Document 6JKKEE3gDRdJonYEjeXoJ82R

AR226-3559 UO Jl. ??? i0 : b 3 Andrea V. M alinow ski Corporate Counsel DuPont Legal Wilmington Office Buildings 1007 Market Street Wilmington, DE 19898 302-774-6443 Tel 302-774-4812 Fax andrea.v.malinowski@usa.dupont.com E-mail UZ4 OVERNIGHT MAIL July 21, 2005 fn e & ~ 7 ^ -(b 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 Telephone: 202-564-8930 Ms. Mary Dominiak Office of Pollution Prevention and Toxics (OPPT) US Environmental Protection Agency EPA East, Room 441 OS 1201 Constitution Avenue, NW Washington, DC. 20460 Re: D ocket O PPT-2003-0012 and/or AR-226 r-o JU i 00 co IN3 o Dear Document Control Officer and Ms. Dominiak: Please find attached correspondence between DuPont and the West Virginia Department of Environmental Protection concerning Dry Run Landfill in West Virginia. Very truly yours, Attachment (9 pages) Andrea V. Malinowski E.l. du Pont de Nemours and Company OCOUNTAIN NO CBf Date 6/30/05 7/8/05 ATTACHMENT Document No. of pages Letter from West Virginia Department of Environmental 2 Protection (WVDEP) to DuPont Letter from DuPont to WVDEP in response to the June 30th letter 6 w att Virginia departm ent o f environmental protection Division o f Water and Waste Management 601 S f * Street SE Charleston, WV 25304 Telephone; (3 0 4 )926-0495 Fax; <304)926-0496 JoeM anchin [II, Governor Stephanie R. Timmenneyer, Cabinet Secretary www.wvdep.org June 30,2005 Mr.R.L. Ritchey DiiPonl Washington Works P.O .B ox 1217 Washington, WV 26181 ' - ........... Certified M ail- Return Receipt Requested Re: Request for Information Dear Mr. Ritchey: The agency received information on June 21,2005, indicating that the sampling results for C-8 taken at the Dry Run Landfill during the month o f May were at or above 150 ug/1. Based on our subsequent telephone conversation, it is our understanding that these higher levels may have been due to a seep that has since been captured and returned to the leachate collection sumps. To appropriately review this situation, the agency is in need o f additional information. 1, Please submit copies o f the laboratory reports for these samples, 2, During our telephone conversation, you indicated that an investigation into the cause o f the seep had been completed and the source identified. Please provide a summary o f this investigation to the agency for review. 3, What is the long-term solution for this seep, and when will it be completely implemented? 4, Please provide any subsequent C-8 sampling results since the 191,1o f May 2005. 5, A review o f the historical data continues to indicate that C-8 is present in file storm water diversion channels (Outlets 003 and 004), As these channels collect diverted storm water that are not associated with active landfill activities, has DuPont taken any investigative measures to determine the source o f C-8 in these outlets? Promoting a healthy environment. Mr. R.L. Richey June 30, 2005 Page 2 o f 2 6. Please provide information regarding the feasibility o f collecting wastewater from Outlet 001 and Outlet 005 and treating these at the Washington Works Plant. 7. Based on the fact that approximately 100,000 gallons per day o f wastewater at the Washington Works Plant is treated via activated carbon technology, please provide information regarding the feasibility o f treating all o f the abovereferenced waste streams generated at the Dry Run Landfill through this process. Please compile your responses to thse "comments ih d submit them to my attentibfh, or before the 8mo f July, 2005. If you should have any questions, please do not hesitate to contact me at 304-926-0499, extension 1018. Perm itting Program M anager cc: Environmental Inspector Environmental Inspector Supervisor O ffice o f Legal Services CDW E. I. du Pont de Nem ours and Company W ashington Works M ail: P.O. Box 1217 W ashington, WV 26181-1217 CERTIFIED M AIL RETURN RECEIPT REQUESTED July 8, 2005 Mr. Cliff D. Whyte, P.E. Permitting Program Manager Division o f Water and Waste Management West Virginia Department o f Environmental Protection 601 57th Street, SE Charleston, WV 25304 Dear Mr. Whyte: In reply to your Request for Information dated June 30,2005 ancLreceived on July 6,2005, DuPont provides the following responses, enumerated to parallel your original listing. 1. Three C-8 samples were taken from the discharge at the Dry Run Landfill Outlet 001 (pond outlet) in the month of May 2005. The seep was captured and routed to the leachate collection system on May 18. A sample was taken directly from the seep mentioned in your letter on May 19 in order to characterize the seep as requested by DEP representatives during a visit to the landfill on May 17. The requested laboratory reports for these four samples are attached. (Please note that the lab report incorrectly identifies die seep result as having been taken on M ay 5 as a consequence o f using the May 5 report template to create drafl reports for all four results.) All four results were reported to DEP representatives by email on June 21, as noted in your letter. 2. A report is being developed by personnel who conducted the investigation. We expect to receive the report by July 15 and will forward it to you when it becomes available. It is our understanding that the report will identify the source of the seep as being from above the geotextile membranes installed as part of the leachate collection system. 3. Since July 1, 2005, and in accordance with discussions with DEP representatives, the seep has been piped directly from the new french drain installed during the investigation to the leachate collection system, thereby eliminating the need for the temporary capture system for collection o f the seep, The piping was installed above ground in order to accomplish the task promptly. The long-term solution has yet to be defined and is expected to be the subject of further discussions between the permit writer and DuPont in order to determine an acceptable solution and to define what permitting steps are required before the work can commence. 4. There have been no additional sample results received for Outlet 001 discharges or for the seep itself since the May 18 and May 19 sampling discussed above. As communicated in a May 19 phone call to Mr. Steve Cooper o f your agency, DuPont discontinued its special sampling o f Outlet 001 once the capture system was in place. There is no June sampling result to report for Outlet 001 because o f a prolonged period o f low precipitation that has resulted in low pond levels. Analytical results from other sampling for C8 at permitted outlets during May have been reported with the DMR mailed to your agency on June 20, 2005. DuPont also has performed some sampling within foe sedimentation pond during the recent period o f no discharge from the sedimentation pond to Outlet 001. A sample was also collected for analysis from foe creek at foe property line. Please let us know if foe agency would like to have foe analytical results for these samples. E. L du Pont de Nem ours and Com pany Shipping: 8480 DuPont Rd W ashington, WV 26181 5. Work is underway to investigate Outlets 003 and 004 as to possible explanations for occasional anomalies in fecal coliform, aluminum and iron results. While C-8 has not been the focus o f this investigation, it is our expectation that the topographic work involved in this investigation will help answer the question you raise. Results o f this investigation are expected by September 30. We have also indicated in discussions with the permit writer that we anticipate addressing this issue with the closure and capping o f the landfill. 6. DuPont plans to develop and install carbon treatment technology at the landfill to treat these two wastewater streams in situ prior to discharge to Dry Run G eek. Design concepts have been discussed with the permit writer. The radically different nature o f the wastewater stream currently being treated at the Washington Works and the current and planned utilization of that existing treatment unit precludes treating these two streams through it, as explained in response 7 below. 7. DuPont process experts indicate that the activated carbon systems existing at Washington Works were developed and designed specifically for the wastewater streams emanating from the manufacturing process. They are designed to operate within narrow windows of operability, with a key consideration being the quality of the water entering filtration and carbon beds. Dirt, sediment, algae, and metals, especially in variable concentrations, would not be tolerated by the systems. Introducing such streams would ruin these very effective treatment systems. Furthermore, design of the existing treatment units is based on inlet C-8 concentrations much higher than those typically seen at the landfill. The exit concentration from the existing treatment unit at the plant is similar to the C-8 concentration o f the wastewaters generated at the landfill. Introducing the landfill wastewaters into the existing treatment systems at Washington Works may result in no significant removal efficiency for those low concentration streams. In addition, current plant site system utilization and plans for capturing additional process wastewater streams for treatment by mid-2006 will result in operating the unit at full capacity, making it unfeasible for treatment o f landfill wastewaters. As explained in response 6 above, DuPont is currently working to design and develop carbon treatment systems that can handle wastewater streams o f the nature of those generated at the landfill, focusing specifically on the wastewaters from Outlets 001 and 005 at the landfill. The information compiled in this letter has been collected in an expedited maimer to respond to your request within the very limited time period provided. DuPont will continue to work to address C8 concentrations in discharges from the Dry Run Landfill and looks forward to working with the agency to provide the information it desires in this regard. I f you have additional questions, please contact me at 304-863-4271. Sincerely, RLRvlw Attachment R o D e rt L . iu tc n e y Senior Environmental Control Consultant Washington Works RESEARCH Precise Research. Proven Results. A n alytical R esu lts D ry Run L an d fill C 8 S am pling 5/05 D uPont Sam ple Id en tificatio n \ A PPO (ng/L) PpO A (ng/L) DRL-Z-Outlet 001 DRL-Z-Outfet 0 0 5 DRL-Z-SS1 D R L -Z -S S 2 DRL-Z-LM1 Leachate ' DRL-K-FBLK-1 \ \ \ \ \ \ . 150000 41400 1510 73500 109000 ND 144000 39800 1450 70600 105000 ND Limit of Detection (LO D) for the procedure is appoximateiy 10 ng/L \ Limit of Quantitation (LO Q) for the procedure is 5 0 ng/L ND - Compound not detected \ NQ - Compound detected at a level betweeri-ihe LOD and LOQ. Result is not quantifiable. ND<LOD<NQ<LOQ \. Results are calculated according to the following criteria v . IFthe sample and laboratory duplicate are greater thar\25Q ng/L, and the relative percent difference (RPD ) is less than 2 0, the average value Is reported. IM ie RPD is greater than 20'. the higher value is reported. \. If the sample and laboratory duplicate are less tha 250 ng/L*. and the absolute difference is less than 50, tine average value Is reported. If the absolute difference is greater than 50, the higher value is reported. \' 058 Research Drive , Stata College, PA 1seen , USA VJ: 814372.1039 ft 814.231.1580 A n aly tica l R esu lts M OU S am pling 5/05 DuPont S am p le Id en tificatio n ! ~ ': APFO (tig /L ) P K >A (ng/L) L M 1-001 \ .' `' 157000 151000 Limit o f Detection (LO D ) fo rth e procedure is appoximately 10 ng/L Lim it o f Quantitation (LO Q ) for'Hie procedure is 50 ng/L \_ ND - Compound not detected \ ' NQ - Compound detected a t a level between the LOD and LOQ. Result is not quantifiable. . \' ND<LOD<NQ<LOQ ' \ "' Results are calculated according to the foliby/fng criteria - ' if the sam ple and laboratory duplicate are greater flian 250 ng/L, arid the relative percent difference (R P D ) is less than 2 0 , die average value is reported. If the R PD is greater than 20, the higher value is reported. . \' If the sam ple and laboratory duplicate are less tha 50 ng/L, and the absolute difference is less than 50, the average value is reported. If the absolute difference is greater than 50, the higher value is reported. \ \ \ sarch Drive PA 16801, USA A n aly tica l R esu lts MOU Sam pling 5/05- D uPont s am p le Id en tificatio n ' APFO (ng/L) PFOA (rig/L) LM 1-001 \; \ '' , Limit of Detection (LO D ) for'the procedure is appoximately 10 ng/L * Limit o f Quantitation (LO Q)-for 'tlie procedurals 50 ng/L. 155000. '. . ` . 149000 . * ] .. ND - Compound not detected , . \ . .. NQ - Compound detected at a level between the LO D and LOQ. Result is not quantifiable. \m . ND < LOD < NQ < LQQ '\ '. ' Results are calculated according to the following criteria * ** .\ * ' ' If the sample and laboratory duplicate a re greater than 250 ng/L, arid the relative percent d ifferen ce.. (R P D ) is less than 20, the average value Is reported, if the RPD 3_gcaater than 20, the higher value is reported. . . '' \ . If the sam ple and laboratory duplicate are less tha 50 ng/L, and the absolute difference is less than 50, the average value is reported. If the absolute difference is greater than 50, the higher value Is ' reported. V `' % ,3058 Research Drive State C o lle t PA 16801, USA t -. q i >i m i r i T o D u p o n t sam p le laehtfhcataon \ A PFO (n g /L) ' PFO A (ng/L) DRL-Leachate Pond \ ' \. Limit o f Detection (LO D) for'the procedure is appoximately 10 ng/L - * * i '* * . Limit o f Quantitation (LOQ) for 'the procedure is 50 ng/L 243000 ' 233000 ND - Compound not detected \ \ NQ - Compound detected at a level between the LOD and LOQ. R esult is not quantifiable. ND < LOD < NQ < LOQ \ Results are calculated according to the fol&wlng criteria \ _ If the sam ple and laboratory duplicata are greater than 250 ng/L, and the relative percent difference, (RPD) Is less than 20, the average value te reported. If the RPD Is greater than 20, the higher . value is reported. , \ *\\ If the sample and laboratory duplicate are less tha 250 ng/L, and the absolute difference is less than 50, the average value is reported. If the absolute difference is greater than 5 0 , the higher value- is reported. '\ \ Research Drive ; Coiiege, PA 1.6801, USA