Gratitude For Sulfur Dioxide Redesignation

February 11, 1999 
75 Hawthorne Street 
Francisco, CA 94105–3901 
Arizona Deparünent of Environrnental Quality 
3033 North Central Avenue 
Phoenix, AZ 85012 
Dear Mr. McKenna: 
Thank you for the opportunity to review and comment on the draft materials assembled 
for the of the Douglas and Miami sulfur dioxide nonattainment areas. Your work 
appears to be mostly complete and very’ comprehensive. I look fonvard to the remainder of the 
draft section items, a narrative to explain how the various Appendices fit together, and several 
emission inventories. 
As you have shown that the Douglas smelter was permanently closed on January 15, 
1987 (with a notarized affdavit), the area’s redesignation should be the simplest of the Arizona 
smelter areas. An approved State Implementation Plan (SIP) maintenance plan would contan 
the above evidence. You have included the ambient data from the years before and after the 
closure (1969–96). The lack of monitoring data for Douglas after 1987 only confirms the 
absence of a problem. May I suggest FRO annual average sulfur dioxide inventories of actual 
emissions for before and after the closure for the nonattainment area. 
As the Miami smelter SIP was approved %dth the exception of the fugitive emissions 
control strategy demonsfration (at 40 CFR 51 .125(a)(1)), your inclusion of such a demonstration 
in the draft submittal (as Appendix C.2.A) showing the monitoring program and the expected 
frequency of violation of the national standards provides most of the evidence needed to 
redesignate. Again the ambient air quality data is suffcient to show the quality of the air over 
the past 27 years. You have included a Gila County inventory of stationary source sulfur dioxide 
emissions for 1994, 1995, 1996, and 1997 (at Appendix C.2.B), but the duplicative enü-ies for 
each source and the “ACTCONT” column need further explanation. The current year inventory 
needs to include all (point, area, and mobile) sources of sulfur dioxide emissions. In this case, 
the actual and potentiaVallowable (annual 24-hour and 3-hour average) disaggregation of smelter 
emissions into stack and fugitive would be useful. 
Printed Recvcled

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