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

Project No.: 0317.00.005.522 Page 1 of 2

Project Name: DMR2011 CBI?

Yes

No

TELEPHONE CALL RECORD

Incoming

Outgoing

Date: 02/05/13 Time: 1:00 am

pm

Company Name: Honeywell International ERG Staff Name: Kimberly Bartell

Contact Name: Brad Campesi Contact Phone Number: (225) 346-3661

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 compounds 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 follow 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 that 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 Baton 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 gas 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 PACs 

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 that were below the 
Need 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 be used for that individual result for the DMR calculations and reporting requirements”. The 

facility reported 0 for PACs and hexachlorobenzene compounds prior to 2010 because they were below the 

MQL. Starting in 2010, the facility decided to be more conservative 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 have 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 Engineer

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, utility 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 to 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

Honeywell 

1 Linde Drive

Chickasaw, AL 36611

Work: (251) 330-7631
Cell: (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. EPC-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-available 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.

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 correction), 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 discharges 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 70821-2830
Phone - 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 besides 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. Again, 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 can’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 amount should be 14.6 instead of 29.2.

Brad Campesi

Environmental Manager - Gulf Region

Honeywell Performance Materials and 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: 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 NPDES 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 days)*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. 
kimberly.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 and 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. EPC-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-available 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