From: <French.Chuck@epamail.epa.gov>

To: <jlanzafame@doerun.com>

CC: Donna Lazzari <Donna.Lazzari@erg.com>, <michael.burr@erg.com>, 

<Topham.Nathan@epamail.epa.gov>

Date: 1/31/2011 5:43 PM

Subject: Secondary Lead Smelters - Fugitive lead emissions and ICR responses

Dear Mr. Lanzafame,

 Thank you for the information and data that you submitted to us in

response to the information collection request letters that we sent you

in June and July of 2010. The data and information are very helpful for

our risk and technology review of the Secondary Lead Smelting source

category. We have been using much of the data and information in our

analyses as you reported.

 However, with regard to the estimates of fugitive emissions,

because of complexities of estimating these emissions, the data gaps and

incomplete information, and various uncertainties, we determined that it

was appropriate to gather additional information and conduct

supplemental analyses to calculate revised draft estimates of fugitive

emissions for some of the facilities.

 As you know, in the section 114 survey, we requested information

for stack and fugitive emissions from the Secondary Lead Smelting

facilities. We are now in the process of conducting dispersion modeling

of the emission estimates. In some instances, we have found a

discrepancy between the preliminary results of the dispersion model and

the values recorded at local ambient monitors which cannot be accounted

for by the stack and fugitive emissions reported. EPA assumes the stack

emissions are generally reliable as they are based on actual test data,

and the primary cause of the discrepancy is due to releases of fugitive

emissions. In the survey, Doe Run provided estimates for roadway

fugitives, but did not provide an estimate for the other possible

sources of fugitive emissions (such as fugitives from storage piles,

slag handling, fugitives which escape from buildings, etc.).

 Therefore, we have derived a draft estimate of fugitive emissions

for your facility based upon a review of the ICR responses and industry

practices and calculation methodologies. We have taken into account the

size of the facility, the degree to which the facility is contained

within enclosures, and the reported work practices described in your

survey. Moreover, we analyzed available ambient monitoring data near

the facility in relation to initial preliminary modeling estimates.

 The draft estimate we have calculated for fugitive emissions for

your facility and the original estimate you provided in the survey are

provided here:

Buick Resource Recycling Facility:
 1. Estimate of fugitive lead emissions provided in your survey

response = 0.02 tons per year (for roadways)

 2. EPA draft estimate of total fugitive lead emissions for this

facility = 3.13 tons per year

 Anyway, with this email we are providing you an opportunity to

comment on our revised estimates, provide calculations and documentation

to support your original estimates, or provide alternative estimates

that you believe are more accurate. If you suggest alternative

estimates, please provide complete documentation and explanation of the

basis of such alternatives. If you would like to comment or provide

additional information or alternative estimates, please send a response

to this email by February 7th, 2011.

 Thank You,

 Chuck French, Environmental Scientist,

 U.S. EPA, Office of Air Quality Planning and Standards,

Sector Policies and Program Division

 Phone: 919-541-7912