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# Freeport-McMoRan Miami, Inc. Presentation to EPA Region 9 on Haze FIP

April 29, 2014

# Introduction2EPA’s proposed FIP for FMMI is technically infeasibleFMMI’s existing controls constitute BARTFMMI’s SO2compliance plan as presented in itsSignificant Permit Revision is Better-than-BARTFMMI has gone to great lengths to determine fugitiveemissions from individual operations in lieu of thesulfur balance methodology in the Arizona SO2SIPEPA should adopt an approach consistent with FMMI’sproposed controls for purposes of the forthcomingrevised SO2SIP

# Location of FMMI34From: Performance Evaluation Guide for Large FlowVentilation SystemsEPA-340/1-84/012, page 125• Unlike Peirce-Smith converters, whichdraft out of the mouth, Hobokenconverters use a side draft flue tocapture process gas• In Subpart QQQ, EPA recognized theimpracticality of installing secondaryhooding at Miami 

# Peirce-Smith vs. Hoboken Converters

# Secondary Capture System Not Feasible5Unlike facilities where the converters are alignedparallel to the aisle, the Hoboken’s at FMMI wereinstalled at a 30 degree angle to the aisle due tobuilding constraintsA secondary capture system, such as used on PeirceSmith hooding, places the hoods in the active craneaisle where ladles would strike the hooding andrelated support structuresThe physical constraints of the converter aislepreclude the ability to utilize Peirce-Smith hooding

# Converter Alignment at FMMI6

# Mouth Cover for Hoboken7The converter mouth coverswere approved by ADEQ onJune 28, 2013 per MinorPermit Revision No. 57738

# The Working Mouth CoverBased on direct measurementsfrom the roofline, baseline SO2emissions from the converter aisleroofline are 109 tpy9 

# FMMI’s Proposed Roofline Capture System

# Treating Fugitive SO

2 

# from the Converter Aisle at the Acid Plant is InfeasibleAcid Plant designed for 11.5%SO2at 135,000 scfm (nominal)Combined gas stream is1,350,000 scfm at 1.1% SO2Acid Plants typically treat gasstrengths above 7%Treatment of high volume, lowconcentration gasses with anacid plant is infeasibleHigh volume/ low concentrationgasses warrant scrubbing10155,700 lb./hr@ 135,000scfm130 lb./hr @1,200,000SCFMComparative Flow Rates(scfm)11 

# FMMI’s Proposed Aisle Scrubber

# EPA’s TSD Overestimates Baseline SO

2 

# EmissionsMass Balance approach initially established in 1983 aspart of current AZ SO2 SIP and is included in FMMI’sTitle V permitMass balance methodology provides highly variableresults-Fugitive emissions are calculated as sulfur inputminus sulfur output-Results are imprecise due to variances in largevolumes and representative sampling-Totals can swing by 7.5 tons of sulfur per 500 tons ofconcentrate processedFugitive emissions are source specific, not facility wideas reported from the mass balance.

# Roofline SO

2 

# Emissions13

# FMMI’s Planned SO

2 

# Controls are Better-than-BARTPlanned SO2Control Upgrades include:-Roofline Capture System and Aisle Scrubber:-Cost effectiveness: $276,300/ton-SO2emission reductions 56.2 tpy-Upgrading both existing scrubbers to caustic-Continuous operation of tail stack scrubber-Installation of mouth covers on converters 2-5

# Better-than-BART Options15Existing controls constitute BART for SO2Three most cost effective options:

# EPA’s TSD Relies on Inapplicable Cost DataUsing ASARCO data, EPA assumes a capital cost of$47,850,000Cost data provided by FMMI indicates that capitalcosts for roofline capture system and aisle scrubberare $102,845,00017Thank You for Your Time and Consideration!Questions and/or Comments