Document 5BDqaqMOzaEwxrzKJ42ZQeJ0

Monsanto Enviro-Chem Monsanto Enviro-Chem System Corporate Square Office Park Box 14547 St. Louis, Missouri 63178 Phone: (314) 694-1000 C<i 74 (o'l-'b - /'bU')-Z* September 1, 1978 Mr. Carl Glaser ASARCO, INC. P.O. Box 1111 El Paso, Texas 79999 Re: Final Tower Brink Acid Spray Dear Carl : In connection with the final tower Brink acid sprays re quested by Fred Scott, I have sent under separate cover complete design drawings and Bill of Materials required to complete the installation. The cost of this installation would be approximately S5000 which includes the following: S1000 (60 manhours) of design engineering, S2500 materials including cast iron fitting, alloy 20 pipe and fittings and spray nozzles and S1500 labor to install. This work will be charged to our contract number 2156. Please let me know of your decision to proceed at your earliest convenience. Sine0'"01'' Julio Serra-Jones Manager, Project Engr. JS:emr cc: M. Ernhart (El Paso)^^_^ /360 ASARCO ELP 0007981 ASARCO INCORPORATED CENTRAL ENGINEERING DEPARTMENT FIELD CONSTRUCTION GAS HANDLING, CLEANING 6 ACID PLT EL PASO, TEXAS JULY 17, 1978 Monsanto Enviro-Chem Systems, Corporate Square Office Park Box 14547 St. Louis, Missouri 63178 Inc. ATTN: Mr. Julio Serra-Jones EA-26-EP, N.Y. 3954, Pit 623 Gas Handling, Cleaning & Acid Plant CE-77-EP-48; 17H-0711 Monsanto Enviro-Chem Acid Plant Stack Extension Gentlemen: The following enclosed drawings have been marked to indicate the required 30' extension to the acid plant stack: 5-317 Rev. 6 - Steel Ducts 5-210 Rev. 2 - Offset Steel Stack Also enclosed are copies of the following letters concerning the extension and sampling locations. R. Kinnan Goleman letter dated May 15, 1978 William F. Harris letter dated May 12, 1978 W. R. Kelly letter dated May 16, 1978 This information, along with Rod Hunt's sketch which was transmitted to you last week, should give you an idea of what is required. Please advise if you have any questions. CLG:bo Ends. - as stated cc: W. T. Sweat W. R. Kelly W. R. Mahoney 623-13539-23 623-FC-315 Construction Engineer ASARCO ELP 0007982 H. S^cwh 69i^t9rst Jack o, NJa^on *t MOWa*;, v\ Rao***E** * ^Ut G, Sa3c^ * , &ic**Sf3 C*/S*. J*. Cha%uc > 9*c Ro 9 t*T V.. D^vis R.Kiasai Gowc*'3' $?fC**Al9 T. HiC-A^woCU Acc P#c<rN Jfti.CCaA*~taBl_arAttConttANOC* Gtose S. 3otts Sco^ P. K't>0 M. C- Pitt-an Wavh c H. Rptscon H DavoHu^hcs #?oJ2r L. Otivcfl Wacte* H. Mircuc PAtnona L. Stokm Davo 3. ARHjaosr Jcr M. Hers R09T . Moumso.N Mjchaee G. Muu.cn .Sea Ann SnrrN Wiluam J Moctz ,A 'JJ l'" * b^w Offices i: - f 1 ! I T. _____ lu Bp ' N, Maroney, Rose, Baker & Barker :?:---------M 1300 AhericanBank Tower p.cw____ / S21 West Sixth Street *j j. Cr\Yl - - /- J V;CF IZZ_c Austin,Texas 7S7QI ARA COOC 5,12 rEceWEOHS( i51978 A3 & May 15, 1978 Mr. W. R. Kelly Plant Manager ASARCO Incorporated P.O. Box 1111 El Paso, Texas 79999 Re: Alternate Sampling Sites on the New Lead Sintering Machine and Ore Un loading and Storage System Dear Mr. Kelly: Enclosed please find copies of the three letters which we recently received from the Texas Air Control Board (TACB) in re sponse to our requests of May 8, 1978 for TAC3 approval of alter- ` nate sampling sites at the El Paso Smelting V7orks. As you can see, the proposals have been approved with some changes. Please, review these letters and advise our office regarding the difficul- ties, if any, that might be presented in complying with the TACB changes. \ As you are aware, it is also necessary for ASARCO to file similar requests with the U. S. Environmental Protection Agency (EPA) for the alternate sites relating to measurement of emissions from the Lead Sintering Machine. I have enclosed a draft of such a request which incorporates the TA.C3 modifications' to the proposals. This request should be sent to the EPA Administrator as indicated on the attached draft. If you have any questions^<3Tr~hornments, please feel free to call, / ' <">/ . . W/,- /^ ... ///' / t *- ,/' Ls /n' JJ / /? [) - 4' /vVC'^ {jv_ R. Kinnan Golemon f / RKG: p 1 Enclosures -v I MAY i o 876 cc: Messrs. Nelson, Travis, Varner, Muth and Duncan Copied for W.R.Mahoneyr Rod Hunt Mto.e, ASARCO ELP 0007983 JOHN L. BLAIR Chairman CHARLES R. JAYNES Vice Chairman BILL STEWA3VT, P.E. Executive Director May 11, 1978 8520SHOAL CREEK BOULEVARD AUSTIN. TEXAS 787S8 512/451-5711 WILLIAM H. ALLAH JOE C. 8RIDGEFARMER. P. E, FRED HARTMAN D. JACK KIUAN, M. D. FRAHKH. LEWIS WILLIAM D. PARISH JEROME W. SORENSON. P.E. Mr. R. Kinnan Golemon Brora, Maroney, Rose, Baker & Barber 1300 AmericanBank Tower 221 V7est Sixth Street Austin, Texas 78701 Dear Mr. Golemon: Your letter of May 8, 1978 on the subject of the location of sampling facilities ror the stack serving the new lead sintering machine at ASARCO, El Paso has been referred to me for reply. A.s you are well aware, we wish to avoid whenever possible any . sampling in a horizontal duct. This is due to the problem of "stratification" which is magnified under these conditions. However, in recognition of the magnitude of the physical ob stacles which must be overcome in order to sample this stack in a more conventional manner, we agree to a sample conducted 'at the location and in the manner which you have proposed - with the following exceptions: ` 1. The ports must'be modified so as to include a total of seven (7) points across the top of the stack instead of the four that are currently provided. To accompany this, the width of the stack should be divided in seven segments of equal lengths and a port placed at the center of each. 2. Seven traverse points must be located on each traverse thus providing a matrix of 7 X 7 ana a total of 49 points. I trust that this has satisfactorily responded to your inquiry but should you have any further questions please don't hesitate to call. ASARCO ELP 0007984 TEXAS AIR CONTROL BOARD JOHN L. BLAIR Chairman CHARLES R. JAYNES Vica Chairman BILL STEWART, P.E. Executive Director B520 SHOAL CREEK BOULEVARD AUSTIN. TEXAS 78753 512/451-5711 WILLIAM N. ALLAN JOE C. BRiDGEFARMER, P. E. FRED HARTMAN D. JACK KILIAN, M. D. FRANK H. LEWIS WILLIAM D. PARISH JEROME W. SORENSON, P.E. May 12, 1978 Mr. R. Kinnan Golemon Brown, Maroney, Rose, Baker, & Barbara 1300 AmericanBank Tower 221 West Sixth Street Austin, Texas 78701 Re: Your letter of May 8, 1978 concerning Texas Air 'Control Board Construction Permit #C-512.7 ASARCO, Inc. (El Paso) Dear Mr. Golemon, X have reviewed the referenced letter and concur in general with your proposal for sampling the stacks of the Metallurgical Scavenger Sulfuric Acid Plant. `' Your attention is invited to your proposal which involves placing the sampling ports four'- feet above the platform. This location of the ports will cause additional expenditure on your part due to the fact that the railing opposite the ports must be cut away in order to permit traversing with sampling equipment. Moreover, it complicates sampling operations by restricting the movement of personnel beneath the monorail and sampling box. It is therefore requested that the platform be located five and one-half feet below the centerline of the ports so as to avoid these problems Your proposal is otherwise accepted as outlined in the referenced letter. ~` If I can be of any further assistance, don't hesitate to call. Sincerely, William F. Harris, P.E. Chief Source Evaluation Section /4 S A- / / ASARCO ELP 0007985 May 16, 1978 Mr. Douglas M. Costle Administrator United States Environmental Protection Agency 401 M Street, S.W. V/ashington, D.C. 20460 Re: Request for Approval of Alternate Sampling Points on ASARCO Incorporated's (El Paso, Texas) Lead Sintering Machine Stacks Dear Mr. Costle: Pursuant to 40 CFR 60.8 and 40 CFR 60.13(i), ASARCO Incorporated (ASARCO) hereby requests approval of alternate sampling sites for use on a source subject to federal New Source Performance Standards (NSPS). The source subject to the NSPS is a new updraft lead sintering machine being in stalled for the replacement of six (6) existing downdraft sintering machines at ASARCO's El Paso Smelting.Works, located in El Paso, Texas. The applicable NSPS is found at 40 CFR Part 60, Subpart R. The provisions which ASARCO requests be altered relate to the location of sampling sites for the monitoring of particulates in sintering machine offgases. These provisions are set out at 40 CFR Part 60, Appendix A, Method 1. By this letter ASARCO requests approval of the following alternate sampling sites: (1) Use of a sampling site located 2.3 diameters downstream and 1.3 diameters upstream' from a stack gas flow disturbance for monitoring the weak SO2 bearing offgas streams from the lead sintering machine and (2) use of a sampling site located 4.5 diameters downstream and 1.0 diameter upstream of a stack gas flow disturbance for monitoring the strong SO? bearing offgases from the lead sintering machine. The reasons for this recpiest along with a more detailed description of the accompanying circumstances is set out more specifically below. 40 CFR 60.186(a) provides that the reference method to be used for monitoring of particulates in the stack gases from lead sintering machines subject to NSPS is Method 5 of 40 CFR Part 60, Appendix A. 40 CRF 60.186(b) further provides that the sampling sites are to be selected accor ding to Method 1 of Appendix A. Method 1 provides, in pertinent part, as follows: [At 40 CFR Part 60, Appendix 1, Method 1, Subparagraph 2.1] ASARCO ELP 0007986 -- Sampling or velocity measurement is performed at a site locr d at least eight stack or di diameters down stream u,id two diameters upstream ox any flow distur bance such as a bend...in the stack ...If necessary, an alternative location may be selected, at a position at least, two stack or duct diameters downstream and a half dia meter upstream from any flow disturbance... ASARCO Incorporated finds it necessary to select alternative sampling sites for use on two stacks at the El Paso Smelting Works. The offgases from the hew lead sintering machine are of two types. The first type (strong S02 bearing offgases) contain sufficient concentrations of SO? for treatment in a new 800 ton per day metallurgical scavenger sulfuric acio plant and related equipment before any of the offgases are vented to the atmosphere. The second type (weak S02 bearing offgases) contain primarily particulates and will be treated in the ^existing D & L baghouse before the cleaned gases are vented through the existing Lead Department Stack. This request concerns (1) the sampling site for the cleaned weak SO? bearing off gas stack (i.e. the existing Lead Department Stack) and (2) sampling site for the cleaned and treated-strong S02 bearing offgas stack (i.e.` acid plant stack emissions). The following discussion is divided into a section de scribing each of these requests and the reasons therefore. Alternate Sampling Sites For The Weak SQ^ Bearing Offgases As mentioned previously, the weak SO~ bearing offgases will first be cleaned in the D & L baghouse. After the offgases exit the baghouse, they travel through a rectangular, horizontal flue to the base of the 612 foot Lead Department stack. There are, therefore, two possible sampling sites: (1) in the horizontal flue and (2) in the 612 foot stack. The 612 foot stack has been in existence for many years. In addition, there presently are sampling sites and other related access facilities on the horizontal flue which have been accepted and approved by the Texas Air Control Beard as an alternate loca tion for measurement of these emissions. The specifications of 40 CFR Part 60, Appendix A, Method 1 require the sampling sites to be located according to the distance from stack gas distur bances. The general rule is eight (8) flue diameters downstream and two (2) diameters upstream from disturbances. The two disturbances in the baghouse offgas occur as the offgases leave the baghouse and enter the horizontal flue and as the offgases leave the horizontal flue and enter the 612 foot stack. As can be seen, there is a disturbance at each end of the horizontal flue. Due to the insufficient length of this flue, the 8 diameters - 2 diameters general rule cannot be met. Instead, the existing sampling sites are located 2.3 diameters downstream and 1.3 diameters upstream from the disturbances. This location is within the criteria of the alternate position specified in Method 1. In addition, it is proposed that the existing system utilizing four sampling points on the horizontal flue be modified by dividing the width of the flue into seven equal segments with a sampling port placed at the center of each. Seven traverse points will be located on each traverse, thus provi ding a matrix of 7 X 7 and a total of 49 sampling points. ASARCO Incorpor- ASARCO ELP 0007987 iviay xo, xy/o Page 3 9 ated requests that the existing sampling site with the modifications as de scribed above be approved for monitoring the baghouse offgases according to 40 CFR Part 60, Appendix A. The only sampling site location which could meet the 8 diameters - 2 diameters general rule would be on the 612 foot stack. Due to the extreme height and large diameter of this tapered stack, however, the sampling site would be at a height of approximately 275 feet above grade level (based on the average stack diameter below the sampling ports). Conducting sampling activities at this height would pose a substantial safety hazard and be quite burdensome on plant personnel and others' required to perform source moni toring. In addition, installation of the necessary access facilities and hand ling of the probes would be prohibitive. We believe that a. much safer and practical approach would be to utilize the existing sampling sites on the hor izontal flue. ' This is especially true since these existing sites conform to the specifications for alternate sites contained in Method 1. Additional design information for the above described facilities is as follows: 1. Stack height - 612'. 2. Stack I.D. - tapered. 3. Distance of sampling ports from stack wall (approximate, taken from scale) - 20'.. . 4. Distance of sampling ports from nearest upstream disturbance (bend in the flue exiting D & L baghouse) - 34'. 5. Inside dimensions of flue at sampling ports (approximate, taken from scale) - 12'5" across, 17'5" deep. 6. Seven sampling ports providing a total of 49 sampling points. .7. Height of monorail above sampling ports - 25' (the monorail system and caged access ladder were installed a year ago and the exper ience in collecting samples vertically from the flue has demonstrated that no difficulty is encountered in handling a 20-foot probe in the vertical mode.) Due to the reasons set forth above, ASARCO respectfully requests that the general criteria of 8 diameter downstream - 2 diameter upstream of any disturbance recommended in Method 1 of Appendix A be altered. Specifically, ASARCO urges that the present sampling location at 2.3 diameters downstream and 1.3 diameters upstream of any disturbance be designated as an acceptable sampling location for use to ensure that the weak SO? bearing offgases are in compliance with the applicable K'SPS by the appropriate reference method. Alternate Sampling Sites For The Strong SO^ Bearing Offgases The second type of sintering machine offgases, strong SO,, bearing, will be vented to the atmosphere after cleaning in the offgas puriacation system ASARCO ELP 0007988 "and 'treatment in .e metallurgical scavenger sunuric acid plant by a new stack. The same general rule of 8 diameters downstream - 2 diameters up stream of a disturbance as discussed previously apply to the sampling port location on this new stack. The engineering drawings for the stack have been reviewed and disclose the following: 1. Stack height - 101'. 2. Stack I.D. - 9'0". 3. Distance from top of breeching (81'2") to sampling ports (90'8") is 9'6", or roughly 1 diameter downstream from a major disturbance. 4. Distance from sampling ports to top of stack is 10'4", or roughly 1 diameter upstream from stack exit. 5. Four sampling ports, 5'6" from platform. 6. Platform is 41 wide. * 7. Guardrail is 42" high. ASARCO urges that the general criteria of 8 diameters downstream - 2 diameters upstream for the sampling port locations be altered. Specifically, ASARCO requests that the stack height be increased to 131 feet and that the sampling ports and platforms be relocated at a height one (1) ^diameter from the top of the stack. At such location the sampling ports would be located approximately 4.5 diameters downstream from the last major disturbance. Re presentative sampling "could be accomplished at this requested location by the use of thirty-six (36) sampling points. This requested alternate sampling port location conforms to the criteria specified in 40 CFR Part 60, Appendix A, Method 1 and has been approved by the Texas Air Control Board. The primary reason for this request is safety. As can be determined from the stack specifications shown above, the stack would have to be ap proximately 171 feet tall to meet the general sampling site criteria. In addi tion, the sampling facilities on the stack would have to be approximately 150 feet from grade level. By utilizing the requested alternate sites, the stack height is reduced by about 40 feet and the work area for sampling is lowered about 28 feet. We believe this height reduction would do much to reduce the safety hazards associated with stack gas sampling and stack maintenance. It should also be noted that the 171 foot stack needed to comply with the general criteria may be contrary to good engineering practice. As was shown above, the engineering design of the stack originally called for a 101 foot height. This height was specified by the engineers responsible for 'the de sign of the new facilities and represents a height which is needed for proper stack operation and for the stack to provide the needed dispersion. ASARCO suggests that this height should only be increased to a level necessary to achieve adequate stack gas sampling. This could be accomplished at the 131 foot height requested and be well within the alternate site location criteria of Method 1. We believe that requiring an additional 40 feet be added to this ASARCO ELP 0007989 Mr. Douglas M. Costle May 16, 1978 Page 5' stack would accomplish nothing in the way of improved sampling,or improved operation but would create a safety hazard, as discussed previously, and impose an unnecessary burden of redesign and associated increased costs. * For these reasons ASARCO requests that the proposed sampling site locations for sampling the strong SO- bearing offgases as they leave the 800 ton per day metallurgical scavenger sulfuric acid plant and are vented to the atmosphere be altered as set out in more detail above. Very truly yours. W. R. Kelly Plant Manager WRK:pl cc: Adlene Harrison Regional Administrator, Region VI United States Environmental Protection Agency Bill Stewart Executive Director Texas Air Control Board William F. Harris Chief Source Evaluation Section Texas Air Control Board Vv ASARCO ELP 0007990 rCHANGE ORDER. OATE PAGE 1 OF 6/8/78 plant job/appropriation no 623/NY 3954 ASARCO Incorporated PURCHASING DEPARTMENT 120 BROADWAY, NEW YORK. N Y. 10005 ORDER NO. 1 7H- 0 7 1 l REQUISITION NO CE-77--EP-48 _____ to. Monsanto Enviro-chem. Sys., Inc. P.O. Box 1457 St. Louis, Mo. 63178 Attn; Mr. D. C. Hale \S DATE REQUIRED AT DESTINATION f INAL OESTINATION.PLEASE NOTE CONSIGNMENT AS INDICATED ON ORIGINAL ORDER El Paso, Texas & (68250-2) SHIPPING INTERVAL PROMISED SELLER WILL SHIP BEFORE QUANTITY UNIT (CO-78- U3) SPECIFICATIONS THE PURPOSE OF THIS CH/N ITEM NO. To record variation orde identified by our above ur contract as 'der as follows; To adjust the contract guaran the cost of performance prej/I which was not part of orig mum price by Worthington Cost of variation Which increases the guaranteed amount'. a like $12, 185.OCj Lot This contract variation order is is guaranteed maximum cost only, no i fee results from this change. adj ust e in fixed NOTE TO PLANT; M.L. Leary: June 2nd, 1978 memo. vc WT This channe order is not b'ndir.rj on purchaser unless the attached Acknowledgment Card is signed by an authorized agent ot seller and returned promptly to purchaser. FOR PURCHASING DEPARTMENT USC ONLY 0 TvoQ 601. URGLR______________ CC_. pc _206___ distribution^l-W.T.Rweat/l-yW. p.ifeWly 1-L. Green ASARCO PD 1C- REVISED5/75 PLEASE ENTER OUR CHANGE ORDER FOR THE ITEMS SPECIFIED ABOVE SUBJECT TO ALL INSTRUCTIONS AND PROVISIONS ON REVERSE SIDE. By - PURCHASING AGE NT ASARCO ELP 0007991