## 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, Sec tion 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 fo r the source category, USEPA reque sted 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 Fe bruary 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 in formation provided in the ICR pertinent to the RTR process and rulemaking effort.

A portion of the response was marked as “Conf idential 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 hydrometa llurgical 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 pub lic sources and only th e 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 c ontents 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 owne r 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 mi ne, and the amount sent to the He rculaneum 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 le ad 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 Herc ulaneum lead smelter, 2000 through 2007. Lead production was highest in 2000 at 238,846 tons and dropped si gnificantly (>35%) by 2002 and then fluctuated slightly ove r the next five years, with th e 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 HAPS 1 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

2003 2 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

Production Year



### 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 fo r compliance demonstration either for 40 CFR Part 63 Subpart TTT or compliance with th e Title V Permit limit for the sources.

Main Stack (All Equip.) M a i n S tac k

Blast Furn Only Low alpha baghouse BH 7/9 BH 8 #3 K ett l e
heater

exhaust #4 K ett l e
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 Emissi ons Inventory Questionnair es prepared for CY 2000 through 2008. Table 2 above summarizes the fac ility total emissions in tons per year as reported. Pertinent information regard ing the emission inventories include:

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

 Inventories provided for all emission poi nts covered by the Title V permit for the pollutants shownDoe Run Resources Corporation ICR Response Summary

November 19, 2010 4 

###  The primary HAP reported was lead

 Approximately 96% of the HAP reported ot her than lead were speciated metals antimony, arsenic, cadmium, cobalt, and nickel

 The HAP emissions were based on engineer ing calculations and the 1997 performance test conducted for MACT compliance

 Facility lead and PM emi ssions decreased significan tly from 2000 through 2008

 The most dramatic decrease occurred between 2001 and 2002-2003 which can be attributed to implementation of significan t 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 showi ng soil lead concentrations in mg/Kg on the

site.

Section 7- Property boundaries. A map was included in the response.

Section 8 - I nformation on emission points/units and emi ssions 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 prev iously identified were reported

Section 9 - Results from the latest sampling an analysis conducted on the ore concentrate including the concentration of all ore concentrate constitu ent 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 attach ment 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 requir ement of the State of Missouri regulations and the 2007 revision to the State Implementa tion 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 requ ested 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 blas t 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 ventila tion 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 fo r the sinter machine, blast furnace, refinery and, and baghouses.

a. 

### Frequency of smelting operations start up 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 ve ntilation ducts

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

b. 

### Listing of procedures followed or any acti vities that occur duri ng startup and shutdown. An attachment provided listing of procedures.

c. 

### Indication of whether the emissi on profile of the process units are different during startup and shutdown than duri ng 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, pr ovide a detailed explanation of how emissions are different during startup and shutdown and why. Not Applicable.

e. 

### Indicate whether there is test data s howing emissions during startup or shutdown. No test data showing lead emission dur ing 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 Demonstr ation Project and Related Activities

Future Plans – Facility provided information classified as CBI.Attachment 1Doe Run Resources CorporationICR Response SummaryApril 9, 20101Attachment 1Doe Run Resources CorporationICR Response SummaryApril 9, 20102Attachment 1Doe Run Resources CorporationICR Response SummaryApril 9, 20103Attachment 1Doe Run Resources CorporationICR Response SummaryApril 9, 20104Attachment 1Doe Run Resources CorporationICR Response SummaryApril 9, 20105Attachment 1Doe Run Resources CorporationICR Response SummaryApril 9, 20106Attachment 1Doe Run Resources CorporationICR Response SummaryApril 9, 20107Attachment 1Doe Run Resources CorporationICR Response SummaryApril 9, 20108Attachment 1Doe Run Resources CorporationICR Response SummaryApril 9, 20109Attachment 1Doe Run Resources CorporationICR Response SummaryApril 9, 201010Attachment 1Doe Run Resources CorporationICR Response SummaryApril 9, 201011Attachment 1Doe Run Resources CorporationICR Response SummaryApril 9, 201012Attachment 1Doe Run Resources CorporationICR Response SummaryApril 9, 201013Attachment 1Doe Run Resources CorporationICR Response SummaryApril 9, 201014