Need to return call by / at/between and

. Signature: Project No.: 0172.08.005.604 Page 1 of 2

Project Name: TRI2009 

### CBI?

Yes

No TELEPHONE CALL RECOR D Incoming Outgoing Date: 01/28 /11 Time: 2:00 am

pm

Company Name: Tronox, LLC ERG Staff Name: Kimberly Landick

Contact Name: Terry Freeze Contact Phone Number: ( 662) 343

- 8510

General Subject: 2009 TRI Manganese and Manganese Compounds Discharges



### TOPICS DISCUSSED AND ACTION TAKEN

On January 28 , 2011, I called Tronox, LLC to speak with Terry Freeze regarding 2009 TRI manganese and manganese compounds discharges. I left a message stating my name, the reason for calling, and if he could call me back or pass my information to the correct personnel for TRI data.

Terry Freeze returned my phone ca ll on January 31, 2011 at 8:45 am. I explained that I was ca lling for some specific information on 2009 TRI manganese and manganese compounds discharges reported by the facility.

Mr. Freeze asked that I send my questions via e

- mail so that he could gather the information. I sent an e

- mail at

10:45am on 01/31/11. P lease see the attached e

- mail correspondence.

On February 3, 2011 at 10:54am, I called Mr. Freeze to confirm that he received my e

- mail and didn’t have any questions. He stated that he was sending his response shortly. Please see the attached e

- mail corr espondence.

On February 9, 2011 at 7:50am, I called Mr. Freeze and left a message to confirm that he received my e

- mail and didn’t have any questions. He called me back at 8am and stated that he was hoping to send his response later today or tomorrow. Du e to weather conditions operations haven’t been completely normal and he is still waiting to hear back from some people but will hopefully be able to respond shortly.

On February 11, 2011 at 2:01pm, I received an e

- mail from Mr. Freeze with the 2009 data . After looking at the information I called Mr. Freeze on February 23, 2011 at 9am and discussed the data that he sent. He said that the high concentration value in June of 2009 was noticed. He thinks that it is caused from the way they were managing the h ydraulic loading into the settling ponds during this time. They have a series of settling ponds and during storm events or maintenance activities the loading can become irregular and therefore cause a higher than average discharge of manganese and manganes e compounds. Mr. Freeze discussed that their process water goes from the process system to a treatment system and then to outfall 201. Their treatment system consists of a neutralization component and a series of settling ponds. He also stated that he has 2008 and 2010 data available and asked for a written request via e

- mail. This was sent at 9:10am, please see attached e

- mail correspondence.

On March 23 rd , 2011 at 12:13pm, I received a phone call from Matthew Peak from Tronox, LLC. He left a

message stating that he would like to talk to me about the confidentiality notice email that I had sent to Mr. Freeze. His phone number is 405

- 775

- 5443. On March 24 th , 2011 at 11:20am I returned his call and left a message asking for him to call me back. On March 25 th , 2011 at 5:28pm, Mr. Peak called me back and left a message asking for me to return his call. At 12:46pm on March 28 th , 2011 I called Mr. Peak back and left a

message.Need to return call by / at/between and

. Signature: On April 8 th , 2011 at 4:14pm I called Mr. Peak again and spoke to him about the c onfidentiality notice. I explained that the TRI data is public information but that we need permission to ignore the confidentiality notice at the bottom of the email correspondence in order to publish that information into the public docket through EPA. M r. Peak stated that it was alright to remove the language on the bottom of the emails and to publish the information.From: Kimberly Landick

Sent : 3/21 /11 11:40 AM

To: Freeze, Terry Subject: RE: Request for 2009 TRI Data Clarification

Mr. Freeze,

Thank you for the data you provided. I would like to request your permission to include the
information you sent below as part of documentation made available at regulations.gov.

EPA is working towards the publication of its 2011 Final Plan and hopes to include the email
(and spreadsheet attachment) below as part of the documentation that describes the corrections
made to the 2009 screening

- level review database. However, when there is an email
signature/footer that claims information as confidential, EP A cannot include it a part of the
public docket and handles it as CBI. If you approve, we will simply remove the following footer
from the email correspondence and include this information in the public docket.

Please reply to this e

- mail to let us know if it is ok to include the information in EPA's public

docket.

Thank you,
Kimberly

*FOOTER LANGUAGE BELOW*
"Tronox Confidentiality Notice!
If you are not the intended recipient of this e

- mail message, any use, distribution or copying of
the message is prohibited.
Please let me know immediately by return e

- mail if you have received this message by mistake,

then delete the e

- mail message.
Thank you."

---------------------------------------- Kimberly D. Landick
Environmental Engineer

Eastern Research Gr oup, Inc.
14555 Avion Parkway, Suite 200
Chantilly, VA 20151
kimberly.landick@erg.com

Phone: 703

- 633

- 1119From: "Freeze, Terry" <Terry.Freeze@tronox.com>

Sent: 3/10/11 10:59AM

To: Landick, Kimberly Subject: Re: Request for 2009 TRI Data Clarification

Kimberly, attached are the data you requested.

Thanks,

Terry

From: Kimberly Landick

Sent : 2/23/11 9:15AM

To: Freeze, Terry

Cc: swietlik.william@epa.gov; Eleanor Codding; Jessica Gray Subject: RE: Request for 20 09 TRI Data Clarification

Mr. Freeze,

Thank you for your time on the phone today. To aid in further understanding the data reported to the 2009 TRI for manganese and manganese compounds, could you please provide a copy of the

2008 and 2010 data for outf all 201 and 101?

If you have any questions, please call me at 703

- 622

- 1119. We appreciate your help in interpreting TRI data correctly.

Thank you, Kimberly

As part of the 2011 annual review, EPA is evaluating the data reported to the 2009 TRI and

n eeds further information to complete the review.

From: "Freeze, Terry" <Terry.Freeze@tronox.com>

Sent: 2/11/11 2:00 PM

To: Landick, Kimberly Subject: Re: Request for 2009 TRI Data Clarification

Kimberly, attached are the monitoring data and flow calculat ions used to determine Mn loading. If you have any questions please contact me.

Thanks,

TerryFrom: Kimberly Landick

To: Freeze, Terry

Sent: 2/3/2011 11:44:01 AM Subject: RE: Request for 2009 TRI Data Clarification

Mr. Freeze,

Thank you for your response. Could you please further explain how your manganese and manganese compounds load is calculated from effluent sample analyses? Also, could you please provide a copy of the monitoring data for all available years that you referenced in your previou s

e

- mail?

If it's easier to discuss this over the phone, please don't hesitate to call me at 703

- 633

- 1119. We appreciate your help in interpreting TRI data correctly.

Thank you, Kimberly

---------------------------------------- Kimberly D. Landi ck Environmental Engineer Eastern Research Group, Inc. 14555 Avion Parkway, Suite 200 Chantilly, VA 20151 kimberly.landick@erg.com

Phone: 703

- 633

- 1119

From: "Freeze, Terry" <Terry.Freeze@tronox.com>

Sent: 2/3/11 11:00 AM

To: Landick, Kimberly Subject: Re: Request for 2009 TRI Data Clarification

Kimberly, these are the responses to your questions. Please let me know if you have any questions.

Thanks,

Terry

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

Sent: Monday, January 31, 2011 9:48 AM

To: Freeze, Terry

Cc: swietlik.william@epa.gov; Eleanor Codding; Elizabeth Sabol; Jessica Gray Subject: Request for 2009 TRI Data Clarification

Mr. Freeze,Thank you for your tim e on the phone this morning. As discussed, EPA is requesting clarification of 2009 TRI data as part of our 2011 annual review of industrial discharges under Section 304 of the Clean Water Act. I am writing to request clarification of manganese and

manganes e compounds discharges, on EPA's behalf under Contract No. 68

- C

- 02

- 095. Please see below for further background.

EPA reviews TRI data to fulfill its review obligation under Section 304(b) of the Clean Water Act. The CWA requires EPA to annually review an d, 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 facili ties. EPA is currently conducting its 2011 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 2011 Effluent Guidelines Program Plan scheduled for publication in the Federal Register in 2011.

As part of the 2011 annual review, EPA is evaluating the data reported to the 2009 TRI and needs further information to complete the review. Specifically, we would like to clarify the amount of manganese and manganese compounds reported to the 2009 TRI. Please confirm/review the following data and questions below.

1. Please confi rm the pounds of manganese and manganese compounds released in

2009: 164,869 pounds

Yes.

2. Please explain how the manganese and manganese compounds load is calculated.

Effluent sample analyses

3. If the load is determined from monitoring data, were the concentrations above the detection limit? Is the monitoring data available?

Yes.

4. If any concentrations were reported below the detection limit, how did you incorporate those

concentrations?

Not applicable.

5. What is the source of the manganese and manganese compounds in the wastewater?

Titanium bearing sands used as process raw material.6. What flow did you use to calculate the load? Is the flow measured at the same location as the manganese, or at the final outfall?

Measured efflu ent flow at final outfall.

We appreciate your help in interpreting TRI data correctly. If you have any questions regarding this request, please call me at (703) 633

- 1119. If you would like to speak directly with EPA regarding this request, you can conta ct 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 Landick

--------------------------------- ------- Kimberly D. Landick Environmental Engineer Eastern Research Group, Inc. 14555 Avion Parkway, Suite 200 Chantilly, VA 20151 kimberly.landick@erg.com

Phone: 703

- 633

- 1119

Tronox Confidentiality Notice!

I f you are not the intended recipient of this e

- mail message, any use, distribution or copying of the message is prohibited. Please let me know immediately by return e

- mail if you have received this message by mistake,

then delete the e

- mail message.

Thank you.

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

Sent: Monday, January 31, 2011 10:47 AM

To: Freeze, Terry

Cc: swietlik.william@epa.gov; Eleanor Codding; Elizabeth Sabol; Jessica Gray Subject: Request for 2009 TRI Data Clarification

Mr. Freeze,

Thank you for your time on the phone this morning. As discussed, EPA is requesting clarification of 2009
TRI data as part of our 2011 annual review of industrial discharges under Section 304 of the Clean Water

Act. I am writing to request clarification of manganese and manganese compounds discharges, on EPA's

behalf under Contract No. 68

- C

- 02

- 095. Please see below for further background.

EPA 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 ofpollutants to waters of the U.S. from various categories of industrial facilities. EPA is currently conducting
its 2011 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 2011 Effluent Guidelines Program Plan scheduled for publication in the Federal

Register in 2011.

As part of the 2011 annual review, EPA is evaluating the d ata reported to the 2009 TRI and needs further
information to complete the review. Specifically, we would like to clarify the amount of manganese and
manganese compounds reported to the 2009 TRI. Please confirm/review the following data and
questions below

.

1. Please confirm the pounds of manganese and manganese compounds released in 2009: 164,869
pounds
2. Please explain how the manganese and manganese compounds load is calculated.
3. If the load is determined from monitoring data, were the concentrati ons above the detection limit? Is
the monitoring data available?
4. If any concentrations were reported below the detection limit, how did you incorporate those

concentrations?
5. What is the source of the manganese and manganese compounds in the wastewa ter?
6. What flow did you use to calculate the load? Is the flow measured at the same location as the
manganese, or at the final outfall?

We appreciate your help in interpreting TRI data correctly. If you have any questions regarding this
request, please call me at (703) 633

- 1119. 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 Landick

---------------------------------------- Kimberly D. Landick

Environmental Engineer

Eastern Research Group, Inc.

14555 Avion Parkway, Suite 200

Chantilly, VA 20151

kimberly.landick@erg.com

Phone: 703

- 633

- 1119