Need to return call by / at/between and

. Signature: Project No.: 

### 0 317.00.005. 522 Page 1 of 2

Project Name: 

### DMR20 11 

## CBI?

Yes

No TELEPHONE CALL RECOR D Incoming Outgoing Date: 

### 0 2 /0 5 /13 Time: 

### 1:00 am

pm

Company Name: 

### Honeywell International ERG Staff Name: 

### Kimberly Bartell

Contact Name: 

### Brad Campesi Contact Phone Number: 

### ( 225 ) 346

- 36 61

General Subject: 

### 2011 DMR Concentration Values and Units



## TOPICS DISCUSSED AND ACTION TAKEN

On February 5, 2013 I called Chris Brescher , 225

- 346

- 3630 and left a message.

At 2:30pm on February 5, Brad Campesi (225

- 346

- 3661) returned my call and left a message. I returned his call and he stated that he would be happy to look into the past DMR data but that it would be easiest to see our request via email. He said that it is odd that the DMRs are showing PACs co mpounds as they don’t typically produce them. Email = brad.campesi@honeywell.com . Please see attached email correspondence.

At 4pm on February 26, I called Mr. Campesi to discuss his email on the hexachlorobenzene and benzo(a)pyrene discharges and left a message. I also returned his email, please see attached email correspondence.

At 4pm on March 12, I called Mr. Campesi and left a message explaining that I had a few f ollow up questions and requested that he return my call.

On March 14, I spoke with Mr. Campesi and explained that we want to know why there have been PACs discharges in 2010 and 2011 but not in 2007

- 2009. He stated that he is the regional manager and tha t they facility no longer had an environmental manager. He said that descriptions for the outfalls and why the limits have changed for outfall 003 should be included in the permit. He also stated that there are 2 Honeywell facilities in Louisiana, the Bato n Rouge facility is an organic process and he wasn’t sure why they were placed in the inorganic category. The Gismar, LA facility has 1⁄2 organic and 1⁄2 inorganic processes. The Baton Rouge facility manufactures refrigerant and sells fluorinated refrigerant g as to homes, shops, etc. Some of the larger raw materials used are chloroform and PERC (tetrachloroethylene). Mr. Campesi told me to contact Rick Frain who is the water quality manager for the Honeywell Facilities and may know more of the details of the PA Cs discharges. He’s out of Alabama

– (251)330

- 7631, Richard.frain@honeywell.com

.

On March 14 at 11:30am, I called Rick Frain (251

- 330

- 7631) and left a message. On March 15, Rick Frain returned my call and left a message requesting an email with our questions. On March 18, I returned Mr. Frain’s call and left a message along with sending him an email with our questions. Please see attached email correspondence.

On March 21, Rick Frain returned my call and left a message. On March 22 at 2:30pm I returned his call and he explained that he had been in contact with the plant and the lab. The lead environmental person for this plant has left the company but Mr. Frain was able to talk to the lab about data before 2010. Prior to 2010, there were no requirements for PACs or hexachlorobenzene discharges for outfall 003 in the facility’s permit and therefore discharges for this outfall were not reported. For outfall 001, the lab measured values t hat were below theNeed to return call by / at/between and

. Signature: 

### Minimum Qualification Level (MQL) of 10 ppb (0.01 ppm) for hexachlorobenzene and benzo(a)pyrene. The facility’s permit states that “ if any individual analytical test result is less than the MQL listed in the permit, a value of zero may b e used for that individual result for the DMR calculations and reporting requirements”. The facility reported 0 for PACs and hexachlorobenzene c ompounds prior to 2010 because they were below the MQL. Starting in 2010, the facility decided to be more conser vative and instead of reporting 0 for PACs and hexachlorobenzene compounds when they were below the MQL, they reported the MQL. This results in discharges being overestimated for PACs and hexachlorobenzene compounds in 2010 and 2011.

As stated above, the plant is a refrigerant plant and uses fluorides and chlorides. It is not expected that the plant will produce and PACs or hexachlorobenzene compounds in their processes and levels have always been below permit limits. The plant is covered under both OCPSF and Inorganic PSCs and both categories’ limits have been incorporated into the facility’s permit.

Mr. Frain stated that they h ave been overestimating the PAC and hexachlorobenzene compound discharges since 2010 and he has reviewed the facility’s permit closely. He stated that they way they report PAC and hexachlorobenzene compound discharges in the future may change; they may go back to reporting any discharge below the MQL as zero.

Mr. Frain emailed me detailed descriptions of the outfalls. Please see attached email correspondence.Email Communication with Honeywell International

From: Kimberly Bartell To: Richard.frain@honeywell.com

Date: 3/22 /13 2:44 PM Subject: Re: 2011 DMR Clarification for PACs Dischargers

Mr. Frain,

Thank you very much for your time on the phone today and for the outfall descriptions below. We will let you know if we have any further questions.

Thanks again, Kimberly

--------------------------------------- Kimberly D. Bartell Environmental Enginee r Eastern Research Group, Inc. kimberly.bartell@erg.com

Phone: 517

- 515

- 1721

From: Frain, Richard <Richard.Frain@Honeywell.com> To: Bartell, Kimberly CC: Brocato, John; Campesi, Brad

Date: 3/22/2013 2 :42 PM Subject: Honeywell Baton Rouge Outfall Descriptions

As requested, please find the Outfall descriptions from Baton Rouge’s LPDES permit below:

Outfall 001, the continuous discharge of treated process wastewater, process and non

- process area storm

water, u tility waters (including but not limited to boiler blowdown, non

- contact cooling water, and noncontact cooling water blowdown), Iron Pond effluent, sanitary wastewater, wash down waters, scrubber effluent, condensates, effluent from the Plasma Destruction Unit, discharge from secondary containment areas, and effluent from Outfall 003 in the event of a process or general plant activity upset, repair or general maintenance.

Outfall 003, the continuous discharge of utility waters (including but not limited t o non

- contact cooling water), condensates, non

- process area storm water runoff, accumulated storm water from containment areas, deminimis untreated process wastewater, and wash down waters.

Richard M. Frain Lead Environmental Specialist

- Gulf Region

Hone ywell

1 Linde Drive Chickasaw, AL 36611

Work: (251) 330

- 7631Cell: (251) 327

- 5359

Fax: (251) 330

- 7052



## ZERO HARM

– Nothing is worth the risk

From: Kimberly Bartell To: Richard.frain@honeywell.com

Date: 3/18/13 11:00 AM Subject: 2011 DMR Clarification for PACs Dischargers

Mr. Frain:

Thank you for returning my phone call. 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 2011 discharge monitoring reports
for Honeywell In ternational Incorporated in Baton Rouge, LA (LA0000329). Here is some background

on what the information is used for.

EPA reviews publicly

- available DMR data to fulfill its review obligation under Section 304(b) of the
Clean Water Act (CWA). The CWA req uires 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 2013 annual review of existing effluent guidelines
and potential industrial guidelines which may need to be included (see http://www.epa.gov/g uide/304m/
for further information). EPA will discuss this review and the results in its 2013 Effluent Guidelines
Program Plan scheduled for publication in the Federal Register sometime in 2013 or 2014. As part of the
2013 annual review, EPA is evaluating the data in discharge monitoring reports from 2011 and needs
further information to complete the review.

As you know, I have been in touch with Brad Campesi and he did confirm the 2011 DMR data for two
PACs compounds: hexachlorobenzene and benzo[a]pyrene . However, we have some additional questions

about the data.

EPA reviews DMR data using the Discharge Monitoring Report (DMR) Pollutant Loading Tool
( http://cfpub.epa.gov/dmr/ ). When we reviewed 2011 DMR data, this Honeywell facility showed up high
in our rankings due to the PACs discharges. The top three PACs compounds discharged in 2011 were
hexachlorobenzne, benzo[a]pyrene and benz[a]anthracene. After Mr. Campesi confirmed the 2011 data
(and provided one small co rrection), we reviewed previous years data to see if the discharges have been
consistent. Previous to 2010, the PACs compounds were reported as zero pounds and fluoride was the top
pollutant in DMR. We would like to figure out why the PACs compound dischar ges were zero prior to
2010 and then discharged in 2010 and 2011.

Additionally, please provide a description of outfall 001 and 003 and a description of the processes
occurring at the plant that may result in PACs discharges.Please call me at (517) 515

- 1721 if you have any questions. 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

From: Kimberly Bartell To: Campesi, Brad

Date: 2/28/13 3:09 PM Subject: RE: 2011 DMR Clarification for PACs Dischargers

Mr. Campesi,

Thank you for sending the changes to the data. We will let you know if we have any further questions.

Thanks again,
Kimberly

---------------------------------------- Kimberly D. Bartell
Environmental Engineer
Eastern Research Group, Inc.
kimberly.bartell@erg.com

Phone: 517

- 515

- 1721

From: Campesi, Brad brad.campesi@honeywell.com To: Bartell, Kimberly

Date: 2/28/13 9:46 AM Subject: RE: 2011 DMR Clarification for PACs Discharges

Changes in RED.

Brad Campesi
Environmental Manager

- Gulf Region
Honeywell Performance Materials and Technologies
Ontario & Lupine Streets

P.O. Box 2830
Baton Rouge, LA 70821

- 2830Phone

- 225.346.3661

Mobile

- 225.936.0310
brad.campesi@honeywell.com

From: Kimberly Bartell To: Campesi, Brad

Date: 2/ 26 /13 4:26 PM Subject: RE: 2011 DMR Clarification for PACs Dischargers

Mr. Campesi,

Thank you for your response. Yes, the data in my email below was totaled for 2011. The data in the excel
file that I sent includes data by month (the file is also attached to this email).

Please confirm that the remaining data is correct besid es the error found for the benzo(a)pryene
discharges from outfall 001. The remaining data includes hexachlorobenzene discharges for outfall 001
and 003 and benzo(a)pyrene discharges for outfall 003.

Please don't hesitate to call me at (517) 515

- 1721. Aga in, thank you for your help in confirming if the

data are accurate.

Thank you,
Kimberly

---------------------------------------- Kimberly D. Bartell
Environmental Engineer
Eastern Research Group, Inc.
kimberly.bartell@erg.com

Phone: 517

- 515

- 1721

From: Campesi, Brad brad.campesi@honeywell.com To: Bartell, Kimberly

Date: 2/25/13 1:13 PM Subject: RE: 2011 DMR Clarification for PACs Discharges

Kimberly: I ca n’t recall a response from me regarding this data. It appears that the 2011 results were
totaled for the year.

For Outfall 001, the permit limit appears to have been used instead of the actual results. This would result
in an error. The Benzo(a)pyrene amou nt should be 14.6 instead of 29.2.

Brad Campesi
Environmental Manager

- Gulf Region
Honeywell Performance Materials and Technologies
Ontario & Lupine StreetsP.O. Box 2830

Baton Rouge, LA 70821

- 2830

Phone

- 225.346.3661

Mobile

- 225.936.0310
brad.campesi@honeywell.com

From: Kimberly Bartell To: Campesi, Brad

Date: 2/7/13 1:23 PM Subject: RE: 2011 DMR Clarification for PACs Dischargers

Mr. Campesi

,

We gathered the data using the EPA's DMR Loading Tool ( http://cfpub.epa.gov/dmr/ ). This tool is a

collection of all the DMR and TRI data from 2007

- 2011. Under the facility search tab you can enter
Honeywell's NPD ES ID (LA0000329) and search. If you click "View Facility Loading Calculations"
about 1/2 way down the page that will take you to the data that we look at.

For the Honeywell facility, Hexachlorobenzene and Benzo(a)pyrene are the top two pollutants. I've
attached the data pulled from the DMR Loading Tool in an excel spreadsheet. The total pounds per outfall
was calculated by finding the load per reporting period using the following calculation:

(kg/d)*number of days in the reporting period (~90 or 365 day s)*conversion to pounds

Then the load for each reporting period was summed to get the annual load.

Doing these calculations, we arrive at the total discharges per outfall of each pollutant:

Hexachlorobenzene:
Outfall 001: 41.66 pounds

Outfall 003: 9.14 pounds

Benzo[a]pyrene:
Outfall 001: 29.2 pounds
Outfall 003: 9.14 pounds

I'd be happy to talk through this with you on the phone if you have any further questions. Please don't
hesitate to call me at (517) 515

- 1721 or we can set up a meeting time. Again, thank you for your help in
confirming if the above data are accurate.

Thank you,
Kimberly

---------------------------------------- Kimberly D. Bartell
Environmental Engineer
Eastern Research Group, Inc.kimb erly.bartell@erg.com

Phone: 517

- 515

- 1721

From: Campesi, Brad brad.campesi@honeywell.com To: Bartell, Kimberly

Date: 2/7/13 9:48 AM Subject: RE: 2011 DMR Clarification for PACs Discharges

Can you further define which DMR reports this data was extrapolated from? Neither of these pollutants are on the routine monthly report.

Also how was the data calculated?

Brad Campesi Environmental Manager

- Gulf Region Honeywell Performance Materials a nd Technologies Ontario & Lupine Streets

P.O. Box 2830 Baton Rouge, LA 70821

- 2830

Phone

- 225.346.3661

Mobile

- 225.936.0310 brad.campesi@honeywell.com

From: Kimberly Bartell

To: brad.campesi@honeywell.com CC: Sabol, Elizabeth; Swietlik, William; Wagoner, Kim

Date: 2/6/13 8:40 AM Subject: 2011 DMR Clarification for PACs Dischargers

Dear Mr. Campesi,

Thank you for returning my phone call. 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 2011 discharge monitoring reports for Honeywell International Incorporated in Baton Rouge, LA (LA0000329). Here is some background

on what the information is used for.

EPA reviews publicly

- av ailable DMR data to fulfill its review obligation under Section 304(b) of the Clean Water Act (CWA). 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 2013 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 2013 Effluent Guidelines Program Plan scheduled for publication in the Federal Register sometime in 2013 or 2014. As part of the 2013 annual review, EPA is evaluating the data in discharge monitoring reports from 2011 and needs further information to complete the review.

We would like to obtain additional information on the following 2011 discharge data for Hexachlorobenzene and Benzo[a]pyrene from your facility. Our records show the following loads were discharged:Hexachlorobenzene:

Outfall 001: 41.66 pounds Outfall 003: 9.14 pounds

Benzo[a]pyrene: Outfall 001: 29.2 pounds Outfall 003: 9.14 pounds

We appreciate your help in confirming if the above data are accurate, or if there are units errors in the

DMR data.

Please call me at (517) 515

- 1721 if you have any questions. 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