Need to return call by / at/between and

. Signature: Project No.: 

### 0 317.0 2 .005.520 Page 1 of 5

Project Name: 

### TRI 20 1 3 

## CBI?

Yes

No TELEPHONE CALL RECOR D

Incoming

Outgoing Date: 

### 5/27/15 Time: 

### 1 0:15 am

pm

Company Name: 

### US Steel ERG Staff Name: 

### Kimberly Bartell

Contact Name: 

### Brian Lasko Contact Phone Number: 

### ( 412) 433

- 5917

General Subject: 

### 2013 DMR and TRI Discharges for U.S. Steel Facilities



## TOPICS DISCUSSED AND ACTION TAKEN

On May 27, 2015 Brian Lasko, Dave Buschmann, and Monica Gesk called to follow up on Brian’s email from

5/20/15. Mr. Lasko gave me permission to use his email in our record, providing I remove the last sentence

about meetings with DRBC. He also stated that in his last paragraph the “central canal” should be “east canal”.

The Fairless Hills facility PCB’s discharges are historic, not from current processes.

For Clairton, the permit was reissued October 2 012 and the cyanide limits were appealed. The facility settled

with DEP with a consent order in January 2014. The permit was reissued and became effective in 2015 with

higher cyanide limits.

See attached email correspondence.Need to return call by / at/between and

. Signature: 

### Email Communication with US Steel

From: Kimberly Bartell

To: Brian Lasko

CC: Eric Williams, Robert Casselberry, Monica Gesk

Date: 06/16/15 3:20 PM

Subject: RE: 2013 DMR Clarification for PCB Discharges

Brian,

Thank you for providing this information. I’ll let you know if we have any additional questions for your company.

Thanks again,

Kimberly

-------------------------------------- Kimberly D. Bartell

Environmental Engineer

Eastern Research Group, Inc.

kimberly.bartell@erg.com

Phone: 517

- 515

- 1721

From: Brian Lasko

To: Kimberly Bartell

CC: Eric Williams, Robert Casselberry, Monica Gesk

Date: 06/16/15 8:49 AM

Subject: RE: 2013 DMR Clarification for P CB Discharges

Kimberly,

I have attached the TRI information and permits you requested. If you have any questions, please let me know.

Thanks,

Brian

Effective 3/8/2006

- 5/31/2015:

Effective 6/1/2015

- no changes to fluoride limits

********** ************************

Brian Lasko

Environmental Control

United States Steel Corporation

(412) 433

- 5917

- Office

(412) 298

- 5195

- Cell

bslasko@uss.com

From: Kimberly Bartell

To: Monica R Gesk ( MRGesk@uss.com ), Brian Lasko

CC: Eric Williams, Robert Casselberry, Dave Buschmann

Date: 06/01/15 4:31 PM

Subject: RE: 2013 DMR Clarification for PCB Discharges

Mr. Lasko/Ms. Gesk:

We greatly appreciate all your help with the questions I have asked for the Fairless Hills and Clairton facilities. As I was finishing the

review of the Iron and Steel Category for EPA’s 2015 Annual Review, I realized that I forgot to ask you questions abo ut two other US

Steel facilities. These facilities came up in our review of DMR and TRI data and I would like to confirm the data below.

1. US Steel Granite City Works, Granite City, IL (NPDES ID: IL0000329, TRI ID: 62040GRNTC20THS)Need to return call by / at/between and

. Signature:

a. Please confirm the TRI pounds of lead and lead compounds released in 2013: 923 pounds. Additionally, please

explain how the load is calculated.

b. Please provide the NPDES permit for this facility that covers the time period of Jan 2013

– Dec 2013. We are

specifically looking at f

luoride discharges for outfall 001. If there have been updates to the permit since 2013,

specifically to fluoride limitations, please send the revised permit as well.

2. US Steel Corp, Great Lakes Works, Ecorse, MI (TRI ID: 48229GRTLKNO1QU)

a. Please confirm t he TRI pounds of lead and lead compounds released in 2013: 753 pounds (744 pounds direct

discharge, 9 pounds indirect discharge). Additionally, please explain how the loads are calculated (both direct and

indirect).

Again, thank you for your help in answ ering our questions. Please give me a call if it would be easier to talk through this on the phone:

517

- 515

- 1721.

Kimberly

-------------------------------------- Kimberly D. Bartell

Environmental Engineer

Eastern Research Group, Inc.

kimberly.bartell@erg.com

Phone: 517

- 515

- 1721

From: Kimberly Bartell

To: Monica R Gesk (MRGesk@uss.com)

CC: Eric Williams, Robert Casselberry, Brian Lasko , Dave Buschmann

Date: 05/27/15 4:22 PM

Subj ect: RE: 2013 DMR Clarification for PCB Discharges

Ms. Gesk,

Thank you for providing this information and for talking with me this morning. I will further review the data and let you kno w if we

have any additional questions.

Thanks again,

Kimberly

--- ----------------------------------- Kimberly D. Bartell

Environmental Engineer

Eastern Research Group, Inc.

kimberly.bartell@erg.com

Phone: 517

- 515

- 1721

From: Monica R Gesk (MRGesk@uss.com)

To: Kimberly Bartell

CC: Eric Williams, Robert Casselberry, Brian Lasko, Dave Buschmann

Date: 05/27/15 10:50 AM

Subject: RE: 2013 DMR Clarification for PCB Discharges

Kimberly,

As discussed, the cyanide permit limits for outfall 183 at U. S. Steel's Clairto n Plant were revised in 2012 and again in the 2015

permit.

The 2012 permit is attached here. Please let me know if you need anything else or have any other questions.

Thanks,

MonicaNeed to return call by / at/between and

. Signature: Monica Gesk, EIT

Environmental Control

United States Steel Corpo ration

412

- 433

- 6365: Office

412

- 298

- 1041: Cellular

mrgesk@uss.com

From: Kimberly Bartell

To: Brian Lasko ( BSLasko@uss.com )

CC: Eric Williams, Robert Casselberry, Monica Gesk, Dave Buschmann

Date: 05/21/15 8:45 AM

Subject: RE: 2013 DMR Clarification for PCB Discharges

Mr. Lasko,

Thank you for providing additional information on the Fairless Hills Facility, it is helpful to understand the background of the facility

for ou r review.

Also, thank you for sending the permit and fact sheet for the Clairton facility. I noticed that the permit you sent became ef fective in

2015. Can you confirm that the cyanide permit limits for outfall 183 remained the same from the previous per mit?

Thank you,

Kimberly

-------------------------------------- Kimberly D. Bartell

Environmental Engineer

Eastern Research Group, Inc.

kimberly.bartell@erg.com

Phone: 517

- 515

- 1721

From: Brian Lasko (BSLasko@uss.com)

To: Kimberly Bartell

CC: Eric Williams, Robert Casselberry, Monica Gesk, Dave Buschmann

Date: 05/20/15 10:36 AM

Subject: RE: 2013 DMR Clarification for PCB Discharges

Kimberly,

The monitoring requirements for PCBs at the Fairles s Hills Facility were the same in the previous permit with the following

exceptions:

- Sample Type for Outfalls 002, 103 & 203 were Grabs

- Outfall 203 sample frequency was 2/year

As far as the source of PCBs, construction of the Fairless works began a round 1950 and production from what was then a fully

integrated steel mill began on December 11, 1952. The Facilities included two blast furnaces, nine open hearth furnaces, two coke

batteries, an 80

- inch hot strip mill, rolling mills, a sheet and tin depa rtment, hot dip galvanizing line, a pipe mill and a deep water

vessel slip, all located on nearly 4,000 acres along the Delaware River. At the time of construction and operation of the Fairless

facility PCBs were common in electrical equipment and were pr esent in electrical equipment at the facility.

On August 8, 1991, the company closed the hot side of the plant (iron making, steel making, coke making, and hot rolling) and the

pipe mill and began to systematically demolish the hot end operations starting with the coke plant, blast furnaces, and open hearth

furnaces. Concurrently U. S. Steel Realty Development was charged with redeveloping some 3,000 acres of property that was vacated

from the shutdown operations. The remaining cold finishing operations, excluding the hot dip galvanizing line, were permanently

idled soon after the import crisis of 1998.

Dismantling of the Fairless works finishing operations continued through 2014. Several buildings still remain in the sheet and tin area

and the site has been substantially redeveloped. The source or sources of PCBs detected in discharges from the Fairless Works are not

known but are not associated with the remaining galvanizing line operation. There is no knowledge of any major historical PCB

release du ring the operational history of the facility that could point to a specific source. The low level detection PCB track down

sampling program that has been conducted as part of the Delaware River Basin Commission PCB TMDL has narrowed the location ofNeed to return call by / at/between and

. Signature: the po tential sources down to the lower segment of the central canal which ends in NPDES outfall 002. As part of the PCB trackdown

sampling program USS will be investigating this segment of the canal using the low level PCB method in the second half of 201 5.

[Paragraph redacted per facility request]

I have also attached the Clairton NPDES permit and Fact Sheet as requested.

If you have any additional questions, please let me know.

Thanks,

Brian

**********************************

Brian Lasko

Environment al Control

United States Steel Corporation

(412) 433

- 5917

- Office

(412) 298

- 5195

- Cell

bslasko@uss.com

From: Kimberly Bartell

To: Brian Lasko (BSLasko@uss.com)

Date: 05/15/15 2:25 PM

Subject: RE: 2013 DMR Clarifica tion for PCB Discharges

Mr. Lasko:

I emailed with you back in December about PCB discharges at the Fairless Hills facility. We completed our initial review of t he DMR

data for the 2015 Annual Review Report and are currently working on writing the report. Upon further reviewing the PCB discharges

at the Fairless Hills facility I had a few follow up questions, listed below.

1) You provided the 2014 permit for the Fairless Hills facility, which has monitoring only requirements for PCBs for outfalls

002, 103, a nd 203. Did the previous permit for this facility have the same monitoring requirements for PCBs for these

outfalls? We are looking at 2013 data so I would like to make sure the permit requirements were the same prior to the 2014

permit.

2) What is the source of the PCBs in the wastewater at the Fairless Hills facility?

Additionally, are you able to send me the NPDES permit and fact sheet for the Clairton Plant (PA0004472)? This facility also came up

in our review for cyanide discharges and it would be helpful to see the permit limits at the facility.

Please let me know if you would like to discuss this over the phone, my number is (517) 515

- 1721.

Thank you for your time.

Kimberly

-------------------------------------- Kimberly D. Bartell

Environmen tal Engineer

Eastern Research Group, Inc.

kimberly.bartell@erg.com

Phone: 517

- 515

- 1721Project No.: 

### 0317.0 2 .005.510 Page 1 of 3

Project Name: 

### DMR20 1 3 

## CBI?

Yes

No TELEPHONE CALL RECOR D

Incoming

Outgoing Date: 

### 12/1 8 /1 4 Time: 

### 11:50 am

pm

Company Name: 

### U.S. Steel ERG Staff Name: 

### Kimberly Bartell

Contact Name: 

### David Buschmann Contact Phone Number: 

### ( 215) 736

- 4063

General Subject: 

### 20 1 3 DMR PCB Discharges



## TOPICS DISCUSSED AND ACTION TAKEN

On December 18, 2014, I called David Buschmann and left a message. He returned my call and stated that their

facility is on the upper estuary of the Delaware River. The Delaware River Basin Commission established a

TMDL for the river and the measurement methods for the TMDL were adopted onto the permit for US Steel.

The facility uses Method 1668 to measure PCBs and they are reporting the raw analytical sum. I gave Mr.

Bu schmann the DMR values we had for PCBs for the three outfalls. He stated that the flows sounded correct

but he would check on the PCB concentrations and get back to me. I followed up with an email, please see

attached email correspondence.

Attachments to Email from Brian Lasko:

 PA0013463 FACTSHEET Final.doc

 2014 Fairless NPDES Permit PA0013463.pdf

### Email Communication with US Steel:

To: Brian Lasko

From: Kimberly Bartell

CC: Dave I Buschmann, Eric Williams, Robert Cassellberry

Date: Tuesday 12/23/14 12:36 PM

Subject: Re: [External]

- 2013 DMR Clarification for PCB Discharges

Mr. Lasko,

Thank you very much for getting back to me. I will review the information you provided and let you know if we have any

further questions.

Thanks,

Kimberly

----------------------------- Kimberly D. Bartell

Environmental Engineer

Eastern Research Group, Inc.

kimberly.bartell@erg.com

Phone: 517

- 515

- 1721

To: Kimberly Bartell

From: Brian Lasko (BSLasko@uss.com )

CC: Dave I Buschman, Eric Williams, Robert Casselberry

Date: Tuesday 12/23/14 10:36 AM

Subject: Fw: [External]

- 2013 DMR Clarification for PCB Discharges

Kimberly,

I am in the U. S. Steel

- Corporate Environmental Control Department and was forwarded th is request by David

Buschmann. I can be your contact should you need any additional information.

I am confirming the discharge monitoring report data you provided is accurate. On December 15, 2003, the USEPA,

Regions 2 and 3, adopted a Total Maximum D aily Load (TMDL) for PCBs for Zones 2, 3, 4, and 5 of the tidal Delaware

River. U. S. Steel is required to perform PCB analysis using EPA Method 1668A as per EPA and the Delaware River

Basin Commission (DRBC) rules. I have attached the current U. S. Stee l Fairless Hills Facility NPDES permit and Fact

Sheet as requested.

If you have any further questions, feel free to contact me.

Thanks,

Brian Lasko

To: dibuschmann@uss.com

From: Kimberly Bartell

CC: William Swietlik, Kim Wagoner

Date: Thursday 12/18/14, 1:49 PM

Subject: 2013 DMR Clarification for PCB Discharges

Dear Mr. Buschmann,

### Thank you for your time on the phone today. Eastern Research Group, Inc. (ERG) under EPA Contract No. EP

- C

- 12

- 021,

is e

- mailing you on EPA's behalf to request clari fication of 2013 discharge monitoring reports for US Steel Fairless Hills

(PA0013463). Please see further background information below.

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 wat ers

of the U.S. fr om 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 i s evaluating the data in discharge monitoring reports from 2013 and needs further information to

complete the review.

As discussed on the phone, we would like to obtain additional information on the following 2013 discharge data for US

Steel Fairless Hi lls. Our records show the following values were discharged:

Outfall Date PCB

Concentration

(mg/L) Flow

(MGD)

002 12/31/2013 0.00032 2.23

103 12/31/2013 0.000003 1.68

203 12/31/2013 0.000008 0.16

We appreciate your help in confirming if the above data are accurate, or if there are units errors in the DMR data. Please

also send a copy of the facility’s current NPDES permit and fact sheet.

Please call me at (517) 515

- 1721 if you have any questions. 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 ema il: swietlik.william@epa.gov

.

Thank you,

Kimberly

----------------------------- Kimberly D. Bartell

Environmental Engineer

Eastern Research Group, Inc.

kimb erly.bartell@erg.com

Phone: 517

- 515

- 1721

### TRI Inquiry

– 2013 RY for GLW and GCW

June 2015

GCW

- The lead and lead compounds calculation for t he 2013 RY SARA 313 report at GC W uses

the analytical and flow rates from the Discharge Monitoring Reports (DMR ). Lead samples were

only required for March, May and December so an average was used for th e remaining months.

The calculation is as follows:

Outfall 001

-

The quantity released for the year is the summation of each month’s releases, which are calculated as follows:

Pb/Pb Compounds (lbs/ month ) = (Flow * 1,000,000 gal/mgal * days/month * Concen tration mg/l * 3.785 l/gal) /

(454 g/lb * 1,000 mg/g)

For 2013 (January

– December values listed in order)

–

923 lbs/year = 

### ( 78.327+70.747+164.3+75.8+78.327+63+78.327+78.327+75.8+78 .327+75.8+5.58 ) lb/month



### GLW

– The lead and lead compounds calculat ion for the 2013 RY SARA 313 report at GLW uses

the analytical and flow rates from the Discharge Monitoring Reports (DMR) and Periodic

Compliance Reports . The calculations for direct and indirect releases are as follows:

DIRECT:

Outfall 008

-

Pb/Pb Compo unds Released (lbs/year) = Annual Flow * 1,000,000* Density * Ave. Annual Concentration/1,000,000

743 lbs Pb released from Outfall 008 = 20,383 MM gals/year * 1,000,000* 8.345 lbs/gal * 0.00437 ppm /1,000,000

Outfall 018

–

Pb/Pb Compounds Released (lbs/yea r) = Annual Flow * 1,000,000* Density * Ave. Annual Concentration/1,000,000

1 lb Pb released from Outfall 018 = 507 MM gals/year * 1,000,000* 8.345 lbs/gal * 0.0003 ppm /1,000,000

INDIRECT:

POTW Discharge To Detroit Water and Sewage Department (DWSD)

-

Pb/ Pb Compounds Released (lbs/year) = Annual Flow * 1,000,000* Density *Concentration/1,000,000

40 lbs Pb sent to POTW = 130 MM gal/year * 1,000,000 *8.3 45 lbs/gal * 0.037 ppm / 1,000, 000



### Per our discussion, our records indicate that 40 lbs of Pb/Pb Compoun ds were released

indirectly in 2013 and not 9 lbs as your records indicate. Therefore, the total Pb/Pb compounds

for GLW in 2013 was 784 lbs.