FINAL REPORT. Notice of Intent. Copperton Concentrator Projects. Prepared for. Kennecott Utah Copper LLC. Prepared by

Transcription

1 FINAL REPORT Notice of Intent Copperton Concentrator Projects Prepared for Kennecott Utah Copper LLC Prepared by March 2011

2 Final Report Notice of Intent for Copperton Concentrator Projects Prepared for Kennecott Utah Copper LLC March 2011

3 Contents Acronyms and Abbreviations... v 1.0 Introduction Process Description Ore Sorting Plant Fifth Ore Grinding Line and Flotation Circuit Emissions Information Ore Sorting Plant Fifth Ore Grinding Line and Flotation Circuit Cold Solvent Degreasers Conveyor Belt Transfer Points Pebble Crusher Lime Bins Diesel Dispensing Cooling Tower Emissions Summary Regulatory Review State of Utah Air Permitting Requirements Notice of Intent and Approval Order (UAC R ) Enforceable Offsets (UAC R , UAC R , and UAC R ) Emissions Impact Analysis (UAC R ) Monitoring and Reporting Federal Air Quality Permitting Requirements New Source Performance Standards (40 CFR 60) General Provisions for Standards of Performance for New Sources (40 CFR 60, Subpart A) Standards for Particulate Matter (40 CFR 60, Subpart LL, ) Monitoring and Testing (40 CFR 60, Subpart LL, , ) Recordkeeping and Reporting (40 CFR 60, Subpart LL, ) Test Methods and Procedures (40 CFR 60, Subpart LL, ) Best Available Control Technology Ore Sorting Plant Ore Sorting Plant Sample Preparation Building \\SNOWBIRD\PROJ\KENNECOTTUTAHCOPPER\411826COPPERTON\NOI\FINAL iii

4 CONTENTS (CONTINUED) 5.2 Fifth Ore Grinding Line and Flotation Circuit Cooling Tower Lime Silos Transfer Points Pebble Crusher References Tables 3-1 Proposed Emissions from the Ore Sorting Plant 3-2 Proposed Emissions from the Sample Preparation Building 3-3 Proposed Emissions from Maintenance Degreasers 3-4 Proposed Emissions from Conveyor Belt Transfer Points 3-5 Proposed Emissions from the New Pebble Crusher 3-6 Proposed Emissions from the Lime Bins 3-7 Proposed Emissions from Diesel Dispensing 3-8 Proposed Emissions from Cooling Tower 3-9 Emissions Summary Figures 2-1 Site Location Map 2-2 Copperton Concentrator: Process Flow Diagram Appendix A Emissions Calculations iv IS SLC\KUC - COPPERTON_NOI_FINAL.DOCX

5 Acronyms and Abbreviations AO BACT BCM CFR EPA ESP KUC mg/l N/A NOI NO x NSPS NSR PM PM 10 PM 2.5 PSD PTE RBLC SAG SO 2 tpy UAC UDAQ VOC Approval Order best available control technology Bingham Canyon Mine Code of Federal Regulations United States Environmental Protection Agency electrostatic precipitator Kennecott Utah Copper LLC milligram per liter not applicable Notice of Intent nitrogen oxide New Source Performance Standards New Source Review particulate matter particulate matter less than 10 micrometers in aerodynamic diameter particulate matter less than 2.5 micrometers in aerodynamic diameter Prevention of Significant Deterioration potential to emit emissions Reasonable Available Control Technology/Best Available Control Technology/Lowest Achievable Emission Rate Clearinghouse semiautogenous grinding sulfur dioxide ton per year Utah Administrative Code Utah Division of Air Quality volatile organic compound IS SLC\KUC - COPPERTON_NOI_FINAL.DOCX v

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7 1.0 Introduction Kennecott Utah Copper LLC (KUC) is submitting this Notice of Intent (NOI) to modify an Approval Order (AO) for the Copperton Concentrator facility, located in Salt Lake County, Utah. Existing operations at the Copperton Concentrator are permitted under DAQE-AN Through this NOI, KUC is proposing to add two new projects at the Copperton Concentrator facility: An ore sorting plant A fifth ore grinding line and flotation circuit This NOI document contains a process description for the proposed projects, emissions information, regulatory review, and control technology analysis. For additional information or questions, please contact Cassady Kristensen at (801) IS SLC\KUC - COPPERTON_NOI_FINAL.DOCX 1-1

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9 2.0 Process Description The Copperton Concentrator is located in Salt Lake County, Utah, near the town of Copperton. The concentrator is currently operating under AO DAQE-AN , issued by the Utah Division of Air Quality (UDAQ). A location map is provided in Figure 2-1. Through this NOI, KUC is proposing to add two new projects at the Copperton Concentrator facility: An ore sorting plant A fifth ore grinding line and flotation circuit 2.1 Ore Sorting Plant KUC is proposing the installation of a new ore sorting plant at the Copperton Concentrator, as a pilot study. Ore crushed in the existing pebble crusher will be used as a feed for this pilot study. The wet material will be fed by a temporary conveyor belt from the existing pebble crushing system to a wet interim stockpile. The material will then be manually fed into a state-of-the-art proprietary sorter, located inside a building. Emissions from the sorting plant will be controlled with a baghouse. The sorter will sort the ore based on its size and create an accepts pile and a rejects pile. Emissions from the storage piles will be minimal, as they will be continuously sprayed with water and moved as necessary to the A-frame located at the Copperton Concentrator. KUC is also proposing to add a new sample preparation building at the Copperton Concentrator. The sample preparation building will be used to generate samples for further testing by a laboratory. Small-scale operations such as grinding, crushing, and screening will result in emissions. Emissions from the sample preparation building will be controlled with a baghouse. 2.2 Fifth Ore Grinding Line and Flotation Circuit The existing Copperton Concentrator facility will be modified to accommodate ore throughput increasing from 160,000 tons per day to 232,900 tons per day, for a planned increase of 72,900 tons per day. Numerous modifications are required for the facility to handle the additional capacity. These modifications include the following: Extending the coarse ore storage pile Adding a fifth grinding line consisting of a semiautogenous grinding (SAG) mill and two ball mills complete with two cyclone clusters for separating the ore slurry Adding a new concentrator building Increasing the pebble crushing capacity of aggregate exiting the SAG mills Adding a new rougher-scavenger flotation circuit IS SLC\KUC - COPPERTON_NOI_FINAL.DOCX 2-1

10 NOTICE OF INTENT FOR COPPERTON CONCENTRATOR PROJECTS Adding tailings thickening capacity Adding a new process water reservoir Relocating and increasing capacity of all reagent tanks Increasing electrical capacity at the substation Details of concentrator process and the impact of the expansion on emissions are described in following sections. A process flow diagram is provided in Figure 2-2. Ore from the Bingham Canyon Mine (BCM) is stockpiled at the coarse ore storage pile in the A-frame enclosure. From the storage pile, the ore is fed to the grinding lines through the coarse ore reclaim tunnels and a series of conveyors directly into the SAG mills. Emissions from the storage pile and reclaim tunnels were presented in the BCM Expansion NOI emissions workbook submitted to UDAQ in August The proposed SAG mill is equipped with a trommel screen allowing minus 5/8-inch material in slurry to pass through for further processing while discharging the larger pebbles at the trommel exit, where they are conveyed to the enclosed pebble crushing building and further reduced. An additional pebble crusher, identical to the existing two crushers, will be installed to handle the increased pebble throughput. The pebble crusher will have an additional processing capacity of 800 tons per hour or 7,008,000 tons per year. The slurry is sent to the cyclone clusters, where the overflow (30 percent solids) is sent to the flotation circuit for concentrating and the underflow (70 percent solids) is sent to the ball mills for further size reduction before being sent back to the cyclones and on to the flotation circuit. Inherent moisture content of the material in the SAG mill, ball mill, and cyclone processes eliminate emissions from each, consistent with current activities. A new cooling system is planned for the grinding line including a dedicated two-cell closed-circuit fluid cooling tower north of the concentrator building to cool the motors used in the grinding circuit. Water with total dissolved solids of 500 milligrams per liter (mg/l) will be fed to the cooling system at a rate of 2,000 gallons per minute. Drift eliminators installed on the cooling tower will eliminate drift to percent of the process water flow. A new rougher-scavenger flotation circuit is needed to accommodate the cyclone overflow from the fifth grinding line. Cyclone overflow is fed into the flotation circuits, mixed with reagents, and aerated to float copper and other valuable by-products from the ore. Concentrate overflow, at approximately 30 percent copper, is pumped to the existing regrinding circuit, while tailings underflow gravity flows to a new collection trench. Because the rougher scavenger flotation process is aqueous based, no emissions are expected from the new flotation circuit consistent with the current floatation circuit. Tailings underflow from the flotation circuits feeds from the collection trenches to the tailings thickener feed distributor. As part of this project, one new thickener will be added to accommodate the increased flow and will discharge tailings underflow to a new drop box and feed into the existing collections system. Tailings are transported by gravity flow to the tailings impoundment for final deposition via pipelines. A third tailings pipeline will be constructed to accommodate shutdown of each pipe for cleaning and descaling activities. The new pipeline will be approximately 3 miles long and reconnect with the existing two 2-2 IS SLC\KUC - COPPERTON_NOI_FINAL.DOCX

11 NOTICE OF INTENT FOR COPPERTON CONCENTRATOR PROJECTS tailings pipelines, allowing tailings to be diverted to any of the three lines. Thickener overflow is pumped back to the process water reservoir. No emissions are anticipated from the tailings thickening operations consistent with current activities. All of the existing reagent storage tanks will be demolished, and new larger tanks will be installed. Three 25,000-gallon tanks for the frother, collector, and fuel oil will be erected to the north of the existing tanks. A new lime slaking facility with two 1,250-ton lime bins, two 18.9-ton-per-hour vertical lime slaking mills, and four lime holding tanks will be installed further north of the existing lime slaking facility. The proposed lime bins will replace the current bins permitted under the BCM operating permit. The lime bins will have emissions associated with filling and loadout, as well as volatile organic compound (VOC) emissions that may exit the fuel oil tank. No emissions are expected from the other reagent tanks consistent with current activities. Emission sources ancillary to the grinding line and flotation circuit include additional cold solvent degreasers for equipment maintenance. In conclusion, emission sources associated with the new fifth grinding line and flotation circuit include cold solvent degreasers, a fuel oil tank, conveyor belt transfer points, a pebble crusher, two lime bins, and a cooling tower. IS SLC\KUC - COPPERTON_NOI_FINAL 2-3

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13 UTAH LAKE 15 Logan PROJECT LOCATION 80 Wendover 80 GREAT SALT LAKE Ogden 84 Salt Lake City West Jordan 80 Park City Vernal Great Salt Lake UTAH 15 Provo Moab KENNECOTT UTAH COPPER MINE KENNECOTT UTAH COPPER CONCENTRATOR Cedar City COPPERTON St. George WEST JORDAN 111 MAGNA 8200 W Image Source: Google Earth Pro; Image Date: June 18, 2010 IS SLC KUC Location Map_ ai ckm FIGURE 2-1 Site Location Map

14 Ore Stockpile BULK FLOTATION To Tailings Impoundment Tailings Thickeners Tailings Line GRINDING Rougher Scavenger Flotation MOLY PLANT SAG Mills Moly 1st Cleaner Flotation Moly Rougher Flotation Copper Moly Thickener Vibrating Screens Pump Station Regrind Ball Mill Regrind Tower Mill Copper to Filtering, Drying Smelting and Refining Tower Mills 1st Cleaner Columns Pebble Crusher Moly 2nd Cleaner Columns Rougher Cleaner Columns Primary Ball Mills Moly 3rd Moly 4th Moly 5th Cleaner Columns Cleaner Columns Cleaner Columns 2nd Cleaner Columns Moly Shipping LEGEND Mechanical Scavengers Ore Concentrate Tailings IS SLC KUC Copperton Flowsheet_v1.ai MAR-11 ckm Moly Mechanical Scavenger Flotation Moly Filtering and Drying FIGURE 2-2 Copperton Concentrator: Process Flow Diagram

15 3.0 Emissions Information Through this NOI, KUC is proposing to add the following two new projects at the Copperton Concentrator facility: An ore sorting plant A fifth ore grinding line and flotation circuit 3.1 Ore Sorting Plant All exhaust air from the ore sorting plant will be routed through the control unit before being vented to the atmosphere. The baghouse will be designed with a grain loading of 0.01 grain per dry standard cubic foot and will operate 8,760 hours per year. Particle distribution is calculated based on the Compilation of Air Pollutant Emission Factors, Volume I: Stationary Point and Area Sources, Fifth Edition (AP-42) (United States Environmental Protection Agency [EPA], 1995), Table B.2.2, Category 3 Mechanically Generated Aggregate Material and Unprocessed Ores. Particulate matter (PM) less than 10 micrometers in aerodynamic diameter (PM 10 ) is 51 percent of the particle distribution, and PM less than 2.5 micrometers in aerodynamic diameter (PM 2.5 ) is 15 percent. Therefore, PM 2.5 is estimated to be 29 percent of PM 10 for operations, including material handling and processing of aggregate and unprocessed ore such as milling, grinding, crushing, screening, conveying, cooling, and drying. Emissions from the ore sorting plant are summarized in Table 3-1. TABLE 3-1 Proposed Emissions from the Ore Sorting Plant PM 10 Emissions Source PM 2.5 Emissions Ore sorting plant All exhaust air from the sample preparation building will be routed through the control unit before being vented to the atmosphere. The baghouse will be designed with a grain loading of 0.01 grain per dry standard cubic foot and will operate 8,760 hours per year. Particle distribution is calculated based on the AP-42, Table B.2.2, Category 3 Mechanically Generated Aggregate Material and Unprocessed Ores. PM 10 is 51 percent of the particle distribution, and PM 2.5 is 15 percent. Therefore, PM 2.5 is estimated to be 29 percent of PM 10 for operations, including material handling and processing of aggregate and unprocessed ore such as milling, grinding, crushing, screening, conveying, cooling, and drying. Emissions from the ore sorting plant are summarized in Table 3-2. IS SLC\KUC - COPPERTON_NOI_FINAL.DOCX 3-1

16 NOTICE OF INTENT FOR COPPERTON CONCENTRATOR PROJECTS TABLE 3-2 Proposed Emissions from the Sample Preparation Building Source PM 10 Emissions PM 2.5 Emissions Sample preparation building Fifth Ore Grinding Line and Flotation Circuit The fifth ore grinding line and flotation circuit will result in particulate emissions from material handling sources and VOC emissions from solvents and fuel oil. Emission sources from the proposed project will include the following: Cold solvent parts washers Conveyor belt transfer points Pebble crusher Lime bin Diesel dispensing Cooling tower Cold Solvent Degreasers Two cold solvent degreasing units will be added to the Copperton Concentrator facility. The units will be housed in the new maintenance shop, with others placed strategically where logistics dictate frequent access to the parts cleaning machines. Approximately 500 gallons of cold solvent will be used annually for maintenance degreasing in the new units. As a conservative estimate, it is assumed that the cold solvent has a VOC content of 100 percent. For purposes of estimating emissions, a conservative estimate of one solvent change-out lost per year is assumed. The VOC emissions resulting from maintenance degreasing were estimated based on the solvent properties and a material balance. Emissions from the cold solvent degreasers are summarized in Table 3-3. TABLE 3-3 Proposed Emissions from Maintenance Degreasers VOC Emissions Emission Source Maintenance degreasers Conveyor Belt Transfer Points Additional conveyor belt transfer points are needed to move material from the reclaim tunnels into the new SAG mill. Two new transfer points (transfer from the pebble crusher onto the conveyor and transfer from the conveyor belt onto the SAG conveyor) are needed to accommodate the additional material flow, with emissions controlled by enclosures and/or water sprays as necessary. Based on preliminary design, the annual process rate for 3-2 IS SLC\KUC - COPPERTON_NOI_FINAL.DOCX

17 NOTICE OF INTENT FOR COPPERTON CONCENTRATOR PROJECTS the transfer points described will be approximately 7,008,000 tpy and 34,675,000 tpy, respectively. Particulate emissions from the conveyor transfer points are estimated using emissions factors from Table of AP-42. AP-42, Table B.2.2, Category 3 Mechanically Generated Aggregate Material and Unprocessed Ores, shows PM 10 to be 51 percent of the particle distribution and PM 2.5 to be 15 percent. Therefore PM 2.5 is estimated to be 29 percent of PM 10 for operations, including material handling and processing of aggregate and unprocessed ore such as milling, grinding, crushing, screening, conveying, cooling, and drying. Consistent with discussion in AP-42, Chapter , the moisture of the material will be greater than 2.88 percent to allow the use of controlled emission factors from this section. In addition to transfer points feeding the SAG mill, transfer points within the pebble crushing building will need to increase in size and a new transfer point added upstream and downstream of the new pebble crusher to accommodate the increased material flow. All material exiting the SAG mill is completely saturated; therefore, no emissions are expected from the increased material throughput in any other transfer points at the facility. Emissions from the transfer points leading up to the SAG mill are summarized in Table 3-4. TABLE 3-4 Proposed Emissions from Conveyor Belt Transfer Points PM 10 Emissions Source PM 2.5 Emissions Transfers Pebble Crusher A third cone crusher is proposed to handle pebbles exiting the SAG mill that are greater than 5/8-inch diameter and require further size reduction before they can be pumped to the cyclone circuits. The pebbles are conveyed to a separate crushing building adjacent to the grinding building, as described previously. Particulate emissions from the pebble crusher are estimated using emissions factors from AP-42, Table AP-42, Table B.2.2, Category 3 Mechanically Generated Aggregate Material and Unprocessed Ores, shows PM 10 to be 51 percent of the particle distribution and PM 2.5 to be 15 percent. Therefore, PM 2.5 is estimated to be 29 percent of PM 10 for operations, including material handling and processing of aggregate and unprocessed ore such as milling, grinding, crushing, screening, conveying, cooling, and drying. Consistent with the existing pebble crushers, a control efficiency of 90 percent is assumed for the building enclosure around the crusher. Material flow through the additional pebble crusher is projected to be 7,008,000 tpy or 800 tons per hour. Emissions from the new pebble crusher are summarized in Table 3-5. TABLE 3-5 Proposed Emissions from the New Pebble Crusher PM 10 Emissions Source PM 2.5 Emissions Pebble crusher IS SLC\KUC - COPPERTON_NOI_FINAL.DOCX 3-3

18 NOTICE OF INTENT FOR COPPERTON CONCENTRATOR PROJECTS Lime Bins A new lime slaking facility with two 1,250-ton lime bins, two 18.9-ton-per-hour vertical lime slaking mills, and four lime holding tanks will be installed north of the existing lime slaking facility. The lime bins will be pneumatically loaded from tanker trucks on an ongoing basis, and particulate emissions will be controlled via fabric bin vent control units. All exhaust air from the lime silos is routed through the control units before being vented to the atmosphere. The two lime bins will have either two bin vent filters with an air flow of 2,000 dry standard cubic feet per minute each or a single bin vent filter with an air flow of 4,000 dry standard cubic feet per minute. The vent fabric filter will be designed with a grain loading of 0.01 grain per dry standard cubic foot and will operate 8,760 hours per year. The EPA s AP-42, Table B.2.2, Category 4 Mechanically Processed Ores and Nonmetallic Minerals, shows PM 10 to be 85 percent of the particle distribution and PM 2.5 to be 30 percent. Therefore, PM 2.5 is estimated to be 35 percent of PM 10 for operations, including material handling and processing of processed ores and nonmetallic minerals such as lime. Emissions from the lime bins are summarized in Table 3-6. TABLE 3-6 Proposed Emissions from the Lime Bins PM 10 Emissions Source PM 2.5 Emissions Lime bins Diesel Dispensing The proposed modification will add a diesel dispensing station with approximately 500,000 gallons of diesel fuel per year. Volatile organic compound emissions from diesel fueling stations are estimated using emission factors from Colorado Department of Public Health and Environment s guidance on Gasoline and Diesel Fuel Dispensing Stations in the absence of an EPA AP-42 factor. Volatile organic compound emissions from the fueling stations are summarized in Table 3-7. TABLE 3-7 Proposed Emissions from Diesel Dispensing VOC Emissions Emission Source Diesel dispensing Cooling Tower A new cooling system is planned to cool the engines employed at the grinding mills. The cooling tower will be a dedicated two-cell closed-circuit evaporative fluid cooler tower located to the north of the concentrator building. Water with total dissolved solids of 500 mg/l will be fed to the cooling system at a rate of 2,000 gallons per minute. The cooling tower will be equipped with drift eliminators capable of controlling drift to percent of 3-4 IS SLC\KUC - COPPERTON_NOI_FINAL.DOCX

19 NOTICE OF INTENT FOR COPPERTON CONCENTRATOR PROJECTS the process water flow. Particulate emissions from the cooling tower are estimated using factors from AP-42, Section , and from the article Calculating Realistic PM 10 Emissions from Cooling Towers by J. Reisman and G. Frisbie (2002). Annual emissions from the cooling tower are summarized in Table 3-8. TABLE 3-8 Proposed Emissions from Cooling Tower Source PM 10 Emissions PM 2.5 Emissions Cooling tower Emissions Summary Table 3-9 summarizes the currently permitted Copperton Concentrator potential to emit emissions (PTE), the proposed modification PTEs, and pertinent emission rates and thresholds. Emissions from the proposed modification are below the modeling thresholds; therefore, no ambient air quality modeling is submitted with this NOI. TABLE 3-9 Emissions Summary Current PTEs Add: Ore Sorting Plant Add: Fifth Line Future Copperton Concentrator PTEs PSD/NSR Significant Emission Rates Modeling Thresholds (UAC R ) Nitrogen oxides Carbon monoxide Sulfur oxides VOCs Total PM Total PM N/A N/A NOTES: N/A = Not Applicable NSR = New Source Review PSD = Prevention of Significant Deterioration UAC = Utah Administrative Code IS SLC\KUC - COPPERTON_NOI_FINAL.DOCX 3-5

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21 4.0 Regulatory Review This section provides a regulatory review of the applicability of state and federal air quality permitting requirements for the Copperton Concentrator facility. 4.1 State of Utah Air Permitting Requirements The State of Utah has been granted authority to implement and enforce the permitting requirements specified by the federal Clean Air Act. The general requirements for permits and permit revisions are codified under the state environmental protection regulations, UAC R Notice of Intent and Approval Order (UAC R ) The KUC Copperton Concentrator modification will result in an increase of emissions, necessitating the issuance of an AO pursuant to UAC R , Permits. The KUC concentrator modification will not trigger Title V or major source NSR permitting. KUC is required by UAC R to submit to UDAQ this NOI application and obtain a UDAQ-issued AO prior to initiation of construction activities associated with concentrator modification. According to UAC R , the NOI must include the following: A description of the project (provided in Section 1.0 of the NOI) A description and characteristics of emissions and control equipment (provided in Sections 2.0 and 3.0 of the NOI) An analysis of the best available control technology (BACT) for the proposed source or modification (provided in Section 5.0 of the NOI) Location map (provided in Section 2.0 of the NOI) Enforceable Offsets (UAC R , UAC R , and UAC R ) Utah Administrative Code R (1)(b) states that enforceable offsets of 1.2:1 are required for new sources or modifications that would produce an emission increase greater than or equal to 50 tpy of any combination of PM 10, sulfur dioxide (SO 2 ), and nitrogen oxide (NO x ). Utah Administrative Code R (1)(c) states that enforceable offsets of 1.1:1 are required for new sources or modifications that would produce an emissions increase greater than or equal to 25 tpy but less than 50 tpy of any combination of PM 10, SO 2, and NO x. Utah Administrative Code R (2) specifically states that for offset determinations, PM 10, SO 2, and NO x will be considered on an equal basis. IS SLC\KUC - COPPERTON_NOI_FINAL.DOCX 4-1

22 NOTICE OF INTENT FOR COPPERTON CONCENTRATOR PROJECTS The net change in the combined total emissions of PM 10, SO 2, and NO x from stationary point sources from the proposed modification, as indicated in Table 3-9, is less than 25 tpy. Therefore, this project will not require any offsets Emissions Impact Analysis (UAC R ) The Copperton Concentrator is not subject to UAC R , which describes the emissions impact analysis requirements, since the emissions increases from the project do not trigger any modeling thresholds. Since the facility is located in a nonattainment area for PM 10 and PM 2.5, modeling is not required for these pollutants Monitoring and Reporting After UDAQ issues an AO, KUC will be required to submit emissions reports and conduct other activities as UDAQ requests. Some of these requirements include the following: Meet the reporting requirements specified in UAC R in the event of an unavoidable breakdown Submit and retain an air emission inventory as required in UAC R , based on its applicability under UAC R (3) 4.2 Federal Air Quality Permitting Requirements New Source Performance Standards (40 CFR 60) KUC s Copperton Concentrator is a metallic mineral processing plant, one of the source categories subject to the New Source Performance Standards (NSPS), specifically 40 Code of Federal Regulations (CFR) 60, Subpart LL. The NSPS apply to any apparatus to which a standard is applicable that initiates construction or modification after August 24, 1982 (40 CFR 60, [b]). The new pebble crusher and conveyor belt transfer points are apparatuses to which Subpart LL standards are applicable General Provisions for Standards of Performance for New Sources (40 CFR 60, Subpart A) Subpart A describes general provisions that are applicable to any source that is subject to NSPS. The KUC concentrator modification is subject to 40 CFR 60, Subpart LL, Standards of Performance for Metallic Mineral Processing Plants, and therefore subject to 40 CFR 60, Subpart A, the General Provisions for Standards of Performance for New Sources Standards for Particulate Matter (40 CFR 60, Subpart LL, ) Particulate matter emissions resulting from the concentrator modification include process fugitive emissions from the new conveyor belt transfer points, storage bins, and pebble crushers. This equipment will be housed inside a building that will have a nonpassive building vent (that is, a vent with a fan). Process fugitive emissions are defined in 40 CFR as PM emissions that are not collected by a capture system. A capture system is defined in 40 CFR as equipment used to capture and transport PM to a control device. The fugitive emissions inside the building will not be captured and transported to a control device but will be vented to the atmosphere through the building vent. Therefore, 4-2 IS SLC\KUC - COPPERTON_NOI_FINAL.DOCX

23 NOTICE OF INTENT FOR COPPERTON CONCENTRATOR PROJECTS the process fugitive emissions from the building vent will be subject to 40 CFR (b), which limits opacity of fugitive emissions to 10 percent. Stack emissions are defined in 40 CFR as PM captured and released to the atmosphere through a stack, chimney, or flue. The building vent of the building housing the crusher and transfer points will not have a stack, chimney, or flue. Therefore, 40 CFR 60 NSPS (a)(1) and (2), which restrict affected facility stack PM emissions to 0.05 gram per dry standard cubic meter and 7 percent opacity, do not apply to the concentrator modification Monitoring and Testing (40 CFR 60, Subpart LL, , ) 40 CFR describes requirements for the installation, operation, and continuous monitoring of the change in pressure of the gas stream through a scrubber and scrubbing liquid flow rates for any affected facility using a wet scrubbing emission control device. The concentrator modification will not include wet scrubbing emission control devices but instead bin vent filters on the lime bins; therefore, this rule does not apply Recordkeeping and Reporting (40 CFR 60, Subpart LL, ) 40 CFR requires affected facilities to conduct performance tests and submit written reports of the results of the tests to UDAQ as specified by 40 CFR 60, Subpart A, 60.8(a). KUC must comply with 40 CFR 60, Subpart A, 60.8 (a), which requires performance tests and a written report of the results of the performance tests be sent to UDAQ within 60 days after achieving the maximum production rate at which the affected facility will be operated, but not later than 180 days after initial startup of such facility Test Methods and Procedures (40 CFR 60, Subpart LL, ) 40 CFR requires that KUC determine compliance with the PM standard from 40 CFR , which restricts process fugitive emissions opacity to 10 percent, using Method 9. IS SLC\KUC - COPPERTON_NOI_FINAL.DOCX 4-3

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25 5.0 Best Available Control Technology This section describes the BACT analysis for the new emissions sources that will be added as part of the proposed modification. According to UAC R , The Executive Secretary will issue an approval order if the following conditions have been met: The degree of pollution control for emissions, to include fugitive emissions and fugitive dust, is at least best available control technology. 5.1 Ore Sorting Plant Ore Sorting Plant Particulate emissions will be emitted from the ore sorting plant. A BACT analysis for the proposed ore sorting plant is presented as follows: Step 1 Identify All Control Technologies. Three control technologies have been identified for particulate control: Electrostatic precipitators (ESPs) Wet scrubbers Fabric filters Step 2 Eliminate Technically Infeasible Options. All three control technologies are feasible to control particulate emissions from this source. Step 3 Rank Remaining Control Technologies by Control Effectiveness. The fabric filter is more effective at capturing fine particulate than an ESP because ESPs tend to collect larger particles selectively. Wet scrubbers, although effective at capturing fine particulate, produce a wet sludge requiring disposal. Also, wet scrubbers have higher operating costs and lower removal efficiencies than fabric filters. Based on their control effectiveness, the fabric filter ranks at the top, followed by an ESP and then by wet scrubbers. Step 4 Evaluate Most Effective Controls and Document Results. Since fabric filters represent the most effective particulate control technique, and since these fabric filters are proposed, no further evaluation is warranted. Step 5 Select BACT. In addition to this analysis, the EPA s Reasonable Available Control Technology/BACT/Lowest Achievable Emission Rate Clearinghouse (RBLC) database was reviewed. Consequently, the BACT selected for this project is fabric filter/baghouse achieving an outlet grain loading 0.01 grain per dry cubic foot. IS SLC\KUC - COPPERTON_NOI_FINAL.DOCX 5-1

26 NOTICE OF INTENT FOR COPPERTON CONCENTRATOR PROJECTS Sample Preparation Building Particulate emissions will be emitted from the sample preparation building. A BACT analysis for the proposed sample preparation building is presented as follows: Step 1 Identify All Control Technologies. Three control technologies have been identified for particulate control: ESPs Wet scrubbers Fabric filters Step 2 Eliminate Technically Infeasible Options. All three control technologies are feasible to control particulate emissions from this source. Step 3 Rank Remaining Control Technologies by Control Effectiveness. The fabric filter is more effective at capturing fine particulate than an ESP because ESPs tend to collect larger particles selectively. Wet scrubbers, although effective at capturing fine particulate, produce a wet sludge requiring disposal. Also, wet scrubbers have higher operating costs and lower removal efficiencies than fabric filters. Based on their control effectiveness, the fabric filter ranks at the top, followed by an ESP and then by wet scrubbers. Step 4 Evaluate Most Effective Controls and Document Results. Since fabric filters represent the most effective particulate control technique, and since these fabric filters are proposed, no further evaluation is warranted. Step 5 Select BACT. In addition to this analysis, the EPA s RBLC database was reviewed. Consequently, the BACT selected for this project is fabric filter/baghouse achieving an outlet grain loading 0.01 grain per cubic foot. 5.2 Fifth Ore Grinding Line and Flotation Circuit Cooling Tower The following describes the BACT analysis for the proposed conventional design, draft force cooling tower system: Step 1 Identify All Control Technologies. The only control method for reducing particulate emissions from cooling towers is the use of drift eliminators. Steps 2, 3, and 4 Eliminate Technically Infeasible Options, Rank, and Evaluate. Drift eliminators were the only control technology identified. They are technically feasible and effective. Because there were no other control technologies identified, Steps 3 and 4 were not necessary. Step 5 Select BACT. Drift eliminators are the only control method identified for control of particulate emissions from cooling towers. Based on this analysis and the EPA s RBLC database, drift eliminators with a control efficiency of percent (gallons of drift per gallon of cooling water flow) are chosen as BACT for the cooling tower in this project. 5-2 IS SLC\KUC - COPPERTON_NOI_FINAL.DOCX

27 NOTICE OF INTENT FOR COPPERTON CONCENTRATOR PROJECTS Lime Silos Particulate emissions will be emitted from the lime silos. A BACT analysis for the proposed lime silos is presented as follows: Step 1 Identify All Control Technologies. Three control technologies have been identified for particulate control: ESPs Wet scrubbers Fabric filters Step 2 Eliminate Technically Infeasible Options. All three control technologies are feasible to control particulate emissions from these sources. Step 3 Rank Remaining Control Technologies by Control Effectiveness. The fabric filter is more effective at capturing fine particulate than an ESP because ESPs tend to collect larger particles selectively. Wet scrubbers, although effective at capturing fine particulate, produce a wet sludge requiring disposal. Also, wet scrubbers have higher operating costs and lower removal efficiencies than fabric filters. Based on their control effectiveness, the fabric filter ranks at the top, followed by an ESP and then by wet scrubbers. Step 4 Evaluate Most Effective Controls and Document Results. Since fabric filters or bin vent filters represent the most effective particulate control technique, and since these bin vent filters are proposed, no further evaluation is warranted. Step 5 Select BACT. Based on this analysis and review of the EPA s RBLC database, bin vent filters achieving an outlet grain loading 0.01 grain per dry standard cubic foot are selected as BACT for this project Transfer Points Particulate emissions will be emitted from the material transfer points from one conveyor to another. The following presents a BACT analysis for the proposed transfer points: Step 1 Identify All Control Technologies. Five control technologies have been identified for particulate control: ESPs Wet scrubbers Fabric filters Water sprays Enclosures Step 2 Eliminate Technically Infeasible Options. Because the emissions from the transfer points are fugitive in nature, ESPs, wet scrubbers, and fabric filters are not technically feasible. Step 3 Rank Remaining Control Technologies by Control Effectiveness. Both the enclosures and water sprays are effective in minimizing emissions from the transfer points. IS SLC\KUC - COPPERTON_NOI_FINAL.DOCX 5-3

28 NOTICE OF INTENT FOR COPPERTON CONCENTRATOR PROJECTS Step 4 Evaluate Most Effective Controls and Document Results. Since both of the remaining control technologies are proposed, no further evaluation is warranted. Step 5 Select BACT. Based on this analysis and review of the EPA s RBLC database, enclosures and/or water sprays are selected as BACT for this project Pebble Crusher Particulate emissions will be emitted from the pebble crusher, and this section presents a BACT analysis for the proposed pebble crusher. Step 1 Identify All Control Technologies. Five control technologies have been identified for particulate control: ESPs Wet scrubbers Fabric filters Water sprays Enclosures Step 2 Eliminate Technically Infeasible Options. Because the emissions will be vented from the building, ESPs, wet scrubbers, and fabric filters are not technically feasible. Water sprays are not feasible as the water makes the material too wet to crush. Step 3 Rank Remaining Control Technologies by Control Effectiveness. Enclosure, or placing the source inside the building, is effective in minimizing emissions from the crusher. Step 4 Evaluate Most Effective Controls and Document Results. Since the remaining control technologies are proposed, no further evaluation is warranted. Step 5 Select BACT. Based on this analysis and review of the EPA s RBLC database, enclosures, or placing the emission source inside the building, is selected as BACT for this project. 5-4 IS SLC\KUC - COPPERTON_NOI_FINAL.DOCX

29 6.0 References Colorado Department of Public Health and Environment. A Guide to Air Regulations for: Gasoline and Fuel Dispensing Stations. Small Business Assistance Program. Available at Accessed January 21, Reisman, J., and G. Frisbie Calculating Realistic PM 10 Emissions from Cooling Towers. Environmental Progress. Vol. 21, No. 2. pp United States Environmental Protection Agency (EPA) Compilation of Air Pollutant Emission Factors, Volume I: Stationary Point and Area Sources. Fifth Edition. Office of Air Quality Planning and Standards; Office of Air and Radiation. January. IS SLC\KUC - COPPERTON_NOI_FINAL.DOCX 6-1

30 NOTICE OF INTENT FOR COPPERTON CONCENTRATOR PROJECTS THIS PAGE INTENTIONALLY LEFT BLANK 6-2 IS SLC\KUC - COPPERTON_NOI_FINAL.DOCX

31 APPENDIX A Emissions Calculations

32 APPENDIX A INDEX Tables Titles A-1 Copperton Concentrator Emissions Summary A-2 Emissions Summaries for the Fifth Line Expansion Project and Ore Sorting Project A-3 Project: Fifth Line Expansion; Source: Cold Solvent Degreasing Parts A-4 Project: Fifth Line Expansion; Source: Pebble Crushers A-5 Project: Fifth Line Expansion; Source: Transfer Points A-6 Project: Fifth Line Expansion; Source: Lime Bins A-7 Project: Fifth Line Expansion; Source: Diesel Fueling A-8 Project: Fifth Line Expansion; Source: Cooling Tower A-9 Project: Ore Sorting; Source: Ore Sorting Plant A-10 Project: Ore Sorting; Source: Sample Preparation Building A-11 Facilitywide GHG Emissions Units tpy dscf dscfm ft 3 gal gr hr kg lb m 3 mg/l MMBtu ppmw yr Definitions ton per year dry standard cubic feet dry standard cubic feet per minute cubic feet gallon grain hour kilogram pound cubic meter milligram per liter million British thermal units part per million by weight year Acronyms Definitions CO 2 carbon dioxide CO 2 e carbon dioxide equivalent AP-42 Compilation of Air Pollutant Emission Factors, Volume I: Stationary Point and Area Sources, Fifth Edition (EPA, 1995) GHG greenhouse gas HAP hazardous air pollutant KUC Kennecott Utah Copper LLC MSDS material safety data sheet CH 4 methane NSR New Source Review N 2 O nitrous oxide N/A not applicable PM particulate matter PM 10 particulate matter less than 10 micrometers in aerodynamic diameter PM 2.5 particulate matter less than 2.5 micrometers in aerodynamic diameter PTE potential to emit emissions PSD Prevention of Significant Deterioration SAG semiautogenous grinding TDS total dissolved solids TP Transfer Point EPA United States Environmental Protection Agency UAC Utah Administrative Code IS SLC\KUC - Concentrator5thLineEmissionCalcs_rev9.xlsx PAGE 1 OF 2

33 APPENDIX A INDEX Acronyms Definitions UDAQ Utah Division of Air Quality VOC volatile organic compound References Colorado Department of Public Health and Environment. A Guide to Air Regulations for: Gasoline and Fuel Dispensing Stations. Small Business Assistance Program. Available at Accessed January 21, Reisman, J., and G. Frisbie Calculating Realistic PM 10 Emissions from Cooling Towers. Environmental Progress. Vol. 21, No. 2. pp United States Environmental Protection Agency (EPA) Compilation of Air Pollutant Emission Factors, Volume I: Stationary Point and Area Sources. Fifth Edition. Office of Air Quality Planning and Standards; Office of Air and Radiation. January. IS SLC\KUC - Concentrator5thLineEmissionCalcs_rev9.xlsx PAGE 2 OF 2

34 TABLE A-1 Copperton Concentrator Emissions Summary Notice of Intent for Copperton Concentrator Projects Add: Ore Sorting Plant Future Copperton Concentrator PTEs PSD/NSR Significant Emission Rates Modeling Thresholds (UAC R ) Current PTEs Add: Fifth Line Nitrogen oxides Carbon monoxide Sulfur oxides VOCs Total PM Total PM N/A N/A NOTE: Modeling thresholds for PM 10 and PM 2.5 are not applicable to this project, as Salt Lake County is nonattainment for PM 10 and PM 2.5 per UDAQ regulations. Modeling for PM 10 and PM 2.5 is not required in a nonattainment area. IS SLC\KUC - Concentrator5thLineEmissionCalcs_rev9.xlsx PAGE 1 OF 1

35 TABLE A-2 Emissions Summaries for the Fifth Line Expansion Project and Ore Sorting Project Notice of Intent for Copperton Concentrator Projects Fifth Line Expansion Project Source PM 10 PM 2.5 VOC Degreasers 1.69 Pebble crusher SAG mill TPs Lime bin Fuel oil tank 0.01 Cooling towers Total Emissions Summary for the Ore Sorting Project Source PM 10 PM 2.5 Ore sorting plant Sample preparation building Total IS SLC\KUC - Concentrator5thLineEmissionCalcs_rev9.xlsx PAGE 1 OF 1

36 TABLE A-3 Project: Fifth Line Expansion; Source: Cold Solvent Degreasing Parts Notice of Intent for Copperton Concentrator Projects Source Name Throughput (gal/yr) Specific Gravity Density (lb/gal) Percent VOCs Uncontrolled VOC Emissions Control Efficiency (percent) Controlled VOC Emissions Cold solvent degreasing parts NOTES: Emissions estimated based on material balance. Throughput based on one solvent change per year for the degreasers. Control System and Comments Degreasers are enclosed IS SLC\KUC - Concentrator5thLineEmissionCalcs_rev9.xlsx PAGE 1 OF 1

37 TABLE A-4 Project: Fifth Line Expansion; Source: Pebble Crushers Notice of Intent for Copperton Concentrator Projects Source Name Number of New Pebble Crushers PM 10 Emission Factor (lb/ton) PM 2.5 Scaling Factor PM 2.5 Emission Factor (lb/ton) Process Flow Rate Control Efficiency PM 10 Emissions PM 2.5 Emissions Pebble crushers ,008,000 90% NOTES: Emissions for PM 2.5 based on factors from AP-42, Table B.2.2, Category 3 Mechanically Generated Aggregate and Unprocessed Ores. Wet suppression emission factors for PM 10 and PM 2.5 taken from AP-42, Chapter 11, Table Control System and Comments The process is fully enclosed within a building IS SLC\KUC - Concentrator5thLineEmissionCalcs_rev9.xlsx PAGE 1 OF 1

38 TABLE A-5 Project: Fifth Line Expansion; Source: Transfer Points Notice of Intent for Copperton Concentrator Projects Number of Transfer Points Annual Process Rate PM 10 Emission Factor (lb/ton) Source Name Transfer from crusher onto CNV-4 Transfer points leading to SAG mill NOTES: Emission factors for controlled transfer points taken from AP-42, Chapter 11, Table PM 10 Emission Factor 4.60E-05 lb/ton PM 2.5 Emission Factor (lb/ton) Enclosure PM 10 Emissions Enclosure PM 2.5 Emissions 1 7,008, ,675, PM 2.5 Emission Factor 1.30E-05 lb/ton With the added water, the moisture of the material will be greater than 2.88 percent as referenced in AP-42, Chapter Control System and Comments Enclosures and water sprays Enclosures and water sprays IS SLC\KUC - Concentrator5thLineEmissionCalcs_rev9.xlsx PAGE 1 OF 1

39 TABLE A-6 Project: Fifth Line Expansion; Source: Lime Bins Notice of Intent for Copperton Concentrator Projects Source Name Number of Bins PM 10 Emission Factor (gr/dscf) Hours of Operation (hr/yr) Design Flow Rate (dcf/min) Controlled PM 10 Emissions (lb/hr) Controlled PM 10 Emissions Controlled PM 2.5 Emissions Control System and Comments Lime bin , NOTES: Emissions for PM 2.5 based on factors from AP-42, Table B.2.2, Category 3 Mechanically Generated Aggregate and Unprocessed Ores. The two lime bins will have either two bin vent filters with an air flow of 2,000 dscfm each or a single bin vent filter with an air flow of 4,000 dscfm. Emissions controlled with a bin vent filter IS SLC\KUC - Concentrator5thLineEmissionCalcs_rev9.xlsx PAGE 1 OF 1

40 TABLE A-7 Project: Fifth Line Expansion; Source: Diesel Fueling Notice of Intent for Copperton Concentrator Projects Annual Throughput Source Name (1,000 gal/yr) Primary Control System and Comments VOC Emissions Diesel fueling Submerged Pipe NOTES: VOC Emission Factor (lb/10 3 gal) In the absence of an applicable AP-42 emission factor, the Colorado Department of Public Health and Environment guidance on emissions from service stations was used for estimating diesel dispensing emissions. HAP Calculations HAP Concentration Emissions Toluene 0.5% Naphthalene 0.5% Total HAP emissions NOTE: HAP concentration data obtained from the MSDS for diesel. IS SLC\KUC - Concentrator5thLineEmissionCalcs_rev9.xlsx PAGE 1 OF 1

41 TABLE A-8 Project: Fifth Line Expansion; Source: Cooling Tower Notice of Intent for Copperton Concentrator Projects Emissions Water flow rate (gal/minute) 2,000 Flow of cooling water (lb/hr) 1,000,800 Calculated TDS (1) of blowdown (mg/l or ppmw) 500 Flow of dissolved solids (lb/hr) 500 Calculated Fraction of flow producing PM 10 drift (2) See Note 2 Control efficiency (3) of drift eliminators (gal drift/gal flow) PM emissions from tower (lb/hr) Calculated PM 10 emissions from tower (lb/hr) Calculated PM emissions from tower Calculated PM 10 emissions from tower Calculated PM 2.5 emissions from tower Calculated NOTES: Method from AP-42, Section (1) TDS obtained from plant data. (2) From Reisman, and Frisbie, (3) Control efficiency taken from vendor supplied data for this type of cooling tower. IS SLC\KUC - Concentrator5thLineEmissionCalcs_rev9.xlsx PAGE 1 OF 1