DOUGLAS SULFUR DIOXIDE
NONATTAINMENT AREA
STATE IMPLEMENTATION AND MAINTENANCE PLAN

AIR QUALITY DIVISION
ARIZONA DEPARTMENT OF ENVIRONMENTAL QUALITY
November 29, 2001

C:\TEMP\MXLibDir\Douglas final.wpd

TABLE OF CONTENTS
1.0

INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1.1
1.1
1.2
1.3
1.4
1.5
1.6

2.0

SO2 Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3.1
Historical Data Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3.1

CONTROL MEASURES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4.1
4.1

4.2
4.3

5.0

Historical Emissions Inventory . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2.1
Emission Inventory for Attainment Demonstration: Years 1985-86, 1999 . . . . . . . . . . . . . . . . . . . . . 2.1

MONITORING NETWORK . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3.1
3.1
3.2

4.0

1.1
1.1
1.2
1.2
1.3
1.4
1.4
1.5
1.6
1.7

SO2 EMISSIONS INVENTORY FOR POINT, AREA AND MOBILE SOURCES 2.1
2.1
2.2

3.0

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 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

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

CONTINGENCY MEASURES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5.1
5.1

Prevention of Significant Deterioration (PSD) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5.1

6.0

CONFORMITY PROVISIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6.1

7.0

MAINTENANCE PLAN . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7.1
7.1
7.2
7.3
7.4
7.6

8.0

Emissions Inventories . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Dispersion Modeling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
PSD Permit Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Commitment to Resume Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Contingency Measures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

7.1
7.2
7.2
7.2
7.2

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

INTRODUCTION

1.1

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

1

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:

Primary

Annual

24-hour average

.030 ppm (80 Fg/m3 )

.14 ppm (365 Fg/m3 )

3-hour average

.5 ppm (1300 Fg/m3 )

Secondary

SOURCE: 40 CFR 50.4 - 50.5
2

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

3

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).

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

2000

2015

% Change
1997 - 2000

% Change
2000 - 2015

Cochise Co.

116,737

121,837

143,793

4%

18 %

Douglas

15,058

15,520

16,325

3%

5%

Arizona

4,595,379

4,961,953

6,744,754

8%

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.

4

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.

1.3

Table 1.2 Labor Force Data - Douglas, Arizona
1980

1990

1998

Civilian Labor

4,331

4,705

4,527

Employed

3,884

4,139

3,912

447

566

616

12.0%

13.6%

Unemployed
Unemployment Rate

10.3%

SOURCE: Arizona Department of Economic Security, 1997
Table 1.3 Growth Indicators - Douglas
1990

1997

1998

Taxable Sales

99,638,900

127,036,800

136,820,880

Postal Receipts

1,036,102

1,267,266

1,168,606

4,412

4,682

4,722

22,927,209

31,727,825

31,270,112

School Enrollment
Net ($) Assessed Valuation

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

See Appendix A.4 for location of these facilities.

6

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
7

Standards of Performance for Existing Primary Copper Smelters; Site-specific Requirements, R18-2-515,
renumbered R18-2-715 (1993).
8

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

SO2 EMISSIONS INVENTORY FOR POINT, AREA AND MOBILE SOURCES

2.1

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

Tons of SO2

300000
250000
200000
150000
100000
50000
0
1985 1986 1987 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999

Year
Tons 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

Tons SO2

700
600
500
400
300

1985 1986 1987 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999

Year
Area 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

CONTROL MEASURES

4.1
Area

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.
11

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.

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

CAA §119 (1)(c)(1)

14

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

1985 Tons of
SO2

1995 Tons of
SO2

Multiplier (based on
population growth
projections)

Projected Tons SO2 for
2015

Area and Mobile
Sources 17

684

385

1.284

494 tons SO2

Point Sources

333,240

5287

1.00

5287 tons SO2

Annual Total

333,924 tons

5,672 tons

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
16

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

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

= 1.73 percent

333,924 tons in 1985
7.2

Dispersion Modeling

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

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

APPENDIX B
Section B.1
Section B.2
Section B.3

SIP Support Information
Relevant Arizona Administrative Codes (AAC)
ADEQ Air Quality Division Organizational Chart
EPA Guidance Memoranda

APPENDIX C
Section C.1
Section C.2

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

Section C.3
Section C.4
Section C.5

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

ADEQ Air Quality Division Organizational Chart

#

Section B.3

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

SO2 (tpy)

1990
1996
1998
1999

0.48
0
2.24
1.41

Emissions Inventory: Chemical Lime, Inc. *
Year of Inventory

SO2 (tpy)

1990
1993
1994
1995
1996
1997
1998
1999

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

SO2 (tpy)

1996
1998
1999
2000

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

1986

1987

1988

1989

1990

1991

1992

1993

1994

1995

1996

1997

1998

163
6

195
9

57
8

51
7

59
10

32
10

33
8

31
8

32
5

6

5

7

6

5

5

3

2

2

32
5
1

32
4
1

31
3
N/A

32
3
N/A

31
3
N/A

5
1

3
1

4
1

4
1

3
1

3
1

2
1

3
1

2
1

2

3

3

3

3

3

3

3

3

3
1
3

2
1
3

2
1
3

2
1
3

3
1
3

2

2

2

2

2

2

2

2

2

3

3

3

3

3

83

83

89

85

101

96

87

88

83

79

54

51

51

52

36
8
252
3
76
3
24
12

37
8
266
4
79
3
26
11

41
9
293
4
83
3
28
20

40
8
291
4
87
3
30
34

45
9
330
4
91
3
32
43

43
9
326
4
95
4
33
7

39
8
295
4
98
3
40
9

38
8
302
4
102
3
41
9

36
7
217
4
106
3
42
11

43
8
57
4
110
3
39
28

32
6
48
4
114
3
38
24

39
6
52
4
118
3
39
29

41
6
54
4
121
3
41
15

41
6
53
4
125
3
41
17

684

735

652

655

740

673

637

644

557

419

368

385

380

387

Table C.3:

Area and Mobile Source Emissions Inventories for 1999

SOURCE

1999

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

0
6
259
155
17

TOTAL SO2 Tons Per Year

476

0
36
3
0

Table C.4: Area and Mobile Source Emissions Projections for 2000 through 2015
*Emissions Projections
Total
for Year:
SO2 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

1065
987
742
629
1135
384
1135
1406
1249
520

217
165
168
159
310
108
274
242
178
88

0
0
0
0
0
0
0
0
0
0

8712
8713
8715
8718
8698
2207
8710
8712
8706
3216

34
13

1144
1011

194
129

0
0

8707
8678

0
0

35
29

11
8

0
0

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

1240
934
987
1048
1205
1258
1039
800

248
233
237
246
293
290
281
114

0
0
0
0
0
0
0
0

8671
8653
8689
8593
8673
8679
8664
6616

57

1162

300

0

3299

0
0

79
52

18
10

0
0

7002
5624

Monitoring Network Data: Year 1984

Monitor

Annual Ave. Max 3-hr. Ave. 24-hr.

No. of Annual
Number of 1-Hr.
and 24-hr.
Samples
Exceedances

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

48
35
24
26
32
26
59
36
6

1093
1153
812
1127
1100
1231
1381
1074
254

254
275
157
231
223
262
278
241
60

0
0
0
0
0
0
0
0
0

6384
6372
6382
6288
6354
6392
6385
6365
5159

36

1311

288

0

8355

3
14

131
183

21
105

0
0

4749
3156

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

27
17
16
17
24
18
35
20
1

917
1643
760
1389
2796
1014
1074
935
168

207
228
223
199
372
186
225
194
24

0
0
0
0
1
0
0
0
0

6404
6526
6540
6535
6423
6534
6528
6537
5104

25

822

737

0

6046

2
2

79
118

13
21

0
0

2115
2253

Monitoring Network Data: Year 1982

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

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

917
1643
760
1389
2796
1014
1074
935
168

207
228
223
199
372
186
225
194
24

0
0
0
0
1
0
0
0
0

6404
6526
6540
6535
6423
6534
6528
6537
5104

25
49
2

822
1229
217

737
250
31

0
0
0

6046
2451
5338

2
2

79
118

13
21

0
0

2115
2253

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

2201
1826
1056
1729
1284
1467
1467
2245
1501
755

328
270
170
262
222
265
225
341
369
126

0
0
0
0
0
0
0
0
1
0

8720
8720
8715
8722
8706
7177
1523
8705
8700
5011

62

1529

425

1

7716

6
4

N/A
N/A

24
24

0
0

N/A
226

Monitoring Network Data: Year 1980

Monitor

No. of Annual
Annual Ave. Max 3-hr. Ave. 24-hr.
and 24-hr.
Exceedances

Number of 1-Hr.
Samples

Phelps-Dodge
0.75 mi. N. of Smelter
Curtis
Fir
1012 G Avenue
Queen
Mobile III
SEAMC Hospital
Pirtleville
McNeal
ADEQ

45
24
18
29
30
22
45
40
4

1511
1554
926
1520
1292
1423
1729
1677
283

283
237
204
259
283
257
309
280
71

0
0
0
0
0
0
0
0
0

8724
8720
8686
8726
8680
8721
8742
8709
5236

1.2 mi. N. of Smelter
County Hospital
McNeal
AEPCO

38
33
1

1479
1696
244

307
280
31

0
0
0

7420
7909
3370

Dragoon
Kansas Settlement

7
6

N/A
N/A

24
14

0
0

N/A
N/A

Monitoring Network Data: Year 1979

Monitor

No. of Annual
Annual Ave. Max 3-hr. Ave. 24-hr.
and 24-hr.
Exceedances

Number of 1-Hr.
Samples

Phelps-Dodge
0.75 mi. N. of Smelter
Curtis
Fir
1012 G Avenue
Queen
Mobile II
Mobile III
NW
Pirtleville
McNeal
ADEQ

48
39
24
37
29
44
94
67
45
9

1920
1816
812
1423
1082
1239
935
1441
1302
1300

270
521
204
244
236
299
136
367
396
197

0
1
0
0
0
0
0
1
1
0

8703
8718
8691
8704
8678
8610
108
8704
8705
6825

2 km NNW of Smelter
U.S. 666
AEPCO

43
42

1785
1276

471
392

3
1

6912
6517

Dragoon
Kansas Settlement

10
11

N/A
N/A

57
44

0
N/A

N/A
N/A

* SOURCE FOR ALL DATA: ADEQ Air Quality Annual Reports

Monitoring Network Data: Year 1978
Monitor

Annual Ave.

Max 3-hr.

24-hr. Max Number of Samples

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

42
28
21
16
18
29
23
46
37
8
55

1213
1527
2078
741
1275
1039
777
1449
1109
922
1711

249
275
259
139
169
197
163
320
246
115
288

8730
8731
8722
7118
1508
8727
1126
7275
8704
3234
8725

2 km NNW of Smelter
U.S. 666, 2 km NNE of Smelter
AEPCO

25
32

951
1069

189
236

6541
4877

Dragoon
Kansas Settlement

6
9

N/A
N/A

42
50

N/A
N/A

Phelps-Dodge

Monitoring Network Data: Year 1977
Monitor

Annual Ave.

Max 3-hr.

Ave. 24-hr.

Number of Samples

0.75 mi. N. of Smelter
Curtis
Fir
Fairgrounds
1012 G Avenue
Martin
Mobile
1.22 mi NW of Smelter
Pirtleville
ADEQ

38
27
29
13
28
13
32
48
40

1546
2009
1800
891
1538
1031
1224
1658
1685

211
389
344
225
354
312
241
257
354

8586
8713
8726
8731
8694
5911
2678
8719
8711

2 km NNW of Smelter

35

1292

214

7053

Phelps-Dodge

U.S. 666, 2 km NNE of Smelter

41

1879

272

6466

Monitoring Network Data: Year 1976
Monitor

Annual Ave. Max 3-hr.

Ave. 24-hr.

Number of Samples

Phelps-Dodge
0.75 mi. N. of Smelter
Curtis
Fir
Fairgrounds
1012 G Avenue
Martin
1.22 mi. NNW of Smelter
Pirtleville
ADEQ

39
31
33
17
31
14
51
43

1677
1546
1100
1188
1768
1039
1406
1511

430
261
247
181
382
183
262
308

8729
8704
8741
8754
8754
8737
8738
8729

2 km NNW N. of Smelter
U.S. 666, 2 km NNE of Smelter

43
39

1233
1767

221
377

5373
6654

Monitoring Network Data: Year 1975
Monitor

Annual Ave. Max 3-hr.

Ave. 24-hr.

Number of Samples

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

710
462
434
576
222

688
411
363
540
210

340
55
328
337
45

86
86

150
150

146
146

11
11

Monitor

Annual Ave. Max 3-hr.

Ave. 24-hr.

Number of Samples

Monitoring Network Data: Year 1974
Monitor

Annual Ave. Max 3-hr.

Max 24-hr.

Number of 24-hr.
Exceedances

ADEQ

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

Annual Ave. Max 3-hr.

44
38

Max 24-hr.

No. of 24-hr.
Exceedances

556
1077
1547

5
20
52

ADEQ
NE1*
NNE2**
NNW2

46
90
107

3605
5385
7408

* station closed 4-11-73 and
relocated to NNE2 site
** station opened on 4-11-73

Monitoring Network Data: Year 1972
Monitor

Annual Ave. Max 3-hr.

Ave. Max 24-hr.

Percent Data Recovery

1046
3768

69.6
67.1

ADEQ
NE1
NNW2*

89
56

6974
7435

* sampling began on
3/14/72

Monitoring Network Data: Year 1971

Monitor

Annual Ave. Max 3-hr.

Ave. Max 24-hr.

Percent Data Recovery

633
457

85.3
86.3

ADEQ
NE1*
ESE3**

55
57

4914
2317

* station opened on
4/28/71
** station closed on
4/29/71

Monitoring Network Data: Year 1970
Monitor

Annual Ave. Max 3-hr.

Ave. Max 24-hr.

Percent Data Recovery

485
463

70
79

ADEQ
ENE4*
ESE3

51
44

1751
1780

* station closed on
11/24/70
* SOURCE FOR ALL DATA: ADEQ Air Quality Annual Reports

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