Document XQ954gVnvbYzXXoRRK83Be7K

AR226-2274 JOHN BENEDICT - C8 update from air quality Page 1 From : To: D ate: S ubject: Jesse Hanshaw DEE ANN STAATS 4/16/02 5:10PM C8 update from air quality Hi Dee Ann, W e are currently in the process of coordinating our modeling efforts with DuPont. A meeting between DuPont and DAQ to discuss modeling protocol and process input parameters has been scheduled for next W ed. 4/24/02 in our Kanawha City Office from 1:00 to 3:00pm, Conference Rm. C. You are invited to attend if your schedule allows. D ave Roberts contacted DuPont's modeler, Debbie Mulrooney, last w eek in order to see if there has been any changes to the modeling input parameters that were supplied to DAQ as a result o f the M ultim edia Consent O rder. Mulrooney stated that there has been no changes to the model inputs since the last submittal. Debbie followed up their conversation by sending Dave a copy of her electronic files used as inputs to the dispersion model. Our modeling section plans to build a revised input file this week and then work on running another air dispersion simulation before our meeting next week. Another interesting fact Debbie shared with Dave was that DuPont has run a deposition model using software different than the standard ISC model. She stated the reason the ISC model was not used is that it doesn't take into account vapor phase deposition. This also corresponds with what Al Sim m ireiii, EPA's modeling expert, told us when Chris and Dave questioned him about the feasibility of running such a model with the inputs DuPont had supplied to us. D ave noted that this may be something DAQ might want to probe DuPont fo r more information on in the future if we decide to attempt to correlate deposition with the water modeling and monitoring results. In order for DAQ to run this type of model it seems that we will have to use something different than our ISC model. From a permitting standpoint DAQ still has 3 C-8 perm it modifications under review. Two of these three are very close to final approval.. Shawn Hickman is working on R13-1823A, Fluoropolymer Monomers, which involves the replacem ent of an incinerator which is planned to be used for C8 containing waste w ater destruction. R 13-1823A is currently finishing up a 45 day public notice period. Provided there are no public comments to be addressed this permit vrili be approved shortly after the end of this notice period. The second permit m odification, which is dose to final approval is the R13-2365A permit, which covers the Fluoropolymer CoPolym ers area. The 45 day public comment period has passed on this permit mod. without any response from the public. The application was placed on hold after the public comment period had commenced due to DuPont sampling and finding C8 in a plugged filter in a part of the production line, which w as originally thought to contain no C8. W hat it boiled down to is that not all of the C 8 is removed in the dryer som e residual amounts are further removed downstream of the dryer thus adding some new C 8 emission points. There was an initial effort to require DuPont to undergo another 45 day public com m ent period based on the new facts, although it was realized that a new legal ad would not have changed from the original since DuPonts net emission changes as a result o f the modification was still negative with respect to PM 10. Typically the legal ads only state the emission increases due to the process modification. Therefore running another ad would not benefit the public since it would be stated in exactly the same way as the first, which didn't receive any comments. The only thing holding this perm it from being approved is that DuPont has asked for some additional tim e to have their process people review the recordkeeping requirements one last time to make sure there are no questions. The third and last C 8 perm it being processed currently is the R13-815E permit modification. The fine powder production unit covered by this permit is the one that inadvertently triggered PSD for PM 10 last year. Currently they are operating under a Consent Order, which limits DuPont to production rates below that which would (rigger PSD applicability under 45CSR14. This permit ranks #5 on my permitting to do list which I plan to have com pleted by the end of the year. This is also the unit which had a stack test on its dryers last month. ! am still waiting to see the result from the testing and also planning to use the test WVDEP000033 EID647374