UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION7 901 NORTH
srn STREET KANSAS CITY

, KANSAS 66101 IN THE MATTER
OF: The Doe Run Transportation

and Haul Routes Southeastern Missouri

) ) ) ) ) T HE DO E RUN RESOURCES CORPORATION

) Respondent. Proceedings under Section 7003 of the Resource Conservation

and Recovery Act

, 42 U.S.C.

§ 6900

, et seq

. , as amended.

) ) ) ) ) ) __ ____ ______ ____ ________________

) Docket No. RCRA-07-2007-0008 MODIFICATION

OF ADMINISTRATIVE ORDER ON CONSENTUNITEDSTATESENVIRONMENTALPROTECTIONAGENCYREGION?KANSASKANSAS66101INTHEMATTEROF:TheDoeRunTransportationandHaulRoutesSoutheasternMissouri)))))THEDOERUNRESOURCESCORPORATION)Respondent.ProceedingsunderSection7003oftheResourceConservationandRecoveryAct,42U.S.C.§etseq.,asamended.)))))))DocketNo.RCRA-07-2007-0008MODIFICATIONOFADMINISTRATIVEORDERONCONSENTI.INTRODUCTIONThefollowingsectionsoftheAdministrativeOrderonConsent("Order"or"AOC")arebeingmodifiedinordertoenhancetheeffectivenessoftheWorkbeingperformedbytheDoeRunResourcesCorporation,("Respondent"or"DoeRun")undertheOrder.ThemodificationisenteredintovoluntarilybytheUnitedStatesEnvironmentalProtectionAgency("EPA")andRespondent.AllParagraphsorsubparagraphsnotincludedinthisModificationshallremainasdraftedintheoriginalAOC,withtwoexceptions.ThePublicCommentandEffectiveDateParagraphsattheendofthisModificationareintendedforthisModificationonly.13.Unlessotherwiseexpresslyprovidedherein,termsusedinthisAOCthataredefinedintheRCRAstatuteshallhavethemeaningassignedtotheminthatstatute.WheneverthetermslistedbelowareusedinthisAOCthefollowingdefinitionsapply:"Concentrate"or"Lead-bearingConcentrate"shallmeanorethathasbeenprocessedatthemillconcentratefacilities,andincludesleadconcentrate,zincconcentrate,andcopperconcentrate.2"Doe Run Facilities" shall mean Doe Run owned and/or operated mines, mills, concentrators, smelters, and other facilities located

in southeastern Missouri where concentrate, ore, or lead-bearing materials
are transferred

on or off vehicles, including,
but not limited

to the Buick mine and mill, Brushy Creek mine and mill, Fletcher mine and mill, Sweetwater mine and mill

, #35 Mine, and #29 Mine; the Glover Smelter located

at Highway

49 North
in Annapolis, Iron County, Missouri;
the Herculaneum Smelter located

at 881 Main Street in Herculaneum

, Jefferson County, Missouri.
For purposes

of describing obligations

at various facilities pursuant to this AOC, the term "Doe Run facilities" shall also include Doe Run's concentrate handling and transportation activities

at the SEMO Port located

in Scott City, Scott County

, Missouri. Respondent

is electing

to cease smelting operations

of and delivery

of lead concentrate

to the Herculaneum Smelter
by December

31, 2013.
If Respondent begins transport

of lead concentrate to a new Doe Run owned and/or operated facility

in Missouri that facility shall be included

in the term "Doe Run facilities."

In addition,

if Respondent begins transport

of lead concentrate

to a new facility

at the former Herculaneum Smelter after ceasing smelting operations, that facility shall be included

in the term

" Doe Run facilities," whether

or not the facility that receives the lead concentrate

is owned and/or operated

by Doe Run

. 60

. Pr o j ec
t Coordin

a t o r s . Project Coordinators

for Respondent
and EPA are as follows: For Respondent: F o r EPA: Calvin
R. Keller Environmental Manager Primary Smelting The Doe Run Company 881 Main Street Herculaneum,

MO 63048 (636) 933-3143 and John E. Carter, P.E., R.G. Environmental Manager Southeast Missouri Mining and Milling Operations P

. O. Box 500 3 5 Iron County Road

# 1 Viburnum,
MO 655

6 6 (573) 244-8152 Jim Aycock Waste Enforcement

and Materials Management U.S. EPA, Region

7 901 N. 5th Street Kansas City

, KS 66101 (913) 551-7887

3RespondentshalldirectallsubmissionsrequiredbythisAOCtoEPA'sProjectCoordinator.CopiesofallsubmissionsrequiredbythisAOCshallbesenttoMr.TomJudge,MissouriDepartmentofNaturalResources,HazardousWasteProgram,P.O.Box176,JeffersonCity,Missouri65102-0176.EachProjectCoordinatorshallberesponsibleforoverseeingtheimplementationofthisAOC.EPAandRespondenthavetherighttochangetheirrespectiveProjectCoordinators.Theotherpartymustbenotifiedinwritingatleastten(10)dayspriortothechange.EPAretainstherighttodisapproveofanyProjectCoordinatornamedbyRespondent.IfEPAdisapprovesofaselectedProjectCoordinator,RespondentshallretainadifferentProjectCoordinatorandshallnotifyEPAofthatperson'snameandqualificationswithintwo(2)workingdaysfollowingEPA'sdisapproYal.ReceiptbyRespondent'sProjectCoordinatorofanynoticeorcommunicationfromEPArelatingtoAOCshallconstitutereceiptbyRespondent.a.TransportationComplianceManagers.Byfive(5)daysaftertheEffectiveDateoftheModification,RespondentshallidentifyaTransportationComplianceManager("TCM")toberesponsibleforoverseeingallofthecomplianceissuesassociatedwiththetransportationoflead-bearingmaterialsasidentifiedinthisOrder.Inaddition,theRespondentshallidentifyaTCMforeachfacilitycoveredbythisOrder.Thefacility-specificTCMshallbesomeonewhoisveryfamiliarwiththeoperationsatthatfacility.Inadditiontocomplianceresponsibilitiesattheirspecificfacility,thefacility-specificTCMshallberesponsibleforensuringthatpeoplewhoconductanyportionoftheWorkunderthisOrderattheirspecificfacilityshallbeappropriatelytrained.Thefacility-specificTCMshallbelimitedtooverseeingonlyonefacility,exceptatthemineormillfacilitieswhereafacility-specificTCMmayoverseemultiplefacilitieswithsimilaroperationsthatareinrelativelycloseproximitytooneanother.b.Training.RespondentshalldevelopandimplementanannualtrainingprogramforanypersonwhoconductsWorkunderthisOrderatanyfacilitycoveredbythisOrder.ThetrainingshallincludeinformationontherequirementsofthisOrder,includingitsattachedSOPs.Byfive(5)daysaftertheEffectiveDateoftheModification,RespondentshallsubmitthewrittentrainingmaterialstoEPAforreview,andRespondentshallcommenceimplementationofthetrainingprogramunlessanduntilEPArequestsrevisionstothetrainingprogram.AllpersonsconductingWorkunderthisOrdershallbetrainedwithinthirty(30)daysoftheEffectiveDateoftheModification,andannuallythereafter;allnewpersonshiredafterthatinitialtrainingdateshallbetrainedpriortoperforminganyWork.PersonssubjecttotrainingshallincludeTCMs,truckdrivers,inspectors,truckwashoperatorsandotherappropriatepersonnelthatperformWorkunderthisOrder.c.Audits.Respondentshallretainanindependentthird-partyenvironmentalcontractortoperformauditsofitscompliancewiththeprovisionsofthisOrderanditsSOPs.Byfive(5)daysaftertheEffectiveDateoftheModificationRespondentshallprovidetoEPAthenameandqualificationsoftheenvironmentalcontractorthatDoeRunwouldproposetoretainforperformingaudits.EPAretainstherighttodisapproveofthecontractorselectedby4Respondent.

If EPA disapproves ofRespondent's selection, Respondent shall propose

a different party
to perform the audits and shall notify EPA of the name and qualifications

of that party within thirty (30) working days ofEPA

' s disapproval

. IfEPA fails to disapprove Respondent

' s proposed environmental contractor within thirty (30) days of receipt
of notification

of qualifications, Respondent's proposed environmental contractor shall be deemed approved,
the contractor may be retained and the audit process may commence

. Respondent shall provide the wash and inspection SOPs and related materials

to the auditor for review, and Respondent shall present the standard training course

to the auditor prior to commencement

of the actual audits.

A full independent third-party audit shall be conducted

at each facility

a minimum

of once every year after an initial audit of each facility has been completed.
The audit shall include

a review

to evaluate whether the inspections
and washing

of all lead-bearing vehicles

at each of the vehicle wash stations are being conducted pursuant

to the requirements

of the Order and

a report shall be prepared

by the auditor and submitted

to EPA and Respondent

as set forth herein. Respondent shall submit
an audit report form for approval

by EPA within sixty (60) days of the Effective Date of the Modification, which includes,
but is not limited
to, the wash station being audited

, the date and time of the audit, the name of the person conducting

the audit

, all of the provisions of the SOP for washing and inspecting trucks transporting lead-bearing

ma

t erial that will be audited,

all deficiencies noted, recommended corrective actions, the Respondent official

to whom the audit report was provided

, and the date the audit report was provided

to Respondent.
The auditor

' s first report relating

to the initial audit(s) shall be due ninety (90) days after EPA's approval

of the auditor and audit report form. Subsequent quarterly audit reports shall be submitted within thirty (30) days after the end of each calendar quarter thereafter

. The audit report shall contain

a certification

by the auditor similar

to that found
in paragraph

89 of this Order. The auditor shall conduct

a full audit of two (2) or three (3) different facilities each quarter. The audits of each facility shall be random and unannounced

, but may require some advance coordination
with Respondent

to ensure access and that certain facilities that are potentially subject

to an audit will be operational

on the potential audit dates. 61

. Contractors

. Respondent shall perform the Work itself, or retain one or more contractors

to perform the Work. Should the Respondent elect to conduct the Work itself,

it shall notify EPA of its qualifications

to perform
the Work within fourteen (14) days of the Effective Date of this AOC

. Should Respondent retain

a contractor

to conduct the Work

, Respondent shall notify EPA of the name and qualifications

of each contractor within fourteen ( 14) days of the Effective Date of this AOC. Respondent shall also notify EPA ofthe name and qualifications

of any other contractor

or subcontractor retained

to conduct any portion
of the Work under this AOC
at least two (2) days prior to commencement

of such portion
of the Work. EPA retains the right to disapprove

of any party Respondent selects
to conduct the Work.

If EPA disapproves

of Respondent's selection, Respondent shall propose

a different party to perform the Work

· and shall notify EPA of the name and qualifications

of that party within ten ( 1 0) working days of EPA

' s disapproval.

a If Respondent contracts with trucking companies

for transportation

of lead-bearing materials

, the contracts shall specify that the trucks which are currently prov

i ding transport 5servicesforRespondent,andwhichareingoodstanding,shallbeparkedonthepropertyoftheRespondentorthecontracttruckingcompany,iffeasible.IfparkingonRespondent'spropertyoracontracttruckingcompany'spropertyisinfeasibleorundulyburdensomeduetoissuesincluding,butnotlimitedto,thedistancefromthedriver'shornetotherespectiYecommercialparkingpropertyorthelocationofthedriver'struckmaintenanceequipmentandservicingarea,atruckmaybeparkedatanindividualresidentialproperty,providedthetruckisparkedinadesignatedareawhichisseparatefromtheresidentialdriveway,awayfromtheresidenceandwhichisusedsolelyfortruckmaintenanceand/orparking.b.AnyemployeeofRespondentfoundtohaveviolatedtherequirementsofthisOrderincludingtheattachedSOPsmustbesubjecttoappropriatedisciplinaryaction,uptoandincludingpermanentterminationofemployment.·ForanycontractororconsultantfoundtohaverepeatedlyviolatedtherequirementsofthisOrder,DoeRunshallnotifytheassociatedemployerthattherespectivecontractororconsultantshallnotbeallowedtoconductworkforRespondentortohaveaccesstoRespondent'sproperty,therebyeffectivelyterminatingthatindividuarssenicetoRespondent.65.VehicleWashStationsa.Priortocommencingoperationofanewfacility,RespondentshallinstallandbegintooperateenclosedvehiclewashstationsatallDoeRunfacilitieswhereConcentrate,Ore,orlead-bearingmaterialsaretransferredonoroffvehicles,andthosevehiclesenter/exitthosefacilitiesaboveground.Thevehiclewashstationsshallbedesignedandbuilttobefullyandsafelyoperationalduringallseasonsoftheyear,includingfreezingte1nperatures;provided,however,thatduringperiodsofextremefreezingtemperatures(e.g.,below25°Fahrenheit),thescheduleforwashingOretrucksmaybesuspendedtominimizehazardousconditions,risksandpropertydamageassociatedwithexcessiveicebuild-upfrommultiple,high-frequencywashings.Allvehiclewashstationsshallbelocatedatorneartheexitofthefacilitypropertyandhavebackupwashsystemsintheeventthattheprimarywashsystemsareinoperative.NothinginthisAOCshallbeconstruedtorequireconstructionofadditionalvehiclewashstations(exceptwhereRespondentbeginsoperationofanadditionalsmelter,mine.millorconcentrator).b.Allvehiclewashstationsshallbedesignedtowashthevehicle'sentireundercarriage,entiresides,backsandtailgates,tiresandwheels.Inthealternative,ifthewashstationisnotdesignedtowashallofthecomponentslistedabove,theoperatorshallwashthoseomittedcomponentswithamanually-operated pressurewasher(ratedataminimumpressureof2200psi),andwillvisuallyinspecteachtruckandrewashanyareasofvisiblecontamination.AfterunloadingConcentratetrucks,theinteriorofthetrailerandbedlinerwillbewashedoutwithahosewithforceandvolumesufficienttoreachthetopofthebed/bedlinerontheraisedtrailer.Thebed/bedlinerwash-outshallbeconductedattheunloadingarea.Bedlbedlinerwashoutoperationsmaybesuspendedduringfreezingtemperatures.Thebed/bedlinerwash-outrequirementshallnotapplytotrucksunloadingandreloadinglead-bearingconcentrateatthe6Glover Facility. Respondent shall implement

the applicabl

e actions

in this sub-paragraph within thirty (30) days of the Effective Date of this Modification. d. Wash water and other lead-containing material generated

at the vehicle wash stations and wash-out areas shall be collected, treated, and discharged/disposed

in accordance with all applicable state and federal requirements

and permits. e. Respondent

has created two re\ised Standard Operating Procedures ("SOPs"), "V.'ashing
and Inspection

of Trucks Transporting Concentrate"

and "Washing/Inspection

of Vehicles Transporting

Ore or Lead-Bearing Materials," which are attached

to this Modification. These SOPs will be implemented

on the Effective Date of the Modification. 66. Road way and Str eet Cleaning

. a . At each Doe Run mine/mill facility,

as well as at the Herculanewn facility, Respondent shall thoroughly sweep with

a regenerative

air sweeper,

or a device of comparable efficiency,

all of the areas traveled
by the Concentrate

and Ore trucks leading from the exit side of the vehicle wash station

to the exit of the facility

at the juncture

of the public highway

or county road at least once each day. At Respondent's Glover and SEMO Port facilities, Respondent shall thoroughly sweep with

a regenerative

air sweeper,

or a device of comparable efficiency,

all of the areas traveled
by the Concentrate trucks leading from the exit side of the vehicle wash station

to the exit of the facility

at the juncture

of the public highway

or county road at least once each week.
In addition,
the interior roads from the loading

or unloading area to the wash station within the Respondent's facilities that are traveled
by Concentrate trucks shall be swept

at least once per week, except for the Herculanewn facility that is subject

to more frequent specific interior road cleaning under an existing Missouri Lead NAAQS SIP. During periods when freezing temperatures
may form snow, ice or hazardous conditions, street cleaning operations may be suspended. Respondent shall implement

the actions

in this subparagraph within ninety (90) days after the Effective Date of the Modification. 67. Enclosure

of Materials During Transit. a. Within thirty (30) days of the Effective Date of this Modification, 100% of contract carrier trucks used to transport Concentrate,
Ore, or lead-bearing materials generated at and transported

to and from Doe Run facilities

on public roadways
and streets shall be equipped with high density polyethylene bedliners (except Ore trucks), seals on tailgates, permanently sealed grain doors (if grain doors exist on the truck), tail gate locks and tail gate security bolts (with wing nuts, if applicable)

. c. Trucks transporting Concentrate,

Ore or lead-bearing materials

to and from Doe Run facilities shall be tarped while
in transit on public streets and roadways, when they are loaded and when they are empty, unless removed from dedicated service

as provided

in subparagraph

d. In addition, within one hundred-twenty
(120) days of the Effective Date of this 7Modification,alltruckstransportingConcentrateshallbeequippedwithbonnetstoreducetheairflowovertheleadingedgeofthetarp.69.ResidentialProperty,StreetandRoadEdgeSamplingandTransportationStudy.a.BeginningMay2007,andannuallythereafter,RespondentshallsampletheyardsurfacesoilandinteriordustofalloccupiedresidentialpropertiesalongtheConcentrate,Ore,orlead-bearingmaterialhaulroute(s)beingutilizedatthetimeofsamplingintheHerculaneumcitylimits,forwhichRespondentorEPAsecuredaccesspursuanttoSectionXI.ThissamplingshallbeconductedaslongasConcentrate,Ore,orlead-bearingmaterialsarebeingtransportedtoandfromHerculaneum,Missouribyvehicletransportation.g.Respondentshallperformsamplingataminimumoftwelve(12)residentialpropertiesalongConcentrateorOrehaulroutesleadingfromtheDoeRunfacilities.Withinsixty(60)daysoftheEffectiveDateofthisModification,Respondentshallprovidealistofatleasttwenty(20)residentialpropertieslocatedalongthehaulroutesfromtheDoeRunfacilities.EPAandRespondentwillagreeontwelve(12)residentialpropertiesrepresentativeoftheresidentialyardslocatedalongRespondent'shaulroutes.RespondentshallprovideadraftQualityAssuranceProjectPlanforthecollectionandanalysisofthesesampleswithinninety(90)daysoftheEffectiveDateoftheModification.Afteragreementonthepropertiestobesampled,RespondentshallattempttoobtainaccesstotheresidentialpropertiesasoutlinedinSectionXIofthisOrder(Sampling,AccessandDataAvailability).Ninety(90)daysafterreceivingapprovalfromtherespectivepropertyownerorEPA-approvaloftheQAPP,whicheverdateislater,Respondentshallcollectandanalyzeonemulti-aliquotsoilsamplefromthemid-yardareaofthetwelveresidentialpropertiesintheportionoftheyardclosesttotheroadway.Respondentshallperformsamplingandanalysisatthesetwelvepropertiesthereafterannually.TheresultsoftherespectivesamplingandanalysisshallbeprovidedtoEPAinthemonthlyreportrequiredinParagraph70followingthereceiptofthesamplingassaysforthoseproperties.h.HandlingandTransportationStudy.Respondentshallretainanindependentthird-partycontractortoconductaConcentrateHandlingandTransportationSystemEngineeringStudy(CHTSES)to:(1)benchmarkRespondent'scurrentlead-bearingmaterialsload,unload,transportationandmonitoringoperations,practicesandplannedimprovements;(2)identifyandevaluatecurrentload,unload,transportationandmonitoringoperationsandpracticesatothersimilarfacilitiesthatareinplacetoreducethepotentialforreleasesatthosefacilitiesandtheirapplicabilitytoRespondent'soperations;and(3)evaluatetheeffectivenessofandopportunitiesforimprovementtotheloading,unloading,transportation,andmonitoringpracticesimplementedundertheOrdertopreventreleasesoflead-bearingmaterialsinoff-siteareas.i.RespondentshallnotifyEPAofthenameandqualificationsoftheleadconsultantthatwillworkontheCHTSESwithinninety(120)daysoftheEffectiveDateoftheModification.RespondentshallalsonotifyEPAofthenameandqualificationsofanyother8contractor

or subcontractor retained

to conduct any portion
of the Work under this Section

at least two (2) days prior to commencement

of such portion
of the Work. EPA retains the right to disapprove

the lead consultant selected
by Respondent

to conduct the Work.

If EPA disapproves of Respondent's selection, Respondent shall propose

a different lead consultant

to perform the Work and shall notify EPA ofthe name and qualifications ofthat party within thirty (30) working days ofEPA's disapproval.

If EPA fails to disapprove Respondent's proposed lead consultant within thirty (30) days ofreceipt

of notification

of qualifications, Respondent's proposed lead consultant shall be deemed approved and the CHTSES process may commence. ii

. Respondent shall provide

to EPA for review and approval

a Work Plan and QAPP for the CHTSES within ninety (90) days of the approval

of Respondent's contractor. Quarterly reports
of progress

of the CHTSES shall be provided

to EPA. The first CHTSES quarterly progress report shall be completed

by no later than one hundred-twenty
(120) days after EPA's approval

of the Work Plan and QAPP

. A Final CHTSES Report shall be submitted

to EPA no later than sixty

( 60) days after the completion

of the CHTSES
for review and approval.

111

. Within
30 days of approval

of the Final CHTSES Report

, the Respondent shall provide

to EPA analysis and recommendations,

if any, for improvements

to the transportation

and materials handling activities covered under this Order. The analysis shall include discussion

on environmental benefits and costs of possible improvements referenced

in the CHTSES. EPA and Respondent
will meet to discuss Respondent's recommendations,

if any. Any further modifications

to the Order based on any recommendations
made by Respondent shall be made pursuant

to Section XXIll "Modification ofThis AOC" paragraph
141. 70. Monthly Monitoring Reporting a. Within forty-five (45) days of the Effective Date of this AOC and by the 15th day of every calendar month thereafter, Respondent shall submit

a monthly monitoring report (paper copy and electronic copy) for activities occurring during the previous month which includes, but is not limited

to

, analytical data collected pursuant

to this AOC, along with corresponding times, dates, locations, vehicle tag numbers and companies; details
of equipment failures

at the vehicle wash stations and loading and unloading stations; schedules

for repairs
of broken equipment; details
on any failures

to clean haul route roadways
and streets; details
of any spill or leak incidents and the resulting cleanup; progress

on construction

of the vehicle wash stations; details on operation

of the street sweeper; progress

in decreasing

the number
of contract carrier trucks used for transporting concentrate,
ore, or lead-bearing materials; and details on any changes

to the mode of transportation

of concentrate,
ore, or lead-bearing materials

by Respondent. 114. Stipulated Penalty Amounts

. a
.

A stipulated penalty
of $2,000 per violation
per day shall accrue for any noncompliance identified below:

91.FailuretosubmitanydeliverablesrequiredbythisAOCinatimelyoradequatemanner,otherthansubmissionofthemonthlymonitoringreport.ii.Failuretoperformsurface,soil,interiordust,road/street,orwipesamplingasrequiredbytheAOCinatimelyoradequatemanner.111.FailuretoconductroadwayandstreetcleaningasrequiredbythisAOCinatimelyoradequatemanner.tY.FailuretoimplementandperformtruckinspectionandwashproceduresinaccordancewithParagraph67.band65.e,respectiYely,inatimelyandadequatemanner;provided,however,thatstipulatedpenaltiesshallnotapplyifthissituationisnecessitatedbyareasonabledeviationthatisexplainedinv.Titingontheinspectionform.v.Failuretoconductauditspursuanttothetimeframesandconditionsinparagraph60.c.v1.FailuretoconducttheConcentrateHandlingandTransportationStudypursuanttothetimeframesand conditionsinparagraph69.h.b.Astipulatedpenaltyof$4,000perviolationperdayshallaccrueforanynoncomplianceidentifiedbelow:1.Failuretoconstructvehiclewashstationsinaccordance¥.ithParagraph65.aandb.inatimelyandadequatemanner.c.Astipulatedpenaltyof$1,500perviolationperdayshallaccrueforanynoncomplianceidentifiedbelow:1.Failuretosubmitawrittenmonthlymonitoringreportinatimelyoradequatemanner.n.AnyotherviolationoftheAOCotherthanthosemilestonesidentifiedin114.a,114.b,114.c,or114.d.d.Astipulatedpenaltyof$10,000perviolationshallaccrueforanynoncomplianceidentifiedbelow:1.Anytruckdriverobtainingaloadoflead-bearingmaterialinatruckthatwaspreviouslyrejectedfor"badorder"("BO")defect(s)whichwerenotcorrectedpriortoobtaininganotherloadoflead-bearingmaterial.ii.Anobservedreleaseoflead-bearingmaterialfromatrucktopubliclyaccessiblestreets,roads,residentialyardsorotherareaslocatedoutsideofDoeRunproperty.Theterm"observedrelease"meansdirectevidenceoflead-bearingmaterialdischargedfromatrucktopubliclyaccessiblestreets,roads,residentialyardsorotherareaslocatedoutsideofDoeRunproperty.Thistermspecificallyexcludesthefollowingeventsandconditions:(a)truckaccidentsresultinginspillsordischargesoflead-bearingmaterials(seeSpillResponsePlanparagraph68ofAOC);(b)stainingontheexteriorofthetrailerthathasnotresultedinadischargeorreleaseoflead-bearingmaterialfromthetrucktopubliclyaccessiblestreets,roads,residentialyardsorotherareaslocatedoutsideofDoeRunproperty;and(3)samplingconductedpursuanttothisOrderoranyotherUnilateralOrderorAdministrativeOrderonConsentthatindicatesthepresenceofleadorother10metals with no direct or recorded evidence

of a discharge

of lead-bearing material from

a truck hauling Respondent's lead-bearing materials. II. PUBLIC COMMEN

T EPA shall provide public notice and

a reasonable opportunity

for public comment

on the proposed Modification. After consideration

of any comments submitted during

a public comment period
of not less than thirty (30) days (which EPA may extend), EPA may \\ithhold consent

or seek to amend all or part of this Modification,

if EPA determines
that comments received disclose facts or considerations which indicate that this Modification

is inappropriate, improper,

or inadequate.

III. EFFECTIVE DAT
E The effective date of this Modificat

i on shall be the date on which EPA signs the Modification, following public comment specified

in Section

II. The undersigned representative of Respondent certifies that s/he
is fully authorized

to enter into the terms and conditions

of this Modification

and to bind the Respondent

to this document. Respondent agrees not to contest the validity

or terms of this Modification,

or the procedures underlying

or relating

to it in any action brought

by the United States, including EPA,
to enforce
its terms or seek penalties
for its violations. Respondent retains
its rights
to assert claims against any third parties with respect

to this site.

11IT IS SO ORDERED AND AGREED. **~lu~** Becky Webber

S Director Air, RCRA and Toxics Division United States Environmental Protection Agency Region

7 For The Doe Run Resources Corporation:

12 Date )E
C' 10 DateI

CodeN°: I **.,.~ ~** 

.... ...,........ ......... COMPANY STANDARD OPERATING PROCEDURE Washing and Inspection

of Trucks Transporting Concentrate

Original Issue Date

: 3/6

/ 08 Approved

by:

Date:

Update Date: Environmental Department

August 2010 1.0 Overview Doe Run

is committed

to protecting human health and the environment. Effective wash and inspection procedures
and Wash Stations require

a team effort involving
the participation

and support
of every Doe Run employee, contractor
and consultant who deals with trucks loading

or unloading lead-bearing concentrate ("Concentrate")

at a Doe Run-owned

or -operated facility.

It is the responsibility

of every user to understand
this Standard Operating Procedure ("SOP"), and to conduct their activities accordingly. 2.0 Purpose The purpose

of this SOP

is to outline the method

of cleaning trucks

at Doe Run's Missouri facilities where Concentrate

is transferred onto or off of trucks, where the trucks enter/exit facilities above ground, and to defme methods

of backup due to mechanical failure

at the Wash Station. This SOP
is in place
to protect human health and the environment. 3.0 Scope This SOP applies

to employees, contractors, consultants,

and other workers

at Doe Run's Missouri facilities, including affiliated third party personnel. This policy applies

to all equipment that is used to handle and transport Concentrate
over the public roads

. Other vehicles that enter or cross an area within

a Doe Run facility where Lead-Bearing Materials

are handled

or stored shall be washed and dried
in the vehicle wash station prior
to exiting the facility. Inspection forms will not be required
for these other vehicles that are not transporting Concentrate,

Ore or other Lead

- Bearing materials

to

. and from Doe Run facilities

. This SOP includes Appendices. Note Appendices may vary from site-to-site

in order
to enhanc

e the training and lend insight

to site-specific requirements.

The purpose
of the SOP

is to provide consistency

in the truck inspection
and wash operations

to allow for effective statistical process control. Any variation will be
a result of very minor differences

in configuration

and location

of wash stations and ancillary equipment (e.g.

, tanks, water valves

, piping, power washer, etc.)

. While the specific physical conditions may be different from site to site, the basic objectives
and standard requirements

are identified and must be achieved

at all facilities. Any material deviation must be set forth
in a site-specific appendix
and be both submitted
and approved

by the EPA. Although they may vary in content, each site will have the following appendices: ./ Appendix

1 Pre

- Operating Checklist

for Wash Stations
for Trucks Transporting Concentrate ./ Appendi x 2 Operating Guidelines

- Inspection

of Trucks

at Concentrate Loading Stations ./ Appendix

3 Operating Guidelines

- Procedures

for Wash Stations
for Trucks Transporting Concentrate ./ Appendix

4 Operating Guidelines

- Inspection

of Trucks

at Concentrate Unloading Stations ./ Appendix

5 Inspection Form for Trucks Transporting Concentrate The following
are covered

by the policy:

Pag

e 1 of 6 080

3 /80004

3

. 0009/9462149

. 1 0001CodeN

° : **I!!WI** .... **~**

.... .., .. COMPANY STANDARD OPERATING PROCEDURE Washing and Inspection

of Trucks Transporting Concentrate

Original Issue Date: 3/6/08 Approved

by

:

Date

:

Update Date

: Environmental Department

August2010 ../ Every truck leaving

a facility above ground after loading

or unloading Concentrate

. ../ Every truck that enters
or crosses
an area within

a Doe Run facility where lead·bearing materials
are otherwise handled

or stored

. ../ Wash Stations

. ../ Wash Station Operators. 4

. 0 Inspection

of Concentrate Trucks Before and After Loading and Unloading Before receiving

a load or unloading, Concentrate trucks must be inspected

in accordance with either Appendix

2 Operating Guidelines

- Inspection

of Trucks

at Concentrate Loading Stations ("Before Loading Trucks")

or Appendix

4 Operating Guidelines

- Inspection

of Trucks

at Unloading Station ("Before Unloading Trucks"),

as applicable. Once loaded

or unloaded,

the Concentrate trucks must be inspected

in accordance with either Append
ix 2 Operating Guidelines - Inspection

of Trucks

at Concentrate Loading Stations ("After Loading Trucks")

or Appendix

4 Operating Guidelines- Inspection

of Trucks

at Unloading Station ("Aft

e r Unloading Trucks"),

as applicable

. After inspection,
the truck may proceed

to the Wash Station. 5.0 Operating Policies Only Certified Operators

are to operate the Wash Station. Certification

is based on: ../ Demonstrated understanding

of the SOP, training manual, safety practices, inspection practices

. ../ Hands
on training performed

by
a certified trainer for both the automatic wash system and the power washer

. ../ A written test will be administered

to verify training. Automatic Facility Design Requirements

: Shall be enclosed. Shall be designed

to fully and safely operate during
all seasons
of the year

. Shall be located

at or near the exit of the facility property. Shall have backup wash systems

as described

in Section 5.3. The Design will be to wash: undercarriages, entire sides, back, tailgates, tires, mud flaps, wheel wells and wheels

. ../ The facility will have the necessary equipment such as spray nozzles, power wash rated at a minimum 2200 psi, etc., at appropriate location, position and angle such that baseline performance

is met or exceeded. These parameters
will be inspected
and recorded

on
a regular basis

a part of the Pre-Operating Checklist

for
V l ash Stations
for Trucks Transporting Concentrate (Appendix

1 ) . c During the pre-operating check the Operator will check the aim and integrity of the nozzles

to assure the Wash Station

is in optimum operating condition. o Water flow and recharge rates

. and pressures will vary upon facility design and available resources
and will meet or exceed performance

of baseline measurements taken
at Herculaneum during the 100 0-truck baseline sample. o Water will be sampled once per month

to check for

l ead content. ../ Wash Water will be collected, treated and discharged

in accordance
with

a ll state and federal requirements

and penil.its.

P ag e 2 of6 0803/800043

. 0009/9462149.1
DDOlCodeN°: **~aa**
... ......,...,....,

.. COMPAII'/ STANDARD OPERATING PROCEDURE Washing and Inspection

of Trucks Transporting Concentrate

Original Issue Date

: 3/6/08 Approved

by:

Date:

Update Date: Environmental Department

August 2010 5.1 Before Operation

of Wash Station for Concentrate Trucks The following procedures
will be performed/followed

at the beginning

of each day shift,
in accordance with Appendix

1 Pre-Operating Checklist

for Wash Stations
for Trucks Transporting Concentrate

. 1. Start-up Wash Station. 2. Run

a wash cycle empty with no truck present. 3. Operator must complete

a pre-operating checklist

of the facility. 4. The pre-operating checklist

is to be turned into the supervisor
and kept on file for

1 0 years

. 5. The supervisor will forward requests
for corrective action
to the maintenance department. 6. If Wash Station

is deemed inoperable during
or after the pre-operating inspection,

see Section

5 .3 for alternative washing techniques. 7. After Correctiye Action

is complete

. a record will be placed into the file. 5.2 Operation ofWasb Station 1. Truck pulls up to the entrance

of the Wash Station and waits for signal
to enter.

A stop/go light system will be employed

at facilities

in conjunction
with the attendant

to signal allowed movements. 2
. Operator must make sure truck

is properly lined up with Wash Station. Failure

to do so could result
in damage

to truck and facility. 3. Operator will grant entry to Wash Station only when system has sufficient water to run an entire cycle without disruption

of water flow or pressure. 4. When entry

is granted, wash cycle will automatically
start,

5 mph
is the maximum speed limit (as posted), and Operator shall control truck speed
to ensure adequate wash and dry cycle retention times. Driver will move truck forward, pause and stop as directed
by Operator based on the condition

of the truck and the phases
of the automatic
and manual power wash cycles and the dry cycle. 5. The truck shall be retained

in the wash cycle for

a minimum

of 40 seconds.

It is recommended

that the wash cycle timer be set at 50 seconds.

If truck

is not retained

in wash cycle for 40 seconds, either manually power wash entire truck
as set forth

in Section
5.3 or require truck
to re-enter the automatic wash system. 6. After the automatic wash, Operator may use 2200 psi power washer

to manually power wash load-side

of truck, including entire side (top to bottom), wheels and tires, mudflaps, back side and tailgate. This manual power wash may be conducted

for each truck
as
a routine part of wash process.

If this procedure

is implemented, Operator would mark both "Manual" and "Auto"
on the Inspection Form. 7. The truck shall be retained

in the dry cycle for

a minimum

of 40 seconds.

If blowers have

a separate "trip" mechanism,

it is recommended

that the dry cycle timer be set at 40 seconds

. If blowers have only one "trip" mechanism,

it is recommended

that the dry cycle timer be set for 70 seconds. a. Blowers will turn on prior
to any part of the truck passing the blowers' forced-air zone. b. Blowers will commence before entire wash cycle

is completed. Page

3 of6 0803/800043

. 0009/9462149

.1 DDOlCodeN°:THE..............COMPANYSTANDARDOPERATINGPROCEDUREWashingandInspectionofTrucksTransportingConcentrateOriginalIssueDate:3/6/08.Approvedby:Date:UpdateDate:EnvironmentalDepartmentAugust2010c.Blowerswillremainonuntilthesidesandallwheels/tireshavepassedtheblowers'forced-airzone.d.Blowersshallbere-triggeredifmanualpowerwashorspotwashoccursafterinitialdrycyclehasended.8.Driverwillbeinstructedtostopthetruckatadesignatedspot(nomorethan70'fromtheWashStation)whichallowsapproximately1/3oftrailertoremaininsideofWashStationforinspectioninaccordancewithSection5.4.·5.3OperationinEventofAutomaticWashCycleMalfunction1.Operatorshallusemanuallyoperatedpowerwasherratedataminimum2200psi.2.Themanuallyoperatedpressurewasherwillbeused insidetheWashStation.3.Usetop-downapproachtomanuallywashtrucks.Withthepowerwasher,startatthetopleadingedgeandwashfronttoback.Uponreachingtheback,lowerspraylocationtojustbelowlastsweepandcontinuewashtowardfrontoftruck.Continuethisprocessofwashingtoptobottomuntilspraydistributionreachesbottomedgeoftrailer.4.Washallofthefollowingkeytruckcomponents:entiresides,back,wheelsandtires,wheelwell,mudflaps,undercarriage,andtailgate.5.Aftercompletionofmanualpowerwash,Operatorshalltriggerblowersanddirecttruckthroughthedrycycle.6.OnInspectionForm,markonly"manual"wash(not"auto"),andnotethereason.5.4TruckInspectionandWipeSampling1.Aftertheroutinewash(i.e.,automaticwashandmanualpowerwash)anddrycyclesarecomplete,andthetruckhasstoppedatthedesignatedspot(nomorethan70'fromtheWashStation)whichallowsapproximately1/3oftrailertoremaininsideofWashStationforinspection,Operatorshallinspecttheexteriorofthetrailer,includingsides,tailgate,graindoor,airlocks,wingnuts,mudflaps,tiresandwheels,andcompletetherelevantportionoftheInspectionFormforTrucksTransportingConcentrate(Appendix5).Specificallynotethefollowing:a.tailgateand graindoorsealshavenogapsandaresecurelylatched.b.airlocksaretightagainsttailgate.c.wingnutsareinplace,secureandworkingproperly.d.noteanyvisiblestainingandmarklocationontheInspectionForm.e.forBrushyCreekonly,itisrecommendedthattheOperatorinspect(fromthetopoftheladder)thetopofthetarpforloosematerialthatmayha-vedroppedontotarpfromoverheadconveyor.Ifpresent,Operatorshalluseappropriatedevicetoremoveanyloosematerial.2.Ifvisiblestainingisobserved,Operatorshall:a.notelocationontheInspectionForm.b.spotwashthosespecificareaswithmanuallyoperatedpowerwasher.c.manuallytriggerblowersandrequireportionoftrailerthatwasspotwashedtorunthroughdrycycleagain.3.OperatorshallconductWipeSa-mpleon10%oftrucks(beginningwiththefirsttrucktoproceedthroughthewashstationeachday)andon"badorder"("BO")trucks.ThewipePage4of6DB03/800043.0009/9462149.1DDOlCo d e N°: **~**

... **~** .......... COIPAif'l' STANDARD OPERATING PROCEDURE Washing and Insp

e ction of Trucks Transporting Concentrate

Original Issue Dat

e : 3 / 6 / 08 Approved

by:

Date:

U pdate Date: Environmental Department

.\ugust 2010 sample procedure

is detailed

in the Quality Assurance Project Plan for Truck Wipe Sampling
and in the Truck Wipe Sample Checklist posted

at all wash stations; please refer to it for specific procedures. 4

. If any key truck component

is in defective condition

or "bad order" ("BO"), Operator shall: a. circle "Out of Sen·ice" and note reason
on Inspection Form. b. require truck to unload (only
if carrying

a load)
in approved lead-bearing material storage area, wash out bed/bedliner,

and return through Wash Station before leaving the facility premises. c. conduct Wipe Sample. d. explain

to Driver the basis for the BO classification

and that no loads may be received

by that truck until the defective condition
has been corrected

. e
. provide copy of Inspection Form
to Driver for immediate written notification

of the defect; the Driver

is required

to return said Form
to the trucking company. 5
. Upon completion

of inspection,

all inspection requirements

and observations

are to be noted on the Inspection Form. 6. Inspection sheets will be turned
in to the supervisor, who will forward truck numbers and required repairs

to all employees, contractors, consultants,

and temporary ·employees who supervise over the road lead-bearing transportation systems. Inspections have been designed

to inspect both incoming and outbound trucks
to help ensure

a deficient truck does not attempt

a subsequent haul. 5

. 5 Routine Cleaning

of Facility 1 . Pressure wash (rated
at minimum pressure

of 2200 psi) the first 70 feet of roadway from the exit side of the Wash Station and the Wash Station floor mice during the day and at the end of the day. 2

. This
is to be done by starting
70 feet from the Wash Station utilizing

a high-pressure wash (rated
at minimum pressure of2200 psi) and cleaning toward the facility drain. 5.6 Safety Guidelines 1. Safety equipment required includes appropriate personal protective equipment, including but not limited to, eye protection, hard-hat, gloves and protective boots. 2

. In the winter be cautious

of ice. 3
. Remember water lines, hoses and spray wands are under high pressure

. During operation the Operator must stand clear

. 4. Operators must also stand clear of blowers during operation 5
. Truck Drivers are to remain

in the trucks with doors and windows shut 6
. The Operator should never walk between
the truck and the Wash Station exit door. Always use man doors and aisle ways

. 6

. 0 Enforcement Any employee, contractor, consultant,
and temporary employ
ee found
to have violated this policy might be subject

to disciplinary action, up to and including termination

of employment. Page

5 of6 06 03/800043.0009/9462149.1

0001CodeN°: **~8.1**
... **~~~** COMPANY STANDARD OPERATING PROCEDURE

Original Issue Date: Washing and Inspection

of Trucks Transporting Concentrate

3/6/08 Approved

by

: Environmental Department 7.0 Definitions Term Certified Operator Certified Trainer Lead-Bearing Concentrate Lead-Bearing Materials

Date:

Update Date

: August 2010 Definition Has read and understands

the SOP and Training Manual. Has demonstrated knowledge

of all tasks
to Certified Trainer through hands on training

. Has passed the written test. A salaried member

of the environmental department

or
a Certified Operator who has scored 95% or better on the written test. Ore that has been processed

at the mill Concentrate facilities

, and includes lead concentrate,
zinc concentrate,

an d copper concentrate

. All granular

or semi-granular product

or waste material which contains more than 400 milligrams
per kilogram (mglkg)

of lead. The Parties
do not interpret this definition

to include contaminated
soils excavated from residential yards, road edges, churches, vacant lots or high child impact areas.

Page

6 of6 DB03/800043.0009/9462149.1

0001

:**~~** ....

CodeN°: ..,.,... .........

SOP Appendix

1 CO.MPAHY Pre-Operating Checklist

- Wash Stations
for Vehicles

Is sue date: Transporting Concentrate Prepared

I Reviewed

by:

Date

:

l Approved

by

:

Date

:

U pdate date: Environmental Department

Environm

en tal Departm

en
t August2010 Operator Name. ______________

Operator Name

_ _ ____

_ ______

_ Operator Name ______________

Operator Name

_ _ _________

**~--** Date __________

_ B 0

0 K

Ch

k Th
F II ec

e

0 OWIDg

A

f T k CIOn

a en Hi2h Pressure Washer Pump Oil Level High Pressure Washer-

All Belts are in place Hi2h Pressure Washer -Electrical Cord High Pressure Washer- Leaks-Oil/Water Check for Water Leaks-Lines/Hoses/Wands Condition

of Spray Wands and Hoses Drain Water Lines (At the end of each shift) Fire Extinguishers/Current Inspection Tag Sump Pump operating correctly Blowers operating correctly Damage

to Buildin2 (Interior

& Exterior) Roll up doors operating pr@erly Water supply line solenoid valve workin2 Side, Tire and Undercarriage Spray Bank Flows -/ Nozzle Angles, Standoff Distance and Location- Any dislocated,

No longer

in place, bent, signs of metal fatigue, damage

to the banks themselves. -/ Nozzle Condition, Cleanliness, integrity and pressure

- (Yisual guide located

in Training Manual) Both Roll up Doors are above Door Frame Stop/Go li2ht system working COLD WEATHER OPERATION Heat Tape pl022ed

in (Cold Weather Only) Furnace turned
on (Cold Weather Only) Spray banks weeping (Cold Weather Only) NOTE: Marking "BO" for an item means you found that Item to be m bad order. Pressure washed
70 feet exiting Wash Station

3 times daily. Start: Initials:---------- Middle: Initials:---------- End: Initials:---------- Conunents ___ ____ _____ ____ ____

_ ___ ____ __ ___ _____ _ _ EQUIPMENT MUST BE INSPECTED AND SIGNED
BY ALL USERS AND PLACED ON CLIP BOARD OR DESIGNATED HOME LOCATION

IN EACH DEPARTMENT. 0803/800043

. 0009/9418356

. 1 0001**~a**
... ..,....... r::t/.::1 OPERATING GUIDELINES (August 2010)

- SOP Appendix

2 INSPECTION

OF TRUCKS
AT CONCENTRATE LOADING STATIONS Before loading trucks 1. Request from Driver: certification materials and most recent Truck Inspection Form:
if prior BO, note correction(s)

on current Form

. 2. Elevate trailer: inspect underside

of bed from side of truck for holes and visible contamination. 3. Inspect tarp position and condition from ladder/platform
while tarp
is still in place covering trailer, including

the following conditions

: a. no holes or tears in tarp (i.e

. , "thumb" rule)

. b. no **~between**

tarp and rim. c. tarp and/or bonnet

in place to prevent wind from entering over front edge. Stay on ladder

/ platform and have driver role upon the tam. 4. Inspect bedliner from ladder/platform

for: a visible holes or tears b. correct position **(no~** b/w bedliner and rails, inside walls and bed of trailer). 5. Inspect exterior
of trailer from ground level, including sides, tailgate

, grain door, air locks, wing nuts, and placards

, and ensuring that all components

are in closed and secured position upon arrival prior to loading. Specifically
note the following: a. tailgate and grain door seals have no gaps and are securely latched. b. air locks are tight against tailgate

. c. wing nuts are in place, secure and working properly. d. placards
are in place and secured

to truck, with bolts

/ fasteners intact. e. observation

of visible contamination should be noted on the relevant part of the truck on the Form. If components

are in good order

, then advance truck forward

to scale

. 6. If

· any key truck component

is in defective condition

or "bad order" (BO): a. do not load truck. b. reject, place "Out of Service", and note reason on Form. c. if condition exists that does not warrant

a "BO" please note on Form. d. wash and sample

at Truck Wash Station

. e. explain

to Driver the basis for BO classification

and that no loads may be received by that truck until defective condition
has been corrected

. DB03/800043.0009/9337577.3

WP06**~I!!U**
... ..,..,._ **~y;r;** OPERATING GUIDELINES (August 2010)- SOP Appendix

2 INSPECTION

OF TRUCKS
AT CONCENTRATE LOADING STATIONS After

l oa ding trucks 1. Inspect rim of trailer from ladder/platform
while tarp
is rolled back in open position.

If loose material

is on trailer rim

, use rim cleaning tool to remove. Once rim is in good order, roll tarp into closed/secured position. 2. Inspect .mr,p (closed/secured position) from ladder/platform

: a . no gaps between tarp and rim

. b
. no tears or holes
in tarp

. c. tarp and/or bonnet are in place to prevent wind from entering over front edge. d. no loose material
on top of tarp

. Ifloose material

is present, remove loose material with appropriate device. 3. If truck

is in good order: a. complete
and initial relevant portions

of Truck Inspection Form b. provide one copy to Driver c
. authorize Driver

to proceed

to Truck Wash Station. 4. If any key truck component

is in defective condition

or "bad order" (BO)

: a . unload truck. b. reject, place "Out of Service", and note reason on Form. c
. if condition exists that does not warrant

a "BO" please note on Form

. d. wash and sample

at Truck Wash Station

. e. explain

to Driver the basis for BO classification

and that no loads may be received by that truck until defective condition
has been corrected

. 0 803/8

0 0 04 3. 0009

/ 9 33 7 5 77. 3 WP06**~a.**
... **.,-~ ~¥D**  OPERA

T ING GUIDE

L INES (August 2010)- SOP Appendix

3 PROCEDURES
FOR WASH STATIONS FOR TRUCKS TRANSPORTING CONCENTRATE Before Operation

of Truck
W a s h 1. T ruck pulls up to entrance

of Vi ash Station and waits for signal
to enter. 2. Operator must make sure truck
is properly lined up with Wash Station. Failure

to do

s o could result
in damage

to truck and facility. 3
. Operator will grant entry
to Wash Station only when system has sufficient water
to run an entire cycle without disruption

of water flow or pressure

. Op era ti o n o f T ruck Wash (Routine Wash and Dry Cycles) 1. Wash cycle shall be set in excess
of 40 seconds and triggered automatically,

and truck shall be retained

in wash cycle for at least 40 seconds. 2
. When entry
is granted, Operator shall control truck speed
to ensure adequate wash and dry cycle retention times

. Truck will drive forward and stop at designated spot prior to blowers

. Wash cycle will continue

as truck
is stationary allowing
for maximum cleaning of trailer and wheels. a . Signs will be posted for speed limit. b. Operator will indicate allowed truck movements. c
. If truck

is not retained

in wash cycle for 40 seconds, either power wash entire truck or instruct truck
to re-enter truck wash. 3. After the automatic wash, Operator shall use 2200 psi power washer

to manually wash load-side

of truck, including entire side (top to bottom), whe

e ls and tires, mudflaps, back side and tailgate. This manual power wash shall be conducted
for each truck
as a routin

e part of wash process.
On Truck Inspection Form

, Operator shall mark both "Manual" and"Auto". 4. Dry cycle shall be set in excess
of 40 seconds and triggered automatically,

and truck shall be retained

in drv cycle for at least 40 seconds. a .

. Blowers may commence before entire wash cycle
is completed. b. Blowers shall be re-triggered

if manual power wash or spot wash occurs after initial dry cycle has ended. 5
. Truck shall stop at designated spot which allows approximately

1 / 3 of trailer
to remain inside of Wash Station for inspection. Operation

in event of Automatic Wash Cycle Malfunction 1 . Operator shall use manually operated power wash

e r rated
at a minimum 2200 psi. 2. Use top-down approach

to manually wash trucks. With the power washer, start at the top leading edge and wash fron

t to back. Upon reaching
the back

, lower spray location

to just below last sw e ep and continue wash toward front of truck

. Continue this process
of washing
top to bottom until spray
di s tribution reach es bottom edge of trailer. DB O J/ 8 00043

. 0009/9347809

. 1 WP06...•lc,VJ.l!OPERATINGGUIDELINES(August2010)-SOPAppendix3PROCEDURESFORWASHSTATIONSFORTRUCKSTRANSPORTINGCONCENTRATE3.Washallofthefollowingkeytruckcomponents:entiresides,back,wheelsandtires,wheelwell,mudflaps,undercarriage,andtailgate.4.Aftercompletionofmanualpowerwash,Operatorshalltriggerblowersanddirecttruckthroughthedrycycle.5.OnTruckInspectionForm,markonly"manual"wash(not"auto"),andnotereason.TruckInspection1.Aftertruckhasstopped,Operatorshallinspectexterioroftrailer,includingsides,tailgate,graindoor,airlocks,wingnuts,mudflaps,tiresandwheels.Specificallynotethefollowing:a.tailgateandgraindoorsealshavenogapsandaresecurelylatched.b.airlocksaretightagainsttailgate.c.wingnutsareinplace,secureandworkingproperly.d.noteanyvisiblecontaminationandmarklocationonForm.e.forBrushyCreekonly,fromtopofladderOperatorshallinspecttopoftarpforloosematerialthatmayhavedroppedontotarpfromoverheadconveyor.Ifpresent,Operatorshalluseappropriatedevicetoremoveanyloosematerial.2.Ifvisible contaminationisobserved,Operatorshall:a.notelocationonForm.b.spotwashthosespecificareaswithmanuallyoperatedpowerwasher.c.·manuallytriggerblowersandrequireportionoftrailerthatwasspotwashedtorunthroughdrycycleagain.3.OperatorshallconductWipeSampleon10%oftrucksandon"badorder"C'BO")trucks.4.Ifanykeytruckcomponentisindefectiveconditionor"badorder"("BO"),Operatorshall:a.circle"OutofService"andnotereasononForm.b.requiretrucktounload(onlyifcarryingaload)inapprovedlead-bearingmaterialstoragearea,washoutbed/bedliner,andreturnthroughTruckWashStationbeforeleavingthefacilitypremises.c.conductWipeSample.d.explaintoDriverthebasisfortheBOclassificationandthatnoloadsmaybereceivedbythattruckuntilthedefectiveconditionhasbeencorrected.5.Uponcompletionofinspection,allinspectionrequirementsandobservationsaretobenotedonTruckInspectionForm.DB03/800043.0009/9347809.1WP06**~I!U**

.... **~**

.-. c:if.t:l OPERATING GUIDELINES (August 2010)

- SOP Appendix

4 INSPECTION

OF T RUCKS AT CONCENTRATE UNLOADING STATIONS Before unloadin

g trucks 1. Inspect tal]? position and condition from ladder/platform
while tarp is still closed

, note the following conditions

: a. no holes or tears in tarp (i.e.

, "thumb" rule). b. no gaps bern·een tarp and rim. c
. tarp and/or bonnet

in place
to prevent wind from entering over fron

t edge. 2. Inspect exterior
of trailer from ground level, including sides

, tailgate, grain door, air locks

, wing nuts, and placards, and ensuring that all components

are in closed and secured position upon arrival prior
to unloading

. Specifically note the following: a
. tailgate and grain door seals have no gaps and are securely latched

. b
. air locks are tight against tailgate

. c. wing nuts are in place, secure and working properly. d. placards
are in place and secured

to truck, with all bolts/fasteners intact. e. note any visible contamination

and mark location

on Form. After unloading trucks 1. While trailer

is in completely raised position: a . wash out interior
of trailer and bedliner (unless reloading lead

- bearing material

at same location)

. b. during and/or

. after wash out inspect bedliner for: (i) visible holes or tears; (ii) correct position (no gaps

b / w bedliner and rails, inside walls and bed); and (iii) condition and posi
ti on ofbedliner
rail s. c. wash off trailer exterior components (including rim, load

s ide

, back, and tailgate). 2. While trailer

is in complet

e ly raised position: a. inspect bed (view under

s ide ofbed from rear side of truck) for visible holes and/or leaking water. b. if water leakage

is seen, lower trailer and conduct closer inspection

. 3. If any key truck component

is in defective condition

or "bad order" (BO): a. reject and place "Out of Service

" and note reason on Form

. b. wash and sample

at the truck wash station

. c. if condition exists that does not warrant

a "BO" please note on Form. d. explain

to Driver the basis for the BO classification

and that no loads may be recei

v ed by that truck until the de f ective condition
has been corrected. 4. If the truck
is in good order: a. complete and initial the relevant portions

of the Truck Inspection Form. b. provide one copy to Driver

. c. authori

z e Driver

to proc

e ed to T ruck Wash Station

. DB0 3/ 80004

3

. 0 009 /9337 572

. 1 WP06

# The Doe Run Company Inspection Form for Trucks Transporting Concentrate SOP Appendix 

# 5 My initia l s on this form certify under pena l ty of law that I 

# have inspected the areas of this truc k l i sted below. The information con t ained on t his form is , to the best of my kno wledge and beli ef, tru e, accurate, and complete. I 

# am aware that there are significant penalties 

# for submitting false information , including t he p os sibility of fine and i mprisonme nt for knowing violations. 

# Truck Cleanliness Loading Station Inspector Initial 

# Loading Wash Station Inspector /njtjal 

# Unl o ading Station Inspector Initial 

# Unloading Wash Station < 

# Particular attention to sides, rim , tailgate, t ires, 

# wheels, undercarriage mudllaps , steps > lnli.P.!:.clor /niti/1.1

Manual Auto Manual Auto

Yes No Yes No 

# I R 

# 'Cd CX5 

# co Mark location of stains/loose materials 

# I R 

# Ill (.X_) 

# CXJ 

# "----0 

# I R 

# ill (.X_) 

# CXJ 

# "----0 

# SJI L 

# CXJ CX) 

# Ill L 

# I u--co oo 

# Ill L 

# I u--- co CXJ 

# c;;J

**~**



# ~ **~**

**~** 

# ~ N/A Yes No N /A 

# Yes No 

# Truck Inspection

<If truck fails inspection, instruct to make U::itJOII"' II Ol UIIIUQUIII)f IV\IaliUII 1 YJ'QO>II VUL UCU UQIVI1J QIIUJYIIIM UU'-"' '-U I'IWiU.W'V t'lt:I IIL' 

# I

. . ... . . . I

__ I



# NOTES: 1) Each truck removed from service must 

# be sampled. 2) '80 ' 

# = t ruck componen t Is in bad order. 3) 'N /A ' 

# = not app lic ab le or not able to 

# be in sp ecte d. Buick

VIEW PRIOR LOAD SHEET

**(Loadin~** 

# lnsoector Onlvl Yes No 

# Fletcher Herculaneum Brushy Creek Glover

COMMENTS 

# Sweetwater SEMO Port

DATE LOADING TIME TRUCKING COMPANY

ANY ADDITIONAL COMMENTS 

# I NOTABLE CONDITIONS 

# Signature of Truck Driver Print 

# Herculaneum Buick Resource Glover Other :

__ _ Bussen Barae Other.

TRUCK NUMBER TRAILER NUMBER SCALE TICKET NUMBER



# Sign 

# I

I

WHITE COPY

- En v ironmental 

# Project Off!C8r 

# Y EL LOW COPY

- Carrier Dr i ver Copy P I NK 

# COPY

- load ilg Faci li ty Copy

### "Co d eN°: **.u.a.** ....,.,... "1oY.t:l STANDARD OPERATING PROCEDURE Washing/Inspection

of Vehicles Transporting

Ore or Lead-Bearing Materials Updated: August2010 1.0 Overview Doe Run
is committed

to protecting human health and the environment. Effective wash and inspection procedures
and Wash Stations require

a team effort involving

the participation

and support·
of every Doe Run employee, contractor
and consultant who deals with vehicles loading or unloading
Ore or Lead-Bearing Materials

at a Doe Run-owned

or -operated facility.

It is the responsibility

of every user
to understand
this Standard Operating Procedure ("SOP")

, and to conduct their activities accordingly. 2.0 Purpose The purpose

of this SOP

is to establish
the method
of washing and inspecting vehicles

at Doe Run's Missouri facilities where Ore or Lead-Bearing Materials

are transferred onto or off of vehicles, where the vehicles enter/exit facilities above ground, and to define methods

of backup due to mechanical failure

at the Wash Station. This SOP
is in place

to protect human health and the environment. 3.0 Scope This SOP applies

to employees, contractors
and consultants

at Doe Run's Missouri facilities, including affiliated third party personnel. This policy applies

to all equipment
that
is used to handle and transport Ore or Lead-Bearing Materials oYer the public roads. Other vehicles that enter or cross an area within

a Doe Run facility where Lead-Bearing Materials
are handled

or stored shall be washed and dried
in the vehicle wash station prior to exiting the facility. Inspection forms will not be required
for these other vehicles that are not transporting Concentrate

, Ore or other Lead-Bearing materials

to and from Doe Run facilities. This SOP includes Appendices. Note Appendices may vary from site-to-site

in order
to enhance the training and lend insight

to site-specific requirements.

The purpose
of the SOP
is to provide consistency

in the vehicle inspection
and wash operations

to allow for effective statistical process control. Any variation will be
a result of very minor differences

in configuration

and location

of wash stations and ancillary equipment (e.g., tanks, water valves, piping, power washer, etc.). While the specific physical conditions may be different from site to site

, the basic objectives
and standard requirements

are identified and must be achieved

at all facilities. Any material deviation must be set forth in
a site-specific appendix
and be both submitted
and approved

by the EPA. Although they may vary in content, each site v.ill have the following appendices: v' Appendix

1 Operating Guidelines

- Daily Inspection

of Vehicles Transporting

Ore or Lead-Bearing Materials v' Appendix

2 Pre-Operating Checklist
for Wash Stations for Vehicles Transporting

Ore or Lead-Bearing Materials v' Appendix

3 Inspection
and Wash Form for Vehicles Transporting

Ore or Lead-Bearing Material

s v' Appendix

4 Operating Guidelines

- Procedur

es for Wash Stations
for Vehicles Transporting

Ore or Lead-Bearing Materials The following

are covered
by the policy: ../ Every vehicle leaving

a facility above ground after loading

or unloading
Ore or LeadBearing Materials. 0803/800043

. 0009/938

9 102.3 WP06 080

3 /80004

3. 0009/9462110

. 1 0001

Pag

e 1 of6CodeN°:=---.........................COMPANYSTANDARDOPERATINGPROCEDUREWashing/InspectionofVehiclesTransportingOreorLead-IIearingMaterialsUpdated:August2010../WashStations.../WashStationOperatorsandInspectors.4.0InspectionofVehiclesTransportingOreorLead-BearingJ.\llaterialsVehiclestransportingOreorBearingMaterialsmustbeinspectedtwicedailybyaDoeRunOperator/InspectorinaccordancewiththeproceduresestablishedinAppendix1OperatingGuidelines-DailyInspectionofVehiclesTransportingOreorLead-BearingMaterials.The"FirstDailyInspection"isrequiredpriortothefirstloadoftheday.DrivermustprovidetoInspectortheprevioushaulingday'sInspectionandWashForm(VehiclesTransportingOreorMaterials).InspectorshallcompleteandinitialthesectionoftheForm(Appendix3InspectionandWashFormforVehiclesTransportingOreorMaterials)entitled"FirstDailyInspection",keepthebottomcopyoftheForm,andreturntheremainderoftheFormtoDriver.The"SecondDailyInspection"isrequiredsometimeafterthe4thloadandpriortothelastloadoftheday(timingofthesecondinspectionisatInspector'sdiscretion).InspectorshallcompleteandinitialthesectionoftheFormentitled"SecondDailyInspection",keepthetop(original)copyoftheForm,andreturnthemiddlecopyoftheFormtoDriver.InadditiontothemorecomprehensiveDailyInspections,loadedvehiclestransportingOreorMaterialsmustundergomorelimited"tailgateandriminspections"attheloadWashStationinaccordance·withAppendix4ProceduresforWashStationsforVehiclesTransportingOreorLead-BearingMaterials("TailgateandRimInspection")andtheappropriateareasontheFormmustbecompleted.Formswillbeturnedintotheresponsibledesignee,whowillforwardVehiclenumbersandrequiredrepairs,ifanyareindicated,toallemployeesandcontractorswhosuperviseOreandBearingMaterialstransportationsystems.5.0OperatingPoliciesOnlyCertifiedOperatorsaretooperatetheWashStation.Certificationisbasedon:../DemonstratedunderstandingoftheSOP,operatingguidelines,safetypractices,inspectionpractices.../Hands-ontrainingperformedbyacertifiedtrainerforboththeautomaticwashsystemandthemanualpowerwasher.../Awrittentestwillbeadministeredtoverifytraining.AutomaticFacilityDesignRequirements:Shallbeenclosed.Shallbedesignedtofullyandsafelyoperateduringallseasonsoftheyear.Shallbelocatedatorneartheexitofthefacilityproperty.ShallhavebackupwashsystemsasdescribedinSection5.4.TheDesignwillbetowash:undercarriages,entiresides,back,tailgates,tires,mudflaps,wheelwellsandwheels.../Thefacilitywillhavethenecessaryequipmentsuchasspraynozzles,powerwasherratedataminimumof2200psi,etc.,atappropriatelocation,positionandanglesuchthatbaselineperformanceismetorexceeded.TheseparameterswillbeinspectedandrecordedonaregularbasisapartoftheChecklist.oDuringthechecktheOperatorwillchecktheaimandintegrityofthenozzlestoassuretheWashStationisinoptimumoperatingcondition.DB03/800043.0009/9389102.3WP06DB03/800043.0009/9462110.1DDOlPage2of6CodeN": **~~**

... .........,.........,.. COIIIPAN'f STANDARD OPERATING PROCEDURE Washing/Inspection

of Vehicles Transporting

Ore or Lead-Bearing Materials

U pdated

: August2010 c Water flow and recharge rates and pressures wil1 vary upon facility design and available resources
and will meet
or exceed performance

of baseline measurements taken
at Herculaneum during the

1 000-truck baseline sample. 0 Water will be sampled once per month

to check for lead content. ../ Wash water will be collected, treated and discharged

in accordance

w ith

a ll state and federal requirements

and permits

. 5.1 Before Operation

of Wash Station 1. These procedures
will be performed/followed

at the beginn

i ng of each day shift

. 2
. Start

- up Wash Station. 3. Run

a wash cycle empty with no vehicle present. 4
. Operator must complete

a pre

- operating checklist

of the facility (See Appendix

2 PreOperating Checklist

for Wash Stations
for Vehicles Transporting

Ore or Lead-Bearing Materials). 5
. The pre-operating checklist

is to be submitted to

the supervisor
and kept on file for 10 years. 6
. The supervisor will forward requests
for corrective action
to the maintenance department. 7
. If Wash Station

is deemed inoperable during

or after the pre-operating inspection,

see Section 5.4 for alternative washing techniques. 8
. After Corrective Action

is complete,

a record will be placed into the file

. 5.2 Operation ofWash Station 1. Vehicle pulls up to the entrance ofthe Wash Station and waits for

s i gnal to enter

. A stop

/ go light system will be employed

at facilities and Drivers must follow the signal lights. 2
. The signal light will be set so that entry
to the Wash Station

i s only authorized when the system has sufficient water
to run an
e ntire cycle without disruption

of wat

e r flow or pressure. 3
. Wh

e n entry

is granted

, the wash cycle will automatically
start (with

a "trip" wire),

5 mph is the maximum speed limit (as posted). Driver will move vehicle slowly forward and pause and stop as directed

by the signal light and the Doe Run Operator

to ensure adequate retention

in the wash and dry cycles. 4. The wash cycle timer shall be set at 45 seconds and triggered automatically
(with

a "trip

11 wire)
to help ensure adequate retention and cleaning. 5
. The dry cycle timer shall be set at 45 seconds and triggered automatically (with

a separate "trip" wire)
to help ensure adequate retention and drying. The blowers shall be positioned
and set to enable the following

: a . Blowers will commence prior to any part of the vehicle passing the blowers' forced-air zone. b
. Blowers will be running

as the vehicle exits the wash cycle

, while the wash

c y cle is still operating

. c
. Blowers will remain
on until the sides and all wheels/tires have passed the blowers' forced-air zone. 6
. If at the unload wash station, Operator shall complete
the Form (Appendix

3 Inspection and Wash Form for Vehicles Transporting

Ore or Lead-Bearing Materials)
and return

it 0803/800043.0009/9389102.3

WPOG 0803/800043.0009/9462110.1

0001

Page

3 of6CodeN°:............lrll......COMPAN'fSTANDARDOPERATINGPROCEDUREWashingnnspectionofVehiclesTransportingOreorLead-BearingMaterialsUpdated:August2010toDriver.Ifattheloadwashstation,OperatorshallconducttheTailgateandRimInspectionasestablishedinSection5.3,completetheFormandreturnittoDriver.5.3TailgateandRimInspection(OnlyatLoadWashStation)1.Aftervehiclehasstopped,Operatorshallinspecttherimofthevehiclecarriage/bed(onlyatloadstation)andcompletetheForm(Appendix3InspectionandWashFormforVehiclesTransportingOreorLead-BearingMaterials).Ifnoloosematerialispresentontherim,circle"N/A"(notapplicable)ontheForminthe"Rimcleaned?"box.Ifloosematerialispresentontherim,Operatorshallusetherimcleaningtooltoremoveanyloosematerial.Oncetheloosematerialisremovedfromtherim,circle"Y"(yes)ontheForm,indicatingthattherimhasbeencleaned.2.Operatorshallinspectthetailgate.Specificallynotethea.tailgateissecurelylatchedandhasnogapsthroughwhichOreorLead-BearingMaterialscouldbereleased.b.confirmthatthereisnoevidenceofOreorLead-BearingMaterialsleakagefromoraroundthetailgate.3.Ifthetailgateissecure,thereisnogapbetweentailgateandvehiclewallthroughwhichOreorLead-BearingMaterialscouldbereleased,andthereisnoOreorLead-BearingMaterialsleakagefromoraroundthetailgate,circle"Y"(yes)onFormin"Securetailgate(noleakage)?"box.4.IfagapexistsbetweentailgateandvehiclewallthroughwhichOreorLead-BearingMaterialscouldbereleased,orifOreorLead-BearingMaterialsleakageisobserved,Operatorshail:a.notespecificproblemandcircle"N"(no)ontheForminthe"Securetailgate(noleakage)?"box.b.requireDrivertoreturntotheOreorLead-BearingNlaterialsloadinglocationandtounloadthevehicle'scontentsintotheOreorLead-BearingMaterialspile.c.requireDrivertoreturnthevehicletothewashstationforroutinewashanddrycycles,andnotecompletionofwash/drycycleonForm.d.requireDrivertorepairthedeficiencypriortoreceivingandhaulinganotherload.5.OperatorshallreturntheFormtoDriver.5.4OperationinEventofAutomaticWashCycleMalfunction1.Operatorshallusemanuallyoperatedpowerwasherratedataminimum2200psi.2.ThemanuallyoperatedpressurewasherwillbeusedinsidetheWashStation.3.Usetop-downapproachtomanuallywashvehicles.Withthepowerwasher,startatthetopleadingedgeandwashfronttoback.Uponreachingtheback,lowerspraystreamtojustbelowlastsweepandcontinuewashtowardfrontofvehicle.Continuethisprocessofwashingtoptobottomuntilspraydistributionreachesbottomedgeofvehicle.4.Washallofthefollowingkeyvehiclecomponents:entiresides,back,wheelsandtires,wheelwell,mudflaps,undercarriage(unloadinglocationonly),andtailgate.5.Aftercompletionofmanualpowerwash,Operatorshalltriggerblowersanddirectvehiclethroughthedrycycle.6.OntheWashandInspectionForm(Appendix3),write"manual"inthe"Time"box,andreturntheFormtoDriver.0803/800043.0009/9389102.3WP060803/800043.0009/9462110.10001Page4of6Co de N°: **~~**

... ....,.,.. .......... COMPANY STANDARD OPERATING PROCEDURE Washing/Inspection

of Vehicles Transporting

Ore or Lead

- Bearing Materials Updated

: August2010 5.5 Routine Cleaning

of Facility 1. Pressure wash (rated
at minimum pressure

of 2200 psi) the first 70 feet of roadway from the exit side of the Wash Station and the Wash Station floor twice during the day and at the end of the day.

. 2. This

is to be done by starting

70 feet from the Wash Station utilizing

a high-pressure wash (rated
at minimum pressur

e of 2200 psi) and cleaning toward the facility drain. 5.6 Safety Guidelines

for Operator 1. Safety equipment required includes appropriate personal protective equipment, including but not limited

to

, eye protection

, hard-hat, gloves and protective boots

. 2. In the winter be cautious

of ice. 3. Remember water lines, hoses and

s pray wands are under high pressure. During operation the Operator must stand clear. 4. Operator must also stand clear ofblowersduring operation. 5. Drivers are to remain

in the vehicles with doors and windows shut. 6
. Operator should never walk between
the vehicle and the Wash Station exit door

. Alwa ys use man doors and aisle ways. 6
. 0 E nforce me nt An y employee, contractor
and consultant found
to hav e v iolated this policy must be subject

to di
s ciplinary action, up to and includin

g termination

. o f employment. DB0

3 /800043.0009/9389102.

3 WP06 DB0

3 /80004

3. 0009/9462110.1
DDOl

Page

5 of6CodeN°: **~a.**
... **~** ........ COJIPA"" STANDARD OPERATING PROCEDURE Washing/Inspectio

n of Vehicles Transporting

Ore or Lead- Bearing Materials Update

d
: August2010 7.0 Definitions Term Certified Operator Certified Trainer Lead- Bearing Materials Ore Vehicle Definition Has read and understands

the SOP an d Training Manual. Has demonstrated knowledge

of all tasks
to Certified Trainer through hands on training. Has passed the written test. A salaried member

of the environmental

d epartment

or
a Certified Operator who has scored 95% or better on the wr itten test. All granular

or semi-granular product

or waste material which contains more than 400 milligrams
per kilogram (mglkg)

of lead

. The Parties
do not interpret this definition

to include contami

n ated soils excavated from residential yards, road edges, churches, vacan

t lots or high child impact areas. Ore is rock/mineral
with approximately 4.25% lead content that has been extracted and crushed into 2"- 8" chunks and fragments
(on average)

in a subsurface mine, conveyed

to the surface

an d loaded into vehicles

to be transported

to and processed

at the mill facilities. A truck, trailer
or pup hauling Ore or Lead-Bearing Materials. Page

6 of6 0803/800043.0009/9389102.3

WP06 0803/800043.0009/9462110.1

0001**~~**

... ........ ,...coVD: OPERATING GUIDELINES (AuGUST 2010)-:- SOP Appendix

1 DAILY INSPECTION

OF VEHICLES TRANSPORTING

ORE OR LEADBEARING MATERIALS Vehicles transporting
Ore or Lead-Bearing Materials must be inspected twice daily by

a Doe Run Operator/Inspector ("Inspector").

The "First Daily Inspection"

is required prior
to the first load

o f the day. Driver must provide

to Inspector
the previous hauling day's Inspection
and Wash Form. Inspector shall complete and initial the section
of the Form entitled "First Daily Inspection",

and return the Form
to Driver

. The "Second Daily Inspection"

is required sometime after the 4th load and prior
to the last load of the day (timing
of the second inspection

is at Inspector's discretion). Inspector shall complete and initial the section
of the Form entitled "Second Daily

I nspection",
and return the Form
to Driver

. 1 . Request from Driver

: most recent Inspection
and Wash Form

. If a prior "BO" was noted on the previous Form, note the physical repair on the current Form

, if completed.

If repair not complete,

do not load

. 2. Request that Driver eleYate the vehicle bed/carriage

. Inspect undercarriage
from side of vehicle for holes and visible ore contamination,
then return vehicle carriage/bed

to normal operating position. 3. Inspect tarp position and condition from ladder/platform
while tarp
is still in place covering trailer, including
the following conditions: a. no significant holes or tears in tarp (i.e., "thumb" rule). b
. tarp is in correct position covering
the vehicle bed. 4
. Stay on ladder/platform

and request that Driver role up the tarp into open position. 5. From ladder/platform, inspect interior
of vehicle bed for visible holes. 6. From ground level, inspect exterior
of trailer, including sides, tailgate,
air locks, and vertical bolts

- ensuring that all components

are functioning
and are in closed and secured position

in preparation

for loading. Specifically
note the following: a. tailgate

is securely latched and has no gaps through which Ore or Lead-Bearing Materials could be released

. b. air locks are tight against tailgate. c. vertical bolts are in place and secure. d
. confrrm that there
is no evidence

of ore leakage from or around the tailgate. 7
. If any key vehicle component

(as identified

on the Inspection
and Wash Form)

is in defective condition

or "bad order" (BO)

: a. do not load vehicle. b. reject the vehicle, circle "BO" ("bad order")
on Form and note specific details,

as necessary. c. place the vehicle "Out of Service"

....OPERATINGGUIDELINES(AuGUST2010)-SOPAppendix1DAILYINSPECTIONOFVEHICLESTRANSPORTINGOREORLEADBEARINGMATERIALSd.explaintoDriYerthebasisforBOclassificationandthatnoloadsmaybereceivedbythatvehicleuntilthedefectiveconditionhasbeencorrected.e.requireDrivertodrivevehicletowashstationforroutinewash.**~.u**

....

CodeN

° : ......................

SOP Appendix

2 COMPANY Pre-Operating Checklist

- Wash Station for Vehicles

Issue dat e: Transporting

Ore and Lead-Bearing Materials Prepared

.' Reviewed

by

:

Dat

e :

j Approved

by

:

Date

:

. Update date

: August

2 0 10 1 Environmental Department
Environmental Department Operator Name ____________

__ Operator **Name~ ----** 

**-- ---** 

**--** OperatorName __________

_ _ __ OperatorName

_ _ ___

_ _ ___ __

_ _ Date __________

_ BO OK

Ch

k Th
F II ec e o owmg

A . T ctaon

a ken High Pressure Washer Pump Oil Level High Pressure Washer-
All Belts are in place High Pressure Washer -Electrical Cord High Pressure Washer- Leaks-Oil/Water Check for Water Leaks-Lines/Hoses/Wands Condition

of Spray Wands and Hoses Drain Water Lines (At the end of each shift) Fire Extinguishers/Current Inspection Tag Sump Pump operating correctly Blowers operating correctly Damage

to Building (Interior

& Exterior) Roll up doors operating properly Water supply line solenoid valve working Side, Tire and Undercarriage Spray Bank Flows ../ Nozzle Angles, Standoff Distance and Location- Any dislocated,

No longer

in place, bent, signs of metal fatigue, damage

to the banks themseiYes

• ../ Nozzle Condition, Cleanliness, integrity and pressure- (Visual guide located

in Training Manual) Both Roll up Doors are above Door Frame Stop/Go light system working COLD WEATHER OPERATION Heat Tape plugged

in (Cold Weather Only) Furnace turned
on (Cold Weather Only) Spray banks weepine; (Cold Weather Only) NOTE: Marking "BO" for an Item means you found that item to be m bad order. Pressure washed
70 feet exiting Wash Station

3 times daily. Start:

Initials

: --

- ------- Middle: Initials:--

- ------

- End: Initials:--

- ------

- **Corrunen~------**

**-- ----------**  **----------**

**--- --**  **------------** EQUIPMENT MUST BE INSPECTED
AND SIGNED
BY ALL USERS AND PLACED ON CLIP BOARD OR DESIGNATED HOME LOCATION

IN EACH DEPARTMENT. DB03/800043.0009/9462129.1

DDOlThe Doe Run Company Inspection
and Wash Form for Vehicles Transporting

Ore and Lead-Bearing Materials SOP Appendix

3 Operator

/ Inspector shall complete

all portions

of this Form after conducting

the inspection
and wash

a c t i vities

. M y initials on this form certify under penalty **of!<~.\\** that

I ha Y e in s pected the areas of the vehicle listed below

. The information contained

on th is form

is
, to the best of m y knowledge
and belief

, true

, accurate, and complete

.
I am aware that

t h ere are s ignificant penal

t ies for submitting false information

, including
the possibility

of fine and impri

s onment for knowing violations. I Date

:

J Vehicle#:

J Driver

:

I Company: FIRST DAILY INSPECTION (inspection required prior
to first load of the day; must review pr
.. -v ious day's Form) Location:

Time:

1 Operator/Inspector

(full name): Tarp

: functional,

no Tarp position Tailgate:

no gaps

Ai
r locks Vertical bolts Trailer/pup walls visible holes

and bed: no holes OK BO

OK BO OK BO
OK BO
OK BO
OK BO De

s cription

of BO Condition: WASH AND TAILGATE INSPECTION Unload

Buick Mine/Mill Load

\l.

· .J.sh S"lat:r.lH

!1:1 5 **Mm~;.'Ca:.tt:d**

#29 Mme. V1hwuum s ECOND

D lAlLY

1

l h NSPECTION (inspection required somet

i me after

4 load and prior

t o last load of!he day

) Location:

Time:

1 Operator/Inspector

( full name)

: T arp

: functional,

no Tarp position Tailgat

e: no gaps Air locks Vertical bolts Trailer

/ pup walls visible holes

and bed: no holes OK BO

OK BO OK BO
OK BO
OK BO

OK BO Description

o f BO Condition:

.. T op!Wh
tte Copy- Envrronmenta! ProJect Manager **~fiddle**

**w** Co oy-
C arner

T ruck Driver

B otto m/Pmk

C ooy Loadmg Facthty Copy 0803

/ 800043 .00 09
/ 9462133.1 DDOl**~a.**

... ......., .. **~~** OPERATING GUIDELINES (AUGUST2010) -SOPAppendix4 WASH STATION PROCEDURES
FOR VEHICLES TRANSPORTING ORE OR LEAD-BEARING MATERIALS Vehicles transporting

Ore or Lead-Bearing Materials must be washed twice per load- (l) after loading, and prior
to entering onto public roadways
and hauling Ore or Lead-Bearing Materials; and (2) after unloading,
and prior
to exiting Doe Run facility and entering onto public roadways. At the Wash Station,

a Doe Run Operatornnspector

shall conduct and monitor
the wash/dry cycles, inspect the rim and tailgate (load wash station only), and complete
and initial the relevant portions

of the Inspection
and Wash Form for Vehicles Transporting

Ore or Lead:-Bearing Materials. After each wash/inspection,

the Doe Run Operator/Inspector

shall return the Form

to Driver

. Before Operation

of Wash Station I. Vehicle pulls up to entrance

of Wash Station and waits for signal
to enter. 2. Operator must make sure vehicle

is properly lined up with Wash Station. Failure

to do so could result
in damage

to vehicle and facility. 3. Operator will allow entry
to Wash Station only when system has sufficient water
to run an entire cycJe without disruption

of water f1ow or pressure. Operation

of Wash Station (Routine Wash and Dry Cycles) 1. The wash cycle timer shall be set at 45 seconds and triggered automatically

to help ensure adequate retention and cleaning ofthe vehicles

. Vehicles must be washed
for

a minimum

of 40 seconds

. 2
. When entry

is allowed, Driver shall move the vehicle slowly forward through the automated wash cycle, minding
the Operator's direction and signals

to ensure adequate wash and dry cycle retention times. a. Signs will be posted for speed limit. b. Operator will indicate allowed vehicle movements. 3
. During the automatic wash, Operator shall be positioned

at the entrance

of the wash station and shall use

a power washer rated

at a minimum of2200 psi to manually wash the entire back side and tailgate (top to bottom). This manual power wash shall be conducted

for each vehicle

as a routine part of wash process. unless the wash station

is designed

to wash the entire tailgate and is effectively accomplishing

that objective. 4
. Dry cycle shall be set at 45 seconds and triggered automatically (with

a separate "trip" wire)
to help ensure adequate retention and drying
of the vehicles. Vehicles must be dried for

a minimum

of 40 seconds

. a . Blowers may commence before entire wash cycle

is completed
and will be running

as vehicle exits the wash cycle. b. Blowers will remain
on until the sides and all wells/tires have passed the blowers. DB03/800043 .0009/93982&6.

l WP06 DB03/800043.0009/946214

1.1 DDDI**~I!!YDLI** w& **~** OPERATING GUIDELINES (AUGUST2010)

- SOPAppendix4 WASH STATION PROCEDURES
FOR VEIDCLES TRANSPORTING ORE OR LEAD-BEARING MATERIALS 5
. Vehicle shall stop
at designated
spo

t wh

i ch allows approximately

1/3 ofvehicle

to remain inside
of Wash Station
for tailgate and Ore or Lead-Bearing Materials leakage inspection (only
at load wash station).

If at unload wash station, return completed Form to Driver

. Tailgate and Rim Inspection (Only
at Load Wash Station) 1 . After vehicle has stopped, inspect rim of vehicle carriage,

If no loose material

is present on rim

, circle "N/A" (not applicable)

on Form
in "Rim cleaned?" box.
If loose materia]

is present
on rim, use rim cleaning tool/brush

to remove any loose mate
ri al. Once loose ma

t erial is removed

, circle "Y'

' (yes) on Form

. 2. Operator shall inspect the tailgate

. Specifically
note the follow

1 ng

: a. tailgate

is securely

l atched and has

· no gaps through which Ore or Lead-Bearing Mater

i als could be released

. b. confirm that there
is no evidence

of Ore or Lead- Beari

n g Materials leakage from or around the tailgate. 3. If the tailgate

is secure, there
is not

a gap between tailgate and

v ehicle wall through which Ore or Lead-Bearing Materials

_ could be released, and there

is no Ore or Lead

Bearing Materials leakage from
or around the tailgate, circle

" Y
" (yes) on Form
in "Secure tailgate (no leakage)?"
box

. 4

. If a g.@ exists between tailgate and veh

i cle wall through wh

i ch Ore or Lead-Bearing Materials could be released,

or if Ore or Lead

- Bearing Materials leakage

is observed, Opera

t or shall

: a . note spec

i fic problem and circle "N" (no) on Form
in

" Secure tailgate (no leakage)?"
box

. b. require Driver
to return
to loading location and

t o unload vehicle

' s contents into the stockpile. c. require Driver
to return

to the wash station for routine wash and dry cycles, note completion

of wash/dry cycle on Form. d. require Driver
to repair the deficiency prior
to receiving
and hauling another load. 5. Return completed Fonn

to Driver. Operation

in Event of Automatic Wash Cycle Malfunction 1 . Operator shall use manually operated power washer rated

at a minimum 2200 psi

. 2. Use top-down approach

to manuall

y wash vehicles. With the power washer

, start at th e top leading edge and wash front to back

. Upon reaching the back, lower spray

s t ream to just below last sweep and continue

to wash toward front of veh

i cle

. Continue this process of washing top to bottom Wltil spray distribution reaches bottom edge

o f vehicle. DB0

3 /8 0 0043

. 0009/9398286.1 WP06 D B03/800043

. 000919462141.l
DDOl

2OPERATING GUIDELINES (AucusT2010) -SOPAppendix4 WASH STATION PROCEDURES
FOR VEHICLES TRANSPORTING ORE OR LEAD-BEARING MATERIALS 3
. Wash all of the following
key vehicl

e components: entire sides, back, wheels and tires, wheel well, mudflaps, undercarriage (unload location only or ifBO'd

at the loading area), and tailgate. 4

. After completion

of manual power wash, Operator shall trigger blowers and direct vehicle through the dry cycle

. 5. On Inspection
and Wash Form for Vehicles Transporting

Ore or Lead-Bearing Materials, write "manual" next to the

" T i m e " box

, and return completed Form
to Driver. DB03
1cl 0 0 043.0009/9398286.1

WP06 **DBO 004~**  **9/9462** 141.1 DDOI

3IN THE MA TIER OF The Doe Run Resources Corporation

, Respondent Docket No

. RCRA-07-2007-0008 CERTIFICATE

OF SERVICE I certify that

a true and correct copy of the foregoing Order was sent this day in the following manner

to the address
ee
s : Copy hand delivered

to Attorney
for Complainant: Steven Sanders Assistant Regional Counsel Region

7 United States Environmental Protection Age

n cy 901 N

. 5th Street Kansas City, Kansas 6610

1 Copy by Certified Mail Return Receipt

to

: Calvin

R. Keller Environmental Manager Primary Smelting The Doe Run Company

· 881 Main Street

, Misso uri 63048 **~it~** Hearing Clerk, Region

7