From: Scott T Northey <Scott.T.Northey@USA.dupont.com>

To: Sabol, Elizabeth Date: 2/28/2011 0:36 AM Subject: Re: 2009 TRI Du Pont PCB Discharges

ElizabethSorry for the delay in my response - I was out sick most of Thursday and Friday.

In blue type below you will find our responses to y our inquiries on 2009 TRI information for PCBs:

1. Please confirm the pounds of PCB released in 200 9: 0.7 pounds The 0.7 lbs of PCB reported as release to surface w ater in 2009 is correct.

2. Please explain how the PCB load is calculated. The PCB in WWTP effluent is a calculated value base d on input loads to WWTP. The data source used was an analysis of the weekly composite sample of off-site waste waters coming in to the facility. During 2009, two weekly composites detected PCB aroclor-1242 for weeks ending 1/29/09 and 5/13/09. These concen trations are converted to a mass loading influent t o WWTP and the effluent PCB is calculated using a Toxchem Plus modeling par tition factor to the aqueous effluent.

3. Can you estimate which PCBs were released? Yes, aroclor-1242 based on laboratory analysis.

4. Is the mass released based on actual sampling da ta, and were PCBs detected? Or, were releases estimated based on valu es below the detection limit? Per response to Question 2, PCBs were based on dete cted PCB concentrations.

5. What is the source of the PCBs in the waste wate r? The source was an off-site waste disposer(s).

If you have any additional questions or need addit ional information, please give me a call.

Scott 856-540-2012

From: Elizabeth Sabol To: scott.t.northey@usa.dupont.com CC: Codding, Eleanor; Gray, Jessica; swietlik.willia m@epa.gov Date: 2/15/2011 2:55 PM Subject: 2009 TRI Du Pont PCB Discharges

Scott,

Thank you for your time on the phone today. As disc ussed, EPA is requesting clarification of 2009 TRI data as part of our 2011 annual review of industrial discharges under Sectio n 304 of the Clean Water Act. I am writing to reque st clarification for DuPont Chambers Works, on behalf of EPA under Contract No. 68-C-02-095. Please find some background below.

EPA reviews TRI data to fulfill its review obligati on under Section 304(b) of the Clean Water Act. The CWA requires EPA to annually review and, if appropriate, revise its water pollut ion control technology-based regulations, called “e ffluent limitations guidelines” or "effluent guidelines,” that limit the discharge of pollutants to waters of the U.S. from various categ ories of industrial facilities. EPA is currently conducting its 2011 annual review of e xisting effluent guidelines and potential industria l guidelines which may need to be included (see http://www.epa.gov/guide/304m/ for further information). EPA will discuss this re view and the results in its 2011 Effluent Guidelines Program Plan scheduled for publ ication in the Federal Register in 2011.

As part of the 2011 annual review, EPA is evaluatin g the data reported to the 2009 TRI and needs furth er information to complete the review. Specifically, we would like to clarify the amount of PCB releases reported to the 2009 TRI from DuPont Chambers Works, Deepwater, NJ (08023DPNTCRT130) plant. Pleas e confirm/review the following data and questions:

1. Please confirm the pounds of PCB released in 200 9: 0.7 pounds 2. Please explain how the PCB load is calculated. 3. Can you estimate which PCBs were released?4. Is the mass released based on actual sampling da ta, and were PCBs detected? Or, were releases estim ated based on values

below the detection limit? 5. What is the source of the PCBs in the wastewater ?

We appreciate your help in interpreting TRI data co rrectly. If you have any questions regarding this r equest, please call me at (703) 633-1659. If you would like to speak directly with EPA regarding this request, you can contact Willia m 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, Elizabeth

Elizabeth A. Sabol Environmental Engineer Eastern Research Group, Inc. 14555 Avion Parkway, Suite 200 Chantilly, VA 20151 elizabeth.sabol@erg.com Phone:703-633-1659

## DuPont Chambers Works – Deepwater, NJ (08023DPNTCRT130)

PCBs 2009 2008 2007 2006 2005 Pounds Released 0.7 NR NR NR 0.3
TWPE 23,824 NR NR NR 10,210



## Facility contact provided information that the only PCB detected was arochlor-1242 (PCB-1242). The TWF for PCB-1242 is 9,136. The TWF for PCB is 34,033.6 and no distribution is available. Below, please find the LBY calculations to result in the correct TWPE.

Reported LBY: 0.70
PCB TWF: 34,033.60
PCB TWPE: 23,823.52
PCB-1242 TWF: 9,136.00
PCB-1242 TWPE: 6,395.20
New LBY: 0.19
Check TWPE: 6,395.20