Document bB6594NnL2GZGv43wzZmDeYpZ

AR226-2360 E L du Pont de Nemours and Company W ashington W orks Halb P.O. Box 1217 W ashington, WV26181-1217 April 16,2004 Allyn G. Turner, Director Division of W ater and Waste Management 414 Summers Street Charleston, WV 25301 Dear D ifectoEjum er, ' In connection with recent discussions between representatives o f the West Virginia Department o f Environmental Protection ("DEP") and representatives o f E.I. du Pont de Nemours and Company ("DuPont") regarding the recommendations contained in the report titled "Ammonium Perfluorooctanoate (C-8) Groundwater Investigation Steering Team Report," dated A ugust'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 carry out the recommendations in the Final GIST Report upon receipt o f 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. In the meantime, if you have any questions concerning this proposal please contact Andrew Hartten at 302-992-6820. DuPont - W ashington Works PJB/djp Attachment ' cc: M. A. Bradley - Spilman, Thomas & Battle bcc: A. V. Malinowski - DuPont Legal - Wilmington D. W. Booth - DuPont - Wilmington Ai S. Hartten - DuPont - Wilmington R. L. Ritchey - DuPont - Washington Works E. I. du Pont de Nemours and Company Shipping: 8480DuPontRd Washington, WV 26181 EXP000377 PLAN FOR IMPLEMENTATION OF GIST RECOMMENDATIONS t Submitted by E.I. du Pont de Nemours and Company April 16,2004 In response to the recommendations o f the Groundwater Investigation Steering Team ("GIST") as set forth in the 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 1. To implement recommendations o f the Final GIST Report with regard to West Virginia public water supply systems, subject to obtaining the consent o f the system owners, DuPont will: a. Beginning in the second quarter o f2004 and ending with the first quarter o f2006, sample quarterly the Lubeck Public Service D istrict, DuPont Washington Works and General Electric public w ater 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 o f2004, DuPont will implement a limited field investigation o f C-8 in soil at the Lubeck Public Service District as reflected in Attachment 2, and w ill report the results of such investigation during fourth quarter of 2004. 2. To implement the recommendations o f the Final GIST Report with regard to Ohio public water supply systems, subject to obtaining consent o f the property owners, DuPont will: a. Beginning in the second quarter of 2004 and ending with the first quarter o f2006, 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 o f the GIST that relate to sampling at DuPont facilities that are covered by environm ental permits issued by the DEP. Such permits have been or w ill be issued or m odified to include those recommendations o f the GIST applicable to these facilities. 2 Annual samples taken under this plan w ill be taken at least 12 months apart. EXP000378 b. Once in calendar year 2004 and once in calendar year 2005, sample the Tappers Plains-Chester W ater District public water system at the locations indicated on Attachment 1. 3. To implement the recommendations o f the Final GIST Report with regard to additional sampling o f private water supplies, DuPont will, subject to obtaining the consent o f 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 o f2004, w ith at least one o f the sample locations being from each o f the five categories listed below: (1) Drinking water wells with detected levels o f C-8; (2) Drinking water springs with detected levels of C-8; (3) Non-drinking w ater wells with detected levels o f C-8; (4) Springs and cisterns with detected levels o f 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 o f2004, with at least one o f the sample locations being from each o f the three categories listed below: (1) Drinking water wells with detectable levels of C-8; (2) Drinking water springs with detectable levels o f C-8; (3) Springs and cisterns with detectable levels o f 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 w ith the second quarter o f2004, with at least one of the sample locations being from each o f the four categories listed below: (1) Drinking water wells with detectable levels o f C-8; , (2) Drinking water springs with detectable levels o f C-8; (3) Non-drinking water wells with detectable levels o f C-8; (4) Springs and cisterns with detected levels o f 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 o f 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 o f C-8 concentrations or to otherwise implement the recommendations of the Final GIST Report. 5. Within 30 days o f receipt o f the validated data for samples collected in the preceding calendar quarter, DuPont w ill submit to DEP a written report o f the results of such sampling. 6. Written reports o f any sampling to be performed described in this plan or any other communication related to this plan w ill be directed as follows: For WVDEP: [Insert designated contact person or position and mailing address] For WVDHHR: For DuPont: ' Andrew S. Hartten E. I. DU PONT DE NEMOURS AND COMPANY P. O. Box 80027 Wilmington DE 19880-0027 I' I Attachment 1 1) Little Hocking W ater 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 W ell F, and Finished Waters ( LPSDAT) 3) DuPont Washington Works Wells designated as AM07-PW01, AO08-PW01, AX13-PW01, K16-PW01, L04PW01, and Y05-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 2'''* * w * * ,<, 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 o f 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 o f 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 o f rain fall followed by a rainfall event that is forecasted not to vary more than 50 percent o f 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 o f rainfall. Soil samples will be collected within 24 hours o f the acceptable storm event. The "dry" sampling event will be defined in this investigation as greater than 72 horns with less that 0.1 inches o f rainfall. Soil samples will be collected within 48 hours o f the acceptable "dry" period. For the proposed field investigation o f soil at the Lubeck PSD, DuPont w ill 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 o f the growing vegetation, the litter layer (the layer of decomposing yet still identifiable organic matter), and the first six inches o f 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 EXPG00382 matter-rich will be sent to a contract laboratory for analysis o f TOC 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 o f a validated analytical method for determining C-8 concentrations in organic matter. Analysis o f the organic rich samples w ill not take place until completion o f method validation. Sample h a n d lin g 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, N J according to ASTM D2487 and will consist o f determining die following soil characteristics: Grain Size, ASTM D422 Atterburg Limits, ASTM D4318 Additional soil tests which are not part o f 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 o f samples were collected. DuPont will issue a report documenting the field investigation and presenting the results after both rounds o f sampling have been conducted and the analytical and soil classification results have been received. EXP000383