1

To: Topham.Nathan@epamail.epa.gov

Subject: RE: Modeling input file for Doe Run

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; 

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 
2

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