DUPONT
TELOMER
MANUFACTURING
SITES:
ENVIRONMENTAL
ASSESSMENT
OF
PFOA
LEVELS
IN
AIR
AND
WATER
Date:
September
2003
Project
No.:
508501
18983843.00003
CORPORATE
REMEDIATION
GROUP
An
Alliance
between
DuPont
and
URS
Diamond
Barley
Mill
Plaza,
Building
27
Wilmington,
Delaware
19805
DuPont
Telomer
Manufacturing
Sites:
Environmental
Assessment
of
PFOA
Levels
In
Air
and
Water
Table
of
Contents
EnvironmentalAssessment.
doc
Oct.
1,
03
i
Wilmington,
DE
TABLE
OF
CONTENTS
Executive
Summary.......................................................................................................
iv
1.0
Introduction............................................................................................................
1
1.1
Chambers
Works
...........................................................................................
1
1.2
Washington
Works
........................................................................................
2
2.0
Data
Analysis
and
Analytical
Reporting
.................................................................
3
3.0
Air
Dispersion
Modeling........................................................................................
4
3.1
Chambers
Works
 
ISC3
Modeling
Methodology
and
Results
.......................
4
3.1.1
Emission
Source
Information............................................................
4
3.1.2
Modeling
Methodology
....................................................................
4
3.1.3
Modeling
Results..............................................................................
4
3.2
Washington
Works
 
Screen3
Modeling
Methodology
and
Results................
6
3.2.1
Data
and
Modeling
Procedures
.........................................................
6
3.2.2
Modeling
Results..............................................................................
8
4.0
Chambers
Works
Groundwater
Sampling...............................................................
9
4.1
Background
...................................................................................................
9
4.2
Regional
Geology..........................................................................................
9
4.3
Site
Geology..................................................................................................
9
4.4
Site
Hydrogeology.......................................................................................
10
4.5
Sample
Location
Selection...........................................................................
11
4.6
Sampling
Activities
and
Results...................................................................
11
4.7
Summary
of
Results.....................................................................................
12
5.0
Chambers
Works
Surface
Water
Sampling
...........................................................
14
5.1
Site
Effluent
Sample
Results........................................................................
14
5.2
Chambers
Works
and
Upstream
Surface
Water
Intake
Results.....................
14
5.3
Delaware
River
Surface
Water
Sampling.....................................................
15
5.3.1
Delaware
River
 
Discussion
of
Results..........................................
16
5.4
Salem
Canal.................................................................................................
17
5.5
Summary
of
Results.....................................................................................
17
6.0
Conclusions..........................................................................................................
18
7.0
References............................................................................................................
19
DuPont
Telomer
Manufacturing
Sites:
Environmental
Assessment
of
PFOA
Levels
In
Air
and
Water
Table
of
Contents
EnvironmentalAssessment.
doc
Oct.
1,
03
ii
Wilmington,
DE
TABLES
Table
1
CATT
Established
Screening
Levels
......................................................
vi
Table
2
Summary
of
Air
Dispersion
Modeling
Results
.......................................
vi
Table
3
Summary
of
Groundwater
Sampling
Results
 
Chambers
Works
.............
vi
Table
4
Summary
of
Surface
Water
Sampling
Results
 
Chambers
Works
...........
vi
Table
5
Chambers
Works
Stack
Parameters
and
Emission
Rates..........................
5
Table
6
Chambers
Works
Building
Heights
.........................................................
5
Table
7
Chambers
Works
Site
Air
Dispersion
Modeling
Results..........................
6
Table
8
Chambers
Works
Telomers
Operations
Air
Dispersion
Modeling
Results6
Table
9
Washington
Works
GEP
Stack
Heights...................................................
7
Table
10
Chambers
Work
Groundwater
Analytical
Results
.................................
12
Table
11
Chambers
Works
Outfall
DSN001
Results............................................
14
Table
12
Chambers
Works
Surface
Water
Intake
Results
....................................
15
Table
13
Chambers
Works
Delaware
River
Sampling,
June
9,
2003........................

..................................................................................
(
see
Tables
section)
Table
14
Chambers
Works
Delaware
River
Sampling,
June
10,
2003
......................
..................................................................................
(
see
Tables
section)

FIGURES
Figure
1
Site
Location
Map
 
Chambers
Works,
Deepwater,
New
Jersey
Figure
2
Site
Location
Map
 
Washington
Works,
Parkersburg,
West
Virginia
Figure
3
Groundwater
Sample
Location
Map
and
Wilmington
1993
Windrose
Diagram
Figure
4
Groundwater
Elevation
Contour
Map
 
B
Aquifer
September
24,
2002
Figure
5
Groundwater
Elevation
Contour
Map
 
C
Aquifer
September
24,
2002
Figure
6
Groundwater
Elevation
Contour
Map
 
D
Aquifer
September
24,
2002
Figure
7
Delaware
River
Zone
Designations
Figure
8
Delaware
River
Surface
Water
Sampling
June
9th
Sampling
Results
(
outgoing
tide
 
high
tide
going
to
low
tide)

Figure
9
Delaware
River
Surface
Water
Sampling
June
9th
Sampling
Results
(
incoming
tide
 
low
tide
going
to
high
tide)

Figure
10
Delaware
River
Surface
Water
Sampling
June
10th
Sampling
Results
(
incoming
tide
 
low
tide
going
to
high
tide)

Figure
11
Delaware
River
Surface
Water
Sampling
June
10th
Sampling
Results
(
outgoing
tide
 
high
tide
going
to
low
tide)
DuPont
Telomer
Manufacturing
Sites:
Environmental
Assessment
of
PFOA
Levels
In
Air
and
Water
Table
of
Contents
EnvironmentalAssessment.
doc
Oct.
1,
03
iii
Wilmington,
DE
Figure
12
Salem
Canal
Surface
Water
Sampling
Results
APPENDICES
Appendix
A
Calculation
of
Air
Emissions
Appendix
B
Screen3
Model
Run
Appendix
C
Site
Assessment
Plan
(
SAP)
to
Assess
PFOA
Levels
In
Air
and
Water
from
DuPont
Telomer
Manufacturing
Operations
at
Chambers
Works,
Deepwater,
NJ
and
Washington
Works,
Parkersburg,
WV
DuPont
Telomer
Manufacturing
Sites:
Environmental
Assessment
of
PFOA
Levels
In
Air
and
Water
Executive
Summary
EnvironmentalAssessment.
doc
Oct.
1,
03
iv
Wilmington,
DE
EXECUTIVE
SUMMARY
A
voluntary
Letter
of
Intent
(
LOI)
was
submitted
by
the
Telomer
Research
Program
(
TRP)
to
the
United
States
Environmental
Protection
Agency
(
EPA)
on
March
14,
2003
to
address
questions
raised
by
the
EPA
about
the
possible
association
of
perfluorooctanoic
acid
(
PFOA)
with
telomer
 
based
products.
One
component
of
the
LOI
was
to
characterize
potential
release
of
PFOA
from
telomer
 
based
product
manufacturing
operations.

As
the
only
fully
integrated
U.
S.
producer/
manufacturer
of
telomer
products,
DuPont
volunteered
to
conduct
a
series
of
environmental
assessments
at
its
telomer
manufacturing
operations
located
at
Chambers
Works
in
Deepwater,
New
Jersey
and
Washington
Works
in
Parkersburg,
West
Virginia
(
TRP
LOI
Appendix
1).
Both
sites
are
multi
 
purpose
manufacturing
operations.
Chambers
Works
alone
manufactures
over
400
products
and
has
around
eight
major
chemistries.
At
Washington
Works,
the
telomer
operation
is
one
of
twelve
different
manufacturing
operations.

The
specific
assessments
are
as
follows:

 
Develop
site
specific
plans
to
assess
levels
of
PFOA
in
air
and
water
from
manufacturing
operations
around
each
site;
development
of
plans
will
begin
no
later
than
April
14,
2003.

 
Conduct
site
 
specific
air
dispersion
modeling
for
applicable
manufacturing
operations,
using
the
EPA­
approved
Industrial
Source
Complex
Short
Term
3
(
ISC3)
model,
as
described
in
EPA's
Guideline
on
Air
Quality
Models
(
40
C.
F.
R.
Part
51,
Appendix
W),
and
assess
the
results
using
the
air
screening
levels
established
in
West
Virginia.

 
Conduct
groundwater
and
surface
water
analyses
at
each
site
and
assess
the
results
using
the
water
screening
levels
established
in
West
Virginia.

 
Use
the
West
Virginia
screening
levels
to
determine
what
additional
actions,
if
any,
may
need
to
be
taken.

This
report
summarizes
the
results
of
this
work
using
the
West
Virginia
Screening
Levels
as
established
by
the
C8
Assessment
of
Toxicity
Team
(
CATT)
(
WVDEP,
2002a
and
2002b).
PFOA
levels
in
surface
water
were
compared
to
CATT­
established
human
health
protective
screening
criteria
for
water
of
150
ppb
(
µ
g/
l)
PFOA
and
the
CATTestablished
aquatic
life
advisory
of
1,360
ppb
PFOA
(
Table
1).
PFOA
levels
in
air
were
compared
to
the
CATT­
established
inhalation
reference
concentration
screening
level
of
1.0
µ
g/
m3
air
(
Table
1).
DuPont
Telomer
Manufacturing
Sites:
Environmental
Assessment
of
PFOA
Levels
In
Air
and
Water
Executive
Summary
EnvironmentalAssessment.
doc
Oct.
1,
03
v
Wilmington,
DE
Chambers
Works
Air
dispersion
modeling
for
PFOA
was
conducted
for
the
telomers
manufacturing
facilities
(
Table
2).
The
Chambers
Works
site
air
dispersion
modeling
results
show
a
maximum
average
annual
off­
site
concentration
of
approximately
0.0036
µ
g/
m3
which
is
nearly
three
orders
of
magnitude
below
the
CATT
established
screening
levels.
The
model
using
only
the
telomers
operations
resulted
in
a
maximum
average
annual
off­
site
concentration
of
0.00004
µ
g/
m3.
This
is
five
orders
of
magnitude
below
the
CATTestablished
inhalation
screening
level
of
1.0
µ
g/
m3
(
Table
2).

Groundwater
at
Chambers
Works
is
contained
by
a
groundwater
collection
system
consisting
of
six
interceptor
wells
that
withdraw
over
1.5
million
gallons
per
day
beneath
the
site
to
maintain
an
inward
hydraulic
gradient
around
the
site.
At
the
interceptor
wells,
located
in
the
central
portions
of
the
site,
the
highest
concentration
(
46.6
ppb)
of
PFOA
was
measured
(
Table
3).
At
the
perimeter
wells,
located
at
the
southeast
and
southwest
site
borders,
concentrations
of
PFOA
were
at
very
low
part
per
billion
levels.
Groundwater
in
the
vicinity
of
Chambers
Works
is
not
removed
from
the
ground
for
drinking
water
or
other
use,
with
the
exception
of
the
IWS;
therefore,
it
is
not
appropriate
to
compare
these
results
with
the
CATT­
established
screening
levels
for
drinking
water.
Nevertheless,
numbers
are
well
below
these
levels.

At
Chambers
Works,
PFOA
measurements
in
surface
water
were
well
below
the
CATTestablished
screening
levels.
Table
4
compares
Chambers
Works
analytical
results
from
surface
water
to
the
CATT­
established
screening
levels.
To
be
conservative,
the
highest
concentrations
of
PFOA
in
the
far­
field
surface
water
samples
are
used
for
comparison.
Because
the
Delaware
River
near
Chambers
Works
is
not
designated
as
a
drinking
water
source,
the
aquatic
life
advisory
(
1,360
ppb)
was
used
for
comparison.
Results
from
Salem
Canal,
designated
a
drinking
water
source
by
New
Jersey
Department
of
Environmental
Protection
(
NJDEP),
were
non­
detect
upstream
of
Chambers
Works
and
a
maximum
of
0.089
ppb
at
the
Chambers
Works
Salem
Canal
water
intake.
These
results
are
below
the
CATT­
established
screening
level
of
150
ppb.

Washington
Works
At
Washington
Works,
PFOA
in
groundwater
and
surface
water
has
been
thoroughly
assessed
for
the
site
(
DuPont,
2003)
so
no
further
work
was
needed
to
characterize
groundwater
and
surface
water.
Air
dispersion
modeling
has
also
been
conducted
for
the
site
using
the
ISC3
model.
However,
potential
PFOA
emissions
from
telomer
manufacturing
were
not
included
in
the
model.
The
EPA
Screen3
dispersion
modeling
tool
was
used
to
evaluate
whether
estimated
emissions
from
telomer
operations
would
have
a
significant
affect
on
the
previous
modeling
results.
The
Screen3
model
for
telomers
manufacturing
at
Washington
Works
predicts
a
maximum
average
annual
fenceline
concentration
of
0.00012
µ
g/
m3
 
significantly
below
the
CATT­
established
inhalation
reference
concentration
screening
level
of
1.0
µ
g/
m3
(
Table
2).
These
data
would
not
significantly
affect
the
current
models
for
the
Washington
Works
site.

Summary
Overall
the
data
show
that
telomers
manufacturing
is
not
a
significant
source
of
PFOA
to
the
environment.
DuPont
Telomer
Manufacturing
Sites:
Environmental
Assessment
of
PFOA
Levels
In
Air
and
Water
Executive
Summary
EnvironmentalAssessment.
doc
Oct.
1,
03
vi
Wilmington,
DE
Table
1
CATT
Established
Screening
Levels
Aquatic
Life
Advisory
Concentration
(
water)
1,360
µ
g/
l
(
ppb)

Human
Health
Protective
Screening
Criteria
(
water)
150
µ
g/
l
(
ppb)

Inhalation
Reference
Concentration
(
air)
1.0
µ
g/
m3
Table
2
Summary
of
Air
Dispersion
Modeling
Results
Air
Maximum
Calculated
Off­
site
Concentrations
CATT
Established
Screening
Levels
Chambers
Works
Site
0.0036
µ
g/
m3
1.0
µ
g/
m3
Chambers
Works
Telomers
Only
0.00004
µ
g/
m3
1.0
µ
g/
m3
Washington
Works
Telomers
Only*
0.00012
µ
g/
m3
1.0
µ
g/
m3
*
Screen3
model
used
Table
3
Summary
of
Groundwater
Sampling
Results
 
Chambers
Works
Groundwater
Maximum
Analytical
Results
Interceptor
Wells
 
Plant
Interior
46.6
ppb
Perimeter
Monitoring
Well
5.0
ppb
Table
4
Summary
of
Surface
Water
Sampling
Results
 
Chambers
Works
Surface
Water
Maximum
Analytical
Results
CATT
Established
Screening
Levels
Delaware
River
 
Far
Field
0.566
ppb
1,360.0
ppb
Salem
Canal
0.089
ppb
150.0
ppb
DuPont
Telomer
Manufacturing
Sites:
Environmental
Assessment
of
PFOA
Levels
In
Air
and
Water
Introduction
1
1.0
INTRODUCTION
A
voluntary
Letter
of
Intent
(
LOI)
was
submitted
by
the
Telomer
Research
Program
(
TRP)
to
the
United
States
Environmental
Protection
Agency
(
EPA)
on
March
14,
2003
to
address
questions
raised
by
the
EPA
about
the
possible
association
of
perfluorooctanoic
acid
(
PFOA)
with
telomer­
based
products.
One
component
of
the
LOI
was
to
characterize
potential
release
of
PFOA
from
telomer­
based
product
manufacturing
operations.

As
the
only
fully
integrated
U.
S.
producer/
manufacturer
of
telomer
products,
DuPont
volunteered
to
conduct
a
series
of
environmental
assessments
at
its
telomer
manufacturing
operations
at
Chambers
Works
in
Deepwater,
New
Jersey
and
Washington
Works
in
Parkersburg,
West
Virginia
(
TRP
LOI
Appendix
1).
Neither
of
these
sites
is
a
pure
telomer
manufacturing
site.
Both
sites
are
multi­
purpose
manufacturing
operations.
Chambers
Works
alone
manufactures
over
400
products
and
has
around
eight
major
chemistries.
At
Washington
Works,
the
telomer
operation
is
one
of
twelve
different
manufacturing
operations.

The
specific
assessments
are
as
follows:

 
Develop
site
specific
plans
to
assess
levels
of
PFOA
in
air
and
water
from
manufacturing
operations
around
each
site;
development
of
plans
will
begin
no
later
than
April
14,
2003.

 
Conduct
site­
specific
air
dispersion
modeling
for
applicable
manufacturing
operations,
using
the
EPA­
approved
Industrial
Source
Complex
Short
Term
3
(
ISC3)
model,
as
described
in
EPA's
Guideline
on
Air
Quality
Models
(
40
C.
F.
R.
Part
51,
Appendix
W),
and
assess
the
results
using
the
air
screening
levels
established
in
West
Virginia.

 
Conduct
groundwater
and
surface
water
analyses
at
each
site
and
assess
the
results
using
the
water
screening
levels
established
in
West
Virginia.

 
Use
the
West
Virginia
screening
levels
to
determine
what
additional
actions,
if
any,
may
need
to
be
taken.

This
report
summarizes
the
results
of
this
work
using
the
West
Virginia
Screening
Levels
as
established
by
the
C­
8
Assessment
of
Toxicity
Team
(
CATT)
(
WVDEP,
2002a
and
2002b).
PFOA
levels
in
surface
water
were
compared
to
CATT­
established
human
health
protective
screening
criteria
for
water
of
150
ppb
PFOA
and
the
CATT­
established
aquatic
life
advisory
of
1,360
ppb
PFOA.
PFOA
levels
in
air
were
compared
to
the
CATT­
established
inhalation
reference
concentration
screening
level
of
1.0
µ
g/
m3.

1.1
Chambers
Works
The
DuPont
Chambers
Works,
located
in
Deepwater,
New
Jersey
near
the
Delaware
Memorial
Bridge,
has
manufactured
a
variety
of
industrial
compounds
over
the
past
86
years
(
Figure
1).
Today,
the
site
produces
approximately
400
different
products.
Telomer
production
is
only
a
portion
of
the
manufacturing
process
and
chemistries
DuPont
Telomer
Manufacturing
Sites:
Environmental
Assessment
of
PFOA
Levels
In
Air
and
Water
Introduction
2
present.
The
manufacturing
site
is
approximately
600
acres,
bounded
by
a
nonmanufacturing
area,
which
includes
a
DuPont
owned
and
maintained
wildlife
habitat
to
the
north,
the
Delaware
River
to
the
west,
Salem
Canal
to
the
south,
and
the
Deepwater,
New
Jersey
community
to
the
east.

Since
the
1970s
the
site
has
had
a
groundwater
containment
system.
The
most
significant
containment
program
is
the
Interceptor
Well
System
(
IWS)
that
withdraws
over
1.5
million
gallons
of
groundwater
a
day
from
the
underlying
aquifers
and
pumps
the
water
to
the
site
wastewater
treatment
plant
(
WWTP)
for
treatment.
The
interceptor
well
systems
maintain
an
inward
hydraulic
gradient
on
the
site
to
prevent
off
site
migration
of
groundwater.

The
study
team
identified
four
operations
on­
site
with
the
potential
for
handling
PFOA.
These
were
a
tenant
manufacturing
operation,
the
site
WWTP,
the
site
groundwater
collection
system,
and
telomers
operations.
For
purposes
of
this
study,
each
operation
was
evaluated
for
its
potential
contribution
to
air
for
input
to
the
air
dispersion
model.

Surface
water
was
evaluated
by
collecting
surface
water
samples
from
the
Delaware
River
and
Salem
Canal
and
at
control
locations
upstream
of
the
potential
influence
from
Chambers
Works
emissions.
Groundwater
was
evaluated
by
sampling
the
IWS
and
perimeter
wells
along
prevailing
wind
directions.
The
specific
contribution
from
telomers
to
water
was
not
evaluated
although
it
is
anticipated
that
the
contribution
is
very
low.

1.2
Washington
Works
DuPont
manufactures
telomer
intermediates
at
its
Washington
Works
Site
located
in
Parkersburg,
West
Virginia.
Washington
Works
manufacturing
operations
cover
about
170
acres,
with
the
telomer
facility
covering
about
one
acre
(
Figure
2).
Telomer
manufacturing
is
one
of
12
different
manufacturing
processes
at
Washington
Works.
The
telomer
facility
manufactures
a
variety
of
telomer
intermediates
that
are
shipped
to
the
DuPont
Chambers
Works
Site
for
further
processing.

PFOA
emissions
from
the
Washington
Works
site
have
been
thoroughly
characterized
through
a
series
of
studies
on
air
dispersion,
surface
water
and
groundwater
(
DuPont,
2003b).
Because
of
the
extensive
work
on
surface
water
and
groundwater
emissions
from
the
site,
no
further
evaluation
was
needed
for
this
study.
Previous
air
disperion
modeling
did
not
include
potential
air
emissions
from
telomers
operations.
To
evaluate
whether
estimated
telomer
PFOA
emissions
had
any
appreciable
effect
on
fenceline
concentration
of
PFOA,
the
EPA's
Screen3
air
dispersion
model
screening
tool
was
used.
The
results
of
this
assessment
are
expected
to
be
more
conservative
than
the
ISC3
dispersion
model.
DuPont
Telomer
Manufacturing
Sites:
Environmental
Assessment
of
PFOA
Levels
In
Air
and
Water
Data
Analysis
and
Analytical
Reporting
3
2.0
DATA
ANALYSIS
AND
ANALYTICAL
REPORTING
Analysis
of
PFOA
in
water
was
performed
by
Exygen
Research,
Inc.
according
to
a
laboratory
Standard
Operating
Procedure
(
SOP)
developed
by
Exygen.
The
analytical
method
utilizes
Liquid
Chromatography/
Tandem
Mass
Spectrometry
(
LC/
MS/
MS).
Exygen
reports
PFOA
results
for
the
laboratory
replicate
of
each
field
sample.
These
results
are
evaluated
for
precision
by
comparing
the
field
sample
result
to
the
corresponding
laboratory
replicate
result:

 
If
both
results
are
less
than
the
practical
quantitation
limit
(
PQL),
the
replicate
sample
for
that
analyte
is
considered
to
have
passed
the
precision
criteria.

 
If
one
or
both
results
are
between
one
and
five
times
the
PQL,
the
replicate
is
considered
to
have
met
the
precision
criteria
if
the
two
results
differ
by
less
than
the
PQL.

 
If
one
result
is
less
than
the
PQL
and
the
other
is
not,
and
if
the
two
results
differed
by
a
value
less
than
the
PQL,
the
replicate
is
said
to
have
met
the
acceptance
criteria.

 
If
both
results
are
at
least
five
times
the
PQL,
the
replicate
is
considered
to
have
met
the
criteria
if
the
relative
percent
difference
(
RPD)
between
the
two
results
is
less
than
or
equal
to
20%.
The
RPD
is
the
absolute
value
of
the
difference
of
two
measurements
divided
by
their
average.

When
the
precision
criteria
outlined
above
are
met,
Exygen
reports
the
average
of
the
field
sample
and
lab
replicate
results
reported
by
the
laboratory.
If
criteria
for
precision
are
exceeded,
Exygen
reports
the
higher
of
the
sample
and
lab
replicate
results.
Finally,
when
one
result
(
from
the
sample/
lab
replicate
pair)
is
above
the
PQL
and
one
below,
the
result
that
is
above
the
PQL
is
reported.
Final
PFOA
results
are
recorded
in
the
Corporate
Environmental
Database
(
CED)
and
are
reported
as
FC­
143
for
consistency
with
historical
results.

An
aliquot
of
each
field
sample
is
also
analyzed
as
a
matrix
spike
(
MS).
Results
of
the
MS
analysis
are
used
to
assess
accuracy.
The
MS
recovery
value
must
fall
between
70
to
130%,
unless
the
sample
concentration
is
at
least
four
times
the
amount
spiked.
The
maximum
amount
used
to
spike
field
samples
is
500
ppb.

All
data
packages
generated
by
Exygen
are
reviewed
in­
house
for
compliance
with
the
laboratory
SOP
and
data
usability,
using
the
checklist
provided
in
Appendix
A
of
the
Quality
Assurance
Project
Plan
(
DuPont
CRG,
2003).
Results
of
the
in­
house
review
indicate
that
data
reported
by
Exygen
have
been
generated
in
compliance
with
the
laboratory
SOP,
with
few
exceptions
as
noted
in
the
individual
review
summaries.
All
data
reported
by
Exygen
have
been
judged
usable
for
the
purposes
of
the
project.
DuPont
Telomer
Manufacturing
Sites:
Environmental
Assessment
of
PFOA
Levels
In
Air
and
Water
Air
Dispersion
Modeling
4
3.0
AIR
DISPERSION
MODELING
3.1
Chambers
Works
 
ISC3
Modeling
Methodology
and
Results
3.1.1
Emission
Source
Information
The
ISC3
model
was
used
to
calculate
ambient
ground­
level
air
concentrations
for
emissions
of
PFOA
from
both
the
Chambers
Works
site
and
from
the
telomers
operations.
Table
5
shows
the
stack
parameters
and
emission
rates
used
in
the
model
for
each
emission
point.
Appendix
A
contains
the
basis
for
the
emission
estimates
of
PFOA
for
the
site.

3.1.2
Modeling
Methodology
Dispersion
modeling
was
performed
using
the
EPA's
Industrial
Source
Complex
3
Model
(
ISC3),
version
00101,
provided
by
Trinity
Consultants.
All
modeling
was
done
in
accordance
with
the
procedures
in
EPA's
Guideline
on
Air
Quality
Models
(
40
CFR
Part
51,
Appendix
W).
The
EPA
regulatory
default
options
and
rural
dispersion
coefficients
were
used
in
the
model.

The
PFOA
emission
sources
were
evaluated
for
downwash
effects
from
surrounding
buildings.
The
Building
Profile
and
Input
Program
(
BPIP)
provided
by
Trinity
Consultants
was
used
to
provide
wind
direction
specific
building
parameters.
All
buildings
on
the
site
were
evaluated
to
determine
if
they
could
potentially
impact
the
stack
by
causing
building
downwash
effects.
Table
6
lists
the
buildings
included
in
the
model
and
their
heights.

A
100­
meter
receptor
grid
extending
out
600
meters
from
the
plant
fenceline
was
used.
In
addition,
discrete
receptors
with
50­
meter
spacing
were
placed
on
the
plant
property
line.
Because
the
area
surrounding
the
plant
site
is
flat,
no
terrain
elevations
were
used.

Per
standard
protocol,
five
years
of
meteorological
data
were
analyzed.
The
surface
data
is
from
New
Castle
County
Airport
(
Wilmington,
DE),
and
the
upper
air
data
is
from
Washington
Dulles
Airport
(
Sterling,
VA).
An
anemometer
height
of
6.1
meters
was
used
for
the
modeling.
For
this
study,
readily
available
data
from
years
1989
through
1993
were
used.
These
data
are
viewed
to
be
representative
of
meteorological
conditions
at
Chambers
Works
and
are
sufficient
for
providing
screening
values
for
this
study.

3.1.3
Modeling
Results
An
averaging
time
of
one
year
was
used
to
determine
the
annual
average
ground­
level
concentrations
over
the
entire
receptor
grid.
For
Chambers
Works
site
emissions
the
modeling
results
for
each
year
are
shown
in
Table
7.
The
maximum
average
annual
offsite
value
predicted
by
the
model
was
0.00364
µ
g/
m3.
This
value
was
located
at
a
receptor
on
the
plant
property
line
along
highway
NJ
State
Route
130.
DuPont
Telomer
Manufacturing
Sites:
Environmental
Assessment
of
PFOA
Levels
In
Air
and
Water
Air
Dispersion
Modeling
5
The
model
was
rerun
using
only
estimated
emission
sources
from
Chambers
Works
telomers
operations
(
Table
5).
For
telomers
operations
estimated
average
annual
emissions,
the
modeling
results
are
shown
for
each
year
in
Table
8.
The
maximum
average
annual
off­
site
value
predicted
by
the
model
is
0.00004
µ
g/
m3.
This
value
was
located
at
a
receptor
on
the
plant
property
line
along
Salem
Canal.
These
results
are
well
below
the
CATT­
established
inhalation
reference
concentration
screening
level
of
1.0
µ
g/
m3.

Table
5
Chambers
Works
Stack
Parameters
and
Emission
Rates
Process
Area
Source
Average
Annual
Emission
Rate
(
lb/
hr)
Stack
Height
Stack
Diameter
Flowrate
or
Velocity
Temperature
Tenant
Operation
Building
1163
Stack
0.033
25
ft
31"
92
ft/
s
194
°
F
Telomer
A*
DMA
Roof
#
1
6.06E
 
06
70
ft
2"
17
acfm
150
°
F
ZFAN
Crude*
1156
Building
Hotwell
4.45E
 
05
12
ft
2"
0.033
acfm
65
°
C
185
Alcohol
Drying*
185
Building
Hotwell
2.94E
 
06
0
ft
6"
0
acfm**
40
°
C
185
Alcohol
Drying*
TS
 
45
Tank
Vent
1.62E
 
06
25
ft
3"
10
ft/
s
70
°
C
D
Building*
D
Building
Roof
1.87E
 
05
55
ft
2"
1
acfm
ambient
D
Building*
D
Building
Jets
2.04E
 
06
88
ft
36"
10,000
acfm
ambient
EO
Center*
Hotwell
and
Stack
2.19E
 
05
85
ft
4"
80
acfm
ambient
*
telomers
operations
**
185
building
hotwell
stack
points
at
the
ground
Table
6
Chambers
Works
Building
Heights
Building
Name
Height
(
ft)
Building
Name
Height
(
ft)

1
60
43
16
J26
38
1050
22
1089
15.5
1163
13.5
1094
30
115
East
45
T3
45
115
West
30
589
15
656
30
745
50
1402
25
888
60
185
68
1183
60
1156
45
1182
60
234
30
669
40
788
40
1205
31
DuPont
Telomer
Manufacturing
Sites:
Environmental
Assessment
of
PFOA
Levels
In
Air
and
Water
Air
Dispersion
Modeling
6
Table
7
Chambers
Works
Site
Air
Dispersion
Modeling
Results
Year
Annual
Average
Concentration
(
µ
g/
m3)
Location
1989
0.00309
plant
fenceline
along
US130
1990
0.00364
plant
fenceline
along
US130
1991
0.00305
plant
fenceline
along
US130
1992
0.00267
plant
fenceline
along
US130
1993
0.00300
plant
fenceline
along
DE
River
Table
8
Chambers
Works
Telomers
Operations
Air
Dispersion
Modeling
Results
Year
Annual
Average
Concentration
(
µ
g/
m3)
Location
1989
0.00003
plant
fenceline
along
Salem
Canal
1990
0.00003
plant
fenceline
along
Salem
Canal
1991
0.00004
plant
fenceline
along
Salem
Canal
1992
0.00004
plant
fenceline
along
Salem
Canal
1993
0.00004
plant
fenceline
along
Salem
Canal
3.2
Washington
Works
 
Screen3
Modeling
Methodology
and
Results
3.2.1
Data
and
Modeling
Procedures
Air
emissions
for
Washington
Works
have
been
characterized
using
the
EPA's
ISC3
dispersion
model
(
Bradley,
2002).
However,
the
model
input
did
not
include
potential
emissions
from
the
telomers
operations
at
the
site.
Because
the
estimated
emissions
from
telomers
operations
are
so
small,
the
EPA's
Screen3
model
was
used
to
see
if
there
was
any
appreciable
affect
from
telomers
to
the
modeled
Washington
Works
site
emissions.
The
Screen3
model
is
a
screening
tool
that
gives
predictions
of
ambient
ground­
level
concentrations
for
a
single
stack.
Due
to
the
assumptions
made
in
the
model,
particularly
those
regarding
meteorological
conditions
and
combining
all
emissions
into
a
single
source
point,
these
predictions
will
always
be
more
conservative
(
higher
concentrations)
than
predictions
made
by
the
ISC3
model.
The
advantage
of
using
this
tool
is
that
one
can
look
at
the
contribution
from
telomers
manufacturing
only,
independent
of
other
site
contributions.

Although
there
are
several
different
potential
point
sources
of
PFOA
emissions
in
the
telomers
area
at
the
Washington
Works
site,
these
emission
points
are
combined
together
into
a
common
stack.
The
following
parameters
for
this
stack
were
used
in
the
model:
DuPont
Telomer
Manufacturing
Sites:
Environmental
Assessment
of
PFOA
Levels
In
Air
and
Water
Air
Dispersion
Modeling
7
Stack
Height:
85
feet
Diameter:
1.5
feet
Temperature:
68
°
F
Velocity:
47
ft/
s
PFOA
Emission
Rate:
0.16
lb/
yr
(
1.83x10­
5
lb/
hr)
The
PFOA
emission
rate
is
based
on
the
maximum
production
rate
for
the
telomers
area.
The
basis
for
the
emission
calculations
is
shown
generically
in
Appendix
A,
section
entitled
Telomers
Processes.

To
determine
the
impacts
of
building
downwash
on
dispersion
from
the
stack,
the
Screen3
model
uses
only
the
dominant
downwash
structure
as
an
input
to
the
model.
The
dominant
downwash
structure
can
be
found
by
first
locating
all
buildings
that
have
an
area
of
influence
encompassing
the
stack.
The
EPA
defines
the
area
of
influence
as
a
distance
of
five
times
the
lesser
of
the
height
or
the
maximum
projected
width
of
the
building.
Once
all
of
the
potential
downwash
structures
are
located,
the
dominant
downwash
structure
is
determined
by
calculating
the
GEP
(
Good
Engineering
Practice)
stack
height
for
each
building.
The
building
with
the
greatest
GEP
stack
height
is
the
building
that
should
be
included
in
the
Screen3
model.
The
GEP
stack
height
is
calculated
according
to
the
following
formula:

H
=
h
+
1.5L,

where
H
=
GEP
stack
height
h
=
building
height
L
=
lesser
of
the
building
height
or
maximum
projected
width
The
following
table
shows
the
buildings
that
were
included
in
the
downwash
analysis
and
their
respective
GEPs
(
Table
9):

Table
9
Washington
Works
GEP
Stack
Heights
Building
Height
(
ft)
Length
(
ft)
Width
(
ft)
Max
Projected
Width
(
ft)
GEP
(
ft)

164
44
90
90
125
110
180
64
70
25
75
160
184*
96
195
120
230
240
*
This
building
has
the
highest
GEP
and
was
used
in
the
model.
DuPont
Telomer
Manufacturing
Sites:
Environmental
Assessment
of
PFOA
Levels
In
Air
and
Water
Air
Dispersion
Modeling
8
3.2.2
Modeling
Results
Using
the
above
data
the
Screen3
model
predicted
a
maximum
off­
site
ground­
level
concentration
of
0.0023
µ
g/
m3
at
a
distance
of
289
feet
from
the
source.
This
concentration
is
based
on
a
one­
hour
averaging
time.
To
convert
a
Screen3
model
result
to
an
annual
average,
EPA
guidance
directs
the
user
to
multiply
the
predicted
Screen3
concentration
by
a
value
of
0.05.
This
gives
an
annual
average
concentration
of
1.15x10­
4
µ
g/
m3.
This
concentration
is
four
orders
of
magnitude
below
the
CATTestablished
inhalation
reference
concentration
screening
level
of
1.0
µ
g/
m3.
These
data
would
not
significantly
affect
the
current
models
for
the
Washington
Works
site.

A
copy
of
the
Screen3
model
output
is
located
in
Appendix
B.
DuPont
Telomer
Manufacturing
Sites:
Environmental
Assessment
of
PFOA
Levels
In
Air
and
Water
Chambers
Works
Groundwater
Sampling
9
4.0
CHAMBERS
WORKS
GROUNDWATER
SAMPLING
4.1
Background
DuPont
operates
and
manages
a
groundwater
containment
program
for
the
Chambers
Works
site.
This
program
comprises
of
several
different
systems
and
programs,
the
most
significant
of
which
is
the
site
Interceptor
Well
System
(
IWS).
The
IWS
consists
of
six
pumping
wells
(
in
five
locations)
that
contain
and
capture
groundwater
beneath
the
site.
Chambers
Works
has
been
pumping
groundwater
beneath
the
site
since
the
early
1970s.
Each
day,
over
1.5
million
gallons
is
withdrawn
from
aquifers
beneath
the
site
and
is
treated
at
the
WWTP.

Groundwater
at
Chambers
Works
is
routinely
monitored
and
evaluated
as
part
of
a
sitewide
program
that
satisfies
the
conditions
of
the
site's
Discharge
to
Groundwater
(
DGW)
Permit
requirements.
There
are
about
400
monitoring
wells
located
on
site.
The
semiannual
groundwater
monitoring
report
is
issued
to
the
NJDEP
and
USEPA
and
covers
the
sampling
of
many
of
these
wells.
The
semi­
annual
report
also
includes
rigorous
statistical
analysis
of
the
well
data
so
that
any
significant
groundwater
quality
trends
can
be
identified.
Through
these
reports,
the
physical
and
chemical
properties
of
site
groundwater
have
been
characterized
and
are
well
understood.
Information
from
these
reports
was
used
to
assist
in
identifying
the
wells
and
locations
sampled
for
this
study.

4.2
Regional
Geology
The
DuPont
Chambers
Works
manufacturing
facility
covers
approximately
600
acres
in
Salem
County,
New
Jersey.
The
site
is
located
in
the
Delaware
River
Basin,
near
the
northwestern
edge
of
the
Atlantic
Coastal
Plain.
In
general,
the
site
is
underlain
by
approximately
500
feet
of
unconsolidated
Coastal
Plain
sediment.
This
sediment
was
deposited
during
the
Holocene,
Pleistocene,
and
Cretaceous
periods.
These
geologic
units
thicken
and
dip
regionally
to
the
southeast
and
are
characteristic
of
fluvial,
estuarine,
and
marine
origins.

4.3
Site
Geology
The
geology
beneath
the
site
is
typical
of
the
geologic
setting,
with
alternating
layers
of
coarse
and
fine
sediments.
Periods
of
erosion
between
depositional
cycles
have
generally
caused
discontinuous
units
across
the
site.
In
the
shallow
zones,
this
has
been
exacerbated
by
building
and
construction
activity
over
the
years.

There
are
five
water­
bearing
units
and
four
confining
units
beneath
the
site
that
make
up
the
geologic
model
of
the
site.
They
are:

 
A
Zone:
This
zone
consists
mainly
of
fill
material,
and
varies
in
thickness
from
0
to
17
feet.
Because
the
site
has
been
excavated
and
filled
over
the
decades
of
operation,
the
unit
is
discontinuous,
and
the
depth
to
groundwater
varies
greatly.
In
some
portions
of
the
site,
the
A
Zone
is
partially
to
fully
saturated;
while
in
others,
a
saturated
zone
is
not
present.
DuPont
Telomer
Manufacturing
Sites:
Environmental
Assessment
of
PFOA
Levels
In
Air
and
Water
Chambers
Works
Groundwater
Sampling
10
 
A/
B
Confining
Unit:
This
unit
is
the
first
clay
horizon
encountered
beneath
the
ground
surface
and
varies
in
thickness
from
0
to
12
feet.
This
unit
is
not
continuous
across
the
site.

 
B
Aquifer:
This
unit
consists
of
interbedded
clay,
silt,
and
sand
and
ranges
from
0
to
30
feet
thick.
There
is
an
extensive
network
of
monitoring
wells
in
the
B
aquifer,
because
it
is
the
shallow­
most
aquifer
that
is
mostly
continuous.

 
B/
C
Confining
Unit:
This
unit
is
the
second
clay
horizon
encountered
beneath
the
surface,
and
varies
in
thickness
from
0
to
25
feet.
The
confining
unit
is
not
continuous
across
the
site,
and
there
is
drawdown
in
the
B
aquifer
in
certain
areas
from
the
ongoing
operation
of
the
IWS.

 
C
Aquifer:
This
unit
is
made
of
coarser
sediment
than
the
B
aquifer
and
varies
in
thickness
from
5
to
40
feet.
The
C
aquifer
is
the
first
water­
bearing
unit
that
contains
the
site's
high­
yielding
interceptor
wells.

 
C/
D
Confining
Unit:
This
unit
is
the
third
clay
horizon
encountered
beneath
the
surface
and
varies
in
thickness
from
5
to
35
feet.
The
confining
unit
is
continuous
across
the
site.

 
D
Aquifer:
This
unit
is
the
deepest
water­
bearing
unit
associated
with
the
Pleistocene
sediment.
It
comprises
poorly
graded
sands
with
occasional
cobbles
and
varies
in
thickness
from
5
to
more
than
35
feet.
The
D
aquifer
also
contains
some
of
the
site's
high­
yielding
interceptor
wells.

 
D/
E
Confining
Unit:
This
unit
is
the
fourth
clay
horizon
and
the
second
mapped
unit
of
the
Cretaceous
Age.
The
clay
is
continuous
across
the
site.
It
is
easily
identified
by
its
red
or
variegated
color
and
varies
from
10
to
50
feet
thick.

 
E
Aquifer:
This
unit
is
mostly
coarse­
grained
sands,
and
is
similar
in
lithology
to
the
shallower
units.
It
comprises
multiple
units
with
varying
degrees
of
hydraulic
connectivity
and
could
range
up
to
100
feet
thick.

4.4
Site
Hydrogeology
The
IWS
wells
are
located
in
the
C
and
D
aquifers,
strategically
located
across
the
site
to
maximize
their
influence
on
the
groundwater
flow.
DuPont
maintains
an
inward
hydraulic
gradient
across
the
B,
C,
and
D
aquifers
through
the
continued
operation
of
the
IWS.
There
are
a
few
perimeter
areas
where
an
inward
gradient
has
not
been
confirmed
in
the
B
aquifer
(
only).

In
addition
to
the
IWS,
there
are
several
other
systems
that
deal
with
localized
groundwater
containment.
These
other
systems
include
the
groundwater
recovery
system
at
the
site's
hazardous
waste
landfill,
the
shallow
recovery
trench
near
a
perimeter
Solid
Waste
Management
Unit
(
SWMU),
and
the
E
aquifer
pumping
well.
All
of
these
systems
create
inward
(
towards
the
site)
gradients
in
the
areas
that
they
operate.
DuPont
Telomer
Manufacturing
Sites:
Environmental
Assessment
of
PFOA
Levels
In
Air
and
Water
Chambers
Works
Groundwater
Sampling
11
4.5
Sample
Location
Selection
The
groundwater
monitoring
program
for
PFOA
was
based
on
the
knowledge
of
the
sitewide
groundwater
and
the
existing
network
of
wells.
Since
the
IWS
creates
a
significant
inward
hydraulic
gradient
and
influences
multiple
aquifers,
sampling
the
IWS
was
the
first
step
of
a
PFOA­
focused
evaluation.
A
complete
round
of
groundwater
sampling
from
all
five
interceptor
well
locations
was
conducted.
In
Figure
2,
the
interceptor
wells
are
shown
as:

 
H­
11
 
R­
09
 
K­
06
 
M­
14
 
Q­
13
(
two
wells)
A
total
of
six
samples
were
collected
from
interceptor
wells
since
Q­
13
is
actually
two
separate
wells,
screened
in
different
aquifers.

The
B
aquifer
monitoring
wells
along
the
fenceline
at
the
southeastern
edge
of
the
site
were
selected
based
on
an
evaluation
of
predominant
wind
direction
to
evaluate
if
groundwater
was
affected
by
any
potential
air
deposition
of
PFOA.
Local
weather
station
data
were
evaluated
to
create
a
windrose
for
the
site.
A
windrose
maps
wind
speed
and
duration
for
the
purpose
of
identifying
the
prevailing
seasonal
wind
direction.
Perimeter
wells
were
identified
for
sampling
by
super­
imposing
the
windrose
over
the
site
well
map
(
Figure
3).

Two
B
aquifer
wells
were
selected
in
an
area
of
the
site
adjacent
to
the
Delaware
River
where
the
hydraulic
gradient
was
not
as
well
defined.
(
Figure
2).

4.6
Sampling
Activities
and
Results
On
May
1
and
2
and
June
20,
2003,
groundwater
was
sampled
from
a
total
of
seven
monitoring
wells
and
five
interceptor
wells.
The
sampling
was
conducted
in
accordance
with
the
"
Site
Assessment
Plan"
(
Appendix
C).
The
sampling
was
conducted
by
experienced
personnel
to
ensure
the
data
quality
objectives
were
achieved.

All
of
the
monitoring
wells
selected
are
screened
in
the
B
aquifer.
One
interceptor
well
is
screened
in
the
C
aquifer,
one
is
screened
in
the
D
aquifer,
and
the
other
four
interceptor
wells
are
screened
across
both
the
C
and
D
aquifers.
A
total
of
fourteen
groundwater
samples,
including
three
duplicates,
were
analyzed
for
PFOA.
Figure
3
shows
the
location
of
the
wells
sampled
for
PFOA.
Table
10
presents
the
PFOA
analytical
results
for
all
of
the
samples.
For
wells
screened
in
the
B
aquifer,
the
range
in
PFOA
concentration
is
0.2
ppb
to
5.2
ppb.
The
PFOA
concentration
measured
in
the
C
aquifer
interceptor
well
at
location
Q­
13
is
3.3
ppb.
The
concentration
measured
for
the
interceptor
well
in
the
D
aquifer
at
Q­
13
is
0.4
ppb.
This
significant
concentration
drop­
off
with
depth
is
consistent
with
other
water
DuPont
Telomer
Manufacturing
Sites:
Environmental
Assessment
of
PFOA
Levels
In
Air
and
Water
Chambers
Works
Groundwater
Sampling
12
Table
10
Chambers
Works
Groundwater
Analytical
Results
Sample
Location
Aquifer
Well
Type
Sample
Date
PFOA
(
ppb)

C08
 
M01B1
B
Monitoring
Well
5/
02/
2003
5.3
C10
 
M01B1
B
Monitoring
Well
5/
02/
2003
1.4
C10
 
M01B1
 
2
B
Monitoring
Well
5/
02/
2003
1.5
N04
 
M01B
B
Monitoring
Well
6/
20/
2003
0.2
O05
 
M01B
B
Monitoring
Well
6/
20/
2003
0.8
P06
 
M01B
B
Monitoring
Well
6/
20/
2003
1.1
P06
 
M01B
 
2
B
Monitoring
Well
6/
20/
2003
1.2
R08
 
M01B
B
Monitoring
Well
6/
20/
2003
0.9
Q13
 
R01C
C
Interceptor
Well
5/
01/
2003
3.3
H11
 
R01C/
D
C
and
D
Interceptor
Well
5/
01/
2003
8.5
H11
 
2
C
and
D
Interceptor
Well
5/
01/
2003
8.4
K06
 
R01C/
D
C
and
D
Interceptor
Well
5/
01/
2003
3.1
M14
 
R01C/
D
C
and
D
Interceptor
Well
5/
01/
2003
46.6
Q13
 
R01D
D
Interceptor
Well
5/
01/
2003
0.4
quality
parameters
at
the
site.
The
PFOA
concentration
range
observed
for
interceptor
wells
screened
in
the
C
and
D
aquifers
is
from
3.1
ppb
to
46.6
ppb.

Groundwater
elevation
contour
maps
for
the
B,
C,
and
D
aquifers
are
provided
in
Figures
4,
5,
and
6,
respectively.

Figure
4
shows
that
a
small
groundwater
mound
exists
in
the
B
aquifer
in
the
southwestern
corner
of
the
site.
Groundwater
on
the
western
side
of
the
mound,
including
groundwater
in
monitoring
wells
C08­
MO1B
and
C10­
MO1B,
may
flow
towards
the
Delaware
River;
while
groundwater
on
the
eastern
side
flows
towards
the
interceptor
well
system.
Groundwater
in
the
B
aquifer
in
the
southeastern
corner
of
the
site,
including
monitoring
wells
N04­
M01B,
O05­
MO1B,
P06­
MO1B,
and
R08­
MO1B,
generally
flows
towards
the
northwest
towards
Interceptor
Wells
M­
14
and
Q­
13.

Figures
5
and
6
show
the
same
general
patterns
of
groundwater
flow
with
flow
towards
the
pumping
interceptor
wells,
indicating
communication
between
the
C
and
D
aquifers.

4.7
Summary
of
Results
The
results
of
the
sampling
program
show
the
existence
of
PFOA
in
the
groundwater
at
the
site
at
very
low
levels.
The
results
show
that
PFOA
is
being
contained
on­
site
by
the
site
groundwater
containment
system.
Groundwater
in
the
vicinity
of
Chambers
Works
is
not
removed
from
the
ground
for
drinking
water
or
other
use,
with
the
exception
of
the
DuPont
Telomer
Manufacturing
Sites:
Environmental
Assessment
of
PFOA
Levels
In
Air
and
Water
Chambers
Works
Groundwater
Sampling
13
IWS;
therefore,
it
is
not
appropriate
to
compare
these
results
with
the
CATT­
established
screening
levels
for
drinking
water.
Nevertheless,
numbers
are
well
below
these
levels.

The
PFOA
concentration
data
clearly
show
a
decrease
outwards
from
the
IWS
and
a
decrease
in
PFOA
concentration
with
depth.
This
is
consistent
with
the
characterization
of
site­
wide
groundwater.
The
site­
wide
groundwater
containment
system
maintains
a
hydraulic
gradient
inwards
towards
the
interceptor
wells.
At
the
southeastern
site
perimeter,
all
four
monitoring
wells
sampled
were
1
ppb
or
less.
This
area
has
a
strong
inward
hydraulic
gradient
towards
the
plant
preventing
off­
site
migration
of
groundwater.

At
the
southwestern
perimeter
of
the
site,
adjacent
to
the
Delaware
River,
the
levels
in
the
B
aquifer
monitoring
wells
were
also
very
low
at
1.3
ppb
and
5.3
ppb.
DuPont
Telomer
Manufacturing
Sites:
Environmental
Assessment
of
PFOA
Levels
In
Air
and
Water
Chambers
Works
Surface
Water
Sampling
14
5.0
CHAMBERS
WORKS
SURFACE
WATER
SAMPLING
DuPont
Chambers
Works
is
located
in
Deepwater,
New
Jersey
at
approximately
Delaware
River
mile
69.
The
Delaware
River
at
river
mile
69
is
a
tidal
estuary,
with
the
salinity
of
the
tidal
river
being
a
function
of
the
freshwater
flows
from
the
Schuyllkill
and
Delaware
River
north
of
Trenton,
New
Jersey
(
Figure
7).

Chambers
Works
has
a
primary
discharge
identified
as
outfall
DSN001
(
NJPDES
Permit
#
NJD0005100),
discharging
treated
process
wastewater
at
a
rate
of
approximately
10
to
12
million
gallons
per
day
(
mgd)
and
non­
contact
cooling
water
and
stormwater
at
a
rate
of
approximately
15
to
25
mgd.

The
site
has
two
water
intakes.
One
intake
is
on
non­
tidal
Salem
Canal
(
freshwater
source)
and
one
intake
is
on
the
tidal
Delaware
River
Zone
5
(
fresh
to
brackish
water
source)
downstream
of
the
primary
Chambers
Works
Discharge
Outfall.
The
Salem
Canal
intake
is
approximately
5
to
10
mgd
and
the
Delaware
River
water
intake
is
approximately
20
to
30
mgd.
Zones
4
through
6
of
the
Delaware
River
are
not
classified
as
drinking
water
sources
per
the
Delaware
River
Basin
Commission
Water
Quality
Standard
Regulations
(
Figure
7).
The
Salem
Canal
is
classified
as
a
drinking
water
source
per
NJDEP
regulations.

DuPont
Chambers
Works
operations
that
have
the
potential
to
be
a
source
of
PFOA
to
the
WWTP
are
batch
operations,
with
the
exception
of
continuous
flow
from
groundwater
sources.
Therefore,
outfall
concentrations
are
only
estimates
at
a
point
in
time
and
cannot
be
used
to
estimate
average
loadings
from
Chambers
Works.

5.1
Site
Effluent
Sample
Results
The
primary
Chambers
Works
outfall
to
the
Delaware
River
is
DSN001.
A
total
of
five
composite
samples
were
collected
from
DSN001
in
April,
May,
and
June.
The
results
are
presented
in
Table
11.

Table
11
Chambers
Works
Outfall
DSN001
Results
Date
Conc.
(
ppb)
Sample
Type
April
18
194
48
hr
Comp
May
16
102
48
hr
Comp
June
2
 
8
139
6
day
Comp
June
9
97
24
hr
Comp
June
10
80
24
hr
Comp
5.2
Chambers
Works
and
Upstream
Surface
Water
Intake
Results
There
are
two
surface
water
intakes
to
the
Chambers
Works
site,
the
non­
tidal
Salem
Canal
Intake
and
the
tidal
Delaware
River
Water
intake.
Another
Delaware
River
intake
DuPont
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Manufacturing
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Levels
In
Air
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Water
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Works
Surface
Water
Sampling
15
located
approximately
14
miles
north
of
Chambers
Works
and
outside
the
influences
of
Chambers
Works
discharges,
was
used
as
the
upstream
sample.
Composite
samples
were
taken
from
the
upstream
site's
tidal
Delaware
River
intake
and
are
considered
representative
of
background
PFOA
concentration.
A
total
of
two
samples
were
taken
from
each
intake.
The
results
are
presented
below.

Table
12
Chambers
Works
Surface
Water
Intake
Results
Date
Intake
Conc
(
ppb)
Sample
Type
April
16
Salem
Canal
0.064
24
hr
Comp
May
14
Salem
Canal
0.089
24
hr
Comp
May
15
Salem
Canal
RR*
ND
Grab
April
16
CW
 
Del
River
3.20
24
hr
Comp
May
14
CW
 
Del
River
0.853
24
hr
Comp
April
18
Upstream
 
Del
River
NQ
24
hr
Comp
May
14
Upstream
 
Del
River
NQ
24
hr
Comp
*
A
grab
sample
was
taken
approximately
¾
mile
upstream
of
the
DuPont
Salem
Canal
Water
intake
on
May
15,
2003.

The
Chambers
Works
Delaware
River
intake
is
located
downstream
of
the
site's
primary
outfall.
These
samples
are
within
the
outfall's
mixing
zone
and
are
not
representative
of
Delaware
River
surface
water
conditions.

5.3
Delaware
River
Surface
Water
Sampling
Tidal
flow
on
the
Delaware
River
can
reach
up
to
8
to
12
miles
upstream
of
the
Chambers
Works
facility
depending
on
the
freshwater
flows
from
the
Schuykill
and
northern
Delaware
River
(
non­
tidal).
DuPont
performed
a
low­
flow
and
high­
flow
dye
dispersion
study
and
a
hydrographic
survey
of
the
Delaware
Estuary
in
the
late
1980s.
These
studies
showed
that
the
Delaware
Estuary
is
well
mixed
vertically,
and
that
is
there
is
no
significant
salinity
gradient
within
the
water
column.
It
also
appeared
to
show
elevated
dye
concentrations
near
the
eastern
shore
when
compared
to
the
western
side
of
the
estuary,
which
indicates
incomplete
mixing
horizontally
(
i.
e.,
the
effluent
tends
to
"
hug"
the
eastern
shore).

Surface
water
samples
were
not
taken
at
different
depths
in
the
river
because
the
estuary
is
well
mixed
vertically.
However,
samples
were
taken
over
the
width
of
the
river
to
take
into
account
the
possibility
of
varying
concentrations
across
the
river.

The
Delaware
River
was
sampled
downstream
of
DSN001
on
June
9
during
the
outgoing
tide
(
DRO1
to
DRO12)
and
on
June
10
during
the
incoming
tide
(
DRI19
to
DRI24).
The
downstream
samples
taken
during
the
outgoing
tide
were
taken
at
points
approximately
½
mile,
1
mile,
4
miles,
and
12
miles
downstream
of
Chambers
Works
effluent
discharge
to
the
river
(
DSN001).
For
the
incoming
tide,
the
samples
were
taken
at
points
approximately
1
mile
and
4
mile
downstream.
The
downstream
results
of
the
surface
water
samples
are
presented
in
Tables13
and
14
and
Figures
8
and
10.
DuPont
Telomer
Manufacturing
Sites:
Environmental
Assessment
of
PFOA
Levels
In
Air
and
Water
Chambers
Works
Surface
Water
Sampling
16
The
tidal
Delaware
River
was
sampled
upstream
of
DSN001
during
the
incoming
tide
on
June
9
(
DRI13
to
DRI18)
and
during
the
outgoing
tide
on
June
10
(
DRO25
to
DRO30).
The
samples
for
the
incoming
and
outgoing
tides
were
taken
at
points
approximately
4
miles
and
13+
miles
upstream
of
the
Chambers
Works
outfall.
The
13+
mile
sample
is
outside
the
influence
of
the
Chambers
Works
effluent
and
is
considered
a
background
sample.
The
upstream
results
of
the
surface
water
samples
are
presented
in
Tables
13
and
14
and
Figures
9
and
11.

The
Chamber
Works
DSN001
effluent
was
sampled
each
day
(
24­
hour
composite)
from
June
2
through
8
prior
to
the
surface
water
sampling
events.
These
samples
were
combined
to
form
a
single
6­
day
composite
sample
for
analysis.
Daily
composite
samples
were
also
taken
at
DSN001
on
June
9
and
10
when
sampling
of
the
Delaware
River
was
being
performed.
The
results
of
the
outfall
samples
collected
are
presented
above
in
Table
11.

5.3.1
Delaware
River
 
Discussion
of
Results
Background
Concentrations
The
upstream
sampling
results
and
the
Delaware
River
surface
water
results,
identified
as
samples
DRO
28
through
30,
are
indicative
of
the
background
concentration
of
PFOA,
outside
the
influence
of
any
PFOA
present
in
the
Chambers
Works
outfall
DSN001.
The
results
indicate
that
the
background
concentration
of
PFOA
is
non­
detectable
(
ND)
or
not
quantifiable
(
NQ).
ND
is
less
than
10
ppt
and
NQ
is
less
the
50
ppt.

Effluent
Concentrations
The
Chambers
Works
outfall
DSN001
average
PFOA
concentration
during
the
sampling
period
was
approximately
133
ppb.
The
range
of
the
data
set
was
80
ppb
to
194
ppb.
The
batch
nature
of
PFOA
loading
into
the
WWTP
is
the
reason
for
the
variability
in
effluent
concentrations,
and
makes
it
difficult
to
extrapolate
the
data
set
to
an
average
concentration.

Near
Field
Concentrations
of
Outfall
001
A
preliminary
assessment
of
near­
field
dilution
of
Chambers
Works
discharge
in
the
Delaware
River
was
performed
by
the
consulting
firm
Lawler,
Matusky,
&
Skelly
Engineers
in
September
1990.
The
results
of
the
near­
field
assessment
indicated
an
average
dilution
of
6:
1
river/
effluent
within
100
ft
of
the
discharge.
This
equates
to
an
estimated
PFOA
average
concentration
of
approximately
20
ppb
at
the
edge
of
the
100­
foot
mixing
zone.

Far
Field
Concentrations
Downstream
of
Outfall
001
Two
sets
of
surface
water
samples
were
taken
downstream
of
the
Chambers
Works
outfall
001,
one
set
during
an
outgoing
tide,
samples
DRO1
through
DRO12
(
Figure
2)
and
the
other
set
during
an
incoming
tide,
samples
DRI19
through
DRI24
(
Figure
4).
The
surface
water
concentrations
ranged
from
NQ
to
0.566
ppb
during
an
outgoing
tide
and
from
NQ
to
0.233
ppb
during
an
incoming
tide
at
the
locations
where
samples
were
collected.
The
data
indicate
that
concentrations
on
the
eastern
side
of
the
river
were
higher
than
western
side
of
the
river,
and
the
concentrations
decreased
downstream.
DuPont
Telomer
Manufacturing
Sites:
Environmental
Assessment
of
PFOA
Levels
In
Air
and
Water
Chambers
Works
Surface
Water
Sampling
17
These
results
are
consistent
with
the
previous
dye
studies
conducted
by
Lawler,
Matusky
&
Skelly
Engineers
for
DuPont.
These
results
are
well
below
the
aquatic
life
advisory
concentration
for
PFOA
(
1,360
ppb).
Because
of
its
high
salinity
the
Delaware
River,
Zone
5
is
not
designated
for
use
as
a
drinking
water
source.

Far
Field
Concentrations
Upstream
of
Outfall
001
Two
sets
of
surface
water
samples
were
taken
upstream
of
the
Chambers
Works
outfall
DSN001,
one
set
during
an
incoming
tide,
samples
DRI13
through
DRO18
(
Figure
3)
and
the
other
set
during
an
outgoing
tide,
samples
DRO25
through
DRO30
(
Figure
5).
The
surface
water
concentrations
were
either
ND
or
NQ
during
the
incoming
and
outgoing
tides.
The
DRO25
through
DRO30
samples
represent
at
or
near
background
concentrations
since
the
samples
were
taken
several
miles
upstream
of
outfall
DSN001.
Samples
DRI13
through
DRI18
were
taken
several
miles
upstream
of
outfall
DSN001
several
hours
after
high
tide
(
outgoing);
during
an
incoming
tide;
however,
these
samples
were
taken
only
an
hour
after
the
change
of
tide.
Therefore,
it
is
not
clear
whether
they
were
influenced
by
the
discharge
from
DSN001;
the
results
were
either
ND
or
NQ.

5.4
Salem
Canal
The
Salem
Canal
is
a
fresh
water
canal
that
connects
to
the
Delaware
River
via
Munson
Dam
at
approximate
river
mile
68.
It
is
separated
from
the
Delaware
River
by
the
dam,
and
flow
to
the
river
is
controlled
by
DuPont
to
maintain
water
level
in
the
canal.
Chambers
Work
withdraws
approximately
8
to
10
mgd
of
water
at
Munson
Dam.
Two
Salem
Canal
intake
samples
were
collected
in
April
and
May
(
Table
12).
The
results
of
these
two
samples
were
0.064
and
0.089
ppb,
respectively
(
average
of
0.077).
An
additional
sample
was
taken
approximately
¾
mile
upstream
of
the
Salem
Canal
intake
at
the
railroad
bridge
that
crosses
the
canal
(
Figure
12).
This
location
is
outside
the
DuPont
Chambers
Works
boundary.
The
PFOA
result
was
ND.
This
indicates
no
off­
site
presence
of
PFOA
in
Salem
Canal.

5.5
Summary
of
Results
Measured
concentrations
of
PFOA
in
the
Salem
Canal
and
Delaware
River
are
well
below
CATT­
established
human
health
protective
screening
criteria
for
water
of
150
ppb
and
CATT­
established
aquatic
life
advisory
of
1,360
ppb,
respectively.
DuPont
Telomer
Manufacturing
Sites:
Environmental
Assessment
of
PFOA
Levels
In
Air
and
Water
Conclusions
18
6.0
CONCLUSIONS
The
Environmental
Assessment
laid
out
in
the
TRP
LOI,
Appendix
1
has
been
completed.
Air
emissions
have
been
evaluated
for
Chambers
Works
and
Washington
Works.
Surface
water
and
groundwater
concentrations
of
PFOA
have
been
assessed
for
Chambers
Works.
Washington
Works
surface
water
and
groundwater
have
already
been
assessed
(
DuPont,
2002b)
and
were
not
included
in
this
study.

All
findings
from
these
assessments
are
well
below
the
CATT­
established
screening
levels,
indicating
telomer
manufacturing
operations
are
not
a
significant
source
of
PFOA
to
the
environment.
At
Chambers
Works
and
Washington
Works,
the
telomers
manufacturing
potential
contribution
to
air
is
very
low,
with
the
maximum
calculated
offsite
concentration
in
air
between
0.00004
µ
g/
m3
and
0.00012
µ
g/
m3.

PFOA
concentrations
in
groundwater
and
surface
water
around
Chambers
Works
are
all
well
below
CATT­
established
screening
levels.

In
summary,
all
PFOA
concentrations
measured
or
modeled
in
the
environment
were
well
below
the
CATT­
established
screening
levels.
DuPont
Telomer
Manufacturing
Sites:
Environmental
Assessment
of
PFOA
Levels
In
Air
and
Water
References
19
7.0
REFERENCES
Bradley,
M.
Ann,
2002.
Letter
and
Report,
ISC
Modeling
Methodology
and
Results,
to
A.
Benincasa
and
D.
A.
Staats,
West
Virginia
Department
of
Environmental
Protection,
June
13,
2002.

DuPont
Environmental
Remediation
Services.
1996a.
SWMU
#
5
Groundwater
Technical
Memorandum.
DuPont
Chambers
Works
Complex,
Deepwater,
New
Jersey.
September
1996a.

DuPont,
Corporate
Remediation
Group.
2003a.
Investigation
Quality
Assurance
Project
Plan
for
DuPont
Chambers
Works,
April
2003.

_____.
2003b.
C­
8
Data
Summary
Report
Consent
Order
GWR­
U19,
February
2003.

Lawler,
Matusky
&
Skelly
Engineers.
1990a.
Modeling
and
Data
Assessment
of
Dilution
of
ChambersWorks
Discharge
in
the
Delaware
River,
September
1990
Lawler,
Matusky
&
Skelly
Engineers.
1990b.
Low­
Flow
Dispersion
and
Hydrographic
Survey
in
the
Delaware
River
Near
Deepwater
Point,
New
Jersey,
February
1990
Delaware
Department
of
Environmental
Protection.
1999.
State
of
Delaware
Surface
Water
Quality
Standards,
As
Amended,
August
11,
1999.

West
Virginia
Department
of
Environmental
Protection.
2002a.
C8
Assessment
of
Toxicity
Team
(
CATT)
Aquatic
Life
Advisory
Concentration
for
C8,
October
2002
_____.
2002b.
Final
Ammonium
Perfluroooctanoate
(
C8)
Assessment
of
Toxicity
(
CATT)
Report,
August
2002
TABLES
Table
13
Chambers
Works
Delaware
River
Sampling
Date:
June
9,
2003
High
Tide:
0835
Low
Tide:
1546
Coordinates
Northing
Westing
(
ft)
(
ft)
(
C)
(
mg/
L)
(
ug/
L)
DRO
01
39­
41­
974
75­
31­
091
40'
13'
0915
6.83
17.3
269
5.34
516
NQ
DRO
02
39­
41­
954
75­
30­
742
62'
20'
0932
7.13
17.2
192.5
4.45
463.3
0.378
DRO
03
39­
41­
827
75­
30­
580
25'
9'
0941
6.87
17.1
194.5
4.49
458
0.566
DRO
04
39­
41­
005
75­
31­
667
22'
7'
0956
7.42
17.2
212
4.56
438.2
NQ
DRO
05
39­
40­
737
75­
31­
390
53'
18'
1008
7.52
17.5
202
4.96
424.7
0.134
DRO
06
39­
40­
561
75­
31­
009
18'
6'
1023
7.26
17.6
201
5.17
419.7
0.301
DRO
07
39­
39­
503
75­
33­
202
27'
9'
1235
7.72
18.3
232
5.31
391.8
NQ
DRO
08
39­
39­
167
75­
32­
824
38'
13'
1246
7.25
17.9
193.2
5.09
388.4
0.101
DRO
09
39­
38­
990
75­
32­
447
24'
8'
1414
7.67
18.8
204
6.01
357
0.287
DRO
10
39­
36­
798
75­
36­
201
24'
8'
1449
7.10
19.0
215
6.53
350.9
0.051
DRO
11
39­
36­
754
75­
34­
823
35'
12'
1516
7.09
17.7
185.7
5.70
365.5
0.051
DRO
12
39­
36­
716
75­
34­
403
25'
8'
1526
6.73
17.8
193.1
5.17
372.2
0.202
DRI
13
39­
46­
182
75­
28­
746
9'
3'
1640
7.39
17.5
180.8
6.28
332.4
NQ
DRI
14
39­
46­
055
75­
28­
351
50'
16'
1649
6.85
16.8
151.8
6.30
335.4
NQ
DRI
15
39­
46­
006
75­
27­
882
30'
10'
1700
6.73
17.3
167.9
6.03
344.2
NQ
DRI
16
39­
49­
525
75­
22­
981
38'
13'
1715
7.44
17.3
179.1
5.92
332.8
ND
DRI
17
39­
49­
391
75­
22­
696
50'
16'
1724
6.95
17.1
156.8
5.85
349.8
NQ
DRI
18
39­
49­
214
75­
22­
563
23'
8'
1735
6.75
17.2
149.4
4.06
332.1
NQ
DTB
­
Depth
to
Bottom
Limit
of
Detection
(
LOD)
for
the
procedure
is
approximately
0.010
ug/
L
Limit
of
Quantification
(
LOQ)
for
the
procedure
is
0.050
ug/
L
ND
­
Compound
not
detected
NQ
­
Compound
detected
at
a
level
between
LOD
an
LOQ.
Result
not
quantifiable.
PFOA
Sample
ID
Temp
C
Spec.
Cond.
D.
O.
Redox
DTB
Sample
Depth
Sample
Time
pH
10/
1/
2003
1
of
1
June
9Tables
13
and
14.
xls
Table
14
Chambers
Works
Delaware
River
Sampling
Date:
June
10,
2003
High
Tide:
0939
Low
Tide:
0424
Coordinates
Northing
Westing
(
ft)
(
ft)
(
C)
(
mg/
L)
(
ug/
L)
DRI
19
39­
41­
949
75­
31­
204
31'
11'
0740
6.94
17.9
137.2
5.08
553.2
NQ
DRI
20
39­
42­
001
75­
30­
770
63'
21'
0755
6.69
17.3
128.8
4.57
519
NQ
DRI
21
39­
41­
764
75­
30­
655
46'
15'
0811
7.07
17.5
116.4
5.2
474.1
0.154
DRI
22
39­
39­
531
75­
33­
287
30'
10'
0914
7.24
17.9
123.8
4.35
397.5
0.057
DRI
23
39­
39­
290
75­
32­
712
51'
17'
0925
7.13
17.9
133.1
4.95
387.5
0.140
DRI
24
39­
39­
059
75­
32­
165
8'
3'
0940
7.09
18.5
141.3
5.22
382.1
0.233
DRO
25
39­
45­
604
75­
29­
017
42'
14'
1220
7.5
18.8
236
6.21
327.5
ND
DRO
26
39­
45­
429
75­
28­
750
31'
10'
1230
7.39
18.0
147.4
9.57
355.8
NQ
DRO
27
39­
45­
314
75­
28­
362
30'
10'
1245
6.69
18.2
126.9
7.21
355.9
ND
DRO
28
39­
49­
470
75­
23­
057
34'
11'
1305
7.09
17.8
157.5
5.78
358.2
ND
DRO
29
39­
49­
307
75­
22­
852
50'
17'
1325
7.25
17.2
101.2
6.46
343.1
ND
DRO
30
39­
49­
167
75­
22­
650
32'
11'
1335
7.18
18.3
99.2
6.42
337.9
NQ
DTB
­
Depth
to
Bottom
Limit
of
Detection
(
LOD)
for
the
procedure
is
approximately
0.010
ug/
L
Limit
of
Quantification
(
LOQ)
for
the
procedure
is
0.050
ug/
L
ND
­
Compound
not
detected
NQ
­
Compound
detected
at
a
level
between
LOD
an
LOQ.
Result
not
quantifiable.
PFOA
Sample
ID
Temp
C
Spec.
Cond.
D.
O.
Redox
DTB
Sample
Depth
Sample
Time
pH
10/
1/
2003
1
of
1
June
10Tables
13
and
14.
xls
FIGURES
Philadelphia
Dover
Allentown
Camden
Trenton
Wi
lm
i
ngt
on
Milford
Pottstown
Salem
Zone
6
Zone
4
Zone
2
Zone
5
Zone
3
Sch
uyl
kil
l
River
Maurice
River
Salem
River
Rancocas
C
r
eek
Leips
ic
River
Nesha
miny
Cree
k
Allo
way
Creek
Tohickon
Creek
S
t.
Jone
s
River
Perkiom
en
Creek
Racco
o
n
Creek
Oldmans
Creek
Christina
River
C
&
D
Canal
Cohansey
R
i
ver
Mantua
Creek
Smyrna
River
Stowe
Creek
Bra
ndywine
Creek
Wissahickon
Cr
eek
Big
Timber
Creek
Mis
pill
ion
River
Pennsa
uk
en
Creek
B
la
cks
Cr
eek
East
Branch
Perkiomen
Creek
Little
Lehigh
C
reek
Assunpink
Cre
ek
White
Clay
C
ree
k
Manatawny
Creek
Murderkill
River
Dennis
Creek
E
ast
Branch
Brandywine
Creek
Cross
wicks
Creek
Cedar
Creek
West
B
ranch
Bran
dywine
Creek
Cape
May
Canal
Salem
Canal
Marsh
Creek
Musconetcong
R
Pohatco
Little
Lehigh
Creek
Delaware
River
Zone
Designations
Figure
7
DuPont
Chambers
Works
Figure
8
Delaware
River
Surface
Water
Sampling
June
9th
Sampling
Results
Outgoing­
Tide
(
High
Tide
going
to
Low
Tide)

June
9,
2003
High
Tide
08:
35
June
2­
8
139
ug/
L
Outgoing
Tide
Outfall
001
June
9
97.15
ug/
L
June
10
80
ug/
L
NQ
(
1)
0.378
(
2)
0.566
(
3)
'­­­­
~
1/
2
mile
downstream
9:
15
9:
32
9:
41
Delaware
Memorial
Bridge
(
DMB)

NQ
(
4)
0.134
(
5)
0.301
(
6)
'­­­­
~
1
mile
downstream
of
discharge
9:
56
10:
08
10:
23
New
NQ
(
7)
0.101
(
8)
0.287
(
9)
'­­­­
~
4miles
downstream
in
front
of
Penns
Beach
Castle
12:
35
12:
46
14:
14
0.051
(
10)
0.051
(
11)
0.202
(
12)
'­­­­­
~
10
miles
downstream
just
before
Pea
Patch
14:
49
15:
16
15:
26
Island
Pea
Patch
Island
Units
are
ug/
L
(
ppb)

Data
is
presented
as
RESULT
(
sample
ID#)
Time
of
sample
Figure
9
Delaware
River
Surface
Water
Sampling
June
9th
Sampling
Results
Incoming­
Tide
(
Low
Tide
going
to
High
Tide)

Pennsylvania
ND
(
16)
NQ
(
17)
NQ
(
18)
'­­­­
13+
miles
upstream
17:
15
17:
24
17:
35
Zone
4
Zone
5
June
9,
2003
Delaware
Low
Tide
15:
46
Fox
Point
State
Pk.
NQ
(
13)
NQ
(
14)
NQ
(
15)
'­­­­
4
miles
upstream
of
discharge
16:
40
16:
49
17:
00
Outfall
001
In
Coming
Tide
June
2­
8
139
ug/
L
June
9
97.15
ug/
L
June
10
80
ug/
L
Delaware
Memorial
Bridge
Pea
Patch
Island
Units
are
ug/
L
(
ppb)

Data
is
presented
as
RESULT
(
sample
ID#)
Time
of
sample
Figure
10
Delaware
River
Surface
Water
Sampling
June
10th
Sampling
Results
Incoming­
Tide
(
Low
Tide
going
to
High
Tide)

June
10,
2003
Low
Tide
04:
24
June
2­
8
139
ug/
L
In­
coming
Tide
Outfall
001
June
9
97.15
ug/
L
June
10
80
ug/
L
NQ
(
19)
NQ
(
20)
0.154
(
21)
'­­­­
1/
2
mile
downstream
7:
40
7:
55
8:
11
Delaware
Memorial
Bridge
'­­­­
1
mile
downstream
of
discharge
New
0.057
(
22)
0.14
(
23)
0.233
(
24)
'­­­­
4
miles
downstream
in
front
of
Penns
Beach
Castle
9:
14
9:
25
9:
40
'­­­­­
10
miles
downstream
just
before
Pea
Patch
Island
Pea
Patch
Island
Units
are
ug/
L
(
ppb)

Data
is
presented
as
RESULT
(
sample
ID#)
Time
of
sample
Figure
11
Delaware
River
Surface
Water
Sampling
June
10th
Sampling
Results
Outgoing­
Tide
(
High
Tide
going
to
Low
Tide)

Pennsylvania
ND
(
28)
ND
(
29)
NQ
(
30)
'­­­­
13+
miles
upstream
13:
05
13:
25
12:
35
Zone
4
Zone
5
Delaware
June
10,
2003
High
Tide
09:
39
Fox
Point
State
Pk.
ND
(
25)
NQ
(
26)
ND
(
27)
'­­­­
4
miles
upstream
of
discharge
12:
20
12:
30
12:
45
Outfall
001
Out­
going
Tide
June
2­
8
139
ug/
L
June
9
97.15
ug/
L
June
10
80
ug/
L
Delaware
Memorial
Bridge
Pea
Patch
Island
Units
are
ug/
L
(
ppb)

Data
is
presented
as
RESULT
(
sample
ID#)
Time
of
sample
Figure
12
Salem
Canal
Surface
Water
Sampling
Results
Chambers
Works
Fence
Line
Rail
road
Munson
Dam
(
flow)

NJ
State
ND
Salem
Canal
Delaware
River
Rte.
130
DuPont
Salem
Canal
Intake
(
0.077
ug/
L)
APPENDICES
APPENDIX
A
CALCULATION
OF
AIR
EMISSIONS
A­
1
APPENDIX
A
Calculation
of
Air
Emissions
Tenant
Operation
The
site
has
a
tenant
operation
running
a
small
batch
manufacturing
process
using
PFOA
as
a
processing
aid.
A
simple
mass
balance
using
conservative
estimates
of
air
emissions
was
used.
Air
emission
estimates
were
based
on
a
96­
hour
campaign,
with
PFOA
released
over
a
10­
hour
drying
cycle.
The
drying
cycles
occurred
after
hours
34,
58,
82
and
106
into
the
cycle.
Estimated
emission
varied
from
0.3
to
0.8
pounds
of
PFOA
released
over
the
10­
hour
cycle.
Model
input
took
the
maximum
emissions
over
110
days
per
year
campaign
schedule.

Wastewater
Treatment
Plant
(
WWTP)

Emissions
characterization
for
the
site
WWTP
was
based
on
a
combination
of
engineering
analysis,
mass
balancing,
and
modeling.
For
wastewater
treatment
operations,
the
TOXCHEM+
model,
Version
3.0
from
Enviromega
in
Canada
was
used
to
predict
how
much
of
the
material
would
be
emitted
to
air
from
treating
wastewater
at
the
site.
For
this
study,
TOXCHEM+
was
run
to
simulate
maximum
expected
PFOA
loading
conditions
from
the
site,
i.
e.,
all
batch
operations
running
at
the
same
time.
Twenty­
two
separate
modeling
runs
were
conducted
to
understand
how
potential
air
emissions
might
vary
with
changing
physical/
chemical
properties
of
PFOA.
In
every
case,
results
showed
that
virtually
none
(
less
than
0.04
lb/
yr)
of
the
material
was
transferred
to
the
air
phase.
Therefore,
these
data
were
not
used
in
the
air
dispersion
modeling
study.

Telomers
Processes
This
assessment
required
the
development
of
a
method
for
estimating
PFOA
concentration
that
could
potentially
be
emitted
from
telomer
manufacturing
operations.
This
method
is
not
validated.
The
resulting
estimated
values
are
not
of
sufficient
accuracy
and
certainty
to
be
used
for
any
purpose
other
than
for
comparison
to
a
screening
level,
as
set
forth
in
the
LOI.
PFOA
emissions
from
telomers
operations
were
calculated
based
on
the
estimated
analytical
data,
which
suggests
that
this
compound
is
present
in
the
process
at
trace
levels.
One
data
sample
was
collected
and
analyzed
at
each
of
various
points
in
the
process
following
a
batch
run.
This
was
repeated
for
different
product
chemistries,
and
the
data
were
used
to
estimate
vapor
phase
emissions
from
a
variety
of
vessels
during
process
steps
that
include
filling,
evacuating,
distilling,
reacting,
homogenizing,
and
packing
out.
These
data
provide
a
reasonable
estimated
concentration
in
the
process
to
be
used
for
this
screening
level
study.
A­
2
Basic
Physical
Property
Data
The
primary
property
determining
vapor
phase
composition
above
a
mixture
containing
PFOA
is
the
vapor
pressure.
Recent
measurements
of
the
vapor
pressure
(
2003)
were
used
in
emission
calculations
and
is
best
described
by
the
following
equation:

Ln
(
VP)
in
psia
=
12.7965
 
3388.046
/
(
T
oK
 
130.441)
The
vapor
pressure
of
PFOA
is
quite
low;
when
combined
with
the
low
levels
of
PFOA
in
the
operations
evaluated,
it
is
anticipated
that
air
emission
rates
will
be
also
be
very
low.

Vapor
Phase
Composition
Calculations
The
composition
of
the
vapor
phase
during
all
processing
steps
was
determined
by
calculating
the
partial
pressure
of
the
PFOA
above
the
organic
solution
using
Raoult's
law
and
the
ideal
gas
law.

The
use
of
Raoult's
law
implies
that
the
liquid
solution
is
ideal
and
that
the
activity
coefficient
of
PFOA
out
of
telomers
is
1.0.
For
similar
compounds
this
would
normally
be
a
reasonable
first
pass
assumption;
however,
there
is
no
measured
vapor­
liquid
equilibrium
data
to
verify
that
this
is
indeed
the
case.
As
a
result,
the
partial
pressure
could
be
greater
(
positive
deviation
systems)
or
less
(
negative
deviation
systems)
than
calculated
by
Raoult's
law.

The
use
of
the
ideal
gas
law
implies
that
all
processing
steps
are
at
low
to
medium
pressures
(
below
100
psig).
This
is
indeed
the
case,
as
the
highest
pressure
encountered
in
processing
is
55
psig.

The
calculation
of
vapor
composition
also
assumes
that
the
vapor
is
primarily
nitrogen
such
that
the
molecular
weight
of
the
vapor
is
approximately
28
lb/
lbmole.
Based
on
processing
temperatures
and
available
vapor
pressure
data,
this
is
a
reasonable
assumption.

The
mole
fraction
of
PFOA
in
the
vapor
is,
therefore,
calculated
as
follows:

y
=
x
(
VP)
/
Ptot
where
y
and
x
represent
mole
fractions
of
PFOA
in
the
vapor
and
liquid
phases
respectively.
Total
pressure
of
the
system
is
represented
as
Ptot
and
VP
represents
the
vapor
pressure
of
PFOA
at
the
liquid
temperature.

Liquid
Phase
Composition
Calculations
The
liquid
phase
composition
was
determined
by
analysis
and
is
altered
only
when
additions
are
made
to
the
vessel
contents.
To
be
conservative,
during
a
distillation
or
evacuation
step
(
low
boiler
removal),
it
was
assumed
that
the
composition
of
any
vapor
leaving
the
condenser
was
based
on
the
partial
pressure
above
the
vessel
contents
at
the
condenser
temperature.
Since
the
PFOA
content
in
the
condenser
liquid
will
be
lower
than
in
the
vessel,
this
assumption
may
be
quite
conservative
in
estimating
the
emissions.

During
processing
steps
in
which
other
materials
are
added
to
the
vessel,
the
vapor
displaced
is
assumed
to
be
at
the
partial
pressure
prior
to
dilution.
Subsequent
process
A­
3
steps
take
credit
for
any
dilution
effects
provided
by
addition
of
other
materials.
When
two
liquid
phases
are
present
(
water
additions),
there
is
no
credit
taken
for
dilution,
and
the
liquid
phase
composition
is
assumed
to
remain
unchanged.
This
results
in
a
conservative
estimate
for
the
emissions
estimates.

During
processing
steps
if
there
was
analytical
data
for
PFOA
content
at
that
step,
it
was
this
value
that
was
provided
as
input
to
the
calculations.

Vapor
Flow
Rate
Calculations
During
any
filling
step,
it
was
assumed
that
the
vapor
displaced
was
equal
in
volume
to
the
liquid
charged
to
the
vessel
and
in
equilibrium
with
the
liquid.
During
steps
in
which
the
vessel
pressure
was
changed,
such
as
in
pressurization
and
venting
or
evacuation,
the
mass
of
vapor
discharged
was
calculated
using
the
ideal
gas
law
and
the
vapor
space
of
the
particular
vessel
as
follows:

Total
Mass
of
Vapor
Discharged
=
V
 
P
MW
/
(
RT)

The
mole
fraction
of
PFOA
in
the
vapor
was
determined
at
the
initial
pressure
and
instantaneous
equilibrium
assumed.
Pressure
let­
downs
were
assumed
to
occur
much
faster
than
the
mass
transfer
rate
to
the
vapor
during
venting
and/
or
evacuations.

Total
Annual
Emission
Calculations
Emissions
were
calculated
based
on
the
operating
procedures
for
each
step
of
the
typical
area
processes.
These
total
emissions
were
then
divided
by
the
total
batch
time
to
arrive
at
an
hourly
rate
of
emission
and
multiplied
by
8,760
hours/
year
to
arrive
at
an
annual
rate.
For
those
processes
that
operated
on
a
continuous
basis,
the
emission
rate
calculated
was
multiplied
by
8,760
hours/
year
to
arrive
at
the
annual
emission
rate.
The
following
represents
the
total
emissions
calculated
for
the
telomers
area
of
Chambers
Works
and
Washington
Works:

Chambers
Works
0.9
lbs/
yr
Washington
Works
0.16
lbs/
yr
APPENDIX
B
SCREEN3
MODEL
RUN
B­
1
Appendix
B
SCREEN3
MODEL
OUTPUT
08/
01/
03
13:
17:
07
***
SCREEN3r
MODEL
RUN***
***
VERSION
DATED
96043***

**
WASHINGTON
WORKS
TELOMERS
EMISSIONS
**
0
SIMPLE
TERRAIN
INPUTS:
SOURCE
TYPE
=
POINT
EMISSION
RATE
(
G/
S)
=
.230576E
 
05
STACK
HEIGHT
(
M)
=
25.9080
STK
INSIDE
DIAM
(
M)
=
.4572
STK
EXIT
VELOCITY
(
M/
S)
=
14.3256
STK
GAS
EXIT
TEMP
(
K)
=
293.1500
AMBIENT
AIR
TEMP
(
K)
=
293.0000
RECEPTOR
HEIGHT
(
M)
=
.0000
URBAN/
RURAL
OPTION
=
RURAL
BUILDING
HEIGHT
(
M)
=
29.2608
MIN
HORIZ
BLDG
DIM
(
M)
=
36.5760
MAX
HORIZ
BLDG
DIM
(
M)
=
59.4360
THE
REGULATORY
(
DEFAULT)
MIXING
HEIGHT
OPTION
WAS
SELECTED.
THE
REGULATORY
(
DEFAULT)
ANEMOMETER
HEIGHT
OF
10.0
METERS
WAS
ENTERED.

BUOY.
FLUX
=
.004
M**
4/
S**
3;
MOM.
FLUX
=
10.719
M**
4/
S**
2.

***
FULL
METEOROLOGY
***

**************************************************
***
SCREEN
AUTOMATED
DISTANCES
***
**************************************************

***
TERRAIN
HEIGHT
OF
0.
M
ABOVE
STACK
BASE
USED
FOR
FOLLOWING
DISTANCES
***

DIST
CONC
U10M
USTK
MIX
HT
PLUME
SIGMA
SIGMA
(
M)
(
UG/
M**
3)
STAB
(
M/
S)
(
M/
S)
(
M)
HT
(
M)
Y
(
M)
Z
(
M)
DWASH
10.
.0000
0
.0
.0
.0
.00
.00
.00
NA
100.
.2091E
 
02
6
1.0
1.7
10000.0
26.21
4.07
18.28
SS
200.
.1291E
 
02
6
1.0
1.7
10000.0
26.21
7.73
24.04
SS
300.
.8797E
 
03
6
1.0
1.7
10000.0
26.21
11.23
30.17
SS
400.
.6730E
 
03
6
1.0
1.7
10000.0
26.21
14.64
30.53
SS
500.
.5466E
 
03
6
1.0
1.7
10000.0
26.21
17.97
30.89
SS
600.
.4609E
 
03
6
1.0
1.7
10000.0
26.21
21.24
31.25
SS
700.
.3988E
 
03
6
1.0
1.7
10000.0
26.21
24.46
31.60
SS
800.
.3517E
 
03
6
1.0
1.7
10000.0
26.21
27.63
31.95
SS
900.
.3147E
 
03
6
1.0
1.7
10000.0
26.21
30.78
32.29
SS
1000
.2848E
 
03
6
1.0
1.7
10000.0
26.21
33.88
32.63
SS
1100
.2601E
 
03
6
1.0
1.7
10000.0
26.21
36.96
32.96
B­
2
SS
1200
.2394E
 
03
6
1.0
1.7
1000.0
26.21
40.01
33.29
SS
1300.
.2217E
 
03
6
1.0
1.7
10000.0
26.21
43.04
33.62
SS
1400.
.2065E
 
03
6
1.0
1.7
10000.0
26.21
46.05
33.94
SS
1500.
.1932E
 
03
6
1.0
1.7
10000.0
26.21
49.03
34.26
SS
1600.
.1815E
 
03
6
1.0
1.7
10000.0
26.21
51.99
34.57
SS
1700.
.1711E
 
03
6
1.0
1.7
10000.0
26.21
54.94
34.89
SS
1800
.1618E
 
03
6
1.0
1.7
10000.0
26.21
57.87
35.20
SS
1900
.1534E
 
03
6
1.0
1.7
10000.0
26.21
60.78
35.50
SS
2000
.1459E
 
03
6
1.0
1.7
10000.0
26.21
63.68
35.80
MAXIMUM
1
 
HR
CONCENTRATION
AT
OR
BEYOND
10.
M:
SS
88.
.2254E
 
02
6
1.0
1.7
10000.0
26.21
3.65
17.65
DWASH=
MEANS
NO
CALC
MADE
(
CONC
=
0.0)
DWASH=
NO
MEANS
NO
BUILDING
DOWNWASH
USED
DWASH=
HS
MEANS
HUBER
 
SNYDER
DOWNWASH
USED
DWASH=
SS
MEANS
SCHULMAN
 
SCIRE
DOWNWASH
USED
DWASH=
NA
MEANS
DOWNWASH
NOT
APPLICABLE,
X<
3*
LB
****************************************************
*****
REGULATORY
(
Default)
*****
PERFORMING
CAVITY
CALCULATIONS
WITH
ORIGINAL
SCREEN
CAVITY
MODEL
(
BRODE,
1988)
****************************************************

***
CAVITY
CALCULATION
 
1***
***
CAVITY
CALCULATION
 
2***
CONC
(
UG/
M**
3)
=
.8839E
 
03
CONC
(
UG/
M**
3)
=
.1001E
 
02
CRIT
WS
@
10M
(
M/
S)
=
1.27
CRIT
WS
@
10M
(
M/
S)
=
2.37
CRIT
WS
@
HS
(
M/
S)
=
1.54
CRIT
WS
@
HS
(
M/
S)
=
2.87
DILUTION
WS
(
M/
S)
=
1.00
DILUTION
WS
(
M/
S)
=
1.44
CAVITY
HT
(
M)
=
38.48
CAVITY
HT
(
M)
=
32.60
CAVITY
LENGTH
(
M)
=
67.12
CAVITY
LENGTH
(
M)
=
48.77
ALONGWIND
DIM
(
M)
=
36.58
ALONGWIND
DIM
(
M)
=
59.44
****************************************
END
OF
CAVITY
CALCULATIONS
****************************************
B­
3
***********************************************************
***
SUMMARY
OF
SCREEN
MODEL
RESULTS
***
***********************************************************

CALCULATION
PROCEDURE
MAX
CONC
(
UG/
M**
3)
DIST
TO
MAX
(
M)
TERRIAN
HT
(
M)
SIMPLE
TERRAIN
.2254E
 
02
88.
0.
BLDG.
CAVITY
 
1
.8839E
 
03
67.
 
 
(
DIST
=
CAVITY
LENGTH)
BLDG.
CAVITY
 
2
.1001E
 
02
49.
 
 
(
DIST
=
CAVITY
LENGTH)

*********************************************************************************
**
REMEMBER
TO
INCLUDE
BACKGROUND
CONCENTRATIONS
**
********************************************************************************

Note:
The
off
 
site
concentration
referenced
in
the
report
is
the
concentration
shown
for
simple
terrain.
This
concentration
is
valid
for
receptor
locations
near
the
fenceline
since
this
area
is
relatively
flat.
Although
the
model
predicted
a
building
cavity
concentration
which
is
higher
than
the
predicted
value
for
simple
terrain,
this
concentration
will
occur
on
site
and
is
not
applicable
for
this
analysis.
APPENDIX
C
SITE
ASSESSMENT
PLAN
(
SAP)
TO
ASSESS
PFOA
LEVELS
IN
AIR
AND
WATER
FROM
DUPONT
TELOMER
MANUFACTURING
OPERATIONS
AT
CHAMBERS
WORKS,
DEEPWATER,
NJ
AND
WASHINGTON
WORKS,
PARKERSBURG,
WV
APPENDIX
C
SITE
ASSESSMENT
PLAN
(
SAP)
TO
ASSESS
PFOA
LEVELS
IN
AIR
AND
WATER
FROM
DUPONT
TELOMER
MANUFACTURING
OPERATIONS
AT
CHAMBERS
WORKS,
DEEPWATER,
NJ
AND
WASHINGTON
WORKS,
PARKERSBURG,
WV
Site
Assessment
Plan
(
SAP)
to
Assess
PFOA
Levels
In
Air
and
Water
Table
of
Contents
AppendixC.
doc
Oct.
1,
03
C­
i
Wilmington,
DE
TABLE
OF
CONTENTS
1.0
Introduction............................................................................................................
1
2.0
Chambers
Works....................................................................................................
2
2.1
Air
Quality
Modeling
Protocol
......................................................................
2
2.1.1
Emissions
Inventory
.........................................................................
2
2.1.2
Model
Selection................................................................................
3
2.1.3
Receptor
Selection............................................................................
3
2.1.4
Meteorological
Data
.........................................................................
3
2.1.5
Modeling
Procedures........................................................................
4
2.2
Surface
Water
Sampling
................................................................................
4
2.2.1
Effluent
and
Intake
Sampling
Plan....................................................
4
2.2.2
Delaware
River
Sampling
Plan
.........................................................
5
2.3
Groundwater
Sampling..................................................................................
6
2.4
Field
Procedures............................................................................................
7
2.4.1
Field
Sampling
Preparation
Procedures.............................................
7
2.4.2
Calibration
Procedures......................................................................
8
2.4.3
Field
Procedures...............................................................................
8
2.4.4
Standards..........................................................................................
8
2.4.5
Sampling
Procedures
........................................................................
9
2.5
Quality
Assurance/
Quality
Control
..............................................................
12
2.5.1
Field
Checks...................................................................................
12
2.6
Quality
Control
Sample
Collection
..............................................................
13
2.6.1
Laboratory
Checks..........................................................................
13
2.7
Waste
Handling
...........................................................................................
13
3.0
Washington
Works...............................................................................................
15
Site
Assessment
Plan
(
SAP)
to
Assess
PFOA
Levels
In
Air
and
Water
Introduction
AppendixC.
doc
Oct.
1,
03
C­
1
Wilmington,
DE
1.0
INTRODUCTION
A
Letter
of
Intent
(
LOI)
was
entered
into
between
Telomers
Research
Program
(
TRP)
and
the
United
States
Environmental
Protection
Agency
(
EPA)
on
March
14,
2003
Appendix
1
of
the
LOI
committed
DuPont
Telomer
Manufacturing
Operations
at
Chambers
Works
in
Deepwater,
New
Jersey
and
Washington
Works
in
Parkersburg,
West
Virginia
to
complete
the
following:

 
Develop
site
specific
plans
to
assess
levels
of
PFOA
in
air
and
water
from
manufacturing
operations
around
each
site;
development
of
plans
will
begin
no
later
than
April
14,
2003.

 
Conduct
site­
specific
air
dispersion
modeling
for
applicable
manufacturing
operations,
using
the
EPA­
approved
Industrial
Source
Complex
Short
Term
3
(
ISC3)
model,
as
described
in
EPA's
Guideline
on
Air
Quality
Models
(
40
C.
F.
R.
Part
51,
Appendix
W),
and
assess
the
results
using
the
air
screening
levels
established
in
West
Virginia.

 
Conduct
groundwater
and
surface
water
analyses
at
each
site
and
assess
the
results
using
the
water
screening
levels
established
in
West
Virginia.

 
Use
the
West
Virginia
screening
levels
to
determine
what
additional
actions,
if
any,
may
need
to
be
taken.

The
purpose
of
the
Site
Assessment
Plan
(
SAP)
is
to
meet
the
requirements
in
Appendix
1
of
the
LOI
and
to
provide
a
description
of
the
activities
to
be
conducted
and
the
procedures
that
will
be
followed
for
modeling
and
sampling.
Site
Assessment
Plan
(
SAP)
to
Assess
PFOA
Levels
In
Air
and
Water
Chambers
Works
AppendixC.
doc
Oct.
1,
03
C­
2
Wilmington,
DE
2.0
CHAMBERS
WORKS
2.1
Air
Quality
Modeling
Protocol
The
following
sections
describe
the
dispersion
modeling
methodology
to
be
employed
in
order
to
assess
the
locations
of
maximum
ambient
air
concentrations
resulting
from
PFOA
emissions
at
the
DuPont
Chambers
Works
facility
located
in
Deepwater,
New
Jersey.

2.1.1
Emissions
Inventory
The
following
emission
inventory
information
will
be
assembled
in
order
to
conduct
the
air
quality
modeling:

 
Stack
locations
 
Stack
base
elevations
 
Stack
heights
 
Stack
diameters
 
Stack
gas
exit
temperatures
 
Stack
gas
flow
rate
or
exit
velocities
 
Detailed
plant
layout,
including
all
building
dimensions
(
provided
in
a
scaled
plot
plan)

 
PFOA
emission
rate
The
detailed
plant
layout
is
necessary
to
evaluate
the
building
dimensions
in
the
vicinity
of
each
stack
and
to
identify
the
plant
perimeter
for
defining
the
starting
point
of
the
receptor
grid.

The
following
emission
sources
will
be
evaluated
by
the
dispersion
model:

 
Tenant
operation:
Emission
rates
have
been
estimated
for
model.

 
Telomer
operations:
There
is
considerable
uncertainty
around
PFOA
Telomers
operations.
A
parallel
program
as
part
of
the
overall
LOI
is
evaluating
presence
of
PFOA
and
whether
there
would
be
any
air
emission
sources
from
the
operations.
This
information
is
required
for
the
model.

The
following
sources
are
not
believed
to
have
air
emissions
of
PFOA:

 
WWTP
operations:
TOXCHEM
modeling
analysis
conducted
indicates
that
PFOA
is
not
present
in
significant
quantities
(<
1x10­
5
lbs/
hr)
in
air
emissions
from
the
facility.
Site
Assessment
Plan
(
SAP)
to
Assess
PFOA
Levels
In
Air
and
Water
Chambers
Works
AppendixC.
doc
Oct.
1,
03
C­
3
Wilmington,
DE
2.1.2
Model
Selection
The
area
surrounding
Chambers
Works
is
primarily
non­
urban
as
previously
determined
by
recommended
EPA
classification
procedures.
The
EPA
procedures
classify
land
use
within
3
kilometers
of
the
site
by
the
Auer
method
(
Auer,
1978).
Previous
review
of
U.
S.
Geological
Survey
(
USGS)
maps,
aerial
photographs,
and
site
visits
clearly
indicated
that
the
area
is
over
50%
non­
urban.
The
terrain
immediately
surrounding
the
plant
is
primarily
flat.

The
Industrial
Source
Complex
Short
Term
Model
(
ISC3)
will
be
used
as
the
primary
model
to
estimate
pollutant
concentrations.
ISC3
is
a
steady­
state
Gaussian
model
recommended
by
the
EPA,
included
in
the
Guidelines
on
Air
Quality
Models
(
40
CFR
51,
Appendix
W)
for
modeling
of
pollutant
emissions
from
industrial­
type
sources
subject
to
significant
building
downwash.
Refined
ISC3
modeling
will
be
conducted
using
five
years
of
sequential
hourly
meteorology
from
the
Greater
Wilmington
New
Castle
County
(
NCC)
Airport,
located
in
Wilmington,
DE
as
described
below.

2.1.3
Receptor
Selection
A
Cartesian
grid
of
receptors
will
be
utilized
in
this
modeling
analysis.
This
grid
will
consist
of
receptors
placed
at
200
meter
(
m)
intervals
on
a
grid
extending
a
minimum
distance
of
6
km
from
any
plant
boundary.
The
nearest
residences
to
the
Chambers
Works
site
will
be
covered
by
this
receptor
grid.
All
receptors
will
be
located
outside
the
plant
boundary.

A
Cartesian
receptor
grid
such
as
the
one
described
above
is
considerably
more
dense
than
recommended
by
the
EPA
in
the
Guidelines
on
Air
Quality
Models
(
EPA,
1998)
for
modeling
a
facility
of
this
type.
Additional
discrete
receptors
will
be
placed
at
100
meter
intervals
along
the
plant
boundary.
Although
the
topography
in
the
immediate
vicinity
of
Chambers
Works
is
primarily
flat,
there
is
some
elevated
terrain
to
the
Northwest
of
the
site.
Additional
modeling
will
be
conducted
at
a
dense
grid
of
receptors
in
the
vicinity
of
the
highest
predicted
concentration.
This
dense
grid
will
consist
of
a
1
km
by
1
km
Cartesian
grid
of
receptors
with
100
meter
spacing
between
each
receptor.

2.1.4
Meteorological
Data
The
Chambers
Works
facility
is
located
approximately
9
km
from
the
New
Castle
County
(
NCC)
Airport.
Meteorological
observations
at
the
airport
are
considered
representative
of
the
site
and
of
conditions
affecting
transport
and
dispersion
of
stack
emissions.
Therefore,
five
years
of
hourly
surface
observations
from
the
National
Weather
Service
(
NWS)
station
at
NCC
Airport
will
be
used
in
the
refined
air
quality
dispersion
analysis.

Hourly
meteorological
data
for
the
period
1989­
1993
will
be
used
in
this
study.
Concurrent
twice
daily
upper
air
data
from
the
Dulles
International
Airport
NWS
station
located
in
Sterling,
VA
will
be
used
along
with
NCC
surface
temperatures
to
obtain
hourly
mixing
depths.
Site
Assessment
Plan
(
SAP)
to
Assess
PFOA
Levels
In
Air
and
Water
Chambers
Works
AppendixC.
doc
Oct.
1,
03
C­
4
Wilmington,
DE
2.1.5
Modeling
Procedures
The
most
recent
version
of
ISC3
will
be
used
in
the
air
quality
dispersion
modeling
of
all
receptors.
All
model
options
will
be
set
to
the
EPA
regulatory
default
version
of
ISCS3.
The
model
will
be
run
in
the
rural
mode
since
the
land
area
in
the
immediate
vicinity
of
Chambers
Works
is
more
than
50%
rural.
Any
effects
of
aerodynamic
downwash
caused
by
structures
adjacent
to
the
modeled
stack
will
be
included
in
the
ISCS3
modeling
analysis,
along
with
a
summary
of
the
building
downwash
input
files
(
BPIP).
Air
quality
dispersion
modeling
will
be
conducted
on
an
hour­
by­
hour
basis
using
the
five
years
of
meteorological
data
described
above.
The
results
will
be
summarized
for
annual
averaging
periods.

2.2
Surface
Water
Sampling
DuPont
Chambers
Works
is
located
in
Deepwater,
New
Jersey
at
approximate
Delaware
River
mile
69.
The
Delaware
River
at
river
mile
69
is
tidal,
with
the
salinity
of
the
tidal
river
being
a
function
of
the
freshwater
flows
from
the
Schuyllkill
and
Delaware
Rivers
north
of
Trenton,
New
Jersey.

The
site
has
one
primary
wastewater
outfall
(
DSN001)
and
two
water
intakes.
One
intake
is
on
Salem
Canal
(
freshwater
source)
and
one
intake
is
on
the
Delaware
River
(
brackish
water
source).
The
Salem
Canal
intake
is
approximately
5­
10
mgd
and
the
Delaware
River
water
intake
is
approximately
20
 
30
mgd.

The
surface
water
sampling
program
is
designed
to
assess
at
PFOA
concentrations
in
Salem
Canal
and
the
Delaware
River
adjacent
to
the
plant
using
previous
hydrology
studies
to
assist
with
the
sample
location
planning.

2.2.1
Effluent
and
Intake
Sampling
Plan
Sampling
Location
Description
Outfall
to
Delaware
River
DSN001
Stormwater
run­
off,
WWTP
effluent
and
noncontact
cooling
water.

Delaware
River
Upstream
Sample
Approx.
15
miles
upstream
Chambers
Works
Salem
Canal
Intake
Raw
Water
Intake
Chambers
Works
Delaware
River
Intake
Water
Intake­
non
contact
cooling
and
fire
water
Sample
Type
 
Outfall
samples
48­
hour
composite
samples
(
two
24­
hr
composites
combined)

 
DuPont
Chambers
Works
Delaware
River
Intake,
Salem
Canal
Intake
and
Upstream
Sample
24­
hour
composite
samples
Site
Assessment
Plan
(
SAP)
to
Assess
PFOA
Levels
In
Air
and
Water
Chambers
Works
AppendixC.
doc
Oct.
1,
03
C­
5
Wilmington,
DE
Parameters
to
be
Sampled
Each
sample
collected
will
be
analyzed
for
PFOA
,
total
organic
carbon,
and
total
suspended
solids.

Upstream
Delaware
River
and
Salem
Canal
samples
will
only
be
taken
during
the
first
sampling
event.
Based
on
results
additional
samples
may
be
taken,
as
appropriate.

2.2.2
Delaware
River
Sampling
Plan
Sampling
Locations
DuPont
Chambers
Works
is
located
in
Deepwater,
New
Jersey
approximately
at
Delaware
River
mile
69.
The
Delaware
River
at
river
mile
69
is
tidal
with
the
salinity
of
the
tidal
river
being
a
function
of
the
freshwater
flows
from
the
Schulykill
and
the
Delaware
River
north
of
Trenton,
New
Jersey.

The
tidal
flow
can
reach
up
to
8
to
12
miles
upstream
of
the
facility
depending
on
the
freshwater
flows
from
the
Schulykill
and
northern
Delaware
River
(
non­
tidal).
DuPont
performed
a
low­
flow
and
high­
flow
dye
dispersion
study
and
a
hydrographic
survey
of
the
Delaware
Estuary
in
the
late
1980s.
These
studies
showed
that
the
Delaware
Estuary
is
well
mixed
vertically,
and
that
is
there
is
no
significant
salinity
gradient
within
the
water
column.
It
also
appeared
to
show
elevated
dye
concentrations
near
the
eastern
shore
when
compared
to
the
western
side
of
the
estuary.

Thus,
surface
water
sampling
does
not
need
to
be
taken
at
different
depths
since
the
estuary
is
well
mixed
vertically;
however,
samples
will
need
to
be
taken
over
the
width
of
the
river
to
take
into
account
the
possibility
of
varying
concentrations.

The
Delaware
Estuary
will
be
sampled
upstream
and
downstream
of
DuPont
Chambers
Works
on
an
incoming
and
outgoing
tide.
The
downstream
samples
on
an
outgoing
tide
will
be
½
mile,
1
mile,
4
miles
and
12
miles
downstream
of
Chambers
Works
outfall.
For
the
incoming
tide
the
samples
will
be
taken
at
the
1
mile
and
4
mile
downstream
points.

The
upstream
samples
taken
on
an
incoming
tide
will
be
4
miles
and
13+
miles
upstream
of
the
Chambers
Works
outfall.
The
13+
mile
sample
will
be
outside
the
influence
of
the
Chambers
Works
wastewater
and
will
be
considered
a
background
sample.
Figures
9
to
11
provide
a
general
description
of
the
sampling
locations.

The
Chamber
Works
outfall
001
effluent
will
be
sampled
each
day
(
24­
hr
composite)
for
a
week
prior
to
the
surface
water
sampling.
These
samples
will
be
combined
to
form
a
single
composite
sample
for
analysis.

Sample
Types
All
samples
in
the
estuary
will
be
grabs
and
taken
at
approximately
0.6
to
0.75
of
the
depth
from
the
bottom
of
the
river.
Effluent
samples
will
be
24­
hour
composite
samples.

Parameters
to
be
Sampled
Surface
water
samples
will
be
analyzed
for
PFOA,
specific
conductivity,
and
total
suspended
solids.
The
location
of
each
sample
must
be
recorded
by
GPS.
The
effluent
samples
will
be
analyzed
for
PFOA.
Site
Assessment
Plan
(
SAP)
to
Assess
PFOA
Levels
In
Air
and
Water
Chambers
Works
AppendixC.
doc
Oct.
1,
03
C­
6
Wilmington,
DE
Collection
of
Samples
Prior
to
collection
of
the
samples
the
sampling
team
must
first
divide
the
estuary
width
by
three
for
each
sampling
location.
The
sampling
team
will
then
determine
the
center
of
each
section
for
sampling
location.
All
samples
will
be
grabs
and
taken
at
approximately
0.6
to
0.75
of
the
depth
from
the
bottom
of
the
river
as
shown
in
Figure
1
below.
(
The
symbol
"
o"
represents
the
sampling
location.)

Figure
1
2.3
Groundwater
Sampling
Groundwater
samples
will
be
collected
at
the
five
interceptor
well
locations..
The
data
will
be
used
to
determine
if
PFOA
is
present
in
groundwater
at
Chambers
Works.
The
interceptor
wells
have
been
chosen
as
the
sampling
location
since
the
interceptor
wells
hydraulically
contain
the
groundwater
beneath
the
site.

A
complete
round
of
groundwater
sampling
from
all
five
interceptor
well
locations
will
be
conducted.
The
interceptor
wells
are
known
as:

 
H­
11
 
R­
09
 
K­
06
 
M­
14
 
Q­
13
(
two
wells)
A
total
of
six
samples
will
be
collected
from
interceptor
wells
since
Q­
13
is
actually
two
separate
wells,
screened
in
different
aquifers.
Samples
will
be
collected
from
sample
ports
from
the
discharge
piping
at
each
location.
Interceptor
well
sampling
ports
(
taps)
will
be
changed
out
to
eliminate
PTFE­
tape,
prior
to
groundwater
sampling.

In
addition,
samples
will
be
collected
from
two
existing
B
Aquifer
monitoring
wells
located
near
the
telomers
area.
The
wells
to
be
sampled
are
identified
as:

 
C10­
M01B
 
C08­
M01B
Water
Level
o
o
o
1
2
3
Site
Assessment
Plan
(
SAP)
to
Assess
PFOA
Levels
In
Air
and
Water
Chambers
Works
AppendixC.
doc
Oct.
1,
03
C­
7
Wilmington,
DE
Prior
to
groundwater
sampling
of
the
B
Aquifer
monitoring
wells,
the
depth
to
water
will
be
measured
with
an
electronic
water­
level
probe.
The
probe
will
be
decontaminated
between
wells
by
rinsing
with
methanol
and
distilled
water.

A
low­
flow
(
minimum
drawdown)
groundwater
sampling
procedure
will
be
used
to
purge
monitoring
wells
and
collect
groundwater
samples.
The
groundwater
sampling
procedures
are
summarized
in
Section
2.4.5,
General
Instructions
for
Water
Sampling.
Samples
will
be
submitted
to
the
laboratory
for
analysis.
Quality
assurance/
quality
control
procedures,
described
in
Section
2.5,
will
be
followed
to
ensure
that
the
data
collected
in
the
field
is
both
valid
and
representative
of
the
site
conditions.

2.4
Field
Procedures
2.4.1
Field
Sampling
Preparation
Procedures
To
ensure
that
sampling
activities
are
conducted
correctly
and
safely,
the
following
six
steps
will
be
followed
prior
to
commencing
field
activities:

 
The
project's
quality
assurance
officer
will
notify
the
laboratory
of
the
upcoming
sampling
event
so
that
the
laboratory
can
prepare
the
appropriate
type
and
number
of
sample
containers.
The
anticipated
number
of
samples,
replicate
requirements,
and
the
number
of
extra
bottles
needed
for
quality
control
testing
will
be
specified
to
the
laboratory
manager.

 
The
field
team
will
inspect
all
equipment
to
be
used
during
the
sampling
event.

 
Field
meters
to
be
used
during
sampling
(
i.
e.,
pH,
temperature
probe,
water
level
specific
conductance,
and
dissolved
oxygen
meters)
will
be
checked
to
ensure
proper
calibration
and
precision
response.

 
The
field
sampling
team
and/
or
the
project's
quality
assurance
office
will
assemble
all
forms
to
be
used
in
the
field
[
including
the
field
logbook,
chain­
ofcustody
(
COC)
sheets
and
seals,
and
sample
analysis
request
forms].

 
Bottles
will
be
"
prelabeled"
during
the
mobilization
phase
of
the
sampling
event
to
reduce
confusion
in
the
field.
Certain
information
(
e.
g.,
well
number,
sample
point,
sample
identification
number,
preservative,
and
type
of
parameters)
will
be
affixed
to
the
label
with
permanent
ink
during
pre­
field
activities.
Other
information
(
e.
g.,
sample
time
and
date,
sampler's
name)
will
be
added
to
the
label
only
after
the
sample
is
collected.
A
cross­
reference
to
information
contained
on
the
label
will
be
documented
in
the
field
notebook
and
will
correspond
with
the
well
number
 
Prior
to
sampling,
sampling
personnel
will
review
proper
sampling
protocols.
In
addition,
proper
health
and
safety
protocols
and
the
site­
specific
Health
and
Safety
Plan
will
be
reviewed
prior
to
sampling.

Scheduling
and
coordination
of
the
sampling
team
will
be
completed
prior
to
field
mobilization
and
then
will
be
reviewed
periodically.
Equipment
calibration
and
inspection
will
be
completed
at
least
once
per
day
(
when
the
equipment
is
used).
Review
of
procedures
and
protocols
will
be
completed
as
required.
Site
Assessment
Plan
(
SAP)
to
Assess
PFOA
Levels
In
Air
and
Water
Chambers
Works
AppendixC.
doc
Oct.
1,
03
C­
8
Wilmington,
DE
2.4.2
Calibration
Procedures
Calibration
is
the
process
of
establishing
a
relationship
of
a
measured
output
to
a
known
input
and
provides
a
point
of
reference
to
which
other
sample
analyses
can
be
correlated.
Each
field
instrument
will
be
calibrated
prior
to
its
first
use
each
day.
More
frequent
calibration
will
be
conducted
as
necessary,
based
on
instrument
performance
checks
and
operator
judgment.
All
calibrations
will
be
performed
using
standard
industry
practices
or
equipment
manufacturer
recommendations.

2.4.3
Field
Procedures
Field
meters
used
during
sampling
(
i.
e.,
PID,
pH,
conductivity,
temperature,
dissolved
oxygen,
turbidity,
redox,
and
water
level)
will
be
checked
for
calibration
consistent
with
manufacturer­
recommended
procedures.
Field
instrument
and
equipment
calibration
should
be
conducted
daily.
Where
the
manufacturer
has
not
specified
a
calibration
interval
for
an
instrument,
it
will
be
established
based
on
industry
practice
or
by
the
sampling
team.
Field
equipment
will
be
supplied
and
maintained
by
the
sampling
team.

The
pH
meter
calibration
will
be
checked
by
using
at
least
two
different
buffer
solutions
that
bracket
the
expected
range
of
pH
in
the
wells
to
be
sampled.
The
probe
of
the
meter
and
sampling
cups
will
be
thoroughly
rinsed
with
deionized
water
before
and
after
use.
Additional
calibration
procedure
details
are
described
in
the
manufacturer's
guidelines
for
this
instrument.

The
specific
conductivity
meter
will
be
checked
daily
against
a
laboratory­
prepared
potassium
chloride
(
KCl)
standard
solution.
When
the
meter
exhibits
unacceptable
error
(
greater
than
five
percent),
it
will
be
recalibrated
according
to
the
procedure
defined
in
the
manufacturer's
guidelines
for
this
instrument.
The
probe
of
the
meter
and
the
sampling
cups
will
be
thoroughly
rinsed
with
deionized
water
before
and
after
use.

The
static
water
level
in
a
well
will
be
measured
using
an
electric
water
 
level
indicator.
The
water
level
will
be
measured
from
a
scribed
mark
at
the
top
of
the
steel
or
PVC
well
casing.

A
PID
will
be
used
for
screening
soil
samples
for
health
and
safety
monitoring
in
accordance
with
the
project
HASP.
The
calibration
will
be
in
accordance
with
manufacturer's
specifications.
The
PID
will
be
calibrated
using
a
zero
air
gas
and
appropriate
calibration
indicator
gas.

2.4.4
Standards
For
the
pH
meter,
buffers
will
be
at
pH
4,
pH
7,
and
pH
10.
Two
of
the
three
buffers
will
be
used
to
calibrate
the
meter.
The
third
buffer
will
be
used
for
periodic
calibration
checks.
The
pH
7
buffer
will
always
be
one
of
the
calibration
buffers.
The
buffers
will
be
purchased
from
a
laboratory
chemical
supply
manufacturer,
and
the
exact
pH
will
be
noted
on
a
calibration
form.

For
the
conductivity
meter,
reference
solutions
will
be
in
the
range
of
500
µ
mhos/
cm.
Three
known
reference
solutions
will
be
used
for
each
calibration.
The
median
standard
will
be
used
for
calibration
checks.
For
the
PID,
span
gases
will
be
purchased
from
Site
Assessment
Plan
(
SAP)
to
Assess
PFOA
Levels
In
Air
and
Water
Chambers
Works
AppendixC.
doc
Oct.
1,
03
C­
9
Wilmington,
DE
chemical
suppliers.
These
gases
will
be
in
the
10
to
100
parts
per
million
(
ppm)
range.
Calibration
procedures
for
all
health
and
safety
related
equipment
are
specified
in
the
HASP.

2.4.5
Sampling
Procedures
Samples
collected
during
this
investigation
will
be
analyzed
for
PFOA
and
will
include
groundwater
and
surface
water
samples
taken
from
the
WWTP.

General
Decontamination
Procedures
All
equipment
in
direct
contact
with
the
material
to
be
sampled
will
be
decontaminated
prior
to
sampling
to
prevent
cross­
contamination
of
samples
collected.
In
addition,
care
will
be
taken
so
as
not
to
allow
anything
to
come
into
contact
with
a
sample
or
sample
area,
which
may
affect
its
composition.

Sampling
equipment
will
include
bailers,
tubing,
and
pumps.
All
of
these
items
will
come
in
direct
contact
with
the
sample
and
have
potential
to
impact
analytical
results.
Therefore,
care
will
be
taken
to
ensure
the
cleanliness
of
all
sampling
equipment.
When
possible,
pre­
cleaned
or
disposable
sampling
equipment
will
be
used
(
e.
g.,
bailers
for
sampling
wells).
Field
decontamination
will
be
permitted
for
bailers
and
pumps,
provided
the
following
method
is
applied:

1
Wipe
off
any
residual
sludge
or
water
with
a
Chem­
wipe.

2
Rinse
the
equipment
with
deionized
water.
3
Rinse
the
equipment
with
methanol.

4
Place
in
zip­
sealed
bag
until
the
next
use.
In
addition
to
the
decontamination
procedures
outlined
above,
the
person
collecting
the
sample
will
wear
clean
latex
or
nitrile
disposable
lab
or
exam
gloves
and
will
limit
his/
her
contact
with
the
samples.
Sample
bottles
and
containers
will
be
prepared
by
the
contracted
laboratory
and
will
be
sealed
to
ensure
cleanliness.
Sample
bottles
will
not
be
cleaned
in
the
field.

A
personnel
decontamination
area
will
be
set
up
at
each
sample
location
prior
to
starting
sampling
activities.
Procedures
for
the
decontamination
of
protective
equipment
and
the
removal
of
respiratory
and
personal
protection
clothing
to
avoid
transfer
of
constituents
from
clothing
to
the
body
are
discussed
in
the
HASP.
To
the
extent
that
it
is
economically
feasible
and
technically
acceptable,
disposable
personal
protective
equipment
(
PPE)
will
be
used.
Where
the
work
scope
restricts
use
of
disposable
PPE,
decontamination
facilities
will
be
provided.

General
Instructions
for
Water
Sampling
Water
sample
bottles
will
not
be
pre­
rinsed
with
site
water
prior
to
sample
collection.
Gloves
will
be
worn
during
sampling
activities
and
replaced
between
samples.
All
samples
will
be
held
chilled
to
approximately
4oC
(
not
frozen
to
6oC)
with
wet
ice
from
collection
to
shipping.

In
order
to
minimize
the
possibility
of
introducing
PFOA­
contamination
into
samples,
the
following
protocol
will
be
followed:
Site
Assessment
Plan
(
SAP)
to
Assess
PFOA
Levels
In
Air
and
Water
Chambers
Works
AppendixC.
doc
Oct.
1,
03
C­
10
Wilmington,
DE
 
Avoid
polytetrafluoroethylene
(
PTFE).

 
Avoid
aluminum
foil.

 
Do
not
use
self­
stick
memo
notes.

 
Avoid
blue
ice.

 
Avoid
pre­
wrapped
foods
or
snacks.

 
Wear
clothing
that
has
been
washed
at
least
six
times
 
Use
only
containers
supplied
by
contract
laboratory.
The
field
team
leader
or
a
senior
member
of
the
field
team
will
be
responsible
for
water
sampling
and
laboratory
coordination.
The
laboratory
will
provide
necessary
sample
containers
with
the
shipping
containers
(
i.
e.,
shuttles).
Containers
and
any
preservative
added
to
the
containers
will
be
in
accordance
with
EPA
document
SW­
846
protocol.
All
samples
requiring
refrigeration
will
be
shipped
at
approximately
4
°
C
(
not
frozen
to
6oC).

Field
equipment
will
consist
of
some
or
all
of
the
following:

 
Polyethylene
collection
bottles
(
laboratory
provided)

 
Field
sampling
record
 
Sufficient
ice
to
maintain
the
samples
at
approximately
4
°
C
(
not
frozen
to
6oC)

 
Methanol
and
deionized/
distilled
water
 
Conductivity
meter,
pH
meter,
temperature
probe,
redox
probe,
dissolved
oxygen
probe,
and
turbidity
meter
 
Glass
beakers
 
PID
and/
or
FID
for
organic
vapor
analysis
 
Pumps
and/
or
bailers
for
purging
 
Rope
 
Stainless­
steel
or
polypropylene
leader
to
attach
rope
to
sampling
device
 
Bailers
or
other
sampling
devices
(
preferably
dedicated
or
pre­
cleaned)
Preparing
for
sampling
includes
acquiring
all
of
the
necessary
monitoring
equipment
listed
above
and
site­
specific
information
to
perform
the
required
monitoring.

Groundwater
Sampling
Groundwater
will
be
sampled
from
monitoring
wells
and
interceptor
(
pumping)
wells
at
the
facility.
Prior
to
initiating
sampling
activities
at
a
given
location
a
complete
round
of
depth
to
water
levels
will
be
measured
to
the
nearest
one
hundredth
of
a
foot.

Prior
to
sample
acquisition,
monitoring
wells
will
be
purged
using
a
low
flow
protocol.
The
low­
flow
pump
will
be
lowered
gently
and
set
at
approximately
the
middle
of
the
screen.
If
the
static
water
level
is
below
the
top
of
the
screen,
then
the
pump
will
be
lowered
to
the
middle
of
the
water
column.
In
either
case,
the
pump
intake
will
be
placed
a
sufficient
distance
above
the
bottom
of
the
well
to
avoid
mobilization
of
any
Site
Assessment
Plan
(
SAP)
to
Assess
PFOA
Levels
In
Air
and
Water
Chambers
Works
AppendixC.
doc
Oct.
1,
03
C­
11
Wilmington,
DE
accumulated
sediment.
Well
purging
will
begin
at
a
rate
of
0.2
to
0.5
L/
min.
Water
level
in
the
well
will
be
monitored
during
purging,
and
the
purge
rate
will
be
lowered,
if
possible,
if
well
drawdown
is
noted.

During
low
flow
purging,
pH,
specific
conductance,
dissolved
oxygen
(
DO),
oxidationreduction
potential
(
Eh),
temperature,
and
turbidity
will
be
monitored
using
a
flow
through
cell.
Purging
is
complete
when
all
field
parameters
have
stabilized
(
variations
in
values
are
within
10
percent
of
each
other
for
three
consecutive
readings
taken
3
to
5
minutes
apart).
Once
field
parameters
have
stabilized,
samples
will
be
collected
directly
from
the
end
of
the
discharge
tube.

Alternatively,
if
low
flow
purging
is
not
practical
due
to
field
conditions,
monitoring
wells
will
be
evacuated
to
a
minimum
of
3
volumes
of
water
standing
in
the
well
casing.
The
depth
of
the
purge
pump
intake
will
depend
on
well
yields.
The
ideal
intake
will
be
at
the
static
water
level
in
the
well.
The
pump
intake
will
be
adjusted
as
the
water
level
responds
to
pumping.
Shallow
wells,
where
the
screened
interval
extends
above
the
water
table
and
cannot
be
purged
of
three
well
volumes
due
to
slow
recovery
rates,
will
be
pumped
dry
and
allowed
to
recover
before
sampling.
The
water
level
in
deeper
wells
will
be
pumped
to
just
above
the
screened
interval
and
will
be
allowed
to
recover
before
sampling.
If
standard
purge
protocols
are
to
be
used,
measurements
of
pH
and
specific
conductance
will
be
collected
during
well
purging,
and
well
evacuation
will
stop
when
at
least
3
volumes
are
evacuated
and
three
consecutive
readings
of
pH
and
specific
conductance
have
stabilized
within
10
percent.

Pre­
cleaned
or
dedicated,
1
¼
­
inch­
diameter
bottom­
loading
bailers
will
be
used
to
collect
grab
groundwater
samples
for
transfer
into
the
proper
sample
containers
if
standard
purge
protocols
are
used.
Monofilament
polypropylene
or
stainless
steel
wire
leaders
attached
to
nylon
or
polypropylene
rope
will
be
used
to
raise
and
lower
the
bailer.
The
bailer
will
be
lowered
to
the
screened
interval
for
sample
collection.
If
well
yields
are
low
at
the
site,
the
samples
will
be
collected
at
or
near
the
screen
as
the
well
recovers
and
provides
a
sufficient
volume
for
sample
collection.
Each
of
the
wells
exhibiting
suitable
recovery
will
be
sampled
within
two
hours
of
evacuation.

Sample
containers
will
be
filled
to
at
least
the
container
shoulder.
After
the
sample
containers
are
filled,
they
will
be
labeled
appropriately
and
placed
in
a
sample
shuttle
containing
ice
or
ice
packs.
Samples
requiring
refrigeration
for
preservation
will
be
stored
at
approximately
4
°
C
(
not
frozen
to
6
°
C)
during
storage
and
shipment.

The
following
procedure
will
be
followed
during
groundwater
sampling:
1
Wipe
the
exterior
of
the
sampling
bottle
using
a
Chem­
wipe
moistened
with
methanol.

2
Remove
the
bottle
cap,
wipe
the
bottle
lip
using
a
Chem­
wipe
moistened
with
methanol,
and
fill
from
the
bailer
or
hose.
Do
not
use
a
secondary
container
to
fill
the
bottle.
3
Recap
the
sample
bottle.
4
Wipe
the
bottle
using
a
Chem­
wipe
moistened
with
methanol
and
affix
a
sample
label.
Site
Assessment
Plan
(
SAP)
to
Assess
PFOA
Levels
In
Air
and
Water
Chambers
Works
AppendixC.
doc
Oct.
1,
03
C­
12
Wilmington,
DE
5
Place
the
sample
in
a
cooler
of
ice.
6
Complete
the
chain­
of
custody
form.

WWTP/
Surface
Water
Sampling
The
following
procedure
will
be
followed
during
surface
water
sampling:
1
Wipe
the
exterior
of
the
sampling
bottle
using
a
Chem­
wipe
moistened
with
methanol.

2
Submerge
the
sample
bottle
below
the
water
surface
and
unscrew
the
bottle
cap.
3
Fill
the
water
bottle
by
turning
the
bottle
parallel
to
the
water
surface
and
slowly
rotating
so
that
the
mouth
of
the
bottle
is
up
right.
This
procedure
will
ensure
that
water
from
the
surface
microlayer
is
not
pulled
into
the
sample
bottle.

4
Recap
the
sample
bottle
under
water.
5
Wipe
the
bottle
using
a
Chem­
wipe
moistened
with
methanol
and
affix
a
sample
label.

6
Place
the
sample
in
a
cooler
of
ice.

7
Complete
the
chain­
of
custody
form.
Disposable
Equipment
All
disposable
equipment
and
other
materials
that
are
not
decontaminated
for
reuse
will
be
disposed
of
in
an
acceptable
manner.

2.5
Quality
Assurance/
Quality
Control
Quality
assurance/
quality
control
(
QA/
QC)
procedures
will
be
performed
to
ensure
that
the
data
collected
is
both
valid
and
representative
of
the
site
conditions.
Quality
assurance/
quality
control
(
QA/
QC)
procedures
are
summarized
below.

2.5.1
Field
Checks
Selected
field
activities
that
are
performed
that
incorporate
QA/
QC
checks
include
the
following:

 
Using
standardized
data
collection
formats
 
Calibrating
field
equipment
 
Collecting
duplicate
samples
and
field
blanks
 
Conducting
field
audits
Field
equipment
will
be
calibrated
prior
to
use
in
accordance
with
the
standardized
procedures
contained
in
the
equipment
manual.

Field
and
laboratory
audits
may
be
performed
by
the
QA
officer
(
or
his/
her
designee)
to
confirm
that
proper
protocols
and
procedures
are
being
employed.
Site
Assessment
Plan
(
SAP)
to
Assess
PFOA
Levels
In
Air
and
Water
Chambers
Works
AppendixC.
doc
Oct.
1,
03
C­
13
Wilmington,
DE
2.6
Quality
Control
Sample
Collection
Duplicate
groundwater
and/
or
surface
water
samples
will
be
collected
by
alternately
filling
sample
containers
from
the
same
sampling
device
for
each
parameter.
Field
duplicates
will
be
collected
at
a
minimum
rate
of
1
per
20
field
samples.
A
greater
frequency
can
be
selected
in
order
to
verify
laboratory
and
field
performance.
Blind
duplicate
samples
will
be
collected
at
one
or
more
well
locations
and
coded
so
that
only
the
sampling
team
knows
the
exact
location
of
the
sample
collection.

Equipment
blanks
(
also
called
rinsate
blanks)
will
be
used
to
evaluate
equipment
cleaning
or
decontamination
procedures.
At
the
sample
location,
analyte­
free
water
or
deionized
water
will
be
poured
over
or
through
the
sample
collection
device,
collected
in
a
sample
container,
and
preserved
as
appropriate.
A
minimum
of
one
equipment
blank
per
day
will
be
collected.

All
blanks
will
be
handled,
transported,
and
analyzed
in
the
same
manner
as
actual
field
samples.
Blanks
will
be
held
on­
site
for
the
minimum
number
of
days.
The
temperature
of
the
blanks
will
be
maintained
at
approximately
4
°
C
while
on­
site
and
during
shipment.

2.6.1
Laboratory
Checks
Periodic
audits
of
the
analytical
laboratory
may
be
performed
by
the
project
QA
officer
(
or
his/
her
designee)
to
confirm
that
proper
analytical
protocols
are
being
followed
concerning
sample
analysis
and
laboratory
QC
checks.

2.7
Waste
Handling
Waste
management
procedures
are
summarized
below.
Each
waste
produced
during
the
sampling
program
will
be
characterized
and
classified
so
that
disposal
options
can
be
determined.
The
typical
wastes
that
will
be
generated
and
managed
during
investigation
activities
include
the
following:

 
Water
from
purging
and
development
of
monitoring
wells
 
Water
from
decontaminating
sampling
equipment
 
Disposable
sampling
equipment
 
Disposable
PPE
Classification
of
the
wastes
generated
during
the
program
will
be
dependant
on
the
source
of
the
waste
and,
when
applicable,
the
classification
of
the
wastes
contained
in
the
nearest
land
disposal
unit.
All
waste
not
classified
at
the
time
of
the
field
investigation
will
be
placed
in
containers
labeled
and
managed
in
accordance
with
state
and
federal
regulation.
PPE
and
disposable
sampling
equipment
wastes
that
do
not
come
into
contact
with
materials
contained
within
SWMUs
will
be
classified
as
nonhazardous
wastes.
All
groundwater
and
decontamination
cleaning
waters
will
be
containerized.
Site
Assessment
Plan
(
SAP)
to
Assess
PFOA
Levels
In
Air
and
Water
Chambers
Works
AppendixC.
doc
Oct.
1,
03
C­
14
Wilmington,
DE
Once
characterized,
wastes
will
be
classified
as
uncontaminated,
nonhazardous,
or
hazardous.
Waste
containers
will
be
labeled
to
indicate
classification.
Wastes
will
be
disposed
of
according
to
applicable
federal
and
state
regulations.
Site
Assessment
Plan
(
SAP)
to
Assess
PFOA
Levels
In
Air
and
Water
Washington
Works
AppendixC.
doc
Oct.
1,
03
C­
15
Wilmington,
DE
3.0
WASHINGTON
WORKS
Washington
Works
has
completed
thorough
assessments
of
surface
water
and
groundwater
around
the
site.
Air
modeling
was
conducted
for
areas
that
are
known
sources
of
PFOA.
However,
there
is
considerable
uncertainty
around
the
presence
of
PFOA
in
telomer
manufacturing
operations.
The
LOI
includes
a
commitment
to
assess
whether
PFOA
is
in
the
telomer
process,
and
if
found,
at
what
levels
and
what
are
the
emission
rates.

Once
this
information
is
determined,
the
data
will
be
compared
with
existing
surface
water
and
groundwater
sampling
results
and
using
the
West
Virginia
Screening
levels,
determine
if
additional
sampling
is
needed.
The
data
will
also
be
compared
to
inputs
for
the
Washington
Works
air
dispersion
assessments
for
PFOA
and
the
West
Virginia
Screening
levels.
If
the
data
indicate
that
further
evaluation
is
needed,
the
models
will
be
rerun
to
include
telomers
operations
at
Washington
Works.
