( 

# 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 offive years. Please keep us informed ofany changes that would affect your air pollution status during the period ofthis permit. You are advised that a permit is a legally enforceable document. Ifyour facility fails to comply with the provisions contained in its permit, you will be subject to enforcement action and could incur civil fines ofup 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. Ifyou have any questions, please do not hesitate to contact the Permits Section ofthe 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) 628-6733ARIZONA 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 controlpermitdoes not relieve applicant of responsibility for meetingallair pollution regulations I. PERMIT TO BE ISSUED TO (Business license name oforganization that is to receive pennit)

-----------------------



### ."·- . : ..**.t'J~ARCO-** 

### Ray**C~mplex** 

### Hayden Smelter
2. NAME (ORNAMES) OF OWNER OR PRINCIPALS DOING BUSINESS AS TilE ABOVE ORGANIZATION------------- 

### ASARCOIncorporated
3. MAILING ADDRESS 

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

### Hayden, AZ85235-0008-08 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 , 2006

__ 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 ofArizona 

### Jacqueline E. 

### Schafer, Director Arizona Department ofEnvironmental 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 oftheir Ray ComplexHayden 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 Smelteroperates 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. TheHayden Smelteris classifiedas a ClassI, MajorSource, pursuantto A.A.C. R18-2-101.61. Thepotential emission rates ofthe following pollutants are greater than 100 tons peryear: (i) particulate matter, (ii) sulfur dioxide, and (iii) nitrogen oxides. This Class I permit is issued in accordance with Title V ofthe Clean Air Act, and Title 49, Chapter 3 ofthe Arizona Revised Statutes. Applicablerequirements for the operations atHayden are listed in portions subtitled "Permitshield" ofthispermit. All definitions, terms, andconditionsused inthis permitconformto those intheArizonaAdministrative Code R18-2-101 et. seq. (A.A.C.) and 40 Code ofFederal Regulations (CFR), except as otherwise defined in this permit. Unless noted otherwise, references cited in the permitconditions referto the A.A.C. Allterms and conditions in this permit are enforceablebytheAdministrator ofthe United StatesEnvironmentalProtectionAgency (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 of65TABLE 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 ORREVISION
......................................... 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 ofthe 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 ofthe 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 FORFURNACE 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 ofthe 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 ofthis 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. OTHERPERIODIC 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 of65ATTACHMENT "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 of65IV.



## v. ATTACHMENT "A": GENERAL PROVISIONS Air Quality Control Permit No. 1000042 For 

## ASARCOIncorporated- Ray ComplexHayden 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 offive years from the date ofissuance ofthe permit. B. Permittee shall submit an application for renewal ofthis permit at least 6 months, but not more than 18 months prior to the date ofpermit 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 ofArizona air quality statutes and the air quality rules. Any permit noncompliance constitutes a violation ofthe Arizona Revised Statutes and is grounds for enforcement action; for permit termination, revocation andre-issuance, orrevision; or for denial ofa permit renewal application. Inaddition, noncompliancewithanyfederally enforceablerequirementconstitutes aviolation ofthe 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 ofthis permit.
VI. PERMITREVISION,REOPENING,REVOCATIONAND REISSUANCE, ORTERMINATIONFOR 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 byPermittee for a permit revision, revocation and reissuance, or termination; or ofa notification ofplanned changes or anticipated noncompliance does not stay any permit condition. B. The permit shall be reopened and revised under any ofthe following circumstances: 1. Additional applicable requirements under the Act become applicable to the Class I source. Such reopening shall only occurifthere are three ormoreyears remaining inthe permitterm. Thereopening shallbe completednot laterthan 18 months afterpromulgation ofthe applicablerequirement. No such reopening is required ifthe effective date ofthe requirement is later than the date onwhich 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 underthe acidrain program. Upon approvalbythe Administrator, excess emissions offsetplans 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 of65ofthe permit. 4. The Director or the Administrator determines thatthe permitneeds to be revised orrevoked 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 ofthis Attachment, affect only those parts ofthe permit for which cause to reopen exists. Suchreopenings shallbe made as expeditiously as practicable. Permitreopenings for reasons otherthan those stated in paragraph III.B.1 ofthis Attachment shall notresult in a resetting of the five year permit term.


### VII. POSTING OF PERMIT [A.A.C. R18-2-315] A. Permittee shall post suchpermit, or a certificate ofpermitissuance on locationwherethe 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 ofthe 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 ofthe 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 byMarch31 orninetydays aftertheDirectormakesthe inventoryform available each year, whichever occurs later, and shall include emission information for the previous calendaryear. B. The questionnaire shall be on a form provided bythe 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 ofthe source with respect to each permit condition. The first certification shall be submitted no later than May 15th, and shall report the compliance status ofthe source during the period between October 1st ofthe previous year and March 31st ofthe current year. The second certification shallbe submittedno laterthanNovember 15th, and shallreportthe compliance status ofthe source during the period between April 1st and September 30th ofthe current year. [A.A.C. R18-2-309.2.a] The compliance certifications shall include the following: 1. Identification ofeach term or condition ofthe permit that is the basis ofthe certification;

ASARCO -Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 6 of65XI. [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 ofthe 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 pursuantto Section XI.D ofthis Attachment. Progress reports submitted with compliance certifications shall satisfy the reporting requirements ofA.A.C. R18-2-309.5.d. [A.A.C. R18-2-309.2.c.v and 309.5.d] B. Acopyofall compliancecertificationfor ClassIpermits shall alsobe submittedtotheEPAAdministrator. [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 responsibleofficialof truth, accuracy, andcompleteness. Thiscertificationandanyothercertificationrequired underthis part shall state that, basedon information and beliefformed afterreasonable 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 allowthe Director orthe authorizedrepresentative ofthe Directorupon presentation ofproper 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 ofthe permit; B. Have access to and copy, atreasonable times, any records that are required to be keptunderthe conditions ofthe 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 ormonitor, at reasonable times, substances orparameters for the purpose ofassuring compliance with the permit or other applicable requirements; and E. Record any inspection by use ofwritten, electronic, magnetic and photographic media.
XIII. PERMIT REVISION PURSUANT TO FEDERAL HAZARDOUS AIR POLLUTANT STANDARD Ifthis source becomes subject to a standard promulgated by the Administrator pursuant to section 112(d) of the Act, then Permittee shall, withintwelve months ofthe 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 ofthe limits established by this permit. The report shall be in two parts as specified below:
a. Notification by telephone or facsimile within 24 hours ofthe time when Permittee first learned of the occurrence ofexcess emissions that includes all available information from XI.A.2 below. b. Detailed written notification by submission ofan excess emissions report as described in XI.A.2 below, within 72 hours ofthe notification paragraph a above. 2. The excess emissions report shall contain the following information:
a. The identity ofeach stack or other emission point where the excess emissions occurred; b. The magnitude ofthe excess emissions expressed in the units ofthe applicable emission limitation and the operating data and calculations used in determining the magnitude ofthe excess emissions;
c. The date, time and duration or expected duration ofthe excess emissions; d. The identity ofthe equipment from which the excess emissions emanated;
e. The nature and cause ofthe emissions; f. The steps taken, ifthe excess emissions were the result ofa malfunction, to remedythe malfunction and the steps taken or planned to prevent the recurrence ofthe malfunctions; g. The steps that were or are being taken to limit the excess emissions; and h. Ifthe source's permit contains procedures governing source operation during periods ofstartup or malfunction and the excess emissions resulted from startup or malfunction, a list ofthe steps taken to comply with the permit procedures. 3. Inthe case ofcontinuous orrecurring excess emissions, thenotificationrequirements ofthis subsection shallbe satisfiedif the sourceprovidestherequirednotificationafterexcess emissions are first detected and includes in such notification an estimate ofthe 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 orpreventive measures taken. Promptreporting shallmeanthatthereportwas submittedtothe Director by certified mail, facsimile, or hand delivery within two working days ofthe time when Permittee first learned ofthe occurrence ofthe deviations. 2. All instances of deviations from permit requirements shall be clearly identified in the required semiannual monitoring report specified in Attachment "B" ofthis permit, and shall be certified by the responsible official. [A.A.C. R18-2-306.A.5.a]

ASARCO -Hayden Smelter Air Quality PermitNo. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 8 of65C. EMERGENCY PROVISION [A.A.C. R18-2-306.E] 1. An "emergency" means any situation arising from sudden andreasonablyunforeseeable eventsbeyond the control ofthe source, including acts ofGod, which situation requires immediate corrective action torestorenormaloperation, andthatcausesthe sourcetoexceedatechnology-basedemission 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 ofpreventative 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 ifthe conditions ofparagraph 3 ofthis subsection are met. 3. Theaffirmativedefense ofemergency shallbedemonstratedthroughproperlysigned, contemporaneous operating logs, or other relevant evidence that:
a. An emergency occurred and that Permittee can identify the cause(s) ofthe emergency; b. The permitted facility was at the time being properly operated;
c. Duringthe period ofthe emergency, Permitteetook all reasonable steps to minimize levels ofemissions that exceeded the emissions standards or other requirements in the permit; and d. Permittee submitted notice ofthe emergency to the Director by certified mail, facsimile, or hand delivery within two working days ofthe time when emission limitations were exceeded due to the emergency. This notice shall contain a description ofthe emergency, any steps taken to mitigate emissions, and corrective action taken. 4. Inany enforcementproceeding, Permittee seeking to establishthe occurrence ofan emergencyhas the burden ofproof. 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 ofremedial 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 ofsampling or measurements; 2. The date(s) analyses were performed; 3. The name ofthe company or entity that performed the analyses; 4. A description ofthe analytical techniques ormethods used; 5. The results ofsuch analyses; and 6. The operating conditions as existing at the time ofsampling 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 ofall required monitoring data and support information for a period ofat least 5 years from the date of the monitoring sample, measurement, report, or application. Support informationincludes allcalibrationandmaintenancerecords andall original strip-chartrecordings orother datarecordingsfor continuousmonitoringinstrumentation, andcopiesofallreportsrequiredbythepermit.
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 ofAttachment "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 ofrecords required to be kept by the permit. For information claimed to be confidential, Permittee shallfurnish an additional copy ofsuchrecords directlytotheAdministrator alongwith a claim ofconfidentiality. B. IfPermittee has failed to submit any relevant facts or ifPermittee 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. Permitteemaymake changes atthepermitted sourcewithoutapermitrevision ifall of the following apply: 1. The changes are not modifications under any provision of Title I ofthe 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 of65rate ofemissions or in terms oftotal 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 permitterms and conditions that are monitoring (including test methods), recordkeeping, reporting, or compliance certification requirements. B. The substitution of an item ofprocess or pollution control equipment for an identical or substantially similar item ofprocess or pollution control equipment shall qualify as a change that does not require a permit revision, ifit meets all ofthe requirements ofsubsections (A) and (C) ofthis Section. C. Foreach such change under subsectionsA and B ofthis Section, awrittennotice by certifiedmail orhand delivery shall be received by the Director and, for Class I permits, the Administrator, a minimum of7 working days in advance ofthe change. Notifications ofchanges associated with emergency conditions, such as malfunctions necessitating the replacement ofequipment, may be provided less than 7 working days in advance ofthe change but must be provided as far in advance ofthe 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 ofeach such change. 3. Any change in emissions ofregulated air pollutants. 4. The pollutants emitted subject to the emissions trade, ifany. 5. The provisions in the implementation plan that provide for the emissions trade with which the source willcomply and anyotherinformation as mayberequiredbytheprovisions in the implementationplan 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 ofthe 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 operatorbasedonrepresentativeperformance ofthe source. Permittee shall make availableto theDirector suchrecords as maybe necessaryto determinethe conditions ofthe performancetests. 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 of65C. Performancetests shall be conducted and datareduced in accordance withthe testmethod andprocedures containedintheArizonaTestingManualunlessmodifiedbytheDirectorpursuanttoA.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 otherparameters 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 ofFinal Results Eachperformancetest shall consistofthree separateruns usingthe applicabletestmethod. Eachrun shall be conducted in accordance withthe applicable standard andtestmethod. Forthe purpose ofdetermining compliance with an applicable standard, the arithmetic means ofresults ofthe three runs shall apply. If a sampleis accidentallylostorconditionsoccurwhich are notunderthePermittee'scontrol andwhichmay invalidatetherun, compliancemay, upontheDirector's approval, be determinedusingthe arithmeticmean ofthe other two runs. Ifthe Director, or Director's designee, is present, tests may only be stopped with the Director's or such designee's approval. Ifthe Director or the Director's designee is not present, tests may only be stopped for good cause. Good cause includes, forced shutdown, failure ofan irreplaceable portion ofthe sampletrain, extrememeteorological conditions or otherconditions beyondthe Permittee's control. Termination ofany test without good cause after the first run is commenced shall constitute a failure ofthe test. Supporting documentation whichdemonstrates goodcausemustbe submittedwiththe test report. G. Report ofFinal Test Results A written report ofthe results ofall performance tests shall be submitted to the Director within 30 days after the test is performed. The report shall be submitted in accordance withthe ArizonaTesting 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 ofany sort, or any exclusive privilege.


### XXII. SEVERABILITY CLAUSE [A.A.C. R18-2-306.A.7] The provisions ofthis permit are severable. In the event ofa challenge to anyportion ofthis permit, orifany portion ofthis 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 of65XXIII. PERMIT SHIELD [A.A.C. R18-2-325] Compliance with the conditions ofthis permit shall be deemed compliance withthe applicable requirements identified in the portions ofthis permit subtitled "Permit Shield". The permit shield shall not apply to any changes made pursuant to Section XV.B ofthis Attachment and Section XVI ofthis Attachment.
XXIV. ACCIDENTAL RELEASE PROGRAM Ifthis source becomes subject to the provisions of40 CFR Part 68, then Permittee shall comply with these provisions according to the timeline specified in 40 CFRPart 68. [40 CFR 68]
XXV. PROTECTION OF STRATOSPHERIC OZONE Ifthis source becomes subject to the provisions of40 CFRPart 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 

## ASARCOIncorporated- Ray ComplexHayden Smelter I. GENERAL A. Abbreviations 1. "A.A.C. R18-2-xyz" stands for the ArizonaAdministrative Code, Title 18, Chapter2, 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 ofFederalRegulations, with standardreferences inthis permitbyTitle andPart, so that "40 CFR 60" means "Title 40 ofthe Code ofFederal Regulations, Part 60." 4. "NSPS" stands for the Standards ofPerformance 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. Thepermitconditions orportions of thepermitconditionswhicharematerialpursuanttoA.A.C. R18-2-331 and A.R.S. §49-464 are indicated by double underlinedand italicizedprint. C. Definitions 1. "Process source" means the last operation orprocess which produces an air contaminantresulting from either: [A.A.C. R18-2-701(22)]
a. The separation ofthe air contaminants from the process material, or b. The conversion of constituents ofthe process materials into air contaminants which is not an air pollution abatement operation. 2. "Fugitive emissions"meansthose emissions which couldnot reasonablypass through a stack, chimney, vent, or other functionally equivalent opening. [A.A.C. R18-2-101(49)] 3. "Non point source" means a source ofair 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 ofsulfur. [A.A.C. R18-2-701(14)] 5. "Low sulfur oil" means fuel oil containing less than 0.90% by weight ofsulfur. [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 of65D. For the purpose ofthis permit, the EPA Reference Method 9 reading shall be defined as an average of24 consecutive opacityobservationsrecorded at 15-second intervals. A setis composed ofany 24 consecutive observations. Sets need not be consecutive in time and in no case shall two sets overlap. For each set of 24 observations, calculatethe average by summingthe opacityofthe 24 observations and dividingthis 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 specifiedinthe applicable sectionofthisAttachment, Permittee shall onlyuse natural gas fuel for operation ofthe 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. Forthe purpose ofthis paragraph, the curtailmentperiods shallnotinclude durations when the natural gas market price is considered high for any reason. [Installation Permit No. 1166] F. Within 180 days ofissuance ofthis permit, Permittee shall have on staffa 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 ofany monitoring required in this Attachment and performed in the six months priorto the date ofthe report. All instances ofdeviations from requirements ofthe 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 ofthe Section 1. Applicability The requirements ofthis section are applicable to the following affected facilities: Nos. 1 and 2 Fuller fluid bed dryers, and the portion ofthe Inco oxygen flash furnace that uses the Monsanto sulfuric acid plant to comply with the sulfur dioxide standard set forth in II.B.3 ofthis section. 2. Definitions
a. "Startup" means the setting in operation ofan affected facility ofthis section for any purpose. [40 CFR 60.2] b. "Shutdown" means the cessation ofoperation ofan affected facility ofthis section for any purpose. [40 CFR 60.2]
c. "Malfunction"means any sudden, infrequent, and not reasonablypreventable failure ofairpollution control equipment, process equipment, or a process to operate in a normal orusual manner. Failures that are caused in part by poor maintenance or careless operation are not malfunctions.[40 CFR 60.2] 3. For the purpose ofthis permit, compliance with standards in this section, otherthan opacity standards, shallbe determined in accordancewithperformancetests. Theperformancetests shallbe conductedand data reduced in accordance with the test methods and procedures contained in subsection E ofthis section, "Performance Testing Requirements". [ 40 CFR 60.11(a) and 60.8(b)] 4. Forthe purpose ofthis permit, compliance with an opacity standard in this section shall be determined by conducting observations in accordance withEPAReference Method 9 in 40 CFRPart 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 PermitNo. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 15 of655. Permittee may submit, for purposes ofcompliance 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 thatthe COMS meets the requirements specified in 40 CFR60.13(c), that the COMS has beenproperly 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 ofthis section, including associated air pollution control equipment, in accordance withtheparticularrequirements specifiedunder subsection II.C, "Air Pollution Control Requirements". Determination of whether acceptable operating and maintenanceprocedures are beingused for these facilities shallbebased on information availabletothe Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection ofthe source. [40 CFR 60.11(d)] 7. For the purpose ofsubmitting compliance certifications or establishing whether or not Permittee has violated or is in violation ofany standard in this section, nothing in this section shall preclude the use, includingthe exclusiveuse, ofanycredible evidence orinformation,relevanttowhethera sourcewould 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 Atalltimes exceptfOrperiods o(startup. shutdown. andmalfunction as definedin paragraphsIlA.2.a. b andc ofthis Section. Permittee shallnotcause to be discharged into the atmospherefrom thefurnace and/or anv drvers o(this section, anv visible emissions which exhibit greater than 20percent opacity Opacity readings ofportions ofplumeswhichcontain condensed uncombinedwater vaporshallnotbe usedfor 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 ofthis section any gases which contain particulate matter in excess of50 mg/dscm (0.022 gr/dscf). Emissions in excess ofthe level ofthe applicable emission limit during periods ofstartup, shutdown, and malfunction shall notbe considered a violation ofthe 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 of0.065 percent by volume. Emissions in excess ofthe level ofthe applicable emission limit during periods ofstartup, shutdown, and malfunction shall notbe considered a violation ofthe 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)] Permitteeshalloperate theR&R CottrellESP. At all times, includingperiods ofstartup, 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 of652. 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 extentpracticable, continue to operate and maintain the Inco oxygen flash furnace and the Monsanto sulfuric acid plantin a manner consistentwith 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 andrecordthe opacity ofgases discharged intothe atmosphere from any dryerof this section. The**s~an** ofthis 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 ofperformingperiodic monitoring ofvisible emissions from the Inco oxygen flash furnace. [A.A.C. R18-2-306.A.3.c]
c. All the COMS underthis section shall meet40 CFR60, AppendixB, "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% ofspan value) and span (50to 100 percentofspanvalue)calibrationdrifts atleastonce daily in accordancewith awritten 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 ofexcess zero and span drift measured atthe 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 shallbe cleanedwhenthe ASARCO

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

# Icumulative 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 conditionusing a certifiedneutral density filter or other relatedtechniquetoproduce aknownobscurationofthe lightbeam. Allprocedures 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 ofoperation [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 ofone cycle of sampling and analyzing for each successive 1 0-second period and one cycle ofdata 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 shallbe calculated from 36 ormore datapoints equally spaced over each 6-minute period. (b) Datarecordedduringperiods ofsystembreakdowns,repairs, calibrationchecks, andzero and span adjustments shall not be included in the data averages computed under the previous paragraph. An arithmetic or integrated average ofall data may be used. 2. Tail Gas Sulfur Dioxide Monitoring
a. Permittee shall operatethe S02 CEMS installedatthe acidplanttailgas monitoring stationtomonitor and record S02 emissions discharged into the atmosphere from the Inco oxygen flash furnace. The span ofthis system shall be set at a sulfur dioxide concentration of0.20 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 ofthe appropriate six contiguous one-hour average sulfur dioxide concentrations provided by the S02 CEMS ofparagraph a above. [40 CFR 60.165(c)]
c. Permittee shall determine compliance with the S02 emission standard of0.065 percent by volume specified inparagraphII.B.3 ofthis section, using the S02 CEMS ofparagraph 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 ofthe 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 ofthe 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 ofCEMS. (3) Preventive maintenance ofCEMS (including spare parts inventory). (4) Datarecording, calculations, and reporting. (5) Accuracy audit procedures including sampling and analysis methods. (6) Program ofcorrective 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% ofspan value) and span (50 to 1 00 percent ofspan 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 ofexcess zero and span drift measured atthe 24- hour interval checks to be recorded and quantified. Ifthe data are automatically adjustedto the corrected calibration values (e.g., microprocessor control), Permittee shall program the S02 CEMS to record the unadjusted concentration measured in the calibration drift priorto resetting the calibration, ifperformed, or record the amount ofadjustment. [A.A.C. R18-2-312.H.3, 40 CFR 60.13(d)(1), 166(b) and Appendix F.4.2] (c) Ifthe S02 CEMS is out-of-control in terms ofthe 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 ofoperation [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 ofoperation (sampling, analyzing, and data recording) for each successive 15-minute period. (4) Data reduction procedures [40 CFR 60.13(h)] (a) Permittee shallreduce all data from the S02 CEMS to 1-houraverages. The 1-hour averages shall be computed from four or more data points equally spaced over each 1-hour period. (b) Datarecorded duringperiods ofcontinuous systembreakdowns, repairs, calibration checks,
ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 19 of65and zero and span adjustments shall notbe included in the data averages computedunderthe previous paragraph. An arithmetic or integrated average ofall 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 ofpollutant). (5) Excessive audit inaccuracy Ifthe S02 CEMS is out-of-control in terms ofthe excessive audit inaccuracy as defined in 40 CPRPart 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, orrelative accuracy audit, as prescribed in II.E.3 ofthis 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 CPRPart 60, AppendixF.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&Rflue COMS on a 24-hourrolling average excludingperiods ofstartup, shutdown, andmalfunction. If the 24-hourrolling average opacityexceeds 15 percent, Permittee shall initiate investigation ofthe relevant controls or equipment within 24 hours ofthe first discovery ofthe high opacity incident and, ifnecessary, 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 ofthe 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 systemormonitoring 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 ofsuch 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 ofexcess emissions for the reporting period is less than 1percent ofthe total operating time for the reporting period and the continuous monitoring system downtime for the reporting period is less than 5 percent ofthe 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 of65submitted unless requested bythe Department. All quarterly reports shall be postmarked bythe 30th day following the end ofeach 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 ofexcess emissions computed, any conversion factor(s) used, and the date and time ofcommencement and completion ofeach time period ofexcess 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 (ifknown), 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 ofthe 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 ofexcess emissions that shall be reportedunder 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 ofthe standard of0.065 percentbyvolume, as specified inparagraphII.B.3. TheDirector shall not consider emissions in excess ofthe level ofthe standard for less than orequalto 1.5 percent ofthe six-hour periods during the quarter as indicative ofa potential violation ofparagraph 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 controlpractice for minimizing emissions during these periods. Emissions in excess ofthe 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. DataAssessment 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 reportthe drift and accuracyinformation as a DataAssessmentReport (DAR), and include one copy ofthis DARfor each quarterly audit for the S02 CEMS. The DAR shall, as a minimum, contain the following information:

ASARCO- Hayden Smelter Air Quality PermitNo. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 21 of65(1) Permittee name and address. (2) Identification and location ofmonitors in the CEMS. (3) Manufacturer and model number ofeach monitor in the CEMS. (4) Assessment ofCEMS data accuracy and date ofassessment as determined by arelative 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 ofthe CEMS for the RAA or CGA, reference method results, cylinder gases certified values, CEMS responses, and calculations results as defined in 40 CFRPart 60, Appendix F, Section 6. Ifthe accuracy audit results showthe CEMS to be out-of-control as described in paragraphII.D.2.f(5), Permittee shall report both the audit results showing the CEMS to be out-of-control and the results ofthe 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) Summaryofall correctiveactionstakenwhenCEMSwasdeterminedout-of-control, as described in paragraphs II.D.2.f(2)(c) and II.D.2.f(5).
e. Permittee shall login inkorelectronicformat andmaintainarecord of24-houropacitymeasurements performed in accordance with II.DJ and corrective actions taken, if any. A record ofcorrective 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 ofthe 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 ofthis section, Permittee shallreport emissions exceeding an emission limitation or standard as deviations in accordancewith Section XI.B ofAttachment "A" ofthis 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 ofemissions from the Inco oxygen flash furnace andNos. 1and 2 fluid bed dryers in accordance withEPAReference Method 9to 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 ofparagraph II.D.2.a, at least once each calendar quarter. Successive quarterly audits shall occur no closerthan 2 months. The audits shallbe 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 of65Permittee shall conduct the RATA at least once every four calendar quarters in accordance with the relative accuracytest procedures specified in 40 CFR 60, AppendixB, Performance Specification 2, Section 7. EPA Reference Methods 3B, 4, and 6, or their approved alternatives, shall be used in conducting the RATA 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 offour 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 conductthe RAA in three offour 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 ofpermit 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 ofthe Section 1. Applicability The requirements ofthis section are applicable to the sulfur dioxide emissions plant wide. 2. Definitions
a. An "operating day", for the purpose ofthis 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 ofthis section, means the 365 calendar days immediately preceding the end ofeach day ofthe month being reported unless that period includes less than 300 operating days. Insuch casethenumberofdaysprecedingthe lastday ofthe complianceperiod 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 of652. Allowable sulfur dioxide emissions profile [A.A.C. R18-2-715(F)(2)(b)] The number ofthree-hour average emissions shall not exceedn cumulative occurrences in excess ofE, the emission level, shown in Table III-B-1 in any compliance period: T bl III B 1 All

a e 

## - - ow abl 

## so e 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 offugitive S02 emissions from the converter building, furnace building, and/or anode building:
a. ESPs; b. Settling chambers; c. Monsanto acidplant; d. Primary hoods for the converters; e. Secondary hoods for the converters; f. Secondary hoods baghousefor 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 ofdetermining total overall emissions, Permittee shall perform material balances for sulfur in accordance with the procedures prescribed in the Attachment D ofthis permit. [A.A.C. R18-2-715.01(0)] 2. Forpurposes ofdetermining compliance withthe cumulative occurrence and emission limits contained in paragraphs III.B.l and 2 ofthis 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 of65a measurement system for continuously monitoring sulfur dioxide concentrations and stack gas volumetric flow rates ofthe following: [A.A.C. R18-2-715.01(K), (K)(1) and (K)(2)]
a. gaseous stream at main flue ofthe five Pierce Smith converter secondary hoods; b. vent gas offugitive emissions captured by all the slag tapping hoods, matte tapping hoods, and slag return hoods; c. main gaseous stream to the center ofthe 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 TestProcedures 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 ofmeasurement 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 ofall 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. Themeasurement systemsinuse shallbe subjecttothemanufacturer'srecommendedzero 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 ofthese procedures shallbe 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 ofthe 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. Failureto measure any 12 consecutivehours ofemissions in accordancewiththe 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 thereplacementwithin sixhoursofanymonitoringequipmentpartwhichfails ormalfunctionsduring 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 of654. For purposes ofthis subsection, continuous monitoring means the taking and recording ofat least one measurement ofsulfur dioxide concentration and stack gas flow rate reading from the effluent ofeach 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 ifthe emissions from all monitored stacks, outlets or other approvedmeasurement locations are measured for at least 45 minutes ofany hour in accordance with the requirements ofthis subsection. [A.A.C. R18-2-715.01(K)(4)] 5. Forpurposes ofdetermining compliance withthe cumulative occurrence and emission limits contained in paragraphs ill.B.l and 2 ofthis section, the annual average emissions and three-hour emissions shall be determined as follows:
a. Permittee shall, atthe end ofeach 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 emissionlevel shallbe determinedusingthe sumtotal ofsulfur dioxide emissions from the smelter processing units and sulfur dioxide control and removal equipment. The capturedfugitive emissions shallbe included as part ofthetotal plantemissions, but not the uncaptured fugitive emissions and those emissions due solely to the use offuel 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 ofthis section, the following scenarios shall be considered violations ofthe 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 ofthis section shall be considered a violation ifeither: [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 ofan emission level (E) will be considered to violate the associated cumulative occurrence limit (n) listed in Table ill-B-1 ofthis section ifboth: (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 averagewasmeasured duringthe lastoperatingdayofthe complianceperiodbeingreported. [A.A.C. R18-2-715.01(E)]
c. A three-hour emissions average can only violate the cumulative occurrence limit (n) ofan 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 of65d. 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 ofany 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" ofthis permit. [A.A.C. R18-2-715.01(P)] b. Monthly reporting requirements All ofthe following measurementresults shallbe expressed as pounds perhour ofsulfur dioxide and shall be summarized monthly and submitted to the Director within 20 days after the end ofeach month: [A.A.C. R18-2-715.01(P)] (1) For all periods described in III.C.5 ofthis subsection, the annual average emissions (expressed in pounds per hour) as calculated at the end ofeach day ofthe month; (2) The totalnumber ofhourly periods duringthe month in whichmeasurements were nottaken and the reason for loss ofmeasurement for each period; (3) The number ofthree-hour emissions averages which exceeded each ofthe applicable emissions levels listed in Table III-B-1 for the compliance periods ending on each day ofthe month being reported; (4) The date on which a cumulative occurrence limit listed in Table III-B-1 was exceeded ifsuch 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 shallbe instrumented and monitoredto detect and record all periods thatthe 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 ofthe use ofthe 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 ofpermit issuance: A.A.C. R18-2-715.F.2, A.A.C. R18-2-715.0l.A, A.A.C. RlS-2-715.0l.B,A.A.C. RlS-2-715.0l.C,A.A.C. R18-2-715.01.E,A.A.C.RlS-2-715.0l.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 PermitNo. 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 ofthis 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 orpermitto be emitted into the atmosphere any plume or effluent from operation ofanyconverters and/orthe portion offurnace notassociatedwiththe Monsanto sulfuric acid plant, the opacity ofwhich exceeds 20 percent. Where the presence ofuncombined water is the only reason for the exceedance ofthe 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 permitthe discharge ofparticulate matter into the atmosphere from the furnace operation in total quantities in excess ofthe amount calculated by one ofthe following equations and rounded offto two decimal places:
a. Forthe furnace operation having a process weight rate of60,000 pounds perhour (30 tons perhour) 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. Pr = Total furnace process weight rate in tons-mass per hour, which is the total weight rate ofall materials introduced into the Inca oxygen flash furnace, including fuels, where these contribute to generation ofparticulate matters. It shall be the total process weight for the entire period ofcontinuous operation or for atypical portionthereof, divided by the number ofhours ofsuch period or portion thereof. b. Forthe furnace operation having a process weight rate greaterthan 60,000 pounds perhour (30 tons perhour), 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 ofparticulate 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 offto 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 of65determined by the following equation:

Where Ec Maximum allowable particulate emissions rate ofall the converters in operation in poundsmass per hour. Pc Total converters process weightrate 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 ofparticulate 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 ofcycles, divided by the hours ofactual 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 ofparticulate 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 bythe following equation: Ec = 17.31Pc0.16 Where "Ec'' and "Pc'' are defined as indicated in N.B.3.a. 

### C. AirPollution 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 shalloperate and maintain the convertersecondary hoods baghouse to minimize particulate emissions from the secondary hoods. [A.A.C. R18-2-317 Change to Operating PermitNo. 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,Permitteeshall. within 180daysfrom the effectivedate oft hispermit. install, calibrate, maintain, and operate a COMSdownstream 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 reportingrequirements as specified in II.D.1 and 4 ofthis attachment for the R&R Cottrell ESP COMS. 2. Permittee shall weigh the material enteringthe Inco flash furnace with a weightometer and shall count the number ofladles 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 of653. Particulate Matter Monitoring for Acid Plant Tailgas and Converter Secondary Hoods
a. In conjunction with the monitoring performed under paragraph II.D.3 ofthis attachment, Permittee shall also evaluate opacity measurements from the converter secondary hoods baghouse COMS described inparagraphiV.D.1 and the main flue COMS described in paragraphii.D.1.b on a24-hour rolling average. Ifthe 24-hour rolling average opacity exceeds 15 percent, Permittee shall initiate investigation ofthe relevant controls or equipment within 24 hours ofthe first discovery ofthe high opacity incident and, ifnecessary, take corrective action as soon as practicable to adjust orrepairthe 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 logininkorelectronicformat andmaintainarecordof24-houropacitymeasurements performed in accordance with paragraph a above and any corrective actions taken, ifany. A record ofcorrective 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 ofthe 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. Permitteeshall. within 180davsfrom the effectivedate oft hispermit. install, calibrate,maintain, and continuously operate a bag leak detection svstem at the converter secondary hoods baghouse to monitorthe baghouseperformance. Forthepurpose ofthis subsection, the bag leak detection system means an instrument that is capable ofmonitoring particulate matter loadings in the exhaust ofthe secondary hoods baghouse in orderto 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 leakdetection svstem shall be certifiedby 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 ofrelative 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 ofthe converter secondary hoods baghouse. (5) Thebagleakdetection system shallbe installed, operated, calibrated, andmaintainedin amanner consistentwiththemanufacturer'swritten specifications andrecommendations. Thecalibration ofthe system shall, at a minimum, consist ofestablishing the relative baseline output level by adjusting the sensitivity and the averaging period ofthe 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 of65c. Ifthe bag leak detection system alarms, Permittee shall initiate investigation ofthe secondaryhoods 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 ofthe particulate standard established in paragraphs 

### N.B.3 ofthis 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" ofthis permit. In the case of any alarming incident, the record shall include an identification ofthe date and time ofall bag leak detection alarms, their cause, and an explanation ofthe corrective actions taken, ifany. [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 conductperformancetests atleastonce everyyearwiththe following reference methods to determine compliance withthe particulate matter emissions standard set forth in

### N.B.2 and 3 ofthis 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 compliancebycomparingthe sumtotalofall emissionsfrom 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 ofthis section shall be deemed compliance with the following applicable requirement(s) in effect on the date ofpermit 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 PermitNo. 1166, Condition 7.


### V. CONVERTERS ARSENIC CHARGING RATE MONITORING A. General Provisions ofthe Section 1. The requirements ofthis section applyto any copperconverterunderthis permitwhere thetotal 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 of65At such time that Permittee becomes aware ofthe 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 ofthe coppermatte and ofany leadmattethat is chargedto 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 ofcopper 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 ofinorganic 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 ofarsenic in the copper matte charged during the month (%) as determined under paragraph b above. A1 Monthly average weightpercent ofarsenic in the lead matte charged during the month (%) as determined under paragraph b above. Wei Total weight ofcopper matte charged to a copper converter during the month (kg). W1 ; Total weight oflead matte charged to a copper converter during the month (kg). He= Total number ofhours the copper converter department was in operation during the month (h). n = Number ofcopper converters in operation during the month. 4. Determine an annual arsenic charging rate for the copper converter department once per month by computingthe arithmetic average ofthe 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 ofat least 2 years and make available to the Director upon request the following records:
a. For all converters, a monthly record ofthe weight percent ofarsenic contained in the copper matte and lead matte as determined under V.B ofthis 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 ofthis section. [40 CFR 61.176(c)(3)] 2. Permittee shall submit annually a written report to the Directorthat includes the monthly computations ofthe average annual converter arsenic charging rate as calculated under V.B.4 ofthis section. The annual report shall be postmarked by the 30th day following the end ofeach 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 ofpermit 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-TonDust Bin #2 9. WTP Lime Silo 

### B. Emission limits and Standards 1. Visible Emissions Permittee shall notcause, allow orpermitto be emitted into the atmosphere any plume oreffluentfrom any material storage facilities under this section, the opacity ofwhich 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 ofparticulate matter into the atmosphere from any affected material storage facilities under this section in total quantities in excess ofthe amount calculated by one ofthe following equations and rounded offto two decimal places:
a. For the material storage facilities having a process weight rate of60,000 pounds per hour (30 tons perhour) or less, the maximum allowable emissions shall be determined bythe following equation: E 3.59 p0.62 Where: E Maximum allowable particulate emissions rate in pounds-mass per hour. P Totalprocess weightrate intons-massperhour, which is thetotal weightrate ofall materials introduced into the bin, where these contribute to generation ofparticulate 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 ofparticulate matter for that process. b. For the material storage facilities having a process weight rate greater than 60,000 pounds perhour

ASARCO

- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 33 of65(30tons perhour), the maximum allowable emissions shall be determinedbythe 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 ofthe associated baghouses under this section when the material feeding is in process, using USEPA Reference Method 22. 2. Ifany ofthe 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 ofvisible emission observations includingthename oftheobserver, the date andtime onwhichthe observationwasmade, andthe results ofthe observation. Permittee shall also keep a record ofcorrective action taken, ifany. 

### 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 ofpermit 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. Primaryjaw crusher; 2. Vibrating screen; 3. Cone crusher; and 4. 4 conveyor belttransfer points, i.e., from primary crusherto 1st conveyor, from 1st conveyorto 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 emissionsthat exhibit greaterthan 20 percent opacity and/or anyprocess fugitive emissionsthatexhibit greater than 40 percent opacity. Where the presence ofuncombined water is the only reason for the exceedance ofthe 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 of652. 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 orpermitthe discharge ofparticulate matter into the atmosphere from the revert crushing plantunderthis section in total quantities in excess ofthe amount calculated by one ofthe following equations and rounded offto two decimal places:
a. Fortherevert crushing operationhaving aprocess weightrate of60,000 poundsperhour(30tons 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 Totalprocess weightrate intons-mass perhour, which is the total weightrate ofallmaterials introduced into the revert crushingplant, wherethese contributeto generation ofparticulate matters. It shall be the total process weight for the entire period ofcontinuous operation or for a typical portion thereof, divided by the number of hours of such period or portion thereof. b. Forthe revert crushing operation having a process weight rate greaterthan 60,000 pounds perhour (30 tons perhour), the maximumallowable emissions shallbe determinedbythe 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 ofmaterial 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. 

### Permitteeshalloperateabaghouse associatedwith the revertcrushingplantsubjecttotherequirements ofthis section with rated efficiency no lower than 99%. [Installation PermitNo. 1215, Conditions 2 and 3] 2. Particulates captured in the control facilities shall behandled and disposed in a mannerwhich prevents re-entrainment into the atmosphere. [Installation PermitNo. 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 ofoperation and process weightrate in tons-mass per hourto 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 ofissuance ofthis permit, Permittee shall conduct at least one certified method 9 performance test in accordance with section XVII ofattachment "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 of65opacity level. Within 30 days ofestablishing 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 visibleemissionsfrom the subjectbaghousewhen it is in operation. Permittee shallkeep arecord ofthe name ofthe observer, the date on which the observation was made, and the results ofthe observation. (2) Ifthe observer sees a plume from the subjectbaghouse that on an instantaneous basis appears to exceedthe baseline opacitylevel, thenthe observer shalltake a six-minute Method 9observation of the plume. If conditions prevent the observation, the observer shall document these conditions. (3) Ifthe six-minute opacity ofthe plume is less than the baseline level, Permittee shall make a record ofthe following: (a) name ofthe observer; (b) date, and time ofthe test; and (c) the results ofthe method 9 observation. (4) Ifthe six-minute opacity ofthe plume exceeds the baseline level but is less than the 20 percent opacity standard, Permittee shall adjust orrepair the controls or equipmentto reduce opacityto below the baseline level. Permittee shall also make a record ofthe following: (a) name ofthe observer; (b) date, and time ofthe test; (c) the results ofthe method 9 observation; and (d) corrective action taken. (5) Ifthe six-minute opacity ofthe plume exceedsboththe 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 reportthe incident as an excess emission for opacity. Permittee shall also make a record ofthe following: (a) name ofthe observer; (b) date, and time ofthe test; (c) the results ofthe 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] Ifnecessitated by the results ofthe monthly monitoring, Permittee may re-establish the baseline opacitylevel. Re-establishmentof thebaseline shallbeperformedutilizingthe sameproceduresused 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 ofthe need for re-establishing the baseline(s). 3. Monthly monitoring for opacity ofprocess 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 ofall

ASARCO- Hayden Smelter Air Quality Permit No. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 36 of65process fugitive emissions from the revert crushing plant when it is in operation. b. Ifthe observer, during the visual survey, does not see any plume from any fugitive source that on an instantaneous basis appears to exceedthe 40 percent opacity standard, thenthe observer shall record his/her name, the date on which the observation was made, and the results ofthe observation.
c. Ifthe 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. Ifconditions prevent the observation, the observer shall document these conditions. d. Ifthe six-minute opacity ofthe plume is less than the 40 percent opacity standard, Permittee shall make a record ofthe following: (1) name ofthe observer; (2) source, date, and time ofthe test; and (3) the results ofthe method 9 observation.
e. Ifthe six-minute opacityofthe 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 ofthe following: (1) name ofthe observer; (2) source, date, and time ofthe test; (3) the results ofthe 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 ofthis 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 holderofMethod 5maybe operatedwithoutheaters ifthe gas streambeing 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 Compliancewiththe terms ofthis section shallbe deemed compliance withthe applicablerequirements set forth in Installation PermitNo. 1215 in effect on the date ofpermit issuance.
VIII. FUEL BURNING EQUIPMENT 

### A. General Provisions ofthis 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 of65products ofcombustionpassthrough a stack orother outlet. Compliancetests shall beconductedduring operation at the nominal rated capacity ofeach unit. The total heat input ofall fuel-burning units on a plant or premises shall be used for determining the maximum allowable amount ofparticulate 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 ofwhich 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 permitthe emission ofparticulate matter, caused bycombustion offuel from operation ofthe acid plant preheater, the anode steam boiler, and/or the oxygen plant boiler, in excess ofthe amount calculated by the following equation: E = 1.02 

### Q 0'769 where: E The maximum allowable particulate emissions rate in pounds-mass perhour. 

### Q The heat input in million Btu per hour. [A.A.C. Rl8-2-724(C)(1)] b. Permittee shall not cause, allow or permitthe discharge ofparticulate matter into the atmosphere in any 1hour from any anode launderburners and/or any anode ladle burners underthis section intotal quantities in excess ofthe amounts calculated by 1 ofthe following equations: (1) For process sources having a process weight rate of60,000 pounds perhour (30 tons perhour) 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 ofthis section, the total process weight from all similar units employing a similar type process shall be used in determining the maximum allowable emission ofparticulate 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 of653. Sulfur Dioxide [A.A.C. R18-2-730(A)(2)] Permitteeshallnotcause, alloworpermitthe emission ofsulfurdioxide from any anode launderburners 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 ofvisible emissions emanatingfrom the stacks ofthe acidplantpreheater, the anode steamboiler, and/orthe oxygenplant boiler. Ifthe opacity ofthe 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 ofthe Method 9 observation shall be maintained. [A.A.C. R18-2-306.A.3.c] b. For the purpose ofreports under excess emissions reporting required by Section XI.A, Attachment "A" ofthis permit, Permittee shall report all six-minute periods in which the opacity ofany 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) approvedTariffagreementthatcontainsthe sulfurcontentandthelowerheating value ofthe natural gas fuel in use. b. Permittee shall maintain a record ofthe fuel firing rate (cubic feet per hour ofnatural 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 particulatematter and sulfur dioxide emissions from the acidplantpreheater,the anode steamboiler, and the oxygen plant boiler ofthis section. 

### D. Permit Shield Compliance with the terms ofthis section shall be deemed compliance with the following applicable requirement(s) in effect on the date ofpermit 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 ofthis Section applyto 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 screwconveyors#10-16,thehammermill, theblowtankpneumatic 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, andthe converterbuilding. The fugitive emissions are those emissions as defined in paragraph I.C.2 ofthis Attachment. 

### B. Opacity Standard Permittee shall notcause, alloworpermittobe emitted intothe atmosphere anyplume oreffluentfrom any affectedfacilities underthis Section,the opacityof whichexceeds40percent,measuredin accordancewith EPAReferenceMethod 9. Wherethepresence ofuncombined water is the onlyreasonfor the exceedance ofthe 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 underthis Sectionwhen the facility is in operation. 2. Ifthe observer, during the visual survey, does not see any plume from any fugitive source that on an instantaneous basis appears to exceedthe opacity standard, thenthe observer shall recordhis/hername, the date on which the observation was made, and the results ofthe observation. 3. Ifthe observer sees a plume from a fugitive source that on an instantaneous basis appears to exceedthe 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. Ifthe six-minute opacity ofthe plume is less than the opacity standard, Permittee shall make a record ofthe following:
a. name ofthe observer; b. source, date, and time ofthe test; and c. the results ofthe method 9 observation. 5. Ifthe six-minute opacity ofthe plume exceeds the opacity standard, Permittee shall adjust orrepairthe controls or equipmentto reduce opacityto belowthe opacity standard and reportthe incident as excess emissions. Permittee shall also make a record ofthe following:
a. name ofthe observer; b. source, date, and time ofthe test; c. the results ofthe 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 ofthe three anode furnaces under this section, provided only two furnaces can be in operation at a time. 

### E. Permit Shield Compliancewiththeterms ofthis section shallbe deemed compliancewiththe applicablerequirements set forth in A.A.C. R18-2-702.B and A.A.C. R18-2-702.C in effect on the date ofpermit 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, storagepiles ormaterialhandlingin excess of40% opacitymeasured in accordance withthe 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 othertypes ofaircontaminants to a minimum in an open areawhere 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 byusing an approved dust suppressant, or adhesive soil stabilizer, orbywetting, 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 ofspray 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 machineryutilized at storage piles at all times with a minimum fall ofmaterial, or with the use ofspray 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 ofsite, roadway, oralley. Earthorothermaterial shallberemovedfrom paved streets ontowhich earth or other material has been transported bytrucking 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 eitherADEQ orthe local officerdelegatedthe authority for issuance ofopenburningpermits, 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 ofthe name ofthe observer,the date onwhichthe observationwasmade, and the results ofthe observation. (2) Ifthe observer sees a plume from a non-point source that on an instantaneous basis appears to exceed 40%, then the observer shall, ifpossible, take a six-minute Method 9 observation ofthe plume. Ifconditions prevent the observation, the observer shall document these conditions. (3) Ifthe six-minute opacity ofthe plume is less than 40%, the observer shall make a record ofthe following: (a) Location, date, and time ofthe observation, and the name ofthe observer; and (b) The results ofthe Method 9 observation. (4) Ifthe six-minute opacity ofthe 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 ofAttachment "A". b. Permittee shall maintain records ofthe dates on which any ofthe activities listed in X.A.1.b( 1) through (9) ofthis section were performed and control measures adopted. [A.A.C. Rl8-2-306.A.3.c] 2. Open Burning Themonitoringrequirementsfor SectionX.A.2 ofthis attachmentmaybecompliedwithbymaintaining copies ofall 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 ofpermit 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 of40% opacity, measured in accordance with EPAReference Method 9. Where the presence ofuncombined water is the only reason for the exceedance ofany visible emissions requirements, such exceedance shall not constitute a violation. [A.A.C. R18-2-702.B and C] 2. Use ofPaints While performing spray painting operations Permittee shall comply with the following requirements:
a. Permittee shallnotconductorcausetobeconductedany spraypaintingoperationwithoutminimizing organic solvent emissions. Such operations otherthan architectural coating and spot painting, shall be conducted in an enclosed area equipped with controls containing no less than 96 percent ofthe 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-chemicallyreactive solvents for industrial or commercial purposes; or (2) Thin or dilute any architectural coating with a photochemically reactive solvent.
c. Forthe purposes ofparts b. and e. ofthis condition, a photochemically reactive solvent shall be any solvent with an aggregate ofmore than 20 percent ofits total volume composed ofthe chemical compounds classified in paragraphs (1) through (3) ofthis subsection, or which exceeds any ofthe following percentage composition limitations, referred to the total volume ofsolvent: [A.A.C. R18-2-727.C] (1) A combination ofthe following types ofcompounds having an olefinic or cyclo-olefinic type of unsaturation

- hydrocarbons, alcohols, aldehydes, esters, ethers, or ketones: five percent (2) A combination ofaromatic compounds with eight ormore 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 ofan organic solvent may be classified from its chemical structure into more than one ofthe groups or organic compounds described in XI.A.2.c(1) through (3), it shall be considered to be a member ofthe group having the least allowable percent of the total volume ofsolvents. [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 of65e. Permittee shall notdisposebyevaporationmorethan 1.5 gallonsofphoto-chemicallyreactive 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%, measuredin accordancewithbyEPAReferenceMethod 9. Wherethepresence ofuncombinedwater is the only reason for the exceedance ofany 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 permitto 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 ofthe requirements of40 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 notemit gaseous orodorous materials from equipment, operations orpremisesunderhis 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 orvolatile compounds in such a manner and by such means thattheywill not evaporate, leak, escape, orbe otherwise discharged into the atmosphere so as to cause or contribute to air pollution. Where means are available to reduce effectivelythe contributionto airpollution from evaporation, leakage, ordischarge, the installation and usage ofsuch 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 Eachtime an abrasive blastingprojectis conducted, Permittee shall log in inkorin anelectronic format, a record ofthe following:
a. The date the project was conducted; b. The duration ofthe project; and c. Type ofcontrol measures employed. 2. Use ofPaints
a. Each time a spraypaintingproject is conducted, Permittee shall log in ink or in an electronic format, a record ofthe 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 ofthe project; (3) Type ofcontrol measures employed; and (4) Material Safety Data Sheets for all paints and solvents used in the project. b. Architecturalcoatingand spotpainting projects shallbe exemptfromtherecordkeeping requirements ofpart a. above. 3. Roadway and Site Cleaning Machinery Permittee shall keep a record ofall 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 ameans ofdemonstratingcompliancewithconditionXI.A.4 ofthisAttachment, Permittee shallkeep a record ofall 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 ameans ofdemonstratingcompliancewithconditionXI.A.5ofthisAttachment, Permittee shallkeep a record ofall relevant paperwork to the applicable requirements of40 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 ofpermit 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 peryear. [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"ofthis permit, shall constitute aviolation ofthe standard. [A.A.C. R18-2-219(C)(1)]

ASARCO -Hayden Smelter Air Quality PermitNo. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 45 of65b. One exceedance per year ofthe 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" ofthis permit. Each additional exceedance ofthe standards at each site shall constitute a violation ofthe 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" ofthe 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 ofthe 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 installationprocedures shallbe in accordance with procedures described in the Appendices to 40 CFR 58. [A.A.C. RI8-2-215(B)] 4. TheDirectormayapprove otherproceduresuponafindingthattheproposedproceduresare 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 ofall ambient air quality standards contained in subsection XII.A ofthis Section shall be in accordance with 40 CFR 50. [A.A.C. Rl8-2-216(A)] 6. The evaluation ofair quality data in terms ofprocedure, methodology, and concept is to be consistent with methods described in A.A.C. R18-2, Appendix 10, "Evaluation ofAir Quality Data". [A.A.C. Rl8-2-216(B)] 7. Monthly reporting requirements [A.A.C. Rl8-2-715.02.E and Operating PermitNo. 0308-85] Permittee shall, within twenty (20) calendar days after the end ofeach month, submit to the Director a report regarding the operation ofthe ambient sulfur dioxide monitors owned by the Permittee as listed in Table C-4, Attachment "C" ofthe permit. The monthlyreport shall containthe data and information as follows:
a. For each ambient air monitor (concentrations in micrograms per cubic meter): (1) Cumulative average concentration ofsulfur dioxide in the ambient air; (2) Monthly average concentration ofsulfur dioxide in the ambient air; (3) Maximum 3-hour average concentration ofsulfur dioxide in the ambient air, and date and time ofoccurrence; (4) Numberoftimesthe 3-hourambient sulfurdioxide standardwas exceededandthe date,time, and concentration ofeach such occurrence; (5) Maximum 24-hour average concentration ofsulfur dioxide in the ambient air, and date and time ofoccurrence; (6) Number oftimes the 24-hour ambient sulfur dioxide standard was exceeded, and the date and concentration ofeach 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 ofthe 3-hour standard; and (2) Hourly emission rates in pounds per hour of sulfur dioxide for all points ofemissions 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 ofthe 3-hour standard.
c. For any exceedance ofthe 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 ofthe 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 priorto the exceedance, 24 hours during the exceedance, and 24 hours after the exceedance ofthe 24-hour standard. 

### C. Permit Shield Compliance with the terms of this section shall be deemed compliance with the following applicable requirement(s) in effectonthe date ofpermitissuance: 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 of65Table 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 ormodified 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 PermitNo. 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 ExistingEquipment 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 11'311 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 CFHx 2 burners Burner firing oil: 270 gph x 2 burners Maximum dryer usage: 6,915 hours per year Blowtank 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 of65Equipment Quantity Manufacturer ModeliType Serial No. Date Installed Size Rated Capacity New or ormodified 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 Inco 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 of65Equipment Quantity Manufacturer Model/Type SerialNo. Date Installed Size Rated Capacity New or ormodified 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 ofthree 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 PermitNo. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 52 of65Equipment 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/dscfinlet 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 ofstart 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 30 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 of65Equipment Quantity Manufacturer ModeliType Serial No. Date Installed Size Rated Capacity New or ormodified 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 ofmain 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 of65Equipment Quantity Manufacturer Model/Type Serial No. Date Installed Size Rated Capacity New or ormodified 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 crusherbaghouse 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 PermitNo. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 55 of65Identification Description Building Size Exit Gas Temperature Exit Gas Velocity Height Inside Dimensions HP-32 200 ton dry # 1bin 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' ofpneumatic 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' ofpneumatic 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 Atthe 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 Atthe 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 0-100% opacity Atthe acid plant exit priorto the Opacity Monitor merging with the main flue to stack R & R Flue Opacity Monitor Labs 550 5500157 0-100% opacity At outlet flue ofthe 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 Atthe 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 of65Type Manufacturer Model Serial No. Range Location Converter Secondary EMRC/Rosemount Mark 5/ 3051CD1A22AIAB4M5 86585 0-2.5 "HP Dp Atthe secondary hooding flue before Hoods Off-gas Flow S-Type Pitot baghouse Monitor Furnace Ventilation Gas Ametek 4600B

- Analyzer 6274 0-0.4% 

### so2 Atthe furnace vent flue prior to the S0

### 2 Monitor 4000

- Control Station merging with dryer exhaust gases Furnace Ventilation Gas EMRC/Rosemount Mark 5/ 3051CDlA22AlAB4E5 0538569 0-2.5 "H

### 2 0 Dp Atthe 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 ofASARCO JL Jail

- ASARCO Thermo Environmental pulsed fluorescent Model43C ASARCO 0.58 miles west ofASARCO HJO Hayden Junction Thermo Environmental pulsed fluorescent Model43B ASARCO 2.00 miles west ofASARCO GA Garfield Avenue Thermo Environmental pulsed fluorescent Model43C ASARCO 0.56 miles south ofASARCO GHO Globe Highway Thermo Environmental pulsed fluorescent Model43B ASARCO 0.50 miles east ofASARCO JL Jail- ADEQ Thermo Electron pulsed fluorescent (TECO) Model40 ADEQ 0.58 miles west ofASARCO

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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 ofsulfur emissions for the smelter as a whole shall be subject to the following conditions: A. The emissions sum shall applyto all process sulfur emitted into the ambient airfrom smelterprocessingunits and sulfur control and removal equipment associated with the smelting process. The total monthly amount of sulfur emissions is equal to the weight ofthe total sulfur introduced into the smelting process in any calendar month minus the weight ofall 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 miscellaneoushyproducts. Allunaccountedfor sulfur, includingfugitive sulfuremissions, shallbeconsidered as emissions to the ambient air. B. Materialbalancesfor sulfurdescribed inI.A. above shallbe obtainedin accordancewiththeprocedures 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 ofthe product ofthe 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. belowplus the amount ofsulfur contained in fuel utilized inthe smeltingprocess as calculated in A.3 below. A. Material weight All sulfuric bearing materials, otherthan 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 ortruck 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 calibratedto 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, revertswhicharenotpartoftheinternal circulatingload, precipitates and miscellaneous outsideproducts. Materials suchas limestone and silicafluxwhichare mixedwith a charge ofsulfurbearingmaterials 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 of65B. Sulfur content The sulfurcontentofall sulfurbearingmaterials introducedintothe smeltingprocess shallbe calculatedusing 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 smelteroperator shall collect a 12 to 15 pound sample from eachtruckload. 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. Ifnecessary, 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 analyzedto determine sulfurcontentusingLECO SulfurAnalyzer. The accuracy ofsuch an analysis will be within a range of±1percent. 4. Sulfur determination The sulfur content of all feed material treated per month will be determined by month and physical inventories inconjunctionwithcertifiedscalesforbedcontents. Physicalinventorydeterminesbeginning 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, andfluxes) thecompositeanalysiswillbeusedto determine sulfur input. C. Fuel sulfur content Sulfur in fuels shall be calculated by multiplying the amount offuel 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 of65III. Calculating removed sulfur Total removed sulfur is the sum ofthe sulfur removed in each ofthe following products as determined by each process set forth below. A. Furnace slags 1. The weight ofthe slag shall be determined using a count offurnace slag ladles. The weightused for slag ladles will be determined periodically. 2. A sample will be collected from each slag ladle during tapping operations. 3. The sample shallbe prepared and analyzed for sulfur. The sample will be dried, pulverizedusing 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 copperusing 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. Aninventoryofstrong acids shallbetaken daily. The inventory shallbeincreasedbythe amounts ofacid 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 ofsound 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 amountofweakaciddischargedfromthe acidplantand scrubber systems is to be determinedthrough flow meters. 2. Flow meters will be calibrated as in C.5 above.

ASARCO

- Hayden Smelter Air Quality PermitNo. 1000042 (Issued on 10/09/01 and printed on 3/25/05) Page 61 of653. A 100 ml sample ofweak 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 ofrailcars shipped. E. Sulfur in copper production 1. The weight ofcopper produced is to be determined byweight ofcopper castto an accuracy ofwithin ±5 percent. 2. The weight and number ofcastings shall be recorded. 3. Three samples per copperanode charge areto be obtained atthebeginning, middle, and end ofeachpour. 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 sulfurand measure the resultant compound using atitrationmethodto an accuracy ofwithin±50 percent. F. Materials in process 1. Total tonnage ofmaterials in process shall be determined by physical inventory on the first day ofeach month. 2. A monthly change ofin-process inventory shall be calculated for each material in process bytaking the difference between the inventory from each material in process on the first day ofthe preceding month and multiplying that difference by the monthly composite sulfur assay for that material. 3. The change ofmonthly 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 of65Appendix 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. BlankAnalyses: A blank analysis consisting ofdeionized water will be analyzed daily. This will be compared to the velocity ofsound in water and must fall within± 5% ofthe published value. 3. Calibration Verification Sample: A standard sample will be analyzed with each set ofsamples. The Calibration Verification Sample must fall within ± 2% ofits control value. The results ofthe 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. QualityAssurance: When control limits are exceeded, the analysis will be repeated. Ifnecessary, 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 of65Appendix 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. BlankAnalyses: A blank analysis consisting ofthe crucible accelerator and coverwill be analyzedwith each set ofsamples. 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. CalibrationVerification Sample: A standard sample will be analyzed with each set ofsamples. The Calibration Verification Sample must fall within ± 10% ofits control value. The results ofthe analysis will be plotted on a control chart to indicate the control value is within three (3) standard deviations. 4. Duplicates: All sampleswillbe analyzedin duplicate. Therelative standard deviationwillbe calculatedand must fall within± 20%. 5. Quality Control Sample: A quality control sample will be analyzed quarterly. The analysis will compare within ± 10%. 6. QualityAssurance: When control limits are exceeded, the analysis will be repeated. Ifnecessary, 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 of65Appendix 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. CalibrationVerification Sample: A standard sample will be analyzed with each set ofsamples. The Calibration Verification Sample must fall within± 10% ofits calculated control value. A 1.0000 gm sample ofAnhydrous Sodium Sulfate will be used as the Calibration Verification sample. The calculated value ofthe sample will be 13545.7 x purity ofreagent. The Barium Sulfate residue will be calculated for a 50 ml sample. The results ofthe analysis will be plotted on a control chart to indicate the control value is within three (3) standard deviations. 4. Duplicates: All sampleswillbe analyzedin duplicate. The relative standard deviationwillbe calculatedand 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. Ifnecessary, 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 PermitNo. 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>
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### Number: · 

## 1 000042 '


### Issued: October 9, 

### 2001

# c{}~ Expires: October 

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### Nancy C. Wrona, Director, Air Quality Division

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