( 

ARIZONA DEPARTMENT 

OF 

ENVIRONMENTAL QUALITY 

jane Dee Hull 

Governor 

October 9, 2001 

CERTIFIED MAIL 

3033 North Central Avenue • Phoenix, Arizona 85012-2809 

(602) 207-2300 • www.adeq.state.az.us 

RETURN RECEIPT REQUESTED .,., 

John R. Shaw, General Manager 

ASARCO Incorporated - Ray Complex 

P.O. Box 8 

Hayden, Arizona 85235 

Subject: Air Quality Permit No. 1000042 

ASARCO - Hayden Smelter 

Dear Mr. Shaw: 

~~]~~ ·~~; ON.-:--- a.v 

'!._11l!Nrl'-'-' 

jacqueline E. Schafer 

Director 

CTS idno: 41794 

Enclosed is a permit for the referenced facility. In accordance with Arizona Revised Statutes, 

§49-430, this permit should be readily available at all times on the premises. 

The permit is issued for a period of five years. Please keep us informed of any changes that 

would affect your air pollution status during the period of this permit. 

You are advised that a permit is a legally enforceable document. If your facility fails to comply 

with the provisions contained in its permit, you will be subject to enforcement action and could 

incur civil fines of up to ten thousand dollars per day under A.R.S. §49-463 and/or be subject to 

criminal penalties in accordance with A.R.S. §49-464. 

If you have any questions, please do not hesitate to contact the Permits Section of the Air Quality 

Division at (602) 207-4490. 

incerely, 

Nancy C. Wrona, Director 

Air Quality Division 

NCW:zfl 

J:\AQD\PERMITS\COMMON\PERMITS\1000042\MISC\issltr.wpd 

Enclosures 

Northern Regional Office 

1515 East Cedar Avenue • Suite F • Flagstaff1 1\Z. 86004 

(928) 779-0313 

Southern Regional Office 

400 West Congress Street • Suite 433 • Tucson/ AZ 85701 

(520) 628-6733 

ARIZONA DEPARTMENT OF ENVIRONMENTAL QUALITY 

Air Quality Division 

3003 N. Central Ave. • Phoenix, AZ 85012-290703 • Phone: (602) 207-2338 (r0 rf\\ rr§JWJ 

AIR QUALITY CONTROL PERMIT ~ ~ \J \.f 

(As required by Title 49, Chapter 3, Article 2, Section 49-426, Arizona Revised Statutes) 

This air quality control permit does not relieve applicant of responsibility for meeting all air pollution regulations 

I. PERMIT TO BE ISSUED TO (Business license name of organization that is to receive pennit) -----------------------

. "· -.: .. .t'J~ARCO- Ray C~mplex Hayden Smelter 

2. NAME (OR NAMES) OF OWNER OR PRINCIPALS DOING BUSINESS AS TilE ABOVE ORGANIZATION-------------

ASARCO Incorporated 

3. MAILING ADDRESS ___..::Pc..:•....:O:::.:•:....:B=ox::.=.....::8::_ ______ ---'---------------------- NUMBER STREET 

Hayden, AZ 85235-0008-08 

CITY OR COMMUNITY STATE ZIP CODE 

4. ORIGINAL EQUIPMENT LOCATION/ADDRESS -~6~4~0-..!A~sa!!:.r:...:C~o~A~v:.!:e:.:.:n:..:U.::.:e::...._ __________________ _ 

NUMBER STREET 

Hayden, Gila County, Arizona 85235 

CITY OR COMMUNITY STATE COUNTY ZIP CODE 

FACILITIES OR EQUIPMENT DESCRIPTION ___ C:::.o:::Jpt:.~P::..:e:.:.r.::.S:.:.m:.:.e::.:l::.:te:.:.r....:.w.:.:l::.:.th.:.....:::O:.::xy:z..a.g::.:en..:.....::.F_::la~s:.:.:h:....:F~u::.:r:...:.n::!a:.::c:::.e,t.:· S::..:e:.::e:...:.A;:.:tt::.:a::!c::.:h:.:.:m::.:e:.:.n:.::t_'~'C:._'_' ----

6. TIIIS PERMIT ISSUED SUBJECT TO THE FOLLOWING __ C=on:.::d::.:i::.:ti::::.o::!n::..S ::::.CO::.:n::.:t:.=a:::in.:.:e:.::d:....:l::.:.n:...:.A;:.:tt::.:a::.:c::.:.:h:.:.:m::.:e:.:.n:.::ts~"A~"L, -'" B::::....."...::a:.:.:n:.::d~'..:.'D:::._" _____ _ 

7. ADEQ PERMIT NUMBER # J 000042 PERMIT CLASS --~/ ___ EXPIRATION DATE October 9 , 2 0 0 6 

__ 9_t_h __ DAYOF _______ o_c_t_o_b_e_r ______________ ,200J 

Nanc C. Wrona Director Air 

TITLE 

ADEQ/AQD/PIOOD (9-93) 

Governor Jane Dee Hull 

State of Arizona 

Jacqueline E. Schafer, Director 

Arizona Department of Environmental Quality 

3033 N. Central Avenue 

Phoenix, AZ 85012 

(602) 207-2316 Voice 

(602) 207-2366 Fax 

ARIZONA DEPARTMENT OF ENVIRONMENTAL QUALITY 

AIR QUALITY CLASS I PERMIT 

COMPANY NAME: 

FACILITY NAME: 

PERMIT NUMBER: 

DATE ISSUED: 

EXPIRY DATE: 

SUMMARY 

ASARCO Incorporated 

Ray Complex Hayden Smelter 

1000042 

October 9, 2001 

October 9, 2006 

This operating permit is issued to ASARCO Incorporated, the Permittee, for operation of their Ray Complex Hayden 

Smelter, located in Hayden, Gila County, Arizona. The Hayden Smelter is a primary copper smelter and consists of 

one Inco oxygen flash furnace, five Pierce-Smith converters, two Fuller anode furnaces, two Fuller fluid bed dryers 

and other auxiliary operations. 

In regard to air pollution control, the Hayden Smelter operates a double contact acid plant, the Monsanto sulfuric acid 

plant to remove sulfur dioxide (S02) from the flash furnace and converters primary gases. The smelter also operates 

an electrostatic precipitator, the R&R Cottrell ESP for particulate matter (PM) removal from the flash furnace vent 

gases and the dryers flue gases, and a baghouse to capture the converters secondary hooding particulates. Baghouses 

are also used in other processes to control PM emissions. 

The Hayden Smelter is classified as a Class I, Major Source, pursuant to A.A.C. R18-2-1 0 1.61. The potential emission 

rates of the following pollutants are greater than 100 tons per year: (i) particulate matter, (ii) sulfur dioxide, and (iii) 

nitrogen oxides. 

This Class I permit is issued in accordance with Title V of the Clean Air Act, and Title 49, Chapter 3 of the Arizona 

Revised Statutes. Applicable requirements for the operations at Hayden are listed in portions subtitled "Permit shield" 

of this permit. All definitions, terms, and conditions used in this permit conform to those in the Arizona Administrative 

Code R18-2-101 et. seq. (A.A.C.) and 40 Code of Federal Regulations (CFR), except as otherwise defined in this 

permit. Unless noted otherwise, references cited in the permit conditions refer to the A.A. C. All terms and conditions 

in this permit are enforceable by the Administrator of the United States Environmental Protection Agency (U.S. EPA), 

except for those terms and conditions that have been designated as "State requirements". 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 1 of65 
TABLE OF CONTENTS 

ATTACHMENT "A": GENERAL PROVISIONS ........................................... Page 5 

I. PERMIT EXPIRATION AND RENEWAL ......................................... Page 5 

II. COMPLIANCE WITH PERMIT CONDITIONS ..................................... Page 5 

III. PERMIT REVISION, REOPENING, REVOCATION AND REISSUANCE, 

OR TERMINATION FOR CAUSE ............................................... Page 5 

IV. POSTING OF PERMIT ........................................................ Page 6 

V. FEE PAYMENT .............................................................. Page 6 

VI. ANNUAL EMISSIONS INVENTORY QUESTIONNAIRE ............................ Page 6 

VII. COMPLIANCE CERTIFICATION ............................................... Page 6 

VIII. CERTIFICATION OF TRUTH, ACCURACY AND COMPLETENESS .................. Page 7 

IX. INSPECTION AND ENTRY .................................................... Page 7 

X. PERMIT REVISION PURSUANT TO FEDERAL HAZARDOUS AIR 

XI. 

XII. 

XIII. 

XIV. 

XV. 

XVI. 

XVII. 

XVIII. 

XIX. 

XX. 

XXI. 

XXII. 

POLLUTANT STANDARD .................................................... Page 7 

REPORTING OF EXCESS EMISSIONS, PERMIT DEVIATIONS, AND EMERGENCIES .. Page 8 

A. EXCESS EMISSIONS REPORTING .......................................... Page 8 

B. PERMIT DEVIATIONS REPORTING ......................................... Page 8 

C. EMERGENCY PROVISION ................................................. Page 9 

D. COMPLIANCE SCHEDULE ................................................. Page 9 

RECORD KEEPING REQUIREMENTS ........................................... Page 9 

REPORTING REQUIREMENTS ................................................ Page 10 

DUTY TO PROVIDE INFORMATION .......................................... Page 10 

PERMIT AMENDMENT OR REVISION ......................................... Page 10 

FACILITY CHANGE WITHOUT PERMIT REVISION ............................. Page 10 

PERFORMANCE TESTING REQUIREMENTS ................................... Page 11 

PROPERTY RIGHTS ......................................................... Page 12 

SEVERABILITY CLAUSE .................................................... Page 12 

PERMIT SHIELD ............................................................ Page 13 

ACCIDENTAL RELEASE PROGRAM .......................................... Page 13 

PROTECTION OF STRATOSPHERIC OZONE ................................... Page 13 

ATTACHMENT "B": SPECIFIC CONDITIONS .......................................... Page 14 

I. GENERAL ................................................................. Page 14 

II. AFFECTED FACILITIES GOVERNED BY THE NEW SOURCE 

PERFORMANCE STANDARDS ............................................... Page 15 

A. General Provisions of the Section . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 15 

B. Emission limits and Standards ............................................... Page 16 

C. Air Pollution Control Requirements ........................................... Page 16 

D. Monitoring, Recordkeeping and Reporting Requirements .......................... Page 17 

E. Performance Testing Requirements ........................................... Page 22 

F. Permit Shield ............................................................ Page 23 

III. PROCESS SOURCES GOVERNED BY THE MULTI-POINT ROLLBACK RULE ....... Page 23 

A. General Provisions of the Section ............................................ Page 23 

B. Emission Limitations and Standards .......................................... Page 23 

C. Monitoring, Recordkeeping and Reporting Requirements .......................... Page 24 

D. Permit Shield ............................................................ Page 27 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 2 of65 
N. MORE REQUIREMENTS FOR FURNACE AND CONVERTERS OPERATION ......... Page 28 

A. Applicability ............................................................. Page 28 

B. Emission limits and Standards ............................................... Page 28 

C. Air Pollution Control Requirements ........................................... Page 29 

D. Monitoring, Recordkeeping and Reporting Requirements .......................... Page 29 

E. Performance Testing Requirements ........................................... Page 31 

F. Permit Shield ............................................................ Page 31 

V. CONVERTERS ARSENIC CHARGING RATE MONITORING ....................... Page 31 

A. General Provisions of the Section ............................................ Page 3 1 

B. Monitoring Requirements ................................................... Page 32 

C. Recordkeeping and Reporting Requirements .................................... Page 32 

D. Permit Shield ............................................................ Page 33 

VI. MATERIAL STORAGE FACILITIES ............................................ Page 33 

A. Affected Facilities ........................................................ Page 33 

B. Emission limits and Standards ............................................... Page 33 

C. Air Pollution Control Requirements ........................................... Page 34 

D. Monitoring, Recordkeeping and Reporting Requirements .......................... Page 34 

E. Permit Shield ............................................................ Page 34 

VII. REVERT CRUSHING PLANT ................................................. Page 34 

A. Applicability ............................................................. Page 34 

B. Emission limits and Standards ............................................... Page 34 

C. Air Pollution Control Requirements ........................................... Page 35 

D. Monitoring, Recordkeeping and Reporting Requirements .......................... Page 35 

E. Performance Testing Requirements ........................................... Page 3 7 

F. Permit Shield . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 3 7 

VIII. FUEL BURNING EQUIPMENT ................................................ Page 3 7 

A. General Provisions of this Section ............................................ Page 3 7 

B. Emission Standards and Limitations .......................................... Page 38 

C. Monitoring, Recordkeeping and Reporting Requirements .......................... Page 39 

D. Permit Shield ............................................................ Page 39 

IX. VISIBLE FUGITNE EMISSIONS FROM PROCESS SOURCES ...................... Page 40 

A. Affected Facilities ........................................................ Page 40 

B. Opacity Standard ......................................................... Page 40 

C. Monitoring, Recordkeeping and Reporting ..................................... Page 40 

D. Alternate Operating Scenario for the Anode Furnaces ............................ Page 41 

E. Permit Shield . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 41 

X. NON-POINT SOURCES ...................................................... Page 41 

A. Emission Limits and Standards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 41 

B. Monitoring, Recordkeeping and Reporting Requirements .......................... Page 42 

C. Permit Shield ............................................................ Page 42 

XI. OTHER PERIODIC ACTNITIES ............................................... Page 43 

A. Emission Limits/Standards .................................................. Page 43 

B. Monitoring, Recordkeeping and Reporting Requirements .......................... Page 44 

C. Permit Shield ............................................................ Page 45 

XII. AMBIENT SULFUR DIOXIDE MONITORING ................................... Page 45 

A. Ambient Sulfur Oxides (Sulfur Dioxide) Standards .............................. Page 45 

B. Monitoring, Recordkeeping and Reporting Requirements .......................... Page 46 

C. Permit Shield ............................................................ Page 47 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 3 of65 
ATTACHMENT "C": EQUIPMENT LIST ............................................... Page 49 

Table C-1. Process and Control Equipment Description .................................... Page 49 

Table C-2. Stack Information ......................................................... Page 55 

Table C-3. Continuous Emission Monitoring Systems Information ........................... Page 56 

Table C-4. Ambient Sulfur Dioxide Analyzers in the Hayden Area ........................... Page 57 

ATTACHMENT "D": SULFUR BALANCE PROGRAM .................................... Page 58 

Appendix D-A. Procedures for Utilizing the Sulfur Balance Method 

for Determining Sulfur Emissions ......................................... Page 58 

Appendix D-B. ASARCO Hayden Laboratory QA/QC Plan for Sulfur Analyses 

Sulfuric Acid - Shipments and Production .................................. Page 62 

Appendix D-C. ASARCO Hayden Laboratory QA/QC Plan for Sulfur Analyses 

LECO Sulfuric Analyzer- Concentrates and By-Products ...................... Page 63 

Appendix D-D. ASARCO Hayden Laboratory QA/QC Plan for Sulfur Analyses 

Weak Acid Solutions- Process Solutions ................................... Page 64 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 4 of65 
IV. 

v. 

ATTACHMENT "A": GENERAL PROVISIONS 

Air Quality Control Permit No. 1000042 

For 

ASARCO Incorporated- Ray Complex Hayden Smelter 

PERMIT EXPIRATION AND RENEWAL [A.R.S. § 49-426.F, A.A. C. R18-2-304.C.2 and 306.A.1] 

A. This permit is valid for a period of five years from the date of issuance of the permit. 

B. Permittee shall submit an application for renewal of this permit at least 6 months, but not more than 18 

months prior to the date of permit expiration. 

COMPLIANCE WITH PERMIT CONDITIONS [A.A. C. R18-2-306.A.8.a and b, A.R.S. §49-463 and A.R.S. §49-464] 

A. Permittee shall comply with all the conditions contained in Attachments "A" through "D"ofthis permit 

including all applicable requirements of Arizona air quality statutes and the air quality rules. Any permit 

noncompliance constitutes a violation of the Arizona Revised Statutes and is grounds for enforcement 

action; for permit termination, revocation andre-issuance, or revision; or for denial of a permit renewal 

application. In addition, noncompliance with any federally enforceable requirement constitutes a violation 

of the Clean Air Act. 

B. Need to halt or reduce activity not a defense. It shall not be a defense for a Permittee in an enforcement 

action that it would have been necessary to halt or reduce the permitted activity in order to maintain 

compliance with the conditions of this permit. 

VI. PERMIT REVISION, REOPENING, REVOCATION AND REISSUANCE, OR TERMINATION FOR 

CAUSE [A.A.C. R18-2-306.A.8.c and 32l.A] 

A. The permit may be revised, reopened, revoked and reissued, or terminated for cause. The filing of a 

request by Permittee for a permit revision, revocation and reissuance, or termination; or of a notification 

of planned changes or anticipated noncompliance does not stay any permit condition. 

B. The permit shall be reopened and revised under any of the following circumstances: 

1. Additional applicable requirements under the Act become applicable to the Class I source. Such 

reopening shall only occur if there are three or more years remaining in the permit term. The reopening 

shall be completed not later than 18 months after promulgation of the applicable requirement. No such 

reopening is required if the effective date of the requirement is later than the date on which the permit 

is due to expire, unless the original permit or any of its terms and conditions has been extended 

pursuant to R18-2-322(B). Any permit revision required pursuant to this subparagraph shall comply 

with provisions in Rl8-2-322 for permit renewal and shall reset the five year permit term. 

2. Additional requirements, including excess emissions requirements, become applicable to an affected 

source under the acid rain program. Upon approval by the Administrator, excess emissions offset plans 

shall be deemed to be incorporated into the Class I permit. 

3. The Director or the Administrator determines that the permit contains a material mistake or that 

inaccurate statements were made in establishing the emissions standards or other terms or conditions 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 5 of65 
ofthe permit. 

4. The Director or the Administrator determines that the permit needs to be revised or revoked to assure 

compliance with the applicable requirements. 

C. Proceedings to reopen and issue a permit, including appeal of any final action relating to a permit 

reopening, shall follow the same procedures as apply to initial permit issuance and shall, except for 

reopenings under paragraph III.B.1 of this Attachment, affect only those parts of the permit for which 

cause to reopen exists. Such reopenings shall be made as expeditiously as practicable. Permit reopenings 

for reasons other than those stated in paragraph III.B .1 of this Attachment shall not result in a resetting of 

the five year permit term. 

VII. POSTING OF PERMIT [A.A.C. R18-2-315] 

A. Permittee shall post such permit, or a certificate of permit issuance on location where the facility is located 

in such a manner as to be clearly visible and accessible. All equipment covered by the permit shall be 

clearly marked with one of the following: 

1. Current permit number. 

2. Serial number or other equipment number that is also listed in the permit to identify that piece of 

equipment. 

B. A copy of the complete permit shall be kept on the site. 

VIII. FEE PAYMENT [A.A.C. R18-2-326 and 306.A.9] 

IX. 

Permittee shall pay fees to the Director pursuant to A.R.S. § 49-426(E) and A.A.C. R18-2-326. 

ANNUAL EMISSIONS INVENTORY QUESTIONNAIRE [A.A.C. R18-2-327] 

A. Permittee shall complete and submit to the Director an annual emissions inventory questionnaire. The 

questionnaire is due by March 31 or ninety days after the Director makes the inventory form available each 

year, whichever occurs later, and shall include emission information for the previous calendaryear. 

B. The questionnaire shall be on a form provided by the Director and shall include the information required 

by A.A.C. R18-2-327. 

X. COMPLIANCE CERTIFICATION 

A. Permittee shall submit a compliance certification to the Director twice each year, which describes the 

compliance status of the source with respect to each permit condition. The first certification shall be 

submitted no later than May 15th, and shall report the compliance status of the source during the period 

between October 1st of the previous year and March 31st of the current year. The second certification 

shall be submitted no later than November 15th, and shall report the compliance status of the source during 

the period between April 1st and September 30th of the current year. [A.A.C. R18-2-309.2.a] 

The compliance certifications shall include the following: 

1. Identification of each term or condition of the permit that is the basis of the certification; 

ASARCO -Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 6 of65 
XI. 

[A.A.C. R18-2-309.2.c.i] 

2. Compliance status with each applicable requirement; [A.A.C. R18-2-309.2.c.ii] 

3. Whether compliance was continuous or intermittent; [A.A.C. R18-2-309.2.c.iii] 

4. Method(s) used for determining the compliance status of the source, currently and over the reporting 

period; [A.A.C. R18-2-309.2.c.iv] 

5. A progress report on all outstanding compliance schedules submitted pursuant to Section XI.D of this 

Attachment. Progress reports submitted with compliance certifications shall satisfy the reporting 

requirements of A.A. C. R18-2-309.5.d. [A.A.C. R18-2-309.2.c.v and 309.5.d] 

B. A copy of all compliance certification for Class I permits shall also be submitted to the EPA Administrator. 

[A.A.C. R18-2-309.2.d] 

CERTIFICATION OF TRUTH, ACCURACY AND COMPLETENESS [A.A.C. R18-2-309.3] 

Any document required to be submitted by this permit, including reports, shall contain a certification by a 

responsible official of truth, accuracy, and completeness. This certification and any other certification required 

under this part shall state that, based on information and beliefformed after reasonable inquiry, the statements 

and information in the document are true, accurate, and complete. 

XII. INSPECTION AND ENTRY [A.A.C. R18-2-309.4] 

Permittee shall allow the Director or the authorized representative of the Director upon presentation of proper 

credentials to: 

A. Enter upon Permittee's premises where a source is located or emissions-related activity is conducted, or 

where records are required to be kept under the conditions of the permit; 

B. Have access to and copy, at reasonable times, any records that are required to be kept under the conditions 

of the permit; 

C. Inspect, at reasonable times, any facilities, equipment (including monitoring and air pollution control 

equipment), practices, or operations regulated or required under the permit; 

D. Sample or monitor, at reasonable times, substances or parameters for the purpose of assuring compliance 

with the permit or other applicable requirements; and 

E. Record any inspection by use of written, electronic, magnetic and photographic media. 

XIII. PERMIT REVISION PURSUANT TO FEDERAL HAZARDOUS AIR POLLUTANT STANDARD 

If this source becomes subject to a standard promulgated by the Administrator pursuant to section 112(d) of 

the Act, then Permittee shall, within twelve months of the date on which the standard is promulgated, submit 

an application for a permit revision demonstrating how the source will comply with the standard. 

[A.A.C. R18-2-304.C] 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 7 of65 
XIV. REPORTING OF EXCESS EMISSIONS, PERMIT DEVIATIONS, AND EMERGENCIES 

A. EXCESS EMISSIONS REPORTING [A.A.C R18-2-310.01] 

1. Permittee shall report to the Director any emissions in excess of the limits established by this permit. 

The report shall be in two parts as specified below: 

a. Notification by telephone or facsimile within 24 hours of the time when Permittee first learned of 

the occurrence of excess emissions that includes all available information from XI.A.2 below. 

b. Detailed written notification by submission of an excess emissions report as described in XI.A.2 

below, within 72 hours of the notification paragraph a above. 

2. The excess emissions report shall contain the following information: 

a. The identity of each stack or other emission point where the excess emissions occurred; 

b. The magnitude of the excess emissions expressed in the units of the applicable emission limitation 

and the operating data and calculations used in determining the magnitude of the excess emissions; 

c. The date, time and duration or expected duration of the excess emissions; 

d. The identity of the equipment from which the excess emissions emanated; 

e. The nature and cause of the emissions; 

f. The steps taken, if the excess emissions were the result of a malfunction, to remedy the malfunction 

and the steps taken or planned to prevent the recurrence of the malfunctions; 

g. The steps that were or are being taken to limit the excess emissions; and 

h. If the source's permit contains procedures governing source operation during periods of startup or 

malfunction and the excess emissions resulted from startup or malfunction, a list of the steps taken 

to comply with the permit procedures. 

3. In the case of continuous or recurring excess emissions, the notification requirements of this subsection 

shall be satisfied if the source provides the required notification after excess emissions are first detected 

and includes in such notification an estimate of the time the excess emissions will continue. Excess 

emissions occurring after the estimated time period or changes in the nature of the emissions as 

originally reported shall require additional notification pursuant to XI.A.l and 2 above. 

B. PERMIT DEVIATIONS REPORTING [A.A.C. R18-2-306.A.5] 

1. Permittee shall promptly report deviations from permit requirements, including those attributable to 

upset conditions as defined in the permit, the probable cause of such deviations, and any corrective 

actions or preventive measures taken. Prompt reporting shall mean that the report was submitted to the 

Director by certified mail, facsimile, or hand delivery within two working days of the time when 

Permittee first learned of the occurrence of the deviations. 

2. All instances of deviations from permit requirements shall be clearly identified in the required 

semiannual monitoring report specified in Attachment "B" of this permit, and shall be certified by the 

responsible official. [A.A.C. R18-2-306.A.5.a] 

ASARCO -Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 8 of65 
C. EMERGENCY PROVISION [A.A.C. R18-2-306.E] 

1. An "emergency" means any situation arising from sudden and reasonably unforeseeable events beyond 

the control of the source, including acts of God, which situation requires immediate corrective action 

to restore normal operation, and that causes the source to exceed a technology-based emission limitation 

under the permit, due to unavoidable increases in emissions attributable to the emergency. An 

emergency shall not include noncompliance to the extent caused by improperly designed equipment, 

lack of preventative maintenance, careless or improper operation, or operator error. 

2. An emergency constitutes an affirmative defense to an action brought for noncompliance with such 

technology-based emission limitations if the conditions of paragraph 3 ofthis subsection are met. 

3. The affirmative defense of emergency shall be demonstrated through properly signed, contemporaneous 

operating logs, or other relevant evidence that: 

a. An emergency occurred and that Permittee can identify the cause(s) of the emergency; 

b. The permitted facility was at the time being properly operated; 

c. During the period of the emergency, Permittee took all reasonable steps to minimize levels of emissions that exceeded the emissions standards or other requirements in the permit; and 

d. Permittee submitted notice of the emergency to the Director by certified mail, facsimile, or hand 

delivery within two working days of the time when emission limitations were exceeded due to the 

emergency. This notice shall contain a description of the emergency, any steps taken to mitigate 

emissions, and corrective action taken. 

4. In any enforcement proceeding, Permittee seeking to establish the occurrence of an emergency has the 

burden of proof. 

5. This provision is in addition to any emergency or upset provision contained in any applicable 

requirement. 

D. COMPLIANCE SCHEDULE 

For any excess emissions or permit deviations that cannot be corrected within 72 hours, Permittee is 

required to submit a compliance schedule to the Director within 21 days of such occurrence. The 

compliance schedule shall include a schedule of remedial measures, including an enforceable sequence 

of actions with milestones, leading to compliance with the permit terms or conditions that have been 

violated. [A.R.S. §426.1.5] 

XV. RECORD KEEPING REQUIREMENTS [A.A.C. R18-2-306.A.4 and 313.E.6] 

A. Permittee shall keep records of all required monitoring information including, but not limited to, the 

following: 

1. The date, place as defined in the permit, and time of sampling or measurements; 

2. The date(s) analyses were performed; 

3. The name of the company or entity that performed the analyses; 

4. A description of the analytical techniques or methods used; 

5. The results of such analyses; and 

6. The operating conditions as existing at the time of sampling or measurement. 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 9 of65 
· B. Permittee shall retain records of all required monitoring data and support information for a period of at 

least 5 years from the date of the monitoring sample, measurement, report, or application. Support 

information includes all calibration and maintenance records and all original strip-chart recordings or other 

data recordings for continuous monitoring instrumentation, and copies of all reports required by the permit. 

XVI. REPORTING REQUIREMENTS [A.A.C. R18-2-306.A.5.a] 

Permittee shall submit the following reports: 

A. Compliance certifications in accordance with Section VII of Attachment "A". 

B. Reports of excess emissions, permit deviations, and emergencies in accordance with Section XI of 

Attachment "A". 

C. Other reports required in "Monitoring, Recordkeeping and Reporting Requirements" subsections of 

Attachment "B". 

XVII. DUTY TO PROVIDE INFORMATION [A.A.C. R18-2-304.G and 306.A.8.e] 

A. Permittee shall furnish to the Director, within a reasonable time, any information that the Director may 

request in writing to determine whether cause exists for revising, revoking and reissuing, or terminating 

the permit or to determine compliance with the permit. Upon request, Permittee shall also furnish to the 

Director copies of records required to be kept by the permit. For information claimed to be confidential, 

Permittee shall furnish an additional copy of such records directly to the Administrator along with a claim 

of confidentiality. 

B. If Permittee has failed to submit any relevant facts or if Permittee has submitted incorrect information in 

the permit application, Permittee shall, upon becoming aware of such failure or incorrect submittal, 

promptly submit such supplementary facts or corrected information. 

XVIII. PERMIT AMENDMENT OR REVISION [A.A. C. R18-2-318, 319 and 320] 

Permittee shall apply for a permit amendment or revision for changes to the facility which do not qualify for 

a facility change without revision under Section XVI, as follows: 

A. Administrative Permit Amendment (A.A. C. R18-2-318); 

B. Minor Permit Revision (A.A. C. R18-2-319); 

C. Significant Permit Revision (A.A.C. R18-2-320). 

The applicability and requirements for such action are defined in the above referenced regulations. 

XIX. FACILITY CHANGE WITHOUT PERMIT REVISION [A.A.C. R18-2-317] 

A. Permittee may make changes at the permitted source without a permit revision if all of the following apply: 

1. The changes are not modifications under any provision of Title I of the Act or under A.R.S. § 49-

401.01(19). 

2. The changes do not exceed the emissions allowable under the permit whether expressed therein as a 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 10 of65 
rate of emissions or in terms of total emissions. 

3. The changes do not violate any applicable requirements or trigger any additional applicable 

requirements. 

4. The changes satisfy all requirements for a minor permit revision under R18-2-319(A). 

5. The changes do not contravene federally enforceable permit terms and conditions that are monitoring 

(including test methods), recordkeeping, reporting, or compliance certification requirements. 

B. The substitution of an item of process or pollution control equipment for an identical or substantially 

similar item of process or pollution control equipment shall qualify as a change that does not require a 

permit revision, if it meets all of the requirements of subsections (A) and (C) of this Section. 

C. For each such change under subsections A and B of this Section, a written notice by certified mail or hand 

delivery shall be received by the Director and, for Class I permits, the Administrator, a minimum of 7 

working days in advance of the change. Notifications of changes associated with emergency conditions, 

such as malfunctions necessitating the replacement of equipment, may be provided less than 7 working 

days in advance of the change but must be provided as far in advance of the change as possible or, if 

advance notification is not practicable, as soon after the change as possible. Each notification shall 

include: 

1. When the proposed change will occur. 

2. A description of each such change. 

3. Any change in emissions of regulated air pollutants. 

4. The pollutants emitted subject to the emissions trade, if any. 

5. The provisions in the implementation plan that provide for the emissions trade with which the source 

will comply and any other information as may be required by the provisions in the implementation plan 

authorizing the trade. 

6. If the emissions trading provlSlons of the implementation plan are invoked, then the permit 

requirements with which the source will comply. 

7. Any permit term or condition that is no longer applicable as a result of the change. 

XX. PERFORMANCE TESTING REQUIREMENTS [A.A.C. R18-2-312] 

A. Permittee shall conduct performance tests as specified in the permit and at such other times as may be 

required by the Director. 

B. Operational Conditions During Testing 

Performance tests shall be conducted under such conditions as the Director shall specify to the plant 

operator based on representative performance of the source. Permittee shall make available to the Director 

such records as may be necessary to determine the conditions of the performance tests. Operations during 

start-up, shutdown, and malfunction shall not constitute representative operational conditions unless 

otherwise specified in the applicable standard. 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 11 of65 
C. Performance tests shall be conducted and data reduced in accordance with the test method and procedures 

contained in the Arizona Testing Manual unless modified by the Director pursuant to A.A.C. R 18-2-312 .B. 

D. Performance Test Plan 

At least 14 calendar days prior to performing a test, the owner or operator shall submit a test plan to the 

Director, in accordance with A.A.C. R18-2-312.B and the Arizona Testing Manual. This test plan must 

include the following: 

1. test location(s); 

2. test method(s); and 

3. source operation and other parameters that may affect test results. 

E. Stack Sampling Facilities 

Permittee shall provide or cause to be provided, performance testing facilities as follows: 

1. Sampling ports adequate for test methods applicable to the facility; 

2. Safe sampling platforms; 

3. Safe access to sampling platforms; and 

4. Utilities for sampling and testing equipment. 

F. Interpretation of Final Results 

Each performance test shall consist of three separate runs using the applicable test method. Each run shall 

be conducted in accordance with the applicable standard and test method. For the purpose of determining 

compliance with an applicable standard, the arithmetic means of results of the three runs shall apply. If 

a sample is accidentally lost or conditions occur which are not under the Permittee's control and which may 

invalidate the run, compliance may, upon the Director's approval, be determined using the arithmetic mean 

of the other two runs. If the Director, or Director's designee, is present, tests may only be stopped with 

the Director's or such designee's approval. If the Director or the Director's designee is not present, tests 

may only be stopped for good cause. Good cause includes, forced shutdown, failure of an irreplaceable 

portion of the sample train, extreme meteorological conditions or other conditions beyond the Permittee's 

control. Termination of any test without good cause after the first run is commenced shall constitute a 

failure of the test. Supporting documentation which demonstrates good cause must be submitted with the 

test report. 

G. Report of Final Test Results 

A written report of the results of all performance tests shall be submitted to the Director within 3 0 days 

after the test is performed. The report shall be submitted in accordance with the Arizona Testing Manual 

and A.A.C. R18-2-312.A. 

XXI. PROPERTY RIGHTS [A.A.C. R18-2-306.A.8.d] 

This permit does not convey any property rights of any sort, or any exclusive privilege. 

XXII. SEVERABILITY CLAUSE [A.A.C. R18-2-306.A.7] 

The provisions of this permit are severable. In the event of a challenge to any portion of this permit, or if any 

portion of this permit is held invalid, the remaining permit conditions remain valid and in force. 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 12 of65 
XXIII. PERMIT SHIELD [A.A.C. R18-2-325] 

Compliance with the conditions of this permit shall be deemed compliance with the applicable requirements 

identified in the portions of this permit subtitled "Permit Shield". The permit shield shall not apply to any 

changes made pursuant to Section XV .B of this Attachment and Section XVI of this Attachment. 

XXIV. ACCIDENTAL RELEASE PROGRAM 

If this source becomes subject to the provisions of 40 CFR Part 68, then Permittee shall comply with these 

provisions according to the time line specified in 40 CFR Part 68. [40 CFR 68] 

XXV. PROTECTION OF STRATOSPHERIC OZONE 

If this source becomes subject to the provisions of 40 CFR Part 82, then Permittee shall comply with these 

provisions accordingly. [40 CFR 82] 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 13 of65 
ATTACHMENT "B": SPECIFIC CONDITIONS 

Air Quality Control Permit No. 1000042 

For 

ASARCO Incorporated- Ray Complex Hayden Smelter 

I. GENERAL 

A. Abbreviations 

1. "A.A. C. R18-2-xyz" stands for the Arizona Administrative Code, Title 18, Chapter 2, Article x, Section 

xyz. 

2. "A.R.S. §49-xyz" stands for the Arizona Revised Statutes, Title 49, Section xyz. 

3. "CFR" means the Code ofFederal Regulations, with standard references in this permit by Title and Part, 

so that "40 CFR 60" means "Title 40 of the Code of Federal Regulations, Part 60." 

4. "NSPS" stands for the Standards of Performance for New Stationary Sources required under 40 CFR 

60. 

5. "COMS" stands for a continuous opacity monitoring system. 

6. "CEMS" stands for a continuous emission monitoring system. 

7. "ESP" stands for an electrostatic precipitator. 

8. "SIP" stands for the state implementation plan. 

B. The permit conditions or portions of the permit conditions which are material pursuant to A.A. C. R18-2-3 31 

and A.R.S. §49-464 are indicated by double underlined and italicized print. 

C. Definitions 

1. "Process source" means the last operation or process which produces an air contaminant resulting from 

either: [A.A.C. R18-2-701(22)] 

a. The separation of the air contaminants from the process material, or 

b. The conversion of constituents of the process materials into air contaminants which is not an air 

pollution abatement operation. 

2. "Fugitive emissions" means those emissions which could not reasonably pass through a stack, chimney, 

vent, or other functionally equivalent opening. [A.A.C. R18-2-101(49)] 

3. "Non point source" means a source of air contaminants which lacks an identifiable plume or emission 

point. [A.A.C. R18-2-101(77)] 

4. "High sulfur oil" means fuel oil containing 0.90% or more by weight of sulfur. [A.A.C. R18-2-701(14)] 

5. "Low sulfur oil" means fuel oil containing less than 0.90% by weight of sulfur. [A.A.C. R18-2-701(16)] 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 14 of 65 
D. For the purpose of this permit, the EPA Reference Method 9 reading shall be defined as an average of24 

consecutive opacity observations recorded at 15-second intervals. A set is composed of any 24 consecutive 

observations. Sets need not be consecutive in time and in no case shall two sets overlap. For each set of 

24 observations, calculate the average by summing the opacity of the 24 observations and dividing this sum 

by 24. [A.A. C. R18-2-306.A.3.c and 40 CFR 60, Appendix A, Method 9, Section 2.5] 

E. Unless otherwise specified in the applicable section of this Attachment, Permittee shall only use natural gas 

fuel for operation of the flash furnace burners, converters, concentrate dryers, and anode furnaces, except 

for natural gas curtailment periods when the natural gas is not available. During the curtailment periods, 

Permittee shall be allowed to use low sulfur fuel as emergency backup to firing the concentrate dryers and 

anode furnaces. For the purpose of this paragraph, the curtailment periods shall not include durations when 

the natural gas market price is considered high for any reason. [Installation Permit No. 1166] 

F. Within 180 days of issuance of this permit, Permittee shall have on staff a person that is certified in EPA 

Reference Method 9. [A.A.C. R18-2-306.A.3.c] 

G. At the time the compliance certifications required by Section VII of Attachment "A" are submitted, 

Permittee shall submit summary reports of any monitoring required in this Attachment and performed in 

the six months prior to the date of the report. All instances of deviations from requirements of the permit 

shall be clearly identified in the reports. [A.A.C. R18-2-306.A.5.a] 

II. AFFECTED FACILITIES GOVERNED BY THE NEW SOURCE PERFORMANCE STANDARDS 

A. General Provisions of the Section 

1. Applicability 

The requirements of this section are applicable to the following affected facilities: Nos. 1 and 2 Fuller 

fluid bed dryers, and the portion of the In co oxygen flash furnace that uses the Monsanto sulfuric acid 

plant to comply with the sulfur dioxide standard set forth in II.B.3 of this section. 

2. Definitions 

a. "Startup" means the setting in operation of an affected facility of this section for any purpose. 

[40 CFR 60.2] 

b. "Shutdown" means the cessation of operation of an affected facility of this section for any purpose. 

[40 CFR 60.2] 

c. "Malfunction" means any sudden, infrequent, and not reasonably preventable failure of air pollution 

control equipment, process equipment, or a process to operate in a normal or usual manner. Failures 

that are caused in part by poor maintenance or careless operation are not malfunctions. 

[40 CFR 60.2] 

3. For the purpose of this permit, compliance with standards in this section, other than opacity standards, 

shall be determined in accordance with performance tests. The performance tests shall be conducted and 

data reduced in accordance with the test methods and procedures contained in subsection E of this 

section, "Performance Testing Requirements". [ 40 CFR 60.11 (a) and 60.8(b )] 

4. For the purpose of this permit, compliance with an opacity standard in this section shall be determined 

by conducting observations in accordance with EPA Reference Method 9 in 40 CFR Part 60, Appendix 

A, or any alternative method that is approved by the Director, or as provided in paragraph 5 below. 

[40 CFR 60.11(b)] 

ASARCO -Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 15 of65 
5. Permittee may submit, for purposes of compliance with an opacity standard in this section, COMS data 

results produced during any performance test required under this section in lieu of the Method 9 

observation data. Permittee using a COMS for compliance purposes is responsible for demonstrating 

that the COMS meets the requirements specified in 40 CFR 60.13(c), that the COMS has been properly 

maintained and operated, and that the resulting data have not been altered in any way. 

[40 CFR 60.11(e)(5)] 

6. Permittee shall maintain and operate any affected facilities of this section, including associated air 

pollution control equipment, in accordance with the particular requirements specified under subsection 

II.C, "Air Pollution Control Requirements". Determination of whether acceptable operating and 

maintenance procedures are being used for these facilities shall be based on information available to the 

Director which may include, but is not limited to, monitoring results, opacity observations, review of 

operating and maintenance procedures, and inspection of the source. [40 CFR 60.11(d)] 

7. For the purpose of submitting compliance certifications or establishing whether or not Permittee has 

violated or is in violation of any standard in this section, nothing in this section shall preclude the use, 

including the exclusive use, of any credible evidence or information, relevant to whether a source would 

have been in compliance with such standards if the appropriate performance or compliance test or 

procedure had been performed. [40 CFR 60.ll(g)] 

B. Emission limits and Standards 

1. Furnace/Dryers Visible Emissions Standard 

At all times except fOr periods o(startup. shutdown. and malfunction as defined in paragraphs IlA. 2.a. b 

and c ofthis Section. Permittee shall not cause to be discharged into the atmosphere from the furnace 

and/or anv drvers o(this section, anv visible emissions which exhibit greater than 20 percent opacity 

Opacity readings ofportions ofplumes which contain condensed uncombined water vapor shall not be 

used for purposes of determining compliance with the opacity standard 

[40 CFR 60.164(a) and (b), 60.11(c) and 60.11(e)(1)] 

2. Dryers Particulate Matter Standard 

Permittee shall not cause to be discharged into the atmosphere from any dryer of this section any gases 

which contain particulate matter in excess of 50 mg/dscm (0.022 gr/dscf). Emissions in excess of the 

level of the applicable emission limit during periods of startup, shutdown, and malfunction shall not be 

considered a violation of the applicable emission limit. [40 CFR 60.8(c) and 60.162(a)] 

3. Furnace Sulfur Dioxide Standard 

Permittee shall not cause to be discharged into the atmosphere from the Inca oxygen flash furnace any 

gases which contain sulfur dioxide in excess of 0.065 percent by volume. Emissions in excess of the 

level of the applicable emission limit during periods of startup, shutdown, and malfunction shall not be 

considered a violation of the applicable emission limit. [40 CFR 60.8(c) and 60.163(a)] 

C. Air Pollution Control Requirements 

1. Particulate Matter Control for Dryers [40 CFR 60.ll(d)] 

Permittee shall operate the R&R Cottrell ESP. At all times, including periods of startup, shutdown, and 

malfunction, Permittee shall, to the extent practicable, continue to operate and maintain the two Fuller 

fluid bed dryers, their product baghouses and the R&R Cottrell ESP in a manner consistent with good 

air pollution control practice for minimizing particulate matter emissions. 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 16 of65 
2. Sulfur Dioxide Control [40 CFR 60.11(d) and 60.164(b)] 

Permittee shall operate the Monsanto sulfuric acid plant to comply with the furnace sulfur dioxide 

standard of 0.065 percent by volume set forth in II.B.3. At all times, including periods of startup, 

shutdown, and malfunction, Permittee shall, to the extent practicable, continue to operate and maintain 

the Inco oxygen flash furnace and the Monsanto sulfuric acid plant in a manner consistent with good air 

pollution control practice for minimizing sulfur dioxide emissions. 

D. Monitoring, Recordkeeping and Reporting Requirements 

1. Visible Emissions Monitoring 

a. Dryer opacity monitor 

Permittee shall operate the R&R flue COMS installed at the outlet of the R&R Cottrell ESP to 

monitor and record the opacity of gases discharged into the atmosphere from any dryer of this section. 

The s~an of this system shall be set at 80 to 100 percent opacity. [ 40 CFR 60.165(b)(1)] 

b. Acid plant tail gas opacity monitor 

Permittee shall employ the COMS installed at the acid plant tail gas monitoring station for the 

purpose of performing periodic monitoring of visible emissions from the Inco oxygen flash furnace. 

[A.A.C. R18-2-306.A.3.c] 

c. All the COMS under this section shall meet 40 CFR 60, Appendix B, "Performance Specification 1 -

Specification and Test Procedures for Opacity Continuous Emission Monitoring Systems in 

Stationary Sources": [40 CFR 60.13(c) and A.A. C. R18-2-306.A.3.c] 

( 1) Apparatus 

(2) Installation Specifications 

(3) Design and Performance Specifications 

( 4) Design Specifications Verification Procedure 

( 5) Performance Specifications Verification Procedure 

( 6) Equations 

d. All the COMS under this section shall meet the following quality assurance requirements: 

(1) Calibration checks [40 CFR 60.13(d)(1) and A.A. C. R18-2-306.A.3.c] 

Permittee shall check the zero (or low-level value between 0 and 20% of span value) and span 

(50 to 100 percent of span value) calibration drifts at least once daily in accordance with a written 

procedure prescribed by the manufacturer. 

(2) Zero and span drift adjustments [40 CFR 60.13(d)(1) and A.A. C. R18-2-306.A.3 .c] 

(a) The zero and span shall, as a minimum, be adjusted whenever the 24-hr zero drift or 24-hr 

span drift exceeds 4% opacity. 

(b) The system shall allow for the amount of excess zero and span drift measured at the 24-hour 

interval checks to be recorded and quantified. 

(c) The optical surfaces exposed to the effluent gases shall be cleaned prior to performing the 

zero and span drift adjustments, except for systems using automatic zero adjustments. 

(d) For systems using automatic zero adjustments, the optical surfaces shall be cleaned when the 

ASARCO - Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 17 of65 

I 
cumulative automatic zero compensation exceeds 4% opacity. 

(3) System checks [40 CFR 60.13(d)(2) and A.A. C. R18-2-306.A.3.c] 

Permittee shall, as minimum procedures, apply a method for producing a simulated zero opacity 

condition and an upscale (span) opacity condition using a certified neutral density filter or other 

related technique to produce a known obscuration of the light beam. All procedures applied shall 

provide a system check of the analyzer internal optical surfaces and all electronic circuitry 

including the lamp and photodetector assembly. 

( 4) Minimum frequency of operation [40 CFR 60.13(e)(1) and A.A.C. R18-2-306.A.3.c] 

Except during periods of system breakdowns, repairs, calibration checks, and zero and span 

adjustments, the COMS shall be in continuous operation and shall complete a minimum of one 

cycle of sampling and analyzing for each successive 1 0-second period and one cycle of data 

recording for each successive 6-minute period. 

(5) Data reduction procedures [40 CFR 60.13(h) and A.A. C. R18-2-306.A.3.c] 

(a) Permittee shall reduce all data from the COMS to 6-minute averages. Six-minute opacity 

averages shall be calculated from 36 or more data points equally spaced over each 6-minute 

period. 

(b) Data recorded during periods of system breakdowns, repairs, calibration checks, and zero and 

span adjustments shall not be included in the data averages computed under the previous 

paragraph. An arithmetic or integrated average of all data may be used. 

2. Tail Gas Sulfur Dioxide Monitoring 

a. Permittee shall operate the S02 CEMS installed at the acid plant tail gas monitoring station to monitor 

and record S02 emissions discharged into the atmosphere from the Inco oxygen flash furnace. The 

span of this system shall be set at a sulfur dioxide concentration of 0.20 percent by volume. 

[40 CFR 60.165(b)(2)] 

b. Permittee shall, on a daily basis, calculate and record six-hour average sulfur dioxide concentrations 

for the four consecutive 6-hour periods of each operating day. Each six-hour average shall be 

determined as the arithmetic mean of the appropriate six contiguous one-hour average sulfur dioxide 

concentrations provided by the S02 CEMS of paragraph a above. [40 CFR 60.165(c)] 

c. Permittee shall determine compliance with the S02 emission standard of 0.065 percent by volume 

specified in paragraph II.B.3 of this section, using the S02 CEMS of paragraph a above to determine 

the S02 concentrations on a dry basis. The sampling time for each run shall be 6 hours, and the 

average S02 concentration shall be computed for the 6-hour period as in paragraph b above. The 

monitoring system drift during the run shall not exceed 2 percent of the span value. 

[40 CFR 60.166(b)(2)] 

d. The S02 CEMS shall meet 40 CFR Part 60, Appendix B, "Performance Specification 2 -

Specifications and Test Procedures for S02 and NOx Continuous Emission Monitoring Systems in 

Stationary Sources": [40 CFR 60.13(a)] 

(1) Installation and Measurement Location Specifications 

(2) Performance and Equipment Specifications 

(3) Performance Specification Test Procedure 

(4) The CEMS Calibration Drift Test Procedure 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 18 of65 
(5) Relative Accuracy Test Procedure 

( 6) Equations 

e. Permittee shall develop and implement a quality control (QC) program for the S02 CEMS. As a 

minimum, the QC program shall include written procedures which should describe in detail, 

complete, step-by-step procedures and operations for each of the following activities: 

[A.A. C. R18-2-312.H.3 and 40 CFR 60, Appendix F.3] 

(1) Calibration ofCEMS. 

(2) Calibration drift determination and adjustment of CEMS. 

(3) Preventive maintenance ofCEMS (including spare parts inventory). 

( 4) Data recording, calculations, and reporting. 

(5) Accuracy audit procedures including sampling and analysis methods. 

(6) Program of corrective action for malfunctioning CEMS. 

f. The S02 CEMS shall meet the following quality assurance requirements: 

( 1) Calibration drift checks 

Permittee shall check the zero (or low-level value between 0 and 20% of span value) and span 

(50 to 1 00 percent of span value) calibration drifts (CD) at least once daily in accordance with 

a written procedure prescribed by the manufacturer. The pollutant gas used to prepare the 

calibration gas mixtures for the calibration drift checks shall be sulfur dioxide. 

[ 40 CFR 60.13( d)(l) and 165(b )(2)(ii)] 

(2) Zero and span drift adjustments 

(a) The zero and span shall, as a minimum, be adjusted whenever the 24-hr zero drift or 24-hr 

span drift exceeds 100 ppm. [40 CFR 60.13(d)(1)] 

(b) The S02 CEMS shall allow for the amount of excess zero and span drift measured at the 24-

hour interval checks to be recorded and quantified. If the data are automatically adjusted to 

the corrected calibration values (e.g., microprocessor control), Permittee shall program the 

S02 CEMS to record the unadjusted concentration measured in the calibration drift prior to 

resetting the calibration, if performed, or record the amount of adjustment. 

[A.A. C. R18-2-312.H.3, 40 CFR 60.13(d)(1), 166(b) and Appendix F.4.2] 

(c) If the S02 CEMS is out-of-control in terms of the CD exceedance as defined in 40 CFR 60, 

Appendix F.4.3, Permittee shall take necessary corrective action. Following corrective 

action, Permittee shall repeat the CD checks as described in paragraph II.D.2.f.(l). 

[A.A. C. R18-2-312.H.3, 40 CFR 60.166(b) and Appendix F.4.3] 

(3) Minimum frequency of operation [40 CFR 60.13(e)(2)] 

Except during periods of system breakdowns, repairs, calibration checks, and zero and span 

adjustments, the S02 CEMS shall be in continuous operation and shall complete a minimum of 

one cycle of operation (sampling, analyzing, and data recording) for each successive 15-minute 

period. 

( 4) Data reduction procedures [ 40 CFR 60.13(h)] 

(a) Permittee shall reduce all data from the S02 CEMS to 1-hour averages. The 1-hour averages 

shall be computed from four or more data points equally spaced over each 1-hour period. 

(b) Data recorded during periods of continuous system breakdowns, repairs, calibration checks, 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 19 of65 
and zero and span adjustments shall not be included in the data averages computed under the 

previous paragraph. An arithmetic or integrated average of all data may be used. The data 

may be recorded in reduced or non-reduced form (e.g., ppm pollutant and percent 0 2 or ng/J 

of pollutant). 

(5) Excessive audit inaccuracy 

If the S02 CEMS is out-of-control in terms of the excessive audit inaccuracy as defined in 40 

CPR Part 60, Appendix F.5.2.3, Permittee shall take necessary corrective action to eliminate the 

problem. Following corrective action, Permittee shall audit the CEMS with a relative accuracy 

test audit, cylinder gas audit, or relative accuracy audit, as prescribed in II.E.3 of this section, to 

determine if the CEMS is operating within the performance specifications referenced in 

paragraph II.D.2.d. [A.A.C. R18-2-312.H.3, 40 CFR 60.166(b) and 40 CFR Part 60, Appendix F.5.2] 

( 6) Repeated excessive inaccuracy 

Whenever excessive inaccuracies as defined in 40 CPR Part 60, Appendix F .5 .2.3 occur for two 

consecutive quarters, Permittee shall revise the written procedures as described in II.D.2.e, or 

modify or replace the S02 CEMS to correct the deficiency causing the repeated excessive 

inaccuracy. [A.A. C. R18-2-312.H.3, 40 CFR 60.166(b) and 40 CFR Part 60, Appendix F.5.3] 

3. Dryers Particulate Matter Monitoring 

Permittee shall evaluate opacity measurements from the R&R flue COMS on a 24-hour rolling average 

excluding periods of startup, shutdown, and malfunction. If the 24-hour rolling average opacity exceeds 

15 percent, Permittee shall initiate investigation of the relevant controls or equipment within 24 hours 

of the first discovery of the high opacity incident and, if necessary, take corrective action as soon as 

practicable to adjust or repair the controls or equipment to reduce the opacity average to below the 15 

percent level. [A.A.C. R18-2-306.A.3.c] 

4. Recordkeeping and Reporting Requirements 

a. Permittee shall maintain records of the occurrence and duration of any startup, shutdown, or 

malfunction in the operation of an affected facility under this Section; any malfunction of the air 

pollution control equipment; or any periods during which a continuous monitoring system or 

monitoring device is inoperative. [40 CFR 60.7(b)] 

b. Permittee shall maintain a file of all measurements, including continuous monitoring system, 

monitoring device, and performance testing measurements; all continuous monitoring system 

performance evaluations; all continuous monitoring system or monitoring device calibration checks; 

adjustments and maintenance performed on these systems or devices; and all other information 

required by this section recorded in a permanent form suitable for inspection. The file shall be 

retained for at least five years following the date of such measurements, maintenance, reports and 

records. [40 CFR 60.7(f) and A.A.C. R18-2-306(A)(4)(b)] 

c. Quarterly excess emissions and monitoring systems performance reports 

( 1) Permittee shall submit an excess emissions and monitoring systems performance (MSP) report 

and/or a summary report form to the Department for every calendar quarter, unless the total 

duration of excess emissions for the reporting period is less than 1 percent of the total operating 

time for the reporting period and the continuous monitoring system downtime for the reporting 

period is less than 5 percent of the total operating time for the reporting period, in which case 

only the summary report form shall be submitted and the excess emissions report need not be 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 20 of65 
submitted unless requested by the Department. All quarterly reports shall be postmarked by the 

30th day following the end of each calendar quarter. [40 CFR 60.7(c) and (d)] 

(2) The summary report form submission required in the preceding paragraph (1) shall be in the 

format specified in 40 CFR 60.7(d). Each excess emission and MSP report shall include the 

following information: [40 CFR 60.7(c)] 

(a) The magnitude of excess emissions computed, any conversion factor(s) used, and the date 

and time of commencement and completion of each time period of excess emissions. The 

process operating time during the reporting period. 

(b) Specific identification of each period of excess emissions that occurs during startups, 

shutdowns, and malfunctions of the affected facility. The nature and cause of any 

malfunction (if known), the corrective action taken or preventative measures adopted. 

(c) The date and time identifying each period during which the continuous monitoring system 

was inoperative except for zero and span checks and the nature of the system repairs or 

adjustments. 

(d) When no excess emissions have occurred or the continuous monitoring system(s) have not 

been inoperative, repaired, or adjusted, such information shall be stated in the report. 

(3) Definitions 

Periods of excess emissions that shall be reported under II.D.4.c( 1) and (2) above are defined as 

follows: 

(a) Opacity 

Opacity excess emissions are defined as any six-minute period during which the average 

opacity, as measured by the COMS as in paragraph II.D.l.a and/or paragraph II.D.l.b, 

exceeds the 20 percent opacity standard, as specified in paragraph II.B.l. 

[ 40 CFR 60.165( d)( 1) and A.A. C. R18-2-306.A.3.c] 

(b) Sulfur Dioxide 

S02 excess emissions are defined as any six-hour period during which the average S02 

emissions, as measured by the S02 CEMS as in paragraph II.D.2.a, exceed the level of the 

standard of 0. 065 percent by volume, as specified in paragraph II.B .3. The Director shall not 

consider emissions in excess of the level of the standard for less than or equal to 1.5 percent 

of the six-hour periods during the quarter as indicative of a potential violation of paragraph 

II.A.6, provided the affected facilities of this section, including air pollution control 

equipment, are maintained and operated in a manner consistent with good air pollution 

control practice for minimizing emissions during these periods. Emissions in excess of the 

level of the standard during periods of startup, shutdown, and malfunction shall not be 

included within the 1.5 percent. [40 CFR 60.165(d)(2)] 

d. Data Assessment Report [A.A.C. R18-2-312.H.3 and 40 CFR Part 60, Appendix F.7] 

Along with the quarterly reporting submittal described in subsection II.D.4.c, Permittee shall also 

report the drift and accuracy information as a Data Assessment Report (DAR), and include one copy 

of this DAR for each quarterly audit for the S02 CEMS. The DAR shall, as a minimum, contain the 

following information: 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 21 of65 
(1) Permittee name and address. 

(2) Identification and location of monitors in the CEMS. 

(3) Manufacturer and model number of each monitor in the CEMS. 

( 4) Assessment of CEMS data accuracy and date of assessment as determined by a relative accuracy 

test audit (RATA), relative accuracy audit (RAA), or cylinder gas audit (CGA) required under 

subsection II.EJ including the relative accuracy for the RATA, accuracy of the CEMS for the 

RAA or CGA, reference method results, cylinder gases certified values, CEMS responses, and 

calculations results as defined in 40 CFR Part 60, Appendix F, Section 6. If the accuracy audit 

results show the CEMS to be out-of-control as described in paragraph II.D.2.f(5), Permittee shall 

report both the audit results showing the CEMS to be out-of-control and the results of the audit 

following corrective action showing the CEMS to be operating within specifications. 

(5) Results from EPA performance audit samples and the applicable reference methods. 

( 6) Summary of all corrective actions taken when CEMS was determined out-of-control, as described 

in paragraphs II.D.2.f(2)(c) and II.D.2.f(5). 

e. Permittee shall log in ink or electronic format and maintain a record of24-hour opacity measurements 

performed in accordance with II.DJ and corrective actions taken, if any. A record of corrective 

actions taken shall include the date and time during which the 24-hour rolling average opacity 

exceeded 15 percent and the date, time and type of the corrective actions. [A.A.C. R18-2-306.A.3.c] 

f. Emission deviations reporting requirements 

In addition to the quarterly reporting required under subsection II.D.4.d of this section, Permittee 

shall report emissions exceeding an emission limitation or standard as deviations in accordance with 

Section XI.B of Attachment "A" of this permit. [A.A.C. R18-2-306.A.5.b] 

E. Performance Testing Requirements 

1. Furnace/Dryers Opacity Observation 

Permittee shall perform an annual opacity observation of emissions from the In co oxygen flash furnace 

and Nos. 1 and 2 fluid bed dryers in accordance with EPA Reference Method 9 to determine compliance 

with the visible emission standard of20 percent opacity specified in paragraph II.B.l. 

[40 CFR 60.166(b)(3)] 

2. Dryers Particulate Matter Emissions Testing 

Permittee shall determine compliance with the dryer particulate matter standard of 0.022 gr/dscf in 

paragraph II.B.2, using EPA Reference Method 5 testing annually at R&R flue to determine the 

particulate matter concentration. The sampling time and sample volume for each run shall be at least 

60 minutes and 0.85 dscm (30 dscf). [40 CFR 60.166(b)(l)] 

3. S02 CEMS Auditing 

Permittee shall conduct audits for the S02 CEMS of paragraph II.D.2.a, at least once each calendar 

quarter. Successive quarterly audits shall occur no closer than 2 months. The audits shall be conducted 

as follows: [A.A.C. R18-2-312.H.3, 40 CFR 60.166(b) and 40 CFR 60, Appendix F.5.1] 

a. Relative accuracy test audit (RATA) [ 40 CFR 60.165(b)(2)(ii) and Appendix F.5.1.1] 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 22 of65 
Permittee shall conduct the RATA at least once every four calendar quarters in accordance with the 

relative accuracy test procedures specified in 40 CFR 60, Appendix B, Performance Specification 2, 

Section 7. EPA Reference Methods 3B, 4, and 6, or their approved alternatives, shall be used in 

conducting the RAT A tests. In addition, Permittee shall analyze the appropriate performance audit 

samples received from EPA as described in the Method 6. 

b. Cylinder gas audit (CGA) [40 CPR 60, Appendix P.5.1.2] 

Permittee shall conduct a CGA in three of four calendar quarters, but in no more than three quarters 

in succession in accordance with the procedures as specified in 40 CFR 60, Appendix F.5.1.2. 

c. Relative accuracy audit (RAA) [40 CPR 60, Appendix P.5.1.3] 

As an alternative to CGA, Permittee may conduct the RAA in three of four calendar quarters, but in 

no more than three quarters in succession. To conduct a RAA, Permittee shall follow the relative 

accuracy test procedures as specified in 40 CFR 60, Appendix B, Performance Specification 2, 

Section 7, except that only three sets of measurement data are required. Analyses of EPA 

performance audit samples are also required. Audit samples are available upon request. 

F. Permit Shield 

Compliance with the terms of this section shall be deemed compliance with the following applicable 

requirement(s) in effect on the date of permit issuance: 40 CFR 60.7(b), 40 CFR 60.7(c), 40 CFR 60.7(d), 

40 CFR 60.7(f), 40 CFR 60.8(b), 40 CFR 60.8(c), 40 CFR 60.11(a), 40 CFR 60.11(b), 40 CFR 60.11(c), 

40 CFR 60.11(d), 40 CFR 60.11(e)(l), 40 CFR 60.11(e)(5), 40 CFR 60.11(g), 40 CFR 60.13(a), 40 CFR 

60.13(d), 40 CFR60.13(e)(l), 40 CFR60.13(e)(2), 40 CFR60.13(h), 40 CFR60.162(a), 40 CFR60.163(a), 

40 CFR 60.164(a), 40 CFR 60.164(b), 40 CFR 60.165(b), 40 CFR 60.165(c), 40 CFR 60.165(d), 40 CFR 

60.166, and A.A.C. R18-2-312.H.3. 

III. PROCESS SOURCES GOVERNED BY THE MULTI-POINT ROLLBACK RULE 

A. General Provisions of the Section 

1. Applicability 

The requirements of this section are applicable to the sulfur dioxide emissions plant wide. 

2. Definitions 

a. An "operating day", for the purpose of this section, means any day in which sulfur containing feed 

is introduced into the smelting process. [A.A.C. R18-2-715.01(J)] 

b. "Compliance period", for the purposes of this section, means the 365 calendar days immediately 

preceding the end of each day of the month being reported unless that period includes less than 300 

operating days. In such case the number of days preceding the last day of the compliance period shall 

be increased until the compliance period contains 300 operating days. [A.A.C. R18-2-715.01(J)] 

B. Emission Limitations and Standards 

1. Annual average sulfur dioxide emissions [A.A.C. R18-2-715(P)(2)(a)] 

Annual average S02 emissions shall not exceed 9,521 pounds per hour. 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 23 of65 
2. Allowable sulfur dioxide emissions profile [A.A.C. R18-2-715(F)(2)(b)] 

The number of three-hour average emissions shall not exceed n cumulative occurrences in excess ofE, 

the emission level, shown in Table III-B-1 in any compliance period: 

T a e bl III - - B 1 All ow a bl e so fil 2 emisswns pro I e 

Occurrences, n Emission Level, E (lbs/hr) Occurrences, n Emission Level, E (lbs/hr) 

0 38,000 180 20,500 

1 36,000 245 19,300 

2 34,000 330 18,500 

4 32,000 435 17,500 

7 30,500 560 16,700 

12 28,800 710 16,000 

20 27,300 890 15,000 

32 26,000 1100 14,200 

48 25,000 1340 13,500 

68 23,800 1610 12,800 

94 22,700 1910 12,200 

130 21,500 2240 11,500 

3. Sulfur dioxide fugitive emissions control [A.A.C. R18-2-306.0l.A and 715.02.C] 

Permittee shall maintain and operate the following emission control equipment and other relevant 

facilities with good housekeeping and operational practices to insure the maximum capture of fugitive 

S02 emissions from the converter building, furnace building, and/or anode building: 

a. ESPs; 

b. Settling chambers; 

c. Monsanto acid plant; 

d. Primary hoods for the converters; 

e. Secondary hoods for the converters; 

f. Secondary hoods baghouse for the converter building; 

g. Furnace vent hoods; and 

h. Furnace wet gas handling system. 

C. Monitoring, Recordkeeping and Reporting Requirements 

I. Sulfur Balance 

As a means of determining total overall emissions, Permittee shall perform material balances for sulfur 

in accordance with the procedures prescribed in the Attachment D of this permit. 

[A.A.C. R18-2-715.01(0)] 

2. For purposes of determining compliance with the cumulative occurrence and emission limits contained 

in paragraphs III.B.l and 2 of this section, Permittee shall continue to calibrate, maintain, and operate 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 24 of65 
a measurement system for continuously monitoring sulfur dioxide concentrations and stack gas 

volumetric flow rates of the following: [A.A.C. R18-2-715.01(K), (K)(1) and (K)(2)] 

a. gaseous stream at main flue of the five Pierce Smith converter secondary hoods; 

b. vent gas of fugitive emissions captured by all the slag tapping hoods, matte tapping hoods, and slag 

return hoods; 

c. main gaseous stream to the center of the one-thousand-foot stack. 

3. Quality control and assurance requirements for the continuous monitoring systems 

a. All the stack gas volumetric flow rate measurement systems shall meet 40 CPR Part 60, Appendix 

B, "Performance Specification 6- Specifications and Test Procedures for Continuous Emission Rate 

Monitoring Systems in Stationary Sources": [A.A.C. R18-2-715.01(K)(5)(a)] 

(1) Performance and Equipment Specifications 

(2) CD Test Procedure 

(3) RA Test Procedure 

b. The S02 CEMS shall meet 40 CPR Part 60, Appendix B, "Performance Specification 2 -

Specifications and Test Procedures for S02 and NOx Continuous Emission Monitoring Systems in 

Stationary Sources": [A.A.C. R18-2-715.01(K)(5)(b)] 

(1) Installation and Measurement Location Specifications 

(2) Performance and Equipment Specifications 

(3) Performance Specification Test Procedure 

(4) The CEMS Calibration Drift Test Procedure 

(5) Relative Accuracy Test Procedure 

( 6) Equations 

c. Permittee shall conduct the demonstrations of measurement systems performance required by the 

preceding paragraphs a and b in accordance with 40 CPR 60, Appendix F. 

[A.A.C. R18-2-312.H.3 and 715.01(K)(5)(c)] 

d. Location change of all sampling points for monitoring sulfur dioxide concentrations and stack gas 

volumetric flow rates shall be approved in writing by the Director. [A.A.C. R18-2-715.01(K)(5)(d)] 

e. The measurement systems in use shall be subject to the manufacturer's recommended zero adjustment 

and calibration procedures at least once per 24-hour operating period unless the manufacturer 

specifies or recommends calibration at shorter intervals, in which case specifications or 

recommendations shall be followed. Records of these procedures shall be made which clearly show 

instrument readings before and after zero adjustment and calibration. [A.A.C. R18-2-715.01(K)(5)(e)] 

f. Failure to measure at least 95 percent of the hours during which emissions occurred in any month, 

using the continuous monitoring systems, shall constitute a violation. [A.A.C. R18-2-715.01(L)] 

g. Failure to measure any 12 consecutive hours of emissions in accordance with the requirements in this 

subsection shall constitute a violation. [A.A.C. R18-2-715.01(M)] 

h. Permittee shall maintain on hand and ready for immediate installation sufficient spare parts or 

duplicate systems for the continuous monitoring equipment required by this subsection to allow for 

the replacement within six hours of any monitoring equipment part which fails or malfunctions during 

operation. [A.A.C. R18-2-715.01(N)] 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 25 of65 
4. For purposes of this subsection, continuous monitoring means the taking and recording of at least one 

measurement of sulfur dioxide concentration and stack gas flow rate reading from the effluent of each 

affected stack, outlet or other approved measurement location in each 15-minute period. An hour of 

smelter emissions will be considered to have been continuously monitored if the emissions from all 

monitored stacks, outlets or other approved measurement locations are measured for at least 45 minutes 

of any hour in accordance with the requirements of this subsection. [A.A. C. R18-2-715.01(K)(4)] 

5. For purposes of determining compliance with the cumulative occurrence and emission limits contained 

in paragraphs ill.B.l and 2 of this section, the annual average emissions and three-hour emissions shall 

be determined as follows: 

a. Permittee shall, at the end of each day, calculate annual average S02 emissions by averaging the S02 

emissions for all hours measured during the compliance period ending on that day. 

[A.A.C. R18-2-715.01(C)(1)] 

b. Permittee shall, at the end of each clock hour, calculate three-hour S02 emissions averages by 

averaging the hourly S02 emissions for the preceding three consecutive hours whenever each such 

hour was measured in accordance with the requirements contained in this subsection. 

[A.A.C. R18-2-715.01(C)(2)] 

c. The actual cumulative occurrence and emission level shall be determined using the sum total of sulfur 

dioxide emissions from the smelter processing units and sulfur dioxide control and removal 

equipment. The captured fugitive emissions shall be included as part of the total plant emissions, but 

not the uncaptured fugitive emissions and those emissions due solely to the use of fuel for space 

heating or steam generation. [A.A.C. R18-2-715.01(A) and 715.01(K)(2)] 

d. Periods of malfunction, startup, shutdown or other upset conditions shall be included in the 

determination. [A.A.C. R18-2-715.01(B)] 

6. Violation Determination 

For purposes of this section, the following scenarios shall be considered violations of the cumulative 

occurrence and/or emission limits contained in paragraphs ill.B.l and 2: 

a. An annual emissions average in excess of the allowable annual average emission limit given in 

paragraph ill.B.l of this section shall be considered a violation if either: [A.A.C. R18-2-715.01(C)(1)] 

( 1) The annual average is larger than the annual average computed for the preceding day; or 

(2) The annual averages computed for the five preceding days all exceed the allowable annual 

average emission limit. 

b. A three-hour emissions average in excess of an emission level (E) will be considered to violate the 

associated cumulative occurrence limit (n) listed in Table ill-B-1 of this section if both: 

(1) The number of all three-hour emissions averages measured during the compliance period in 

excess of that emission level exceeds the cumulative occurrence limit associated with the 

emission level; and 

(2) The average was measured during the last operating day of the compliance period being reported. 

[A.A.C. R18-2-715.01(E)] 

c. A three-hour emissions average can only violate the cumulative occurrence limit (n) of an emission 

level (E) in the day containing the last hour in the average. [A.A.C. R18-2-715.01(F)] 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 26 of65 
d. Multiple violations of a cumulative occurrence limit in the same day and violations of different 

cumulative limits in the same day shall constitute a single violation. [A.A.C. R18-2-715.01(G)] 

e. The violation of any cumulative occurrence limit and an annual average emission limit in the same 

day shall constitute only a single violation. [A.A.C. R18-2-715.01(H)] 

f. Multiple violations of a cumulative occurrence limit by different three-hour emissions averages 

containing any common hour shall constitute a single violation. [A.A.C. R18-2-715.01(I)] 

7. Recordkeeping and Reporting Requirements 

a. Permittee shall maintain a record of all average hourly emissions measurements required to be 

measured by this section in accordance with the requirements specified in Section XII, Attachment 

"A" of this permit. [A.A.C. R18-2-715.01(P)] 

b. Monthly reporting requirements 

All of the following measurement results shall be expressed as pounds per hour of sulfur dioxide and 

shall be summarized monthly and submitted to the Director within 20 days after the end of each 

month: [A.A.C. R18-2-715.01(P)] 

(1) For all periods described in III.C.5 of this subsection, the annual average emissions (expressed 

in pounds per hour) as calculated at the end of each day of the month; 

(2) The total number of hourly periods during the month in which measurements were not taken and 

the reason for loss of measurement for each period; 

(3) The number of three-hour emissions averages which exceeded each of the applicable emissions 

levels listed in Table III-B-1 for the compliance periods ending on each day of the month being 

reported; 

(4) The date on which a cumulative occurrence limit listed in Table III-B-1 was exceeded if such 

exceedance occurred during the month being reported. 

c. Bypass reporting requirements 

At each point in the permitted smelter facility where a means exists to bypass the sulfur removal 

equipment, such bypass shall be instrumented and monitored to detect and record all periods that the 

bypass is in operation. Permittee shall report to the Director, not later than the 15th day of each 

month, the information required to be recorded by this Section. Such report shall include an 

explanation for the necessity of the use of the bypass. [A.A.C. R18-2-715.01(T)] 

D. Permit Shield 

Compliance with the terms of this section shall be deemed compliance with the following applicable 

requirement(s) in effect on the date of permit issuance: A.A.C. R18-2-715.F.2, A.A.C. R18-2-715.0l.A, 

A.A. C. RlS-2-715.0 l.B, A.A. C. RlS-2-715.0 l.C, A.A. C. R18-2-715.01.E, A.A.C. RlS-2-715 .0 l.F, A.A. C. 

R18-2-715.0l.G, A.A.C. R18-2-715.0l.H, A.A.C. RlS-2-715.01.1, A.A. C. Rl8-2-715.01.J, A.A.C. R18-2-

715.0l.K, A.A.C. R18-2-715.0l.L, A.A.C. R18-2-715.0l.M, A.A.C. R18-2-715.0l.N, A.A.C. RlS-2-

715.01.0, A.A.C. R18-2-715.0l.P, and A.A.C. R18-2-715.0l.T. 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 27 of65 
IV. MORE REQUIREMENTS FOR FURNACE AND CONVERTERS OPERATION 

A. Applicability 

The requirements of this section are applicable to the following process sources: the Inca oxygen flash 

furnace and Nos. 1-5 Pierce Smith converters. 

B. Emission limits and Standards 

1. Opacity Standard 

Permittee shall not cause, allow or permit to be emitted into the atmosphere any plume or effluent from 

operation of any converters and/ or the portion of furnace not associated with the Monsanto sulfuric acid 

plant, the opacity of which exceeds 20 percent. Where the presence of uncombined water is the only 

reason for the exceedance of the visible emissions requirement, such exceedance shall not constitute a 

violation. [A.A.C. R18-2-702(C) and 715(D)] 

2. Furnace Particulate Matter Standard [40 CFR 52.126(b) and A.A.C. R18-2-701(23), 701(24), 702(E) and 715(A)] 

Permittee shall not cause, allow or permit the discharge of particulate matter into the atmosphere from 

the furnace operation in total quantities in excess of the amount calculated by one of the following 

equations and rounded off to two decimal places: 

a. For the furnace operation having a process weight rate of 60,000 pounds per hour (30 tons per hour) 

or less, the maximum allowable emissions from the furnace shall be determined by the following 

equation: 

Where 

Er Furnace maximum allowable particulate emissions rate in pounds-mass per hour. 

P r = Total furnace process weight rate in tons-mass per hour, which is the total weight rate of all 

materials introduced into the Inca oxygen flash furnace, including fuels, where these 

contribute to generation of particulate matters. It shall be the total process weight for the 

entire period of continuous operation or for a typical portion thereof, divided by the number 

of hours of such period or portion thereof. 

b. For the furnace operation having a process weight rate greater than 60,000 pounds per hour (30 tons 

per hour), the maximum allowable emissions from the furnace shall be determined by the following 

equation: 

Er = 17.31 Pro.J6 

Where "Er" and "Pr" are defined as indicated in IV.B.2.a. 

3. Converter Particulate Matter Standard 

[40 CFR 52.126(b) and A.A. C. R18-2-701(23), 701(24), 702(E), 715(C) and 715(A)] 

Permittee shall not cause, allow or permit the discharge of particulate matter into the atmosphere from 

all the converters in operation in total quantities in excess of the amount calculated by one of the 

following equations and rounded off to two decimal places: 

a. For the converters operation having a process weight rate of 60,000 pounds per hour (30 tons per 

hour) or less, the maximum allowable emissions from all the converters in operation shall be 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 28 of65 
determined by the following equation: 

Where 

Ec Maximum allowable particulate emissions rate of all the converters in operation in poundsmass per hour. 

P c Total converters process weight rate in tons-mass per hour, which is the total weight rate of 

all materials introduced into all the converters in operation, including fuels, where these 

contribute to generation of particulate matters. The process weight for each converter shall 

be the total process weight for a period which covers a complete operation or an integral 

number of cycles, divided by the hours of actual process operation during such period. In 

addition, for purposes of this section, the total process weight from all similar units 

employing a similar type process shall be used in determining the maximum allowable 

emission of particulate matter for that process. 

b. For the converters operation having a process weight rate greater than 60,000 pounds per hour (30 

tons per hour), the maximum allowable emissions from all the converters in operation shall be 

determined by the following equation: 

Ec = 17.31Pc0.16 

Where "Ec'' and "Pc'' are defined as indicated in N.B.3.a. 

C. Air Pollution Control Requirements 

1. Particulate Matter Control for Flash Furnace Vent Gas 

Permittee shall operate the R&R Cottrell ESPs to treat all captured fugitive gases from matte tapping 

and slag skimming stations at the flash furnace for particulate matter removal prior to discharge to the 

atmosphere. [Installation Permit No. 1166, Condition 7] 

2. Particulate Matter Control for Secondary Hoods Vent Gas 

Permittee shall operate and maintain the converter secondary hoods baghouse to minimize particulate 

emissions from the secondary hoods. [A.A. C. R18-2-317 Change to Operating Permit No. 0308-85] 

D. Monitoring, Recordkeeping and Reporting Requirements 

1. Converter Secondary Hoods Baghouse COMS [A.A.C. R18-2-306.A.3.c] 

a. Unless the alternative methods and procedures as provided in subsection N.D.4 below are 

implemented, Permittee shall. within 180 days from the effective date oft his permit. install, calibrate, 

maintain, and operate a COMS downstream o[the converter secondary hoods baghouse to monitor 

the baghouse outlet flue gas opacity. 

b. The converter secondary hoods baghouse COMS shall comply with the same performance, quality 

assurance, recordkeeping, and reporting requirements as specified in II.D.1 and 4 of this attachment 

for the R&R Cottrell ESP COMS. 

2. Permittee shall weigh the material entering the Inco flash furnace with a weightometer and shall count 

the number of ladles carrying material to the converters to determine the process weight rates in tonsmass per hour to the furnace and converters. [A.A.C. R18-2-306.A.3.c] 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 29 of65 
3. Particulate Matter Monitoring for Acid Plant Tailgas and Converter Secondary Hoods 

a. In conjunction with the monitoring performed under paragraph II.D.3 of this attachment, Permittee 

shall also evaluate opacity measurements from the converter secondary hoods baghouse COMS 

described in paragraphiV.D.1 and the main flue COMS described in paragraphii.D.1.b on a24-hour 

rolling average. If the 24-hour rolling average opacity exceeds 15 percent, Permittee shall initiate 

investigation of the relevant controls or equipment within 24 hours of the first discovery of the high 

opacity incident and, if necessary, take corrective action as soon as practicable to adjust or repair the 

controls or equipment to reduce the opacity average to below the 15 percent level. 

[A.A.C. R18-2-306.A.3.c] 

b. Permittee shall log in ink or electronic format and maintain a record of24-hour opacity measurements 

performed in accordance with paragraph a above and any corrective actions taken, if any. A record 

of corrective actions taken shall include the date and time during which the 24-hour rolling average 

opacity exceeded 15 percent and the date, time and type of the corrective action. 

[A.A.C. R18-2-306.A.3.c] 

4. Alternative Monitoring Requirements 

Permittee may apply the following baghouse leak detection approach as the alternative to the COM 

requirements set forth in paragraph IV.D.1 above: 

a. Permittee shall. within 180 davs from the effective date oft his permit. install, calibrate, maintain, and 

continuously operate a bag leak detection svstem at the converter secondary hoods baghouse to 

monitor the baghouse performance. For the purpose of this subsection, the bag leak detection system 

means an instrument that is capable of monitoring particulate matter loadings in the exhaust of the 

secondary hoods baghouse in order to detect bag failures. The bag leak detection shall include, but 

is not limited to, an instrument that operates on triboelectric, light scattering, or other principle to 

monitor relative or absolute particulate matter loadings. [A.A.C. R18-2-306.A.3.c and 312.H.3] 

b. The converter secondary hoods baghouse leak detection system required by the paragraph IV.D.4.a 

above shall comply with the following specifications and requirements: [A.A.C. R18-2-306.A.3.c] 

( 1) The bag leak detection svstem shall be certified by the manufacturer to be capable of detecting 

particulate matter emissions at concentrations that can effectively discern any dysfunctional 

leaks o(the secondary hoods baghouse. 

(2) The bag leak detection system sensor shall provide output of relative or absolute particulate 

matter loadings. 

(3) The bag leak detection system shall be equipped with an alarm system that will sound 

automatically when an increase in relative particulate emissions over a preset level is detected. 

The alarm shall be located where it is easily heard by plant operating personnel. 

( 4) The bag leak detection system shall be installed downstream of the converter secondary hoods 

baghouse. 

( 5) The bag leak detection system shall be installed, operated, calibrated, and maintained in a manner 

consistent with the manufacturer's written specifications and recommendations. The calibration 

of the system shall, at a minimum, consist of establishing the relative baseline output level by 

adjusting the sensitivity and the averaging period of the device, and establishing the alarm set 

points and the alarm delay time. 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 30 of65 
c. If the bag leak detection system alarms, Permittee shall initiate investigation of the secondary hoods 

baghouse within 24 hours of the first discovery of the alarming incident and, if necessary, take 

corrective action as soon as practicable to adjust or repair the baghouse to minimize possible 

exceedances of the particulate standard established in paragraphs N.B.3 of this section. 

[A.A.C. R18-2-306.A.3.c] 

d. Permittee shall log in ink or electronic format and maintain a record of installation, calibration, 

maintenance, and operation of the bag leak detection system in accordance with Section XII, 

Attachment "A" of this permit. In the case of any alarming incident, the record shall include an 

identification of the date and time of all bag leak detection alarms, their cause, and an explanation 

of the corrective actions taken, if any. [A.A. C. R18-2-306.A.3.c] 

E. Performance Testing Requirements [A.A.C. R18-2-715(E)] 

1. Performance Testing Methods and Frequency 

Permittee shall conduct performance tests at least once every year with the following reference methods 

to determine compliance with the particulate matter emissions standard set forth in N.B.2 and 3 of this 

section for the one-thousand-foot stack: 

a. Reference Method 1 for sample and velocity traverses; 

b. Reference Method 2 for volumetric flow rate; 

c. Reference Method 3 for gas analysis; 

d. Arizona Testing Method A1 or Reference Method 5 for concentration of particulate matter and 

associated moisture content. 

2. Sampling Location 

The performance tests shall be conducted at and samples be withdrawn contemporaneously from the 

following locations: 

a. R&R ESP outlet flue; 

b. Secondary Hoods Baghouse outlet flue; and 

c. Monsanto Acid Plant outlet flue. 

3. Compliance Demonstration 

Permittee shall demonstrate compliance by comparing the sum total of all emissions from each sampling 

location as determined under N.E.l and 2 above with the sum total of all the maximum allowable 

particulate emissions rates set forth in N.B.2 and 3. 

F. Permit Shield 

Compliance with the terms of this section shall be deemed compliance with the following applicable 

requirement(s) in effect on the date of permit issuance: 40 CFR 52.126(b), A.A.C. R18-2-715.A, A.A.C. 

R18-2-715.C, A.A.C. R18-2-715.D, A.A.C. R18-2-715.E, and Installation Permit No. 1166, Condition 7. 

V. CONVERTERS ARSENIC CHARGING RATE MONITORING 

A. General Provisions of the Section 

1. The requirements of this section apply to any copper converter under this permit where the total arsenic 

charging rate for the copper converter department averaged over a 1-year period is less than 75 kg/hr. 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 31 of65 
At such time that Permittee becomes aware of the 1-year period average total equal to or greater than 

75 kg/hr, Permittee shall submit an application for permit revision in accordance with Section XV, 

Attachment "A". [40 CFR61.172(a)] 

2. Arsenic charging rate means the hourly rate at which arsenic is charged to the copper converters based 

on the arsenic content of the copper matte and of any lead matte that is charged to the copper converters. 

[40 CFR61.171] 

B. Monitoring Requirements [40 CFR 61.174(f)] 

Permittee shall determine the converter arsenic charging rate as follows: 

1. Collect daily grab samples of copper matte and any lead matte charged to the copper converters. 

2. Each calendar month, from the daily grab samples collected under paragraph 1 above, put together a 

composite copper matte sample and a composite lead matte sample. Analyze the composite samples 

individually using Method 1 08A, 1 08B, or 1 08C to determine the weight percent of inorganic arsenic 

contained in each sample. 

3. Calculate the converter arsenic charging rate once per month using the following equation: 

Where: 

~ Converter arsenic charging rate (kg/h). 

Ae = Monthly average weight percent of arsenic in the copper matte charged during the month (%) as 

determined under paragraph b above. 

A1 Monthly average weight percent of arsenic in the lead matte charged during the month (%) as 

determined under paragraph b above. 

Wei Total weight of copper matte charged to a copper converter during the month (kg). 

W1

; Total weight of lead matte charged to a copper converter during the month (kg). 

He= Total number of hours the copper converter department was in operation during the month (h). 

n = Number of copper converters in operation during the month. 

4. Determine an annual arsenic charging rate for the copper converter department once per month by 

computing the arithmetic average of the 12 monthly converter arsenic charging rate values(~) for the 

preceding 12-month period. 

C. Recordkeeping and Reporting Requirements [40 CFR61.174(f)] 

1. Permittee shall maintain at the source for a period of at least 2 years and make available to the Director 

upon request the following records: 

a. For all converters, a monthly record of the weight percent of arsenic contained in the copper matte 

and lead matte as determined under V.B of this section. [40 CFR 61.176(c)(2)] 

b. For all converters, the monthly calculations of the average annual arsenic charging rate for the 

preceding 12-month period as determined under V.B of this section. [40 CFR 61.176(c)(3)] 

2. Permittee shall submit annually a written report to the Director that includes the monthly computations 

of the average annual converter arsenic charging rate as calculated under V .B .4 of this section. The 

annual report shall be postmarked by the 30th day following the end of each calendar year. 

[ 40 CFR 61.177(f)] 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 32 of65 
D. Permit Shield 

Compliance with the terms of this section shall be deemed compliance with the following applicable 

requirement(s) in effect on the date of permit issuance: 40 CFR 61.172(a), 40 CFR 61.174(£), 40 CFR 

61.176( c )(2), 40 CFR 61.176( c )(3), and 40 CFR 61.177(£). 

VI. MATERIAL STORAGE FACILITIES 

A. Affected Facilities 

The affected facilities under this section shall include the following: 

1. 200-Ton West Wet Bin #1 

2. 200-Ton West Wet Bin #2 

3. 200-Ton Dry Bin #1 

4. 200-Ton Dry Bin #2 

5. 200-Ton Dry Bin #3 

6. 200-Ton Dry Bin #4 

7. 30-Ton Dust Bin #1 

8. 30-Ton Dust Bin #2 

9. WTP Lime Silo 

B. Emission limits and Standards 

1. Visible Emissions 

Permittee shall not cause, allow or permit to be emitted into the atmosphere any plume or effluent from 

any material storage facilities under this section, the opacity of which exceeds 20 percent. Where the 

presence of uncombined water is the only reason for the exceedance of the visible emissions 

requirement, such exceedance shall not constitute a violation. [A.A.C. R18-2-702(c) and 715(D)] 

2. Particulate Matter Standard [40 CFR 52.126(b) and A.A. C. R18-2-701(23), 701(24), 702(E), 715(A) and 715(C)] 

Permittee shall not cause, allow or permit the discharge of particulate matter into the atmosphere from 

any affected material storage facilities under this section in total quantities in excess of the amount 

calculated by one ofthe following equations and rounded off to two decimal places: 

a. For the material storage facilities having a process weight rate of 60,000 pounds per hour (30 tons 

per hour) or less, the maximum allowable emissions shall be determined by the following equation: 

E 3.59 p0.62 Where: 

E Maximum allowable particulate emissions rate in pounds-mass per hour. 

P Total process weight rate in tons-mass per hour, which is the total weight rate of all materials 

introduced into the bin, where these contribute to generation of particulate matters. It shall 

be the total process weight for the entire period of continuous operation or for a typical 

portion thereof, divided by the number of hours of such period or portion thereof. In 

addition, for purposes of this section, the total process weight from all similar units 

employing a similar type process shall be used in determining the maximum allowable 

emission of particulate matter for that process. 

b. For the material storage facilities having a process weight rate greater than 60,000 pounds per hour 

ASARCO - Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 33 of65 
(3 0 tons per hour), the maximum allowable emissions shall be determined by the following equation: 

E = 17.31 P 0 16 

Where "E" and "P" are defined as indicated in the preceding equation in VI.B.2.a. 

C. Air Pollution Control Requirements 

Permittee shall operate baghouses associated with the material storage facilities subject to the 

requirements of this Section. [A.A. C. R18-2-317 Change to Operating Permit No. 0308-85] 

D. Monitoring, Recordkeeping and Reporting Requirements [A.A.C. R18-2-306.A.3.c] 

1. A trained observer shall conduct a bi-weekly (once in every two weeks) visual survey of visible 

emissions from stacks of the associated baghouses under this section when the material feeding is in 

process, using USEPA Reference Method 22. 

2. If any of the stacks is observed having a visible emission that lasts longer than six minutes, Permittee 

shall commence corrective action as necessary to adjust or repair the associated baghouse. 

3. Permittee shall log in ink or electronic format and maintain a record of visible emission observations 

including the name ofthe observer, the date and time on which the observation was made, and the results 

of the observation. Permittee shall also keep a record of corrective action taken, if any. 

E. Permit Shield 

Compliance with the terms of this section shall be deemed compliance with the following applicable 

requirement(s) in effect on the date of permit issuance: 40 CFR 52.126(b), A.A.C. R18-2-715.A, A.A.C. 

R18-2-715.C, and A.A.C. R18-2-715.D. 

VII. REVERT CRUSHING PLANT 

A. Applicability 

The revert crushing plant under this section shall include the following affected facilities: 

1. Primary jaw crusher; 

2. Vibrating screen; 

3. Cone crusher; and 

4. 4 conveyor belt transfer points, i.e., from primary crusher to 1st conveyor, from 1st conveyor to screen, 

from screen to 2nd conveyor, and from cone crusher to 2nd conveyor. 

B. Emission limits and Standards 

1. Visible Emissions 

Permittee shall not cause to be discharged into the atmosphere from the revert crushing plant any stack 

emissions that exhibit greater than 20 percent opacity and/or any process fugitive emissions that exhibit 

greater than 40 percent opacity. Where the presence of uncombined water is the only reason for the 

exceedance of the visible emissions requirement, such exceedance shall not constitute a violation. 

[A.A.C. R18-2-702(B) and (C) and 715(D)] 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 34 of65 
2. Particulate Matter Standard [40 CFR 52.126(b) and A.A. C. R18-2-701(23), 701(24), 702(E), and 715(A)] 

Permittee shall not cause, allow or permit the discharge of particulate matter into the atmosphere from 

the revert crushing plant under this section in total quantities in excess of the amount calculated by one 

of the following equations and rounded offto two decimal places: 

a. For the revert crushing operation having a process weight rate of 60,000 pounds per hour (3 0 tons per 

hour) or less, the maximum allowable emissions shall be determined by the following equation: 

E 3.59P 062 Where: 

E Maximum allowable particulate emissions rate in pounds-mass per hour. 

P Total process weight rate in tons-mass per hour, which is the total weight rate of all materials 

introduced into the revert crushing plant, where these contribute to generation of particulate 

matters. It shall be the total process weight for the entire period of continuous operation or 

for a typical portion thereof, divided by the number of hours of such period or portion 

thereof. 

b. For the revert crushing operation having a process weight rate greater than 60,000 pounds per hour 

(30 tons per hour), the maximum allowable emissions shall be determined by the following equation: 

E = 17.31P 016 

Where "E" and "P" are defined as indicated in the preceding equation in Vll.B.2.a. 

3. The amount of material processed at the revert crushing plant shall not exceed 42,000 tons per year 

without prior approval from the Director. [Installation Permit No. 1215, Condition 8] 

C. Air Pollution Control Requirements 

1. Permittee shall operate a bag house associated with the revert crushing plant subject to the requirements 

of this section with rated efficiency no lower than 99%. [Installation Permit No. 1215, Conditions 2 and 3] 

2. Particulates captured in the control facilities shall be handled and disposed in a manner which prevents 

re-entrainment into the atmosphere. [Installation Permit No. 1215, Condition 5] 

3. All conveyor transfer points shall be enclosed. [Installation Permit No. 1215, Condition 6] 

4. Spray bars shall be used at every dumping and conveyor transfer point, as necessary to minimize the 

particulate matter emissions. [Installation Permit No. 1215, Condition 7] 

D. Monitoring, Recordkeeping and Reporting Requirements 

1. Permittee shall record the date, hours of operation and process weight rate in tons-mass per hour to the 

revert crushing system. [A.A.C. R18-2-306.A.3.c] 

2. Monthly monitoring for opacity/particulate matter emissions from the revert crushing plant baghouse 

a. Baseline establishment [A.A.C. R18-2-306.A.3.c] 

Within 180 days of issuance of this permit, Permittee shall conduct at least one certified method 9 

performance test in accordance with section XVII of attachment "A" for the revert crushing plant 

baghouse while it is operating at normal representative working conditions, to establish a baseline 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 35 of65 
opacity level. Within 30 days of establishing the baseline opacity, Permittee shall report the results 

to the Director. 

b. Monthly monitoring [A.A.C. R18-2-306.A.3.c] 

(1) A certified Method 9 observer shall conduct a monthly (once in every month) visual survey of 

visible emissions from the subject baghouse when it is in operation. Permittee shall keep a record 

of the name of the observer, the date on which the observation was made, and the results of the 

observation. 

(2) If the observer sees a plume from the subject baghouse that on an instantaneous basis appears to 

exceed the baseline opacity level, then the observer shall take a six-minute Method 9 observation 

of the plume. If conditions prevent the observation, the observer shall document these 

conditions. 

(3) If the six-minute opacity of the plume is less than the baseline level, Permittee shall make a 

record ofthe following: 

(a) name of the observer; 

(b) date, and time of the test; and 

(c) the results ofthe method 9 observation. 

( 4) If the six-minute opacity of the plume exceeds the baseline level but is less than the 20 percent 

opacity standard, Permittee shall adjust or repair the controls or equipment to reduce opacity to 

below the baseline level. Permittee shall also make a record of the following: 

(a) name ofthe observer; 

(b) date, and time of the test; 

(c) the results of the method 9 observation; and 

(d) corrective action taken. 

(5) If the six-minute opacity of the plume exceeds both the baseline level and the 20 percent opacity 

standard, Permittee shall adjust or repair the controls or equipment to reduce opacity to below 

the baseline level and report the incident as an excess emission for opacity. Permittee shall also 

make a record of the following: 

(a) name of the observer; 

(b) date, and time of the test; 

(c) the results of the method 9 observation; 

(d) corrective action taken; and 

(e) excess emission report. 

c. Baseline re-establishment [A.A.C. R18-2-306.A.3.c] 

If necessitated by the results of the monthly monitoring, Permittee may re-establish the baseline 

opacity level. Re-establishment of the baseline shall be performed utilizing the same procedures used 

in setting up the initial baseline level. Within 30 days of re-establishing the baseline opacity, 

Permittee shall report the results to the Director. The report shall also contain a description of the 

need for re-establishing the baseline(s). 

3. Monthly monitoring for opacity of process fugitive emissions [A.A.C. R18-2-306.A.3.c] 

a. A certified Method 9 observer shall conduct a monthly (once in every month) visual survey of all 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 36 of65 
process fugitive emissions from the revert crushing plant when it is in operation. 

b. If the observer, during the visual survey, does not see any plume from any fugitive source that on an 

instantaneous basis appears to exceed the 40 percent opacity standard, then the observer shall record 

his/her name, the date on which the observation was made, and the results of the observation. 

c. If the observer sees a plume from a fugitive source that on an instantaneous basis appears to exceed 

the 40 percent opacity standard, then the observer shall take a six-minute Method 9 observation of 

the plume. If conditions prevent the observation, the observer shall document these conditions. 

d. If the six-minute opacity of the plume is less than the 40 percent opacity standard, Permittee shall 

make a record of the following: 

( 1) name of the observer; 

(2) source, date, and time of the test; and 

(3) the results of the method 9 observation. 

e. If the six-minute opacity of the plume exceeds the 40 percent opacity standard, Permittee shall adjust 

or repair the controls or equipment to reduce opacity to below 40 percent opacity and report the 

incident as excess emissions. Permittee shall also make a record of the following: 

(1) name of the observer; 

(2) source, date, and time of the test; 

(3) the results of the method 9 observation; 

( 4) corrective action taken; and 

(5) excess emission report. 

E. Performance Testing Requirements 

Permittee shall determine compliance with the particulate matter standards set forth in VII.B.2 of this 

section by conducting performance tests, at least once during the permit term, at the revert crushing 

ventilation baghouse, using EPA Reference Method 5 or 1 7 to determine the particulate matter 

concentration. The sample volume for each run shall be at least 1.70 dscm (60 dscf). The sampling probe 

and filter holder of Method 5 may be operated without heaters if the gas stream being sampled is at ambient 

temperature. For gas streams above ambient temperature, the Method 5 sampling train shall be operated 

with a probe and filter temperature slightly above the effluent temperature (up to a maximum filter 

temperature of 121 oc (250°F)) in order to prevent water condensation on the filter. 

[Installation Permit No. 1215, Condition 2 and A.A. C. R18-2-312.A] 

F. Permit Shield 

Compliance with the terms of this section shall be deemed compliance with the applicable requirements set 

forth in Installation Permit No. 1215 in effect on the date of permit issuance. 

VIII. FUEL BURNING EQUIPMENT 

A. General Provisions of this Section 

1. The requirements of this section are applicable to the following affected facilities: the acid plant 

preheater, the anode steam boiler, all the anode launder burners, all the anode ladle burners, and the 

oxygen plant boiler. [A.A.C. R18-2-724(A)] 

2. For purposes of this Section, the heat input shall be the aggregate heat content of all fuels whose 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 37 of65 
products of combustion pass through a stack or other outlet. Compliance tests shall be conducted during 

operation at the nominal rated capacity of each unit. The total heat input of all fuel-burning units on a 

plant or premises shall be used for determining the maximum allowable amount of particulate matter 

which may be emitted. [A.A.C. R18-2-724(B)] 

B. Emission Standards and Limitations 

1. Visible Emissions 

a. Permittee shall not cause, allow or permit to be emitted into the atmosphere any plume or effluent 

from the acid plant preheater, the anode steam boiler, and/or the oxygen plant boiler, the opacity of 

which exceeds 15 percent. [A.A.C. R18-2-724(J)] 

b. Permittee shall not cause, allow or permit to be emitted into the atmosphere any plume or effluent 

from the anode launder burners and/or the anode ladle burners, the opacity of which exceeds 40 

percent, as determined by Reference Method 9 in 40 CFR 60, Appendix A. [A.A.C. R18-2-702(B)] 

c. Where the presence of uncombined water is the only reason for the exceedance of any visible 

emissions requirements above, such exceedance shall not constitute a violation. 

[A.A.C. R18-2-702(C)] 

2. Particulate Matter 

a. Permittee shall not cause, allow or permit the emission of particulate matter, caused by combustion 

of fuel from operation of the acid plant pre heater, the anode steam boiler, and/or the oxygen plant 

boiler, in excess of the amount calculated by the following equation: 

E = 1.02 Q 0

'

769 where: 

E The maximum allowable particulate emissions rate in pounds-mass per hour. 

Q The heat input in million Btu per hour. 

[A.A.C. Rl8-2-724(C)(1)] 

b. Permittee shall not cause, allow or permit the discharge of particulate matter into the atmosphere in 

any 1 hour from any anode launder burners and/or any anode ladle burners under this section in total 

quantities in excess of the amounts calculated by 1 ofthe following equations: 

(1) For process sources having a process weight rate of 60,000 pounds per hour (30 tons per hour) 

or less, the maximum allowable emissions shall be determined by the following equation: 

E = 3.59 P 0

·

62 where: 

E The maximum allowable particulate emissions rate in pounds-mass per hour. 

P The process weight rate in tons-mass per hour. For purposes of this section, the total 

process weight from all similar units employing a similar type process shall be used in 

determining the maximum allowable emission of particulate matter. 

(2) For process weight rate greater than 60,000 pounds per hour (30 tons per hour), the maximum 

allowable emissions shall be determined by the following equation: 

E= 17.31 P 0

·

16 

Where "E" and "P" are defined as indicated in (1) above. 

[40 CFR 52.126(b), A.A.C. R18-2-730(A)(l) and 730(B)] 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3125/05) Page 38 of65 
3. Sulfur Dioxide [A.A.C. R18-2-730(A)(2)] 

Permittee shall not cause, allow or permit the emission of sulfur dioxide from any anode launder burners 

and/or any anode ladle burners under this section at rates greater than 600 parts per million. 

4. Nitrogen Oxides [A.A.C. R18-2-730(A)(3)] 

Permittee shall not cause, allow or permit the emission of nitrogen oxides from any anode launder 

burners and/or any anode ladle burners under this section at rates greater than 500 parts per million, 

expressed as N02• 

5. Fuel Limitation [A.A.C. R18-2-306.A.2] 

Permittee shall only use natural gas as fuel in all the affected units under this Section. 

C. Monitoring, Recordkeeping and Reporting Requirements 

1. Visible Emissions 

a, A certified EPA Reference Method 9 observer shall conduct a monthly survey of visible emissions 

emanating from the stacks of the acid plant preheater, the anode steam boiler, and/or the oxygen plant 

boiler. Ifthe opacity of the emissions observed appears to exceed the 15 percent standard specified 

in VIII.B.1.a, the observer shall conduct a certified EPA Reference Method 9 observation. The 

results of the Method 9 observation shall be maintained. [A.A.C. R18-2-306.A.3.c] 

b. For the purpose of reports under excess emissions reporting required by Section XI.A, Attachment 

"A" of this permit, Permittee shall report all six-minute periods in which the opacity of any plume 

or effluent from the acid plant preheater, the anode steam boiler, and/or the oxygen plant boiler of 

this section exceeds 15 percent. [A.A.C. R18-2-724.J] 

2. Particulate Matter and Sulfur Dioxide Emissions [A.A.C. R18-2-306.A.3.c] 

a. Permittee shall maintain a vendor-provided copy of that part of the Federal Energy Regulatory 

Commission (FER C) approved Tariff agreement that contains the sulfur content and the lower heating 

value of the natural gas fuel in use. 

b. Permittee shall maintain a record of the fuel firing rate (cubic feet per hour of natural gas) for each 

affected facility under this section. 

c. Permittee shall use the natural gas fuel records described in paragraphs a and b above and the latest 

edition of AP-42 formulas for fossil-fuel fired equipment to determine on a monthly basis the 

particulate matter and sulfur dioxide emissions from the acid plant preheater, the anode steam boiler, 

and the oxygen plant boiler of this section. 

D. Permit Shield 

Compliance with the terms of this section shall be deemed compliance with the following applicable 

requirement(s) in effect on the date of permit issuance: A.A.C. R18-2-724.B, A.A.C. R18-2-724.C.l, and 

A.A.C. R18-2-724.J. 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 39 of65 
IX. VISIBLE FUGITIVE EMISSIONS FROM PROCESS SOURCES 

A. Affected Facilities 

The provisions of this Section apply to fugitive emissions from the following affected facilities: the dump 

hopper with unloading conveyors, the tripper car and belt separator, the bedding area with vibrating 

screen/grizzley, the reclaim hopper and feeder, #2 main incline conveyor, #3 inclined conveyor, the 

delumper at oxygen furnace charge system, #4 horizontal conveyor, the wet bin conveyors, the dry screw 

conveyors# 1-8, the feed screw conveyors# 10-16, the hammer mill, the blow tank pneumatic conveyor, the 

converter silica conveying system, the R & R ESP screw conveyors, the R & R ESP bucket elevator, the 

reverts screen # 1 and #2, the anode furnace # 1, #2 and #3, the furnace building, and the converter building. 

The fugitive emissions are those emissions as defined in paragraph I.C.2 of this Attachment. 

B. Opacity Standard 

Permittee shall not cause, allow or permit to be emitted into the atmosphere any plume or effluent from any 

affected facilities under this Section, the opacity of which exceeds 40 percent, measured in accordance with 

EPA Reference Method 9. Where the presence of uncombined water is the only reason for the exceedance 

of the visible emissions requirement, such exceedance shall not constitute a violation. 

[A.A.C. R18-2-702(B) and (C)] 

C. Monitoring, Recordkeeping and Reporting [A.A.C. R18-2-306.A.3.c] 

1. A certified Method 9 observer shall conduct a bi-weekly (once in every two weeks) visual survey of 

visible fugitive emissions for each affected facility under this Section when the facility is in operation. 

2. If the observer, during the visual survey, does not see any plume from any fugitive source that on an 

instantaneous basis appears to exceed the opacity standard, then the observer shall record his/her name, 

the date on which the observation was made, and the results of the observation. 

3. If the observer sees a plume from a fugitive source that on an instantaneous basis appears to exceed the 

opacity standard, then the observer shall take a six-minute Method 9 observation of the plume. If 

conditions prevent the observation, the observer shall document these conditions. 

4. If the six-minute opacity of the plume is less than the opacity standard, Permittee shall make a record 

ofthe following: 

a. name ofthe observer; 

b. source, date, and time of the test; and 

c. the results of the method 9 observation. 

5. If the six-minute opacity of the plume exceeds the opacity standard, Permittee shall adjust or repair the 

controls or equipment to reduce opacity to below the opacity standard and report the incident as excess 

emissions. Permittee shall also make a record of the following: 

a. name ofthe observer; 

b. source, date, and time of the test; 

c. the results of the method 9 observation; 

d. corrective action taken; and 

e. excess emission report. 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 40 of65 
D. Alternate Operating Scenario for the Anode Furnaces 

Permittee may operate any of the three anode furnaces under this section, provided only two furnaces can 

be in operation at a time. 

E. Permit Shield 

Compliance with the terms of this section shall be deemed compliance with the applicable requirements set 

forth in A.A.C. R18-2-702.B and A.A.C. R18-2-702.C in effect on the date of permit issuance. 

X. NON-POINT SOURCES 

A. Emission Limits and Standards 

1. Open Areas, Roadways & Streets, Storage Piles, and Material Handling 

a. Permittee shall not cause, allow or permit visible emissions from open areas, roadways and streets, 

storage piles or material handling in excess of 40% opacity measured in accordance with the Arizona 

Testing Manual, Reference Method 9. Open fires permitted under A.A.C. R18-2-602 are exempt 

from this requirement. [A.A.C. R18-2-610] 

b. Permittee shall employ the following reasonable precautions to prevent excessive amounts of 

particulate matter from becoming airborne: 

( 1) Keep dust and other types of air contaminants to a minimum in an open area where construction 

operations, repair operations, demolition activities, clearing operations, leveling operations, or 

any earth moving or excavating activities are taking place, by good modem practices such as 

using an approved dust suppressant or adhesive soil stabilizer, paving, covering, landscaping, 

continuous wetting, detouring, barring access, or other acceptable means; [A.A.C. R18-2-604.A] 

(2) Keep dust to a minimum from driveways, parking areas, and vacant lots where motor vehicular 

activity occurs by using an approved dust suppressant, or adhesive soil stabilizer, or by wetting, 

or by paving, or by barring access to the property, or by other acceptable means; 

[A.A.C. R18-2-604.B] 

(3) Keep dust and other particulates to a minimum by employing dust suppressants, temporary 

paving, detouring, wetting down or by other reasonable means when a roadway is repaired, 

constructed, or reconstructed; [A.A.C. R18-2-605.A] 

( 4) Take reasonable precautions, such as wetting, applying dust suppressants, or covering the load 

when transporting material likely to give rise to airborne dust; [A.A.C. R18-2-605.B] 

(5) Take reasonable precautions, such as the use of spray bars, wetting agents, dust suppressants, 

covering the load, and hoods when crushing, handling, or conveying material likely to give rise 

to airborne dust; [A.A.C. R18-2-606] 

(6) Take reasonable precautions such as chemical stabilization, wetting, or covering when organic 

or inorganic dust producing material is being stacked, piled, or otherwise stored; 

[A.A.C. R18-2-607.A] 

(7) Operate stacking and reclaiming machinery utilized at storage piles at all times with a minimum 

fall of material, or with the use of spray bars and wetting agents; [A.A. C. R18-2-607.B] 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 41 of65 
(8) Take reasonable precautions such as wetting or applying dust suppressants before the cleaning 

of site, roadway, or alley. Earth or other material shall be removed from paved streets onto which 

earth or other material has been transported by trucking or earth moving equipment, erosion by 

water or by other means; or [A.A.C. RI8-2-804.B] 

(9) Any other method as proposed by Permittee and approved by the Director. 

[A.A.C. Rl8-2-306.A.3.c] 

2. Open Burning [A.A.C. Rl8-2-602] 

Except as provided in A.A.C. R18-2-602.C(1), C(3), and C(4), and except when permitted to do so by 

either ADEQ or the local officer delegated the authority for issuance of open burning permits, Permittee 

shall not conduct open burning. 

B. Monitoring, Recordkeeping and Reporting Requirements 

1. Open Areas, Roadways & Streets, Storage Piles and Material Handling 

a. Bi-weekly Monitoring Requirement [A.A.C. R18-2-306.A.3.c] 

(1) A certified Method 9 observer shall conduct a bi-weekly (once in two weeks) visual survey of 

visible emissions from all non-point sources plant wide when they are in operation. Permittee 

shall keep a record of the name of the observer, the date on which the observation was made, and 

the results of the observation. 

(2) If the observer sees a plume from a non-point source that on an instantaneous basis appears to 

exceed 40%, then the observer shall, if possible, take a six-minute Method 9 observation of the 

plume. If conditions prevent the observation, the observer shall document these conditions. 

(3) If the six-minute opacity of the plume is less than 40%, the observer shall make a record of the 

following: 

(a) Location, date, and time of the observation, and the name of the observer; and 

(b) The results of the Method 9 observation. 

(4) If the six-minute opacity of the plume exceeds 40%, then Permittee shall do the following: 

(a) Adjust or repair the controls or equipment to reduce opacity to below 40%; and 

(b) Report it as an excess emission under Section XI.A of Attachment "A". 

b. Permittee shall maintain records of the dates on which any of the activities listed in X.A.1. b( 1) 

through (9) of this section were performed and control measures adopted. [A.A.C. Rl8-2-306.A.3.c] 

2. Open Burning 

The monitoring requirements for Section X.A.2 of this attachment may be complied with by maintaining 

copies of all open burning permits on file. [A.A.C. Rl8-2-306.A.3.c] 

C. Permit Shield 

Compliance with the terms of this section shall be deemed compliance with the following applicable 

requirement(s) in effect on the date of permit issuance: A.A.C. R18-2-602, A.A.C. R18-2-604.A, A.A.C. 

R18-2-604.B, A.A.C. R18-2-605, A.A.C. R18-2-606, A.A.C. R18-2-607, A.A.C. R18-2-610, and A.A.C. 

R18-2-804.B. 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 42 of65 
XI. OTHER PERIODIC ACTIVITIES 

A. Emission Limits/Standards 

1. Abrasive Blasting [A.A.C. R18-2-726] 

a. Permittee shall not cause or allow sandblasting or other abrasive blasting without minimizing dust 

emissions to the atmosphere through the use of good modern practices. Good modern practices 

include, but are not limited to: 

(1) wet blasting; 

(2) effective enclosures with necessary dust collecting equipment. 

b. Permittee shall not cause, allow or permit visible emissions from sandblasting or other abrasive 

blasting operations in excess of 40% opacity, measured in accordance with EPA Reference Method 

9. Where the presence of uncombined water is the only reason for the exceedance of any visible 

emissions requirements, such exceedance shall not constitute a violation. [A.A.C. R18-2-702.B and C] 

2. Use of Paints 

While performing spray painting operations Permittee shall comply with the following requirements: 

a. Permittee shall not conduct or cause to be conducted any spray painting operation without minimizing 

organic solvent emissions. Such operations other than architectural coating and spot painting, shall 

be conducted in an enclosed area equipped with controls containing no less than 96 percent of the 

overspray. [A.A.C. R18-2-727.A] 

b. Permittee or his designated contractor shall not either: [A.A.C. R18-2-727.B] 

(1) Employ, apply, evaporate or dry any architectural coating containing photo-chemically reactive 

solvents for industrial or commercial purposes; or 

(2) Thin or dilute any architectural coating with a photochemically reactive solvent. 

c. For the purposes of parts b. and e. of this condition, a photochemically reactive solvent shall be any 

solvent with an aggregate of more than 20 percent of its total volume composed of the chemical 

compounds classified in paragraphs (1) through (3) of this subsection, or which exceeds any of the 

following percentage composition limitations, referred to the total volume of solvent: 

[A.A.C. R18-2-727.C] 

( 1) A combination of the following types of compounds having an olefinic or cyclo-olefinic type of 

unsaturation - hydrocarbons, alcohols, aldehydes, esters, ethers, or ketones: five percent 

(2) A combination of aromatic compounds with eight or more carbon atoms to the molecule except 

ethylbenzene: eight percent 

(3) A combination of ethylbenzene, ketones having branched structures, trichloro-ethylene or 

toluene: 20 percent 

d. Whenever any organic solvent or any constituent of an organic solvent may be classified from its 

chemical structure into more than one of the groups or organic compounds described in XI.A.2.c(1) 

through (3), it shall be considered to be a member of the group having the least allowable percent of 

the total volume of solvents. [A.A. C. R18-2-727.D] 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 43 of65 
e. Permittee shall not dispose by evaporation more than 1.5 gallons of photo-chemically reactive solvent 

in any one day. [SIP Provision R9-3-527.C] 

f. Visible emissions from spray painting operations shall not have an opacity greater than 40%, 

measured in accordance with by EPA Reference Method 9. Where the presence of uncombined water 

is the only reason for the exceedance of any visible emissions requirements, such exceedance shall 

not constitute a violation. [A.A.C. R18-2-702.B and C] 

3. Roadway and Site Cleaning Machinery 

Permittee shall not cause, allow or permit to be emitted into the atmosphere from any roadway and site 

cleaning machinery smoke or dust for any period greater than ten consecutive seconds, the opacity of 

which exceeds 40 percent. Visible emissions when starting cold equipment shall be exempt from this 

requirement for the first ten minutes. [A.A.C. R18-2-804.A] 

4. Demolition/Renovation 

Permittee shall comply with all of the requirements of 40 CFR 61, Subpart M (National Emissions 

Standards for Hazardous Air Pollutants- Asbestos). [A.A.C. R18-2-110l.A.8] 

5. Nonvehicle Air Conditioner Maintenance and/or Services 

Permittee shall comply with the applicable requirements of 40 CFR 82 - Subpart F (Protection of 

Stratospheric Ozone- Recycling and Emissions Reduction). [40 CFR 82, Subpart F] 

6. Gaseous or Odorous Materials 

Permittee shall not emit gaseous or odorous materials from equipment, operations or premises under his 

control in such quantities or concentrations as to cause air pollution. [A.A.C. R18-2-730.D] 

7. Solvent Degreasing 

Permittee shall process, store, use, and transport materials including solvents or volatile compounds in 

such a manner and by such means that they will not evaporate, leak, escape, or be otherwise discharged 

into the atmosphere so as to cause or contribute to air pollution. Where means are available to reduce 

effectively the contribution to air pollution from evaporation, leakage, or discharge, the installation and 

usage of such control methods, devices, or equipment shall be mandatory. [A.A. C. R18-2-730.F] 

B. Monitoring, Recordkeeping and Reporting Requirements [A.A.C. R18-2-306.A.3.c] 

1. Abrasive Blasting 

Each time an abrasive blasting project is conducted, Permittee shall log in ink or in an electronic format, 

a record of the following: 

a. The date the project was conducted; 

b. The duration of the project; and 

c. Type of control measures employed. 

2. Use of Paints 

a. Each time a spray painting project is conducted, Permittee shall log in ink or in an electronic format, 

a record of the following: 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 44 of65 
(1) The date the project was conducted; 

(2) The duration of the project; 

(3) Type of control measures employed; and 

(4) Material Safety Data Sheets for all paints and solvents used in the project. 

b. Architectural coating and spot painting projects shall be exempt from the recordkeeping requirements 

of part a. above. 

3. Roadway and Site Cleaning Machinery 

Permittee shall keep a record of all emission related equipment maintenance activities performed on 

roadway and site cleaning machinery stationed at the facility as per manufacturer's specifications. 

4. Demolition/Renovation 

As a means of demonstrating compliance with condition XI.A.4 of this Attachment, Permittee shall keep 

a record of all relevant paperwork on file. The relevant paperwork shall include but not be limited to 

the "NESHAP Notification for Renovation and Demolition Activities" form, and all supporting 

documents. 

5. Nonvehicle Air Conditioner Maintenance and/or Services 

As a means of demonstrating compliance with condition XI. A. 5 of this Attachment, Permittee shall keep 

a record of all relevant paperwork to the applicable requirements of 40 CFR 82 - Subpart F on file. 

C. Permit Shield 

Compliance with the terms of this section shall be deemed compliance with the following applicable 

requirement(s) in effect on the date of permit issuance: SIP Provision R9-3-527.C, A.A.C. Rl8-2-702.B, 

A.A.C. R18-2-702.C, A.A.C. R18-2-726, A.A.C. R18-2-727, A.A.C. R18-2-730.D, A.A.C. R18-2-730.F, 

A.A.C. R18-2-804.A, A.A.C. R18-2-1101.A.8, and 40 CFR 82 (Subpart F). 

XII. AMBIENT SULFUR DIOXIDE MONITORING 

A. Ambient Sulfur Oxides (Sulfur Dioxide) Standards 

1. The primary ambient air quality standards for sulfur oxides, measured as sulfur dioxide, are: 

a. 80 micrograms per cubic meter (0.03 ppm) -- annual arithmetic mean. 

b. 365 micrograms per cubic meter (0.14 ppm) --maximum 24-hour concentration not to be exceeded 

more than once per year. 

[A.A.C. R18-2-202.A] 

2. The secondary ambient air quality standard for sulfur oxides, measured as sulfur dioxide, is 1300 

micrograms per cubic meter (0.5 ppm)-- maximum 3-hour concentration not to be exceeded more than 

once per year. [A.A. C. R18-2-202.B] 

3. Violations 

a. Each exceedance of the annual S02 standard, as specified in paragraph A.1.a above, at each 

monitoring site, as described in Table C-4, Attachment "C" of this permit, shall constitute a violation 

of the standard. [A.A.C. R18-2-219(C)(1)] 

ASARCO -Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 45 of65 
b. One exceedance per year of the S02 standards prescribed in paragraphs A.1. b and A.2 above shall 

be allowed at each monitoring site listed under Table C-4, Attachment "C" of this permit. Each 

additional exceedance of the standards at each site shall constitute a violation of the standards. 

[A.A.C. Rl8-2-219(A) and (B)] 

B. Monitoring, Recordkeeping and Reporting Requirements 

1. Permittee shall continue to calibrate, maintain and operate any ambient sulfur dioxide monitoring 

equipment listed in Table C-4, Attachment "C" of the permit that is owned by the Permittee and in 

operation within the area ofthe smelter enclosed by a circle with 10-mile radius as calculated from a 

center point which shall be the point of the smelter's greatest sulfur dioxide emissions. 

[A.A.C. Rl8-2-715.02.E] 

2. Only those methods which have been either designated by USEPA as reference or equivalent methods 

or approved by the Director shall be used to monitor ambient air. [A.A.C. RI8-2-215(A)] 

3. Quality assurance, monitor siting, and sample probe installation procedures shall be in accordance with 

procedures described in the Appendices to 40 CFR 58. [A.A.C. RI8-2-215(B)] 

4. The Director may approve other procedures upon a finding that the proposed procedures are substantially 

equivalent or superior to procedures in the Appendices to 40 CFR 58. [A.A.C. Rl8-2-215(C)] 

5. Unless otherwise specified, interpretation of all ambient air quality standards contained in subsection 

XII.A of this Section shall be in accordance with 40 CFR 50. [A.A.C. Rl8-2-216(A)] 

6. The evaluation of air quality data in terms ofprocedure, methodology, and concept is to be consistent 

with methods described in A.A.C. R18-2, Appendix 10, "Evaluation of Air Quality Data". 

[A.A.C. Rl8-2-216(B)] 

7. Monthly reporting requirements [A.A. C. Rl8-2-715.02.E and Operating Permit No. 0308-85] 

Permittee shall, within twenty (20) calendar days after the end of each month, submit to the Director a 

report regarding the operation of the ambient sulfur dioxide monitors owned by the Permittee as listed 

in Table C-4, Attachment "C" of the permit. The monthly report shall contain the data and information 

as follows: 

a. For each ambient air monitor (concentrations in micrograms per cubic meter): 

( 1) Cumulative average concentration of sulfur dioxide in the ambient air; 

(2) Monthly average concentration of sulfur dioxide in the ambient air; 

(3) Maximum 3-hour average concentration of sulfur dioxide in the ambient air, and date and time 

of occurrence; 

( 4) Number of times the 3 -hour ambient sulfur dioxide standard was exceeded and the date, time, and 

concentration of each such occurrence; 

( 5) Maximum 24-hour average concentration of sulfur dioxide in the ambient air, and date and time 

of occurrence; 

(6) Number of times the 24-hour ambient sulfur dioxide standard was exceeded, and the date and 

concentration of each such occurrence; and 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 46 of65 
(7) Monthly data recovery (to the nearest tenth of a percent) and time periods when valid data is 

unavailable. 

b. For any exceedance ofthe 3-hour average sulfur dioxide concentration standard ofXII.A.2: 

(1) Average hourly concentrations in micrograms per cubic meter at the affected monitoring site(s) 

for the period three hours prior to the exceedance, three hours during the exceedance, and three 

hours after the exceedance of the 3-hour standard; and 

(2) Hourly emission rates in pounds per hour of sulfur dioxide for all points of emissions to the 

atmosphere being permanently monitored. Hourly emission rates shall be submitted for the 

period three hours prior to the exceedance, three hours during the exceedance, and three hours 

after the exceedance of the 3-hour standard. 

c. For any exceedance of the 24-hour average sulfur dioxide concentration standard ofXII.A.l.a: 

(1) Average hourly concentrations in micrograms per cubic meter at the affected monitoring site(s) 

for the period 24 hours prior to the exceedance, 24 hours during the exceedance, and 24 hours 

after the exceedance of the 24-hour standard; and 

(2) Hourly emission rates in pounds per hour of sulfur dioxide for all points of emissions to the 

atmosphere being permanently monitored. Hourly emission rates shall be submitted for the 

period 24 hours prior to the exceedance, 24 hours during the exceedance, and 24 hours after the 

exceedance of the 24-hour standard. 

C. Permit Shield 

Compliance with the terms of this section shall be deemed compliance with the following applicable 

requirement(s) in effect on the date of permit issuance: A.A. C. R18-2-202, A.A. C. R18-2-215, A.A. C. R18-

2-216, A.A.C. R18-2-219.A, A.A.C. R18-2-219.B, A.A.C. R18-2-219.C.1, and A.A.C. R18-2-715.02.E. 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 47 of65 
This page is left blank intentionally. 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 48 of65 
Table C-1. P 

Equipment 

ATTACHMENT "C": EQUIPMENT LIST 

Air Quality Control Permit No. 1000042 

for 

ASARCO Incorporated Ray Complex - Hayden Smelter 

dC IE ~cmpment . D 

' 

Quantity Manufacturer Model/Type Serial No. Date Installed Size 

or modified 

Sampling and Unloading Operations: 

Dump hopper 1 Linkbelt stainless steel lining n/a 1983 12':x28.6' 

Unloading conveyors 3 Linkbelt n/a 60"x17'8" 

Tripper car & belt 2 Linkbelt 51M n/a 1964/1968 cars: 30":x20' 

separator 

Bedding area - 4 Concrete n/a n/a 1964/1968 220'x40':x20' 

4 storage bins 

Bedding area- 1 Ty-rock I -surface/F300 7308 1967 4'x 8' 

Vibrating screen/ 

grizzly 

Reclaim hopper & 1 Feeder Belt, n/a n/a 1968 Hopper: 20 cy 

feeder Rex Chainbelt Belt feeder: 42" 

Inc. wid. x20' 

centers 

No.2 main inclined 1 n/a 50 HPmotor n/a 1982 24" width by 

conveyor 625' length 

No. 3 inclined 1 Boston Dulon 3 -ply n/a 1982 30" width by 

conveyor 600 439' length 

Delumper at oxygen 1 Jeffrey Jeffrey 5WR5 13492 1982 n/a 

furnace charge system Manufacturing /Reversible 

Division impactor 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 49 of65 

Rated Capacity New or 

Existing 

175 tph, 1,533,000 tpy Existing 

175 tph, 1,533,000 tpy Existing 

175 tph, 1,533,000 tpy Existing 

30,000 wet tons, Existing 

26,000 dry tons 

n/a Existing 

150 tph, 1,533,000 tpy Existing 

300 tph, 2,628,000 tpy Existing 

300 tph, 2,628,000 tpy Existing 

300 tph, 2,628,000 tpy Existing 
Equipment Quantity Manufacturer Model/Type Serial No. Date Installed Size Rated Capacity New or 

or modified Existing 

No.4 Horizontal 1 Boston Dulon 4-ply n/a 1982 4211 width by 300 tph, 2,628,000 tpy Existing 

Conveyor 600 139' length 

Flash Furnace Building Operations: 

Wet bin conveyors, 4 ASARCO n/a n/a 1983 3011 width 85 tph, 744,600 tpy Existing 

dryer feed & weigh design 

belts 

Hammer Mill 1 Pennsylvania GRT#1 n/a 1983 4211 X 1211 X 31 II 6tph, 52,560 tpy Existing 

Crusher 

Corporation 

Nos. 1 & 2 Fluid bed 2 Fuller 11-81-20337-106 n/a 1983 11'3 11 diameter Production: 64 wet ton!hr, New 

dryers with burners Farrier natural gas (ID shell) x 26' 560,640 tpy 

burners high Burner firing gas: 

38,000 CFH x 2 burners 

Burner firing oil: 

270 gph x 2 burners 

Maximum dryer usage: 

6,915 hours per year 

Blow tank pneumatic 1 Fuller/ Abresist n/a n/a 1983 411 4.2 tph, 36,792 tpy Existing 

conveyor (hammer mill 

feeds surge bin then 

material drops into line 

with air blown to dry 

dust bin) 

Fluid bed dryer product 2 Peabody PMTR-10-1692 TW n/a 1982 n/a Gas flow rate: 55,000 ACFM New 

baghouse Nos. 1 & 2 Process Pulse 

Systems, Inc. 

Dry screw conveyors 8 FMC n/a n/a 1983 16" and 911 56.9 tph, 498,444 tpy Existing 

# 1-8, furnace charge width 

system 

Feed screw conveyors 7 FMC n/a n/a 1983 12" width n/a Existing 

# 10-16, furnace charge 

system 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 50 of65 
Equipment Quantity Manufacturer ModeliType Serial No. Date Installed Size Rated Capacity New or 

or modified Existing 

200-ton west wet bins 2 nla nla nla 1983 nla nla Existing 

nos. 1 & 2 

200-ton dry bins nos. 1 4 DCE Vokes DLM V10/10 F3 nla 1983 Cloth area: 1050 acfrn Existing 

through 4, each served 20 envelope filter 105 sq. ft. 

by one ventilation bags 

baghouse 

30-ton dust bin no. 1 1 BHA 4 Cartridge Filters n/a 1998 Cloth area: 1200 acfrn Existing 

served by a ventilation 480 sq. ft. 

baghouse 

30-ton flux bin no. 3 1 Fuller Pulse nla 1983 Cloth area: 1200 acfrn Existing 

served by a ventilation 166 sq. ft. 

baghouse 

Oxygen flash furnace 1 In co with oxygen burner n/a 1983 24 ft. X 80 ft. 24,000 tpd concentrates New 

with burner (smelter) When process is down, 

furnace is kept hot with up to 

4 natural gas burners. 

Maximum gas usage is 91,113 

CFH. 

WGHS Venturi 1 Swemco Inc. SW-A-138696 14520 August, 1997 42" inlet flow rate 62,913 acfrn nla 

Scrubber Variable throat diameter 

WGHS Disengagement 1 Swemco Inc. SW-A-138696 14525-100 August, 1997 5' diameter inlet flow rate 62,913 acfrn nla 

vessel 

WGHS Condensing 1 Fleck, Ltd. 95-336 1781 1997 8' diameter 80 MBtulhr heat exchange nla 

Heat Exchanger Shell & tube vessel 

WGHS Saturation 1 Structural Steel Refractory lined wet nla fourth quarter 25' high X 8' 125,168 acfrn nla 

Tower and Fabrication tower 1997 dia. 

Company 

WGHS Stripping 1 Structural Steel Disk and Do-nut nla fourth quarter 34' high X 3' 1,032 acfrn n/a 

Tower and Fabrication 1997 dia. 

Company 

-------

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 51 of65 
Equipment Quantity Manufacturer Model/Type Serial No. Date Installed Size Rated Capacity New or 

or modified Existing 

Revert Crushing System: 

Feeder 1 Kue-Ken Hydro stroke feeder 270 1980 n/a 200 tph, 42,000 tpy New 

Jaw Crusher 1 Kue-Ken n/a 11011781 1980 25' x42' 200 tph, 42,000 tpy New 

Vibrating screen 1 Tyler Industry R1204X 502626 1980 n/a 200 tph, 42,000 tpy New 

Cone crusher 1 Kue-Ken n/a 3095132 1980 n/a 200 tph, 42,000 tpy New 

Belt conveyors 2 Kue-Ken BC-203 and BC- n/a 1980 n/a 200 tph, 42,000 tpy New 

206 

Revert crushing 1 Peabody PMTR-10-592W 01-5011-01 1989 6,974 sq. ft. 32,000 actin New 

baghouse Process pulse 

Systems, Inc. 

Converter Building: 

Converters 5 n/a Pierce Smith n/a 1969 one with 1 00 tons copper per cycle Existing 

Each converter has 13'x35', one 170 tons matte per cycle 

a natural gas burner with 13'x30' 40 tons cold dope per cycle 

to keep vessel and three with Maximum gas usage: 

heated during 13'x33' 17,695.8 CFHx1.5 converters 

holding fire. 

Converter silica 1 B.F. Goodrich Consists of three n/a 1968 24" belts 60 tph, 525,600 tpy Existing 

conveying system for belts unloading hoppers 44.3' length 

with conveying 

belts 

Converter primary 5 ASARCO Steel n/a 1999/2000 length 10.28 n/a Existing 

hooding design feet 

Converter cyclones 10 Ducon Model 1000 with n/a 1966 and 1968 1000 n/a Existing 

high efficiency 

duclones 

Converter spray I ASARCO Spray n/a 1973 n/a n/a Existing 

chamber 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 52 of65 
Equipment Quantity Manufacturer Model/Type Serial No. Date Installed Size Rated Capacity New or 

or modified Existing 

Converter secondary 1 ASARCO nla nla 1979 nla nla Existing 

hooding design 

Secondary hoods 1 Hosakawa 1000 J-10-30-TRH 950281 H1- 1996 Seven modules 300,000 acfm total working nla 

baghouse Mikropul pulse type H7 with 11,780 sq. volume, 0.1158 gr/dscf 

ft. per module maximum dust loading, and 

0.0861 gr/dscf inlet loading 

Gas Cleaning Plant: 

Process gas 4 Chemiebau Four train nla 1969 nla 200,000 scfm nla 

precipitators 

Gas Scrubbers 5 Rust Open towers (3) and nla 1961 nla nla nla 

Engineering packed (2) 

Mist precipitators 8 ASARCO Mist wet ESP nla 1983 180 tubes nla nla 

design Gas flows through 4 15 foot length 

parallel trains, each 

2 units deep, thus 4 

inlets and 4 outlets 

Gas cleaning plant 1 ASARCO nla nla 1967 nla nla nla 

pugmill 

Acid Plant: 

Acid plant 1 Monsanto double contact nla 1983 nla 2,820 STPD (100% acid nla 

basis) as 93% H2S04 using 

12.4% S02 24,703,200 STPY 

Acid plant preheater 1 Thermal Natural gas fired nla 1983 22.75'x8' O.D. 40,000 scfm of start up air Existing 

Transfer shell 107,925 CFH max. fuel input 

Corporation 

Anode Plant: 

Anode furnaces # 1 & 3 nla Fuller Co. nla 1971 13'x35' 3 3 0 ton per furnace Existing 

#2 with burners, Anode Natural gas fired Gas usage for both furnace: 

furnace #3 with burners 648 cfm max. measured and 

(spare) 736.7 cfm (402 gph) max. 

estimated 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 53 of65 
Equipment Quantity Manufacturer ModeliType Serial No. Date Installed Size Rated Capacity New or 

or modified Existing 

Anode steam boiler 1 Parker Packaged boiler nla 1995 90HP 3,780,000 Btu/hr Existing 

horizontal drum, 

natural gas fired 

Anode casting wheels, 2 Steams- nla nla 1972 29' diameter 24 mold Existing 

north & south Rodgers 

Corporation 

Anode launder burners 6 Hauck RFS 1120A nla 1972 2" nla Existing 

Natural gas fired 

Anode ladle burners 3 ASARCO Natural gas fired nla 1972 4" nla Existing 

Oxygen Plant: 

Oxygen plant boiler 1 General CB Packaged Boiler L-75227 1982 nla 8,740,000 Btu/hr Existing 

Electric 700X-300, natural 8,740 CFH designed natural 

gas fired gas usage 

Oxygen plant 1 Air Products Consists of main air nla 1983 nla 650 tpd gaseous oxygen Existing 

compressor, oxygen 5,694,000 tpy 

compressor, direct 

contact after cooler, 

liquid oxygen 

storage tank and 

cooling tower 

Furnace Ventilation Gas Control: 

R & R Electrostatic 1 ASARCOinc. Plate wire nla built in 1961 62'x76' 43,350 dsc:fm nla 

precipitator and expanded 

in 1968 

R & R ESP screw 17 Screw nla nla 1968 #1-15: 9" 12 tph, 105,120 tpy Existing 

conveyors #1-15, 17, Conveyor #17, 18: 12" 

18 Corporation 

R & R ESP Bucket 1 Automation 3-SA nla 1975 48' center to 35 tph, 306,600 tpy Existing 

Elevator Supply center L_ - --

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 54 of65 
Equipment Quantity Manufacturer Model/Type Serial No. Date Installed Size Rated Capacity New or 

or modified Existing 

R & R ESP Pugmill 1 Automation Double shaft n/a 1968 n/a 15 ton storage Existing 

Supply& 

Engineering 

Other Processes: 

Reverts (matte & slag) 1 Screen USA BF35E2/two deck 3011096 1996 4'x8' and 100 tph, 44,000 tpy New 

Screen #1, south of 4'x8' for closed 12'x14' 

acid tanks single deck and 

12'x14' for open 

single deck 

Reverts (matte & slag) 1 Grizzly Open single deck n/a 1994 10'x15' 200 tph, 40,000 tpy New 

Screen #2, south of 33/34" openings 

converter isle 

WTP lime silo 1 Portee 850-QLH/Steel n/a 1983 n/a 150 ton Existing 

WTP lime silo 1 Portee DF-44 n/a 1983 1 HP 1,176 cfm n/a 

baghouse 

0.5 million gallon 1 Garland Steel steel n/a fourth quarter 500,000 gallons n/a Existing 

diesel storage tank Company 1971 diameter 52 feet 

height 32 feet 

Table C-2. Stack Information - ----- -

Identification Description Building Size Exit Gas Temperature Exit Gas Velocity Height Inside Dimensions 

HP-1 Acid plant (main stack core) n/a 303 °F 19 fps 1000 feet 1 7 foot diameter 

HP-2 Main stack annulus (ventilation gases) n/a 135 °F 34 fps 920 feet 432 sq. ft. 

HP-4 Revert crusher baghouse stack n/a 99 °F 42 fps 46 feet 3.83 foot diameter 

HP-26 #2 acid plant preheater n/a n/a n/a 65 feet 5.42 foot diameter 

HP-28 Oxygen plant boiler n/a 346 °F (estimated) 1,650 scfm (estimated) 22 feet 1.66 foot diameter ----- ----

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 55 of65 
Identification Description Building Size Exit Gas Temperature Exit Gas Velocity Height Inside Dimensions 

HP-32 200 ton dry # 1 bin ventilation baghouse nla Unknown Capacity 1050 acfm 6 feet 0.5' X 0.5' 

(located inside furnace building) 

HP-33 200 ton dry #2 bin ventilation baghouse nla Unknown Capacity 1050 acfm 6 feet 0.5' X 0.5' 

(located inside furnace building) 

HP-34 200 ton dry #3 bin ventilation baghouse n/a Unknown Capacity 1050 acfm 6 feet 0.5' X 0.5' 

(located inside furnace building) 

HP-35 200 ton dry #4 bin ventilation baghouse nla Unknown Capacity 1050 acfm 6 feet 0.5' X 0.5' 

(located inside furnace building) 

HP-38 30 ton dust bin ventilation baghouse #1 (part n/a Ambient Capacity 480 acfm 12.25 feet 0.68' X 0.66' 

of pneumatic conveying system) 

HP-39 30 ton dust bin ventilation baghouse #2 (part n/a Ambient Capacity 480 acfm 12.25 feet 0.68' X 0.66' 

of pneumatic conveying system) 

HP-50 Anode steam boiler n/a n/a nla 32 feet 20 inch diameter 

Table C-3. Continuous Emission Monitoring Systems Information 

Type Manufacturer Model Serial No. Range Location 

Acid Plant Tail Gas S02 Ametek 4600B - Analyzer 6146 o-o.2o% soz At the acid plant exit prior to the 

Monitor 4000 - Control Station merging with the main flue to stack 

Acid Plant Tail Gas Flow EMRC/Rosemount Mark 5/ 3051CDIA22A1AB4M5 0306343 0-2.5 "HP Dp At the acid plant exit prior to the 

Monitor S-Type Pitot merging with the main flue to stack 

Acid Plant Tail Gas Lear Ziegler 1100M 0833 0-1 00% opacity At the acid plant exit prior to the 

Opacity Monitor merging with the main flue to stack 

R & R Flue Opacity Monitor Labs 550 5500157 0-100% opacity At outlet flue of the R & R Cottrell 

Monitor ESP prior to the merging with the 

secondary hoods off-gas flue 

Converter Secondary Ametek 4600B - Analyzer 5289 o-1.0% soz At the secondary hooding flue before 

Hoods Off-gas S02 4000 - Control Station baghouse 

Monitor 

ASARCO - Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 56 of65 
Type Manufacturer Model Serial No. Range Location 

Converter Secondary EMRC/Rosemount Mark 5/ 3051CD1A22AIAB4M5 86585 0-2.5 "HP Dp At the secondary hooding flue before 

Hoods Off-gas Flow S-Type Pitot baghouse 

Monitor 

Furnace Ventilation Gas Ametek 4600B - Analyzer 6274 0-0.4% so2 At the furnace vent flue prior to the 

S02 Monitor 4000 - Control Station merging with dryer exhaust gases 

Furnace Ventilation Gas EMRC/Rosemount Mark 5/ 3051CDlA22AlAB4E5 0538569 0-2.5 "H20 Dp At the furnace vent flue prior to the 

Flow Monitor S-Type Pitot merging with dryer exhaust gases 

Table C-4. Ambient Sulfur Dioxide Analyzers in the Hayden Area 

Identifier Unit Make/Model Owned and Operated by Location 

MTO Montgomery Ranch Thermo Environmental pulsed fluorescent Model43B ASARCO 2.52 miles northwest of ASARCO 

JL Jail - ASARCO Thermo Environmental pulsed fluorescent Model43C ASARCO 0.58 miles west of ASARCO 

HJO Hayden Junction Thermo Environmental pulsed fluorescent Model43B ASARCO 2.00 miles west of ASARCO 

GA Garfield A venue Thermo Environmental pulsed fluorescent Model43C ASARCO 0.56 miles south of ASARCO 

GHO Globe Highway Thermo Environmental pulsed fluorescent Model43B ASARCO 0.50 miles east of ASARCO 

JL Jail- ADEQ Thermo Electron pulsed fluorescent (TECO) Model40 ADEQ 0.58 miles west of ASARCO 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 57 of65 
This page is left blank intentionally. 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 58 of65 
ATTACHMENT "D": SULFUR BALANCE PROGRAM 

Air Quality Control Permit No. 1000042 

for 

ASARCO Incorporated Ray Complex- Hayden Smelter 

Appendix D-A. Procedures for Utilizing the Sulfur Balance Method for Determining Sulfur Emissions 

I. Determination of sulfur emissions for the smelter as a whole shall be subject to the following conditions: 

A. The emissions sum shall apply to all process sulfur emitted into the ambient air from smelter processing units 

and sulfur control and removal equipment associated with the smelting process. The total monthly amount 

of sulfur emissions is equal to the weight of the total sulfur introduced into the smelting process in any 

calendar month minus the weight of all the sulfur removed from the smelting process streams in that month 

in any physical form. Removed sulfur shall include, but not be limited to, sulfur contained in slag, anodes, 

sulfuric acid, flue dust, precipitator dust, WTP filter cake, cone settler overflow (CSO), reverts and 

miscellaneous hyproducts. All unaccounted for sulfur, including fugitive sulfur emissions, shall be considered 

as emissions to the ambient air. 

B. Material balances for sulfur described in I.A. above shall be obtained in accordance with the procedures listed 

in this Appendix which are equivalent to Appendix 8 to A.A.C. Title 18, Chapter 2. 

C. Average daily emissions are to be determined by dividing the total monthly emissions by the number of 

operating days in the particular month. 

II. Calculating input sulfur 

Total sulfur input is the sum of the product of the weight of each sulfur bearing material introduced into the 

smelting process as calculated in II.B. below multiplied by the fraction of sulfur contained in that material as 

calculated in II. C. below plus the amount of sulfur contained in fuel utilized in the smelting process as calculated 

in A.3 below. 

A. Material weight 

All sulfuric bearing materials, other than fuels, introduced into the smelting process shall be weighed. Such 

weighing shall be subject to the following conditions: 

1. Weight shall be determined on a belt scale, rail or truck scales, or other weighing device. 

2. Weight shall be determined within an accuracy of ±5 percent. 

3. All devices or scales used for weighing are to be calibrated to manufacturer's specifications. Scales will 

be calibrated at least quarterly. 

4. Sulfuric bearing materials subject to being weighed shall include, but not be limited to, concentrate, 

reverts which are not part ofthe internal circulating load, precipitates and miscellaneous outside products. 

Materials such as limestone and silica flux which are mixed with a charge of sulfur bearing materials shall 

be weighed and reported. 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 59 of65 
B. Sulfur content 

The sulfur content of all sulfur bearing materials introduced into the smelting process shall be calculated using 

the following steps: 

1. Sampling- The procedure to be followed in sampling is dependent upon the input vehicles for the sulfur 

bearing material. 

a. Railcar - The smelter operator shall collect a sample using the auger method. Six to nine holes per 

car will be taken and combined with the total sample. One to twenty cars from the same source will 

be combined into one lot. 

b. Truck- The smelter operator shall collect a 12 to 15 pound sample from each truckload. Samples are 

to be taken from one to six points using the auger method. Samples will be combined into lots from 

trucks delivering material from the same source. For fluxes, one truckload per day will be sampled. 

2. Sample preparation - each total sample shall be prepared for analysis in the following manner: 

a. If necessary, the sample shall be crushed to minus quarter inch particles. 

b. Each sample is to be thoroughly blended in a roto-cone blender or similar device. 

c. A blended composite sample is to be prepared based on individual sample weight and moisture. 

Material to be used in the composite sample is to be cut with a sample scoop or knife and used to 

make a 1800 gram composite sample for each lot. 

d. Each dry composite sample is pulverized to minus 100 mesh using a roto-disc pulverizer or similar 

equipment and then blended in a roto-cone blender or similar equipment. 

e. A 200 gram portion is to be cut from the composite sample for analysis. 

3. Sample analysis 

a. The sample shall be analyzed to determine sulfur content using LECO Sulfur Analyzer. The accuracy 

of such an analysis will be within a range of± 1 percent. 

4. Sulfur determination 

The sulfur content of all feed material treated per month will be determined by month and physical 

inventories in conjunction with certified scales for bed contents. Physical inventory determines beginning 

and ending bed contents for each month and all bed contents processed during the month, together with 

inventory changes for secondaries. Based upon individual lot numbers for each material processed (i.e. 

concentrates, reverts, purchased secondaries, and fluxes) the composite analysis will be used to determine 

sulfur input. 

C. Fuel sulfur content 

Sulfur in fuels shall be calculated by multiplying the amount of fuel delivered to the process by the fraction 

of sulfur in the fuel as reported to the smelter operator by the fuel's supplier. The sulfur content 

determination shall be accurate to within ±5 percent. 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 60 of65 
III. Calculating removed sulfur 

Total removed sulfur is the sum of the sulfur removed in each ofthe following products as determined by each 

process set forth below. 

A. Furnace slags 

1. The weight of the slag shall be determined using a count of furnace slag ladles. The weight used for slag 

ladles will be determined periodically. 

2. A sample will be collected from each slag ladle during tapping operations. 

3. The sample shall be prepared and analyzed for sulfur. The sample will be dried, pulverized using a rotadisc pulverizer, then a 200 gram sample will be split out using a Jones Splitter, or equivalent. 

4. The sample will be analyzed as in B.3 above. 

B. Scrubber blowdown 

1. Scrubber blowdown is collected (as a slurry), thickened and drum filtered. The filter cake is collected 

on a solar drying pad. An average truck payload weight is determined for all filter cake recycled onsite. 

When shipped, all railcars are weighed. The filter cake that is recycled onsite is stockpiled and sampled 

(minimum two holes, ten pounds). For shipment offsite, all railcars are sampled (three holes per car to 

make one composite for all cars). The sample will be prepared and analyzed for sulfur and copper using 

the procedures in II.A.3 and II.B.3 above. 

2. If filter cake is managed in a manner other than as set forth in III.B.1 above, it shall be quantified, 

sampled, and analyzed pursuant to generally acceptable methods. 

C. Strong acids 

1. An inventory of strong acids shall be taken daily. The inventory shall be increased by the amounts of acid 

shipped or otherwise transferred during that day. 

2. The daily inventory will be accurate to within ±5 percent. 

3. Strong acid analysis both at the acid plant and the laboratory is performed with a sonic analyzer that 

measures the velocity of sound in the acid. A temperature correction and the velocity are then used to 

determine the acid concentration. Samples are taken every two hours to compare to the on-stream 

analyzers. 

4. The product sample will be sent to the laboratory for daily analysis. 

5. All flow meters, density gauges, sonic sensors, pressure sensors, etc., used in determining the sulfur 

balance will be calibrated according to manufacturer's specifications or as needed. 

D. Weak acids 

1. The amount of weak acid discharged from the acid plant and scrubber systems is to be determined through 

flow meters. 

2. Flow meters will be calibrated as in C.5 above. 

ASARCO - Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 61 of65 
3. A 100 ml sample of weak acid shall be collected daily and combined in a sample container to form a 

monthly composite sample which is analyzed monthly for sulfur content using the Barium Sulfate 

Gravimetric Method. 

4. Weak acid railcars are loaded to a mark (20,125 gallons) and the total volume is determined by the 

number of railcars shipped. 

E. Sulfur in copper production 

1. The weight of copper produced is to be determined by weight of copper cast to an accuracy of within ±5 

percent. 

2. The weight and number of castings shall be recorded. 

3. Three samples per copper anode charge are to be obtained at the beginning, middle, and end of each pour. 

A portion (approximately 1 gram) from each sample becomes part of a monthly composite which is 

analyzed for sulfur content using a LECO Sulfur Analyzer with an induction furnace to volatilize the 

sulfur and measure the resultant compound using a titration method to an accuracy of within ±50 percent. 

F. Materials in process 

1. Total tonnage of materials in process shall be determined by physical inventory on the first day of each 

month. 

2. A monthly change of in-process inventory shall be calculated for each material in process by taking the 

difference between the inventory from each material in process on the first day of the preceding month 

and multiplying that difference by the monthly composite sulfur assay for that material. 

3. The change of monthly in-process inventory must be accurate to within ±50 percent. 

IV. General provisions 

A. The processes and procedures specified in the Appendix shall be available for inspection, review, and 

verification by the Department at all reasonable times. 

B. The sulfur capture and/or monitoring equipment may be replaced or changed from time to time without a 

permit revision to the extent such changes comply with A.A.C. R18-2-317 (facility allowed without permit 

revisions). 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 62 of65 
Appendix D-B. ASARCO Hayden Laboratory QA/QC Plan for Sulfur Analyses 

Sulfuric Acid - Shipments and Production 

section: 

reVISIOn: 

date: 

page: 

1. Operation: The Sulfuric Acid Analyzer will be operated as per manufacturer's instructions. 

2. Blank Analyses: A blank analysis consisting of deionized water will be analyzed daily. This will be compared 

to the velocity of sound in water and must fall within± 5% of the published value. 

3. Calibration Verification Sample: A standard sample will be analyzed with each set of samples. The Calibration 

Verification Sample must fall within ± 2% of its control value. The results of the analysis will be plotted on a 

control chart to indicate the control value is within three (3) standard deviations. 

4. Duplicates: Every twentieth (20) sample, or one sample from each analytical set, will be analyzed in duplicate. 

The relative standard deviation will be calculated and must fall within ± 20%. 

5. Quality Control Sample: A quality control sample will be analyzed quarterly. The analysis will compare within 

± 10%. (blind note: JTBaker Sulfuric acid 9681-02) 

6. Quality Assurance: When control limits are exceeded, the analysis will be repeated. If necessary, a supervisory 

chemist will be notified and the necessary steps will be taken to bring the analysis within control. No analyses 

will be reported or used as valid data, until the method is found to be under control. 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 63 of65 
Appendix D-C. ASARCO Hayden Laboratory QA/QC Plan for Sulfur Analyses 

LECO Sulfuric Analyzer- Concentrates and By-Products 

section: 

revision: 

date: 

page: 

1. Operation: The LECO Sulfur Analyzer will be operated as per manufacturers instructions. 

2. Blank Analyses: A blank analysis consisting of the crucible accelerator and cover will be analyzed with each set 

of samples. The blank value will be calculated assuming a 0.500 gm weight. Blanks that are above 0.10% must 

be replaced and the analysis repeated. 

3. Calibration Verification Sample: A standard sample will be analyzed with each set of samples. The Calibration 

Verification Sample must fall within ± 10% of its control value. The results of the analysis will be plotted on a 

control chart to indicate the control value is within three (3) standard deviations. 

4. Duplicates: All samples will be analyzed in duplicate. The relative standard deviation will be calculated and must 

fall within± 20%. 

5. Quality Control Sample: A quality control sample will be analyzed quarterly. The analysis will compare within 

± 10%. 

6. Quality Assurance: When control limits are exceeded, the analysis will be repeated. If necessary, a supervisory 

chemist will be notified and the necessary steps will be taken to bring the analysis within control. No analyses 

will be reported or used as valid data, until the method is found to be under control. 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 64 of65 
Appendix D-D. ASARCO Hayden Laboratory QA/QC Plan for Sulfur Analyses 

Weak Acid Solutions- Process Solutions 

section: 

revision: 

date: 

page: 

1. Method: ASARCO Standard Method No. 63, Sulfate in Water Samples. (Barium Sulfate Gravimetric Method) 

2. Blank Analyses: A blank analysis consisting of deionized water will be analyzed with each set of analyses. 

Blanks that are above 100 ppm must be replaced and the analysis repeated. The blank will be calculated for a 50 

ml sample. 

3. Calibration Verification Sample: A standard sample will be analyzed with each set of samples. The Calibration 

Verification Sample must fall within± 10% of its calculated control value. A 1.0000 gm sample of Anhydrous 

Sodium Sulfate will be used as the Calibration Verification sample. The calculated value of the sample will be 

13545.7 x purity of reagent. The Barium Sulfate residue will be calculated for a 50 ml sample. The results of the 

analysis will be plotted on a control chart to indicate the control value is within three (3) standard deviations. 

4. Duplicates: All samples will be analyzed in duplicate. The relative standard deviation will be calculated and must 

fall within± 20%. 

5. Quality Control Sample: A quality control sample will be analyzed quarterly. The analysis will compare within 

± 10%. (Blind note: JTBaker 0.2N Sulfuric acid 5960-02) 

6. Quality Assurance: When control limits are exceeded, the analysis will be repeated. If necessary, a supervisory 

chemist will be notified and the necessary steps will be taken to bring the analysis within control. No analyses 

will be reported or used as valid data, until the method is found to be under control. 

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 65 of65 

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- - - --- -----···- ·- --· --·- -----------·---- ---'"·-·---·-------. ·-- -------:------·---- ·--- ----- ··--·--· . . 

ARIZONA DEPAR.rMEN1' O.F ENVIRONJVIENTAL QUALIT'Y 

AIR QUALITY CONTROL 

PERlVIIT NUMBER 1000042 

Has been issued to ASARCO - Rav Comolex Havden Smelter 

P.O. Box 8 

Havden~ AZ 85235 

For operation of _ Copper Smelter 

Subject to terms and conditions therein and all applicable Arizona 

Revised Statutes and the Arizona Administrative Codt> .. 

,. ~ 

Number: · 1 00004 2 

' 

Issued: October 9, 2001 

Expires: October 9, 2006 c{}~ 

;. ©©[§)W 

,- -----

1 

Nancy C. Wrona, Director, Air Quality Division 

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TO BE FRAMED AND DISPLAYED. IN A CONSPICUOUS PLACE . . . I 

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