Document K2LxQoMVL1G3v6dDJz29v0QK

03/13/2003 10:06 oa/ia/oa os:09 UU DEP LEGAL SERUICES -> 915133010205 NO.129 304 026 8738 WV AIR QUALITY At.*a _ i? 0 5 002 @002 Division of A ir Quality 7012 MacCorkle Avenue. South E*n Charleston, W V 25304-2943 Telephone Number: (304) 926-3727' _______Fax Number: (304) 926-3739 W est Virginia Department of Environmental Protection Bob Wise Governor Stephanie R- Ttmmenneyer Amlng Cabinet Secretary Paul J. Bossert Jr. Plant Manager DuPont Washington Works P. O. Box 1217 Parkersburg, WV 26102-1217 Dear Mr. Bossert: March 13, 2003 C E R T IF IE D MAIL 7002 0860 0001 4581 3412 * RE: Additional Obligations Notice E.l. DuPont do Nemours & Co.. Inc. Washington Works GWR-2001-019 ' Plant ID No. 107-00001 The West Virginia Department of Environmental Protection's Division of Air Quality (DAO) is hereby providing notice to DuPont, Washington Works, of the implementation of the provisional air screening level of 1.0 mlcrogram per cubic meter (pg/m3) ammonium perfluorooctanoate (C8) concentration as developed by the C8 A ssessm ent of Toxicity (CAT) Team pursuant to Attachment C of Consent Order GWR2001-019. The emissions by DuPont are not to exceed the screening level in areas accessible to the public. As stated in the Consent Order, the air screening level adopted by the CAT Team wilt be the basis for compliance until such time as the United States Environmental Protection Agency promulgates A standard for C3. Section XI (l.a.) of the Order requires DuPont to limit exposure of C8 to no more than the 1 pg/m3screening level. The DAQ will require DuPont to limit Its emissions, as determined by modeling, to no more than 1.0 mlcrogram per cubic meter in ambient air as defined by 40 CFR Part 50.1 (e). Ambient Air is generally considered to include alt areas outside the plant fence line or not otherwise subject to controlled access by DuPont. Compliance shall be demonstrated by use of Air Dispersion Modeling in accordance with Appendix W to 40 CFR Part 51 (Guidelines on Air Quality Models), on site meteorology data (1996 or more recent calendar year), and the most current and quantifiable stack-specific annualized CQ emission rates a s well as physical stack parameters. The DAQ has conducted a preliminary modeling analysis of C6 emissions using adjusted calendar year 2000 stack-specific emissions data assuming representative values to account lor increased stack height and control efficiency in the fine powder area and 1996 on-site meteorological data provided by DuPont. The results of this 00/ 200 3 sBed ES3# / 0fn ri 000310 `"Promoting a healthy environment.* 03/13/03 THU 10:04 [T.T/RI NO 6014 1 IIVNNI3NI0 HWSI S0Z0T8CCTSTO ZC=TT 0_nd TTTH V u o s u m o p J9;uTM<- WV6E: ll EO/Et/E CO/CT/CO .-peATsoeu 03X13/2003 10:06 UU DCP LEGAL SERVICES * 915133010205 03/13/03 09:10 3 0 4 928 3738 wv AIR q u a l i t y N O . 129 Letter to Paul J. Bossert, Jr. March 13, 2003 analysis indicate there is a potential for DuPont to exceed the standard if annual emissions of C8 are reallocated among the various emission sources in a manner which approaches the units' permitted allowable emission levels. Specifically, when operating at maximum permitted capacity, emission points 163-E11, 163-E26 and 242 could exceed the 1 pg/m9ground level screening standard. In light of the foregoing, the reporting mechanism established in Section X .i. of the above referenced order h as been determined insufficient for future C8 compliance demonstrations. The quarterly report specified In Section X.i. was developed as an aggregate, thus giving a total for.several different operating units containing multiple emission points. In order for OAQ to be able to monitor compliance through air dispersion modeling to estimate concentrations of CB around the Washington Works facility, it is imperative that'DuPOnt report C8 Emissions for each individual stack. This will eliminate needing to make any assumptions that the total amount of emissions were released entirely from select emission points, which could result In concentrations above the C8 screening level. Therefore, DuPont shall submit to DAQ for approval a Monitoring, Record keeping and Reporting (MRR) Plan pursuant to GWR-2001-019 Section Xlll "Additional Actions" in order to establish a practically enforceable means of demonstrating compliance with the C8 screening level. Prior to implementing the MRR plan, an initial compliance demonstration shall be based on stack specific 2000 calender year emission data, which incorporates control efficiency increases as well as modified stack configurations resulting from add-on controls/process improvements required by the above referenced order. Compliance with the CB screening level will be determined by DAQ within 60 days of receiving updated process information via 45CSR13 permit application(s) to modify/update each affected process unit. The complete revised permit applications defining operational changes required by Consent Order GWR-2001-019 shall be submitted to DAQ no later than June 30, 2003. DAQ's objective is to include all MRR requirements established pursuant to this letter, and thus Section XIH of the Order, within the facility's 45GSR30, Title V operating permit via the individual 45CSR13 permits. Thus a practically enforceable means of demonstrating compliance for future operations Involving C8 at DuPont's Washington Works facility shall be obtained by incorporation of the MRR plan into DuPont's 45CSR13 construction and modification permits. As DuPont is aware, the provisional screening level established by the CAT Team is directed at chronic exposure to the public. However, DAQ will conduct further investigation into the applicability of worker exposure guidelines for m easures necessary to protect the general public outside the facility. oo/eoo 03/13/03 THU 10:04 [TX/RI NO 60141 IIVNMIONID HVS1 SOZOmCTSTO CC:IT e eBed -` EBB# i 0~1~ld XTTH 1? u o s u L io r J91UTM<- iim vee: 1.1. eo/e i / e C0/CT/C0 :pe/\TeoeH XU wv- Lts-r \_&wnu a c . r 7 ?xJxooaxucuo 03/13/03 08:10 @304 926 3739 WV AIR QUALITY in u . @1004 Letter to Paul J. Bossert. J r March 13, 2003 Page 3 The American Conference of Governmental Industrial Hygienists has determined a threshold limit value (TLV) for C8. TLVs are guidelines for use by industrial hygienists in making decisions regarding safe levels of exposure to chemicals In the workplace. The U.S. Occupational Safety and Health Administration (OSHA) has not developed a Permissible Emission Level (PEL) for C8. DAQ intends to seek information from a variety of sources, including OSHA, the National Institute of Occupational Safety and Health, the U.S. Environmental Protection Agency, and the Ohio Environmental Protection Agency In connection with this issue. Sincerely. Deputy Director JAB OO/f-OO O0O33L2 03/13/03 THU 10:04 (TX/RX NO 80141 IIVNKIDKID HSSX S0Z0T8CCTSTO CC =TT * oBed JESS# f TTTH V uosuLjop je4.UTA/l< - iWVkS: l l GO/El/S C0/CT/C0 :p e A i a o e y