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 misi nterpreted by third persons or entities who were not involved in the investigative or consultation pr ocess. 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 

## D E V I A T I O N R E P O R T

The following presents a brief description of all deviations which occurred during the testing program at Coeur Rochester, Inc. cond ucted 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 througho ut 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 re sults are presented in this report. See
Section II.1.1 for a more detailed description of this deviation.

No additional devi ations 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 – O 2 

### and CO 2 

### 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 - Mercury V-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-2TABLE 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-3INTRODUCTION

155233-0000 I-1 

### SECTION I INTRODUCTION

I.1 Overview

Coeur Rochester, Inc. (CRI) operates the Ro chester and Nevada Packard precious metals mines and processing facilities in Pershing County, Nevada. The facility is located approximately 12 miles east of Interstate Hi ghway 80, Exit 119 in the Humboldt Range.
As a participant in the new Nevada Merc ury Control Program (NMCP), CRI performed mercury emission testing on th e 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 we re 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 sp eciation on the outlet of the WESP using the Ontario Hydro Method (OHM).

The project was under the direct ion 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 we re Ms. Cindy Jones, Processing Superintendent for Coeur Rocheste r, 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 conduc ted 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 load ed 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 temperat ure was ramped up to 400°F.

3⁄4 After maintaining at 400°F for 1-hour th e temperature was then ramped up to each retort’s operating temp erature (approximately 1200°F).

3⁄4 The retorts were held at their op erating 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 th e Nevada Division of Environmental Protection – Bureau of Air Pollution Contro l (NDEP-BAPC) requested that four (4) test runs be performed under the following schedule:

3⁄4 The first test run was initiated once bo th 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 s ooner 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 wa s 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, an d 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 glasswar e prior to the filter be cleaned and recovered into the front half recovery bottle. Following the cleaning of the filter assemblies’ front half, the recove ry 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 contacte d his superior and a mutual decision was made to conduct a fifth test run imme diately 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 Electr ostatic Precipitator (WESP) the next day (December 5, 2007). The following sub-section pr esents 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 hi gh-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 an d the WESP were turned off.
On December 5, 2007, the refinery furnac e was loaded with a total of 5033 dry pounds (2282.9 dry kilograms) of dry pr ecipitate. On December 6, 2007, the refinery furnace was loaded with 4989 dr y 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 furnac e/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 Me thod 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 Pack ard precious metals mines and processing facilities in Pershing County, Nevada. The mine administration and precious metals recovery complex is accessed by exiting Inters tate 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 th e Merrill-Crowe zinc precipitat e processing of conventional heap leach pregnant process solution. Refini ng 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 ar e controlled by a wet electrostatic precipitator (WESP) (see Figure III-2).PROCESS AND CONTROL EQUIPMENT SITE BACKGOUND155233-0000III-2Figure III-1 Coeur Rochester, Inc. – Mercury Retorts Process Flow DiagramCondensers (4)Vac. PumpCarbon Filters (2)From Filter PressTo Refinery FurnacesTo AtmosphereMercury Retorts (2)Liquid MercuryCollectedPROCESS 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 WESP VenturiSAMPLING LOCATION AND FREQUENCY

155233-0000 IV-1 

### SECTION IV SAMPLING LOCATION AND FREQUENCY

The following sub-sections present the samplin g 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 thou gh the common abatem ent 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 an d 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 modificati on to the sampling procedure was made. This modification is addressed in Section V.3.1. Follow EPA Method s 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) contro ls emissions from the refinery furnace. Sampling was performed in the re ctangular outlet stack position on the top of the WESP. Samples were collected through th ree (3) ports located along one side of the outlet stack. Prior to sampling, measurements of the outlet stack were made to determine the upstreamSAMPLING LOCATION AND FREQUENCY

155233-0000 IV-2 and downstream equivalent diam eters. This information can be found in Appendix A, (Traverse Point Location for Circular and Re ctangular 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 LocationSampling and Analytical Procedures

155233-0000 V-1 

### SECTION V SAMPLING AND ANALYTICAL PROCEDURES

This section describes the procedures that TR C 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 Traverse s 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 Emi ssions 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. Ea ch 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 calibra tion. Calibration of the equipment was conducted in accordance with the procedures out lined in EPA docu ments entitled " Quality
Assurance Handbook for Air Pollution Measur ement 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, whic h 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 HNO 3 solution.

6. Rinse glassware three times with DI wate r. 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 conj unction with the M29 and OHM sampling. For the refinery furnace, measurements were taken with an S-type Pitot, thermocouple and nozzle assembly in acco rdance 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 ve locity and temperature, readings were taken according to EPA Methods 1A and 2C. Both these methods cover procedures associated with small ducts. These method s 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 meas urements 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 directsSampling and Analytical Procedures

155233-0000 V-3 that flue gas velocity be me asured downstream of the ac tual 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 re finery furnace outlet stack.



### V.3.2 EPA Method 3 – O 2 

### and CO 2 

### Determination for Molecular Weight

Oxygen and carbon dioxide concentrations we re determined at each of the sampling locations. Sample gas was co llected 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-measurem ents of the mercury retort system, a Tedlar ® bag was filled with effluent gas from th e exhaust stack. An alysis 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 resultin g 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 anal yzer 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 r un 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 th e 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 efflue nt gas stream on both the mercury retort systems and the refinery furnace.
A series of five (5) EPA Method 29 sample s were collected on the mercury retort system and three (3) on the re finery furnace. The initial test run for each series of test was 120-minute. This was done to ev aluate 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 sufficien t 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 in dicated that the minimum sample volume requirement was achievable as long as the differential pressure ( Δ p) readings did not decrease. A decrease in the Δ p readings would directly affect the amount of sample volume that is collected . Anticipating that this decrease in Δ p might occur, a slightly large diameter nozzle was used for Runs 2 and 3. Sampling times for Runs 2 and 3 were de creased 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 reasse mbled, so no other leak checks were necessary. All leak checks and leakage ra tes 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 th e 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 sa mple 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 permanga nate 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 conden sing/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 imping ers contained 100 milliliters of an aqueous 1N potassium ch loride (KCl) solution.

3⁄4 The fourth impinger contained an aqueous solution of 5% v / v nitric acid (HNO 3 ) and 10% v / v hydrogen peroxide (H 2 O 2 ).

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

4% w / v potassium permanganate (KMnO 4 ) and 10% v / v sulfuric acid (H 2 SO 4 ).

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 te st 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 reassemble d, so no other leak checks were necessary. All leak checks and leakage ra tes 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 th e 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 HNO 3 Impinger Catch & Rinse, 5. Impingers 5 - 7 - KMnO 4 Impinger Catch & Rinse.



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

The recovered samples were digested acco rding to the procedures detailed in the individual methods. Follow ing the digestion the appropri ate fractions were analyzed for mercury by cold vapor atomic absorp tion 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 presenti ng 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 Syst em Mercury Emission Summary

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

3⁄4 Table VI-4 Refinery Furnace/WE SP 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 EfficiencySummary of Results155233-0000VI-1Table VI-1 Mercury Retort System Parameter SummaryMercury Retort System Sampling Data Summary Run 1 - 5EPA METHOD 29Run Number1 2 3 4 5Run Date3-Dec-07 4-Dec-07Run Times0826-1032 1303-1507 1710-1915 0835-1040 1131-1341SYMBOL UNITSTotal Sampling Time min minutes 120 120 120 120 120Stack Gas Oxygen Content O2 % 21.0 21.0 21.0 21.0 21.0Stack Gas Carbon DioxideContentCO2 % 0.0 0.0 0.0 0.0 0.0Average StdevPercent Moisture Bws % 2.34 3.29 3.24 3.38 3.18 3.09 0.42Isokinetic Rate I % 97.75 97.39 95.62 95.44 96.22 96.51 1.01Vm(std) cu. ft. 80.159 75.694 77.373 95.560 93.908 84.54 9.46Gas Sample Volume at StandardConditions,cu. m. 2.269 2.143 2.190 2.705 2.659 2.39 0.27Vs ft/sec 14.78 14.67 15.25 18.30 17.84 16.16 1.75Stack Gas Velocitym/sec 4.51 4.47 4.655.58 5.44 4.93 0.53Qsd dscf/min 60.8 57.6 60.0 74.3 72.4 65.01 7.66Dry Stack Gas Flow Rate(Dry, STP),dscm/min 1.72 1.63 1.70 2.10 2.05 1.84 0.22Summary of Results155233-0000VI-2Table VI-2 Mercury Retort System Mercury Emission SummaryMercury Retort System Mercury Emission Summary Run 1 - 5EPA METHOD 29Run Number1 2 3 4 5Run Date3-Dec-07 4-Dec-07Run Times0826-1032 1303-1507 1710-1915 0835-1040 1131-1341UNITSAverage StdevMercury (Hg) - Particulate Boundmg 6.120 6.750 0.082 2.620 4.820 4.08 2.74mg/m3 2.70E+00 3.15E+00 3.73E-021.96E+00 1.72E+001.91E+00 1.19E+00lb/hr 6.14E-04 6.80E-04 8.37E-064.34E-04 3.74E-044.22E-04 2.63E-04Mercury (Hg) - Gaseous mg 3.421 2.906 0.169 12.695 13.062 6.45 6.00mg/m3 1.51E+00 1.36E+00 7.69E-029.80E-01 8.04E-019.45E-01 5.61E-01lb/hr 3.43E-04 2.93E-04 1.73E-052.18E-04 1.76E-042.09E-04 1.25E-04Mercury (Hg) - Total mg 9.541 9.656 0.250 15.315 17.882 10.53 6.79mg/m3 4.2E+00 4.5E+00 1.1E-012.9E+00 2.5E+002.86E+00 1.7E+00lb/hr 9.6E-04 9.7E-04 2.6E-056.5E-04 5.5E-046.32E-04 3.9E-04Summary of Results155233-0000VI-3Table VI-3 Refinery Furnace/WESP Parameter Summary – EPA Method 29Refinery Furnace WESP Sampling Data Summary Run 1 - 3EPA METHOD 29Run Number1 2 3Run Date5-Dec-07Run Times0601 - 0809 0844 - 1027 1051 - 1234SYMBOL UNITSTotal Sampling Time min minutes 120 96 96Stack Gas Oxygen Content O2 % 12.5 12.5 12.5Stack Gas Carbon Dioxide Content CO2 % 5.0 5.0 5.0Average StdevPercent Moisture Bws % 10.94 10.12 11.12 10.73 0.53Isokinetic Rate I % 106.70 102.99 108.70 104.78 3.76Vm(std) cu. ft. 63.041 61.993 62.374 62.47 0.53Gas Sample Volume at Standard Conditions,cu. m. 1.785 1.755 1.766 1.77 0.02Vs ft/sec 9.60 11.25 10.71 10.60 0.85Stack Gas Velocitym/sec 2.93 3.43 3.26 3.23 0.26Qsd dscf/min 5,073.8 6,058.1 5,685.3 5649.00 500.37Dry Stack Gas Flow Rate (Dry, STP),dscm/min 143.6 171.5 161.0 159.92 14.17Summary of Results155233-0000VI-4Table VI-4 Refinery Furnace/WESP Mercury Emission SummaryEPA Method 29Refinery Furnace WESP Mercury Emission Summary Run 1 - 3EPA METHOD 29Run Number1 2 3Run Date5-Dec-07Run Times0601 - 0809 0844 - 1027 1051 - 1234UNITSAverage StdevMercury (Hg) - ParticulateBound mg 0.052 0.034 0.030 0.04 0.01mg/m3 2.91E-02 1.94E-021.71E-02 2.19E-02 6.39E-03lb/hr 5.54E-04 4.40E-043.64E-04 4.52E-04 9.54E-05Mercury (Hg) - Gaseous mg 42.320 8.078 7.004 19.13 20.09mg/m3 2.37E+01 4.60E+003.97E+00 1.08E+01 1.12E+01lb/hr 4.51E-01 1.04E-018.44E-02 2.13E-01 2.06E-01Mercury (Hg) - Total mg 42.372 8.112 7.034 19.17 20.10mg/m3 2.4E+01 4.6E+004.0E+00 1.08E+01 1.1E+01lb/hr 4.5E-01 1.0E-018.5E-02 2.14E-01 2.1E-01Summary of Results155233-0000VI-5Table VI-5 Refinery Furnace/WESP Parameter Summary – OHMRefinery Furnace WESP Sampling Data Summary Run 1 - 3Ontario Hydro Method (OHM)Run Number1 2 3Run Date6-Dec-07Run Times0601 - 0809 0844 - 1027 1051 - 1234SYMBOL UNITSTotal Sampling Time min minutes 120 96 96Stack Gas Oxygen Content O2 % 12.5 12.5 12.5Stack Gas Carbon Dioxide Content CO2 % 5.2 5.1 5.2Average StdevPercent Moisture Bws % 9.16 8.82 9.53 9.17 0.35Isokinetic Rate I % 108.59 101.91 102.35 104.29 3.74Vm(std) cu. ft. 61.220 66.884 64.341 64.148 2.84Gas Sample Volume at Standard Conditions,cu. m. 1.733 1.893 1.822 1.82 0.08Vs ft/sec 8.20 11.58 11.22 10.33 1.86Stack Gas Velocitym/sec 2.50 3.53 3.42 3.15 0.57Qsd dscf/min 4,450.9 6,351.6 6,083.8 5,628.8 1028.8Dry Stack Gas Flow Rate (Dry, STP),dscm/min 126.0 179.8 172.2 159.35 29.13Summary of Results155233-0000VI-6Table VI-6 Refinery Furnace/WESP Mercury Emission Summary - OHMRefinery Furnace WESP MercuryEmission Summary Runs 1 - 3Ontario Hydro Method (OHMRun Number1 2 3Run Date6-Dec-07Run Times0601 - 0809 0844 - 1027 1051 - 1234UNITSAverage StdevMercury (Hg) - ParticulateBound mg 0.052 0.034 0.053 0.05 0.01mg/m3 2.92E-02 1.79E-022.90E-02 2.54E-02 6.46E-03lb/hr 4.87E-04 4.26E-046.60E-04 5.24E-04 1.22E-04Mercury (Hg) - Gaseous mg 10.470 6.841 5.697 7.67 2.49mg/m3 6.04E+00 3.61E+003.13E+00 4.26E+00 1.56E+00lb/hr 1.01E-01 8.59E-027.13E-02 8.60E-02 1.47E-02Mercury (Hg) - Total mg 10.521 6.875 5.750 7.72 2.49mg/m3 6.1E+00 3.6E+003.2E+00 3.28E+00 1.6E+00lb/hr 1.0E-01 8.6E-027.2E-02 8.65E-02 1.5E-02Summary of Results155233-0000VI-7Table VI-7 Mercury Retort System Removal EfficiencyMercury Retort System Removal Efficiency Summary Runs 1 - 5EPA METHOD 29Run Number1 2 3 4 5Run Date3-Dec-07 4-Dec-07Run Times0826-1032 1303-1507 1710-1915 0835-1040 1131-1341UNITSAverage StdevMercury Concentration inFeedstockmg/kg 142,500 142,500 142,500 142,500 142,500 142,500Total Feed (Retort 1 & 2) kg 4,119.5 4,119.5 4,119.5 4,119.5 4,119.5 4,119.5Total Mercury Feed Rate mg 5.87E+08 5.87E+08 5.87E+08 5.87E+085.87E+08 5.87E+08Hourly Mercury Feed Rate(48 hour batch run)mg/hr 1.22E+07 1.22E+07 1.22E+07 1.22E+07 1.22E+07 1.22E+07Hourly Mercury Feed Rate(48 hour batch run)lb/hr 26.905 26.905 26.905 26.905 26.905 26.905Mercury (Hg) - Outlet Total lb/hr 9.58E-049.73E-04 2.57E-05 6.52E-04 5.50E-04 6.32E-04 0.0004Removal Efficiency(lb/hr feed – lb/hr outlet)X100lb/hr feed%99.9964 99.9964 99.9999 99.9976 99.9980 99.9977 0.0014Quality Assurance

155233-0000 VII-1 

### SECTION VII QUALITY ASSURANCE

VII.1 OVERVIEW

This section highlights the specific QA/QC pr ocedures 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 equipm ent 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 sampli ng 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 af ter every test, or if replacement of a component became necessary. Both pre- test and post-test leak checks were performed All leakage rates were record ed 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 configuratio n 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 sh ipment 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 af ter 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 eachQuality Assurance

155233-0000 VII-2 container as to its sample type, test run, and sample fraction . When the sample batches were shipped, a sample-pac king 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 an d time the shipping container was sealed along with the signature of th e person who packed the
containers.

Chain-of-Custody Procedures - When the sampling trains were broken down and various samples recovered, the samples we re recorded on the Chain-of-Custody Form. All chain-of-custody sh eets 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 co llected data was reviewed in the field by the Field Team Leader. Any e rrors or discrepancies were corrected and initialed. An additional in-house review of the raw data was conducted.
Appendix B contains the computer-generat ed 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.