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Dow Chemical Company, Freeport Texas

Letter from Walter Walsh to Richard Olson


March 22, 1996

Mr. Richard A. Olson
Senior Environmental Associate
Environmental & Health Regulatory Affairs
The Dow Chemical Company
2030 Dow Center
Midland, MI 48674

Dear Mr. Olson:

Dow's proposal for an XL Project is currently undergoing review. We have determined that, due to the distinct nature of each of the components of the proposal, it may simplify and perhaps expedite the review and selection process if each component--Midland, Michigan; Freeport, Texas; and Plaquemine, Louisiana--is handled as a separate, individual proposal. Additionally, in the event that one or more of the components is selected as a XL Project, it will ease development of the Final Project Agreement(s) and related logistics, local stakeholder issues, etc. Please advise us if you are agreeable to this separation.

We also would like to request some additional details to assist us in evaluating Dow's XL proposal for the Freeport, Texas, facility. At the present time, this component of the proposal is on hold in the Technical Review stage pending receipt of information that addresses the following concerns:

1. The proposal references "a 25% reduction in the unit ratio of liquid halogenated wastes burned per pound of associated product." The specific ratio and base year are to be formalized in the Final Project Agreement (FPA). To evaluate how this proposed reduction meets the selected criteria that the project achieve superior environmental results, we will need to know the volume of waste incinerated both before and after implementation of the XL project.

2. Also, the proposal states that Dow seeks to reduce the emissions of dioxins and furans (D&F) by 90% by the year 2005. What is the base year? Dow states that since 1990, it has reduced dioxin release by 90% through its NPDES outfalls. Does this mean that Dow intends an additional 90% reduction in D&F emissions for a total reduction of 99% compared with 1990?

The proposal states that after completion of a sampling and analysis plan for D&F and establishment of a baseline by year-end 1996, Dow will commit to a specific reduction in D&F emissions. How does this relate to the 90% reduction described above?

Also, the proposal notes that Dow has recently formalized a global goal of reducing D&F emissions to air and water by 90% by the year 2005. With whom has this goal been formalized? If Dow has already committed to these reductions, please explain how and why you see this as a point of negotiation in the context of Project XL.

3. Please provide specific details to explain how Dow plans to achieve a 20% reduction in BIF units in liquid service. Will the waste streams be reduced or will they be shifted to other BIFs or alternative treatment units?

The proposal discusses elimination of the need for trial burns and Part B call-ins for BIF units that will not be operated in liquid service in the long term. Please provide additional details to identify those units; to explain how this would be accomplished; and to describe the period of time the units would be operated.

4. Dow asks for an approval of a schedule of trial burns that would extend four to six years beyond the initial TNRCC Part B call-ins. Does Dow have to negotiate with TNRCC directly for this request? How long are facilities typically given to conduct a trial burn after a Part B call-in? Would all of Dow's BIF's Part Bs be called in simultaneously?

5. What specific reductions does Dow seek regarding the frequency and scope of its BIF record keeping?

6. Please clarify the specific modification Dow is requesting for the 3-year BIF rectification.

7. The proposal asks for a waiver from requirements to perform risk assessments if the BIF technical standards are met, or alternatively to waive the BIF technical standards for units passing risk assessments. Are these references to upcoming MACT technical standards for BIFs? If so, this request in problematic as those standards will not be promulgated in the foreseeable future. At this point, the Agency cannot determine what the final standards are likely to be. How would Dow propose to address this issue?

While it is true that many of the specific details of an XL proposal are negotiated during development of the FPA, the framework for those negotiations are approved in the Technical Review process. Your assistance in providing the additional information requested will enable us to complete this review. We believe that there is enormous potential to make significant environmental gains at the Freeport facility in the context of Project XL. We look forward to resolving these technical issues as soon as possible so that this component of Dow's XL proposal can continue to move through the Project XL selection process. If you have any questions or require clarification concerning this request, please feel free to contact me at (202) 260-2770.


Walter Walsh
Staff Advisor
Project XL

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