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 CR01RESPONSE 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 RG13construed 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 2Provide 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 RG134. 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 OPM, Total Mercury Volatile organic

compounds

(VOC) Other acid gases (hydrochloric

acid HF, others) VOC HAP (for example,

benzene,

formaldehyde,

xylene, others) NOxS02Sulfuric acid 4 DB04/800043.0023/2346628.3 RG13Dioxins/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 RG130 0• • 0

0 0 • 0000o #0 0 0bO •• 0 • oList 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 ArsenicBeryllium 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 SulfurSilicaZinc 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 RG1310. 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

point

for 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 22The 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 RG1313. 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 RG13PART 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