Need to return call by / at/between and

. Signature: Project No.: 

### 0 317.0 2 .005.510 Page 1 of 14
Project Name: 

### DMR20 1 3 

## CBI? Yes No TELEPHONE CALL RECOR D Incoming Ou tgoing Date: 

### 12/4 /1 4 Time: 

### 12 :00 am pm

Company Name: 

### AF&PA and NCASI ERG Staff Name: 

### Kimberly Bartell

Contact Name: 

### Jerry Schwartz (AF&PA)

Paul Wiegand (NCASI) Contact Phone Number: 

### Jerry: (202) 463

- 2581 Paul: (919) 941

- 6417
General Subject: 

### 2013 DMR and TRI Pulp and Paper Discharges



## TOPICS DISCUSSED AND ACTION TAKEN

I set up a conference call with Jerry Schwartz from AF&PA and Paul Wiegand from NCASI on December 4, 2014. We discussed DMR mercury discharges and TRI hydrogen sulfide and dioxin releases on the call. Both Jerry and Paul stated that they are more than happy to help us answer our questions for the 2015 Annual Review

.
Email correspondence with AF&PA and NCASI is below , broken out between November 201 4

- January 2015 correspondence and July/October 2015 correspondence . An overview of the topics discussed from the December 4, 2014 meeting are also attached.

Additionally, the following attachments from AF&PA and NCASI are included at the end of this doc ument:

- PCA Wallula

- DDCL.pdf

- Resolute Calhoun

- Hg Corrected.pdf

- RockTenn Hopewell

- H2S.pdf

- IP Georgetown.pdf

- PulpPaper Sulfide Summary

- final.pdfNeed to return call by / at/between and

. Signature: 

### Email Communication with AF&PA and NCASI: July & October 2015

From: Kimberly Bartell To: Paul Wiegand, pwiegand@NCASI.org CC: Jerry Schwartz, jer ry_schwartz@afandpa.org Date: 10/7/15 4:08 PM Subject: RE: 2013 DMR and TRI Pulp and Paper Dischargers

Paul,

Thank you for sending this information. I will review it and let you know if we have any further questions.

Kim

From: Paul Wiegand, pwiegand@NC ASI.org To: Kimberly Bartell CC: Jerry Schwartz, jerry_schwartz@afandpa.org Date: 10/7/15 9:51 AM Subject: RE: 2013 DMR and TRI Pulp and Paper Dischargers

Kimberly,

Responses from Georgia

- Pacific concerning the two referenced questions are shown below. Please let me know if you have any follow

- up questions.

Question 2: The mill stated that the 2013 TRI H2S release was based on a measured treated effluent concentration of 1.435 mg/L. What is the effluent concentration a measurement of? Total sulfides ?

Answer: The effluent value was 1.435 mg/L of total sulfide.

Question 3: The facility also stated that internal wastewater treatment system improvements reduced the effluent concentration in 2014. What were these improvements and how did they reduce the sulfide discharges?

Answer: The treatment basins were dredged of accumulated solids. This increased the available aeration zone and reduced the potential for hydrogen sulfide production from anaerobic activity due to the settled solids.

Paul

Paul Wiegand Vice President, Water Resources & Director, Northern and Western Regions National Council for Air and Stream Improvement (NCASI), Inc. 1513 Walnut Street, Suite 200 Cary, NC 27511 phone (919) 941

- 6417 cell (919) 607

- 8120 fax ( 919) 941

- 6401 PWiegand@ncasi.org

From: Kimberly Bartell To: Paul Wiegand, pwiegand@NCASI.org CC: Jerry Schwartz, jerry_schwartz@afandpa.org Date: 10/5/15 2:34 PM Subject: RE: 2013 DMR and TRI Pulp and Paper Disch argers

Paul,

I wanted to follow up on my original email from July 13 th . You provided an answer to our first question, but I wanted to see if you ever heard back from Georgia

- Pacific (questions 2

- 3 below)? Please let me know if you were able to obtain ans wers to these questions.Need to return call by / at/between and

. Signature: Thank you! Kim

From: Kimberly Bartell To: pwiegand@NCASI.org CC: jerry_schwartz@afandpa.org Date: 7/21/15 5:24 PM Subject: RE: 2013 DMR and TRI Pulp and Paper Dischargers

Hi Paul,

Thank you for providing this information. I’ll look through it and let you know if we have any additional questions about hydrogen sulfide.

Thanks again, Kimberly

-------------------------------------- Kimberly D. Bartell Environmental Engineer Eastern Research Group, Inc. kimberly.bartell@erg.com Phone: 517

- 515

- 1721

From: Paul Wiegand, pwiegand@NCASI.org To: Kimberly Bartell CC: Jerry Schwartz, jerry_schwartz@afandpa.org Date: 7/21/15 3:19 PM Subject: RE: 2013 DMR and TRI Pulp and Paper Di schargers

Kimberly,

This is a partial follow

- up to the questions you asked concerning information we submitted related to the 2015 ELG Annual Review Report. This note relates to questions embodied in Question No. 1. Questions No. 2 and 3 have been for warded to Georgia

- Pacific.

Question No. 1 (broken down by sentence)

In the H2S summary it is stated that NCASI sampled 25 pulp and paper mills in the U.S. and Canada in 2012 for total sulfide concentrations.

Comment: Please note that the H2S summ ary does not state that the 25 pulp and paper mills were sampled in 2012, rather that data from 25 mills were published in 2012. Work at some of the mills was conducted prior to 2012.

Based on the factors discussed in the memo, the concentrations may be high biased estimates for hydrogen sulfide.

This statement is correct.

How does the data collected for the 25 pulp and paper mills relate to the reported releases in TRI?

The data reported in NCASI 2012 and related data discussed in the H2S summ ary are available to NCASI members to assist them with their TRI reporting. As you know, mill staff use various means to estimate releases for purposes of TRI reports, ranging from mill specific measurements to engineering estimates. To the extent that m ill staff relied on NCASI data for calculating water releases, the estimated releases could be biased high due to issues with the analytical procedure as described in the H2S summary.

Do the facilities use the same methodology when reporting releases to TRI as they did during the study (based on total sulfide concentrations)?

NCASI has not queried the facilities for which we generated total sulfide data in treated effluents to determine how, or if, these data were used for TRI reporting by these mills. Neither has NCASI queried mills regarding the method they may have used to estimate water releases for H2S. However, to the extent that mills made measurements in effluents for purposes of estimating H2S releases toNeed to return call by / at/between and

. Signature: water, we would expect that such measu rements would have been total sulfide measurements and subject to the same potential high bias as the measurements made by NCASI in our work.

Please let me know if you have further questions.

Paul Wiegand Vice President

- Water Quality National Counc il for Air and Stream Improvement (NCASI), Inc. P.O. Box 13318 Research Triangle Park, NC 27709

- 3318 phone (919) 941

- 6417 cell (919) 607

- 8120 fax (919) 941

- 6401 PWiegand@ncasi.org

From: Kimber ly Bartell To: pwiegand@NCASI.org, jerry_schwartz@afandpa.org Date: 7/13/15 4:31 PM Subject: RE: 2013 DMR and TRI Pulp and Paper Dischargers

Paul and Jerry,

Based on the information both of you provided in January, ERG drafted the pulp and paper section of the 2015 Annual Review Report. As the report section was reviewed, a few questions were brought up that we request your assistance with.

The first question focuses on the hydrogen sulfide summary (PDF), attached for reference.

1. In the H2S summary it is stated that NCASI sampled 25 pulp and paper mills in the U.S. and Canada in 2012 for total sulfide concentrations. Based on the factors discussed in the memo, the concentrations may be high biased estimates for hydrogen sulfide. How does the data colle cted for the 25 pulp and paper mills relate to the reported releases in TRI? Do the facilities use the same methodology when reporting releases to TRI as they did during the study (based on total sulfide concentrations)?

The next questions focus on the i nformation provided by the Georgia

- Pacific mill in Monticello, MS. The email chain is attached for reference.

2. The mill stated that the 2013 TRI H2S release was based on a measured treated effluent concentration of 1.435 mg/L. What is the effluent concentr ation a measurement of? Total sulfides? 3. The facility also stated that internal wastewater treatment system improvements reduced the effluent concentration in 2014. What were these improvements and how did they reduce the sulfide discharges?

I apologize f

or the delay in asking follow

- up questions, please let me know if any clarification is needed.

Thank you, Kim

-------------------------------------- Kimberly D. Bartell Environmental Engineer Eastern Research Group, Inc. kimberly.bartell@erg.com Phone: 517

- 515

- 1721Need to return call by / at/between and

. Signature: 

### Email Communication with AF&PA and NCASI: November 2014

– January 2015

F rom: Kimberly Bartell To: pwiegand@NCASI.org CC: jerry_schwartz@afandpa.org , Kim Wagoner, Elizabeth Gentile Date: 1/30/15 11:43 AM Subject: RE: Responses to ERG Questions

– Georgetown

Paul & Jerry,

Thank you for providing all of the responses. We’ll review the information and let you know if we have any questions.

Again, we greatly appreciate all your help!

Kimberly

-------------------------------------- Kimberly D. Bartell Environmental Engineer Eastern Research Group, Inc. kimberly.bartell@erg.com Phone: 517

- 515

- 1721

From: pwiegand@NCASI.org To: Kimberly Bartell CC: Kim Wagoner, Elizabeth Gentile, jerry_schwartz@afandpa.org Date: 1/30/15 10:31 AM Subject: Responses to ERG Questions

– Georgetown

Kimberly,

Attached you will find responses to questions posed for the Georgetown mill. Please let me know if you have any questions concerning these responses.

[Attachment: Bartell

- ERG

- IP

- Georgetown.pdf]

Paul

Paul Wiegand Vice President

- Water Quality National Council for Air and Stream Improvement (NCASI), Inc. P.O. Box 13318 Research Triangle Park, NC 27709

- 3318 phone (919) 941

- 6417 cell (919) 607

- 8120 fax (919) 941

- 6401 PWiegand@ncasi.org

From: Kimberly Bartell To: pwiegand@NCASI.org CC: jerry_schwartz@afandpa.org , Kim Wagoner, Elizab eth Gentile Date: 1/27/15 7:49 AM Subject: RE: Responses to ERG Questions

– Pine Hill and Monticello

Paul,

Thank you for this information, we greatly appreciate it. We will review the details below and let you know if we have any fu rther questions.Need to return call by / at/between and

. Signature: At this point it looks like we are only waiting for a response from International Paper’s Georgetown Mill on their dioxin and di oxin like compound discharges in TRI.

Thanks again, Kimberly

-------------------------------------- Kimberly D. Bartell Environme ntal Engineer Eastern Research Group, Inc. kimberly.bartell@erg.com Phone: 517

- 515

- 1721

From: pwiegand@NCASI.org To: Kimberly Bartell CC: Kim Wagoner, Elizabeth Gentile, jerry_schwartz@afandpa.or g Date: 1/26/15 11:49 AM Subject: Responses to ERG Questions

– Pine Hill and Monticello

Kimberly,

I have received updates from International Paper’s Pine Hill mill and Georgia

- Pacific’s Monticello mill regarding your questions. Responses are as follows:

International Paper, Pine Hill, TRI Report for Dioxin and Dioxin

- like Compounds Facility Specific Question: 1. Please confirm the 2013 dioxin distribution shown above. Please confirm that the 2012 and 2013 distributions reflect the 2008 TRI dioxin con gener numbering change (in Dioxin Congener tab). Response: The mill has confirmed that the data for 2012 and 2013 were reported using the old (pre

- 2008) congener numbering scheme rather than the revised numbering scheme in use for the 2008 reporting year and beyond. The facility will make an effort to correct the data in the TRI database.

Georgia

- Pacific, Monticello, TRI Report for Hydrogen Sulfide Releases to Water Facility Specific Question: 1. Please confirm the hydrogen sulfide discharges.

The Ge orgia

- Pacific

- Monticello, Mississippi mill originally and correctly reported a mass release of 115,148 pounds per year of hydrogen sulfide for the 2012 TRI based on a measured treated effluent concentration of 1.435 mg/L. After internal
wastewater treatme nt system improvements, the measured treated effluent concentration of hydrogen sulfide was reduced to 0.415 mg/L which reduced the calculated mass release at the same flow rate to 32,097 pounds per year. The 2014 value is more representative of the curren t situation.

Please let me know if you have any questions about these responses.

Paul

Paul Wiegand Vice President

- Water Quality National Council for Air and Stream Improvement (NCASI), Inc. P.O. Box 13318 Research Triangle Park, NC 27709

- 3318 phone (919) 941

- 6417 cell (919) 607

- 8120 fax (919) 941

- 6401 PWiegand@ncasi.org

From: Kimberly Bartell To: jerry_schwartz@afandpa.org CC: pwiegand@NCASI.org Date: 1/20/15 7:32 AM Subject: RE: SAPPI H2 S TRI ReportNeed to return call by / at/between and

. Signature: Jerry,

Thank you for providing this information. It should be sufficient, but I will do a closer review and let you know if we have any additional questions.

Thanks again, Kimberly

-------------------------------------- Kimberly D. Bartell Environmental Engineer Eastern Research Group, Inc. kimberly.bartell@erg.com Phone: 517

- 515

- 1721

From: jerry_schwartz@afandpa.org To: Kimberly Bartell CC: pwiegand@NCASI.org Date: 1/19/15 4:40 PM Subject: SAPPI H2S TRI Report

Kimberly,

I have contacted the SAPPI Cloquet mill regarding the H 2 S value of 175,000 pounds per year reported for 2013. That value was based on one sample taken in 2006, as part of an odor reduction project the mill had undertaken. As part of that work, the mill sampled plant effluent for H 2 S on 12/15/2006

– the test results were 8.6 ug/l. The mill used that as an average effluent concentration and applied actual 2013 effluent volume to arrive at the reported value.

However, in response to my inquiry, the mill reviewed the calculations underlying the reported value. It appears that the mill accidentally reported grams/yr instead of lbs/yr. The value of 174,673 grams/year is equivalent to 385 lbs/yr and the latter val ue should have been reported The calculations supporting the corrected value are shown below. The mill intends to submit a revised TRI report to correct the error. Calculations for Corrected Value:

(8.6 ug/l) x (1g/1,000,000 ug) x (3.785 l/gal) x (1 lb / 453.6 g) x 5,373,000,000 gal/yr = 385 lb/yr Please let me know if you have any questions or need more information. Jerry

Jerry Schwartz Senior Director Energy and Environmental Policy Jerry_Schwart z@afandpa.org (202) 463

- 2581 AMERICAN FOREST & PAPER ASSOCIATION 1101 K Street, N.W., Suite 700 Washington, D.C. 20005

From: Kimberly Bartell To: pwiegand@NCASI.org CC: Kim Wagoner, Elizabeth Gentile, jerry_schwartz@afandpa.org Date: 1/22/15 8:48 AM Subj ect: RE: 2013 DMR and TRI Pulp and Paper Dischargers

Paul,

Thank you for this information. We’ll let you know if we have any further questions.

Kimberly

-------------------------------------- Kimberly D. Bartell Environmental EngineerNeed to return call by / at/between and

. Signature: Eastern Research Group, Inc. kimberly.bartell@erg.com Phone: 517

- 515

- 1721

From: pwiegand@NCASI.org To: Kimberly Bartell CC: Kim Wagoner, Elizabeth Gentile, jerry_schwartz@afandpa.org Date: 1/22/15 8:09 AM Subject : RE: 2013 DMR and TRI Pulp and Paper Dischargers

Kimberly,

Please find attached a corrected memo summarizing the data for Hg at Resolute’s Calhoun, Tennessee mill. The summary table has been corrected and the mill has confirmed that the December concen tration of 37.2 ng/L is the value that represents the discharge.

[Attachment: Bartell

- ERG

- Resolute Calhoun

- Hg Corrected.pdf]

Paul Paul Wiegand Vice President

- Water Quality National Council for Air and Stream Improvement (NCASI), Inc. P.O. Box 13318 Res earch Triangle Park, NC 27709

- 3318 phone (919) 941

- 6417 cell (919) 607

- 8120 fax (919) 941

- 6401 PWiegand@ncasi.org

From: pwiegand@NCASI.org To: Kimberly Bartell CC: Kim Wagoner, Elizabeth Genti le, jerry_schwartz@afandpa.org Date: 1/19/15 4:21 PM Subject: RE: 2013 DMR and TRI Pulp and Paper Dischargers

Kimberly,

Part of this is my mistake. The summary table on the cover letter is missing the month of August and the values for later in the year are incorrectly shifted as a result. The lab sheets are correct. In looking over these again, however, I noticed that there are two values shown on the December sheet, and it is not clear whether just one or both are circled. I have contacted the mill with this follow

- up question and when I hear back I will send you and updated/corrected letter. My apologies for the mistake.

Paul

From: Kimberly Bartell To: pwiegand@NCASI.org CC: Kim Wagoner, Elizabeth Gentile, jerry_schwartz@afandpa.org Date: 1/19/15 1:31 PM Subject: RE: 2013 DMR and TRI Pulp and Paper Dischargers

Paul,

Thank you for providing the information below. Upon review, we wanted to confirm one data point for the Resolute facility in Calhoun, TN. A summary of the mercury discharges was prov ided for the facility in the attached pdf. On the last page of this pdf the data for December 2013 is listed. ERG would like to confirm that we should use the value of 37.2 ng/L for this month. This da ta is missing from the summary table on the first page of the pdf, therefore, we would like to confirm we are using the correct value.

Thank you! Kimberly

--------------------------------------Need to return call by / at/between and

. Signature: Kimberly D. Bartell Environmental Engineer Eastern Research Group, Inc. kimberly.bartell@erg.com Phone: 517

- 515

- 1721

From: pwiegand@NCASI.org To: Kimberly Bartell CC: Kim Wagoner, Elizabeth Gentile, jerry_schwartz@afandpa.org Date: 1/9/15 8:57 AM Subject: RE: 2013 DMR and TRI Pulp and Paper Dischargers

Kimbe rly,

As noted earlier this week, we have contacted all of the facilities for which you had questions concerning TRI and DMR report s for certain substances being evaluated as part of your regular effluent guidelines review. This e

- mail represents a partia l response to the questions posed. Responses are provided for Boise in Wallula, WA (PCDD/F), RockTenn in Hopewell, VA (H 2 S), and Resolute in Calhoun, TN (Hg). Attached to this message are individual .pdf files that provide the information you are seeking for each of these facilities. We will continue to pursue responses from the remaining facilities.

Also attached to this message is a summary describing sources, fate, and effluent concentrations of sulfides in pulp and pape r mill
wastewaters. This in formation should help you to better understand TRI reports for H 2 S releases to water. If you have questions concerning the facility responses or the sulfide summary paper, please do not hesitate to contact me.

[Attachments: PulpPaper Sulfide Summary

- fina l.pdf, Bartell

- ERG

- PCA Wallula

- DDCL.pdf, Bartell

- ERG

- Resolute Calhoun

- Hg.pdf, Bartell

- ERG

- RockTenn Hopewell

- H2S.pdf]

Paul

Paul Wiegand Vice President

- Water Quality National Council for Air and Stream Improvement (NCASI), Inc. P.O. Box 13318 Research Tr iangle Park, NC 27709

- 3318 phone (919) 941

- 6417 cell (919) 607

- 8120 fax (919) 941

- 6401 PWiegand@ncasi.org

From: Kimberly Bartell To: pwiegand@NCASI.org CC: Kim Wagoner, Elizabeth Gentile, jer ry_schwartz@afandpa.org Date: 12/12/14 3:55 PM Subject: RE: 2013 DMR and TRI Pulp and Paper Dischargers

Hi Paul,

Thank you for looking into our questions. I’ve provided responses to your follow up questions below.

After reviewing the dioxin and dioxin

- like compound discharges for the International Paper Mills in Pine Hill and Georgetown, we did identify loads for reporting years 2008 through 2013. For the Pine Hill Mill, we anticipate that the 2012 and 2013 distributi ons reflect the old dioxin congener numbering scheme (updated in 2008), compared to their 2011 distribution. We would like to see if they can confirm their distribution. However, the discharges for the Georgetown facility have increased from 2011 and 2013. Therefore, we are still interested in learning about the cause of the increase in discharges and any sampling data they may have used to estimate discharges. I’ve attached a revised spreadsheet with the 2011

- 2013 dioxin distributions and revised questions.

In regards to the hydrogen sulfid e discharges, we are aware that the SAPPI, Cloquet and RockTenn, Hopewell facilities send wastewater to POTWs for treatment. We are currently working on estimating POTW removals for the indirect discharges; but we a re still gathering supporting data. If yo u have any data regarding a POTW’s removal of H2S discharges that would be helpful, as weNeed to return call by / at/between and

. Signature: would like to be able to take that removal into account for facilities with indirect discharges. However, we are still intere sted in how the mills, both direct and in direct dischargers, estimated their discharges as this would inform our general understanding of the H2S discharge data reported to TRI.

Please let me know if you have any further questions.

Thank you, Kimberly

----------------------------- Kimberly D. B artell Environmental Engineer Eastern Research Group, Inc. kimberly.bartell@erg.com Phone: 517

- 515

- 1721

From: pwiegand@NCASI.org To: Kimberly Bartell CC: Kim Wagoner, Elizabeth Gentile, jerry_schwartz@afandp a.org Date: 12/12/14 7:24 AM Subject: RE: 2013 DMR and TRI Pulp and Paper Dischargers

Kimberly,

I’ve been in the process of following up on your request for information related to DMR and TRI reports for pulp and paper in dustry releases and now have a co uple of questions about the requested information. Some additional insight from ERG would help Jerry and I in following up with some of these facilities.

First, as regards the dioxin and dioxin

- like compound (DDLC) reports for the International Paper mil ls in Pine Hill and Georgetown, your questions include: “can you explain why no dioxin discharges have been reported prior to 2013”. One of my colleagues at NCASI and I have reviewed the TRI databases and we believe that both of these mills have reported DDLC every year since at least 2007 and probably before that (we didn’t look back further). Would any of your questions change given this information?

The second question concerns hydrogen sulfide TRI reports for SAPPI, Cloquet and RockTenn, Hopewell. B oth of these mills send wastewater to Publicly

- Owned Treatment Works (POTWs) for treatment. Neither mill reported wastewater releases to receiving waters (Part II, Section 5.3 in the Form R) but did report hydrogen sulfide releases to POTWs (Section 6.1). Recognizing that hydrogen sulfide is a reduced form of sulfur, and that most POTWs operate aerobic treatment systems where hydrogen sulfide wo uld be oxidized (and/or released to the atmosphere), very little of the hydrogen sulfide would be expected to pa ss through the POTW system. Thus, reports for hydrogen sulfide in section 6.1 of Form R are not really comparable to releases to receiving waters following on

- site wastewater treatment at mills as reported in Section 5.3. Does this information change any of the questions you would have us ask?

Thanks for the help. Paul

Paul Wiegand Vice President

- Water Quality National Council for Air and Stream Improvement (NCASI), Inc. P.O. Box 13318 Research Triangle Park, NC 27709

- 3318 phone (919) 941

- 6417 cel l (919) 607

- 8120 fax (919) 941

- 6401 PWiegand@ncasi.org If you do not wish to be contacted by NCASI please notify publications@ncasi.org

From: Kimberly Bartell To: jerry_schwartz@afandpa.org; pwiegand@NCASI.org CC: Kim Wagoner, Elizabeth Gentile Date: 12/5/14 11:15 AM Subject: RE: 2013 DMR and TRI Pulp and Paper DischargersNeed to return call by / at/between and

. Signature: Jerry and Paul,

Thank you for your time on the phone yesterday. Below is the ad ditional information we discussed on the call. Please let us know if you have any further questions.

Thanks! Kim

TRI Dioxin Data Facility name: Boise White Paper in Wallula, WA TRI ID: 99363BSCSCPOBOX The facility reported a total discharge of 0.124 gra ms dioxin in 2013 and their distribution has changed from previous years. We would be interested in any new sampling data from the facility for 2013 or 2014.

2013 TRI Dataset The final 2013 TRI dataset is publically available at the link below. Note that the top of the webpage says it’s a preliminary dataset but below it says that the data is complete and final. http://www2.epa.gov/toxics

- release

- inventor y

- tri

- program/2013

- tri

- preliminary

- dataset

DMR Loading Tool & ECHO Effluent Chart Information The DMR Loading Tool is available here: http://cfpub.epa.gov/dmr/ EPA uses this tool to present DMR And TRI data to he lp the public and industry understand who is discharging, what pollutants they are discharging and how much, and where they are discharging. The tool uses data from ICIS

- NPDES for DMR. Facilities can investigate and submit data errors in the DMR Loading To ol here: http://cfpub.epa.gov/dmr/error_correction.cfm

However, for DMR data the best way to submit errors is through the ECHO effluent chart system. These error reports go directl y to the stat e data stewards who can work with a facility to make sure the data in ICIS

- NPDES is correct. To access an effluent chart for a NPDES permit, use the ECHO Water Facility Search ( https://echo.epa.gov/facilities/facility

- search?mediaSelected=cwa ). On the search results page, facilities with Effluent Charts available have an "E" icon in the Reports column of the Results table. Clicking the "E" icon opens the Effluent Charts page in a new tab. If the NPDES permit ID is known, users can access the effluent charts directly by populating the following URL with the NDPES ID after the “#” sign: https://echo.epa.gov/effluent

- charts# , e .g., https://echo.epa.gov/effluent

- charts#LA1234567

.
For further information on the ECHO Effluent Charts including how to submit an error report, please refer to Effluent Charts Help ( https://echo.epa.gov/help/reports/effluent

- charts

- help ) or contact ECHO Technical Support through the Contact Us link at the top right of any ECHO web page.

----------------------------- Kimberly D. Bartell Environmental Engineer Eastern Research Group, Inc. kimberly.bartell@erg.com Phone: 517

- 515

- 1721

From: Kimberly Bartell To: jerry_schwartz@afandpa.org; pwiegand@NCASI.org CC: Kim Wagoner, Elizabeth Gentile Date: 12/3/14 12:43 PM Subject: RE: 2013 DMR and TRI Pulp and Paper Dischargers

Jerry and Paul,

Attached, please find an outline of the information we would like to discuss with you on our call tomorrow. I’ve also attache d an excel she et with facility

- specific data discussed in the outline. Please let me know if you have any questions, otherwise we will talk to you at 12 EST tomorrow.

Thank you! Kim

-----------------------------Need to return call by / at/between and

. Signature: Kimberly D. Bartell Environmental Engineer Eastern Rese arch Group, Inc. kimberly.bartell@erg.com Phone: 517

- 515

- 1721

From: Kimberly Bartell To: jerry_schwartz@afandpa.org; pwiegand@NCASI.org CC: Kim Wagoner, Elizabeth Gentile Date: 12/1/14 10:18 AM Subject: RE: 2013 DMR and TRI Pulp and Paper Dischargers

Jerry and Paul,

Thank you for getting back to us. Let’s plan on a call on Thursday (12/4) from 12

- 1, please confirm that this will work for both of you. I’ve included the call in information below.

Conferenc e Line: 888

- 346

- 3659 Entry Code: 9714193

Thank you! Kim

----------------------------- Kimberly D. Bartell Environmental Engineer Eastern Research Group, Inc. kimberly.bartell@erg.com Phone: 517

- 515

- 1721

Fro m: jerry_schwartz@afandpa.org To: Kimberly Bartell; pwiegand@NCASI.org CC: Kim Wagoner, Elizabeth Gentile Date: 11//30/14 8:38 PM Subject: RE: 2013 DMR and TRI Pulp and Paper Dischargers

Kimberly, yes, I would be happy to join a call. This week is a bit tight; here are some possibilities: Tues: 11

- 12 Thurs: 12

- 1 Fri: 10

- 1 or 4

- 5 Thanks for reaching out to us.

From: pwiegand@NCASI.org To: jerry_schwartz@afandpa.org; Kimberly Bartell CC: Kim Wagoner, Elizabeth Gentile Date: 11/25/14 5:26PM Subject: RE : 2013 DMR and TRI Pulp and Paper Dischargers

Kimberly,

I, and I’m quite certain Jerry, would be happy to participate on a call. My schedule next week is fairly open so let’s wait to learn what Jerry’s schedule looks like and go from there. Thanks for engaging us. These discussions have been helpful for several years now.

Paul

Paul Wiegand Vice President

- Water Quality National Council for Air and Stream Improvement (NCASI), Inc. P.O. Box 13318 Research Triangle Park, NC 27709

- 3318Need to return call by / at/between and

. Signature: phone (919) 9 41

- 6417 cell (919) 607

- 8120 fax (919) 941

- 6401 PWiegand@ncasi.org

If you do not wish to be contacted by NCASI please notify publications@ncasi.org

Fr om: Kimberly Bartell To: jerry_schwartz@afandpa.org; pwiegand@NCASI.org CC: Kim Wagoner, Elizabeth Gentile Date: 11/25/14 4:45PM Subject: 2013 DMR and TRI Pulp and Paper Dischargers

Jerry and Paul,

Eastern Research Group, Inc. (ERG) is assisting EPA with the 2015 Annual Review and would like to obtain additional information on DMR and TRI discharges associated with the pulp and paper category. Specifically, we have questions about mercury discharg es in DMR, and hydrogen sulfide and dioxin discharges in TR I. We would like to set up a call to discuss our questions if you have some time available next week. Please let us know some days and times that would work for you, we appreciate your help with the 20 15 Annual Review.

Thank you, Kim

--------------------- -------- Kimberly D. Bartell Environmental Engineer Eastern Research Group, Inc. kimberly.bartell@erg.com Phone: 517

- 515

- 1721Need to return call by / at/between and

. Signature: 

## Pulp and Paper Category (40 CFR Part 430) Summary of EPA’s 2015 Annual Review f or AF&PA & NCASI December 4, 2014

As EPA continues its 2015 review of industry discharges, we would like to confirm some of the 2013 DMR and TRI discharges.

As before, EPA reviews DMR and 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 appro p riate, 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 201 5 annual review of existing effluent guidelines and assessing the need for potential new industrial effluent guidelines (see http://www.epa.gov/guide/ 304m/ for further information). EPA plans to discuss this review and the results in its 201 5 Effluent Guidelines Program Plan scheduled for publication in the Federal Register in 201 5 or 2016.

As part of the 2015 annual review, EPA is evaluating 2013 DMR and TRI data and needs further information to complete the review. Specifically, we have questions regarding the following three topic areas.

1. Mercury Discharges in DMR One facility, Abibow US Inc, Calhoun Operations in Calhoun, TN (TN0002356) ranks high for mercury discharges in 2013 DMR data. We would like to confirm the mercury concentrations and concentration units in the attached excel sheet (DMR Mercury Discharges tab) to accurately interpret the data.

2. Hydrogen Sulfide Discharges in TRI Hydrogen su lfide was reinstated as a TRI chemical in 2012. In 2013, 93 pulp and paper facilities report hydrogen sulfide discharges to TRI. The top three facilities make up 60 percent of the total hydrogen sulfide discharges from pulp and paper facilities.

Please c onfirm the hydrogen sulfide discharges for the top three facilities listed below and in the attached excel sheet (TRI hydrogen sulfide discharges tab). In addition we would like for you to confirm how the hydrogen sulfide discharges were estimated for thes e facilities (e.g., wastewater sampling, mass balance calculations, guidance, etc.).

 SAPPI Cloquet LLC, Cloquet, MN

 Rocktenn CP LLC, Hopewell, VA

 Georgia

- Pacific Monticello LLC, Monticello, MS

Additionally, we would be interested in learning about any A F&PA/NCASI industry guidance for reporting hydrogen sulfide discharges, if such guidance exists.

3. Dioxin Discharges in TRI Two facilities rank high for dioxin discharges in 2013 TRI data: International Paper in Pine Hill, AL and International Paper in Geo rgetown, SC. Neither facility has reported dioxin discharges in recent years so they have not been contacted. We would like to confirm the dioxin concentrations and distributions in the attached spreadsheet (see the TRI Dioxin Discharges tab).

We apprec iate your help in interpreting the DMR and TRI data correctly. We look forward to speaking with you regarding these issues tomorrow at 12:00 EST.

# n ca si

NATIONAL COUNCIL FOR AIR AND STREAM IMPROVEMENT, INC. P.O. Box 13318, Research Triangle Park, NC 27709

- 3318 3106 East Highway 54, Research Triangle Park, NC 27709 Phone (919) 941

- 6417 Fax (919) 941

- 6401 Paul Wiegand Vice President, Water Quality pwiegand@ncasi.org



### December 18 , 201 4

TO: Kimberly Bartell , ERG

FROM: Paul Wiegand, NCASI

SUBJECT: Response to EPA Inquiry Concerning 2013 TRI Report for DDLC at PCA (Boise White Paper) in Wallula, Washington

Pursuant to your request, NCASI contacted staff at the PCA (formerly Boise) mill located in Wallula

, Washington concerning TRI releases reported in 2013 for dioxin and dioxin

- like compounds (DDLC). The requested data and responses to the questions posed by E RG are

a ttached to this memo

. Please contact me if y ou have additional questions about this information.

Attachment

ec: Jerry Schwartz, AF&PABoise White Paper LLC Year Grams Wallula, WA 2009 2.3204 99363BSCSCPOBOX 2011 1.5509 2012 2.4396 2013 0.1241

Notes Notes Congener Number 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 2009 (Submitted by Facility During 2011 Annual Review) 0.034618 0.003643 0.005942 0.005709 0.005425 0.261445 1.353729 0.470188 0.030226 0.045469 0 0 0.005193 0.004237 0 0 0.094554 TRI Report for 2011 ND = 0 2011 0 0 0 0 0 0.13964 1.14183 0.16143 0.03806 0.05145 0 0 0.01827 0 0 0 0.00026 Data requested by EPA in 2013 2012 0 0 0 0 0 0.246142 1.574584 0.240454 0.083771 0.141687 0 0.058174 0 0 0 0 0 TRI Report for 2012 ND = 0.5*DL 2012 0.0069 0.0143 0.0097 0.0095 0.0220 0.2461 1.5746 0.2405 0.0838 0.1417 0 0.0582 0.0160 0.0163 0 0 0 TRI Report for 2013 ND = 0.5*DL 2013 0.01289 0.0112 0.01008 0.01233 0.0119 0 0 0.04397 0.00695 0.00771 0 0 0.00374 0.00334 0 0 0

Congener Number 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 2009 Effluent Test Data (Submitted by Facility During 2011 Annual Review) 1.34 0.281 (ND) 0.459 (ND) 0.442 (ND) 0.420 (ND) 15.1 87.1 18.2 1.17 1.76 0.281 (ND) 0.284 (ND) 0.327 (ND) 0.401 (ND) 0.418 (ND) 0.380 (ND) 6.84 Method 1613 B Minimum Level 10 50 50 50 50 50 100 10 50 50 50 50 50 50 50 50 100 2011 Effluent Test Data ND ND ND ND ND 10.3 78.2 6.15 1.45 1.96 ND 0.673 0.696 ND 1.51 ND 3.19 2012 Effluent Test Data ND ND ND ND ND 14.5 95.6 9.30 3.24 5.48 ND 3.15 ND ND ND ND ND 2013 Effluent Test Data ND ND ND ND ND ND 20.8 ND ND ND ND ND ND ND ND ND ND 2014 Effluent Test Data ND ND ND ND ND ND 97.2 7.03 ND ND ND ND ND ND ND ND ND

EPA Question(s) "The facility reported a total discharge of 0.124 grams dioxin in 2013 and their distribution has changed from previous years. We would be interested in any new sampling data from the facility for 2013 or 2014."

Company Responses Data for 2012 and 2013 reflect new company reporting conventions. These include: (1) use of half of the sample-specific detection limit for values not-detected. Some congeners are periodically dectected in wastewater residuals and thus they could be present in mill effluent at values less than analytical detection limits. (2) for congeners 6, 7, 11, 12, 15, 16, and 17 - loads reflect the subtraction of mean concentrations found in raw surface water as reported in the NCASI TRI Handbook. (3) for congeners 6, 7, 11, 12, 15, 16, and 17 - if raw surface water concentrations are greater than effluent measured or ND values, zero grams is reported. Data for 2014 are provided in the table above. Total Water Release (g)

Effluent Sampling Data - (pg/L)

# n ca si

NATIONAL COUNCIL FOR AIR AND STREAM IMPROVEMENT, INC. P.O. Box 13318, Research Triangle Park, NC 27709

- 3318 3106 East Highway 54, Research Triangle Park, NC 27709 Phone (919) 941

- 6417 Fax (919) 941

- 6401 Paul Wiegand Vice President, Water Quality pwiegand@ncasi.org



### December 18 , 201 4 (corrected January 21 , 2015)

TO: Kimberly Bartell , ERG

FROM: Paul Wiegand, NCASI

SUBJECT: Response to EPA Inquiry Concerning 2013 DMR Reports for Mercury at Resolute in Calhoun, Tennessee

Pursuant to your request, NCASI contacted staff at the Resolute pulp and paper mill located in Calhoun, Tennessee concerning NPDES Discharge Monitoring Report (DMRs) data for mercury. As you suspected, the data obtained by ERG from EPA’s DMR database contained some errors

. The data obtained from the EPA database and the correct ed data obtained from the mill are shown in the following table. Attached to this memo are the raw laboratory sheets reporting the results of each monthly sample in 2013, i.e., the corrected data

.

201 3 Monthly Sample Results for Mercury Resolute, Calhoun, Tennessee, (mg/L)

201 3 Month Data Obtained by ERG Correct ed Data January 0.000099 0.000099* February 0.0002 <0.0002 March 0.06 <0.0002 April 0.06 <0.0002 May 0.05 <0.0002 June 0.05 <0.0002 July 0.0021 0.0000136 August 0.0000067 0.0000067 September 0.0602 <0.0002 October 0.0000069 0.0000069 November 0.0000086 0.0000086 December 0.00037 0.0000372 * estimated value, see “J” qualifier in lab report

Please contact me if you have additional questions about this information.

Attachment

ec: Jerry Schwartz, AF&PA

# n ca si

NATIONAL COUNCIL FOR AIR AND STREAM IMPROVEMENT, INC. P.O. Box 13318, Research Triangle Park, NC 27709

- 3318 3106 East Highway 54, Research Triangle Park, NC 27709 Phone (919) 941

- 6417 Fax (919) 941

- 6401 Paul Wiegand Vice President, Water Quality pwiegand@ncasi.org



### December 19 , 201 4

TO: Kimberly Bartell , ERG

FROM: Paul Wiegand, NCASI

SUBJECT: Response to EPA Inquiry Concerning 2013 TRI Report for Hydrogen Sulfide at RockTenn in Hopewell, Virginia

Pursuant to your request, NCASI contacted staff at the RockTenn mill located in Hopewell, Virginia concerning TRI releases reported in 2013 for hydrogen sulfide

. The questions you asked and the mill responses to those questions are provided below.

ERG request #1 : “ confirm the hydrogen sulfide discharges (to the POTW) .”

Mill response: T he reported 168,600 pound release to the POTW is correct

. ERG request #2 : “ confirm how the hydrogen sulfide discharges were estimated (e.g., wastewater sampling, mass balance calculations, guidance, etc.). ”

Mill response: The discharges to the POTW were calculated using the NCASI SARA Handbook factors . The amount reported represents th e amount estimated to be in the wastewater discharge from the mill and the amount collected in k raft pulping condensates, which are also d ischarged to the POTW for treatment in accordance with the MACT Standards at 40 CFR Part 63, Subpart S

.

Please contact me if you have additional questions about this information.

Attachment

ec: Jerry Schwartz, AF&PA

# n ca si

NATIONAL COUNCIL FOR AIR AND STREAM IMPROVEMENT, INC. P.O. Box 13318, Research Triangle Park, NC 27709

- 3318 3106 East Highway 54, Research Triangle Park, NC 27709 Phone (919) 941

- 6417 Fax (919) 941

- 6401 Paul Wiegand Vice President, Water Quality pwiegand@ncasi.org



### January 30 , 2015

TO: Kimberly Bartell , ERG

FROM: Paul Wiegand, NCASI

SUBJECT: Response to EPA Inquiry Concerning 201 2/2013 TRI Reports for Dioxin and Dioxin

- like Compounds at International Paper in Georgetown, South Carolina

Pursuant to your request, NCASI contacted staff at International Paper concerning the Toxics Release Inventory (TRI) reports made in 2012 and 2013 by their mill in Georgetown, South Carolina. Your questions related to the difference in reported values for dioxin and dioxin

- like compound (DDLC) releases to water for these years relative to 2011. Company responses to your specific questions are provided below. Supporting laboratory data is also attached

. Facility Specific Questions and Responses :

1. Plea se confirm the 2013 dioxin distribution shown above (in the Excel spreadsheet table).

Response: The data in the table are correct as reported by the mill.

2. Are there any updated sampling data for dioxin compounds (updated data sources, new sampling, etc .)? If there are updated sampling data, please provide a copy of the results.

Response: Updated sampling data are available only for 2,3,7,8

- TCDD (Congen er No. 1). The lab report is attached and the value for this congener is “non

- detect.”

3. Please e xplain the change in the reported dioxin distribution from 2011 to 2012.

Response: Data reported for 2011 were based on sampling results from more than a decade earlier. These data included the subtraction of congeners found at detectable levels in intak e water. For 2012 (and 2013) the older data was considered out of date and
instead the mill used effluent factors from NCASI and did not include credits for congeners in intake waters. The NCASI factor for 2,3,7,8

- TCDD (Congener No. 1) is zero. However, the mill misinterpreted the attached lab report and provided a non

- zero value for Congener No. 1. Future reports will reflect the updated data.

### Please contact me if you have additional questions about this information.

Attachment

ec: Jerry Schwartz, AF& PA

### 1



# A Summary of Information R egarding the Presence , Fate

, and Concentrations of Reduced Sulfur in Pulp and Paper Mill Treated Effluents

NCASI 2015

Prepared in Support of EPA Effluent Limitations Guidelines Evaluations

BACKGROUND
Beginning with the 2012 reporting year, industrial releases of hydrogen sulfide ( H 2 

### S ) were required to be estimated and reported under Section 313 of the Superfund Amendments and Reauthorization Act (SARA 313). EPA uses the data reported under SARA 313 for a variety of purposes. Among these uses, EPA’s Office of Water considers reported SARA 313 releases to water as part of its activity to review and plan for updating e ffluent limitations g uidelines (ELGs) for industrial categories. Like other industr ial categories, the pulp and paper industry reported H 2 

### S releases beginning in 2012. In response to an EPA request related to its recurring ELG review activities

, NCASI has prepared this summary of information related to the presence, fate, and co ncentrat ions of reduced sulfur, including H 2 

### S , in treated mill
wastewaters.

INTRODUCTION
Hydrogen sulfide ( H 2 

### S ) is one of several forms of reduced sulfur. It can occur in pulp and paper mill wastewater from two sources. At some chemical pulp mills, use and recov ery of pulping liquors can produce H 2 

### S and some H 2 

### S precursors, and certain wastewaters from the liqu or recovery cycle can contribute H 2 

### S to mill wastewater. H 2 

### S may also be formed in wastewater collection or treatment systems by way of biologically mediated reduction of sulfate (SO4=) or other oxidized sulfur species.

H 2 

### S is both volatile and readily converted to chemical forms that are rapidly oxidized in the pr esence of oxygen in wastewater. Because most wastewater treatment systems used in the forest products industry employ aerobic biological treatment or include aerobic zones prior to the release of treated wastewaters, H 2 

### S does not occur at high concentrati ons in properly treated wastewaters. It is possible

, however

, for trace levels of H 2 

### S to be present in some treated effluents.

ANALYZING FOR HYDROGEN SULFIDE
Analytical techniques for measuring H 2 

### S at low concentrations in aqueous samples are not straightforward, owing to both the reactivity of H 2 

### S and the manner in which wastewater properties affect the speciation of reduced inorganic sulfur. In particular, it is important to distinguish H 2 

### S from total sulfide (TS) measurements. Sulfide determin ations are, by necessity, method defined because sulfide assumes various forms depending on sample pH (Figure 1), temperature, dissolved oxygen, ionic strength, and the biological constituents present in the matrix. TS is defined herein as dissolved H 2 

### S p lus hydrosulfide ion (HS - 

### ) plus acid soluble metallic sulfide and sulfide weakly associated with organics in the sample. Metallic and organic sulfides may be present in pulp mill wastewaters and may ( but do not always ) serve as sources of H 2 

### S. The majori ty of metallic sulfides would not be significant source s of H 2 

### S under normal wastewater treatment facility operating conditions

, as they are mostly insoluble in water and require a strong acid to increase the solubility (Moeller et al. 1980). Sulfide (S 2

- 

### ) would also be considered a component of TS , but is present in negligible amounts unless sample pH is extremely basic.

### 2 Figure 1

. Dependence of Sulfide Dissociation on Liquid Phase pH

Analytical determination of H 2 

### S is challenging due to its absorptive, adsorptive, photo reactive, volatile, biologically active, and oxidative properties, which can lead to imprecise measurements.

As noted, H 2 

### S concentrations in treated mill effluents will be less than TS concentrations, in part due to the likely presence of metal and organic sulfide complexes disassociated during the analytical procedure. NCASI has recently developed a sampling system that allows for measurement of “dissolved” sulfides in aqueous samples (defined as sul fide forms passing a 0.7 μm filter) (NCASI 2015). H 2 

### S in an effluent would be in the dissolved form

, as would certain other reduced sulfur substances. Measurements of dissolved sulfides, therefore, would represent a lesser overestimate of H 2 

### S concentrati ons. During method development, only one treated final effluent was sampled ; dissolved sulfides were less than the analytical detection limit of 0.01 m g S/L for that sample. A c omparison of total and dissolved sulfides in various untreated or partially treated wastewater samples collected at five mills indicated that dissolved concentration ranged from 0 to 82% of the TS concentration

. HYDROGEN SULFIDE IN WASTEWATER TREATMENT
As illustrated in Figure 2, several processes in a pulp and paper mill treatment system can impact the concentration of H 2 

### S in final effluent. For example, aerobic biological activity can convert H 2 

### S to oxidized species (e.g., SO 4 2

- 

### ), while anaerobic activity can generate H 2 

### S from oxidized species.

Bec ause sulfides can be both generated and destroyed in wastewater treatment systems, it is not possible to make generic statements about the “treatability” of H 2 

### S across treatment systems of various types. However, because H 2 

### S is both volatile and easily oxidized, and because most wastewater treatment systems used in the forest products industry employ aerobic biological treatment or include aerobic zones prior to release of treated wastewaters, it is likely that most H 2 

### S enter ing forest products industry wastewater treatment systems is oxidized or otherwise removed from the wastewater prior to discharge of treated final effluent. Table 1 shows available data comparing inlets and outlets from biological treatment at four mills using aerobic treatment. Average values are shown where multiple measurements were made. For calculating averages, non

- detect values were replaced with one

- half of the detection limit. Removal at these mills was >98%, mostly due to oxidation in the wast ewater treatment system (NCASI 2008).

### 3

Figure 2. Sulfur Reactions in an Aerated Stabilization Basin Wastewater Treatment Plant

Table 1. Removal of Total Sulfide a cross Wastewater Treatment Systems (NCASI 2008)

Facility Inlet

Stream Total Sulfide

Concentration ( μ g S/L) Outlet

Stream Total Sulfide

Concentration ( μ g S/L) Removal Mill 1 ASB i nlet 2

, 570 ASB o utlet 48 98.1% Mill 2 ASB i nlet (94.6% of flow) 

### 511 ASB o utlet 24.8 99.6%

Condensates (5.4% of flow) 

### 102

, 825 Mill 3 ASB i nlet 19

, 340 ASB o utlet 91.5 99.5% Mill 4 AS i nlet 6

, 846 AS o utlet 19 99.7% ASB = aerated stabilization basin treatment AS = activated sludge t reatment



### TOTAL SULFIDE IN TREATED FINAL EFFLUENTS
NCASI has previously measured TS levels in biologically treated final effluents from 25 pulp and paper mills in the US and Canada. As noted, these data are not equivalent to concentrations of H 2 

### S in final effluents because H 2 

### S is only one component of TS

. TS data presented in this sect ion were obtained by analyzing final treated effluent samples using NCASI Method RSC

- 02.02 (NCASI 2007). The method utilizes direct aqueous injection gas chromatography coupled with a pulsed flame photometric detector (GC/PFPD). The concentration of sulf ide measured using this method represents the total amount of sulfide in the sample that is volatile at pH 2.5. It is believed that this includes all freely dissolved sulfide (H 2 

### S, HS - 

### ) plus sulfide weakly associated with either dissolved organic matter o r certain transition metals. Importantly, because biological treatment plants are typically operated at a neutral pH (much higher than 2.5), these numbers represent a high biased estimate of H 2 

### S levels in the samples assessed. NCASI Method RSC

- 02.02 is calibrated from 20 to 1000 μg S/L. The nominal method detection limit for TS is 32 μg S/L (0.03 mg/L). TS concentrations were converted from μg S/L to mg/L by multiplying the
μg S/L concentration by 1.06 (mass of hydrogen sulfide/mass of sulfur) and dividing the result by 1000 (1000 μg/1 mg).

### 4

The quality of the data generated was assured by method protocols including calibration checks, daily blank measurements, sample duplicate analyses, and matrix spiked samples with each set of samples analyzed on a given day. In addition, surrogate spike r ecoveries were determined within each matrix tested. All aspects of the quality control and assurance program were met or exceeded for the data reported herein. Table 2 provides information regarding mill furnish, process type, wastewater treatment plant (WWTP) type, number of samplings, and treated effluent concentrations

.

Table 2 Mill Wastewater Treatment Plants Sampled and Final Effluent Total Sulfide Concentrations (NCASI 2012)

Mill Code Furnish a 

### Process Type b 

### WWTP c 

### Sampling (n =) d 

### Average Conc

.

(mg/L) A SW kraft ASB 1 0.24 B SW, deink GW, TMP, recycle AS/ASB 1 ND C SW, OCC kraft ASB 3 0.09 D SW kraft, dissolving kraft ASB 3 0.10 E SW, OCC kraft, recycle ASB 1 ND F SW/HW, OCC kraft, recycle ASB 1 0.16 G SW, HW kraft ASB 2 0.13 H SW, HW, deink kraft, recycle ASB/AS 2 0.18 I SW kraft ASB 2 0.04 J HW, SW, OCC kraft, recycle, NSSC ASB 2 0.05 K HW, SW kraft ASB 1 ND L SW, deink TMP, recycle AS 3 0.10 M HW, OCC NSSC, recycle ASB/AS 2 0.24 N HW/SW kraft AS 1 ND O SW kraft ASB 2 0.04 P SW kraft ASB 8 0.28 Q SW/HW, OCC kraft, recycle ASB 1 0.23 R SW/HW kraft ASB 1 ND S SW/HW kraft ASB 2 0.07 T SW/HW kraft ASB 1 0.03 U SW/HW kraft ASB 2 0.29 V SW/HW kraft AS/ASB 2 ND W SW kraft, GW ASB 1 0.10 X SW, HW, not deinked kraft, NSSC, recycle ASB 1 0.06 Y SW kraft ASB 1 0.04

Mean Concentration 0.10 Range of Concentrations 0.02

- 0.29

a HW = hardwood; SW = softwood; OCC = old corrugated containers
b GW = groundwood; TMP = thermo

- mechanical pulping; NSSC = neutral sulfite semi

- chemical

c AS = activated sludge; ASB = aeration stabilization basin
d n=1 provides concentration for a single analysis and sample date, n>1 provides mean of multi ple sampling dates and analyses ND = not detected a bove method detection limit



### Table 2 r epresent s data from mills that were investigating odor

- related issues in which sulfide may have been a factor. It is, therefore, more representative of mills with higher levels of sulfide in wastewater and effluent. A n average is presented f or treated mi ll effluents sampled more than once. TS concentration s

were below the detection limit of the method for 6 of the 25 mills sampled. In cases where detect and

### 5

non

- detect values were found in effluents sampled more than once, non

- detects were replaced with one

half of the method detection limit for purposes of calculating an average concentration.
Figure 3 is a plot of the data from Table 2

. TS concentration s in biologically treated final effluents ranged from non

- detect to 0.29 mg/L with an average concentration of 0.10 mg/L and a median concentration of 0.07 mg/L . N on

- detect values are plotted at 0.01 mg/L , approximately one

- half of the detection limit. Fo r reasons noted earlier, concentrations of H 2 

### S in these effluents would have been less than or equal to the TS concentrations shown.

Figure 3

. Final Effluent Total Sulfide Concentrations at 25 Pulp and Paper Mills (NCASI 2012) ; [ average concentration of 0.10 mg/L (solid line) ; median concentration of 0.07 mg/L (dashed line) ;

Non

- detect values plotted at 0.01 mg/L (dotted) line ]

SUMMARY
Hydrogen sulfide ( H 2 

### S ) was reportable under SARA 313 beginning in 2012 and the substance can occur at some pulp and paper mills. H 2 

### S is one of several forms of reduced sulfur that are collectively referred to as total sulfides (TS). The information presented here in focuses o n the presence, fate, and treated final effluent concentrations o f H 2 

### S and total sulfides in pulp and paper mill wastewaters. Key point s include:

 H 2 

### S is not directly measureable in aqueous matrices because of its variable presence depending on pH, tempera ture, ionic strength, and organic and inorganic complexes ;

 TS measurements are defined by the measurement method used and yield a high biased estimate of H 2 

### S ;

 measurements for TS made at 25 mills showed that biologically treated final effluent concentratio n s ranged from non

- detect to 0.29 mg/L ( average 0.10 and median 0.07 mg/L ) , and that 6 of the 25 samples were non

- detect at a nominal detection limit of 0.03 mg/L ;

 removal of total sulfide across aerobic biological treatment at 4 mills was greater than 98%; and

 a new sampling system developed by NCASI may allow measurement of dissolved sulfides

, which would lessen the high bias in estimates of H 2 

### S from TS data.

### 6

REFERENCES
Moeller, T., Bailar, J., Kleinberg, J., Guss, C., Castellion, M., and Metz, C. 198 0. Chemistry with inorganic qualitative analysis

. New York: Academic Press Inc.
National Council for Air and Stream Improvement, Inc. (NCASI). 201 5

. Development and evaluation of a method for measuring dissolved sulfide in pulp and paper mill wastewate rs

. Technical Bulletin ( in
press )

. Research Triangle Park, NC: National Council for Air and Stream Improvement, Inc.
National Council for Air and Stream Improvement, Inc. (NCASI). 2012. The presence, fate, and ecological significance of hydrogen sulfide in pulp and paper mill effluents . Technical Bulletin No. 997. Research Triangle Park, NC: National Council for Air and Stream Improvement, Inc.
National Council for Air and Stream Improvement, Inc. (NCASI). 2008. Emissions of reduced sulfur

com pounds and methane from kraft mill wastewater treatment plants . Technical Bulletin No. 956. Research Triangle Park, NC: National Council for Air and Stream Improvement, Inc.
National Council for Air and Stream Improvement, Inc. (NCASI). 2007. Developm ent and application of a method for measuring reduced sulfur compounds in pulp and paper mill wastewaters

. Technical Bulletin No. 933. Research Triangle Park, NC: National Council for Air and Stream Improvement, Inc.