Need to return call by / at/between and

. Signature: Project No.: 

### 0 317.0 2 .005.510 Page 1 of 3

Project Name: 

### DMR20 1 3 

## CBI?

Yes

No TELEPHONE CALL RECOR D Incoming Outgoing Date: 

### 12/22 /1 4 Time: 

### 2 :3 0 am

pm

Company Name: 

### Smithfield Farmland Corp ERG Staff Name: 

### Kimberly Bartell

Contact Name: 

### Susan Murphy Contact Phone Number: 

### ( 816) 550

- 8922

General Subject: 

### 2013 TRI Hydrogen Sulfide Discharges for Smithfield Farmland Corp in Denison, IA



## TOPICS DISCUSSED AND ACTION TAKEN

On December 22 nd 

### , I called Mr. Bottjen and left a message (712

- 263

- 7300)

.

On December 29 th 

### Justin Terrell returned my call and left a message. He stated that he is the environmental coordinator for Smithfield Farmland in Denison, IA and he received my contact info from Mr. Bottjen. His

number is 712

- 490

- 3338. I returned his call on December 30 t h 

### and left a message. Mr. Terrell returned my call

on December 30 th 

### and we discussed the TRI hydrogen sulfide discharges. Mr. Terrell stated that he would prefer that I speak with Susan Murphy who is the environmental director for all of Smithfield Farmlan d. Their facility received a spreadsheet from corporate and plugged in facility specific data. He stated that the facility sent their wastewater samples to a lab and had them tested for hydrogen sulfide but then used the corporate spreadsheet to

calculate the discharges reported.

On December 29 th 

### , Susan Murphy, the corporate environmental director for Smithfield Farmland called me and left a message (out of Missouri), her phone number is 816

- 550

- 8922. I returned her call on December 30 th 

### and left a messag e. On December 30 th 

### she returned my call and requested that I email her with our contract

information. Please see attached email communication.

On January 14 th 

### at 5pm, Susan Murphy returned my call. Ms. Murphy confirmed the hydrogen sulfide data for

the three Smithfield Farmland facilities: Denison, IA, Clinton, NC, and Smithfield, VA. She stated that the discharges reported to TRI are based on direct sampling at each facility. At the Denison, IA and Smithfield, VA

facilities there are two anaerobic uncov ered lagoons as part of the on

- site wastewater treatment. The Smithfield, VA facility has more treatment technologies than other facilities so their hydrogen sulfide discharges are lower. She stated that the following process is used at the IA and VA facil ities:

Pretreatment  Anaerobic Lagoons (biological activity)  Outfall (effluent)

In the anaerobic lagoons the assumption of 5% of H2S released to atmosphere is used, the rest is assumed to be in water. The sample is taken at the outfall and sent to an outside lab. The ppm result from the lab is multiplied by the wastewater flow to esti mate discharge to POTW for lagoons. Ms. Murphy stated that this is probably an overestimate but they want to be conservative. They use literature on the air side for hydrogen sulfide but direct samples on the wastewater side.

At the Clinton, NC facility, there is a big tank (no lagoon) and the effluent is sampled prior to sending to the

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

. Signature: 

### Ms. Murphy stated that in general the H2S is a result of lagoon activity and wastewater treatment; it is not from a specific process. She also stated that the faci lity did not request any guidance from EPA or trade associations on H2S discharges. They did a direct sample because they were unsure what else to do.

Email Communication with Smithfield Farmland:

From: su san.murphy@sf

- fl.com To: Kimberly Bartell

Date: 1/14/2015 8:21 AM Subject: RE: 2013 TRI Clarification for Hydrogen Sulfide Discharges

Hello Kimberly I am still out of town but will be able to answer your questions today if you will be in the office. I will try dialing your phone sometime this late afternoon

Susan A. Murphy

Smithfield

- Farmland Corp Sr. Director Environmental Engineering

From: Kimberly Bartell

To: susan.murphy@sf

- fl.com CC: Kim Wagoner, Wil liam Swietlik

Date: 12/30/14 5:03 PM Subject: 2013 TRI Clarification for Hydrogen Sulfide Discharges

Dear Ms. Murphy:

Eastern Research Group, Inc. (ERG) under EPA Contract No. EP

- C

- 12

- 021, is e

- mailing you to request information for

Smithfield Farmland. See below for background on what the information is used for.

EPA reviews publicly

- available discharge monitoring report (DMR) and toxic release inventory (TRI) data to fulfill its

review o bligation 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 guidelines," that limit the discharge of pollutants to wat ers of the U.S. from various categories of industrial facilities. EPA is currently conducting its 2015 annual review of existing effluent guidelines and potential industrial guidelines which may need to be included (see http://www.epa.gov/guide/304m/ for further information). EPA will discuss this review and the results in its 2015 Effluent Guidelines Program Plan scheduled for publication in the Federal Register sometime in 2015 or 2016.

As part of the 2015 annual review, EPA is evaluating the data reported to the 2013 TRI and needs further information to complete the review. Specifically, we would like to clarify the amount of hydrogen sulfide releases to TRI from three

Smithfield Farmland facilities. Please confirm/review the following data and questions below.

1. Please confirm the pounds of hydrogen sulfide released in 2013 for the following facilities:

a. Smithfield Farmland in Denison, IA: 22,306 pounds

b. Smithfield Farmland in Clinton, NC: 21,657 pounds

c. Smith field Farmland in Smithfield, VA: 1,338 pounds

2. Please explain how the hydrogen sulfide load is calculated for each facility.

Please call me at (517) 515

- 1721 once you have collected the above information. If you would like to speak directly with EPA rega rding this request, you can contact William F. Swietlik of EPA's Office of Water/Engineering Analysis Division by phone at (202) 566

- 1129 or by email: swietlik.william@epa.gov

.

Thank you,Need to return call by / at/between and

. Signature: Kimberly

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

Phone: 517

- 515

- 1721