Need to return call by / at/between and

. Signature: Project No.: 0 317.0 2 .005.52 0 Page 1 of 3

Project Name: 2015 Annual Review

– Preliminary

Category Review OCPSF (PSC 414 ) 

### CBI?

Yes

No TELEPHONE CALL RECOR D

Incoming

Outgoing Date: 05 / 0 8 / 20 15 Time: 11 :00 am

pm

Company Name: The Dow Chemical Co

. ERG Staff Name: Eva Knoth

Contact Name: Nathan Kerns

, Michigan Operations Public

Affairs

Rob Rouse

, EH&S Regulatory Services Contact Phone Number: 989

- 633

- 4975

kerns@dow.com

989

- 638

- 4003

rmrouse@dow.com

General Subject: 2013 TRI Dioxin Releases from Dow Chemical Co

. , Midland, MI

TRI ID: 48667THDWCMICHI



### TOPICS DISCUSSED AND ACTION TAKEN

I left a message on May 8 , 2015 at 11 am

.

Mr. Kerns returned my call at 11:45 am and requested further information via email so he could review the

information and send us a response. Please see attached email communication.

Rob Rouse call ed on May 26 to request mailing addresses for ERG and EPA. He will be sending a written

response to the questions in the email below. He verbally confirmed the reported release of dioxins and

explained that the dioxins are measured in accordance with the facility’s NPDES permit, using EPA Method

1613B, 24 hour composite. For TRI annual loading calculations, non

- detects were treated as zero. The dioxins

are historical byproducts o f manufacturing and combustion and were never produced at the facility.

From: Rouse, Rob (RM) [mailto:RMRouse@dow.com]

Sent: Monday, May 18, 2015 7:44 AM

To: Kerns, Nathan; Eva Knoth

Subject: RE: 2013 TRI Clarification for Dioxin Water Releases

We are currently gathering the information. I believe we are waiting to hear back from our analytical contacts

regarding the methods used.

_____ ______________________________ Rob Rouse

EH&S Regulatory Services

The Dow Chemical Company

1790 Building

Midland, MI 48674 USA

Office: 989

- 638

- 4003

Cell: 989

- 859

- 4169

Fax: 989

- 638

- 7800

E

- mail: rmrouse@dow.comNeed to return call by / at/between and

. Signature: From: Kerns, Nathan

Sent: Friday, May 15, 2015 11:32 AM

To: Eva Knoth

Cc: Rouse, Rob (RM)

Subject: RE: 2013 TRI Clarificati on for Dioxin Water Releases

Hi Eva,

My colleague Rob Rouse, copied here, will be providing you with answers to your questions.

Rob

- please see Eva’s email below about timing for the response.

Regards,

Nate

Nathan Kerns

Michigan Operations Public Affa irs

The Dow Chemical Company

1790 Building Michigan Ops Midland, MI 48667

phone: 989.633.4975 | email: kerns@dow.com

From: Eva Knoth [ mailto:Eva.Knoth@erg.com ]

Sent: 15 May 2015 11:16

To: Kerns, Nathan

Subject: RE: 2013 TRI Clarification for Dioxin Water Releases

Mr. Kerns,

I wanted to confirm that you received the email below last week. If possible, it would be helpful to have a

response from you by the end of the day Tuesday (5/19).

Thank you for your time,

Eva

Eva Knoth

Environmental Engineer

Eastern Research Group, Inc. (ERG)

eva.knoth@erg.com

(703) 633

- 1648

From: Eva Knoth

Sent: Friday, May 08, 2015 12:29 PM

To: kerns@dow.comNeed to return call by / at/between and

. Signature: Cc: Swietlik, William; Kimberly Bartell

Subject: 2013 TRI Clarification for Dioxin Water Releases

Dear Mr. Kerns,

Thank you for your time on the phone this morning. As discussed, Eastern Research Group, I nc. (ERG) under

EPA Contract No. EP

- C

- 12

- 021, is e

- mailing you to request clarification of 2013 TRI water releases of dioxins

reported by The Dow Chemical Co., Midland, MI (TRI ID 48667THDWCMICHI). See below for background

on what the information is used f or.

EPA reviews publicly

- available discharge monitoring report (DMR) and toxic release inventory (TRI) data to

fulfill its review obligation under Section 304(b) of the Clean Water Act. The CWA requires EPA to annually

review and, if appropriate, revise i ts water pollution control technology

- based regulations, called "effluent

guidelines," that limit the discharge of pollutants to waters of the U.S. from various categories of industrial

facilities. EPA is currently conducting its 2015 annual review of exis ting effluent guidelines and potential

industrial guidelines which may need to be included (see http://www.epa.gov/guide/304m/ for further

information). EPA will discuss this review and the results in its 2015 Effluent Guidelines Program Plan

scheduled for publication in the Federal Register in 2015 or 2016.

As part of the 2015 annual review, EPA is evaluating the data reported to the 2013 TRI and requests further

information to complete the review. Specifical ly, we would like to clarify the amount of dioxin and dioxin

compounds reported as released to surface waters. Please confirm/review the following data and questions

below.

1. Please confirm the amount of dioxins released to surface waters in 2013: 1.8527 grams ( 0.00408

pounds )

2. Please confirm the facility reported dioxin distribution, see attached spreadsheet.

3. What methodology was used to measure or estimate the reported release? If monitoring was conducted:

how often were measurements take n and, if applicable, how were non

- detects handled?

4. What source or processes contribute to the reported release of dioxins?

We appreciate your help in interpreting TRI data correctly. If you have any questions regarding this request,

please call me at (703) 633

- 1648. If you would like to speak directly with EPA regarding this request, you can

contact William F. Swietlik of EPA' s Office of Water/Engineering Analysis Division by phone at (202) 566

- 1129 or by email: swietlik.william@epa.gov

.

Thank you,

Eva

Eva Knoth

Environmental Engineer

Eastern Research Group, Inc. (ERG)

eva.knoth@erg.com

(703) 633

- 1648