From: "Love, B. (Brian)" <Brian.Love@akzonobel.com>

To: Elizabeth Sabol <Elizabeth.Sabol@erg.com>

Date: 8/16/2011 10:13 AM Subject: RE: Carbon Disulfide - Follow Up

Elizabeth: If I am not mistaken the repor ted solubility value of 0.2% would repres ent 2000 ppmv. We have seen the opposite conc lusion, the CS2 is very volatile and quickly moves from the water to the air. I spoke with one of our chemists and he remembers having difficul ty trying to achieve the reported solubility value due to volatilization of the free CS2 into the va por space, and dissolved levels were qui ckly dropping. I find the 17 mg/l value that you mention after aeration and biologi cal treatment very inconsistent with our experience. Lookin g at analytical values from the discharge points of our wa stewater treatment system (aeration/neutra lization only), the concentrations were nor mally much less than 1mg/l with an overall removal in excess of 99%. Best Regards,

Brian Love Principal Environmental Engineer Global Environmental Affairs Group, HSE Governance

T +1 770 246 4627

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E brian.love@akzonobel.com<mailto:name.surname@akzonobel.com>

AkzoNobel 3587 Parkway Lane Norcross, GA 30092 www.akzonobel.com<http://www.akzonobel.com/>

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From: Elizabeth Sabol [mailto:Elizabeth.Sabol@erg.com] Sent: Monday, August 15, 2011 8:18 AM To: Love, B. (Brian) Cc: Alicea.Jezebele@epa.gov; Eleanor Codding Subject: Carbon Disulfide - Follow Up

Brian,

Thank you for your information so far regarding the chemical a nd physical properties of carbon di sulfide. Below, I've included some background information and a follow-up question we ha ve for you regarding carbon disulfide.

From the carbon disulfide air emission and water discharge data we have for several facilities, it appears that more than the e stimated amount of carbon disulfide (with a solubility of 0.2%) is not volatilizing, but is staying in the water. For example, one facility retain ed a maximum concentration of 17.1 mg/L of carbon disulfide after biological treatment through an aeration basin and final clarification. Ha ve you ever studied or do you have any data on wh ether carbon disulfide follows ideal gas or solubility laws?

Thank you in advance for your time,

Elizabeth

Elizabeth A. Sabol Environmental Engineer Eastern Research Group, Inc. 14555 Avion Parkway, Suite 200 Chantilly, VA 20151 elizabeth.sabol@erg.com<mailto:elizabeth.sabol@erg.com>

Phone:703-633-1659

From: "Love, B. (Brian)" <Brian.Love@akzonobel.com>

To: "elizabeth.sabol@erg.com" <elizabeth.sabol@erg.com>

CC: "Bisinger, E.C. (Edwin)" <Edwin.Bisinger@akzonobel. com>, "Scott, K(Kathy)" <K athy.Scott@AkzoNobel.com>

Date: 7/1/2011 11:17 AM Subject: Carbon Disulfide - Fate and Transport

Elizabeth: I am in receipt of your email request from Edwin Bisi nger. We have reviewed Eastern Research Group's request for inf ormation under EPA Contract No. 68-C-02-095 regarding the fate and transport of Carbon Disulfide in water and ai r. Please find the information provided below in answer to your four questions, which we ha ve taken from our Materi al Safety Data Sheet.(1) Do you have any data about CS2's physical chemis try properties, including solub ility and Henry's Law Constant?

Solubility in water at 20C = 0.2 %

Henry's Law Constant = 1748 Pa*m3/mol at 25C and 1 atm-abs

Evaporation rate (butyl acetate = 1) = 22.6

Partition Coefficient (n-octa nol/water) Log Po/w = 1.9

(2) Do you have any data on the effect of CS2 on aqua tic life, such as LC50, LD 50, or whole effluent toxicity?

Acute Toxicity on Danio rerio, freshw ater, semi-static 96 hours LC50 = 3 mg/l

Acute Toxicity on Poecilia reticulate, 96 hour LC50 = 3 mg/l

EC50, 48 hour on Daphnia magna = 2.1 mg/l Chronic Toxicity on Danio rerio, freshwater 8 day No Observable Effect Concentration = 1 mg/l

(3) Through research and review, we ar e aware that when CS2 enters surface water, it partitions rapidly to the atmosphere th rough

volatilization. What is the fate of CS2 when it volatilizes? Does it oxidize or take on another fo rm? What are the daughter pro duct chemicals?

CS2 degrades photochemically to COS and SO 2 with a half life time of 2-15 days

CS2 does not hydrolyze therefore hydrolytic degr adation is not relevant (several years)

Biodegradation of CS2 is >80% after 28 days of exposure

(4) How quickly does CS2 volatilize from water? We've seen ex amples where CS2 concentrations at the inlet and outlet of a di scharge pipe drastically reduce likely due to volatilizati on. Do you have any further information or data on the fate and transport of CS2 i n water?

CS2 volatilizes quickly from wate r. Based on our experience, it w ould be difficult to determine fa te and transport of CS2 in wa ter due to the fast

volatilization.

I trust that this information will be helpful. If you have any questions please let me know.

Best Regards,

Brian Love Principal Environmental Engineer Global Environmental Affairs Group, HSE Governance

T +1 770 246 4627

F +1 770 441 2962

M +1

E brian.love@akzonobel.com<mailto:name.surname@akzonobel.com>

AkzoNobel 3587 Parkway Lane Norcross, GA 30092 www.akzonobel.com<http://www.akzonobel.com/>

Follow AkzoNobel online at www.akzonobel.com/ followus<http://www.akzonobel.com/followus>

----------------------------------------------------------------------------------------- The information contained in this message , including any attachments, may be privile ged and confidential and is intended only f or the use of the individual and/or entity identifie d in the address of this messa ge. If you are not an intended recipient, please notify the sen der and delete and destroy this message, including any back-up copies. Please re fer to www.akzonobel.com/legal- entities<http://www.akzonobel.com/l egal-entities> for further legal information re garding the sending entity if from the EU, Croa tia, Norway, Turkey, Ukraine or Switzerland.

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From: Elizabeth Sabol [mailto:Elizabeth.Sabol@e rg.com]<mailto:[mailto:Elizabeth.Sabol@erg.com]> Sent: Thursday, June 16, 2011 8:36 AM To: Bisinger, E.C. (Edwin)Cc: Alicea.Jezebele@epa.gov<mailto:Ali cea.Jezebele@epa.gov>; Eleanor Codding Subject: Carbon Disulfide - Fate and Transport

Dr. Bisinger,

Thank you for your time on the phone today. As discussed, East ern Research Group, Inc. (ERG), under EPA Contract No. 68-C-02-09 5, is e-mailing you on EPA's behalf to request info rmation on the fate and transport of carbon disulfide (CS2) in water and air, as y ou were identified

as a member of the Carbon Disulfide Coalition by Kathleen Roberts. Please find some background is provided below.

EPA reviews industrial water discharges annually, as required by Section 304(b) of the Clean Water Act. The Clean Water Act (CW A) under Section 304(b) requires EPA to annually revi ew and, if appropriate, revise its wate r pollution control technology-based regulat ions, called "effluent limitations guidelines" or "effluent guidelines," that limit the discharge of pollutants to waters of the U.S. from v arious categories of industrial facilities. EPA is currently conducting a study of wast ewater discharges from cellulose manufacturers as a result o f CS2 discharges identified during EPA's 2011 and prior year's review (see http://www.epa.gov/guide/304m/ fo r further information). As part of the study, EPA is requesting information on the fate and transport of CS2.

We would like to obtain additional in formation on CS2, specifically pert aining to the following questions.

1. Do you have any data about CS2's physical chem istry properties, including solub ility and Henry's Law Constant?

2. Do you have any data on the effect of CS2 on a quatic life, such as LC50, LD 50, or whole effluent toxicity?

3. Through research and review, we are aware that when CS2 enters surface water, it par titions rapidly to the atmosphere through

volatilization. What is the fate of CS2 when it volatilizes? Does it oxidize or take on another fo rm? What are its daughter pro duct chemicals?

4. How quickly does CS2 volatilize from the water? We've seen examples where CS2 concentr ations at the inlet and outlet o f a discharge pipe drastically reduce likely due to volatilization. Do you have any further information or data on the fate and transport of CS2 in water?

We appreciate your timely response to the questions listed above . If a phone call is better to discuss the topic, please call m e directly at 703-633-1659 so that we can set up a convenient time.

If you would like to speak directly with EPA regarding this request, you can contact Jezebele Alicea-Virella of EPA's Office of Water/Engineering Analysis Division by phone at (202) 566-1755 or by email: Alicea.Jezebele@epamail.epa.gov<mailto :Alicea.Jezebele@epamail.epa.gov>.

Thanks,

Elizabeth

Elizabeth A. Sabol Environmental Engineer Eastern Research Group, Inc. 14555 Avion Parkway, Suite 200 Chantilly, VA 20151 elizabeth.sabol@erg.com<mailto:elizabeth.sabol@erg.com>

Phone:703-633-1659