Document EO740XVmbmGJwBzBRj6DMajn

AR226-2563 OuPont FluaroproducB Onstnut Run Plaza P.O. Box 80702 Wilmiiiatlin.OE 1988(1-0702 DuPont Fluoroproducts September 28, 2001 Mr. Qarth Connor (3BC10) U. S. Environmental Protection Agency, Region ffl 1650 Arch Street Philadelphia,PA 19103 Via Federal Express Dee Ann Stoats, Ph. D. West Virginia DepaiOnent of Environmental Protection 1356 Hansford Street Charleston, WV 25301 Na BandDettveTy Re: First Supplemental Response to July 24,2001 Request for Information Dear Mr. Connor and Dr. Staate: On behalf of E. I. dnPont de Nemours and Company ("DuPont") we hereby file this Fast Supplemental Response to the Requestfor Information addressed to Mr. Paul Bossert at DuPonfs Washington Works facility and dated July 24.2001 ("Monnatfon Request"). This response supplements ovs initial response which was dated August 31, 2001. In providing this First SupplementalResponse, DuPont reiterates and falty incoiporates by reference its objectionsset forth in the August 31,2001 response. Additionally, this supplement does not include information relating to "capital requests' because DaPont is awaiting clarification from EPA Region HI as to meaning of (his term. When such clarification is provided, DuPont will address this information in an additional supplemental response. DuPont's supplemental responses are as follows: BEQUEST NO. 1: Provide a process flow diagram for each manufacturing process line and teeatmeat system where C-8 is utilized at me Facility. For each process unit in the manu facturing process Hoe or treatment system provide a narrative description of me process wait, a C-8 material balance for each process unit, the identification of me destination of C-8 (whether it is recycled, recovered, emitted to air, land or water), and the concenttanon of C-8 and its byproducts in each of me process streams. The basis for calculation should be me design capacity of the mat RESPONSE; DuPont's response is provided in Exhibit 1 to (his supplemental response. Illllll e.Hiil'nIB AN--BIB* Bill Clllilfiiiy I MimdaiRKytWFltB WSSM EID197012 First Supplemental Response September 28,2001 Page 2 of 4 BEQUEST NO. 2; Describe each treatment process used for As recovery or treatment ofPFOA and the effectiveness of each unit in the recovery or treatment ofPFOA or substances containing PFOA utilized at the Facility. BESPQNSE; DuPonfs response is provided in Exhibit 1 to this supplementalresponse. REQUEST NO. 3; For each of the previous five years quantifythe amount of C-8 utilized at me Facility and provide the quantity and composition of C-8 released into each media from each process unit and for the Facility as a whole. RESPONSE; DuPont's response is provided in Exhibit 1 to this supplementalresponse. BEQUEST NO. 5i Provide a copy of each document and study related to me treatment, disposal, containment, and remediation of C-8, commissioned by or conducted by DuPont, for all facilities. Include all documents related to such studies (including all capital requests and attachments thereto) and actions taken as the result of such studies. RESPONSE; DuPont supplements its August 31, 2001 response with me documents provided in Exhibit 2 to this supplemental response. BEQUEST NO. 7s Identifyall landfills utilized by DuPont to disposeof C-8 ftom the Facility where seeps or leakage or migration to groundwater have occurred. Describe what measures DaPont has taken to eliminate me seeps, and if the seeps have been eliminated. Provide all sampling data for all constituents from such seeps, including C-8. BESgONgE; DuPoBt supplementsits August 31,2001 response by providing sampling data for aU constituents for the Local, Letart. and Dry Run landfills ia Exhibit 3 to this supplementalresponse. BEQUEST NO. 9; Provide all monitoring and modeling of C-8 for groundwater, soil, surface water, air, sludges, sediments, tenestrial and aquatic species and humans ia West Virginia and Ohio. Include in your response a copy of each capital request for such monitoring and modeling and all attachments thereto. RESPONSE; DuPont supplementsits August 31,2001 response with me documents provided in Bxhibits 2 and 4 to mis supplementarlesponse. DuPoat has initiated as air roodelingstudy for PFOA at the Washington Works facility and when finalized, DuPont will submit the report of this modeling to the agencies. EID197013 ': First Supplemental Response September 28,2001 Page 3 of4 REOIJEST NQ. 11: Provide all sampling analysis and volume of any leachate or (^oundwater recovery systems in operation at any facility handling C-8 sludges flom the Facility, or other Teflon manufacturing byproducts, aad &e location and means of disposal of that waste/wastewater. RESPONSE; DuPont supplementsits August 31,2001 response with the documents provided in Exhibit 5 to flits supplementalresponse. REQUEST NO. 1?: Set forth in detail (he samplingprocedures and analyticalmethods for C-8 m water, soil, air and biological tissues. Describe if method differs dependingon location, e.g., landfill leachate versus efBueat outfall. Identify and describe what, if any, limitations or problems (e.g. adhesion to glass),.are associated with such procedures or methods. As a pbmt of clarification, the sampling and analytical procedures described in subparagrapha ofDuPont's August 31,2001 response to Request No. 12 apply to soil, groundwater and surface water. REQUEST JNO. l6i Provide a copy of each study and document related to qodstingor potential human health or environmental effects of C-8 conducted or commissioned by you or in your possession. Include all documents related to the need for such studies and actions taken as the result of such studies. RESPONSE: DuPont supplements its August 31. 2001 response with the documents provided m Exhibit 2 to this supplemental response. BEQUEST NO. 17: Provide a complete copy of the C-8 monitoring database for Facility employees on disk and identify format Include any results of blood sampling or urmafysesof the Facilityemployeeswhere C-8 was detected. RESPONSE; to response to this request, DoPont submits a complete copy of the APPO monitoring database for Facility employees on compact disk labeled as Exhibit 6. The database is formatted TO MS Word, BEQUEST NO. 19t Provide copies of all documents related to the procedures. Justification, background data, analysis, used to establish. DuPont's community and wolker action levels for C-8. EID1$7014 First Supplemental Response September 28,2001 Page 4 of 4 RESPONSE: DuPont supplementsits August 31, 2001 response with the documents provided in Exhibit 2 to this supplementalresponse. Should there be any questions related to this supplementalresponse please contact me at (302) $99-2415 or Bernard Reilty at (302) 774-5445. Very truly yours, 'T^a^O^u.^ David Rttrak ^NUP, ' Enctosurest cc: Janet E. Sharke, Esq. (w/o ends.) _ Doc.No. 17S441 EID197015