SUMMARY OF TECHNICAL DATA

     RELATED TO FUGITIVE EMISSIONS OF

LEAD, ARSENIC, COPPER AND SULFUR DIOXIDE

     FROM THE 16 U.S. COPPER SMELTERS
                     by

                Manuel Gomez
                Richard Duffy
               Vincent Trivelli

                   INFORM
               25 Broad Street
            New York, N.Y.  10004
             Order # D0773NANT
                Prepared for:

 U.S. Environmental Protection Agency (D0773)
 Research Triangle Park, N.C. 27711
 Attn:  Stanton Coerr

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                  CONTENTS






I.  Introduction and Methodology



II. Fact Sheets




       A.  ARCO, Anaconda




       B.  ASARCO, El Paso



       C.  ASARCO, Hayden




       D.  ASARCO, Tacoma



       E.  Cities Service, Copperhill



       F.  Copper Range, White Pine



       G.  Inspiration  Consolidated Copper, Inspiration



       H.  Kennecott Copper, Garfield



       I.  Kennecott Copper, Hayden



       J.  Kennecott Copper, Hurley



       K.  Kennecott Copper, McGill



       L.  Newmont Mining, San Manuel




       M.  Phelps Dodge, Ajo



       N.  Phelps Dodge, Douglas




       O.  Phelps Dodge, Morenci




       P.  Phelps Dodge, Hidalgo

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             INTRODUCTION AND METHODOLOGY








    This report presents a summary of the technical data which INFORM




has gathered and analyzed over the past three years related to fugitive




emissions from the sixteen domestic primary copper smelters.




    Basic information on the nature of the process used at  each smelter




was obtained primarily from published materials (company publications,



journal articles,  EPA reports, papers presented at professional conferences,



etc.), from site visits by INFORM personnel, from inspection reports



prepared by the U.S. Occupational Safety and Health Administration on



file at the agency's area offices, from interviews with workers, and from



companies cooperating with the INFORM study  (Anaconda,  ASARCO and



Copper Range).



    The  data on the effectiveness  of fugitive emission controls, in particular



in-plant  monitoring and personnel sampling data, was gathered primarily



from the following sources:



    (1)   Regulatory agency inspection reports. These include reports



        - obtained from  U.S.  Occupational Safety and Health Adminis-



         tration Area Offices, from OSHA state plan designees, such



         as the Washington Industrial Safety and Health  Administration,




         from other relevant state safety and health agencies, such as



         the  Arizona Office of the State Mine Inspector,  and from the




         U.S. Mining Enforcement and Safety Administration.  (See



         complete list of these agencies following this section.)




    (2)   Surveys  sponsored by the National Institute for Occupational




         Safety and Health.

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    (3)   Company data and expert testimony presented at



         U.S. OSHA hearings on the agency's proposed
                                           V


         arsenic standard (held during 1975-76)  and on the



         proposed sulfur dioxide standard (held  during 1977).



    (4)   Data supplied directly to INFORM by companies



         cooperating with the INFORM study (Anaconda,



         ASARCO, Copper Range).




    Information on corporate programs and policies relating to these



hazards was gathered primarily through interviews with workers and


union officials, from the arsenic and sulfur dioxide hearings cited  above,



and from company management in the companies cooperating with the



INFORM study.


    The "Fact Sheets" on each smelter which follow were prepared at



various dates between January, 1978 and November,  1978.   They



incorporated the most up-to-date information available from the above



sources,  as of the date of their preparation.

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                 REGULATORY AGENCIES
                      FROM WHICH
       SMELTER INSPECTION DATA WAS OBTAINED


Arizona
    U.S. OSHA Phoenix Area Office
    Office of the State Mine Inspector, Phoenix Office
New Mexico
    U.S. OSHA, Albuquerque Area Office
    Environmental Improvement Agency,  Santa Fe
Nevada
    U.S. OSHA, Carson City Area Office
    Nevada Industrial Commission, Carson City
    U.S. MESA (presently MSHA)
    State Mine Inspector,  Carson City
Montana
    U.S.  OSHA, Billings Area Office
Michigan
    U.S. OSHA, Detroit Area Office
    Michigan Department of Labor, Lansing
    Michigan Department of Public Health, Lansing
Tennessee
    Tennessee Department of Labor,  Nashville
    Tennessee Department of Public Health, Nashville
    U.S. OSHA, Nashville Area Office
Utah
    U.S. OSHA, Salt Lake City
    Utah Industrial Commission, Salt Lake City
Washington
    U.S.  OSHA, Bellevue Area Office
    Department of Labor and Industries,  Olympia

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FACT SHEET

FACILITY:  The Anaconda Reduction Works

COMPANY:  ARCO, Inc.
                                                   INFORM
                                                   25 Broad Street
                                                   New York City
                                                   10004

                                                   (212)  425-3550

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                                                                         page 1
GENERAL

Name:  Anaconda Reduction Works

Location :  Anconda,  Montana
Description:
    1)
    2)
    3)

    4)

    5)

    6)
Combination of receiving facilities, fluo-solids reactor, electric
furnace, converters  (3 operating), anode furnaces (4), casting
wheels (2),  and  supportive facilities.

Present feed structure is 60% Weed,  30% Twin Buttes, and 10%
precipitates.  Yerington and Britania have been shut down.
Considerable  future production from Carr Fork will reduce the
average arsenic  content of the  smelter feed.  Arsenic content
estimated at 0.97% ,  lead content estimated at 0.28%.
Reserves are estimated at 800 million tons.
1,300 employees  (approximately	in-copper  production).   Payroll
approximately $28 million.
Plant is main source  of tax revenue,  and principal purchaser of fuel,
power, freight,  and  supplies in Anaconda area.
Production
                            1972
                             1973
1974
1975
1976
1977
Anode Copper
Sulfuric Acid
242,955

208,110

197,543
91,000
193,000
108,000
185,000
84,000


Comments:
PROCESS AND HAZARDS—SMELTER

NOTE:  Throughout the following remarks, the phrase "poorly characterized"
or "uncharacterized" is used to indicate that we have  found no evidence that
either the company or the regulatory agencies have sufficiently characterized
the exposures to permit proper evaluation and corrective action.

NOTE:  All documented arsenic exposures are  expressed in terms of OSHA's
new 10 yg/m3 standard.  Copper dust exposures are expressed in terms of
OSHA's  1 mg/m3 standard.  Lead exposures are expressed in terms of OSHA's
.1 mg/m3 standard (to be promulgated  October 1978).   Sulfur dioxide exposures
are expressed in terms of OSHA's proposed 2 ppm standard.  Noise exposures
are expressed in terms of OSHA's 90 dBA standard.

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                                                                          page
NOTE:  In most areas of the plant, workers wear company-supplied and main-
tained respirators on a need basis.  The following comments evaluate  TWA
exposures independent of respirator usage.

A.  Material Handling Areas (     workers)

    1.   Process materials—concentrate slurries, dry concentrates, and pre-
        cipitates  are received, weighed, sampled,  blended and stored in the
        smelter's  material handling areas.  Slurried concentrates are  received
        by rail, unloaded and pumped to thickening tanks.  Dry concentrates
        are  received by rail, unloaded at one of two unloading facilities, and
        transferred  to roaster bins for  storage.  Additional dry concentrates
        are  stored in an outside storage area—Coal Pile—until needed.   The
        dry concentrates are then fed into a repulping system and mixed with
        the  slurried concentrates and additional water to form a pulp, which
        is then pumped to surge tanks prior to transfer to the fluo-solids
        reactor.

            a.  Dry Concentrate Unloading (	workers)— Car shaker find
               air lance use  create visible dust and high noise levels during
               railroad car unloading.  Arsenic exposures ranging from
               slightly above to 20 times the standard.  Potential copper and
               lead dusts are poorly characterized.   Noise levels exceeding
               115  dBA reported during shaker operation; company requires
               mandatory use of hearing protection.  Operator booth for noise
               control has been reported impractical  during  unloading opera-
               tions .

          -  b.  Roaster #2 (storage bins and transfer areas)  (_2JL workers)--
               Documented arsenic exposures ranging from the  standard 1o
               18 times the standard.  Copper dust documented ranging from
               slightly above to 11 times the standard.  Lead dust exposures
               slightly above the proposed  standard.  Company has reported
               that engineering controls in this area—hoods  on all bins and
               belt transfer points, fresh air booth and rest station, and n
               centralized vacuum system—have  substantially reduced dust
               exposures; however, intermittent  exposures require mandatory
               respirator use throughout this area.

            c.  Slurried Concentrate Unloading and Handling (jy__ workers)--
               Exposures in  this area  uncharacterized.  All materials are  wot,
               reducing potential dust exposures.  However, spills can dry
               on floors and  eventually become airborne causing potential
               worker exposure.

    2.   Flux materials—limestone and silica rock—are  also used in the smelting
        process.  Crushed and sized limestone is purchased from a nearby
        quarry, received by rail,  and treated in the smelter's lime plant for
        use  in the smelting process and to produce milk of lime (calcium hy-
        droxide)  for use in the concentrating process  and for pollution con
        trol at various Anaconda operations.  Silica rock—for use in the con-
        verting process—is purchased from another quarry near the  smelter
        site. The company also purchases some concentrates  with high silica
        content,  thus precluding the need for silica flux in the electric fur-
        nace process.

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                                                                            page 3
             a.   Potential exposures to lime dust,  free silica, and calcium
                 hydroxide mist in the flux handling and treatment areas,
                 and during transfer, are uncharacterized.  (     workers)
 Comments:
 B.  Fluo-Solids Reactor Area (60 workers)

     1.  The blended slurried concentrates are pumped to a distributor tank
         located at the top of the fluo-solids reactor.  This feed is then dis-
         tributed through air-aspirated feed guns into the reactor's roasting
         zone.  Fluxes are fed into the same area through a series of bins,
         conveyors, and a sealed screw conveyor.  Preheated air is introduced
         under pressure through the reactor floor where it reacts with the feed
         materials to produce calcine and sulfur dioxide.  Most of the calcines
         leave the reactor entrained in the offgas stream  and are collected in
         primary and secondary cyclones, from which they are removed by
         screw conveyors which discharge into drag flight conveyors that feed
         the electric furnace.  Some of the, calcines are discharged from the
         reactor through  two bed overflow valves directly into the drag-flight
         conveyors.

     2.  While the reactor operation is  enclosed, the operation is under pres^
         sure and seal leakage occurs intermittently. There  have also been
         problems with the cyclone seals which on occasion "blow out," releas-
         ing dust and fumes into adjacent areas. Workers in this area  are also
         potentially exposed to fugitive emissions from the electric furnace,
         since the reactor is located adjacent to the furnace and in the same
         building.

     3. Number of workers in  this area and their respective duties are un-
         known.  Company reports average sulfur dioxide  & arsenic exposures
         above current standards.

Comments:

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                                                                         page 4
C.  Electric Furnace Area ( ^Q  workers)

    1.   Upper Furnace Levels

        a.   Feed Levels  (drag flight conveyor and slag launder/furnace roof
            levels)— Calcines from the reactor, as well as recycled flue dust,
            molten converter slag,  and cold slag accretions from the converters
            and ladles,  serve as feed for the electric furnace.  Calcines and
            flue dust are fed to the furnace through multiple discharge points
            along the length of two parallel drag-flight conveyors located    /
            above the furnace.  Converter slag is introduced into the furnace
            through two converter  slag launders located at the converter aisle
            end of the furnace.  The revertable slag—converter accretions,
            skulls,  etc.—is loaded  into portable hoppers, which are then
            placed directly over chutes located along one side of the furnace.

        b.   Paste and Storage Levels—  The  uppermost level of the electric
            furnace  is used for  storage—i.e., electrode paste.  Just below the
            storage  level is the paste level, where paste is added to the six
            electrodes—daily, usually  during each afternoon shift.

        c.   Worker exposures in upper furnace levels:

            1)   Documented arsenic exposures  ranging three to seven times
                the  standard.  Copper dust exposures  documented at slightly
                above the standard to greater than eight times the standard.
                Documented lead exposures twice the proposed standard.

            2)   The company reported that it has identified the sources that
                were contributing to dust exposures in this area and is now
                in the process of implementing  engineering and administrative
                controls to reduce  these exposures.   Extent and effectiveness
                of controls are unknown.

            3)   Company reported  sulfur dioxide levels ranging from greater
                than twice to twenty times  the  proposed standard.  Peak
                levels up to 100 ppm.

            4)   Engineering attempts presently being implemented may  reduce
                some of the sulfur  dioxide  emission points and  resulting
                worker exposures;  however, it has been reported that  con-
                verter aisle fugitive emissions drift into electric furnace
                building and contribute  to  worker exposures in this area.

            5)   Potential aromatic hydrocarbon exposures, resulting from the
                "baking" of the  electrodes, and subsequent leakage around the
                electrodes' seals.

    2.   Tapping Areas

        a.   Matte Tapping—  Matte is tapped from the converter aisle end of
            the furnace into ladles  located  underneath the tapping floor in a
            semi-enclosure (short tunnel).  After ladle is full,  it is pulled out
            of this area into the center of the converter aisle,  where it is
            picked up by an overhead bridge crane.  Doghouse hoods cover
            the matte tapping points for collecting the gaseous and particulate
            fugitive  emissions during tapping operations.  The matte launders
            are covered.

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                                                                          page 5
           1)   Documented arsenic levels of 1,500 to 2,100 ug/m .  Company
                reoorts oersonal TWA arsenic exposures uncharacterized of 87
           2)   It has been noted that the matte tapper gets his head in heavy
                smoke when checking the level of the ladles.  Documented sul-
                fur levels of  45 ppm.  Personal TWA exposures are uncharacter-
                ized.

           3)   Other potential exposures—i.e., lead—are uncharacterized.

           Slag Tapping— Slag is tapped  in one of two tapping bays located
           on the opposite ends  of the furnace. This operation utilizes rubber-
           tired  slag pot carriers which accept the slag directly from the
           furnace.  The  slag is then transported to a disposal area.   Similar
           to the matte area, the tapping  points are hooded by doghouses and
           the launders are  covered.

           1)   Personal TWA arsenic exposures are poorly characterized.  One
                three-hour level of 10 times the standard has been  documented.

           2)   Sulfur dioxide and other potential  exposures—i.e., lead—are
                uncharacterized.
Comments:
D.  Converter Area ( 59 workers)

    1.   Matte from the electric furnace is transferred to one of three Peirce-
        Smith converters.  Silica is added to the converters to form  an iron
        silicate slag which is returned to the electric furnace for additional
        processing.  The current practice is to have two converters operating
        with the other one on hold.  There are three  additional converters in
        the converter aisle; however, they are no longer used.  All  converters
        have primary water-cooled hoods which capture the off gases and vent
        them to the plant's baghouse.  At the completion of the converter
        cycle, blister copper is transferred to the anode area  by overhead
        crane.

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                                                                          page 6
       a.  A consultant assisting Anaconda in a survey of potential arsenic
           problem areas after the start-up of the electric furnace stated that
           the arsenic and sulfur dioxide levels in the converter aisle would not
           change after the elimination of the reverberatory furnaces.  During
           the OSHA Arsenic Hearings the  company reported average arsenic
           exposures in the converter area at almost five times the standard
           with arsenic area levels of up to 2,194 pg/m^.  The company recently
           reported that converter1 employees' arsenic  exposures ranged up to
           twice the  standard.

       b.  OSHA found high sulfur dioxide levels (35-40 ppm) that intermit-
           tently occur and cause converter employee  eye irritation.  In 1978,
           the company reported that converter employees' exposures ranged
           up to 1£ times the proposed standard.

    2.  Crane cabs are under positive pressure and air conditioned.  A worker
       reported that  the company wanted cranemen to  work with respirators
       when air conditioning failed.  Complaints about crane cab conditions are
       still heard during Joint Safety and Health Committee meetings.

    3.  Skimmer— Documented arsenic exposures of five to seven times the
       standard  and  very high episodic levels of sulfur dioxide prior to the
       insulating of the skimmer shacks and fitting them with positive-pressure
       fans and duct heaters.  Effectiveness of these controls is unknown.

    4.  Puncher— Documented noise exposures of 1^ times the standard with
       intermittent noise levels exceeding 115 dBA prior to the installation of
       insulated soundproof punching cabs on the active converters.   Effec-
       tiveness of these controls is unknown.

    5.  Potential exposures of arsenic, lead, and copper dusts,  and sulfur
       dioxide to converter aisle employees—ladle chasers, cat operator, etc.—
       from converter aisle activities—skull breaking,  cleaning of aisle with
       bulldozer, ladle emissions, etc.—are poorly characterized.
Comments:

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                                                                         page 7
E.  Anode Casting Area (35 workers)

    1.   Overhead bridge cranes transfer the blister copper from the converters
        to one of four anode furnaces,  the refining cycle—oxidation and re-
        duction  (using natural gas)—usually takes- four hours, after which the
        anode copper is cast on one of two casting wheels, each containing 26
        anode molds.  Gases emitted  by the anode furnaces are not captured,
        but  are vented directly into  the building.  A fume exhaust system,
        which encloses the new airless spray system—used to cool the anodes
        on the casting wheels—collects gases, vapors,  and particulate emis-
        sions .  These emissions are exhausted via a stack through the building
        roof line to the atmosphere.  After cooling,the  anodes are placed into
        rack cars and shipped to Anaconda's Great Falls Refinery for electro-
        lytic refining.

        a.   Documented arsenic  exposures ranging from  slightly above to 10
            times the standard.

        b.   The company recently reported sulfur dioxide exposures below the
            proposed standard.  During the 1977 OSHA Sulfur Dioxide  hearings,
            employee exposures  were reported ranging from at  to three  times
            the proposed standard.

        c.   After a 1975 OSHA noise citation, the company installed soundproof
            pourer's booths equipped with electric heaters, ventilating fans,
            and air conditioners.  In addition, the open furnace burners were
            converted to a closed type and the moldwash sprayers were con-
            verted to an airless  spray-  Present noise exposures are reported
            at the standard.

        d.   Poling generates "black smoke-"-unburned hydrocarbons—which is
            released uncollected into the anode area.  Worker exposures, if
            any, are uncharacterized.  It is unknown whether the company has
            reduced the amount  of unburned hydrocarbons by mixing air with
            the reducing gas in  the tuyeres.

        e.   Potential heat exposures are uncharacterized.

Comments:

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                                                                         page
F.  Baghouse  (14 Workers)

    1.   A new particulate control facility that incorporates a baghouse was
        installed to replace the plant's old Cottrell units.  Major components of
        this facility include two spray chambers to. cool the offgases, three
        centrifugal fans, and an eighteen-chamber baghouse.  After cleaning,
        the gases are routed  to the main stack or to the acid plant.  Dust col-
        lected in this facility is either returned to the electric furnace by screw
        conveyor—to lower the furnace's roof temperature and to reduce the
        rapidity of gasing in  the furnace—or dumped.  The dusts that are
        dumped are first transferred  to ventilated tanks where lime is added to
        fixate the arsenic and then pumped to a retention  pond where it is
        stockpiled.

        a.  Arsenic exposures  reported ranging from at to 47  times the stand-
           ard.  Area levels of up to 1,570 yg/m3 have been documented.*

        b.  Sulfur dioxide levels of up to 300 ppm have been  reported, per-
           sonal TWA exposures are  poorly characterized.

        c.  Lead exposures have been reported from slightly above to seven
           times the proposed standard.*

        c.  Cadmium  exposures have  been documented ranging from above to
           twice the standard recommendec by the National Institute for Occu-
           pational Safety and Health (NIOSH).*

Comments:
*Many exposures documented in the baghouse area were for employees who
carried out repair tasks in the area and only worked there intermittently-

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                                                                         page 9
G.  Acid Plant  (16 Workers)

    1.   A single contact 660 ton per day sulfuric acid plant was enlarged to a
        990 tons per day double contact plant in  1977.  The company now in-
        tends to add an additional plant to increase air pollution control.

        a.  Data on worker exposures in this area was not available to
           INFORM.   Hazardous exposures have been reported in acid  plant
           areas at other copper smelters.

Comments:

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                                                                         page 10
COMPANY SAFETY AND HEALTH ACTIVITIES

A.  History

    1.   Anaconda's Industrial Hygiene Department was first formed in 1943 and
        remained at the smelter until  1958 when operations were switched to
        the Butte Environmental Department.  Industrial hygiene operations
        were reorganized in 1969 under the Department of Environmental Af-
        fairs. Since the ARCO takeover of Anaconda operations, industrial
        hygiene  activities were established at the corporate level under the
        auspices of the Vice President of Environment, Health, and Technology.
        At the smelter the program is overseen by the Director of Industrial
        Health and Safety.  In addition,  the Industrial Health and Safety
        Program is completely independent of the plant's environmental pro-
        gram.

    2.   History of Anaconda's Safety  Program not available to INFORM.

B.  Staff (smelter)

    1.   Director of Industrial Health and Safety

        a.   Industrial Health Staff
            1)   Industrial Hygiene Engineer

            2)   Industrial Hygiene Technician
            3)  Respirator cleaning and maintenance (3)
        b.   Safety Staff

            1)   Safety Engineers (2)

C.  Industrial Hygiene Activities

    1.   Environmental (inplant)  Sampling

        a.   Until recently, personal sampling  was performed on a "rule of
            thumb" basis, basically in high risk areas  such as the baghouse.
            A routine sampling schedule  has recently been implemented as a
            result of regulatory actions—i.e. , new arsenic standard.  The
            company has recently completed a comprehensive sampling protocol
            of all job  categories  at the smelter, even workers in outlying areas
            where exposures were not thought to occur in the past.   After
            documentation of each job category's  exposures, the company ex-
           pects to adhere to the required sampling provisions as provided
           for in the new arsenic standard.  Air contaminants monitored for
           include arsenic, sulfur dioxide, copper,  lead, and cadmium.

        b.  Area sampling has been performed in many areas of  the plant to
           evaluate control approaches—i.e. , concentrate blending  area and
           electric furnace.

        c.  All area and personal samples collected at the plant are sent  to
           Anaconda's industrial hygiene lab in Tucson,  Arizona.  This
           laboratory was certified by the American Industrial Hygiene Asso-
           ciation in  February, 1977.

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                                                                          page 11
    2.   Noise Sampling

        a.  The company performs, on an annual basis, both area level (sound
           level meters) and personal (dosimeters)  noise sampling surveys.

    3.   Ventilation and engineering control systems  are checked by the plant
        engineering maintenance crews and environmental engineering techni-
        cians on an "as needed" basis.

    4.   No formal reports or education are given to  workers regarding the
        need, objectives,  and results of industrial hygiene activities.
Comments:
D.  Respirator Program

    1.   Training, education, and supervision of respirator is the responsibility
        of the Director of Health and Safety.

    2.   All workers are assigned and fitted with their own respirators accord-
        ing to the hazards present in their work area.  Respirators are worn
        on an as needed basis, except in designated mandatory-use areas.

    3.   All workers at the plant have received extensive respirator training
        which includes viewing of a film produced  at the plant, and individual
        fitting/leak testing of each respirator-

    4.   Workers in the smelting areas of the plant  are furnished with a clean,
        individually marked respirator at the beginning of each work shift.
        Other workers are issued unmarked respirators which can be ex-
        changed any time  cleaning or maintenance  is required.

E.  Safety Activities

    1.   Plant safety engineers conduct routine inspections (monthly,  bi-
        monthly, annually) of the plant, in  addition to those performed by the
        Joint Safety and Health Committee.  No specific checklists are used.
        Results of inspections are prepared in memorandum format.

    2.   Accident investigations, for  all compensated accidents, ambulance
        calls, fatalities, and near misses with potential serious injury are con-
        ducted jointly by  the company and the union.  In all cases, written re-
        ports are prepared and a copy is forwarded to the union  in memorandum
        format.

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                                                                          page 12
    3.  New employees are instructed as to the safety aspects, the associated
       hazards, and the proper safety practices of their particular job
       through an indoctrination orientation.  After  initial orientation, the
       worker is assigned to work with an experienced worker.  The length
       of training period is dependent on the hazard of the job.

    4.  Formal safety refresher courses for all employees are not available.

    5.  Safety and health implications of new equipment and/or process
       changes are  first discussed with Joint Safety  and Health Committee.
       Safety training is then provided for those employees involved with the
       change /addition.

    6.  Accident frequency rates are computed by prescribed MESA methods
       (adopted from American National Standards Institute [ANSI] methods).
       These rates  were not available to INFORM.

    7.  OSHA 102 data is available for 1973 through 1976.

    8.  Identification of accident factors is a normal part  of the plant's safety
       program;  however, these efforts have not resulted in any publicly
       available findings.

    9.  Yearly estimated  cost of the plant's  safety program—labor and equip-
       ment—was $360,000 in 1977.

   10.  Company reports that they are not engaged in any formal system of
       safety information exchange outside the company.

Comments:

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                                                                          page 13
F.  Health Care

    1.   Smelter complex has its own onsite clinic which is staffed by four
        Industrial Medics—enabling 24-hours-per-day availability.

    2.   All serious injuries and illnesses are treated at Anaconda Community
        Hospital--a 60-bed facility—located two miles from smelter. Ambulance
        is'avaHable at smelter site.

    3.   Emergency medical equipment—first aid/burn kits, stretchers—are
        located at various locations  throughout the smelter.

    4.   All employees receive pre-employment  medical and audiometric exams
        as required by Montana state law.

    5.   Annual audiometric exams are given all employees.  Evaluation of
        these tests is performed by a local otologist.

    6.   Until recently, company only provided annual physicals for baghouse
        employees and those exposed to asbestos.   While the  company paid for
        the examination—no company physicians at the plant—they were only
        available  to the employees on their own time. Company also provided
        urine analyses (arsenic) for every person who is monitored  for
        arsenic exposure.
    7.   A new medical screening program--including chest x-ray, sputum
        cytology, pulmonary function, and blood and urinary analysis for
        heavy metals—was recently made available, on a  voluntary basis,  to
        all plant employees.  Results of the exams  will only be available to the
        individual worker; company officials will not receive the results of
        these individual tests.  These exams were  performed  by an independent
        medical consulting firm—Tabershaw Occupational Medicine Associates.
        After completion of and analysis of all  the workers' examinations,  the
        consulting firm will report to the company  any trends that management
        should address.  The company presently plans to make this screening
        program available  on an annual basis.

    8,   Until the above program was implimented, there  was no evidence of a
        formal education program  regarding the need, objectives, and results
     i   of medical activities.
    9.   Epidemiological and medical  research studies have been performed at
        the Anaconda smelter.  These studies  have included the Lee and Frau-
        meni study, a University of Utah study of Sputum cytology testing and
        a study of smelter workers' urinary arsenic levels.

Comments:

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                                                                          page 14
SAFETY AND HEALTH COMMITTEE                     I
                                                      i
A.  The Joint Safety and Health Committee was established in compliance with
    contract provisions in 1971.                        i,

B.  Committee includes five management representatives and five union repre-
    sentatives.   One member  from  each group serves as a co-chairman for a
    one-year period.
                                                          i
C.  Committee meets once a month  to discuss safety and health!  conditions and
    to make recommendations  for corrective action.  Inspection  tours are con-
    ducted if any member so  requests.  A written report ;(minutes) is prepared
    at the conclusion  of the meeting by the company and forwarded to all com-
    mittee members and the union.

D.  Other safety and  health topics may be discussed, such as any new process
    changes and/or additions.  The union also uses the committee to air any
    safety and health  complaints.                       !

E.  The safety and health provisions of the union contract address other
    matters, such  as :                                    '
                                                        f
    1.   Right to refuse unsafe work. Specific procedures  for handling dis-
        puted cases have been incorporated into the contract.

    2.  Right of the International  to enter areas of the plant if any dispute
        arises over safety and health issues,

    3.  Right to retain wage  rates if worker is forced  to change jobs as a
        result of toxic substance exposures.

F.  There is no company policy which would allow the union to  review the
    results of the company's  industrial hygiene monitoring.

Comments:

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                                                                          page 15
REGULATORY HISTORY                                I
                                                       i
A.  Pre-1970                                           jj
    1.   Safety
        a.   Industrial Accident Board
            1)  Smelters designated as hazardous workplace, 1961.
                No inspection records available to INFORM.   i
                                                           I
    2.   Health
        a.   Montana State  Department of Health
                                                       i
            1)  1943 established methods of determining ^nd monitoring air
                contaminants.                           i
            2)  Periodic monitoring of Anaconda Reduction Works re:
                arsenic, lead,  zinc, sulfur dioxide, etc., beginning in 1943
                —inspections on file at INFORM.        <
            3)  Passed statutory inspection provision for Industrial Hygiene,
                1967.                                    {
B.  Post-1970                                           ;
    1.   Safety
        a.   Bureau of Safety and Health, Division of Workers' Compensation
            1)  Drafted OSHA  State Plan
            2)  State never passed enabling legislation; plan withdrawn
                6/30/74.
            3)  No longer  inspect.
    2.   Health
        a.   Department of  Health and  Environmental Sciences
            1)  1971 passed  comprehensive occupational health  regulations
                and standards.
            2)  Bureau of  Occupational Health presently  answers complaints
                and requests.
C.  OSHA Activities
    1.   Sole jurisdiction over state occupational safety and health activities
    2.   Inspections (see Table 3)
Comments:

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PROCESS EQUIPMENT—Anaconda
NAME
AGE
POLLUTION CONTROLS
COMMENTS
Fluo-Solid Reactor
1975
1° + 2° Cyclones -> Spray Chamber
       Baghouse ->- Acid Plant or  Stack
Electric Furnace
1975
Balloon Flue ->• Spray Chamber
Baghouse -> Acid Plant or Stack
Matte and slag tap hoods (dog-
houses) .   Semi-enclosed matte
ladle bay.
Converters
     (6--  3 active)
3 -  1941       Primary Hoods -> Balloon Flue ->
1 -  1968       Spray Chamber-Baghouse ->
2 -  1972       Acid Plant or Main Stack
                                        Skimmer booths enclosed,
                                        Punching cabs enclosed.
Refining Furnaces
     (4)
2 - 1941       Furnace off gases not collected
2 - 1972       vented through roof monitor.
                                        Closed-type burners.
Casting Wheels
     (2)
              Fume exhaust system which encloses
              airless  spray—cools anodes and
              collects gases, vapors, and particulate
              emissions
                                        Enclosed pourers booths,
Baghouse
1976
                                        Collected dusts returned to
                                        furnace or mixed with lime and
                                       -dumped.
Acid Plant
Enlarged
in 1976
No controls needed.
Presently controls 35% of total
sulfur input.
                                                                                                               oq
                                                                                                                to

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SUMMARY OF HEALTH HAZARDS—Anaconda
Number of-,
Employees
PLANT AREA in Area
Dry Concentrate
Receiving & Handling
Slurried Concentrate
Receiving & Handling
Fluo-Solids Roaster/
Electric Furnace Area
Converter Area
Refining & Casting
Baghouse
Acid Plant
35
9
64
102
53
16
.9
TWA Exposures *
(area levels)
Copper
(mg/m3)
.25-11.8
9
10-210
1.21-8.29
.05-. 22
.06-. 8
.05-. 20
9
Arsenic
(yg/m3)
10-450
9
10-210
[30-2,100]
46
[up to 2,199]
11-100
10-470
[770-1,570]
9
Lead
(mg/m^)
.01-. 13
9
.03-. 24
.01-. 02
.005-. 05
.01-. 74
..^.. . ^,
Sulfur Noise
dioxide Levels
(ppm) (dBA) NOTES
	

5-39.4
[20-100]
.04-3
[35-40]
.1-5.7
[16]
[up to 300]
	 f\
109-
117
9
92
115
90
9
9
High dust exposures occur
intermittently (e.g., large
spills) . Mandatory respi-
rator use area.
Potential exposures from
spills (drying on floors) ,
return side of belts. Ex-
posures, if any .unknown.
Re-engineering partly un-
derway: feeding opera-
tions, flues, draft.


High exposures occurring
intermittently during repair
Exposures unknown
        independent of respirator usage

        SOURCES:   Arsenic OSHA  hearings  1975.  Company data
                    Sulfur dioxide OSHA hearings 1975.
                    OSHA inspections
                    NIOSH surveys
                    State Department of Health Inspections
                    Company data
                                                                                                                  Co
                                                                                                                  crq

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OSHA INSPECTIONS--Anaconda
DATE
5/26-27/71
12/26/72 -
4/17/73
case com-
pleted
2/4/74
6/26/73
7/2/73
3/4-7/75
case com-
pleted
9/15/75
3/7-11/75
9/9/75 -
2/13/76
case com-
pleted
1/24/77
TYPE
complaint -
health
general
schedule -
health
complaint -
health
Follow-up
general
schedule -
safety
complaint -
health:
gases §
dusts
general
schedule -
health
FINDINGS
PENALTIES
FOLLOW-UP
NO SPECIFIC STANDARDS IN EFFECT AT THE TIME
19 non-
serious
violations
1 serious
violation
In Compliance
21 non-
serious
violations
In Compliance
4 w i 1 f u 1
6 repeated
9 serious
16 non-
serious
$235
Contested - "controls
not feasible" for
dust § noise
$800
NONE
$535 - contested.
1 citation vacated
2 reduced by $15
Final penalty —-$47-5
NONE
$45,055 - contested.
Final penalty
$28,645. Repeated
violations reduced
to non-serious .
NONE
As per terms $
conditions set
forth in settle-
ment, abatement
dates were ex-
tended.
Violation
abated 7/2/73
NONE
Violations
abated 9/15/75
NONE
Interim inspec-
tions as per
terms & conditions
set forth in
settlement .
COMMENTS

Cu, Pb, As dusts sampling;
noise; asbestos storage,
handling, monitoring.
Guardrails in crane areas.
No violations pertaining to
complaints which were for
excessive noise, SO , dusts,
§ fume .
Follow-up on crane
guardrails.
Various safety violations -
guardrails, shields, etc.
	
Cited for Cu, Pb , As dusts
greater than unity; respi-
rator violations; asbestos
storage, handling, ti
monitoring; noise.
                                                                                                                          to
                                                                                                                         oq
                                                                                                                          CD

-------
DATE
12/06/76






12/14-14/76



3/2/77





3/29/77


4/8/77






TYPE
Accident
Fatality





Complaint
Health



Complaint
Safety





Follow-
up of
3/2/77
Complaint
[accident]
Safety





FINDINGS
1 other
violation





1 other
violation



1 serious
and 8 other
violations







3 other
violations






PENALTIES

$140





$0



$280





	


$0






rULjljWH-Lir

Company sub-
mitted abate-
ment .



Company sub-
mitted abate-
ment.


OSHA follow-up
inspection.





	


Company sub-
mitted abat"e=
•- ~" Tnent.





	

Cited for failure to complete
a written engineering survey
prior to starting demoloition
work. CSHO concluded that
accidental death was due to
employee insubordination.
Cited for not providing PPE
to prevent occasional eye
irritation from SC>2 . Company
enclosed and ventilated skimmer
shacks .
Serious violation for not having
access gates in place on one of
the conveter cranes. Other
violations for various crane
violations including lack of
load markings, guardrails &
electriacal violations.
OSHA found all violations of
3/2/77 have been abated.

Accident occurred during rebuilc
of converter.— --Injury sustained
was a fracture and dislocation
.QfLbones in hand. Complaintee
stated that noone accompanied
him to first aid, poor procedure
to take care of injuried. Citec
for three scaffold violations.
0>

-------
9/19/77
11/3/77
Follow-up
Health of
9/9/75 [#7]
2 other
violations
$60
Company sub-
mitted abate-
ment.
Copper exposures in the belt
areas of Ro. #2 and Serpentix
building ranging between
1.9 to 11.8 mg/m3.
11/1/77
3/20/78
Complaint
Health
4 other
violations
$0
Unless PMA is
granted, all
violations are
to abated by
09/27/78
Citations for copper and lead
exposures.  Area sampling for
arsenic [up to 2,100 ug/m3]-4
sulfur dioxide [up to 45.5 ppm
All sampling performed in
electric furnace dept., after
worker complaint stating that
electric furnace workers are
exposured to dusty, hot, gaseous
conditions.
12/22/77
Complaint
Health
No
violations
                                        Worker complaint in re to
                                        asbestos exposures in converter,
                                        boiler,  and reverb shops, compl-
                                        aint was informal since worker
                                        would not release his name.
                                        CSHO found that physicals were
                                        given to exposured employees(44)
                                        air sampling was performed (with
                                        in limits), areas were posted.
                                        asbestos maFeriats—labeled,  and
                                        asbestos materials properly ;
                                        -s.to.red.  -- no violations
                                        observed.
                                                                                                                      Oq
                                                                                                                       0>
                                                                                                                       to
                                                                                                                       o

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FACT SHEET

FACILITY:  El Paso Copper Smelter

COMPANY:  ASARCO, Inc.
                                                         INFORM
                                                         25 Broad Street
                                                         New York, New  York
                                                         10004

                                                         (212) 425-3550

-------
 I.   GENERAL

     Name:   El  Paso Copper Smelter

     Location:   El  Paso,  Texas

     Description:

         1)   Custom non-ferrous  smelter complex producing  lead,  zinc,  copper  and
             cadmium.   Facilities  to  extract  autimony  from a complex  copper ore
             will  soon  go into operation.   INFORM has  researched! only the  copper
             circuit of the complex.   Copper  has been  smelted since 1916.

         2)   Copper concentrates are  mostly from Arizona.   Company reported in
             communications to INFORM in 1977 that  the arsenic content of  the
             copper feed is 0.01%.   In mid-1975, a  consultant retained by  ASARCO
             presented  testimony of the OSHA  arsenic hearinjgs which placed the
             arsenic content at  0.20%.   Lead  content is  reported by the company
             at 0.4%.                                       !

         3)   Entire operation involves 900  to 1,000 employees.   Copper circuit
             production employees  number approximately 150,  excluding the  yard
             gang  and the ore unloading departments which  are shared  by the
             different  smelter processes.
         4)   Plant  is located in a relatively large metropolitan area (population
             MOO,000)  with diverse sources of employment.  , Smelter is  an  impor-
             tant  area  employer^ but  not the  predominant one.'
                                                           i
         5)   Production                                    ;

               a)   Approximately 30%  of ASARCO's total copper production.
               bj                   1972    1973    1974      1975      1976
Copper
78,000
98,000
78,479
88,706
83,793
     Comments:
II.   PROCESS AND HAZARDS
     NOTE:   In most areas  of the plant, workmen wear  company-supplied respirators
     The  following comments refer  to  exposures independent of  respirator usage.

     NOTE:   The  El Paso area is subject to strong winds  several months during  the
     year.   Since many of  the  areas of the  smelter  are  semi-open, exposures can
     be seriously influenced by the windy  conditions.

     NOTE:   Throughout the following  remarks, the phrase "poorly  characterized"
     is used to  indicate that  we have found no evidence that either  the company
     or the  regulatory agencies have  sufficiently characterized the  exposures  to
     permit  proper evaluation  and  corrective  action.

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                                                                     [page 2,
A)  Receiving and Bedding Areas

    1)  Concentrates are received in bottom-drop railrdad cars or unloaded
        with clamshell buckets into grate and undergroiifnd belt conveyor.
        Occasional exposures to excessive noise (R.R. car vibrators) and
        dust.  Potential arsenic and lead exposures.  A report by an ASARCO
        consultant in 1975 estimated the percentage of arsenic in pavement
        dust to be 0.9%.

    2)  Concerete ore bins.  Materials distributed by automjatic tripper con-
        veyor into appropriate bins.  Both lead and copper (concentrates are
        housed in same building.  Potential lead and arsenic exposure haz-
        ards.  High dust exposures occur particularly when men use air
        lances in bins to dislodge concentrate for delivery to hoppers
        below.  Company reports plans to remodel entirfe receiving and bed-
        ding areas, automating and enclosing much of the operation.  Plans
        are a response to local and state pressures to- control fugitive
        emissions of particulates.

B)  Roasters
    1)  Four wedge roasters.

    2)  Operating decks
            a)  Arsenic exposures documented in a range ten. times the
                proposed standard.  Sulfur dioxide exposures are variable
                but in a range between the present and! the proposed stan-
                dard.  Dust exposures, if any, are poorly characterized.
            b)  Exposures occur from "puffs" that exceed the draft in the
                roaster, from the need to use access doors on all decks for
                maintenance and repair, and from emissions during loading
                of larry cars.
    3)  Unloading areas--larry car

            a)  Calcine is discharged at 1,000° F.
            b)  Company reports a "ventilation tunnel" for the loading area
                is in operation.

            c)  Larry cars are not covered during rail transfer to top of
                reverb,  thus becoming an intermittent source of air contami-
                nants .
            d)  Larry motorman has a very high documented exposure to sulfur
                dioxide (four to five times the present standard).  Excessive
                arsenic exposures are almost certain, but they are not
                available to INFORM.  Dust and lead exposures are not char-
                acterized.
            e)   Larry motorman exposures occur both in the roaster area and
                above the reverbs while feeding calcine.
C)   Reverb
    1)   One sprung-arch reverb furnace,  charged with Wagstaff guns along the
        sidewalks.

    2)   Slag is tapped into holding furnace, where residual copper settles
        out.   Tapping operation into slag cars from holding furnace is not
        hooded.

-------
                                                                    [page 3]
    3)   Matte tapping ports and launders are hooded and ventilated.   Matte
        ladle is  exhausted with hinged hood while filling.

    4)   Compressed air is  used for "blowing" the top of the furnace.   No
        vacuuming has been attempted.                  !•
    5)   Airborne  arsenic levels in the entire area are eight to ten  times
        the  proposed standard.   Personal exposures for different job  cate-
        gories are probably characterized by the company,  but not available
        to INFORM.                                         j

    6)   Sulfur dioxide levels  in the charge deck area  are 'reported  variable
        between 1 to 50 ppm.   Personal exposures to sulfur dioxide in this
        and  other reverb areas  are poorly characterized.
    7)   Copper dust and/or fume exposures are poorly characterized.

    8)   There are reported airborne lead levels in the| charge deck area in
        the  range of the proposed standard.

D)   Converter Aisle
    1)   Three Pierce-Smith converters  with primary water-cooled hoods.

    2)   Company presently building nearly complete enclosure around  conver-
        ter  building.  Together with roof fans and collection equipment,
        however,  these changes  are in  response to local and state pressures
        to control fugitive emissions.  Company statements  indicate  uncer-
        tainty and some apprehension regarding the impjact  of this enclosure
        on workplace exposures.                        j
    3)   Zinc fuming furnace is  in converter aisle area.  It receives  slag
        from the  lead circuit,  containing zinc as well as  lead.   This fur-
        nace is probably the main source of airborne lead  in the converter
        and  reverb areas,  although some copper matte from  the lead blast
        furnace is fed to  the  reverb and probably results  in airborne lead
        as well.
    4)   Arsenic exposures  in the aisle average approximately ten times  the
        proposed  standard.   Personal exposures in different job  categories
        are  probably characterized by  company but not available  to INFORM.
    5)   Sulfur dioxide exposures in the aisle and platforms are  reported
        close to  the proposed  standard.   Exposures to cranemen are reported
        in the same range.
    6)   Crane cabs are not enclosed and ventilated.   Cranemen wear respira-
        tors.   Company reports  plans to modify cabs.
    7)   Airborne  lead levels reported  to be around the proposed standard  in
        the  platform area  and  around the present standard  for cranemen.

    8)   Exposures to copper fumes are  not characterized.
    9)   Converter punchers  and  skimmers are exposed to noise levels  in
        excess of the standard.   Efforts to enclose the operator's cab  were
        made  and abandoned.   Company  now reports steps to  try out tuyere
        mufflers.

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                                                                    [page 4]


E)   Anode Casting

    1)   Two anode furnaces,  one casting wheel.
    2)   Company estimates arsenic levels to be  two to iien times the proposed
        standard.  Personal  exposures are not characterized.
    3)   Other potentially hazardous exposures are not characterized (e.g.,
        heat, unburned hydrocarbons,  burner noise).

F)   Other Areas
    1)   Coarse and fine crushing areas.   Very dusty conditions with ineffec-
        tive engineering controls.                     I
    2)   Cadmium operation near the  smelter, coupled with strong winds  and
        semi-open smelter areas may result in hazardous  exposures  to cadmium
        in areas remote from actual handling.         !
    3)   Dust handling from flues, baghouses and precipitators  is in the
        hands of outside crews, under contract, according to  company hy-
        gienist.  Exposures  are poorly characterized.  : Company respirator
        program requires supplied air for man entering baghouses during
        operation.                                      !
    4)   Exposures to other maintenance personnel have only recently begun to
        be studied by the company.   Details not availably to  INFORM.
    5)   Exposures, if any, in the acid plant are not available to  INFORM.

G)   General
    1)   Potential engineering controls applicable to the El Paso smelter  are
        discussed in some detail in three documents which were introduced as
        testimony at the arsenic and sulfur dioxide hearings.   They are:
            a)  Testimony by Edwin  S. Godsey of ASARCO at OSHA arsenic hear-
                ings in 1975.
            b)  Feasibility  and Cost Study prepared by Industrial  Health
                Engineering  Associates,  Inc., for ASARCO,  and  presented at
                the OSHA arsenic hearings in 1975.
            c)  Feasibility  and Cost Study prepared by Industrial  Health
                Engineering  Associates,  Inc., and presented at the OSHA
                sulfur dioxide hearings  in 1977.
            INFORM may utilize these materials  in its final smelter profile.
    2)   The El Paso smelter  has been involved in a continuing  controversy/
        dialogue with city and state air pollution authorities in  relation
        to stack and fugitive emissions  of heavy metals, sulfur dioxide,  and
        particulates.   The record of the controversy (studies, legal deci
        sions, articles, etc.)  is voluminous and largely available to INFORM.
        The matter is particularly  important in relation to in-plant condi-
        tions because many of the controls which have been installed in the
        last few years, as well as  those now being installed,  have been the
        result of enforcement of air pollution  regulations, particularly
        through a court case in the city of El  Paso.

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                                                                        [page  5]
       3)  A number of areas in  the smelter have never be^n inspected by a  reg-
           ulatory agency.  The  sampling building,  the receiving areas, the
           bedding areas, and the  crushing plant are reportedly under MESA1s
           jurisdiction; yet MESA  has never inspected them1, probably because
           there is no mine at the site.  OSHA did  not toilich these areas during
           its two inspections.
    Comments:
I.   COMPANY SAFETY AND HEALTH ACTIVITIES

    A)  Staff

       1)  Environmental and Industrial Hygiene

               Since late 1976, El Paso has had a resident environmental scien-
               tist who performs duties related to both occupational health and
               air pollution.
       2)  Safety

               a)  Program is directed by a Personnel and Safety Director who
                   devotes approximately 40% of his time to safety matters.

               b)  In addition, the company reports another full-time employee
                   in the safety program.  ("Safety Officer")

    B)  Respirator Program

       1)  Training, education and supervision is the responsibility of
           smelter's environmental scientist.

       2)  Storage and facilities for daily cleaning are provided.   Workmen
           turn in their respirators at the end of each shift and a full-time
           employee is in charge of daily maintenance.

    C)  Industrial Hygiene

       1)  Yearly sampling of some areas and work stations for S0~ and arsenic
           since before OSHA.  Extent of yearly monitoring increased signifi-
           cantly in 1976, with more personal sampling carried out.

       2)  No monitoring conducted in areas under MESA jurisdiction.

       3)  Ventilation systems are checked "as needed" by department superin-
           tendents .

       4)  No formal reports or education are given to the workmen regarding
           the need,  objectives and results of air monitoring.

-------
                                                                     [page 6]
    5)  The company has provided a substantial amount of industrial hygiene-
        related data to OSHA in the course of the arsenjic and sulfur dioxide
        hearings.   No data is routinely exchanged with/the union.
                                                       ''\
D)  Safety Activities                                  j'
    1)  Plant safety staff conducts regular safety inspections.  No check-
        list is used but written reports are prepared.
    2)  Plant safety staff conducts investigations of accidents and near
        misses with written reports.  Labor is not invited jbo participate in
        accident investigations.
    3)  Company reported to NIOSH in 1972 that corporate safety engineer
        services were provided to the plant 8 hours/month.  INFORM has not
        determined whether this arrangement still exists.
    4)  There are no formal safety training procedures'for new employees.
        Foremen and fellow employees introduce new employees to area haz-
        ards .                                         i

    5)  Initial safety training is provided to new foremen.
    6)  Refresher safety training is provided to supervisors.
    7)  Monthly departmental safety meetings take place under the direction
        of foremen.                                      i
    8)  Monthly safety meeting is conducted by the safety officer with two
        representatives from each department.
    9)  Safety training for new equipment and changed processes is provided.
   10)  Company reports that certain "informal studies" have been conducted
        to investigate the relationship of accidents to plant areas, worker
        seniority, overtime, and different shifts.  Written findings of
        these studies are not available.

   11)  There has  been no study of cost-benefit considerations in relation
        to the safety program or related matters.

   12)  Safety statistics (frequency rates)  are kept according to the tradi-
        tional system of the National Safety Council.  Data available to
        INFORM for years 1972 to 1976.

   13)  Company reports that information exchange regarding safety issues
        takes place in a formal way within the company.
   14)  OSHA 102 data available for 1973, 1975, and 1976.

   15)  INFORM has calculated incidence rates for 1973, 1975,  and 1976,
        according to OSHA methods.

E)  Health Care

    1)  Smelter uses local health care  facilities for major health services,
        including emergency care.
    2)  Plant clinic is staffed by a full-time nurse and a practical nurse
        as well as physicians on a part-time basis (12 hours/week).

    3)  In excess  of 100 employees are  trained in first aid, with the empha-
        sis on foremen.

-------
                                                                        [page 7]
        4)   There is a fairly comprehensive system of pre-p! lacement and periodic
            health monitoring, including general exams, audiometric tests, blood
            tests, x-rays, and pulmonary function tests.   i|

        5)   Company estimates the  cost of its medical prog'ram at $60,000 per
            year (personnel, testing and equipment).
    Comments:
:V.  SAFETY COMMITTEE
                                                            I
    A)  According to the company questionnaire responses,  nofjoint safety and
        health committe exists at El Paso.

    B)  Contract language specifies a joint safety and health committee with
        three employee representatives and specific functions (monthly meetings,
        safety inspections,  paid time).

    Cl  Union reports a joint safety committee with three  union representatives.
        Committee meets monthly to discuss  safety matters.   It also conducts
        inspections of different departments each month with subsequent discus-
        sion and write-up of recommendations for the supervisory personnel in
        the area inspected.   The committee  does not address health issues, and
        the smelter's environmental scientist does not take part in its activi
        ties.

    D)  The Safety and Health provisions of the contract address other matters,
        such as:
        1)   Right to refuse  unsafe work.  Reports to INFORM indicate that no
            such instances have required arbitration.
        2)   Right of joint committee members to review monitoring records
            "required by the Department  of Labor."  Individual workers do not
            have the right to review their  own monitoring results.

        3)   Right of international union representatives to enter the plant for
            safety and health issues.  The  right to enter depends on the plant
            manager's permission,  and INFORM is not aware  of any instances where
            the union has requested entrance.

    Comments:

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                                                                        [page  8]
/.  REGULATORY HISTORY

   A)  Pre-1970

       As far as INFORM could determine, no state regulatory agency ever  car-
       ried out any inspection activity in the El Paso smelter.  The State
       Health Department, under the "Texas Occupational Safety Act" of  1967,
       had safety and health jurisdiction.

   B)  Post-1970

       1)  Texas made relatively feeble attempts to develop a state OSHA  plan.
           Consequently, the state continued to play little or no role  in rela-
           tion to the smelter after 1970.
2)

3)

OSHA Activities
a)
Other
a)
Three inspections. One safety.

MESA reportedly has jurisdiction
ing, receiving and bedding areas.
been conducted by MESA.
Two hpalth. (See Table 3.
1
over the sampling, crush-
No inspection has ever
)


   Comments :

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Table  1
PROCESS  EQUIPMENT--E1 Paso,  Texas
NAME
AGE
POLLUTION CONTROLS
Coarse and Fine Crushing
Bedding Bins
Wedge Roasters (4)
Some water sprays
None
Spray chamber -*• ESP
(joined, with reverb off gases) -*•
1921 stack
Reverb Furnace
   Sprung Arch
   Wagstaff gun feed on sides
1913
2 WHB + spray chamber
  ESP -> s|tack
Reverb Holding Furnace
Converters
1 § 2
3
Two cranes in aisle
Anode Furnaces (2)
1970 ,

1916 2 WHB ->• spray chamber
1937 ->- ESP -> acid plant

1916
Casting Wheel (1)

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Table 2
SUMMARY OF HEALTH HAZARDS--E1 Paso, Texas
TWA
Number of
PLANT AREA Employees
Receiving and
Beading Areas
Roasters


Reverberatory Area
Converter Aisle
Anode Casting
-- 	 4-5 -
18


27
33
15-20
TWA Exposures in mg/M^
Copper
-






Arsenic
.06—-
.01-. 05


.10-. 15
.01-. 05
.01-. 05
Lead

.02<


.01-. 10
.10-. 18
.04
Sulfur
Dioxide
fppml NOTES

0.3-6


1-50*
0.3-8.4



*Area samples.
Average S02 exposure on charge deck is
9-10 ppm.
Larryman exposure to S09 is 23 ppm.
Converter punchers and skimmers are
exposed to noise in excess of standard.

SOURCES:  1)  Company testimony at the OSHA arsenic and sulfur dioxide hearings
          2)  NIOSH industrial hygiene survey, April, 1972

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Table 3
OSHA INSPECTIONS--E1 Paso, Texas
DATE
TYPE
FINDINGS
PENALTIES   FOLLOW UP
              COMMENTS
1/14/74
General Schedule
Health
No violations
  None
None
Sampling for Pb, Cd, S02.   Mostly
in lead circuit.  Many excessive
exposures found, but not cited
because protective equipment was
judged adequate protection by
OSHA.
1/24-27/77
General Schedule
Safety
2 Citations
one serious
one nonserious
63 items
  4245      None yet      Diverse safety items.
                          Contested.   Settlement agreed upon.
1/25/77 -
   4/20/77
General Schedule
Health
1 Citation
nonserious
5 items
  None      None yet      Pb,  Cd,  As problems.   Mostly in
                          lead circuit.
                          Noise in copper converter area
                          lunchroom facilities.
                          Citation in contest.

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FACT SHEET

FACILITY:  Hayden Smelter

CCMPANY:  ASARCO, Inc.
                                                          INFORM
                                                          25  Broad  Street
                                                          New York,  New York
                                                          10004

                                                          (212)  425-3550

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                                                                            page 1
   GENERAL

   Name:  ASARCO
   Location:   Hayden,  Arizona
   Description:

       1)   Custom smelter,  no concentrator facilities.

       2)
                                                 Smelter built 1912.
    Ore comes from three ASARCO mines in Arizona, from independent Ari
    zona mines,  and Speiss from ASARCO--E1 Paso.  Arsenic content esti
    mated variously as 0.005% and 0.04 to 0.1%.  Other trace metal
    information on hand.
3)  450-500 production and maintenance employees.  65-70 administrative.
4)  In 1974, $6.5 million in payroll and $1.98 million in taxes.
5)  Production
                                            Second only to Kennecott's
             a)  ASARCO's  largest  copper producer.
                Garfield,  Utah operation.
             b)
                           1972
1973
1974
1975
1976
Blister Copper
Anode Copper
Sulfuric Acid
160,000


147,000


129,000
43,844
130,420
105,000
101,396
92,157
102,000


    Comments:
[.  .PROCESS AND HAZARDS--SMELTER

   NOTE:  In most areas of the plant, workmen wear company-supplied respirators
   on a need basis.  The following comments evaluate TWA exposures independent
   of respirator use.

   NOTE:  Throughout the following remarks, the phrase "poorly characterised"
   is used to indicate that we have found no evidence that either the company
   or the regulatory agencies have sufficiently characterized the exposures to
   permit proper evaluation and corrective action.

   A)  Sample Building.  Three men per shift.  Dust exposures despite local
       exhaust ventilation.  Likely Arsenic exposures above proposed standard.

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                                                                         page 2


    Poorly characterized.   Vacuum cleaning and wet housekeeping indicated
    but not yet adopted.

B)  Unloading of Ore.   Likely exposure above proposed Arsenic standard.
    Local exhaust and elimination of air lances indicated but not yet
    adopted.   Four men per shift.

C)  Beds.  Three men per shift.   Varying dust exposures as well as general
    area contamination.  Arsenic exposures likely above proposed standard,
    but poorly characterized.  Local exhaust at the transfer point to the
    bin-conveyor system leading to the roasters is indicated, as well as
    better enclosure of entire bedding area to prevent wind-generated dust.
    These measures not yet adopted.

D)  Roasters

    1)  22 men per shift.   Arsenic exposures two to fifty times the proposed
        standard.  Copper dust exposures slightly above present standard.
        Some lead exposure in the neighborhood of the proposed limits.   SC^
        exposures in the neighborhood of the present standard.
    2)  Dust-fume characteristics and respirability of airborne particulates
        are not well studied.

    3)  Company considers all except one of the twelve roasters to be too
        old to be repairable (for leaks).
    4)  Maintenance tasks generally in progress in one to four roasters.
        Exposures to arsenic are likely to be very high.  Poorly character-
        ized.

    5)  Hot calcine discharge point is a source of heavy arsenic, S02,  and
        dust exposures to the workmen in that area, including clean-up
        crews.  Company reports improvement of local exhaust ventilation
        system.  Effectiveness unknown.

    6)  Larrymen traveling between calcine loading and reverb feeding areas
        have the highest combined ^articulate and SO-? exposures.   Arsenic
        exposures have been reported as high as 20 times the proposed  standards,
        Company reports that more recent data indicates exposures ranging from
        4 to 5 times the proposed arsenic  standard.

    7)  Other sources of contamination are:

            a)  uncovered conveyor systems, transfer points, and bins at
                the top level of the roaster

            bj  Lack of ventilation at roaster feed stations

            c)  Use of poles to help move the hot calcine during loading

            d)  Poor maintenance on calcine hopper - larry car seal

E)  Reverberatory Furnaces

    1)  Four to five larry cars  carrying calcine to the furnaces.

    2)  Charge floors  of  the reverbs have  the highest SCL concentrations in
        the smelter,  1974  peak above 140 ppm.  1975 peak concentration  23 ppm.
        Larrymen and helpers (four per shift) are intermittently exposed.
        Arsenic exposures  20 times the proposed limits.  Larry car shakers
        produce noise exposures  twice the  allowable limits.

-------
                                                                         page 3
    3)   Two  large., rooftop fans installed to provide dilution ventilation in
        charge floor area.   Effectiveness unknown.

    4)   Feeding of furnace  with Wagstaff guns causes positive pressure
        build-up and thus fugitive emissions.
    5)   Company reported to the State Mine Inspector in 1973 on efforts to
        modify Wagstaff guns to stationary feed guns in order to avoid dust
        generated while moving them from one feed hole to another.   Success
        of efforts not known.

    6)   Matte and slag tapping and launders are hooded.  Arsenic exposures
        exceed the proposed standard.  Copper,  lead, and total dust expo-
        sures are within allowable limits.  Sulfur Dioxide exposures are
        poorly characterized.   SC^ data suggests reduction since 1975, but
        production was also substantially reduced from previous years; hence
        cause-effect is difficult to ascertain.

    7)   Slag transfer in tunnel is a source of general contamination.   Nega-
        tive pressure in tunnel is indicated but not yet adopted.
    8)   Reverb arches are "blown" with compressed air.  Source of general
        contamination.  Vacuuming tried slightly but failed.
    9)   Transfer of dust from the waste heat boilers,  using payloaders, is a
        source of high-arsenic contamination and exposure.  Poorly  charac-
        terized.  Enclosed  conveyors indicated but  not yet adopted.

   10)   Reverb maintenance  tasks are likely to result  in high dust  and
        arsenic exposures.   They are poorly characterized.

F)  Roaster  and Reverb Dust Control Equipment
    1)   7% of smelter's daily roaster input is recirculated flue dust.  Its
        arsenic content is  0.1 to 1.0%, much higher than the concentrate.

    2)   Dust exposures to the dustman and the pugmill  operator, in  the
        precipitator, are comparable to those of the larryman.  Since
        arsenic and lead content are higher, the hazard is even more serious.
    3)   Little characterization exists for exposures of other workmen (i.e.,
        precipitator operators and helpers)
    4)   Enclosed conveyor systems for dust handling are indicated but  not
        yet  adopted.

G)  Converter Aisle
    1)   Exposure to arsenic-laden dust for the personnel involved with the
        dust-control equipment is variable but  likely  to be high.   Poorly
        characterized.  Enclosed conveyor system is indicated but not  yet
        adopted.  Company reports exposures below .5 mg/m .

    2)   Skimmers (4 per shift) and cranemen (3 per  shift)  are exposed  to
        arsenic concentrations two to four times the proposed standard.

    3)   Cranemen are likely exposed to SO,, concentrations  in excess  of pro-
        posed limits  Inside the crane cabs.   TWA are poorly characterized.

    4)   Punchers are  exposed to noise levels two to four times the  allowable
        limits.   Ear  muffs  are worn.   Company reports  no efforts to silence

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                                                                         page 4
        the punching operation except "observation" of Anaconda's experi-
        ments (cab enclosures).
    5)  A 1973 fatality resulted from a converter "blow-out."  No satisfac-
        tory explanation was ever found.

H)  Anode Furnaces

    1)  Furnace burners create noise exposures one to four times the allow-
        able limits to workmen involved in casting.   Company has eliminated
        the use of one burner per furnace to reduce noise.
    2)  Mold spraying position also results in excessive noise exposure.

    3)  Potential heat exposures in casting area.  Not characterized.

Comments:
COMPANY SAFETY AND  HEALTH ACTIVITIES

A)  History--in corporate profile

B)  Staff

        Safety Director  (responds to plant manager)
        Environmental Scientist.   Sent yearly (or as needed) from corporate
        Salt  Lake City Labs to perform personal sampling and/or air pollu-
        tion tests.  His role is advisory to plant management.

C)  Yearly industrial hygiene sampling of some plant areas.  -No reports or
    education given to workmen.

D)  Respirator Program:  Full-time person devoted to maintenance and proper
    instruction of employees.  Satisfies OSHA requirements.  Fairly rigid
    enforcement of respirator-wear  requirements.

E)  Safety.  Weekly meetings in all plant areas between foremen and workmen.
    Begun as a result of 1973 fatality.  Meetings of General Superintendent
    with staff people take up safety and other matters.  OSHA 102 reports
    for 1972 through 1976 on hand.
F)  Health Care
    1)  Clinic at Hayden.  One doctor.  One nurse.  Closed weekends and
        nights, when workers must go to Kennecott's Kearny hospital.

    2)  Contract gives workers right to see own doctor.  Many take advantage
        and see physicians in Tucson.

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                                                                             page 5
        3)   Pre-employment physical and audiometric exams.
        4)   Yearly blood lead  tests for all  production workers.
        5)   Yearly audiometric tests for all noise-exposed Corkers.  Referrals
            if needed.
    Comments:
 V.   SAFETY COMMITTEE
     A)  Description
        1)  Begun in 1971 contract.
        2)  Modified in 1974
        3)  Two USW representatives, 2  IBEW; and two company1.
        4)  Monthly tour and discussion.  Written reports !to participants.
        5)  Mostly visible safety  focus, but union has often brought up matters
            of health concern.
     Comments:
/.   REGULATORY HISTORY
    A)  Pre-1970
       1)  Office of State Mine  Inspector
    B)  Post-1970
       1)  State OSI1A Plan
               a)  Developmental.  Headed by Arizona  Industrial  Commission.
                   Approved  10/74.
               b)  Jurisdiction  over  smelters  still in  hands  of  State  Mine
                   Inspector.

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                                                                         page  6
    2)   Office  of State  Mine  Inspector
            a)   No contractual  relationship exists  with! Arizona In-
                dustrial Commission.
            b)   Approximately two inspections  per year in 1972; five
                per year in 1976.  See  Table 3.
            cj   Limited  industrial hygiene efforts.
C)  OSHA Activities
    1)   Three inspections.  None complete.   See  Table 3.
Comments:

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NAME
     AGE
POLLUTION CONTROLS
COMMENTS
Roasters 1-8  (McDouglas)
Roasters 9-11  (Herreshoff)
Roaster 12 (Bartlett-Snow-
                  Pacific)
     1911-1969
Settling chamber and Cottrell
precipitator shared with
reverberatory furnace.
6 to 10 operating.
Reverb. #2
Reverb. #4



Converter
Converter
Converter
Converter
Converter
1942
1968



1949
1965
1968
1975

4 waste heat boilers.
Spray chamber.
Settling chamber and Cottrell
precipitator shared with
roasters .
Water-cooled hoods.
Cyclones, spray chambers,
scrubbing towers, mist
precipitator, ESP


2 Anode Furnaces
                                1974
2 Anode Casting Wheels
     1974
Acid Plant
(single contact)
1968-1971
           ''Process  flowsheet,  Figures  2,  4;  Design  and Operating Parameters  for  Emission  Control
           Studies:  ASARCO, Hayden, Copper  Smelter.
                                                                                                             OP
                                                                                                             0>

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PLANT AREA
Unloading, Sampling,
Bedding
Roaster Department
Reverberatory
Furnace Department
Converter Department
Anode Casting
Plant
Acid Plant
Number of
Employees
10
36
54
42
34
12
Copper
2.9-7.0
0.25-7.82
0.24-3.87
0.02-0.68


Arsenic

0.01-0. 34
0.03-0. 36
0.003-O.Q2


-Lead
0.07-0.15
0.006-0.18
0.02-0.21
0.006-0.09


uioxxde
(ppm)

0-732
0-700



NOTES'



Noise exposures to
skimmers are up to 5
times the standard


* Independent of respirator usage.
Sources:  Company Data.
          OSHA Inspection records.
          Office of State Mine Inspector.  Inspection records.
          Feasibility Document--David Burton Associates, 1975.
          NIOSH Study, 1972.
                                                                                                               fo
                                                                                                               era
                                                                                                               oo

-------
  Inspections--ASARCO,  Hayden
                                                                              page 9
ME
13/73
10/75
16/75
TYPE
fatality
accident
complaint
FINDINGS
In Compliance
In Compliance
In Compliance
PENALTIES
NONE
NONE
NONE
FOLLOW-iUP
Recommended
i
Not Recommended
Not Recommended
COMMENTS
#3 converter blow
Waste heat boiler
pipe rupture
Alleged personal
harassment
zona  State Mine  Inspector--Inspections—ASARCO, Hayden
ATE
31/71
71/72
12/72
'26/73
79/73
'13/73
i/6/74
'17/74
1/4/75
2/4/75
TYPE
health
health
safety
health
safety
fatality
safety
safety
safety
health
FINDINGS
7 S02 samples
9 dust counts
7 S02 samples
9 dust counts
7 violations
9 S02 samples
9 dust counts
9 violations
In compliance
1 violation
8 violations
9 violations
8 S02 samples
9 dust counts
PENALTIES










FOLLOW-UP
NONE
NONE
Co. abatement
letter
Co. abatement
letter
Co. abatement
letter
NONE
NONE
8 notices
abated 2/4/75
NONE
NONE
COMMENTS
Grab area samples
Grab area samples

Grab area samples

#3 converter blow
acid plant


Grab area samples
                                       (aj

-------
ona State  Mine Inspector—cent'd)
                                                                            page 10
•E
1/75
'/75
'76-
1/76
/76-
2/76
6/76
/76-
0/76
TYPE
safety
safety
safety
health
complaint
safety &
toxic gas
FINDINGS
19 violations
24 violations
11 violations
14 SC>2 samples
10 dust counts

4 SCL samples
30 safety
violations
PENALTIES






FOLLOW-UP
1
Abatement :
letter andi memo
i.
24 violations
abated 4/22/76
11 violations,
abated 6/1/76J
1
NONE
{
, 1
abatecl
I
NON'E
COMMENTS



Grab area samples
#4 crane cab

                                     (b)

-------
FACT SHEET

Facility:   Tacoma Smelter

Company:    ASARCO, Inc.
                                                       INFORM
                                                       25 Broad Street
                                                       New York, New York
                                                       10004
                                                       (212)  425-3550

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 I.  GENERAL
    Name:  ASARCO, Tacoma, Copper Smelter

    Location:  Tacoma, Washington

    Descripton:

        1)  Combination of concentrate receiving facilities, coarse ore and
            concentrate  handling and crushing facilities, roasters (10),
            reverberatory furnaces (2), converters (4), anode furnaces (3),
            and supportive facilities.  The complex also has refinery
            facilities for producing arsenic trioxide, dore, metallic arsenic,
            nickel sulfate, and sodium selenite products, as well as electro-
            lytically refined copper.

        2)  "Smelter began operation in 1890; purchased by ASARCO in 1905.
        3)  Employees:  822 (approximately 300 smelter production)

        4)  Tacoma is a custom smelter, where concentrates are treated under
            contractual agreement.  Concentrates from Philippines (Lepanto),
            Vancouver, British Columbia (Similkameen), and Arizona (Sierrita
            and Mineral Park).

        5)  ASARCO a major contributor to the economy of the surrounding area.

        6)  Production:
                                             1974
1975
1976
Copper (tons)
Arsenic Trioxide (tons)
Nickel Sulfate (tons)
Sulfuric Acid (tons)
Sulfur Dioxide (tons)
Metallic Arsenic (Ibs.)
Gold (ozs.)
Silver (Ozs.)
117,381
9,646
863
47,657
20,360
96,562
120,484
776,289
119,670
10,518
943
52,895
42,290
320,616
127,385
786,789
87,699
9,835
695
46,509
47,2,81
508,000
N/A
N/A
Comments:

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                                                                       rage
IT.  PROCESS AND HAZARDS

    NOTE:  Respirators are  company-supplied  and worker maintained.  They  are
           worn on a need basis.  The following comments evaluate TWA
           exposures independent of respirator usage.

    NOTE:  Throughout the following remarks, the phrase "poorly characterized"
           is used to indicate that we have  found no evidence that either the
           company or the regulatory agencies have sufficiently characterized
           the exposures to permit proper evaluation and corrective action.

    A)  Material Handling
        1)  Concentrates are  received by ship at the South Dock where they are
            are unloaded by crane.  A crane  hopper - conveyor belt system
            transports these  materials to the Martin Mill.  Significant air-
            borne dusts are generated during the unloading operations and by
            the conveyor belt.  Arsenic exposures above the proposed standard.
            Other dust exposures are poorly  characterized.

        2)  Martin Mill.  Concentrates are received, split, and sampled prior
            to roasting.  Dusts are generated from the belts, transfer points,
            sampling points,  and the multiple bins.  Arsenic exposures are above
            the proposed standard.  A wet collector dust control system is
            presently  in use, but  is reported inadequate to reduce arsenic levels to
            meet proposed standard.  Other exposures,  if any, are poorly  characterized

        3)  Crushing Area.  A jaw  crusher is used to crush and screen concentrates
            that are too large, so that they are ameneable to roasting.  Arsenic
            levels above the  proposed standard.  The crusher building is  equipped
            with dust  control (rotoclone collectors) but system is reported inadequate
            to reduce  arsenic levels below .10 mg/m3.  Other exposures, if any, are
            poorly characterized.
        4)  Fine Ore Storage.  The concentrates, along with other raw materials
            (silica and lime  fluxes) are stored in bunkers in the Fine Ore Shed.
            The materials are mixed and moved by clamshell and crawler crane and
            tripper belt, and finally transfered to the Roasters via a conveyor
            system.  Railroad cars, loaded with concentrates, are also unloaded
            in this area.   This building is  wide open  and a source of airborne
            arsenic to other  plant operations.  The principles of exhaust
            ventilation cannot be  applied to this area without enclosing  the
            entire building.  The  two cranes and the two operator stations are
            not presently enclosed.  Arsenic levels are above the proposed
            standard.  Other  exposures are poorly characterized.

        5)  South Dump.  Silica and lime fluxes are received and stored in
            this area prior to mixing with concentrates in the Fine Ore Shed.
            These materials are transfered by the yard personnel.  Exposures,
            if any, are unknown.

    B)  Roaster Area
        1)  Ten Multi-hearth  Roasters.  There are usually four Roasters operating
            at one time.

-------
                                                               Page  3
2)  Roaster feed materials are transfered from the Fine Ore Shed via
    an overhead conveyor system.  The system consists of the conveyor,
    tripper belts, and storage bins.  The belt tripper, transfer points,
    and the uncovered storage bins are major dust sources.  Exposures
    are uncharacterized.

3)  Operating decks.

    a)  Exposures from dusts generated during feeding operations and
        from intermittent "puffs" during roasting operations.  Puffs
        are due to draft reduction by the ESP operator to maximize dust
        recovery or due to failure of the automatic draft control to
        respond to changing requirements.  S02 leaks through upper
        hearth, refractory doors, and around doors.
    b)  Feedermen.  Feeds the Roaster at the upper levels.  Uses air
        lance to blow hoppers, also shovels feed and performs other
        cleaning tasks.  Exposed to arsenic levels above the proposed
        standard.  S02 levels are poorly characterized.

    c)  Beltmen.  5-6 men make up a "belt crew"  Crew brings feed to
        hoppers during a belt run.  Workers exposed to arsenic levels
        above the proposed standard.  S02 levels are poorly characterized.
4)  Unloading areas.
    a)  Calcines are discharged at 900° F. into larry cars.  The number of
        loads vary.  During normal operating conditions eight loads per hour
        are collected and transfered to the Reverb.
    b)  During normal operations there are usually -2 larry car operators
        and 1 relief man.  Arsenic exposures documented in a range greater
        than ten times the present standard.  Copper dust exposures at
        five times the standard.  S02 levels eight times the proposed
        standard.  Lead levels at five times the proposed standard.
        Total particulate levels documented at five times the nuisance
        dust standard.
    c)  Larry cars presently covered during transit, however seals are not
        adequate to stop leakage.
    d)  Larry car operator exposures occur both in the Roaster area and
        above the Reverbs while feeding calcines.
    e)  Company proposes to enclose the larry car loading area to capture
        fugitive emissions that escape during loading operations.

5)  Firemen.  Operator of the Roaster.  Controls the gas burners during
    roasting.  Exposed to arsenic levels above the proposed standard.
    Other exposures are poorly characterized.
6)  Flue dust pullers.  The roaster flue is cleaned out daily by emptying
    the hoppers and loading the dusts into a  dust  car.  Arsenic levels
    five times the present standard.  Total particulate levels exceed
    the standard for nuisance dusts.  Conditions and job will be eliminated
    once the new baghouse is put on stream.

-------
                                                                  rage
C)  Reverberatory Area.

    1)   One suspended silica arch furnace and one suspended arch basic
        brick furnace.

    2)   Reverb feed deck.

        a)  Larry car men.  Exposures discussed in Roaster Area section.

        b)  Feed floor clean-up crew.  Exposures similiar to larry car
            operators.  Clean-up performed on an "as needed" basis.

    3)   Furnacemen.  Controls Reverb's burners.  Arsenic levels above the
        proposed standard.  Noise levels exceed the present standard.

    4)   Tapper and Tapper Helper.  The matte tap hole, the matte runner,
        and the ladle charging station are presently hooded and exhausted.
        Company reports that emissions (from this source) are normally
        controlled, however, strong winds blowing through the building
        cause S02 to escape from these ventilating systems.  After ladles
        of matte are poured, they are left smoking - also contributing to
        background S02 levels.  Company proposes placing ladles under a
        hood, but such a practice has yet to be established.  Arsenic levels
        exceed the proposed standard.  Noise levels exceed the present
        standard.

    5)   Skimmer and Skimmer Helper.  The slag tap hole and the slag runner  is
        hooded and exhausted.  The effectiveness of this control equipment
        diminishes as slag skimming operations continue.  During the filling
        of slag train cars, the filled cars continue to fume while the train
        changes position to fill subsequent cars. Arsenic levels at the present
        standard.  Lead levels above the proposed standard.

    6)   Company reports that the skimmer, the tapper, and their respective
        helpers are exposed to severe heat during skimming and tapping
        operations.
    7)   Arch is blown once a week during the grave-yard shift.  Company
        unsuccessfully attempted vacuuming.

    8)   Waste Heat Boilers
        a)  Dusts entrained in the Reverb off-gases build up in the boiler
            and must be frequently removed by air lancing.  Dusts settle  to
            bottom and removed via screw conveyor system.  Conveyor must  be
            cleaned out manually due to jams caused by fused chunks of ash.

        b)  The boiler lancer is exposed to arsenic levels above the present
            standard.  Lead levels above the present standard.

        c)  Exposures to other Waste Heat Boiler employees are poorly
            characterized, however the company reports these employees are
            exposed to area arsenic levels in the 1.0 - 2.0 mg/m3 range.

D)  Converter Area
    1)   Four Fierce-Smith Converters with primary water cooled hoods.  Three
        are usually running at any one time with blowing limited to no more
        than two at any one time.

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                                                                 Page 5
    2)  Usual practice is to keep a Converter, not immediately required
        for production, hot by use of a burner through the burner mouth.
        This practice results in S02 release into the work environment
        due to the oxidation of sulfur from the charge remaining in the
        Converter.

    3)  Cranemen.  Crane cabs (2) are not enclosed.  Cranemen are exposed
        to arsenic levels above the proposed standard.  S02 levels are above
        the present standard.  Lead levels are above the present standard.

    4)  Skimmers.  Skimmer shacks are not enclosed.  The skimmers are
        exposed to arsenic levels above the proposed standard.  Lead levels
        are above the present standard.  Noise levels exceed the present
        standard.

    5)  Punchers.  Exposures to arsenic above the proposed standard.  Lead
        levels above the proposed standard.  Noise levels exceed the present
        standard.  Company attempted to abate noise exposures by enclosing
        and insulating punching platforms.  Company presently studying
        feasibility of of installing tuyere silencers.

        a)  Head puncher.  Rolls converter and operate automatic punchers
            on Converters #1, #2, and #4.

        b)  Tail puncher.  Punches Converter #3 manually.

    6)  Exposures to other Converter workers are poorly characterized.

E)  Anode Area.

    1)  Three Anode Furnaces and three Casting Wheels.  #3 Anode is normally
        in use.

    2)  Blister copper is transfered via converter crane to the Anode
        Furnace where a final blow and subsequent deoxidation, using 20
        foot logs, takes place.   Anodes are'poured in the Casting Wheel
        and after cooled with water sprays, are transported to the refinery.

    3)  Company states that many of the jobs in this area, notably the
        wheelmen and anode tapper, are very hot, physically demanding, and
        among the most hazardous in the smelter.  Personal sampling results
        for Anode workers were not available to INFORM.   Background arsenic
        levels reportedly ablove the proposed standard.

    4)  Noise levels have been reduce by burner and water spray alterations
        after being cited by WISHA.
    5)  Company is also planning to capture Anode emissions  and send
        gases to the #2 ESP.

F)  Cottrell Department.

    1)  Three ESP's are used for brick flues #1 and #2 to collect particulates
        before the gases are emitted from the main stack.  The two ESP's in
        the #1 flue generally treat the Roaster off-gases and the single
        ESP in the #2 flue treats the Reverberatory off-gases.

    2)  The dust puller is exposed to arsenic levels above the present
        standard.  Lead exposures above the proposed standard.

    3)  The treatermen are exposed to arsenic levels above the proposed
        standard.

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                                                                     Page  6
   G)  DMA  (Liquid  S02)  Plant.

       1)   The DMA  Plant processes  a portion  of the  converter  off-gases. The
            system uses  dimethylaniline  to  absorb the gaseous S02  which  is
            then  regenerated  by stripping with steam  - producing  100%  S02 as
            a  gas.   The  S02 is liquified by compression and  stored under pressure.
       2)   Union complained  to WISHA about conditions in  the DMA  Plant, resulting
            in inspections.   One  inspection documented arsenic  levels  above the
            present  standard,  lead  levels above the present  standard,  and S02
            levels five  times  the present standard.   No violations were  found
            during the other  inspection, however five repair-crew  men  became
            ill from effects  of unidentified chemical  exposure.

       3)   Leaks from the poorly sealed DMA Plant cause high S02  levels in
            other areas  of the smelter complex.

   H)  Acid Plant

       1)   The single contact acid  plant,  originally designed  in  1950 for
            100 TPD  production, was  recently enlarged to a 200  TPD Plant.

       2)   Exposures and job descriptions  for workers in  this  area were not
            available to INFORM.
Comments:

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                                                                       Page 7
I.   COMPANY SAFETY AND HEALTH ACTIVITIES

    A)  History

       1)  Department of  Industrial  Hygiene  was  established  in  1945  at  the
           corporate  level.  In  1966 this  department  combined with ASARCO's
           Department of  Agricultural  Research to  form  the Department of
           Environmental  Sciences.   In 1975  an industrial hygienist  was
           assigned to  Tacoma  on a  full-time basis.

       2)  History of ASARCO's Safety  Program not  available  tb  INFORM.

    B)  Staff

       1)  Safety Director  (50%  of  time  devoted  to safety matters)

       2)  Safety Superintendent

       3)  Safety Engineer

       4)  Industrial Hygienist

       5)  Environmental  Scientist  (operator of  Intermittent Control System)

    C)  Respirator Program

       1)  Training,  education,  and  supervision  of respirator usage  is the
           responsibility of the industrial  hygienist.    j

       2)  All workers  are  assigned  and  fitted with their own respirators
           according  to the hazards  present  in their  wor!k area.  Respirators
           worn on an "as needed" basis. Workers are  responsible for cleaning
           and maintenance.

    D)  Industrial Hygiene Activities

       1)  Annual sampling  of  areas  and  personnel  by  corporate personnel prior
           to OSHA.   Extent of monitoring  increased with the assignment of
           industrial hygienist.

       2)  Annual monitoring results are compiled  in  a  final survey  report.  ASARCO
           would not  provide INFORM  with copies  of these materials.

       3)  Ventilation  systems are checked  by the mechanical superintendent
           on an "as  needed" basis.

       4)  No formal  reports or  education  are given to workers regarding the
           need, objectives, and results of  industrial hygiene sampling.  However,
           during a pre-employment indoctrination, the company informs workers
           of hazards they will  possibly encounter while on the job.

       5)  The company  has provided  a  substantial  amount of industrial hygiene
           related data to OSHA  during the course  of  the arsenic and sulfur
           dioxide hearings.  The bulk of  this material was related specifically
           to Tacoma.    The company provides  the Union with monitoring results.

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                                                                    Page  8
E)  Safety Activities

    1)  Plant safety engineer conducts a monthly inspection of the
        plant.  No checklists are used except during Crane
        inspections.  In all cases, written reports are prepared
        and a copy is forwarded to the Union.        "

    2)  Accident investigations, for all lost-time accidents, compensated
        accidents, and some near misses, are conducted jointly by the
        Company and the Union.   Written reports, which establish cause,
        place responsibility, and make recommendations, arb prepared at
        the conclusion of accident investigations.        !

    3)  New employees are instructed as to the safety'aspects, the associated
        hazards, and the proper safety practices of their particular job.
        The indoctrination includes a tour of the smelter.

    4)  Formal  safety refresher courses for all emplbyees are not available,
        however, safety awareness is mainteined by way of safety committees.

            a)  Foremen Safety Committee   includes a|ll formen and meets
                weekly.                               :

            b)  Worker Safety Committee   includes a representative from
                each department and a management representative,  meets
                monthly.                               '

            c)  These committees' activities are independent of the Joint
                Safety and Health Committee.

    5)  Safety training for new equipment and process; changes is  provided.

    6)  OSHA 102 data is available for 1973, 1974, 1975,  and 1976.

    7]  Accident frequency rates, computed according to the traditional
        system of the National  Safety Council, are available for  1972 -
        1976.
    8)  Company reports  that information exchange regarding safety issues
        takes place in a formal way within the company.

    9)  Company reported that a study to determine the relationship of accidents
        between new and old workers was performed at Tacoma.  Written findings of
        this study were not made available to INFORM.

   10)  Company reports  that it has never conducted any studies to estimate
        the indirect costs of smelter accidents.

F)  Health Care
    1)  Smelter complex  has its own on-site medical clinic with facilities
        and staff to perform preventive testing and first aid care.

            a)  Staff:   1 part-time physician (3 days  a week), 1  full-time
                        nurse,  and 1 secretary.

            b)  Facilities:  comprised of a waiting room, a dispensary  and
                             a 2-bed ward and equipped with an EKG, oxygen
                             facilities, audiometry and eye-testing equipment,
                             and an X-ray machine (used only for accident
                             diagnosis,e.g. fractures).

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                                                                        Page 9
        2)  All major  injuries/illnesses  .occurring in the smelter are  referred
            to one of  three neighboring hospitals    the  closest being  five
            miles away.
                                                          l|
        3)  Smelter does not have  an  on-site  ambulance,  readily available
            emergency  transportation  is provided by the  Tacoma Fire Department.

        4)  There is a fairly  comprehensive system of pre-placement and periodic
            health monitoring,  including:  general  exams,  audiometric tests,
            blood and  urine analyses,  and pulmonary function  tests.  Frequency
            of blood analyses  (lead)  and  urine  analyses  (arsenic)  is determined
            through industrial  hygiene department's monitoring' results.
        5)  Epidemiological and research  studies,  through1contract or  through
            its own medical department, have  been  conducted and were available
            to INFORM.                                    '
 Comments:
IV.   SAFETY AND HEALTH COMMITTEE
     A)  The Joint Safety  and Health Committee was  established in 1971.

     B)  Committee includes  three management  representatives and three Union
        representatives.
     C)  Meets once a month  for a full day.   Meetings begin with a tour, after-
        which there is  a  discussion on the tour  findings.  A written report,
        which includes  documentation of the  areas  visited, subjects covered,
        and recommendations made,  is prepared by the company and forwarded
        to each representative and the Union.
     D)  Other safety and  health topics may be discussed, such as any new process
        changes and/or  additions.  The Union also  uses the committee to air any
        safety and health complaints.

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                                                                       Page 10
    E)  The  Safety  and  Health  provisions  of the contract  address  other  matters,
       such as:                                          !
                                                         i
       1)   Right to  refuse  unsafe  work.   A specific grieyance  procedure
            (arbitration)  to handle disputed cases  has  been incorporated
            into the  contract.

       2)   Right of  Union to  review the  results of the company's  monitoring.

       3)   Right of  the International  to enter all areas  of the  plant  for
            safety  and  health  issues and  to review  company-projduced  materials
            regarding safety and health.                      j

    F)  Workers do  not  retain  wage  rates  if they are forced to  change jobs
       as  a result of  an  occupational  injury or illness.
Comments:
V.   REGULATORY  HISTORY

    A)   Pre-1970
        1)   Washington Department of Labor and Industries  has  juris  over
            safety matters since 1910.   Pre-OSHA safety inspections  of smelter
            were not available to INFORM.
        2)   An  Industrial  Hygiene section  was established  in 1963.   The smelter's
            first health inspection was performed in 1970  - very limited  due
            to  lack of equipment.

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                                                                       Page 11
    B) Post-1970
      1)  State OSHA  Plan  (WISHA)
          a)  Developmental  plan  approved  in  June  1973,  Allowing  the Department
              of  Labor  and  Industries  to operate under  18(b).
          bj  Developmental  steps  completed by  March  1976.   Presently  operating
              under an  operational status  agreement with OSHA.
          c)  Inspections:  See  Table 2.
      2)  OSHA Activities.
          a)  One inspection   safety.
Comments:

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PROCESS EQUIPMENT -- Tacoma
                                                      Table 1
NAME
AGE
         POLLUTION CONTROLS
                                              COMMENTS
Roasters  (10)
    Herreshoff
       (multi-hearth)
#1-6:  1915
#7-8:  1923
#9-10: 1929
         ESP #1 (Pipe ESP ->•  Plate  ESP)  -> Stack
                                              Considerable leakage through
                                              roaster and ductwork.  Roaster
                                              baghouse now under construction
Reverberatory  (Silica)
    Furnace #1
       1915
         #1 Waste heat boilers
         #2 ESP ->  stack
                                                              Not normally used.
Reverberatory  (Basic)
    Furnace #2
       1929
         #2 § #3 Waste heat boilers
         #2 ESP -v stack
                                              Reverb emissions will be
                                              treated in #1 ESP when roaster
                                              baghouse on-stream.	
Converter
    #1-3 Pierce-Smith
           13 by 30
    #4   Pierce-Smith
           11 by 26	
#1-2:
#3:
#4:
1916
1915
1968
Watercooled primary hooded -»•
multicyclone ->• ESP -*- acid plants
            OR
multicyclone -*• ESP -»- liquid S02 (DMA)  plant
Up to 3 used at one time.
Fan system to partially
capture fugitive emissions
during roll-out, venting
to ESPs.
Anode Furnace  (3)
#1-2:
#3:
1915
1936
None
Proposed capture and treatment
of anode-emissions in #2 ESP
when roaster baghouse on-stream.
Acid Plant
       1951
                                                       200 TPD
DMA Plant
       1974
Arsenic Plant
    Godfrey roasters  (6)
#1-4:
#5-6:
1913
1938
Tail gases treated in baghouse.
Presently under  variance  from
arsenic emission standards
from the tall  stack  and  low-
level sources.

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tions—Tacoma  [WISHA],  continued)


    TYPE         FINDINGS
           EMPLOYEES
PENALTIES  AFFECTED   FOLLOW-UP  COMMENTS
5


General
Schedule
Safety
2 None 4
non-serious
violations
1
Complied
i.

Test certificates
for Cranes not
displayed .
5  .Complaint
    Health
None
14
                non-serious
                violations
S02 Plant cottrells
inspected for S02,
lead,  and noise
exposures - cited for
failure to provide
engineering controls
to reduce S02 and
Lead exposures, and
for failure to provide
lockout system.
5





5


75


6




Complaint
Safety




General
Schedule
Safety
General
Schedule
Health
General
Schedule
Safety


2 serious, $400. 14
13 non-
serious, and
1 Deminimus


No 	 15
violations

No 	 1
violations

3 None 4
non-serious
violations


Complied S02 Plant - No resp-
i irator , program, No
SOP for material
handling, violations
| for brakes, derails,
i guards and sings.
	 Explosive magazine
i section.

	 Medical Clinic


None Ore Dock Cranes -
Warning signals and
rails needed , and
posting of dock's load
capacity.

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                                    TABLE 2


ECTIONS  — ASARCO,  Tacoma Smelter
ington Industrial Safety and Health Administration
    TYPE
FINDINGS
           EMPLOYEES
PENALTIES  AFFECTED   FOLLOW-UP  COMMENTS
General
Schedule
Safety
Accident
'73 General
Schedule
Safety
4 Accident
Asbestos
Survey
4 General
Schedule
Health
3 None 50
non-serious
violations
No 	
violations
1 None 4
non-serious
violation
1 serious $200. 1
violation
Consultation 	
5 $360. 927
non-serious
violations
None
I
I
Company
abatement
letter
1
None.
Company
abatement
letter^
|

Dock Area
Inspection.
Runaway in Anode //
No injuries.
No fire extinguisher
in Office.
Systemic blood
poisoning - AsH^
inhalation - Nickel
Plant employee.
Evaluation -of Asbestos
exposures
Failure to provide
engineering or
administrative con-
                                                                trol of exposures to:
                                                                1) LEAD
                                                                2) ARSENIC
                                                                3) SULFUR DIOXIDE
                                                                4) NOISE
                                                                Failure to provide and
                                                                use respirators for
                                                                protection from ex-
                                                                posure to LEAD.
    General
    Schedule
    Safety
No
violations
           10
           Locomotive crane
           inspection.
    General
    Schedule
    Safety
No
violations
           10
           Crane inspection.
    Complaint
    Health
No
violations
                                 Liquid Sulfur Dioxide
                                 Plant inspection.
    General
    Schedule
    Safety
               None
           20
None
non-serious
violations
Labeling and warning
devices needed for
Cranes.

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                                                  Table 3
SUMMARY OF HEALTH HAZARDS--Tacoma, Washington
PLANT AREA
Material
Handling
Roaster Area
Reverberator/ Area
Converter Area
Anode Area
Number of
Employees
60
48
53
38
37
TWA Exposures in mg/m3
Copper

.1-5.3
.8
<.2

Arsenic

.2-6.7
.02-. 5
.1-.3
	
Lead

.01-2.20
.05-. 46
.01-. 36

TWA
Sulfur
Dioxide
(ppm)





NOTES

Tappers and furnacemen are exposed
to noise in excess of standard.
Larrymen exposure to SOz is > 17 ppm.
Converter punchers and skimmers are
exposed to noise in excess of standard.

SOURCES:  1)  Company testimony at the OSHA Arsenic and Sulfur Dioxide Hearings
          2)  WISHA health inspections

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FACT SHEET

Facility:   Copperhill Operations (copper smelter)

Company:   Cities Service Company
                                                       INFORM
                                                       25 Broad Street
                                                       New York, New York
                                                       10004

                                                       (212) 425-3550

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GENERAL

Name:  Copperhill Operations, Cities Service Company
Location:  Copperhill, Tennessee

Description:

    1)  Fully integrated chemical and metal producing complex including:
        mine, mill, copper smelter, iron roasters, power plant, copper sul-
        fate and fungicide plant, acid plants, organic chemical plant, pel-
        letizing plant, recovery plant, ferri-floc plant ar(d liquid sulfur
        dioxide facility.                                  j

    2)  Mine begun 1850; smelter, early 1900s.        ;
    3)  Employees approximately 2,000 with 250 to 300 in copper production.
                                                      i
    4)  Ore from the Ducktown converted underground mijne.  Exect arsenic
        content of concentrates unknown but likely nedr .003%.   Other im-
        purities if any are unknown.

    5)  Largest employer in Polk County.  Annual per qapita income for
        county--$2,642.                               ;

    6)  Production (figures in thousand tonsj
                                1976     1975     1974  !   1973     1972
Sulfuric Acid
Other indus-
trial chemicals
Copper ('+)
985.4
201.4
86.6
865.3
155.8
46.9
849.6 ;
161.4
30.6
910.0
205.5
39.6
916.3
206.3
44.9
            (+) possible inclusion of toll concentrates sold from company
                complex in Miami, Arizona.
Comments:
PROCESS AND HAZARDS--SMELTER

NOTE:  Workers in most areas are issued company-supplied respirators.  Work-
ers are responsible for maintenance and storage; however, the company has
established a number of sanitary cleaning facilities.

NOTE:  The following comments evaluate TWA exposures independent of respi-
rator use.

NOTE:  Throughout the following remarks, the phrase "poorly characterized"
is used to indicate that we have found no evidence that either the company
or the regulatory agencies have sufficiently characterized the exposures to
permit proper evaluation and corrective action.

NOTE:  The sole known evaluation by a regulatory agency of arsenic concen-
tration at the Copperhill complex was made by the Tennessee Division of

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Public Health in December of 1975.   After initial release of the data in
terms of the present arsenic standard,  the levels were(recalculated in light
of the proposed arsenic standard.   All  samples were reported well below the
proposed standard.   The areas sampled were the electrif furnace and conver-
ter areas.                                              '

A)  Material Handling

    1)  Concentrates in a moist state are transferred  from the nearby Lon-
        don Mill by open railroad cars.  Dust an intermittent problem due
        to wind.

    2)  After storage in 450-ton open bins,   flux is added to the concen-
        trate.  The mixture is conveyed uncovered to the repulping station.
        The concentrates are then res lurried with weak, acid recycled from
        the copper gas-cleaning circuit.  Dust an intermittent problem due
        to wind and spillage along conveyors, and air |lance use in bin area
        clean-up.  16 workers.

B)  Fluosolids Roaster

    1)  One 10-foot diameter slurry-fed roaster.

    2)  Slurry is gravity fed by injection nozzle in roaster dome.  The
        approximate 4/1 (concentrate to silica sand feed) ratio yields
        calcines with a 38% to 40% copper content.  The 'gases leaving the
        vessel contain 84% to 85% of the calcines.  The calcines collected
        in the cyclones are combined with roaster bedicalcines, for pro-
        cessing in the electric furnace.              ;
    3)  INFORM has found no evidence of air monitoring by either the com-
        pany or a regulatory agency in the copper roaster area.  The union
        reports an intermittent gas and dust problem throughout the system.
        Additional problems include cyclone clean-up and repair.   Actual
        exposures are uncharacterized.

C)  Electric Furnace

    1)  In 1972, the company built the first electric furnace in the U.S.

    2)  Calcines pass through "drop pipes" to one of two partially enclosed
        pinless drag chain conveyors above electric furnace.   The furnace
        is fed through charge points near electrodes.   Matte is tapped
        through exhausted tap point onto unhooded launders  and ladles.
        Slag is tapped for an hour two to three times per shift and is
        granulated for use and sale.

    3)  Arsenic and sulfur dioxide levels and exposures are poorly charac-
        terized throughout the entire electric furnace area.   Arsenic expo-
        sures were reported below proposed standard throughout area in the
        single state-conducted survey.     Company reports that forty work-
        ers in "smelter" are exposed to sulfur dioxide levels greater than
        or equal to the proposed TWA standard.

    4)  Furnace operator helper—job station is on ceiling of furnace
        measuring electrode paste and bath depth. Union reports gassy con-
        ditions.   Actual exposures  are  poorly characterized.   3 workers.

    5)  Slag tapper—job station is at  unhooded slag launders beyond ex-
        hausted tap points  near granulation pump.  Exposures, if any, in

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slag area are uncharacter!zed.  Worker also assists in matte tap-
ping.  Potential exposures during reportedly gassy tapping opera-
tion are uncharacterized.                     I
                                               i
Matte tapper -- matte launders are unhooded past tapping points.
Union reports gassy conditions.  Actual exposures are poorly char-
Rrt.ffri7.erl.  3 workers
    6)

        acterized.  3 workers.

    7)  Relief man--worker assists matte and slag tapping as well as feed
        pipe clean-out.  Union reports gassy conditions at jmatte tap and
        feed pipe clean-out locations.  Actual exposures are poorly charac-
        terized.  7 workers.

D)  Converter Aisle

    1)  Two Fierce-Smith primary hooded converters.   Only one is in use at
        a time, operating approximately ten hours per day.  Slightly more
        than 50% of the blister copper produced is used internally as cop-
        per shot in the copper sulfate plant.  The remainder is cast into
        2,500-lb. bars and shipped to a refinery.

    2)  Arsenic and sulfur dioxide levels and exposures are poorly charac-
        terized throughout the entire converter area.   A'rsenic exposures
        reported'below proposed standard in the single sftate-conducted
        survey.    Company reports forty workers in  "smelter" exposed to
        levels greater than proposed standard.   Lack of positive seal be-
        tween converter and hood makes fugitive sulfuy emissions likely.
    3)  Crane operator—continued problem with window'seals in crane cabs.
        Company repairs often but problem persists.   Actual exposures are
        poorly characterized.  3 men.

    4)  Crane chaser—union reports gassy condition  throughout converter
        area.  Actual exposures are poorly characterized.
    5)  Operator/foreman—job station is "all over the entire area," and at
        converter control platform during pouring.  Union reports gassy
        conditions throughout converter area.

    6)  Puncher--documented noise violations prior to installation of auto-
        matic punchers, effectiveness in reducing noise exposure unknown.
        Union reports high noise levels continue.  Exposures are poorly
        characterized.  6 workers.
    7)  Flue duster—worker cleans out exhaust flues and works near open
        conveyor belts.  Union reports spillage and  dust problem.  Actual
        exposures are poorly characterized.   2 workers.
    8)  Documented noise violation to puncher and workers near lunchroom
        from #2 converter blower.   Company studied possibility of enclosing
        blower; effectiveness unknown.

E)  Liquid S02 and Acid Plants
    1)  Company reports sixteen workers exposed to levels of 2ppm or
        greater in the liquid sulfur dioxide and acid plants.

    2)  State documented sulfur dioxide levels  above the existing standard
        prior to installation of new ventilation. Company reports levels
        in "compliance with 5 ppm TWA."  Actual levels are uncharacterized.

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    3)  Reported possibility of V2o5 TWA violations duUng bed replacement
        Actual exposures are uncharacterized.
Comments:
COMPANY SAFETY AND HEALTH ACTIVITIES
A)  History—Details unavailable.
B)  Staff (Safety Department)
        Director—Industrial Hygiene (1)
        Director—Safety Director (1)
        Engineers (3)
        Technical personnel (part-time)
C)  Industrial Hygiene
    1)   Industrial hygiene functions are  divided among the full-time  indus-
        trial hygienist and the safety personnel.
    2)   The  company does "occasional" evaluatory sampling for hazards.
        Exact frequency of sampling unknown.
D)  Respirator Program
    1)   Respirators  are issued on a need  basis,  based on evaluatory sam-
        pling.

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    2)   Education for use and maintenance is administered by the worker's.
        immediate supervisor.

    3)   Workers are responsible for storage and cleaning in most areas.
        The company has established some sanitary cleaning facilities.

E)  Safety

    1)   The company has no established pre-employment safety orientation
        other than safety instruction administered by experienced employ-
        ees .

    2)   Weekly departmental safety meetings were re-es'tablished in 1973.

    3)   Company issues free of charge most necessary slafety equipment in-
        cluding:   hard hats, safety shoes, fire-resistant clothes (where
        needed) and safety glasses.                   '

F)  Health Care

    1)   Cities Service Company has established a contractual-leasing rela-
        tionship with Basin General Hospital.
                                                        l
    2)   Medical program is administered by one full-time and three part-
        time physicians, as well as one nurse and several part-time techni-
        cal personnel.                                  j

    3)   First aid is administered through first-aid stations located
        throughout the complex.                       !

    4)   Company reports that pre-employment test include:  respirator com-
        patibility, chest x-rays, blood and urine analysis, audiometric and
        optometric testing, as well as history and physical.

    5)   The company in 1976 established a series of voluntary annual medi-
        cal tests.  Tests include chest x-rays and blood and urine analy-
        sis,  and audiometric and optometric testing.

Comments:
SAFETY COMMITTEE

A)   Description

    1)  Monthly meetings are attended by the safety director, three safety
        engineers,  the company industrial hygienist, and one union repre-
        sentative from each department.

-------
       2)   The committee is advisory in nature and has nojinspection powers.
       3)   The committee assists in all accident investigations.
   Comments:
f.  REGULATORY HISTORY
   A)  Pre-1970
       1)   Tennessee Industrial Hygiene Service--1937 to 1^70.
   B)  Post-1970
       1)   State OSHA Plan
               a)  State plan, approved June 29, 1973, after 15-month contract
                   period.                              ;
               b)  Originally divided between Tennessee Department of Public
                   Health and Tennessee Department of Labor; recently health
                   function (Division of Occupational and Radiological Health)
                   has been incorporated into Department of Labor.
       2)   OSHA activities
               a)  Never inspected Copperhill facilities.
               b)  Performs advisory and monitoring functions with inspection
                   jurisdiction over longshoring,  shipbuilding and railroads.
   Comments:

-------
PROCESS  EQUIPMENT--Copperhill*
                                                  Table  1
NAME
     AGE
POLLUTION CONTROLS
COMMENTS
 Fluosolids  Roaster  (1)
     1972
15TettTrc - Furnace  (1)
-— - 19-72-
Gas-es-from all furnaces are combined
and sent through a. Peabody Scrubber.
Gases are then added to iron roaster
gases and transported to the liquid
S02 and acid plants.
Converters  (3)
      (Pierce Smith)
                                                            Cylindrical  mouth
                                                            shape  prevents
                                                            tight  hood seal.
Acid Plant #4, #5
   Combined
     1975
                                         1,910 TPD
Acid Plant #6
     1975
                                         2,100 TPD
Liquid S02 Plant
                   Gases  taken  down stream of acid
                   plant  #6.
                                         On-stream factor of
                                         90% to 95%.
* Copper smelter  and  related facilities.

SOURCES:   Engineering Evaluation of Cities Service Smelter,

-------
                                    Table 2
ctions--Copperhill
ssee  Department  of  Labor
       TYPE
FINDINGS
PENALTIES   FOLLOW-UP
COMMENTS
75
75
75
complaint/
safety
complaint/
safety
complaint/
safety
no violations
1 non-serious
violation
no violations
	 	 walk area
! #4 acid
$60 	 i plant
converter
; puncher
	 	 j- blow-back
ctions--Copperhill
ssee Department of Public Health
       TYPE
FINDINGS
PENALTIES   FOLLOW-UP
COMMENTS
i/73
'4
/74
75
complaint/
health
follow-up/
health
general
schedule/
health
complaint/
health
1
15 violations $0 7/1/74
no violations 	 	
no violations 	 	
1 violation $0 	
liquid
S02 plant

arsenic
levels
noise/
converter
punchers

-------
                                                     Table 3
SUMMARY OF HEALTH HAZARDS--Copperhill
PLANT AREA
Material Handling —
Fluosolids
Roaster
Electric Furnace
Converters
Acid £ Dm plants
TWA Exposures*
Number of
Employees
16
50

27
100
Copper
mg/M3





Arsenic
mg/M3

- 	
.0001-. 0002
.0002-. 001

Lead
mg/M3





Sul fur
Dioxide
(PPM) NOTES

see noteA
see noteA
to
Roaster
see noteA
to
Roaster
see notet

AND known surveys for sulfur
dioxide by government regula-
tory agencies. Company re-
ports 40 workers in "smelter"
exposed to TWA levels of 2ppm
or greater.

Noise--documented violations
(>115 dBA) prior to installa-
tion of new punching system,
effectiveness unknown.
tDocumented levels S02 (6ppm)
prior to installation of new
ventilation in DMA plant.
Company reports 16 workers
exposed to TWA levels greater
than or equal to 2ppm.
SOURCES:  Arsenic OSHA hearing, 1975.   Company data.
          Tennessee Department of Public Health inspections,
 *Independent of respirator usage.

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FACT SHEET

Facility:   White Pine Copper Smelter

Company:   Copper Range Company
                                                        INFORM
                                                        25 Broad Street
                                                        New York, New York
                                                        10004
                                                        (212) 425-3550

-------
I.   GENERAL

    Name:  Copper  Range  Company,  White Pine Smelter
    Location:  White  Pine,  Michigan
    Description:

        1)   Combination  of  concentrate receiving and mixing facilities,  rotary
            dryer,  reverberatory  furnaces  (2),  converters (2) ,, fire-refining
            furnaces  (2), holding furnace  (1),  semi-continuous! casting machines
            (2), casting wheel  (1), and supportive facilities.1
        2)   Smelter began operation in 1955.         n    !
                        Wf>                       13n"
        3)   Employees:   %%% smelter production.   ~2-9-©0- at i the  White Pine complex
        4)   Ores from White Pine  underground mine (Nonesuph formation) are
            concentrated in the White Pine Mill, adjacent to the smelter.
            Arsenic content of the concentrates  estimated' at .003%.   Low sulfur
            content requires the  addition  of pyrite to make feed amenable to
            smelting.  Other trace material information on hand.
        5)   White  Pine is the second largest employer in Michigan's  Upper
            Peninsula.                                      j,
        6)   Production                                      ;

                .	                 1973        1974     '  ;1975         1976
                                                         !	
              Copper (tons)        78,506       66,898    ;  70,776      46,053

    Comments :
I.   PROCESS AND HAZARDS

    NOTE:  Respirators are  company-supplied  and  company-maintained.   They are
    worn on a need basis.   The  following  comments  evaluate  TWA exposures
    independent of respirator use.

    NOTE:  Throughout the following  remarks,  the phrase  "Poorly characterized"
    is used to indicate  that we have found no evidence that either the company
    or. the regulatory agencies  have  sufficiently characterized the exposures  to
    permit proper evaluation and corrective  action.

-------
                                                                       Page 2
A)  Material Handling

    1)  The smelter feed, in the form of filter cake fa copper bearing concentrate
        of -30-32% Cu and 18% H20), is received at thp Filter and Dryer Building.
        *£feejr drying in the Rotary Dryer, fluxes (limestone, pyrite, and recycle
        materials) are added to obtain good smelting characteristics.  Exposures,
        if any are uncharacterized for the Rotary Dryer Operator and the Operator's
        Helper.  Eight workers -- Company classifies these employees as Mill
        workers.

    2)  If the reverberatory furnace is being charged the dried materials are
        transfered directly to the reverberatory charge bins   If not being
        charged, the materials are transfered to the Smelter Feed and Bedding
        Building.  All concentrate transfer is by encjlosed conveyors.  Documented
        copper dust exposures for bedding plant employees.  The company proposed
        to implement certain engineering and administrative controls in this
        building.  Effectiveness of reducing hazards by this effort unknown.
        Five workers.

    3)  Other material handling workers -- the conveyormen and the conveyor
        attendants --  are potentially exposed to copper! dusts during the transfer
        of concentrates.   Documented copper dust exposures above the standard.
        The company was to abate the dusty conditions during transfer by increasing
        moisture of materials leaving the Rotary Dryer.!  Effectiveness of reducing
        dusts is unknown.  Ten Workers.

B)  Reverberatory Area

    1)  Two identical  suspended arch reverberatory furnaces.  At the present time
        only one (#1)  is  presently in operation.  The concentrate-flux mixture
        is fed from the charge bins by a tripper belt - shuttle conveyor system
        and is charged into the reverb through water cooled chutes.   Approximately
        50 workers.

    2)  Charge Floor

        a)  Tripperman.  Operation consists of charging reverberatory furnace by
            operating  mechanized conveyor to load furnace hoppers with feed.
            Loading operation takes about 2 hours,  afterwhich worker spends about
            1/2 hour  cleaning hoppers.  Documented S02 and Cu dust exposures above
            standard.   Arsenic levels above proposed standard.**  Six workers.

        b)  Arch Attendant.   Potential exposures similiar to tripperman.   Reportedly
            very high  dust exposures during blowing of arch.  Company attempted
            vacuuming, however proven unsuccessful.  Actual exposures are poorly
            characterized.  Four workers.

        c)  Brickmasons.   Replacing refactory and maintaining furnace roof.
            Documented Cu dust exposures of up to 13 times the standard.   Arsenic
            exposures  above the proposed OSHA standard.**  Potential S02 exposures
            poorly characterized.   Twelve workers.

-------
                                                                       Page 3
    3)   Operating Floor

        aj   Furnaceman.  Operator of the reverberator^ furnace.  Documented Arsenic
            exposures above the proposed standard.** ,'Potential Cu dust and S02
            exposures are poorly characterized.  Five,"workers .

        b)   Tapper and Tapper Helper.  Matte and slag tap holes are ventilated
            with hoods.  The slag launder is reportedly uncovered.  Slag and
            matte is collected in a"tunnel located beneath! the operating floor.
            Area S02 reported at >15 ppm.  Arsenic exposures at the proposed
            standard.**  Eight workers.

    4)   Others

        aj   Locomotive Engineer and Carman.   Transferj matte via electrical  ladle
            car to converter aisle and transfer slag via slag train to slag
            dump (located adjacent to the smelter).   'Workers reportedly leave
            tunnel during the filling of ladles.  Potential S02 exposures are
            poorly characterized.  Other exposures,  if any, unknown.   Six workers.

        b)   Flue Dust Man and Flue Dust Helper.  Emptying hoppers  on  ESP and
            Waste Healt Boilers, among other dust handliing system  tasks.
            Documented Cu exposures above the standard.'  Arsenic exposures  above
            the proposed standard.**  S02 exposures, -if! any, are unknown.
            Five workers.

        c)   Boiler (Waste Heat) Lancers.  Performs lancing of boiler  tubes.   Cu
            dust exposures above the standard.   Other exposures, if any, are
            poorly characterized.  These employees are assigned to the Power
            Plant -- number of boiler lancers unknown.

C)  Converter Area

    1)   Matte from the reverberatory furnace is transfered in ladles  to one of
        the two Fierce-Smith converters by an enclosed and air conditioned  over-
        head crane.   A siliceous flux is added  to the converter bath  to form
        an  iron oxide slag that is skimmed off  and returned to the reverb.   At
        the completion of the converter cycle,  blister copper is transfered to
        a holding furnace or directly to the refining area for further processing.

    2)   Crane Man.   Workers report conditions in the crane cabs to be good  and
        protective equipment (respirators)  is not required.  Three workers.

    3)   Crane Chaser.  Directs crane-man on ladle movements and other converter
        aisle tasks.  One documented Arsenic exposure above the proposed
        standard.**  Other exposures, if any, poorly characterized.  Six workers.

    4)   Skimmer.  Operator of the converter.  Some Arsenic exposures  above
        the proposed standard.  S02 and Cu dust levels below the standards.
        Three workers.

-------
GENERAL

Name:  Copper Range Company, White Pine Smelter

Location:  White Pine, Michigan

Description:

    1)  Combination of concentrate receiving and mixing facilities, rotary
        dryer, reverberatory furnaces (2), converters (2), fire-refining
        furnaces (2), holding furnace (1), semi-continuous casting machines
        (2), casting wheel  (1), and supportive facilities.
    2)  Smelter began operation in 1955.

    3)  Employees:    166 smelter production.  1279  at the White Pine complex.

    4)  Ores from White Pine underground mine (Nonesuch formation) are
        concentrated in the White Pine Mill, adjacent to the smelter.
        Arsenic content of the concentrates estimated at  .003%.  Low sulfur
        content requires the addition of pyrite to make feed amenable to
        smelting.  Other trace material information on hand.

    5)  White Pine is the second largest employer in Michigan's Upper
        Peninsula.

    6)  Production

           	1973	1974	1975	1976

           Copper (tons)       78,506      66,898      70,776      46,053

Comments:
PROCESS AND HAZARDS

NOTE:  Respirators are company-supplied and company-maintained.  They are
worn on a need basis.  The following comments evaluate TWA exposures
independent of respirator use.

NOTE:  Throughout the following remarks, the phrase "Poorly characterized"
is used to indicate that we have found no evidence that either the company
or the regulatory agencies have sufficiently characterized the exposures to
permit proper evaluation and corrective action.

-------
                                                                       Page  2
A)  Material Handling

    1)   The smelter feed, in the form of filter cake (a copper bearing concentrate
        of -30-32% Cu and 18% H20),  is received at the Filter and Dryer Building.
        Before drying in the Rotary Dryer, fluxes (limestone, pyrite, and recycle
        materials) are added to obtain good smelting characteristics.  Exposures,
        if any are uncharacterized for the Rotary Dryer Operator and the Operator's
        Helper.   Eight workers -- Company classifies these employees as Mill
        workers.

    2)   If the reverberatory furnace is being charged the dried materials are
        transfered directly to the reverberatory charge bins   If not being
        charged,  the materials are transfered to the Smelter Feed arid Bedding
        Building.  All concentrate transfer is by enclosed conveyors.  Documented
        copper dust exposures for bedding plant employees.   The company proposed
        to implement certain engineering and administrative controls in this
        building.  Effectiveness of reducing hazards by this effort  unknown.
        Five workers.

    3)   Other material handling workers -- the conveyormen and the conveyor
        attendants -- are potentially exposed to copper dusts during the transfer
        of concentrates.   Documented copper dust exposures  above the standard.
        The company was to abate the dusty conditions during transfer by increasing
        moisture  of materials leaving the Rotary Dryer.  Effectiveness of reducing
        dusts is  unknown.  Ten Workers.

B)  Reverberatory Area

    1)   Two identical suspended arch reverberatory furnaces.  At the present time
        only one  (#1) is  presently in operation.  The concentrate-flux mixture
        is fed from the charge bins  by a tripper belt - shuttle conveyor system
        and is charged into the reverb through water cooled chutes.   Approximately
        50 workers.

    2)   Charge Floor

        a)  Tripperman.   Operation consists of charging reverberatory furnace by
            operating mechanized conveyor to load furnace hoppers with feed.
            Loading operation takes  about 2 hours , afterwhich worker spends about
            1/2 hour  cleaning hoppers.  Documented  S02 and Cu dust  exposures above
            standard.  Arsenic levels above proposed standard.**  Six workers.

        b)  Arch  Attendant.  Potential exposures similiar to tripperman.   Reportedly
            very  high dust exposures during blowing  of arch.  Company attempted
            vacuuming, however proven unsuccessful.   Actual exposures are poorly
            characterized.   Four workers.

        c)  Brickmasons.   Replacing  refactory and maintaining furnace roof.
            Documented Cu dust exposures of up to 13 times  the standard.   Arsenic
            exposures above the proposed OSHA standard.**  Potential S02 exposures
            poorly characterized. Twelve workers.

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                                                                       Page  3
    3)   Operating Floor

        a)   Furnaceman.  Operator of the reverberator/ furnace.   Documented Arsenic
            exposures above the proposed standard.**  Potential  Cu dust and S02
            exposures are poorly characterized*  Five workers.

        b)   Tapper and Tapper Helper.   Matte and slag tap holes  are ventilated
            with hoods.  The slag launder is reportedly uncovered.  Slag and
            matte is collected in a"tunnel"located beneath the operating floor.
            Area S02 reported at >15 ppm.  Arsenic exposures at  the proposed
            standard.**  Eight workers.

    4)   Others

        a)   Locomotive Engineer and Carman.   Transfer matte via  electrical  ladle
            car to converter aisle and transfer slag via slag train to  slag
            dump (located adjacent to  the smelter).   Workers reportedly leave
            tunnel during the filling  of Ladles.   Potential S02  exposures are
            poorly characterized.   Other exposures,  if any, unknown.  Six workers.

        b)   Flue Dust Man and Flue Dust Helper.  Emptying hoppers  on  ESP and
            Waste Healt Boilers, among other dust handling system  tasks.
            Documented Cu. exposures above the standard.   Arsenic exposures  above
            the proposed standard.**  S02 exposures, if any, are unknown.
            Five workers.

        c)   Boiler (Waste Heat) Lancers.  Performs lancing of boiler  tubes.  Cu
            dust exposures above the standard.   Other exposures, if any,  are
            poorly characterized.   These employees are assigned  to the  Power
            Plant -- number of boiler  lancers unknown.

C)  Converter Area

    1)   Matte from the reverberatory furnace is transfered in ladles  to one  of
        the two Pierce-Smith converters by an enclosed and air conditioned  over-
        head crane.   A siliceous flux  is added to the converter  ba^th  to form
        an  iron oxide slag that is skimmed off and returned to the reverb.   At
        the completion of the converter cycle,  blister copper is transfered  to
        a holding furnace or directly  to the refining area for further  processing.

    2)   Crane Man.  Workers report conditions in the crane cabs  to be good  and
        protective equipment (respirators) is not required.  Three workers.

    3)   Crane Chaser.  Directs crane man on  ladle movements and  other converter
        aisle tasks.  One documented Arsenic exposure above the  proposed
        standard.**  Other exposures,  if any, poorly characterized.  Six workers.

    4)   Skimmer.  Operator of the converter.  Some Arsenic exposures  above
        the proposed standard.  S02 and Cu dust levels below the standards.
        Three workers.

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                                                                         Page 4
      5)   Puncher.   Punching the converters is performed manually by two workers
          using six-foot steel  rods..   Noise levels in punching area documented
          as  >105  dBA.   Punching operations are intermitj'tent and 8-hour TWA's
          are poorly characterized.   Documented Arsenic 'exposures at the
          proposed standard.  S02 exposures below the proposed standard.  Eleven
          workers.

  D)   Refining and Casting Area.

      1)   Blister  copper is fire-refined in one of two fire-refining furnaces
          and cast into different shapes (copper ingots, wire bar, and copper
          cakes)  in the casting wheel or in one of two semi-continuous casting
          machines.   35 employees.

      2)   S02 and  Arsenic area samples throughout the Refining and Casting area
          are documented below the proposed standards. 'However, actual 8-hour
          TWA exposures for these employees are poorly characterized.

      3)   General  dusty conditions prevailing in the Casting Area have been
          reported due to the spraying of bone ash (a mold lubricant)  and lamp-
          black (a material that prevents re-oxidizing of I the fire-refined
          copper).   Actual exposures  to these materials are uncharacterized.

      4)   NOTE--A  uniqueness found at White Pine is that their final product,
          the fire-refined copper,  does not need electrplytic refining.   While
          the electrical conductivity (due to silver cohtent)  is not equivalent
          to  electrolytic copper it  carries the same classification.

  E)   Others.
      1)
Due to the transient nature of a selected number of smelter jobs, INFORM
has created an "Others" cateogory.  While many workers on this list are
permanently associated with on sub-department of the smelter  -- i.e.
some of the surface laborers work full-time in the Reverb department --
we have been unable to differentiate these workers from their transient
counterparts.  Hence they are included in this cateogory.  These workers
are listed as follows:
                                Laborers
                                Maintenance Men
                                Technicians
                                Tool Room Man
                                Inspector
                                Janitors
                                        69 workers,
                                        27 workers.
                                         3 workers,
                                         1 worker.
                                         1 worker.
                                         2 workers,
      2)   Most exposures for these workers are poorly characterized.
**NOTE--Due to the low arsenic content in White Pine's ore,  in-plant arsenic
  levels  have been documented as ranging between none detected and 20 yg/m .
  However,  many arsenic exposures,  especially those of reverberatory workers,
  are above the proposed action level.  Therefore,  these workers will be subjected
  to the  monitoring and medical surveillance requirements as set forth in the
  standard.

-------
                                                                           rage b
    Comments:
I.   Company Safety and Health Activities.

    A)  History

          Details not available.

    B)  Staff

          Safety Director (1)

          Safety Engineer (2)

          Director of Environmental Affairs (1)

          Industrial Hygienist (2)

   C)  Industrial Hygiene

          There is no regular schedule of sampling of in-plant levels of
          gases and vapors in the smelter.  However, since January of
          1976, monitoring for copper dust levels has been performed

-------
                                                                       Page  b
        monthly in the concentrate handling system,  flue-dust handling,
        and the waste heat boilers.   This monitoring involves the personal
        sampling of 16 to 20 workers.

D)  Respirator Program

        Respirators are company supplied and NIOSH approved.  The respirators
        are supplied on demand and worn on an "as needed" basis.   Workers
        are responsible for daily cleaning.  Respirators are turned in weekly
        to be replaced, torn down and rebuilt, and/or sterilized.  The main-
        tenance and rebuilding of respirators is performed by two Safety
        Department technicians.

E)  Safety

    1)  The company reports that a safety man is assigned to periodically (not
        less than once a week) inspect the. smelter.  If a substandard condi
        tion is noted, "He will write it up."

    2)  Personal protective safety equipment—hard hats, safety glasses,
        metatarsal guards — is issued to all smelter employees.  Special pro-
        tective equipment--aluminized clothing and gloves, face shields — is
        issued where required.

    3)  General Safety Committee
        Aside from the Joint Safety and Health Committee, a General Safety
        Committee exists at this smelter.   It consists of three management
        and three union representatives.  The committee reviews the general
        safety policies of the company.

    4)  OSHA 100s for 1971-1976 and OSHA 102s for 1972-1974 on hand.

F)  Health Care

    1)  White Pine owns and operates a 20-bed hospital located one mile from
        the smelter.

    2)  Hospital staff of 34 (27 full -time, 7 part time),  including 3 full-
        time physicians.
    3)  All minor injuries,  are treated at hospital.  Preliminary  treatment
        only,  for major injuries.

    4)  Supervisory personnel receive basic first aid training.

    5)  All employees, receive a pre-employment physical.  Extent  of annual
        physicals, if any, is unknown.

Comments:

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                                                                          Page 7
\l.  Safety and Health Committee

   A)  Description

       1)  Joint Safety and Health Committees(both underground and surface) have
           been in existence since the beginning of operations.

       2)  Committee consists of three management representatives and three union
           representatives.

       3)  A once-a-month joint inspection of the plant is:made "to detect and
           record violations of applicable OSHA standards and to detect and
           record instances of non-compliance to other recommended safety prac-
           tices."

       4)  At the tour's conclusion, a written report, consisting of union/man-
           agement recommendations for corrections of conditions found to be
           hazardous, and tentative abatement dates, is prepared by the company
           and forwarded to the union.

   B)  The safety and health provisions of the contract address other matters,
       s uch as:

       1)  Right to refuse unsafe work.  A specific grievance procedure (third
           party review) has been incorporated to handle disputed cases.

       2)  Exposure levels are made available to union.

       3)  International has access right to the plant for safety and health
           meeting and inspections upon advance notification of management.

       4)  After a physical examination by the company physician, each employee
           is furnished with the results.

   Comments:

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                                                                          rage »
V.   REGULATORY  HISTORY

    A)   Pre-OSHA

        1)   Safety—Passage  of first state safety law an4 the  creation  of the
            state's  Department of Labor occurred in 1909.:  A comprehensive safety
            law—Occupational  Safety Standards  Act (Act 282)--was  passed  in 1967.
            MIDOL  records  show that  the White Pine smeltdr was  never inspected
            under  this Act.

        2)   Health—Division of Occupational  Health,  Michigan  Department  of Public
            Health,  formed in  1937.   INFORM has on file health  inspections per-
            formed at  White  Pine dating back  to 1959.

    B)   Post-OSHA

        1)   State  OSHA Plan

                a)   Developmental plan  approved in October,  1973.   The  enabling
                    legislation became  effective on January 1,  1975.

                bj   The Michigan Department of Labor  has  full authority to
                    endorse  and administer the  laws pertaining  to  occupational
                    safety.

                c)   The Michigan Department of Health  is  responsible  for  admin-
                    istering and enforcing laws concerning occupational health.

                d)   Inspections —See Table 2.

        2)   OSHA activities

                a)   Inspections —See Table 2.

-------
PROCESS EQUIPMENT -- White Pine
                                                     Table 1
NAME
Rotary Dryer
Reverberatory Furnaces (2)
Converters (Fierce-Smith)
Holding Furnace (1)
Fire Refining Furnace (2)
Casting Wheel (1)
Semi-Continuous Casting
Machine
SOURCES: Design and
White Pine
AGE
1970
1955
(2) 1955
1955
1974
1955
1955
POLLUTION CONTROLS COMMENTS
Two Stage Wet Scrubber -> Stack Particulate emissions are
also controlled by main-
taining a 9% moisture content
in the mixed charge.
Waste Heat Boilers -> ESP [Flat Plate ESP installed in 1961.
Type] -> 500' Main Stack Coal fired.
Baloon Flue •> 500' Main Stack No S02 control at this smelter.
Gases vented to 92' Stack
Gases vented to Separate 125 '
Stacks


Operating Parameters for Emission Control Studies:
Copper Smelter.

               Field Study of The White Pine Copper Company  NIOSH Study.

-------
                                     Table  2
iections--White Pine

dgan Department of Labor
                                                                           Page 10
         TYPE
             FINDINGS
                                        PENALTIES    FOLLOW-UP
                                                         COMMENTS
1/75      general      5 citations          $52
         schedule     (14 violations)
                                           company
                                           abatement
                                           letter
                                                                  guards,  warning
                                                                  devices, barriers
                                                                  £ other  safety
                                                                  violations
775
follow-up
                                                                  Involved whether
                                                                  or not to issue  a
                                                                  variance from a
                                                                  standard cited in
                                                                  5/20/75  inspec-
                                                                  tion.   Variance
                                                                  granted.
>/76
general
schedule
                       14  citations
                       (32 violations)
guards, electri-
cal, personal
protective equip-
ment, other
safety violations
7/76-     general      7 citations          $33
!2/76     schedule     (21 violations)
                                           company
                                           abatement
                                           letter
                                                                  guards,  electri-
                                                                  cal,  maintenance
                                                                  records,  other
                                                                  safety  violations
ligan Department of Health

:         TYPE         FINDINGS
                                       PENALTIES   FOLLOW-UP
referral     no violations
inspection
                                                        COMMENTS
j/75-
L8/75


general 1 violation
schedule


$30 company
abatement
progress
reports
copper dust
violations


                                                                 MIDOL calling  for
                                                                 inspection of
                                                                 flux building

-------
iections--White Pine
                                                                            Page 11
TYPE
1/72 accident
fatality
1/72 health
general
schedule
'75- health
>/75 general
schedule
(THHP)
FINDINGS
14 non-serious
violations
1 non-serious
violation
0
PENALTIES FOLLOW-UP
$180 company
abatement
letter
i
i
0 company
abatement
letter
1
i
I
i
COMMENTS
Death resulting
from fall from
roof during rest
period.
Cited for S02
exposures above
the reverb.
sampling for
As, Cu, and S02

-------
                                                       Table 3
SUMMARY OF HEALTH HAZARDS--White  Pine
                                              TWA Exposures'
Number of
PLANT AREA Employees
Material Handling
Reverberatory
Furnace area


Converter area



Refining
and Casting
Other
24
46


23



36
107
Copper
mg/M3
.7-4.7
<.1-13.








Arsenic
mg/M3

<.0002-.02


<.001-.011





Lead
mg/M3








	

Dioxide
(PPM) NOTES

S02 levels above
reverb range
between 4-10
ppm.
Tapping area
>15 ppm.




-- —

One copper dust measure-
ment of 245.5 mg/M3



All S02 sampling by
either state or federal
OSHA shows exposures
below proposed S02
standard.
Noise levels 105 dBA --
punching area.
	

               insnections
*Inder>endent of resnirator

-------
FACT SHEET

Facility:   Inspiration Smelter

Company:   Inspiration Consolidated Copper Co.
                                                INFORM
                                                25 Broad Street
                                                New York,  New York
                                                10004

                                                (212) 425-3550

-------
GENERAL

Name:   Inspiration Smelter (Inspiration Consolidated Copper Co.)

Location:   Inspiration, Arizona

Description:

     1) Part of an integrated copper producing operation wh|ch also includes
        three open pit mines, vat and heap leaching, a concentrator, an
        electrolytic refinery, and a continuous casting and!rolling plant.

     2) Smelting has been carried out since 1915.  Purchased by Inspiration
        in 1960, the plant was modernized considerably.]  In 1974, a brand
        new smelter with an electric furnace and Hobok^n converters was put
        in operation.                                  I
                                                       I
     3) Entire complex employs approximately 2,000 people.   Some 450 are
        employed in the smelter, including administrative and maintenance
        employees.

     4) Smelter is located in the Globe-Miami area of Arizona, with a popu-
        lation of 17,500 people.  Inspiration is the largest employer in the
        area.

     5) Arsenic content of the concentrates is unknown).

     6X Production

          a) Approximately 45-70% of the ore treated is on a custom basis.

          b)                  1972    1973    1974    1975    1976    1977
Copper (tons)
Sulfuric Acid
(tons)






94,000
175,000
127,000
237,000


Comments:

-------
                                                                    [page 2]
PROCESS' AND HAZARDS
NOTE:   In some areas of the plant, workmen wear company-isupplied respirators
on a need basis.   The following comments refer to exposures independent of
respirator usage.                                       ,

NOTE:   Throughout  the following remarks, the phrase "poorly characterized"
is used to indicate that we have found no evidence that either the company
or the regulatory  agencies have sufficiently characterized the exposures to
permit proper evaluation and corrective action.

A)  Material Handling-Receiving, Bedding Areas, and Dryer

    1)  Concentrates and precipitates are received mostly by rail car (some
        by truck), unloaded to hopper with car shaker,  find finally moved on
        conveyor belt to bedding area.

    2)  Foreman and operator (3 shifts) in unloading area are exposed to
        intermittent dust and noise from car shaking anii  unloading.   Actual
        exposures  are poorly characterized.             :

    3)  Sampling area has been reported in need of ventilation.   Actual
        exposures  were poorly characterized.  SMI reported in late 1976 that
        area would be replaced.  Actual status is unknown
    4)  Bedding area is an enclosed building, with 2 doori and some windows.
        It was built with the new smelter.   Materials a|re bedded by means -of
        an overhead tripper conveyor system, then placejd  onto another con-
        veyor by means.of a payloader with an open cab.   Intermittent dust
        exposures  are poorly characterized.

    5)  Concentrates are conveyed to a 150 ton wet charge storage bin ahead
        of the dryer.  Fuller rotary dryer is designed to reduce the moisture
        content from about 10% to less than 0.3%.  The exit gases are cleaned
        by cyclones and a baghouse before being vented into the  atmosphere.
        Dry material is fed directly to two 700-bins above the electric
        furnace.   The bins are "totally enclosed structures vented into the
        dryer dust collection system."  Dust exposures  to the single operator,
        if any, are poorly characterized.

    6)  Cleaning of the baghouse--carried out infrequently—is reported to  be
        "very dusty."

B)  Electric Furnace

    !)•  Began operations in 1974.   Largest in the world.

    2)  Feed is drawn from storage bins by screw feeders  which deliver the
        materials  to two drag conveyors.   Conveyor operation is  reported
        dusty.

    3)  Potential  exposures to sulfur dioxide,  metal dust and fumes on all
        floors  above the furnace roof are poorly characterized.   A few grab
        samples of S02 on record indicate levels of 2-28  ppm at  the smelter
        control room.   The heat on the sixth floor of the furnace is reported
        "terrible."  Actual levels are not characterized.

-------
                                                                    [page 3)


    4)   Matte is tapped from four holes on the converter aisle end of the
        furnace.  Only one is ventilated.  The launders(converge onto two
        ladle-filling spots.   There is no ventilation at these spots.   The
        launders are reported to be partly covered, but^exact extent is un-
        known.   Potential exposures in these areas are poorly characterized.

    5)   Slag is skimmed from two tap holes in end wall of the furnace.
        Tapping is done with machine.   There is no hooding or ventilation
        on tap holes, launders or slag pots.   Slag is taken to dump by
        rubber-wheeled vehicles.  Potential exposures in thiis area are
        poorly characterized.                               '

C)  Converter Aisle

    1)   Five Hoboken-Overpelt converters.  Off gases ar|b drawn from the
        "siphon" units on the side rather than traditional primary hoods.
                                                       t
    2)   Emissions into the converter aisle through converter mouths are
        reported frequent.  These occur particularly wh|en there are diffi-
        culties with the gas cleaning system downstream of the converters.
        Labor walkouts have occurred in protest of conditions in aisle when
        acid plant is down.

    3)   Potential exposures to sulfur dioxide and metal fumes, if any, in
        the converter aisle are poorly characterized.

    4)   Usually one converter is down for repairs, particularly in the
        "smoke box" section.   Repair work by masons and others inside these
        is reported to be extremely dusty.  Actual exposures are poorly
        characterized.

    5)   Crane cabs (2)  are enclosed and supplied with fresh air.   Maintenance
        of seals and fresh air equipment is reported adequate.   Sulfur di-
        oxide levels inside the crane cabs are reported near zero.

    6)   Noise levels in converter aisle reported around 95-96 dBA.   Actual
        exposures are poorly characterized.  No measures to reduce noise
        levels  from converters have been taken.

D)  Refining and Casting Area

    1)   Blister copper is either cast into 6000-pound cakes directly or
        refined in an anode furnace and cast  into anodes in the 10-mould
        anode casting wheel.

    2)   There is no hooding or ventilation at the anode furnace.

    3)   Potential exposures in these areas are poorly characterized.

E)  Other  Areas

    1J   Transfer of revert dust from dust control devices (e.g.  cyclones,
        flues,  precipitators) is reportedly by enclosed systems (screw con-
        veyors) back to mixing areas before rotary dryer.   Potential dust
        exposures,  if any,  are poorly characterized.

-------
                                                                    ("page 4]


    2)   Crushing plant handles silica and smelter reverts.   Scant information
        available to INFORM suggests that wetting systems are inoperative and
        that there is no exhaust ventilation.   Potential dust exposures are
        poorly characterized.

    3)   Exposures, if any,  in the acid plant are poorly, characterized.

Comments:
COMPANY SAFETY AND HEALTH ACTIVITIES

A)  History--Not Available

B)  Staff
                                                      l
    1)  Safety Department:  Safety Director and two safety engineers working
        under the director of industrial relations.  Activities encompass
        entire complex, not only smelter.

    2)  Industrial Hygiene:  Former safety director now holds the position of
        Director of Industrial Hygiene.

C)  Respirator Program

    1)  There is no specific training, education or supervision of respirator
        usage.

    2)  Respirators are cleaned and disinfected and repaired by the company
        on a monthly or weekly basis, according to areas of use.   Some work-
        men are dissatisfied because respirators are returned at random.

Comments:

-------
                                                                    [page 5]
D)   Industrial  Hygiene
    1)   Company performs some monitoring of personal exposures.   Details of
        monitoring program are unavailable.

    2)   Ventilation systems are not inspected according, to written plan or
        schedule.

    3)   There is no exchange of information with the union regarding the
        goals or results of air sampling.

    4)   Company presented no substantive testimony regarding hazards or
        controls during the OSHA hearings  for the proposed sulfur dioxide
        and arsenic standards.  INFORM found no evidence of any systematic
        exchange of industrial hygiene data with government, unions, or
        other companies.
Comments:
E)  Safety
    1)  Company safety inspections are the same as those conducted by the
        joint safety committee.

    2)  Details of accident investigation procedures are not available.

    3)  Safety training for new employees consists of

        a)  one-hour lecture

        b)  safety movie

        c)  instructions on protective equipment.

    4)  INFORM found no evidence of any refresher safety education.

    5)  Union reports that workmen were not trained in the safety aspects  of
        the new equipment put in operation in 1974.

    6)  INFORM has available OSHA 102 data for the years 1972,  1973,  1974,
        and 1975.

-------
                                                                     [page 6]


Comments:
F)  Health Care

    1)  Health care for employees and dependents is provided by private
        clinic set up by the company.  Staff includes 7 physicians as well
        as other personnel.
                                                      i
    2)  Clinic is approximately one mile from the smelter.
JOINT SAFETY COMMITTEE

    1)  A joint safety committee exists, with representatives from each of
        the nine unions, as well as 3-4 management representatives.   There
        is no contract language outlining the existence, make-up, or
        functions of this committee.

    2)  Committee meets monthly, when it selects one area of the smelter to
        inspect.  Committee has no specific authority; it can only make
        recommendations.

    3)  There is no specific procedure for joint accident investigations
        and union committee members are seldom included.

    4)  Other activities of the safety committee, if any, are unknown.

Comments:

-------
                                                                     [page 7]
REGULATORY HISTORY

A)  Pre-1970

    Office of State Mine Inspector

B)  Post-1970

    1)  State OSHA Plan

        a)  Developmental plan approved October 1974.  Headed by Arizona
            Industrial Commission.

        b)  Jurisdiction:  Still  in hands of state mine inspector.

    2)  State Mine Inspector

        a)  Inspections:  see table.

        b)  Limited industrial hygiene efforts.

    3)  OSHA (Federal) Activities

        Four inspections.  Two  accidents.   Two complaints.

Comments:

-------
Table  1
PROCESS EQUIPMENT--Inspiration
NAME
AGE
POLLUTION CONTROLS
COMMENTS
Fuller Rotary Dry~ex
1974    Two Dracco cyclones in series
        followed by a baghouse
Elkem Electric Furnace
1974    Gas coolers (with some heat recovery)
        -> 2 Dracco dust cyclones
        -> electrostatic precipitator (ESP)
        -> join the converter gases on the
          way to the acid plant
                                          Largest electric
                                          furnace in the world.
                                          Furnace fed by 2 drag
                                          chain conveyors.
Hoboken-Overpelt Converters  (5)     1974
        Gas coolers -+• one Duccon cyclone per
        converter -> mixing chamber -> 3
        electrostatic precipitators -»• join
        furnace gases on way to acid plant
Anode Furnace  (1)
1915
Anode Casting Wheel  (1)
1915
Acid Plant
1974

-------
                                                   Table 2
SUMMARY OF HEALTH HAZARDS--Inspiration
                                           TWA Exposures in
Number of
PLANT AREA Employees
Material Handling
	 -Receiving Area . -. 	
--Bedding Area
--Dryer
Electric Furnace
Converter Aisle
Refining and Casting Area
Other
--Crushing Plant
--Acid Plant
-- 	 ..




Copper
dust
- 	




Arsenic





OUJ. J. UX
Dioxide
(PPM) NOTES






Levels from 2-28 ppm reported.
TWA exposures not available.
Noise levels 95-96 dBA in
aisle. Details unavailable.



-------
HA INSPECTIONS--Inspiration
TF,
18/73
TYPE
Accident
Death
FINDINGS
l--non-serious. Failed
provide derail or bumper

to
: blocks
PENALTIES
$90.00
FOLLOW-
UP
No
                       on  railroad spur track  which
                       would have  prevented  car from
                       entering  building and contacting
                       another car.
6/74
/18/74
llll
Accident
Death
Complaint
Complaint
In compliance. (Fall from crane
while changing lights. )
6--non-serious. t ?
No violation. Complaint re use of
--
No
—
                       wood brake handles  at  sampling  and
                       unloading area.

-------
DATE
TYPE
FINDINGS
FOLLOW-UP
COMMENTS
10/21/74
Safety--smelter   19 violations
                       Co.  abatement  letter
                       11/25/74
                       Guards,  clean-up,  covers,  etc.
                       Oil spill  problem  £ electrode
                       control  tower.
                                                      Co.  abatement letter
                                                      for acid plant in-
                                                      spection. No report.
5/1/75
Safety--smelter   18 violations
                       Co.  abatement  letter
                       5/28/75
9/18/75
Health $ safety
--smelter
9 noise readings
  >90dbA

43 safety
violations
                       Signs requiring hearing protec-
                       tion need to be posted
                                                      Co. abatement letter
                                                      requesting 6 delays.
                                                      Others abated
3/8/76
Health--smelter
Dust.
S02--4 samples
     >5 ppm.
     2 >25 ppm.
3/16-17/76
Safety--acid
plant, smelter,
shops	
33 violations
                       Housekeeping
5/7/76
Safety—use of
explosive
3 violations
5/10-11 spot check.
Co. in compliance.
1) No instruction on  explosive
2). Not directed by  authorized
   personnel.
3) Area to be fired,  not
   guarded.
[Blasting the spill copper at
the dust box at converter.]

-------
DATE
9/21/76
9/21/76
TYPE
Health
Health--cranes
FINDINGS FOLLOW-UP
2 violations
4 dusts--
no violation
COMMENTS
1)
2)

Provide respirator program.
SOz violation at converters.


9/21-23/76   Health $ safety
40 sample plant
   violations
 3 acid plant
   violations
3 3/16-17/76
violations abated;
1 3/16-17/76
extension
S02--5 above 5 ppm
    [4 >20 ppm]
10/29/76     Abatement
Inspection of
above
(9/21-23/76)

-------
FACT SHEET

Facility:  Utah Copper Division,  Garfield Copper' Smelter

Company:   Kennecott Copper Company
                                                        INFORM
                                                        25 Broad Street
                                                        New York, New York
                                                        10004

                                                        (212) 425-3550

-------
GENERAL

Name:  Utah Copper Division, Garfield Copper Smelter

Location:  Magna, Utah

Description:

    1)  Combination (within 15-mile radius) of open pit mine, three concen-
        trators, copper smelter and refinery, silver refiner1/ and related
        facilities.

    2)  1,350 employees.  Approximately 700 in production.

    3)  Ore received from Bingham Mine, largest open pi't mine in the world.
        Concentrate arsenic content .135-. 15%.  Other impurity data on hand

    4)  Kennecott, Utah Copper Division is Utah's largest taxpayer, with an
        annual payroll of $100 million.
    5)  Production
                             1972
1973
1974
1975
1976
Copper
(net tons)
Silver
Molybdenum
258,037


254,965


1
229,330 !


171,482


188,917


Comments:
PROCESS AND HAZARDS

NOTE:  Workers are issued company-supplied respirators.  Use is not manda-
tory.  Workers are responsible for maintenance, storage and clean-up.

NOTE:  Throughout the following remarks, the phrase "poorly characterized"
is used to indicate that we have found no evidence that either the company
or the regulatory agencies have sufficiently characterized the exposures to
permit proper evaluation and corrective action.

NOTE:  The following outline attempts to define existing equipment, general
operating procedures and potential problem areas associated with the new
Noranda smelting system.  The Garfield system is the first Noranda of its

-------
                                                                          [page 2]
size and the first one used to produce 70% copper matte1, instead of blister
copper which the original continuous smelting process called for.

NOTE:   Potential exposures to sulfur dioxide throughout!'the new system are
uncharacterized.  Sulfur dioxide exposures in the reactor area will depend on
the percentage of sulfur that is removed at the reactor mouth, the extent of
the oxygen enrichment process and the effectiveness of ventilation and hood-
ing systems.  Exposures in the remainder of the operation wi,ll be indirectly
affected by the Noranda system.  Process and controls in the! converter area
remain virtually unchanged, making sulfur dioxide exposure l!ikely.

NOTE:   Potential exposures to arsenic throughout the new system are uncharac-
terized.  Experience with the old system and the high concentrate arsenic
percentage make exposures likely.  Levels in the reverb'eratory furnace area
of arsenic ranged from .01 mg/m^ to .25 mg/m3.   All oth'er areas were unchar-
acterized.

NOTE:   Potential exposures to lead throughout the new system are uncharac-
terized.  Scant sampling at the old reverberatory area indicates levels above
the OSHA proposed standard during some operations.   Other( exposures, if any,
were uncharacterized.

A)  Material Handling

    1)  Concentrates are received at the material handling building in a 15%
        wet state, which is fairly effective at reducing dust,  according to
        the union.  Despite original plans to construct new facilities as of
        this writing,  no new receiving areas exist.   Concentrates are then
        transferred through a new dryer on covered and underground conveyor
        belts to bins  above one of three Noranda reactors.

B)  Reactors

    1)  There are three Noranda reactors at the Garfield smelter.   Two of the
        new reactors have been operating since  December of 1977 with the
        third beginning production in April, 1978.   The company has reported
        that it intends to operate two of the reactors during normal produc-
        tion.  The Norandas will be fed a mixture of concentrate,  crushed
        converter and  reactor slag and flux by  way of a slinger feed system.
        Heat will be provided through a combination of burners, one on each
        end, and oxygen enrichment by way of tuyeres.   The mouth of the con-
        verter shaped  furnace is hooded and the 20% sulfur off-gases are sent
        to one of four acid plants.   Matte is tapped into  ladles on the
        south side of the reactors and transported by motorized transfer
        cars underneath the reactor and out into the center of the con-
        verter aisle.   The tunnel under the reactors is under negative
        pressure.  The ladles are not covered during transfers.  From the
        center of the  aisle the ladles are carried by overhead cranes to
        one of four Fierce-Smith type converters.  Slag is  tapped into
        hooded ladles  and cools for 24 hours in the north  portion of the
        smelter building before it is carried by transfer  haulers to the
        new slag concentrating plant.   All tapping points  are hooded.
        According to the company, the Noranda will  be rolled out of its
        hooding only in emergency situation.

-------
                                                                          [page 3]
    2)   Crane Cabs-- The union reports that the new enclosed, charcoal-
        filtered cabs are not as effective as those in the old smelter.
        Actual exposures are uncharacterized.          ;'

    3)   Ladles--  The union reports that ladles are left smoking (after
        unloading)  in the converter aisle.  Other emissions from slag haulers
        and matte ladles make conditions in the aisle "much the same" as in
        the old reverberatory furnace building.

C)   Converters

    1)   There are four converters in the new building. -One of the advantages
        of the Noranda system when producing 70% copper, matte is the need of
        fewer converter-hours per ton of copper.   This Jin turn is reflected
        in the fact that there are only four convertersi connected with the
        new system versus nine in the old reverberatory building despite
        comparable production rates.  Kennecott has constructed two new
        Fierce-Smith type converters and has retrofitted two old converters
        and placed them in the new smelting building.  The converters are
        primary hooded, and gases are sent to the acid plant complex.  Slag
        is skimmed and transported to the new slag concentrator-floatation
        facility before being charged into the reactors,  f

    2)   Punching--   The union reports that the punchers are partially en-
        closed and  are used in conjunction with Norand^ silencers.   INFORM
        has been unable to determine if the company is ^experiencing any
        difficulties with the silencers.  The union indicated to INFORM that
        there are intermittent noise exposures.  Other exposures,  to arsenic
        and sulfur dioxide, if any, are uncharacterized.

    3)   Skimmer--  Skimmers are, as in most smelters, in the open for ex-
        tended periods of time during the work day.  Exposures,  if any, are
        uncharacterized and depend on the overall converter area levels.

D)   Anode Area

        Although construction on the new anode building is complete, the
        company does not plan to construct new furnaces or casting wheels at
        this time.   Smelter operations continue to use the old anode fur-
        naces.  Exposures, if any, at the old anode area being used in con-
        junction with the new system are uncharacterized.

E)   Slag Concentrator

        Reactor and converter slag are transported by ladle haulers to the
        new slag floatation and concentrator.  Slags are open-air-cooled and
        then "crushed, ground, and treated by floatation for the recovery of
        copper."  The union reported early problems with workplace heat.

F)   Other

    1)    The company is constructing a Zig Zag blender to treat ESP dust
         prior to feeding into the reactors.  All other revert dusts are
         pneumatically conveyed to the reactor feed system.

-------
                                                                           [page 4]
    2)  The company is constructing a boiler to supplement the power supply
        at the smelter and will continue to operate oneiof the reverbs until
        construction is completed.
Comments:
COMPANY SAFETY AND HEALTH ACTIVITIES

A)  History-- Details unavailable.

B)  Staff

        Safety Director (1)

        Senior Industrial Hygienist (1)

        Technicians (3)

C)  Industrial Hygiene

    1)  The smelter industrial hygienist performs some industrial hygiene
        sampling.  Exact frequency of sampling is unknown.   The union
        reports little sampling being performed in the new  smelter areas.

    2)  The smelter has limited contact with the company environmental
        division in Salt Lake City.

D)  Respirator Program

    1)  Respirators are provided on a need basis,  based on  industrial hygiene
        sampling and workers'  requests.

    2)  Workers are responsible for maintenance, cleaning and storage of
        respirators.

    3)  The union reports  that the company provides  little  education for
        respirator use and maintenance.

-------
                                                                          [page 5]
E)   Safety

    1)   Pre-employment safety orientation consists of the issuance of a
        safety booklet and approximately one-half hour of instruction.

    2)   Refresher safety education is administered through monthly depart-
        ment  meetings.   In many departments the meetings are held infre-
        quently.

    3)   Company issues free of charge most necessary safety 'equipment.

F)   Health Care

    1)   Most  medical care is administered through the Wksatch Medical Clinic
        located 20 miles from the smelter.             |

    2)   The Clinic staff consists of two doctors and three registered nurses.
                                                       [

    3)   The company has also established emergency clinics on both the
        smelter and refinery grounds, with a full-time staff of two nurses at
        each  and daily visits by one of the doctors.     ;.

    4)   There are first aid trained guards and foremen in;all shifts.

    5)   The company performs pre-employment physicals o|n all employees.
        Blood tests, hearing tests and lung function te;sts are administered
        to appropriate employees.

Comments:
SAFETY COMMITTEE

A)  Description

    1)  Joint Safety Council
        aj   Established in 1954 following a fatal accident.
        b)   The Council meets monthly with four representatives from the
            union and four from the company.  The Council acts on safety
            suggestions and tours portions of the smelter.

    2)  Union representatives assist in accident investigations.

-------
                                                                           [page 6]
Comments:
REGULATORY HISTORY

A)  Pre-1970

    1)   Utah State Industrial Commission cooperating with the State Depart-
        ment of Health and Welfare, Bureau of Occupational Health.

B)  Post-1970

    1)   State OSHA Plan

        a)  Utah State Industrial Commission, Occupational Safety and Health
            Division and the State of Utah Department of Social Services,
            Division of Health.

        b)  The state has conducted eleven inspections :of the Garfield
            smelter.

    2)   OSHA Activities
        a)  OSHA has inspected Garfield on four occasions, all between 1972
            and 1973.

Comments:

-------
                                                  Table  A
PROCESS EQUIPMENT--Garfielcr
NAME
AGE
                                                          POLLUTION CONTROLS     COMMENTS
Noranda Reactor  (3
1977
                                                          Electrostatic
                                                          precipitator  (ESP)
                                                          ->•  acid plants
                                 (2)  1977

Pierce-Smith Converters  (4)	(2)  1977  (retrofitted)    ESP -*• acid plants


Anode Furnace  (2)                1950     	 	
Anode Casting Wheel  (2)
1950
                                                          none
                          none
                                                 Originally scheduled to
                                                 modify  the   anode area.
Acid Plant ,"S

           #5,6,7
1977

1977 (retrofitted)
                                                                                 Reactor  and converter gases
                                                                                 are  combined prior to
                                                                                 acid plants.	
         *Sources:  "Emission Control  Effort  at  [\ennecott's  Utah  Smelter,"  September 21,  1974.
                    K. H. Matheson.

-------
SUMMARY OF HEALTH HAZARDS--Garfield
                                                  Table 2
                                                  TWA Exposures7
Number of
PLANT AREA Employees
Material Handling
Smelting Department
Reactors
Converters
Anode area
Acid Plants
Slag Concentrator
Other
41
120
(80)
(40)
117



Copper
mg/m3








Arsenic
mg/m3








Lead
mg/m3








auirur
Dioxide
(PPM) NOTES
















          •Independent  of respirator usage

-------
tions--Garfield
                                   Table 3
      TYPE
FINDINGS
                                      PENALTIES    FOLLOWUUP
72

'3
'73
accident
fatality
complaint
safety
follow-up
to 4/2/73
accident
fatality
1 non-serious
violation $600 recommended
i
22 non-serious I
violations $220 6/11/73 !
all violations
abated 	 	
death natural
causes 	 —
—

:tions--Garfield
OSHA

'5
i
75
75
75
75
:>
75

TYPE
general
schedule
health
complaint
safety
complaint
health
general
schedule
safety.
complaint
health
complaint
health
complaint
safety
complaint
health

FINDINGS PENALTIES FOLLOW-UP
in compliance 	 	
2 non-serious
violations $45 	
in compliance 	 	
25 non-serious
violations $290 	
in compliance 	 7/29/75
in compliance 	 	
3 non- serious
violations $45 	
in compliance 	
[to next page]
COMMENTS
1973 company
silica monitor-
ing data cited.
Item til
vacated 7/11/75
No samples
taken.
Six items
vacated 8/1/75
Roaster plate
treater bldg.
Roaster plate
treater bldg.
Anode area
Acid plant


-------
. 3--cont'd]

:tions--Garfield
OSHA
.nued]

      TYPE
FINDINGS
PENALTIES    FOLLOW-UP
                                                                     COMMENTS
general 1 serious ,
schedule 11 non-serious
i health violations $875 	
complaint
i health in compliance 	 	
complaint 3 non-serious
'6 health violations $90 	
1 serious and
7 non-serious
violations
abated 10/1/76
and 11/5/76.
Catenary
flue cleaning
Asbestos

-------
FACT SHEET

Facility:   Ray Mines Division, Hayden Smelter

Company:   Kennecott Copper Corporation
                                                       INFORM
                                                       25 Broad Street
                                                       New York, New York
                                                       10004
                                                       (212) 425-3550

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                                                                      Page 1
GENERAL

Name:  Kennecott Copper Corporation, Hayden Smelter
Location:  Hayden, Arizona

Description:

    1)  Combination of concentrate receiving facilities^ fluo-solids
        roaster, reverberatory furnace, converters (3),'anode casting
        facilities, and supportive facilities.

    2)  Smelter built 1958; mill, 1909.

    3)  Employees:  194 smelter production.

    4)  Ore from Ray mines.  Concentrates from Kennecott Hayden concentra-
        tor.  Arsenic content of concentrate estimated at .016%; other trace
        material information on hand.

    5)  Area's  (Hayden-Kearny)  economic base largely derived from mining,
        milling, and reduction of copper ores.        '

    6)  Production
                                  1973
1974
,'l975
1976
Copper* (tons)
H?S04 (tons)
Molybdenum (Ibs)
Gold (ozs)
Silver (ozs)
98,908

611,307
1,213
234,994
74,764

682,514
1,468
244,864
'• 	 — r 	
42,036
175,000
^330,032
1,188
153,872
88,089

743,037
1,016**
107,855**
            *Includes copper hydrometallurgically produced from silicate
            ores as follows:  1973, 24,714; 1974, 18,065; 1975, 7,336;
            1976, 25,213.
            **1976 gold and silver production based on refinery figures.
Comments:
PROCESS AND HAZARDS

NOTE:  Respirators are company-supplied and worker-maintained.  They are
worn on a need basis.  The following comments evaluate TWA exposures
independent of respirator use.

NOTE:  Throughout the following remarks, the phrase "poorly characterized"
is used to indicate that we have found no evidence that either the company
or the regulatory agencies have sufficiently characterized the exposures to
permit proper evaluation and corrective action.

-------
                                                                      Page 2


A)   Material Handling

    1)   Sulfide and Leach-Precipitation-Flotation (LPFjj concentrates are
        received, as a slurry, at the Filter Plant whefe they are "de-
        watered."  Materials are then transferr d via open conveyors to a
        screw conveyor/dryer.  A final sent of conveyors transfer the
        material to storage areas.  Potential dust exposures to filter plant
        and dryer operators and their helpers from open conveyors and trans-
        fer points.  Poorly characterized.

    2)   Storage building provides storage and removal facilities.  Removal
        consists of overhead cranes equipped with hoppers.  Once charged,
        the hopper then feeds the materials via open conveyor system to
        the concentrate feed hopper above the fluid-bed roaster.  Potential
        dust exposures to the craneman, binmen, secondary materials
        operators, and laborers.  Poorly characterized1.

    3)   Outside storage area.  Removal by front end loader.   Loader dumps
        materials on grizzly above a conveyor belt.   Qpen conveyor belt
        system transfers materials to storage above roaster.   Yard covered
        with 4 to 6 inches dust, which is constantly stirred by loader,
        general activity, and the wind.  Area cited by State Mine Inspector
        after worker complaint.                         f

    4)   Lime Plant.  Five employees.  State inspection shows  Si02 levels
        below;TLVs.  Noise levels above present standards.

B)   Fluo-Solids Reactor                               !
    1)   Blended materials (concentrate, lime, silica, and precipitates)  are
        fed into reactor via a screw feeder which controls feed rate and
        seals reactor vessel.
    2)   The "roasted" fine solids leave the reactor via the  gas stream and
        are recovered in primary and secondary cyclone banks  above the
        reverbs.   Oversized materials (M5%) are removed from the reactor
        via a cone type valve located in the reactor floor.   This material
        is transferred to the calcine bins above the reverb  by drag chain
        conveyor.
    3)   Exposures to the reactor operators(6) and reactor utilitymen (3) are
        poorly characterized.
    4)   Cyclone utilitymen (3) must enter cyclones from time  to time when
        they become plugged.   Exposed to high S02 and dust levels due to
        nature and location of job.  Poorly characterized.
    5)   Roaster feed ports must be cleaned out once a month.   The operation
        takes fourteen hours  and involves entering the reactor and drilling
        over 2,000 holes.   To decrease exposures, the reactor is first
        heated to VL,8000F to "burn it out."  The reactor is  then cooled
        with sonic (fog)  sprays.   Unions wanted a 48-hour cooling time
        before the reactor could be entered.  However, a "sufficient cooling
        period" was enacted,  which leaves the cooling time up to the com-
        pany's discretion.  (Arizona Mining Code R-ll-1 1632)  Workers enter
        in teams  (substituting in and out).   One worker reported entering
        reactor with a thermometer, and recording 300°F.  Workers report
        entering  reactor and  coming out two minutes later,  not being able to
        work for  the rest of  the day.   Others report exiting from reactor
        vomiting   after five  minutes.

-------
                                                                      Page 3

C)   Reverberator/ Furnace                              !
                                                       I
    1)   One suspended arch furnace.                    f
                                                       'i
    2)   Charge bins above the reverb receive the calcines from the reactor.
        The calcines are intermittently fed to the reverb via Wagstaff
        feeders.

    3)   The cyclone man and other working in the bin area above the reverb
        are exposed to sizable S02 and arsenic levels.  Employees complain
        that "the company does not correct the dust and fumje problem [in
        this area]  at the source, they [company] just add on safety equip-
        ment."                                        I

    4)   Furnaceman.  Workers report extreme noise levels—due to air and
        steam blowing from the burner.  They are supplied with ear plugs;
        however,  the furnaceman cannot wear them since1 he "relies on his
        ears to notice changes in what's going on."  OSHA determined noise
        levels within standard.
                                                      i
    5)   Tapper.  25-30 ladles of matte are removed from reverb per day--
        taking 10-20 minutes to fill a ladle.   During tapping there is
        considerable exposure to S02 and fume.   The tapping area is hooded.
        S02 and arsenic exposures above the present standard.
    6)   Slag Motorman.  Slag is removed at an average rate of 650 TPD and
        transferred to the slag dump via slag cars.  The launders are
        hooded; however., the cars themselves become fugitive emission
        sources.   Exposures to motormen poorly characterized.
    7)   Arch Blower.   One man per day in afternoon shift.   Arch blown from
        catwalk 15-20 feet above the reverb.  Company tried vacuuming;
        proved unsuccessful, however.  Arch blower works above reverb for
        six out of every eight hours.  Temperature exposures range from
        130°to 200°F.  He is equipped with safety glasses, safety shoes,
        overalls,  respirator, and rags to keep out irritating dusts.   Nature
        and location of job cause  extreme S02 and dust exposures.  Poorly
        characterized.
    8)   Waste Heat  Boilers.  Dusts entrained in gas stream are collected in
        hoppers.   They are removed and transferred to converters via front
        end loaders.    Due to nature and location of job,  dust and S02 expo-
        sures are  likely.  Poorly characterized.

D)   Converter Area
    1)   Matte transfer via matte ladle/cars to converter aisle.  Matte then
        fed to converter via crane/ladle operation. ,  Empty ladle returns to
        reverb.
    2)   Crane cabs  (2) are under positive pressure, filtered, and air condi-
        tioned.  The  cranes are located 80 feet above the converters. Crane-
        men intermittently exposed to S02 levels as high as 12 times the
        present standard.
    3)   Three Fierce-Smith converters equipped with water cooled hoods and
        gas cleaning  spray chamber.  The spray chamber nozzles (water and
        air pipes  join at nozzle to create spray) have to be changed, two
        times per  shift, with the resulting exposures poorly characterized.

-------
                                                                      Page 4


        Workers report that the hoods leak excessively!.  There are no
        secondary hoods .                                ',

    4)  Skimmer.  Skimmer has a shelter where he governs the converter
        operation by flame color.  S02 exposures are Likely, but poorly
        characterized.  Due to nearby punching operation, the skimmer is
        intermittently exposed to excessive noise levels.  Area cited by
        OSHA for noise.

    5)  Puncher.  Noise levels of up to 16 times the standard.  Cited by
        OSHA.  Company plans to implement muffler devices as a result of
        this citation.  Converter equipped with spark .shield which provides
        puncher with ventilation and necessary protection from sparks.
    6)  Slag Haulage Operator.  Slag is continuously "iskimmed" until all
        iron sulfides have been removed.  Slag then cqoled in cooling pits,
        crushed, and sent to flotation mill to recover1 copper.  The concen-
        trate is "dewatered" and sent to roaster.  Exposures poorly char-
        acterized.                                   I

    7)  Silica Flux Operation.  Converter hoods are equipped with openings
        through which silica flux is added.  Silica transferred from
        storage bins behind converters via an open belt .system, terminating
        at hood.  Material is discharged directly into  a, chute, feeding
        converter.  Probable dust and S02 exposures.  Poorly characterized.

E)  Refining Area                                    \
    1)  Two 250-ton anode furnaces surround one common  anode casting wheel.

    2)  Poling, to rid the blister copper of oxides and other impurities, is
        accomplished by reduction/oxidation with natural gas/compressed air.
        The usual practice is to 'blow'  these furnaces  during the night
        shift.
    3)  Casting furnacemen (2) control the furnaces, the pouring  spoon,  and
        the casting wheel from one of the two enclosed, air conditioned
        control booths.  Exposures poorly characterized.
    4)  Furnace Helpers (8).   Tending burners on the furnaces,  among other
        responsibilities.  Area was cited by OSHA for burner noise.   Company
        was to have abated noise hazard by making change in burner system.
        Extent of correction unknown.
    5)  After anodes are  cast and cooled, they are removed via a  Bosh-crane
        and placed for further cooling in the two water filled Bosh-tanks.
        After cooling, anodes are removed by an overhead crane to a storage
        area.  Anodes are shipped to refinery for additional processing.

    6)  Health hazards poorly characterized for anode casting area.

F)  Auxiliary Equipment
    1)  Gas cleaning and  acid plant.  Fourteen employees.  Job descriptions
        and exposures are poorly characterized.  A welder was severely
        burned (sulfuric  acid burns) at the acid plant  loading station.

Comments:

-------
                                                                       Page  5
COMPANY SAFETY AND HEALTH ACTIVITIES                  I

A)  History                                           ,

        Details not available.                        I

B)  Staff

        Safety Director (1)

        Safety Engineer (1)

        Industrial Hygienist  (1)
                                                      I
C)  Industrial Hygiene                                ;

        Company reports "Monitoring throughout plant at least once annually.
        --Sampling for sulfur dioxide, lead, arsenic, cadmium, mercury.
        Main contaminant sulfur dioxide--due to fact Ray ores are very low
        in concentrations of other elements."  Conflicting data on hand as
        to actual extent of monitoring.

D)  Respirator Program
        No specific company details available.  All workers issued
        respirators.   "Some use them.  Some do not."
        Workers responsible for maintenance.  Respirator program cited by
        OSHA 4/75--Extent of abatement unknown--No OSHA follow up.

E)  Safety

    1)   Company details not available.
    2)   The number of lost workdays in 1974, as reported to State Mine
        Inspector by  company,  is three times the number that appears on
        1974 OSHA 102.

F)  Health Care
    1)   Kennecott owns  and staffs a 20-bed hospital seven miles from
        smelter.   Ambulance at smelter.
    2)   Hospital  staff  of 37,  including five full-time physicians.  Smelter
        staff consists  of licensed practical nurse [1) and emergency medical
        technician (1)   Supervisory personnel receive first aid training.

-------
                                                                      Page 6


    3)   Pre-employment physical.  Audiometric tests gijen annually to start
        with.   Hearing conservation program for workers in high risk areas.
    4)   Discrepancy exits between availability and extent of annual medical
        testing that company reports giving and that workers report
        receiving.
Comments:
SAFETY COMMITTEE
                                                        I
A)  Description                                         r

    1)  Established 1958.                                :

    2)  Two management representatives(safety director, and safety engineer);
        two United Steelworkers representatives; one Representative each
        from other unions.
    3)  Meets once a month  on company time.   They decide what areas to
        inspect and write  down what improvements should be made.   Company
        then decides either to reject or abate.

Comments:
REGULATORY HISTORY

A)   Pre-1970
    1)   Office of State Mine Inspector

B)   Post 1970

    1)   State  OSHA Plan
            a)  Developmental pi an--Approved October 1974--Headed by
                Arizona Industrial Commission.
            b)  Jurisdiction over smelter still in hands of State Mine
                Inspector.   No contractual agreement exists between SMI
                and Arizona Industrial Commission.

-------
                                                                      Page  7
    2)   State  Mine  Inspector                          j
            a)   Inspections:  see table.               i(
            b)   Limited industrial hygiene efforts.
    3)   OSHA Activities
            a)   Two inspections — one safety; one health.
Comments:

-------
NAME
                                                 AGE
              CONTROLS
                                                       COMMENTS
Filter Plant
1958
Cyclone Scrubber
Storage Area
1958
DNA
Inside and
outside areas
Fluid Bed Roaster
1969
1° and 2° Cyclone Banks, Venturi
Scrubber, Peabody Scrubber, Mist
Precipitator,  Drying Tower, Mist
Eliminator, Acid Plant
Reverb fed
pneumatically
Reverb (Detrick-type suspended arch)
Converters (3)
(Pierce-Smith 13' x 30 ' )
Casting Furnaces (2)
Casting Wheel
Acid Plant
(Double contact)
Lime Plant
and Silica Crushing Facilities
1958
1958
1958
1958
1969
Rebuilt 1974
1958
Waste Heat Boilers, ESP, 600' Stack
ESP, Peabody Scrubber , Mist Precip-
itator, Drying Tower, Mist Elimi-
nator, Acid 'Plant
None
None
Tail gases uncontrolled—leave via
100' Stack 950 TPD
DNA
       SOURCES:   Design and Operating Parameters  for  Emission Control Studies:
                 Kennecott, Hayden,  Copper  Smelter

                 "The New Hayden Smelter,"  Journal  of Metals, June  1959
                                                                                                                    T3
                                                                                                                    V>
                                                                                                                    (TO

-------
Number of
AREA Employees


Material Handling

Roaster and
Reverb area
Converter Aisle
Anode Refining.,
and Casting
Acid Plant and
Gas Cleaning
Equipment


78

45
38
15

15
Copper
mg/M-S




.003-. 013




Arsenic
mg/M-5




.002-. 009




Lead
mg/M^









suirur
Dioxide
ppm NOTES




Reactor
10-29.5
Reverb
.9-6
0-60



Primary crusher and lime kilns
noise levels exceed standard.
Hazardous dust concentration at
outside feed area.
Content of dust poorly characterized.
Arch blower subject to temperature
range of 130°-200°F.
Severe dust exposure--likely arsenic
hazards .
Reactor cleanout crew exposed to
temperature exceeding 300°F.
Due to nature of job, high dust
exposure likely, but poorly
characterized
Mechanical puncher exposed to 16
times allowable noise.
Furnace man subject to noise
exceeding standard.

Most exposures poorly characterized.
SOURCES:  OSHA data
          State Mine Inspector reports
          Union data
* Inspection reports  consistently
 state  "poor housekeeping"
 throughout plant.
                                                                                                              -a
                                                                                                              vo

-------
tions-.-Kennecott  Hayden
                                                    Page 10

75

75
TYPE
general
schedule
safety

general
schedule
health
FINDINGS
15
non-serious
violations

2
non-serious
violations
PENALTIES
None

$90
Reduced
to $45
FOLLOW-UP ' COMMENTS
' All violations but one
;' abated before inspection
None team left premises.
S02 --cyclone man
wearing non-approved
rejspirator.
Noise-- #2 § #3 conver-
ter, anode furnace and
Recommended casting wheel.
tions--Kennecott  Hayden
of Arizona,  State Mine  Inspector
      TYPE
FINDINGS
PENALTIES   FOLLOW-UP
                                                          I1
COMMENTS
72*

safety--
smelter
spot
safety--
concentrator
22
violations **
No
violations 	
]
Spot inspection of
reagent handling area.
      accident
Insufficient
water pres-
sure for
deluge
shower and
eye wash; no
instructions
for safe
loading
operations.
                          Welder burned over 1/3
                          of body due to acid
                          plant § loading accident.
      safety--
74     smelter
47
violations
            1/2/75 SMI
            letter--
            granting
            extension
            for 11
            violations.
Handrai1s, guards, etc.
      safety--
      smelter
violations
            All
            violations
            of 10/22/74
            abated.
Keep after housekeeping
  *1972-1974  State  Mine  Inspection not available to INFORM.
 **State Mine Inspector  issues no $ penalties.

-------
:tions--Hayden  [SMI], continued)
Page 11
TYPE FINDINGS PENALTIES FOLLOW-UP COMMENTS
safety--
prep 67
plant violations
7
noise-- violations
crusher, (above
'5 lime kiln 90 dBA)
health--
i flux
health- -
76 smelter
spot
health--
'6 lime plant
safety-- 30 safety
6 smelter violations
compliance
inspection
complaint--
flux 2 dust
division violations
health--
6 lime plant
1
6 complaint violation
1
complaint violation
8, health--
smelter;
S02, dust.
76 complaint 	
,' Toe boards, guard rails,
	 ' machinery guards.
Housekeeping must be
	 improved.
i
Sajmples below TLV for
	 Si'02.
Dust samples.
j All samples (7) below
TLV for dusts containing
	 • Si02.
1
' All samples (6) below
	 TLV forSi02 dusts.
i
	 i'
21 i
violations ; '
abated, of I
4/20/76 i
smelter
safety in-
spection.
5
extensions
	 granted.
Outside feed area--clust
stirred by front end
	 loader.
All samples (5) below
	 TLV for Si02.
Crane Cab repairs—by
	 September 2.
Same cab, different
complaint --abate
	 immediately.
No cited violations, but
one area sample above
5 TLV for Si02 (14 samples
extensions taken) , and five out of
of 4/20 eight S02 samples above
	 abated. 5 ppm TLV--one for 60 ppm.
Complaint re accident on
slag train. Inspector
recommendation: take up
	 slack on hand brake.

-------
FACT SHEET

FACILITY:   Hurley Reduction Works

COMPANY:   Kennecott Copper Company
                                                         INFORM
                                                         25 Broad Street
                                                         New York, New York
                                                         10004

                                                         (212) 425-3550

-------
                                                                        page 1
GENERAL
                                                       I
Name:   Hurley Reduction Works                          j
Location:   Hurley, New Mexico                          'i
Description:

    1)   Combination of concentrator, "green-feed" smelter, fire refining
        and supportive facilities.

    2)   Mine begun in 1909.  Smelter built 1939-1942.      i

    3)   1,300 employees (total including mine): 196  (smelter production)
    4)   Ore from Chino Mine, reserves more than 50 years.  Arsenic content
        variously estimated as smaller than 0.005%;  greater than 0.025°6.
        Other trace metal information on hand.        j
    5)   Largest employer in Grant County, N.M.; payrol'l $20 million.
    6)   Production                                    '
          a) Approximately 1/6 of Kennecott's total   !
          b)                     1972     1973     1974
1975
1976
Copper (tons)
Molybdenum (Ibs)
Gold (ozs)
Silver (ozs)
Sulfuric Acid
73,403
396,671
587
12,650

67,836
608,098
228
5,428

60,557,
274,563'
1,990
39 , 7;76
?
53,193
421,596
1,911
55,604
?
57,202
190,200
1,929

?
 Comments:
PROCESS AND HAZARDS--SMELTER

NOTE:  In most areas of the plant, workmen wear company-supplied respirators
on a need basis.  The following comments evaluate TWA exposures independent
of resporator use.

NOTE:  Throughout the following remarks, the phrase "poorly characterized"
is used to indicate that we have found no evidence that either the company
or the regulatory agencies have sufficiently characterized the exposures to
permit proper evaluation and corrective action.

-------
                                                                        page 2

A)   Material Handling

    1)   Open conveyor from mill to open pile storage i| yard.  Wind some-
        times results in dust exposure to yard personnel and even smelter
        workers.  Poorly characterized.               'i

    2)   Dryer.  Potential dust and arsenic exposures to operator, clean-up
        man, and heavy-equipment operator.  No local exhaust at feed
        station.  Poorly characterized.  Approximately 3 men per shift.

B)  Reverberatory Furnace Area                             |

    1)  Two furnaces, only one operated at a time.         '

    2)  "Down" furnace.  Refurbishing may mean excessive noise and dust
        exposures to jackhammerman, 'rebrickers, and others.  Poorly charac-
        terized.  "Special smelter laborer" cleans outj the inside of waste
        heat boilers  and flues when furnace is down, i Likely very high
        exposures to arsenic, other dust.  Poorly characterized.
    3)  Tripper conveyor system, though automatic, requires frequent inter-
        vention by operator.  Intermittent but sizable S02 and dust expo-
        sures.  Arsenic in excess of proposed standard likely.   Poorly
        characterized.  One man per shift.              I

    4)  Feedermen.  Wear full-face air-supplied respirat'ors while feeding,
        as a result of OSHA citation.  Sizable dust exposures.   S02 expo-
        sures above present standard with peaks above 100 ppm.   Arsenic
        exposures above proposed standard.  Sizable contribution to all
        exposures from "blowing of the arch." 2 to 4 times per shift.   Two
        to four men per shift.
    5)  Matte and Slag tapping.  Exposures to S02 above recommended stan-
        dard, but below present.  Arsenic exposures above proposed standard.
        Tap points and launders are not hooded or ventilated.  Three men per
        shift.
    6)  Waste heat boilers.  Three men per shift with S02 exposures above
        proposed standard, but below present.  Arsenic exposures above pro-
        posed standard.  Heat exposure likely but not characterized.

    7)  Reverb--General
           a)  Others in reverb area (furnaceman, slag train motorman,
               furnace brick repairman) probably have exposures similar to
               tappers.  Poorly characterized,  Three to five men per shift.

           b)  Reverb "explosions" while feeding are commonplace source of
               contamination.  Cause and prevention of such unknown.

C)   Converter Aisle
    1)   Four converters with water-cooled hoods.   Secondary converter hood-
        ing was outlined in fugitive emission control plans submitted to New
        Mexico authorities in or around early 1974, but plans were never
        implemented.
    2)   Skimmers and crane chasers with S02 exposures below proposed stan-
        dards.  Arsenic above proposed standard.   Four to six men per
        shift.  Skimmers sometimes exposed to excessive noise as a result of
        nearby punching.

-------
                                                                        page 3


    3)   Crane seals and ventilation allow excessive S02 levels (above 2 ppm)
        in crane cabs.  Cranemen must often wear respirators.   Three men per
        shift.   Arsenic poorly characterized but likeliy because of location
        above converter aisle.                         .'
                                                      i|
    4)   The hood(s) to cover ladles while filling are hot routinely
        used.

    5)   Maintenance of cranes (regarding safety) has been a source of some
        labor-management conflict.
                                                          I
    6)   Converter punchers.   Noise levels up to 6 times standard;  also
        exceeding 115 dBA.   Men wear ear plugs.  Cited by OSHA in  1974 for  lack
        of engineering controls.    Modifications to one converter  brought
        noise down from 115  dBA to 100 dBA.   Other converters  not  yet
        modified.  Arsenic exposures above proposed standard.   Three men
        per shift.                                   '
        r                                            I
    7)   Converter repair likely to involve serious dust exposures,  as for
        jackhammerman and others in reverb rebuilding.   Poorly character-
        ized.                     •                    !

    8)   Silica flux handling tasks reported by union to be very dusty.
        Poorly characterized.  One man per shift.      |
                                                       f
D)  Refinery Area
    1)   Molten blister copper by ladle to holding furnade(s) or refinery
        furnace.  Reduction  by "poling'' with natural gas.   Metal covered
        with coke.  "Black smoke" (unburned hydrocarbons)  emitted.   Canopy
        type hood above furnace.  Effectiveness unknown.   Hazardous expo-
        sures,  if any, poorly characterized.
    2)   Refinery tapper and  helper exposed to "irritating smoke."   Not
        characterized.  Two  men per shift.
    3)   Potential heat hazard during long casting runs.   Not characterized.
        Two to three men per shift.

E)  Auxiliary Operations
    1)   Lime plant crusher.   No local exhaust.  Dust exposures.  Free silica
        12%.  One man per day.   Poorly characterized.
    2)   Lime kiln operator.   Dust from lime transfer.   One man per  day.
        Poorly characterized
    3)   Lime slaker.  Irritating calcium hydroxide mist exposure.   No local
        exhaust ventilation.  One man per day.  Poorly characterized.

    4)   Flux crushing.  Siliceous dust exposure in crushing (ap'prox.  6  hours
        per day) and transfer (approx. 2 hours per day).   One  man per shift.
        Wetting but no ventilation.   Poorly characterized.
    5)   Acid plant.  Laborer's  job description hints at potential  dust  and
        arsenic hazards during cleaning of gas-cleaning equipment.

-------
                                                                         page 4
    6)   ESP  operator and helper.   Precipitate drier operator.  Poorly char-
        acterized.   Job descriptions suggest intermitteht high exposures to
        arsenic.                                        i
Comments:
COMPANY SAFETY AND HEALTH ACTIVITIES
A)   History.   Details unavailable
B)   Staff--for entire complex
        Director of Safety and Environmental Control
        Safety Engineer (1)
        Industrial Hygiene Technician (1)
        Respirator Maintenance Person (1)
        Supervisor of Environmental Control (1)
                                                   }m;
                                                   i;
                                                   mainly air-pollution
        Environmental Control Engineer (1}      _)  issues
        NOTE:   Staff has grown by 3-4 since early 1970s.
C)  Industrial Hygiene
    1)   Yearly sampling of some areas and work stations since 1973.
    2)   No reports or education given to workmen.
    3)   Results of monitoring are reportedly made available to the Inspec-
        tor of Mines since 1976.  That agency uses such to evaluate  hazards.
D)  Respirator Program.  No details available
E)  Safety
    1)   No accident investigations except those conducted through joint
        safety committee.
    2)   1973 OSHA 102 data on hand.  Other years not available.
F)  Health Care
    1)   Bayard clinic (under contract) or Silver City hospital (more serious
        cases)

-------
                                                                         page 5
    2)   No  nurse on premises.   Some first-aid training
    3)   Pre-employment physical.  Hearing tests availably yearly but not
        frequently taken by workers.  No clearly define^ hearing conserva-
        tion program.                                   'i
G)   Corporate activities are essentially educational and advisory to plant
    management.   Local activities are fairly independent (except investment
    decisions).
                                                            I
 Comments:                                                   i
SAFETY COMMITTEE                                         j,
A)  Description                                          :
    1)  More than a decade old                         I
    2)  Two-management representatives, two from each o'f four unions
    3)  1974 contract stipulates general characteristics, i.e., inspection
        tours,  accident investigations, written records, etc.
    4)  No occupational health concerns addressed by committee.
    5)  Records indicate that inspection tours focus on visible safety
        hazards.
Comments:
REGULATORY HISTORY
A)  Pre-1970
    1)  State Inspector of Mines

-------
                                                                         page 6
B)   Post-1970

    1)   State  Inspector of Mines                        (
                                                        i
            a)   Almost  exclusively a safety focus until-'1973, when limited
                health  activities were implemented.      '

            b)   Approximately two inspections per year. ' No union partici-
                pation.

            c)   Agency  still active.  Jurisdiction question vis a vis New
                Mexico  State OSHA plan (see below) still unclear.
                                                            !
    2)   State  OSHA plan                                     '

            a)   Administered by New Mexico Environmntal Improvement Agency.

            b)   Approved 12/75.  No smelter inspections\yet conducted.

C)  OSHA Activities                                     |

    1)   First  two inspections:  Safety.
    2)   Third  inspection:  Industrial Hygiene.  Citations for noise and
        personal protective equipment.

    3)   Fourth inspection:  Brief follow-up of (2) above.)
                                                         r
D)  MESA Activities

        For the period October  1973 through April 1976 MESA conducted
    6 safety inspections, 4 of  which  included among other areas the acid
    plant,  lime kiln and  the receiving area.

Comments:

-------
NAME
Rotary Dryer (for ppt . )
5-Hearth Dryer? (old roaster?)
Flux crushing plant
Rotary Lime Kiln
Reverb #1
Reverb #2
Converter (Pierce Smith)
Converter "
Converter "
Converter "
Holding Furnace
Holding Furnace
Holding Furnace
Refining Furnace
Acid Plant (double contact)
*Process flowsheet, Figures
AGE
1965
1962
N.A.
1941
1937
1950
1938
1938
1940
1972
1942
1943
1951
1940
1974-1975
2,3; Design
POLLUTION CONTROLS
Cyclone § baffle spray

N.A.
Cyclone
2 waste heat boilers;
it ii it • H
Tight fittings; water-
Gas to acid plant
None
Canopy-type hood while

(scrubber)



flue; ESP (40%
capacity) ; stack
cooled hoods .

poling only
Gas conditioning, ppts; scrubbers; drop-
out chambers; heat exchangers.
and Operating Parameters
for Emission Control
Studies: Kennecott, Hurley, Copper Smelter.
                                                                                                         OQ
                                                                                                         CD

-------
Number of
Employees
MATERIAL HANDLING
REVERBERATORY
FURNACE AREA
CONVERTER AISLE
REFINERY,
CASTING £ LOADING
ACID PLANT
43
43
37
44
6
Copper
mg/M3

0.20-2.3
.01-. 42


Arsenic
mg/M3

<^.03-0.9
^.003-. 09


Lead
mg/M3

.002-. 01
.003-. 006


Sulfur
Dioxide (PPM)

2.5-22
0-18


NOTES
Most exposures poorly characterized
Some likely Arsenic hazards. Some
estimates possible through job
descriptions, interviews, other
indirect sources .

Punchers exposed to up to six times
the allowable noise
Most exposures poorly characterized.
Some estimates possible through job
descriptions, interviews, other
indirect sources.

* Independent of respirator usage.

Sources:  OSHA Inspection records.
          State Inspector of Mines records.
                                                                                                               re
                                                                                                               00

-------
Inspections--Hurley
                                                                            page 9
E •
m
'74
'74
'74
TYPE
general
schedule
safety
general
schedule
health
general
schedule
safety
follow-up
to
4/22/74
FINDINGS PENALTIES FOLLOW'J-UP COMMENTS
15 non-serious
violations
3 non-serious
violations
16 non-serious
violations
3 non-serious
violations
$330.--
$130.--
$300.--
$80.--
i'
NONE
I
i
6/11/74 !
NONE
1
I
NONE

S02 : #2 reverber-
atory furnaces
Noise: #] -
3 converters

Respirator program
 :tions:   State of New Mexico, Inspector of Mines Dept.
       TYPE
FINDINGS
PENALTIES    FOLLOiy-UP








-
72



72


72

72-
72


n


13









safety



check-up

spot £
check-up


safety


safety

safety §
check-up
7 improvements
abated during
inspection
12 recommendations
smelter, refinery,
lime plant
3 recommendations
general
12 recommendations
mill-shops






1 notice


20 notices


16 notices


29 notices



































4/20/72
9 notices
abated
3 notices
unabated

3 notices
abated

17 notices
abated 3/1/73
14 notices
abated
10/9/73








Mill
Shops
Smelter
Refinery
Lime Plant
Quarry

Smelter
Shop
Refinery
Smelter
Shop
Refinery
Smelter
Shop
Refinery
Smelter
Shop
Refinery
Smelter
Shop
Refinery
COMMENTS*
            INFORM was unable  to  obtain  records  of inspections
                         for the  years 1974-1975.

-------
;ions:  State of New Mexico, Inspector of Mines Dept.  --cont'd)
                                                                          page 10
      TYPE
FINDINGS
                                      PENALTIES   FOLLOW-UP
COMMENTS


6


6
6

6
7
7
safety $
check-up

safety £
check-up


i
dust
safety $
check-up

electrical
Noise
safety $
check-up
22 notices
17 notices
mill-shops
2 notices
power plant
3 notices
acid plant
3 notices
14 free silica
samples
5 S02 samples
24 dust samples
23 notices
37 notices:
other
3 notices:
acid plant
3 recommendations
9 notices
16 notices











1
i
''\
19 notices ,
abated !
9/30/76 !

1
1
22 notices
abated
3/24/77 !
F
1


Smelter
Shop
Refinery

Mill-Shops
Power Plant
Acid Plant


Mill
Mill-Shops
Power Plant
Acid Plant

Mill-Shops
Power Plant
Acid Plant
Mines
Plant
   *This  column  lists  the  areas  covered by the inspection.

-------
FACT SHEET

Facility:   Nevada Mines Division, McGill Smelter

Company:   Kennecott Copper Company
                                                        INFORM
                                                        25 Broad Street
                                                        New York, New York
                                                        10004

                                                        (212) 425-3550

-------
GENERAL

Name:   Nevada Mines Division, Kennecott Copper Corporation
                                                      i'
Location:   McGill,  Nevada

Description:

    1)   Combination of McGill concentrator, green feed smelter and support-
        ive facilities.                                    j
                                                           i
    2)   Mine begun in 1907; smelter, 1908.
    3)   300 employees (170 concentrator, 130 smelter).

    4)   Ore from Ruth Pit.  Arsenic content .12%.  Othjer impurities unknown.

    5)   Largest employer in White Pine County.        |
    6)   Production (figures in tons)*                 !

                        1972        1973       1974    !   1975       1976
Copper
39,962
50,012
37,562
21,393
12,219
            * Includes copper produced from precipitates ;obtained by leaching
            waste dumps.                                '
Comments:
PROCESS AND HAZARDS

NOTE: The following comments evaluate TWA exposures independent of respira-
tor use.

NOTE:  Following an OSHA citation of 8/13/74, the company has supplied res-
pirators to most areas of the plant.  However, workers remain responsible
for maintenance, clean-up and storage.

NOTE:  Throughout the following remarks, the phrase "poorly characterized"
is used to indicate that we have found no evidence that either the company
or the regulatory agencies have sufficiently characterized the exposures to
permit proper evaluation and corrective action.

A)  Material Handling
    1)  Copper concentrates are received from the nearby McGill concentrator
        on open railroad cars, and unloaded into hoppers at the central
        dumping area.  After storage the concentrates are transferred by
        open conveyor belts to charge bins above one of the two reverbera-
        tory furnaces.  Arsenic and copper dust exposures throughout the
        area are poorly characterized.
    2)  Central dumper—documented violation for respirable silica exposures
        to laborer and tripperman, as well as documented housekeeping prob-
        lems, indicate potential exposures to copper and arsenic dust.
        Seven workers.

-------
    3)   Coal ball mill —OSIIA reports potential noise hazard.  Actual noise
        and other exposures are uncharacterized.      1

    4)   Conveyor belts — documented spillage from uncovered conveyors.
        Actual   levels  of  arsenic, copper and silica!.dust are uncharacter-
        ized.

B)   Reverberatory Furnaces

    1)   Concentrates  and flux are fed into one of two reveijberatory furnaces
        by  way  of tripper bin / shuttle conveyor system.   Ccjal is fed to
        reverb  \\2 by  a similar tripper bin system.   Matte is tapped into
        hooded  ladles and transferred to the converters  by overhead crane.
        Slag is tapped into a 200-yard "slag tunnel" which transports  it to
        the tailings  pond where it is granulated and plumped to the slag
        dump.                                          I

    2)   Feederrnan--documented TWA sulfur dioxide exposures above the exist-
        ing standard  prior to installation of "fume collection equipment."
        Effectiveness in reducing hazard levels is  unknown.   Excursions of
        S02 as  high as 20 times the existing standard during "puffs."
        Arsenic levels are uncharacteri zed.   General dus,ty conditions  re-
        ported  in the area.   Eight workers.             i

    3)   Skimmers--documented S02 excursion levels to eighty times  the  exist-
        ing standard.   Actual TWA SC>2 and arsenic exposures  are  uncharacterized
        Five workers.                                 I
    4)   Tappers —documented sulfur dioxide levels well above  existing  stan-
        dard.   Actual TWA sulfur dioxide and arsenic exposures  are  unchar-
        a-cterized.  Five workers.

    5)   Tripper—cited by OS HA  for sulfur dioxide TWA violations.    Docu-
        mented  excursion levels  of sulfur dioxide to twenty  times  existing
        standard during puffs,  prior to company-reported  enclosure  of  trip-
        per floor.  Effectiveness  of enclosure  in reducing'hazard  levels
        unknown.   Potential  arsenic exposures  are uncharacterized.   One
        worker.
    6)   Reverb  helper—actual exposures  to sulfur dioxide  and  arsenic  are
        uncharacterized;  however,  job description places  workers in  areas
        of  documented high sulfur  dioxide  levels.   OSHA citation for high
        noise levels  during  jackhammering  procedure.  Thirteen workers.

    7)   Flue dust handler--  OS HA indicates similiar operation  and  personnel  as
        converter dust conveyor operator.   Total dust TWA violations docu-
        mented  by OSHA for converter flue  cleaning.   Company  reports the use
        of  specially  equipped respirators  during operation.   Other exposures,
        if  any,  are uncharacterized.   One  worker.
    8)  Other workers —documented  dusty  and  gassy conditions in  area.
       Actual  exposures,  if any;  to  additional workers are uncharacterized.
       Nine workers.
   9)  Slag tunnel — documented  "safety  problem" in  slag  tunnel  in  1974.
       Problems  included  sulfur dioxide,  erosion,  lack of access,  sub-
       standard  guard  rails and structural  weaknesses.   Union reports no
       major changes  made since that  time.  Number  of workers varies.

-------
C)  Converter Aisle

    1)   Matte is transferred by overhead crane to charge four Pine-Smith
        converters (two of which are normally in operation).   The converters
        are primary hooded; however, mouth design problems have led to fugi
        tive emissions at hood-mouth seal.  Blister copper is then molded
        into cakes and transported for electrolytic refining. 23-27 workers.
    2)   Central platform—documented sulfur dioxide levels average at or
        slightly above existing standard for platforms on converters 112, 3
        and 4.   However, most severe exposures appear to be related to cop-
        per pouring and cooling schedules.  Excursions up to nine times
        existing SO^ standard during these operations.  Arsenic levels are
        uncharacterized.

    3)   Skimmer—documented sulfur dioxide levels in "general room" between
        converters #2 and 3 varied from below proposed standard to three
        times existing standard.  Excursions during other smelter activity
        are^documented.  Actual S02 and arsenic TWA exposures are uncharac-
        terized.  Nine workers.

    4)   Crane chaser—documented sulfur dioxide area levels above existing
        standard in converter aisle.  Job description places  worker in area
        "all the time."  Actual sulfur dioxide and arsenic TWA exposures are
        uncharacterized.  Four to five workers.

    5)   Dust coitveyor operator--OSHA citation for total dust  TWA  violations
        during cleaning and belt operations.   Company reports use of spe-
        cially equipped respirators during operation.   Other  exposures,  if
        any,  are uncharacterized.   One worker.

    6)   Converter helper—documented dusty conditions  during  "clean-up"  pro-
        cedures.  Other exposures,  if any.  are uncharacterized.   Three
        workers.
    7)   Converter punching—punching is accomplished with Kennecott  type
        punchers.  Workers report  maintenance problems similar  to  those  at
        Kennecott's Hayden smelter^	      	
    8)   Crane operators are represented by the IBEW.   The  union reports  that
        the company samples for potential hazards and  repairs  cabs  if neces-
        sary  upon request.   Actual  exposures,  if any,  are  uncharacterized.

D)  Auxiliary Operations

    1)   Silica-bentonite mixing area—documented violations  for silica  to
        the mixer and sacker prior to the design of mechanical  system.
        Extent  and effectiveness of system in reducing exposures  is  unknown.
    2)   Foundry—documented high noise levels  to operator  for short  duration
        of time (79-108 dBA).   Potential  problem of "gas and  fume"  rising
        from  furnace  to crane  cabs.   Actual  exposures,  if  any,  are  poorly
        characterized.   27 workers.
    3)   Areas of uncharacterized potential hazards  include  cake-casting
        (five workers),  waste  heat  boiler clean-up  and repair,  and ESP
        clean-up and  dust  handling.

-------
 Comments:
COMPANY SAFETY AND HEALTH ACTIVITIES

A)  History—Details unavailable

B)  Staff

        Safety and security director (1)
        Senior industrial hygienist (2)

        Safety inspectors (2)

C)  Industrial Hygiene

    1)   There are full-time industrial  hygienists at the division and com-
        pany levels.

    2)   The company performs some evaluatory sampling.   Exact frequency of
        sampling is unknown.

D)  Respirator Program

    1)   Respirators are supplied on a need basis, based on evaluatory sam-
        pling.

    2)   Education for respirator use and maintenance is supplied by  the com-
        pany following a 1974  OSHA citation.
    3)   Workers  are responsible  for maintenance,  cleaning and storage of
        respirators.

-------
E)   Safety                                            (

    1)   The company has established pre-employment safety orientation con-
        sisting of a safety booklet and instruction by!, immediate super-
        visors,                                        j,

    2)   Refresher safety education is administered through monthly safety
        meetings.

    3)   Company issues free of charge most necessary safety equipment.
                                                           |
F)   Health Care                                            I

    1)   Most medical care is administered through the public hospital in
        Ely, Nevada.  There is an emergency transportation system from
        McGill to Ely.                                j

    2)   The company has established an "emergency hospital" in McGill.
        Staffing consists of a registered nurse.       ,
    3)   There are first-aid trained foremen and guard^ on all shifts.
    4)   The company performs pre-employment physicals and "occasional"  hear-
        ing tests.

Comments:                                                '
SAFETY COMMITTEE

A)  Description
    1)   Department Safety Committee
            a)   Monthly meetings attended by a company representative,  plant
                safety engineer, one union representative per department,
                and the Steelworkers'  general plant safety man.
            b)   The committe discusses safety suggestions and inspects  each
                department.
    2)   General Plant Safety Committee
            a)   Quarterly meetings attended by the plant superintendent,  the
                company safety director,  and one union representative from
                each plant.
            b)   The committee acts on  safety suggestions originating from
                the Department Safety  Committee.
    3)   The  committees assist in most  accident investigations.

-------
Comments:
REGULATORY HISTORY
                                                       !
A)  Pre-1970                                           I
    1)  State Inspector of Mines                       :
B)  Post-1970
    1)  State OS HA Plan
     1                                                  I
            a)  Nevada Industrial Commission            \
            b)  pre-empted from the  enforcement  of health  regulations.
            c)  The Industrial Commission has  not  inspected the  McGill
                facility.                              i
C)  MESA Activities
                                                                     '^
                 -
    1)  MESA ha^ retained -j-u-ris diet ion  over the  central  dumpei>f  and has  per-
        formed both safety and health inspections  of the area.
Comments :

-------
PROCESS EQUIPMENT--McGill
                                                 Table 1
NAME
AGE
POLLUTION CONTROLS
COMMENTS
Reverberatory Furnace (2)
Converters (4)
(Pierce Smith)
Foundry
1903


Waste heat boiler -»•
ESP •+ stack
4 multi-cyclone
units -*- brick flue -»•
stack
Gas rises to roof
and passes through
vents to atmosphere.
There is presently no S02
control at the McGill
smelter.
SOURCES:   Design and Operating Parameters for Emission Control Studies
          Kennecott, McGill Smelter
          OSHA inspections

-------
tions--McGill
                                   Table 2
      TYPE
FINDINGS
PENALTIES   FOLLOW-UP
                                                                   COMMENTS
4
4
4
74

D-
75
accident/
fatality
complaint/
health
complaint/
safety
follow-up/
safety
follow- up/
safety
follow-up/
health
1 serious $600
violation
6 non-serious $215
violations
41 non-serious $1,030
violations
6 non-serious $240
violations amended
to $40
1 non-serious $80
violation
no new 	
violations
!
last
progress
report
August| 4,
1976 I
10/7/7,4
3/6/75 |
1
completed
5/14/75
	
contestment
was withdrawn
sulfur
dioxide,
silica, §
noise
violations

item #3
deleted;
contestment
withdrawn
1/75

levels of S02
similar to
8/13/74

-------
                                                    Table 3
 SUMMARY  OF  HEALTH  HAZARDS--MeGill
                                             TWA Exposures'
Number of
PLANT AREA Employees
Material Handling

Reverberator/
Furnace area



Converter area


Others

34

39 - 41



35


45

Copper
mg/M3











Arsenic
mg/M3











Lead
mg/M3










_.
OUO. -LUJ.
Dioxide
(PPM) NOTES


15 ppm TWAt
excursions
to 400 ppm


average
level ap-
proximately
10 ppm;
excursions
to 45 ppm

	 	
Respirable silica dust
violations in central
dumper.
fPrior to installation of
controls. Effectiveness
reducing levels is
unknown.
Documented noise viola-
tions for reverb helper
125%.
Total dust violation to
dust conveyor operator.


Includes maintenance and
-• -foundry workers,- _=-. 	
SOURCES:  OSHA inspections
          MESA inspections
* Independent of respirator usage

-------
FACT SHEET

Facility:   Magma Copper Company, San Manuel Smeltei

Company:   Newmont Mining Corporation
                                                     INFORM
                                                     25 Broad Street
                                                     New York, New York
                                                     10004

                                                     (212) 425-3550

-------
                                                                     Page  1
 I.   GENERAL                                           !
                                                      i
     Name:  Magma  Copper Company,  San Manuel  Smelter  l|

     Location:   San  Manuel,  Arizona                   ;'

     Description:

         1)   Combination of  concentrate receiving  facilities,  reverberator/
             furnaces  (3) , converters (6) ,  refining  furnacejs  (4) ,  casting
             wheels  (2),  and supportive facilities.         I

         2)   Smelter began operation  in 1956.   Magma became a  wholly owned
             subsidiary of Newmont Mining  Corporation in  1969.
         3)   Employees:   398 smelter  production.       !

         4)   Ore from  the San Manuel  mine  (containing approximately 1 billion
             tons  of ore - making  it  the largest underground copper mine in the
             world)  and the  underground Superior mine.. Old smelter slag has
             also  been processed to yield  approximately the same recoverable
             copper  content  as the San Manuel  ore, making  a substantial contrib-
             ution to  total  production.                  I

         5)   Area's  economic base  largely  derived  from mining,- milling, and
             reduction of copper ores.                   !

         6)   Production*:
1973
Copper (tons) 158,300
Sulfuric Acid (tons) 	
*Figurcs for other San Manuel pr
1974
149!,600
-- -
oducts go
1975
139,000
;;o3,ooo
Id , si Iver ,
urn
145,000
DNA
and
                 molybdenum  sulfide  -  were not  available to INFORM.

     Comments:
II.   PROCESS  AND  HAZARDS

     NOTE:   Respirators  are  company supplied and  worn  on  a  need basis.  The
     following  comments  evaluate TWA exposures  independent  of  respirator use.

     NOTE:   Throughout  the  following remarks, the phrase  "poorly  characterized"
     is  used to indicate  that  we have found no  evidence that either the company
     or  the  regulatory  agencies  have sufficiently characterized the exposures to
     permit  proper evaluation  and corrective action.

-------
                                                                      Page 2
NOTE-:   All  documented arsenic exposures are expressed i|i terms of the new
10 yg/m  standard.   May worker exposures, while below tljie standard, are
above  the action level (5 ug/m3).   Therefore these workers will be re-sub-
jected to the monitoring and medical surveillance requirements as set forth
in the standard.

A)  Material  Handling (feed preparation area)

    1)  Ores  from the San Manuel mine are concentrated in thle San Manuel
        mill  prior  to transfer to 500-ton concentrate storage bins located
        adjacent to the smelting complex.  Concentrates from other sources
        (i.e., the  Superior concentrator) are received by railroad car and
        transferred to the bin storage area.  Fluxes (silica and limestone)
        are crushed and prepared in the Lime Plant and jalso transferred to
        storage bins prior to transfer to the smelting 'circuit.  The feed
        materials are transferred to the reverberatory Building by a series
        of overhead covered conveyors.  Poor housekeeping conditions docu-
        mented at the walkways along the conveyors leading to the reverb
        building.

    2)  Charge Operator and Sub-charge Operator-- Supervises the loading and
        unloading of the storage bins.  Also performs air' lancing tasks when
        laborer's crew not available.  Exposures to potential arsenic,  cop-
        per,  and silica dusts presently uncharacterized.  ' (4 workers)
                                                       I
    3)  Laborers--  Principal job duties entail the unlcjading of the bins by
        using air lances to blow the materials down the sides of the bins
        and general clean-up duties such as shoveling up spills of materials
        around the  bins.  Potential exposures to arsenic,  copper and silica
        dusts are presently uncharacterized.  Potential noise exposures,
        especially  during air lance use, are presently poorly characterized.

    4)  Standard safety equipment-- Safety lines and belts are provided to
        employees while working above these storage bins.

B)  Reverberatory Furnace Area  (81 workers)

    1)  Three suspended-arch furances.  All three furnaces are usually  oper-
        ating at full capacity at  all times.  A five-year  campaign conducted
        on  the furnaces before rebuilding is required.   The #2 reverb was
        recently rebuilt, and the  #1 furnace is presently  shut down for
        rebuild.

    2)  Reverb Charge Deck--  Feed materials enter the reverberatory furnace
        building proper where  tripper belts distribute it to charge bins.
        Employees work over the reverberatory furnace on platforms elevated
        approximately 75 feet from the floor.   Jobs in this area entail
        managing the distribution  of concentrate and flux  into the charge
        bins.   Specific tasks include shoveling up spills  of material  around
        the bins and cleaning the  bins with air lances.
           a)   Charge and Sub-charge Operators:  Documented sulfur dioxide
                exposures above the present standard.  Potential exposures
                to  arsenic and copper dusts during air lance use and loading
                operations are poorly characterized.  Potential noise expo-

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                                                                  Page 3
            sures during air lance use are also poorly characterized.
            (4 workers)                             I

        b)  Departmental Laborers:  These workers perform clean-up tasks
            throughout the reverberator/ department:,  Their exposures
            vary, depending on the conditions in the'area where the em-
            ployee is working.  They are presently uncharacterized.
        c)  Since a 1975 citation by OSHA, the company has attempted to
            abate the excessive levels of sulfur dioxidej in the upper
            reaches of the reverberatory building by the,1 installation
            and the improvement of various engineering controls.  These
            controls and improvements include:     i

                --Water cooled charge hoppers were [installed.   However,
                  the company has stated that the hoppers continue to be
                  a source of sulfur dioxide leakag'e.  The company in-
                  formed OSHA that they are presently studying the
                  feasibility of implementing a different method of
                  feeding the reverbs "as yet untrr'ed in the industry."

                --Roof fans:  In order to enhance/improve the  "chimney
                  effect" and improve the flow of makte-up air  through
                  the building, the company has increajsed the number of
                  roof fans and altered the configuration of various
                  walls throughout the smelter.    ,  '•
        d)  Upon OSHA's  return in late 1977 for ajfollow-up inspection,
            the Industrial Hygienist noted that the; employees' exposures
            (sub-charge operators) had not changed, even after the im-
            plementation of various controls.  The company's response in
            the latest progress report was that they are presently plan-
            ning to install a control cab on the tripper.

3)   Feed Deck--  The reverberatory charge is fed to one of the three
    reverbs by way of a belt tripper that moves along the furnace side-
    wall unloading the materials into water-cooled hoppers which feed
    the down chutes leading into the furnace.
        a)  Feederman:  Manages the distribution of the feed into the
            furnaces.   OSHA documented sulfur dioxide levels of up to
            35 ppm.  The most recently available company figures show
            feederman exposures ranging between 2 and 13 ppm--all above
            the proposed OSHA standard.   Documented arsenic exposures
            above the new arsenic standard.   Noise levels were found to
            be below the standard.  (15 workers)
        b)  Helper:  This job category includes the spoutman and the
            arch-blowers.   The spoutmen work in the converter  slag re-
            turn area where they clean the slag from the spouts that
            load into the furnace.  Potential exposures to sulfur diox-
            ide, during the return of slag and from leakage through the
            spout,  are poorly characterized.   Other exposures, if any,
            are poorly characterized.   The arch-blower's job is to blow
            the reverberatory roofs clear of dust by using compressed
            air lances.   Documented exposures to arsenic at the stand-
            ard, and documented exposurs  to  sulfur dioxide above the
            present standard.   OSHA documented  noise levels  at greater

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                                                                  Page 4
            than 115 dBA with the equivalent 8-hour (TWA at 110 dBA.  The
            company submitted plans to OSHA in regard to eliminating the
            blowing of the arch by replacing air lan,ce use with a vacuum
            system.  The company stated that they have repeatedly tried
            vacuuming; however, the roofs are still 'blown.  (13 workers)
        c)   Aside from dust, gas, and noise exposures, another hazard
            experienced in this area of the reverbs (feed deck) is blow
            backs from the furnace.  In 1976, a worker w^s severely
            burned after such an event.  A blow back occjirs when the
            furnace experiences a build-up of gases that occasionally
            flair up and vent out the feed chutes or other openings in
            the reverberatory roof such as the slag spout.  The State
            Mine Inspector cited the company for not providing adequate
            protective clothing.  Reverb workers arp now required to
            wear flame-proof jackets.
                                                   i
        d)   The company installed a White-Cap System for use by all em-
            ployees working above the reverbs.   The! company experienced
            "considerable difficulty" maintaining this respiratory pro-
            tective  equipment when first installed in 1976.   In 1977,
            the company reported that the system is "flow effective and
            probably more significant in SC^ protection than it was at
            the time of installation."  The Union reports that the
            system is no longer used (1978).          i
                                                   !
4)   Matte and Slag Tapping Areas-- Once tapped, the; matte flows through
    a matte drop hole to a ladle car.  This ladle car is located in a
    tunnel  that travels the length of the furnace to the converter
    aisle.   Several ladles are filled before being brought out to the
    aisle by a cable system that pulls the cars back and forth.  Two of
    the reverbs are equipped with operating exhaust enclosures--dog-
    houses--that cover the tap hole, the launder, and the drop point to
    the tunnels.  The company is currently planning to redesign the dog-
    houses  to allow for the use of new tapping  equipment that they plan
    to install.  This new design will be the company's fifth  attempt at
    capturing sulfur dioxide at the tapping points and exhausting it ^awa
    from areas where employees are working.  The slag tapping is neither
    enclosed nor ventilated.   The slag is tapped and loaded into cars
    loaded  into cars located in the slag tunnel beneath the reverb.

        a)   Tapper and Tapper Helper:  Worker opens and closes tap hole
            and manages the flow of matte into  the ladle cars.  The
            company reports that the tapper is  exposed to S02 levels
            ranging from 1 to 16.8 ppm.  OSHA documented arsenic expo-
            sures  above the standard.  Other exposures,  if any, are
            poorly characterized.  (19 workers)
        b)   Slag Motorman:  Opens and closes  the slag tap hole, manages
            the flow of slag into the slag train ladles, and  drives the
            slag train to the slag dump.   The company reports that
            sulfur dioxide exposures are below  the standard.   Other ex-
            posures, if any,  are poorly characterized.   (18 workers)

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                                                                      Page 5
            c)   Some employees must work intermittentlyjin the matte and
                slag tunnels.  These include maintenance men, electricians,
                and equipment operators.  Exposures, if'i any., while working'
                in these tunnels are poorly characterized.  Union filed
                complaint in regard to operating a D-8 loader in the tunnel
                without adequate "headache" protection.  These loaders are
                occasionally brought into the tunnels for clean-up purposes.
                The State Mine Inspector issued an order prohibiting use of
                the loader in the tunnel until protection is! provided for
                the operator.                               '

    5)   Reverb  Man--  This job category is a combination of two jobs:  con-
        trol room operator and furnace operator.  The jbb includes checking
        the furnace for adequate feed, determines when 'the matte and the
        slag should be tapped, checks to ensure that adequate draft is main-
        tained, and other duties relating to the overall!  operation of the
        furnace.  The reverb man does not remain at one; job station since
        his duties require him  to be at different stations throughout the
        reverberatory furnace department.  The company reports sulfur diox-
        ide exposures above the proposed standard.   Other) exposures are
        poorly  characterized and dependent on the area inj. which he is work-
        ing. (12 workers)

C)   Converter Area  (45  workers)

    1)   Watte from the reverberatory furnaces is transferred in ladles to
        one of  the six Fierce-Smith  converters by an overhead crane.  A
        siliceous flux is added to the converters.   Gases from the converter
        process enter water cooled primary hoods over each converter and are
        then ducted to the acid plant.  At the completion of the converter
        cycle,  blister copper is transferred to the anode casting area.

    2)   Crane man-- There are four overhead "hot metal" cranes--three in
        operation.   After an OSHA citation for sulfur dioxide exposures  to
        crane men,  the company began experimenting with new air purifying
        devices on one of the cabs.   Company abatement data submitted to
        OSHA indicated that sulfur  dioxide levels  have been reduced to
        below the proposed standard.  However, the company submitted expo-
        sure data, during the 1977 S02 hearings that indicated craneman expo-
        sure levels were above proposed standard.   The company later re-
        ported  that it was having problems with the durability of the unit
        and was experiencing a shorter than expected lifetime of the filter-
        ing media.   As a result,  such units have not as yet been installed
        in  the  other crane cabs.   Union reports that respirators are at
        times needed in  the crane cabs.  OSHA documented  arsenic exposures
        above the standard.   (9 workers)

    3)   Skimmer-- Operator of the converter.   OSHA  documented SO? levels
        above the present standard.   Company industrial hygiene data from
        early 1977  indicated SO,-,  exposures for skimmer platform as being
        below the proposed standard.  Personal exposures  are reported as
        variable with some exposures above the proposed standard.   The union
        reports that the skimmer platforms at the  #5 and  #6 converters are

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                                                                      Page 6
        high S02 areas.   Arsenic levels were found to bi at or below the
        arsenic standard.  Company was cited for excessive noise exposures
        in this area.   Noise sources affecting the skimmers are the tuyere
        punching operation (see Punchers) and the reverb,eratory furnace
        burners.  The  company installed an acoustical wall at  the burner
        end of the reverb; however, it was destroyed by swinging crane
        hoods  before  any evaluation of its noise level abatement capabili-
        ties could be  made.  Since the company is presently converting the
        reverberatory  furnaces' fuel supply from natural gasj to coal,  a hold
        has been put on any additional construction of sound barriers  in
        this area.  The company's research has indicated that coal firing
        burners may be much quieter.  A partial enclosure is, however, being
        designed and built to reduce skimmer exposure from the tuyere  noise
        and other background noise sources, such as the] reverb burners.
                                                       I
    4)   Puncher--  Punching performed mechanically by pneumatically operated
        tuyere punchers.   The puncher operator sits on a moving cart and
        operates this  mechanism.  Company industrial hygiene  data shows  that
        sulfur  dioxide levels in the punching area are above the present
        standard.  Trace  metal exposures are presently poorly characterized.
        Company was cited for excessive noise to the puncher--often exceed-
        ing 115 dBA.  The company abatement program included  the installa-
        tion of Noranda Tuyere Silencers on all the converters.   Leaks in
        the air lines  to  the tuyeres were also found to be problematic.   To
        eliminate this noise source, the company has bqgun replacing the
        lines with "a  new, longer, and more durable flex-line."  The company
        reported to an OSHA hygienist that they were thinking of punching
        the converters remotely from an enclosed booth by using a laser  as
        the aiming, device.  The company's latest quarterly report, however,
        does not discuss  this concept.  Instead, they are partially enclos-
        ing the punch  car cab and presently evaluating its effectiveness.

    5)   Silica Belt Tender (sub-charge'operator)-- These workers spend a few
        hours every other shift managing the distribution of  silica fluxes
        into the converter flux storage bins.   The flux belt  gallery is  not
        enclosed—subjecting these workers to high levels of  sulfur dioxide.
        Other exposures--arsenic, silica dusts, etc.--are at  present poorly
        characterized.

    6)   Converter Laborer-- Performs various tasks in the converter aisle
        and around the adjacent converters. Potential exposures to arsenic,
        sulfur dioxide and noise are poorly characterized.  (3 workers)

    7)   Converter Aisle Equipment Operator--  Cabs are not enclosed.  Expo-
        sures are poorly  characterized.   (3 workers)

D)   Anode  Area (81 workers)

    1)   Four anode furnaces and two casting wheels

    2)   Blister copper from the converters is transferred by  overhead  crane
        to an anode furnace where a final blow and subsequent deoxidation,
        using reformed gas, takes place.  Anodes are poured in the casting
        wheel and after being cooled, are transported to the  neighboring San
        Manuel Refinery for electrolytic refining.

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                                                                            Page  7
    3)  After  a worker complaint in 1976 (regarding high sulfur dioxide
       levels  "in all of the smelter"), an OSHA hygienist  found S02  concen-
       trates  on  the Anode Floor at the present standard.   During  the in-
       spection one  interviewed worker stated that the;.gas (S02) comes when
       the  wind "sets up" the valley and is only bad when  several  of the
       converters are out of the stack at the same time.   TWA exposures in
       the  anode  area are poorly characterized.

    4)  Trace  metal,  noise, and heat exposures, if any are  uincharacterized.

E)   Acid  Plant Area  (19  workers)

    1)  The  2,400  TPD single contact was completed and placed on-stream in
       December of 1975.   If the total amount of acid produced cannot be
       sold or it it exceeds the avialable storage capacity,  it is neutral-
       ized in an adjacent acid neutralization plant.  ,

    2)  Exposures  to  workers (acid plant men,  helpers,  'and  departmental
       laborers), if any, are poorly characterized.

F)   Electrostatic  Precipitator Area

    1)  Dusts  from the reverberatory precipitator are combined with lime and
       processed  in  a pug mill before being returned to the reverberatory
       furnace feed  in the materials handling area.   Dusts from the  conver-
       ter  precipitator  are taken by truck to the reverberatory furnaces or
       loaded into ladles and fed to the converters.

    2)  Potential  exposures to copper and arsenic dusts are poorly  charac-
       terized.   Other exposures unknown.

G)   Others   (158 workers)

    1)  Due  to the transient nature of a selected number of jobs, INFORM has
       created an "Others" category.  While many of  the workers  on this
       list may be permanently associated with one sub-department  of the
       smelter--i.e. , some of the laborers work full-time  in  the material
       handling areas—we have been unable to differentiate these  workers
       from their transient counterparts.   Hence they are  included in this
       category.   These  workers are listed as follows:

            Laborers-- 102 workers

            Utilitymen—  28 workers

            Brick  Masons-- 14 workers

            Equipment Operators-- 11 workers

            Tool Tender--  1 worker

            Mechanical Sweeperman-- 1 worker

            Janitor--  1 worker

    2)  Most exposures for these employees  are poorly characterized.

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                                                                        Page
Comments :

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                                                                      Page 9
COMPANY  SAFETY AND  HEALTH ACTIVITIES                   I
                                                       i
A)  History                                             /
                                                       'i

    1)   Industrial  Hygiene Program.   In June of 1975, an  Industrial Hygien-
        ist-in-training was added to Magma's staff.   Other historical
        details  were  not available to INFORM.

    2)   Safety Program.   History of Magma's safety program nlot available to
        INFORM.                                              j

B)  Staff                                               :

    1)   Safety Director                                I

    2)   Safety Engineers (2)                            I

    3)   Director of Environmental Affairs              !

    4)   Industrial  Hygienist  (in training]              '

    5)   Safety Aide (respirator man)
                                                         l
C)  Respirator Program                                    i:

    1)   Administration  of program is the responsibility of the Division
        safety department.  Training,  education,  and supervision  of respira-
        tor usage is  the responsibility of  plant  managers,  superintendents,
        and--department  heads.

    2)   All workers are assigned and fitted to a  respirator according to  the
        hazard present  in their work areas.   They are responsible for daily
        cleaning and  maintenance of respirators.

    3)   A permanent employee  (safety aide)  was hired to service the respira-
        tors.  Each week respirators are exchanged for ones that  have been
        repaired and  sanitized.

D)  Safety Equipment

    1)   All required  safety equipment  is loaned to employees,  except  safety
        shoes with  metatarsal  guards which  must be bought outright  by the
        worker.

E)  Industrial Hygiene  Activities

    1)   Area and personal  sampling for sulfur dioxide and noise performed by
        hygienist.  No  evidence  that the company  samples  for other  in-plant
        hazards.

    2)   INFORM was  unable  to determine the  extent and frequency of  the in-
        plant sampling  program.

    3)   No formal reports  or education are  given  to  workers regarding the
        need, objective,  and results of industrial hygiene sampling.

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                                                                     Page 10
   4)  The company provided  limited  industrial  hygiene;related  data  during
       the course of  the OSHA  sulfur dioxide hearing,  /Magma did  not parti-
       cipate in the  arsenic hearings.                 'i

F)  Safety Program

   1)  Smelter safety program  as  well as  the safety programs throughout  the
       San Manuel complex  are  under  the  direction of the  Safety Director.
       Safety acitivities  are  carried out by two safety engineers.

   2)  Extent and frequency  of safety inspections unknown to INFORM.

   3)  Accident investigations are conducted by companjy;  however, workers
       are not allowed  to  participate.   Written report's prepared  at  the
       conclusion of  the accident investigations are not  available to  the
       union.                                         >

   4)  New employees  are instructed  on the general  safety aspects of their
       jobs prior to  employment in the smelter.
                                                        I
   5)  Formal safety  refresher courses for all  workers  ajre not  available.

   6)  Safety training  for new equipment  and process changes is provided on
       a limited basis.

   7)  OSHA 102 data  is available for 1974,  1975, and'1976.

G)  Health Care

   1)  Smelter complex  has a first aid station  staffed by a nurse.   Aside
       from general first  aid,  nurse performs yearly pulmonary  function
       exams.

   2)  Company owns and operates  its own  hospital in San  Manuel, with  phy-
       sicians on call  24  hours  a day.   Union reports,  however, that
       while "on call," physicians are not always available.

   3)  Emergency transportation is available at  the plant.   The ambulance
       is operated by a plant  guard,  who,  the union reports,  is not  readily
       available.

   4)  All employees  receive a physical  examination prior to employment.
       Periodic health  monitoring—excepting pulmonary  function exams  and
       audiograms--are  not provided  to workers.   Salaried employees  receive
       yearly physicals.

   5)  Hearing program
           a)   The company performed a plant-wide noise survey  to determine
               areas  where noise  levels  exceed  85 dBA. Areas found to  be
               above  this  level were designated  in  writing and  posted.

           b)   All workers in  designed areas were given an audiogram.  _In
               1976   the second year of  this program, the company initiated
               an annual resereening audiogram  program  of the exposed  work-

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                                                                      Page 11
                force.   More frequent testing—in some (pases quarterly—for
                those workers showing "a shift in hearing acuity and for
                those with an apparent, large-, absoluteness."
                                                       'i
            c)   If a further loss of hearing is noted, the worker is moved
                out of the designated area or occupation.  Workers do not
                retain wage rates if they are forced to change jobs as a re-
                sult of an occupational injury or illness.

            d)   It is the company's position that hearing protection can
                prevent "deterioration of hearing acuity if (the employee
                will use it without fail."  If worker audiogr'am results show
                a  shift in hearing acuity, the company assumes that the
                worker  failed to wear hearing protection properly and as a
                consequence he is removed from the exposure.

            e)   INFORM  has not found any evidence that the company performed,
                either  through contract or through its medical department,
                any epidemiological or medical research, studies.
Comments:
SAFETY AND HEALTH COMMITTEE

A)  There  is  no  joint  safety and health committee at the San Manuel  complex.

B)  The union appoints a safety man from each division of the complex — mine,
    mill,  smelter,  refinery.  Each representative is then allowed to accom-
    pany the  company's safety engineer on an inspection of his  respective
    division  every six weeks during which time "he shall cooperate in  making
    recommendations with respect to safety."  The areas entered for  the  pur-
    pose of inspection are at the discretion of the company's engineers.

C)  At the conclusion  of the inspection tour, a report is prepared and for-
    warded to the union.

D)  There  is  no  contractual right to refuse unsafe or unhealthy work.

E)  The union does  not have the right to review the results of the company's
    industrial hygiene monitoring.

F)  The International  does not have the right to enter the plant for safety
    and health issues,nor is it allowed to review company-produced materials
    regarding safety and health.

G)  Workers do not  retain wage rates if they are forced to change jobs as  a
    result  of an  occupational injury or illness.

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                                                                      Page 12
Comments:
REGULATORY HISTORY

A)   Pre-1970                                            ,
                                                       I
        Office  of State Mine Inspector                 |

B)   Post-1970

    1)   State OSHA  Plan

           a)   Developmental.   Headed by Arizona Industrial Committion.
                Approved October,  1974.                   I1

           b)   Jurisdiction over  smelters still in hands: of State  Mine
                Inspector
                                                       j
    2)   Office  of State Mine Inspector                 !

           a]   No  contractual  relationship exists  with Arizona Industrial
                Commission.

           b)   Two to  three inspections  per year,  1972-1976.

           c)   Limited industrial hygiene efforts.

    3)   OSHA Activities
           a)   OSHA has inspected smelter ten times.   All  were due  to
                worker  complaints.

Comments:

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NAME
Reverberator/ Furnaces (3)
[Suspended arch]
Converters (6)
3 - 13'x35'
2 - 15'x35'
1 -
Anode Furnaces (4]
Casting Wheels (2)
Acid Plant
Acid Neutralization Plant
AGE
1956
1956
1956
1975
1956
1956
1975
1975
POLLUTION CONTROLS
Waste Heat Boilers -> ESP + 515'
Stack
Radiation/Conductive cooling ducts -> ESP
Scrubber Cooler -> Acid Plant -> Stacks


Tail gases vented through (2) 200' stacks

COMMENTS
Green feed operation.
Gases that by-pass Acid Plant «
are vented through 550' Stack,;


2400 TPD with two parallel
single contact sections.

SOURCES:   Design and Operating Parameters for Emission Control Studies
          Magma, San Manuel,  Copper Smelter

          An Industrial Hygiene Study of the Magma Copper-Company
          Smelter [NIOSH Study~                           	 — —
                                                                                                                    -0
                                                                                                                    P

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Number of
PLANT AREA Employees
Material Handling
Reverberatory Furnace
Converter
Anode
Other
(including acid plant]
14
81
45
81
177
TWA Exposures*
Copper
mg/M3

L >2



Arsenic
pg/fm3
i
<10-60
<10-40

<40
Lead
mg/M3





Sulfur
Dioxide
(PPM) NOTES

35
l.S->30
10

Worker exposures in material
handling (bins to reverb)
are uncharacterized.
S02 excursions greater than
200 ppm. Arch blower exposed
to noise levels .> 115 dBA.
Skimmer and puncher noise
exposures > standard.

Most exposures poorly charac-
terized.
* Independent of respirator usage

SOURCES:  Sulfur dioxide OSHA hearings, 1975.  Company data,
          OSHA inspections
          OSHA/company abatement correspondence
          Arizona State Mine Inspector inspections
          NIOSH data
                                                                                                                     00
                                                                                                                      CO

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                                   Table 3
'ECTIONS  --  MAGMA,  San Manuel Smelter
;c of Arizona,  State Mine Inspector
                                                                         Page 15
''
,8/71
1/72
16/72
/701
/701
/711
/73
73
/73
3/74
TYPE
Safety
Dust
Survey
Safety
Dust
Survey
Safety
Dust and
Toxic Gas
Survey
Dust
Survey
Special
Inspection
Safety
Safety
FINDINGS PENALTIES FOLLOW-UP , COMMENTS
4 -0- Company Machinery guards , fire
violations abatement extinguishers, gratings.
letter ,
No --.- S02 levels in tripper
violations : belt area 14-18 ppm (not
cited) . Poor housekeeping
tripper floor.
20 -0- All viola- • Poor housekeeping -
violations tions abated excessive dust build-up
within 60 t on steel beams.
days .
No 	 l NO counts above limit.
violations j,
2 -0- All viola- ; S02 above limit. House-
violations tions were keeping exceptionally
subsequently good.
abated.
No 	 Two S02 counts above
violations limit.
No 	 Si02 measurement above
violations standard not cited.
S02 "fairly high" in some
areas .
No 	 Special inspection investi
violations gating State Sen. Ulm's
24 complaints describing
unsafe or unhealthy condi-
tions in the smelter.
? ? Inspection results not
available to INFORM.
9 _0- Violations concerned guards
violations covers, safety chains, etc.
1/74    Safety  -        No
       Acid  Plant      violations
Good housekeeping and drain-
age in the Acid Plant.

-------
pections--San Manuel [SMI], continued)
                                                                        Page  16
       TYPE
FINDINGS    PENALTIES   FOLLOW-UP   I   COMMENTS
/75 Complaint
'75 Safety
'75 Abatement
inspection
'5 Safety
'6 Complaint
76 Complaint
6 Accident
investigation
Toxic Gas
76 Inspection
'i
1 -0- Variance !' Complaint re use of Dozer
violation granted in matte tunnel without
"headache bar".
6 (smelter) -0- Dipt conditions must be
violations improved in smelter.
	 --- , Violations of 2/15/75
abated.
5 -0- Investigate the engineering
violations • solution to the precipitator
dust handling system.
i
1 -0- Abated : #4 converter crane not in
violation immediately compliance steel plate
1 over "deadman" switch.
No 	 < Complaint re solitary
violations ; employment, high temper-
encountered atures, and no ventilation
' at sub-charge operator's
station.
1 -0- Employee severly burned
violation during smelter "blow-
back".
5 -0- All S02 samples above TLV's
violations Levels range from 22 ppm
                                                             125  ppm.

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                                  Table  4

ACTIONS -- MAGMA,  San Manuel Smelter
                                                                        Page  17
       TYPE
           FINDINGS
PENALTIES
                                             FOLLOW-UP
                                                     COMMENTS
'72     Complaint  In
                  Compliance
                                                     Found complaint to be in-
                                                     valid.   Management-Labor
                                                     issue.
'73     Complaint   In
                  Compliance
                                                     Employee discharges  because
                                                     refused unsafe work.   CSHO
                                                     found that "facts  as  stated
                                                     in complaint were  not entire!-
                                                     the same as observed  at  the
                                                     actual scene.   Employee
                                                     reinstated.
       Complaint   In
                  Compliance
                                                     Employee  complaint  re  heat
                                                     stress  in tank  house.
'/74    Complaint   2  citations
75                (5 non-serious
                  items)
                             $45.       abatement     I'Cited    1.  noise    reverbs
                                       plan  sub-     'for:     2.  noise  -  converters
                                       mitted        :         3.  S02    -  reverbs,
                                                  I                      cranes
                                                             4.  no  emergency  eye  §
                                                                body flushing
                                                                facilities
                                                             5.  noise  -  rod plant
 /74    Complaint   1  citation       $35.
                  (7 non-serious
                  items)
                                       recommended
                                       by  CSHO
                           Complaintant listed 24 hazard:
                           that he believed  existed.
                           Union rep was "somewhat
                           disturbed over way which
                           complaintant had acted...they
                           [Union] had a safety committee
                           that took care of [such]
                           problems ....
       Complaint   1  non-serious    $35
 75                violation
                                      recommended
                                      by CSHO
                           complaint re inadequate
                           respirators.   Company abated
                           by initiating new respirator
                           program.[S02-Sub-charge area
      Complaint   In
                  Compliance
                                                    Complaint  re  lack  of  lunch
                                                    room  for smelter repair  crew.
                                                    Lunch room available  in
                                                    general vicinity.
 75
Complaint  In
           Compliance
                                                           Reverb worker complained abou
                                                           elimination of White Cap
                                                           protective equipment.  OSHA
                                                           only requires approved
                                                           respirators   which were
                                                           issued.

-------
iCTIONS -- MAGMA, San Manuel  Smelter
(continued)
                                                                       Page  18
      TYPE
           FINDINGS
PENALTIES
FOLLOW-UP
                                                           COMMENTS
/75   Complaint   1 non-serious     $0
      [Health]    violation
                                        none
                           Complaint re condition of
                           holding vessels.  Company now
                           under a repair schedule to
                           correct this condition.  Othei
                           areas of complaint not cited
                           since company under an
                           abatement plan.
/75    Complaint  no  violations
       [Safety]
                                                     Safety  inspection  for  12/10/7!
                                                     complaint  inspection.   CSHO
                                                     noted that "there  appears  to
                                                     be  a lack  of  communications
                                                     between employees  and  super-
                                                     vision  to  inform them
                                                    I(employees) of  maintenance £
                                                    j,repair  schedules".
 76     Complaint   In
                  Compliance
                                                    Complaint  re  S02  levels    no
                                                    'violations found  that  were
                                                    not  already cited and  under
                                                    an abatement  schedule.
 76
Complaint  3 non-serious
           violations
             company       Complaint re unsanitary
             abatement     conditions in lunch room  
-------
FACT SHEET

Facility:   New Cornelia Branch, Ajo Smelter

Company:  Phelps  Dodge Corporation
                                                       INFORM
                                                       25 Broad Street
                                                       New York, New York
                                                       10004
                                                       (212) 425-3550

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GENERAL
                                                      I
Name:  New  Cornelia Branch,  Ajo Smelter               i
Location:   Ajo,  Arizona                               ;i
Description:
    1)   Combination of open  pit mine, concentrator, green feed smelter,
        anode  casting, and supportive facilities.
    2)   Smelter  built in 1950; mill in 1922.               j
    3)   Employees:   176--concentrator; 129--smelter; 1,400-!-mine.
    4)   Ore from New Cornelia open pit mine, as well as  some custom work.
        Arsenic  content of concentrate "less than  .005%" as reported by
        James  E.  Foard, Phelps Dodge metallurgist.    j
    5)   Largest  employer in  Pima County               '
    6)   Production
                                                      j
          a)   Approximately  1/6 of Phelps Dodge's total
          b)
1972
1973
1974
1975
1976
Copper
(short tons)
Acid
57,876

53,799

1
43,501,

33,025




Comments:
PROCESS AND HAZARDS--SMELTER
NOTE:   Workers  are issued company-supplied respirators; however, use is not
mandatory.   Workers are responsible for maintenance and storage.  OSHA
inspection  of 2/24-26/76 indicated use but lack of clean-up program for USBM-
and NIOSH-approved respirators.  Level of recorded exposures precluded
establishment of comprehensive program.
NOTE:   The  following  comments evaluate TWA exposures independent of respira-
tor use.
NOTE:   Throughout the following remarks, the phrase "poorly characterized"
is used to  indicate that we have found no evidence that either the company
or the  regulatory agencies have sufficiently characterized the exposures to
permit  proper evaluation and corrective action.
A)  Material  Handling
    1)   Concentrates  are transferred from the Cornelia Mine by uncovered
        conveyer belts.  Exposures are uncharacterized but dusty conditions
        prevail.

-------
    2)   Concentrate  passes  through filter and drying bililding;  open conveyer
        to  charge  can filling area.   New swivel conveyejr hood of unknown
        effectiveness.   Background exposures to arsenic ijand S02.   Six men.

B)   Reverberatory  Furnace

    1)   One sprung arch  type furnace situated parallel to converter aisle.

    2)   Arch last  rebuilt June 1976.  Workers compalined of excessive heat
        and dust.  OSHA  found allegations to be unfounded, jforeman appar-
        ently relieved of duties.  Approximately 22 workers to rebuild.
        Exposures  are uncharacterized.

    3)   Charge cans  are  tranferred by overhead cranes to three  charge
        points on  each side (north and south) of reverberatory  furnace.
        Crane cabs are enclosed but  not pressurized.   Exposure  levels are a
        source of  union/management friction.   Three men.
    4)   Reverb is  fed by high speed slinger system.  Operator is exposed to
        levels of  arsenic above the  proposed standard.!  Sulfur  dioxide  expo-
        sures are  poorly characterized.

    5)   Reverberatory arch  cleaning  is  the responsibility of reverberatory
        laborer #2.   Cleaning actually occurs no more than once  a week.
        Vacuum system all but discontinued, arch is air  lance blown.   S02
        exposure above the  proposed  standard.  Arsenic exposures are  poorly
        characterized.
    6)   Also present in  the reverb area at various times is the  refractory
        department.    Hot patching is accomplished at least three
        times during each day.  Reverberatory furnace area monitoring
        indicates  arsenic levels above  the proposed standard.   Personal
        samples are  poorly  characterized, but likely  to  be high.   Five  men
        per shift.
    7)   Matte tap  launders  are uncovered but  short.  Launders transfer  matte
        from reverberatory  furnace into enclosed matte ladle area.  Workers
        complain of  inoperable exhaust  and matte tap  hole punching systems.
        Exposures  above  the proposed arsenic  and S02  standards.
    8)   Slag drops to waiting cars below the  reverb floor and is transferred
        to  the slag  dumping area.   Exposures  above the proposed  arsenic
        standard have been  reported.  Slag launders are  unhooded.
    9)   Reverb waste heat boilers  reportedly  leak and need replacing.   There
        is  a staff of nine,  divided  between the two reverb and  three  pres-
        surized waste heat  boiler  areas.  Arsenic levels of .062 mg/M^  are
        reported.  Hand-lancing (soot-blowing)  several times per day
        involves an  unknown quantity of workers.  Exposures during this
        mechanical operation are uncharacterized.
   10)   Crane repair bay (north end  of reverberatory  crane aisle)  area  ex-
        posures of S02 are  as high as 6 times the proposed standard.
        Arsenic exposures are uncharacterized.   Number of men and length of
        exposure are undetermined  but likely  to be varied.

-------
C)   Converter  Aisle
                                                      I
    1)   Three  Fierce-Smith converters with movable radiation cooled rib
        steel  primary and secondary hoods.  Due to production cutback,  only
        one  or two operate at a time.

    2)   Crane  cabs are enclosed and air conditioned (1573,  1975 respec-
        tively) .   Exposures are poorly characterized.   Cabs reportedly
        ride "roughly."

    3)   Converter punching stations cited for noise by OSHAJ.  "Quietaire"
        and  auto  mufflers on pneumatic cylinder exhausts ha've reduced levels
        considerably.  However, tuyere silencers have  proved ineffective
        over time.  Therefore,  baffling of puncher platform reportedly  was
        to be  installed in January, 1977.  As of July,, 1977, no progress in
        installation.  Cooling  system reported to be ineffective,  even  when
        functioning.   Supply air system never fully developed.

    4)   Silica is discharged into the converters by wa;y of  a Garr  gun
        attached  to  portable silica hoppers above the  jskimming  platform.
        Arsenic exposures above proposed standard.   SQ2 exposures  are poorly
        characterized.  Three workers.

    5)   Converter operator  (skimmer) is unsheltered from exposure.   Expo-
        sures  above  proposed arsenic standard are reportfed.   S02 and noise
        exposures are uncharacterized.  Three workers.  '

    6)   Exposures during soot-blowing of waste heat boilers  uncharacterized.
    7)   Converter repair bay S02 exposures average above proposed  standard.
        Excursions as high as 22.28 ppm.  Other exposures are poorly charac-
        terized.   Number of men unknown.

D)   Oxidizing  Furnace
    1)   Formerly  used for copper blowing.  Due to production cutback, pres-
        ently  used as holding furnace.
    2)   Copper is tranferred from the converters by overhead crane  to an
        unhooded  Great Falls Oxidizing Furnace.   There are  four 2-inch
        tuyeres.   Exposures to  arsenic,  S02,  and noise are  uncharacterized.
        Possible  high S02 and arsenic levels  due to its  proximity  to the
        converter and reverb areas.

E)   Anode Area
    1)   One  anode furnace and one anode  casting wheel.   Area S02 exposures
        are  generally low,  while arsenic exposures  above proposed  standard
        are  reported.    Pedestal fans are reportedly situated throughout  the
        area.   Twelve workers.
    2)   Blowing of unhooded anode furnace is  with reformed  natural  gas.
        Exposures during procedure are uncharacterized.

    3)   Two  to four men per shift work on the anode casting  wheel  removing
        anodes, placing them in water and spraying silica solution  in the
        anode  molds.   Exposures are poorly characterized.

-------
F)  Auxiliary Operations                               |

   1)  Silica  Crushing  and  Handling

           a)   Silica circuit  consists  of junction house,  smelter  crushing
                building,  uncovered conveyer belts,  a ball  mill,  and  por-
                table hoppers.   Exposures  to silica likely.   Number of men
                unknown.

           b)   Crushed  silica  is  transferred by converter  pverhead cranes.
                Crusher  exposures  to arsenic documented  above the proposed
                standard.  Other exposures are poorly characterized.
   2)  Acid Plant

           a)   Acid  Plant designed to handle the off-gases from  one  con-
                verter blow.   Problems have included insufficient mist
                precipitator capacity and  extensive corrosions.   Exposures
                to  the six men  are poorly  characterized.
   3)  DMA Plant                                      !
           a)   1972  plant designed to handle overflow converter  gases,
                redirected to handle lower-sulfur-dioxide-concentration
                reverberatory furnace off-gases.  Longest continuous  run
                ten days.  Exposures are uncharacterized,  S02 exposures
                possible during malfunctions.           |

   4)  Electrostatic Precipitators                   I
                                                      I
           a)   Electrostatic precipitators are cleaned  at  undetermined
                intervals, by hand.  Workers are equipped only with halfmask
                respirators.
           b)   Revert  is  reportedly stored in open piles at various  loca-
                tions throughout the smelter building.  Blowing dust  is
                problem  prior to recharging in converters.   Possible  expo-
                sures unknown.

Comments:

-------
COMPANY SAFETY AND HEALTH ACTIVITIES                  ,
                                                      I
A)  History--Details Unavailable.
                                                      'i
B)  Staff                                             '•
        Safety Director (1)
        Environmental Engineer (1)
        Safety technical personnel  (part-time)             !
                                                           i
C)  Industrial Hygiene
    1)   There is no full-time staff at local level.  Company technicians
        from Tuscon on premises part-time.            i
D)  Respirator Programs
    1)   Respirators are available in most areas of the smelter, but use is
        not mandatory-                                ;
    2)   Workers are responsible for training, maintenance and storage.
    3)   Levels of recorded exposure during 2/24-26/76 OSHA inspection pre-
        cluded establishment of comprehensive program.
    4)   1977 union contract demands included establishment of a respirator
        program.                                      I
E)  Safety                                            '
    1)   There is no extensive pre-employment safety instruction.
    2)   Monthly departmental safety meetings are held infrequently if at
        all.
    3)   1974, 1975 OSHA 102 Data on hand.
F)  Health Care
    1)   New Cornelia hospital built and staffed by the Phelps Dodge Corpora-
        tion.
    2)   Staff includes six doctors, twelve registered nurses, on full-time
        staff.   Undetermined number of part-time technical personnel.
    3)   Adequate 24-hour emergency facilities,as well as pre-arranged
        referral capabilities to Phoenix and Tuscon medical centers.
    4)   Pre-employment physical includes x-ray, audiometric,  and pulmonary
        function tests.
    5)   Conflicting information as to existence and/or extent of company-
        sponsored annual medical testing offered.
Comments:

-------
SAFETY COMMITTEE
A)  Description                                       '
    1)  Established following the 1974 contract negotiations.
    2)  Management and labor (I/union) represented
    3)  Committee acts on suggestions received from departmental meetings.
        The committee has no investigatory or inspection powers.
Comments:
REGULATORY HISTORY
A)   Pre-1970
    1)   Office  of State Mine Inspector
B)   Post-1970
    1)   State OSHA Plan
           a)   Developmental.   Headed by Arizona Industrial Commission.
                Approved October,  1974.
           b)   Jurisdiction over  smelters still in hands of State Mine
                Inspector.
    2)   Office  of State Mine Inspector
           a)   No contractual  relationship exists with Arizona Industrial
                Commission.
           b)   Two to  three inspections  per year, 1972 - 1976.
           c)   Limited industrial hygiene efforts.

-------
   3)  OSHA Activities                               I
       1)  Initial  inspection:   fatality  investigation
                                                     ii
       2)  2nd  inspection:   general  schedule  safety ,
       3)  3rd  inspection:   general  schedule  health. ' Citation  for  noise
           while punching  converters.
       4)  4th  inspection:   complaint,reverberatory arch building.   In
           compliance.                                    j
Comments:

-------
 PROCESS EQUIPMENT*--Ajo
                                                   Table I
 NAME
AGE
POLLUTION CONTROLS
COMMENTS
Reverb (1)
Converter (Pierce Smith]
Converter "
Converter "
Oxidizing Furnace (Great Falls)
Anode Furnace
Casting Wheel
Acid Plant (Single Contact)
DMA Plant
Waste Heat Boilers (5)
1950
1950
1950
1971

1950
1950
1972
1972

ESP
DMA plant or stack
Primary and secondary hoods,
ESP,
acid plant
None
None
None


3--Converter (pressurized)
2--Reverb
high speed slinger feed

Used primarily as holding furnace


600 TPD
50 TPD--handles reverb off-gases
Longest continuous run- -10 days

*Figures 2,3,4,5; Design and Operating Parameters for Emission Control Studies:
                  Phelps Dodge, Ajo, Copper Smelter

-------
ictions--Ajo
                                  Table 2
       TYPE
FINDINGS
                                        PENALTIES   FOLLOW-UP
                                                 COMMENTS
'72
,/75
76
'6
fatality
general
schedule
safety
general
schedule
health
complaint
hazard not covered
by standard None
17 non-serious
violations $185
1 non-serious
violation None
in compliance 	
None
company
letters
company
letters £ memos
through 1/3/77



converter
#2,3--noise
reverb arch
rebuilding
:Ctions--Ajo
 of Arizona, State Mine  Inspector

72
72
72
73
m
4
/74
75
/75
76
76
5
TYPE
fatality .
dust j
safety
dust
safety
spot
safety
!
1
safety
dust
safety
safety
safety
FINDINGS PENALTIES FOLLOW-UP
i
4 recommendations 	 10/5/72
5 S02 samples
13 dust counts
COMMENTS
#3 converter
rollback
•spill
grab area
samples
6 violations
'9-dust counts
1 11 violations
i 3 recommendations
' 1 violation
2 recommendations
6 violations
11 violations
abated
11 violations 10/20/75
6 S02 samples
,,' 13 dust counts
!| 10 violations
i 10 violations abated 5/18/76
i
8 violations
3 violations
grab area
samples
smelter
acid plant
acid plant


grab area
samples
smelter
acid plant
rebuilding
reverb arch

-------
 SUMMARY  OF  HEALTH HAZARDS--Ajo
                                                   Table 3
Number of
PLANT AREA Employees
Material Handling
Reverberator/ Furnace
Converter
Anode
Other
43
25
13
12
66
TWA Exposures*
Copper
mg/M3





Arsenic
mg/M3

000-.317
000-.026
000-.012

Lead
mg/M3





Sulfur
Dioxide
(PPM) NOTES

0-48
0-22




Noise levels 1.59 times the
standard for
converter puncher.


independent of respirator usage

SOURCES:  Arsenic OSHA hearings, 1975.  Company data.
          OSHA inspections
          Arizona State Mine Inspector inspections

-------
FACT SHEET

Facility:   Douglas Reduction Works

Company:   Phelps Dodge Corporation
                                               INFORM
                                               25 Broad Street
                                               New York, N.Y.
                                               10004

                                               (212) 425-3550

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GENERAL

Name:   Douglas Reduction Works, Phelps Dodge Corporation

Location:   Douglas,  Arizona

Description:

    1)   Combination  of custom smelter and supportive facilities.

    2)   Smelter built in 1903.

    3)   Employees:   565

    4)   Ore is received as toll from nearby open pit mines.  Arsenic content
        of concentrate reported by the company to be between .1 and .3 per-
        cent.

    5)   The Douglas  smelter employs 42% of Cochise County's manufacturing
        workforce,  and is responsible for 50% of the County's manufacturing
        payroll, with an annual payroll of $8,000,000.

    6)   Production:

        Prior to the closing of the Bisbee Mine in 1974-1975, the Douglas
        smelter received the majority of its concentrate from there, with a
        small  percentage from the developing Tyrone mines.   Currently,  the
        smelter processes Tyrone and toll concentrates and scrap purchased
        by  the company,  and revert  dust  from the  company's  Morenci  smelter.

Comments:
PROCESS AND HAZARDS--SMELTER

NOTE:   Respirators  are available in most areas of the plant; however,  use is
not mandatory.   Workers are responsible for training, maintenance,  clean-up
and storage of  respirators.

NOTE:   The  following comments evaluate TWA exposures independent of respira-
tor use.

NOTE:   Throughout  the following remarks, the phrase "poorly characterized"
is used to  indicate that we have found no evidence that either the  company
or the  regulatory  agencies  have sufficiently characterized the exposures to
permit  proper evaluation and corrective action.

-------
A)   Material  Handling

    1)   Concentrates are received at the preparation plant in open railroad
        cars  which are dumped into bins.  Dust generated by air lance use is
        reported.   Documented respirable nuisance and 'silica dust violations
        as  well as noise violations at concentrate unloading dock and bins.
        Five  workers.

    2)   Concentrates are crushed,  screened,  and mixed,  prior to open con-
        veyor transportation to 100-ton feed bins above the! multi-hearth
        roasters.   Documented silica violations to feeder c!ar man,  screen
        operator and bedding plant operator, with near, violations  to several
        other workers.   Documented noise violation to feeder car man,  slag
        screen operator and rolls  operator,  with potential exposures to sev-
        eral  other workers.   Use of hearing  protection' is intermittent
        throughout preparation plant.   Forty workers. !

    3)   Potential  exposure  to arsenic dust is uncharac^terized throughout the
        preparation plant.                            '•

B)   Multi-Hearth Roasters                                (

    1)   There are  24 Herreschoff multi-hearth roasters,  with 16 to  20  nor-
        mally in operation.   Off-gases  from  the two  parallel rows of 12
        roasters pass into  an electrostatic  precipitator,  are  combined with
        reverb off-gases, and sent out  through the stack.   Concentrates  are
        fed by vaned drum feeders into roasters.  Company  reports  average  area
        sulfur dioxide  levels to be two times the existing standard.

    2)   Operating  Decks

             a)  Tripper floor sulfur dioxide exposures  vary from below  pro-
                posed  standard to four times existing  standard.  Arsenic
                exposures  are poorly characterized.

             b)  Company reports charge floor average sulfur dioxide  level
                at proposed standard.   Excursions during malfunctions docu-
                mented  to  220 ppm.   Company also reports  feeder station TWA
                arsenic levels  slightly above proposed  standard, with oper-
                ator exposure averaging well above  proposed standard.
                Twelve  workers.

    3)   Unloading  Areas

             a)  Calcines are discharged into larry  cars  below  roasters.
                Larry car  trains  of two cars each make  approximately  fif-
                teen trips  to reverb per shift.

            b)  Larry cars  are  filled  from  hoppers  through  pneumatically
                activated  gates by  remote control.   Discharge  points  are
                draft hooded.   Operator station  is  approximately 30 feet
                from hoppers; however,  company reports  sulfur  dioxide ex-
                posures as high as  11.30  ppm,  due  to  gap  between larry car

-------
                and  hoppers,  and unhooded areas  betweeiji hoppers.   Company
                states  gap  is "necessary for clearance;and is  a source  of
                gas  spillage."  Operator arsenic exposures are poorly  char-
                acterized.                             ''•'

            c)   Larry  cars  during transit are presently uncovered.   Expo-
                sures  to  motor man reported by company to be  as high as
                19.53  ppm.   Company reports that it has bee|n  unable  to
                "put together a workable system" of closed jcontainers  or
                cars.   Arsenic exposures are poorly characterized; however,
                limited company data indicates a level of four times pro-
                posed  standard for 2-hour period.
                                                      i
    4)   Company  reports that structure  and design  of bjuilding  allow  for
        "S02  and dust  from  this source  (calcine  cars)  drift upward and per-
        meate other  working areas in the roaster building."
                                                      I
    5)   Other areas  of potential exposure to hazards include  the  center
        aisle,where  the company reports sulfur dioxide levels  averaging ap-
        proximately  six times the existing standard, andl the  roaster flue
        test  station,  where limited company data indicates arsenic levels
        slightly above  the  proposed standard.   Actual  exposure and exact
        number of workers affected are  unknown.          :

C)   Reverberatory Furnace

    1)   Three reverberatory furnaces: two silica sprung arch,  one  suspended
        basic roof.  Company reports area average  sulfur dioxide  level to be
        slightly above  proposed standard.

    2)   After traveling approximately 200 yards,  the larry cars are  emptied
        through  "close  fitting linkages" on underside  of car.   There is no
        attempt  to capture  dust and gases at this  area.   Company  reports
        calcine  motor  man exposed to levels of sulfur  dioxide  averaging two
        and one-half times  the existing standard in reverberatory  furnace
        area.  Potential  arsenic exposures in  this  area  are uncharacterized.

    3)   Charge floor:  Sprung arch furnaces #9  and  #10  are fed  through grav-
        ity  (Wagstaff  feeders),  while #8 is fed  by  drag  chain  conveyor.
        Company  reports  leakage at both types  and  average sulfur  dioxide ex-
        posure to area  workmen slightly above  proposed standard, with excur-
        sions higher than existing standard.

           a)   Reverb  #8--  Company reports charge  floor area  arsenic levels
                average three  times proposed standard.   Company reports
                charge  helper  personal  exposure  to  be  nine times proposed
                standard  for  2-hour period.   Actual TWA  exposures  are un-
                characterized.   Documented sulfur  dioxide levels of  six
                times existing standard during charging.

           b)   Reverbs #9  and #10--  Company  reports  spoutman personal ex-
                posures to  arsenic ranging from  the proposed action  level to
                thirteen  times  the proposed standard.   Documented  sulfur di

-------
                                                      I
                oxide  levels  as  high as  four times  theiexisting standard
                during car  unloading.                  I

   4)   Matte  tap  areas:  Company  reports  vented launder covers have become
        "distorted and ill-fitting," and ladle hoods  are damaged,  rendering
        them "ineffectual."  Company sulfur dioxide data indicates an  aver-
        age area level below  proposed standard, while working station  con-
        centration near vented launders  is above proposed sjtandard and two
        times  existing standard  at unvented launders.       I

           a)   Reverb #10--  Company reports average  arsenic  level at  the
                west side of  matte launder to be greater than two  times the
                proposed standard.                     j
                                                      j
           b)   Reverb #9-- Company reports personal  arsenic  exposures  to
                tapper to range  between  two and twenty times  the proposed
                standard.                              i

   5)   Slag skimming  areas:   Slag holes are locally  exhausted and vented.
        Company  reports  that  sulfur dioxide exposure  rarely exceed existing
        standard.   Arsenic  exposures are uncharacteri zed1.

   6)   Reverberatory  furnace man:   Company reports that;arsenic exposures
        range  from three to thirty times the proposed  (standard for short
        periods  of time.  Actual time-weighted-average exposures are poorly
        characterized.  Sulfur dioxide levels are uncharacterized.

D)  Converter  Aisle

   1)   Five Fierce-Smith converters with  three running  during normal  opera-
        tion.  The  converters are  primary-hooded.   Secondary  hoods  are  con-
        sidered  "infeasible"  by  company.   Company reports  average  area  S02
        level  to be below the proposed standard; however,  company  also  re-
        ports  "SC>2  in  work  areas adjacent  to the  Douglas  converter has been
        measured at 4.26 ppm."   Arsenic  exposure in entire  converter area is
        poorly characterized.

   2)   Matte  is transported  across the  converter aisle  by  overhead cranes.
        Cranes are  enclosed and  ventilated.   Sulfur dioxide levels  inside
        cabs are reported near or  above  the proposed  standard.  Arsenic ex-
        posures, if any, are  uncharacterized.

   3)   Skimmer:   Controls  blowing  schedule  as  well as silica  flux  input.
        Sulfur dioxide levels  reported at  present standard.   Arsenic levels
        are poorly characterized.

   4)   Potential converter punching hazards--arsenic, sulfur  dioxide,  and
       noise--are poorly characterized.

   5)  Company reports extensive sulfur dioxide problem in upper  galleys  of
       converter area.  Sulfur dioxide  levels  range from 60  to 170 ppm.
       Company is considering-enclosing the  most heavily exposed walkways
       (galleys).   Arsenic exposures are poorly characterized.

-------
E)   Anode  Area

    1)   Two furnaces and one casting wheel

    2)   Company data indicates sulfur dioxide levels below proposed stan-
        dard.   Arsenic exposures, if any, are uncharacterized.

F)   Auxiliary  Operations

    1)   Company reports potential  arsenic problem in roaster gas cleaning
        bag house.     Company data places arsenic exposure to  inspector
        at greater than three times the proposed standard during inspection.
        Potential additional problem for repair and clean-up workers.   Other
        exposures,  if any,  are uncharacterized.

    2)   Waste  heat boilers:   Company data indicates average sulfur dioxide
        level  to be above proposed standard.  Company also reports arsenic
        levels at #10 waste  heat boiler to average above the proposed  stan-
        dard and personal exposure to #10 boiler fireman to average twice
        the proposed standard.

    3)   Electrostatic precipitators:  Company reports arsenic  levels above
        the proposed standard at converter precipitate dust bin.  Other ex-
        posures, if any, are uncharacterized.

    4)   Documented exposure  to dust in sample mill and bucking room.  Actual
        current exposures are uncharacterized.

Comments:

-------
COMPANY  SAFETY AND HEALTH ACTIVITIES

A)   History — Details unavailable.

B)   Staff

    1)   Labor Department Head / Safety Director (1)

    2)   The  Labor Department Head is assisted by the department heads, the
        master mechanic and one safety inspector.          I

C)   Industrial Hygiene

        There is no full-time staff at the local leveli.  Company technicians
        from Tuscon on premises part time.            i

D)   Respirator Program
                                                      I
    1)   The  company provides respirators in most areas of the plant, but use
        is not mandatory-
                                                        I
    2)   Workers are responsible for training, maintenance, clean-up and
        storage of respirators.

E)   Safety                                            I

    1)   Pre-employment safety orientation was developed in 1972.

    2)   New  or transferred employees receive seven days of supervision at
        new  job.

    3)   The  company provides protective equipment in most areas of the plant.

F)   Health Care

    1)   All  employees are required to learn basic first aid.    The Company
        annually reviews each employee's competence in the skill.

    2)   There are first aid stations located throughout the plant.

    3)   The  extent of annual medical examinations is unknown  at this time.

    4)   All  extensive care is administered through the Cochise County Hospi-
        tal  in Douglas.

Comments:

-------
SAFETY  COMMITTEE

A)   Description

    1)   Established in 1971.
    2)   The  quarterly meetings of the Committee are attended by three com-
        pany representatives and one representative from each union in the
        ^Tnp I T f*.T .                                            i
    3)   The  Committee is advisory in nature and has no inspection or inves-
        tigatory powers.                               :
Comments:
REGULATORY HISTORY

A)   Pre-1970

        Office  of State Mine Inspector

B)   Post-1970

    1)   State OSHA Plan

           a)   Developmental.   Headed by Arizona Industrial Commission.
                Approved October,  1974.

           b)   Jurisdiction over smelters still in hands of State Mine In-
                spector.

    2)   Office  of State Mine Inspector

           a)   No contractual  relationship exists with Arizona Industrial
                Commission.

           b)   Two to  three inspections per year, 1972-1976.

           cj   Limited industrial  hygiene efforts.

    3)   OSHA Activities

           a)   There has  only  been one OSHA inspection.   A fatal  accident
                on December  27,  1973,  brought two non-serious  violations.

-------
   4)  MESA Activities

           a)   MESA has  jurisdiction over the Douglas: Preparation Plant

           b)   There  have  been ten inspections of the! Preparation Plant
                since  October of 1974.

           c)   Citations have included safety violations,  housekeeping,
                silica dust violations and noise violations'.
Comments:

-------
PROCESS EQUIPMENT--Douglas
                                                   Table 1
NAME
AGE
POLLUTION CONTROLS
COMMENTS
Roasters (24)
multi-hearth
Reverberator/ Furnaces
#8--suspended arch
#9 and #10--silica
spray arch
Converters (5)
Anode Furnace (2)
1903
1903
1903


flue -»- 4 parallel
ESPs ->- stack
flue ->• 3 parallel
ESPs •+ stack
Balloon flue -*• 4
parallel
ESPs ->- stack


Side-charge-fed furnace.
There is no S02 control at Doug-
las. Acid plant was destroyed in
1945.

SOURCES:  Design and Operating Parameters for Emission Control Studies:
          Phelps Dodge, Douglas , Copper Smelter
          OSHA inspections

-------
                                    Table 2
:tions--Douglas
of Arizona,  State Mine Inspector

'2

'2

'3

'73

74

74

5
S

6
6
TYPE
dust

safety

dust

safety

safety

complaint
--dust

follow-up
safety
safety
safety
complaint
FINDINGS
6 S02 samples
18 dust counts

23 violations

60 SC>2 samples
14 dust counts

31 violations

18 violations

20 dust counts

15 violations
abated
26 violations
25 abatements
1 extension
7 violations
1 violation
PENALTIES FOLLOWfUP
	 i.
i
!
i
	 company
letter:
2/19/75
1
)
1
1 	 company !
letters : :
1/24/7J4.
5/21/74
	 company
letter:
11/26/74
company
letter
11/26/74;
3/28/75
inspection
	 	
_.__ 2/5/76
inspection
	 	
	 8/31/76
	 4/13/76
COMMENTS
3 dust samples
above allowable
limit .
4 S02 samples
20 ppm or above.


1 dust count
above allowable
limit .
S02 as high as
220 ppm.




"potential dust
problem" at
concentrate
loading bin.




preparation
plant
dust, heat 5 gas

-------
3 2—continued)

76
76
76
76
76
'6
'76
TYPE FINDINGS PENALTIES FOLLOW-UP
accident 4 violations 	 4/13/76
safety 9 violations 	 8/31/76
follow-up
accident 	 	 	 |
i
dust 5 S02 samples 	 	
12 dust counts j
general 4 safety 	 	 ,
inspection violations;
15 dust counts '
!
i
complaint/ 4 violations --.-- 	 ;
accident: :
safety ,
;tions--Douglas
TYPE FINDINGS PENALTIES FOLLOW-UP
'73
accident/ 2 violations $75 none
fatality
COMMENTS
reverb #9: roof

slag train
1 S02 sample at
25 ppm.
Preparation
department--
no dust counts
above allowable
limit.
reverb repair
COMMENTS
dock area

-------
                                                                                                            Table  3
SUMMARY OF HEALTH HAZARDS--Douglas
Number of
PLANT AREA Employees
Preparation
Department
Roasters


Reverberator/ Furnace





Converter

Anode
Other
40













TWA Exposures*
Copper
mg/M3














Arsenic
mg/M^

.004
average

charge floor
average
.0135t
tapping aver-
age .out




see note



Lead
mg/M^














Sulfur
Dioxide
(PPM) NOTES



10.59 ppm
average


area general
average
2.38 tt
calcine
motorman :
10.59tt

~"" ~47 ppm
0-.46 ppm


TWA as high as .007 reported.

Company data—Excursions re-
ported to 100 ppm. SMI indi-
cates excursions to 200 ppm.
tCompany data indicates levels
of .054, .121 for 2-hour time
periods .

ttCompany data. SMI indicates
reverb floor levels of 24 ppm.



Company data for dust handling
only. Data indicates TWA at
—..006, with excursions,. to_ JD69 .
Company data. SMI indicates
skimmer-platform levels at
5 ppm. Company indicates gal-
ley levels to be as high as
170 ppm.



-------
FACT SHEET

Facility:  Morenci  Smelter

Company:   Phelps Dodge Corporation
                                                       INFORM
                                                       25 Broad Street
                                                       New York,  New York
                                                       10004
                                                       (212) 425-3550

-------
GENERAL

Name:   Phelps  Dodge Corporation, Morenci Branch
Location:   Morenci, Arizona
Description:

    1)   Combination of crushing plant, concentrator, smelter, and supportive
        facilities in operation since 1942.

    2)   Smelter division had 374 employees in 1977.  Entirejoperation (includ-
        ing mines) had 2800 employees.

    3)   Ore from Morenci open pit mine (70%) and the Metcalf open pit mine
        (30%).   Arsenic content in the concentrate reported between .001% and
        .02%.                                           j

    4)   Largest employer in the county, with a payroll of approximately $50
        million.                                        !
    5)   Production                                     I
        a)   Approximately 45% of Phelps Dodge's total copper
        b)   	1972     1973     1974     *1975     1976
            -j_	_	
            Copper
            (short tons)    119,700  119,500  101,400  118,100  157,200
            Sulfuric Acid (tons)	         |         327,026

Comments:
PROCESS AND HAZARDS

NOTE:   In many areas of the plant, workmen wear company supplied respirators
on a need basis.   The following comments evaluate TWA exposures independent
of respirator usage.

NOTE:   A number of the areas discussed below have been cited by OSHA.   The
details are all available to INFORM but not generally included in the interest
of brevity.

NOTE:   A.significant amount of information concerning the issue of engineering
controls is available in the record of the OSHA arsenic and sulfur dioxide
hearings.   Such information is not, on the whole, included below.

-------
                                                                          2.
NOTE:   Throughout the following remarks, the phrase "poorly characterized"
is used to indicate that we have found no evidence that either the company
or the regulatory agencies have sufficiently characterized the exposures to
permit proper evaluation and corrective action.        ;

A)  Fluid bed roaster

    1)  Feeds 2 reverbs.  About 35% of total feed.

    2)  Feed is very fine.  Calcine is moved by screw conveyor.

    3)  Union has filed grievances for "dusty and gassy conditions."

    4)  Area samples in the control room indicate exposures 2 times the
        proposed arsenic standard.                     ;

    5)  Sulfur dioxide exposures in control room reported with a TWA of
        10 ppm.  Reportedly exposures occur as a result of emissions from
        nearby acid plant.

    6)  Personal exposures are poorly characterized.
                                                      I
B)  Reverbs

    1)  Two furnaces with sprung silica arch.  Three witty suspended arches.
        Usually four in operation at once.              f

    2)  Four of the furnaces have "doghouse" ventilation on tap holes and
        covered launders.  Newest furnace (#5) has the matte tap hole in an
        enclosed room with an automatic punching machine.   Ladle car is with-
        drawn from room after filling.
    3)-  Arsenic exposures range from undetectable to 40 times the proposed
        standard.  Personal exposures are poorly characterized.

    4)  Sulfur dioxide exposures range from 3 to 78 ppm.  TWA personal expo-
        sures are poorly characterized.
    5)  Furnacemen and chargers were exposed to excessive noise.  Enclosure
        and maintenance lubrication of drag chain conveyors corrected the
        problem after it was cited by OSHA in 1974.
    6)  Copper exposures among feeders range from 1 to 9 times the dust stan-
        dard.  Use of vibrators, air lances and blow pipes to dislodge jammed
        concentrate from bins is source of dust in area above reverbs.

    7)  Waste heat boilers and uptakes reportedly leaky.

    8)  Flue cleaners lance waste heat boilers during day shift.  Exposures
        uncharacterized.  Reported "gassy and hot" by union.

    9)  Several burn and flashback incidents around the furnaces in 1974
        exemplify a serious safety concern in the area.
   10)  Two acute exposures to sulfur dioxide have occurred in conveyor areas
        above the reverbs.  Both cases have required hospitalization and the
        union has filed grievances.
   11)  Tops of furnaces are "blown" with compressed air causing general area
        contamination.   No vacuuming has been tried,  even on the 2 suspended
        arch furnaces.

-------
                                                                            3.
C)   Converter Aisle

    1)   Nine Fierce-Smith converters.   About 7 operating at once.   All are
        equipped with primary and secondary hoods.     ;'

    2)   4 cranes are sealed and air-conditioned, but maintenance and/or
        design are poor and leaks cause exposure to sulfur dioxide above the
        present standard.  Arsenic exposures are poorly characterized but
        likely high.  17 men.

    3)   Arsenic exposure range from 0.0 to 0.209 in the arei.   Personal expo-
        sures are poorly characterized.                    i

    4)   Sulfur dioxide exposures in the lower levels of the aisle (skimmer
        platforms, aisle floor) are reported in excess of the proposed stan-
        dard but are generally poorly characterized.   i

    5)   Punchers' noise exposure has been eliminated by enclosing the punchers'
        cabs after an OSHA citation.  No safety concerns have been voiced by
        employees regarding the enclosures.

    6)   Conveyor galleries above the aisle result in excessive exposures to
        sulfur dioxide and metal fumes for workmen who must enter the area.
        Exposures are poorly characterized.             I

D)   Refinery and Casting

    1)   Four anode furnaces and two casting wheels.  Mouths of furnaces are
        not exhausted.                                I

    2)   Some reports indicate occasional exposures to sulfur dioxide in excess
        of the proposed standard due to proximity to converters.
    3)   Some excessive exposures to noise (1-3 times the standard) occur near
        the refining furnaces.  Personal exposures are poorly characterized.

E)   Other
    1)   Exposures to air contaminants in the acid plants,  if any,  are poorly
        characterized.
    2)   Exposures arising from handling of dust from flues, precipitators, pug
        mills, etc., are poorly characterized.
    3)   A significant number of repairmen work in the different areas of the
        plant.  Potentially high exposures may exist in areas such as the crane
        bay repair section.  Repairmen are affiliated with the Machinists Union.
        Exposures are poorly characterized.
    4)   Men in refractory department are likely exposed to levels existing in
        reverb areas.  13 men.  Poorly characterized.
    5)   Crushing plant.  Silica dust exposures three times the limit, documented
        by MESA samples.  Wetting system inoperative or nearly so.  No local
        exhaust ventilation.   4 men.
    6)   Lime plant.   Excessive silica exposures in crushing were documented by
        MESA in early 1976.  Union reports that local exhaust was  installed,
        with notable improvement.   Lime slaking has no local exhaust ventila-
        tion, resulting in exposures to irritating calcium hydroxide mist.

-------
    7)   Bedding areas.  Documented high copper exposures for laborers
        suggest arsenic exposures as well most likely Resulting from their
        duties in conveyor lines above the reverb.  Poqrly characterized.
        Transfer of silica flux in and around bins is Reported dusty-
        Potential silica exposures are poorly characterized.  (Four dust
        collectors were being installed in this area as of mid-1976.J
Comments:
COMPANY SAFETY AND HEALTH ACTIVITIES

A)  History—Details Unavailable.

B)  Staff

        Safety Director (1)

        Safety Engineer (1)

        Smelter Safety Superintendent or Inspector (1)

        Dust  Engineer (1)

        Other
C)   Industrial  Hygiene
    1)   Testimony  during arsenic and  sulfur dioxide hearings  strongly  suggests
        that  little  evaluation of air contaminants  took  place  before 1974-1975.
        Since that time,  the company  has  conducted  some  area  sampling, but
        little  or  no personal sampling.
    2)   Dust  Engineer,  who  performs air  sampling, does not  work under  the super-
        vision  of  a  corporate industrial  hygiene  or similarly  competent person.

    3)   Company statements  strongly suggest that  there is little  industrial
        hygiene or occupational  health expertise  at the  corporate  level.

-------
                                                                           5.

D)   Respirator Program
    1)   Cited by OSHA in mid-1976.  No corrections yet (implemented.
E)   Safety                                             ''
                                                       ii
    1)   Company conducts accident investigations utilizing a written format
        and report form.
    2)   Monthly safety inspections.  Labor does not participate.
                                                           i
    3)   Monthly safety meetings and discussion for each work crew.
                                                           i
    4)   Company computes injury frequency and severity rates routinely,
        using ANSI method.                             [
    5)   Frequency rates in 1974,  1975, and 1976 for total cases, lost workday
        cases and lost workdays are above the industry!average for SIC 3333.
                                                       I
F)   Health Care                                        ,
    1)   100-bed hospital in Morenci with 6 doctors andl other staff.  24-hour
        emergency room.                                :
    2)   Pre-placement exam.                              t
    3)   No periodic health exams  or medical monitoring, with the following
        exceptions:                                      1
        a)  Yearly audiometric exams.
        b)  Yearly medical exams  for cranemen.         !
    4)   First aid equipment and trained personnel at the plant.  Ambulance
        service is available.
    5)   Referral system pre-arranged with medical institutions in Tucson
        and Phoenix.
    6)   No company rehabilitation program.  Workers rely on state efforts.
Comments:

-------
SAFETY COMMITTEE
                                                       i
A)   Description                                        '
                                                       i|
    1)  Begun in 1971 contract.                        ,,
    2)  Two company, two union representatives.
    3)  Few specific functions except to review suggestions.   No regularly
        scheduled joint inspection tours.   No written record provided to
        union participants.   No monthly meetings.           i
    4)  Union judges it to be of little effectiveness.      !
Comments:
REGULATORY HISTORY
A)  Pre-1970
    1)   Office of State Mine Inspector
B)  Post-1970
    1)   State OSHA Plan
        a)   Approved 10/74.
        b)   Developmental.
        c)   Headed by Arizona Industrial Commission.
    2)   State Mine Inspector
        a)   Still retains  jurisdiction over smelters.
        b)   No contractual  relationship exists  with  the  Industrial Commission.
        c)   Approximately  2-3 inspections per year between  1972  and  1976.
        d)   Limited industrial hygiene efforts.   Essentially  spot sampling.
    3)   OSHA Activities
        a)   Four  inspections,  all  as  a result of complaints.  Two were safety
            only,  one health only,  and one combined.   Last  inspection was
            completely contested.
    4)   MESA Activities
        MESA has  traditionally inspected the lime plant, the  silica  plant
        and  even  sections of the bedding area.   The  jurisdiction which is
        exercised over the acid plants (i.e., MESA or  OSHA) is unclear to
        INFORM.

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 PROCESS  EQUIPMENT*--Morenci
                                                   Table I
NAME
                                  AGE
POLLUTION CONTROLS
COMMENTS
 Bedding Plant
    Crushing Plant
    Lime Kiln
                                            wet  scrubber
                                            baghouse	
Roaster
    Fluid Bed
                                            series  of  cyclones •>
                                            .scrubber ->     acid  plant
                                             A.P.  produces 100% ti2SOk
                                             150 TPD used
                                             in plant, remainder sold
                                             operates 21 hrs.  a day
Reverbs
    #1---,
    £2__jsprung silica arch

    #3--,
    #.  /suspended arch
    #5--l new reverb; suspended
        roof with tripper belt
        sidewall feed
                                            gases  pass  through waste heat boiler ->
                                  1942-43   ESP  ->•  some  dilution ->• 605'  stack
                                            (reverb)
                                            *A new ESP  installed  to control #5
                                            particulates
Converters
    9 Pierce Smith  (7 usually
    active) (x~3.37 blowing
    when 7 converters active)
                                            close  fitting hoods  on  all  converters  •>
                                            gas  coolers  ->• 4  ESP  -> gas cleaning
                                            (i.e.  scrubber)  -> single  contact acid
                                            plant  ->- tail gases out  60S'  stack (con-
                                            verter)  secondary hoods on  all  now operating
                                             1500 TPD H2SOk produced
Anode Furnace
    4
                                            None
                                             Reducing gas through
                                             tuyeres (at one time
                                             practiced poling)
Casting Wheels (2)
                                            None
                                           750 tons per day
                                           2500 tons per day
Acid Plants  (2)  (single  contact)
tFigures 2,3; Design and Operating Parameters  for Emission Control  Studies:
              Phelps Dodge, Morenci, Copper Smelter

-------
ections--Morenci
                                   Table 2
       TYPE
FINDINGS
                                         PENALTIES  FOLLOW-UP
                                                COMMENTS
/73
74
n
(7/76
complaint
safety
complaint
health
complaint
safety
complaint
safety $
health
1 non-serious
10 non-serious
41 non-serious
29 items
8 lumped as
serious
1
$40 None I
$120 None ,
!
i
$995 None !
1
$700 None
f
crane issues
7 noise
2 S02
1 respirator
program

in contest
 ;ctions--Morenci
 ; of Arizona, State Mine  Inspector
       TYPE
FINDINGS
PENALTIES  FOLLOW-UP
COMMENTS
 •14/72
       health
noise £ SOa some
high spot samples
   None
 2     health
4 of 18 grab dust
samples exceeded
standards
           compliance
   None    letter from co.
772
3
73
74
/74
74
safety
health
safety
safety
safety
safety
22 violations
1 of 9 grab dust
samples exceeded
standards
16 violations
9 violations
25 violations
32 violations
None
None
None
None
None
None
None
None
compliance
letter from co.
compliance
letter from co.
compliance
letter from co.
compliance jointly with
letter from co. MESA

-------
                               Table  2  (cont.)
ections--Morenci
e of Arizona, State Mine  Inspector
	TYPE	FINDINGS	PENALTIES  FOLLOW-UP |	COMMENTS	
                                                              I
                                                    compliance
/75	safety	15 violations	None    letter from co.	
                                                         f
                                                    compliance
^75	safety	28 violations	None    letter from co.	

                                                                     recommended
       health       high SOa  exposure                   '            respirators and
•15/76  complaints   in crane	None    None	     I.H. testing

!,13,   safety and   "No  dust                               •
'76	health	problems"	None    None   '	

-------
                                                      Table 3




SUMMARY OF HEALTH HAZARDS--Phelps Dodge, Morenci, Arizona
Number of
PLANT AREA Employees
Preparation Dept.
Fluid Bed Roaster
and Acid Plant
+ Converter Acid Plant
Reverberator/ Dept.
Converter Aisle
Refining and Casting
23
27
83
87
34
TWA Exposures*
^ Copper
mg/M3
1.03-9.07
(among la-
borers ;
other expo-
sures
unknown)

22
(Feeders
only, not
entire dept)


Arsenic
mg/M3
.001-. 030
(around
Junction
House and
some
conveyors)
.002-. 007
<.001-.169
0 - .209

Sulfur
Dioxide (ppm) NOTES

0.85-10.86
0 - 131
0-23

Some hazardous exposure to
siliceous dust in lime and
silica plants .
Area samples.
Highest exposures to arsenic and
sulfur dioxide occur in Feed floor.
Worst sulfur dioxide exposures are
in upper reaches of converter aisle
No hard data-available to INFORM.
Some excessive noise exposures
reported near the refining furnaces
                                         •'Independent of  respirator  usage.
SOURCES:  OSHA Inspections

-------
                                                  Table 3 (cont.)

SUMMARY OF HEALTH HAZARDS--Phelps Dodge, Morenci, Arizona


                                            TWA Exposures
Number of
PLANT AREA Employees
Refractory Dept.
Other
13
141
rCopper
mg/M


Arsenic
mg/M


Sulfur
Dioxide (ppm) NOTES


No details available to INFORM.
Exposures likely similar to those
in reverb areas .
Some of the job categories strongly
suggest hazardous exposures (eg. >
flue cleaners, sweepermen, clean-up
laborers, etc.). No details
available to INFORM.
                                        independent of respirator usage.
SOURCES:   OSHA Inspections
          State Mine Inspector Inspections
          Company testimony in arsenic and sulfur dioxide hearings.

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FACT SHEET

FACILITY: Hidalgo Smelter

COMPANY: Phelps Dodge Corporation
                                                   INFORM
                                                   25 Broad Street
                                                   New York, New York
                                                   10004

                                                   (212) 425-3550

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GENERAL                                             ,
                                                      i
    Name:   Hidalgo  Smelter,  Phelps Dodge Corporation;

    Location:  Playas,  New Mexico                      ['

    Description:

        1.   Copper smelter and supportive  facilities.  Production equipment
            includes flash furnace, electric furnace, three converters, two
            anode furnaces, casting wheel,  elemental sulfur plant  and two
            acid plants.

        2.   460 employees.
                                                      i
        3.   Concentrates are received from the Tyrone mine and concentrator.
            Arsenic  content of concentrate is .002%.  Other impurity  data on
            hand.  In  the future the smelter will also handle concentrates
            from the company's Arizona Bagdad mine.

        4.   Annual payroll at the smelter is  $6 million.

        5.   Production:                                 !

                                      1977         1976   f
Comments:
Copper (tons)
82,500
37,900

PROCESS AND  HAZARDS

NOTE:  Respirators and replacement parts are issued to all smelter employees.
Employees are responsible for care, maintenance, and storage.  Following a
1976 OSHA citation, the company installed respirator storage and cleaning
stations.

NOTE:  Throughout the following remarks, the phrase "poorly characterized"
is used  to indicate that  we have found no evidence to indicate that either the
company or the regulatory agencies have sufficiently characterized the expo-
sures to permit proper evaluation and corrective action.

NOTE:  The Outokumpa type flash furnace at  Hidalgo is  the first application  of
this technology in the United States.

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A.  Material Handling

    Concentrates are received at the  smelter by rail and ^re transported by
    conveyor to the  24,000-ton covered storage area.  Fripm there conveyors
    transfer the concentrates to storage bins near the roitary drier.  Concen-
    trates and flux are transported,  as needed, through•• the rotary drier
    on a single conveyor belt.

    1.  Exposures in the smelter's material handling areas are, poorly charac-
        terized.  The company has spent three years developing a dust-sup-
        pression wetting system to increase the moisture content of the con-
        centrates received.

B .  Flash Furnace                                     I

    Concentrates and silica flux are pneumatically conveyed to bins above the
    flash furnace. The  mixture is fed by a drag-chain conveyor into the
    furnace's reactor chamber where  four concentrate  burners preheat it.
    The feed rate (the speed of the feed belt) is established after a chemical
    analysis of the copper  content of the furnace slag. A chemical analysis of
    the matte grade  and temperature  determines the air inflow and the concen-
    trate burner combustion rates. Matte is  tapped througih hooded and ex-
    hausted tap holes and  transported by overhead cranesj
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       have been documented at other smelters with similar arsenic content
       in their concentrate.  The  company has reported! average sulfur diox-
       ide exposures to be 8.17 ppm and average area levels to be 4.67ppm.

   2.  OSHA has documented sulfur dioxide levels  as high as 25 ppm near
       the charge floor conveyors.  OSHA has documented exposures for the
       operator helper to be 9 ppm.

   3.  The company has reported average sulfur dioxide levels on the west
       side of the slag skimming area to range between 0 anal 138.5 ppm and
       average 28 ppm.
                                                     I
D. Converter Aisle
                                                     i
   The Hidalgo smelter has three  Peirce-Smith converters.  Matte from the
   flash and  electric furnaces is transported to the converters by overhead
   cranes  whose cabs  are enclosed.  Slag from the converters is returned to
   the electric furnace.  Blister copper from the converters is carried by
   crane to the anode area.

   1.  Arsenic exposures are poorly characterized.  Potentially hazardous
       exposures due to fugitive emissions during converter roll-out  and
       matte transportation have been documented in smelters with similar
       arsenic content in the concentrate.  In 1977, the company reported
       average exposures to sulfur dioxide at 2.45 ppm and average area
       levels to be 5.58 ppm.  OSHA has documented sttlfur dioxide levels
       on the converter operating floors  to range between 2 and  11 ppm.
       However, exposures  are uncharacterized.

   2.  The company is currently operating under an extended variance
       for high noise  levels  during converter punching  (110 dBA).  OSKA
        documented high to very high exposures to the converter puncher
        and utility man (2 to 2.5 times the allowable exposure limit).  The
        company is currently testing Noranda tuyere silencers to control
        noise levels.   In requesting the extended variance the company
        stated, "Our  preliminary investigaions to date [June,  1977] suggest
        that the success of the tuyere silencers in regard to satisfying the
        OSHA regulation is marginal." Exposures are uncharacterized.

 E.  Anode Area
    The  Hidalgo smelter has two anode furnaces and one casting wheel.  The
    blister copper in the anode furnaces is "poled"  with a reformed propane/
    air mixture to drive off the oxygen in it, and then cast into anodes on
    the casting wheel.  The casting wheel is  equipped with an automatic
    "take off" device  which removes the anodes.

    1.   Following an August, 1977 inspection, OSHA issued serious citations
        for high noise levels  in the anode area (utility man's exposures
        ranged from 2 to more than 3 times the allowable exposure limit).In
        March, 1978,  the company reported to OSHA that conversion from
        high-pressure air propane burners to low-pressure kerosene  burners
         was reducing  exposures and area levels which had ranged from 86
         to 93 dBA.  However, Phelps Dodge added, "We are not in compliance
         with the regulation at all times due to the proximity of the anode
         area to the converter tuyere punchers."  Current  exposures  are
         unknown.

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    2.   Arsenic exposures, if any, are poorly characterised.  Although by
        this time  most arsenic has been driven off from the blister copper,
        and the arsenic content of the concentrates at  the Hidalgo smelter is
        low, this  area has sometimes been the scene of potentially hazardous
        arsenic exposures at other smelters.            ['

F.  Other Areas

    1.   The company has reported  an average sulfur dioxide Jevel on the
        fourth floor of the Alhstrom Boiler to be 6.96 ppm.  EjXposures and
        number of workers affected are uncharacterized.

    2.   The company has reported  that the average personal exposure to
        sulfur dioxide at the drier  is 3 ppm.  Individual jexposures are un-
        characterized.                                 j

Comments:
COMPANY SAFETY AND HEALTH ACTIVITIES

A.  Staff
        Industrial hygiene technician - 1

        Safety Supervisors - 1

        Safety Engineers - 2
        Labor Department Director - 1

B.  Industrial Hygiene

    1.   There is no industrial hygienist on staff at the smelter.

    2.   All industrial hygiene activities are co-ordinated by the  Safety
        Supervisor and the industrial hygiene technician.

    3   The company performs some industrial hygiene sampling for noise,
        sulfur dioxide,  and hydrogen sulfide.  Extent and exact frequency
        of sampling for these and other hazards is unknown.

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C.  Respirator Program                                I

        Respirators are issued to all employees.  Employees are responsible
        for maintenance and storage.  Following  a  1976 OSHA citation, the
        company installed respirator cleaning stations.  '•

D.  Safety

    1.   Pre-employment safety orientation is conducted by the Safety Super-
        visor,                                             i
                                                           i

    2.  Refresher safety education is administered through department-level
        meetings every six weeks.
                                                      i
    3.  The company issues free of charge most necessary safety equipment.

F.  Health Care
                                                      I
    1.  Most medical care is administered through  the company clinic in
        Playas, New Mexico, ten miles from the smelter.
                                                         i
    2.  Clinic  staff includes registered nurses,  and  paraprofessional per-
        sonnel.  Closed circuit  TV monitor connects  clinic  with hospital in
        Silver City  during  emergencies.  An M.D.  visits the clinic twice a
        week.

    3.  Facilities for emergency and out-patient care only. All other treat-
        ment is handled in  the  Silver City Hospital,  sixty  miles to the north.

    4.  There are  supervisors  and workers trained in first aid on all shifts.

    5.  The company performs  pre-employment physicals.

 Comments:
 SAFETY COMMITTEE
 There is no Joint  Safety and Health Committee at the Hidalgo smelter-

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REGULATORY HISTORY                               (
                                                      i

A.  Pre-1970                                          i(


    1.  State Inspector of Mines


B.  Post-1970


    1.  State Inspector of Mines                            j
                                                           I
        a.  Almost exclusively a safety focus until  1973, when limited health
            activities were implemented.                ;

        b.  Approximately two inspections per year.  No union participation.

        c.  Agency still active.  Jurisdiction question vis a vis New Mexico
            State OSHA plant (see below) still unclear -
                                                      i

    2.  State OSHA plan                              ,

        a.  Administered  by New Mexico Environmental Improvement Agency

        b.  Approved 12/75. No smelter inspections  yet cpnducted.

                                                        I1
 C.  OSHA Activities


    Seven inspections:  3  health, 3 safety and one fatality.

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PROCESS EQUIPMENT—Hidalgo
                                          TABLE 1
NAME
Flash Furnace ( 1)
Electric Furnace ( 1)
Peirce-Smith Converters (3)
Anode Furnace (2)
Anode Casting- Wheel (1)
Acid Plant (2)
Elemental Sulfur Plant
AGE
1977
1977
1977
1977
1977
1977
1977
POLLUTION CONTROLS COMMENTS
Waste Heat Boiler ->
Electrostatic Precipitator
-> Acid Plants
Scrubber -> Stack
WHB + ESP -> Acid Plants
none
none



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                                           TABLE 2
SUMMARY OF HEALTH HAZARDS—Hidalgo
                                       TWA Exposures A
Number of
PLANT AREA Employees
Material Handling-
Smelting Furnaces
Flash Furnace
Electric Furnace
Converters
Anode Area
Acid Plants
Ahlstrom Boiler







Copper
mg/m^







Arsenic
mg/m3





	

Lead







Dioxide
(PPM) NOTES
3.00 personal*t
4. 35 personal*
6.39 area*
8. 17 personal*
4.67 area
2.45 personal*
5. 58 area*
. 16 personal*
1.05 personal*
6.96 area*
tDryer
excursions to 64 ppm
of sulfur dioxide
excursions to 138 ppm
of SO2.
Noise exposures to
248 percent of standard
• Silica exposure to
cast sprayer approxi-
mately one-half permis-
sible level.
•Noise exposures to
316% of standard
- •- ^- 	
	
A Independent of respirator usage




Sources: OSHA inspections
                                                                *Company reported average figures


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                                TABLE 3
SHA Inspections
idalgo, Phelps Dodge
                                              FOLLOW-]'

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