Document B8wEYJ6Zg1BE8vB1ggJjJVaem

AR226-2570 [Andrew S Hartten To: Mary A Kaiser/AE/DuPont@DuPont cc: John R Bowman/AE/DuPont@DuPont Subject: Sampling Program Mary, l6/0T/20di'Q5T02 PM t I'm a little concerned about the decision to contract Battellle to provide sampling services related to the Consent Order. Let me provide a few Pros/Cons on the matter so you can see where I'm stand, then you can tell me how we should proceed. Time is short here and I'm very worried about being "quick" with respect to bringing a contractor on board when we can easily have a team in the field collecting "critical" samples (using new sampling SOPS) next week if we go with our folks. In addition, the time spent on my part and the plant's part managing and coordinating things will dramtically Increase if we go with Battelle. Alternatively, we could contract with Battelle to provide "training" prior to CO start (as per their program for "Multi Cities" which calls for training and passing procedure to "plant" personnel) and then we'd take it from there. Really, the SOPs they developed are very basic compared to some of the "other" things we do in the sampling world. Also, let the QC samples/program document the story. Use Battelle (vs On-site URSA/VW Site Resources) Pro -Developed 3M sampling procedure (used for "Multi-Cities Project") -Experienced using procedure (??-depends on resources you get) -True "3rd party" and respected in environmental world Con -Developing scope, getting quote, agreeing on scope, cutting contract will take valuable time -No DuPont plant site or W W plant site experience (don't have our "culture") -Will require signif. site and Iandfill(s) safety and process area safety training -Will require 100% DuPont oversight -Will require HASP review and new PSA (project safety analysis) -Aren't local and can't respond to "rapid" requests -No local sampling equipment, will have to ship and/or transport -No relationships and familiarity with plant, regulators and community -Likely (Including travel expenses and DuPont oversight) to be 4x cost -Technicians likely to be less experienced and unlikely to have the training that our URS/DuPont Site team will have, including, Profess Geologist with West Virginia Licensed Remediation Specialist (LRS) credentials (Note: we have an awesome CRG URS resource stationed at the site) -Will displace piant (DuPont) resource on Outfall samples, which may result in political issues -Worked for 3M (is this a conflict of interest?) -3rd party to Plant, CR&D and CRG project leadership and will require additional coordination and management time Another issue includes the fact that we have a large compliance program at the main plant and 3 landfills for "other constituents". Will Battelle collect these samples as well? It doesn't make sense to have a team purging wells and collecting C-8 samples, only to be followed by another team collecting everything else. (I'd have to make it a 6 sigma project). As to the 3rd party issue. This hasn't been as issue in years to DEP and ERA and I'm surprised they put the language in the draft CO. This would set a bad precedent and go against their own regulations (LRS noted above). If they have an issue around trust, then we can invite them to split some samples. E ID 317132 Let me know your thoughts. An audix is fine (since I know typing is difficult). If its Battelie no matter what, then let me know if you want me to try to find a contact in Duxbury, MA who worked on Multicities and begin the process. Take care. Andrew EXD317133