Need to return call by / at/between and

. Signature: Project No.: 0 317.0 1.005.510 Page 1 of 1

Project Name: DMR20 11 

### CBI?
Yes
No TELEPHONE CALL RECOR D Incoming Outgoing Date: 01/15 /1 4 Time: 4: 40 am
pm

Company Name: Aventis Cropscience ERG Staff Name: Kimberly Bartell

Contact Name: Gordon Smith Contact Phone Number: ( 304)

- 7 67

- 6069
General Subject: 2011 DMR PCB Discharges



### TOPICS DISCUSSED AND ACTION TAKEN

On January 15 th , 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 16 th , 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. O n January 20 th , 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 20 th , I called Mr. Smith and he referred me to Ms. Stewart. I called Ms. Stewart and left a message.

On January 22 nd 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 22 nd at 2:30, Ms. Stewart and Mr. Smith returned my call. T hey 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 24 th 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/LEmail 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 G esellschaft: 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 o n 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 "e ffluent 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 annualreview 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

- 1 129 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 DischargesMs. McClure,

Th ank 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 7:52 AM 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.Smit h@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 c an 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 BartellTo: 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 revie w 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 fa cilities. 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 in formation). 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 f rom 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:

Out fall 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 req uest, 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