Need to return call by / at/between and

. Signature: Project No.: 

### 0 317.0 2 .005.510 Page 1 of 3

Project Name: 

### DMR20 1 3 

## CBI?

Yes

No TELEPHONE CALL RECOR D

Incoming

Outgoing Date: 

### 12/22 /1 4 Time: 

### 2 :3 0 am

pm

Company Name: 

### JR Simplot ERG Staff Name: 

### Kimberly Bartell

Contact Name: 

### John Prigge Contact Phone Number: 

### ( 208) 369

- 8851

General Subject: 

### 2013 TRI Hydrogen Sulfide Discharges for JR Simplot in Grand Forks, ND



## TOPICS DISCUSSED AND ACTION TAKEN

On December 22 nd 

### , I called Mr. Myers and left a message.

On December 26 th 

### , John Prigge (john.prigge@simplot.com) returned my call and left a message stating that he

is the Environmental Manager for the Idaho plant. His cell is 208

- 369

- 8851. I called and left a message for him

on December 30 th



### .

On January 5 th 

### , Mr. Prigge returned my call. He stated that in 2013 the facility discharged to their own

wastewater treatment system, an anaerobic digester. The facility has since put in a much larger treatment system

at the facility. The corporate office provided instructions on how to report hydrogen sulfide discharges to T RI.

The facility took various measurements on their wastewater going to the anaerobic digester including flow rate,

COD, temperature, and pH. These measurements were used in a spreadsheet provided by the corporate office to

calculate a lbs of hydrogen sulf ide discharge. The facility also takes a sample of H2S from their digester flare,

but this is not used in the aqueous H2S calculations since it’s in the gas phase. The flare burns 98% of the

gaseous H2S.

Mr. Prigge also stated that the facility has a lar ge land application site (a lagoon) and they review the pounds of

H2S entering and existing this lagoon (and account for the amount lost to the atmosphere). The wastewater from

the facility first enters the anaerobic digester and then flows to the lagoon. H2S concentrations are measured at

both the digester and the lagoon; the amount reported to TRI is the sum of both H2S discharges.

The facility is a potato manufacturing plant, and the source of the H2S is t he breakdown of potato product. Mr.

Prigge requ ested an email to confirm the amount of hydrogen sulfide discharged. Please see attached email

communication.

David Huck from the corporate JR Simplot office in Boise, ID called me on January 6 th 

### and stated that he would

be responding to my request for th e Grand Forks facility. They are also a potato manufacturing facility. See

attached email communication.Need to return call by / at/between and

. Signature: 

### Email Communication with JR Simplot:

From: David Huck (david.huck@simplot.com)

To: Kimberly Bartell

CC: Burl Ackerman, John Prigge, Casey Byram

Date: 1/9/15 5:30 PM

Subject: RE: 2013 Clarification for Hydrogen Sulfide Discharges

Good Afternoon Ms. Bartell,

John Prigge of our Caldwell, ID manufacturing plant forwarded me your message to respond on behalf of our Grand

Forks, ND facility. As you m ay recall from our phone conversation a couple days ago, I am a Simplot corporate

environmental manager based in Boise, ID and can provide you with the Grand Forks facility information you are looking

for. Please see my comments to the questions you asked regarding how our Grand Forks facility calculated hydrogen

sulfide in effluent discharged to the City of Grand Forks POTW.

Hope this is what you were looking for. Let me know if you have any additional questions or comments.

Thanks

David Huck, MNRM

Environmental Engineering Manager

J. R. Simplot Company

Tel. (208) 389

- 7519 | Cell. (208) 789

- 1356

david.huck@simplot.com

From: Kimberly Bartell

To: john.prigge@simplot.com

CC: Kim Wagoner, William Swietlik

Date: 1/6/15 2:48 PM

Subject: 2013 Clarification for Hydrogen Sulfide Discharges

Dear Mr. Prigge:

Thank you for your time on the phone yesterday. As discussed, Eastern Research Group, Inc. (ERG) under EPA Contract

No. EP

- C

- 12

- 021, is e

- mailing y ou to request information for JR Simplot in Grand Forks, ND (TRI ID:

58201JRSMP3630G). See below for background on what the information is used for.

EPA reviews publicly

- available discharge monitoring report (DMR) and toxic release inventory (TRI) data to fulfill its

review obligation under Section 304(b) of the Clean Water Act. The CWA requires EPA to annually review and, if

appropriate, revise its water pollution control technology

- based regulations, called "effluent guidelines," that limit the

discharge of pollutants to waters of the U.S. from various categories of industrial facilities. EPA is currently conducting

its 2015 annual review of existing effluent guidelines and potential industrial guidelines which may need to be included

(see http://www.epa.gov/guide/304m/ for further information). EPA will discuss this review and the results in its 2015

Effluent Guidelines Program Plan scheduled for publication in the Federal Register sometime in 2015 or 2016.Need to return call by / at/between and

. Signature: As part of the 2015 annual review, EPA is evaluating the data reported to the 2013 TRI and needs further information to

complete the review. Specifically, we would like to clarify the amount of hydrogen sulfide releases to TRI from JR

Simplot in Grand For ks, ND. Please confirm/review the following data and questions below.

1. Please confirm the pounds of hydrogen sulfide released in 2013: 22,931 lbs

2. As discussed on the phone, below is a summary of how the hydrogen sulfide load for TRI is calculated. Please

confirm this description is correct and provide any additional details, including monitoring data if available.

The facility discharges wastewater to an anaerobic digester where the flow rate, COD, pH, temperature, and other

measurements are taken. The wa stewater from the digester then flows to a lagoon where similar measurements are

taken. Values from the digester and lagoon are entered into a spreadsheet provided by the JR Simplot corporate

office to calculate the hydrogen sulfide discharge reported to T RI. The facility also samples the hydrogen sulfide

at the digester flare, but this data is not used to report TRI wastewater discharges since it’s in the gaseous phase.

The source of the hydrogen sulfide in the wastewater is from the breakdown of potato pr oduct.

We appreciate your help in interpreting TRI data correctly. If you have any questions regarding this request, please call

me at (517) 515

- 1721. If you would like to speak directly with EPA regarding this request, you can contact William F.

Swietli k of EPA's Office of Water/Engineering Analysis Division by phone at (202) 566

- 1129 or by email:

swietlik.william@epa.gov

.

Thank you,

Kimberly

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

Environmental Engineer

Eastern Research Group, Inc.

kimberly.bartell@erg.com

Phone: 517

- 515

- 1721