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:
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 & Safety DAY.

901 LAKESIDE AVENUE CLEVELAND, OHIO 44114

DIRECT 216.586.7542 • FAX 216.579.0212•

JREGO@JONESDAY.COM

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