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From. Bernard J KMMy 0 10/13/2001 08:08 AM To rharrts0amwoncorp com. iwashburnanvironcorp com cc. Subjact Ra. Action Itamt from Maating with W VDEP/DAQ - Privileged Communication
--------- .. -- .... Forwarded by Barnard J Reiliy/AE/DuPont on 10/13/2001 08:08 AM -- ....... From: Barnard J Reilly on 10/13/2001 08:07 AM To M Ann Bradley cc: John R Bowman. Paula Durst-Giilis. Andrea V Malinowski, Heather H. Jones, Stephanie R Timt Subject Re: Action Items from Mealing with W VDEP/DAQ - Privileged Communication Cj
l was not on the call with the D A Q , but my conversation with Ann late Friday, coupled with this note suggest we are not on the same page as the DAQ on whether when assessing potential off-plant impacts they should focus on acute exposures, e g one-hour or 8-hour, as we often do in a workplace for TLV/AELs, or chronic exposures, i.e. the annual average concentration in the community.
l believe that we are of the strong view that since any risk to A P F O is chronic that the annual average concentration in the community is the proper focus is this correct? If so. seem s there is an urgent need to reach agreement with the DA Q to avoid needlessly alarming modeling, e g impact maps showing large areas around the plant above (wrong) standards Do we know if Dr Staats agrees the focus should be chronic?
-Bem ie M. Ann Bradley (Spilman Thomas & Battle)
M Ann Bradley (Spilman Thomas & Battle) 10/12/2001 05 55 PM
To: Barnard J Rally cc: John R Bowman. Paula Durrt-GiMt* Andraa v MaunowaM. Haathar H Jonaa. Staphania R nmmanrwyar Subjact Action Items from Meeting with W VDEP/DAQ
Bemie:
A s you and I have discussed, a s a result of our meeting with the agency today there are several tasks that need to be undertaken. To that end. could you please forward the following email to Bob Ritchey. Thanks.
Privilagati and Confidential Attorney Work Product Praparad in Anticipation of Litigation
Bob: In connection with our negotiations with the W V D E P DAQ concerning consent orders, we are requesting the following items be prepared:
1. W e need language to be drafted that will ultimately be added to the Mulit-Media Order concerning reductions in emissions of A P F O to air and water 2. W e need modeling of emissions which would result from the revised permit application submitted on Oct. 4.2001 for Permit R13-815D. 3. W e need someone at DuPont to determine what percentage of all air emissions reductions is represented by the reductions from the dryers due to the new scrubbers and stack modifications. 4. W e need an evaluation of D A Q 's air emissions modeling results as depicted in charts provided
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