Document RJ7Ja99z5DGxv8DyXwpmrkDZv
AR226-2308
jKay Gilmer - Pwd: Dupont update
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BiB Spires Kay Gilmer 3/12/03 3:10PM Fwd: Dupont update
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> > Bill Spires 03/12/03 07:48AM
Director's update:
DAPG had discussions with both The State of West Virginia and Dupont concerning the air emissions of C8 from the West Virginia facility.
In a conference call with West Virginia on March 11,2003, we discussed'the two major issues expressed
in your January 7 2003 tetter to Dupont. The first was the concern over the potential need for a short term
screening level, potentially comparable to the workplace standard, to augment the current CATT annual
screening level of 1.0 ug/m3. The second was the need for actual permit Itmitalions to regulate future
emissions of C8.
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West Virginia believes the long term screening level developed by the CATT is adequate, but will enter into discussions with our lexicologist and the U.S. EPA lead toxicotogist to determine where U.S. EPA is heading with their evaluation of this substance. Wast Virginia is in agreement with the need for permit
limits and will be proposing a compliance plan to Dupont soon.
In a meeting on the afternoon of March 11.2003, Dupont met with DAPC to discuss the issues in your tetter as well as lay out the most recent developments in their efforts to reduce releases of CB.
Dupont presented modeling results for the year 2002 actual emissions and projected 2003 and 2004 emissions. While there are significant reductions (-50%) from the year 2000 levels in 2002 and significantly lower emissions projected for 2003 and 2004. it was not clear how much of the reduction is due to controls and how much is due to reduced production. A table was presented that the draft annual permit allowables that may be included as part of the consent agreement will limit annual emissions to about the same as 2002 emissions. They are checking to see if the draft permits will also include short
term limits.
The topic of a short term screening level was also discussed. Dupont indicated'that the constraining target was the liver and that it is a long term concern, not short term. Dupont claims that the potential short terrn effects were included during the CATT analyses and that the long term was still constraining.
We indicated that levels above the workplace limits would not be an acceptable impact on elderly or sensitive citizens in Ohio and indicated that we would urge West Virginia to address the short term in their implementation of the final solution. We have requested the latest modeling files to enable us to evaluate
short term impacts. Dupont will consider sending the files.
CAB000286 EID719358