Document aBLmywk58jxm6egNO7437Jqza

AR226-2350 Ohio EPA December 2,2003 Objectives Provide grounding/update on recent activities Solicit input on upcoming activities Agenda Water - GIST Final Report Recommendations - Proposed MOU Based on GIST Recommendations - OEPA Requests - DuPont Suggested Modifications Air - Review Recent Model Results - Air Permit Update - Additional Reduction Programs - Air Model Verification Plan Proposed Memorandum of Understanding-West Virgini DEP and Ohio EPA Summary of Activities December 2, 2003 GIST Report Recommendations Summary Final GIST report issued August, 2003 Continued quarterly/annual monitoring of certain Ohio River public water systems Quarterly/annual monitoring of private water supplies (10 locations West Virginia and Ohio - West Virginia: Wash Works 0-2 mile radius and Dry Run Landfill/Letart Landfill 1-mile radius - Ohio: Wash Works 0-2 mile radius - List to include wells, springs, cisterns Conduct C8 monitoring at all DuPont Washington Works facilities according to applicable West Virginia Solid Waste/NPDES, NPDES and EPA HSWA (Corrective Action) permit requirements Proposed MOU -Administrative Details Parties: - West Virginia Department of Environmental Protection - West Virginia Department of Health and Human Resources - Ohio Environmental Protection Agency - E.I. du Pont de Nemours & Company Objectives: - Continued monitoring and reporting ofC8 concentrations in groundwater and surface water - Implement recommendations of me GIST concerning continu sampling and monitoring in WV & Ohio ("in and around the facilities") - Begin first quarter 2004 Proposed MOU -Public Water System Sampling WV Public Water Systems: - Quarterly sampling 1Q2004-4Q2005 atLubeckPS DuPont WW, and GE production wells and finished water (if applicable) - Annual sampling 2004-2005 at Blennerhassett Islan State Park, Mason Cty. PSD, and Racine L&D Ohio Public Water Systems: - Quarterly sampling 1Q2004-4Q2005 at Little Hock Water Association production wells and finished w - Annual sampling ofTuppers Plains-Chester PWS Proposed MOU -Private Water Supply Sampling West Virginia: - Quarterly sampling for 1 year beginning 1Q2004 at locations within Wash Works facility 0-2 mile radius - 10 samples with at least 1 sample being from the following locations with detectable levels ofC8: i Drinking water wells i Drinking water springs i Non-drinking water wells : Springs and cisterns ; One well and spring used for cattle where prior sampling detected C8 concentrations above 5 ug/L - Further sampling/frequency beyond 4Q2004 will be evaluated parties to the MOU Proposed MOU -Private Water Supply Samplin; Ohio: Quarterly sampling for 1 year beginning 1Q2004 at locations within Wash Works facility 0-2 mile radiu 10 samples with at least 1 sample being from me following locations with detectable levels ofC8: Drinking water wells Drinking water springs Non-drinking water wells Springs and cisterns. Further sampling/frequency beyond 4Q2004 will be evaluated by parties to the MOU OEPA Request for Addition Investigation OEPA Request for Additional Investigation OEPA letter to DuPont dated October 23 2003 e Objective: - Better understand the range ofC8 concentrations in surface soil and shallow groundwater, and how these concentrations change over time Proposed Additional Investigation in Ohi -Little Hocking and Porterfield Areas Establish 8 locations for surface soil sampling in these areas based on results of air and groundwater modeling Install 4 new shallow groundwater monitoring wells wi the LHWA to monitor shallowest portion of aquifer. Sample quarterly in conjunction with production well sampling. Proposed Additional Investigation on Ohi -Little Hocking and Porterfield Areas DuPont Suggested Modifications Establish 8 locations for surface soil sampling in these areas based o results of air and groundwater modeling: - Two sampling events will be conducted, one directly after a >.5 inch rain event, the other after 5 days of no precipitation. Durin each event, the following samples will be collected: Foliage layer sample (grass and root zone) Surface soil sample (depth interval to be determined) Install 4 new shallow groundwater monitoring wells within the LHW to monitor shallowest portion of aquifer. Sample quarterly in conjunction with production well sampling. Path Forward Execute MOU covering GIST recommendations Gain agreement on OEPA proposal and DuPont suggestions Propose the additional testing (OEPA proposal and DuPont suggestions) at the ECA process on December 9 Air Topics Modeling Results Sept 2002 - Aug 2003 Air Permit Update Additional Reduction Programs Air Modeling Verification Project - Phase I: Fence Line Monitoring - Phase II: Community Monitoring Modeling Methodology EPA^s Industrial Source Complex 3 (ISCST3) Mode Followed procedures in EPA's Guideline on Air Qua Models (Appendix W) BPIP model to evaluate building downwash effects Terrain elevations imported from USGS electronic fi Receptor grid with 100-meter spacing On-site met data (1996) Rural dispersion coefficients Modeling Inputs - Stack Parameters Emissions from Sept 2002- Aug 2003 = 7,120 Ib/yr Summary of Modeling Result Emissions Scenario Year 2000 Actual Year 2002 Actual Sept 2002-Aug 2003 Maximum Annual Average Concentration (ug/m3) 2.67 1.36 0.86 Maximum Annual Average Concentration in Ohio (ug/m 0.87 0.36 0.18 September 2002 - August 2003 Emissions Air Permit Status Four permits cover APFO sources Each permit has been modified to place APFO emission limits on each emitting unit Emission limits are hourly and annual Emission limits were confirmed via air disper modeling to assure annual ambient air concentrations below 1 ug/m3 at fence line Future changes must not exceed the same fenc line limit, demonstrated by modeling Permit modifications effective November 26, Emission limits will be included in Title V pe Additional Air Reduction Prosram Continuing operational upgrades to five existing scrubbers - instrumentation, interlocks, operating conditions May, 2004 startup of additional filter scrubbers on four existing scrubbers - builds on technology recently developed on scrubber at Washington Works testing of potentially more efficient filter m Air Dispersion Modeling Verification Study Objective Compare results from ambient air sampling an dispersion modeling to understand how mode predictions relate to measured ambient air concentrations Verification Study Scope Air Sampling Program Analytical Methods Modeling Analysis of Results Conducted in Two Phases Phase I: Verification of modeling at facility fence line Phase II: Verification of modeling in community Phase I: Air Sampling Location Simultaneous coverage of all 4 major win directions (N, S, E, W) Capture point of predicted maximum concentration from modeling Include co-located samplers at predicted maximum Total of six locations ASH028071 EXP015846 ASH028072 EXP015847 i> i 00 s -u 0 m co ^ oo Air Sampling Strategy Measure ambient air levels 24-hour sampling duration Seven (7) sampling events scheduled over 6 weeks Vary day of week to capture variations in d operations (non^ expected) and variations in meteorology Record site-specific meteorological and operational data Monitoring Strategy: Samples taken every 6 days for 6 MONTH 1 Oj23456Q[) 8 9 10 11 12(^14 15 16 17 18(^)2021 22 23 24^5)2627 28 29 3(J MONTH 2 1234 5(3)7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Total Samples (1) field blank per event (5) primary samples per event (1) duplicate sample per event*___ (7) samples x (7) sampling events = 49 total sa * Sample location 3 is co-located with location 2 and serves as a duplicate sample Equipment "Sorbent59 sampling method to capture PFOA on ion-exchange media OSHA Versatile Sampling tube (OVS) Captures particles and vapors Remote power source will be provided Weatherproof stations for sampling equipment ^ 0 ^ .'=1 << ASH028077 EXP015852 Analytical Method Validated method being used Acetone extraction followed by liquid chromatography/mass spectrometry (LC/MS) Quantification limit of 0.1 ug/m3 Detection limit of 0.05 ug/m3 Modeling Program Using U.S. EPA ISCST3 Model Model will simulate actual field conditions - Site-specific surface meteorological data (wind s direction, temp, stability) - Off-site upper air meteorological data - Emissions data - 24-hour averaging time - Predictions at actual height and location of air m intake Comparison of Results Comparing 35 pairs of measured and model - (5) primary sampling points x (7) sampling even Will use statistical tools to evaluate correlation/differences between measured an modeled data Phase II: Verification of Modeling in Community Sampling and analytical protocol same as Locations will be selected to: - Correspond with a range of predicted concent - Ensure security of sample Sampling frequency - Expect 8 events at 5 locations during a six we m 5 (n " -0 0 ->. 01 00 ui -4 Summary of Path Forward Items Water - Execute MOU covering GIST recommendations - Gain agreement on OEPA proposal and DuPont suggestions - Propose the additional testing at the ECA process o December 9 Air - Conclude Phase I monitoring, modeling, and evalua -1Q04 - Begin Phase II effort - 2Q04