Need to return call by / at/between and

. Signature: Project No.: 0317.01.005.510 Page 1 of 2

Project Name: TRI20 11 

### CBI?
Yes
No TELEPHONE CALL RECOR D Incoming Outgoing Date: 01/08 /1 4 Time: 12:30 am
pm

Company Name: Millennium Inorganic Chemicals ERG Staff Name: Kimberly Bartell

Contact Name: Robert Schmude Contact Phone Number: ( 440 ) 994

- 1 581
General Subject: 2011 TRI Discharges



### TOPICS DISCUSSED AND ACTION TAKEN

Robert Schmude: Email = Robert.schmude@cristal.com , Phone = 440

- 994

- 1581.

On January 8, 2014 I called and left a message for Rob Schmude.

On January 15, 2014 I called and left a message for Mr. Schmude.

On January 17 th

, at 9:15 am, Mr. Schmude returned my call and requested an email with our questions. Please see attached emai l communication.

On January 20 th , at 2:30pm, I called Mr. Schmude and left a message asking if he received my email and when he thought he could get the data back to me.

Questions for Rob Schmude: 1. Dioxin and Dioxin Like Compounds for 44004SCMCH2900M

- What was the facility flow in 2009 and 2011? What caused the flow increase (increased production?)?

- Provide 2012 or 2013 TRI Data

- Is it just one outfall where sampling is taking place? Description of outfall?

- Previously didn’t report all congeners (2009 only c ongeners 7, 15, and 17 were reported in 2011 all congeners were reported). Why is this?

- Has the feedstock changed?

- What process conditions affect the concentration of congeners?

- Why were there no dioxin discharges prior to 2009?

2. Manganese and Manganese Co mpounds for 44004SCMCH2426M

- Actual flow values for 2009 and 2011?

- What cause the increase in flow besides the change in raw material? An increase in production?

From previous communication (Winter 2013):

On January 7, 2013 at 2pm, I called Millennium Ino rganic Chemicals to speak with George Armstrong and left

a message

. On January 16, 2013 , January 25, 2013 and February 1, 2013 I called George Armstrong and left a

message.

On February 1 st I also tried some other contacts found on the ECHO website. Jeff N ick is an Environmental Engineer but his phone number was not a working number. I was able to leave a message for Richard Hughes atNeed to return call by / at/between and

. Signature: 440

- 994

- 1721. On February 4 th , Rob Schmude returned my call and left a message (440

- 994

- 1581). I returned his call and left a message.

On February 6, Rob Schmude returned my call. We discussed the following data for the two Millennium Inorganic Chemicals facilities. Mr. Schmude also requested an email follow up with a summary of the data we discussed. Email = Robert.schmude@cristal.com , Phone = 440

- 994

- 1581. Please see attached email correspondence.

Mr. Schmude did not respond to my email so I called to verify he received it on 2/20/13. I left a message asking him to contact me wi th any questions. He responded to my email and confirmed the data we discussed.

1. Millennium Inorganic Chemicals A Cristal Co. TRI ID: 44004SCMCH2900M Dioxin and dioxin

- like compounds

- 2011 total discharges confirmed: 1.11 grams, 0.0024 pounds

- Confirme d 2011 dioxin distribution (see Inorganic Chemicals Category spreadsheet)

- The facility calculated dioxin discharges based off of quarterly sampling at the NPDES compliance point (final effluent)

- Non detect results are included as zeros in the d istribution

- There has been a slight increase in the dioxin concentrations as well as an increase in the flow from 2009

- 2011. This has caused the dioxin discharges to increase from 2009

- 2011. The dioxin compounds are a byproduct of the processing of raw m aterials, the amount discharged depends on the process conditions. The cause for the increase in dioxin compounds is not directly known at this time.

2. Millennium Inorganic Chemicals A Cristal Co. TRI ID: 44004SCMCH2426M Manganese and manganese compounds

- 2011 total discharge confirmed: 79,000 pounds

- The facility calculated manganese discharges based off of direct sampling at the NPDES compliance point (final effluent). The samples are taken once per week and they are 24 hour composite samples.

- Ther e has been an increase in flow and the raw material blend has changed (the concentration of manganese in the raw material blend has increased) , both factors have contributed to an increase in manganese discharges from 2009

- 2011.Email Communication with Millennium Inorganic Chemicals

From: Kimberly Bartell To: Robert Schmude Date: 1/22/14 1:52 PM Subject: Re: 2011 TRI Clarification for Dioxin and Manganese Discharges

Mr. Schmude,

Thank you very much for your responses. I will review the information and let you know if we have any further questions.

Thanks again, Kimberly

From: Robert Schmude To: Kimberly Bartell Date: 01/22/14 1:40 PM Subject: Re: 2011 TRI Clarification for Dioxin and Manganese Discharges

Responses in red below...

From: Kimberly Bartell [ mailto:Kimberly.Bartell@erg.com ]
Sent: Friday, January 17, 2014 9:58 AM

To: Robert Schmude
Cc: William Swietlik; Elizabeth Sabol; Kim Wagoner Subject: Re: 2011 TRI Clarification for Dioxin and Manganese Discharges

Mr. Schmude,

Thank you for your time on the phone this morning. As discussed, we are completing the 2013 Annual Review of industrial wastewater discharges and need some additional informati on. ERG requests this information on behalf of EPA under Contract No. EP

- C

- 12

- 021. Here is some background on what the information is used for.

EPA reviews publicly

- available TRI data to fulfill its review obligation under Section 304(b) of
the Clean Wa ter Act (CWA). 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 2013 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 2013 Effluent Guidelines Program Plan scheduled for publication inthe Federal Register in 2014. As part of the 2013 annual review, EPA is ev aluating the data

in TRI from 2011 and needs further information to complete the review.

As I have previously discussed with you, there are two Millennium Inorganic facilities. I've split

up our additional questions below.

1. Millennium Inorganic Chemicals A Cristal Co. TRI ID: 44004SCMCH2900M
Dioxin and dioxin

- like compounds

- Please explain why only three dioxin congeners were reported to TRI in 2009 but all 17 dioxin congeners were reported to TRI in 2011. Has the analyti cal method or feedstock changed? In 2011, the non

- detect data was inadvertently and erroneously reported using the minimum detection limit for all congeners. In 2009 and all other years, non

- detect data was reported as ‘0’. Therefore, the data for 2011 a ppears artificially high compared to others years.

- What is the reason that dioxin discharges were not reported to TRI prior to 2009? See response
above. We did report prior to 2009, the results were 0 or non detect

- Please list the process conditions a ffecting the concentration of dioxin congeners. It is believed that the formation of congeners occur within a very narrow temperature range immediately following the chlorination process. The congeners that are formed are of extremely small quantity.

- Provide the facility flow values for 2009 and 2011. What caused the flow increase? 2009 flow:
812.7 million gal/yr; 2011 flow: 867.5 million gal/yr. This is a slight increase in effluent flow; many factors influence volume of water flow, including proce ss rate, process conditions, and
volume of stormwater.

- Provide a description of the outfall where dioxin sampling is conducted. Sampling is conducted at the NPDES effluent compliance point prior to the mixing zone and discharge into
Lake Erie.

- Provi de any 2012 and 2013 dioxin TRI data. 2013 data is not yet available. 2012 dioxin to water was reported as 0.1436 grams.

2. Millennium Inorganic Chemicals A Cristal Co. TRI ID: 44004SCMCH2426M Manganese and manganese compounds

- Please provide the facility flow values for 2009 and 2011. 2009 flow: 1604 million gal/yr; 2011 flow: 1675 million gal/yr.

- What has caused the increase in flow? This is a slight increase in effluent flow; many factors
influence volume of water flow , including process rate, process conditions, and volume of

stormwater.

- Provide any 2012 or 2013 dioxin TRI data. 2013 data is not yet available. 2012 Mn to water was 53,463 lbs.

We appreciate your help in interpreting the data correctly. For referenc e, my previous emailcommunication with you is below. Please call me at (517) 515

- 1721 if you have any questions.

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

From: Kimberly Bartell To: Robert.schmude@cristal.com CC: Sabol, Elizabeth; Swietlik, William; Wagone r, Kim Date: 01/17/14 9:58 AM Subject: Re: 2011 TRI Clarification for Dioxin and Manganese Discharges

Mr. Schmude,

Thank you for your time on the phone this morning. As discussed, we are completing the 2013 Annual Review of industrial wastewater discharges and need some additional information. ERG requests this information on behalf of EPA under Contract No. EP

- C

- 12

- 02 1. Here is some background on what the information is used for.

EPA reviews publicly

- available TRI data to fulfill its review obligation under Section 304(b) of the Clean Water Act (CWA). The CWA requires EPA to annually review and, if appropriate,
revi se 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 2013 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 2013 Effluent Guidelines Program Plan scheduled for publication in the Federal Register in 2014. As part of the 2013 annual review, EPA is evaluating the data
in TRI from 2011 and needs further information to complete th e review.

As I have previously discussed with you, there are two Millennium Inorganic facilities. I've split

up our additional questions below.

1. Millennium Inorganic Chemicals A Cristal Co. TRI ID: 44004SCMCH2900M
Dioxin and dioxin

- like compounds

- Please explain why only three dioxin congeners were reported to TRI in 2009 but all 17 dioxin congeners were reported to TRI in 2011. Has the analytical method or feedstock changed?

- What is the reason that dioxin discharges were not reported to TRI prior to 2009?

- Please list the process conditions affecting the concentration of dioxin congeners.- Provide the facility flow values for 2009 and 2011. What caused the flow increase?

- Provide a description of the outfall where dioxin sampling is conducted.

- Provide any 2012 and 2013 dioxin TRI data.

2. Millennium Inorganic Chemicals A Cristal Co. TRI ID: 44004SCMCH2426M Manganese and manganese compounds

- Please provide the facility flow values for 2009 and 2011.

- What has caused the increase in flow?

- Provide any 2012 or 2013 dioxin TRI data.

We appreciate your help in interpreting the data correctly. For reference, my previous email communication with you is below. Please call me at (517) 515

- 1721 if you have any questions. 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. Bartell Environmental Engineer Eastern Research Group, Inc. kimberly.bartell@erg.com
Phone: 517

- 515

- 1721 >>> Kimberly Bartell 2/6/2013 2:07 PM >>> Dear Mr. Schmude,

Thank you for your time on the phone this morning. As discussed, EPA has requested clarification of 2011 TRI data as part of our 2013 annual review of industrial discharges under
Section 304 of the Clean Water Act. ERG req uested clarification for Millennium Inorganic Chemicals discharges of dioxin and manganese on behalf of EPA under Contract No. EP

- C

- 12

- 021. Please see below for further information.

EPA, Office of Water (OW), reviews TRI data to fulfill its review oblig ation 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 t he discharge of pollutants to waters of the U.S. from various categories of industrial facilities. EPA is currently conducting its 2013 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 thisreview and the results in its 2013 Effluent Guidelines Program Plan scheduled for publication in

the Federal Register sometime in 2013 or 2014.

Below is a summary of the data discussed during our call this morning. Please let me know if any of this data does not match the TRI data submitted in 2011.

1. Millennium Inorganic Chemicals A Cristal Co. TRI ID: 44004SCMCH2900M
Dioxin and di oxin

- like compounds

- 2011 total discharges confirmed: 1.11 grams, 0.0024 pounds

- Confirmed 2011 dioxin distribution, see attached spreadsheet.

- The facility calculated dioxin discharges based off of quarterly sampling at the

NPDES compliance point (fin al effluent)

- Non detect results are included as zeros in the distribution

- There has been a slight increase in the dioxin concentrations as well as an increase in the flow
from 2009

- 2011. This has caused the dioxin discharges to increase from 2009

- 2011. The dioxin compounds are a byproduct of the processing of raw materials, the amount discharged depends on the process conditions.

2. Millennium Inorganic Chemicals A Cristal Co. TRI ID: 44004SCMCH2426M Manganese and manganese compounds

- 2011 total dis charge confirmed: 79,000 pounds

- The facility calculated manganese discharges based off of direct sampling at the NPDES compliance point (final effluent). The samples are taken once per week and they are 24 hour composite samples.

- There has been an inc rease in flow and the raw material blend has changed, both factors have contributed to an increase in manganese discharges from 2009

- 2011.

We appreciate your help in interpreting TRI data correctly. If you have any questions, please call me at (517) 515

- 1721. If you would like to speak directly with EPA regarding this request, you can contact William F. Swietlik of EPA's Office of Water/Engin eering Analysis Division by phone at (202) 566

- 1129 or by email: swietlik.william@epa.gov

.

Thank you, Kimberly

---------------------------------------- Kimberly D. Bartell Environmental Engineer

Eastern Res earch Group, Inc. kimberly.bartell@erg.com
Phone: 517

- 515

- 1721