MEMORANDUM 

Date:    November 19, 2010

To:    Docket  

From:      V. Hanzel, M. Laney, RTI International

Subject:     Summary of Information Collection Request (ICR) Response  

Doe Run Resources Corporation, Herculaneum, MO

Purpose: 

The purpose of this memo is to summarize the response received from The Doe Run Resources 

Corporation (DRRC) to the December 4, 2009, Section 114 Information Collection Request for 

the Primary Lead Risk and Technology Review rulemaking effort. The Doe Run Resources 

Corporation is the sole facility in the Primary Lead Smelters industry category for which USEPA 

is requesting information. 

Background: 

USEPA is conducting research in support of the CAA Section 112(d)(6) and (f)(2) residual risk 

an technology (RTR) review for the “Primary Lead Smelter” source category. To gather current 

facility and emissions data for the source category, USEPA requested updated information be 

submitted by the sole covered facility, the Doe Run Resources Corporation, in Herculaneum, 

MO, under authority of CAA Section 114. 

 

The facility responded to the request on February 5, 2010. The sections below summarize 

information provided by Doe Run with respect to the requested information and identify any 

gaps in information as well as highlight new information provided in the ICR pertinent to the 

RTR process and rulemaking effort. 

A portion of the response was marked as “Confidential Business Information” and was logged 

and filed under CAA CBI requirements. The CBI included in the ICR response included test and 

process information pertaining to a hydrometallurgical process (FLUBOR®) for lead production 

that DRRC is developing to replace the current pyrometallurgical process at the Herculaneum, 

MO facility. It should be noted that the fact that the FLUBOR® process is being developed is 

public knowledge and available through many public sources and only the specific technical 

information provided in the ICR is considered to be CBI. Based on the CBI classification, this 

summary will not include any discussion of the contents of that portion of the ICR response. 
Doe Run Resources Corporation 

ICR Response Summary 

 

November 19, 2010 2 

Below is a summary of pertinent information provided in the ICR response, organized by the 

sections of the ICR. 

Part I Doe Run Facility Information

Section - Name and address of the legal owner and primary lead smelting facility. 

Owner: The Doe Run Resources Corporation 

1802 Park 270 Drive, Suite 300 

St. Louis, MO, 63146. 

Primary lead smelting facility: Herculaneum Smelting Division 

 881 Main Street 

 Herculaneum, MO 63048. 

Section 2- Name, and street address of each mine that supplies the Herculaneum facility, the 

total ore processed by each mine, and the amount sent to the Herculaneum facility in CY 2008. 

Table 1 – Mine Ore Concentrate Production and Shipments CY 2008 

 Total Concentrate (short dry tons) 

Mine Name/Location Produced Shipped to Herculaneum 

Buick Mine/Mill, Boss, MO 100,764 33,124 

Brushy Creek Mine/Mill, Boss, MO 68,800 66,873 

Fletcher Mine/Mill, Centerville, MO 88,569 84,338 

Sweetwater Mine/Mill, Ellington, MO 29,745 20,745 

Section 3- Total amount of ore processed and lead produced at the Herculaneum lead smelter 

for CY 2008. Total ore processed - 207, 980 tons 

Total lead produced - 149,564 tons 

Section 4 - Lead production at the Herculaneum lead smelter, 2000 through 2007. 

Lead production was highest in 2000 at 238,846 tons and dropped significantly (>35%) by 2002 

and then fluctuated slightly over the next five years, with the lowest production at 136,673 tons 

in 2007. Table 2 below summarizes the annual production rates. 
Doe Run Resources Corporation 

ICR Response Summary 

 

November 19, 2010 3 

PM10 PM2.5 SOx NOx VOC CO Lead HAPS1 NH3

2008 149564 14.72 10.76 35997 12.31 2.21 23.26 19.26 0.18 0.37

2007 136573 21.95 13.43 32904 22.15 3.5 27.89 21.77 0.15 0

2006 168030 26.72 16.96 44306 24.82 0.92 6.08 26.42 0.26 0

2005 154752 27.12 17.46 41845 24.77 2.56 21.06 28.09 0.29 0

2004 163734 25.22 32.26 16679 24.3 2.72 22.47 25.95 0.25 0

20032 150550 46.12 33.98 14866 36.71 3.53 31.21 25.13 0.22 0

2002 154652 86.63 0 15223 21.4 2.42 21.13 58.8 0.57 0

2001 191629 128.56 0 26641 25.93 3.24 24.28 110.39 1.68 0

2000 238846 149.17 0 28833 29.13 3.91 25.34 125.82 0.83 0 1

 Approximately 96% of HAP emissions reported other than lead are speciated metals - antimony, arsenic, cadmium, 

 cobalt and nickel

2

 2002 SIP controls implemented

Pollutants Reported

Table 2 - Herculaneum Lead Production and Emissions Inventory Summaries - 2000 to 2008

Lead 

Year Production

Section 5 - Emissions test reports. 

Table 3 summarizes the test reports provided by the facility. All tests were for lead only. All 

tests were performed using USEPA Method 12 for compliance demonstration either for 40 CFR 

Part 63 Subpart TTT or compliance with the Title V Permit limit for the sources. 

Main Stack

(All Equip.)

Main Stack

Blast Furn 

Only

Low alpha 

baghouse BH 7/9 BH 8

#3 Kettle 

heater 

exhaust

#4 Kettle

 heater 

exhaust

Mar, 1999 35.75 0.03

Apr, 1999 37.88 0.02

May, 1999 80.98 20.075

May, 1999 27.75 1.4

Jun, 1999 0.0529 15.854

Oct, 1999 81.1 3.03

Jan, 2001 38.72 1.541

Apr, 2001 25.35 4.72

Apr, 2002 23.651 23.032

Jan, 2003 24.363 17.246

Dec, 2004 19.6 7.1

Dec, 2006 N/A 3.8

Jun, 2008 N/A 15.8445 0.2956 0.0297

Mar, 2009 N/A 0.0615 0.0291

Jun, 2009 N/A 15.6018

Lead Emission Rate (lb/hr)

Test Date

Production 

Rate (lb/hr)

Table 3 - Herculaneum Smelter Emission Test Report Summary

Doe Run provided copies of the annual Emissions Inventory Questionnaires prepared for CY 

2000 through 2008. Table 2 above summarizes the facility total emissions in tons per year as 

reported. Pertinent information regarding the emission inventories include: 

 Inventories were prepared for the State of Missouri pursuant to their Title V permit 

 Inventories provided for all emission points covered by the Title V permit for the 

pollutants shown 
Doe Run Resources Corporation 

ICR Response Summary 

 

November 19, 2010 4 

 The primary HAP reported was lead 

 Approximately 96% of the HAP reported other than lead were speciated metals 

antimony, arsenic, cadmium, cobalt, and nickel 

 The HAP emissions were based on engineering calculations and the 1997 performance 

test conducted for MACT compliance 

 Facility lead and PM emissions decreased significantly from 2000 through 2008 

 The most dramatic decrease occurred between 2001 and 2002-2003 which can be 

attributed to implementation of significant engineering and work practice controls 

required based on a 2002 SIP revision to address fugitive emissions of lead 

Section 6 - Soil monitoring test results. 

Doe Run provided a property boundary map showing soil lead concentrations in mg/Kg on the 

site. 

Section 7- Property boundaries. 

A map was included in the response. 

Section 8 - Information on emission points/units and emissions limits and/or work practice requirements 

as contained in 2007 State operating permit 

A table containing the information requested in contained in Attachment 1. 

 All emissions provided were from CY 2008 

 All emission sources were addressed 

 No new sources were identified 

 No limits or emissions not previously identified were reported 

Section 9 - Results from the latest sampling an analysis conducted on the ore concentrate including the 

concentration of all ore concentrate constituent and the date of the sampling and analysis.   

 The facility provided the June 8, 20008 ore sampling analysis results. 

 Notable constituent values included lead at 79% by weight and sulfur at 14.59%. 

 Several other metals were reported in low concentrations and mercury was reported at 

below detection limit. 

Section 10 - Work practices and pollution prevention techniques. 

 The facility provided an attachment which included a copy of Work Practice Manual for 

Control of Lead Emissions (with appendices), dated January, 2007 

 According to Doe Run, the manual was a requirement of the State of Missouri regulations 

and the 2007 revision to the State Implementation Plan (SIP) for the Herculaneum Lead 

Nonattainment area 

 The manual addressed specific work practices for all areas of the facility including the 

yard and haul roads and included monitoring and surveying requirements 

Section 11 - Monitoring, recordkeeping, and reporting requirements. 

The facility responded that all of the information requested is set forth in the Doe Run’s current operating 

permit, #OP2006-011B which was included as an attachment. 
Doe Run Resources Corporation 

ICR Response Summary 

 

November 19, 2010 5 

Section 12 - Cost information for each add-on control device. 

The facility provided total costs (or budgets) for each 2000 and 2007 SIP projects. The table 

below summarizes cost information provided. 

Table 4 – Add-on Control Device Cost Summary 

SIP 

Year Project Description 

Total 

Cost 

2000 Addition of or update to #7, #8 and #9 baghouses 

Building enclosures for the blast furnace and refinery buildings 

$12.5 M 

2007 31 projects ranging in cost from $5K to $2.9M 

Most significant project costs were; 

 relocation of the #1 blast furnace – $2.9M 

 blast furnace front end ventilation improvements - $500K 

 several projects including pugger area enclosure, regenerative air sweeper purchase, 

and baghouse improvements (pleated filter cartridges and increased stack heights) – 

>$200K each 

$6.1M 

Section 13 - Startup and shutdown. 

The facility responded with specific answers as indicated below as well as providing an 

attachment showing startup/shutdown procedures for the sinter machine, blast furnace, refinery 

and, and baghouses. 

a. Frequency of smelting operations startup and shutdown (e.g. routine, never, etc.):

o Depends on the storage capacity of the final product 

o No statistics were available on frequency 

o Shut down of the blast furnace occurs roughly every three to four months for one to 

two days to clean ventilation ducts 

o Acid plant shuts down occasionally due to major projects in other areas of the plant. 

b. Listing of procedures followed or any activities that occur during startup and shutdown. 

An attachment provided listing of procedures. 

c. Indication of whether the emission profile of the process units are different during 

startup and shutdown than during normal operating conditions. 

Doe Run stated that plant operations do not yield excess emissions during startups and 

shutdowns.

d. If the answer to 11.c. is yes, provide a detailed explanation of how emissions are different 

during startup and shutdown and why. 

Not Applicable. 

e. Indicate whether there is test data showing emissions during startup or shutdown.

No test data showing lead emission during equipment startup or shutdowns. 

CEMS data since summer 2009 provides test results for SO2 emissions only, but none of 

the CEMS results are tied to startup/shutdown. 

f. Please submit any test data you have conducted during any startup or shutdown. 

No data available. 

Part II – Information Concerning Demonstration Project and Related Activities 

Future Plans – Facility provided information classified as CBI. 
Attachment 1 

Doe Run Resources Corporation ICR Response Summary April 9, 2010 
Attachment 1 

Doe Run Resources Corporation ICR Response Summary April 9, 2010 
Attachment 1 

Doe Run Resources Corporation ICR Response Summary April 9, 2010 
Attachment 1 

Doe Run Resources Corporation ICR Response Summary April 9, 2010 
Attachment 1 

Doe Run Resources Corporation ICR Response Summary April 9, 2010 
Attachment 1 

Doe Run Resources Corporation ICR Response Summary April 9, 2010 
Attachment 1 

Doe Run Resources Corporation ICR Response Summary April 9, 2010 
Attachment 1 

Doe Run Resources Corporation ICR Response Summary April 9, 2010 
Attachment 1 

Doe Run Resources Corporation ICR Response Summary April 9, 2010 
Attachment 1 

Doe Run Resources Corporation ICR Response Summary April 9, 2010 
Attachment 1 

Doe Run Resources Corporation ICR Response Summary April 9, 2010 
Attachment 1 

Doe Run Resources Corporation ICR Response Summary April 9, 2010 
Attachment 1 

Doe Run Resources Corporation ICR Response Summary April 9, 2010 
Attachment 1 

Doe Run Resources Corporation ICR Response Summary April 9, 2010