-------
market sales showed a gain of 6.2 percent. The transportation market
shows a gain of 5.0 percent. An increase of 9.7 percent occurred in
the electrical and electronic product markets. The demand for elec-
trical equipment has risen because of increased emphasis on safety,
comfort, recreation, and a pollution-free environment. Automation,
including the use in computers, has also boosted the use of copper.
Substitution of other materials, coupled with the recession, has
caused the slight drop of less than 1 percent in the consumer and
general products markets. The 1 percent decline in the industrial
machinery and equipment market is largely due to the impact of the
recession.
The Bureau of Mines estimates that the most growth in copper
demand will occur in the electrical and electronic products industries,
consumer and general products, and building construction. Copper is an
important metal in electric vehicles. If electric vehicles become
popular, this would be a source of increased demand for copper.
General Motors plans to produce an electric family car for mass market-
ing in the mid-19801s. A conventional internal combustion automobile
contains from 6.8 to 20.4 kg of refined copper, whereas electric
vehicles use much more copper. The Copper Development Association
estimates range from 45.4 kg to 90.7 kg, with an average nearer
to 45.4 kg.21
Another potential area for growth is in the solar energy indus-
try. Presently, the extent of this sector is relatively modest,
consuming approximately 4,500 Mg/yr of copper in the U.S. However,
consumption in this sector has the potential to climb considerably.
In addition, the U.S. military demand for copper is expected to
increase. Increased military expenditures will have a significant
impact on copper demand because copper is an important element in
modern electronic weaponry. During heavy rearmament periods the mili-
tary demand for the metal has reached 18 percent of copper mill ship-
ments. Although military demand is not expected to return to the
record high 18 percent level, analysts do expect a large increase in
military requirements for copper from the low level in 1979 of less
than 2 percent.zz
The demand picture in the United States may receive a boost from
the federal government. The government is committed to eventually
acquire 1.1 gigagrams of copper for its currently depleted strategic
stockpile. The previous stockpile was largely depleted in 1968; the
final sale was in 1974 after copper prices had soared. Further Congres-
sional action is necessary to implement and fund the purchase plan.
F.I.4.2 Substitutes. Substitutes for copper are readily avail-
able for most of copper's end uses. Copper's most competitive substi-
tute is aluminum. Other competitive materials are stainless steel,
zinc, and plastics. Aluminum, because of its high electrical conduc-
tivity, is used extensively as a copper substitute in high voltage
F-ll
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electrical transmission wires. Aluminum has not been used as exten-
sively in residential wiring because of use problems, and minimal
savi ngs.
Aluminum is also potentially a substitute for copper in many heat
exchange applications. For example, automobile companies are still
experimenting with the use of aluminum versus copper in car radiators.
When copper prices are high, or copper supply is limited, cast iron and
plastics are used in building construction as a copper pipe substitute.
A relatively new substitute for copper is glass, which is used in fiber
optics in the field of telecommunications.
F.I.5 Prices
Numerous factors influence the copper market, and thus the price
of refined copper. These factors include: production costs, long-run
return on investment, demand, scrap availability, imports,- substitute
materials, inventory levels, the difference between metal exchange
prices and the refined price, and federal government actions (e.g.,
General Services Administration stockpiling and domestic price controls).
Among the many published copper price quotations, two key price
levels are: 1) those quoted by the primary domestic copper producers
and 2) those on the London Metal Exchange and reported in Metals Week,
Metal Bulletin, and the Engineering and Mining Journal. The producers'
price listed most often is for refined copper wirebar, f.o'.b. refinery.
The London Metal Exchange price, referred to as LME, is also for copper
sold as wirebar. The LME is generally considered a marginal price
reflective of short-term supply-demand conditions, while the producer
price is more long-term and stable and often lags the LME price movement.
Copper is also traded on the New York Commodity Exchange (Comex).
Arbitrage keeps the LME price and the Comex price close together (with
minor price differences due to different contract terms on the two
exchanges, and a transportation differential).
Table F-5 shows the LME, the U.S producer price, and the U.S.
producer price adjusted to a 1982 constant price for the years 1970
through 1982. Data were obtained from U.S. Bureau of Mines publications.
Several points can be observed from the table with respect to the
LME price versus the U.S. producer price: (1) the LME price has had
wider swings than the producer price; (2) in the past when both prices
are relatively high, the LME price has been considerably higher than
the producer price, while during relatively low price periods, the
producer price has been moderately higher than the LME price; and (3)
in recent years a marked change appears to be taking place away from a
two-price system and toward a one-price system, with the difference
between the LME and the U.S. producer price accounted for only by a
transportation differential. These earlier situations had reoccurred
repeatedly over the past 20 years. One other point about the table
should be mentioned, although unrelated to the relationship of the
F-12
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Table F-5. AVERAGE ANNUAL COPPER PRICES23»24,25
(cents per kg)a
Year
LMEb
U.S Producer Pn'cec
U.S. Producer Price
1982 Constant Priced
1970
1971
1972
1973
1974
1975
1976
1977
1978
1979
1980
1981
1982e
138.6
106.7
106.7
178.0
204.8
123.4
140.6
130.7
136.2
198.2
218.5
174.7
147.4
128.0
114.4
112.6
130.9
170.1
141.2
153.1
147.0
146.3
205.3
225.3
187.2
162.8
290.9
248.7
234.6
256.7
303.8
231.5
239.2
216.2
200.4
259.9
262.0
199.1
162.8
aTo convert from cents/kg to cents/1b, multiply by 0.454.
bLondon Metal Exchange "high-grade" contract.
CU.S producer price, electrolytic wirebar copper, delivered U.S destinations
basis.
dAdjusted to 1982 constant price by applying implicit price deflator for
gross national product (1972 = 100).
Preliminary.
F-13
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LME to the producer price.
general inflation.
The producer price has not kept pace with
In theory, the U.S. producer price should be somewhat higher than
the LME price since ocean transport costs must be incurred to get the
refined copper to the U.S. However, this relationship appears to hold
only during slack price periods. When LME prices are high, the pro-
ducers do not raise their prices as much, which in theory appears
contrary to profit maximization. Explanations offered for such behavior
include: the producers' fear of long-run substitution for copper if
the producers raised the price to the fabricators, high profits for
integrated fabricators while reducing supply to nonintegrated fabri-
cators, past fears of government stockpile sales that would reduce
prices, and fear of the return of government intervention through price
controls.
The cost of producing copper is one of the elements that influences
the price of copper. Considerable data exist to validate the point
that the long-run economic cost of producing copper is increasing.26
During the early 1970's the capital costs per megagram of annual
capacity for developing copper from the mine through refining stage
were $2,000 to $2,500, and by the late 1970's had risen sharply to
$7,200 to $7,700. Estimates are that a price of $2.76 per kg to $3.30
per kg for refined copper would be needed to support such new capital
outlays.
The above costs are for conventional pyrometallurgical smelting.
The newer smelting processes such as Noranda and Mitsubishi offer some
capital cost savings at that stage due to lower pollution control
costs. The hydrometallurgical processes also require less capital.
However, the mining costs are the highest part of overall development
costs for which limited cost saving techniques exist. The mine develop-
ment costs in the U.S. have risen significantly, largely as a result of
the shifting from higher to lower grades of available copper ores and
sometimes remote locations that require infrastructure costs for towns,
roads, etc.
In 1979, the Bureau of Mines analyzed 73 domestic copper proper-
ties to determine the quantity of copper available from each deposit
and the copper price required to provide each operation with 0 and 15
percent rates of return. The Bureau estimates that a copper price of
$4.56 per kg would be required if all properties, producing and nonpro-
ducing, were to at least break even. The average break-even copper
price for properties producing in 1978, $1.46 per kg, was about equiva-
lent to the average selling price for the year. At this price, analysts
calculate that only 25 properties could either produce at break-even or
receive an operating profit. Of these properties, only 12 could receive
at least a 15 percent rate of return.
Annual domestic copper production, from 1969 to 1978, averaged
1,337,000 megagrams. According to this study, in order to produce at
this level and receive at least a 15 percent rate of return, a copper
F-14
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price of $1.81 per kg Is required. If the United States were to
produce the additional 248,000 megagrams that were imported each year
over this period, a copper price of $1.94 would be necessary.27 The
report concludes that increases in copper prices are required in order
for many domestic deposits to continue to produce.
It has been suggested that long-term potential for higher prices,
plus the high cost of new capacity are significant reasons for the
increased purchases several years ago of copper properties by oil
companies. The reasoning is that oil companies need places for heavy
cash flows, and diversification to other products is desirable. The
oil companies reportedly can wait for expected copper price increases
to obtain their return. Further, by purchasing existing facilities,
rather than building new capacity, they avoid the escalating new
capacity costs. However, more recently, some oil companies seem to be
rethinking their investments in copper.
As shown below, U.S. oil (and gas) companies own or have major
interests in many of the largest domestic copper producers:
1. Amax - Approximately 20 percent owned by Standard Oil of
California
2. Anaconda - Owned by Atlantic Richfield Company (ARCO)
3. Cities Service - Also a primary copper producer
4. Copper Range - Owned by Louisiana Land and Exploration
Company
5. Cyprus Pima Mining Company - Standard Oil Company (Indiana)
6. Duval - Owned by Pennzoil Company
7. Kennecott - Standard Oil of Ohio (British Petroleum)
These copper producers own or control a large portion of domestic
copper reserves, mine production, and U.S. refinery capacity. Their
investment in the copper industry is significant, and thus they must
expect higher prices and profits in the future.
F-15
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F.2 ECONOMIC ANALYSIS
F.2.1 Introduction
This section presents the economic analysis of the arsenic NESHAP
for the 14 primary copper smelters. The fifteenth primary copper
smelter (ASARCO-Tacoma) is not discussed in this analysis, because the
company has announced its intention to close the smelter during 1985.
Two principal economic effects are analyzed. First, the ability
of the smelters to pass pollution control costs forward to consumers,
in the form of an increase in the price of copper. Second, the reduc-
tion in profits if part or all of the control costs cannot be passed
forward in the form of price increases but must be absorbed by the
copper producers. Section F.2.2 presents a summary of the results.
Section F.2.3 presents the methodology. Section F.2.4 presents the
impact on prices, Section F.2.5 presents the impact on profits, and
Section F.2,'6 presents a discussion of capital availability.
F.2.2 Executive Summary
In 1982 the copper producers experienced one of the worst years in
recent history. During much of 1982 major segments of the industry
were closed for sustained periods. Such a depressed situation cannot
be used as the foundation to examine the long-term economic effects of
the potential arsenic NESHAP. Therefore the economic analysis is based
on a more normal condition for the industry. However, even under more
typical conditions for the industry, six smelters may face significant
financial impairment, and two additional smelters, Cities Service-Copper-
hill and Kennecott-McGi11, appear to be likely closures. The control
costs for the remaining six smelters appear affordable.
If each smelter attempts to pass control costs forward in the form
of a price increase, the price increases would range from 0 percent to
15.2 percent, at an 80 percent capacity utilization rate, and depending
on the regulatory alternative. For Alternative II the price increase
would be 0 for every smelter, with one exception (Kennecott-McGill)
that would have a large 15.2 percent price increase. For Alternative
III the price increases would range from 0.2 percent to 6.3 percent.
For Alternative IV the price increases are lower and would range from 0
to 1.3 percent. For Alternative III+IV the price increases would range
from 0.2 percent to 7.6 percent. Competition will prevent the existence
of such a broad variation, and therefore partial or complete absorption
of control costs is more likely than a full pass forward of control
costs.
If control costs are absorbed and profit margins reduced, again a
broad range exists. At an 80 percent capacity utilization rate and a
ten percent profit margin, for Alternative II the profit decrease would
be 0 for every smelter, with one exception (Kennecott-McGill) that
would result in a net loss. For Alternative III the profit decrease
would range from 2.1 percent to 62.6 percent. For Alternative IV the
F-16
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profit decrease would be lower and would range from 0 percent to 12.8
percent. For Alternative III+IV the profit decrease would range from
2.1 percent to 75.4 percent.
Although the capital costs of the control equipment are not minor
amounts, for most of the producers the capital cost would not present a
major obstacle. For two of the producers, ASARCO and Phelps Dodge, the
capital costs may present some difficulty but should not be an insur-
mountable financial obstacle.
F.2.3 Methodology
The purpose of this section is to explain in general terms the
methodology used in the analysis. Each of the appropriate sub-sections
explains the methodology in more detail. No single financial indicator
is sufficient by itself to use for decision making purposes about the
primary copper smelters. Therefore the methodology relies on several
indicators which in total can be used to draw conclusions about the
industry.
The methodology has three major parts. The first part is an
analysis of price effects. The analysis of price effects introduces an
upper limit on the problem and provides a benchmark to make evaluations
on a relatively uncomplicated basis. A price increase represents the
"worst case" from the viewpoint of a consumer of copper. The second
major part of the methodology is an analysis of profit effects. The
analysis of profit effects introduces a lower limit on the problem and
is the "worst case" from the viewpoint of the firm. The individual
characteristics of each smelter increase in importance and are incorpor-
ated to a greater extent. The third and final part of the methodology
is an analysis of the availability of capital to purchase the control
equipment.
Firms in the copper industry face a wide variety of variables that
in the aggregate determine the economic viability of the firm generally,
and a smelter specifically. The variables can be grouped into four
broad categories. The categories are described here separately and in
a simplified manner for discussion purposes. However, there is a close
interrelationship among the four categories and changes in one will
have implications for the others. The four broad categories that
determine the economic viability of the smelter are described below.
1) Macroeconomic conditions. The two most prominent variables in
this category are copper prices and copper demand. By-products and
co-products represent a significant source of revenues for most copper
operations. Therefore in addition to the price of copper, the price of
by-products and co-products also influence an assessment of economic
viability. Common by-products and co-products of copper production
include: gold, silver, molybdenum, and sulfuric acid. Other by-products
include selenium, tellurium, and antimony. For ease of presentation
and in order to present a conservative analysis, by-products and
co-products are not considered explicitly in the analysis.
F-17
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Another important variable, though somewhat less visible, is
government actions, such as: federal and state tax policy; stockpiling;
price controls; tariffs and import quotas; and international develop-
ment loans and trade credits. The government variable includes the
U.S. Government, as well as foreign governments. For example, consider
that a report by the U.S. Bureau of Mines has stated that at least 40
percent of the total mine production of copper in market economy
countries was produced by firms in which various foreign governments
owned an equity interest.28 The significance of government ownership
and involvement in the production of copper is that the forces of
supply and demand are distorted by the involvement.
2) Environmental regulations. Since roughly 1970, environmental
regulations have evolved to the point that they have become a major
variable that must be considered in the corporate decision making
process. Here again, government actions are important.
3) Corporate organizational strategy. This category includes the
corporation's strategy with respect to variables such as remaining or
becoming an integrated copper producer versus a non-integrated copper
producer, or perhaps leaving the industry entirely.
Many of the companies that produce refined copper are integrated
producers; that is, they own the facilities to treat copper during each
of the four principal stages of processing: mining, milling, smelting,
and refining. Also, several of the producers are integrated one
additional step into the fabrication of refined copper. However, not
all companies in the copper industry are integrated producers. There
are companies that only mine and mill copper ore to produce copper
concentrate, and then have the copper concentrate smelted and refined
on a custom basis (the smelter takes ownership of the copper) or on a
toll basis (the smelter charges a service fee and returns the copper to
the owner). The existence of both integrated and non-integrated
producers introduces a complex economic element into this analysis.
That complex economic element manifests itself in the choice of
the appropriate profit center to use in the analysis. This standard
affects only one stage of the production process (smelting) in a direct
way, but has indirect effects on the other stages (mining, milling, and
refining).
For accounting purposes, integrated producers frequently view the
smelter as a cost center, rather than a profit center. However, in an
economic sense the smelter provides a distinct contribution to the
production process that ultimately allows a profit to be earned,
although that profit may be realized for accounting purposes at another
stage of the production process such as the mine or refinery.
4) Competition. Mines have long-run flexibility in deciding
where they will send their copper concentrate for smelting. Therefore,
copper smelters face competition from three sources: other existing
domestic smelters, new smelters that may be built, and foreign smelters,
especially Japanese. Other competition, though less direct, is also
F-18
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important. For example, copper scrap and substitutes such as plastic
and aluminum present competition.
Japan is a major force among copper producing countries in terms
of its volume of smelting, refining, and fabrication of copper.
However, Japan does not have copper ore deposits of any noteworthy
size. Therefore it must import concentrates in order to supply its
smelting, refining, and fabricating facilities. Japan seeks concen-
trates from many countries, including the United States. Japan's
ability to be competitive with U.S. smelters for U.S. concentrates is
indicated by the contractual arrangements it has established with
Anamax and Anaconda to purchase concentrates. Also, the Japanese
smelters have approached many other copper mine owners in the United
States. For example, Cyprus Corporation is reported to have seriously
considered shipping concentrates from its Bagdad mine to Japan.
The cost to transport concentrates across the Pacific Ocean is
significant. The fact that Japanese smelters can compete with U.S.
smelters, in spite of the costs to transport concentrates across the
Pacific Ocean, is quite noteworthy. One factor that explains the
Japanese ability to compete is that Japanese smelters are newer than
U.S. smelters and, in theory, should be more cost competitive. Other
factors that operate to the advantage of Japanese smelters, including a
protective tariff mechanism, are described later.
The existence of competition for concentrates introduces what is
commonly referred to as a "trigger" price. The "trigger" price is that
price which triggers or provides an economic incentive for the supplier
of concentrate to change to another smelter and refinery. If a given
smelter charges a service fee in excess of competing smelters, that
smelter will lose business and eventually be forced to cease operations.
In the case of new smelters or expansions, the new process facilities
will not be built. Faced with an increase in costs, a smelter could
respond using one of three options, or any combination of the three.
First, the smelter could pass the costs forward in the form of a price
increase. Two important considerations with respect to a price increase
are: the prices of competitors in the copper business, and the elasti-
city of demand for the end users of copper. For example, even if all
copper producers experience the same increase in costs, at some point
the end users of copper will consider changing to a substitute.
Second, the smelter could absorb the cost increase by reducing its
profit margins, thereby reducing its return on investment (ROI). If
the smelter's profit margins are reduced significantly it will cease
operation. Third, the smelter could pass the costs back to the mines
by reducing the price it is willing to pay for concentrate. An import-
ant consideration in setting the service fee a smelter charges for
custom or toll smelting is that the concentrate may be shipped else-
where, such as to Japan. Market conditions suggest that the option of
passing costs back to the mines does not seem feasible at this time,
due to the existence of excess smelting capacity.
F-19
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F.2.3.1 Japanese Tariff Mechanism. One example of foreign
government assistance to the copper industry occurs in Japan. Japanese
copper producers operate under a system that permits the payment of a
premium for concentrates, which is then recovered through a premium for
refined copper, due to a protected internal market supported by a high
tariff. Japan imposes high import duties on refined unwrought copper,
while allowing concentrates to be shipped into the country duty-free.
Duty on refined unwrought copper in 1981 was 8.2 percent of the value
of the copper, including freight and insurance, as opposed to a U.S.
customs duty of 1.3 percent of the value of copper. The import duties
allow Japanese producers to sell their refined copper in Japan at an
artificially high price and still remain competitive with foreign
producers.
Specifically, copper concentrates and ore imported into Japan are
free of duty. Refined copper imported into Japan is subjected to a
tariff of 15,000 yen/Mg.29 Using a December 1982, exchange rate of
$0.003623/yen, the tariff was $0.0543/kg. Refined copper may be
duty-free under the preferential tariff, subject to certain limitations.
As a result of the tariff situation, Japanese copper producers can
pay a premium to attract concentrates and can recover the premium
through a premium on the price of the refined copper used in Japan. If
the refined copper is returned to the customer outside of Japan, the
premium on the price of refined copper is not recovered because world
prices would prevail in this case, rather than the protected internal
Japanese producer price. As a result, the principal interest of the
Japanese copper producers is in producing copper for internal consump-
tion. Toll smelting in Japan is generally used as a means of balancing
inventories. The absence of a tariff on ore and concentrates encourages
companies to import ore into Japan. The presence of a tariff on
refined copper and the costs of holding metal in Japan discourage
companies from importing refined copper into Japan.
The Japanese tariff on refined copper, combined with the cost of
holding the metal until users have a demand for it, provides an extra
margin for Japanese copper producers. The Japanese producers can
charge what the market will bear for their copper and still remain
competitive with the importers. The loss incurred by Japanese producers
in charging toll customers low processing rates is covered by the extra
margin of profit realized by charging prices for Japanese refined
copper at competitive import levels.
Robert H. Lesemann (industry expert, formerly with Metals Week,
now with Commodities Research Unit), in an affidavit for the Federal
Trade Commission, outlined the situation in September 1979:
It is generally true that operating costs of
U.S. smelters are the same as smelters in Japan,
Korea, and Taiwan. The competitive advantage
is without doubt due to the subsidies outlined
above. Thus, while the terms of the Nippon-
F-20
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Amax deal have not been revealed, the treatment
charge is likely well below the operating cost
levels of U.S. smelters.30
F.2.3.2 Other Japanese Advantages. The tariff mechanism described
above is one example of government assistance to the Japanese copper
industry. Another example is provided by the Japanese government's
approval of a brass rod production cartel. In an effort to reduce
stocks and boost profit margins for the ailing Japanese brass rod
industry, the government officially approved the formation of a tempor-
ary cartel to cut production.31
Apart from government assistance, other reasons are cited for the
advantage of the Japanese copper industry over the U.S. copper industry.
Additional reasons include:
• A high debt-to-equity ratio—a typical Japanese smelter may
have a debt-to-equity ratio of 0.8 to 0.9.32»33»34
« Lower labor rates—Japanese hourly rates in the primary metals
industry were estimated to be about two-thirds of the U.S. rate
in 1978.35
• By-product credits—the market for by-products, sulfuric acid,
and gypsum is better in Japan than in the United States and
reduces operating costs significantly.36
F.2.4 Maximum Percent Price Increase
Insight into the economic effects of the arsenic NESHAP can be
gained by examining the maximum percentage copper price increase that
would occur if all control costs were passed forward. A complete pass
forward of control costs may not be possible in every case, and later
in the analysis this assumption is relaxed. However, the initial
assumption that a complete pass forward is possible in every case
introduces a common reference point, which then facilitates comparisons
of various control alternatives and scenarios.
The maximum percentage price increase is calculated using a
simplified approach, for ease of presentation, that divides annualized
control costs by the appropriate production and further divides that
result by the refined price of copper, with the result expressed as the
necessary percentage price increase per kilogram. The above approach
does not consider the investment tax credit, and thus is a conservative
approach that will tend to overstate the effects of the control costs.
The investment tax credit would act to reduce the capital cost of the
control equipment by ten percent. Other approaches could be used to
determine price increases. For example, a net present value (NPV)
approach could be used. A net present value approach determines the
revenue increases necessary to exactly offset the control costs, such
that the NPV of the plant remains constant. An NPV analysis can
also take into account the investment tax credit, depreciation over the
F-21
-------
applicable time period, income taxes, operating and maintenance costs,
and the time value of money. Although the NPV approach is a more
sophisticated calculation, the two approaches yield similar results.
Therefore, the first method is preferable in this particular case due
to its straightforward nature, ease of presentation, and reasonable
results.
Table F-6 shows the cost increase, and then Table F-7 shows the
maximum percentage price increase, of arsenic controls'for primary
copper smelters. The increase in the cost of production is shown for
two capacity utilization rates, 100 percent and 80 percent. The
advantage of presenting two capacity utilization rates is in the
conduct of sensitivity analysis. A rate of 100 percent is optimistic,
but is useful here as a reference point. A rate of 80 percent is more
likely and as noted in Section F.I this is the approximate industry
average utilization rate achieved in 1981. For 1982, the industry
average capacity utilization rate was substantially lower at 59
percent. However, no analysis is shown here of the impact of control
costs on the industry at a 59 percent utilization rate because regard-
less of control costs, a rate of 59 percent is damaging to the industry
even as a baseline condition. Alternatives II, III, and IV are shown
as well as the combination of III+IV. The smelters are ranked according
to the cost of Alternative III+IV (with the exception of Kennecott-
McGill). The Kennecott-McGi11 smelter is shown last because it is the
only smelter faced with costs under Alternative II. The purpose of
showing the increase in production cost is to supplement the maximum
percentage price increase that is discussed later. One advantage of
reviewing the cost increase is that it is only dependent on the capa-
city utilization rate, and is not affected by the refined price of
copper. A second advantage is that it is not affected by the choice of
the profit center. Several points should be observed from the cost
increases:
1) The amount of the cost increases are substantial for two of
the smelters in particular, Cities Service-Copperhill, and Kennecott-
McGill. The cost increases are substantial for several reasons.
First, copper is a commodity, which means that product differentiation
is not possible and thus competition is based almost exclusively on
price. The copper producers can be characterized as price-takers and
thus no individual producer controls the marketplace. Therefore, in an
industry that competes based on price, the cost of production becomes
exceptionally important. Second, copper is traded on an international
basis and thus domestic producers compete among themselves, as well as
against foreign producers that may not experience the same cost in-
creases. Finally, copper is faced with a significant threat from
substitutes: such as, aluminum and plastic.
2) Within a single alternative, the differences among smelters
are substantial. As described above, copper producers compete princi-
pally on price. As a result, the cost of production is quite important.
Therefore differences in costs among smelters of as little as several
cents per kilogram of copper are important.
F-22
-------
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3) The cost increases for Alternative II are 0 in every case with
one exception, Kennecott-McGi11. For Kennecott-McGi11 the costs for
Alternative II are large. The cost increases for Alternative III range
from a low of 0.4^/kg to a high of 9.4^/kg. The costs for Alternative
IV are lower, and range from 0 to 1.9£/kg. The costs for Alternative
III+IV range from 0.4i£/kg to 11.3jd/kg.
Table F-7 shows maximum percentage price increases. The purpose
of reporting the maximum percentage price increase figures is to add
perspective to the cost increase figures. Results are shown for two
refined copper prices (187 cents per kg. and 220 cents per kg.), and
for the same two capacity utilization rates presented earlier, 100
percent and 80 percent. The same cases are shown as were presented
earlier for the cost increases, Alternatives II, III, IV, and III+IV.
The price increase assumes the firm is an integrated producer. The
average annual price for refined copper over the past five years, from
1978 to 1982, has been approximately 187 cents per kg. The price of
copper is difficult to predict, and therefore a second price is exam-
ined. As shown previously in Section F.I, the highest average annual
current dollar price for refined copper was 225.3 cents per kilogram,
achieved in 1980. (The year 1980 was marked by an industry strike and
reduced production.) Therefore, 220£/kg is used to represent a price
that, based on the results of past years, appears optimistic. This
"optimistic" price of 220£/kg is useful as a reference point for
sensitivity analysis and also as an approximate upper limit to the
range of probable serious economic effects. At a price greater than
220^/kg the financial health of the industry would be improved
dramatically and consequently the effects of the control costs would be
reduced sharply. An alternative "pessimistic" price is not presented
because even the baseline results are highly likely to be damaging
using a pessimistic price, and thus the addition of control costs would
merely reinforce an obvious conclusion. A ready example of the effects
of a price significantly below 187^/kg was provided in 1982 when the
average price for the year was about 163^/kg and large segments of
the industry closed for sustained periods.
The analysis of the results for the maximum percentage price
increase figures is similar to the analysis discussed above for the
cost increase figures. Once again, for Alternative II only Kennecott-
McGill experiences a price increase. The price increase is high, 12.1
percent based on a 100 percent capacity utilization rate and a price of
187^/kg. For Alternative III the maximum price increases range from
0.2 to 5.0 percent. For Alternative IV the price increases are lower,
and range from 0 to 1.0 percent. For Alternative III+IV the price
increases range from 0.2 to 6.0 percent, with two smelters above 2.2
percent. The two smelters are Cities Service-Copperhill at 6.0 percent
and Kennecott-McGi11 at 2.9 percent. There is some variation in the
price increases among the smelters. The significance of the variation
in the maximum percentage price increases among the smelters is that
those smelters with higher price increases would probably be constrained
in the marketplace by those smelters with lower price increases. As a
result, at least some of the smelters could quite possibly have to
F-25
-------
absorb a part of the control costs. As mentioned above, two additional
constraining influences are foreign competition and substitutes.
F.2.5 Maximum Percent Profit Reduction
Apart from the calculation of maximum percentage price increase,
additional insight into the economic effects of the arsenic NESHAP can
be gained by making the opposite assumption from maximum percent price
increase, that is, zero percent price increase, or complete control
cost absorption. The assumption of complete control cost absorption
provides a measure of the reduction in profits if the control costs are
absorbed completely.
Assuming control costs are absorbed, the critical element in an
analysis of profit reduction is the profit margin. The larger a firm's
profit margin, the greater is the firm's ability to absorb control
costs and earn an acceptable rate of return on investment (ROI), and
thus continue operation. The profit margin is simply the difference
between price and production cost. As mentioned in an earlier section,
the central issue becomes the choice of an appropriate profit center
and its corresponding price and cost. The processing of virgin ore
into refined copper involves four distinct steps: mining, milling,
smelting, and refining. Although the four steps are often joined to
form an integrated business unit, they are not inextricably bound
together in an economic sense. For example, it is not uncommon for
mines to have their concentrate toll smelted and refined. The diffi-
culty that this variability presents in terms of an assessment of the
effects of the arsenic standard is in the method of assigning the
costs.
This report presents an analysis of profit impacts using two
methods. The first method assumes copper producers are fully inte-
grated and all have the same costs and thus earn a uniform profit
margin. The objective of this method is to permit a ready, and uni-
form, examination of profit impacts. With the first method as a
foundation, the second method introduces more smelter specific vari-
ables into the analysis in an effort to focus more sharply on the
complex organizational structure of the industry.
F.2.5.1 Method One. As mentioned above, the critical element in
an examination of profit reduction is the profit margin. Therefore an
examination of profit margins for members of the industry is presented
below. Table F-8 shows the revenues and operating profit (before tax)
for each of the seven copper producers that own smelters, for the
period from 1977 to 1982. Table F-8 also shows the percentage profit
margin, which is operating profit divided by revenues. The revenue and
operating profit figures are for the business segment within the
company that includes copper. The use of business segment information
provides a closer representation of the results for copper than would
the use of the consolidated results for the company. The reason for
this is that for several of the firms copper represents a relatively
small share of the total company results. Although the business
F-26
-------
Table F-8. BUSINESS SEGMENT RETURN ON SALES FOR COPPER COMPANIES*
($ 103)
Revenues
Year
1977
1978
1979
1980
1981
1982
Operating 1977
Profits 1978
1979
Profit/
Revenues
(percent)
I
i
1980
1981
1982
1977
1978
1979
1980
1981
1982
Average
ASARCO
733,293
849,002
1,339,917
1,440,220
1,153,022
1,074,014
65,919
112,474
225,763
145,286
68,364
35,783
9.0
13.2
16.8
10.1
5.9
3.3
9.7
Cities
Servi ce
184,000
241,500
276,300
224,100
NA
NA
(38,600)
(23,900)
25,400
16,300
NA
NA
(21.0)
(9.9)
9.2
7.3
NA
NA
(3.6)
Copper
Rangeb
NA
64,600
89,300
83,900
72,300
36,400
NA
(6,600)
10,000
1,800
(20,600)
(42,000)
NA
(10.2)
11.2
2.1
(28.5)
(115.4)
(28.2)
Inspiration0
95,676
101,251
136,849
178,004
NA
NA
(9,994)
(6,235)
9,889
(6,563)
NA
NA
(10.4)
(6.2)
7.2
(3.7)
NA
NA
(3.3)
Kennecott
NA
683,000
1,091,400
987,400
539,000
596,000
NA
(100)
164,000
131,400
(99,000)
(187,000)
NA
0
15.0
13.3
(18.4)
(31.4)
(4.3)
Magmad
NA
274,137
381,512
287,581
328,842
221,001
NA
13,601
67,252
11,522
(15,658)
(30,790)
NA
5.0
17.6
4.0
(4.8)
(13.9)
1.6'
Phelps
Dodge
453,184
446,970
618,188
714,591
706,404
426,509
52,831
63,738
159,428
95,439
27,618
(78,104)
11.7
14.3
25.8
13.4
3.9
(18.3)
8.59
Business segments contain other products in addition to copper.
bThe figures are for The Louisiana Land and Exploration Company which
acquired Copper Range in May 1977.
cAcquired and privately-owned after 1980 by Anglo American Corp. of
South Africa through a complex arrangement that includes Minerals &
Resources Corp. (Minorco), Hudson Bay Mining & Smelting Co.,, and Plateau
Holdings Inc.
dProfit is net income after tax in this case.
eBefore interest and tax. *
fWould yield 2.3 percent if adjusted to before tax with an effective
tax rate of 30 percent.
9lmputed profit on intersegment sales for 1977 to 1982 would yield
average return of about 9.8 percent.
F-27
-------
segment Information is a better representation of the results for
copper than the total company results, the business segments contain
other products in addition to copper. Therefore conclusions must be
drawn accordingly. The table shows that there is considerable variation
in results, both within a company from one year to the next, as well as
from one company to the next. The averages range from a loss of 28.2
percent to a high of 9.7 percent. Rather than a profit, four of the
seven companies show an average loss.
Table F-9 shows the maximum percentage reduction in the profit
margin for each of the 14 smelters. This table assumes each smelter is
viewed as part of a fully integrated operation. Two profit levels are
shown and two capacity utilization rates (100 percent and 80 percent).
The first profit level is based on a refined copper price of 187^/kg
and a 10 percent profit margin, which yields a profit of 18.7jd/kg.
The second profit level is based on an increased price of refined
copper to a level of 220£/kg. The second profit margin is based on
the original 18.7£/kg. but adds the increase in price as extra profit
while process costs are held constant. The second profit margin is
51.7ji/kg. Three considerations suggest the use of the second profit
margin. The first consideration is the desirability of presenting
sensitivity analysis in general. The second consideration is that
a profit margin of 51.7£/kg. based on a price of 220^/kg. is a
margin of 23.5 percent, which though clearly high, has been achieved
within recent years by a member of the industry. Finally, because the
margin is high, it in effect can be viewed as an upper limit, and thus
any smelter that has a
substantial profit reduction in spite of such a favorable profit margin
is in a very vulnerable position at a lower, more likely, profit
margin.
The same cases discussed earlier are still applicable, the results
on Table F-9 are for Alternatives II, III, IV, and III+IV. At the
first profit margin (18.7£/kg.), with a 100 percent capacity utiliza-
tion rate for Alternative III + IV, eight smelters have a maximum
profit reduction of 15 percent or less, and three smelters have a
reduction of 15 to 20 percent. The results show a maximum profit
reduction of greater than 20 percent for three of the 14 smelters
(Kennecott-Hurley, Cities Service-Copperhill, and Kennecott-McGi11) at
the 100 percent capacity utilization rate for Alternative III+IV. At
the more likely level of an 80 percent capacity utilization rate, six
smelters have a reduction of 15 percent or less, four smelters have a
reduction of between 15 and 20 percent, and four smelters exceed 20
percent (Kennecott-Hayden, Kennecott-Hurley, Cities Service-Copperhill,
and Kennecott-McGi11). A profit reduction in excess of 20 percent is a
substantial reduction, but when viewed in isolation is not a definite
indicator of closure. However, a profit reduction in excess of 20
percent, when viewed together with the generally depressed economic
condition of the copper industry, is a cause for concern about the
ability of the four smelters in this category to continue in operation.
Also, Table F-9 shows that of the four smelters between 15 and 20
percent, three smelters have profit reductions in excess of 19 percent,
F-28
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F-29
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which though less than 20 percent, is not appreciably different from 20
percent. For two of the above smelters (Cities Service-Copperhill and
Kennecott-McGill) the profit reduction is greater than 30 percent at
the 80 percent capacity utilization rate, and greater than 50 percent
for one smelter (Cities Service-Copperhill). Profit reductions of
greater than 30 percent would seriously call into question the continued
viability of these two smelters.
At the second, higher, profit margin (51.74/kg.) the profit
reductions are lessened substantially. Only two smelters have profit
reductions of greater than 10 percent. However, the Cities Service-
Copperhill smelter continues to experience profit reductions of greater
than 20 percent.
F.2.5.2 Method Two. Method two uses method one as a starting
point and then supplements it with additional information, some of
which is qualitative. Table F-10 provides an added means to identify
those smelters that are most likely to face the greatest impact.
Method one assumed that each smelter was part of a fully integrated
operation. However, not all smelters are integrated to the same
degree, and therefore additional variables are introduced in method two
in order to examine the degree of integration for each smelter. The
significance of whether a smelter is analyzed as part of an integrated
business unit or analyzed on a "stand alone" basis is that the financial
effect of the control costs is greater for a smelter that must "stand
alone", versus a smelter that is part of an integrated operation.
Additionally, a smelter plus a refinery could be considered together as
a single business unit, depending on the individual circumstances. For
example, the production costs associated solely with smelting (excluding
mining, milling, and refining) will vary depending on the individual
smelter but a representative figure is approximately 42£/kg. This
represents about 25 percent of total production costs from mining
through refining. Therefore if the total integrated profit presented
earlier of 18.7/4/kg is apportioned to each stage of production in
proportion to the costs associated with each stage of production the
result is th-at only about 25 percent of the total profit of 18.7/i/kg
is assigned to the smelter. The net effect is that if the control costs
are charged against only the smelter's share of the total profit the
control costs increase in importance.
Table F-10 starts by showing the smelters ranked according to the
profit reduction described earlier for Alternative III+IV at the 80
percent capacity utilization rate . The size of the profit reduction
and the rank provides one indication of the potential effect of con-
trols. A caveat that should be mentioned concerning this indicator is
that it does not take into consideration baseline costs. The profit
reductions expressed on the basis of a fully integrated operation were
discussed previously in method one and will not be repeated here.
However, for perspective, if the smelters are viewed on a stand alone
basis, rather than as part of a fully integrated operation, the size of
the profit reductions could at least double.
F-30
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A second indicator that is presented to provide additional insight
into a firm's possible reaction to control costs is a review of any
major capital commitments to the smelter that a firm has made recently.
Most of the firms with the lower control cost increases have also
recently made major capital commitments to their smelters which in turn
suggests a stronger commitment to the continued operation of a smelter
than a firm that has postponed capital expenditures for a smelter.
A third indicator is provided by a review of whether or not a
smelter has a major integrated mine that supplies much or all of its
concentrates. The presence of a major mine near a smelter does not
guarantee that a firm will consider the mine and smelter as a single
business unit. For example, both the Phelps Dodge-Ajo smelter and the
Kennecott-Hayden smelter have been closed in spite of the fact that the
mines located near these two smelters have been open. However, in
general a smelter that is associated with a major mine is likely to be
considered as an integrated operation.
A fourth indicator is provided by a review of whether or not a
smelter is closely associated with a refinery. Similar to the situa-
tion with a mine, the existence of a refinery closely associated with a
smelter does not guarantee that a firm will consider the smelter and
refinery as a single business unit. However, in general this is likely
to be the case because if a closure occurs at a smelter that provides
all, or a substantial percentage, of the copper supply for a refinery
this will have serious consequences for the refinery.
A fifth indicator is provided by the estimates of others who have
analyzed the smelters. The estimates are from four sources as noted in
the references. The estimates are based on the overall economic and
environmental outlook faced by the smelters, and are not estimates
related specifically to arsenic control costs.
A sixth and final indicator is provided by a review of the recent
operating status of the smelters. Those smelters that have recently
been closed for sustained periods of time are obviously in a vulnerable
financial condition even in the absence of arsenic control costs.
Therefore the weak baseline financial condition of those smelters
reduces the affordability of arsenic control costs. Two smelters are
involved in major modernization programs, ASARCO-Hayden and Kennecott-
Hurley.
F.2.6 Capital Availability
The principal determinant of the financial viability of a smelter
is profitability. However, the amount of capital needed to purchase
control equipment is one of the components that enters into an evalua-
tion of profitability. Most firms prefer to finance pollution control
equipment with debt, both because debt is less expensive than equity in
general, and additionally because debt incurred to purchase pollution
control equipment is often tax exempt. Assuming control equipment is
financed with debt, as the capital cost of the control equipment
F-32
-------
increases, the level of debt increases. An increased debt level means
the fixed costs required to service the debt increase and therefore the
level of risk increases. As a result, a discussion of capital avail-
ability will serve to supplement an assessment of profitability.
Table F-ll shows the pollution control capital expenditures that
will be necessary for each firm and for each smelter. The component"
parts of the capital expenditures were explained in detail in an
earlier section and will not be repeated here. The baseline capital
expenditures are presented, as well as the capital expenditures for
Alternatives II, III, IV, and III+IV. Three firms own more than one
smelter and in those three cases the total capital costs are shown,
although the firms can make capital budgeting decisions on an individual
smelter basis. The capital costs for the smelters are not trivial
sums. However, all seven companies are major corporations with a large
capital base. Additionally, five of the seven companies are owned
wholly, or to a substantial degree, by significantly larger parent
corporations and thus are quite likely to have access to the necessary
capital. The remaining two companies that are not owned by some other
corporation are ASARCO and Phelps Dodge.
For these two companies Table F-ll shows the percent increase in
long-term debt if controls are added. For the other companies the
increases are below one percent and are not shown. The pre-control
debt level is based on a 3-year average (1981 to 1979) debt level for
each company. Controls are assumed to be financed totally with debt.
The baseline percentage increase in debt is 24 percent for ASARCO and
16 percent for Phelps Dodge. These increases are considerable. For
Alternatives II, III, IV, and III+IV the incremental increases are
In ASARCO's case the increases are 0, 2, 1, and 3
, In the case of Phelps Dodge the increases are 0,
6, 1, and 7 percent, respectively. The capital costs associated solely
with Alternatives II, III, IV, and III+IV do not, in isolation, suggest
a major capital availability problem. However, the baseline increase,
taken together with the alternatives, is a considerable increase and
may be a problem for these two companies.
An additional indicator of capital availability is provided by the
debt rating assigned to a company by one of the major national rating
services. Although the rating is assigned specifically for a company's
debt, the factors that enter into a debt rating include the overall
financial condition of a company. Therefore a debt rating is also an
indirect measure of the overall financial condition of a company. In
1982, as well as 1981 and 1980, ASARCO1s debt was rated as A3 by
Moody's.40 This is an investment grade rating, but it is the lowest
A rating. In 1982, the debt rating by Moody's for Phelps Dodge was
lowered to Baa2 from its previous rating in 1980 and 1981 of A.
Although Baa2 is still a relatively strong rating, the fact that
it was lowered from 1981 to 1982 is a negative factor and suggests that
substantial increases in the amount of debt held by the company may
present some difficulties.
generally moderate.
percent respectively,
F-33
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Table F-ll. CAPITAL COSTS OF ARSENIC CONTROLS
FOR PRIMARY COPPER SMELTERS
($103)
Alternative
Company
ASARCO
Cities Service
Copper Range
Inspiration
Kennecott
Newmont
Phelps Dodge
Smelter
El Paso
Hayden
Debt Increase3'
Copperhill
White Pine
Mi ami
Garfield
Hayden
Hurley
McGill
Magma
Ajo
Douglas
Hidalgo
Morenci
Debt Increase3
Baseline
46
75,606
75,652
b 24%
0
0
0
0
0
54,044
0
54,044
0
0
0
0
95,294
95,294
16%
II
0
Q_
0%
0
0
0
0
0
0
10,530
10,530
0
0
0
0
0
0
0%
III
1,894
3,660
5,554
2%
4,434
4,434
9,825
8,800
8,000
8,760
9,000
34,560
13,050
6,731
9,825
6,731
12,971
36,258
6%
IV
370
0
"370
1%
893
893
922
7,828
894
952
893
10,567
1,786
894
1,787
894
1,786
5,361
1%
III+IV
2,264
3,660
"5792T
3%
5,327
5,327
10,747
16,628
8,894
9,712
9,893
45,127
14,836
7,625
11,612
7,625
14,747
41,619
7%
aPercent increase in average long-term debt level for the 3 years
(1981 to 1979) if controls are added as debt.
Increases of less than one percent for a firm are not shown.
F-34
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F.3 SOCIO-ECONOMIC IMPACT ASSESSMENT
F.3.1 Executive Order 12291
The purpose of Section F.3.1 is to address those tests of macro-
economic impact as presented in Executive Order 12291, and, more
generally, to assess any other significant macroeconomic impacts that
may result from the NESHAP. Executive Order 12291 stipulates as "major
rules" those that are projected to have any of the following impacts:
9 An annual effect on the economy of $100 million or more.
• A major increase in costs or prices for consumers; individual
industries; Federal, State, or local government agencies;
or geographic regions.
• Significant adverse effects on competition, employment,
investment, productivity, innovation, or on the ability of
U.S.-based enterprises to compete with foreign-based enter-
prises in domestic or export markets.
F.3.1.1 Annualized Control Costs. The annualized control costs
for each of the four alternatives is well below the $100 million which
is the figure used to identify a major rule. The annualized control
costs for Alternatives II, III, IV, and III+IV are $4.1 million, $29.1
million, $6.0 million, and $35.1 million, respectively.
F.3.1.2 Regional Effects. Employment and Competition. Most of
the 14 primary copper smelters are located in the Southwestern United
States, and in particular, seven smelters are located in Arizona. As a
result, economic impacts would be concentrated in that geographical
area.
A copper smelter typically employs about 500 people. A smelter
has an indirect as well as a direct effect on employment in its local
community. The indirect effect is twofold; one part of it results from
the local business purchases that a smelter makes, and the other part
results from the local consumer purchases by smelter employees and
their families. These expenditures generate additional employment at
local firms. An estimate of the employment multiplier for the smelting
industry is approximately 1.6.
The domestic copper producers compete among themselves, as well as
against foreign copper producers and substitutes such as aluminum and
plastics. Any substantial increase in costs will put pressure on the
competitive position of some domestic smelters with respect to other
domestic smelters, and also with respect to foreign copper producers
and substitutes.
F.3.2 Regulatory Flexibility
The Regulatory Flexibility Act of 1980 (RFA) requires that differ-
ential impacts of Federal regulations upon small business be identified
F-35
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ential impacts of Federal regulations upon small business be identified
and analyzed. The RFA stipulates that an analysis is required if a
substantial number of small businesses will experience significant
impacts. Both measures must be met, substantial numbers of small
businesses and significant impacts, to require an analysis. If either
measure is not met then no analysis is required. The EPA definition of
a substantial number of small businesses in an industry is 20 percent.
The EPA definition of significant impact involves three tests, as
follows: one, prices for small entities rise 5 percent
assuming costs are passed forward to consumers; or two,
investment costs for pollution control are greater than
of total capital spending; or three, costs as a percent
small entities are 10
for large entities.
or more,
annualized
20 percent
of sales for
percent greater than costs as a percent of sales
The Small Business Administration (SBA) definition of a small
business for Standard Industrial Classification (SIC) Code 3331,
Primary smelting and refining of copper is 1,000 employees. Table F-12
shows recent employment levels for each of the seven companies that own
primary copper smelters. All seven have more than 1,000 employees.
Therefore, none of the seven companies meets the SBA definition of a
small business and thus no regulatory flexibility analysis is required.
F-36
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Table F-12. NUMBER OF EMPLOYEES AT COMPANIES
THAT OWN PRIMARY COPPER SMELTERS
Company
Employees
Source3
ASARCO, Inc.
Cities Service Co.
Copper Range Co.b
Inspiration Consolidated
Copper Co.
Kennecott Corp.c
Newmont Mining Corp.
Phelps Dodge Corp.
9,800
18,900
3,049
2,180
35,000
9,900
9,678
1982 SEC 10-K p. A3
1980 SEC 10-K p. 6
1980 SEC 10-K p. 22
1980 SEC 10-K p. 2
1980 SEC 10-K p. 10
1982 SEC 10-K p. 5
1982 SEC 10-K p. 1
aSEC 10-K is Securities and Exchange Commission, Form 10-K.
bCopper Range Co. is a wholly-owned subsidiary of the Louisiana Land and
Exploration Company. Figures are for Louisiana Land and Exploration.
cPrior to merger with Sohio on March 12, 1981.
F-37
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F.4 References
1. Review of New Source Performance Standards for Primary Copper
Smelters — Background Information Document, Preliminary Draft.
U.S. Environmental Protection Agency. Research Triangle Park,
North Carolina. Publication No. EPA-February 1983. p. 3-2.
2. ASARCO, Inc., Form 10-K. December 31, 1980. p. A2.
3. Cities Service Co., Annual Report 1980. p. 41.
4. The Louisiana Land Exploration Co., Form 10-K. December 31,
1980. p. 16.
5. Inspiration Consolidated Copper Company, Annual Report 1980. p. 2.
6. Kennecott Corp., Form 10-K. December 31, 1980. p. 4.
7. Newmont Mining Corp., Form 10-K. December 31, 1980. p. 3.
8. Phelps Dodge Corp., Form 10-K. December 31, 1980. p. 2, 4.
9. Butterman, W.C. U.S. Bureau of Mines. Preprint from the 1981
Bureau of Mines Minerals Yearbook. Copper, p. 3.
10. Butterman, W.C. U.S. Bureau of Mines. Mineral Industry Surveys.
Copper Production in December 1982. p. 2.
11. Schroeder, H. J. and James A. Jolly. U.S. Bureau of Mines.
Preprint from Bulletin 671. Copper - A Chapter from Mineral
Facts and Problems, 1980 Edition, p. 14-16.
12. Annual Data 1982. Copper Supply and Consumption. Copper
Development Association Inc. New York, New York. p. 6, 14.
13. Reference 11, p. 5.
14. Reference 9, p. 1.
15. Reference 9, p. 5.
16. Arthur D. Little, Inc. Economic Impact of Environmental Regula-
tions on the United States Copper Industry. U.S. EPA. January
1978. p. V-8.
17. Reference 9, p. 24-29.
18. Reference 12, p. 14.
19. Reference 11, p. 14.
F-38
-------
20. Reference 12, p. 18.
21. Copper's Hope: Electric Vehicles. Copper Studies. Commodities
Research Unit, Ltd. New York. March 30, 1979, p. 5.
22. Copper in Military Uses. Copper Studies. Commodities Research
Unit, Ltd. New York, February 15, 1980. p. 1.
23. Butterman, W.C. U.S. Bureau of Mines. Mineral Industry Surveys.
Copper in 1982 - Annual, Preliminary, p. 2.
24. Butterman, W.C. U.S. Bureau of Mines. Preprint from the 1980
Bureau of Mines Minerals Yearbook. Copper, p. 1.
25. Schroeder, H. J., and G. J. Coakley. U.S. Bureau of Mines
Preprint from the 1975 Minerals Yearbook. Copper, p. 2.
26. The Capital Cost Picture. Copper Studies. Commodities Research
Unit, Ltd. New York. August 18, 1975. p. 1.
27. Rosenkranz, R.D., R.L. Davidoff, and J.F. Lemons, Jr., Copper
Availability-Domestic: A Minerals Availability System Appraisal.
U.S. Bureau of Mines. 1979. p. 13.
28. Sousa, Louis J. U.S. Bureau of Mines. The U.S. Copper Industry:
Problems, Issues, and Outlook. Washington, D.C. October, 1981.
p. 67.
29. Copper Imports on Preferential Tariff. Japan Metal Journal
(Tokyo). December 8, 1980. p. 3.
30. Affidavit of Robert J. Lesemann, Commodities Research Unit/CRI
and former editor-in-chief of Metals Week, to the Federal Trade
Commission. September 27, 1979. FTC Docket Number 9089.
31. Brass Rod Production Cartel Starts. Japan Metal Journal (Tokyo).
July 6, 1981. p. 1.
32. Smelter Pollution Abatement: How the Japanese Do It. Engineer-
ing and Mining Journal. May 1981. p. 72.
33. Rieber, Michael. Smelter Emission Controls: The Impact on
Mining and The Market For Acid. University of Arizona, Tucson,
Arizona. March, 1982. p. 5-10.
34. Custom Copper Concentrates. Engineering and Mining Journal.
May 1982. p. 73.
35. Everest Consulting Associates, Inc., and CRU Consultants, Inc.
The International Competitiveness of the U.S. Nonferrous Smelt-
ing Industry and the Clean Air Act. Princeton, NJ. April 1982.
p. 9-9.
F-39
-------
36. Reference 32.
37. Reference 33, p. 1-11.
38. Everest Consulting Associates, Inc. The International Competi-
tiveness of the U.S. Non-Ferrous Smelting Industry and the Clean
Air Act. Princeton, N.J. April 1982. p. 3-17.
39. Phelps Dodge Corp. 1981 Annual Report, p. 8.
40. Moody's Industrial Manual 1982 Vol. I, p. 58, Vol. II, p. 4236.
F-40
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APPENDIX G
DEVELOPMENT OF MAIN STACK AND LOW-LEVEL
ARSENIC EMISSION RATES FOR THE ARSENIC PLANT
AT ASARCO-TACOMA
6-1
-------
DEVELOPMENT OF MAIN STACK AND LOW -LEVEL ARSENIC EMISSION RATES
FOR THE ARSENIC PLANT AT ASARCO-TACOMA
G.I INTRODUCTION
Estimates of inorganic arsenic emissions from the ASARCO-Tacoma
smelter were presented in the high-arsenic proposal BID, EPA-450/3-83-
009a (III-B-1). Since the standard was proposed, EPA has revised these
emission estimates after making several visits to the smelter, and
through an extensive test program. On June 21 through 23, 1983, EPA
conducted a comprehensive inspection of the smelter to identify poten-
tial sources of low-level emissions and to document the particular
control measures and practices already being applied at the smelter
On September 12 through 29, 1983, EPA conducted source testing on the
No. 1 Cottrell and the arsenic plant main fabric filter (referred to as
the arsenic plant baghouse"). Results from these tests are presented
in Appendix H.
Arsenic emission rates at ASARCO-Tacoma were estimated for two
categories of sources: (1) main stack emissions, consisting of outlet
gas streams from six control devices used at the smelter that are
vented to the smelter's 563-ft main stack; and (2) low-level emissions
or those from all other arsenic emission points at the smelter. Main
stack emission rates were derived generally from an arsenic material
balance for the smelter based on actual smelter operations during 1982
In the case of the arsenic plant, contributions to main stack emissions
were determined from the September 1983, test results referred to above.
Low-level arsenic emissions were estimated for two groups of
emission controls. The first group of controls consists of those in
place at the ASARCO-Tacoma smelter as of December 31, 1982. The second
group includes the additional emission controls that have been applied
since that time or are planned under ASARCO-initiated projects, ASARCO
actions to comply with the Tripartite Agreement (IV-D-447), and ASARCO
actions to comply with the final arsenic NESHAP standard.
In light of ASARCO 's recent closure of its copper smelting opera-
tions at Tacoma, and its continuation of the operation of the arsenic
plant (arsenic trioxide and metallic arsenic production facilities) on
the same site, EPA is presenting only its estimates for arsenic emissions
from the arsenic plant. Therefore, the following sections discuss main
stack and low-level arsenic emissions only from the arsenic plant.
G.2 ARSENIC PLANT EMISSION RATES
G.2.1 Main Stack Emissions
n^H. process abases from the arsenic trioxide and metallic arsenic
production operations are vented to a baghouse before being ducted to
tne main stack. It is not known presently whether the main stack at
the Tacoma smelter will be retained, but the contribution of arsenic
!;ilsl!n!h -tte*aT"1c Plant Wl11 st111 be vented from this baghouse,
even if the main stack is removed from the site
G-2
-------
In September 1983, EPA conducted source tests to determine arsenic
emissions at the inlet and outlet of the baghouse controlling emissions
from the arsenic plant. Test results are summarized in Appendix H
The results for Run Nos. 1 through 4 show that the average arsenic
emission level from this baghouse was 0.33 pound per hour (0.15 kg/h).
Test results for Run Nos. 5 through 7 were not utilized in establishing
average emissions because of uncertainties about the flow conditions
during these test runs. After the copper smelting operation has been
shut down, emissions from the arsenic plant baghouse are likely to
change, but neither the magnitude nor direction of any future change
can be predicted at the present time.
G.2.2 Low-Level Emissions
The low-level emission factors for the arsenic plant are based on
a detailed arsenic material balance that ASARCO prepared specifically
for the arsenic trioxide and metallic arsenic production facilities at
ASARCO-Tacoma (II-D-42). These low-level arsenic emissions are considered
to consist of contributions from seven separate operations performed in
connection with running the arsenic plant. Low-level emission rates
based on controls in place on December 31, 1982, and on additional
controls since that date, are presented in Table G-l. The methodology
used to derive these emission estimates is described in the paragraphs
below. It should be recognized that these estimates reflect the present
configuration at the Tacoma smelter (both copper smelter and arsenic
plant in operation), and might be changed after the copper smeltinq
operation is shut down. «-r 3
G.2.2.1 Raw Material Handling. The arsenic plant material
balance shows that a total of 2,682 Ib/h of arsenic is handled during
the various flue dust, white dust, Cottrell dust, and roaster baghouse
dust transfer operations performed in the arsenic plant. The assumption
is that uncontrolled arsenic emissions from the handling of these
materials are 0.1 percent of the arsenic contained in the materials.
The transfer operations are performed inside the arsenic plant building
using a combination of covered belt conveyors, pneumatic conveyor
systems, and enclosed chutes. An overall control efficiency of 90
percent is assumed for these controls. Multiplying 2,682 Ib/h by
0.1 percent, an uncontrolled emission rate of 2.68 Ib/h was calculated
Applying the control efficiency value of 90 percent, a low-level arsenic
emission rate of 0.27 Ib/h was calculated for arsenic plant raw material
handling.
G.2.2.2 Godfrey Roasters. In 1983, a construction program was
completed at the ASARCO-Tacoma smelter to replace the arch on the Mo 5
Godfrey roaster with a poured solid-refractory arch. Solid-refractory
arches previously had been installed on the No. 4 and No. 6 Godfrey
roasters. (The No. 1, No. 2, and No. 3 Godfrey roasters have been
removed from the arsenic plant.) Also included in the ASARCO construc-
tion program was the installation of a water-cooled screw conveyor on
each Godfrey roaster for transfer of the hot calcines from the roaster
TO represent baseline Godfrey roaster operations for the estimation of
arsenic emissions, it is assumed that the solid-refractory arch was not
in place on the No. 5 Godfrey roaster.
G-3
-------
.Table 6-1. LOW-LEVEL ARSENIC EMISSION RATES FOR
THE ARSENIC PLANT AT ASARCO-TACOMA
Low-Level Emission Source
Average Arsenic
Emission Rate (Ib/h)
Controls as of December 31, 1982
1. Raw material handling
2. Godfrey roasters
3. Calcine handling
4. Kitchen pulling
5. Arsenic trioxide handling
6. Metallic arsenic production
7. Baghouse dust transfer
Hith Additional Controls
Total
1,
2,
3,
4.
5.
6.
Raw material handling
Godfrey roasters
Calcine handling
Kitchen pulling
Arsenic trioxide handling
Metallic arsenic production
7. Baghouse dust transfer
0.27
4.04
Total
1.63
6-4
-------
To estimate baseline Godfrey roaster emissions, it is assumed that
0.1 percent of the arsenic vaporized during the roasting process is
discharged into the arsenic plant building as a result of the transfer
of hot calcines from the roaster hearth and the leakage of process
offgases from openings in the roaster roof. The arsenic plant material
balance shows that a total of 2,178 Ib/h of arsenic is vaporized in
the Godfrey roasters. Multiplying 2,178 Ib/h .by 0.1 percent, the low-
level arsenic emission rate calculated for the Godfrey roasters is
2.18 Ib/h.
G-2-2-3 Calcine Handling. In late 1983, ASARCO began start-up
of a pneumatic conveyor system to transfer the Godfrey roaster calcines
directly to the Herreshoff roasters. This system replaced the belt
conveyor system previously used to handle the calcines. To represent
baseline calcine handling operations for the estimation of arsenic
emissions, it is assumed that the belt conveyor system is used for all
calcine handling. The belt conveyor system consists of a covered belt
conveyor to an open, inclined belt conveyor that discharges the calcines
into a railcar. No ventilation is applied along the belt conveyor
system. Therefore, it is assumed that arsenic emissions from the belt
conveyor system are uncontrolled.
The arsenic plant material balance shows that a total of 504 Ib/h
of arsenic is handled inside the arsenic plant during the transfer of
the Godfrey roaster calcine to the railcar loading station at the south
end of the building. The assumption is that uncontrolled arsenic
emissions from calcine handling are 0.1 percent of the arsenic contained
in the calcines loaded into the rail cars. Multiplying 504 Ib/h by
0,1 percent, an uncontrolled emission rate of 0.50 Ib/h was calculated.
G-2-2'4 Kitchen Pulling. Arsenic emissions from kitchen pulling
were calculated using an emission factor developed by PSAPCA (pages 2-40
and 2-41 of the high-arsenic proposal BID), which is based on the
estimate that 0.5 percent of the arsenic processed through the arsenic
plant is potentially lost during the kitchen pulling operations, and on
an estimate of the capture efficiency achieved by the local ventilation
system currently applied. The kitchen pulling operation is ventilated
by movable hoods that vent to a baghouse. Based on observations of
kitchen pulling operations during the EPA June 1983, smelter inspection,
1*.!s. A s Jud9me|it: that the hoods are approximately 90 to 95 percent
efficient in capturing dust emissions generated during kitchen pulling
Applying the 0.5 percent emission factor for potential emissions to the
arsenic rate of 1,523 Ib/h reported in the material balance, and
assuming that 10 percent of the potential emissions escape capture, the
low-level arsenic emission rate due to kitchen pulling is calculated
to be 0.76 Ib/h.
G.2.2.5 Arsenic Tripxide Handling. The arsenic plant material
balance shows that a total of 1,523 Ib/h of arsenic is handled during
the transfer, barreling, and railcar loading of arsenic trioxide. It
is assumed that uncontrolled arsenic emissions from arsenic trioxide
handling are 0.1 percent of the total arsenic trioxide shipped from the
plant. The arsenic trioxide is transferred inside the arsenic plant
building using a combination of enclosed belt and screw conveyors and
6-5
-------
pneumatic conveying systems. An overall control efficiency of 90 percent
is assumed for these controls. Multiplying 1,523 Ib/h by 0.1 percent
an uncontrolled emission rate of 1.52 Ib/h was calculated. Applying
the control efficiency value of 90 percent, a low-level arsenic emis-
sion rate of 0.15 Ib/h was calculated for arsenic trioxide handling.
. . G-2-2.6 Metallic Arsenic Production. The arsenic plant material
balance shows tnat the average nourly arsenic input to the metallic
arsenic plant is 111 Ib/h. Input arsenic is in the form of purchased
refined arsenic trioxide that is manually loaded from barrels into the
hoppers of the two metallic arsenic furnaces. The final product is
manually removed from the condensers downstream of the furnaces and
loaded into barrels for shipment. The material balance shows that the
n«n?u/uave!ra9e hourly arsentc output of the metallic arsenic plant is
99 Ib/h. The EPA based its estimate of low-level arsenic emissions
from the metallic arsenic plant on an approximate annual average hourly
arsenic throughput of 100 Ib/h. Using the same material handling
emission and control factors used for other sources in the arsenic
' from the metaiiic arsenic piant
h*i;,n k °USt Transfer- ™e arsenic plant material
balance shows that the annual average arsenic content of the off gases
^IK/! ar!enic,k\tcfiens and metallic arsenic production facilities is
Si,,! ?; J°aCa !a!u !h! ar\senic Plant baghouse dust transfer emission
value, it is assumed that total uncontrolled arsenic emissions are
O.l percent of the arsenic contained in the collected dust. An overall
control efficiency of 90 percent is assumed for the baghouse airslide.
Based on source test data, an average of 0.33 Ib/h is vented from the
baghouse. Therefore, a value of 831.7 Ib/h was calculated for the
HnrnnL0!!^116?*6? ^^ Mult1PW"9 83L7 Ib/h by 0.1 percent, an
uncontrolled emission rate of 0.83 Ib/h was calculated. Applying the
£! I n ni°!K/uy value°f 90 Percent, a low-level arsenic emission
rate of 0.08 Ib/h was calculated for arsenic plant baghouse dust transfer
6-6
-------
APPENDIX H
SUMMARY OF TEST RESULTS FOR THE ARSENIC PLANT
BAGHOUSE AT ASARCO-TACOMA
H-l
-------
SUMMARY OF TEST RESULTS FOR THE ARSENIC PLANT
BAGHOUSE AT ASARCO-TACOMA
H.I INTRODUCTION
From September 12 to 29, 1983, EPA performed a series of emission
tests at the ASARCO-Tacoma smelter (IV-A-6). The primary objectives of
the test program were:
1. To obtain representative arsenic and participate emission
data at the outlet of the No. 1 Cottrell controlling emissions
from the No. 2 reverberatory smelting furnace.
2. To obtain representative arsenic emission data at the inlet and
outlet of the fabric filter controlling emissions from the
arsenic plant. Testing was to be conducted so as to provide
arsenic removal efficiency data for this source.
3. To obtain data for evaluation of the accuracy of arsenic
results obtained with the ASARCO continuous sampler compared
with those obtained with the EPA testing and analytical
procedures for inorganic arsenic.
4. To approximate the arsenic removal efficiency of the No. 1
Cottrel1.
Sample and analytical procedures.were performed by personnel from an
EPA contractor (PEDCo Environmental, Inc.), under the supervision of
personnel from the EPA Emissions Measurement Branch. Personnel from
another EPA Contractor (Pacific Environmental Services, Inc.), under
the supervision of personnel from the EPA Industrial Studies Branch,
monitored operating conditions of the processes and control devices
during the testing.
Due to ASARCO's decision to close the Tacoma copper smelting
facilities and continue to operate only the arsenic plant at Tacoma
(IY-D-802), only the test results for the arsenic plant baghouse are
presented and discussed in this appendix.
H.2 TEST PROTOCOL
Table H-l presents a summary of the number and type of tests
performed in the test program. The actual sequence of test events was
different from the sequence shown because of the arsenic plant production
schedule during the test period.
Arsenic concentrations and mass emission rates were determined at
the inlet and outlet of a fabric filter (baghouse) controlling emissions
from the arsenic trioxide (AsgOs) and metallic arsenic processes. All
H-2
-------
Table H-l. SUMMARY OF ARSENIC PLANT BAGHOUSE TEST ACTIVITY
Date (1983)
9-14
9-15
9-16
9-17
9-23
9-24
Test (Sample) ID
ABKI-1
AABO-1
ABKI-2
AABO-2
ABKI-3
AABO-3
ABKI-4
AABO-4
ABKI-5
ABMI-1
AABO-5
ABKI-6
ABM I -2
AABO-6
ABKI-7
ABM I -3
Test Location
AsgOs baghouse Inlet
Baghouse outlet
AS203 baghouse inlet
Baghouse outlet
AseOs baghouse inlet
Baghouse outlet
As£03 baghouse inlet
Baghouse outlet
AS2<33 baghouse inlet
Metallic plant baghouse
inlet
Baghouse outlet
As£03 baghouse inlet
Metallic plant baghouse
inlet
Baghouse outlet
AS203 baghouse inlet
Metallic plant baghouse
AABO-7
inlet
Baghouse outlet
H-3
-------
tests were made by the sampling and analytical procedures outlined in
Reference Methods 1 through 5va) and proposed Reference Method 108(b).
The baghouse controls emissions from two process gas streams; one
transports off gases from the AS203 plant and metallic arsenic condensers,
and the other transports off gases from the metallic arsenic process.
The gases exiting the baghouse are conveyed to the main stack.
Initially, four Method 108 tests were conducted simultaneously at
the AsgOs plant inlet and the baghouse outlet while the metallic plant
was not operating. Once the metallic plant came back on line, Method
108 tests were performed at the AsgOs and metallic plant inlets and the
baghouse outlet. A total of three Method 108 tests were conducted
simultaneously at the three test locations (two inlet and one outlet).
These data were used to characterize arsenic emissions to the main
stack and to estimate the arsenic collection efficiency of the baghouse.
Process operations were closely monitored during each emission test
period, and samples of Godfrey roaster charge material and baghouse
hopper catch were collected and analyzed for arsenic content.
Section H.3 presents the results of the test program on the
arsenic plant.
H.3 ARSENIC PLANT TEST RESULTS
Tables H-2 and H-3 summarize pertinent sample, flue gas, and
analytical data for tests performed at the arsenic plant baghouse.
Initially, four simultaneous tests were conducted at the
(kitchen) inlet and baghouse outlet test locations. During these tests,
the metallic arsenic plant was not in operation. For the inlet tests,
designated ABKI (ASARCO Baghouse Kitchen Inlet), the volumetric gas
flow rate averaged 731 dscm/min (26,000 dscfm) with an average gas
temperature of 74°C (165°F) and moisture content of 5.8 percent. The
flue gas composition was consistent for each test and showed oxygen,
carbon dioxide, arid carbon monoxide results of 19.2, 0.45, and 0.0
percent, respectively. Concentrations of SOg typically averaged less
than 3,000 ppm or less than 0.3 percent of the total sample volume.
The uncontrolled arsenic concentration from the As20a plant averaged
7,892 mg/dscm "(3.44 gr/dscf), and the corresponding mass emission rate
was 343 kg/h (757 Ib/h). Results from Test ABKI-1 are not included
in the group average; results of this test are biased low because of a
loss of sample during analysis. For the baghouse outlet tests, designated
AABO (ASARCO Arsenic Baghouse Outlet), flow rates averaged 783 dscm/min
(27,700 dscfm) with an average gas temperature of 74°C (165°F) and
moisture content of 5.3 percent. Average flue gas composition results
were identical to those reported for the kitchen inlet tests. Outlet
(a)40 CFR 60, Appendix A, Reference Methods 1 through 5, July 1982.
(^Federal Register, Vol. 48, No. 140, July 20, 1983, p. 33166-33177.
H-4
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arsenic concentrations and mass emission rates averaged 3.15 mg/dscm
(0.0014 gr/dscf) and 0.15 kg/h (0.33 Ib/h), respectively.
Based on mass emission rate results from this group of tests, the
arsenic collection efficiency of the baghouse was greater than 99.9
percent. Volumetric flows, temperatures, moisture contents, and S02
concentrations measured at each location were comparable.
When the metallic arsenic plant began operation, the same test
sequence was repeated and simultaneous tests were conducted at three
test locations—the kitchen inlet, the metallic plant inlet, and the
baghouse outlet. At the completion of the first set of simultaneous
tests (ABKI-5, ABMI-1, and AABO-5), preliminary calculations showed a
flow imbalance between the inlet and outlet test locations. The
cumulative inlet volumetric flow was 629 dscm/min (22,200 dscfm) compared
with an outlet flow of 841 dscm/min (29,700 dscfm). The 7,000-dscfm
flow imbalance was attributed to an open flow control damper located in
a bypass duct, which entered the metallic arsenic plant exhaust duct
downstream of both the metallic and kitchen inlet test locations (see
Figure H-l). This condition did not exist during the first series of
runs because a second flow control damper located in the metallic plant
duct downstream at the bypass duct was closed. The flow imbalance
occurred when this second damper was opened. The negative pressure
associated with the control system served to divert a part of the flow
from the kitchen through the bypass duct and into the baghouse, where
it was ultimately measured at the outlet test location.
In addition to the flow imbalance, the arsenic concentration and
mass flow rate measured at the As£03 inlet test location were signifi-
cantly less than that measured during the first set of tests (0.45 gr/
dscf and 66 Ib/h versus 3.44 gr/dscf and 748 Ib/h). No conclusive
explanation can be found to account for the significant difference in
AS203 plant loading. The arsenic concentration and mass emission rate
at the baghouse outlet averaged 3.17 mg/dscm (0.0014 gr/dscf) a'nd
0.15 kg/h (0.35 Ib/h). These values are essentially identical to those
measured during the first test series, when only the AS203 plant was
being operated.
Since a malfunctioning flow control damper made the inlet mass
emission rate suspect, the arsenic collection efficiency of the baghouse
was recalculated with an adjusted arsenic inlet mass rate for each run.
Results were adjusted by assuming that the flow imbalance was diverted
to AsgQs gas. The flow difference was assumed to have the same concen-
tration as the kitchen inlet and was added to the total inlet mass
rate. The arsenic collection efficiency averaged 99.5 percent with
both arsenic processes in operation without a calculation adjustment,
and 99.6 percent with an adjustment.
Table H-4 summarizes arsenic analytical results for Godfrey roaster
charge and baghouse dust samples collected by ASARCO during each test.
H-8
-------
BLOWER ( -
OUTLET
SAMPLE LOCATION
TO MAIN STACK
SLIDE BLIND,OPEN
WOOD DUCT
P»-2"H20
KITCHEN INLET
SAMPLE LOCATION
DAMPER
INDICATES
CLOSED
FLOW DIVERSION
METAL FURNACE HOODS
MAIN FLUE
FROM ARSENIC
KITCHENS
SLIDE BLIND,CLOSED
- METALLIC B n .„, „
INLET SAMPLE P=-0.4"H20
LOCATION
Figure H-l Arsenic Plant Gas Flow Schematic — ASARCO-TACOMA
H-9
-------
Table H-4. ANALYTICAL RESULTS FOR ARSENIC PLANT TEST SAMPLES
Date
(1983)
9/14
9/15
9/16
9/17
9/23
9/23
9/24
Sample description
Roaster charge
Baghouse dust
Roaster charge
Baghouse dust
Roaster charge
Baghouse dust
Roaster charge
Baghouse dust
Roaster charge 7:00 a.m. - 3:00 p.m.
Baghouse dust 7:00 a.m. - 3:00 p.m.
Roaster charge 3:00 p.m. - 11:00 p.m.
Baghouse dust 3:00 p.m. - 11:00 p.m.
Roaster charge 7:00 a.m. - 3:00 p.m.
Baghouse dust 7:00 a.m. - 3:00 p.m.
Percent
Arsem'ca
37.2
74.5
27.8
73.5
25.3
75.2
32.2
67.7
33.2
75.8
61.6
72.8
47.1
71.8
aPercent arsenic (by weight) determined by the sample preparation and
analytical techniques described in proposed EPA Method 108.
Note: All samples were collected and identified by ASARCO.
H-10
-------
TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA/450/3-83-010b
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
Inorganic Arsenic Emissions from Primary Copper
Smelters and Arsenic Plants -
Background Information for Promulgated Standards
5. REPORT DATE
May 1986
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-02-3060
12. SPONSORING AGENCY NAME AND ADDRESS
DAA for Air Quality Planning and Standards
Office of Air and Radiation
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
EPA/200/04
15. SUPPLEMENTARY NOTES
16. ABSTRACT
National emission standards to control air emissions of inorganic arsenic from new
and existing primary copper smelters and from arsenic trioxide and metallic arsenic
production facilities are being promulgated under Section 112 of the Clean Air Act.
Part I of this document contains a detailed summary of the public comments on the
proposed standard for primary copper smelters (48 FR 33112), and Part II on the
proposed standard for arsenic production facilities (48 FR 55880). The document also
contains Agency responses to these comments and a summary of the changes made to the
standards between proposal and promulgation.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
Air Pollution
Hazardous air pollutant
Pollutant control
Standards of performance
Inorganic arsenic
Primary copper smelters
Air Pollution
Stationary sources
13 B
18. DISTRIBUTION STATEMENT
Unlimited
19. SECURITY CLASS (This Report)
Unclassified
21. NO. OF PAGES
322
20. SECURITY CLASS (Thispage)
Unclassified
22. PRICE
EPA Form 2220-1 (Rev. 4-77)
PREVIOUS EDI TION IS OBSOLETE
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