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: 

### 01/21 /11 Time: 

### 8:30 am pm

Company Name: 

### Charter Steel Risingsun ERG Staff Name: 

### Kimberly Landick

Contact Name: 

### Tammy Bukach Contact Phone Number: 

### ( 419) 457

- 4002 General Subject: 

### 2009 TRI Zinc and Zinc Compounds Discharges



## TOPICS DISCUSSED AND ACTION TAKEN

On January 21, 2011, I called Charter Steel Risingsun to speak with Dennis Woods regarding 2009 TRI Zinc and Zinc Compounds discharges. I left a message stating my name , the reason for calling, and if he would call me back or pass my information to the correct personnel for TRI data.

Dennis Woods passed on my information to Tammy Bukach, and Environmental Engineer at Charter Steel. Her phone number is (216) 429-8904. Tammy returned my phone call on January 21, 2011 at 11:40am. She confirmed that the reported load was correct and that they had calculated it based on monitoring data. She also stated that all the concentrations were above the detection limit and that none of them were below the detection limit. When asked why the TRI value had increased significantly, she said that the concentration they discha rge increased considerably so there is a higher amount of zinc and zinc compounds in the wastewater. She did not give a reason why the concentration had increased by so much. The source of the zinc and zinc compounds is from a zinc phosphate cleaning line and the load was calculated using the flow based on a discharge meter reading at the outflow. The outflow where the fl ow was measured was right at the point where the zinc was discharged. I thanked her for her time and told her I would call back if I had further questions.

I called Tammy back at 12:45pm on January 21, 2011. I asked her why the concentration had increased by so much and she said they didn’t have a reason and weren’t exactly sure. They do have a permit for effluent discharge and there are z inc permit levels in the permit. I asked if I could get a copy of the concentration and flow data from 2008-present and she asked for a written request. She also mentioned that due to the high zinc and zinc compounds concentration in 2009 they installed wa ter system upgrades which are now complete. She stated that the samples taken in December 2010 were well below the permit levels and also that they only sample twice a year. I thanked her for her time and then followed up with an email sent at 4:30pm on January 21, 2011. Please see attached email correspondence.

On January 27, 2011 I received an e- mail response from Tammy asking for clarification on which data we were looking for. I called Tammy on January 28, 2011 at 11:25am and left her a message asking her to call me back and telling her that I would send her an e-mail with a response to her question. I sent an e-mail at 11:30am on January 28, 2011.

On February 1 st 

### , 2011 at 2:30pm I called Tammy and left a message asking if she had received my e

- mail and if she had any questions.

On February 3 rd 

### , 2011 at 12:15pm I called Tammy and left a message asking if she had received my e- mail and if she had any questions.Need to return call by / at/between and

. Signature: 

### On February 8 th 

### , 2011 at 10:33am I called Tammy and left a message asking if she had received my e

- mail and if she had any questions.From: Bukach, Tammy <BukachT@chartersteel.com>

Received: 3/2/11 7:56 AM To: Landick, Kimberly Subject: RE: Request for 2009 TRI Data Clarification



### K im,

Please feel free to include Charter Steel’s data in the public docket. If you need anything else, please let
me know.

Thanks Tammy

From: Kimberly Landick [mailto:Kimberly.Landick@erg.com] Sent: Tuesday, March 01, 2011 11:40 AM To: Bukach, Tammy Subject: RE: Request for 2009 TRI Data Clarification

Hi Tammy,

Thank you for your information that you have provided. EPA would like to include these data as part of their public docket, to show why they are adjusting the discharged pounds of Zinc due to errors in the calculation method. The public docket is available at http://www.regulations.gov, Docket ID EPA-HQ-OW2008-0517. 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 Zinc information for Charter Steel that you provided in the publicdocket, we would need your permission to ignore the auto-disclaimer generated at the bottom of this email:



### "The information contained in this message and any attachments are for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any review, retransmission, dissemination or other use of this message by persons or entities other than the intended recipient is prohibited. If you receive this information in error please contact the sender and permanently delete from all storage media without forwarding or retaining a copy."

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: Bukach, Tammy <BukachT@chartersteel.com> Received: 2/16/11 3:58 PM To: Landick, Kimberly Subject: RE: Request for 2009 TRI Data Clarification



### Kim,

I am sorry, but I only work on Mondays and Wednesdays so it takes a little longer to get to everything. Let me give you a little bit of background to help you with this. We have a storm water pond onsite and a storm water permit. The only items that are stored outside are the steel coils – what we call greenrod (unprocessed coils). We are required to sample this pond once a year. We are not required to monitor the flow from the pond. For 2008 and 2009, there was little to no discharge from that pond so we were not able to sample it. The discharge from the pond is approximately 5 feet from the bottom of the pond. So, it doesn’t discharge unless it is completely full. We had two very dry summers in 2008 and 2009 and there was little discharge and no sampling. To determine the discharge from the pond for the TRI Report, we utilize the sampling data and calculate the storm water runoff (based on rainfall, land area, and runoff coefficient). Because we were not able to sample the discharge for the last two years, we used data from 2007 to make these calculations. Therefore, we have no sampling data or flow data for the storm water discharge, unless you want the calculation for the storm water runoff. We figured this would be very conservative and it was better to be conservative than to under report. Only storm water is directed to the pond. All waste water is discharged to the POTW.

As far as the discharge to the POTW from our waste water treatment goes, we are required to sample the two outfalls from our site semiannually. We have an outfall (S100) at the discharge from waste water treatment. We have another outfall (S200) located at the discharge to the POTW. S200 is the metered discharge and we use the volume of water from this discharge for our calculations. Other water discharges to this outfall also, such as restrooms, showers, etc. If needed, we will resample the outfalls. We use the average of all sampling events for a given year and the total discharge from the site (outfall S200) to calculate the discharges to the POTW. I have attached the sampling data and flow data for 2008 and 2009 to this email. If you have any questions, please feel free to contact me.

### Please find the answers to your questions below:

1. What is your National Pollutant Discharge Eliminatio n System (NPDES) Permit ID?

Our NPDES Permit ID is - 2 GR00414*DG. We are covered under Ohio’s Industrial Storm Water General Permit.

2. W hat are your permit limits for zinc?

I am not sure what permit limit you are referring to for this one. However, we do not have any permit limits for storm water. For our discharge to the City of Fostoria, we have a the following limits:

Outfall S100 (discharge from waste water treatment) – 2.61 mg/l (daily max) and 1.48 (monthly average)

Outfall S200 (site effluent discharge) – 4.588 mg/l (daily max)
3 . What is the water system upgrade that you referenced earlier on the phone?

In 2010, Charter Steel modified the waste water trea tment with a pH adjustment system. The system increases the pH of the water so that zinc will drop out of solution. The system then adjusts the pH back down (so it is in line with our permit limits). In addition, a pump and bag filter were also installed to filter and pump the water to a polishing system before discharge. These changes gave us better pH control to our system and allows us to drop zinc out of solution prior to discharge.

4. W hat processes and/or unit operations existed before the water system upgrades and what processes and/or unit operations were installed during the water system upgrades? There were no changes to the process or unit operati ons before or after the system upgrade. The system was upgraded to enhance the waste water system and allow Charter Steel better control over the system and the discharge.



### If you have any other questions, please let me know. I am in on Mondays and Wednesdays, but I do check my email while I am out.

Thanks

Tammy S. Bukach

F rom: Kimberly Landick Sent: 1/28/2011 11:32:32 AM To: Bukach, Tammy Cc: Codding, Eleanor; Gray, Jessica; Sabol, Elizabeth Subject: RE: Request for 2009 TRI Data ClarificationHi Tammy,

We're interested in the following zinc and zinc compound releases from TRI 2009: 2,100,759.9 pounds transferred to the POTW and 4,570 pounds discharged to receiving streams. As previously stated we would like the concentration and flow data used to calculate the zinc and zinc compound POTW transfers and receiving stream discharges from 2008 through current. Additionally, we have the following additional questions below.

1. What is your National Pollutant Discharge Elimination System (NPDES) Permit ID?

2. What are your permit limits for zinc?

3. What is the water system upgrade that you referenced earlier on the phone?

4. What processes and/or unit operations existed before the water system upgrades and what processes and/or unit operations were installed during the water system upgrades?

Please let me know if you have any further questions, 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: Bukach, Tammy <BukachT@chartersteel.com> Received: 1/27/11 10:16AM To: Landick, Kimberly Subject: RE: Request for 2009 TRI Data Clarification



### Kim,

C ould you please verify for me the total amounts of zinc discharges you are referring to for the information below. I would also like to know if you are looking at all zinc and zinc compound discharges or if there are certain ones in particular you are referring to for the information. We reported zinc and zinc compound discharges for onsite releases, offsite release (Landfills), and other offsite releases (city of Fostoria POTW). That information will help me understand what information you need.

Thank you,

Tammy S. BukachFrom: Kimberly Landick [mailto:Kimberly.Landick@erg.com]

Sent: Friday, January 21, 2011 4:28 PM To: Bukach, Tammy Cc: sweitlik.william@epa.gov; Eleanor Codding; Jessica Gray Subject: Request for 2009 TRI Data Clarification

Tammy,

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 zinc and zinc 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 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 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. Based on our discussion today we are requesting a copy of the concentration and flow data from the 2008 through current zinc and zinc compounds discharges. Additionally, please review the questions below.

1. What is your National Pollutant Discharge Elimination System (NPDES) Permit ID? 2. What is your permit limit for Zinc? 3. What is the water system upgrade that you referenced earlier on the phone? 3. What processes/unit operations existed before the water system upgrades and what processes/unit operations were installed during the water system upgrades?

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: 703-633-1119Data from Chater Steel:

Date Zn (mg/L)

2/18/2008 1.65 6/9/2008 0.497 11/25/2008 0.567 Average (2008) 0.905

6/10/2009 10.6 6/26/2009 0.53 12/1/2009 12.7 1/12/2010 5.73 Average (2009) 7.390

Facility contact provided information that they divided mg/year by 1000 to convert to kg/year when it should be 1,000,000. The TWF for Zinc is 0.046886.

Zinc and Zinc Compounds 2009 Pounds Released to POTW 2,100,759.90 Pounds Directly Discharged 4570.85

Calculation Units Flow 34,074,392 gal/year Average Zn Conc 7.390 mg/L
Total Load Calculation released to POTW 128,985,203.48 L/year 953,200,653.69 mg/year
953.20 kg/year 2,100.85 lbs/year

Reported LBY 2,100,759.92 POTW Removal 0.79
TWF 0.05
TWPE 20,546.31
New LBY 2,100.76 Divided reported LBY by 1,000 to convert from g/yr to kg/yr.
New TWPE 1,584.59

Reported LBY 4,570.85 Reported TWF 0.05
TWPE 214.31
New LBY 4.57 Divided reported LBY by 1,000 to convert from g/yr to kg/yr.
New TWPE 0.21 2009

ERG Load Calculation Description



### ERG Zinc Calculations

Indirect Discharges 2008

Direct Discharges Convert flow to L/year by multiplying by 3.7854 L/gal Multiply L/year flow by average Zn concentration

Convert to lbs/year by multiplying by 2.204 lbs/kg To convert mg/year to kg/year the facility divided by 1000 instead of 1,000,000. Convert to kg/year by dividing by 1,000,000