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 RECOR D Incoming Outgoing Date: 

### 01/21/11 Time: 

### 8:30 am

pm

Company Name: 

### Mountain State Carbon ERG Staff Name: 

### Kimberly Landick

Contact Name: 

### Patrick Smith Contact Phone Number: 

### (740)283-5542

General Subject: 

### 2009 TRI PAC Discharges



## TOPICS DISCUSSED AND ACTION TAKEN

On January 21, 2011, I called Mountain State Carbon to speak with Bud Smith regarding 2009 TRI PAC discharges. Bud Smith gave me the contact informat ion for Patrick Smith, the correct contact for TRI data. I called Patrick and left a message stating my name, the reason for calling, and if he could call me bac k or pass my information to the correct personnel for TRI dat a.

Patrick Smith returned my phone call on January 21, 2011 at 9:00am. I returned his call and explained that I was calling for some specific information on 2009 T RI PAC discharges reported by the facility. Mr. Sm ith asked that I send my questions via e-mail so that h e could gather the information. Please see the atta ched e-mail correspondence.

### From: Kimberly Landick

To: Patrick.Smith@severstalna.com
Sent: 1/28/2011 11:53:17 AM Subject: RE: Request for 2009 TRI Data Clarification

Hi Patrick,

Thank you for this information. At this point we ha ve no further questions but will contact you if additional questions arise.

Thanks, 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

>>> "Smith, Patrick J." < Patrick.Smith@severstalna.com > 1/21/2011 12:09 PM >>>
Ms. Landick,

To answer your request, I’ve re-copied your questio ns below, with my responses in blue:

1. Please confirm the pounds of PACs released i n 2009: 360 pounds

Yes.

2. Please explain how the PAC load is calculate d.

The PAC loading is calculated by multiplying the av erage flowrate at outfall 205 (our biological WWTP) by the average

concentration of PACs in the outfall effluent. Of the list of 21 chemicals considered PACs by the TRI report, 8 have

been found in our effluent and are tested for month ly. The calculation was 0.7 Million gallons/day x 365 Days x 8.34 Lbs/gallon x 0.18 parts per million PACs = 383 lbs. From this amount was subtracted 25 lbs. of PACs d etected in intake water, resulting in a final result of 358 lb s (or 360 lbs in two significant figures).

3. Can you estimate which PACs were released?

The 8 PACs detected are Benzo(a)anthracene, Benzo(b )fluoranthene, Benzo(k)fluoranthene, Benzo(j,k)fluo rene, Benzo(a)phenanthrene, Benzo(a)pyrene, Dibenzo(a,h)a nthracene, and Indeno(1,2,3-cd)pyrene.

4. Is the mass released based on actual samplin g data, and were PACs detected? Or, were releases e stimated based

on values below the detection limit?The PAC data is based on results above the detectio n limit. In the event results are below the detect ion limit, they are

counted as zero (for example in the intake).

5. What is the source of the PACs in the wastew ater?

The Mountain State Carbon Follansbee facility produ ces coke and coke byproducts, including coal tar. The PACs are constituents of coal tar, and wastewater contacting the tar and treated downstream may contain these c onstitutents. I trust this information satisfies your request. L et me know if you need any clarification on the abo ve. Sincerely.

Patrick Smith

From: Kimberly Landick

To: patrick.smith@severstalna.com

CC: Codding, Eleanor; Gray, Jessica; swietlik.willia m@epa.gov

Date: 1/21/2011 9:58 AM Subject: Request for 2009 TRI Data Clarification

Patrick,

Thank you for your time on the phone this morning. As discussed, EPA is requesting clarification of 20 09 TRI data as part of our 2011 annual review of indus trial discharges under Section 304 of the Clean Wat er Act. I am writing to request clarification of PAC d ischarges from the Mountain State Carbon, LLC,
Follansbee Plant, 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 obligati on 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-bas ed regulations, called “effluent limitations guideline s” or "effluent guidelines,” that limit the dischar ge of pollutants to waters of the U.S. from various categ ories of industrial facilities. EPA is currently c onducting its 2011 annual review of existing effluent guideli nes and potential industrial guidelines which may n eed to be included (see http://www.epa.gov/guide/304m/ for further information). EPA will discuss this re view

and the results in its 2011 Effluent Guidelines Pro gram Plan scheduled for publication in the Federal Register in 2011.

As part of the 2011 annual review, EPA is evaluatin g the data reported to the 2009 TRI and needs furth er information to complete the review. Specifically, w e would like to clarify the amount of PACs reported to the 2009 TRI. Please confirm/review the following d ata and questions below.

1. Please confirm the pounds of PACs released in 20 09: 360 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 da ta, 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 co rrectly. If you have any questions regarding thisrequest, please call me at (703) 633-1119. If you would like to speak directly with EPA regarding thi s

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, Kimberly

---------------------------------------- Kimberly D. Landick Environmental Engineer Eastern Research Group, Inc. 14555 Avion Parkway, Suite 200 Chantilly, VA 20151 kimberly.landick@erg.com

Phone: 703-633-1119PAC Distribution from Mountain State DMR Sampling DataPARAMETER Jan TWF Feb TWF Mar TWF Apr TWF May TWF Jun TWFJul (TWF) Aug (TWF) Sep (TWF) Oct (TWF) Nov (TWF) Dec (TWF) AVG 2009TWFTRI TWFBenzo(a)anthracene3.7220 2.83610 3.16537 3.97386 5.17805 6.19264 5.07119 5.93245 2.98680 4.84159 5.64585 5.14545 4.15314 36.26Benzo(a)pyrene29.3663 29.52447 28.06253 23.40056 23.57431 25.78671 26.27880 25.29146 10.55286 19.54990 24.81594 25.71137 25.97465 100.66Benzo(b)fluoranthene6.7913 8.24345 7.42515 4.48019 6.30482 6.88979 7.14665 6.27031 3.21429 6.32687 7.35977 6.96126 6.89917 30.66Benzo(k)fluoranthene2.8159 3.37232 3.19454 2.03645 3.50268 2.75592 2.68714 3.22473 18.59699 2.67961 2.98369 3.96405 4.24711 30.66Dibenz(a,h)anthracene1.8221 1.19905 1.81312 0.91640 2.45188 1.01969 2.51562 2.95600 0.57398 7.07120 4.17717 2.32042 1.72479 30.66Fluoranthene0.0003 0.00020 0.00018 0.00018 0.00024 0.00031 0.00026 0.00031 0.00016 0.00032 0.00034 0.00025 0.00023 0.829Indeno(1,2,3-cd)pyrene7.1226 6.44488 6.99346 12.72780 6.83022 6.88979 6.00319 5.46412 2.52552 4.46602 3.77934 5.22095 6.35354 30.66Phenanthrene0.0000 0.00002 0.00003 0.00005 0.00003 0.00003 0.00005 0.00013 0.00004 0.00054 0.00014 0.00002 0.00003 0.295TOTAL51.64 51.62 50.65 47.54 47.84 49.53 49.70 49.14 38.45 44.94 48.76 49.32 49.35Pounds Released360Original TWPE36,237.60Average TWF49.35Average TWPE17,766.96Maximum TWF51.64Maximum TWPE18,590.60TRI2008 TWF Calculated TWF100.66 51.64TWPE UsingTRI 2008 TWFTWPE usingCalculated TWF Notes:TRI2008 Pounds360 36,237.60 18,590.60 Reported LBY and automatic TRITWFRevised Pounds184.69 18,590.60