From: Balaji Vaidyanathan

To: Steve M. Calderon; Bruce J. Friedl

Subject: FW: Asarco Hayden BART submittal

Date: Thursday, March 28, 2013 1:49:18 PM

Attachments: Asarco Hayden BART submittal 2013-03-20.pdf

From: Eric Hiser [mailto:EHiser@jordenbischoff.com] 

Sent: Wednesday, March 20, 2013 11:08 AM

To: Balaji Vaidyanathan

Cc: Eric C. Massey; Jack Garrity (jgarrity@asarco.com)

Subject: Asarco Hayden BART submittal

Balaji:

 Attached is ASARCO LLC's Best Available Retrofit Technology demonstration for the Hayden Smelter.

Please review and call with any questions or concerns.

Thanks,

Eric Hiser
From: Balaji Vaidyanathan

To: Steve M. Calderon; Bruce J. Friedl

Subject: FW: BART/RP SIP language

Date: Thursday, March 28, 2013 1:48:41 PM

Attachments: 2013-3-06a - PCC Comments on Proposed SIP Disapproval - Arizona.pdf

2013-3-06b - Electronic Data Files That Go With Attachment 3 of PCC Comments.xlsx

From: Lindsay, Brett [mailto:BLindsay@srmaterials.com] 

Sent: Thursday, March 21, 2013 8:54 PM

To: Balaji Vaidyanathan

Subject: RE: BART/RP SIP language

Sorry for the delay.....I was away from my computer. Here are the files that were submitted to EPA

on the disapproval.

Thanks,

Brett Lindsay

Environmental Manager

Salt River Materials Group /

Phoenix Cement Company and

Salt River Sand & Rock

Office: (928) 634-2261 Ext. 8062

Direct: (928) 639-8062

Mobile: (928) 593-0209

Fax: (928) 634-3543

From: Balaji Vaidyanathan [mailto:Vaidyanathan.Balaji@azdeq.gov] 

Sent: Thursday, March 21, 2013 3:55 PM

To: Lindsay, Brett

Subject: RE: BART/RP SIP language

Brett,

Any chance that I can get a copy of your March 6th comments? Trevor is out with the arrival of a new

baby and Eric is stuck in meetings. Thanks for your help.

Balaji

From: Lindsay, Brett [mailto:BLindsay@srmaterials.com] 

Sent: Thursday, March 21, 2013 12:20 PM

To: Balaji Vaidyanathan

Subject: RE: BART/RP SIP language

Balaji:

Attached is the language that PCC proposes be input into the Revised SIP regarding Phoenix

Cement in the Reasonable Progress Section. Please review and let me know if you have any
questions or concerns. I know you are on a tight schedule, so don’t hesitate to email or call me.

Thanks again,

Brett Lindsay

Environmental Manager

Salt River Materials Group /

Phoenix Cement Company and

Salt River Sand & Rock

Office: (928) 634-2261 Ext. 8062

Direct: (928) 639-8062

Mobile: (928) 593-0209

Fax: (928) 634-3543

From: Balaji Vaidyanathan [mailto:Vaidyanathan.Balaji@azdeq.gov] 

Sent: Wednesday, March 20, 2013 2:52 PM

To: Lindsay, Brett

Subject: Re: BART/RP SIP language

Thanks Brett. I totally agree. I will handle the discussions with Jay. Your assistance is much

appreciated!

Balaji

Sent from my iPhone

On Mar 20, 2013, at 2:33 PM, "Lindsay, Brett" <BLindsay@srmaterials.com> wrote:

Balaji:

As a follow up to our discussion yesterday, we are currently working on language

specific to PCC that we would like to be considered for insertion into the Revised SIP.

With the understanding that time is precious and we have little of it, we will be

reviewing the proposed language internally (PCC and SRPMIC) this afternoon and

anticipate having it approved by 10 AM tomorrow morning. At that point I will be

able to send it to you for your review. In advance I can tell you that it is not long

winded, but short and succinct. We envision it looking and feeling similar to the other

non-BART source format that was included in the RP section of the AZ SIP. I hope that

this timetable is acceptable.

I know you were planning on speaking with APCC regarding this same issue and what

their thoughts were. I think in both PCC’s, ADEQ’s and APCC’s best interest, APCC

should be made aware that we are submitting a PCC verbiage (as described above) to

ADEQ with the intent of it being included in the Revised SIP. I just want to make sure

APCC knows our plans in a case that would affect their decision to include any

verbiage. While I can contact Jay Grady, I figured it might be best if you or ADEQ do

it. Let me know either way.
Thanks again for the opportunity to work with you and ADEQ on this. PCC feels that

this is a great opportunity to provide input into getting the SIP and regional haze

issued finalized. Let me know if you have any questions or concern.

Thanks again,

Brett Lindsay

Environmental Manager

Salt River Materials Group /

Phoenix Cement Company and

Salt River Sand & Rock

Office: (928) 634-2261 Ext. 8062

Direct: (928) 639-8062

Mobile: (928) 593-0209

Fax: (928) 634-3543

From: Balaji Vaidyanathan [mailto:Vaidyanathan.Balaji@azdeq.gov] 

Sent: Tuesday, March 19, 2013 3:34 PM

To: Lindsay, Brett

Subject: RE: BART/RP SIP language

Great, thanks Brett.

From: Lindsay, Brett [mailto:BLindsay@srmaterials.com] 

Sent: Tuesday, March 19, 2013 3:33 PM

To: Balaji Vaidyanathan

Subject: RE: BART/RP SIP language

....and here is the file I forgot to attach.

Brett Lindsay

Environmental Manager

Salt River Materials Group /

Phoenix Cement Company and

Salt River Sand & Rock

Office: (928) 634-2261 Ext. 8062

Direct: (928) 639-8062

Mobile: (928) 593-0209

Fax: (928) 634-3543

From: Balaji Vaidyanathan [mailto:Vaidyanathan.Balaji@azdeq.gov] 

Sent: Tuesday, March 19, 2013 12:55 PM

To: Lindsay, Brett

Subject: RE: BART/RP SIP language

Great, thanks Brett.

From: Lindsay, Brett [mailto:BLindsay@srmaterials.com] 

Sent: Tuesday, March 19, 2013 12:55 PM
To: Balaji Vaidyanathan

Subject: RE: BART/RP SIP language

There are some other things I would like included that I don’t think is common to

both facilities. I’ll try and give you a call within the hour.

Brett Lindsay

Environmental Manager

Salt River Materials Group /

Phoenix Cement Company and

Salt River Sand & Rock

Office: (928) 634-2261 Ext. 8062

Direct: (928) 639-8062

Mobile: (928) 593-0209

Fax: (928) 634-3543

From: Balaji Vaidyanathan [mailto:Vaidyanathan.Balaji@azdeq.gov] 

Sent: Tuesday, March 19, 2013 12:46 PM

To: Lindsay, Brett

Subject: RE: BART/RP SIP language

We can break it up if needed. I believe the pre-heater/pre-calciner language could be

common for the 2 plants unless you have concerns. Please let me know. Thanks Brett.

From: Lindsay, Brett [mailto:BLindsay@srmaterials.com] 

Sent: Tuesday, March 19, 2013 12:34 PM

To: Balaji Vaidyanathan

Subject: RE: BART/RP SIP language

I’m on a call right now, but I do have some language I was going to send your way.

Are you planning on discussing the cement plants together, not separately?

Brett Lindsay

Environmental Manager

Salt River Materials Group /

Phoenix Cement Company and

Salt River Sand & Rock

Office: (928) 634-2261 Ext. 8062

Direct: (928) 639-8062

Mobile: (928) 593-0209

Fax: (928) 634-3543

From: Balaji Vaidyanathan [mailto:Vaidyanathan.Balaji@azdeq.gov] 

Sent: Tuesday, March 19, 2013 12:31 PM

To: Lindsay, Brett

Subject: BART/RP SIP language

Brett, this is whatI intend to add to the RP discussion. Do you have any concerns? If

you have edits, please feel free to suggest. If there is a chance for you to reply to today,

it will be quite helpful. Thanks.
The operating kilns (Kiln 4 in CPC and the new kiln in Phoenix Cement) both

employ preheater/pre-calciner technology to optimize fuel consumption patterns

and consequently result in reduced nitrogen oxides emission levels relative to

kilns that are not equipped with the technology. With the technology, more fuel

is typically combusted at lower temperatures prior to the high-heat burning zone

in the main kiln burner and consequently, the potential for thermal NOX

generation is significantly reduced. Low NOX emission performance is

enhanced by employing staged combustion. The purpose of staged combustion is

to burn the fuel in 2 stages. Staged air combustion suppresses the formation of

NOX by operating under fuel rich reducing conditions in the flame or primary

zone where most of the NOX is potentially formed. This zone is followed by

oxygen-rich conditions in a downstream secondary zone where CO is oxidized at

a lower temperature with minimal NOX formation. 

It should be noted very minimal SO2 emissions are expected from these two

cement plant operations. The principal ingredient in the manufacture process is

limestone and it provides an inherent scrubbing opportunity. Most SO2

produced by fuel combustion are essentially “scrubbed” resulting in very

minimal SO2 emissions at the stack.

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NOTICE: This e-mail (and any attachments) may contain PRIVILEGED OR CONFIDENTIAL information

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used or disclosed only in accordance with law, and you may be subject to penalties under law for

improper use or further disclosure of the information in this e-mail and its attachments. If you have

received this e-mail in error, please immediately notify the person named above by reply e-mail,

and then delete the original e-mail. Thank you.

NOTICE: This e-mail (and any attachments) may contain PRIVILEGED OR CONFIDENTIAL information

and is intended only for the use of the specific individual(s) to whom it is addressed. It may contain

information that is privileged and confidential under state and federal law. This information may be

used or disclosed only in accordance with law, and you may be subject to penalties under law for

improper use or further disclosure of the information in this e-mail and its attachments. If you have

received this e-mail in error, please immediately notify the person named above by reply e-mail,

and then delete the original e-mail. Thank you.

NOTICE: This e-mail (and any attachments) may contain PRIVILEGED OR CONFIDENTIAL information

and is intended only for the use of the specific individual(s) to whom it is addressed. It may contain

information that is privileged and confidential under state and federal law. This information may be

used or disclosed only in accordance with law, and you may be subject to penalties under law for

improper use or further disclosure of the information in this e-mail and its attachments. If you have

received this e-mail in error, please immediately notify the person named above by reply e-mail,

and then delete the original e-mail. Thank you.

NOTICE: This e-mail (and any attachments) may contain PRIVILEGED OR CONFIDENTIAL information and is intended

only for the use of the specific individual(s) to whom it is addressed. It may contain information that is privileged

and confidential under state and federal law. This information may be used or disclosed only in accordance with law,

and you may be subject to penalties under law for improper use or further disclosure of the information in this email and its attachments. If you have received this e-mail in error, please immediately notify the person named

above by reply e-mail, and then delete the original e-mail. Thank you.

NOTICE: This e-mail (and any attachments) may contain PRIVILEGED OR CONFIDENTIAL information and is intended
only for the use of the specific individual(s) to whom it is addressed. It may contain information that is privileged

and confidential under state and federal law. This information may be used or disclosed only in accordance with law,

and you may be subject to penalties under law for improper use or further disclosure of the information in this email and its attachments. If you have received this e-mail in error, please immediately notify the person named

above by reply e-mail, and then delete the original e-mail. Thank you.
From: Bruce J. Friedl

To: Eric C. Massey; Steve M. Calderon; Lisa M. Tomczak

Subject: FW: PCC"s 4-Factor Analysis for Clarkdale Facility

Date: Thursday, March 28, 2013 4:30:42 PM

Attachments: 2013-3-21b - PCC"s 4-Factor Analysis for Clarkdale Facility.docx

Importance: High

From: Lindsay, Brett [mailto:BLindsay@srmaterials.com] 

Sent: Thursday, March 28, 2013 4:11 PM

To: Balaji Vaidyanathan; Bruce J. Friedl

Subject: Fwd: PCC's 4-Factor Analysis for Clarkdale Facility

Importance: High

Sent from my Verizon Wireless 4G LTE DROID
SUMMARY OF ASARCO - RAY COMPLEX 

ACID PLANT #2 

HAYDEN, ARIZONA 

H1SO/SO/PARTICULATE/S01 EMISSION DATA 

11/04/02 

TIME RUN # H1S04 S03 

PPM PPH PPM PPH 

v/v Dry vtv Dry 

1117-122 I-HzSO/S03 1.866 3.81 1.868 3.11 

1320-1424 2-HzSO/S03 1.198 2.28 1.201 1.86 

1508-1615 3-HzSO/S03 1.159 2.28 1.163 1.86 

Mean 1-3 1.408 2.79 1.411 2.28 

TIME RUN # SOl PARTICULATES 

PPM PPH GR/DSCF PPH 

v/v Dry 

1117-1222 I-PT/SOz 104.6 138.67 0.0066 7.558 

1320-1424 2-PT/SOz 92.0 114.44 0.0079 8.441 

1508-1615 3-PT/SOz 87.2 111.95 0.0109 12.023 

Mean 1-3 94.6 121.69 0.0085 9.341 

TIME RUN # GAS STREAM CHARACTERISTICS 

AWCFM ADCFM DSCFH T(s) %H1O %CO,/01 

OF v/v v/v Dry 

1117-1222 I-PT/SOz 205,877.0 205,094.7 8,015,672.0 286 0.38 0.0/15.8 

1320-1424 2-PT/S02 191,827.1 191,539.4 7,479,606.4 285 0.15 0.0/15.8 

1508-1615 3-PT/SOz 201,979.5 201,434.2 7,720,907.4 299 0.27 0.0/15.0 

Mean 1-3 199,894.5 199,356.1 7,738,728.6 290 0.27 0.0/15.5 
I
 

I
 

I 

considered insignificant to the overall emission picture. These metals were Beryllium (Be), Cobalt 

(Co), Chromium (Cr), Manganese (Mn), Nickel (Ni), and Vanadium (V). In the reported metals were 

selected samples were non-detectable in the lab report, a value of one-half the analytical limit of 

detection was used, as a detectable quantity, to support metals averaging. 

I 

The initial month of September 1994, in the six-month study, represented a series of start up 

problems, inoperable fans affecting the manifold flow, and lost sample periods. Due to these issues 

and limited documentation, this month was omitted from the total program database for the 

statistical averaging and reporting. 

One additional note that must be addressed when reViewing the data presented in this report. The 

reported emission summaries are based upon the data review and calculational summaries of all raw I	 field data. The dtlta does not incorportlte any modifiers of adjustment factors. However, an 

initial visualization and confirmation study was completed by NAWC using tracer gases entitled 

"Evaluation of the Installed Fugitive Emission Monitoring System September, 1994 - Report EM 94­

43, November 1994." In this study, the overall fugitive emission monitoring system collection 

efficiency was determined to be 76%. Based upon this, the emissions data, provided in this report for 

particulate and metals, can be increased by a collection efficiency factor of 1.3158 (Le. a reported 

emission value of 100 Ibs/day can be normalized to 131.58 pounds per day). 

Table 1 

Fugitive Emission Program Overall Summary 

Average Emissions in Pounds per Day 

October 1, 1994 through March 1, 1995 

Furnace Convener Anode Total 

Parameter Building Building Building Emissions 

Paniculate (PM) 244.48 138.53 350.69 733.61 

Silver (Ag)	 0.08 0.06 0.60 0.74 

Arsenic (As)	 3.55 3.40 13.24 20.20 

Cadmium (Cd) 0.20 0.14 0.13 0.47 

Copper (Cu) 48.01 22.21 111.86 182.08 

Iron (Fe)	 19.08 5.21 2.37 26.65 

lead (Pb)	 6.28 9.26 9.03 24.58 

Antimony (Sb) 0.23 0.64 0.30 1.17 

Selenium (Se) 0.95 1.10 11.87 13.92 

linc (In)	 3.11 8.63 2.89 14.63 

The Data Summary section of this report provides detailed program results for each month and 

each source. Complete data summaries and documentation of daily data runs are provided in 

the Appendix of this report. 

2 
7.0	 SUMMARY AND DISCUSSION OF RESULTS 

The six-month study was performed to obtain an estimate of the total fugitive S~

emissions from the Hayden smelter during typical operations. The Arizona DEQ also requested 

that a correlation between fugitive S02 emissions and ambient S02 concentrations be performed. 

This correlation would assist in determining the level of ambient S~ concentration attributable 

to fugitive S02 emissions. To perform these measurements the following items were completed: 

•	 Continuous emission measurements were made from the Converter, Furnace and 

Anode Buildings for a six month period; 

•	 Continuous ambient S02 measurements at the 4th Avenue monitoring station were 

measured at a monitoring station that was expected to measure the highest 

ambient impacts from the fugitive emission sources; and 

•	 Continuous meteorological measurements at the Joint Control Meteorological 

Station were measured at a station representative of conditions at the ambient SOz 

monitoring station. 

Based on the data collected during the six-month study the following conclusions can be 

made regarding the fugitive emission sources at the Hayden Smelter: 

1)	 Fugitive S02 emissions from the Converter and Furnace Buildings represent 

nearly all of the fugitive S02 emissions from the smelter. On average the 

Converter Building emits 525 lbs/hr or 64 percent of the facility fugitive S02 

emissions. The Furnace Building emits 288 lbs/hr or 35 percent and the Anode 

building contributes slightly over one percent or 13 lbs/hr. Emissions for the 

Furnace Building may be over estimated due to occasional double counting of 

Converter Building emissions blowing through the Furnace Building under 

easterly-flow conditions. 

7-1 
Attachment 1 

DERIVATION OF NEW FUGITIVE S02 EMISSION FACTORS 

Emission factors from NAWC study (Ibs/day) 

Converter 12430 

Flash Furnace 6818 

Anode 327 

2001 adjusted emission factors after WGH 

and primary hood modifications (Ibslday) 

Converter 5717.8 (54.00% reduction) 

Flash Furnace 3309.5 (51.46% reduction) 

Anode 327 

2001 AEI reported fugitive S02 (tons) 2001 operating days 

Converter 975.46 341.2 

Flash Furnace 564.59 

Anode 55.92 2001 sulfur balance 

fugitive S02 (tons) 

Total 1595.97 794 

New emission factors as reconciled 

by the 2001 sulfur balance (Ibs/day) 

Converter 2740.3 = (794 - 55.92) / (975.46 + 564.59) x 5717.8 

Flash Furnace 1586.1 = (794 - 55.92) / (975.46 + 564.59) x 3309.5 

Anode 327.0 

Re-calculated 2001 fugitive S02 emissions (tons) 

Converter 467.49 = 2740.3 Ibslday x 341.2 op days / 2000 

Flash Furnace 270.59 = 1586.1 Ibslday x 341.2 op days / 2000 

Anode 55.92 = 327 Ibslday x 341.2 op days / 2000 + .13 502 in natural gas 

Total 794 
FEB- 5-98 J10N 14: 49 TRC f«)RTH MERICAN WX FAK NO. 8019723813 P.01 

N!AN DAIlV 

(NUMBeR OF DAYS 

FURNACE 

S02 IN lB/OAV 

IN PARENTHESES) 

CO"VERT~ft ANODE 

SEP 

"CT 

NOV 

OfC 

JAN 

FE8 

MAR 

A." 

sse;, (23) 

521a (3.) 

717. (25) 

8432 (31) 

7633 (31) 

59tH (21) 

S8S. (1~)

, fIt 

0/ 

'" 

0/ 

" 

v· 

....... 

..,/ 

1/./1 

, 

If'-" 1.-­

• 

k.......". 

634. (31) .­

1136' (29) ..... 

14814 (31) v17 ••1 (2g) ".,. 

13984 (27) L 

11186 (16) ..... 

/11 '1jo fJ/f) 

.....;.., • ."••<.... ":4.. 'r\,~.

('....... . 

,­

4 •• (24) ",-­

267 (31) - 423 (29) ,/ 

27~ (38) V 

282 (91) v' 

27& (27) ..,.. 

369 (2')~'

3'/.7 

...... , "'­ -+

z-6-Qeo 
Basis for Natural Gas PTE for a Single Converter

Max Natural Gas Usage 519401 cu ft

Annual Max Natural Gas (Cubic Feet) 189581365 cu Ft

Annual Max Natural Gas (MMCF) 189.6 mmCF

158.0

15798 lb/yr

7.90 tons/yr

31.6

Maximum converter life is 10 months due to refractory erosion

Natural gas is conveyed to the converter burners using flexible hose.  Burners are removed

during operation for safety reasons.

NOx @ 100 lb/mmcf (AP‐42)

Total NOx for 4 converts

Nat Gas based on 10 months

Basis:  Natural gas usage based on highest one day flow to any converter during the period

of 1/1/2007 to 21/31/2012.