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PROJECT OVERVIEW
ASARCO requested that they be allowed to reroute the baghouse stack exhaust from the pugmill from the present 308-foot stack to the 828-foot copper stack annulus. There will be no increase, or decrease, of emission rate from this facility.
REQUEST FOR COMMENTS
REGION: 6 Reviewed by: Archie Clouse
CITY:
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The exhaust gasses from the holding furnace and converters, which are rich in SO2, are cleaned of particulate matter before they are conditioned and converted to SO3. The SO3 gas is then scrubbed with water to produce 98% sulfuric acid. The particulate matter captured from this gas stream is sent to the pugmill where it is mixed with a little moisture and loaded in rail cars for recycling. Some of this material is recycled at this facility.
A safety inspection has shown that the 308-foot stack is in need of repairs. The stack was originally built over 80 years ago. The company wants to reroute the pugmill baghouse exhaust stack to the taller copper stack annulus. The old stack will be removed. The taller stack will give better dispersion of the emissions.
SOURCES, CONTROLS AND BACT
The pugmill is controlled by the baghouse, which is BACT. In my opinion, BACT has been applied to this facility.
IMPACTS EVALUATION
1. Was modeling done? No Type? N/A
2. Will GLC of any air contaminant cause violation of NAAQS?
NO
3. Is this a sensitive location with respect to nuisance?
NO
4. Is the site within 3000 feet of any school?
NO
5. Toxics Evaluation: This is a change of representation for the pugmill baghouse stack to vent into a taller stack. This will help lower the off-property impacts.
COMPLIANCE HISTORY
1. Was a NOV issued for construction without a permit?
NO
2. Was the NOV resolved by issuance of permit?
N/A
Comments:
MISCELLANEOUS
1. Is applicant in agreement with special conditions?
Yes
Company representative(s)?
Contacted via?
Date of contact?
2. Did the franchise tax verify the applicant to be in good standing?
N/A
Permit Engineer Date Team Leader/Section Manager/Backup Date
C:\NSRFORMS\FM\TECHRVW.FM
Revised
1 comment:
Is it Archie Clouse saying "In my opinion, BACT has been applied to this facility."?
What is BACT, I wonder.
I notice Mr. Clouse does not list supporting evidence for his opinion.
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