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.La ndick@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 EPA

HQ

- 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, dis tribution 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.

Mate rials/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 4.2From: 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, Januar y 28, 2011 2:40 PMTo: 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 request ing 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 tech nology

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 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 po unds

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 i n 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 y es. 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 wastew ater? 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 ha ve 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) 56 6

- 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 20 11 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 backgroun d.

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 technology

based regulations, called “effluent limitatio ns 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 indust rial 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 mangane se 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 incorpor ate 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 reques t, 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

- 1119Need 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 RECOR D Incoming Outgoing Date: 

### 01/2 8 /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 28 th 

### , 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 2 nd 

### , 2011, Mr. Blackmon called me at 9:10am to verify some of the questions discussed in the e

mail correspondence. He stated that the EPD is the Environmental Protection Division which is the Georgia Department of Natural Resources. They take samples of the wa stewater at random . The l ast 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 sam ple 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 2 nd 

### , 2011, I called Mr. Blackmon and a sked 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 sl owly shut down until August 2009 when all producti on 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 RECOR D 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 ca ll on January 31, 2011 at 8:45 am. I explained that I was ca lling 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. P lease 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 corr espondence.

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. Du e 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 h ydraulic 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 manganes e 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 23 rd 

### , 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 24 th 

### , 2011 at 11:20am I returned his call and left a message asking for him to call me back. On March 25 th 

### , 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 28 th 

### , 2011 I called Mr. Peak back and left a

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

. Signature: 

### On April 8 th 

### , 2011 at 4:14pm I called Mr. Peak again and spoke to him about the c onfidentiality 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. M r. Peak stated that it was alright to remove the language on the bottom of the emails and to publish the information.