Ariz. Admin. Code § R18-2-B1302 - Limits on SO[2] Emissions from the Hayden Smelter
A. Applicability.
1. This Section applies to the owner or
operator of the Hayden Smelter. It establishes limits on sulfur dioxide
emissions from the Hayden Smelter and monitoring, recordkeeping and reporting
requirements for those limits.
2.
Effective date. Except as otherwise provided, the requirements of this Section
shall become applicable on the earlier of July 1, 2018 or 180 days after
completion of all project improvements authorized by Significant Permit
Revision No. 60647.
B.
Definitions. In addition to definitions contained in
R18-2-101 and
R18-2-B1301, the following
definitions apply to this rule.
1.
"Continuous emissions monitoring system" or "CEMS" means the total equipment,
required under the emission monitoring provisions in this Chapter, used to
sample, condition (if applicable), analyze, and to provide, on a continuous
basis, a permanent record of emissions.
2. "Operating day" means any calendar day in
which any of the following occurs:
a.
Concentrate is smelted in the smelting furnace;
b. Copper or sulfur bearing materials are
processed in the converters;
c.
Blister or scrap copper is processed in the anode furnaces;
d. Molten metal, including slag, matte or
blister copper, is transferred between vessels; or
e. Molten metal is cast into anodes or other
intermediate or final products.
3. "Out of control period" means the time
that begins with the completion of the fifth, consecutive, daily calibration
drift check with a calibration drift in excess of two times the allowable
limit, or the time corresponding to the completion of the daily calibration
drift check preceding the daily calibration drift check that results in a
calibration drift in excess of four times the allowable limit, and the time
that ends with the completion of the calibration check following corrective
action that results in the calibration drifts at both the zero (or low-level)
and high-level measurement points being within the corresponding allowable
calibration drift limit.
C. Sulfur Dioxide Emissions Limitations.
1. Emissions from the Main Stack shall not
exceed 1069.1 pounds per hour on a 14-operating day average unless 1,518 pounds
or less is emitted during each hour of the 14-operating day period.
D.
Operational Standards.
1. Process equipment
and control device operations. At all times, including periods of startup,
shutdown, and malfunction, the owner or operator shall, to the extent
practicable, maintain and operate smelter processes and associated emission
control and/or control equipment in a manner consistent with good air pollution
control practices for minimizing SO2 emissions to the
levels required by subsection (C). Determination of whether acceptable
operating and maintenance procedures are being used will be based on all
information available to the Director and EPA Region IX, which may include, but
is not limited to, monitoring results, review of operating and maintenance
procedures and records, and inspection of the relevant equipment.
2. Capture system and control device
operations and maintenance plan. The owner or operator shall develop and
implement an operations and maintenance plan for each capture system and/or
control device used to ventilate or control process gas or emissions from the
flash furnace including matte tapping, slag skimming, and slag return
operations; converter primary hoods, converter secondary hoods, tertiary
ventilation system, and anode refining operations. The operations and
maintenance plan must address the following requirements as applicable to each
capture system and/or control device.
a.
Monitoring devices. The plan shall provide for installation, operation,
calibration, and maintenance of appropriate monitoring devices to measure and
record operating limit values or settings at all times the required capture and
control system is operating, except during periods of monitor calibration,
repair and malfunction. The initial plan shall provide for volumetric flow
monitoring on the vent gas baghouse (inlet or outlet), each converter primary
hood, each converter secondary hood, the tertiary ventilation system and the
anode furnace baghouse (inlet or outlet). All monitoring devices shall be
accurate within +/-10 percent and calibrated according to manufacturer's
instructions. If direct measurement of the exhaust flow is infeasible due to
physical limitations or exhaust characteristics, the owner or operator may
propose a reliable equivalent method for approval. Initial monitoring may be
adjusted as provided in subsection (D)(2)(e). Dampers that are manually set and
remain in the same position while the capture system is operating are exempt
from these monitoring requirements. Capture system damper position setting(s)
shall be specified in the plan.
b.
Operational limits. The owner or operator shall establish operating limits in
the operations and maintenance plan for the capture systems and/or control
devices that are representative and reliable indicators of the performance of
the capture system and control device operations. The initial operating limits
may be adjusted as provided in subsection (D)(2)(e). Initial operating limits
shall include the following:
i.
Identification of those modes of operation when the double dampers between the
flash furnace vessel and the vent gas system will be closed and the
interstitial space evacuated to the acid plant.
ii. A minimum air flow for the furnace
ventilation system and associated damper positions for each matte tapping hood
or slag skimming hood when operating to ensure that the operation(s) are within
the confines or influence of the capture system.
iii. A minimum air flow for the secondary
hood baghouse and associated damper positions for each slag return hood to
ensure that the operation is within the confines or influence of the capture
system's ventilation draft during times when the associated process is
operating.
iv. A minimum air
infiltration ratio for the converter primary hoods of 1:1 averaged over 24
converter Blowing hours, rolled hourly measured as volumetric flow in primary
hood less the volumetric flow of tuyere Blowing compared to the volumetric flow
of tuyere Blowing.
v. A minimum
secondary hood exhaust rate of 35,000 SCFM during converter Blowing, averaged
over 24 converter Blowing hours, rolled hourly.
vi. A minimum secondary hood exhaust rate of
133,000 SCFM during all non-Blowing operating hours, averaged over 24
non-Blowing hours, rolled hourly.
vii. A minimum negative pressure drop across
the secondary hood when the doors are closed equivalent to 0.007 inches of
water.
viii. A minimum exhaust rate
on the tertiary hooding of 400,000 ACFM during all times material is processed
in the converter aisle, averaged over 24 hours and rolled hourly.
ix. Fan amperes or minimum air flow for the
anode furnace baghouse and associated damper positions for each anode furnace
hood to ensure that the anode furnace off-gas port is within the confines or
influence of the capture system's ventilation draft during times when the
associated furnace is operating.
x.
The anode furnace charge mouth shall be kept covered when the tuyeres are
submerged in the metal bath except when copper is being charged to or
transferred from the furnace.
xi.
The temperatures of the acid plant catalyst bed, which shall at minimum, meet
the manufacturer's recommendations.
xii. The acid plant catalyst replenishment
criteria, which shall at minimum, meet the manufacturer's
recommendations.
c.
Preventative maintenance. The owner or operator must perform preventative
maintenance on each capture system and control device according to written
procedures specified in the operation and maintenance plan. The procedures must
include a preventative maintenance schedule that is consistent with the
manufacturer's or engineer's instructions, or operator's experience working
with equipment, and frequency for routine and long-term maintenance. This
provision does not prohibit additional maintenance beyond that required by the
plan.
d. Inspections. The owner or
operator must perform inspections in accordance with written procedures in the
operations and maintenance plan for each capture system and control device that
are consistent with the manufacturer's, engineer's or operator's instructions
for each system and device.
e. Plan
development and revisions.
i. The owner or
operator shall develop and keep current the plan required by this Section. Any
plan or plan revision shall be consistent with this Section, shall be designed
to ensure that the capture and control system performance conforms to the
attainment demonstration in the Hayden 2010 Sulfur Dioxide National Ambient Air
Quality Standards Nonattainment Area State Implementation Plan (SIP), and shall
be submitted to the Department for review. Any plan or plan revision submitted
shall include the associated manufacturer's recommendations and/or instructions
used for capture system and control device operations and
maintenance.
ii. The owner or
operator shall submit the initial plan to the Department no later than May 1,
2018 and shall include the initial volumetric flow monitoring provisions in
subsection (D)(2)(a), the initial operational limits in subsection (D)(2)(b),
the preventative maintenance procedures in subsection (D)(2)(c), and the
inspection procedures in subsection (D)(2)(d).
iii. The owner or operator shall submit to
the Department for approval a plan revision with changes, if any, to the
initial volumetric flow monitoring provisions in subsection (D)(2)(a) and
initial operational limits in subsection (D)(2)(b) not later than six months
after completing a fugitive emissions study conducted in accordance with
Appendix 14. The Department shall submit the approved changes to the volumetric
flow monitoring provisions and operational limits pursuant to this subsection
to EPA Region IX as a SIP revision not later than 12 months after completion of
a fugitive emissions study.
iv.
Other plan revisions may be submitted at any time when necessary. All plans and
plan revisions shall be designed to achieve operation of the capture system
and/or control device consistent with the attainment demonstration in the
Hayden 2010 Sulfur Dioxide National Ambient Air Quality Standards Nonattainment
Area SIP. Except for changes to the volumetric flow monitoring provisions in
subsection (D)(2)(a) and operational limits in subsection (D)(2)(b), which
shall require prior approval, plans and plan revisions may be implemented upon
submittal and shall remain in effect until superseded or until disapproved by
the Department. Disapprovals are appealable Department actions.
3. Emissions
from the anode furnace baghouse stack shall be routed to the Main
Stack.
E. Monitoring.
1. To determine compliance with subsection
(C)(1) the owner or operator of the Hayden Smelter shall install, calibrate,
maintain, and operate a CEMS for continuously monitoring and recording
SO2 concentrations and stack gas volumetric flow rates
at the following locations.
a. The exit of
the acid plant;
b. The exit of the
secondary hood particulate control device after the High Surface Area (HSA)
lime injection system;
c. The exit
of the flash furnace particulate control device after the HSA lime injection
system;
d. The tertiary ventilation
system prior to mixing with any other exhaust streams; and
e. The anode furnace baghouse stack prior to
mixing with any other exhaust streams.
2. Except during periods of systems
breakdown, repairs, maintenance, out-of-control periods, calibration checks,
and zero and span adjustments, the owner or operator shall continuously monitor
SO2 concentrations and stack gas volumetric flow rates
at each location in subsection (E)(1).
3. For purposes of this section, continuous
monitoring means the taking and recording of at least one measurement of
SO2 concentration and stack gas flow rate reading from
the effluent of each affected stack, outlet, or other approved measurement
location in each 15-minute period when the associated process units are
operating. Fifteen-minute periods start at the beginning of each clock hour,
and run consecutively. All CEMS required by subsection (E)(1) shall complete at
least one cycle of operation (sampling, analyzing, and data recording) for each
successive 15-minute period.
4. If
the owner or operator can demonstrate to the Director that measurement of stack
gas volumetric flow rate in the outlet of any particular piece of
SO2 control equipment would yield inaccurate results or
would be technologically infeasible, then the Director may allow measurement of
the flow rate at an alternative sampling point.
5. The owner or operator shall demonstrate
that the CEMS required by subsection (E)(1) meet all of the following
requirements:
a. The
SO2 CEMS installed and operated under this Section meets
the requirements of 40 CFR 60, Appendix B, Performance Specification 2 and
Performance Specification 6. The CEMS on the anode furnace baghouse stack and
tertiary ventilation system shall complete an initial Relative Accuracy Test
Audit (RATA) in accordance with Performance Specification 2. The RATA runs
shall be tied to when the anode furnace is in use and, for the tertiary system,
when the converters are in operation and/or material is being transferred in
the converter aisle. Asarco may petition the Department and EPA Region IX on
the criteria for subsequent RATAs for the anode furnace baghouse stack or
tertiary ventilation system CEMS. The petition shall include submittal of CEMS
data during the year.
b. The
SO2 CEMS installed and operated under this Section meets
the quality assurance requirements of 40 CFR 60, Appendix F.
c. The owner or operator shall notify the
Director in writing at least 30 days in advance of the start of the relative
accuracy test audit (RATA) performed on the CEMS.
d. The Director shall approve the location of
all sampling points for monitoring SO2 concentration and
stack gas volumetric flow rates and the appropriate span values for the
monitoring systems. This approval shall be in writing before installation and
operation of the measurement instruments.
e. The measurement system installed and used
under this subsection is subject to the manufacturer's recommended zero
adjustment and calibration procedures at least once per operating day unless
the manufacturer specifies or recommends calibration at shorter intervals, in
which case the owner or operator shall follow those specifications or
recommendations. The owner or operator shall make available a record of these
procedures that clearly shows instrument readings before and after zero
adjustment and calibration.
f. The
owner or operator shall maintain on hand and ready for immediate installation
sufficient spare parts or duplicate systems for the CEMS required by this
Section to allow for the replacement within six hours of any monitoring
equipment part that fails or malfunctions during operation.
6. The owner or operator of the
Hayden Smelter may petition the Department to substitute annual stack testing
for the tertiary ventilation or the anode furnace baghouse stack CEMS if the
owner or operator demonstrates, for a period of two years, that either CEMS
contribute(s) less than five percent individually of the total sulfur dioxide
emissions. The Department must determine the demonstration adequate to approve
the petition. Annual stack testing shall use EPA Methods 1, 4, and 6C in 40 CFR
60 Appendix A or an alternate method approved by the Department and EPA Region
IX. Annual stack testing shall commence no later than the one year after the
date the continuous emission monitoring system was removed. The owner or
operator shall submit a test protocol to the Department at least 30 days in
advance of testing. The protocol shall provide for three or more 24-hour runs
unless the owner or operator justifies a different period and the Department
approves such different period. Reports of testing shall be submitted to the
Department no later than 60 days after testing or 30 days after receipt,
whichever is later. The report shall provide an emissions rate, in the form of
a pound per hour or pound per unit of production factor, that shall be used in
the compliance demonstration in subsection (F)(1). Except as provided herein,
the owner or operator shall otherwise comply with section
R18-2-312 in conducting such
testing.
F. Compliance
Demonstration Requirements.
1. For purposes
of determining compliance with the emission limit in subsection (C)(1) the
owner or operator shall calculate emissions for each operating day as follows:
a. Sum the hourly pounds of
SO2 vented to each uncontrolled shutdown ventilation
flue and through each monitoring point listed in subsection (E)(1) for the
current operating day and the preceding 13-operating days to calculate the
total pounds of SO2 emissions over the 14-operating day
averaging period, as applicable.
b.
Divide the total amount of SO2 emissions calculated from
subsection (F)(1)(a) by 336 to calculate the 14-operating day average
SO2 emissions.
c. If the calculation in subsection (F)(1)(b)
exceeds 1069.1 pounds per hour, then the owner or operator shall sum the hourly
pounds of SO2 vented to each uncontrolled shutdown
ventilation flue and through each monitoring point listed in subsection (E)(1)
for each hour of the current operating day and each hour of the preceding
13-operating days to ascertain if any hour exceeded 1,518 pounds per
hour.
2. When no valid
hour or hours of data have been recorded by a continuous monitoring system
required by subsections (E)(1) and (E)(2) and the associated process unit is
operating, the owner or operator shall calculate substitute data for each such
period according to the following procedures:
a. For a missing data period less than or
equal to 24 hours, substitute the average of the hourly
SO2 concentrations recorded by the system for the hour
before and the hour after the missing data period.
b. For a missing data period greater than 24
hours, substitute the greater of:
i. The 90th
percentile hourly SO2 concentrations recorded by the
system during the previous 720 quality-assured monitor operating
hours.
ii. The average of the
hourly SO2 concentrations recorded by the system for the
hour before and the four hours after the missing data period.
c. Notwithstanding subsections
(F)(3)(a) and (F)(3)(b), the owner or operator may present any credible
evidence as to the quantity or concentration of emissions during any period of
missing data.
3. The
owner or operator shall determine compliance with the requirements in
subsection (D)(2) as follows:
a. Maintaining
and operating the emissions capture and control equipment in accordance with
the capture system and control device operations and maintenance plan required
in subsection (D)(2) and recording operating parameters for capture and control
equipment as required in subsection (D)(2)(b); and
b. Conducting a fugitive study in accordance
with Appendix 14 starting not later than 6 months after completion of the
Converter Retrofit Project authorized by Significant Permit Revision No. 60647.
The fugitive study shall demonstrate, as set forth in Appendix 14, that
fugitive emissions from the smelter are consistent with estimates used in the
attainment demonstration in the Hayden 2010 Sulfur Dioxide National Ambient Air
Quality Standards Nonattainment Area SIP.
4. The owner or operator shall include
periods of startup, shutdown, malfunction, or other upset conditions when
determining compliance with the emission limits in subsection (C).
G. Recordkeeping.
1. The owner or operator shall maintain a
record of each operation and maintenance plan required under subsection
(D)(2).
2. The owner or operator
shall maintain the following records for at least five years:
a. All measurements from the continuous
monitoring system required by subsection (E)(1), including the date, place, and
time of sampling or measurement; parameters sampled or measured; and results.
All measurements will be calculated daily.
b. All records of quality assurance and
quality control activities for emissions measuring systems required by
subsection (E)(1).
c. All records
of calibration checks, adjustments, maintenance, and repairs conducted on the
continuous monitoring systems required by subsection (E); including records of
all compliance calculations required by subsection (F).
d. All records of the occurrence and duration
of any startup, shutdown, or malfunction in the operation of concentrate
drying, smelting, converting, anode refining and casting emission units; any
malfunction of the associated air pollution control equipment; or any periods
during which a continuous monitoring system or monitoring device required by
subsection (E)(1) is inoperative or not operating correctly.
e. All records of planned and unplanned
shutdown ventilation flue utilization events and calculations used to determine
emissions from shutdown ventilation flue utilization events if the owner or
operator chooses to use the alternative compliance determination method.
f All records of major maintenance
activities and inspections conducted on emission units, capture system, air
pollution control equipment, and CEMS, including those set forth in the
operations and maintenance plan required by subsection (D)(2).
g. All records of operating days and
production records required for calculations in subsection (F).
h. All records of fugitive emissions studies
and study protocols conducted in accordance with Appendix 14.
i. All records of reports and notifications
required by subsection (H).
H Reporting .
1.
The owner or operator shall notify the Director in writing at
least 30 days in advance of the start of relative accuracy test audit (RATA)
procedures performed on the continuous monitoring systems required by
subsection (E)(1).
2. Within 30
days after the end of each calendar quarter, the owner or operator shall submit
a data assessment report to the Director in accordance with 40 CFR Part 60,
Appendix F for the continuous monitoring systems required by subsection
(E).
3. The owner or operator shall
submit an excess emissions and monitoring systems performance report or summary
report form in accordance with
40 CFR §
60.7(c) to the Director
quarterly for the continuous monitoring systems required by subsection (E)(1).
Excess emissions means any 14-operating day average as calculated in subsection
(F) in excess of the emission limit in subsection (C)(1), any period in which
the capture and control system was operating outside of its parameters
specified in the capture stem and control device operation and maintenance plan
in subsection (D)(2). For any 14-operating day period exceeding 069.1 pounds
per hour that the owner or operator claims does not exceed the limit in
subsection (C)(1) because all hours in the 1 erating period are below 1,518
pounds per hour, the owner or operator shall submit the CEMS data for each hour
during that period. All reports shall be postmarked by the 30th day following
the end of each calendar quarter time period.
4. The owner or operator shall provide the
following to the Director:
a. The owner or
operator shall notify the Director of commencement of construction of any
equipment necessary to comply with the operational or emission
limits.
b. The owner or operator
shall submit semiannual progress reports on construction of any such equipment
postmarked by July 30 for the preceding January-June period and January 30 for
the preceding July-December period
c. The owner or operator shall submit
notification of initial startup of any such equipment within 15 business days
of such startup.
I. Preconstruction review This Section is
determined to be Reasonably Available Control Technology (RACT) for
SO2 emissions from the operations subject to subsection
(C) for purposes of minor source NSR requirement addressed in
R18-2-334.
Notes
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