Need to return call by / at/between and . Signature:

Project No.: 0317.02.005.520 Page 1 of 3

Project Name: 2015 Annual Review – Preliminary 

Category Review OCPSF (PSC 414) CBI?

Yes

No

TELEPHONE CALL RECORD

Incoming

Outgoing

Date: 05/08/2015 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 called 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 of 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.com
Need 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 Clarification 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 Affairs 

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.com
Need 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, Inc. (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 for.

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 its 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 existing 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. Specifically, 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 taken 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