Document 1ga3kdmK4vp6y6DEEvKopYkbd

DuPont Fluoroproducts AR226-2342 DuPont Fluoroproducts Chestnut Run Plaza P.O. Box 80711 Wilmington, DE 19880-0711 October 20,2003 Document Control Office (DCO) Office of Pollution Prevention and Toxics (OPPT) US Environmental Protection Agency EPA East, Room 6428 1201 Constitution Avenue, NW Washington, DC 20460 VIA OVERNIGHT MAIL Attention: Docket No. AR-226 and/or OPPT-2003-0012 Re: Follow-up to September 15,2003 Submission ofDuPont Progress Report on Environmental Assessments Pursuant to the APPO Users LOI dated March 14, 2003: Air Dispersion Modeling Reports Dear Sir/Madam: Further to my letter of September 1-5,2003 (referenced above) and DuPont commitments made in the above-identified LOI, air dispersion modeling, based upon year 2002 air emissions for the Washington Works facility and using the EPA approved Industrial Source Complex Short Term 3 (ISCST3) model, as described in the APFO Useis LOI, has been completed. The report is included as Attachment 1. These modeled results are presented solely for the purpose of establishing a baseline year by which future reductions in air emissions can be compared. Verification of the air model on which these results are based is planned to begin shortly. In addition, air dispersion modeling based upon air emissions from September 2002 through August 2003 has also been conducted, per request of the West Virginia Department of Environmental Protection. Those results are reported in Attachment 2. The modeled air emissions for this time period are reduced in comparison to the modeled air emissions for baseline year 2002- The reduction in air emissions is primarily due to the addition, in May 2002, of a secondary recovery scrubber to the largest single emission point. The previously existing packed-bed scrubber collected 50% of the emitted material- The new device uses a deep- bed fiber system to collect fine particles that were not collected by the existing scrubberThe recovery efficiency, measured across both devices, has been demonstrated to be 98% or greater. ASH027173 EID780453 EID780453 Document Control Office Office of Pollution Prevention and Toxics Page 2 October 20, 2003 Additional reductions in air emissions resulted from improvements applied to scrubbers on other significant emission points. A DuPont study identified improvements to scrubber operating parameters and changes to control strategies that can allow efficiencies to improve from 75% - 85% to 90% or better. If you need farther clarification on the information presented with this letter, please contact me at the number provided below. Very truly yours, Attachments (2) David M. Rurak Safety, Health, and Enviroiunenlal Manager Global Business Manager, APFO DuPont PIooroproducts CKPBld.71IG2IO-C P.O. Box 80711 Wilmington, Delaware 19880-0711 302-999-2415 (phone) 302-999-3095 (fax) E-mail: Pavid.M.RuraIaShisa.dupont.com cc: Mary Dominiak, EPA (via overnight mail) U.S. Environmental Protection Agency Office of Pollution Prevention and Toxics EPA East, Room 4410 1201 Constitution Avenue, NW Washington, DC 20460 564-4760 ASH027174 EID780454 EID780454