RE: Ferroalloys NESHAP-- Fugitive PM Emission Factors John Rego to: Beth Friedman
09/12/2012 02:26 PM Cc Conrad Chin, Jeff.McKinney, Imcafee, nelson.brad, rkemp, Chuck French Beth: EMI has reviewed guidance document referenced below. Based on our conference call of August 27, 2012, EMI’s understanding

is that while EPA intends
to apply the AP-42 fugitive emission factors for BOF tapping and hot metal transfer, rather than applying the factors specified for fugitive emissions
“at the building monitor,” EPA intends
to apply averages
of those factors and the corresponding factors for emissions
“at the source.” Having reviewed the guidance document, EMI does not believe that the averaging approach

is technically justified. The EPA experts most familiar with all of the referenced studies and data, not just summary notes in Table

7 of the guidance document, determined that the data was sufficient

to derive separate emission factors for each process. EMI does not believe identified document provides

a technical basis for EC/R to effectively substitute
its judgment for that of the EPA authors from 1979 and 1995.

If there is additional material upon which EC/R relied to conclude that EMI’s fugitive emissions from its building monitors 100’ above grade should not be modeled using the AP-42 factors for emissions
“at the building monitor,” EMI would like to review that information and might reconsider
it’s view. EMI appreciates EPA’s willingness

to explain its approach. Since EMI has not yet had an opportunity

to comment
on EPA’s revised emissions dataset, and EMI does not know whether EPA intends
to make any revisions

to its AERMOD modeling/risk assessment assumptions,

it’s not possible

to know whether the averaging approach will impact the ultimate residual risk conclusions. However, EMI believes that by applying the factors as specified

in AP-42, EPA can eliminate

a possible need to revisit the emissions dataset later in the process when available time may be very limited. Please let me know
if further discussion might be helpful. Thanks, John John Rego• Environmental, Health

& Safety JAY. 901 LAKESIDE AVENUE• CLEVELAND, OHIO 44114 DIRECT 216.586.7542• FAX 216.579.0212. JREGO@JONESDAY.COM From: “Beth Friedman” <friedman.beth@ecrweb.com> To: “John Rego” <jrego@JonesDay.com>, “Conrad Chin” <Chin.Conradepamail.epa.gov> Cc: <Jeff. McKinney©erametgroup.com>, <nelson. brad@ecrweb.com>, <lmcafee@bdlaw.com>, <RLunn@fpiwv.com>, <rkemp@environcorp.com> Date: 08/27/2012 01:44 PM Subje RE: Ferroalloys NESHAP-- Fugitive PM Emission Factors Ct:Here’s the link to the background documents

in Chapter 12. Go to Section s05 and look for Reference

3. http://www.epa.gov/ttn/chief/old/ap42fchl2/ Be From: John Rego [maifto:jregoJonesDay.comj Sent: Thursday, August 23, 2012 5:27 PM To: Conrad Chin Cc: Beth Friedman; Jeff. Mckinney@erametgroup.com;
nelson. brad@ecrweb.com; lmcafeebdlaw.com; RLunn@fpiwv.com; rkemp@environcorp.com Subject: Ferroalloys NESHAP-- Fugitive PM Emission Factors Conrad: EMI and Felman are available for a call next week to discuss EPA’s selection
of fugitive PM emission factors for tapping and casting during any of the following: Monday (8/27) between
10 AM and

3 PM Tuesday (8/28) between

1 PM and
2 PM or between

3 PM and 4 PM Wednesday (8/29) between
10 AM and

3 PM Also,

I noted
in Beth Friedman’s summary
of the July 16, 2012 source control meeting that EPA was/is working on a hood capture performance standard that would be different from (or maybe
in addition to) the face velocity approach we proposed.

I would be interested

in hearing more about the status of that analysis on next week’s call, if possible. Let me know
if one of the times identified above will work for RTP. Thanks, John jc-s John Rego• Environmental, Health

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