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: 01/21/11 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 information 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 back or pass 

my information to the correct personnel for TRI data. 

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 TRI PAC discharges reported by the facility. Mr. Smith 

asked that I send my questions via e-mail so that he could gather the information. Please see the attached 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 have 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 questions below, with my responses in blue: 

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

Yes. 

2. Please explain how the PAC load is calculated. 

The PAC loading is calculated by multiplying the average 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 monthly. 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 detected in 

intake water, resulting in a final result of 358 lbs (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)fluorene, 

Benzo(a)phenanthrene, Benzo(a)pyrene, Dibenzo(a,h)anthracene, and Indeno(1,2,3-cd)pyrene. 

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? 
The PAC data is based on results above the detection limit. In the event results are below the detection limit, they are 

counted as zero (for example in the intake). 

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

The Mountain State Carbon Follansbee facility produces 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 constitutents. 

I trust this information satisfies your request. Let me know if you need any clarification on the above. 

Sincerely. 

Patrick Smith

From: Kimberly Landick 

To: patrick.smith@severstalna.com 

CC: Codding, Eleanor; Gray, Jessica; swietlik.william@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 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 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 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: 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 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) 633-1119. 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. 

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
PAC Distribution from Mountain State DMR Sampling Data

PARAMETER Jan TWF Feb TWF Mar TWF Apr TWF May TWF Jun TWF Jul (TWF) Aug (TWF) Sep (TWF) Oct (TWF) Nov (TWF) 

Benzo(a)anthracene 3.7220 2.83610 3.16537 3.97386 5.17805 6.19264 5.07119 5.93245 2.98680 4.84159 5.64585 Benzo(a)pyrene 29.3663 29.52447 28.06253 23.40056 23.57431 25.78671 26.27880 25.29146 10.55286 19.54990 24.81594 Benzo(b)fluoranthene 6.7913 8.24345 7.42515 4.48019 6.30482 6.88979 7.14665 6.27031 3.21429 6.32687 7.35977 Benzo(k)fluoranthene 2.8159 3.37232 3.19454 2.03645 3.50268 2.75592 2.68714 3.22473 18.59699 2.67961 2.98369 Dibenz(a,h)anthracene 1.8221 1.19905 1.81312 0.91640 2.45188 1.01969 2.51562 2.95600 0.57398 7.07120 4.17717 Fluoranthene 0.0003 0.00020 0.00018 0.00018 0.00024 0.00031 0.00026 0.00031 0.00016 0.00032 0.00034 Indeno(1,2,3-cd)pyrene 7.1226 6.44488 6.99346 12.72780 6.83022 6.88979 6.00319 5.46412 2.52552 4.46602 3.77934 Phenanthrene 0.0000 0.00002 0.00003 0.00005 0.00003 0.00003 0.00005 0.00013 0.00004 0.00054 0.00014 TOTAL 51.64 51.62 50.65 47.54 47.84 49.53 49.70 49.14 38.45 44.94 48.76 Pounds Released 360Original TWPE 36,237.60Average TWF 49.35Average TWPE 17,766.96Maximum TWF 51.64Maximum TWPE 18,590.60

TRI2008 TWF Calculated TWF

100.66 51.64

TWPE Using 

TRI 2008 TWF

TWPE using 

Calculated TWF Notes:

TRI2008 Pounds 360 36,237.60 18,590.60 Reported LBY and automatic TRI TWF

Revised Pounds 184.69 18,590.60