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AR226-2358 m DRAFT PHASE II MONITORING/SAMPLING WORK PLAN DUPONT WASHINGTON WORKS SITE WASHINGTON, WEST VIRGINIA Date: March 2004 Project N o.: 507423 18983990.04006 18983992.04006 lig sr A CORPORATE REMEDIATION GROUP An Alliance between DuPont and URS Diamond Barley Mill Plaza, Building 27 Wilmington, Delaware 19805 EXP000387 Draft Document Do Not Cite or Quote, March 30, 2004 Draft Phase II Monitoring/Sampling W ork Plan w TABLE OF CONTENTS Table o f Contents 1.0 Introduction 2.0 Background Information 3.0 Air M odeling V erification S tu dy................................................ 3.1 Phase II A ir M onitoring A ctiv ity ..................................... 3.1.1 A ir Sampling Events, Duration and Locations 3.1.2 Number o f S am p les.......................... -.................. 3.1.3 Sampling Equipment, Methods and Schedule. 3.1.4 Analytical M ethods............................................... 3.1.5 M eteorological M onitoring................. ............... 3.1.6 M eteorological D ata............................................ 3.1.7 M odel Selection and M ethodology................... 3.1.8 Receptor S election ............................................... 3.2 Progress Reports and R esu lts............................................ 4.0 Water M onitoring A ctiv ities....................................................................................... 4.1 Private W ater Sources....................................................................... ................ 4.1.1 W est Virginia: GIST Conclusions and Recommendations for W est Virginia Private Water Supply Sources............................... 4.1.2 W est Virginia: Private Water Supply Sources A ctiv ities........... 4.1.3 Ohio: GIST C onclusions and Recommendations for Ohio Private Water Supply S ources..................... ................................... 4.1.4 Ohio: Private W ater Supply Sources A ctivities........................... 4.2 Public W ater S ources.........................................................................-.............. 4.2.1 W est Virginia: GIST Conclusions and Recommendations for W est Virginia Public Water Supply Sources............................... 4.2.2 W est Virginia Public Water Supply Sources A ctiv ities............ 4.2.3 Ohio: GIST Conclusions and Recommendations for Ohio Public W ater Supply S ources.......................................................... 4.2.4 O hio Public W ater Supply Sources A ctivities............................. 4.2.5 Ohio: OEPA Recommended W ell Installation at Little Hocking W ater A ssociation W ell F ield ........................................ 5.0 Surface Water and Groundwater M onitoring..... 6.0 Surface S oil/B iota (V egetation) Sam pling......... 7.0 Schedule and R eporting.......................................... 8.0 R eferences.................................................................. 5 5 5 5 6 6 7 7 8 8 8 .9 .9 .9 10 11 12 13 13 13 14 14 15 EXP000388 2004W orkP lan 4.do c Wilmington, DE Draft Document Do Not Cite or Quote, March 30, 2004 Draft Phase II Monitoring/Sampling W o rt Plan Table o f Contents Table 1 Table 2 Table 3 . TABLES, Summary Data for Proposed Sampling Locations In and Around DuPont W ashington W orks Site Summary o f GIST Private Water Source Sampling Recommendations Summary o f GIST Public W ater Source Sampling Recommendations Figure 1 Figure 1.5 Figure 2 Figure 2A Figure 3 Figure 4 Figure 5 Figure 6 FIGURES O ffsite M onitoring Locations Near the W ashington W orks Facility/Local Landfill in W est V irginia and Ohio OVS Tube O ffsite M onitoring Locations Near the Dry Run Landfill in W est Virginia W ind R ose - DuPont W ashington Works O ffsite M onitoring Locations Near the Letart Landfill in W est Virginia Public Water Source M onitoring Locations in W est Virginia and Ohio Proposed Locations o f the Four Shallow W ells at the Little Hocking W ell Field W ashington W orks M OU Schedule Appendix A APPENDICES Phase II Quality Assurance Project Plan, DuPont W ashington Works Site, W ashington, W est V irginia 2004VVorkPlan4.doc Wilmington, DE ------------------ -- EXP000389 ii Draft Document Do Not Cite or Quote, March 30, 2004 Draft Phase 11Monitoring/Sampling Worfc Plan Introduction 1.0 INTRODUCTION This Phase II M onitoring/Sam pling W ork Plan (W ork Plan) is referenced as Appendix 5 in a Memorandum o f Understanding (M OU) between the United States Environmental Protection A gency (USEPA) and E. I. DuPont de Nemours and Company (DuPont) that documents DuPont's intent to conduct a Perfluorooctanoic Acid (PFOA) Site-Related Environmental A ssessm ent Program. This MOU summarizes DuPont s commitment to provide additional m edia-specific m onitoring o f PFOA by conducting a PFOA SiteRelated Environmental Assessm ent Program at and near the DuPont W ashington Works Site in W est V irginia. PFOA is a disassociated form o f ammonium perfluorooctanoate (APFO, com m only known as C-8 and historically know as FC-143) and other salts. PFOA is the entity detected by the analytical instrument for all media. S oil and aqueous samples w ill be analyzed for PFOA and reported as C-8 for consistency with historical including Phase I, results. C-8 results for soil and aqueous samples are obtained through a mathematical conversion. PFOA results for soil and aqueous sam ples are m ultiplied by the ratio o f the m olecular w eight o f C -8 over the m olecular weight o f PFOA. Air and biota samples w ill be analyzed and reported as PFOA. The PFOA Site-R elated Environmental Assessm ent Program em ploys a phased approach. Phase I includes commitments previously made by DuPont that were m em orialized m a Letter o f Intent (LOI) and that includes environmental monitoring and m odeling activities ' at and near the DuPont W ashington W orks Site in W est Virginia. Phase I also encom passes other relevant environmental work not within the scope o f the LOI. Many o f the Phase I environmental m onitoring/m odeling commitments have already been conducted. However, some Phase I com mitments, such as surface water and groundwater monitoring at the L ocal, Letart and Dry Run Landfills per W eJ Virgima National Pollutant Discharge Elim ination System (W V/NPDES) permits W V0001279, W V0076538, W V 0076066 and W V 0076244, are ongoing. D etails o f the LOI commitments and other relevant environmental commitments can be found in Appendices 3 and 4 o f the MOU. A listing o f subm issions made by DuPont pertaining to environmental m onitoring/m odeling at or near the DuPont W ashington Work facility is also provided in the Appendix 1 o f the MOU. Phase II o f the PFOA Site-Related Environmental Assessm ent Program includes activities that augment and build upon the LOI and other relevant environmental commitments. Phase II includes sam pling on-site and sampling off-site m both W est Virginia and Ohio. The follow ing m edia w ill be sampled during Phase II: Air ' Drinking water sources (private and public water sources) Groundwater O Surface water Soil Biota EXP000390 2004WorkPlan4.doc Wilmington, DE Draft Document Do Not Cite or Quote, March 30, 2004 Dran Phase II Monitoring/Sampling W ork Plan Introduction A description o f the Phase II work for each media is provided in this W ork Plan. A ll work described in this W ork Plan w ill be com pleted by DuPont or its authorized representatives. This document is organized into the follow ing sections: Background Information Air M odeling Verification Study Water Source M onitoring A ctivities Surface W ater and Groundwater M onitoring A ctivities Soil/B iota (Vegetation) Sam pling A ctivities Schedule and Reporting References For each m edia section, a brief discussion o f the study objective.sampling locations, number o f sam ples, and frequency o f sam pling is presented in this W ork Plan. The Quality Assurance Project Plan (QAPP describes the specific procedures and practices that were and w ill be follow ed to ensure that data generated during the Phase II investigation at and near the DuPont W ashington W orks facility in W est Virginia and Ohio are technically sound, usable, and properly documented. 2004WorkPlan4.doc W ilmington, DE EXP000391 ------ 2 Draft Document Do Not Cite or Quote, March 30, 2004 Draft Phase II Monitoring/Sampling W ork Plan background Information 2.0 BACKGROUND INFORMATION oi This Work Plan has been prepared to document m ulti-media PFOA sam pling and monitoring activities that w ill be com pleted by DuPont during Phase II. These activities were developed pursuant to discussions w ith one or more o f the follow ing regulatory agencies: W est Virginia Department o f Environmental Protection (W VDEP) in regard to m ulti-m edia consent order G W R -2001-019 (Consent Order) Ohio Environmental Protection A gency (OEPA) United States Environments The m ulti-media Consent Order was entered into between the W VDEP, the W est Virginia Department o f Health and Human Resources - Bureau for Public Health (W VDHHR-BPH) and DuPont on Novem ber 15,2001. The Consent Order identified a series o f requirements and tasks to be performed by the parties (W VDEP, WVDHHRBPH, and DuPont) in order to determine whether there has been an impact on human health and the environment as a result o f releases o f C-8 from DuPont operations at the W ashington W orks facility (facility) and the associated landfills (Local, Letart, and Dry R u n 1). le Consent Order established the C-8 A ssessm ent o f T oxicity Team (CA TT)\which consisted oE scientists from a ca d W a (M arshall University), government (USEP^, EPA Region 3,W VDEP, W VDHHR-BPH), non-profit organizations [NatiohaTInstituteW Chemical Studies (NIC S), T oxicology E xcellence fpr Risk A ssessm ent (TTERA)], and industry (D uP ont^ M ), to assess/t^ K id ty add r ik to thunan health a n tn te ^environment associated with e x p q sp r e io 0 8 releases fronrDuPont activities\T h e (TT established thehum an health protective C-8 screenmgNsriteria for watenjC-8 water SL) o f 150 ug/L, the C-8 screening crnmia o f 240 m g/kg f^ rsoils (C-8 s o il\L ; WVD&P, 2002), and the A^uc L ife Advisor^Concentration foC C ^ (C-8 ALAC) o f 1,360 ug*L (M enzie-Cura & A ssociates, 2002). The Consent Order atoe established the C-8 Groundwater Investigation Steering Team (GIST), which consisted o f scientists from W VDEP, W VDHHR-BPH, USEPA Region III and DuPont, to oversee investigations and activities conducted under the Consent Order. These tasks included Task A: Groundwater U se and W ell Survey/Groundwater Monitoring, Task B: Assessm ent o f Existing Groundwater and Surface Water Monitoring Data, and Task C: Plume Identification/Groundwater Assessm ent at each site. Upon DuPont's com pletion o f Tasks A, B, and C, and comparison o f the results to-tho CArFFaotabliphed ocreening oriteria, DuPont issued the C-8 Data Summary Report (DuPont, 2003) to the GIST. The GIST then prepared its Final C-8 GIST Report (GIST, 2003) with findings and conclusions regarding groundwater quality and the extent o f groundwater impacts. These documents are in the EPA Docket as O PPT-2003-00120039 and Q PPT -2003-0012-0204, respectively. EXP000392 "''Ks*' 1Note: In the Consent Order, C-8 means ammonium perfluorooctanoate (CAS Number 3825-26-1). 20 04W orkP lan 4.do c W ilmington, DE 3 Draft Document Do Not Cite or Quote, March 30, 2004 Draft Phase II Monitoring/Sampling W ork Plan Background Information The Final C-8 GIST Report (GIST, 2003) also presented recommendations regarding the need to conduct further work. In addition to the recommendations made by the GIST, the OEPA, w hich was a non-voting member o f the GIST, also made recommendations that additional work be conducted in the state o f Ohio, across the Ohio R iver from the W ashington W orks facility in W est V irginia. Around this sam e tim e, USEPA began its exposure assessm ent investigation o f C-8. DuPont and other members o f the Fluoropolym er Manufacturers Group (FMG) shared available data on PFOA in the environment w ith USEPA. D iscussions occurred amongst U SEPA and industry concerning the need for and type o f data that would be useful and relevant to assess sources and pathways o f exposure to PFOA. In this W ork Plan, DuPont presents the details o f the sampling, monitoring, and m odeling activities it intends to conduct during Phase II, as based on discussions with one or more o f USEPA, GIST and OEPA. D etails o f the specific procedures and practices that w ill be follow ed to ensure that the Phase II data generated are technically sound, usable and properly docum ented can be found in the QAPP located in the attached Appendix A. 2004WorkPlan4.doc Wilmington. DE EXP000393 4 Draft Document Do Not Cite or Quote, March 30, 2004 Draft Phase II Monitoring/Sampling W ork Plan A ir Modeling Verification Study 3.0 AIR MODELING VERIFICATION STUDY DuPont is conducting a two-phased verification study to compare results from air dispersion m odeling to ambient air sampling data. The purpose o f this study is to understand how m odeling predictions relate to measured ambient air concentrations o f PFOA. To evaluate this objective, actual ambient air m odeling w ill be performed in tw o phases. Phase I activity has been initiated and includes perimeter m onitoring at six locations at the W ashington Works fenceline. The details for this activity w ill be set forth in EPA public docket document number O PPT-2003-0012. Phase II o f the verification study activity is described in this W ork Plan. 3.1 Phase II Air Monitoring Activity 3.1.1 Air Sampling Events, Duration and Locations The Phase II air monitoring program w ill consist o f seven sampling events conducted over a period o f six w eeks. During each sam pling event, one sample w ill be collected over a 24-hour period at each location. One sam pling event w ill occur every six days during the six-w eek period. The sample network w ill consist o f nine locations, seven in Ohio and two in W est Virginia. These locations are shown in Figure 1 and listed in Table 1. Sample locations were selected based on the follow ing rationale: To be representative o f the com plete range o f wind directions (North, South, East, and W est). O To provide sufficient spatial coverage up to 2 kilom eters from the site. Because a physical terrain barrier (ridge) exists approxim ately 2 kilom eters to the north o f the site, m eteorological conditions outside that radius would differ from those measured by the site m eteorological station. These data points would not be consistent w ith th rest o f the data set, creating conditions that are not optimal for conducting a verification analysis. To evaluate potential concentration gradients along prevailing wind directions to the northeast and east to w est (see Figure 2A for the wind rose). To coincide w ith co-located soil and grass sam ples, in order to gain a better conceptual understanding o f important environmental compartments. 3.1.2 Number of Samples A total o f 77 sam ples w ill be analyzed over the duration o f the program. The samples w ill include the follow ing: One field blank per sampling event O One sam ple from each o f the nine sam pling locations per ever* EXP000394 2004W orkPIan4.doc Wilmington. DE 5 Draft Document Do Not Cite or Quote, March 30, 2004 Draft Phase II Monitoring/Sampling W ork Plan A ir Modeling Verification Study One duplicate (co-located) sam ple for each event, place at a location where concentrations are expected to be highest A total o f 11 sam ples per event x 7 events = 77 samples 3.1.3 Sampling Equipment, Methods and Schedule Sampling w ill be conducted using a sorbent method for collection and analysis. In general, this method involves drawing ambient air through a medium and adsorbing the analyte o f concern onto that m edium. The collected species are preserved and shipped to a laboratory for analysis. The laboratory desorbs the analyte from the medium and proceeds w ith analysis. For collection and analysis o f PFOA, the Occupational Safety and Health Administration (OSHA) V ersatile Sampling (O VS) tube w ith a 0.3 micron filter w ill be used (catalogue # 226-58 from SKC, Inc., Eighty Four, Pennsylvania, or equivalent). This tube is uniquely designed to sim ultaneously capture aerosols and vapors (see Figure 1.5). Details describing the tube design are included in Appendix A. Pumps w ill be required at each sam pling location to provide airflow through sample tubes. Sample pum ps, such as the Universal PCXR4, capable o f 500 mL to 1,500 mT./minute flowrate w ill be specified. The samplers w ill be set to run at approximately 1 liter per minute for a total volum e o f 1.44 cubic meters over the 24-hour sampling period. Sampling equipment w ill be mounted on poles and covered as needed to provide protection from weather and other potential damage. If these locations do not have AC power, battery operated pumps w ill be used. D uplicate pumps w ill be provided at each location to m inim ize potential pow er failure issues. Field personnel w ill be trained by professional industrial hygienists fam iliar with OVS equipment. Field logs w ill be provided to record pertinent information during sampling events. Sampling is expected to begin in the second quarter o f 2004 (2Q 2004), provided property owners grant perm ission for sampling. If a property owner declines perm ission, an alternative air sam pling location w ill be proposed by DuPont. . 3.1.4 Analytical Methods Ambient air sam ples w ill be analyzed by Exygen Research o f State C ollege, Pennsylvania. E xygen w ill use analytical m ethodology that has undergone third-party validation and has been submitted to the public docket under O PPT-2003-0012-0317 through 0318. The m ethodology uses a methanol extraction with liquid chromatograph/mass spectrometer (LC/M S) system to detect PFOA. Method detection limits are approximated at 0.1 ug/m 3. Contents o f sam ple tubes w ill be analyzed separately for vapor and particles greater than 0.3 microns, then com posited for a total concentration at each sampling location. Additional details o f the analytical m ethodology can be found in the QAPP (see Appendix B). 2004WorkPlan4.doc Wilmington, DE EXP000395 6 Draft Document Do Not Cite or Quote, March 30, 2004 Draft Phase 11 Monitoring/Sampllng Worte Plan Air Modeling Verification Study 3.1.5 Meteorological Monitoring 1 M eteorological measurements w ill be taken during each event using an on-site m eteorological station. The use o f an on-site m eteorological station ensures the data are representative o f conditions at the perimeter o f the site. Data collected during each 24-hour sampling event w ill include the follow ing: Hourly average wind speed Hourly average wind direction Hourly average ambient air temperature Calculation o f stability class . Phase II Air M odeling A ctivity Em ission Inventory Source Characterization The follow ing information w ill be collected and used as input into air dispersion m odeling: Stack locations Stack heights Stack diameters Stack gas exit temperatures Stack gas flow rates or exit velocities . E m ission rates Methods for Estimating Emissions Site-specific operational data w ill be used to relate production data to em issions levels using a factor. Through a com bination o f actual stack monitoring (for vents with highest em issions) and m ass balance estim ates (for vents w ith very small em issions), a factor has been established for each PFOA em ission point to estim ate the quantity o f em issions released at a given production rate. This factor w ill be com bined w ith production data to calculate PFOA em issions during each 24-hour sam pling event. 3.1.6 Meteorological Data O n-site m eteorological data w ill be collected during each sampling event, as described in Section 3.1.5. Concurrent tw ice-daily upper air observations w ill be collected from the upper air station located in W ilmington, Ohio in order to compute hourly m ixing depth. Both sets o f data w ill be com bined and preprocessed by Trinity consultants o f D allas, Texas, to be used as input to the air dispersion m odel. M issing data and measured wind speeds o f less than l.O m /s w ill be treated consistent w ith the recommendations in USEPA's Meteorological Monitoring Guidancefor Regulatory Model Applications. An anemometer height o f approximately 9.14 meters w ill be used for m odeling analysis. , EXP000396 2004W orkPlan4.doc Wilmington, DE Draft Document Do Not Cite or Quote, March 30, 2004 Draft Phase II Monitoring/Sampling W ork Plan Air Modeling Verification Study 3.1.7 Model Selection and Methodology - The Industrial Source Complex Short Term M odel (ISCST3), version 02035 w ill be used to conduct air dispersion m odeling. A ll modeling w ill be performed in accordance with the procedures in USEPA's Guideline on Air Quality Models (40 CFR Part 51, Appendix W ). A ll m odel options w ill be set to the USEPA default version o f ISCST3. PFOA em ission sources w ill be evaluated for downwash effects from surrounding buildings. USEPA's Building Profile and Input Program (BPIP) w ill be used to provide wind direction specific building parameters. A ll buildings on site w ill be evaluated to determine i f these buildings could potentially impact the stack by causing building downwash effects. The area surrounding W ashington Works is primarily non-urban. The USEPA procedures classify land use within 3 kilometers o f the site by the Auer method. Previous review o f the U .S. G eological Survey (USGS) m aps, aerial photographs, and site visits indicate the area is w ell over 50% non-urban. The W ashington W orks facility is located within the Ohio River Valley, and is surrounded by significant terrain features on both sides o f the river valley. As a result, terrain elevations w ill be considered in the m odeling analysis. An averaging tim e o f 24 hours w ill be used to simulate the duration o f field sampling. 3.1.8 Receptor Selection Receptors w ill be placed at exact coordinates o f the perimeter sam pling locations shown in Figure 1. A Global Positioning System (GPS) w ill be used to identify UTM coordinates o f each sample location. The aboveground elevation o f intake tubing for each sample location w ill also be measured and input into the ISCST3 m odel. 3.2 Progress Reports and Results Progress o f Phase II sampling w ill be summarized in semi-annual status reports that w ill be issued by DuPont. Following com pletion o f Phase II air monitoring and m odeling, DuPont w ill submit a report, no later than 30 days after the report is finalized to USEPA, W VDEP, and DEPA providing results o f the verification study (Phases I and II). 2004W orkPlan4.doc W ilmington, DE EXP000397 8 Draft Document Do Not Cite or Quote, March 30, 2004 Draft Phase II Monitoring/Sampling W ork Plan W ater Monitoring Activities 4.0 WATER MONITORING ACTIVITIES In the Final C-8 GIST Report (GIST, 2003), conclusions were presented and recommendation were made related to the three tasks performed by DuPont and evaluated by the GIST (Tasks A , B , and C). Task A required DuPont to conduct a distance-phased public water supply service survey along the O hio River on both the W est Virginia and Ohio sides o f the river. Subsequent to the Task A requirement, a one-m ile (and possibly a tw o- and three-m ile) radial distance o f the W ashington Works facility and Local, Letart and Dry Run Landfills was also surveyed. This phased approach to the water and groundwater use survey and sampling w as intended to allow the GIST to focus efforts along potential C-8 impacted transport pathways and eventually cease activities in directions where impacts were not present or where there were low concentrations. 4.1 Private Water Sources 4.1.1 West Virginia: GIST Conclusions and Recommendations for West Virginia Private Water Supply Sources Follow ing com pletion o f Task A , GIST concluded the following: Initial sam pling within a one-m ile radius o f the Washington Works facility and each o f the three landfills resulted in varying levels o f C-8 being found in private water sources. Private water sources w ithin a one- to tw o-m ile radius were sampled around the W ashington W orks facility and the Local Landfill based on C-8 concentrations detected in groundwater greater than 1.0 ug/L in the one-m ile radius. N o further private water source sam pling beyond the tw o-m ile radius is necessary based on the low er concentrations detected in the one- and two-m ile radius sampling area. No private water sources in W est Virginia were found to exceed the C-8 drinking water screening level o f 150 ug/L . The highest concentration detected was 10.4 ug/L. Based on these conclusions, lim ited private water source resampling in W est Virginia was recommended by the GIST for the purpose o f evaluating the current trend o f C-8 concentrations w ith respect to those sources. For private water sources around the W ashington W orks facility/L ocal Landfill, the Dry Run Landfill, and the Letart Landfill, water-sam pling categories were defined, the number o f samples from each category was identified, and the sam pling frequency w as specified (GIST, 2003) as indicated in the follow ing table. 20 04W orkP lan 4.do c Wilmington. DE EXP000398 9 Draft Document Do Not Cite or Quote, March 30, 2004 Draft Phase I! Monitoring/Sampling Worfc Plan W ater Monitoring Activities Washington Works/Local Landfill (Total of 10 locations) Dry Run Landfill (Total of 10 Locations) Letart (2 Locations) Drinking water springs with detected levels of PFOA Non-drinking water wells with detected levels of PFOA ______ Springs and cisterns with detected levels of PFOA One well and spring used for cattle where prior sampling has detected PFOA concentrations above 5 ug/L________________ Drinking water wells with detectable levels of PFOA ______ Drinking water springs with detectable levels of PFOA _______ Springs and cisterns with detectable levels of PFOA ____ GERLACHIBA BRINKERA 3 ~2 Quarterly for one year Quarterly for one year Quarterly for one year Quarterly for one year Quarterly for one year Quarterly for one year Quarterly for one year Annually for one year 4.1.2 West Virginia: Private W ater Supply Sources Activities DuPont intends to resample ten private water sources around the W ashington Works facility/L ocal Landfill and ten private water sources around the Dry Run Landfill on a quarterly basis for one year for the purpose o f evaluating the C-8 concentration trend for those sources. Sam pling is anticipated to start in 2Q 04. This start date w ill be dependent upon obtaining property owner perm ission to resam ple. If a property owner declines to have the private water source resampled, then an alternative sam pling location w ill be proposed by DuPont. Private water sam pling locations for the W ashington Works facility/Local Landfill and the Dry Run Landfill were selected based on the follow ing: Specific water sampling categories defined by the GIST and the number o f sam ples required for each category based on GIST recommendations (see Table 2) _________________ _ EXP000399 2004W orkPlan4 .doc Wilmington, DE Draft Document Do Not Cite or Quote, March 30, 2004 Draft Phase II Monitoring/Samplirtg W ork Plan W ater Monitoring Activities Potential access to the sam pling locations The ability to cluster private water sam pling locations with locations also selected for air m onitoring and/or sam pling o f soil and biota to m inim ize the total number o f access points (Air monitoring and soil/biota sam pling activities and locations are discussed in Sections 3.0 and 5.0, respectively.) Private water sources selected for sam pling at the W ashington W orks facility/L ocal Landfill and the Dry Run Landfill are shown in Figures 1 and 2, respectively. Each private water sam pling location shown in Figures 1 and 2 is also listed in Table 2 according to the water-sam pling category. Table 1 also summarizes additional data for each private water source to be sampled. In addition, at the Letart Landfill, DuPont intends to sam ple the tw o private water sources recommended by the GIST (i.e., the Gerlach and Brinker residences), annually for one year. Figure 3 shows the locations o f the Gerlach and Brinker residences. Sampling w ill be conducted in 2Q 04 provided perm ission to sam ple is granted. The sampling m ethodology used for acquiring these sam ples is dependant upon water source and sam pling point (e.g., spring, w ell, cistern, tap). The analytical method that w ill be used is a validated LC/MS/MS aqueous m ethod developed by Exygen Research o f State C ollege, Pennsylvania. The method has a PQL o f 0.05 ug/L. D etails describing the private water sam pling methods and the analytical m ethodology are provided in the QAPP (see Appendix A ). The progress o f the Phase II private water sam pling in W est V irginia w ill be summarized in the sem i-annual status reports that w ill be issued b y DuPont. The results o f the W est Virginia private water supply sam pling w ill be included in final report submitted to USEPA, W VDEP, and GIST no later than 30 days after the report is finalized. 4.1.3 Ohio: GIST Conclusions and Recommendations for Ohio Private Water Supply Sources Following com pletion o f Task A , GIST concluded the follow ing: Initial sam pling within a one-m ile radius o f the W ashington Works facility resulted in varying levels o f C-8 being found in approxim ately 94% o f the water sources sampled. Private water sources w ithin a one- and tw o-m ile radius from the W ashington W orks facility were sampled based on the levels o f C-8 detected at the outer lim its o f the one-m ile radius. N o private water sources in Ohio were found to exceed the drinking water screening lev el o f 150 ug/L. The highest concentration detected was 23.6 ug/L. Based on these conclusions, lim ited private water source resampling in Ohio was also recommended by the GIST for the purpose o f evaluating the current trend o f C-8 concentrations w ith respect to those sources. For private water sources in Ohio, water- sampling categories were defined, the number o f sam ples from each category was identified, and the sampling frequency w as specified by the GIST (GIST, 20031 as shown the follow ing table. ___ EXP000400 2004WorkPlan4 .doc Wilmington, DE Draft Document Do Not Cite or Quote, March 30, 2004 Draft Phase il Monitoring/Sampling W ork Plan W ater Monitoring Activities Ohio (Total of 11 Locations) Drinking water wells with detectable levels of PFOA Drinking water springs with detectable levels of PFOA Non-drinking water wells with detectable levels of PFOA Springs and cisterns with detected levels of PFOA 5 Quarterly for one year 1 Quarterly for one year 1 Quarterly for one year 4 . Quarterly for one year 4.1.4 Ohio: Private W ater Supply Sources Activities DuPont intends to resample eleven private water sources in Ohio on a quarterly basis for one year, starting in 2Q 04, for the purpose o f evaluating the C-8 concentration trend for those sources. Sam pling is anticipated to start in 2Q 04. This start date w ill be dependent upon obtaining property owner perm ission to sample. I f a property owner declines to have the private water source resampled, then an alternative sampling location w ill be proposed by DuPont. The ten private water source sam pling locations in Ohio were selected based on the same criteria given for private water sources in W est Virginia. In February 2004, USEPA and OEPA requested that one additional private water source be included in the proposed sampling program. This location has been added to the program. The eleven private water sources selected for sam pling are shown in Figure 1. Each private water sam pling location shown in Figure 1 is also listed in Table 2 according to the water-sampling category. Table 1 also summarizes additional data for each private water source to be sampled. The sampling m ethodology used for acquiring these sam ples is dependant upon water source and sam pling point (e.g., spring, w ell, cistern, tap). The analytical method that w ill be used is a validated LC/MS/MS aqueous method developed by Exygen Research o f State C ollege, Pennsylvania. The method has a PQL o f 0.05 ug/L. D etails describing the private water sam pling and the analytical m ethodology are provided in the QAPP (see Appendix A ). The progress o f the Phase II private water sampling in Ohio w ill be summarized in the semi-annual status reports that w ill be issued by DuPont. The results o f the Ohio private 2004WorkPlan4.doc Wilmington, DE EXP000401 __1_2 Draft Document Do Not Cite or Quote. March 30, 2004 Draft Phase II Monitoring/Sampling W ork Plan W ater Monitoring Activities water supply sam pling w ill be included in final report submitted to USEPA, WVDEP, OEPA, and GIST no later than 30 days after the report is finalized. 4.2 Public Water Sources 4.2.1 West Virginia: GIST Conclusions and Recommendations for West Virginia Public Water Supply Sources The GIST concluded the follow ing for W est Virginia public water supply sources: N o public water supply production w ells in W est Virgmia were found to exceed the drinking water screening level o f 150 ug/L. The highest concentration detected w as 1.87 ug/L. The widespread distribution and low concentrations o f C-8 indicate that the primary migration pathways to public water supplies are air em issions from the W ashington Works facility and pum ping-induced infiltration from the Ohio River, which receives C-8 from the NPDES outfalls and the W ashington Works facility and the Letart landfill. Based on these conclusions, GIST recommended continued quarterly sampling at the Lubeck Public Service District (PSD ), the DuPont W ashington W orks facility, and the General Electric public water system for tw o years. Annual sampling o f the Blennerhassett Island State Park, M ason County PSD, and the Racine Lock and Dam Public Water System (PW S) for tw o years was also recommended. Continued sampling was recommended for the purpose o f evaluating the C-8 concentration trend for those' sources. Follow ing these m onitoring periods, the GIST recommended re-evaluation o f the monitoring. For each o f these public water sources, the GIST identified specific production w ells and finished water sampling points to be monitored. In addition, the GIST recommended DuPont conduct a lim ited field investigation o f C-8 in soil at the Lubeck PSD to determine the extent and concentration o f C-8 in soil at the Lubeck PSD in the vicinity o f their production w ells. DuPont would document the results in a report and submit this report to the GIST. Follow ing data evaluation o f the soil results, the GIST would then determine what additional sampling activities would be necessary, if any, to com plete the investigation. The details o f the investigation to be conducted at the Lubeck PSD are provided in Section 6.0. 4.2.2 West Virginia Public Water Supply Sources Activities DuPont intends to monitor public water sources in W est Virginia, follow ing the recommendations o f the GIST, for the purpose o f evaluating the C-8 concentration trend for those sources. Figure 4 shows the locations o f public water sources in W est Virginia that w ill be monitored for two years. At each monitoring location, the color (pink or blue) and shape (square or circle) o f the label indicates monitoring frequency (annually or quarterly) and individual sampling points (production w ells and finished water sampling points) are listed. Table 1 also summarizes additional data for each public water source to be sampled. Table 3 indicates the duration o f monitoring for each public water source. 2004WorkPlan4.doc Wilmington. DE ____________ EXP000402 ___ 13 Draft Document Do Not Cite or Quote. March 30. 2004 Draft Phase II Monitoring/Sampling W ork Plan W ater Monitoring Activities The sam pling m ethodology used for acquiring these samples is dependant upon sampling point (e.g., spring, w ell, cistern, tap). The analytical method to be used is a validated LC/MS/MS aqueous method developed by Exygen Research o f State C ollege, Pennsylvania. The method has a PQL o f 0.05 ug/L. D etails describing the public water sampling methods and the analytical m ethodology are provided in the QAPP (see Appendix A ). The progress o f the Phase II public water sampling in W est Virginia w ill be summarized in the sem i-annual status reports that w ill be issued by DuPont. The results o f the W est Virginia public water supply sam pling w ill be included in final report submitted to USEPA, W VDEP, OEPA, and GIST no later than 30 days after the report is finalized. 4.2.3 Ohio: GIST Conclusions and Recommendations for Ohio Public Water Supply Sources Following the com pletion o f Task A , GIST concluded the follow ing: N o public water supply production w ells in Ohio were found to exceed the drinking water screening level o f 150 ug/L. The highest concentration detected was 8.58 ug/L. O The widespread distribution and low concentrations o f C-8 indicate that the primary migration pathways to public water supplies are air em issions from the W ashington Works facility and pumping-induced infiltration from the Ohio River, which receives C-8 from the NPDES outfalls and the W ashington Works facility and the Letart landfill. The GIST recommended continued quarterly sam pling at the Little H ocking Water A ssociation PWS for tw o years and annual sampling o f the Tuppers Plains PWS for two years for the purpose o f evaluating the C-8 concentration trend for those sources. For these tw o public water sources in Ohio, the GIST listed specific production w ells and finished water sampling points to be monitored. Follow ing these monitoring periods, the GIST recommended re-evaluation o f the monitoring. 4.2.4 Ohio Public Water Supply Sources Activities DuPont intends to monitor the public water sources in Ohio, follow ing the recommendations o f the GIST, for the purpose o f evaluating the C-8 concentration trend for those sources. In Ohio, two public water sources w ill be sampled (the Little Hocking Water A ssociation and the Tuppers Plains-Chester Public Service D istrict) for a period o f two years. Figure 4 shows the locations o f public water sources in Ohio that w ill be monitored. At each monitoring location, the color (pink or blue) or the shape (square or circle) o f the sym bol, which indicates monitoring frequency (annually or quarterly) and , individual sam pling points (production w ells and finished water sam pling points), are also listed. Table 1 also summarizes additional data for each public water source to be sampled. Table 3 indicates the duration o f monitoring for each public water source. The sampling m ethodology used for acquiring these samples is dependent upon sampling point (e.g., spring, w ell, cistern, tap). The analytical method to be used is a validated LC/MS/MS aqueous method developed by Exygen Research o f State C ollege, EXP0004Q3 20 04W orkP lan 4.do c Wilmington, DE Draft Document Do Not Cite or Quote, March 30, 2004 Draft Phase II Monltoring/Sampling W ork Plan W ater Monitoring Activities Pennsylvania. The method has a PQL o f 0.05 ug/L. D etails describing the public water source sam pling m ethods and the analytical m ethodology are provided in the QAPP (see Appendix A ). The progress o f the Phase II public water sampling in Ohio w ill be summarized in the sem i-annual status reports that w ill be issued by DuPont. The results o f the Ohio public water supply sam pling w ill be included in final report submitted to USEPA, W VDEP, OEPA, and GIST no later than 30 days after the report is finalized. 4.2.5 Ohio: OEPA Recommended Well Installation at Little Hocking Water Association Well Field As part o f Task A o f the Consent Order, public water supplies along the Ohio River in both Ohio and W est Virginia were sampled. The L ittle Hocking Water A ssociation is one o f the public water supplies located in Ohio that was sampled. It is located im m ediately across the Ohio River from the DuPont W ashington W orks facility. Groundwater results for test w ell, TW -4, which was installed to evaluate groundwater quality and is not used as drinking water, showed unusually high C-8 concentration compared w ith other concentration measured at this public water supply. Based on the elevated results at TW -4 compared to the surrounding w ells, the OEPA requested that DuPont conduct a focused field investigation to delineate C-8 concentrations in soil and groundwater near TW -4. . In August 2002, DuPont conducted the field investigation at the Little H ocking Water A ssociation w ell field. During this investigation, ten temporary soil borings were drilled and geologic inform ation was continuously monitored. Soil and groundwater were sampled and groundwater parameters were monitored at various depths within the ten temporary borings. In addition, groundwater in all production and test w ells was sampled, and recorded groundwater elevations were recorded. Ohio River stage was also m onitored. There were three primary conclusions from this investigation, which are as follow: O First, consistently high pH values measured in TW -4 and other field observations indicate that this test w ell's construction is likely compromised, possibly due to a failed grout seal or to a failed w ell casing. Secondly, based on the current data available, DuPont believes the follow ing C-8 m igration pathway exists: C-8 from the DuPont facility is transported via air em issions by wind and is deposited on the Little Hocking w ell field surface soils. Precipitation then leaches the C-8 downward through the unsaturated zone to the aquifer. D issolved C-8 then migrates with groundwater within the aq u ifer.. Groundwater containing low levels o f C-8 is then pumped from the aquifer through the four production w ells. Water from the production w ells is mixed and the finished water, containing even lower levels o f C-8, then enters the Little H ocking Water A ssociation distribution system . . Third, the C-8 results for finished water, a combination o f waters from the production w ells that is distributed to Little Hocking customers, ranged from 1.69 to 4.29 ug/L, significantly low er than the water C-8 SL o f 150 ug/L. EXP000404 2004WprkPlan4.doc Wilmington, DE is Draft Document Do Not Cite or Quote, March 30, 2004 Draft Phase II Monttoring/Sampling W otk Plan W ater Monitoring Activities These conclusions and other findings o f this investigation were documented in a report to the GIST (DuPont, 2003). A s indicated in the Final C-8 GIST Report (GIST, 2003), OEPA and DuPont together would determine what additional activities are necessary to com plete the Little H ocking field investigation to the satisfaction o f the GIST and OEPA. After review ing the Little Hocking Sampling Investigation Report, the OEPA recommended revisions to the report and requested additional investigation. The revisions have been made to the report and the Revised Little Hocking Sampling Investigation Report w as submitted to the GIST in February 2004. During Phase II, DuPont intends to install the four shallow w ells at the Little Hocking Water A ssociation w ell field as recommended by OEPA. One o f the shallow w ells w ill be installed north o f production w ells #5, if possible, as requested by the OEPA. The other three shallow w ells w ill be clustered w ith existing test w ells TW -1, TW -6, and TW -12. Proposed shallow w ell locations are shown in Figure 5. During w ell installation, surface soil/biota and subsurface soil w ill b e sampled. D etails o f the shallow w ell installation and the surface and subsurface so il sam pling are provided in the QAPP (see Appendix A ). Installation o f the w ells is anticipated to begin 2Q 04 and if dependent upon the property owner granting perm ission for such installation. In the event perm ission is not granted, DuPont w ill consult w ith OEPA. Follow ing installation and developm ent o f the four new shallow w ells at Little H ocking, these w ells, along with the deeper clustered w ells (Figure 5), w ill be included in the quarterly groundwater sampling program for Little H ocking. The progress o f the Phase II shallow w ell installation at the LHW A w ell field and the sam pling o f these clustered test w ells w ill be summarized in the sem i-annual status reports that w ill b e issued by DuPont. The results o f the shallow w ell installation and the test w ell monitoring w ill be included in final report that is due to USEPA no later than 30 days after the report is finalized. 2004WorkPlan4.doc Wilmington, DE EXP000405 16 Draft Document Do Not Cite or Quote, March 30, 2004 Draft Phase II Monitoring/Sampllng W ork Plan______________S u r f a c e W a t e r a n d G r o u n d w a t e r M o n it o r in g 5.0 SURFACE WATER AND GROUNDWATER MONITORING Task B o f the C onsent Order (A ssessm ent o f Existing Groundwater and Surface Water Monitoring Data) required the developm ent and im plem entation o f a monitoring plan that would determine the extent and presence o f C-8 in drinking water, groundwater, and surface water at the W ashington W orks facility and the three landfills. In addition, this task required DuPont to com pile all the available groundwater and surface water monitoring data and hydrogeological data for each site. For the W ashington W orks facility and the three landfills, the GIST recommended that surface water and groundwater monitoring continue at selected sam pling points. Surface-water and groundwater monitoring activities w ill be continued under the requirements o f the W V/NPDES permits W V 0001279, W V 0076538, W V 0076066 and W V0076244 for the W ashington Works facility and the Local, Letart and Dry Run Tanrifills, respectively. Because surface-water and groundwater m onitoring is being conducted in accordance with the W V/NPDES perm its, this monitoring is not part o f Phase II and is not discussed further in this document. Additional details o f this monitoring can b e found in the perm its. The results o f monitoring conducted pursuant to permits w ill be submitted to USEPA as part o f the sem i-annual reports set forth in the LDI. - 2004WorkPlan4.doc Wilmington, DE EXP000406 - : 77 Draft Document Do Not Cite or Quote, March 30, 2004 Draft Phase II Monitoring/SamplingWork Plan______ _____ SurfaCB SoU/Biota (Vegetation) Sampling 6.0 SURFACE SOIL/BIOTA (VEGETATION) SAMPLING IN WEST VIRGINIA AND OHIO OEPA recommended establishing at least eight locations to collect surface soils for analysis o f C -8. Sam pling locations were to be selected based on available C-8 data from air m odeling, groundwater m odeling and sampling activities. OEPA recommended that som e o f the eight sam ples be collected from residential areas near the Little Hocking w ell field and in areas where different so il types would be expected. GIST recommended DuPont conduct a lim ited field investigation o f C-8 in soil at the Lubeck PSD to determine the extent and concentration o f C-8 in soil at the Lubeck PSD in the vicinity o f their production w ells. Based on the recomm endations from OEPA and GIST, and on additional data needs identified by USEPA, DuPont plans to conduct a soil and biota (vegetation) sampling program at the follow ing locations in W est Virginia and Ohio for the purpose o f determining if C-8 is present: On the surface o f vegetation O W ithin the vegetation matrix (i.e., it is being uptake onto plant structure) W ithin the topm ost, highly organic soil underlying the vegetative layer For the field investigation o f surface soil/biota, DuPont has selected eleven locations in Ohio and ten locations in W est Virginia (see Figure 1 and Table 1). Sampling locations were selected to be consistent w ith locations selected for air and private water sampling locations. In O hio, four surface soil/biota sam ple locations were selected, adjacent to where the four new shallow w ells w ill be installed at the Little Hocking Water Association w ell field. Seven private residences in Ohio were also selected for surface soil/biota sam pling. In W est Virginia, seven private residences were selected for surface soil/biota sam pling. In addition, three surface soil/biota sample locations w ill be selected at the Lubeck Public Service D istrict w ell field. The exact position o f these three sampling locations w ill be determined follow ing a site visit by DuPont (or its authorized representative). I f a property owner declines soil/biota sampling, DuPont w ill propose an alternative surface soil/biota sam pling location. After perm ission has been granted to collect the soil/biota samples for the private residences and the public water suppliers, exact sampling locations w ill be identified and surveyed using a global positioning system and the location marked w ith flagging or equivalent. For the surface soil/biota sam pling in Ohio and W est Virginia, DuPont proposes conducting two synoptic sam pling events in the late spring 2004 (providing access is granted), one follow ing a "wet" period and one following a "dry" period. ("W et" and ' "dry" periods are defined in Appendix A .) The objective o f sampling follow ing a wet and " dry" period is to evaluate if precipitation has an effect on the concentration o f PFOA measured. M eteorological data w ill be monitored prior to and during the "wet' and " dry" sam pling events. At each sampling location, two samples will be collected immediately adjacent to each other during each sampling event. Each sample will consist of a 6-inch depth core of 20 04W orkP lan 4.do c Wilmington, DE 18 Draft Document Do Not Cite or Quote, March 30, 2004 EXP0004 Draft Phase II Moriitoring/Sampling W ork Plan Surface Soil/B iota (Vegetation) Sampling vegetation and soil. The two sam ples w ill be collected adjacent to each other. The first sample w ill be submitted for analysis and the second sam ple, w hich w ill be a larger diameter sam ple, w ill be used to determine the soil classification (ASTM D 2487) at the location. Sample collection m ethodology is presented in Section 2.2.10 o f the QAPP (see Appendix A ). The first sample w ill be divided in the field into two portions, the organic-rich portion (vegetation and litter layer) and the mineral matter-rich portion (root, root zone and the material below the root zone). The objective o f dividing the sample into a biota (organicrich) portion and soil (mineral matter-rich) portion is to evaluate if the PFOA is detectable in both portions and to compare the PFOA concentrations betw een the organic-rich portion and the m ineral matter-rich portion. In addition, for the samples collected during the "dry" event, the organic-rich portion w ill be washed w ith deionized water, prior to processing the so il sam ples for analysis, to differentiate between adsorbed (sticking) or "external" PFOA rem oved by the deionized wash water and PFOA incorporated within the organic material itself. The washed organic-rich portion and the wash water w ill be analyzed for PFOA. The mineral-rich portion o f four samples (OHS/B -3, O H -S/B-4, O H -S/B-7 and W W -S/B-10) collected during the "dry" event w ill also be washed for com parison. For these four sample, the washed mineral-matter-rich portion and the wash water w ill be analyzed for PFOA. N ote that DuPont is not currently aware o f a validated analytical method for determining PFOA concentrations in organic matter. Method developm ent for surface soil/biota (organic matter-rich portions and mineral-matter rich portions) analysis has been initiated at Morse Laboratories (M orse), Sacramento, California. I f M orse is unable to provide analysis for surface soil/biota sam ple extracts, then STL w ill provide analysis o f these extracts. Biota sam pling w ill be conducted during the synoptic "wet" and "dry" events although analysis o f the organic rich sam ples w ill not take place until successful com pletion o f method validation. Sam ple handling and storage prior to analysis w ill follow the protocol outlined in the QAPP. D etails o f the sampling and analytical methodology are provided in the QAPP (see Appendix A ). The second, larger diameter sam ple w ill be used for soil classification according to ASTM D2487. Soil classification w ill be based on the results o f grain size determination and Atterburg Lim its, and may include results o f specific gravity, organic content and moisture content. The progress o f the Phase II synoptic surface soil/biota sampling at private residences and at public water suppliers O hio and W est Virginia w ill be summarized in the sem i annual status reports that w ill be issued by DuPont. The results o f the two synoptic surface soil/biota sam pling events w ill be included in final report submitted to USEPA, OEPA, and W VDEP no later than 30 days after the report is finalized. 2004WorkPian4.doc Wilmington, DE EXP000408 19 Draft Document Do Not Cite or Quote, March 30, 2004 Draft Phase II Monitoring/Sampling W ork Plan Schedule and Reporting 7.0 SCHEDULE AND REPORTING The schedule for com pleting the Phase II work required by the MOU is shown in Figure 6. The schedule begins with USEPA and DuPont signing the MOU and concludes with submitting the Phase II report for all sampled media (except air). Subsequent tasks required by the M OU (i.e., conducting assessm ents, performing the peer consultation, and implementing post-peer consultation commitments, etc.) w ill be addressed in updated schedules that w ill be included in the status reports generated for this assessm ent. Phase II sam pling w ill begin after perm ission has been granted from the off-site property owners. Throughout this assessm ent, reports w ill be generated to update status and provide data generated during this investigation. Status updates w ill b e submitted to USEPA sem i-annually. A final air report w ill be submitted after the air verification study is conducted and data reduction and m odeling is com plete. A Phase II report w ill be submitted (for all m edia except air) after Phase II is com plete and after data are reduced and analyzed. B ased on the current schedule, the Phase II report is expected to be submitted in N ovem ber 2006. A ll final reports w ill be submitted to USEPA w ithin 30 days o f becom ing final (in accordance w ith the terms o f the MOU). 2004WorkPlan4.doc Wilmington, DE EXP000409 20 Draft Document Do Not Cite or Quote, March 30, 2004 Draft Phase II Monitoring/Sampling W ork Plan 8.0 REFERENCES To be com pleted in the final report References 20 04W orkP lan4.doc Wilmington, DE EXP000410 : - 21 Draft Document Do Not Cite or Quote, March 30, 2004 EXP000411 TABLES EXP000412 Table 1. Summary Data for Proposed Sampling Locations In and Around DuPont W ashington Works Site DuPont Washington Works Site Washington, W est Virginia 1 .1 V" Soil Biota ^Sampling OH-S/B-3,4,5,6 OH-A-3 3,4,_________ Finished_________ LHPSD1.2, 3, Production Wells and 5, EPOOl Finished Water 3/30/2004 1 of 3 Tab 1 workplan2004.xls EXP000413 Table 1. Summary Data for Proposed Sampling Locations In and Around DuPont Washington Works Site DuPont Washington Works Site Washington, W est Virginia EXP000414 3/30/2004 2 of 3 Tab 1 workplan2004.xls T a b la i. Summary Data for Proposed Sampling Locations In and Around DuPont Washington Works Site DuPont Washington Works Site Washington, W est Virginia ijgDuP.ont ProposedSampling Soil/Biota ' - DuPont Proposiad Soil/Biota 1 , i Air DR-P-2 DR-P-3 DR-P-1 DR-P-6 DR-P-8 DR-P-9 DR-P-10 DR-P-4 DR-P-5 DR-P-7 t-P-1 L-P-2 Well (1) Wells (2nd of 2) Well (1) Well (1) Cistern (1) Well (1) Spring (1) Spring Cistern (1) Drinking Water Used Drinking Water Used Drinking Water Used Drinking Water Drinking Water Used Used Drinking Water Drinking Water Used Used Unused Non-drinking Water Used fPi Drinking Water Used Unused WWK-D-AbbottRL All purposes (excluding drinking - but used to make ice for drinks) WWK-D-AbbottS All purposes_______________________________ WWK-D-AtklnsonJ2 Drinking only WWK-D-BakerH All purposes WWK-D-NicholsonDH All purposes WWK-D-NickelsonDH2 Used if well is running low WWK-D-ParkerJL WWK-D-SeebaughR WWK-G-TennantJD WWK-G-DowlerE1 All purposes All uses - household, drinking, etc. Used for washing vehicles, watering aarden/flowers, etc... f Vtr> M WWK-D-Bi1nkerA 1 All purposes I EXP000415 3/30/2004 3 Of 3 Tab 1 workplan2004.xls Table 2 Summary of GIST Recommended Private Water Source Smpllng Category In and Around DuPont Washington Works Site and DuPont Proposed Sampling Locations DuPont Washington Works Site Washington, West Virginia Washington Works/Local Landfill (Total of 10 locations) Drinking water wells with detected Drinking water springs with detected Non-drinking water wells with HAtpriftri IavaIs nf C-8 Springs and cisterns with detected One well and spring used for cattle where prior sampling has detected C- ft r.nnr.Rntrations above 5 uq/L_____ Dry Run Landfill (Total of 10 Drinking water wells with detectable Locations) iAVftlfi n f L -8 ----------------------------- --------- Drinking water springs with riRtfictahle levels of C-8 Springs and cisterns with detectable levels of C-8 Letart (2 Locations) RPRI ACHIBA BRINKERA Ohio (Total of 11 Locations Drinking water wells with detectable Drinking water springs with Non-drinking water wells with rlfitectahlfl levels of C-8 Springs and cisterns with detected levels of C-8 3 YVVV-r-l, VVVV-r-t, v v y v -r- 1 WW-P-8 Quarterly for one year 1 WW-P-5 Quarterly for one year 3 WW-P-6, WW-P-7, WW-P-9 Quarterly for one year 2 WW-P-2, WW-P-3 Quarterly for one year 6 DR-P-1, DR-P-2, DR-P-3, Quarterly for one year n P -P -fi H R -P-ft DR-PtIQ-- 1 Quarterly for one year DR-P-4 3 Quarterly for one year DR-P-5, DR-P-7. DR-P-9 1 L-P-1 Annually for one year 1 L-P-2 Annually for one year 5 OH-P-1, OH-P-2, OH-P-5, Quarterly for one year OH-P-7. OH-P-11 1 Quarterly for one year OH-P-10 1 Quarterly for one year OH-P-6 4 OH-P-3, OH-P-4, OH-P-8, Quarterly for one year OH-P-9 EXP000416 3/30/2004 Tab 2w orkplan2004.xls Table 3. Summary of GIST Public Water Source Sampling Recommendations DuPont Washington Works Site Washington, West Virginia rg 'T Ohio State <* Tuppers Plains - Chester 1 ^ ^ d d w T, t p p s d d v w l T Annual/2 yrs TPPSDDW3, TPPSDD 4, TPPSDDW5, TPPSDDW6, WV Consent Order/OEPA r.1 ' 1 *, . .x - 1Sjapi vY$: v * T'jr: Little Hocking Association Water j - - West Virgin's Lubeck PDS TPPSDAT LHPSD1, LHPSD2, LHPSD3, Quarterly/2 yrs WV Consent LHPSD5, LHPSDEP001 Order/OEPA LPSD Well A, LPSD Well B, Quarterly/2 yrs WV Consent Order LPSD Well C, LPSD Well D, n* v V-jj^ DuPont Washington Works LPSD Well E, LPSD Weil F, LPSDAT AM07-PW01, AO08-PW01, Quarterly/2 yrs WV Consent Order AX13-PW01, K16-PW01, L04 PW01, V05-PW01 Mason County PSD MASONCPSD1, Annual/2 yrs WV Consent Order -ciy- MASONCPSD2, ' r\ ,' ' v$.- ' ` V IE , V , i t fcl f-`L-^sfataslKi - '.1jTi'-'^i, fiWs' -kl Racine Lock and Dam PSD GE Blennerhassett Island______ MASONCPSD3 RACINELD GE Well 3________________ BLENISEPS1 Annual/9 \/rQ Quarterlv/2 yrs Annual/2 vrs WV Consent Order WV Consent Order WV Consent Order EXP000417 3/ 30/2004 1 of 1 Tab 3workplan2004.xls F IG U R E S EXP000418 FIGURES EXP000419 Figure 1.5 OVS Tube DuPont Washington Works Site Washington, West Virginia Air flow (1 L/min) Hoiclmg Pmg, F lit*' S orb ent Lay*.' -- Polyurethane Flam Sotbent Laye; Polyurethane Pja m End Cap Gass I u b * particulates > vapor > Breakthrough vapor End Cap EXP000421 EXP000422 LEGEND: * NON DRINKING WATER SAMPLE * DRINKING W ATER SAM PLE ^ PROPOSED GROUNDWATER MONITORING LOCATION (S) SPRING SAMPLE (C ) CISTERN SAMPLE 0 2 4 2 0 6 CONCENTRATION (u g fl) MAP TAKEN FROM THE LUBECK. WV USGS QUANDRANGLE SCALE 250 . 0 250' 55s--------- ... A OFFSTE MONITORING LOCATIONS Corporal RomodlaUon Group fra* <4D a HM<r IKtOflinrWtelaan. w. M MIHKV Dry Run Londfn 2000' EXP000423 Corporate Romedatlon Group , in M U m o t Sofa *n D u l*e n i a n d SS m e n d Borioy Ml Plaza, Building 27 WBmlnqtcn. Delaware 19805 WIND ROSE D u P o n t W ashington W orks Plant W ashington, West Virginia [MC1 jan s frw* VaW j **-- | 3A :POOQ424 03-KEARNSMG ND(0.01> OSN-J0U{D0.G01E)T .ND(0.0i) LEGEND: NON DRINKING WATER SAMPLE * DRINKING WATER SAMPLE ^ PROPOSED GROUNDW ATER M ONITORING LOCATION 0.139 0 -8 CONCENTRATION (ug/1) I OHIO LANDFILL AREA LETART PROPERTY PERIMETER " *" **" B ! 4^ Corporata Remediation Group 4f>4Uim* M m * OFFSITE MONITORING LOCATIONS NEAR LETART LANDFILL U tart U n titi W ort. Wert Virginia twWMrhUtStavFWtilMn,an INM27 I i i i I % i I I 9 iggj I El O APPENDICES EXP000427 APPENDIX A EXP000428 APPENDIX A PHASE II QUALITY ASSURANCE PROJECT PLAN WASHINGTON WORKS SITE, WASHINGTON, WEST VIRGINIA EXP000429