Correspondence_DoeRun_Email101510.txt

From: Marucheau, Louis [lmarucheau@doerun.com]

Sent: Friday, October 15, 2010 7:11 PM

To: Nizich.Sharon@epamail.epa.gov

Cc: Laney, Michael N.; Fruh.Steve@epamail.epa.gov; Hanzel, Veronica; Miller, 

Aaron; Keller, Rusty

Subject: RE: Questions about Doe Run

Sharon,

I have discussed your questions with our people and have the following

answers:

1. As you have described, Baghouses #8 and #9 control emissions from the 

refinery operations and building. Emissions from the dross and blast furnace 

areas are vented to Baghouse #7 and are not part of the control systems for 

the refinery operations. Rusty and Aaron will be able to provide more details 

during our call on Tuesday. 

2. Because the basis of the consent decree air limitations at Herculaneum 

were allegations concerning the sintering machine and acid plant, these are 

the activities that will cease by the end of 2013.

Although the production of sinter will cease at the end of 2013, there will be 

a time lag before all stockpiled sinter is consumed in the blast furnace, 

hence the different closure dates. Given that there will be limited sinter 

stockpiled at the end of the year, our people believe that the blast furnace 

will actually stop well before the April deadline.

3. If lead refining, casting, or alloying is continued at Herculaneum, it 

will likely occur in the same location and the building housing these 

activities would be maintained. These operations would have fewer emissions 

as the amount of lead produced is likely to be less than currently produced 

and any refining that might occur would not have all the refining requirements 

currently needed for the characteristics of lead produced by the blast 

furnace. The remediation process will address the portions of the Herculaneum 

buildings that house the sinter machine and blast furnace and will address 

other areas of the plant, but would not address the portion of the plant used 

for refining, casting, and alloying.

If you have any further questions, Aaron, Rusty, and I will try to address 

them during our call on Tuesday.

Lou Marucheau

-----Original Message-----

From: Nizich.Sharon@epamail.epa.gov

[mailto:Nizich.Sharon@epamail.epa.gov]

Sent: Thursday, October 14, 2010 12:13 PM

To: Marucheau, Louis

Cc: Laney, Michael N.; Fruh.Steve@epamail.epa.gov; Hanzel, Veronica

Subject: Questions about Doe Run

Hello Mr. Marucheau -

We had some specific questions on the current and future operation at

Herculaneum. The answers would have an impact on the proposed rule that

we are developing. If you could send back the answers before our

discussion Tuesday, that would be helpful.

1. Our information indicates that Baghouse #8 controls emissions from

12 refining kettles and lead casting, and stack lead emissions for 2008

were 0.45 tons. Baghouse #9 controls emissions from the refinery

building and emissions for 2008 were 2.03 tons.

 - Do either of these stacks have a contribution of lead emissions from

any other source or activity that would not be completely attributable

to refining operations (i.e. fugitives from dross or blast furnace)?

- If there is a contribution from other activities, what portion

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Correspondence_DoeRun_Email101510.txt

(percentage) of the stack emissions are likely attributable solely to

refinery operations?

2. According to the consent decree, delivery and handling of sulfide

ore concentrate, operation of sintering machine, and operation of the

sulfuric acid plant will permanently cease by 12/31/2013. Blast furnace

operations are to permanently cease by 4/30/2014. Why the different date

for blast furnaces?

3. The consent decree states that Doe Run may continue to use a portion

of the property for lead refining, casting and alloying purposes. Will

they continue in their current location and/or will the refining,

casting and alloying operations be modified; if so how? Will the

building that currently houses these operations be part of the

remediation process?

THANK YOU!!

Sharon V. Nizich

Metals and Minerals Group

Sector Policies and Programs Division

OAQPS - US EPA

RTP NC 27711

919/541-2825

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