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 docket2 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