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AR226-2360 E.!.du Font tie Nemours and Company WashingtonWoria Mall: P.O. Box 1217 Washington,WV 26181-1217 April 16, 2004 Allyn G. Turner, Director Division of Water and Waste Management 414 Summers Street Charleston, WV 25301 DearDirectorJumer, In connection with recent discussions between representatives of the West Virginia Department of Environmental Protection ("DBF") and representatives of E.I. du Font de Nemours and Company ("DuPont") regarding the recommendations contained in the report titled "Ammonium Perfluorooctanoate (C-8) Groundwater Investigation Steering Team Report," dated August''2003 (the "Final GIST Report"), DuPont submits the attached proposal. The attached proposal addresses recommendations in the Final GIST Report that cannot be incorporated as conditions in environmental permits issued to DuPont by the DEP and is intended to reflect our discussions with DEP representatives. It is DuPont's intention to implement the attached proposal or the proposal with such modifications as are deemed necessary to cany out the recommendations in the Final GIST Report upon receipt of your approval. At that time, a more formal Work Plan will be submitted reflecting actual sampling locations, sample collection methodology, analytical procedures, and a schedule for implementation, m the meantime, if you have any questions concerning this proposal please contact Andrew Hartten at 302-992-6820. Plant Manager DuPont - Washington Works PJB/djp Attachment cc: bcc: M. A. Bradley - Spilman, Thomas & Battle A. V. Malinowski - DuPont Legal - Wilmington D. W. Booth - DuPont - Wilmington A. S. Hartten - DuPont - Wilmington R. L. Ritchey - DuPont - Washington Works E. I. du Font de Nemours and Company Shipping:8480 DuPont Rd Washington, WV 26181 EXP000377 PLAN FOR IMPLEMENTATION OF GIST RECOMMENDATIONS Submitted by E.I. du Font de Nemours and Company April 16,2004 m response to the recommendations of the Groundwater Investigation Steering Team ("GIST") as set forth in me report titled "Ammonium Perfluorooctanoate (C-8) Groundwater Investigation Steering Team Report," dated August 2003 (the "Final GIST Report"), E.L du Pont de Nemours and Company ("DuPont") will perform the following tasks upon the terms and conditions indicated:' 1. To implement recommendations of the Final GIST Report with regard to West Virginia public water supply systems, subject to obtaining the consent of the system owners, DuPont will: a. Beginning in the second quarter of 2004 and ending with the first quarter of 2006, sample quarterly the Lubeck Public Service District, DuPont Washington Works and General Electric public water systems at the locations identified on Attachment 1. b. Once in calendar year 2004 and once in calendar year 2005,2 sample the production wells indicated on Attachment 1 at the Blennerhassett Island State Park, Mason County Public Service District and Racine Lock and Dam Public Water System. c. Beginning in the second quarter of 2004, DuPont will implement a limited field investigation of C-8 in soil at the Lubeck Public Service District as reflected in Attachment 2, and will report the results of such investigation during fourth quarter of 2004. 2. To implement the recommendations of the Final GIST Report with regard to Ohio public water supply systems, subject to obtaining consent of the property owners, DuPont will: a. Beginning in the second quarter of 2004 and ending with the first quarter of 2006, sample quarterly the Little Hocking Water Association public water system at the locations indicated on Attachment 1. 1 This plan does not address those recommendations of the GIST that relate to sampling at DuPont facilities that are covered by environmental permits issued by the DEP. Such permits have been or will be issued or modified to include those recommendations of the GIST applicable to these facilities. 2 Annual samples taken under this plan will be taken at least 12 months apart. EXP000378 b. Once in calendar year 2004 and once in calendar year 2005, sample the Tuppers Plains-Chester Water District public water system at the locations indicated on Attachment 1. 3. To implement the recommendations of the Final GIST Report with regard to additional sampling of private water supplies, DuPont will, subject to obtaining the consent of property owners: a. Collect additional samples from private water sources at locations near the Washington Works facility and the Local Landfill by sampling ten locations within the five categories listed below on a quarterly basis for one year, beginning in the second quarter of 2004, with at least one of the sample locations being fiom each of the five categories listed below: (1) Drinking water wells with detected levels ofC-8; (2) Drinking water springs with detected levels of C-8; (3) Non-drinking water wells with detected levels of C-8; (4) Springs and cisterns with detected levels of C-8; (5) One well or spring used for cattle where prior sampling has detected C-8 concentrations above 5 ug/L. b. Collect one sample during each calendar year 2004 and 2005 from each of the GERLACHIBA and BRINKERA private water supply sources near the Letart Landfill. c. Collect additional samples from private water supplies at locations near the Dry Run Landfill by sampling ten locations within the three categories listed below on a quarterly basis for one year, beginning in the second quarter of 2004, with at least one of the sample locations being from each of the three categories listed below: (1) Drinking water wells with detectable levels of C-8; (2) Drinking water springs with detectable levels of C-8; (3) Springs and cisterns with detectable levels of C-8. d. Collect additional samples from private water supplies in Ohio by sampling ten locations within the four categories listed below on a quarterly basis for one year, beginning with the second quarter of 2004, with at least one of the sample locations being from each of the four categories listed below: (1) Drinking water wells with detectable levels of C-8; (2) Drinking water springs with detectable levels of C-8; (3) Non-drinking water wells with detectable levels of C-8; (4) Springs and cisterns with detected levels of C-8. In addition, DuPont has agreed to sample an eleventh location, for the same time period, chosen with input from Ohio EPA. EXP000379 4. Upon completion of the sampling described herein DuPont and the DEP will confer with the GIST to determine what, if any, additional sampling is necessary to evaluate trends ofC-8 concentrations or to otherwise implement the recommendations of the Final GIST Report. 5. Within 30 days of receipt of the validated data for samples collected in the preceding calendar quarter, DuPont will submit to DEP a written report of the results of such sampling. 6. Written reports of any sampling to be performed described in this plan or any other communication related to this plan will be directed as follows: ForWVDEP: [Insert designated contact person or position and mailing address] ForWVDHHR: For DuPont: Andrew S. Hartten E. I. DU FONT DE NEMOURS AND COMPANY P. 0. Box 80027 WilmingtonDE 19880-0027 ^p000380 Attachment 1 j 1) Little Hocking Water Association Wells designated as LHPSD1, LHPSD2, LHPSD3, LHPSD5, LHPSDEP001, and Finished Water 2) Lubeck Public Service District Wells designated as LPSD Well A, LPSD Well B, LPSD Well C, LPSD Well D, LPSD Well E, LPSD Well F, and Finished Waters (LPSDAT) 3) DuPont Washington Works Wells designated as AM07-PW01, A008-PW01, AX13-PW01, K16-PW01, L04PW01,andV05-PW01 4) General Electric Well designated as GE Well 3 5) Blennerhasset Island State Park Well designated as BLENISEPS1 6) Mason County PSD Wells designated as MASONCPSD1, MASONCPSD2, MASONCPSD3 7) Racine Lock and Dam PSD Well designated as RACINELD 8) Tuppers Plains-Chester Wells designated as TPPSDW1, TPPSDW2, TPPSDW3, TPPSDW4, TPPSDW5, TPPSDW6, and Finished water (TPPSDAT) EXP000381 <-^ Attachment! PROPOSED SOIL INVESTIGATION AT THE LUBECKPSD, LUBECK, WEST VIRGINIA DuPont proposes implementing a limited field investigation to sample for C-8 in soil at the Lubeck Public Service District (PSD) well field to comply with the recommendations of the Final Groundwater Investigation Steering Team (GIST) Report (GIST, 2003) for West Virginia. The objective of this field investigation is to determine if air emissions of C-8 from the DuPont Washington Works facility are deposited on the Lubeck well field surface soils and are a possible secondary source of C-8 in groundwater. As determined by the GIST, the primary source of C-8 in groundwater at the Lubeck PSD is Ohio River surface water that contains low concentrations (i.e., around 1 ug/L) of C-8 recharging the alluvial aquifer at/near the Lubeck PSD. For the field investigation of soil at the Lubeck PSD, DuPont proposes conducting two soil sampling events in the late spring 2004, one following a "wet" period and one following a "dry" period. The "wet" period will be defined using the United States Environmental Protection Agency (USEPA) stormwater sampling requirements (40CFR122.21(g)(7)]. A "wet" period or acceptable storm to collect surface water samples is defined by the USEPA as a 72 hour period with less than 0.1 inches of rain fall followed by a rainfall event that is forecasted not to vary more than 50 percent of the average or median event for the sampling area. For the Lubeck PSD, which is located in the Northeast Rain Zone (USEPA July 1992, exhibit 2.8), the representative storm or "wet" event will range from 5.6 to 16.8 hours in duration and will include between 0.25 and 0.75 inches of rainfall. Soil samples will be collected within 24 hours of the acceptable storm event. The "dry" sampling event will be defined in this investigation as greater than 72 hours with less that 0.1 inches of rainfall. Soil samples will be collected within 48 hours of the acceptable "dry" period. For the proposed field investigation of soil at the Lubeck PSD, DuPont will sample surface soil from three locations within the well field. Sample locations will be selected based on field conditions. The three sample locations will be selected that most closely resemble each other (similar vegetation type, topography, etc). At each location, two soil samples will be collected immediately adjacent to each other during each sampling event. Both samples will consist of the growing vegetation, the litter layer (the layer of decomposing yet still identifiable organic matter), and the first six inches of organic material and mineral matter immediately under the litter layer. The first soil samples will be collected using a soil punch (a six inch long punch or thin walled steel tube) or equivalent to extract six inch cores from the soil. The sample will be divided in the field based on visual observation into two portions, an organic-rich portion (vegetation, litter layer and root zone) and a mineral matter-rich portion (material below the root zone). Both portions of the soil sample, the organic-rich and the mineral EXP000382 matter-rich will be sent to a contract laboratory for analysis ofTOC and C-8 using appropriate analytical methods. Prior to analysis for C-8, an attempt will be made to separate any liquid (water) from the soil (organic-rich and mineral matter-rich) samples for independent analysis. Alternatively, soil (organic-rich and mineral matter-rich) samples may be washed with deionized water to determine adsorbed or "external" C-8, prior to processing the soil samples for analysis. Note that DuPont is not currently aware of a validated analytical method for determining C-8 concentrations in organic matter. Analysis of the organic rich samples will not take place until completion of method validation. Sample handling and storage will follow the protocol outlined in the QAPP (to be revised prior to sample collection). The second soil sample will be collected immediately adjacent to the first soil sample and will be collected using a ring sampler (a seamless steel ring six inches in diameter) or equivalent that is driven into the soil to a depth of six inches. This larger volume sample will be used to determine the soil classification at the location. Soil classification will be determined at the URS Corporation Geotechnical Laboratory, Totowa, NJ according to ASTM D2487 and will consist of determining me following soil characteristics: Grain Size, ASTM D422 Atterburg Limits, ASTM D4318 Additional soil tests which are not part of the soil classification determination but which may be determined are: Specific Gravity, ASTM D854 Organic Content, ASTM D2974 Water Content, ASTM D2216 Following sample collection at each location, the sampling location will be surveyed and marked using flagging so that the second sampling event can be conducted at a location immediately adjacent to where the first set of samples were collected. DuPont will issue a report documenting the field investigation and presenting the results after both rounds of sampling have been conducted and the analytical and soil classification results have been received. EXP000383