Document LpyyX1R7BwX66pk8nawV3GnJq
AR226-2210
Robert Pinchot 11/05/2001 03:02 PM ________ ____________________
To: Debbie J Mulrooney/AE/DuPont@DuPont, Steven L Grise/AE/DuPont@DuPont, Mary A Kaiser/AE/DuPont@DuPont, Ron J Buchanan/AE/DuPont@DuPont>Roger J Zipfel/AE/DuPont@DuPont
cc: Ta-W ei Fu/SE/DuPont@DuPont, Bernard J Reilly/AE/DuPont@DuPont, David M Rurak/AE/DuPont@DuPont, Chris E Shoop/AE/DuPont@DuPont, Robert L Ritchey/CL/DuPont@DuPont, Charles J Zarzecki/AE/DuPont@DuPont, Stephen T Breske/AE/DuPont@DuPont
Subject: 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 W V Dept, of Environmental Protection, the W V 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
Tasks
Building dimension
Confirm existing data are
parameters that have a complete and accurate
significant impact on air
dispersion
Permitted allowable emission rates, acutal
Confirm existing data are complete and accurate
emissions 2000, stack
parameters Phase of APFO at Stack Conditons
Determine mass fraction particles and mass Fraction vapor for each
stack emitting APFO
Particle Characterization Determine appropriate particle size classes for
modeling based on
experimental data
collected by Zipfel in
1996
Lead Responsibility Mulrooney Mulrooney ' Zipfel Mulrooney
Mulrooney
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) for the vapor scavaging coefficient of APFO as a function of droplet size
Grise Grise
Other Responsibility Shoop, Fu, Zipfel Shoop, Fu , Zipfel
Grise, Fu, Mulrooney Zipfel
Zipfel Mulrooney, Zarzecki
Others in DuET
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Phase Diagram of APFO Develop phase diagram for the range of operating
conditions. Include critical properties, and
phase transition temperature ranges
APFO in water information
Report, with references, the soluability and Krafft Point of APFO in aqueous solutions and measured pK value.
Head Space GC mesurements
Develop analytical method to detect AFPO in gas phase above an aqueous solution of APFO. Measure the
concentrations at operating conditions.
Henry's Law Constant
As a function of Temperature and a discussion of its dependence on pH
Carbon Absorption Data Any isotherms for the absorption of APFO onto
carbon from aqueous solutions
Grise
i
Grise
Kaiser
Pinchot (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
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