# Attachment 1

July 12, 2012 email to Darcie Smith (minus the referenced modeling file attachments)

regarding the revised risk estimates resu lting from the revise d emissions inventory

developed in accordance with AP-42 emission factorsSubject: Proposed Ferrolloys NESHAP , additional data regarding updated ErametMarietta modelFrom: John Rego 07/12/2012 05:15 PMExtension: 67542 (within JD)216-586-7542 (outside JD)To: Smith.DarcieCc: Jeff.McKinney, rkempBcc: alincoln, thillier, John.Willoughby,jskonrady, Gregory.TimmonsMs. Smith:As you requested, I am forwarding the input and output files for the modeling of the updated "base case" (i.e., current emissions), as described insection I.B and Appendix B of my July 2, 2012 submittal to Messrs. French and Chin My understanding is that the updated modelyields thefollowing results:Exposure Scenario(EPA model with various revisions)Maximum Off-Site ManganeseHQ atVarious ReferenceConcentration (RfC) ValuesParkersburgMeteorologicalDataRespirable(PM2.5) OnlyExposureCorrected forTime Indoors andAway From HomeEMIFugitiveSourceControlsHighestCalculatedOff-SiteManganeseConcentration(ug/m3)0.05ug/m30.1ug/m30.5ug/m31ug/m32ug/m3●0.27530.50.30.1●●0.11210.20.10.06●●●0.0710.70.10.070.04●●0.145310.30.10.07●●●0.05510.60.10.060.03●●●●0.0330.60.30.060.030.02In addition, EMI asked Gradient to compare the results of the updated base case model to recently released ambient manganese PM2.5datacollected in Marietta in 2009 and 2010 to see how results from the updated model compare to directly measured conditions. In Haynes, 

# et al.,“Assessment of personal exposure to manganese in children living near a ferromanganese refinery,” Sci. Total Environ. (2012), doi :10.1016/scitotenv. 2012.03.037, the authors reported manganese PM2.5data collected from a stationary air sampler placed on a building at MariettaCollege (UTM coordinates: X= 461,343; Y= 4,363,098) “in the highest population density area within the community [to provide]an exposurescenario experienced by a majority of the study participants.”Haynes, 

# et al. reported ( 

# seeTable 2 of the manuscript) directly measured concentrations of manganese as PM2.5during April-May 2009 andduring March-June 2010. When ambient manganese PM2.5concentrations are modeled for the Marietta College location during these time periodsusing the updated baseline model parameters and emissions dataset presented in EMI’s July 2, 2010 submittal, along with EPA’s 41% “TotalPM-to-PM2.5” factor, there is excellent agreement between the modeled data and the measured data: 6.6 ng/m3manganese PM2.5(modeled) vs. 5.5ng/m3manganese PM2.5(measured) during April-May 2009 and 9.8 ng/m3manganese PM2.5(modeled) vs. 10.3 ng/m3manganese PM2.5(measured)during March-June 2010. The input and output files from which the modeled concentrations were derived are also attached.Conversely, however, use of the point and area source emissions estimates from EPA’s draft AERMOD modeling of EMI’s emissions forthe proposed residual risk assessment -- even with the more relevant Parkersburg, WV meteorological data and the 41% “Total PM-to-PM2.5”adjustment -- yields modeled concentrations that are more than three times larger than what actually was measured in Marietta:19 ng/m3manganese PM2.5(modeled) vs. 5.5 ng/m3manganese PM2.5(measured) during April-May 2009 and 33 ng/m3manganese PM2.5(modeled) vs. 10.3ng/m3manganese PM2.5(measured) during March-June 2010. Thus, the newly released Haynes, 

# et al. data supports EMI’s revisions to the draftmodel parameters and baseline emissions dataset.Let me know if you have any additional questions.John Rego•Environmental, Health & Safety901 LAKESIDE AVENUE • CLEVELAND, OHIO 44114DIRECT216.586.7542 •FAX216.579.0212 •JREGO@JONESDAY.COMEramet_6-19-12 Base_Parkersburg_5yr.LSTEramet_6-19-12 Base_Parkersburg_5yr.DTAEramet_6-19-12 Haynes_Base_10.LSTEramet_6-19-12 Haynes_Base_10.LSTEramet_6-19-12 Haynes_ Base_09.dtaEramet_6-19-12 Haynes_ Base_09.dtaEramet_6-19-12 Haynes_Base_09.LSTEramet_6-19-12 Haynes_Base_10.dta==========This e-mail (including any attachments) may contain information that is private, confidential, or protected by attorney-clientor other privilege. If youreceived this e-mail in error, please delete it from your system without copying it and notify sender by reply e-mail, so thatour records can becorrected.==========

# Attachment 2

Figures presenting modeled PM 2.5 

# manganese emissions concentration contours

from two periods in 2009-10 when ambient manganese PM 2.5 

# data were collected

at Marietta CollegeGradient1Figure 1. Contours of Modeled Average Air Concentrations of Manganese (ng/m3): Base Case Emissions- adjusted for PM2.5, for the period AprilMay 2009430000 440000 450000 460000 470000 480000UTM East (meters)4350000436000043700004380000

U T M North (meters)MariettaCollegeGradient2Figure 2. Contours of Modeled AverageAir Concentrations of Manganese (ng/m3): Base Case Emissions- adjusted for PM2.5, for the PeriodMarch-June 2010430000 440000 450000 460000 470000 480000UTM East(meters)4350000436000043700004380000

UTM North (meters)MariettaCollege

# Attachment 3

July 12, 2012 correspondence to Darcie Smith and Kelly Rimer

addressing modeling and ri sk assessment issues

discussed at a June 14, 2012 meeting at RTP