From: Kenneth N Wood <Kenneth.N.Wood@USA.dupont.com> 

To: <Eleanor.Codding@erg.com> 

CC: <swietlik.william@epa.gov> 

Date: 11/22/2010 5:46 PM 

Subject: Re: Request for Clarification of 2008 TRI Data for EPA's Annual Review 

Ellie, 

You have our permission to remove the confidentiality claim footer from 

the email correspondence and include the information transmitted on April 

21, 2010 in the public docket. 

Regards, 

Ken 

"Eleanor Codding" <Eleanor.Codding@erg.com> 

11/19/2010 05:49 AM 

To 

Kenneth N Wood/AE/DuPont@DuPont 

cc 

<swietlik.william@epa.gov> 

Subject 

Re: Request for Clarification of 2008 TRI Data for EPA's Annual Review 

Ken, 

 

I would like to request your permission to include the information you 

sent below as part of documentation made available at regulations.gov. 

 

EPA is nearing publication of its 2010 Final Plan and hopes to include the 

email (and spreadsheet attachment) below as part of documentation that 

describes the corrections made to the 2008 screening-level review 

database. However, when there is an email signature/footer that claims 

information as confidential, EPA cannot include it a part of the public 

docket and handles it as CBI. If you approve, we will simply remove the 

following footer from the email correspondence and include this 

information in the public docket. 

 

If you could let us know your thoughts before Thanksgiving, I would 

appreciate it, as it would give us time to include the information in the 

docket. 

 

Thanks, and please feel free to email any questions to myself or Bill 

Swietlik, the EPA contact who leads this work (William Swietlik, 

swietlik.william@epa.gov). 

 

- Ellie Codding 

 

*FOOTER LANGUAGE BELOW* 

This communication is for use by the intended recipient and contains 

information that may be Privileged, confidential or copyrighted under 

applicable law. If you are not the intended recipient, you are hereby 

formally notified that any use, copying or distribution of this e-mail, 

in whole or in part, is strictly prohibited. Please notify the sender by 

return e-mail and delete this e-mail from your system. Unless explicitly 

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not constitute a contract offer, a contract amendment, or an acceptance 

of a contract offer. This e-mail does not constitute a consent to the 

use of sender's contact information for direct marketing purposes or for 

transfers of data to third parties. 
 

----------------------------------------------------- 

Eleanor Ku Codding, P.E. 

Eastern Research Group, Inc. 

14555 Avion Parkway, #200 

Chantilly, VA 20151 

703-633-1673 (voice) 

703-263-7280 (fax) 

http://www.erg.com>>> Kenneth N Wood <Kenneth.N.Wood@USA.dupont.com> 

4/21/2010 3:04 PM >>> 

Ellie, 

Attached is our response to the request for clarification of 2008 TRI data 

for the four subject DuPont facilities. Let us know if you have any 

further questions. 

We appreciate the followup as we agree that correct data interpretation is 

critical in the effluent guidelines review process. And thanks for your 

patience and understanding as we took extra time to ensure the accuracy of 

our responses. 

Regards, 

Ken 

"Eleanor Codding" <Eleanor.Codding@erg.com> 

03/18/2010 04:27 PM 

To 

Kenneth N Wood/AE/DuPont@DuPont 

cc 

<swietlik.william@epa.gov> 

Subject 

Request for Clarification of 2008 TRI Data for EPA's Annual Review 

Ken, 

It's been 4 years since we last requested such data, but I am writing to 

request clarification of TRI data for four Du Pont facilities, on EPA's 

behalf under EPA Contract No. 68-C-02-095. 

As before, EPA reviews 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 limitations guidelines” or 

"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 2010 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 2010 Effluent Guidelines 

Program Plan scheduled for publication in the Federal Register in December 

2010. 

As part of the 2010 annual review, EPA is evaluating the data reported to 

the 2008 TRI and needs further information to complete the review. 

Specifically, we would like to clarify the amount of dioxin/furan releases 
and the congener distribution reported to the 2008 TRI from the following 

Du Pont plants (detailed in the attached spreadsheet): 

1. New Johnsonville. Is the mass released and congener distribution in the 

spreadsheet accurate for water releases? Starting in 2008, the TRI allowed 

for reporting media-specific congeners. Also, the congener numbering 

changed. 

2. Edgemoor. Is the mass released accurate for water releases? Can you 

estimate what congeners were released? If not, we can estimate one based 

on the New Johnsonville facility. Would this be accurate? 

3. DeLisle. Is the mass released accurate for water releases? Can you 

estimate what congeners were released? If not, we can estimate one based 

on the New Johnsonville facility. Would this be accurate? 

4. Starke. Do you prefer to coordinate our requested data for the Starke 

facility? If not, ERG can contact the listed TRI contact directly (see 

spreadsheet). Is the mass released and congener distribution in the 

spreadsheet accurate for water releases? Is the mass released based on 

actual sampling data, and were dioxins/furans detected? Or, were releases 

estimated based on values below the detection limit? The congener 

distribution listed in the spreadsheet was reported for air, not water (no 

distribution was reported for water releases). 

We appreciate your help in interpreting TRI data correctly. 

If you have any questions regarding this request, please call me at (703) 

633-1673. 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. 

Thanks, 

- Ellie Codding 

----------------------------------------------------- 

Eleanor Ku Codding, P.E. 

Eastern Research Group, Inc. 

14555 Avion Parkway, #200 

Chantilly, VA 20151 

703-633-1673 (voice) 

703-263-7280 (fax) 

http://www.erg.com[attachment "Du Pont 2008 TRI Data.xls" deleted by 

Kenneth N Wood/AE/DuPont] 

This communication is for use by the intended recipient and contains 

information that may be Privileged, confidential or copyrighted under 

applicable law. If you are not the intended recipient, you are hereby 

formally notified that any use, copying or distribution of this e-mail, 

in whole or in part, is strictly prohibited. Please notify the sender by 

return e-mail and delete this e-mail from your system. Unless explicitly 

and conspicuously designated as "E-Contract Intended", this e-mail does 

not constitute a contract offer, a contract amendment, or an acceptance 

of a contract offer. This e-mail does not constitute a consent to the 

use of sender's contact information for direct marketing purposes or for 

transfers of data to third parties. 

Francais Deutsch Italiano Espanol Portugues Japanese Chinese Korean 

 http://www.DuPont.com/corp/email_disclaimer.html 

This communication is for use by the intended recipient and contains 
information that may be Privileged, confidential or copyrighted under 

applicable law. If you are not the intended recipient, you are hereby 

formally notified that any use, copying or distribution of this e-mail, 

in whole or in part, is strictly prohibited. Please notify the sender by 

return e-mail and delete this e-mail from your system. Unless explicitly 

and conspicuously designated as "E-Contract Intended", this e-mail does 

not constitute a contract offer, a contract amendment, or an acceptance 

of a contract offer. This e-mail does not constitute a consent to the 

use of sender's contact information for direct marketing purposes or for 

transfers of data to third parties. 

Francais Deutsch Italiano Espanol Portugues Japanese Chinese Korean 

 http://www.DuPont.com/corp/email_disclaimer.html 
Response to Request for Clarification of 

2008 TRI Data for EPA's Annual Review 

DuPont Company, April 21, 2010 

1. New Johnsonville

The total reported 2008 mass releases to water for dioxin and dioxin-like compounds 

(DDLC) of 2.77 gm. is correct but the congener distribution in the spreadsheet is not. 

The 2007 TRI congener order was mistakenly used instead of the new 2008 congener 

renumbering and order. Upon recognition of the error, a TRI DDLC Form R revision was 

submitted to EPA and the state of Tennessee on 3/22/2010. The corrected mediaspecific congener distribution for water releases, which is based on two sets of analytical 

results, indicates that 100% of the total DDLC is in the form of OCDD. 

2. Edge Moor

The total reported 2008 mass releases to water for dioxin and DLCs of 0.57 grams is 

correct. The media-specific congener distribution for water releases is correct as 

provided in the site’s 2008 TRI report submittal. The calculated congener distribution 

was based on actual sampling and analysis conducted for the Edge Moor facility in 2008 

and is as follows: 

 

1,2,3,4,6,7,8-HPCDD

OCDD

5.91%

65.11%

1,2,3,4,6,7,8-HPCDF 2.73%

1,2,3,4,7,8,9-HPCDF 0.19%

OCDF 26.06%

3. DeLisle

The actual reported 2008 mass releases to water for dioxin and dioxin-like compounds 

(DDLC) is 0.0602 grams, which rounds up to 0.1 grams as shown in the spreadsheet for 

DeLisle. For the congener distribution, site-specific analytical data are available. Like 

New Johnsonville, the 2007 TRI congener order was mistakenly used instead of the new 

2008 congener renumbering and order. DeLisle’s most up-to-date information for 

congener and mass release amount is reflected in their TRI report DDLC Form R 

revision submitted electronically to EPA on 4/14/10 and submitted in hard copy to the 

state of Mississippi. 

The correct media-specific congener distribution for water releases is as follows: 

1,2,3,4,6,7,8-HpCDF 15.06% 

OCDF 84.94% 

Total 100.00% 
4. Starke 

The total estimated 2008 mass releases to water for dioxin and DLCs of 0.04 grams is 

correct. However, the congener distribution in the spreadsheet is not accurate. Starke 

made the same error as DeLisle and New Johnsonville. A revised TRI report DDLC Form 

R was filed with the EPA on 04/16/10. 

Note that the DuPont Starke facility is not in the same industrial category as the above 

three titanium dioxide manufacturing facilities. It is covered under SIC code 1099 

(NAICS 212299) Mining-Other. The facility does not generate or manufacture any

dioxin or furan compounds. The only potential source is from the use of chemicals 

in its wastewater treatment operations. Releases estimated are based on annual total 

consumption of and quality information provided by the supplier of the wastewater 

treatment chemicals. 

The correct media-specific congener distribution for water releases is shown in the table 

below: 

Congener % of 

Total

1,2,3,4,6,7,8-HpCDF 0.9 

1,2,3,4,7,8,9-HpCDF 0.45 

1,2,3,4,7,8-HxCDF 0.18 

1,2,3,6,7,8-HxCDF 0.03 

1,2,3,7,8,9-HxCDF 0 

2,3,4,6,7,8,-HxCDF 0.03 

1,2,3,4,7,8-HxCDD 0 

1,2,3,6,7,8-HxCDD 0 

1,2,3,7,8,9-HxCDD 0 

1,2,3,4,6,7,8-HpCDD 0 

OCDF 97.99 

OCDD 0.36 

1,2,3,7,8-PeCDF 0.02 

2,3,4,7,8-PeCDF 0.02 

1,2,3,7,8-PeCDD 0 

2,3,7,8-TCDF 0.02 

2,3,7,8-TCDD 0 

Total 100