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Project No.: 0317.02.005.510 Page 1 of 2

Project Name: DMR2013 CBI?

Yes

No

TELEPHONE CALL RECORD

Incoming

Outgoing

Date: 12/22/14 Time: 3:30 am

pm

Company Name: John Morrell & Co. ERG Staff Name: Kimberly Bartell

Contact Name: Charles Schulz Contact Phone Number: (605) 330-3656

General Subject: 2013 TRI Hydrogen Sulfide Discharges for John Morrell & Co. 

TOPICS DISCUSSED AND ACTION TAKEN

I called Mr. Schulz on December 22nd and left a message. I did speak with Scott Langer who suggested calling 

back next week to talk to Mr. Schulz.

On December 30th, I called Mr. Schulz back and left a message.

Mr. Schulz returned my call on January 7 and requested more information via email. He stated that the facility 

has a covered anaerobic lagoon system and the H2S discharges were based on EPA’s formulation sheet. Mr. 

Schulz stated that Smithfield is their parent company and they received guidance on H2S discharges from Eric 

Lassalle. See attached email correspondence.

On July 14, 2015, I followed up with Mr. Schulz about the H2S discharges. Mr. Schulz reiterated that the 

corporate office (for Smithfield) provided guidance to calculate H2S discharges. All discharges in the 

spreadsheet sent in January are in units of ppm (mg/L). The facility has a rendering plant that includes a blood 

dryer. There are air emissions and biogas from this plant. Mr. Schulz also walked me through their wastewater 

treatment system at the facility:

Pretreatment System  Internal Rotator Screens  Dissolved air flotation cells  5 anaerobic lagoons 

aeration basins for activated sludge  2 clarifiers  sand screen  Chlorine contact station (sodium 

hypochlorinate) dechlorination (sodium disulfide)  discharge to stream

The H2S discharge is calculated by adding together the aeration basin fugitive emissions and the covered 

anaerobic H2S leakage. The H2S aeration basin fugitive emission calculations use emission factors from source 

test data collected at the facility, the covered anaerobic H2S leakage calculations use collection efficiencies 

from the Technical Support Document for Industrial Wastewater Treatment (see: 

http://www2.epa.gov/sites/production/files/2015-06/documents/subpart-ii_tsd.pdf). The facility provided an 

excel sheet with detailed calculations (attached). 
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Email Communication with John Morrell & Co.:

From: Charles.schulz@jmfg.com

To: Kimberly Bartell

Date: 1/15/15 1:16 PM

Subject: RE: 2013 TRI Clarification for Hydrogen Sulfide Discharges

Hi Kimberly,

I am attaching the work sheet we used here for the hydrogen sulfide emissions for the John Morrell facility in Sioux Falls, 

SD.

The 1,602 non-point emissions were from a calculated leak rate on the covered lagoons based flow throughput Million 

gallons, biogas production.

If you see something not right let me know.

Chuck Schulz

(605) 330-3656

From: Kimberly Bartell

To: Charles.schulz@jmfg.com

CC: Kim Wagoner, William Swietlik

Date: 1/7/15 4:49 PM

Subject: 2013 TRI Clarification for Hydrogen Sulfide Discharges

Dear Mr. Schultz:

Thank you for your time on the phone today. Eastern Research Group, Inc. (ERG) under EPA Contract No. EP-C-12-021, 

is e-mailing you to request information for John Morrell & Co in Sioux Falls, SD (TRI ID: 57117JHNMR1400N) . 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 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 guidelines," that limit the 

discharge of pollutants to waters of the U.S. from various categories of industrial facilities. EPA is currently conducting 

its 2015 annual review of existing effluent guidelines and potential industrial 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 reported to the 2013 

TRI from the facility. Please confirm/review the following data and questions below.

1. Please confirm the pounds of hydrogen sulfide released in 2013: 1,602 pounds

2. Please explain how the hydrogen sulfide load is calculated.

We appreciate your help in interpreting TRI data correctly. If you have any questions regarding this request, please call 

me at (517) 515-1721. If you would like to speak directly with EPA regarding this request, you can contact William F. 

Swietlik of EPA's Office of Water/Engineering Analysis Division by phone at (202) 566-1129 or by email: 

swietlik.william@epa.gov.

Thank you,

Kimberly