Need to return call by / at/between and

. Signature: Project No.: 0 317.0 1.005.510 Page 1 of 1

Project Name: DMR20 11 

### CBI?

Yes

No TELEPHONE CALL RECOR D Incoming Outgoing Date: 12/13 /13 Time: 2:00 am

pm

Company Name: Celanese LTD Bay City Plant ERG Staff Name: Kimberly Bartell

Contact Name: Gladys Gavronovic Contact Phone Number: (979) 241

- 4022

General Subject: 2011 DMR Chlorine Discharges for Celanese LTD



### TOPICS DISCUSSED AND ACTION TAKEN

Greg Blanchard: 979

- 241

- 4386 (Celanese) Billy Campbell: 979

- 241

- 4441

– retired, contact Mike Arnold instead

Mike Arnold: 979

- 241

- 4169 (Celanese) Gladys Gavronovic: 979

- 241

- 4022

Brian Meek: 979

- 241

- 4053

On December 13 th , I called Greg Blanchard and left a message.

On December 17 th at 10am, I called Greg Blanchard and left a message. I also called Billy Campbell but got a message that he is retired and that I should contact Mike Arnold. I ca lled Mike Arnold and also left a message.

Mr. Arnold returned my call at 10:15am on December 17 th and told me that a few years ago Celanese sold parts of the company to Oxea and that Oxea holds the wastewater permits. They are both part of the same plant. He told me to contact Gladys Gavra novic at 979

- 241

- 4022 or Brian Meek at 979

- 241

- 4053. I called Ms.

Gavra novic and left a message. I also called Brian Meek and spoke with him. He stated that he is the air engineer while Ms. Gavra novic is the water engineer so she would be the best contact. He took my information and stated that someone should be getting back to me in the next few hour s.

At 1:30pm on December 17 th , Gladys Gavranovic returned my call. She stated that the chlorine limit in their permit is for an internal outfall, not for the actual discharge (chlorine must be at least 1mg/L). The state usually

lists the chlorine limit f

or the internal outfall on their DMRs so it’s a common issue where their DMR data is much higher than their limit shown. The limit is a minimum for the internal outfall; the final outfall does not

have a chlorine limit. Ms. Gavranovic also stated that thei r permit renewal is in progress and that it would be

easiest for her to confirm the DMR data via email. Please see attached email communication.

On December 20 th at 1pm I called Ms. Gavranovic and left a message asking for a timeframe of when she will

b e able to get me the data.

On December 30 th at 1pm I called Ms. Gavranovic and left a message asking for a timeframe of when she will be able to get me the data.

On January 9 th , Ms. Gavranovic returned my email, please see attached email communication.Email Communication with Celanese LTD

From: Kimberly Bartell To: Gladys.gavranovic@oxea

- chemicals.com CC: Sabol, Elizabeth; Swietlik, William; Wagoner, Kim

Date: 1/9/14 10:33 AM Subject: RE: 2011 DMR Clarification for Chlorine Discharges

Ms. Gavranovic,

Thank you for your response. I will review the information provided below and will let you
know if we have any further questions.

Thanks again,
Kimberly

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

Eastern Researc h Group, Inc.
kimberly.bartell@erg.com

Phone: 517

- 515

- 1721

From: Gladys.gavranovic@oxea

- chemicals.com To: Bartell, Kimberly ; Swietlik, William CC: Sabol, Elizabeth; Wagoner, Kim ; Scott, Karen J., Oxea/US

Date: 1/9 /1 4 10:27 A M Subject: Re: 2011 DMR Cl arification for Chlorine Discharges

This email is in reply to your request regarding the 2011 DMR data for total residual chlorine for
Outfall 001 for OXEA Corporation in Bay City, TX.

We would like notify you that the chlorine (Cl) values you reference below are not for Outfall

001. The Cl values below apply to the internal domestic wastewater treatment plant effluent

which is not discharged via Outfall 001. The internal domestic wastewater treatment plant

effluent is sent to the permitted on

- site neutral effluent treatment (NET) system, along with
process wastewater streams, for biological treatment. Outfall 001 applies only to effluent from
the permitted on

- site wastewater treatment system, or NET system, and not the internal domestic
wastewater treatment plant effluent.

For further understanding of this, please see the attached partial copy of our permit. The Cl limit
and discussion for the internal domestic wastewater treatment plant effluent are located on thela st page. As noted in item 2 of the table for Outfall 001, “ The effluent from the domestic

wastewater treatment plant shall be monitored at the outlet line from the clarifier and shall
contain a chlorine residual of at least 1.0 mg/l after a detention time of at least 20 minutes.......”

Unfortunately, when our permit was issued, the residual Cl limit for the internal domestic
wastewater treatment unit was included in the Outfall 001 limits table by the TCEQ even though
it is not applicable to Outfall 001. Th erefore, when the DMR form was developed, the Cl
requirement was also included in the Outfall 001 DMR even though the Cl limit does not apply

to Outfall 001. As such, we are required to report these residual Cl values on our Outfall 001
DMR even though th ey are not a measurement of the effluent (Outfall 001) that is discharged

from the site. We hope that we can get this resolved during the current permit renewal cycle.

In summary:

 The Cl values below are for the interna l domestic wastewater treatment effluent and not

Outfall 001. However, we are required to report this Cl value on our DMR for Outfall 001 due to how the permit / DMR report was developed by the TCEQ.

 Chlorine concentrations that appear on the Outfall 001 DMR’s are not being discharged outside the facility via Outfall 001.

 To address your request, I have confirmed that the values shown below are the values that were submitted in the monthly DMR reports.

 Furthermore, in the January 2011 DMR we reported that the DMR residual Cl minimum limit of 1.0 mg/L was not met. That DMR report also includes a footnote in which reads

as follows: “On January 24, 2011, the chlorine residual limit of at least 1.0 mg/L was not met. An
investigation concluded that the ch lorine feed tank level was low due to a delayed bleach
delivery and the analyzer probe was plugged. Make

- up bleach was added to the tank, the probe was cleared and a resample was collected with a result of 38 mg/L”
Please contact Karen Scott if you have an y further questions as I will be out of the office during

the next week. Otherwise our replies will be delayed.

Sincerely,

Gladys Gavranovic

Environmental Affairs
OXEA Corporation

Phone: +1 979

- 241

- 4022

Fax: +1 979

- 241

- 4141
gladys.gavranovic@oxea

- chemicals.com

The information contained in this e

- mail, and any attachments thereto, is confidential and is
intended only for use by the individual(s) and/or entity named above. If you are not the in tended
recipient of this e

- mail, you are hereby notified that any dissemination, distribution or copying ofthis communication or any disclosure of the contents of this communication to others is strictly

prohibited. If you have received this communication in error please notify the sender
immediately by replying to this e

- mail. Please then delete the original including all attachments
and any copy of any e

- mail and printout thereof.

From: Kimberly Bartell To: Gladys.gavranovic@oxea

- chemicals.com CC: Sabol, Elizabeth; Swietlik, William; Wagoner, Kim

Date: 12/31/13 9:13 AM Subject: RE: 2011 DMR Clarification for Chlorine Discharges

Ms. Gavranovic,

Thank you for getting back to me, I'll look for confirmation of the data sometime next week.

Happy New Year!

Thanks, Kimberly

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

Eastern Research Group, Inc. kimberly.bartell@erg.com

Phone: 517

- 515

- 1721

From: Swietlik, William <swietlik.william@epa.gov> To: Bartell, Kimberly; Gavranovic, Gladys Oxea/US CC: Sabol, Elizabeth; Wagoner, Kim

Date: 12/31/13 8:10 AM Subject: Re: 2011 DMR Clarification for Chlorine Discharges

Gladys: Thank you for your attention to our request. Have a happy New Year.

_______________________________ William F. Swietlik US EPA, Office of Water Engineering and Analysis Division (4303T) 1200 Pennsylvania Ave. , NW Washington, DC 20460

202

- 566

- 1129: phone

202

- 566

- 1053: FaxFrom: Gladys.gavranovic@oxea

- chemicals.com

To: Bartell, Kimberly CC: Sabol, Elizabeth; Swietlik, William; Wagoner, Kim

Date: 12/30/13 6:03 PM Subject: Re: 2011 DMR Cl arification for Chlorine Discharges

Hi Kimberly,

Sorry for the delay in getting back to you

– I’ve been out of the office, along with several others. I believe I can get the info to you sometime next week, as everyone should be back in the office.

Gladys Gavranovic

Environmental Affairs OXEA Corporation

Phone: +1 979

- 241

- 4022

Fax: +1 979

- 241

- 4141 gladys.gavranovic@oxea

- chemicals.com

The information contained in this e

- mail, and any attachments thereto, is confidential and is intended only for use by the individual(s) and/or entity named above. If you are not the intended recipient of this e

- mail, you are hereby notified that any dissemination, distribution or copying of

this communication or any disclosure of the contents of this communication to others is strictly prohibited. If you have received this communication in error please notify the sender immediately by replying to this e

- mail. Please then delete the original inclu ding all attachments and any copy of any e

- mail and printout thereof.

From: Kimberly Bartell

To: Gladys.gavranovic@oxea

- chemicals.com CC: Sabol, Elizabeth; Swietlik, William; Wagoner, Kim

Date: 12/17/13 2:27 PM Subject: 2011 DMR Clarification for Chlorine Discharges

Dear Ms. Gavranovic,

Thank you for your time on the phone today. Eastern Research Group, Inc. (ERG) under EPA

Contract No. EP

- C

- 12

- 021,is e

- mailing you on EPA's behalf to request clarification of 2011 discharge monitoring reports for Celanese LTD Bay City Plant ( TX0006017). Here 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 (CWA). The CWA requires EPA to annually review and, if appropri ate, revise its water pollution control technology

- based regulations, called "effluent limitationsguidelines" or "effluent guidelines," that limit the discharge of pollutants to waters of the U.S.

from various categories of industrial facilities. EPA is c urrently 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 discharge monit oring reports from 2011 and needs further information to complete the review.

We would like to obtain additional information on the following 2011 discharge data for total residual chlorine for your facility. Our records show the following values were di scharged:

Outfall 001:

Date Total Residual

Chlorine

Concentration (mg/L) Wastewater

Flow (MGD)

1/31/2011 0.1 1.086

2/28/2011 105 1.009

3/31/2011 105 1.21

4/30/2011 10 0.75

5/31/2011 65 0.87

6/30/2011 10 0.92

7/31/2011 110 0.78

8/31/2011 159 0.91

9/30/2011 160 1.091

10/31/2011 129 0.85

11/30/2011 39 0.74

12/31/2011 8 0.907

Please also send a copy of your current NPDES permit. We appreciate your help in confirming if the above data are accurate, or if there are units errors in the DMR data.

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