## Technical Support Document for Recommendation of
Nonattainment Boundaries in Missouri for the 2008 Lead National Ambient Air Quality Standard

Adopted by the
Missouri Air Conservation Commission December 3, 2009

Division of Environmental Quality Air Pollution Control Program
P.O. Box 176
1659 East Elm Street Jefferson City, Missouri 65102 Telephone (573) 751-4817ii This page intentionally left blank.iii Table of Contents

LIST OF FIGURES................................................................................................................ .................................. IV

LIST OF TABLES................................................................................................................. .....................................V

INTRODUCTION ................................................................................................................... ....................................7

COMBUSTION SOURCE ANALYSIS..................................................................................................... ................9

GLOVER SMELTER

................................................................................................................. ..............................10

E XISTING L EAD M ONITORING N ETWORK AND P AST M ONITORING R ESULTS ..........................................................10
C ONCLUSION

............................................................................................................................... ............................14

HERCULANEU M SM ELTER

............................................................................................................ .....................15

E XISTING L EAD M ONITORING N ETWORK AND P AST M ONITORING R ESULTS ..........................................................15
S PATIAL I NTERPOLATION OF A IR Q UALITY M ONITORING I NFORMATION ................................................................18

M ODELING R ESULTS AND A NALYSIS .......................................................................................................................21
A NALYSIS OF F ACTORS TO C HANGE P RESUMPTIVE B OUNDARY ..............................................................................23
C ONCLUSION

............................................................................................................................... ............................25

BUICK SMELTER AND TH E VIBURNUM TREND ..........................................................................................2 7

E XISTING L EAD M ONITORING N ETWORK AND P AST M ONITORING R ESULTS ..........................................................27

M ODELING R ESULTS AND A NALYSIS .......................................................................................................................29
A NALYSIS OF F ACTORS TO C HANGE P RESUMPTIVE B OUNDARY ..............................................................................32
C ONCLUSION

............................................................................................................................... ............................33

OTHER AREAS WITH LEAD SOURCES .................................................................................................. ..........36

S ECONDARY S MELTER

............................................................................................................................... ..............36 Exide Technologies ............................................................................................................. ...............................36

I NACTIVE L EAD M INE A REAS

............................................................................................................................... ...36
Tri-State Area................................................................................................................. ....................................36
Old Lead Belt Ar ea ............................................................................................................. ...............................39

SUMMARY........................................................................................................................ ........................................41

LIST OF APPENDICES ............................................................................................................. ..............................42iv List of Figures

F IGURE 1: S TATEWIDE A CTIVE AND P ROPOSED M ONITORING S ITES .............................................................................8

F IGURE 2: G LOVER A IRBORNE L EAD C ONCENTRATIONS

, C ALENDAR Q UARTER A VERAGES (1987-2008)..................11

F IGURE 3: G LOVER M ONITORING S ITES ......................................................................................................................12

F IGURE 4: G LOVER A IRBORNE L EAD C ONCENTRATIONS

, 3-M ONTH A VERAGES (1997-2008) ....................................13

F IGURE 5: G LOVER A IRBORNE L EAD C ONCENTRATIONS

, 3-M ONTH R OLLING A VERAGES (2006-2008) .....................14

F IGURE 6: H ERCULANEUM F ACILITY F ENCE L INE AND M ONITORING S ITES ................................................................16

F IGURE 7: D ISCONTINUED H ERCULANEUM M ONITORING S ITES (1995-2005) .............................................................17

F IGURE 8: H ERCULANEUM A IRBORNE L EAD C ONCENTRATIONS

, 3-M ONTH R OLLING A VERAGES (1995-2008)..........18

F IGURE 9: I NTERPOLATION OF H ERCULANEUM M ONITORING D ATA ...........................................................................20

F IGURE 10 H ERCULANEUM M ODELED C ONCENTRATION V ALUES ...............................................................................22

F IGURE 11: H ERCULANEUM P OPULATION D ENSITY M AP ............................................................................................24

F IGURE 12: R ECOMMENDED H ERCULANEUM L EAD N ONATTAINMENT A REA ..............................................................26

F IGURE 13: V IBURNUM T REND F ACILITIES AND M ONITORING S ITES ..........................................................................28

F IGURE 14: B UICK A IRBORNE L EAD C ONCENTRATIONS

, 3-M ONTH R OLLING A VERAGES (1995-2008) ......................29

F IGURE 15: V IBURNUM T REND M ODELED C ONCENTRATION V ALUES OF N ORTHERN A REA .......................................30

F IGURE 16: V IBURNUM T REND M ODELED C ONCENTRATION V ALUES OF S OUTHERN A REA ........................................31

F IGURE 17: R ECOMMENDED B UICK L EAD N ONATTAINMENT A REA ............................................................................34

F IGURE 18: R ECOMMENDED T RI -S TATE U NCLASSIFIABLE A REA ................................................................................38

F IGURE 19: R ECOMMENDED O LD L EAD B ELT U NCLASSIFIABLE A REA .......................................................................40v List of Tables

T ABLE 1: D ISTANT S ITE AND H IGH S CHOOL M ONITORING D ATA U SED FOR I NTERPOLATION .....................................19

T ABLE 2: N ON -A MBIENT S AMPLING R ESULTS N EAR B RUSHY C REEK M INE ...............................................................27

T ABLE 3: M ODELING R ESULTS OF B UICK /V IBURNUM T REND I MPACTS ......................................................................32This page intentionally left blank.7 Introduction

On October 15, 2008, the U.S. Environmental Protection Agency (EPA) promulgated a revision to the National Ambient Air Quality Standa rd (NAAQS) for lead, which establishes 0.15 micrograms per cubic meter (μg/m 3 ) as the primary and secondary standard. Compliance with the 2008 standard is determined by calculating the monthly average of the lead concentrations at each monitor and averaging that value with the prior two months’ averages (e.g. three-month rolling average). When calculating the thre e-month average, concentrations below 0.155 μg/m 3 are rounded to 0.15 μg/m 3 and are still in compliance, while c oncentrations equal to or above 0.155 μg/m 3 are rounded to 0.16 μg/m 3 and represent a violation of the standard. It should be noted that compliance with the old standard of 1.5 μg/m 3 was based on a calendar quarterly

average.

As provided under Clean Air Act Subparagraph 1 07(d)(1)(A), the governor of each state is required to submit to the EPA a recommendation re garding the attainment status of all areas within that state. Each area (or portion ther eof) of the state shall be designated as:
nonattainment for areas that do not meet the NAA QS or contain sources that contribute to nonattainment in a nearby area that does not meet the NAAQS; attainment for areas that meet the NAAQS; or unclassifiable for areas that cannot be classified a ttainment or nonattainment based on available information. The purpose of this docum ent is to provide the technical bases for the
recommendations described in the Lead Designation and Boundary Recommendation

.

Lead is a pollutant primarily emitted from the combustion of fuel that contains lead, processing of recycled materials that contai n lead (e.g. batteries), and the conve rsion of lead ore into refined
lead. Since lead is a dense material that canno t be transported significan t distances like other air pollutants, the impact from lead sources is usually in close proximity to the source.

Since the 2008 NAAQS requires the use of the most recent three- year period for determination of compliance, the Missouri Department of Natu ral Resources (Departmen t) has evaluated the lead monitoring data from the years 2006-2008 to begin the recommendation process. Also, the EPA guidance for developing the lead designation recommendations included in the final lead NAAQS rule published in the November 12, 2008, Federal Register has been utilized in the development of these recommendations. In a ddition, the Department has published a lead monitoring network plan for implementation unde r the 2008 standard. The recommendations for sites under this network plan have been consid ered in the development of this document.

The current lead monitoring networ k in Missouri has several compone nts. There is one site in St. Louis County that monitors ex tremely low concentrations and was located to provide a site representative of the St . Louis metropolitan area. The remain ing sites in the current network are
located near three lead smelti ng facilities operated by the Doe Run Company. The Department and Doe Run operate several monitors near Herc ulaneum in Jefferson County, which is the only existing lead nonattainment area in the state. These monitors were sited for compliance
evaluations with the 1978 lead standard and most are located in close proximity to the primary lead smelter at Herculaneum. At this time, all these sites monitor violations of the 2008 standard. Doe Run operates two lead monitoring sites near the Buick sec ondary lead smelter in western Iron County that are in violation of the 2008 standard. Doe Run also operates two8 monitors at the inactive Glover smelting operation in eastern Iron County. Since the shutdown of the pyro-processing equipment at the Gl over facility, these sites have monitored concentrations below the 2008 NAAQS. In the past, many other monitoring lead monitoring
sites were located in Missouri. Some of thes e sites were temporary in nature and did not evaluate compliance with the 1978 NAAQS. Figur e 1 presents the current and newly proposed lead monitoring areas in Missouri.

Figure 1: Statewide Active and Proposed Monitoring Sites Note: Glover, Herculaneum, and the Viburnum trend have monitors in place and will be adding new samplers with the expansion of the lead monitoring network by January 1, 2010.9 In addition to the monitoring data review, th e Department has conducted several sets of dispersion modeling analyses for different lead sources in Miss ouri. One of these analyses evaluated the impact of a larg e combustion source of lead comp ared to the 2008 standard. The other analyses focused on Doe Run propertie s (Viburnum Trend lead mine/mills, Buick Resource Recycling, and Herculaneum). The Depart ment has determined that these stationary sources have the potential to contribute to viol ations of the 2008 standard. However, the extent
of this contribution to concentrations over the standard is lim ited due to the density of the lead particles and the corresponding lack of lead tr ansport over distance. This finding is based on multiple plans developed for control of lead at the Doe Run facilities and the monitoring data associated with those areas. Therefore, the Department is recomme nding areas considerably smaller than the presumptive county boundaries due to the proximity of each source’s
contribution to areas of violation. These re commendations are supported by the eight factors included in the final rulemaking for the 2008 lead NAAQS. These include:

1) emissions, 2) air quality concentrations, 3) population density and degree of urbanization including commercial development, 4) expected growth, 5) meteorology, 6) geography/topography, 7) jurisdictional boundaries, and 8) level of control of emission sources.

In the next few sections, the Department will provide rationale for the draft recommendation for
each area under consideration as unclassifiable or nonattainment.

Combustion Source Analysis

As part of the monitoring network plan develo pment, the Department evaluated several coal combustion sources of lead emissions. Many of these sources have very tall stacks and the emissions from many of these stacks are very small [less than 0.1 tons per year (TPY)]. Nonetheless, a dispersion modeli ng exercise was conducted to eval uate the potential for one of these sources to violate the new air quality stan dard. The source selected was a cement kiln in Jefferson County and was modeled at an emission rate over two TPY (nearly 40 times the actual emission rate). The surface meteorological da ta was obtained from nearby St. Louis (2001- 2005) and the upper air data was obtained from Lincol n, Illinois. The stack height of this source is 250 feet and the maximum monthly impact was 0.0045 μg/m 3 . Based on this finding, there is virtually no risk for a source of this type to contribute to an ambient viola tion of the 2008 NAAQS. Therefore, no additional analyses were conducted for coal combustion sources of lead in Missouri and no nonattainment designations w ill be recommended near any large coal-fired
combustion sources.10 Glover Smelter

The Doe Run Company owns a primary lead sm elting facility at Gl over, Missouri (DRG), located in eastern Iron County. Operation of the Glover primary smelter was suspended in December 2003 and it currently does not have an operating permit to use the pyro-processing equipment for lead smelting. The operation of this equipment led to the previous violations of the 1978 lead NAAQS. However, some lead ore has been stored in the past at the facility; zinc and copper concentrate from the mine/mill facilitie s is shipped by rail/truck from Glover; and other lead processing operati ons may begin in the future.

Existing Lead Monitoring Network and Past Monitoring Results

Airborne lead monitoring is done near the primar y lead smelter in Glover, Missouri by Doe Run:

 Post Office (two collocated samplers)

 Big Creek

The Department and Doe Run have conducted airbor ne lead monitoring at multiple sites near the Glover smelter in the past. Figure 2 shows monitoring results (calendar quarter average concentrations) from third quarter 1987 through third quarter 2008. Results are plotted on the time scale at the initial month for each quarter. In other words, results plotted at “January” are for the January-February-March quarter, etc. The Hogan, Dunn, and South sites were operated by the Department’s Environmental Services Pr ogram (ESP). The North, Post Office (two collocated), Big Creek, and Chloride sites were operated by Doe Run Company (abbreviated in the figure legend as DRG N, DRG PO(1 and 2), DR G BC, and DRG CL). Th e Glover facility is located in a narrow valley that trends from Nort h to South, and the monito ring sites, as listed in the legend, generally trend from north to south. Approximate locations of these monitoring sites are indicated in Figure 3. Results in Figure 2 clearly fall into thr ee periods with different levels
of lead concentrations: re sults through the end of 1996, results from 1997 through 2003, and results since 2003. In late 1996, under a revision to the State Implementation Plan (SIP) for the 1978 NAAQS, the sinter plant was enclosed and ventilated under negative pressure, and some other operations at the facility we re also enclosed. These controls installed at Glover resulted in emission reductions that correspond to the lower concentrations seen in the figure starting at January 1997. In December 2003, pyro-proces sing operations were discontinued. This shutdown resulted in no process emissions from th e sinter plant, blast furnace, or refinery operations and resulted in the significant reducti on in concentrations seen in the figure starting January 2004.11 0 5 10 15 20 25

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Hogan DRG N DRG PO DRG PO 2 DRG BC DRG CL Dunn South Plant Modifications Smelter Operation Suspended

Figure 2: Glover Airborne Lead Concentrations, Calendar Quarter Averages (1987-2008)12 Figure 3: Glover Monitoring Sites

Note : Figure 3 shows the past and present (DRG Post Office and DRG Big Creek) monitoring sites (yellow pins), and a recommended site (Glover Baptist Church, indicated by the red dot) near the Doe Run Glover facility.

Figure 4 illustrates the second and third periods with expand ed scales. Following the facility changes in late 1996, measured results indica ted compliance with the old lead NAAQS (1.5 μg/m 3 , calendar quarter average). The highest concentrations we re observed at the Big Creek site, south of the facility, and the nearby Dunn site . The Post Office site, located to the northeast of the facility, monitored slightly lower concen trations. The other sites (Hogan and DRG North to the north, and South and DR G Chloride to the south) m onitored lower concentrations.13 0.0 0.2 0.4 0.6 0.8 1.0 1.2 1.4

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Figure 4: Glover Airborne Lead Concen trations, 3-Month Averages (1997-2008)

Monitoring was discontinued at all but the DRG Post Office and Big Creek sites following the shutdown of pyro-processing operations. Figur e 5 illustrates three-month rolling average
airborne lead concentrations (calculated per the 2008 NAAQS) measured at these sites for January 2006 through September 2008. Results w ould be in compliance with the 2008 NAAQS, averaging about half the level of the standard.14 0.00 0.02 0.04 0.06 0.08 0.10 0.12 0.14 0.16Jan-06Feb-06Mar-06Apr-06May-06Jun-06Jul-06Aug-06Sep-06Oct-06Nov-06Dec-06Jan-07Feb-07Mar-07Apr-07May-07Jun-07Jul-07Aug-07Sep-07Oct-07Nov-07Dec-07Jan-08Feb-08Mar-08Apr-08May-08Jun-08Jul-08Aug-08Sep-08Oct-08Nov-08Dec-08ug/m3

Glover PO Glover PO col. Glover BC new standard
Figure 5: Glover Airborne Lead Concentrations, 3-Month Rolling Averages (2006-2008)

Conclusion

Based on the review of the monitoring data , the Department has found that the ongoing operations at the Glover site wi ll not cause or contribute to a violation of the NAAQS. Therefore, the area near Doe Run – Glover is recommended for designation as attainment under
the 2008 lead standard.15 Herculaneum Smelter

The Doe Run – Herculaneum lead smelter is the only operating primary lead smelter in the United States. The Department has developed multip le lead attainment plans as revisions to the Missouri SIP for the Herculaneum area, with the latest submitted to EPA in May 2007. A brief discussion of the 2001 and 2007 plan revisions is included here. The emission control strategy of the 2001 plan involved enclosur e of the main processes at the plant, and the installation of building ventilation systems. The ventilati on gases are filtered by high-efficiency baghouse systems prior to release to the atmosphere. The refinery building was encl osed and ventilated. All these projects were completed by July 31, 2 002. The 2007 plan revision required extensive control on material handling/delivery opera tions, haul roads, additional process enclosures/ventilation, reduction of process emissi ons within buildings already controlled under the 2001 plan, additional measures to reduce emissions from equipment failures, and a requirement for continual improvement that dir ects Doe Run to identify and implement “new” control requirements. These projects were comple ted in April 2008. No other stationary sources of lead are located within the area. Operati ons within and supporting the Herculaneum smelter are solely responsible for the concentrations in viol ation of the 2008 standard.

Existing Lead Monitoring Network and Past Monitoring Results

Airborne lead monitoring is done near the prim ary lead smelter in Herculaneum, Missouri both by the Department and by Doe Run. The Department operates samplers at:

 Bluff

 Broad Street (non-ambient; insi de the facility fence line)

 Circle Street

 Dunklin High School (two collocated samplers through August 2008)

 Main Street (two collocated samplers starting September 2008)

The Doe Run Company operates samplers at:

 Bluff

 Broad Street (see above)

 Church Street (two collocated samplers)

 Circle Street (discontinued at the end of September 2008)

 Dunklin High School (two collocated samplers through March 2008)

 Main Street/City Hall

 Mott Street

 Sherman Drive

 South Cross Street

 North Cross Street

The location of these sites is included in Figur e 6 with locations of previous sites in the
Herculaneum area. Each of the current sites has monitored violations of the 2008 standard in the recent past. There are also three historical site s that were discontinued in 2005 due to monitoring
concentrations well under the 1978 standard. The Dow site was located about 1.5 miles to the16 Figure 6: Herculaneum Facility Fence Line and Monitoring Sites Note: Doe Run’s Herculaneum facility is delineated by green dots.17 north-northwest of the Doe Run facility. The Golf Course site was located about 0.9 miles to the west of the facility. The Ursulin e site was located about 0.5 miles to the south of th e facility. In addition to these three sites, the Department operated a temporary site (2004-2005) on Thurwell Street to the west north-west of the facility (~1 mile away). Since the standard has been tightened, the three-month rolling average concentrat ions at these more dist ant sites have been in
violation of the 2008 standard in th e past as seen in Figure 7. Th e red line on Figure 7 represents
the 2008 standard.

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Figure 7: Discontinued Herculaneum Monitoring Sites (1995-2005) Note: The red line on Figure 7 represents the new lead standard.

Since these sites were discontinued in 2005, it is nearly impossible to estimate the current
monitored concentrations due to the process, emission, and operat ional changes at the facility resulting from the 2007 plan. To better unders tand the impact of the recent controls, the Department evaluated the three-month rolling av erage concentrations at the Broad St. and High School sites during 1995-2008. The da ta contained in Figure 8 from these sites provides a better understanding regarding the impact of both the 2001 and 2007 control measures at these nearby monitoring sites.18 Lead Concentration Data in Herculaneum, Missouri (3-month Rolling Average)

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Figure 8: Herculaneum Airborne Lead Concen trations, 3-Month Rolling Averages (1995-2008)

The monitoring results provided in Figure 8 illustra te the substantial benefits of the controls implemented in the previous control plans. However, based on the data in Figure 7, no conclusion can be made with respect to the atta inment status of the Go lf Course or the Dow monitoring sites. While the overall concentrations continue to decrease at the proximate sites
and this will also occur at the more distant site s, there is no definitive evidence that these sites will or will not comply with the standard under the current operating scenario at the Herculaneum facility. The far south site (Ursul ine) has not monitored a violation of the 2008 standard since before the 2001 control plan. This data provides evidence that the area near the
Ursuline site will not exceed the 2008 standard.

Per the EPA guidance on designation boundaries, ther e are three techniques th at can be used to
determine the extent of areas in violation of th e relevant air quality standard: (1) qualitative analysis, (2) spatial interpolation of air qua lity monitoring information, and (3) air quality simulation by dispersion modeling. The following sections discuss the last objective techniques for the boundary recommendation.

Spatial Interpolation of Air Quality Monitoring Information

As discussed above, the geographic extent of the current monitoring networ k is not sufficient to identify areas of violation of the 2008 standard. Therefore, the Department utilized the ArcMAP program from ESRI to interpolate all availa ble air quality monitoring data from two time19 periods. The first time frame is after the 2001 SI P controls were in place (July 2002) up to the 2007 SIP control implementation (April 2008). The second is post-2007 SIP control implementation. For these interpolations, th e maximum 3-month rolling average at each monitoring site during the tim e frame was utilized.

However, the lack of available monitoring data at the more distant sites does not provide sufficient geographic coverage to allow an interpolation for the second time frame. Therefore, the Department used two different sets of information for the more distant sites as part of the interpolation for the post-2007 SIP analyses. The fi rst set of data from the more distant sites
included the maximum concentrations measured after the 2001 SIP controls. This is
conservative since it does not incl ude any of the 2007 SIP emission reductions at the smelter.
The second data set was derived from the relationship between th e more distant sites and the High School monitor (the most distant of the si tes with continuous data). The ratio of the monitoring data from the distan t sites and the High School monitoring site was calculated for each 3-month rolling average since March 1995. Th ese concentration ratios were analyzed to find the maximum, minimum, and average along with the standard deviation of the dataset. The Department chose to use the average ratio plus one standard deviation to provide additional conservatism to the analysis. The resultant rati o for each monitoring site was then multiplied by the maximum 3-month rolling average concentra tion at the High School after April 2008 (0.386 micrograms per cubic meter -  g/m 3 ). Table 1 provides the concen tration data and the ratios
utilized for this calculation.

Table 1: Distant Site and High School Monitoring Data Used for Interpolation Dow - Pevely Golf Course Ursuline Thurwell
MAX RATIO 0.7342 1.1078 0.4503 1.4629
MIN RATIO 0.0524 0.0201 0.0185 0.2871
AVG RATIO 0.2268 0.2592 0.1290 0.8928
STDEV 0.1319 0.2102 0.0793 0.4370
AVG+1STD 0.3587 0.4693 0.2083 1.3298

Post-2007 High School
MAX 0.386 0.386 0.386 0.386 Ratio Adjusted 2007 Concentrations 0.139 0.181 0.081 0.514
Maximum 3-month Rolling (Post – 2001) 0.192 0.232 0.084 0.330

The resultant interpolations are displayed in Figure 9 and illust rate the reduction in
concentrations after the 2007 SIP controls using either distant si te data set when compared to the post-2001 control timeframe. The ov erall interpolation requires the use of “ghost sites” to complete the interpolation. These sites seen at the edges of the interpolated zone were assumed

to have a concentration of 0.005  g/m 3 . The results using the post-2007 SIP monitoring data illustrate a pattern of concentra tions over the standard outside the 1978 lead nonattainment area. However, there are still uncerta inties with the use of either post-2007 monitoring dataset to
ascertain the exact extent of the area that violates the 2008 l ead air quality standard.20Figure 9: Interpolation ofHerculaneum Monitoring Data21 Modeling Results and Analysis

Given the uncertainty with respect to the area in violation of the 2008 standard, the Department completed dispersion modeling using the atta inment demonstration modeling from the 2007 planning exercise. It is important to note that this modeling is not representative of the current production levels at the Herculaneum facility becau se it was designed to verify compliance with the quarterly 1.5 μg/m 3 standard at specified maximum produc tion levels. In addition, since the 2007 analysis was complete, the faci lity has redirected truck traffi c to the plant to shorten the route from Interstate 55. This change has been incorporated into the analyses. Further, the surface meteorological data utili zed was collected at the on-s ite meteorological station in Herculaneum and the upper air data was obtained fr om Lincoln, Illinois. The time period for the modeling was February 2007 to May 2009.

The Department utilized the current approved EP A modeling system (AERMOD) instead of the previous ISC-PRIME model used in the 2007 an alysis. The new modeling system did not undergo the same level of model performance revi ew as the previous modeling at Herculaneum and, therefore, has additional uncertainty. None theless, the modeling does reflect the current building and operational configurat ion at Herculaneum and provides the best available tool to investigate impacts from the facility on the surr ounding area. Figure 10 i llustrates the maximum three-month rolling average concen trations for this analysis with the green dots indicating areas that are predicted to meet the 2008 lead standard. The maximum c oncentrations near the site are
somewhat overestimated based on historical mon itoring data comparisons. However, the extent of the area predicted to violate the 2008 standard is within reason and has been included as a portion of the evaluation to determine the nonattainment boundaries for the area.

Example input files for Herculaneum and the Vi burnum Trend modeling anal yses are included in Appendices A and B, respectively.22 Figure 10 Herculaneum Modeled Concentration Values23 Analysis of Factors to Change Presumptive Boundary

1) Emissions for the Herculaneum area are limite d to operations within or that support the Doe Run primary smelter. The lead emissions from the smelter site were over 19 tons per year in 2008. 2) Based on the review of histor ic and current air quality monitoring data, the highest
concentrations of airborne lead occur very near the smelter s ite. Over the last 10 years,
concentrations over the 2008 standard have occurred at the geographic extent of the previous monitoring network. While concen trations in Herculaneum have decreased dramatically over the years, there are sti ll several sites that monitor over the 2008 standard. Dispersion modeling was conducted using the latest SIP input files and the results were used along with the relevant m onitoring data to charac terize areas near the smelter that may be in violation of the sta ndard. There is no monitoring or modeling data available that would suppor t the inclusion of Jefferson County as a whole in the nonattainment area. Further, there is evid ence that lead concen trations outside the sections immediately surrounding the smelte r are in compliance with the 2008 lead NAAQS. 3) The sections surrounding the smelter do not contain higher population density and many
of the areas are residential/li ght commercial and not industrial (Figure 11). There is no information related to this factor that pr ovides rationale to cha nge the concentrationbased recommendation. The Department believe s that all citizens should be protected from exposure to concentrations over the NAAQS. Further, there are no additional
sources of lead in the area that cont ribute to elevated lead concentrations. 4) Growth of the community has no impact on the area designated because the permitting of
lead sources in the state of Missouri is extremely rare wi thout other pollutants. Any major source permit issued in Jefferson C ounty would be a nonattainment permit and would require Lowest Achievable Emission Rate (LAER) technology and offsets. This is because Jefferson County is included in the St. Louis ozone and PM 2.5 nonattainment area. Further, any population growth does not bring additional lead sources into the area because lead emissions are primarily from st ationary sources. This is considerably
different than ozone or PM sources/areas. 5) The meteorological conditions associated w ith the Herculaneum ar ea typical of other areas along the Mississippi Rive r. Wind flows have a tendency to follow the river valley, but the predominant wind direction in Miss ouri includes a strong southerly component. Further, the modeling analysis conducted to help determin e the boundary includes on-site meteorological data from the Herculaneu m smelter and supports the recommendation. 6) There are no significant ge ographic or topographic feat ures that impact lead
concentrations in the Herculaneum area. 7) The only existing jurisdictional boundary related to air quality manage ment is the current
and recommended nonattainment area that includ es only the City of Herculaneum. The city boundaries for other comm unities in the area were noted as part of our review. 8) The only source of lead emissions in the area has been controlled dramatically as detailed in the regulatory history secti on above. These controls have reduced lead concentrations from over 10 μg/m 3 to less than 1 μg/m 3

.24 Figure 11: Herculaneum Population Density Map25 Conclusion

The Herculaneum area is in violation of the 2008 lead NAAQS. This area is being impacted by the Doe Run primary lead smelter. There are no other significant sources of lead that contribute to the violations in the surrounding areas. Theref ore, the Doe Run property has been included in
the recommended nonattainment area. The mode ling analysis illustrates an area over the standard that is much smaller than the pres umptive county boundary. The “distant” monitoring site data suggest the area of violation is limited to much less than two miles from the installation. Further, there is still a lack of current monitoring data at distan ce from the smelter and there is a great deal of uncertainty associated with th e EPA-recommended monitoring data interpolation and dispersion modeling techniques . This leads to the Departme nt’s recommendation of the area denoted in Figure 12 as the Herculaneum nona ttainment area. The recommendation for
nonattainment is identical to th e 1978 nonattainment boundary - the Herculaneum city limits. As seen in the figure, the Department is using the county-township-range-secti ons legal descriptions to define surrounding areas as unclassifiabl e with respect to the 2008 standard.

Given the local communities’ adverse comments to being nonattainment designation for the 2008 lead standard and the lack of any current mon itoring data to support a nonattainment designation at this time, the Department is recommending unclassifiable desi gnations for areas to the north and south of the Herculaneum city limits. Th e rationale for this recommendation includes the spatially interpolated monitoring data that exhi bits areas outside the city limits exceeding the 2008 standard. Also, the dispersion modeling data predicted a viola tion of the standard in areas outside the city limits. Any of these areas we re recommended as unclassif iable due to potential violations of the air quality standard. The Depa rtment has committed to re-examine these areas after 2010 (sampling begins at new Hercul aneum sites in January 2010) to propose a
recommendation of attainment or nonattainment for the areas recommended as unclassifiable.

It is important to note the size of the sections/land grants does not allow for the exact area of violation to be included, but doe s provide a justifiable extent of the violating area that may
include areas that do not violat e the standard (e.g. Ursuline).26 Figure 12: Recommended Herculaneum Lead Nonattainment Area Note: The green dotted line represents the Doe Run proper ty boundary and the stars indicate monitoring sites.27 Buick Smelter and the Viburnum Trend

The Buick Smelter, located near Boss and Bixby, Missouri in Iron County is a secondary smelter used for recycling lead primarily from lead-acid storage batteries. It is operated by the Doe Run Company’s Resource Recycling Division. This area has monitored atta inment of the 1.5 μg/m 3 standard for many years until the 4 th quarter of 2008. Since the facili ty has been in attainment of the standard, there have not been the same air qua lity improvement projects at the Buick facility when compared to the Herculaneum facility. Doe Run owns and operates several lead mine/mill
sites in the area around the Buick Smelter. Th ese sites are located along the Viburnum Trend and are shown, along with the Buick smelter, in Figure 12. The active mine/mill sites include (from the north to the south): Buick, Brushy Creek, Fletcher, and Sweetwater.

Existing Lead Monitoring Network and Past Monitoring Results

The monitoring results for the currently operating monitoring sites near the Buick smelting facility (north and south) demonstrate that the area is in violation of the 2008 lead standard. Also, data from two additional sites to the west a nd northwest of the smelter operated in the past also demonstrate violations. Figure 12 illustra tes the locations of these sites around the Buick facility. Figure 13 provides the three-month ro lling average concentration data from 1995-2008. The geographic extent of the network is not br oad and the average concentrations at the two
current sites are well above the 2008 standard. Therefore, based on the monitoring data only, it
is difficult to determine the area that is in viol ation of the standard. In addition to the ongoing compliance monitoring at Doe Run – Buick, Doe Run undertook a temporary sampling program in non-ambient air near the Brushy Creek mine /mill (about 0.3 miles fr om the active mine/mill site to the north/northeast). This sampling was conducted between April – July 2009 as is shown
in Table 2 and is illustrated in Figure 11. For completeness, a ll the relevant sampling data is included in Appendix C.

Table 2: Non-Ambient Sampling Re sults Near Brushy Creek Mine Month Average Concentration (μg/m 3 ) April 2009 0.14 May 2009 0.29

June 2009 0.22 August 2009 0.14

Since this data is non-ambient (i .e. public access is precluded to the site), it cannot be used to determine compliance with the 2008 lead standar d. However, this sampling gives the indication
that concentrations above the standard could occu r very near the mine/mill locations. Therefore, the Department determined that the areas near Brushy Creek and Fletcher mine/mill facilities should be designated unclassifiable until ambient sampling has been conducted.28 Figure 13: Viburnum Trend Facilities and Monitoring Sites29 0.000 0.500 1.000 1.500 2.000 2.500 3.000

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Figure 14: Buick Airborne Lead Concentrations, 3-Month Rolling Averages (1995-2008)

Modeling Results and Analysis

In addition to the monitoring data review, the Department conducted a dispersion modeling analysis for all the active sources in the area including the Buick smelter and all the mine/mill operations. As with the Herculan eum area, the results indicate potential violations near the large stationary sources. However, in the case of the Viburnum Tre nd, several sources are located along the trend within a few mile s of each other. The modeling analyses demonstrate that each operational source has limited influence on the recepto rs near the other operational sources. This is true except for the Buick smelter and Buick mine/mill, which have considerable overlap between predicted violations near the property boundaries for each site.

The overall modeling exercise ut ilized the latest emissions fo r each group of sources including “stack” testing conducted at one of the mine vent shafts to better characte rize the emissions from
these sources. The Buick smelter emissions were from the latest approved permit action (not the latest requested permit from Doe Run). The m odeling utilized surface meteorological data from
Fort Leonard Wood for 2004-2007. The results are depicted in Figures 14 and 15 with the source locations for each facility and potential area of ambient violations highlighted. As with the Herculaneum analysis, the AERMOD modeling system was used without the benefit of a model performance evaluation. The areas of pr edicted ambient violations are limited very closely to the property boundary for se veral of the sour ces along the trend. μg/m 330 Figure 15: Viburnum Trend Modeled Con centration Values of Northern Area Note: Doe Run facilities outlined in black are, from north to south, Buick Smelter, Buick Mine/Mill, and Brushy
Creek Mine/Mill31 Figure 16: Viburnum Trend Modeled Concentration Values of Southern Area Note: Doe Run facilities outlined in black are, from north to south, West Fork and Fletcher (outlined as one property boundary), and Sweetwater32 The overall analysis was supplemented with a facility-specific eval uation using the same receptor network as detailed above. This evalua tion was utilized to understand the impact from each facility on other violating receptors insi de the Viburnum Trend. Specifically, all the receptors predicted over the standard near the Buick smelter and mine/mill showed over a 99 percent impact from sources at the Buick smelter and mine/mill for all violating 3-month rolling averages (first 15 receptors in Table 3). The re maining receptors with predicted concentrations
over the standard near the Fletcher mine/mill faci lity (last 2 receptors in Table 3) illustrate a maximum of 3 percent from the other sources and the remainder from the Fletcher sources (over 96 percent). This data indicates that the Buic k smelter and mine/mill facility do not contribute significantly to the exceeding values around the ot her mine/mill complexes. Also, the mine/mill complexes (other than Buick) do not contribut e to the predicted exceedance values of the
recommended nonattainment area.

Table 3: Modeling Results of Buick/Viburnum Trend Impacts

Buick Buick Fletcher Fletcher Brushy Brushy Sweetwater Sweetwater Overall

UTM-X UTM-Y Min. Max. Min. Max. Min. Max. Min. Max. Max
663500 4167000 99.2% 99.6% 0.1% 0.2% 0.3% 0.5% 0.0% 0.1% 0.183

664000 4166500 99.1% 99.4% 0.2% 0.3% 0.4% 0.6% 0.0% 0.0% 0.178

664000 4167000 99.5% 99.8% 0.1% 0.1% 0.1% 0.3% 0.0% 0.0% 0.311

664500 4164000 99.3% 99.5% 0.1% 0.2% 0.3% 0.5% 0.0% 0.0% 0.174

664500 4166000 99.4% 99.6% 0.1% 0.2% 0.2% 0.3% 0.0% 0.0% 0.174

664500 4166500 99.5% 99.9% 0.0% 0.1% 0.1% 0.4% 0.0% 0.0% 0.335

665000 4164000 99.2% 99.7% 0.1% 0.1% 0.2% 0.6% 0.0% 0.0% 0.309

665000 4164500 99.6% 99.6% 0.1% 0.1% 0.3% 0.3% 0.0% 0.0% 0.215

665500 4166000 99.7% 99.7% 0.1% 0.1% 0.2% 0.2% 0.0% 0.0% 0.166

665500 4166500 99.4% 99.9% 0.0% 0.2% 0.1% 0.4% 0.0% 0.0% 0.309

665500 4167000 99.6% 99.9% 0.0% 0.2% 0.1% 0.3% 0.0% 0.0% 0.446

665500 4168500 99.5% 99.5% 0.1% 0.1% 0.3% 0.4% 0.0% 0.0% 0.165

666000 4164500 99.2% 99.2% 0.2% 0.2% 0.5% 0.5% 0.0% 0.0% 0.156

666000 4166500 99.7% 99.7% 0.1% 0.1% 0.2% 0.2% 0.0% 0.0% 0.183

666000 4167000 99.7% 99.7% 0.1% 0.1% 0.2% 0.2% 0.0% 0.0% 0.187

667500 4148500 0.5% 1.6% 97.6% 99.1% 0.2% 0.7% 0.0% 0.2% 0.518

667500 4149000 2.0% 2.5% 96.4% 97.1% 0.7% 0.9% 0.2% 0.3% 0.181

Analysis of Factors to Change Presumptive Boundary

1) Emissions in the Viburnum Trend are dominated by the Doe Run secondary smelter. The
lead emissions from the smelter site were nearly 13 tons per year in 2008. The Buick mine/mill has the next highest emissions with 3 tons per year in 2008. The Fletcher and Brushy Creek mines emitted 2.9 and 1.9 tons per year respectively. The Sweetwater mine only emitted 0.6 tons per year in 2008. 2) Based on the review of histor ic and current air quality monitoring data, the highest
concentrations of airborne l ead occur very near the smelter site. The network around the Buick smelter is not as geographically divers e as the Herculaneum area. Currently, there
is one site located no rth of the smelter and one site in between the smelter and the Buick33 mine. Both the current sites show concentratio ns well above the standa rd in the last few years. Dispersion modeling was conducted us ing the latest permit input files for the smelter and updated emissions from the mine/mill sources. The results were used along with the relevant monitoring data to characte rize areas that may be in violation of the 2008 standard along the Viburnum Trend. 3) The population density of the Trend is very small due to the very rural nature of the area. Further, there is no information related to this factor that provides rationale to change the concentration-based recommendation. The Depa rtment believes that all citizens should be protected from exposure to co ncentrations over the NAAQS. 4) Growth rates within the area are very sm all and are primarily related to production
increases/decreases at the Doe Run facilities . Further, any popul ation growth does not bring additional lead sources into the area because lead emissions are primarily from stationary sources. 5) The meteorological conditions a ssociated with the Viburnum Trend are typical of other areas in Missouri. The predominant wi nd direction in Missouri includes a strong southerly component. Further, the modeling analyses conduc ted to help determine the boundary includes meteorological data from nearby Fort Leonard Wood supports the
recommendation. 6) There are no significant ge ographic or topographic feat ures that impact lead
concentrations in the Viburnum Trend area. 7) The only existing jurisdictional boundary related to air quality manage ment is the current
maintenance area that includes Dent Townsh ip in Iron County. These boundaries were noted as part of our review, but the primary rationale for inclusion of sections in the boundary was related to concentrations over the standard and the inclus ion of sources that contribute to those pot ential violations. 8) All the sources of lead in the Trend have been issued constr uction and/or operating permits. The Doe Run Buick smelter has been controlled in the past to come into compliance with the 1978 NAAQS.

Conclusion

The Buick area is in violation of the 2008 lead NAAQS. The monitored vi olating area is being impacted by the Doe Run secondary lead sm elter and the nearby Doe Run Buick mine/mill operation. Therefore, these two Doe Run propert ies have been included in the recommended
nonattainment area. The monitored violations of the standard are inside sec tions that are part of the Doe Run property. The modeling analysis illu strates an area over the standard that includes small portions of three counties (Iron, Reynolds, and Dent) that are much smaller than the presumptive county boundary. The previous lead maintenance area includes Dent Township in Iron County. In the same manner as Herculaneu m, the Department is recommending that the sections containing the viola ting monitor and contributing so urces be included in the nonattainment area. These sections are depicted in Figure 16. Due to the high levels of lead
concentrations at the monitors , the Department is including a buffer zone around the monitoring sites and Doe Run properties that includes sec tions with no previous monitoring data, but predicted violations in the di spersion modeling exercise.34 Figure 17: Recommended Buic k Lead Nonattainment Area35 Further, the Department is recommending two of the nearby Doe Run oper ational sites (Brushy Creek and Fletcher mine/mill) as unclassifiable due to the temporary monitoring data at the Brushy Creek site and the potenti al violations predicted by the modeling exercises. However, the individual culpability analyses do not suppor t inclusion of these sections in the recommended
Buick nonattainment area. The basis for this find ing is the impact from the Buick sources on the predicted violations and the im pact of these more distant sources on the Buick predicted violations. Since monitoring data will be availa ble near these two operational sites in the near future, an indication of the attainment stat us will be made upon review of that data.

In addition, the Department’s dispersion modeli ng analyses for each area show less than one percent contribution to violating monitoring locations from the more distant mine/mill sources in the Viburnum trend. Also, the impact of the Buick sources on the more distant mine/mill predicted violations is 2.5 percen t of the standard with the remai nder originating from the source in close proximity to the violation.36 Other Areas with Lead Sources

Secondary Smelter

Exide Technologies

In addition to the Doe Run facilitie s, another lead source in the st ate is a facility in Holt County owned by Exide Technologies (for merly known as Schuylkill Metals) located in Canon Hollow. This facility is a secondary smelter for recycling of lead, primarily from lead acid storage batteries. The Department examined data from an air monitoring sampler that was located near the facility from 1992 to 2000. The facility violated the 1.5 μg/m 3 standard in the third quarter
of 1994 and concentrations that were a significant fraction of the sta ndard in other quarters. That monitoring site was subseque ntly acquired by Exide Technologies, so it was no longer considered ambient. Department staff evaluate d current emission estimates for the facility and visited the facility in January 2009. The facility has added substantial emission controls since the time of the monitoring described above, and lead emissions are estimated to be about 0.01 tons per year. Source test re sults confirm that emissions ha ve been reduced, indicating a 96 percent reduction since monitori ng was discontinued. Therefore, it is extremely unlikely that
ambient lead concentrations exceed the 2008 NAAQS at this location and the area is being
recommended as attainment/unclassifiable.

Inactive Lead Mine Areas

Two specific lead mine tailings cleanup areas in Missouri that were gi ven consideration as potential lead problem areas. The first is an ar ea near Joplin, Missouri (known as the Tri-State Area). Lead and zinc were mined in the tri- state area (southwestern Missouri, southeastern Kansas, and northeastern Oklahom a) between about 1830 and the 1970s . Chat and tailings from the mining and milling have remained in the area following cessation of mining activity.

Tri-State Area

Within Missouri, mining in the Tri-State Area occurred within Jasper and Newton Counties. Eleven separate areas within Ja sper and Newton Counties were li sted on the National Priorities or Superfund list in 1990. These areas are know n collectively as the Oronogo-Duenweg Mining Belt Superfund Site, also sometimes called th e Jasper County Site. Figure 17 shows the
locations of these areas. Remediation activities are categorized under five operable units (OU). Remediation activities within OU 2 and 3, Resi dential Yard Soils, in cluded cleanup activities completed in 2002 and institutional controls es tablished in 2005. Activities within OU 4, Groundwater, were completed in 2004 with the in stallation of public water supply systems. OU 5 relates to the Spring River basi n and is currently under study. OU 1 is mine and mill waste. Remediation activities within OU 1 have recently begun and will continue for several years. The
remediation includes removal of contaminated material with contaminant concentrations above established thresholds and dispos ing of it in mining pits and in repository areas that will be capped and vegetated.37 Some very limited airborne lead measurements were collected in this area and largely do not suggest violations of the 2008 lead NAAQS (see Missouri Lead Monitoring Network Plan ). However, these measurements were not made during remediation or earthmoving activity, but primarily measure windblown dust in the area ne ar the sampler. Therefore, in the lead monitoring plan, the Department has recommended airborne lead monitoring at a location within ambient air as close as practicable to remedi ation activity such as earthmoving and generally downwind of the activity. At this time, the Department has no strong indication of concentrations over the 2008 standard, but will designate the areas c ontaining each of the remediation sites with the Oronogo-Duenweg Mining Belt Superfund Site as unclassifiable. The
recommended Tri-State unclassifiable area includ es Duval, Galena, Jackson, Jasper, Joplin, Marion, Mineral, Preston, and Twin Groves To wnships in Jasper County and Shoal Creek Township in Newton County.38 Figure 18: Recommended Tri-St ate Unclassifiable Area39 Old Lead Belt Area

The second area is the Old Lead Belt area in St . Francois County. Even though mining has been
discontinued in the old lead belt area, chat and tailings disposal areas remain from the mining activity. The larger chat and/or tailings disposal areas include : Bonne Terre, Desloge or Big River, National, Elvins or Rivermines, Leadw ood, and Federal, all in St. Francois County. Locations of these areas are shown on Figure 18. Remediation activities are currently underway at the National chat pile in Park Hills, Missouri.

St. Joe State Park is also located in the old lead belt area near Park Hills, Missouri. The area of the park was donated to the state by the St. Joe Mi nerals Corporation in 19 76 after lead mining in the old lead belt area ceased. The park is over 8,000 acres and in cludes approximately 2,000
acres that are set aside for off-road vehicle (ORV) riding. Of these 2,000 acres, 800 acres contain crushed dolomite remaining from past milling of lead ore (tailings). This area within the park is known as the Federal tailings pile. Le ad emissions from areas in the park have never been quantified in emissions inventories. Ho wever, windblown dust and/or dust raised by ORV activities are a potential source of airb orne lead in and near the park.

Some limited airborne lead measurements were co llected in this area and suggest some limited
concern that violations of the 2008 lead NAAQS could be occurring in these areas (see Missouri Lead Monitoring Network Plan ). Therefore, in the lead monitoring plan, the Department has recommended airborne lead monitoring at a locati on within St. Joe State Park and in ambient air as close as practicable to remediation activity at the National chat pile. At this time, the Department has no strong indication of concentr ations over the 2008 standa rd, but will designate the areas containing each of the re mediation sites within the Old Lead Belt as unclassifiable.
The recommended Old Lead Belt unclassifiable ar ea includes Perry, Randolph, and St. Francois Townships in St. Francois County.40 Figure 19: Recommended Old Lead Belt Unclassifiable Area41 Summary

The Department is recommending for nonattai nment designation areas around the active Doe Run smelting operations at Herculaneum and Buick, Missouri. This designation also includes the Buick mine/mill property to the south of the smelter. These recommended areas are smaller than the presumptive county boundaries proposed by EPA due to the very localized nature of the impacts from these large lead sources. The impact of these sources is isol ated to ambient air in close proximity to these operations. The inclusi on of other areas not im pacted by these sources
would not assist these areas in attaining the 2008 lead NAAQS.

Around the Herculaneum and Buick smelter locati ons, there are areas w ith unknown air quality at this time. These areas have been designated unclassifiable due to pr edicted concentrations above the standard with no supporting monitori ng data and/or non-ambient sampling that
identifies levels near the standard near other le ad sources in the area. Also, the Department is recommending for unclassifiable designation areas th at are near remediation sites for lead mine tailings cleanup. Some sites within the Oronogo- Duenweg Mining Belt in Jasper County (also known as the Tri-State Area) and the Old Lead Belt in St. Francois County) have been recommended for the unclassifiable designation.42 List of Appendices

Appendix A Herculaneum Modeling Input Files

Appendix B Viburnum Modeling Input Files

Appendix C Brushy Creek Mine Sampling Data

Appendix D Herculaneum Monitoring Data

Appendix E Comments Received on the Proposed Lead Boundary Recommendation

Appendix F Responses to Comments on the Prop osed Lead Boundary Recommendation