Project No.: 

### 0317.01.005.510 Page 1 of 7

Project Name: 

### DMR20 11 

## CBI?

Yes

No TELEPHONE CALL RECOR D

Incoming

Outgoing Date: 

### 12/11/13 Time: 

### 3:02 am

pm

Company Name: 

### Nyrstar Clarksville, Inc. ERG Staff Name: 

### Julia Kolberg

Contact Name: 

### William (Chad) Crocker Contact Phone Number: 

### (931) 552

- 4200 ext. 3277

General Subject: 

### 20 11 DMR Discharges



## TOPICS DISCUSSED AND ACTION TAKEN

On December 11, 2013 at 3:02pm I called Dana Waits (615

- 532

- 1171) and left a message asking her to return

my call.

Dana returned my call on 12/12/13, but I was out of the office. I called her back on 12/13/13 and alerted her to

my availability to talk the following Monday.

On December 16, 2013 at 2:22pm I spoke with Dana. I agreed to send her our DMR data and ask her to verify

the measured values.

On January 7, 2014 at 10:14am I left a message with Dana stating that I would send additional lead

concentrations for her to verify.

On January 16, 2014 at 3:11pm I called and left another message with Dana, asking for any additional

expediency that they could provide. I also called the main office line and requested additional support; they

suggested sending someone to TN to look at the documents.

On January 17, 2014 at 1:51pm I called the facility directly to discuss our questions (931

- 552

- 4200). I was

directed to William ( Chad ) Crocker’s voicemail, where I left a voicemail.

On January 20, 2014 at 12:23pm, Chad returned my call. We briefly discussed the on

- site sampling procedure

(twice a month for cadmium and quarterly for lead), as well as the various outfalls on

- site. T here are a total of

five outfalls on

- site; two are used for process water discharge and the other three are used for stormwater.

Outfall 001 is discharge of process water that has been run through a metals recovery treatment plant. Outfall

002 is from a filter backwash pond that is used to contain overflows. SW3 is the primary stormwater drain for

the facility. SW4 is the stormwater outlet for the raw material transfer area of the facility. SW5 is used to

discharge water that accumulates due to the fac ility location being at the bottom of a hill. The contact requested

I send an e

- mail with any additional questions.

On January 24, 2014 at 4:25pm, Chad e

- mailed me back with a partial confirmation of the lead data and some

of the cadmium data.

On Januar y 27, 2014 at 9:34am, I called Chad to follow up on the information he sent and to ask some

additional questions. I left a voicemail and sent an e

- mail as well. He returned my call at 11:47am and told me

that, plus or minus a slight amount, he had roughl y the same values for the mass of discharge for both cadmium

and lead. He also confirmed that there were discharges out of the SW outfalls throughout 2007, 2008 and 2009

and would send reports th at correspond to those outfalls, and that it was possible th ere was miscommunication

with the state of TN based on changes in reporting software and methods.

### Please see attached e

- mail correspondence for additional information on this facility.From: Crocker, William

Sent: Thursday, February 6 , 2014 5:30 PM

To: Julia Kolberg

Subject: Re: TN0029157 Nyrstar Clarksville

Sorry again for the delay. I could go as far back as Aug 2008 in my records here. The program we used before that to

submit the data is old and does not work on my computer anymore. But I did get what I could put into a spreadsheet

format.

Chad Crocker

Senior Environmental Advisor

Nyrstar

D: + 1 931

- 552

- 4200 x. 3277

F: + 1 931

- 221

- 3215

William.Crocker@nyrstar.com

From: Julia Kolberg [ mailto:Julia.Kolberg@erg.com ]

Sent: Thursday, February 06, 2014 7:40 AM

To: Crocker, William

Subject: RE: TN0029157 Nyrstar Clarksville

Good morning, Chad;

I'm following up on our conversation last week to see if you had a chance to pull together the 2007, 2008 and 2009 DMR

information for outfalls 001, SW3, SW4 and SW5. Please let me know if there are any questions or if I can assist in any

way.

Thanks!

Julia

Julia Kolb erg

Eastern Research Group, Inc.

703

- 633

- 1610

julia.kolberg@erg.com

>>> Julia Kolberg 1/31/2014 9:05 AM >>>

Good morning Chad!

I just wanted to follow up to see if you had any additional questions or were able to take a look at this information yet.

I'm available by phone or e

- mail all day today.

Thanks again for your help.

Julia

Julia Kolberg

Eastern Research Group, Inc.

703

- 633

- 1610

julia.kolberg@erg.com

>>> Julia Kolberg 1/27/2014 9:46 AM >>>

Good morning, Chad;Again, my apologies for indicating the wrong units for cadmium measurements in the spreadsheet I sent you. Please

see the attache d, updated spreadsheet. Our report comes from the DMR database, which consists of

information reported by the state of TN to ICIS. The state of TN gets their data from the DMR reports that are sent to

them by discharging facilities. As you can guess, th ere's a lot of opportunity for error as the information is passed among

so many different parties.

I'll be available most of the week to discuss and follow up on some of the questions from my voicemail.

Thanks again!

Julia

Julia Kolberg

Eastern Resea rch Group, Inc.

703

- 633

- 1610

julia.kolberg@erg.com

>>> "Crocker, William" < william.crocker@nyrstar.com > 1/24/2014 4:24 PM >>>

1. The flow data and the cadmium data for the stormwater outfalls matches my records. The cadmium data for outfall

001 does not match anything that I have. Is this a calculated value in the report that you ran? We report the data for

001 in units of lb/d.

2. All of the lead data in your attached spreadsheet is correct. I have compared it to my sheets I use for reporting.

3. The site has been reporting cadmium and lead discharges for many years, as far back as my records are. We began

reporting data into netDMR in 2010.

4. Outfall 001

– Treated water from our on

- site Metals Recovery process that discharges into the Cumberland River

through a closed pipe. The water is sampled by automatic composite sampler prior to discharge into the river. SW3

–

Stormwat er runoff that drains from the main production area of the facility through underground storm sewer system.

SW4

– Stormwater runoff that drains from the “Materials Handling” areas, including concentrate/oxide storage, covered

conveyor systems, and truck u nloading operations. SW5

– Stormwater runoff that drains from ancillary areas of the

facility, including parking lots, maintenance shop, drainage from up

- gradient residential, and truck loadout.

If there is anything else you need, let me know. Sorry for the delay.

Chad Crocker

Senior Environmental Advisor

Nyrstar

D: + 1 931

- 552

- 4200 x. 3277

F: + 1 931

- 221

- 3215

William.Crocker@nyrstar.com

From: Julia Kolberg [ mailto:Julia.Kolberg@erg.com ]

Sent: Friday, January 24, 2014 12:06 PM

To: Crocker, William

Subject: Re: TN0029157 Nyrstar Clarksville

Hi Chad

I just wanted to follow up and make sure you had received this e

- mail. Do you have a rough idea when this information

might be available?

Thanks!

Julia

Julia Kolberg

Eastern Research Group, Inc.

703

- 633

- 1610julia.kolberg@erg.com

>>> Julia Kolberg 1/20/2014 1:45 PM >>>

Dear Mr. Crocker,

Thank you for speaking with me earlier. Eastern Research Group, Inc. (ERG) under EPA Contract No. EP

- C

- 12

- 021, is e

mailing you on EPA's behalf to request clarification of 2011 DMR data for the Nyrstar Clarksville facility in Clarksville,

TN (TN0029157). P lease see below for further background.

EPA, Office of Water (OW) reviews 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 wat ers

of the U.S. from various categories of industrial facilities. EPA is currently conducting its 2013 an nual 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 2014.

As part of the 2013 annual review, EPA is evaluating 2011 DMR data and need s further information to complete the

review. Specifically, we have the following questions:

- Please confirm the cadmium discharge values (Outfalls 001, SW3, SW4 and SW5) for the 2011 DMR data (see attached).

- Please confirm the lead discharge values ( Outfalls SW3, SW4, and SW5) for the 2011 DMR data (see attached).



### - When did the facility start monitoring for cadmium and lead discharges?

- Provide a description of outfalls 001, SW3, SW4, and SW5.

- If readily available, please send the 2012 and 2013 ca dmium and lead DMR data.



### We appreciate your help in interpreting DMR data correctly. Please call me at (703) 633

- 1610 if you have any

questions. If you would like to speak directly with EPA regarding this request, you can contact William F.

Swietlik of EP A's Office of Water/Engineering Analysis Division by phone at (202) 566

- 1129 or by email:

swietlik.william@epa.gov

.

Thank you,

Julia

Julia Kolberg

Eastern Research Group, Inc.

703

- 633

- 1610

julia.kolberg@erg.comNPDES ID : TN0029157

Facility

Name: Nyrstar Clarksville, Inc.

Outfall Parameter

Name Monitoring

Period Measurement Type Avg Daily

Value Wastewater Flow

(MGD)

001 Cadmium Aug

- 08 Quantity (lb/day) 1.16 0.602

001 Cadmium Sep

- 08 Quantity (lb/day) 0.84 0.495

001 Cadmium Oct

- 08 Quantity (lb/day) 1.19 0.637

001 Cadmium Nov

- 08 Quantity (lb/day) 0.7 0.574

001 Cadmium Dec

- 08 Quantity (lb/day) 1.13 0.637

001 Cadmium Jan

- 09 Quantity (lb/day) 0.79 0.511

001 Cadmium Feb

- 09 Quantity (lb/day) 0.81 0.56

001 Cadmium Mar

- 09 Quantity (lb/day) 1.03 0.578

001 Cadmium Apr

- 09 Quantity (lb/day) 0.86 0.613

001 Cadmium May

- 09 Quantity (lb/day) 1.05 0.717

001 Cadmium Jun

- 09 Quantity (lb/day) 1.78 0.548

001 Cadmium Jul

- 09 Quantity (lb/day) 0.82 0.627

001 Cadmium Aug

- 09 Quantity (lb/day) 0.94 0.604

001 Cadmium Sep

- 09 Quantity (lb/day) 1.23 0.689

001 Cadmium Oct

- 09 Quantity (lb/day) 1.04 0.658

001 Cadmium Nov

- 09 Quantity (lb/day) 1.13 0.634

001 Cadmium Dec

- 09 Quantity (lb/day) 1.19 0.728

SW3 Cadmium Dec

- 08 Concentration (mg/L) 1.73 0.282

SW3 Cadmium Mar

- 09 Concentration (mg/L) 1.57 0.093

SW3 Cadmium Jun

- 09 Concentration (mg/L) 1.89 0.049

SW3 Cadmium Sep

- 09 Concentration (mg/L) 0.69 0.228

SW3 Cadmium Dec

- 09 Concentration (mg/L) 1.17 0.091

SW4 Cadmium Dec

- 08 Concentration (mg/L) 0.32 0.276

SW4 Cadmium Mar

- 09 Concentration (mg/L) 0.1 0.079

SW4 Cadmium Jun

- 09 Concentration (mg/L) 0.05 0.045

SW4 Cadmium Sep

- 09 Concentration (mg/L) 0.17 0.123

SW4 Cadmium Dec

- 09 Concentration (mg/L) 0.45 0.076

SW5 Cadmium Dec

- 08 Concentration (mg/L) 0.14 2.399

SW5 Cadmium Jun

- 09 Concentration (mg/L) 0.47 0.685

SW5 Cadmium Dec

- 09 Concentration (mg/L) 0.05 1.074NPDES ID : TN0029157

Facility

Name: Nyrstar Clarksville, Inc.

Outfall Parameter

Name Monitoring

Period Measurement Type Avg Daily

Value Wastewater Flow

(MGD)

SW3 Lead Dec

- 08 Concentration (mg/L) 1.45 0.282

SW3 Lead Mar

- 09 Concentration (mg/L) 0.05 0.093

SW3 Lead Jun

- 09 Concentration (mg/L) 1.68 0.049

SW3 Lead Sep

- 09 Concentration (mg/L) 0.44 0.228

SW3 Lead Dec

- 09 Concentration (mg/L) 1.52 0.091

SW4 Lead Dec

- 08 Concentration (mg/L) 0.05 0.276

SW4 Lead Mar

- 09 Concentration (mg/L) 0.58 0.079

SW4 Lead Jun

- 09 Concentration (mg/L) 0.05 0.045

SW4 Lead Sep

- 09 Concentration (mg/L) 0.05 0.123

SW4 Lead Dec

- 09 Concentration (mg/L) 2.68 0.076

SW5 Lead Dec

- 08 Concentration (mg/L) 0.05 2.399

SW5 Lead Jun

- 09 Concentration (mg/L) 0.14 0.685

SW5 Lead Dec

- 09 Concentration (mg/L) 0.05 1.074