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 

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THE DOE RUN RESOURCES CORPORATION ) 

Respondent. 

Proceedings under Section 7003 of the 

Resource Conservation and Recovery Act, 

42 U.S.C. § 6900, et seq., as amended. 

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Docket No. RCRA-07-2007-0008 

MODIFICATION OF 

ADMINISTRATIVE ORDER ON CONSENT 
The Doe Run Transportation and Haul Routes 

Southeastern Missouri 

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THE DOE RUN RESOURCES CORPORATION ) 

Respondent. 

Proceedings under Section 7003 of the 

Resource Conservation and Recovery Act, 42 U.S.C. § et seq., as amended. 

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Docket No. RCRA-07-2007-0008 

MODIFICATION OF 

ADMINISTRATIVE ORDER ON CONSEN T 

I. INTRODUCTION 

The following sections of the Administrative Order on Consent ("Order" or "AOC") are being 

modified in order to enhance the effectiveness of the Work being performed by the Doe Run 

Resources Corporation, ("Respondent" or "Doe Run") under the Order. The modification is 

entered into voluntarily by the United States Environmental Protection Agency ("EPA") and 

Respondent. All Paragraphs or subparagraphs not included in this Modification shall remain as 

drafted in the original AOC, with two exceptions. The Public Comment and Effective Date 

Paragraphs at the end of this Modification are intended for this Modification only. 

13. Unless otherwise expressly provided herein, terms used in this AOC that are 

defined in the RCRA statute shall have the meaning assigned to them in that statute. Whenever 

the terms listed below are used in this AOC the following definitions apply: 

"Concentrate" or "Lead-bearing Concentrate" shall mean ore that has been processed at 

the mill concentrate facilities, and includes lead concentrate, zinc concentrate, and copper 

concentrate. 

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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. Project Coordinators. Project Coordinators for Respondent and EPA are as follows: 

For Respondent: 

For 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 65566 

(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 

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the change. EPA retains the right to disapprove of any Project Coordinator named by 

Respondent. If EPA disapproves of a selected Project Coordinator, Respondent shall retain a 

different Project Coordinator and shall notify EPA of that person's name and qualifications 

within two (2) working days following EPA's disapproYal. Receipt by Respondent's Project 

Coordinator of any notice or communication from EPA relating to AOC shall constitute 

receipt by Respondent. 

a. Transportation Compliance Managers. By five (5) days after the Effective Date of 

the Modification, Respondent shall identify a Transportation Compliance Manager ("TCM") to 

be responsible for overseeing all of the compliance issues associated with the transportation of 

lead-bearing materials as identified in this Order. In addition, the Respondent shall identify a 

TCM for each facility covered by this Order. The facility-specific TCM shall be someone who is 

very familiar with the operations at that facility. In addition to compli ance responsibilities at 

their specific facility, the facility-specific TCM shall be responsible for ensuring that people who 

conduct any portion of the Work under this Order at their specific facility shall be appropriately 

trained. The facility-specific TCM shall be limited to overseeing only one facility, except at the 

mine or mill facilities where a facility-specific TCM may oversee multiple facilities with similar 

operations that are in relatively close proximity to one another. 

b. Training. Respondent shall develop and implement an annual training 

program for any person who conducts Work under this Order at any facility covered by this 

Order. The training shall include information on the requirements ofthis Order, including its 

attached SOPs. By five (5) days after the Effective Date of the Modification, Respondent shall 

submit the written training materials to EPA for review, and Respondent shall commence 

implementation ofthe training program unless and until EPA requests revisions to the training 

program. All persons conducting Work under this Order shall be trained within thirty (30) days 

of the Effective Date of the Modification, and annually thereafter; all new persons hired after that 

initial training date shall be trained prior to performing any Work. Persons subject to training 

shall include TCMs, truck drivers, inspectors, truck wash operators and other appropriate 

personnel that perform Work under this Order. 

c. Audits. Respondent shall retain an independent third-party environmental 

contractor to perform audits of its compliance with the provisions of this Order and its SOPs. By 

five (5) days after the Effective Date of the Modification Respondent shall provide to EPA the 

name and qualifications of the environmental contractor that Doe Run would propose to retain 

for performing audits. EPA retains the right to disapprove of the contractor selected by 

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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 material 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 providing transport 

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which is used solely for truck maintenance and/or parking. 

b. Any employee of Respondent found to have violated the requirements of this Order 

including the attached SOPs must be subject to appropriate disciplinary action, up to and 

including permanent termination of employment.· For any contractor o r consultant found to have 

repeatedly violated the requirements of this Order, Doe Run shall notify the associated employer 

that the respective contractor or consultant shall not be allowed to con duct work for Respondent 

or to have access to Respondent's property, thereby effectively termina ting that individuars 

senice to Respondent. 

65. Vehicle Wash Stations 

a. Prior to commencing operation of a new facility, Respo ndent shall install and 

begin to operate enclosed vehicle wash stations at all Doe Run facilitie s where Concentrate, Ore, 

or lead-bearing materials are transferred on or off vehicles, and those vehicles enter/exit those 

facilities above ground. The vehicle wash stations shall be designed and built to be fully and 

safely operational during all seasons of the year, including freezing te1nperatures; provided, 

however, that during periods of extreme freezing temperatures (e.g., below 25° Fahrenheit), the 

schedule for washing Ore trucks may be suspended to minimize hazardous conditions, risks and 

property damage associated with excessive ice build-up from multiple, high-frequency washings. 

All vehicle wash stations shall be located at or near the exit of the facility property and have 

backup wash systems in the event that the primary wash systems are inoperative. Nothing in this 

AOC shall be construed to require construction of additional vehicle wash stations (except where 

Respondent begins operation of an additional smelter, mine. mill or concentrator). 

b. All vehicle wash stations shall be designed to wash the vehicle's entire 

undercarriage, entire sides, backs and tailgates, tires and wheels. In the alternative, if the wash 

station is not designed to wash all of the components listed above, the operator shall wash those 

omitted components with a manually-operated pressure washer (rated at a minimum pressure of 

2200 psi), and will visually inspect each truck and rewash any areas of visible contamination. 

After unloading Concentrate trucks, the interior of the trailer and bedl iner will be washed out 

with a hose with force and volume sufficient to reach the top of the bed/bedliner on the raised 

trailer. The bed/bedliner wash-out shall be conducted at the unloading area. Bedlbedliner washout operations may be suspended during freezing temperatures. The bed/bedliner wash-out 

requirement shall not apply to trucks unloading and reloading lead-bearing concentrate at the 

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e. Respondent has created two re\ised Standard Operating Procedures (

SOPs

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"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. Roadway and Street 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 

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surface soil and interior dust of all occupied residential properties along the Concentrate, Ore, or 

lead-bearing material haul route(s) being utilized at the time of sampli ng in the Herculaneum city 

limits, for which Respondent or EPA secured access pursuant to Sectio n XI. This sampling shall 

be conducted as long as Concentrate, Ore, or lead-bearing materials are being transported to and 

from Herculaneum, Missouri by vehicle transportation. 

g. Respondent shall perform sampling at a minimum of twelve (12) residential 

properties along Concentrate or Ore haul routes leading from the Doe Run facilities. Within 

sixty (60) days of the Effective Date of this Modification, Respondent shall provide a list of at 

least twenty (20) residential properties located along the haul routes from the Doe Run facilities. 

EPA and Respondent will agree on twelve (12) residential properties representative of the 

residential yards located along Respondent's haul routes. Respondent shall provide a draft 

Quality Assurance Project Plan for the collection and analysis of these samples within ninety (90) 

days ofthe Effective Date of the Modification. After agreement on the properties to be sampled, 

Respondent shall attempt to obtain access to the residential properties as outlined in Section XI 

of this Order (Sampling, Access and Data Availability). Ninety (90) days after receiving 

approval from the respective property owner or EPA-approval of the QAPP, whichever date is 

later, Respondent shall collect and analyze one multi-aliquot soil sample from the mid-yard area 

of the twelve residential properties in the portion of the yard closest to the roadway. Respondent 

shall perform sampling and analysis at these twelve properties thereafter annually. The results of 

the respective sampling and analysis shall be provided to EPA in the monthly report required in 

Paragraph 70 following the receipt of the sampling assays for those properties. 

h. Handling and Transportation Study. Respondent shall r etain an independent 

third-party contractor to conduct a Concentrate Handling and Transportation System Engineering 

Study (CHTSES) to: (1) benchmark Respondent's current lead-bearing materials load, unload, 

transportation and monitoring operations, practices and planned improvements; (2) identify and 

evaluate current load, unload, transportation and monitoring operations and practices at other 

similar facilities that are in place to reduce the potential for releases at those facilities and their 

applicability to Respondent's operations; and (3) evaluate the effectiveness of and opportunities 

for improvement to the loading, unloading, transportation, and monitoring practices implemented 

under the Order to prevent releases of lead-bearing materials in off-site areas. 

i. Respondent shall notify EPA of the name and qualifications of the lead 

consultant that will work on the CHTSES within ninety (120) days of the Effective Date of the 

Modification. Respondent shall also notify EPA of the name and qualifications of any other 

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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: 

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accordance with Paragraph 67.b and 65.e, respectiYely, in a timely and 

adequate manner; provided, however, that stipulated penalties shall not apply if this situation is necessitated by a reasonable deviation that is 

explained in v.Titing on the inspection form. 

v. Failure to conduct audits pursuant to the time frames and conditions in 

paragraph 60.c. 

v1. Failure to conduct the Concentrate Handling and Transportation Study 

pursuant to the time frames and conditions in paragraph 69.h. 

b. A stipulated penalty of $4,000 per violation per day shall accrue for any 

noncompliance identified below: 

1. Failure to construct vehicle wash stations in accordance ¥.ith Paragraph 

65.a and b. in a timely and adequate manner. 

c. A stipulated penalty of$1,500 per violation per day shall accrue for any 

noncompliance identified below: 

1. Failure to submit a written monthly monitoring report in a timely or 

adequate manner. 

n. Any other violation of the AOC other than those milestones identified in 

114.a, 114.b, 114.c, or 114.d. 

d. A stipulated penalty of$10,000 per violation shall accrue for any noncompliance 

identified below: 

1. Any truck driver obtaining a load of lead-bearing material in a truck 

that was previously rejected for "bad order" ("BO") defect(s) which were 

not corrected prior to obtaining another load of lead-bearing material. 

ii. An observed release oflead-bearing material from a truck to publicly 

accessible streets, roads, residential yards or other areas located outside of Doe 

Run property. The term "observed release" means direct evidence of lead-bearing 

material discharged from a truck to publicly accessible streets, roads, residential 

yards or other areas located outside of Doe Run property. This term specifically 

excludes the following events and conditions: (a) truck accidents resulting in 

spills or discharges oflead-bearing materials (see Spill Response Plan paragraph 

68 of AOC); (b) staining on the exterior of the trailer that has not resulted in a 

discharge or release oflead-bearing material from the truck to publicly accessible 

streets, roads, residential yards or other areas located outside of Doe Run property; 

and (3) sampling conducted pursuant to this Order or any other Unilateral Order 

or Administrative Order on Consent that indicates the presence of lead or other 

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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 DATE 

The effective date of this Modification 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. 

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United States Environmental Protection Agency 

Region 7 

For The Doe Run Resources Corporation: 

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)E C' 10 

Date 

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 enhance 

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 

./ Appendix 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: 

Page 1 of 6 

0803/800043.0009/9462149.1 0001 
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 Appendix 2 Operating Guidelines 

- Inspection of Trucks at Concentrate Loading Stations ("After Loading Trucks") or Appendix 4 

Operating Guidelines- Inspection of Trucks at Unloading Station ("Afte 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 Vl 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 lead content. 

../ Wash Water will be collected, treated and discharged in accordance with all state and 

federal requirements and penil.its. 

Page 2 of6 

0803/800043.0009/9462149.1 DDOl 
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 10 

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 DDOl 
d. Blowers shall be re-triggered if manual power wash or spot wash occurs after 

initial dry cycle has ended. 

8. Driver will be instructed to stop the truck at a designated spot ( no more than 70' from the 

Wash Station) which allows approximately 1/3 of trailer to remain inside of Wash Station 

for inspection in accordance with Section 5.4. · 

5.3 Operation in Event of Automatic Wash Cycle Malfunction 

1. Operator shall use manually operated power washer rated at a minimum 2200 psi. 

2. The manually operated pressure washer will be used inside the Wash Station. 

3. Use top-down approach to manually wash trucks. With the power washer, start at the top 

leading edge and wash front to back. Upon reaching the back, lower spray location to 

just below last sweep and continue wash toward front of truck. Continue this process of 

washing top to bottom until spray distribution reaches bottom edge of trailer. 

4. Wash all of the following key truck components: entire sides, back, wheels and tires, 

wheel well, mudflaps, undercarriage, and tailgate. 

5. After completion of manual power wash, Operator shall trigger blowers and direct truck 

through the dry cycle. 

6. On Inspection Form, mark only "manual" wash (not "auto"), and note the reason. 

5.4 Truck Inspection and Wipe Sampling 

1. After the routine wash (i.e., automatic wash and manual power wash) and dry cycles are 

complete, and the truck has stopped at the designated spot (no more than 70' from the 

Wash Station) which allows approximately 1/3 of trailer to remain inside of Wash Station 

for inspection, Operator shall inspect the exterior of the trailer, including sides, tailgate, 

grain door, air locks, wing nuts, mudflaps, tires and wheels, and complete the relevant 

portion of the Inspection Form for Trucks Transporting Concentrate (Appendix 5). 

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. note any visible staining and mark location on the Inspection Form. 

e. for Brushy Creek only, it is recommended that the Operator inspect (from the top 

of the ladder) the top of the tarp for loose material that may ha-ve dropped onto 

tarp from overhead conveyor. If present, Operator shall use appropriate device to 

remove any loose material. 

2. If visible staining is observed, Operator shall: 

a. note location on the Inspection Form. 

b. spot wash those specific areas with manually operated power washer. 

c. manually trigger blowers and require portion of trailer that was spot washed to 

run through dry cycle again. 

3. Operator shall conduct Wipe Sa-mple on 10% of trucks (beginning with the first truck to 

proceed through the wash station each day) and on "bad order" ("BO") trucks. The wipe 

Page 4 of6 

DB03/800043.0009/9462149.1 DDOl 
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 employee found to have violated this policy might be subject to disciplinary action, up to and including termination of employment. 

Page 5 of6 

0603/800043.0009/9462149.1 0001 
Term 

Certified Operator 

Certified Trainer 

Lead-Bearing 

Concentrate 

Lead-Bearing 

Materials 

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, and 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 
Operator Name ______________ Operator Name _ _ _________ ~--

Date __________ _ 

B 0 0 K Ch ec k Th e F 0 II OWIDg A CIOn f T k 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

er: 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 
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. 

0 803/800043.0009/9337577.3 WP06 
y

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. 

Operation of Truck 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), wheels and tires, mudflaps, back 

side and tailgate. This manual power wash shall be conducted for each truck as a routine 

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 washer 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 front to back. Upon reaching the back, lower spray location to 

just below last sweep and continue wash toward front of truck. Continue this process of 

washing top to bottom until spray distribution reaches bottom edge of trailer. 

DBOJ/800043.0009/9347809.1 WP06 
through the dry cycle. 

5. On Truck Inspection Form, mark only "manual" wash (not "auto"), and note reason. 

Truck Inspection 

1. After truck has stopped, Operator shall inspect exterior of trailer, including sides, tailgate, 

grain door, air locks, wing nuts, mudflaps, tires and wheels. 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. note any visible contamination and mark location on Form. 

e. for Brushy Creek only, from top of ladder Operator sha ll inspect top oftarp for 

loose material that may have dropped onto tarp from overhead conveyor. If 

present, Operator shall use appropriate device to remove any loose material. 

2. If visible contamination is observed, Operator shall: 

a. note location on Form. 

b. spot wash those specific areas with manually operated power washer. 

c. ·manually trigger blowers and require portion of trailer that was spot washed to 

run through dry cycle again. 

3. Operator shall conduct Wipe Sample on 10% oftrucks and on "bad order" C'BO") trucks. 

4. If any key truck component is in defective condition or "bad order" ("BO"), Operator 

shall: 

a. circle "Out of Service" and note reason on 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 Truck 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. 

5. Upon completion of inspection, all inspection requirements and observations are to be 

noted on Truck Inspection Form. 

DB03/800043.0009/9347809.1 WP06 
b. no gaps bern·een tarp and rim. 

c. tarp and/or bonnet in place to prevent wind from entering over front 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 position ofbedliner rails. 

c. wash off trailer exterior components (including rim, load side, back, and tailgate). 

2. While trailer is in completely raised position: 

a. inspect bed (view underside 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 

received by that truck until the defective 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. authorize Driver to proceed to Truck Wash Station. 

DB03/800043.0009/9337572.1 WP06 

The Doe Run Company 

Inspection Form for Trucks Transporting Concentrate 

SOP Appendix 5 

My initials on this form certify under penalty of law that I have inspected the areas of this truck listed below. The information contained on this form is, to the best of my knowledge and belief, true, 

accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations. 

Truck Cleanliness Loading Station 

Inspector Initial 

Loading Wash Station 

Inspector /njtjal 

Unloading Station 

Inspector Initial 

Unloading Wash Station < Particular attention to sides, rim, tailgate, tires, wheels, undercarriage mudllaps, steps > lnli.P.!:.clor /niti/1.1 

Manual Auto Manual Auto 

Yes No Yes No 

I R 

CX5 co 'Cd 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\IaliUII1 YJ'QO>II VUL UCU UQIVI1J QIIUJYIIIM UU'-"' '-U I'IWiU.W'V t'lt:IIIL' I . . ... . . . I __ I 

NOTES: 1) Each truck removed from service must be sampled. 2) '80' = truck component Is in bad order. 3) 'N/A' = not applicable or not able to be inspected. 

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 - Environmental Project Off!C8r YELLOW COPY - Carrier Driver Copy PINK COPY - loadilg Facility Copy 
" 
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 

Materials 

v' Appendix 4 Operating Guidelines - Procedures 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. 

0803/800043.0009/9389102.3 WP06 

0803/800043.0009/9462110.1 0001 

Page 1 of6 
Vehicles transporting Ore or Bearing Materials must be inspected twice daily by a Doe Run 

Operator/Inspector in accordance with the procedures established in Appendix 1 Operating 

Guidelines - Daily Inspection of Vehicles Transporting Ore or Lead-Bearing Materials. The 

"First Daily Inspection" is required prior to the first load of the day. Driver must provide to 

Inspector the previous hauling day's Inspection and Wash Form (Vehicles Transporting Ore or 

Materials). Inspector shall complete and initial the section of the Form (Appendix 

3 Inspection and Wash Form for Vehicles Transporting Ore or Materials) entitled 

"First Daily Inspection", keep the bottom copy of the Form, and return the remainder of 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 Inspection", keep the top 

(original) copy of the Form, and return the middle copy of the Form to Driver. In addition to the 

more comprehensive Daily Inspections, loaded vehicles transporting Ore or 

Materials must undergo more limited "tailgate and rim inspections" at the load Wash Station in 

accordance ·with Appendix 4 Procedures for Wash Stations for Vehicles Transporting Ore or 

Lead-Bearing Materials ("Tailgate and Rim Inspection") and the appropriate areas on the Form 

must be completed. Forms will be turned into the responsible designee, who will forward 

Vehicle numbers and required repairs, if any are indicated, to all employees and contractors who 

supervise Ore and Bearing Materials transportation systems. 

5.0 Operating Policies Only Certified Operators are to operate the Wash Station. Certification is based on: 

../ Demonstrated understanding of the SOP, operating guidelines, safety practices, 

inspection practices . 

../ Hands-on training performed by a certified trainer for both the automatic wash system 

and the manual 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 5.4. 

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 washer rated 

at a minimum of 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 Checklist. 

o During the check the Operator will check the aim and integrity 

of the nozzles to assure the Wash Station is in optimum operating condition. 

DB03/800043 .0009/9389102.3 WP06 DB03/800043 .0009/9462110.1 DDOl 

Page 2 of6 
../ Wash water will be collected, treated and discharged in accordance with all state and 

federal requirements and permits. 

5.1 Before Operation of Wash Station 

1. These procedures will be performed/followed at the beginning 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 signal 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 is only authorized when the 

system has sufficient water to run an entire cycle without disruption of water flow or 

pressure. 

3. When 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 "trip11 

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 cycle 

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 of6 
1. After vehicle has stopped, Operator shall inspect the rim of the vehicle carriage/bed (only 

at load station) and complete the Form (Appendix 3 Inspection and Wash Form for 

Vehicles Transporting Ore or Lead-Bearing Materials). If no loose material is present on 

the rim, circle "N/A" (not applicable) on the Form in the "Rim cleaned?" box. If loose 

material is present on the rim, Operator shall use the rim cleaning tool to remove any 

loose material. Once the loose material is removed from the rim, circle "Y" (yes) on the 

Form, indicating that the rim has been cleaned. 

2. Operator shall inspect the tailgate. Specifically note the 

a. tailgate is securely latched and has no gaps through which Ore or Lead-Bearing 

Materials could be released. 

b. confirm that there is no evidence of Ore or Lead-Bearin g Materials leakage from 

or around the tailgate. 

3. If the tailgate is secure, there is no gap between tailgate and vehicle 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 gap exists between tailgate and vehicle wall through whi ch Ore or Lead-Bearing 

Materials could be released, or if Ore or Lead-Bearing Materials leakage is observed, 

Operator shail: 

a. note specific problem and circle "N" (no) on the Form in the "Secure tailgate (no 

leakage)?" box. 

b. require Driver to return to the Ore or Lead-Bearing Nlaterials loading location 

and to unload the vehicle's contents into the Ore or Lead -Bearing Materials pile. 

c. require Driver to return the vehicle to the wash station for routine wash and dry 

cycles, and note completion of wash/dry cycle on Form. 

d. require Driver to repair the deficiency prior to receiving and hauling another 

load. 

5. Operator shall return the Form to Driver. 

5.4 Operation in Event of Automatic Wash Cycle Malfunction 

1. Operator shall use manually operated power washer rated at a minimum 2200 psi. 

2. The manually operated pressure washer will be used inside the Wash Station. 

3. Use top-down approach to manually wash vehicles. With the power washer, start at the 

top leading edge and wash front to back. Upon reaching the back, lower spray stream to 

just below last sweep and continue wash toward front of vehicle. Continue this process of 

washing top to bottom until spray distribution reaches bottom ed ge of vehicle. 

4. Wash all of the following key vehicle components: entire sides, back, wheels and tires, 

wheel well, mudflaps, undercarriage (unloading location only), and tailgate. 

5. After completion of manual power wash, Operator shall trigger blowers and direct 

vehicle through the dry cycle. 

6. On the Wash and Inspection Form (Appendix 3), write "manual" in the "Time" box, and 

return the Form to Driver. 

0803/800043.0009/9389102.3 WP06 0803/800043.0009/9462110.1 0001 

Page4 of6 
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 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 spray 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. Always 

use man doors and aisle ways. 

6.0 Enforcement 

Any employee, contractor and consultant found to have violated this policy must be subject to 

disciplinary action, up to and including termination. of employment. 

DB03/800043.0009/9389102.3 WP06 

DB03/800043.0009/9462110.1 DDOl 

Page 5 of6 
Certified Trainer 

Lead-Bearing 

Materials 

Ore 

Vehicle 

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 written 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 contamin ated soils excavated from 

residential yards, road edges, churches, vacant 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 and 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 
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 Inspection", 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". 

OperatorName ___________ _ __ OperatorName _ _ ____ _ ______ _ 

Date __________ _ 

BO OK Ch ec k Th e o F II 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 DDOl 

1 Operator/Inspector (full name): 

Tarp: functional, no Tarp position Tailgate: 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 of BO Condition: 

WASH AND TAILGATE INSPECTION 

Unload Buick Mine/Mill 

Load \l.·.J.sh S"lat:r.lH !1:15 Mm~;.'Ca:.tt:d #29 Mme. V1hwuum 

s ECOND D lAlLY 1 lh NSPECTION (inspection required sometime after 4 load and prior to last load of!he day) 

Location: Time: 1 Operator/Inspector (full name): 

Tarp: functional, no Tarp position Tailgate: 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 of BO Condition: 

.. Top!Whtte Copy- Envrronmenta! ProJect Manager ~fiddle w Cooy- Carner Truck Driver Bottom/Pmk Cooy Loadmg Facthty Copy 

0803/800043.0009/9462133.1 DDOl 

y 

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p

y

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 
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 material. Once loose 

material is removed, circle "Y'' (yes) on Form. 

2. Operator shall inspect the tailgate. Specifically note the follow1ng: 

a. tailgate is securely latched and has· no gaps through which Ore or Lead-Bearing 

Materials could be released. 

b. confirm that there is no evidence of Ore or Lead-Bearin 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 LeadBearing 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 vehicle wall through which Ore or Lead-Bearing 

Materials could be released, or if Ore or Lead-Bearing Materials leakage is observed, 

Operator shall: 

a. note specific problem and circle "N" (no) on Form in "Secure tailgate (no 

leakage)?" box. 

b. require Driver to return to loading location and to 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 manually wash vehicles. With the power washer, start at the 

top leading edge and wash front to back. Upon reaching the back, lower spray stream to 

just below last sweep and continue to wash toward front of vehicle. Continue this process 

of washing top to bottom Wltil spray distribution reaches bottom edge of vehicle. 

DB03/800043. 0009/9398286.1 WP06 

DB03/800043.000919462141.l DDOl 

2 
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 "Time" box, and return completed Form to Driver. 

DB031cl00043.0009/9398286.1 WP06 DBO 004~ 9/9462 141.1 DDOI 

3 

Attorney for Complainant: 

Steven Sanders 

Assistant Regional Counsel 

Region 7 

United States Environmental Protection Agency 

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 

, Missouri 63048 

~it~ 

Hearing Clerk, Region 7