ENVIRONMENTAL PROTECTION AGENCY
       OFFICE OF ENFORCEMENT
      ASARCO
         HAYDEN
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
       DENVER, COLORADO

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STATE  IMPLEMENTATION PLAN
INSPECTION OF
ASARCO INCORPORATED
HAYDEN SMELTER
HAYDEN/  ARIZONA
                           AUGUST 1976
                           ENVIRONMENTAL PROTECTION AGENCY
                           NATIONAL  ENFORCEMENT  INVESTIGATIONS CENTER
                           Denver
                           OFFICE OF AIR QUALITY PLANNING AND
                           STANDARDS
                           Durham
                           REGION IX
                           San Francisco

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                          ASARCO INCORPORATED
                            HAYDEN, ARIZONA
SUMMARY AND CONCLUSIONS
     ASARCO Incorporated operates a custom smelter in Hayden, Arizona.
An inspection to acquire data with which to evaluate the design and
operation of existing particulate matter air pollution control equipment
at the smelter was conducted by EPA personnel on January 29, 1976.
Substantial amounts of process and control equipment information were
requested of, and received from, ASARCO.

     The following conclusions are based on the inspection and a review
of the information obtained:

     1.   The ASARCO smelter is the only Arizona Smelter to use spray
          chambers as conditioning units preceding their electrostatic
          precipitators (ESP's).  The Company reported that the units
          preceding the roaster/reverberatory furnace (R/R) and con-
          verter ESP's use acid water as the conditioning agent for the
          reverberatory furnace and converter exhaust gases.  More
          definitive design, operation,  and maintenance data for both
          spray chambers are necessary to more clearly understand their
          intended use at ASARCO and to  better determine the applicability
          and appropriateness of the principle for other smelters.

     2.   Cyclones are used as additional  pretreatment following the
          spray chamber, but before the  converter ESP.   The specific
          function of these devices was  not provided in the Company
          data.   Definitive data as to their designed purpose and
          collection efficiency is necessary to more clearly understand
          the applicability and appropriateness of this principle for
          other smelters.

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3.   The source test data reported are so variable that independent
     source tests for the R/R and converter processes are necessary.
     The data indicate the Company is not in compliance with the
     process weight regulation.  However, procedural, methodology,
     and process information regarding the Company conducted source
     tests is so sketchy one cannot be certain the tests were
     performed correctly or that physical and, perhaps even abnormal
     operational, characteristics did not unduly influence or bias
     the results.

4.   Any tests conducted at the R/R sampling station must take into
     account the fact that traverses must be done vertically with a
     6 m (20 ft) probe, with an inert (e.g., glass or quartz)
     liner, to obtain representative results for the roaster and
     reverberatory furnace processes.  The profile of the duct at
     the sampling station approximates a 6 m (20 ft) square.

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                             INSPECTION OF
                          ASARCO INCORPORATED
                            HAYDEN SMELTER
                            Hayden, Arizona
                           January 29, 1976
                             602/356-7717
INTRODUCTION

     ASARCO Incorporated operates a custom copper smelter at Hayden,
Arizona using pyrometallurgical  processes to produce copper anodes from
copper concentrates and precipitates.   Average anode copper production
during 1975 was 218 to 310 m.  tons (240 to 342 tons)/day.

     On December 17, 1976, the manager of ASARCO was requested by letter
to provide process and air pollution control information on the Hayden
Plant and informed of a planned plant inspection [Appendix A].  On
January 29, 1976 the following EPA personnel conducted a process in-
spection:  Mr. Larry Bowerman, Region IX; Mr. Reid Iversen, OAQPS; Mr.
Gary D. Young, NEIC; Mr. Jim V.  Rouse, NEIC.  Mr. Lary G. Cahill,
Manager, participated for the Company.

     All the information requested was supplied at the completion of the
inspection or by subsequent letter or telephone call [Appendix B].

     The purpose of the inspection was to acquire data with which to
evaluate the design and operation of existing particulate matter air
pollution control equipment.  The process equipment, the particulate
matter emission sources, and the air pollution control equipment,
focusing primarily on the smelter, were examined.

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     The applicable regulation contained in the Arizona State Implementation
Plan (SIP) specific to this inspection was the process weight regulation
[Appendix C],  This regulation was promulgated as 40 CFR §52.126 on May
14, 1973, to replace the State's process weight regulation, which was
determined by EPA to be insufficiently stringent.  The regulation provides
an allowable emission rate for each process unit based on production
feed rate to the unit.
PROCESS DESCRIPTION

     Figure 1 is a simplified process flow diagram for the smelter.
Table 1 lists the smelter process equipment and operating data.

     Concentrates and precipitates are delivered to the ASARCO smelter
by railroad cars.  Silica and limerock flux are delivered by truck.  All
materials are discharged to storage bins where they are mixed to the
required metallurgical balance.  The mix is then reclaimed and conveyed
by belt conveyor to the feed bins serving each of the twelve multihearth
roasters.  The blended materials are fed to the roasters at the top.
The charge is heated to the ignition point of sulfur using natural gas,
as available, or fuel oil to dry the charge and eliminate enough sulfur
to'produce a desired balance between copper, iron, and sulfur.  The
roasters revolve at about 2 rpm, while the charge is heated (roasted)
and swept by arms either toward a hole near the center or on the circumference
of the roaster.  As the charge passes to the hearth below, it continues
to be roasted and swept toward a hole located opposite of the hole in
the hearth above.  After passing six or seven hearths, the resultant hot
material (calcine) is discharged from a roaster to electrified rail cars
and conveyed to one of the two reverberatory furnaces.

     Both reverberatory furnaces are of sprung arch construction with
suspended arch uptakes to the waste heat boilers.  The No. 2 furnace is

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CASTING WHEELS
        (2)

                 ANODE
               FURNACES  (2)
                  /

                /
                ^
W

<
O
                          D
                          h
                                      CONVERTERS

                                            (5)
h



2
                        ROASTERS  (12)
                                          UJ
                                          UJ
                                          o:
o


U)
                                                          AIR
                               SILICA FLUX
                                                   SLAG
                                                      CONCENTRATES
                            PRECIPITATES

                            LIMEROCK

                            REVERTS
Figure 7.  ASARCO, Hoyden  Process  Flow.-Diagram

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                                     Table 1

                  SMELTER PROCESS EQUIPMENT AND OPERATING DATA
                               ASARCO INCORPORATED
                                 Hoyden, Arizona
Parameter Roasters
No. of Units 12
Feed
Constituents Co,P,SF,LF
Feed Rate
(per day) m.tons tons
969- 1 ,067-
1,414 1,558
Total
Size of Unit m ft
(#l-5)diameter 7.3 24
height 7.2 23.75
(#6-8)diameter 5.8 19
height 6.9 22.75
(#9-ll)diameter 6.6 21.6
height 5.6 18.5
(#12)diameter 7.6 25
height 10.6 34.75
Hours of
Operation/month 730
Gas Volume..
Generated
std m3/min 190-614
scfm 6,700-21,700
Exit Gas
Temperature °C °F
132-238 270-46
Reverberatory
Furnaces
2
Ca.SF.CS
m.tons tons
Ca 921-1,344 1,014-1,480
Cs 305-514 336-566
1,226-1,858 1,350-2,046
m ft
(#2)width 10 34 (#1,3,4)
length 35 115
(#4) width 9 30 (#2)
length 34 110
(#5)
730
#2 1,190-1,770
#4 1,150-1,280
#2 42,100-62,500
#4 40,500-45,200
°C °F
#2 266-366 510-690
#4 204-321 400-610
Converters
5
M.SF.AS
m.tons tons
M 639-806 704-888
SF 109-166 120-183
AS 3 3
751-975 827-1,074
m ft
diameter 4 13
length 10 33
diameter 4 13
length 9 30
diameter 4 13
length 11 35
730
821-1,460
29,000-51,700
ec op
404-549 760-1,020
 t  Concentrates (Co), Precipitates (P), Silica Flux (SF), Limerock Flux  (LF),
    Calcines (Ca),  Converter Slag (CS), Matte (M), Anode Furnace Slag  (AS)
tt  The gas volumes are ranges for the set of process units per unit and standard
    conditions are 760 mm Hg (29.9 in Hg or 14.7 psia) and 21°C (70°F).

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10 m (34 ft) wide and 35 m (115 ft) long, while the No.  4 furnace is 9 m
(30 ft) wide and 34 m (110 ft) long.   Calcine is fed through Wagstaff
feeders located in the sidewalls of both furnaces.   Both furnaces are
normally fired with natural gas, but if natural gas delivery is interrupted,
fuel oil is used.

     The calcine, upon melting, produces two products - slag and matte.
Consisting principally of iron, silica, calcium oxide, and alumina,  slag
floats on top of the bath.  It is skimmed from the  furnaces into large
rail mounted ladles and transported to a dump area.  The matte, consisting
principally of copper sulfide and iron sulfide, is  tapped near the
bottom of the furnaces into steel ladles which are  moved into the
converter aisTe.

     The matte ladles are picked up by overhead crane and charged to one
of the five Fierce-Smith converters.   Converters No. 1,  3 and 4 are  4 x
10 m (13 x 33 ft), Converter No. 2 is 4 x 9 m (13 x 30 ft), and Converter
No. 5 is 4 x 11 m (13 x 35 ft).  A typical initial  charge to a converter
consists of four ladles of matte.  Air is blown into the charge through
tuyeres for about sixty minutes.  Slag is skimmed and returned to one of
the reverberatory furnaces.  Then four identical cycles  take place
consisting of charging two ladles of matte to a converter, blowing for
35 to 60 minutes, skimming slag, and returning slag to a reverberatory
furnace.  During each of these "slag blows," silica is added to the
converter to combine with the iron released when sulfur in the iron
sulfide is oxidized to SOg.  Following each of the  slag  blows, the
converter is blown for roughly four hours on the "copper blow."

     The final converter product is blister copper  which is poured into
ladles and carried by overhead crane to one of the  two anode furnaces.
There additional air is blown through tuyeres to remove  final traces of
sulfur, and then natural gas is added to the furnace to  remove any
residual oxygen.  Finished anode copper is cast into anodes on either

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of the two casting wheels.  The anodes are cooled, inspected, and shipped
to ASARCO's refinery in El Paso, Texas.
EMISSION SOURCES AND RELATED CONTROL EQUIPMENT

     The primary participate matter sources at the ASARCO smelter are
the roasters, reverberatory furnaces, and the converters.  The majority
of the exhaust gas volumes produced by these sources is treated by
control systems which are discussed below.  However, fugitive emissions
from feeding concentrates, skimming converter slag, or returning converter
slag are neither collected, nor treated, but are exhausted directly to
the atmosphere.  Exhaust from the matte tap area is collected and is
exhausted untreated in the duct following the roaster/reverberatory
furnace (R/R) electrostatic precipitator (ESP).  Converter "smoke" not
collected by the primary hood system is exhausted untreated through the
converter aisle roof vent.  The anode furnaces also emit some untreated
particulate matter directly to the atmosphere above the converter aisle;
however, since the gas stream is not collected, the concentrations are
indeterminate.

     Figure 2 is a diagram of the ASARCO smelter layout, the air pollution
control system, and the exhaust gas flow.   Table 2 summarizes certain de-
sign and operating data for the individual air pollution control systems.
Appendix B contains more specific information on each control system.

Multihearth Roaster Control System

     The roaster process gases are discharged to a common flue maintained
under negative pressure.  The gases flow through a settling chamber
following which they join the reverberatory furnace exhaust gases as
they enter the R/R ESP.   The gas volume generated by ten of the twelve
roasters, considered to be maximum normal  operations, could be as high
as 2,720 std m3/min (96,000 scfm)  [Appendix D].

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                                                                          \  ABSORBING
                                                                          N TOWER
CASTING
WHEELS (2)
 ANODE FURNACES
     (2)
Ul
I
K
O
B.
                ESP (8)
                        CO
                        2
                        >

                        K
                             > «
                             ? W
            * »
            5 m
            s<
            M
            ui U.
                       '-O
                                                                       i   ^v  \   7^:
                                                                            OxNv f^f-
                                                                               X^VJ^""
                                                                                v^*^
                                                             SCRUBBING
                                                             TOWERS (3
                                                                           SPRAY CHAMBER
                                                                         CYCLONES (18)
                                                              _^^_ PROCESS PLOW

                                                              ........ EXHAUST OASES
                                                                                            CATALYST
                                                                                            CHAMBER
                                CASTERS (19)
                   Figure 2.  ASARCO, Hoyrftn Flanf layout, frocen (Mhawtr Flew, and Air Follufion Cenfrol Syifcm*

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                                                         Table 2

                               SMELTER AIR POLLUTION CONTROL EQUIPMENT AND OPERATING DATA
                                                   ASARCO INCORPORATED
                                                     Hoyden, Arizona
Control Manufacturer
Device
Date of
Installation/
Modification
No. of
Units
Gas Flow
Rate

3 3
m /min scfm
Operating
Temperature
°C °F
Pressure
H-0
cm
Drop
in
Collection
Area
mz ft2
Velocity
m/sec ft/sec
Retention
Time
sec
                                                         Roasters
ESP (see description under Reverberatory Furnaces)
                                                  Reverberatory  Furnaces
ESP           b               2/75          1      7,790-  275,000-  121-   250-  0.5    0.2 12,766 137,411   5.8   18.9       3.05
                                                  8,500   300,000  135    275

Cyclones
ESP
Acid Plant

NRe
Chemiebau
Rust Engineering

NR
10/70
e
Converters
15 NR NR NR
1 2,830 100,000 371 700 7.7 3
1 3,110 110,000 454 850 NR

NAd
NR
NA

NR
NR
flA

NR
NR
NA
a  Standard conditions are 760 mm Eg (29.92 in Eg or 14.7 peia)  and 21°C  (70°P).
b  No manufacturer,  ASARCO design and construction
 *  NR = Not reported
 d  NA = Not applicable
 e Underaay during inspection
                                                                                                                               CO

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Reverberatory Furnace Control System

     The process gases from each reverberatory furnace pass through
waste heat recovery boilers for steam production.   Upon exiting the
waste heat boilers, the gases pass through a spray chamber for scrubbing
and temperature conditioning.  The exit gas volume of the two reverberatory
                                                   o
furnace gas streams could be as high as 3,030 std  m /min (107,700 scfm)
[Appendix D].  The reverberatory furnace gases then join the roaster
gases and enter an ESP.  The ESP handles an actual gas flow rate of
                    o
7,790 to 8,500 std m /min (275,000 to 300,000 scfm); the design gas flow
rate was not reported.  The ESP consists of eight  banks (parallel units)
of four stages each (units in series) with a total collection area of
12,800 m2 (137,400 ft2).   Gas treatment time is estimated as slightly
over 3 seconds with an average gas velocity of nearly 6 m (19 ft)/sec.
The pressure drop across the ESP is less than 0.5  cm (0.2 in) of water.
The exit gas stream is discharged through the 305  m (1,000 ft) stack.
Converter Control System

     The principal converter exhaust gases become laden with particulate
matter when air is blown into a converter through tuyeres to oxidize the
iron and copper sulfides.  The process gases are collected -n water-
cooled hoods installed over each converter mouth before passing through
settling chambers where the larger, heavier particulate matter settles
out of the gas stream.  The gas stream, which could be as high as 4,160
std m /min (146,800 scfm), then passes through high velocity flues to
three cyclones servicing each converter.  The exhaust gases then combine
and enter a spray chamber in which the gases are scrubbed and their
temperature is lowered prior to the ESP.  The ESP actually handles a
                               o
reported maximum of 2,830 std m /min (100,000 scfm).   The ESP consists
of four parallel units (banks) with each parallel unit consisting of
three sections (stages).  The collection area, gas velocity, and retention

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                                                                  10
time were not reported, as they were not requested.   The pressure drop
across the unit is 8 cm (3 in) of water, maximum.

     Following the ESP, the gas enters a 50% acid spray tower.   The gas
stream is then split and enters one of the two gas scrubbing towers,
followed by one of the two gas cooling towers.  The gas then enters a
series of two mist ESP's, before the two individual  gas streams are
reunited.  The clean gas then enters the acid plant where it is dried,
the S02 is converted into SO-j, and the S03 is. absorbed in acid to form
the final strength acid.  Although designed to produce 680 m. tons (750
tons)/day, approximately 445 m. tons (490 tons)/day of 93-98% strength
sulfuric acid is the actual production rate.  The exit gas from the
final absorption tower passes through a demister before being ducted to
and exhausted from the 305 m (1,000 ft) stack.
EMISSIONS DATA

     Four source tests were conducted at the ASARCO smelter during 1975;
all four were performed by the Company at the request of either the EPA
Region IX Enforcement Division or the State of Arizona.  The first,
third, and fourth tests were conducted for the roaster and reverberatory
furnace processes and the second for the converter process.  Each test
was attempted as a compliance test following the prescribed methods
(Methods 1-5) in the EPA regulation [Appendix C].

     The R/R tests were conducted at the sampling station on the nearly
square [6 m (20 ft)] R/R flue downstream from the R/R ESP before the
flue enters the 305 m (1,000 ft) stack.  The sampling station is six
duct diameters downstream from and five and one-half duct diameters
upstream of any flow disturbance.  Thirty-six traverse points, six for
each of the six vertical ports, were sampled during each test run.

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                                                                  11
     The converter tests were conducted at the sampling station on the
3-m (10-ft) diameter acid plant exhaust gas duct.   The sampling station
is eight diameters downstream from and two diameters upstream of any
flow disturbance.  Twelve traverse points, all located on the vertical
diameter since there is no horizontal  port, were sampled.

     Individual process weights were determined for the roasters, reverberatory
furnaces, and converters.  The roaster process weight was determined by
summing the differences between the start and end weights of the ore bin
and each of the twelve roaster bins.  The reverberatory furnace process
weight was determined by multiplying the number of charges and ladles of
converter slag by individually assumed density factors (tons per charge
or ladle) and adding the two products.  The converter process weight was
determined by multiplying the number of ladles of matte and scrap by
individually assumed density factors,  adding the two products, adding
the tons of silica flux charged, and dividing the entire sum by the
number of hours all converters, which were in operation sometime during
the actual time of the test run, were on charge and not idle.  The
allowable rates were then calculated by the formula contained in the
applicable regulation [Appendix C] and the test results compared with
the allowable rates.

     Following is a summary of each of the four tests and comments
regarding the methods, procedures, and results of each test.
R/R:  June 30-July 5. 1975

     Four test runs were conducted at the R/R flue sampling station.
The minimum sampling time (2 hours), minimum sampling volume [1.70 m
(60 ft )], and isokinetic tolerances (90-110%) were all met.  For the
first three runs a 6 m (20 ft) Inconel  probe was used; for the fourth
run a 3 m (10 ft) glass-lined probe was used.

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                                                                  12
     The Company reported the process operations were erratic during the
test period.  They also reported that the acid water conditioning preceding
the R/R ESP was not adjusted properly.  In addition, since the probe
washes for the first three runs showed higher chrome and nickel concentrations,
in comparison with the probe washes for the fourth run, the Company
concluded the deterioration of the Inconel probe was the cause for the
high particulate values.  For all the above reasons, the Company concluded
that this test should not be considered representative of normal operations
or reliable and offered to redo the tests upon acquiring a 6 m (20 ft)
Teflon-lined probe and making the necessary process adjustments to
reflect normal operation.  The results of the four runs are presented in
Table 3.
Converters:  July 1 and 9, 1975

     Three test runs were conducted at the sampling station on the acid
plant exhaust gas duct.  The minimum sampling time and volume were met.
The isokinetic rates were within tolerances, except for the first run
where the rate was 88%.  Again, only a single diameter was used for the
twelve traverse points.  A 3 m (10 ft) glass-lined probe was used for
the test.  The results of the test are presented in Table 3.


R/R:  September 8-11. 1975

     Three test runs were conducted at the R/R flue sampling station.
The minimum sampling time and volume were met.  However, isokinetic
rates were 110, 113, and 113%.  A 6 m (20 ft) Teflon-lined probe was
used.

     The Company reported that production was, to some extent, above
normal; i. e. production exceeded capacity for short periods of time
during some of the test period.  The Company also reported that the acid

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                                                                        13
                                   Table 3

                  PARTICULATE MATTER EMISSIONS TEST RESULTS
                             ASARCO INCORPORATED
                               Hoyden,  Arizona
Test
Run

R/R-1*
R/R-2°
R/R-3?
R/R-4D
C-ld
** H
C-3d
R/R-lE
R/R-2J
R/R-3 b
R/R-lb
R/R-2b
R/R-3b
Date
1975

6-30
7-3
7-3
7-5
7-1
7-9
7-9
9-8
9-10
9-11
11-3
11-4
11-4
Stack
Temperature
Op
264
255
261
234
143
167
164
267
296
277
241
243
235
°C
129
124
127
112
62
75
73
131
147
136
116
117
113
Gas
Vol ume
scfma
303,948
308,929
307,146
298,318
88,800
90,694
87,936
283,132
292,449
296,619
276,173
279,666
303,349
3. .
m /mm
8,607
8,748
8,697
8,447
2,515
2,568
2,490
8,017
8,281
8,399
7,820
7,919
8,590
Moisture
Content
%
7.
8.
8.
5.
<0.
<0.
<0.
9.
9.
9.
11.
10.
11.
i
7
0
5
8
1
1
1
6
8
5
9
2
6
Actual
Emissions
Ib/hr
124
124
1,155
48
49
23
30
64
91
83
77
112
122
kg/hr
56
56
524
22
22
10
14
29
41
38
35
51
55
Allowable
Emissions
Ib/hr kg/hr
68
67
67

30
29
31
72
76
76



31
30
30
NDC
14
13
14
33
34
34
NRe
NR
NR
a Standard conditions are reported as 29.92 in Hg and 21°C (70°F).
^Sampling took place along the roaster/reverberatory (R/R) furnace flue
  downstream from the R/R ESP and upstream of the stack.
*.ND = Not determined
  Sampling took place along the duct downstream from the acid plant and
  upstream of the stack.
eM? = Not reported

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                                                                  H
water conditioning system was operated manually,  as the automatic
neutralization section would not control  acid content within the range
desired.  The results of the three runs are presented in Table 3.

R/R:  November 3-4, 1975

     At the request of the State of Arizona, the Company conducted
another test at the R/R flue sampling station.  Although the details of
the test were not provided in Reference 1, a summary of the results was,
part of which is presented in Table 3.

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                             BIBLIOGRAPHY
1.   Copper Smelter Information Needs,  ASARCO Incorporated,  Hayden
     Plant, Hayden, Arizona.   Jan.  29,  1976.

2.   Letter from K. D.  Loughridge,  Vice President,  ASARCO Incorporated
     to Don R.  Goodwin, Director,  Emission Standards and Engineering
     Division,  EPA-RTP, Oct.  9, 1975.

3.   Compilation and Analysis of Design and Operating Parameters  of
     the ASARCO Incorporated, Hayden Plant, Hayden, Arizona  for Emission
     Control Studies.  Pacific Environmental  Services, Inc., Santa
     Monica, Nov. 1975.

4.   Letter from L. G.  Cahill, Manager, ASARCO Hayden Plant  to R.  L.
     O'Connell, Director, Enforcement Division, EPA-Region IX, July
     17, 1975.

5.   Letter from L. G.  Cahill, Manager, ASARCO Hayden Plant  to R.  L.
     O'Connell, Director, Enforcement Division, EPA-Region IX, Oct.
     7, 1975.

6.-  Letter from L. G.  Cahill, Manager, ASARCO Hayden Plant  to
     Thomas P.  Gallagher, Director, EPA-NEIC, Denver, Mar. 2, 1976.

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     APPENDICES
NEIC Information Request
  Letter to ASARCO
ASARCO Response to NEIC
  Information Request
SIP Regulation Applicable to
  ASARCO
Estimates of Gas Flow Rates

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       Appendix A

NEIC Information Request
    Letter to ASARCO

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                  ENVIRONMENTAL PROTECTION AGENCY
                        OFFICE OF ENFORCEMENT
             NATIONAL FIELD INVESTIGATIONS  CENTER- DENVER
                 BUILDING 53. BOX 25227. DENVER FEDERAL CENTER
                         DENVER,  COLORADO 80225
                           December 17,  1975

Lary G. Cahill
Manager
Hayden Smelter
ASARCO Incorporated
Hayden, Arizona 85235

Dear Mr. Cahill:

     The Environmental Protection Agency has undertaken  a  program  to
evaluate the performance characteristics of particulate  control  facilities
at the copper smelters in  Arizona and  Nevada.  Representatives  of  EPA
will observe each smelter's process operations and  air pollution control
facilities, review source  test data, examine appropriate records,  etc.,
during a site inspection of each  smelter.

     In anticipation of such a site inspection of your smelter,  we have
prepared the attached list of detailed information  needs which  we  intend
to use as a discussion outline during  our inspection.  We  would  appreciate
it if you could inform the appropriate company personnel about  the
attached list and the forthcoming inspection of your  facility so that
the necessary information  will be readily available and  the inspections
can be expedited.

     We are conducting these inspections under the  authority of Section
114(a)(ii) of the Clean Air Act,  which authorizes representatives  of EPA
to enter facilities for the purpose of determining  whether the  facility
is in violation of any requirement of  a  state implementation plan.  At
your facility, we anticipate that EPA  or a contractor hired by  EPA will
be conducting an emissions source test for particulate matter within the
next few months.  Therefore, EPA  will  make a source test pre-survey,
either separately or in conjunction with our site inspections,  prior to
performing such a source test.

     If you have any questions concerning the purpose of these  site
inspections, please feel free to  contact Mr.  Gary D.  Young of my staff
(303/234-4658) or Mr. Larry Bowerman,  EPA Region IX (415/556-6150).  Mr.
Young will be in contact with you within the next few weeks concerning a
site inspecton of your smelter during  January or early February.

                                                 Sincerely,
                                                  Thomas  P. Gallagher
Attachment                                        Director

cc:  Richard O'Connell
     Bruce Scott

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                   COPPER SMELTER INFORMATION NEEDS
A.  GENERAL

     1.  Plant location

     2.  Person to contact regarding plant survey information needs, his
         telephone number and address

     3.  Simple block flow diagram showing smelter process equipment, air
         pollution control devices, and stack configuration


B.  PROCESS

     1.  General

          a.  Detailed description of the process, including flow diagrams,
              unique features, and how the process operates

          b.  Definition of normal operation

          c.  Actual production rate (Ibs blister copper/hr and percent Cu)

          d.  Type and quantity of fuel consumed

               Oil - i.  Heating value (BTU's/gal)
                    ii.  Percent sulfur (by weight)
                   iii.  Percent ash (by weight)
                    iv.  Specific gravity
                     v.  Consumption (gals or bbls/yr)

               Gas - i.  Type of gas (constituents in percent by weight)
                    ii.  Density (Ibs/SCF)
                   iii.  Heating value (BTU's/SCF)
                    iv.  Percent sulfur (by volume and grains/SCF)
                     v.  Consumption (SCF/yr)

              Coal - i.  Heating value (BTU's/T)
                    ii.  Percent sulfur (by weight)
                   iii.  Percent ash (by weight)
                    iv.  Consumption (Ibs/unit/hr)

          e.  Ore composition, including a typical percent and range of
              percentages for each chemical constituent

          f.  Flux composition, including a typical percent and range of
              percentages for each chemical constituent

          g.  Standard conditions - pressure (psi) and temperature (°F)--
              used to calculate SCFM

-------
2.  Concentrators

     a.  Design process feed rate (Ibs raw ore/hr)

     b.  Actual process feed rate (Ibs raw ore/hr),  including method
         and estimated accuracy of measurement

     c.  Average number of hours of operation per month

     d.  Process instrumentation used, including data for a typical
         reading and range of readings

     e.  Description of where and how samples of process material can
         be collected

     f.  Description of typical types of process fluctuations and/or
         malfunctions, including frequency of occurrence and anticipated
         emission results

     g.  Expected life of process equipment (years)

     h.  Plans to modify or expand process production rate

3.  Roasters

     a.  Design process feed rate (Ibs concentrate/hr)

     b.  Actual process feed rate (Ibs concentrate/hr), including
         method and estimated accuracy of measurement

     c.  Design process gas volumes (SCFM)

     d.  Actual process gas volumes (SCFM), including method of
         determination, calculation, or measurement

     e.  Actual process temperature (°F)

     f.  Average number of hours of operation per month

     g.  Process instrumentation used, including data for a typical
         reading and range of readings

     h.  Description of where and how samples of process material
         can be collected

     i.  Description of typical types of process fluctuations and/or
         malfunctions, including  frequency of occurrence and anticipated
         emission results

-------
     j.  Expected life of process equipment (years)

     k.  Plans to modify or expand process production rate

4.  Reverberatory furnaces

     a.  Design process feed rate (Ibs calcine/hr + Ibs flux/hr +
         Ibs converter slag/hr)

     b.  Actual process feed rate (Ibs calcine/hr + Ibs flux/hr +
         Ibs converter slag/hr), including method and estimated
         accuracy of measurement

     c.  Design process gas volumes (SCFM)

     d.  Actual process gas volumes (SCFM), including method of
         determination, calculation, or measurement

     e.  Actual process temperature (°F)

     f.  Average number of hours of operation per month

     g.  Process instrumentation used, including data for a typical
         reading and range of readings

     h.  Description of where and how samples of process material can
         be collected

     i.  Description of typical types of process fluctuations and/or
         malfunctions,  including frequency of occurrence and anticipated
         emission results

     j.  Expected life of process equipment (years)

     k.  Plans to modify or expand process production rate

5.  Converters

     a.  Design process feed rate (Ibs matte/hr + Ibs slag/hr +
         Ibs flux/hr)

     b.  Actual process feed rate (Ibs matte/hr + Ibs slag/hr +
         Ibs flux/hr),  including method and estimated accuracy of
         measurement

     c.  Design process gas volumes (SCFM)

     d.  Actual process gas volumes (SCFM),  including method of
         determination,  calculation,  or measurement

     e.  Actual process temperature (°F)

-------
     f.  Average number of hours of operation per month

     g.  Process instrumentation used,  including data for a typical
         reading and range of readings

     h.  Description of where and how samples of process  material can
         be collected

     i.  Description of typical types of process fluctuations and/or
         malfunctions,  including frequency of occurrence  and anticipated
         emission results

     j.  Expected life of process equipment (years)

     k.  Plans to modify or expand process production rate

6.  Refining Furnaces

     a.  Design process feed rate (Ibs  blister copper/hr)

     b.  Actual process feed rate (Ibs  blister copper/hr), including
         method and estimated accuracy  of measurement

     c.  Design process gas volumes (SCFM)

     d.  Actual process gas volumes (SCFM), including method of
         determination, calculation,  or measurement

     e.  Actual process temperature (°F)

     f.  Average number of hours of operation per month

     g.  Process instrumentation used,  including data for a typical
         reading and range of readings

     h.  Description of where and how samples of process  material can
         be collected

     i.  Description of typical types of process fluctuations and/or
         malfunctions,  including frequency of occurrence  and anticipated
         emission results

     j.  Expected life  of process equipment (years)

     k.  Plans to modify or expand process production rate

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C.  EMISSIONS

     1.  List of sources of particulate emissions  in the  plant  (including
         fugitive emissions)

     2.  Level of uncontrolled particulate emissions by source  (Ibs/hr  or
         T/yr)

     3.  Existing source test data employed for particulates  by stack,
         process unit,  or control device,  including:

          a.  Test method

          b.  Data acquired

          c.  Operating process weight rate

          d.  Calculations

          e.  Test results

     4.  Particle size and chemical composition of uncontrolled particulate
         emissions, including method of determination

     5.  Level of uncontrolled visible emissions by source (percent  opacity)
         and method of determination

     6.  Extent of and reason for variance of particulate emissions  with:

          a.  Process design parameters

          b.  Process operating parameters

          c.  Raw material composition or type

          d.  Product specifications or composition

          e.  Production rate

          f.  Season or climate

          g.  Sulfur dioxide control


D.  CONTROL SYSTEMS

     1.  Detailed description of the particulate and sulfur dioxide  emissions
         control systems, including:

          a.  Process treated

-------
     b.   Type of fuel consumed per unit

     c.   Quantity of fuel consumed per unit

     d.   Method of determination of design parameters

     e.   Engineering drawings or block flow diagrams

     f.   Expected life of control system

     g.   Plans to upgrade existing system

2.  Electrostatic precipitators

     a.   Manufacturer, type,  model number

     b.   Manufacturer's guarantees, if any

     c.   Date of installation or last modification and a detailed
         description of the nature and extent of the  modification

     d.   Description of cleaning and maintenance practices,  including
         frequency and method

     e.   Design and actual values for the following variables:

            i.  Current (amperes)
           ii.  Voltage
          iii.  Rapping frequency (times/hr)
           iv.  Number of banks
            v.  Number of stages
           vi.  Particulate resistivity (ohm-centimeters)
          vii.  Quantity of ammonia injected (Ibs/hr)
         viii.  Water injection flow fate (gals/min)
           ix.  Gas flow rate (SCFM)
            x.  Operating temperature (°F)
           xi.  Inlet particulate concentration (Ibs/hr or grains/SCFM)
          xii.  Outlet particulate concentration (Ibs/hr or grains/SCFM)
         xiii.  Pressure drop (inches of water)

3.  Fabric filters

     a.   Manufacturer, type,  model number

     b.   Manufacturer's guarantees, if any

     c.   Date of installation or last modification and a detailed
         description of the nature and extent of the  modification

-------
     d.   Description of cleaning and maintenance practices,  including
         frequency and method

     e.   Filter material

     f.   Filter weave

     g.   Bag replacement frequency

     h.   Forced or induced draft

     i.   Design and actual values for the following variables:

            i.   Bag area (ft2)
           ii.   Bag spacing (inches)
          iii.   Number of bags
           iv.   Gas flow rate (SCFM)
            v.   Operating temperature (°F)
           vi.   Inlet particulate concentration (Ibs/hr or grains/SCF)
          vii.   Outlet particulate concentration (Ibs/hr or grains/SCF)
         viii.   Pressure drop (inches of water)

4.  Scrubbers

     a.   Manufacturer, type,  model number

     b.   Manufacturer's guarantees, if any

     c.   Date of installation of last modification and a detailed
         description of the 'nature and extent of the modification

     d.   Description of cleaning and maintenance practices, including
         frequency and method

     e.   Scrubbing media

     f.   Design and actual values for the following variables:

            i.   Scrubbing media flow rate (gals/min)
           ii.   Pressure of scrubbing media (psi)
          iii.   Gas flow rate (SCFM)
           iv.   Operating temperature (°F)
            v.   Inlet particulate concentration (Ibs/hr or grains/SCF)
           vi.   Outlet particulate concentration (Ibs/hr or grains/SCF)
          vii.   Pressure drop (inches of water)

5.  Sulfuric acid plants

     a.   Manufacturer, type,  model number

-------
     b.   Manufacturer's guarantees,  if  any

     c.   Date of installation or last modification and  a  detailed
         description of the nature and  extent  of  the  modification

     d.   Description of cleaning and maintenance  practices,  including
         frequency and method

     e.   Frequency of catalyst screening

     f.   Type of demister

     g.   Design and actual values for  the following variables:

            i.  Production (T of acid/day)
           ii.  Conversion rate (percent)
          iii.  Acid strength (percent  l^SC^)
           iv.  Number of catalyst beds
            v.  Gas flow rate (SCFM)
           vi.  Operating temperature  (°'F)
          vii.  Inlet S02 concentration (ppm)
         viii.  Outlet S02 concentration (ppm)
           ix.  Acid mist (Ibs t^SO^/T  of acid)
            x.  Blower pressure (psi)

6.  Liquid S02 plants

     a.   Manufacturer, type, model number

     b.   Manufacturer's guarantees,  if  any

     c.   Date of installation or last modification and  a  detailed
         description of the nature and  extent  of  the  modification

     d.   Description of cleaning and maintenance  practices,  including
         frequency and method

     e.   Absorbing media

     f.   Design and actual values for  the following variables

            1.  Production (T of S02/day)
           ii.  Conversion rate (percent)
          iii.  Gas flow rate (SCFM)
           iv.  Operating temperature  (°F)
            v.  Inlet S02 concentration (ppm)
           vi.  Outlet $62 concentration (ppm)
          vii.  Acid mist (Ibs H2S04/T  of S02)

-------
     7.  Detailed description of how the particulate and sulfur dioxide
         emission control systems operate

     8.  Description of instrumentation (flow meters, continuous monitors,
         opacity meters, etc.) used, including manufacturer and model
         number, data for typical and range of readings, and identification
         of location by process unit, control system unit,  or by stack

     9.  Description of typical types of control system malfunctions,
         including frequency of occurrence and anticipated  emission results
E.  STACKS
     1.  Detailed description of stack configuration,  including process
         and/or control system units exhausted

     2.  Identification by stack of:

          a.  Heights (ft above terrain)

          b.  Elevation of discharge points (ft above  sea level)

          c.  Inside diameters (ft)

          d.  Exit gas temperatures (°F)

          e.  Exit gas velocities (ft/sec)

-------
        Appendix B

      ASARCO Response
to NEIC Information Request

-------
       COPPER SMELTER INFORMATION NEEDS
                 Submitted To
       ENVIRONMENTAL PROTECTION AGENCY
            OFFICE OF ENFORCEMENT
NATIONAL FIELD INVESTIGATIONS CENTER - DENVER
              ASARCO INCORPORATED
                 HAYDEN PLANT
            HAYDEN, ARIZONA  85235
               January 29, 1976

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              COPPER SMELTER INFORMATION NEEDS
A.  GENERAL
    1.   Plant location

        Hayden, Arizona
    2.   Person to contact regarding plant survey information
        needs, his telephone number and address
        Mr. Lary G. Cahill, Manager
        ASARCO Incorporated
        P. 0.  Box 98
        Hayden, Arizona  85235
        (602)  356-7717
    3.   Simple block flow diagram showing smelter process
        equipment, air pollution control devices, and stack
        configuration
        Drawing 5258-A  (Attached)

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B.  PROCESS
    1.   General

        a.   Detailed description of the process,  including flow
            diagrams,  unique features,  and how the process
            operates

            See Attached - PROCESS FLOW SHEETS B,  C, D,  E, E-l,
            F, G,  H AND J.

            The Hayden Plant is a custom copper smelter using
            pyrometallurgical processes to produce copper
            anodes from copper concentrates and precipitates.

            Copper concentrates and precipitates are delivered
            to the plant by railroad cars.  The cars, after
            weighing and sampling, are unloaded to one of four
            ore bins.   Silica and limerock flux,  delivered by
            truck, is also discharged to these same bins to
            provide the required metallurgical balance to flux
            the iron and alumina content of the concentrates
            and precipitates (PROCESS FLOW SHEET B).  The mix
            is then reclaimed and conveyed by belt conveyor to
            the feed bins serving each of the roasters.   The
            plant  has twelve roasters.   Nos.  1-5 are McDougals
            24' O.D. by 23'-9" high, 6-hearth; Nos. 6-8 are
            McDougals 19' O.D. by 22'-9" high, 7-hearth; Nos.
            9-11 are Herreshoff 21'-7" O.D. by 18'-6" high, 7-
            hearth; and No.  12 is Bartlett-Snow-Pacific 25'
            O.D. by 34'-9" high, 12-hearth.

            The mix or charge is heated to the ignition point
            of sulfur using natural gas or fuel oil to dry the
            charge and eliminate enough of the sulfur to pro-
            vide for a balance between the copper, iron and
            sulfur to produce the desired matte grade in the
            reverberatory furnaces.  The resulting material
            called calcine is hot, approximately 950°F,  and
            very fluid to facilitate rapid melting in the
            reverberatory furnaces (PROCESS FLOW SHEET C).
            The calcines are discharged from each roaster into
            calcine hoppers to await removal and transporting
            to the reverberatory furnaces.  Calcines are con-
            veyed  to the reverberatory furnaces in 10-ton
            electrified rail cars called "Larry cars".  The
            roaster process gases are discharged to a common
            flue maintained under negative pressure to an elec-
            trostatic precipitator for dust removal before
            being  emitted to the atmosphere from a 1,000-foot
            stack.

-------
Calcines are charged to the reverberatory furnaces
from the Larry cars 'through charge guns located in
the sidewalls of the furnaces.  The revcrberatory
furnaces are natural gas or fuel oil fired to
generate the heat required to melt the calcines and
maintain the bath in the furnaces in a liquid state.
The calcine upon melting produces two products —
slag and matte.  The slag consisting principally of
iron, silica, CaO and alumina, and due to its lower
specific gravity, floats on the top of the furnace
bath.  Slag is skimmed from the furnaces into rail
track mounted ladles and transported to a dump area
where it is discarded.  The matte consisting princi-
pally of copper, iron and sulfur as copper sulphide
and iron sulphide, and due to its higher specific
gravity, settles to the bottom of the furnace.  The
matte is tapped out of the bottom of the furnaces
in cast steel ladles where it is transferred to the
copper converters.  The plant has two reverberatory
furnaces:   No. 2 - 115* long by 34' wide, and No.
4 - 110' long by 30' wide.  The process gases from
each furnace are passed through waste heat boilers
for recovery of waste heat and production of steam
used to produce process air and generation of elec-
trical power.  The gases upon exiting the waste heat
boilers are conveyed through a spray chamber for
scrubbing and temperature conditioning before being
passed through the electrostatic precipitators for
particulate removal.  The gases are then emitted to
the atmosphere from the 1,000' stack (PROCESS FLOW
SHEET D).

The copper matte tapped from the reverberatory
furnaces is transferred by overhead crane to one of
five copper converters.  The converters consist of
three 13' by 33'; one 13' by 30'; and one 13' by 35'
furnaces.  A typical converter cycle consists of an
initial slag blow of sixty minutes using 4 ladles
of matte, followed by four additional slag blows of
35 to 60 minutes using additions of two ladles of
matte each time.  After each blow, slag is skimmed
before the next matte addition.  After the five slag
blows, the remaining slag is skimmed from the con-
verter and it is blown for four hours on the copper
blow.  The complete cycle takes roughly 10 hours at
the end of which 5 ladles of copper are transferred
to the anode furnace.

During slag blows, silica js added to the converter
to flux the iron released when the sulfur attached
to the iron is oxidized to S02.  This forms a slag
called converter slag which is skimmed off at the end
of the slag blow.  The converter slag is returned to

-------
the reverberatory I'urnaces.  The copper blow com-
mences once the converter is fully charged and the
iron has been fluxed and skimmed off as slag.  The
copper blow oxidizes the sulfur in the copper sul-'
phide to S02 gas which is emitted to the converter
flue system.  The final converter product is blister
copper which is transferred in steel ladles to one
of two anode furnaces (PROCESS FLOW SHEET E).

The process gases from the converter furnaces are
collected in water-cooled hoods installed over
each converter mouth before passing into settling
chambers where larger and heavier particulate matter
settles out of the gas stream.  This particulate
matter is transferred back to the ore bins for re-
cycling through the plant.  The process gases are
then conveyed through high velocity flues to three
cyclones servicing each converter before joining
into a spray chamber.  The spray chamber is used
to scrub and temperature condition the gases prior
to passing  into an electrostatic precipitator.  The
particulate collected by the cyclones and spray
chamber is  recycled back to the ore bins.  The elec-
trostatic precipitator consists of four sections of
three units each.  Particulate collected in the
electrostatic precipitator is conveyed to a pugmill
for wetting before loading to rail cars for shipment
to Asarco's El Paso, Texas plant for processing.
The converter gases are conveyed through the flue
system by three hot gas fans.  These fans discharge
to either the acid plant or to the 1,000-ft. stack
(PROCESS FLOW SHEET E-l).

The converter gases discharge from the hot gas fans
into the 50% scrubbing tower, two gas scrubbing
towers, two gas cooling towers and wet gas mist
precipitators (PROCESS FLOW SHEET F) before going
on to the acid plant (PROCESS FLOW SHEET H) to con-
vert the S02 into 803 and produce sulfuric acid.
The blister copper produced by the converters is
treated in one of two anode furnaces and cast into
anodes for shipment to the copper refinery.  The
treatment consists of blowing the copper with air
to remove final traces of sulfur and poling the
copper with natural gas to remove any residual
amounts of oxygen (PROCESS FLOW SHEET J).
Definition of normal operation

Processing an average of 2,000 TPD copper concen-
trates utilizing approximately 10 roasters, 2 rever-
beratory  furnaces, 3 converters and 2 anode  furnaces

-------
    Actual production rate (Ibs. blister copper /hr
    and percent Cu)

    Actual production rate is variable.  At design
    capacity - 39,000. Ibs/hr; calendar year 1975 -
            to 28,473 ibs/hr.
d.  Type and quantity of fuel consumed

    Oil -    i.  Heating value (BTU's/gal) - 140,000
            ii.  Percent sulfur (by weight) - 0.35
           iii.  Percent ash (by weight) - 0.0001
            iv.  Specific gravity (API) - 32.0
             v.  Consumption (gals or bbls/yr) -
                   Variable depending on natural gas
                   curtailments.  (2,572,870 gals,  for
                                   1975)

    Gas -    i.  Type of gas (constituents in percent by
                 weight)

                 Helium           -   0.03
                 Carbon Dioxide   -   0.19
                 Nitrogen         -   2.39
                 Oxygen           -   0.00
                 Menthane         -  88.35
                 Ethane           -   7.23
                 Propane          -   1.52
                 Iso-Butane       -   0.09
                 N- Butane         -   0.18
                 Iso-Pentane      -   0.01
                 N-Pentane        -   0.01
                 Hexanes          -   0.00

            ii.  Density (Ibs/SCF)  -   .047
           iii.  Heating value (BTU's/SCF) - 1,050
            iv.  Percent sulfur -
                   (a)  by volume - NIL
                   (b)  grains/SCF - 0.0005
             v.  Consumption (SCF/yr) - For 1975 -
                   2,891,220 MCF

    Coal - NOT APPLICABLE
e.  0a»er composition,  including  a.  typical  percent  and
    range of percentages  for  each chemical  constituent
             Oz/Ton
            Au    Ag
    High    0.050  4.78

    Low    0.002  2.09

Pb
0.3
0.1

Cu
32.
21.
P

0,
6
e
Si 02
10.5
3.3
r
Fe
29.
20.
c
i
3
6
e
CaO
0.9
0.2
n

Zn
1.
0.
a
3
t

s
37
28
.8
.3

A12O3
3.1
1.0

-------
    f.   Flux composition,  including a typical percent and
        range of percentages for each chemical constituent

                 Oz/Ton     	P  e   r   c  e   n
Au
High
Low
0
0
.005
.004
fig
0.
0.
42
33
Cu
0.
0.
20
12
Si 02
78.7
76.3
Fe
3.7
2.3
CaO
2.0
0.7
S
1.5
0.3
A12O3
7.6
4.1
    g.   Standard conditions - pressure (psi) and temperature
        (°F) - used to calculate SCFM

        Pressure          -    14.7 psi
        Temperature       -    70°F


2.  Concentrators

    NOT APPLICABLE.


3.  Roasters

    a.   Design process feed rate (Ibs. concentrate/hr)

        167,000 Ibs. concentrates/hr.
    b.  Actual process feed rate (Ibs. concentrate/hr),
        including method and estimated accuracy of
        measurement

        Variable
        1975 - 129,817 to 88,957 Ibs/hr.
    c.  Design process gas volumes (SCFM)

        Not available.
    d.  Actual process gas volumes (SCFiM), including method
        of determination, calculation, or measurement*

    e.  Actual process temperature (°F) *

        Measurements taken with 45°pitot tubes.
       * SEE ATTACHED.

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R.3;
. and e.
Roaster
1
2
3
4
5
6
7
8
9
10
11
12
12
ACFM
to 27
SCFM
DATA SHEET No. 1
IIAYDEN ROASTERS
Measurements taken
% H20 determined by
(d)
Date ACFM (wet)
10/1/70 13,000
10/1/70 15,970
10/1/70 12,300
10/1/70 13,560
10/1/70 12,200
10/1/70
10/1/70 11,750
10/1/70
10/1/70
10/1/70 11,780
10/1/70 38,000
10/1/70 22,700
10/17/73- 22,400
10/19/73
with 45°
dry /wet
Oe)
Temp. °F
400
400
400
270
400
—
400
—
—
400
400
350
460
pitot tubes
bulb method.
SCFM (wet)
7,420,
9,120
7,020
9,120
6,970
—
6,710
—
—
6,730
21,700
13,760
12,100
volumes based on air density of ,0807n/Ft3, then
.7" Hg and measured temperature.
is 70°Fr 29.9" Ilg calculated by:
530
27.7

% H20












13.8
corrected

Temp. +460  x  29.9

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    f.   Average  number of  hours  of  operation  per month

        730  hrs/month


    g.   Process  instrumentation  used,  including data for  a
        typical  reading and range of readings

        The  only instrumentation used are timers on each  of
        the  roaster feed belts.   They measure the time that
        feed is  being  provided the  roaster.
    ji.   Description of where and how samples of process
        material  can be collected

        Process material samples may be taken at the feed
        bins,  feed hoppers,  from any of the roaster hearths
        or from the Larry cars that transport the calcine
        to the furnace.
    i.   Description of typical types of process fluctuations
        and/or malfunctions,  including frequency of occurrence
        and anticipated emission results

        Process fluctuations  include curtailment of smelting
        operations as ordered by the Joint Control Center
        which would cause the stopping of a roaster.

        Malfunctions include  breaking of shear pins on the
        drive, loss of rabble blades and plows, broken arms,
        brick falling out of  hearths, loss of feed on belts,
        belts burning, and loss of draft.


    j.   Expected life of process equipment (years)

        20 Years


    k.   Plans to modify or expand process production rate

        None.


4.  Reverberatory furnaces
    a.  Design process feed rate (Ibs. calcine/hr +
        Ibs. converter slag/hr)

        204,000 Ibs. calcine/hr + 90,000 Ibs. converter
        slag/hr.

-------
        b.   Actual process fcy.-d rate  (Ibs.  calclne/hr +
             Ibs. converter' sl;'g/hr),  including method and
             estimated  accuracy of measurement

             Variable
             1975:  123,326-84,509 Ibs.  calcine/hr.
                     47,153-28,022 Ibs.  converter slag/hr.


        c.   Design process gas volumes  (SCFM)

             No.  2 furnace   -  333,000 SCFM
             No.  4 furnace   -  177,000 SCFM
        d.   Actual process gas volumes  (SCFM), including method
             of determination, calculation, or measurement

             SEE ATTACHMENT.
        e.   Actual process temperature  (°F)

             SEE ATTACHMENT.


        f.   Average number of hours  of  operation per month

             730 hours/month.
        g.   Process instrumentation  used,  including data for a
             typical reading and range  of readings
        Type

    Integrators
         n
         n
         •i
Chart Recorders
    Measurement

Fuel:  Oil
      Gas
Combustion Air
Atomizing Air
Furnace Draft
Combustion Air Temp.
Arch Temp.
Air/Fuel Ratio
Oil Flow
Gas flow
Atomizing Air Flow
Combustion Air Flow
Exit Gas Temp.
Preheater Gas Flow
     Typical

     Variable
     Variable
     Variable
     Variable
     .005-, 01
      900°F
     2S50°F
      0.55
26,000 gal./day/fee
150,000 MCF/day/fce

     900 MCF/hr
      80°F
    20-35 MCF/hr
     Rant
0-52,000 gals/day
0-375,000 MCF/day
280-1,860 MCF/hr

    0± 0.15
    0-1200°F
 2400-2750°F
      0-1
                                                        280-1,860 MCF/hr
                                                            0-120°F

-------
•B.4.
•d. and e,
i
DATA SHEET No. 2
IIAYDEN
REVERES

Measurements taken with a 45° pi tot tube
in the spray chamber bypass flue.
Date
9/13/68
9/13/63
11/27/68
11/26/68
Reverb
No. ACFM
2 98,500
4 98,600
2 123,500
4 71,000
(d)
SCFM (v;et)-
42,100
45,200
62,500
40,500
(e)
Temp.
op
690
610
510
400
Static
Press
In H20
5.2
5.3
5.8
—
Rev.
Firing rate
CFH Hat. Gas
139,000
111,000
121,000
75,000
ACFM volumes based on gas density of .0807#/Ft3, then corrected
to 27.7" Hg and operating temperature.
SCFM calculated from ACFM by multiplying:
                    ACFM x
                                530
          27.7
                            Temp
.  + 460 X 29.9

-------
    h.   Description  of  whore and how samples of  process
        material can be collected

        .Process samples may be obtained of slag  from the
        slag launder as the furnace is  being skimmed and
        matte from the  matte launder as the furnace is
        being tapped.

    i.   Description  of  typical types of process  fluctuations
        and/or malfunctions, including  frequency of occur-
        rence and anticipated emission  results

        Process fluctuations include dropping of calcine
        charges which require a cut in  firing rate and
        skimming of  furnace which does  not allow charge  to
        be dropped.

        Malfunctions include loss of'fuel, combustion air,
        process control (draft, drop firing rate,  combus-
        tion air/fuel ratio), or electrical power.
    j.   Expected life of process equipment (years)

        20 Years.


    k.   Plans to modify or expand process production rate

        None.


5.  Converters
    a.   Design process feed rate (Ibs.  matte/hr + Ibs.
        slag/hr + Ibs. flux/hr + precipitates Ibs/hr)

        127,200 Ibs. matte/hr
            250 Ibs. anode slag/hr

         31,400 Ibs. flux/hr
          3,400 Ibs. precipitates/hr.


    b.   Actual process feed rate (Ibs.  matte/hr + Ibs
        slag/hr + Ibs. flux/hr), including method and
      .  estimated accuracy of measurement

        1975:  74,020 - 58,660 Ibs. matte/hr.
               250 Ibs. anode slag/hr.  (est.)

               15,250 - 10,000 Ibs. flux/hr.


        Variable

-------
c.  Design process gas volumes  (SCFM)

    40,000 SCFM.
d.  Actual process gas volumes  (SCFM),  including
    method of determination, calculation, or
    measurement

    SEE ATTACHMENT.
e.  Actual process temperature  (°F)

    SEE ATTACHMENT.


f.  Average number of hours of  operation per month

    730 hrs/month.
g.  Process instrumentation used,  including  data  for  a
    typical reading and range of  readings  *

    Blast Air Flow:  The pressure drop  is  taken across
       a calibrated orifice plate located  in the  blast
       air line.  This pressure drop  is sensed by a
       differential pressure transmitter which sends
       a signal to a 3-15 psi receiver  gage  which is
       calibrated to print out on a chart  reading
       0-35,000 SCFM.  This chart is  located in the
       converter office.

    Blast Air Pressure:  The blast air  pressure is
       measured through a port in the blast  air line
       by a bellows-type pressure sensing  transmitter
       which sends a signal to a  3-15 psi  receiver
       gage in the converter office which  is calibra-
       ted to print out on a chart reading 0-20 psi.
h.  Description of where  and how  samples  of  process
    material can be collected

    Samples of slag and copper  are  taken  through  the
    mouth of the converter with the converter  out of
    the stack.  The samples are taken with a small
    spoon or on an iron bar.
*Volumetric and pressure instrumentation on blast air.
                      10

-------
B.5.
d. and e.
_ <
i
i »
yilS) j^ -tot
*\.Bv£i DATA SIIEET NO< 3
^ ^ IIAYDEU CONVERTERS


it'
•y r Volumes taken with 45° pitot tube
in the high velocity flues.

-------
    i.   Description of typical types of process fluctuations
        and/or malfunctions,  including frequency of occurrence
        and anticipated emission results

        Cyclone damper malfunction (once every 3 months)
        results in no draft on the converter.   Converter
        hood door failure (once/month) diminishes the draft
        on the converter.  These two items are repaired as
        they occur.
    j.   Expected life of process equipment (years)

        20 Years.


    k.   Plans to modify or expand process production rate

        None.


6.  Refining Furnaces


    a.   Design process feed rate (Ibs. blister copper/hr)

        39,000 Ibs. blister copper/hr.
    b.  Actual process feed rate (Ibs. blister copper/hr),
        including method and estimated accuracy of measure-
        ment

        Variable
        1975:  28,473 - 20,005 Ibs. blister copper/hr.
    c.  Design process gas volumes (SCFM)

        Unknown.
    d.  Actual process gas volumes (SCFM), including method
        of determination, calculation, or measurement

        Unknown.
    e.  Actual process temperature (°F)

        2200 - 2100°F.
    f.  Average number of hours of operation per month

        730 hrs/month.
                           11

-------
    Process instrumentation used, including data for
    a typical reading and range of readings

    Leeds & Northrup Temp-Tip Recorder
    Speedomax W  -  Type S
    Range - 2000 - 2200°F
    Typical - 2150°F
h.  Description of where and how samples of process
    material can be collected

    Furnace mouth or pouring spout with hand ladle.


i.  Description of typical types of process fluctuations
    and/or malfunctions, including frequency of occurrence
    and anticipated emission results

    Low temp blister @ 1/wk.
    Additional firing time - no emissions.
j.  Expected life of process equipment (years)

    20 Years.


k.  Plans to modify or expand process production rate

    None.
                       12

-------
C.  EMISSIONS
    1.   List  of sources  of  particulate  emissions in the  plant
         (including fugitive emissions)

         Roasters
         Reverberatory Furnaces
         Converters
    2.   Level of uncontrolled particulate  emissions by  source
         (Ibs/hr or T/yr)

         NONE
    3.   Existing source  test data employed for particulates by
         stack,  process unit, or control  device, including:
         (a)  Test method;  (b) Data acquired;  (c) Operating
         process weight rate; (d) Calculations; (e) Test  results,


                    Hayden  Absorbing Tower

              Samples taken above mist eliminator.
              Sample train:  Two Buchner medium  porosity
              •funnels heated to approximately  240°pt two
              80% isopropyl alcohol wash bottles, Dryrite,
              gas meter, and accessories.
Run
No.
1
2
3
4
5
Run
No.
1
2
3
4
5
Date
3/3/75
3/4/75
3/4/75
3/5/75
3/5/75
S03
As SO3
3.29 x 10~7
10.2 x 10~7
5.51 x 10-7
5.51 x 10~7
4.74 x 10~7
Vol. Outlet*
SCFM
68,220
59,930
66,060
52,800
70,650
0/SCF
As H2SO4
4.03 x 10-7 g.
12.5 x 10~7 5.
6.75 x 10~7 8.
6.75 x 10~7 7.
5.81 x 10~7 6-
No. of % SO<2
Converters Feed
1.3
1.2
1.2
1.4
1.6
H2SO4
ti/SCF
63 x 10~6
66 x 10-6
01 x 10~6
71 x 10~6
16 x 10"6
3.5 .
5.2
3.8
3.8
5.5
Total H2SO4
8/SCF
10.0 x 10-6
6.91x '10~6
8.69x 10-6
8.33x 10~6
6.74 x 10~6
        *Volume determined from acid plant blower recording and adjusted
         for the conversion of SO2 and 02 to acid and its removal  in the
         absorbing tower.
                                   13

-------
                HAYDEN COTTRELL OUTLET

    Samples were taken in the flue with medium porosity alundum
    thimbles.  Three impingers preceded the gas meter, first  '
    H20, second blank, third Dryrite.  Samples were taken on
    outlet of hot cottrell.
Date
9/21/74
9/21/74
9/21/74

Cottrell
Temo. °F
370
350
355
HAYDEN
H20
4.8
6.6
7.6
R&R SAMPLE
Grain
ti/SCF Dry
0.
0.
0.
STATION
Loading
(32°F &
043
045
033

SL)



I//)
             Modified Method 5 - 20% H202  substitu
             for water in  first two im'pingers.  Other
             Methods 1 and 2 were followed.
Run
NO.
1
2
3
Run
No.
1
2
3


Run
No.
1
2
3
% % Vol. Based on Dry Gas
Date H2O
11/3/75 11.
11/4/75 10.
11/4/75 11.
Volume
SCFM Dm
276,173
279,666
303,349


P A R T I C
fi/SCF Dry
4.66 x 10~6
6.66 x 10-6
6.70 x 10~6
CO2
9 3.8
2 2.7
6 2.7
Volume
ACFM
444,636
441,414
483,085


U L A T E
Gr/SCF 8/Hr
0.0325 77.
0.0465 111.
0.0468 122.
O2 N2+CO
16.3 79.9
16.2 81.7
16.2 81.7
Flue S
Cott.
In
270
282
300
5 Total
Temp. °F Roasters
241
243
235


S02
ff/SCF
2 13.35 x 10~4
8 14.78 x 10~4
0 15.36 x 10~4
93.5
86.9
80.5



ff/Hr.
22,138
24,800
27,957
Temp. F
Out
255
258
275
Capacity
Reverbs
64.0
97.2
76.9
Acid
Content
Cot.
Dust %
2.6
2.4
2.4
4,  Particulate size and  chemical composition of uncontrolled
    particulate emissions,  including method of determination

    Not  applicable
                            14

-------
5.   Level of uncontrolled visible emissions by source
    (percent opacity) and method of determination

    Unknown
6.   Extent of and reason for variance of particulate
    omissions with:

    a.  Process design parameters

        Wrong design or malfunction of equipment.


    b.  Process operating parameters

        Temperature control, process,gas conditioning
        and power input.


    c.  Raw material composition or type

        Depends on quantity of volatile metals present,
        particle size and moisture content.


    d.  Product specifications or composition

        No effect, as product is uniform.


    e.  Production rate

        Production rate increases will increase particulate
        emissions.


    f.  Season or climate

        Humidity.


    g.  Sulfur dioxide  control

        Controls not operating or malfunctioning will
        increase particulate emissions.

-------
'D.   CONTROL SYSTEMS
     1.  Detailed description of  the particulate  and  sulfur
        dioxide emissions control  systems,  including:

        a.  Process treated

            Roaster and reverberatory  furnace process gases  are
            treated for particulate control with electrostatic
            precipitators.  Converter  process gases  are  treated
            for particulate control with electrostatic preci-
            pitators  and scrubbers.

            Roaster and reverberatory  furnace process gases  are
            not treated for sulfur dioxide  control.  Converter
            process gases are treated  for sulfur dioxide control
            by a single absorption contact  acid  plant.
        b.  Type of  fuel consumed per unit

            The electrostatic precipitators  do  not  consume  fuel.
            Instead,  large quantities of electrical power are
            required amounting  to an average of  105,000  KWH per
            month  for the R.& R. Cottrell and 390,000 KWH per
            month  for the Converter Cottrell.   The  acid  plant
            uses a natural gas  fired preheater  for  heating
            plant  up to process  temperature  and  to  hold  process
            temperature during  periods of low gas grades, i.e.,
            less than 4.0% S02-
            Quantity of fuel  consumed per unit

            The acid plant has  consumed  natural gas on  a monthly
            average of 1,471  MCF  in  1972; 3,911 MCF in  1973;
            6,625 MCF in  1974;  and 6,732 MCF  in the first  11
            months of 1975.   In addition to fuel,  the acid plant
            consumed 32,585,903 KWH  in 1972;  26,844,246 KWH in
            1973; 25,593,689  KWH  in  1974; and 21,964,066 KWH  in
            the first 11  months of 1975.  This is  an average  of
            47.6% of the  total  Hayden Plant electrical  power
            requirements.
         d.  Method of determination of design parameters

            SEE ATTACHED.


         e.  Engineering drawings or block  flow diagrams

            SEE ATTACHED PROCESS FLOW SHEETS C, D, E-l and H
                                 16

-------
D. i.d.
                                               DATA SHEET  No.  9
        IIAYDEN  -  DESIGN  PARAMETERS OF ASARCO COTTRELLS
 D.   Control  Systems
     d.  jMethod  of  determination  of  design  parameters

        I  am  not familiar  with  the  method  Chemibau used  in
 selecting the  size of  the acid  plant  hot  gas  filter,  so I will
 limit my  explanation on "method of determination  of  design
 parameters"  to our own cottrells.

        The formula we  used for  developing the curve  of  Fig.  1
 was  based on the  formula
                     n   OC  1  -
 This is  valuable in predicting what the  dust recoveries would
 be in an existing cottrell if all  other  factors  are  kept con-
 stant, but the time in the electrical  field is varied.

       As an example of the application  of this  formula, I
 have selected a cottrell operating at  90%  efficiency and three
 seconds  retention time in the electrical field.   This is shown
 on Fig.  1 where at 90% efficiency  the  curve intersects  the 98th
 line of  the graph.  This is equal  to 32.67 line  per  second.

        If \7e wish to increase the  efficiency of  this cottrell
 to 98% at the same volume, then the curve  intersects the 98%
 efficiency on line 166 from the origin of  the curve.  This
 would indicate that a retention time of 5.08 seconds is neces-
 sary to  achieve 98% efficiency.  This  increase in efficiency
 is equal to an increase of cottrell capacity of  some 69.3%
 over the original installation.  We use the same method for
 determining cottrell size and efficiency whether we  are en-
 larging  an existing cottrell or building a new cottrell for a
 similar  gas stream.

-------

-------
                                   i> . isu.
        20 Years


    g.  Plans to upgrade existing system

        NONE


2.  Electrostatic precipitators -  Reverb  and  Roaster

    a.  Manufacturer, type, model number

        ASARCO design

    b.  Manufacturer's guarantees, if any

        NONE
    c.  Date of installation or -last modification and a
        detailed description of the nature and extent of
        the modification

        Pla'tes and wires were repaired or replaced on all
        units.  Work was completed February 14, 1975.

        All existing transformers and automatic controls
        were replaced with larger units to achieve approx-
        imately double the previous power input.

        Work on this phase for increasing the precipitator
        efficiency was completed by November 15, 1974.
    d.  Description of cleaning and maintenance practices,
        including frequency and method

        Each bank is automatically isolated each hour by
        means of inlet and outlet dampers, the power cut
        off, and air vibrators clean both the hot and
        cold frames.  After a null period, the dampers are
        opened and the cleaning cycle proceeds to the next
        bank.

        Normal maintenance includes replacing broken elec-
        trodes and cleaning insulator boxes with air.  Fresh
        hydrated lime is added to react with free acid on
        insulator blocks supporting the hot frame.
    e.  Design and actual values for the following variables
                           17

-------
           i.  Current  (amperes)
          ii.  Voltage
         iii.  Rapping  frequency  (tdmes/hr)
          iv.  Number of banks
           v.  Number of stages
          vi.  Particulate resistivity
                 (ohm-centimeters)           Unknown
         vii.  Quantity of ammonia injected
                 (Ibs/hr)                    None
        viii.  Water injection flow rate
                 (gals/min)
          ix.  Gas flow rate (ltOOO SCFM)
           x.  Operating temperature  (°F)
          xi.  Inlet particulate  concentration
                 (lbs/100,000 SCFM)
         xii.  Outlet particulate concentration
                 (grains/SCFM)
        xiii.  Pressure drop (inches of water)
Design
1




,000
35
1
8
4
Actual
820-850
31-33
1
8
4
   Unknown

   None

 Approx. 75
   275-300
   250-275

   35-40

0.0325-0.0468
  0.06-0.15
2.  Electrostatic precipitators - Converter
    a.   Manufacturer,  type,  model number
         Chemiebau

    b.   Manufacturer's guarantees,  if  any
         97% (indicated only)
         Date of installation or last  modification  and a
         detailed description of the nature and extent
         of the modification.
         Limited operation of the precipitator was  started
         on October  16,  1970, with one converter.   Since
         this date there have been no  major repairs on the
         unit.
    d.   Description  of  cleaning and  maintenance practices,
         including  frequency and method
         Cleaning is  effected by drop hammers fixed to a
         rotating shaft  which strike  each row of plates and
         electrodes.   Cleaning frequency and operating time
         is adjustable and is accomplished during  operation
         with no interruption in gas  flow.

-------
    e.   Design and  actual values  for the followj
                                            Design
           i.   Current (amperes) (MA DC)      Unknown
          ii.   Voltage (Volts AC)             Unknown
         iii.   Rapping frequency (times/hr)   Variable
          iv.   Number of banks                   4
           v.   Number of stages                  3
          vi.   Particulate Resistivity        Not Known
         vii.   Quantity of ammonia injected     None
         viii.   Water injection flow rate  (gpm)   None
          ix.   Gas flow rate  (SCFM)           200,000
           x.   Operating temperature  (°F)     650-700
          xi.   Inlet particulate concentra-
                tion                       Unknown
         xii.   Outlet particulate concentra-
                tion  (grains/'SCFM)          Unknown
         xii'i.   Pressure drop  (inches of water) Unknown
ng variables:
     Actual
    120-500
    370-390
   Variable
       4
       3
   Not Known
      None
     10-60
 40,000-100,000
   200-700
    Unknown

   .033-.045
      0-3
3.  Fabric filters
    Not  applicable.

4.  Scrubbers
    a.   Manufacturer,  type, model number
         Manufactured by Rust  Engineering  Company; process
         designed by  Chemiebau.

    b.   Manufacturer's guarantees, if any
         None.
    c.   Date of  installation  of last modification  and a
         detailed description  of the nature and extent of
         the modification.
         The Plant was shut down on January 11, 1975  for
         replacement  of the tops of gas cooling towers and
         to tie in the APV heat  exchangers.   At this  time
         modification to the settling tanks and tie-in were
         made.  Work  was completed on February 21,  1975.

-------
    d.  Description of cleaning  and maintenance practices,
        including frequency  and  method
        The cleaning and maintenance practices are done on
        a continuous basis.   The scrubbing  system is con-
        tinually  blown down  to rid the system  of solids.
        The solids are settled out in tanks and later
        shipped with the cottrell dust.
    e.  Scrubbing media
        Water.
    f.  Design  and actual values for the  following variables
          i.  Scrubbing media  flow rate  (GPM)
                50% Scrubber
                North Scrubber
                South Scrubber
                Cooling Towers
         ii.
        Hi.
         iv.
          v.

         vi.
                                            Design
                               723
                               309
                               309
                             1,739
Pressure of scrubbing media (THD)   95'
Gas flow rate (SCFM)
Operating temperature (°F)
Inlet particulate concentration
   (ti/SCF)
Outlet particulate concentra-
  tion (it/SCF)
        vii.  Pressure drop (inches of water)
0-110f000
 600-700

 Unknown

 Unknown
 Unknown
                                           Actual
    1,100
     640
     640
Not Available
  Variable
  0-110,000
   200-650

    .040

   Unknown
     7
5.  Sulfuric acid plants
    a.  Manufacturer, type,  model number
        Manufactured and  engineered by  Rust Engineering
        Company;  designed by Chemiebau.   Single absorption
        contact plant.

    b.  Manufacturer's  guarantees, if any
         Process Guarantees
         750 tons per  100% monohyclrate  as 93.5%
         per twenty-four  hours.
                            20

-------
    Conversion efficiency SC>2 to S03 of 95.5%

    Absorption of SOa to form sulfuric acid - 99.

    Maximum 803 content in stack gases:  0.0042
                                         gr/cu. ft.

    Drying of process gases:              0.0028
                                         gr/cu. ft.

    These guarantees are based on supply by Asarco of
    a minimum of 98,000 SCFM  average hourly grade of
    4.12% S02 gas.
    SEE ATTACHMENT - Letter dated December 15, 1971,
       HAYDEN ACID PLANT PROCESS GUARANTEE TESTS.
c.   Date of installation or last modification and a
    detailed description of the nature and extent of
    the modification

    Originally installed November 1971.  Modification
    presently underway - January thru March, 1976.
d.  Description of cleaning and maintenance practices,
    including frequency and method

    Done as required.
e.  Frequency of catalyst screening

    Catalyst screening is required annually.


f.  Type of demister

    York Type S - Teflon.
g.  Design and actual values for the following
    variables:

-------
                                               Salt Lake City,  Utah
                                               December 15,  1971
 ,r. E.  H.  Haug
 alt Lake  City Office
                          IIAYDEN ACID PLANT
                       PROCESS GUARANTEE TESTS
          During the period from November 2  through December 8, 1971
 csts were made at the Hayden acid plant to  determine if the plant
met the following process guarantees:

          1.   Conversion efficiency of S02 to 803 of 95.5%.
          2.   99.91 absorption of 803  to form sulfuric acid.
          3.   Maximum 803 content in stack gases of 0.0042 grams/cu.ft.
          4.   Moisture content of dried gases of 0.0028 grams/cu.ft.

1.        The conversion efficiency was calculated from data obtained
 iy makinq simultaneous determinations  of SO2 in the feed gas and in
 he stack gas.  The acid plant S02 recorder was used to determine the
S02 in the feed gas during the test period.   S02 was determined in the
':ail gas with the Reich method using 0.01 normal iodine solution.

          Eight conversion efficiency tests were made and are tabulated
rn the following table.

                                  1.
                       CONVERSION EFFICIENCY
          GUARANTEE: 95.55 CONVERSION WITH 4.125, FEED GAS
)ATE
11/8/71
1 1/8/71
1/8/71
,.1/22/71
11/22/71
.1/30/71
.,2/2/71
12/3/71
VOLUME
(SCFM)
57,500
84,500
84,800
98,300
98,300
87,000
77,900
88,900
% S02 FEED
GAS
5.2
4.6
4.5
7.5
4.625
6.42
6.44
5.12
% S02 TAIL
GAS
0.0965
0.119
0.162
0.320
0.325
0.257
0.180
0.276
% CONVERSION
98.3
97.7
96.7
96.2
93.4*
96.4
97.5
95. C**
         *There is reason to believe that the feed gas analysis  for
this test is wrong, thus giving the low conversion efficiency, because
 luring this test work was being done at the SO2 recorder.

         **Aftcr this test v/ater was found in the sample  line  left,  from
i previous test, so these results could have been affected.

          The chart on the next page shows the plot of the points  obtained
when the percent conversion is plotted against the SO2 content of  the feed
 jas.  The   solid  line  is the variation expected by Chemiebau with  a
 variation in grade of feed gas.  Only the two tests that arc  suspect gave
conversions lower than expected, and the conversion efficiency meets the
 guarantee.

-------
Mr. H. II. Hauq
"nyden Acid Plant
December 15, 1971
•>.        The absorption efficiency was calculated from data obtained
 ncn tests were made to determine the 803 content of the stack gas.
_.i making the determination for 503 in the stack gas, the SO3 as such
is determined separately from the II2SO/J mint.  For the SOo content of
 tack gas, both components are considered; however, for calculating the
 asorption efficiency only the 803 component is considered.  In making
this calculation, it is assumed that 96% of the SC>2 entering is con-
 arted to S03.

          The following table shows the absorption efficiency for the
 ive tests that were made.

                                   2.
                    ABSORPTION OF £03 TO FORM H2SO4
                      GUARANTEE: 99.9?, ABSORPTION

ATE
11/2/71
1/10/71
1/11/71
11/21/71
2/2/71
% S02 IN
FEED GAS
5.0
6.0
5.0
5.4
5.37
VOLUME FEED
GAS (SCFM)
65,500
79,400
79,400
90,700
90,000

% ABSORPTION
99.98
99.97
99.96
99.97
99.99
The absorption efficiency is veil above the guarantee.

          The stack gases were sampled at the top of the absorbing
^ov;er above the two spray catchers to determine the 803 contained in
them.  The arrangement of the sampling equipment with a heated  filter
 s such that the two SO^ bearing components, namely the H2S04 mist  and
 03 as such, are determined separately, then the total 803 content  of
the stack gas calculated.  The H2S04 mist was captured in the probe and  the
 eated filter, and the S03 was captured in  805 Isopropyl alcohol.   Each  of
 he components v/as collected separately and boiled to remove SO2, and the
803 sample v/as boiled until, all the alcohol was driven off.  The samples
 ere then titrated with a standard solution of caustic.  The following
 able shows the results of five tests to determine the 803 in the stack
gases.

                                   3.
                       803 CONTENT IN STACK GAS
               GUARANTEE: LESS THAN 0.0042  GRAMS/CU. FT.
SO2 IN
ATE FEED GAS
11/2/71
'1/10/71
1/11/71
11/21/71
•V2/2/71
5.0
6.0
5.0
5.4
5.37
VOLUME FEED
GAS (SCFM)
65,500
79,400
79,400
90,700
90,000
H2SO/i MIST
IN STACK GAS.
GRAMS/SCF
0.000615
0.00104
0.00117
0.00122.
0.000398
S03 IN TOTAL 803 IN
STACK GAS STACK GAS
GRAMS/SCF GRAMS/SCF
0.000583
0.00189
0.00191
0.00145
0.000532
O.OC108
0.00273
0.00236
0.00245
0.000857
 i'hese  tests  all meet  the  guarantee.

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                                 - 4 -
Mr.' E. H. iiaug
Ilayden Acid Plant
                        December 15, 1971
4.        To determine moisture content of the dried gas, a sample of
qas was drawn through a moisture collector.  For thc.sc tcr.ts, cither
P205 or Anhydronc was u.c;od, and the gain in weight dcterminod by woiqh-
inq the collector before and after each test.  This was found to be a
very difficult test to make, mainly because of weighing difficulties.
The difficulty in weighing came about because the equipment necessary
to hold the rcaqent through which the gas sample is drawn is relatively
large compared to the change in weight nroduced with the collected
rr.oisture.  Also, it was found that the balance at the acid plant gave
erratic readings because the table on which it was mounted was subject
to vibrations and could be thrown out of level with the slightest shift
of weight on the table.  After the conclusion was reached that it was
necessary to lengthen the sampling time and that weighing should be done
in the plant's laboratory, good results were obtained.

          The following table shows the results obtained from eleven
tests.  Some of the results are above the guarantee, but when the test
period was extended to periods lasting overnight, the results were con-
sistently well below the guarantee.

                                   4.
                    MOISTURE CONTENT OF DRIED GAS
               GUARANTEE: LESS THAN 0.0028 GRAMS/CU. FT.
            DATE
VOLUME OF GAS
SAMPLED (SCF)
MOISTURE CONTENT
   GRAMS/SCF
11/4/71
11/5/71
11/7/71
11/8/71
11/20/71
12/2/71
12/3/71
12/5/71
12/6/71
12/7/71
12/8/71
9.95
18.40
6.09
"12.95
7.95
17.65
14.78
10.17
40.6
64.3
48.4
0.0032
0.0025
0.0021
0.00265
0.0038
Negative
0.00288
0.000585*
0.000555 - 0.000585*
0.000601
0.000430
         *These results are calculated using weights from those bulbs
in the train which show a gain in weight.

5.        A number of attempts were made to check the SO2 recorder
using the Reich method for analyzing the gas for S02-  At first the
•results were unsatisfactory because there were wide variations recorded
>n the chart from minute to minute, and it v/as difficult to pinpoint the
recorded value -that should correspond to the value determined iodo-
metrically.

          To avoid this problem, a large quantity of 0.IN 12 solution
was used so that the time required to make the Reich determination v/as
jxtended to a period which varied from 15 minutes to 40 minutes and

-------
•Mr. -E. H. Hauci
 ayden Acid Plant
                             December 15,  1971
 uring this period the S02 analyzer-recorder was read every thirty
 econds.  The readings taken during the exact corresponding time period
were then averaged for comparison with the results of the Reich deter-
"ination.

          The tabulation below shows the results of seven such tests.
proin the averages it was determined that the S02 analyzer-recorder
 as reading high and that a correction of -0.2 should be applied to
 _he chart reading to get the S02 content of the feed gas.

                                  5.
                CALIBRATION OF SO2 ANALYZER-RECORDER
             DATE
      ANALYZER
      READING
     REICH
DETERMINATION
             11/25/71
             11/25/71
             11/28/71
             11/30/71
             11/30/71
             11/30/71
             11/30/71
         4.20
         4.51
         6.24
         6.62
         6.27
         6.34
         5.24

        39.42
Average  5.63
      3.71
      4.43
      6.38
      6.82
      5.84
      6.07
      5.00

     38.25
      5.46
             Correction to  be  applied  to  recorder  reading -0.2.

           Early in the start-up period the  question  arose whether the
  low meter reading gas flow to the acid  plant  blowers  was recording
.the flow as standard CFM.   A  number of volume  determinations  were made
 ".sing a Dwyer standard pitot  tube plus two  determinations with  an
  SARCO 45? tube,  and each  was compared with the  flow meter reading.

           The location in  the duct where the measurements wore  made
  •as a good one, being long and straight; however, this location was
  igh up in the air, and with  the platform arrangement, measurements
 could be made along only one  diameter.  Also,  the duct was six  feet in
  liameter, and the pitot tube  was only five  feet  long so an allowance
  iad to be made for being able to reach only part way across the duct.

           These less than  ideal conditions  probably  contributed to the
  •eadings being erratic as  shown in the tabulation; however, except for
 chose tests made on November  9 and November 30 where the instrument
 'lid agree fairly closely with the measurements in SCFM, the readings
  iveraged 812 of the flow meter reading.   It is the feeling that this
 _s the factor by which the chart was  reading wrong.

           With the plant operating at rated volume,  98,000 SCFM, the
  :low meter would then read approximately 120,000 which is very near
 the upper end of the range of the chart.  It is  desirable to have the

-------
       H. Haug
       Acid Plant
                            December 15, 1971
flow meter read more nearly the SCFM actually flov;inq, so the fluid
  \ this flow meter is to be changed to a more dense fluid in order
  > achieve thin.  The instrument supplier recommended ethylcnc glycol,
After the fluid is changed, the flow meter should be recalibrated so
 "iat the factor for the meter reading will be known.
               FLOW METER COMPARED TO PITOT MEASUREMENTS
                       FLOW METER
                        READING
                   PITOT TUBE
              MEASUREMENT (SCFM)
                 % OF
               MTR. RDG,
11/10/71
 L/10/71
 L/22/71
11/23/71
 L/29/71
 L/29/71
11/29/71
"1/29/71
 L/30/71
j.1/30/71
U/30/71
 L/30/71
.2/1/71
12/3/71
 V3/71
 V3/71
12/5/71
 2/5/71
 2/7/71
12/7/71
 44,000
109,000
104,000
118,000
 90,000
 87,500
 51,000
 90,000
100,000
104,000
106,100
113,500
114,360
 60,500
101,500
101,500
102,900
111', 870
115,000
 99,000
108,500
 '45,700
 89,500
 84,700
 90,100
 84,600
 63,200
 40,600
 74,400
 82,000
 94,600
103,500
110,500
114,700
 53,200
 79,800*
 81,300
 84,000
 87,700
 91,300
 82,800
 87,800
100.4
 82.2
 81.0
 76.3
 94.0
 72.2
 79.6
 82.6
 82.0
 91.0
 97.5
 97.4
100.1
 88.0
 78.6
 80
 81
 78
 79
 83
 79.3
  Made with 45° pitot tube immediately prior to following test.

          The results of these acceptance tests bear out that  the plant
  > conservative in design.
~ ids. -Worksheets
 3C:bm
cc: K.D.Loucyhridge
    L.C.Travis
    A.J.Kroha
    M.J.Winkel
    W.T.Sweat
    T.Jordan
                                                C. R. COUNTS
W.R.Mahoney
J.J.Donoso^ w/encls.
E.S.Godsey

-------
©
                                    ©
O
            O
                     /A'
                                                             \\c 7/fat-
                                                       dJOi Ticrsa L.
                                               7.0

-------
                                                  Design      Actual
            i.  Production (T/operating day)        750         492
           ii.  Conversion rate (percent)            95.5        97.2
          Hi.  Acid strength (percent l^SOq)      93-98       93-98
           iv.  Number of catalyst beds             3           3
            v.  Gas flow rate (SCFM)              0-98,000    0-110,000
           vi.  Operating temperature (°F)          850         850
          vii.  Inlet S02 concentration (ppm)      41,200      51,600
         viii.  Outlet SO2 concentration (ppm)     Unknown      2,700
           ix.  Acid Mist (grain/SCF)              .0042        .052
            x.  Blower pressure (inches water)       150         140
6.   Liquid SC>2  plants
     Not  applicable.
                              22

-------
E.  STACKS
    1.   Detailed description of stack configuration,  including
        process and/or control system units exhausted

        For stack configuration see Drawing 5079.   The stack
        is of reinforced concrete construction and hand]es
        waste gas products from the roaster-reverb operations
        and excess gases from the converter operations,  both
        of which have first passed thru electrostatic preci-
        pitators.
    2.   Identification by stack of:

        a.   Heights (ft.  above terrain)

            1,000 feet.


        b.   Elevation of  discharge points (ft.  above sea level)

            3,182 feet.


        c.   Inside diameters (ft. )

            Top           17'-0" I.E.
            Bottom        45'-2" I.E.


        d.   Exit gas temperatures  (°F)

            270-300°F


        e.   Exit gas velocities (ft/sec)

            38-43 fpm
                             23

-------
D.I.a.
                             BEPPIUi
                    i. CAKS
     CONCENTRATE £3 PRECIPITATES
                         I
            (T) 3 RE-rEIYIN'G  BINS
                3 BELT FEEDERS
           (5) EAST TRlPPiR. CoMVuYQIt
    zr
                           e.
    wc
-------
                     1

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-------
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                                                          [9)2I.C>
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-------
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-------
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                                     AC ID PLANT

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-------
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-------
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-------
 Hayden Plant
 Lary G. Cahill
 Manager

 Melvin A. Sharp
 General Superintendent

 Robert A. Moon
 Accounting Manager
                                   March 2,  1976
Mr. Thomas P.  Gallagher, Director
Environmental  Protection Agency
Office of Enforcement
National Field Investigations Center-Denver
Building 53, Box 25227, Denver Federal  Center
Denver, Colorado  80225

Dear Mr. Gallagher:

This letter  is to confirm the information given to Mr.
Reed Iversen,  EPA -  Durham, SC, by  phone on February 26,
1976, pertaining to  Asarco Hayden's roaster and reverbera-
tory cottrell.

The information given to Mr. Iversen was - -


(1)  Collection area  =  137,410.56 sq.  ft.

(2)  Gas velocity =  18.9 ft/sec.
(3) ' Treatment time   =  3.05 sec.
                                   Very truly yours,
LGC:cch

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            Appendix C
SIP Regulation Applicable to ASARCO

-------
             RULES AND REGULATIONS
                  Subpart D—Arizona
        §52.124   [Revoked]
          1. Section 52 124 is revoked.
          2. Section 52.12G is amended by add-
        ing paragraph (b) as follows:
        §52.126   Control  strategy  and  regula-
            tions : Inarticulate mailer.
            4       •       •       •      »
          (b)  Replacement regulation for Regu-
        lation  1-1-3 S of the Arizona Rules and
        Regulations for Air  Pollution Control.
        Rule 31 (E) of Regulation III of the Man-
        copa County Air Pollution Control Rules
        and Regulations, and Rule 2(O) of Reg-
        ulation II of the Rules  and Regulations
        of Pima  County Air Pollution Control
        District I Phoenix-Tucson Intrastate Re-
        gion) .—(1) No owner or operator of any
        stationary process source in the Phoenix-
        Tucson Intrastate Region (§ 813G of this
        chapter)  shall  discharge or cause  the
        discharge of participate matter into the
        atmosphere in excess of the hourly rate
        shown in the following table for the proc-
        ess  weight rate  identified  for such
        source:
          Process    Emission   Process    Emission
         Wright rate    rale    weight rate     rate
          (pounds    dwuncls    (pounds    (pound's
         per hour)    per hour)   per hour)   per hour)
BO 	
100 	
BOO 	
1,000 	
5,000 	
10,000 . , .
20,000 	

0 36
0 55
1.51
2.2*
634
9 73
14.09

so. ono
80,0(10
170,000
ico. cm
200.000
400.000
1,000,000

79 GO
31.19
3328
31 »
35 11
4036
4072

          (i) Interpolation of the data In the ta-
        ble for process weight rates IIP to 60.000
        Ibs/hr shall be accomplished by use of
        the equation:
                E=3 53 P*« P£ 30 lons/h
        and interpolation and extrapolation of
        the -data for process weight rates in ex-
        cess of 60.000 Ibs/hr  shall  be accom-
        plished by use of the equation :
                            P>30tons/h
  
-------
        Appendix D
Estimates of Gas Flow Rates

-------
Flowrate Estimates*

Roasters

     Given:  (1)  Nos.  1-5 same size
             (2)  Nos.  6-8 same size

             (3)  Nos.  9-11  same size

             (4)  No measured gas volumes  generated for Nos.  6,  8,  or  9

     Assume:  Generated gas  volumes for Roasters  6, 8,  and  9  are the
              average of the measured gas  volumes for the same  size
              roasters  within the tolerances of the measured  gas volumes
              for Roasters 1-5.
                                       or 7930 + 1000 or  7930  +  13%
1:7420      therefore -510
2:9120      therefore +1190
3:7020      therefore - 910
4:9120      therefore +1190
5:6970      therefore -960


Avg = 7930 scfm
     7:6710 scfm  therefore Nos.  6 and 8 = 6710 + 13% or  6710  +  870

     10:6730
     11:21700     therefore No.  9 = 14215 + 13% or 14215  +  1845
     Avg = 14215 scfm
*  Reference 1

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Therefore,
     1:7420
     2:9120
     3:7020
     4:9120
     5:6970
     6:5840-7580
     7:6710
     8:5840-7580
     9:12,370-16,060
     10:6730
     11:21,700
     12:12,100-13,760

     110,940-119,770 scfm

     Avg 115,000 scfm with all  12 roasters  operating

     Normal operation = 10 roasters = yj x  115,000  =  96,000  scfm
Reverberatory Furnace

     No. 2: 42,100
            62,500

      Avg:  52,300 scfm
               No. 4:  40,500
                      45.200
                Avg:  42,850 scfm
                    Min:   82,600
                    Max:  107,700
                    Avg:   95,150 scfm
Converters

     No. 1
27,500
27,600
29,000
36,400
29,900
26,300
31,400
31.500
         Avg:   30,000 scfm
Normal operation = 3 converters
          Min = #1, 2,  3 = 121,100 scfm
          Max = #3, 4,  5 = 146,800 scfm
No. 2   51,700
        43,900
        41.000
 Avg:   45,500
No. 3  45,600 scfm

No. 4  51,200 scfm
                                     Assume  No.  5 = 50,000 scfm
          Avg =  • (1,2,3,4,5)  = 133,400 scfm

-------