## Need to return call by / at/between and . Signature: ___________________________ Project No.: 0172.07.005.504 DISTRIBUTION

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### Project Name: 304(m) Annual Review

TELEPHONE CALL RECORD

Outgoing Call Date: 3/17/2010 Time: 10:20 am EST

Company Name: Akzo Nobel Functional Chemical
(AL0001961) Contact Name: Sylvia Williams

Phone No.: 251-675-1310

Name: Elizabeth Sabol Eastern Research Group

GENERAL SUBJECT : Mercury concentration reported to DMR in 2008



# TOPICS DISCUSSED AND ACTION TAKEN

I called Akzo Nobel Functional Chemical on March 17, 2010, t o speak with Sylvia Williams. I left Ms. Williams a message identifying myself and why I was calling. Ms. Williams returned my phone call on Wednesday, March 17, 2010, at 3:30 pm. We briefly discussed merc ury discharges and from Outfall 006.

Ms. Williams explained that she would have to respond to my request at another time, suggesting that e-mail may be a better form of communication. I told her tha t I would send her an e-mail, identifying ERG as an EPA contractor and explaining what the information was being used for. Please see attached e-mail documentation regarding the mercury discharges.From: "Williams, SF (Sylvia)" <Sylvia.Williams@AkzoNobel .com>

To: "Elizabeth Sabol" <Elizabeth.Sabol@erg.com>

CC: "Naron, JA (John)" <John.Naron@AkzoNobel.com>

Date: 10/29/2010 11:40 AM Subject: RE: Akzo Nobel - DMR 2008 Mercury Discharges

Ms. Sabol, You have permission to include the data I submitted to you on 3/22/2010 via e-mail in the EPA docket.

Sylvia F. Williams Senior Environmental Engineer

Akzo Nobel Functional Chemicals LLC 13440 Highway 43 North Axis, Alabama 36505 E-mail: sylvia.williams@akzonobel.com Telephone: 251-679-4315
Fax :251-679-4362

This message, including attached files is confiden tial and may be privileged. If you are not an inte nded recipient, please notify the sender then delete and destroy the original message and all cop ies. You should not copy, forward and/or disclose this message, in whole or in part, without permission of the sender.

From: Elizabeth Sabol [mailto:Elizabeth.Sabol@erg.c om] Sent: Friday, October 29, 2010 9:30 AM To: Williams, SF (Sylvia) Cc: swietlik.william@epa.gov; Eleanor Codding Subject: RE: Akzo Nobel - DMR 2008 Mercury Discharg es

Ms. Williams,

Thanks again for the data you provided. EPA would like to include these data as part of their public docket, to show why they adjusted the discharged pounds of mercury based on units errors (μg/L vs. mg/L). The public docket is available at http://www.regulations.gov <http://www.regulations.gov/> , Docket ID EPA-HQ-OW -2008-0517. We have included this type of informati on in the docket in the past; however, this data transmittal included an auto-dis claimer at the end of this e-mail.

In order to do include the updated Mercury informat ion that Akzo Nobel provided in the public docket, we would need your permission to ignore the auto-disclaimer generated at the bottom of this e-mail:

"This message, including attached files is confiden tial and may be privileged. If you are not an inten ded recipient, please notify the sender then delete and destroy the original message and all cop ies. You should not copy, forward and/or disclose t his message, in whole or in part, without permission of the sender."

Please reply to this e-mail to let us know if it is ok to include the information in EPA's public dock et.

Thanks,

Elizabeth

Elizabeth A. Sabol Environmental Engineer Eastern Research Group, Inc. 14555 Avion Parkway, Suite 200 Chantilly, VA 20151 elizabeth.sabol@erg.com
Phone:703-633-1659

From: "Williams, SF (Sylvia)" <Sylvia.Williams@AkzoNobel .com>
To: "Elizabeth Sabol" <Elizabeth.Sabol@erg.com>
CC: <swietlik.william@epa.gov>, "Eleanor Codding" <Ele anor.Codding@erg.com>, "Jessica Wolford" <Jessica.Wolford@erg.com>

Date: 3/22/2010 11:41 AM Subject: RE: Akzo Nobel - DMR 2008 Mercury Discharges

Attachments: DSN006 NPDES limits.pdf

Ms. Sabol,

As we discussed the NPDES permit requires me to rep ort the Mercury for outfall DSN006 in micrograms/li ter. We reported 170 μg/l Hg which is equivalent to 0.17 mg/liter Hg. I also ha ve provided the response to your e-mail below:

1. The concentration reported for the 2nd semi-annu al monitoring event was 170 μg/l (micrograms/liter)

.2. The concentration reported for DSN006 is microg rams per liter (μg/l). I have attached the NPDES Permit page for this

outfall.

3. There are no below detection limit indicators f or this concentration value.

Please confirm receipt of this information by reply ing to this e-mail. If you require further informa tion let me know.

Kind Regards,

Sylvia F. Williams Senior Environmental Engineer

Akzo Nobel Functional Chemicals LLC 13440 Highway 43 North Axis, Alabama 36505 E-mail: sylvia.williams@akzonobel.com Telephone: 251-679-4315

Fax :251-679-4362

This message, including attached files is confident ial and may be privileged. If you are not an inten ded recipient, please notify the sender then delete and destroy the original message and all cop ies. You should not copy, forward and/or disclose this message, in whole or in part, without permission of the sender.

________________________________

From: <Swietlik.William@epamail.epa.gov>

To: "Williams, SF (Sylvia)" <Sylvia.Williams@AkzoNobel .com> CC: <elizabeth.sabol@erg.com>

Date: 3/22/2010 10:55 AM Subject: RE: Akzo Nobel - DMR 2008 Mercury Discharges

Ms. Williams:

Thank you for your e-mail. Yes, Eastern Research G roup (ERG) is an authorized EPA contractor and the work they are doi ng is under my

direction.

I tried to call you and provide you with this infor mation the week of March 8th. I hope you received my voice mail messa ge

If any of the information you are submitting is con sidered Confidential Business Information (CBI) please label it so, so w e can process and handle it correctly under our CBI procedures.

Thank you for your cooperation.

_______________________ Bill Swietlik Engineering and Analysis Division (4303-T) Office of Water/Office of Science and Technology

U. S. EPA 1200 Pennsylvania Ave., N.W. Washington, DC, 20460
202-566-1129: Desk

202-566-1053: FAX

From: "Williams, SF (Sylvia)" <Sylvia.Willi ams@AkzoNobel.com>

To: William Swietlik/DC/USEPA/US@EPA

Cc: <elizabeth.sabol@erg.com>

Date: 03/18/2010 02:14 PM

Subject: RE: Akzo Nobel - DMR 2008 Mercury Dis chargesMr. Swietlik,

Please confirm that Eastern Research Group is an EP A contractor and that it is ok to provide the information requested. I h ave the information ready and am happy to provide it. Just need to mak e sure I follow the security protocol.

Kind Regards,

Sylvia

Sylvia F. Williams Senior Environmental Engineer

Akzo Nobel Functional Chemicals LLC 13440 Highway 43 North Axis, Alabama 36505 E-mail: sylvia.williams@akzonobel.com Telephone: 251-679-4315
Fax :251-679-4362

This message, including attached files is confident ial and may be privileged. If you are not an intended recipient, please notify the sender then delete and destroy the original message and all copies. You should not copy, forward and/or disclose this messa ge, in whole or in part, without permission of the sender.

From: Elizabeth Sabol [mailto:Elizabeth.Sabol@erg.c om] Sent: Thursday, March 18, 2010 10:09 AM To: Williams, SF (Sylvia) Cc: swietlik.william@epa.gov; Eleanor Codding; Jess ica Wolford Subject: Akzo Nobel - DMR 2008 Mercury Discharges

Dear Ms. Williams,

Thank you for your time on the phone yesterday. Ea stern Research Group, Inc. (ERG) under EPA Contract No. 68-C-02-095 is e- mailing you on EPA’s behalf to request information on mercury discharges reported in your 2008 discharge monitoring reports. Here is some bac kground on what the

information is used for.

EPA reviews publicly-available DMR data to fulfill its review obligation under Section 304(b) of the Clean Water Act. The CW A requires EPA to annually review and, if appropriate, revise its wat er pollution control technology-based regulations, called “effluent limi tations guidelines” or "effluent guidelines,” that limit the discharge of pollutants to waters of the U.S. from various categories of indus trial facilities. EPA is currently conducting its 2010 annual review of existing effluent guidelines and potential industrial guidelines whic h may need to be included (see http://www.epa.gov/guide/304m/ for fu rther information).

EPA will discuss this review and the results in its 2010 Effluent Guidelines Program Plan scheduled for publication i n the Federal Register in December 2010. As part of the 2010 annu al review, EPA isevaluating the data you reported in your discharge monitoring reports in

2008 and needs further information to complete the review. EPA is also contacting POTWs, permitting authorities, and other facilities to verify

similar information.

We would like to obtain additional information on t he mercury concentration for Outfall 006 you reported for Dece mber 2008. The following questions will help us obtain the correct concentration for your facility.

1. What was the reported mercury concentration valu e for 2008? 2. What are the units for the mercury concentration ? 3. Are there any below detection limit indicators w ith the concentration

value?

The data we have currently show:

- 170 mg/L for DSCH 006 reported Dec ember 31, 2008

We appreciate your help in confirming if the above data are accurate, or

if there is a units error in the DMR data.

If you have any questions regarding this request, p lease call me at (703) 633-1659. If you would like to speak directl y with EPA regarding this request, you can contact William F. Swietlik o f EPA's Office of Water/Engineering Analysis Division by phone at (20 2) 566-1129 or by email: swietlik.william@epa.gov.

Thanks,

Elizabeth Sabol

Elizabeth A. Sabol Environmental Engineer Eastern Research Group, Inc. 14555 Avion Parkway, Suite 200 Chantilly, VA 20151 elizabeth.sabol@erg.com
Phone:703-633-1659

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