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 Page 1Correspondence_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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