Primary Lead Smelting NESHAP Technical Support Document



## Risk and Technology Review

National Emission Standards for Hazardous Air Pollutants (NESHAP) for the Primary Lead Smelting Source Category

Technical Support Document

Docket No. EPA-HQ-OAR-2004-0305

January 31, 2011Primary Lead Smelting NESHAP Technical Support Document

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### Table of Contents

1.0 Residual Risk Analysis - Development of the Emissions Dataset for the Primary Lead Smelting Source Category ............................................................................................................... ................ 1

1.1 Emissions Data Sources .................................................................................................... .. 2

1.2 Risk Analysis Emissions Data Set ...................................................................................... 2

1.2.1 Actual Emissions ................................................................................................... 3

1.2.2 Allowable Emissions ............................................................................................. 5

2.0 Calculation of Proposed Risk-Based Emission Limits Based on Modeled Concentrations ............ 7

3.0 Estimated Costs of Proposed Revisions to the Primary Lead Smelting NESHAP ........................ 10

3.1 Emission Control Costs for Ample Margin of Safety Reductions .................................... 10

3.2 Additional Testing and Monitoring Costs ......................................................................... 13

Appendix A 2005 NATA - Volatile Orga nic HAP from Boilers Risk Screening

Tables

Table 2.1 Calculations of Risk-Based Emi ssion Limits Based on Modeled Concentrations Table 2.2 Calculation of Proposed Refinery Operation Emission Limit based on Modeled Concentrations Table 3.1 Cost Effectiveness of Upgrad ing to Membrane Bags for Main Stack Table 3.2 Cost Effectiveness of Adding an Additional Baghouse to Control Emissions for Main Stack Table 3.3 Additional Testing and Monitoring CostsPrimary Lead Smelting NESHAP Technical Support Document

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### 1.0 Residual Risk Analysis ­ Development of the Emissions Dataset for

the Primary Lead Smelting Source Category

This memo describes the development of the data set used to conduct the residual risk analysis under Section 112 (f)(2) of the Clean Air Act (CAA) for the Primary Lead Smelting source
category.

Section 112 of the Clean Air Act (CAA) establishe s a two-stage regulatory process to address emissions of hazardous air pollutants (HAP) from st ationary sources. In the first stage, after EPA has identified categories of sources emitting one or more of the HAP listed in section 112(b) of the CAA, section 112(d) of the CAA ca lls for us to promulgate a National Emission Standard for Hazardous Air Pollutants (NESHAP) for those sources. These technology-based standards must reflect the maximum degree of emission reductions of HAP achievable (after considering cost, energy requirements, and non- air quality health and environmental impacts) and are commonly referred to as maximum achieva ble control technology (MACT) standards. The NESHAP for the Primary Lead Smelting sour ce category was promulgated on June 4, 1999.

The EPA is then required to review these te chnology-based standards and to revise them “as necessary (taking into account de velopments in practices, proce sses, and control technologies)” no less frequently than every 8 years, under CAA section 112(d)(6). In conducting this review, EPA is not obliged to completely recalc ulate the prior MACT determination. NRDC v. EPA

, 529 F.3d 1077, 1084 (D. C. Cir., 2008).

The second stage in standard-setting focuses on reducing any remaining “residual” risk according to CAA section 112(f)(2) and requires EP A to determine for source categories subject to certain MACT standards, whether the emission s standards provide an ample margin of safety to protect public health. If the MACT standa rds apply to a source category emitting a HAP that is “classified as a known, proba ble, or possible human carcin ogen do not reduce lifetime excess
cancer risks to the individual mo st exposed to emissions from a source in the category or subcategory to less than one-in-one million,” EPA must promulgate residual risk standards for the source category (or subcategory) as necessary to provide an ample margin of safety to protect public health. CAA section 112(f)(2)(A). In doing so, EPA may adopt standards equal to existing MACT standards if EPA determines that the existing standards are sufficiently protective.

In order to conduct the risk analysis of sources in the Primary Lead Smelting source category, a dataset was developed that included estimates of individual HAP emi ssions from each HAP emitting source as well as source characteristics. The dataset used includes both actual and allowable facility emissions and was used in the emissions modeling ex ercise to determine
concentrations of various HAPs at the modeled receptor locations. Those concentrations were compared to the established risk-based thresh old for each HAP to determine the potential forPrimary Lead Smelting NESHAP Technical Support Document

2 residual risk from the emissions. The methods, thresholds, and results of risk analysis and modeling are described in the “Residual Risk As sessment for the Primary Lead Smelting Source Category” memorandum included in this docket. Below is a discussion of the sources of the
actual and allowable emissions data and source ch aracteristics used in the risk analysis and modeling exercise.

1.1 Emissions Data Sources

The preliminary sources used to gather emissions and source characteristic data included the 2002 National Emissions Inventory (N EI) Final Inventory, Version 1 (made publicly available on February 26, 2006), and the 2005 National Emi ssions Inventory (NEI), version 2.0 (made publicly available in October 2008). The 2005 NEI was updated to develop the 2005 National Air Toxics Assessment (NATA) Inventory. NATA inventory updates for the primary lead smelting category included SIP da ta provided by the state of MO to EPA. These data sets
include information about sources that emit criter ia air pollutants, their precursors, and HAP.
The NEI database includes estimates of annual air pollutant emissions from point and volume sources, emission release characteristic data such as emission release he ight, temperature, and velocity, and location latitude/longitude coordina tes. We reviewed the NEI datasets, checked geographic coordinates, and made ch anges based on available information.

The sole remaining facility in this source category is the Doe Run Company in Herculaneum, Missouri. The Doe Run facility has been the su bject of many compliance and regulatory actions by the State of Missouri and by EPA Region 7 related to complia nce with the lead National Ambient Air Quality Standard (NAAQS). The controls applicable to the faci lity in order to meet the NAAQS were adopted by the State and submitted to EPA for approval into the Lead State Implementation Plan. The most recent SIP submi ssion to address the lead NAAQS was made in 2007 and it included modeling of facility emissi ons to determine compliance with the lead NAAQS. EPA reviewed the emissions data used re lied on in that submission to update the risk analysis data set. Since many improvements in emissions controls have been implemented from 2001 through 2007 due to the 2001 SIP and the 2007 SI P revision, EPA determined that the most
recent data should be considered to determine ri sk based on actual emissions from the facility. EPA requested emissions and source control information through a section 114 information collection request (ICR) in Oc tober, 2009. The February, 2010 response from Doe Run included copies of the emissions inventories that were provided to the Missouri Department of Natural Resources (MDNR) for CY 2000 through 2008.

1.2 Risk Analysis Emissions Data Set

The analysis performed considers HAPs that em itted by the sources with in the source category addressed by the existing MACT standard. The risk analysis considers both the actual emissions of the facility and the emissions allowed under th e MACT rule. Once the analysis is complete,Primary Lead Smelting NESHAP Technical Support Document

3 EPA determines if any further emission reductions are necessary to assure that an acceptable level of risk is achieved and must promulgate additional standards, if necessary, to protect public health and welfare with an ample margin of safe ty. For the Doe Run facility, we determined the
actual and allowable emissions as described below.

1.2.1 Actual Emissions
We reviewed the NEI datasets, checked geograp hic coordinates, and made changes based on
available information. We also reviewed the emi ssions and other data to identify data anomalies
that could affect risk estimates. Since the 2008 emissions inventory is th e most recent emissions data source available, and reflects the implem entation of the numerous SIP emission reduction requirements (as evidenced by the ICR response), EPA determined that the emissions reported for the facility in the CY2008 emissions inventory report are the most representative of current facility operations.

The dataset derived from the review of the 2002 and 2005 NEI/NATA data was updated to
include the emissions for all sources from the CY2008 emissions inventory report. Any
differences in the data between the NEI a nd the CY2008 emission inventory were noted and analyzed. If data found in the NEI was not included in the CY2008 emi ssion inventory, but was found to be pertinent, then it wa s included in the data set used for the risk analysis. Any discrepancies found between the NEI and the CY2008 emission inventory was discussed with the facility.

One specific change to the data set derived from the combination of the NEI data and the CY2008 emission inventory pertained to organic HAP (VOC) emissions. The 2005 NEI file included several boiler sources that emitted trace levels of 25 organic HAP (VOC) from natural gas
combustion sources and from combustion of small amounts of coke fed to the blast furnace. During the original MACT development in 1997, EPA believed these leve ls of organic HAP emissions were not significant enough to warrant regulation and were far below what the EPA has historically considered achievable with a dd-on controls (e.g., thermal oxidizers). VOC emission levels as reported in the ICR response were consistent with the 1997 levels, however;
the ICR did not include individual VOC HAP emi ssions data. We did a screening of the VOC HAP from the 2005 NEI file (NATA) and found the maximum cancer risk was 0.0002 in a million at any off site location, the maximum hazard index was 0.000002 and the maximum acute exposure was for formaldehyde with an REL of 0.1. Based on the very low emission levels and the anticipated low concentrations (and corresponding risk) that would result from modeling these emission points, the organic HAP emissions s ources were removed from the modeling dataset and not considered during the risk analysis. The dataset and results of the VOC HAP risk screening analysis are included as Appendix A.Primary Lead Smelting NESHAP Technical Support Document

4 The final dataset included emissions of lead compounds and other metal HAP (i.e. antimony, arsenic, cadmium, chromium , cobalt, and nickel).

“Lead compounds” is the primary HAP emitted from the Doe Run facility and accounts for approximately 99 percent of the total HAP emitted. Of the lead compound emissions, approximately 86 percent is emitted through stacks ( point or vertical sources) with the remainder being fugitive emissions. The point or vertic al sources include stacks that discharge from baghouses, heat stacks and roof vents. The MA CT emission limit applies to operations that discharge through 2 stacks, the main and the fu rnace area stacks which account for 15.1 of the total 17.9 TPY stack lead compound emissions. Since promulgation of the MACT rule, the facility has captured and c ontrolled all refining operations with two additional baghouses (baghouse #8 which vents to a stack and baghous e #9 which vents to a common stack with the furnace area ). These emissions are included in the table below. Fugitive sources include material handling and plant yard and roadwa y dust. Table 1.1 summarizes the types and volumes of HAP emitted from fugitive and point sour ces that were included in the dataset for the Doe Run Company facility. To tal actual lead emissions including fugitive emissions are 20.7 tons per year (TPY). The risk dataset incl udes 137 data points for lead compound emissions.
Emissions sources of lead include 115 individual fugitive emission sources (or data points in the dataset) and 22 point sources (stacks). The 22 point sources include th e main stack and the furnace area stacks which together account for 98 percent of the total stack lead emissions and are the two sources that are subjec t to the MACT standard emission limit. It should be noted that
non-volatile metal HAP other th an lead are reported by Doe Run based on speciation tests
conducted for the various sources.

HAP Number
of Sources TPY Number
of Sources TPY Number
of Sources TPY
Lead 115 2.8483 22* 17.8600 137 20.7083 Antimony 6 0.0030 4 0.0250 10 0.0280
Arsenic 10 0.0010 6 0.0205 4 0.0215
Cadmium 12 0.0296 7 0.0875 19 0.1118
Chromium 0 0.0056 3 0.0000 3 0.0056
Cobalt 6 0.0054 6 0.0048 12 0.0054
Nickel 8 0.0021 7 0.0131 15 0.0172 *Of the 22 stack sources, 4 are included within the emission limit which account for 17.6 of the 17.86 TPY Fugitive Stack Total Summary of Doe Run Company Risk Dataset Emission Sources

*2 stacks (main and furnace area) account for 17.6 or th e total 17.9 TPY and are subject to the MACT emission
limit.

The actual emissions dataset for this facility repr esents the entire source category. Likewise, all emission points located at this facility and th at emit HAP are included in the risk analysisPrimary Lead Smelting NESHAP Technical Support Document

5 dataset; therefore, the facility-wide emission dataset for this source category is the same as the risk analysis dataset.

1.2.2 Allowable Emissions

Allowable emissions are emissions that would be allowed under the current MACT standard for primary lead smelters. Under the Primary Lead Smelting MACT, lead HAP emissions are regulated and lead emissions serve as a surr ogate for all other non-vol atile metal HAP emitted from the source.. For the Doe Run facility, a llowable emissions are summarized in Table 1.2.

Under the NESHAP, an aggregate emission limit of 1.0 pound of lead per ton of lead produced (lb/ton) applies to the following nine sources:

1) Sinter machine 2) Blast furnace 3) Dross furnace 4) Dross furnace charging location 5) Blast furnace and dross furnace tapping location 6) Sinter machine charging location 7) Sinter machine discharge end 8) Sinter crushing and sizing equipment 9) Sinter machine area

Applying the allowable emissions rate of 1.0 lb/ton to the Do e Run’s 2008 lead production of 149,564 tons, the aggregate allowable emissions resu lts in aggregate lead emissions of 74.8 TPY
from the above nine sources. All emissions from the source’s nine emissi on points listed above are captured and controlled by baghouses, which vent to the main stack or the furnace area stack. The total allowable emissions were prorated be tween the two stacks base d on the ratio of actual emissions reported for the two stacks.

Note that refining operations are not listed above and ar e not subject to the 1.0 lb/ton limit in the original MACT. At the time the NESHAP was promulgated, the refining operations were not enclosed and emissions from this operation we re regulated under the provisions addressing fugitive emissions sources, however, based on mo re recent requirements adopted by the State, refinery emissions are now captured, controlle d by a baghouse, and vented through two stacks.
We were unable to calculate an allowable emission level for re fining operations.

Under the NESHAP, fugitive emissions are governed by work practices, which under §63.1544
are defined as the measures that will be “put into place to contro l fugitive dust emissions.” Thus, the actual fugitive emissions, which reflect the meas ures that have been put in place, would be equivalent to the allowable emissions. Fugitiv e emissions levels were taken from Doe Run’s 2008 Emissions Inventory that is submitted annually to the MDNR.Primary Lead Smelting NESHAP Technical Support Document

6 Table 1.2 Summary of Actual and Allowable Lead Emissions for the Doe Run Primary Lead Smelter, 2008 1

Emission Point Processes Actual Emissions

(TPY) Allowable Lead Emissions

(TPY) Main Stack (BH # 3, 5, 6) Sintering, blast furnace, dross furnace 13.31 65.8

Furnace Area (BH # 7) Smelter building 1.81 8.94 Refining (BH # 8, 9) Refining kettles and building 2.74 N/A Fugitives Roadways, storage piles, materials handling and transport 2.85 2.85

N/A = not available

The MACT-allowable emissions from this sour ce category are based on the MACT limit (1 lb/ton) applied to 2008 production data . The modeling file for this risk anal ysis can be reviewed in the EXCEL spreadsheet

“ PrimLead_RTR_ModelingFile_102110_2008_DOE_RUNrev012811.xls ” available in the
docket.

References:

1. Curran, D., Stinson Morrison Hecker, for The Doe Run Company, to Nizich, S., US EPA, Response to Section 114 Information Collection Request, February 5, 2010.Primary Lead Smelting NESHAP Technical Support Document

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### 2.0 Calculation of Proposed Emission Limits Based on Modeled

Concentrations

The risk analysis process included modeling of ac tual and allowable emissions to determine the anticipated concentration at individual recept or locations. For this source category, the emissions for the lead emissions sources were individually modeled fo r each receptor location and the results were compared to the Primary National Ambient Air Quality Standard (NAAQS) for lead (0.15 μ g/m 3 ). If the modeled emissions exceeded the lead NAAQS, those locations were considered to be exposed to unacceptable risk. The results indicated multiple locations exceeded the level of the NAAQS to various degrees.

Our modeling results indicated that the highe st concentration location was a point on the property boundary. Emissions cont ributing to this exceedance were found to be cumulative fugitive dust emissions. Other emission points with modeled emission showing an exceedance of the lead NAAQS were the furnace area stack and the Baghouse #9 stack for the refinery building. Both of these stacks showed mode led levels above the NAAQS at various census block locations. The emissions from the main stack did not exceed NAAQS within the 50 km radius modeled area.

Each emission point (with fugitive dust emissi ons being treated as one emission point) was analyzed to determine what emission levels woul d be necessary to reduce risk to an acceptable level i.e., such that modeled emissions met or were below the leve l of the NAAQS. EPA assumes that if the highest or worst-case concen tration at a receptor lo cation resulting from the emissions from each emission point were reduced to below the NAAQS level, then the risks for that emission point at any location would be re duced to an acceptable level. Further, EPA assumes that a reduction in emissions from an emission point will result in a proportionate reduction in the modeled concentration at a give n receptor location. For example, if emissions from a stack are reduced by 50 percent, the modeled concentration at a receptor location will be reduced by 50 percent. Since the relationshi p between level of emissions and modeled concentrations is linear, a percen tage reduction could be applied to the actual emissions from the CY 2008 emissions inventory for a given emission point that woul d reflect the same reduction in modeled concentration. Therefore, a calculation was made for each emission point to determine what percent reduction in concentration was requ ired for each of the highest concentration locations to meet the NAAQS.

The reduction necessary in fugitive dust emissions was determined to be 98 percent. Our analysis indicated that the maximum lead concen tration location for the furnace area and refinery stack overlapped at the same census block (cen sus block #). Therefore, their combined concentrations at that location w ould be the driver for the reduction from these emission points. The reduction necessary for the combined furnace area stack and refinery stacks emissions was determined to be 80 percent.

The refinery emissions are vented through Baghouse #8 and Baghouse #9 stacks, and ten heat stacks. For the refinery operation, only one st ack (Baghouse #9) showed an exceedance of the NAAQS. The emission reduction found necessary from Baghouse #9 stack is 66 percent. ItPrimary Lead Smelting NESHAP Technical Support Document

8 was also found that the furnace area and refinery stack emissions maximum lead concentration overlap at the same census block (censu s block #290997006014031). To address the overlap, these points would need to be re duced together such that the l ead concentration at that point would be acceptable. The emission reduction necessary for the combined furnace area and refinery stacks is 80 percent.

Table 2.1 summarizes the calculati ons and recommended limits for the total facility including furnace area/refinery stacks and fugitive dustPrimary Lead Smelting NESHAP Technical Support Document9Table 2.1 - Calculations of Risk-Based Emission Limits Based on Modeled ConcentrationsModeled Source2008 Emissions(tpy)Modeled leadconcentrationat the site of maximumimpact(μg/m3)Roll back tomeet NAAQS%Emissions afterrollback (tpy) NotesStacks- Furnace area (Baghouse #7) 1.81 0.314 52 0.86 At census block #290997006014031- Refinery stacks 2.74 0.4363 66 0.94At census block #290997006014031Combined Stacks 4.55 0.7503 80 0.91FugitivesAll Fugitives 2.94 7.289 980.06fume, sinter and concentrate handlingRoadways, plant yard, resuspensionHighest concentration at property boundaryreceptor location1) Emission LimitLead concentration in air*0.15μg/m32) Emissions CapFurance Area and refinery stacks0.91 TPYCalculations Roll back % = (Actual concentration - 0.15)/actual concentrationEmissions after rollback = 2008 emissions * (1-(rollback%/100))*MeasuredatlocationsrepresentativeofpropertyboundaryasdeterminedbytheAdministratorPROPOSED ACTIONSAll Modeled SourcesPrimary Lead Smelting NESHAP Technical Support Document

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### 3.0 Estimated Costs of Proposed Revisions to the Primary Lead Smelting NESHAP

With regard to lead emissions, we are proposing emission limits that are consistent with the results of our risk and technol ogy reviews of the current NESHAP for primary lead smelters. Under our ample margin of safety analysis, we considered addition c ontrols beyond the existing level of control for the main stack to determine if additional controls would be warranted in order to provide an ample margin of safety. This section summarizes the im pacts analysis conducted on additional emission control options that we re considered technologically feasible for achieving additional emission reductions for the main stack. Although our analysis indicated that additional controls were not warranted for the main stack, we are proposing to lower the plant-wide emission limit to reflect performan ce achievable from technological improvements. In addition we are proposing to increase the frequency of mo nitoring stack emission from the current annual emissions testing to quarterly testing. This se ction, therefore, also includes estimates of the impacts for the additional mon itoring costs necessary to comply with proposed requirement.

We note that the controls that reduce lead emi ssions are the same controls that would reduce emissions and risks from cadmium and othe r metal HAP; therefore we are not proposing additional controls for other metal HAP.

For the main stack emission point, we consider ed the option of upgrading of existing baghouses from the use of cloth bags to membrane bags and the option of addi ng in-series baghouses.

3.1 Emission Control Costs for Ample Margin of Safety Reductions
Once we determine that risk will be reduced to a level that is acceptable, we then determine whether further reductions are appropriate to ensure an ample margin of safety. We investigated available control options that could be implem ented by the facility to attain the additional emissions reductions that would provid e an ample margin of safety.

No additional controls beyond those described above were identified to further control fugitive dust emissions or emissions from the furnace area stack or the refinery stacks. For the main stack, however, additional controls were evaluated and considered with regard to risk reduction and cost under the ample margin of safety analysis.

For the main stack, our risk analys is indicates that emissions do not result in ambient lead levels exceeding the NAAQS based on either actual or allowable emi ssion levels. However, we determined that it is technologically feasible to reduce emissions from the main stack to a level well below the allowable level of the MACT, sin ce those levels are currently being achieved. We evaluated additional controls such as memb rane bags or add-on baghouses as a means for achieving those reductions and reduc ing associated risk. We determined that the additional controls would not provide an appreciable risk reduction (emission reduction) for the associated cost. However, we have determined that em issions allowable under MACT should be reducedPrimary Lead Smelting NESHAP Technical Support Document

11 under the section 112(d)(6) technology review as described in the technology review memorandum found in this docket.

Table 3.1 summarizes the costs and cost-effectiveness for the main stack of replacing cloth bags with membrane bags. Table 3.3 summarizes the co sts and cost-effectivene ss of adding an inseries baghouse. The calculations supporting the costs reflected in the summary are included in EXCEL spreadsheet ImpactsEst_PrimLeadRTR_122210.xls found in the docket.Primary Lead Smelting NESHAP Technical Support Document12Total CostInvestmentTotalAnnualizedCost2008 BaselinePb Emissions(tpy)Emission Reductionfrom upgrade*(tpy)CE($/ton)Main Stack 1,958,851 322,823 13.31 8.0 40,424*We estimate removal efficiency for membrane bag update to be between 50 and 70 percent.Cost of Upgrade toMembrane BagsTable 3.1 - Cost Effectiveness of Upgrading to Membrane Bags for Main StackImpactsSourcePb emissions (tpy)reported in 2008EIPb emission reductionwith additional BHassuming 50% RE (tpy)Pb emission reductionwith additional BHassuming 97% RE (tpy)Annualized cost ofadding extra BH's($/yr)Cost effectivenessassuming 50% RE($/ton)Cost effectivenessassuming97% RE($/ton)Main Stack 13.31 6.7 12.9 $1,529,730 $229,862 $118,4851Reflects costs for pulsejet baghouses2See DRAFT ImpactsEst_PrimLeadRTR_122210.xls for detail on cost analysis.RE = Removal efficiencyTable 3.2 - Cost Effectiveness of Adding an Additional Baghouse to Control Emissions for the Main Stack1,2Primary Lead Smelting NESHAP Technical Support Document

13 3.2 Additional Testing and Monitoring Costs
To demonstrate compliance with the new plant-wi de emission limit, EPA is proposing to require quarterly stack testing. Although the method for te sting is the same as it was under the current MACT, the quarterly frequency requirement imposes additional impact with re gard to the cost of additional testing.

The proposed additional testing a nd monitoring requirements will re sult in additional cost as
summarized in Table 3.3 below.

Table 3.3 - Additional Testing and Monitoring Costs Type of Testing/Monitoring Notes Cost Annual Cost 1 Stack Testing Method 12 $13,000 per test $39,000

1 Includes 3 additional stack testsPrimary Lead Smelting NESHAP Technical Support Document



### APPENDIX A

Doe Run Company, Herculaneum, MO

2005 NEI (NATA) - Volatile Organic HAP from Boilers

Risk ScreeningPrimary Lead Smelting NESHAP Technical Support Document

Appendix A

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