Need to return call by / at/between and

. Signature: Project No.: 

### 0 317.0 2 .005.510 Page 1 of 4

Project Name: 

### DMR20 1 3 

## CBI?

Yes

No TELEPHONE CALL RECOR D Incoming Outgoing Date: 

### 12/1 7 / 1 4 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 17 th 

### , I called the general number for Graftech International (304

- 624

- 1200) and left a message

with Bill Wil liams (direct line: 304

- 624

- 1331 , William.williams@graftech.com).

I received D a n 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 18 t h 

### and left a message.

I called Mr. Arnold on Dec 23 rd 

### and left a message.

I called Mr. Arnold on Jan 7 th 

### , 2015 and left a message.

I called Mr. Arnold on Jan 9 th 

### , 2015 and left a message.

I called Mr. Arnold on Jan 13 th 

### , 2015 and left a message. I also called Bill Williams at Graftech International on

Jan 13 th 

### and left a message.

On January 15 th 

### , 2015, Bill Williams at Graftech returned my call. He stated that the facility had an inspection in 2013 by WV DEP and was tol d 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 o f 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 22 nd 

### and left a message stating he had received my email. They are working on confirming the data and ans wering 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 23 rd 

### and left a message.

I called Mr. Williams on January 28 th 

### and left a message.

See attached email communication and response f rom the facility.Need to return call by / at/between and

. Signature: 

### 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 apprecia te 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

Su bject: 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/Need to return call by / at/between and

. Signature: 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 t he 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 underl ying 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 R esearch 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 the n 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 Mic robac. 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 co nfirm 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 BartellNeed to return call by / at/between and

. Signature: 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

- availa ble 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 guideline s 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 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

- 1721GrafTech International Holdings Inc. 

# G

R•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