SUBJECT: 

FROM: 

TO: 

THRU: 

Technical Support Document for Approval to the State Implementation Plan; 

State of Missouri 

. .~ · ·? ~~~'"e R~ &/n/1~- stephame Doolan #U-1" l f.t..---q.) 

AWMD/APDB/AtPS 

M0-285 and M0-335; EPA-R07-0AR-20I5-0223 

Joshua Tapp, Branch Chief, AWMD/APDB _s;:" \"1. Michael Jay, Section Chief, A WMD/ APDB/ AtPS 

I. Introduction 

On November 6, 2009, EPA received a request from Missouri to revise its State Implementation Plan 

(SIP) to include a revision to Missouri rule I 0 CSR I 0-6.120, "Restriction of Lead from Specific Lead 

Smelter-Refinery Installations." This rule was specifically intended to update the existing emissions 

limitations and to reflect throughput limits for Doe Run's Buick Resource Recycling Facility (BRRF) 

contained in the November 2007 revised Prevention of Significant Deterioration (PSD) permit. It should 

be noted that this revised rule is intended to address attainment of the 1978 Lead National Ambient Air 

Quality Standard (NAAQS) at the BRRF and Herculaneum facilities. 

Missouri withdrew portions of IO CSR 10-6.120 on March 4, 2015. 1 Specifically, Missouri withdrew 

subsection (3)(B)l. and Table I, which contained superseded emission limits for the Herculaneum 

primary lead smelter and refinery. In addition, Missouri withdrew the BRRF main stack emissions limit 

of0.00087 grains oflead per dry standard cubic feet (gr/dscf) in subsection (3)(B)2. 

This Technical Support Document (TSD) describes EPA's review and analysis of the proposed SIP 

revision to incorporate the remaining changes to the Missouri rule. 

1 See email from Wendy Vit, Air Quality Planning Section Chief for the Missouri Department ofNatural Resources, to 

Michael Jay, Chief of Atmospheric Programs Section, Air Planning and Development Branch of EPA Region 7, dated March 

4, 2015, available in the Docket for today's action. 

Printed on Recycled Paper 
3. Subsection (3)(C), Provisions Pertaining to Limitations of Lead Emissions from Specific 

Installations, is now (3)(B). 

4. Subsection (3)(C)2.A formerly contained specific stack emissions limits for BRRF listed in 

Table II below. 

Table II 

Emissions Limitation 

Stack Name _(lbs _l!er 24 

Main Stack 540.0 

And Subsection (3)(C)2.B formerly contained fugitive lead emissions from lead production 

processes listed in Table III below. 

Table III 

Emissions Limitation 

Stack Name (lbs per 24 hours) 

Blast Furnace 786 Charge Reverb Furnace 500 Chai"g_e 

Rotary Melt 300 Charg_e Refinery 648 Lead Cast 

Subsection (3)(C)2.A and (3)(C)2.B, including Tables II and III, have been replaced with the 

following, in new Subsection (3)(B)2: 

"Doe Run Resource Recycling Division in Boss, Missouri, shall limit main stack lead 

emissions into the atmosphere to 0.00087 grains of lead per dry standard cubic feet of air. 

This installation shall limit total lead production to one hundred seventy-five thousand 

(175,000) tons per year." 

5. Section (4), Reporting and Record Keeping, subsection (C), has been revised to remove the 

requirement to keep records "of daily process throughput corresponding with the processes in 

Table III in subparagraph (3)(C)2.B of this rule," and to maintain these records on-site "for at 

least three (3) years and made available upon the request of the director," and replaces this 

language with reference to subsection (5)(E), the reference to the Maximum Achievable Control Technology, or MACT, regulations.2 

2 National Emissions Standard for Hazardous Air Pollutants (NESHAP) for Secondary Lead Smelting (77 FR 556, January 5, 

2012) 

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docket. Comments and responses were as follows: 

COMMENT #1: EPA commented that an air quality analysis, including any appropriate modeling 

results, is necessary to show that the conditions contained in the rule are sufficient to provide for 

attainment ofthe 1.5 ~g/m3 NAAQS for lead. EPA recommended that the analysis address all ofthe 

applicable completeness requirements contained in 40 CFR part 51, Appendix V, Section 2.2 Technical 

Support. 

RESPONSE: The department's Air Pollution Control Program will provide EPA with an air quality 

analysis when the rule is submitted to EPA to replace the current rule in the Missouri SIP. No wording 

changes have been made to the proposed amendment as a result of this comment. 

COMMENT #2: EPA noted that the amendment changes the emissions limit for the main stack and 

removes all throughput process limits. The PSD permit for the Doe Run Company's Buick facility 

contains a total lead production limit of one hundred seventy-five thousand (175,000) tons per year. 

This limit is not contained in the rule amendment. The limits in the SIP and in the PSD permit should be 

similar. Future permit changes that could impact attainment and maintenance of the NAAQS for lead 

would also need to be reflected in the SIP. 

RESPONSE AND EXPLANATION OF CHANGE: As a result ofthis comment, paragraph (3)(B)2 has 

been amended to incorporate the addition of the lead production limit contained in the current PSD 

permit. 

COMMENT #3: EPA notes that the rule makes several references to 40 CFR part 63, subpart X, which 

is not part of Missouri's SIP for the Doe Run Resource Recycling Division. Since the state rule 1 0 CSR 

10-6.075, which includes 40 CFR part 63, subpart X, is not approved into the Missouri SIP, the 

reference to it should be removed from subsection (5)(E) of 10 CSR 10-6.120. 

RESPONSE AND EXPLANATION OF CHANGE: As a result ofthis comment, subsection (5)(E) has 

been amended to incorporate this suggestion. 

COMMENT #4: EPA proposed revising subsection (4)(C) to include a reference to the emissions 

limitations described in subsection (3)(B). 

RESPONSE AND EXPLANATION OF CHANGE: As a result ofthis comment, subsection (4)(C) has 

been amended to include the suggested language. 

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On April 18, 2013, Missouri submitted its attainment demonstrations to EPA for both the 

Buick/Viburnum Trend Lead Nonattainment Area and the Herculaneum Nonattainment Area. 3 The 

attainment demonstration SIPs contain an air quality analysis, including modeling, in order to 

demonstrate attainment of the 2008 Lead NAAQS. 

On October 20, 20 14, EPA promulgated the final rule approving the Herculaneum attainment 

demonstration SIP (79 FR 62573). 

Both the Buick/Viburnum Trend and Herculaneum attainment demonstration SIPs rely on portions of 

the Missouri rule 10-6.120 for implementation; however, in order to meet the 2008 Lead NAAQS, both 

the BRRF and Herculaneum facility have undergone substantial changes in operations since the 

Missouri rule was initially promulgated. Thus, EPA focused its review of Missouri rule 10-6.120 on 

consistency with the operational conditions modeled for the attainment SIPs and the elements of the rule 

needed to enforce the control measures, test methods and record keeping requirements. 

The following analysis of the proposed SIP revision for Missouri rule 10-6.120 is organized according to 

the six revisions to the rule listed above in Section II, Description of Revisions. 

1. As listed above, Section (3)(A), Methods of Measurement of Lead Emissions, has been moved to 

section (5), and renamed "Test Methods." The reference to paragraph (l)(C)2 has been revised to 

refer to Section (5)(B). 

There is no change in the original language, and the original language refers to test methods 

which remain current. These test methods are relied upon by both the Viburnum Trend Area and 

Herculaneum SIPs for implementation; therefore, EPA proposes to approve this revision to 

Missouri rule 10-6.120. 

2. Subsection (3)(B), Operational Malfunction, is now (3)(A) with the removal of the previous 

Section (3)(A), as discussed above in item 1. Since there is no change in the language, and the 

provisions of this paragraph are still relied upon for enforcement of the operating conditions at 

both facilities modeled in both SIPs, EPA proposes to approve this revision to Missouri rule 

10-6.120. 

3 The nonattainment designations, effective December 31 , 2010, were fmalized in a Federal Register Notice published on 

November 22, 2010 (75 FR 71033). 

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Baghouse Stack. These limits were enforceable under the 2007 Consent Judgment for 

Herculaneum which was intended to control emissions from Herculaneum as a primary smelter 

and meet the 1978 Lead NAAQS. 

According to Missouri's withdrawal request, the emissions limitations listed in Table I are no 

longer relevant to the facility's operations and its modeling emissions that show attainment of the 

2008 Lead NAAQS. The Herculaneum facility ceased operations as a primary smelter on 

December 31,2013, pursuant to the 2011 Consent Decree4. Pursuant to the 2013 Herculaneum 

SIP and associated Consent Judgment, the Number 7 Baghouse is no longer operational and the 

Numbers 8 & 9 baghouse limits have been superseded by a more stringent limit of3.5 lbs per 24 

hours (the same for both); whereas, the old limits were 8.2 and 56.6 lbs per 24 hours 

respectively. 

New Subsection (3 )(B) 1 and Table I of the revision to Missouri rule 1 0-6.120 has been 

withdrawn by MDNR, and therefore EPA is not taking action on this portion of the revision. 

4. As listed above, Subsection (3)(C)2.A formerly contained specific stack emissions limits for 

BRRF listed in Table II and Subsection (3)(C)2.B formerly contained fugitive lead emissions 

from lead production processes listed in Table III. Tables II and III were replaced with main 

stack lead emissions limits of 0.00087 grains of lead per dry standard cubic feet (gr/dsct) of air 

and a total production limit of 175,000 tons oflead per year in new Subsection (3)(B)2. 

According to Missouri's withdrawal request, the requirement to limit main stack lead emissions 

at BRRF to 0.00087 gr/dscflead conflicts with the Secondary Lead National Emissions 

Standards for Hazardous Air Pollutants (NESHAP, 77 FR 556, January 5, 2012), which requires 

facilities to meet a standard one order of magnitude lower, or 0.000087 gr/dscflead. 

The revision to Missouri rule 10 CSR 1 0-6.120(B)(2) also limits production at BRRF to 175,000 

tons oflead per year. This limit was established in the facility's Prevention of Significant 

Deterioration (PSD) permit. The lead emissions from the present operations are significantly less 

than the previous operational configuration in the PSD permit. This is due to the elimination of 

4 The former Herculaneum primary lead smelter ceased lead smelting operations on December 31, 2013, pursuant to the 

terms of the Consent Decree applicable to the Herculaneum facility entered into by Doe Run, Missouri, and EPA in the 

United States District Court in the Eastern District of Missouri, Case No. 4:10-cv-01895-JCH (2011 Consent Decree) on 

December 21, 2011. 

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emission limits modeled in the SIP. 

Appendix H of the SIP document contains the specific emission factors used in the modeling 

under the "Base" and "Future" cases, and the corresponding production rates (labelled as 

"Throughput"). In the "Future" case analysis, Missouri modeled emissions at a production rate of 

140,810 tons oflead per year for the Reverberatory Furnace and 35,672 tons ofPb per year for 

the Blast Furnace, for a total of 176,482 tons of lead produced per year. The modeled emissions 

in the "Future" case analysis were based on a production amount that slightly exceeded the 

175,000 tons of lead per year imposed by 10 CSR 10-6.120(3)(B)2. The "Future" case modeling 

demonstrates that under conservative production rates (i.e., slightly higher than the maximum 

allowable by the revised Missouri rule), the facility still attains the 2008 Pb NAAQS. 

There is an additional layer of conservatism built into the modeling of the "Future" Case. 

Emissions from all of the major sources associated with the Reverberatory Furnace are based on 

the maximum production level of 140,810 tons of lead per year for this furnace without 

apportioning on the basis of the number ofkettle heat stacks operating at any given time. In other 

words, there are two Dross Kettle Heat Stacks and four Refinery Kettle Heat Stacks; emissions 

were modeled as though all six heat stacks were constantly operational at a maximum production 

level of 140,810 tons oflead per year, assuming 100 % of the emissions from all heat stacks. 

Thus, the "Future" case modeling demonstrates attainment with factors of conservatism built into 

the analysis because all six heat stacks cannot be operating at 100% all at once. 

EPA conducted an independent analysis ofMissouri's attainment SIP modeling and has 

determined that the control measures will result in attainment of the 2008 Lead NAAQS. The 

above analysis of the lead production limits for BRRF imposed by Missouri rule 10-6.120 

demonstrates that they correspond with the SIP control measures, expressed as stack emission 

limits, imposed by the Viburnum Trend Area Lead NAAQS attainment SIP and supporting 

Consent Judgment, and will provide for attainment of the 2008 Lead NAAQS. 

Missouri rule 10 CSR 10-6.120, General Provision (3 )(B)2., which limits main stack lead 

emissions at BRRF to 0.00087 gr/dscf of air has been withdrawn by MDNR, and therefore EPA 

is not taking action on this portion ofthe revision. Based on EPA's analysis discussed above, the 

175,000 tons oflead in Missouri rule 10-6.120 will be retained for approval because enforcement 

of the SIP relies upon this production limit in order to meet the 2008 Lead NAAQS. 

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the rule is acceptable. EPA proposes to approve this portion of the rule. 

6. As discussed above, Section (5)(E) has been added to the rule to reference 40 CFR subpart X, as 

incorporated in 10 CSR 10-6.075, Maximum Achievable Control Technology Regulations, for 

methods for demonstrating compliance at BRRF. 

Test Methods for determining compliance with the Secondary Lead Smelter NESHAP, 40 CFR 

Part 63.547, contains the methods for performance testing. These methods are federally 

approved. Reference in the Missouri rule to these federally approved methods therefore reduces 

the regulatory burden on the facility by requiring compliance with one standard. Thus, EPA 

proposes to approve this portion of the revised rule. 

As stated above, MDNR received four comments on the proposed rule revisions from EPA. All 

comments were adequately addressed. 

IV. SUMMARY AND RECOMMENDATIONS 

In accordance with Missouri's withdrawal request, EPA is not taking action on the following revisions 

to Missouri rule 10-6.120 : 

1. Section (3 )(B) 1 and Table 1, which pertains to the Herculaneum facility. 

2. Subsection (3)(B)2, pertaining to BRRF, which establishes main stack lead emissions limits of 

0.00087 gr/dscf. 

The remaining portions of the revised Missouri rule 10-6.120 support the Herculaneum and Viburnum 

Trend Area attainment demonstration SIPs; therefore, it is recommended that these provisions be 

proposed for approval as a part of the M0-285 and M0-335 combined SIP action. 

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