Document zzVxD1n1qnLX52wXv7bdr0wVB

AR226-2308 i-ffe g e f } From : To: D ate : S u b ject: B I Spires Kay G ilm er 3/12/03 3:10P M Fwd: Dupont update > B ill Spires 03/12/03 07:48A M > Director's update: DAPG had discussions with both Th e State of W est Virginia and Dupont concerning the air em issions o f C 8 from the W est Virginia facility. In a conference call with W est Virginia on March 1 1 ,2 0 0 3 , w e discussed'the two m ajor issues expressed in your January 7 20 03 letter to Dupont. The first was the concern over the potential need fo r a short term screening level, potentially com parable to the workplace standard, to augm ent the current C A T T annual screening level of 1.0 ug/m 3. T h e second was the need for actual perm it limitations to regulate future em issions of C 8. ' W est Virginia believes the long term screening level developed by the C A TT is adequate, but w ill en ter into discussions with ourtoxicologist and the U.S. EPA lead toxicologist to determ ine where U .S . E PA is heading with their evaluation o f this substance. W est Virginia is in agreem ent with the need fo r perm it lim its and will be proposing a compliance plan to Dupont soon. In a meeting on the afternoon o f M arch 11,2003, Dupont m et with D A PC to discuss the issues in your tetter as well as lay out the m ost recent developments in their efforts to reduce releases o f C 8. Dupont presented modeling results for the year 2002 actual em issions and projected 2003 and 20 04 em issions. W hile there are significant reductions (-5 0 % ) from the year 2 0 0 0 levels in 2002 and significantly lower em issions projected for 2003 and 2004. it w as not clear how m uch o f the reduction is due to controls and how m uch Is due to reduced production. A table w as presented that the d ra ft annual perm it allowables teat m ay be included as part o f the consent agreem ent w ill lim it annual em issions to about the same as 2002 em issions. They are checking to see if the draft permits w ill also include short term limits. The topic o f a short term screening level was also discussed. Dupont indicated'fhat the constraining target w as the liver and that it is a long term concern, not short term . Dupont claim s that the potential short term effects w ere included during the CATT analyses and that the long term was still constraining. W e indicated that levels above the workplace limits would not b e an acceptable im pact on elderly or sensitive citizens in O hio and indicated that we would urge W est Virginia to address the short term in their implementation of the final solution. W e have requested the latest modeling files to enable us to evaluate short term impacts. Dupont w ill consider sending the files. CB000286 EID719358