Document RpByLmed023yBJ1z506d4JvYn

AR226-2358 DRAFT PHASE II MONITORING/SAMPLING WORK PLAN DUPONT WASHINGTON WORKS SITE WASHINGTON, WEST VIRGINIA Date: March 2004 Project No.: 507423 18983990.04006 18983992.04006 CORPORATE REMEDIAT10N GROUP An Alliance between DuPont and URS Diamond Barley Mill Plaza, Building 27 Wilmington, Delaware 19805 EXP000387 Draft Document Do Not Cite or Quote, March 30, 2004 Draft Phase II Monitoring/Sampling Work Plan____ _____ ______Table Of Contents TABLE OF CONTENTS 1.0 1 Introduction....................--...............................--...,........--................--..................... 2.0 Background Information............................................................................................ 3 3.0 Air Modeling Verification Study............................................................................... 5 3.1 Phase II Air Monitoring Activity...................................................................... 5 3.1.1 Air Sampling Events, Duration and Locations.................................... 5 3.1.2 Number of Samples ............................................................................. 5 3.1.3 Sampling Equipment, Methods and Schedule..................................... 6 3.1.4 3.1.5 3.1.6 3.1.7 3.1.8 Analytical Methods..............................................................................6 Meteorological Monitoring.................................................................. 7 Meteorological Data..........................--............................................... 7 Model Selection and Methodology...................................................... 8 Receptor Selection.........--................................................................... 8 3.2 Progress Reports and Results --.........................................................................8 4.0 Water Monitoring Activities...................................................................................... 9 4.1 Private Water Sources..........................;............................................................ 9 4.1.1 West Virginia: GIST Conclusions and Recommendations For 4.1.2 West Virginia Private Water Supply Sources...................................... 9 West Virginia: Private Water Supply Sources Activities.................. 10 4.1.3 Ohio: GIST Conclusions and Recommendations for Ohio Private Water Supply Sources........................................................... 11 4.1.4 Ohio: Private Water Supply Sources Activities................................. 12 4.2 Public Water Sources...................................................................................... 13 4.2.1 West Virginia: GIST Conclusions and Recommendations for 4.2.2 West Virginia Public Water Supply Sources..................................... 13 West Virginia Public Water Supply Sources Activities.................... 13 4.2.3 Ohio: GIST Conclusions and Recommendations for Ohio 4.2.4 4.2.5 Public Water Supply Sources............................................................ 14 Ohio Public Water Supply Sources Activities................................... 14 Ohio: OEPA Recommended Well Installation at Little Hocking Water Association Well Field............................................. 15 5.0 Surface Water and Groundwater Monitoring........................................................... 17 6.0 Surface Soil/Biota (Vegetation) Sampling............................................................... 18 7.0 Schedule and Reporting...................................................................--.---......--...... 20 8.0 21 References.......................................................................................................... 2004WorkPlan4.doc Wilmington, DE EXP000388 I Draft Document Do Not Cite or Quote, March 30, 2004 Draft Phase II Monitoring/Sampling Wori< Plan Table of Contents Table 1 Table 2 Table 3 TABLES, Summary Data for Proposed Sampling Locations In and Around DuPont Washington Works Site Summary of GIST Private Water Source Sampling Recommendations Summary of GIST Public Water Source Sampling Recommendations Figure 1 Figure 1.5 Figure 2 Figure 2A Figure 3 Figure 4 Figure 5 Figure 6 FIGURES Offsite Monitoring Locations Near the Washington Works Facility/Local Landfill in West Virginia and Ohio OVSTube Offsite Monitoring Locations Near the Dry Run Landfill in West Virginia Wind Rose - DuPont Washington Works Offsite Monitoring Locations Near the Letart Landfill in West Virginia Public Water Source Monitoring Locations in West Virginia and Ohio Proposed Locations of the Four Shallow Wells at the Little Hocking Well Field Washington Works MOU Schedule Appendix A APPENDICES Phase II Quality Assurance Project Plan, DuPont Washington Works Site, Washington, West Virginia 2004WorkPlan4.doc Wilmington, DE EXP000389 Draft Document Do Not Cite or Quote, March 30, 2004 Draft Phase II Monitoring/Sampling Wo* Plan ______ ________ Introduction 1.0 INTRODUCTION This Phase n Monitoring/Sampling Work Plan (Work Plan) is referenced as Appendix 5 in a Memorandum of Understanding (MOU) between the United States Environmental Protection Agency (USEPA) and E. I. DuPont de Nemours and Company (DuPont) that documents DuPont's intent to conduct a Perfluorooctanoic Acid (PFOA) Site-Related Environmental Assessment Program. This MOU summarizes DuPont's commitment to provide additional media-specific monitoring of PFOA by conducting a PFOA SiteRelated Environmental Assessment Program at and near the DuPont Washington Works Site in West Virginia. PFOA is a disassociated form of ammonium perfluorooctanoate (APFO, commonly known as C-8 and historically know as FC-143) and other salts. PFOA is the entity detected by the analytical instrument for all media. Soil and aqueous samples will be analyzed for PFOA and reported as C-8 for consistency with historical, including Phase I, results. C-8 results for soil and aqueous samples are obtained through a mathematical conversion. PPOA results for soil and aqueous samples are multiplied by the ratio of the molecular weight of C-8 over the molecular weight of PFOA. Air and biota samples will be analyzed and reported as PFOA. The PFOA Site-Related Environmental Assessment Program employs a phased approach. Phase I includes commitments previously made by DuPont that were memorialized in a Letter of Intent (LOI) and that includes environmental monitoring and modeling activities at and near the DuPont Washington Works Site in West Virginia. Phase I also encompasses other relevant environmental work not within the scope of the LOI. Many of the Phase I environmental monitoring/modeling commitments have already been conducted. However, some Phase I commitments, such as surface water and groundwater monitoring at the Local, Letart and Dry Run Landfills per West Virginia National Pollutant Discharge Elimination System (WV/NPDES) permits WV0001279, WV0076538, WV0076066 and WV0076244, are ongoing. Details of the LOI commitments and other relevant environmental commitments can be found in Appendices 3 and 4 of the MOU. A listing of submissions made by DuPont pertaining to environmental monitoring/modeling at or near the DuPont Washington Work facility is also provided in the Appendix 1 of the MOU. Phase II of the PFOA Site-Related Environmental Assessment Program includes activities that augment and build upon the LOI and other relevant environmental commitments. Phase II includes sampling on-site and sampling off-site in both West Virginia and Ohio. The following media will be sampled during Phase II: Q Air Q Drinking water sources (private and public water sources) Q Groundwater Q Surface water Q Soil Q Biota EXP000390 2004WorkPlan4.doc wilmington, OE 1 Draft Document Do Not Cite or Quote, March 30, 2004 3 Draft Phase II Monitoring/Sampling Wotk Plan Introduction A description of the Phase n work for each media is provided in this Work Plan. All work described in this Work Plan will be completed by DuPont or its authorized representatives. This document is organized into the following sections: Q Background Information Q Air Modeling Verification Study Q Water Source Monitoring Activities Q Surface Water and Groundwater Monitoring Activities Q Soil/Biota (Vegetation) Sampling Activities Q Schedule and Reporting Q References For each media section, a brief discoufsssiaomnpolifntgheisspturedsyeonbtejedcitnivteh,issaWmoprlikngPllaonc.atTiohnes, nQuumalbiteyr Aosf ssuarmapnlcees,ParonjdecfrtePqluaenn(cQyAPP describes the specific procedures and practices that were and will be followed to ensure that data generated during the Phase II investigation at and near the DuPont Washington Works facility in West Virginia and Ohio are technically sound, usable, and properly documented. 2004WorkPlan4.doc Wilmington, DE EXP000391 Draft Document Do Not Cite or Quote, March 30, 2004 The multi-media Consent Order was entered into between the WVDEP, the West Virginia Department of Health and Human Resources - Bureau for Public Health (WVDHHR-BPH) and DuPont on November 15,2001. The Consent Order identified a series of requirements and tasks to be performed by the parties (WVDEP, WVDHHRBPH, and DuPont) in order to determine whether there has been an impact on human health and the environment as a result of releases ofC-8 from DuPont operations at the Washington Works facility (facility) and the associated landfills (Local, Letart, and Dry /fheConsent Order established the C-8 Assessment ofToxicity Team (CATT),\which consisted OTsscientists from academia (Marshall University), govenuttent (USEFA, EPA Region 3,WVDEP, WVDHHR-BPH), non-profit org^uzation[sNatiohal Institute Iw Chemical Studies (NICS), Toxicology Excellence for Risk Assessment WERA)], anas. Veinndvuirsotrnym(eDnutPaossnotc'^iaMte)d, twoitahsseexsps/lmoes^utroeKTicdit^y~ar8rdidearsilpks tforonnmrnDaunPhoenatltahctaivniotitehse^The \^ Q\TT established thenuman health protective C-8 screenmg\riteria for water^C-8 watesSL) of 150 ug/L, the C-8 screening crrteria of 240 mg/kgreff soils (C-8 soinsiL; WVDBP, 2002), and the Aquatic Life Advisor^Concentration for^.8 (C-8 ALAC) of 1,360 uffL (Menzie-Cura & Associates, 2002). V^,________V-____^----- The Consent Order atee established the C-8 Groundwater Investigation Steering Team (GIST), which consisted of scientists from WVDEP, WVDHHR-BPH, USEPA Region III and DuPont, to oversee investigations and activities conducted under the Consent Order. These tasks included Task A: Groundwater Use and Well Survey/Groundwater Monitoring, Task B: Assessment of Existing Groundwater and Surface Water Monitoring Data, and Task C: Plume Identification/Groundwater Assessment at each site. Upon DuPont's completion of Tasks A, B, and C, and comparison ogthe resulto to tho CATT- BOtabliohod oerconing-oritcria, DuPont issued the C-8 Data Summary Report (DuPont, 2003) to the GIST. The GIST then prepared its Final C-8 GIST Report (GIST, 2003) with findings and conclusions regarding groundwater quality and the extent of groundwater impacts. These documents are in the EPA Docket as OPPT-2003-00120039 and OPPT-2003-0012-0204, respectively. EXP000392 Note: In the Consent Order, C-8 means ammonium perfluorooctanoate (CAS Number 3825-26-1). 2004WorkPlan4.doc Wilmington. DE Draft Document Do Not Cite or Quote, March 30, 2004 Draft Phase II Monitoring/Sampling Work Plan________________________Background Information The Final C-8 GIST Report (GIST, 2003) also presented recommendations regarding the need to conduct further work. In addition to the recommendations made by the GIST, the OEPA, which was a non-voting member of the GIST, also made recommendations that additional work be conducted in the state of Ohio, across the Ohio River from the Washington Works facility in West Virginia. Around this same time, USEPA began its exposure assessment investigation of C-8. DuPont and other members of the Fluoropolymer Manufacturers Group (FMG) shared available data on PFOA in the environment with USEPA. Discussions occurred amongst USEPA and industry concerning the need for and type of data that would be useful and relevant to assess sources and pathways of exposure to PFOA. In this Work Plan, DuPont presents the details of the sampling, monitoring, and modeling activities it intends to conduct during Phase II, as based on discussions with one or more of USEPA, GIST and OEPA. Details of the specific procedures and practices that will be followed to ensure that the Phase II data generated are technically sound, usable and properly documented can be found in the QAPP located in the attached Appendix A. 2004Wori<Plan4.doc Wilmington, DE EXP000393 4 Draft Document Do Not Cite or Quote, March 30, 2004 Draft Phase II Monitoring/Sampling Work Plan Air Modeling Verification Study 3.0 AIR MODELING VERIFICATION STUDY DuPont is conducting a two-phased verification study to compare results from air dispersion modeling to ambient air sampling data. The purpose of this study is to understand how modeling predictions relate to measured ambient air concentrations of PFOA. To evaluate this objective, actual ambient air modeling will be performed in two phases. Phase I activity has been initiated and includes perimeter monitoring at six locations at the Washington Works fenceline. The details for this activity will be set forth in EPA public docket document number OPPT-2003-0012. Phase II of the verification study activity is described in this Work Plan. 3.1 Phase II Air Monitoring Activity 3.1.1 Air Sampling Events, Duration and Locations The Phase II air monitoring program will consist of seven sampling events conducted over a period of six weeks. During each sampling event, one sample will be collected over a 24-hour period at each location. One sampling event will occur every six days during the six-week period. The sample network will consist of nine locations, seven in Ohio and two in West Virginia. These locations are shown in Figure 1 and listed in Table 1. Sample locations were selected based on the following rationale: Q To be representative of the complete range of wind directions (North, South, East, and West). Q To provide sufficient spatial coverage up to 2 kilometers from the site. Because a physical terrain barrier (ridge) exists approximately 2 kilometers to the north of the site, meteorological conditions outside that radius would differ from those measured by the site meteorological station. These data points would not be consistent with the rest of the data set, creating conditions that are not optimal for conducting a verification analysis. Q To evaluate potential concentration gradients along prevailing wind directions to the northeast and east to west (see Figure 2A for the wind rose). Q To coincide with co-located soil and grass samples, in order to gain a better conceptual understanding of important environmental compartments. 3.1.2 Number of Samples A total of 77 samples will be analyzed over the duration of the program. The samples will include the following: Q One field blank per sampling event Q One sample from each of the nine sampling locations per ever* EXP000394 2004WorkPlan4.doc wilmington. DE 5 Draft Document Do Not Cite or Quote, March 30, 2004 Draft Phase II Monitoring/Sampling Work Plan__________A8r Modeling Verification Study Q One duplicate (co-located) sample for each event, place at a location where concentrations are expected to be highest Q A total of 11 samples per event x 7 events == 77 samples 3.1.3 Sampling Equipment, Methods and Schedule Sampling will be conducted using a sorbent method for collection and analysis. In general, this method involves drawing ambient air through a medium and adsorbing the analyte of concern onto that medium. The collected species are preserved and shipped to a laboratory for analysis. The laboratory desorbs the analyte from the medium and proceeds with analysis. For collection and analysis ofPFOA, the Occupational Safety and Health Administration (OSHA) Versatile Sampling (OVS) tube with a 0.3 micron filter will be used (catalogue # 226-58 from SKC, Inc., Eighty Four, Pennsylvania, or equivalent). This tube is uniquely designed to simultaneously capture aerosols and vapors (see Figure 1.5). Details describing the tube design are included in Appendix A. Pumps will be required at each sampling location to provide airflow through sample tubes. Sample pumps, such as the Universal PCXR4, capable of 500 mL to 1,500 mL/minute flowrate will be specified. The samplers will be set to run at approximately 1 liter per minute for a total volume of 1.44 cubic meters over the 24-hour sampling period. Sampling equipment will be mounted on poles and covered as needed to provide protection from weather and other potential damage. If these locations do not have AC power, battery operated pumps will be used. Duplicate pumps will be provided at each location to minimize potential power failure issues. Field personnel will be trained by professional industrial hygienists familiar with OVS equipment. Field logs will be provided to record pertinent information during sampling events. Sampling is expected to begin in the second quarter of 2004 (2Q2004), provided property owners grant permission for sampling. If a property owner declines permission, an alternative air sampling location will be proposed by DuPont. 3.1.4 Analytical Methods Ambient air samples will be analyzed by Exygen Research of State College, Pennsylvania. Exygen will use analytical methodology that has undergone third-party validation and has been submitted to the public docket under OPPT-2003-0012-0317 through 0318. The methodology uses a methanol extraction with liquid chromatograph/mass spectrometer (LC/MS) system to detect PFOA. Method detection limits are approximated at 0.1 ug/m . Contents of sample tubes will be analyzed separately for vapor and particles greater than 0.3 microns, then composited for a total concentration at each sampling location. Additional details of the analytical methodology can be found in the QAPP (see Appendix B). 2004WorkPlan4.doc Wilminglon, DE EXP000395 6 Draft Document Do Not Cite or Quote, March 30, 2004 Draft Phase II Monitoring/Sampling Work Plan__________________Air Modeling Verification Study 3.1.5 Meteorological Monitoring Meteorological measurements will be taken during each event using an on-site meteorological station. The use of an on-site meteorological station ensures the data are representative of conditions at the perimeter of the site. Data collected during each 24-hour sampling event will include the following: 0 Hourly average wind speed 0 Hourly average wind direction Q Hourly average ambient air temperature Q Calculation of stability class 0 Phase II Air Modeling Activity Q Emission Inventory Source Characterization The following information will be collected and used as input into air dispersion modeling: Q Stack locations Q Stack heights- Q Stack diameters 0 Stack gas exit temperatures Q Stack gas flow rates or exit velocities Q Emission rates Methods for Estimating Emissions Site-specific operational data will be used to relate production data to emissions levels using a factor. Through a combination of actual stack monitoring (for vents with highest emissions) and mass balance estimates (for vents with very small emissions), a factor has been established for each PFOA emission point to estimate the quantity of emissions released at a given production rate. This factor will be combined with production data to calculate PFOA emissions during each 24-hour sampling event. 3.1.6 Meteorological Data On-site meteorological data will be collec.ted during each sampling event, as described in Section 3.1.5. Concurrent twice-daily upper air observations will be collected from the upper air station located in Wilmington, Ohio in order to compute hourly mixing depth. Both sets of data will be combined and preprocessed by Trinity consultants of Dallas, Texas, to be used as input to the air dispersion model. Missing data and measured wind speeds of less than 1.0 m/s will be treated consistent with the recommendations in USEPA's Meteorological Monitoring Guidance for Regulatory Model Applications. An anemometer height of approximately 9.14 meters will be used for modeling analysis. 2004WorkPlan4.doc Wilmington, DE EXP000396 Draft Document Do Not Cite or Quote. March 30, 2004 Draft Phase II Monitoring/Sampling Work Modeling Verification Study Plan__________________AlF 3.1.7 Model Selection and Methodology The Industrial Source Complex Short Term Model (ISCST3), version 02035 will be used to conduct air dispersion modeling. All modeling will be performed in accordance with the procedures in USEPA's Guideline on Air Quality Models (40 CFR Part 51, Appendix W). All model options will be set to the USEPA default version of ISCST3. PFOA emission sources will be evaluated for downwash effects from surrounding buildings. USEPA's Building Profile and Input Program (BPIP) will be used to provide wind direction specific building parameters. All buildings on site will be evaluated to determine if these buildings could potentially impact the stack by causing building downwash effects. The area surrounding Washington Works is primarily non-urban. The USEPA procedures classify land use within 3 kilometers of the site by the Auer method. Previous review of the U.S. Geological Survey (USGS) maps, aerial photographs, and site visits indicate the area is well over 50% non-urban. The Washington Works facility is located within the Ohio River Valley, and is surrounded by significant terrain features on both sides of the river valley. As a result, terrain elevations will be considered in the modeling analysis. An averaging time of 24 hours will be used to simulate the duration of field sampling. 3.1.8 Receptor Selection Receptors will be placed at exact coordinates of the perimeter sampling locations shown in Figure 1. A Global Positioning System (GPS) will be used to identify UTM coordinates of each sample location. The aboveground elevation of intake tubing for each sample location will also be measured and input into the ISCST3 model. 3.2 Progress Reports and Results Progress of Phase II sampling will be summarized in semi-annual status reports that will be issued by DuPont. Following completion of Phase II air monitoring and modeling, DuPont will submit a report, no later than 30 days after the report is finalized to USEPA, WVDEP, and DEPA providing results of the verification study (Phases I and II). 2004WorkPlan4.doc Wilmington, DE EXP000397 8 Draft Document Do Not Cite or Quote, March 30, 2004 Draft Phase II Monitoring/Sampling Work Plan ___ Water Monitoring Activities 4.0 WATER MONITORING ACTIVITIES In the Final C-8 GIST Report (GIST, 2003), conclusions were presented and recommendation were made related to the three tasks performed by DuPont and evaluated by the GIST (Tasks A, B, and C). Task A required DuPont to conduct a distance-phased public water supply service survey along the Ohio River on both the West Virginia and Ohio sides of the river. Subsequent to the Task A requirement, a one-mile (and possibly a two- and three-mile) radial distance of the Washington Works facility and Local, Letart and Dry Run Landfills was also surveyed. This phased approach to the water and groundwater use survey and sampling was intended to allow the GIST to focus efforts along potential C-8 impacted transport pathways and eventually cease activities in directions where impacts were not present or where there were low concentrations. 4.1 Private Water Sources 4.1.1 West Virginia: GIST Conclusions and Recommendations for West Virginia Private Water Supply Sources Following completion of Task A, GIST concluded the following: Q Initial sampling within a one-mile radius of the Washington Works facility and each of the three landfills resulted in varying levels of C-8 being found in private water sources. Q Private water sources within a one- to two-mile radius were sampled around the Washington Works facility and the Local Landfill based on C-8 concentrations detected in groundwater greater than 1.0 ug/L in the one-mile radius. No further private water source sampling beyond the two-mile radius is necessary based on the lower concentrations detected in the one- and two-mile radius sampling area. Q No private water sources in West Virginia were found to exceed the C-8 drinking water screening level of 150 ug/L. The highest concentration detected was 10.4 ug/L. Based on these conclusions, limited private water source resampling in West Virginia was recommended by the GIST for the purpose of evaluating the current trend of C-8 concentrations with respect to those sources. For private water sources around the Washington Works facility/Local Landfill, the Dry Run Landfill, and the Letart Landfill, water-sampling categories were defined, the number of samples from each category was identified, and the sampling frequency was specified (GIST, 2003) as indicated in the following table. 2004Worl<Plan4.doc Wilinington, DE EXP000398 9 Draft Document Do Not Cite or Quote, March 30, 2004 Draft Phase II Monitoring/Sampling Work Plan Water Monitoring Activities ashington |Works/Local Landfill (Total of 10 locations) Dry Run Landfill (Total of 10 Locations) Letart (2 Locations) Drinking water wells with detected levels of PFOA Drinking water springs with detected levels of PFOA Non-drinking water wells with detected levels of PFOA Springs and cisterns with detected levels of PFOA One well and spring used for cattle where prior sampling has detected PFOA concentrations above 5 ug/L Drinking water wells with detectable levels of PFOA Drinking water springs with detectable levels of PFOA Springs and cisterns with detectable levels of PFOA GERLACHIBA BRINKERA Quarterly for one year Quarterly for lone year Quarterly for lone year Quarterly for lone year Quarterly for one year Quarterly for one year Quarterly for |oneyear Quarterly for lone year [Annuallyfor one year 4.1.2 West Virginia: Private Water Supply Sources Activities DuPont intends to resample ten private water sources around the Washington Works facility/Local Landfill and ten private water sources around the Dry Run Landfill on a quarterly basis for one year for the purpose of evaluating the C-8 concentration trend for those sources. Sampling is anticipated to start in 2Q04. This start date will be dependent upon obtaining property owner permission to resample. If a property owner declines to have the private water source resampled, then an alternative sampling location will be proposed by DuPont. Private water sampling locations for the Washington Works facility/Local Landfill and the Dry Run Landfill were selected based on the following: Q Specific water sampling categories defined by the GIST and the number of samples required for each category based on GIST recommendations (see Table 2) EXP000399 2004WorkPlan4.doc Wilmington, DE Draft Document Do Not Cite or Quote, March 30, 2004 Draft Phase II Monitoring/Sampling Wptk Plan______________________Water Monitoring Activities Q Potential access to the sampling locations Q The ability to cluster private water sampling locations with locations also selected for air monitoring and/or sampling of soil and biota to minimize the total number of access points (Air monitoring and soil/biota sampling activities and locations are discussed in Sections 3.0 and 5.0, respectively.) Private water sources selected for sampling at the Washington Works facility/Local Landfill and the Dry Run Landfill are shown in Figures 1 and 2, respectively. Each private water sampling location shown in Figures 1 and 2 is also listed in Table 2 according to the water-sampling category. Table 1 also summarizes additional data for each private water source to be sampled. In addition, at the Letart Landfill, DuPont intends to sample the two private water sources recommended by the GIST (i.e., the Geriach and Brinker residences), annually for one year. Figure 3 shows the locations of the Geriach and Brmker residences. Sampling will be conducted in 2Q04 provided permission to sample is granted. The sampling methodology used for acquiring these samples is dependant upon water source and sampling point (e.g., spring, well, cistern, tap). The analytical method that will be used is a validated LC/MS/MS aqueous method developed by Exygen Research of State College, Pennsylvania. The method has a PQL of 0.05 ug/L. Details describing the private water sampling methods and the analytical methodology are provided in the QAPP (see Appendix A). The progress of the Phase n private water sampling in West Virginia will be summarized in the semi-annual status reports that will be issued by DuPont. The results of the West Virginia private water supply sampling will be included in final report submitted to USEPA, WVDEP, and GIST no later than 30 days after the report is finalized. 4.1.3 Ohio: GIST Conclusions and Recommendations for Ohio Private Water Supply Sources Following completion of Task A, GIST concluded the following: Q Initial sampling within a one-mile radius of the Washington Works facility resulted in varying levels ofC-8 being found in approximately 94% of the water sources sampled. Q Private water sources within a one- and two-mile radius from the Washington Works facility were sampled based on the levels ofC-8 detected at the outer limits of the one-mile radius. Q No private water sources in Ohio were found to exceed the drinking water screening level of 150 ug/L. The highest concentration detected was 23.6 ug/L. Based on these conclusions, limited private water source resampling in Ohio was also recommended by the GIST for the purpose of evaluating the current trend ofC-8 concentrations with respect to those sources. For private water sources in Ohio, water- sampling categories were defined, the number of samples from each category was identified, and the sampling frequency was specified by the GIST (GIST, 2003t as shown the following table. EXP000400 2004VVorkPlan4.doc Wilmington. DE ___ Draft Document Do Not Cite or Quote, March 30, 2004 Draft Phase II Monitoring/Sampling Work Plan Water Monitoring Activities Ohio (Total of 11 Locations) Drinking water wells with detectable levels of PFOA Drinking water springs with detectable levels of PFOA Non-drinking water wells with detectable levels of PFOA Springs and cisterns with detected levels of PFOA [Quarterlyfor one year Quarterly for one year Quarterly for one year Quarterly for one year 4.1.4 Ohio: Private Water Supply Sources Activities DuPont intends to resample eleven private water sources in Ohio on a quarterly basis for one year, starting in 2Q04, for the purpose of evaluating the C-8 concentration trend for those sources. Sampling is anticipated to start in 2Q04. This start date will be dependent upon obtaining property owner permission to sample. If a property owner declines to have the private water source resampled, then an alternative sampling location will be proposed by DuPont. The ten private water source sampling locations in Ohio were selected based on the same criteria given for private water sources in West Virginia. In February 2004, USEPA and OEPA requested that one additional private water source be included in the proposed sampling program. This location has been added to the program. The eleven private water sources selected for sampling are shown in Figure 1. Each private water sampling location shown in Figure 1 is also listed in Table 2 according to the water-sampling category. Table 1 also summarizes additional data for each private water source to be sampled. The sampling methodology used for acquiring these samples is dependant upon water source and sampling point (e.g., spring, well, cistern, tap). The analytical method that will be used is a validated LC/MS/MS aqueous method developed by Exygen Research of State College, Pennsylvania. The method has a PQL of 0.05 ug/L. Details describing the private water sampling and the analytical methodology are provided in the QAPP (see Appendix A). The progress of the Phase II private water sampling in Ohio will be summarized in the semi-annual status reports that will be issued by DuPont. The results of the Ohio private 2004WorkPlan4.doc Wilmington. DE EXP000401 12 Draft Document Do Not Cite or Quote, March 30, 2004 Draft Phase II Monitoring^Sampling Work Plan_____________________Water Monitoring Activities water supply sampling will be included in final report submitted to USEPA, WVDEP, OEPA, and GIST no later than 30 days after the report is finalized. 4.2 Public Water Sources 4.2.1 West Virginia: GIST Conclusions and Recommendations for West Virginia Public Water Supply Sources The GIST concluded the following for West Virginia public water supply sources: Q No public water supply production wells in West Virginia were found to exceed the drinking water screening level of 150 ug/L. The highest concentration detected was 1.87 ug/L. Q The widespread distribution and low concentrations of C-8 indicate that the primary migration pathways to public water supplies are air emissions from the Washington Works facility and pumping-induced infiltration from the Ohio River, which receives C-8 from the NPDES outfalls and the Washington Works facility and the Letart landfill. Based on these conclusions, GIST recommended continued quarterly sampling at the Lubeck Public Service District (PSD), the DuPont Washington Works facility, and the General Electric public water system for two years. Annual sampling of the Blennerhassett Island State Park, Mason County PSD, and the Racine Lock and Dam Public Water System (PWS) for two years was also recommended. Continued sampling was recommended for the purpose of evaluating the C-8 concentration trend for those' sources. Following these monitoring periods, the GIST recommended re-evaluation of the monitoring. For each of these public water sources, the GIST identified specific production wells and finished water sampling points to be monitored. In addition, the GIST recommended DuPont conduct a limited field investigation of C-8 in soil at the Lubeck PSD to determine the extent and concentration of C-8 in soil at the Lubeck PSD in the vicinity of their production wells. DuPont would document the results in a report and submit this report to the GIST. Following data evaluation of the soil results, the GIST would then determine what additional sampling activities would be necessary, if any, to complete the investigation. The details of the investigation to be conducted at the Lubeck PSD are provided in Section 6.0. 4.2.2 West Virginia Public Water Supply Sources Activities DuPont intends to monitor public water sources in West Virginia, following the recommendations of the GIST, for the purpose of evaluating the C-8 concentration trend for those sources. Figure 4 shows the locations of public water sources in West Virginia that will be monitored for two years. At each monitoring location, the color (pink or blue) and shape (square or circle) of the label indicates monitoring frequency (annually or quarterly) and individual sampling points (production wells and finished water sampling points) are listed. Table 1 also summarizes additional data for each public water source to be sampled. Table 3 indicates the duration of monitoring for each public water source. 2004WorkPlan4.doc wilmington, DE EXP000402 13 Draft Document Do Not Cite or Quote, March 30, 2004 Draft Phase II Monitoring/Sampling Work Plan Monitoring Activities ________________Water The sampling methodology used for acquiring these samples is dependant upon sampling point (e.g., spring, well, cistern, tap). The analytical method to be used is a validated LC/MS/MS aqueous method developed by Exygen Research of State College, Pennsylvania. The method has a PQL of 0.05 ug/L. Details describing the public water sampling methods and the analytical methodology are provided in the QAPP (see Appendix A). The progress of the Phase II public water sampling in West Virginia will be summarized in the semi-annual status reports that will be issued by DuPont. The results of the West Virginia public water supply sampling will be included in final report submitted to USEPA, WVDEP, OEPA, and GIST no later than 30 days after the report is finalized. 4.2.3 Ohio: GIST Conclusions and Recommendations for Ohio Public Water Supply Sources Following the completion of Task A, GIST concluded the following: 0 No public water supply production wells in Ohio were found to exceed the drinking water screening level of 150 ug/L. The highest concentration detected was 8.58 ug/L. Q The widespread distribution and low concentrations of C-8 indicate that the primary migration pathways to public water supplies are air emissions from the Washington Works facility and pumping-induced infiltration from the Ohio River, which receives C-8 from the NPDES outfalls and the Washington Works facility and the Letart landfill. The GIST recommended continued quarterly sampling at the Little Hocking Water Association PWS for two years and annual sampling of the Tuppers Plains PWS for two years for the purpose of evaluating the C-8 concentration trend for those sources. For these two public water sources in Ohio, the GIST listed specific production wells and finished water sampling points to be monitored. Following these monitoring periods, the GIST recommended re-evaluation of the monitoring. 4.2.4 Ohio Public Water Supply Sources Activities DuPont intends to monitor the public water sources in Ohio, following the recommendations of the GIST, for the purpose of evaluating the C-8 concentration trend for those sources. In Ohio, two public water sources will be sampled (the Little Hocking Water Association and the Tuppers Plains-Chester Public Service District) for a period of two years. Figure 4 shows the locations of public water sources in Ohio that will be monitored. At each monitoring location, the color (pink or blue) or the shape (square or circle) of the symbol, which indicates monitoring frequency (annually or quarterly) and individual sampling points (production wells and finished water sampling points), are also listed. Table 1 also summarizes additional data for each public water source to be sampled. Table 3 indicates the duration of monitoring for each public water source. The sampling methodology used for acquiring these samples is dependent upon sampling point (e.g., spring, well, cistern, tap). The analytical method to be used is a validated LC/MS/MS aqueous method developed by Exygen Research of State College, _20_04W_o_rkP_la_n4_.do_c ____________________________________ EXP000403 wilmington, DE Draft Document Do Not Cite or Quote, March 30, 2004 Draft Phase II Monitoring/Sampling Work Plan __________ Water Monitoring Activities Pennsylvania. The method has a PQL of 0.05 ug/L. Details describing the public water source sampling methods and the analytical methodology are provided in the QAPP (see Appendix A). The progress of the Phase II public water sampling in Ohio will be summarized in the semi-annual status reports that will be issued by DuPont. The results of the Ohio public water supply sampling will be included in final report submitted to USEPA, WVDEP, OEPA, and GIST no later than 30 days after the report is finalized. 4.2.5 Ohio: OEPA Recommended Well Installation at Little Hocking Water Association Well Field As part of Task A of the Consent Order, public water supplies along the Ohio River in both Ohio and West Virginia were sampled. The Little Hocking Water Association is one of the public water supplies located in Ohio that was sampled. It is located immediately across the Ohio River from the DuPont Washington Works facility. Groundwater results for test well, TW-4, which was installed to evaluate groundwater quality and is not used as drinking water, showed unusually high C-8 concentration compared with other concentration measured at this public water supply. Based on the elevated results at TW-4 compared to the surrounding wells, the OEPA requested that DuPont conduct a focused field investigation to delineate C-8 concentrations in soil and groundwater near TW-4. In August 2002, DuPont conducted the field investigation at the Little Hocking Water Association well field. During this investigation, ten temporary soil borings were drilled and geologic information was continuously monitored. Soil and groundwater were sampled and groundwater parameters were monitored at various depths within the ten temporary borings. In addition, groundwater in all production and test wells was sampled, and recorded groundwater elevations were recorded. Ohio River stage was also monitored. There were three primary conclusions from this investigation, which are as follow: Q First, consistently high pH values measured in TW-4 and other field observations indicate that this test well's construction is likely compromised, possibly due to a failed grout seal or to a failed well casing. Q Secondly, based on the current data available, DuPont believes the following C-8 migration pathway exists: C-8 from the DuPont facility is transported via air emissions by wind and is deposited on the Little Hocking well field surface soils. Precipitation then leaches the C-8 downward through the unsaturated zone to the aquifer. Dissolved C-8 then migrates with groundwater within the aquifer.. Groundwater containing low levels of C-8 is then pumped from the aquifer through the four production wells. Water from the production wells is mixed and the finished water, containing even lower levels of C-8, then enters the Little Hocking Water Association distribution system. Q Third, the C-8 results for finished water, a combination of waters from the production wells that is distributed to Little Hocking customers, ranged from 1.69 to 4.29 ug/L, significantly lower than the water C-8 SL of 150 ug/L. EXP000404 2004WprkPlan4.doc wilmington, DE 15 Draft Document Do Not Cite or Quote, March 30, 2004 Draft Phase II Monitoring/Sampling Work Plan______________________Water Monitoring Activities These conclusions and other findings of this inv6stigation were documented in a report to the GIST (DuPont, 2003). As indicated in the Final C-8 GIST Report (GIST, 2003), OEPA and DuPont together would determine what additional activities are necessary to complete the Little Hocking field investigation to the satisfaction of the GIST and OEPA. After reviewing the Little Hocking Sampling Investigation Report, the OEPA recommended revisions to the report and requested additional investigation. The revisions have been made to the report and the Revised Little Hocking Sampling Investigation Report was submitted to the GIST in February 2004. During Phase II, DuPont intends to install the four shallow wells at the Little Hocking Water Association well field as recommended by OEPA. One of the shallow wells will be installed north of production wells #5, if possible, as requested by the OEPA. The other three shallow wells will be clustered with existing test wells TW-1, TW-6, and TW-12. Proposed shallow well locations are shown in Figure 5. During well installation, surface soil/biota and subsurface soil will be sampled. Details of the shallow well installation and the surface and subsurface soil sampling are provided in the QAPP (see Appendix A). Installation of the wells is anticipated to begin 2Q04 and if dependent upon the property owner granting permission for such installation. In the event permission is not granted, DuPont will consult with OEPA. Following installation and development of the four new shallow wells at Little Hocking, these wells, along with the deeper clustered wells (Figure 5), will be included in the quarterly groundwater sampling program for Little Hocking. The progress of the Phase II shallow well installation at the LHWA well field and the sampling of these clustered test wells will be summarized in the semi-annual status reports that will be issued by DuPont. The results of the shallow well installation and the test well monitoring will be included in final report that is due to USEPA no later than 30 days after the report is finalized. 2004WorkPlan4.doc Wilmington, DE EXP000405 16 Draft Document Do Not Cite or Quote, March 30, 2004 Draft phase ii Monitoring/Samplingwork plan____ Surface Water and Groundwater Monitoring 5.0 SURFACE WATER AND GROUNDWATER MONITORING Task B of the Consent Order (Assessment of Existing Groundwater and Surface Water Monitoring Data) required the development and implementation of a monitoring plan that would determine the extent and presence ofC-8 in drinking water, groundwater, and surface water at the Washington Works facility and the three landfills. In addition, this task required DuPont to compile all the available groundwater and surface water monitoring data and hydrogeological data for each site. For the Washington Works facility and the three landfills, the GIST recommended that surface water and groundwater monitoring continue at selected sampling points. Surface-water and groundwater monitoring activities will be continued under the requirements of the WV/NPDES permits WV0001279, WV0076538, WV0076066 and WV0076244 for the Washington Works facility and the Local, Letart and Dry Run Landfills, respectively. Because surface-water and groundwater monitoring is being conducted in accordance with the WV/NPDES permits, this monitoring is not part of Phase II and is not discussed filrther in this document. Additional details of this monitoring can be found in the permits. The results of monitoring conducted pursuant to permits will be submitted to USEPA as part of the semi-annual reports set forth in the LDI. 2004WorkPlan4.doc Wilmington. DE EXP000406 Draft Document Do Not Cite or Quote, March '17 30, 2004 Draft Phase II Monitoring/Sampling Work Plan ______Surface SoJi/BJOta (Vegetation) Sampling 6.0 SURFACE SOIUBIOTA (VEGETATION) SAMPLING IN WEST VIRGINIA AND OHIO OEPA recommended establishing at least eight locations to collect surface soils for analysis ofC-8. Sampling locations were to be selected based on available C-8 data from air modeling, groundwater modeling and sampling activities. OEPA recommended that some of the eight samples be collected from residential areas near the Little Hocking well field and in areas where different soil types would be expected. GIST recommended DuPont conduct a limited field investigation of C-8 in soil at the Lubeck PSD to determine the extent and concentration of C-8 in soil at the Lubeck PSD in the vicinity of their production wells. Based on the recommendations from OEPA and GIST, and on additional data needs identified by USEPA, DuPont plans to conduct a soil and biota (vegetation) sampling program at the following locations in West Virginia and Ohio for the purpose of determining if C-8 is present: Q On the surface of vegetation Q Within the vegetation matrix (i.e., it is being uptake onto plant structure) 0 Within the topmost, highly organic soil underlying the vegetative layer For the field investigation of surface soil/biota, DuPont has selected eleven locations in Ohio and ten locations in West Virginia (see Figure 1 and Table 1). Sampling locations were selected to be consistent with locations selected for air and private water sampling locations, m Ohio, four surface soil/biota sample locations were selected, adjacent to where the four new shallow wells will be installed at the Little Hocking Water Association well field. Seven private residences in Ohio were also selected for surface soil/biota sampling. In West Virginia, seven private residences were selected for surface soil/biota sampling, hi addition, three surface soil/biota sample locations will be selected at the Lubeck Public Service District well field. The exact position of these three sampling locations will be determined following a site visit by DuPont (or its authorized representative). If a property owner declines soil/biota sampling, DuPont will propose an alternative surface soil/biota sampling location. After permission has been granted to collect the soil/biota samples for the private residences and the public water suppliers, exact sampling locations will be identified and surveyed using a global positioning system and the location marked with flagging or equivalent. For the surface soil/biota sampling in Ohio and West Virginia, DuPont proposes conducting two synoptic sampling events in the late spring 2004 (providing access is granted), one following a "wet" period and one following a "dry" period. ("Wet" and "dry" periods are defined in Appendix A.) The objective of sampling following a "wet" and " dry" period is to evaluate if precipitation has an effect on the concentration of PFOA measured. Meteorological data will be monitored prior to and during the "wet" and " dry" sampling events. At each sampling location, two samples will be collected immediately adjacent to each other during each sampling event. Each sample will consist of a 6-inch depth core of 2004Wori<Plan4.doc wilmington, DE 18 Draft Document Do Not Cite or Quote, March 30, 2004 : ; EXP0004 Draft Phase II Monitoring/Sampling Work Plan__________Surface Soil/BJOta (Vegetation) Sampling vegetation and soil. The two samples will be collected adjacent to each other. The first sample will be submitted for analysis and the second sample, which will be a larger diameter sample, will be used to determine the soil classification (ASTM D2487) at the location. Sample collection methodology is presented in Section 2.2.10 of the QAPP (see Appendix A). The first sample will be divided in the field into two portions, the organic-rich portion (vegetation and litter layer) and the mineral matter-rich portion (root, root zone and the material below the root zone). The objective of dividing the sample into a biota (organicrich) portion and soil (mineral matter-rich) portion is to evaluate if the PFOA is detectable in both portions and to compare the PFOA concentrations between the organic-rich portion and the mineral matter-rich portion. In addition, for the samples collected during the "dry" event, the organic-rich portion will be washed with deionized water, prior to processing the soil samples for analysis, to differentiate between adsorbed (sticking) or "external" PFOA removed by the deionized wash water and PFOA incorporated within the organic material itself. The washed organic-rich portion and the wash water will be analyzed for PFOA. The mineral-rich portion of four samples (OHS/B-3, OH-S/B-4, OH-S/B-7 and WW-S/B-10) collected during the "dry" event will also be washed for comparison. For these four sample, the washed mineral-matter-rich portion and the wash water will be analyzed for PFOA. Note that DuPont is not currently aware of a validated analytical method for determining PFOA concentrations in organic matter. Method development for surface soil/biota (organic matter-rich portions and mineral-matter rich portions) analysis has been initiated at Morse Laboratories (Morse), Sacramento, California. If Morse is unable to provide analysis for surface soil/biota sample extracts, then STL will provide analysis of these extracts. Biota sampling will be conducted during the synoptic "wet" and "dry" events although analysis of the organic rich samples will not take place until successful completion of method validation. Sample handling and storage prior to analysis will follow the protocol outlined in the QAPP. Details of the sampling and analytical methodology are provided in the QAPP (see Appendix A). The second, larger diameter sample will be used for soil classification according to ASTM D2487. Soil classification will be based on the results of grain size determination and Atterburg Limits, and may include results of specific gravity, organic content and moisture content. The progress of the Phase II synoptic surface soil/biota sampling at private residences and at public water suppliers Ohio and West Virginia will be summarized in the semi annual status reports that will be issued by DuPont. The results of the two synoptic surface soil/biota sampling events will be included in final report submitted to USEPA, OEPA, and WVDEP no later than 30 days after the report is finalized. 2004Worl<Plan4.doc Wilmington, DE EXP000408 19 Draft Document Do Not Cite or Quote, March 30, 2004 \ w' V,,^' Draft Phase 11Monitoring/Sampling Work Plan_______________________Schedule and Reporting 7.0 SCHEDULE AND REPORTING The schedule for completing the Phase II work required by the MOU is shown in Figure 6. The schedule begins with USEPA and DuPont signing the MOU and concludes with submitting the Phase 11 report for all sampled media (except air). Subsequent tasks required by the MOU (i.e., conducting assessments, performing the peer consultation, and implementing post-peer consultation commitments, etc.) will be addressed in updated schedules that will be included in the status reports generated for this assessment. Phase n sampling will begin after permission has been granted from the off-site property owners. Throughout this assessment, reports will be generated to update status and provide data generated during this investigation. Status updates will be submitted to USEPA semi-annually. A final air report will be submitted after the air verification study is conducted and data reduction and modeling is complete. A Phase n report will be submitted (for all media except air) after Phase II is complete and after data are reduced and analyzed. Based on the current schedule, the Phase II report is expected to be submitted in November 2006. All final reports will be submitted to USEPA within 30 days of becoming final (in accordance with the terms of the MOU). 2004WorkPlan4.doc Wilmington, DE EXP000409 20 Draft Document Do Not Cite or Quote, March 30, 2004 Draft Phase II Monitoring/Sampling Work Plan 8.0 REFERENCES To be completed in the final report References 2004WorkPlan4.doc wilmington, DE EXP000410 _211 Draft Document Do Not Cite or Quote, March . 30, 2004 EXP000411 TABLES EXP000412 Table 1. Summary Data for Proposed Sampling Locations In and Around DuPont Washington Works Site DuPont Washington Works Site Washington, West Virginia PH-S/B-8 OH-S/B-10 OH-S/B-1 IOH-S/B-7 iOH-S/B-9 iOH-S/B-11 OH-A-5 OH-A-2 OH-A-4 OH-A-6 .OH-A-7 OH-A-1 OH-P-2 OH-P-10 OH-P-9 OH-P-8 OH-P-3 OH-P-4 OH-P-1 OH--P-11 Well Well Spring iSpring Cistern Spring Cistern Well Well Well (hand-dug) i Drinking Water |Drinking Water Drinking Water iUnused Non-drinking Water Used Non-drinking Water |Used Non-drinklna Water Used Drinking Water Drinking Water Non-drinking Water Used WWK-D-RumerJH WWO-D-FosterTV |WWK-G-SplcerRF WWK-G-StahlPRZ WWK-G-StepnanML.1 WWK-G-WatsonMP3 WWK-G-WatsonMP4 WWO-D-TalttWJ WWO-D-WhIteAL WWO-G-KidderEM Well used for all household pu have city water but use well wa Isource. All purposes All purposes except drinking a which bottled water is used. Occasionally used for drinking Unused at present, but planne ;Cistern used for watering lives Used to water livestock. Occasionally used to water liv City water and well. Uses well garden. Drinks the well water All purposes. Only water sour Outdoor purposes (i.e. waterin ,eto.) 3/30/2004 1of3 Table 1. Summary Data for Proposed Sampling Locations In and Around DuPont Washington Works Site DuPont Washington Works Site Washington, West Virginia iWW-S/B-1,2, 3 AM07-PW01 A008-PW01, AX13-PW01, 'K16-PW01,1.04 PW01.V05- 'PWO-I MASONCPSD1 Production Wells ,2,3 RACINELD Finished Water GE Well 3 Finished Water BLEN1SEPS1 Finished Water LPSD Well A, Production Wells and B,C, D, E, F, AT Finished Water Mason County PSD Racine Lock and Dam PSD BIennerhassett Island Lubeck PDS WW-S/B-7 WW-S/B-8 iWW-S/B-6 iWW-S/B-10 WW-S/B-5 WW-A-2 WW-P-1 WW-P-7 WW-P-6 WW-P-10 WW-P-9 WW-P-2 WW-P-3 WW-P-8 |Well(1) Spring (1) Cistern (1) Cistern Spring (1) Wells (1st of 2) Spring 1 " Drinking Water Used Non-drinking Water |Used Non-drinking WatenUsed Drinking Water Used Non-drinking WaterTDsed Unused Non-drinking Water Unused Orinking Water WWK-D-ChristmanS iWWK-G-Tallhamer ,WWK-G-ThompsonB WWK-D-PhlllipsAE iWWK-G-WaltersMM WWK-G-LawsonDH2 WWK-G-FurbeeC WWK-D-Stuttleri-R All purposes Watering livestock Watering animals Well used for all purposes. Childem play In water, water gar Livestock Spring used occasionally for cof 3/30/2004 2of3 Table 1. Summary Data for Proposed Sampling Locations In and Around DuPont Washington Works Site DuPont Washington Works Site Washington, West Virginia DR-P-2 DR-P-3 DR-P-1 DR-P-6 OR-P-8 DR-P-9 DR-P-10 DR-P-4 !Well(1) Well(1) Wells (2nd of 2) Well (1) [Well (1) Cistern (1) Well(1) Spring (1) Drinking Water Drinking Water Drinking Water Drinking Water Drinking Water Drinking Water Drinking Water Drinking Water Used Used Used Used IUsed Used Used Used IWWK-D-AbbottRL WWK-D-AbbottS WWK-D-AtkinsonJ2 WWK-D-BakerH WWK-0-NicholsonDH WWK-D-NlckelsonDH2 WWK-D-ParkerJL WWK-D-SeebaughR All purposes (excluding drinking make ice for drinks) All purposes Drinking only All purposes All purposes [Used If well Is running low All purposes All uses - household, drinking, etc 3/30/2004 3 Of 3 T Table 2 Summary of GIST Recommended Private Water Source Smpling Category In and Around DuPont Washington Works Site and DuPont Proposed Sam DuPont Washington Works Site Washington, West Virginia Washington Works/Local Landfill (Total of 10 locations) Drinking water springs with detected levels of C-8 Non-drinking water wells with detected levels of C-8 Springs and cisterns with detected levels of C-8 One well and spring used for cattle where prior sampling has detected C8 concentrations above 5 ug/L Dry Run Landfill (Total of 10 Drinking water wells with detectable Locations) levels nf C..K Drinking water springs with detectable levels of C-8 Springs and cisterns with detectable Letart (2 Locations) levels of C-8 GERLACHIBA BRINKERA Ohio (Total of 11 Locations) Drinking water wells with detectable levels of C-8 Drinking water springs with detectable levels of C-8 Non-drinking water wells with detectable levels of C-8 Springs and cisterns with detected levels of C-8 WW-P-8 Quarterly for one WW-P.5 |Quarterlyfor one WW-P-6, WW-P-7. WW-P-9 Quarterly for one iWW-P-2, WW-P-3 DR-P-1,DR-P-2,DR-P-3, DR-p-fi DR-P-R nR-p-m DR-P-4 DR-P-5, DR-P-7, DR-P-9 L-P-1 L-P-2 OH.P-1.0H-P-2.0H-P-5, OH-P-7,OH-P-11 OH-P-10 OH-P-6 OH-P-3, OH-P-4, OH-P-8, OH-P-9 Quarterly for one Quarterly for one [Quarterlyfor one Quarterly for one Annually for one Annually for one Quarterly for one Quarterly for one Quarterly for one Quarterly for one 3/30/2004 1 ofl Tab Table 3. Summary of GIST Public Water Source Sampling Recommendations DuPont Washington Works Site Washington, West Virginia 3/30/2004 1 of1 Tab FIGURES FIGURES EXP000419 ^mm \..-:-:--4-w^t4' Figure 1.5 OVS Tube DuPont Washington Works Site Washington, West Virginia Air flow (1 L/min) Hoidmg "'"g. F.'i';-?''.--- Swhent La'/fi -- Pc!yl.i.'^lh^,":<f P^A"' So.'fcenr l-a/'r; -^~~ Pc."/>l;^^,l'^."e Fi^n' ."d Cap Gi'ass ri.b'? j- Breakthrough vapor End Cap EXP000421 @ J >\ = NE gm E"E ae 2 -- Re a BE EE ci YX ON --- TEL I Siti eng, Fe --EE = roms, & = 9 --p-- ] : Sao oe SE a e Go i! | G=. ea Sh Ca a a t pS5HErRa es Go Co i ire ee oo Su Ee n hE snrSmih ; i D a F To EE eR sa fo i La Lo eee eei pSe o a % ha e3 ls pntmoi h ga alae eE n e a bs pofieoi 13 Sg ey ae SC airlo ednge Sa L @ys oi i ie Teas al a : ALR hor Sone | @ 0 oS N = a = WESTVIRGINIA / / & Aya J J) ee pe "0 OHIO LANDFILL AREA i eg : HR, ( LETART PROPERTY PERIMETER RESET SETA Tee cu | CNN) WINN or frSI -- ee E Efe. To] m #2 i .J s 3 k. (33 i - .L ^ C=3 ..... C3 C3 1=3 3 ^ IJ1 III j^: J, i)T -J 1 1 a 1 r DO ^- ,n - CD JOJ . 1 < S i ii 1J!.|s | | |s i1 |s js |^ ~01! i||SS|SS5S5S5SaS "iS t 1 t t S 1 S ! S g s a 8 g g a | J1 | | I | 1 ^ I 1 I E 1 I. S 3 g g '? S 1 S =3 j eB i 5 t3 e e @ S3 fr. E sPS3! S3 g |..| SSt S1 t St sgggsgia J , . H 11 i . . ] j1 ' < ii 1 111 1 ^1 1 S i g- g j 1S1e1ll1 . I ^ E I | S i | i 1 | 1 I { j 11 j | 1 1 , j S J1 3 g S 1 ilslliiis 0 i CRI B ia s in o ia S = S s s s s ft 8 : i0 * 0 b g 1 1 p LJ j1 ^ 5 0 1 S s- s I [1-1 1 | 1 1 | 2 r-i - a S ji & 1 APPENDICES EXP000427 APPENDIX A ^ y .y fc:^-?;^.-:^^ **siBi^' APPENDIX A PHASE 11QUALITY ASSURANCE PROJECT PLAN WASHINGTON WORKS SITE, WASHINGTON, WEST VIRGINIA EXP000429 D = = cnn = One Wttobedecd laterdoe: La po * eu ss w:o i ve 12 | a po <#| ' Cwp r| D & + _ ll -- | RS = | ov I -- N = -- op -- OF BR--E _--_ on0 RNER -- _ | RE sn rvs [a gnetmseoe Test we eens Corporate Remediation Group | Ue focing Note Ascstion . SCALE at tte Hocking, Ohio >ed > .oo . [E PeP PEa