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

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: 1:30 am

pm

Company Name: Cargill Inc. ERG Staff Name: Kimberly Bartell

Contact Name: Jonathan Razink Contact Phone Number: (701) 671-1600

General Subject: 2013 TRI Hydrogen Sulfide Releases for Cargill Inc., in Wahpeton, ND (Direct discharger)

TOPICS DISCUSSED AND ACTION TAKEN

Jonathan Razink: 701-671-1600, jonathan_razink@cargill.com

I called Mr. Razink on December 22nd and was told to send an email with our questions. Please see attached 

email correspondence. 

Mr. Razink returned my call on January 8th, 2015 to answer my questions. He stated that the facility 

manufactures high fructose corn syrup. They have their own wastewater treatment plant with an aerobic and 

anaerobic system. The breakdown of their food products ends up in the wastewater. Mr. Razink believes that the 

hydrogen sulfide discharges are a result of the wastewater treatment at the facility (microorganisms breaking 

down COD from waste), not directly from their manufacturing process. The facility also creates biogas from the 

wastewater treatment system that is reused at the facility, there are gaseous H2S discharges in this as well but 

these discharges are not aqueous. 

To determine aqueous H2S concentrations in their effluent, the facility took 4 direct samples from their outfall 

at the wastewater treatment plant before discharging into the Red River (at effluent point). These samples were 

taken on different days, but all within the same 1-2 weeks. They were all taken at the same location. The facility 

uses HACH Method 8131 and received guidance on determining H2S discharges from their trade association. A 

concentration measurement of dissolved sulfide was taken for each of the 4 samples, and then averaged out over 

the 4 days. The concentration was then multiplied by flow to and converted to determine lbs/day. The facility 

then assumed this concentration for each day of the year to reach the lbs/year reported to TRI. See below 

calculations. The facility confirmed that the 62,453 lbs is correct. 

Data used to determine concentrations:

Average dissolved sulfide concentration: 23.25 mg/L

Average flow for the year: 0.88 MGD

Formula: 23.25 mg/L * 0.88 MGD * 8.34 lbs/gallon = 170.64 lbs/day

170.64 lbs/day * 366 days (leap year) = 62,453 lbs/year
Need to return call by / at/between and . Signature:

Email Correspondence:

To: jonathan_razink@cargill.com

From: Kimberly Bartell

CC: Kim Wagoner, William Swietlik

Date: 12/22/14 2:17PM

Subject: 2013 TRI Clarification for Hydrogen Sulfide Discharges

Dear Mr. Razink:

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 Cargill, Inc. in Wapheton, ND. See below for background on what the 

information is used for.

EPA reviews publicly-available DMR 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 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 Cargill facility. Please confirm/review the following data and questions below.

1. Please confirm the pounds of hydrogen sulfide released in 2013: 62,453 pounds

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

Please call me at (517) 515-1721 once you have collected the above information. 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

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

Kimberly D. Bartell

Environmental Engineer

Eastern Research Group, Inc.

kimberly.bartell@erg.com

Phone: 517-515-1721