Document OJ1B9LZEzEwow50MQJXNek8pK

AR226-2280 , Privileged and Confidential Attorney Work Product-Prepared in Anticipation o fLitigation Summary of Meeting with DAO `Representatives April 24. 2002 Attendees: DuPont Rob Pinchot Debbie Mulrooney Bob Ritchey Ann Bradley WVDEP-DAQ John Benedict Chris Arrington Dave Roberts WVDEP Dee Ann Staats Chris Negley (Office of Legal Services) Dave Watkins (Division of Water - Leader of GIST) Debbie Mulrooney provided an overview of the air modeling report that was sent to DAQ on April 19, 2002. There were numerous questions from DAQ staff regarding the report, but no significant disagreements with the methodology used. John Benedict asked whether the data used for particle size distribution was representative of all the different C8 sources at the plant. The response was that the distribution probably differs for different sources, but that the data used would be reflective of the source that drives the model result, and therefore would make the results more accurate than any other assumption. Benedict also inquired as to the source of the rainfall data that was used and DuPont representatives were uncertain of the source. Dave Roberts of DAQ reported on his conversation with Al Cimorelli a modeler with EPA-Region III concerning the scavenging coefficients for C8. Cimorelli had indicated that he was very comfortable with the coeffiecient developed for the particle phase, but was, not prepared to concur on the coefficient for the vapor phase. DAQ posed the question of whether the 2000 actual emissions data that was used in the model would have been representative of the highest levels of emissions in prior years. Bob Ritchey was uncertain of this point and agreed to look into this issue and provide a response to the agency. RWR003594 EID585215 * Privileged and Confidential Attorney Work Product-Prepared in Anticipation o fLitigation Dr. Staats wanted to know whether the maximum concentration point of 2.86 ug/m3 would be all respirable (if there was a receptor at that point) and the response was affirmative. DAQ reported that they had performed air modeling on the same data and that their results corresponded very closely with DuPont's. A draft of the modeling report from the DAQ was reviewed by those present, but, as it was a draft report, it was not retained by DuPont representatives. It was agreed that DuPont would provide a revised report to the agency that reflected the 2 additional minor sources of C8 that had been identified after the report was prepared. DuPont was asked whether modeling had been performed reflecting the physical changes to be made at the plant, as described in the WV Consent Order. Rob Pinchot responded that some preliminary work had been done in this area, but that the company was reluctant to do full scale modeling until it had better information about the efficiencies to be obtained from the new equipment and a better idea of projected production levels. Dr. Staats stated that she hoped this information would be available for the public meeting to be held sometime in the summer. On the issue of what would be reported at the 5/15 public meeting, Dr. Staats indicated that WVDEP did not intend to draw any conclusions regarding sources of contamination, and, in particular did not think it would be appropriate to discuss the results of the air modeling until more work had been done. She stated that the meeting on 5/15 would focus on the Screening Level developed by the CAT Team and its implications given the groundwater well and public water supply data generated to date. She said that another public meeting would be appropriate after TERA had completed its risk assessment and after all the groundwater well sampling had been completed. This would probably take place in July or August, 2002. She stated that at this meeting it would be appropriate to also consider sources of contamination and what action needed to be taken with regard to these sources. Dr. Staats made it clear that no one from DEP would address any data related to Ohio at the 5/15 public meeting. She said that OEPA and EPA were planning a separate public meeting for 5/16 for the purpose of addressing the Ohio data. Dr. Staats had been requested by Karen Johnson (EPA) to speak at the Ohio . meeting, but she felt it was unlikely that she would do so. She indicated that WVDEP's legal position was that the Screening Level developed by the CAT Team was not a regulatory standard (which is typically developed following extensive administrative procedures including subjecting drafts for public review and comment) but rather a site-specific standard that would be applicable to DuPont's Washington Works. It was a standard that was being developed as a result of this specific enforcement action, and was not intended to have wide- KWR003595 EXD585216 __ P rivileged and Confidential Attorney Work Product-Prepared in Anticipation o fLitigation spread applicability. She offered this explanantiop as partial justification for why she should not be speaking at public meetings in Ohio to defend the CAT Team work. No specific deadline was mentioned in the meeting for providing that revised version of the modeling report to the agency, but Dr. Staats was comfortable that a submission within 30 days would be timely for purposes of TERA's risk assessment work. i RWR003596 EID585217