Document jyMxkey337KJ79J8o9mRQOyr2

'^ AR226-2567 ) INTER OFFICE ' -.... " I"ltnm~~ MEMO To; , F rom : Mr. Nfike Dorsey, A sst Chief, Perarits & Compliance, OWM Mr, Dave Watkins, Leader, Groundwater Section, WR. Naresh R, S h a h * ^ Subject: Groundwater Monitoring & Contamination at DuPont Washington Works Date: M y 21,2000 ' A meeting was held with DuPont personnel k OWM conference room on M y 19,2000. It was attended by both o f you, m yself Cindy Musser, Jim Duranti, Mark Priddy and Rick Shaver from the agency. DuPont was represented by Bob Ritchey, Andrew Hartten and George Woytowich. The purpose of the meeting was to discuss DuPont's work related to R.CRA Facility Investigation CRFI) program, results and potential next steps and fee status o f well monitoring under the current NPDES pennit so feat interrelationships are defined and concerns understood, !) Andrew Hartten o f DuPont presented DuPont's work related to RFI program. Under this program, DuPont studied environmental impacts (on groundwater & soil) ofpast unitt- Solid Waste Management Units (SWMUs)- Riverbank Landfill, Anaerobic Digestion Ponds, Burning Grounds and Polyacetal Waste Incinerator- at Washington Works. For this purpose,* DuPont took and analyzed many soil samples and installed a number of groundwater monitoring wells fbr monitoring groundwater quality. Most o f fee wells are located along fee Ohio River bank and in the vicinity o f SWMU as shown to fee attached figure. My major comments on this subject are as follows: (1) From fee figure, it is obvious feat DuPont did not install any groundwater monitoring well in fee m anufacturing .(process) area to evaluate impacts o f past manufacturing processes and material handling practices (material storage tanks and Ioading/unloading operations). This may be because it is not required under this RFI program- Mike Dorsey can comment on this item. At other industrial facilities, severe groundwater contamination was uncovered by monitoring groundwater underneath fee process areas. This is a main deficiency of DuPont's work. Under fee appropriate State regulations, fee agency (either Mike Dorsey or Dave W atkins) should require DuPont to install additional monitoring wells at appropriate locations in fee process areas to determine Impacts of past & current manufacturing operations and material handling practices on groundwater quality underneath fee plant site. Several o f these wells should be cluster wells to evaluate impacts on shallow (or perched) and deep aquifers. Groundwater quality data from these wells will help to identify fee contaminants, and to define their plumes and their rates of migration Such work his been already done at many industrial sites for optimizing locations o f groundwater recovery wells (to JBO00J !7 zool iva n :TT IHd T0/80/80 ASH014631 EID192501 Mr. M ike Dorsey, Asst. Chief, Peiasits & Compliance, OWM Page 2 M y 24,2000 pomp & treat) in order to expedite groundwater dean-up, I am really surprised and shocked to leam that DuPont has not even started such w ork (2) Since most o f die groundwater monitoring wells are located along the river bank, the groundwater in these wells can be influenced by the river water and hence measured concentrations o f pollutants present would be lower than actual concentrations. (3) Im pacts of on-slte landfills and other* activities (such as injection wells) perm itted under the State program (or other programs) should also be considered to comprehend the facility w ide picture of groundwater quality. Groundwater program is so fragmented (piece meal) that it is very difficult tc get an overall feefiity wide picture on groundwater quality and hence require any meaningful groundwater clean-up. This is the most critical hurdle to overcome. Note that seepage o f contaminated groundwater from industrial sites is a major non-point source of pollution as far as the surface waters are concerned. (4) In addition to Appendix VDI (of 40 C I S P a rt 26X-RCRA regulations) poUutants/param eters, groundwater samples a t the industrial sites (especially located along the river banks) should be analyzed for the priority pollutants and the water quality stan d ard s for the surface waters because of the above mentioned comment num ber 3 and also many facilities (including DuPont) use groundwater for process purposes including as non-contact cooling water and discharge into the surface waters without any treatment and thus can be impacting quality of the surface waters. (5) DuPont should monitor water levels in flic groundwater monitoring wells quarterly rather than annually to account for seasonal variations, which may not change the groundwater flov direction but may change concentrations o f pollutants. (6) I n light of discovery of methylene chloride seep (by Charlie Moses* compliance group/OEE) an d a seep from Did Fire T raining area gotog into the Ohio River (on the surface), I do not concur with DuPont's conclusion that there is no off-site migration of any contam inated groundw ater because of operation of their well system. I f this was the case, there should not be any seep in the first place. It is difficult to find out any subsurface seeps going into the river. W ith these case. I sincerely request both o f you to pursue appropriate actions in DuPont's cc: Cindy Musser, Rick Shaver, Mark Priddy, Jim Duranti, Jerry L. Ray, Allyn G.Tumer, Previn G. Sangaru, Mike Zeto, Randy Sovic, Charlie Moses, John Britvec JBQO0118 sooB rv i et:tt i ns io/ so/sd ASH014632 E ID 1925Q 2