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Project No.: 0317.02.005.510 Page 1 of 14

Project Name: DMR2013 CBI?

Yes

No

TELEPHONE CALL RECORD

Incoming

Outgoing

Date: 12/4/14 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 2014-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 document:

- PCA Wallula-DDCL.pdf

- Resolute Calhoun-Hg Corrected.pdf

- RockTenn Hopewell-H2S.pdf

- IP Georgetown.pdf

- PulpPaper Sulfide Summary-final.pdf
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Email Communication with AF&PA and NCASI: July & October 2015

From: Kimberly Bartell 

To: Paul Wiegand, pwiegand@NCASI.org

CC: Jerry Schwartz, jerry_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@NCASI.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 Dischargers

Paul,

I wanted to follow up on my original email from July 13th. 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 answers 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 Dischargers

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 forwarded 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 summary 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 summary 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 mill 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 to 
Need to return call by / at/between and . Signature:

water, we would expect that such measurements 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 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, 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 collected 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 information 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 concentration 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 for 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: 517-515-1721
Need to return call by / at/between and . Signature:

Email Communication with AF&PA and NCASI: November 2014 – January 2015

From: 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, Elizabeth 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 further 

questions. 
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At this point it looks like we are only waiting for a response from International Paper’s Georgetown Mill on their dioxin and dioxin 

like compound discharges in TRI. 

Thanks again,

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: 1/26/15 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 congener 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 Georgia-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 treatment 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 current 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 H2S TRI Report
Need 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 H2S 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 H2S 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 value 

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_Schwartz@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

Subject: 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 Engineer
Need 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 concentration 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

Research 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 Gentile, 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 provided 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 data 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

Kimberly,

As noted earlier this week, we have contacted all of the facilities for which you had questions concerning TRI and DMR reports for 

certain substances being evaluated as part of your regular effluent guidelines review. This e-mail represents a partial response to the 

questions posed. Responses are provided for Boise in Wallula, WA (PCDD/F), RockTenn in Hopewell, VA (H2S), 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 paper mill 

wastewaters. This information should help you to better understand TRI reports for H2S 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-final.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 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: Kim Wagoner, Elizabeth Gentile, jerry_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 distributions 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 sulfide 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 are 

still gathering supporting data. If you have any data regarding a POTW’s removal of H2S discharges that would be helpful, as we 
Need 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 interested in how 

the mills, both direct and indirect 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. 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: 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 industry 

releases and now have a couple 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 mills 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. Both 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 would 

be oxidized (and/or released to the atmosphere), very little of the hydrogen sulfide would be expected to pass 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

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

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 Dischargers
Need to return call by / at/between and . Signature:

Jerry and Paul,

Thank you for your time on the phone yesterday. Below is the additional 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 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. 

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-inventory-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 help 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 Tool 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 directly to 

the state 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 attached an excel 

sheet 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 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: 12/1/14 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. 

Conference 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

From: 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 27709-3318
Need to return call by / at/between and . Signature:

phone (919) 941-6417

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

From: 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 discharges in 

DMR, and hydrogen sulfide and dioxin discharges in TRI. 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 2015 

Annual Review.

Thank you,

Kim

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

Kimberly D. Bartell

Environmental Engineer

Eastern Research Group, Inc.

kimberly.bartell@erg.com

Phone: 517-515-1721
Need to return call by / at/between and . Signature:

Pulp and Paper Category (40 CFR Part 430)

Summary of EPA’s 2015 Annual Review for 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 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 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 2015 Effluent Guidelines Program Plan scheduled for publication in the 

Federal Register in 2015 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 sulfide 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 confirm 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 these 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 AF&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 Georgetown, 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 appreciate 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.
ncasi

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, 2014

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 ERG are

attached to this memo.

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

Attachment

ec: Jerry Schwartz, AF&PA
Boise 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)
ncasi

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, 2014 (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 corrected 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.

2013 Monthly Sample Results for Mercury Resolute, Calhoun, Tennessee, (mg/L)

2013 Month Data Obtained by ERG Corrected 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













ncasi

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, 2014

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: The 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 the amount estimated to be in the wastewater

discharge from the mill and the amount collected in kraft pulping condensates, which are also

discharged 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
ncasi

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 2012/2013 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. Please 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 (Congener

No. 1). The lab report is attached and the value for this congener is “non-detect.”

3. Please explain 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 intake 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 Regarding 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 (H2S) 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 effluent limitations guidelines (ELGs) for industrial categories. Like other industrial

categories, the pulp and paper industry reported H2S 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 concentrations of reduced sulfur, including H2S, in treated mill

wastewaters.

INTRODUCTION

Hydrogen sulfide (H2S) 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 recovery of pulping liquors can

produce H2S and some H2S precursors, and certain wastewaters from the liquor recovery cycle can

contribute H2S to mill wastewater. H2S may also be formed in wastewater collection or treatment systems

by way of biologically mediated reduction of sulfate (SO4=) or other oxidized sulfur species.

H2S is both volatile and readily converted to chemical forms that are rapidly oxidized in the presence 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,

H2S does not occur at high concentrations in properly treated wastewaters. It is possible, however, for

trace levels of H2S to be present in some treated effluents.

ANALYZING FOR HYDROGEN SULFIDE

Analytical techniques for measuring H2S at low concentrations in aqueous samples are not

straightforward, owing to both the reactivity of H2S and the manner in which wastewater properties affect

the speciation of reduced inorganic sulfur. In particular, it is important to distinguish H2S from total

sulfide (TS) measurements. Sulfide determinations 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 H2S plus

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 H2S. The majority of metallic sulfides would not be significant sources of

H2S 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 (S2-) 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 H2S is challenging due to its absorptive, adsorptive, photo reactive, volatile,

biologically active, and oxidative properties, which can lead to imprecise measurements.

As noted, H2S 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 sulfide forms passing a 0.7 μm filter) (NCASI 2015). H2S 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 H2S concentrations. During

method development, only one treated final effluent was sampled; dissolved sulfides were less than the

analytical detection limit of 0.01 mg S/L for that sample. A comparison 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 H2S in final effluent. For example, aerobic biological activity can convert H2S to

oxidized species (e.g., SO4

2-

), while anaerobic activity can generate H2S from oxidized species.

Because sulfides can be both generated and destroyed in wastewater treatment systems, it is not possible

to make generic statements about the “treatability” of H2S across treatment systems of various types.

However, because H2S 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 H2S entering 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 wastewater treatment system (NCASI

2008).
3

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

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

Facility

Inlet

Stream

Total Sulfide

Concentration

(μg S/L)

Outlet

Stream

Total Sulfide

Concentration

(μg S/L) Removal

Mill 1 ASB inlet 2,570 ASB outlet 48 98.1%

Mill 2 ASB inlet (94.6% of flow) 511 ASB outlet 24.8 99.6%

Condensates (5.4% of flow) 102,825

Mill 3 ASB inlet 19,340 ASB outlet 91.5 99.5%

Mill 4 AS inlet 6,846 AS outlet 19 99.7%

ASB = aerated stabilization basin treatment

AS = activated sludge treatment

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 H2S in final

effluents because H2S is only one component of TS. TS data presented in this section 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 sulfide 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

(H2S, HS-) plus sulfide weakly associated with either dissolved organic matter or 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 H2S 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 recoveries 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 FurnishaProcess Typeb WWTPc

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 multiple sampling

dates and analyses

ND = not detected above method detection limit

Table 2 represents 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. An average is presented for treated mill effluents sampled more than once. TS concentrations

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 onehalf of the method detection limit for purposes of calculating an average concentration.

Figure 3 is a plot of the data from Table 2. TS concentrations 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. Non-detect values are plotted at 0.01 mg/L, approximately one-half of the detection limit.

For reasons noted earlier, concentrations of H2S 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 (H2S) was reportable under SARA 313 beginning in 2012 and the substance can occur

at some pulp and paper mills. H2S is one of several forms of reduced sulfur that are collectively referred

to as total sulfides (TS). The information presented herein focuses on the presence, fate, and treated final

effluent concentrations of H2S and total sulfides in pulp and paper mill wastewaters. Key points include:

 H2S is not directly measureable in aqueous matrices because of its variable presence depending on

pH, temperature, ionic strength, and organic and inorganic complexes;

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

H2S;

 measurements for TS made at 25 mills showed that biologically treated final effluent concentrations

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 H2S from TS data.
6

REFERENCES

Moeller, T., Bailar, J., Kleinberg, J., Guss, C., Castellion, M., and Metz, C. 1980. Chemistry with

inorganic qualitative analysis. New York: Academic Press Inc.

National Council for Air and Stream Improvement, Inc. (NCASI). 2015. Development and evaluation of

a method for measuring dissolved sulfide in pulp and paper mill wastewaters. 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

compounds 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. Development 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.