Email Communication with AF&PA and NCASI

From: Kimberly Bartell

To: j erry_schwartz@afandpa.org ; pwiegand@NCASI.org

CC: Sabol, Elizabeth; Swietlik, William; Wagoner, Kim

Date: 01/16/14 9:56 AM

Subject: 2011 DMR Sulfide Discharges

Jerry and Paul,

Eastern Research Group Inc. (ERG) is assisting EPA with the 2013 Annual Review of effluent

guidelines and would like to obtain additional information on DMR sulfide discharges from one

mill, Smurfit

- Stone Container in Florence, SC (SC0000876). The facility was reviewed as part

of EPA's 2011 Annual Review and the sulfide discharges were determined to be below or near

treatable levels. However, they facility's sulfide discharges have increased significantly since the

201 1 review. We would like to determine if the sulfide discharges are correct, and if so, the

reason behind the increase.

Please let us know if you would like us to contact the facility directly or if we should send the

data and specific questions to you. We appreciate your help with the 2013 Annual Review.

Thank you,

Kim

---------------------------------------- Kimberly D. Bartell

Environmental Engineer

Eastern Research Group, Inc.

kimberly.bartell@erg.com

Phone: 517

- 515

- 1721

From: Schwartz, Jerry [ j erry_schwartz@afandpa.org ]

To: Kimberly Bartell ; pwiegand@NCASI.org

CC: Sabol, Elizabeth; Swietlik, William; Wagoner, Kim

Date: 01/16/14 10:01 AM

Subject: Re: 2011 DMR Sulfide Discharges

Kim: I can work with the mill directly. Can you send me the relevant information?From: Kimberly Bartell

To: j erry_schwartz@afandpa.org ; pwiegand@NCASI.org

CC: Sabol, Elizabeth; Swietlik, William; Wagoner, Kim

Date: 01/16/14 11:10 AM

Subject: Re: 2011 DMR Sulfide Discharges

Jerry,

Thank you for working with the mill directly. Below is the relevant information, please let me

know if you have any questions.

Smurfit

- Stone Container in Florence, SC discharges sulfide from outfall 001. As part of the 2011

Annual Reviews it was determined that the facility uses sodium

- based alkaline pulping solution

(liquor) which consists of s odium sulfide and sodium hydroxide in 10 percent solution. This is

the primary source of sulfides in the wastewater. It was also determined that the wastewater is

treated in the mill's wastewater treatment ponds before being discharged, but the facility do es not

have any specific treatment technologies in place for sulfide treatment. 2009 data was reviewed

for the 2011 Annual Review.

For the 2013 Annual Review, we review 2011 data. I've attached the 2011 DMR data for the mill

and we have the following que stions:

1. Please confirm the 2011 DMR sulfide discharges for outfall 001 (see attached, I also included

2009 data for comparison).

2. If the data is correct, why have the discharges significantly increased from 2009

- 2011?

3. Have there been any changes in the source of sulfides in the wastewater?

4. Have there been any changes in sulfide treatment?

Please let me know if you have any questions or would like to set up a call.

Thank you!

Kim

---------------------------------------- Kimberly D. Bartell

Environmental Engineer

Eastern Research Group, Inc.

kimberly.bartell@erg.com

Phone: 517

- 515

- 1721From: Wiegand, Paul [PWiegand@NCASI.org]

To: Kimberly Bartell ; Jerry Schwartz

CC: Sabol, Elizabeth; Swietlik, William; Wagoner, Kim

Date: 01/16/14 11:49 AM

Subject: Re: 2011 DMR Sulfide Discharges

Kimberly and Jerry,

Please let me know if NCASI can be of any additional assistance with r egard to this or other

matters related to the 2013 annual review. The past collaboration we’ve had has been helpful to

all of our organizations.

Paul

Paul Wiegand

Vice President

- Water Quality

National Council for Air and Stream Improvement (NCASI), Inc

.

P.O. Box 13318

Research Triangle Park, NC 27709

- 3318

phone (919) 941

- 6417

cell (919) 607

- 8120

fax (919) 941

- 6401

PWiegand@ncasi.org

From: Schwartz, Jerry [ j erry_schwartz@afandpa.org ]

To: Kimberly Bartell

Date: 02/0 3 /14 9:30 AM

Subject: Re: 2011 DMR Sulfide Discharges

Kim: Have you heard from the mill on this? Are you still waiting for an answer on it?

From: Kimberly Bartell

To: Schwartz, Jerry [

j erry_schwartz@afandpa.org ]

Date: 02/0 3 /14 9:36 AM

Subject: Re: 2011 DMR Sulfide Discharges

Jerry:

I am still waiting on an answer; I have not heard anything from the mill.

Thanks,

KimFrom: Schwartz, Jerry [ j erry_schwartz@afandpa.org ]

To: Kimberly Bartell

Date: 02/03/14 9:38 AM

Subject: Re: 2011 DMR Sulfide Discharges

Ok. I will follow up

Jerry Schwartz

From: Kimberly Bartell

To: Schwartz, Jerry [

j erry_schwartz@afandpa.org ]

Date: 02/0 3 /14 9:39 AM

Subject: Re: 2011 DMR Sulfide Discharges

Sounds great, thank you!

Kim

From: Schwartz, Jerry [ j erry_schwartz@afandpa.org ]

To: Kimberly Bartell ; Paul Wiegand

CC : William Swietlik; Elizabeth Sabol; Kim Wagoner; Nina

- Mary Butler

Date: 02/19 /14 10:34 P M

Subject: Re: 2011 DMR Sulfide Discharges

Kim: Here are the responses from the company. Please let me know if you have any questions.

Jerry

Below is RockTenn's response to the questions posed by Ms. Bartell regarding the Florence,

South Carolina mill. Note that our evaluation of effluent sulfide concentrations for the period

2009 through 2013 sho ws a downward trend, even considering that we apparently have two

months of outlier data from January and February 2011.

Question #1 : Please confirm the 2011 DMR sulfide discharges for outfall 001 (see attached, I

also included 2009 data for comparison).

Answer #1 : The data has been confirmed, although two data points from 2011 appear to

be anomalies.

Question #2 : If the data is correct, why have the discharges significantly increased from 2009

-

2011?Answer #2 : Two months of sulfide data from 2011 showed elevated concentrations that

skew the average sulfide concentration. A review of DMR data from the period 2009

through 2013 indicates that these two months of data are anomalies. The attached graph

clearly shows that sulfide concentrations in the F lorence mill’s effluent are trending

downward.

Question #3 : Have there been any changes in the source of sulfides in the wastewater?

Answer #3 : No process changes have occurred that would impact source of sulfide in

the Florence mill

Question #4 : Have there been any changes in sulfide treatment?

Answer #4 : No changes to the treatment system have occurred; however, the mill has

formed a team that is focused on minimizing losses from the pulp mill to the process

sewers.

From: Kimberly Bartell

To: Schwartz, Jerry [

j erry_schwartz@afandpa.org ] ; Paul Wiegand

CC : William Swietlik; Elizabeth Sabol; Kim Wagoner; nbutler2@rocktenn.com

Date: 02/20 /14 7:36 AM

Subject: Re: 2011 DMR Sulfide Discharges

Jerry,

Thank you very much for getting back to me. I will review the information from mill below and

will let you know if we have any further questions.

Thanks again,

Kimberly