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Project No.: 0317.02.005.510 Page 1 of 4

Project Name: DMR2013 CBI?

Yes

No

TELEPHONE CALL RECORD

Incoming

Outgoing

Date: 12/17/14 Time: 1:00 am

pm

Company Name: Graftech International, Anmoore, WV ERG Staff Name: Kimberly Bartell

Contact Name: Bill Williams Contact Phone Number: (304) 624-1331

General Subject: 2013 DMR Arsenic Discharges

TOPICS DISCUSSED AND ACTION TAKEN

On December 17th, I called the general number for Graftech International (304-624-1200) and left a message 

with Bill Williams (direct line: 304-624-1331, William.williams@graftech.com). 

I received Dan Arnold’s contact information from John Lockhert at WV DEP. Mr. Arnold works for MSES 

Consultants. Phone number: 304-624-9700, email: Daniel.t.arnold@msesinc.com.

I called Mr. Arnold on Dec 18thand left a message. 

I called Mr. Arnold on Dec 23rd and left a message.

I called Mr. Arnold on Jan 7th, 2015 and left a message.

I called Mr. Arnold on Jan 9th, 2015 and left a message.

I called Mr. Arnold on Jan 13th, 2015 and left a message. I also called Bill Williams at Graftech International on 

Jan 13th and left a message.

On January 15th, 2015, Bill Williams at Graftech returned my call. He stated that the facility had an inspection 

in 2013 by WV DEP and was told that their units are sometimes incorrect (for example in May 2013 and Dec 

2014). Contact did not provide corrected data; he requested an email with the information. He did state that 

outfall 026 doesn’t typically flow. And outfall 038 is representative of 036 and 037 because 036 and 037 never 

flow (unless there’s a storm event). Please see attached email correspondence.

Mr. Williams called on January 22nd and left a message stating he had received my email. They are working on 

confirming the data and answering our questions. He stated that the flow values that we have are incorrect but 

the arsenic concentrations are correct. Their team is working on collecting the data. In the area where the 

facility is located arsenic concentrations are common because of the mining activity and they believe the higher 

discharges in 2013 were an isolated issue. I called Mr. Williams back on January 23rd and left a message. 

I called Mr. Williams on January 28th and left a message.

See attached email communication and response from the facility.
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Email Communication with Graftech in Anmoore, WV:

From: Kimberly Bartell

To: William Williams (William.williams@graftech.com)

Date: 2/4/15 5:13 PM

Subject: RE: Followup

Bill:

Thank you for sending us this information, we greatly appreciate your facility looking into the data. I’ll review the memo 

you sent and let you know if we have any further questions.

Kim

--------------------------------------

Kimberly D. Bartell

Environmental Engineer

Eastern Research Group, Inc.

kimberly.bartell@erg.com

Phone: 517-515-1721

From: William Williams (William.williams@graftech.com)

To: Kimberly Bartell

Date: 2/4/15 4:58 PM

Subject: Followup

Kim,

Sorry for the delay, I just now realized I had not sent this to you. If you have any questions or need additional 

clarification, let me know.

Thanks,

Bill Williams

HSEP Manager

GrafTech International 

101 North Philippi Pike

Anmoore, WV 26323-0120

(w) 304-624-1331

(c) 304-476-2392

(f) 304-624-1242

"Get smart, use safety from the start"

From: Kimberly Bartell

To: William Williams (William.williams@graftech.com)

Date: 1/30/15 11:22 AM

Subject: RE: 2013 DMR Clarification for Arsenic and Aluminum Discharges

Mr. Williams:

We are looking at the DMR data using EPA’s DMR Pollutant Loading Tool: http://cfpub.epa.gov/dmr/
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This tool pulls DMR data from the ICIS-NPDES database. It doesn’t look like the DMR corrections submitted have made 

it into the ICIS-NPDES database yet because they are not showing up in the DMR Loading Tool. 

What would be most helpful to us is for you to provide us with the detailed response with the data corrections and then 

follow up with the WV DEP to confirm the DMR data changes will be incorporated. Having the updated corrections now 

will be extremely helpful for our analyses, but it will not ultimately fix the underlying data in DMR. That needs to be 

done through WV DEP. 

Let me know if you have any further questions, I’ll be in the office until 3 today. 

Thank you!

Kimberly

--------------------------------------

Kimberly D. Bartell

Environmental Engineer

Eastern Research Group, Inc.

kimberly.bartell@erg.com

Phone: 517-515-1721

From: William Williams (William.williams@graftech.com)

To: Kimberly Bartell

Date: 1/30/15 11:04 AM

Subject: RE: 2013 DMR Clarification for Arsenic and Aluminum Discharges

Kimberly,

I have a quick question, the information on the DMR you referred to regarding the flow units, when did you pull that 

information? My HSEP Engineer made several corrections in 2013, however, what we recently found is that once the 

DMR was submitted and then had to be corrected, it doesn’t update. You have to go ot another screen to see the 

corrections. I also found that Arsenic value was incorrectly reported. It should have been reported .00083. The date was 

misread from the EDD supplied to us from Microbac. It was just a data transfer error. We confirmed that because 019 is 

a representative outfall for 026. Therefore, 019 should have had the same reading for 026, but it didn’t.

I am preparing a detailed letter for your records and just wanted to confirm whether or not you might have been looking at 

data that would have been corrected already.

Call me if you have additional questions. I want to provide you the complete response today.

Thanks,

Bill Williams

HSEP Manager

GrafTech International 

101 North Philippi Pike

Anmoore, WV 26323-0120

(w) 304-624-1331

(c) 304-476-2392

(f) 304-624-1242

"Get smart, use safety from the start"

From: Kimberly Bartell
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To: William Williams (William.williams@graftech.com)

CC: William Swietlik, Kim Wagoner

Date: 1/15/15 2:49 PM

Subject: 2013 DMR Clarification for Arsenic and Aluminum Discharges

Dear Mr. Williams:

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 2013 discharge monitoring reports for Graftech International 

in Anmoore, WV (WV0004707). Please see background information below.

EPA reviews publicly-available DMR 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 2015 annual review of existing 

effluent guidelines and potential industrial guidelines which may need to be included 

(seehttp://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 sometime in 2015 or 2016. As part of 

the 2015 annual review, EPA is evaluating the data in discharge monitoring reports from 2013 and needs further 

information to complete the review.

We would like to obtain additional information on the following 2013 discharge data for Graftech International. Our 

records show the following values were discharged:

Outfall Date

Arsenic 

Concentration 

(mg/L)

Aluminum 

Concentration 

(mg/L) Flow (MGD)

026 7/31/2013 2.48 -- 4.99

036 1/31/2013 -- 2.87 0

036 7/31/2013 -- 1.25 14.3

037 1/31/2013 -- 0.025 0

037 7/31/2013 -- 1.25 14.3

038 3/31/2013 -- 1.25 0.0205

038 6/30/2013 -- 1.74 14.2

038 9/30/2013 -- 1.3 0.039

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
GrafTech International Holdings Inc.

GR•AEinterna~ioijai Redefining limits Anmoore, West ‘vlrgirua USA 26323

Phone: 1.304.624.1200

Kimberly D. Bartell

Environmental Engineer

Easter Research Group, Inc

Ms. Bartell,

In response to your January 15th, 2015 correspondence regarding the 2013 DMR report, the following

information was found:

1. Outfall 026 Arsenic concentration results reported for 7/31/13 should have read 0.00083.

Outfall 019 represents outfall 026; they have the same results. An error was found in

transferring these results from the lab reports. We have contacted WVDEP in regards to

changing this input value.

2. The concentration results for Outfall 036 and 038 are correct.

3. The concentration Results for Outfall 037 Aluminum were reported correctly as under the MDL

of 0.05 on 8/13/13. There were several corrections and updates made to the eDMR in 2013.

Some of the information that Eastern Research Group has may have been before these

corrections were made.

4. Outfalls 036 and 037 for July 2013 were represented by 038 outfall. 038 is a quarterly

requirement while 036 and 037 were required on a semi-annual basis. The reference manual

for reporting did not cover this situation. In discussions with the DEP, it was found that this

was an issue with multiple industrial sites in WV. In February 2014, this issue was corrected in

the reference manual. Graftech will follow-up with the DEP regarding the results that might

have been entered prior to the reference manual update.

5. All of the flows that are over 0 were entered in GPM instead of MGD. They are updated below.

Aluminum

Arsenic Concentration Concentration

Outfall Date (mg/L) (mg/L) Flow (MGD)

4.99 (actual:

026 7/31/2013 2.48 (actual 0.00083) 0.0071 9)
GrafTech International Hold i ngs Inc.

GRAF Redefining imi ~ 101 N. Philippi Pike

Inernafionai Anmoore, West Virginia USA 26323

Phone: 1.304.624.1200

036 1/31/2013 2.87 0

14.3 (actual: 1.25 036 7/31/2013 -- 0.0206)

0.025 (actual: 0

037 1/31/2013 -- <0.05)

14.3 (actual: 1.25 037 7/31/2013 -- 0.0206)

038 3/31/2013 -- 1.25 0.0205

038 14.2 (actual: 1.74 6/30/2013 -- 0.0204)

038 9/30/2013 -- 1.3 0.039

If you need additional information and clarification, please do not hesitate to contact me.

HSEP Manager

GratTech International Holdings, Inc.

Anmoore, West Virginia Plant