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Fact Sheet

October 2010

Public Meeting for RCRA Administrative Orders Announced, The Doe Run Resources Corporation, St. Louis, Missouri


On September 1, 2010, The Doe Run Resources Corporation (Doe Run) signed an Administrative Order on Consent (AOC) and a modification to an existing Transportation AOC. The modification requires additional work practices related to the company's handling and transportation of lead materials. The new AOC sets out specific procedures for continued yard cleanups. Both agreements are being issued under Section 7003 of the Resource Conservation and Recovery Act (RCRA).

EPA invites the public to comment on the modification of the Transportation Administrative Order on Consent and the new Administrative Order on Consent for soils. The 30-day public comment period opens on October 21 and runs through November 22, 2010.


Doe Run produces lead and other metals from the New Lead Belt or the Viburnum Trend in southeast Missouri. Production began in the mid-1960s and continues to this day. Ore from the mines is crushed, milled and processed to form lead and other metal concentrates. Lead concentrate commonly contains lead at levels greater than 70 percent (700,000 parts per million). This lead concentrate is trucked over public roadways to the Herculaneum smelter for processing or trucked to the Southeast Missouri Regional Port Authority near Cape Girardeau for shipment overseas.

Plan to Attend Public Meeting

You are invited to attend a public meeting to discuss the administrative orders between EPA and Doe Run. The meeting has been scheduled for Tuesday, November 9, 2010, beginning at 7 p.m. at the:

Senn-Thomas Middle School Gymnasium
200 Senn-Thomas Dr.
Herculaneum, Missouri

If you have questions about the meeting, please contact:

Beckie Himes
Community Involvement Coordinator
Office of Public Affairs
U.S. EPA Region 7
901 No. 5th Street
Kansas City, Kansas 66101
Phone: (913) 551-7253
Toll Free: (800) 223-0425

EPA Region 7 is committed to providing reasonable accommodation to individuals with disabilities. If you require a reasonable accommodation to participate in the meeting, please notify the EPA Reasonable Accommodations Coordinator, Jonathan Cooper, 800-223-0425 or at cooper.jonathan@epa.gov. Speech or hearing impaired individuals should e-mail or call using the local relay service.


Since 2001, EPA, the Missouri Department of Natural Resources (MDNR) and Doe Run have entered into several agreements designed to address lead contamination associated with operations at Doe Run facilities located in southeast Missouri. As a result of these agreements, Doe Run has installed air controls, cleaned up residential properties, sampled soils, and conducted investigations.

Through oversight of Doe Run's work, EPA and MDNR have collected samples from haul roads in Herculaneum and along other trucking routes which confirm high lead levels on road surfaces, road shoulders and adjacent residential yards. In response, EPA required Doe Run to develop and implement a Smelter Transportation and Materials Handling Plan to minimize the release of lead along haul routes. EPA approved Doe Run's transportation plan in July 2003.

The plan set forth, among other practices, operation of an automated undercarriage truck wash for vehicles to use prior to leaving the smelter, operation of dry street sweepers within Herculaneum and a spill response policy.

Despite these practices, sampling evidence indicated that lead-bearing trucks continued to contaminate roads in southeast Missouri. An AOC was issued in May 2007, to address these ongoing transportation issues. This Transportation AOC required Doe Run to install vehicle wash stations, perform roadway and street washing, enclose materials during transit, wash and inspect trucks daily, collect samples from trucks and residential properties along haul routes and provide reports of these activities to EPA.

In August through October 2008, EPA inspected Doe Run's implementation of the Transportation AOC and discovered significant violations of that Order. EPA finalized a report of these inspection activities in October 2009, and subsequently issued a modification to the Transportation AOC.


EPA has continued to monitor soil lead levels in previously excavated residential yards within Herculaneum. Recent trend analysis of the soil data monitored by EPA, completed in July 2009, for 13 properties up to 0.75 miles from the Doe Run facility, demonstrated a statistically significant upward trend in lead levels in residential surface soils for all of the properties analyzed.

In July 2009, EPA ordered Doe Run to sample all residential properties within 1 mile of the lead smelter. ;The results of this sampling, provided to EPA by Doe Run in October 2009, indicated that 129 properties, out of 372 sampled had lead soil concentrations in at least one sample greater than EPA's level of concern of 400 parts per million (ppm). One hundred four of these properties had already been cleaned up at least once by Doe Run. These data results confirm the upward trend in soil lead levels in residential yards in Herculaneum.


Lead concentrate that settles on roads along haul routes can be tracked beyond the roads into adjacent residential yards and homes. In addition, lead emissions from the Herculaneum smelter can settle in residential yards contaminating the yards and homes of residents. Exposure of young children to lead can cause adverse health effects including slowed physical growth; hearing problems; learning difficulties; behavior problems; and decreased intelligence.


Doe Run has agreed to implement additional specific work practices through a modification to the existing Transportation AOC in an effort to further reduce lead releases to public roads from its transportation activities. These work practices include the following:

Inspection/Washing Procedures – Doe Run will implement improved truck inspection and washing procedures for all trucks hauling lead materials to and from their facilities. Revised standard operating procedures (SOPs) have been developed for inspection and washing of trucks. These new SOPs will be implemented on the Effective Date of the modification of the Transportation AOC.

Independent Audits – Doe Run will hire an independent contractor to audit the inspection and washing requirements of the AOC on an annual basis for each facility covered by the Transportation AOC.

Handling and Transportation Study – Doe Run will hire a contractor to perform a Concentrate Handling and Transportation System Engineering Study. This study will benchmark Doe Run's current transportation operations, evaluate transportation operations at other similar facilities, and evaluate opportunities for improvement to its transportation operations.

Sampling and Reports – Doe Run will perform additional residential sampling and submit monthly reports so that EPA may monitor whether these measures are working.


Doe Run will initially sample all residential properties within 1.5 miles of the Herculaneum lead smelter. In addition, all properties that have soil lead concentrations greater than 200 ppm will be sampled annually thereafter. After the lead smelter facility has ceased operation and the smelter facility is cleaned up, all residential properties within 1.5 miles of the facility will be sampled one last time. During any of these sampling activities if a property has soil lead concentrations greater than or equal to 400 ppm, the property will be cleaned up.


On October 8, 2010, the United States lodged a Consent Decree with Doe Run to resolve violations of RCRA; the Clean Air Act; Clean Water Act; Emergency Planning and Community Right-to-Know Act; Comprehensive Environmental Response, Compensation and Liability Act; and State law at several Doe Run facilities. Doe Run has agreed to perform many response actions and pay a civil penalty to resolve these violations. A separate notice and comment period on the Consent Decree is being conducted by the Department of Justice. The new Soils Order and the modification of the Transportation Order were included as part of this larger settlement. The modification of the Transportation Order is included as part of the Consent Decree.


EPA has established an Administrative Record which includes a copy of the modification of the transportation Administrative Order on Consent, the new Administrative Order on Consent for soils, and other relevant documents. The Administrative Record is available for review during normal business hours at the following locations:

Herculaneum City Hall
1 Parkwood Court
Herculaneum, Missouri

Viburnum City Hall
#1 Missouri Avenue
Viburnum, Missouri

Windsor Branch
Jefferson County Library
7479 Metropolitan Blvd.
Barnhart, Missouri

U.S. EPA Region 7
Records Center
901 North 5th Street
Kansas City, Kansas

Again, EPA invites the public to comment on the modification of the Transportation Administrative Order on Consent and the new Administrative Order on Consent for soils. The 30-day public comment period opens on October 21 and runs through November 22, 2010.

Written comments, postmarked no later than November 22, 2010, should be directed to Beckie Himes at the address shown below. EPA will consider all comments submitted during the public comment period and determine whether it is appropriate for EPA to sign and finalize the modification and the Administrative Order on Consent.


If you have questions or need additional information, please contact:

James Aycock
Environmental Scientist
Waste Enforcement and Materials Management Branch
U.S. EPA Region 7
901 North 5th Street
Kansas City, Kansas 66101
Phone: (913) 551-7887
E-mail: aycock.jim@epa.gov

Beckie Himes
Community Involvement Coordinator
Office of Public Affairs
U.S. EPA Region 7
901 North 5th Street
Kansas City, Kansas 66101
Phone: (913) 551-7253 or
Toll Free: (800) 223-0425
E-mail: himes.beckie@epa.gov


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