Document q3kd1aDy3xVXzgJ6YKQbaQV4j

AR226-2535 WASHINGTON WORKS, PARKERSBURG COMMITS ON DRAFT R O M PERMIT 1. Page 5, paragraph 8 - Inspection and Entry Reasonable advance notice should be given to the permittee for a facility inspection or site visit. The advance notice will allow proper arrangements to be made by the permittee to accomodate the inspector(s). 2. Page 9 - Item A, paragraph 4 - Nature of VI The draft permit states that a Verification Investigation (VI) will be required for six SWMUs. According to this paragraph, the nature of a VI is to determine if a more comprehensive ROSA Facility Investigation (BFI) is needed. Several of the requirements for the VI are more appropriate for an VI. We request that the permit specify that commonly-used field* screening technologies, such as soil-gas surveying and conepenetration technology, can be used for the purpose of the Verification Investigation. 3. Page 10, Item B-l first paragraph - Timeframe The permit requires that Du Pont submit a VI work plan within 45 days of the effective date of the permit. This timeframe should be modified to specify 60 days. The more reasonable timeframe is needed to assess the currently available data and determine where additional investigation is needed. 4. Page 10, Item b.(1)(a) Considering the purpose of the VI as stated by the agency, we request that the permittee be allowed to take either soil or ground-water samples to determine the occurance of contamination, if it can be justified. Accordingly, we suggest that the wording of the permit be modified from "soil and ground-water samples are to he obtained* to "soil and/or ground-water samples will be obtained." This language will also provide for consistency with Item (3)(d) on pages 11 and 12 of the draft permit, which specifies that the permittee may replace the ground-water investigation with an alternate sampling methodology (e.g., soil-gas surveying). CF019242 EID182404 5. Page 11, Item (2) - Sampling Parameters Attachment 1 of the Draft Permit contains the required sampling parameters for each of the SfMUs (except for the injection wells). This list contains oyer 100 compounds. Du Pont should he permitted to review the plant records and tailor the parameters to those compounds expected to be present in the SWMU . If the nature of the compounds present in the SWMU is unknown, a more comprehensive list of parameters would be appropriate* 6. Page 11, Item (2) - Analytical Methodology Attachment 1 contains the suggested methodology for analysis of samples. It is our understanding that the laboratory can use alternate methods of analysis providing that they can justify the change. The permit should be modified to include language specifying this understanding. 7. Page 13, Item (3) - Timeframe The permit specifies that the YI report must he submitted within 180 days of EPA's approval of the work plan. We request that the permit specify that an extension will be granted if winter months are included in the 180-day period. For example, if the plan is approved in late fall, the winter weather la the Parkersburg area will prohibit much of the field work (data collection). In addition, the VI work plan may specify a longer timeframe for field work, based on the degree of data collection determined to be necessary. The timeframe in the permit should state 180 days or in accordance with a schedule approved by EPA as specified in the VI work plan. 8. Page 13, Item (4) - Timeframe We request that the timeframe for submittal of existing ground-water data be extended from 45 to 60 days. We are _ currently installing monitoring wells and collecting sampling data. The additional time may allow for more complete information to be submitted. CF019243 EID182405 9, Page IB, Items (e) and (!) We suggest two additional wording modifications on page 18, sections (e) and (f). The geologic cross sections should describe the extent of "all impacted and/or potentially impacted hydrogeologic units. Presentation of water level data will include "if applicable, vertical gradient sections." If, however, the shallow aquifer is not contaminated, deeper wells need not be installed at all locations. Vertical gradient information may not be collected in some areas. 10. Page 17, Item (3), first paragraph The added requirement that split or duplicate samples be taken-should- not-be-unnecessarily burdensome. 11. Page 17, Item (4) - Corrective Action Criteria EPA'a current policy regarding the criteria used to. determine if a corrective measures study is required should be made available to Du Pont. This information should include new corrective-action standards or guidelines for contaminant concentrations. 12. Page 22, Surface Water Sampling The requirements for a surface-water study are too detailed. The surface-water study should not require inflow, outflow, depth, temperature stratification, and volume of lakes and estuaries. This information requires a complex investigation sad collection of field data which may be unnecessary to achieve the desired goal of the EFI. This information should only be required if it is shown to be needed for delineation and/or remediation of a release. 13. Page 25, Item 1-3 - Report Revision and Dispute Resolution The timeframes are unreasonable and should be modified as proposed below: . o The draft permit requires that DuPont submit a revised report/plan within 30 days of receipt of BPA's disapproval letter. H EPA's comments are extensive, more time will be required to revise the report. Due to the complexity wo6fi0lltdhameysas.kieteWa,hegwoneoBdrPefAqafusietschtometmfehfnaottrstthateroetsimumibnemofirrt,amretehvbeiespeeedrxmpriaetpntodereetd to within 30 days. CF019244 EID182406 ft Msnute resolution: A timeframe of IB days to respond to IPA^s comments is unreasonable. We would need a minimum of 30 days to prepare a written justification for the disagreements. The permit requires that a reyised report/plan be submitted within 45 days of EPA s disapproval letter. We request that the timeframe for submittal of a revised plan/report be within 46 days of receipt of IPA'a response to our letter of explanation for the disagreement. 14. Pact Sheet, page 3 third full paragraph The fact sheet states that if a release into the environment from a SWMU occurs, a substantial threat to human health and in some instances. All releases and/or probable releases should not indiscriminately be assumed to pose a significant lhat % human health and the environment, fe propose that the last sentence of this paragraph be deleted. IS. Pact Sheet, page 6 - Polyacetal Products Incinerator The nolvacetal products incinerator is not an open-burning process. The pits are covered during operation. The reference in the permit should be modified according y. 16. Fact Sheet, page 9, third full paragraph According to the fact sheet, adjustments to theproposed feed Units will be made in the final permit if site-specific information becomes available to justify the adjustmenta. Attachment 1 of this letter contains proposed adjusted feed limits. The site-specific incinerator stack dispersion 2efforts which support these adjustments is In Attachment , CF019245 SID182407