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Project No.: 0317.02.005.520 Page 1 of 5

Project Name: TRI2013 CBI?

Yes

No

TELEPHONE CALL RECORD

Incoming

Outgoing

Date: 6/01/15 Time: 1:30 am

pm

Company Name: Charter Steel Cleveland ERG Staff Name: Kimberly Bartell

Contact Name: Jay Lawniczak Contact Phone Number: (216) 429-7675

General Subject: 2013 TRI Lead and Lead Compound Discharges for Charter Steel

TOPICS DISCUSSED AND ACTION TAKEN

Matt Schroeder: 262-268-2565, schroederm@chartersteel.com

I called Mr. Schroeder on June 1, 2015 and left a message. I followed up with an email on June 1 as well. See 

attached email correspondence.

On June 23, I called Jay Lawniczak and left a message stating that I had a follow up question about their data. 

Mr. Lawniczak returned my call and stated that all the stormwater discharges were BDL (<0.01 mg/L). He also 

confirmed an error in their conversion from mg to pounds of lead discharged in their indirect discharge 

calculations (values should be divided by 1,000). Mr. Lawniczak asked if the facility should update their data 

with TRI and requested a follow up email from me. See attached email correspondence.
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Email Communication with Charter Steel Cleveland

From: Jay Lawniczak (lawniczakj@chartersteel.com)

To: Kimberly Bartell

CC: Matt Schroeder (schroederm@chartersteel.com)

Date: 06/30/15 11:53 AM

Subject: RE: 2013 TRI Clarification for Lead Discharges

Kimberly,

Thanks for your help in the matter.

Regards,

Jay Lawniczak SR. ENVIRONMENTAL ENGINEER, CHARTER STEEL

DIRECT 216.429.7675 : MOBILE 440.787.4555

Charter Manufacturing, Inc. One Family. One Team.

www.chartermfg.com

From: Kimberly Bartell

To: Jay Lawniczak (lawniczakj@chartersteel.com)

CC: Matt Schroeder (schroederm@chartersteel.com)

Date: 06/30/15 10:16 AM

Subject: RE: 2013 TRI Clarification for Lead Discharges

Hi Jay,

I checked on updating the TRI data for your facility due to the error identified after we talked last week. If possible, we suggest at the 

minimum correcting 2013 and 2014 data and working with TRI to correct reporting from earlier years, if possible. I don’t have a direct 

contact at TRI to send to you, but we have found that using the TRI program contacts on this page is fairly simple: 

http://www2.epa.gov/toxics-release-inventory-tri-program/forms/tri-program-contacts.

Thank you,

Kimberly

--------------------------------------

Kimberly D. Bartell

Environmental Engineer

Eastern Research Group, Inc.

kimberly.bartell@erg.com

Phone: 517-515-1721

From: Kimberly Bartell

To: Jay Lawniczak (lawniczakj@chartersteel.com)

CC: Matt Schroeder (schroederm@chartersteel.com)

Date: 06/03/15 4:31 PM

Subject: RE: 2013 TRI Clarification for Lead Discharges

Hi Jay,

Thank you for your response. Yes, I should have clarified, indirect discharges are those to a local POTW and direct discharges are via 

stormwater. I’ll look through the information you provided and let you know if we have any further questions. 

Thanks again,

Kimberly

--------------------------------------

Kimberly D. Bartell
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Environmental Engineer

Eastern Research Group, Inc.

kimberly.bartell@erg.com

Phone: 517-515-1721

From: Jay Lawniczak (lawniczakj@chartersteel.com)

To: Kimberly Bartell

CC: Matt Schroeder (schroederm@chartersteel.com)

Date: 06/03/15 12:27 PM

Subject: RE: 2013 TRI Clarification for Lead Discharges

Hello Kimberly,

I am responding on behalf of Matt Schroeder in regards to 2013 Pb direct and indirect water discharges from the Charter Steel

Cleveland site. I have attached the 2013 Pb Form R and it doesn’t exactly line up with what you provided water releases. I am 

assuming indirect discharge refers to water discharged to the local POTW and that direct discharge is via stormwater. 

We have two wastewater treatment plants (Meltshop and Rolling Mill) on-site that discharge (indirect discharge) to the local POTW. 

The 2013 amount discharged is listed with each plant along with the most recent analytical information for lead (among other 

pollutants). I also have included stormwater data (direct discharge) for 2013. Please contact me if you have additional questions. The 

lead analytical testing for the stormwater discharges had a lower detection limit of 0.010 mg/L so we reported 0.010 mg/L. The result 

may have been much lower.

Jay Lawniczak SR. ENVIRONMENTAL ENGINEER, CHARTER STEEL

DIRECT 216.429.7675 : MOBILE 440.787.4555

Charter Manufacturing, Inc. One Family. One Team.

www.chartermfg.com

POTW Discharge - Melt Shop

Discharge 20,540,854.59 Gallons

77,755,597 Liters

Lead (mg/L) Zn (mg/L) Ni (mg/L) Hg (mg/L)

Average 0.030 0.139 0.013 1.38E-05

mg Release (kg) Release (lbs)

Lead 2,332,668 2,333 5,142.65

Zinc 10,808,028 10,808 23,827.59

Nickel 1,010,823 1,011 2,228.48

Mercury 1,073 1 2.37

POTW Discharge - Rolling Mill

Discharge 9,098,000 Gallons

34,439,678 Liters

Lead (mg/L) Zn (mg/L) Hg (mg/L)

Average 0.016 0.033 0.000005

mg Release (kg) Release (lbs)
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Lead 551,035 551 1,214.82

Zinc 1,136,509 1,137 2,505.57

Mercury 172 0 0.38

Stormwater Discharge

Stormwater Discharge was calculated by multiplying the annual rainfall by the runoff coefficient and the land 

area.

Discharge 5,755,587 Gallons

21,787,26

8 Liters

Cr (mg/L) Mn (mg/L)

Lead 

(mg/L) Zn (mg/L) Hg (mg/L) Ni (mg/L)

Cu 

(mg/L)

Al 

(mg/L)

8/7/2007 & 

5/28/09 BQL 0.002 BQL 0.009 BQL 0.005 BQL

6/9/2010 <0.010 <0.050 <0.050

11/7/2013 <0.01 0.0579

12/20/2013 <0.01 0.023

2/25/2013 0.16

Average 0.010 0.002 0.010 0.009 0.005 0.050 0.16

mg

Release 

(kg)

Release 

(lbs)

Chromium 217,873 218 480.33 480.33

Manganese 43,575 44 96.07

Lead 217,873 218 480.33

Zinc 196,085 196 432.29

Mercury 0 0 0.00

Nickel 108,936 109 240.16

Copper 1,089,363 1,089 2,401.63

Aluminum 3,485,963 3,486 7,685.22

Jay Lawniczak SR. ENVIRONMENTAL ENGINEER, CHARTER STEEL

DIRECT 216.429.7675 : MOBILE 440.787.4555

Charter Manufacturing, Inc. One Family. One Team.

www.chartermfg.com

From: Kimberly Bartell

To: Matt Schroeder (schroederm@chartersteel.com)

CC: William Swietlik

Date: 06/01/15 2:05 PM

Subject: 2013 TRI Clarification for Lead Discharges

Mr. Schroeder:

Eastern Research Group, Inc. (ERG) under EPA Contract No. EP-C-12-021, is e-mailing you to request clarification for the Charter 

Steel Cleveland lead and lead compound discharges (TRI ID: 44125MRCNS4300E). See below for background on what the 

information is used for.
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EPA reviews publicly-available discharge monitoring report (DMR) and toxic release inventory (TRI) data to fulfill its review 

obligation under Section 304(b) of the Clean Water Act. The CWA requires EPA to annually review and, if appropriate, revise its 

water pollution control technology-based regulations, called "effluent guidelines," that limit the discharge of pollutants to waters of the 

U.S. from various categories of industrial facilities. EPA is currently conducting its 2015 annual review of existing effluent guidelines 

and potential industrial guidelines which may need to be included (see http://www.epa.gov/guide/304m/ for further information). EPA 

will discuss this review and the results in its 2015 Effluent Guidelines Program Plan scheduled for publication in the Federal Register 

sometime in 2015 or 2016.

As part of the 2015 annual review, EPA is evaluating the data reported to the 2013 TRI and needs further information to complete the 

review. Specifically, we would like to clarify the amount of lead and lead compounds reported to the 2013 TRI for Charter Steel 

Cleveland. Please confirm/review the following data and questions below.

1. Please confirm the pounds of lead and lead compounds released in 2013: 1,945 pounds (483 pounds direct discharge, 1,462 

pounds indirect discharge)

2. Please explain how the lead and lead compound load is calculated for both direct and indirect discharges.

We appreciate your help in interpreting TRI data correctly. If you have any questions regarding this request, please call me at (517) 

515-1721. If you would like to speak directly with EPA regarding this request, you can contact William F. Swietlik of EPA's Office of

Water/Engineering Analysis Division by phone at (202) 566-1129 or by email: swietlik.william@epa.gov.

Thank you,

Kimberly

--------------------------------------

Kimberly D. Bartell

Environmental Engineer

Eastern Research Group, Inc.

kimberly.bartell@erg.com

Phone: 517-515-1721