September 25, 2013

Jared Blumenfeld

U.S. Environmental Protection Agency, Region IX

Mail Code: ORA-1

75 Hawthorne Street

San Francisco, CA 94105

RE: EPA’s Recommendation to Re-designate Hayden, Arizona for the National Lead Standard

Dear Mr. Blumenfeld:

The State of Arizona, on June 12, 2013, received the Environmental Protection Agency’s (EPA) letter indicating its intention of designating the Hayden, Arizona, area to nonattainment from

unclassifiable for the 2008 lead National Ambient Air Quality Standards (NAAQS). This decision apparently is a result of lead standard violations for the reporting periods February- April, March-May, and April-June of 2012.

The State of Arizona respectfully requests that the Hayden area not be designated nonattainment because there have been no lead standard violations since June 2012, when the ASARCO

Hayden Copper Smelter completed the addition of controls to reduce lead emissions.

On December 15, 2009, in accordance with the process set out in the Clean Air Act (CAA) section 107(d)(1), Arizona submitted its recommended designations for the revised standard to the EPA. At that time, preliminary lead monitoring data indicated that the Hayden area, within which the ASARCO Hayden Copper Smelter is the single significant source of lead emissions,

was violating the new standard. At that time, I recommended that EPA delay designating the Hayden area based on ASARCO’s written commitment to improve its control of lead emissions. I further recommended that the EPA promulgate a nonattainment designation for the Hayden

area if, despite ASARCO’s eftbrts, the area continued to violate the NAAQS on or after March 2010.

In a November 8, 2011, letter informing Arizona of the EPA’s decision to designate the Hayden

area unclassifiable, EPA Administrator Lisa Jackson advised us that should EPA subsequently determine that the lead standards are being violated, EPA would initiate the process to re designate the Hayden area to nonattainment.

1700 WEST WASHINGTON STREET, PHOENIX, ARIZONA 85007

602-542-4331 FAx 602-542-7602
correlation of lead and SO2values, it was found that lead and SO2 monitored values drifted apart after the control project was completed. According to ASARCO, the control project has reduced lead emissions by approximately 2 tons per year. As a result, based on the maximum 3-month

average for each calendar year, lead concentrations at the ADEQ Globe Highway monitoring site have decreased by approximately 56% between 2011 and 2013. Since the installation of the

anode furnace controls, ambient lead concentrations at the monitoring site have decreased by approximately 40%. ADEQ will provide EPA the technical information supporting this data.

The State of Arizona respectfully requests that EPA not designate the Hayden area as nonattainment for the lead standard at this time, as the additional controls have improved the air quality in the Hayden area. ADEQ will continue to monitor lead concentrations in the vicinity of the ASARCO Hayden Smelting Facility. If additional violations of the lead standard occur, the State of Arizona acknowledges that a designation to nonattainment for the lead standard would

be appropriate. As recommended in my December 15, 2009, letter, if EPA still determines that a

nonattainment designation is necessary, Arizona recommends that the lead nonattainment area

have boundaries identical to the Hayden sulfur dioxide nonattainment area boundaries.

Thank you for your time and consideration of the State of Arizona’s request.

Janice K. Brewer

Governor

Sincerely,