Document 2R39qnoV1Y3w7QRw3QY4eeQMa

Ohio EPA December 2,2003 ks o to CO o Ul AR226-2350 EXP01582Q O b jectives Provide grounding/update on recent activities Solicit input on upcoming activities 'H****** 8O1000 o <j\ EXP015821 Agenda Water - GIST Final Report Recommendations - Proposed MOU Based on GIST Recommendations - OEPA Requests - DuPont Suggested Modifications Air - Review Recent M odel Results g - Air Permit Update I - Additional Reduction Programs - Air Model Verification Plan EXP015822 Proposed Memorandum of Understanding-West Virginia DEP and Ohio EPA Summary of Activities December 2, 2003 m oxo cUol ASH028048 GIST Report Recommendations Summary Final GIST report issued August, 2003 Continued quarterly/annual monitoring of certain Ohio River public water systems Quarterly/annual monitoring of private water supplies (10 locations) in West Virginia and Ohio - West Virginia: Wash Works 0-2 mile radius and Dry Run Landfill/Letart Landfill 1-mile radius - Ohio: Wash Works 0-2 mile radius - List to include wells, springs, cisterns Conduct C8 monitoring at all DuPont Washington Works facilities according to applicable West Virginia Solid Waste/NPDES, NPDES, g and EPA HSWA (Corrective Action) permit requirements to GO o EXP015824 Proposed MOU -Administrative Details Parties: - West Virginia Department of Environmental Protection - West Virginia Department of Health and Human Resources - Ohio Environmental Protection Agency - E.I. du Pont de Nemours & Company i Objectives: - Continued monitoring and reporting of C8 concentrations in groundwater and surface water - Implement recommendations of the GIST concerning continued sampling and monitoring in WV & Ohio ("in and around the g facilities") g00 - Begin first quarter 2004 o w o E X P 0 1 5825 Proposed MOU -Public Water Syste II Sampling WV Public Water Systems: - Quarterly sampling 1Q2004-4Q2005 at Lubeck PSD, DuPont WW, and GE production wells and finished water (if applicable) - Annual sampling 2004-2005 at Blennerhassett Island State Park, Mason Cty. PSD, and Racine L&D Ohio Public Water Systems: - Quarterly sampling 1Q2004-4Q2005 at Little Hocking S Water Association production wells and finished water oIO 00 o(J1 - Annual sampling of Tuppers Plains-Chester PWS EXP015826 Proposed MOU -Private Water Supply Sampling West Virginia: - Quarterly sampling for 1 year beginning 1Q2004 at locations within Wash Works facility 0-2 mile radius - 10 samples with at least 1 sample being from the following locations with detectable levels of C8: iDrinking water wells iDrinking water springs . Non-drinking water wells : Springs and cisterns ; One well and spring used for cattle where prior sampling detected C8 concentrations above 5 ug/L - Further sampling/frequency beyond 4Q2004 will be evaluated by parties to the MOU EXP015827 Proposed MOU -Private Water Supply Sampling Ohio: - Quarterly sampling for 1 year beginning 1Q2004 at locations within Wash Works facility 0-2 mile radius - 10 samples with at least 1 sample being from the following locations with detectable levels of C8: Drinking water wells Drinking water springs Non-drinking water wells Springs and cisterns. - Further sampling/frequency beyond 4Q2004 will be evaluated by parties to the MOU OEPA Request for Additional Investigation gffi o to CD O in EXP015829 OEPA Request for Additional Investigation OEPA letter to DuPont dated October 23, 2003 Objective: - Better understand the range o f C8 concentrations in surface soil and shallow groundwater, and how these concentrations change over time to oN OCO iinn EXP015830 EXP015831 I Proposed Additional Investigation in Ohio -Little Hocking and Porterfield Areas Establish 8 locations for surface soil sampling in these areas based on results of air and groundwater modeling Install 4 new shallow groundwater monitoring wells within the LHWA to monitor shallowest portion of aquifer. Sample quarterly in conjunction with production well sampling. o to CD 00011 i Proposed Additional Investigation on Ohio -Little Hocking and Porterfield Areas DuPont Suogogested Modifications Establish 8 locations for surface soil sampling in these areas based on results of air and groundwater modeling: - Two sampling events will be conducted, one directly after a >.5 inch rain event, the other after 5 days of no precipitation. During each event, the following samples will be collected: Foliage layer sample (grass and root zone) Surface soil sample (depth interval to be determined) i Install 4 new shallow groundwater monitoring wells within the LHWA i to monitor shallowest portion of aquifer. Sample quarterly in g -conjunction with production well sampling. 8 O ODnJJ EXP015832 Path Forward Execute MOU covering GIST recommendations Gain agreement on OEPA proposal and DuPont suggestions Propose the additional testing (OEPA proposal and DuPont suggestions) at the ECA process on December 9 Air Topics Modeling Results Sept 2002 - Aug 2003 Air Permit Update Additional Reduction Programs Air Modeling Verification Project - Phase I: Fence Line Monitoring - Phase II: Community Monitoring o N> CD OUVO1 E X P O 15834 Modeling Methodology EPA's Industrial Source Complex 3 (ISCST3) Model Followed procedures in EPA's Guideline on Air Quality i Models (Appendix W) BPIP model to evaluate building downwash effects Terrain elevations imported from USGS electronic file Receptor grid with 100-meter spacing i On-site met data (1996) i Rural dispersion coefficients &a o N> 00 Oa O EXP015835 Modeling Inputs - Stack Parameters 71ECTF 699 THI652 THG658 CDT231 CDW 232 CEH242 CFS 274 CFK268 TIV 697 TIF 694 R022EEF6 R022EEF86 R022EEF87 R022EEF89 442091 441920 441923 441953 441952 441954 441787 441774 442129 442104 442086 442069 442058 442063 4346836 4346767 4346756 4346766 4346776 4346741 4346744 4346753 4346836 4346822 4346624 4346627 4346634 4346635 4 ..... 1.96 1.63 0.67 0.67 0.5 0.69 0.27 1.67 1.67 2.5 2 2 2 170 70 68 81 93 114.5 110 72.5 45 45 47 49 49 49 27.9 ^ 2 ^ 54.1 200 22.4 300 28.4 130 23.6 130 106.1 200 44.6 255 29.1 110 15.2 H 66 15.2 66 30 80 40 80 10 80 20 80 S EG O Ma> Emissions from Sept 2002- Aug 2003 - 7,120 lb/yr oa> EXP015836 Summary o f M odeling Results Em issions Scenario - Year 2000 Actual Year 2002 Actual Sept 2002- A u g 2003 Maximum Annual Average Concentration (ug/m3) 2.67 1.36 0.86 Maximum Annual Average Concentration in Ohio (ug/m3) 0.87 0.36 0.18 O to GO 001 to EXPO15837 W :') / mil . ' September 2002 - August 2003 Emissions . ASH028063 EXP015838 V Air Permit Status Four permits cover APFO sources Each permit has been modified to place APFO em ission limits on each emitting unit Emission limits are hourly and annual Em ission limits were confirmed via air dispersion modeling to assure annual ambient air concentrations below 1 ug/m3 at fence line Future changes must not exceed the same fence line limit, demonstrated by m odeling Permit modifications effective Novem ber 26, 2003 Em ission limits will be included in Title V permit EXP015839 Additional Air Reduction Programs Continuing operational upgrades to five existing scrubbers - instrumentation, interlocks, operating conditions May, 2004 startup of additional filter scrubbers on four existing scrubbers - builds on technology recently developed on one scrubber at Washington Works - testing o f potentially more efficient filter media - Air Dispersion M odeling Verification Study o1oeom0 EXP015841 O b jective Compare results from ambient air sampling and air dispersion modeling to understand how modeling predictions relate to measured ambient air concentrations 8 o M C0D 0v1l EXP015842 Verification Study Scope Air Sampling Program Analytical Methods Modeling Analysis of Results 8 o tao> o <T\ CD EX P 015843 Conducted in Two Phases Phase I: Verification o f modeling at facility fence line Phase II: Verification o f modeling in community ON3 COD a\ E X P 0 15844 Phase I: Air Sampling L ocations Simultaneous coverage of all 4 major wind i directions (N, S, E, W) 1 Capture point of predicted maximum i concentration from modeling Include co-located samplers at predicted maximum Total of six locations & BO10 GO-4O O EXPO15845 EXP015846 ASH028Q72 EXP015847 Air Sampling Strategy Measure ambient air levels 24-hour sampling duration Seven (7) sampling events scheduled over 6 weeks Vary day of week to capture variations in daily operations (none expected) and variations in meteorology Record site-specific meteorological and operational data EXPO15848 Monitoring Strategy: Samples taken every 6 days for 6 weeks. MONTH 1 02 34 5 60 8 9 10 11 1 2 ( 1 3 ) 1 4 15 16 17 1 8 (1 9 )2 0 21 22 23 2 4 (2 5 )2 6 27 28 29 3 d G j) MONTH 2 12 34 5 0 7 8 9 [0 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 EXP015849 Total Samples (1) field blank per event (5) primary samples per event (1) duplicate sample per event*_____________ __ (7) samples x (7) sampling events = 49 total samples s K oN00) 001J * Sample location 3 is co-located with location 2 and serves as a duplicate sample E X P 0 15850 Equipment "Sorbent" sampling method to capture PFOA on ion-exchange media OSHA Versatile Sampling tube (OVS) Captures particles and vapors Remote power source will be provided Weatherproof stations for sampling gw O equipment to o o\ EXP015851 OVS Tube b-3 o q=i S -i i-- 1 ASH028077 EXP015852 Analytical M ethod Validated method being used Acetone extraction followed by liquid chromatography/mass spectrometry (LC/MS) Quantification limit of 0.1 ug/m3 Detection limit of 0.05 ug/m3 M odeling Program Using U.S. EPAISCST3 Model Model will simulate actual field conditions - Site-specific surface meteorological data (w ind speed and direction, temp, stability) - Off-site upper air meteorological data - Emissions data - 24-hour averaging time - Predictions at actual height and location o f air monitoring intake oN 0O-v0Jo EXP015854 Comparison o f R esults Comparing 35 pairs of measured and modeled data - (5) primary sampling points x (7) sampling events Will use statistical tools to evaluate correlation/differences between measured and modeled data Phase II: V erification o f M odeling in Com m unity Sampling and analytical protocol same as Phase 1 Locations will be selected to: - Correspond with a range o f predicted concentrations - Ensure security o f sample Sampling frequency - Expect 8 events at 5 locations during a six w eek period Summary o f Path Forw ard Item s Water - Execute MOU covering GIST recommendations - Gain agreement on OEPA proposal and DuPont suggestions - Propose the additional testing at the ECA process on December 9 Air - Conclude Phase I monitoring, modeling, and evaluation - 1Q04 - Begin Phase II effort - 2Q04 o tooo o owo EXP015857