The Doe Run Company 

Herculaneum Smelter 

Herculaneum, Missouri 

WORK PRACTICE MANUAL 

For Control of Lead Emissions 

January 2007 

Use and Maintenance of this manual is a requirement of the Missouri Air 

Conservation Rule 10 CSR 10-6 .120 (4), and the 2007 Revision of the 

State Implementation Plan (SIP) for the Herculaneum Lead Nonattainment 

Area . This document is intended to fulfill the obligation of 2007 SIP 

Consent Judgment . 

(with the Primary Lead MACT) 

Note : Revisions to manual are shown underlined for revision date shown 

on same page . 
WORK PRACTICE MANUAL 

Herculaneum Smelter 

Table of Contents 

Area No . Area Page No . 

Introduction 1 

--- List of appendices 3 

--- Purpose, Use and Change 4 

150 Sinter Plant 5 

152 Blast Furnace 7 

155 Strip Mill 10 

156 Refinery 10 

162 Baghouse 12 

166 Yard 13 

185a Environmental crew 15 

185b Environmental Dept . 18 

185c Meteorological monitoring 18 

185d Monitoring for improvement 20 

--- Construction guidelines 22 

Record Keeping - General 22 

Suspension of Work Practices 23 

- Demo 

Ventilation Survey 24 

Appendices 25 
WORK PRACTICE MANUAL 

HERCULANEUM SMELTER 

APPENDICES 

Appendix Location/Usage Page No . 

A Sinter Hood - Decision Tree 25 

B Sinter plant - Waste gas Inlet Temperature to # 3 

Baghouse 26 

Blast-Furnace/# 5 BacLhouse - Waste Gas Inlet 

Temperature to # 5 Baghouse - - - - - - - - - - - -27 

D Ventilation Systems : 

D-1 Smooth Rolls Baghouse 28 

D-2 CV-10 Grizzly 28 

D-3 CV-10 and CV-11 Vent 29 

D-4 CV-.13 and CV-14 Vent 29 

D-5 Scale Belt Vent 30 

D-6 Crow's Nest Ventilation 31 

D-7 "D" Kettle Fluxing Vent 31 

D-8 Blast Furnace Front End Vent 32 

D-9 Sinter Plant Wheel Tunnel Ventilation 32 

E-1 Plant Layout with Water Truck Route(s) 33 

E-2 Plant Layout with Wet Sweeper Route 34 

E-3 Plant Layout with Regenerative Sweeper Route 35 

E-4 Monthly Sweepers and Water trucks summary 36 

F Plant Fence Line current and projected 37 

G Building Enclosure Inspection 38 

H Meteorological weekly/monthly inspection 39 

I Hosedown to wet or reduce material form 40 

J MACT Blast Furnace & Refinery daily form 41 

K MACT Sinter Plant daily records form - 42 

L Concentrate Receiving Procedure - - - ---- 43 

M Concentrate_Receivinq Backup Plan 45 

N Preliminary -sample of a review day chart 46 

O Street Sampling Protocol - 47 

P Smelter Flow Diagram - - -- -- --- 48 
WORK PRACTICE MANUAL 

HERCULANEUM SMELTER 

PURPOSE, USE AND CHANGE 

1 . This manual is written to comply with the Missouri Air Conservation 

Rule 10 CSR 10-6 .120 Section (4) . 

This manual is also intended to fulfill the obligation under 

paragraph B.7 .of the 2007 SIP Consent Judgment which was entered as 

an element of the 2007 Revision of the State Implementation Plan 

(SIP) for the Herculaneum Lead Nonattainment Area . 

2 . The manual shall be the method of determining compliance with the 

provisions of Doe Run's obligation under the rule and Consent 

Judgment . Failure to adhere to the work practices in the manual 

shall be a violation of the rule or Consent Judgment . 

3 . Any change to the work practices in the manual requires prior 

written approval from the MDNR director before any change becomes 

effective and goes into practice . 

ACTION TO PREVENT EXCESS PROCESS EMISSIONS 

-Utilizing Emissions Predictor Profile Operating Procedures (OP) and 

Decision Trees (DT) 

Appendix A : Sinter Hood - Decision Tree 

Appendix B : Sinter plant - Waste gas Inlet Temperature to # 3 

Baghouse 

Appendix C : Blast Furnace/# 5 Baghouse - Waste Gas Inlet 

Temperature to #5 Baghouse 

4 . Definitions : 

Accumulated materials : lead bearing particulate that has the 

potential to become easily re-entrained . 

Hose down : to wet or reduce accumulated materials . 

Wetting : sufficient water to be used to insure no visible emission 

immediately following hose down . 
150 Sinter Plant 

l . A simplified crushing circuit was installed in 1991 in the sinter 

plant, resulting in a reduction in the number of physical pieces of 

equipment, reduced number of transfer points and improved 

ventilation through more efficient baghouses versus the previous 

wet scrubbers . The sinter plant crushing circuit is ventilated by 

the sinter plant "smooth rolls" baghouse . 

2 . Hose down of areas to be performed when weather conditions permit 

so as not to create slipping hazards due to ice forma'tion or 

glazing of surfaces . These conditions can exist when the 

temperature is less than 39 F or whenever the application of water 

results in the formation of ice, which could result in injury to 

personnel . 

a . The following areas will be hosed down on a per shift basis to 

wet or reduce accumulated material : 

Location Elevation, ft . (*) 

sinter machine main floor 55 

claw breaker floor 40 

CV-40 floor area 40 

Live roll floor area 19 

bottom floor of sinter plant 0 

b . The following areas are scheduled for hose down on a per day 

basis to wet or reduce accumulated material : 

-- wind box floor area 45 

-- crusher baghouse floor 40 

(*) In a . and b . elevations are Relative to the bottom floor 

elevation of 0 feet . 

3 . Sinter production will be limited to no more than 2160 tons per day 

and 169,190 tons per calendar quarter . 

4 . Sinter will be wet finished prior to loading to truck or rail for 

stock . 

5 . Sinter to stock pile shall be limited to 45000 tons to pile per 

quarter with a maximum in sinter stock storage pile of 20,000 tons . 

6 . Building doors to be kept closed during operations : 

a . By April 7, 200$ Personnel doors (man doors) to the building 

will be kept closed except when entering and exiting the 

building by the aid of door weights or similar device to allow 

for automatic closure 

b . By April 7, 2007 Large equipment doors will be kept locked and 

access allowed only by the shift supervisors permission for 

various pieces of mobile equipment and repair parts to enter 

and exit the building . Events of door opening and closing 

will be recorded in departments equipment doors key logbook . 
Automatic closure systems may be used in place of the lock and 

key method . Equipment doors will be kept closed except when 

entering and exiting the building . 

* During periods of heat alerts, it may be necessary to open 

these doors to prevent heat stress or exhaustion of those 

employees working inside . A record will be kept of those 

events as noted in "Record Keeping General" section 2 "Reasons 

for suspension of work practices" . 

7 . Maintenance of doors and siding - During normal operating 

conditions all doors will be kept closed and siding/doors will be 

inspected regularly and repaired promptly . The area's employees 

will inspect the condition of the doors/siding every two weeks 

noting both need for repairs and executed repairs using the form 

found in Appendix G . If holes or openings are found in the 

doors/siding, request for repairs will be initiated and recorded on 

the building inspection form on the day of the inspection . 

Enclosed areas such as the sinter loading area on the northeast 

corner of the sinter area and cooler baghouse dust handling area 

will be integrated into the sinter building doors and siding 

inspection routine . The area supervisor will keep the Appendix G 

forms . Items for repair will be prioritized such that if a larger 

type opening such as a 4ft x 4ft size section is found missing, the 

department will immediately reduce operations up to and including 

shutting down the buildings processing of material if needed until 

opening is sealed ., Smaller size openings such as a 6 inch type 

opening that will require bringing in offsite mobile equipment will 

be scheduled and sealed within 2 weeks . 

8 . By April 7, 2007 DOE RUN will maintain the hot gas section wheel 

tunnel of the sinter machine at a design rate of 15,000 cfm . These 

gases will be vented to the #3 baghouse which shall be designed to 

meet a total suspended particulate specification of 0 .022 grains 

per dry standard cubic foot . The wheel tunnel ventilation will be 

continuously operated except when #3 sinter plant baghouse is down 

or when conducting necessary maintenance, in which instances 

interlocks will be activated, shutting down the fan . 

9 . By April 7, 2008 Doe Run will measure the wheel tunnel ventilation 

in conjunction with the wheel tunnel damper setting and fan 

amperage and develop a calculation of fan amperage to flow rates . 

Fan amps will be continuously recorded . 

10 . Record keeping for the sinter plant will include : 

a . shift hose down to wet or reduce accumulated material of 1) 

sinter machine floor, 2) claw breaker floor, 3) cv40 floor 

area, 4) live roll floor area, 5) bottom floor of sinter plant 

b . Record that water was being added to sinter going to truck or 

rail at the clamshell area . 

c . daily sinter trucks to stock . 

d . daily hose down to wet or reduce accumulated material of 1) 

wind box floor area, 2) crusher baghouse floor area . 
e . Every two week Building doors and siding inspections with 

record of requests for maintenance to be performed on findings 

of holes, openings or improperly working doors, as well as 

executed repairs, on appendix G form . 

f . Quarterly ventilation reading on Wheel Tunnel ventilation fan . 

9- Once installed, instruments shall continuously record fan 

amperage of the Wheel tunnel ventilation fan . 

h . Daily MACT differential pressure readings on baghouses . 

i . heat events that require doors to be open . 

j . Record entries of reasons of suspension of any work practices 

as noted in Record keeping - general section 2 . 

k . Continuous recording of #3 baghouse fan amps . 

1 . Large equipment doors key log of when doors were opened and 

closed . (In the event that doors become automatic, this 

logbook will no longer be required .) 

152 Blast Furnace 

1 . Blast Furnace charge will be limited to no more than 2160 tons of 

sinter per day and 169,190 tons per calendar quarter . 

2 . The Dross Plant will be limited to no more than 1260 tons of rough 

lead produced per day . 

3 . Hose down of areas to be performed when weather conditions permit 

so as not to create slipping hazards due to ice formation or 

glazing of surfaces . These conditions can exist when the 

temperature is less than 39 F or whenever the application of water 

results in the formation of ice, which could result in injury to 

personnel . 

a . The blast furnace feed floor operator will hose down feed 

floor areas north and south of the charging slots on a per 

shift basis to wet or reduce accumulated material . 

b . The floor area in front of the blasting furnaces (blast 

furnace crane bay) is to be hosed down on a daily basis to wet 

or reduce accumulated material . 

c . The area underneath the CV-13 conveyor will be hosed down on a 

weekly basis to wet or reduce accumulated material . 

4 . At least 3 pots will be used in lead pot rotation during normal 

furnace operations . ' 

5 . Building doors to be kept closed during operations : 

a . By April 7, 2008 Personnel doors (man doors) to the building 

will be kept closed except when entering and exiting the 
building by the aid of door weights or similar device to allow 

for automatic closure . 

b . By April 7, 2007 Large equipment doors will be kept locked and 

access allowed only by the shift supervisors permission for 

various pieces of mobile equipment and repair parts to enter 

and exit the building . Events of door opening and closing 

will be recorded by way of departments equipment doors key 

checkout logbook . Automatic closure systems may be used in 

place of the lock and key method . Equipment doors will be 

kept closed except when entering and exiting the building . 

* During periods of heat alerts, it may be necessary to open 

these doors to prevent heat stress or exhaustion of those 

employees working inside . A record will be kept of those 

events as noted in "Record Keeping General" section 2 "Reasons 

for suspension of work practices" . 

6 . Maintenance of doors and siding - During normal operating 

conditions all doors will be kept closed and siding/doors will be 

inspected regularly and repaired promptly . The area's employees 

will inspect the condition of the doors/siding every two weeks . If 

holes or openings are found in the doors/siding, request for 

repairs will be initiated and recorded on the building inspection 

form on the day of the inspection . The area supervisor will keep 

records of every two week inspections using a form found in 

appendix G . Items for repair will be prioritized such that if a 

larger type opening such as a 4ft x 4ft size section is found 

missing that results in visible building air outflow, the 

department will immediately reduce operations up to and including 

shutting down the buildings processing of material if needed until 

opening is sealed . Smaller size openings such as a 6 inch type 

opening that will require bringing in offsite mobile equipment will 

be scheduled and sealed within 2 weeks . 

7 . By April 7 ; 2007 furnace void "Blow Hole" Tuyere controls will be 

operated and maintained . The Automated flow controllers on the 

tuyers that inject air into the bottom of the furnace will be 

installed to continuously monitor flow at each tuyere . Tuyere 

controls will be operated with an interlock system that will 

automatically reduce the air flow into particular area of the 

furnace where the computer system detects a "blow hole" effect may 

be occurring . When the air flow is reduced into the bottom of the 

furnace, the "Blow Hole" effect on top of the furnace is then 

reduced to a point where the building ventilation will capture the 

remaining dust on the furnace feed floor if any residual dust from 

a hole through the feed shows up on the feed floor within the 

building . Electrical department will check the system once per' 

quarter and correct programming as problems are found . 

8 . By April 7, 2007 Doe Run will operate an interlock system that will 

restrict air feed to the bottom of the furnace when the #5 baghouse 

fans are not operational such as during an electrical malfunction 

or mechanical failure . See appendix C . 
9 . By April 7, 2007 Doe Run will operate an alarm system that will 

detect when the number 5 baghouse temperature is nearing a point 

that will cause the baghouse fans to shut down . The alarm will 

give notice to the blast furnace personnel, by way of an audible 

alarm and flashing signal, resulting in measures to prevent 

automatic furnace air reduction and fan shutdown to occur . In the 

event that fan shutdown will occur, the above item #8 interlock 

system will take over . See appendix C . 

10 . By April 7, 2008 Doe Run will continuously record #5 baghouse flow 

readings on the outlet duct of #5 baghouse and maintain a 

ventilation rate of 300,000 actual cubic feet per minute . 

11 . By April 7, 2008 Doe Run will Continuously record #6 baghouse 

amperages and maintain a ventilation rate of 50,000 actual cubic 

feet per minute . 

12 . By April 7, 2008 Doe Run will Continuously record #7 baghouse 

amperages . Minimum flowrates to be determined during the building 

in-flow study . 

13 . Record keeping for the blast furnace shall include : 

a . Shift items : 

1) hose down to wet or reduce accumulated material of 1) feed 

floor areas north and south of the charging slots, the 

shift work performed on (eg . Day, evening, night) and 

shift crew supervisor (eg . John Smith) . 

2) Pots in rotation 

b . Daily hose down to wet or reduce accumulated material of the 

floor area (crane bay) in front of the blasting furnaces 

(blast furnace crane bay), the shift work performed on (eg . 

Day, evening, night) and shift crew supervisor (eg . John 

Smith) . 

c . Weekly hose down to wet or reduce accumulated material of 1) 

area underneath the CV-13 conveyor the shift work performed on 

(eg . Day, evening, night) and shift crew supervisor (eg . John 

Smith) . 

d . Every two weeks building doors and siding inspections with 

record of requests for maintenance to be performed on findings 

of holes, openings or improperly working doors, as well as 

executed repairs, on appendix G form . 

e . Large Equipment doors key log of when doors were opened and 

closed . In the event that doors become automatic this logbook 

will no longer be a requirement . 

f . Continuous measurement of #5 baghouse flow on the outlet side 

of the baghouse . 

g . Continuous measurement of #5 baghouse fan amperages . 
h . Quarterly - Automated "blow holes control" Inspection record 

by the electrical department showing that the program has been 

checked and is in proper working order . Any problems found 

will be corrected at the time of the program inspection and 

noted with the log of the inspection . 

J " 

Quarterly - #5 fans down warning due to #5 baghouse 

temperatures inspection record by the electrical department 

that the system has been checked and assured to be in proper 

working order . Any problems found will have corrective 

measures initiated on the day of the inspection and noted with 

the log of the inspection . Executed repairs will be recorded 

in the log with the inspection . 

Quarterly - Record by the electrical department that the #5 

fans down automated restriction (of air flow to bottom of 

furnace tuyeres) system has been checked and assured to be in 

proper working order . Any problems found will be corrected on 

the day of the inspection and noted with the log of the 

inspection . 

k . Record entries of reasons of suspension of any work practices 

as noted in Record keeping - general, section 2 . 

1 . Continuous recording of #7 building ventilation baghouse fan 

amperages . 

m . Continuously recording of #6 baghouse fan amperages 

155 Strip Mill 

l . Strip mill floor will be vacuumed or washed at least once a week to 

wet or reduce accumulated material . 

2 . Record keeping for the strip mill shall include : 

a . For vacuuming of the strip mill floor area the date, the shift 

work performed on (eg . day, evening, night) and foreman 

supervising the shift (eg . John Smith) . 

b . Record entries of reasons of suspension of any work practices 

as noted in Record keeping - general, section 2 . 

156 Refinery 

l . Refinery dock floor will be vacuumed at least once a month to 

reduce accumulated materials . 

2 . Refinery kettle department will hose down the kettle floor at least 

once a week to wet or reduce accumulated material . 

3 . Refinery will be limited to 888 tons of refined lead produced per 

day and 50,000 tons per calendar quarter . Limitation may fluctuate 

as per consent agreement B (6)(c) 

10 
4 . Hose down will only be performed when weather conditions permit so 

as not to create slipping hazards due to ice formation or glazing 

of surfaces . These conditions can exist when the temperature is 

less than 39 F or whenever the application of water results in the 

formation of ice, which could result in injury to personnel . 

5 . Building doors to be kept closed during operations : 

a . By April 7, 2008 Personnel doors (man doors) to the building 

will be kept closed except when entering and exiting the 

building by the aid of door weights or similar device to allow 

for automatic closure 

b . By April 7, 2007 Large equipment doors will be kept locked and 

access allowed only by the shift supervisors permission for 

various pieces of mobile equipment and repair parts to enter 

and exit the building . Events of door opening and closing 

will be recorded by way of departments equipment doors key 

checkout logbook . Automatic closure systems may be used in 

place of the lock and key method . Equipment doors will be 

kept closed except when entering and exiting the building . 

* During periods of heat alerts, it may be necessary to open these 

doors to prevent heat stress or exhaustion of those employees 

working inside . A record will be kept of those events . 

6 . Maintenance of doors and siding - During normal operating 

conditions all doors will be kept closed and siding/doors will be 

inspected regularly and repaired promptly . The area's employees 

will inspect the condition of the doors/siding every two weeks . If 

holes or openings are found in the doors/siding, request for 

repairs will be initiated and recorded on the building inspection 

form on the day of the inspection . The area supervisor will keep 

records of every two week inspections using a form found in 

appendix G . Items for repair will be prioritized such that if a 

larger type opening such as a 4ft x 4ft size section is found 

missing that results in visible building air outflow, the 

department will immediately reduce operations up to and including 

shutting down the buildings processing of material if needed until 

opening is sealed . Smaller size openings such as a 6 inch type 

opening that will require bringing in offsite mobile equipment will 

be scheduled and sealed within 2 weeks . 

7 . By April 7, 2008 a Kettle heat stack camera will be placed in a 

location that allows it to survey all Dross Plant and Refinery 

kettle heat stacks . The camera will be positioned so that 

emissions can be attributed to specific individual stacks, with 

minimal light interference . The camera will broadcast in real time 

to the sinter plant control room, environmental department, blast 

furnace control room, general foreman's office and the security 

office so that multiple people can observe for an event . Operators 

in the sinter plant control room will regularly observe this 

monitor, and the security office will provide a backup during 

periods when sinter operators are occupied . In the event that a 

plume of smoke is noticed from one or more of the kettle heat 

stacks, the refinery department will be contacted so that they can 

11 
immediately shut off the burners to the kettle(s) showing the 

problem(s) to stop the smoke, have the kettle dipped out to place 

contents into a previous kettle in the department before the 

material freezes in the kettle and log that a kettle heat stack 

event(s) occurred and which kettles were found to be causing the 

event(s) . 

8 . Kettles and kettle settings will be inspected prior to putting back 

into operation to assure that any visible lead that was in the 

kettle setting area has been cleaned out and returned to the 

process . 

9 . By April 7, 2008 Doe Run will Continuously record #8 & #9 baghouse 

amperages (separately) . Minimum flowrates to be determined during 

the building in-flow study . 

10 . Recording keeping for the Refinery shall include : 

a . Weekly hose down of the kettle floor area the date, the shift 

work performed on (eg . day, evening,-night) and foreman 

supervising the shift (eg . John Smith) . 

b . bi-weekly building doors and siding inspections with record of 

requests for maintenance to be performed on findings of holes, 

openings or improperly working doors on appendix G form . 

c . Monthly vacuuming of the refinery lead dock area the date, the 

shift work performed on (eg . day, evening, night) and foreman 

supervising the shift (eg . John Smith) . 

d . Continuously record #9 & #8 baghouse fan amperages 

(separately) . 

e . Large Equipment doors key log of when doors were opened and 

closed . In the event that doors become automatic this logbook 

will no longer be a requirement . 

f . Record entries of reasons of suspension of any work practices, 

as noted in Record keeping - general section 2 . 

9- Recording that kettle and kettle settings where inspected 

prior to replacing kettle and putting back into service . 

h . Events of kettle failures, including discovery and resolution, 

will be recorded and summarized monthly for the quarterly 

report . 

i . Record entries of reasons of suspension of any work practices 

as noted in Record keeping - general section 2, such as any 

heat events requiring doors to be open . 

162 Baghouse 

1 . Hose down of areas to be performed when weather conditions permit 

so as not to create slipping hazards due to ice formation or 

glazing of surfaces . These conditions can exist when the 

temperature is less than 39 F or whenever the application of water 

12 
results in the formation of ice, which could result in injury to 

personnel . 

a . The ground floor in the # 3 baghouse will be hosed down on a 

daily basis to wet or reduce accumulated material Monday 

through Friday . 

b . The ground floor in the # 5 baghouse will be hosed down on a 

daily basis to wet or reduce accumulated material Monday 

through Friday . 

2 . The #3 and _#5 baghouse will use the redler conveyor to move 

captured dust back to the sinter plant for recycle . 

3 . By April 7, 2007 Doe Run will operate water sprays during the 

movement of dust to railcars to prevent any visual dust from the 

area during the activity . The operator will increase the amount of 

water needed at this location in the event that cars begin showing 

a moisture content less than 8% from the yard departments fume rail 

car sampling . The purpose for additional water usage at this 

location is to reduce the need for any additional work of wetting 

fume by the fume railcar unloading person to maintain the 8% 

moisture content . 

4 . Baghouses will be maintained in accordance with the subpart TTT 

MACT standards . 

5 . Record keeping : 

a . Shift hose down of #3 baghouse floor to wet or reduce material . 

b . Shift hose down of #5 baghouse floor to wet or reduce material . 

c . Weekly MACT inspection items 

d . Monthly MACT inspection items 

e . Quarterly MACT inspection items 

f . Record entries of reasons of suspension of any work practices as 

noted in Record keeping - general section 2 . 

166 Yard 

1 . Transportation will wet finished sinter with a fire hose prior to 

loading sinter to Railcars . 

2 . Hosedown of plant areas may be suspended during any period when the 

temperature is less than 39 F, or whenever the application of water 

results in the formation of ice which could result in injury to 

plant personnel . 

3 . Concentrate will be received by truck at the truck unloading 

station between the hours of 6am and lOpm up to a total of 1,800 

tons per day . (See appendix L) . 

13 
4 . A minimum of 11 truck loads of concentrate shall be received 

directly to railcar on days that concentrate is received . Doe Run 

shall endeavor to convey concentrate directly to rail cars at all 

times feasible . The concentrate delivery system may be altered if 

Doe Run identifies an improved system upon written approval of the 

Director of the Department of Natural Resources Air Pollution 

Control Program . 

* Note, In the event of broken rails, derailed equipment, or if the 

unloading conveyor is under repair, direct loading to rail cars 

will be suspended, and the backup unloading plan (described in 

appendix M) will be implemented . 

5 . Concentrate will be received at a daily average moisture content of 

60 or greater . The attendant at the unloading station will take a 

sample from each truck and place in a plastic bag to prevent 

drying . At the end of the shift the samples will be delivered to 

the laboratory for moisture analysis . The plant metallurgist will 

maintain the concentrate file for the daily average moisture 

contents . If the average daily moisture drops to be below 6%, the 

plant metallurgist will make the necessary contacts so that daily 

average moistures will be maintained at 6% or higher . 

6 . Slag will be hauled by truck to the slag storage pile for 

approximately 2 weeks per calendar quarter . Truck hauling shall 

occur during daylight hours . Hauling must be coordinated with 

Environmental crew to assure that unpaved haul-route is covered by 

water truck at least once every 4 hours during days of hauling and 

treated with a dust suppressant within 72 hours after hauling 

period is complete . 

7 . Concentrate shall be unloaded at the railcar tipper/unloader 

between the hours of 6 AM and 10 PM . 

8 . Concentrate loaded to railcars from the ground will be limited to 

no more than 1187 tons per 6am to lOpm day period . 

9 . By April 7, 2007, fume shall only be unloaded to stock at the south 

end stock area between the hours of noon and 6 pm . The unloading 

of fume to the south end will be limited to 13 cars per quarter . 

By April 7, 2008, outside fume handling is to be maintained at a 

daily average moisture content of 8% or higher . Moisture samples 

will be taken from each car before it is unloaded at the south end 

stock area . An operator working the area will take the sample, 

place in a plastic bag and deliver to the lab for moisture 

analysis . If the moisture level is below 80, water will be added 

to bring the moisture up to the 80 level or above . Yard department 

will notify the baghouse department if the trend for more or less 

moisture in the fume is needed . 

10 . Fume unloaded to stock on south end storage will be limited to no 

more than 1170 tons,per calendar quarter . 

11 . Fume shall only be added into concentrate cars on the south end 

between the hours of 6am and lOpm . Outside fume handling is to be 

maintained at a daily average moisture content of 80 or higher . On 

14 
days they are working on the fume pile, the operators will visually 

ensure that moisture levels are such that dusting does not occur . 

If there is any visual sign of dusting, the operator performing the 

loading operation will ensure that water is added to the pile 

before continuing . The portion the pile that is going to be worked 

with will be sampled daily by the operators performing the loading 

to assure that moisture levels are being maintained at the 80 or 

greater level . If the moisture level result falls below the 80 

level, water spray will be added to the material with a water hose 

to bring it back into the 80 or greater moisture level . 

12. By April 7, 2008, Doe Run shall limit opening of doors at Rail car 

tipper/unloader building . Both North and South doors must be 

closed once a railcar is moved inside the building . Doors will 

remain closed while the car is tipped and material is conveyed out 

of the hopper . Doors may be opened to move out an empty car or to bring a 

loaded car inside. Doors will be kept closed when unloader is not in use. Doors 

may remain open during times equipment that will not fit inside the building is 

required for maintenance but tipper may not move material during these times. . 

13 . Record keeping for the yard shall include : 

1 . Record of dates and time periods that trucks hauled slag to 

slag storage pile . 

2 . Daily record of railcar loading times : 

a . Direct loading of concentrate from truck unloading 

b . Storage loading of concentrate to railcar ; dates, times, 

and tons . 

c . Time when fume was added to concentrate railcars on south 

end . 

3 . Daily record of date and times sinter cars loaded on the south 

end stock area to rail cars . 

4 . Daily log record of date and times that rail loads were 

delivered to unloader and Furnace Trestle . 

5 . Daily average moisture contents of concentrate loads received . 

6 . Daily average o moisture, dates, times, and calculated tons of 

fume transferred on South end stock area from railcar to 

storage pile and recorded in daily log book . 

7 . Daily average a moisture in fume pile transferred to railcars 

at south end stock area . 

8 . Record of concentrate delivery dates, times and tons received . 

9 . Record entries of reasons of suspension of any work practices 

as noted in Record keeping - general section 2 . 

10 . Record of when backup plan is used . Steps taken to correct . 

15 
185a Environmental Crew 

l . Areas of the plant that are accessible by equipment will be cleaned 

a minimum of 6 hours per day on a Monday through Friday schedule . 

One or more of the following pieces of equipment will be used to 

perform the minimum of 6 hours of cleaning . Wet Sweeper, Water 

truck, hose washing and/or dry sweeper truck will wet and sweep 

those areas of plant that are accessible by the equipment . 

Operators will work off of daily check sheets to assure that all 

sweeping and watering routes, (see appendices E1, E2 and E3), have 

adequate coverage . A monthly summary of the daily hours of work 

performed will be kept by the environmental crew's supervisor . (see 

appendix E4) 

On traffic routes inside the plant, the wet sweeper will be 

operated unless the temperature falls to below 39 Fahrenheit, 

When the temperature is below 39 degrees, the traffic routes in the 

plant will be swept with a high efficiency dry sweeper . 

2 . Environmental department crew is responsible for hosing down the 

area between the blast furnace blower room and the trestle on a 

weekly basis . Record will indicate which shift the work was 

performed on (eg . Day, evening, night) and the crew Supervisor for 

that shift . (eg . John Smith) . 

3 . By April 7, 2007 Doe Run will operate a Regenerative air sweeper . 

Street Sweeping with a Regenerative air sweeper (or sweeper with 

equivalent or better capture efficiency design) will be performed 

at a minimum of 6 hours per day Monday through Friday and on any 

other day that concentrate is scheduled for delivery to the plant . 

(see routes appendix E3) (see monthly summary of daily sweeper use 

appendix E4) Sweeper effectiveness will be tracked by a minimum of 

Quarterly road/street samples designated as 1) Refinery dock road 

exit, 2) Truck wash exit, 3) Main and Curved Street 4) Station 

Street . (See Appendix O) 

4 . Temporary sources of dust on paved surfaces outside the plant due 

to spillage of materials will be addressed so as to limit the reentrainment of those materials . Clean up to consist of those 

materials being loaded into transfer vehicles by either hand 

shoveling or should the need arise mechanized equipment . Final 

clean up will incorporate the use of floor sweep compound which 

will adhere to the smaller particles, making them easier to remove . 

5 . Chemically stabiiize unpaved portion of slag haul route from blast 

furnace dewatering tanks to paved portion of roadway east of the 

refinery lead load out dock within 72 hours of completing slag 

hauling activity . See dotted line on water truck route map . 

(Appendix E1) 

6 . Water truck will wet the unpaved slag haul road route from slag 

dewatering tanks to paved portion of roadway east of the refinery 

lead load out dock at least once every 4 hours during any day or 

portion of day that the road is used for hauling slag to storage . 

(see dotted line on water truck route map (Appendix E1) The water 

truck will provide a minimum rate of 1000 gallons per day over the 

defined stretch of road (350 gal per trip) . In the event that 

16 
rainfall occurs during the slag hauling process, the water truck 

will not be required to cover the road section . Record will be kept 

on daily water truck log . 

7 . Chemically stabilize inactive concentrate storage piles a minimum 

of once every month to crust surface area of piles and reduce 

particulate from wind born re-suspension . 

8 . Chemically stabilize inactive portion of fume storage pile at the 

yard area where fume is added to concentrate cars a minimum of once 

every month to crust surface area of pile and minimize particulate 

from wind born re-suspension . The water truck operator will spray 

the pile working with a pump and nozzle setup on the water truck . 

Record will be kept on the water truck operators piles treatment 

record form and on the monthly summary kept by the environmental 

crew supervisor (appendix E4) 

9 . Truck watering and hosedown of plant areas may be suspended during 

any period when the temperature is less than 39 F, or whenever the 

application of water results in the formation of ice which could 

result in injury to plant personnel . Watering and hosedown may be 

suspended during periods of natural wetting by rainfall . 

10 . By April 7, 2008 Doe Run will continuously operate a sprinkler 

system to cover haul routes within the plant . The sprinkler system 

will be operated when weather conditions permit so as not to create 

slipping hazards due to ice formation or glazing of surfaces . 

These conditions can exist when the temperature is less than 39 F 

or whenever the application of water results in the formation of 

ice, which could result in injury to personnel . Coverage area map 

is provided in appendix E-5 . Record reasons for any activities not 

being performed relative to paragraph 2 of "General Record Keeping" 

section such as short periods of time when water pumps have to be 

off line for repair and maintenance or conditions exist that cause 

ice formation which would normally occur at less than 39° F . 

11 . By April 7, 2007 Doe Run will maintain a fence to preclude Public 

access to in plant property . See appendix F fence line map . 

12 . Record keeping for the environmental crew shall include : 

a . Daily-Regenerative air outer roads/streets street sweeper 

route trip coverage record . 

b . Daily in plant and slag haul road route water truck use log . 

c . In plant Envirowhirl sweeper truck log . 

d . Weekly hosing down the area between the blast furnace blower 

room and the trestle the shift work performed on (eg . Day, 

evening, night) and shift crew supervisor (eg . John Smith) . 

e . Daily in plant wet sweeper log . 

f . Quarterly sampling results of outer roads/streets sampling . 

q . Monthly record of treating piles on south end stock storage . 

17 
h . Weekly sprinkler inspection record . 

h . Quarterly fence inspection record . 

Sweeper effectiveness surveys . 

Reasons for any activities not being completed relative to 

paragraph 2 of General Record keeping . 

k . Monthly sweeper, water truck summary log for Quarterly report . 

185b 

Environmental Dept . 

1 . Monthly reviews for action items/data/recording by departments 

2 . Sample day reviews for monitoring for improvement . 

3 . 

Reporting : 

1 . Quarterly S .I .P . Report to MDNR by end of first month following a 

standard sampling quarter that will include : 

A . Summary of sample day reviews 

B . Monthly summary log of sweeper activities 

C . Quarterly air lead report 

a . latest laboratory lead audit result 

b . sample day results for the quarter 

c . reasons for no sample results 

D . 

2 . Quarterly meteorological audits to EPA by end of first month 

following a standard sampling quarter : 

185c 

Meteorological Monitoring 

1 . No later than April 7, 2007 Doe Run will operate all instruments 

necessary to measure the following parameters in accordance with 

manufacturer's instructions as well as the latest version, Vol . IV 

- Meteorological Measurements, Revised EPA/600/R-94/038d (EPA454/R-99-005, Meteorological Monitoring Guidance for Regulatory 

Applications, may also be consulted), until EPA has formally 

redesignated the Herculaneum Lead Nonattainment area as an 

attainment area for lead : 

a . At the River meteorological station : 

i . 10 meter wind speed 

ii . 10 meter wind direction 

iii . 10 meter temperature 

18 
iv . 2 meter temperature 

v . Delta T, 2-10 meters 

vi . Sigma-theta, 10 meters 

vii . Barometric pressure (between 1-6 meters) 

viii . Relative humidity (between 1-6 meters) 

ix . Incoming solar radiation (between 1-6 meters) 

x . Net radiation (between 1-6 meters) 

xi . Precipitation (between 1-6 meters) 

b . At the Broad Street meteorological station : 

i . 2 meter wind speed 

ii . 2 meter wind direction 

iii . 2 meter temperature 

iv . 10 meter wind speed 

v . 10 meter wind direction 

vi . 10 meter temperature 

vii . 40 meter wind speed 

viii . 40 meter wind direction 

ix . 40 meter temperature 

x . Delta T, 2-10 meters 

xi . Delta T, 10-40 meters and 10 meter sigma theta 

xii . Delta T, 2-40 meters and 40 meter sigma theta 

xiii . Barometric pressure (between 1-6 meters) 

xiv . Relative humidity (between 1-6 meters) 

xv . Incoming solar radiation (between 1-6 meters) 

xvi . Net radiation (between 1-6 meters) 

xvii . Precipitation (between 1-6 meters) 

2 . By April 7, 2007, Doe Run will submit a protocol applying to all 

Doe Run meteorological sites (as identified above)to MDNR and EPA. 

Any issues identified by EPA or MDNR following submission will be 

addressed by Doe Run . The protocol will address all elements 

contained in the Doe Run document entitled, "Meteorological QA 

Project Plan", updated on October 1997, in addition to the 

following, applicable to each meteorological site and all 

parameters collected therein: 

a . A quality assurance (QA) and quality control (QC) program in 

accordance with the manufacturer's instructions, in accordance 

with the EPA's Quality Assurance Handbook for Air Pollution 

Measurements, Vol . IV-Meteorological Measurements, Revised 

EPA/600/R-94/038d . 

b . The data from the meteorological monitor shall be continuously 

recorded, reported and processed as fifteen (15) minute and 

one (1) hour averages . 

c . Electronic copies of the fifteen (15) minute and one (1) hour 

averages data for the previous month will be provided to EPA 

no later than the end of each month . 

d . Raw electronic data will be permanently archived . Specific 

sets of raw data will be provided in electronic format to MDNR 

or EPA within 30 days of receipt of written request . 

19 
e . Install, maintain, and respond to an automated alert system 

which will issue an alert when any data are not being 

recorded . 

Weekly reviews of the meteorological data shall be conducted 

by an independent Certified Consulting Meteorologist (CCM) or 

equally qualified individual to identify any potential biases, 

errors, or equipment malfunctions . The independent CCM or 

equally qualified individual shall have the authority to order 

immediate changes in monitoring equipment or procedures to 

rectify any identified issues . Weekly findings summaries will 

be completed and permanently filed . Weekly summaries will be 

provided to MDNR or EPA on request . 

9- Minimum weekly visual observations of equipment . Conduct 

visual checks for debris, verify that the wind vane and wind 

speed propeller are behaving consistently with observed 

conditions . Maintain a log of checks and findings . See 

logsheet example in appendix H . 

h . At least once per month, qualified technicians will visit the 

monitoring site and conduct a visual inspection of all 

sensors . Real-time observation of the data will be viewed and 

compared to visual observations of the sensors . The 

technician will also check for the elements listed in appendix 

H . Should any problems be found, corrective action will be 

taken immediately . If data capture falls below 900, visits 

will become every two weeks . 

i . Quality assurance audits on all instruments will be conducted 

once every three months by a qualified technician using 

calibration devices certified annually to NIST standards . 

Audit findings will be reported to Doe Run within a week of 

the audit . 

k . Doe Run will have a complete unit backup system ready to be 

installed at all times . 

1 . Doe Run will ensure that all sensor and data collection 

problems are rectified no later than 24 hours following 

detection . If Doe Run expects a problem will take longer than 

24 hours to rectify, Doe Run will communicate this to MDNR and 

EPA no later than 24 hours following initial detection, and 

will report the cause for the delay and what they are doing to 

address the situation, and will institute measures to prevent 

such a delay in the future . 

m . Quality assurance audits will be sent to EPA when sent to or 

produced by Doe Run . Data will be provided to MDNR upon 

request . 

185d 

Monitoring for Improvement 

20 
l . By April 7, 2007 operate Teom Total Suspended Particulate (TSP) 

samplers at the Broad Street site and Main Street/City Hall site to 

continuously monitor Total Suspended Particulate in the air . 

Samplers will be operated according to manufacturers specifications 

and audited each quarter with NIST traceable equipment . Samplers 

will be maintained to achieve 90% data capture . 

2 . Air samples from the every 6th day EPA sampling schedule at the 

Broad St . and City Hall monitoring sites will be evaluated to 

determine the total lead concentration . If either of the samples 

records a daily average concentration greater than 1 .5 micrograms 

of lead per cubic meter, then the sample(s) with the concentration 

above 1 .5 micrograms, will be evaluated using a receptor modeling 

technique (e .g . Chemical Mass Balance) . In conjunction with this 

analysis of the lead samples, staff will evaluate the 15-minute 

average Tapered End Oscillating Microbalance (TEOM) data for each 

site that exceeds the 1 .5 microgram threshold to identify periods 

of high particulate loading . Also, the 15-minute average 

meteorological data from the Broad St . meteorological station will 

be analyzed to determine precipitation events and wind speed/wind 

direction for all time periods during the day with special 

attention to period(s) of high particulate loading identified 

above . Production records for each department and any upset 

conditions will be tracked to identify sources of lead emissions 

from the facility . For samples less than 1 .5 micrograms daily 

average lead concentration, staff will conduct the same type of 

,evaluation without the receptor modeling and particulate data 

review (only meteorological data, production records, and upset 

conditions) . This sampling and analyses are designed to provide a 

baseline for plant operation for daily concentrations less than 5 

micrograms of lead per cubic meter . An example of the full 

analysis summary is provided in Appendix N . 

3 . Any air sample at the Broad St . or City Hall monitoring sites with 

a daily average over 5 micrograms of lead per cubic meter will 

undergo the full review prescribed above in (2) . The results of 

this review will include an identification of source(s) or source 

area(s) responsible for the 5 microgram concentration and a record 

of the root cause analysis conducted for this day . The root cause 

analysis will address plant operations/upsets and meteorological 

conditions associated with periods of high particulate loading at 

the TEOM sampler(s) . At a minimum, these analyses will be 

categorized with respect to department and utilized to identify 

sources or source areas for which potential contigency measures 

will be investigated (if necessary) under the 2007 consent 

agreement . 

4 . An Environmental Task Management System will be implemented that 

will include area tasks relating to requirements of the Herculaneum 

State Implementation Plan for Lead . 

5 . Recordkeeping for the Monitoring for Improvement 

a . Sample day chart with Broad Street meteorological data and TSP 

data for the EPA six day sample schedule of each month . See 

appendix N Preliminary example of sample day chart . 

b . Sample day chart with Broad Street meteorological data and TSP 

data for any sample days with equal to or greater than 5 

micrograms of lead per cubic meter of air per day . 

21 
c . operations report for each EPA six day sample schedule of each 

month as well as any days with results of equal to or greater 

than 5 Pb ug/m3/day 

Reporting 

a. a one to two page summary of sample day 

of the first month following the end of the 

quarterly standard monitoring 

that a sample falls late in a 

could not be received in time 

late sample's results will be 

quarterly report . 

Quarterly - submit 

reviews by the end 

period to MDNR . In the event 

quarter and CMB analysis results 

for the quarterly report, the 

included in the following 

Construction guidelines 

For Capital Construction Projects 

1 . Prevention of fugitive dust shall be a consideration in the 

planning of construction projects . 

2 . Where feasible old building components will be cleaned by either 

vacuum or water hose to reduce fugitive emissions prior to removal . 

Additional power washing may be performed once the component has 

been removed to an area where electrical shock or shorting of 

existing equipment can be avoided to assure fugitive emissions do 

not occur during further handling . 

3 . Where feasible both the in house water truck and sweeper truck 

shall be used during construction projects to address dirt stirred 

up by trucks . 

4 . Water hoses/water sprays shall be used to address potential dust 

emissions during excavation should the specific conditions warrant 

their use . 

5 . Excavation materials shall be managed to minimize dust blowing (for 

example, wetting with water hoses, surface treatment with dust 

binder, establishment of vegetation, trapping) . 

Record Keeping - General 

22 
l . Records will be maintained of regularly scheduled quarterly 

inspections made by the environmental department of fugitive 

emissions control equipment such as hoods, air ducts and exhaust 

fans . See Appendix D for diagrams . 

2 . For records during periods of suspension of any work practices an 

entry will be made in the weekly/monthly record after the date that will relate to the following reasons for suspension : "Weather 

suspension", "Equipment repair/maint", "Operations suspension", 

"Rain" etc . 

A . Adverse Weather : 

The work practices that use the application of water as 

described herein may be suspended whenever the application of 

water results in the formation of ice which could result in 

injury to plant personnel . 

The work practices that refer to closure of doors may be 

suspended based on heat alerts as issued for the St . Louis 

area by the National Weather Service or to protect the 

employees from heat stress and heat exhaustion . 

B. RAIN : 

The work practices that refer to water truck, wet sweeping and 

hose down in the yard may be suspended when precipitation has 

resulted in the ground being naturally wetted . 

C . Equipment Maintenance and Repair : 

Sweeping and application of water may also be suspended during 

those periods necessary to perform maintenance and repairs of 

equipment essential to the respective activity . Any 

maintenance and repair work shall be completed as soon as 

possible, and upon completion, the respective activity shall 

-be immediately resumed in accordance with the stated practice . 

D . Suspension of Production Operations : 

When department is down and material is not being conveyed or 

processed . 

E . Suspension of Sweeping : 

When snow or ice interfere with operation of sweeper . 

3 . Records will be maintained of monthly audits conducted by the 

environmental department with those departments who conduct work 

practice controls contained in this manual on a daily or more 

frequent basis . The purpose of the audit is to certify that the 

requirements of the WPM are being followed . 

4 . Records of throughputs will be compiled as follows : 

a . daily records = day shift 5am-5pm report + night shift report 

5pm-5am 

b . 24 hour total = activities occurring from day shift 5am-5pm 

report + night shift report 5pm-5am 

23 
c . MDNR will be notified In the event that shift work hours 

change to a different time frame . 

SUSPENSION OF WORK PRACTICES 

A . Adverse Weather 

The work practices that use the application of water as 

described herein may be suspended whenever the application of water 

results in the formation of ice which could result in injury to 

plant personnel . 

The work practices that refer to closure of doors may be 

suspended based on heat alerts as issued for the St . Louis area by 

the National Weather Service or to protect the employees from heat 

stress and heat exhaustion . 

B . Equipment Maintenance and Repair 

Sweeping and application of water may also be suspended during 

those periods necessary to perform maintenance and repairs of 

equipment essential to the respective activity . Any maintenance 

and repair work shall be completed as soon as possible, and upon 

completion, the respective activity shall be immediately resumed in 

accordance with the stated practice . 

C . Suspension of Production Operations 

In the event that department production operations are suspended 

and shutdown; sweeping and watering applications in the department 

may be suspended for the duration of the such period until normal 

operations are resumed . 

VENTILATION SURVEY 

A . The plant ventilation systems list in the "D" appendices will be 

given a volume survey each calendar quarter . 

B . Volumes recorded will be compared with previous quarters to 

determine need for attention . If the flow rate drops to roughly 

75% of what the approximate flow rate is expected to be, the system 

will be reviewed to see if ventilation ductwork needs cleaning 

attention or maintenance on items such as fan belts, ductwork, 

dampers or fan blades need attention . 

C . Ventilation Systems : 

Name/Location Approx . rate, acfm 

1 . New smooth rolls baghouse 11,000 

2 . CV-10 Grizzly 9,000 

3 . CV-10/CV-11/CV-12 vent 8,000 

4 . CV-13 and CV-14 vent 6,000 

24 
5 . Scale belt vent 11,000 

6 . Crow's nest vent 14,000 

8 . "D" kettle fluxing vent 12,000 

9 . Blast fce front end vent 25,000 

10 . Wheel Tunnel Vent . 15,000 

D . Systems air flow Diagrams - See Appendix D