Need to return call by / at/between and

. Signature: Project No.: 

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

Project Name: 

### DMR20 1 3 

## CBI?

Yes

No TELEPHONE CALL RECOR D

Incoming

Outgoing Date: 

### 5/1 3 /15 Time: 

### 1 :00 am

pm

Company Name: 

### King America Finishing ERG Staff Name: 

### Kimberly Bartell

Contact Name: 

### Matthew Hutcheson Contact Phone Number: 

### ( 912) 863

- 4511 ext 2052

General Subject: 

### 2013 DMR Sulfide Discharges for King America Finishing (GA0003280)



## TOPICS DISCUSSED AND ACTION TAKEN

General facility number: 912

- 863

- 4511

Matthew Hutcheson: 912

- 863

- 2052

On May 13, I called the general facility number and was transferred to Jamie Calloway and left a message.

On May 15, I called the general facility number and was transferred to Jamie Calloway. He requested an email

with more information and that it be sent to Matt Hutcheson ( matt hew .hutcheson@milliken.com ). See attached

email correspondence.

Mr. Hutcheson called me on May 15 th 

### before responding to my email. He stated that the facility reports

discharges in lbs /day for sulfide. He converted his data to kg/day and it generally matches up with the data in

the DMR database (there are only slight differences due to rounding). He stated that the facility takes daily

samples of their wastewater (whenever they are disc harging) and uses the average of those samples to develop

the monthly average reported on the DMRs. Most days the sulfide discharges are ND but occasionally they have

a detection. Since the data is averaged the detections result in the monthly average disc harges. Mr. Hutcheson

does not believe they were doing daily sampling prior to 2011 but they have done so since then.Need to return call by / at/between and

. Signature: 

### Email Communication with King America Finishing

From: Matthew Hutcheson <Matthew.Hutcheson@milliken.com>

To: Kimberly Bartell

CC: Lee Slusher, Kasel Knight

Date: 07/13/15 4:55 PM

Subject: RE: 2013 DMR Clarification for Sulfide Discharges

Kim,

I apologize for the delayed response. I was on vacation and then we had a shutdown for July 4 th week, so it’s been a little busy. We

typically use the detection limit in our concentration calculations, although we understand from the Georgia regulations that we have

the option to use “0” if we chose. Let me know if you have any other questions.

Matthew Hutcheson

Environmental Specialist

Millike n & Company

– Longleaf

1351 Scarboro Hwy

Sylvania, GA 30467

T 912

- 863

- 4511

matthew.hutcheson@Milliken.com

From: Kimberly Bartell

To: Matthew Hutcheson <matthew.hutcheson@milliken.com>

Date: 06/24/15 5:30 PM

Subject: RE: 2013 DMR Clarification for Sulfide Discharges

Mr. Hutcheson,

I was reviewing the information that you sent last month on your DMR sulfide discharges and have one follow up question for y ou:

When you calculate the monthly average su lfide concentration, do you assume the non

- detect values are zero, at the detection limit, or

1⁄2 the detection limit?

Thank you!

Kim

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

Environmental Engineer

Eastern Research Group, Inc.

kimberly.bartell@erg.com

Phone: 517

- 515

- 1721

From: Matthew Hutcheson <Matthew.Hutcheson@milliken.com>

To: Kimberly Bartell

CC: William Swietlik, Lee Slusher, Kasel Knight

Date: 05/15/15 3:59 PM

Sub ject: RE: 2013 DMR Clarification for Sulfide Discharges

That’s correct. Most days during the referenced period, we had “ND1.00”, but there were days where sulfides were detected and

values were something other than “ND1.00”. So, in a given month, ND1.00 days and days were sulfides were above this limit were

found, then the average would be greater than ND1.00. For example, one month may be reported as ND1.04, where both “type” of

values were found throughout that month. I assume there are a number of f actors that could cause sulfides to be detected in the system

so I can’t speak directly as to what exactly could’ve caused above detection limit values.

Matthew Hutcheson

Environmental Specialist

Milliken & Company

– Longleaf

1351 Scarboro HwyNeed to return call by / at/between and

. Signature: Sylvania, GA 30467

T 912

- 863

- 4511

matthew.hutcheson@Milliken.com

From: Kimberly Bartell

To: Matthew Hutcheson <matthew.hutcheson@milliken.com>

CC: William Swietlik, Lee Slusher, Kasel Knight

Date: 05/15/15 3:42 PM

Subject: RE: 2013 DMR Clarification for Sulfide Discharges

Mr. Hutcheson,

Thank you for your response. To clarify, the discharges are not all non

- detect for each month. Wastewater samples are taken daily

when there is a discharge. Most of the day s are non

- detect but some days had sulfide discharges which impacted the monthly average

that was ultimately reported on the DMR. Is this correct? Do you have any thoughts as to what processes may cause the sulfide

discharges that resulted in the monthly a verages on the DMR since you do not typically have sulfide in the system?

Thank you,

Kim

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

Environmental Engineer

Eastern Research Group, Inc.

kimberly.bartell@erg.com

Phone: 517

- 515

- 1721

From: Matthew Hutcheson <Matthew.Hutcheson@milliken.com>

To: Kimberly Bartell

CC: William Swietlik, Lee Slusher, Kasel Knight

Date: 05/15/15 3:10 PM

Sub ject: RE: 2013 DMR Clarification for Sulfide Discharges

Kimberly,

In response to your recent inquiry, the below chart shows the values that I obtained from our DMR data. Most of the average flows in

your chart are the same as mine just extended to an ex tra decimal based on what we reported. I got a very small difference in the

Sulfide Quantity, which is probably just related to rounding differences in your system and our electronic database system. We do

report on our DMR the Average Flow in MGD. Howe ver, we do not report sulfides in kg/day. Sulfides are reported for a loading of

lbs/day and for a concentration at mg/L. It should be noted that all of the monthly average sulfide values for the referenced time

period (on our DMR) are “NDX.XX”, as we ty pically do not have sulfide in our system. If you have any questions please feel free to

contact me. Thanks.

Date Sulfide Quantity

(kg/day) Flow

(MGD)

1/31/2013 5.55 1.287

2/28/2013 5.99 1.388

3/31/2013 5.47 1.404

4/30/2013 5.71 1.409

5/31/2013 5.01 1.204

6/30/2013 5.61 1.481

7/31/2013 7.33 1.613

8/31/2013 6.51 1.720

9/30/2013 6.62 1.733

10/31/2013 6.14 1.574

11/30/2013 6.75 1.538

12/31/2013 5.33 1.355Need to return call by / at/between and

. Signature: Matthew Hutcheson

Environmental Specialist

Milliken & Company

– Longleaf

1351 Scarboro Hwy

Sylvania, GA 30467

T 912

- 863

- 4511

matthew.hutcheson@Milliken.com

From: Kimberly Bartell

To: Matthew Hutcheson <matthew.hutcheson@milliken.com>

CC: Wil liam Swietlik, Elizabeth Gentile

Date: 05 /15/15 11:51 AM

Subject: 2013 DMR Clarification for Sulfide Discharges

Dear Mr. Hutcheson,

I was given your contact information from Jamie Calloway. Eastern Research Group, Inc. (ERG) under EPA Contract No. EP

- C

- 12

- 021, is e

- mailing you on EPA's behalf to request clarification of 2013 discharge monitoring reports for King America Finishing, Inc.,

in Sylvania, GA (GA0003280). Please see background information below.

EPA reviews publicly

- available DMR data t o 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 2015 annual review of existing effluent guidelines and potential indus trial

guidelines which may ne ed 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 is evaluating the data in discharge monitoring reports from 2013 and needs furth er

information to complete the review.

We would like to obtain additional information o n the following 2013 discharge data for King America Finishing, Inc. Our records

show the following values were discharged:

Date Sulfide Quantity

(kg/day) Flow

(MGD)

1/31/2013 5.44 1.28

2/28/2013 5.89 1.38

3/31/2013 5.45 1.404

4/30/2013 5.89 1.409

5/31/2013 4.98 1.204

6/30/2013 5.6009 1.48

7/31/2013 7.44 1.61

8/31/2013 6.503 1.72

9/30/2013 6.59 1.73

10/31/2013 6.077 1.57

11/30/2013 6.84 1.59

12/31/2013 5.65 1.44

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

describe the source of the sulfide discharges.

Please call me at (517) 515

- 1721 if you have any questions. If you wo uld 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: swiet lik.william@epa.gov

.

Thank you,

KimberlyNeed to return call by / at/between and

. Signature: -------------------------------------- Kimberly D. Bartell

Environmental Engineer

Eastern Research Group, Inc.

kimberly.bartell@erg.com

Phone: 517

- 515

- 1721