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

Project No.: 0172.08.005.603 Page 1 of 1

Project Name: DMR2009 CBI?

Yes

No

TELEPHONE CALL RECORD

Incoming

Outgoing

Date: 02/24/11 Time: 9:53 am

pm

Company Name: Clean Harbors Baton Rouge ERG Staff Name: Kimberly Landick

Contact Name: Billy Clark Contact Phone Number: (225) 778-3570

General Subject: 2009 DMR Bendizine Discharges

TOPICS DISCUSSED AND ACTION TAKEN

On February 24, 2011 at 9:53am I called Clean Harbors Baton Rouge and spoke with John Arbuthnot (225-778-

3596). He requested an e-mail confirming who we are before we talk on the phone. Mr. Arbuthnot also 

mentioned that I will be talking to Billy Clark (225-778-3570) about DMR data. He requested an e-mail sent to 

arbuthnot.john@cleanharbors.com (John Arbuthnot) and clarkwj@cleanharbors.com (Billy Clark). I sent an email at 3:15pm on February 24, 2011. Please see attached e-mail correspondence. 

On March 1, 2011 at 4pm I called John Arbuthnot and asked if he received my e-mail. He said that he had 

gotten my e-mail and that Billy Clark will be getting back to me soon. 

On March 2, 2011 at 2:11pm I called Billy Clark and left a message asking him to return my call. 

On March 4, 2011 at 1:05pm I called Billy Clark and left a message asking him to return my call. 

On March 7, 2011 at 3:51pm I called Billy Clark and left a message asking him to return my call. At 3:52pm I 

called John Arbuthnot and told him that Mr. Clark had not gotten back to me yet and that I needed to wrap up 

this information as soon as possible. He apologized and told me that one of them would be getting back to me 

on Tuesday, March 8th, 2011. 

On March 8, 2011 at 3:34pm I called Billy Clark and left a message asking him to return my call. 

On March 9, 2011 at 2:18pm Billy Clark returned my call and apologized for not getting back to me sooner. He 

stated that the BDL indicator should be added to the Dec. 2009 benzidine concentration. He also stated that Dec 

2009 was higher than normal due to dilution factors. The results came back non-detect but he felt comfortable 

reporting that he knew the value was less than 1.584 lbs/day. He also stated that their permit limit for flow is 0.7 

MGD. None of the flows for 2009 exceed this value. I thanked him for his time and told him I’d call back with 

any further questions. 
E-mail Correspondence with Clean Harbors:

From: Kimberly Landick

To: Arbuthnot.john@cleanharbors.com; clarkwj@cleanharbors.com

CC: Codding, Eleanor; Gray, Jessica, Swietlik, William

BC: Landick, Kimberly; Sabol, Elizabeth

Sent: 2/24/11 3:18:24 PM

Subject: DMRs Clarification Needed for Clean Harbors Baton Rouge

Dear Mr. Arbuthnot,

Thank you for your time on the phone this morning. Eastern Research Group, Inc. (ERG) under EPA 

Contract No. 68-C-02-095 is e-mailing you on EPA’s behalf to request clarification of 2009 discharge 

monitoring reports for the Clean Harbors Baton Rouge in Baton Rouge, LA (LA0038245). 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. 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 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 December 2011. As part of the 2011 annual review, 

EPA is evaluating the data in discharge monitoring reports from 2009 and needs further information to 

complete the review.

We would like to obtain additional information on the following quantity data for Benzidine discharges 

from your facility. Our records show the following quantity was discharged:

Outfall 001:

Benzidine (Dec 2009): 1.584 lbs/day

Additionally, the below detection limit symbol is missing from Dec 2009. Was the quantity reported below 

the detection limit?

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

DMR data, as we expect.

Please call me at (703) 633-1119 when you have gathered this information 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,

Kimberly

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

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