From: "Blackmon, Joseph" <Joseph.Blackmon@tronox.com>

To: Landick, Kimberly

Date: 2/9/2011 9:11:00 AM

Subject: RE: Request for 2009 TRI Data Clarification

Kim,

You may include the information that I sent to you within the public docket. Disregard the disclaimer.

Thanks,

Joseph Blackmon

Environmental & Safety Specialist

Tronox Pigments, Savannah

1 Kerr McGee Road

P.O. Box 368

Savannah, GA 31402

Office: 912-652-1151

Cell: 912-660-8109

Fax: 912-652-1170

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

Sent: Wednesday, February 09, 2011 8:21 AM

To: Blackmon, Joseph

Subject: RE: Request for 2009 TRI Data Clarification

Mr. Blackmon, 

Thank you for the data you provided. EPA would like to include these data as part of their public docket,

to show why they are not adjusting the discharged pounds of manganese due to the method of calculation 

and process termination. The public docket is available at http://www.regulations.gov, Docket ID EPAHQ-OW-2008-0517. We have included this type of information in the docket in the past; however, this 

data transmittal included an auto-disclaimer at the end of this e-mail.

In order to do include the updated Manganese information for Tronox Pigments that you provided in the 

public docket, we would need your permission to ignore the auto-disclaimer generated at the bottom of 

this e-mail:

"Tronox Confidentiality Notice!

If you are not the intended recipient of this e-mail message, any use, distribution or copying of the 

message is prohibited.

Please let me know immediately by return e-mail if you have received this message by mistake,

then delete the e-mail message.

Thank you."

Please reply to this e-mail to let us know if it is ok to include the information in EPA's public docket.

Thank you,

Kim
----------------------------------------

Kimberly D. Landick

Environmental Engineer

Eastern Research Group, Inc. 

14555 Avion Parkway, Suite 200

Chantilly, VA 20151

kimberly.landick@erg.com

Phone: 703-633-1119

From: "Blackmon, Joseph" <Joseph.Blackmon@tronox.com>

To: Landick, Kimberly

Date: 2/2/2011 9:24:44 AM

Subject: RE: Request for 2009 TRI Data Clarification

Due to the large size of the report, I am only sending you the scanned in results for the page with 

Manganese in it, along with the COC. The calculation is performed by taking the average daily flow for 

the entire year:

We then calculate the amount of flow generated (average daily x 365), convert it into liters (Flow x 

3.785411464), calculate amount of Manganese (Liters x 13 x 0.000001) in kg and convert it to pounds 

(kg x 2.2046224). The calculated data is shown below.

Materials/Wast

es Generated

Amount of 

Material/Waste

Kilogra

ms of 

Pounds 

of 

or Used Onsite

Amount 

Generated/Used Existing Site 

Data Generated in 2009

Mn 

Generat

ed

Mn 

Generate

d

WW/Solids to 

River (D001)(c)

1,530,345,52

8

gallo

ns

13

.0

mg/l or 

ppm

5,792,987,5

05 liters 75,309 166,028

Let me know if you need anything else.

Thanks,

Joseph Blackmon

Environmental & Safety Specialist

Tronox Pigments, Savannah

1 Kerr McGee Road

P.O. Box 368

Savannah, GA 31402

Office: 912-652-1151

Cell: 912-660-8109

Fax: 912-652-1170

001

Flow

Date mgd

Ave 4.2 
From: Kimberly Landick [mailto:Kimberly.Landick@erg.com] 

Sent: Wednesday, February 02, 2011 7:52 AM

To: Blackmon, Joseph

Subject: RE: Request for 2009 TRI Data Clarification

Mr. Blackmon, 

Thank you for your response. Could you please provide a copy of the monitoring data that you referenced 

in your previous e-mail? Also, please further explain the EPD process and how you use that with the 2002 

concentration in your calculations and provide the date (month/year) that the titanium dioxide 

manufacturing process was discontinued. 

If it's easier to discuss this over the phone, please don't hesitate to call me at 703-633-1119. We 

appreciate your help in interpreting TRI data correctly. 

Thank you,

Kim

----------------------------------------

Kimberly D. Landick

Environmental Engineer

Eastern Research Group, Inc. 

14555 Avion Parkway, Suite 200

Chantilly, VA 20151

kimberly.landick@erg.com

Phone: 703-633-1119

From: "Blackmon, Joseph" <Joseph.Blackmon@tronox.com>

To: Landick, Kimberly

Date: 1/31/2011 8:48:16 AM

Subject: Request for 2009 TRI Data Clarification

See below for responses. Let me know if you have any questions.

Thanks,

Joseph Blackmon

Environmental & Safety Specialist

Tronox Pigments, Savannah

1 Kerr McGee Road

P.O. Box 368

Savannah, GA 31402

Office: 912-652-1151

Cell: 912-660-8109

Fax: 912-652-1170

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

Sent: Friday, January 28, 2011 2:40 PM
To: Blackmon, Joseph

Cc: swietlik.william@epa.gov; Eleanor Codding; Elizabeth Sabol; Jessica Gray

Subject: Request for 2009 TRI Data Clarification

Mr. Blackmon, 

Thank you for your time on the phone today. As discussed, EPA is requesting clarification of 2009 TRI 

data as part of our 2011 annual review of industrial discharges under Section 304 of the Clean Water Act. 

I am writing to request clarification of manganese and manganese compounds discharges on EPA's behalf 

under Contract No. 68-C-02-095. Please see below for further background.

EPA 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 technologybased 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 2011 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 2011 Effluent Guidelines Program Plan scheduled for publication in the 

Federal Register in 2011. 

As part of the 2011 annual review, EPA is evaluating the data reported to the 2009 TRI and needs further 

information to complete the review. Specifically, we would like to clarify the amount of manganese and 

manganese compounds reported to the 2009 TRI. Please confirm/review the following data and 

questions below.

1. Please confirm the pounds of manganese and manganese compounds released in 2009: 166,000 pounds

Yes

2. Please explain how the manganese and manganese compounds load is calculated. We use a 

concentration amount from a 2002 split sample from a Compliance Sampling Inspection for crosscheck 

with EPD for our effluent. We use the concentration level in ppm to calculate against million gallons of 

day flow-rate and 8.34 pounds per gallon to calculate the load.

3. If the load is determined from monitoring data, were the concentrations above the detection limit? Is 

the monitoring data available? Yes, and yes.

4. If any concentrations were reported below the detection limit, how did you incorporate those 

concentrations? When we have non-detectable levels, we use the detection limit.

5. What is the source of the manganese and manganese compounds in the wastewater? Titanium Dioxide 

Manufacturing

6. What flow did you use to calculate the load? Is the flow measured at the same location as the 

manganese, or it the final outfall? We used the outfall flow data.

It should be noted that the titanium dioxide manufacturing process has been discontinued onsite. Due to 

this, there should be no future releases pertaining to this source.

We appreciate your help in interpreting TRI data correctly. If it is more convenient to discuss this over the 

phone or if you have any questions regarding this request, please call me at (703) 633-1119. 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,
Kim

----------------------------------------

Kimberly D. Landick

Environmental Engineer

Eastern Research Group, Inc. 

14555 Avion Parkway, Suite 200

Chantilly, VA 20151

kimberly.landick@erg.com

Phone: 703-633-1119

Tronox Confidentiality Notice!

If you are not the intended recipient of this e-mail message, any use, distribution or copying of the 

message is prohibited.

Please let me know immediately by return e-mail if you have received this message by mistake,

then delete the e-mail message.

Thank you. 

From: Kimberly Landick

To: joseph.blackmon@tronox.com

CC: Codding, Eleanor; Gray, Jessica; Sabol, Elizabeth; swietlik.william@epa.gov

Date: 1/28/2011 2:39:33 PM

Subject: Request for 2009 TRI Data Clarification

Mr. Blackmon, 

Thank you for your time on the phone today. As discussed, EPA is requesting clarification of 2009 TRI 

data as part of our 2011 annual review of industrial discharges under Section 304 of the Clean Water Act. 

I am writing to request clarification of manganese and manganese compounds discharges on EPA's behalf 

under Contract No. 68-C-02-095. Please see below for further background.

EPA 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 technologybased 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 2011 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 2011 Effluent Guidelines Program Plan scheduled for publication in the 

Federal Register in 2011. 

As part of the 2011 annual review, EPA is evaluating the data reported to the 2009 TRI and needs further 

information to complete the review. Specifically, we would like to clarify the amount of manganese and

manganese compounds reported to the 2009 TRI. Please confirm/review the following data and 

questions below.

1. Please confirm the pounds of manganese and manganese compounds released in 2009: 166,000 pounds

2. Please explain how the manganese and manganese compounds load is calculated. 

3. If the load is determined from monitoring data, were the concentrations above the detection limit? Is 

the monitoring data available?

4. If any concentrations were reported below the detection limit, how did you incorporate those 

concentrations?
5. What is the source of the manganese and manganese compounds in the wastewater?

6. What flow did you use to calculate the load? Is the flow measured at the same location as the 

manganese, or it the final outfall?

We appreciate your help in interpreting TRI data correctly. If it is more convenient to discuss this over the 

phone or if you have any questions regarding this request, please call me at (703) 633-1119. 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,

Kim

----------------------------------------

Kimberly D. Landick

Environmental Engineer

Eastern Research Group, Inc. 

14555 Avion Parkway, Suite 200

Chantilly, VA 20151

kimberly.landick@erg.com

Phone: 703-633-1119
Need to return call by / at/between and . Signature:

Project No.: 0172.08.005.604 Page 1 of 1

Project Name: TRI2009 CBI?

Yes

No

TELEPHONE CALL RECORD

Incoming

Outgoing

Date: 01/28/11 Time: 2:00 am

pm

Company Name: Tronox Pigments, Inc. ERG Staff Name: Kimberly Landick

Contact Name: Joseph Blackmon Contact Phone Number: (912)652-1151

General Subject: 2009 TRI PAC Discharges

TOPICS DISCUSSED AND ACTION TAKEN

On January 28th, 2011, I called Tronox Pigments, Inc. to speak with Joseph Blackmon regarding 2009 TRI 

manganese and manganese compounds discharges. Mr. Blackmon answered and I stated my questions. He 

requested an e-mail in order to verify our credibility. I sent Mr. Blackmon an e-mail on January 28, 2011 at 

2:40pm. Please see attached e-mail correspondence. 

On February 2nd, 2011, Mr. Blackmon called me at 9:10am to verify some of the questions discussed in the email correspondence. He stated that the EPD is the Environmental Protection Division which is the Georgia 

Department of Natural Resources. They take samples of the wastewater at random. The last time the EPD 

visited and reported data for manganese was 2002 so Tronox Pigments uses that data to calculate the amount of 

pounds released. He also stated that manganese is not part of wastewater requirements under their NPDES 

permit so they do not sample for it on a regular basis and therefore rely on the data from the EPD. Mr. 

Blackmon stated that he would send me the data through e-mail shortly. Please see attached e-mail 

correspondence. 

At 10:20am on February 2nd, 2011, I called Mr. Blackmon and asked when the Titanium Dioxide 

Manufacturing process was shut down which was the source of the manganese and manganese compounds. He 

stated that the process was shut down to 50% in December 2008 and then slowly shut down until August 2009

when all production stopped. Since the source of the manganese and manganese compounds has been 

discontinued there will be no further reports of manganese and manganese compounds discharges to TRI. 
Need to return call by / at/between and . Signature:

Project No.: 0172.08.005.604 Page 1 of 2

Project Name: TRI2009 CBI?

Yes

No

TELEPHONE CALL RECORD

Incoming

Outgoing

Date: 01/28/11 Time: 2:00 am

pm

Company Name: Tronox, LLC ERG Staff Name: Kimberly Landick

Contact Name: Terry Freeze Contact Phone Number: (662) 343-8510

General Subject: 2009 TRI Manganese and Manganese Compounds Discharges

TOPICS DISCUSSED AND ACTION TAKEN

On January 28, 2011, I called Tronox, LLC to speak with Terry Freeze regarding 2009 TRI manganese and 

manganese compounds discharges. I left a message stating my name, the reason for calling, and if he could call 

me back or pass my information to the correct personnel for TRI data.

Terry Freeze returned my phone call on January 31, 2011 at 8:45am. I explained that I was calling for some 

specific information on 2009 TRI manganese and manganese compounds discharges reported by the facility. 

Mr. Freeze asked that I send my questions via e-mail so that he could gather the information. I sent an e-mail at 

10:45am on 01/31/11. Please see the attached e-mail correspondence. 

On February 3, 2011 at 10:54am, I called Mr. Freeze to confirm that he received my e-mail and didn’t have any 

questions. He stated that he was sending his response shortly. Please see the attached e-mail correspondence. 

On February 9, 2011 at 7:50am, I called Mr. Freeze and left a message to confirm that he received my e-mail 

and didn’t have any questions. He called me back at 8am and stated that he was hoping to send his response 

later today or tomorrow. Due to weather conditions operations haven’t been completely normal and he is still 

waiting to hear back from some people but will hopefully be able to respond shortly. 

On February 11, 2011 at 2:01pm, I received an e-mail from Mr. Freeze with the 2009 data. After looking at the 

information I called Mr. Freeze on February 23, 2011 at 9am and discussed the data that he sent. He said that 

the high concentration value in June of 2009 was noticed. He thinks that it is caused from the way they were 

managing the hydraulic loading into the settling ponds during this time. They have a series of settling ponds and 

during storm events or maintenance activities the loading can become irregular and therefore cause a higher 

than average discharge of manganese and manganese compounds. Mr. Freeze discussed that their process water 

goes from the process system to a treatment system and then to outfall 201. Their treatment system consists of a 

neutralization component and a series of settling ponds. He also stated that he has 2008 and 2010 data available 

and asked for a written request via e-mail. This was sent at 9:10am, please see attached e-mail correspondence. 

On March 23rd, 2011 at 12:13pm, I received a phone call from Matthew Peak from Tronox, LLC. He left a 

message stating that he would like to talk to me about the confidentiality notice email that I had sent to Mr. 

Freeze. His phone number is 405-775-5443. On March 24th, 2011 at 11:20am I returned his call and left a 

message asking for him to call me back. On March 25th, 2011 at 5:28pm, Mr. Peak called me back and left a 

message asking for me to return his call. At 12:46pm on March 28th, 2011 I called Mr. Peak back and left a 

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

On April 8th, 2011 at 4:14pm I called Mr. Peak again and spoke to him about the confidentiality notice. I 

explained that the TRI data is public information but that we need permission to ignore the confidentiality 

notice at the bottom of the email correspondence in order to publish that information into the public docket 

through EPA. Mr. Peak stated that it was alright to remove the language on the bottom of the emails and to 

publish the information.