## 2005 Hourly Lead Emission Inventory for the Doe

Run Company's Herculaneum, Missouri Smelter

Prepared For : The Doe Run Company Prepared By: Shell Engineering &Associates, Inc.

2403 West Ash Columbia MO, 65203

February l, 2007

## Table of Contents

Table of Contents. . . . . . . . . . . . . . . . .. .. . .. .. .. . .. .. .. . .. .. . ... . .. .. .. . .. .. . .. .. .. .. . .. .. .. . .. .. .. .. . .. .. .i List of Tables . . . . .. . . . . . . . . . . . . . . . . . .. .. . .. .. .. . .. .. . .. .. .. . ... . .. .. .. . .. .. . .. .. .. .. . .. .. .. . .. .. .. .. . .. . .ii

.. List of Figures. . . .. . . . . . .. . . . . . .. . . . .. .. . .. .. .. .. . .. .. . .. .. .. .. . .. .. .. . .. .. . .. .. .. .. . .. .. .. . .. .. .. .. . .. . .ii 1 .0 Introduction . . . . . .. . . . . . .. . . . .. .. . .. .. .. .. . .. .. . ... . .. .. . .. .. .. . .. .. . .. .. .. .. . .. .. .. . .. .. .. .. . .. . .i 1 .1 Project Description . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . .. . . . . . . . . . .. .. . . . . . .. . . . .. . . . . . . . . . . . . . .. . . . . . . . .1 1 .2 Facility Description . . . . .. . . . . . . . . . .. . . . . . . . . . . . . . .. . . . . . . . . . .. . . . . . . . .. . . . .. . . .. . . . . . . . . . .. . . . . . . . .2 2.0 Unloading Department .. .. .. . .. .. .. . .. .. . ... . .. .. . .. .. .. . .. .. .. . .. .. .. . .. .. .. . .. .. .. .. . . .14 3.0 Sinter Plant . . . . . . .. . . . . . .. . . . .. .. .. . .. .. .. . .. .. . ... . .. .. . .. .. .. . .. .. . .. .. .. .. . .. .. .. . .. .. .. .. . . .21 4.0 Blast Furnace . . . . . . . . . . .. . . . . . .. .. . .. .. .. . .. .. . ... . .. .. . .. .. .. . .. .. .. . .. .. .. . .. .. .. . .. .. .. .. . . .32 5.0 Drossing Plant . . . . . . . . . .. . . . . . .. .. . .. .. .. . .. .. . ... . .. .. . .. .. .. . .. .. .. . .. .. .. . .. .. .. . .. .. .. .. . . .36 6.0 Refinerv.. . . . . . .. . . . . . . . . . . .. . . . . . .. .. . .. .. .. . .. .. . ... . .. .. . .. .. .. . .. .. .. . .. .. .. . .. .. .. . .. .. .. .. . . .40 7.0 RO D _Rolling Mil1. . . . . . . . . . . . . .. .. . .. .. .. . .. .. . ... . .. .. .. . .. .. .. . .. .. . .. .. .. . .. .. .. . .. .. .. .. . . .47 8.0 Fugitive Emissions. . . . . . . .. .. .. . .. .. . .. .. . ... . .. .. .. . .. .. .. . .. .. . .. .. .. . .. .. .. . .. .. .. .. . .. 53 8.1 Storage Piles-Material Handling. . . . .. .. . . . . . . . . . .. . . . . . . . . . . . .. .. . . . .. .. . . . . . . . . . . . . . . . . . . .53 8.2 Storage Piles-Wind Erosion . .. .. . . . . . .. .. . . . . . . . . . .. . . . . . . . . . . . .. .. . . . .. .. . . . . . . . . . . . . . . . . .. .57 8.3 Haul Roads . . . . . . . .. .. . . . . . .. . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . .. .. . . . .. .. . . . . . . . . . . . . . . . . . . .63

## List of Tables

Table 1-1 . Source Summarv.. . .. .. .. . .. .. . .. .. .. . ... . . ... . .. .. . .. .. . .. .. .. . .. .. . .. .. . .. .. .. . .. .4 Table 8-1 . Material /Storage Pile Information .. . .. .. . .. .. . .. .. .. . .. .. . .. .. . .. .. .. . .77 Table 8-2. Street Sample Summarv..... .. .. .. . ... . . ... . .. .. . .. .. .. . .. .. . .. .. . .. .. .. . .. .. ..78 

## List of Figures Figure 1-1 . Figure 1-2. Ficgure 1-3. Figure 2-1 . Figure 2-2. Figure 2-3. Figure 3-1 . Figure 3-2. Figure 4-1 . Figure 5-1 . Figure 6-1 . Figure 6-2. Figure 7-1 . Figure 7-2. Figure 8-1 . Figure 8-2. Figure 8-3. Fiqure 8-4. 2005 Annual Emissions by Department. .. .. . .. .. . .. .. .. . .. .. .. . .. .. 11

General Facilitv_Location.. . ... . . ... . .. .. .. . .. .. . .. :. . .. .. . .. .. .. . .. .. .. . .. . .12 General__Facilitv Lavout . ... . .. .. . .. .. .. . .. .. . .. .. . .. .. . .. .. . .. .. .. . .. .. . .. .. . . 13 Hourly Traffic Scalars .. . ... . .. .. . .. .. . .. .. .. . .. .. . .. .. . .. .. . .. .. .. . .. .. . .. .. . . 18 Daily Concentrate Deliverv. .. . .. .. . .. .. .. . .. .. .. . .. .. . .. .. . .. .. . .. .. . .. .. . . 19 Dailv_Unloadinq Department Emissions.. . .. .. . .. .. . .. .. . .. .. . .. .. . .20 Dailv Sinter Production . .. . .. .. . .. .. .. . .. .. . .. .. .. . .. .. . .. .. . .. .. . .. .. .. . .. . .30 Daily Sinter Plant Emissions. . .. .. .. . .. .. . .. .. .. . .. .. . .. .. . .. .. . .. .. .. . .. ..31 Dailv Blast Furnace Emissions. .. .. . .. .. . .. .. .. . .. .. . .. .. . .. .. . .. .. .. . .. ..35 Dailv Dross Plant Emissions . .. . .. .. . .. .. . .. .. .. . .. .. . .. .. . .. .. . .. .. .. . .. . .39 Daily Refined Lead Production .. .. . .. .. .. . .. .. . .. .. . .. .. .. . .. .. . .. .. .. . ..45 Daily Refinery Emissions. . .. .. .. . .. .. .. . .. .. . .. .. . .. .. . .. .. . .. .. .. . .. .. .. . ..46 Daily Lead Strip Production.. .. . .. .. .. . .. .. . .. .. . .. .. . .. .. . .. .. .. . .. .. .. . .. 51 Daily Strip Rollinq Mill Emissions.. . .. .. . .. .. . .. .. .. . .. .. . .. .. .. . .. .. . .. 52 Haul Roads . .. . . . .. .. .. . .. .. . .. .. .. . .. .. . .. .. .. . .. .. . .. .. . .. .. .. . .. .. . .. .. . .. .. .. . . .79 Haul Roads (Continuedj .. .. . .. .. . .. .. .. . .. .. . .. .. . .. .. .. . .. .. . .. .. . .. .. .. . . .80 Haul Roads (Continued) .. .. . .. .. .. . .. .. . .. .. . .. .., . . .. .. . .. .. . .. .. .. . .. .. . . .81 Dailv_Fuqitive Emissions.. .. . .. .. .. . .. .. . .. .. . .. .. . .. .. .. . .. .. .. . .. .. . .. .. . . .82

## 1 .0 Introduction

Z,1 Project Description _ The Doe Run Company operates a primary lead smelter in Herculaneum, Missouri, located approximately 25. miles south of St. Louis, Missouri, adjacent to the Mississippi River. The city of Herculaneumwas designated as nonattainment for lead in 1991 . The Missouri Department of Natural Resources submitted a revised SIP in 1994, which failed to meet the quarterly lead National Ambient Air Quality Standard (NAAQS) . An additional SIP revision was submitted in 2001, which established an attainment date of August 14, 2002. Following the August 2002 attainment date, lead monitoring in Herculaneumindicated that the lead NAAQS was met for ten consecutive quarters. However, measured lead concentrations at the Broad Street monitor site exceeded the lead standard for the first three quarters of 2005. Violations have also occurred in the 1St and 3rd quarters during 2006

. Based on these violations of the lead NAAQS, ~the Missouri lead SIP must be revised so the Herculaneumarea will be in attainment of the lead standard. An integral part of developing the revision to the lead SIP is the development of the hourly lead emission inventory that will be used as input into the atmospheric dispersion model . The purpose of this report is to discuss in detail the methodology that has been used in the development of the emission inventory. In accordance with the recommendations of the Missouri Department of Natural Resources (MDNR) and Region 7 EPA, the year of 2005 was used as the study period for the analysis. The remainder of the report has broken out into seven sections, one for each department at the facility: Section 2 - Unloading Department Section 3 - Sinter PlantSection 4 - Blast Furnace (Includes the Main Stack)

Section 5 - Drossing Plant Section 6- Refinery Section 7 - Strip Rolling Mill Section 8 - Fugitive Emissions (Storage Piles and Haul Roads) The emission points at the smelter and changes since the 2000 SIP study have been summarized in Table 1-1 . The annual lead emissions for each department have been summarized in Figure 1-1 . 

### Z,2 Facility Description As previously mentioned, the smelter is located in Herculaneum, Missouri . A map showing the general location of the facility has been provided as Figure 1-2 and the general facility layout has been depicted in Figure 1-3. Lead concentrate, which contains approximately 75%lead by weight, is delivered to the facility by truck. The trucks currently come down main street and enter on the south end of the plant north of the strip rolling mill . The trucks dump the concentrate into a hopper and the material is then conveyed to a storage pile. The concentrate is then picked up using a front end loader and dumped into a railcar. The railcar transports the concentrate to the rotary dumper where it is unloaded and transferred to the mixing bins. The concentrate, secondary feed constituents, and return sinter are then crushed and mixed before being sent to the sinter machine. The material coming off of the sinter machine is screened. The overs (sinter) are crushed using a smooth roll crusher (in the sinter plant) and are then ready to be fed to the blast furnace. The fines (material that needs additional contact time on the sinter machine) are cooled and crushed before returning to the sinter machine for additional processing. The fines drop from the screen to a conveyor that feeds the sinter cooler. The cooled sinter then drops onto the CV-30 belt that fills the 130ton return fines bin. The CV-37A belttransports the fines fromthe bin to the smooth roll crusher which feeds the CV37B belt. Material on the CV-37B belt puts the material back to the sinter machine feed line. The sintered material, which contains approximately 50%lead, is mixed with coke and fed to the blast furnace. Molten lead exits the bottomof the blast furnace and is transferred to the drossing plant in pots using overhead cranes. Slag is also tapped off of the blast furnace. The slag is granulated and then is either used as a feedstock to the sinter machine or is hauled to storage. In the drossing department, the molten lead is cooled and impurities are skimmed fromthe surface. The lead is approximately 97%pure when it exits the drossing plant for the refinery. In the refinery, the remaining trace amounts of impurities are removed producing a refined lead that is greater than 99.999% pure. The lead is then sent to either the casting machine or the strip rolling mill to put it into its final form .Table 1-1 . Source Summary Change from 2005Annual Source ID Source

Description Department the 2000 SIP Pb Emissions Study (Ib/yr) When the 2000 SIP study was developed concentrate was Dump- Unloading delivered by rail . 10001A1 Concentrate- Department Concentrate is 370

Hopper now delivered to the facility by truck and unloaded at the hopper.

_ , When the 2000

SIP study was developed concentrate was Dump- Unloading delivered by rail . 10001A2 Concentrate- Department Concentrate is 370

Storage nowdelivered to the facility by truck and unloaded at the hopp er. Load-Conc.- Unloading j 10001B1 Railcar (Front Department No Change 382

End Loader Concentrate is Dump-Conc. And now loaded with 10001132 Sec.-Unloader . Unloading secondaries on

the south end 459 (80%Conc, 20% Department and mix is Sec) dumped at the unloader. Fume is now dumped with concentrate at 10001C Dump-Fume- Unloading the unloader. ---

Unloader Department Source Removed. Emissions accounted for in 10001132.Load-Sinter20001A,13 Railcar/Dump- Sinter Plant No Change 0.219

Sinter-UnloaderLoad-Sinter20002,3 Truck/Dump- Sinter Plant No Change 0.18

Sinter-StorageSource ID Source Description Department Change from the 2000SIP Study 2005Annual

Pb Emissions (Ib/yr) When the 2000 SIP study was developed dry fume was loaded to railcar and then transferred to the unloader and dumped. Load-Fume- Fume is now 20004 Railcar Sinter Plant loaded to railcar 3 wet (>8% moisture, 30% typical) and stored on the south end. It is then loaded with concentrate and dumped at the unloader When the 2000 SIP study was developed dry fume was loaded

. to railcar and

then transferred to the unloader and dumped. Railcar Fume Fume is now 20004B Unloading (At Sinter Plant loaded to railcar 3

Storage) wet (>8% moisture, 30% typical) and stored on the south end. It is then loaded with concentrate and dumped at the unloaderChange from 2005Annual Source ID Source

Description Department the 2000 SIP Pb Emissions Study (Ib/yr) When the 2000 SIP study was developed dry fume was loaded to railcar and then transferred to the unloader and dumped. Railcar Fume Fume is now 20004C (South, Front Sinter Plant loaded to railcar 2

End Loader) ' wet (>8% moisture, 30% typical) and stored on the south end. It is then loaded with concentrate and dumped at the unloader The 2000 SIP study included Sinter Plant Mix sinter handling in 20005A-F RoomFugitives- Sinter Plant the mix room . 461 Concentrate and Sinter is not Fume Handling handled in the mix roomand was removed. As part of the model reconciliation work and comparison to

, " the CMB data

and meassured 20006 Sinter Plant Sinter Plant lead values, the 1408

Building Fugitives sinter plant fugitives were scaled up by a factor of 4 from the emissions used in the 2000 SIP study. 20007 Baghouse No. 3 Sinter Plant No Change 14

Fugitives Revised emission 30001 Main Stack Blast Furnace factor from 12/9/2004 Stack 50007 TestSource Change from 2005Annual Source ID Description Department the 2000SIP Pb Emissions Study (Ib/yr) As part of the 2000SIP control strategy the blast furnace building 30002 Blast Furnace Blast Furnace openings were 1744 I

Fugitves enclosed (30002) and the charge belt roof vent was enclosed - (30003-5) . 30011-13 Baghouse No. 5 Blast Furnace No Change 22 Vents 40004,5 Dross Kettle Heat

Stacks Dross Plant No Change 83 As part of the 2000 SIP control strategy the dross aerovents were removed 40006 Dross Plant Dross Plant (40001-3) . A 1047

Fugitives baghouse was added to ventilate the dross plant (40007, Ba house No. 7) . This is a new baghouse added 40007 Baghouse No. 7 Dross Plant as part of the 4032 2000SIP control strategy. As part of the 2000 SIP control strategy the refinery roof monitors (50001- ` 2) and aerovents Refinery Plant (50004-5) were 50006 Fugitives Refinery removed. Two 1055 baghouses were added to ventilate the refinery (50007, Baghouse 8 and 50008, Baghouse 9 .Change from 2005 Annual Source ID Source

Description Department the 2000SIP Pb Emissions Study (Ib/yr) This is a new baghouse added 50007 Baghouse No. 8 Refinery as part of the 1964 2000 SIP control strategy. This is a new baghouse added 50008 Baghouse No. 9 Refinery as part of the 13301 2000 SIP control strategy. 50011-18 Kettle Setting

Heat Stacks Refinery No Change 880 60001 2 Strip Mill Heat Strip Mill No Change 1 , Stacks 60003 Strip Mill

Ba house Strip Mill No Change 0.04 60004 LowAlpha

Baghouse Strip Mill No Change 5 60005-8 Strip Mill Roof Strip Mill No Change 24

Vents 70001 Fugitive Dross

Handling Fugitives No Change 11 70007 Fugitive Slag Fugitives No Change 0.15

Handling Fugitive 70009 Secondaries Fugitives No Change 1

Handling Dross Storage 70002 Fugitive Wind Fugitives No Change 0

Erosion Conc. Storage 70004 Fugitive Wind Fugitives No Change 0

Erosion Sinter Storage 70006 Fugitive Wind Fugitives No Change 0

Erosion Slag Storage 70008A,B Fugitive Wind Fugitives No Change 80

Erosion Sec Storage 70010 Fugitive Wind Fugitives No Change 0

ErosionSource Change from 2005Annual Source ID Description Department the 2000 SIP Pb Emissions Study (Ib/yr) NewSource. In Hwy 55 to plant and outside 70100-122 JoachimBridge Fugitives plant haul road 97

Exit (Segment A- emissions B) completely updated. New Source. In JoachimBridge plant and outside 70150-213 Exit to Plant Fugitives plant haul road 955

Entrance emissions (Segment B-C) completely updated. New Source. In Plant Entrance to plant and outside 70250-252 NW

Corner of Fugitives plant haul road 63 Strip Mill Building emissions (Segment C-D) completely updated. NW Corner of NewSource. In Strip Mill Building plant and outside 70300 to.Concentrate Fugitives plant haul road 11

Hopper emissions (Segment D-E) completely updated. Concetrate New Source. In Hopper to SW plant and outside 70350-358 Corner of Strip Fugitives plant haul road 14

Mill Building emissions (Segment E-F) completely updated. NW Corner of New Source. In Strip Mill Building plant and outside 70400-406 to SW Corner of Fugitives plant haul road 39 Strip Mill Building emissions (Segment D-F) completely updated. SW Corner of NewSource. In Strip Mill Building plant and outside 70450-454 to North End of Fugitives plant haul road 24

Slag Haul Road ` J emissions (Segment F-G) completely updated.Change from 2005Annual Source ID Source

Description Department the 2000 SIP Pb Emissions Study (Ib/yr)

, New

Source. In North End of plant and outside 70500-513 Slag Haul Road Fugitives plant haul road 157

to Refinery Dock emissions (Segment G-H) completely updated. New Source. In South Slag Haul plant and outside 70550-553 Road (Paved) Fugitives plant haul road 21

(Segment G-K) emissions completely updated. North End of NewSource. In plant and outside Main Building to plant haul road 70600-612 Refinery Dock Fugitives emissions 2801

(Unpaved) completely (Segment H-L) updated. New Source. In Sinter Plant to plant and outside 70650-669 Sinter Storage Fugitives plant haul road 17

(Segment I-J) , emissions completely updated. New Source. In South Slag Haul plant and outside 70700-703 Road (Unpaved) Fugitives plant haul road 29$

(Segment K-M) emissions completely updated.

1047

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## 2.0 Unloading Department

10001A1 Dump-Concentrate-Hopper Emission Factor Pb Emission Factor = 1 .63E-03 Ib-Pb/Tons-Concentrate-Handled Test at the trestle operation (73.75 g-Pb/100ton-Concentrate-Dumped) TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 1, Source 10001 . When the 2000 SIP was developed concentrate was delivered by rail . Production Data ° 2005 Average Daily Production Rate = 621 Tons-Concentrate-Handled/day Given Daily Lead Emissions The average daily Pb emissions were then calculated for each production day (6amto 6amof the following day) . A sample calculation using the average daily production rate has been provided below : 2005 Average Daily Pb Emissions = 621 (Tons-Concentrate-Handled/day) * 1 .63E-03 (Ib-Pb/Tons-ConcentrateHandled) * 1 Sources = 1 .0129 Ib-Pb/day Annual Lead Emissions The annual lead emissions can be calculated fromthe average daily lead emissions: 2005 Annual Pb Emissions = 1 .0129 (Ib-Pb/day) * 365 (day/yr) _ 370 Ib-Pb/yr Hourly Lead Emissions Daily emissions apportioned to each hour using the traffic scalars. Refer to TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 7. Refer to Figure 2-1 .10001A2

Dump-Concentrate-Storage Emission Factor Pb Emission Factor = 1 .63E-03 Ib-Pb/Tons-Concentrate-Handled Test at the trestle operation (73.75 g-Pb/100ton-Concentrate-Dumped) TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 1, Source 10001 . When the 2000 SIP was developed concentrate was delivered by rail . Production Data 2005 Average Daily Production Rate = 621 Tons-Concentrate-Handled/day Given Daily Lead Emissions The average daily Pb emissions were then calculated for each production day (6amto 6amof the following day) . A sample calculation using the average daily production rate has been provided below : 2005 Average Daily Pb Emissions = 621 (Tons-Concentrate-Handled/day) * 1 .63E-03 (Ib-Pb/Tons-ConcentrateHandled) * 1 Sources = 1 .0129 Ib-Pb/day Annual Lead Emissions The annual lead emissions can be calculated fromthe average daily lead emissions: 2005 Annual Pb Emissions = 1 .0129 (Ib-Pb/day) * 365 (day/yr) _ 370 Ib-Pb/yr Hourly Lead Emissions Daily emissions apportioned to each hour using the traffic scalars. Refer to TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 7. Refer to Figure 2-1 .10001131

Load-Conc.-Railcar (Front End Loader) Emission Factor Pb Emission Factor = 1 .63E-03 Ib-Pb/Tons-Concentrate-Handled Test at the trestle operation (73.75 g-Pb/100ton-Concentrate-Dumped) TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 1, Source 10001 . Production Data 2005 Average Daily Production Rate = 642 Tons-Concentrate-Handled/day Given Daily Lead Emissions The average daily Pb emissions were then calculated for each production day (6amto 6amof the following day) . A sample calculation using the average daily production rate has been provided below : 2005 Average Daily Pb Emissions = 642 (Tons-Concentrate-Handled/day) * 1 .63E-03 (Ib-Pb/Tons-ConcentrateHandled) * 1 Sources = 1 .0471 Ib-Pb/day Annual Lead Emissions The annual lead emissions can be calculated fromthe average daily lead emissions: 2005 Annual Pb Emissions = 1 .0471 (Ib-Pb/day) * 365 (day/yr) _ 382 Ib-Pb/yr Hourly Lead Emissions Daily Emissions prorated over the 6 hours between 6a and 12a.10001B2

Dump-Conc. And Sec.-Unloader (80%Conc, 20%Sec) Emission Factor Pb Emission Factor = 1 .63E-03 Ib-Pb/Tons-Concentrate-Handled Test at the trestle operation (73.75 g-Pb/100ton-Concentrate-Dumped) TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 1, Source 10001 . Secondaries and fume are nowmixed w/ the concentrate on the south end (80/20 split) before being dumped at the unloader. Production Data 2005Average Daily Production Rate = 771 Tons-Concentrate-Handled/day (Conc. Feed to Sinter Plant) * 1 .2 ` ` 80 tons of concentrate is loaded into each railcar. The railcars are then topped off (additional 20 tons) with secondaries (ie cleanup) . Daily Lead Emissions The average daily Pb emissions were then calculated for each production day (6amto 6am

of the following day) . A sample calculation using the average daily production rate has been provided below : 2005 Average Daily Pb Emissions = 771 (Tons-Concentrate-Handled/day) * 1 .63E-03 (Ib-Pb/Tons-ConcentrateHandled) * 1 Sources = 1 .2565 Ib-Pb/day Annual Lead Emissions The annual lead emissions can be calculated fromthe average daily lead emissions: 2005 Annual Pb Emissions = 1 .2565 (Ib-Pb/day) * 365 (day/yr) _ 459 Ib-Pb/yr Hourly Lead Emissions Daily Emissions prorated over the 6 hours between 6a and 12a.c~r rLa N 0 .-i Nu

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20001A,B Load-Sinter-Railcar/Dump-Sinter-Unloader Emission Factor Pb Emission Factor = 1 .15E-05 Ib-Pb/Tons-Sinter-Handied Test at the trestle operation TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 2, Source 20001 . Production Data 2005 Average Daily Production Rate = 26 Tons-Sinter-Handled/day Given Daily Lead Emissions The average daily Pb emissions were then calculated for each production day (6amto 6amof the following day) . A sample calculation using the average daily production rate has been provided below : 2005 Average Daily Pb Emissions = 26 (Tons-Sinter-Handled/day) * 1 .15E-05 (Ib-Pb/Tons-Sinter-Handled) * 2 Sources = 0.0006 Ib-Pb/day Annual Lead Emissions The annual lead emissions can be calculated fromthe average daily lead emissions: 2005 Annual Pb Emissions = 0.0006 (Ib-Pb/day) * 365 (day/yr) _ 0.219 Ib-Pb/yr Hourly Lead Emissions Daily Emissions prorated over the 6 hours between 6a and 12a.20002,3

Load-Sinter-Truck/Dump-Sinter-Storage Emission Factor Pb Emission Factor = 1 .15E-05 Ib-Pb/Tons-Sinter-Handled Test at the trestle operation TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 2, Source 20002 and 20003. Production Data 2005 Average Daily Production Rate = 23 Tons-Sinter-Handled/day (Sinter Produced) * 0.02 2005 Blast Furnace-Sinter Feed-FromStorage = 9613 tpy. 2005 Sinter Produced = 415212 tpy. 9613/415212 = 0.02. Daily Lead Emissions The average daily Pb emissions were then calculated for each production day (6amto 6am

of the following day) . A sample calculation using the average daily production rate has been provided below : 2005 Average Daily Pb Emissions = 23 (Tons-Sinter-Handied/day) * 1 .15E-05 (Ib-Pb/Tons-Sinter-Handied) * 2 Sources = 0.0005 Ib-Pb/day Annual Lead Emissions The annual lead emissions can be calculated fromthe average daily lead emissions: 2005 Annual Pb Emissions = 0.0005 (Ib-Pb/day) * 365 (day/yr) _ 0.18 Ib-Pb/yr Hourly Lead Emissions _ , Daily emissions prorated over the day (typically operates 24 hr/dy) . The production data utilized in the anlaysis is referenced to the "production day" 6a of day i to 6a of day (i+1) .20004

Load-Fume-Railcar Emission Factor Pb Emission Factor = 7.06E-03 Ib-Pb/Tons-Fume-Handled Test at the trestle operation (3202.22 g-Pb/100ton-Fume-Dumped) . This testing was done when the fume was dumped dry. The fume is now sent to storage at approximately 30%moisture. The emissions were estimated at 1/10 of the tested level . TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 2, Source 20004. Production Data 2005 Average Daily Production Rate = 1 Tons-Fume-Handled/day (Sinter Produced) * 0.001 . Fume Unloaded (10/1/98-4/30/99) = 350 tons. Sinter Produced (10/1/98- 4/30/99) = 406023 tons. 350/460023=0.001 . Daily Lead Emissions The average daily Pb emissions were then calculated for each production day (6amto 6amof the following day) . A sample calculation using the average daily production rate has been provided below : 2005 Average Daily Pb Emissions = 1 (Tons-Fume-Handled/day) * 7.06E-Q3-~Ib-Pb/Tons-Fume-Handled) * 1 Sources 0.0069 Ib-Pb/day Annual Lead Emissions The annual lead emissions can be calculated fromthe average daily lead emissions: 2005 Annual Pb Emissions = 0.0069 (Ib-Pb/day) * 365 (day/yr) _ 3 Ib-Pb/yr Hourly Lead Emissions Daily Emissions prorated over the 6 hours between 6a and 12a.20004B

Railcar Fume Unloading (At Storage) Emission Factor Pb Emission Factor = 7.06E-03 Ib-Pb/Tons-Fume-Handled Test at the trestle operation (3202.22 g-Pb/100ton-Fume-Dumped) . This testing was done when the fume was dumped dry. The fume is now sent to storage at approximately 30%moisture. The emissions were estimated at 1/10 of the tested level . TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 2, Source 20004. When the 2000 SIP was developed fume was stored in railcars and then dumped by itself at the unloader. Fume is now taken by rail to the south end and put to storage (wet, >8%moisture) . The fume is then added to the concentrate cars and dumped. Production Data 2005 Average Daily Production Rate = 1 Tons-Fume-Handled/day (Sinter Produced) * 0.001 Fume Unloaded (10/1/98-4/30/99) = 350 tons. Sinter Produced (10/1/98- 4/30/99) = 406023 tons. 350/460023=0.001 . Daily Lead Emissions The average daily Pb emissions were then calculated for each production day (6amto 6am

of the following day) . Asample calculation using the average daily production rate has been provided below : 2005 Average Daily Pb Emissions = 1 (Tons-Fume-Handled/day) * 7.06E-03 (Ib-Pb/Tons-Fume-Handled) * 1 Sources 0.0069 Ib-Pb/day Annual Lead Emissions The annual lead emissions can be calculated fromthe average daily lead emissions: 2005 Annual Pb Emissions = 0.0069 (Ib-Pb/day) * 365 (day/yr) _ 3 Ib-Pb/yr Hourly Lead Emissions Daily Emissions prorated over the 6 hours between 6a and 12a. 2420004C

Railcar Fume (South, Front End Loader) Emission Factor Pb Emission Factor = 7.06E-03 Ib-Pb/Tons-Fume-Handled Test at the trestle operation (3202.22 g-Pb/100ton-Fume-Dumped) . This testing was done when the fume was dumped dry. The fume is now sent to storage at approximately 30%moisture. The emissions were estimated at 1/10 of the tested level . TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 2, Source 20004. When the 2000 SIP was developed fumewas stored in railcars and then dumped by itself at the unloader. Fume is now taken by rail to the south end and put to storage (wet, >8%moisture) . The fume is then added to the concentrate cars and dumped. Production Data 2005 Average Daily Production Rate = 1 Tons-Fume-Handled/day (Conc. Used) * 0.0151 Fume Produced (2005) = 356 tons. Conc. Used (2005) = 235148 tons. 356/235148 = 0.00151 . Daily Lead Emissions The average daily Pb emissions were then calculated for each production day (6amto 6amof the following day) . A sample calculation using the average daily production rate has been provided below : 2005 Average Daily Pb Emissions = 1 (Tons-Fume-Handied/day) * 7.06E-03 (Ib-Pb/Tons-Fume-Handied) * 1 Sources 0.0068 Ib-Pb/day Annual Lead Emissions The annual lead emissions can be calculated fromthe average daily lead emissions: 2005 Annual Pb Emissions = 0.0068 (Ib-Pb/day) * 365 (day/yr) _ 2 Ib-Pb/yr Hourly Lead Emissions Daily Emissions prorated over the 6 hours between 6a and 12a. 2520005A-F

Sinter Plant Mix RoomFugitives-Concentrate Handling Emission Factor Pb Emission Factor = 1 .63E-03 Ib-Pb/Tons-Concentrate-Handled Test at the trestle operation (73.75 g-Pb/100ton-Concentrate-Dumped) TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 2, Source 20005. , , Production Data 2005 Average Daily Production Rate = 775 Tons-Concentrate-Handled/day Given Daily Lead Emissions The average daily Pb emissions were then calculated for each production day (6amto 6amof the following day) . A sample calculation using the average daily production rate has been provided below : 2005Average Daily Pb Emissions = 771 (Tons-Concentrate-Handled/day) * 1 .63E-03 (Ib-Pb/Tons-ConcentrateHandled) * 1 Sources = 1 .2567 Ib-Pb/day Annual Lead Emissions The annual lead emissions can be calculated fromthe average daily lead emissions: 2005 Annual Pb Emissions = 1 .2567 (Ib-Pb/day) * 365 (day/yr) _ 458.7 Ib-Pb/yr Hourly Lead Emissions Daily Emissions prorated over the 6 hours between 6a and 12a.20005A-F

Sinter Plant Mix RoomFugitives-Fume Handling Emission Factor Pb Emission Factor = 7.06E-03 Ib-Pb/Tons-Fume-Handled Test at the trestle operation (3202.22 g-Pb/100ton-Fume-Dumped) . This testing was done when the fume was dumped dry. The fume is now sent to storage at approximately 30%moisture. The emissions were estimated at 1/10 of the tested level . TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 2, Source 20005. Production Data 2005 Average Daily Production Rate = 1 Tons-Fume-Handled/day (Sinter Produced) * 0.001 Fume Unloaded (10/1/98-4/30/99) = 350 tons. Sinter Produced (10/1/98- 4/30/99) = 406023 tons. 350/460023=0.001 . Daily Lead Emissions The average daily Pb emissions were then calculated for each production day (6amto 6amof the following day) . A sample calculation using the average daily production rate has been provided below : 2005 Average Daily Pb Emissions = 1 (Tons-Fume-Handled/day) * 7.06E-03 (Ib-Pb/Tons-Fume-Handled) * 1 Sources = 0.0071 Ib-Pb/day Annual Lead Emissions The annual lead emissions can be calculated fromthe average daily lead emissions: 2005 Annual Pb Emissions = 0.0071 (Ib-Pb/day) * 365 (day/yr) _ 2.6 Ib-Pb/yr Hourly Lead Emissions Daily Emissions prorated over the 6 hours between 6a and 12p.20006

Sinter Plant Building Fugitives Emission Factor Pb Emission Factor = 3.40E-03 Ib-Pb/Tons-Sinter-Produced Personnel Sampling (2000 SIP value times 4 per model reconcilliation work) (0.00085*4=0.0034 Ib/ton) TRCEnvironmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 2, Source 20006. Production Data 2005 Average Daily Production Rate = 1135 Tons-Sinter-Produced/day Given Daily Lead Emissions The average daily Pb emissions were then calculated for each production day (6amto 6amof the following day) . A sample calculation using the average daily production rate has been provided below : 2005 Average Daily Pb Emissions = 1135 (Tons-Sinter-Produced/day) * 3.4aE-03 (Ib-Pb/Tons-Sinter-Produced) * 1 Sources = 3.8578 Ib-Pb/day Annual Lead Emissions The annual lead emissions can be calculated fromthe average daily lead emissions: 2005 Annual Pb Emissions = 3.8578 (Ib-Pb/day) * 365 (day/yr) _ 1408 Ib-Pb/yr Hourly Lead Emissions Daily emissions prorated over the day (typically operates 24 hr/dy) . The production data utilized in the anlaysis is referenced to the "production day" 6a of day i to 6a of day (i+1) .20007

Baghouse No. 3 Fugitives Emission Factor Pb Emission Factor = 3.28E-05 Ib-Pb/Tons-Sinter-Produced In-house testing for the No. 5 Baghouse Vents (1981) TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 2, Source 20007. Production Data 2005 Average Daily Production Rate = 1135Tons-Sinter-Produced/day Given Daily Lead Emissions The average daily Pb emissions were then calculated for each production day (6amto 6amof the following day) . A sample calculation using the average daily production rate has been provided below : 2005 Average Daily Pb Emissions = 1135 (Tons-Sinter-Produced/day) * 3.28E-05 (Ib-Pb/Tons-Sinter-Produced) * 1 Sources = 0.0372 Ib-Pb/day Annual Lead Emissions The annual lead emissions can be calculated fromthe average daily lead emissions: 2005 Annual Pb Emissions = 0 .0372 (Ib-Pb/day) * 365 (day/yr) _ 14 Ib-Pb/yr Hourly Lead Emissions Daily emissions prorated over the day (typically operates 24 hr/dy) . The production data utilized in the anlaysis is referenced to the "production day" 6a of day i to 6a of day (i+l) ._

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30001 Main Stack Emission Factor Pb Emission Factor = 5.70E-02 Ib-Pb/(Tons-Sinter-Produced)+(Tons-Lead Bearing Material-Charged to the Blast Furnace) 12/9/2004 Stack Test 7.1/124.58 = 5.7e-2 Ib/ton Production Data 2005 Average Daily Production Rate = 2-404 (Tons-Sinter-Produced)+(Tons-Lead Bearing Material-Charged to the Blast Furnace)/day Given Daily Lead Emissions The average daily Pb emissions were then calculated for each production day (6amto 6am

of the following day) . A sample calculation using the average daily production rate has been provided below : 2005 Average Daily Pb Emissions = 2404 ((Tons-Sinter-Produced)+(Tons-Lead~ Bearing Material-Charged to the Blast Furnace)/day) * 5.70E-02 (Ib-Pb/(Tons-Sinter-Produced)+(Tons-Lead Bearing Material-Charged to the Blast Furnace)) * 1 Sources = 137.0065 Ib-Pb/day Annual Lead Emissions The annual lead emissions can be calculated fromthe average daily lead emissions: _ 2005 Annual Pb Emissions = 137.0065 (Ib-Pb/day) * 365 (day/yr) _ 50007 Ib-Pb/yr Hourly Lead Emissions Daily emissions prorated over the day (typically operates 24 hr/dy) . The production data utilized in the anlaysis is referenced to the "production day" 6a of day i to 6a of day (i+1) . 3230002

Blast Furnace Fugitves Emission Factor Pb Emission Factor = 4.10E-03 Ib-Pb/Tons-Sinter-Charged to the Blast Furnace 30002-5 2000 SIP pre-control emission factor (8.2E-02 Ib/ton) with a 95% capture efficiency TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 3, Source 30002. . ~- As part of the 2000 SIP control strategy the blast furnace building openings were enclosed (30002) and the charge belt roof vent was enclosed (30003-5) . Production Data 2005 Average Daily Production Rate = 1166 Tons-Sinter-Charged to the Blast Furnace/day Given Dailv Lead Emissions The average daily Pb emissions were then calculated for each production day (6amto 6amof the following day) . A sample calculation using the average daily production rate has been provided below : 2005 Average Daily Pb Emissions = 1166 (Tons-Sinter-Charged to the Blast Furnace/day) * 4.10E-03 (Ib-Pb/TonsSinter-Charged to the Blast Furnace) * 1 Sources = 4.77881b-Pb/day Annual Lead Emissions The annual lead emissions can be calculated fromthe average daily lead emissions: 2005 Annual Pb Emissions = 4.7788 (Ib-Pb/day) * 365 (day/yr) _ 1744 Ib-Pb/yr Hourly Lead Emissions Daily emissions prorated over the day (typically operates 24 hr/dy) . The production data utilized in the anlaysis is referenced to the "production day" 6a of day i to 6a of day (i+i) .30011-13

Baghouse No. 5 Vents Emission Factor Pb Emission Factor = 1 .70E-05 Ib-Pb/Tons-Sinter-Charged to the Blast Furnace In-house testing for the No. 5 Baghouse Vents (1981) . 5.ie-5/3=1 .7e-5. TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 3, Source 30011-13. Production Data 2005 Average Daily Production Rate = 1166 Tons-Sinter-Charged to the Blast Furnace/day Given Daily Lead Emissions The average daily Pb emissions were then calculated for each production day (6amto 6am

of the following day) . A sample calculation using the average daily production rate has been provided below : 2005 Average Daily Pb Emissions = 1166 (Tons-Sinter-Charged to the Blast Furnace/day) * 1 .70E-05 (Ib-Pb/TonsSinter-Charged to the Blast Furnace) * 3 Sources = 0.0594 Ib-Pb/day Annual Lead Emissions The annual lead emissions can be calculated fromthe average daily lead emissions: 2005 Annual Pb Emissions = 0.0594 (Ib-Pb/day) * 365 (day/yr) _ 22 Ib-Pb/yr Hourly Lead Emissions Daily emissions prorated over the day (typically operates 24 hr/dy) . The production data utilized in the anlaysis is referenced to the "production day" 6a of day i to 6a of day (i+1) .0 H W V f0 G L O N

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## 5.0 Drossing Plant

40004,5 Dross Kettle Heat Stacks Emission Factor Pb Emission Factor = 5.19E-04 Ib-Pb/Tons-Rough Lead-Produced Stack test of No. 4 kettle heat stack (1999) TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 4, Source 40004-5. Production Data 2005 Average Daily Production Rate = 438 Tons-Rough Lead-Produced/day (Refined Lead Produced) / 0.97 Refined Lead Produced (10/1/98-4/30/99) = 151470 tons. Rough Lead Produced (10/1/98-4/30/99) = 156450 tons. 151470/156450=0.97. Daily Lead Emissions The average daily Pb emissions were then calculated for each production day (6amto 6am

of the following day) . Asample calculation using the average daily production rate has been provided below : 2005 Average Daily Pb Emissions = I ° 438 (Tons-Rough Lead-Produced/day) * 5.19E-04 (Ib-Pb/Tons-Rough LeadProduced) * 1 Sources = 0.2273 Ib-Pb/day Annual Lead Emissions The annual lead emissions can be calculated fromthe average daily lead emissions: 2005 Annual Pb Emissions = 0.2273 (Ib-Pb/day) * 365 (day/yr) _ 83 Ib-Pb/yr Hourly Lead Emissions Daily emissions prorated over the day (typically operates 24 hr/dy) . The production data utilized in the anlaysis is referenced to the "production day" 6a of day i to 6a of day (i+1) . 3640006

Dross Plant Fugitives Emission Factor Pb Emission Factor = 6.55E-03 Ib-Pb/Tons-Rough Lead-Produced 40001-3 2000 SIP pre-control emission factor (1 .31E-01 Ib/ton) with a .95% capture efficiency TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 4, Source 40001-3. As part of the 2000 SIP control strategy the dross aerovents were removed (40001-3) . A baghouse was, added to ventilate the dross plant (40007, Baghouse No. 7) . Production Data 2005 Average Daily Production Rate = 438Tons-Rough Lead-Produced/day (Refined Lead Produced) / 0.97 Refined Lead Produced (10/1/98-4/30/9g) = 151470 tons. Rough Lead Produced (10/1/98-4/30/99) = 156450 tons. 151470/156450=0.97. Daily Lead Emissions The average daily Pb emissions were then calculated for each production day (6amto 6amof the following day) . A sample calculation using the average daily production rate has been provided below : 2005 Average Daily Pb Emissions = 438 (Tons-Rough Lead-Produced/day) * 6.55E-03 (Ib-Pb/Tons-Rough LeadProduced) * 1 Sources = 2.8692 Ib-Pb/day Annual Lead Emissions The annual lead emissions can be calculated fromthe average daily lead emissions: 2005 Annual Pb Emissions = 2.8692 (Ib-Pb/day) * 365 (day/yr) _ 1047 Ib-Pb/yr Hourly Lead Emissions Daily emissions prorated over the day (typically operates 24 hr/dy) . The production data utilized in the anlaysis is referenced to the "production day" 6a of day i to 6a of day (i+1) . 3740007

Baghouse No. 7 Emission Factor - ° Pb Emission Factor = 9.48E-03 Ib-Pb/Tons-Sinter-Charged to the Blast Furnace 12/3/2002 Stack Test 0.5/52.75=9.48e-3 Ib/ton This is a new

baghouse added as part of the 2000 SIP control strategy. Production Data 2005 Average Daily Production Rate = 1166 Tons-Sinter-Charged to the Blast Furnace/day Given Daily Lead Emissions The average daily Pb emissions were then calculated for each production day (6amto 6amof the following day) . A sample calculation using the average daily production rate has been provided below : 2005 Average Daily Pb Emissions = _ 1166 (Tons-Sinter-Charged to the Blast Furnace/day) * 9.48E-03 (Ib-Pb/TonsSinter-Charged to the Blast Furnace) * 1 Sources = 11 .0479 Ib-Pb/day Annual Lead Emissions The annual lead emissions can be calculated fromthe average daily lead emissions: 2005 Annual Pb Emissions = 11 .0479 (Ib-Pb/day) * 365 (day/yr) _ 4032 Ib-Pb/yr Hourly Lead Emissions Daily emissions prorated over the day (typically operates 24 hr/dy) . The production data utilized in the anlaysis is referenced to the "production day" 6a of day i to 6a of day (i+l) .0 N

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.0 Refinery 50006 Refinery Plant Fugitives Emission Factor Pb Emission Factor = 6.80E-03 Ib-Pb/Tons-Refined Lead-Produced 50001-2,4-5 2000 SIP pre-control emission factor (1 .36E-01 Ib/ton) with a 95% capture efficiency TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 5. As part of the 2000 SIP control strategy the refinery roof monitors (50001-2) and aerovents (50004-5) were removed. Two baghouses were added to ventilate the refinery (50007, Baghouse 8 and 50008, Baghouse 9) . Production Data 2005 Average Daily Production Rate = 425 Tons-Refined Lead-Produced/day Given Daily Lead Emissions The average daily Pb emissions were then calculated for each production day (6amto 6amof the following day) . A sample calculation using the average daily production rate has been provided below : 2005 Average Daily Pb Emissions = 425 (Tons-Refined Lead-Produced/day) * 6.80E-03 (Ib-Pb/Tons-Refined LeadProduced) * 1 Sources = 2.8893 Ib-Pb/day Annual Lead Emissions The annual lead emissions can be calculated fromthe average daily lead emissions: 2005 Annual Pb Emissions = 2.8893 (Ib-Pb/day) * 365 (day/yr) _ 1055 Ib-Pb/yr Hourly Lead EmissionsDaily emissions prorated over the day (typically operates 24 hr/dy) . The

production data utilized in the anlaysis is referenced to the "production day" 6a of day i to 6a of day (i+i) .50007

Baghouse No. 8 Emission Factor Pb Emission Factor = 1 .27E-02 Ib-Pb/Tons-Refined Lead-Produced 12/5/2002 StackTest 0 .21/16.58=1 .27e-2 Ib/ton This is a new

baghouse added as part of the 2000 SIP control strategy. Production Data 2005 Average Daily Production Rate = 425Tons-Refined Lead-Produced/day Given Daily Lead Emissions The average daily Pb emissions were then calculated for each production day (6amto 6amof the following day) . A sample calculation using the average daily production rate has been provided below : 2005 Average Daily Pb Emissions = 425 (Tons-Refined Lead-Produced/day) * 1 .27E-02 (Ib-Pb/Tons-Refined LeadProduced) * 1 Sources = 5.3817 Ib-Pb/day Annual Lead Emissions The annual lead emissions can be calculated fromthe average daily lead emissions: 2005 Annual Pb Emissions = 5.3817 (Ib-Pb/day) * 365 (day/yr) _ 1964 Ib-Pb/yr Hourly Lead Emissions Daily emissions prorated over the day (typically operates 24 hr/dy) . The production data utilized in the anlaysis is referenced to the "production day" 6a of day i to 6a of day (i+1) .50008

Baghouse No. 9 Emission Factor Pb Emission Factor = 8.58E-02 Ib-Pb/Tons-Refined Lead-Produced 12/4/2002 Stack Test 1 .44/16.79=8.58e-2 Ib/ton This is a new

baghouse added as part of the 2000 SIP control strategy. Production Data 2005 Average Daily Production Rate =`425 Tons-Refined Lead-Produced/day Given Daily Lead Emissions The average daily Pb emissions were then calculated for each production day (6amto 6amof the following day) . A sample calculation using the average daily production rate has been provided below : 2005 Average Daily Pb Emissions = 425 (Tons-Refined Lead-Produced/day) * 8.58E-02 (Ib-Pb/Tons-Refined LeadProduced) * 1 Sources = 36.4416 Ib-Pb/day Annual Lead Emissions The annual lead emissions can be calculated fromthe average daily lead emissions: 2005 Annual Pb Emissions = 36.4416 (Ib-Pb/day) * 365 (day/yr) _ 13301 Ib-Pb/yr Hourly Lead Emissions Daily emissions prorated over the day (typically operates 24 hr/dy) . The production data utilized in the anlaysis is referenced to the "production day" 6a of day i to 6a of day (i+i) .50011-18

Kettle Setting Heat Stacks Emission Factor Pb Emission Factor = 7.09E-04 Ib-Pb/Tons-Refined Lead-Produced Stack test of No. 3 kettle heat stack (1999) TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 5, Sources 50011-18. Production Data 2005 Average Daily Production Rate = 425Tons-Refined Lead-Produced/day Given Daily Lead Emissions The average daily Pb emissions were then calculated for each production day (6amto 6amof the following day) . A sample calculation using the average daily production rate has been provided below : 2005 Average Daily Pb Emissions = 425 (Tons-Refined Lead-Produced/day) * 7.09E-04 (Ib-Pb/Tons-Refined LeadProduced) * 8 Sources = 2.4100 1b-Pb/day Annual Lead Emissions The annual lead emissions can be calculated fromthe average daily lead emissions: 2005 Annual Pb Emissions = 2.4100 (Ib-Pb/day) * 365 (day/yr) _ 880 Ib-Pb/yr Hourly Lead Emissions Daily emissions prorated over the day (typically operates 24 hr/dy) . The production data utilized in the anlaysis is referenced to the "production day" 6a of day i to 6a of day (i+1) .c



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60001,2 Strip Mill Heat Stacks Emission Factor Pb Emission Factor = 2.13E-04 Ib-Pb/Tons-Lead Strip-Produced Stack test of No. 3 kettle heat stack (1999) proportioned down to the size of the unit (30%of the refinery unit) . 0.000709 Ib/ton * 0.3 TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 6, Sources 60001-2. Production Data 2005 Average Daily Production Rate = 8 Tons-Lead Strip-Produced/day Given Daily Lead Emissions The average daily Pb emissions were then calculated for each production day (6amto 6am

of the following day) . A sample calculation using the average daily production rate has been provided below : 2005 Average Daily Pb Emissions = 8 (Tons-Lead Strip-Produced/day) * 2.13E-04 (Ib-Pb/Tons-Lead Strip-Produced) * 2 Sources = 0.0032 Ib-Pb/day Annual Lead Emissions The annual lead emissions can be calculated fromthe average daily lead emissions: 2005 Annual Pb Emissions = 0.0032 (Ib-Pb/day) * 365 (day/yr) _ 1 Ib-Pb/yr Hourly Lead Emissions Daily emissions prorated over the day (typically operates 24 hr/dy) . The production data utilized in the anlaysis is referenced to the "production day" 6a of day i to 6a of day (i+1) . 4760003

Strip Mill Baghouse Emission Factor Pb Emission Factor = 1 .12E-05 Ib-Pb/Tons-Lead Strip-Produced Uncontrolled emission factor fromAP-42, Table 2.3-2 (0.0007 Ib/ton) . A 98.4% control efficiency for the fabric filter was then utilized (AP-42, Table 2.3-5) . TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 6, Source 60003. Production Data 2005 Average Daily Production Rate = 8 Tons-Lead Strip-Produced/day Given Daily Lead Emissions The average daily Pb emissions were then calculated for each production day (6amto 6amof the following day) . A sample calculation using the average daily production rate has been provided below :, 2005 Average Daily Pb Emissions = 8 (Tons-Lead Strip-Produced/day) * 1 .12E-05 (Ib-Pb/Tons-Lead Strip-Produced) * 1 Sources = 0.0001 Ib-Pb/day Annual Lead Emissions The annual lead emissions can be calculated fromthe average daily lead emissions: 2005 Annual Pb Emissions = 0.0001 (Ib-Pb/day) * 365 (day/yr) _ 0.04 Ib-Pb/yr Hourly Lead Emissions Daily emissions prorated over the day (typically operates 24 hr/dy) . The production data utilized in the anlaysis is referenced to the "production day" 6a of day i to 6a of day (i+i) .60004

Low Alpha Baghouse Emission Factor Pb Emission Factor = 3.58E-01 Ib-Pb/Tohs-Lead Bearing Material-Charged to the Low Alpha Furnace Stack Testing (1999) . Note that the emission factor used in the 2000 SIP was based on Ib-Pb per Ib-charge. This was updated to a Ib/ton basis for consistency with other sources. 1 .79e-4*2000=0.358 Ib/ton. TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 6, Source 60004. Production Data 2005 Average Daily Production Rate = 0.04Tons-Lead Bearing Material-Charged to the Low

Alpha Furnace/day (Refined Lead Produced) * 9e-5 Low Alpha Charge (10/1/98-4/30/99) = 14 tons. Refined Lead Produced (10/1/98-4/30/99) = 151470 tons. 14/151470 = 9e-5. Daily Lead Emissions The average daily Pb emissions were then calculated for each production day (6amto 6amof the following day) . A sample calculation using the average daily production rate has been provided below : 2005 Average Daily Pb Emissions = 0.04 (Tons-Lead Bearing Material-Charged to the Low Alpha Furnace/day) * 3.58E-01 (Ib-Pb/Tons-Lead Bearing Material-Charged to the Low Alpha Furnace) * 1 Sources = 0.0137 Ib-Pb/day Annual Lead Emissions The annual lead emissions can be calculated fromthe average daily lead emissions: 2005 Annual Pb Emissions = 0.0137 (Ib-Pb/day) * 365 (day/yr) _ 5 Ib-Pb/yr Hourly. Lead Emissions Daily Emissions prorated over the 6 hou~_s between 6a and 12a. 4960005-8

Strip Mill Roof Vents Emission Factor Pb Emission Factor = 2.21E-03 Ib-Pb/Tons-Lead Strip-Produced Personnel Sampling. Emission factor is for each vent. 8.84e-3/4=2.21e-3 Ib/ton. TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 6, Source 60005. Production Data 2005 Average Daily Production Rate = 8 Tons-Lead Strip-Produced/day Given Daily Lead Emissions - ° The average daily Pb emissions were then calculated for each production day (6amto 6amof the following day) . Asample calculation using the average daily production rate has been provided below : 2005 Average Daily Pb Emissions = 8 (Tons-Lead Strip-Produced/day) * 2.21E-03 (Ib-Pb/Tons-Lead Strip-Produced) * 4 Sources = 0.0670 Ib-Pb/day Annual Lead Emissions The annual lead emissions can be calculated fromthe average daily lead emissions: 2005 Annual Pb Emissions = 0.0670 (Ib-Pb/day) * 365 (day/yr) _ 24 Ib-Pb/yr Hourly Lead Emissions Daily emissions prorated over the day (typically operates 24 hr/dy) . The production data utilized in the anlaysis is referenced to the "production day" 6a of day i to 6a of day (i+1) .0

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## 8.0 Fugitive Emissions

8,1 Storage Piles-Material Handling Production for the fugitive handling sources was assumed proportional to the refined lead produced. Dross - Refined lead produced times 0.046 Slag - Refined lead produced times 0.032 Secondaries - Refined lead produced times 0.058 Material is handled at the storage piles approximately 12 hours per day from6a to 6p. The fugitive particulate handling emissions were calculated using the methodology presented in AP42, Section 13.2.4 (Aggregate Handling and Storage Piles) . The equation has been presented below : E = 0.74 * 0.0032 * (U/5)1~3 / (M/2)1~4 * (Pb/100) E = Lead emission factor (Ib/ton) U = Average wind speed (mph) M = Material moisture content (%) Pb = Material lead content (%) The lead and moisture contents have been provided in Table 8-1 . Refer to TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 7.70001

Fugitive Dross Handling Emission Factor Pb Emission Factor = Varies Ib-Pb/Tons-~Material-Handled AP42, Section 13.2.4 TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 7, Material Handling. Hourly emissions vary by avg. hourly wind speed and material throughput. Emissions are also dependent upon the material moisture content and lead fraction. Production Data 2005 Average Daily Production Rate = 20 Tons-Material-Handled/day (Refined Lead Produced) * 0.046 Dross to Storage (10/1/98-4/30/99) = 6916 tons. Refined Lead Produced (10/1/98-4/30/99) = 151470 tons. 6916/151470 = 0.046. Daily Lead Emissions The average daily Pb emissions were then calculated for each production day (6amto 6am

of the following day) . A sample calculation using the average daily production rate has been provided below :, 2005 Average Daily Pb Emissions = 20 (Tons-Material-Handled/day) * Varies (Ib-Pb/Tons-Material-Handled) * 1 Sources = 0.0290 Ib-Pb/day Annual Lead Emissions The annual lead emissions can be calculated fromthe average daily lead emissions: 2005 Annual Pb Emissions = 0.0290 (Ib-Pb/day) * 365 (day/yr) _ 11 Ib-Pb/yr Hourly Lead Emissions Daily Emissions prorated over the 12 hours between 6a and 6p.70007

Fugitive Slag Handling Emission Factor Pb Emission Factor = Varies Ib-Pb/Tons-Material-Handled AP42, Section 13.2.4 TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 7, Material Handling. Hourly emissions vary by avg. hourly wind speed and material throughput. Emissions are also dependent upon the material moisture content and lead fraction. Production Data 2005 Average Daily Production Rate = 14 Tons-Material-Handled/day (Refined Lead Produced) * 0.032 Slag to Storage (10/1/98-4/30/99) = 4739 tons. Refined Lead Produced (10/1/98-4/30/99) = 151470 tons. 4739/151470 = 0.032. Daily Lead Emissions The average daily Pb emissions were then calculated for each production day (6amto 6amof the following day) . A sample calculation using the average daily production rate has been provided below : 2005 Average Daily Pb Emissions = 14 (Tons-Material-Handled/day) * Varies (Ib-Pb/Tons-Material-Handled) * 1 Sources = 0.0004 Ib-Pb/day Annual Lead Emissions The annual lead emissions can be calculated fromthe average daily lead emissions: 2005 Annual Pb Emissions = 0.0004 (Ib-Pb/day) * 365 (day/yr) _ 0.15 Ib-Pb/yr Hourly Lead Emissions Daily Emissions prorated over the 12 hours between 6a and 6p.70009

Fugitive Secondaries Handling Emission Factor _ Pb Emission Factor = Varies Ib-Pb/Tons-Material-Handled AP42, Section 13.2.4 TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 7, Material Handling. Hourly emissions vary by avg. hourly wind speed and material throughput. Emissions are also dependent upon the material moisture content and lead fraction. Production Data 2005 Average Daily Production Rate = 25 Tons-Material-Handled/day (Refined Lead Produced) * 0.058 Plant and Sump Cleanings to Storage (10/1/98-4/30/99) = 8763 tons. Refined Lead Produced (10/1/98-4/30/99) = 151470 tons. 8763/151470 = 0.058. Daily Lead Emissions The average daily Pb emissions were then calculated for each production day (6amto 6amof the following day) . Asample calculation using the average daily production rate has been provided below :~ 2005 Average Daily Pb Emissions = 25 (Tons-Material-Handled/day) * Varies (Ib-Pb/Tons-Material-Handled) * 1 Sources = 0.0037 Ib-Pb/day Annual Lead Emissions The annual lead emissions can be calculated fromthe average daily lead emissions: 2005 Annual Pb Emissions = 0.0037 (Ib-Pb/day) * 365 (day/yr) _ 1 Ib-Pb/yr Hourly Lead Emissions Daily Emissions prorated over the 12 hours between 6a and 6p.

### 8,2 Storage Piles-WindErosion

The fugitive wind erosion emissions were calculated using the methodology presented in AP42, Section 13.2.5 (Industrial Wind Erosion) . The equation has been presented belowfor friction velocities exceeding the threshold friction velocity: P = (58 * (u* - ut*)z + 25 * (u*-ut*)) * (Pb/100) P = Lead Erosion (g/m2) u* = Friction velocity (m/s) ut* = Threshold friction velocity (m/s) Pb = Material lead content (%) If the friction velocity is less than the threshold friction velocity, the erosion is assumed equal to zero. The friction velocity is calculated by multiplying the maximumhourly 5-minute average wind speed in mph by 0.0053. The 5-minute average wind speed corresponds well with the typical time of an erosion event. The lead content, storage pile area, and threshold friction velocity for each storage pile have been provided in Table 8-1 .70002

Dross Storage Fugitive Wind Erosion Emission Factor Pb Emission Factor = Varies Ib-Pb/m2-hr AP42, Section 13.2.5 TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 7, Wind Erosion. A potential emission rate was calculated for each hour using the referenced equation and the material lead content. The friction velocity was calculated by multiplying the 5-min. maximumwind speed by 0.053. If the friction velocity was geater than the Production Data 2005 Average Daily Production Rate = Emissions are referenced to storage area not throughput. 465 square meters TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 7, Pb and Moisture of Materials Stored Outside (Table) . 100*50* .3048^2 = 465 Annual Lead Emissions 2005 Annual Pb Emissions = 0 Ib-Pb/yr There were no wind events during 2005 that exceeded the threshold friction velocity of the storage pile.70004

Conc. Storage Fugitive Wind Erosion Emission Factor ' Pb Emission Factor = Varies Ib-Pb/m2-hr AP42, Section 13.2.5. TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 7, Wind Erosion. A potential emission rate was calculated for each hour using the referenced equation and the material lead content. The friction velocity was calculated by multiplying the 5-min. maximumwind speed by 0.053. If the friction velocity was geater than the Production Data 2005 Average Daily Production Rate = Emissions are referenced to storage area not throughput. 1161 square meters TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 7, Pb and Moisture of Materials Stored Outside (Table) . 250*50* .3048^2 = 1161 Annual Lead Emissions 2005 Annual Pb Emissions = 0 Ib-Pb/yr v There were no wind events during 2005 that exceeded the threshold friction velocity of the storage pile.70006

Sinter Storage Fugitive Wind Erosion Emission Factor Pb Emission Factor = Varies Ib-Pb/m2-hr AP42, Section 13.2.5 TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 7, Wind Erosion. A potential emission rate was calculated for each hour using the referenced equation and the material lead content. The friction velocity was calculated by multiplying the 5-min. maximumwind speed by 0.053. If the friction velocity was geater than the Production Data - ° 2005 Average Daily Production Rate = Emissions are referenced to storage area not throughput. 1742 square meters TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 7, Pb and Moisture of Materials Stored Outside (Table) . 375*50* .3048^2 = 1742 Annual Lead Emissions 2005 Annual Pb Emissions = 0 Ib-Pb/yr There were no wind events during 2005 that exceeded the threshold friction velocity of the storage pile.70008A,B

Slag Storage Fugitive Wind Erosion Emission_Factor Pb Emission Factor = Varies Ib-Pb/m2-hr AP42, Section 13.2.5 TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 7, Wind Erosion. A potential emission rate was calculated for each hour using the referenced equation and the material lead content. ~The friction velocity was calculated by multiplying the 5-min. maximumwind speed by 0.053. If the friction velocity was geater than the Production Data 2005 Average Daily Production Rate = Emissions are referenced to storage area not throughput. 72565 square meters TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 7, Pb and Moisture of Materials Stored Outside (Table) . Annual Lead Emissions 2005 Annual Pb Emissions = 80 Ib-Pb/yr70010

Sec Storage Fugitive Wind Erosion Emission Factor Pb Emission Factor = Varies Ib-Pb/m2-hr AP42, Section 13.2.5 TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 7, Wind Erosion. A potential emission rate was calculated for each hour using the referenced equation and the material lead content.c,The friction velocity was calculated by multiplying the 5-min. maximumwind speed by 0.053. If the friction velocity was geater than the Production Data 2005 Average Daily Production Rate = Emissions are referenced to storage area not throughput. 465 square meters TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 7, Pb and Moisture,of Materials Stored Outside (Table) . 100*50* .3048^2 = 465 Annual Lead Emissions 2005 Annual Pb Emissions = 0 Ib-Pb/yr There were no wind events during 2005 that exceeded the threshold friction velocity of the storage pile.

### 8

.3 Haul Roads The haul roads at the facility were broken out into twelve segments: A-B Hwy 55 to Joachim Bridge Exit B-C JoachimBridge Exit to Plant Entrance C-D Plant Entrance to NW Corner of Strip Mill Building D-E NW

Corner of Strip Mill Building to Concentrate Hopper E-F Concetrate Hopper to SW Corner of Strip Mill Building D-F NW

Corner of Strip Mill Building to SW Corner of Strip Mill Building F-G SW

Corner of Strip Mill Building to North End of Slag Haul Road G-H North End of Slag Haul Road to Refinery Dock G-K South Slag Haul Road (Paved) H-L North End of Main Building to Refinery Dock - 1-J Sinter Plant to Sinter Storage K-M South Slag Haul Road (Unpaved) The results fromthe sampling of the streets in and around the facility have been summarized in Table 8-2. Maps showing the locations of each road segment have been provided as Figures 8-1, 8-2, and 8-3. The emissions fromthe paved haul roads were calculated using AP42, Section 13.2.1, Equation 1 and the lead content: E = 0 .082 * (sL/2)0.ss * (W/3)l .s * (Pb/100) E = Lead Emission Factor (Ib/VMT) sL = Surface Silt Loading (g/m2) W = Average Vehicle Weight (tons) Pb = Material Lead Content (%) , The emissions fromthe unpaved haul roads were calculated using AP42, Section 13.2.2, Equation 1a. E = 4.9 * (s/12)0

.7 * (W/3)0.45 * (Pb/100) E = Lead Emission Factor (Ib/VMT) sL = Surface Silt Content (%) W = Average Vehicle Weight (tons) 63Pb = Material Lead Content (%)

The daily lead emissions were calculated based on the daily amount of material hauled. The hourly emissions were apportioned using the traffic scalars. The traffic scalars were developed, and approved for use in the 2000 SIP study (Refer to TRC Environmental, "Doe Run Lead Emission Inventory Herculaneum Smelter", March 2000, Section 7 and Figure 2-1) . The vehicle miles traveled for each segment were calculated based on the amount of material hauled (each day), the average payload for each material hauled, and the length of the segment. For example, on segment A-B (outside plant haul road) concentrate, refined lead, and lead strip product are hauled. The concentrate, refined lead, and lead strip hauled during 2005 were 226812 tons, 155088 tons, and 2766 tons, respectively. The average payload for the trucks is 25 tons which equates to 9072 concentrate delivery trucks, 6204 refined lead product trucks, and 111 lead strip product trucks for the year of 2005. This equates to 15387 total trucks traveling over the A-B segment . The length of segment A-B is 4683 ft, therefore the total vehicle miles traveled for 2005 over segment A-B was 27295 miles. 2005 Haulage on Segment A-B = 15387 (trucks/yr) * 4683 (ft) / 5280 (ft/mi) * 2 = 27295 miles/yr Emissions were assumed negligible for hours that had at least 0.01" of precipitation.Paved Haul Roads

70100-122 Hwy 55 to JoachimBridge Exit (Segment A-B) Parameters Segment Length = 4683 ft 2005 Annual Traffic Rate = 27295 VMT/yr Silt Content = 7.5% TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 7, Paved Haul Roads. Dust Loading = 0.3491 g/m2 Station Sample Silt loading was calculated by multiplying the dust loading by the silt content. Silt Loading = 0.3491 (g/m2) * (7.5/100) _ 0.0262 g/m2 2005 Average Truck Weight = 26.74 tons Calculated fromthe weight and traffic rate of the individual trucks that travel on the segment. Lead Content of Road Dust = 2.73% Station Sample Annual Emission Calculation 2005 Annual Pb Emissions = 0.082 * [0.0262 (g/mz)/2]o.ss * [26.74 (tons)/3]1'5 * [Station Sample (%)/100] * 27295 (VMT/yr) _ 97 Ib-Pb/yr The emissions were calculated for each day and segment. Daily emissions were apportioned to each hour using the traffic scalars. Refer to TRCEnvironmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 7.70150-213

JoachimBridge Exit to Plant Entrance (Segment B-C) Parameters Segment Length = 12819 ft 2005 Annual Traffic Rate = 74718 VMT/yr Silt Content = 7.5% TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 7, Paved Haul Roads. Dust Loading = 0.6545 g/m2 Main &Curved Sample Silt loading was calculated by multiplying the dust loading by the silt content. Silt Loading = 0.6545 (g/m2) * (7.5/100) _ 0.0491 g/m2 2005 Average Truck Weight = 26.74 tons Calculated fromthe weight and traffic rate of the individual trucks that travel on the segment. Lead Content of Road Dust = 6.52% Main &Curved Sample Annual Emission Calculation 2005 Annual Pb Emissions = 0.082 * [0.0491,(g/m2)/2]°~65 * [26.74 (tons)/3]1~5 * [Main &Curved Sample (%)/100] * 74718 (VMT/yr) _ 955 Ib-Pb/yr The emissions were calculated for each day and segment . Daily emissions were apportioned to each hour using the traffic scalars. Refer to TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 7.70250-252

Plant Entrance to NW

Corner of Strip Mill Building (Segment C-D) Parameters . Segment Length = 465 ft 2005 Annual Traffic Rate = 2711 VMT/yr Silt Content - 7.5% TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 7, Paved Haul Roads. Dust Loading = 1 .4312 g/m2 Truck Wash Sample Silt loading was calculated by multiplying the dust loading by the silt content. Silt Loading = 1 .4312 (g/m2) * (7.5/100) _ 0.1073 g/m2 2005 Average Truck Weight = 26.74 tons Calculated fromthe weight and traffic rate of the individual trucks that travel on the segment. Lead Content of Road Dust = 7.17% Truck Wash Sample Annual Emission Calculation 2005 Annual Pb Emissions = 0.082 * [0.1073 (g/m2)/2]o.s5 * [26.74 (tons)/3]1'5 * [Truck Wash Sample (%)/100] * 2711 (VMT/yr) _ 63 Ib-Pb/yr The emissions were calculated for each day and segment. Daily emissions were apportioned to each hour using the traffic scalars. Refer to TRCEnvironmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 7.70300

NW Corner of Strip Mill Building to Concentrate Hopper (Segment D-E) Parameters Segment Length = 151 ft 2005 Annual Traffic Rate = 260VMT/yr Silt Content = 7.5% TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 7, Paved Haul Roads. Dust Loading = 1 .4312 g/m2 Truck Wash Sample Silt loading was calculated by multiplying the dust loading by the silt content. Silt Loading = 1 .4312 (g/m2) * (7.5/100) _ 0.1073 g/m2 2005 Average Truck Weight = 38.70 tons Calculated fromthe weight and traffic rate of the individual trucks that travel on the segment. Lead Content of Road Dust = 7.17% Truck Wash Sample Annual Emission Calculation 2005 Annual Pb Emissions = 0.082 * [0.1073 (g/m2)/2]o.ss * [38.70 (tons)/3]1~5 * [Truck Wash Sample (%)/100] * 260 (VMT/yr) _ 11 Ib-Pb/yr The emissions were calculated for each day and segment. Daily emissions were, apportioned to each hour using the traffic scalars. Refer to TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 7.70350-358

Concetrate Hopper to SW Corner of Strip Mill Building (Segment E-F) Parameters Segment Length = 746 ft 2005 Annual Traffic Rate = 1360VMT/yr Silt Content = 7.5% TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 7, Paved Haul Roads. Dust Loading = 1 .4312 g/m2 Truck Wash Sample Silt loading was calculated by multiplying the dust loading by the silt content. Silt Loading = 1 .4312 (g/m2) * (7.5/100) _ 0.1073 g/m2 2005 Average Truck Weight = 15.77 tons Calculated fromthe weight and traffic rate of the individual trucks that travel on the segment. Lead Content of Road Dust = 7.17% Truck Wash Sample Annual Emission Calculation 2005 Annual Pb Emissions = 0.082 * [0.1073 (g/mz)/2]o.65 * [15.77 (tons)/3]1~5 * [Truck Wash Sample (%)/100] * 1360 (VMT/yr) _ 14 Ib-Pb/yr The emissions were calculated for each day and segment. Daily emissions were apportioned to each hour using the traffic scalars. Refer to TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 7.70400-406

NW Corner of Strip Mill Building to SW Corner of Strip Mill Building (Segment DF) Parameters Segment Length = 544 ft 2005 Annual Traffic Rate = 2234 VMT/yr Silt Content = 7.5% TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 7, Paved Haul Roads. Dust Loading = 1 .4312 g/m2 Truck Wash Sample Silt loading was calculated by multiplying the dust loading by the silt content. Silt Loading = 1 .4312 (g/m2) * (7.5/100) _ 0.1073 g/m2 2005 Average Truck Weight = 21 .85 tons Calculated fromthe weight and traffic rate of the individual trucks that travel on the segment. Lead Content of Road Dust = 7.17% Truck Wash Sample Annual Emission Calculation 2005 Annual Pb Emissions = 0.082 * [0.1073 (g/mz)/2]o.ss * [21 .85 (tons)/3]15 * [Truck Wash Sample (%)/100] * 2234 (VMT/yr) _ 39 Ib-Pb/yr The emissions were calculated for each day and segment. Daily emissions were apportioned to each hour using the traffic scalars. Refer to TRCEnvironmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 7.70450-454

SW Corner of Strip Mill Building to North End of Slag Haul Road (Segment F-G) Parameters Segment Length = 413 ft 2005 Annual Traffic Rate = 1013 VMT/yr Silt Content = 7.5% TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 7, Paved Haul Roads. Dust Loading = 1 .4312 g/m2 Truck Wash Sample Silt loading was calculated by multiplying the dust loading by the silt content. Silt Loading = 1 .4312 (g/m2) * (7.5/100) _ 0.1073 g/m2 2005 Average Truck Weight = 27.25 tons Calculated fromthe weight and traffic rate of the individual trucks that travel on the segment. Lead Content of Road Dust = 7.17% Truck Wash Sample Annual Emission Calculation 2005 Annual Pb Emissions = 0.082 * [0.1073 (g/m2)/2]o'6s * [27.25 (tons)/3]1~5 * [Truck Wash Sample (%)/100] * 1013 (VMT/yr) _ 241b-Pb/yr The emissions were calculated for each day and segment. Daily emissions were apportioned to each hour using the traffic scalars. Refer to TRCEnvironmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 7.70500-513

North End of Slag Haul Road to Refinery Dock (Segment G-H) Parameters Segment Length = 1073 ft 2005 Annual Traffic Rate = 4716 VMT/yr Silt Content = 7.5% TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 7, Paved Haul Roads. Dust Loading = 1 .0094 g/m2 Dock Exit Sample Silt loading was calculated by multiplying the dust loading by the silt content . Silt Loading = 1 .0094 (g/m2) * (7.5/100) _ 0.0757 g/m2 2005 Average Truck Weight = 30.34 tons Calculated fromthe weight and traffic rate of the individual trucks that travel on the segment . Lead Content of Road Dust = 10.62% Dock Exit Sample Annual Emission Calculation 2005 Annual Pb Emissions = 0 .082 * [0.0757 (g/mz)/2]o.ss * [30 .34 (tohs)/3]1~5 * [Dock Exit Sample (%)/100] * 4716 (VMT/yr) _ 157 Ib-Pb/yr The emissions were calculated for each day and segment. Daily emissions were apportioned to each hour using the traffic scalars. Refer to TRCEnvironmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 7.70550-553

South Slag Haul Road (Paved) (Segment G-K) Parameters Segment Length = 276 ft 2005 Annual Traffic Rate = 535 VMT/yr Silt Content = 7.5% TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 7, Paved Haul Roads. Dust Loading = 1 .0094 g/m2 Dock Exit Sample Silt loading was calculated by multiplying the dust loading by the silt content. Silt Loading = 1 .0094 (g/m2) * (7.5/100) _ 0.0757 g/m2 2005 Average Truck Weight = 34.26 tons Calculated fromthe weight and traffic rate of the individual trucks that travel on the segment. Lead Content of Road Dust = 10.62% Dock Exit Sample Annual Emission Calculation 2005 Annual Pb Emissions = 0.082 * [0.0757 (g/m2)/2]o.6s * [34.26 (tons)/3]1~5 * [Dock Exit Sample (%)/100] * 535 (VMT/yr) _ 21 Ib-Pb/yr The emissions were calculated for each day and segment. Daily emissions were apportioned to each hour using the traffic scalars. Refer to TRCEnvironmental, "Doe Run Lead Emission Inventory He`rculaneumSmelter", March 2000, Section 7.70650-669

Sinter Plant to Sinter Storage (Segment I-J) Parameters Segment Length = 1377 ft 2005 Annual Traffic Rate = 434 VMT/yr` , Silt Content = 7.5% TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 7, Paved Haul Roads. Dust Loading = 1 .0094 g/m2 Dock Exit Sample Silt loading was calculated by multiplying the dust loading by the silt content. Silt Loading = 1 .0094 (g/m2) * (7.5/100) _ 0.0757 g/m2 2005 Average Truck Weight = 34.19 tons Calculated fromthe weight and traffic rate of the individual trucks that travel on the segment. Lead Content of Road Dust = 10.62% Dock Exit Sample Annual Emission Calculation 2005 Annual Pb Emissions = 0.082 * [0.0757 (g/mZ)/2]o.6s * [34.19 (tons)/3]1~5 * [Dock Exit Sample (%)/100] * 434 (VMT/yr) _ 17 Ib-Pb/yr The emissions were calculated for each day and segment. Daily emissions were apportioned to each hour using the traffic scalars. Refer to TRCEnvironmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 7.Unpaved Haul Roads

70600-612 North End of Main Building to Refinery Dock (Unpaved) (Segment H-L) Parameters Segment Length = 1229 ft 2005 Annual Traffic Rate = 2383 VMT/yr Silt Content = 8.3% TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 7, Unpaved Haul Roads. 2005 Avg. Truck Weight = 32.59 tons Lead Content = 10.62% Dock Exit Sample Annual Emission Calculation 2005 Annual Pb Emissions = 4 .9 * [8.3(%)/12]°~' * [32.59 (tons)/3]0.41 * [10.62 (%)/100] * 2383 (VMT/yr) _ 2801 Ib-Pb/yr The emissions were calculated for each day and segment. Daily emissions were apportioned to each hour using the traffic scalars. Refer to TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 7.70700-703

South Slag Haul Road (Unpaved) (Segment K-M) Parameters Segment Length = 463 ft 2005 Annual Traffic Rate = 897 VMT/yr Silt Content = 8.3% TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 7, Unpaved Haul Roads. 2005 Avg. Truck Weight = 32.59 tons Lead Content = 3.00% Slag Lead Content . Typical is 1%, however the fraction was increased to 3% to be conservative. This was agreed upon after consultation with MDNR . Annual Emission Calculation 2005 Annual Pb Emissions = 4.9 * [8.3(%)/12]0~' * [32.59 (tons)/3]0.41 * [3.00 (%)/100] * 897 (VMT/yr) _ 298 Ib-Pb/yr The emissions were calculated for each day and segment. Daily emissions were apportioned to each hour using the traffic scalars. Refer to TRC Environmental, "Doe Run Lead Emission Inventory HerculaneumSmelter", March 2000, Section 7.Table 8-1 . Material/Storage Pile Information Material Dross Conc. Sinter Slag Sec Moisture Content % 2 2 8 Lead Content % 56 ~ 79 44 1 40

~ Storage Pile Area m2 465 1161 1742 72565 465 Threshold Friction Veloci ty ( m /s) 1 .12 1 .12 1 .12 0.45 1 .12 Wind Erosion

70002 Dross 70004 Concentrate 70006 Sinter 70008 Slag 70010 Secondaries Fugitive Handling

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