Need to return call by / at/between and . Signature: ___________________________ Project No.: 0172.07.005.503 DISTRIBUTION

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Project Name: 304(m) Annual Review

TELEPHONE CALL RECORD

Outgoing Call Date: 2/12/2010 Time: 12:15 pm EST

Company Name: Graftech International Holdings Inc. Contact Name: Julie Aslinger

Phone No.: 931-380-4346

Name: Elizabeth Sabol Eastern Research Group

GENERAL SUBJECT : Basis of PAC load reported to TRI in 2008



### TOPICS DISCUSSED AND ACTION TAKEN

I called Graftech International Holdings Inc. on Febr uary 12, 2010, to speak with Tommy Underwood. I left a message with Mr. Underwood’s voicemail identifying myself and explaining my reason for calling. I asked that he give me call back or forward my contact information t o the appropriate person.

Ms. Aslinger called me back later that afternoon. She s tated that she was the person that compiles the information reported to TRI. We briefly discussed the PAC discharges that the facility reported to TRI in 2008. She stated that PACs are used in processes regarding the manufacturing of furnaces. Ms. Aslinger explained that the facility estimates the PAC discharge using t he flow and the concentration of total suspended solids. M s. Aslinger explained that they know the percentage of the solids that is the furnace material and also the percentage of that material that is PACs in order to es timate the flow.

I explained that EPA assigns a TWF of benzo(a)pyrene (th e highest) to discharges of PACs in TRI. I asked what individual PAC compounds Graftech monitored for and if any we re detected above the detection limit in order

to better estimate the TWPE associated with the load. Ms. Aslinger stated that the facility uses a distributi on of the 21 individual compounds and that she would e-mail me t he distribution. I told Ms. Aslinger that I would send her an e-mail confirming the annual review work done fo r EPA and the information on PAC discharges that she agreed to send.

Please see the attached email correspondence.From: Julie Aslinger <jaslinger@cteh.com>

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

CC: "swietlik.william@epa.gov" <swietlik.william@epa.g ov>, Eleanor Codding <Eleanor.Codding@erg.com>, Jes sica Wolford <Jessica.Wolford@erg.com>, "Bursley, Juanit a M" <Juanita.Bursley@graftech.com>, "Underwood, To mmy" <J.Underwood@graftech.com>, Rick Bolton <rbolton@ct eh.com>, "Bryant, Jeff M" <Jeff.Bryant@graftech.com >

Date: 3/22/2010 12:31 PM Subject: RE: PAC Discharge Summary

Attachments: Columbia PAC Enquiry Response v2.doc

Ms. Sabol, Please find attached a document containing the resp onse to your questions from the February 25, 2010, email contained below. Please let me know if you have any questions concer ning this response. Thank you,

Julie Julie Aslinger Senior Environmental Scientist - Project Manager Center for Toxicology and Environmental Health, LLC

124 First Avenue South, Suite 100 Franklin, TN 37064

Phone: (615) 628-3207 Cell: (615) 587-5800 Fax: (615) 591-6646 From: Elizabeth Sabol [mailto:Elizabeth.Sabol@erg.c om] Sent: Thursday, February 25, 2010 3:48 PM To: Julie Aslinger Cc: swietlik.william@epa.gov; Eleanor Codding; Jess ica Wolford Subject: PAC Discharge Summary

Dear Ms. Aslinger,

Thank you for your time on the phone other week. Ea stern Research Group, Inc. (ERG) under EPA Contract No. 68-C-02-095 is e-mailing you on behalf of EPA to request information on your pol ycyclic aromatic compound (PAC) discharges reported by you to the Toxic Release Inventory (TRI) in 2008. Here is some background on what the information is used for.

We are requesting this additional information in ac cordance with Section 304(b) of the Clean Water Act , which requires EPA to annually review and, if appropriate, revise its water pollution con trol 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 i ndustrial facilities. EPA is currently conducting its 2010 annual review of existing efflu ent guidelines and potential industrial guidelines which may need to be included (see http://www.epa.gov/guide/304m/ for further informat ion). EPA will discuss this review and the results in its 2010 Effluent Guidelines Program Plan scheduled for publication in the Federal Regis ter in December 2010. As part of the 2010 annual re view, EPA is evaluating the data you reported in the 2008 Toxic Release Inventory and ne eds further information to complete the review. In some cases, EPA is contacting POTWs or facilities to verify the information in TRI. Th ese contacts are being made on behalf of EPA by ERG

.

We would like to obtain additional information on h ow you determined the total pounds of polycyclic ar omatic compounds (PACs) discharged, by answering the following questions:

1. What individual PACs were monitored for? 2. What were the results of the monitoring? 3. Which, if any, PACs were detected above the dete ction limit?

If you have any questions regarding this request, p lease call me at (703) 633-1659. If you would like to speak directly with EPA regarding this request, you can contact William F. Swietlik o f EPA's Office of Water/Engineering Analysis Divisi on by phone at (202) 566-1129 or by email: swietlik.william@epa.gov<mailto:swietlik.wil liam@epa.gov>.

Thanks,

Elizabeth A. Sabol Environmental Engineer Eastern Research Group, Inc. 14555 Avion Parkway, Suite 200 Chantilly, VA 20151 elizabeth.sabol@erg.com<mailto:elizabeth.sabol@erg. com>

Phone:703-633-1659RESPONSES PROVIDED BELOW FOR GRAFTECH INTERNATIONAL HOLDINGS INC. –

COLUMBIA, TN FACILITY

Q1. What individual PACs were monitored for?

A1. GrafTech does not routinely monitor individual PACs/Polynuc lear Aromatic Hydrocarbons (PAHs) or for total PAHs in its wastewater discharges, as we ar e not required to do so by our NPDES Permit.

Q2. What were the results of the monitoring?

A2. N/A

Q3. Which, if any, PACs were detected above the detection limit?

A3. N/A

Explanation : GrafTech's NPDES Permit does not require that we mon itor for the PAC Category, any of the individual substances listed in the PAC Category, or Tota l PAHs. Therefore, testing of the wastewater discharge is not typically performed. In addition, the SA RA Rule does not require a company to perform testing on listed toxic substances for Toxic Release In ventory (TRI) reporting purposes, but allows reporting entities to estimate its releases based on sound enginee ring estimates, process knowledge and available data.

GrafTech has estimated the total quantity of PACs rel eased to water for our TRI Report. Specifically, the

conservative estimate was based on the calculated annual average total suspended solids (TSS) in the wastewater discharges at each of the two permitted outf alls (which was, in turn, based on 12-month average flow measurements and 12-month average TSS test data), the product mix formula, and composition data received from our raw material suppliers. Please note that the quantities of reported PACs released to water has varied significantly in submitted TRI Reports for ca lendar years 2006, 2007 and 2008 because the calculation results using the described method depend heavily on the quantity of wastewater discharged. This quantity varies both with the production level of this manufa cturing facility and the annual precipitation, which impacts the quantity of collected stormwater disch arged at Outfall 001. Historically, the TSS levels have not varied significantly at this facility.

Based on a recent representative sampling of wastewater at Outfall 001 (that is comprised of process cooling water and stormwater runoff), the analytical results p er EPA Method 8310 for listed PACs are provided in the table below. GrafTech plans to use this test data, r ather than the previous conservative engineering estimate, to derive the quantity of PACs discharged to water for future SARA TRI Reporting. In comparison, if this analytical data had been used for the 2008 TRI Rep ort, rather than the conservative engineering estimate method described above, 249 pounds of PACs released to water would have been reported rather than 1,091 pounds. So, while the engineering estimate used was an acceptable method to determine the quantity of PACs released to water for SARA TRI Repor ting purposes, it did, unfortunately, significantly over-estimate the quantities reported in the past. Future T RI reported PACs will be more representative.



### PARAMETER RESULT DETECTION

LIMIT UNITS EPA METHOD

Polynuclear Aromatic Hydrocarbons: Benzo(a)anthracene 0.0051 0.000010 m g/L 83 10 Benzo(a)pyrene 0.0065 0.000010 m g/L 8310 Benzo(b)fluoranthene 0.0053 0.000010 m g/L 8310 Benzo(k)fluoranthene 0.0032 0.000010 m g/L 8310 Chrysene 0.0051 0.000010 m g/L 8310 Dibenz(a,h)anthracene 0.0041 0.000010 m g/L 8310

Fluoranthene 0.0081 0.0 00010 m g/L 8310 Indeno(1,2,3

- cd)pyrene 0.0051 0.000010 m g/L 8310

TOTAL PACs 0.0425 m g/L