www.fcx.com

Freeport-McMoRan Miami, In

Presentation to EPA Region 9 on Haz

April 29, 2014
Introduction

 EPA’s proposed FIP for FMMI is technically infe FMMI’s existing controls constitute BART FMMI’s SO2 compliance plan as presented in it

Significant Permit Revision is Better-than-BART

 FMMI has gone to great lengths to determine f

emissions from individual operations in lieu of sulfur balance methodology in the Arizona SO2 

 EPA should adopt an approach consistent with 

proposed controls for purposes of the forthcomrevised SO2 SIP
Location of FMMI
From: Performance Evaluation Guide for Large EPA-340/1-84/012, page 125

• Unlike Peirce-Smith converters, which 

draft out of the mouth, Hoboken converters use a side draft flue to capture process gas 

• In Subpart QQQ, EPA recognized the 

impracticality of installing secondary hooding at Miami

Peirce-Smith vs. Hoboken Converters
Secondary Capture System Not Feas

 Unlike facilities where the converters are aligne

parallel to the aisle, the Hoboken’s at FMMI weinstalled at a 30 degree angle to the aisle due building constraints

 A secondary capture system, such as used on 

Smith hooding, places the hoods in the active aisle where ladles would strike the hooding anrelated support structures

 The physical constraints of the converter aisle 

preclude the ability to utilize Peirce-Smith hood
Converter Alignment at FMMI
Mouth Cover for Hoboken

The converter m

were approved June 28, 2013 pPermit Revision 
The Working Mouth Cover

Based on direct measurements from the roofline, baseline SO

2

emissions from the converter aisle roofline are 109 tpy
FMMI’s Proposed Roofline Capture Sy
Treating Fugitive SO2 from the Convert

at the Acid Plant is Infeasible

 Acid Plant designed fo

SO

2 at 135,000 scfm (

 Combined gas stream 

1,350,000 scfm at 1.1

 Acid Plants typically tr

strengths above 7%

 Treatment of high vol

concentration gasses acid plant is infeasible

 High volume/ low con

gasses warrant scrubb

155,700 lb./hr 

@ 135,000 

scfm

130 lb./hr @ 

1,200,000 

SCFM

Comparative Flow Rates

(scfm)
FMMI’s Proposed Aisle Scrubber
EPA’s TSD Overestimates Baseline SO2 Em

 Mass Balance approach initially established in 19

part of current AZ SO2 SIP and is included in FM

Title V permit

 Mass balance methodology provides highly varia

results

- Fugitive emissions are calculated as sulfur inp

minus sulfur output 

- Results are imprecise due to variances in larg

volumes and representative sampling

- Totals can swing by 7.5 tons of sulfur per 500 

concentrate processed

 Fugitive emissions are source specific, not facility 

as reported from the mass balance.
Roofline SO2 Emissions
FMMI’s Planned SO2 Controls are Better-tha

 Planned SO2 Control Upgrades include: - Roofline Capture System and Aisle Scrubber

- Cost effectiveness: $276,300/ton - SO2 emission reductions 56.2 tpy - Upgrading both existing scrubbers to causti

- Continuous operation of tail stack scrubber - Installation of mouth covers on converters 2
Better-than-BART Options

 Existing controls constitute BART for SO

2

 Three most cost effective options:
EPA’s TSD Relies on Inapplicable Cost D

 Using ASARCO data, EPA assumes a capita

$47,850,000

 Cost data provided by FMMI indicates that 

costs for roofline capture system and aisle are $102,845,000
Thank You for Your Time and Considerati

Questions and/or Comments