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Project No.: 0317.02.005.520 Page 1 of 4

Project Name: TRI2013 CBI?

Yes

No

TELEPHONE CALL RECORD

Incoming

Outgoing

Date: 5/21/15 Time: 10:21 am

pm

Company Name: AK Steel ERG Staff Name: Kimberly Bartell

Contact Name: Dave Miracle Contact Phone Number: (513) 425-5329

General Subject: 2013 TRI Nitrate Discharges for AK Steel

TOPICS DISCUSSED AND ACTION TAKEN

I emailed Barry Racey on 5/21/15 requesting information on two AK Steel facilities. Dave Miracle provided the 

information. See email correspondence below. 
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Email Communication with AK Steel

From: Kimberly Bartell

To: dave.miracle@aksteel.com

CC: William Swietlik

Date: 05/26/15 4:47 PM

Subject: RE: 2013 TRI Clarification for Nitrate Discharges

Mr. Miracle,

Thank you for the detailed explanation below. I will review the information you provided and let you know if we have any further 

questions. 

Thanks again,

Kim

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

Kimberly D. Bartell

Environmental Engineer

Eastern Research Group, Inc.

kimberly.bartell@erg.com

Phone: 517-515-1721

From: dave.miracle@aksteel.com

To: Kimberly Bartell

CC: William Swietlik

Date: 05/22/15 2:04 PM

Subject: FW: 2013 TRI Clarification for Nitrate Discharges

Ms. Bartell,

In response to your email on May 21, 2015, AK Steel has verified that the reported calendar year 2013 nitrate compounds discharges 

you listed for the Rockport Works and the Coshocton Works are correct. Below, please find an explanation of our methodology for 

determining the nitrate compounds discharges. Both plants calculate the nitrate compounds discharges in exactly the same manner.

On a weekly basis, a composite outfall sample is collected and analyzed for nitrate as nitrogen. The weekly concentrations are then

averaged for each month and multiplied by the average daily flow and the number of days in the month. That number is converted to 

pounds by multiplying by 3.78 (liters / gallon) and dividing by 454,000 (milligrams / pound). This is the number of pounds per month 

of nitrate as nitrogen discharged at the outfall . The final step of the calculation converts the pounds of nitrates as nitrogen to pounds 

of nitrate as nitrate compounds by multiplying the molecular weight ratio of nitrate compounds (NO3 = 62.01) to nitrogen (N =14.01) 

to determine the pounds of nitrate compounds discharged for the TRI reporting purposes. Without the molecular weight conversion 

step, our calculations would be approximately 4.43 times less than what is required to be reported. We then total the monthly 

calculated results of nitrate compounds in pounds to get the annual total.

Additionally, nitrate releases have historically been a sore spot in the public arena since they were added to the TRI list back in the 90s 

even though background nitrate loading in the receiving stream are often remarkably high. In Rockport for instance, ORSANCO data 

indicates that there are approximately 1.6 billion pounds of nitrites/nitrates annually flowing down the Ohio River upstream of the 

Rockport Works making the impact of AK Steel's discharge negligible by comparison. Furthermore, 2013 ORSANCO data also 

indicates that the nitrate/nitrite concentrations are higher upstream of our outfall than downstream which is further evidence of a 

negligible impact. We have historically had a very difficult time communicating to the general public that these discharges are nonissues due to the vast size of the associated receiving stream. I suspect this is largely due to how TRI data is reviewed and the various 

chemicals are not really "weighted" by risk. For example, many would assume that one pound of nitrate carries the same risk as one 

pound of mercury based on the way the data are often reported by ORSANCO or even U.S. EPA which is obviously not the case.

If you have any questions or would like to discuss this matter further, please do not hesitate to call me at (513) 425-5329.

Sincerely,

Dave
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David Miracle

AK Steel Corporation

General Manager - Environmental Affairs

Office: (513) 425-5329

From: William Swietlik

To: Dave.Miracle@aksteel.com

CC: Kimberly Bartell

Date: 05/22/15 12:04 PM

Subject: Re: 2013 TRI Clarification for Nitrate Discharges

Thank you for your request to verify my contractor's email sent to you (below). 

Yes, this is an official request for information from EPA, via Eastern Research Group, Inc. (ERG) -- my authorized contractor.

Kimberly Bartell of ERG is conducting this work on my behalf.

In addition, the collection of this information is authorized under the Clean Water Act (CWA) and is a part of our annual review of 

industrial wastewater discharges under section 304 of the CWA.

In sum, the nitrate releases to water reported to the Toxics Release Inventory (TRI), reported by the two facilities listed below are 

quite high, and are raising "red flags" in our review, so we are trying to confirm whether these are legitimate data points, or if there 

might be estimation or reporting errors involved.

Please let me know if you have any further questions or concerns.

Thank you for your cooperation,

Bill

__________________________________

William F. Swietlik

US EPA, Office of Water

Engineering and Analysis Division (4303T)

1200 Pennsylvania Ave., NW

Washington, DC 20460

202-566-1129: phone

202-566-1053: Fax

________________________________________

From: Dave.Miracle@aksteel.com [Dave.Miracle@aksteel.com]

Sent: Friday, May 22, 2015 11:40 AM

To: Swietlik, William

Subject: Fw: 2013 TRI Clarification for Nitrate Discharges

Mr. Swietlik,

Good morning. Please verify that the email below is a credible request from U.S. EPA's contractor. I assume so, but just wanted to 

make sure before we responded.

Thank you very much,

Dave

David Miracle

AK Steel Corporation

General Manager - Environmental Affairs

Office: (513) 425-5329
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----- Forwarded by Dave Miracle/AKSTEEL on 05/22/2015 11:36 AM -----

From: Barry Racey/AKSTEEL

To: Dave Miracle/AKSTEEL@AKSTEEL,

Cc: Renee Filiatraut/AKSTEEL@AKSTEEL

Date: 05/21/2015 11:14 AM

Subject: Fw: 2013 TRI Clarification for Nitrate Discharges

________________________________

Dave --

I believe this should have been sent to you, so forwarding to you for your response directly to EPA.

Thanks.

Barry

From: Kimberly Bartell

To: barry.racey@aksteel.com

CC: William Swietlik

Date: 05/21/15 10:21 AM

Subject: 2013 TRI Clarification for Nitrate Discharges

Mr. Racey:

Eastern Research Group, Inc. (ERG) under EPA Contract No. EP-C-12-021, is e-mailing you to request clarification for the AK Steel 

Corp nitrate compound discharges. See below for background on what the information is used for.

EPA reviews publicly-available discharge monitoring report (DMR) and toxic release inventory (TRI) 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 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 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 is evaluating the data reported to the 2013 TRI and needs further information to complete the 

review. Specifically, we would like to clarify the amount of nitrate compounds reported to the 2013 TRI for two AK Steel facilities. 

Please confirm/review the following data and questions below.

1. AK Steel Corp, Rockport Works, Rockport, IN (TRI ID: 47635KSTLC6500N)

a. Please confirm the pounds of nitrate compounds released in 2013: 15,887,487 pounds

b. Please explain how the nitrate compound load is calculated.

2. AK Steel Corp, Coshocton Works, Coshocton, OH (TRI ID: 43812CSHCTSTATE)

a. Please confirm the pounds of nitrate compounds released in 2013: 4,200,000 pounds

b. Please explain how the nitrate compound load is calculated.

We appreciate your help in interpreting 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 Analysis 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