STATEOF ARIZONA JANICEK. BREWER
EXECUTIVEOFFICE GOVERNOR 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, onJune 12, 2013, received the Environmental Protection Agency’s (EPA) letter indicating
its intention of designating the Hayden, Arizona, areatononattainment from unclassifiable
for the 2008 lead National Ambient Air Quality Standards (NAAQS). This decision apparently

is aresult of lead standard violations for the reporting periods February- April, March-May, and April-June of 2012. The State of Arizona respectfully requeststhat the Hayden areanotbe designated nonattainment because there have been nolead standard violations since June 2012, when the ASARCO Hayden Copper Smelter completed the addition of controls toreduce lead emissions. On December 15, 2009, in accordance with the processsetoutin 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 sourceof lead emissions, was violating the newstandard. At that time,

I recommended that EPA delay designating the Hayden areabased onASARCO’s written commitment

to improve its control of lead emissions. I further recommended that the EPA promulgate

anonattainment designation for the Hayden area if, despite ASARCO’s eftbrts, the areacontinued
toviolate the NAAQS onorafter March 2010. In aNovember

8, 2011, letter informing Arizona of the EPA’s decision to designate the Hayden area unclassifiable, EPA Administrator Lisa Jackson advised usthat should EPA subsequently determine that the lead standards are being violated, EPA would initiate the processtore designate the Hayden areato nonattainment. 1700WESTWASHINGTONSTREET,PHOENIX,ARIZONA85007 602-542-4331FAx 602-542-7602Jared Blumenfeld September 25, 2013 Page
2 The Arizona Department
of Environmental Quality (ADEQ) determined that in June of 2012, ASARCO completed the installation
of a baghouse
tocontrol lead emissions from the anode furnaces
atthe smelter. Since that time there have been noviolations of the lead standard. Further, ADEQ reviewed the lead data and found that there is acorrelation of lead concentrations tosulfur dioxide (SO 2 ) concentrations

in the atmosphere

in the Hayden area.In examining this correlation of lead and SO 2 values,
it wasfound that lead and SO 2 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 aresult, based onthe maximum 3-month averagefor each calendar year,lead concentrations

atthe 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

atthe 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 areaas nonattainment
for the lead standard
atthis time, asthe additional controls have improved the air quality in the Hayden area. ADEQ will continue
tomonitor 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

tononattainment
for the lead standard would be appropriate. As recommended

in myDecember 15, 2009, letter, if EPA still determines that a nonattainment designation

is necessary,Arizona recommends that the lead nonattainment area have boundaries identical
tothe Hayden sulfur dioxide nonattainment areaboundaries. Thank youfor yourtime and consideration
of the State of Arizona’s request. Janice K. Brewer Governor Sincerely,