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AR226-2210 Robert F Pinchot 11/05/2001 03:02 PM To: cc: Subject: Debbie J Mulrooney/AE/DuPorrt@DuPont, Steven L Grise/AE/DuPorrt@DuPont, Mary A Kaiser/AE/DuPont@DuPont, Ron J Buchanan/AE/DuPontQDuPont, Roger J Zipfel/AE/DuPont@DuPont Ta-Wei Fu/SE/DuPont@DuPont, Bernard J Reilly/AE/DuPont@DuPont, David M Rural</AE/DuPont@DuPont, Chris E Shoop/AE/DuPontQDuPont, Robert L Ritchey/CL/DuPont@DuPont. Charles J Zarzecki/AE/DuPont@DuPont, Stephen T Breske/AE/DuPontQDuPont Mulit Media Consent Order APFO data requirements It looks like we are getting close to agreeing on the requirements for a Consent order between the WV Depl. of Environmental Protection, the WV Department of Health and Human Resources, and DuPont. This order, as many of you know, will require us to submit a lot of data concerning AFPO and our emissions of APFO to the state agencies. To make sure that we all understand our role in getting these data put together and submitting it to the State in the time stated in the order, a lot of coordination needs to be in place. Though the final wording of the order isn't known yet, the following table outlines the requirements, responsibilities, and the tasks to be completed. All items except the Mary Kaiser's analytical work will need to be supplied to the State within 30 days of the effective date of the Consent Order. Summary Requirement Building dimension parameters that have a significant impact on air dispersion 'ermitted allowable emission rates, acutal emissions 2000, stack parameters Phase of APFO at Stack Conditons Particle Characterization Tasks Confirm existing data are complete and accurate Confirm existing data are complete and accurate determine mass fraction particles and mass faction vapor for each stack emitting APFO Determine appropriate particle size classes for modeling based on experimental data collected by Zipfel in 1996 Particle Scavaging Coefficient Vapor Scavaging Coefficient Estimate particle density Develop technically sound basis for the use of the scavaging coefficients in the ISC users Guidance which are based on particle size. Develop technically sound estimate (and document methodology) 'or the vapor scavaging coefficient of APFO as a function of droplet size Lead Responsibility Mulrooney Mulrooney ' Zipfel Mulrooney Mulrooney Grise Grise Other Responsibility Snoop, Fu, Zipfel Shoop, Fu , Zipfel Grise, Fu, Mulrooney Zipfel Zipfel Mulrooney, Zarzecki Others in DuET EID323794 Phase Diagram ofAPFO APFO in water information Head Space GC mesurements Henry's Law Constant Carbon Absorption Data Develop phase diagram or the range of operating conditions. Include critical properties, and )hase transition emperature ranges report, with references, the soluabil'rty and Krafft Point of APFO in aqueous solutions and measured pK value. 3evelop analytical method to detect AFPO in gas phase above an aqueous solution of APFO. Measure the concentrations at operating conditions. As a function of Temperature and a discussion of its dependence on pH Any isotherms for the absorption of APFO onto carbon from aqueous solutions Grise t Grise Kaiser Pinchol (I'll provide the operating conditions to be analyzed in a separate note) Grise Buchanan Breske, Zipfel Since we don't have a lot of time, 1will be checking on progress weekly. Please get all the data to me and I will work with our legal representation to develop the communication package(s) that we send. I will let you know when the effective date of the consent order as soon it is signed by all parties. If there are any questions, please do not hesitate to call. Thanks, Rob EID323795