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

 Project No.: 0172.08.005.100 Page 1 of 2 

 Project Name: PMF Preliminary Study CBI? 

 Yes 

 No 

TELEPHONE CALL RECORD 

 Incoming 

 Outgoing 

Date: 8/1/2011 Time: 3:00 am 

 pm 

Company Name: Innovia Films, Inc ERG Staff Name: Elizabeth Sabol 

Contact Name: Tony Martin Contact Phone Number: (785-276-3430) 

General Subject: CS2 at the Innovia Films, Inc Facility 

TOPICS DISCUSSED AND ACTION TAKEN 

On July 27, 2011, I called Tony Martin to discuss carbon disulfide discharges and cellulose products 

manufacturing processes at the Innovia Films facility. I left a message for him asking to return my call. I left 

another message for Mr. Martin on July 28, 2011. 

On August 1, 2011, Mr. Martin returned my call. Mr. Martin stated that the CS2 ends up in the wastewater 

through the following processes: 

1. The viscose and de-aeration processes can result in various losses of carbon disulfide as liquid viscose. 

This liquid viscose is collected by the facility drain system and discharged to the wastewater treatment 

system. Innovia Film’s wastewater treatment is an activated sludge extended aeration process to treat the 

wastewater. The process includes settling ponds, equalization, activated sludge aeration, and 

clarification. 

2. The CS2 recovery system. The stream of CS2 and H2S from the process is collected in a steel chamber 

and sent to the recovery plant. Steam is used to condense the CS2, which is sent to recovery. Any 

remaining CS2 that isn’t condensed is then oil scrubbed and recovered. Leftover CS2 and H2S are sent 

out to a flare. Because CS2 is slightly soluble, there is some CS2 transferred to the condensing steam. 

This waste stream is sent to the wastewater treatment plant. 

3. Another source of wastewater results from continuously dumping some of the coagulation bath used to 

decompose xanthate. The plant dumps this coagulation bath because sodium sulfate can build up which 

needs to be balanced. When the coagulation bath is dumped, some CS2 is also discharged. 

4. Start-up processes can also result in a “viscose dump”. The facility’s permit requires CS2 to be sampled 

12 hours (system residence time) after a viscose dump to make sure the wastewater treatment system 

will operate appropriately. 

Mr. Martin stated that the sample point for CS2 sampling is at the final outfall. He stated that CS2 is not 

completely soluble in water; however, so much water is discharged that some CS2 is present. 

ERG and EPA continued conversations with Mr. Martin to gain information on sampling methods and points. 

Please see the attached e-mail correspondence for more information. 

From: Martin Anthony <Anthony.Martin@innoviafilms.com> 
Need to return call by / at/between and . Signature: 

To: "Alicea.Jezebele@epamail.epa.gov" <Alicea.Jezebele@epamail.epa.gov> 

CC: Elizabeth Sabol <Elizabeth.Sabol@erg.com>, Eleanor Codding <Eleanor.Codding@erg.com>, "Mester Joe (jmester@kdheks.gov)" <jmester@kdheks.gov> 

Date: 8/30/2011 3:07 PM 

Subject: RE: Carbon Disulfide Discharges 

Ms Jezebele, 

In reply to your questions listed below: 

1 The method used for CS2 analysis is "Purge & Trap GCMS #624". 

2 Samples for CS2 testing are taken at the splitter box which receives flow from the aeration basin and feeds the flow to the 2 clarifiers. 

3 The underflow from the clarifiers returns to the aeration basin and the overflow is piped underground by gravity to the outfall. The outfall discharges into the 

receiving stream approximately 7000 feet from the splitter box. 

I trust that this information satisfies your questions. Please confirm that you have received this reply. 

If you require more information, please contact me. 

Sincerely, 

Tony Martin 

Site Services Manager 

Innovia Films Inc. - Tecumseh, Kansas 

phone: (785) 276-3430 

cell: (785) 925 1799 

e-mail: Anthony.Martin@innoviafilms.com 

-----Original Message----- 

From: Alicea.Jezebele@epamail.epa.gov [mailto:Alicea.Jezebele@epamail.epa.gov] 

Sent: Thursday, August 25, 2011 2:02 PM 

To: Martin Anthony 

Cc: Elizabeth Sabol; Eleanor Codding 

Subject: Carbon Disulfide Discharges 

Greetings Mr. Martin, 

EPA is requesting clarification from you on the analytical method used to measure carbon disulfide discharges at the Innovia Films facility. 

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

68-C-02-095, is collecting this information as EPA's authorized agent. 

EPA, and its agents, are authorized under Section 308 of the Clean Water Act (CWA) to collect information related to the discharge of pollutants to water of the U.S. 

and the permits issued for that purpose. I request your cooperation and the submittal of this information to ERG, or directly to me if you prefer, at your earliest 

convenience but not later than September 1, 2011. 

As part of the review of the cellulose products manufacturing industry, EPA would like to report discharges of carbon disulfide as accurately as possible. As part of this 

review, we would like to obtain answers to the following questions: 

1. What is the analytical method used to measure carbon disulfide at the designated sampling point? We have been working with members of the Carbon Disulfide 

Coalition to determine how such a high concentration of carbon disulfide remains in the water, when it is such a volatile pollutant. In order to identify why so much 

stays in solution, we need to know the analytical method being used to measure for carbon disulfide. 

2. In the wastewater treatment process, please provide the specific sampling location where carbon disulfide is measured (e.g., before the aeration basin, after the 

aeration basin, after the clarifier). It is unclear from the diagrams and the permit where the actual sample is being taken. 

3. From the sample location, how far away is the end of pipe discharge to the receiving water? 

If you have questions regarding this request, you may contact Elizabeth Sabol of ERG by phone at (703) 633-1659. Please return the requested information to Elizabeth 

Sabol, ERG via e-mail at elizabeth.sabol@erg.com, or to me directly if you prefer. 

Thanks in advance for your cooperation. 

Sincerely, 

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