## Environmental solutions delivered uncommonly well 

# ROOFLINE STUDY Freeport-McMoRan Miami Inc. – Miami Smelter

Prepared	By:

Trinity Consultants 1661	E.	Camelback	Rd. Phoenix,	AZ	85016 (602)	274‐2900

Freeport

‐ McMoRan Miami Inc
PO	Box	4444 Claypool,	AZ	85532 (928)	473‐7149

November	2013Freeport-McMoRan Miami Inc. | Roofline Study Trinity Consultants i 

## TABLE OF CONTENTS

1. EXECUTIVE SUMMARY & BACKGROUND 1-1

2. PRE-FEASIBILITY AND FEASIBILITY STUDIES 2-1

3. DESIGN OF EXPERIMENT 3-1
3.1. SO 2 Sampling

............................................................................................................................... ............................ 3

‐ 3 3.2. Flow Readings

............................................................................................................................... .......................... 3

‐ 3 3.3. Temperature

............................................................................................................................... ............................ 3

‐ 3 3.4. Open Areas Along the Converter Aisle and Anode Area

............................................................................ 3

‐ 3



### 4. SO 2 

### EMISSION CALCULATION METHODOLOGY 4-1

5. RESULTS 5-1
5.1. Overall Sampling Results

............................................................................................................................... ..... 5

‐ 1 5.2. Anode Area Test Results........................................................................................................................

.............. 5

‐ 2 5.3. Converter Aisle Test Results

.............................................................................................................................. 5

‐ 3 5.4. Isa Test Results

............................................................................................................................... ........................ 5

‐ 4 5.5. Electric Furnace Test Results........................................................................................................................

..... 5

‐ 5 5.6. Average SO 2 , Temperature, and Wind Speed Results

................................................................................ 5

‐ 6



### 6. CONCLUSION 6-1Freeport-McMoRan Miami Inc. | Roofline Study Trinity Consultants ii 

## LIST OF FIGURES

Figure	1‐1.		Annual	Smelter	SO 2 Fugitive	Emissions	(Calculated	via	Sulfur	Balance	Methodology) 1‐2

Figure	3‐1.		Gas	Sampling	Locati ons	for	the	Miam i	Smelter	 3‐2

Figure	3‐2.		Miami	Smelter	–	Diagram	of	Non‐Monitored	Open	Area s	(Northwest	to	Southeast	View)	 3‐4

Figure	4‐1.		Sampling	System 4‐1Freeport-McMoRan Miami Inc. | Roofline Study Trinity Consultants iii 

## LIST OF TABLES

Table	1‐1.		Concentrate	Throughpu t	with	Corresponding	Fugitive SO 2 Emissions	 1‐2

Table	3‐1.		Gas	Sampling	Date s	and	Parameters	Measured	 3‐3

Table	4‐1.		Adjustment	Factors	for	SO 2 Emission	Calculations	 4‐2

Table	5‐1.		Average	Study Sampling	Results	 5‐1

Table	5‐3.		Anode	Area	Sampling	Results	 5‐2

Table	5‐4.		Converter	Ais le	Sampling	Results	 5‐3

Table	5‐5.		Isa	Sampling	Results 5‐4

Table	5‐6.		Electric	Furn ace	Sampling	Results	 5‐5

Table	5‐7.		Average	SO 2 ,	Temperature,	and	Wind	Sp eed	Sampling	Results	 5‐6Freeport-McMoRan Miami Inc. | Roofline Study Trinity Consultants 1-1 

## 1. EXECUTIVE SUMMARY & BACKGROUND

Freeport‐McMoRan	Miami	Inc.	(FMMI )	owns	and	operates	a	copper	s melting	facility	in	Clay pool,	Arizona	(Miami Smelter).		Operations	at	the	Mia mi	Smelter	are	authorized	pursu ant	to	Arizona	Departm ent	of	Environmental Quality	(ADEQ)	Class	I	Air	Qual ity	Permit	53592,	issued	on	Nove mber	26,	2012.		Attachment	“B”	Condition (VI)(B)(2)	of	this	permit	requi res	FMMI	to	determine	smelter	fu gitive	sulfur	dioxide	(SO 2 )	emissions	on	a monthly	basis	using	the	“sulfur balance”	(or	sulfur	mass	balanc e)	procedures	prescribed	in	Attachment	“D”	of the	permit	and	the	Arizona	State Implementation	Plan	(SIP).		Th e	following	report	detail s	the	motivation	behind FMMI’s	investigation	into	an	alt ernative	methodology	to	determi ne	smelter	fugitive	SO 2 emissions,	the	design	of a	short‐term	testing	protocol	to quantify	these	emissions,	and the	test	results.

In	2010,	the	U.S.	Environmental	P rotection	Agency	(EPA)	finaliz ed	a	revision	to	the	pri mary	National	Ambient Air	Quality	Standard	(NAAQS)	for	SO 2 to	75	parts	per	bill ion	(ppb)	based	on	a 1‐hour	averaging	peri od.		Prior	to this	revision,	the	primary	SO 2 NAAQS	was	140	ppb	averaged	over 24‐hours	and	30	ppb	evaluated over	an	entire year.		A	secondary	NAAQS	of	150 ppb	based	on	a	3‐hour	average	r emained	unchanged.		F MMI	operations	were in	compliance	with	the	prior	sta ndards	and	the	Miami	Planning	A rea	was	designated	as	“Attainment”	for	SO 2

. However,	given	the	stringent	new standard	and	existing	ambient monitoring	data,	the	Miami	planning	area	has been	designated	“Nonattainment”	for	the	revised	SO 2 NAAQS.

FMMI	engaged	Hatch	Engineering	(Ha tch)	to	perform	a	Pre‐Feasibi lity	Study	and	subsequently	a	Feasibility Study	to	determine	if	FMMI	coul d	modify	smelter	operations	so	t hat	ambient	SO 2 levels	would	meet	the	revised standard	at	current	an d	possibly	increased smelter	throughput. The	goal	of	the	modifications	would	be	to reduce	SO 2 emissions	from	both	stacks	and	from	fugitive	sources.

FMMI	evaluated	its	past	SO 2 emissions	from	its	Emissions	In ventory	Reports	to	ADEQ,	prepar ed	as	set	forth	in FMMI’s	Class	I	Air	Quality	Permit .		During	the	evaluation,	FMMI determined	the	SO 2 stack	emissions	were	well defined,	primarily	because	FMMI	u ses	continuous	e missions	monit oring	(CEMS)	to	measu re	them.		However,	the
SO 2 fugitive	emissions	w ere	calculated	using	t he	sulfur	balance.		T he	sulfur	balance	estima tes	fugitive	emissions by	quantifying	the	amount	of	sulfur	introduced	into	the	system (in	copper	concentrate	f eed	and	fuels)	and	that which	exits	the	system	(including,	but	not	limited	to,	sulfuric acid,	anode	copper	produced,	and	slag).

A	review	of	the	sulfur	balance	da ta	indicated	wide	variability in	the	fugitive	SO 2 emitted	from	the	smelter. Figure	1‐1	demonstrates	thi s	variability	in	smelter	SO 2 fugitive	emissions	calculated	via	the	sulfur	balance methodology	between	2005	and	2012.Freeport-McMoRan Miami Inc. | Roofline Study Trinity Consultants 1-2 Figure 1

‐ 1. Annual Smelter SO 2 Fugitive Emissions (Calculated via Sulfur Balance Methodology)

To	put	the	emissions	variability in	context,	the	concentrate	th roughputs	for	the	2005	to 2012	operating	years are	presented	in	Table	1‐1,	whic h	indicate	a	large	variability in	fugitive	emissions	compared	to	consistent	feed rates	for	six	of	the	eight	operating	years	presented.

Table 1

‐ 1. Concentrate Throughput with Corresponding Fugitive SO 2 Emissions

Year Concentrate Fugitive
Emissions (tpy) (tpy)
2005	 677,537	 6,089
2006	 680,645	 4,623 2007	 804,075	 6,858
2008	 792,813	 4,832 2009	 672,216	 2,659
2010	 688,827	 8,473 2011	 693,595	 8,460 2012	 689,775	 1,212 0 1,000 2,000 3,000 4,000 5,000 6,000 7,000 8,000 9,000

2005 2006 2007 2008 2009 2010 2011 2012SO2Emissions(st/y)

Fugitive SourcesFreeport-McMoRan Miami Inc. | Roofline Study Trinity Consultants 2-1 

## 2. PRE-FEASIBILITY AND FEASIBILITY STUDIES

FMMI	engaged	Hatch	to	perform	a Pre‐Feasibility	Study	(PFS)	to evaluate	whether	the Miami	Smelter	could modify	smelter	operations	so	that	ambient	SO 2 levels	would	meet	the	revised	N AAQS.		During	the	PFS,	Hatch evaluated	each	emission	source	to determine	whether	a	given	sou rce	was	a	candidate	fo r	improvement.		Hatch then	evaluated	and	selected	the appropriate	control	technology to	ensure	future	emi ssions	met	the	NAAQS standards.		Due	to	a	lack	of	direc t	monitoring	data	for	fugitiv e	emissions,	Hatch	based	its	evaluation	on	FMMI’s 2010	Emissions	Inventory	submitte d	to	ADEQ.		The	use	of	2010	da ta	represented	the	wo rst	case	fugitive emissions	based	on	the	sul fur	balance	methodology.

Due	to	concerns	with	the	var iability	of	emissions	for	SO 2 using	the	sulfur	balance,	FMMI	requested	Hatch	to develop	a	fugitive	sam pling	protocol	and	perform	testing	to	ver ify	the	fugitive	emissions.		The	goal	of	the	study would	be	to	provide	a	more	accu rate	emissions	estimate	and	allo w	for	the	proper	sizing	of the	roofline	collection and	scrubbing	system.		Hatch’s	pro tocol	proposed	to	establish	r oofline	SO 2 emissions,	temperature	profiles,	and gas	flow	rates.

Roofline	SO 2 emission	testing	occurred	from	Ju ne	3	to	June	12, 2012	during a	period	of	normal	operations. Hatch	teamed	with	AECOM	(Ft.	Co llins,	CO)	to	perform	the	testin g.		AECOM	was	selected	based	on	their familiarity	with	FMMI’s	operations.Freeport-McMoRan Miami Inc. | Roofline Study Trinity Consultants 3-1 

## 3. DESIGN OF EXPERIMENT

The	protocol	developed	by	Hatch used	a	series	of	gas	sample	pro bes	and	instrumentatio n	to	directly	measure the	parameters	of	interest	for	th e	four	major	operating	areas	a t	the	smelter	th at	have	fugitive emissions	(Isa Building,	Electric	Furnace	Build ing,	Converter	Aisle,	and	Anode Area). 1 Each	operating	area	had	probes	and instrumentation	placed	at	multip le	locations	to	ensure	an	accur ate	assessment	of	emission s.		In	some	locations, multiple	the	probes	and	instrume nts	were	placed	a s	a	single	uni t.		In	other	locations, individual	probes	or instrumentation	(primarily	therm ocouples)	were	placed	to	allow the	measurement	of	the	selected	parameter. The	system	was	designed	to	measu re	gas	flow	rates,	temperature, and	SO 2 concentration	for	the	calculation	of
SO 2 emissions	from	each	operating	ar ea.		Figure	3‐1	depicts	the	pla cement	of	sample	probes	and instrumentation	in	each	of	the	o perating	areas.		Table	3‐1	list s	the	sampling	dates	and parameters	measured	in each	area.

1 Note that a flow rate test was also conduc ted at the “Crane Bay” to validate the flow rates being used for purposes of executin g a Computational Fluid Dynamics (C FD) modeling analysis for the Miami smelter. This test was not performed to determine SO2 emissions from the “Crane Bay.” Any SO2 emissions from that ar ea are incidental and accounted for in the adjustment factors discussed in this report.Freeport-McMoRan Miami Inc.|Roofline StudyTrinity Consultants3-2Figure3‐1.GasSamplingLocationsfortheMiamiSmelterMeasuredthroughgapbetweenmonitor&rooflinea1a2a3a4c1i1c2c3c4i2i3e1e2Measuredthroughgapbetweenmonitorandrooflinee3Measurementstobetakeninsidethebuilding,behindlouvers.ApproximateSWENMeasuredinopeningi3Measuredinopeningi1Measuredbelowtheridgeventi2Legende1‐e3:	Electric	Furnacei1‐i3:	Isaa1‐a4:	Anode	Areac1‐c4:	Converter	AisleFreeport-McMoRan Miami Inc. | Roofline Study Trinity Consultants 3-3 Table 3

‐ 1. Gas Sampling Dates and Parameters Measured

Number of Measurements
Area Dates Gas Velocity SO 2 Concentration Temperature Converter	Aisle	 June	3	to	6,	2012	 4	 4	 7

Anode	Area	 June	3	to	6,	2012	 4	 4	 11 Isa	Building	 June	10	to	12,	2012	 3	 3	 3 Electric	Furnace	Building	 June	10	to	12,	2012	 3	 3	 3

The	following	is	a	discussion of	the	parameters	measured.



### 3.1. SO 2 

### SAMPLING

Collection	of	SO 2 was	accomplished	using	1⁄2	inch	st ainless	steel	probes	placed	at the	building	opening	locations shown	in	Figure	3‐1.		The	SO 2 sample	was	collected	through	the use	of	a	vacuum	pump	drawing 1	liter	per minute	of	sample	from	each	probe .		Each	probe	contained	a	filte r	to	prevent	the	sample lines	from	becoming blocked.		The	sample	lines	for	a specific	locati on	were	manifol ded	into	a	single	sample	line	and	routed	to	a	CEMS for	the	duration	of	th e	test	program.		AECOM	used	Ametek	CEMS	t o	measure	SO 2 (Range:	0	to	2,000	ppm).		The CEMS	were	calibrated	daily	for	z ero	(clean)	air	a nd	full	span	( approximately	1,800	ppm	SO 2 )	using	certified calibration	gasses.		Readings	fr om	the	CEMS	were	taken	every	15 seconds,	averaged	every	2	minutes,	and recorded.		The	data	were	then	dow nloaded	and	sent	to	Hatch	for analysis.



### 3.2. FLOW READINGS

In	locations	where	anem ometers	could	be	plac ed,	the	study	used RM	Young	Gill	Prope ller	Anemometers	to measure	the	exhaust	sp eed	(in	feet	per	seco nd).		In	locations	w here	fixed	anemometers	c ould	not	be	used	full time	due	to	elevated	temperature s	at	the	Anode	Area,	a	hot	wire anemometer	was	used	to	collect	the	exhaust speed.		Flows	(in	act ual	cubic	feet	per	mi nute)	were	then	calcu lated	using	the	source	o pening	size	and	then converted	to	standard	cubic	feet per	minute	(scfm)	by	correctin g	the	flows	using	the gas	temperature	and barometric	pressure.



### 3.3. TEMPERATURE

Temperatures	were	recorded	by	using Type	J	thermoc ouples	which were	placed	at	multiple	locations throughout	the	operating	areas.		The	sampling	protocol	used	add itional	thermocouples	a cross	the	facility.



### 3.4. OPEN AREAS ALONG THE CONV ERTER AISLE AND ANODE AREA

It	should	be	noted	that	there	are several	openings along	the	co nverter	aisle	and	anod e	area	which	were	not actively	monitored	for	SO 2 because	analyses	indicated	emi ssions	do	not	escape	from	them. There	are	openings at	the	end	walls	located	on	the west	and	east	sections	of	the	M iami	Smelter	which	pr ovide	access	to	the Converter	Aisle	for	vehicles.		T here	is	also	an	opening	to	the south	of	the	Mold	Barrel and	on	the	north	wall behind	each	converter.		Figure	3‐ 2	provides	a	depiction	of	thes e	open	areas.Freeport-McMoRan Miami Inc. | Roofline Study Trinity Consultants 3-4 Figure 3

‐ 2. Miami Smelter

– Diagram of Non

‐ Monitored Open Areas (Northwest to Southeast View)

Air	flow	measurements were	taken	during	the	testing	and	indicat ed	that	flows	for	thes e	areas	were	from	the outside	of	the	building	inward. The	areas	that	are	currently	o pen	in	Figure	3‐2	are	th e	medium	blue	and	light green	areas.		Light	green	indicat es	sections	that	FMMI	will	enc lose	in	the	expansion.		Blue indicates	that	the	area will	remain	open.		Red indicates	that	the	r oofline	will	be	encl osed	in	the	future	for	r oofline	monitoring.		The lower	open	areas	are	necessary	to allow	for	ventilation	air	int ake	for	the	fu ture	scrubber.

Only	during	specific	high‐wind	c onditions	(greate r	than	10	m/s) where	air	flow s	strike	the	build ing	will	there	be cross	flows	that	could result	in	emissions escaping	from	the	ea st	to	west	and	west	to	east. It	is	important	to	note that	these	high‐wind	conditions occur	during	less	than	2.5%	of the	annual	smelter	operat ing	time.		In	addition, high‐wind	conditions	at	the	east end	of	the	Converter	Aisle	(ea st‐southeast	to	west‐northwest	wind	flow,	78.75 to	123.75°	wind	direction ),	where	there	is	no shielding	provide d	by	geographic	or	engin eered	structures,	occur during	less	than	0.12%	of	the	a nnual	smelter	operating	time.		D ue	to	shielding,	the	southern	opening	is protected	from	most	adverse	wind conditions.		Furthermore,	the west	end	of	the	Converter Aisle	is	below	grade of	the	acid	plant	which	provides for	some	shielding	of	winds	fr om	the	west.		High‐wind	conditions	at	the	west end	of	the	Converter	Aisle	(west ‐northwest	to	east‐southeast	wi nd	flow,	258.75	to	303.75°	wind	direction) occur	during	less	than 0.02%	of	the	annual smelter	operating	ti me.		For	the	impact	of	winds	from	the	north,	the emissions	would	blow	a cross	the	aisl e	and	primarily	affect	emis sions	from	the	mold	vesse l.		Emissions	from	the converters	during	the	winds	origi nating	from	the	north	would	ei ther	impact	internal	wa lls	and	be	deflected upwards	to	the	roof	openings,	w hich	were	monitored ,	or	exit	the openings	through	the	Is a	or	Electric	Furnace buildings,	which	w ere	also	monitored.

It	should	also	be	noted	that	emi ssions	from	the	converters,	mol d	vessel	and	anode	vessels	are	elevated approximately	25	feet	above	the	g round	and	are	located	signific antly	inside	the	building	from	the	east	and	westFreeport-McMoRan Miami Inc. | Roofline Study Trinity Consultants 3-5 openings	(approximately	80	to	100 feet	inside	the	building).		T he	east	and	west	openings	are	approximately	35 feet	high.

Therefore,	due	to	the	negligible emissions	from	these	areas	und er	normal	operating	condi tions,	these	sources were	not	actively	monitored	for	SO 2

.Freeport-McMoRan Miami Inc. | Roofline Study Trinity Consultants 4-1 

## 4. SO 2 

## EMISSION CALCULATION METHODOLOGY

Locations	for	SO 2 measurement,	as	shown	in	Figure 3‐1	were	selected	to	be	repres entative	of	average	SO 2 concentrations	for	each	operatin g	area	and	thus	provided	a	repr esentative	analysis	of	the total	smelter	fugitive emissions.		Concentrations	of	SO 2 were	reported	in	2	minute	inter vals,	reflective	of	the	duratio n	of	operating activities	such	as	transfers.		A ll	data	points	recorded	during calibrations,	as	indicated by	AECOM,	were	removed from	the	data	set	reported	and	n ot	used	in	the	analysis.		Relev ant	apparatus	components are	shown	in	Figure 4‐1	for	reference.

Figure 4

‐ 1. Sampling System

Emissions	of	SO 2 were	calculated	for	each	operat ing	area	from	total	gas	flows	a nd	SO 2 concentration.		An adjustment	factor	was	applied	wh en	calculating	mass	emissions	o f	SO 2 (lb/hr)	to	account	for	the	fact	that	all sample	locations	in	a	given	oper ating	area	are	sent	to	a	single analyzer.		As	the	sample rate	from	each	sample location	within	an	operating	are a	is	not	increased	with	increas ed	gas	flow	(typically	due to	increased	activity and	associated	emissions),	sample locations	with	high	gas	flow may	be	underweighted	in the	calculation	of average	concentration	of	SO 2 in	building	ventilation.		The	a djustment	factor	assumes	that	S O 2 concentrations increase	linearly	with	gas	flow. This	is	considered	reasonably conservative.		The	avera ge	adjustment	factors applied	are	listed	in	Table	4‐1, where	a	factor	of	1	represents no	adjustment	and	reflect s	perfectly	uniform	gas flow.Freeport-McMoRan Miami Inc. | Roofline Study Trinity Consultants 4-2 Table 4

‐ 1. Adjustment Factors for SO 2 Emission Calculations

Area Adjustment Factor
Converter	Aisle	 1.05
Anode	Aisle	 1.24 Isa	Building	 1.18
Electric	Furnace	 1.02

It	should	be	noted	that	the	adju stment	factor	for	the	Anode	Ais le	area	conservatively	incorporates	any	SO 2 emissions	that	may	res ult	from	carryover	into	the	Crane	Bay	Are a	in	addition	to	accounting	for	the	fact	that	all sample	locations	in	the	area	are	sent	to	a	single	analyzer,	as discussed	in	Section	5.2.Freeport-McMoRan Miami Inc. | Roofline Study Trinity Consultants 5-1 

## 5. RESULTS

5.1. OVERALL SAMPLING RESULTS

A	summary	of	gas	sampling	results are	presented	in	this	section .		Table	5‐1	summarizes	the	average	results	of the	sampling	campaign	as	well	as	the	SO 2 emission	rate	following	the	application	of	the	adjustment	fact or discussed	in	Section	4.		Note	th at	all	parameters	contained	in Table	5‐1	are	an	average	o f	the	sample	population for	illustration	purposes.		Note that	due	to	the	short	duration of	the	measurement	freq uency	(in	minutes),	the average	values	may	not	adequatel y	describe	the	true	value	of	th e	parameter	(which	i s	more	adequately represented	using	the	99 th percentile	of	the	sampling	population).

Table 5

‐ 1. Average Study Sampling Results

Operating Area Gas Flow Gas Flow Gas Temperature
Rise Gas Temperature Rise

(99 th Percentile) Adjusted SO 2 Emissions (acfm) (scfm) (°F) (°F) (lb/hr) Anode	Area	 548,800	 403,700 84.8 168.3	 43.5 Converter	Aisle	 767,300	 619,400 30.4 72.3	 123.3

Isa	Buildin g 225,900	 182,900 27.0 68.0	 57.0 Electric	Furnace Buildin g 186,100	 147,300 39.4 80.4	 9.1

T

ota l 1, 7 28,000 1,353,300 4 7

. 0 97.3 2 33

The	following	is	a	discussion	of	the	specific,	actively	monitor ed	operating	areas.Freeport-McMoRan Miami Inc. | Roofline Study Trinity Consultants 5-2 

### 5.2. ANODE AREA TEST RESULTS

A	total	of	three	sample	runs	w ere	performed	at	the	Anode	Area	o perating	area	from	June 4	through	6,	2012.		The samples	were	collected	over	a 480‐minute	period	at	three	locati ons	along	the	roof	monitor using	a	single	sample point	in	the	center	of	the	monit or	area.		The	average	of	the	re corded	test	parameters,	including	stack temperature,	meter	temperature, and	pressure	for	the	three	Anod e	sample	runs	are	provid ed	in	Table	5‐2.		Also included	in	this	table	are	calcul ations	of	effluent	molecular	w eight	(wet	and	dry)	an d	moisture	content.		In addition,	the	average	SO 2 concentration,	temperature	(°C) and	flow	rate	(m/s)	measured	d uring	the	test	run	are listed.		For	all	operating	areas,	SO 2 concentrations	were	converted	to emission	rates	using	the	foll owing methodology: ൬ ݁ݐܴܽ	݊݋݅ݏݏ݉݅ܧ ݈ܾ
ݎ݄ ൬ ݁ݐܴܽ	ݓ݋݈ܨ	݈݋ܸ ൌ ൰ ݂ܿݏ

݉݅݊ ൈ ൰ ݐݎܽ݌	1

10 ଺ ݏݐݎܽ݌ ൈ 60	݉݅݊
ݎ݄ ൈ ݈݋݉ ݂ܿݏ	385 ൈ 64	݈ܾ
݈݋݉

Table 5

‐ 2. Anode Area Sampling Results

Test Parameters A2

‐ 1 A3

‐ 1 A4

‐ 1

Average 06/04/31 06/05/12 06/06/12 0610

‐ 1410 1100

‐ 1900 0800

‐ 1600 Sample	Time	(min)	 480	 480	 480	 480

Vol	meter	(acf)	 214.447	 210.652	 229.866	 218.322 Ave.	SQRT	dP	(in	WC)1/2	 0.17	 0.17	 0.17	 0.17 dH	(in	WC)	 0.48	 0.48	 0.56	 0.51 T	stack	(F)	 142.6	 192.0	 179.3	 171.3 T	meter	(F)	 101.1	 106.9	 118.3	 108.8 P	static	(in	WC)	 0.01	 0.01	 0.01	 0.01

P	bar	(in	Hg)	 26.30	 26.25	 26.20	 26.25 P	stack	(in	WC)	 26.30	 26.25	 26.20	 26.25
H 2 O	Mass	Gain	(g)	 25.90	 60.10	 34.70	 40.23

Yd	(meter	coef.)	 0.970	 0.970	 0.970	 0.970

dH	@	(in	WC)	 1.857	 1.857	 1.857	 1.857 Cp	(pitot	coef.)	 0.84	 0.84	 0.84	 0.84 Dia	stack	(in)	 NA	 NA	 NA	 NA Dia	nozzle	(in)	 0.358	 0.358	 0.358	 0.358 CO 2 (%)	 0.00	 0.00	 0.00	 0.00 O 2 (%)	 20.90	 20.90	 20.90	 20.90 Vol	meter	(dscf)	 172.162	 167.055	 178.386	 172.534 Md	(lb/lb‐mole)	 28.84	 28.84	 28.84	 28.84 Ms	(lb/lb‐mole)	 28.76	 28.66	 28.74	 28.72 Vwc	 1.22	 2.83	 1.63	 1.89 H 2 O	(%)	 0.7	 1.7	 0.9	 1.1 ISO	(%)	 100.8	 102.6	 107.9	 103.8
SO 2 Results
SO 2 (ppm)	 0.8	 6.2	 10.5	 5.8 SO 2 (lb/hr)	 0.00	 0.00	 0.00	 0.00 Meteorological	Results Temp	(°C)	 61.3	 85.3	 81.0	 75.9 Flow	Rate	(m/s)	 1.33	 1.88	 2.17	 1.79Freeport-McMoRan Miami Inc. | Roofline Study Trinity Consultants 5-3 

### 5.3. CONVERTER AISLE TEST RESULTS

A	total	of	four	sample	runs	were performed	at	the	Converter	Ais le	operating	area	from	J une	3	through	6,	2012. The	samples	were	collected	over a	480‐minute	period	at	four	loc ations	along	the	roof	monitor	using	a	single sample	point	in	the	center	area	o f	the	monitor.		The	average	of the	recorded	parameters,	including	stack temperature,	meter	temperature, and	pressure	for	the	four	Conve rter	sample	runs	are	pr ovided	in	Table	5‐3. Also	included	in	this	table	are calculations	of	effluent	molecu lar	weight	(wet	and	dry)	and	moisture	content.		In addition,	the	average	SO 2 concentration,	temperature	(°C) and	flow	rate	(m/s)	measured	d uring	the	test	run	are listed.

Table 5

‐ 3. Converter Aisle Sampling Results

Test Parameters C1

‐ 1 C2

‐ 1 C3

‐ 1 C4

‐ 1

Average 06/03/31 06/04/31 06/05/31 06/06/31 0553

‐ 1353 0556

‐ 1356 0801

‐ 1601 0825

‐ 1625 Sample	Time	(min)	 480	 480	 480	 480	 480

Vol	meter	(acf)	 220.655	 218.772	 220.043	 253.861	 228.333 Ave.	SQRT	dP	(in	WC)1/2	 0.17	 0.17	 0.17	 0.20	 0.18 dH	(in	WC)	 0.60	 0.59	 0.59	 0.78	 0.64 T	stack	(F)	 99.6	 105.3	 107.3	 125.1	 109.3 T	meter	(F)	 92.7	 87.8	 103.9	 111.5	 99.0 P	static	(in	WC)	 0.01	 0.01	 0.01	 0.01	 0.01

P	bar	(in	Hg)	 26.30	 26.30	 26.25	 26.20	 26.26 P	stack	(in	WC)	 26.30	 26.30	 26.25	 26.20	 26.26
H 2 O	Mass	Gain	(g)	 21.60	 21.10	 30.50	 20.30	 23.37

Yd	(meter	coef.)	 0.974	 0.974	 0.974	 0.974	 0.974

dH	@	(in	WC)	 1.894	 1.894	 1.894	 1.894	 1.894 Cp	(pitot	coef.)	 0.84	 0.84	 0.84	 0.84	 0.84 Dia	stack	(in)	 NA	 NA	 NA	 NA	 #DIV/0! Dia	nozzle	(in)	 0.369	 0.369	 0.369	 0.369	 0.369 CO 2 (%)	 0.00	 0.00	 0.00	 0.00	 0.00 O 2 (%)	 20.90	 20.90	 20.90	 20.90	 20.90 Vol	meter	(dscf)	 180.734	 180.802	 176.307	 200.449	 184.573 Md	(lb/lb‐mole)	 28.84	 28.84	 28.84	 28.84	 28.84 Ms	(lb/lb‐mole)	 28.78	 28.78	 28.75	 28.78	 28.77 Vwc	 1.02	 0.99	 1.44	 0.96	 1.10 H 2 O	(%)	 0.6	 0.5	 0.8	 0.5	 0.6 ISO	(%)	 95.8	 96.4	 94.4	 95.0	 95.4
SO 2 Results
SO 2 (ppm)	 19.4	 19.2	 21.5	 19.9	 20.0 SO 2 (lb/hr)	 0.00	 0.00	 0.00	 0.00	 0.00 Meteorological	Results Temp	(°C)	 39.1	 41.0	 44.0	 52.5	 44.2 Flow	Rate	(m/s)	 0.448	 0.514	 1.124	 2.431	 1.13Freeport-McMoRan Miami Inc. | Roofline Study Trinity Consultants 5-4 

### 5.4. ISA TEST RESULTS

A	total	of	three	sample	runs	were performed	at	the	Isa	Building operating	area	from	Jun e	11	and	12,	2012.		The first	two	samples	w ere	collected	over	a	480‐minute	period	and	t he	third	was	collected	over	a	300‐minute period.		The	samples	were	collect ed	using	a	singl e	sample	point in	the	roof	monitor	in the	center	area	of	the monitor	and	at	the	two	openings on	the	south	and	east	sides	of the	building.		The	average	of	the	recorded	test parameters	including,	stack	temp erature,	meter	temperature,	and pressure	for	the	three Isa	sample	runs	are provided	in	Table	5‐4.		Also	incl uded	in	this	table	are	calcula tions	of	effluent	molecular	weight	(wet	and	dry)	and
moisture	content.		In	a ddition,	the	average	SO 2 concentration,	temperature	(°C) and	flow	rate	(m/s)	measured during	the	test	run	are	listed.

Table 5

‐ 4. Isa Sampling Results

Test Parameters ISA1

‐ 1 ISA2

‐ 1 ISA3

‐ 1

Average 06/11/12 06/12/12 06/11/12 0840

‐ 1640 1828

‐ 2412 0845

‐ 1645 Sample	Time	(min)	 480	 300	 480	 420

Vol	meter	(acf)	 222.706	 140.309	 227.756	 196.924 Ave.	SQRT	dP	(in	WC)1/2	 0.17	 0.17	 0.17	 0.17 dH	(in	WC)	 0.55	 0.52	 0.53	 0.53 T	stack	(F)	 108.4	 112.3	 98.3	 106.3 T	meter	(F)	 108.8	 101.7	 101.8	 104.1 P	static	(in	WC)	 0.01	 0.01	 0.01	 0.01

P	bar	(in	Hg)	 26.30	 26.30	 26.30	 26.30 P	stack	(in	WC)	 26.30	 26.30	 26.30	 26.30
H 2 O	Mass	Gain	(g)	 28.70	 36.40	 28.60	 31.23

Yd	(meter	coef.)	 0.989	 0.970	 0.970	 0.976

dH	@	(in	WC)	 1.722	 1.857	 1.857	 1.81 Cp	(pitot	coef.)	 0.84	 0.84	 0.84	 0.84 Dia	stack	(in)	 NA	 NA	 NA	 #DIV/0! Dia	nozzle	(in)	 0.370	 0.358	 0.358	 0.362 CO 2 (%)	 0.00	 0.00	 0.00	 0.00 O 2 (%)	 20.90	 20.90	 20.90	 20.90 Vol	meter	(dscf)	 179.876	 112.538	 182.636	 158.350 Md	(lb/lb‐mole)	 28.84	 28.84	 28.84	 28.84 Ms	(lb/lb‐mole)	 28.76	 28.67	 28.76	 28.73 Vwc	 1.35	 1.71	 1.35	 1.47
H 2 O	(%)	 0.7	 1.5	 0.7	 1.0 ISO	(%)	 95.8	 103.4	 102.9	 100.7
SO 2 Results
SO 2 (ppm)	 32.6	 37.2	 31.8	 33.9 SO 2 (lb/hr)	 0.00	 0.00	 0.00	 0.0 Meteorological	Results Temp	(°C)	 43.9	 46.1	 38.1	 42.7 Flow	Rate	(m/s)	 1.543	 1.376	 0.130	 1.016Freeport-McMoRan Miami Inc. | Roofline Study Trinity Consultants 5-5 

### 5.5. ELECTRIC FURNACE TEST RESULTS

A	total	of	two	sample runs	were	performed	at the	Electric	Furna ce	operating	area	from	June	11	and	12,	2012. The	samples	were	collected	over a	480‐minute	period	and	a	300‐m inute	period,	respectiv ely,	at	two	locations along	the	roof	monitor	using	a	s ingle	sample	point	in	the	cente r	area	of	the	monitor. The	average	of	the recorded	test	parameters	includi ng,	stack	temperature,	meter	te mperature,	and	pressure,	etc.	for	the	two Electric	Furnace	sample	runs	are provided	in	Table	5‐5.		Also	i ncluded	in	this	table	are calculations	of	effluent molecular	weight	(wet	and	dry)	and	moisture	content.		In	additi on,	average	SO 2 results,	temperature	(°C)	and flow	rate	(m/s)	measured	dur ing	the	test	run	are	listed.

Table 5

‐ 5. Electric Furnace Sampling Results

Test Parameters E2

‐ 1 E1

‐ 1

Average 06/11/12 06/12/12
0821

‐ 1621 1824

‐ 0012 Sample	Time	(min)	 480	 300	 390

Vol	meter	(acf)	 222.826	 137.229	 180.028 Ave.	SQRT	dP	(in	WC)1/2	 0.17	 0.17	 0.17 dH	(in	WC)	 0.63	 0.60	 0.61 T	stack	(F)	 123.7	 124.6	 124.1 T	meter	(F)	 109.5	 97.8	 103.6 P	static	(in	WC)	 0.01	 0.01	 0.01

P	bar	(in	Hg)	 26.30	 26.35	 26.33 P	stack	(in	WC)	 26.30	 26.35	 26.33
H 2 O	Mass	Gain	(g)	 27.70	 7.90	 17.80

Yd	(meter	coef.)	 0.974	 0.974	 0.974

dH	@	(in	WC)	 1.894	 1.894	 1.894 Cp	(pitot	coef.)	 0.84	 0.84	 0.84 Dia	stack	(in)	 NA	 NA	 NA Dia	nozzle	(in)	 0.369	 0.369	 0.37 CO 2 (%)	 0.00	 0.00	 0.00 O 2 (%)	 20.90	 20.90	 20.90 Vol	meter	(dscf)	 177.157	 111.599	 144.378 Md	(lb/lb‐mole)	 28.84	 28.84	 28.84 Ms	(lb/lb‐mole)	 28.76	 28.80	 28.78 Vwc	 1.30	 0.37	 0.84 H 2 O	(%)	 0.7	 0.3	 0.5 ISO	(%)	 96.1	 96.5	 96.3
SO 2 Results
SO 2 (ppm)	 4.4	 3.5	 4.0 SO 2 (lb/hr)	 0.00	 0.00	 0.0 Meteorological	Results Temp	(°C)	 52.6	 50.9	 51.8 Flow	Rate	(m/s)	 1.702	 1.596	 1.649Freeport-McMoRan Miami Inc. | Roofline Study Trinity Consultants 5-6 

### 5.6. AVERAGE SO 2 

### , TEMPERATURE, AND WIND SPEED RESULTS

Table	5‐6	contains	the	average	SO 2 (ppm),	temperature	(°C)	and	wind speed	(m/s)	for	the	entire	me asurement time	at	each	operating	area.		Inc luded	in	the	table	are	the	tes t	location,	start	time,	st op	time	and	average	value recorded.

Table 5

‐ 6. Average SO 2 , Temperature, and Wind Speed Sampling Results

Test Start Stop SO2 Temp. Wind Speed Location Date Time Date Time (ppm) (°C) (m/s)

Crane Bay 6/1/12 1140 6/5/12 0816 NA 31.62 0.906

Anode 6/2/12 1500 6/6/12 1600 11.2

A1 5/31/12 1305 6/7/12 0826 61.52
A2 5/31/12 0940 6/7/12 0828 63.91 1.555
A3 5/31/12 1305 6/7/12 0826 70.96
A4 5/31/12 0940 6/7/12 0828 78.45 1.775
A5 5/31/12 1305 6/7/12 0826 78.93
A6 5/31/12 1306 6/7/12 0826 75.20
A7 5/31/12 1306 6/7/12 0826 69.03
A8* 5/31/12 0940 6/7/12 0828 77.07 2.058
A9 6/1/12 0855 6/7/12 0826 74.79
A10** 5/31/12 0940 6/7/12 0828 72.72 1.325

A11 6/2/12 1415 6/7/12 0754 57.20

Converter 6/2/12 1625 6/7/12 0736 16.7
C1 6/2/12 1325 6/7/12 0754 45.45 2.124
C2 6/2/12 1415 6/7/12 0754 40.81
C3 6/2/12 1325 6/7/12 0754 42.34 1.299
C4 6/2/12 1415 6/7/12 0754 44.14
C5 6/2/12 1325 6/7/12 0754 42.10 0.911
C6 6/2/12 1415 6/7/12 0754 41.27
C7 6/2/12 1325 6/7/12 0754 38.98 0.385

ELF 6/10/12 1822 6/13/12 1114 4.8
E1 6/8/12 1926 6/13/12 1304 49.61 1.658
E2 6/8/12 1926 6/13/12 1304 49.60 1.833
E3 6/8/12 1926 6/13/12 1304 47.17 1.381

ISASmelt 6/10/12 1736 6/13/12 0922 26.6
ISA1 6/10/12 1718 6/13/12 1158 40.65 1.629
ISA2 6/10/12 1718 6/13/12 1158 46.20 1.470
ISA3 6/10/12 1718 6/13/12 1158 35.46 0.466

* Wind speed at A8 started on 6/1/12 at 0855. ** Wind speed at A10 was out of service from 6/5/12 at 1912 through 6/6/12 at 1008.Freeport-McMoRan Miami Inc. | Roofline Study Trinity Consultants 6-1 

## 6. CONCLUSION

Based	upon	the	results	from	the study,	the	Miami	Smelter’s	fugi tive	SO 2 emissions	were	calc ulated	as	1,021	tons per	year.		The	calculated	results from	the	study are	approximat ely	13%	of	the	2010	emissi ons	estimation	using the	sulfur	balance	requi red	by	Arizona’s	SIP.

A	long	term	study	of	the	roofli ne	emissions	has	been	undertaken to	further	validate	the emissions	estimated	in this	report.		The	sampling	locations	used	for	the	long	term	stu dy	are	generally	the	same	with	sole	exception	that measurements	for	the	Electric	Fu rnace	operating	area	now	has	on ly	two	sample	locations rather	than	three,	the Anode	Aisle	has	three	sa mple	locations	rather	than	four,	and	th e	Converter	Aisle	has	four	sample	locations rather	than	five.		These	minor	changes	in	sampling	protocol	are not	expected	to	impact	th e	concentration	results significantly.		In	addi tion,	the	probe	plac ements	in	the	Anode Aisle	and	Converter	Aisle have	been	placed	such that	the	sampling	results	w ould	bias	the	average	SO 2 emissions	higher	than	the	ori ginal	study	due	to	their placement	closer	to	the	vesse l	openings.		Preliminary	SO 2 concentration	results	for the	long	term	roofline sampling	campaign	sugge st	no	major	changes from	the	emissions	e stimated	in	this	report.