UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION

7 11201 Renner Boulevard Lenexa, Kansas 66219 MAR 2 7 2015 MEMORANDUM 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I, which contained superseded emission limits for the Herculaneum primary lead smelter and refinery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 Wend
y V i t, A ir Quality Planning Section Chief for the Missouri Department ofNatural Resources

, to M i chael 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 PaperII.DESCRIPTIONOFREVISIONSTherevisiontoMissourirule10CSR10-6.120amendssections(3),GeneralProvisions;section(5),TestMethods,andsubsection(4)(C),ReportingandRecordKeeping.Thefollowingdescribestheamendments.1.Section(3)(A),MethodsofMeasurementofLeadEmissions,hasbeenmovedtosection(5),andrenamed"TestMethods."Thereferencetoparagraph(1)(C)2hasbeenrevisedto(5)(B).2.Subsection(3)(B),OperationalMalfunction,isnow(3)(A).3.Subsection(3)(C),ProvisionsPertainingtoLimitationsofLeadEmissionsfromSpecificInstallations,isnow(3)(B).4.Subsection(3)(C)2.AformerlycontainedspecificstackemissionslimitsforBRRFlistedinTableIIbelow.TableIIEmissionsLimitationStackName_(lbs_l!er24MainStack540.0AndSubsection(3)(C)2.BformerlycontainedfugitiveleademissionsfromleadproductionprocesseslistedinTableIIIbelow.TableIIIEmissionsLimitationStackName(lbsper24hours)BlastFurnace786ChargeReverbFurnace500Chai"g_eRotaryMelt300Charg_eRefinery648LeadCastSubsection(3)(C)2.Aand(3)(C)2.B,includingTablesIIandIII,havebeenreplacedwiththefollowing,innewSubsection(3)(B)2:"DoeRunResourceRecyclingDivisioninBoss,Missouri,shalllimitmainstackleademissionsintotheatmosphereto0.00087grainsofleadperdrystandardcubicfeetofair.Thisinstallationshalllimittotalleadproductiontoonehundredseventy-fivethousand(175,000)tonsperyear."5.Section(4),ReportingandRecordKeeping,subsection(C),hasbeenrevisedtoremovetherequirementtokeeprecords"ofdailyprocessthroughputcorrespondingwiththeprocessesinTableIIIinsubparagraph(3)(C)2.Bofthisrule,"andtomaintaintheserecordson-site"foratleastthree(3)yearsandmadeavailableupontherequestofthedirector,"andreplacesthislanguagewithreferencetosubsection(5)(E),thereferencetotheMaximumAchievableControlTechnology,orMACT,regulations.22NationalEmissionsStandardforHazardousAirPollutants(NESHAP)forSecondaryLeadSmelting(77FR556,January5,2012)26. Subsection (3)(D), Provisions Pertaining

to Limitations
of Lead Emissions From Other Than Stacks
at All Installations, has become subsection (3)(C). Subsection (5)(E) has been added 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. III. EVALUATION
OF THE PROPOSED SIP REVISIONS In a letter dated Aprill, 2009, EPA provided comment on Missouri's proposed rule revision. EPA's comments and Missouri's responses were published
in the Missouri Register which is included
as an attachment

to the SIP revision request dated October 30, 2009. This document

is included
in the SIP 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/m**

**3** 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.

3The four EPA comments above were the only comments received on this rulemaking. Missouri addressed each ofEPA's comments satisfactorily. As discussed
in the Response

to Comment
#1 above, Missouri submitted

a TSD for the amendment
of 10 CSR 10-6.120. Missouri's TSD contains

a modeling demonstration that shows attainment with the 1978 Lead NAAQS (1.5 Jlg/m

3 ). However, on October 15, 2008, EPA promulgated

a final rule which lowered the lead NAAQS
to 0.15 Jlg/m

3 (73 FR 66964). EPA delayed action on approval ofthe revision of Missouri rule 10 CSR 10-6.120 into the SIP until the state submitted
its modeling

to demonstrate attainment
of the 2008 Lead NAAQS. 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)

.

43. Subsection (3)(C), Provisions Pertaining

to Limitations
of Lead Emissions from Specific Installations, has been renumbered

to (3)(B) because the former (3)(A) has been moved to (5)(B). The renumbering

of this section
is not an issue for implementation

of the Herculaneum

or Viburnum Trend Area SIPs; however, the content in paragraphs

1 and 2 is no longer consistent with the operational configurations
and emissions limitations used in the SIP modeling

to attain the 2008 Lead NAAQS. New Subsection (3)(B)1, which pertains
to the Herculaneum facility,

is discussed

in item 3, while new Subsection (3)(B)2, which pertains
to BRRF,
is discussed

in item 4 below. New Subsection (3)(B)1 contains Table

I which provides the Emissions Limitations

in pounds (lbs) per 24 hours for the Main Stack, Number

7 & 9 baghouses, Baghouse Stack, and Number

8 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 Decree

4 . 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.

5the Rotary Melter, and the addition of control measures listed in Section

5
. 1 of the SIP document, including two new baghouses, enclosure of the facility's process and materials handling areas under negative pressure
to achieve the Secondary Lead NESHAP, and additional work practice standards also to comply with the NESHAP. In order to determine the approvability

of the BRRF production limits contained
in the revised Missouri rule 10-6.120(3)(B)2, EPA compared them with the modeled emissions contained
in the Viburnum Trend Area attainment SIP and supporting Consent Judgment required
to attain the 2008 Lead NAAQS (see Table 4, Stack Emission Limits). Although Missouri rule 10 CSR 1 0-6.120(3 )(B)2 establishes the maximum lead production limit for BRRF rather than
a specific emission limitation by stack, the lead production limit, or throughput, correlates with the stack 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. 65. 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 NESHAP,

or Maximum Achievable Control Technology (MACT), regulations. Under the NESHAP (or MACT), 40 CFR Part 63.550, facilities are required

to maintain records on-site for a minimum
of two to five years, depending
on the type of record, and to make those records available upon request of the Administrator

or designee. Reference

in the Missouri rule to the NESHAP standard reduces the regulatory burden on the facility; therefore, this revision
to 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. 7