Document nm4Kkz4v2nxE9xarng1DNKwwR

ent t .Winter Johnson & Hill PLLC mtm* A V * 304 345 7830; 0 1/15/0 3 12:21PM;#040; Page 2 /3 tts n n p y tm m s i Canto 22S .Frcit Street lumttja,OH 40215-109 s u t* o f Ohl EaWromatttal Afocy . m s t< i*v u -a e o FAX: ti oa^-zsas .... ' .\:VJV Zso*; ' n M H b - l& O J L WHUHSAOCWe C olum bus. CH 4321S-1049 January 7, 2003 Mr. Paul Bossert EJ. Du Pont da Nemours and Company Washington Works P.O. Box .1217 Parkersburg, West Virginia 26102 P o s t-it* Fax N o t# CoVDapL Ptionc * *x i 7571 Co. Phone Fm &U 2 -- Re:'Ammonium Perfluorooctanoate (C8) Impacts in Little Hocking. Ohio Dear Mr. Bossert 1am writing to express Ohio EPA's concerns with respect to air impacts in Ohio; due to emissions of C8 from your Washington Works facility. We have been following the progress on the evaluation and review of ambient impacts due to this facility, as well as the evaluation of ambient screening levels for both the air and water pathways developed by the C8 Assessment of Toxicity Team (CATT). We are also aware of additional evaluations in progress by U.S. EPA and the Science Advisory board for reassessing the toxicity and possible carcinogenic effects of C8. i j In addition, we have been contacted by a citizens group expressing concern over ambient j levels of C8, as predicted by air quality modeling of year 2000 actual emissions. Short i term levels used to assess workplace exposures were identified as health based levels not fully considered by the CAT team in the development of an air screening level for C8. My staff has assessed the modeled ambient Impacts resulting from the year2000 emission levels, Afoong the averaging times evaluated, my staff has identified predicted eight-hour concentrations well above the ACGIH health based work place standard at multiple receptors In Ohio. While these ambient concentrations may not be directly comparable to j workplace exposures, these predicted concentrations raise our level of concern with ; regards to short term exposures to workers and sensitive populations. i k Du Pont has indicated that future production levels, modifications to a scrubber, a taller stack on a major source, as well as agreements with U.S. EPA to reduce releases to all media wilt limit future impacts In the area. You presented information that future impacts would bel below those associated with year 2000 actual Impacts. And. the year 2000 \ emissions are the basis of your agreement with West Virginia to limit future air emission levels. However, we do not believe that there is enough certainty in the assumptions to insure th it future ambient air impacts will be significantly b e lo w 2000 le v e ls . f>m tad an AavM iM F t Scfe H rit, Gewacnar M a m a n O O onnof. Ueutonant Oovarno C hflafepbar Jonas. Director 000006 `ert by: Winter Johnson & Hill PLLC 304 345 7830; 0 1 /1 5 / 03 1 2 :21P M ; #840 ; Page 3 / 3 Page 2 , Mr. Paul Bossert .. f January 3l 2003 . W e are requesting that you work with the State of West Virginia to adopt enforceable permit restrictions that will reduce ambient impacts below the workplace exposure limits at all receptors beyond the plant fence line. We believe that this is a prudent interim step until the potential effects of C8 are fully evaluated. Once these evaluations are complete, future acceptable emission levels can be determined. If you have any questions with respect to our concerns, please feel free to contact Bob Hodanbosi of the Division of Air Pollution Control at 614-644-2270. Sincerely, Gnnsuspner uones Director ? cc: Bnard J. Reilly Esq., E,I. Du Pont de Nemours and Company, Legal D ept John Benedict, WV Department of Environmental Protection .I 000007