Document Qg5Kwz1GwzgV1kGD9v70XoYB4

Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: 05/15/2018 Water Clean Water Act The Dow Chemical Company Dow Chemical - Freeport 2301 N. Brazosport Blvd Freeport, Texas 332 SH 332 E Lake Jackson, TX 77566 Brazoria County Yvonne E. Samson 979-238-4814 EH&S Leveraged Delivery Operations Leader ysamson@dow.com FRS Number: Identification/Permit Number: Media Number: NAICS: SIC: TX0006483 424690 2869, 2865, 2812, 2821, 2819, 2822, 2813, 2879, 3339 Personnel participating in inspection: Michael Williams EPA / 6EN-WMH Maria Valdez Dow Chemical Chuck Zemanek Dow Chemical Mike Kidd Dow Chemical Inspector EH&S Environmental Operations Environmental Operations 281-983-2150 979-238-9778 EPA Lead Inspector Signature/Date Supervisor Signature/Date Digitally signed by MICHAEL WILLIAMS MICHAEL WILLIAMS DN: c=US, o=U.S. Government, ou=USEPA, ou=Staff, cn=MICHAEL WILLIAMS, dnQualifier=0000015063 Date: 2018.08.20 14:26:38 -05'00' Michael D. Williams Date Digitally signed by CAROL PETERS-WAGNON CAROL PETERS-WAGNON DN: c=US, o=U.S. Government, ou=USEPA, ou=Staff, cn=CAROL PETERS-WAGNON, dnQualifier=0000009981 Date: 2018.08.24 13:41:35 -05'00' Carol Peters Date The Dow Chemical Company (TX0006483) Inspection Date 05/15/2018 Section I - Introduction PURPOSE OF THE INSPECTION EPA Region 6 inspectors, Michael Williams arrived at The Dow Chemical Co.(Dow) at 10:45 am on May 15, 2018 for an unannounced inspection. I met with Maria Valdez, Environmental Health and Safety Specialist. I presented my credentials to Ms. Valdez and informed her that this was an EPA lead inspection to determine compliance with the Clean Water Act. The scope of the inspection was with permit TX0006483 and facility operations and maintenance under the Clean Water Act. The information presented in this report is based on the materials and information supplied by the Dow Chemicals Company representatives, (the permittee), observations made during the inspection and records and reports maintained by the permittee. FACILITY DESCRIPTION Dow is located at 2301 N. Brazosport Blvd, Freeport, Texas. The plant is a large integrated chemical manufacturing facility with over 65 separate chemical processing units. These units are owned by Dow, joint ventures between Dow and other companies, or owned by other companies. The site manufactures a variety of bulk, commodity and specialty chemicals as well as thermosetting and thermoplastic resins. The chlor-alkali units play a major role in the manufacturing of various products across the site. Products and feed materials are distributed utilizing a variety of shipping methods including, pipeline transfers, tank trucks, rail cars, barges and ships. Electricity is generated onsite through a series of power plants. Salt Dome Operations and the Dow pipeline systems are an integral party of the Dow Freeport site. These operations are used to mine brine, transfer and store products and raw materials Wastewater is generated from multiple wastewater streams generated by the process units at the facility that include both process and non-process wastewater. The wastewater is treated at the wastewater treatment plant. The plant is composed of a biological treatment system as well as neutralization, solids separation and settling to treat many of the wastewater streams. The facility has a variety of storm water discharges that are required to be monitored. Section II- Observations This inspection revealed the following observations: Operations - On the day of the inspection, the facility wastewater treatment plant appeared to be operating as designed. Exceedances have occurred during wet weather conditions with heavy rainfall. Within the last twelve months, the facility has exceeded their loading twice and flow limitations once for their storm water outfalls. Section III- Areas of Concerns This inspection revealed the following areas of concerns: No major areas of concerns on the day of the inspection. 2 Section IV - LIST OF APPENDICES Appendix A - Block Flow Overview The Dow Chemical Company (TX0006483) Inspection Date 05/15/2018 Appendix A Block flow Overview 3 PO Vents Vapor WWTP Flow Diagram Thermal Treatment Units Vapor Vapor Waste Water Tanks Primary Treatment Reactors Clarifiers Solids Water Solid Treatment & Handling Landfill Water from Thermal Treatment Units Waste Water Solid Precipitation Settler Solids to Landfill Organic Separator Organics Vents/ Water Steam Stripper Water Outfall DSN 202 Vents Incineration Thermal Treatment Units Outfall DSN 202 Water to Outfall DSN 202 Vapor Vapor DOW RESTRICTED