Document byo8NzrmyMVaKpkgk9aDYRpE6
AR226-2545
WTO04587S291 DOPOHT WASHINGTON WORKS RESPONSE TO EPA RFI WORK PLAN NOTICE OF.DEFICIENCY (NQDl_eOMMENTS
An MOD lefcfcer dated 1/15/98 concerning the 9/24/97 DuPonfc Washington
III Works RFI Werkplan, was received from Region
EPA on 1/20/98. EPA and
DuFont personnel held a phone conference call to review and discuss the NOD conanenba on 2/3/98. Our response to the NOD coomenta presented bel&w
Include the underafcandinga and agreefflenta reached during the 2/3/98
conference call.
RESPONSE TO GENERAL COMMENTS
General CoMieate <1
III As agreed with Region
EPA on 2/3/97, DuPont will conduct the
following Investigations concurrent with RFI Work Plan iBplaaentation:
A, Monitoring Data Evaluation
B. Slope Stability Investigation
C. Leachate and Perched Water Investigation D. Process Lines and Waste Stream i,ln@s Investigation
Please nob, the EPA basis for these investigations speelfloally pertains to NOD general eensienta 2, 3 4, and S, respectively. Our detailed comments and clarifications are provided in those specific response sections.
With regard to Items A, 8, C and D, listed above, it is our Intent to
complete this work either prior to conducting the prellBinary groundwater modeling activity, or concurrent with RFI field work implementation. The RFI Implementation Schedule has been revised to reflect these additional Itens and a copy of the revised schedule is included in the Attachnenta.
General Comment 12
We agree that current and previous site groundwafcer flow conditions are
significantly influenced by production well Installation and pumping. The
groundwater system's transient nature la the primary reason for conducting
^
preliminary groundwater nodeling activities prior to performing the RFI
ffi
field wopk. (Mote: "preliminary" inplies that further model refinement will
g
b@ completed after the field investigation). It l8 our belief that only
;3
through groundwater modeling can an accurate evaluation of current,
j
historical and future site groundwater flow conditions be conducted,
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The preliminary modeling groundwater flow conditions
of
current,
historical
and
future
site
and/or
investigation
foeua
will
areas
help identify any additional
which should be added
data
needs
investigation.
Refinement
needs
of. the
newly
bo
constructed
the
RPI
field
t(her.ogu.g, haeqoulilfeeer tihoyndroafulaicddpirtioopnearltiedsatoa.r aquifer heads) will gbroeuansdsweastseerdmodel
The preliminary groundwater modeling
needs will be coianmieated BPA
results
and
any
additional
data
Technical
Memorandum",
to
to
in the "Final RPI Sampling
be Issued in accordance with
locations
provided in Appendix A, Project Issued to EPA for review and
Management
Plan.
the schedule
Thia mettorandua will be
Implementation.
approval prior to beginning RFI field work
We plan to continuously
investigation phase Is
upgrade
the
site
groundwater
flow
model
as
each
model Data
will
be
completed. However, a constructed upon conclusion of
very accurate groundwater
the RPI field work
validation further defined
methodology la in the QAPP.
an
integral
step
in
this
process
aotvltiea. and is
With regard to item A, compiling and evaluating
Monitoring Data
Evaluation,
DuPonb
is
currently
input into to; site
the
g
r
o
u
n
d
w
a
t
c er
urrent model
.
a
n
d T
hi
his
sto da
ric ta
al in
c
site lude
h s,
ydro but
geo
is
logt not
e
l
data imite
f d
a
r
well pumpginegoloragtye, am, oannidtoarqwueiflel r potentioBetrio head measurements, production
set
primarily
exists
through
properties,
conducting the
Thia 1991
very
comprehensive
data
and
other
current/historical ite
groundwater
Verification Investigation investigation activities which
includes s
1997.
groundwater elevations taken as recently as fourth quarter
General eoBMnt_t3
We agree to conduct a slope
However, it la important to
stability
investigation
as
requested.
indicates prevented
riverbank by the
slope
I
no
nst
te
ab
that ility.
no S
evide lope
nce
Ins
current tability
l
y Is
exists large
l
th y
a
t
vines,
and
well maintained vegetative grass) that Is present
cover
(i.e.,
treea,
shrubs,
and
riverbank area.
along the alluvial terrace downslope and
slopeInsatcacboirlditaynceinvweitshtigGaetnioernaldCuorianagenfBc P#I 3>fiewled wimillplecmomenptleatteionth; e fallowing
*
Conduct a Riverbank
visual 'inspection Landfill
of
the
slope
area
along
the
entire
exist.
Areas
with
length to extensive
Identify if any slope stability
vegetative covers will be
issues
InteraittenM.y cleared to expose soils, if practical.
*
Conduct a visual inspection Ranney Well) in the
of
the
site
production
wells
(e.g.,
occurred
due
to
area pumping.
to determine if
Note: In 0091
any
land
deformation
haa
production
wells
are
constructed
on
instances, the concrete platforms
site
and
are
situated on areas bo evaluate.
covered
by
cement
or
asphalt
and
may
be
difficult
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* Conduct an evaluation of the ultimate dynamic factors, such as heavy
precipitation (e.g., 25, 50, and 100 year flooda) te determine their potential inpact on the site. DuPonfc intends to consult with
various agencies such.aa the WVDEP, National Weather Service and V Army Corps of Engineers as needed during completion of this evaluation.
The slope stability asaesBent results will be included in the final RFI
Work Plan report.
General Comment 4
As proposed In RFI Work Plan section 3.5.2.1, a thorough soil and groundwater investigation of the RBU.1 seep area will be conducted. This Investigation is designed bo determine whether the current "trench drain" type leaehate collection system effectively captures the perched groundwafcer containing metbylene chloride. The investigation in thia area will also aid in delineating the extent of soil and groundwater impact. The leachate source elevation will be surveyed In conjunction with other
RFI survey work.
As noted previously in the quarterly reports submitted to USEPA, all
collected groundwater is passed through an on-sit carbon adsorption unit where greater than 99% metbylene oblorlde removal is typically achieved prior to discharge to fche Ohio River through an HPDES permitted outfall.
As requested during the 2/3/97 phone conference call, we will prepare
a unit operation performance summary of the RBU.1 leachate collection and treatment system to aupplenenb the information previously aubsiifcted on
7/11/97. This information will be Included in the ?1 Work Plan report. With regard to investigation of RBLL2, we will proceed with th
activities proposed in the RPI Work Plan, which include collecting a soil boring sample and installation of a groundwater Monitor well located downgradienb of RBLL2. In addition to these activities, a survey of the laaohate source location and flowrate will be completed during fche BFI field work.
general Comment t5
Aa reviewed during the 2/3/97 conference call, we plan to first conduct soil sampling at known of suspected source areas (i.e., the site SWMUg).
The 1991 Verification Investigation (VI) did not generally Include soil sampling at locations within known SWMU boundaries but instead was focused on sampling locations outside fche SHMO perlneter. For this reason, the 8FI Work Plan haa been designed to primarily focus on SWMO source area characterization and delineation. Analysis of fche data collected from the
RFI field work will determine if there is a basis to ivestigate any
underground process lines as possible release sources. Any need identified for further process line evaluation will be reeoBMiended in the RFI Work
Plan Report.
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General.Comment 6
DuPont has now received SPA guidance documents EPA/540/4-91/001, "Soil Safflpling and Analysis fop Volatile Organio Compounds" and EPA/540/S-95/504, "Low Flow (MinliBal Drawdown) Ground-Wafcer SaiBpiing Procedwea". DuPonfc
Intends to eonduot; all BFI Plan field aetelviblea In accordanoe with these
guidance documents, site conditions permitting. Any field deviations from this guidance will be eoBBiunieated to BPA.
EID911323
HVD045875291 OUPOMT WASHINGTON WORKS RESPONSE TO EPA KFI WOKK PLAN NOTICE OF DEFICIENCY (SOD) COMMENTS
RESPONSE TO SPECIFIC COt&ffiMTS
Documents nenttonaii below are Included In the "List of Attachments" located at the end of this section.
Specific Comment *7 The DuPont Washington Works 100 year floodplain elevation la 606.2 feet
above mean sea. level (MSL). This information has been added to Section 2.3.3 and revised text Is included in the Attaehflienbs.
Specific Commanj: >8 Section 3.5.3 haa been revised and the revision is included in the
Attactenenta.
Specific Comment 9 Figure 1 has not been revised since Lock and Dan No. 19 was removed
years ago and is no longer in service. It has no impact n determining the
pool elevation of the Ohio River adjacent to Washington Works. The Belleville dan, located approximately 12 miles down river from the DuPoofc Washington Works site, well beyond the area covered in Figure 1, now controls the Ohio River pool elevation adjacent to OuPont Washington Works.
Specif ie Comment^ HO Figure 2 has been revised to include the location of outfall *005 and
the seepage eolleetion and treatment unit. A revised copy of Figure 2 is included in the Attaehnehts; Please refer to the 7/11/97 seepage treatment unit subaittal for additional detail regarding the location of the seepage treatment unit and capture area.
Specif ijs Coiiroent til
A scheBatic has been created to indicate the general location of the DuPont Washington Works fluaropolymer manufacturing area. The location of DuPonte Washington Works and Ita associated warehouses, General Eleotria Plastics and the Shell Chemical and HuntsBan Chemical manufacturing site are shown on a modified sehenatic of Figure 1, included in the Attachments. Anoeo is located approximately 12 ailes up river in Ohio, well beyond the
area covered in Figura 1, and we have removed it from Section 1.2. Revised
text is included In the Attachments.
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Specific Coanent l2 A revised RFI Implementation Schedule l3 Included In the Attachments.
Spec if ic Coiangnt H3
Table B-2 has beea revised to replace method 8240 with 8260 and is inoluded in the Attachmenta.
Specifio Comnenta *l4. 15 & i6 The QAPP haa been revlaed to reflect the information in eonaaentg *l4,
#15 and #16. Revised OAPP text is included In the Attachments.
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WTO045875291
DUPONT WASHINGTOM WORKS RESPONSE TO SPA RPI WORK PLAN MOTICB OP DEFICIESCY (HOD) COlfltCTTS
LIST Of ATTACTPJEMTS { to be added }
EID911326
1?
^
^w <fr^ ^'^ / ^ ^'rc
c^-W^ ,/ 2'
|/\JCw4- a iun"a"/^
^
tt+.
*
3/,+a4-^-
,
k*$ ^
,
-
ts system 60 e&pture the water leaking tn the <luropalvn55?orQeeaain<y area. -
^- k i i WW\ It still f"y" l
l
f)Crf>o(J Through the second guartar of seepage have been processed.
1997,
ts
approxieiataly 2.5 million gallons unclear whether oe OBS SBtA-1 ia
off
H _
Vv'""^
,,
i^ortcptek.
seeping or nst. please eottEinn. Tha Work Plan should include She
'
measurement oC alevaeign and quaneifey of BBIA-I. KBU<-2 (Attaehftenta e
^
|
\vM^
and 0) and other geepa fouad. Also, the perched eanta.riiina6.ad watnr
'
should be invstigaeed Sor the exfceat and source control..
S.
a,fttS+fC'iirrrssf+fi--11t.,
6.
tU ^dr^^^ The VesiticaisiLan. lavestigatian laborateayy resulta def6d TC8 and SCB do ,
i& the gro'tadwaeeE samples, hue noe in the soila. tse<s AefcaehswitB B ajunid., P?I MWhhfetrrfet ias thue asoaurcee(ta)l ooet feehtoa ecQoAnceaaBmiiinaaafetioeion? AAnn. innwveftssf&ciiag'aaffecii.oon on th process lins aad waata atream l.iae should be conducted. Thia ioves^-g'&Sion (Bust be pepformed prior to conducting tha inodaliag.
P^ Cr<'A.r yo'.tt^aAiT <^(>c^ lii.ss <<Q B(oc$' Ws OS *<'<+ Sk'P
the Collowin^ E?A publioaciens, which are included, should be gonaidsred. in ths aanipling. B9A/540/4-&3./Q01 SotX Sampling and ftnXysia tor
Volatile Organic COfflpaunda and S?A/540/S*-95/S04 tow-Plow (Miniaal
Orawdewnt Oroiffld-Waear Saaipling Proesdures.
TWu ^clodt.^ ^
'-
s?gezzc eoiotaT8
/
'
Ocrt"<_^----
Section 2.3.3 inusfe include the MashingtQR Works.
ehe
elevation
of
the
lOQi'year
/
tloodplain
for
<8y
'--'
/ Iji^"*
',
Swaeellesiondea3i.g3n.3aeemduse&incclluodseuralanmguusatgeRatvhBajtsssiotartsaappccoavaatl. antryoffol ldthem^oWaVttDoBrPingas
wall as the O.S. SPA. Q^ ^^4 ^^^ V
u ^p ^pplca^'e
E'igure l should ioclude the s&fueturs line o( Iioek and Dam Ho. IS across ehe Ohio River, and should alao include the aetval location o thtt site.
\^\i^J'ff
-1'--'
V'f^'
?iguE'e 2 should include ehe seepage collection and tEeatmenc unit as well as outfall 005.
h\\c "
'~^r*~
1
/-\
11.3.
A- f^ U^
\i^i /~^.
","- ^W ^P .' All described locations in
Huntsman Chemicals, Amoco,
aopear on a iwp.
OW
Quarcerly pccgsess repocta
RFI iBiplementaeion Schedule
tha Woek Plan, such aa Shell Chemicals,
Fluropolymer Manueaeturing area, etc, should. .
iP
Opooi^s'iifloilse
-^^4--
or deSC'-'.O^ <OC&.+^A
Qf ^&."taj^^ poxA+i-o+o IWft+HM .
to EPA, and the WV OBB inuae b added -ko the
in Appendix A.
Q^
Table B-2 in Appendix
off the Sampling and AnalyiB plan EBeereneea SW-
946 ,,chod 6240 ter analyala ot voSs. Please note that shia aeehed. is
now obsolete and has been Eeplaead by Biachod 82SO.
lf<AO^-
The Quality Assurance validaston tor 10 ot
and criteria tor how
STOjeet Plan ths aaaples. these aamplea
(QA9P). Appeadix C, propoaM
The
will
plan should include toe selected. /V\iKfc
safci.oniLi.e
A- OAWV
in addition ea the arocedures listed in Seceion 5.2 at the QAM in
ABpandi.x C. EPA Ettcsnunedds
meEhanol sr eeagent grade alcohol rinse cor
e<iuipmeot used (or eolleccing organic samples. A dilute nxtne ri-nse
should be used tor inorganic (infttala) sampling equipment. Q^
^(I,fA-S^we^f
^Cil?
,.
l?-"'lwif
The narrative describing trip blanKa in Section 3.7.3 ofi and Analysis Plan. Appendix B, ifl in airror. The language consistent "ich the diacussioaa in the QAPP, Appendix c.
^.^
^u"55
/i, l4otfe
cha Sampling should 6a
^. r^t L,.-6^
Apr.1 1.
t-rt
CQfVSTe> ^Unak^ 1^/^icS
EID911327
