0211.003 / 17 / 00061525.DOC 2 BERGESON & CAMPBELL, P.C

. 1203 Nineteenth Street, NW | Suite 300 | Washington, DC | 20036-2401 | tel 202.557.3800 | fax 202.557.3836 | web www.lawbc.com

Christopher R. Bryant direct dial 202.557.3818 e-mail cbryant@lawbc.com

June 2, 2010

Via E-Mail

Mr. Charles French Metals and Minerals Group Sector Policies and Program Division Office of Air Quality Planning and Standards U.S. Environmental Protection Agency
109 T.W. Alexander Drive
Mail Code: D243-02 Research Triangle Park, NC 27709

Re: Meeting with RSR Corporation

Dear Mr. French:

On behalf of RSR Corporation (RSR), I write to thank you for meeting with us on May 27, 2010, to discuss the extraordinary reducti ons in emissions of l ead and other hazardous air pollutants that RSR has achieved at its Quemet co, Inc. (Quemetco) s ubsidiary in City of Industry, California. We found the meeting productive and informative and very much appreciate you taking the time to disc uss this important technology with us.

Quemetco’s installation of a Wet Electrostatic Precipitator (WESP) and a Regenerative Thermal Oxidizer (RTO) has yielded dramatic reductions in air emissions from its operations. For example, prior to the insta llation of the WESP and RTO, Quemetco emitted 614.95 pounds of lead annually. After installing th e technology, lead emissions plummeted to 1.22 pounds per year -- a 99.8 percent reduction. Th e table below highlight s equally impressive reductions in other air pollutants at the Quemetco facility.

Pollutant Pre-WESP/RTO
Emissions (lbs/year) Post-WESP/RTO
Emissions (lbs/year) Percent Reduction (%)

Arsenic 96.01 1.59 98.3 1,3-butadiene 2,024.88 16.49 99.2

Cadmium 6.55 0.53 91.9 Chromium (VI) 0.33 0.06 81.8

Dioxins 0.0004 3.83 X 10 -7 99.9 Benzene 1,653.07 681.09 58.8Mr. Charles French June 2, 2010 Page 2

0211.003 / 17 / 00061525.DOC 2 BERGESON & CAMPBELL, P.C.

Pollutant Pre-WESP/RTO
Emissions (lbs/year) Post-WESP/RTO
Emissions (lbs/year) Percent Reduction (%)

Lead 614.95 1.22 99.8 Formaldehyde 5,815.93 179.36 96.9 Acetaldehyde 3,996.93 330.69 91.7

Nickel 7.07 0.18 97.5

RSR’s primary goal in installing this technology was to ensure consistent compliance with the revised National Ambient Air Quality Standard (NAAQS) for lead and to invest in its ability successfully to operate in arguably the most challe nging air district in the nation -- the South Coast Air Quality Management District. RSR could have chosen more conventional -- and less costly -- technology to achieve these ends . And there was appreciable
risk associated with the insta llation of the WESP/RTO technology; this particular configuration and approach had never been successfully implemented before at a secondary lead smelter. After considerable research and analysis, how ever, the company chose the WESP/RTO approach because it believes the technology w ill achieve world class reductions in emissions of lead and other hazardous pollutants from its operations.

The results speak for themselves. The technology is even more effective than the company originally hoped. The substantial reducti ons in emissions listed above means that the
cancer risk attributable to emissions of these compounds was slashed by approximately 87 percent to 2.88 cancer cases in one million exposed individuals ove r a 70-year evaluation period. Because of the overwhelming success of the t echnology, RSR intends to install the WESP/RTO technology at its Indianapolis, In diana, facility this year a nd at its Middletown, New York, facility in 2011.

Meaningful reductions in the residual risks posed by secondary lead smelters are achievable. RSR has proven this with the succe ssful installation of th e WESP/RTO technologies at its operations. As EPA develops the rule making for the Residual Risk Maximum Achievable Control Technology (MACT) rule for secondary l ead smelters, we thus strongly urge EPA to evaluate fully the potential that this technology can bring to bear. EPA need look no further for
its MACT floor.

As you requested, appended are the Quem etco fenceline monitoring data from 2007 (pre-WESP/RTO) and 2009 (pos t-WESP/RTO). After you have had time to review the data, we would welcome the opportunity to visit with you again to answer any questions and to
discuss the data in more detail. I will be in touch shortly to sche dule a follow-up meeting.Mr. Charles French June 2, 2010 Page 3

0211.003 / 17 / 00061525.DOC 2 BERGESON & CAMPBELL, P.C.

Once again, I want to thank you for meeting with us.

Sincerely,

Christopher R. Bryant

Attachment cc: Mr. Robert E. Finn (w /attachment) (via e-mail) Mr. John A. De Paul (w/attachment) (via e-mail) Mr. Homer P. Hine (w/attachment) (via e-mail) Mr. Mike Buckantz (w/attachment) (via e-mail)