Memorandum to File 

Subject: Meetings between EPA and with Asarco on BART FIP 

From: Colleen McKaughan, Associate Director, Air Division, EPA Region 9 

To: File 

Date: June 16, 2014 

Participants: 

 Asarco: Jack Garrity, Technical Services Manager 

 Krishna Parameswaran, Director, State and Federal Regulatory Affairs 

 Eric Hiser, Attorney 

 Steve Gasser, Smelter Manager 

 Matt Russell, Consultant

 

EPA: Colleen McKaughan, Associate Director, Air Division 

 Eugene Chen, Engineer, Permits Office 

 Geoffrey Glass, Permits Office 

 Thomas Webb, Planning Office 

 Charlotte Withey, Attorney 

 

Summary: Asarco discussed its proposed converter retrofit project and the implications for the Regional 

Haze BART FIP. Asarco also provided additional information on control options mentioned in its 

comments on the proposed Regional Haze FIP. 

Materials: Agenda 

 Powerpoint Presentation 

 Followup Emails with Information to Geoffrey Glass on 5/19/2014, 5/20/2014 (2), 

5/21/2014 

 

 
May 15, 2014 Asarco / EPA BART FIP Meeting 

AGENDA 

1. Introductions 

2. Asarco’s objectives for meeting 

3. Hayden Smelter operations and plans 

a. Asarco’s goals 

b. The Converter Retrofit Project 

c. Fitting all the regulatory and engineering pieces together 

4. Secondary ventilation acid plant feasibility 

5. Secondary ventilation Wet scrubbing feasibility 

6. Existing primary acid plant 

a. Need for limits 

b. Measurement limitations and impact on BART 

c. Limit form/level 

7. Additional questions 

8. Next steps 
Regional Haze FIP Discussion

May 15, 2014
Meeting Agenda

• Introductions 

• Asarco’s objectives for meeting

• Hayden Smelter operations and plans

– Asarco’s goals

– The Converter Retrofit Project

– Fitting all the regulatory and engineering pieces together

• Secondary ventilation acid plant feasibility

• Secondary ventilation wet scrubbing feasibility

• Existing primary acid plant 

– Need for limits

– Measurement limitations and impact on BART

– Limit form/level 

• Additional questions

• Next steps
Asarco’s Objectives for Meeting

• Explain Hayden Smelter operations and plans to provide EPA context for 

discussion

• Discuss why a performance standard is needed and not a specific method 

of control

• Explain why secondary ventilation acid plant is not feasible

• Explain limitations on wet scrubbing

• Discuss limits for existing primary acid plant

• Answer any questions EPA may have about the Hayden Smelter operations 

and Asarco’s FIP comments
Hayden Smelter Operations

• Smelter includes an INCO Flash furnace, Peirce Smith Converters, Anode 

refining furnaces and ancillary equipment

• Asarco operates 5 Peirce-Smith Converters, 4 BART-eligible

– Primary hoods exhaust to the Acid Plant

– Secondary hoods exhaust to the Secondary Hood Baghouse

– Fugitives exhaust to atmosphere

• Acid Plant controls the flash furnace process gas in addition to the primary gas 

from all five converters

• Asarco’s goal is to upgrade the converting operation to meet all Clean Air Act 

requirements

– Many requirements (Regional Haze, SO2, PM, Pb NAAQS, NSPS, 

NESHAP, SIP)

– Engineering must balance all of these requirements

• Goal: Any limits or approaches developed under any one program must not 

hinder ability to achieve development of improved smelter that can meet all 

applicable requirements
Hayden Smelter SO2 Emissions – Current (PTE)
Peirce-Smith vs. Hoboken Converters

• ASARCO Hayden operates Peirce-Smith converters which differ from 

the Hoboken converters used at FMI Miami

Hoboken Converter Peirce-Smith Converter
Peirce-Smith vs. Hoboken Converters

Hoboken Operation

• Off-gas syphoned through end wall to close-coupled spray chamber

• Typically no hood over charge mouth

• Some fugitives can escape charge mouth if no cover

• Difficult to capture secondary emissions locally

• Miami converters installed at angle to aisle

Peirce-Smith Operation

• Off-gas exits charging mouth in center of vessel

• Typically have a tight primary hood over mouth and larger secondary hood 

over the primary hood

• Gases escaping mouth captured by primary and secondary hoods

• Easier to capture secondary emissions locally

– Allows for lower exhaust rate and higher SO2 strength
Converter Off Gas Design – Blowing 
Velocity (FPM)

4,900

4,700

4,400

4,200

3,900

3,700

3,400

3,200

3,000

2,700

2,500

2,200

2,000

1,700

1,500

1,200

1,000

700

500

200

0

Primary Hood CFD Modeling - Results
Converter Secondary Gas SO2 Treatment

• Converter secondary baghouse gas – current operation

– 275,000 SCFM at 100 - 200°F

– 1,580 ppmv SO2 average (0 to 10,000 ppmv variability)

– 95.4% from blowing, 4.6% from secondary activities

• EPA’s FIP proposed a control efficiency of 99.8% for the converter 

secondary gas stream

• Double Contact Acid Plant Not Feasible for this gas stream:

– SO2 concentration well below 6% SO2(60,000 ppmv) to operate autothermally

– Unproven in this application – not aware of any acid plants that: 

• operate at this low of inlet concentration, or 

• achieve 5ppmv outlet concentration

– To make a DCDA acid plant work in this application, 100% external heating 

plus reheating would be required

– High moisture content relative to SO2 content would require energy 

intensive dehumidification for proper acid strength and effective conversion

– High external heating load would contribute excessive collateral emissions
Converter Secondary Gas SO2 Treatment

• Wet alkali scrubbing is technically feasible but cannot provide 99.8% 

removal efficiency

– Best case efficiencies of between 85% and 95% possible depending on 

inlet concentration and reagent used

– Based on existing converter secondary gas conditions, an efficiency of 

around 90% would be expected on a 30-day basis

– BART FIP should not require a removal efficiency standard beyond 

what is achievable by wet alkali scrubbing
Smelter SO2 Emissions – Post-Retrofit (PTE)
Converter Secondary Gas SO2 Treatment

• The converter retrofit project will achieve emission reductions that 

will exceed those that would result from application of BART to the 

present configuration

– Secondary hood exhaust during blowing will be sent to acid plant

• Represents 95.4% of current secondary baghouse SO2 emissions

– Converter secondary baghouse SO2 emissions reduced by 95.8% 

– Total roofline fugitive SO2 emissions reduced by 87.3%

– Significant particulate and metals emissions reduction also achieved

– 67 ppmv average SO2 concentration in secondary baghouse outlet 

post-retrofit
Emissions Reduction Comparison

Annual Converter SO2 Emissions Estimate - TPY (Potential to Emit – 8,760 hrs)

Source Current

Converter

Secondary 

Scrubber 

85% Eff.

Converter

Secondary 

Scrubber 

95% Eff.

Converter

Retrofit 

Project

Total SO2 Generated by Converters 166,440 166,440 166,440 166,440

Total SO2from Converters to AP 143,895 143,895 143,895 165,251

- SO2 Captured by Primary Hood to AP 143,895 143,895 143,895 160,438

- SO2 Captured by Secondary Hood to AP 0 0 0 4,814

SO2 Captured by Secondary Hood to 

Secondary Baghouse

22,235 22,235 22,235 936

SO2 Captured by Tertiary Hood to Stack 0 0 0 240

Roofline SO2 Fugitive Emissions 310 310 310 13

Secondary Baghouse SO2 Emissions 22,235 3,335 1,112 796

Acid Plant Tail Gas SO2 Emissions 186 186 186 202

Total Converter SO2 Emissions 22,731 3,831 1,608 1,251

Total Converter SO2 Removal Efficiency 86.3% 97.7% 99.0% 99.2%
Converter Secondary Gas SO2 Treatment

• Converter Retrofit project SO2removal performance will exceed 

scrubbing of current secondary gases

– Total converter SO2removal will be 99.2% versus 97.7% to 99.0% from 

scrubbing current converter secondary gas

– Converter roofline fugitive SO2 emissions will be reduced from 300 to 13 

tpy 

• Flash furnace roofline fugitive SO2 emissions will also be reduced 

from 326 to 68 tpy

• No fugitives reduction achieved by scrubbing current converter 

secondary gas
Existing Acid Plant Issues

• Existing limits on Acid Plant have achieved substantial reductions and 

maintained them over long term – why are they now inadequate if goal is to 

maintain status quo?

• Setting new limits is difficult: Must address spikes and variability

• Measurement limitations constrain choices

– Accuracy/precision of process inputs and products

– Accuracy/precision of measurement devices

– Cumulative error where ± 1% may equal ± 1000 tons or more over year

– Issues are compounded as approach “unity”

• An unworkable limit benefits no one
Existing Acid Plant

• Proposed control efficiency and lb/ton acid produced are not feasible

– 99.8x limit was derived from taking estimated annual post-CRP acid 

plant emissions and comparing them to estimated annual post-CRP 

sulfur inputs and adjusting control efficiency to make them meet, 

consistent with engineering judgment

– No consideration given to less than annual emissions variability or 

impact of startup/shutdown cycle

– Measurement limitations are a concern

• Variability is considerable: (n = 10 years)

– Hourly ppm Mean: 128 with ± 176 standard deviation (max 

2000+)

– 30-day ppm Mean: 128 with ± 72 standard deviation (max 388)

– Hourly pph Mean: 127 with ± 166 standard deviation (max 

2750+)

– 30-day pph Mean: 127 with ± 76 standard deviation (max 384)
Summary

• Asarco is committed to engineering and installing next generation controls 

on its operation resulting in development of an improved smelter that meets 

all environmental requirements

• Based on current Hayden Smelter configuration and operating conditions, 

BART should be established as:

– Converter secondary gas emissions limit should be a 30-day 

pound/hour or removal efficiency limit based on what is achievable with 

wet alkali scrubbing at no more than 90% removal efficiency

– Acid plant tail gas emissions limit should not be an unachievable short 

term control efficiency limit but rather a tail gas ppmv concentration limit 

using the existing NSPS limit of 650 ppmv, with 1.5% exceedance per 

quarter, or an alternative annual or 30-day ppmv limit 

• BART limits need to be set so that they do not inhibit the ability of the 

smelter to move to its final improved condition where it can meet all 

environmental requirements
From: Garrity, Jack [mailto:JGarrity@asarco.com] 

Sent: Monday, May 19, 2014 4:05 PM 

To: GLASS, GEOFFREY; Parameswaran, Krishna 

Cc: Withey, Charlotte; McKaughan, Colleen; Chen, Eugene; Eric Hiser; Matt Russell; Veek, Amy 

Subject: RE: Questions about control options at Hayden Smelter 

Geoffrey: 

Thank you for your email. Asarco appreciates your taking the time to meet with us last Thursday and 

subsequently providing additional opportunity to try to clarify the potential operation of various control 

systems at its Hayden Smelter. We have responded to your observations and questions below with the 

information that we have available today. We will forward you any additional information that we can 

develop as quickly as possible. 

We will first respond to your observations from the meeting. We have set these out with any further 

clarifications that we want to provide. 

1. Because of the low inlet concentration, GCS believes that an acid plant could only achieve 

96% SO2 control on the secondary stream. GCS also estimates that our estimate of capital 

costs and energy costs are too low by approximately a factor of two. 

It is important to understand GCT’s and Asarco’s position on the acid plant. An acid plant on the existing 

converter secondary off gas could theoretically achieve at most 96% SO2 control. However, for the 

reasons set forth in Asarco’s and GCT’s comments, an acid plant on the converter secondary is not a 

practicable option because of the variability in the inlet concentrations, volumes, and operational 

constraints on the system. Therefore, trying to establish an SO2 control percentage for this option makes 

little sense because it is not practically achievable (e.g., it won’t work as a practical matter) and hence 

does not qualify as BART under the Guidelines. 

The estimated cost of $160 million for the base unit comes from MECS, an acid plant provider, and is 

contained in the MECS letter. 

2. GCS recommends a control efficiency no higher than 95% for caustic scrubbing. GCS did 

not question (but also did not confirm) our cost estimates of $28,000,000 in capital costs or 

$9,000,000 in operating costs (provided by Asarco in an earlier data request) nor the 

estimates for sludge hauling. 

GCT’s best estimate for maximum SO2 control efficiency for the Asarco converter secondary system is 

90% for the reasons stated by Matt Russell at the Thursday meeting. Additional cost information is 

provided below. 

3. GCS stated that Cansolv indicated they could achieve an “almost 99 percent” reduction, 

with an installed cost of $70,000,000. Cansolv would require 30 tph of steam which 

presumably would come from a new boiler. 

GCT and Cansolv do not recommend Cansolv technology for this application for the reasons stated by 

Matt Russell during the Thursday meeting. The concentrations are lower and more erratic than desirable; 

extensive steam heat would be required and would require provision of a boiler, and the additional cost of 

Cansolv does not warrant the very small improvement that would likely result over caustic 

scrubbing. GCT has estimated that the total installed cost for Cansolv would be $85 million once the 

boiler and cooling tower system are included with the $70 million Cansolv budget pricing. 
In response to your specific questions, Asarco can provide the following information at this time: 

1. Do you have more refined cost information on construction and operation of a conventional 

wet scrubber on the secondary emissions? 

We have not developed any more refined capital cost estimating on this item. The estimates to date have 

been preliminary budgetary estimates for comparison purposes only. Further refining them to a definitive 

cost estimate would require a few months of engineering. GCT also provided estimates of annual 

operating costs of $14 million for caustic scrubbing and $9.3 million for Cansolv. The caustic scrubber 

expense was increased from $9 million to $13.9 million after including expense for additional power 

requirements for the fans, pumps and other system ancillaries, makeup water, and more accurate sludge 

handling costing ($60/ton). 

2. Do you have more refined information on quantities of sludge and sludge handling costs? 

GCT did not previously evaluate the sludge generation rate or sludge handling costs provided by 

EPA. GCT has since evaluated the sludge generation rate and estimates a sludge generation rate 

of 3 tons calcium sulfate sludge per ton of SO2 removed. Sludge handling costs are very sitespecific and impurity-specific and have not been estimated by GCT. GCT used $60/ton provided 

by EPA in the operating cost estimate. If the sludge is hazardous, which Asarco believes may be 

the case, the cost would be closer to $200/ton and add over $7 million to the annual operating 

costs. 

3. Freeport has raised the possibility of using spent scrubber liquor to cool gases before 

sending them to their dust collection system/acid plant at the Miami Smelter. Would 

something like this be feasible at the Hayden Smelter? This would reduce the mass of waste 

and reduce handling costs. 

GCT and Asarco do not see any benefit of doing this at Asarco. GCT does not see this as reducing waste. 

Any material sprayed into the gas cooling units will end up in dust requiring disposal or in the acid plant 

blowdown sludge. It also will not save water consumption as it would result in equivalent makeup water 

requirements to the scrubber system. It also may present process risks to the process gas handling system 

in terms of plugged spray nozzles, ESP and other equipment buildup, etc. 

4. Do you have operating cost information for a Cansolv amine scrubber? The GCS letter only 

provided explicit information on the installed cost. 

GCT estimates an annual operating cost of $9.3 million for the current converter secondary 

gases. Cansolv would also require 30 ton/hour steam support, or 58 MMBtu/hour, which will also lead to 

the following collateral emissions based on AP-42, Chapter 1.4, Tables 1.4-1 and 1.4-2 (7/98) for external 

combustion: 

 NOx: 12.5 tons/year 

 CO: 20.9 tons/year 

 SO2: 0.02 tons/year 

 PMTotal 1.9 tons/year 

 VOC: 1.4 tons/year 

 Lead: 0.00012 tons/year 

 CO2: 29,887 tons/year 
These calculations do not address collateral emissions for electric demand. 

All costs provided in this email are budgetary estimates based on knowledge of similar projects. Finally, 

as Asarco must upgrade the converters to meet the 1-hour SO2 NAAQS, the BART limits need to be set 

so that they do not inhibit the smelter’s ability to move to its final improved condition where it can meet 

all environmental requirements. 

Regards, 

Jack Garrity 

From: GLASS, GEOFFREY [mailto:GLASS.GEOFFREY@EPA.GOV] 

Sent: Friday, May 16, 2014 3:48 PM 

To: Garrity, Jack; Parameswaran, Krishna 

Cc: Withey, Charlotte; McKaughan, Colleen; Chen, Eugene 

Subject: Questions about control options at Hayden Smelter 

Jack and Krishna: 

Thank you for meeting with us in San Francisco. There is a lot of useful information in your 

comments to the proposed BART FIP and in the presentation you shared with us 

yesterday. However, we need some additional information in order to make direct 

comparisons between the three control options of an acid plant, an amine (Cansolv) 

scrubber, and a caustic scrubber. 

Based on the letter from GCS you provided as an attachment to your comments: 

1. Because of the low inlet concentration, GCS believes that an acid plant could 

only achieve 96% SO2 control on the secondary stream. GCS also estimates that 

our estimate of capital costs and energy costs are too low by approximately a 

factor of two. 

2. GCS recommends a control efficiency no higher than 95% for caustic scrubbing. 

GCS did not question (but also did not confirm) our cost estimates of $28,000,000 

in capital costs or $9,000,000 in operating costs (provided by Asarco in an earlier 

data request) nor the estimates for sludge hauling. 

3. GCS stated that Cansolv indicated they could achieve an “almost 99 percent” 

reduction, with an installed cost of $70,000,000. Cansolv would require 30 tph of 

steam which presumably would come from a new boiler. 

My questions: 

1. Do you have more refined cost information on construction and operation of a 

conventional wet scrubber on the secondary emissions? 

2. Do you have more refined information on quantities of sludge and sludge 

handling costs? 

3. Freeport has raised the possibility of using spent scrubber liquor to cool gases 

before sending them to their dust collection system/acid plant at the Miami 
Smelter. Would something like this be feasible at the Hayden Smelter? This would 

reduce the mass of waste and reduce handling costs. 

4. Do you have operating cost information for a Cansolv amine scrubber? The GCS 

letter only provided explicit information on the installed cost. 

In order to meet our regulatory deadline, we need to have a decision for internal 

review by the end of next week. I will need this information on Monday in order to 

incorporate it into a final decision. 

Thank you 

_____________________________________________ 

Geoffrey L. Glass 

Environmental Engineer 

Air Permits Office, EPA Region 9 

415.972.3498 
From: Garrity, Jack [mailto:JGarrity@asarco.com] 

Sent: Tuesday, May 20, 2014 8:43 AM 

To: GLASS, GEOFFREY 

Cc: Withey, Charlotte; McKaughan, Colleen; Chen, Eugene; Eric Hiser; Parameswaran, Krishna 

Subject: RE: Questions about control options at Hayden Smelter 

Geoffrey, 

If I referred to a communiqué from Cansolv as a letter, I misspoke. We have a letter from 

MECS that was attached to our comments. What we have from Cansolv is an email (attached) 

in which a Cansolv engineer addresses application of their technology to low concentration SO2

streams. That specific discussion resulted from issues raised in our FOV negotiations and 

relates to post-retrofit emissions control. Further discussion with our consultants, GCT, 

informed Asarco’s understanding that Cansolv is best suited (most cost effective) for control of 

SO2 concentrations ranging from about 1% or 10,000 ppm to the lower threshold of what can 

practically be treated by a conventional acid plant (about 4%). Lower concentrations, such as 

our pre-retrofit secondary gas that averages 1580 ppm, are more practically controlled by 

caustic scrubbing. Therefore, our comments to your observation #3 below should be 

considered as an extrapolation of the attached email from Cansolv as qualified by Matt Russell 

during last Thursday’s meeting. I apologize for any confusion. 

Regards, 

Jack 

From: GLASS, GEOFFREY [mailto:GLASS.GEOFFREY@EPA.GOV] 

Sent: Monday, May 19, 2014 4:28 PM 

To: Garrity, Jack; Parameswaran, Krishna 

Cc: Withey, Charlotte; McKaughan, Colleen; Chen, Eugene; Eric Hiser; Matt Russell; Veek, Amy 

Subject: RE: Questions about control options at Hayden Smelter 

Thanks, Jack. 

At the meeting last week you mentioned a letter from Cansolv. I don’t see it in the 

attachments to your comment letter. Could you please provide a copy? 

From: Garrity, Jack [mailto:JGarrity@asarco.com] 

Sent: Monday, May 19, 2014 4:05 PM 

To: GLASS, GEOFFREY; Parameswaran, Krishna 

Cc: Withey, Charlotte; McKaughan, Colleen; Chen, Eugene; Eric Hiser; Matt Russell; Veek, Amy 

Subject: RE: Questions about control options at Hayden Smelter 

Geoffrey: 

Thank you for your email. Asarco appreciates your taking the time to meet with us last Thursday and 

subsequently providing additional opportunity to try to clarify the potential operation of various control 

systems at its Hayden Smelter. We have responded to your observations and questions below with the 

information that we have available today. We will forward you any additional information that we can 

develop as quickly as possible. 
We will first respond to your observations from the meeting. We have set these out with any further 

clarifications that we want to provide. 

1. Because of the low inlet concentration, GCS believes that an acid plant could only achieve 

96% SO2 control on the secondary stream. GCS also estimates that our estimate of capital 

costs and energy costs are too low by approximately a factor of two. 

It is important to understand GCT’s and Asarco’s position on the acid plant. An acid plant on the existing 

converter secondary off gas could theoretically achieve at most 96% SO2 control. However, for the 

reasons set forth in Asarco’s and GCT’s comments, an acid plant on the converter secondary is not a 

practicable option because of the variability in the inlet concentrations, volumes, and operational 

constraints on the system. Therefore, trying to establish an SO2 control percentage for this option makes 

little sense because it is not practically achievable (e.g., it won’t work as a practical matter) and hence 

does not qualify as BART under the Guidelines. 

The estimated cost of $160 million for the base unit comes from MECS, an acid plant provider, and is 

contained in the MECS letter. 

2. GCS recommends a control efficiency no higher than 95% for caustic scrubbing. GCS did 

not question (but also did not confirm) our cost estimates of $28,000,000 in capital costs or 

$9,000,000 in operating costs (provided by Asarco in an earlier data request) nor the 

estimates for sludge hauling. 

GCT’s best estimate for maximum SO2 control efficiency for the Asarco converter secondary system is 

90% for the reasons stated by Matt Russell at the Thursday meeting. Additional cost information is 

provided below. 

3. GCS stated that Cansolv indicated they could achieve an “almost 99 percent” reduction, 

with an installed cost of $70,000,000. Cansolv would require 30 tph of steam which 

presumably would come from a new boiler. 

GCT and Cansolv do not recommend Cansolv technology for this application for the reasons stated by 

Matt Russell during the Thursday meeting. The concentrations are lower and more erratic than desirable; 

extensive steam heat would be required and would require provision of a boiler, and the additional cost of 

Cansolv does not warrant the very small improvement that would likely result over caustic 

scrubbing. GCT has estimated that the total installed cost for Cansolv would be $85 million once the 

boiler and cooling tower system are included with the $70 million Cansolv budget pricing. 

In response to your specific questions, Asarco can provide the following information at this time: 

1. Do you have more refined cost information on construction and operation of a conventional 

wet scrubber on the secondary emissions? 

We have not developed any more refined capital cost estimating on this item. The estimates to date have 

been preliminary budgetary estimates for comparison purposes only. Further refining them to a definitive 

cost estimate would require a few months of engineering. GCT also provided estimates of annual 

operating costs of $14 million for caustic scrubbing and $9.3 million for Cansolv. The caustic scrubber 

expense was increased from $9 million to $13.9 million after including expense for additional power 

requirements for the fans, pumps and other system ancillaries, makeup water, and more accurate sludge 

handling costing ($60/ton). 
2. Do you have more refined information on quantities of sludge and sludge handling costs? 

GCT did not previously evaluate the sludge generation rate or sludge handling costs provided by 

EPA. GCT has since evaluated the sludge generation rate and estimates a sludge generation rate 

of 3 tons calcium sulfate sludge per ton of SO2 removed. Sludge handling costs are very sitespecific and impurity-specific and have not been estimated by GCT. GCT used $60/ton provided 

by EPA in the operating cost estimate. If the sludge is hazardous, which Asarco believes may be 

the case, the cost would be closer to $200/ton and add over $7 million to the annual operating 

costs. 

3. Freeport has raised the possibility of using spent scrubber liquor to cool gases before 

sending them to their dust collection system/acid plant at the Miami Smelter. Would 

something like this be feasible at the Hayden Smelter? This would reduce the mass of waste 

and reduce handling costs. 

GCT and Asarco do not see any benefit of doing this at Asarco. GCT does not see this as reducing waste. 

Any material sprayed into the gas cooling units will end up in dust requiring disposal or in the acid plant 

blowdown sludge. It also will not save water consumption as it would result in equivalent makeup water 

requirements to the scrubber system. It also may present process risks to the process gas handling system 

in terms of plugged spray nozzles, ESP and other equipment buildup, etc. 

4. Do you have operating cost information for a Cansolv amine scrubber? The GCS letter only 

provided explicit information on the installed cost. 

GCT estimates an annual operating cost of $9.3 million for the current converter secondary 

gases. Cansolv would also require 30 ton/hour steam support, or 58 MMBtu/hour, which will also lead to 

the following collateral emissions based on AP-42, Chapter 1.4, Tables 1.4-1 and 1.4-2 (7/98) for external 

combustion: 

 NOx: 12.5 tons/year 

 CO: 20.9 tons/year 

 SO2: 0.02 tons/year 

 PMTotal 1.9 tons/year 

 VOC: 1.4 tons/year 

 Lead: 0.00012 tons/year 

 CO2: 29,887 tons/year 

These calculations do not address collateral emissions for electric demand. 

All costs provided in this email are budgetary estimates based on knowledge of similar projects. Finally, 

as Asarco must upgrade the converters to meet the 1-hour SO2 NAAQS, the BART limits need to be set 

so that they do not inhibit the smelter’s ability to move to its final improved condition where it can meet 

all environmental requirements. 

Regards, 

Jack Garrity 

From: GLASS, GEOFFREY [mailto:GLASS.GEOFFREY@EPA.GOV] 

Sent: Friday, May 16, 2014 3:48 PM 
To: Garrity, Jack; Parameswaran, Krishna 

Cc: Withey, Charlotte; McKaughan, Colleen; Chen, Eugene 

Subject: Questions about control options at Hayden Smelter 

Jack and Krishna: 

Thank you for meeting with us in San Francisco. There is a lot of useful information in your 

comments to the proposed BART FIP and in the presentation you shared with us 

yesterday. However, we need some additional information in order to make direct 

comparisons between the three control options of an acid plant, an amine (Cansolv) 

scrubber, and a caustic scrubber. 

Based on the letter from GCS you provided as an attachment to your comments: 

1. Because of the low inlet concentration, GCS believes that an acid plant could 

only achieve 96% SO2 control on the secondary stream. GCS also estimates that 

our estimate of capital costs and energy costs are too low by approximately a 

factor of two. 

2. GCS recommends a control efficiency no higher than 95% for caustic scrubbing. 

GCS did not question (but also did not confirm) our cost estimates of $28,000,000 

in capital costs or $9,000,000 in operating costs (provided by Asarco in an earlier 

data request) nor the estimates for sludge hauling. 

3. GCS stated that Cansolv indicated they could achieve an “almost 99 percent” 

reduction, with an installed cost of $70,000,000. Cansolv would require 30 tph of 

steam which presumably would come from a new boiler. 

My questions: 

1. Do you have more refined cost information on construction and operation of a 

conventional wet scrubber on the secondary emissions? 

2. Do you have more refined information on quantities of sludge and sludge 

handling costs? 

3. Freeport has raised the possibility of using spent scrubber liquor to cool gases 

before sending them to their dust collection system/acid plant at the Miami 

Smelter. Would something like this be feasible at the Hayden Smelter? This would 

reduce the mass of waste and reduce handling costs. 

4. Do you have operating cost information for a Cansolv amine scrubber? The GCS 

letter only provided explicit information on the installed cost. 

In order to meet our regulatory deadline, we need to have a decision for internal 

review by the end of next week. I will need this information on Monday in order to 

incorporate it into a final decision. 

Thank you 

_____________________________________________ 

Geoffrey L. Glass 

Environmental Engineer 

Air Permits Office, EPA Region 9 
415.972.3498 

From: Garrity, Jack [mailto:JGarrity@asarco.com] 

Sent: Tuesday, May 20, 2014 9:55 AM 

To: GLASS, GEOFFREY 

Cc: Withey, Charlotte; McKaughan, Colleen; Chen, Eugene; Eric Hiser; Parameswaran, Krishna 

Subject: FW: Questions about control options at Hayden Smelter 

From: Matt Russell [mailto:russell@gcteng.com] 

Sent: Tuesday, May 20, 2014 9:49 AM 

To: Garrity, Jack 

Subject: RE: Questions about control options at Hayden Smelter

 

Jack,

That was calculated based on the estimated annual emissions PTE (assuming 8760 hrs of operation – 

18900 tpy) for the current smelter configuration and a flow rate of 275,000 SCFM. Therefore it is 

basically estimated on an operating hours only basis.

Regards,

Matt Russell

Senior Process Engineer

Gas Cleaning Technologies, LLC

Phone (214) 613-1785 x 13

Email: Russell@gcteng.com

From: Garrity, Jack [mailto:JGarrity@asarco.com] 

Sent: Tuesday, May 20, 2014 11:38 AM 

To: Matt Russell 

Subject: FW: Questions about control options at Hayden Smelter

 

Do you recall where the 1580 came from?

From: GLASS, GEOFFREY [mailto:GLASS.GEOFFREY@EPA.GOV] 

Sent: Tuesday, May 20, 2014 9:25 AM 

To: Garrity, Jack 

Cc: Withey, Charlotte; McKaughan, Colleen; Chen, Eugene; Eric Hiser; Parameswaran, Krishna 

Subject: RE: Questions about control options at Hayden Smelter

 

Thanks, Jack.

By the way, is that 1580 ppm a simple average or does it only include operating hours?

Geoffrey
From: Garrity, Jack [mailto:JGarrity@asarco.com] 

Sent: Wednesday, May 21, 2014 3:20 PM 

To: McKaughan, Colleen; GLASS, GEOFFREY 

Cc: Eric Hiser; Parameswaran, Krishna 

Subject: RE: Asarco 5/15/14 Presentation 

Colleen / Geoffrey, 

At the meeting last Thursday, Asarco presented a couple of conceptual approaches to setting 

limits for the BART-eligible units. Because the BART-eligible units are co-controlled with nonBART-eligible units, Asarco proposes a controlled limit for each control device, but the final 

BART-determination should be clear that the control determination applies only to the BARTeligible units. 

Based on its study of past data and EPA’s request that only “operating” hours be used, Asarco 

has determined that the existing acid plant can achieve a limit of 420 pounds/hour, 30-day 

rolling average. Because the flash furnace is not subject to BART, but contributes the majority 

of the emissions, EPA should provide that any exceedance that Asarco can demonstrate is due 

to the flash furnace is not a violation of the BART limit. As a practical matter, this might take the 

form of demonstrating that if certain flash furnace-only hours of operation are excluded from the 

compliance demonstration and the BART limit is met, then no violation of BART has 

occurred. Asarco does not anticipate any such exceedances, but believes the principle is 

important. 

Similarly, for the proposed wet scrubbing on the converter secondary gases, should EPA decide 

that it is warranted as BART, Asarco believes that a limit based on 90% control efficiency is 

practicable. Based on the 20,341 tons/year baseline with five converters, this would be 4,068 

tons/converter, with four converters controlled to 407 tons each and 1 converter at 4,068 tons 

for a total of 5,696 tons/year. Assuming 330 operating days in a typical year (an operating day 

being any day that blast air is introduced into a BART-eligible converter), a 30-day rolling 

average of 1,438 pounds/hour and a rolling 12-month sum of 5,696 tons/year would be 

appropriate. 

Finally, in light of the impending converter retrofit project, Asarco requests that EPA clarify in the 

preamble to the final rule that the BART limits apply only to the BART-eligible units and do not 

apply if those units are removed. 

Regards, 

Jack 

From: Garrity, Jack 

Sent: Tuesday, May 20, 2014 11:48 AM 

To: McKaughan, Colleen (McKaughan.Colleen@epa.gov); GLASS, GEOFFREY 

(GLASS.GEOFFREY@EPA.GOV) 

Subject: Asarco 5/15/14 Presentation 

Colleen / Geoffrey, 

Here are the slides of our presentation last Thursday. You’ll recall that we also shared additional 

thoughts of possible alternatives to the efficiency limit for our existing acid plant. We will send 
our recommendation of the most appropriate form of limit as soon as we have finished revising 

data to EPA’s preferred “operating hours only” format. 

Regards, 

Jack