Z 

United States 

Environmental Protection 

Agency 

Preliminary Study of Carbon Disulfide 

Discharges from Cellulose Products 

Manufacturers 

December 2011 
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U.S. Environmental Protection Agency 

Office of Water (4303T) 

1200 Pennsylvania Avenue, NW 

Washington, DC 20460 

EPA-821-R-11-009 
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Preliminary Study of Regenerated Cellulose Manufacturers 

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CONTENTS 

Page 

1.0 STUDYING DISCHARGES FROM REGENERATED CELLULOSE MANUFACTURERS ................... 1

1.1 Introduction............................................................................................................. 1

1.2 Background – Manufacturing Process.................................................................... 1

1.3 Background - Existing Effluent Guidelines and Regenerated Cellulose 

Manufacturing......................................................................................................... 2

1.3.1 40 CFR Part 414.......................................................................................... 2

1.3.2 40 CFR Part 463.......................................................................................... 3

1.3.3 Potential New Subcategories for the OCSPF Category.............................. 4

1.3.4 NPDES Permit Basis................................................................................... 4

1.4 Background – Industry Profile of U.S. Cellulose Manufacturers........................... 5

2.0 CARBON DISULFIDE PROPERTIES ......................................................................................... 7

2.1 Chemical Properties of Carbon Disulfide............................................................... 7

2.2 Carbon Disulfide - Potential Pathways into the Environment................................ 9

3.0 WASTEWATER SOURCES ...................................................................................................... 9

3.1 Unloading and Storage............................................................................................ 9

3.2 Process Steps......................................................................................................... 11

3.3 Air Pollution Control ............................................................................................ 12

4.0 REGENERATED CELLULOSE PROCESS WASTEWATER TREATMENT .................................... 13

5.0 FACILITY DISCHARGE DATA.............................................................................................. 15

5.1 Innovia Films, Inc in Tecumseh, KS .................................................................... 15

5.1.1 Waste Streams........................................................................................... 15

5.1.2 Wastewater Treatment .............................................................................. 16

5.1.3 Discharge Data.......................................................................................... 17

5.2 Viskase Corporation in Loudon, TN..................................................................... 19

5.2.1 Wastewater Source and Treatment ........................................................... 19

5.2.2 Discharge Data.......................................................................................... 19

6.0 CONCLUSIONS.................................................................................................................... 20

7.0 REFERENCES ...................................................................................................................... 20
Preliminary Study of Regenerated Cellulose Manufacturers 

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LIST OF TABLES 

Page 

Table 1. Applicability of Subcategories in the PMF Category........................................................3

Table 2. Existing ELGs for Regenerated Cellulose Materials.........................................................4

Table 3. Operating U.S. Cellulose Products Manufacturers and Corresponding 2009 TRI and 

DMR Discharges..................................................................................................................6

Table 4. Closed or Idled Cellulose Manufacturers in the United States..........................................7

Table 5. Chemical Properties of Carbon Disulfide, Acetone, and Ethanol .....................................7

Table 6. Inhalation Exposure Limits for Carbon Disulfide, Acetone, and Ethanol.........................8

Table 7. TRI 2009 Carbon Disulfide Air Emissions and Water Discharges for Cellulose 

Products Manufacturers .......................................................................................................9

Table 8. Facility Carbon Disulfide Unloading and Storage Practices as of 2000..........................11

Table 9. Cellulose Products Wastewater Treatment......................................................................13

Table 10. Confirmed Sources of Wastewater and Wastewater Treatment at Cellulose 

Manufacturing Facilities ....................................................................................................14

Table 11. Innovia Films, Inc Waste Streams .................................................................................15

Table 12. 2008, 2009, and 2010 Carbon Disulfide Concentration Data for Innovia Films, 

Inc. .....................................................................................................................................17

Table 13. Carbon Disulfide Concentration Data for Viskase Corporation in Loudon, TN...........19

Table A-1. Applicability of Subcategories in the OCPSF Category ...............................................1
Preliminary Study of Regenerated Cellulose Manufacturers 

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1.0 STUDYING DISCHARGES FROM REGENERATED CELLULOSE MANUFACTURERS

1.1 Introduction

EPA is studying wastewater discharges from regenerated cellulose manufacturers 

because these facilities report large discharges of carbon disulfide (CS2) (U.S. EPA, 2006, U.S. 

EPA, 2010). Currently no existing regulation sets federal effluent limitations for CS2 discharges 

from the seven regenerated cellulose manufacturers that operate in the United States. Cellulose 

products manufacturers use CS2 in the viscose process to break down aged alkali cellulose prior 

to regeneration. CS2 can enter the wastewater stream at these facilities from CS2 unloading and 

storage, the viscose process, CS2 recovery, and/or air pollution control. 

The main pollutant of concern discharged from these facilities, CS2, is a volatile organic 

compound. EPA researched how the CS2 enters the wastewater and its fate in the facilities’ 

existing wastewater treatment systems. EPA also collected data on whether the CS2 discharges 

would impact human health or aquatic life. EPA continues to resolve the overall question of how 

significant concentrations of CS2 remain in the wastewater, although CS2 is highly volatile. 

1.2 Background – Manufacturing Process

Regenerated cellulose products manufacturers use the viscose process to form cellulose 

film, sponge, food casings, and rayon from dissolving-grade wood pulp. In the viscose process, 

sheets of dissolving-grade cellulose pulp are saturated with caustic (e.g., sodium hydroxide) to 

convert the cellulose into alkali cellulose. The alkali cellulose partially oxidizes and degrades by 

aging in ambient air. Gaseous CS2 is mixed with the aged alkali cellulose in a vessel to form 

sodium cellulose xanthate. The sodium cellulose xanthate is dissolved in aqueous caustic 

solution, creating the viscose solution. The viscose solution is ripened, filtered, degassed, and 

extruded, and then sulphuric acid is added to the viscose solution to form regenerated cellulose 

(Schmidtke, 2000). Figure 1 presents a simplified flow diagram of the general viscose process 

and the different process steps for each type of regenerated cellulose (cellulose film or 

cellophane, sponge, food casings, and rayon) (Schmidtke, 2000). 
Preliminary Study of Regenerated Cellulose Manufacturers 

Figure 1. Simplified Process Flow Diagram for the Generic Viscose Process and 

Regenerated Cellulose Products 

1.3 Background - Existing Effluent Guidelines and Regenerated Cellulose 

Manufacturing

The regenerated cellulose manufacturing process is closely related to two effluent 

limitation guidelines and standards (ELGs) point source categories: Organic Chemicals, Plastics, 

and Synthetic Fibers (OCPSF, 40 CFR Part 414) and Plastics Molding and Forming (PMF, 40 

CFR Part 463). However, wastewater discharges from the manufacture of several cellulose 

products are not covered by any existing categorical ELGs or pretreatment standards. 

1.3.1 40 CFR Part 414 

The OCPSF ELGs (40 CFR Part 414, Subpart B) apply to wastewater discharged from 

the manufacture of rayon, a regenerated cellulose fiber. However, these regulations specifically 

exclude discharges from the manufacture of cellulose film, sponge, and meat casings (40 CFR 

§414.20). Further, these regulations do not include limitations for CS2 and there are no rayon 

facilities currently operating in the United States. Appendix A includes further information on 

the applicability and subparts of 40 CFR Part 414. 

2 
Preliminary Study of Regenerated Cellulose Manufacturers 

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1.3.2 40 CFR Part 463 

The PMF industry includes facilities that are engaged in blending, molding, forming, or 

other types of processing of plastic materials. These processes commonly include extrusion, 

coating and laminating, thermoforming, calendaring, casting, foaming, cleaning, and finishing 

(U.S. EPA, 1984). EPA first promulgated ELGs for the PMF Category (40 CFR Part 463) on 

December 17, 1984 (49 FR 49040). There are three subcategories, all of which have best 

practicable control technology (BPT), new source performance standards (NSPS), pretreatment 

standards for existing sources (PSES), and pretreatment standards for new sources (PSNS) 

limitations. 

The manufacture of cellulose products are not covered by Part 463 (the PMF Category). 

The product is made of regenerated cellulose using the viscose process, and Part 463 specifically 

excludes products manufactured from regenerated cellulose, as well as the molding and forming 

of regenerated cellulose (U.S. EPA, 1984). 

40 CFR §463.1(g) Processes used to regenerate cellulose and to 

produce a product (e.g., rayon) from the regenerated cellulose are not 

subject to the effluent limitations guidelines and standards in this part. 

Processes that mold or form cellulose derivatives (e.g., cellulose 

acetate) are subject to the effluent limitations guidelines and standards 

in this part if they discharge process water. 

The regenerated cellulose manufacturing process is similar to the operations regulated by 

40 CFR Part 463 because water contacts extrusion equipment and regenerated cellulose products 

for cooling, cleaning, and finishing; however, regenerated celluloses are not plastic materials and 

are not regulated by the PMF ELGs. Table 1 describes the three subcategories regulated by the 

PMF ELGs. 

Table 1. Applicability of Subcategories in the PMF Category 

Subpart Description Applicability 

A Contact Cooling and Heating Water Processes where water contacts plastic material or plastic 

products for the purpose of heat transfer. 

B Cleaning Water Processes where water contacts the plastic products or 

shaping equipment for the purpose of cleaning. 

C Finishing Water Processes where water contacts plastics products during 

finishing. 

Source: Preliminary Review of Prioritized Categories of Industrial Dischargers (U.S. EPA, 2005a) 

The Technical Development Document for Effluent Limitations Guidelines and New 

Source Performance Standards for the Plastics Molding and Forming Point Source Category

(PMF TDD) provides the rationale for excluding regenerated cellulose manufacturers from the 

PMF ELGs. It states that plastic materials are a group of synthetic, organic materials composed 

of high molecular weight, long chain molecules. The definition of plastic materials in the PMF 

regulation also includes natural polymers that are combined with synthetic organic materials, 
Preliminary Study of Regenerated Cellulose Manufacturers 

4 

such as cellulose acetate. However, wholly natural organic materials, such as regenerated 

cellulose, are not included in the PMF definition of plastic materials. 

The PMF TDD also states that the final step in the xanthate process used to regenerate 

cellulose is to wash the regenerated cellulose to remove dissolved salts and sulfur compounds 

within the product. Process water used in this step is not considered cleaning water as defined in 

the final PMF ELGs because it does more than just clean the surface of the regenerated cellulose. 

Therefore, wastewater discharges from the manufacture of several cellulose products, 

including film, sponge, and food casings, are not covered by any existing categorical ELGs or 

pretreatment standards. Table 2 provides an overview of the cellulose products that are covered 

by existing ELGs and corresponding CS2 limitations. 

Table 2. Existing ELGs for Regenerated Cellulose Materials 

Regenerated Cellulose Product 40 CFR Part 414 (OCPSF) 40 CFR Part 463 (PM&F) 

Rayona Included, but no CS2 limits Excluded 

Cellulosic Film (Cellophane) Excluded Excluded 

Cellulosic Sponge Excluded Excluded 

Food Casing Excluded Excluded 

Source: 40 CFR §414.20 and 40 CFR §463.1(g) 

a – There are not rayon manufacturers currently operating in the United States. 

1.3.3 Potential New Subcategories for the OCSPF Category 

EPA reviewed the information provided in Tables 1 and 2 and determined that the 

cellulose products manufacturers using the viscose process to manufacture cellophane, cellulosic 

sponge, and food casings have processes, operations, wastewaters, and pollutants identical to the 

rayon manufacturers regulated by the OCPSF Category (Subpart B – Rayon Fibers). The end 

products at these facilities are all considered regenerated cellulose materials and are all produced 

using the same viscose process. For future screening level data review, EPA will classify the 

discharges from these facilities as a potential new subcategory of the OCPSF Category. 

1.3.4 NPDES Permit Basis 

Because wastewater discharges from the manufacture of several cellulose products, 

including film, sponge, and food casings are not covered by any existing categorical ELGs or 

pretreatment standards, permit writers have used state water quality standards, historical 

performance effluent data (HPED), other similar ELGs (i.e., OCSPF Subpart D – Thermoplastic 

Resins BPT), and best professional judgment (BPJ) as the basis for permit limits. The permits for 

wastewater discharges from cellulose products manufacturing include limits for the following 

pollutants: biological oxygen demand (BOD), total suspended solids (TSS), ammonia, ammonia 

nitrogen, total residual chlorines, oil and grease, and total organic carbon. 

Only one NPDES permit (for Innovia Films, Tecumseh, KS, a cellulose products 

manufacturer), includes monitoring requirements for CS2. Innovia Films is required to monitor 

CS2 to avoid process upsets to the facility’s activated sludge treatment system. Other permitted 

facilities are not required to monitor CS2, likely because there are no national water quality 

criteria for it, and other similar ELGs do not have limitations for CS2. 
Preliminary Study of Regenerated Cellulose Manufacturers 

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1.4 Background – Industry Profile of U.S. Cellulose Manufacturers

EPA identified seven cellulose products manufacturers operating in the U.S. as of 2009. 

The final products of these facilities compete in markets with products made from alternative 

materials, especially plastics. Cellulose products have generally been declining in market share 

over time as newer non-cellulose products have been introduced (Beach, et al., 2000). The 

cellophane manufacturing industry has been declining since the 1950s due to new regulations 

and economic issues. The domestic market for rayon has also been eliminated because textile 

production has moved out of the United States (Beach, Houtven, Buckley, and Depro, 2000). 

Table 3 lists the operating U.S. cellulose products manufacturers and their discharges from the 

2009 TRI and DMR databases, in pounds per year (LBY) and toxic-weighted pound equivalents 

(TWPE). Table 4 lists those manufacturing operations that appear to have been idled or closed 

prior to 2009. 
Preliminary Study of Regenerated Cellulose Manufacturers 

Table 3. Operating U.S. Cellulose Products Manufacturers and Corresponding 2009 TRI and DM

2009 TRI Data 2009 

Facility a Location Product Type 

Discharge 

Type b 

Basis of 

Estimate c

CS2

Pounds 

Released 

from 

Facility d

CS2 Pounds 

Released to 

Stream e

CS2

TWPE 

Average 

Flow 

(MGD) 

1 

3M Corporation Elyria, OH 

Cellulosic 

Sponges Indirect M2 NR NR NR NA 

2 

3M Corporation 

Tonawanda, NY 

Cellulosic 

Sponges Indirect O 4,700 752 2,105 NA 

3 

Innovia Films Inc. 

Tecumseh, KS Cellophane Direct M2 26,500 26,500 74,300 2.22 

4 Spontex Inc. 

Columbia, TN 

Cellulosic 

Sponges Direct M2 223 223 624 0.38 

5 

Viscofan USA Inc. Danville, IL Food Casings Indirect M2 14,000 2,240 6,270 NA 

6 

Viskase Corporation Osceola, AR Food Casings Direct O 473 473 1,320 1.16 

7 

Viskase Corporation Loudon, TN Food Casings Indirect M2 13,000 2,080 5,820 NA 

Source: Industry Profile of the Cellulose Products Manufacturing Facilities in the U.S. (Schmidtke, 2000), DMRLoads2009_v2, TRIRelease

a – Cellulose manufacturing facilities that are currently operating in the United States. b – ELGs control pollutant discharges at the point of discharges from industrial facilities and cover discharges directly to surface water (dire

discharges to POTWs (indirect discharges). c – Basis of Estimate Descriptions: M1: continuous monitoring data or measurements; M2: periodic or random monitoring data or measuremcalculations, such as calculation of the amount of the toxic chemical in streams entering and leaving process equipment; E: published emissspecific emission factors; and O: other approaches, such as engineering calculations. d – Discharges include transfers to POTWs and do not account for POTW removals. e – Discharges include transfers to POTWs and account for POTW removals. NR – No data reported. 

6 
Preliminary Study of Regenerated Cellulose Manufacturers 

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Table 4. Closed or Idled Cellulose Manufacturers in the United States

Facility Name Location Product Type 

Facility Status 

in 2011 

Type of 

Discharger a

Lenzing Fibers Corp. Axis, AL Rayon Closed Direct 

Lenzing Fibers Corp. Lowland, TN Rayon Closed Direct 

3M Corporation Prairie du Chien, WI Cellulosic Sponges Idled Indirect 

Source: Industry Profile of the Cellulose Products Manufacturing Facilities in the U.S. (Schmidtke, 2000) 

2.0 CARBON DISULFIDE PROPERTIES 

All cellulose products manufacturers use CS2 in the viscose process to regenerate 

cellulose. The CS2 is used to react with aged alkali cellulose to form sodium cellulose xanthate. 

CS2 is an extremely flammable and highly volatile chemical that is slightly soluble in water. 

2.1 Chemical Properties of Carbon Disulfide

Table 5 presents chemical properties for CS2 compared to acetone and ethanol. The 

Henry’s Law Constant for CS2 is 1,748 Pa m3/mol at 25o C (Love, 2011). Henry’s Law Constant 

is the measure of the solubility of a gas in a liquid at a particular temperature, proportional to the 

pressure of that gas above the liquid (Kotz and Treichel, 1999). Chemicals with a higher Henry’s 

Law Constant are more volatile. For example, CS2 is highly volatile: the gas constant for CS2 is 

approximately 403 times higher than that for acetone (4.02 Pa m3/mol). 

Table 5. Chemical Properties of Carbon Disulfide, Acetone, and Ethanol 

Chemical Properties CS2 Acetone Ethanol 

Henry’s Law Constant at 25oC 1,748 Pa m3/mol 4.02 Pa m3/mol 0.585 Pa m3/mol 

Water Solubility 0.2% at 20o C Soluble Miscible 

Evaporation Rate a 22.6 5.7 NA 

National Fire Protection Association (NFPA) 

Flammability Rating b

4 3 3 

Sources: EPA On-line Tools for Site Assessment Calculation; Fischer Scientific MSDS for Acetone and Ethanol; 

Love, 2011; Ohio EPA, 2010; and OSHA Guidelines for Carbon Disulfide. 

a – The rate at which a material will vaporize when compared to the known standard rate of butyl acetate 

(evaporation rate = 1.0).

b – The NFPA flammability rating ranks the relative danger for a chemical. The higher the rating, the higher danger 

associated with the chemical flammability. 

CS2 is also hazardous to humans when inhaled. Table 6 presents the Occupational Safety 

& Health Administration (OSHA) and National Institute for Occupational Safety and Health 

(NIOSH) established permissible exposure limits (PELs) and recommended exposure limits 

(RELs) for CS2, acetone, and ethanol. These exposure limits correspond to the amount or 

concentration of the substance in the air and may also contain skin designation. As part of the 

Occupation Safety and Health Guidelines, OSHA also established CS2 PELs of 30 ppm 

(acceptable peak concentration for a 30 minute exposure) and 100 ppm (instantaneous maximum 

peak). NIOSH RELs also include a 10 ppm short-tem exposure limit. 
Preliminary Study of Regenerated Cellulose Manufacturers 

8 

Table 6. Inhalation Exposure Limits for Carbon Disulfide, Acetone, and Ethanol

Exposure Limits CS2 Acetone Ethanol 

OSHA PELS (TWA)a 20 ppm b 1000 ppm 1000 ppm 

NIOSH RELs (TWA)a 1 ppm 250 ppm 1000 ppm 

Sources: Fischer Scientific MSDS for Acetone and Ethanol and OSHA Guidelines for Carbon Disulfide. 

a – Time weighted average. 

b – OSHA PEL for CS2 is an 8-hour time weighted average (TWA) concentration. 

Because CS2 is highly volatile and flammable, facilities take additional precautions to 

reduce emissions to the air and sparks during the transfer of CS2. These precautions include 

submerging the pipelines from storage tanks to the process in water trenches, transporting 

recovered CS2 underground from the process to storage tanks, and transferring CS2 by gravity or 

magnetically sealed pumps. 

EPA contacted the Carbon Disulfide Coalition to determine its toxicity levels and fate 

and transport in water. The Akzo Nobel contact, a Carbon Disulfide Coalition member and a 

manufacturer of CS2, provided the following freshwater toxicity levels: 

 Freshwater, acute: 3 mg/L; and 

 Freshwater, chronic: 1 mg/L. 

The Akzo Nobel contact also stated that CS2 volatilizes quickly from water. Historically, 

Carbon Disulfide Coalition scientists had difficulty measuring the solubility of CS2, due to the 

rapid volatilization of free CS2 into the vapor space. They found that the dissolved levels quickly 

dropped during the experiment. The Coalition concluded that the fate and transport of CS2 in 

water would be volatilization, i.e., none would stay in solution (Love, 2011). 

Table 7 presents the total air emissions and water discharges (to surface water or POTW) 

for the seven cellulose products manufacturers. The reported data confirm that the majority of 

the CS2 evaporates, which corresponds with the physical/chemical properties. However, the 

estimated concentration of CS2 in the water discharged from four facilities exceeds the CS2

solubility at 25o C (0.2 %) (Love, 2011). 
Preliminary Study of Regenerated Cellulose Manufacturers 

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Table 7. TRI 2009 Carbon Disulfide Air Emissions and Water Discharges for Cellulose 

Products Manufacturers 

Facility Location 

Discharge 

Type a

Water Releases 

% of Total CS2

Discharges 

Total CS2

Air 

Emissions 

CS2

Discharge 

before POTW 

Removals 

1 3M Corporation Elyria, OH Indirect NA 187,000 NR 

2 3M Corporation Tonawanda, NY Indirect 1.22 % b 379,000 4,700 

3 Innovia Films Inc. Tecumseh, KS Direct 3.1 % b 820,000 26,500 

4 Spontex Inc. Columbia, TN Direct 0.03 % 618,000 223 

5 Viscofan USA Inc. Danville, IL Indirect 0.41 % b 3,360,000 14,000 

6 Viskase Corporation Osceola, AR Direct 0.05 % 924,000 473 

7 Viskase Corporation Loudon, TN Indirect 0.68 % b 1,890,000 13,000 

Source: TRIReleases2009_v2. 

a – ELGs control pollutant discharges at the point of discharges from industrial facilities and include discharges 

directly to surface water (direct discharges) and discharges to POTWs (indirect discharges). 

b – The estimated CS2 concentrations discharged to water from these facilities exceeds the CS2 solubility at 25o C 

(0.2 %) 

NR – No data reported. 

NA – Not applicable. 

 

2.2 Carbon Disulfide - Potential Pathways into the Environment

Releases of CS2 from manufacturing facilities are almost exclusively to the atmosphere 

(ATSDR, 1996). However, facilities transfer CS2 to wastewater during feedstock unloading and 

storage and air pollution control. Other than cellulose products manufacturing, industries that use 

CS2 as a raw material or form it as a by-product include the manufacturing of soil disinfectant, 

development restrainer for instant color photography, aging of roasting coffee, pesticide 

intermediates, degreasing, chemical analysis, electroplating of gold and nickel, oil extraction, 

and dry cleaning (ATSDR, 1996). Natural sources of CS2 in the environment include anaerobic 

ocean floors, wetlands, microbial activity in solids, certain crop plants and trees, volcano and 

marsh emissions, and vapor space above liquid sulfur (ATSDR, 1996). 

3.0 WASTEWATER SOURCES

At cellulose products manufacturing facilities, the primary sources of wastewater 

containing CS2 are railcar unloading, storage, viscose process steps, and air pollution control 

(Schmidtke, 2000). After reviewing the available data, the majority of the CS2 enters the 

wastewater from the viscose processes used to regenerate the cellulose (KDHE, 2005; Martin, 

2011). 

3.1 Unloading and Storage

Most cellulose products manufacturing facilities receive CS2 in the liquid or gas form by 

railcar. Because CS2 is highly flammable, facilities unload CS2 by water and/or nitrogen 

displacement to prevent fire or explosion. Water displacement is a method of unloading liquid 

CS2 from railcars where water enters the railcar at the same flow rate that the CS2 is expelled to 

the storage container. Nitrogen displacement is the same process; however, the inert gas fills the 

railcar as CS2 is expelled. Facilities use water and/or nitrogen displacement to prevent 
Preliminary Study of Regenerated Cellulose Manufacturers 

flammable, gaseous CS2 emissions to the atmosphere and to preclude contact with oxygen (§40 

CFR 63.5610). 

Once in the storage pool and/or tank, water or inert gas is again used to contain the CS2. 

If nitrogen is used, a nitrogen blanket is applied with enough pressure to keep the CS2 in liquid 

form. If water is used, the liquid CS2 is more dense than water, and a water blanket will also keep 

the CS2 in liquid form. The liquid CS2 remains at the bottom and is recovered or discharged to 

the wastewater treatment system. CS2 does not evaporate from the unloading/storage system 

because the systems are closed to the atmosphere and are not mixed/aerated, the process that 

allows CS2 to volatilize. Figure 2 shows the CS2 unloading and storage processes by 

displacement. 

Figure 2. CS2 Unloading and Storage System Using Containment Pool/Tank 

Facilities using water displacement for raw material unloading generate CS2-saturated 

wastewater during railcar unloading; water displaced from the CS2 storage tank is sent to the 

facility’s wastewater treatment system (Schmidtke, 2000). 

After unloading CS2, facilities store pressurized, liquid CS2 in large tanks. Because CS2 is 

extremely flammable, the facilities store the tanks with one or a combination of the following 

methods: 

10 
Preliminary Study of Regenerated Cellulose Manufacturers 

11 

 Submerged under water in a containment pool; 

 Raised above a water containment pool; or 

 Covered by a nitrogen blanketing system. 

Because liquid CS2 has a higher specific gravity than water, any CS2 that leaks during 

storage will settle to the bottom of the containment pool that a storage tank is submerged in or 

stored above. 

In addition to underwater or nitrogen blanket storage, the facilities use a water or nitrogen 

padding system to fill headspace in the tank and further prevent contact with oxygen. The water 

or nitrogen padding is displaced into the water pool as CS2 is loaded into the storage vessel. 

Conversely, the water or nitrogen padding in the storage tank fills the headspace as CS2 is 

expelled for use in the manufacturing process, also shown in Figure 2. 

Any water that is displaced from the unloading or storage in the pool and water padding 

is sent to the wastewater treatment system (Schmidtke, 2000). Table 8 presents the unloading and 

storage practices for each cellulose products manufacturing facility. 

Table 8. Facility Carbon Disulfide Unloading and Storage Practices as of 2000

Facility Unloading 

Procedures Facility Storage Procedures 

Facility 

Facility 

Location 

Unloading 

System 

Water 

Displacement a Tank Location 

Padding 

System 

1 3M Corporation Elyria, OH N2 NA Submerged in 

Water Pool 

Water 

2 3M Corporation Tonawanda, NY N2 Yes Mounted Over 

Water Dike 

Water 

3 Innovia Films Inc. b Tecumseh, KS N2 No Mounted Over 

Water Dike 

N2 

4 Spontex Inc. Columbia, TN Water NA NA Water 

5 Viscofan USA Inc. Danville, IL N2 No Submerged in 

Bottom Sloped 

Water Pool 

Water 

6 Viskase Corporation Osceola, AR N2 NA Submerged in 

Water Pool 

N2 

7 Viskase Corporation Loudon, TN N2 Yes Submerged in 

Water Pool 

N2 

Source: Schmidtke, 2000 

a – Some facilities use nitrogen to displace CS2 from the railcar into storage tanks, but use a water dike or pool for 

the storage tank. Therefore, they create a wastewater stream as CS2 enters the storage tank. 

b – Innovia Films is the only facility where the CS2 is not directly in contact with water as part of the unloading or 

storage processes at the facility. The facility contact confirmed that the majority of the facility’s discharges are from 

the viscose processes and CS2 recovery at the plant. 

3.2 Process Steps

CS2 is combined with aged alkali cellulose to form sodium cellulose xanthate. After this 

reaction, the sodium cellulose xanthate is combined with liquid caustic and water in a 

coagulation bath. In order to control the sodium sulfate levels of the coagulation bath, water is 

continuously drained from this process step. Because the sodium cellulose xanthate contains 

some CS2 from previous process steps, CS2 is discharged with the wastewater (Martin, 2011). 
Preliminary Study of Regenerated Cellulose Manufacturers 

12 

Any wastewater overflow from the viscose solution steps also contains CS2 discharges 

(Schmidtke, 2000). At this time, EPA is unable to determine what causes overflow from the 

viscose solution steps or the amount of wastewater that results from process overflow. 

At one facility, CS2 used in the viscose process is recovered through condensation. The 

facility uses steam to condense the CS2, which is ultimately sent to the recovery plant. The CS2

not captured from condensation is oil-scrubbed and recovered. Because some CS2 is soluble in 

water, the steam condensate may contain CS2. The steam condensate is sent to the facility’s 

wastewater treatment plant (Martin, 2011). 

3.3 Air Pollution Control

On June 11, 2002, EPA promulgated a NESHAP for Cellulose Products Manufacturing 

(40 CFR Part 63, Subpart UUUU, 67 FR 40055). The Cellulose Products Manufacturing 

NESHAP regulates the Miscellaneous Viscose Processes and Cellulose Ethers Production 

Categories. The Miscellaneous Viscose Process category includes cellulose food casings, rayon, 

cellulosic sponge, and cellophane manufacturing facilities. The NESHAP established emissions 

limits for hazardous air pollutants (HAPs), such as CS2, carbonyl sulfide, ethylene oxide, 

methanol, methyl chloride, propylene oxide, and toluene. The resulting additional air pollution 

control may be transferring more CS2 to the water via scrubbers (U.S. EPA, 2006). 

Gaseous by-products formed during the regeneration of cellulose, including hydrogen 

sulfide and CS2, are off-gassed from the process equipment. Facilities control emissions of these 

toxic gases using either a wet gas scrubber, a direct-contact condenser, or a biofilter system. In a 

wet gas scrubber, the air pollutants are absorbed by an aqueous solution. The wet scrubber 

removal efficiency for CS2 varies depending on facility specific operations. For example, some 

systems can remove up to 65 percent of CS2 prior to the stack (Marshall, 1998). The majority of 

the scrubbed CS2 is either recovered or sent to wastewater treatment as scrubber effluent 

wastewater. At other facilities, CS2 removal is low but the scrubber effluent wastewater may 

contain some CS2 (Schmidtke, 2000). 

In direct-contact condensers, water vapors are condensed out of the vent stream. The 

condensed water is sent to the wastewater treatment system. The remaining CS2 vapors are 

pulled by a vacuum jet to a second direct-contact condenser. The CS2 condenses because of the 

decrease in temperature and is sent to a settling tank with other process by-products. The 

condensed CS2 is piped underground to the storage tanks in the water containment pool. The CS2

emission reduction for these condenser systems is 99 percent (Schmidtke, 1998a). 

Biofilters are also used as air pollution control at cellulose products manufacturing 

facilities. Each biofilter (bed) has a plenum at the bottom (air space), a midsection that contains 

grating and media that contain microbes, and a cover on top. The gases enter the bottom of the 

bed and exit from the top. The removal efficiency of the biofilter varies based on process 

conditions; however, normal CS2 reductions across the bed are approximately 80 percent 

(Nicholson, 2000). Wastewater from the biofilter, which may contain some CS2, is sent to 

wastewater treatment facilities. The spent media from the biofilter are neutralized with lime and 

hauled offsite (Nicholson, 2000). 
Preliminary Study of Regenerated Cellulose Manufacturers 

13 

4.0 REGENERATED CELLULOSE PROCESS WASTEWATER TREATMENT

Table 9 summarizes the wastewater treatment used by the three cellulose products 

manufacturers where EPA obtained data (Schmidtke, 2000). Table 10 summarizes the possible 

sources of wastewater containing CS2 and the methods of wastewater treatment specific to each 

plant. 

Table 9. Cellulose Products Wastewater Treatment 

Product

Pretreatment Used by Indirect 

Dischargers Treatment Used by Direct Dischargers

Cellophane NA Neutralization, settling, equalization, 

second neutralization, aeration, and 

clarification (i.e., activated sludge) 

Food Casings Neutralization, filtration and 

settling. Achieved CS2

concentrations of 5-20 parts per 

million (ppm). 

Neutralization using lime, equalization, and 

clarification. 

Cellulosic Sponges Neutralization and oxidization Equalization, aeration, and clarification 

(activated sludge). 

Source: Industry Profile of the Cellulose Products Manufacturing Facilities in the U.S. (Schmidtke, 2000). 

NA – Not applicable. 

In addition to wastewater treatment, facility management practices also affect how much 

CS2 is discharged in wastewater. For example, the Loudoun, TN Viskase facility formerly used a 

water blanket during CS2 unloading. This led to 10,000 gallons of CS2 saturated water being 

discharged to the wastewater treatment facility every time CS2 was unloaded. By converting to 

the nitrogen blanket system, the Viskase facility eliminated a significant source of CS2

wastewater discharges (Schmidtke, 1998b). 
Preliminary Study of Regenerated Cellulose Manufacturers 

Table 10. Confirmed Sources of Wastewater and Wastewater Treatment at Cellulose Manufacturing 

Facility Name Location 

Product 

Type Possible Sources of Wastewater 

Wastewater 

Treatment 

1 

3M Corporation 

Elyria, OH Cellulosic 

Sponges 

- Biofilter - Oxidation 

- Neutralization - Holding tanks 

2 3M Corporation Tonawanda, NY Cellulosic Sponges - Storage tank displaced water - Rotary vacuum filters - Neutralization 3 

Innovia Films Inc. 

Tecumseh, KS Cellophane - Viscose steps 

- Extrusion/regeneration 

- Neutralization - Settling basin - Equalization basin - Activated Sludge 

4 

Spontex Inc. Columbia, TN Cellulosic 

Sponges 

- Storage tank displaced water - Railcar blowoff - H2S scrubber vacuum pump discharge 

- Equalization - Activated Sludge

5 

Viscofan USA Inc. 

Danville, IL Food 

Casings 

- Overflow of storage tank submersion water - Viscose steps (slurry, ripening, filtration) - Extrusion/regeneration - Washing - Acid systems (acid recovery, basement systems, 

anhydrous department) 

- Mixing basin - Neutralization - Settling basins - Discharge basin (stack) 

6 

Viskase Corporation 

Osceola, AR Food 

Casings 

- Viscose steps (ripening room trenches) - Extrusion/regeneration (extrusion wash water, extrusion  acid) - Deaerator condensate - Waste handling 

- Neutralization (lime) - Equalization - Clarifiers 

7 Viskase Corporation Loudon, TN Food Casings - Extrusion/regeneration - Washing - Filter 

- Neutralization 

Source: Industry Profile of the Cellulose Products Manufacturing Facilities in the U.S. (Schmidtke, 2000). a – ELGs control pollutant discharges at the point of discharges from industrial facilities and cover discharges directly to surface water (dire

discharges to POTWs (indirect discharges). 

14 
Preliminary Study of Regenerated Cellulose Manufacturers 

15

5.0 FACILITY DISCHARGE DATA

EPA reviewed all available CS2 concentration data for facilities presented in Table 3. 

EPA located wastewater treatment information for two facilities: Innovia Films, Inc in 

Tecumseh, KS and Viskase Corporation in Loudon, TN. 

5.1 Innovia Films, Inc in Tecumseh, KS

Innovia Films, Inc in Tecumseh, KS manufactures cellophane used primarily in food 

packaging. EPA obtained 2009 discharge monitoring report (DMR) data for this facility, the only 

cellulose products manufacturing facility required to monitor for CS2. EPA obtained facilityspecific waste stream and wastewater treatment data from the facility’s permit and fact sheet. 

5.1.1 Waste Streams 

Acid, alkaline, and neutral waste streams are generated from the cellulose production 

process. All process wastewaters are commingled, treated, and discharged through the treatment 

plant discharge (outfall 001). Approximately 2.0 MGD wastewater is treated and discharged 

through Outfall 001. Table 11 describes the facility waste streams and typical flow. 

Table 11. Innovia Films, Inc Waste Streams

Waste Stream Description Typical Flow (MGD) 

Alkaline Domestic waste flows and alkaline waste 

streams from the mix house, finishing, 

coating, casting, and the viscose 

manufacturing areas (VMA) 

0.67 

Acid Acid waste process flows from casting 

areas and the powerhouse a 

0.6 

Neutral Condensate flow from the hot well area 0.68 

Source: Facility Fact Sheet (KDHE, 2005). 

a – The powerhouse discharge also includes water from reverse osmosis cleaning and demineralizer washes. 

CS2 enters the wastewater from different processes at the plant (Martin, 2011): 

 Start up procedures that call for the dumping of liquid viscose (alkaline waste 

stream); 

 Overflow from the viscose process, which results in various losses of CS2 as 

liquid viscose (alkaline waste stream); 

 Continuous dumping of the coagulation bath solution to the wastewater treatment 

system, which is dumped to control the balance of sodium sulfate in the viscose 

process (alkaline waste stream); 

 Casting area water and wash water (acid waste stream); and 

 CS2 recovery system (neutral waste stream), which is described below. 

Because CS2 is volatile valuable feedstock, the facility recovers volatilized CS2 used in 

the process in the CS2 recovery system (Martin, 2011). The following process steps result in 

excess or liberated CS2 air emissions: 
Preliminary Study of Regenerated Cellulose Manufacturers 

16

 The xanthation step in the viscose process, where CS2 is sprayed on alkali 

cellulose to produce xanthate (an intermediate product in the cellophane process); 

 The extrusion/casting step, where the viscose solution is soaked in concentrated 

and dilute sulfuric acid baths, which liberates CS2 and hydrogen disulfide; and 

 The extrusion/casting step where the cellulose is washed in a hot water bath, 

which also liberates CS2. 

At the CS2 recovery plant, the facility uses steam to recover the CS2. Although the 

majority of the CS2 is recovered, the facility contact stated that some CS2 is captured in the steam 

condensate which is transferred to the wastewater treatment system (Martin, 2011). 

5.1.2 Wastewater Treatment 

The plant uses an activated sludge extended aeration process to treat the wastewater. The 

acid wastestream is first neutralized using hydrated lime in settling pond #1. The neutralized acid 

stream is then commingled with the alkaline and neutral wastestreams in settling pond #2. The 

combined wastestream is pumped to the equalization basin. As the wastestream is pumped from 

the equalization basin to the activated sludge aeration basin, the plant adds phosphoric acid and 

ammonium hydroxide to provide supplemental nutrients for biological treatment. The excess 

activated sludge is settled in clarifiers, and the treated effluent is discharged to the Kansas River 

through a long outfall sewer. The sludge is concentrated by a centrifuge and land applied 

(KDHE, 2005). Figure 3 diagrams the Innovia Films wastewater treatment system (Mester, 

2011). 
Preliminary Study of Regenerated Cellulose Manufacturers 

Settling Basin #1

Lime

Acid 

Wastestream

Holding Ponds Settling Pond #2

Neutral 

Wastestream

Alkaline 

Wastestream

Post Neutralization Equalization Tank

Sodium Hydroxide (if 

necessary)

Post Neutralization

Diversion Tank Aeration Basin

Splitter Box

100' Clarifier 60' Clarifier

Waste Sludge 

(Hauled Offsite)

Clarifier Overflow 

(Effluent) Discharge 

to Kansas River

Return Activated 

Sludge

Figure 3. Block Diagram of Innovia Films Wastewater Treatment System 

5.1.3 Discharge Data 

Innovia Films’ permit requires the facility to monitor for CS2 because concentrations at 

35 mg/L or greater inhibit the activated sludge process. The permit requires remedial action if the 

CS2 concentration exceeds 17.5 mg/L. The facility analyzes the CS2 samples using EPA Method 

624. 

The facility samples for CS2 at the splitter box, which receives flow from the aeration 

basin and feeds the flow to the clarifiers. The overflow (treated effluent) from the clarifiers is 

piped underground by gravity to the outfall. The outfall discharges to the receiving stream 

approximately 7,000 feet from the splitter box. Table 12 shows the 2008, 2009, and 2010 CS2

concentration data for Innovia Films, Inc. 

Table 12. 2008, 2009, and 2010 Carbon Disulfide Concentration Data for Innovia Films, 

Inc.

Outfall Date 

Monthly Minimum 

Concentration 

(mg/L) 

Monthly Average 

Concentration 

(mg/L) 

Monthly Maximum 

Concentration 

(mg/L) 

001 31-Jan-08 0.63 2.03 2.86 

001 29-Feb-08 1.58 4.98 8.45 

17
Preliminary Study of Regenerated Cellulose Manufacturers 

18

Table 12. 2008, 2009, and 2010 Carbon Disulfide Concentration Data for Innovia Films, 

Inc.

Outfall Date 

Monthly Minimum 

Concentration 

(mg/L) 

Monthly Average 

Concentration 

(mg/L) 

Monthly Maximum 

Concentration 

(mg/L) 

001 31-Mar-08 7.11 9.48 12.5 

001 30-Apr-08 0.56 0.56 0.56 

001 31-May-08 0.52 0.74 0.98 

001 30-Jun-08 0.13 0.55 0.99 

001 31-Jul-08 0.26 0.36 0.56 

001 31-Aug-08 0.75 0.75 0.75 

001 30-Sep-08 3.23 5.76 8.29 

001 31-Oct-08 0 0 0 

001 30-Nov-08 3.51 8.34 13.1 

001 31-Dec-08 0 2.14 4.29 

001 31-Jan-09 6.02 9.77 17.1 

001 28-Feb-09 5.19 5.19 5.19 

001 31-Mar-09 6.63 10.67 14.5 

001 30-Apr-09 0.25 0.39 0.52 

001 31-May-09 0.21 0.66 1.53 

001 30-Jun-09 0.07 0.22 0.33 

001 31-Jul-09 0.06 0.86 1.67 

001 31-Aug-09 0.25 0.25 0.25 

001 30-Sep-09 0.1 0.15 0.21 

001 31-Oct-09 0.16 0.85 1.55 

001 30-Nov-09 0 0.12 0.25 

001 31-Dec-09 4.14 4.14 4.14 

001 31-Jan-10 1.18 2.79 4.62 

001 28-Feb-10 1.74 3.22 4.7 

001 31-Mar-10 2.42 2.42 2.42 

001 30-Apr-10 0.88 1.54 2.14 

001 31-May-10 2.84 2.84 2.84 

001 30-Jun-10 0 0.07 0.14 

001 31-Jul-10 0.28 0.42 0.55 

001 31-Aug-10 0.24 0.27 0.30 

001 30-Sep-10 0.88 0.88 0.88 

001 31-Oct-10 0.79 0.84 0.88 

001 30-Nov-10 0.52 1.10 1.79 

001 31-Dec-10 2.94 3.50 4.07 

Source: Envirofacts 

As shown in Table 12, a total of 10 average concentrations (28 percent) exceed 3 mg/L, 

the acute freshwater toxicity level for CS2, and a total of 17 average concentrations (47 percent) 

exceed 1 mg/L, the chronic freshwater toxicity level for CS2 (Love, 2011). There are no 

concentrations above the 17.5 mg/L permit monitoring concentration. The Carbon Disulfide 

Coalition finds these concentrations are inconsistent with their experiences. The coalition 

reviewed analytical values from a wastewater treatment system consisting of aeration and 

neutralization only. The concentrations of CS2 at the discharge points were less than 1 mg/L, 

with an overall CS2 removal over 99 percent (Love, 2011). The final effluent concentrations are 

likely less than those taken at the splitter box, because after the sampling point, the wastewater 

goes through clarification and travels over 1.3 miles through a pipe to the surface water, allowing 

for further volatilization. 
Preliminary Study of Regenerated Cellulose Manufacturers 

19

5.2 Viskase Corporation in Loudon, TN

The Viskase Corporation in Loudon, TN is a food casings manufacturer, one of two 

operated by Viskase Corporation, the world’s largest producer of small-sized food casings 

(Schmidtke, 1998b). 

5.2.1 Wastewater Source and Treatment 

The Viskase Corporation plant uses approximately 1.95 MGD of water. Wastewater from 

the extrusion, regeneration, and washing areas is sent to the wastewater treatment facility. At the 

wastewater treatment plant, coarse materials are removed from the waste stream and the 

wastewater is neutralized with lime. The wastewater is sent off site for treatment at a POTW. 

The CS2 levels in the wastewater sent to the POTW typically vary between 5 and 20 ppm 

(Schmidtke, 1998b). 

5.2.2 Discharge Data 

In 2009, EPA contacted Viskase Corporation and the local pretreatment coordinator to 

confirm CS2 discharges. The facility’s industrial user permit limit for CS2 is 5 mg/L. Viskase 

collects samples at the point where the discharge leaves the facility and enters a pipe connected 

to the adjacent POTW. In addition, the POTW collects samples at the other end of this pipe, 

where the Viskase discharge enters the POTW. These samples are analyzed for CS2. The 

combined data show that the facility releases close to 100,000 pounds of CS2 to the POTW, but 

the POTW receives less than 3,000 pounds per year from the discharge pipe per year. This 

decrease in pollutant load suggests the possible volatilization of 97,000 pounds per year of CS2

within the discharge pipe (Birkholtz, 2009; Glarrow, 2009; U.S. EPA, 2009). 

The POTW provided CS2 concentration measurements taken at the influent to their 

treatment system. Table 13 shows the results of these sampling events. 

Table 13. Carbon Disulfide Concentration Data for Viskase Corporation in Loudon, TN 

Date 

POTW Measurement at Treatment 

Works Influent (mg/L) Discharge Limit (mg/L) 

13-Feb-06 12 5 

14-Aug-06 <0.001 5

20-Feb-07 <0.001 5

19-Sept-07 1.1 5

1-Apr-08 1.4 5

19-Aug-08 <0.001 5

3-Feb-09 <0.001 5

Source: Facility Contact (Birkholz, 2009). 

The CS2 concentrations for Viskase Corporation do not exceed the discharge limit of 5 

mg/L, except for the February 2006 concentration. More importantly, these discharges represent 

the CS2 concentrations prior to treatment through the POTW. Therefore, the CS2 concentrations 

are likely below levels of detection in the POTW effluent, and are likely of no concern to human 

health and aquatic life. 
Preliminary Study of Regenerated Cellulose Manufacturers 

20

6.0 CONCLUSIONS

The conclusions of the cellulose products manufacture review are as follows: 

 From available data, EPA identified seven active regenerated cellulose 

manufacturers in the U.S. These facilities use and discharge wastewater 

containing CS2 generated from CS2 storage, recovery, and the viscose process. 

EPA continues to resolve the overall question of how significant concentrations of 

CS2 (ranging from values below detection to 17.1 mg/L) remain in the water after 

treatment, although CS2 is highly volatile (430 times more volatile than acetone, 

for example). 

 There are three direct dischargers, but only one facility collects data on CS2 in 

their wastewater. This facility, Innovia Films, Inc, discharges up to 17.1 mg/L of 

CS2 after activated sludge wastewater treatment. There are 17 of 36 monthly 

average concentrations in the facility’s 2008 through 2010 CS2 data that are above 

the chronic freshwater toxicity level of 1 mg/L. The concentration of CS2 entering 

the receiving stream is likely lower, because the sample point is more than one 

mile from the final discharge point, allowing for further CS2 volatilization in the 

discharge pipe. The measurements reported by Innovia Films are inconsistent 

with information received from the Carbon Disulfide Coalition. Based on 

Coalition solubility and volatility data, the CS2 concentrations would be less than 

1 mg/L following aeration. 

 There are four indirect dischargers, but EPA obtained data from only one facility 

on CS2 in their wastewater. Because facilities pre-treat their wastewater, and it is 

processed through a POTW, CS2 concentrations for indirect dischargers likely are 

well below aquatic life criteria. 

 The cellulose products manufacturers using the viscose process include a small 

number of U.S. facilities. For this reason, EPA considers these discharges are best 

controlled by facility-specific permitting assistance. 

EPA prioritizes point source categories with existing regulations for potential revision 

based on the greatest estimated toxicity to human health and the environment, measured as 

TWPE. Based on the above conclusions, EPA will categorize these discharges with Part 414, 

OCPSF for future annual reviews. EPA is assigning this category with a lower priority for 

revision (i.e., this category is marked with “(3)” in the “Findings” column in Table V-1 in the 

Federal Register notice that presents the 2011 annual review of existing effluent guidelines and 

pretreatment standards). 

7.0 REFERENCES

1. Acetone. MSDS No. 00140 [Online]; Fischer Scientific: Fair Lawn, NJ. February 28, 

2008, http://fscimage.fishersci.com/msds/00140.htm (accessed August 2, 2011). 
Preliminary Study of Regenerated Cellulose Manufacturers 

21

2. Agency for Toxic Substances and Disease Registry (ATSDR). 1996. Toxicological 

Profile for Carbon Disulfide. Atlanta, GA. U.S. Department of Health and Human 

Services, Public Health Service. EPA-HQ-OW-2010-0824. DCN 07673. 

3. Beach, Robert, et al. 2000. Economic Analysis of Air Pollution Regulations: 

Miscellaneous Cellulose Manufacturing Industry, Industry Profile. Research Triangle 

Institute. (February). EPA-HQ-OW-2010-0824. DCN 07674. 

4. Birkholtz, Dave. 2009. Telephone conversation with Dave Birkholtz of City of Loudoun, 

TN POTW and Eleanor Codding of Eastern Research Group, Inc. “Carbon Disulfide 

Discharges Reported to TRI by Viskase Facility in Loudoun, TN.” (March 12). EPA-HQOW-2008-0517 DCN 07300. 

5. ERG, 2010. Quality Assurance Project Plan for the Plastics Molding and Forming 

Preliminary Category Review. (November). EPA-HQ-OW-2010-0824. DCN 07675. 

6. Ethanol. MSDS No. 91467 [Online]; Fischer Scientific: Fair Lawn, NJ. September 26, 

2007, http://fscimage.fishersci.com/msds/91467.htm (accessed August 2, 2011). 

7. Glarrow, Patrick. 2009. Telephone communication with Patrick Glarrow of Viskase in 

Loudoun, TN and Eleanor Codding of Eastern Research Group, Inc. “Carbon Disulfide 

Discharges Reported to TRI by Viskase Facility in Loudoun, TN.” (March 10). EPA-HQOW-2008-0517-0074. 

8. KDHE, 2005. Kansas Department of Health and Environment – Bureau of Water. 

NPDES Permit Fact Sheet for Innovia Films, Inc. NPDES KS0003204. Tecumseh, KS. 

(September). EPA-HQ-OW-2010-0824. DCN 07676. 

9. Kotz, John and Treichel, Paul. 1999. Chemistry and Chemical Reactivity, Fourth Edition. 

Saunders College Publishing. pp. 653-654. 

10. Love, Brian. 2011. Notes from E-mail Communication between Brian Love, Akzo Nobel, 

and Elizabeth Sabol, ERG. “RE: Carbon Disulfide - Fate and Transport.” (July 1). EPAHQ-OW-2010-0824. DCN 07677. 

11. Marshall, Amy and Rebecca Nicholson. 1998. Site Visit Notes from 3M Corporation, 

(NESHAP for the Miscellaneous Cellulose Manufacturing Industry). Tonawanda, NY. 

(November 3). EPA-HQ-OW-2010-0824. DCN 07678. 

12. Martin, Tony. 2011. Notes from Telephone Communication between Tony Martin, 

Innovia Films, Inc, and Elizabeth Sabol, ERG. “RE: Carbon Disulfide – Wastewater 

Discharges and Recovery System.” (August 1). EPA-HQ-OW-2010-0824. DCN 07679. 

13. Mester, Joe. 2011. Notes from Telephone Communication between Joe Mester, KDHE, 

and Elizabeth Sabol, ERG. “RE: Carbon Disulfide - Wastewater Discharges at Innovia 

Films, Inc.” (July 22). EPA-HQ-OW-2010-0824. DCN 07680. 

14. Nicholson, Rebecca and Amy Marshall. 2000. Site Visit Notes from Nylonge 

Corporation, (NESHAP for the Miscellaneous Cellulose Manufacturing Industry). Elyria, 

OH. (May 1, 2000). EPA-HQ-OW-2010-0824. DCN 07681. 
Preliminary Study of Regenerated Cellulose Manufacturers 

22

15. Ohio EPA, 2010. National Pollutant Discharge Elimination System (NPDES); BADCT 

Limits for Volatile Organic Compounds. (November 8). EPA-HQ-OW-2010-0824. DCN 

07683. 

16. OSHA, 1994. Guidelines for Carbon Disulfide. Available online at: 

http://www.osha.gov/SLTC/healthguidelines/carbondisulfide/recognition.html 

17. Schmidtke, Karen and Rebecca Nicholson. 1998a. Site Visit Notes from Lenzing Fibers 

Corporation in Lowland, TN (Miscellaneous Cellulose Manufacturing Industry 

NESHAP). Lowland, TN. (May 22). EPA-HQ-OW-2010-0824. DCN 07682. 

18. Schmidtke, Karen and Rebecca Nicholson. 1998b. Site Visit Notes from Viskase 

Corporation in Loudon, TN (Miscellaneous Cellulose Manufacturing Industry NESHAP). 

Loudon, TN. (August 4). EPA-HQ-OAR-2003-0193-0006. 

19. Schmidtke, Karen and Thomas Holloway. 2000. Industry Profile of the Cellulose 

Products Manufacturing Facilities in the U.S. Prepared for U.S. EPA National Emissions 

Standards for Hazardous Air Pollutants: Cellulose Products Manufacturing. Cary, NC. 

(April 11). EPA-HQ-OAR-2003-0193-0004. 

20. U.S. EPA. EPA On-line Tools for Site Assessment Calculation. Available online at: 

http://www.epa.gov/athens/learn2model/part-two/onsite/sparcproperties.html

21. U.S. EPA. 1984. Development Document for Effluent Limitations Guidelines and New 

Source Performance Standards for the Plastics Molding and Forming Point Source 

Category. EPA 440/1-84/069. Washington, DC. (December). 

22. U.S. EPA. 1987. Development Document for Effluent Limitations Guidelines and 

Standards for the Organic Chemical, Plastics, and Synthetic Fibers Point Source 

Category - Final. EPA 4401-87-009. Washington, DC. (October). 

23. U.S. EPA. 2005a. Preliminary Review of Prioritized Categories of Industrial 

Dischargers. EPA-821-B-05-004. Washington, DC. (August). EPA-HQ-OW-2004-0032-

0053. 

24. U.S. EPA. 2005b. Product and Product Group Discharges Subject to Effluent Limitations 

and Standards for the Organic Chemicals, Plastics, and Synthetic Fibers Point Source 

Category - 40 CFR 414. Washington, DC. EPA-HQ-OW-2004-0032-0941. 

25. U.S. EPA. 2006. Technical Support Document for the 2006 Effluent Guidelines Program 

Plan. EPA-821-R-06-018. Washington, DC. (December). EPA-HQ-OW-2004-0032-

2782. 

26. U.S. EPA. 2009. Technical Support Document for the Preliminary 2010 Effluent 

Guidelines Program Plan. EPA-821-R-09-006. Washington, DC. (October). EPA-HQOW-2008-0517-0515. 

27. U.S. EPA. 2011. Technical Support Document for the 2010 Effluent Guidelines Program 

Plan. Washington, D.C. (October). EPA-820R-10-021. EPA-HQ-OW-2008-0517 DCN 

07320. 
Preliminary Study of Regenerated Cellulose Manufacturers 

A-1 

APPENDIX A 

40 CFR Part 414 

EPA first promulgated ELGs for the OCPSF Category (40 CFR Part 414) on November 

5, 1987 (52 FR 42568). This category consists of seven subcategories that apply to the 

manufacture of products and product groups, as shown in Table A-1 with corresponding 

Standard Industrial Classification (SIC) codes and applicability. Subparts B through H have 

limitations for biochemical oxygen demand (BOD5), total suspended solids (TSS), and pH. The 

regulation also includes limitations and/or pretreatment standards for certain toxic pollutants in 

three additional subparts: 

Subpart I — Direct Discharge Point Sources That Use End-of-Pipe Biological Treatment; 

Subpart J — Direct Discharge Point Sources That Do Not Use End-of-Pipe Biological 

Treatment; and 

Subpart K — Indirect Discharge Point Sources. 

Table A-1. Applicability of Subcategories in the OCPSF Category

Subpart Subcategory Title Corresponding SIC Code(s) a Subcategory Applicability 

B Rayon Fibers 2823: Cellulosic Manmade 

Fibers 

Cellulosic manmade fiber (Rayon) 

manufactured by the Viscose process. 

C Other Fibers 2824: Synthetic Organic Fibers, 

Except Cellulosic 

All other synthetic fibers (except Rayon) 

including, but not limited to, products 

listed in Section 414.30. 

D Thermoplastic Resins 28213: Thermoplastic Resins Any plastic product classified as a 

thermoplastic resin including, but not 

limited to, products listed in Section 

414.40. 

E Thermosetting Resins 28214: Thermosetting Resins Any plastic product classified as a 

thermosetting resin including, but not 

limited to, products listed in Section 

414.50. 

F Commodity Organic 

Chemicals 

2865: Cyclic Crudes and 

Intermediates, Dyes and 

Organic Pigments 

2869: Industrial Organic 

Chemicals, NEC 

Commodity organic chemicals and 

commodity organic chemical groups 

including, but not limited to, products 

listed in Section 414.60. 

G Bulk Organic 

Chemicals 

2865: Cyclic Crudes and 

Intermediates, Dyes and 

Organic Pigments 

2869: Industrial Organic 

Chemicals, NEC 

Bulk organic chemicals and bulk organic 

chemical groups including, but not limited 

to, products listed in Section 414.70. 

H Specialty Organic 

Chemicals 

2865: Cyclic Crudes and 

Intermediates, Dyes and 

Organic Pigments 

2869: Industrial Organic 

Chemicals, NEC 

All other organic chemicals and organic 

chemical groups including, but not limited 

to, products listed in the OCPSF 

Development Document (Vol. II, 

Appendix II-A, Table VII). 

Source: Product and Product Group Discharges Subject to Effluent Limitations and Standards for the Organic 

Chemicals, Plastics, and Synthetic Fibers Point Source Category — 40 CFR 414, Table 2-2 (U.S. EPA, 2005b). 

a – During the 2009 annual review EPA developed a crosswalk between SIC codes and NAICS codes. Because there 

is not a direct match EPA did not report NAICS codes. 

NEC – Not elsewhere classified.