Need to return call by / at/between and

. Signature: Project No.: 

### 0317.00.005.522 Page 1 of 1

Project Name: 

### TRI20 11 

## CBI?

Yes

No TELEPHONE CALL RECOR D Incoming Outgoing Date: 

### 01/0 8 /13 Time: 

### 3: 45 am

pm

Company Name: 

### Sasol North America ERG Staff Name: 

### Kimberly Bartell

Contact Name: 

### Steve Hookanson Contact Phone Number: 

### ( 337 ) 494

- 5072

General Subject: 

### 2011 TRI Dioxin Discharges



## TOPICS DISCUSSED AND ACTION TAKEN

On January 8 , 2013 at 3:30 pm, I called Sasol North America to speak with Steve Hookanson and left a message.

On January 17, 2013 I called Sasol North America to speak with Michael Hayes (previous contact from 2011

Annual Review )

- 337

- 494

- 5038 and left a message.

On January 18, Scott Shaw from Sasol North America returned my call and requested an email detailing our questions and data. His email is scott.shaw@us.sasol.com , phone

– 337

- 494

- 5058. Please see attached email

communication.

On February 1, I called Mr. Shaw and confirmed that he had received my email and asked if he had any questions about our inquiry. He stated that he wasn’t sure what the data would be used for and that they weren’t sure how to respond to our questions. I ex plained how the 304m review process works and EPA’s yearly review and reports following the clean water act. He stated that he now had a better understanding of what we needed and that he would get back to me next week.

On February 15, I called Mr. Shaw and asked if he had any further questions. He stated that he was working on getting us an answer and will be emailing me back in the next week or so.

Please see attached email communication.

### Sasol North America Email Communication

From: Kimberly Bartell

To: scott.shaw@us.sasol.com, Swietlik, William CC: Hookanson, Stephen (SH)

Date: 3/13/2013 8:05 AM Subject: RE: 2011 TRI Clarification for Dioxin Discharges

Scott,

Thank you for sending this information. I will review it and let you know if we have any further questions.

Thanks again, Kimberly

---------------------------------------- Kimberly D. Bartell Environmental Engineer Eastern Research Group, Inc. kimberly.bartell@erg.com

Phone: 517

- 515

- 1721

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

To: Shaw, Scott CC: Bartell, Kimberly, Hookanson, Stephen (SH)

Date: 3/13/2013 7:39 AM Subject: RE: Dioxin discharges at Sasol North American fac ility in Westlake, Louisiana

Scott:

Thank you.

Bill Swietlik

From: Shaw, Scott < scott.shaw@us.sasol.com > To: Swietlik, William CC: Bartell, Kimberly, Hookanson, Stephen (SH)

Date: 3/12/2013 4:17 PM Subject: RE: Dioxin discharges at Sasol North American facility in Westlake, Louisiana

Please accept our apology for the delay in getting these answers back to you. I have been waiting for my
manager to review this with appropriate channels within our company. The questions and answers are as

follows:

1. Please confirm the pounds of dioxin released in 2011: 0.00091 pounds (0.413 grams).

Answer : Sasol reported 0.4138 grams of dioxin released from our facility to the Calcasieu River in the CY2011 TRI Report. Converting 0.4138 grams into pounds gives the 0.00091 po unds that you mentioned.2. Please confirm the facility reported dioxin distribution in the attached spreadsheet.

Answer : Sasol confirms that the spreadsheet attached to your email is the dioxin distribution that we reported in the CY2011 TRI for releases to water.

3. If you used monitoring data to determine the dioxin distribution, where was the monitoring

conducted and how are non

- detect results included in the distribution? If available, please provide
a copy of the monitoring results.

Answer : Sasol has taken grab samples of our wastewater. The results of the monitoring are attached. Samples were taken at the main outfall 001, which flows into the Calcasieu River. Outfall 001 is the combination of the effluent from our Activated Sludge Unit and other streams

t hat are discharged directly (such as cooling tower blow

- down). Samples were also taken at our Activated Sludge Unit effluent (upstream of the outfall 001). I have also included the results of a sample analysis that was performed on solids (sludge) from our Activated Sludge Unit. Since all dioxin congeners were detected in the sludge sample, we have conservatively assumed half of

detection limits for all non

- detect congeners for the water release calculations.

4. If you don’t have monitoring data, please descri be how the distribution and pounds were reported

in CY2011.

Answer : Not applicable. See the answer to question 3.

Sasol North America Inc

2201 Old Spanish Trail

Westlake, La. 70669

www.sasolnorthamerica.com Scott Shaw
Environmental Specialist/SHERQ

- Env/LCCC

Sasol Olefins & Surfactants

Tel: +1 337 494 5058

Fax: +1 281 368 2618

Mobile: +1

E

- mail: Scott.shaw@us.sasol.com

Environmental awareness starts with each of us

– think before you print this page

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

To: scott.shaw@us.sasol.com CC: Bartell, Kimberly

Date: 3/11/2013 1:21 PM Subject: Dioxin discharges at Sasol North American facility in Westlake, Louisiana

Dear Mr. Shaw:On January 18, 2013, Kimberly Bartell of Eastern Research Group, Inc. (ERG) acting on behalf of the

U.S. EPA, contacted you via e

- mail requesting clarification on data and information pertaining to dioxin

and dioxin

- like compound discharges to waters of th e United States from the Sasol North American facility in Westlake, Louisiana, as reported by you in the 2011 Toxics Release Inventory (TRI). Please see a copy of this request and a table of the dioxin data in question in the two attachments.

As of March 11, 2013, we have not yet heard back from you.

ERG, operating as my contractor under EPA Contract No. EP

- C

- 12

- 021, is collecting this information as my authorized agent. EPA, and its agents, are authorized under Section 308 of the Clean Water Act (CWA) t o collect information related to the discharge of pollutants to waters of the U.S. and the NPDES permits issued for that purpose. Therefore, I request your cooperation and the submittal of the information requested to ERG, or directly to me, if you prefer, as soon as possible.

Please return the requested information to Kimberly Bartell of ERG via e

- mail at kimberly.bartell@erg.com , or to me directly.

If you have any questions regarding this request, you may contact Kimberly Bartell of ERG by phone at (517) 515

- 1721 or at the e

- mail address listed above.

If you would like to speak with me regarding this request, I am available at (202) 566

- 1129 or by e

- mail: swietlik.willam@epa.gov

.

Thank you for your cooperation.

William F. Swietlik US EPA, Office of Water Engineering and Analysis Division (4303T) 1200 Pennslyvania Ave., NW Washington, DC 20460

202

- 566

- 1129

From: Kimberly Bartell

To: scott.shaw@us.sasol.com CC: Sabol, Elizabeth; Swietlik, William; Wagoner, Kim

Date: 1/18 /2013 3:00 PM Subject: 2011 TRI Clarification for Dioxin Discharges

Dear Mr. Shaw,

Thank you for returning my phone cal l. As discussed, EPA is requesting clarification of 2011 TRI data as part of our 2013 annual review of industrial discharges under Section 304 of the Clean Water Act. I am writing to request clarification for the Sasol North America, Inc. dioxin discharges on behalf of EPA

under Contract No. EP

- C

- 12

- 021. Please see below for further background.

EPA, Office of Water (OW), reviews TRI data to fulfill its review obligation under Section 304(b) of the Clean Water Act. The CWA requires EPA to annually review an d, 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 facili ties. EPA is currently conducting its 2013 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 informat ion). EPA will discuss this review and the results in its 2013 Effluent Guidelines

Program Plan scheduled for publication in the Federal Register sometime in 2013 or 2014.

As part of the 2013 annual review, EPA is evaluating the data reported to the 2011 TRI and needs further information to complete the review. Specifically, we would like to clarify the amount of dioxin compounds reported to the 2011 TRI. Please confirm/review the following data and questions below.

1. Please confirm the pounds of dioxi n released in 2011: 0.00091 pounds (0.413 grams) 2. Please confirm the facility reported dioxin distribution in the attached spreadsheet. 3. If you used monitoring data to determine the dioxin distribution, where was the monitoring conducted

and how are no n

- detect results included in the distribution? If available, please provide a copy of the monitoring results. 4. If you don't have monitoring data, please describe how the distribution and pounds were reported in

2011.

We appreciate your help in interpr eting 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 Anal ysis 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