## Need to return call by / at/between and . Signature: ___________________________ Project No.: 0172.07.005.503 DISTRIBUTION

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### Project Name: 304(m) Annual Review

TELEPHONE CALL RECORD

Outgoing Call Date: 3/15/2010 Time: 2:30 pm EST

Company Name: Carolina Pole – Leland

(28451GNRLWHIGHW) Contact Name: Jane House

Phone No.: 803-664-4014

Name: Elizabeth Sabol Eastern Research Group

GENERAL SUBJECT : Dioxin Distribution and Dioxin load re ported to TRI in 2008



# TOPICS DISCUSSED AND ACTION TAKEN

I called Carolina Pole Leland on Monday, March 15, 2010 at 2: 30 pm, to speak with Mike Rouse. I left a message with Mr. Rouse identifying myself and explaining my r eason for calling. Mr. Rouse returned my phone call later that afternoon at 4:45 pm, stating that he would put me in contact with the correct TRI contact, Jane

House.

Ms. House left me a message on Tuesday, March 16, 2010 at 1:00 pm, I returned her called later that day at 3:00 pm. I provided Ms. House with a brief overview of the 304( m) annual review and how we obtain TRI data. I asked her about the dioxin distribution the facility repo rted to TRI in 2008, explaining that there was no distribution reported in the previous years. She stated th at the facility was issued a new storm water permit in 2008, for 5 years. This permit requires the facility to rep ort dioxin to TRI.

Ms. House stated that the dioxin distribution is based on actual sampling data. She stated that the facility uses any values over the detection limit to estimate the l oad for TRI reporting. Ms. House further explained that usually dioxin is non-detect. She stated that no dioxin conge ners were detected for the reporting year 2009. Ms.

House stated that the dioxin estimation for 2008 is based on one or two samples that reported dioxin over the

detection limit.

I asked Ms. House if she could confirm the dioxin distrib ution that was reported to TRI in 2008. She stated that she did not have the data in front of her, and that I sh ould call back Wednesday morning.

I called Ms. House on Wednesday, March 17, 2010 at 10:00 am and left a message for Ms. House. Ms. House returned my call the next day to confirm the dioxin distr ibution. All data matched.

I called Ms. House with some follow-up questions on Wedne sday, March 24, 2010, at 10:30 am. She instructed me to call her back on Monday, March 29, 2010, when she was back in the office.

I called Ms. House back on Monday March 29, 2210 at 1:30 pm and l eft a message asking her to return my call.

I called Ms. House again on Wednesday, March 31, 2010 at 12:45 pm . I left a message stating that I had some follow-up questions. I left my e-mail on the message as a nother form of communication.

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

# Ms. House called me back at 1:30 on Wednesday, March 31, 2010. She confirmed that the facility reported discharging 21 grams of dioxin. She stated that the samp le location is an internal monitoring point and that on e or two samples were collected in order to estimate th e dioxin distribution/load. She stated that they are require d to sample twice a year; however, sometimes there is not enough rain to collect the samples. Ms. House also

stated that no dioxin was detected in 2009.

I asked Ms. House if she could please forward the monitori ng data for 2008 and 2009. I told her that I would send an e-mail to her with the request for the data, al ong with an explanation of the review process and

confirmation of ERG’s affiliation with EPA.From: Jane House <jhouse@coxwood.com>

To: Elizabeth Sabol <Elizabeth.Sabol@erg.com>

Date: 4/1/2010 3:05 PM Subject: RE: Carolina Pole Leland - Dioxin Discharges Repor ted to TRI 2008

Attachments: CPL 082708 Dioxin Samp Results.pdf; Oct 2009 SW Di oxin Sampling.pdf

Elizabeth, I have attached our sampling results for Dioxin in 2008 and 2009. Part of the problem is probably the amount of run-off we estimated for 2008. We were using a much higher coefficient (and even t he one I gave for 2009 is probably too high as we h ave so much absorption). This entire site is sandy soil and even in the industrial areas we have a lot of water absorption and must have at a minimum, a 2-4" rain event, depending on the last rain, before we start having any run-off t hat leaves the property site. Based upon this information, I will need to modify my 2008 TRI. Thanks. Any questions, let me know.

Number of Outfalls:

2007-2008

2009

Outfall

Est. Acres

Est. Sq Ft.

Coefficient

Avg gals. per 1" rain

Remarks

001

128

5,575,680

0.821

2,853,391

Number of Outfalls:

Outfall

Est. Acres

Est. Sq Ft.

Coefficient

Avg gals. per 1" rain

Remarks

001128

5,575,680

0.7025

1,220,772

50% of coefficient used as run off

Jane House, CHMM Environmental, Health, and Safety Cox Industries, Inc.

P. O. Box 1124 Orangeburg, SC 29116 (803) 664-4014 (Cell) (803) 531-1959 (Fax) jhouse@coxwood.com<mailto:jhouse@coxwood.com>

Cox(r) Cares about people, products, and practices

From: Elizabeth Sabol [mailto:Elizabeth.Sabol@erg.c om] Sent: Thursday, April 01, 2010 1:17 PM

To: Jane House Cc: swietlik.william@epa.gov; Eleanor Codding; Jess ica Wolford Subject: Carolina Pole Leland - Dioxin Discharges R eported to TRI 2008

Dear Ms. House,

Thank you for your time on the phone yesterday. Eas tern Research Group, Inc. (ERG) under EPA Contract No. 68-C-02-095 is e-mailing you on behalf of EPA to request information on your dioxin distribution and discharges reported by you to the Toxic Release Inventory (TRI) in 2008. Here is some background on what the information is used for.

We are requesting this additional information in ac cordance with Section 304(b) of the Clean Water Act , which requires EPA to annually review and, if appropriate, revise its water pollution con trol 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 fac ilities. EPA is currently conducting its 2010 annual review of existing effluent guidelines and p otential industrial guidelines which may need to be included (see http://www.epa.gov/guide/304m/ for further informat ion). EPA will discuss this review and the results in its 2010 Effluent Guidelines Program Plan scheduled for publication in the Federal Regis ter in December 2010. As part of the 2010 annual re view, EPA is evaluating the data you reported in the 2008 Toxic Release Inventory and ne eds further information to complete the review. In some cases, EPA is contacting POTWs or facilities to verify the information in TRI. Th ese contacts are being made on behalf of EPA by ERG

.

We would like to obtain additional information on h ow you determined the total pounds of dioxin and di oxin like compounds discharged, by reviewing the sampling results from the monitoring data in 2008 along with 2009, if available.

If you have any questions regarding this request, p lease call me at (703) 633-1659. If you would like to speak directly with EPA regarding this request, you can contact William F. Swietlik o f EPA's Office of Water/Engineering Analysis Divisi on by phone at (202) 566-1129 or by email: swietlik.william@epa.gov<mailto:swietlik.wil liam@epa.gov>.

Thanks,

Elizabeth A. SabolEnvironmental Engineer

Eastern Research Group, Inc. 14555 Avion Parkway, Suite 200 Chantilly, VA 20151 elizabeth.sabol@erg.com<mailto:elizabeth.sabol@erg. com>
Phone:703-633-1659

www.coxwood.com

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