Document mYnvXXDpzG5q025DXzxr9M2J

FILE NAME: Calaveras (CALV) DATE: 1985 Jan DOC#: CALVO 12 DOCUMENT DESCRIPTION: EPA Inspection a a a h a m m m \ LIMITED STATES ENVIRONMENTAL PROTECTION AGENCY OFFICE OF ENFORCEMENT AND COMPLIANCE MONITORING EP-330/2-85-002 ASBESTOS COMPLIANCE INSPECTION CALAVERAS ASBESTOS, LTD. Copperopolls, California January 1985 Richard Ida NATIONAL ENFORCEMENT INVESTIGATIONS CENTER Denver, Colorado 'S 000022 CONTENTS INTRODUCTION ........ SUMMARY AND CONCLUSIONS SUMMARY ........ CONCLUSIONS . . . PROCESS DESCRIPTION . MINING ............................ ORE PREPARATION .................... ORY ROCK HANDLING AND STORAGE . . . MILL OPERATION .................. TAILING AREAS .................. AIR POLLUTION CONTROL EQUIPMENT . . . . ORE PREPARATION 8AGHOUSES ........ DRYER ANO ORY ROCK STORAGE BAGHQUSES MILL BAGHQUSES . . . . . ........ INSPECTION RESULTS . COMPLIANCE EVALUATION 18 APPENDICES A INSPECTION PARTICIPANTS 8 SAMPLING RESULTS C TYPICAL MANOMETER READING RECORD O BAGHOUSE PRESSURE OROPREADINGS DURING OCTOBER 30, 1984 INSPECTION E TYPICAL WEEKEND MAINTENANCE LOG SHEET F PHOTOGRAPH LOG TABLES 1 Calaveras County Operating Permits ............................. 2 BaghouseJDesign Oata ........................................... 3 Saghouse Specifications.................. ' ..................... FIGURES 1 Process Flow Diagram .............. . . . . .................. 7 2 Ore Preparation Dust Control and Feed Flow Diagram . . . . . . . 13 3 MK Baghouse Air Flow Qiagraro ................................... 15 4 Mill Baghouse Air Flow D i a g r a m ................................ 000023 f I 1 I I 1 8 I 8 1 a i i a a a a a 8 INTRODUCTION Calaverai Asbestos Ltd. operates an asbestos mine and mill near Copperopolis, California. The ill recovers chrysotile asbestos fibers from serpentine ore by the dry asbestos process which consists of a series of crushing, screening and air-lifting operations. Asbestos mills are sub ject to the requirements of the National Emission Standards for Hazardous Air Pollutants (NESHAP) under 40 CFR, Chapter 1, Part 61, Subpart M National Emission Standard for Asbestos. During an inspection by the California Air Resources Board (CARB) on June 19, 1984, violations of the NESHAP standards were documented. As a followup to the CARB inspection, EPA, Region IX, on October 17, 1984, requested the National Enforcement Investigations Center (NEIC) to conduct' a NESHAP survey of the facility to include visible emissions observations " and a limited number of bulk asbestos samples and subsequent analyses. On October 30, 1984, NEIC personnel, accompanied by a representative from the Calaveras County Air Pollution Control Division (CCAPCO), inspected the Calaveras Asbestos facility. The inspection was preceded by a visit to the offices of the CCAPCD where files were reviewed and the general background of the facility was discussed. The participants in the inspection are listed in Appendix A. Credentials were presented to Mr. Gordon A. Coats, President, and Michael R. Dell'Orto of Calaveras Asbestos Ltd. and the purpose of the inspection was explained to the plant per sonnel. During the inspection, information was gathered on the process operations, emission points and related control equipment. In addition, the process operations were inspected to determine the compliance status with the asbestos NESHAP regulations. The plant employs about 220 people and operates 5 days per week, three shifts per day for the mine and mill and two shifts per day for the ore preparation area. In recent years the mill has been shut down from the 000024 2 middle of December to April I of the following year. The mine usually resumes operation sometime in February. This year, the mill shut down on November 2, 1984, and will resume operation on April 1, 1985. The truck Shop and mine closed November 21, 1984 and will reopen February 2, 1985. This report includes a process description, a description of emission points and related control equipment and the results of the inspection, including sample analyses. Photographs were taken to document the inspection observations [Appendix F]. 000025 sr9 JmHimm m m h B iS iJ` Bi; S l m lHHRd8B' I BBS i M lB 3 l ;-r SUMMARY AND CONCLUSIONS SUMMARY The two objectives of the inspection were to C D determine the compliance status of the facility with the National Emission Standard for Asbestos Subpart M of 40 CFR, Chapter 1, Part SI, the National Emission Standards for Hazardous Air Pollutants (NE5HAP) and (2) determine the effectiveness of measures taken by the Company to ensure compliance at the E-5 conveyor system which was in violation during a recent CARB inspection. To meet these objectives, Calaveras Asbestos personnel were interviewed, records were reviewed, visible observations were made and a limited number of samples were taken and subsequently analyzed. The NESHAP standards (40 CFR 1.142) require an owner or operator of * an asbestos mill to either discharge no visible emissions or control the emissions with a fabric filter collection system that meets certain fabric and pressure drop specifications (40 CFR 61.154). Visible emission obser* vations were made of all systems including crushers, screens, air lifting hoods, conveyor belts, transfer points and baghouse exhausts. Baghouse data were provided by the Company including air flow diagrams, manufacturers specifications and fabric specifications. Maintenance logs and baghouse pressure drop logs were reviewed and compared to readings taken during the inspection. The NESHAP standards for active and inactive disposal sites at asbestos mills require the discharge of no visible emissions and the use of a wetting agent. The waste handling system and tailing piles were observed for vis* ible emissions and to determine if use of the wetting agent was adequate to wet the dust and tailings to prevent wind erosion. Samples of the material being handled in various areas of the plant were taken to confirm that the material contained asbestos and, therefore, was subject to the NESHAP requirements. Samples were taken in the ore prep* aration area, the mill and the tailings area. Chain-of*custody procedures were followed to maintain the integrity of the samples. 000026 IIBflllBlIlIIlIIKll 4 The measures taken by the Company to eliminate the visible emissions problem observed during the CARS inspection were discussed with Company personnel. The tailing conveyor system was inspected to determine if the equipment was in place and if the visible emissions were eliminated. Photographs were taken to document the inspection observations. CONCLUSIONS The Calaveras Asbestos Ltd. facility near Copperopalis, California was found to be in compliance with the NE5HAP standards during the Inspection on October 30, 1984. No visible emissions were observed in the following process areas: ore preparation, dryers, dry rock storage and handling, mill and tailings. Also, the exhausts from all the baghouses were meeting the "no visible emission" rule. The following baghouse exhausts were observed: ore preparation baghouses A, B and C; baghouses MK1 through 6 and the mill baghouse. Documents submitted by the Company indicate that the baghouse bags meet the requirements of 61.154(a)(1)(ii) and (iii) regarding type of fabric, permeability, thickness and weight. In addition to the bag speci fications, |61.154(a)(l}(i) also requires that the pressure drop across the baghouse filters be no more than 4 inches water gauge to be exempt from the no visible emissions rule. Pressure drop readings taken at the time of the inspection and obtained from a review of the Company records show that the baghouses operate above 4 inches of water gauge immediately prior to clean ing. Once the bags are cleaned, the pressure drop falls below 4 inches water gauge. Because no visible emissions were observed from the baghouse exhausts, the_pressure drop across the baghouse filters are within the requirements of 61.142 and 61.154. The cleaning cycle and pressure drop are within the baghouse manufacturer's specifications. From a review of the maintenance log, the baghouse appears to be operated and maintained properly. No visible emissions were observed from the transfer of waste material to the tailing piles which meets the requirements of 61.151(c). Also the 000027  IffJllllllIIIfllll wetting agent, Oustrol, was being mixed with the waste material before depositing the material on the tailings pile which, additionally, meets the requirements of 61.1Sl(c)(l)(i). No visible emissions were observed from the inactive portions of the mill tailings piles, meeting the requirements of 61.153(1). In addition, a crust had formed on the surface of the piles from the application of Oustrol. Windblown dust could be a problem in the future if the crust is broken. If windblown dust becomes a problem, provisions for limiting access and traffic on the tailings and adequate wetting would mitigate it. Measures taken by the Company to eliminate the visible emission problem observed during the June 19, 1934 CARB inspection appear to be adequate. No visible emissions were observed from the E-5A tail pulley or the E-5A to E~58 transfer point. Measures taken by the Company included adding new sprayers, a new booster pump, new plows and additional skirting, curtains * and enclosure. 000028 & PROCESS DESCRIPTION A schematic of the mine and mill operations is shown in Figure 1. The " operations of the plant are divided into the following areas: mining, ore preparation, dry rock handling and storage and mill operations. The ore is v mined in an open pit mine and the asbestos fibers are released and recov- ered from the serpentine rock by a series of crushing, screening and air lifting operations. ft MINING Asbestos ore is obtained from an open pit mine where the serpentine ore is mined from the deposit by pit blasting. The present depth of the pit is 440 feet and about 5,000 tons of ore are mined each day. Pit blast- ^ ing occurs about four times per week. A blasting schedule was requested but the mine does not blast on a set schedule. Blasting is usually deter mined the day before and depends upon the size of material needed by the mill. Different areas of the mine produce different size fibers of exclusively chrysotile asbestos. Once the ore has been blasted loose, the rock is loaded into dump trucks and hauled to the ore preparation area. * ORE PREPARATION Run-of-the-mine ore is fed to a primary jaw crusher which reduces the ore to minus 6-inch material. The capacity of the jaw crusher is 300 tons per hour. Q_this amount, about one-third of the material is eventually rejected by the subsequent crushing and screening operations and two-thirds of the material is sent to the mill area for further processing. A belt conveyor moves the crushed material to a secondary cone crusher which reduces the material size to minus % inch. The material is then screened by two triple-deck shakers where the minus 3/8 inch and minus H inch mate rial are dropped onto belt conveyor -2 which transports the material from the ore preparation area to the dryers. The oversize material is sent to 000029 m -4 m na sw O A S B C S T O f MINING ANU M ILI ir lo O O o O.'- o Figure I Calaveras Asbestos Ltd. -v PROCESS FLOU 01AGRAM Copperopo I is, California m RB| IBI 8 two Hazemag tertiary crushers by a belt conveyor. The discharge of the tertiary crushers are sent by a belt conveyor, OP-4, to another set of triple-deck shakers where the minus 3/8-inch material is discharged- onto belt E-2 and the oversize material is returned to the tertiary crushers or sent to the rock reject pile by a belt conveyor. The crushed ore is transported to the dryer and dry rock area by belt conveyor E-2. The conveyor discharges the ore to a vibrating screen where the ore is separated into various size fractions. Minus V*1nch material is sent to the vertical dryer and minus 3/8-inch material can be sent to either the vertical dryer or the horizontal dryer. The plus 3/8-inch material is sent to the horizontal dryer. The vertical dryer handles about one-fourth of the material from the ore preparation area and the horizontal dryer dries the remainder of the ore. Discharge from the dryers is sent to a sifter screen that recovers 40-mesh material which is sent by belt conveyors E-3 " and E-4 to the dry rock storage building. Waste from the sifter screen is conveyed by belt E-5 to the tailings pile; DRY ROCK HANDLING AND STORAGE The dry rock storage building is an A-frame sheet metal building which houses the storage piles. Ore is removed from the building by a belt con veyor housed in a concrete tunnel located under the storage piles. Ore is fed onto the conveyor belt by vibrating feeders located at openings in the concrete tunnel. Ores are blended by operating several feeders at the same time. Blended ores are delivered to the mill building by the - belt conveyor. MILL OPERATION In the mill- building, the ore is subjected to a series of six stages of crushing and four screening and air-lifting operations to liberate and recover the asbestos fibers. The maximum process weight rate for the mill is 150 tons per hour and the normal rate is 100 tons per hour. Operating in the mill building are 12 crushers, 40 screening decks, 19 collectors and four baghouses. 000031 B B IB V IE H V I I B B I R H 9 The ore Is passed over a series of shaker screens for separation into size fractions of plus 3/16 inch down to minus 20 mesh. The material larger than 3/16 inch is returned to the crushers for further size reduc tion. Each shaker screen is fitted with an aspirating hood to lift off asbestos fibers es the material passes from screen to screen. The liberated fibers are collected in a series of cyclone collectors that dis charge to horizontal rotary graders where a rough separation of fibers is made by fiber length. The fiber products are grouped and collected in four bins and are fed by screw feeders to pressure-type bag packers. The bags are then flattened and palletized for storage and shipment. Barren rock or non-fibrous material from the final screening operation is sent to tailings by a series of belt conveyors. The dust and waste material are fed to a water screw where the material is saturated with water and wetting agent to prevent visible emissions. TAILING AREAS The facility produces three types of tailings: mining waste (over burden), rock rejects from the ore preparation area (aggregate) and mill waste tailings. The mine waste tailings are northeast of the mill around the east side of the pit. The rock reject tailing piles are northwest of the mill on the southeast edge of the pit. The mill tailings are piled east of the mill. The Company adds a surfactant (Dustol) to the mill tail ings before depositing the waste on the tailings pile. The surfactant is mixed with water and sprayed on the material at a rate of about 20 gph. 000032 8, II 8 8 8 8 8 I I 9 I 10 AIR POLLUTION CONTROL EQUIPMENT The sir pollution control equipment (beghouses) and related process operations are permitted annually by the Calaveras County APCD. A listing of the active operating permits 1s given in Table 1. The baghouse design data are listed in Table 2. ORE PREPARATION BACH0USE5 The ore preparation feed and dust control system flow sheet is shown In Figure 2. The ore preparation baghouses (A, B and C) vent and control the dust from the following process equipment: Jaw crusher, cone crusher and Hazemag impact crushers Four tripledeck shakers Conveyor belts, including the E"2 conveyor belt to the mill All of the equipment is vented to baghouse C, then the air flow is split between baghouses A and B before being vented to the atmosphere. The ore preparation baghouse specifications are given in Table 2. Baghouse C is a Fuller baghouse with four compartments. Each compartment has 4,000 square feet of cloth area for a total cloth area of 16,000 square feet. The air-to-cloth ratio is 2:1. The bag specifications are given in the Compliance Evaluation section of this report. Baghouses B and C were manufactured by Industrial Clean Air-Reese and have one compartment each. The total cloth area for baghouse B is 4,200 square feet with an air-lo-cloth ratio of 3:1. Baghouse C has a total cloth area of 7.000 square feet with an air-to*cloth ratio of 3:1. The design pressure drop for both baghouses is less than 4 inches water gauge. 000033 RBI m m nx n Operating Permit No. 84-03-02 84-03-03 84-03-04 84-03-05 84-03-07 Tabic 1 CALAVERAS COUNTY APCO OPERATING PERMITS CALAVERAS ASBESTOS LTD. Copperopolis, California Equipment `Listed Rating Pulseflo filter MK-1 Pulseflo filter MK-2 Vertical (tower) dryer Pulseflo filter MK-3 Pulseflo filter MK-4 Horizontal (rotary) dryer Pulseflo filter MK-5 Pulseflo filter MK-6 Baghouses A, B, C Draco fabric filter C Model HM8-100 Ore prep., primary crushing dust control Mill dust conveyor system and all equipment in mill building 4,300,000 Btu/hr 13,000,000 Btu/hr 480 hp 1500 hp 4900 hp Permit Period 4/2/84 to 4/2/85 4/2/84 to 4/2/85 4/2/84 to 4/2/85 4/2/84 to 4/2/85 4/2/84 to 4/2/85 m m 000034 m r . Hm. Baghouse Kanufacterar ^ O r e Preparation Baghoutas 9@gna(rt A "Industrial Claan Air * A n ^^Baghousa 8 { M H Industrial Claan Air * Raesa " "aaghousa C Fullar S ^ f t l c a l Oryar Baghouse HK1-2 .^-- Western Precipitation * Jay TM T O r i i o n t a l Dryer Baghouse MK3-4 ivastarn P r e c ip ita tio n Joy Dry Rock S to ra g e B aghouse 1 8 * 5 -6 ^ ^ w e s te r n P recip ita tio n - Joy m'l l B aghouse Rock O ust System sW h eela b ra to r F ib er O ust System [W heelaerator O ust H ygiene System jg jjw n eeia b ra to r m m n Q No. of Compartments Tapia 2 BAGHOUSE DESIGN DATA CALAVERAS ASBESTOS LTD. Coppferopolis. California Cloth Araa (sq. ft.) Air-to* Cloth Ratio 4 16.000 2:1 1 4.200 3:1 1 7,000 3:1 z 11.300 2.5:1 2 11 .2 0 0 3 .3 :1 2 1 1 ,3 0 0 3:1 4 27.5 0 0 2 .5 :1 3 8 3 .0 0 0 2 .5 :1 fn cl. a above 2 .5 :1 12 Datign Prossura Drop (inches Y.G.) Air Flow (cfa) Fan (hp'. <4 33,000 100 <4 12,600 75 <4 21.000 100 - 4-6 29,000 150 4-6 . 3 8 ,0 0 0 ISO 4-6 32.0 0 0 200 i <4 50 .0 0 0 800 in c ) <4 1 7 5 ,0 0 0 abov in C l. in el <4 above IDOV 000035 TO. \\ : / I i H".% *'1 fi'! r- ,<0- O ... ,4 :L * . `*4- IM.MI' M i_...j ------ ^ i-- ''p -- t - - ! .. a L '* aiWi4i a iiiiUt n Figure 2 ORE PREPARATION DOST CONTROL AND FEED DIAGRAM CALAVERAS ASBESTOS LTD. * Copperopolis, California :<jv I i I i ! i I ! ! I 1 'I'-- l i i tI ! w , Tv l i!vv . r ;L . ...... . t m i * v ' : i; f " _i _ d i r r i_i\/ k* (M* 1*41 * -Hrr? ____ J 1 ^ sirocoo rxvr I. iwrav *1 . * b 4) .0- . fc-*.+-#m-* i .? '* . jj -if* ! /i . - * V* .u?l ;---Vi, ' '-P ^ , .v '. i * . ( jfr. >**>*.- * y*"l ^ .' A '**, ..fruii 14 1. % 1 i, 1 I a a i a a i DRYER AND PRY. ROCK STORAGE BAGHOUSES The vertical dryer, horizontal dryer and dry rock storage are vented to baghouses MK1 through 6. The MK baghouse air flow diagram 1s shown in Figure 3 and the design specifications are listed 1n Table 1. All of the MK baghouses were manufactured by Western Precipitation - Joy Manufacturing. All of the bag specifications are given in the Compliance Evaluation section of this report. The vertical dryer is vented to the MK1-2 baghouse, then to the atmos phere. The baghouse has two compartments with a total cloth area of 11,300 square feet. The air-to-cloth ratio is 2.5:1. The horizontal dryer is vented to the MK3-4 baghouse which has two compartments. The total cloth area is 11,300 square feet with an air-to- cloth ratio of 3.3:1. The design pressure drop is 4 to 6 inches of watergauge and the air flow is 38,000 cfm. MK5-6 baghouse vent the dry rock storage area, the mill basement, E-5 conveyor system and E-6 tunnel'. The MK5-6 baghouse has a total cloth area of 11.300 square feet with an air-to-cloth ratio of 3:1. The design pres sure drop is 4 to 6 inches water gauge. MILL BAGHOUSES The mill baghouse was manufactured by Wheelabrator, with a design pressure drop of less than 4 inches water gauge. The mill baghouse is located in the mill building penthouse that collects air from three differ ent systems: the rock circuit, the fiber circuit and the hygiene circuit. The mill baghouse air-flow diagram is shown in Figure 4 and the design data * is given in Table 2. The.air is sent to two large plenum chambers, through the baghouse compartment, then to the atmosphere. The rock dust system baghouse has four compartments with a total cloth area of 27,500 square feet. The air to cloth ratio is 2.5:1. The fiber circuit has three compartments with a total cloth are of 83,000 square feet. 000037 if Ai n a n u i n ! 000038  `.i'I'riftC* 1U` i f f i l l| -l l wsrewwww^/ L--\ llraifia "-- v r - ' y i*.* ??* I < I r ii _.._ _ ^ __ ^ _ ir ~|J ___ ^__ I \H ' f i V | V f v'iJ't v/b1 V V" Jk o o o \ ij;*=V \V .`,,sVr * %j;r\ i k i i r ; fl IH CO Figure li f_p M U I Baghouse Air Flow Diagratn Calaveras Asbestos, Ltd. CopperopolIs, California 3 ... f m* *' .Sid'fc** i J i . i- r . i ... V "\ 7*"l|!l' ve,,i`*"J`Cv<''!C ! T ' , v *1 , Vr '!s 4 i l ?l i t i j :1 H rpr1 l & 'r- ' V ! l-W-L f^ A JE rULfiS U E t t A U U T o b . u to 4L> , | ~ ~ r " , _____________ 17 The air t cloth ratio is 2.5:1. The dust hygiene system is included with the rock dust system. The baghouse compartments for the mill building are located In the sealed penthouse that is accessible for inspection. Person nel can enter the penthouse routinely for maintenance and bag-leak checks. 000040 18 INSPECTION RESULTS COMPLIANCE EVALUATION The compliance evaluation of the facility was based on the NESHAP requirements, 40 CFR Part 61, Subpart M - National Emission Standards for Asbestos. The visible emissions standard for asbestos mills (40 CFR 1.142) requires that the owner or operator either discharge no visible emissions to the outside air or control the emissions with a fabric filter collection system that meets certain fabric and pressure drop specifications (40 CFR 61.154). Visible emission observations were made of all operations including crushers, screens, air lifting hoods, conveyor belts, transfer points and baghouse exhausts. 8aghouse data was provided by the Company including air flow diagrams, manufacturer's specifications and fabric specifications. Maintenance and baghouse pressure drop logs were reviewed and pressure drop readings were taken. After a short briefing meeting with Company personnel, the following plant areas were inspected: the ore preparation area, the dryer and dry rock handling area, the mill and the tailing areas for the mine and mill. Samples of the material being handled in the various areas of the plant were taken to confirm that the material contained asbestos, thus subjecting the facility to the NESHAP requirements. Samples were taken in the ore preparation area, the mill, the tailings area and the mine and haul roads. Chain*of-custody procedures were followed to maintain the integrity of the samples. Ore Preparation Area The ore preparation area reduces the mined ore to minus 6 inches of material and separates the asbestos-containing ore from the serpentine rock. Fugitive dust from the crushing, screening and transfer operations is controlled by baghouse A, 8 and C, water sprays and enclosures. During the inspection, no visible emissions were observed from any points in the ore preparation area. This includes the baghouse exhausts, transfer points, crushing area and the rock reject bin. 000041 BS B B B I I K I I I B I I I I V V I 19 Th aggregate material in the rock reject bin was wet and no visible emissions or dust were observed when the material was dumped into a truck for transfer to the rock reject tailings pile. The material being handled at the rock reject bin was sampled for asbestos content to determine if the NESHAP standards were applicable. The aggregate was covered with a white fibrous material. The white material was analyzed and found to contain 65*85% chrysotile asbestos confirming that the handling of the reject rock and the reject rock tailing piles are subject to the "no visible emission" rule of NESHAP. At the time of the inspection, this area was in compliance with this rule. The laboratory results of the sampling, the sampling record and the chain-of-custody forms are contained in Appendix B. Drying and Dry Rock Storage The material from the ore preparation area is transferred to the dryers via a covered conveyor belt (E-2). No visible emissions were observed from the belt or the transfer points to the dryers. Both dryers are controlled by baghouses. Baghouse HK1-2 controls the emissions from the vertical dryer and baghouse MK3-4 controls the emissions from the hori zontal dryer. No visible emissions were noted from the exhausts from either baghouse. From the dryers, the material is screened and conveyed to the dry rock storage building via a covered conveyor. No visible emissions were observed from this operation. The dry rock is stored in an enclosed building and moved to a mill building by a number of covered conveyor belts running under the storage piles. The dry rock storage area and conveyor system is controlled by baghouse MK5-6. No visible emissions were observed from the baghouse exhaust or from the conveyor system. Hill Operation The asbestos fibers are released and collected by a series of crushing, screening and air-lifting operations. These systems are enclosed and 000042 H n V Q Q a 20 ducted to a series of cyclones, a plenum chamber and the mill baghouse. During the Inspection, visible dust was negligible within the building and around the crashing, screening and lifting operations. The beams, stair ways and walkways were clean and no accumulations of dust were observed. No visible emissions were observed from the transfer equipment within the building or from the baghouse exhaust. A sample of the material being handled in the mill building was taken at the hood opening of the E-6 head pulley. The white material covering the rock in the sample contained 60-80% chrysotile asbestos. The sampling results are documented in Appendix 8. The mill waste is conveyed to the mill tailings pile by a series of conveyor belts (E-5, E-5A and E-5B). The transfer points between these conveyors were observed to be in violation of the visible emission require ment during an inspection by the ARB on June 19, 1984. Since that time, " the Company has completed a project at the E-5A tail pulley to eliminate the visible emissions. The project included the following: 1. Enclosure was extended about 20 feet. 2. Skirting was added around the tail pulley and the full length of the enclosure (added rubber between enclosure and belt). 3. Plows were installed to spread material on belt. 4. Six new sprays were added. 5. Mew sprayers were added in the water screw. 6. Curtains were added inside the enclosure to direct the water sprays onto belt. 7. High pressure water booster pump (7 1/2 hp) and a 500-gallon storage tank for the surfactant (Dustrol) were added to provide a mors, consistent and steady mixture of surfactant to the sprayers. 8. Monitoring and cleanup of the area was increased. The work done at the E*5A tail pulley has also solved the problem at the E-5A and E-5B transfer point since the material is kept wet. No visi ble emissions were observed at any of the transfer points including the dropoff to the tailings pile. A sample of the aggregate in the tailings pile was taken and the white material covering the aggregate was found to 000043 s 1 1 a n i m 21 contain 30*60% asbestos fibers. The actual weight percent of asbestos in the aggregate was not determined. Company personnel indicated that the mill tailings-contain 0.4-0.6% asbestos by weight but most of the asbestos 1s bound in the aggregate. Tailings Areas The NESHAP standards for active and inactive waste disposal sites (61.151 and 61.153) require either the discharge of no visible emissions or the use of an adequate wetting agent to effectively wet the dust and tailings. During the inspection, no visible emissions were observed from the tailing areas. The Company adds a surfactant (Dustrol) to the mill tailings before depositing the waste on the tailings pile. The surfactant is mixed with water and sprayed on the material at a rate of about 20 gph.A crust formed on the piles that was easily broken by walking on the piles exposing the loose material under the crust. Those areas of the waste piles that are routinely disturbed, such as roadways, should be kept wet to prevent fugitive dust emissions. Runoff from Tailings Because the mine and mill tailings are located close to the Stanislaus River, the California State Water Quality Control Board (WQCB) annually inspects the tailings area to determine if runoff or asbestos-containing material enters the river. The last inspection by the WQCB was done on September 20, 1984. The results of the inspection were not available. The WQCB has required Calaveras Asbestos to do the following to prevent the erosion of material or runoff from entering the Stanislaus River. 1. Maintain catch basins to prevent runoff from entering the river. 2. Sample the river upstream and downstream of the tailings piles for asbestos whenever runoff enters the river. The sampling will start next year using the sampling method described in EPA Publi cation 600-54-83-044 dated November 1983. 000044 ififliiiniiiBaaiiBBi 22 3. Take pictures annually of the tailing piles from specific points to show that the piles have not severely eroded during the past year. These pictures are submitted to the WQCB annually. The catch basins were observed and there was no evidence of overflowing. The north pond and a series of three catch basins on the northeast side of the pit catch runoff from the mine tailing piles. A series of six catch basins in Long Canyon catch the runoff from the mill tailings. Mined Land Reclamation Test Plot About 4 years ago the Bureau of Mines established a test plot on the mill tailings pile. Various grasses, trees and shrubs were planted to determine if the waste could support these plants. The grass and the trees' were living and stabilized the test plot soil. However, the test plot was level and the problem with growing grass and/or shrubs on the tailing piles is the slope of the piles. Company personnel indicated that growing mate'* rial on their tailings pile Is not feasible. The Bureau of Mines has not completed their study of the test plot. Baqhouses The Company has installed baghouses to meet the air-cleaning requirements of 61.154 which could exempt them from the "no visible emission" rule at certain points in their process. Table 3 was developed from data received from the Company during the inspection. The fabric specifications meet the requirements of 61.154(1)(ii)(iii) and (iv). 000045 rs i i B i i a i i i i i i igea i Doghouse Nuobar A a c 1.2.4 C3 MK-1 end MK-2 m - J end MK-4 m-S ml MR-6 Wheelabretor Wheelebrotor Equipment Service! * Bag Description Ore Prep Ore Prep. Ore Prep. Ore Prep. Cotton Sateen - Style 100 F.F.*. Cotton Sateen-Style 100 f.F. Cotton Sateen-Style 100 f.F. Cotton Sateen, C'14 Fuller Vertical Oryer Nonen VP. (Globe) 1019-11397-31-2 Rotary Dryer None W.P. (Globe) 039-11397-31-2 Dryrock Storage Mill Mill Dacron Polyester H P. (Globe) 009-11397-31-2 Polyester 7K2435-6Q Sateen W.W. Criswell Cotton Fire-Retardant 101-70 Sateen W.W. Criswell lobte 3 BACHOUSE SPECIFICATIONS CALAVERAS ASBESTOS LTD. Copperope11*. Colt forni IAGH0USE Pressure Drop (W.G.) Type of fabric FABRIC SPECIF1CAII0NS Permeability cfn/ft* (0%-W.C.) Weight oi./yd.* Hfg. red. Mfg. Nfg. Mfg. FecT Spec. ..Iti,...SfiCCx....tea*...__ ..tea*.... . S t --- Man. Max. Min. -4" -4" -4 -4" Woven Woven Woven or felt Woven or Felt If Woven 12 30 9 1n Not Felt None ~ r r ----- Nat Woven 12 30 Felt 9 1/2 None 1 Woven If or Woven -4" -4" Woven Felt 12 30 9 1/2 Not Felt None -4" -4- Woven Woven or felt 20-3D If Woven 30 B-8 1/2 Net Felt None Woven or 4"-6M -4" Felted Felted 25 if Fall end on Dryer 45 15-16 If Felt 14 Woven or 4"-6" -4" felted felted 25 If Felt and on Oryer 45 15-14 If felt 14 4**4" -4' -4" 4* -4" Felted Woven Woven Woven or felted tfovftn or Felted Woven or fglted If Fell end an Hill 30 35 16 If Woven 15-25 30 6 B-12 Woven 30 i-- i----- 10 1/2 If Felt 14 Not Felt None Hot Felt None Thickness inches Mfg. , Fed. .lilt... Min. 0.23 .012 Not Felt Mone Not Felt None .023 Mot felt Mone .019 to .021 Not felt None If Felt .OB .0425 If Felt .06 .0625 .OB .015 .022 If Felt .0625 Not Felt None Not ft It None N 009046 24 During the inspection, pressure drop readings were taken of various baghouses to determine if the requirements of 61.154(1)(i) were being met. The readings Were taken for all of the baghouses except the ore preparation baghouses. The readings were recorded on the Company's Manometer Reading Record form and are shown in Appendix D. Ore preparation baghouse pressure drop .readings were not available at the time of the inspection. Typical ore preparation baghouse pressure drop readings are given in Appendix C. The readings were between 3 inches and 6 inches of water column and within the manufacturer's specifications. The lower readings were on those com partments just cleaned and the higher readings were made on those compart ments awaiting cleaning. The cleaning cycle time was not known, but was set by the various manufacturer's of the baghouses. Since March of 1984, the Company has been recording the baghouse pres sure drop readings weekly. Before, they were recorded monthly. The log was reviewed and a copy of a typical manometer reading record is shown in Appendix C. The baghouse pressure drop readings are routinely above 4 inches water gauge. Because no visible emissions were observed from the baghouse exhausts, the pressure drop across the baghouse filters are within the requirements of 61.142 and 61.154. The baghouse exhausts must meet the no visible emissions requirements of 61.142. The Company maintains a baghouse maintenance log book where a record of routine maintenance, dye checks, repairs and bag replacement are recorded. A typical log sheet is shown in Appendix E. The bags in the Mark 1 through 6 baghouses are dye checked for leaks at least once per month and sometimes weekly. The bags in the mill and ore preparation baghouses are visually checked for leaks weekly. It appeared that the bag* houses were being operated and maintained properly since there were no visible emissions at the time of the inspection. Mine and Haul Roads Although the mine and haul roads from the mine are exempt from the NESHAP requirements, the mining operation was observed to determine the magnitude of the dust plume generated by a pit blast. 000047 25 V 1 * i i 1 1 Ia Quring the inspection a blast was observed. A plume of dust was generated but was confined to the pit area. The blast occurred at the bottom of the pit under favorable wind conditions. The dust plume had settled within 10 minutes of the blast. In order to minimize the dust generated during blasting, the Company changed the blasting procedures. For the past 2 years, the Company has been using the following blasting procedures. 1. Use a 10~circuit blasting board set at 33 milliseconds to control the firing sequence of the charges. 2. Use slurry type #927 Dupont explosive rather than stick explosive for better control of blast. 3. Blast only under favorable wind conditions. As a result of these changes, Company personnel indicated that the blasts are uniform and localized, generating a smaller dust plume than before. In addition, less explosive is used than before the changes were made. The Company presently used about 9-12,000 pounds per shot or about 120,000 pounds per month. The haul roads from the pit to the ore preparation area and 1n the vicinity of the mill were wetted and no visible dust was being generated by the truck traffic. The pit roads were also wetted and negligible dust was being generated from the loading of ore into the ore trucks. The visible dust was confined to the bottom of the pit. 1 000048 m a H M a APPENDICES A INSPECTION PARTICIPANTS 6 SAMPLING RESULTS AND DOCUMENTATION C COPY OF TYPICAL COMPANY MONOMETER READING RECORD O BAGHOUSE PRESSURE DROP READINGS E COPY OF TYPICAL WEEKEND MAINTENANCE LOG SHEET F PHOTO LOG SHEET AND PHOTOS 000043 4 APPENDIX A OCTOBER 30. 1984 INSPECTION PARTICIPANTS CALAVERAS ASBESTOS LTD. C0PPER0P0LIS, CALIFORNIA 000030 mat n n m Name Gordon A. Coats * IN Michael R. Dell'Orto George Jackson B Joey E. Toney n Michael P. Redgrave i i Richard B. Ida a a ii a a Appendix A INSPECTION PARTICIPANTS CALAVERAS ASBESTOS LTD. Copperopolis, California October 30, 1984 Title Affiliation and Address President Calaveras Asbestos Ltd. P.O. Box 127 Copperopolis, CA 95228 Oirector of Purchasing Calaveras Asbestos Ltd. P.O. Box 127 Copperopolis, CA 95228 Project Engineer Calaveras Asbestos Ltd P.O. Box 127 Copperopolis, CA 95228 Director of Environmental Affairs Calaveras Asbestos Ltd. P.O. Box 127 Copperopolis, CA 95228 Assistant Sanitarian Calaveras County Health Department Environmental Health Government Center San Andreas, CA 9524$ Environmental Engineer ILS. EPA National Enforcement Investigations Center Denver Federal Center Bldg. 53, Box 25227 Oenver, CO 80225 Telephone (209)785-2201 (209)785-2201 (209)785-2201 (209)785-2201 (209)754-3849 (303)236-5139 FTS 776-5139 000051 APPENDIX B SAMPLING RESULTS AND DOCUMENTATION OCTOBER 30, 1S84 INSPECTION CALAVERAS ASBESTOS LTD. COPPEROPOLIS, CALIFORNIA 000052 ENVIRONMENTAL PROTECTION AGENCY OFFICE OF ENFORCEMENT NATIONAL ENFORCEMENT INVESTIGATIONS CENTER BUILDING 33. BOX 23237. DENVER FEDERAL CENTER DENVER. COLORADO 80223 Richard Ida Operations Division_ OAU: December 3, 1984 Douglas K e n d a lt " y ' Laboratory Services Division Asbestos Determinations Calaveras Asbestos Background On November 5. 1984, three samples collected from the Calaveras Asbestos Company were received at KEXC for the determination of asbestos. The samples were collected by Richard Ida of NEIC. Results All three of the samples were found to contain chrysotile asbestos. The samples consisted of black and gray crushed rock covered with a white, fibrous material. Only the white material was examined and it was this material in all of the samples that contained major amounts of chrysotile asbestos. Tag N-13074, Station No. 1, from the reject rock bin, contained 65 to 85Z asbestos. Tag N-13075, Station No. 10, from a tailings pile, contained 30 to 50Z asbestos in the white covering of the rock. Tag N-13076, Station No. 15, from the head pulley feed, contained 60 to 80Z chrysotile asbestos in the white material. Method The analysis was performed by polarized light microscopy using the EPA "Interim Method for the Determination of Asbestos in Bulk Insulation Sam ples". Samples are'mounted in liquids of various refractive indices and examined under the microscope for fibers. If fibers are observed, their optical properties are determined to see if chose properties are characteristic of one of the forms of asbestos. Asbestos is identified from its morphology, extinction characteristics, sign of elongation, re fractive indices, birefringence and any color or pieochroisra. Quality assurance includes participation in the EPA sponsored round robin program and checks by a second analyst. 000053 a jh m O l l i c o o l G ni o r e m e ni P R O J. N O PROJECT N A M E C09 p f l^ S f ir o s sT u o y 4*.l RECEIPT FOR SAMPLES N a m e ol Facility C/f* A v e / tA * JU m - x '' Building U . B o i ! S 2 2 0 ) M v r F r d u a l C m u Denver. Colorado 00225 X 7~ & Split S a m p l e s Ol i e r e i / ( ) Accepted < ) Declined ST N O DATE TIME & m 3 < o a u o SPLIT SAMPLES oof "$5 f? n t \ -- X 0(0 S X n At 0/5 * > /* /* t n o 6. XT TAG NUMBERS Aj - P yy ( J - i 70 S AJ Facility L o c a t i o n f. O &O AT /J 7 t o f / '< T A t > f o . iS C q S 2 2- f STATION DESCRIPTION iie S F c . T /e o e K . AW S jA C M e f l^ d i s E - H G ad fu L L G Y rF c o O fi- Y o cK N O OF con tainers / / F A !A / i REMARKS 000054 Tuna -4 S 3 f/T] D istribution O riginal io Coordinator Field Files, C o p y io Facility /] R e c e i v e d b / S tg n U t 'T li'c it; l'*0 Telephone 7S< ' 2?c-/ Time sssy N 885 O Olite* of E n J o t c m * n i S i l f i fi l E LI B w h i H V l U . 8 q k 25227. Deiwei Federal Cerner APPENDIX C COPY OF TYPICAL COMPANY HONOMETER READING RECORD OCTOBER 12, 1984 CALAVERAS ASBESTOS LTD. COPPERQPOLIS, CALIFORNIA 000056 Manometer Reading Record Ckt / J r A f - ' P rtttu r Orop Bogtieut* Compartment Ml 9 t/2 R vod iM ot Ptoding c l L e ft S a t Riant S e 2 1 t j L I j l Zzl 2 .V</ 1iSVr a.% 1 it i 2.yy 1 J l ^ h e s e f^ | w # ilo of fisa K < 1iS o. *2; SS1 5. SS 9.6 Vi j. r 'U'ti </, v> 2.r^ 1 IA 3 1 / f I -, 5. Or ZA 3A 4A Vertical Prati.,. RofCry Oryer Oryrock Storage noci a Mx*z M X-3 W C -4 MK*S6 MK*6 Or Prp 8H A ,, \/v X'N _a/f2. Or Pflp 0HQ BHC Comp. I Comp. 2 Comp. 3 Comp. 4 / / *Ty -2J1 r? y4 At V>/ -7./: 1 ^ 1 //<= i ^ '4 I / i -? j I -* 1Vy i -*<' *- . * \V, I * / * '/ A"-' v i '/-; /.rii Vi"? 'W7> ci?? V&'> SO i.n le - 5. W !>v* # Of-^tf ' j.n* o 1UCL ^ i l Y?~) JOV'O `/ l'ki I. IMMI W - n r. '* f Notte . TJtnTDTT APPENDIX D BAGHOUSE PRESSURE DROP READINGS TAKEN DURING OCTOBER 30, 1984 INSPECTION CALAVERAS ASBESTOS LTD. COPPEROPOLIS, CALIFORNIA 000058 BBS m Manometer Reading Record PC, / p / & / f ? Tim m I hI "S o flh o u it Location Compartmtnt 1 M z in A .iii.ji 3 9B l IB I "_ L a r cim i " ^ J_ a 4 3 1/2 6 7 IA ZA 3A ai t 4A " " TwrJieqji^i MK-1 a MK-2 Of ver MH &ryir gLjbrroek r BS?r09J MK-3aMK"4 MK*Sa MK*6 , Ora Prep forti H -CCr_ " t u '*<_ la fi? md d (a In -- : BHA 8H8 BHC Comp. 1 Comp.2 Como. 3 Camp. 4 fin '<t J.7 ' 3,4 1 3L 3 + 7 .2 - 1 J f yo io 3.i* 1 3. 4 2,r 1 i r t r 13< 2 * .1 3,/ Co) / ? 1 2 . < ;.r - 3 r 1* } 2 -3 2. ^ /r /. 3 1 / / 1 2.4 1 li - . r1 1Pressor Drop Inch of Conversion Oil * Factor H I T 0' y , 3 1 1. m*JIS L. Maximum Fed. soc. 4 /Jb Notes _6.r1 6.. 3 ' / - *~`A 4 4 . 7.1 1 S' O 4 4 i* 1 V /.i T 4 7 ,0 1 4 r ,r .3 ' ' i- u 4 S .L (/. 3 4 ~ W ~ 7o 1 S.8 4 Ll 1 r. r 4 ,<. 1 3 -f 4 3,6 3. 3,? 1 r . z 4 /rutn 4 41K~ 4 l '' 1 4 - i ' i 4 1 ^ 1 j . immi 4 l 1 4 1 1 4 i 1 1 4 000059 APPENDIX E COPY OF TYPICAL WEEKEND MAINTENANCE LO SHEET CALAVERAS ASBESTOS LTD. COPPEROPOLIS, CALIFORNIA -4 * 000060 W fPKgNP MAINTENANCE, omt^JLuLiS^fc-- -- -- orr Serti Job Oiaeriptloa t* t HJ*3L pjT T aflT C_Vct.Uf* U DETl R^c^CY' ^OlAV^ISY* V ^0 a Lpio Hr * Mi Ijal i ISi lJ * 11 2 mI a%ril __ *4 Con Mochante' Non mMNeiij_Xiti< * te X < & w . &S&. ^41 la i. 2k T ava. Tftwi T U a . .... 4. W W t C f ................................ .. ! ________ * .i i U U u 'v i _ APPENDIX F CALAVERAS ASBESTOS LIO. i S OCTOBEPHROT30O,S 1384 COPPEROPOUS, CALIFORNIA II ia i a a a a a 9 000062 Appendix F PHOTO LOG CALAVERAS ASBESTOS LTD. Copperopolis, California October 30, 1984 1 o Picture Number 1 through 6 7 8 (not printed) 9 (not printed) 10 11 12 13 14 15 16 17 J.O 19 21 22 23 24 Description Sequence of pictures of open pit mine taken from NW edge of pit. Blasting of asbestos ore from SE edge of pit. Blast dust plume from SE edge of pit. Blast dust plume from SE edge of pit. Blest dust plume from SE edge of c-- pit. #2 catch basin at edge of mine tailing pile next to Stanislaus River. #3 catch basin of mine tailing pile. l|iine tailing pile next to river. Emergency spillway for dam north of pit. Taken from mine tailing pile. Reject rock being dumped into truck. Baghouse B exhaust and conveyor or 0P-1 in ore preparation area. Baghouse A exhaust and conveyor belt OP-6 in background feeding reject belt. E-5 head pulley, water screw 2 and E-5A tail pulley and water spray enclosure. Long canyon catch basins #3, #2, #1 (can't be seen), #3 in foreground. Catch basins are for mill tailings piles. Long canyon catch basins #3, #2, #1. #1 can't be ssen very well. SE end of property by Stacker #3. E-5C head pulley to Stacker #3*., Stacker #3 to pile. Horizontal dryer. Baghouse MK3-4 for horizontal dryer and collectors. Dry rock storage air line (circu lar). Belts, E-3 and E-4 to dry rock storage E-6 from storage to mill. 000063 31 ai m m m 000064 000065 990000 000067 R90000 F-7 B~B I I B B I flH IBB fifi S 000071 MO 000072 F-1J 000073 T F-12 000074