Need to return call by / at/between and

. Signature: Project No.: 0 317.0 2 .005.510 Page 1 of 3

Project Name: DMR20 1 3 

### CBI?

Yes

No TELEPHONE CALL RECOR D

Incoming

Outgoing Date: 12/2 3 /1 4 Time: 2 :3 0 am

pm

Company Name: Sasol North America ERG Staff Name: Kimberly Bartell

Contact Name: Scott Shaw Contact Phone Number: ( 337)

- 494

- 5058

General Subject: 2013 TRI Dioxin Discharges for Sasol



### TOPICS DISCUSSED AND ACTION TAKEN

Scott Shaw: 337

- 494

- 5058, scott.shaw@us.sasol.com

I called Mr. Shaw on December 23 rd and left a message.

I called Mr. Shaw on December 30 th and left a message.

On January 5 th 2015 at 9:30AM, Mr. Shaw returned my call. He requested further information via email so he

could review the information and send us a response. Please see attached email communication.

I contacted Mr. Shaw again in May 2015, see email co mmunication below.Need to return call by / at/between and

. Signature: Email Communication with Sasol North America:

From: scott.shaw@us.sasol.com

To: Kimberly Bartell

Date: 1/12/15 3:21 PM

Subject: RE: 2013 TRI Clarification for Dioxin Discharges

Sorry for the delay. I was not able to get into the TRI

- ME Web program on Friday. See my answers to your questions

below:

1. Q: Please confirm the pounds of dioxin released in 2013: 0.0011 pounds (0.485 grams) ). A: For CY2013, Sasol

reported 0.4846 g dioxin to Calcasieu River, 0.0000587 g to Bayou Verdine (both to water).

2. Q: Please confirm the facility reported dioxin distribution in the attached spreadsheet. A: The data in your

attached spreadsheet looks correct.

3. Q: Has the method of determining the dioxin distribution, including where monitoring was con ducted and how

non

- detect results are handled, changed since 2011? If available, please provide a copy of the monitoring results

from 2013. A: No, the method of determining the dioxin distribution and monitoring for water has not changed

since 2011. Ther e is some small variation from year to year due to rounding.

North American Operations

2201 Old Spanish Trail

Westlake, La. 70669

www.sasolnorthamerica.com Scott Shaw

Environmental Specialist

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: Kimberly Bartell

To: scott.shaw@us.sasol.com

CC: William Swietlik, Kim Wagoner

Date: 1/6/15 1:54 PM

Subject: 2013 TRI Clarification for Dioxin Discharges

Dear Mr. Shaw:

Thank you for your time on the phone yesterday. As discussed, Eastern Research Group, Inc. (ERG) under EPA Contract

No. EP

- C

- 12

- 021, is e

- mailing you to request clarification for the Sasol North America, Inc. dioxin discharges. See below

for background on what the information is used for.

EPA reviews publicly

- available discharge monitoring report (DMR) and to xic 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 gu idelines," 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 includedNeed to return call by / at/between and

. Signature: (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 dioxin compounds reported to the 2013 TRI.

Please confirm/review the following data and questions below.

4. Please confirm the pounds of dioxin released in 2013: 0.0011 pounds (0.485 grams)

5. Please confirm the facility reported dioxin distribution in the attached spreadsheet.

6. Has the method of determining the dioxin distribution, including where monitoring was conducted and ho w non

detect results are handled, changed since 2011? If available, please provide a copy of the monitoring results from

2013.

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

Phon e: 517

- 515

- 1721Need to return call by / at/between and

. Signature: Project No.: 0 317.0 2 .005.52 0 Page 1 of 4

Project

Name: 2015 Annual Review

– Preliminary

Category Review OCPSF (PSC 414 ) CBI?

Yes

No TELEPHONE CALL RECOR D

Incoming

Outgoing Date: 05 / 0 8 / 20 15 Time: 11:00 am

pm

Company

Name: Sasol NA Inc. Lake Charles Chemical

Complex ERG Staff Name: Kimberly Bartell

Contact

Name: Scott Shaw, Environmental Specialist

Michael Hayes , Public TRI Contact Contact Phone

Number: 337

- 494

- 5058

scott.shaw@us.sasol.com

337

- 494

- 5038

michael.hayes@us.sasol.com

General

Subject: 2013 TRI PACs Releases from Sasol NA Inc. Lake Charles Chemical Complex

, Westlake, LA

TRI ID: 70669VSTCHOLDSP

TOPICS DISCUSSED AND ACTION TAKEN

From: Shaw, Scott (SA) [ mailto:Scott.Shaw@us.sasol.com ]

Sent: Thursday, May 21, 2015 4:33 PM

To: Kimberly Bartell

Subject: RE: 2013 TRI Clarification for PAC Discharges

Sorry for the delay getting back to you. I had already scheduled to be out of the office Monday through

Wednesday this week and I was not done looking into it on Friday. The answers to your question s are provided

below (shown in red).

1. Please confirm the pounds of PACs released to surface waters in 2013: 123 lbs (23 lbs to Bayou Verdine

and 100 lbs to Calcasieu River) Yes that is correct. The main wastewater plant almost always

discharges directly t o the Calcasieu River although the permit allows it to be discharged through Bayou

Verdine as an alternate route if necessary.

2. Please explain how the PAC load is calculated. Samples of the effluent from our onsite wastewater

treatment unit as well as fro m actual storm water events are obtained and analyzed according to the

requirements of our LPDES water permit. The effluent water flow from the main wastewater treatment

plant is measured; the storm water flows are estimated based on actual rainfall data and estimated outfall

areas. We then use the analytical data and flows to estimate the emissions. When the analytical results

are below detection limit and we have evidence that the chemicals are onsite, we use half of detection

limit in our calculations

.

3. The total water releases have increased since 2010. What factor(s) have contributed to the overall

increase?

One reason for the increase is there was an increase in flow of water through our outfalls. We

discharged more gallons of water from our main wastewater treatment plant outfall in 2013 compared to

2010 (about 20% more volume in 2013). The amount of rainf all at our facility was also higher in 2013

(70 inches) compared to 43 inches in 2010.Need to return call by / at/between and

. Signature:

We also included an additional chemical in the PAC calculations for CY2013 for our main wastewater

treatment effluent that we had not in previous years. This is anot her PAC chemical that was reported by

the laboratory as below detection limits but is believed to be present onsite.

North American Operations

2201 Old Spanish Trail

Westlake, La. 70669

www.sasolnorthamerica.com Scott Shaw

Environmental Specialist

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: Kimberly Bartell [ mailto:Kimberly.Bartell@erg.com ]

Sent: Friday, May 15, 2015 9:59 AM

To: Shaw, Scott (SA)

Subject: RE: 2013 TRI Clarification for PAC Discharges

Mr. Shaw,

Thank you for confirming you received my request. We look forward to hearing from you.

Kim

From: Shaw, Scott (SA) [ mailto:Scott.Shaw@us.sasol.com ]

Sent: Friday, May 15, 2015 10:57 AM

To: Kimberly Bartell

Subject: RE: 2013 TRI Clarification for PAC Discharges

Yes, I received it and we are working on it.

North American Operations

2201 Old Spanish Trail

Westlake, La. 70669

www.sasolnorthamerica.com Scott Shaw

Environmental Specialist

Tel: +1 337

- 494

- 5058

Fax: +1 281

- 368

- 2618

Mobile: +1

E

- mail: scott.shaw@us.sasol.comNeed to return call by / at/between and

. Signature: Environmental awareness starts with each of us

– think before you print this page

From: Kimberly Bartell [ mailto:Kimberly.Bartell@erg.com ]

Sent: Friday, May 15, 2015 9:54 AM

To: Shaw, Scott (SA)

Cc: Eva Knoth

Subject: RE: 2013 TRI Clarification for PAC Discharges

Mr. Shaw:

I wanted to confirm that you received the email below last week. If possible, it would be helpful to have a

response from you by the end of the day Tuesday (5/19).

Thank you for your time,

Kim

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

Environmental Engineer

Eastern Research Group, Inc.

kimberly.bartell@erg.com

Phone: 517

- 515

- 1721

From: Kimberly Bartell

Sent: Friday, May 08, 2015 11:00 AM

To: Shaw, Scott (SA)

Cc: Eva Knoth; Swietlik.William@epa.gov

Subject: 2013 TRI Clarification for PAC Discharges

Mr. Shaw:

I contacted you in January about your facility’s dioxin discharges, please see the email chain below. We

appreciate your prior assistance and had a follow up question on polycyclic aromatic compounds (PACs)

discharges at your facility. We would like to clarify the amount of PACs reported by Sasol North America, Inc.

as released to surface wat ers to the 2013 TRI. We have the following questions:

1. Please confirm the pounds of PACs released to surface waters in 2013: 123 lbs (23 lbs to Bayou Verdine and

100 lbs to Calcasieu River)

2. Please explain how the PAC load is calculated.

3. The total water releases have increased since 2010. What factor(s) have contributed to the overall increase?

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.Need to return call by / at/between and

. Signature: Thank you,

Kim

‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ Kimberly D. Bartell

Environmental Engineer

Eastern Research Group, Inc.

kimberly.bartell@erg.com

Phone: 517

‐ 515

‐ 1721