DuPooproducts
October
20,
2003
Document
Control
Office
(
DCO)
Office
of
Pollution
Prevention
and
Toxics
(
OPPT)
US
Environmental
Protection
Agency
EPA
East,
Room
6428
1201
Constitution
Avenue,
NW
Washington,
DC
20460
VIA
OVERNIGHT
MAIL
Attention:
Docket
No.
AR­
226
and/
or
OPPT­
2003­
0012
Re:
Follow­
up
to
September
15,
2003
Submission
of
DuPont
Progress
Report
on
Environmental
Assessments
Pursuant
to
the
APFO
Users
LOI
dated
March
14,
2003:
Air
Dispersion
Modeling
Reports
Dear
Sir/
Madam:

Further
to
my
letter
of
September
15,
2003
(
referenced
above)
and
DuPont
commitments
made
in
the
above­
identified
LOI,
air
dispersion
modeling,
based
upon
year
2002
air
emissions
for
the
Washington
Works
facility
and
using
the
EPA
approved
Industrial
Source
Complex
Short
Term
3
(
ISCST3)
model,
as
described
in
the
APFO
Users
LOI,
has
been
completed.
The
report
is
included
as
Attachment
1.
These
modeled
results
are
presented
solely
for
the
purpose
of
establishing
a
baseline
year
by
which
future
reductions
in
air
emissions
can
be
compared.
Verification
of
the
air
model
on
which
these
results
are
based
is
planned
to
begin
shortly.

In
addition,
air
dispersion
modeling
based
upon
air
emissions
from
September
2002
through
August
2003
has
also
been
conducted,
per
request
of
the
West
Virginia
Department
of
Environmental
Protection.
Those
results
are
reported
in
Attachment
2.
The
modeled
air
emissions
for
this
time
period
are
reduced
in
comparison
to
the
modeled
air
emissions
for
baseline
year
2002.

The
reduction
in
air
emissions
is
primarily
due
to
the
addition,
in
May
2002,
of
a
secondary
recovery
scrubber
to
the
largest
single
emission
point.
The
previously
existing
packed­
bed
scrubber
collected
50%
of
the
emitted
material.
The
new
device
uses
a
deepbed
fiber
system
to
collect
fine
particles
that
were
not
collected
by
the
existing
scrubber.
The
recovery
efficiency,
measured
across
both
devices,
has
been
demonstrated
to
be
98%
or
greater.
 
DuPont
Fluoroproducts
DuPont
Fluoroproducts
Chestnut
Run
Plaza
P.
O.
Box
80711
Wilmington,
DE
19880­
0711
RECEIVED
OPPT
NCIC
2003
October
28
8:
25AM
OPPT­
2003­
0012­
0223
Document
Control
Office
Page
2
Office
of
Pollution
Prevention
and
Toxics
October
20,
2003
Additional
reductions
in
air
emissions
resulted
from
improvements
applied
to
scrubbers
on
other
significant
emission
points.
A
DuPont
study
identified
improvements
to
scrubber
operating
parameters
and
changes
to
control
strategies
that
can
allow
efficiencies
to
improve
from
75%
­
85%
to
90%
or
better.

If
you
need
further
clarification
on
the
information
presented
with
this
letter,
please
contact
me
at
the
number
provided
below.

Very
truly
yours,

David
M.
Rurak
Safety,
Health,
and
Environmental
Manager
Global
Business
Manager,
APFO
DuPont
Fluoroproducts
CRP
Bld.
711/
2210­
C
P.
O.
Box
80711
Wilmington,
Delaware
19880­
0711
302­
999­
2415
(
phone)
302­
999­
3095
(
fax)
E­
mail:
David.
M.
Rurak@
usa.
dupont.
com
Attachments
(
2)

cc:
Mary
Dominiak,
EPA
(
via
overnight
mail)
U.
S.
Environmental
Protection
Agency
Office
of
Pollution
Prevention
and
Toxics
EPA
East,
Room
4410
1201
Constitution
Avenue,
NW
Washington,
DC
20460
564­
4760
Document
Control
Office
Page
3
Office
of
Pollution
Prevention
and
Toxics
October
20,
2003
ATTACHMENTS
Attachment
No.
Title___________________________
No.
of
Pages
1
Year
2002
Air
Dispersion
Modeling
Analysis
8
of
APFO
Emissions
2
September
2002
through
August
2003
Air
8
Dispersion
Modeling
Analysis
of
APFO
Emissions
