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

Project No.: 0317.01.005.510 Page 1 of 1

Project Name: DMR2011 CBI?

Yes

No

TELEPHONE CALL RECORD

Incoming

Outgoing

Date: 01/15/14 Time: 4:40 am

pm

Company Name: Aventis Cropscience ERG Staff Name: Kimberly Bartell

Contact Name: Gordon Smith Contact Phone Number: (304)-767-6069

General Subject: 2011 DMR PCB Discharges 

TOPICS DISCUSSED AND ACTION TAKEN

On January 15th, I called Cindy Elkins (304-747-5684) and she referred me to MaryAnn McClure (304-747-

7902; szulm2@dow.com). I called Ms. McClure and left a message. On January 16th, Ms. McClure returned my 

call and requested a formal request from ERG. Please see attached email communication. Ms. McClure called 

and left a message stating that this was not the correct facility but that she forwarded my information to the 

correct facility contact. On January 20th, I received an email from Ms. McClure with the correct contact 

information – see below. 

Gordon Smith: 304-767-6069, gordon.smith@bayer.com

Connie Stewart: 304-767-6123, connie.stewart@bayer.com

On January 20th, I called Mr. Smith and he referred me to Ms. Stewart. I called Ms. Stewart and left a message.

On January 22nd at 1:30pm, I called Ms. Stewart and spoke to her receptionist, Kim Burgess. She requested that 

I send her an email with the information and she would give everything to Ms. Stewart to follow up on. Kim’s 

email is kim.burgess@bayer.com. 

On January 22nd at 2:30, Ms. Stewart and Mr. Smith returned my call. They stated that they have submitted data 

corrections to WVDEP and are waiting for the corrections to get verified in the system. Ms. Stewart requested 

that I email them our data and they will provide data corrections along with the letter they sent to DEP stating 

the reason behind the changes. Please see attached email communication.

On January 24th at 1:33, Gordon Smith returned my call and stated that all data for 2011 should be BDL. The 

facility reported the following values on their DMR (all method detection limits). He stated he would send a 

follow up email to confirm the data.

3/31/11: <0.672 ug/L

6/30/11: <0.71 ug/L

9/30/11: <0.71 ug/L
Email Communication with Aventis Cropscience

From: Kimberly Bartell

To: Gordon Smith

Date: 1/31/14 4:04 PM

Subject: RE: 2011 DMR Clarification for PCB Discharges

Mr. Smith,

Thank you very much for getting back to me. I will let you know if we have any further 

questions.

Kimberly

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

Kimberly D. Bartell

Environmental Engineer

Eastern Research Group, Inc. 

kimberly.bartell@erg.com

Phone: 517-515-1721

From: Gordon Smith

To: Kimberly Bartell

Date: 1/31/14 4:01 PM

Subject: RE: 2011 DMR Clarification for PCB Discharges

Please let me know if you have any questions or need additional information. E-mail 

(gordon.smith@bayer.com) Phone(304-767-6069) cell (3044151345). 

Note: Data was attached to email.

From: Connie Stewart 

Sent: Thursday, January 23, 2014 12:41 PM

To: GORDON SMITH

Cc: Tony Elmore

Subject: FW: 2011 DMR Clarification for PCB Discharges

Gordon, can you follow-up on the request and as the data is available I’ll reply also with the 

letter already attached to the e-DMRs?
Freundliche Grüße / Best regards,

Connie Stewart

Director of QHSE

Bayer CropScience LP

Institute Site

Phone: +1 304 767 6123

Mobile: +1 304 741 3629

Fax: 304 767 6063

E-mail: connie.stewart@bayer.com

Web: http://www.bayercropscience.com

Vorstand: Liam Condon, Vorsitzender | Lykele van der Broek, Achim Noack, Rüdiger 

Scheitza, Michael A. Schulz

Vorsitzender des Aufsichtsrats: Werner Baumann

Sitz der Gesellschaft: Monheim am Rhein | Eintragung: Amtsgericht Düsseldorf, HRB 46985

From: Kimberly Bartell

To: connie.stewart@bayer.com

CC: Elizabeth Sabol, Kim Wagoner, Swietlik.william@epa.gov

Date: 1/20/14 8:15 AM

Subject: 2011 DMR Clarification for PCB Discharges

Dear Ms. Stewart & Mr. Smith,

Thank you for your time on the phone today. Eastern Research Group, Inc. (ERG) under EPA 

Contract No. EP-C-12-021,is e-mailing you on EPA's behalf to request clarification of 2011 

discharge monitoring reports for Aventis Cropscience in Institute, WV (WV0000086). Here is 

some background on what the information is used for. 

EPA reviews publicly-available DMR data to fulfill its review obligation under Section 304(b) of 

the Clean Water Act (CWA). 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 2013 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 2013 Effluent Guidelines Program Plan scheduled for publication in 

the Federal Register in 2014. As part of the 2013 annual review, EPA is evaluating the data in 

discharge monitoring reports from 2011 and needs further information to complete the review.

We would like to obtain additional information on the following 2011 discharge data for PCB 

for the Aventis Cropscience facility. Our records show the following values were discharged: 

Outfall 001:

Date

PCB 

Concentration 

(mg/L)

Wastewater 

Flow (MGD)

3/31/2011 0.00033 4

6/30/2011 0.00035 4.12

9/30/2011 0.00035 4.084

Please also send a copy of the letter sent to WV DEP and your current NPDES permit. We 

appreciate your help in confirming if the above data are accurate, or if there are units errors in 

the DMR data. 

Please call me at (517) 515-1721 if you have any questions. 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,

Kimberly

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

Kimberly D. Bartell

Environmental Engineer

Eastern Research Group, Inc. 

kimberly.bartell@erg.com

Phone: 517-515-1721

From: Kimberly Bartell

To: szulm2@dow.com

CC: Elizabeth Sabol, Kim Wagoner, Swietlik.william@epa.gov

Date: 1/20/14 8:15 AM

Subject: RE: 2011 DMR Clarification for PCB Discharges
Ms. McClure,

Thank you for forwarding this information, I appreciate your assistance. I will contact Gordon 

Smith and Connie Stewart directly.

Kimberly

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

Kimberly D. Bartell

Environmental Engineer

Eastern Research Group, Inc. 

kimberly.bartell@erg.com

Phone: 517-515-1721

From: McClure, Marianne (MF) [szulm2@dow.com]

To: Kimberly Bartell

CC: Elizabeth Sabol, Kim Wagoner, Swietlik.william@epa.gov

Date: 1/20/14 7:52AM

Subject: RE: 2011 DMR Clarification for PCB Discharges

Kimberly,

The contact info I have for that NPDES permit number is as follows. I forwarded your request to 

them last week but have not gotten a response. You may want to contact them directly.

Gordon Smith – Gordon.Smith@Bayer.com, 304.767.6069

Connie Stewart – Connie.Stewart@Bayer.com, 304.767.6123

I am not involved with the DMRs for WV0000086; sorry I can’t help with your data request.

Hopefully either Connie or Gordon can be of assistance.

Marianne McClure

EH&S Regulatory Affairs

Infrastructure Operations Leader

Union Carbide Corporation

A Subsidiary of The Dow Chemical Company

West Virginia Operations

office: (304) 747-7902

mobile: (304) 550-0351

From: Kimberly Bartell
To: szulm2@dow.com

CC: Elizabeth Sabol, Kim Wagoner, Swietlik.william@epa.gov

Date: 1/16/14 9:46 AM

Subject: 2011 DMR Clarification for PCB Discharges

Dear Ms. McClure,

Thank you for your time on the phone today. Eastern Research Group, Inc. (ERG) under EPA 

Contract No. EP-C-12-021,is e-mailing you on EPA's behalf to request clarification of 2011 

discharge monitoring reports for Aventis Cropscience in Institute, WV (WV0000086). Here is 

some background on what the information is used for. 

EPA reviews publicly-available DMR data to fulfill its review obligation under Section 304(b) of 

the Clean Water Act (CWA). 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 2013 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 2013 Effluent Guidelines Program Plan scheduled for publication in 

the Federal Register in 2014. As part of the 2013 annual review, EPA is evaluating the data in 

discharge monitoring reports from 2011 and needs further information to complete the review.

We would like to obtain additional information on the following 2011 discharge data for PCB 

for the Aventis Cropscience facility. Our records show the following values were discharged: 

Outfall 001:

Date

PCB 

Concentration 

(mg/L)

Wastewater 

Flow (MGD)

3/31/2011 0.00033 4

6/30/2011 0.00035 4.12

9/30/2011 0.00035 4.084

Please also send a copy of your current NPDES permit. We appreciate your help in confirming if 

the above data are accurate, or if there are units errors in the DMR data. 

Please call me at (517) 515-1721 if you have any questions. 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,

Kimberly

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

Kimberly D. Bartell

Environmental Engineer

Eastern Research Group, Inc. 

kimberly.bartell@erg.com

Phone: 517-515-1721