From:
<
Johnston.
Carey@
epamail.
epa.
gov>
To:
"
Williams,
Jim
Bob
(
JB)"
<
Jim
Bob@
dow.
com>
Date:
Tue,
Jun
1,
2004
11:
42
AM
Subject:
RE:
308
letter
to
Midland,
MI
Dear
Jim
Bob:

I've
passed
your
request
for
extension
to
my
Division
Director
for
approval.
I
hope
to
have
an
answer
for
you
shortly.

As
for
your
specific
questions...

Q:
Of
course,
Dow
would
welcome
any
assistance
from
U.
S.
EPA
particularly
if
the
Agency
possesses
any
"
generic"
process
diagrams
or
has
a
recommended
format
for
data
that
could
expedite
preparation
of
a
response.

A:
Unfortunately,
EPA
doesn't
have
any
generic
process
diagrams
or
recommended
format
for
data.
If
it
helps
facilitate
your
processing,
we
would
gladly
accept
data
that
already
exists
electronically
(
as
opposed
to
hard
copy
data).

Q:
On
a
related
item,
Question
4
under
the
"
Ethylene
Dichloride
Manufacturing"
section
of
the
308
letter
refers
to
"
Question
8
above."
Dow
believes
that
U.
S.
EPA
intended
to
incorporate
Question
2
considering
that
there
is
no
Question
8
in
the
letter.
Was
this
EPA's
intent?

A:
Yes.
Question
4
under
the
"
Ethylene
Dichloride
Manufacturing"
section
of
the
308
letter
should
refer
to
"
Question
2"
as
this
is
the
question
that
identified
outfalls
discharging
EDC
wastewaters.

Sincerely,

Carey
A.
Johnston,
P.
E.
U.
S.
EPA,
Office
of
Water
ph:
(
202)
566
1014
fx:
(
202)
566
1053
johnston.
carey@
epa.
gov
"
Williams,

Jim
Bob
(
JB)"
To:
Carey
Johnston/
DC/
USEPA/
U
S@
EPA
<
Jim
Bob@
dow.
com>
cc:

Subject:
RE:
308
letter
to
Midla
nd,
MI
06/
01/
2004
10:
00
AM
Subject:
308
letter
to
Midland,
MI
Dear
Carey:

Since
receiving
the
PDF
file
of
the
308
letter,
we've
held
two
meetings
with
our
technical
folks,
and
we're
going
to
be
making
a
formal
request
for
an
extension
on
the
308
letter
this
week.
We
will
comply
with
the
information
request,
but
the
scope
of
work
is
large,
given
a
21
day
request
period.
Allow
me
to
provide
an
overview
of
the
letter,
and
let's
talk
later
this
week
about
the
details.
There
are
three
general
areas
of
concern:
scope
of
work,
data
format,
and
need
for
clarification.

1.
Scope
of
Work
Our
circumstances
may
be
unique
the
preparation
of
our
response
requires
individual
assessments
of
at
least
ten
Dow
facilities:

5
Chlor
Alkali
plants
2
Ethylene
Dichloride
plants
2
Vinyl
Manufacturing
plants
1
Oxychlorination
plant
The
amount
and
type
of
monitoring
data
available
for
each
facility
varies.
Even
when
different
plants
make
the
same
products,
the
processes
used
can
have
significant
differences.

2.
Format
and
Details
of
Data
to
be
Supplied
Further,
to
accurately
respond,
Dow
must
create
data
templates,
prepare
simplified
process
flowsheets,
and
generate
new
reports
that
consolidate
the
requested
data.

Of
course,
Dow
would
welcome
any
assistance
from
U.
S.
EPA
particularly
if
the
Agency
possesses
any
"
generic"
process
diagrams
or
has
a
recommended
format
for
data
that
could
expedite
preparation
of
a
response.

3.
Clarification
on
Ethylene
Dichloride
request
On
a
related
item,
Question
4
under
the
"
Ethylene
Dichloride
Manufacturing"
section
of
the
308
letter
refers
to
"
Question
8
above."
Dow
believes
that
U.
S.
EPA
intended
to
incorporate
Question
2
considering
that
there
is
no
Question
8
in
the
letter.
Was
this
EPA's
intent?

We
will
of
course
comply
with
the
308
letter,
but
believe
an
extension
will
be
needed
to
provide
the
level
of
detail
you
need.
When
are
you
free
to
discuss
details?

Regards,

James
B.
(
Jim
Bob)
Williams,
P.
E.
Water
Coach,
Regulatory
Affairs
Expertise
Center
The
Dow
Chemical
Company
437
MacCorkle
Avenue
SW
South
Charleston,
WV
25303
Phone:
(
304)
747
3756
FAX:
(
304)
747
5963
E
mail:
Jim
Bob@
Dow.
com
CC:
<
Smith.
Maryt@
epamail.
epa.
gov>,
<
Wall.
Tom@
epamail.
epa.
gov>,
<
Matuszko.
Jan
@
epamail.
epa.
gov>,
<
jan.
mat@
verizon.
net>
??
