
?
Need
to
return
call
by
/
at/
between
and
.
Signature:
Project
No.:
0172.01.005.060
DISTRIBUTION
Page
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Project
Name:
304(
m)
OCPSF
Detailed
Study
TELEPHONE
CALL
RECORD
Outgoing
Call
Date:
1/
23/
04
Time:
3
p.
m.

Company
Name:
Texas
Commission
on
Environmental
Quality
(
TCEQ)
Contact
Name:
Ellie
Ku
Codding
Phone
No.:
703­
633­
1673
Name:
Michael
Sunderlin
Eastern
Research
Group,
Inc.

GENERAL
SUBJECT
:
Dow
Freeport
Facility
NPDES
Permit
TOPICS
DISCUSSED
AND
ACTION
TAKEN
I
called
Michael
Sunderlin
to
ask
about
the
dioxin
limit
in
the
Dow
Freeport
facility's
NPDES
Permit
dated
2003.
Mr.
Sunderlin
is
the
permit
writer.

He
said
that
the
dioxin
limit
was
determined
as
a
water
quality
screening
requirement.
The
Texas
Water
Quality
Screening
Requirements
require
permit
applicants
to
test
for
toxic
pollutants,
including
dioxin.
Results
from
Outfall
001
for
Freeport
exceeded
the
dioxin
water
quality
screening
limit
(
a
daily
average
requirement)
by
more
than
85%.
If
a
site
exceeds
the
water
quality
screening
requirements
(
the
daily
average)
by
greater
than
70%,
then
they
are
required
to
monitor
for
the
parameter.
If
the
site
exceeds
the
water
quality
screening
requirements
by
greater
than
85%
of
the
daily
average,
then
they
are
required
to
have
an
effluent
limitation
for
the
parameter.
Freeport
is
now
required
to
test
for
dioxin
for
three
years,
after
which
a
permit
limitation
will
be
set
for
dioxin.
If
Freeport
demonstrates
for
three
years
that
dioxin
is
not
present
in
the
wastewater,
then
no
limitation
would
be
set.

The
outfall
that
failed
for
dioxin
includes
wastewaters
from
several
other
sites.
Mr.
Sunderlin
explained
that
Outfall
001
is
a
canal
to
which
Freeport
discharges,
after
which
it
enters
the
Brazos
River.
However,
upstream
of
Freeport,
several
other
chemical
companies
discharge
to
the
same
canal.
Freeport
has
accepted
final
responsibility
for
the
water
quality
in
that
outfall.
The
wastewater
that
failed
the
dioxin
water
quality
standard
came
from
this
mixed
wastewater.

I
asked
Mr.
Sunderlin
if
an
effluent
guideline
for
dioxin
would
be
helpful.
He
did
not
feel
that
one
would
be
helpful.
