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, 2011 
Primary 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 Organic HAP from Boilers Risk Screening 

Tables 

Table 2.1 Calculations of Risk-Based Emission 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 Upgrading 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 Costs
Primary 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 dataset 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) establishes a two-stage regulatory process to address 

emissions of hazardous air pollutants (HAP) from stationary 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 calls 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 achievable control technology (MACT) standards. 

The NESHAP for the Primary Lead Smelting source category was promulgated on June 4, 1999. 

The EPA is then required to review these technology-based standards and to revise them “as 

necessary (taking into account developments in practices, processes, 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 recalculate 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 EPA to determine for source categories subject 

to certain MACT standards, whether the emissions standards provide an ample margin of safety 

to protect public health. If the MACT standards apply to a source category emitting a HAP that 

is “classified as a known, probable, or possible human carcinogen do not reduce lifetime excess 

cancer risks to the individual most 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 emissions 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 exercise to determine 

concentrations of various HAPs at the modeled receptor locations. Those concentrations were 

compared to the established risk-based threshold for each HAP to determine the potential for 
Primary Lead Smelting NESHAP Technical Support Document 

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residual risk from the emissions. The methods, thresholds, and results of risk analysis and 

modeling are described in the “Residual Risk Assessment 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 characteristics 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 (NEI) Final Inventory, Version 1 (made publicly available on 

February 26, 2006), and the 2005 National Emissions 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 data provided by the state of MO to EPA. These data sets 

include information about sources that emit criteria 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 height, temperature, and 

velocity, and location latitude/longitude coordinates. We reviewed the NEI datasets, checked 

geographic coordinates, and made changes 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 subject of many compliance and regulatory actions 

by the State of Missouri and by EPA Region 7 related to compliance with the lead National 

Ambient Air Quality Standard (NAAQS). The controls applicable to the facility 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 submission to address the lead NAAQS was made in 

2007 and it included modeling of facility emissions to determine compliance with the lead 

NAAQS. EPA reviewed the emissions data used relied 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 SIP revision, EPA determined that the most 

recent data should be considered to determine risk based on actual emissions from the facility. 

EPA requested emissions and source control information through a section 114 information 

collection request (ICR) in October, 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 emitted by the sources within 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 the MACT rule. Once the analysis is complete, 
Primary Lead Smelting NESHAP Technical Support Document 

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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 safety. 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 geographic coordinates, and made changes based on 

available information. We also reviewed the emissions and other data to identify data anomalies 

that could affect risk estimates. Since the 2008 emissions inventory is the most recent emissions 

data source available, and reflects the implementation 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 and the CY2008 emission inventory were noted and 

analyzed. If data found in the NEI was not included in the CY2008 emission inventory, but was 

found to be pertinent, then it was 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 dataset 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 levels of organic HAP 

emissions were not significant enough to warrant regulation and were far below what the EPA 

has historically considered achievable with add-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 emissions 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 sources 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 

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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 vertical sources include stacks that discharge from 

baghouses, heat stacks and roof vents. The MACT emission limit applies to operations that 

discharge through 2 stacks, the main and the furnace 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 controlled all refining operations with two additional baghouses 

(baghouse #8 which vents to a stack and baghouse #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 roadway dust. Table 1.1 summarizes the types and 

volumes of HAP emitted from fugitive and point sources that were included in the dataset for the 

Doe Run Company facility. Total actual lead emissions including fugitive emissions are 20.7 

tons per year (TPY). The risk dataset includes 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 the 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 subject to the MACT standard emission limit. It should be noted that 

non-volatile metal HAP other than 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 the total 17.9 TPY and are subject to the MACT emission 

limit.

The actual emissions dataset for this facility represents the entire source category. Likewise, all 

emission points located at this facility and that emit HAP are included in the risk analysis 
Primary Lead Smelting NESHAP Technical Support Document 

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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 surrogate for all other non-volatile metal HAP emitted 

from the source.. For the Doe Run facility, allowable 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 Doe Run’s 2008 lead production of 

149,564 tons, the aggregate allowable emissions results in aggregate lead emissions of 74.8 TPY 

from the above nine sources. All emissions from the source’s nine emission 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 between the two stacks based on the ratio of actual 

emissions reported for the two stacks. 

Note that refining operations are not listed above and are 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 were regulated under the provisions addressing 

fugitive emissions sources, however, based on more recent requirements adopted by the State, 

refinery emissions are now captured, controlled by a baghouse, and vented through two stacks. 

We were unable to calculate an allowable emission level for refining 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 control fugitive dust emissions.” Thus, 

the actual fugitive emissions, which reflect the measures that have been put in place, would be 

equivalent to the allowable emissions. Fugitive 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 

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Table 1.2 Summary of Actual and Allowable Lead Emissions for the Doe Run Primary Lead 

Smelter, 20081

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 source category are based on the MACT limit (1 

lb/ton) applied to 2008 production data . The modeling file for this risk analysis 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. 
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2.0 Calculation of Proposed Emission Limits Based on Modeled

Concentrations  

The risk analysis process included modeling of actual and allowable emissions to determine the 

anticipated concentration at individual receptor locations. For this source category, the 

emissions for the lead emissions sources were individually modeled for each receptor location 

and the results were compared to the Primary National Ambient Air Quality Standard (NAAQS) 

for lead (0.15 μg/m3

). 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 highest concentration location was a point on the 

property boundary. Emissions contributing 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 modeled 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 emissions being treated as one emission point) was 

analyzed to determine what emission levels would be necessary to reduce risk to an acceptable 

level i.e., such that modeled emissions met or were below the level of the NAAQS. EPA 

assumes that if the highest or worst-case concentration at a receptor location 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 reduced 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 given 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 relationship between level of emissions and modeled 

concentrations is linear, a percentage reduction could be applied to the actual emissions from the 

CY 2008 emissions inventory for a given emission point that would reflect the same reduction in 

modeled concentration. Therefore, a calculation was made for each emission point to determine 

what percent reduction in concentration was required 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 concentration location for the furnace area and refinery 

stack overlapped at the same census block (census block #). Therefore, their combined 

concentrations at that location would 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 stack (Baghouse #9) showed an exceedance of the 

NAAQS. The emission reduction found necessary from Baghouse #9 stack is 66 percent. It 
Primary Lead Smelting NESHAP Technical Support Document 

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was also found that the furnace area and refinery stack emissions maximum lead concentration 

overlap at the same census block (census block #290997006014031). To address the overlap, 

these points would need to be reduced together such that the lead 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 calculations and recommended limits for the total facility including 

furnace area/refinery stacks and fugitive dust 
Primary Lead Smelting NESHAP Technical Support Document 

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Table 2.1 - Calculations of Risk-Based Emission Limits Based on Modeled ConcentrationsModeled Source

2008 Emissions 

(tpy)

Modeled lead 

concentration 

at the site of maximum 

impact

(μg/m3

)

Roll back to 

meet NAAQS

%

Emissions after 

rollback (tpy) N

Stacks 

 - Furnace area (Baghouse #7) 1.81 0.314 52 0.86 At census block #290 - Refinery stacks 2.74 0.4363 66 0.94 At census block #290

Combined Stacks 4.55 0.7503 80 0.91

Fugitives All Fugitives 2.94 7.289 98 0.06 fume, sinter and conc

Roadways, plant yardHighest concentration receptor location

1) Emission Limit Lead concentration in air* 0.15 μg/m3

2) Emissions Cap  Furance Area and refinery stacks 0.91 TPYCalculations Roll back % = (Actual concentration - 0.15)/actual concentration

Emissions after rollback = 2008 emissions * (1-(rollback%/100))

* Measured at locations representative of property boundary as determined by the Administrator

PROPOSED ACTIONS

All Modeled Sources
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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 technology reviews of the current NESHAP for primary lead smelters. 

Under our ample margin of safety analysis, we considered addition controls 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 impacts analysis conducted 

on additional emission control options that were 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 performance achievable from technological improvements. 

In addition we are proposing to increase the frequency of monitoring stack emission from the 

current annual emissions testing to quarterly testing. This section, therefore, also includes 

estimates of the impacts for the additional monitoring costs necessary to comply with proposed 

requirement. 

We note that the controls that reduce lead emissions are the same controls that would reduce 

emissions and risks from cadmium and other metal HAP; therefore we are not proposing 

additional controls for other metal HAP. 

For the main stack emission point, we considered the option of upgrading of existing baghouses 

from the use of cloth bags to membrane bags and the option of adding 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 implemented by the facility to attain the additional 

emissions reductions that would provide 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 analysis indicates that emissions do not result in ambient lead levels 

exceeding the NAAQS based on either actual or allowable emission 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, since those levels are currently being achieved. 

We evaluated additional controls such as membrane bags or add-on baghouses as a means for 

achieving those reductions and reducing 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 emissions allowable under MACT should be reduced 
Primary Lead Smelting NESHAP Technical Support Document 

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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 costs and cost-effectiveness 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 Document 

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Total Cost 

Investment

Total 

Annualized 

Cost

2008 Baseline 

Pb Emissions 

(tpy)

Emission Reduction 

from 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 to

Membrane Bags

Table 3.1 - Cost Effectiveness of Upgrading to Membrane Bags for Main Stack

Impacts

Source

Pb emissions (tpy) 

reported in 2008 

EI

Pb emission reduction 

with additional BH 

assuming 50% RE (tpy)

Pb emission reduction 

with additional BH 

assuming 97% RE (tpy)

Annualized cost of 

adding extra BH's 

($/yr)

Cost effectiveness 

assuming 50% RE 

($/ton)

Cost effectivenes

assuming 97% R

($/ton)

Main Stack 13.31 6.7 12.9 $1,529,730 $229,862 $118,485

1 Reflects costs for pulsejet baghouses2 See DRAFT ImpactsEst_PrimLeadRTR_122210.xls for detail on cost analysis.

RE = Removal efficiency

Table 3.2 - Cost Effectiveness of Adding an Additional Baghouse to Control Emissions for the Main Stack 1,2
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3.2 Additional Testing and Monitoring Costs

To demonstrate compliance with the new plant-wide emission limit, EPA is proposing to require 

quarterly stack testing. Although the method for testing is the same as it was under the current 

MACT, the quarterly frequency requirement imposes additional impact with regard to the cost of 

additional testing. 

The proposed additional testing and monitoring requirements will result 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 Cost1

Stack Testing Method 12 $13,000 per test $39,000 

1

 Includes 3 additional stack tests 
Primary Lead Smelting NESHAP Technical Support Document 

APPENDIX A 

Doe Run Company, Herculaneum, MO 

2005 NEI (NATA) - Volatile Organic HAP from Boilers 

Risk Screening 
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