Attachment 1 

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

 regarding the revised risk estimates resulting from the revised emissions inventory 

developed in accordance with AP-42 emission factors 

 
Subject: Proposed Ferrolloys NESHAP , additional data regarding updated Eramet 

Marietta model

From: John Rego 07/12/2012 05:15 PM

Extension: 67542 (within JD) 

216-586-7542 (outside JD)

To: Smith.DarcieCc: Jeff.McKinney, rkempBcc: alincoln, thillier, John.Willoughby, jskonrady, Gregory.Timmons

Ms. Smith:As you requested, I am forwarding the input and output files for the modeling of the updated "base case" (i.e., current emisssection I.B and Appendix B of my July 2, 2012 submittal to Messrs. French and Chin My understanding is that the updated following results:

Exposure Scenario

(EPA model with various revisions)

Maximum Off-Site Manganes

HQ at

Various Reference 

Concentration (RfC) Values

Parkersburg 

Meteorological 

Data

Respirable 

(PM2.5) Only

Exposure 

Corrected for 

Time Indoors and 

Away From Home

EMI 

Fugitive 

Source 

Controls

Highest 

Calculated 

Off-Site 

Manganese 

Concentration

(ug/m3

)

0.05 

ug/m3

0.1 

ug/m3

0.5 

ug/m3

1 

ug/m3

2 

ug/

● 0.27 5 3 0.5 0.3 0.● ● 0.11 2 1 0.2 0.1 0.0● ● ● 0.07 1 0.7 0.1 0.07 0.0● ● 0.145 3 1 0.3 0.1 0.0● ● ● 0.055 1 0.6 0.1 0.06 0.0● ● ● ● 0.033 0.6 0.3 0.06 0.03 0.0
In addition, EMI asked Gradient to compare the results of the updated base case model to recently released ambie

collected in Marietta in 2009 and 2010 to see how results from the updated model compare to directly measured conditions

“Assessment of personal exposure to manganese in children living near a ferromanganese refinery,” Sci. Total Environ. (2010.1016/scitotenv. 2012.03.037, the authors reported manganese PM2.5 data collected from a stationary air sampler placed 

College (UTM coordinates: X= 461,343; Y= 4,363,098) “in the highest population density area within the community [to pro

scenario experienced by a majority of the study participants.”

Haynes, et al. reported (see Table 2 of the manuscript) directly measured concentrations of manganese as PM2.5 d

during March-June 2010. When ambient manganese PM2.5 concentrations are modeled for the Marietta College location du

using the updated baseline model parameters and emissions dataset presented in EMI’s July 2, 2010 submittal, along with PM-to-PM2.5” factor, there is excellent agreement between the modeled data and the measured data: 6.6 ng/m3 manganese 

ng/m3 manganese PM2.5 (measured) during April-May 2009 and 9.8 ng/m3 manganese PM2.5 (modeled) vs. 10.3 ng/m3 mang

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 o

the proposed residual risk assessment -- even with the more relevant Parkersburg, WV meteorological data and the 41% “T

adjustment -- yields modeled concentrations that are more than three times larger than what actually was measured in Marmanganese PM2.5 (modeled) vs. 5.5 ng/m3 manganese PM2.5 (measured) during April-May 2009 and 33 ng/m3 manganese P

ng/m3 manganese PM2.5 (measured) during March-June 2010. Thus, the newly released Haynes, et al. data supports EMI’s model parameters and baseline emissions dataset.

Let me know if you have any additional questions.

John Rego • Environmental, Health & Safety901 LAKESIDE AVENUE • CLEVELAND, OHIO 44114 DIRECT 216.586.7542 • FAX 216.579.0212 • JREGO@JONESDAY.COM

 Eramet_6-19-12 Base_Parkersburg_5yr.LST Eramet_6-19-12 Base_Parkersburg_5yr.DTA  Eramet_6-19-12 Haynes_Base_10.LST Eramet_6-19-12 Haynes_Base_10.LST Eramet_6-19-12 Haynes_ Base_09.dta Eramet_6-19-12 Haynes_ Base_09.dta Eramet_6-19-12 Haynes_Base_09.LST 

 Eramet_6-19-12 Haynes_Base_10.dta 
==========

This e-mail (including any attachments) may contain information that is private, confidential, or protected by attorney-client received this e-mail in error, please delete it from your system without copying it and notify sender by reply e-mail, so that ocorrected.==========
Attachment 2 

Figures presenting modeled PM2.5 manganese emissions concentration contours 

from two periods in 2009-10 when ambient manganese PM2.5 data were collected 

at Marietta College 

 
Gradient 

Figure 1. Contours of Modeled Average Air Concentrations of Manganese (ng/m3): Base Case Emissions- adjusted for PM

May 2009 

430000 440000 450000 460000 470000 480

UTM East (meters)

4350000436000043700004380000

UTM North (meters) Marietta College 
Gradient 

Figure 2. Contours of Modeled Average Air Concentrations of Manganese (ng/m3): Base Case Emissions- adjusted fo

March-June 2010 

430000 440000 450000 460000 470000 4

UTM East (meters)

4350000436000043700004380000

UTM North (meters) Marietta College 
Attachment 3 

July 12, 2012 correspondence to Darcie Smith and Kelly Rimer 

addressing modeling and risk assessment issues 

discussed at a June 14, 2012 meeting at RTP