Need to return call by / at/between and

. Signature: Project No.: 0317.02.005.510 Page 1 of 6

Project

Name: 2015 Annual Review CBI?

Yes

No TELEPHONE CALL RECOR D Incoming Outgoing Date: December 12,

2014 Time: 4:15 am

pm

Company

Name: PCS Nitrogen Fertilizer LP

TRI ID: 70734RCDNCHIGHW ERG Staff Name: Eva Knoth

Contact

Name: Cecil Hopper (Public TRI Contact)

Clint Roberts Contact Phone

Number: 225

- 621

- 1867

225

- 621

- 1808

General Subject: 2013 TRI Surface Water Releases

TOPICS DISCUSSED AND ACTION TAKEN

On December 12, 2014 at 3:45 pm, I left a voicemail for Mr. Hopper explaining the purpose of the call to confirm some of the water release information reported to TRI in 2013. Mr. Hopper left a message with me at 4:10 confirming that he was the appropriate contact to discuss TRI data.

I returned Mr. Hopper’s call at 4:15 pm and spoke to him about TRI data for surface water releases of metals, and cadmium, in particular. Mr. Hopper explained that the metals releases are attributable to the phosphoric

acid production process. The facility purchases rock as a raw material from Morocco with naturally occurring low levels of metals. The waste product generated from processing is gypsum and there are two gypsum stacks on the property

– one active and one inactive. The inactive stack is covered and lined and includes a leachate collection system with di scharges permitted under NPDES.

However, the TRI releases are estimated using the concentrations found in the rock. Samples of rock are sent to

a l ab for metals analysis. Mr. Hopper stated that the cadmium concentration of the rock used for the 2013 TRI estimate was 73.7 ppm. I asked if he could provide an example calculation. Mr. Hopper responded that he could provide such calculations and requested that I send him an email so he could follow up with the staff member that put together the estimations.

I asked why cadmium discharges were reported starting in 2012 and not in prior years. Mr. Hopper replied that

he wasn’t sure because he started workin g at the company in 2012 but would follow up via email.

To: cecil.hopper@pcsnitrogen.com

From: eva.knoth@erg.com Subject: 2013 TRI Clarification for Cadmium

Sent: Fri 12/12/2014 5:18 PM

Dear Mr. Hopper,

It was a pleasure speaking with you today. As discussed, EPA is requesting clarification of 2013 Toxics Release Inventory (TRI) data as part of our 2015 annual review of industrial discharges under Section 3 04 of the Clean Water Act. I am writing to request clarification for PCS Nitrogen Fertilizer LP (TRI ID:Need to return call by / at/between and

. Signature: 70734RCDNCHIGHW), on behalf of EPA under Contract No. EP

- C

- 12

- 021. Please see below for further background.

EPA Office of Water reviews TRI data to f ulfill 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 "efflu ent 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 Annual Review Report scheduled for publication in the Federal Register sometime in 2015.

EPA is evaluating the data reported to the 2013 TRI and needs further information to complete the review. As a follow up to our conversation, we would like to clarify the amount of cadmium releases reported to the 2013 TRI from PCS Nitrogen Fertilizer LP. Please confirm/review the following data and questions below.

1. Please confirm the reported pounds of cadmium released to surface waters in 2013: 29,886 pounds 2. Please explain how the cadmium load is calcula ted. During our conversation, you stated that the calculations were based on concentrations of metals measured in the raw material. Could you provide an example

calculation? 3. Are other metals (e.g., manganese, chromium, and copper) calculated using the s ame method? If not, would you please explain how these three metal releases were calculated? 4. Why were cadmium discharges reported starting in 2012 and not in prior years?

We appreciate your help in interpreting TRI data correctly. If you have any ques tions 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

On December 15

, 9:15 a

. m

. , Clint Roberts called me to fol low up and clarify on my conversation with Mr. Hopper . Mr. Roberts stated that he calculated the TRI release estimates. He first clarified that the metals

concentration measurements from the raw materials was u sed for TRI threshold determination and not in the

water release estimates.

Cadmium water releases were estimated from three internal outfalls: 201, 301

, and 401.

- For 201 and 401, no cadmium was measured so the limit value from the NPDES permit multiplie d by the average flow was used to estimate the annual release. Outfall 201: 25 lbs, Outfall 401: 0 lbs.

- Outfall 301 is leachate collected from the gypsum stack and the main source of metals in the

wastewater . For 301, monthly analytical data was used to ca lculate and annual release. This data is collected as part of the facility’s NPDES permit. The average concentration (10.7 mg/L) wasNeed to return call by / at/between and

. Signature:

multiplied by the annual flow (335 MG or 2.8 Billion pounds water) to yield an annual release of
29,862.

I asked if other metals (e.g., manganese, chromium, and copper) were calculated using the same method.

Manganese

- The facility does not monitor for this chemical , so they used a value from a p r e vious TRI reporting

year

.

Copper and Chromium

- Water release estimates used the same methodology as for cadmium. These pollutants are measured quarterly as part of NPDES reporting requirements.

I asked why cadmium discharges were reported starting in 2012 and not in prior years. Mr. Roberts replied that he and Mr. Hopper both started working at the facility around the same time and were responsible for TRI reporting beginning in RY 2012. They have not ev aluated TRI reporting methodologies from prior years in

detail

.

To: clint.roberts@pcsnitrogen.com From: eva.knoth@erg.com

CC: cecil.hopper@pcsnitrogen.com; swietlik.william@epa.gov; kimberly.bartell@erg.com; kim.wagoner@erg.com Subject: Request for Confirmation: 2013 TRI Water Release Information

Sent: Mon 12/22/2014 5:46 PM

Mr. Roberts,

It was a pleasure speaking with you la st week. As discussed, ERG is requesting clarification of 2013 Toxics Release Inventory (TRI) data, on behalf of EPA under Contract No. EP

- C

- 12

- 021, as part of the 2015 annual review of industrial discharges under Section 304 of the Clean Water Act (see http://www.epa.gov/guide/304m/ for further information). EPA will discuss this review and the results in its 2015 Effluent Guidelines Annual Review Report scheduled for publication in the Federal Register someti me in 2015. To complete the review

, further information is needed for PCS Nitrogen Fertilizer LP (TRI ID: 70734RCDNCHIGHW).

As a follow up to our conversation on December 15, 2014, I would like to confirm the accuracy of the

information in the call sum mary below. Please confirm that the information is accurate to the best of your knowledge or note any corrections or clarifications.

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

.

---

Please confirm the reported pounds of cadmium released to surface waters in 2013. 29,886 pounds

Please explain how the cadmium water release was calculated.Need to return call by / at/between and

. Signature: The facility uses rock with naturally occurring low levels of metals as a raw material in the phosphoric acid production process. Samples of the rock used are sent to a lab for metals analysis. The metals concentration measurements from the raw material were used for TRI reporting threshold determinati on and not for the water

release estimates.

Cadmium water releases were estimated from three internal outfalls: 201, 301, and 401.

- For Outfalls 201 and 401, cadmium measurements were not taken, so the annual release was estimated by multiplyi ng the permit limit value from the NPDES permit by the average flow.

· Outfall 201: 25 lbs

· Outfall 401: 0 lbs

- Outfall 301 is stormwater and leachate collected from the inactive gypsum stack; it is the main source of

metals in t he wastewater at the facility. For 301, monthly analytical data was used to calculate the annual release. This data is collected as part of the facility’s NPDES permit. The average concentration (10.7 mg/L) was multiplied by the annual flow (335 Million Ga llons or 2.8 Billion pounds water) to yield an annual release
of 29,862.

Were other metals (i.e., manganese, chromium, and copper) calculated using the same method? The facility does not monitor for Manganese through its NPDES permit, so a methodology from a previous TRI reporting year was applied. Water release estimates for copper and chromium used the same methodology as for cadmium. However, these pollutants are measured quarterly as part of NPDES reportin g requirements.

Why were cadmium discharges reported starting in 2012 and not in prior years? Mr. Roberts and Mr. Hopper both started working at the facility around the same time and were responsible for TRI reporting beginning in RY2012. They have not e valuated TRI reporting methodologies from prior years in

detail.

---

Thanks and have a wonderful holiday,

Eva

Eva Knoth Environmental Engineer Eastern Research Group, Inc. (ERG)
(703) 633

- 1648

To: eva.knoth@erg.com

From: clint.roberts@pcsnitrogen .com CC: cecil.hopper@pcsnitrogen.com; swietlik.william@epa.gov; kimberly.bartell@erg.com; kim.wagoner@erg.com Subject: Request for Confirmation: 2013 TRI Water Release Information

Received: Mon 12/29/2014 11:03 AM

Ms. Knoth, I believe you've summarized our conversation well; however, I did make a couple corrections/clarifications within your text below. If you need anything else from me let me know.
Thanks,

ClintNeed to return call by / at/between and

. Signature: ---

Please confirm the reported pounds of cadmium released to surface waters in 2013. 29,886 pounds

Please explain how the cadmium water release was calculated. The facility uses rock with naturally occurring low levels of metals as a raw material in the phosphoric acid production process. Samples of the rock used are sent to a lab for metals analysis. The metals concentration measurements from the raw material were used for TRI reporting threshold determination and not for the water

release estimates.

Cadmium water releases were estimated from three internal outfalls: 201, 3 01, and 401.

- For Outfalls 201 and 401, cadmium measurements were not taken, so the annual release was estimated by multiplying the permit limit value from the NPDES permit maximum daily concentration listed on Form 2C from the December 2008 pe rmit application by the average annual flow.

· Outfall 201: 25 lbs

· Outfall 401: 0 lbs

- Outfall 301 is stormwater and leachate collected from the inactive gypsum stack; it is the main source of metals in the wastewater at the facility. For 301, monthly analytical data was used to calculate the annual release. This data is collected as part of the facility’s NPDES permit. The average concentration (10.7 mg/L) was multiplied by the annual flow (335 Million Gallons or 2.8 Billion pounds water) to yield an annual release
of 29,862.

Were other metals (i.e., manganese, chromium, and copper) calculated using the same method?

The facility does not monitor for Manganese through its NPDES permit, so a methodology from a previous TRI reporting year was applied. Water release estimates for copper and chromium used the same methodology as for
cadmium. However, for Outfall 301 these pollutants (Cu and Cr) are measured quarterly as part o f NPDES reporting requirements.

Why were cadmium discharges reported starting in 2012 and not in prior years? Mr. Roberts and Mr. Hopper both started working at the facility around the same time and were responsible for TRI reporting beginning in RY20 12. They have not evaluated TRI reporting methodologies from prior years in

detail.