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Project No.: 0317.02.005.520 Page 1 of 4

Project 

Name:

2015 Annual Review – Preliminary 

Category Review OCPSF (PSC 

414)

CBI?

Yes

No TELEPHONE CALL RECORD

Incoming

Outgoing

Date: 05/07/2015 Time: 4:00 am

pm

Company 

Name:

ExxonMobil Chemical Co Baytown 

Olefins Plant (Part)

ERG Staff 

Name:

Eva Knoth

Contact 

Name:

Kevin Brewer 

Connie Tilton

Snigdha Joshi

Contact 

Phone 

Number:

kevin.r.brewer@exxonmobile.com

281-834-0101

connie.g.tilton@exxonmobil.com

281-834-7342

snigdha.n.joshi@exxonmobil.com

281-834-5146

General 

Subject:

2013 TRI PACs Releases from ExxonMobil Chemical Co Baytown Olefins Plant, Baytown, TX 

TRI ID: 77522XXNCH3525D

TOPICS DISCUSSED AND ACTION TAKEN

I left a message with Ms. Tilton on May 7, 2015 at 4 pm.

Mr. Kevin Brewer, Environmental Section Supervisor (kevin.r.brewer@exxonmobile.com), returned my call on 

May 7, 2015 at 5:15 pm. He requested further information via email so he could review the information and 

send us a response. Please see email communication below.

I called Ms. Snigdha Joshi on July 10, 2015 at 11 am to get further clarification on her email response. To 

estimate the PACs release, the measured stormwater flow is multiplied by the half detection limits (units of 

concentration) for benzo(a)anthracene, benzo(a)pyrene and chrysene. The facility does not monitor for PACs in 

their NPDES permits, so there are no pollutant measurements included in the TRI release estimate. The 

variation in past reported TRI releases of PACs was due to variation in flow.

The stormwater does not have contact with process areas at the facility, therefore the PACs estimate was 

reported as a conservative estimate. The facility has since reevaluated this approach and will be reporting 0 lb/yr 

PACs wastewater releases for RY2014 because there is no reason to believe any PACs are discharged.

From: Eva Knoth 

Sent: Tuesday, May 19, 2015 4:19 PM

To: 'Joshi, Snigdha N'; Brewer, Kevin R

Subject: RE: 2013 TRI Clarification for PACs Water Releases

Thank you both. We will review the information and let you know if we have any further questions. 

Thanks,

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

Eva Knoth

Environmental Engineer

Eastern Research Group, Inc. (ERG)

eva.knoth@erg.com

(703) 633-1648

From: Joshi, Snigdha N [mailto:snigdha.n.joshi@exxonmobil.com] 

Sent: Tuesday, May 19, 2015 2:56 PM

To: Brewer, Kevin R; Eva Knoth

Subject: RE: 2013 TRI Clarification for PACs Water Releases

Eva,

Below is the information requested. Please me know if you have any additional questions or comments.

1. Please confirm the pounds of PACs released to surface waters in 2013: 33 pounds. 

Response: Yes, that is correct.

2. What methodology was used to measure or estimate the reported release? If monitoring was 

conducted: how often were measurements taken and, if applicable, how were non-detects handled?

Response: No monitoring conducted specifically for PACs, however half the detection limit for 

Benzo(a)anthracene, Benzo(a)pyrene and Chrysene was used in the calculation of PACs discharged in the 

wastewater.

Regards,

Snigdha Joshi

Emissions Advisor

SSH&E Department

ExxonMobil Chemical Company

CAB W-118, 

5000 Bayway Drive,

Baytown, TX 77520

281 834 5146 Tel

From: Brewer, Kevin R 

Sent: Friday, May 15, 2015 11:02 AM

To: Eva Knoth

Cc: Joshi, Snigdha N

Subject: RE: 2013 TRI Clarification for PACs Water Releases

Eva- I did receive your email. As I mentioned in our phone conversation the Environmental Advisor 

responsible for that area is out due to a fractured hand. She has had surgery and is expected to return to work 

Monday. It is likely we can respond by EOD Tuesday.

Kevin Brewer

Environmental Section Supervisor

Permitting, Release Reporting, Emission Reporting

ExxonMobil Chemical Company
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5000 Bayway Drive

Baytown, TX 77522

281-834-0101 (office)

832-784-2894 (cell)

From: Eva Knoth [mailto:Eva.Knoth@erg.com] 

Sent: Friday, May 15, 2015 10:15 AM

To: Brewer, Kevin R

Subject: RE: 2013 TRI Clarification for PACs Water Releases

Mr. Brewer,

I wanted to confirm that you received the email below. If possible, it would be helpful to have a response from 

you by the end of the day Tuesday (5/19). 

Thank you for your time,

Eva

Eva Knoth

Environmental Engineer

Eastern Research Group, Inc. (ERG)

eva.knoth@erg.com

(703) 633-1648

From: Eva Knoth 

Sent: Monday, May 11, 2015 8:34 AM

To: KEVIN.R.BREWER@EXXONMOBIL.COM

Cc: Kimberly Bartell; Swietlik, William

Subject: 2013 TRI Clarification for PACs Water Releases

Dear Mr. Brewer,

Thank you for your time on the phone last week. As discussed, Eastern Research Group, Inc. (ERG) under EPA 

Contract No. EP-C-12-021, is e-mailing you to request clarification of 2013 TRI water releases of polycyclic 

aromatic compounds (PACs) reported by ExxonMobil Chemical Co. Baytown Olefins Plant (TRI ID 

77522XXNCH3525D). See below for background on what the information is used for.

EPA reviews publicly-available discharge monitoring report (DMR) and toxic release inventory (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 

guidelines," that limit the discharge of pollutants to waters of the U.S. from various categories of industrial 

facilities. EPA is currently conducting its 2015 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 2015 Effluent Guidelines Program Plan 

scheduled for publication in the Federal Register in 2015 or 2016.

As part of the 2015 annual review, EPA is evaluating the data reported to the 2013 TRI and requests further 

information to complete the review. Specifically, we would like to clarify the amount of PACs reported as

released to surface waters. Please confirm/review the following data and questions below.
Need to return call by / at/between and . Signature:

1. Please confirm the pounds of PACs released to surface waters in 2013: 33 pounds

2. What methodology was used to measure or estimate the reported release? If monitoring was 

conducted: how often were measurements taken and, if applicable, how were non-detects handled?

We appreciate your help in interpreting TRI data correctly. If you have any questions regarding this request, 

please call me at (703) 633-1648. 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, 

Eva

Eva Knoth

Environmental Engineer

Eastern Research Group, Inc. (ERG)

eva.knoth@erg.com

(703) 633-1648