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) 751-4817 
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iii 

Table of Contents 

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

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

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

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

GLOVER SMELTER ...............................................................................................................................................10

EXISTING LEAD MONITORING NETWORK AND PAST MONITORING RESULTS ..........................................................10

CONCLUSION ...........................................................................................................................................................14

HERCULANEUM SMELTER.................................................................................................................................15

EXISTING LEAD MONITORING NETWORK AND PAST MONITORING RESULTS ..........................................................15

SPATIAL INTERPOLATION OF AIR QUALITY MONITORING INFORMATION ................................................................18

MODELING RESULTS AND ANALYSIS.......................................................................................................................21

ANALYSIS OF FACTORS TO CHANGE PRESUMPTIVE BOUNDARY..............................................................................23

CONCLUSION ...........................................................................................................................................................25

BUICK SMELTER AND THE VIBURNUM TREND ..........................................................................................27

EXISTING LEAD MONITORING NETWORK AND PAST MONITORING RESULTS ..........................................................27

MODELING RESULTS AND ANALYSIS.......................................................................................................................29

ANALYSIS OF FACTORS TO CHANGE PRESUMPTIVE BOUNDARY..............................................................................32

CONCLUSION ...........................................................................................................................................................33

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

SECONDARY SMELTER.............................................................................................................................................36

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

INACTIVE LEAD MINE AREAS..................................................................................................................................36

Tri-State Area.....................................................................................................................................................36

Old Lead Belt Area ............................................................................................................................................39

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

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

FIGURE 1: STATEWIDE ACTIVE AND PROPOSED MONITORING SITES .............................................................................8

FIGURE 2: GLOVER AIRBORNE LEAD CONCENTRATIONS, CALENDAR QUARTER AVERAGES (1987-2008)..................11

FIGURE 3: GLOVER MONITORING SITES ......................................................................................................................12

FIGURE 4: GLOVER AIRBORNE LEAD CONCENTRATIONS, 3-MONTH AVERAGES (1997-2008) ....................................13

FIGURE 5: GLOVER AIRBORNE LEAD CONCENTRATIONS, 3-MONTH ROLLING AVERAGES (2006-2008) .....................14

FIGURE 6: HERCULANEUM FACILITY FENCE LINE AND MONITORING SITES................................................................16

FIGURE 7: DISCONTINUED HERCULANEUM MONITORING SITES (1995-2005) .............................................................17

FIGURE 8: HERCULANEUM AIRBORNE LEAD CONCENTRATIONS, 3-MONTH ROLLING AVERAGES (1995-2008)..........18

FIGURE 9: INTERPOLATION OF HERCULANEUM MONITORING DATA ...........................................................................20

FIGURE 10 HERCULANEUM MODELED CONCENTRATION VALUES ...............................................................................22

FIGURE 11: HERCULANEUM POPULATION DENSITY MAP ............................................................................................24

FIGURE 12: RECOMMENDED HERCULANEUM LEAD NONATTAINMENT AREA..............................................................26

FIGURE 13: VIBURNUM TREND FACILITIES AND MONITORING SITES ..........................................................................28

FIGURE 14: BUICK AIRBORNE LEAD CONCENTRATIONS, 3-MONTH ROLLING AVERAGES (1995-2008) ......................29

FIGURE 15: VIBURNUM TREND MODELED CONCENTRATION VALUES OF NORTHERN AREA .......................................30

FIGURE 16: VIBURNUM TREND MODELED CONCENTRATION VALUES OF SOUTHERN AREA........................................31

FIGURE 17: RECOMMENDED BUICK LEAD NONATTAINMENT AREA ............................................................................34

FIGURE 18: RECOMMENDED TRI-STATE UNCLASSIFIABLE AREA ................................................................................38

FIGURE 19: RECOMMENDED OLD LEAD BELT UNCLASSIFIABLE AREA .......................................................................40
v 

List of Tables 

TABLE 1: DISTANT SITE AND HIGH SCHOOL MONITORING DATA USED FOR INTERPOLATION.....................................19

TABLE 2: NON-AMBIENT SAMPLING RESULTS NEAR BRUSHY CREEK MINE...............................................................27

TABLE 3: MODELING RESULTS OF BUICK/VIBURNUM TREND IMPACTS ......................................................................32
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7 

Introduction 

On October 15, 2008, the U.S. Environmental Protection Agency (EPA) promulgated a revision 

to the National Ambient Air Quality Standard (NAAQS) for lead, which establishes 0.15 

micrograms per cubic meter (μg/m3) 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 three-month average, concentrations below 0.155 μg/m3 

are rounded to 0.15 μg/m3 and are still in compliance, while concentrations equal to or above 

0.155 μg/m3

 are rounded to 0.16 μg/m3 and represent a violation of the standard. It should be 

noted that compliance with the old standard of 1.5 μg/m3 was based on a calendar quarterly 

average. 

As provided under Clean Air Act Subparagraph 107(d)(1)(A), the governor of each state is 

required to submit to the EPA a recommendation regarding the attainment status of all areas 

within that state. Each area (or portion thereof) of the state shall be designated as: 

nonattainment for areas that do not meet the NAAQS 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 attainment or nonattainment based 

on available information. The purpose of this document 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 contain lead (e.g. batteries), and the conversion of lead ore into refined 

lead. Since lead is a dense material that cannot be transported significant 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 Natural Resources (Department) 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 addition, the Department has published a lead 

monitoring network plan for implementation under the 2008 standard. The recommendations for 

sites under this network plan have been considered in the development of this document. 

The current lead monitoring network in Missouri has several components. There is one site in 

St. Louis County that monitors extremely low concentrations and was located to provide a site 

representative of the St. Louis metropolitan area. The remaining sites in the current network are 

located near three lead smelting facilities operated by the Doe Run Company. The Department 

and Doe Run operate several monitors near Herculaneum 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 secondary lead smelter in 

western Iron County that are in violation of the 2008 standard. Doe Run also operates two 
8 

monitors at the inactive Glover smelting operation in eastern Iron County. Since the shutdown 

of the pyro-processing equipment at the Glover 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 these sites were temporary in nature and did not 

evaluate compliance with the 1978 NAAQS. Figure 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, the Department has conducted several sets of 

dispersion modeling analyses for different lead sources in Missouri. One of these analyses 

evaluated the impact of a large combustion source of lead compared to the 2008 standard. The 

other analyses focused on Doe Run properties (Viburnum Trend lead mine/mills, Buick 

Resource Recycling, and Herculaneum). The Department has determined that these stationary 

sources have the potential to contribute to violations of the 2008 standard. However, the extent 

of this contribution to concentrations over the standard is limited due to the density of the lead 

particles and the corresponding lack of lead transport 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 recommending areas considerably 

smaller than the presumptive county boundaries due to the proximity of each source’s 

contribution to areas of violation. These recommendations 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 development, 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 modeling exercise was conducted to evaluate the potential for one of 

these sources to violate the new air quality standard. 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 data was obtained from nearby St. Louis (2001-

2005) and the upper air data was obtained from Lincoln, Illinois. The stack height of this source 

is 250 feet and the maximum monthly impact was 0.0045 μg/m3

. Based on this finding, there is 

virtually no risk for a source of this type to contribute to an ambient violation of the 2008 

NAAQS. Therefore, no additional analyses were conducted for coal combustion sources of lead 

in Missouri and no nonattainment designations will be recommended near any large coal-fired 

combustion sources. 
10 

Glover Smelter 

The Doe Run Company owns a primary lead smelting facility at Glover, 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 facilities is shipped by rail/truck from Glover; and 

other lead processing operations may begin in the future. 

Existing Lead Monitoring Network and Past Monitoring Results

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

 Post Office (two collocated samplers) 

 Big Creek 

The Department and Doe Run have conducted airborne 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 Program (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), DRG BC, and DRG CL). The Glover facility is 

located in a narrow valley that trends from North to South, and the monitoring 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 three periods with different levels 

of lead concentrations: results 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 were 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-processing operations were discontinued. This 

shutdown resulted in no process emissions from the sinter plant, blast furnace, or refinery 

operations and resulted in the significant reduction in concentrations seen in the figure starting 

January 2004. 
11 

0

5

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ug/m3

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 expanded scales. Following the facility 

changes in late 1996, measured results indicated compliance with the old lead NAAQS (1.5 

μg/m3

, calendar quarter average). The highest concentrations were 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 concentrations. The other sites (Hogan and DRG North 

to the north, and South and DRG Chloride to the south) monitored lower concentrations. 
13 

0.0

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ug/m3

Hogan DRG N DRG PO DRG PO 2 DRG BC DRG CL Dunn South

Figure 4: Glover Airborne Lead Concentrations, 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. Figure 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 would be in compliance with the 2008 NAAQS, 

averaging about half the level of the standard. 
14 

0.00

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ug/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 will 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 multiple 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 enclosure of the main processes at the plant, and the installation of 

building ventilation systems. The ventilation gases are filtered by high-efficiency baghouse 

systems prior to release to the atmosphere. The refinery building was enclosed and ventilated. 

All these projects were completed by July 31, 2002. The 2007 plan revision required extensive 

control on material handling/delivery operations, haul roads, additional process 

enclosures/ventilation, reduction of process emissions within buildings already controlled under 

the 2001 plan, additional measures to reduce emissions from equipment failures, and a 

requirement for continual improvement that directs Doe Run to identify and implement “new” 

control requirements. These projects were completed in April 2008. No other stationary sources 

of lead are located within the area. Operations within and supporting the Herculaneum smelter 

are solely responsible for the concentrations in violation of the 2008 standard. 

Existing Lead Monitoring Network and Past Monitoring Results

Airborne lead monitoring is done near the primary lead smelter in Herculaneum, Missouri both 

by the Department and by Doe Run. The Department operates samplers at: 

 Bluff 

 Broad Street (non-ambient; inside 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 Figure 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 sites that were discontinued in 2005 due to monitoring 

concentrations well under the 1978 standard. The Dow site was located about 1.5 miles to the 
16 

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 Ursuline site was located about 0.5 miles to the south of the 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 concentrations at these more distant sites have been in 

violation of the 2008 standard in the past as seen in Figure 7. The red line on Figure 7 represents 

the 2008 standard. 

0.000

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Dow Golf Course Ursuline Thurwell

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 operational changes at the facility 

resulting from the 2007 plan. To better understand the impact of the recent controls, the 

Department evaluated the three-month rolling average concentrations at the Broad St. and High 

School sites during 1995-2008. The data 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)

0.000

2.000

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End Month

ug/m^3

Bluff

High School

Broad St.

2008 Standard

2001 SIP Controls 

Completed

2007 SIP Controls 

Completed

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

The monitoring results provided in Figure 8 illustrate 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 attainment status of the Golf 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 sites, 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 (Ursuline) 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, there are three techniques that can be used to 

determine the extent of areas in violation of the relevant air quality standard: (1) qualitative 

analysis, (2) spatial interpolation of air quality 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 network is not sufficient to 

identify areas of violation of the 2008 standard. Therefore, the Department utilized the ArcMAP 

program from ESRI to interpolate all available air quality monitoring data from two time 
19 

periods. The first time frame is after the 2001 SIP 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, the maximum 3-month rolling average at each 

monitoring site during the time 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 first 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 include any of the 2007 SIP emission reductions at the smelter. 

The second data set was derived from the relationship between the more distant sites and the 

High School monitor (the most distant of the sites with continuous data). The ratio of the 

monitoring data from the distant sites and the High School monitoring site was calculated for 

each 3-month rolling average since March 1995. These 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 ratio for each monitoring site was then multiplied by 

the maximum 3-month rolling average concentration at the High School after April 2008 (0.386 

micrograms per cubic meter - g/m3

). Table 1 provides the concentration 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 illustrate the reduction in 

concentrations after the 2007 SIP controls using either distant site data set when compared to the 

post-2001 control timeframe. The overall 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/m3

. The results using the post-2007 SIP monitoring data 

illustrate a pattern of concentrations over the standard outside the 1978 lead nonattainment area. 

However, there are still uncertainties with the use of either post-2007 monitoring dataset to 

ascertain the exact extent of the area that violates the 2008 lead air quality standard. 
20 

Figure 9: Interpolation of Herculaneum Monitoring Data 
21 

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 attainment 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 because it was designed to verify compliance with 

the quarterly 1.5 μg/m3

 standard at specified maximum production levels. In addition, since the 

2007 analysis was complete, the facility has redirected truck traffic to the plant to shorten the 

route from Interstate 55. This change has been incorporated into the analyses. Further, the 

surface meteorological data utilized was collected at the on-site meteorological station in 

Herculaneum and the upper air data was obtained from Lincoln, Illinois. The time period for the 

modeling was February 2007 to May 2009. 

The Department utilized the current approved EPA modeling system (AERMOD) instead of the 

previous ISC-PRIME model used in the 2007 analysis. The new modeling system did not 

undergo the same level of model performance review as the previous modeling at Herculaneum 

and, therefore, has additional uncertainty. Nonetheless, the modeling does reflect the current 

building and operational configuration at Herculaneum and provides the best available tool to 

investigate impacts from the facility on the surrounding area. Figure 10 illustrates the maximum 

three-month rolling average concentrations for this analysis with the green dots indicating areas 

that are predicted to meet the 2008 lead standard. The maximum concentrations near the site are 

somewhat overestimated based on historical monitoring 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 Viburnum Trend modeling analyses are included in 

Appendices A and B, respectively. 
22 

Figure 10 Herculaneum Modeled Concentration Values 
23 

Analysis of Factors to Change Presumptive Boundary

1) Emissions for the Herculaneum area are limited 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 historic and current air quality monitoring data, the highest 

concentrations of airborne lead occur very near the smelter site. Over the last 10 years, 

concentrations over the 2008 standard have occurred at the geographic extent of the 

previous monitoring network. While concentrations in Herculaneum have decreased 

dramatically over the years, there are still 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 monitoring data to characterize areas near the 

smelter that may be in violation of the standard. There is no monitoring or modeling data 

available that would support the inclusion of Jefferson County as a whole in the 

nonattainment area. Further, there is evidence that lead concentrations outside the 

sections immediately surrounding the smelter 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/light commercial and not industrial (Figure 11). There is no 

information related to this factor that provides rationale to change the concentrationbased recommendation. The Department believes 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 contribute 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 without other pollutants. Any 

major source permit issued in Jefferson County 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 PM2.5 nonattainment 

area. Further, any population growth does not bring additional lead sources into the area 

because lead emissions are primarily from stationary sources. This is considerably 

different than ozone or PM sources/areas. 

5) The meteorological conditions associated with the Herculaneum area typical of other 

areas along the Mississippi River. Wind flows have a tendency to follow the river valley, 

but the predominant wind direction in Missouri includes a strong southerly component. 

Further, the modeling analysis conducted to help determine the boundary includes on-site 

meteorological data from the Herculaneum smelter and supports the recommendation. 

6) There are no significant geographic or topographic features that impact lead 

concentrations in the Herculaneum area. 

7) The only existing jurisdictional boundary related to air quality management is the current 

and recommended nonattainment area that includes only the City of Herculaneum. The 

city boundaries for other communities 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 section above. These controls have reduced lead concentrations 

from over 10 μg/m3

 to less than 1 μg/m3. 
24 

Figure 11: Herculaneum Population Density Map 
25 

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. Therefore, the Doe Run property has been included in 

the recommended nonattainment area. The modeling analysis illustrates an area over the 

standard that is much smaller than the presumptive 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 distance from the smelter and there is a 

great deal of uncertainty associated with the EPA-recommended monitoring data interpolation 

and dispersion modeling techniques. This leads to the Department’s recommendation of the area 

denoted in Figure 12 as the Herculaneum nonattainment area. The recommendation for 

nonattainment is identical to the 1978 nonattainment boundary - the Herculaneum city limits. As 

seen in the figure, the Department is using the county-township-range-sections legal descriptions 

to define surrounding areas as unclassifiable 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 monitoring data to support a nonattainment designation 

at this time, the Department is recommending unclassifiable designations for areas to the north 

and south of the Herculaneum city limits. The rationale for this recommendation includes the 

spatially interpolated monitoring data that exhibits areas outside the city limits exceeding the 

2008 standard. Also, the dispersion modeling data predicted a violation of the standard in areas 

outside the city limits. Any of these areas were recommended as unclassifiable due to potential 

violations of the air quality standard. The Department has committed to re-examine these areas 

after 2010 (sampling begins at new Herculaneum 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 does provide a justifiable extent of the violating area that may 

include areas that do not violate the standard (e.g. Ursuline). 
26 

Figure 12: Recommended Herculaneum Lead Nonattainment Area 

Note: The green dotted line represents the Doe Run property 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 attainment of the 1.5 μg/m3

standard for many years until the 4th quarter of 2008. Since the facility has been in attainment of 

the standard, there have not been the same air quality 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. These 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 and northwest of the smelter operated in the past 

also demonstrate violations. Figure 12 illustrates the locations of these sites around the Buick 

facility. Figure 13 provides the three-month rolling average concentration data from 1995-2008. 

The geographic extent of the network is not broad 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 violation 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 from 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, all the relevant sampling data is 

included in Appendix C. 

Table 2: Non-Ambient Sampling Results Near Brushy Creek Mine 

Month Average Concentration (μg/m3

) 

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 standard. However, this sampling gives the indication 

that concentrations above the standard could occur 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 Sites 
29 

0.000

0.500

1.000

1.500

2.000

2.500

3.000

Mar-95

Sep-95

Mar-96

Sep-96

Mar-97

Sep-97

Mar-98

Sep-98

Mar-99

Sep-99

Mar-00

Sep-00

Mar-01

Sep-01

Mar-02

Sep-02

Mar-03

Sep-03

Mar-04

Sep-04

Mar-05

Sep-05

Mar-06

Sep-06

Mar-07

Sep-07

Mar-08

Sep-08

DRB#1South DRB#4Short DRB#5North DRB#6NW

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 Herculaneum area, the results indicate potential violations near the large 

stationary sources. However, in the case of the Viburnum Trend, several sources are located 

along the trend within a few miles of each other. The modeling analyses demonstrate that each 

operational source has limited influence on the receptors 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 utilized the latest emissions for each group of sources including 

“stack” testing conducted at one of the mine vent shafts to better characterize 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 modeling 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 predicted ambient violations are limited very 

closely to the property boundary for several of the sources along the trend. 

μg/m3
30 

Figure 15: Viburnum Trend Modeled Concentration 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/Mill 
31 

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 Sweetwater 
32 

The overall analysis was supplemented with a facility-specific evaluation using the same 

receptor network as detailed above. This evaluation was utilized to understand the impact from 

each facility on other violating receptors inside 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 remaining receptors with predicted concentrations 

over the standard near the Fletcher mine/mill facility (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 Buick smelter and mine/mill facility do not contribute 

significantly to the exceeding values around the other mine/mill complexes. Also, the mine/mill 

complexes (other than Buick) do not contribute 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 historic and current air quality monitoring data, the highest 

concentrations of airborne lead occur very near the smelter site. The network around the 

Buick smelter is not as geographically diverse as the Herculaneum area. Currently, there 

is one site located north of the smelter and one site in between the smelter and the Buick 
33 

mine. Both the current sites show concentrations well above the standard in the last few 

years. Dispersion modeling was conducted using 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 characterize 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 Department believes that all citizens should 

be protected from exposure to concentrations over the NAAQS. 

4) Growth rates within the area are very small and are primarily related to production 

increases/decreases at the Doe Run facilities. Further, any population growth does not 

bring additional lead sources into the area because lead emissions are primarily from 

stationary sources. 

5) The meteorological conditions associated with the Viburnum Trend are typical of other 

areas in Missouri. The predominant wind direction in Missouri includes a strong 

southerly component. Further, the modeling analyses conducted to help determine the 

boundary includes meteorological data from nearby Fort Leonard Wood supports the 

recommendation. 

6) There are no significant geographic or topographic features that impact lead 

concentrations in the Viburnum Trend area. 

7) The only existing jurisdictional boundary related to air quality management is the current 

maintenance area that includes Dent Township 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 inclusion of sources that 

contribute to those potential violations. 

8) All the sources of lead in the Trend have been issued construction 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 violating area is being 

impacted by the Doe Run secondary lead smelter and the nearby Doe Run Buick mine/mill 

operation. Therefore, these two Doe Run properties have been included in the recommended 

nonattainment area. The monitored violations of the standard are inside sections that are part of 

the Doe Run property. The modeling analysis illustrates 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 Herculaneum, the Department is recommending that the 

sections containing the violating monitor and contributing sources 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 sections with no previous monitoring data, but 

predicted violations in the dispersion modeling exercise. 
34 

Figure 17: Recommended Buick Lead Nonattainment Area 
35 

Further, the Department is recommending two of the nearby Doe Run operational sites (Brushy 

Creek and Fletcher mine/mill) as unclassifiable due to the temporary monitoring data at the 

Brushy Creek site and the potential violations predicted by the modeling exercises. However, 

the individual culpability analyses do not support inclusion of these sections in the recommended 

Buick nonattainment area. The basis for this finding is the impact from the Buick sources on the 

predicted violations and the impact of these more distant sources on the Buick predicted 

violations. Since monitoring data will be available near these two operational sites in the near 

future, an indication of the attainment status will be made upon review of that data. 

In addition, the Department’s dispersion modeling 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 percent of the standard with the remainder 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 facilities, another lead source in the state is a facility in Holt County 

owned by Exide Technologies (formerly 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/m3

 standard in the third quarter 

of 1994 and concentrations that were a significant fraction of the standard in other quarters. That 

monitoring site was subsequently acquired by Exide Technologies, so it was no longer 

considered ambient. Department staff evaluated 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 results confirm that emissions have been reduced, indicating a 96 

percent reduction since monitoring 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 given consideration as 

potential lead problem areas. The first is an area 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 Oklahoma) 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 Jasper and Newton Counties were listed on the National Priorities 

or Superfund list in 1990. These areas are known collectively as the Oronogo-Duenweg Mining 

Belt Superfund Site, also sometimes called the 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, Residential Yard Soils, included cleanup activities 

completed in 2002 and institutional controls established in 2005. Activities within OU 4, 

Groundwater, were completed in 2004 with the installation of public water supply systems. OU 

5 relates to the Spring River basin 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 disposing 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 near 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 remediation 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 containing each of the 

remediation sites with the Oronogo-Duenweg Mining Belt Superfund Site as unclassifiable. The 

recommended Tri-State unclassifiable area includes Duval, Galena, Jackson, Jasper, Joplin, 

Marion, Mineral, Preston, and Twin Groves Townships in Jasper County and Shoal Creek 

Township in Newton County. 
38 

Figure 18: Recommended Tri-State Unclassifiable Area 
39 

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, Leadwood, 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 Minerals Corporation in 1976 after lead mining in 

the old lead belt area ceased. The park is over 8,000 acres and includes 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. Lead emissions from areas in the park have never 

been quantified in emissions inventories. However, windblown dust and/or dust raised by ORV 

activities are a potential source of airborne lead in and near the park. 

Some limited airborne lead measurements were collected 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 location 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 concentrations over the 2008 standard, but will designate 

the areas containing each of the remediation sites within the Old Lead Belt as unclassifiable. 

The recommended Old Lead Belt unclassifiable area includes Perry, Randolph, and St. Francois 

Townships in St. Francois County. 
40 

Figure 19: Recommended Old Lead Belt Unclassifiable Area 
41 

Summary 

The Department is recommending for nonattainment 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 isolated to ambient air in 

close proximity to these operations. The inclusion of other areas not impacted by these sources 

would not assist these areas in attaining the 2008 lead NAAQS. 

Around the Herculaneum and Buick smelter locations, there are areas with unknown air quality 

at this time. These areas have been designated unclassifiable due to predicted concentrations 

above the standard with no supporting monitoring data and/or non-ambient sampling that 

identifies levels near the standard near other lead sources in the area. Also, the Department is 

recommending for unclassifiable designation areas that 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 Proposed Lead Boundary Recommendation