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I I 1 Final Work Plan-Voiumo I Phas* Remedial kivaatlgal FMaMtty ~ DuponMtowpOJ Newport, ftoi Fabmary j Prepared fon \ E. 1.du Pont de Nemours & Co., Inc. , Brandywfne Building 3 WHmfngton, Ddawor* 19898 1 Pr«par«d by: | W o o d w a r d - C ! y d « Consultants 5120 Bultsr Pfk« Plymouth M«etfng, Pennsylyanfa 19462 I . ftR|(|650? 1 Woodward-Clyde Consultants ConwItlne EflflirtMra. 0«oteg««t« and EnvkennMntal

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Page 1: Final Work Plan-Voiumo I Phas* • Remedial kivaatlgal ... · Re: Final Work Plan - Volume 1 Phase HI RI/FS, Du Font-Newport Site Newport, Delaware Dear Mr. Karmazyn: The referenced

II1

Final Work Plan-Voiumo IPhas* • Remedial kivaatlgal

FMaMtty ~DuponMtowpOJNewport, ftoiFabmary j

Prepared fon\ •

E. 1. du Pont de Nemours & Co., Inc., Brandywfne Building3 WHmfngton, Ddawor* 19898

1 Pr«par«d by:

| W o o d w a r d - C ! y d « Consultants5120 Bultsr Pfk«

Plymouth M«etfng, Pennsylyanfa 19462

I. ftR|(|650?1 Woodward-Clyde Consultants

ConwItlne EflflirtMra. 0«oteg««t« and EnvkennMntal

Page 2: Final Work Plan-Voiumo I Phas* • Remedial kivaatlgal ... · Re: Final Work Plan - Volume 1 Phase HI RI/FS, Du Font-Newport Site Newport, Delaware Dear Mr. Karmazyn: The referenced

MS0 Woodward-Clyde ConsultantsPennsylvania 19462215-825-3000 .-Fax 215-834-0234

February 14, 199188C2076-4U

Mr. Randy SturgeonEnforcement Project ManagerU.S. Environmental Protection AgencyRegion HI, 841 Chestnut StreetPhiladelphia, PA 19107

Re: Final Work Plan - Volume IPhase III RI/FS, Du Pont-Newport SiteNewport, Delaware

Gentlemen:

On behalf of Du Pont, Woodward-Clyde Consultants (WCC) is pleased to submit on schedulesix copies of the Final Phase III Remedial Investigation/Feasibility Study (RI/FS) Work Plan -Volume I for the Newport Site. Du Pont and WCC believe that the work tasks describedherein satisfy all of EPA's requests for the Phase HI RI data. Because the schedule forcompletion of the RI/FS process at the Site is currently under negotiation between Du Pontand the EPA, it will be forwarded to the EPA under separate cover after an agreement isreached.

Please contact either the Du Pont or WCC Project Manager if you have any questions.

Very truly yours,

WOOPWARD-CLYDE CONSULTANTS

JMes P. Buczala'Assistant Project Geok

Rog«r T. Gresh, P.O.Project Managercc: K. Kalbacher, Delaware DNREC

J. Karmazyn, Du PontF. Hannigan, Ciba-GeigyC. Trmal, Du PontA. Hirsch, WCC

AR-306508WorkPlan/Phase III/DPN2 . 2/14/91

Revision 0Consulting Engineers. Geologistsand Environmental Scientists

Paper Offices in Other Principal Cities

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5120 Butier pike Woodward-Clyde ConsultantsPlymouth MeetingPennsylvania 19462215-825-3000Fax 215-834-0234

February 14, 199188C2076-4U

Mr. Joel KarmazynDu Pont Environmental Remediation Services300 Bellevue Parkway, Suite 390Wilmington, Delaware 19809

Re: Final Work Plan - Volume 1Phase HI RI/FS, Du Font-Newport SiteNewport, Delaware

Dear Mr. Karmazyn:

The referenced Work Plan, dated February 5, 1991, was prepared by Mr. James Buczala andthe undersigned. This document has been peer reviewed in keeping with Woodward-ClydeConsultants (WCC) Corporate Quality Assurance policy. Besides overseeing all of the PhaseIII design and field work, I have also personally reviewed the contents with regard to thehydrogeologic information obtained and reported in previous reports by WCC for the NewportSite. The interpretations and judgements herein, in my opinion, are consistent with thestandards of technical practice for these services.

Thank you for your continuing confidence in Woodward-Clyde Consultants.

Very truly yours,

WOODWARD-CLYDE CONSULTANTS

Roger T. Gresh, P.O.Senior Project HydrogeologistDelaware RegisteredProfessional Geologist No. 452

RTG/kcs/DPN2

cc: K. Kalbacher, Delaware DNRECC. Trmal, Du PontA. Hirsch, WCC

WoricPlan/Phase HI/DPN2Revision 0

Consulting Engineers, Geologistsand Environmental Scientists

Paper Offices in Other Principal Cities

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Woodward-Clyde ConsultantsPennsylvania 19462215-825-3000Fax 215-834-0234

February 5, 199188C2076-4U

Mr, Joel KarmazynDu Pont Environmental Remediation Services300 Bellevue Parkway, Suite 390Wilmington, Delaware 19809

Re: Final Work Plan - Volume 1Phase III RI/FS, Du Font-Newport SiteNewport, Delaware

Dear Mr. Karmazyn:

Enclosed please find two copies of the referenced document submitted for review byDu Pont and Ciba-Geigy Corporation prior to submittal to the EPA. Based on thediscussions between Du Pont and Woodward-Clyde Consultants, we believe this FinalWork Plan satisfies EPA's request for a Phase III Remedial Investigation at the NewportSite.

Following any revisions based on Du Font's or Ciba-Geigy's final review, we plan tosubmit this document to the EPA by February 14, 1991 in accordance with the tentativeDu Pont-EPA schedule. If you have any questions regarding this plan, please do nothesitate to call.

Very truly yours,

WOODWARP-CLYDEJCONSULTANTS

les P. BuczalaAssistantProject Geologist

R6ge/T. Gresh, P.G.Project ManagerJPB/RTG/kcs/DPN2encl.cc: F. Hannigan, Ciba-Geigy

C. Trmal, Du PontA. Hirsch, WCC

WorkPlan/Phase III/DPN2 $ & 3 0 6 5 I 0 2/5/91** • Revision 0

Consulting Engineers. Geologists"and Environmental Scientists

Offices .n Other Principal Cit;es ! "" „ ~". _. " - - ••

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FINAL WORK PLAN - VOLUME 1

PHASE III REMEDIAL INVESTIGATION/FEASIBILITY STUDY

DU FONT-NEWPORT SITE

NEWPORT, DELAWARE

Prepared forE.I. Du Pont de Nemours & Co., Inc.

Brandywine BuildingWilmington, Delaware 19898

Prepared byWoodward-Clyde Consultants

5120 Butler PikePlymouth Meeting, Pennsylvania 19462

Project Number 88C2076-4U

February 5, 1991

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Woodward'Clyde Consultants

TABLE OF CONTENTS

Section Page

EXECUTIVE SUMMARY ES-1

1.0 INTRODUCTION 1-1

1.1 DESCRIPTION OF PRESENT SITUATION 1-2

2.0 SITE INVESTIGATION 2-1

2.1 DRILLING PROGRAM 2-1

2.1.1 Drilling Locations 2-22.1.2 Pilot Holes 2-72.1.3 Monitoring Well Installation/Methods 2-9

2.1.3.1 Types B and C PotomacFormation Wells 2-9

2.1.3.2 Type A (Shallow Zone)and Type F (Fill Zone)Wells 2-12

2.1.4 Soil Borings 2-142.1.5 Soil Sampling 2-142.1.6 Miscellaneous Items 2-16

2.2 GROUNDWATER SAMPLING 2-182.3 SUPPLEMENTAL WETLANDS INVESTIGATION 2-20

2.3.1 Surface Water Chemistry 2232.3.2 Sediment Chemistry and

Physical Parameters 2-242.3.3 Sediment Toxicity Testing 2-262.3.4 Benthic Community Surveys 2-272.3.5 Vegetation Bioaccumulation 2-282.3.6 Fish Tissue Analyses 2-292.3.7 Technical Data Report 2-30

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TABLE OF CONTENTS (Continued)

Section Page

3.0 SITE INVESTIGATION ANALYSES 3-1

4.0 REMEDIAL INVESTIGATION REPORT 4-1

5.0 FEASIBILITY STUDY 5-1

6.0 DATA MANAGEMENT 6-1

7.0 SCHEDULE, REPORTING, DOCUMENT CONTROLAND PROJECT MANAGEMENT 7-1

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TABLE OF CONTENTS (Continued)

LIST OF TABLES

TABLE 1 SOIL SAMPLING SUMMARY

TABLE 2 GROUND WATER SEEPAGE SAMPLING SUMMARY

TABLE 3 SAMPLING PLAN, SUPPLEMENTAL PHASE HIWETLANDS INVESTIGATION

TABLE 4 WETLANDS LABORATORY ANALYSES

TABLE 5 RI/FS SCHEDULE

LIST OF FIGURES

FIGURE 1 MONITORING WELL LOCATION PLAN

FIGURE 2 MONITORING WELL AND BORING LOCATIONPLAN, CIBA-GEIGY PLANT

FIGURE 3 MONITORING WELL AND BORING LOCATIONPLAN, HOLLY RUN PLANT

FIGURE 4 WELL CONSTRUCTION DIAGRAM TYPE I WELL

FIGURE 5 WELL CONSTRUCTION DIAGRAM TYPE H WELL

FIGURE 6 GROUNDWATER SEEPAGE SAMPLING POINTS

FIGURE 7 SEDIMENT SAMPLING STATIONS, CHRISTINA RIVER

FIGURES WETLANDS SAMPLING STATIONS

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TABLE OF CONTENTS (Continued)

LIST OF APPENDICES

APPENDIX A PHASE III SAMPLING OF GROUNDWATERMONITORING WELLS, NEWPORT SITE WORK PLAN

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EXECUTIVE SUMMARY

This Final Work Plan has been prepared in general accordance with the guidelinesprovided in the "EPA Guidance for Conducting Remedial Investigations and FeasibilityStudies under CERCLA, October 1988" and reflects the emphasis and provisions of theSuperfund Amendments and Reauthorization Act of 1986.

The primary purpose of this Final Work Plan - Volume I is to describe the third phaseof field investigation (Phase III) recently completed for the RemedialInvestigation/Feasibility Study (RI/FS) at the Du Font-Newport Superfund (NationalPriorities List) Site (Site). Some supplemental Phase III RI work tasks are currentlyunder consideration by Du Pont and the EPA. If additional tasks are agreed upon, theywill be documented in a Final Work Plan - Volume II.

The Phase III RI was initially requested by the EPA on March 8, 1990 and modified bysubsequent agreements between Du Pont and the EPA. This approach, whereinprogram modifications were agreed upon by Du Pont and the EPA while work was inprogress, expedited completion of the Phase III RI. The work tasks for the Phase III RIapply to the Ciba-Geigy Newport Plant area and the Du Pont Holly Run Plant areawhich border the North Disposal site. These work tasks also apply to all the potentiallyimpacted groundwater, the associated wetlands, and the associated segment of theChristina River.

The scope of work included: well installations at locations in the Ciba-Geigy and HollyRun Plant areas and other locations around the perimeter of the Site; the collection andanalysis of soil samples in the Ciba-Geigy and Holly Run Plant areas; the collection andanalysis of groundwater samples from all of the previously existing and Phase HImonitoring wells plus four privately owned wells along Old Airport Road southwest ofthe Site; the collection and analysis of groundwater samples from groundwater seepsalong the north bank of the Christina River at the Site; and a Supplemental Phase IE

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Wetlands Investigation in response to the EPA's March 29, 1990 review comments onthe initial Phase III wetlands program.

All data and information evaluations will be submitted to the EPA as a Phase III RIData Sufficiency Report. A Risk Assessment, a Remedial Investigation Report, and aFeasibility Study will also be prepared and submitted to the EPA. Assuming thespecified contingencies are met, the RI/FS program will follow the enclosed calendarschedule.

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1.0INTRODUCTION

This Final Work Plan has been prepared in general accordance with the guidelinesprovided in the "EPA Guidance for Conducting Remedial Investigations and FeasibilityStudies under CERCLA, October 1988" and reflects the emphasis and provisions of theSuperfund Amendments and Reauthorization Act of 1986. All utilization of "the EPA"in this document refers to the United States Environmental Protection Agency, RegionIII Superfund Branch.

The primary purpose of this Final Work Plan - Volume I is to describe the third phaseof field investigation (Phase III) conducted between June 1990 and November 1990 forthe Remedial Investigation/Feasibility Study (RI/FS) at the Du Pont-Newport Superfund(National Priorities List) Site (Site). In addition, this Final Work Plan provides aschedule for completion of the RI/FS process for the Site. Some supplemental PhaseIII RI work items are currently under consideration by Du Pont and the EPA. Ifadditional tasks are agreed upon, the plans for their execution will be documented in aFinal Work Plan - Volume II.

This Phase III RI was initially requested by the EPA in a letter dated March 8, 1990.The work tasks for the Phase III RI apply to: the Ciba-Geigy Newport Plant area andthe Du Pont Holly Run Plant area, which border the North Disposal site; all thepotentially impacted ground water; the associated wetlands; and the associated segmentof the Christina River.

Modifications to the initial work scope were agreed upon by Du Pont and the EPA bothbefore the Phase III RI field tasks were initiated and at several points in time duringimplementation. The unapproved Draft Work Plan (WCC, April 12, 1990) provided abasis for the Phase III RI work scope, but was subject to on-going revision by the EPAand Du Pont during the Phase III efforts and thus served as a living document. Thisapproach expedited completion of the Phase III RI.

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The scope of work for this phase of the investigation included: 30 well installations atthe Ciba-Geigy and Holly Run Plant areas and 12 well installations around the perimeterof the Site; the collection and analysis of soil samples from 25 borings at the Ciba-Geigyand Holly Run Plant areas; the collection and analysis of groundwater samples from 42 uof the 44 pre-Phase III and all of the 42 Phase III monitoring wells plus(tour private ' *~owned wells along Old Airport Road southwest of the Site; the collection and analysis u_' _u.of groundwater from 12 seepage points identified along the north bank of the ChristinaRiver; and a Supplemental Phase III Wetlands Investigation in response to the EPA'sMarch 29, 1990 review comments on the initial Phase III wetlands program.

The Newport Site Quality Assurance Project Plan (QAPP, WCC, July 1988), the Healthand Safety Plan (HASP; WCC, June 1987), and subsequent document submittals withrespect to these Plans were followed during this phase of the investigation, except asnoted in this report, and are provided by reference only. In addition, the work presentedin this Plan was performed in accordance with agreements made in numerouscorrespondence between the EPA and Du Pont during the program.

1.1 DESCRIPTION OF PRESENT SITUATION

Two phases of the RI were performed prior to Phase HI for the entire Site along withthree phases of wetlands investigation. The information collected and analyzed duringthese earlier phases was presented to the EPA in the following documents:

Phase II RI/FS Work Plan (Phase II), Du Font-Newport Site, (WCC, July28, 1988)

Wetlands Investigation, Du Font-Newport Site, (WCC, March 23, 1989)

Data Sufficiency Memorandum, Rl-Phase II, Du Pont-Newport Site(WCC, April 27, 1989)

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Data Sufficiency Supplement, Rl-Phase II, Du Pont-Newport Site (WCC,November 8, 1989)

Phase III Wetlands Investigation, Du Pont-Newport Site (WCC, January19, 1990)

Phase III of the RI was designed to provide the additional data requested by EPA tosupplement data previously collected during the first two phases. The EPA requestedthat monitoring wells be installed at select locations outside the perimeter of the Site todefine better the hydraulic gradients and chemical quality of the groundwater off-site.To investigate potential sources related to site-specific parameters (e.g., barium,cadmium, zinc, tetrachloroethylene and trichloroethylene) monitoring wells and boringswere installed at the Ciba-Geigy Newport Plant and Du Pont Holly Run Plant areas.

The EPA also requested additional data collection and evaluation in order tosupplement the Phase III Wetlands Investigation. Therefore, the Phase III RI includedthe collection of data in the wetlands near the North Disposal site and in the ChristinaRiver. Chemical analyses and toxicity testing were performed on the sediment samples.Representative vegetation was evaluated for bioaccumulation of heavy metals. Fish werecollected for tissue analyses of heavy metals and other parameters.

To facilitate the investigation of the Site and surrounding areas, the EPA divided theSite area into two operable units (OU's). OU I encompasses the two landfills only(North Disposal site and South Disposal site). OU II involves all the remaining Sitearea, including the Ciba-Geigy and Holly Run Plant areas, the potentially impactedgroundwater, the associated wetlands, and the associated segment of the Christina River.Besides consideration being given to supplemental Phase IE field tasks, Du Pont and theEPA are also discussing the possible return of the Newport Site area into one OU. ThisFinal Work Plan has been prepared with the expectation that the EPA will agree to treator address the Newport Site area as one OU.

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2.0SITE INVESTIGATION

As requested by the EPA, the Site area is currently divided into the two OUs describedin Section 1.1. No additional data collection was requested for OU I. Thus, the PhaseIII RI work tasks apply only to OU II. The Phase III investigation included: installationof 42 monitoring wells into four vertical zones; drilling of 25 soil borings in the Ciba-Geigy and Holly Run Plant areas; collection of soil samples from these borings forchemical analyses; and the collection of groundwater samples for chemical analyses fromthe 84 monitoring wells and 12 groundwater seepage points along the bank of theChristina River. The purpose of these tasks was to better define the lateral extent ofpotential groundwater contamination and to obtain soils and groundwater data in thevicinity of, and immediately downgradient of, three centralized areas of historic (andsome present day) manufacturing operations.

2.1 DRILLING PROGRAM

Both hollow-stem augers and mud rotary drilling methods were used during the drillingprogram. The program was broken into three parts: pilot holes; soil borings andmonitoring well installation. a// . //

Vt

Three-to five-inch diameter mud rotary pilot holes/were drilled at each of the wellcluster locations to collect soil samples (forxanalytical and lithologic descriptionpurposes) and to conduct downhole geepltysicaTToggin . The data gathered from eachpilot hole was used to select screen intervals fortberwells at that cluster location and todetermine whether a permeable and HyTiraulically independent deep zone existed.

While data from the pilot holes were being reviewed, 23 soil borings were advanced tothe top of the Potomac Formation and 2 soil borings were advanced to the base of thefill material in the Ciba-Geigy and Holly Run Plant areas for the collection of soilsamples for analytical and lithologic description purposes.

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Forty-two monitoring wells were installed during Phase III field investigations. Thirty-one wells were installed at 11 well cluster locations. In addition, eight single shallowwells were installed and three shallow wells were added to pre-Phase III well clusters.The screened interval for each well within a given well cluster was selected on the basisof the soil samples and geophysical data collected from the pilot holes. The screenedinterval for each single shallow well was selected on the basis of the soil samplescollected continuously from ground surface to the top of the Potomac Formation. Allscreen intervals were agreed upon by Du Pont and the EPA prior to the screeninstallation. Upon completion of the wells, development procedures were conducted toremove fines and bentonite drilling mud from the sand pack.

> (£ -2.1.1 Drilling Locations [t*"* O-t m> (£ - /f ! / A

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The 15 drilling locations agreed upon by Du Pont and the EPA for the Phase III RI areshown on Figures 1 and 2 as locations MW-20, MW-21, and MW-23 through MW-35.Up to four types of wells were installed at each location, based on agreements reachedbetween Du Pont and the EPA during the Phase III program. A type A shallow zonewell was installed at each of these 15 locations to provide additional groundwater dataon the Columbia Formation or other Quaternary deposits. Type B monitoring wellswere installed into the intermediate zone at all 11 of the well cluster locations toevaluate the uppermost permeable unit of the Potomac Formation. The third type ofmonitoring well (type C) was installed into the deep zone at four of the eleven wellcluster locations to provide additional groundwater data where a permeable andhydraulically independent zone in the lower portion of the Potomac Formation existedand required evaluation. Each of these three zones correspond to hydrostratigraphicunits previously defined for the Newport Site (see Phase H RI/FS Work Plan, WCC, July28, 1988).

In addition to the three types of wells described above, Du Pont chose to install sixtype F fill zone wells to monitor groundwater in the permeable fill material above theColumbia Formation in portions of the Ciba-Geigy and Holly Run Plant areas. Du Pontalso installed five additional type A shallow zone wells to monitor groundwater

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downgradient of the Holly Run Plant area and at three pre-Phase III well clusterlocations.

Using mud rotary drilling, the pilot hole at each of the well cluster locations wasadvanced to the top of weathered bedrock at all of the cluster locations except MW-26where the boring was stopped upon reaching the base of the intermediate zone.Geophysical logging was conducted in the pilot holes to aid in the assessment ofstratigraphy and water-bearing zones.

Six of the well cluster locations (MW-29 through MW-35) were selected to clarify thepotential impacts on groundwater due to possible contaminant sources associated withhistoric operations within these areas. These locations were chosen on the basis of pre-Phase III groundwater contaminant concentration contour maps of the Site's targetparameters (barium, zinc, cadmium, tetrachloroethylene and trichloroethylene).Previously submitted groundwater elevation contour maps for the intermediate zone andthe shallow zone were also used.

Each of the individual monitoring well locations is discussed below:

Locations MW-20 and MW-21 - Both type A shallow zone and type B intermediatezone monitoring wells were installed at these two off-site locations. The fill andoverburden deposits above the Columbia Formation were sealed off from the screenedhorizon of the Columbia Formation in the shallow zone wells at these locations and allother Phase III type A shallow zone well locations.

Only one permeable zone was encountered within the Potomac Formation at these twolocations. A monitoring well was installed into this zone and designated as a type Bintermediate zone well.

Locations MW-23 through MW-25 - One type A shallow zone monitoring well wasinstalled at each of these three off-site locations to provide shallow groundwater datadowngradient from the eastern and southeastern perimeters of the South Disposal site.

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These wells were installed into the first water-bearing permeable zone encountered. Thescreened interval was sealed off from any readily identified fill material observed aboveit.

Location MW-26 - One type A shallow zone and two type B intermediate zonemonitoring wells were installed at this off-site location to provide additional groundwaterdata in the area to the southwest of the South Disposal site. The pilot hole at thislocation was advanced to the top of the previously defined Hydrostratigraphic Unit IIIB (Phase II RI/FS Work Plan, WCC, July 28, 1988). The top of this unit is identifiedby a violet-red clay. Two apparently hydraulically independent and permeable intervalswere encountered in the intermediate zone at this location. Consequently, as requestedby the EPA, one type B well (MW-26BS) was installed in the uppermost interval and asecond type B Potomac Formation well (MW-26BD) was installed at this location in thelowermost zone.

Location MW-27 - One type A shallow zone monitoring well was installed at thislocation to monitor shallow groundwater southwest of the North Disposal site and wellsMW-3A and SM-4. The well was installed into the permeable water-bearing materialsabove and at the top of the Potomac Formation. The EPA requested that the shallowwell at this location be installed into the permeable deposits at the top of the PotomacFormation.

Location MW-28 - A shallow soil boring was advanced to the top of the natural depositsand soil samples were collected for analysis. Because the results of soil analyses for thefill material were within background concentrations, the location was acceptable to theEPA as an upgradient cluster well location. One type A shallow zone, one type Bintermediate zone and one type C deep zone monitoring well were installed at MW-28to provide background groundwater chemistry data at the Site. The pilot hole at thislocation was advanced to the top of weathered bedrock.

Location MW-29 - This location at the Du Pont Holly Run Plant was selected due toits upgradient location from MW-1A and SM-2, where tetrachloroethylene (PCE) was

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previously detected in the Columbia Formation at concentrations ranging from 20 to 720parts per billion (ppb). This location, which is also near the center of the Holly RunPlant on the downgradient side of the production buildings, is expected to provide datathat will confirm that the Holly Run Plant is neither a historic nor present-day sourceof the contaminants detected in wells MW-1A and SM-2. It is the opinion of Du Pontand WCC that a type B intermediate zone well in the Potomac Formation was notneeded at this location because concentrations of PCE and trichloroethylene (TCE) inthe nearby intermediate zone wells MW-1B and MW-13 were just above the detectionlimit or not detected at all during pre-Phase III groundwater sampling. Furthermore,the range of concentrations of cadmium (not detected to 8.6 ppb) and zinc (41 - 121ppb) in the groundwater at MW-1B was considered low compared to concentrationsfound at many of the other well locations at the Site (based on pre-Phase IIIgroundwater data). However, at the request of the EPA, a type F fill zone well, a typeA shallow zone well, a type B intermediate zone well and a type C deep zone well wereinstalled at this location to provide a complete set of groundwater data from thislocation.

Location MW-30 - This location was selected to provide groundwater data in the areaof the oldest historic production buildings on-site. In addition, solvents are currentlyreported to be stored in this area. PCE was detected in a groundwater sample from thePhase II temporary monitoring well DB-2 located in this same general area. Due to thetemporary nature of the well, however, the annular space was not sealed. This possiblyallowed hydraulic communication between the Columbia and Potomac Formations.Thus, it is unclear whether that groundwater sample was obtained from the ColumbiaFormation or the Potomac Formation. Two wells, a type A shallow zone well and a typeB intermediate zone well, were installed at this location. In addition, a type F fill zonewell was installed at this location to monitor the groundwater in the permeable fillmaterial deposits above the Columbia Formation.

Location MW-31 - This location was selected to provide groundwater data in the centerof the area historically used for the storage and processing of zinc and barium ores.Location MW-31 is also adjacent to Building 100, which once was a part of copper

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phthalocyanide (CPC) production operations, where solvents such as PCE were used.Types F, A, and B wells were installed in the fill zone, shallow zone, and intermediatezone, respectively, at this location.

Location MW-32 - This location was selected to investigate further the possible sourceof PCE detected at existing shallow monitoring well MW-2A. The MW-32 clusterlocation is downgradient from Buildings 200, 201, and 70, which have historically beeninvolved in the production of CPC, which used PCE. It is the opinion of Du Pont andWCC that existing data on Potomac Formation groundwater chemistry nearby did notwarrant a type B intermediate zone well at this location. However, as requested by theEPA, an intermediate zone well was installed at this location.

Location MW-33 - One type A shallow zone well was completed here along with a typeB intermediate zone well and a type C deep zone well. This location is downgradientfrom historic Lithophone, CPC and quinacridone (QA) production.

Location MW-34 - A shallow boring was advanced to the top of natural deposits andsoil samples were collected for analysis. Because the fill material analyses fell withinbackground concentrations for the tested parameters, the location was acceptable to theEPA as an upgradient cluster well location. Both a type A shallow zone and type Bintermediate zone well were installed at this location to provide data on groundwaterquality upgradient of the Ciba-Geigy Plant area. Groundwater analytical data collectedfrom these wells, along with the MW-28 cluster wells, will be used to determinebackground chemistry for groundwater in the Columbia and Potomac Formations at theSite.

Location MW-35 - At the request of the EPA, a type A shallow zone, a type Bintermediate zone, and a type C deep zone well were installed at this location to monitorthe groundwater on the downgradient side of the eastern portion of the Site.

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Location MW-36 and MW-37 - One type A shallow zone well was installed at each ofthese locations to monitor groundwater in the Columbia Formation downgradient of theHolly Run Plant area.

Location MW-38 and MW-39 - One type F fill zone well was installed at each of theselocations to monitor the groundwater in the permeable deposits above the ColumbiaFormation in relation to the chemistry of the groundwater seeping from the northernbank of the Christina River, just to the south of these locations.

Soil Boring Locations - Also, as requested by the EPA, 23 soil borings were drilled atthe approximate locations labeled B-l through B-22, and B-25 shown on Figures 2 and3. These locations were distributed across the Ciba-Geigy and Holly Run Plant areasto evaluate potential areas of soil contaminants. Specific attention was given tohistorical Lithophone, CPC and QA manufacturing operations areas for the selection ofthese boring locations. QA operations continue today at the Newport Plant, under Ciba-Geigy ownership, in the same buildings in which Du Pont conducted operations andusing the same chemical processes and materials. The data from the Phase III soilborings and monitoring well locations will be evaluated in conjunction with thepreviously available soils data.

2.1.2 Pilot Holes

At each of the well cluster locations, a small diameter (3- to 5-inch) mud rotary hole wasdrilled to collect soil samples for chemical analyses and lithologic logging. The muddedholes were geophysically logged by WCC. An EPA representative was present duringsome of the geophysical logging operations. Screened intervals were selected, andapproved in advance by the EPA, for all of the wells to be installed at that well clusterbased upon the lithologic and the geophysical logs generated from the pilot holes. Thepilot holes were drilled using the following procedures:

1) Temporary 6-inch steel surface casing was installed through the fillmaterial and into the top of natural deposits.

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2) Nominal 3- to 5-inch diameter hole was drilled using the mud rotarydrilling method.

3) The drilling mud was changed and the mud tub was cleaned out two timesduring the drilling operations: upon reaching the base of the fill material;and upon reaching the base of the Columbia Formation. Once the mudand soil cuttings from the previous interval were cleaned out of the mudtub, the tub was again used during the advancement of the borehole.

4) Two-inch and/or 3-inch I.D. split-spoon samples were collected from eachof the pilot holes. Split-spoon samplers were driven through 24-inches ofmaterial in advance of the borehole continuously from approximately 2feet below ground surface to the top of natural deposits where the sampleinterval changed to either 6-foot or 5-foot intervals. Where soil sampleswere to be collected for chemical analyses (see Section 2.1.5), sampleswere collected at 6-foot intervals through the Columbia Formation andthen at 5-foot intervals through the Potomac Formation to the completiondepth. At locations where analytical samples were not to be collected,samples were collected at 5-foot intervals from the top of natural depositsthrough the Columbia and Potomac Formations to the completion depth.Standard penetration tests were performed in accordance with ASTM D-1586 specifications. As agreed upon by Du Pont and the EPA, some ofthe soil samples collected on the Holly Run and Ciba-Geigy Plant areaswere sent to CompuChem Laboratories for chemical analyses (see Section2.1.5). Three-inch diameter split-spoon samplers were used for thecollection of samples for which chemical analyses were to be performed;all other samples were collected using 2-inch diameter split-spoonsamplers.

5) Immediately upon completion of geophysical logging of the borehole, theborehole was sealed from the bottom to ground surface by pumping a 5percent bentonite-cement slurry (approximately 7 gallons of potable water

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per 94 pound sack of Portland Type I cement) through a tremie lineplaced to the bottom of the hole. The 6-inch temporary steel surfacecasing was removed during the grouting operation. The grout level wasmaintained above the bottom of the steel casing at all times.

2.1.3 Monitoring Well Installation Methods

2.1.3.1 Types B and C Potomac Formation Wells

As all of the necessary well completion information were collected from pilot holescompleted at type B and type C well locations, the borings for the monitoring wellinstallations were advanced primarily for this purpose. Monitoring wells were installedinto the Potomac Formation using two methods, identified below as the Type I andType II Methods.

To satisfy EPA requirements, the type B and type C Potomac Formation monitoringwells were constructed using the two different procedures outlined below and shown inFigures 4 and 5. The factor determining which of the methods was used was theanticipated metals concentrations in the groundwater at the location and/or depth of thewell based on pre-Phase III data. At locations where metal concentrations in thegroundwater are anticipated to be low, the Type I Method was used; whereconcentrations are expected to be high, the Type II Method was used. Specifications forwell construction are provided below. The EPA and Du Pont agreed upon whetherType I or Type II wells were to be installed at each location during the drilling program.A total of 16 Potomac Formation wells were installed during the Phase III investigation.

TYPE I METHOD

1) A nominal 14-inch diameter borehole was drilled and a temporary 14-inchO.D. steel casing was installed through the fill material and into the topof the Columbia Formation (see Figure 4).

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2) The 14-inch casing was then flushed out with fresh potable water and themud tub was cleaned out.

3) Using mud rotary techniques a nominal 14-inch diameter borehole wasdrilled through the Columbia Formation and several feet into the top ofthe Potomac Formation. Only premium-grade western sodium bentoniteand potable water were used for mixing drilling mud. This restrictionapplied to all mud drilling during the Phase III programs. Portable mudtubs (tanks) were used at all locations for the rotary drilling.

4) A permanent 10-inch I.D. steel casing was installed to the bottom of themudded borehole and the annular space was grouted to grade via tremiepipe (see previous specified grouting requirements). Centralizers wereplaced at the bottom of the casing and an effort was made to install thecasing plumb and aligned in the center of the borehole. If a clay layer waspresent at this casing setting depth, the casing was driven approximately1 to 2 feet into the clay to seal the casing prior to grouting. Thetemporary 14-inch casing was removed as the annular space was groutedfrom the bottom upwards, with the level of grout kept above the bottomof the 14-inch casing as it was removed.

5) Following a minimum 24-hour grout set period, the drill bit was placed tothe bottom of the casing. Then, the used drilling mud was flushed outwith new, clean drilling mud and the mud tub was, again, cleaned out. Anominal 10-inch diameter borehole was, then, drilled with mud rotary toa depth of 5 feet above the top of the proposed screen interval.

6) An 8-inch I.D. flush-joint steel casing was installed to the bottom of theborehole and the drilling mud and cuttings were thoroughly flushed outwith potable water and the mud tub was, again, cleaned out. Theborehole was, then, drilled with potable water (only) to the wellcompletion depth utilizing drill and wash (wash boring) techniques. In

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accordance with the EPA's requirement, no bentonite drilling mud wasintroduced into the screen interval.

7) For the type B or type C monitoring wells, 5 to 10 feet of 4-inch I.D. pipesize Type 304 No. 20-slot stainless steel welded-wire screens (U.O.P.Johnson or equivalent) with welded or threaded bottom cap were set intothe selected water-bearing zone. Four-inch I.D. Schedule 40 PVCthreaded flush joint riser pipe was utilized to bring the well to grade level.Nominal 10-inch centralizers were firmly secured to the top and bottomof the screen to keep the screen and riser pipe centered in the borehole.A sand pack of clean, graded silica Jessie Morie No. "OON" well gravelwas placed into the annular space, with progress continuously monitored(to ensure that the sand did not bridge), until the sand pack level was atleast 2 feet above the top of the screen. A granular bentonite slurry seal(minimum 3 feet thick) was placed on top of the sand pack. Theremaining annular space was filled with a five percent bentonite-cementgrout to grade. The bentonite slurry seal and grout were installed by thetremie method from the bottom of the annular space upward.

TYPE II METHOD

1) A nominal 12-inch diameter borehole was drilled and a temporary 12-inchI.D. steel casing was installed through the fill material into the top of theColumbia Formation (see Figure 5).

2) The 12-inch diameter casing was then flushed with potable water and themud tub was cleaned out.

3) Using mud rotary techniques (bentonite and potable water only asdescribed above), a nominal 12-inch diameter borehole was drilledthrough the Columbia Formation and several feet into the top of thePotomac Formation.

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4) A permanent 8-inch I.D. steel casing was installed to the bottom of themudded borehole and the annular space was grouted to grade (seeprevious specified grouting requirements). Centralizers were placed at thebottom of the casing and an effort was made to install the casing plumband aligned in the center of the borehole. If a clay layer was present atthis depth, the casing was driven approximately 1 to 2 feet into the clay toseal the casing prior to grouting. The temporary 12-inch diameter casingwas removed as the annular space was grouted from the bottom upwards,keeping the level of grout above the bottom of the 12-inch diametercasing.

5) Following a minimum 24-hour grout set period, the drill bit was placed tothe bottom of the casing. The used drilling mud was flushed out with new,clean drilling mud and the mud tub was, again, cleaned out. A nominal8-inch diameter borehole was, then, drilled to the selected completiondepth for the type B or type C Potomac Formation well. On the type Cwells, the used drilling mud was replaced with fresh drilling mud at thebase of the intermediate zone prior to continuing the hole to thecompletion depth.

6) The well was completed using the same 4-inch screen and riser pipeinstallation techniques as described above for the Type I method, exceptthat 8-inch centralizers were used.

2.1.3.2 Type A (Shallow Zone) and Type F (Fill Zone) Wells

1) If sampling was not conducted during drilling of a pilot hole at a clusterlocation, a split-spoon sampler was driven in advance of the hollow stemaugers. Some wells were sampled continuously. Standard penetrationtests were performed in accordance with ASTM D-1586 specifications.Archive samples were collected from each split-spoon.

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2) Using minimum 6-1/4-inch I.D. hollow stem augers, a borehole was drilledthrough the overburden until the water-bearing unit of interest wasencountered. Type A wells were screened in the Columbia Formation orother Quaternary deposits with care taken to seal off fill material from thescreened interval with a bentonite g Type F wells were screened in the* fsaturated fill material or nafi pTdepOMS above the Columbia Formatu* *

3) The wells were completed by installing, 4-inch I.D. Schedule 40 PVCmachine-slotted No. 10 slot screen with 4-inch I.D. Schedule 40 PVCthreaded flush-joint riser pipe through the hollow stem augers. Thelengths of the screen and riser varied with the geologic conditions and thewell location. A sand pack consisting of clean, graded, silica Jessie MorieNo. "OO" Well Gravel was placed into the annular space from the bottomof the screen to several feet above the top of screen, with continuousmeasurements made to monitor progress. A bentonite pellet seal(minimum of 2 feet thick) was placed on top of the sand pack, followedby a 5 percent bentonite-cement grout (maximum 7 gallons of potablewater per 94 pound sack of Portland Type I cement) pumped through atremie pipe filling the annular space from the bottom upward to groundsurface. At some locations a bentonite slurry was placed as a seal usingthe same method used during the grouting operations. A threaded capwas firmly secured to the bottom of the 4-inch screen. A slip cap wasused on the bottom of the well at some locations by attaching it to thewell with stainless steel screws. The augers were withdrawn from the holeduring the installation of the sand pack, bentonite seal and groutbackfilling operations; however, the bottom of the augers were maintainedbelow the top of the well construction materials at all times as the wellwas built.

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2.1.4 Soil Borings

Twenty-three soil borings were advanced to the top of the Potomac Formation. Drillingand sampling procedures used are outlined below.

1) Minimum 4-1/4-inch I.D. hollow stem augers were used to drill to the topof the Potomac Formation.

2) Split-spoon samples were collected continuously from 2 feet below groundsurface to the top of natural deposits where the sample interval changedto 6-foot intervals until the Potomac Formation was encountered. Samplecollection specifications used for the pilot holes and for single type A welllocations were also used for samples collected from the borings. Three-inch diameter split-spoons were used at depths where analytical sampleswere collected.

3) Upon completion of the borehole, the hole was filled with a 5-percentbentonite cement grout slurry through a tremie pipe placed to the bottomof the borehole (as specified in grouting procedures used duringmonitoring well installations).

2.1.5 Soil Sampling

Soil samples were collected from: locations where one type A or type F well wasinstalled; pilot holes where well clusters were installed; and soil borings. All sampleswere collected with either 2-inch or 3-inch diameter by 2-foot long split-spoon samplers.The soil samples collected with each split-spoon were archived in jars provided by thedrillers. In addition to the archive samples, analytical samples were collected from allof the soil borings, and pilot holes drilled at the MW-28 through MW-35 clusterlocations. The samples were collected for the analysis of the following parameters:Target Compound List (TCL) volatile organics, semi-volatile organics, pesticides/PCBs,and Target Analyte List (TAL) metals. Depth intervals, from which analytical samples

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were required, were sampled with the 3-inch diameter split-spoon samples to ensure thatthere was enough sample volume to fill all of the analytical glassware. The 2-inchdiameter split-spoon samples were used at locations where only archive samples werecollected for lithologic description. Sample intervals for all locations are outlined inTable 1.

For each analytical sample collected above the water table, one 8-ounce glass bottle wasfilled for TCL volatile organic analysis and one 1-liter glass bottle was filled for TCLsemi-volatile organics, pesticides/PCB's, and TAL metals analyses. Soil samples forTAL metals only were collected from below the water table to the top of the PotomacFormation unless there were indications that other contaminants were present (basedupon organic vapor measurements or visual observations). If the presence ofcontaminants was indicated, then glassware for the full suite of analytical parameters wasfilled. In addition, if there were indications that contaminants were possibly presentbetween the specified analytical sample points, then additional samples were alsocollected for the full suite of analytical parameters.

One field duplicate and one field blank were collected for every 20 field samplescollected; as part of the Quality Assurance/Quality Control (QA/QC) program. Thefield duplicate consisted of one 8-ounce bottle and one 1-liter bottle for the same set ofparameters discussed above. The field blank was collected by pouring deionized water(supplied by the laboratory) over a clean split-spoon sampler and sampling tool andcollecting the rinsate into two 40-ml vials for TCL volatile organics analysis, four 1-literbottles for TCL semi-volatile organic and pesticides/PCBs analysis and two 500-mlbottles for TAL metals analyses. The field blanks to be analyzed for TAL metals werepreserved with HNC to a pH of less than 2.

Upon opening the split-spoon sampler, the sample was vertically split and the sample forvolatile organics analysis was immediately collected followed by the sample(s) for theremainder of the analyses. The archive sample was collected last. Each sample wascollected along the entire 2-foot length of the split-spoon sample with stainless steelsampling tools in an effort to obtain a sample that was representative of that entire

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sample interval. Visual and geologic descriptions were noted during the samplecollection and were written into the field notes after all of the analytical glassware forthat sample had been filled. The samples were placed into a cooler containing ice orblue ice immediately after collection.

Samples were packaged (for overnight shipment to the laboratory) with freshly frozenblue ice in sample shuttles supplied by the laboratory. Chain-of-custody forms werecompleted and placed into the shuttles prior to sealing them for shipment. The chain-of-custody forms included sample ID, sample date, sample time, bottle sets, type of analysesto be performed, and requested turnaround time. One trip blank was sent for theanalysis of TCL volatile organics per shipment.

Samples were identified using the following system:

• for pilot holes = TB - # of boring - bottom of sample interval (feet)

for borings = B - # of boring - bottom of sample interval (feet)

for single type A wells = MW- Well # - bottom of sample interval (feet)

2.1.6 Miscellaneous Items

Well Head Completion - A 5-foot long, 6-inch diameter steel protective pipe wasinstalled over the 4-inch PVC riser pipe at type A well locations. A concrete pad, aminimum 6-inch thick, 2-foot by 2-foot square, was placed around each protective pipe.The permanent 8-inch or 10-inch diameter permanent casings at the type B and type Cwell locations were used as the protective casings for these wells. At some of the welllocations the protective casings have approximately 2 feet of stick-up above grade andhave a lockable steel cap over them with keyed-alike locks and a slip-on PVC caps withslide handles over the top of the 4-inch PVC riser.

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Other locations required the installation of steel flush mount manholes and manholecovers capable of withstanding tractor-trailer vehicle traffic. These manholes wereinstalled flush with the ground surface and include lockable water tight caps on the 4-inch riser pipes.

Well Development - Each well was developed using a surge block, sand pump, andsubmersible pump until there were no noticeable improvement in well efficiency, sandinfiltration, and turbidity. Specific capacity, sand entry into the screen, and pumpedwater turbidity and sand content were recorded during development.

Guard Posts - Concrete-filled steel pipe guard posts were set in concrete to a minimumdepth of 3 feet in 12-inch diameter holes (nominal) at well locations where thepossibility existed for damage to the well head due to heavy vehicle activity. Each postextends approximately 4 feet above grade and was painted fluorescent yellow.

Decontamination - Split-spoon samplers were cleaned by brushing with an Alconoxsolution and rinsing with potable water between usage at each well. All downhole tools,including split-spoon samplers, drill rods, augers, bits, etc., were thoroughly steamcleaned and the drilling fluid circulation system on the rig was flushed with Alconox andpotable water between wells and prior to drilling the first well to minimize the potentialfor cross-contamination. The steam cleaning activities took place on a concretedecontamination pad sloped to a sump at the center so that all rinsate from the cleaningactivities was contained. Split-spoon samplers used to collect soil samples for chemicalanalyses were decontaminated before the collection of each sample with an Alconox andpotable water wash followed by a potable water rinse, and finally a deionized waterrinse.

Waste Handling - All soils and drilling fluids generated during drilling activities as wellas all groundwater removed during well development activities and rinsate fromdecontamination activities were collected, containerized, labeled, and tracked throughto off-site disposal as outlined in the waste management plan (Du Pont-Newport SiteWaste Management Plan, WCC, January 31, 1991) developed for this proij

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22 GROUNDWATER SAMPLING

Upon completion of the drilling program, groundwater samples were collected from 84of the monitoring wells at the Site and from 12 groundwater seeps along the ChristinaRiver bank adjacent to the North Disposal site and the Ciba-Geigy Plant area. Tworounds of groundwater level measurements for all monitoring wells were also made inearly November 1990.

Each well remained undisturbed for a minimum of two weeks from the date that welldevelopment was completed until the well was sampled. All wells present prior to thePhase III drilling program were sampled for the presence of TCL volatile organics, totalTAL metals, and dissolved TAL metals. The wells installed during this program weresampled for the presence of the parameters discussed above as well as TCL semi-volatiles, and TCL pesticides and PCBs. In addition, four private wells (labeled R4, R5,R6 and R14) on Old Airport Road were also sampled three times during 1990 foranalysis of TCL volatile organics, total TAL metals, and dissolved metals. Groundwaterlevel measurements were taken and samples were collected by Du Pont personnel. Thesampling plan developed by Du Pont for these activities is presented as Appendix A.All of the project analytical work was performed by subcontracted analytical labs underContract Laboratory Program (CLP) protocol in accordance with the QAPP and itssupplements.

Groundwater seepage samples were collected by WCC personnel at the approximatelocations presented in Figure 6. The EPA verbally approved the sampling proceduresprior to the groundwater seepage sample collection. The locations were selected basedupon a review of the river bank. Samples were collected for the analysis of TCL volatileorganics, TCL semi-volatile organics, TAL dissolved metals, TAL total metals, and totalpetroleum hydrocarbons. Analytical parameters performed on each sample (individualseepage point for volatile organics or composite from several seepage points for metalsand semi-volatile organics) are presented on Table 2. Samples for volatile organics andtotal petroleum hydrocarbons analyses were collected by directly filling sample bottlesfrom selected seepage stations. Samples for semi-volatile organics, and dissolved and

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total metals analyses were collected by filling a one gallon glass container with an equalamount of water from each seepage station within a composite group (i.e., if there werethree stations within a group, the one gallon container was filled one-third at each of thestations). Sample bottles for the semi-volatile organics and the metals analyses werethen filled from the one gallon container after thorough mixing. The sample fordissolved metals was filtered through a 0.45 micron filter prior to filling the bottlelabeled for that analysis.

Samples to be analyzed for volatile organic analyses were preserved with hydrochloricacid (HC1) by placing a few drops of HC1 into the 40 ml vial prior to filling it. Samplesto be analyzed for total petroleum hydrocarbons were preserved with HC1 to a pH ofless than 2 after filling the sample bottle. Samples to be analyzed for both total anddissolved metals were preserved with nitric acid (HNOtj) to a pH of less than 2immediately .after filling the sample bottle. All glassware (including the glass compositecontainers) were supplied by the laboratory.

All sampling tools were cleaned using the procedures outlined in the groundwatersampling plan in Appendix A.

Because the seepage points were all located in the inter-tidal zone of the river bank, thesamples had to be collected during low tide (within a two hour period). Seven of the19 sampling stations identified for the collection of groundwater seepage samples duringthe preliminary review of the river bank were not flowing, or produced water at such alow rate that samples could not be collected within the limited sampling time (beforethe river level was too high).

One field duplicate, one field blank, and one matrix spike and matrix spike duplicatesample were collected during the groundwater seepage sampling program in accordancewith the QAPP. The field duplicate was collected in the same manner and at the sametime as the primary sample. The field blank was collected by pouring deionized water(supplied by the laboratory) through and over the sampling tools used to collect the

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samples and into the sample bottles. The field blank was filtered and preserved in thesame manner as the groundwater sample.

2.3 SUPPLEMENTAL WETLANDS INVESTIGATION

In August and December of 1989, a Phase III Wetlands Investigation was performed inthe Christina River and wetland drainageways in the vicinity of the Du Pont- NewportSite. Data generated in the investigation was compiled in a Technical Data SummaryReport (TDSR) generated by WCC in January of 1990. In response to the EPA's March29, 1990 review comments of the TDSR, Du Pont proposed a Supplemental Phase IIIeffort to aid in the assessment of potential ecological impacts associated with the DuPont-Newport Site and to supplement and clarify data collected in Phases II and III.This proposed work responded to all of EPA's comments of March 1990 and wassubmitted as part of the Draft Work Plan (WCC April 12, 1990).

On May 8,1990, Du Pont received comments from EPA on the Draft Work Plan. Thesecomments were responded to in a letter submitted to EPA by WCC on Du Font's behalfon July 5, 1990. On August 9, 1990, EPA responded to the letter and included requestsfor additional data collection. The scope of work defined below addresses all commentsto date.

Comments by the EPA prompted additional investigation in the following componentsof the field investigation and laboratory analyses:

Surface Water Chemistry (Section 2.3.1)

• Sediment Chemistry and Physical Parameters (Section 2.3.2)

Sediment Toxicity Testing (Section 2.3.3)

Benthic Community Surveys (Section 2.3.4)

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Vegetation Bioaccurnulation (Section 2.3.5)

Fish Tissue Analyses (Section 2.3.6)

Section 2.3.7 describes the proposed Phase III Wetlands Investigation report. A summaryof the sampling plan is provided in Table 3. A summary of analytical work associatedwith the plan is provided in Table 4.

Sampling locations are shown on Figures 7 and 8. For the purpose of this investigation,in response to EPA's comments and concerns involving the Site, seven new stations weresampled in October of 1990 in addition to nine stations which had already been sampledin previous phases of the Wetlands Investigation. The new stations are as follows:

Station AS 12 is the most up-gradient station in the North Disposal sitedrainage ditch.

Stations RS13 and RS14 were located in depositional areas of theChristina River, at the mouth of the North Disposal site drainage ditch.

• RS15 served as a reference station for this investigation. It was locatedin the Christina River approximately one mile upstream of RS04, thecontrol or field reference station in the initial Phase HI Investigation.

RS11 and RS12 were located in the Christina River in the Site vicinitybetween existing stations RS01 and RS07.

Owing to the multi-disciplinary needs and technical issues of this Wetlands Investigation,the following regulatory personnel were identified by the EPA as contacts to provideguidance in their respective areas of expertise as authorized by the EPA remedial projectmanager, R. Sturgeon (personal communication with R. Sturgeon, August 22, 1990):

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___Contact ____Technical Issues____

Kevin Novo - Gradac - Sediment Chemistry and PhysicalEPA, Athens, Georgia Parameters; MINTEQA2 Modeling

Diane Wehner - Toxicity TestingNOAA, Region III EPA

Jim Ryan - Vegetation BioaccumulationEPA, Cincinnati, Ohio

Richard Greene - Fish Tissue AnalysesDNREC

Multimedia analytical needs required that several laboratories be contracted. Thefollowing laboratories performed the indicated analyses in accordance with the QAPPand its supplements:

Surface Water Chemistry;EnsecoCambridge, Massachusetts

Sediment Chemistry;EnsecoCambridge, Massachusetts

• Sediment Physical Parameters;Bowser-Morner, Inc.,Dayton, Ohio

• Toxicity Testing (Hyalella azteca):Barry A. Vittor, and AssociatesMobile, Alabama

Toxicity Testing (Chironomus tentans):TAI Environmental SciencesMobile, Alabama

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Biological Tissue Analyses;Hazelton LabsMadison, Wisconsin

2.3.1 Surface Water Chemistry

Surface water sampling was performed in the north drainage ditch and vicinity atStations AS 12, AS09, RS13, and RS14 (filtered and unfiltered water samples), and atStations AS03 and AS05 (unfiltered water samples only) in the vicinity of the SouthDisposal site (see Tables 3 and 4 and Figures 7 and 8). A total of 10 surface watersamples were collected by WCC staff by walking to the sampling station, including theRS13 and RS14 locations adjacent to the wetlands.

Filtered and unfiltered sample results from the north drainage ditch and vicinity will beevaluated to determine whether there is potential suspended sediment transport fromthis area to the Christina River. These data, and data collected in the vicinity of theSouth Disposal site, will also be used as inputs by EPA into the MINTEQA2 model asdescribed in EPA comments received May 8, 1990.

Water samples were sub-sampled from a larger vessel containing several gallons ofsample water. Water collected in the larger vessel was thoroughly mixed prior totransfer to a shipping container (sample jar). Surface water samples to be analyzed fordissolved metals were filtered through a .45 micron filter in the field prior to transfer ofthe filtrate to a shipping container. The suite of parameters to be analyzed forunfiltered and filtered water samples as listed in EPA comments (May 8,1990; personalcommunication with K. Novo-Gradac, September 18,1990) were TAL metals, dissolvedferrous and ferric ions, phosphate (as total phosphorus), sulfate, chloride, silica,suspended solids, and dissolved organic carbon. Temperature, conductivity, Eh, pH,alkalinity, and dissolved oxygen were measured in the field.

With the exception of ferrous and ferric ions, all analyses were performed in accordancewith Methods for Chemical Analysis of Water and Wastes (EPA-600/4-79-020, March1983), using the most currently available CLP protocol. Ferrous and ferric ions were

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analyzed according to ASTM Method 315B (the phenanthroline method of iron analysisusing bathophenanthroline).

As requested in the EPA's letter of August 9, 1990, major sources of carbon to theriver/wetland system will be defined as part of the surface water quality task. A list ofexisting permitted outfalls will be assembled to identify these sources. Existing data onother major sources of carbon will be included if available (personal communication withK. Novo-Gradac, September 18, 1990.) No quantification or evaluation of these datawill be performed by Du Pont or WCC, as agreed upon by the EPA.

2.3.2 Sediment Chemistry and Physical Parameters

Sediment chemistry samples were collected at all stations where benthos, plant tissue,surface water and sediment for toxicity testing were collected during the week ofOctober 8, 1990. This included seven stations in the vicinity of the North Disposal site,three stations in the vicinity of the South Disposal site and five stations in the ChristinaRiver, for a total of 15 stations (see Tables 3 and 4 and Figures 7 and 8). Sedimentsamples were collected to the specified sample depth, or point of refusal, whicheveroccurred first (personal communication with K. Novo-Gradac, September 18,1990.). Atfive of the Stations (AS07, AS09, AS01, RS15 and RS07), an attempt was made tocollect sediments from the following three depths: 0- to 6-inches, 6- to 12-inches and 12-to 18-inches; however, the 12- to 18-inch depth was only recoverable at stations RS15,RS07 and AS01. At the remainder of the stations, only the 0- to 6-inch and 6- to 12-inchdepths were sampled. Chemical and physical analyses performed on each surficialsediment sample were as follows:

TAL metals percent moisturepH grain-size distributionpaniculate organic carbon amorphous ironpercent combustible organics

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This sampling configuration and analytical plan reflects comments received from theEPA (May 8, 1990 and August 9, 1990) and conversations with the EPA (personalcommunication with K. Novo-Gradac, August 21, 1990 and September 18, 1990).

Surface sediment samples (0- to 6-inches) were collected using a petite Ponar bottomgrab sampler. Subsurface samples were collected using a 3-inch diameter stainless steelhand corer lined with clear Lexan liner tubes. Cores were extruded using a push rodtool and separated into two or three samples representing the target depths. New linerswere used at each station to prevent cross contamination. Sufficient sediment wascollected from surficial sediment samples at each location to provide a composite samplefrom which sediment was taken for chemical and physical analyses and toxicity testing.

Samples collected from the 6- to 12-inch and 12- to 18-inch depths were emptied directlyinto sample vessels. Surface samples were emptied into lab-cleaned, stainless steelcontainers. The surface sediment samples were thoroughly mixed, and sample jars werefilled for each sample depth using dedicated laboratory-cleaned scoops. The Ponar graband core sampler nose piece were cleaned before and after collection at each stationusing nitric acid and distilled water. New liner tubes were used at each samplinglocation.

From each homogenized surficial sample, four subsamples were removed for: (1) TALmetals analyses; (2) amorphous iron (at five stations only); (3) toxicity testing (seeSection 2.3.3); and (4) the remainder of chemical and physical parameters. Sample jarswere appropriately labeled, packed in blue ice and shipped by over-night delivery to thelaboratories. Appropriate chain-of-custody forms were maintained for all samples.

TAL metals analyses and quality control were performed in accordance with EPA-600/4-79-020, using the most currently available CLP protocol. Amorphous iron was analyzedusing the hydroxylamine hydrochloride extraction method described in Jenne andCrecelius, 1988, as requested by the EPA (personal communication with K. Novo-Gradac, August 21,1990). Duplicate quality control samples were analyzed for the five

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amorphous iron samples (personal communication with K. Novo-Gradac, September 18,1990).

2.3.3 Sediment Toxicity Testing

Solid phase toxicity testing of sediments using Chironomus tentans and Hyalella aztecawas performed using sediments collected at the 14 stations listed in Table 3 and shownon Figures 7 and 8. The purpose of the solid phase method is to assess the potentialtoxicity of contaminated sediments during continuous exposure of the organisms in short-term partial life cycle tests.

As specified in supplemental comments received from the EPA on May 8, 1990,methodology followed ASTM standardized procedures and the Proposed Guide forConducting Solid Phase Sediment Toxicity Tests with Freshwater Invertebrates, DraftNo. 6 (Nelson, Ingersoll and Dwyer, 1988). Sediments for toxicity testing were sub-samples of homogenized surface sediment (0- to 6-inch) samples.

The 28-day survival and growth test was performed for the Hyalella azteca test. Over-lying water was renewed twice daily. Test organisms were juveniles, less than one weekold. Twenty test organisms were placed in each of the four replicates per test sediment.

In each vessel 200 ml of test sediment was maintained with 800 ml of overlying waterand maintained at 20° to 23° C. The reference sediment was collected from RS15, themost upstream station. Negative controls (lab controls) were also tested but noreference toxicant was used. Dissolved oxygen, pH, and conductivity were monitoreddaily. Alkalinity and hardness were performed at the initiation of the test and weekly,thereafter.

The same test was performed for Chironomus tentans. except the test duration was 14days. Test organisms were 8-day larvae, with 10 individuals per test replicate. Watertemperature was maintained between 20P to 22° C. Dissolved oxygen levels weremeasured daily.

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2.3.4 Benthic Community Surveys

In the Phase III Investigation, benthic macroinvertebrates were recovered in locationswhere laboratory toxicity testing indicated that sediment contaminant levels wouldpreclude life. Hence, benthic community analyses are an important "in vivo" gage ofactual environmental conditions.

Benthic macroinvertebrates were collected from the 12 stations listed on Table 3 andshown on Figures 7 and 8. Field and laboratory sampling and analytical methodsfollowed those given in Section 2.5 of the Phase III Wetlands Investigation Work Plan(WCC, 1989). To summarize those methods, five replicates were collected at each ofthe 12 stations using a petite Ponar bottom grab sampler. Samples were washed througha 500 micron sieve and temporarily fixed in a 10 percent formalin solution. Sampleswere washed in fresh water within 72 hours and transferred to a 70 percent solution ofisopropyl alcohol and glycerin. Three of the five replicates from each station wereanalyzed; two were archived.

As specified in the supplemental comments received from the EPA on May 8, 1990, aspecies diversity index such as Shannon's, and an evenness index will be computed foreach replicate sample. These measures will be used, along with density and richnessmeasures, as a basis for comparison of benthic data collected at the different stations.

As mentioned in the TDSR and reiterated in Du Font's response to EPA's comments(July 1990), most benthic taxa recovered are common and widely distributed infreshwater habitats throughout North America. Since some are generally tolerant of awide range of pollutants it is difficult to specify whether their presence is due to

(/___toleranee of metal contamination or some other factor. Despite these limitations, aX cursorv iterature search will be performed to identify references concerning metals

tolerant species identified in the study area.

Benthic community data will be utilized along with sediment chemistry data and toxicitytesting results to assess ecological impacts of sediment contamination. These three

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complimentary data sets have been shown to provide empirical evidence oncontamination and effects that can be used to classify relative sediment quality. Thedata will be used descriptively, similar to data presented in the TDSR, to evaluate andclassify the relative quality of habitat among the sampling stations. Data collected in theSite vicinity will be compared with other locations in the river.

2.3.5 Vegetation Bioaccumulation

Bioaccumulation of contaminants by wetland vegetation will be evaluated using datafrom tissue analyses performed on selected emergent wetland plant species (e.g.,Nuphar spp.). Tissue samples were collected from the South Disposal site pond (AS01),a drainageway from the South Disposal site pond (AS03), AS05, and RS15, the referencelocation, as requested (EPA, May 5, 1990).

EPA comments of May 5, 1990, suggest that tissue sampling "be conducted at the peaktime of metals uptake which is documented in the literature." Peak uptake generallyoccurs in the spring, with levels decreasing through the growing season. Although it isrecognized that levels measured in plant tissues collected in October with the approvalof EPA, and data generated for the environmental evaluation, probably do not representpeak concentrations, no further plant tissue sampling is proposed.

At each of the four stations, three replicate tissue samples of roots or rhizomes andabove ground leaves were collected. Using Method 3050 of USEPA SW-846, above andbelow ground tissue samples were analyzed for levels of TAL metals and percentmoisture. Since there are no plant tissue standards, and available data is sparse forspecific metals levels in specific taxa, levels will only be compared to literature valueswhere available. Sediment samples were also collected at each location and tested forparameters listed in Section 2.3.2, Sediment Chemistry.

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2.3.6 Fish Tissue Analyses

The purpose of the fish tissue analyses is to measure levels of TAL metals in edibleportions (i.e., fillets) of commonly considered edible fish species from two locations inthe Christina River. These data will provide additional information on metalconcentration levels in fish tissue for input into the RI/FS reports. These data will notprovide appropriate information on which a determination could be made whether theDu Pont-Newport Site is the source of any detected contaminants in the fish tissue, sincefish are highly mobile and other contaminant sources are known to occur in theChristina River basin.

A representative from DNREC accompanied WCC personnel during the fish collectionefforts. As requested, aliquots of excess homogenized fish tissue, were frozen andfurnished to DNREC for analyses. DNREC is aware of the potential for matrix effectswhich could preclude attainment of target quantitation limits and decrease the usefulnessof the data. Target quantitation limits (QL's) for TAL metals in fish tissue will beidentical to minimum CLP limits for soil samples. Matrix effects may preclude achievingthe target QL's.

Fish tissues were collected and analyzed in accordance with guidelines delineated inEPA's response to Du Font's letter dated August 9, 1990. Fish were collected upstreamof the Site, and in the Site vicinity. The upstream location was in the general vicinityof RS15, a new station upstream of RS04. The location in the Site vicinity was from theJames Street Bridge, upstream to the vicinity of the North Disposal site ditch. Trap netswas used to sample the fish since these collect bottom-dwelling as well as nektonicspecies. Gill nets were set over night in the Site vicinity but were unsuccessful.

Sampling continued several days, until an adequate quantity of tissue was collected, oruntil the catch per unit effort became negligible, as determined by WCC and DNRECpersonnel. Attempts were made to collect two target species at each of the twolocations. Based on previous collections made in the Site vicinity, edible target speciesincluded white catfish, brown bullhead, yellow bullhead, channel catfish, white perch,

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pumpkinseed, black crappie, large mouth bass and carp. At RS15 samples of brownbullhead, largemouth bass and black crappie were collected in sufficient quantities foranalyses. In the Site vicinity brown bullhead, white catfish, black crappie and channelcatfish were collected.

Where sufficient quantities of each species were collected, two replicate samples of eachspecies were retained for a total of nine samples. Each replicate sample consisted of theminimum number of fish of the same species with the most similar length, weight andphysical conditions. Fish were filleted, and the fillets were homogenized and compositedto represent edible portions to comprise a 250 gram sample. All samples were analyzedfor TAL metals and percent lipids. Any additional tissue collected above what wasneeded by WCC and DNREC to perform the desired analyses, was documented.

2.3.7 Technical Data Report

Data generated in the Supplemental Phase III Wetland Investigation will be tabulatedand compiled so that each of the sampling stations can be described using all data sets.The study area will be divided into North Disposal site wetland stations, South Disposalsite wetland stations and river stations for descriptive purposes. Data from the initialPhase III Investigation will not necessarily be presented again, but reference will bemade to the TDSR to identify locations where new data are in obvious agreement ordisagreement with previous findings. For the river, data from stations in the Site vicinitywill be compared to upstream Station RS15 to identify differences in habitat qualitywhich could be attributable to the Site. As requested by the EPA (August 9, 1990) theSupplemental Phase III Wetlands Investigation Report will also include the following:

Tabulated results of the inventory for major sources of carbon to theriver/wetland system;

Analytical data on amorphous iron, tabulated for input into theMINTEQA2 model by EPA's Athens, Georgia laboratory; and

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A description of metals levels measured in Site vegetation and comparisonwith upstream reference station vegetation and literature values, whereavailable.

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3.0SITE INVESTIGATION ANALYSIS

The objectives of this task are to:

perform QA/QC evaluation and Phase III data validation; andevaluate sufficiency of the Phase III collected data and information.

These objectives will be met during the Phase III RI. The Phase III analytical data willbe subjected to QA/QC evaluation for validation in accordance with the procedurespresented in the QAPP (WCC, July 28, 1988). The validated Phase III analytical dataand other Phase III information will be evaluated to determine if they meet theapplicable data sufficiency objectives outlined in the Phase II Work Plan (WCC, July 28,1988) and be submitted to the EPA as a Phase III RI Data Sufficiency Report. Includedin this document will be the Technical Data Report for the Supplemental Phase IIIWetlands Investigation.

Assuming the EPA elects to return the Newport Site into one OU, one Risk Assessmentwill be performed in accordance with the EPA's "Risk Assessment Guidance forSuperfund, Volume I: Human Health Evaluation Manual (September 29, 1989) andVolume II: Environmental Evaluation Manual (March 1989)." This document will besubmitted to the EPA with the RI report (see Section 4.0).

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4.0REMEDIAL INVESTIGATION REPORT

Assuming that EPA elects to return the Newport Site into one OU, the evaluation ofPhases I, II and III of the RI will be presented in one RI Report to EPA prepared inaccordance with "EPA Guidance for Remedial Investigations and Feasibility StudiesUnder CERCLA" (October 1988) and additional updated guidance documents whichmay be provided by EPA. This RI Report will be submitted to the EPA after the EPAhas approved the sufficiency of the Phases I, II, and III RI data. The majority of thesedata will be provided in the RI Report by reference, only, to prior documents.

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5.0FEASIBILITY STUDY

The objectives of the Feasibility Study (FS) are to identify available remedialtechnologies, screen technologies, and develop and evaluate remedial alternatives basedon the RI results for the Du Pont-Newport Site. The FS will be conducted inaccordance with the "EPA Guidance for Remedial Investigations and Feasibility StudiesUnder CERCLA" (October 1988). Following completion and approval by EPA of theRI Report, Du Pont will submit a FS Report to EPA which is expected to focus on selectremedial alternatives.

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6.0DATA MANAGEMENT

A data management system will provide a mechanism for data tracking, storage, retrievaland identification of appropriate QA/QC procedures. The RI/FS Phase II Work Plan(WCC, July 28, 1988) provided an outline of the procedures to be used in tracking andprocessing information and analytical data, which will be followed during the Phase IIIinvestigation. The collected information and data will be processed and documented ina way which would make them available for use in Site descriptions, groundwatermodeling, risk assessments and engineering design of remedial alternatives.

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7.0SCHEDULE, REPORTING, DOCUMENT CONTROL

AND PROJECT MANAGEMENT

The RI/FS activities in this Phase III Work Plan will be implemented according toTable 5, subject to the contingencies noted in that table.

In addition to the deliverables identified in Table 5, monthly progress reports willcontinue to be submitted to EPA by the tenth calendar day of each month. Thedocument control system outlined in the RI/FS Phase II Work Plan (WCC, July 28,1988)will continue to be followed.

The currently designated project managers for the Newport Site are:

Du Pont Project Manager Joel KarmazynWCC Project Manager Roger T. Gresh, P.O.EPA Remedial Project Manager Randy Sturgeon

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Tabl

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aR306560

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TABLE 4

LABORATORY ANALYSESPHASE III SUPPLEMENTAL WETLANDS INVESTIGATION

DU PONT - NEWPORT SITE

Media/Analyses No. Samples ______Parameters______ ____Lab_____

Surface Water (10+4 QC) TAL metals, alkalinity ENSECOdissolved ferrous/ferric Cambridge, MAions, phosphate, sulfatechloride, silicon,suspended solids/dissolved organic carbon

Sediment (35+9 QC) TAL metals ENSECOChemistry I Cambridge, MA

Sediment (15) pH, particulate organic Bowser MornerChemistry II carbon, percent combustible Dayton, OH

organics, percent moisturegrain-size distribution

(5+5 QC) amorphous iron

Solid Phase — TAIToxocity Testing (14+1 QC) EnvironmentalC. tentans Services

Mobile, AL

Solid Phase — Barry A. VittorToxicity Testing (14+1 QC) AssociatesHyalella azteca Mobile, AL

Plant Tissue (24+3 QC) TAL metals Hazelton LabsAnalyses percent moisture Madison, WI

Fish Tissue (9+1 QC) TAL metals Hazelton LabsAnalyses percent moisture Madison, WI

percent lipids

WorkPIan/Phase III/DPN2 *. 1/14/91Revision 0

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TABLE 5

RI/FS SCHEDULE

The calendar schedule for completion of the RI/FS at theNewport Site is currently under negotiation betweenDu Pont and the EPA. After an agreement is reached, thefinal schedule will be submitted to the EPA underseparate cover.

UorkPlan/Phase III/DPN2 Mn 2/14/91

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Figures

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TEMPORARY 14 INCH DIA.STEEL CASING SET.THROUGH FILL

PERMANENT 10 INCHDIA. CASING GROUTEDTHROUGH COLUMBIA

DRILL MUD ROTARY NOMINAL •10 INCH DIA. BOREHOLETO 5 FEET ABOVESCREENED INTERVAL

DRILL AND WASH 8 INCH DIA.CASING TO COMPLETION ——DEPTH (CASING TO BEPULLED UPON COMPLETIONOF WELL)

FILL

COLUMBIAFORMATION

POTOMACFORMATION

5 FEET ABOVESCREENED INTERVAL

4" DIAM. WELL INSTALLEDWITH APPROPIATE SCREEN.SAND FILTER, BENTONITESEAL AND BENTONITE-CEMENT GROUT

BEDROCK

3

Rav. No. Dot* TIP* of Revftfci U U U Dh«ok<VM

SCHEMATIC DIAGRAMTYPE I POTOMAC "B AND C-DEPTH" WELLS

DuPONT - NEWPORT SITENEWPORT, DELAWARE

£2} Wopch- Conwiltlng Eng

Job No.: 88C2076Drown by; TJ".Seo<«

vard-Ctydo ComuttanteiiMn. Geologist* and Environmental Scientist*Drawing No. 80760330Checked by: IB.

Dot« 01/11/91

FIGURE 4

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TEMPORARY 12 INCH DIA.STEEL CASING SET ______THROUGH FILL ~~~~ — -«».

PERMANENT 8 INCHDIA. CASING GROUTED ——— -•-THROUGH COLUMBIA

RILL MUD ROTARY NOMINAL • —— •»INCH DIA. BOREHOLE0 TOTAL DEPTH OF WELL

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POTOMACFORMATION

*"- 5 FEET ABOVESCREENED INTERVAL

4" DIAM. WELL INSTALLEDWITH APPROPIATE SCREEN.SAND FILTER. BENTONITESEAL AND BENTONITE-CEMENT GROUT

4BEDROCK

RR30S569Rev. No. Dot* Type of Revision Cheeked by:

SCHEMATIC DIAGRAMTYPE II POTOMAC "B AND C-DEPTH" WELLS

DuPONT - NEWPORT SITENEWPORT, DELAWARE

Woodw«tf-eiy* CoMuttaiteConsulting Engineer*. Geologist* and Environmental So

Job No.: HC2078 Drawing Na 80780340 Date: 01/11/91by: T.P. Checked by: OB.

Scale: FIGURE 5

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^

Appendix

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REMEDIAL INVESTIGATION - PHASE IHSAMPLING OF GROUNDWATER MONITORING WELLS

NEWPORT SITE WORK PLANOCTOBER 31, 1990

1.0 OBJECTIVEThis proposal describes the tasks for groundwater field activities at the Holly Run plant inNewport, Delaware.

2.0 DESCRIPTION OF TASKS

2.1 GROUNDWATER ELEVATIONSStatic water levels from all wells sampled will be measured for the purpose of preparingwater table and piezometric surface maps. Since the water levels are tidally influenced,measurements will be taken on two separate occasions; the first, starting one hourbefore and concluding no later than one hour after high tide. The second will be takenstarting one hour before and concluding no later than one hour after the next low tide.

Depth to water measurements will be measured to surveyed reference points marked onthe well casing with chalked steel tapes. The entire tape will be rinsed with deionizedwater as it is removed from the the well. A table of well elevations (top of casing),depth to water and water level elevations will be generated from the field data.

2.2. FIELD ACTIVITIESGroundwater samples will be collected from a total of 86 wells according to thefollowing protocol:

1. A site map is attached showing the approximate locations of each well(Figure 1).

2. All field data will be recorded in site-dedicated field notebooks and transferredas necessary to specific forms or tables.

3. Wear safety glasses, Tyvek® coveralls, rubber boots and rubber gloves forpersonal and sample protection at each well location.

4. All water level measurements will be recorded in tenths and hundredths of feet

5. Calibrate field instruments (pH, temperature and specific conductance) daily,before use. Record calibration in field book.

6. Several minutes prior to well evacuation and water level measuring, the wellcover will be unlocked and cap will be removed to allow venting of anypotentially trapped gases or vapors.

AR306571*SKGl/rpts "lNewport RFI

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7 Create a "clean" zone for all equipment used at each well by placing a piece ofplastic sheeting, approximately six feet square.

8. Using a stainless steel weighted tape, measure the total depth (TD) of the well.

9. Using a M-scope water level indicator, measure the depth to water (DTW) fromthe top of the well casing. Record the value in the field book.

10. Determine the length of the water column in the well by subtracting the DTWfrom the TD. Multiply the length of the water column by the proper conversionfactor depending on the diameter of the well (i.e. 0.163 gallons per foot for a 2"well) to determine the well volume.

11. All well measuring devices will be rinsed with deionized water as they arewithdrawn from the well.

12. Evacuate a minimum of three well volumes using either a submersible,centrifugal, or peristaltic pump, depending upon well yield. The first wellvolume will be removed with the pump set close to the bottom of the well toremove any silts or sands accumulated there; the pump will then be pulled uptoward the top of the water column so that all static water is removed. In mostcases, removal of three well volumes should ensure the collection of arepresentative sample not influenced by stagnant water remaining in the wellcasing, and yet not result in overpumping of the well. All wells will be purgedat a steady rate low enough to not create turbid flow into the well. Purge rateswill be maintained below 5 gpm in Potomac Formation wells (type B & C) ifturbidity clears fairly quickly. Discharge rates will be regulated to avoidlowering pumping level below 50%-75% of available drawdown. If turbiditypersists, higher purge rates up to a maximum of 10 gpm may be deemednecessary by field personnel to clear the wells of turbidity while purging inexcess of three well volumes. In shallow (type A & F) wells, maximum purgerates of 1-2 gpm will be utilized using pumping equipment, not bailers,discharging at steady rates to avoid any surging of the wells. Pumps will enterand exit the well's water column in a manner which minimizes splashing andagitation. All purged water will be contained and disposed of as determined inthe Waste Management Plan (currently in preparation). A field determinationbased on pH and specific conductance will dictate if the well should be purgedbeyond the three well volumes. Field readings of pH, specific conductance,and temperature will be taken periodically throughout the purging process.When three consecutive measurements representing no more man a 10% changebetween all three values are recorded and at least three well volumes have beenremoved, purging will cease.

13. After allowing wells to recharge for no more than two hours, groundwatersamples will be collected using laboratory decontaminated bottom-fill Teflon®bailers attached to new polypropylene rope. Bailers will be carefully loweredand raised into and out of the water column. Water from the first bailerwithdrawn from the well will be contained and disposed of in a similar manneras purged water. Water from successive bails will be transferred into properlylabeled sample containers. When sampling for volatile compounds, care will betaken to minimize splashing and agitation while filling the vials. Vials for YOGanalyses will be filled so that no air space remains.

SKGl/rpts 2Newport RFI

AR306575

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14. Wells will be sampled in the order as shown on Table 2. This order wasdefined by determining if the evacuated water would be classified as "on hold"or "non-hazardous", according to previous analytical results and geographicallocations.

15. Measure pH, temperature and specific conductance in the field just aftercollection of the VOC bottles and before collection of the remaining bottles ofeach sample bottle set.

16. Samples to be analyzed for dissolved metals will be filtered in the field througha dedicated 0.45 micron on-line filter before adding nitric acid as a preservative.

17. Collect Quality Assurance/Quality Control (QA/QC) samples as follows:

- One duplicate per 10 samples collected;

,• - One field blank per 10 samples collected;j '

i - One matrix spike (MS) per 20 samples collected and one matrix spikeduplicate (MSD) per 20 samples collected (including duplicates and fieldblanks); and

- One trip blank per shipment to the laboratory involving volatile organicsanalysis.

18. Samples will be placed in coolers with ice until samples are delivered to thelaboratory. Custody of samples will be maintained by EPS personnel untilreceived by the lab.

19. Analytical parameters vary from well to well and Table 2 shows the selectedparameters for each well.

20. Samples will be shipped daily to Comp-Chem Laboratories by overnightcourier. Maximum sample field holding time at the site will not exceed24 hours.

21. To maintain proper sample custody, the laboratory chain of custody formshown in Figure 2 will be used to trace the possession and handling of thesample from the moment of its collection through analysis at the lab.

22. For sample tracking purposes, a traffic report form will be completed for eachsample. An example of this form is Figure 3.

23. All reusable equipment will be placed into plastic bags for storage until it can bedecontaminated. All disposable equipment will be placed in plastic bags andwill be disposed of according to Waste Management Plan.

24. All wells will be locked with steel padlocks. One set of master keys will be leftwith Holly Run plant site personnel and another set retained at Engineering TestCenter for future use.

25. Equipment cleaning procedures that will be used are described below:

SKGllrpts 3Newport RFI

SR306576

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A. Laboratory clean and wrap Teflon® bailers, according to the followingprocedures (reference: New Jersey Department of EnvironmentalProtection, Field Sampling Procedures Manual, February 1988):

a. non-phosphate detergent and tap water washb. tap water rinsec. deionized water rinsed. 10% nitric acid rinsee. deionized water rinsef. hexane rinseg. total air dryh. deionized water rinsei. wrap in hexane rinsed aluminum foil

B. Clean submersible pumps, including internal components with non-phosphate detergent wash and tap water rinse. Flush with potable water.

3.0 HEALTH AND SAFETYA site specific safety plan is provided as Attachment 1.

4.0 FINAL REPORTA final report will be prepared, which summarizes the field activities, field parameters, generalsampling information and chain of custody procedures.

AR306577

SKGl/rptsNewport RFI

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UNSCANNED ITEM(S)

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PHOTOGRAPHSDRAWINGS

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FIGURE 3

Form 90-1626No. . ______

Du PONT ENVIRONMENTAL REMEDIATION SERVICES500 W. Dutton's Mill Road, Suite 102Aston, PA 19014(215)497-5800Fax: (215)485-3184

TRAFFIC REPORT FORM

Project Name | [Sample Number | ' Sample DataLocation:

Project Location Project Number

Date Time

ab e! Shipping Information Project Personnel - .... , _ , _ . ,——rr °————————————' ' ————————— Conditions of Samples ReceivedCheck One: Sampler: v ... - . . , . .Yes No Samples received intactQ Fed Ex ———————————————— Yes No Samples at 4 degrees (C)Q UPS Project Manager Yes No Samples not leaking

Other Yes No Container numbers match———————:————————— Yes No Container tags match Chain-Of-Custody

—————— Yes No Cooler received with Custody SealsShip To | Sample Matrix , v .. ,. , .... ,•——£-———————————————I ———"———••————————— Yes No Samples within bagsCheck One: Check One:

DERS Laboratories 1i Liquid ~z——TT-————7-7—:—:————r——TZ~~T~-———500 W. Dutton's Mill Rd. 3 Solid *?? *"? °f * Numb€r °f ContainereSuite 102 Q Other and Approximate VolumeAston, PA 19014(215)497-7000 Sample Description

•3 Other ——~—————~——

\Login Personne , Q

Check Applicable:3 Surface WaterQ GroundwaterG LeachateQ SedimentQ SoilQ Solid

No. ofBottles

TotalVolume!

Analyses / MethodRequired

Name:

Additional CommentsSignature

Special Handling(Safety Procedures/Hazards)

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AR306582

4J 9i i

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TABLE 2

ANALYSES AND SCHEDULEPHASE III GROUNDWATER SAMPLING PROGRAM

DU PONT'S NEWPORT SITENEWPORT, DELAWARE

SampleDate1

Nov. 7Nov. 7Nov. 7Nov. 7Nov. 7Nov. 7Nov. 8Nov. 8Nov. 8Nov. 8Nov. 8Nov. 8Nov. 8Nov. 8Nov. 9Nov. 9Nov. 9Nov. 9Nov. 9Nov. 9Nov. 9Nov:9Nov. 12Nov. 12Nov. 12Nov. 12Nov. 12Nov. 12Nov. 12Nov. 12

WellNo.

MW-18BMW-18AMW-14MW-7CMW-7BMW-7AMW-13MW-6CMW-6BMW-6A(F)MW*11MW-SCMW-5BMW-5AMW-19BMW-6A(A)MW-4CMW-3CMW-3BDM-6MW-29CMW-29B

MW-28BMW-28AMW-34BMW-34AMW-21BMW-23AMW-24AMW-25A

AnalysesTCLvocXXXXXXXXXXXXXXXXXXXXXXXXXXXXX

• X

TAL Metals(Total &Dissolved)

XXXXXXXXXXXXXXXXXXXXXX .XXXXXXXX

TCLSemi-Volatile

«

•* •

•X

XXXXXXXXXX

TCLPest &PCB's

*

X

XXx ,XXXXXXX

Waste2Classification

NH 'NHNHNHNH •NHNHNHNHNH [NHNH A\

'• NH 1NHNHNHNHNHNHNHNHNH"NHNHNHNHNHNHNHNH

AR306585

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TABLE 2

(CONTINUED)

SampleDate1

Nov. 13.Nov. 13Nov. 13Nov. 13Nov. 13Nov.- 13Nov. 13Nov. 13Nov. 13

Nov. 14Nov. 14Nov. 14Nov. 14Nov. 14Nov. 14Nov. 14Nov. 14Nov. 14

Nov. 15Nov. 15Nov. 15Nov. 15Nov. 15Nov. 15Nov. 15Nov. 15 '

WellNo.

MW-26BSMW-26BDMW-8MW-9DM-U7DM-L7MW-4BMW-4AMW-15

MW-16AMW-21AMW-19AMW-17BMW-17AMW-2CMW-2BMW-2A(A)MW-2A(F)

SM-3MW-1CMW-1BMW-1A(A)MW-1A(F)MW-3ASM-4SM-2

Analyses *TCLvocx.XXXXXXXX

XXXXXXXXX

XXXX 5XXXX

TAL Metals(Total &.Dissolved)

XXXXXXXXX

XXXXXXXXX

X.XXXXXXX

TCLSemi'Volatile

XX

•-

X

X•

X

TCLPest &PCB's

XX

X

X

*

X

Waste2Classification

NHNHOHOHOH"OHOHOHOH

OHOHOHOHOHOHOHOH "OH

OHOHOHOHOH .OHOH

' OH

AR306586Page -2-

GCTrjva • vGroundwater 911/5/90

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TABLE 2

(CONTINUED)

SampleDate1

Nov. 16Nov. 16 •Nov. 16Nov. 16Nov. 16Nov. 16

Nov. 19Nov. 19Nov. 19Nov. 19Nov. 19-Nov. 19Nov. 19Nov. 19

Nov. 20Nov. 20Nov. 20Nov. 20Nov. 20Nov. 20Nov. 20Nov. 20

Nov. 21Nov. 21Nov. 21Nov. 21Nov. 21Nov. 21Nov. 21Nov. 21

WellNo.

MW-36AMW29A(A).MW29A(F)MW-37ADM-8SM-5

MW-32BMW-32AMW-32FSM-1MW-33CMW-33AMW-31 AMW-31 F

MW-38FMW-39FMW-35CMW-35BMW-35AMW-30BMW-30AMW-30F

MW-28CWW-11MW-26AMW-27AMW-20AMW-20BMW-33BMW-31 B

Analyses |TCLvocXXXXXX

XXXXXXXX

XXXXXXXX

XXXXXXXX

TAL Metals(Total &Dissolved)

XXXXXX

XXXXXXXX

XXX.XXXXX

XXXXXXXX

TCLSemi-Volatile

XXXX

XXX

XXXX

XXX

•• XXXXX

X

XXXXXX

TCLPest &PCB's

XXXX

X. XX

XX

' XX

XXXXXXXX

X

XXXXXX

Waste2Classification

OHOHOHOHOHOH

OH• OHOH 'OHOHOHOHOH

OH fOH

. CHOHOHOHOHOH

NHNHOHOHOHOHOHOH

GCT:jvaGroundwater 911/5/90

Page -3- SR3Q6587

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TABLE 2

(CONTINUED)

. NOTES:

1 Sample dates are estimated. They are Hkely to vary according to weather* conditions and other unforeseen events. .

2 NH - Non-hazardous wastesOH - On hold wastes (as given by Du Pont Engineering Services)

Page -4- SR306588GCT:jvaGroundwator 911/5/90

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TABLE 3

ANALYSES TO BE PERFORMEDPHASE III GROUNDWATER SAMPLING PROGRAM

DU PONT-NEWPORT SITENEWPORT, DELAWARE

t.

Analytical Group I

Includes .all Pre-Phase III wells (Total of 44)*" •. *

Parameters: • .TCL Volatile Organics * . ' ' : . . 'TAL Metals (total and dissolved)

QC Samples:10% Field Duplicates (5)10% Field Blanks (5)5% Matrix Spikes (3), MS5% Matrix Spike Duplicates (3), MSD

MS and MSD samples to be collected togetherwith a primary sample (not a field blank);triple volume needed at locations where MS andMSD samples are to be collected.

l Trip Blank per shipment to lab.

Preservatives:HC1 for Volatile OrganicsHNO3 for Metals

Analytical Group II

Includes all Phase III wells (total of 42).

Parameters:TCL Volatile OrganicsTCL Semi-Volatile OrganicsTCL Pesticides and PCBsTAL Metals (Rota'1 and dissolved)

QC Samples: Same as Group I

Preservatives: Same as Group I

Glassware •Volatile Organics 2 - 40 mlMetals , 2-1 literSemi-Volatile Organics 2-1 literPesticides and PCBs 2-1 liter AR3Q65890

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HEALTH AND SAFETY PLANADDENDUM

Project Site; Hn Pom Newport SiteNewport, Delaware

DERS Project No: . " 90102Activity: Groundwater Monitor Well Sampling ,Project Manager; Joel Karmn/ynHealth ayci Safety Officer: Kim Dalsis

This addendum is prepared to provide information on additional site activities and the associatedhealth 'and safety protocols to be employed during these activity. This addendum is to be usedin conjunction with the Health and Safety Plan developed for the RemedialInvestigation/Feasibility Study prepared by Woodward Clyde Consultants. All persons involved.with this field activity must read and comply with the requirements set forth in the HASP anddocument compliance by signing the Health -and Safety compliance agreement. Site activitieswill be conducted by Du Pont Environmental Remediation Services, Inc. (DERS) and 'Engineering Field Services (EPS) and will involve the purging' and sampling of 86 wellsthroughout the Newport site. All purge water and decontamination solutions will be containedin n tanker truck.

Sampling will be initiated at a modified Level D protection (Tyvek, latex inner glove, nitrileouter glove, safety goggles or splash shield). In addition, sleeves must be taped to gloves. Thislevel is selected based on i?\e chemicals of concern and the air monitoring data generated duringthe monitor well installation. See section 4.0, Hazard Assessment of the original HASP for thespecific compounds of concern.

Real time air monitoring will be performed using either HNu with an I l.v or 10.2 eV probe oran OVA-Monitoring of ihe inner Using will be performed upon initial opening and in theworkers breathing /one during sampling. If sustained readings of 5 ppm above background inthe workers breathing zone during sampling. It sustained readings of 5 ppm above backgroundin the workers breathing 7.one are detected, an upgrade to I-evel C (organic vapor/acid gascartridges) will be required.

• ' *

The decontamination of sampling equipment and personnel will be conducted at a designatedlocation and will be performed in accordance with 7.1 of the original HASP.

Addendum Approval (Groundwater Monitor Well Sampling),~\ • ' is

' *Joeh&rrna/.yn * •' ' r ' • . • DaleProject Manager ' <.-

Mary L. /01owacki, tHMM . DateHealth and Safety Consultant $ R 306590

Du POM ENVIRONMENTAL RCMCDIATION SERVICES

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HEALTH AND SAFETY PLAN COMPLIANCE AGREEMENT

I have read, undeistand, and agree to comply with the protocols presented in the Health

and Safety Plan (HASP) and information discussed in the health and safety briefing. I alsounderstand that non-compliance with the HASP may result in dismissal from the site.

PRINTED NAME ORGANIZATION SIGNATURE PATE

Personal Health and Safety Briefing Conducted by:

Name Signature Date

AR306S9.I