Dow Chemical 2012 Annual Report Download - page 90

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Information regarding environmental sites is provided below:
Environmental Sites Dow-owned Sites (1) Superfund Sites (2)
2012 2011 2012 2011
Number of sites at January 1 286 289 120 120
Sites added during year 83115
Sites closed during year (4) (6) (5) (5)
Number of sites at December 31 290 286 126 120
(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.
150 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.
Additional information is provided below for the Company’s manufacturing sites in Freeport, Texas; Midland, Michigan;
Philadelphia, Pennsylvania; and Camaçari, Brazil, the sites for which the Company has the largest environmental remediation
accruals; as well as a Superfund site in Wood-Ridge, New Jersey.
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 and Recovery Act (“RCRA”), in concert with the state of Texas. At December 31,
2012, the Company had an accrual of $31 million ($29 million at December 31, 2011) related to environmental remediation at
the Freeport manufacturing site. In 2012, $5 million ($6 million in 2011) 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 the City of Midland area soils; the
Tittabawassee and Saginaw River sediment and floodplain soils; and the Saginaw Bay, and requires the Company to conduct
interim response actions. In January 2010, the Company, the U.S. Environmental Protection Agency ("EPA") and the State of
Michigan ("State") entered into an administrative order on consent that requires the Company to conduct a remedial
investigation, a feasibility study and a remedial design for the Tittabawassee River, the Saginaw River and the Saginaw Bay,
and will pay the oversight costs of the EPA and the State under the authority of the Comprehensive Environmental Response,
Compensation, and Liability Act Administrative Order. See Note 14 to the Consolidated Financial Statements for additional
information. At December 31, 2012, the Company had an accrual of $85 million ($81 million at December 31, 2011) for
environmental remediation and investigation associated with the Midland site. In 2012, the Company spent $24 million
($16 million in 2011) 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, 2012, the Company had an accrual of $57 million ($57 million at December 31, 2011) for
environmental remediation at the Philadelphia Plant. In 2012, the Company spent $1 million ($1 million in 2011) on
environmental remediation at the Philadelphia Plant.
Rohm and Haas is a PRP at the Wood-Ridge, New Jersey Ventron/Velsicol Superfund Site, and the adjacent Berry’s Creek
Study Area ("BCSA"). 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. Remediation of
the upland portions of the Ventron/Velsicol site was completed in 2011. Currently, the Berry’s Creek Study Area PRP group is
undertaking a multi-stage Remedial Investigation/Feasibility Study ("RI/FS") to identify contamination in surface water,
sediment and biota related to numerous contaminated sites in the Berry's Creek watershed. The RI/FS eventually will support a
remedial action plan for the BCSA and is expected to require several more years to complete. At December 31, 2012, the