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

Project No.: 0172.07.005.503 DISTRIBUTION 

Page _1_ of __1_

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 reported 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 reason 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 reported to TRI in 2008, explaining that there was no 

distribution reported in the previous years. She stated that the facility was issued a new storm water permit in 

2008, for 5 years. This permit requires the facility to report 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 load for TRI reporting. Ms. House further explained that 

usually dioxin is non-detect. She stated that no dioxin congeners 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 distribution that was reported to TRI in 2008. She stated that 

she did not have the data in front of her, and that I should 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 distribution. All data matched. 

I called Ms. House with some follow-up questions on Wednesday, 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 left 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 another 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 sample location is an internal monitoring point and that one 

or two samples were collected in order to estimate the dioxin distribution/load. She stated that they are required 

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 monitoring data for 2008 and 2009. I told her that I would 

send an e-mail to her with the request for the data, along 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 Reported to TRI 2008 

Attachments: CPL 082708 Dioxin Samp Results.pdf; Oct 2009 SW Dioxin 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 the one I gave for 2009 is probably too high as we have 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 that 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 

001 
128 

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.com] 

Sent: Thursday, April 01, 2010 1:17 PM 

To: Jane House 

Cc: swietlik.william@epa.gov; Eleanor Codding; Jessica Wolford 

Subject: Carolina Pole Leland - Dioxin Discharges Reported to TRI 2008 

Dear Ms. House, 

Thank you for your time on the phone yesterday. Eastern 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 accordance with Section 304(b) of the Clean Water Act, which 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 2010 

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 2010 Effluent Guidelines Program 

Plan scheduled for publication in the Federal Register in December 2010. As part of the 2010 annual review, EPA is evaluating the data you 

reported in the 2008 Toxic Release Inventory and needs further information to complete the review. In some cases, EPA is contacting POTWs 

or facilities to verify the information in TRI. These contacts are being made on behalf of EPA by ERG. 

We would like to obtain additional information on how you determined the total pounds of dioxin and dioxin 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, 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<mailto:swietlik.william@epa.gov>. 

Thanks, 

Elizabeth A. Sabol 
Environmental 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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