Document y29NQdo0322m6pozdxzYZKvr

AR226-2544 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III 941 Chestnut Building Philadelphia, Pennsylvania 19107-4431 INVUiONMiNrAl O ffici ta Reply Refer Tot 3WC23 JAN 1 5 '698 CERTIFIED HAIL RETURN RECEIPT BROtTCfiTm Robert L. Ritchey Senior Environmental Control Consultant S .I . duPont de Nemours & Company Washington Works P.O. Box 1217 Parkersburg, West Virginia 26102-1217 Ret RCRA Facility Investigation work Plan Notice of Deficiency Washington, West Virginia Facility Facility SPA ID #: WVD 045 875 251 Dear Mr. Ritcheyt On September 24, 1997 E.I. duPont de Nemours 6 Company, Inc. submitted the RCRA Facility investigation Plan (r f i ) for their Washington, West Virginia facility. This document was reviewed to determine if the plan fulfilled the conditions of the RCRA corrective Action Permit Number w v d 045 875 291. - The attached report summarizes conclusions reached during the review. DuPont shall modify the RFI Work plan to overcome the deficiencies noted in the review and reply to ERA within forty-five (4S) calendar days of receipt of * this letter. If you have any questions on this matter please contact me at (215) 566 3431. . Attachments cc; C.P. Wokpara, WV DIP Denis M. Zielinski RCRA Operations Branch ASH01991 EID911334 8.1. PUPO* ss HSMOtmS fi COMPASS, m e , WASHINGTON, NB3T VIRGINIA SPA 3ED # SVO 045 875 251 1 RCRA FACILITY INVH5TISASXO noi PLAN SH&SRAL COMMENTS 1. As described on page 2 of the work plan, the first purpose of the RPX is to collect data of sufficient quality and quantity that characterizes the nature and extent of contamination from release sources and to determine the rate of migration into groundwater, soil or other media, if applicable, in order to accomplish this purpose the following investigations should be performed as an input of the groundwater flow modal and the site conceptual model; ^ ^ JP&ot**- prof 5 f A. Monitoring Data Evaluation ri/uAi Ur. 1 < T . B. Slope Stability Investigation i C. Leachate and Perched Water Investigation, and D. Process Lines and Waste stream Lines Investigation 2. E P A has a different interpretation of the groundwater then DuPont. It , i x,lrt . a p p e a r s that the alluvial groundwater flow at the site runs from the iR+ i u <? laadfill side to the Ohio River side as a discharge zone, - \*Aiwde$ nuS1. therefore, a Monitoring Data Evaluation must take place. The clay layer ,nn the Ohio River bank acts as a lining of the river water to form a Jbarriarjbetween the river and the inland side, since the production ` wells ware installed, the groundwater level was locally altered, M , if according to the pumping operations, so the groundwater flow model 1*1(168 should include the local landfill area, the bedrock aquifer (Attachment L ms A) and the perched water thereby considering the site as a whole. It is , " important that the input data is accurate, because the simulation can't Aor h e mere accurate then the data available for the calculations. All ,1. ..,,L Iexisting data should be evaluated before input. For example, the Q,u ^groundwater levels were observed 501.05 and 581.98 respectively in _ ^ R B L M W - 4 and TW-l of the 1991 sampling program. It indicated a piping ifyk Hus phenomenon or cracks which occurred on the clay which seeped the river water into the RBL area, layer of the river and not a recharge bank from/' ^ALL Mf(U the Ohio River. Attachment B gives some suggestions for evaluating the/ '' monitoring data along the river side due to groundwater changes. O {Jpi'f fJo, M o fo 3. -evnlfoie As described on page 12 of the work Plan, some slumping of the clay and silt exists along the River's edge, therefore a slope stabilization investigation must take place. The stability of the river bank slope could be undergoing deformation. If the slope fails, it will not only damage the barrier area, but could also damage the plant. A through investigation including the following is suggested; . . fLa \ A d ^ it * * visual .inspection of the scrap area surface failures and erosion above the river water level should be conducted. The evidence is often hidden by vegetation. Careful investigation should be conducted at the Rannay well and other punning areas because lowering of the groundwater table can lead to land movement. Evaluation of the ultimate dynamic factors, such as extremely heavy precipitation, 100-year frequency flood and sudden drawdowns, to estimate the future risks should be conducted. A leachate and perched water investigation should also be conducted. According to your July 11, 1997 response letter, DuPont has installed, a n d began operating on April 25, 1991, an activated carbon treatment g.r.3" t66\00HSV *AU ^ ^ 4 v m C. EID911335 j W tS W "" ' " , 47 +*a 50tfrC * 2- - Wow4- SiyM^ Wv CtvkuW^iA , n t- flu M v H. ,s. system*to capture the water leaking in the<lurooolvnS?t>rocessing area. Through the second quarter of 1997, approximately 2.S million gallons of seepage have been processed. I--t i--a u-n-c--l-e-a-r--w-h-e-t-h-e-r o--r --not R--B-L-L-i is . still seeping or not, please confirm. The Work Plan should include the measurement of elevation and quantity of RBLL-i, RBLL-2 (Attachments C and D) and other seeps found. Also, the perched contaminated water should be investigated for the extent and source control. . IL, 1 U '5 1 ouftt The Verification investigation laboratory results detected TCB and PCE in the groundwater samples, but not in the soils. (See Attachments B and F) where is the source (s) of the contamination? A n investigation on the process lines and waste stream lines shculd.be .conducted. This investigation must be performed prior to conducting the modeling. The following SPA publications, which are included*, should be Considered in the sampling. BPA/540/4-91/QQX Soil Sampling and Analysis for Volatile Organic Compounds and EPA/S40/S-9S/504 Lew-Flow (Minimal Drawdown) Ground-Water Sampling Procedures. D.<L -Ha<u w e lode v ^ SPECIFIC COMMKHTS Do* * c 8. 9. Section 2.3.3 must include the elevation of the 100-year floodplain for the Washington Works. Sectiojn 33..S5.. 33 must include language thnat states thnat any olidumwonitoring wells deUe?s=-iigrmn=ait-oerdl for closure must have Drier anpoproval from the WV DEP as well aass the O.S. SPA. Qfe ^ \ U I F .ppW&ilf Figure 1 should include the structure line of Lock and Dam Wo. 19 across the Ohio River, and should also include the actual location of the site. Figure 2 should include the seepage collection and treatment unit as well as outfall oos. ' IX . 12. All described locations in the Work Plan, such as Shell Chemicals, Huntsman chemicals, Amoco, Fluropolyaer Manufacturing area, etc. should . 'ftttCA appear on a amp. * , ,F Pm W I * Quarterly progress reports to EPA and the wv DBF must be added-to tbe RFt Implementation Schedule in Appendix A. ^ j^iW. A' i3. Table B-2 ia Appendix S of the Sampling and Analysis Plan references SW- S4 method 6240 for analysis of VQCs. Please note that this method is now obsolete and has been replaced by method 8260. t ^ hCAovJ- The Quality Assurance project Plan (QAPP), Appendix C, proposes _ validation for 10% of the samples. The plan should include a rationale and criteria for how these samples will be selected fttke n 6A$iMf In addition to the procedures listed in Section S.2 of the QAPP in Appendix c, EPA recommends a methanol or reagent grade alcohol rinse for equipment used for collecting organic samples. A dilute nitric rinse should be used for inorganic (metals) sampling equipment. Q k ' V 16. The narrative describing trip blanks in Section 3.7.3 of the Sampling and Analysis Plan, Appendix B. is in error. The language should be consistent with the discussions ia the QAPP, Appendix C. j^Aill. A- oiAitts * ' T W U- " ** Aprvl 1 s U A S H 001993 EID911336