Need to return call by / at/between and

. Signature: Project No.: 0317.00.005.522 Page 1 of 3

Project Name: TRI20 11 

### CBI?

Yes

No TELEPHONE CALL RECOR D Incoming Outgoing Date: 01/1 6 /2013 Time: 3 : 3 0 am

pm

Company Name: Eastman Chemical Co. ERG Staff Name: K im Wagoner

Contact Name: Fredna Smith Contact Phone Number: 423

- 229

- 4320

General Subject: 2011 TRI Arsenic, Mercury, and Hydroquinone Discharges



### TOPICS DISCUSSED AND ACTION TAKEN

On January 15, 2013, I called Eastman Chemical Co. to speak with Wanda Valentine regarding 2011 TRI arsenic, mercury, and hydroquinone discharges. I left a message for Wanda stating my name, the reason for calling, and if he could call me back or pass on my information to the correct personnel for TRI data.

I received a call back at 3:3 0 pm from Fredna Smith on January 1 6 , 2013. Sh e confirmed that the reported 1,991

p ounds of arsenic, 2,850 pounds of hydroquinone, and 9 pounds of mercury in 2011 w ere correct . I asked Ms. Smith where the arsenic was coming from the process. She indicated that arsenic ( and was fairly certain that mercury as well ) were coming from the coal they use for generating electricity onsite and not from the manufacturing process. They do not measure these pollutants directly, rather they estimate the discharges based upon the ana lytical data from their coal use. I asked her if she would be willing to provide us with a copy of the method of estimation. She indicated that she would, but that she would have to pass along the request to

another division that handles that information. I indicated that I would send a follow up email with this request, including some background information about the program, why we need the data, and how we use it.

I also asked Ms. Smith where the hydroquinone was coming from in the process. She was u nsure and said that she would have to look into it. I indicated that I would also include a request about the hydroquinone discharge in my follow up email.

Follow up Email

– 1/18/2013

Dear Ms. Smith,

Thank you for returning my phone call. As discussed, EPA is requesting clarification of 2011 TRI data as part of our 2013 annual review of industrial discharges under Section 304 of the Clean Water Act. I am writing to request clarification for the Eastman Chemical Co., on behalf of EPA under Contract No. EP

- C

- 12

- 021. Please see below for further background.

EPA, Office of Water (OW), reviews TRI 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 "effluent guidelines," that limit the discharge of pollutants to waters of the U.S. from various categories of ind ustrial 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 fu rther information). EPA will discuss this reviewNeed to return call by / at/between and

. Signature: 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 report ed to the 2011 TRI and needs further information to complete the review. Specifically, we would like to clarify the amount of arsenic, mercury, and hydroquinone reported to the 2011 TRI. Please confirm/review the following data and questions below.

1. You had mentioned/could you confirm that the arsenic and mercury discharges come from the coal you use to generate electricity onsite. Could you provide us with a copy of your facility NPDES permit so that we may assess how that discharge is handled?

2. How did you estimate the 2,850 pounds of hydroquinone report in the 2011 TRI? Do you use emission factors or measured data (or other means) to estimate releases? Are releases based on any measured

values that were below detection or near the detection limit?

We appreciate your help in interpreting TRI data correctly. If you have any questions regarding this request, please call me at (703) 633

- 1620. If you would like to speak directly with EPA regarding this request, you can

contact William F. Swietlik of EPA's O ffice of Water/Engineering Analysis Division by phone at (202) 566

- 1129 or by email: swietlik.william@epa.gov

.

Regards, Kim Wagoner

I followed up with a phone call to Ms. Smith on January 24, 2013 at 2:25pm. Ms. Smith indicated that she had gathered the information we had requested and was working to get us a link to their NPDES permit. Then she needed to run everything by her supervisor before she could send it along. She indicated that they would work

to g et us the information by January 29.

Follow up email

– Received January 29, 2013

Kimberly,

Thank you for your patience as we retrieved the information you requested. I have listed your questions below and placed the Eastman response after them:

1. You had mentioned/could you confirm that the arsenic and mercury discharges come from the coal
you use to generate electricity onsite. Could you provide us with a copy of your facility NPDES permit
so that we may assess how that discharge is handled?

Eastman’s Res ponse : Eastman uses coal in boilers and gasification units onsite. Mercury compounds and arsenic compounds are common constituents in coal. Therefore, Eastman addressed both mercury compounds and arsenic compounds in the TRI reporting. However, Eastman’s a nalysis of discharge samples showed that if any arsenic compounds or mercury compounds were present at all, which is unknown, it was below detection limits. Pursuant to EPA guidance and despite our analysis not detecting the presence of arsenic compounds o r mercury compounds, Eastman used half the detection limit to calculate arsenic compound and mercury compound releases.

Eastman’s NPDES Permit is provided in the attachment line above.Need to return call by / at/between and

. Signature:

2. How did you estimate the 2,850 pounds of hydroquinone report in the 201 1 TRI? Do you use emission
factors or measured data (or other means) to estimate releases? Are releases based on any measured

values that were below detection or near the detection limit?

Eastman’s Response : Eastman estimated the 2,850 pounds of hydroquin one in the 2011 TRI using wastewater modeling software based on influent manufacturing data. Eastman reports hydroquinone

pursuant to EPA’s Basis of Estimate code “O”. EPA’s definition of that code is “Estimate is based on other approaches such as engineer ing calculations (e.g. estimating volatization using published mathematical formulas) or best engineering judgment. This would include applying an estimated removal efficiency to a waste stream, even if the composition of the stream before treatment was

fu lly identified through monitoring data.”

If you have any questions, please don’t hesitate to call me.

Fredna Smith

Eastman Chemical Company

(423)229

- 4320

Follow

- up email

– Sent February 1, 2013

Ms. Smith,

Thank you very much for sending your response. We will review the information and let you know if we have any further questions.

Regards,

Kim