and delivery tickets show ULS fuel delivered. This type of fuel meets the listed requirement. In
compliance.

II.B.1.f Condition:

The permittee shall use natural gas as a primary fuel and propane as back-up fuel in the following smelter
operations: acid plant preheater, anode plant (including shaft furnace, anode furnaces, holding furnaces, and
mold furnace), launder heaters, matte grinding and concentrate drying. The propane shall only be used
during periods of natural gas curtailment. Natural gas curtailment is defined as any period when the natural
gas provider/supplier imposes an interruption of service, and the curtailment is involuntary and beyond the
control of the permittee. [Origin: DAQE-AN103460061-22]. [R307-401-8]

II.B.1.f.1 Monitoring:

The backup fuel shall be monitored by use of level sensors in the tanks, which shall be observed
following each use of backup fuel.

II.B.1.f.2 Recordkeeping:

The permittee shall maintain records that document the reason for backup fuel usage (i.e. natural gas
curtailment, maintenance, etc.), date, and duration. All readings required to be taken shall be
documented and maintained consistent with the requirements of Provision S.1 in Section I of this
permit.

II.B.1.f.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Natural gas is the primary source of fuel used at the source. The propane farm can be used during
curtailment but only has enough fuel to keep units in hot standby. The last listed curtailment (less
than two hours) occurred on 1 January 2017. Logs were maintained of time and no excess emissions
were noted. The propane units have levels and pressure sensors to determine fuel use as needed. In
compliance.

II.B.1.g Condition:

The permittee shall implement a fugitive dust control plan that has been approved by the director. Activities
regulated by R307-309 shall not commence before the fugitive dust control plan is approved by the director.
The plan shall include the minimum fugitive dust control plan requirements in R307-309-6(4), as applicable,
and the information required in R307-309-6(5). Natural sources of dust and fugitive emissions are not
fugitive dust within the meaning of this condition. [Origin: DAQE-AN103460061-22, R307-309-6]. [R307-
309-6, R307-401-8]

II.B.1.g.1 Monitoring:

23
Adherence to the most recently approved fugitive dust control plan shall be monitored to
demonstrate that appropriate measures are being implemented to control fugitive dust.

II.B.1.g.2 Recordkeeping:

Records that demonstrate compliance with this condition and records required by the most recently
approved fugitive dust control plan shall be maintained in accordance with the plan and section I.S.1
of this permit.

II.B.1.g.3 Reporting:

If site modifications that result in changes to fugitive dust emissions are made, an updated fugitive
dust control plan shall be submitted as required by R307-309-6(3). There are no additional reporting
requirements for this provision except those specified in Section I of this permit.

Status: Material hauling areas are all paved. Water trucks are active daily, and sweeping is performed on an
as needed basis. Fugitive dust was not observed during the inspection. Daily monitoring of the storage
piles is conducted by the operations group. A fugitive dust control plan was submitted, through the
web-based system, on May 8, 2018, for the smelter. The refinery FDCP was submitted on the web-
based system December 19, 2013. The web-based system includes all required items from state and
federal rules. The current plan is in effect. In compliance.

II.B.1.h Condition:

All roads, permanent parking lots, and service yards directly servicing the permittee's approved constructed
installations listed as emission units II.A.2 through II.A.51, with the exception of II.A.49 and II.A.50, shall
be paved. The permittee shall comply with the fugitive dust requirements and work practices contained in
R307-309-7 and R307-309-9, as applicable. [Origin: DAQE-AN103460061-22, R307-309]. [R307-309-7,
R307-309-9, R307-401-8]

II.B.1.h.1 Monitoring:

Adherence to the most recently approved fugitive dust control plan shall be monitored to
demonstrate that appropriate measures are being implemented to control fugitive dust.

II.B.1.h.2 Recordkeeping:

Records that demonstrate compliance with this condition and records required by the most recently
approved fugitive dust control plan shall be maintained in accordance with the plan and section I.S.1
of this permit.

II.B.1.h.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: All areas listed above were paved. Kennecott is following a fugitive dust control plan as described in
“Status” under Condition II.B.1.g above. In compliance.

II.B.1.i Condition:

24
Pressure drops and liquid flow rates for each scrubber listed below shall be maintained within the given
ranges. (All pressure drop readings in inches Water Gauge)

SME 011d - Hydrometallurgical Plant Scrubber:
Model # 480 - Pressure Drop = 5" - 10" Liquid Flow Rate = greater than 50 gpm
Model # 575 - Pressure Drop = 6" - 12" Liquid Flow Rate = greater than 40 gpm

SME 011a - Secondary Gas System (2 scrubbers):
Pressure Drop = 3.5" minimum (across both scrubbers combined) Liquid Flow Rate = greater than 4800
gpm (each)

SME 011e - Rotary Dryer Scrubber:
Pressure Drop = 5" - 19.25" Liquid Flow Rate = greater than 7360 gpm

SME 011h1 - Anode Refining Furnaces Scrubber:
Pressure Drop = 18" - 50.5" Liquid Flow Rate = greater than 2000 gpm.
[Origin: DAQE-AN103460061-22]. [R307-401-8]

II.B.1.i.1 Monitoring:

The permittee shall make at least one pressure drop and one liquid flow observation each week for
each scrubber listed above that has operated during the week. The pressure drop reading shall be
made to the nearest 1/4 inch W.G. and the liquid flow reading shall be made to within +/- 10 percent
of maximum scrubber flow rate. The observation shall be made during typical operating conditions.
The instrument(s) shall be calibrated in accordance with manufacturer's instructions. Additionally,
the pressure drop and liquid flow rate for each scrubber shall be observed and recorded at the time
of any compliance stack testing. If the pressure drop or liquid flow rate is outside of the listed
ranges, the permittee shall initiate corrective action and perform daily pressure drop and/or liquid
flow observations until the scrubber is operating within the listed ranges. If the pressure drop or the
liquid flow rate remains outside of the listed ranges for greater than 48 operating hours from the
initial out of range reading it shall be considered a deviation from this permit term.

II.B.1.i.2 Recordkeeping:

The permittee shall record at least one pressure drop and one liquid flow observation each week for
each scrubber listed above that has operated during the week. If the pressure drop or liquid flow rate
is outside of the listed ranges, the permittee shall record the pressure drop and/or liquid flow
observations daily until the scrubber is operating within the listed ranges. Records shall be
maintained in accordance with Provision I.S.1 of this permit.

II.B.1.i.3 Reporting:

The permittee shall report the following on a quarterly basis:
a) Periods when the weekly pressure drop and/or liquid flow observations trigger daily
observations, and
b) Periods when the pressure drop and/or liquid flow observations are outside the listed ranges for
greater than 48 operating hours from the initial deviation reading.
There are no additional reporting requirements for this provision except those specified in Section I
of this permit.
25

The quarterly reports are considered prompt notification of permit deviations required in Provision
I.S.2.c of this permit if all information required by Provision I.S.2.c is included in the report.

Status: Reports are submitted, as necessary. Pressure drops and liquid flow rates are tracked electronically
and can be read from the computer system. Trend lines show that each scrubber appeared to be
maintained within the required ranges. Calibration records are also online and can be seen from the
computer system. Pressure drops and flow readings are made weekly from the tracking system and
recorded for reporting purposes. Any reading showing outside of range is marked as red and work
orders are done to recall or repair. Pressure drops and flow rate readings at the time of the inspection
were as follows:

SME 011d - Hydrometallurgical Plant Scrubber:
Model # 480 - Pressure Drop = 7.2" Last Calibration 04/11/2023
Liquid Flow Rate = 78.5 gpm. Last Calibration 04/11/2024
Model # 575 - Pressure Drop = 10.8" Last Calibration 04/11/2023
Liquid Flow Rate = 65.7 gpm. Last Calibration 10/11/23

SME 011a - Secondary Gas System (2 scrubbers): Unit A and B: dp = 3.6” Last Calibration
02/07/2024
Unit A: Liquid Flow Rate was 5798 gpm. Last Calibration 3/29/2024
Unit B: Liquid Flow Rate was 6488 gpm. Last Calibration 3/29/2024

SME 011e - dp= 8.8” Last Calibration 03/22/2024
Liquid Flow Rate = 12,396 gpm. Last Calibration 02/03/24

SME 011h1 - Anode Refining Furnaces series Scrubbers: dp = 26.9” Last Calibration 02/03/23
Unit A: Liquid Flow Rate = 2530 gpm. Last Calibration 02/06/2024
Unit B: Liquid Flow Rate = 2347 gpm. Last Calibration 02/06/2024

Most readings show actual dp readings to 2 decimal places with rounding done to one place and flow
reading to one decimal place and rounded to whole number.

In compliance.

II.B.1.j Condition:

Pressure drops for each baghouse listed below shall be maintained within the given ranges. (All pressure
drop readings in inches Water Gauge)
SME 001 -Filter Plant Wet Feed Conveyor Baghouse:
Pressure Drop = 0.5 – 4

SME 002 - Wet Feed Storage Building Baghouse:
Pressure Drop = 1.5 - 5
SME 003 - Wet Feed Conveyor Belt Transfer Point Baghouse:
Pressure Drop = 0.5 - 5.25
SME 004 - Wet Feed Bin(s) Baghouse:
Pressure Drop = 2.75 - 5
SME 005 - Flash Smelting Furnace Dry Feed Bin Baghouse:
Pressure Drop = 0.25 - 11
SME 006 - Limestone Flux Bin Baghouse:
26
Pressure Drop = 0.5 - 4
SME 011a - Secondary Gas Handling System Baghouse:
Pressure Drop = 6 - 15
SME 011g - Matte Drying and Grinding Plant Baghouse:
Pressure Drop = 5 - 15
SME 013 - Dry Matte Bin Baghouse:
Pressure Drop = 0.5 - 13
SME 011h1 - Anode Refining Furnace Baghouse:
Pressure Drop = 1 - 9
SME 011h2 - Anode Shaft Furnace Baghouse:
Pressure Drop = 1 - 10
SME 015 - Mold Coating (Barite) Bin Baghouse:
Pressure Drop = 0.25 - 4
SME 017a, c - Vacuum Cleaning Systems (2 Baghouses):
Pressure Drop = 0.25 - 6 (each)
SME 019 - Hydrometallurgical Plant Limestone Storage Bin Baghouse:
Pressure Drop = 0.5 - 4
SME 020 - Hydrometallurgical Plant Lime Storage Bin Baghouse:
Pressure Drop = 0.25 - 4
SME 027 - Recycle Materials Crushing and Storage Building Baghouse:
Pressure Drop = 1 - 5
[Origin: DAQE-AN103460061-22]. [R307-401-8]

II.B.1.j.1 Monitoring:

The permittee shall make at least one pressure drop observation each week for each baghouse listed
above that has operated during the week. The pressure drop reading shall be made to the nearest 1/4
inch W.G. The observation shall be made during typical operating conditions. The instrument(s)
shall be calibrated in accordance with manufacturer's instructions. Additionally, the pressure drop
for each baghouse shall be observed and recorded at the time of any compliance stack testing. If the
pressure drop is outside of the listed ranges, the permittee shall initiate corrective action and perform
daily pressure drop observations until the baghouse is operating within the listed ranges. If the
pressure drop remains outside of the listed ranges for greater than 48 operating hours from the initial
out of range reading it shall be considered a deviation from this permit term.

II.B.1.j.2 Recordkeeping:

The permittee shall record at least one pressure drop observation each week for each baghouse listed
above that has operated during the week. If the pressure drop is outside of the listed ranges, the
permittee shall record the pressure drop observations daily until the baghouse is operating within the
listed ranges. Records shall be maintained in accordance with Provision I.S.1 of this permit.

27
II.B.1.j.3 Reporting:

The permittee shall report the following on a quarterly basis:
a) Periods when the weekly pressure drop observations trigger daily observations, and
b) Periods when the pressure drop observations are outside the listed ranges for greater than 48
operating hours from the initial deviation reading.
There are no additional reporting requirements for this provision except those specified in Section I
of this permit.

The quarterly reports are considered prompt notification of permit deviations required in Provision
I.S.2.c of this permit if all information required by Provision I.S.2.c is included in the report.

Status: Reports are submitted as necessary. Pressure drops for each baghouse appeared to be maintained
within the required ranges. All units (except SME027) are tracked electronically and read from the
data tracking system with trend lines available. Instrument calibration is conducted in accordance
with the manufacturer’s specifications. Any reading showing outside of range is marked as red and
work orders are done to recall or repair. Pressure drops and flow rate readings at the time of the
inspection were as follows:

(All reading shown as reading - calibration date)
SME 001 -Filter Plant Wet Feed Conveyor Baghouse: Pressure Drop = 3.7 – 06/10/2023
SME 002 - Wet Feed Storage Building Baghouse: Pressure Drop = 2.5 – 03/05/2024
SME 003 - Wet Feed Conveyor Belt Transfer Point Baghouse: Pressure Drop = 2.3 – 03/05/2024
SME 004 - Wet Feed Bin(s) Baghouse: Pressure Drop = 3.4 – 03/05/2024
SME 005 - Flash Smelting Furnace Dry Feed Bin Baghouse = 1.6 – 03/14/2024
SME 006 - Limestone Flux Bin Baghouse: Pressure Drop = Decommissioned 1996
SME 011a - Secondary Gas Handling System Baghouse: Pressure Drop = 8.4 – 03/03/2024
SME 011g - Matte Drying and Grinding Plant Baghouse: Pressure Drop = 7.3 – 03/07/2024
SME 013 - Dry Matte Bin Baghouse: Pressure Drop = 2.8 – 03/15/2024
SME 011h1 - Anode Refining Furnace Baghouse = 4.5 – 02/01/2024
SME 011h2 - Anode Shaft Furnace Baghouse: = 1.9 – 03/01/2024
SME 015 - Mold Coating (Barite) Bin Baghouse: Not operating. Fill use only. Last reading = 0.5 on
2/6/2024 – 02/29/2024
SME 017a, c - Vacuum Cleaning Systems (2 Baghouses): inactive
SME 019 - Hydrometal. Plant Limestone Storage Bin Baghouse: operates when filling. Last operation
02/29/2024 Reading = 1.0 – 02/02/2024
SME 020 - Hydrometallurgical Plant Lime Storage Bin Baghouse: Pressure Drop: operates when
filling. Last operation 02/28/2024. Reading = 1.0 – 02/29/2024
SME 027 - Recycle Materials Crushing and Storage Building Baghouse: Pressure Drop: 1.0 –
03/18/2024 (manually read 2x day with operator’s log)

Most readings are listed to two decimal places with rounding to one decimal place for report.
In compliance.

II.B.1.k Condition:

The permittee shall maintain an Emergency Episode Plan outlining the procedures that will be taken in the
event of an emergency episode as outlined in R307-105-2. The plan shall identify what control/production
measures shall be implemented when an emergency episode is declared. Specific control/production
measures shall be outlined for all three levels (Alert, Warning, Emergency). The plan shall be submitted and
28
approved by the Director within 60 days of the issue date of this permit, unless a previously submitted and
approved plan is available. [Origin: SIP Section VII.F]. [R307-105-2, R307-110-8]

II.B.1.k.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.k.2 Recordkeeping:

A copy of the approved Emergency Episode Plan shall be made available to the Director upon
request.

II.B.1.k.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: An emergency episode plan was submitted on September 12, 1994. The DAQ reviewed the plan and
issued an acceptance letter. A copy of the plan and DAQ acceptance letter (DAQE-765-94) is kept on
site. No updates have been made to the plan as it is general to areas and not specific equipment pieces.
In compliance.

II.B.1.l Condition:

Any open storage pile(s) shall be watered, covered, or chemically treated to minimize generation of fugitive
dusts, as dry conditions warrant or as determined necessary by the Director. [Origin: DAQE-AN103460061-
22]. [R307-401-8]

II.B.1.l.1 Monitoring:

Visual inspections of any open storage pile(s) shall be made on a daily basis to ensure minimization
of fugitive dust generation. If visual inspection results for eight consecutive weeks confirm the
minimization of fugitive dust generation, the inspection frequency shall be reduced to a weekly
basis. If minimization of fugitive dust generation is not confirmed during any weekly inspection, the
frequency shall revert to a daily basis for the storage pile(s) generating fugitive dust.

Any storage pile that has been covered, undisturbed, or chemically treated to minimize fugitive dust
generation shall be visually inspected on a monthly basis to ensure covers are properly in place
and/or chemical treatments are working properly.

II.B.1.l.2 Recordkeeping:

During each visual inspection, the permittee shall record in a log the specific piles determined to be
undisturbed. Records of inspections and determinations shall be maintained as described in
Provision I.S.1 of this permit.

II.B.1.l.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

29
Status: No visible emissions were observed coming from any open storage piles during this inspection. KUC
applies water to storage piles when dust is observed. Daily visual inspections are conducted and
recorded by the operations group, and weekly inspections are conducted by the environmental staff or
contractor. In compliance.

II.B.1.m Condition:

The permittee shall operate and maintain an upwind/downwind fugitive SO2 monitoring system. [Origin:
DAQE-AN103460061-22]. [R307-401-8]

II.B.1.m.1 Monitoring:

The permittee shall monitor the output of the fugitive upwind/downwind SO2 monitoring system on
a daily basis to ensure that no high levels of SO2 have passed over the monitors. The daily
monitoring will not be required if the system is equipped with an alarm system to notify personnel
when high levels of SO2 have passed over the monitors. The monitoring system shall be calibrated
in accordance with the manufacturer's recommendations.

II.B.1.m.2 Recordkeeping:

Continuous recording of the monitoring device(s) is not required for systems equipped with an
alarm. Records of all alarm events and the corrective action taken shall be maintained as described
in Provision I.S.1 of this permit.

II.B.1.m.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: KUC has installed SO2 monitoring stations throughout the area and outside the plant boundaries.
These monitors are equipped with alarms. The SO2 monitors are calibrated as recommended by the
manufacturer. Calibration dates are recorded in the maintenance logbook. The systems are also
audited independently by third party (Trinity Consultants). Quarterly reports are submitted to DAQ
and reviewed under separate cover. Reports are in the main source files. KUC submitted an updated
SO2 plan. This plan detailed more remote monitoring and equipment. DAQ review was completed,
and plan was accepted with acceptance letter dated 1/22/2020. In compliance.

II.B.1.n Condition:

Fugitive emissions shall be no greater than 15 percent opacity unless otherwise specified in this permit.
[Origin: R307-309-4]. [R307-309-4]

II.B.1.n.1 Monitoring:

A visual opacity survey of each affected emission unit shall be performed on a weekly basis by an
individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. If visible
emissions other than steam are observed from an emission unit, an opacity determination of that
emission unit shall be performed by a certified observer within 24 hours of the initial survey. The
opacity determination shall be performed in accordance with 40 CFR 60, Appendix A, Method 9, or
other EPA-approved testing method, as acceptable to the Director, for point sources, and in
accordance with 58 FR 61640 Method 203C, or other EPA-approved testing method, as acceptable
30
to the Director, for intermittent sources. Fugitive dust is not a fugitive emission within the meaning
of this condition.

For each affected emission unit, if no visible emissions are observed for eight consecutive weeks the
observation frequency shall be reduced to a monthly basis. If visible emissions are observed during
any monthly observation the frequency shall revert to a weekly basis.

II.B.1.n.2 Recordkeeping:

A log of the visual opacity survey(s) shall be maintained in accordance with Provision I.S.1 of this
permit. If an opacity determination is indicated, a notation of the determination will be made in the
log. All data required by 40 CFR 60, Appendix A, Method 9, 58 FR 61640, Method 203C, or other
EPA-approved testing method, as acceptable to the Director, shall also be maintained in accordance
with Provision I.S.1 of this permit.

II.B.1.n.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: KUC maintains a logbook with all visible emission units and weekly surveys. This logbook was
reviewed during the inspection and appeared to be complete. KUC uses the weekly-to-monthly skip
monitoring provision and enters all data into a spreadsheet to track whether a point source is on the
weekly or monthly schedule. The site has two forms each for Smelter and Refinery: 1 for specific
listed sources and one for other sources such as storage piles. No excess visible emissions were noted at
any point during either inspection or any stack tests. The initial readings are done by contractor and
then submitted to be included on the compliance section spreadsheets. The contractor is Method 9
certified and review of VEO sheets show proper method and annotation of readings. Review of the
tracking spreadsheets show all points are included. In Compliance.

II.B.1.o Condition:

Visible emissions caused by fugitive dust shall not exceed 10 percent at the property boundary and 20
percent on site. Opacity shall not apply when the wind speed exceeds 25 miles per hour if the permittee has
implemented, and continues to implement, the most recently approved fugitive dust control plan and
administers one or more of the following contingency measures:
(1) Pre-event watering;
(2) Hourly watering;
(3) Additional chemical stabilization;
(4) Cease or reduce fugitive dust producing operations to the extent practicable.
[Origin: DAQE-AN103460061-22, R307-309-5]. [R307-309-5, R307-401-8]

II.B.1.o.1 Monitoring:

In lieu of monitoring via visible emissions observations, adherence to the most recently approved
fugitive dust control plan shall be monitored to demonstrate that appropriate measures are being
implemented to control fugitive dust. Wind speed shall be measured by an anemometer to establish
an exception from the visible emissions limit.

II.B.1.o.2 Recordkeeping:

31
Records of measures taken to control fugitive dust shall be maintained to demonstrate adherence to
the most recently approved fugitive dust control plan. If wind speeds are measured to establish an
exception from the above visible emissions limit, records of the administered contingency measures
and the wind speed measurements shall be maintained. Records shall be maintained as described in
Provision I.S.1 of this permit.

II.B.1.o.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Kennecott implements a fugitive dust control plant as described above. No fugitive dust was observed
during this inspection. Daily monitoring of fugitive dust sources is conducted by the operations group.
A fugitive dust control plan was submitted May 8, 2018, via the web based system. In compliance.

II.B.1.p Condition:

A Risk Management Plan (RMP) developed in accordance with 40 CFR Part 68 shall be submitted to the
United States Environmental Protection Agency not later than the applicable date in 40 CFR 68. [Origin: 40
CFR 68]. [40 CFR 68]

II.B.1.p.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.p.2 Recordkeeping:

A copy of the Risk Management Plan shall be available to the Director upon request. Records shall
be maintained as described in Provision I.S.1 of this permit.

II.B.1.p.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: This requirement was in the original permit, requirement was removed and then returned in newest
federal regulation. The RMP was submitted to EPA and approved in 2019. EPA requested a new plan
as new authority named. In compliance.

II.B.1.q Condition:

(1) For all solvent cleaning operations, the permittee shall not use solvent products with a VOC content
greater than the amounts specified in Table 1 of R307-304-5.
(2) As an alternative to the limits in Table 1 and for all general miscellaneous cleaning operations, the
permittee may use a cleaning material with a VOC composite vapor pressure no greater than 8 mm Hg
at 20 degrees Celsius.
(3) The permittee shall store used applicators and shop towels in closed fireproof containers.
These requirements do not apply to the exemptions listed in R307-304-3.
[Origin: R307-304]. [R307-304]

II.B.1.q.1 Monitoring:
32

Records required for this permit condition will serve as monitoring.

II.B.1.q.2 Recordkeeping:

The permittee shall maintain records demonstrating compliance with this condition. Records shall
include the VOC content or composite vapor pressure of the solvent product applied. Records shall
be maintained in accordance with Provision I.S.1 of this permit and shall be available to the director
upon request.

II.B.1.q.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: All solvents are bought from third party suppliers and have MSD sheets which show compliant
product purchased. The company sent a new EM episode plan to EPA the first quarter of 2022. In
compliance.

II.B.1.r Condition:

Except as provided in R307-361-4, the permittee shall not supply, solicit for application, or apply within the
counties in R307-361-2 any architectural coating with a VOC content in excess of the corresponding limit
specified in Table 1 of R307-361-5. The permittee shall comply with the additional standards and work
practices contained in R307-361-5, as applicable. [Origin: R307-361]. [R307-361]

II.B.1.r.1 Monitoring:

Compliance shall be demonstrated as specified in R307-361-8.

II.B.1.r.2 Recordkeeping:

Records demonstrating compliance with this condition shall be maintained in accordance with
Provision I.S.1 of this permit.

II.B.1.r.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: The company purchases all material as compliance from third party vendor and uses as purchased. In
compliance.

II.B.1.s Condition:

1. The permittee shall not sell supply or offer for sale any adhesive, sealant, adhesive primer or sealant
primer with a VOC content in excess of the limits in Table 1 of R307-342-5 and that was manufactured
on or after September 1, 2014.
2. The permittee shall not apply any adhesive, sealant, adhesive primer or sealant primer with a VOC
content in excess of the limits specified in Table 1 of R307-342-5 unless an add-on control device as
33
specified in R307-342-8 is used or unless the adhesive, sealant, adhesive primer or sealant primer was
manufactured before September 1, 2014.
3. The VOC content limits in Table 1 of R307-342-5 for adhesives applied to particular substrates shall
apply as specified in R307-342-5(4).
4. The permittee shall comply with the additional standards and work practices contained in R307-342-6
and R307-342-7, as applicable.
5. These requirements do not apply if exempted in accordance with R307-342-3.
[Origin: R307-342]. [R307-342]

II.B.1.s.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.s.2 Recordkeeping:

(a) For operations that are not exempt under R307-342-3, the permittee shall maintain records
demonstrating compliance as specified in R307-342-7(2).
(b) If an exemption is claimed pursuant to R307-342-3 the permittee shall record and maintain
operational records sufficient to demonstrate compliance. (R307-342-3(7))
Records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.1.s.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: The company purchases all material as compliant (MSD sheets available) from third party vendor
and uses as purchased. Company is not a retailer and end user only. In compliance.

II.B.2 Conditions on #SME 001: Filter Plant Wet Feed Conveyor (Stack 1).

II.B.2.a Condition:

Emissions of PM10 shall be no greater than 0.7 lbs/hour (filterable) and 0.016 grains/dscfm (68 degrees F,
29.92" Hg). [Origin: DAQE-AN103460061-22]. [R307-401-8]

II.B.2.a.1 Monitoring:

Stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested every five years based on the date of the most recent stack
test. The source may also be tested at any time if directed by the Director.
(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source shall attend a
pretest conference if determined necessary by the Director.
(c) Methods.
(1) Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other EPA-approved testing method, as acceptable to the
Director, and Occupational Safety and Health Administration (OSHA)-approved and/or
Mine Safety and Health Administration (MSHA)-approved access shall be provided to the
test location.
(2) PM10/PM2.5 (filterable):
34
For stacks in which no liquid drops are present, the following methods shall be used: 40
CFR 51, Appendix M, Methods 201 or 201a or other EPA-approved testing method
acceptable to the Director.

For stacks in which liquid drops are present, methods to eliminate the liquid drops shall be
explored. If no reasonable method to eliminate the drops exists, then the following
methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d, 5i or other EPA-
approved testing method acceptable to the Director. If using Method 5 or any variation of
Method 5, a scanning electron microscopy analysis or other equivalent method shall be
used to determine the fraction of PM10 and/or PM2.5, as approved by the Director.

PM10/PM2.5 (condensable):
Not applicable.
(3) 40 CFR 60, Appendix A, Method 2, Method 19, or other EPA-approved testing method, as
acceptable to the Director, shall be used to determine volumetric flow rate.
(d) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate
and any necessary conversion factors determined by the Director to give the results in the
specified units of the emission limitation.
(e) Conditions During Testing: Stack testing shall be performed during representative operations.
The production rate during all compliance tests shall be no less than 90% of the maximum
average hourly production rate achieved in a 24-hour period during the previous three (3) years.

II.B.2.a.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated test
method and Provision S.1 in Section I of this permit.

II.B.2.a.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of the
testing. Reports shall clearly identify results as compared to permit limits and indicate compliance
status. There are no additional reporting requirements for this provision except those specified in
Section I of this permit.

Status: Stack testing on SME 001 was last conducted May 17, 2019. DAQ-calculated results of the test for
PM10 were 0.0011 gr/dscf and 0.047 lbs/hr. Next testing is due in 2024. In compliance.

II.B.2.b Condition:

Visible emissions shall be no greater than 7 percent opacity. [Origin: DAQE-AN103460061-22]. [R307-
401-8]

II.B.2.b.1 Monitoring:

A visual observation of each affected emission unit shall be performed on a weekly basis by an
individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. The
individual is not required to be a certified visible emissions observer. If any visible emissions other
than steam are observed, an opacity determination of that emission unit shall be performed by a
certified visible emissions observer in accordance with 40 CFR 60, Appendix A, Method 9, or other
EPA-approved testing method, as acceptable to the Director, within 24 hours of the initial
35
observation. For each affected emission unit, if no visible emissions are observed for eight
consecutive weeks the observation frequency shall be reduced to a monthly basis. If visible
emissions are observed during any monthly observation the frequency shall revert to a weekly basis.

II.B.2.b.2 Recordkeeping:

Records of visual observations performed and data required by 40 CFR 60, Appendix A, Method 9,
or other EPA-approved testing method, as acceptable to the Director, for each determination shall be
maintained in accordance with Provision I.S.1 of this permit.

II.B.2.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Opacity observations have been performed and recorded weekly. No excursions were noted in an
onsite records review, and no opacity was observed during the inspection. In compliance.

II.B.3 Conditions on #SME 002: Wet Feed Storage Building (Stack 2).

II.B.3.a Condition:

Emissions of PM10 shall be no greater than 3.91 lbs/hour (filterable) and 0.008 grains/dscfm (68 degrees F,
29.92" Hg). [Origin: DAQE-AN103460061-22]. [R307-401-8]

II.B.3.a.1 Monitoring:

Stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested every five years based on the date of the most recent stack
test. The source may also be tested at any time if directed by the Director.
(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source shall attend a
pretest conference if determined necessary by the Director.
(c) Methods.
(1) Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other EPA-approved testing method, as acceptable to the
Director, and Occupational Safety and Health Administration (OSHA)-approved and/or
Mine Safety and Health Administration (MSHA)-approved access shall be provided to the
test location.
(2) PM10/PM2.5 (filterable):
For stacks in which no liquid drops are present, the following methods shall be used: 40
CFR 51, Appendix M, Methods 201 or 201a or other EPA-approved testing method
acceptable to the Director.

For stacks in which liquid drops are present, methods to eliminate the liquid drops shall be
explored. If no reasonable method to eliminate the drops exists, then the following
methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d, 5i or other EPA-
approved testing method acceptable to the Director. If using Method 5 or any variation of
Method 5, a scanning electron microscopy analysis or other equivalent method shall be
used to determine the fraction of PM10 and/or PM2.5, as approved by the Director.
36

PM10/PM2.5 (condensable):
Not applicable.
(3) 40 CFR 60, Appendix A, Method 2, Method 19, or other EPA-approved testing method, as
acceptable to the Director, shall be used to determine volumetric flow rate.
(d) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate
and any necessary conversion factors determined by the Director to give the results in the
specified units of the emission limitation.
(e) Conditions During Testing: Stack testing shall be performed during representative operations.
The production rate during all compliance tests shall be no less than 90% of the maximum
average hourly production rate achieved in a 24-hour period during the previous three (3) years.

II.B.3.a.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated test
method and Provision S.1 in Section I of this permit.

II.B.3.a.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of the
testing. Reports shall clearly identify results as compared to permit limits and indicate compliance
status. There are no additional reporting requirements for this provision except those specified in
Section I of this permit.

Status: Stack testing on SME 002 was last conducted May 15, 2019. These results were submitted to and
reviewed by DAQ. DAQ-calculated results of the test for PM10 were 0.0076 gr/dscf and 0.13 lbs/hr.
Next testing is due in 2024. In compliance.

II.B.3.b Condition:

Visible emissions shall be no greater than 7 percent opacity. [Origin: DAQE-AN103460061-22]. [R307-
401-8]

II.B.3.b.1 Monitoring:

A visual observation of each affected emission unit shall be performed on a weekly basis by an
individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. The
individual is not required to be a certified visible emissions observer. If any visible emissions other
than steam are observed, an opacity determination of that emission unit shall be performed by a
certified visible emissions observer in accordance with 40 CFR 60, Appendix A, Method 9, or other
EPA-approved testing method, as acceptable to the Director, within 24 hours of the initial
observation. For each affected emission unit, if no visible emissions are observed for eight
consecutive weeks the observation frequency shall be reduced to a monthly basis. If visible
emissions are observed during any monthly observation the frequency shall revert to a weekly basis.

37
II.B.3.b.2 Recordkeeping:

Records of visual observations performed and data required by 40 CFR 60, Appendix A, Method 9,
or other EPA-approved testing method, as acceptable to the Director, for each determination shall be
maintained in accordance with Provision I.S.1 of this permit.

II.B.3.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Opacity observations have been performed and recorded weekly. No excursions were noted in an
onsite records review, and no opacity was observed during the inspection. In compliance.

II.B.3.c Condition:

Water sprays or chemical dust suppression sprays shall be installed at all stationary conveyor transfer points
if they are not enclosed or do not have baghouses to control fugitive emissions. The sprays shall operate
whenever dry conditions warrant or as determined necessary by the Director. [Origin: DAQE-
AN103460061-22]. [R307-309, R307-401-8]

II.B.3.c.1 Monitoring:

Visual inspections of the water spray system(s) shall be made weekly to ensure proper operating
condition.

II.B.3.c.2 Recordkeeping:

A log of the visual inspections containing all applicable information required by Provision I.S.1 of
this permit shall be kept for all periods of operation. Records shall be maintained in accordance with
Provision I.S.1 of this permit.

II.B.3.c.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: There are several points outside of the building and these do have sprays attached and used as needed.
Weekly inspections are done and logged. In compliance.

II.B.4 Conditions on #SME 003: Wet Feed Conveyor Transfer Point (Stack 3).

II.B.4.a Condition:

Emissions of PM10 shall be no greater than 0.4 lbs/hour (filterable) and 0.016 grains/dscfm (68 degrees F,
29.92" Hg). [Origin: DAQE-AN103460061-22]. [R307-401-8]

II.B.4.a.1 Monitoring:

Stack testing shall be performed as specified below:
38
(a) Frequency. Emissions shall be tested every five years based on the date of the most recent stack
test. The source may also be tested at any time if directed by the Director.
(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source shall attend a
pretest conference if determined necessary by the Director.
(c) Methods.
(1) Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other EPA-approved testing method, as acceptable to the
Director, and Occupational Safety and Health Administration (OSHA)-approved and/or
Mine Safety and Health Administration (MSHA)-approved access shall be provided to the
test location.
(2) PM10/PM2.5 (filterable):
For stacks in which no liquid drops are present, the following methods shall be used: 40
CFR 51, Appendix M, Methods 201 or 201a or other EPA-approved testing method
acceptable to the Director.

For stacks in which liquid drops are present, methods to eliminate the liquid drops shall be
explored. If no reasonable method to eliminate the drops exists, then the following
methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d, 5i or other EPA-
approved testing method acceptable to the Director. If using Method 5 or any variation of
Method 5, a scanning electron microscopy analysis or other equivalent method shall be
used to determine the fraction of PM10 and/or PM2.5, as approved by the Director.

PM10/PM2.5 (condensable):
Not applicable.
(3) 40 CFR 60, Appendix A, Method 2, Method 19, or other EPA-approved testing method, as
acceptable to the Director, shall be used to determine volumetric flow rate.
(d) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate
and any necessary conversion factors determined by the Director to give the results in the
specified units of the emission limitation.
(e) Conditions During Testing: Stack testing shall be performed during representative operations.
The production rate during all compliance tests shall be no less than 90% of the maximum
average hourly production rate achieved in a 24-hour period during the previous three (3) years.

II.B.4.a.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated test
method and Provision S.1 in Section I of this permit.

II.B.4.a.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of the
testing. Reports shall clearly identify results as compared to permit limits and indicate compliance
status. There are no additional reporting requirements for this provision except those specified in
Section I of this permit.

Status: Stack testing on SME 003 was last conducted May 15-17, 2019. These results were submitted to DAQ
and reviewed. DAQ-calculated results of the test for PM10 were 0.0014 gr/dscf and 0.013 lbs/hr. Next
testing is due in 2024. In compliance.

39
II.B.4.b Condition:

Visible emissions shall be no greater than 7 percent opacity. [Origin: DAQE-AN103460061-22]. [R307-
401-8]

II.B.4.b.1 Monitoring:

A visual observation of each affected emission unit shall be performed on a weekly basis by an
individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. The
individual is not required to be a certified visible emissions observer. If any visible emissions other
than steam are observed, an opacity determination of that emission unit shall be performed by a
certified visible emissions observer in accordance with 40 CFR 60, Appendix A, Method 9, or other
EPA-approved testing method, as acceptable to the Director, within 24 hours of the initial
observation. For each affected emission unit, if no visible emissions are observed for eight
consecutive weeks the observation frequency shall be reduced to a monthly basis. If visible
emissions are observed during any monthly observation the frequency shall revert to a weekly basis.

II.B.4.b.2 Recordkeeping:

Records of visual observations performed and data required by 40 CFR 60, Appendix A, Method 9,
or other EPA-approved testing method, as acceptable to the Director, for each determination shall be
maintained in accordance with Provision I.S.1 of this permit.

II.B.4.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Opacity observations have been performed and recorded weekly. No excursions were noted in an
onsite records review, and no opacity was observed during the inspection. In compliance.

II.B.5 Conditions on #SME 004: Wet Feed Bins (Stack 4).

II.B.5.a Condition:

Emissions of PM10 shall be no greater than 3.4 lbs/hour (filterable) and 0.016 grains/dscfm (68 degrees F,
29.92" Hg). [Origin: DAQE-AN103460061-22]. [R307-401-8]

II.B.5.a.1 Monitoring:

Stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested every five years based on the date of the most recent stack
test. The source may also be tested at any time if directed by the Director.
(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source shall attend a
pretest conference if determined necessary by the Director.
(c) Methods.
(1) Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other EPA-approved testing method, as acceptable to the
Director, and Occupational Safety and Health Administration (OSHA)-approved and/or
40
Mine Safety and Health Administration (MSHA)-approved access shall be provided to the
test location.
(2) PM10/PM2.5 (filterable):
For stacks in which no liquid drops are present, the following methods shall be used: 40
CFR 51, Appendix M, Methods 201 or 201a or other EPA-approved testing method
acceptable to the Director.

For stacks in which liquid drops are present, methods to eliminate the liquid drops shall be
explored. If no reasonable method to eliminate the drops exists, then the following
methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d, 5i or other EPA-
approved testing method acceptable to the Director. If using Method 5 or any variation of
Method 5, a scanning electron microscopy analysis or other equivalent method shall be
used to determine the fraction of PM10 and/or PM2.5, as approved by the Director.

PM10/PM2.5 (condensable):
Not applicable.
(3) 40 CFR 60, Appendix A, Method 2, Method 19, or other EPA-approved testing method, as
acceptable to the Director, shall be used to determine volumetric flow rate.
(d) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate
and any necessary conversion factors determined by the Director to give the results in the
specified units of the emission limitation.
(e) Conditions During Testing: Stack testing shall be performed during representative operations.
The production rate during all compliance tests shall be no less than 90% of the maximum
average hourly production rate achieved in a 24-hour period during the previous three (3) years.

II.B.5.a.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated test
method and Provision S.1 in Section I of this permit.

II.B.5.a.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of the
testing. Reports shall clearly identify results as compared to permit limits and indicate compliance
status. There are no additional reporting requirements for this provision except those specified in
Section I of this permit.

Status: Stack testing on SME 004 was last conducted on May 14, 2019. These results were submitted to DAQ
and reviewed. DAQ-calculated results of the test for PM10 were 0.0028 gr/dscf and 0.19 lbs/hr. Next
testing is due in 2024. In compliance.

II.B.5.b Condition:

Visible emissions shall be no greater than 7 percent opacity. [Origin: DAQE-AN103460061-22]. [R307-
401-8]

II.B.5.b.1 Monitoring:

A visual observation of each affected emission unit shall be performed on a weekly basis by an
individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. The
41
individual is not required to be a certified visible emissions observer. If any visible emissions other
than steam are observed, an opacity determination of that emission unit shall be performed by a
certified visible emissions observer in accordance with 40 CFR 60, Appendix A, Method 9, or other
EPA-approved testing method, as acceptable to the Director, within 24 hours of the initial
observation. For each affected emission unit, if no visible emissions are observed for eight
consecutive weeks the observation frequency shall be reduced to a monthly basis. If visible
emissions are observed during any monthly observation the frequency shall revert to a weekly basis.

II.B.5.b.2 Recordkeeping:

Records of visual observations performed and data required by 40 CFR 60, Appendix A, Method 9,
or other EPA-approved testing method, as acceptable to the Director, for each determination shall be
maintained in accordance with Provision I.S.1 of this permit.

II.B.5.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Opacity observations have been performed and recorded weekly. No excursions were noted in an
onsite records review, and no opacity was observed during the inspection. In compliance.

II.B.6 Conditions on #SME 005: Flash Smelting Furnace Dry Feed Bin (Stack 5).

II.B.6.a Condition:

Emissions of PM10 shall be no greater than 1.2 lbs/hour (filterable) and 0.016 grains/dscfm (68 degrees F,
29.92" Hg). [Origin: DAQE-AN103460061-22]. [R307-401-8]

II.B.6.a.1 Monitoring:

Stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested every five years based on the date of the most recent stack
test. The source may also be tested at any time if directed by the Director.
(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source shall attend a
pretest conference if determined necessary by the Director.
(c) Methods.
(1) Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other EPA-approved testing method, as acceptable to the
Director, and Occupational Safety and Health Administration (OSHA)-approved and/or
Mine Safety and Health Administration (MSHA)-approved access shall be provided to the
test location.
(2) PM10/PM2.5 (filterable):
For stacks in which no liquid drops are present, the following methods shall be used: 40
CFR 51, Appendix M, Methods 201 or 201a or other EPA-approved testing method
acceptable to the Director.

For stacks in which liquid drops are present, methods to eliminate the liquid drops shall be
explored. If no reasonable method to eliminate the drops exists, then the following
methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d, 5i or other EPA-
42
approved testing method acceptable to the Director. If using Method 5 or any variation of
Method 5, a scanning electron microscopy analysis or other equivalent method shall be
used to determine the fraction of PM10 and/or PM2.5, as approved by the Director.

PM10/PM2.5 (condensable):
The back half condensable particulate emissions shall also be tested using 40 CFR 51,
Appendix M Method 202, or other EPA-approved testing method acceptable to the
Director. All particulate captured using Method 202 shall be considered PM2.5 and/or
PM10.

For filterable emission limits, condensable emissions shall not be used for compliance
demonstrations. For filterable + condensable emission limits, condensable emissions shall
be used for compliance demonstrations.
(3) 40 CFR 60, Appendix A, Method 2, Method 19, or other EPA-approved testing method, as
acceptable to the Director, shall be used to determine volumetric flow rate.
(d) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate
and any necessary conversion factors determined by the Director to give the results in the
specified units of the emission limitation.
(e) Conditions During Testing: Stack testing shall be performed during representative operations.
The production rate during all compliance tests shall be no less than 90% of the maximum
average hourly production rate achieved in a 24-hour period during the previous three (3) years.

II.B.6.a.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated test
method and Provision S.1 in Section I of this permit.

II.B.6.a.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of the
testing. Reports shall clearly identify results as compared to permit limits and indicate compliance
status. There are no additional reporting requirements for this provision except those specified in
Section I of this permit.

Status: Stack testing on SME 005 was last conducted October 25, 2023. Stack testing results were submitted
to DAQ and reviewed in DAQC-028-24. DAQ-calculated results of the test for PM10 were 0.003
gr/dscfm and 0.04 lbs/hr. Next testing is due in 2025. In compliance.

II.B.6.b Condition:

Visible emissions shall be no greater than 7 percent opacity. [Origin: DAQE-AN103460061-22]. [R307-
401-8]

II.B.6.b.1 Monitoring:

A visual observation of each affected emission unit shall be performed on a weekly basis by an
individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. The
individual is not required to be a certified visible emissions observer. If any visible emissions other
than steam are observed, an opacity determination of that emission unit shall be performed by a
certified visible emissions observer in accordance with 40 CFR 60, Appendix A, Method 9, or other
43
EPA-approved testing method, as acceptable to the Director, within 24 hours of the initial
observation. For each affected emission unit, if no visible emissions are observed for eight
consecutive weeks the observation frequency shall be reduced to a monthly basis. If visible
emissions are observed during any monthly observation the frequency shall revert to a weekly basis.

II.B.6.b.2 Recordkeeping:

Records of visual observations performed and data required by 40 CFR 60, Appendix A, Method 9,
or other EPA-approved testing method, as acceptable to the Director, for each determination shall be
maintained in accordance with Provision I.S.1 of this permit.

II.B.6.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Opacity observations have been performed and recorded weekly. No excursions were noted in an
onsite records review, and no excess opacity was observed during the inspection. In compliance.

II.B.7 Conditions on #SME 011e: Rotary Dryer.

II.B.7.a Condition:

Particulate emissions (PM) shall be no greater than 0.022 grains/dscf (68 degrees F, 29.92" Hg) (filterable).
[Origin: DAQE-AN103460061-22]. [40 CFR 60 Subpart P, R307-401-8]

II.B.7.a.1 Monitoring:

Stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested every five years based on the date of the most recent stack
test. The source may also be tested at any time if directed by the Director.
(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source shall attend a
pretest conference if determined necessary by the Director.
(c) Methods.
(1) Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other EPA-approved testing method, as acceptable to the
Director, and Occupational Safety and Health Administration (OSHA)-approved and/or
Mine Safety and Health Administration (MSHA)-approved access shall be provided to the
test location.
(2) Sample Method - 40 CFR 60. Appendix A, Method 5, or other EPA-approved testing
method, as acceptable to the Director, shall be used to determine the particulate matter
concentration and the volumetric flow rate of the effluent gas. The minimum sample time
and sample volume shall be 60 minutes and 0.85 dscm (30.0 dscf).
(d) Calculations: To determine mass emission rates (lb./hr., etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate
and any necessary conversion factors determined by the Director to give the results in the
specified units of the emission limitation.
(e) Conditions During Testing: Stack testing shall be performed during representative operations.
The production rate during all compliance tests shall be no less than 90% of the maximum
average hourly production rate achieved in a 24-hour period during the previous three (3) years.
44

II.B.7.a.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated test
method and Provision S.1 in Section I of this permit.

II.B.7.a.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of the
testing. Reports shall clearly identify results as compared to permit limits and indicate compliance
status. There are no additional reporting requirements for this provision except those specified in
Section I of this permit.

Status: Stack testing was conducted on July 30, 2021. Stack testing results were submitted to DAQ and
reviewed in DAQC-1388-21. DAQ-calculated results of the test for TSP were 0.0008 gr/dscf. Next
testing is due in 2026. In compliance.

II.B.7.b Condition:

Visible emissions shall be no greater than 15 percent opacity. [Origin: DAQE-AN103460061-22]. [40 CFR
60 Subpart P, R307-401-8]

II.B.7.b.1 Monitoring:

The permittee shall calibrate, maintain and operate a continuous monitoring system for measuring
the opacity of emissions in accordance with R307-170, UAC and 40 CFR 60, Appendix B,
Specification 1 - Opacity, and shall record the output of the system. The output shall be reviewed at
least monthly for compliance with the opacity limit. Compliance is to be based on the percent
opacity averaged over six consecutive minutes.

II.B.7.b.2 Recordkeeping:

Results of opacity measurements shall be recorded and maintained as required in R307-170 and as
described in Provision I.S.1 of this permit.

II.B.7.b.3 Reporting:

The permittee shall comply with the reporting provisions in R307-170-9 and any additional
reporting provisions contained in Section I of this permit.

The quarterly reports required in R307-170-9 are considered prompt notification of permit
deviations required in Provision I.S.2.c of this permit if all information required by Provision I.S.2.c
is included in the report.

Status: The COM is installed, and reports are made to the DAQ for review. Reports are in the main source
files. COM readings during the inspection were 1.02% instant, 1.38% 1- minute avg and 1.1% 6-
minute avg. Normal trends are less than 2% readings. In compliance.

II.B.8 Conditions on #SME 011b1: Flash Smelting Furnace (FSF)

II.B.8.a Condition:
45

Visible emissions shall be no greater than 20 percent opacity from the emergency generator. [Origin:
DAQE-AN103460061-22, R307-305-3(3)]. [R307-305-3(3), R307-401-8]

II.B.8.a.1 Monitoring:

During any period that an emergency generator is operated for longer than 12 hours consecutively, a
visual observation of that generator's exhaust shall be made by an individual trained on the
observation procedures of 40 CFR 60, Appendix A, Method 9. The individual is not required to be a
certified visual emissions observer. If any visible emissions other than steam are observed, then an
opacity determination shall be performed in accordance with 40 CFR 60, Appendix A, Method 9, or
other EPA-approved testing method, as acceptable to the Director, by a certified visible emissions
observer. If a generator continues to operate on consecutive days following the initial observation,
an opacity determination shall be performed on a daily basis.

II.B.8.a.2 Recordkeeping:

Records of visual observations performed and data required by 40 CFR 60, Appendix A, Method 9,
or other EPA-approved testing method, as acceptable to the Director, for each determination shall be
maintained in accordance with Provision I.S.1 of this permit.

II.B.8.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: This unit is on the VEO log. In compliance. Did not run over 12 hours at any time in last year. See
specific operating hours below. In compliance.

II.B.8.b Condition:

The emergency generator shall comply with the emission standards for new nonroad compression ignition
(CI) engines in 40 CFR 60.4202(a) and (a)(2), for all pollutants, for the same model year and maximum
engine power for 2007 model year and later emergency stationary CI internal combustion engines (ICE).
[Origin: 40 CFR 60 Subpart IIII]. [40 CFR 60.4205(b), 40 CFR 63 Subpart ZZZZ]

II.B.8.b.1 Monitoring:

The permittee shall comply by purchasing an engine certified to the emission standards in 40 CFR
60.4205(b) for the same model year and maximum engine power. The engine shall be installed and
configured according to the manufacturer's emission-related specifications, except as permitted in 40
CFR 60.4211(g). [40 CFR 60.4211(c)]

II.B.8.b.2 Recordkeeping:

The permittee shall keep records of engine certifications indicating compliance with the standards.
The permittee shall keep records demonstrating compliance with the manufacturer's specifications
for engine installation and configuration. Results of monitoring shall be maintained in accordance
with Provision I.S.1 of this permit.

46
II.B.8.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Records of certification are available for review. In compliance.

II.B.8.c Condition:

The permittee shall operate and maintain the emergency generator according to the manufacturer's emission-
related written instructions, over the entire life of the engine. In addition, the permittee may only change
those settings that are permitted by the manufacturer. The permittee shall also meet the requirements of 40
CFR part 1068, as applicable. [Origin: 40 CFR 60 Subpart IIII]. [40 CFR 60.4206, 40 CFR 60.4211(a), 40
CFR 63 Subpart ZZZZ]

II.B.8.c.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.8.c.2 Recordkeeping:

Permittee shall document activities performed to assure proper operation and maintenance. Records
shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.8.c.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Kennecott has placed maintenance requirements into their electronic preventative maintenance
database called SAP. Quarterly checks are performed and recorded. The engine operates as provided
in the operator’s manual. Annual maintenance is completed, and all required items are performed
during maintenance checks. In compliance.

II.B.8.d Condition:

Any diesel fuel combusted in the emergency generator shall meet the requirements of 40 CFR 60.4207(b)
for nonroad diesel fuel. [Origin: 40 CFR 60 Subpart IIII]. [40 CFR 60.4207(b), 40 CFR 63 Subpart ZZZZ]

II.B.8.d.1 Monitoring:

For all diesel fuel combusted, the permittee shall:
(a) Determine the fuel sulfur content expressed as weight percent in accordance with the methods
of the American Society for Testing Materials (ASTM); or
(b) Inspect the fuel sulfur content expressed as weight percent determined by the vendor using
methods of the ASTM; and
(c) Inspect documentation provided by the vendor that directly or indirectly demonstrates
compliance with this provision.

II.B.8.d.2 Recordkeeping:

47
For all diesel fuel combusted, the permittee shall maintain fuel receipt records and documentation
demonstrating compliance with this provision. These records shall be maintained in accordance with
Provision I.S.1. of this permit.

II.B.8.d.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: All diesel fuel combusted is delivered from Sinclair’s pioneer pipeline and is listed as ultra-low sulfur
diesel as delivered. In compliance.

II.B.8.e Condition:

The emergency generator shall be operated according to the requirements in paragraphs (1) through (3). In
order for the engine to be considered an emergency stationary ICE, any operation other than emergency
operation, maintenance and testing, and operation in non-emergency situations for 50 hours per year, as
described in paragraphs (1) through (3), is prohibited. If the engine is not operated according to the
requirements in paragraphs (1) through (3), the engine will not be considered an emergency engine and shall
meet all requirements for non-emergency engines.
(1) There is no time limit on the use of emergency stationary ICE in emergency situations.
(2) The permittee may operate the emergency stationary ICE for the purpose specified in 40 CFR
60.4211(f)(2)(i) for a maximum of 100 hours per calendar year. Any operation for non-emergency
situations as allowed by paragraph (3) counts as part of the 100 hours per calendar year allowed by this
paragraph.
(i) Emergency stationary ICE may be operated for maintenance checks and readiness testing,
provided that the tests are recommended by federal, state or local government, the manufacturer,
the vendor, the regional transmission organization or equivalent balancing authority and
transmission operator, or the insurance company associated with the engine. The permittee may
petition for approval of additional hours to be used for maintenance checks and readiness testing,
but a petition is not required if the permittee maintains records indicating that federal, state, or
local standards require maintenance and testing of emergency ICE beyond 100 hours per calendar
year.
(3) Emergency stationary ICE may be operated for up to 50 hours per calendar year in non-emergency
situations, as specified in 40 CFR 60.4211(f)(3).
[Origin: 40 CFR 60 Subpart IIII]. [40 CFR 60.4211(f), 40 CFR 63 Subpart ZZZZ]

II.B.8.e.1 Monitoring:

Records required for this permit condition will serve as monitoring. Additionally, if the emergency
stationary CI internal combustion engine does not meet the standards applicable to non-emergency
engines, the permittee shall install a non-resettable hour meter prior to startup of the engine. [40
CFR 60.4209(a)]

II.B.8.e.2 Recordkeeping:

Documentation shall be kept that demonstrates compliance with this provision. Records shall be
kept in accordance with 40 CFR 60.4211(f), as applicable.

Starting with the model years in Table 5 of 40 CFR 60 Subpart IIII, if an emergency affected
emission unit does not meet the standards applicable to non-emergency engines in the applicable
48
model year, the permittee shall keep records of the operation of the engine in emergency and non-
emergency service that are recorded through the non-resettable hour meter. The permittee shall
record the time of operation of the engine and the reason the engine was in operation during that
time. [40 CFR 60.4214(b)]

Records shall be maintained as described in Provision I.S.1 of this permit.

II.B.8.e.3 Reporting:

The permittee shall submit an annual report in accordance with 40 CFR 60.4214(d), as applicable.
There are no additional reporting requirements for this provision except those specified in Section I
of this permit.

Status: Generators use logs are kept. The permittee recorded less than 30 hours of use during the calendar
year to the date of inspection. The monthly use shows 2 to 3 hours testing. This unit does have a non-
resettable meter. All use is logged, and records are maintained. Twelve-month totals as of February
29, 2024, were 22.5 hours for generator 915 and 24 hours for generator 916. In compliance.

II.B.9 Conditions on #SME SLAG: Slag Concentrator.

II.B.9.a Condition:

Visible emissions shall be no greater than 10 percent opacity from the slag concentrator bin, slag crushing &
grinding transfer points, and the crushers within the crushing and screening operation. [Origin: DAQE-
AN103460061-22, 40 CFR 60 Subpart OOO, R307-312-4]. [R307-401-8]

II.B.9.a.1 Monitoring:

A visual observation of each affected emission unit shall be performed on a weekly basis by an
individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. The
individual is not required to be a certified visible emissions observer. If any visible emissions other
than steam are observed, an opacity determination of that emission unit shall be performed by a
certified visible emissions observer in accordance with 40 CFR 60, Appendix A, Method 9, or other
EPA-approved testing method, as acceptable to the Director, within 24 hours of the initial
observation. For each affected emission unit, if no visible emissions are observed for eight
consecutive weeks the observation frequency shall be reduced to a monthly basis. If visible
emissions are observed during any monthly observation the frequency shall revert to a weekly basis.

Additionally, for affected emission units subject to 40 CFR 60 Subpart OOO:
(a) The permittee shall perform monthly periodic inspections to check that water is flowing to
discharge spray nozzles in the wet suppression system. The permittee shall initiate corrective
action within 24 hours and complete corrective action as expediently as practical if the
permittee finds that water is not flowing properly during an inspection of the water spray
nozzles.
(b) If an affected emission unit relies on water carryover from upstream water sprays to control
fugitive emissions, the permittee shall conduct periodic inspections of the upstream water
spray(s) that are responsible for controlling fugitive emissions from the affected emission unit.
These inspections shall be conducted as specified above, and the permittee shall designate
which upstream water spray(s) will be periodically inspected at the time of the initial
performance test required under 40 CFR 60.11 and 40 CFR 60.675.
(40 CFR 60.674(b)).
49

II.B.9.a.2 Recordkeeping:

Records of visual observations performed and data required by 40 CFR 60, Appendix A, Method 9,
or other EPA-approved testing method, as acceptable to the Director, for each determination shall be
maintained in accordance with Provision I.S.1 of this permit.

Additionally, for affected emission units subject to 40 CFR 60 Subpart OOO:
(a) The permittee shall record each periodic inspection of the water spray nozzles, including the
date of each inspection and any corrective actions taken, in a logbook (in written or electronic
format). The permittee shall keep the logbook onsite and make hard or electronic copies
(whichever is requested) of the logbook available to the Director upon request. (40 CFR
60.676(b)(1))
(b) If an affected emission unit that routinely uses wet suppression water sprays ceases operation of
the water sprays or is using a control mechanism to reduce fugitive emissions other than water
sprays during the monthly inspection (for example, water from recent rainfall), the logbook
entry required above shall specify the control mechanism being used instead of the water
sprays. (40 CFR 60.674(b)(2)).

II.B.9.a.3 Reporting:

Reports shall be submitted in accordance with Section I of this permit and, for affected emission
units subject to 40 CFR 60 Subpart OOO, as specified in 40 CFR 60.676(f) for applicable
performance tests.

Status: Opacity observations have been performed and recorded weekly. No excursions were noted in an
onsite records review, and no opacity was observed during this inspection. Monthly inspections are
done on water sprays and recorded in the operator’s logs, which includes weather-related issues. This
is a new requirement related to crushing silica (previously was brought in pre-crushed). In
compliance.

II.B.9.b Condition:

Emissions from the slag concentrator bin shall be controlled with water sprays. Treatment shall be of
sufficient frequency and quantity to maintain the surface material in a damp/moist condition. The degree of
control is a minimum of that required to meet the opacity limitation in Condition II.B.9.a of this permit.
Sprays shall not be required during periods of freezing temperatures. [Origin: DAQE-AN103460061-22].
[R307-401-8]

II.B.9.b.1 Monitoring:

Visual inspections of the water spray system(s) shall be made weekly to ensure proper operating
condition.

II.B.9.b.2 Recordkeeping:

A record of required inspections shall be maintained in accordance with Provision S.1 in Section I
of this permit.

II.B.9.b.3 Reporting:

50
There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Visual inspections of the water spray systems are conducted by operators daily instead of weekly. All
inspections are recorded in the daily Flash report. The unit is tracked on the compliance log sheets. In
compliance.

II.B.9.c Condition:

The crushing and screening operation shall not process more than 5,000 tons of material per calendar day
and 750,000 tons of material per rolling 12-month period. [Origin: DAQE-AN103460061-22]. [R307-401-8]

II.B.9.c.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.9.c.2 Recordkeeping:

Records of daily material processing shall be kept for all periods when the smelter is in operation.
Daily total material processing shall be determined by daily reports. The permittee shall use the
daily totals to calculate a monthly total. The permittee shall calculate a new 12-month total by the
20th day of each month using data from the previous 12 months. Records shall be maintained in
accordance with Provision I.S.1 of this permit.

II.B.9.c.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Daily production records are kept by the contractor and were reviewed on site. This operation
typically produced between 1500-2000 tons per day of operation based on the new crushing of silica.
There were 87,187 tons processed during the 12-month period ending February 29, 2024.

II.B.9.d Condition:

Water sprays or chemical dust suppression sprays shall be installed at the following points if they are not
enclosed or do not have baghouses to control fugitive emissions:
i. All crushers
ii. All stationary conveyor transfer points
iii. The crusher and screening units shall have water sprays at the input to the crusher and at the discharge
points from the crusher.
The sprays shall operate whenever dry conditions warrant or as determined necessary by the Director.
[Origin: DAQE-AN103460061-22]. [R307-309, R307-401-8]

II.B.9.d.1 Monitoring:

Visual inspections of the water spray system(s) shall be made weekly to ensure proper operating
condition.

II.B.9.d.2 Recordkeeping:

51
A log of the visual inspections containing all applicable information required by Provision I.S.1 of
this permit shall be kept for all periods of operation. Records shall be maintained in accordance with
Provision I.S.1 of this permit.

II.B.9.d.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Visual inspections of the water spray systems are conducted weekly by operations. All required points
have sprayers installed. In compliance.

II.B.9.e Condition:

Visible emissions shall be no greater than 7 percent opacity from all affected emission units constructed,
modified, or reconstructed on or after April 22, 2008, including, but not limited to, screens, transfer points,
and all other affected emission units associated with the crushing and screening operation. This condition
does not apply to the crushers within the crushing and screening operation. [Origin: 40 CFR 60 Subpart
OOO, R307-312-4]. [40 CFR 60.672(b), 40 CFR 60 Subpart OOO Table 3]

II.B.9.e.1 Monitoring:

For fugitive emissions from affected emission units without water sprays, the permittee shall
conduct a repeat performance test using 40 CFR 60, Appendix A, Method 9, according to 40 CFR
60.11 and 40 CFR 60.675, within five years of the previous performance test. (40 CFR 60 Subpart
OOO Table 3)

For affected emission units that use wet suppression, the permittee shall perform monthly periodic
inspections to check that water is flowing to the discharge spray nozzles in the wet suppression
system. The permittee shall initiate corrective action within 24 hours and complete corrective action
as expediently as practical if the permittee finds that water is not flowing properly during an
inspection of the water spray nozzles. (40 CFR 60.674(b))

If an affected emission unit relies on water carryover from upstream water sprays to control fugitive
emissions, then that unit is exempt from the 5-year repeat testing requirement provided it meets the
following criteria:
a) The permittee conducts periodic inspections of the upstream water spray(s) that are responsible
for controlling fugitive emissions from the affected emission unit as specified above, and
b) The permittee has designated which upstream water spray(s) will be periodically inspected at the
time of the initial performance test required under 40 CFR 60.11 and 40 CFR 60.675.
(40 CFR 60.674(b)(1)).

II.B.9.e.2 Recordkeeping:

The permittee shall record each periodic inspection of the water spray nozzles, including the date of
each inspection and any corrective actions taken, in a logbook (in written or electronic format). The
permittee shall keep the logbook onsite and make hard or electronic copies (whichever is requested)
of the logbook available to the Director upon request. (40 CFR 60.674(b), 40 CFR 60.676(b)(1))

If an affected emission unit that routinely uses wet suppression water sprays ceases operation of the
water sprays or is using a control mechanism to reduce fugitive emissions other than water sprays
52
during the monthly inspection (for example, water from recent rainfall), the logbook entry required
above shall specify the control mechanism being used instead of the water sprays. (40 CFR
60.674(b)(2))

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.9.e.3 Reporting:

For performance tests involving only Method 9 (40 CFR part 60 Appendix A-4) testing, the
permittee may provide a 7-day advance notification.(40 CFR 60.675(g)) Reports shall be submitted
in accordance with 40 CFR 60.676(f) and as specified in Section I of this permit.

Status: Opacity observations have been performed and recorded weekly. No excursions were noted in an
onsite records review, and no opacity was observed during this inspection. Monthly inspections are
done on water sprays and recorded in the operator’s log, which includes weather-related issues. This
is a new requirement related to crushing silica (previously was brought in pre-crushed). All units have
water sprays. In compliance.

II.B.10 Conditions on #SME 006: Smelter Limestone Flux Bin (Stack 6).

II.B.10.a Condition:

Emissions of PM10 shall be no greater than 0.3 lbs/hour (filterable) and 0.016 grains/dscfm (68 degrees F,
29.92" Hg). [Origin: DAQE-AN103460061-22]. [R307-401-8]

II.B.10.a.1 Monitoring:

Stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested every five years based on the date of the most recent stack
test. The source may also be tested at any time if directed by the Director. If the unit is not
operational when a stack test is due, it shall be tested within six months of resumed operation.
(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source shall attend a
pretest conference if determined necessary by the Director.
(c) Methods.
(1) Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other EPA-approved testing method, as acceptable to the
Director, and Occupational Safety and Health Administration (OSHA)-approved and/or
Mine Safety and Health Administration (MSHA)-approved access shall be provided to the
test location.
(2) PM10/PM2.5 (filterable):
For stacks in which no liquid drops are present, the following methods shall be used: 40
CFR 51, Appendix M, Methods 201 or 201a or other EPA-approved testing method
acceptable to the Director.

For stacks in which liquid drops are present, methods to eliminate the liquid drops shall be
explored. If no reasonable method to eliminate the drops exists, then the following
methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d, 5i or other EPA-
approved testing method acceptable to the Director. If using Method 5 or any variation of
Method 5, a scanning electron microscopy analysis or other equivalent method shall be
used to determine the fraction of PM10 and/or PM2.5, as approved by the Director.
53

PM10/PM2.5 (condensable):
Not applicable.
(3) 40 CFR 60, Appendix A, Method 2, Method 19, or other EPA-approved testing method, as
acceptable to the Director, shall be used to determine volumetric flow rate.
(d) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate
and any necessary conversion factors determined by the Director to give the results in the
specified units of the emission limitation.
(e) Conditions During Testing: Stack testing shall be performed during representative operations.
The production rate during all compliance tests shall be no less than 90% of the maximum
average hourly production rate achieved in a 24-hour period during the previous three (3) years.

II.B.10.a.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated test
method and Provision S.1 in Section I of this permit.

II.B.10.a.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of the
testing. Reports shall clearly identify results as compared to permit limits and indicate compliance
status. There are no additional reporting requirements for this provision except those specified in
Section I of this permit.

Status: Not applicable at this time. KUC has suspended operations at the Limestone Flux Bin. The limestone
flux operations are no longer needed. This plant was not operational at the time of the inspection and
has not operated for over 9 years. No stack testing has been conducted. The company is aware of
requirements if the unit does operate in future.

II.B.10.b Condition:

Visible emissions shall be no greater than 10 percent opacity. [Origin: DAQE-AN103460061-22]. [R307-
401-8]

II.B.10.b.1 Monitoring:

In lieu of monitoring via visible emissions observations, the permittee shall inspect the baghouse
during typical operating conditions to verify proper operation and maintenance according to the
manufacturer's recommendations. The permittee shall perform at least one inspection each month
for each baghouse that has operated during the month. At a minimum, the inspection shall include
the following.
a) Verify exhaust is properly ducted to the baghouse
b) Monitor cleaning cycle
c) Monitor discharge system to ensure dust is removed as needed
d) Check baghouse for normal or abnormal visual and audible conditions
e) Check drive components on fan
f) Spot check bag-seating condition
g) Check all hoses and clamps
h) Spot check for bag leaks and holes
i) Check duct for dust buildup
54

II.B.10.b.2 Recordkeeping:

In addition to recording the results of the monthly inspections, the permittee shall document all
maintenance performed on the baghouse, including bag replacement. Records shall be maintained in
accordance with Provision I.S.1 of this permit.

II.B.10.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Not applicable at this time. KUC has suspended operations at the Limestone Flux Bin. The limestone
flux operations are no longer needed. This plant was not operational at the time of the inspection and
has not operated for over 9 years. No stack testing has been conducted. The company is aware of
requirements if the unit does operate in future.

II.B.11 Conditions on #SME 013: Dry Matte Bin (Stack 13).

II.B.11.a Condition:

Emissions of PM10 shall be no greater than 0.3 lbs/hour (filterable) and 0.016 grains/dscfm (68 degrees F,
29.92" Hg). [Origin: DAQE-AN103460061-22]. [R307-401-8]

II.B.11.a.1 Monitoring:

Stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested every five years based on the date of the most recent stack
test. The source may also be tested at any time if directed by the Director.
(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source shall attend a
pretest conference if determined necessary by the Director.
(c) Methods.
(1) Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other EPA-approved testing method, as acceptable to the
Director, and Occupational Safety and Health Administration (OSHA)-approved and/or
Mine Safety and Health Administration (MSHA)-approved access shall be provided to the
test location.
(2) PM10/PM2.5 (filterable):
For stacks in which no liquid drops are present, the following methods shall be used: 40
CFR 51, Appendix M, Methods 201 or 201a or other EPA-approved testing method
acceptable to the Director.

For stacks in which liquid drops are present, methods to eliminate the liquid drops shall be
explored. If no reasonable method to eliminate the drops exists, then the following
methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d, 5i or other EPA-
approved testing method acceptable to the Director. If using Method 5 or any variation of
Method 5, a scanning electron microscopy analysis or other equivalent method shall be
used to determine the fraction of PM10 and/or PM2.5, as approved by the Director.

PM10/PM2.5 (condensable):
55
The back half condensable particulate emissions shall also be tested using 40 CFR 51,
Appendix M Method 202, or other EPA-approved testing method acceptable to the
Director. All particulate captured using Method 202 shall be considered PM2.5 and/or
PM10.

For filterable emission limits, condensable emissions shall not be used for compliance
demonstrations. For filterable + condensable emission limits, condensable emissions shall
be used for compliance demonstrations.
(3) 40 CFR 60, Appendix A, Method 2, Method 19, or other EPA-approved testing method, as
acceptable to the Director, shall be used to determine volumetric flow rate.
(d) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate
and any necessary conversion factors determined by the Director to give the results in the
specified units of the emission limitation.
(e) Conditions During Testing: Stack testing shall be performed during representative operations.
The production rate during all compliance tests shall be no less than 90% of the maximum
average hourly production rate achieved in a 24-hour period during the previous three (3) years.

II.B.11.a.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated test
method and Provision S.1 in Section I of this permit.

II.B.11.a.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of the
testing. Reports shall clearly identify results as compared to permit limits and indicate compliance
status. There are no additional reporting requirements for this provision except those specified in
Section I of this permit.

Status: Stack testing was conducted on August 10, 2021. Stack testing results were submitted to DAQ and
reviewed (DAQC-1390-21). DAQ-calculated results of the test for TSP were 0.0012 gr/dscf and 0.019
lbs/hr. Next testing is due in 2026. In compliance.

II.B.11.b Condition:

Visible emissions shall be no greater than 10 percent opacity from the baghouse. [Origin: DAQE-
AN103460061-22]. [R307-401-8]

II.B.11.b.1 Monitoring:

A visual observation of each affected emission unit shall be performed on a weekly basis by an
individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. The
individual is not required to be a certified visible emissions observer. If any visible emissions other
than steam are observed, an opacity determination of that emission unit shall be performed by a
certified visible emissions observer in accordance with 40 CFR 60, Appendix A, Method 9, or other
EPA-approved testing method, as acceptable to the Director, within 24 hours of the initial
observation. For each affected emission unit, if no visible emissions are observed for eight
consecutive weeks the observation frequency shall be reduced to a monthly basis. If visible
emissions are observed during any monthly observation the frequency shall revert to a weekly basis.

56
II.B.11.b.2 Recordkeeping:

Records of visual observations performed and data required by 40 CFR 60, Appendix A, Method 9,
or other EPA-approved testing method, as acceptable to the Director, for each determination shall be
maintained in accordance with Provision I.S.1 of this permit.

II.B.11.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Opacity observations have been performed and recorded weekly and are included on the compliance
log sheets. No excursions were noted in an onsite records review, and no opacity was observed during
this inspection. In compliance.

II.B.12 Conditions on #SME FSF/FCF: Flash Smelting & Converting Combined.

II.B.12.a Condition:

All gases produced during smelting and/or converting which enter the primary gas handling system shall
pass through an online sulfuric acid plant, except that during the startup and/or shutdown process of any
equipment, the gas emissions shall be ducted as necessary, either to the acid plant or to the secondary gas
system for control. [Origin: DAQE-AN103460061-22]. [R307-401-8]

II.B.12.a.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.12.a.2 Recordkeeping:

A log shall be kept of any time the gases produced during smelting and/or converting are not passed
through an online sulfuric acid plant. An additional log shall be kept and include the dates, times
and durations of all times any gases from smelting and/or converting bypass both the acid plant and
the secondary gas system. Records shall be maintained in accordance with Provision I.S.1 of this
permit.

II.B.12.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: All exhaust gases pass through the online sulfuric acid plant unless the facility is in startup/shutdown
mode, or a breakdown occurs. Records of startup/shutdown events and breakdowns are kept in the
operator’s logbook and reports have been submitted to the DAQ to comply with the breakdown rule
when applicable. Damper ampere outputs are also tracked electronically. In compliance.

II.B.13 Conditions on #SME 010: Slag Granulation Exhaust Scrubber (Stack 10)

II.B.13.a Condition:

57
Emissions of PM10 shall be no greater than 1.9 lbs/hour (24 hour average - calendar day) (filterable).
[Origin: DAQE-AN103460061-22]. [R307-401-8]

II.B.13.a.1 Monitoring:

Stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested every three years. The source may also be tested at any
time if directed by the Director.
(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source shall attend a
pretest conference if determined necessary by the Director.
(c) Methods.
(1) Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other EPA-approved testing method, as acceptable to the
Director, and Occupational Safety and Health Administration (OSHA)-approved and/or
Mine Safety and Health Administration (MSHA)-approved access shall be provided to the
test location.
(2) PM10/PM2.5 (filterable):
For stacks in which no liquid drops are present, the following methods shall be used: 40
CFR 51, Appendix M, Methods 201 or 201a or other EPA-approved testing method
acceptable to the Director.

For stacks in which liquid drops are present, methods to eliminate the liquid drops shall be
explored. If no reasonable method to eliminate the drops exists, then the following
methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d, 5i or other EPA-
approved testing method acceptable to the Director. If using Method 5 or any variation of
Method 5, a scanning electron microscopy analysis or other equivalent method shall be
used to determine the fraction of PM10 and/or PM2.5, as approved by the Director.

PM10/PM2.5 (condensable):
The back half condensable particulate emissions shall also be tested using 40 CFR 51,
Appendix M Method 202, or other EPA-approved testing method acceptable to the
Director. All particulate captured using Method 202 shall be considered PM2.5 and/or
PM10.

For filterable emission limits, condensable emissions shall not be used for compliance
demonstrations. For filterable + condensable emission limits, condensable emissions shall
be used for compliance demonstrations.
(3) 40 CFR 60, Appendix A, Method 2, Method 19, or other EPA-approved testing method, as
acceptable to the Director, shall be used to determine volumetric flow rate.
(d) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate
and any necessary conversion factors determined by the Director to give the results in the
specified units of the emission limitation.
(e) Conditions During Testing: Stack testing shall be performed during representative operations.
The production rate during all compliance tests shall be no less than 90 percent of the
maximum average hourly production rate achieved in any 24-hour period during the previous
three (3) years.

II.B.13.a.2 Recordkeeping:

58
Results of all stack testing shall be recorded and maintained in accordance with the associated test
method and Provision S.1 in Section I of this permit.

II.B.13.a.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of the
testing. Reports shall clearly identify results as compared to permit limits and indicate compliance
status. There are no additional reporting requirements for this provision except those specified in
Section I of this permit.

Status: Stack testing was conducted on SME 010b on August 16-17, 2022. Stack testing results were submitted
to DAQ and reviewed. DAQ-calculated results of the test for PM10 were 0.51 lbs/hr. Next testing is due
in 2025. In compliance.

II.B.13.b Condition:

Emissions of SO2 shall be no greater than 2.0 lbs/hour (24 hour average - calendar day). [Origin: DAQE-
AN103460061-22]. [R307-401-8]

II.B.13.b.1 Monitoring:

Stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested every three years. The source may also be tested at any
time if directed by the Director.
(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source shall attend a
pretest conference if determined necessary by the Director.
(c) Methods.
(1) Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other EPA-approved testing method, as acceptable to the
Director, and Occupational Safety and Health Administration (OSHA)-approved and/or
Mine Safety and Health Administration (MSHA)-approved access shall be provided to the
test location.
(2) 40 CFR 60, Appendix A, Method 6, 6A, 6B, or 6C, or other EPA-approved testing
method, as acceptable to the Director, shall be used to determine the pollutant emission
rate.
(3) 40 CFR 60, Appendix A, Method 2, Method 19, or other EPA-approved testing method, as
acceptable to the Director, shall be used to determine the volumetric flow rate.
(d) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate
and any necessary conversion factors determined by the Director to give the results in the
specified units of the emission limitation.
(e) Conditions During Testing: Stack testing shall be performed during representative operations.
The production rate during all compliance tests shall be no less than 90 percent of the
maximum average hourly production rate achieved in a 24-hour period during the previous
three (3) years.

II.B.13.b.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated test
method and Provision S.1 in Section I of this permit.
59

II.B.13.b.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of the
testing. Reports shall clearly identify results as compared to permit limits and indicate compliance
status. There are no additional reporting requirements for this provision except those specified in
Section I of this permit.

Status: Stack testing was conducted on SME 010b on August 16-17, 2022. Stack testing results were submitted
to DAQ and reviewed. DAQ-calculated results of the test for SO2 were 0.000028 lb/hr. Next testing is
due in 2025. In compliance.

II.B.13.c Condition:

Hours of operation shall be no greater than 3,504 hours per rolling 12-month period. [Origin: DAQE-
AN103460061-22]. [R307-401-8]

II.B.13.c.1 Monitoring:

Compliance with the limitation shall be demonstrated through a rolling 12-month total. The
permittee shall calculate a new 12-month total by the 20th day of each month using data from the
previous 12 months.

II.B.13.c.2 Recordkeeping:

An operator's log shall be maintained which shall include the results of the monitoring required. All
records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.13.c.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Hours are tracked on an electronic system. The FC Slag Scrubber tapping 12 month rolling hours as
of March 1, 2024, were 1333 hours. In compliance.

II.B.13.d Condition:

Visible emissions shall be no greater than 15 percent opacity. [Origin: DAQE-AN103460061-22]. [R307-
401-8]

II.B.13.d.1 Monitoring:

A visual observation of each affected emission unit shall be performed on a weekly basis by an
individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. The
individual is not required to be a certified visible emissions observer. If any visible emissions other
than steam are observed, an opacity determination of that emission unit shall be performed by a
certified visible emissions observer in accordance with 40 CFR 60, Appendix A, Method 9, or other
EPA-approved testing method, as acceptable to the Director, within 24 hours of the initial
observation.

60
II.B.13.d.2 Recordkeeping:

Records of visual observations performed and data required by 40 CFR 60, Appendix A, Method 9,
or other EPA-approved testing method, as acceptable to the Director, for each determination shall be
maintained in accordance with Provision I.S.1 of this permit.

II.B.13.d.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Opacity observations have been performed and recorded weekly. No excursions were noted in an
onsite records review, and no opacity was observed during this inspection. This unit is tracked on the
compliance log sheets. In compliance.

II.B.14 Conditions on #SME 029: Secondary Gas System Lime Silo (Stack 29).

II.B.14.a Condition:

Visible emissions shall be no greater than 10 percent opacity. [Origin: DAQE-AN103460061-22]. [R307-
401-8]

II.B.14.a.1 Monitoring:

In lieu of monitoring via visible emissions observations, the permittee shall inspect the baghouse
during typical operating conditions to verify proper operation and maintenance according to the
manufacturer's recommendations. The permittee shall perform at least one inspection each quarter
for each baghouse that has operated during the quarter. At a minimum, the inspection shall include
the following.
a) Verify exhaust is properly ducted to the baghouse
b) Monitor discharge system to ensure dust is removed as needed
c) Check baghouse for normal or abnormal visual and audible conditions
d) Spot check bag-seating condition
e) Check all hoses and clamps
f) Spot check from top of tube sheet for bag leaks and holes
g) Check discharge area for dust buildup

II.B.14.a.2 Recordkeeping:

In addition to recording the results of the quarterly inspections, the permittee shall document all
maintenance performed on the baghouse, including bag replacement. Records shall be maintained in
accordance with Provision I.S.1 of this permit.

II.B.14.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: This source has been inactive for 5 years.

II.B.15 Conditions on #SME 028: Anode Area Lime Silo (Stack 28).
61

II.B.15.a Condition:

Visible emissions shall be no greater than 10 percent opacity. [Origin: DAQE-AN103460061-22]. [R307-
401-8]

II.B.15.a.1 Monitoring:

In lieu of monitoring via visible emissions observations, the permittee shall inspect the baghouse
during typical operating conditions to verify proper operation and maintenance according to the
manufacturer's recommendations. The permittee shall perform at least one inspection each quarter
for each baghouse that has operated during the quarter. At a minimum, the inspection shall include
the following.
a) Verify exhaust is properly ducted to the baghouse
b) Monitor discharge system to ensure dust is removed as needed
c) Check baghouse for normal or abnormal visual and audible conditions
d) Spot check bag-seating condition
e) Check all hoses and clamps
f) Spot check from top of tube sheet for bag leaks and holes
g) Check discharge area for dust buildup

II.B.15.a.2 Recordkeeping:

In addition to recording the results of the quarterly inspections, the permittee shall document all
maintenance performed on the baghouse, including bag replacement. Records shall be maintained in
accordance with Provision I.S.1 of this permit.

II.B.15.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Records were reviewed onsite and indicated that baghouse inspections have been conducted each
week. These inspections included the stipulated checklist in accordance with this condition. Operators
fill out checklist and then submit to environmental section for inclusion on spreadsheet. In
compliance.

II.B.16 Conditions on #SME 015: Mold Coating (Barite) Bin (Stack 15).

II.B.16.a Condition:

Visible emissions shall be no greater than 10 percent opacity. [Origin: DAQE-AN103460061-22]. [R307-
401-8]

II.B.16.a.1 Monitoring:

In lieu of monitoring via visible emissions observations, the permittee shall inspect the baghouse
during typical operating conditions to verify proper operation and maintenance according to the
manufacturer's recommendations. The permittee shall perform at least one inspection each month
for each baghouse that has operated during the month. At a minimum, the inspection shall include
the following.
62
a) Verify exhaust is properly ducted to the baghouse
b) Monitor cleaning cycle
c) Monitor discharge system to ensure dust is removed as needed
d) Check baghouse for normal or abnormal visual and audible conditions
e) Check drive components on fan
f) Spot check bag-seating condition
g) Check all hoses and clamps
h) Spot check for bag leaks and holes
i) Check duct for dust buildup

II.B.16.a.2 Recordkeeping:

In addition to recording the results of the monthly inspections, the permittee shall document all
maintenance performed on the baghouse, including bag replacement. Records shall be maintained in
accordance with Provision I.S.1 of this permit.

II.B.16.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Records were reviewed onsite and indicated that baghouse inspections have been conducted each
week. These inspections included the stipulated checklist in accordance with this condition. Operators
fill out checklist and then submit to environmental section for inclusion on spreadsheet. In
compliance.

II.B.17 Conditions on #SME 008: Acid Plant Preheater (Stack 8).

II.B.17.a Condition:

Visible emissions shall be no greater than 10 percent opacity. [Origin: DAQE-AN103460061-22]. [R307-
401-8]

II.B.17.a.1 Monitoring:

In lieu of monitoring via visible emission observations, the type of fuel used shall be monitored to
demonstrate that only natural gas or propane is being combusted.

II.B.17.a.2 Recordkeeping:

The permittee shall maintain records of the types of fuel combusted. Records shall be maintained in
accordance with Provision I.S.1 of this permit.

II.B.17.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Natural gas is the only fuel used in the Acid Plant Preheater. Fuel records are used to track usage and
are kept by the source. In compliance.

63
II.B.17.b Condition:

Consumption of natural gas shall be no greater than 74,476 MMBtu per rolling 12-month period. [Origin:
DAQE-AN103460061-22]. [R307-401-8]

II.B.17.b.1 Monitoring:

Compliance shall be demonstrated with a rolling 12-month total. The permittee shall calculate a new
12-month total by the 20th day of each month using data from the previous 12 months. Natural gas
consumption shall be determined by individual gas meter readings reconciled against monthly
billing statements. Propane may be used as an alternate fuel supply during natural gas curtailment.

II.B.17.b.2 Recordkeeping:

Gas meter readings and billing statement reconciliations and rolling 12-month totals shall be
recorded on a monthly basis. Records of consumption shall be kept for all periods when the plant is
in operation. Results of monitoring shall be maintained in accordance with Provision I.S.1 of this
permit.

II.B.17.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Fuel records are used to track usage with Btu determined by usage and heat value. Records indicate
that 11,522 MMBtu of natural gas consumption occurred during the 12-month period ending March
1, 2024. In compliance.

II.B.18 Conditions on #SME 011b: Acid Plant.

II.B.18.a Condition:

Emissions of SO2 shall be no greater than 250 ppmdv based on a 6 hour block average, 170 ppmdv based on
a 24 hour average - calendar day, and 100 ppmdv based on an annual average. [Origin: DAQE-
AN103460061-22]. [40 CFR 60 Subpart P, R307-401-8]

II.B.18.a.1 Monitoring:

The permittee shall calibrate, maintain and operate a continuous monitoring system for measuring
the emissions of sulfur dioxide (SO2) concentration in accordance with UAC R307-170 and 40 CFR
60, Appendix B, Specification 2 - SO2.

To demonstrate compliance with an annual average emission limitation, the permittee shall calculate
a new annual average by the 20th day of each month using data from the previous 12 months. All
annual average emission limits shall be based on a rolling 12-month average using the daily
averages from the previous 12 months.

II.B.18.a.2 Recordkeeping:

Results of SO2 monitoring shall be recorded and maintained as required in R307-170 and as
described in Provision I.S.1 of this permit.
64

II.B.18.a.3 Reporting:

The permittee shall comply with the reporting provisions in R307-170-9 and any additional
reporting provisions contained in Section I of this permit.

The quarterly reports required in R307-170-9 are considered prompt notification of permit
deviations required in Provision I.S.2.c of this permit if all information required by Provision I.S.2.c
is included in the report.

Status: CEM is installed and operating. Relative accuracy test and cylinder gas audits, and quarterly SEDR
reports are submitted, reviewed, and kept in DAQ’s main source files. CEM reading the day of
inspection were 88.7 instant, 118.5 ppm 6-hour average and 121.5 ppm 24 hour average and 66.5 ppm
annual average; with trend lines showing these to be normal values for instant and yearly readings. In
compliance.

II.B.18.b Condition:

Emissions of Sulfuric Acid mist shall be no greater than 0.67 mg/scf (68 degrees F, 29.92" Hg). [Origin:
DAQE-AN103460061-22]. [R307-401-8]

II.B.18.b.1 Monitoring:

Stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested every three years. Every three years means the test must
be performed every third year and in the same calendar quarter in which the most recent test
was performed. The source may also be tested at any time if directed by the Director.
(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source shall attend a
pretest conference if determined necessary by the Director.
(c) Methods.
(1) Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other EPA-approved testing method, as acceptable to the
Director, and Occupational Safety and Health Administration (OSHA)-approved and/or
Mine Safety and Health Administration (MSHA)-approved access shall be provided to the
test location.
(2) 40 CFR 60, Appendix A, Method 8, or other EPA-approved testing method, as acceptable
to the Director, shall be used to determine the pollutant emission rate.
(3) 40 CFR 60, Appendix A, Method 2, Method 19, or other EPA-approved testing method, as
acceptable to the Director, shall be used to determine the volumetric flow rate.
(d) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate
and any necessary conversion factors determined by the Director to give the results in the
specified units of the emission limitation.
(e) Conditions During Testing. Stack testing shall be performed during representative operations.
The production rate during all compliance tests shall be no less than 90 percent of the
maximum average hourly production rate achieved in a 24-hour period during the previous
three (3) years.

II.B.18.b.2 Recordkeeping:

65
Results of all stack testing shall be recorded and maintained in accordance with the associated test
method and Provision S.1 in Section I of this permit.

II.B.18.b.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of the
testing. Reports shall clearly identify results as compared to permit limits and indicate compliance
status. There are no additional reporting requirements for this provision except those specified in
Section I of this permit.

Status: Stack testing on SME 011b was last conducted January 13, 2021. Stack testing results were submitted
to DAQ and reviewed in DAQC-361-21. DAQ-calculated results of the test for H2SO4 were 0.16
mg/scf. Next test is due in 2024. In compliance.

II.B.18.c Condition:

Visible emissions from the acid plant tail gas shall be no greater than 15 percent opacity. [Origin: DAQE-
AN103460061-22]. [40 CFR 60 Subpart P, R307-401-8]

II.B.18.c.1 Monitoring:

The permittee shall calibrate, maintain and operate a continuous monitoring system for measuring
the opacity of emissions in accordance with R307-170, UAC and 40 CFR 60, Appendix B,
Specification 1 - Opacity, and shall record the output of the system. The output shall be reviewed at
least monthly for compliance with the opacity limit. Compliance is to be based on the percent
opacity averaged over six consecutive minutes.

II.B.18.c.2 Recordkeeping:

Results of opacity measurements shall be recorded and maintained as required in R307-170 and as
described in Provision I.S.1 of this permit.

II.B.18.c.3 Reporting:

The permittee shall comply with the reporting provisions in R307-170-9 and any additional
reporting provisions contained in Section I of this permit.

The quarterly reports required in R307-170-9 are considered prompt notification of permit
deviations required in Provision I.S.2.c of this permit if all information required by Provision I.S.2.c
is included in the report.

Status: COM unit is installed and operational. Relative accuracy test and cylinder gas audits, and quarterly
SEDR reports are submitted, reviewed, and kept in DAQ’s main source files. COM reading the day of
the inspection was 1.5% instant, 1.4% one-minute average and 1.5% as six-minute average; with
trend showing this is in normal operating range. In compliance.

II.B.19 Conditions on #SME GLCS: Acid Plant Process Gas Leak Collection System.

II.B.19.a Condition:

66
Visible emissions from acid plant process gas leaks shall be no greater than 20 percent opacity. [Origin:
DAQE-AN103460061-22]. [R307-401-8]

II.B.19.a.1 Monitoring:

a) To minimize emissions from leaks of sulfur dioxide, sulfur trioxide, and other process
emissions, a visual opacity survey of each affected emission unit shall be performed on a weekly
basis by an individual trained on the observation procedures of 40 CFR 60, Appendix A, Method
9. The individual is not required to be a certified visible emissions observer. If any visible
emissions other than steam are observed, an opacity determination of that emission unit shall be
performed by a certified visible emissions observer in accordance with 40 CFR 60, Appendix A,
Method 9, or other EPA-approved testing method, as acceptable to the Director, within 24 hours
of the initial observation.
b) If visible emissions greater than 15 percent opacity are observed, best operational practices to
minimize the emissions by repair, correction, or control shall be initiated within 24 operating
hours of the observation to ensure leakage of gases to the ambient air are being controlled to
20% opacity or less. Best operational practices may include, but are not limited to, placement or
adjustment of negative pressure ductwork and collection hoses, welding or containment of
process gas leaks.

II.B.19.a.2 Recordkeeping:

A log of visual opacity surveys performed, opacity determinations, and data required by 40 CFR 60,
Appendix A, Method 9, or other EPA-approved testing method, as acceptable to the Director, shall
be maintained in accordance with Provision I.S.1 of this permit.

II.B.19.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Opacity observations have been performed and recorded weekly. No excursions were noted in an
onsite records review, and no opacity was observed during this inspection. In compliance.

II.B.20 Conditions on #SME 019: Hydrometallurgical Plant Limestone Bin (Stack 19).

II.B.20.a Condition:

Visible emissions shall be no greater than 10 percent opacity. [Origin: DAQE-AN103460061-22]. [R307-
401-8]

67
II.B.20.a.1 Monitoring:

In lieu of monitoring via visible emissions observations, the permittee shall inspect the baghouse
during typical operating conditions to verify proper operation and maintenance according to the
manufacturer's recommendations. The permittee shall perform at least one inspection each month
for each baghouse that has operated during the month. At a minimum, the inspection shall include
the following.
a) Verify exhaust is properly ducted to the baghouse
b) Monitor cleaning cycle
c) Monitor discharge system to ensure dust is removed as needed
d) Check baghouse for normal or abnormal visual and audible conditions
e) Check drive components on fan
f) Spot check bag-seating condition
g) Check all hoses and clamps
h) Spot check for bag leaks and holes
i) Check duct for dust buildup

II.B.20.a.2 Recordkeeping:

In addition to recording the results of the monthly inspections, the permittee shall document all
maintenance performed on the baghouse, including bag replacement. Records shall be maintained in
accordance with Provision I.S.1 of this permit.

II.B.20.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Records were reviewed onsite and indicated that baghouse inspections have been conducted each
week. These inspections included the stipulated checklist in accordance with this condition.
Inspections are done by operators and then submitted to the environmental section through the
tracking system. In compliance.

II.B.21 Conditions on #SME 020: Hydrometallurgical Plant Lime Bin (Stack 20).

II.B.21.a Condition:

Visible emissions shall be no greater than 10 percent opacity. [Origin: DAQE-AN103460061-22]. [R307-
401-8]

II.B.21.a.1 Monitoring:

In lieu of monitoring via visible emissions observations, the permittee shall inspect the baghouse
during typical operating conditions to verify proper operation and maintenance according to the
manufacturer's recommendations. The permittee shall perform at least one inspection each month
for each baghouse that has operated during the month. At a minimum, the inspection shall include
the following.
a) Verify exhaust is properly ducted to the baghouse
b) Monitor cleaning cycle
c) Monitor discharge system to ensure dust is removed as needed
d) Check baghouse for normal or abnormal visual and audible conditions
68
e) Check drive components on fan
f) Spot check bag-seating condition
g) Check all hoses and clamps
h) Spot check for bag leaks and holes
i) Check duct for dust buildup

II.B.21.a.2 Recordkeeping:

In addition to recording the results of the monthly inspections, the permittee shall document all
maintenance performed on the baghouse, including bag replacement. Records shall be maintained in
accordance with Provision I.S.1 of this permit.

II.B.21.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Records were reviewed onsite and indicated that baghouse inspections have been conducted each
week. These inspections included the stipulated checklist in accordance with this condition.
Inspections are done by operators and then submitted to the environmental section through the
tracking system. In compliance.

II.B.22 Conditions on #SME 030: Powerhouse Rentech Boiler

II.B.22.a Condition:

Emissions of NOx shall be no greater than 3.29 lbs/hour (30-day rolling average). [Origin: DAQE-
AN103460061-22]. [40 CFR 60.44b(l), R307-401-8]

II.B.22.a.1 Monitoring:

Compliance shall be demonstrated in accordance with 40 CFR 60.46b(e) and either 40 CFR
60.48b(g)(1) or 40 CFR 60.48b(g)(2). Either a CEM shall be used or an alternate plan to monitor
boiler operating conditions and predict NOx emission rates shall be used.
The CEM shall be maintained and operated in accordance with R307-170. For monitoring the boiler
NOx limit, either a CEM or the most recent alternate monitoring plan approved by the Director shall
be used.

II.B.22.a.2 Recordkeeping:

The permittee shall document all boiler tests and their results. A copy of the most recently approved
alternate monitoring plan shall be kept in a readily accessible location on site. All records and
results of monitoring shall be maintained in accordance with 40 CFR 60.49b, R307-170, and
Provision I.S.1 of this permit.

II.B.22.a.3 Reporting:

Notifications and reports shall be submitted as required in 40 CFR 60.49b, R307-170, and Provision
I.S.2 of this permit. Results of additional 30-day CEM tests (30-day test via certified NOx CEM per
40 CFR 60.46b(e)) shall be submitted within 60 days of the completion of the test.

69
Quarterly reports submitted in accordance with R307-170-9 or the most recently approved alternate
monitoring plan are considered prompt notification of permit deviations required in Provision I.S.2.c
of this permit if all information required by Provision I.S.2.c is included in the report.

Status: SME 030 (Smelter Auxiliary Superheated Steam Boiler) stack testing was conducted on October 4,
2023. Test results were submitted to DAQ and reviewed in DAQC-1347-23. DAQ- calculated results
were NOx- 2.10 lbs/hr. CEMS reading on inspection was 1.21 lbs/hr 30-day average. The company
submitted an alternate plan (revision 1A) with DAQ requested changes on November 1, 2021 (dated
October 29, 2021); which allows for monitoring of fuel flow and other parameters in place of CEMS
as allowed by the subpart. The plan was approved in DAQC-1489-21 letter to the company on
November 26, 2021. In compliance.

II.B.22.b Condition:

Emissions of NOx shall be no greater than 4.94 lbs/hour (calendar-day average). [Origin: DAQE-
AN103460061-22]. [R307-401-8]

II.B.22.b.1 Monitoring:

Stack testing to show compliance with the emission limitation shall be performed as specified
below:
(a) Frequency. Emissions shall be tested every three years. The source may also be tested at any
time if directed by the Director.
(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source shall attend a
pretest conference if determined necessary by the Director.
(c) Methods.
(1) Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other EPA-approved testing method, as acceptable to the
Director, and Occupational Safety and Health Administration (OSHA)-approved and/or
Mine Safety and Health Administration (MSHA)-approved access shall be provided to the
test location.
(2) 40 CFR 60, Appendix A, Method 7, 7A, 7B, 7C, 7D, 7E, or other EPA-approved testing
method, as acceptable to the Director, shall be used to determine the pollutant emission
rate.
(3) 40 CFR 60, Appendix A, Method 2, Method 19, or other EPA-approved testing method, as
acceptable to the Director, shall be used to determine the volumetric flow rate.
(d) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate
and any necessary conversion factors determined by the Director to give the results in the
specified units of the emission limitation.
(e) Conditions During Testing. Stack testing shall be performed during representative operations.
The production rate during all compliance tests shall be no less than 90% of the maximum
average hourly production rate achieved in a 24-hour period during the previous three (3) years.
For the initial test, the permittee shall propose in the test protocol, stack test conditions to
assure that stack testing is representative of actual operations.

II.B.22.b.2 Recordkeeping:

70
Results of monitoring and any information used to determine compliance shall be recorded for all
periods when the source is in operation. Records shall be maintained in accordance with Provision
I.S.1 of this permit.

II.B.22.b.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of the
testing. Reports shall clearly identify results as compared to permit limits and indicate compliance
status. There are no additional reporting requirements for this provision except those specified in
Section I of this permit.

Status: SME 030 (Smelter Auxiliary Superheated Steam Boiler) stack testing was conducted on October 4,
2023. Test results were submitted to DAQ and reviewed in DAQC-1347-23. DAQ- calculated results
were NOx- 2.10 lbs/hr. Next stack test is due in 2026. In compliance.

II.B.22.c Condition:

Visible emissions shall be no greater than 10 percent opacity. [Origin: DAQE-AN103460061-22]. [R307-
401-8]

II.B.22.c.1 Monitoring:

A visual observation of each affected emission unit shall be performed on a weekly basis by an
individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. The
individual is not required to be a certified visible emissions observer. If any visible emissions other
than steam are observed, an opacity determination of that emission unit shall be performed by a
certified visible emissions observer in accordance with 40 CFR 60, Appendix A, Method 9, or other
EPA-approved testing method, as acceptable to the Director, within 24 hours of the initial
observation. For each affected emission unit, if no visible emissions are observed for eight
consecutive weeks the observation frequency shall be reduced to a monthly basis. If visible
emissions are observed during any monthly observation the frequency shall revert to a weekly basis.

II.B.22.c.2 Recordkeeping:

Records of visual observations performed and data required by 40 CFR 60, Appendix A, Method 9,
or other EPA-approved testing method, as acceptable to the Director, for each determination shall be
maintained in accordance with Provision I.S.1 of this permit.

II.B.22.c.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Opacity observations have been performed and recorded weekly and tracked on the compliance log.
No excursions were noted in an onsite records review, and no opacity was observed during this
inspection. In compliance.

II.B.23 Conditions on #SME 026: Powerhouse Holman Boiler (Stack 26).

71
II.B.23.a Condition:

Visible emissions shall be no greater than 10 percent opacity. [Origin: DAQE-AN103460061-22]. [R307-
401-8]

II.B.23.a.1 Monitoring:

A visual observation of each affected emission unit shall be performed on a weekly basis by an
individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. The
individual is not required to be a certified visible emissions observer. If any visible emissions other
than steam are observed, an opacity determination of that emission unit shall be performed by a
certified visible emissions observer in accordance with 40 CFR 60, Appendix A, Method 9, or other
EPA-approved testing method, as acceptable to the Director, within 24 hours of the initial
observation. For each affected emission unit, if no visible emissions are observed for eight
consecutive weeks the observation frequency shall be reduced to a monthly basis. If visible
emissions are observed during any monthly observation the frequency shall revert to a weekly basis.

II.B.23.a.2 Recordkeeping:

Records of visual observations performed and data required by 40 CFR 60, Appendix A, Method 9,
or other EPA-approved testing method, as acceptable to the Director, for each determination shall be
maintained in accordance with Provision I.S.1 of this permit.

II.B.23.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Opacity observations have been performed and recorded weekly and tracked on the compliance log.
No excursions were noted in an onsite records review, and no opacity was observed during this
inspection. In compliance.

II.B.23.b Condition:

Emissions of NOx shall be no greater than 9.34 lbs/hour (30-day rolling average). [Origin: DAQE-
AN103460061-22]. [40 CFR 60.44b, R307-401-8]

II.B.23.b.1 Monitoring:

Compliance shall be demonstrated in accordance with 40 CFR 60.46b(e) and either 40 CFR
60.48b(g)(1) or 40 CFR 60.48b(g)(2). Either a CEM shall be used or an alternate plan to monitor
boiler operating conditions and predict NOx emission rates shall be used. The CEM shall be
maintained and operated in accordance with R307-170. For monitoring the boiler NOx limit, either a
CEM or the most recent alternate monitoring plan approved by the Director shall be used.

II.B.23.b.2 Recordkeeping:

The permittee shall document all boiler tests and their results. A copy of the most recently approved
alternate monitoring plan shall be kept in a readily accessible location on site. All records and
72
results of monitoring shall be maintained in accordance with 40 CFR 60.49b, R307-170, and
Provision I.S.1 of this permit.

II.B.23.b.3 Reporting:

Notifications and reports shall be submitted as required in 40 CFR 60.49b, R307-170, and Provision
I.S.2 of this permit. Results of additional 30-day CEM tests (30-day test via certified NOx CEM per
40 CFR 60.46b(e)) shall be submitted within 60 days of the completion of the test.

Quarterly reports submitted in accordance with R307-170-9 or the most recently approved alternate
monitoring plan are considered prompt notification of permit deviations required in Provision I.S.2.c
of this permit if all information required by Provision I.S.2.c is included in the report.

Status: KUC is using the alternate method (1998 initial approval and updated with Rentek boiler alt
monitoring plan in November 2021). Monthly smelter emissions reports have been submitted and
included exceedance information on the Holman boiler. No exceedances have been reported during
the 12-month period preceding this inspection. The 30-day averages from the tracking system during
the inspection were: 1.97 lbs/hr and 0.03. lbs/MMBtu. In compliance.

II.B.23.c Condition:

Emissions of NOx shall be no greater than 14.0 lbs/hour (calendar-day average). [Origin: DAQE-
AN103460061-22, SIP Section IX.H.2.i, SIP Section IX.H.12.j]. [R307-401-8, SIP Section IX.H.12.j, SIP
Section IX.H.2.i]

II.B.23.c.1 Monitoring:

a) Stack testing to show compliance with the emission limitation shall be performed as specified
below:
(1) Frequency. Emissions shall be tested every three years. The source may also be tested at
any time if directed by the Director.
(2) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source shall attend a
pretest conference if determined necessary by the Director.
(3) Methods.
(a) Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other EPA-approved testing method, as acceptable to the
Director, and Occupational Safety and Health Administration (OSHA)-approved
and/or Mine Safety and Health Administration (MSHA)-approved access shall be
provided to the test location.
(b) 40 CFR 60, Appendix A, Method 7E, or other EPA-approved testing method, as
acceptable to the Director, shall be used to determine the pollutant emission rate.
(c) 40 CFR 60, Appendix A, Method 2, or other EPA-approved testing method, as
acceptable to the Director, shall be used to determine the volumetric flow rate.
(4) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow
rate and any necessary conversion factors determined by the Director to give the results in
the specified units of the emission limitation.
(5) Conditions During Testing. Stack testing shall be performed during representative
operations. The production rate during all compliance tests shall be no less than 90% of the
73
maximum average hourly production rate achieved in a 24-hour period during the previous
three (3) years.
b) The permittee shall use an EPA-approved test method every three years and in between years
use CEMS or alternate method according to applicable NSPS standards. During
startup/shutdown operations, NOx emissions are monitored by CEMS or alternate methods in
accordance with applicable NSPS standards. (SIP Section IX.H.12.j state-only requirement).

II.B.23.c.2 Recordkeeping:

Results of monitoring and any information used to determine compliance shall be recorded for all
periods when the source is in operation. Records shall be maintained in accordance with Provision
I.S.1 of this permit. Any or all of these records shall be made available to the Director upon request.

II.B.23.c.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of the
testing. Reports shall clearly identify results as compared to permit limits and indicate compliance
status. There are no additional reporting requirements for this provision except those specified in
Section I of this permit.

Status: Stack testing for SIP requirements was done on October 5, 2023. Test results were submitted to and
reviewed by DAQ in DAQC-1347-23. DAQ- calculated results were NOx 7.2 lbs/hr. Next stack test is
due in 2026. In compliance.

II.B.24 Conditions on #SME 011: Main Stack (Stack 11).

II.B.24.a Condition:

Emissions of PM10 shall be no greater than:
i. 89.5 lbs/hour (24 hour average - calendar day) (filterable).
[Origin: DAQE-AN103460061-22, SIP Section IX.H.2.i]. [40 CFR 63 Subpart EEEEEE, R307-401-8,
SIP Section IX.H.2.i]
ii. 439 lbs/hour (filterable + condensable).
[Origin: DAQE-AN103460061-22, SIP Section IX.H.2.i]. [R307-401-8, SIP Section IX.H.2.i]

II.B.24.a.1 Monitoring:

A) The permittee shall calibrate, maintain and operate a system to continuously measure emissions
of particulate matter from the main stack in accordance with 40 CFR 63.8(b), (c), (f), (g). For
purposes of determining compliance with the emission limit, all particulate matter collected
shall be reported as PM10. To determine the mass emissions rate, the PM10 concentration as
determined by the smelter main stack continuous PM sampling system is multiplied by the
volumetric flow rate for the smelter main stack and any necessary conversion factors.
Compliance with the main stack emission limit for PM10 shall be demonstrated using the
smelter main stack continuous particulate sampling system to provide an average mass PM10
emission rate for each 24-hour period.
B) Stack testing shall be performed as specified below:
(1) Frequency. Emissions shall be tested once per calendar year. The source may also be tested
at any time if directed by the Director.
74
(2) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source shall attend a
pretest conference if determined necessary by the Director.
(3) Methods.
(a) Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other EPA-approved testing method, as acceptable to the
Director, and Occupational Safety and Health Administration (OSHA)-approved
and/or Mine Safety and Health Administration (MSHA)-approved access shall be
provided to the test location.
(b) PM10/PM2.5 (filterable):
For stacks in which no liquid drops are present, the following methods shall be used:
40 CFR 51, Appendix M, Methods 201 or 201a or other EPA-approved testing method
acceptable to the Director.

For stacks in which liquid drops are present, methods to eliminate the liquid drops
shall be explored. If no reasonable method to eliminate the drops exists, then the
following methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d, 5i or
other EPA-approved testing method acceptable to the Director. If using Method 5 or
any variation of Method 5, a scanning electron microscopy analysis or other
equivalent method shall be used to determine the fraction of PM10 and/or PM2.5, as
approved by the Director.

PM10/PM2.5 (condensable):
The back half condensable particulate emissions shall also be tested using 40 CFR 51,
Appendix M Method 202, or other EPA-approved testing method acceptable to the
Director. All particulate captured using Method 202 shall be considered PM2.5 and/or
PM10.

For filterable emission limits, condensable emissions shall not be used for compliance
demonstrations. For filterable + condensable emission limits, condensable emissions
shall be used for compliance demonstrations.
(c) 40 CFR 60, Appendix A, Method 2, Method 19, or other EPA-approved testing
method, as acceptable to the Director, shall be used to determine volumetric flow rate.
(4) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow
rate and any necessary conversion factors determined by the Director to give the results in
the specified units of the emission limitation.
(5) Conditions During Testing. Stack testing shall be performed during representative
operations. The production rate during all compliance tests shall be no less than 90% of the
maximum average hourly production rate achieved in a 24-hour period during the previous
three (3) years.

II.B.24.a.2 Recordkeeping:

A) The results of PM10 monitoring and calculated average mass PM10 emission rate for each 24-
hour period shall be recorded and maintained. Collected data shall be available for inspection
when the required laboratory analysis is completed. Additionally, the permittee shall maintain
records of the following:
i) parameters for calculating an average mass PM10 emission rate for each 24-hour period,
ii) parameters for demonstrating data validation procedures are conducted,
iii) performance evaluations of the continuous particulate sampling system, and
75
iv) maintenance activities and adjustments conducted on the continuous particulate sampling
system.
Records shall be maintained in accordance with Provision I.S.1 of this permit and shall be
available to the director at any time.
B) Results of all stack testing shall be recorded and maintained in accordance with the associated
test method and Provision I.S.1 of this permit.

II.B.24.a.3 Reporting:

A) A summary of the 24-hour averages shall be submitted to the Director by the 20th day of each
month for the previous month.
B) The results of stack testing shall be submitted to the Director within 60 days of completion of
the testing. Reports shall clearly identify results as compared to permit limits and indicate
compliance status. There are no additional reporting requirements for this provision except
those specified in Section I of this permit.

Status: Stack testing was conducted on SME 011 on 12/21-202/2023. Test results were submitted to DAQ and
reviewed in DAQC-219-23. DAQ- calculated results were PM10 -7.45 lbs/hr (filterable) and PM10
(total) 24.0 lbs/hr. PM2.5 – 6.0 lbs/hr (filterable) and PM2.5 (total) – 23.0 lbs/hr. Daily readings are
done by filter weights with collections done 2am to 2am. All daily readings are reported in the
monthly report with any non-readable or missing data points noted. No exceedance of this limit has
been reported. In compliance.

II.B.24.b Condition:

Emissions of SO2 shall be no greater than:
i. 552 lbs/hour based on a 3 hour rolling average
[Origin: DAQE-AN103460061-22, SIP Section IX.H.2.i, SIP Section IX.H.12.j]. [R307-401-8, SIP
Section IX.H.12.j, SIP Section IX.H.2.i]
ii. 422 lbs/hour based on a 24 hour average - calendar day
[Origin: DAQE-AN103460061-22, SIP Section IX.H.2.i, SIP Section IX.H.12.j]. [R307-401-8, SIP
Section IX.H.12.j, SIP Section IX.H.2.i]
iii. 211 lbs/hour based on an annual average
[Origin: DAQE-AN103460061-22]. [R307-401-8]

II.B.24.b.1 Monitoring:

The permittee shall calibrate, maintain and operate a continuous monitoring system for measuring
the emissions of sulfur dioxide (SO2) discharged to the atmosphere and stack gas volumetric flow
rates in accordance with UAC R307-170 including the requirements for annual Relative Accuracy
Test Audits and quarterly Relative Accuracy Audits or Cylinder Gas Audits. The required Relative
Accuracy Test Audits, Relative Accuracy Audits, and Cylinder Gas Audits shall be conducted
following procedures contained in Appendix B, Specification 2, Part 60, Title 40, CFR and
Appendix F, Part 60, Title 40, CFR. Acceptable methods for the annual Relative Accuracy Test
Audits include 40 CFR 60, Appendix A, reference methods 6 or 6c. The permittee shall perform
Appendix E, Part 52, Title 40, CFR Performance Specification procedures on the stack gas flow rate
measurement system, if directed by the Director, in the event that the results of the quarterly and
annual tests required above demonstrate that the SO2 monitoring system is not performing properly.
Failure to measure at least 95 percent of the hours during which emissions occurred in any quarter
or failure to measure any 18 consecutive hours of emissions data shall constitute a violation. Any
hour for which the measurements comply with R307-170 UAC shall be considered as measured.
76
Any hours for which the emissions data are greater than 20 percent in error will be considered to
have not been measured. During periods of malfunction or maintenance of the stack gas temperature
and velocity measurement instrumentation, the permittee may estimate stack gas flow rate. These
estimates will be considered as measurements. No more than 10 percent of the flow rates in any one
month shall be estimated.

During startup/shutdown operations, SO2 emissions shall be monitored by CEMS or alternate
methods in accordance with applicable NSPS standards. (SIP Section IX.H.12.j state-only
requirement)

To demonstrate compliance with an annual average emission limitation, the permittee shall calculate
a new annual average by the 20th day of each month using data from the previous 12 months. All
annual average emission limits shall be based on a rolling 12-month average using the daily
averages from the previous 12 months.

II.B.24.b.2 Recordkeeping:

Results of SO2 measurements shall be recorded and maintained as required in R307-170 and as
described in Provision I.S.1 of this permit. The permittee shall express the measurements as pounds
of SO2 emitted per hour calculated at the end of each day for the preceding 24 hours and calculated
at the end of each hour for the preceding 3-hour period. Additionally, the following data shall also
be recorded: the total number of hourly periods during the month in which measurements were not
taken; for any periods where loss of measurement is greater than three continuous hours, the reason
for loss of measurement in each period; the dates and number of exceedances on which the 3- and
24-hour emissions averages exceeded the applicable emission level; calculations used to derive the
estimated flow rates and a list of the periods where stack gas flow rate was estimated in each month,
and all conversion values used to derive the 3-, 24-hour, and annual average emissions for SO2,
including temperature and differential pressure of stack gases.

II.B.24.b.3 Reporting:

All audit and accuracy test results shall be submitted to the Director within 60 days after the audit or
accuracy test is completed. Data, reports, or results required to be submitted to the Director shall be
deemed to be verified and accepted as valid and not subject to challenge and shall be used by the
Director in determining compliance with the main smelter stack SO2 emission limits, unless, within
30 days of the time of submittal the permittee or the Director provides evidence that the data,
results, or reports or any part thereof, are greater than 20 percent in error. Any additional reporting
required by R307-170 and Provision I.S.1 of this permit shall also be met. The quarterly reports
required in R307-170-9 are considered prompt notification of permit deviations required in
Provision I.S.2.c of this permit if all information required by Provision I.S.2.c is included in the
report.

Status: SO2 CEM is installed and operational. Relative accuracy test and cylinder gas audits and quarterly
SEDR reports are submitted, reviewed, and kept in DAQ’s main source files. Monthly reports
including all required data have been submitted by the 20th of each month. These reports are reviewed
for accuracy and kept in DAQ’s source files. CEM readings during the inspection were 87.77 ppm
instant, 92.6 lbs/hr 3-hour average, 85.15 lbs/hr as 24-hour average and 108.35 lbs/hr as annual
average. Average lbs/hr conversions shown for 3-hour, 24- hour and annual averages only. In
compliance.

II.B.24.c Condition:
77

Visible emissions shall be no greater than 20 percent opacity. [Origin: DAQE-AN103460061-22]. [R307-
401-8]

II.B.24.c.1 Monitoring:

The permittee shall calibrate, maintain and operate a continuous monitoring system for measuring
the opacity of emissions in accordance with R307-170, UAC and 40 CFR 60, Appendix B,
Specification 1 - Opacity, and shall record the output of the system. The output shall be reviewed at
least monthly for compliance with the opacity limit. Compliance is to be based on the percent
opacity averaged over six consecutive minutes.

II.B.24.c.2 Recordkeeping:

Results of opacity measurements shall be recorded and maintained as required in R307-170 and as
described in Provision I.S.1 of this permit.

II.B.24.c.3 Reporting:

The permittee shall comply with the reporting provisions in R307-170-9 and any additional
reporting provisions contained in Section I of this permit.

The quarterly reports required in R307-170-9 are considered prompt notification of permit
deviations required in Provision I.S.2.c of this permit if all information required by Provision I.S.2.c
is included in the report.

Status: COM is installed and operational. Reports are sent, reviewed, and kept in the main source files.
Reading during the inspection was 4.65% as instant reading, 3.42% as one-minute average and 3.76%
as 6-minute average. In compliance.

II.B.24.d Condition:

Emissions of Lead shall be no greater than 1.3 lbs/hour (annual average). [Origin: DAQE-AN103460061-
22]. [R307-401-8]

II.B.24.d.1 Monitoring:

The permittee shall determine lead emissions from the main stack using the main stack particulate
data and laboratory analysis of the material collected by the continuous stack particulate sampler. If
the permittee cannot monitor the lead emissions using the continuous particulate sampler, the test
method shall be submitted for approval or may be assigned by the Director. The permittee shall
monitor lead emissions in accordance with the most recent monitoring plan approved by the
Director.

To demonstrate compliance with an annual average emission limitation, the permittee shall calculate
a new annual average by the 20th day of each month using data from the previous 12 months. All
annual average emission limits shall be based on a rolling 12-month average using the daily
averages from the previous 12 months.

II.B.24.d.2 Recordkeeping:

78
The permittee shall keep appropriate records of the particulate sampling at the main stack and
laboratory analysis of the lead in the particulate, as outlined in the monitoring plan. Results of
monitoring and all records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.24.d.3 Reporting:

The permittee shall report as specified in the monitoring plan and as specified in Section I of this
permit.

Status: Lead emissions are based on PM filter rates and analysis of lead content. 12-month rolling average
lead emissions reports have been submitted to DAQ monthly and include the required information.
The annual average has not exceeded the 1.3 lbs/hr limit. Copies of these monthly reports are kept in
DAQ’s source files. In compliance.

II.B.24.e Condition:

Emissions of NOx shall be no greater than:
i. 35.0 lbs/hour (annual average).
[Origin: DAQE-AN103460061-22]. [R307-401-8]
ii. 146.5 lbs/hour (daily average).
[Origin: DAQE-AN103460061-22, SIP Section IX.H.2.i, SIP Section IX.H.12.j]. [R307-401-8]

II.B.24.e.1 Monitoring:

The permittee shall calibrate, maintain and operate a continuous monitoring system for measuring
the emissions of NOx discharged to the atmosphere and stack gas volumetric flow rates in
accordance with UAC R307-170 including the requirements for annual Relative Accuracy Test
Audits and quarterly Relative Accuracy Audits or Cylinder Gas Audits. The monitoring system shall
comply with all applicable sections of R307-170, UAC and 40 CFR 60, Appendix B, Specification 2
- Oxides of Nitrogen. The required Relative Accuracy Test Audits, Relative Accuracy Audits, and
Cylinder Gas Audits shall be conducted following procedures contained in Appendix B,
Specification 2, Part 60, Title 40, CFR and Appendix F, Part 60, Title 40, CFR. Acceptable methods
for the annual Relative Accuracy Test Audits include 40 CFR 60, Appendix A, reference method 7
or 7E. The permittee shall perform Appendix E, Part 52, Title 40, CFR Performance Specification
procedures on the stack gas flow rate measurement system, if directed by the Director, in the event
that the results of the quarterly and annual tests required above demonstrate that the NOx monitoring
system is not performing properly. During periods of malfunction or maintenance of the stack gas
temperature and velocity measurement instrumentation, the permittee may estimate stack gas flow
rate. These estimates will be considered as measurements. No more than 10 percent of the flow rates
in any one month shall be estimated.

During startup/shutdown operations, NOx emissions shall be monitored by CEMS or alternate
methods in accordance with applicable NSPS standards. (SIP Section IX.H.12.j state-only
requirement)

To demonstrate compliance with an annual average emission limitation, the permittee shall calculate
a new annual average by the 20th day of each month using data from the previous 12 months. All
annual average emission limits shall be based on a rolling 12-month average using the daily
averages from the previous 12 months.

II.B.24.e.2 Recordkeeping:
79

Results of NOx measurements shall be recorded and maintained as required in R307-170 and as
described in Provision I.S.1 of this permit. The permittee shall record the output of the systems, for
measuring the NOx emissions on the main stack. Measurement results shall be expressed as pounds
of NOx emitted per hour calculated at the end of each day for the preceding 24 hours. Additionally,
the following data shall also be recorded: the total number of hourly periods during the month in
which measurements were not taken; for any periods where loss of measurement is greater than
three continuous hours, the reason for loss of measurement in each period; the dates and number of
exceedances on which the annual emissions average based on hourly emissions exceeded the
applicable emissions level for the month being reported, the daily NOx averages, calculations used
to derive the estimated flow rates and a list of the periods where stack gas flow rate was estimated in
each month, and all conversion values used to derive the 24 hour average and annual average for
NOx including temperature and differential pressure of stack gases.

II.B.24.e.3 Reporting:

All audit and accuracy test results shall be submitted to the Director within 60 days after the audit or
accuracy test is completed. Data, reports, or results required to be submitted to the Director shall be
deemed to be verified and accepted as valid and not subject to challenge and shall be used by the
Director in determining compliance with the main smelter stack NOx emission limits, unless, within
30 days of the time of submittal the permittee or the Director provides evidence that the data,
results, or reports or any part thereof, are greater than 20 percent in error. Any additional reporting
required by R307-170 and Provision I.S.1 of this permit shall also be met.

The quarterly reports required in R307-170-9 are considered prompt notification of permit
deviations required in Provision I.S.2.c of this permit if all information required by Provision I.S.2.c
is included in the report.

Status: CEM is installed and operational. Reports are submitted monthly and reviewed by DAQ staff. All
reports are in the main source files. No exceedance of the NOX limit has been reported. Reading
during the inspection was 21.36 lbs/hr as hourly average and 21.36 lbs/hr as a daily average. Yearly
averages are reported in the monthly reports. The annual lbs/hr average was 20.72 observed during
the inspection. In compliance.

II.B.24.f Condition:

Emissions of PM2.5 shall be no greater than:
i. 85 lbs/hour (filterable)
ii. 434 lbs/hr (filterable + condensable)
[Origin: DAQE-AN103460061-22, SIP Section IX.H.12.j]. [R307-401-8, SIP Section IX.H.12.j]

II.B.24.f.1 Monitoring:

To demonstrate compliance with each limit, stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested once per calendar year. The source may also be tested at
any time if directed by the Director.
(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source shall attend a
pretest conference if determined necessary by the Director.
(c) Methods.
80
(1) Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other EPA-approved testing method, as acceptable to the
Director, and Occupational Safety and Health Administration (OSHA)-approved and/or
Mine Safety and Health Administration (MSHA)-approved access shall be provided to the
test location.
(2) PM10/PM2.5 (filterable):
For stacks in which no liquid drops are present, the following methods shall be used: 40
CFR 51, Appendix M, Methods 201 or 201a or other EPA-approved testing method
acceptable to the Director.

For stacks in which liquid drops are present, methods to eliminate the liquid drops shall be
explored. If no reasonable method to eliminate the drops exists, then the following
methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d, 5i or other EPA-
approved testing method acceptable to the Director. If using Method 5 or any variation of
Method 5, a scanning electron microscopy analysis or other equivalent method shall be
used to determine the fraction of PM10 and/or PM2.5, as approved by the Director.

PM10/PM2.5 (condensable):
The back half condensable particulate emissions shall also be tested using 40 CFR 51,
Appendix M Method 202, or other EPA-approved testing method acceptable to the
Director. All particulate captured using Method 202 shall be considered PM2.5 and/or
PM10.

For filterable emission limits, condensable emissions shall not be used for compliance
demonstrations. For filterable + condensable emission limits, condensable emissions shall
be used for compliance demonstrations.
(3) 40 CFR 60, Appendix A, Method 2, Method 19, or other EPA-approved testing method, as
acceptable to the Director, shall be used to determine volumetric flow rate.
(d) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate
and any necessary conversion factors determined by the Director to give the results in the
specified units of the emission limitation.
(e) Conditions During Testing: Stack testing shall be performed during representative operations.
The production rate during all compliance tests shall be no less than 90% of the maximum
average hourly production rate achieved in a 24-hour period during the previous three (3) years.

II.B.24.f.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated test
method and Provision S.1 in Section I of this permit.

II.B.24.f.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of the
testing. Reports shall clearly identify results as compared to permit limits and indicate compliance
status. There are no additional reporting requirements for this provision except those specified in
Section I of this permit.

Status: Stack testing was conducted on SME 011 on 12/21-202/2023. Test results were submitted to DAQ and
reviewed in DAQC-219-23. DAQ- calculated results were PM10 -7.45 lbs/hr (filterable) and PM10
(total) 24.0 lbs/hr. PM2.5 – 6.0 lbs/hr (filterable) and PM2.5 (total) – 23.0 lbs/hr. Daily readings are
81
done by filter weights with collections done 2am to 2am. All daily readings are reported in the
monthly report with any non-readable or missing data points noted. No exceedance of this limit has
been reported. In compliance.

II.B.25 Conditions on #SME 027: Recycle Crushing and Storage Building (Stack 27).

II.B.25.a Condition:

Visible emissions shall be no greater than 10 percent opacity. [Origin: DAQE-AN103460061-22]. [R307-
401-8]

II.B.25.a.1 Monitoring:

A visual observation of each affected emission unit shall be performed on a monthly basis by an
individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. The
individual is not required to be a certified visible emissions observer. If any visible emissions other
than steam are observed, an opacity determination of that emission unit shall be performed by a
certified visible emissions observer in accordance with 40 CFR 60, Appendix A, Method 9, or other
EPA-approved testing method, as acceptable to the Director, within 24 hours of the initial
observation.

II.B.25.a.2 Recordkeeping:

Records of visual observations performed and data required by 40 CFR 60, Appendix A, Method 9,
or other EPA-approved testing method, as acceptable to the Director, for each determination shall be
maintained in accordance with Provision I.S.1 of this permit.

II.B.25.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Opacity observations have been performed and recorded monthly. No excursions were noted in an
onsite records review, and no opacity was observed during this inspection. In compliance.

II.B.26 Conditions on #SME PH: Powerhouse

II.B.26.a Condition:

The permittee shall maintain records of the amount of each fuel combusted during each calendar month for
the superheater. [Origin: 40 CFR 60 Subpart Dc]. [40 CFR 60.48c(g)]

II.B.26.a.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.26.a.2 Recordkeeping:

Gas meter readings shall be recorded on a monthly basis for the previous month and shall be
maintained as described in Provision I.S of this permit.

82
II.B.26.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Records are kept of fuel use. Fuel use is used in calculations below. In compliance.

II.B.26.b Condition:

Emissions of NOx shall not exceed 23.3 tons per rolling 12-month period from the Holman boiler and
Rentech boiler combined. [Origin: DAQE-AN103460061-22]. [R307-401-8]

II.B.26.b.1 Monitoring:

Compliance with the limitation shall be demonstrated through a rolling 12-month total. The
permittee shall calculate a new 12-month total by the 20th day of each month using data from the
previous 12 months. Monthly totals of NOx emissions from each boiler shall be based on the
following.
a) For the Holman boiler, the permittee shall use the 30-day average NOx emission rate (lb/hr)
determined in Condition II.B.23.b.1 for each calendar month and the hours of operation for the
Holman boiler during each calendar month.
b) For the Rentech boiler, the permittee shall use the 30-day average NOx emission rate (lb/hr)
determined in Condition II.B.22.a.1 for each calendar month and the hours of operation for the
Rentech boiler during each calendar month.

II.B.26.b.2 Recordkeeping:

An operations log shall be maintained that includes the results of the required monitoring. Records
used for compliance demonstration, including emission rates, hours of operation, calculations, and
the rolling 12-month totals, shall be recorded in the operations log each month. Records shall be
kept for all periods when the plant is in operation and shall be maintained in accordance with
Provision I.S.1 of this permit.

II.B.26.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: The company has a spreadsheet to show all required items and calculations. Review shows all
required items and correct calculations. The NOx emissions for the twelve-month period ending
March 1, 2024, were 12.01 tons. In compliance.

II.B.27 Conditions on #SME NG: Pyrometallurgical Process Group

II.B.27.a Condition:

Consumption of natural gas shall be no greater than 1,947,847 MMBtu per rolling 12-month period. [Origin:
DAQE-AN103460061-22]. [R307-401-8]

II.B.27.a.1 Monitoring:

83
Compliance shall be demonstrated with a rolling 12-month total. The permittee shall calculate a new
12-month total by the 20th day of each month using data from the previous 12 months. Natural gas
consumption shall be determined by individual gas meter readings reconciled against monthly
billing statements. Propane may be used as an alternate fuel supply during natural gas curtailment.

II.B.27.a.2 Recordkeeping:

Gas meter readings and billing statement reconciliations and rolling 12-month totals shall be
recorded on a monthly basis. Records of consumption shall be kept for all periods when the plant is
in operation. Results of monitoring shall be maintained in accordance with Provision I.S.1 of this
permit.

II.B.27.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Natural gas consumption from Group 2 natural gas consumption group (Hydrometallurgical process)
was recorded at 1,115,691 MMBtu for the 12-month period ending February 28, 2024. This was
previously called SME NG#2 group (Hydometallugical process). In compliance.

II.B.28 Conditions on #SME 022: Smelter Laboratory Sample Preparation (Stack 22).

II.B.28.a Condition:

Visible emissions shall be no greater than 10 percent opacity. [Origin: DAQE-AN103460061-22]. [R307-
401-8]

II.B.28.a.1 Monitoring:

A visual observation of each affected emission unit shall be performed on a monthly basis by an
individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. The
individual is not required to be a certified visible emissions observer. If any visible emissions other
than steam are observed, an opacity determination of that emission unit shall be performed by a
certified visible emissions observer in accordance with 40 CFR 60, Appendix A, Method 9, or other
EPA-approved testing method, as acceptable to the Director, within 24 hours of the initial
observation.

II.B.28.a.2 Recordkeeping:

Records of visual observations performed and data required by 40 CFR 60, Appendix A, Method 9,
or other EPA-approved testing method, as acceptable to the Director, for each determination shall be
maintained in accordance with Provision I.S.1 of this permit.

II.B.28.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Opacity observations have been performed and recorded monthly. No excursions were noted in an
onsite records review, and no opacity was observed during this inspection. In compliance.
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II.B.29 Conditions on #SME 017a, c: Vacuum Cleaning Systems (Stacks 17a, 17c).

II.B.29.a Condition:

Combined emissions of PM10 shall be no greater than 0.7 lbs/hour (filterable) and 0.016 grains/dscfm (68
degrees F, 29.92" Hg). [Origin: DAQE-AN103460061-22]. [R307-401-8]

II.B.29.a.1 Monitoring:

Stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested every five years based on the date of the most recent stack
test. The source may also be tested at any time if directed by the Director. If the unit is not
operational when a stack test is due, it shall be tested within six months of resumed operation.
(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source shall attend a
pretest conference if determined necessary by the Director.
(c) Methods.
(1) Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other EPA-approved testing method, as acceptable to the
Director, and Occupational Safety and Health Administration (OSHA)-approved and/or
Mine Safety and Health Administration (MSHA)-approved access shall be provided to the
test location.
(2) PM10/PM2.5 (filterable):
For stacks in which no liquid drops are present, the following methods shall be used: 40
CFR 51, Appendix M, Methods 201 or 201a or other EPA-approved testing method
acceptable to the Director.

For stacks in which liquid drops are present, methods to eliminate the liquid drops shall be
explored. If no reasonable method to eliminate the drops exists, then the following
methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d, 5i or other EPA-
approved testing method acceptable to the Director. If using Method 5 or any variation of
Method 5, a scanning electron microscopy analysis or other equivalent method shall be
used to determine the fraction of PM10 and/or PM2.5, as approved by the Director.

PM10/PM2.5 (condensable):
The back half condensable particulate emissions shall also be tested using 40 CFR 51,
Appendix M Method 202, or other EPA-approved testing method acceptable to the
Director. All particulate captured using Method 202 shall be considered PM2.5 and/or
PM10.

For filterable emission limits, condensable emissions shall not be used for compliance
demonstrations. For filterable + condensable emission limits, condensable emissions shall
be used for compliance demonstrations.
(3) 40 CFR 60, Appendix A, Method 2, Method 19, or other EPA-approved testing method, as
acceptable to the Director, shall be used to determine volumetric flow rate.
(d) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate
and any necessary conversion factors determined by the Director to give the results in the
specified units of the emission limitation.
85
(e) Conditions During Testing: Stack testing shall be performed during representative operations.
The production rate during all compliance tests shall be no less than 90% of the maximum
average hourly production rate achieved in a 24-hour period during the previous three (3) years.

II.B.29.a.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated test
method and Provision S.1 in Section I of this permit.

II.B.29.a.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of the
testing. Reports shall clearly identify results as compared to permit limits and indicate compliance
status. There are no additional reporting requirements for this provision except those specified in
Section I of this permit.

Status: None of the three systems are currently operating. In the event of operation, DAQ will be notified,
stack testing will be performed, and baghouse checks will be initiated.

II.B.29.b Condition:

Visible emissions shall be no greater than 10 percent opacity. [Origin: DAQE-AN103460061-22]. [R307-
401-8]

II.B.29.b.1 Monitoring:

In lieu of monitoring via visible emissions observations, the permittee shall inspect the baghouse
during typical operating conditions to verify proper operation and maintenance according to the
manufacturer's recommendations. The permittee shall perform at least one inspection each month
for each baghouse that has operated during the month. At a minimum, the inspection shall include
the following.
a) Verify exhaust is properly ducted to the baghouse
b) Monitor cleaning cycle
c) Monitor discharge system to ensure dust is removed as needed
d) Check baghouse for normal or abnormal visual and audible conditions
e) Check drive components on fan
f) Spot check bag-seating condition
g) Check all hoses and clamps
h) Spot check for bag leaks and holes
i) Check duct for dust buildup

II.B.29.b.2 Recordkeeping:

In addition to recording the results of the monthly inspections, the permittee shall document all
maintenance performed on the baghouse, including bag replacement. Records shall be maintained in
accordance with Provision I.S.1 of this permit.

II.B.29.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.
86

Status: None of the three systems are currently operating. In the event of operation, DAQ will be notified,
stack testing will be performed, and baghouse checks will be initiated.

II.B.30 Conditions on #SME SA-1: Smelter Unleaded Gasoline Storage Tank.

II.B.30.a Condition:

The permittee shall maintain records of the average monthly storage temperature, the type of liquid,
throughput quantities, and the maximum true vapor pressure. [Origin: R307-327-4(2)]. [R307-327-4(2)]

II.B.30.a.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.30.a.2 Recordkeeping:

The parameters listed above shall be recorded on a monthly basis and maintained as specified in
Provision I.S.1 of this permit. The permittee shall maintain fuel specification records from the fuel
supplier to demonstrate the maximum true vapor pressure.

II.B.30.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Records of temperature, type of fuel, throughput, and vapor pressure are maintained. Fuel use is
determined by employee card readers which allow gas to be dispensed. Ambient low temperature is
used for storage temperature. The type of fuel stored is recorded. All tanks and averages are kept in
single file. Tank fuel usage is based on the card readers which also track which tank is used. In
compliance.

II.B.30.b Condition:

The permittee shall not allow gasoline to be handled in a manner that would result in vapor releases to the
atmosphere for extended periods of time. Measures to be taken include, but are not limited to, the following:
(1) Minimize gasoline spills;
(2) Clean up spills as expeditiously as practicable;
(3) Cover all open gasoline containers and all gasoline storage tank fill-pipes with a gasketed seal when not
in use;
(4) Minimize gasoline sent to open waste collection systems that collect and transport gasoline to
reclamation and recycling devices, such as oil/water separators.
(5) Portable gasoline containers that meet the requirements of 40 CFR part 59, subpart F, are considered
acceptable for compliance with paragraph (3) of this section.

At all times, the permittee shall operate and maintain any affected emission unit, including associated air
pollution control equipment and monitoring equipment, in a manner consistent with safety and good air
pollution control practices for minimizing emissions. Determination of whether such operation and
maintenance procedures are being used will be based on information available which may include, but is not
limited to, monitoring results, review of operation and maintenance procedures, review of operation and
maintenance records, and inspection of the source.
87

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as identified in Table
3 of 40 CFR 63 Subpart CCCCCC.

[Origin: 40 CFR 63 Subpart CCCCCC]. [40 CFR 63.11111(b), 40 CFR 63.11115, 40 CFR 63.11116, 40
CFR 63.11130]

II.B.30.b.1 Monitoring:

Records required for this permit condition will serve as monitoring. Additionally, the permittee shall
comply with the applicable general provisions in 40 CFR 63.1-15 as identified in Table 3 of 40 CFR
63 Subpart CCCCCC. [40 CFR 63.11130]

II.B.30.b.2 Recordkeeping:

The permittee shall keep records demonstrating monthly throughput is less than the 10,000-gallon
threshold level. Records shall be available within 24 hours of a request by the Director to document
gasoline throughput in the affected emission unit. [40 CFR 63.11111(e), 40 CFR 63.11116(b)]

The permittee shall keep records of the occurrence and duration of each malfunction of operation
(i.e., process equipment) or the air pollution control and monitoring equipment. Records shall be
kept of actions taken during periods of malfunction to minimize emissions, including corrective
actions to restore malfunctioning process and air pollution control and monitoring equipment to its
normal or usual manner of operation. [40 CFR 63.11115(b), 40 CFR 63.11125(d)]

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as identified
in Table 3 of 40 CFR 63 Subpart CCCCCC. [40 CFR 63.11130]

Documentation shall be kept that demonstrates compliance with this provision. Records shall be
maintained in accordance with Provision I.S.1. of this permit.

II.B.30.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Kennecott keeps a spill kit on site and has procedures in place to minimize gasoline spills.
Preventative maintenance is followed and recorded through their electronic ‘SAP’ database. Records
are kept to demonstrate that throughput is less than 10,000 gallons each month. The throughput for
12 months ending February 29, 2024 was 20,281 gallons; with no monthly total exceeding 10,100
gallons. In compliance.

II.B.31 Conditions on #SMEi210: Smelter Cold Solvent Degreasers.

II.B.31.a Condition:

The permittee shall ensure that the following conditions are met:
(1) Each solvent degreaser is equipped with a cover which shall remain closed except during actual
loading, unloading or handling of parts in cleaner. The cover shall be designed so that it can be easily
operated with one hand if
88
(a) the volatility of the solvent is greater than 2 kPa (15 mm Hg or 0.3 psi) measured at 38 degrees C
(100 degrees F),
(b) the solvent is agitated, or
(c) the solvent is heated.
(2) An internal draining rack for cleaned parts shall be installed on which parts shall be drained until all
dripping ceases. If the volatility of the solvent is greater than 4.3 kPa (32 mm Hg at 38 degrees C (100
degrees F)), the drainage facility must be internal, so that parts are enclosed under the cover while
draining. The drainage facility may be external for applications where an internal type cannot fit into
the cleaning system.
(3) Waste or used solvent shall be stored in covered containers.
(4) Tanks, containers and all associated equipment shall be maintained in good operating condition and
leaks shall be repaired immediately or the degreaser shall be shutdown.
(5) Written procedures for the operation and maintenance of the degreasing or solvent cleaning equipment
shall be permanently posted in an accessible and conspicuous location near the equipment.
(6) If the solvent volatility is greater than 4.3 kPa (33 mm Hg or 0.6 psi) measured at 38 degrees C (100
degrees F), or if solvent is heated above 50 degrees C (120 degrees F), then one of the following control
devices shall be used:
(a) freeboard that gives a freeboard ratio greater than 0.7;
(b) water cover if the solvent is insoluble in and heavier than water;
(c) other systems of equivalent control, such as a refrigerated chiller or carbon adsorption.
(7) If used, the solvent spray shall be a solid fluid stream at a pressure which does not cause excessive
splashing and may not be a fine, atomized or shower type spray.
[Origin: R307-335-4]. [R307-335-4]

II.B.31.a.1 Monitoring:

Visual inspections shall be made monthly to demonstrate compliance with this condition.

II.B.31.a.2 Recordkeeping:

Results of monthly inspections, the solvent VOC content applied, and the physical characteristics
that demonstrate compliance with R307-335 shall be recorded and maintained as described in
Provision I.S.1 of this permit.

II.B.31.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: All Smelter degreasers have been converted to Safety Kleen green non-solvent cleaner.

II.B.32 Conditions on #SME gen: Smelter Powerhouse Emergency Generators.

II.B.32.a Condition:

Visible emissions shall be no greater than 20 percent opacity. [Origin: R307-305-3(3)]. [R307-305-3(3)]

II.B.32.a.1 Monitoring:

During any period that an emergency generator is operated for longer than 12 hours consecutively, a
visual observation of that generator's exhaust shall be made by an individual trained on the
89
observation procedures of 40 CFR 60, Appendix A, Method 9. The individual is not required to be a
certified visual emissions observer. If any visible emissions other than steam are observed, then an
opacity determination shall be performed in accordance with 40 CFR 60, Appendix A, Method 9, or
other EPA-approved testing method, as acceptable to the Director, by a certified visible emissions
observer. If a generator continues to operate on consecutive days following the initial observation,
an opacity determination shall be performed on a daily basis.

II.B.32.a.2 Recordkeeping:

Records of visual observations performed and data required by 40 CFR 60, Appendix A, Method 9,
or other EPA-approved testing method, as acceptable to the Director, for each determination shall be
maintained in accordance with Provision I.S.1 of this permit.

II.B.32.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: The Smelter powerhouse emergency generators were not operating at the time of this inspection.
Records indicated the emergency generators had not operated consecutively for over 12 hours in the
previous 12-month period. They have only been operated for maintenance purposes and for weekly
operational checks. In compliance.

II.B.32.b Condition:

The permittee shall comply with the following at all times for each emergency affected emission unit:
1. The permittee shall operate the emergency stationary RICE according to the requirements in paragraphs
a. through c. In order for the engine to be considered an emergency stationary RICE, any operation other
than emergency operation, maintenance and testing, and operation in non-emergency situations for 50
hours per year, as described in paragraphs a. through c., is prohibited. If the engine is not operated
according to the requirements in paragraphs a. through c., the engine will not be considered an
emergency engine under this subpart and shall meet all requirements for non-emergency engines.
a. There is no time limit on the use of emergency stationary RICE in emergency situations.
b. The permittee may operate the emergency stationary RICE for the purpose specified in paragraph
(b)(i) for a maximum of 100 hours per calendar year. Any operation for non-emergency situations as
allowed by paragraph c. counts as part of the 100 hours per calendar year allowed by this paragraph.
(i) Emergency stationary RICE may be operated for maintenance checks and readiness testing,
provided that the tests are recommended by federal, state or local government, the manufacturer,
the vendor, the regional transmission organization or equivalent balancing authority and
transmission operator, or the insurance company associated with the engine. The permittee may
petition for approval of additional hours to be used for maintenance checks and readiness testing,
but a petition is not required if the permittee maintains records indicating that federal, state, or
local standards require maintenance and testing of emergency RICE beyond 100 hours per
calendar year.
c. Emergency stationary RICE located at area sources of HAP may be operated for up to 50 hours per
calendar year in non-emergency situations, as specified in 40 CFR 63.6640(f)(4).
(i) If the affected emission unit operates for the purpose specified in 40 CFR 63.6640(f)(4)(ii), the
permittee shall use diesel fuel that meets the requirements in 40 CFR 1090.305 for nonroad
diesel fuel.
2. The permittee shall meet the following requirements at all times, except during periods of startup:
a. Change oil and filter every 500 hours of operation or annually, whichever comes first;
90
b. Inspect air cleaner every 1,000 hours of operation or annually, whichever comes first, and replace as
necessary;
c. Inspect all hoses and belts every 500 hours of operation or annually, whichever comes first, and
replace as necessary.
During periods of startup the permittee shall minimize the engine's time spent at idle and minimize the
engine's startup time to a period needed for appropriate and safe loading of the engine, not to exceed 30
minutes, after which time the non-startup emission limitations apply.
3. The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as identified in
Table 8 of 40 CFR 63 Subpart ZZZZ.
[Origin: 40 CFR 63 Subpart ZZZZ]. [40 CFR 63.6595(a)(1), 40 CFR 63.6603(a), 40 CFR 63.6604(b), 40
CFR 63.6605(a), 40 CFR 63.6625(h), 40 CFR 63.6640(f), 40 CFR 63.6665, 40 CFR 63 Subpart ZZZZ Table
2d, 40 CFR 63 Subpart ZZZZ Table 8]

II.B.32.b.1 Monitoring:

The permittee shall install a non-resettable hour meter if one is not already installed. [40 CFR
63.6625(f)]

If an emergency engine is operating during an emergency and it is not possible to shut down the
engine in order to perform the management practice requirements on the required schedule or if
performing the management practice on the required schedule would otherwise pose an
unacceptable risk under federal, state, or local law, the management practice can be delayed until the
emergency is over or the unacceptable risk under federal, state, or local law has abated. The
management practice shall be performed as soon as practicable after the emergency has ended or the
unacceptable risk under federal, state, or local law has abated. [40 CFR 63 Subpart ZZZZ Table 2d
Footnote 2]

The permittee shall demonstrate continuous compliance by operating and maintaining the stationary
RICE and after-treatment control device (if any) according to the manufacturer's emission-related
written operation and maintenance instructions or develop and follow their own maintenance plan
which must provide to the extent practicable for the maintenance and operation of the engine in a
manner consistent with good air pollution control practice for minimizing emissions. [40 CFR
63.6625(e), 40 CFR 63.6640(a), 40 CFR 63 Subpart ZZZZ Table 6]

The permittee has the option of utilizing an oil analysis program in order to extend the specified oil
change requirement in accordance with 40 CFR 63.6625(i).

If the affected emission unit operates for the purpose specified in 40 CFR 63.6640(f)(4)(ii), fuel
records shall be kept to demonstrate compliance with the requirements in 40 CFR 1090.305 for
nonroad diesel fuel.

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as identified
in Table 8 of 40 CFR 63 Subpart ZZZZ. [40 CFR 63.6665].

II.B.32.b.2 Recordkeeping:

The permittee shall keep the records described in 40 CFR 63.6655(a)(1)-(5) as applicable. [40 CFR
63.6655(a)]

For each affected emission unit that does not meet the standards applicable to non-emergency
engines, the permittee shall keep records of the hours of operation of the engine that are recorded
91
through the non-resettable hour meter. The permittee shall document how many hours are spent for
emergency operation, including what classified the operation as emergency and how many hours are
spent for non-emergency operation. If the engine is used for the purpose specified in 40 CFR
63.6640(f)(4)(ii), the permittee shall keep records of the notification of the emergency situation, and
the date, start time, and end time of engine operation for these purposes. [40 CFR 63.6655(f)]

If additional hours are to be used for maintenance checks and readiness testing, the permittee shall
maintain records indicating that federal, state, or local standards require maintenance and testing of
emergency RICE beyond 100 hours per calendar year. [40 CFR 63.6640(f)]

The permittee shall keep records that demonstrate continuous compliance with each applicable
operating limitation including, but not limited to, the manufacturer's emission-related operation and
maintenance instructions or the permittee-developed maintenance plan. [40 CFR 63.6655(d), 40
CFR 63 Subpart ZZZZ Table 6]

Records of the maintenance conducted shall be kept in order to demonstrate that the permittee
operated and maintained the affected emission unit and after-treatment control device (if any)
according to their own maintenance plan. [40 CFR 63.6655(e)]

If the affected emission unit operates for the purpose specified in 40 CFR 63.6640(f)(4)(ii), the
permittee shall maintain records of diesel fuel purchase invoices or obtain certification from the
diesel fuel supplier that indicate the diesel fuel meets the requirements in 40 CFR 1090.305.

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as identified
in Table 8 of 40 CFR 63 Subpart ZZZZ. [40 CFR 63.6665]

Records shall be maintained in accordance with 40 CFR 63.6660 and Provision I.S.1 of this permit.

II.B.32.b.3 Reporting:

The permittee shall report any failure to perform the management practice on the schedule required
and the federal, state or local law under which the risk was deemed unacceptable. [40 CFR 63
Subpart ZZZZ Table 2d Footnote 2]

The permittee shall submit an annual report in accordance with 40 CFR 63.6650(h), as applicable.

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as identified
in Table 8 of 40 CFR 63 Subpart ZZZZ. [40 CFR 63.6665] The permittee shall also report each
instance in which it did not meet the applicable requirements in Table 8. [40 CFR 63.6640(e)]

There are no additional reporting requirements for this provision except those specified in Section I
of this permit.

Status: Non-resettable hour meters have been installed. The SAP preventative maintenance program has
been updated to include these new maintenance requirements. Use logs are kept for each generator.
Both generators are diesel and annual maintenance tune-ups include all required items. In
compliance.

II.B.32.c Condition:

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At all times the permittee shall operate and maintain any affected source, including associated air pollution
control equipment and monitoring equipment, in a manner consistent with safety and good air pollution
control practices for minimizing emissions. The general duty to minimize emissions does not require the
permittee to make any further efforts to reduce emissions if levels required by this standard have been
achieved. Determination of whether such operation and maintenance procedures are being used will be
based on information available to the Director which may include, but is not limited to, monitoring results,
review of operation and maintenance procedures, review of operation and maintenance records, and
inspection of the source. [Origin: 40 CFR 63 Subpart ZZZZ]. [40 CFR 63.6595(a)(1), 40 CFR 63.6605(b)]

II.B.32.c.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.32.c.2 Recordkeeping:

The permittee shall keep the records described in 40 CFR 63.6655(a)(1)-(5) as applicable. [40 CFR
63.6655(a)] The permittee shall document activities performed to assure proper operation and
maintenance. Records shall be maintained in accordance with 40 CFR 63.6660 and Provision I.S.1
of this permit.

II.B.32.c.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: The SAP preventative maintenance program has been updated to include these new maintenance
requirements. Use logs are kept for each generator. Both generators are diesel and annual
maintenance tune-ups include all required items. In compliance.

II.B.33 Conditions on #Refinery: Refinery Operations.

II.B.33.a Condition:

Unless otherwise specified in this permit, at all times, including periods of startup, shutdown, and
malfunction, the permittee shall, to the extent practicable, maintain and operate any permitted plant
equipment, including associated air pollution control equipment, in a manner consistent with good air
pollution control practices 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. [Origin: DAQE-AN103460058-20]. [R307-401-8]

II.B.33.a.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.33.a.2 Recordkeeping:

Permittee shall document activities performed to assure proper operation and maintenance. Records
shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.33.a.3 Reporting:
93

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: The facility appeared to be well maintained. Records are being kept showing operating and
maintenance procedures and logs. A preventative maintenance plan is in place and is tracked along
with as needed maintenance through work orders entered in an electronic “SAP” system. In
compliance.

II.B.33.b Condition:

The permittee shall comply with the applicable requirements for recycling and emission reduction for class I
and class II refrigerants pursuant to 40 CFR 82, Subpart F - Recycling and Emissions Reduction. [Origin: 40
CFR 82]. [40 CFR 82.150(b)]

II.B.33.b.1 Monitoring:

The permittee shall certify, in the annual compliance statement required in Section I of this permit,
its compliance status with the requirements of 40 CFR 82, Subpart F.

II.B.33.b.2 Recordkeeping:

All records required in 40 CFR 82, Subpart F shall be maintained consistent with the requirements
of Provision S.1 in Section I of this permit.

II.B.33.b.3 Reporting:

All reports required in 40 CFR 82, Subpart F shall be submitted as required. There are no additional
reporting requirements except as outlined in Section I of this permit.

Status: KUC certified compliance with this condition in the most recent annual compliance certification. This
is not a delegated subpart. In compliance.

II.B.33.c Condition:

Visible emissions shall be no greater than 10 percent opacity unless otherwise specified in this permit.
[Origin: R307-305-3, DAQE-AN103460058-20]. [R307-305-3, R307-401-8]

II.B.33.c.1 Monitoring:

A visual opacity survey of each affected emission unit shall be performed on a weekly basis by an
individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. The
individual is not required to be a certified visible emissions observer. If any visible emissions other
than steam are observed, an opacity determination of that emission unit shall be performed by a
certified visible emissions observer in accordance with 40 CFR 60, Appendix A, Method 9, or other
EPA-approved testing method, as acceptable to the Director, within 24 hours of the initial
observation. For each affected emission unit, if no visible emissions are observed for eight
consecutive weeks the observation frequency shall be reduced to a monthly basis. If visible
emissions are observed during any monthly observation the frequency shall revert to a weekly basis.

Minor natural gas combustion sources (<5 MMBtu/hr), cold solvent degreasers, organic liquid
94
storage tanks (<19,812 gallons), cooling towers, and units equipped with a continuous opacity
monitor are not affected emission units subject to this condition.

II.B.33.c.2 Recordkeeping:

A log of the visual opacity survey(s) shall be maintained in accordance with Provision I.S.1 of this
permit. If an opacity determination is indicated, a notation of the determination shall be made in the
log. All data required by 40 CFR 60, Appendix A, Method 9, or other EPA-approved testing
method, as acceptable to the Director, shall also be maintained in accordance with Provision I.S.1 of
this permit.

II.B.33.c.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: KUC maintains a logbook with all visible emission units and weekly surveys. This logbook was
reviewed during the inspection and appeared to be complete. KUC uses the weekly-to-monthly skip
monitoring provision and enters all data into a spreadsheet to track whether a point source is on the
weekly or monthly schedule. The site has two forms each for Smelter and Refinery: 1 for specific
listed sources and one for other sources such as storage piles. No excess visible emissions were noted at
any point during either inspection or any stack tests. The initial readings are done by contractor and
then submitted to be included on the compliance section spreadsheets. The contractor is Method 9
certified and review of VEO sheets show proper method and annotation of readings. Review of the
tracking spreadsheet shows all points are included. In Compliance.

II.B.33.d Condition:

The permittee shall only combust diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) that meets the
definition of ultra-low sulfur diesel (ULSD), which has a sulfur content of 15 ppm or less. [Origin: DAQE-
AN103460058-20]. [R307-203-1, R307-401-8]

II.B.33.d.1 Monitoring:

Compliance with this limitation shall be demonstrated either by testing each fuel delivery for the
sulfur content or by inspection of the fuel sulfur-content certifications provided by the diesel fuel
supplier in purchase records. Sulfur content in either instance shall be determined in accordance
with ASTM-4294, or equivalent. Records required for this permit condition will also serve as
monitoring.

II.B.33.d.2 Recordkeeping:

The permittee shall maintain records that demonstrate compliance with the limitation. Records of
diesel fuel purchase invoices that indicate the diesel fuel meets the ULSD requirements, fuel
supplier certifications of sulfur content, or records of sulfur content testing shall be maintained in
accordance with Provision I.S.1. of this permit.

II.B.33.d.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.
95

Status: KUC receives ultralow sulfur diesel from Sinclair. All fuel deliveries come out of the Pioneer Pipeline
and delivery tickets show ULS fuel delivered. This type of fuel meets the listed requirement. In
compliance.

II.B.33.e Condition:

All roads, permanent parking lots, and service yards directly servicing the permittee's approved constructed
installations listed as emission units II.A.53 through II.A.73 shall be paved. The permittee shall comply with
the fugitive dust requirements and work practices contained in R307-309-7 and R307-309-9, as applicable.
[Origin: DAQE-AN103460058-20, R307-309]. [R307-309-7, R307-309-9, R307-401-8]

II.B.33.e.1 Monitoring:

Adherence to the most recently approved fugitive dust control plan shall be monitored to
demonstrate that appropriate measures are being implemented to control fugitive dust.

II.B.33.e.2 Recordkeeping:

Records that demonstrate compliance with this condition and records required by the most recently
approved fugitive dust control plan shall be maintained in accordance with the plan and section I.S.1
of this permit.

II.B.33.e.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: All areas listed above are paved. Visual opacity surveys are conducted weekly. Records were reviewed
with no violations noted. No fugitive dust was noted during the inspection. Material hauling areas are
all paved. Water trucks are active daily, and sweeping is performed on an as needed basis. Fugitive
dust was not observed during the inspection. Daily monitoring of the storage piles is conducted by the
operations group. A fugitive dust control plan was submitted, through the web-based system, on May
8, 2018, for the smelter. The refinery FDCP was submitted on the web-based system December 19,
2013. The web-based system includes all required items from state and federal rules. The current plan
is in effect. In compliance.

II.B.33.f Condition:

The permittee shall comply with the applicable requirements for servicing of motor vehicle air conditioners
pursuant to 40 CFR 82, Subpart B - Servicing of Motor Vehicle Air Conditioners. [Origin: 40 CFR 82]. [40
CFR 82.30(b)]

II.B.33.f.1 Monitoring:

The permittee shall certify, in the annual compliance statement required in Section I of this permit,
its compliance status with the requirements of 40 CFR 82, Subpart B.

II.B.33.f.2 Recordkeeping:

96
All records required in 40 CFR 82, Subpart B shall be maintained consistent with the requirements
of Provision S.1 in Section I of this permit.

II.B.33.f.3 Reporting:

All reports required in 40 CFR 82, Subpart B shall be submitted as required. There are no additional
reporting requirements except as outlined in Section I of this permit.

Status: KUC certified compliance with this condition in the most recent annual compliance certification. This
is not a delegated subpart. In compliance.

II.B.33.g Condition:
Pressure drops and liquid flow rates for each scrubber listed below shall be maintained within the given
ranges. (All pressure drop readings in inches Water Gauge)
REF 006 - Hydrometallurgical Precious Metals Recovery Scrubber:
Pressure Drop = 5 - 15 Liquid Flow Rate = greater than 100 gpm
REF 007 - Hydrometallurgical Silver Production Scrubber:
Pressure Drop = 0.75 - 4 Liquid Flow Rate = greater than 60 gpm.
[Origin: DAQE-AN103460058-20]. [R307-401-8]

II.B.33.g.1 Monitoring:

The permittee shall install, calibrate, maintain, and operate monitoring devices for the continuous
measurement of the pressure drop of the gas stream and the scrubbing liquid flow rate through each
scrubber. The instruments that measure scrubbing liquid flow rate and gas stream pressure drop
shall be installed such that an inspector/operator can safely read the output at any time.

The permittee shall make at least one pressure drop and one liquid flow observation per calendar
day for each scrubber listed above that operated during that day. If the pressure drop or liquid flow
rate deviates from the listed ranges the permittee shall immediately investigate the cause and initiate
corrective action to return the scrubber to proper operating parameters. If the pressure drop or the
liquid flow rate remains out of range for greater than 48 operating hours from the initial out of range
reading it shall be considered a deviation from this permit term.

The gas stream pressure drop reading shall be accurate to one inch W.G. and the scrubbing liquid
flow rate shall be accurate to five (5) gallons per minute. The observation shall be made during
typical operating conditions. The instrument(s) shall be calibrated according to the manufacturer's
instruction at least semi-annually (every six months), except for those instruments that are sealed by
the manufacturer and cannot be calibrated. Additionally, the pressure drop and liquid flow rate for
each scrubber shall be observed and recorded at the time of any compliance stack testing.

For each affected emission unit, if pressure drop and liquid flow rate observations are within range
for eight consecutive weeks, the observation frequency shall be reduced to a weekly basis. If
pressure drop or liquid flow rate observations are not within range during any weekly observation,
the frequency shall revert to once per calendar day for the emission unit that was out of range.

II.B.33.g.2 Recordkeeping:

Results of monitoring shall be maintained in an operator's log or by computer recording. Continuous
recording for the monitoring device is not required. Records shall be maintained in accordance with
Provision I.S.1 of this permit.
97

II.B.33.g.3 Reporting:

Deviations from this condition shall be considered to be promptly reported if reported on a calendar
quarter basis and in accordance with Provision I.S.2 of this permit. There are no additional reporting
requirements for this provision except those specified in Section I of this permit.

Status: Pressure drops and liquid flow rate are observed and recorded at least once daily. Periods of pressure
drop or liquid flow rate excursions lasting 48 hours or longer have been reported accordingly. Gas
stream pressure drop gauges have been calibrated semi-annually. The REF 007 is not included on the
pie tracking systems and readings are done by operations per shift and supplied to environmental to
include on the tracking spreadsheet. Calibrations are done through the maintenance control system
and are scheduled no more than 180 days post most recent calibration. The system does show if
calibrations are not completed 15 days prior to stop date.
REF 006 - Hydrometallurgical Precious Metals Recovery Scrubber:
Pressure Drop = 7.9 Liquid Flow Rate = 275 gpm Last calibration 4/24/2024
REF 007 - Hydrometallurgical Silver Production Scrubber:
Pressure Drop = 0.89 Liquid Flow Rate = 76 gpm Last calibration 2/18/2024
In Compliance.

II.B.33.h Condition:

The permittee shall maintain an Emergency Episode Plan outlining the procedures that will be taken in the
event of an emergency episode as outlined in R307-105-2. The plan shall identify what control/production
measures shall be implemented when an emergency episode is declared. Specific control/production
measures shall be outlined for all three levels (Alert, Warning, Emergency). The plan shall be submitted and
approved by the Director within 60 days of the issue date of this permit, unless a previously submitted and
approved plan is available. [Origin: SIP Section VII.F]. [R307-105-2, R307-110-8]

II.B.33.h.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.33.h.2 Recordkeeping:

A copy of the approved Emergency Episode Plan shall be made available to the Director upon
request.

II.B.33.h.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: The original emergency episode plan was submitted along with the original Title V application. A
copy of the plan is on site. No updates have been necessary to reflect changes at the facility as of the
date of the inspection. In compliance.

98
II.B.33.i Condition:

Fugitive emissions shall be no greater than 15 percent opacity unless otherwise specified in this permit.
[Origin: DAQE-AN103460058-20]. [R307-309-4, R307-401-8]

II.B.33.i.1 Monitoring:

A visual opacity survey of each affected emission unit shall be performed on a weekly basis by an
individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. If visible
emissions other than steam are observed from an emission unit, an opacity determination of that
emission unit shall be performed by a certified observer within 24 hours of the initial survey. The
opacity determination shall be performed in accordance with 40 CFR 60, Appendix A, Method 9, or
other EPA-approved testing method, as acceptable to the Director, for point sources, and in
accordance with 58 FR 61640 Method 203C, or other EPA-approved testing method, as acceptable
to the Director, for intermittent sources. Fugitive dust is not a fugitive emission within the meaning
of this condition.

For each affected emission unit, if no visible emissions are observed for eight consecutive weeks the
observation frequency shall be reduced to a monthly basis. If visible emissions are observed during
any monthly observation the frequency shall revert to a weekly basis.

II.B.33.i.2 Recordkeeping:

A log of the visual opacity survey(s) shall be maintained in accordance with Provision I.S.1 of this
permit. If an opacity determination is indicated, a notation of the determination will be made in the
log. All data required by 40 CFR 60, Appendix A, Method 9, 58 FR 61640, Method 203C, or other
EPA-approved testing method, as acceptable to the Director, shall also be maintained in accordance
with Provision I.S.1 of this permit.

II.B.33.i.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: KUC maintains a logbook with all visible emission units and weekly surveys. This logbook was
reviewed during the inspection and appeared to be complete. KUC uses the weekly-to-monthly skip
monitoring provision and enters all data into a spreadsheet to track whether a point source is on the
weekly or monthly schedule. The site has two forms each for Smelter and Refinery: 1 for specific
listed sources and one for other sources such as storage piles. No excess visible emissions were noted at
any point during either inspection or any stack tests. The initial readings are done by contractor and
then submitted to be included on the compliance section spreadsheets. The contractor is Method 9
certified and review of VEO sheets show proper method and annotation of readings. Review of the
tracking spreadsheet shows all points are included. In Compliance.

II.B.33.j Condition:

The permittee shall implement a fugitive dust control plan that has been approved by the Director. Activities
regulated by R307-309 shall not commence before the fugitive dust control plan is approved by the director.
The plan shall include the minimum fugitive dust control plan requirements in R307-309-6(4), as applicable,
and the information required in R307-309-6(5). Natural sources of dust and fugitive emissions are not
fugitive dust within the meaning of this condition. [Origin: R307-309-6]. [R307-309-6]
99

II.B.33.j.1 Monitoring:

Adherence to the most recently approved fugitive dust control plan shall be monitored to
demonstrate that appropriate measures are being implemented to control fugitive dust.

II.B.33.j.2 Recordkeeping:

Records that demonstrate compliance with this condition and records required by the most recently
approved fugitive dust control plan shall be maintained in accordance with the plan and section I.S.1
of this permit.

II.B.33.j.3 Reporting:

If site modifications that result in changes to fugitive dust emissions are made, an updated fugitive
dust control plan shall be submitted as required by R307-309-6(3). There are no additional reporting
requirements for this provision except those specified in Section I of this permit.

Status: Material hauling areas are all paved. Water trucks are active daily, and sweeping is performed on an
as needed basis. Fugitive dust was not observed during the inspection. Daily monitoring of the storage
piles is conducted by the operations group. A fugitive dust control plan was submitted, through the
web-based system, on May 8, 2018, for the smelter. The refinery FDCP was submitted on the web-
based system December 19, 2013. The web-based system includes all required items from state and
federal rules. The current plan is in effect. In compliance.

II.B.33.k Condition:

Unless otherwise specified in this permit, visible emissions caused by fugitive dust shall not exceed 10
percent opacity at the property boundary and 20 percent on site. [Origin: DAQE-AN103460058-20, R307-
309]. [R307-309-5, R307-401-8]

II.B.33.k.1 Monitoring:

In lieu of monitoring via visible emissions observations, adherence to the most recently approved
fugitive dust control plan shall be monitored to demonstrate that appropriate measures are being
implemented to control fugitive dust.

Control of fugitive dust from disturbed or stripped areas is required at all times (24 hours per day
every day) for the duration of the operation. Methods of control of fugitive emissions from these
areas shall include, but not be limited to, water treatments or chemical treatments.

II.B.33.k.2 Recordkeeping:

Records of measures taken to control fugitive dust shall be maintained to demonstrate adherence to
the most recently approved fugitive dust control plan. Records shall be maintained as described in
Provision I.S.1 of this permit.

II.B.33.k.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.
100

Status: Kennecott implements a fugitive dust control plant as described above. No fugitive dust was observed
at the refinery facilities during this inspection. All areas around the refinery are paved and
periodically swept, and speed limit signs are posted. In compliance.

II.B.33.l Condition:

Natural gas consumption shall not exceed 966,228 MMBtu per rolling 12-month period for the CHP unit
and south tankhouse boiler combined. [Origin: DAQE-AN103460058-20]. [R307-401-8]

II.B.33.l.1 Monitoring:

Consumption shall be determined using natural gas fuel purchasing records or flow meter. To
demonstrate compliance, the permittee shall calculate a new 12-month total by the 20th day of each
month using data from the previous 12 months.

II.B.33.l.2 Recordkeeping:

Records of consumption shall be kept on a monthly basis for all periods the plant is in operation.
Records used to demonstrate compliance with this condition shall be maintained as described in
Provision I.S.1 of this permit.

II.B.33.l.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: For the rolling 12-month period ending on April 1, 2024, gaseous fuel consumption totaled 633,384
dekatherms (633,574.1 MMBTU). Company records are in DTH with 0.9997 DTH to 1 MMBTU
conversion. In compliance.

II.B.33.m Condition:

(1) For all solvent cleaning operations, the permittee shall not use solvent products with a VOC content
greater than the amounts specified in Table 1 of R307-304-5.
(2) As an alternative to the limits in Table 1 and for all general miscellaneous cleaning operations, the
permittee may use a cleaning material with a VOC composite vapor pressure no greater than 8 mm Hg
at 20 degrees Celsius.
(3) The permittee shall store used applicators and shop towels in closed fireproof containers.

These requirements do not apply to the exemptions listed in R307-304-3.
[Origin: R307-304]. [R307-304]

II.B.33.m.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.33.m.2 Recordkeeping:

The permittee shall maintain records demonstrating compliance with this condition. Records shall
include the VOC content or composite vapor pressure of the solvent product applied. Records shall
101
be maintained in accordance with Provision I.S.1 of this permit and shall be available to the director
upon request.

II.B.33.m.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: All material is purchased and used as purchased from third party vendor. MSD sheets are available
for review. Shop areas have containers, and all containers were closed. In compliance.

II.B.33.n Condition:

Except as provided in R307-361-4, the permittee shall not supply, solicit for application, or apply within the
counties in R307-361-2 any architectural coating with a VOC content in excess of the corresponding limit
specified in Table 1 of R307-361-5. The permittee shall comply with the additional standards and work
practices contained in R307-361-5, as applicable. [Origin: R307-361]. [R307-361]

II.B.33.n.1 Monitoring:

Compliance shall be demonstrated as specified in R307-361-8.

II.B.33.n.2 Recordkeeping:

Records demonstrating compliance with this condition shall be maintained in accordance with
Provision I.S.1 of this permit.

II.B.33.n.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: All material is purchased and used as purchased from third party vendor. MSD sheets are available
for review. In compliance.

II.B.33.o Condition:

1. The permittee shall not sell supply or offer for sale any adhesive, sealant, adhesive primer or sealant
primer with a VOC content in excess of the limits in Table 1 of R307-342-5 and that was manufactured
on or after September 1, 2014.
2. The permittee shall not apply any adhesive, sealant, adhesive primer or sealant primer with a VOC
content in excess of the limits specified in Table 1 of R307-342-5 unless an add-on control device as
specified in R307-342-8 is used or unless the adhesive, sealant, adhesive primer or sealant primer was
manufactured before September 1, 2014.
3. The VOC content limits in Table 1 of R307-342-5 for adhesives applied to particular substrates shall
apply as specified in R307-342-5(4).
4. The permittee shall comply with the additional standards and work practices contained in R307-342-6
and R307-342-7, as applicable.
5. These requirements do not apply if exempted in accordance with R307-342-3.
[Origin: R307-342]. [R307-342]

102
II.B.33.o.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.33.o.2 Recordkeeping:

(a) For operations that are not exempt under R307-342-3, the permittee shall maintain records
demonstrating compliance as specified in R307-342-7(2).
(b) If an exemption is claimed pursuant to R307-342-3 the permittee shall record and maintain
operational records sufficient to demonstrate compliance. (R307-342-3(7))
Records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.33.o.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: All material is purchased and used as purchased from third party vendor. MSD sheets are available
for review. The company does no sales or products. In compliance.

II.B.34 Conditions on #REF 001: Electrolyte Purification Liberator.

II.B.34.a Condition:

Emissions of Sulfuric Acid (H2SO4) shall be no greater than 0.004 grains/dscf and 0.46 lbs/hour. [Origin:
DAQE-AN103460058-20]. [R307-401-8]

II.B.34.a.1 Monitoring:

Stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested every three years. Every three years means the test shall
be performed every third year and in the same calendar quarter in which the most recent test
was performed. The source may also be tested at any time if directed by the Director.
(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source test protocol shall
outline the proposed test methodologies, stack to be tested, procedures to be used, and shall be
approved by the Director prior to performing the test(s). The source shall attend a pretest
conference if determined necessary by the Director.
(c) Methods.
(1) Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other EPA-approved testing method, as acceptable to the
Director, and Occupational Safety and Health Administration (OSHA)-approved and/or
Mine Safety and Health Administration (MSHA)-approved access shall be provided to the
test location.
(2) 40 CFR 60, Appendix A, Method 8, or other EPA-approved testing method, as acceptable
to the Director, shall be used to determine the pollutant emission rate.
(3) 40 CFR 60, Appendix A, Method 2, or other EPA-approved testing method, as acceptable
to the Director, shall be used to determine the volumetric flow rate.
(d) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate
103
and any necessary conversion factors determined by the Director to give the results in the
specified units of the emission limitation.
(e) Production Rate During Testing. The production rate during all compliance testing shall be no
less than 90 percent of the maximum production achieved in the previous three (3) years.

II.B.34.a.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated test
method and Provision S.1 in Section I of this permit.

II.B.34.a.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of the
testing. Reports shall clearly identify results as compared to permit limits and indicate compliance
status. There are no additional reporting requirements for this provision except those specified in
Section I of this permit.

Status: The most recent testing was conducted on August 25, 2022. Test results were submitted to DAQ and
reviewed. DAQ-calculated test results for H2SO4 were 1.4E-04 grains/dscf and 3.1E-03 lbs/hr. Next
test is due in 2025. In compliance.

II.B.34.b Condition:

Visible emissions shall be no greater than 15 percent opacity from the demisters. [Origin: DAQE-
AN103460058-20]. [R307-401-8]

II.B.34.b.1 Monitoring:

A visual observation of each affected emission unit shall be performed on a weekly basis by an
individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. The
individual is not required to be a certified visible emissions observer. If any visible emissions other
than steam are observed, an opacity determination of that emission unit shall be performed by a
certified visible emissions observer in accordance with 40 CFR 60, Appendix A, Method 9, or other
EPA-approved testing method, as acceptable to the Director, within 24 hours of the initial
observation. For each affected emission unit, if no visible emissions are observed for eight
consecutive weeks the observation frequency shall be reduced to a monthly basis. If visible
emissions are observed during any monthly observation the frequency shall revert to a weekly basis.

II.B.34.b.2 Recordkeeping:

Records of visual observations performed and data required by 40 CFR 60, Appendix A, Method 9,
or other EPA-approved testing method, as acceptable to the Director, for each determination shall be
maintained in accordance with Provision I.S.1 of this permit.

II.B.34.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

104
Status: No visible emissions were observed during this inspection. Visual opacity surveys have been conducted
and recorded weekly. Records were reviewed onsite during inspection with no deviations noted. In
compliance.

II.B.35 Conditions on #REF 002/003: Refinery Boilers (Tankhouse)

II.B.35.a Condition:

The permittee shall maintain records of the amount of each fuel combusted during each calendar month for
each affected emission unit. [Origin: 40 CFR 60 Subpart Dc]. [40 CFR 60.48c(g)]

II.B.35.a.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.35.a.2 Recordkeeping:

Records of gas meter readings and, on days when oil is burned, the oil tank sensor levels shall be
kept on a monthly basis and shall be maintained as described in Provision I.S.1 of this permit.

II.B.35.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Natural gas was the only fuel used in the 12-month period prior to this inspection. Fuel meter readings
are maintained and available upon request. Fuel consumption is tracked and recorded. In compliance.

II.B.35.b Condition:

The permittee shall use natural gas as the primary fuel and #2 fuel oil, or better, as a backup fuel. Usage of
fuel oil for periodic testing, maintenance, or operator training shall not exceed 48 hours per calendar year.
There is no time limit on the use of fuel oil in the boiler during periods of natural gas curtailment, natural
gas supply interruption, or startups. [Origin: DAQE-AN103460058-20]. [R307-401-8]

II.B.35.b.1 Monitoring:

The backup fuel shall be monitored by use of level sensors in the tanks, which shall be observed
following each use of backup fuel.

II.B.35.b.2 Recordkeeping:

Records documenting fuel oil usage shall be kept in a log. Additionally, the permittee shall maintain
records that document the reason for backup fuel usage (i.e. natural gas curtailment, testing,
maintenance), date, and duration. Records shall be maintained in accordance with Provision I.S.1 of
this permit.

II.B.35.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.
105

Status: Natural gas is the primary fuel used. Landfill gas has never been used. Level sensors are used to
monitor the backup fuel. The level sensors electronically report fuel levels to a computer. Number 2
fuel oil can be used in the event of natural gas curtailment. No curtailments have occurred at the
refinery in the past 12-month period. In compliance.

II.B.35.c Condition:

Visible emissions shall be no greater than 10 percent opacity. [Origin: DAQE-AN103460058-20, 40 CFR 60
Subpart Dc]. [40 CFR 60.43c(c), R307-401-8]

II.B.35.c.1 Monitoring:

A visual observation of each affected emission unit shall be performed on a weekly basis by an
individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. The
individual is not required to be a certified visible emissions observer. If any visible emissions other
than steam are observed, an opacity determination of that emission unit shall be performed by a
certified visible emissions observer in accordance with 40 CFR 60, Appendix A, Method 9, or other
EPA-approved testing method, as acceptable to the Director, within 24 hours of the initial
observation.

The permittee shall operate the affected emission unit in accordance with the most recently
approved written site-specific monitoring plan. The monitoring plan shall include procedures and
criteria for establishing and monitoring specific parameters for the affected emission unit indicative
of compliance with the opacity standard. (40 CFR 60.47c(f)(3)).

II.B.35.c.2 Recordkeeping:

Records of visual observations performed and data required by 40 CFR 60, Appendix A, Method 9,
or other EPA-approved testing method, as acceptable to the Director, for each determination shall be
maintained.

A copy of the most recently approved written site-specific monitoring plan shall be maintained.

Records shall be maintained in accordance with 40 CFR 60.48c(c) and Provision I.S.1 of this
permit.

II.B.35.c.3 Reporting:

The permittee shall submit a written site-specific monitoring plan for approval. There are no
additional reporting requirements for this provision except those specified in Section I of this
permit.

Status: No visible emissions were observed during this inspection. Visual opacity surveys have been conducted
and recorded weekly. Records were reviewed onsite during inspection with no deviations noted. In
compliance.

II.B.35.d Condition: State-only Requirement

Emissions of NOx from the south tankhouse boiler shall not exceed 1.5 lbs/hour and 9 ppmvd at 3% O2.
[Origin: DAQE-AN103460058-20, SIP Section IX.H.12.j]. [R307-401-8, SIP Section IX.H.12.j]
106

II.B.35.d.1 Monitoring:

Stack testing shall be performed as specified below:
(a) Frequency.
Emissions shall be tested at least once every three years from the most recent stack test. Every
three years means the test shall be performed every third year and in the same calendar quarter
in which the most recent stack test was performed. The source may also be tested at any time if
directed by the Director.
(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source test protocol shall
outline the proposed test methodologies, stack to be tested, procedures to be used, and shall be
approved by the Director prior to performing the test(s). The source shall attend a pretest
conference if determined necessary by the Director.
(c) Methods.
(1) Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other EPA-approved testing method, as acceptable to the
Director, and Occupational Safety and Health Administration (OSHA)-approved and/or
Mine Safety and Health Administration (MSHA)-approved access shall be provided to the
test location.
(2) 40 CFR 60, Appendix A, Method 7, 7A, 7B, 7C, 7D, or 7E, or other EPA-approved testing
method, as acceptable to the Director, shall be used to determine the pollutant emission
rate.
(3) 40 CFR 60, Appendix A, Method 2, Method 19, or other EPA-approved testing method, as
acceptable to the Director, shall be used to determine the volumetric flow rate.
(d) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate
and any necessary conversion factors determined by the Director to give the results in the
specified units of the emission limitation.
(e) Conditions During Testing. Stack testing shall be performed during representative operations,
defined as 90 percent of the maximum firing rate for the burners. Boiler tests shall be
conducted using the fuel(s) or fuel mixture representative of normal operations. The permittee
shall submit for approval in the pretest protocol the fuel(s) to be used during the test.

II.B.35.d.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated test
method and Provision S.1 in Section I of this permit.

II.B.35.d.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of the
testing. Reports shall clearly identify results as compared to permit limits and indicate compliance
status. There are no additional reporting requirements for this provision except those specified in
Section I of this permit.

Status: The North boiler has been decommissioned. South Boiler stack testing was conducted on REF 003 on
12/15/2023. Test results were submitted to DAQ and reviewed in DAQC-206-24. DAQ- calculated
results were CO- 0.02 lbs/hr, NOx- 0.7 lbs.hr and 8.0 ppmdv @3% O2. Next test is due in 2026. In
compliance.

107
II.B.35.e Condition:

Emissions of CO shall be no greater than 3.00 lbs/hour from the south tankhouse boiler. [Origin: DAQE-
AN103460058-20]. [R307-401-8]

II.B.35.e.1 Monitoring:

Stack testing shall be performed as specified below:
(a) Frequency.
Emissions shall be tested at least once every three years from the most recent stack test. Every
three years means the test shall be performed every third year and in the same calendar quarter
in which the most recent stack test was performed.
(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source test protocol shall
outline the proposed test methodologies, stack to be tested, procedures to be used, and shall be
approved by the Director prior to performing the test(s). The source shall attend a pretest
conference if determined necessary by the Director.
(c) Sample Point. The emission sample point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other EPA-approved testing method, as acceptable to the Director.
In addition, Occupational Safety and Health Administration (OSHA) approved access shall be
provided to the test location.
(d) Methods.
(1) 40 CFR 60, Appendix A, Method 10, or other EPA-approved testing method, as
acceptable to the Director, shall be used to determine CO emissions;
(2) 40 CFR 60, Appendix A, Method 2, Method 19, or other EPA-approved testing method, as
acceptable to the Director, shall be used to determine stack gas velocity and volumetric
flow rate.
(e) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate
and any necessary conversion factors determined by the Director to give the results in the
specified units of the emission limitation.
(f) Conditions During Testing. Stack testing shall be performed during representative operations,
defined as 90 percent of the maximum firing rate for the burner(s). Boiler tests shall be
conducted using the fuel(s) or fuel mixture representative of normal operations. The permittee
shall submit for approval in the pretest protocol the fuel(s) to be used during the test.

II.B.35.e.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated test
method and Provision S.1 in Section I of this permit.

II.B.35.e.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of the
testing. Reports shall clearly identify results as compared to permit limits and indicate compliance
status. There are no additional reporting requirements for this provision except those specified in
Section I of this permit.

Status: The North boiler has been decommissioned. South Boiler stack testing was conducted on REF 003 on
12/15/2023. Test results were submitted to DAQ and reviewed in DAQC-206-24. DAQ- calculated
108
results were CO- 0.02 lbs/hr, NOx 0.7 lbs.hr and 8.0 ppmdv @3% O2. Next test is due in 2026. In
compliance.

II.B.35.f Condition:

At all times, including periods of startup, shutdown, and malfunction, sulfur content of fuel oil burned shall
be no greater than 0.0015 percent by weight. [Origin: DAQE-AN103460058-20]. [40 CFR 60.42c(d), 40
CFR 60.42c(i), R307-401-8]

II.B.35.f.1 Monitoring:

Compliance with this limitation shall be demonstrated using certifications from the fuel supplier, as
described under 40 CFR 60.48c(f). (40 CFR 60.42c(h)).

II.B.35.f.2 Recordkeeping:

Fuel supplier certifications shall be maintained that show the sulfur content of the delivered fuel.
Certification shall include the following information for distillate oil:
(a) The name of the oil supplier;
(b) A statement from the oil supplier that the oil complies with the specifications under the
definition of distillate oil in 40 CFR 60.41c; and
(c) The sulfur content or maximum sulfur content of the oil.
(40 CFR 60.48c(f)(1))
Records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.35.f.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Kennecott burns ultra-low sulfur diesel out of the Pioneer Pipeline. Ultra-low sulfur is required by
contract. Fuel delivery tickets are kept on file. In compliance.

II.B.35.g Condition:

The permittee shall operate and maintain the permitted plant equipment, air pollution control equipment, and
monitoring equipment in a manner consistent with good air pollution control practices for minimizing
emissions at all times including during startup, shutdown, and malfunction. [Origin: DAQE-AN103460058-
20, SIP Section IX.H.2.i, SIP Section IX.H.12.j]. [R307-401-8, SIP Section IX.H.12.j, SIP Section IX.H.2.i]

II.B.35.g.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.35.g.2 Recordkeeping:

Permittee shall document activities performed to assure proper operation and maintenance. Records
shall be kept on site which indicate the date and time of startups and shutdowns. (SIP Section
IX.H.12.j) Records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.35.g.3 Reporting:
109

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: The South tankhouse was operating normally. The last stack test with installed burners was under the
listed limit. This unit is in the maintenance system and has both preventive and as needed
maintenance services. In compliance.

II.B.36 Conditions on #REF 004: Cathode Wash.

II.B.36.a Condition:

Emissions of Sulfuric Acid (H2SO4) shall be no greater than 0.0008 grains/dscf and 0.12 lbs/hour. [Origin:
DAQE-AN103460058-20]. [R307-401-8]

II.B.36.a.1 Monitoring:

Stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested every three years. Every three years means the test shall
be performed every third year and in the same calendar quarter in which the most recent test
was performed. The source may also be tested at any time if directed by the Director.
(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source test protocol shall
outline the proposed test methodologies, stack to be tested, procedures to be used, and shall be
approved by the Director prior to performing the test(s). The source shall attend a pretest
conference if determined necessary by the Director.
(c) Methods.
(1) Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other EPA-approved testing method, as acceptable to the
Director, and Occupational Safety and Health Administration (OSHA)-approved and/or
Mine Safety and Health Administration (MSHA)-approved access shall be provided to the
test location.
(2) 40 CFR 60, Appendix A, Method 8, or other EPA-approved testing method, as acceptable
to the Director, shall be used to determine the pollutant emission rate.
(3) 40 CFR 60, Appendix A, Method 2, Method 19, or other EPA-approved testing method, as
acceptable to the Director, shall be used to determine the volumetric flow rate.
(d) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate
and any necessary conversion factors determined by the Director to give the results in the
specified units of the emission limitation.
(e) Production Rate During Testing. The production rate during all compliance testing shall be no
less than 90 percent of the maximum production achieved in the previous three (3) years.

II.B.36.a.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated test
method and Provision S.1 in Section I of this permit.

II.B.36.a.3 Reporting:

110
The results of stack testing shall be submitted to the Director within 60 days of completion of the
testing. Reports shall clearly identify results as compared to permit limits and indicate compliance
status. There are no additional reporting requirements for this provision except those specified in
Section I of this permit.

Status: The most recent testing was conducted on August 23, 2022. Test results were submitted to DAQ and
reviewed. DAQ-calculated test results for H2SO4 were 1.2E-04 grains/dscf and 2.6E-03 lbs/hr. Next
test is due in 2025. In compliance.

II.B.36.b Condition:

Visible emissions shall be no greater than 15 percent opacity. [Origin: DAQE-AN103460058-20]. [R307-
401-8]

II.B.36.b.1 Monitoring:

A visual observation of each affected emission unit shall be performed on a weekly basis by an
individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. The
individual is not required to be a certified visible emissions observer. If any visible emissions other
than steam are observed, an opacity determination of that emission unit shall be performed by a
certified visible emissions observer in accordance with 40 CFR 60, Appendix A, Method 9, or other
EPA-approved testing method, as acceptable to the Director, within 24 hours of the initial
observation. For each affected emission unit, if no visible emissions are observed for eight
consecutive weeks the observation frequency shall be reduced to a monthly basis. If visible
emissions are observed during any monthly observation the frequency shall revert to a weekly basis.

II.B.36.b.2 Recordkeeping:

Records of visual observations performed and data required by 40 CFR 60, Appendix A, Method 9,
or other EPA-approved testing method, as acceptable to the Director, for each determination shall be
maintained in accordance with Provision I.S.1 of this permit.

II.B.36.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: No visible emissions were observed during this inspection. Visual opacity surveys have been conducted
and recorded weekly. Records were reviewed onsite during inspection with no deviations noted. In
compliance.

II.B.37 Conditions on #REF 005: Anode Scrap Wash.

II.B.37.a Condition:

Emissions of Sulfuric Acid (H2SO4) shall be no greater than 0.0008 grains/dscf and 0.02 lbs/hour. [Origin:
DAQE-AN103460058-20]. [R307-401-8]

II.B.37.a.1 Monitoring:

Stack testing shall be performed as specified below:
111
(a) Frequency. Emissions shall be tested every three years. Every three years means the test shall
be performed every third year and in the same calendar quarter in which the most recent test
was performed. The source may also be tested at any time if directed by the Director.
(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source test protocol shall
outline the proposed test methodologies, stack to be tested, procedures to be used, and shall be
approved by the Director prior to performing the test(s). The source shall attend a pretest
conference if determined necessary by the Director.
(c) Methods.
(1) Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other EPA-approved testing method, as acceptable to the
Director, and Occupational Safety and Health Administration (OSHA)-approved and/or
Mine Safety and Health Administration (MSHA)-approved access shall be provided to the
test location.
(2) 40 CFR 60, Appendix A, Method 8, or other EPA-approved testing method, as acceptable
to the Director, shall be used to determine the pollutant emission rate.
(3) 40 CFR 60, Appendix A, Method 2, or other EPA-approved testing method, as acceptable
to the Director, shall be used to determine the volumetric flow rate.
(d) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate
and any necessary conversion factors determined by the Director to give the results in the
specified units of the emission limitation.
(e) Production Rate During Testing. The production rate during all compliance testing shall be no
less than 90 percent of the maximum production achieved in the previous three (3) years.

II.B.37.a.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated test
method and Provision S.1 in Section I of this permit.

II.B.37.a.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of the
testing. Reports shall clearly identify results as compared to permit limits and indicate compliance
status. There are no additional reporting requirements for this provision except those specified in
Section I of this permit.

Status: The most recent testing was conducted on August 24, 2022. Test results were submitted to DAQ and
reviewed. DAQ-calculated test results for H2SO4 were 1.5E-04 grains/dscf and 1.0E-03 lbs/hr. Next
test is due in 2025. In compliance.

II.B.37.b Condition:

Visible emissions shall be no greater than 15 percent opacity. [Origin: DAQE-AN103460058-20]. [R307-
401-8]

112
II.B.37.b.1 Monitoring:

A visual observation of each affected emission unit shall be performed on a weekly basis by an
individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. The
individual is not required to be a certified visible emissions observer. If any visible emissions other
than steam are observed, an opacity determination of that emission unit shall be performed by a
certified visible emissions observer in accordance with 40 CFR 60, Appendix A, Method 9, or other
EPA-approved testing method, as acceptable to the Director, within 24 hours of the initial
observation. For each affected emission unit, if no visible emissions are observed for eight
consecutive weeks the observation frequency shall be reduced to a monthly basis. If visible
emissions are observed during any monthly observation the frequency shall revert to a weekly basis.

II.B.37.b.2 Recordkeeping:

Records of visual observations performed and data required by 40 CFR 60, Appendix A, Method 9,
or other EPA-approved testing method, as acceptable to the Director, for each determination shall be
maintained in accordance with Provision I.S.1 of this permit.

II.B.37.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: No visible emissions were observed during this inspection. Visual opacity surveys have been conducted
and recorded weekly. Records were reviewed onsite during inspection with no deviations noted. In
compliance.

II.B.38 Conditions on #REF 006: Hydrometallurgical Precious Metals Recovery.

II.B.38.a Condition:

Emissions of SO2 shall be no greater than 1.7 lbs/hour. [Origin: DAQE-AN103460058-20]. [R307-401-8]

II.B.38.a.1 Monitoring:

Stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested every three years. Every three years means the test shall
be performed every third year and in the same calendar quarter in which the most recent test
was performed. The source may also be tested at any time if directed by the Director.
(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source test protocol shall
outline the proposed test methodologies, stack to be tested, procedures to be used, and shall be
approved by the Director prior to performing the test(s). The source shall attend a pretest
conference if determined necessary by the Director.
(c) Methods.
(1) Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other EPA-approved testing method, as acceptable to the
Director, and Occupational Safety and Health Administration (OSHA)-approved and/or
Mine Safety and Health Administration (MSHA)-approved access shall be provided to the
test location.
113
(2) 40 CFR 60, Appendix A, Method 6, 6A, 6B, or 6C, or other EPA-approved testing
method, as acceptable to the Director, shall be used to determine the pollutant emission
rate.
(3) 40 CFR 60, Appendix A, Method 2, Method 19, or other EPA-approved testing method, as
acceptable to the Director, shall be used to determine the volumetric flow rate.
(d) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate
and any necessary conversion factors determined by the Director to give the results in the
specified units of the emission limitation.
(e) Production Rate During Testing. The production rate during all compliance testing shall be no
less than 90 percent of the maximum production achieved in the previous three (3) years.

II.B.38.a.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated test
method and Provision S.1 in Section I of this permit.

II.B.38.a.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of the
testing. Reports shall clearly identify results as compared to permit limits and indicate compliance
status. There are no additional reporting requirements for this provision except those specified in
Section I of this permit.

Status: The most recent testing was conducted February 25, 2021. Test results were submitted to DAQ and
reviewed. DAQ-calculated test results for SO2 were 0.47 lbs/hr. Testing was done March 13, 2024;
with results pending. In compliance.

II.B.38.b Condition:

Emissions of Lead shall be no greater than 0.02 lbs/hour. [Origin: DAQE-AN103460058-20]. [R307-401-8]

II.B.38.b.1 Monitoring:

Stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested every three years. Every three years means the test shall
be performed every third year and in the same calendar quarter in which the most recent test
was performed. The source may also be tested at any time if directed by the Director.
(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source test protocol shall
outline the proposed test methodologies, stack to be tested, procedures to be used, and shall be
approved by the Director prior to performing the test(s). The source shall attend a pretest
conference if determined necessary by the Director.
(c) Methods.
(1) Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other EPA-approved testing method, as acceptable to the
Director, and Occupational Safety and Health Administration (OSHA)-approved and/or
Mine Safety and Health Administration (MSHA)-approved access shall be provided to the
test location.
(2) 40 CFR 60, Appendix A, Method 12, or other EPA-approved testing method, as
acceptable to the Director, shall be used to determine the pollutant emission rate.
114
(3) 40 CFR 60, Appendix A, Method 2, or other EPA-approved testing method, as acceptable
to the Director, shall be used to determine the volumetric flow rate.
(d) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate
and any necessary conversion factors determined by the Director to give the results in the
specified units of the emission limitation.
(e) Production Rate During Testing. The production rate during all compliance testing shall be no
less than 90 percent of the maximum production achieved in the previous three (3) years.

II.B.38.b.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated test
method and Provision S.1 in Section I of this permit.

II.B.38.b.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of the
testing. Reports shall clearly identify results as compared to permit limits and indicate compliance
status. There are no additional reporting requirements for this provision except those specified in
Section I of this permit.

Status: The most recent testing was conducted February 25, 2021. Test results were submitted to DAQ and
reviewed. DAQ-calculated test results for Pb were 0.00012 lbs/hr. Testing was done March 13, 2024;
with results pending. In compliance.

II.B.38.c Condition:

Emissions of Sulfuric Acid (H2SO4) shall be no greater than 0.005 grains/dscf and 0.36 lbs/hour. [Origin:
DAQE-AN103460058-20]. [R307-401-8]

II.B.38.c.1 Monitoring:

Stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested every three years. Every three years means the test shall
be performed every third year and in the same calendar quarter in which the most recent test
was performed. The source may also be tested at any time if directed by the Director.
(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source test protocol shall
outline the proposed test methodologies, stack to be tested, procedures to be used, and shall be
approved by the Director prior to performing the test(s). The source shall attend a pretest
conference if determined necessary by the Director.
(c) Methods.
(1) Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other EPA-approved testing method, as acceptable to the
Director, and Occupational Safety and Health Administration (OSHA)-approved and/or
Mine Safety and Health Administration (MSHA)-approved access shall be provided to the
test location.
(2) 40 CFR 60, Appendix A, Method 8, or other EPA-approved testing method, as acceptable
to the Director, shall be used to determine the pollutant emission rate.
(3) 40 CFR 60, Appendix A, Method 2, or other EPA-approved testing method, as acceptable
to the Director, shall be used to determine the volumetric flow rate.
115
(d) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate
and any necessary conversion factors determined by the Director to give the results in the
specified units of the emission limitation.
(e) Production Rate During Testing. The production rate during all compliance testing shall be no
less than 90 percent of the maximum production achieved in the previous three (3) years.

II.B.38.c.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated test
method and Provision S.1 in Section I of this permit.

II.B.38.c.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of the
testing. Reports shall clearly identify results as compared to permit limits and indicate compliance
status. There are no additional reporting requirements for this provision except those specified in
Section I of this permit.

Status: The most recent testing was conducted February 25, 2021. Test results were submitted to DAQ and
reviewed. DAQ-calculated test results for H2SO4 were 0.027 lbs/hr and 0.00039 gr/dscf. Testing was
done March 13, 2024; with results pending. In compliance.

II.B.38.d Condition:

Visible emissions shall be no greater than 15 percent opacity. [Origin: DAQE-AN103460058-20]. [R307-
401-8]

II.B.38.d.1 Monitoring:

A visual observation of each affected emission unit shall be performed on a weekly basis by an
individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. The
individual is not required to be a certified visible emissions observer. If any visible emissions other
than steam are observed, an opacity determination of that emission unit shall be performed by a
certified visible emissions observer in accordance with 40 CFR 60, Appendix A, Method 9, or other
EPA-approved testing method, as acceptable to the Director, within 24 hours of the initial
observation. For each affected emission unit, if no visible emissions are observed for eight
consecutive weeks the observation frequency shall be reduced to a monthly basis. If visible
emissions are observed during any monthly observation the frequency shall revert to a weekly basis.

II.B.38.d.2 Recordkeeping:

Records of visual observations performed and data required by 40 CFR 60, Appendix A, Method 9,
or other EPA-approved testing method, as acceptable to the Director, for each determination shall be
maintained in accordance with Provision I.S.1 of this permit.

II.B.38.d.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

116
Status: No visible emissions were observed during this inspection. Visual opacity surveys have been conducted
and recorded weekly. Records were reviewed onsite during inspection with no deviations noted. In
compliance.

II.B.38.e Condition:

Emissions of Hydrogen chloride (HCl) shall be no greater than 0.003 grains/dscf and 0.22 lbs/hour. [Origin:
DAQE-AN103460058-20]. [R307-401-8]

II.B.38.e.1 Monitoring:

a) Stack testing shall be performed as specified below:
(1) Frequency. Emissions shall be tested every three years. Every three years means the test
shall be performed every third year and in the same calendar quarter in which the most
recent test was performed. The source may also be tested at any time if directed by the
Director.
(2) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source test protocol
shall outline the proposed test methodologies, stack to be tested, procedures to be used, and
shall be approved by the Director prior to performing the test(s). The source shall attend a
pretest conference if determined necessary by the Director.
(3) Methods.
(i) Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other EPA-approved testing method, as acceptable to the
Director, and Occupational Safety and Health Administration (OSHA)-approved
and/or Mine Safety and Health Administration (MSHA)-approved access shall be
provided to the test location.
(ii) 40 CFR 60, Appendix A, Method 26 or 26A, or other EPA-approved testing method,
as acceptable to the Director, shall be used to determine the pollutant emission rate.
(iii) 40 CFR 60, Appendix A, Method 2, or other EPA-approved testing method, as
acceptable to the Director, shall be used to determine the volumetric flow rate.
(4) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow
rate and any necessary conversion factors determined by the Director to give the results in
the specified units of the emission limitation.
(5) Production Rate During Testing. The production rate during all compliance testing shall be
no less than 90 percent of the maximum production achieved in the previous three (3)
years.
b) Scrubber liquid pH shall be used as a primary indicator and scrubber liquid flow rate shall be
used as a secondary indicator to provide reasonable assurance of compliance with the HCL
emission limitation as specified below.
1) Primary Indicator - Scrubber Liquid pH
(I) Measurement Approach: The permittee shall continuously measure the scrubber liquid
pH using a pH probe.
(II) Indicator Range: An excursion is defined as scrubber liquid pH below 6.0 for a 24-hour
block average under typical operating conditions. Excursions trigger an inspection,
corrective action, and a reporting requirement.
(III) Performance Criteria:
a. Data Representativeness: The scrubber liquid pH shall be measured using a pH
probe located in the scrubber liquid.
117
b. QA/QC Practices and Criteria: The pH sensor shall be calibrated by comparison to
laboratory buffer solutions. The pH meter shall be checked for accuracy and
calibrated according to the manufacturer's recommendations at least every three
months. All operating equipment and process downtime shall be monitored.
c. Monitoring Frequency: Scrubber liquid pH shall be measured continuously.
d. Data Collection Procedure: Scrubber liquid pH readings shall be recorded
electronically. During periods when electronic readings are not available or
functional, manual readings shall be used until electronic readings are restored. If
manual readings are used, the permittee shall collect and record at least four or more
scrubber liquid pH values equally spaced over each hour. Hourly average pH values
shall be used to compute the 24-hour block average for comparison to the indicator
range.
e. Averaging Period: 24-hour block.
2) Secondary Indicator - Scrubber Liquid Flow Rate
(I) Measurement Approach: The permittee shall continuously measure the scrubber liquid
flow rate using a flow meter.
(II) Indicator Range: An excursion is defined as a scrubber liquid flow rate below 135
gallons per minute (gpm) for a 24-hour block average under typical operating
conditions. Excursions trigger an inspection, corrective action, and a reporting
requirement.
(III) Performance Criteria:
a. Data Representativeness: The scrubber liquid flow rate shall be measured using a
flow meter located on the scrubber liquid recirculation line. The scrubber liquid
flow rate shall be accurate to five (5) gpm.
b. QA/QC Practices and Criteria: The flow meter shall be calibrated according to the
manufacturer's recommendations at least every six months. All operating equipment
and process downtime shall be monitored.
c. Monitoring Frequency: Scrubber liquid flow rate shall be measured continuously.
d. Data Collection Procedure: Scrubber liquid flow rates shall be recorded
electronically. During periods when electronic readings are not available or
functional, manual readings shall be used until electronic readings are restored. If
manual readings are used, the permittee shall collect and record at least four or more
scrubber liquid flow values equally spaced over each hour. Hourly average flow
rates shall be used to compute the 24-hour block average for comparison to the
indicator range.
e. Averaging Period: 24-hour block.

II.B.38.e.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated test
method and Provision I.S.1 of this permit.

In addition to the recordkeeping requirement described in Provision I.S.1 of this permit, the
permittee shall maintain a file of the occurrence and duration of any excursion, corrective actions
taken, and any other supporting information required to be maintained under 40 CFR 64 (such as
data used to document the adequacy of monitoring, or records of monitoring maintenance or
corrective actions). Instead of paper records, the permittee may maintain records on alternative
media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use
of such alternative media allows for expeditious inspection and review, and does not conflict with
other applicable recordkeeping requirements. (40 CFR 64.9(b))

118
II.B.38.e.3 Reporting:

In addition to the reporting requirements in Provision I.S.2 of this permit,
(a) Monitoring reports shall include, at a minimum, the following information, as applicable:
(i) Summary information on the number, duration and cause (including unknown cause, if
applicable) of excursions or exceedances, as applicable, and the corrective actions taken;
(40 CFR 64.9(a)(2)(i))
(ii) Summary information on the number, duration and cause (including unknown cause, if
applicable) for monitor downtime incidents (other than downtime associated with zero and
span or other daily calibration checks, if applicable). (40 CFR 64.9(a)(2)(ii))
(b) The results of stack testing shall be submitted to the Director within 60 days of completion of
the testing. Reports shall clearly identify results as compared to permit limits and indicate
compliance status.

Status: The most recent testing was conducted February 25, 2021. Test results were submitted to DAQ and
reviewed. DAQ-calculated test results for HCl were 0.0052 lbs/hr and 0.000075 gr/dscf. Testing was
done March 13, 2024; with results pending. Flow rate and pH readings are logged continuously and
averaged hourly. No excursions or exceedances were noted during inspection. Instruments are
calibrated semi-annually. Reports have been submitted as required. The readings during inspection
were pH 10.5 and flow 274 gpm. Last Calibration 10/22/2023. In Compliance.

II.B.39 Conditions on #REF 011: Soda Ash Silo.

II.B.39.a Condition:

Visible emissions shall be no greater than 10 percent opacity during silo loading operations. [Origin: DAQE-
AN103460058-20]. [R307-401-8]

II.B.39.a.1 Monitoring:

A visual observation of each affected emission unit shall be performed on a monthly basis by an
individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. The
individual is not required to be a certified visible emissions observer. If any visible emissions other
than steam are observed, an opacity determination of that emission unit shall be performed by a
certified visible emissions observer in accordance with 40 CFR 60, Appendix A, Method 9, or other
EPA-approved testing method, as acceptable to the Director, within 24 hours of the initial
observation.

II.B.39.a.2 Recordkeeping:

Records of visual observations performed and data required by 40 CFR 60, Appendix A, Method 9,
or other EPA-approved testing method, as acceptable to the Director, for each determination shall be
maintained in accordance with Provision I.S.1 of this permit.

II.B.39.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

119
Status: The silo was not being loaded during this inspection. Visual opacity surveys have been conducted and
recorded monthly. Records were reviewed onsite during inspection with no deviations noted. In
compliance.

II.B.40 Conditions on #REF 007: Hydrometallurgical Silver Production.

II.B.40.a Condition:

Visible emissions shall be no greater than 15 percent opacity. [Origin: DAQE-AN103460058-20]. [R307-
401-8]

II.B.40.a.1 Monitoring:

A visual observation of each affected emission unit shall be performed on a weekly basis by an
individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. The
individual is not required to be a certified visible emissions observer. If any visible emissions other
than steam are observed, an opacity determination of that emission unit shall be performed by a
certified visible emissions observer in accordance with 40 CFR 60, Appendix A, Method 9, or other
EPA-approved testing method, as acceptable to the Director, within 24 hours of the initial
observation. For each affected emission unit, if no visible emissions are observed for eight
consecutive weeks the observation frequency shall be reduced to a monthly basis. If visible
emissions are observed during any monthly observation the frequency shall revert to a weekly basis.

II.B.40.a.2 Recordkeeping:

Records of visual observations performed and data required by 40 CFR 60, Appendix A, Method 9,
or other EPA-approved testing method, as acceptable to the Director, for each determination shall be
maintained in accordance with Provision I.S.1 of this permit.

II.B.40.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: No visible emissions were observed during this inspection. Visual opacity surveys have been conducted
and recorded weekly. Records were reviewed onsite during inspection with no deviations noted. Listed
as Ammonia Scrubber on VEO form. In compliance.

II.B.40.b Condition:

Emissions of Sulfuric Acid (H2SO4) shall be no greater than 0.009 grains/dscf and 0.22 lbs/hour. [Origin:
DAQE-AN103460058-20]. [R307-401-8]

120
II.B.40.b.1 Monitoring:

Stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested every three years. Every three years means the test shall
be performed every third year and in the same calendar quarter in which the most recent test
was performed. The source may also be tested at any time if directed by the Director.
(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source test protocol shall
outline the proposed test methodologies, stack to be tested, procedures to be used, and shall be
approved by the Director prior to performing the test(s). The source shall attend a pretest
conference if determined necessary by the Director.
(c) Methods.
(1) Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other EPA-approved testing method, as acceptable to the
Director, and Occupational Safety and Health Administration (OSHA)-approved and/or
Mine Safety and Health Administration (MSHA)-approved access shall be provided to the
test location.
(2) 40 CFR 60, Appendix A, Method 8, or other EPA-approved testing method, as acceptable
to the Director, shall be used to determine the pollutant emission rate.
(3) 40 CFR 60, Appendix A, Method 2, or other EPA-approved testing method, as acceptable
to the Director, shall be used to determine the volumetric flow rate.
(d) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate
and any necessary conversion factors determined by the Director to give the results in the
specified units of the emission limitation.
(e) Production Rate During Testing. The production rate during all compliance testing shall be no
less than 90 percent of the maximum production achieved in the previous three (3) years.

II.B.40.b.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated test
method and Provision S.1 in Section I of this permit.

II.B.40.b.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of the
testing. Reports shall clearly identify results as compared to permit limits and indicate compliance
status. There are no additional reporting requirements for this provision except those specified in
Section I of this permit.

Status: The most recent testing was conducted February 24, 2021. Test results were submitted to DAQ and
reviewed. DAQ-calculated test results for H2SO4 were 0.0052 lbs/hr and 0.00027 gr/dscf. Testing was
done March 14, 2024, with results pending. In compliance.

II.B.40.c Condition:

Emissions of Ammonia (NH3) shall be no greater than 0.14 lbs/hour. [Origin: DAQE-AN103460058-20].
[R307-401-8]

II.B.40.c.1 Monitoring:

121
Stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested every three years. Every three years means the test shall
be performed every third year and in the same calendar quarter in which the most recent test
was performed. The source may also be tested at any time if directed by the Director.
(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source test protocol shall
outline the proposed test methodologies, stack to be tested, procedures to be used, and shall be
approved by the Director prior to performing the test(s). The source shall attend a pretest
conference if determined necessary by the Director.
(c) Methods.
(1) Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other EPA-approved testing method, as acceptable to the
Director, and Occupational Safety and Health Administration (OSHA)-approved and/or
Mine Safety and Health Administration (MSHA)-approved access shall be provided to the
test location.
(2) An EPA-approved testing method, as acceptable to the Director, shall be used to determine
the pollutant emission rate. The test method shall be submitted for approval prior to testing
or may be assigned by the Director.
(3) 40 CFR 60, Appendix A, Method 2, or other EPA-approved testing method, as acceptable
to the Director, shall be used to determine the volumetric flow rate.
(d) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate
and any necessary conversion factors determined by the Director to give the results in the
specified units of the emission limitation.
(e) Production Rate During Testing. The production rate during all compliance testing shall be no
less than 90 percent of the maximum production achieved in the previous three (3) years.

II.B.40.c.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated test
method and Provision S.1 in Section I of this permit.

II.B.40.c.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of the
testing. Reports shall clearly identify results as compared to permit limits and indicate compliance
status. There are no additional reporting requirements for this provision except those specified in
Section I of this permit.

Status: The most recent testing was conducted February 24, 2021. Test results were submitted to DAQ and
reviewed. DAQ-calculated test results for NH3 were 0.010 lbs/hr. Testing was done March 14, 2024,
with results pending. In compliance.

II.B.41 Conditions on #REF 008: Precious Metals Filter Presses.

II.B.41.a Condition:

Visible emissions shall be no greater than 10 percent opacity. [Origin: DAQE-AN103460058-20]. [R307-
401-8]

II.B.41.a.1 Monitoring:
122

A visual observation of each affected emission unit shall be performed once each week that the unit
operates by an individual trained on the observation procedures of 40 CFR 60, Appendix A, Method
9. The individual is not required to be a certified visible emissions observer. If any visible emissions
other than steam are observed, an opacity determination of that emission unit shall be performed by
a certified visible emissions observer in accordance with 40 CFR 60, Appendix A, Method 9, or
other EPA-approved testing method, as acceptable to the Director, within 24 hours of the initial
observation. For each affected emission unit, if no visible emissions are observed for eight
consecutive weeks the observation frequency shall be reduced to a monthly basis. If visible
emissions are observed during any monthly observation the frequency shall revert to a weekly basis.

II.B.41.a.2 Recordkeeping:

Records of visual observations performed and data required by 40 CFR 60, Appendix A, Method 9,
or other EPA-approved testing method, as acceptable to the Director, for each determination shall be
maintained in accordance with Provision I.S.1 of this permit.

II.B.41.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: No visible emissions were observed during this inspection. Visual opacity surveys have been conducted
and recorded weekly. Readings are done by the operators and the environmental section is called if
Method 9 reading is needed. This is a non-continuous process. Records were reviewed onsite during
inspection with no deviations noted. In compliance.

II.B.42 Conditions on #REF 009: Selenium Crushing and Packaging.

II.B.42.a Condition:

Visible emissions shall be no greater than 10 percent opacity. [Origin: DAQE-AN103460058-20]. [R307-
401-8]

II.B.42.a.1 Monitoring:

A visual observation of each affected emission unit shall be performed once each week that the unit
operates by an individual trained on the observation procedures of 40 CFR 60, Appendix A, Method
9. The individual is not required to be a certified visible emissions observer. If any visible emissions
other than steam are observed, an opacity determination of that emission unit shall be performed by
a certified visible emissions observer in accordance with 40 CFR 60, Appendix A, Method 9, or
other EPA-approved testing method, as acceptable to the Director, within 24 hours of the initial
observation. For each affected emission unit, if no visible emissions are observed for eight
consecutive weeks the observation frequency shall be reduced to a monthly basis. If visible
emissions are observed during any monthly observation the frequency shall revert to a weekly basis.

II.B.42.a.2 Recordkeeping:

Records of visual observations performed and data required by 40 CFR 60, Appendix A, Method 9,
or other EPA-approved testing method, as acceptable to the Director, for each determination shall be
maintained in accordance with Provision I.S.1 of this permit.
123

II.B.42.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: No visible emissions were observed during this inspection. Visual opacity surveys have been conducted
and recorded weekly. Operators do readings and call the environmental section if Method 9 is
required. Records were reviewed onsite during inspection with no deviations noted. In compliance.

II.B.42.b Condition:

The baghouse pressure drop shall not be less than 1.0 inch of water gauge or greater than 6.0 inches of water
gauge. [Origin: DAQE-AN103460058-20]. [R307-401-8]

II.B.42.b.1 Monitoring:

The permittee shall make at least one pressure drop observation per month. The observation shall be
made during typical operating conditions. The pressure drop shall be monitored with instruments
located such that an inspector/operator can safely read the output at any time. The instrument(s)
shall be calibrated in accordance with the manufacturer's instructions at least once each year. If the
pressure drop remains out of range for greater than 48 operating hours from the initial out of range
reading, it shall be considered a deviation from this permit term.

II.B.42.b.2 Recordkeeping:

The permittee shall record the results of the pressure drop observation once each month. These
records along with the annual calibration records shall be maintained in accordance with Provision
I.S.1 of this permit.

II.B.42.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Pressure drop readings have been performed and recorded at a minimum of once per month. The
gauge is calibrated in January and July of each year. Monthly observation records were reviewed
during inspection and no deviations were noted. Readings are done by operations and reported to the
compliance section for tracking. Last reading available was 3/20/2024 -dp – 3.0 inches. The last
calibration date was 10/22/2023. In compliance.

II.B.43 Conditions on #REF 010: Gold/Silver Recovery.

II.B.43.a Condition:

Emissions of PM10 shall be no greater than 0.010 grains/dscf and 0.43 lbs/hour (filterable). [Origin: DAQE-
AN103460058-20]. [R307-401-8]

II.B.43.a.1 Monitoring:

Stack testing shall be performed as specified below:
124
(a) Frequency. Emissions shall be tested every three years. Every three years means the test shall
be performed every third year and in the same calendar quarter in which the most recent test
was performed. The source may also be tested at any time if directed by the Director.
(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source test protocol shall
outline the proposed test methodologies, stack to be tested, procedures to be used, and shall be
approved by the Director prior to performing the test(s). The source shall attend a pretest
conference if determined necessary by the Director.
(c) Methods.
(1) Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other EPA-approved testing method, as acceptable to the
Director, and Occupational Safety and Health Administration (OSHA)-approved and/or
Mine Safety and Health Administration (MSHA)-approved access shall be provided to the
test location.
(2) PM10/PM2.5 (filterable):
For stacks in which no liquid drops are present, the following methods shall be used: 40
CFR 51, Appendix M, Methods 201 or 201a or other EPA-approved testing method
acceptable to the Director.

For stacks in which liquid drops are present, methods to eliminate the liquid drops shall be
explored. If no reasonable method to eliminate the drops exists, then the following
methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d, 5i or other EPA-
approved testing method acceptable to the Director. Using Method 5, all filterable
particulate emissions shall be considered PM2.5 and/or PM10 unless otherwise approved by
the Director. The portion of the filterable particulate emissions considered PM2.5 and/or
PM10 shall be based on information in Appendix B of the fifth edition of the EPA
document, AP-42 or other data acceptable to the Director.

PM10/PM2.5 (condensable):
The back half condensable particulate emissions shall also be tested using 40 CFR 51,
Appendix M Method 202, or other EPA-approved testing method acceptable to the
Director. All particulate captured using Method 202 shall be considered PM2.5 and/or
PM10.

For filterable emission limits, condensable particulate emissions shall not be used for
compliance demonstrations. For filterable + condensable emission limits, condensable
particulate emissions shall be used for compliance demonstrations.
(3) 40 CFR 60, Appendix A, Method 2, Method 19, or other EPA-approved testing method, as
acceptable to the Director, shall be used to determine volumetric flow rate.
(d) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate
and any necessary conversion factors determined by the Director to give the results in the
specified units of the emission limitation.
(e) Production Rate During Testing. The production rate during all compliance testing shall be no
less than 90 percent of the maximum production achieved in the previous three (3) years.

II.B.43.a.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated test
method and Provision S.1 in Section I of this permit.

125
II.B.43.a.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of the
testing. Reports shall clearly identify results as compared to permit limits and indicate compliance
status. There are no additional reporting requirements for this provision except those specified in
Section I of this permit.

Status: The most recent testing was conducted February 26, 2021. Test results were submitted to DAQ and
reviewed. DAQ-calculated test results for PM10 were 0.0078 lbs/hr and 0.0005 gr/dscf. Testing was
done March 15, 2024, with results pending. In Compliance.

II.B.43.b Condition:

Visible emissions shall be no greater than 10 percent opacity. [Origin: DAQE-AN103460058-20]. [R307-
401-8]

II.B.43.b.1 Monitoring:

A visual observation of each affected emission unit shall be performed on a weekly basis by an
individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. The
individual is not required to be a certified visible emissions observer. If any visible emissions other
than steam are observed, an opacity determination of that emission unit shall be performed by a
certified visible emissions observer in accordance with 40 CFR 60, Appendix A, Method 9, or other
EPA-approved testing method, as acceptable to the Director, within 24 hours of the initial
observation. For each affected emission unit, if no visible emissions are observed for eight
consecutive weeks the observation frequency shall be reduced to a monthly basis. If visible
emissions are observed during any monthly observation the frequency shall revert to a weekly basis.

II.B.43.b.2 Recordkeeping:

Records of visual observations performed and data required by 40 CFR 60, Appendix A, Method 9,
or other EPA-approved testing method, as acceptable to the Director, for each determination shall be
maintained in accordance with Provision I.S.1 of this permit.

II.B.43.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: No visible emissions were observed during this inspection. Visual opacity surveys have been conducted
and recorded weekly. Records were reviewed onsite during inspection with no deviations noted. In
compliance.

II.B.44 Conditions on Emergency Generators - Precious Metals.

II.B.44.a Condition:

Visible emissions from diesel-fired emergency engines shall be no greater than 20 percent opacity. [Origin:
DAQE-AN103460058-20, R307-305-3(3)]. [R307-305-3(3), R307-401-8]

II.B.44.a.1 Monitoring:
126

During any period that an emergency generator is operated for longer than 12 hours consecutively, a
visual observation of that generator's exhaust shall be made by an individual trained on the
observation procedures of 40 CFR 60, Appendix A, Method 9. The individual is not required to be a
certified visual emissions observer. If any visible emissions other than steam are observed, then an
opacity determination shall be performed in accordance with 40 CFR 60, Appendix A, Method 9, or
other EPA-approved testing method, as acceptable to the Director, by a certified visible emissions
observer. If a generator continues to operate on consecutive days following the initial observation,
an opacity determination shall be performed on a daily basis.

II.B.44.a.2 Recordkeeping:

Records of visual observations performed and data required by 40 CFR 60, Appendix A, Method 9,
or other EPA-approved testing method, as acceptable to the Director, for each determination shall be
maintained in accordance with Provision I.S.1 of this permit.

II.B.44.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Records indicate that the emergency generator has not operated for longer than 12 hours
consecutively. In compliance.
127
II.B.44.b Condition:

For the diesel-fired engine (#REFi 210):

The permittee shall comply with the following at all times for each emergency affected emission unit:
1. The permittee shall operate the emergency stationary RICE according to the requirements in paragraphs
a. through c. In order for the engine to be considered an emergency stationary RICE, any operation other
than emergency operation, maintenance and testing, and operation in non-emergency situations for 50
hours per year, as described in paragraphs a. through c., is prohibited. If the engine is not operated
according to the requirements in paragraphs a. through c., the engine will not be considered an
emergency engine under this subpart and shall meet all requirements for non-emergency engines.
a. There is no time limit on the use of emergency stationary RICE in emergency situations.
b. The permittee may operate the emergency stationary RICE for the purpose specified in paragraph
(b)(i) for a maximum of 100 hours per calendar year. Any operation for non-emergency situations as
allowed by paragraph c. counts as part of the 100 hours per calendar year allowed by this paragraph.
(i) Emergency stationary RICE may be operated for maintenance checks and readiness testing,
provided that the tests are recommended by federal, state or local government, the manufacturer,
the vendor, the regional transmission organization or equivalent balancing authority and
transmission operator, or the insurance company associated with the engine. The permittee may
petition for approval of additional hours to be used for maintenance checks and readiness testing,
but a petition is not required if the permittee maintains records indicating that federal, state, or
local standards require maintenance and testing of emergency RICE beyond 100 hours per
calendar year.
c. Emergency stationary RICE located at area sources of HAP may be operated for up to 50 hours per
calendar year in non-emergency situations, as specified in 40 CFR 63.6640(f)(4).
(i) If the affected emission unit operates for the purpose specified in 40 CFR 63.6640(f)(4)(ii), the
permittee shall use diesel fuel that meets the requirements in 40 CFR 1090.305 for nonroad
diesel fuel.
2. The permittee shall meet the following requirements at all times, except during periods of startup:
a. Change oil and filter every 500 hours of operation or annually, whichever comes first;
b. Inspect air cleaner every 1,000 hours of operation or annually, whichever comes first, and replace as
necessary;
c. Inspect all hoses and belts every 500 hours of operation or annually, whichever comes first, and
replace as necessary.
During periods of startup the permittee shall minimize the engine's time spent at idle and minimize the
engine's startup time to a period needed for appropriate and safe loading of the engine, not to exceed 30
minutes, after which time the non-startup emission limitations apply.
3. The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as identified in
Table 8 of 40 CFR 63 Subpart ZZZZ.
[Origin: 40 CFR 63 Subpart ZZZZ]. [40 CFR 63.6595(a)(1), 40 CFR 63.6603(a), 40 CFR 63.6604(b), 40
CFR 63.6605(a), 40 CFR 63.6625(h), 40 CFR 63.6640(f), 40 CFR 63.6665, 40 CFR 63 Subpart ZZZZ Table
2d, 40 CFR 63 Subpart ZZZZ Table 8]

II.B.44.b.1 Monitoring:

The permittee shall install a non-resettable hour meter if one is not already installed. [40 CFR
63.6625(f)]

If an emergency engine is operating during an emergency and it is not possible to shut down the
engine in order to perform the management practice requirements on the required schedule or if
performing the management practice on the required schedule would otherwise pose an
128
unacceptable risk under federal, state, or local law, the management practice can be delayed until the
emergency is over or the unacceptable risk under federal, state, or local law has abated. The
management practice shall be performed as soon as practicable after the emergency has ended or the
unacceptable risk under federal, state, or local law has abated. [40 CFR 63 Subpart ZZZZ Table 2d
Footnote 2]

The permittee shall demonstrate continuous compliance by operating and maintaining the stationary
RICE and after-treatment control device (if any) according to the manufacturer's emission-related
written operation and maintenance instructions or develop and follow their own maintenance plan
which must provide to the extent practicable for the maintenance and operation of the engine in a
manner consistent with good air pollution control practice for minimizing emissions. [40 CFR
63.6625(e), 40 CFR 63.6640(a), 40 CFR 63 Subpart ZZZZ Table 6]

The permittee has the option of utilizing an oil analysis program in order to extend the specified oil
change requirement in accordance with 40 CFR 63.6625(i).

If the affected emission unit operates for the purpose specified in 40 CFR 63.6640(f)(4)(ii), fuel
records shall be kept to demonstrate compliance with the requirements in 40 CFR 1090.305 for
nonroad diesel fuel.

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as identified
in Table 8 of 40 CFR 63 Subpart ZZZZ. [40 CFR 63.6665].

II.B.44.b.2 Recordkeeping:

The permittee shall keep the records described in 40 CFR 63.6655(a)(1)-(5) as applicable. [40 CFR
63.6655(a)]

For each affected emission unit that does not meet the standards applicable to non-emergency
engines, the permittee shall keep records of the hours of operation of the engine that are recorded
through the non-resettable hour meter. The permittee shall document how many hours are spent for
emergency operation, including what classified the operation as emergency and how many hours are
spent for non-emergency operation. If the engine is used for the purpose specified in 40 CFR
63.6640(f)(4)(ii), the permittee shall keep records of the notification of the emergency situation, and
the date, start time, and end time of engine operation for these purposes. [40 CFR 63.6655(f)]

If additional hours are to be used for maintenance checks and readiness testing, the permittee shall
maintain records indicating that federal, state, or local standards require maintenance and testing of
emergency RICE beyond 100 hours per calendar year. [40 CFR 63.6640(f)]

The permittee shall keep records that demonstrate continuous compliance with each applicable
operating limitation including, but not limited to, the manufacturer's emission-related operation and
maintenance instructions or the permittee-developed maintenance plan. [40 CFR 63.6655(d), 40
CFR 63 Subpart ZZZZ Table 6]

Records of the maintenance conducted shall be kept in order to demonstrate that the permittee
operated and maintained the affected emission unit and after-treatment control device (if any)
according to their own maintenance plan. [40 CFR 63.6655(e)]

If the affected emission unit operates for the purpose specified in 40 CFR 63.6640(f)(4)(ii), the
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permittee shall maintain records of diesel fuel purchase invoices or obtain certification from the
diesel fuel supplier that indicate the diesel fuel meets the requirements in 40 CFR 1090.305.

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as identified
in Table 8 of 40 CFR 63 Subpart ZZZZ. [40 CFR 63.6665]

Records shall be maintained in accordance with 40 CFR 63.6660 and Provision I.S.1 of this permit.

II.B.44.b.3 Reporting:

The permittee shall report any failure to perform the management practice on the schedule required
and the federal, state or local law under which the risk was deemed unacceptable. [40 CFR 63
Subpart ZZZZ Table 2d Footnote 2]

The permittee shall submit an annual report in accordance with 40 CFR 63.6650(h), as applicable.

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as identified
in Table 8 of 40 CFR 63 Subpart ZZZZ. [40 CFR 63.6665] The permittee shall also report each
instance in which it did not meet the applicable requirements in Table 8. [40 CFR 63.6640(e)]

There are no additional reporting requirements for this provision except those specified in Section I
of this permit.

Status:

Non-resettable hour meters have been installed. Plant representatives indicated that the maintenance
requirements have been put into the refinery’s electronic preventative maintenance program. Logs
are kept for generator use date, time, and reason for each use. This generator operated has not
exceeded the hourly limitations this calendar year-to-date. The 12-month use total as of 01/01/2024
was 40 hours. In compliance.

II.B.44.c Condition:

For the diesel-fired engine (#REFi 210):

At all times the permittee shall operate and maintain any affected source, including associated air pollution
control equipment and monitoring equipment, in a manner consistent with safety and good air pollution
control practices for minimizing emissions. The general duty to minimize emissions does not require the
permittee to make any further efforts to reduce emissions if levels required by this standard have been
achieved. Determination of whether such operation and maintenance procedures are being used will be
based on information available to the Director which may include, but is not limited to, monitoring results,
review of operation and maintenance procedures, review of operation and maintenance records, and
inspection of the source. [Origin: 40 CFR 63 Subpart ZZZZ]. [40 CFR 63.6595(a)(1), 40 CFR 63.6605(b)]

II.B.44.c.1 Monitoring:

Records required for this permit condition will serve as monitoring.

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II.B.44.c.2 Recordkeeping:

The permittee shall keep the records described in 40 CFR 63.6655(a)(1)-(5) as applicable. [40 CFR
63.6655(a)] The permittee shall document activities performed to assure proper operation and
maintenance. Records shall be maintained in accordance with 40 CFR 63.6660 and Provision I.S.1
of this permit.

II.B.44.c.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Generators are maintained according to manufacturer recommendations or the requirements of
subpart if more stringent. In compliance.

II.B.44.d Condition:

The permittee shall only use natural gas as a fuel in the precious metals generator (#2). [Origin: DAQE-
AN103460058-20]. [R307-401-8]

II.B.44.d.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.44.d.2 Recordkeeping:

The permittee shall keep one of the following sets of records for each affected emission unit, as
applicable:
a) Documentation that the emission unit can only burn natural gas;
b) Documentation that fuels other than natural gas cannot be supplied to the emission unit without
modification of the fuel supply system.

Records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.44.d.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: This unit is a Natural Gas only unit. No other connections were noted. In compliance.

II.B.44.e Condition:

Visible emissions from natural gas-fired emergency engines shall be no greater than 10 percent opacity.
[Origin: DAQE-AN103460058-20]. [R307-401-8]

II.B.44.e.1 Monitoring:

In lieu of monitoring via visible emission observations, the type of fuel used shall be monitored to
demonstrate that only natural gas is being combusted.

131
II.B.44.e.2 Recordkeeping:

The permittee shall maintain records of the types of fuel combusted for all periods of operation.
Records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.44.e.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: This unit is a Natural Gas only unit. No other connections were noted. In compliance.

II.B.44.f Condition:

For the natural gas-fired generator (#2):

(i) For stationary SI ICE with a maximum engine power greater than or equal to 75 KW (100 HP) (except
gasoline and rich burn engines that use LPG), the permittee shall comply with the emission standards in
Table 1 of 40 CFR 60 Subpart JJJJ. (40 CFR 60.4233(e))
(ii) For emergency stationary SI ICE with a maximum engine power of greater than 19 KW (25 HP), the
permittee shall not install engines that do not meet the applicable requirements in 40 CFR 60.4233 after
January 1, 2011. (40 CFR 60.4236(c)) This requirement does not apply to affected emission units that
have been modified or reconstructed, and it does not apply to affected emission units that were removed
from one existing location and reinstalled at a new location. (40 CFR 60.4236(e))
(iii) The permittee shall operate and maintain affected emission units that achieve the emission standards as
required in this condition over the entire life of the engine (40 CFR 60.4234)
(iv) The air-to-fuel ratio (AFR) controller, if used, shall be maintained and operated appropriately by the
permittee in order to ensure proper operation of affected emission units and control device to minimize
emissions at all times. (40 CFR 60.4243(g))
[Origin: 40 CFR 60 Subpart JJJJ]. [40 CFR 60.4233(e), 40 CFR 60.4234, 40 CFR 60.4236, 40 CFR 60.4243,
40 CFR 63 Subpart ZZZZ]

II.B.44.f.1 Monitoring:

(a) For affected emission units subject to 40 CFR 60.4233(e), the permittee shall demonstrate
compliance according to one of the methods specified in paragraphs (a)(1) and (2) of this
section.
(1) Purchasing an engine certified according to procedures specified in 40 CFR 60 Subpart
JJJJ, for the same model year and demonstrating compliance according to one of the
methods specified in paragraphs (1)a) and b) of this section.
a) If the permittee operates and maintains the certified stationary SI internal combustion
engine and control device according to the manufacturer's emission-related written
instructions, the permittee shall keep records of conducted maintenance to
demonstrate compliance, but no performance testing is required. The permittee shall
also meet the requirements as specified in 40 CFR part 1068, subparts A through D,
as they apply. If the permittee adjusts engine settings according to and consistent
with the manufacturer's instructions, the affected emission unit will not be considered
out of compliance.
b) If the permittee does not operate and maintain the certified stationary SI internal
combustion engine and control device according to the manufacturer's emission-
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related written instructions, the engine will be considered a non-certified engine, and
the permittee shall demonstrate compliance according to (i) of this section.
(i) If the affected emission unit is greater than or equal to 100 HP and less than or
equal to 500 HP, the permittee shall keep a maintenance plan and records of
conducted maintenance and shall, to the extent practicable, maintain and operate
the engine in a manner consistent with good air pollution control practice for
minimizing emissions. In addition, the permittee shall conduct an initial
performance test within 1 year of engine startup to demonstrate compliance.
(2) Purchasing a non-certified engine and demonstrating compliance with the emission
standards specified in 40 CFR 60.4233(e) and according to the requirements specified in
40 CFR 60.4244, as applicable, and according to paragraph (2)a) of this section.
a) If the affected emission unit is greater than 25 HP and less than or equal to 500 HP,
the permittee shall keep a maintenance plan and records of conducted maintenance
and shall, to the extent practicable, maintain and operate the engine in a manner
consistent with good air pollution control practice for minimizing emissions. In
addition, the permittee shall conduct an initial performance test to demonstrate
compliance.
(Origin: 40 CFR 60.4243(b))
(b) For affected emission units less than or equal to 500 HP and the permittee purchases a non-
certified engine or does not operate and maintain the certified affected emission unit and control
device according to the manufacturer's written emission-related instructions, the permittee is
required to perform initial performance testing as indicated in this section, but is not required to
conduct subsequent performance testing unless the stationary engine undergoes rebuild, major
repair or maintenance as specified in 40 CFR 60.4243(f). (Origin: 40 CFR 60.4243(f))
(c) The permittee shall conduct performance tests in accordance with the procedures in 40 CFR
60.4244(a) through (f). (Origin: 40 CFR 60.4244)

Records required for this permit condition will also serve as monitoring.

II.B.44.f.2 Recordkeeping:

(a) For the affected emission unit, the permittee shall keep records of the information in paragraphs
(a)(1) through (4) of this section.
(1) All notifications submitted to comply with this condition and all documentation
supporting any notification.
(2) Maintenance conducted on each affected emission unit.
(3) If the affected emission unit is a certified engine, documentation from the manufacturer
that the affected emission unit is certified to meet the emission standards and information
as required in 40 CFR parts 1048, 1054, and 1060, as applicable.
(4) If the affected emission unit is not a certified engine or is a certified engine operating in a
non-certified manner and subject to section (a)(1)b) of monitoring, documentation that the
engine meets the emission standards.
(Origin: 40 CFR 60.4245(a))
(b) The permittee shall keep records of the install date of each affected emission unit and the
applicable requirements under 40 CFR 60 Subpart JJJJ for the respective model year engine.

Records and results of monitoring shall be maintained in accordance with Provision I.S.1 of this
permit.

II.B.44.f.3 Reporting:

133
For affected emission units that are subject to performance testing, the permittee shall submit a copy
of each performance test as conducted in 40 CFR 60.4244 within 60 days after the test has been
completed. (Origin: 40 CFR 60.4245(d))

There are no additional reporting requirements for this provision except those specified in Section I
of this permit.

Status: This unit is a certified unit with certification on unit structure and company has paperwork. The
maintenance is done in accordance with the manufacturer’s requirements and subpart rules. This unit
has been put into the maintenance database. In compliance.

II.B.44.g Condition:

For the natural gas-fired generator (#2):

The permittee shall operate the emergency affected emission unit according to the requirements in
paragraphs (1) through (3). In order for the engine to be considered an emergency stationary ICE under 40
CFR 60 Subpart JJJJ, any operation other than emergency operation, maintenance and testing, and operation
in non-emergency situations for 50 hours per year, as described in (1) through (3), is prohibited. If the
engine is not operated in accordance with paragraphs (1) through (3), it will not be considered an emergency
engine and shall meet all requirements for non-emergency engines.
(1) There is no time limit on the use of emergency stationary ICE in emergency situations.
(2) Emergency stationary ICE may be operated for the purpose specified in 40 CFR 60.4243(d)(2)(i) for a
maximum of 100 hours per calendar year. Any operation for non-emergency situations as allowed by
paragraph (3) counts as part of the 100 hours per calendar year allowed by this paragraph.
(a) Emergency stationary ICE may be operated for maintenance checks and readiness testing,
provided that the tests are recommended by federal, state or local government, the manufacturer,
the vendor, the regional transmission organization or equivalent balancing authority and
transmission operator, or the insurance company associated with the engine. The permittee may
petition for approval of additional hours to be used for maintenance checks and readiness testing,
but a petition is not required if the permittee maintains records indicating that federal, state, or
local standards require maintenance and testing of emergency ICE beyond 100 hours per calendar
year.
(3) Emergency stationary ICE may operate up to 50 hours per calendar year in non-emergency situations,
as specified in 40 CFR 60.4243(d)(3).
[Origin: 40 CFR 60 Subpart JJJJ]. [40 CFR 60.4243(d), 40 CFR 63 Subpart ZZZZ]

II.B.44.g.1 Monitoring:

If the emergency stationary SI ICE that is greater than or equal to 130 HP and less than 500 HP that
was built on or after January 1, 2011, does not meet the standards applicable to non-emergency
engines, the permittee shall install a non-resettable hour meter. (40 CFR 60.4237(b)) Records
required for this permit condition will also serve as monitoring.

II.B.44.g.2 Recordkeeping:

Records shall be kept in accordance with 40 CFR 60.4243(d), as applicable.

For each affected emission unit greater than or equal to 130 HP and less than 500 HP manufactured
on or after July 1, 2011 that does not meet the standards applicable to non-emergency engines, the
permittee shall keep records of the hours of operation of the affected emission unit that is recorded
134
through the non-resettable hour meter. The permittee shall document how many hours are spent for
emergency operation, including what classified the operation as emergency and how many hours are
spent for non-emergency operation.
(Origin: 40 CFR 60.4245(b))

Documentation shall be kept that demonstrates compliance with this provision. Records shall be
maintained as described in Provision I.S.1 of this permit.

II.B.44.g.3 Reporting:

The permittee shall submit an annual report in accordance with 40 CFR 60.4245(e), as applicable.
There are no additional reporting requirements for this provision except those specified in Section I
of this permit.

Status: This is a new engine. Total Hours since installation (19 months) is less than 100. In compliance.

II.B.45 Conditions on #REF SA-1: Refinery Unleaded Gasoline Storage Tank.

II.B.45.a Condition:

The permittee shall maintain records of the average monthly storage temperature, the type of liquid,
throughput quantities, and the maximum true vapor pressure. [Origin: R307-327-4(2)]. [R307-327-4(2)]

II.B.45.a.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.45.a.2 Recordkeeping:

The parameters listed above shall be recorded on a monthly basis and maintained as specified in
Provision I.S.1 of this permit. The permittee shall maintain fuel specification records from the fuel
supplier to demonstrate the maximum true vapor pressure.

II.B.45.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Records of temperature, type of fuel, throughput, and vapor pressure are maintained. Sinclair fills
tanks for Kennecott’s refinery at least monthly and billing data is kept for throughput tracking.
Ambient temperature is used for storage temperature. The type of fuel stored has not changed in any
tank since the last inspection. In compliance.

II.B.45.b Condition:

The permittee shall not allow gasoline to be handled in a manner that would result in vapor releases to the
atmosphere for extended periods of time. Measures to be taken include, but are not limited to, the following:
(1) Minimize gasoline spills;
(2) Clean up spills as expeditiously as practicable;
(3) Cover all open gasoline containers and all gasoline storage tank fill-pipes with a gasketed seal when not
in use;
135
(4) Minimize gasoline sent to open waste collection systems that collect and transport gasoline to
reclamation and recycling devices, such as oil/water separators.
(5) Portable gasoline containers that meet the requirements of 40 CFR part 59, subpart F, are considered
acceptable for compliance with paragraph (3) of this section.

At all times, the permittee shall operate and maintain any affected emission unit, including associated air
pollution control equipment and monitoring equipment, in a manner consistent with safety and good air
pollution control practices for minimizing emissions. Determination of whether such operation and
maintenance procedures are being used will be based on information available which may include, but is not
limited to, monitoring results, review of operation and maintenance procedures, review of operation and
maintenance records, and inspection of the source.

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as identified in Table
3 of 40 CFR 63 Subpart CCCCCC.
[Origin: 40 CFR 63 Subpart CCCCCC]. [40 CFR 63.11111(b), 40 CFR 63.11115, 40 CFR 63.11116, 40
CFR 63.11130]

II.B.45.b.1 Monitoring:

Records required for this permit condition will serve as monitoring. Additionally, the permittee shall
comply with the applicable general provisions in 40 CFR 63.1-15 as identified in Table 3 of 40 CFR
63 Subpart CCCCCC. [40 CFR 63.11130]

II.B.45.b.2 Recordkeeping:

The permittee shall keep records demonstrating monthly throughput is less than the 10,000-gallon
threshold level. Records shall be available within 24 hours of a request by the Director to document
gasoline throughput in the affected emission unit. [40 CFR 63.11111(e), 40 CFR 63.11116(b)]

The permittee shall keep records of the occurrence and duration of each malfunction of operation
(i.e., process equipment) or the air pollution control and monitoring equipment. Records shall be
kept of actions taken during periods of malfunction to minimize emissions, including corrective
actions to restore malfunctioning process and air pollution control and monitoring equipment to its
normal or usual manner of operation. [40 CFR 63.11115(b), 40 CFR 63.11125(d)]

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as identified
in Table 3 of 40 CFR 63 Subpart CCCCCC. [40 CFR 63.11130]

Documentation shall be kept that demonstrates compliance with this provision. Records shall be
maintained in accordance with Provision I.S.1. of this permit.

II.B.45.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Kennecott keeps a spill kit on site to minimize gasoline spills. Preventative maintenance is followed
and recorded through their electronic ‘SAP’ database. Records are kept to demonstrate that
throughput is less than 10,000 gallons each month. The average fuel use based on card reader use was
595 gallons per month with no month exceeding 10,000 gallons. In compliance.

136
II.B.46 Conditions on #REFi 201: Refinery Cold Solvent Degreasers.

II.B.46.a Condition:

The permittee shall ensure that the following conditions are met:
(1) Each solvent degreaser is equipped with a cover which shall remain closed except during actual
loading, unloading or handling of parts in cleaner. The cover shall be designed so that it can be easily
operated with one hand if
(a) the volatility of the solvent is greater than 2 kPa (15 mm Hg or 0.3 psi) measured at 38 degrees C
(100 degrees F),
(b) the solvent is agitated, or
(c) the solvent is heated.
(2) An internal draining rack for cleaned parts shall be installed on which parts shall be drained until all
dripping ceases. If the volatility of the solvent is greater than 4.3 kPa (32 mm Hg at 38 degrees C (100
degrees F)), the drainage facility must be internal, so that parts are enclosed under the cover while
draining. The drainage facility may be external for applications where an internal type cannot fit into
the cleaning system.
(3) Waste or used solvent shall be stored in covered containers.
(4) Tanks, containers and all associated equipment shall be maintained in good operating condition and
leaks shall be repaired immediately or the degreaser shall be shutdown.
(5) Written procedures for the operation and maintenance of the degreasing or solvent cleaning equipment
shall be permanently posted in an accessible and conspicuous location near the equipment.
(6) If the solvent volatility is greater than 4.3 kPa (33 mm Hg or 0.6 psi) measured at 38 degrees C (100
degrees F), or if solvent is heated above 50 degrees C (120 degrees F), then one of the following control
devices shall be used:
(a) freeboard that gives a freeboard ratio greater than 0.7;
(b) water cover if the solvent is insoluble in and heavier than water;
(c) other systems of equivalent control, such as a refrigerated chiller or carbon adsorption.
(7) If used, the solvent spray shall be a solid fluid stream at a pressure which does not cause excessive
splashing and may not be a fine, atomized or shower type spray.
[Origin: R307-335-4]. [R307-335-4]

II.B.46.a.1 Monitoring:

Visual inspections shall be made monthly to demonstrate compliance with this condition.

II.B.46.a.2 Recordkeeping:

Results of monthly inspections, the solvent VOC content applied, and the physical characteristics
that demonstrate compliance with R307-335 shall be recorded and maintained as described in
Provision I.S.1 of this permit.

II.B.46.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: These units use non-halogenated solvent (safety kleen orange). In compliance.

II.B.47 Conditions on #REF COM GEN: Emergency Generator - Communications.

137
II.B.47.a Condition:

The permittee shall use only liquefied petroleum gas (LPG) for fuel in the affected emission unit. [Origin:
DAQE-AN103460058-20]. [R307-401-8]

II.B.47.a.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.47.a.2 Recordkeeping:

The permittee shall keep one of the following sets of records for each affected emission unit, as
applicable:
a) Documentation that the emission unit can only burn liquefied petroleum gas;
b) Documentation that fuels other than liquefied petroleum gas cannot be supplied to the emission
unit without modification of the fuel supply system.

Records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.47.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Only liquefied petroleum gas is used as fuel in the generator. The generator is designed to run on LPG
only. No other connections were noted. In compliance.

II.B.47.b Condition:

Visible emissions shall be no greater than 10 percent opacity. [Origin: DAQE-AN103460058-20]. [R307-
401-8]

II.B.47.b.1 Monitoring:

In lieu of monitoring via visible emission observations, the type of fuel used shall be monitored to
demonstrate that only LPG is being combusted.

II.B.47.b.2 Recordkeeping:

The permittee shall maintain records of the types of fuel combusted for all periods of operation.
Records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.47.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: This unit is a LPG unit with a separate feed tank. No other connections were noted. In compliance.

II.B.48 Conditions on #REF CHP: Refinery Combined Heat and Power Unit.

138
II.B.48.a Condition:

Emissions of NOx from the CHP unit shall be no greater than:
i. 5.96 lbs/hour during TEG firing mode
[Origin: DAQE-AN103460058-20, SIP Section IX.H.2.i, SIP Section IX.H.12.j]. [R307-401-8, SIP
Section IX.H.12.j, SIP Section IX.H.2.i]
ii. 7.49 lbs/hour during fresh air firing mode
[Origin: DAQE-AN103460058-20]. [R307-401-8]

II.B.48.a.1 Monitoring:

To demonstrate compliance with each limit, stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested every 12 months based on the date of the most recent
stack test. Every 12 months means the test shall be performed every 12 months and no more
than 14 calendar months following the previous performance test. The source may also be
tested at any time if directed by the Director.
(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source test protocol shall
outline the proposed test methodologies, stack to be tested, procedures to be used, and shall be
approved by the Director prior to performing the test(s). The source shall attend a pretest
conference if determined necessary by the Director.
(c) Methods.
(1) Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other EPA-approved testing method, as acceptable to the
Director. An Occupational Safety and Health Administration (OSHA)-approved and/or
Mine Safety and Health Administration (MSHA)-approved access shall be provided to the
test location.
(2) 40 CFR 60, Appendix A, Method 7, 7A, 7B, 7C, 7D, or 7E, or other EPA-approved testing
method, as acceptable to the Director, shall be used to determine the pollutant emission
rate.
(3) 40 CFR 60, Appendix A, Method 2, Method 19, or other EPA-approved testing method, as
acceptable to the Director, shall be used to determine the volumetric flow rate.
(d) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate
and any necessary conversion factors determined by the Director to give the results in the
specified units of the emission limitation.
(e) Conditions During Testing. The production rate during all compliance testing shall be no less
than 90 percent of the maximum production achieved in the previous three (3) years.

II.B.48.a.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated test
method and Provision S.1 in Section I of this permit.

II.B.48.a.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of the
testing. Reports shall clearly identify results as compared to permit limits and indicate compliance
status. There are no additional reporting requirements for this provision except those specified in
Section I of this permit.

139
Status: CHP stack testing was conducted on 12/14/2024. Test results were submitted to DAQ and reviewed in
DAQC-193-24 memo. DAQ- calculated results were:
Source Test Date RM/Pollutant DAQ Result Test Result Limit
REFCHP 12/14/2023 RM 7/NOx 3.59 lb/hr 3.58 lb/hr 5.96 lb/hr
Combined RM 10/CO 2.15 lb/hr 2.15 lb/hr 6.43 lb/hr

REFCHP 12/14/2023 RM 7/NOx 6.4 ppmvd * 6.4 ppmvd * 25 ppmvd *
Turbine only

REFCHP 12/14/2023 RM 7/NOx 4.82 lb/hr 4.83 lb/hr 7.49 lb/hr
Duct Burner only 31 ppmvd * 31 ppmvd * 54 ppmvd *
RM 10/CO 2.40 lb/hr 2.40 lb/hr 2.5 lb/hr

*@ 15% O2

In compliance.

II.B.48.b Condition:

Emissions of CO from the CHP unit shall be no greater than:
i. 6.43 lbs/hour during TEG firing mode
ii. 2.5 lbs/hour during fresh air firing mode.
[Origin: DAQE-AN103460058-20]. [R307-401-8]

II.B.48.b.1 Monitoring:

To demonstrate compliance with each limit, stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested every 12 months based on the date of the most recent
stack test. Every 12 months means the test shall be performed every 12 months and no more
than 14 calendar months following the previous performance test. The source may also be
tested at any time if directed by the Director.
If a test result is less than 60.0 percent of the limit for three consecutive years, subsequent
testing may be performed every three years. If at any time a test result is greater than 60.0
percent of the limit, testing shall be performed every year. After three consecutive years with
test results less than 60.0 percent the Director may be repetitioned for less frequent testing.
(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source test protocol shall
outline the proposed test methodologies, stack to be tested, procedures to be used, and shall be
approved by the Director prior to performing the test(s). The source shall attend a pretest
conference if determined necessary by the Director.
(c) Methods.
(1) Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other EPA-approved testing method as acceptable to the
Director. An Occupational Safety and Health Administration (OSHA)-approved and/or
Mine Safety and Health Administration (MSHA)-approved access shall be provided to the
test location.
(2) 40 CFR 60, Appendix A, Method 10, or other EPA-approved testing method as acceptable
to the Director, shall be used to determine the pollutant emission rate.
(3) 40 CFR 60, Appendix A, Method 2, Method 19, or other EPA-approved testing method as
acceptable to the Director, shall be used to determine the volumetric flow rate.
140
(d) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate
and any necessary conversion factors determined by the Director to give the results in the
specified units of the emission limitation.
(e) Conditions During Testing. The production rate during all compliance testing shall be no less
than 90 percent of the maximum production achieved in the previous three (3) years.

II.B.48.b.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated test
method and Provision S.1 in Section I of this permit.

II.B.48.b.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of the
testing. Reports shall clearly identify results as compared to permit limits and indicate compliance
status. There are no additional reporting requirements for this provision except those specified in
Section I of this permit.

Status: CHP stack testing was conducted on 12/14/2024. Test results were submitted to DAQ and reviewed in
DAQC-193-24 memo. DAQ- calculated results were:
Source Test Date RM/Pollutant DAQ Result Test Result Limit
REFCHP 12/14/2023 RM 7/NOx 3.59 lb/hr 3.58 lb/hr 5.96 lb/hr
Combined RM 10/CO 2.15 lb/hr 2.15 lb/hr 6.43 lb/hr

REFCHP 12/14/2023 RM 7/NOx 6.4 ppmvd * 6.4 ppmvd * 25 ppmvd *
Turbine only

REFCHP 12/14/2023 RM 7/NOx 4.82 lb/hr 4.83 lb/hr 7.49 lb/hr
Duct Burner only 31 ppmvd * 31 ppmvd * 54 ppmvd *
RM 10/CO 2.40 lb/hr 2.40 lb/hr 2.5 lb/hr

*@ 15% O2

In compliance.

II.B.48.c Condition:

Visible emissions shall be no greater than 10 percent opacity. [Origin: DAQE-AN103460058-20]. [R307-
401-8]

II.B.48.c.1 Monitoring:

A visual observation of each affected emission unit shall be performed on a monthly basis by an
individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. The
individual is not required to be a certified visible emissions observer. If any visible emissions other
than steam are observed, an opacity determination of that emission unit shall be performed by a
certified visible emissions observer in accordance with 40 CFR 60, Appendix A, Method 9, or other
EPA-approved testing method, as acceptable to the Director, within 24 hours of the initial
observation.
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II.B.48.c.2 Recordkeeping:

Records of visual observations performed and data required by 40 CFR 60, Appendix A, Method 9,
or other EPA-approved testing method, as acceptable to the Director, for each determination shall be
maintained in accordance with Provision I.S.1 of this permit.

II.B.48.c.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: No visible emissions were observed during this inspection or stack test observations. Visual opacity
surveys have been conducted and recorded monthly. Records were reviewed onsite during inspection
with no deviations noted. In compliance.

II.B.48.d Condition:

For new natural gas fired stationary combustion turbines with heat input at peak load (HHV) greater than 50
MMBtu/h and less than or equal to 850 MMBtu/h, emissions of NOx shall be no greater than 25 ppm at 15
percent O2 or 150 nanograms per Joule (ng/J) of useful output (1.2 pounds per megawatt-hour (lb/MWh)).
[Origin: 40 CFR 60 Subpart KKKK]. [40 CFR 60.4320(a)]

II.B.48.d.1 Monitoring:

NOx performance tests shall be conducted on an annual basis (no more than 14 calendar months
following the previous performance test). [40 CFR 60.4400(a)]

To demonstrate continuous compliance, the permittee shall conduct annual performance tests in
accordance with 40 CFR 60.4400(a)(1)-(a)(3)(ii)(B), 60.4400(b), 60.4400(b)(2), 60.4400(b)(4),
60.4400(b)(6).

At least 30 days before the test, the source shall notify the Director of the date, time, and place of
testing. The source shall attend a pretest conference if determined necessary by the Director. [40
CFR 60.8(d), R307-165].

II.B.48.d.2 Recordkeeping:

Results of all performance tests shall be recorded and maintained in accordance with the associated
test method and Provision S.1 in Section I of this permit.

142
II.B.48.d.3 Reporting:

The permittee shall submit a written report of the results of each performance test before the close of
business on the 60th day following the completion of the performance test. [40 CFR 60.4375(b)]
There are no additional reporting requirements for this provision except those specified in Section I
of this permit.

Status: CHP stack testing was conducted on 12/14/2024. Test results were submitted to DAQ and reviewed in
DAQC-193-24 memo. DAQ-calculated results were:
Source Test Date RM/Pollutant DAQ Result Test Result Limit

REFCHP 12/14/2023 RM 7/NOx 3.59 lb/hr 3.58 lb/hr 5.96 lb/hr
Combined RM 10/CO 2.15 lb/hr 2.15 lb/hr 6.43 lb/hr

REFCHP 12/14/2023 RM 7/NOx 6.4 ppmvd * 6.4 ppmvd * 25 ppmvd *
Turbine only

REFCHP 12/14/2023 RM 7/NOx 4.82 lb/hr 4.83 lb/hr 7.49 lb/hr
Duct Burner only 31 ppmvd * 31 ppmvd * 54 ppmvd *
RM 10/CO 2.40 lb/hr 2.40 lb/hr 2.5 lb/hr

*@ 15% O2

In compliance.

II.B.48.e Condition:

For heat recovery units operating independent of the combustion turbine, emissions of NOx shall be no
greater than 54 ppm at 15 percent O2 or 110 ng/J of useful output (0.86 lb/MWh). [Origin: 40 CFR 60
Subpart KKKK]. [40 CFR 60.4320(a)]

II.B.48.e.1 Monitoring:

NOx performance tests shall be conducted on an annual basis (no more than 14 calendar months
following the previous performance test). [40 CFR 60.4400(a)]

To demonstrate continuous compliance, the permittee shall conduct annual performance tests in
accordance with 40 CFR 60.4400(a)(1)-(a)(3)(ii)(B), 60.4400(b), 60.4400(b)(2), 60.4400(b)(4),
60.4400(b)(6).

At least 30 days before the test, the source shall notify the Director of the date, time, and place of
testing. The source shall attend a pretest conference if determined necessary by the Director. [40
CFR 60.8(d), R307-165].

II.B.48.e.2 Recordkeeping:

Results of all performance tests shall be recorded and maintained in accordance with the associated
test method and Provision S.1 in Section I of this permit.

143
II.B.48.e.3 Reporting:

The permittee shall submit a written report of the results of each performance test before the close of
business on the 60th day following the completion of the performance test. [40 CFR 60.4375(b)]
There are no additional reporting requirements for this provision except those specified in Section I
of this permit.

Status: CHP stack testing was conducted on 12/14/2024. Test results were submitted to DAQ and reviewed in
DAQC-193-24 memo. DAQ-calculated results were:
Source Test Date RM/Pollutant DAQ Result Test Result Limit

REFCHP 12/14/2023 RM 7/NOx 3.59 lb/hr 3.58 lb/hr 5.96 lb/hr
Combined RM 10/CO 2.15 lb/hr 2.15 lb/hr 6.43 lb/hr

REFCHP 12/14/2023 RM 7/NOx 6.4 ppmvd * 6.4 ppmvd * 25 ppmvd *
Turbine only

REFCHP 12/14/2023 RM 7/NOx 4.82 lb/hr 4.83 lb/hr 7.49 lb/hr
Duct Burner only 31 ppmvd * 31 ppmvd * 54 ppmvd *
RM 10/CO 2.40 lb/hr 2.40 lb/hr 2.5 lb/hr

*@ 15% O2

In compliance.

II.B.48.f Condition:

The permittee shall comply with either (1) or (2) below.
(1) The permittee shall not discharge into the atmosphere from the subject stationary combustion turbine
any gases which contain SO2 in excess of 110 nanograms per Joule (ng/J) (0.90 pounds per megawatt-
hour (lb/MWh)) gross output;
(2) The permittee shall not burn in the subject stationary combustion turbine any fuel which contains total
potential sulfur emissions in excess of 26 ng SO2/J (0.060 lb SO2/MMBtu) heat input.
[Origin: 40 CFR 60 Subpart KKKK]. [40 CFR 60.4330(a)]

II.B.48.f.1 Monitoring:

a) The permittee shall monitor the total sulfur content of the fuel being fired in the turbine, except
as provided in b) below. The sulfur content of the fuel shall be determined using total sulfur
methods described in 40 CFR 60.4415. Alternatively, if the total sulfur content of the gaseous
fuel during the most recent performance test was less than half the applicable limit, ASTM
D4084, D4810, D5504, or D6228, or Gas Processors Association Standard 2377 (all of which
are incorporated by reference, see 40 CFR 60.17), which measure the major sulfur compounds,
may be used. [40 CFR 60.4360]

If the permittee elects not to demonstrate sulfur content using options in b) below, and the fuel is
supplied without intermediate bulk storage, the sulfur content value of the gaseous fuel shall be
determined and recorded once per unit operating day or according to custom schedules as
specified in 40 CFR 60.4370(c). [40 CFR 60.4370(b), (c)]
144
b) The permittee may elect not to monitor the total sulfur content of the fuel combusted in the
turbine, if the fuel is demonstrated not to exceed potential sulfur emissions of 26 ng SO2/J (0.060
lb SO2/MMBtu) heat input. The permittee shall use one of the following sources of information
to make the required demonstration: [40 CFR 60.4365]
1) The fuel quality characteristics in a current, valid purchase contract, tariff sheet or
transportation contract for the fuel, specifying that the total sulfur content for natural gas is
20 grains of sulfur or less per 100 standard cubic feet, and has potential sulfur emissions of
less than 26 ng SO2/J (0.060 lb SO2/MMBtu) heat input; or [40 CFR 60.4365(a)]
2) Representative fuel sampling data which show that the sulfur content of the fuel does not
exceed 26 ng SO2/J (0.060 lb SO2/MMBtu) heat input. At a minimum, the amount of fuel
sampling data specified in 40 CFR 75 appendix D section 2.3.1.4 or 2.3.2.4 is required. [40
CFR 60.4365(b)]

II.B.48.f.2 Recordkeeping:

Results of monitoring and records used to demonstrate compliance shall be maintained in
accordance with Provision I.S.1 of this permit.

II.B.48.f.3 Reporting:

If the permittee elects to periodically determine the fuel sulfur content, reports of excess emissions
and monitor downtime, as defined in 40 CFR 60.4385, shall be submitted in accordance with 40
CFR 60.7(c). Excess emissions shall be reported for all periods of unit operation, including start-up,
shutdown, and malfunction. [40 CFR 60.4375(a)] All reports required under 40 CFR 60.7(c) shall be
postmarked by the 30th day following the end of each 6-month period. [40 CFR 60.4395] There are
no additional reporting requirements for this provision except those specified in Section I of this
permit.

Status: KUC complies with option 2 by purchasing and burning only pipeline quality natural gas from
Questar. A tariff contract is in place and confirms compliance. In compliance.

II.B.48.g Condition:

The permittee shall operate and maintain the stationary combustion turbine, air pollution control equipment,
and monitoring equipment in a manner consistent with good air pollution control practices for minimizing
emissions at all times including during startup, shutdown, and malfunction. [Origin: 40 CFR 60 Subpart
KKKK, SIP Section IX.H.2.i, SIP Section IX.H.12.j]. [40 CFR 60.4333(a)]

II.B.48.g.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.48.g.2 Recordkeeping:

Permittee shall document activities performed to assure proper operation and maintenance. Records
shall be kept on site which indicate the date and time of startups and shutdowns. (SIP Section
IX.H.12.j state-only requirement) Records shall be maintained in accordance with Provision I.S.1 of
this permit.

145
II.B.48.g.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: KUC appears to operate and maintain the stationary combustion turbine, air pollution control
equipment, and monitoring equipment in a manner consistent with good air pollution control
practices for minimizing emissions. Maintenance is performed based on manufacturer
recommendations and has been recorded as required. In compliance.

II.B.48.h Condition:

The permittee shall only use natural gas as a fuel in the CHP unit. [Origin: DAQE-AN103460058-20].
[R307-401-8]

II.B.48.h.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.48.h.2 Recordkeeping:

The permittee shall keep one of the following sets of records for each affected emission unit, as
applicable:
a) Documentation that the emission unit can only burn natural gas;
b) Documentation that fuels other than natural gas cannot be supplied to the emission unit without
modification of the fuel supply system.

Records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.48.h.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: This unit uses only natural gas, and no other use has been recorded. In compliance.

II.C Emissions Trading
(R307-415-6a(10))

Not applicable to this source.

II.D Alternative Operating Scenarios.
(R307-415-6a(9))

Not applicable to this source.

146
SECTION III: PERMIT SHIELD

The following requirements have been determined to be not applicable to this source in accordance with
Provision I.M, Permit Shield:

III.A. 40 CFR, Part 60, Subpart LL (NSPS, Metallic Mineral Processing Plants)

This regulation is not applicable to the Permitted Source for the following reason(s): the smelter
facility does not produce metallic mineral concentrates from ore and the smelter facility is not
located adjacent to the concentrator facility. [Last updated November 15, 2021]

III.B. 40 CFR Part 61, Subpart O (National Emission Standard for Inorganic Arsenic Emissions From
Primary Copper Smelters)

This regulation is not applicable to the #Smelter: for the following reason(s): the smelter does not
charge molten matte to a copper converter. Subpart O: converter = vessel where copper matte is
charged and oxidized to copper; copper matte = molten copper and iron sulfides produced by
smelting. FCF not converter by definition. [Last updated November 15, 2021]

SECTION IV: ACID RAIN PROVISIONS

This source is not subject to Title IV. This section is not applicable.

EMISSIONS INVENTORY: The combined 2022 emissions inventory for the KUC Smelter and
Refinery are listed in SLEIS as: (2023 report submitted but has not been
completed in SLEIS)

Polluant Tons/yr
PM10 326.19
PM2.5 145.49
SO2 641.89
NOx 120.02
CO 93.98
VOC 9.55
Pb 3.79
NH3 3.91

PREVIOUS ENFORCEMENT
ACTIONS: None in the previous 5 years.

COMPLIANCE STATUS &
RECOMMENDATIONS: In compliance with the applicable Conditions of Title V Operating
Permit 3500030003, Federal, and State rules.

HPV STATUS: Not Applicable

147
RECOMMENDATION FOR
NEXT INSPECTION: None.

COMPLIANCE
ASSISTANCE: Discussion of electronic submissions and need to still do hard copies.

ATTACHMENT: VEO form.