Need to return call by / at/between and . Signature: ___________________________ 

Project No.: 0172.07.005.504 DISTRIBUTION 

Page _1_ of __1_

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, to 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 mercury 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 that 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 confidential 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 message, in whole or in part, without 

permission of the sender. 

From: Elizabeth Sabol [mailto:Elizabeth.Sabol@erg.com] 

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 Discharges 

 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 information in the docket in the past; 

however, this data transmittal included an auto-disclaimer at the end of this e-mail. 

In order to do include the updated Mercury information 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 confidential 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 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 docket. 

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" <Eleanor.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 report the Mercury for outfall DSN006 in micrograms/liter. We reported 170 μg/l Hg 

which is equivalent to 0.17 mg/liter Hg. I also have provided the response to your e-mail below: 

1. The concentration reported for the 2nd semi-annual monitoring event was 170 μg/l (micrograms/liter). 
2. The concentration reported for DSN006 is micrograms per liter (μg/l). I have attached the NPDES Permit page for this 

outfall. 

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

 

Please confirm receipt of this information by replying to this e-mail. If you require further information 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 confidential 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 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 Group (ERG) is an 

authorized EPA contractor and the work they are doing is under my 

direction. 

I tried to call you and provide you with this information the week of 

March 8th. I hope you received my voice mail message 

If any of the information you are submitting is considered Confidential 

Business Information (CBI) please label it so, so we 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.Williams@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 Discharges 
 

Mr. Swietlik, 

Please confirm that Eastern Research Group is an EPA contractor and that 

it is ok to provide the information requested. I have the information 

ready and am happy to provide it. Just need to make 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 confidential 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 message, in whole or in 

part, without permission of the sender. 

From: Elizabeth Sabol [mailto:Elizabeth.Sabol@erg.com] 

Sent: Thursday, March 18, 2010 10:09 AM 

To: Williams, SF (Sylvia) 

Cc: swietlik.william@epa.gov; Eleanor Codding; Jessica Wolford 

Subject: Akzo Nobel - DMR 2008 Mercury Discharges 

Dear Ms. Williams, 

Thank you for your time on the phone yesterday. Eastern 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 background 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 CWA requires EPA to 

annually review and, if appropriate, revise its water pollution control 

technology-based regulations, called “effluent limitations guidelines” 

or "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 2010 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 2010 Effluent 

Guidelines Program Plan scheduled for publication in the Federal 

Register in December 2010. As part of the 2010 annual review, EPA is 
evaluating 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 the mercury 

concentration for Outfall 006 you reported for December 2008. The 

following questions will help us obtain the correct concentration for 

your facility. 

1. What was the reported mercury concentration value for 2008? 

2. What are the units for the mercury concentration? 

3. Are there any below detection limit indicators with the concentration 

value? 

The data we have currently show: 

 - 170 mg/L for DSCH 006 reported December 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, please call me at 

(703) 633-1659. 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. 

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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