Dow Chemical 2009 Annual Report Download - page 102

Table of Contents
Information regarding environmental sites is provided below:
Environmental Sites Dow-owned Sites (1) Superfund Sites (2)
2009 2008 2009 2008
Number of sites at January 1 252 251 85 94
Sites acquired from Rohm and Haas 42 - 39 -
Sites added during year 2 3 6 9
Sites closed during year (5) (2) (6) (18)
Number of sites at December 31 291 252 124 85
(1) Dow-owned sites are sites currently or formerly owned by Dow, where remediation obligations are imposed in the
United States by the Resource Conservation Recovery Act or analogous state law. 153 of these sites were formerly
owned by Dowell Schlumberger, Inc., a group of companies in which the Company previously owned a 50 percent
interest. Dow sold its interest in Dowell Schlumberger in 1992.
(2) Superfund sites are sites, including sites not owned by Dow, where remediation obligations are imposed by Superfund
Law.
The Company’s manufacturing sites in Freeport, Texas; Midland, Michigan; and Philadelphia, Pennsylvania; and a Superfund site in Wood-Ridge,
New Jersey, are the sites for which the Company has the largest environmental remediation accruals.
From the start of operations at the Freeport site in the 1940s until the mid-1970s, manufacturing wastes were typically placed in on-site pits and landfills.
The resulting soil and groundwater contamination is being assessed and remediated under the provisions of the Resource Conservation Recovery Act
(“RCRA”), in concert with the state of Texas. At December 31, 2009, the Company had an accrual of $29 million ($25 million at December 31, 2008) related
to environmental remediation at the Freeport manufacturing site. In 2009, $3 million ($5 million in 2008) was spent on environmental remediation at the
Freeport site.
Similar to the Freeport site, in the early days of operations at the Midland site, manufacturing wastes were usually disposed of on-site, resulting in soil
and groundwater contamination, which has been contained and managed on-site under a series of RCRA permits and regulatory agreements . The most recent
Hazardous Waste Operating License for the Midland site, issued in 2003, also included provisions for the Company to conduct an investigation to determine
the nature and extent of off-site contamination from historic Midland site operations. The scope of the investigation includes Midland area soils; the
Tittabawassee and Saginaw River sediment and floodplain soils; and Saginaw Bay, and requires the Company to conduct interim response actions. In
January 2010, the Company entered into a Federal Comprehensive Environmental Response, Compensation, and Liability Act Administrative Order on
Consent to perform a Remedial Investigation, Feasibility Study and Remedial Design for the Tittabawassee and Saginaw River sediment and floodplain soils,
and Saginaw Bay. See Note N to the Consolidated Financial Statements for additional information. At December 31, 2009, the Company had an accrual of
$64 million ($35 million at December 31, 2008) for environmental remediation and investigation associated with the Midland site. In 2009, the Company
spent $19 million ($36 million in 2008) on environmental remediation at the Midland site.
On April 1, 2009, the Company acquired Rohm and Haas’ Philadelphia Plant, which has been an industrial site since the early 1700s, and since the
1920s used by Rohm and Haas for the manufacture of a wide range of chemical products. Chemical disposal practices in the early years resulted in soil and
groundwater contamination at the site and in the sediments of the adjacent Frankford Inlet. The site has undergone a number of investigations and interim
cleanup measures under the RCRA Corrective Action Program, and in 2009, was transferred to the regulatory management of the Pennsylvania One Cleanup
Program. At December 31, 2009, the Company had an accrual of $58 million for environmental remediation at the Philadelphia Plant. Since the acquisition,
the Company has spent $1 million on environmental remediation at the Philadelphia Plant.
Rohm and Haas is a lead PRP at the Wood-Ridge, New Jersey Ventron/Velsicol Superfund Site, and the adjacent Berry’s Creek Study Area. Rohm and
Haas is a successor in interest to a company that owned and operated a mercury processing facility, where wastewater and waste handling resulted in
contamination of soils and adjacent creek sediments. The Ventron/Velsicol site is currently undergoing remediation. The Berry’s Creek Study Area is under the
preliminary remedial
72