Need to return call by / at/between and

. Signature: Project No.: 

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

Project Name: 

### DMR20 1 3 

## CBI?

Yes

No TELEPHONE CALL RECOR D Incoming Outgoing Date: 

### 12/22 /1 4 Time: 

### 1 :3 0 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 Release s 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 22 nd 

### and was told to send an email with our questions. Please see attached email correspondence.

Mr. Razink returned my call on January 8 th 

### , 2015 to answer my questions. He stated that the facility manufactures high fructose corn syrup. They have their own waste water 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 br eaking 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 d ays, 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 take n 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/yearNeed 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 b ackground 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 "effl uent 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 ma y 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

Fe deral 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 re ported 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