DOUGLAS SULFUR DIOXIDE NONATTAINMENT AREA STATE IMPLEMENTATION AND MAINTENANCE PLAN
AIR QUALITY DIVISION ARIZONA DEPARTMENT OF ENVIRONMENTAL QUALITY November 29, 2001
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TABLE OF CONTENTS
1.0 INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1.1
1.1 1.2 1.3 1.4 1.5 1.6 Purpose and Regulatory Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . History . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Climate . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Population . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Economy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . General SIP Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1.6.1 CAA Section 110(a)(2) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1.6.2 CAA Section 172(c) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1.6.3 CAA Section 175(a) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1.6.4 CAA Sections 191 and 192 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1.1 1.1 1.2 1.2 1.3 1.4 1.4 1.5 1.6 1.7
2.0
SO2 EMISSIONS INVENTORY FOR POINT, AREA AND MOBILE SOURCES 2.1
2.1 2.2 Historical Emissions Inventory . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2.1 Emission Inventory for Attainment Demonstration: Years 1985-86, 1999 . . . . . . . . . . . . . . . . . . . . . 2.1
3.0
MONITORING NETWORK . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3.1
3.1 3.2 SO2 Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3.1 Historical Data Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3.1
4.0
CONTROL MEASURES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4.1
4.1 Reasonably Available Control Technology for SO2 Major Sources in the Douglas Nonattainment Area . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4.1 4.1.1 Reasonably Available Control Technology (RACT) #1: AAC Rule 18-2-715 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4.1 4.1.2 Reasonably Available Control Technology (RACT) #2: AAC Rule 18-2-715.02 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4.3 Controls for Other Point Sources in the Douglas Nonattainment Area . . . . . . . . . . . . . . . . . . . . . . . 4.4 Controls for Area and Mobile Source in the Douglas Nonattainment Area . . . . . . . . . . . . . . . . . . . 4.4
4.2 4.3
5.0 6.0 7.0
CONTINGENCY MEASURES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5.1
5.1 Prevention of Significant Deterioration (PSD) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5.1
CONFORMITY PROVISIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6.1 MAINTENANCE PLAN . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7.1
7.1 7.2 7.3 7.4 7.6 Emissions Inventories . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Dispersion Modeling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . PSD Permit Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Commitment to Resume Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Contingency Measures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7.1 7.2 7.2 7.2 7.2
8.0
REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8.1
LIST OF TABLES
CHAPTER 1.0 ? ? ? Table 1.1 Population Statistics Table 1.2 Labor Force Data - Douglas, Arizona Table 1.3 Growth Indicators - Douglas
CHAPTER 7.0 ? Table 7.1 Sulfur Dioxide Emission Projections for 2015 in Cochise County
LIST OF FIGURES
CHAPTER 2.0 ? ? Figure 2.1 Point Sources in Cochise County Figure 2.2 Area and Mobile Sources in Cochise County
1.0 1.1
INTRODUCTION Purpose and Regulatory Background
This document consists of the attainment demonstration, maintenance plan, and redesignation to attainment request for the Douglas Sulfur Dioxide (SO2) Nonattainment Area. The purpose of this document is to demonstrate how the State of Arizona has met the National Ambient Air Quality Standards (NAAQS) for SO2 and intends to maintain compliance with the NAAQS in the Douglas area. Air quality standards are divided into two types: primary standards based on health effects and secondary standards based on environmental effects such as damage to property, plants, visibility, etc. Both standards are established by EPA for criteria air pollutants such as sulfur dioxide.1 1.2 History
The United States Environmental Protection Agency (EPA) designated the entire area of Cochise County as nonattainment for SO2 on March 3, 1978, (43 FR 8968) for lack of a State recommendation. At the request of Arizona Department of Environmental Quality (ADEQ), the nonattainment area was subsequently reduced to three townships in and around Douglas on April 10, 1979 (44 FR 21261). As shown in the table below, the portions of Cochise County that define the boundary of the Douglas nonattainment area (40 CFR 81.303) are marked and classified as2: Douglas Location T23S, R27E T24S, R27E T24S, R28E T23S, R26E T23S, R28E T24S, R26E Does Not Meet Primary Standards X X X Cannot Be Classified
X X X
Sulfur Dioxide Standards: In 1971, EPA published in the Federal Register (36 FR 81875 for 1971) the primary and secondary NAAQS for SO2. Secondary annual and 24-hour standards were later revoked and May 22, 1996 (61 FR 25566) the primary standard revised from Fg/m3 to parts per million (ppm). The current established NAAQS for SO2 are:
Annual Primary Secondary .030 ppm (80 Fg/m3 ) 24-hour average .14 ppm (365 Fg/m3 ) . 5 ppm (1300 Fg/m3 )
S O U R C E : 40 CFR 50.4 - 50.5
2
1
3-hour average
See Appendix A.1 for a delineation of the existing area as codified in 40 CFR 81.303.
1.1
Phelps Dodge Douglas Reduction Works Smelter (PDDRWS) was the largest point source in the nonattainment area. The PDDRWS facility was located off highway 80, approximately 1.5 miles west of the city of Douglas, in Cochise County, Arizona; at a latitude coordinate of 310-21' and a longitude coordinate of -1090-35', and an elevation of 3990' (See Appendix A for a detailed map and photographs). A more detailed description of PDDRWS operations can be found in Section 2.1. As required by the Clean Air Act (CAA), Arizona submitted a State Implementation Plan (SIP) for all major sources in the State on January 30, 1972. At that time, the portion of the SIP pertaining to SO2 in the Douglas area (part of the Southeast Arizona Intrastate Air Quality Control Region (40 CFR 81.272)) was not approved due in part to the failure to analyze the impact of smelter fugitive emissions from PDDRWS on ambient air quality (40 CFR 52.125(a)(1)). On November 30, 1981, Arizona submitted a proposed Multi-Point Rollback (MPR) rulemaking as part of revisions to the Arizona SIP. It was approved by the EPA as final rulemaking on January 14, 1983 (48 FR 1717).3 The rule, which establishes standards of performance for existing primary copper smelters, set requirements for analyzing the impact of smelter fugitive SO2 emissions on ambient air quality. PDDRWS failed to meet these standards and subsequently made the decision to cease operations. On January 15, 1987, the facility was permanently closed and dismantling began. In 1991, the facility was completely dismantled. By January 30, 1992, ADEQ confirmed that the facility was dismantled and no longer existed at the former site (See Photographs in Appendices A.2 and A.3). 1.3 Climate
Both desert terrain and mountain ranges are found within Cochise County's landscape. The elevations range from 2,000 to 9,000 feet above sea level, and the City of Douglas sits at an elevation of 3,990 feet. This unique environment experiences both warm desert and cool alpine climates, including all the variations within those extremes. In the Douglas area, the hottest month of the year is July, when the average daily temperature is 89o Fahrenheit (F). January is the coolest month of the year; with an average daily temperature of 45o F. The average yearly temperature for Douglas is 62o F. Rainfall generally occurs in two seasons. The wettest month is July when monsoon-type rains produce 3.41 inches of rain in the Douglas area. Pacific winter storms moving across the area in December produce an average of 1.04 inches of rain in Douglas. The driest month is May, when Douglas receives an average of 0.20 inches of rain. The average yearly precipitation for Douglas is 13.42 inches of rain. 1.4 Population The population data for the City of Douglas and the Cochise County area were compiled from data
Arizona Code of Rules and Regulations (ACR): Rule (R) 9-3-515 (recodified as Arizona Administrative Code (AAC) R18-2-515; renumbered as R18-2-715 in 1993 as Standards of Performance for Existing Primary Copper Smelters; Site Specific Requirements).
3
1.2
developed by the Arizona Department of Economic Security (ADES).4 Table 1.1 presents ADES records of 1997-2000 population for Cochise County and the city of Douglas in addition to estimates for 2000-2015. Population counts and projections are also provided for the entire state of Arizona. Recent growth patterns indicate that population growth rates in the Cochise County area have moderated and are now less than the surrounding regions.
Table 1.1 Population Statistics 1997 Cochise Co. Douglas Arizona 116,737 15,058 4,595,379 2000 121,837 15,520 4,961,953 2015 143,793 16,325 6,744,754 % Change 1 9 9 7 - 2000 4% 3% 8% % Change 2 0 0 0 - 2015 18 % 5% 35 %
SOURCE: Arizona Department of Economic Security, 1997
1.5
Economy
Cochise County was created in 1881 by the Eleventh Territorial Assembly. The County covers 6,215 square miles. Individual and corporate ownership accounts for 40 percent of land ownership in the County. The U.S. Forest Service and the Bureau of Land Management own 22.2 percent; the state of Arizona owns 34.6 percent; and other public lands comprise the remaining 3.2 percent. There are no Indian reservations in Cochise County. Douglas was founded in 1901 as a site for a copper smelter and was incorporated in 1905. Because of its location, the economy of the Douglas area includes international commerce. Douglas has three manufacturing plants, and the nearby border community of Agua Prieta in the state of Sonora, Mexico has 32 manufacturing plants. Some of the Agua Prieta plants are "maquiladoras" (twin-plants manufacturing on both sides of the border). These maquiladoras manufacture clothing, electronics, auto parts, and plastic injection moldings. Agriculture and ranching are still important economic segments of the area as well. Douglas also serves as a retail center for shoppers on both sides of the border. Thirty-nine percent of retail sales in the Douglas area are attributed to Mexican shoppers. Tourists are attracted to the area because of the frontier mining town of Tombstone, shopping in Agua Prieta, and the historic and scenic sites of Old Fort Bowie, Fort Huachuca, Coronado National Memorial, Cochise Stronghold, Chiricahua National Monument, Coronado National Forest, Texas Canyon, Kartchner Caverns State Park, and the San Bernardino Wildlife Refuge. Additional background economic information on the area can be found in Table 1.2 and Table 1.3.
According to Executive Order 95-2, signed by Governor Fife Symington, February 10, 1995, ADES statistics are to be used by all State agencies instead of US Census data for the purposes of planning. This was done to prepare one official set of population estimates and projections. US Census data for the year 2000, records the population for Cochise County as 97,624; Douglas as 17,324; and Arizona as 3,665,228 persons.
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1.3
Table 1.2 Labor Force Data - Douglas, Arizona 1980 Civilian Labor Employed Unemployed Unemployment Rate 4,331 3,884 447 10.3% 1990 4,705 4,139 566 12.0% 1998 4,527 3,912 616 13.6%
SOURCE: Arizona Department of Economic Security, 1997 Table 1.3 Growth Indicators - Douglas 1990 Taxable Sales Postal Receipts School Enrollment Net ($) Assessed Valuation 99,638,900 1,036,102 4,412 22,927,209 1997 127,036,800 1,267,266 4,682 31,727,825 1998 136,820,880 1,168,606 4,722 31,270,112
SOURCE: Arizona Department of Commerce, 1997
1.6
General SIP Requirements Section 110 and Title I, Part D, subparts 1 and 5 of CAA are applicable to this SIP.
1.6.1
CAA Section 110(a)(2) Section 110(a)(2) sets forth the following requirements for nonattainment areas: a. States shall include enforceable emission limitations and other control measures, means, or techniques, as well as schedules and timetables for compliance (See Chapter 4.0). b. States shall provide for establishment and operation of appropriate devices, methods, systems, and procedures necessary to monitor, compile, and analyze data on ambient air quality (See Chapter 3.0). c. States shall include a program to provide for the enforcement of the measures described in (a) above, and regulation of the modification and construction of any stationary source within the areas covered by the plan to assure that national ambient air quality standards are achieved, including a permit program as required in part (d ) below (See Chapter 4.0). d. SIPs shall contain adequate provisions prohibiting any source or other type of emissions activity within the State from emitting any air pollutant in amounts which will contribute 1.4
significantly to nonattainment or interfere with measures required to be included in the applicable implementation plan (See Chapters 4.0, 6.0 and 9.0). e. Provide necessary assurances that the State will have adequate personnel, funding, and authority under State law to carry out such implementation plans (See Section 4.4). 1.6.2 CAA Section 172(c)
Section 172(c) of CAA, Nonattainment Plan Provisions, sets forth the following requirements for nonattainment areas: a. Implementation of all reasonably available control measures (RACM) as expeditiously as practicable (CAA ? 172(c)(1)) - RACM is met for the PDDRWS because the facility was completely dismantled and no longer exists. There are three remaining SO2 point sources in the nonattainment area and within the 50km buffer area: Chemical Lime, Incorporated (Chemical Lime), Arizona Public Service (APS), Fairview Station, and Maddux & Sons, Coleman Pit.5 See Section 4.2 for further explanation of applicable RACM and emissions data for these sources. b. Reasonable further progress (RFP) must be demonstrated in accordance with CAA ?172(c)(2) - EPA's RFP requirements stipulate that annual incremental reductions in SO2 are needed to achieve attainment of the SO2 NAAQS. With the closure of PDDRWS in 1987, this submittal demonstrates progress, towards and achievement of attainment for the SO2 primary NAAQS. c. A current inventory of actual emissions from all sources of relevant pollutant or pollutants (CAA ?172(c)(3)) - The ADEQ Air Quality Division maintains a historical and current database of actual emissions from State-permitted point and area sources. All non-permitted source emissions data (ie: mobile sources) comes from EPA's AIRData emission inventories.6 For historical purposes, ADEQ's inventory lists emissions from SO2 units at PDDRWS during its time of operation. The total SO2 emissions are based upon the measured fugitive emissions plus total stack emissions. Monitoring data is also available to supplement the emissions inventory, including data for point, area, and mobile sources (See Chapters 2.0 and 3.0, and Section 8.1). d. Requirements for new and modified major stationary sources are required for the construction and operation of new and modified major stationary sources throughout the nonattainment area (in accordance with CAA ?172( c)(5) and CAA ?173). The ADEQ Air Quality Division has codified the permit application process in Title 18, Article 3 of the Arizona Administrative Code (AAC). It should be noted that the ADEQ Air Quality Division currently has interim approval of its Title V permit program and expects full approval by the end of 2001 (See Sections 8.3 and 8.5).
5 6
See Appendix A.4 for location of these facilities.
AIRData provides access to air pollution data for the entire United States. Website address (as of date published): http://www.epa.gov/air/data/index.html
1.5
e. The Plan shall include enforceable emissions limitations and such other control measures, means or techniques, as well as schedule and timetables for compliance, as may be necessary or appropriate to provide for attainment of such standard in such area by the applicable attainment date (CAA ?172(c)(6)). AAC R18-2-715 contains the required annual average emission limitations and number of three-hour average emission limits for Arizona smelters. AAC R18-715.01 (Standards of Performance for Existing Primary Copper Smelters; Compliance and Monitoring; See Appendix B.1), set forth the compliance date of January 14, 1986, for monitoring, calibration, measurement system performance requirements, record keeping, bypass operation, and issuance of notices of violation.7 Details regarding control for the remaining SO2 sources may be found in Chapter 4.0. f. Equivalent techniques for modeling, emissions inventory, and planning procedures allowed by the administrator (CAA ?172(c)(8)) - The Air Quality Division (AQD) at ADEQ is utilizing a Memorandum from John Seitz, EPA's Director of the Office of Air Quality Planning and Standards, dated October 18, 2000, "Redesignation of Sulfur Dioxide Nonattainment Areas in the Absence of Monitored Data," to make the attainment demonstration for this nonattainment area. g. Contingency measures that can be implemented automatically in the event the area fails to make reasonable further progress (CAA ?172(c)(9)) - the area has met the RFP requirement for attainment, so no specific attainment demonstration contingency measures are necessary (See Chapter 5.0). 1.6.3 CAA Section 175(a) Section 175(a) of CAA, Maintenance Plans, sets forth the following requirements for nonattainment areas.8 a. Plan Revision - each State which submits a request for redesignation of a nonattainment area shall also submit a revision of the applicable SIP to provide for the maintenance of the NAAQS for at least ten years after the redesignation. This submittal shows attainment through year 2015. b. Subsequent Plan Revisions - eight years after redesignation as any attainment area, the State shall submit an additional revision of the applicable SIP for maintaining the NAAQS for ten years after the expiration of the ten-year period referred to in subsection (a). ADEQ commits to submit an additional SIP revision in the year 2013 time frame. c. Nonattainment Requirements Applicable Pending Plan Approval - until such plan revision is approved and an area is redesignated as attainment for any area designated
Standards of Performance for Existing Primary Copper Smelters; Site-specific Requirements, R18-2-515, renumbered R18-2-715 (1993).
8 7
A discussion of this SIP's Maintenance Plan can be found in Chapter 7.0.
1.6
nonattainment, the requirements of this part shall continue in force and effect. ADEQ commits to keeping all applicable measures in place. d. Contingency Provisions - each plan revision submitted under this section shall contain such contingency provisions to assure that the State will promptly correct any violation of the standard which occurs after the redesignation of the area as an attainment area. Such provisions shall include a requirement that the State will implement all measures with respect to the control of the air pollutant concerned before redesignation. ADEQ commits to implementing all identified measures as necessary (See Chapter 6.0). 1.6.4 CAA Sections 191 and 192
Sections 191 and 192, Plan Submission and Attainment Dates - This submittal fulfills this requirement. And, with the submittal of this SIP and Maintenance Plan, ADEQ requests redesignation of the Douglas SO2 Nonattainment Area to attainment.
1.7
2.0 2.1
SO2 EMISSIONS INVENTORY FOR POINT, AREA AND MOBILE SOURCES Historical Emissions Inventory
The historical emissions inventories for the Douglas area indicate that although there were other point sources of SO2 emissions in the area, PDDRWS was the primary point source for SO2 emissions for this nonattainment area. The Douglas smelter was the fifth largest copper smelter in the country and used a standard reverberatory furnace smelting process. Major process equipment included 24 roasters, three reverberatory furnaces, five converters, and two anode furnaces. Copper feed arrived at the plant by rail and was transferred to the bedding plant. Feed material was dropped onto the top hearth of a roaster. The resulting material (calcines) produced in the roasters was charged into one of the two operating reverberatory furnaces. Matte from these two furnaces was then tapped into ladles and transferred by overhead cranes to one of five converters. Slag was carried by rail to a nearby dump. Blister copper from the converters was then cast into anodes after refining in one of two anode furnaces. The final product was approximately 99.7 percent pure copper anodes. Emissions from these sources were collected, treated for particulate removal and ducted to one of two stacks. The average annual SO2 emissions for the two years prior to the closure (1985 and 1986), was 287,588 tons per year (tpy) of SO2 (See Appendix C.1). Area and mobile source emissions during this period were 684 tpy and 750 tpy respectively (See Figure 2.). 2.2 Emission Inventory for Attainment Demonstration: Years 1985-86, 1999
Point Sources PDDRWS was the major source for the area. When it closed in 1987, the SO2 point source emissions in the Douglas nonattainment area were reduced to1,325 tpy in 1987. The total SO2 emissions for point sources in 1999 was 1,969 tpy. Additional data show that no other point, area or mobile sources have contributed, or contribute to the same levels of sulfur dioxide in the Douglas nonattainment area PDDRWS when it was operational. There are three SO2 point sources within 50 kilometers of the Douglas nonattainment area: Chemical Lime, APS, Fairview, and Maddux & Sons. (See Section 6.1 for emissions inventory data).
Figure 2.1 Point Sources In CochiseCounty
350000 300000
Tons of SO2
250000 200000 150000 100000 50000 0 1985 1986 1987 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999
Year
T o n s SO2 per year
2.1
Area and Mobile Sources There are no significant area or mobile sources associated with the Douglas nonattainment area. As reflected in Figure 2.2, EPA's AIRData for all of Cochise County shows in 1985 area and mobile sources emitted 684 tpy of SO2 (See Appendix C.1). By 1987, area and mobile sources had dropped to a low of 652 tpy. In 1998, area sources emitted 387 tpy, a reduction of over 50 percent of the 1987 level. Area and point sources operating in Mexico are beyond fifty kilometers from the southern boundary of the nonattainment area.
Figure 2.2 Area and Moblie Sources in Cochise County
800 700
Tons SO2
600 500 400 300
1985 1986 1987 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999
Year
A r e a Sources
2.2
3.0
MONITORING NETWORK
Protocols for SO2 monitoring are found in 40 CFR Part 50, Appendix A, Reference Method for the Determination of Sulfur Dioxide in the Atmosphere, Part 58, Subpart B, Section 58.14, Special Purpose Monitors, Subpart C, Section 58.20, State and Local Air Monitoring Stations, Air Quality Surveillance: Plan Content, and Subpart D, Section 58.30, National Air Monitoring Stations (NAMS). 3.1 SO2 Monitoring
ADEQ began monitoring for SO2 in the Douglas area as early as 1970.9 With ADEQ concurrence, PDDRWS began ambient SO2 air quality monitoring in Douglas in 1975. Since then, the last recorded exceedance for the annual standard was one, recorded in 1983. Monitoring data from ADEQ, PDDRWS and Arizona Electric Power Cooperative (AEPCO) analyzers are provided in Appendix C.2. These monitors included coulometric, flame photometric and fluorescent monitors. Currently there are no operating ambient SO2 monitors in the Douglas area. Due to the lack of an existing monitoring network, and as outlined in Director John Seitz's October 18, 2000, Memorandum, "Redesignation of Sulfur Dioxide Nonattainment Areas in the Absence of Monitored Data," redesignation for this area does not require eight current consecutive quarters (two years) of quality-assured, violation-free data (See Appendix B.3). 3.2 Historical Data Analysis A review of the SO2 monitoring data in the nonattainment area verifies that: a. There have not been any recorded exceedances of either the 24-hour or annual SO2 NAAQS in Douglas since 1984. b. During the network's history, annual average SO2 levels were generally one-half of the NAAQS (80g/m3). c. There have not been any recorded exceedances of the 3-hour secondary SO2 NAAQS in the Douglas area since 1984 (Also see Appendix C.2).
9
Air Quality Report, Air Quality Division, 1970.
3.1
4.0 4.1 Area
CONTROL MEASURES Reasonably Available Control Technology for SO2 Major Sources in the Douglas Nonattainment
Reasonably Available Control Technology (RACT) is the emissions control level for sources located in SO2 nonattainment areas. RACT is determined by the technological and economic feasibility of the control.10 4.1.1 Reasonably Available Control Technology (RACT) #1: AAC Rule 18-2-715
Standards of Performance for Existing Primary Copper Smelters; Compliance and Monitoring. Technology Description: PDDRWS was subject to all the requirements in R18-2-715(A)-(E).11 PDDRWS submitted a notice of intent to apply for a Nonferrous Smelter Order (NSO) for the Douglas smelter on March 14, 1985, to EPA and the State of Arizona. Upon receipt of the denial of the NSO on April 17, 1986, the PDDRWS smelter was scheduled for closure, which was completed on January 15, 1987. Estimated SO2 Emission Reduction: The closure of the Douglas smelter in 1987 resulted in 300,000 tpy SO2 emission reduction from stack and fugitive emissions. Responsible Agency and Authority for Implementation: ADEQ was the responsible agency with authority designated from: ? ARS ?49-104 ? ARS ?49-422 ? Implementation Schedule: Compliance with the rule by PDDRWS was effective with the facility's shutdown date, January 14, 1987. Level of Personnel and Funding Allocated for Implementation: No additional personnel is required.
10
US EPA Office of Air and Radiation, Office of Air Quality Planning and Standards, "SO2 Guideline Document," February 1994. ADEQ promulgated site specific requirements in the AAC R18-2-715 (See Appendix B.1), known as a Multi-Point Rollback (MPR) Rule, for all existing primary copper smelters (See Section 1.2). MPR included a compliance date of January 14, 1986, in R18-2-715(D). PDDRWS was pending a nonferrous smelter order (NSO) determination from EPA at the time the rule was promulgated. Therefore, no site specific requirements were listed for this facility in the MPR rule.
11
4.1
Enforcement Program: ADEQ is responsible for enforcing performance standards for existing primary copper smelters through inspections, issuance of compliance correspondence (Notices of Opportunity to Correct (NOCs), Notices of Violations (NOVs), Orders, etc.), and the development of other escalated enforcement actions as facts dictate. Monitoring Program: For purposes of determining compliance, ADEQ required PDDRWS to install, calibrate, maintain, and operate a measurement system for continuously monitoring SO2 concentrations and for stack gas volumetric flow rates.12 Measurement of stack gas volumetric flow in the outlet of any particular piece of SO2 control equipment was approved prior to May 18, 1984, during the review of the compliance plan as required by AAC R18-2-715.02(B)(1). In addition, the measurements for continuous monitoring (CEMS) were taken and recorded by taking a minimum of one measurement of SO2 concentration and stack gas flow rate reading from the effluent of each affected stack, outlet or other approved measurement location in each 15-minute period. An hour of smelter emissions was considered to have been continuously monitored if the emissions from all monitored stacks, outlets, or other approved measurement locations are measured for at least forty-five minutes of any hour in accordance with the requirements of AAC R18-2-715. As required by AAC R18-2-715.01(C)(l), PDDRWS measured at least 95 percent of the hours during which emissions occurred in any month, and the smelter also complied with the requirement to measure any of the twelve consecutive hours of emissions per R18-2-715.01(C)(1). ADEQ did not issue a NOV for any monitoring violation to this facility, according to the Air Quality Divisions' compliance file. As required by 40 CFR 60 Subpart P - Standards of Performance for Primary Copper Smelters, PDDRWS maintained records of all average hourly emissions measurements. The records of such emissions were retained for at least two years following the date of measurement. All of the following emission measurement results were expressed as pounds per hour of SO2, and were summarized monthly and submitted to the Director of the ADEQ within twenty days after the end of each month: a. The annual average of the month; b. The total number of hourly periods during the month in which measurements were not taken and the reason for loss of measurement for each period; c. The number of three-hour emissions averages which exceeded each of the applicable emissions levels listed in R18-2-715.01(F) for the compliance periods ending on each day of the month being reported; d. The date on which a cumulative occurrence limit listed in R18-2-715.01(F) was exceeded if such exceedance occurred during the month being reported. A summary report is provided in Appendix D.1. Permit #0263-83 for the PDDRWS copper smelter was issued on March 10 , 1983. The previous permit for PDDRWS expired on December 31, 1982. On May 15, 1985, the Phelps Dodge Corporation
12
Only applicable for stacks emitting five percent or more of the allowable annual average SO2 emissions.
4.2
applied directly to EPA for a second period NSO for PDDRWS.13 An NSO may have been issued by the State for PDDRWS if the EPA found that the facility was unable to comply with the SIP requirements because the requirements were not demonstrated to be reasonably achievable.14 EPA denied the NSO application. The denial was published in the Federal Register on April 17, 1986 (Vol. A9 FR pg 3004-9), "Proposed Decision To Deny a Non-Ferrous Smelter Order to Phelps Dodge Corporation, Douglas, AZ; Section 119 of the Clean Air Act." The smelter was closed within one year of the denial, on January 15, 1987. 4.1.2 Reasonably Available Control Technology (RACT) #2: AAC Rule 18-2-715.02
Standards of Performance for Existing Primary Copper Smelters; Fugitive Emissions Technology Description: AAC 18-2-715.02 was required for all applicable sources as of January 14, 1986. The rule required sources to measure and evaluate fugitive emissions from various smelters. Estimated SO2 Emission Reduction: The closure of the Douglas smelter in 1987 resulted in 300,000 tpy SO2 emission reduction, including stack and fugitive emissions. Responsible Agency and Authority for Implementation: ADEQ was the responsible agency with authority designated by: ? ARS ?49-104(A)(11) ? ARS ?49-422 ? Implementation Schedule: Compliance with the rule by PDDRWS was effective with the facility's shutdown date, January 15, 1987. Level of Personnel and Funding Allocated for Implementation: No additional personnel is required Enforcement Program: ADEQ is responsible for enforcing performance standards for existing primary copper smelters through inspections, issuance of compliance correspondences (NOCs, NOVs, and orders), and the development of other escalated enforcement actions as facts dictate. Monitoring Program: See Section 4.1.1
13 14
CAA ?119 (1)(c)(1) CAA ?119 (1)(C)(3)
4.3
4.2
Controls for Other Point Sources in the Douglas Nonattainment Area
1. Chemical Lime: Although the source's permits contains limits for other criteria pollutants, there are no current federal or state SO2 emission limits for lime plants (See Appendix C.1 for emissions data). 2. Maddux & Sons, Coleman Pit: Maddux & Sons operates portable crushing and screening equipment at the Coleman Pit in Douglas, Arizona. The Coleman Pit is a Class II source, operating under a crushing and screening general permit. This source has actual SO2 emissions of one ton or less per year. The permit limits the SO2 emissions from the combustion of fuel in their internal combustion engine to not more than 1.0 pound per million btu of heat input. The permit also prohibits the use of high sulfur oil (See Appendix C.1 for emissions data). 3. APS, Fairview Generating Station: In accordance with AAC R18-2-719, the APS facility complies with RACT because the standard for SO2 emissions limitations is at no more than 1,300 tpy. The source's permit, however, limits the potential to emit (PTE) from the existing equipment at the Fairview Generating Station to 700 tpy of SO2. Actual emissions, however, are minimal, at less than 3 tpy (See Appendix C.1 for actual emissions data). 4.3 Controls for Area and Mobile Source in the Douglas Nonattainment Area As Table C.2 in Appendix C indicates, these source categories are considered minor.
4.4
5.0 5.1
CONTINGENCY MEASURES Prevention of Significant Deterioration (PSD)
ADEQ has a PSD permitting program (See AAC R18-2-406, Appendix B.1) that was established to preserve the air quality in areas where ambient standards have been met by requiring stationary sources to undergo preconstruction review before the facility is constructed, modified, or reconstructed and to apply Best Available Control Technology (BACT).15 This program will apply to any major source wishing to locate in the area, once redesignated to attainment (See Chapter 7.0, "Maintenance Plan").
15
AAC R18-2-406, "Permit Requirements for Sources Located in Attainment and Unclassifiable Areas."
5.1
6.0
CONFORMITY PROVISIONS
Section 176(c)(1)(A) of CAA requires SIPs to contain information regarding the State's compliance with conformity requirements. As stated in 40 CFR 93.153(b), "Conformity determinations for Federal actions related to transportation plans, programs and projects developed, funded, or approved under title 23 U.S.C. or the Federal Transit Act (40 U.S.C. 1601 et seq.) must meet the procedures and criteria of 40 CFR part 51, subpart T, in lieu of the procedures set for in this subpart." 40 CFR 93.103(b) waives transportation conformity for SO2 nonattainment areas, but general conformity for the Douglas, Cochise County area must still be addressed to assure SO2 emissions from any Federal actions or plans do not exceed the rates outlined in 40 CFR 93.153(b)(1). Criteria for making determinations and provisions for general conformity as outlined in 40 CFR 93.153 can be located in R18-2-1438 of the Arizona Administrative Code. There are no Federal plans or actions affecting air quality currently in the Douglas, Cochise County area, nor are any foreseen through the year 2015.
6.1
7.0
MAINTENANCE PLAN
Section 107(d)(3) of CAA requires that nonattainment areas have a fully-approved maintenance plan meeting the requirements of CAA ?175(a) before they can be redesignated to attainment. Section 175(a) of CAA further requires such a SIP revision provide for maintenance of the NAAQS for at least ten years after the redesignation to attainment. A subsequent SIP revision providing for maintenance of the NAAQS for an additional ten years is due eight years into the first ten-year maintenance period. As indicated in Director John Seitz's Memorandum, "Redesignation of Sulfur Dioxide Nonattainment Areas in the Absence of Monitored Data," dated October 18, 2000, four specific requirements for demonstration of maintenance are necessary: (1) future emission inventory projections, (2) dispersion modeling to show no SO2 violations are projected for the maintenance period, (3) commitment for PSD requirements, and (4) commitment to resume monitoring. These requirements are outlined in the following sections. 7.1 Emissions Inventories
Arizona does not anticipate any new plans to construct additional SO2 point sources within the Douglas nonattainment area. However, should growth occur, ADEQ's permit program limits all emissions as part of the construction of new point sources or the upgrading of existing sources. ADEQ projects actual emissions of SO2 from mobile sources may grow as the population of Cochise County grows. Based on ADES projections, an approximate 28.4 percent increase in the population in Cochise County between 1995 and 2015 would correlate to the following trends in SO2 emissions for 201516:
Table 7.1 Sulfur Dioxide Emission Projections for 2015 in Cochise County Type of Source Area and Mobile Sources 17 Point Sources Annual Total 1985 Tons of SO2 684 333,240 333,924 tons 1995 Tons of SO2 385 5287 5,672 tons Multiplier (based on population growth projections) 1.284 1.00 Projected Tons SO2 for 2015 494 tons SO2 5287 tons SO2 5781 tons SOURCE: EPA NET inventory report, 1997
As a comparison to Table 7.1, when PDDRWS was in operation in 1985, the source emitted 330,000 tons of SO2 during that year. The following equation shows projected emissions for the year 2015 to be less than
The 1995 population of Cochise County was projected as 112,000 in 1995, and the 2015 population is projected to be 143,793, thus giving the 28.4percent increase in population and emissions.
17 16
As consistent with EPA AIRData, emissions "Area Source" emissions includes mobile sources.
7.1
1.73 percent of the 1985 levels: 5,781 tons in 2015 333,924 tons in 1985 7.2 Dispersion Modeling = 1.73 percent
In the event that new point sources are considered during the maintenance period, ADEQ commits to doing the appropriate modeling before any permitting actions are finalized. 7.3 PSD Permit Requirements
AAC R18-2-406, Permit Requirements for Sources Located in Attainment and Unclassified Areas, will apply after redesignation for any new point source (See Appendix B.1). 7.4 Commitment to Resume Monitoring
Since SO2 NAAQS monitoring began in the nonattainment area in 1970, average ambient annual levels were generally half of the NAAQS of 80g/m3. There have not been any recorded exceedances of the 24-hour primary SO2 NAAQS in Douglas since 1984. As such, there is no current monitoring for SO2 within the nonattainment area. However, ADEQ is prepared to resume monitoring in accordance with Director John Seitz's October 18, 2000, Memorandum, "Redesignation of Sulfur Dioxide Nonattainment Areas in the Absence of Monitored Data," outlining the requirements for resuming monitoring (See Appendix B.3). ADEQ commits to resume monitoring before any major source of SO2 emissions commences operation. 7.6 Contingency Measures
The current permit program places limits on SO2 emissions for existing sources (See Chapter 4.0 for further explanation). Secondly, as explained in Section 7.3, should an existing facility want to upgrade or increase SO2 emissions, they would be subject to the PSD program (See Section 5.1). Finally, should a new facility be constructed in the Douglas nonattainment area, the facility would also be subject to PSD required in Director John Calacgni's Memorandum, "Procedures for Processing Requests to Redesignate Areas to Attainment."
7.2
8.0
REFERENCES
Arizona Copper Smelter Handbook, Arizona Mining Association, Phoenix, Arizona, April 20, 1982. Arizona Testing Manual for Air Pollutant Emissions (Revision E), Arizona Department of Air Quality, May 15, 1989. "Attainment Determination Policy for Sulfur Dioxide Nonattainment Areas," Memorandum from Director Sally L. Shaver to Regional Office Air Division Directors, U.S. Environmental Protection Agency, January 26, 1995. Breathing Easier: A Report on Air Quality in California, Arizona, Nevada, & Hawaii, U.S. Environmental Protection Agency, EPA-909-R-95-001, Region 9, Air and Toxics Division, San Francisco, California, May 1995. National Annual Industrial Sulfur Dioxide Emission Trends 1995- 2015, U.S. Environmental Protection Agency, EPA 454-R-95-001, Air and Radiation, Research Triangle Park, N.C., June 1995. "Procedures for Processing Requests to Redesignate Areas to Attainment," Memorandum from Director John Calcagni to the Regional Office Air Division Directors, U.S. Environmental Protection Agency, September 4, 1992. "Redesignation of Sulfur Dioxide Nonattainment Areas in the Absence of Monitored Data," Memorandum from Director John R. Seitz to the Regional Office Air Division Directors, U.S. Environmental Protection Agency, Research Triangle Park, North Carolina, October 18, 2000. "Section 107 Designation Policy Summary," Memorandum from Director Sheldon Meyers to the Regional Office Air Division Directors, U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, Washington DC, April 21, 1983. Sulfur Dioxide Guideline Document, U.S. Environmental Protection Agency, EPA-452/R-94-008, Research Triangle Park, North Carolina, February 1994. Supplemental D to Compilation of Air Pollutant Emission Factors, Volume I: Stationary Point and Area Sources (AP- 42 5th Edition), U.S. Environmental Protection Agency, EPA-454-F-9903, Department of Commerce, National Technical Information Service, Springfield, Virginia, August 31, 1998.
LIST OF APPENDICES
APPENDIX A Section A.1 Section A.2 Section A.3 Section A.4 APPENDIX B Section B.1 Section B.2 Section B.3 APPENDIX C Section C.1 Section C.2 Section C.3 Section C.4 Section C.5
Photographs and Map of Area Douglas Nonattainment Boundary Area Photograph of PDDRWS before shutdown and dismantling Photograph of PDDRWS after dismantling Map of other facilities located in the Douglas Nonattainment Area SIP Support Information Relevant Arizona Administrative Codes (AAC) ADEQ Air Quality Division Organizational Chart EPA Guidance Memoranda Emissions Inventory and Monitoring Network Douglas Nonattainment Area Emissions Inventory - Point Sources Douglas Nonattainment Area Emissions Inventory - Area and Mobile Sources for Years 1985 - 1998 Douglas Nonattainment Area Emissions Inventory - Area and Mobile Sources for Year 1999 Douglas Nonattainment Area Emissions Projections - Area and Mobile Sources for Years 2000 - 2015 Ambient Air Monitoring Data
APPENDIX A Photographs and Map of Area
# # #
Section A.1 Section A.2 Section A.3
Douglas Nonattainment Boundary Area Nonattainment Area and 50 Km Buffer Map Aerial Photography of PDDRWS Site
APPENDIX B SIP Support Information
#
Section B.1
Relevant Arizona Administrative Codes (AAC)
? ? ? ? ? ?
AAC R18-2-202 (Sulfur Oxides) AAC R18-2-403 (Permits for Sources Located in Nonattainment Areas) AAC R18-2-406 (Permit Requirements for Sources Located in Attainment and Unclassifiable Areas) AAC R18-2-715 (Standards of Performance for Existing Primary Smelters AAC R18-2-715.01 (Standards of Performance for Existing Primary Copper Smelters; Compliance and Monitoring) AAC R18-2-715.02 (Standards of Performance for Existing Primary Copper Smelters; Fugitive Emissions)
# #
Section B.2 Section B.3
ADEQ Air Quality Division Organizational Chart EPA Guidance Memoranda ? ? ? "Section 107 Designation Policy Summary," April 21, 1983, Director Sheldon Meyers "Procedures for Processing Requests to Redesignate Areas to Attainment," September 4, 1992, Director John Calcagni "Attainment Determination Policy for Sulfur Dioxide Nonattainment Areas," January 26, 1995, Director Sally L. Shaver "Redesignation of Sulfur Dioxide Nonattainment Areas in the Absence of Monitored Data," October 18, 2000, Director John Seitz.
?
APPENDIX C Emissions Inventory and Monitoring Network Data
# # # # #
Section C.1 Section C.2 Section C.3 Section C.4 Section C.5
Douglas Nonattainment Area Emissions Inventory - Point Sources (Table C.1) Douglas Nonattainment Area Emissions Inventory - Area and Mobile Sources for Years 1985 - 1998 (Table C.2) Douglas Nonattainment Area Emissions Inventory - Area and Mobile Sources for Year 1999 (Table C.3) Douglas Nonattainment Area Emissions Projections - Area and Mobile Sources for Years 2000 - 2015 (Table C.4) Ambient Air Monitoring Data (Table C.5)
Table C.1:
Annual Point Source Emissions Inventories
Emissions Inventory: Arizona Public Service (APS), Fairview Generating Station *
Year of Inventory
1990 1996 1998 1999
SO2 (tpy)
0.48 0 2.24 1.41
Emissions Inventory: Chemical Lime, Inc. *
Year of Inventory
1990 1993 1994 1995 1996 1997 1998 1999
SO2 (tpy)
212.22 268.01 412.71 346.33 363.97 684.48 724.47 744.55
Emissions Inventory: Maddux & Sons, Coleman Pit *
Emissions data for this facility with the exception of years 1996, 1998,1999 and 2000 is unavailable. In accordance with AAC R18-2-327(B)(3)(a) facilities with less than one ton of emissions are exempt from annual reporting of emissions.
Year of Inventory
1996 1998 1999 2000
SO2 (tpy)
1.00 .25 0.41 1.08
Table C.2:
Annual Area and Mobile Source Emissions Inventories for Years 1985 through 1998
SOURCE Fuel Combustion Industrial - Coal Fuel Combustion Industrial - Oil Fuel Combustion Commercial/Institution Oil Fuel Combustion - Residential Wood Fuel Combustion - Residential Other Waste Disposal and Recycling Incineration Waste Disposal and Recycling - Open Burning Light Duty Gas Vehicles and Motorcycles Light Duty Gas Trucks Heavy Duty Gas Vehicles Diesels Off-Highway, Non-Road Gasoline Off-Highway, Non-Road Diesel Aircraft Railroads Other Combustion TOTAL SO2 Tons per Year
1985 163 6 6 5 1 2 2 83 36 8 252 3 76 3 24 12 684
1986 195 9 5 3 1 3 2 83 37 8 266 4 79 3 26 11 735
1987 57 8 7 4 1 3 2 89 41 9 293 4 83 3 28 20 652
1988 51 7 6 4 1 3 2 85 40 8 291 4 87 3 30 34 655
1989 59 10 5 3 1 3 2 101 45 9 330 4 91 3 32 43 740
1990 32 10 5 3 1 3 2 96 43 9 326 4 95 4 33 7 673
1991 33 8 3 2 1 3 2 87 39 8 295 4 98 3 40 9 637
1992 31 8 2 3 1 3 2 88 38 8 302 4 102 3 41 9 644
1993 32 5 2 2 1 3 2 83 36 7 217 4 106 3 42 11 557
1994 32 5 1 3 1 3 3 79 43 8 57 4 110 3 39 28 419
1995 32 4 1 2 1 3 3 54 32 6 48 4 114 3 38 24 368
1996 31 3 N/A 2 1 3 3 51 39 6 52 4 118 3 39 29 385
1997 32 3 N/A 2 1 3 3 51 41 6 54 4 121 3 41 15 380
1998 31 3 N/A 3 1 3 3 52 41 6 53 4 125 3 41 17 387
Table C.3:
Area and Mobile Source Emissions Inventories for 1999
SOURCE Fuel Combustion Electric Utility Fuel Combustion Industrial Fuel Combustion - Other Petroleum and Related Industries Other Industrial Processes Waste Disposal and Recycling Highway Vehicles Off-Road Vehicles Other Combustion TOTAL SO2 Tons Per Year
1999 0 36 3 0 0 6 259 155 17 476
Table C.4: Area and Mobile Source Emissions Projections for 2000 through 2015
*Emissions Projections Total for Year: S O2 Ton Per Year 2000 57.2 2005 60.8 2010 64.2 2015 67.4 * Projections based on expected population growth from ADES
Table C.5:
Monitoring Network Data* Monitoring Network Data: Year 1987
Monitor
ADEQ 1.2 mi. N of Smelter
No. of Annual Number of 1-Hr. Annual Ave. Max 3-hr. Ave. 24-hr. and 24-hr. Samples Exceedances
2 473 64 0 8551
Monitoring Network Data: Year 1986 Monitor
Phelps-Dodge 0.75 mi. N. of Smelter Curtis Fir F Ave. & 9th St. Queen Mexican Border Mobile IV SEAMC Hospital Pirtleville McNeal ADEQ 1.2 mi. N. of Smelter Lazy KJ Ranch AEPCO Dragoon Kansas Settlement
No. of Annual Number of 1-Hr. Annual Ave. Max 3-hr. Ave. 24-hr. and 24-hr. Samples Exceedances
42 22 24 25 31 20 28 46 31 4 34 13 0 0 1065 987 742 629 1135 384 1135 1406 1249 520 1144 1011 35 29 217 165 168 159 310 108 274 242 178 88 194 129 11 8 0 0 0 0 0 0 0 0 0 0 0 0 0 0 8712 8713 8715 8718 8698 2207 8710 8712 8706 3216 8707 8678 5489 4261
Monitoring Network Data: Year 1985 Monitor
Phelps-Dodge Curtis Fir F Ave. & 9th St. Queen Mobile IV SEAMC Hospital Pirtleville McNeal ADEQ 1.2 mi. N. of Smelter AEPCO Dragoon Kansas Settlement
No. of Annual Number of 1-Hr. Annual Ave. Max 3-hr. Ave. 24-hr. and 24-hr. Samples Exceedances
36 36 34 42 35 65 50 10 57 0 0 1240 934 987 1048 1205 1258 1039 800 1162 79 52 248 233 237 246 293 290 281 114 300 18 10 0 0 0 0 0 0 0 0 0 0 0 8671 8653 8689 8593 8673 8679 8664 6616 3299 7002 5624
Monitoring Network Data: Year 1984 No. of Annual Number of 1-Hr. and 24-hr. Samples Exceedances
0 0 0 0 0 0 0 0 0 0 0 0 6384 6372 6382 6288 6354 6392 6385 6365 5159 8355 4749 3156
Monitor
Phelps-Dodge 0.75 mi. N. of Smelter Curtis Fir F Ave. & 9th St. Queen Mobile IV SEAMC Hospital Pirtleville McNeal ADEQ 1.2 mi. N. of Smelter AEPCO Dragoon Kansas Settlement
Annual Ave. Max 3-hr. Ave. 24-hr.
48 35 24 26 32 26 59 36 6 36 3 14
1093 1153 812 1127 1100 1231 1381 1074 254 1311 131 183
254 275 157 231 223 262 278 241 60 288 21 105
Monitoring Network Data: Year 1983 Monitor
Phelps-Dodge 0.75 mi. N. of Smelter Curtis Fir 1012 G Street Queen Mobile IV SEAMC Hospital Pirtleville McNeal ADEQ 1.2 mi. N. of Smelter AEPCO Dragoon Kansas Settlement
Annual Ave. Max 3-hr. Ave. 24-hr.
No. of Annual Number of 1-Hr. and 24-hr. Samples Exceedances
0 0 0 0 1 0 0 0 0 0 0 0 6404 6526 6540 6535 6423 6534 6528 6537 5104 6046 2115 2253
27 17 16 17 24 18 35 20 1 25 2 2
917 1643 760 1389 2796 1014 1074 935 168 822 79 118
207 228 223 199 372 186 225 194 24 737 13 21
Monitoring Network Data: Year 1982 No. of Annual and Number of 1Annual Ave. Max 3-hr. Ave. 24-hr. 24-hr. Hr. Samples Exceedances
27 17 16 17 24 18 35 20 1 25 49 2 2 2 917 1643 760 1389 2796 1014 1074 935 168 822 1229 217 79 118 207 228 223 199 372 186 225 194 24 737 250 31 13 21 0 0 0 0 1 0 0 0 0 0 0 0 0 0 6404 6526 6540 6535 6423 6534 6528 6537 5104 6046 2451 5338 2115 2253
Monitor
Phelps-Dodge 0.75 mi. N. of Smelter Curtis Fir 1012 G Street Queen Mobile IV County Hospital Pirtleville Pinedo Farm ADEQ 1.2 mi. N. of Smelter County Hospital 2.6 WSW of Town AEPCO Dragoon Kansas Settlement
Monitoring Network Data: Year 1981 Monitor
Phelps-Dodge 0.75 mi. N. of Smelter Curtis Fir 1012 G Street Queen Mobile III Mobile IV SEAMC Hospital Pirtleville McNeal ADEQ 1.2 mi. N. of Smelter AEPCO Dragoon Kansas Settlement
No. of Annual and Number of 1Annual Ave. Max 3-hr. Ave. 24-hr. 24-hr. Hr. Samples Exceedances
59 37 25 34 39 35 43 67 46 5 62 6 4 2201 1826 1056 1729 1284 1467 1467 2245 1501 755 1529 N/A N/A 328 270 170 262 222 265 225 341 369 126 425 24 24 0 0 0 0 0 0 0 0 1 0 1 0 0 8720 8720 8715 8722 8706 7177 1523 8705 8700 5011 7716 N/A 226
Monitoring Network Data: Year 1980 Monitor
Phelps-Dodge 0.75 mi. N. of Smelter Curtis Fir 1012 G Avenue Queen Mobile III SEAMC Hospital Pirtleville McNeal ADEQ 1.2 mi. N. of Smelter County Hospital McNeal AEPCO Dragoon Kansas Settlement 45 24 18 29 30 22 45 40 4 38 33 1 7 6 1511 1554 926 1520 1292 1423 1729 1677 283 1479 1696 244 N/A N/A 283 237 204 259 283 257 309 280 71 307 280 31 24 14 0 0 0 0 0 0 0 0 0 0 0 0 0 0 8724 8720 8686 8726 8680 8721 8742 8709 5236 7420 7909 3370 N/A N/A
No. of Annual Annual Ave. Max 3-hr. Ave. 24-hr. and 24-hr. Exceedances
Number of 1-Hr. Samples
Monitoring Network Data: Year 1979 Monitor
Phelps-Dodge 0.75 mi. N. of Smelter Curtis Fir 1012 G Avenue Queen Mobile II Mobile III NW Pirtleville McNeal ADEQ 2 km NNW of Smelter U.S. 666 AEPCO Dragoon Kansas Settlement 48 39 24 37 29 44 94 67 45 9 43 42 10 11 1920 1816 812 1423 1082 1239 935 1441 1302 1300 1785 1276 N/A N/A 270 521 204 244 236 299 136 367 396 197 471 392 57 44 0 1 0 0 0 0 0 1 1 0 3 1 0 N/A 8703 8718 8691 8704 8678 8610 108 8704 8705 6825 6912 6517 N/A N/A
No. of Annual Annual Ave. Max 3-hr. Ave. 24-hr. and 24-hr. Exceedances
Number of 1-Hr. Samples
* SOURCE FOR ALL DATA: ADEQ Air Quality Annual Reports
Monitoring Network Data: Year 1978 Monitor
Phelps-Dodge 0.75 mi. N. of Smelter Curtis Fir Fairgrounds Queen 1010 G Avenue Mobile II Mobile Pirtleville McNeal 1.22 mi. NW of Smelter ADEQ 2 km NNW of Smelter U.S. 666, 2 km NNE of Smelter AEPCO Dragoon Kansas Settlement 42 28 21 16 18 29 23 46 37 8 55 25 32 6 9 1213 1527 2078 741 1275 1039 777 1449 1109 922 1711 951 1069 N/A N/A 249 275 259 139 169 197 163 320 246 115 288 189 236 42 50 8730 8731 8722 7118 1508 8727 1126 7275 8704 3234 8725 6541 4877 N/A N/A
Annual Ave.
Max 3-hr.
24-hr. Max Number of Samples
Monitoring Network Data: Year 1977 Monitor
Phelps-Dodge 0.75 mi. N. of Smelter Curtis Fir Fairgrounds 1012 G Avenue Martin Mobile 1.22 mi NW of Smelter Pirtleville ADEQ 2 km NNW of Smelter 38 27 29 13 28 13 32 48 40 35 1546 2009 1800 891 1538 1031 1224 1658 1685 1292 211 389 344 225 354 312 241 257 354 214 8586 8713 8726 8731 8694 5911 2678 8719 8711 7053
Annual Ave.
Max 3-hr.
Ave. 24-hr.
Number of Samples
U.S. 666, 2 km NNE of Smelter
41
1879
272
6466
Monitoring Network Data: Year 1976 Monitor
Phelps-Dodge 0.75 mi. N. of Smelter Curtis Fir Fairgrounds 1012 G Avenue Martin 1.22 mi. NNW of Smelter Pirtleville ADEQ 2 km NNW N. of Smelter U.S. 666, 2 km NNE of Smelter 39 31 33 17 31 14 51 43 43 39 1677 1546 1100 1188 1768 1039 1406 1511 1233 1767 430 261 247 181 382 183 262 308 221 377 8729 8704 8741 8754 8754 8737 8738 8729 5373 6654
Annual Ave. Max 3-hr.
Ave. 24-hr.
Number of Samples
Monitoring Network Data: Year 1975 Monitor
Phelps-Dodge 0.75 mi. N. of Smelter Cochise College* 1012 G Avenue Pirtleville 15th Street Park ADEQ 2 km NNW of Smelter U.S. 666, 2 km NNE of Smelter * station closed 2-75 94 89 100 92 86 86 86 710 462 434 576 222 150 150 688 411 363 540 210 146 146 340 55 328 337 45 11 11
Annual Ave. Max 3-hr.
Ave. 24-hr.
Number of Samples
Monitor
Annual Ave. Max 3-hr.
Ave. 24-hr.
Number of Samples
Monitoring Network Data: Year 1974 Monitor
ADEQ
Annual Ave. Max 3-hr.
Max 24-hr.
Number of 24-hr. Exceedances 44 38 No. of 24-hr. Exceedances
5 20 52
2 km NNW of Smelter 130 5284 1069 U.S. 666, 2 km NNE of Smelter 79 5667 1174 Monitoring Network Data: Year 1973 Monitor
ADEQ NE1* NNE2** NNW2 * station closed 4-11-73 and relocated to NNE2 site ** station opened on 4-11-73 46 90 107 3605 5385 7408 556 1077 1547
Annual Ave. Max 3-hr.
Max 24-hr.
Monitoring Network Data: Year 1972 Monitor
ADEQ NE1 NNW2* * sampling began on 3/14/72 89 56 6974 7435 1046 3768 69.6 67.1
Annual Ave. Max 3-hr.
Ave. Max 24-hr.
Percent Data Recovery
Monitoring Network Data: Year 1971
Monitor
ADEQ NE1* ESE3** * station opened on 4/28/71 ** station closed on 4/29/71
Annual Ave. Max 3-hr.
55 57 4914 2317
Ave. Max 24-hr.
633 457
Percent Data Recovery
85.3 86.3
Monitoring Network Data: Year 1970 Monitor
ADEQ ENE4* ESE3 * station closed on 11/24/70 * SOURCE FOR ALL DATA: ADEQ Air Quality Annual Reports 51 44 1751 1780 485 463 70 79
Annual Ave. Max 3-hr.
Ave. Max 24-hr.
Percent Data Recovery
November 28, 2001 RESPONSIVENESS SUMMARY to Testimony Taken at Oral Proceeding and Written Comments Received on Douglas Sulfur Dioxide State Implementation and Maintenance Plan
The oral proceeding on Douglas Sulfur Dioxide State Implementation and Maintenance Plan was held at 4:00 p.m., Tuesday, November 6, 2001, at Cochise Community College, Douglas, Arizona. No oral comments were received during the proceeding, nor did the Arizona Department of Environmental Quality (ADEQ) received any written comments during the public comment period, which ended November 6, 2001. ADEQ did make some grammatical corrections and clarified certain phrases throughout the document.
* Source: ADEQ Air Quality Division - Compliance Section, Technical Services Unit
