S T 1 N S O N 

.M O R.RI S O N 

HECKER •:•,p 

Douglas Y. Curran 

(816) 691-3113 

dcurran@stinson.com 

www.stinson.com 

1201 Walnut Street, Suite 2900 

Kansas City, MO 64106-2150 

Tel (816) 842-8600 

Fax (816) 412-1089 February 5, 2010 

VIA FEDERAL EXPRESS 

Ms. Sharon Nizich 

U.S, EPA Mailroom (D243-02) 

U.S. Environmental Protection Agency 

Office of Air Quality Planning and Standards 

Research Triangle Park, NC 27711 

Re: The Doe Run Resources Corporation 

Dear Ms. Nizich: 

Enclosed please find the response on behalf of The Doe Run Resources 

Corporation to the December 4, 2009, Section 114 Request from USEPA's Office of 

Air Quality Planning and Standards. If you should have any questions, please contact 

the undersigned or Stacy Stotts at 816-842-8600. 

Very truly yours, 

STINSON MORRISON HECKER LLP 

DYC:cm 

Enclosure 

KANSAS CVI'Y 

OVERLAND PARK 

WICHITA 

WASHINGTON, I).C •. 

PIIOENIX 

ST, LOU|S 

OMA I-{A 

JE}:FI•RSON CITY 

DB04/800043.0023/2396315.1 CR01 
RESPONSE OF THE DOE RUN RESOURCES CORPORATION 

to the U.S. Environmental Protection Agency 

Office of Air Quality, Planning and Standards 

December 4, 2009 

Request for Information Pursuant to Section l14(a) 

of the Clean Air Act 

Submitted February 5, 2010 

This is the response of The Doe Run Resources Corporation ("Doe Run") to the U.S. 

Environmental Protection Agency Office of Air Quality, Planning and Standards("EPA") December 4, 2009 request for information pursuant to Section 114(a) of the Clean Air Act 

("CAA") ("Information Request") regarding Doe Run's primary lead smelter in Herculaneum, Missouri. EPA granted an extension of time, until February 8, 2010, to respond. Doe Run has 

made every effort to respond to the Information Request in a timely and comprehensive manner. 

Doe Run reserves the right to supplement this response through the submittal of additions or 

corrections. 

There are documents provided in the response for which Doe Run is asserting a 

confidentiality claim pursuant to 40 C.F.R. Section 2.203(b). For such documents, Doe Run has 

stamped them "Confidential Business Information" and requests that they be protected as 

confidential in accordance with 42 U.S.C. Section 74 i 4(c) and applicable regulations. 

Doe Run has attempted to protect from disclosure all "attorney/client" or "attorney work 

product" privileged documents. However, please be advised that in the event that Doe Run has 

inadvertently submitted a privileged document, such submittal shall not be deemed or construed 

to be a waiver of any applicable privilege, Doe Run requests that any privileged or confidential document inadvertently provided be returned to Doe Run. 

Enclosure 1 to the Information Request contains terms that are subject to varying interpretations. Doe Run has attempted to be fully responsive and in doing so may be overly inclusive in its response. Inclusion of the information and documents provided in this Response is not an admission that the information and documents provided are properly characterized by the terminology used in the Information Request. If EPA believes any of the information provided by Doe Run is not responsive or is inconsistent with the intent of the Information 

Request, for clarification please contact our outside counsel Doug Curran or Stacy Stotts, stinson Morrison Hecker LLP, 1201 Walnut Street, Kansas City, Missouri 64106, 816-842-8600. 

Nothing in this response or the documents provided is to be used or construed as an 

admission of liability. Additionally, Doe Run believes that the scope of the Section 114 

Information Request in some respects exceeds the authority granted to EPA under the CAA. 

While Doe Run objects to these requests as beyond EPA's authority under Section 114, Doe Run 

has provided the requested information and has prepared requested documents in good faith for those questions that the information was available. Doe Run further reserves the right to object on any grounds to any and all parts of the Information Request, including any supplements thereto or additional information requests in the future, and nothing contained herein should be 

1 

DB04/800043.0023/2346628.3 RG13 
construed as a waiver of any objection that Doe Run may have related to the Information 

Request or any supplements thereto or additional information requests. 

The following narrative sets forth the questions from EPA's Information Request 

(italicized) and Doe Run's responses. 

Provide the name and address of the legal owner as well as the name and address of the 

primary lead smelting.facility. 

Name of legal owner 

Street address of legal owner 

Name and street address of 

primary lead smelting facility 

The Doe Run Resources Corporation 

1801 Park 270 Drive, Suite 300 

St. Louis, MO 63146 

Herculaneum Smelting Division 

881 Main Street 

Herculaneum, MO 63048 

DB04/800043.0023/2346628.3 RG13 

2 
Provide the following information for each mine that supplies 6re concentrate to your 

primary lead smelting facility in Herculaneum. 

The name and pkysical 

location (street address) of 

each mine 

For each mine, the total ore 

processed (short or metric 

tons) in 2008 and the amount 

sent to your primary lead 

smelting facility in 

Herculaneum 

The Doe Run Company 

Buick Mine/Mill 

270 Forest Road 2231 

Highway KK 

Boss, MO 65440 

The Doe Run Company 

Brushy Creek Mine/Mill 

10827 Highway KK 

Boss, MO 65440 

The Doe Run Company 

Fletcher Mine/Mill 

230 County Road 849 

Centerville, MO 63633 

The Doe Run Company 

Sweetwater Mine/Mill 

1382 Sweetwater Mine Road 

Ellington, MO 63628 

2008 lead concentrate produced, short dry tons: 

Buick- 100,764 

Brushy Creek 68,800 

Fletcher- 88,569 

Sweetwater 29,398 

2008 lead concentrate shipped to Herculaneum, short dry tons: 

Buick 33,124 

Brushy Creek 66,873 

Fletcher- 84,338 

Sweetwater- 20,745 

3. Provide 2008 ore processing and lead production for the Herculaneum lead smelter. 

Total Ore Processed (tons) in 2008 207,980 as concentrate 

Total Lead Produced (tons) in 2008 149,564 

3 

DB04/800043.0023/2346628.3 RG13 
4. Provide 2000 through 2007 lead production for the Herculaneum lead smelter. 

Year TotalLeadProduced(ton• 

2007 136,573 

2006 168,030 

2OO5 154,752 

2004 163,734 

2003 150,550 

2002 154,652 

2001 191,629 

2000 238,846 

Provide copies of all emissions test reports and results for the air pollutants listed below 

for your primary lead smelting facility at Herculaneum. Include results of emissions tests 

and individual run results, conducted from the yoar 2000 to the present. If the test result 

summaries do not identify the test methods used include that information. Also include 

speciated data for compounds listed Please provide this information for each emission 

point at the facility., 

Antimony compounds 

Arsenic compounds 

Beryllium compounds 

Cadmium compounds 

Chromium compounds 

Lead compounds 

Manganese. compounds 

Mercury compounds 

Nickel compounds 

PM2. 5, filterable and condensable 

PMI O 

PM, Total 

Mercury 

Volatile organic compounds (VOC) 

Other acid gases (hydrochloric acid HF, others) 

VOC HAP (for example, benzene, formaldehyde, xylene, others) 

NOx 

S02 

Sulfuric acid 

4 

DB04/800043.0023/2346628.3 RG13 
Dioxins/furans 

Opacity 

Other l12(b) HAP that you are aware are emitted by the facility 

Doe Run objects to this request as overbroad and unduly burdensome, because it seeks 

information starting in 2000. The requested information fills numerous file cabinets. It could 

take several months to locate, review and copy all of this information back to 2000, much, if not 

all, of which EPA already has in its possession. Doe Run also objects to the request to the extent 

that it seeks information for compounds that are not listed as hazardous air pollutants pursuant to 

Section 112 of the Clean Air Act. Doe Run is subject to the NESHAPs at 40 CFR Part 63 

Subpart III- "National Emission Standards for Hazardous Air Pollutants for Primary Lead 

Smelting" as a result of lead emissions from its primary smelter in Herculaneum. Doe Run is a 

major source under Section 112 for lead only. As such and without waiving these objections, Doe Run is providing the lead stack test results in its possession. Most if not all of these tests 

were submitted to EPA pursuant to 40 CFR Part 63 Subpart III. In addition, Doe Run is 

providing Emissions Inventory Questionnaires that provide information regarding other 

emissions at the Herculaneum primary lead smelter. See Attachment 2. 

Provide the latest soil monitoring, or other non-air testing results performed at the 

Herculaneum site. Also include results for any testing done on behalf of the Doe Run 

Company for the surrounding areas around the Herculaneum site. 

Doe Run objects to this request as overly broad and unduly burdensome. In recent years, 

Doe Run's contractors have taken thousands of soil and water samples at the Herculaneum 

facility and inthe Herculaneum community. EPA already has all of these sampling results. Doe 

Run should not be required to go to the great expense of recreating all of this information which 

EPA already has in its possession. 

Provide the latest property boundaries for the Herculaneum site, via a map or a list of vertices. 

A map showing the property boundaries for the Company's Herculaneum facility is being produced. See Attachment 3. 

5 DB04/800043.0023/2346628.3 RG13 

0 

0 

• • 0 

0 

0 • 0 

0 

0 


0 

o # 



0 0 0 
bO • 

• 0 

• o 



List results from the latest sampling and analysis conducted on the ore concentrate and 

include the concentration (specify units, e.g., percent, ppm, ppb) o fall ore concentrate 

constituents. Please include the date of the sampling and analysis. 

6/08/2008 

6/08/2008 

6/08/2008 

6/08/2008 

6/08/2008 

6/08/2008 

6/08/2008 

6/08/2008 

6/08/2008 

6/08/2008 

Antimony <100 ppm 

Arsenic 

Beryllium 

Cadmium 

Chromium 

Lead 

600 ppm 

<100 ppm 

200 ppm 

117 ppm 

79% by weight 

Manganese <1 O0 ppm 

Mercury < Detection 

Nickel 500 ppm 

Selenium Not assayed for 

6/08/2008 Asbestiform fibers None 

6/08/2008 Fluorine <100 ppm 

Chlorine 

Sulfur 

Silica 

Zinc 

6/08/2008 

6/08/2008 

6/08/2008 

6/08/2008 

<100 ppm 

14.59 % 

.34% 

1.060 % 

6/08/2008 Sodium 900 ppm 

6/08/2008 Copper 0.38 % 

6/08/2008 Cobalt 0.04 % 

6/08/2008 Potassium 

6/08/2008 Iron 

6/08/2008 Aluminum 

6/08/2008 

0.10% 

1.30 % 

0.19% 

Carbon Black 0.92 % 

21 

DB04/800043.0023/2346628.3 RG13 
10. For each emission point not listed in Question 8, identify all work practices and 

pollution prevention techniques employed to reduce emissions of the pollutants identified 

in question 5.at the Herculaneum site. Please specify the year in which the facility 

implemented the practice and identify the emission reductions (if measured or 

estimated)from these practices Also include the costs associated with these 

practices. (Add additional pages if more space is needed.) 

Doe Run objects to this request as overbroad and unduly burdensome. It also seeks 

information that Doe Run does not have in its possession. Without waiving these objections, 

Doe Run is producing its current Work Practice Manual For Control Of Lead Emissions (with 

appendices). See Attachment 4. 

11. For each emission pointfor which there is an emission limit or work practice 

required by the State, provide the required monitoring, recordkeeping, and reporting 

requirements including the required frequency. 

All of the requested information is set forth in Doe Run's current operating permit, # 

OP2006-011B, for the Herculaneum facility, which is being produced. See Attachment 5. 

12. For each add-on control device, provide the following cost information, if available. Use 

additional sheets as necessary. 

Doe Run objects to this request as overly broad and unduly burdensome. It also is not 

limited in time. This request seeks a staggering amount of very specific cost information about 

numerous projects all over the Herculaneum facility. For more recent projects, it would take 

Doe Run personnel several months to obtain and produce the requested information. For older 

projects, the Company no longer has the requested cost information. Without waiving these 

objections, Doe Run is providing its total costs (or budgets) for each.project (for which it could 

locate information) that it performed pursuant to the 2000 and 2007 State Implementation Plans 

for Lead: 

2000 Lead SIP 

• #7 baghouse (permit emission unit # 0110) venting the blast $4.4 million 

furnace building ..,. 

• #8 baghouse (permit emission unit # 0120) venting the refinery 

kettles 

$1.3 million 

• #9 baghouse (permit emission unit #0130) venting the refinery 

building 

$3.4 million 

• Building enclosure of Blast Furnace and Refinery buildings $3.4 million 

Total: $12.5 million 

DB04/800043.0023/2346628.3 RG13 

22 
The foregoing costs include all of the electrical power, compressed air, engineering and 

construction management needed to construct each project. 

2007 Lead SIP Budget 

• Ins{all fence around plant to preclude public access 

• In plant sprinkler system 

• No. 1 blast furnace relocation 

• Blast furnace dog house ventilation improvement 

• Begin annual stack testing of main stack and restart MACT testing 

schedule 

• Construct storage bins for concentrate 

• Install pleated filter cartridges in #9 baghouse 

• Install pleated filter cartridges in #7 baghouse 

• Blast furnace front end ventilation improvements 

• Load a minimum of 11 trucks directly from the conveyor belt to railcar 

per day 

• Repairs to siding 

• Increase height of#8 baghouse stack to 150' 

• Increase height of#7/9 baghouse stack to 150' 

• Install partial enclosure on concentrate receiving hopper at truck unloader 

• Enclose south end of rail car tipper 

• Record amps from #5 baghouse fans 

• Record amps from #3 baghouse fan 

• Record wheel tunnel ventilation fan amps 

• Install automatic closers on all man doors in sinter plant, blast furnace 

and refinery buildings 

• Install cameras surveillance for kettle heat stacks 

• Begin quarterly stack testing of#8 and #7/9 baghouse stacks 

• Have weekly reviews of MET data by a Certified Consulting 

Meteorologist 

• Install fence around plant to preclude public access 

• Install partial enclosure on concentrate receiving hopper at truck unloader 

• Enclose south end of rail car tipper 

• Install mechanism to continuously record flow from #5 baghouse 

• Record amps from #6, #7, #8 and #9 baghouse fans 

• Install drop sleeve on concentrate conveyor at rail loading and stock pile drop points 

• Enclose pugger with building and rollup doors 

• Purchase regenerative air sweeper 

• Purchase wet sweeper 

Total: 

$150,000 

$150,000 

$2,900,OOO 

$25,000 

$14,000 

$100,000 

$170,000 

$248,000 

$500,000 

$100,000 

$125,000 

$242,000 

$150,000 

$40,000 

$85,000 

$5,000 

$5,000 

$5,000 

$10,000 

$6,000 

$69,000 

$15,000 

$150,000 

$40,000 

$85,000 

$35,000 

$20,O00 

$10,000 

$250,000 

$250,000 

$160,000 

$6,114,000 

-23 

DB04/800043.0023/2346628.3 RG13 
13. Please provide the following information for operations during startup and shutdown. 

Attach additional pages if necessary. 

a. How often does your smelting operations startup and shutdown (e.g. routine, never, etc.)." Please indicate number of times per year. 

The sinter plant routinely shuts down depending on the storage capacity of the final 

product. Doe Run does not have statistics as to how frequently shutdown occurs. During usual 

operations, roughly every three to four months, the blast furnace is shut down for one to two 

days to clean the ventilation duct from the blast furnace to the baghouse. Occasionally, the acid 

plant is shut down for major projects in other areas of the facility. 

b. List whatprocedures are followed or any activities that occur during startup and shutdown. 

The startup/shutdown procedures for the sinter machine, the blast furnace, the refinery, and the baghouse are being produced. See Attachment 6. 

c. Is the emission profile of the process units different during startup and shutdown than during normal operating conditions? 

Doe Run objects to this request because the term "emissions profile" is not defined. In 

any event, plant operations do not yield excess emissions during startups or shutdowns. 

do If the answer to l l.c. is yes, please explain, in detail, how emissions are different during startup and shutdown and why. Please also provide any information that supports your 

response to this question. 

Not applicable. 

e. Do you have test data that show emissions during startup or shutdown? 

If yes, when did you conduct such testing and why? 

Yes X No 

Doe Run has no test data showing lead emissions during equipment shutdowns or startups. After the installation of a Continuous Emissions Monitoring System in Summer 2009, Doe Run 

does have test results for SO2 emissions only, but none of those results are tied to shutdowns or 

startups. 

What were the test conditions at the time of testing? Were the tests associated with a routine 

startup or shutdown? 

Not applicable. See response to 13(e) above. 

f. Please submit any test data you have conducted during any startup or shutdown. 

Doe Run has no test data for lead emissions during shutdowns or startups. See response 

to 13 (e) above. 

24 

DB04/800043.0023/2346628.3 RG13 
PART II-- Information Concerning Demonstration Project and Related Activities 

14. Future Plans 

See Attachment 1, all of which is marked "Confidential." 

DB04/800043.0023/2346628.3 RG13 

25