## 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 hi m 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. Ma rtin stated that the CS2 ends up in the wastewater through the following processes:

1. The viscose and de-aeration processe s can result in various losses of carbon disulfide as liquid viscose. This liquid viscose is collected by th e facility drain system and discha rged to the wastewater treatment system. Innovia Film’s wastewater treatment is an ac tivated sludge extended aera tion 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 coll ected 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 sc rubbed and recovered. Leftover CS2 and H2S are sent out to a flare. Because CS2 is slightly soluble, th ere is some CS2 transferre d to the condensing steam. This waste stream is sent to the wastewater treatment plant.

3. Another source of wastewater results from continuous ly dumping some of the coagulation bath used to decompose xanthate. The plant dumps this coagulati on bath because sodium sulfate can build up which needs to be balanced. When the coagulation ba th 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 wa ter 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 corre spondence 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 <E leanor.Codding@erg.com>, "Mester Joe (jmester@kdheks.gov)" <jmest er@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 wh ich receives flow from the aera tion basin and feeds the flow to the 2 clarifiers.

3 The underflow from the clarifiers returns to the aera tion 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 informa tion, 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 [m ailto: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 met hod used to measure carbon disulfide discharges at the Innovia Fi lms 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 discha rge of pollutants to water of the U.S. and the permits issued for that purpose. I request your cooperati on 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 th e cellulose products manufacturing industry, EPA w ould 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 sa mpling point? We have been working with m embers of the Carbon Disulfide Coalition to determine how such a high concentration of carbon disu lfide remains in the water, wh en it is such a volatile pollu tant. In order to id entify why so much stays in solution, we need to know the analytical method being used to measure for carbon disulfide.

2. In the wastewater tr eatment process, please provide th e specific sampling location where car bon 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 th e end of pipe discharge to the receiving water?

If you have questions regarding this re quest, 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.c om, or to me directly if you prefer.

Thanks in advance for your cooperation. Sincerely,

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