October 1,2007 

BY U.S. MAIL & ELECTRONIC MAIL 

CERTIFIED MAIL NUMBER: 7005 1820 0000 3674 5613 

RETURN RECEIPT REQUESTED 

Ms. Nancy C. Wrona, Director 

Air Quality Division 

Arizona Department of Environmental Quality 

11 10 West Washington Street 

Phoenix, AZ 85007 

Re: ASARCO LLC Hayden Smelter-Potentially Subject to Best Available Retrofit 

Technology (BART) Determination 

Dear Ms. Wrona: 

ASARCO LLC (Asarco) received your July 13,2007 letter based on the results of 

the CALPUFF modeling performed by the Regional Modeling Center (RMC) for the 

Arizona Department of Environmental Quality (ADEQ). Based on the results of RMC 

modeling, Best Available Retrofit Technology (BART) determinations will be required 

for certain emission units at Asarco's Hayden smelter. Asarco notes, however, that these 

units already have BART-equivalent controls and that additional controls are not 

necessary. 

A. Emission Units Potentially-Subject- to- BART 

Based on the results of RMC modeling, ADEQ has determined that the following 

emissions units at the Hayden smelter are potentially-subject-to-BART: 

-,, 1 Anode Furnace 1-3 I SO2,, PM 

Table 1: Potentially-Subject-to-BART Emission Unit(s) 

In addition the June 9, 2006 ADEQ letter from Ms. Wrona to Mr. Tom Moore states 

that converters 1-5 and anode furnaces 1-3 at Asarco's Hayden smelter are BARTeligible units for at least one pollutant that can potentially cause visibility impairment 

in a Class I area. 

Emission Unit(s) 

Converters 1-5 

100 HAYDEN AVENUE . P.O. BOX 8. HAYDEN, ARIZONA 85235 TEL 520 356 781 1 

Potentially-Subject-to-BART 

So,. PM 
In Section 1.0 of Attachment 3, ADEQ identifies potentially BART-eligible 

emissions units for various source categories using a three-step process. The results 

for the Primary Copper Smelters are presented in Section 5.3. The data for the 

Hayden smelter are presented in Section 5.3.1. There are inaccuracies in the data that 

we wish to correct as follows: 

Source of information: ASARCO LLC records 

Step 1: Are Emission Units Part of a Categorical Source? 

Yes. Fluid Bed Dryers (2), INCO Oxygen Flash Furnace (1) 

Converters (5), Anode Furnaces 0-2, Acid Plant (1) 

(A.A.C. R-18-2-406(2) (g) and 1601(2) (h)) 

No: NIA 

Step 2: Are Emission Units in Step 1 Date Eligible? 

Fluid Bed Dryers (2): Constructed 1983- No 

INCO Oxygen Flash Furnace (1): Constructed 1983-No 

Converters: Three-converter operation prior to 1962. One converter was 

enlarged in 1965 from 13 x 32 to 13 x 35 feet, converters #I and #4 were 

added in 1968 - "two or three of five are date eligible" 

Anode Furnaces #1 and #2: Constructed 1972 - Yes. 

Anode Furnace #0: Constructed 200 1 - No 

Acid Plant (1): Constructed 1983 - No 

Step 3: C Potential to Emit > 250 TPY of Visibility Impairing Pollutants? 

2004 Actual Emissions Inventory Information 

Yes for SO,. 

Smelter 

Total for BART 

Eligible Emission 

Notes: Acid Plant may be considered control device for SOz. If so, part eligibility 

may be impacted by installation of this control. 

PMlo (~PY) 

157.3 

Unit 

Total Hayden 

2 1.4 (2 converters) 

23.3 (3 converters) 

NOx (tpy) 

47.4 

SO, (tpy) ' 

19394.9 

6903 (2 converters) 

10337 (3 converters) 

6 1.1 (2 converters) 

70.0 (3 converters) 
The RMC modeling was done with NO,, PM and SO2 emissions from the entire 

smelter. The results (Table 1 of the July 13, 2007 letter) indicate that the Hayden 

smelter would be BART- eligible for the five converters and three anode firnaces at 

Hayden. For PM, the modeling shows an average visibility impact of 0.53 deciviews 

(dV) for the Galiuro Wilderness. The PM emissions associated with the BARTeligible emissions units are 61.1 tpy (2 converters) and 70.0 tpy, compared to 157.3 

for the entire smelter. If emissions from the BART-eligible units alone are modeled 

the visibility impact would be below the 0.5 dV threshold. Therefore, BART 

determination is necessary only for SO2. 

B. BART for SO2 Emissions from Relevant Emission Units at Hayden Smelter 

During the deliberations of the Market Trading forum of the Western Regional Air 

Partnership (WRAP), all parties involved including ADEQ and the U.S. 

Environmental Protection Agency (EPA), agreed that the controls and emissions 

limitation for primary copper smelters already met BART for SO2, This was reflected 

in the milestones included in the State Implementation Plan (SIP) that ADEQ 

submitted to EPA under 40 CFR 51.309 (Section 309 SIP). The milestones being 

proposed for inclusion in the model 308 SIP currently being developed by the WRAP 

include an allowance of 26,000 tons of SO2 for the Hayden smelter and are based on 

the fact that the smelter is at or beyond the BART requirements. 

Asarco believes that BART controls for SO2 are already in place at Asarco's 

Hayden smelter and no additional controls are necessary. Asarco looks forward to 

working with ADEQ to confirm this conclusion. If you have any questions please call 

Jack Garrity at 520-356-3284. 

Sincerely, 

John Shaw 

General Manager 

Hayden Operations & Adrnin. 

cc: Mr. Eric Massey, Manager Air Quality Compliance Section, ADEQ