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

Project No.: 0172.07.005.503 DISTRIBUTION 

Page _1_ of __1_

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 February 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 to the appropriate person. 

Ms. Aslinger called me back later that afternoon. She stated 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 the flow and the concentration of total suspended solids. Ms. 

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 estimate the flow. 

I explained that EPA assigns a TWF of benzo(a)pyrene (the highest) to discharges of PACs in TRI. I asked what 

individual PAC compounds Graftech monitored for and if any were detected above the detection limit in order 

to better estimate the TWPE associated with the load. Ms. Aslinger stated that the facility uses a distribution of 

the 21 individual compounds and that she would e-mail me the distribution. I told Ms. Aslinger that I would 

send her an e-mail confirming the annual review work done for 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.gov>, Eleanor Codding <Eleanor.Codding@erg.com>, Jessica 

Wolford <Jessica.Wolford@erg.com>, "Bursley, Juanita M" <Juanita.Bursley@graftech.com>, "Underwood, Tommy" 

<J.Underwood@graftech.com>, Rick Bolton <rbolton@cteh.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 response to your questions from the February 25, 2010, email contained below. 

Please let me know if you have any questions concerning 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.com] 

Sent: Thursday, February 25, 2010 3:48 PM 

To: Julie Aslinger 

Cc: swietlik.william@epa.gov; Eleanor Codding; Jessica Wolford 

Subject: PAC Discharge Summary 

Dear Ms. Aslinger, 

Thank you for your time on the phone other week. Eastern 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 polycyclic 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 accordance with Section 304(b) of the Clean Water Act, which 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 2010 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 2010 Effluent Guidelines Program 

Plan scheduled for publication in the Federal Register in December 2010. As part of the 2010 annual review, EPA is evaluating the data you 

reported in the 2008 Toxic Release Inventory and needs further information to complete the review. In some cases, EPA is contacting POTWs 

or facilities to verify the information in TRI. These contacts are being made on behalf of EPA by ERG. 

We would like to obtain additional information on how you determined the total pounds of polycyclic aromatic 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 detection limit? 

If you have any questions regarding this request, please call me at (703) 633-1659. 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<mailto:swietlik.william@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:703-633-1659 
RESPONSES 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/Polynuclear Aromatic Hydrocarbons (PAHs) or 

for total PAHs in its wastewater discharges, as we are 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 monitor for the PAC Category, any of the 

individual substances listed in the PAC Category, or Total PAHs. Therefore, testing of the wastewater 

discharge is not typically performed. In addition, the SARA Rule does not require a company to perform 

testing on listed toxic substances for Toxic Release Inventory (TRI) reporting purposes, but allows reporting 

entities to estimate its releases based on sound engineering estimates, process knowledge and available data. 

 

GrafTech has estimated the total quantity of PACs released 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 outfalls (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 calendar 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 manufacturing facility and the annual precipitation, 

which impacts the quantity of collected stormwater discharged 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 per EPA Method 8310 for listed PACs are provided in 

the table below. GrafTech plans to use this test data, rather 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 Report, 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 Reporting purposes, it did, unfortunately, significantly 

over-estimate the quantities reported in the past. Future TRI reported PACs will be more representative. 

PARAMETER RESULT DETECTION 

LIMIT UNITS EPA METHOD 

Polynuclear Aromatic 

Hydrocarbons: 

Benzo(a)anthracene 0.0051 0.000010 mg/L 8310

Benzo(a)pyrene 0.0065 0.000010 mg/L 8310

Benzo(b)fluoranthene 0.0053 0.000010 mg/L 8310

Benzo(k)fluoranthene 0.0032 0.000010 mg/L 8310

Chrysene 0.0051 0.000010 mg/L 8310

Dibenz(a,h)anthracene 0.0041 0.000010 mg/L 8310

Fluoranthene 0.0081 0.000010 mg/L 8310

Indeno(1,2,3-cd)pyrene 0.0051 0.000010 mg/L 8310

TOTAL PACs 0.0425 mg/L