Need 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 RECORD

 Incoming 

 Outgoing 

Date: 01/10/11 Time: 10:00 am

 pm 

Company Name: ExxonMobil Baton Rouge ERG Staff Name: Elizabeth Sabol 

Contact Name: George Graham Contact Phone Number: (225) 977-1455 

General Subject: 2009 TRI PAC Discharges 

TOPICS DISCUSSED AND ACTION TAKEN 

On January 10, 2011, I called ExxonMobil Baton Rouge to speak with G. Pietrogaleo regarding 2009 TRI PAC 

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. 

Called and left a message for G. Pietrogaleo on January 12, 2011 at 10:00 am. 

Called and left a message for G Pietrogaleo on January 17, 2011 at 11:00 am. 

George Graham returned my phone call on January 17, 2011 at 1:00 pm. I returned his call and explained that I 

was calling for some specific information on 2009 TRI PAC discharges reported by the facility. Mr. Graham 

asked that I send my questions via e-mail. Please see the attached e-mail correspondence. 
From: <george.a.graham@exxonmobil.com> 

To: "Elizabeth Sabol" <Elizabeth.Sabol@erg.com> 

Date: 1/18/2011 5:08 PM 

Subject: Re: Request for 2009 TRI Data Clarification 

Dear Ms. Sabol, 

Please find ExxonMobil's response to your five questions regarding the 

ExxonMobil Baton Rouge Chemical Plant's PAC discharges for TRI reporting 

year 2009 as requested in your email dated January 18, 2011. 

 1. Please confirm the pounds of PACS released in 2009: 1,000 lbs 

 Response: This is the estimated quantity of PACs reported in 

 Section 5.3 (Discharges to Receiving Streams or Water Bodies) of 

 the Form R. 

 2. Please explain how the PAC load is calculated. 

 Response: The following PACs are sampled monthly in our treated 

 wastewater effluent: 

 |------------------------------+------------+----------------+-------------| 

 | PAC | CAS No. | Avg. Conc. | Lbs | 

 | | | (ppb) | | 

 |------------------------------+------------+----------------+-------------| 

 |Benzo(a)anthracene | 56-55-3 | < D.L. (10.625)| 100 | 

 |------------------------------+------------+----------------+-------------| 

 |Benzo(a)pyrene | 50-32-8 | < D.L. (10.625)| 100 | 

 |------------------------------+------------+----------------+-------------| 

 |Benzo(b)fluoranthene | 205-99-2 | < D.L. (10.625)| 100 | 

 |------------------------------+------------+----------------+-------------| 

 |Benzo(k)fluoranthene | 207-08-9 | < D.L. (10.625)| 100 | 

 |------------------------------+------------+----------------+-------------| 

 |Chrysene | 218-01-9 | < D.L. (10.625)| 100 | 

 |------------------------------+------------+----------------+-------------| 

 |Dibenzo(a,h)acridine | 224-42-0 | < D.L. (10.625)| 100 | 

 |------------------------------+------------+----------------+-------------| 

 |Dibenzo(a,h)anthracene | 226-36-8 | < D.L. (10.625)| 100 | 

 |------------------------------+------------+----------------+-------------| 

 |Indeno(1,2,3-cd)pyrene |193-39-5 | < D.L. (10.625)| 100 | 

 |------------------------------+------------+----------------+-------------| 

 |7,12-Dimethylbenz(a)anthracene| 57-97-6 | < D.L. (21.25) | 200 | 

 |------------------------------+------------+----------------+-------------| 

 | PAC Category|(N590) | Total| 1000 | 

 |------------------------------+------------+----------------+-------------| 

 In 2009 reporting year, all analytical results were non-detect. 

 Per the EPA 1998 EPCRA Section 313 Questions and Answers Document 

 (Section 4, Q&A No. 472), 1/2 detection limit was used to 

 calculate PAC load to water using the annual average flowrate, 

 which is metered continuously. 

 3. Can you estimate which PACs were released? 

 Response: See response to Question #2 for list of PACs analyzed. 

 4. Is the mass released based on actual sampling data, and were PACs 

 detected? Or, were releases estimated based on values below the 

 detection limit? 

 Response: Our calculations are based on actual sample data. In 

 reporting year 2009, all analysis for the PACs listed above were 

 non-detect. PAC load was estimated using 1/2 the detection limit. 

 5. What is the source of the PACs in the wastewater? 

 Response: Potential sources of PACs in wastewater are from 

 residuals in the Olefins Cracking Process.

If you need additional information, please give me a call. 
Sincerely 

George A. Graham 

ExxonMobil Baton Rouge Complex SH&E Division 

Environmental Regulatory Compliance Programs Section Supervisor 

(225) 977-1455 phone 

(504) 352-5099 cell 

Protect Tomorrow. Today 

Are you doing your SPSAs? 

 

 "Elizabeth 

 Sabol" 

 <Elizabeth.Sab To 

 ol@erg.com> <george.a.graham@exxonmobil.com> 

 cc 

 <swietlik.william@epa.gov>, "Eleanor 

 01/18/2011 Codding" <Eleanor.Codding@erg.com>, 

 07:01 AM "Jessica Gray" 

 <Jessica.Gray@erg.com> 

 Subject 

 Request for 2009 TRI Data 

 Clarification 

 

George, 

Thank you for your time on the phone yesterday. 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 PAC 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. 

Specifically, we would like to clarify the amount of PACs reported to the 

2009 TRI. Please confirm/review the following data and questions below. 

1. Please confirm the pounds of PACs released in 2009: 1,000 pounds 

2. Please explain how the PAC load is calculated. 

3. Can you estimate which PACs were released? 

4. Is the mass released based on actual sampling data, and were PACs 

detected? Or, were releases estimated based on values below the detection 

limit? 

5. What is the source of the PACs in the wastewater? 
We appreciate your help in interpreting TRI data correctly. If you have any 

questions regarding this request, please call me at (703) 633-1659. 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. 

Thanks, 

Elizabeth 

Elizabeth A. Sabol 

Environmental Engineer 

Eastern Research Group, Inc. 

14555 Avion Parkway, Suite 200 

Chantilly, VA 20151 

elizabeth.sabol@erg.com 

Phone:703-633-1659