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 your inquiries on 2009 

TRI information for PCBs: 

1. Please confirm the pounds of PCB released in 2009: 0.7 pounds 

The 0.7 lbs of PCB reported as release to surface water in 2009 is correct. 

2. Please explain how the PCB load is calculated. 

The PCB in WWTP effluent is a calculated value based on input loads to WWTP. The data source used was an analysis of the weekly 

composite sample of off-site waste waters coming into the facility. During 2009, two weekly composites detected PCB aroclor-1242 

for weeks ending 1/29/09 and 5/13/09. These concentrations are converted to a mass loading influent to WWTP and the effluent 

PCB is calculated using a Toxchem Plus modeling partition 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 data, and were PCBs 

detected? Or, were releases estimated based on values below the detection 

limit? 

Per response to Question 2, PCBs were based on detected PCB concentrations. 

5. What is the source of the PCBs in the waste water? 

The source was an off-site waste disposer(s). 

 If you have any additional questions or need additional 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.william@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 discussed, EPA is requesting clarification of 2009 TRI data as part of our 2011 

annual review of industrial discharges under Section 304 of the Clean Water Act. I am writing to request 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 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 2011 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 2011 

Effluent Guidelines Program Plan scheduled for publication in the Federal Register in 2011. 

 

As part of the 2011 annual review, EPA is evaluating the data reported to the 2009 TRI and needs further 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. Please confirm/review the following data and questions: 

 

1. Please confirm the pounds of PCB released in 2009: 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 data, and were PCBs detected? Or, were releases estimated 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 correctly. If you have any questions regarding this request, please call me at (703) 

633-1659. 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, 

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