Need to return call by / at/between and

. Signature: Project No.: 0 317.0 1.005.510 Page 1 of 2

Project Name: DMR20 11 

### CBI?

Yes

No TELEPHONE CALL RECOR D Incoming Outgoing Date: 12/13 /13 Time: 4:00 am

pm

Company Name: Cahaba Timber Co ERG Staff Name: Kimberly Bartell

Contact Name: Al Woodruff Contact Phone Number: (205) 926

- 5966

General Subject: 2011 DMR Chlorine Discharges for Cahaba Timber Co



### TOPICS DISCUSSED AND ACTION TAKEN

Cahaba Timer plant: 205

- 926

- 5966 Cahaba Management Office: 205

- 926

- 6690

Al Woodruff: 205

- 926

- 6703 (office), 205

- 316

- 8937 (cell), al_woodruff@msn.com Ken Layton: 205

- 951

- 7375

On December 13 th I called Cahaba Timber at the number above and spoke to a receptionist. She told me to contact the management office at 205

- 926

- 6690. I called the management office and spoke to Jennifer. She told

me that I would need to emai l her the information I was looking for so that she could verify who I was. Her

email is Jennifer@cahabatimber.com . Please see attached email communication.

On December 17 th , I called the Cahaba Timber management office and once again spoke with Jennifer. She stated that they had forwarded my email to Al Woodruff and that he would be the correct contact to call. His

cell number is 205

- 316

- 8937.

On December 18 th , I called Al Woodruff but he has not set up his voicemail yet so I was not able to leave a message. I called the management office back and asked for Mr. Woodruff’s office number and email address. I called his office number and left a message. I followed up with an e mail to Mr. Woodruff.

On December 30 th , I called and left a message for Mr. Woodruff, asking if he received my email and requesting a time frame that we can expect a response.

On January 8 th , I called and left a message for Mr. Woodruff.

On January 8 th , I also called the management office back and requested that Mr. Woodruff or someone else please return my calls. I was told that they would follow up with Mr. Woodruff and someone would be in touch

with me soon.

On January 10 th , Mr. Woodruff returned my call and left a message. He also replied to my email, which I

returned. See attached email communication.

On January 15 th , I called Mr. Woodruff and left a message to confirm that he received my email with additional questions.Need to return call by / at/between and

. Signature: On January 16 th at 8: 30am I received a call from Ken Layton from Layton Environmental Engineering LLC, the

environmental consultant for Cahaba Timber. His number is 205

- 951

- 7375. He stated that he could provide the necessary information about Cahaba Timber and provided the fol lowing details:

- Cahaba timber performs wood preserving operations, mostly pole treating (telephone poles, etc.)

- The facility uses three wood preservatives: Chromated Copper Arsenate (CCA) ( http: //www.epa.gov/oppad001/reregistration/cca/ ), Creosote ( http://www.epa.gov/pesticides/factsheets/chemicals/creosote_main.htm ), and Pentachlorophenol ( http://www.epa.gov/pesticides/factsheets/chemicals/pentachlorophenol_main.htm )

- Minor chlorine discharges could be coming from the storage of poles from the pentachlorophenol preservative. After dipping the poles in preservatives, the facility leaves the poles on a drip pad for awhile and then they are moved to the yard. If dripping from the poles is noticed after they are moved to the yard, the liquid is cleaned up. However, small amounts m ay enter the water supply this way through drips of pentachlorophenol.

- The facility has no process wastewater at all.

- All outfalls are stormwater outfalls with additional discharges from cooling tower/boiler blowdown. The cooling tower/boiler blowdown co

- mingles with the stormwater before discharge.

- Suspect that chlorine discharges are from the cooling tower/boiler blowdown discharges. The facility uses water from the city which could be over

- chlorinated.

- Cahaba Timber was not required to report disch arges of chlorine prior to 2011. The old permit only required chloride monitoring (2005 permit).

- A new permit was issued in 2011 that requires the facility to sample for chlorine, no limit is listed.

- The facility has no treatment processes in place.

- The f acility was covered under the AL general stormwater permit for a long time until ADEM decided to require that wood preserving operations have an individual stormwater permit (around 2004/2005).

- ADEM did not originally include chlorine monitoring in the ind ividual stormwater permits for facilities with cooling towers/boiler blowdown. Suspect that ADEM decided to add the chlorine limit in individual permit revisions (in 2011) because it has always been in the general stormwater permit.

- Q after outfalls in th e permit indicates quarterly monitoring.

Next Steps: look into treatment levels for chlorine, also look into ELGs

– is this facility meeting ELG limits?Email Communication with Cahaba Timber Co.

From: Bartell, Kimberly

To: jennifer@cahabatimber.com CC: Sabol, Elizabeth; Swietlik, William; Wagoner, Kim

Date: 12/13/13 6:10 P M Subject: 2011 DMR Clarification for Chlorine Discharges

Dear Jennifer,

Thank you for your time on the phone today. 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 discharge monitoring reports for Cahaba Timber Co. (AL0055395). Here is some background on

what the information is used for.

EPA reviews publicly

- available 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 pol lution 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 2 013 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 2013 Effluent Guidelines Program Plan scheduled for publication in the Federal Register in 2014. As part of the 2013 annual review, EPA is evaluating the data in discharge monitoring reports from 2011 and needs further information to com plete the review. We would like to obtain additional information on the following 2011 discharge data for total

residual chlorine for your facility. Our records show the following values were discharged:

Total Residual Chlorine

Outfall Date Total Residua l Chlorine

Concentration (mg/L) Wastewater Flow (MGD)

001 9/30/2011 24.1 0.78

001 12/31/2011 7.2 0.19

002 9/30/2011 9.24 0.78

002 12/31/2011 5.73 0.19

003 9/30/2011 33 0.78

003 12/31/2011 6.55 0.19

004 9/30/2011 18.4 0.78

004 12/31/2011 7.19 0.19

005 9/30/2011 8.89 0.78

005 12/31/2011 3.8 0.19

We appreciate your help in confirming if the above data are accurate, or if there are units errors

in the DMR data.Please call me at (517) 515

- 1721 if you have any questions. 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 ema il: swietlik.william@epa.gov

.

Thank you, Kimberly

---------------------------------------- Kimberly D. Bartell Environmental Engineer Eastern Research Group, Inc. kimberly.bartell@erg.com

Phone: 517

- 515

- 1721

From: Bartell, Kimberly To: al_woodruff@msn.com

Date: 12/18/13 4:19 PM Subject: Fwd: 2011 DMR Clarification for Chlorine Discharges

Mr. Woodruff,

I was given your contact information from Jennifer and wanted to follow up with you on the email I sent to her last Friday (see below). Please confirm the DMR data discussed below.

If you would like to discuss this over the phone, feel free to call me a t (517)

- 515

- 1721.

Thank you, Kimberly

---------------------------------------- Kimberly D. Bartell Environmental Engineer Eastern Research Group, Inc. kimberly.bartell@erg.com

Phone: 517

- 515

- 1721

>>> Kim berly Bartell 12/13/2013 6:10 PM >>> Dear Jennifer,

Thank you for your time on the phone today. 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 discharge monitoring reports for Cahaba Timber Co. (AL0055395). Here is some background on

what the information is used for.EPA reviews publicly

- available DMR data to fulfill its review obl igation 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 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 and the results in its 2013 Effluent Guidelines Program Plan scheduled for publication in the Federal Register in 2014. As part of the 2013 annual review, EPA is evaluating the data in discharge monitoring reports from 2011 and needs further information to complete the review. We would like to obtain additional information on the following 2011 discharge data for total

resi dual chlorine for your facility. Our records show the following values were discharged:

Total Residual Chlorine

Outfall Date Total Residual Chlorine

Concentration (mg/L) Wastewater Flow (MGD)

001 9/30/2011 24.1 0.78

001 12/31/2011 7.2 0.19

002 9/30/2011 9.24 0.78

002 12/31/2011 5.73 0.19

003 9/30/2011 33 0.78

003 12/31/2011 6.55 0.19

004 9/30/2011 18.4 0.78

004 12/31/2011 7.19 0.19

005 9/30/2011 8.89 0.78

005 12/31/2011 3.8 0.19

We appreciate your help in confirming if the above data are accurate, or if there are units errors

in the DMR data.

Please call me at (517) 515

- 1721 if you have any questions. If you would like to speak directly with EPA regarding this request, you can c ontact 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, Kimberly

---------------------------------------- Kimberly D. Bartell Environmental Engineer Eastern Research Group, Inc. kimberly.bartell@erg.com

Phone: 517

- 515

- 1721