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AR226-2563 DuPont Fluoroproducts September 28, 2001 DuPont Fluafoproilucts Chestnut Run Plaza P.0. Box 80702 Wilmington, DE 19830-0702 M r. Garth Connor (3EC10) U, S. Environmental Protection Agency, Region DDE 1650 Arch Street Philadelphia, PA 19103 Via FederalExpress Dee Ann Staats, Ph. D . W est Virginia Departm ent o f Environmental Protection 1356 Hansford Street Charleston, WV 25301 Via HandD elivery R e; F irst Supplem ental Response to July 24,2001 Request fo r Inform ation Dear M r. Connor and D r. Staats: On behalf of E . I. dupont de Nemours and Company ("DuPont*) we hereby file this F irst Supplemental Response to the Request for Inform ation addressed to M r. Paul Bossert at DuPont's W ashington W orks facility and dated July 24,2001 ("Information Request"). This response supplements our initial rp o n se which was dated August 31, M 01. In providing this F irst Supplemental Response, DuPont reiterate} and fully incorporates by reference its objections set forth in the August 31,2001 rp o n se. Additionally, this supplement does not include inform ation relating to "capita! requests" because DuPont is awaiting clarification from EPA Region HI as to meaning o f this term. W hen such clarification is provided, DuPont will address this inform ation in an additional supplemental response. , DuPont's supplem ental responses are as follows: REQUEST NO. I t Provide a process flow diagram for each manufacturing process line and treatm ent system where C-8 is utilized at the Facility, For each process unit in the manu facturing p ro c s Une or treatment system provide a narrative description o f the process unit, a C-8 m aterial balance fo r each process unit, the identification o f the destination o f C*8 (whether it is recycled, recovered, emitted to air, land or w ater), and the concenlration o f C-8 and its b y products in each o f the process streams. The basis for calculation should be the design capacity o f the u nit RESPONSE: D uPont's response is provided in Exhibit 1 to tins supplemental response. t Ltf POG!& NfftoontAdCmnpury @ MiMfMRiejcMFtlW EID197012 First Supplemental Response September 2 8 ,2 0 0 1 Page 2 o f4 REQ U EST NO . 2; Describe each treatment process used for die recovery or treatment o f PFOA and the effectiveness o f each unit in the recovery or treatment o f PFOA or substances containing PFOA utilized at the Facility. RESPON SE; DuPont's response is provided in Exhibit 1 to this supplemental response. REQUEST NO . 3; For each o f the previous five years quantity the amount o f C-8 utilized at die Facility and provide the quantity and com position o f C-8 released into each m edia from each process unit and for the Facility as a whole. RESPON SE; DuPont's response is provided in Exhibit 1 to this supplemental response. REQUEST NO. 5 ; Provide a copy o f each document and study related to the treatment, disposal, containm ent, ami remediation o f C*8, commissioned by or conducted by DuPont, for all facilities. Include afi documents related to such studies (Including all capital requests sad attachments thereto) and actions taken as the result o f such studies. RESPONSE; DuPont supplements its August 31, 2001 response with t o documents provided in Exhibit 2 to this supplemental response. REQUEST N O . 7 ; Identity all landfills utilized by DuPont to dispose o f C-8 from t o Facility where seeps or leakage or migration to groundwater have occurred. Describe what measures DuPont has taken to eliminate t o seeps, and if- t o seeps have been eliminated. Provide all sampling data for all constituents from such seeps, including C-8. RESPONSE; D uPont supplements its August 31,2001 response by providing sampling data for aU constituents for t o Local, Letart, and D ry Run landfills in Exhibit 3 to this supplemental response. REQUEST N O . 9; Provide all monitoring and modeling o f C-8 for groundwater, soil, surface water, air, sludges, sediments, terrestrial and aquatic species and htm ans in W est Virginia and Ohio. Include in your response a copy o f each capital request for such momtoimg and modeling and all attachm ents thereto. RESPONSE; D uPont supplements its August 31,2001 response with t o documents provided in Exhibits 2 and 4 to this supplemental response. DuPont has initiated an air m odeling study for PFOA at t o W ashington Works facility and when finalized, DuPont w ill submit t o report o f this modeling to t o agencies. EID197Q13 First Supplemental Response September 28,2001 Page 3 o f4 REQUEST NO. 11; Provide all sampling analysis and volume o f any leachate or groundwater recovery systems in operation at any facility handling C-8 sludges from the Fatality, o r other Teflon manufhcturing byproducts, and the location and means o f disposal o f that w aste/w astew ater. RESPONSE; DuPont supplements its August 31, 2001 response with the documents provided in Exhibit 5 to this supplemental response, REQUEST NO. 12: Set forth in detail the sampling procedures and analytical methods for C-8 in water, soil, air and biological tissues. Describe if m ethod differs depending on location, e.g., landfill leachate versus effluent outfall. Identify and describe what, if any, lim itations or problems (e,g., adhesion to glass), are associated with such procedures or methods. RESPONSE: As a point o f clarification, the sampling and analytical procedures described in subparagraph a o f DuPont's August 31,2001 response to Request No, 12 apply to soil, groundwater and surface w ater. REQUEST NO. 16; Provide a copy o f each study and document related to existing or potential human health or environmental effects o f C-8 conducted or commissioned by you or in your possession. Include all documents related to foe need for such studies and actions taken as the result o f such studies. RESPONSE: DuPont supplements to August 31, 2001 response with the documents provided in Exhibit 2 to fins supplemental response. REQUEST NO. 17: Provide a com plete copy of. foe C-8 monitoring database for Facility employees on disk and identify form at Include any results o f blood sampling or urinalyses o f foe Facility employees where C-8 w as detected. B B ^ Q N S ll to response to this request, DuPont submits a complete copy o f foe APFO monitoring database for Facility employees on compact disk labeled as Exhibit 6 , The database is formatted in MS W ord, REQUEST NQ. 19: Provide copies o f all documents related to foe procedures, justification, background data, analysis, used to establish DuPont's community and worker action levels for C-8. EID197014 First Supplemental Response September 28,2001 Page 4 of4 RESPONSE; D uPont supplements its August 31, 2001 response w ith the documents provided in Exhibit 2 to this supplemental response. Should there be any questions related to this supplemental response please contact m e at (302) 999-2415 or Bernard Reilly at (302) 774-5445. Very truly yours, David Rurak Enclosures cc: Janet E, Sharke, Esq, (w/o en d s.) D oc.N o. 178441 ED197015