## Need to return call by / at/between and . Signature: Project No.: 

# 0172.08.005.607 Page 1 of 2

Project Name: 

# 2011 Prelim Cat Rev 

# CBI?

Yes

No TELEPHONE CALL RECORD Incoming Outgoing Date: 

# 08/26/2011 Time: 

# 2:00 am

pm

Company Name: 

# FL DEP ERG Staff Name: 

# Elizabeth Sabol

Contact Name: 

# Jacquelyn Champion Contact Phone Number: 

# 813-632-7600 X133

General Subject: 

# 2009 DMR Fluoride Discharges



# TOPICS DISCUSSED AND ACTION TAKEN

I called Mr. Chupka on Wednesday, August 24, 2011 to disc uss fluoride discharges from phosphate mines in Florida. Mr. Chupka stated that I should e-mail th e FL DEP Phosphate Management Permit Manager and Program Administrator to request the data that I was looking for. Please see the following e-mail below:

From: Elizabeth Sabol

To: robert.vanderslice@dep.state.fl.us; vishwas.sathe@dep.state.fl.us

CC: Codding, Eleanor; swietlik.william@epa.gov

Date: 8/25/2011 2:11 PM Subject: Phosphate Mines FL - Fluoride Discharges

Mr. Sathe/Mr. Vanderslice,

My name is Elizabeth Sabol from Eastern Research Group, In c. under EPA under Contract No. 68-C-02-095, supporting EPA's 2011 In dustrial Category Annual Review process. I am writing to request clarification of DMR discharge data for three phosphate mines in Florida: Mosaic Fertilizer LLC Fort Green and Four Corners facilities and Cargill Fertilizers South Fort Meade facility. I've recently been in touch with Mr. Andre w Chupka regarding wastewater discharges (spe cifically fluoride) from three phosphate mines in Flor ida. He stated that my data request and questio ns would be more appropriate for you. Please find some background below.

EPA reviews DMR data to fulfill its review obligation under Section 304(b) of the Clean Water Act. The CWA requires EPA to annu ally review and, if appropriate, revise its water pollution control technology-based regulations, called “effluent limitations guidelines” or "effl uent guidelines,” that limit the discharge of pollutants to waters of the U.S. from various categories of industrial facilities. EPA is currently conducting it s 2011 annual review of existing effluent guidelines and potential industri al guidelines which may n eed to be included (see http://water.epa.gov/lawsr egs/lawsguidance/cwa/304m/ for further information). EPA will discuss this review and the results in its 2011 Effluent Guidelines Program Plan scheduled for pub lication in the Federal Register in 2011.

As part of the 2011 annual review, EPA is ev aluating the 2009 DMR data and needs furthe r information to complete the review. Sp ecifically, we would like to determine if we are appropriately estimating discharge flows from the three mines listed above (NPDES IDs: FL0027600, F L0036412, FL0037958). Currently we assume the facilities discharge wastewater for all months out of the year. Mr. Chupka indicated that t hese facilities only discharge during the winter months and that the facilities provide five years of daily discharge data as part of the permit ren ewal process. In order to come up with a better estimation of flow for our databases, we are requesting the most recent fl ow data available for these fac ilities.

Additionally, from the facility permits, we are aware that the fluoride permit limits are based on the Florida Water Quality St andard (10 mg/L). Have there been any studies or data that suggest fluoride discharges from the phosphate mines in Florida affect water quality, huma n health, or aquatic life? Are there any studies being done on treatment technologies that can further reduce fluoride discharges from these mines?

We appreciate your help in interpreting DMR data correctly. 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/Engi neering Analysis Division by phone at (202) 566-1129 or by ema il: swietlik.william@epa.gov.

Thank you,

Elizabeth Environmental Engineer Eastern Research Group, Inc. 14555 Avion Parkway, Suite 200 Chantilly, VA 20151 elizabeth.sabol@erg.com

Phone:703-633-1659

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

# On August 26, 2011, Jacquelyn Champion returned my call to discuss the information th at I requested in the email above. She stated that the fluori de permit limitations were set over te n years ago and that fluoride limits

will not be included in the most recen t tri annual review. She st ated that FL DEP will likely not review fluoride discharges because facilities usua lly are under the 10 mg/L permit limit by a significant amount (average concentrations are about 3 mg /L). Ms. Champion also stated that FL DE P is not investigating any new treatment options because they facilitie s are not exceeding limits.

Ms. Champion described the phosphate mines as massive la nd areas with outfalls that are mine and rainfall dependent. She stated that it would difficult to estimate the actual discharge area because the mine sites are constantly changing.