From: 

"Teresa S. Bowers" <TBOWERS@gradientcorp.com> 

To: 

Mark Morris/RTP/USEPA/US@EPA, "Stotts, Stacy" <SStotts@stinson.com>, "Marucheau, 

Louis" <lmarucheau@doerun.com>, 

"'Miller, Aaron'" <amiller@doerun.com>, Joe Stolle <joseph@shellengr.com>, Nathan 

Topham/RTP/USEPA/US@EPA, Michael 

Stewart/RTP/USEPA/US@EPA, Sharon Nizich/RTP/USEPA/US@EPA, Dave 

Guinnup/RTP/USEPA/US@EPA, Steve 

Fruh/RTP/USEPA/US@EPA, Jan Tierney/DC/USEPA/US@EPA, Ted Palma/RTP/USEPA/US@EPA, 

Richard 

Daye/R7/USEPA/US@EPA, "bern.johnson@dnr.mo.gov" <bern.johnson@dnr.mo.gov> 

Date: 

04/08/2011 12:53 PM 

Subject

: 

RE: Modeling input file for Doe Run

I'm glad the file was helpful. In answer to your specific questions: 

The 2009 information is the most recent that we have, and we believe it is 

equivalent to the current situation. 

There are houses within the buyout area where the owners have refused to be 

bought out. They still own, and in many cases, are still living, in those 

houses. There are additional non-residential parcels within the buyout area 

that were not eligible for the buyout program, for example, vacant lots, some 

storage buildings, a couple churches. 

We do not have a single polygon file for the entire property, we only have 

what we sent you. 

Terri 

Teresa S. Bowers, Ph.D. | Gradient 

-----Original Message----- 

From: Morris.Mark@epamail.epa.gov [mailto:Morris.Mark@epamail.epa.gov] 

Sent: Friday, April 08, 2011 11:52 AM 

To: Teresa S. Bowers; Stotts, Stacy; Marucheau, Louis; 'Miller, Aaron'; Joe 

Stolle; Topham.Nathan@epamail.epa.gov; Stewart.Michael@epamail.epa.gov; 

Nizich.Sharon@epamail.epa.gov; Guinnup.Dave@epamail.epa.gov; 

Fruh.Steve@epamail.epa.gov; tierney.jan@epamail.epa.gov; 

Palma.Ted@epamail.epa.gov; Daye.Richard@epamail.epa.gov; 

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bern.johnson@dnr.mo.gov 

Subject: Modeling input file for Doe Run 

Hello, everyone. Thanks, Terri, for sending the shapefile of Doe Run's 

property boundary. We have a couple of questions about it. First, the date 

of the boundary seems to be 2009. Is it the most current? Also, there seem to 

be gaps in the buyout area west of the facility. Are there parcels of land 

that were not part of the buyout and, if so, is there any population still in 

those areas? Do you have a single polygon file that encompasses the entire 

property? 

As discussed in the meeting between Doe Run and EPA on March 29, we used the 

Human Exposure Model (which includes AERMOD as its dispersion model) to 

estimate concentrations of lead and other HAPs for the purposes of our Risk 

and Technology Review for the Primary Lead Smelting source category. The 

draft risk document (in the docket) states that we calculated 3-month rolling 

averages for lead to compare to the lead NAAQS. The docket includes all the 

emission source data (locations, emissions, release parameters), and the risk 

document discusses the modeling choices made and the receptors and 

meteorological data used. 

The docket does not include the AERMOD input or output files created within 

HEM. We described in the March 29th meeting that, although HEM is not 

designed to calculate the monthly averages needed to calculate 3-month rolling 

averages, monthly averages can nonetheless be calculated in HEM by excluding 

emissions for all months except the month of interest. We did 12 HEM runs in 

this way to calculate monthly concentrations for an entire year. Although 

specific details of these model runs are not included in the docket, the 

monthly average concentrations can be recreated with HEM or by using AERMOD 

independent of HEM using information available in the docket. In a follow-up 

meeting on April 5, we stated that we had done such a recreation using only 

AERMOD, and that we would provide that AERMOD input file. The attached AERMOD 

input file was created using: 1) emissions source data from the docket for 

significant sources (those contributing 97% of the total emissions), 2) nearby 

receptors (HEM automatically selects Census block centroids as receptors and 

creates a polar grid; these were imported into AERMOD and used as receptors, 

along with the boundary receptors shown on a map in the risk document), and 3) 

one year (1998) of the site-specific met data supplied by the State of 

Missouri. 

We conclude that the docket has sufficient information to recreate our 

results. Although the specific AERMOD input and output files created by the 

HEM model were not included in the docket, the HEM model inputs and results 

were. We are providing the attached AERMOD input files not because we 

conclude that the docket is incomplete, but to demonstrate that it is 

relatively easy to recreate our results using AERMOD alone with the input data 

and choices we have documented. 

Thanks. 

(See attached file: DOERUN.ROU)(See attached file: DoeRun.ADI) 

Mark Morris 

USEPA 

Mailcode C539-02 

109 TW Alexander Drive 

RTP, NC 27711 

(919) 541-5416 

morris.mark@epa.gov

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