Document 6vZoyYaa907nRzXpX6wv1Ex3

AR226-2535 "w'' WASHINGTON WORK3, PAIUCBR8BUE6 ooyyEHTS w DRAFT BORA PEBMIT 1. Page 5, paragraph 8 - Inspection and Entry Reasonable advance notice should be given to the permittee for a, facility inspection or site visit. The advance notice will allow proper arrangements to be made by the persiittee to accomodate the inspector(s). 2. Page 9 ~ Itea A, paragraph 4 ~ Nature of VI Tha draft permit states that a Verification Investigation (VI) will be required for six SWBJa. According to this paragraph, the nature of a VI is to deteroiae if a more coaprehensive RCBA Facility Investigation (BFI) is needed. Several of the requirements for the VI are more appropriate for an ?1. We request that the permit specify that commonly-used field- screening technologies, such as soil-gaa surveying and eonepeBetratioa technology, caa be used for the purpose of the Verification Investigation. 3. Page 10, Item B-l first paragraph - Tiaeframe The perait requires that Du Font submit a VI work plan within 45 days of the effective data of the permit. This tuBefraae should be modified to Specify 60 days* The more reasonable fciaefrane is needed to assess the currently available data aad deteraino nhcre additional investigation is needed. 4. Paga 10, Itb.(l)() Considoriag the purpose of the VI as stated by the agency, e request that the peniitteB be allowed to take either soil or ground-later sattpies to determine th< oceurancs of eoatwiiaa.tion, if it can be justified. Accordingly, VB suggest that the wording of tha perait be modified froa "soil and ground-water samples are to be obtained1' to "soil and/or ground-TOter saaplea will be obtained.' This language will also provide ies consistency with Itea (3)(d) on pages 11 and 12 of the draft parait, which specifies that the permittee ay replace the ground-waiter investigation with an alternate sanpling methodology (e.g., aoil-gas surveying). CE'019242 EID182404 5. Page 11, Itea (2) - Saapling Parameters Attachment 1 of the Draft Permit contains the required sampling parameters for each of the SWa (except for the injection wells). This list contains over 100 compounds. Du Pant should he permitted to review tha plant records and If tailor the parameters to those conpounds expected to be present in the SVMU . the nature of the compounds present in the STOO is unknown, a nore comprehensive list of parameters would be appropriate* 6. Page 11, Item (2) - Analytical Methodologr It Attachment 1 contains the suggested methodology for analysis of samples. is our understanding that the laboratory can us alternate methods of analysis providing that they can justify the change. Th perait should be modified to include language specifying this understanding. 7. Page 13 Itea (3) - Tilneframe Ths peraifc specifies that the VI report must be submitted within 180 days of EPA'a approval of the nork plan. We request that the perait specify that an extension irill be granted if winter months are included in the 180-day period. Por examplftj if the plan is approved in late fall, the irinter ^aather is ths Parlceraburg area iill prohibit much of the field work (data collection). In addition, the VI rork platt aay specify a longer tiaefraae to? field work, based on the degree of data collection determined to be necessary. The binefraae in the perait should state 180 days or in accordance rith a schedule approved by EPA as specified in the VI rork plan. 8. Page 13, lien (4) - Tiaefraae Wa request that the tittefraae for sutoittal of existing ground-wa.te? data be extended from 45 to 60 days, Wa are currently iast&lling monitoring Trella and collecting sampling data. The Additional tine may allow for inorB complete iaforBation to be submitted. CE'019243 EID182405 9. Paga 16, Items (a) and (t) IITe suggest two additional wording modifications on pags 18, sections (e) and (f). The geologic cross sections should describe the extent of "all iapaeted agd/or potentially impacted hydrogeologic units~-- Presentation of -water level data will include "it ai&nlica.ble, vertical gradient sections.11 If, however, the shallow aquifer is not contaminated, deeper wells need not be installed at all locations. Vertical gradient inforaatioa aay not be collected in soae areas. 10. Page 17, Iten (3), first paragraph The added requirement that split or duplicate saBples ba takea-should-net-be-unnecessarily burdensome. 11. Page 17, ItMi (4) - Corrective Action Criteria SPA'a current policy regarding the criteria, used to. deterolna if a corrective neasures study is required should be nade available to Du Font* This infornation should include new corrective-action st&adarda or guidelines for eontaainant concentrations. 12. Page 22, Surface Water Sanpling The reattireiaeats for a surfaca-water study are too detailed. The surlace-TOter study should not require inflow, outflow, depth, teaperature stratitie&tioa, and volune of lakes and aatuaries. This information requires a coaplex investigation and collection of field data which nay bs unnecessary to achieve the desired goal of the BFI. This inforn&tion should only be required if it is shown to bt needed for delineation and/or reaediation of a release. 13. Pgs 28, Item B-3 - Report iBvision and Dispute Kesolution The tiMifraoea are unreasona.ble and should be modified W proposed belev: o The dr&It permit requires that DuPont submit & revised report/plan within 30 days of receipt of KPA's disapproval letter. If SPA'S ee--entB are extensive, nore tine will be required to revise the report. Due to the eeaplexity of the sift, we request that the tiaefraae be expanded to 80 day. When BPA's conaents are minor, the permittee 'rill make & good faith effort to submit revised report within 30 days. CS'019244 EID182406 o Dispute resolution; A. tinefraae of 18 days to respond to SPA'S of 30 comments is unreasonable. days to prepare a witten Ve ^ould need & ainiauia Ittstificatiott for the disagreeaents. The permit requires that a. revised nifchin 45 days of EPA's report/plan disapproval be submitted letter. We request that the tittefraae for souf braeictetaipl toof f a EPrAe'vaisreesdpopnlasen/rteopoourtr blee twteirthoinf 4e8xpdlaaynsation for the disagreement. 14. Pact Sheet, page 3, third full paragraph The tact sheet SWflJ states that if a release into the environnent substantial threat to huttan health and fron a occurs, a. the environment is assumed. This assumption wsy be incorrect in sone instances. All releases and/or probable releases be assumed to pose a significant should net indiscriainately threat to huaaa health and the environaeat. We propose that the last sentence of this paragraph be deleted. 15. Fact Sheet, page 6 - Polyacetal Products Incinerator The polyacetal products incinerator is not an open-buaming The process. reference The pits we covered in the pernit should during operation. be modified aseordiogly. 16. Fact Sheet, page 9, third full paragraph AHcaclotrsdinngiltlobtehematdaecitnsthbesetf, inaadjlusptemretlnitts Ifto atihtee-Bprpoepcoisteied feed in-f en-nation becomes available to justify the adjustments. proposed adjusted feed Attachaent 1, Units. The of this letter contains site-specific incinerator ata-ck dispersion modelling efforts which support these adjustments is documented ia Attachment 2. CB'01$245 EID182407