From: Colleen McKaughan/R9/USEPA/US

To: jgarrity@asarco.com, George Tsiolis <gtsiolis@nj.rr.com>, 

Cc: ecm@azdeq.gov

Date: 01/10/2013 05:21 PM

Subject: Information Request for Pending BART Determination

Jack and George,

I wanted to give you a heads up that EPA will be requesting information to assist us in our BART 

determinations. We are asking for quite a bit of information in a short amount of time so I wanted to send 

you a copy of the letter via email. We will send a hard copy to Jack, unless there is another contact that is 

more appropriate. The tight time frame is being driven by our consent decree deadline of March 8, 2013, 

when we have to propose a FIP.

Please call me at the number below if you have questions. And thank you for your assistance in advance.

(See attached file: ASARCO Letter 2013-01-10.final.docx)

Colleen W. McKaughan

Associate Director, Air Division

USEPA, Region 9

(520) 498-0118
January 10, 2013 

Jack Garrity 

ASARCO Incorporated 

P.O. Box 8 

Hayden, AZ 85235 

Dear Mr. Garrity: 

On December 21, 2012, the Environmental Protection Agency, Region 9 (EPA) proposed 

to approve in part and disapprove in part a revision of Arizona’s State Implementation Plan (SIP) 

to implement the regional haze program for the first planning period through 2018. (77 FR 

75703). We are subject to a court-ordered deadline of March 8, 2013 to sign a notice of proposed 

rulemaking that includes proposed BART determinations for SO2 and PM10 at the Hayden 

Smelter. We are very interested in having your input before we make those decisions. 

In its Regional Haze SIP, the Arizona Department of Environmental Quality (ADEQ) 

identified the primary copper smelter in complex in Hayden, Arizona (the Hayden Smelter or the 

Facility) operated by ASARCO LLC (ASARCO) as subject to Best Available Retrofit 

Technology (BART) for sulfur dioxide (SO2), but not for nitrogen oxides (NOx) or coarse 

particulate matter (PM10). The Regional Haze SIP also included ADEQ’s BART determination 

for SO2 at the Hayden Smelter. We proposed to approve ADEQ’s determination that the Hayden 

Smelter is not subject to BART for NOx, but proposed to disapprove ADEQ’s determination that 

the Hayden Smelter is not subject to BART for PM10. In addition, we also proposed to 

disapprove ADEQ’s SO2 BART determination for the Hayden Smelter, or, in the alternative, to 

approve the BART determination, if ADEQ could substantiate its BART determination. 

As explained in our December 21, 2012 notice of proposed rulemaking, we are required 

to propose a Federal Implementation Plan (FIP) for those elements of ADEQ’s SIP that we have 

proposed to disapprove. For the Hayden Smelter, this consists of the BART determinations for 

SO2 and PM10. In order to ensure that our BART determinations are supported by sound 

technical analyses, we request the following information outlined below. 

Information Needed to Make a BART Determination for SO2:

1. The average daily measurement for the SO2 continuous emission monitoring system 

(CEMS) for the sulfuric acid plant at the Facility since January 1, 2005 in parts per 

million (ppm) and the total tons of SO2 per day recorded by the SO2 CEMS for the 

sulfuric acid plant since January 1, 2005. Please provide this information in an electronic 

format that may be edited by a spreadsheet program such as Excel or comparable 

software. Please also provide all SO2 stack test data and relative accuracy test audits 
(RATAs) performed for the sulfuric acid plant for the period from January 2005 through 

December 2012. 

2. The daily production of sulfuric acid by the sulfuric acid plant since January 2005 in tons. 

Describe the source of the data. 

3. The daily production of copper by the copper smelter since January 2005 in tons. 

Describe the source of the data.

4. The quantity of concentrated ore processed by the smelter each calendar month since 

January 2005 in tons, along with the average daily percentage of sulfur of the 

concentrate. Describe the source of the data. 

5. Monthly material balances of sulfur (as described in Specific Provision III.C.1 and 

Attachment D of Title V Operating Permit 1000042) performed since January 2005, 

along with any support documents for each monthly balance. 

 

6. Copies of all actual SO2 emissions calculations performed since January 1, 2005 for any 

copper smelting equipment that was submitted to any regulatory agency. Include with 

your response a detailed description of all equations relied upon, including the 

identification of all data inputs into the equation, a description of all emissions factors 

(EFs) relied upon and their source, and all other methods or data relied upon to perform 

the calculations; 

7. A summary and supporting documentation showing which units at the Facility comprise 

the BART-eligible source under the Regional Haze Rule (40 CFR part 51, subpart P) and 

the BART Guidelines (40 CFR part 51, appendix Y). Include any records that indicate 

which units at the Facility were “in existence” on August 7, 1977 and which units were 

“in operation” before August 7, 1962, as defined under the Regional Haze Rule and the 

BART Guidelines. 

8. Provide the following information about the sulfuric acid plant: 

a. the volume (liters) of catalyst in each catalyst bed; 

b. The diameter of the converter; 

c. the type of catalyst (including trade-name) in each catalyst bed; 

d. the maximum volumetric capacity (liters) of catalyst; 

e. the amount and type of catalyst replaced during each turn around since 2005; and 

f. if ASARCO is using cesium promoted catalyst, provide the date the facility began 

using cesium catalyst. 

9. Provide all vendor quotes for cesium promoted catalyst installation that the facility has 

received. Include any emission estimates provided by the vendors. 

10. Provide the following information about process gas capture and treatment: 
Page 3 of 4 

a. Indicate the maximum capacity of the acid plant to accept process off gases, 

including both airflow and inlet SO2 concentration; 

b. Provide a detailed description of what happens to captured excess gas flow that 

would otherwise be vented to the acid plant when that total gas flow exceeds the 

capacity of the acid plant; 

c. Provide a detailed analysis of the capture efficiency of gases emitted from all 

copper smelter process equipment; 

d. Provide a schematic diagram showing which equipment at the Facility are 

captured and controlled or controllable by the acid plant; 

e. Provide the following information about SO2 emissions from the Pierce-Smith 

Converters Secondary System: 

i. Any and all data, in native format, on measurements or calculations of SO2

concentration in ppm of gas exiting the Secondary System on an hourly

basis (or as frequent as measurements or calculations are/have been 

taken/performed) since January 1, 2005; 

ii. The total daily emissions of SO2 in tons from the Secondary System since 

January 1, 2005; 

iii. The total daily amount of lime in tons injected into the Secondary System; 

iv. An estimation, on a daily basis, of the control efficiency of the injected 

lime for SO2; 

v. For information provided under 8.c.i and 8.c.iv, a description of the 

underlying measurement and/or data used and any calculations performed. 

f. For the emergency bypass vent that is part of the acid plant line, please respond to 

the following requests: 

i. Describe the location of the bypass in regard to any particulate matter 

(PM) controls (i.e. is it before or after each PM control); 

ii. Describe what happens to process off-gases vented through the bypass (i.e. 

are they emitted directly to the atmosphere or controlled); 

iii. Describe how the gas flow exiting the bypass is measured; 

iv. In a chart format, since January 1, 2005, specify the total amount of gas 

vented through the bypass on a daily basis. Describe the source of the 

data. 

g. Provide a detailed description of SO2-laden gas flow emitted from all copper 

smelter process equipment at the Facility (e.g. maximum and typical flow rates in 

actual cubic feet per minute (acfm), temperature, and SO2 concentration in ppm), 

and whether it is currently vented to the acid plant, to other controls in place, or to 

the atmosphere uncontrolled. 

Information Needed to Make a BART Determination for PM10: 
Page 4 of 4 

1. A description of existing PM control for all copper smelter process equipment at the 

Facility. 

2. The average PM and PM10 emissions from any copper smelter process equipment at the 

Facility since January 2005 calculated in tons per calendar month and the assumptions 

and emission factors relied upon to perform the calculations. Please provide all PM and 

PM10 stack tests performed on any of this equipment. 

3. A description of opacity monitors and other equipment and practices used to directly or 

indirectly measure PM or PM10 emissions from this equipment. 

4. A summary of all Method 9 opacity measurements taken at any part of smelter since 

January 2005, including a description of the location of the Method 9 reading, the results 

of the reading, and the name and affiliation of the individual who took the reading. 

Where possible, please provide data in an electronic format such as Excel or Word, and 

not in an image format. If responding via a disk (CD or DVD format) please include electronic 

data with any written responses and a cover letter to the following address: 

Thomas Webb 

U.S. EPA, Region IX 

Planning Office, Air Division 

75 Hawthorne Street (AIR-2) 

San Francisco, CA 94105 

As mentioned above, we are subject to a court-ordered deadline of March 8, 2013 to sign 

a notice of proposed rulemaking that includes proposed BART determinations for SO2 and PM10

at the Hayden Smelter. In order for your responses to be included in our analysis, please respond 

to EPA by January 25, 2013. If you need more time to process specific items included in this 

request, please contact me at (520) 498-0118 so my staff can arrange a discussion with you and 

assist you in prioritizing the requested data. 

Sincerely, 

Colleen McKaughan, 

Associate Director 

cc: Eric Massey, ADEQ