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 Deleted: DRAFT 12/28/10¶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 Sour ce Category ...............................................................................................................

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

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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 Ri sk-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 Am ple 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 Field Code Changed Deleted: Acceptability

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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 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 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 EP A 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 standard s apply to a source category emitting a HAP that is “classified as a known, probable, or poss ible 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 thresh old for each HAP to determine the potential for Deleted: would be

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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 crite ria 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 cate gory 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 emissi ons 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 em itted 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, Deleted: due

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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 emi ssions and other data to identify data anomalies that could affect risk estimates. Since the 200 8 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 CY 2008 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 19 97, 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 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 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

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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 em itted. 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 vert ical 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 em issions 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 f ugitive 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 em ission 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 re presents the entire source category. Likewise, all emission points located at this facility and that emit HAP are included in the risk analysis Deleted: ) which are the HAP currently regulated under the MACT standard.

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

1.2.2 Al lowable 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 in to 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. Fug itive emissions levels were taken from Doe Run’s 2008 Emissions Inventory that is submitted annually to the MDNR. Deleted: NESHAP

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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) Si ntering, blast furnace, dross furnace 13.31 65.8

Furnace Area (BH # 7) Sm elter building 1.81 8.94 Refining (BH # 8, 9) Refi ning 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. Deleted: N/A

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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 recepto r 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 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 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 emissi ons 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 Deleted: emissions from the main stack did not exceed NAAQS within the 50 km radius modeled. The

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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 recomm ended limits for the total facility including furnace area /refinery stacks and fugitive dust Deleted: stack, fugitive dust, and the refinery operations. Table 2.2 summarizes just the refining operation calculation, considering all contributing emission points.Primary 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)1.810.314520.86 At census block #290997006014031- Refinery stacks2.740.4363660.94At census block #290997006014031Combined Stacks4.550.7503800.91FugitivesAll Fugitives2.947.289980.06fume, 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 SourcesField Code ChangedDeleted:Table 2.1 - Calculations of Risk-BasModeled SourceStacks- Furnace area (Baghouse #7)- Refinery stacksCombined StacksFugitivesAll Fugitives1) Emission LimitLead concentration in air*2) Emissions CapFurance Area and refinery stacksCalculationsEmissio*MeasuredatlocationsrepresentativPROPOSED ACTIONS... [2]Primary 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 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 no t 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 monitoring stack emission from the current annual emissions testing to quarterly tes ting. 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 fa cility 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, sinc e 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 Deleted: to require most of

Deleted: emission sources at the facility to implement all technically feasible

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Deleted: the lead NAAQS, which is the level we have determined will ensure an acceptable level of risk. EPA has determined that lead compound emissions must be reduced to allow for an acceptable level of risk

Deleted: fugitive dust emissions, emissions from the furnace area stack, and the refining operation. As a result, the facility will need to implement emission controls or other actions that will reduce lead emissions to an acceptable level and to meet the new emission limits/caps in this proposed rule. In addition, in order to demonstrate compliance with these limits,

Deleted: ambient lead continuous monitoring is being required.¶

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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. Deleted: 3

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Formatted: Font: Not ItalicPrimary Lead Smelting NESHAP Technical Support Document12Total CostInvestmentTotalAnnualizedCost2008 BaselinePb Emissions(tpy)Emission Reductionfrom upgrade*(tpy)CE($/ton)Main Stack1,958,851 322,823 13.318.040,424*We estimate removal efficiency for membrane bag update to be between 50 and 70 percent.Cost of Upgrade toMembrane BagsTable 3.1 - Cost Effectiveness of Upgrading to Membrane Bags for Main StackImpactsSourcePb emissions (tpy)reported in 2008EIPb emission reductionwith additional BHassuming 50% RE (tpy)Pb emission reductionwith additional BHassuming 97% RE (tpy)Annualized cost ofadding extra BH's($/yr)Cost effectivenessassuming 50% RE($/ton)Cost effectivenessassuming 97% RE($/ton)Main Stack13.316.712.9$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 Stack1,2Deleted:Total CoInvestmFurnace area, BH 7 81,548Refining, BH 8102,032Refining BH 9366,932*We estimate removal efficiency for membrCosMeTable 3.1 - Cost EffectiveneDeleted:SourcePb emissions (tpy)reported in 2008EIPasMain Stack13.311Reflects costs for pulsejet baghouses2See DRAFT ImpactsEst_PrimLeadRTR_122RE = Removal efficiencyTable 3.2 - Cost EffeDeleted:¶Total CostInvestmentMain Stack 1,958,851*We estimate removal efficiency for membrane bag upCost of UpgrMembraneTable 3.3 - Cost Effectivenesso¶... [8]Primary Lead Smelting NESHAP Technical Support Document

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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 Cost 1 Stack Testing Method 12 $13,000 per test $ 39 ,000

1 Includes 3 additional stack tests Deleted: 3

Deleted: Based on the elevated risk levels found for the furnace area stack and the refining operation stacks, EPA is proposing emission caps for those emission points.

Deleted: emission caps and the

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Deleted: In addition, the risk analysis results indicate that modeled lead concentrations exceed the NAAQS at several of the property boundary receptor locations. Since the impact at these locations is driven by fugitive dust emissions, EPA is proposing an ambient lead concentration limit at the property boundary. To demonstrate compliance with this limit, EPA is proposing to require ambient lead monitoring at four locations that would be most representative of the highest modeled emissions of lead. ¶

Deleted: additional monitoring requirements will cause annual costs for the performance of

Deleted: . Since EPA assumes that monitoring equipment will be leased and not purchased, there are no anticipated capital costs associated with the new requirements. We have determined the

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## 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

Page 1Primary Lead Smelting NESHAP Technical Support DocumentAppendixAPage2Primary Lead Smelting NESHAP Technical Support DocumentAppendixAPage3Primary Lead Smelting NESHAP Technical Support DocumentAppendixAPage4Primary Lead Smelting NESHAP Technical Support DocumentAppendixAPage5Primary Lead Smelting NESHAP Technical Support DocumentAppendixAPage6Primary Lead Smelting NESHAP Technical Support DocumentAppendixAPage7Primary Lead Smelting NESHAP Technical Support DocumentAppendixAPage8Primary Lead Smelting NESHAP Technical Support DocumentAppendixAPage9Primary Lead Smelting NESHAP Technical Support DocumentAppendixAPage10Primary Lead Smelting NESHAP Technical Support DocumentAppendixAPage11Primary Lead Smelting NESHAP Technical Support DocumentAppendixAPage12Primary Lead Smelting NESHAP Technical Support DocumentAppendixAPage13Primary Lead Smelting NESHAP Technical Support DocumentAppendixAPage14Primary Lead Smelting NESHAP Technical Support DocumentAppendixAPage15Primary Lead Smelting NESHAP Technical Support Document

Appendix A

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Appendix A

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Appendix A

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## Table 1.1 - Summary of Doe Run Comp any Risk Dataset Emission Sources Fugitive Stack Total

HAP Number of Sources TPY Number of Sources TPY Number of Sources TPY
Lead 115 2.8053 22* 17.9030 137 20.7083 Antimony 6 0.0028 4 0.0252 10 0.0280
Arsenic 10 0.0005 6 0.0210 4 0.0215
Cadmium 12 0.0296 7 0.0823 19 0.1118
Chromium 0 0.0000 3 0.0056 3 0.0056
Cobalt 6 0.0005 6 0.0049 12 0.0054
Nickel 8 0.0019 7 0.0154 15 0.0172 *Of

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### Table 2.1 - Calculations of Emission Limits Based on Modeled Concentrations

Modeled Source 2008 Emissions (tpy) Highest receptor location Concentration Roll back % Emissions after rollback (tpy) N o Stacks - Main 13.31 0.007 0 13.31 No risk impacts with in - Baghouse #7, furn ace area 1.81 0.314 52 0.86 At census block #29 0 - Baghouse #8 - refinery kettles 2.03 0.079 0 see below Included in refinery m - Baghouse #9- refinery buiding 0.45 0.352 57 see below Included in refinery m Total of BHs 7+8+9 4.29 0.745 80 15.12

Refinery stacks 2.74 0.4363 66 0.94 BHs #8, #9 and heat max calculation

Smelter Fugitives 2.55 6.94 98 0.06 Fume, sinter and con c Plantwide Fugitives 0.39 1.063 86 0.06 Roadays, plant yard, r All Fugitives 2.94 7.289 98 0.06

1) Emission Limit
Ambient lead concentration at property boundary* 0.15 ug/m3

2) Emissions Cap Furance Area stack (BH#7) 0.86 TPY Refinery stacks 0.94 TPY

* To address 98% reduction needed from fugitive emissions, with receptor location at property boundary.

Calculations Roll back % = (Actual concentration - 0.15)/actual concentration Emissions after rollback = 2008 emissions * (1-(rollback%/100)) 

### RECOMMENDED ACTIONS All Modeled SourcesPage 9: [2] Deleted Veronica Hanzel 2/1/2011 12:33:00 PM



### Table 2.1 - Calculations of Emission Limits Based on Modeled Concentrations

Modeled Source 2008 Emissions (tpy) Highest receptor location Concentration Roll back % Emissions after rollback (tpy) N o Stacks - Main 13.31 0.007 0 13.31 No risk impacts with in - Baghouse #7, furn ace area 1.81 0.314 52 0.86 At census block #29 0 - Baghouse #8 - refinery kettles 2.03 0.079 0 see below Included in refinery m - Baghouse #9- refinery buiding 0.45 0.352 57 see below Included in refinery m Total of BHs 7+8+9 4.29 0.745 80 15.12

Refinery stacks 2.74 0.4363 66 0.94 BHs #8, #9 and heat max calculation

Smelter Fugitives 2.55 6.94 98 0.06 Fume, sinter and con c Plantwide Fugitives 0.39 1.063 86 0.06 Roadays, plant yard, r All Fugitives 2.94 7.289 98 0.06

1) Emission Limit Ambient lead concentration at

p roperty boundary* 0.15 ug/m3

2) Emissions Cap Furance Area stack (BH#7) 0.86 TPY Refinery stacks 0.94 TPY

* To address 98% reduction needed from fugitive emissions, with receptor location at property boundary.

Calculations Roll back % = (Actual concentration - 0.15)/actual concentration Emissions after rollback = 2008 emissions * (1-(rollback%/100)) 

### RECOMMENDED ACTIONS All Modeled Sources

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## fugitive dust emissions, which ar e controlled by work practices , no additional controls were evaluated because all reasonable practices are curr ently being implemented. Therefore, there are no additional controls and cost impacts consider ed for fugitive dust emis sions however, based on our proposed concentration limit, we have evaluated

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## costs for ambient monitoring to meet the requirement. For the four

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## addition of an in-series baghouse emi ssion as emission reduction options.

## 3.1 Emission Control Costs for Acceptability Reductions
Emissions from the main stack did not trigger unacceptable ri sk levels however; emission reductions were required from the furnace ar ea (baghouse #7), refining kettles (baghouse #8), refinery building (baghouse #9) and fugitive dust to meet acceptability re quirements. Although costs are not considered under s ection 112(f)(1) (acceptab ility) in order to meet acceptable risk, EPA has estimated the cost impacts for these emis sion controls for the fu rnace area and refining operation stacks, and has also estimated the cost s for the proposed ambi ent lead monitoring.
EPA estimates that replacing existing cloth bags in all baghouses will provide an approximately 95 percent reduction in emissions from the e mission points controlled by baghouses.

Table 3.1 summarizes the costs and cost-effect iveness upgrading existing baghouses from cloth bags to membrane bags. Table 3.2 summa rizes the costs and cost-effectiveness

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## The calculations supporting the costs reflect ed in the summary are included in EXCEL spreadsheet DRAFT ImpactsEst_P rimLeadRTR_122210.xls found in the docket.

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## Because all feasible controls wi ll need to be adopted in order to meet the risk acceptability reductions, there are no

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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 3.3 - Cost Effectiveness of Upgrading Baghouses 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 effectiveness assumin g 97% RE ($/ton) Main Stack 13.31 6.7 12.9 $1,529,730 $229,862 $118,485

1 Reflects costs for pulsejet baghouses

2 See DRAFT ImpactsEst_PrimLeadRTR_122210.xls for detail on cost analysis. RE = Removal efficiency Table 3.4 - Cost Effectiven ess of Adding Additional Baghouses to Control Emis sions for the Main Stack 1 , 2

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## A bi t L d M it i (l b P i d it i l $127 t t $185 420

## Ambient Monitoring Equipment Annual Lease $2,500 per unit $10,000