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 HiserFrom: 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 PMTo: 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 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 intendedonly 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 H 1SO/SO/PARTICULATE/S0 1 

### EMISSION DATA 11/04/02



### TIME RUN # H 1S0 4 

### S03 PPM PPH PPM PPH v/v Dry 

### vtv Dry 1117-122 I-H zSO/S0 3 

### 1.866 3.81 1.868 3.11 1320-1424 2-H 

### zSO/S0 3 

### 1.198 2.28 1.201 1.86 1508-1615 3-H zSO/S0 3 

### 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/SO 

### z 104.6 138.67 0.0066 7.558 1320-1424 2-PT/SO 

### z 92.0 114.44 0.0079 8.441 1508-1615 3-PT/SO z 

### 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) %H 1O %CO,/01 OF v/v v/v 

### Dry 1117-1222 I-PT/SO z 

### 205,877.0 205,094.7 8,015,672.0 286 0.38 0.0/15.8 1320-1424 2-PT/S0 2 

### 191,827.1 191,539.4 7,479,606.4 285 0.15 0.0/15.8 1508-1615 3-PT/SO z 

### 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.

7-1Attachment 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 50 2 in natural gas

Total 794

### FEB- 5-98 J10N 14: 49 

### TRC f«)RTH MER I CAN 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) 

## .....
/1 1 

## '1 jo 

## fJ/f)

.....

;.., • ."•• <.... ":4..**'r\,~.**

(' 

# .......

. 

### ,­ 4 •• (24) ",-­

267 (31) 

# -

423 (29) 

### ,/**27~** (38) 

## V

282 (91) v'

27& (27) 

# ..,..

369**(2')~'** 

## 3'/.7

...... 

# -+

, "'­



# z-6-QeoBasis 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.