CREW: Environmental Protection Agency: Regarding Mary Gade: Dow CREW Appeal ADR - Revised Improperly Classified - PDF-R

Document Log
Review Status = Complete
Exemption/Privilege = Ex. 5 -- Deliberative Process
Privilege
Review Status
Pending Complete
From To
Gregory Rudloff/R5/USEPA/US John Steketee
CC BCC
Subject Date/Time Document Type
Fw: Invitation to Trustees

04/01/2008 12:26 PM
Tracking Number Pages Exemption/Privilege
DowADRImp-97
Ex. 5 -- Deliberative Process Privilege
Previous #
Description
originated from another agency
General Responsiveness Determination
Responsive Partially responsive Not responsive Undecided
ADR? ADR not determined

Does Not Contain ADR
Superfund
Contains ADR
Improperly Classified
Detailed Release/Withhold Status Explain Release/Withhold Status
Withhold in Full
Document Body
----- Forwarded by Gregory Rudloff/R5/USEPA/US on 04/01/2008 12:26 PM -----
Mary Gade/R5/USEPA/US
04/01/2008 12:03 PM
To
Gregory Rudloff/R5/USEPA/US@EPA
cc
"Ralph Dollhopf" <dollhopf.ralph@epa.gov>, "Bharat Mathur"
<mathur.bharat@epamail.epa.gov>, "Robert Kaplan"
<kaplan.robert@epa.gov>
Subject
Re: Invitation to Trustees
We will not have anyone from epa (region or hq) attend.
-----------------
Sent by EPA Wireless E-Mail Services

Gregory Rudloff
----- Original Message -----
From: Gregory Rudloff
Sent: 04/01/2008 10:57 AM CDT
To: Gade.Mary@epamail.epa.gov@EPA; Dollhopf.Ralph@epamail.epa.gov@EPA
Subject: Fw: Invitation to Trustees
MDEQ would like to know if anyone from Region 5, or EPA Headquarters is attending the meeting
described below. This is the first that I have heard about the two day meeting. MDEQ has not seen an
agenda for the meeting yet, so I do not know what the purpose is.
Thanks,
Gregory A. Rudloff, P.G.
Corrective Action Section
Waste Management Branch
Land and Chemicals Division
Region 5, U.S. EPA
(312) 886-0455
rudloff.gregory@epa.gov
----- Forwarded by Gregory Rudloff/R5/USEPA/US on 04/01/2008 10:52 AM -----
"Allan Taylor"
<taylora@michigan.gov>
04/01/2008 10:50 AM
To
cc
Subject
Fwd: Invitation to Trustees
Al Taylor
Geology Specialist
Hazardous Waste Technical Support Unit
Waste and Hazardous Materials Division
Michigan Department of Environmental Quality
517-335-4799
taylorab@michigan.gov
>>> "Joseph Heimbuch" <heimbuch@demaximis.com> 4/1/2008 8:42 AM >>>
Al,
Yesterday, I sent an e-mail to the Natural Resourec Trustees on behalf
of Dow inviting them to attend the April 9th and 10th meetings in
Lansing. I have not heard back from any of them as yet.
For planning purposes, it would be helpful if you could let me know as

soon as possible how many from MDEQ and USEPA Region 5 we might expect
to attend.
Give me a call if you have any questions...
Joe
______________________________
Joseph A. Heimbuch
demaximis, inc.
2975 Bee Ridge Road
Suite C
Sarasota, Florida 34239
941-926-7929
_______________________________________________________________________
Unless otherwise indicated, the information contained in this email
message is the exclusive property of de maximis, inc. and is privileged
and confidential information intended for the use of the individual(s)
or entity(s) named above. If the reader of this message is not the
intended recipient, or the employee or agent responsible to deliver it
to the intended recipient, you are hereby notified that any use,
dissemination, distribution, or copying of this communication is strictly
prohibited. If you have received this communication in error or are not
sure whether it is privileged, please immediately reply to the sender and
/or notify us by phone (865-691-5052) and destroy all copies whether
electronic and/or paper.

Document Log
Privilege
Review Status
Pending Complete
From To
John Steketee/R5/USEPA/US Bertram Frey/R5/USEPA/US@EPA
Eric Cohen/R5/USEPA/US@EPA
Leverett Nelson/R5/USEPA/US@EPA
Stephen Mendoza/R5/USEPA/US@EPA
Mark Palermo/R5/USEPA/US@EPA
Robert Kaplan/R5/USEPA/US@EPA
DowChemicalORCGroup
CC BCC

04/01/2008 12:35 PM
DowADRImp-98
Previous #
Description
ADR?
ADR not determined
Superfund
Contains ADR
Withhold in Full
Document Body
----- Forwarded by John Steketee/R5/USEPA/US on 04/01/2008 12:35 PM -----
Gregory
To
Rudloff/R5/USEPA/US
04/01/2008 12:26 PM
Subject
04/01/2008 12:03 PM
To
cc
Subject
-----------------
Gregory Rudloff
Sent: 04/01/2008 10:57 AM CDT
Thanks,
Region 5, U.S. EPA
(312) 886-0455
"Allan Taylor"
04/01/2008 10:50 AM
To
cc
Subject
Al Taylor
Geology Specialist
517-335-4799
Al,
to attend.
Joe
______________________________
Joseph A. Heimbuch
demaximis, inc.
2975 Bee Ridge Road
Suite C
941-926-7929
_______________________________________________________________________

Document Log
Privilege
Review Status
Pending Complete
From To
John Steketee/R5/USEPA/US Jeff Cahn/R5/USEPA/US@EPA Jeff
Cahn/R5/USEPA/US
CC BCC

04/01/2008 01:14 PM
DowADRImp-99
Previous #
Description

Superfund
Contains ADR
Withhold in Full
Document Body
Gregory
To
Rudloff/R5/USEPA/US
04/01/2008 12:26 PM
Subject
04/01/2008 12:03 PM
To
cc
Subject
-----------------
Gregory Rudloff
Sent: 04/01/2008 10:57 AM CDT
Thanks,
Region 5, U.S. EPA
(312) 886-0455
"Allan Taylor"
04/01/2008 10:50 AM
To
cc
Subject
Al Taylor
Geology Specialist
517-335-4799
Al,
to attend.
Joe
______________________________
Joseph A. Heimbuch
demaximis, inc.
2975 Bee Ridge Road
Suite C
941-926-7929
_______________________________________________________________________

Document Log
Privilege
Review Status
Pending Complete
From To
"Allan Taylor" <taylora@michigan.gov> Gregory Rudloff/R5/USEPA/US@EPA
John Steketee/R5/USEPA/US@EPA
CC BCC
"Cheryl Howe" <HOWEC@michigan.gov>
"Deborah Mackenzie-Taylor"
<Mackenzie-TaylorD@michigan.gov>
"Delores Montgomery" <MontgomeryD1@michigan.gov>
Fwd: Tittabawasse & Saginaw Rivers - Preliminary Briefing

04/01/2008 03:46 PM
DowADRImp-100
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Description

Superfund
Contains ADR
Withhold in Full
Document Body
FYI -
Does Dow know that Ells and Greenbery are not going to the meeting per Gade?
>>> "Joseph Heimbuch" <heimbuch@demaximis.com> 4/1/2008 4:33 PM >>>
All...
In order to make the upcoming April 9th and 10th technical meetings as
productive and efficient as possible for Steve Ells and Marc
Greenberg,
we (Dow) wanted to offer them the opportunity to get caught with the
rest
of the folks from MDEQ and USEPA, Region 5 - who have been involved
over a
longer period. As a result, we are setting up a brief web meeting for
Steve
and Marc sometime this week. This web meeting will basically include
the
powerpoints and/or information that was presented recently in a couple
of different meetings with MDEQ and others on the site background; the
geomorphological features of the two rivers; and an overview of sample
results.
An exact date and time has not been determined; however, we are
currently
looking at Wednesday or Thursday afternoons or Friday (except for early
afternoon).
Representatives from MDEQ or USEPA, Region 5 are certainly welcome to
participate.
Please let me know as soon as possible as to you participation so I can
provide the call-in number and web link information in advance.
Joe Heimbuch
______________________________
Joseph A. Heimbuch
demaximis, inc.
2975 Bee Ridge Road
Suite C
941-926-7929
_______________________________________________________________________


Document Log
Privilege
Review Status
Pending Complete
From To
Gregory Rudloff/R5/USEPA/US John Steketee
CC BCC
Fw: Tittabawasse & Saginaw Rivers - Preliminary Briefing

04/02/2008 08:19 AM
DowADRImp-101
Previous #
Description

Superfund
Contains ADR
Withhold in Full
Document Body
"Allan Taylor"
To
04/01/2008 03:46 PM
Subject
FYI -
All...
Greenberg,
rest
over a
Steve
the
results.
currently
afternoon).
participate.
Joe Heimbuch
______________________________
Joseph A. Heimbuch
demaximis, inc.
2975 Bee Ridge Road
Suite C
941-926-7929
_______________________________________________________________________


Document Log
Privilege
Review Status
Pending Complete
From To
John Steketee/R5/USEPA/US Bertram Frey/R5/USEPA/US@EPA
DowChemicalORCGroup
CC BCC

04/02/2008 08:20 AM
DowADRImp-102
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Description
ADR?
ADR not determined
Superfund
Contains ADR
Withhold in Full
Document Body
----- Forwarded by John Steketee/R5/USEPA/US on 04/02/2008 08:19 AM -----
Gregory
To
Rudloff/R5/USEPA/US
04/02/2008 08:19 AM
Subject
"Allan Taylor"
To
04/01/2008 03:46 PM
Subject
FYI -
All...
Greenberg,
rest
over a
Steve
the
results.
currently
afternoon).
participate.
Joe Heimbuch
______________________________
Joseph A. Heimbuch
demaximis, inc.
2975 Bee Ridge Road
Suite C
941-926-7929
_______________________________________________________________________

Document Log
Privilege, Ex. 5 -- Attorney Client Privilege, Ex. 7(A)
-- Law Enforcement Proceedings
Review Status
Pending Complete
From To
Jeff Cahn/R5/USEPA/US John Steketee/R5/USEPA/US@EPA
CC BCC
Bertram Frey/R5/USEPA/US@EPA
Catherine Garypie/R5/USEPA/US@EPA
Mark Durno/R5/USEPA/US@EPA
RALPH DOLLHOPF/R5/USEPA/US@EPA
Re: Fw: Prompt Review Requested--MDEQ Draft IRA Letter --

04/10/2008 08:52 AM
CONFIDENTIAL WORK PRODUCT / ATTORNEY CLIENT
COMMUNICATION
DowADRImp-103
Ex. 5 -- Deliberative Process Privilege, Ex. 5 --
Attorney Client Privilege, Ex. 7(A) -- Law
Enforcement Proceedings
Previous #
Description
ADR?
ADR not determined
Superfund
Contains ADR
Withhold in Full
Document Body
I have some comments. My comments are based on the numbered headings used by MDEQ.
Ex. 5 - Deliberative Process Privilege
John Steketee/R5/USEPA/US
04/10/2008 08:24 AM
To Bertram Frey/R5/USEPA/US@EPA, Eric
Cohen/R5/USEPA/US@EPA, Leverett
Nelson/R5/USEPA/US@EPA, Stephen
Mendoza/R5/USEPA/US@EPA, Mark
Palermo/R5/USEPA/US@EPA, Robert
Kaplan/R5/USEPA/US@EPA
cc
Jeff Cahn/R5/USEPA/US@EPA, Catherine
Garypie/R5/USEPA/US@EPA
Subject
Fw: Propmpt Review Requested--MDEQ Draft IRA Letter
ORC Mgmt:
Please provide any comment you may have on the attached draft MDEQ IRA letter asap.
LCD would like to provide EPA’s comments to MDEQ by COB today. Thanks.
-John
RALPH
DOLLHOPF/R5/USEPA/US
04/09/2008 05:32 PM
To "Gregory Rudloff" <Rudloff.Gregory@epamail.epa.gov>,
"John Steketee" <Steketee.John@epamail.epa.gov>, "Mark
Durno" <Durno.Mark@epamail.epa.gov>
cc
Subject
Fw: Draft IRA Letter
From: RALPH DOLLHOPF
Sent: 04/09/2008 06:31 PM EDT
Subject: Fw: Draft IRA Letter
Greg
Please compile R5 comments from you ,e marka nd john. Per Sygo’s request by
Fri . Cc me please.
From: "Jim Sygo" [SYGOJ@michigan.gov]
Sent: 04/09/2008 05:19 PM AST
To: Ralph Dollhopf; Mary Gade; Bharat Mathur
Cc: "George Bruchmann" <BruchmannG@michigan.gov>
Subject: Draft IRA Letter
Attached is the letter that was completed late this afternoon on the IRAs that
are being requested of Dow. I thought we would share this with you in draft
form to see if you have any comment. The City of Midland will be handled as a
separate IRA.
It would be helpful to have any comments that you would like to provide by
9:00 am on Friday April 11, or sooner. We are targeting this letter to go out
late on April 11th.
Jim Sygo
Deputy Director
Department of Environmental Quality
517-241-7394
sygoj@michigan.gov
[attachment "copy of 4-10-2008 IRA demand letter 4 on ltrh.pdf" deleted by
Jeff Cahn/R5/USEPA/US] [attachment "Jim Sygo.vcf" deleted by Jeff
Cahn/R5/USEPA/US]
Document Log
Review Status
Pending Complete
From To
Cahn/R5/USEPA/US
CC BCC

04/10/2008 09:11 AM
COMMUNICATION
DowADRImp-104
Previous #
Description
ADR?
ADR not determined
Superfund
Contains ADR
Withhold in Full
Document Body
Confidential Communication/Privileged/FOIA Exempt
Good points. Thanks.
Ex. 5 - Attorney Clent Privilege, Ex. 5 Deliberative Process Priviliege, Ex. 7(A) - Law Enforcement Proceedings Privilege
Ex. 5 - Deliberative Process P...

Answers to these questions will help us to craft LCD’s response to MDEQ. Any
thoughts? Thanks.
Jeff Cahn/R5/USEPA/US
04/10/2008 08:52 AM
To
cc
Bertram Frey/R5/USEPA/US@EPA, Catherine
Garypie/R5/USEPA/US@EPA, Eric
Nelson/R5/USEPA/US@EPA, Mark
Kaplan/R5/USEPA/US@EPA, Stephen
Durno/R5/USEPA/US@EPA, RALPH
DOLLHOPF/R5/USEPA/US@EPA
Subject
Re: Fw: Prompt Review Requested--MDEQ Draft IRA Letter
-- CONFIDENTIAL WORK PRODUCT / ATTORNEY CLIENT
COMMUNICATION
04/10/2008 08:24 AM
cc
Subject
ORC Mgmt:
-John
RALPH
04/09/2008 05:32 PM
cc
Subject
Sent: 04/09/2008 06:31 PM EDT
Greg
Fri . Cc me please.
Sent: 04/09/2008 05:19 PM AST

separate IRA.
late on April 11th.
Jim Sygo
Deputy Director
517-241-7394
sygoj@michigan.gov
Cahn/R5/USEPA/US]
Document Log
Review Status
Pending Complete
From To
Jeff Cahn/R5/USEPA/US John Steketee/R5/USEPA/US@EPA
CC BCC

04/10/2008 09:24 AM
COMMUNICATION
DowADRImp-105
Previous #
Description
ADR?
ADR not determined
Superfund
Contains ADR
Withhold in Full
Document Body
Ex. 5 - Attorney Clent Privilege, Ex. 5 Deliberative Process Priviliege, Ex. 7(A) - Law Enforcement Proceedings Privilege
04/10/2008 09:11 AM
To
Jeff Cahn/R5/USEPA/US@EPA
cc
Durno/R5/USEPA/US@EPA, Mark
Palermo/R5/USEPA/US@EPA, RALPH
DOLLHOPF/R5/USEPA/US@EPA, Robert
Mendoza/R5/USEPA/US@EPA
Subject
COMMUNICATION
Good points. Thanks.
Ex. 5 - Deliberative Proc...

Answers to these questions will help us to craft LCD’s response to MDEQ. Any
thoughts? Thanks.
04/10/2008 08:52 AM
To
cc
Subject
COMMUNICATION
04/10/2008 08:24 AM
cc
Subject
ORC Mgmt:
-John
RALPH
04/09/2008 05:32 PM
cc
Subject
Sent: 04/09/2008 06:31 PM EDT
Greg
Fri . Cc me please.
Sent: 04/09/2008 05:19 PM AST
separate IRA.
late on April 11th.
Jim Sygo
Deputy Director
517-241-7394
sygoj@michigan.gov
Cahn/R5/USEPA/US]
Document Log
Review Status
Pending Complete
From To
Cahn/R5/USEPA/US
CC BCC

04/10/2008 11:31 AM
COMMUNICATION
DowADRImp-106
Previous #
Description

Superfund
Contains ADR
Withhold in Full
Document Body
To All:
Here is the first draft of LCDs comments on MDEQ’s draft IRA notice letter. LCD proposes to
send these comments to
MDEQ by COB today. Thanks.

-John
04/10/2008 08:52 AM
To
cc
Subject
COMMUNICATION
04/10/2008 08:24 AM
cc
Subject
ORC Mgmt:
-John
RALPH
04/09/2008 05:32 PM
cc
Subject
Sent: 04/09/2008 06:31 PM EDT
Greg
Fri . Cc me please.
Sent: 04/09/2008 05:19 PM AST

separate IRA.
late on April 11th.
Jim Sygo
Deputy Director
517-241-7394
sygoj@michigan.gov
Cahn/R5/USEPA/US]
Document Log
Review Status
Pending Complete
From To
Cahn/R5/USEPA/US@EPA
CC BCC

04/10/2008 01:29 PM
COMMUNICATION
DowADRImp-107
Previous #
Description

Superfund
Contains ADR
Withhold in Full
Document Body
To All:
Here is a revised version of the LCD’s comment on MDEQ’s draft IRA notice letter. Thanks.
-John
__________________
To All:
-John
04/10/2008 08:52 AM
To
cc
Subject
COMMUNICATION

04/10/2008 08:24 AM
cc
Subject
ORC Mgmt:
-John
RALPH
04/09/2008 05:32 PM
cc
Subject
Sent: 04/09/2008 06:31 PM EDT
Greg
Fri . Cc me please.
Sent: 04/09/2008 05:19 PM AST
separate IRA.
late on April 11th.
Jim Sygo
Deputy Director
517-241-7394
sygoj@michigan.gov
Cahn/R5/USEPA/US]
Document Log
Review Status
Pending Complete
From To
RALPH DOLLHOPF/R5/USEPA/US John Steketee/R5/USEPA/US@EPA
CC BCC

04/10/2008 02:09 PM
COMMUNICATION
DowADRImp-108
Previous #
Description

Superfund
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John
I need until tomoorow am to review thiis before it goes to MDEQ.
John Steketee
From: John Steketee
Sent: 04/10/2008 01:29 PM CDT
To: Jeff Cahn
Cc: Bertram Frey; Catherine Garypie; Eric Cohen; Leverett Nelson; Mark
Durno; Mark Palermo; Ralph Dollhopf; Robert Kaplan; Stephen Mendoza; Gregory
Rudloff
Subject: Re: Fw: Prompt Review Requested--MDEQ Draft IRA Letter --

CONFIDENTIAL WORK PRODUCT / ATTORNEY CLIENT COMMUNICATION
To All:
-John
[attachment "EPACommentsonMDEQApril2008DraftIRALetterVersion2.doc" deleted by RALPH
DOLLHOPF/R5/USEPA/US]
__________________
To All:
-John
[attachment "EPACommentsonMDEQApril2008DraftIRALetter.doc" deleted by RALPH
04/10/2008 08:52 AM
To
cc
Subject
COMMUNICATION

04/10/2008 08:24 AM
cc
Subject
ORC Mgmt:
-John
RALPH
04/09/2008 05:32 PM
cc
Subject

Sent: 04/09/2008 06:31 PM EDT
Greg
Fri . Cc me please.
Sent: 04/09/2008 05:19 PM AST
separate IRA.
late on April 11th.
Jim Sygo
Deputy Director
517-241-7394
sygoj@michigan.gov
Cahn/R5/USEPA/US]
Document Log
Review Status
Pending Complete
From To
John Steketee/R5/USEPA/US RALPH DOLLHOPF/R5/USEPA/US@EPA RALPH
CC BCC

04/10/2008 02:45 PM
COMMUNICATION
DowADRImp-109
Previous #
Description

Superfund
Contains ADR
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Document Body
Ok. Another version is coming in a couple of minutes so you do not need to review the prior versions.
Thanks.
RALPH DOLLHOPF/R5/USEPA/US
RALPH
To
04/10/2008 02:09 PM
cc
Subject
COMMUNICATION
John
I need until tomoorow am to review thiis before it goes to MDEQ.
John Steketee
From: John Steketee
Sent: 04/10/2008 01:29 PM CDT
To: Jeff Cahn
Rudloff
To All:
-John
__________________
To All:
-John
04/10/2008 08:52 AM
To
cc
Subject

COMMUNICATION
04/10/2008 08:24 AM
cc
Subject
ORC Mgmt:
-John
RALPH
04/09/2008 05:32 PM
cc
Subject
Sent: 04/09/2008 06:31 PM EDT
Greg
Fri . Cc me please.
Sent: 04/09/2008 05:19 PM AST
separate IRA.
late on April 11th.
Jim Sygo
Deputy Director
517-241-7394
sygoj@michigan.gov
Cahn/R5/USEPA/US]
Document Log
Review Status
Pending Complete
From To
CC BCC

04/10/2008 03:10 PM
COMMUNICATION
DowADRImp-110
Previous #
Description

Superfund
Contains ADR
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Document Body
Can you paste most recent version into an email for me so I can hanle it on bb
John Steketee
From: John Steketee
Sent: 04/10/2008 02:51 PM CDT
To: Jeff Cahn
Rudloff

To All:
Another revised version. Sorry. Also, EPA’s comments will not be sent to MDEQ until tomorrow
morning in order to give
everyone a chance to review and comment on the document.
Thanks.
-John
__________________
To All:
-John
__________________
To All:
-John
04/10/2008 08:52 AM
To
cc
Subject

COMMUNICATION
04/10/2008 08:24 AM
cc
Subject
ORC Mgmt:
-John
RALPH
04/09/2008 05:32 PM
cc
Subject
Sent: 04/09/2008 06:31 PM EDT
Greg
Fri . Cc me please.
Sent: 04/09/2008 05:19 PM AST
separate IRA.
late on April 11th.
Jim Sygo
Deputy Director
517-241-7394
sygoj@michigan.gov
Cahn/R5/USEPA/US]
Document Log
Review Status
Pending Complete
From To
CC BCC

04/10/2008 03:17 PM
COMMUNICATION
DowADRImp-111
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Do you want the draft IRA letter and our comments or just our comments? Thanks.
RALPH
To
04/10/2008 03:10 PM
cc
Subject
COMMUNICATION
John Steketee
From: John Steketee
Sent: 04/10/2008 02:51 PM CDT
To: Jeff Cahn
Rudloff
To All:
Thanks.
-John
__________________
To All:
-John
__________________
To All:
-John
04/10/2008 08:52 AM
To
cc
Subject
COMMUNICATION
04/10/2008 08:24 AM
cc
Subject
ORC Mgmt:
-John
RALPH
04/09/2008 05:32 PM
cc
Subject
Sent: 04/09/2008 06:31 PM EDT
Greg
Fri . Cc me please.
Sent: 04/09/2008 05:19 PM AST
separate IRA.
late on April 11th.
Jim Sygo
Deputy Director
517-241-7394
sygoj@michigan.gov
Cahn/R5/USEPA/US]
Document Log
Review Status
Pending Complete
From To
CC BCC

04/10/2008 03:33 PM
COMMUNICATION
DowADRImp-112
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Here is the latest version of LCDs comments. They are in [brackets] imbeded into the letter.
I gave you both to provide context for the comments. Thanks.
************************************************************************************************************************
*************************************************
DRAFT 4/10/2008 3:00 PM
April __, 2008 DRAFT
VIA E-MAIL and U.S. MAIL
Mr. Greg Cochran, Director

Michigan Dioxin Initiative
Michigan Operations
The Dow Chemical Company
1790 Building, Washington Street
Midland, Michigan 48674
Dear Mr. Cochran:
SUBJECT: 2008 Interim Response Activities (IRA)/Pilot Corrective Action Plans (PCAP)
Notice for the Tittabawassee River and Saginaw River; The Dow Chemical
Company (Dow); MID 000 724 724
The Michigan Department of Environmental Quality (MDEQ) has determined that IRAs for
portions of the Tittabawassee River are necessary in accordance with Conditions XI.B.9.
and XI.G. of the hazardous waste management facility operating license (License) issued to
Dow on June 12, 2003, pursuant to Part 111, Hazardous Waste Management, of the Natural
Resources and Environmental Protection Act, 1994 PA 451, as amended (Act 451). In some
cases these IRAs are a continuation of work that Dow began implementing in 2007 as IRAs
and Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
removal actions.
Pursuant to Condition XI.G.1. of the License, Dow is required to submit written IRA Work
Plan(s) to the Chief of the Waste and Hazardous Materials Division (WHMD) for review and
approval within 60 days of this notification. Condition XI.B.9. of the License provides that the
WHMD Chief may require Dow to implement IRAs to prevent, minimize, or mitigate injury to
public health, safety, welfare, or the environment in accordance with Condition XI.G. of the
License at any of the specific off-site area(s) identified in Condition XI.B.2. of the License
(which includes the Tittabawassee River and Saginaw River sediments and/or floodplain) at
any time during the corrective action process where information indicates that injury has, or
may have, resulted directly or indirectly from the facility. Condition XI.G. of the License
requires such activities to conform with or be substantively equivalent to the IRA provisions
of Part 201, Environmental Remediation, of Act 451, and Conditions XI.G.1. - XI.G.7. of the
License.
Consistent with discussions held between Dow and the MDEQ in 2007, and most recently
on March 25, 2008, the MDEQ supports the implementation of certain IRAs, once approved,
as PCAPs. If successful, the information obtained from implementation of these PCAPs may
be used to address areas that require IRAs and/or possibly final corrective actions in other
portions of the Tittabawassee River and Saginaw River. Mr. Greg Cochran 2 April __, 2008
DRAFT
Specific IRAs/PCAPs Required by this Notification
At this time, the MDEQ has determined that the following IRAs are necessary for the
Tittabawassee River and Saginaw River:
Reach D
1. Dow recently notified the U.S. Environmental Protection Agency (U.S. EPA) and the
MDEQ that the performance-based work required by the July 2007, CERCLA Removal
Order was complete and that Dow would begin restoration activities at Reach D
beginning in April 2008. During the March 25, 2008, meeting between Dow and the
MDEQ, Dow was notified by the MDEQ that additional corrective action work would be
necessary at the Reach D area because elevated levels of dioxins and furans continue
to be present in the Reach D area. In addition, other contaminants of concern, such as
chlorobenzenes and hexachlorobutadiene, which were not specifically addressed by the
CERCLA removal action, remain at levels that require further interim response work.
Dow and the MDEQ agreed to a follow-up meeting with the U.S. EPA to further discuss
these issues; that meeting took place on April 3, 2008. During the meeting on April 3,
2008, the MDEQ, Dow, and the U.S. EPA agreed that in order to close out work under
the CERCLA Removal Order, Dow would complete a number of “micro removals” to
address high levels of residual dioxin contamination followed by verification sampling in
these areas. As agreed at this meeting, the verification sampling is to include analysis
for dioxin and furans as well as: (a) the list of other contaminants of concern and (b)
detailed descriptions of the sampled media to distinguish resuspended sediments versus
bottom sediments. This would complete work required under the CERCLA Removal
Order and remaining work on elevated levels of dioxins and other contaminants of
concern would be conducted under an IRA Work Plan approved by the MDEQ. This
work is also to include additional delineation of contamination in the Reach D area and
probable additional sediment removal and/or capping and maintenance and monitoring.
Although not discussed during the meeting on April 3, 2008, it may appropriate to
evaluate this area as a candidate for the design and operation of a sediment trap,
depending on the results of the additional characterization work and the nature of the
remaining contaminants.

2. Tittabawassee Bank Stabilization Interim Response Activity/Pilot Corrective Action Plan
Large areas of bank erosion are present along the Tittabawassee River. In many cases
these eroding areas are highly contaminated with dioxins and furans. Consistent with the
U.S. EPA’s December 2005 Contaminated Sediment Guidance Document and in
follow-up to the MDEQ’s 2007 requirement to conduct IRAs on eroding banks in the
upper six miles of the Tittabawassee River Study Area, the MDEQ is now requiring Dow
to prioritize and propose three areas where bank stabilization will be implemented in
2008. In addition to controlling active sources of contamination early, the goal of these
projects would be to evaluate the effectiveness of bank stabilization technologies for
further use along the Tittabawassee River. Monitoring before and after bank stabilization
will be necessary for this evaluation.

Mr. Greg Cochran 3 April __, 2008 DRAFT
As previously discussed with Dow, the MDEQ and the Natural Resource Damage
Assessment (NRDA) Trustees believe that it is important to evaluate technologies that have
a “soft footprint” and are less intrusive than the CERCLA removal action proposed and
implemented by Dow on Reach J/K. The MDEQ has identified several areas that are of high
concern along the upper and middle Tittabawassee River, and we would like to discuss
these areas with Dow in light of the data that was submitted on March 1, 2008 (2007
Tittabawassee River Characterization Report), and April 1, 2008 (River Bank Stabilization
Pilot Corrective Action Project Report for the Tittabawassee River). The MDEQ considers
this work to be a very high priority. Without controls to stabilize or remove active eroding
bank sources, any other areas in the river channel or on the floodplain that have had
remedial actions completed are at risk of becoming recontaminated.
3. Saginaw River Sediment Trap Pilot Ongoing studies that have been conducted under the
Alternative Dispute Resolution/NRDA process have demonstrated the merits of
designing and proceeding with a pilot sediment trap on the Saginaw River. The February
1, 2008, Saginaw River and Bay Scope of Work (SRB SOW) Approval with Modifications
requires Dow to begin removing sediments from the Saginaw River as an IRA.
Consistent with the SRB SOW Approval with Modifications, Dow is required to develop
and submit a work plan to begin removing sediments from the Sixth Street Turning Basin
Area as an IRA.

4. Tittabawassee In-Channel Deposits During the implementation of the sampling plans to
characterize contaminated sediments in the Tittabawassee River during 2006 and 2007,
Dow identified a number of areas where high levels of contamination are present in river
sediments. Dow is required to evaluate and remove, cap, or otherwise stabilize, where
necessary, any areas in the Tittabawassee River where sediment concentrations in the
upper one foot the of sediment profile exceed 10,000 parts per trillion (ppt) TEQ. Where
sediment concentrations are greater than 10,000 ppt at the sediment surface, as an
interim response, Dow is required to propose removal or capping of these areas.
In the cases of the Reach L and Reach J/K deposits, Dow has indicated that these
deposits are stable in the short term and are unlikely to be remobilized by routine river
events, and Dow has not proposed removal or stabilization of these deposits as IRAs.
The MDEQ has identified several technical concerns with Dow’s evaluation and as an
IRA is now requiring Dow to develop and submit additional data to confirm the short-term
stability of these deposits and to provide additional empirical data on the behavior of
these types of deposits in the Tittabawassee River system. Dow is required to collect
this information early in the 2008 field season in order to determine if it will be necessary
to remove or otherwise stabilize one or both of these high concentration deposits in
advance of the implementation of a final remedy. Note that the surficial concentrations in
excess of 10,000 ppt TEQ that were identified at Reach J/K need to be removed or
capped as noted above as an IRA. Any removal and/or stabilization of these deposits
will need to be sequenced with the removal and/or stabilization of upstream in-channel
and eroding bank deposits to prevent recontamination of these areas after response
activities have been completed.
The following additional information is needed in order to evaluate Dow’s conclusion that the
Reach L and Reach J/K deposits are stable in the short term:
· Characterization of the deposits for other potential constituents of interest (PCOIs).
Samples of the high TEQ material and the “cap” material need to be evaluated for
the other Dow-related PCOIs. Note that the diffusion modeling conducted in the Dow
analysis is likely to be more appropriate for the nondioxin PCOIs.
· Bedload and suspended load sampling conducted on, and adjacent to, upstream and
downstream of the Reach L and Reach J/K deposits.
· Repetition of high resolution bathymetry in late spring of 2008 so that the geometry of
the deposit and adjacent thalweg can be compared to 2007 conditions.
· In-channel measurements to evaluate the stability and movement of the deposit (i.e.,
scour chains and elevation surveys of the top of sediment) over the spring and
summer.
· Additional information on the modeling that was conducted to evaluate the potential for
scour:
- Does the modeling take into account the upstream bridge structures at
Gordonville Road for the upper Reach L deposit?
- What were the results of the model for the 7-10 year flood event and
typical/non-flood flow conditions (especially given the presence of the upstream
constricting bridge structures)?
- What would be the effect of ice damming and/or ice scour on the upper Reach L
deposit, especially given the proximity of the Gordonville Road bridge structure?
The above information will also be useful in the future evaluation of in-channel deposits and
for the Tittabawassee River Remedial Investigation Work Plan.

5. Continued Signage and Advisory Outreach on the Tittabawassee River and Saginaw
River
The escrow account that Dow funded to address the placement of advisory signage along
the Tittabawassee River has been exhausted. The posting of additional signs and the
replacement and maintenance of the original signs on the Tittabawassee River and Saginaw
River needs to continue to be addressed as an IRA to advise the public to limit their
exposure to contaminated fish, wild game, and soils.
In addition, since the MDEQ’s supply of the informational pamphlets that were produced as
part of the Communications IRA for use in public outreach activities is nearly depleted, Dow
needs to provide additional copies of these pamphlets to the MDEQ. Mr. Greg Cochran 5
April __, 2008 DRAFT
Therefore, as a continuation of the Communications IRA, Dow is required to refresh the
escrow account so that sign placement and maintenance can continue. Dow is also required
to provide 1000 copies each of the Health Questions - Dioxins and Furans and Reducing
Exposure at Homes informational pamphlets and 300 copies of the Reducing Exposure from
Agricultural Activities informational pamphlets to the MDEQ for continued public outreach
activities.
6. Work Plan to Address the Disturbance and Management of Soils in Areas with Potential
Dioxin/Furan Contamination and Provision of Extent of Contaminated Floodplain
Notification to Miss Dig
Based upon the dioxin and furan investigation results to date that show the portions of the
Tittabawassee River floodplain that are contaminated with greater than 1,000 ppt TEQ
dioxins and furans, Dow is required submit the “Appendix C - Work Plan to Address the
Disturbance and Management of Soils in Areas with Potential Dioxin/Furan Contamination”
portion of the Communications IRA Work Plan that was deferred for later review and
approval at the time the Communications IRA Work Plan was approved in October 2004. In
particular, as part of this IRA, Dow is to provide a notification to the Miss Dig system of the
areas where safety and soil handling precautions should be taken by utility workers,
residents, etc. for any construction activities in these areas. The MDEQ can provide Dow
with a copy of the previous working draft of the Appendix C language.
In conjunction with this IRA, the MDEQ also requires Dow to submit a work plan for working
with the MDEQ to develop and print the informational pamphlet, Management of Disturbed
Soils and Dredged Sediments , required in Section 2.2, Informational Materials to be
Developed, of the February 2004 Communications IRA Work Plan that was approved with
modifications by the MDEQ on October 7, 2004.
Areas Where Follow-up IRAs are Likely to be Necessary in the Near Future
7. Follow-up on Exposure Unit Sampling Areas
The MDEQ, in coordination with U.S. EPA and the Michigan Department of Community
Health (MDCH), is conducting an independent assessment of certain areas along the
Tittabawassee River where the MDEQ has determined that there is high potential for human
exposure to dioxins and furans at levels that may require additional IRAs beyond those
implemented by Dow in 2005 and 2006. Following the review of sampling results and data
interpretation for sampling that is currently being conducted at the Riverside Boulevard Area
and the West Michigan Park Area, the MDEQ, in consultation with the U.S. EPA, MDCH,
and the Agency for Toxic Substances and Disease Registry, will determine what additional
actions, if any, need to be initiated as IRAs.

Although the MDEQ is not requiring additional IRAs in these areas at this time, it is quite
possible, based on initial chemical characterization information, that IRAs beyond those
completed in 2005 and 2006 by Dow, will be required in the near future.
Schedule
As noted above, Condition XI.G.1. of the License requires Dow to submit a written IRA Work
Plan to the Chief of the WHMD for review and approval within 60 days after the licensee
receives written notification by the WHMD Chief that IRAs are necessary. Accordingly, the
IRA/PCAP Work Plan for Reach L must be submitted to this office by June __, 2008. In the
meantime, the MDEQ remains available to meet with Dow to discuss the specific technical
requirements of these IRAs.
Please contact Mr. Al Taylor, Hazardous Waste Section, WHMD, at 517-335-4799 or
taylora@michigan.gov, to schedule a follow-up meeting or if you have any questions
regarding this notification.
Sincerely,
George W. Bruchmann, Chief
517-373-9523
cc: Mr. Ben Baker, Dow
Mr. David Gustafson, Dow
Mr. Philip Simon, ATS
Mr. Peter Simon, ATS
Mr. Ralph Dollhopf, U.S. EPA, Region 5
Mr. Greg Rudloff, U.S. EPA, Region 5
Mr. Jim Sygo, Deputy Director, MDEQ
Ms. De Montgomery, MDEQ
Mr. Steve Buda, MDEQ
Ms. Cheryl Howe, MDEQ
Dr. Deb MacKenzie-Taylor, MDEQ
Mr. Al Taylor, MDEQ
Mr. Terry Walkington/Ms. Trisha Peters, MDEQ
Off-Site Correction Action File
RALPH
To
04/10/2008 03:10 PM
cc
Subject
COMMUNICATION
John Steketee

From: John Steketee
Sent: 04/10/2008 02:51 PM CDT
To: Jeff Cahn
Rudloff
To All:
Thanks.
-John
__________________
To All:
-John
__________________
To All:
-John
04/10/2008 08:52 AM
To
cc
Subject
COMMUNICATION
04/10/2008 08:24 AM
cc
Subject
ORC Mgmt:
-John
RALPH
04/09/2008 05:32 PM
cc
Subject
Sent: 04/09/2008 06:31 PM EDT
Greg
Fri . Cc me please.
Sent: 04/09/2008 05:19 PM AST
separate IRA.
late on April 11th.
Jim Sygo
Deputy Director
517-241-7394
sygoj@michigan.gov
Cahn/R5/USEPA/US]
Document Log
Review Status
Pending Complete
From To
Catherine Garypie/R5/USEPA/US John Steketee/R5/USEPA/US@EPA
CC BCC

04/10/2008 04:51 PM
COMMUNICATION
DowADRImp-113
Previous #
Description
ADR?
ADR not determined
Superfund
Contains ADR
Withhold in Full
Document Body
My comment is in highlight
Catherine Garypie, Associate Regional Counsel
Office of Regional Counsel
U.S. Environmental Protection Agency, Region 5
77 West Jackson Blvd. (C-14J)
Chicago, Illinois 60604

PH 312-886-5825
FAX 312-886-0747
email: garypie.catherine@epa.gov
CONFIDENTIAL: This message may contain information that is privileged or otherwise exempt from
disclosure under applicable law. Do not disclose without consulting the Office of Regional Counsel. If
you think you received this email in error, please notify the sender immediately.
04/10/2008 02:51 PM
To
cc
Mendoza/R5/USEPA/US@EPA, Gregory
Rudloff/R5/USEPA/US@EPA
Subject
COMMUNICATION
To All:
Thanks.
-John
__________________
To All:
-John
__________________
To All:
-John
04/10/2008 08:52 AM
To
cc
Subject
COMMUNICATION
04/10/2008 08:24 AM
cc
Subject
ORC Mgmt:
-John
RALPH
04/09/2008 05:32 PM
cc
Subject
Sent: 04/09/2008 06:31 PM EDT
Greg
Fri . Cc me please.
Sent: 04/09/2008 05:19 PM AST

separate IRA.
late on April 11th.
Jim Sygo
Deputy Director
517-241-7394
sygoj@michigan.gov
Cahn/R5/USEPA/US]
Document Log
Review Status
Pending Complete
From To
John Steketee/R5/USEPA/US Catherine Garypie/R5/USEPA/US@EPA Catherine
Garypie/R5/USEPA/US
CC BCC

04/10/2008 05:01 PM
COMMUNICATION
DowADRImp-114
Previous #
Description
ADR?
ADR not determined
Superfund
Contains ADR
Withhold in Full
Document Body
You said:

My response:
Ex. 5 - Deliberativ...

Thanks.
-John
Catherine Garypie/R5/USEPA/US
Catherine
Garypie/R5/USEPA/US
To
04/10/2008 04:51 PM
cc
Leverett Nelson/R5/USEPA/US@EPA, Jeff
Subject
COMMUNICATION
PH 312-886-5825
FAX 312-886-0747
04/10/2008 02:51 PM
To
cc
Subject
COMMUNICATION
To All:
Thanks.
-John
__________________
To All:
-John
__________________
To All:
-John
04/10/2008 08:52 AM
To
cc
Subject
COMMUNICATION
04/10/2008 08:24 AM
cc
Subject
ORC Mgmt:
-John
RALPH
04/09/2008 05:32 PM
cc
Subject
Sent: 04/09/2008 06:31 PM EDT
Greg
Fri . Cc me please.
Sent: 04/09/2008 05:19 PM AST
separate IRA.
late on April 11th.
Jim Sygo
Deputy Director
517-241-7394
sygoj@michigan.gov

Cahn/R5/USEPA/US]
Document Log
Review Status
Pending Complete
From To
John Steketee/R5/USEPA/US Gregory Rudloff/R5/USEPA/US@EPA Gregory
Rudloff/R5/USEPA/US
CC BCC
Fw: Prompt Review Requested--MDEQ Draft IRA Letter --

04/10/2008 05:02 PM
COMMUNICATION
DowADRImp-115
Previous #
Description

Superfund
Contains ADR
Withhold in Full
Document Body
04/10/2008 05:01 PM
To
cc
Jeff Cahn/R5/USEPA/US@EPA, Leverett
Nelson/R5/USEPA/US@EPA
Subject
COMMUNICATION
You said:

My response:
Ex.
5 - Deliberative Process Privilege

Thanks.
-John
Catherine
Garypie/R5/USEPA/US
To
04/10/2008 04:51 PM
cc
Subject
COMMUNICATION
PH 312-886-5825
FAX 312-886-0747
04/10/2008 02:51 PM
To
cc
Subject
COMMUNICATION
To All:
Thanks.
-John
__________________
To All:
-John
__________________
To All:
-John
04/10/2008 08:52 AM
To
cc
Subject
COMMUNICATION
04/10/2008 08:24 AM
cc
Subject
ORC Mgmt:
-John
RALPH
04/09/2008 05:32 PM
cc
Subject
Sent: 04/09/2008 06:31 PM EDT
Greg
Fri . Cc me please.
Sent: 04/09/2008 05:19 PM AST
separate IRA.
late on April 11th.
Jim Sygo
Deputy Director
517-241-7394
sygoj@michigan.gov
Cahn/R5/USEPA/US]
Document Log
Review Status
Pending Complete
From To
John Steketee/R5/USEPA/US Gregory Rudloff/R5/USEPA/US@EPA Gregory
Rudloff/R5/USEPA/US
CC BCC
Fw: Prompt Review Requested--MDEQ Draft IRA Letter --

04/11/2008 06:53 AM
COMMUNICATION
DowADRImp-116
Previous #
Description

Superfund
Contains ADR
Withhold in Full
Document Body
Leverett
Nelson/R5/USEPA/US
To
04/10/2008 05:43 PM
cc
Catherine Garypie/R5/USEPA/US@EPA, Jeff
Subject
COMMUNICATION
All:
I’ve read the draft through and don’t have any substantive comments.
Just an idea of many that might work.
-Rett
04/10/2008 05:01 PM
To
cc
Jeff Cahn/R5/USEPA/US@EPA, Leverett
Nelson/R5/USEPA/US@EPA
Subject
COMMUNICATION
You said:

My response:
Ex.
5 - Deliberative Process Privilege

Thanks.
-John
Catherine
Garypie/R5/USEPA/US
To
04/10/2008 04:51 PM
cc
Subject
COMMUNICATION
PH 312-886-5825
FAX 312-886-0747
04/10/2008 02:51 PM
To
cc
Subject
COMMUNICATION
To All:
Thanks.
-John
__________________
To All:
-John
__________________
To All:
-John
04/10/2008 08:52 AM
To
cc
Subject
COMMUNICATION

04/10/2008 08:24 AM
cc
Subject
ORC Mgmt:
-John
RALPH
04/09/2008 05:32 PM
cc
Subject
Sent: 04/09/2008 06:31 PM EDT
Greg
Fri . Cc me please.
Sent: 04/09/2008 05:19 PM AST
separate IRA.
late on April 11th.
Jim Sygo
Deputy Director
517-241-7394
sygoj@michigan.gov
Cahn/R5/USEPA/US]
Document Log
Review Status
Pending Complete
From To
CC BCC
Re: mdeq letter to dow

04/16/2008 01:20 PM
DowADRImp-117
Previous #
Description

Superfund
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This language was in the 4/9/08 version (see below).

******************************************************************************
********************
Sent: 04/09/2008 06:31 PM EDT
Greg
Fri . Cc me please.
Sent: 04/09/2008 05:19 PM AST
separate IRA.
late on April 11th.
Jim Sygo
Deputy Director
517-241-7394
sygoj@michigan.gov
- copy of 4-10-2008 IRA demand letter 4 on ltrh.pdf
RALPH
04/16/2008 12:26 PM
To John Steketee/R5/USEPA/US@EPA, Gregory
cc
Subject
mdeq letter to dow
I just read it.
Document Log
Review Status
Pending Complete
From To
CC BCC
"Gregory Rudloff" <Rudloff.Gregory@epamail.epa.gov>

04/16/2008 01:33 PM
DowADRImp-118
Previous #
Description

Superfund
Contains ADR
Withhold in Full
Document Body
John Steketee
From: John Steketee
Sent: 04/16/2008 01:20 PM CDT
To: Ralph Dollhopf
Cc: Gregory Rudloff
Subject: Re: mdeq letter to dow


******************************************************************************
********************
Sent: 04/09/2008 06:31 PM EDT
Greg
Fri . Cc me please.
Sent: 04/09/2008 05:19 PM AST
separate IRA.
late on April 11th.
Jim Sygo
Deputy Director
517-241-7394
sygoj@michigan.gov
[attachment "copy of 4-10-2008 IRA demand letter 4 on ltrh.pdf" deleted by RALPH
RALPH
04/16/2008 12:26 PM
cc
Subject
mdeq letter to dow
I just read it.
Document Log
Review Status
Pending Complete
From To
CC BCC

04/16/2008 01:42 PM
DowADRImp-119
Previous #
Description

Superfund
Contains ADR
Withhold in Full
Document Body
Ok. Greg & I will discuss and we will keep an eye on this as we move forward.
RALPH
To
04/16/2008 01:33 PM
cc
Subject

John Steketee
From: John Steketee
Sent: 04/16/2008 01:20 PM CDT
To: Ralph Dollhopf
Cc: Gregory Rudloff

******************************************************************************
********************
Sent: 04/09/2008 06:31 PM EDT
Greg
Fri . Cc me please.
Sent: 04/09/2008 05:19 PM AST
separate IRA.
late on April 11th.
Jim Sygo
Deputy Director
517-241-7394
sygoj@michigan.gov
RALPH
04/16/2008 12:26 PM
cc
Subject
mdeq letter to dow
I just read it.
Document Log
Review Status
Pending Complete
From To
CC BCC

04/16/2008 02:04 PM
DowADRImp-120
Previous #
Description

Superfund
Contains ADR
Withhold in Full
Document Body
Yup
John Steketee
From: John Steketee
Sent: 04/16/2008 01:42 PM CDT
To: Ralph Dollhopf
Cc: Gregory Rudloff
Ok. Greg & I will discuss and we will keep an eye on this as we move forward.
RALPH
To
04/16/2008 01:33 PM
cc
Subject
John Steketee
From: John Steketee
Sent: 04/16/2008 01:20 PM CDT
To: Ralph Dollhopf
Cc: Gregory Rudloff

******************************************************************************
********************
Sent: 04/09/2008 06:31 PM EDT
Greg
Fri . Cc me please.
Sent: 04/09/2008 05:19 PM AST

separate IRA.
late on April 11th.
Jim Sygo
Deputy Director
517-241-7394
sygoj@michigan.gov
RALPH
04/16/2008 12:26 PM
cc
Subject
mdeq letter to dow
I just read it.

CREW: Environmental Protection Agency: Regarding Mary Gade: Dow CREW Appeal ADR - Revised Improperly Classified - PDF-R

Diunggah oleh

Informasi Dokumen

Judul Asli

Hak Cipta

Format Tersedia

Bagikan dokumen Ini

Bagikan atau Tanam Dokumen

Opsi Berbagi

Apakah menurut Anda dokumen ini bermanfaat?

Apakah konten ini tidak pantas?

Hak Cipta:

Format Tersedia

CREW: Environmental Protection Agency: Regarding Mary Gade: Dow CREW Appeal ADR - Revised Improperly Classified - PDF-R

Diunggah oleh

Hak Cipta:

Format Tersedia

Document Log

Review Status = Complete

Exemption/Privilege = Ex. 5 -- Deliberative Process

Gregory Rudloff/R5/USEPA/US John Steketee

Subject Date/Time Document Type

Fw: Invitation to Trustees

Tracking Number Pages Exemption/Privilege

General Responsiveness Determination

Responsive Partially responsive Not responsive Undecided

ADR? ADR not determined

Detailed Release/Withhold Status Explain Release/Withhold Status

----- Forwarded by Gregory Rudloff/R5/USEPA/US on 04/01/2008 12:26 PM -----

<mathur.bharat@epamail.epa.gov>, "Robert Kaplan"

We will not have anyone from epa (region or hq) attend.

Sent by EPA Wireless E-Mail Services

----- Original Message -----

From: Gregory Rudloff

Sent: 04/01/2008 10:57 AM CDT

To: Gade.Mary@epamail.epa.gov@EPA; Dollhopf.Ralph@epamail.epa.gov@EPA

Subject: Fw: Invitation to Trustees

Gregory A. Rudloff, P.G.

Corrective Action Section

Waste Management Branch

Land and Chemicals Division

Region 5, U.S. EPA

----- Forwarded by Gregory Rudloff/R5/USEPA/US on 04/01/2008 10:52 AM -----

Hazardous Waste Technical Support Unit

Waste and Hazardous Materials Division

Michigan Department of Environmental Quality

>>> "Joseph Heimbuch" <heimbuch@demaximis.com> 4/1/2008 8:42 AM >>>

Yesterday, I sent an e-mail to the Natural Resourec Trustees on behalf

Lansing. I have not heard back from any of them as yet.

For planning purposes, it would be helpful if you could let me know as

Give me a call if you have any questions...

2975 Bee Ridge Road

Sarasota, Florida 34239

Unless otherwise indicated, the information contained in this email

message is the exclusive property of de maximis, inc. and is privileged

and confidential information intended for the use of the individual(s)

or entity(s) named above. If the reader of this message is not the

intended recipient, or the employee or agent responsible to deliver it

dissemination, distribution, or copying of this communication is strictly

prohibited. If you have received this communication in error or are not

sure whether it is privileged, please immediately reply to the sender and

/or notify us by phone (865-691-5052) and destroy all copies whether

electronic and/or paper.

Exemption/Privilege = Ex. 5 -- Deliberative Process

John Steketee/R5/USEPA/US Bertram Frey/R5/USEPA/US@EPA

Subject Date/Time Document Type

Fw: Invitation to Trustees

Tracking Number Pages Exemption/Privilege

General Responsiveness Determination

Responsive Partially responsive Not responsive Undecided

Detailed Release/Withhold Status Explain Release/Withhold Status

----- Forwarded by John Steketee/R5/USEPA/US on 04/01/2008 12:35 PM -----

----- Forwarded by Gregory Rudloff/R5/USEPA/US on 04/01/2008 12:26 PM -----

<mathur.bharat@epamail.epa.gov>, "Robert Kaplan"

We will not have anyone from epa (region or hq) attend.

Sent by EPA Wireless E-Mail Services

----- Original Message -----

From: Gregory Rudloff

Sent: 04/01/2008 10:57 AM CDT

To: Gade.Mary@epamail.epa.gov@EPA; Dollhopf.Ralph@epamail.epa.gov@EPA