155233-0000

TRC Project No. 155233 

JANUARY 30, 2007 

Emission Test Final Report 

for 

Mercury Emission Testing 

at 

Coeur Rochester, Inc. 

Pershing County, Nevada 

Prepared for 

Coeur Rochester, Inc. 

P.O. Box 1057 

Lovelock, Nevada 89419-1057 

Prepared by 

TRC Environmental Corporation 

47 South Orange Street 

Suite B-1 

Salt Lake City, Utah 84116

DISCLAIMER 

This document is intended for use solely by Coeur Rochester, Inc. (CRI) for the specific purposes described 

in the contractual documents between TRC Environmental Corporation (TRC) and CRI. All professional services performed and 

reports generated by TRC have been prepared for CRI’s purposes as described in the contract. The information, statements and 

conclusions contained in the document have been prepared in accordance with the work statement and contract terms and 

conditions. The document may be subject to differing interpretations and/or may be misinterpreted by third persons or entities

who were not involved in the investigative or consultation process. TRC Environmental Corporation therefore expressly 

disclaims any liability to persons other than CRI who may use or rely upon this document in any way or for any purpose.
155233-0000

DEVIATION REPORT

The following presents a brief description of all deviations which occurred during the testing 

program at Coeur Rochester, Inc. conducted the week of December 2, 2007. 

1. During preliminary set-up of the mercury retort system on December 3, 2007 an 

initial EPA Method 3A was performed to determine the oxygen and carbon dioxide 

values to complete the calculations for nozzle selection. The results of this 

preliminary analysis indicated ambient values of 21.0% for oxygen and 0.0% for 

carbon dioxide. Prior to sampling on December 4, 2007 another Method 3A was 

performed which resulted in the same values for oxygen and carbon dioxide. 

These ambient results were used throughout the entire testing program on the 

mercury retort system. 

2. During recovery of EPA Method 29, Run 2 on the mercury retort system a portion 

of the front-half rinse was lost due to spillage. The recovery was completed and 

included in the samples sent to the laboratory for analysis. An additional run 

(Run 5) was performed. All five tests results are presented in this report. See 

Section II.1.1 for a more detailed description of this deviation. 

No additional deviations occurred during this testing.
TABLE OF CONTENTS 

155233-0000 i

TABLE OF CONTENTS 

Section I Introduction ...........................................................................................I-1

I.1 Overview .........................................................................................................I-1

Section II Sampling activities...............................................................................II-1

II.1 Testing Activities ............................................................................................II-1

II.1.1 Retort System (Retort 1 & 2) Testing .....................................................II-1

II.1.2 Refinery Furnace/Wet Electrostatic Precipitator (WESP) Testing.......... II-2

Section III Process and Control Equipment Site Background..........................III-1

Section IV Sampling Location and Frequency ...................................................IV-1

IV.1 Refinery Mercury Retort System 1 & 2..........................................................IV-1

IV.2 Refinery Furnace with WESP........................................................................IV-1

Section V Sampling and analytical Procedures .................................................V-1

V.1 Field Program Description..............................................................................V-1

V.2 Pre-sampling Activities...................................................................................V-1

V.2.1 Equipment ..............................................................................................V-1

V.2.2 Glassware Preparation...........................................................................V-2

V.2.3 Sample Media Preparation.....................................................................V-2

V.3 On-site Sampling Activities ............................................................................V-2

V.3.1 EPA Methods 1 or 1A and 2 or 2C for Velocity Measurements and 

Cyclonic Flow .........................................................................................V-2

V.3.2 EPA Method 3 – O2 and CO2 Determination for Molecular Weight........V-3

V.3.3 EPA Method 4 for Moisture Determination.............................................V-3

V.3.4 EPA Methods 29 Mercury Determination...............................................V-3

V.3.5 ASTM D 6784-02 Ontario Hydro Method (OHM) ...................................V-4

V.4 EPA Method 29 and ASTM D 6784-02 OHM Analytical Procedures - MercuryV-5

Section VI Summary of Results ...........................................................................VI-1

Section VII Quality Assurance..............................................................................VII-1

VII.1 OVERVIEW..................................................................................................VII-1

VII.2 FIELD QUALITY CONTROL SUMMARY.....................................................VII-1

VII.2.1 Calibration Procedures.........................................................................VII-1

VII.2.2 Equipment Leak Checks ......................................................................VII-1

VII.2.3 Cyclonic Flow Check............................................................................VII-1

VII.2.4 Sample Handling Quality Assurance/Quality Control...........................VII-1

VII.3 DATA REDUCTION, VALIDATION, AND REPORTING..............................VII-2
TABLE OF CONTENTS 

155233-0000 ii

VII.3.1 Field Data Reduction............................................................................VII-2

VII.3.2 Data Validation.....................................................................................VII-2

VII.3.3 Data Reporting .....................................................................................VII-2

APENDICES 

Appendix A Field Sampling Data Sheets 

Appendix B Computer Calculations 

Appendix C Analytical Data Packages 

Appendix D Calibration Information 

Appendix E Correspondence 

Appendix F Test Protocol 

Appendix G NDEP-BAPC Excel Spreadsheets 

TABLES 

Table VI-1 Mercury Retort System Parameter Summary .........................................VI-1

Table VI-2 Mercury Retort System Mercury Emission Summary..............................VI-2

Table VI-3 Refinery Furnace/WESP Parameter Summary – EPA Method 29..........VI-3

Table VI-4 Refinery Furnace/WESP Mercury Emission Summary ...........................VI-4

Table VI-5 Refinery Furnace/WESP Parameter Summary – OHM...........................VI-5

Table VI-6 Refinery Furnace/WESP Mercury Emission Summary - OHM................VI-6

Table VI-7 Mercury Retort System Removal Efficiency............................................VI-7

FIGURES 

Figure III-1 Coeur Rochester, Inc. – Mercury Retorts Process Flow Diagram........... III-2

Figure III-2 Coeur Rochester, Inc. – Refinery Furnace Process Flow Diagram......... III-3

Figure IV-1 Sampling Arrangement for Small Ducts.......................................................IV-1

Figure IV-2 WESP Sampling Location .......................................................................IV-3
INTRODUCTION 

155233-0000 I-1

SECTION I INTRODUCTION 

I.1 Overview 

Coeur Rochester, Inc. (CRI) operates the Rochester and Nevada Packard precious metals 

mines and processing facilities in Pershing County, Nevada. The facility is located 

approximately 12 miles east of Interstate Highway 80, Exit 119 in the Humboldt Range. 

As a participant in the new Nevada Mercury Control Program (NMCP), CRI performed 

mercury emission testing on the following thermal sources; 

3⁄4 Refinery mercury retort system (two retorts controlled by the same carbon 

filtration system), and 

3⁄4 Refinery furnace, equipped with a wet electrostatic precipitator (WESP) 

Total mercury emissions for both sources were determined using EPA Method 29 (M29). 

M29 is the Nevada Division of Environmental Protection Bureau of Air Pollution Control’s 

(NDEP BAPC) accepted method for determining total mercury emissions. In addition, CRI 

performed a series of three runs for mercury speciation on the outlet of the WESP using the 

Ontario Hydro Method (OHM). 

The project was under the direction of Mr. Tim Senger of TRC’s Las Vegas, Nevada office. 

The field crew was comprised of Mr. Joseph C. Zuzolo and Mr. Mark Patrick of TRC’s Salt 

Lake City office. 

On-site representatives for Coeur Rochester, Inc. during testing were Ms. Cindy Jones, 

Processing Superintendent for Coeur Rochester, and Mr. Todd Lewis, Lewis Environmental 

Consulting, LLC. 

The on-site representative for the NDEP-BAPC during testing was Mr. Joseph Prary, Staff 

Engineer. 

The field test phase of the program was conducted during the week beginning December 2, 

2007. 
Sampling Activities 

155233-0000 II-1

SECTION II SAMPLING ACTIVITIES 

II.1 Testing Activities 

The field crew arrived on-site the afternoon of December 2, 2007. After receiving sitespecific training, the lab trailer was positioned and initial set-up of equipment on the retort 

system was begun. The following morning set-up was completed and testing of the retort 

system was initiated. The following sub-section presents a detailed description of the retort 

testing. 

II.1.1 Retort System (Retort 1 & 2) Testing 

The “Retort System” consists of two separate cylindrical shaped mercury retorts, a 

common condenser system, a vacuum pump followed by two carbon filters (in 

series). Effluent gases from each of the mercury retorts pass though the common 

abatement equipment and are exhausted to the atmosphere through a four (4) inch 

diameter stack. 

On the morning of December 3, 2007, each retort was loaded with a charge of wet 

process precipitate feedstock. Retort 1 was loaded with 4386 wet pounds (1989.5 

wet kilograms) and Retort 2 was loaded with 4696 wet pounds (2130.1 wet 

kilograms). 

Once the retorts were loaded and sealed, the batch operational sequence was as 

follows: 

3⁄4 Each retort operating temperature was ramped up to 400°F. 

3⁄4 After maintaining at 400°F for 1-hour the temperature was then ramped up to 

each retort’s operating temperature (approximately 1200°F). 

3⁄4 The retorts were held at their operating temperature for 48 hours. 

3⁄4 At the conclusion of the period, each retort was turned off and allowed to 

cool. 

To accommodate this batch operation the Nevada Division of Environmental 

Protection – Bureau of Air Pollution Control (NDEP-BAPC) requested that four (4) test 

runs be performed under the following schedule: 

3⁄4 The first test run was initiated once both mercury retort reached an interim 

operating temperature of 650°F. 

3⁄4 The second test run was initiated once both mercury retorts reached their 

normal maximum operating temperature. 

3⁄4 The third test run was initiated no sooner than 2 hours after the completion of 

the second test run. 

3⁄4 The fourth test run was initiated no sooner than 24 hours from the start of 

the first test run. 
Sampling Activities 

155233-0000 II-2

A fifth test run was performed immediately following the fourth test run. This 

additional test run was performed due to the following deviation. 

3⁄4 Following the completion of Run 2, sample recovery procedures began with 

the cleaning of the nozzle, probe, and heated line (front half). After 

completing this portion of the sample recovery the front half recovery bottle, 

filter assembly, and the condensate impinger collection portion of the sample 

train were transported to the recovery trailer. M29 recovery procedures 

require that the all-connecting glassware prior to the filter be cleaned and 

recovered into the front half recovery bottle. Following the cleaning of the 

filter assemblies’ front half, the recovery bottle was tipped over and a portion 

of the front half rinse was spilled. Subsequent volume measurement of the 

remaining recover reagent indicated that 50 ml were lost to spillage. 

Discussions as to the direction to take were initiated between TRC, CRI and 

the NDEP-BAPC representative on-site, Mr. Joe Prary. Following a brief 

discussion of options, Mr. Prary contacted his superior and a mutual decision 

was made to conduct a fifth test run immediately following the fourth run. All 

five runs would be analyzed, reported and evaluated in the final report. The 

remaining sample recovery for Run 2 was completed with no further 

deviations. 

Following the completion of testing on the retort system on December 4, 2007, testing was 

initiated on the Refinery Furnace/Wet Electrostatic Precipitator (WESP) the next day 

(December 5, 2007). The following sub-section presents a detailed description of the WESP 

testing. 

II.1.2 Refinery Furnace/Wet Electrostatic Precipitator (WESP) Testing 

The “Refinery Furnace/WESP System” consists of a refinery furnace vented to a 

fume hood, a venturi-induced draft fan (ID fan) and a wet electrostatic precipitator 

exhausting through a 44 X 44 inch square stack (see Figure III-2 and Figure IV-2). 

On the mornings of December 5 and 6, 2007 the following operating procedure was 

followed. 

3⁄4 At 0600 hours, the furnace was fired under low-fire conditions to heat the 

walls. 

3⁄4 At 0630 hours, the furnace was put on high-fire conditions and loaded with 

ten (10) trays of dry precipitate. 

3⁄4 At 0900 hours, slag was poured off. 

3⁄4 At 0930 hours, an additional five (5) trays of dry precipitate were loaded. 

3⁄4 Furnace stabilization occurred at 1000 hours. 

3⁄4 At 1200 hours, a second slag pour was completed. 

3⁄4 At 1330 hours, metals were poured. 
Sampling Activities 

155233-0000 II-3

3⁄4 At 1415 hours, the pour was completed and the high-fire and the WESP were 

turned off. 

On December 5, 2007, the refinery furnace was loaded with a total of 5033 dry 

pounds (2282.9 dry kilograms) of dry precipitate. On December 6, 2007, the 

refinery furnace was loaded with 4989 dry pounds (2263.0 dry kilograms) of dry 

precipitate. 

Coeur Rochester personnel collected samples of the feedstock for both the mercury retort 

system and the refinery furnace/WESP system prior to loading. These samples were set 

directly to SVL Analytical, Inc. (SVL), One Government Gulch, Kellogg, Idaho. SVL 

performed mercury analysis following SW-846 Method 7471A. Tables VI-1 through VI-7 

summarize the results of the mercury sampling, along with calculated removal efficiencies 

for the mercury retort system. Laboratory results of these analyses can be found in 

Appendix C. 
PROCESS AND CONTROL EQUIPMENT SITE BACKGOUND 

155233-0000 III-1

SECTION III PROCESS AND CONTROL EQUIPMENT SITE 

BACKGROUND 

CRI operates the Rochester and Nevada Packard precious metals mines and processing 

facilities in Pershing County, Nevada. The mine administration and precious metals 

recovery complex is accessed by exiting Interstate Highway 80 at Exit 119; then traveling 

east approximately twelve (12) miles to the top of the Humboldt Range. 

Construction, pre-production mining operations and the first pour of silver dore’ (low purity 

silver bars) were completed in September 1986. Through April 2007, over 183.9 million 

tons of ore were mined and placed on three heap leach pads. Precious metals were, and 

continue to be, recovered by the Merrill-Crowe zinc precipitate processing of conventional 

heap leach pregnant process solution. Refining of the precious metals precipitate to 

produce dore’ occurs in the onsite refinery furnace. 

Mining operations at CRI were completed in August 2007. Residual leaching of ore placed 

on lined heaps, and precious metals recovery, will continue for approximately three to five 

years. 

The precious metals refining process includes two thermal sources that have the potential to 

emit mercury: 

3⁄4 Two new mercury retorts (installed CY2006) whose emissions are controlled by a 

carbon filtration system (see Figure III-1), and 

3⁄4 A melting furnace whose emissions are controlled by a wet electrostatic 

precipitator (WESP) (see Figure III-2). 
PROCESS AND CONTROL EQUIPM

155233-0000 III-2

Figure III-1 Coeur Rochester, Inc. – Mercury Retorts Process Flo

Condensers (4)

Vac. Pump

Carbon Filters (2)

From FTo Ref

To Atmosphere

Liquid Mercury Mercury Retorts (2)

Collected
PROCESS AND CONTROL EQUIPMENT SITE BACKGOUND 

155233-0000 III-3 

Figure III-2 Coeur Rochester, Inc. – Refinery Furnace 

Process Flow Diagram 

 Fan

WESP

- Current and Voltage

To Barren Sump

To Atmosphere

Refinery Furnace

 Fume Hood

Venturi WESP
SAMPLING LOCATION AND FREQUENCY 

155233-0000 IV-1 

SECTION IV SAMPLING LOCATION AND FREQUENCY 

The following sub-sections present the sampling locations for each of the systems to be 

tested. 

IV.1 Refinery Mercury Retort System 1 & 2 

The “Retort System” consists of two separate cylindrical shaped mercury retorts, a common 

condenser system, a vacuum pump followed by two carbon filters (in series). Effluent gases 

from each of the mercury retorts pass though the common abatement equipment and are 

exhausted to the atmosphere through a four (4) inch diameter stack. Sampling was 

performed on the circular outlet stack exiting the second carbon filter. An outlet duct was 

fabricated to meet the optimum upstream and downstream diameter requirement of EPA 

Method 1, “Sample and Velocity Traverses for Stationary Sources”. Due to the four (4) inch 

diameter of the fabricated duct a modification to the sampling procedure was made. This 

modification is addressed in Section V.3.1. Follow EPA Methods 1, 1A, and 2C, sampling 

was performed using four (4) points per traverse for a total of eight (8) points per test run. 

Sampling point locations can be found in Appendix A, (Traverse Point Location for Circular 

and Rectangular Ducts). 

Figure IV-1 Sampling Arrangement for Small Ducts 

IV.2 Refinery Furnace with WESP 

A wet electrostatic precipitator (WESP) controls emissions from the refinery furnace. 

Sampling was performed in the rectangular outlet stack position on the top of the WESP. 

Samples were collected through three (3) ports located along one side of the outlet stack. 

Prior to sampling, measurements of the outlet stack were made to determine the upstream 
SAMPLING LOCATION AND FREQUENCY 

155233-0000 IV-2 

and downstream equivalent diameters. This information can be found in Appendix A, 

(Traverse Point Location for Circular and Rectangular Ducts). Following EPA Method 1, 

“Sample and Velocity Traverses for Stationary Sources” it was determined that twenty-four 

(24) (the maximum number) sampling points would be used for sampling. A total of eight 

(8) points were sampled in each port. 
SAMPLING LOCATION AND FREQUENCY 

155233-0000 IV-3 

Figure IV-2 WESP Sampling Location 
Sampling and Analytical Procedures 

155233-0000 V-1 

SECTION V SAMPLING AND ANALYTICAL PROCEDURES 

This section describes the procedures that TRC followed during the field-sampling program. 

V.1 Field Program Description 

TRC personnel utilized the following EPA Methods as listed in 40 CFR Part 60, Appendix A, 

and the American Society for Testing and Materials (ASTM): 

3⁄4 EPA Method 1 “Sample Velocity Traverse for Stationary Sources”, 

3⁄4 EPA Method 1A “Sampling and Velocity Traverses for Stationary Sources with 

Small Stacks or Ducts”, 

3⁄4 EPA Method 2 “Determination of Stack Gas Velocity and Volumetric Flow 

Rate (Type S Pitot tube)”, 

3⁄4 EPA Method 2C “Determination of Gas Velocity and Volumetric Flow Rate in 

Small Stacks or Ducts (Standard Pitot Tube)”, 

3⁄4 EPA Method 3 “Gas Analysis for the Determination of Dry Molecular Weight”, 

3⁄4 EPA Method 4 “Determination of Moisture Content in Stack Gases”, 

3⁄4 EPA Method 29 “Determination of Metals Emissions From Stationary Sources”

(Mercury only), and. 

3⁄4 ASTM Method D 6784-02 “Elemental, Oxidized, Particulate-bound and Total 

Mercury in Flue Gas (Ontario Hydro Method)”

V.2 Pre-sampling Activities 

Pre-sampling activities included equipment calibration, pre-cleaning of the sample train 

glassware, and other miscellaneous tasks. Each of these activities are described or 

referenced in the following subsections. 

V.2.1 Equipment 

All equipment utilized for this program was inspected for proper operation and 

durability prior to calibration. Calibration of the equipment was conducted in 

accordance with the procedures outlined in EPA documents entitled "Quality 

Assurance Handbook for Air Pollution Measurement Systems; Volume III - Stationary 

Source Specific Methods" (EPA-600/4-77-027b), 40 CFR Part 60 Appendix A, and the 

test protocol submitted in November 2007. 

3⁄4 Probe Nozzles, 

3⁄4 Pitot tubes, 

3⁄4 Thermocouples, 

3⁄4 Dry gas meter orifice, 

3⁄4 Field barometer, and 

3⁄4 Analytical balance. 
Sampling and Analytical Procedures 

155233-0000 V-2 

V.2.2 Glassware Preparation 

Sample train glassware was pre-cleaned to avoid contamination of the sample. The 

sample train glassware necessary for the EPA Method 29 and the OHM was precleaned as follows: 

1. Rinsed with hot water. 

2. Washed glassware with hot soapy (Alconox®) water using non-metallic 

brushes to remove particulate, which might be adhered to the glass. 

3. Rinse glassware three times with hot tap water. 

4. Rinse glassware three times with DI water. 

5. Soak glassware for four hours in 10% v

/v HNO3 solution. 

6. Rinse glassware three times with DI water. If contamination is still visible 

repeat step five substituting with a 10% v

/v chromic acid solution and 

repeat the DI water rinse. 

7. Rinse glassware with acetone. 

8. Allow the glassware to air dry then seal openings with non-metallic 

(Parafilm® or plastic wrap) material. 

9. Place cleaned and sealed glassware into dedicated glassware trunks. 

V.2.3 Sample Media Preparation 

All reagents used were purchased from a chemical supply company and were of 

trace-metal (or higher)-grade. Certificate of analysis were obtained and are included 

in Appendix D. 

V.3 On-site Sampling Activities 

Onsite sampling activities included the emissions testing of the previously mentioned outlet 

stacks and collection of operational data. 

V.3.1 EPA Methods 1 or 1A and 2 or 2C for Velocity Measurements and Cyclonic 

Flow 

Velocity traverses were conducted in conjunction with the M29 and OHM sampling. 

For the refinery furnace, measurements were taken with an S-type Pitot, 

thermocouple and nozzle assembly in accordance with EPA Reference Methods 1 and 

2. The required number of velocity measurements points for the sampling location 

was determined following EPA Method 1. 

For the refinery mercury retort systems velocity and temperature, readings were 

taken according to EPA Methods 1A and 2C. Both these methods cover procedures 

associated with small ducts. These methods are limited to stacks or ducts less than 

about 12.0 inches (0.30 meters) in diameter but equal to or greater than 4.0 inches 

(0.10 meters) in diameter. Velocity measurements were measured using a standard 

Pitot tube (per method requirement) as a replacement for the S-type Pitot tube 

allowable in Methods 1 and 2. In addition to standard Pitot tube, Method 1A directs 
Sampling and Analytical Procedures 

155233-0000 V-3 

that flue gas velocity be measured downstream of the actual emission sampling site 

(see Figure IV-1) to minimize flow blockage which would occur with a normal 

sampling probe assembly. 

A Cyclonic flow check was conducted on the outlet duct of the mercury retort 

system. This check confirmed the absence of any cyclonic flow. A cyclonic flow 

check was not performed on the refinery furnace outlet stack. 

V.3.2 EPA Method 3 – O2 and CO2 Determination for Molecular Weight 

Oxygen and carbon dioxide concentrations were determined at each of the sampling 

locations. Sample gas was collected in an evacuated Tedlar® bag. Analysis of the 

bag was performed with a Fyrite analyzer in accordance with EPA Method 3, "Gas 

Analysis for the Determination of Dry Molecular Weight". 

On December 3, 2007, during pre-measurements of the mercury retort system, a 

Tedlar® bag was filled with effluent gas from the exhaust stack. Analysis of this bag 

resulted in ambient air readings. It was determined at this time that an oxygen 

value of 21.0% and a carbon monoxide value of 0.0% would be used in the 

calculation of the molecular weight of the effluent gas stream. This same procedure 

was followed on December 4, 2007 resulting in the same ambient air values for 

oxygen and carbon monoxide. 

During sampling of the WESP, a composite Tedlar® bag sample of the effluent gas 

was collected during each test run for both the M29 and OHM sampling. These 

samples were analyzed with a Fyrite analyzer and the resulting oxygen and carbon 

dioxide values were used in the calculation of the molecular weight of the effluent 

gas stream. 

V.3.3 EPA Method 4 for Moisture Determination 

Moisture was determined for each test run according to EPA Reference Method 4, 

"Determination of Moisture Content in Stack Gases". Moisture was collected by the 

condensing/absorbing system. The amount of moisture collected was determined 

gravimetrically by difference between the final and tare weights of the glass 

impingers, which made up the condensing/absorbing system. 

V.3.4 EPA Methods 29 Mercury Determination 

An EPA Method 29, “Determination of Metals from Stationary Sources” sampling train 

was used to collect mercury from the effluent gas stream on both the mercury retort 

systems and the refinery furnace. 

A series of five (5) EPA Method 29 samples were collected on the mercury retort 

system and three (3) on the refinery furnace. The initial test run for each series of 

test was 120-minute. This was done to evaluate whether the sample time necessary 

to collect the minimum 1.7 dry standard cubic meters (dscm) (60 dscf) could be 

achieved using a shorter sampling time. It was determined that a sampling time of 

96 minutes would be sufficient to collect the necessary sample volume on the 

mercury retort system. 
Sampling and Analytical Procedures 

155233-0000 V-4 

On the refinery furnace, the initial 120-minute test indicated that the minimum 

sample volume requirement was achievable as long as the differential pressure (Δp) 

readings did not decrease. A decrease in the Δp readings would directly affect the 

amount of sample volume that is collected. Anticipating that this decrease in Δp 

might occur, a slightly large diameter nozzle was used for Runs 2 and 3. Sampling 

times for Runs 2 and 3 were decreased to a 96-minute period. 

Leak checks of the entire EPA Method 29 sampling train were performed prior to and 

at the completion of each test run. At no point during any test run was any portion 

of the sample train disassembled and reassembled, so no other leak checks were 

necessary. All leak checks and leakage rates are documented on the relevant field 

test data sheet. In no case did any leak check exceed the acceptable limits. A more 

detailed description of the procedure and the acceptable limits may be found in the 

Test Protocol. 

Following the completion of each test run, the EPA Method 29 train sample was 

recovered. A detailed description of the sample recovery procedure may be found in 

the Test Protocol. 

The EPA Method 29 train produced the following sample fractions: 

1. Filter, 

2. Front-half 0.1N nitric acid rinse, 

3. Impingers 1 & 2 catch and 0.1N nitric acid rinse, 

4. Impinger 3 catch and 0.1N nitric acid rinse, 

5. Impingers 4 and 5 catch and acidified potassium permanganate rinse, and 

6. Impingers 4 and 5 8N HCl acid rinse. 

V.3.5 ASTM D 6784-02 Ontario Hydro Method (OHM) 

An ASTM D 6784-02 “Elemental, Oxidized, Particulate-bound and Total Mercury in 

Flue Gas (Ontario Hydro Method)” sample train was used to collect mercury on the 

effluent gas stream from the refinery furnace. 

The sample train configuration followed that of EPA Method 29 with the exception of 

the number of impingers (8) in the condensing/absorbing system, and the absorbing 

solutions contained in the each impinger. The condensing/absorbing system for the 

OHM sampling train was as follows: 

3⁄4 The first, second, and third impingers contained 100 milliliters of an 

aqueous 1N potassium chloride (KCl) solution. 

3⁄4 The fourth impinger contained an aqueous solution of 5% v

/v nitric acid 

(HNO3) and 10% v

/v hydrogen peroxide (H2O2). 

3⁄4 The fifth, sixth, and seventh impingers contained an aqueous solution of 

4% w/v potassium permanganate (KMnO4) and 10% v

/v sulfuric acid 

(H2SO4). 

3⁄4 The eighth impinger contained silica gel. 
Sampling and Analytical Procedures 

155233-0000 V-5 

A test series, consisting of three (3) OHM test runs, was performed on the refinery 

furnace. The sampling times for each test run followed the procedure present in 

Section V.3.4. 

Leak checks of the entire OHM sampling train were performed prior to and at the 

completion of each test run. At no point during any test run was any portion of the 

sample train disassembled and reassembled, so no other leak checks were 

necessary. All leak checks and leakage rates are documented on the relevant field 

test data sheet. In no case did any leak check exceed the acceptable limits. A more 

detailed description of the procedure and the acceptable limits may be found in the 

Test Protocol. 

The OHM sample train produced the following sample fractions: 

1. Filter, 

2. Front-half 0.1N nitric acid rinse, 

3. Impingers 1, 2 & 3 KCl Impinger Catch & Rinse, 

4. Impinger 4 - 0.1N HNO3 Impinger Catch & Rinse, 

5. Impingers 5 - 7 - KMnO4 Impinger Catch & Rinse. 

V.4 EPA Method 29 and ASTM D 6784-02 OHM Analytical Procedures - Mercury 

The recovered samples were digested according to the procedures detailed in the 

individual methods. Following the digestion the appropriate fractions were analyzed 

for mercury by cold vapor atomic absorption spectroscopy (CVAAS), SW-846 Method 

7470A. A complete analytical data package may be found in Appendix C. 
Summary of Results 

155233-0000 VI-1 

SECTION VI SUMMARY OF RESULTS 

The following tables present the results of the mercury sampling performed on the mercury 

retort system and the refinery furnace at the Coeur Rochester, Inc. Rochester mining 

facility, located east of Lovelock, Nevada. 

The following is a list of the tables presenting the test parameters and mercury emissions 

for both the mercury retort system and the refinery furnace/WESP. 

3⁄4 Table VI-1 Mercury Retort System Parameter Summary 

3⁄4 Table VI-2 Mercury Retort System Mercury Emission Summary 

3⁄4 Table VI-3 Refinery Furnace/WESP Parameter Summary – EPA Method 29 

3⁄4 Table VI-4 Refinery Furnace/WESP Mercury Emission Summary 

3⁄4 Table VI-5 Refinery Furnace/WESP Parameter Summary – OHM 

3⁄4 Table VI-6 Refinery Furnace/WESP Mercury Emission Summary - OHM 

3⁄4 Table VI-7 Mercury Retort System Removal Efficiency 
155233-0000 VI-1

Table VI-1 Mercury Retort System Parameter Summar

Mercury Retort System Sampling Data Summary Run 1 - 5 

EPA METHOD 29 

Run Number 1 2 3 4 

Run Date 3-Dec-07 4-Dec-07 

Run Times 0826-1032 1303-1507 1710-1915 0835-1040 11

SYMBOL UNITS 

Total Sampling Time min minutes 120 120 120 120 Stack Gas Oxygen Content O2 % 21.0 21.0 21.0 21.0 Stack Gas Carbon Dioxide Content CO2 % 0.0 0.0 0.0 0.0 Percent Moisture Bws % 2.34 3.29 3.24 3.38 Isokinetic Rate I % 97.75 97.39 95.62 95.44 

Vm(std) cu. ft. 80.159 75.694 77.373 95.560 9

Gas Sample Volume at Standard Conditions, cu. m. 2.269 2.143 2.190 2.705 

Vs ft/sec 14.78 14.67 15.25 18.30 

Stack Gas Velocity 

 m/sec 4.51 4.47 4.65 5.58 

Qsd dscf/min 60.8 57.6 60.0 74.3 

Dry Stack Gas Flow Rate (Dry, STP), dscm/min 1.72 1.63 1.70 2.10 
155233-0000 VI-2

Table VI-2 Mercury Retort System Mercury Emission Summ

Mercury Retort System Mercury Emission Summary Run 1 - 5 

EPA METHOD 29 

 Run Number 1 2 3 4 5  Run Date 3-Dec-07 4-Dec-07 

Run Times 0826-1032 1303-1507 1710-1915 0835-1040 1131-1341 

UNITS 

Mercury (Hg) - Particulate Bound mg 6.120 6.750 0.082 2.620 4.820 

 mg/m3 2.70E+00 3.15E+00 3.73E-02 1.96E+00 1.72E+00  lb/hr 6.14E-04 6.80E-04 8.37E-06 4.34E-04 3.74E-04 

Mercury (Hg) - Gaseous mg 3.421 2.906 0.169 12.695 13.062 

 mg/m3 1.51E+00 1.36E+00 7.69E-02 9.80E-01 8.04E-01  lb/hr 3.43E-04 2.93E-04 1.73E-05 2.18E-04 1.76E-04 

Mercury (Hg) - Total mg 9.541 9.656 0.250 15.315 17.882 

 mg/m3 4.2E+00 4.5E+00 1.1E-01 2.9E+00 2.5E+00  lb/hr 9.6E-04 9.7E-04 2.6E-05 6.5E-04 5.5E-04 
155233-0000 VI-3

Table VI-3 Refinery Furnace/WESP Parameter Summary – EPA 

Refinery Furnace WESP Sampling Data Summary Run 1 - 3 

EPA METHOD 29 

Run Number 1 2 3 

Run Date 5-Dec-07 

Run Times 0601 - 0809 0844 - 1027 1051 - 1234 

SYMBOL UNITS 

Total Sampling Time min minutes 120 96 96 Stack Gas Oxygen Content O2 % 12.5 12.5 12.5 Stack Gas Carbon Dioxide Content CO2 % 5.0 5.0 5.0 Percent Moisture Bws % 10.94 10.12 11.12 Isokinetic Rate I % 106.70 102.99 108.70 

Vm(std) cu. ft. 63.041 61.993 62.374 

Gas Sample Volume at Standard Conditions, 

 cu. m. 1.785 1.755 1.766 

Vs ft/sec 9.60 11.25 10.71 

Stack Gas Velocity 

 m/sec 2.93 3.43 3.26 

Qsd dscf/min 5,073.8 6,058.1 5,685.3 

Dry Stack Gas Flow Rate (Dry, STP), 

 dscm/min 143.6 171.5 161.0 
155233-0000 VI-4

Table VI-4 Refinery Furnace/WESP Mercury Emission Sum

 EPA Method 29 

Refinery Furnace WESP Mercury Emission Summary Run 1 - 3 

EPA METHOD 29 

Run Number 1 2 3 

Run Date 5-Dec-07 

Run Times 0601 - 0809 0844 - 1027 1051 - 1234 

UNITS A

Mercury (Hg) - Particulate Bound mg 0.052 0.034 0.030 

 mg/m3 2.91E-02 1.94E-02 1.71E-02 2 lb/hr 5.54E-04 4.40E-04 3.64E-04 4

Mercury (Hg) - Gaseous mg 42.320 8.078 7.004 

 mg/m3 2.37E+01 4.60E+00 3.97E+00 1 lb/hr 4.51E-01 1.04E-01 8.44E-02 2

Mercury (Hg) - Total mg 42.372 8.112 7.034 

 mg/m3 2.4E+01 4.6E+00 4.0E+00 1 lb/hr 4.5E-01 1.0E-01 8.5E-02 2
155233-0000 VI-5

Table VI-5 Refinery Furnace/WESP Parameter Summary – 

Refinery Furnace WESP Sampling Data Summary Run 1 - 3 

Ontario Hydro Method (OHM) 

Run Number 1 2 3 

Run Date 6-Dec-07 

Run Times 0601 - 0809 0844 - 1027 1051 - 1234 

SYMBOL UNITS 

Total Sampling Time min minutes 120 96 96 Stack Gas Oxygen Content O2 % 12.5 12.5 12.5 Stack Gas Carbon Dioxide Content CO2 % 5.2 5.1 5.2 Percent Moisture Bws % 9.16 8.82 9.53 Isokinetic Rate I % 108.59 101.91 102.35 

Vm(std) cu. ft. 61.220 66.884 64.341 

Gas Sample Volume at Standard Conditions, 

 cu. m. 1.733 1.893 1.822 

Vs ft/sec 8.20 11.58 11.22 

Stack Gas Velocity 

 m/sec 2.50 3.53 3.42 

Qsd dscf/min 4,450.9 6,351.6 6,083.8 

Dry Stack Gas Flow Rate (Dry, STP), 

 dscm/min 126.0 179.8 172.2 
155233-0000 VI-6

Table VI-6 Refinery Furnace/WESP Mercury Emission Summa

Refinery Furnace WESP Mercury Emission Summary Runs 1 - 3 

Ontario Hydro Method (OHM 

Run Number 1 2 3 

Run Date 6-Dec-07 

Run Times 0601 - 0809 0844 - 1027 1051 - 1234 

UNITS A

Mercury (Hg) - Particulate Bound mg 0.052 0.034 0.053 

 mg/m3 2.92E-02 1.79E-02 2.90E-02 2 lb/hr 4.87E-04 4.26E-04 6.60E-04 5

Mercury (Hg) - Gaseous mg 10.470 6.841 5.697 

 mg/m3 6.04E+00 3.61E+00 3.13E+00 4 lb/hr 1.01E-01 8.59E-02 7.13E-02 8

Mercury (Hg) - Total mg 10.521 6.875 5.750 

 mg/m3 6.1E+00 3.6E+00 3.2E+00 3 lb/hr 1.0E-01 8.6E-02 7.2E-02 8
155233-0000 VI-7

Table VI-7 Mercury Retort System Removal Efficiency 

Mercury Retort System Removal Efficiency Summary Runs 1 - 5 

EPA METHOD 29 

 Run Number 1 2 3 4 5  Run Date 3-Dec-07 4-Dec-07 

Run Times 0826-1032 1303-1507 1710-1915 0835-1040 1131-1341 

UNITS 

Mercury Concentration in Feedstock mg/kg 142,500 142,500 142,500 142,500 142,500 Total Feed (Retort 1 & 2) kg 4,119.5 4,119.5 4,119.5 4,119.5 4,119.5 Total Mercury Feed Rate mg 5.87E+08 5.87E+08 5.87E+08 5.87E+08 5.87E+08 Hourly Mercury Feed Rate (48 hour batch run) mg/hr 1.22E+07 1.22E+07 1.22E+07 1.22E+07 1.22E+07 Hourly Mercury Feed Rate (48 hour batch run) lb/hr 26.905 26.905 26.905 26.905 26.905 

Mercury (Hg) - Outlet Total lb/hr 9.58E-04 9.73E-04 2.57E-05 6.52E-04 5.50E-04 

 Removal Efficiency 

(lb/hr feed – lb/hr outlet) X100 

lb/hr feed 

% 99.9964 99.9964 99.9999 99.9976 99.9980 
Quality Assurance 

155233-0000 VII-1

SECTION VII QUALITY ASSURANCE 

VII.1 OVERVIEW 

This section highlights the specific QA/QC procedures that were followed on this test 

program and described in more detail in the Test Protocol. 

VII.2 FIELD QUALITY CONTROL SUMMARY 

VII.2.1 Calibration Procedures 

Calibrations of the field sampling equipment were performed prior to the field 

sampling effort. Copies of the calibration sheets are presented in Appendix D. 

VII.2.2 Equipment Leak Checks 

Prior to sampling, each M29 and OHM sampling train was leak-checked according to 

the procedures outlined in EPA Reference Method 5. During the course of a test run, 

a leak check was conducted before and after every test, or if replacement of a 

component became necessary. Both pre-test and post-test leak checks were 

performed All leakage rates were recorded on the appropriate field data sheet. 

All leakage rates were less than the allowable limit. 

VII.2.3 Cyclonic Flow Check 

The absence of cyclonic flow within the sampling location was verified prior to 

sampling in the mercury retort system. No cyclonic flow check was performed on the 

WESP since the stack configuration did not induce cyclonic flow. 

VII.2.4 Sample Handling Quality Assurance/Quality Control 

Shipping and Packing of Samples - All samples were transported to TRC’s Salt 

Lake City office for IATA packaging and shipment to Test America Laboratory, West 

Sacramento, California. The samples were shipped by over-night delivery service. 

Sample Traceability and Integrity – Traceability of all the samples were 

maintained using completed Chain of Custody forms. 

Sample integrity was maintained throughout the testing program by insuring that the 

samples were: 

3⁄4 In a person's physical possession, and/or 

3⁄4 In direct view of a person after acquiring possession, and/or 

3⁄4 Secured by a person in the field laboratory trailer. 

Labeling - Sample identification labels were used by TRC to ensure that the required 

information was affixed to every sample container. This information identified each 
Quality Assurance 

155233-0000 VII-2

container as to its sample type, test run, and sample fraction. When the sample 

batches were shipped, a sample-packing list accompanied the shipment. 

Integrity Seals - Integrity seals were used during shipping to detect unauthorized 

sample handling. The seal included, at a minimum, the date and time the shipping 

container was sealed along with the signature of the person who packed the 

containers. 

Chain-of-Custody Procedures - When the sampling trains were broken down and 

various samples recovered, the samples were recorded on the Chain-of-Custody 

Form. All chain-of-custody sheets are maintained by TRC. 

VII.3 DATA REDUCTION, VALIDATION, AND REPORTING 

Specific QC measures were used to ensure the generation of accurate and reliable data. 

VII.3.1 Field Data Reduction 

Appendix A contains copies of the raw field data. This collected data was reviewed in 

the field by the Field Team Leader. Any errors or discrepancies were corrected and 

initialed. An additional in-house review of the raw data was conducted. 

Appendix B contains the computer-generated calculation package. This package 

incorporates all the required raw data and calculations. The data collected was 

reviewed in the field by the Field Team Leader. Errors or discrepancies identified 

were noted on the field data sheet and in the field book. 

VII.3.2 Data Validation 

The following criterion were used to evaluate the field sampling data: 

3⁄4 Use of approved test procedures; 

3⁄4 Proper operation of the process being tested; 

3⁄4 Use of properly operating and calibrated equipment; 

3⁄4 Leak checks conducted before and after tests; 

3⁄4 Proper chain-of-custody maintained. 

The criterion listed below were used to evaluate the analytical data: 

3⁄4 Use of approved analytical procedures; 

3⁄4 Use of properly operating and calibrated instrumentation; 

3⁄4 Acceptable results from analyses of QC samples. 

VII.3.3 Data Reporting 

All data is reported in standard units depending on the measurement and the 

ultimate use of the data.