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Project No.: 0317.00.005.522 Page 1 of 3

Project Name: TRI2011 CBI?

Yes

No

TELEPHONE CALL RECORD

Incoming

Outgoing

Date: 01/16/2013 Time: 3:30 am

pm

Company Name: Eastman Chemical Co. ERG Staff Name: Kim 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 3:30 pm from Fredna Smith on January 16, 2013. She confirmed that the reported 1,991 

pounds of arsenic, 2,850 pounds of hydroquinone, and 9 pounds of mercury in 2011 were 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 analytical 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 unsure 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 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 
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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 reported 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 Office 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 get 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 Response: 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 analysis 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 or 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.
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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? 

Eastman’s Response: Eastman estimated the 2,850 pounds of hydroquinone 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 engineering 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 

fully 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