Project No.: 0317.01.005.510 Page 1 of 7

Project Name: DMR20 11 

### CBI?

Yes

No TELEPHONE CALL RECOR D

Incoming

Outgoing Date: 1/ 23 /1 4 Time: 2 :02 am

pm

Company Name: Republic Conduit ERG Staff Name: Meghan Camp

Contact Name: Bruce D. Gaylord Contact Phone Number: (502) 995

- 5941

General Subject: 20 11 DMR Discharges



### TOPICS DISCUSSED AND ACTION TAKEN

Please see attached email correspondence for information on the facility.>>> Meghan Camp 6/12/2013 3:12 PM >>>

>>> "Johnston, Carey" <Johnston.Carey@epa.gov> 5/23/2013 11:25 AM >>>

Carey A. Johnston, P.E.

U.S. EPA, Office of Compliance

ph: 202

- 566

- 1014

johnston.carey@epa.gov

From: Johnston, Carey

Sent: Thursday, May 23, 2013 11:24 AM

To: 'GAYLORD Bruce'

Cc: 'PUB:Edwards, Cheryl (EEC)'; Velez, Ezequiel

Subject: RE: Data Quality Questions Regarding your 2010 and 2011 TRI Reports

Hello Bruc e

–

Thank you for reporting this error to KY and to EPA. I can see that KYDEP has corrected your flow data in EPA’s

source database (ICIS

- NPDES).

http://www.epa

- echo.gov/cgi

bin/effluent1.cgi?permit=KY0105881&pipe=002¶mtr=50050&monlocn=1&period=1&outt=effonly&date=

20110101%7C20111231&charts=all&tool=echo

You are correct in that these error corrections are not in the database supporting the Loading Tool (see

below).EPA makes every possible effort to present quality data to the public and identifies limitations to data users.

The database supporting the DMR Pollutant L oading Tool ( www.epa.gov/pollutantdischarges ) uses annual

data extracts from ICIS

- NPDES with monthly error correction updates from EPA’s Integrated Error Correction

Process (IECP). The IECP is currently the main way that EPA uses to update the database supporting the

Loading Tool. States can also fix errors by updating ICIS

- NPDES without having to complete an IECP form. This

looks like this was the case for your facility. I will take these error correcti ons and update the database

supporting the Loading Tool. Additionally, over the next several months I am also updating the connection

between the Loading Tool database and ICIS

- NPDES so that these issues are resolved automatically with more

frequent data r efreshes.

Thank you again for alerting me to this error.

Sincerely,

Carey A. Johnston, P.E.

U.S. EPA, Office of Compliance

ph: 202

- 566

- 1014

johnston.carey@epa.gov

From: GAYLORD Bruce [ mailto:bgaylord@tenaris.com ]

Sent: Thursday, May 23, 2013 7:10 AM

To: Velez, Ezequiel; Johnston, Carey

Cc: 'PUB:Edwards, Cheryl (EEC)'

Subject: RE: Data Quality Questions Regarding your 2010 and 2011 TRI Reports

An explanation of the weird and excessively large numbers calculated from the DMR’s. My plant underwent an internal

audit in 2012. One of the findings was: I was calculating (reporting) the quantity of stormwater per month incorrectly. I

had believed that M Gallons was to report in thousand gallons. The values were to have been reported in million gallons.

I notified KY DNR July 5, 2012 of the discovery and requested advice as to how to correct the error.

Ms. Cheryl Edwards immediately informed me to sub mit corrected DMRs.

I made copies of the original submittals, performed a cross out and insertion of the correct data in red ink.There were three years of reports to correct, the corrections were sent to Kentucky DNR July 9 th

.

My guess is, Ms. Johnson, that you were using the old data (uncorrected), on stream flow. Basing the calculations of so

many mg/l, the values would be extremely large.

Meaning, if I had entered 1,000 thinking it was 1,000 units of a thousand gallons and you all look at the data and assume

that its 1,000 units of a million gallons, a large amount is assumed to have went into the stormwater flow.

Look over my explanation; you should have all of the corrections in the system. I copied Ms. Edwards because she

helped me th rough the process of self disclosure and correction of the DMR errors.

I hope this was of assistance to you and If there is anything else you need, please don’t hesitate to contact me.

bruce

Bruce D. Gaylord PG, QEP, CHMM Environmental Regional Coordinator

Republic Conduit TM 7301 Logistics Drive | Louisville, KY 40258

P 502

- 995

- 5941 | M 502

- 758

- 2382

bgaylord@tenaris.com | www.republicconduit.com

EMT | GRC | IMC | Aluminum | Inch

- Marked® | Guide

- Lined® | Silverslick® | Diamond Knurl

From: PUB:Velez, Ezequiel [ mailto:Velez.Ezequiel@epa.gov ]

Sent: Wednesday, May 22, 2013 3:31 PM

To: GAYLORD Bruce

Subject: RE: Data Quality Questions Regarding your 2010 and 2011 TRI Reports

Mr. Gaylord,

Below in RED is a short clarification I received from Carey A. Johnston, U.S . EPA, Office of Compliance........



## Ezequiel Velez

TRI Coordinator

US EPA Region 4

Air Toxics & Monitoring Branch

Air Toxics Assessment & Implementation Section

61 Forsyth, St. S.W.

Atlanta, GA 30303

Tel. (404) 562

- 9191

velez.ezequiel@epa.gov

www.epa.gov/tri

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

EPA’s Clean Water Act (CWA) regulations require reporting of samples and measurements taken for the

purpose of compliance monitoring at intervals specified in the National Pollutant Discharge Elimination System

(NPDES) permit [40 CFR 122.41(j) and (l)(4)]. When self

- monitoring results are reported to the permitting

authority, t hey are compared with current permit limits and any existing enforcement orders to determine

facility compliance. The sample collection and analytical results required by the NPDES permit must be

reported to the permitting authority through the submission of Discharge Monitoring Reports (DMRs) [40 CFR122.41(l)(4)(i)]. It is extremely important that the data reported on the DMR is timely, accurate, complete, and

legible to ensure that the facility’s compliance status is correctly reflected.

Carey A. Johnst on, P.E.

U.S. EPA, Office of Compliance

ph: 202

- 566

- 1014

johnston.carey@epa.gov

From: GAYLORD Bruce [ mailto:bgaylord@tenaris.com ]

Sent: Wednesday, May 22, 2013 1:49 PM

To: Velez, Ezequiel

Subject: RE: Data Quality Questions Regarding your 2010 and 2011 TRI Reports

Upon Re

- reading your e

- mail

I may be a little (or a lot) confused.

When you are talking about DMR’s, are you referring to the stormwater monitoring reports?

Or are you referring to the reports, I submit to the metropolitan sewer district, that they, I would imagine, have to report

onto EPA?

bruce

Bruce D. Gaylord PG, Q EP, CHMM Environmental Regional Coordinator

Republic Conduit TM 7301 Logistics Drive | Louisville, KY 40258

P 502

- 995

- 5941 | M 502

- 758

- 2382

bgaylord@tenaris.com | www.republicconduit.com

EMT | GRC | IMC | Aluminum | Inch

- Marked® | Guide

- Lined® | Silverslick® | Diamond Knurl

From: PUB:Velez, Ezequiel [ mailto:Velez.Ezequiel@epa.gov ]

Sent: Wednesday, May 22, 2013 12:19 PM

To: GAYLORD Bruce

Cc: Velez, Ezequiel; Chatham, Douglas

Subject: Data Quality Questions Regarding your 2010 and 2011 TRI Reports

US EPA Regio n 4

61 Forsyth Street, S.W., Atlanta, GA 30303

Toxic Release Inventory (TRI) Data Quality Initiative

BRUCE GAYLORD (or Current Environmental Manager)

REPUBLIC CONDUIT MANUFACTURING

7301 LOGISTICS DR



### LOUISVILLE, KY

TRI Facility ID: 40258RPBLC731LG

Data Quality Questions to Facilities Regarding 2010 TRI National Analysis (TNA)Dear TRI reporting Facility:

It appears that you may have made an error in the Form R report you submitted for the 

### 2010

reporting year. EPA would like to provide you an opportuni ty to double

- check your submissions. Your

facility has been identified because:



### Your facility has reported 85,987 pounds of discharges of CHROMIUM

and/or CHROMIUM COMPOUNDS according to discharge monitoring

reports (DMR), but has reported zero (0) pounds of CHROMIUM and/or

CHROMIUM COMPOUNDS released to water in TRI for RY2011.

Your facility has reported 61,544 pounds discharges of ZINC and/or ZINC

COMPOUNDS according to discharge monitoring reports (DMR) but

has reported only 16 pounds for ZINC and/or ZINC COMPOUNDS released

to water in TRI for RY2010.

Your facility has reported 104,439 pounds discharges of ZINC and/or ZINC

COMPOUNDS according to discharge monitoring reports (DMR) but

has reported only 51 pounds for ZINC and/or ZINC COMPOUNDS released

to water in TRI for RY2011.

How to respond to this inquiry?

Please check one of the following, explain ‘Reason(s) for Change(s)’ if needed, and reply to me by return

email:

( ) New Submission ( ) Revision ( ) Withdrawal

( ) No Change ( ) Other (please explain)

_____________________________________________________

Reason(s) for Change(s):

_____________________________________________________________________________

_____________________________________________________________________________

If you have any revisions, withdrawals or new submissions, you will need to get this information to

EPA preferably by 5:00 p.m. EST, Friday, May 31, 2013

.

Please make sure to report or revise your RY2010, RY2011 report(s) and enter correct information on your

RY2012 report(s) as well.

EPA recommends that you respond as follows:



### Steps to follow for submitting a revision, withdrawal or new submission:

1a. The use of the TRI Made

- Easy web (TRI

- ME web), a web

- based version of TRI

- ME software and

submitting responses through the Internet via the Central Data Exchange (CDX) is highly

recommended.

Or

1b. Although we strongly discourage the use of paper submissions, you may make corrections by using your

electronic Facility Data Profile (eFDP). An eFDP presents the information you have submitted to EPA

that has be en entered into the TRI database. If you are using your eFDP to make corrections, you mustsubmit the full Form R (and Form R Schedule 1, if reporting dioxin), along with a signed certification

statement on page 3 of the eFDP. If you do not have a copy o f your eFDP, please go to your TRI

MEweb facility account via the CDX login web page and print a copy of the eFDP report for the TRI

chemical reported by your facility. Mail the signed eFDP report and the correction of the Form R to

EPA’s Data Processing Center. If you have questions about how to respond by using your eFDP, please

refer to page 3 of the eFDP. Send a second copy of your signed eFDP report, corrected Form R and

Form R Schedule 1 to your State TRI Contact.

Overnight Deliveries: P.O. Box for Regular Mail:

CGI Federal Inc. TRI Data Processing Center

c/o EPA Reporting Center P.O. Box 10163

12601 Fair Lakes Circle Fairfax, VA 22038

Fairfax, VA 22033

Phone: 703

- 227

- 7644

If you have any follow up questions, please email me at velez.ezequiel@epa.gov or call me at 404

- 562

- 9191.

Thank you for your prompt attention to this matter.



## Ezequiel Velez

TRI Coordinator

US EPA Region 4

Air Toxics & Monitoring Branch

Air Toxics Assessment & Implementation Section

61 Forsyth, St. S.W.

Atlanta, GA 30303

Tel. (404) 562

- 9191

velez.ezequiel@epa.gov

www.epa.gov/tri