Need to return call by / at/between and

. Signature: Project No.: 

### 0172.08.005.604 Page 1 of 1

Project Name: 

### TRI2009 

## CBI?

Yes

No TELEPHONE CALL RECOR D Incoming Outgoing Date: 

### 01/28/11 Time: 

### 3:00 am

pm

Company Name: 

### Sasol North America Inc. ERG Staff Name: 

### Kimberly Landick

Contact Name: 

### Michael Hayes Contact Phone Number: 

### (337) 494-5038

General Subject: 

### 2009 TRI Dioxin Discharges



## TOPICS DISCUSSED AND ACTION TAKEN

On January 28, 2011 at 3pm, I called Sasol North Am erica Inc. to speak with Michael Hayes regarding 20 09 TRI dioxin discharges. I left a message stating my name, the reason for calling, and if he could call me back or pass my information to the correct personnel for TR I data.

On February 2, 2011 at 3:15pm, I called Sasol North America Inc. to speak with Michael Hayes regarding 2009 TRI dioxin discharges. I left a message stating my name, the reason for calling, and if he could call me back or pass my information to the correct personnel for TR I data.

On February 3, 2011 at 9:45am, I called Sasol North American Inc. to speak with Michael Hayes regardin g 2009 TRI dioxin discharges. After explaining the re ason for calling he stated that he was the correct person to talk to. I stated the questions that we had and he requested an e-mail with the questions. He also ask ed that we state which group within the EPA that we are workin g with and our contract number. Michael Hayes state d his email address as: Michael.hayes@us.sasol.com. I sen t him an e-mail at 10:43am on 2/3/11. Please see th e attached e-mail correspondence.

On February 9, 2011 at 7:55am I called Michael Haye s and left a message stating that I was following u p on my e-mail and asked him to call me back with any furth er questions he may have.

.From: Kimberly Landick [mailto:Kimberly.Landick@erg.com]

Sent: Tuesday, March 01, 2011 3:02 PM

To: Hayes, Michael (MG) Subject: RE: FW: Request for 2009 TRI Data Clarification

Hi Mike,

Thanks for getting back to me so quickly, I appreciate i t!

Kimberly

---------------------------------------- Kimberly D. Landick Environmental Engineer Eastern Research Group, Inc. 14555 Avion Parkway, Suite 200 Chantilly, VA 20151 kimberly.landick@erg.com

Phone: 703-633-1119

From: "Hayes, Michael (MG)" <Michael.Hayes@us.sasol.com>

To: "Kimberly Landick" <Kimberly.Landick@erg.com>

Date: 3/1/2011 2:47 PM Subject: RE: Request for 2009 TRI Data Clarification

Hello Kimberly

We apparently have one of those mail systems that automatic ally assigns the blanket confidentiality statement to our correspondence. Please ignore the footer for our purposes. That information is not confidential and should be made available to the public.

Best regards

Mike

Michael Hayes

337-494-5038 Office

337-842-7839 Mobile

From: Kimberly Landick [mailto:Kimberly.Landick@erg.com]

Sent: Tuesday, March 01, 2011 12:58 PM

To: Hayes, Michael (MG) Subject: RE: FW: Request for 2009 TRI Data Clarification

Hi Mike,

I am sorry to hear about your loss as well. It is a dif ficult time and my thoughts are with you and your family.I apologize for not including this in my previous e-mail but I would like to request your permission to

include the information you sent below as part of documentat ion made available at regulations.gov.

EPA is working towards the publication of its 2011 Final Plan a nd hopes to include the email (and spreadsheet attachment) below as part of the documentation that describes the corrections made to the 2009 screening-level review database. However, when there is a n email signature/footer that claims information as confidential, EPA cannot include it a part o f the public docket and handles it as CBI. If you approve, we will simply remove the following footer from the email correspondence and include this information in the public docket.

Please reply to this e-mail to let us know if it is ok t o include the information in EPA's public docket.

Thank you, Kimberly

*FOOTER LANGUAGE BELOW* This eMail message is from Sasol and is for the sole use of the intended recipient(s), and may contain confidential and privileged information. Any unauthorized r eview, use, disclosure or distribution is prohibited. If you are not the intended recipient(s), please contact the sender or email@sasol.com by reply eMail, and destroy all copies of the original mess age. You may not distribute, disseminate or copy

this eMail. Please note that all eMail within Sasol is subject to continuous and ad hoc filtering, scrutiny and reporting. This policy also applies to incoming eMai l.

---------------------------------------- Kimberly D. Landick Environmental Engineer Eastern Research Group, Inc. 14555 Avion Parkway, Suite 200 Chantilly, VA 20151 kimberly.landick@erg.com

Phone: 703-633-1119

From: "Hayes, Michael (MG)" <Michael.Hayes@us.sasol.com>

To: "Kimberly Landick" <Kimberly.Landick@erg.com>

Date: 2/28/2011 2:43 PM Subject: RE: Request for 2009 TRI Data Clarification

Hello Kimberly

My deepest condolences for your loss. Actually my reply to you was delayed for the same reason.

All the best to you and your family.

Regards

Mike

Michael Hayes337-494-5038 Office

337-842-7839 Mobile

From: Kimberly Landick [mailto:Kimberly.Landick@erg.com]

Sent: Thursday, February 24, 2011 6:36 AM

To: Hayes, Michael (MG) Subject: Re: FW: Request for 2009 TRI Data Clarification

Hi Mr. Hayes,

Thank you for sending us this information. I apologize for no t responding to you sooner, I've been out of the office due to a death in my family. I have looked over t he data you sent and at this point we do not need any further information. We will contact you if addition al questions arise.

Thank you, Kimberly

---------------------------------------- Kimberly D. Landick Environmental Engineer Eastern Research Group, Inc. 14555 Avion Parkway, Suite 200 Chantilly, VA 20151 kimberly.landick@erg.com

Phone: 703-633-1119

From: "Hayes, Michael (MG)" <Michael.Hayes@us.sasol.com>

To: "Kimberly Landick" <Kimberly.Landick@erg.com>

Date: 2/16/2011 5:01 PM Subject: RE: Request for 2009 TRI Data Clarification

Kimberly

My apologies. Please reply to confirm that I finally pa ssed along the information you requested.

Best regards

Mike

Michael Hayes

337-494-5038 Office

337-842-7839 Mobile

From: Kimberly Landick Sent: 2/11/2011, 3:27:53 PM To: Hayes, Michael (MG) Subject: RE: Request for 2009 TRI Data ClarificationMr. Hayes,

Thank you for your response to these questions. Your attachm ents for the 2008 water dioxin distribution and a summary table of sample results were not included . Please attach those documents for review.

Thank you, Kimberly

---------------------------------------- Kimberly D. Landick Environmental Engineer Eastern Research Group, Inc. 14555 Avion Parkway, Suite 200 Chantilly, VA 20151 kimberly.landick@erg.com

Phone: 703-633-1119

From: "Hayes, Michael (MG)" <Michael.Hayes@us.sasol.com>

To: "Kimberly Landick" <Kimberly.Landick@erg.com>

CC: "William Swietlik" <Swietlik.William@epamail.epa.gov>, "Eleanor Codding" <Eleanor.Codding@erg.com>, "Jessica Gray" <Jessica.Gray@ erg.com>

Date: 2/10/2011 4:25 PM Subject: RE: Request for 2009 TRI Data Clarification

Kimberly,

Apologies for the delay in my response to your questions. R esponses are as follows:

Q1. Please confirm the pounds of dioxin released in 2009: 0.0009 pounds (0.408 grams)

Answer 1- The total dioxins released to water in 2009 wa s reported by Sasol as 0.4041 grams (0.0009 pounds).

Q2. Please confirm the facility reported dioxin distribut ion in the attached spreadsheet.

Answer 2 - The dioxin distribution attached to your email accurately represents the 2009 Sasol dioxin releases to water.

Q3. How did you determine the 2009 water dioxin distribution as the re was no distribution reported in 2008.Answer 3 - Sasol reported a water dioxin distribution in 2008. Attached

is the 2008 Form R submitted in 2009 which includes a water diox in distribution (shown in Schedule 1 of the Form R). (Please see the attached copy of the RY2008 Dioxin Form R Schedule 1)

Q4. If you used monitoring data to determine the dioxin distr ibution, where was the monitoring conducted and how are non-detect results included in the distribution? If available, please provide a copy of the monitoring results.

Answer 4 - The distribution is based on 12 different samples dating from 1994 to 2004. The samples were all taken at the outlet of our onsite Activated Sludge Wastewater Treatment Unit. An average of all the sample results was used. Per EPA protocol, Sasol assume d that all non-detect results are equal to one half of the method detection limit reported for that particular congener, with the exception of 2 samples. One particular test result for one congener from 2001 was included as 0 because of method blank contamination. Additionally, Sasol decided not to adjust the calculated average total dioxin content of t he wastewater downward after the 2006 sample results came back less than the previously calculated average. We have laboratory reports on file, but for the purposes of this inquiry, we have not taken the time to make scanned copies. Instead, we have included a table showing a summary of the sample results. If you need copies of the analytic al results we

have them available.

Q5. If you don't have monitoring data, please describe how the distribution and pounds were reported in 2009.

Answer 5 - Sasol used the total effluent from our Activat ed Sludge Wastewater Unit and the concentrations from the analytical results

described above.

Q6. What is the source of the dioxin compounds in the wastewa ter?

Answer 6- The source of the dioxins in Sasol's wastew ater is the Georgia Gulf Vinyl Chloride plant wastewater. Sasol re ceives and treats wastewater from Georgia Gulf in our above ground, tank based activated sludge treatment unit. The wastewater treatm ent process does not destroy the dioxins. Should you require further information, please let me know.

RegardsMichael Hayes

Michael Hayes

337-494-5038 Office

337-842-7839 Mobile

________________________________

From: Kimberly Landick [mailto:Kimberly.Landick@erg.com ] Sent: Thursday, February 03, 2011 9:43 AM To: Hayes, Michael (MG) Cc: William Swietlik; Eleanor Codding; Jessica Gray Subject: Request for 2009 TRI Data Clarification

Mr. Hayes,

Thank you for your time on the phone this morning. As discuss ed, 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 of dioxin c ompounds discharges, on EPA's behalf under Contract No. 68-C-02-095. Please see below for further background.

EPA, Office of Water (OW), reviews TRI data to fulfil l its review obligation under Section 304(b) of the Clean Water Act. The C WA requires EPA to annually review and, if appropriate, revise its wa ter pollution control technology-based regulations, called "effluent limi tations guidelines" or "effluent guidelines," that limit the discha rge of pollutants to waters of the U.S. from various categories of industrial facilities. EPA is currently conducting its 2011 annual revie w of existing effluent guidelines and potential industrial gu idelines which may need to be included (see http://www.epa.gov/guide/304m/ f or further information). EPA will discuss this review and the results i n 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 r eview. Specifically, we would like to clarify the amount of dioxin compounds reported to the 2009 TRI. Please confirm/review the following data and questions below.

1. Please confirm the pounds of dioxin released in 2009: 0.0009 po unds (0.408 grams)2. Please confirm the facility reported dioxin distributi on in the

attached spreadsheet.

3. How did you determine the 2009 water dioxin distribution as the re was no distribution reported in 2008.

4. If you used monitoring data to determine the dioxin distribut ion, where was the monitoring conducted and how are non-detect results included in the distribution? If available, please provide a copy of the monitoring results.

5. If you don't have monitoring data, please describe how the distribution and pounds were reported in 2009.

6. What is the source of the dioxin compounds in the wastewa ter?

We appreciate your help in interpreting TRI data correct ly. If you have any questions regarding this request, please call me at (703) 633-1119. If you would like to speak directly with EPA regarding t his request, you

can contact William F. Swietlik of EPA's Office of W ater/Engineering Analysis Division by phone at (202) 566-1129 or by email: swietlik.william@epa.gov.

Thank you,

Kimberly Landick

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

Kimberly D. Landick

Environmental Engineer

Eastern Research Group, Inc.

14555 Avion Parkway, Suite 200

Chantilly, VA 20151

kimberly.landick@erg.com

Phone: 703-633-1119

"This eMail message is from Sasol and is for the sole u se of the intended recipient(s), and may contain confidential and privileged information. Any unauthorized r eview, use, disclosure or distribution is prohibited. If you are not the intended recipient(s), please contact the sender or email@sasol.com by reply eMail, and destroy all copies of the original mess age. You may not distribute, disseminate or copythis eMail. Please note that all eMail within Sasol is subject to continuous and ad hoc filtering, scrutiny

and reporting. This policy also applies to incoming eMai l."ASU Effluent(001) SamplesTest Results(ppq)AssumedConc.(ppq)Test Results(ppq)AssumedConc.(ppq) Test Results (ppq)AssumedConc.(ppq)Test Results(pg/L) Assumed Conc.(ppq) Test Results (pg/L)AssumedConc.(ppq)Test Results(pg/L) Assumed Conc.(ppq)Test Results(pg/L) Assumed Conc.(ppq)Test Results(pg/L) Assumed Conc.(ppq)Test Results(pg/L)AssumedConc.(ppq)Test Results(pg/L)AssumedConc.(ppq) Test Results (pg/L)AssumedConc.(ppq)Test Results(pg/L)AssumedConc.(ppq)Conc.Mass Avg(ppq)2,3,7,8 TCDF ND 2.5 ND 3.05 ND 1.3 ND 0.85 ND 1.45 ND 2.25 ND 1.55 ND 2.5 ND 1.8 ND 1.3 ND 1.15 ND 1.1 1.71,2,3,7,8 PeCDF ND 2.15 ND 2.4 ND 3.05 ND 1.55 ND 1.7 ND 3 ND 5 ND4.2 ND 5.5 ND 6.5 ND 5.5 ND 5.5 3.82,3,4,7,8 PeCDF ND 2.1 ND 2.35 ND 2.65 ND 1.5 ND 1.75 ND 3.2 ND 4.05 ND 4.15 ND 5.5 ND 6.5 ND 5.5 ND 5.5 3.71,2,3,4,7,8 HxCDF ND 2.7 ND 4.65 ND 1.2 ND 1.85 ND 8 ND 2.15 ND 5.5 ND 4.15 ND 5.5 ND 6.5 ND 5.5 ND 5.5 4.41,2,3,6,7,8 HxCDF ND 2.05 ND 3.45 ND 1.15 ND 1.75 ND 3.1 ND 2.1ND 4.25 ND 4.45 ND 5.5 ND 6.5 ND 5.5 ND 5.5 3.82,3,4,6,7,8 HxCDF ND 2.55 ND 4.35 ND 1.2 ND 1.95 ND 3.9 ND 1.8 ND 4.6 ND 3.6 ND 5.5 ND 6.5 ND 5.5 ND 5.5 3.91,2,3,7,8,9 HxCDF ND 3.3 ND 5.65 ND 1.15 ND 2.15 ND 2.9 ND 1.8 ND 5 ND 3.5 ND 5.5 ND 6.5 ND 5.5 ND 5.5 4.01,2,3,4,6,7,8 HpCDF ND 2.45 ND 3.8 ND 2.75 28J* 28 62 62 ND 8.5 ND 10.5 29J* 29 60I 60 16I 16 ND 5.5 20J 20 20.71,2,3,4,7,8,9 HpCDF ND 4.5 ND 6.95 ND 3.1 ND 1.75 ND 7.5 ND 1.9ND 4.95 ND 3.45 15J 15 ND 6.5 ND 5.5 ND 5.5 5.6OCDF ND 6.2 ND 8.3 18 18 ND 15.5 120J* 120 ND 15 ND 19 ND 15.5 160 16033J 33 24J 24 29J 29 38.62,3,7,8 TCDD ND 3.4 ND 4.05 ND 3 ND 1.25 ND 1.65 ND 2.35 ND 1.05 ND 1.7 ND 1.5 ND 1.3 ND 1.15 ND 1.1 2.01,2,3,7,8 PeCDD ND 3.1 ND 4.05 ND 1.55 ND 2.35 ND 2.85 ND 4.1 ND3.65 ND 6 ND 5.5 ND 6.5 ND 5.5 ND 5.5 4.21,2,3,4,7,8 HxCDD ND 4 ND 6.65 ND 2.15 ND 2.4 ND 5 ND 2.75 ND 3.8ND 4.7 ND 5.5 ND 6.5 ND 5.5 ND 5.5 4.51,2,3,6,7,8 HxCDD ND 3.35 ND 5.6 ND 2 ND 2.45 ND 4.75 ND 2.85 ND4.9 ND 5 ND 5.5 ND 6.5 ND 5.5 ND 5.5 4.51,2,3,7,8,9 HxCDD ND 3.6 ND 6.05 ND 1.9 ND 2.25 ND 4.5 ND 2.65 ND 4.95 ND 4.65 ND 5.5 ND 6.5 ND 5.5 ND 5.5 4.51,2,3,4,6,7,8 HpCDD ND 4.95 ND 6.65 ND 5 ND 1.7 ND 9 ND 3.8 ND 8 ND 5.5 15J 15 ND 6.5 ND 5.5 ND 5.5 6.4OCDD 51.1 51.1 ND 9.8 ND 23.5 ND 6.5 110J*B* 0 60J* 60 ND 23 60J* 60 42J 42 ND 13 ND 11.5 ND 11 26.0**USED HIGHEST OF SAMPLE & FIELD DUPLICATE142.4NOTE: The VI Study used EPA Method 1613A (5), the 1994 and 2000 samples were analyzed using Method 8290Method 1613 treats non-detects as zero per EPA-745-B-00-00X0.0000000039Method 8290 does not say how to treat non-detects.2006 NPDES 001 Sample = 3.90 ppqAssumed results<DL are 1/2 DL since all congeners detected in sludge.Note: the 2006 NPDES sample is less than the amount usedfor TRI calculation so do not change assumption for 001*J = Estimated result. Result is less than the reportinglimit.*B=Method Blank Contamination*I = Interference7/27/1994 - Method 8290 7/26/1994 - Method 8290 1997VI Study - Method 1613 2000 NPDES Sample - Method 82901/7/04 Sample - Method 8290 2/23/04 Sample - Method8290 3/16/04 Sample - Method 8290 4/12/04 Sample - Method 829011/01NPDES Sample Method 1613** 12/01 NPDES Sample Method 1613** 1/02 NPDES Sample Method 1613 2/02 NPDESSample Method 1613**ERG Revised Facility DataNotes: From research on U and J values as reviewed by EAD, ERG zeroed ND, Method Blank Contaminations, and kept J and I values.ASU Effluent(001) SamplesTest Results(ppq)AssumedConc.(ppq) ERG ResultTest Results(ppq)AssumedConc.(ppq) ERG Result Test Results (ppq)AssumedConc.(ppq) ERG ResultTest Results(pg/L) Assumed Conc.(ppq) ERG Result Test Results (pg/L)AssumedConc.(ppq) ERG ResultTest Results(pg/L) Assumed Conc.(ppq) ERG ResultTest Results(pg/L) Assumed Conc.(ppq) ERG ResultTest Results(pg/L) Assumed Conc.(ppq) ERG ResultTest Results(pg/L)AssumedConc.(ppq) ERG ResultTest Results(pg/L)AssumedConc.(ppq) ERG Result Test Results (pg/L)AssumedConc.(ppq) ERG ResultTest Results(pg/L)AssumedConc.(ppq) ERG ResultConc.Mass Avg(ppq)ERGConcMass Avg(ppq)JG ConcMass Avg2,3,7,8 TCDF ND 2.5 0 ND 3.05 0 ND 1.3 0 ND 0.85 0 ND 1.45 0 ND 2.250 ND 1.55 0 ND 2.5 0 ND 1.8 0 ND 1.3 0 ND 1.15 0 ND 1.1 0 1.7 0 01,2,3,7,8 PeCDF ND 2.15 0 ND 2.4 0 ND 3.05 0 ND 1.55 0 ND 1.7 0 ND 30 ND 5 0 ND 4.2 0 ND 5.5 0 ND 6.5 0 ND 5.5 0 ND 5.5 0 3.8 0 02,3,4,7,8 PeCDF ND 2.1 0 ND 2.35 0 ND 2.65 0 ND 1.5 0 ND 1.75 0 ND 3.2 0 ND 4.05 0 ND 4.15 0 ND 5.5 0 ND 6.5 0 ND 5.5 0 ND 5.5 0 3.7 0 01,2,3,4,7,8 HxCDF ND 2.7 0 ND 4.65 0 ND 1.2 0 ND 1.85 0 ND 8 0 ND 2.15 0 ND 5.5 0 ND 4.15 0 ND 5.5 0 ND 6.5 0 ND 5.5 0 ND 5.5 0 4.4 0 01,2,3,6,7,8 HxCDF ND 2.05 0 ND 3.45 0 ND 1.15 0 ND 1.75 0 ND 3.1 0ND 2.1 0 ND 4.25 0 ND 4.45 0 ND 5.5 0 ND 6.5 0 ND 5.5 0 ND 5.5 0 3.8 0 02,3,4,6,7,8 HxCDF ND 2.55 0 ND 4.35 0 ND 1.2 0 ND 1.95 0 ND 3.9 0 ND 1.8 0 ND 4.6 0 ND 3.6 0 ND 5.5 0 ND 6.5 0 ND 5.5 0 ND 5.5 0 3.9 0 01,2,3,7,8,9 HxCDF ND 3.3 0 ND 5.65 0 ND 1.15 0 ND 2.15 0 ND 2.9 0 ND 1.8 0 ND 5 0 ND 3.5 0 ND 5.5 0 ND 6.5 0 ND 5.5 0 ND 5.5 0 4.0 0 01,2,3,4,6,7,8 HpCDF ND 2.45 0 ND 3.8 0 ND 2.75 0 28J* 28 28 62 62 0ND 8.5 0 ND 10.5 0 29J* 29 29 60I 60 60 16I 16 16 ND 5.5 0 20J 20 20 20.712.75 20.708331,2,3,4,7,8,9 HpCDF ND 4.5 0 ND 6.95 0 ND 3.1 0 ND 1.75 0 ND 7.5 0ND 1.9 0 ND 4.95 0 ND 3.45 0 15J 15 15 ND 6.5 0 ND 5.5 0 ND 5.5 0 5.6 1.25 5.404167OCDF ND 6.2 0 ND 8.3 0 18 18 18 ND 15.5 0 120J* 120 120 ND 15 0 ND 19 0 ND15.5 0 160 160 160 33J 33 33 24J 24 24 29J 29 29 38.6 32 37.333332,3,7,8 TCDD ND 3.4 0 ND 4.05 0 ND 3 0 ND 1.25 0 ND 1.65 0 ND 2.35 0 ND 1.05 0 ND 1.7 0 ND 1.5 0 ND 1.3 0 ND 1.15 0 ND 1.1 0 2.0 0 01,2,3,7,8 PeCDD ND 3.1 0 ND 4.05 0 ND 1.55 0 ND 2.35 0 ND 2.85 0 ND4.1 0 ND 3.65 0 ND 6 0 ND 5.5 0 ND 6.5 0 ND 5.5 0 ND 5.5 0 4.2 0 01,2,3,4,7,8 HxCDD ND 4 0 ND 6.65 0 ND 2.15 0 ND 2.4 0 ND 5 0 ND 2.750 ND 3.8 0 ND 4.7 0 ND 5.5 0 ND 6.5 0 ND 5.5 0 ND 5.5 0 4.5 0 01,2,3,6,7,8 HxCDD ND 3.35 0 ND 5.6 0 ND 2 0 ND 2.45 0 ND 4.75 0 ND 2.85 0 ND 4.9 0 ND 5 0 ND 5.5 0 ND 6.5 0 ND 5.5 0 ND 5.5 0 4.5 0 01,2,3,7,8,9 HxCDD ND 3.6 0 ND 6.05 0 ND 1.9 0 ND 2.25 0 ND 4.5 0 ND2.65 0 ND 4.95 0 ND 4.65 0 ND 5.5 0 ND 6.5 0 ND 5.5 0 ND 5.5 0 4.5 0 01,2,3,4,6,7,8 HpCDD ND 4.95 0 ND 6.65 0 ND 5 0 ND 1.7 0 ND 9 0 ND 3.8 0 ND 8 0 ND 5.5 0 15J 15 15 ND 6.5 0 ND 5.5 0 ND 5.5 0 6.4 1.25 6.283333OCDD51.151.151.1ND9.80ND23.50ND6.50110J*B*0060J*6060ND23060J*606042J4242ND130ND11.50ND11026.017.7583325.40833**USED HIGHEST OF SAMPLE & FIELD DUPLICATE142.465.0083395.1375NOTE: The VI Study used EPA Method 1613A (5), the 1994 and 2000 samples were analyzed using Method 8290Method 1613 treats non-detects as zero per EPA-745-B-00-00X0.0000000039Method 8290 does not say how to treat non-detects.2006 NPDES 001 Sample = 3.90 ppqAssumed results<DL are 1/2 DL since all congeners detected in sludge.Note: the 2006 NPDES sample is less than the amount usedfor TRI calculation so do not change assumption for 001*J = Estimated result. Result is less than the reportinglimit.*B=Method Blank Contamination*I = Interference1/02 NPDES Sample Method 1613 2/02 NPDES Sample Method 1613** 1/7/04 Sample - Method 8290 2/23/04 Sample- Method 8290 3/16/04 Sample - Method 8290 4/12/04 Sample - Method 82907/27/1994 - Method 8290 7/26/1994 - Method 8290 1997VI Study - Method 1613 2000 NPDES Sample - Method 8290 11/01NPDES Sample Method 1613** 12/01 NPDES SampleMethod 1613**