Meeting
with
the
Boeing
Company
Date:
June
17,
2003
Attending:
from
Boeing:
Chris
Zervas,
David
Moore,
Maurice
Hedlund,
Dan
Guth,
Peter
Verge
from
US
EPA:
Margaret
Sheppard
from
Garrett
Services,
Inc.:
Andy
Garrett
from
Albemarle
Corporation:
Joe
Miller,
Mick
Kassem
Chris
Zervas
opened
the
meeting
with
introductions.
Margaret
Sheppard
from
EPA
provided
information
on
the
environmental
and
health
effects
of
n­
propyl
bromide
(
nPB)
(
see
attachment/
Docket
A­
2001­
07,
item
IV­
B­
3).
She
summarized
EPA's
proposed
acceptability
decision
for
nPB,
including
the
use
condition
that
nPB
formulations
used
in
SNAP
end
uses
must
contain
no
more
than
0.05%
isopropyl
bromide
(
iPB)
before
adding
other
chemicals.

Boeing
staff
asked
about
the
possibility
of
recycling
spent
solvent.
Albemarle
representatives
said
that
there
is
not
yet
recycling
in
the
U.
S.
because
there
is
not
quite
enough
volume
of
nPB
to
make
recycling
viable.
However,
it
is
possible
that
this
could
happen
in
the
future
if
the
volume
of
nPB
use
increases
slightly
(
30
to
40
tons
per
year).

Dan
Guth
asked
about
details
of
EPA's
derivation
of
an
acceptable
exposure
limit
(
AEL).
In
particular,
he
asked
about
EPA's
use
of
a
benchmark
dose
low
(
BMDL)
for
sperm
motility.
Dr.
Guth
said
that
he
basically
agreed
with
EPA's
final
conclusion
of
an
AEL
of
25
ppm
and
the
general
approach.
However,
he
noted
that
he
thought
it
would
have
been
simpler
to
divide
a
NOAEL
of
250
ppm
by
10
to
reach
25
ppm,
as
some
external
reviewers
had
suggested.

David
Moore
asked
if
EPA
had
developed
a
reference
concentration
(
RfC)
for
nPB.
Ms.
Sheppard
said
that
the
SNAP
program
had
developed
a
community
exposure
guideline
using
EPA's
RfC
guidelines,
and
that
it
was
basically
an
estimated
RfC.
However,
the
community
exposure
guideline
is
not
in
IRIS.
Mr.
Moore
asked
if
EPA
planned
to
issue
an
official
RfC.
Ms.
Sheppard
said
that
the
SNAP
program
had
developed
the
estimated
RfC
for
purposes
of
its
acceptability
determination,
not
for
purposes
of
IRIS.

Boeing
personnel
expressed
concern
that
other
parts
of
EPA
or
OSHA
might
come
out
with
a
different,
and
perhaps
stricter,
AEL.
Ms.
Sheppard
said
that
if
OSHA
did
regulate
nPB,
they
would
be
likely
to
look
at
results
of
the
ongoing
carcinogenicity
testing
under
the
National
Toxicology
Program,
and
OSHA
would
apply
their
own
statutory
criteria
for
developing
a
permissible
exposure
limit.
Ms.
Sheppard
mentioned
that
it
was
likely
that
either
the
American
Industrial
Hygienists
Association
or
the
American
Conference
of
Governmental
Industrial
Hygienists
would
recommend
an
exposure
limit.
If
this
were
to
happen
before
the
nPB
rule
became
final,
EPA
would
make
that
information
available
to
the
public
and
would
consider
it
in
developing
a
final
rule.

Ms.
Sheppard
also
discussed
a
number
of
SNAP
submissions
related
to
fire
suppression.
She
gave
Chris
Zervas
a
copy
of
a
report
on
CF
3
I
prepared
for
the
military.
She
mentioned
that
2
with
CF
3
I,
a
major
issue
for
aircraft
is
whether
the
agent
will
be
emitted
at
high
enough
altitudes
to
impact
the
ozone
layer.
Ms.
Sheppard
mentioned
that
Dan
Lewinsky
and
his
group
at
Boeing
were
asking
the
University
of
Illinois
to
look
at
the
same
issue
for
Agent
707.
Ms.
Sheppard
also
mentioned
a
number
of
submissions
currently
under
review
(
Goodrich
244,
AeroK,
and
NAF
S­
125)
and
submissions
the
SNAP
program
expects
in
the
near
future
(
N2
Inert
Gas
generator,
PBr
3).
She
said
that
several
of
these
agents
were
likely
to
work
in
particular
applications
in
aircraft
such
as
cargo
holds
or
engine
nacelles.
