Document YGYY9DYz2yEN047DyKJb4KnM8

AR226-2567 1 N OF To; From; TE R PICE MEMO Mr. Mike Dorsey,Asst Chief, Pemats & Compliance, OWM Mr. Dave Wafldns, Leader, Oro'undwater Section, OWR. NareshR.Shah'^ Subject: Date; Groundwater Monitoring & Contamiiaation at DvPont Washington Works July 21,2000 A meeting was held with DuPont personnel in OWM conference room on July 19,2000, It was attended by loth of you, myself Cmdy Musser, Jim Duranti, Mark Friday and Rick Shaver from the agency. DuPont was leprescnted by Bob Ritchey, Andrew Hartten and George WoytowiehThe purpose of the meeting was to discuss DuPont's workrelated lo RCRA Facility Investigation ffSl) program, lesults find potentialoact steps aad Ac status of well monitoringunder the narent NPDES pennit so that interrelationships are defined and concerns understood, Andrew Hartten of DuPoat presented DuPont's work related to RFI program. Under this program, DuPont studied environmental impacts (on groundwater &. soil) of past disposal unitsSolid Waste Management Units (SWMUs)- Riverbarik Landfill, Anaerobic Digestion Ponds. Binning Grounds and Polyacelal Waste Incinerator- at Washuigton Works. For this purpose, DuPont took and analyzed many soil samples and installed a number of groundwater monitoring wells fbr moaitodftg groundwater quality. Most of the wells w located along the Ohio River bank and in the vicinity ofSWMU as shown in the attached figwe. My m^or comments on this subject are as follows: (I) From the figure, it is obvious that DnPont did not install any groundwater monitoring well In tite Bianufacturing.tproeess) area to evaluate impacts ofpastimannfairturing processes and material handling practices (material storage tanks aad laading/iialoaduig operations). This may be because it is not required under tfaisRFI prograo)- Mike Dorsey can coHiment on this item. At otter industrial facilities, severe groundwatercontamination was uncovered by monitoring groundwater uateoeath the process areas. Ihis is a main deficiencyof DuPont's work. Under the appropriate State regulations, the agency (either Mike Dorsey or Dave Watldns) should require DuPont to Install additional monitoring wells at appropriate locations in the process areas to determine impacts of past & current manufacturing operations and material handling practices OB groundwater quality underneath the plant site. Several of these wells should be cluster wells to evaluate Impacts on shallow (or perched) and deep aquifers. Qfoundwater quality data &oa: these wells will helpto identify Ac 53 contaminants, and to define their plumes aid their rates of migration. Such work TUBSbeen o o already done at many mdustrial sites for optimizing locations of groundwater recovery wells (to 0 rvd n:n iaa TO/SO/SO ASH014631 EID192501 Mr. Mike Dorsey, Asst Chief, Pennits & Cotaynffliei?, OWM Page 2 July 24,2000 pump & treat) in order to expeditegroundwater deaa-up. I am really surprisedand shocked to learn, (hat DuPoat has not even started sush.'woik. (2) Sine? most of tils groundwatermonitoring wells are located along the river bank, the groundwater to these wells caa be influenced, by the river "water and hence measured concentrations of pollutats presentwould be lower than acfti&l eoneenttacioDS. (3) Imparts of write landfills and othw activities (such as injection welh) permitted under the State program (or other projp'ams) should also be considered to comprehend the faelUty wide plefcans ofgroandwater quality. Groandwate piopam is so fiagmented (piece meal) that it is vexy difficult to get an overall facility wide picture on gi-oimdwater quality and hence require any ineaiaEigfiu grolBidwater clean-lp. Tilis is the most critical bwdle to overcome. Note aiat seqsage ofeontamiiated groundwater fiom iadusteial sites is a major non-point source ofpollutioB as far as the surface waters are concerned. (4) In addition to Appendix Vin (of 40 CBB Part 261-SLCSlA regnlatipns) pollutants/parameters, groundwater samples at the industrial sites (CTpeeiaBylocated along the river banks) should be analyzed for the priority polhxtants and the water quality standards for the s'ttrftcB waters because of the above meatfoned comment number 3 and also many facilities (including DuPont) use p-oundwater for process purposes including as non-contact cooUflg water aad discharge into the surface watem? without any treatment and thus can be impacting quality of the surface waters. (5) DuPont should monitor water levels in the groundwgter monitoring wells quarterly rather than annually to account for seasonal variations, which may not change the groundwater flow directioo but may ehaage concentrations of pollutants. (6) In light of discovery of metnytene chloride seep (by Charlie Moses' compliance groitp/OEE) and a seep from Old Fire Training area gotog into tfae Ohio River (on the surface), I do not concur with DuPoat'a conclusion that there is no off-site migration of any contaminated groundwater because of operation of their well system. If this was (be case, there should not be any seep in the lElrst place. It is difficult to find out any subsurface seeps going Into the liver. Wifli these comments, I sincerely request both of you to pursue appropriateactions in DuPont's case. cc: Cindy Musaer, RjcTcShaver, Mark Priddy, Jim Duianti, Jeny L. Ray, Allyn CJumer, Pravm 0. Sangaiu, Mike Zeto, Bandy Sovie, Charlie Moses, John Britvec o 0 eaoia IVd ET;TT ISd 10/80/80 ASH014632 EID192502