Need to return call by / at/between and . Signature:

Project No.: 0172.08.005.603 Page 1 of 1

Project Name: DMR2009 CBI?

Yes

No

TELEPHONE CALL RECORD

Incoming

Outgoing

Date: 02/24/11 Time: 9:15 am

pm

Company Name: Bulk Plant Grayson ERG Staff Name: Kimberly Landick

Contact Name: Jory Becker Contact Phone Number: (502)-564-3410

General Subject: 2009 DMR Flow Values and Units

TOPICS DISCUSSED AND ACTION TAKEN

On February 24, 2011 I called the KY Department of Environmental Protection and spoke with Morgan 

Elliston. She stated that they needed everything in writing and to e-mail her at morgan.elliston@ky.gov. At 

9:20am I left a message for Jory Becker (contacted in 2008) explaining that we needed to confirm some 2009 

DMR flows and to call me back. 

At 11:05am on February 25, 2011, Jory Becker called back and left a message. At 11:08am I returned Jory’s 

call and he confirmed the following values:

Benzene: 20090331 6.4 mg/L (avg) and 6.4 mg/L (max)

20090930 1.8 mg/L

Flow: 20090331 4320 MGD (avg) and 144 MGD (max)

20090930 4320 MGD (avg) and 144 MGD (max)

He was not aware why the flow values differed significantly. He told me to e-mail Morgan Elliston and request 

a copy of the permit. I e-mailed Ms. Elliston on March 2, 2011 at 2:20pm, see attached e-mail correspondence. 

On March 3, 2011 I called Charles Phillips, the facility contact, at 859-625-8163. He said that he was out of the 

office but to send him an e-mail with a description of the information I am looking for and he would get back to 

me on Monday, March 7. I e-mailed him the information on March 4, 2011 at 1:35pm at 

charles_phillips@shieldmw.com. 

On March 7, 2011 at 4:09pm I called Charles Phillips to see if he had received my e-mail and reviewed it. He 

said that he had gathered the information today but hadn’t had a chance to get back to me. He stated that the 

technician entering the data misunderstood the units and reported MGD as gallons per month so all maximum 

values are multiplied by 30 for a gallon per month value (recorded in the average column). He also stated that 

units should be GPD instead of MGD. 

On March 8, 2011 at 10:07am I called Charles Phillips and asked him to clarify what he meant by 

misunderstanding the units. He confirmed that the maximum values are really the daily max for a month (during 

a rain event) and should be GPD instead of MGD. They then multiplied those values by 30 for a gallon per 

month value, assuming the maximum flow for 30 days. He also stated that the concentrations may be high for 

this permit because they include a significant amount of offsite roadway property that drains into the facility’s 

storm water discharge. This is most likely the reason that the Benzene concentrations are elevated. I thanked 

him for his time and told him I’d call back with any further questions. 
Need to return call by / at/between and . Signature:

Project No.: 0172.08.005.603 Page 1 of 1

Project Name: DMR2009 CBI?

Yes

No

TELEPHONE CALL RECORD

Incoming

Outgoing

Date: 02/24/11 Time: 9:15 am

pm

Company Name: Bulk Plant Flemingsburg ERG Staff Name: Kimberly Landick

Contact Name: Jory Becker Contact Phone Number: (502)-564-3410

General Subject: 2009 DMR Flow Values and Units

TOPICS DISCUSSED AND ACTION TAKEN

On February 24, 2011 I called the KY Department of Environmental Protection and spoke with Morgan 

Elliston. She stated that they needed everything in writing and to e-mail her at morgan.elliston@ky.gov. At 

9:20am I left a message for Jory Becker (contacted in 2008) explaining that we needed to confirm some 2009 

DMR flows and to call me back. 

At 11:05am on February 25, 2011, Jory Becker called back and left a message. At 11:08am I returned Jory’s 

call and he confirmed the following values:

Benzene: 20090331 2.7 mg/L

Flow: 20090331 2160 MGD (avg) and 72 MGD (max)

20090630 4.320 MGD (avg) and 144 MGD (max)

He was not aware why the flow values differed significantly. He told me to e-mail Morgan Elliston and request 

a copy of the permit. I e-mailed Ms. Elliston on March 2, 2011 at 2:20pm, see attached e-mail correspondence. 

On March 3, 2011 I called Charles Phillips, the facility contact, at 859-625-8163. He said that he was out of the 

office but to send him an e-mail with a description of the information I am looking for and he would get back to 

me on Monday, March 7. I e-mailed him the information on March 4, 2011 at 1:35pm at 

charles_phillips@shieldmw.com. 

On March 7, 2011 at 4:09pm I called Charles Phillips to see if he had received my e-mail and reviewed it. He 

said that he had gathered the information today but hadn’t had a chance to get back to me. He stated that the 

technician entering the data misunderstood the units and reported MGD as gallons per month so all maximum 

values are multiplied by 30 for a gallon per month value (recorded in the average column). He also stated that 

units should be GPD instead of MGD. 

On March 8, 2011 at 10:07am I called Charles Phillips and asked him to clarify what he meant by 

misunderstanding the units. He confirmed that the maximum values are really the daily max for a month (during 

a rain event) and should be GPD instead of MGD. They then multiplied those values by 30 for a gallon per 

month value, assuming the maximum flow for 30 days. I thanked him for his time and told him I’d call back 

with any further questions. 
E-mail Correspondence with the State of Kentucky:

From: Kimberly Landick

To: morgan.elliston@ky.gov 

Sent: 3/4/11 9:06:54 AM

Subject: RE: Request for Facility Permits

Ms. Elliston,

Thank you for this information. At this point we have no further requests but will contact you if we need 

additional information. 

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

From: "Elliston, Morgan (EEC)" <Morgan.Elliston@ky.gov>

To: Landick, Kimberly

Sent: 3/3/11 10:20 AM

Subject: RE: Request for Facility Permits

Ms. Landick,

I have attached your request.

Thank you,

Morgan P. Elliston

KY Division of Water

200 Fair Oaks Lane

Frankfort, KY 40601

Phone: 502-564-3410 ext. 4820

Fax: 502-564-0111

From: Kimberly Landick

To: morgan.elliston@ky.gov

CC: Codding, Eleanor; Gray, Jessica, Swietlik, William

BC: Landick, Kimberly; Sabol, Elizabeth

Sent: 3/2/11 2:32:02 PM

Subject: Request for Facility Permits

Dear Ms. Elliston, 
Eastern Research Group, Inc. (ERG) under EPA Contract No. 68-C-02-095 is e-mailing you on EPA’s 

behalf to request a copy of the each permit for Bulk Plant Grayson #266 (KY0027910) and Bulk Plant 

Flemingsburg #39 (KY0039357). These permits will be used for clarification of 2009 discharge monitoring 

reports. Below is some background on what the information is used for.

EPA reviews publicly-available DMR 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 December 2011. As part of the 2011 annual review, 

EPA is evaluating the data in discharge monitoring reports from 2009 and needs further information to 

complete the review.

 

We appreciate your assistance, please call me at (703) 633-1119 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. Landick

Environmental Engineer

Eastern Research Group, Inc. 

14555 Avion Parkway, Suite 200

Chantilly, VA 20151

kimberly.landick@erg.com

Phone: 703-633-1119
Date

Average 

Flow Value Units Max Flow Value Units

Average Bnezene 

Concentration Units Date

Average Flow 

Value Units

Max Flow 

Value Units

Average Bnezene 

Concentration Units

Feb-09 Feb-09 4032 144

Mar-09 4320 MGD 144 MGD 6.4 MG/L Mar-09 2160 MGD 72 MGD 2.7 MG/L

Apr-09 2160 MGD 72 MGD Apr-09 MGD

May-09 21600 MGD 720 MGD May-09 4464 MGD 144 MGD

Jun-09 21600 MGD 720 MGD 2.9 MG/L Jun-09 4.320 MGD 144 MGD 3.5 MG/L

Jul-09 360 MGD 11160 MGD Jul-09 144 MGD 4464 MGD

Aug-09 43200 MGD 1440 MGD Aug-09 34560 MGD 1152 MGD

Sep-09 4.320 MGD 144 MGD 1.8 MG/L Sep-09 4320 MGD 144 MGD 0.91 MG/L

Oct-09 33480 MGD 1080 MGD Oct-09 4464 MGD 144 MGD

Nov-09 10800 MGD 360 MGD Nov-09 4.320 MGD 144 MGD

Dec-09 2.8 MG/L Dec-09 1.5 MG/L

Outfall 001

KY0027910

Bulk Plant Grayson #266 Bulk Plant Flemingsburg #39

KY0039357

Outfall 001