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Intel

Final Project Agreement -- Draft Air Permit Conditions

Maricopa County Environmental Services Department (MCESD) has made available draft air permit conditions for the Intel facility at 4500 South Dobson Road in Chandler, Arizona. The 30 day comment period for these draft air permit conditions began on Thursday, August 15, 1996, and is scheduled to end on Monday, September 16, 1996. In addition, MCESD will be holding a public hearing on the draft air permit conditions on Monday, September 16, 1996. If you would like to comment on the draft permit conditions, you have one of two options: 1. Submit written comments, with signature, to:
Jess Lotwala
Manager, Permits and Engineering
Maricopa County Environmental Services Department
2406 South 24th Street, Suite E-204
Phoenix, Arizona 85034 OR 2. Attend the public hearing on Monday, September 16, 1996. Court stenographers will be available at the hearing to take formal comments. If you have any questions regarding the draft air permit conditions, please contact Dale Lieb at (602) 506-6738.

PERMIT CONDITIONS

Intel Corporation August 14, 1996 Permit Number 96-0743

The numerical section references in this Permit are based on Maricopa County Air Pollution Control Regulations ("Rules") currently in effect as of August 14, 1996. In the event that these Rules are revised to change the numerical references during the term of this Permit, the revised numbering system will apply to this Permit.

GENERAL CONDITIONS:

1. Annual Compliance Certification:

The Permittee shall file an annual compliance certification with the Maricopa County Environmental Services Department ("MCESD"), Attention: Compliance Supervisor. The compliance certification must be filed based on the requirements set forth in Rule 220 Section 302 and Condition 14(e) of this Permit, and it must be on a form and in a manner specified by the Maricopa County Air Pollution Control Officer ("Control Officer"). The Control Officer has specified that, for this Permit, the annual compliance certification may be included as part of the annual report that the Permittee is required to submit to Maricopa County pursuant to Rule 100 Section 508 and to Section II(G) of the Final Project Agreement for the Intel Corporation Ocotillo Site ("facility") Project XL (FPA). In the event that the FPA lapses or is otherwise no longer effective, or Maricopa County no longer is a Party to the FPA, the compliance certification shall be filed on a form and in the manner specified by the Control Officer.

2. Certification: Any submissions required under this Permit, including the electronic reporting of actual emissions, shall be backed by a responsible official's certification as to truth, accuracy and completeness. This certification shall state that, based on information and belief formed after reasonable inquiry, the statements and information in the submission are true, accurate and complete.

3. Confidentiality Claims: Any claim of confidentiality associated with this Permit shall meet the requirements of Rule 100 Section 507 and Rule 200 Section 411.

4. Controls and Equipment: The Permittee shall comply with all applicable requirements of Federal air quality law, Arizona air quality law, and all applicable air quality Rules and other conditions of this Permit. In particular, the Permittee shall keep all equipment regulated under this Permit and applicable Rules in good working order through an active maintenance program. Except as provided by the applicable Rules or these Permit Conditions, the Permittee shall not operate any equipment or process unless air pollution controls required by either this Permit or the Rules are in place, are operating without bypass, and are operating within their design parameters and in accordance with any other conditions specified in this Permit. This requirement to operate any required air pollution control equipment may be temporarily waived based on the following conditions:

1. For those conditions specified in Section 500 of Rule 100 and any amendments to those conditions; or
2. For preventative maintenance of the control device, if the shutdown is allowed in the control's Operation and Maintenance Plan ("O&M") which has been approved in writing by the Control Officer; and
3. In the event that control equipment is not operated, as covered by either paragraph a or b of this Permit Condition, the Permittee shall provide additional monitoring data and, if requested, additional modeling data to MCESD in accordance with the O&M plan.

 

5. Fees: The Permittee shall pay, in a timely manner, annual fees for this Permit as determined by the Control Officer in accordance with Arizona Revised Statutes § 49-480(D) and Rule 280.

6. Fugitive Dust: The Permittee shall take all reasonable precautions to minimize the emissions of fugitive dust in accordance with Section 300 of Rule 310.

7. Malfunctions (Emergency Upsets): A malfunction that causes emissions in excess of those allowed by either the Rules or these Permit Conditions shall constitute a violation. For all situations that constitute an emergency as defined in Section 501 of Rule 100, it shall be an affirmative defense to an action brought for noncompliance if the Permittee has complied with the requirements of Section 501 of Rule 100 and any amendments to those requirements. In all other circumstances where emissions are in excess of those allowed by either the Rule or these Permit Conditions, it shall be an affirmative defense if the Permittee has complied with the requirements of Section 502 of Rule 100 and any amendments to those requirements.

8. Renewal: The Permittee shall file an application for a permit renewal at least six months, but not more than 18 months, before the expiration date of this Permit.

9. Reopening For Cause: This Permit shall be reopened prior to expiration under the conditions specified in Section 402 of Rule 200.

10. Right to Entry: The authorized representative of the Control Officer, upon presentation of proper credentials, shall be permitted to:

1. Enter upon the premises where the source is located or emissions-related activity is conducted, or in which any records are required to be kept under the terms and conditions of this Permit;
2. Have access to and copy, at reasonable times, any records required to be kept under the terms and conditions of this Permit;
3. Inspect, at reasonable times, any source, equipment (including monitoring and air pollution control equipment), practices or operations regulated or required in this Permit;
4. Sample or monitor, at reasonable times, substances or parameters for the purpose of assuring compliance with this Permit or other applicable requirements; and
5. Record any inspection by use of written, electronic, magnetic, and photographic media.

The Permittee has the right to assert a claim of confidentiality for trade secrets and commercial information that is privileged and exempt from disclosure under the Federal Freedom of Information Act, federal regulations found at 40 C.F.R. Part 2 as well as to make a showing under A.R.S. § 49-487.C.1; provided that no claim of confidentiality can limit the scope of or otherwise interfere with an on-site inspection authorized by this Permit Condition.

11. Rights and Privileges: This Permit does not convey any property rights nor exclusive privileges of any sort.

12. Severability: The provisions of this Permit are severable, and, if any provision of this Permit is held invalid, the remainder of this Permit shall not be affected thereby.

13. FPA Election: As long as the FPA is in effect and MCESD is a party thereto, the Permittee may elect to submit the information required under Permit Conditions 1 and 18 of this Permit in the form and manner prescribed in Section II(G) of the FPA. This manner of complying with the reporting requirements of the Permit has been duly approved by the Control Officer.

SPECIFIC CONDITIONS:

14. Plant Site Emission Limits:

1. The Permittee is not allowed to exceed the following Plant Site Emission Limits (PSELs):
   
   

Pollutant	12-Month Rolling Average (tons per year)
Total Volatile Organic Compounds (VOCs)	40
Oxides of Nitrogen (NOx)	49
Carbon Monoxide (CO)	49
Particulate of 10 Microns or Smaller (PM10)	5
Oxides of Sulfur (SOx)	5
Total Organic Hazardous Air Pollutants (HAPs)(1)	10(2)
Total Inorganic HAPs(1)	10(2)
Phosphine	5(3)



⁽¹⁾ The hazardous air pollutants ("HAPs") covered by this Permit are the HAPs that are listed in Section 112(b) of the federal Clean Air Act as amended. ⁽²⁾ The 10 ton per year limits for total organic HAPs and total inorganic HAPs assume that more than one HAP will be emitted from the site. If a single HAP is emitted from the site, the PSEL for such HAP shall be 9.9 tons per year. ⁽³⁾ A special limit on phosphine has been established at a level that corresponds to the current Arizona Ambient Air Quality Guidelines (AAAQG) for that chemical substance.
2. The PSELs identified in Condition 14 (a) of this Permit are below the thresholds for major sources under the Clean Air Act, as amended, and under the Maricopa County Air Pollution Control Regulations. The PSELs for VOC emissions and other criteria pollutants will remain below the thresholds for major sources under the Clean Air Act and Maricopa County Air Pollution Control Regulations even if the Maricopa County area is reclassified to serious nonattainment for ozone. This Permit Condition is issued in accordance with Rule 220 Section 305.
3. The Permittee shall not allow the property line concentration of the chemicals emitted from the facility to exceed the relevant Arizona Ambient Air Quality Guidelines (AAAQG) as compiled by the Arizona Department of Health Services. For the purposes of these Permit Conditions, the relevant AAAQGs shall be defined as the July 15, 1992 annual (if available) or 24-hour Arizona Ambient Air Quality Guidelines (AAAQGs) currently in effect for such constituents.
4. Before the Permittee introduces a new chemical which generates air emissions during the permit term for which a relevant AAAQG has been established, but which is not included in Appendix A of this Permit, the Permittee shall undertake an air quality analysis. That is, the Permittee will apply the assumption that the chemical and its byproducts will each be emitted at the rate of 10 tons per year, or at a higher rate that corresponds to the expected emissions level for the chemical. The Permittee will analyze the resulting ambient air concentrations using an EPA approved air dispersion screening model. The Permittee will then evaluate whether the relevant AAAQG would be exceeded under such circumstances. If application of the screen modeling analysis indicates a potential for exceeding the relevant AAAQG, the Permittee can use a more refined, EPA-approved analysis to evaluate the accuracy of the screen modeling. If the Permittee declines to perform this additional analysis, or if such analysis confirms the results of the screen modeling, a special emissions limit will be established for such chemical so that its emissions will not exceed the applicable AAAQG. The Permittee shall notify the MCESD of the requirement for a lower emission limit to meet the AAAQG so that the PSEL for that chemical may be added to these Permit Conditions. Any additional modeling or analysis shall be undertaken in consultation with, and with the approval of MCESD and, if requested by the MCESD, in consultation with ADEQ. Such modeling shall take into account any changes in relevant parameters that may have occurred due to activities at the facility.
5. Demonstration of compliance with the PSELs contained in this Permit shall be based on the total material used at the facility and the total actual emissions from the facility which shall be calculated in accordance with the formulas and techniques set forth in Appendix B of this Permit and emissions factors specific to this Permit which have been approved in writing by the Control Officer.
   
   

The 12-month rolling averages shall be calculated by summing the total emissions over the most recent twelve calendar months in accordance with the formulas set forth in Appendix B of this Permit. Monthly VOC emissions shall be calculated by dividing the quarterly VOC emissions by 3. As required by Condition 18 of this Permit, reports of actual emissions shall be prepared on a quarterly basis and shall be available within two months after the close of the quarter. The annual compliance certification required in Condition 1 of this Permit shall be based on a demonstration that compliance was satisfied for each of the rolling 12-month periods that was completed during the year covered by the certification.

The Permittee shall provide MCESD with access to confidential business information if the MCESD determines that the information is needed to evaluate air emissions associated with specific processes and equipment. MCESD officials agree to maintain the confidentiality of any such information provided to them provided that the confidentiality claim requirements of Condition 3 of this Permit are met. The quarterly reporting of emissions under Condition 18 of this Permit shall be accompanied by an identification of the specific emissions factors used in completing each report.

15. Control Requirements:


1. Because NOx, SOx and VOC emissions from the facility may exceed 25 tons per year, Rule 241 states that emissions of these pollutants from the facility are subject to Best Available Control Technology ("BACT") controls.
   
   

   BACT for the boilers shall be the installation, operation and maintenance of low NOx burners having overall average NOx. emissions less than or equal to 50 ppmv (parts per million by volume), with an average overall emission level of no more than 100 ppmv of CO, corrected to 3% O2 when fired by natural gas. If a reliable burner capable of meeting a lower NOx level is available at the time of a new installation, it may be used as long as the CO emission limit of this Permit Condition is met.

   BACT for VOC emissions shall be the installation, operation and maintenance of carbon concentration condensation units ("CCCUs). Such units shall achieve VOC removal efficiencies of, or equivalent to, at least 90% by volume of isopropanol gasses when the isopropanol inlet concentration is 100 ppm or higher (based on volume) and, in addition, shall remove overall VOC emissions by at least 80% by weight (capture with processing). Compliance with these efficiency requirements shall be demonstrated in accordance with the testing requirements of Condition 21 of this Permit.

   VOCs from the manufacturing operations shall be vented to the VOC control device unless the Permittee demonstrates to the satisfaction of the Control Officer that connecting the source to the control would result in dilution of the stream to the extent that overall VOC emissions would not be reduced.

   BACT for SOx shall be the use of:
   
   

   1. natural gas or liquified petroleum gas as the primary boiler fuel, and
   2. fuel oil with a sulfur content of 0.055 weight percent or less in the emergency generators and as the emergency backup fuel for the boilers.
      
      

   BACT for air emission units that are installed during the life of the Permit may evolve over time due to technological advances and thus may differ from BACT for such equipment installed at the time this Permit is issued. The Permittee, in consultation with, and with the agreement of, MCESD, and in accordance with Rule 220 Section 400, shall determine BACT for affected equipment installed during the permit term in a manner that is consistent with evolving technologies.

2. The Permittee shall install, operate and maintain scrubbers to control inorganic HAPs that are emitted from the facility. Such units shall achieve removal efficiencies of, or equivalent to, at least 90% by volume of hydrogen chloride gasses when the hydrogen chloride gas inlet concentration is 10 ppmv. Inorganic HAP emissions from the manufacturing operations shall be vented to the scrubbers unless the Permittee demonstrates to the satisfaction of the Control Officer that connecting the source to the control would result in dilution of the stream to the extent that overall HAPs emissions would not be reduced.

MCESD may waive the requirement to vent a specific piece or pieces of equipment to scrubbers or equivalent approved control devices based on a consideration of the Permittee's efforts under its Design for the Environment program and its continued compliance with applicable PSELs and other permit conditions. However, the amount of additional air pollutants emitted as a result of any control requirement waiver cannot be greater than the voluntary emission reduction demonstrated by the Permittee.

16. Preapproved Modifications: The Permittee is approved to make physical changes or changes in operations, including but not limited to, routine changes in equipment and processes as well as the addition of new operations, processes and equipment to the facility. However, no more than 10 boilers with an input rating of between 10 and 100MM BTU/hr each may be installed and any control equipment replacements will be handled in accordance with Rule 200 Section 400. Preapproved changes include, but are not limited to, changes in operations and routine changes in equipment and processes that do not create increases in emissions above the PSELs set forth herein, and more significant changes, including the addition of new operations at the facility which include semiconductor manufacturing, semiconductor test and assembly, and semiconductor mask production, so long as (i) the PSELs in Permit Condition 14 (a) are not exceeded; (ii) any new operations, processes or equipment added to the facility are covered by this Permit; and (iii) no new applicable requirements are triggered. Preapproved changes that are preapproved in accordance with this provision are identified in the Permit within the meaning of Section 302.1(g) of Rule 220. Accordingly, no additional notices or approvals are required for such changes. Facility changes that do not meet the requirements of this Permit Condition shall be processed in accordance with Rule 200 Section 400.

17. Recordkeeping: The Permittee shall maintain accurate records which shall be kept in a form that allows verification of compliance with these Permit Conditions. All records shall be maintained on-site for five years. All records required by this Permit shall be available for inspection upon request by a representative of the Control Officer. Upon request, the Permittee shall furnish to the Control Officer copies of records required to be kept by this Permit. The Permittee shall keep the following records onsite and available for inspection by MCESD:

1. A log which shall record the following types of changes: (i) any change in the application of approved control technology if more than one type of control is approved as part of this Permit; (ii) any change in fuel type; and (iii) introduction of a new chemical substance that produces air emissions and that is not listed in Appendix A of this Permit;
2. The background calculations and results of the air quality analysis required by Condition 14(d) of this Permit;
3. Monthly chemical use records for all materials used at the facility that are classified as VOCs. The Permittee also shall maintain files documenting the calculations performed to determine the 12-month rolling average for VOC emissions;
4. Monthly chemical use records for all materials which generate HAP emissions, as well as records on all calculations demonstrating how the HAP emissions for the facility were determined. Backup documentation demonstrating the technical validity of the emissions factors, including emissions test data and related calculations, also shall be available⁽¹⁾;
5. Records for boilers as specified in 40 C.F.R. Part 60 Subpart Dc and records of the sulfur content of the fuel oil used in the emergency generators if the sulfur content is not covered by the records required for the boilers;
6. Monthly records of fuel use for emergency generators and boilers;
7. Records detailing all control device operating parameters needed to demonstrate proper operation of a required control device as specified in O&M Plans required and approved by MCESD;
8. Records detailing malfunctions which cause significant unexpected air emissions, regardless of whether such events will trigger the exceedance of a PSEL.



⁽¹⁾ Some backup documentation may be generated at other locations, and may not be available onsite at all times. Such documentation shall be made available upon request.

18. Reporting: The Permittee shall keep on site quarterly emissions inventory reports. Each report shall summarize the air emissions from the facility during the previous quarter. The quarterly reporting of emissions shall be accompanied by an identification of the specific emissions factors used in completing each report. These quarterly reports shall satisfy the requirements of Sections 504, 505 and 507 of Rule 100. In the event that the FPA lapses or is otherwise no longer effective, the emissions inventory reports shall be handled in a manner specified by the Control Officer. The Permittee shall file an annual emissions report with the MCESD as required by Rule 100 Section 508. The Control Officer has specified that, for this Permit, the annual emissions report may be filed in accordance with Condition 1 of this Permit and Section II(G) of the FPA. In the event that the FPA lapses or is otherwise no longer effective, or Maricopa County no longer is a Party to the FPA, the annual emissions report shall be filed on a form and in the manner specified by the Control Officer. The Permittee shall file reports on the boilers as specified in 40 C.F.R. Part 60 Subpart Dc. The Permittee shall furnish to the Control Officer, within a reasonable time, any information that the Control Officer may request in writing to determine whether cause exists for revising or revoking and reissuing this Permit or to determine compliance with this Permit.

19. Operations and Maintenance: The Permittee shall keep all emission control equipment under this Permit in good working order through an active maintenance program established in accordance with the Operation and Maintenance (O&M) plans approved in writing by the MCESD, or, in their absence, with manufacturers' recommendations and generally accepted industry standards. The Permittee shall operate all emission control equipment and processes in accordance with these Permit Conditions, applicable approved O&M plans, and all applicable requirements of Federal laws, Arizona laws, and Maricopa County Air Pollution Control Regulations. The Permittee shall halt or reduce activities if necessary in order to maintain compliance with these Permit Conditions, all approved O&M plans, and all applicable requirements of Federal laws, Arizona laws, and Maricopa County Air Pollution Control Regulations. The Permittee shall submit an O&M plan to the MCESD for approval for each control device which is operated to meet the requirements of these Permit Conditions. Control device operating parameters shall be identified in the O&M plan for each device. O&M plans for control devices that are currently in operation or are expected to be in operation within a reasonable time frame shall identify each parameter and associated value necessary for compliance. For control devices that are not yet identified, O&M plans shall be evaluated for the requisite parameters prior to beginning operation of the control device. The Permittee shall file an O&M plan within thirty days of new emission control equipment becoming operational that is not otherwise covered by the currently approved O&M plans. O&M documents shall be maintained on-site and be available for review.

20. Production/Usage Limitations:

1. Emergency generators. Except for routine testing, emergency generators shall be used only when normal power service fails or when it must be turned off for maintenance. Emergency electrical power generators shall not be used for peak shaving or if the power interruption is due to a voluntary usage reduction by the Permittee. Each emergency generator shall be operated for no more than 500 hours during any calendar year, but must be operated for a lesser number of hours if necessary in order to comply with the PSELs contained in Permit Condition 14(a). The fuel for the emergency electrical power generators shall contain a maximum sulfur content of 0.055 weight percent.
2. Boilers. Natural gas shall be used as the fuel in all boilers except fuel oil may be used for routine readiness testing. If natural gas becomes unavailable due to circumstances beyond the control of the Permittee, fuel oil with a maximum sulfur content of 0.055 weight percent may be used in the boilers.
   
   
21. Source Testing-Startup Testing: The Permittee shall conduct emissions testing on the equipment listed below within 60 days after the equipment has achieved the capability to operate at its maximum production rate on a sustained basis. This time frame may be extended by the Control Officer for good cause, but in no case shall the testing period extend for more than 180 days after the initial startup of the equipment. The testing shall be conducted in accordance with Rule 270 and USEPA approved test procedures or other testing procedures if written approval is given in advance of the testing by the MCESD. The Permittee shall submit an approvable test protocol to the MCESD, Attn.: Compliance Testing Manager, for review and approval at least 30 days prior to the emissions test. A fee for each stack to be tested, as required by Rule 280, shall be submitted with the test protocol. The Permittee shall notify MCESD at least two weeks in advance of the actual time and date of the emissions test so that MCESD may have a representative attend. The Permittee shall submit a written report on the emissions testing within 30 days after completion of each test. The report shall include a summary of the results from the testing in sufficient detail to allow a compliance determination to be made.


1. VOC Emissions Control Systems: The Permittee shall test each unit for the mass emission rate for VOCs as well as for VOC removal efficiency. MCESD may accept one or more tests as being representative for other substantially similar VOC emissions control units. The Permittee may, with advance written approval of the MCESD, use a surrogate material in the gas stream if the Permittee can demonstrate to the satisfaction of the MCESD that the measured removal efficiency demonstrated for the surrogate is equivalent to the removal efficiency required by Permit Condition 15.
2. Emergency Generator Emissions: If the Permittee decides not to use the worst case of either the manufacturer's emission data or AP-42 emission factors, then the Permittee shall test each emergency generator for mass emission rates for NOx, carbon monoxide and PM10. MCESD may accept one or more tests as being representative for other substantially similar generators.
3. Boilers: The Permittee shall test each boiler for NOx and carbon monoxide emission rates. MCESD may accept one or more tests as being representative for other substantially similar boilers.
4. Scrubbers: The Permittee shall test each scrubber in a manner that ensures accurate, reliable and representative scrubber measurements for hydrogen chloride removal efficiency. MCESD may accept one or more tests as being representative for the other substantially similar scrubbers. If the hydrogen chloride inlet concentration to the scrubber is at a low level (<10ppmv), the Permittee may, with written approval from the MCESD:
   
   
   1. Use a surrogate material in the gas stream if the Permittee can demonstrate to the satisfaction of the MCESD that the measured removal efficiency demonstrated for the surrogate is equivalent to the removal efficiency required by Permit Condition 15, or
   2. Demonstrate to the satisfaction of the MCESD that the measured removal efficiency demonstrated for the low inlet level of hydrogen chloride is equivalent to the removal efficiency required by Permit Condition 15, or
   3. Use an alternative method to demonstrate the removal efficiency required by Permit Condition 15
      
      
5. If the Permittee installs a new piece of air pollution control equipment which MCESD believes is not adequately represented by previous performance tests, MCESD may require emissions testing to be performed on the new equipment.
APPENDIX A In order to provide additional assurance that the PSELs for HAPs that are contained in Condition 14(a) of this Permit do not pose risks to the community, the Permittee, MCESD, EPA and the Arizona Department of Environmental Quality (ADEQ) have analyzed potential property line concentrations for the chemicals identified in this Appendix, based on the application of EPA's SCREEN3 Model, as measured against the July 15, 1992 annual (if available) or 24-hour Arizona Ambient Air Quality Guidelines (AAAQGs) currently in effect for such constituents. The analysis has assumed that each constituent was emitted at 10 tons per year. The analysis has demonstrated that the AAAQGs are not exceeded for the constituents listed in this Appendix, with the exception of phosphine which is an inorganic HAP. Accordingly, rather than the PSEL of 10 tons per year for other inorganic HAPs, a more restrictive PSEL of 5 tons per year applies to emissions of phosphine. This separate PSEL has been established at a level that corresponds to the current AAAQG for phosphine, thus ensuring that phosphine's AAAQG will not be exceeded. In addition to HAPs, this air quality evaluation has been completed for a number of additional chemicals identified in this Appendix. In addition, Condition number 14(d) of this Permit requires that a similar analysis be performed in the future before any new chemical that has a relevant AAAQG is emitted from the facility.

HAPs - INORGANIC Chlorine
Phosphine
Hydrochloric Acid
Hydrofluoric Acid

HAPs - ORGANIC Xylene (OM&P)
Ethylene Glycol
Methanol
NON-HAPs
Acetone
n-Butyl Acetate
Isopropyl Alcohol
Ammonia
Sulfuric Acid
Phosphoric Acid
Boron Trifluoride
Nitric Acid
Acetic Acid
n-Methyl Pyrilidone
Hexamethyldisiloxane
Ethyl Lactate
Polyamic Acid
Propylene Glycol
Potassium Hydroxide
Tetramethyl Ammonium Hydroxide
Ammonium Hydroxide
Hydrogen Peroxide
Tetraethyloethosilicate
Trimethyl Borate
Boron Trichloride
Hydrogen Bromide
Dichlorosilane
Sodium Hydroxide
Tungsten Hexafluoride
Silicon Hexafluoride APPENDIX B

1. NOx, CO, SOx, PM10 The 12-month rolling annual average for CO, NOx, PM10 and SOx emissions for the Ocotillo Site shall be the sum of the emissions calculated monthly for each emissions unit in accordance with the following formulas:

Emissions = (Q) x (EF) where: Q = fuel consumption EF = emission factor for each emissions unit

Initially, emissions calculations for the facility shall be based on EPA's AP-42 emissions factors to determine combustion emissions from boilers. For emergency generators, the Permittee shall use the worst case of either the emissions factors supplied by the generator manufacturer, or applicable AP-42 emission factors. Alternate emissions factors which are based on emissions testing of the specific units at the facility also may be if approved in writing by the MCESD and, if requested by the MCESD, in consultation with ADEQ. 2. VOCs The 12-month rolling annual average for VOC emissions from the facility shall be calculated quarterly by using a mass balance technique: The Permittee shall assume that all volatile organic compounds consumed at the Site during the quarter are emitted to the air, less volatile organic compounds contained within the compounds removed from the facility.

VOC emissions shall be calculated on a Plant Site basis as follows: (Mass of VOCs⁽²⁾ consumed⁽³⁾) - (Mass of spent VOCs collected, less water and nonprecursor organic compounds⁽⁴⁾) = Mass of VOCs emitted to atmosphere⁽⁵⁾.

⁽²⁾ VOC as defined by Maricopa County Rule 100.
⁽³⁾ Consumed shall mean chemicals used on the Site.
⁽⁴⁾ Some spent VOCs are collected in tanks which also can contain some percentage of water and nonprecursor organic compounds. The water and nonprecursor organic compounds content shall be assessed using test methods and procedures approved in writing by the MCESD. This mass of water and nonprecursor organic compounds will then be subtracted from the total spent material mass in order to account for only that portion which is a VOC.
⁽⁵⁾ The "mass of VOC consumed" is a monthly calculation, whereas the "mass of spent VOCs collected" and the "mass of VOCs emitted" are quarterly claculations. VOCs from combustion sources shall be calculated with the same method explained above for calculating NOx , CO, etc. (i.e., (Q) x (EF)). EPA's AP-42 emission factors, or data supplied by the equipment manufacturer, shall be used to estimate VOC emissions from fossil fuel combustion. This number will then be added to the VOC mass balance number to determine total Site VOCs. Alternate emissions factors which are based on emissions testing of the specific units at the facility also may be used if approved in writing by the MCESD and, if requested by the MCESD, in consultation with ADEQ. 3. HAPs The 12 month rolling annual average HAPs emissions shall be calculated monthly via the following methods.

There are three primary sources of HAPs emissions from the facility:

1. Liquid acid baths
2. Fluorinated and chlorinated process gases
3. Liquid organic process chemicals
   
   

1. Liquid Acid Baths Emissions from the liquid acid baths shall be calculated monthly using the standard evaporation rate equation recognized by EPA for use in compliance with Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA), Section 112(r) of the Clean Air Act and other applications. This equation is: (W-MKAp°)/RT where:
   W = evaporation rate M = molecular weight
   
   A = surface area p° = vapor pressure
   
   R = ideal gas constant T = temperature
   
   K = mass transfer coefficient, dependent upon air flow
   
   Net acid bath emission will be equal to (W) x (1-scrubber efficiency)
   
   
2. Fluorinated and Chlorinated Process Gases Fluorinated and chlorinated process gases may generate byproduct emissions of HF, HCl and Cl₂. The 12 month rolling average for emissions of these materials shall be calculated monthly as follows: HAP_i = Sum of [(Q_j)(EF_ji)] x (1-scrubber efficiency) where: HAP_i = mass of emissions of HAP_i Q_j = mass of chemical j consumed which contributes to formation of HAP_i EF_ji = emissions factor reflecting the portion of chemical j which is emitted as HAPi The HAPs emissions factors have been developed by the Permittee through analytical testing of process tools. The emission factor for a given chemical to generate a given HAP incorporates the overall result of testing and analysis for all the places within the manufacturing process that the chemical is used. For example, if an HF producing chemical is used in three places in the process, the overall emission factor will be the ratio of the mass of HF emissions created to the mass of the chemical used in all three of those steps combined. In this way, the total amount of the chemical used throughout the process can be converted to the HAPs emissions generated by that chemical. These emissions factors can change if the manufacturing process changes. The Permittee will update these factors and calculation frequency as needed and will review changes to the emission factors and calculation frequency with MCESD. Changes shall first be approved in writing by the MCESD.
   
   
3. Organic HAPs The Permittee shall develop emissions estimates for individual organic HAPs through mass balance (case 1) and/or the development of individual emission factors (case 2). The net organic HAP emissions will be equal to (organic HAP process emissions) x (1-control device efficiency). The 12 month rolling average for emissions of these materials shall be calculated quarterly as follows for Case 1:

   Case 1: (Mass of VOCs consumed) - (Mass of spent VOCs collected, less water) = Mass of VOCs emitted to atmosphere

   The 12 month rolling average for emissions of these materials shall be calculated monthly as follows for Case 2:

   Case 2:

   HAP_o = Sum of [(Q_o)(EF_o)] x (1-control efficiency) where: HAP_o = mass of emissions of HAP_o Q_o = mass of chemical i consumed which contributes to formation of HAP_o EF_o = emissions factor reflecting the portion of chemical _o which is emitted as HAP _o

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