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 confidentiali ty claim footer from the email correspondence and include the informatio n 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 a nd hopes to include the email (and spreadsheet attachment) below as part of documentation that

describes the corrections made to the 2008 screenin g-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 wi ll 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 Thank sgiving, 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 (Will iam Swietlik, swietlik.william@epa.gov).

- Ellie Codding

*FOOTER LANGUAGE BELOW* This communication is for use by the intended recip ient and contains information that may be Privileged, confidential or copyrighted under applicable law. If you are not the intended recipie nt, you are hereby formally notified that any use, copying or distribu tion 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 syst em. Unless explicitly and conspicuously designated as "E-Contract Intende d", this e-mail does not constitute a contract offer, a contract amendme nt, or an acceptance
of a contract offer. This e-mail does not constitut e a consent to the

use of sender's contact information for direct mark eting 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.Woo d@USA.dupont.com>

4/21/2010 3:04 PM >>> Ellie, Attached is our response to the request for clarifi cation 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 revi ew obligation under Section 304(b) of the Clean Water Act. The CWA requ ires EPA to annually review and, if appropriate, revise its water pollut ion control technology-based regulations, called “effluent limi tations guidelines” or "effluent guidelines,” that limit the discharge of pollutants to waters of

the U.S. from various categories of industrial faci lities. EPA is currently conducting its 2010 annual review of exis ting effluent guidelines and potential industrial guidelines whic h may need to be included (see http://www.epa.gov/guide/304m/ for fu rther information). EPA

will discuss this review and the results in its 201 0 Effluent Guidelines Program Plan scheduled for publication in the Feder al Register in December

2010.

As part of the 2010 annual review, EPA is evaluatin g the data reported to the 2008 TRI and needs further information to compl ete the review. Specifically, we would like to clarify the amount o f dioxin/furan releasesand the congener distribution reported to the 2008 TRI from the following

Du Pont plants (detailed in the attached spreadshee t):

1. New Johnsonville. Is the mass released and conge ner distribution in the

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

for reporting media-specific congeners. Also, the c ongener numbering changed. 2. Edgemoor. Is the mass released accurate for wate r releases? Can you estimate what congeners were released? If not, we c an estimate one based on the New Johnsonville facility. Would this be acc urate?

3. DeLisle. Is the mass released accurate for water releases? Can you estimate what congeners were released? If not, we c an estimate one based on the New Johnsonville facility. Would this be acc urate? 4. Starke. Do you prefer to coordinate our requeste d data for the Starke facility? If not, ERG can contact the listed TRI co ntact directly (see spreadsheet). Is the mass released and congener dis tribution in the spreadsheet accurate for water releases? Is the mas s released based on actual sampling data, and were dioxins/furans detec ted? 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 co rrectly.

If you have any questions regarding this request, p lease 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 (20 2) 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 Dat a.xls" deleted by Kenneth N Wood/AE/DuPont]

This communication is for use by the intended recip ient and contains information that may be Privileged, confidential or copyrighted under applicable law. If you are not the intended recipie nt, you are hereby formally notified that any use, copying or distribu tion 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 syst em. Unless explicitly and conspicuously designated as "E-Contract Intende d", this e-mail does not constitute a contract offer, a contract amendme nt, or an acceptance
of a contract offer. This e-mail does not constitut e a consent to the

use of sender's contact information for direct mark eting purposes or for transfers of data to third parties.

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http://www.DuPont.com/corp/email_disclai mer.html

This communication is for use by the intended recip ient and containsinformation that may be Privileged, confidential or copyrighted under

applicable law. If you are not the intended recipie nt, you are hereby formally notified that any use, copying or distribu tion 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 syst em. Unless explicitly and conspicuously designated as "E-Contract Intende d", this e-mail does not constitute a contract offer, a contract amendme nt, or an acceptance
of a contract offer. This e-mail does not constitut e a consent to the

use of sender's contact information for direct mark eting purposes or for transfers of data to third parties.

Francais Deutsch Italiano Espanol Portugues Japa nese Chinese Korean

http://www.DuPont.com/corp/email_disclai mer.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 dist ribution 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 3/22/20 10. 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 i n 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 f or water releases is correct as provided in the site’s 2008 TRI report submittal. T he 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 gram s as shown in the spreadsheet for DeLisle. For the congener distribution, site-specif ic analytical data are available. Like New Johnsonville, the 2007 TRI congener order was m istakenly used instead of the new 2008 congener renumbering and order. DeLisle’s mos t up-to-date information for congener and mass release amount is reflected in th eir 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 rele ases 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 chemi cals in its wastewater treatment operations. Releases es timated 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 fo r 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