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

Project No.: 0317.00.005.522 Page 1 of 1

Project Name: TRI2011 CBI?

Yes

No

TELEPHONE CALL RECORD

Incoming

Outgoing

Date: 01/08/13 Time: 4:00 am

pm

Company Name: DuPont Johnsonville ERG Staff Name: Kimberly Bartell

Contact Name: Gregg Martin Contact Phone Number: (931) 535-7251

General Subject: 2011 TRI PCB Discharges

TOPICS DISCUSSED AND ACTION TAKEN

On January 8, 2013 at 4 pm, I called DuPont Johnsonville to speak with Gregory Martz and left a message with 

his office. 

On January 11 at 2pm, Gregg Martin returned my phone call and requested an email with our request. I 

explained to him that we wanted to confirm the 2011 TRI PCB release and he stated he would look into it. 

Email = Gregg.w.martin@dupont.com Please see attached email communication.
Email Communication with Millennium Inorganic Chemicals

From: Kimberly Bartell

To: Robert Schmude

Date: 1/22/14 1:52 PM

Subject: Re: 2011 TRI Clarification for Dioxin and Manganese Discharges

Mr. Schmude,

Thank you very much for your responses. I will review the information and let you know if we 

have any further questions.

Thanks again,

Kimberly

From: Robert Schmude

To: Kimberly Bartell

Date: 01/22/14 1:40 PM

Subject: Re: 2011 TRI Clarification for Dioxin and Manganese Discharges

Responses in red below...

From: Kimberly Bartell [mailto:Kimberly.Bartell@erg.com] 

Sent: Friday, January 17, 2014 9:58 AM

To: Robert Schmude

Cc: William Swietlik; Elizabeth Sabol; Kim Wagoner

Subject: Re: 2011 TRI Clarification for Dioxin and Manganese Discharges

Mr. Schmude,

Thank you for your time on the phone this morning. As discussed, we are completing the 2013 

Annual Review of industrial wastewater discharges and need some additional information. ERG 

requests this information on behalf of EPA under Contract No. EP-C-12-021. Here is some 

background on what the information is used for. 

EPA reviews publicly-available TRI 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 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 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 TRI from 2011 and needs further information to complete the review.

As I have previously discussed with you, there are two Millennium Inorganic facilities. I've split 

up our additional questions below. 

1. Millennium Inorganic Chemicals A Cristal Co. TRI ID: 44004SCMCH2900M

Dioxin and dioxin-like compounds

- Please explain why only three dioxin congeners were reported to TRI in 2009 but all 17 dioxin 

congeners were reported to TRI in 2011. Has the analytical method or feedstock changed? In 

2011, the non-detect data was inadvertently and erroneously reported using the minimum 

detection limit for all congeners. In 2009 and all other years, non-detect data was reported as ‘0’.

Therefore, the data for 2011 appears artificially high compared to others years.

- What is the reason that dioxin discharges were not reported to TRI prior to 2009? See response 

above. We did report prior to 2009, the results were 0 or non detect

- Please list the process conditions affecting the concentration of dioxin congeners. It is believed 

that the formation of congeners occur within a very narrow temperature range immediately 

following the chlorination process. The congeners that are formed are of extremely small 

quantity.

- Provide the facility flow values for 2009 and 2011. What caused the flow increase? 2009 flow: 

812.7 million gal/yr; 2011 flow: 867.5 million gal/yr. This is a slight increase in effluent flow; 

many factors influence volume of water flow, including process rate, process conditions, and 

volume of stormwater.

- Provide a description of the outfall where dioxin sampling is conducted. Sampling is 

conducted at the NPDES effluent compliance point prior to the mixing zone and discharge into 

Lake Erie.

- Provide any 2012 and 2013 dioxin TRI data. 2013 data is not yet available. 2012 dioxin to 

water was reported as 0.1436 grams.

2. Millennium Inorganic Chemicals A Cristal Co. TRI ID: 44004SCMCH2426M

Manganese and manganese compounds

- Please provide the facility flow values for 2009 and 2011. 2009 flow: 1604 million gal/yr; 

2011 flow: 1675 million gal/yr.

- What has caused the increase in flow? This is a slight increase in effluent flow; many factors 

influence volume of water flow, including process rate, process conditions, and volume of 

stormwater.

- Provide any 2012 or 2013 dioxin TRI data. 2013 data is not yet available. 2012 Mn to water 

was 53,463 lbs.

We appreciate your help in interpreting the data correctly. For reference, my previous email 
communication with you is below. 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

From: Kimberly Bartell

To: Robert.schmude@cristal.com

CC: Sabol, Elizabeth; Swietlik, William; Wagoner, Kim

Date: 01/17/14 9:58 AM

Subject: Re: 2011 TRI Clarification for Dioxin and Manganese Discharges

Mr. Schmude,

Thank you for your time on the phone this morning. As discussed, we are completing the 2013 

Annual Review of industrial wastewater discharges and need some additional information. ERG 

requests this information on behalf of EPA under Contract No. EP-C-12-021. Here is some 

background on what the information is used for. 

EPA reviews publicly-available TRI 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 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 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 TRI from 2011 and needs further information to complete the review.

As I have previously discussed with you, there are two Millennium Inorganic facilities. I've split 

up our additional questions below. 

1. Millennium Inorganic Chemicals A Cristal Co. TRI ID: 44004SCMCH2900M

Dioxin and dioxin-like compounds

- Please explain why only three dioxin congeners were reported to TRI in 2009 but all 17 dioxin 

congeners were reported to TRI in 2011. Has the analytical method or feedstock changed?

- What is the reason that dioxin discharges were not reported to TRI prior to 2009?

- Please list the process conditions affecting the concentration of dioxin congeners.
- Provide the facility flow values for 2009 and 2011. What caused the flow increase?

- Provide a description of the outfall where dioxin sampling is conducted. 

- Provide any 2012 and 2013 dioxin TRI data.

2. Millennium Inorganic Chemicals A Cristal Co. TRI ID: 44004SCMCH2426M

Manganese and manganese compounds

- Please provide the facility flow values for 2009 and 2011. 

- What has caused the increase in flow?

- Provide any 2012 or 2013 dioxin TRI data. 

We appreciate your help in interpreting the data correctly. For reference, my previous email 

communication with you is below. 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

>>> Kimberly Bartell 2/6/2013 2:07 PM >>>

Dear Mr. Schmude,

Thank you for your time on the phone this morning. As discussed, EPA has requested 

clarification of 2011 TRI data as part of our 2013 annual review of industrial discharges under 

Section 304 of the Clean Water Act. ERG requested clarification for Millennium Inorganic 

Chemicals discharges of dioxin and manganese on behalf of EPA under Contract No. EP-C-12-

021. Please see below for further information. 

EPA, Office of Water (OW), reviews 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 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 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 sometime in 2013 or 2014. 

Below is a summary of the data discussed during our call this morning. Please let me know if 

any of this data does not match the TRI data submitted in 2011.

1. Millennium Inorganic Chemicals A Cristal Co. TRI ID: 44004SCMCH2900M

Dioxin and dioxin-like compounds

- 2011 total discharges confirmed: 1.11 grams, 0.0024 pounds

- Confirmed 2011 dioxin distribution, see attached spreadsheet. 

- The facility calculated dioxin discharges based off of quarterly sampling at the 

NPDES compliance point (final effluent)

- Non detect results are included as zeros in the distribution

- There has been a slight increase in the dioxin concentrations as well as an increase in the flow 

from 2009-2011. This has caused the dioxin discharges to increase from 2009-2011. The dioxin 

compounds are a byproduct of the processing of raw materials, the amount discharged depends 

on the process conditions. 

2. Millennium Inorganic Chemicals A Cristal Co. TRI ID: 44004SCMCH2426M

Manganese and manganese compounds

- 2011 total discharge confirmed: 79,000 pounds

- The facility calculated manganese discharges based off of direct sampling at the NPDES 

compliance point (final effluent). The samples are taken once per week and they are 24 hour 

composite samples. 

- There has been an increase in flow and the raw material blend has changed, both factors have 

contributed to an increase in manganese discharges from 2009-2011.

We appreciate your help in interpreting TRI data correctly. If you have any questions, please call 

me at (517) 515-1721. 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