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OAR Box 1778 

Prepped by Ollie Stewart 

Document Number: 

44) ll-B-19 

Docket Number: 

A-90-06 

Printed 10/28/2008 9:50:53 AM Sheet 44 of 276 
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2 4 I98T OFFICE OF 

MR AND RADIATION 

MEMORANDUM 

SUBJECT: Compliance Status of Phelps Dodge's^Hidalgo Smelter 

FROM: John S. Seitz, Director^^ 

Stationary Source ComplrsCnce Division 

Office of Air Quality Planning and Standards 

TO: William B. Hathaway, Director 

Air, Pesticides and Toxics Division, Region VI 

On September 1, 1987 your office forwarded information 

concerning the compliance status of Phelps Dodge's Hidalgo 

Smelter in Playas, New Mexico, and requested that our office 

review that information. This memorandum serves as an update c.r. 

our review. 

The analysis forwarded by your office concluded that the 

1986 addition of the oxygen enrichment plant at Phelps Dodge 

resulted in a decrease in sulfur dioxide and particulates, and 

that there are no violations of the PSD or NSPS requirements. Ir. 

our review we have consulted with the Office of Policy Analysis 

and Review (OPAR). SSCD and OPAR have indicated that the 

PSD/NSPS compliance status could not be evaluated without 

information on actual hours of operation and feed rate. In 

response to this comment, on October 6, 1987 your staff forwarded 

the confidential information on "normal" days of operation and 

"normal" feed rate deleted from the September 1 package. 

SSCD 

October 6, 

establish 

determine 

—^ k9/hr basi 

and after 

emissions 

enrichment 

those emis 

and OPAR have reviewed the information forwarded on 

and have determined that it is not specific enough to 

NSPS nor PSD applicability. For NSPS, we need to 

if there has been an increase in S02 emissions on a 

s when operating conditions are held constant before 

the change. Although Phelps Dodge did provide kg/hr 

data before and after the addition of the oxygen 

plant, they did not specify the conditions under v:'nic; 

sions occurred. For PSD, actual emissions in tons per 
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ri 

4 r- • 

year before the change must be compared to potential emissions in 

tons per year after the change. Phelps Dodge did not provide 

either of those figures for particulate matter. Although' Phelps 

Dodge has established an actual emissions baseline for S02 before 

the change, it is not possible to determine if the actual S02 

emissions reported after the change represent maximum potential 

emissions. Therefore, in order to establish NSPS and PSD 

applicability, more specific information is needed from Phelps 

Dodge, including data on actual (as opposed to "normal") feed 

rate, and the net particulate emissions increase. 

You have also requested that our office review the alleged 

SIP violation. We have reviewed the information submitted and 

agree with your analysis that the frequent by-passes of the 

sulfur dioxide control equipment constitute violations of the 

New Mexico Implementation Plan. Although a SIP violation alone 

in an attainment area would not qualify this source as a 

significant violator, this violation should be resolved in a 

timely manner in light of Annex IV to the U.S.-Mexican border 

agreement. 

If you have any questions regarding our review, please 

contact Sally M. Farrell at FTS 382-2875. 

cc: Bruce Armstrong, OPAR 

Stanley Spruiell, Region 6 

Steve Hitte, SSCD 

Laxmi Kesari, SSCD 

Michael S. Alushin, AED 

Rachel M. Hopp, AED