Need to return call by / at/between and

. Signature: Project No.: 

### 0317.00.005.522 Page 1 of 1
Project Name: 

### TRI20 11 

## CBI? Yes No TELEPHONE CALL RECOR D Incoming Outgoing Date: 

### 01/30 /13 Time: 

### 2 : 00 am pm

Company Name: 

### AF&PA and NCASI ERG Staff Name: 

### Kimberly Bartell

Contact Name: 

### Paul Wiegand & Jerry Schwartz Contact Phone Number: 

### ( 919 ) 941

- 6417/(800)878

- 8878 General Subject: 

### 2011 TRI Pulp and Paper Dioxin Discharges



## TOPICS DISCUSSED AND ACTION TAKEN

On January 30, 2013 ERG held a conference call with Paul Wiegand of NCASI and Jerry Schwartz of AF& PA. Kim Bartell and Liz Sabol were on the phone from ERG. ERG explained that EPA wants to confirm its 2011 TRI Pulp and Paper Dioxin Discharges for four pulp and paper facilities. The data was reviewed with NCASI and AF&PA and they requested more specific questions for each mill. They also wanted to know why these four facilities had been chosen; it was explained that they were the highest ranking in terms of TWPE for the pulp and paper category. Mr. Wiegand and Mr. Schwartz also requested that ERG provide some of our conclusions when looking at the sampling data. They stated that to their knowledge the facilities have not been using the DMR Loading Tool recently.

Paul Wiegand: pwiegand@ncasi.org , 919

- 941

- 6417 Jerry S chwartz: jerry_schwartz@afandpa.org , 800

- 878

- 8878

On February 22, 2013 I spoke with Jerry Schwartz of AF& PA. He had sent the response from S.D. Warren and stated that they are always willing to cooperate with us but that they perform the same calculations every year. The facility is wondering if they will be contacted again regarding their dioxin discharges. I told Mr. Schwartz that we would only contact the facility in the future if their data looks off and raises a concern since we have documented their calculation process for dioxin discharges. Mr. Schwartz stated that he would communicate this to the plant

.
Please see attached email correspondence for additional information on pulp facilities.

### AF&PA & NCASI Email Communication

From: Kimberly Bartell To: Schwartz, Jerry ; Wiegand, Paul CC: Sabol, Elizabeth Date: 3/7 /2013 1:02 P M Subject: RE: 2011 TRI Pulp and Paper Dioxin Dischargers

Jerry,

Thank you for this information. I will review it and let you know if we have any further questions.

Thanks again, Kimberly

---------------------------------------- Kimberly D. Bartell Environmental Engineer Eastern Research Group, Inc. kimberly.bartell@erg.com
Phone: 517

- 515

- 1721

From: Jerry Schwartz To: Bartell, Kimberly ; Wiegand, Paul CC: Sabol, Elizabeth Date: 3/7 /2013 12:58 PM Subject: 2011 TRI Pu lp and Paper Dioxin Dischargers

Kimberly: Here is the Simpson response. Please let me know if you have any questions. Jerry

From: Kimberly Bartell To: Schwartz, Jerry CC: Sabol, Elizabeth; Wiegand, Paul Date: 3/6/2013 5:45 P M Subject: RE: 2011 TRI Pulp and Paper Dioxin Dischargers

- Rayonier, Fernandina Beach, FL

Jerry,

That's great, thanks for the update!

Kimberly

---------------------------------------- Kimberly D. Bartell Environmental Engineer Eastern Research Group, Inc. kimberly.bartell@erg.com
Phone: 517

- 515

- 1721

From: Jerry Schwartz To: Bartell, Kimberly ; Wiegand, Paul CC: Sabol, Elizabeth; David.rogers@rayonier.comDate: 3/6/2013 5:22 PM

Subject: 2011 TRI Pulp and Paper Dioxin Dischargers

- Rayonier, Fernandina Beach, FL

All; I have had some communications with Simpson and I should have something for you soon.

From: Kimberly Bartell To: Wiegand, Paul CC: David.rogers@rayonier.com ; Sabol, Elizabeth; Schwartz, Jerry Date: 3/6/2013 5:19 P M Subject: RE: 2011 TRI Pulp and Paper Dioxin Dischargers

- Rayonier, Fernandina Beach, FL

Paul,

Thank you for this information. I will review the responses and let you know if we have any further questions.

Thanks again, Kimberly

----------------------------------- ----- Kimberly D. Bartell Environmental Engineer Eastern Research Group, Inc. kimberly.bartell@erg.com
Phone: 517

- 515

- 1721

From: Wiegand, Paul To: Bartell, Kimberly CC: Sabol, Elizabeth; Schwartz, Jerry ; David.rogers@rayonier.com Date: 3/6/2013 5:13 PM Subject: 2011 TRI Pulp and Paper Dioxin Dischargers

- Rayonier, Fernandina Beach, FL

Kimberly,

I have been in communication with David Rogers at Rayonier’s mill in Fernandina Beach, FL regarding your request for information rela ted to 2011 TRI reports for dioxin and dioxin

- like compounds. The text below provides responses to the four questions you posed concerning differences between 2009 and 2011 TRI reports. The attached files support those responses. Please let me know if y ou have additional questions.

1. Please confirm the 2011 dioxin distribution shown above (in the attached spreadsheet).

The data in the spreadsheet are correct.

2. Are there any updated sampling data for dioxin compounds (updated data sources , new sampling, etc.)?

Yes. A copy of the data used for the 2011 TRI reports is provided.

3. Can you explain why congeners 5 and 10 were reported in the 2009 distribution and reported as "0" in the 2011 distribution?

We did not have any hits in the 2011 samplings for congeners 5 or 10, the values were all ND.4. If there are updated sampling data, please provide a copy of the results. Were any congeners detected

above the Method 1613B Minimum Level in 2011 (see table above for minimum levels)?

As you can see in the attached information, there were hits above the Method 1613B Minimum Level for cogener 7 at a mean of 268.7 pg/L and cogener 8 at a mean of 18.5 pg/L.

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: Kimberly Bartell To: Wiegand, Paul CC: MaryLeeRansmeier@BoiseInc.com; Sabol, Elizabeth; Schwartz, Jerry Date: 2/22/2013 11:57 AM Subject: RE: 2011 TRI Pulp and Paper Dioxin Dischargers

- Boise, Wallula WA

Paul,

Thank you for sending this information. I will review the responses and will let you know if we have any further questions.

Thanks again, Kimberly

---------------------------------------- Kimberly D. Bartell Environmental Engineer Eastern Research Group, Inc. kimberly.bartell@erg.com Phone: 517

- 515

- 1721

From: Wiegand, Paul To: Bartell, Kimberly CC: MaryLeeRansmeier@BoiseInc.com; Sabol, Elizabeth; Schwartz, Jerry Date: 2/21/2013 10:45 PM Subject: 2011 TRI Pulp and Paper Dioxin Dischargers

- Boise, Wallula WA

Kimberly,

Find attached a spreadsheet that was prepared by Boise’s Wallula mill staff in response to your questions concerning the 2011 TRI report for dioxin and dioxin

- like compounds. I think the answers are straightforward but if you have additional questions I’d be happy to coordinate responses with the company.

Paul

Paul W iegand Vice President

- Water Quality National Council for Air and Stream Improvement (NCASI), Inc. P.O. Box 13318Research Triangle Park, NC 27709

- 3318

phone (919) 941

- 6417 cell (919) 607

- 8120 fax (919) 941

- 6401 PWi egand@ncasi.org

If you do not wish to be contacted by NCASI please notify publications@ncasi.org

From: Schwartz, Jerry To: Bartell, Kimberly Date: 2/22/2013 10:56 AM Subject: RE: 2011 TRI Pulp and Paper Dioxin Discharges

No problem. Yes, the congeners.

From: Kimberly Bartell To: Schwartz, Jerry Date: 2/22/2013 10:53 AM Subject: RE: 2011 TRI Pulp and Paper Dioxin Discharges

Jerry,

Sorry to bother you, but I wanted to confirm one thing with you: when SAPPI states below that the congener data in columns 13 & 14 had been reversed, they are referencing congeners 13 and 14, correct? The columns are labeled with letters not numbers so I'm assuming they are talking about the congeners 13 & 14 but I wanted to double check with you to make sure I am interpreting it correctly.

Thank you! Kim

---------------------------------------- Kimberly D. Bartell Environmental Engineer Eastern Research Group, Inc. kimberly.bartell@erg.com Phone: 517

- 515

- 1721

From: Kimberly Bartell To: Schwartz, Jerry; Wiegand, Paul CC: Sabol, Elizabeth Date: 2/22/2013 7:03 AM Subject: RE: 2011 TRI Pulp and Paper Dioxin Discharges

Jerry,

Thank you for sending us this information. I look forward to talking to you today about the SAPPI data.

Thanks again, Kim

From: Schwartz, Jerry To: Bartell, Kimberly, Wiegand, Paul CC: Sabol, Elizabeth Date: 2/21/2013 10:45 PM Subject: RE: 2011 TRI Pulp and Paper Dioxin DischargesKim: Here is the response from SAPPI. I think it is pretty self

- explanatory. Also, I will give you a call tomorrow to

discuss one aspect of this. Thanks.

Jerry,

As discussed the calculation process for 2011 was the same as previous years. The concentration data obtained in 2002 was applied to the annual flow rate and then we made corrections for the naturally occurring congers ( i.e. OCDD, HpCDD and OCDF ) contained in the mill’s receiving water, pu lp wood and kaolin clay. After review of the 2011 data it was found that the congener data in columns 13 and 14 had been inadvertently reversed. As discussed this does not change the reported totals.

Kind Regards, Kim Hibbard

From: Kimberly Bartell To: Schwartz, Jerry; Wiegand, Paul CC: Sabol, Elizabeth Date: 2/5/2013 8:07 AM Subject: RE: 2011 TRI Pulp and Paper Dioxin Discharges

Jerry and Paul,

Thank you for getting back to us. Please let us know if you have any further questions as you contact the mi lls.

Thank you, Kimberly

---------------------------------------- Kimberly D. Bartell Environmental Engineer Eastern Research Group, Inc. kimberly.bartell@erg.com Phone: 517

- 515

- 1721

From: Schwartz, Jerry To: Bartell, Kimberly, Wiegand, Paul CC: Sabol, Elizabeth Date: 2/5/2013 7:17 AM Subject: RE: 2011 TRI Pulp and Paper Dioxin Discharges

Kimberly. Paul and I have discussed it and we have all we need

- this format is a better approach. We can take it from h ere.

Jerry Schwartz Sent from my iPhone

From: Wiegand, Paul To: Bartell, Kimberly, Schwartz, Jerry CC: Sabol, Elizabeth Date: 2/4/2013 4:54 PM Subject: RE: 2011 TRI Pulp and Paper Dioxin Discharges

Kimberly,

This is quite helpful. Jerry and I will discuss it, but I think we’ll have what we need to begin communications with the mills.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

If you do not wish to be contacted by NCASI please notify publications@ncasi.org

From: Kimb erly Bartell To: Schwartz, Jerry; Wiegand, Paul CC: Sabol, Elizabeth Date: 2/4/2013 3:44 PM Subject: 2011 TRI Pulp and Paper Dioxin Discharges

Jerry and Paul,

Based on our call last week, ERG revised the dioxin data excel spreadsheet to include facility specific questions. Attached please find the revised spreadsheet. As before, there are four facilities included in the spreadsheet along with individual dioxin distributions for each facility.

Please let me know if you have any questions about the data or if you would like to set up another call.

Thank you! Kimberly

---------------------------------------- Kimberly D. Bartell Environmental Engineer Eastern Research Group, Inc. kimberly.bartell@erg.com Phone: 517

- 515

- 1721

From: Schwartz, Jerry To: Bartell, Kimberly, Wiegand, Paul CC: Sabol, Elizabeth Date: 1/30/2013 9:32 AM Subject: RE: 2011 TRI Pulp and Paper Dioxin Dischargers Meeting Thanks, Kimberly. This will help us get ready for the call. From: Kimbe rly Bartell To: Schwartz, Jerry; Wiegand, Paul CC: Sabol, Elizabeth Date: 1/30/2013 9:23 AM Subject: 2011 TRI Pulp and Paper Dioxin Dischargers Meeting

Jerry and Paul,

Before our 2pm call today I wanted to send you a summary of the data we are reviewing. Attached please find a word document summarizing our 2013 annual review process and questions we have, and an excel document with dioxin distributions for the four facilities we are looking at. Please let me know if you have any questions prior to our cal l.

Thank you!Kimberly

---------------------------------------- Kimberly D. Bartell (Landick) Environmental Engineer Eastern Research Group, Inc. kimberly.bartell@erg.com Phone: 517

- 515

- 1721

From: Kimberly B artell To: Schwartz, Jerry; Wiegand, Paul CC: Sabol, Elizabeth; Wagoner, Kim Date: 1/28/2013 9:34 AM Subject: Re: 2011 TRI Clarification for Dioxin Discharges

Jerry and Paul,

Thank you for getting back to me. I looked at everyone's schedules and it looks like Wednesday at 2pm will work. I'll go ahead and send an appointment shortly.

Thanks again, Kimberly

---------------------------------------- Kimberly D. Bartell (Landick) Environmental Engineer Eastern Research Group, Inc. kimberly.bartell@erg.com Phone: 517

- 515

- 1721

From: Schwartz, Jerry To: Bartell, Kimberly CC: Sabol, Elizabeth; Wagoner, Kim; Wiegand, Paul Date: 1/25/2013 6:06 PM Subject: RE: 2011 TRI Clarification for Dioxin Discharges

Kimberly. Happ y to do it. Next week I am open Wednesday 9

- 4, Thursday 3

- 5 and Friday 9

- 1. Thanks Jerry Schwartz Sent from my iPhone

From: Wiegand, Paul To: Bartell, Kimberly , Schwartz, Jerry CC: Sabol, Elizabeth; Wagoner, Kim Date: 1/24 /2013 3:07 PM Subject: RE: 2011 TRI Clarification for Dioxin Discharges

Hi Kimberly.

I’d be happy to discuss 2011 TRI questions on dioxin discharges. My schedule next week is pretty open. Times I

canno t attend a call are Tuesday before 1:00 PM, Thursday 2

- 3:00 PM, and Friday 1

- 2:0 0 PM. Other times would be fine.

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

- 64 01 PWiegand@ncasi.org

From: Kimberly Bartell To: Schwartz, Jerry; Wiegand, Paul CC: Sabol, Elizabeth; Wagoner, Kim Date: 1/24/2013 2:59 P M Subject: 2011 TRI Clarification for Dioxin Discharges

Jerry and Paul,

As discussed on the phone Eastern Research Group Inc. (ERG) would like to schedule a meeting to discuss 2011 TRI pulp and paper dioxin dischargers. Please let me know if you are available next week for a conference call.

If you have any questions, please fee l free to call me at 517

- 515

- 1721.

Thank you! Kimberly

---------------------------------------- Kimberly D. Bartell (Landick) Environmental Engineer Eastern Research Group, Inc. kimberly.bartell@erg.com Phone : 517

- 515

- 1721Boise White Paper LLC Wallula, WA 99363BSCSCPOBOX

Year Grams Released 2009 2.3204 Congener Number 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17

2011 1.55094 2009 (Submitted by Facility During 2011 Annual Review) 0.034618 0.003643 0.005942 0.005709 0.005425 0.261445 1.353729 0.470188 0.030226 0.045469 0 0 0.005193 0.004237 0 0 0.094554 2011 0 0 0 0 0 0.13964 1.14183 0.16143 0.03806 0.05145 0 0 0.01827 0 0 0 0.00026 2012 0 0 0 0 0 0.246142 1.574584 0.240454 0.083771 0.141687 0 0.058174 0 0 0 0 0

Congener Number 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 2009 Effluent Test Data (Submitted by Facility During 2011 Annual Review) 1.34 0.281 (ND) 0.459 (ND) 0.442 (ND) 0.420 (ND) 15.1 87.1 18.2 1.17 1.76 0.281 (ND) 0.284 (ND) 0.327 (ND) 0.401 (ND) 0.418 (ND) 0.380 (ND) 6.84 Method 1613 B Minimum Level 10 50 50 50 50 50 100 10 50 50 50 50 50 50 50 50 100 2011 Effluent Test Data ND ND ND ND ND 10.3 78.2 6.15 1.45 1.96 ND 0.673 0.696 ND 1.51 ND 3.19 2012 Effluent Test Data ND ND ND ND ND 14.5 95.6 9.30 3.24 5.48 ND 3.15 ND ND ND ND ND

Facility Specific Questions:

1. Please confirm the 2011 dioxin distribution shown above. The 2011 dioxin distribution is correct.

2. Are there any updated sampling data for dioxin compounds (updated data sources, new sampling, etc.)? Yes, 2012 values are included in the table above.

3. Can you explain why congeners 1, 2, 3, 4, 5, and 14 were reported in the 2009 distribution and reported as "0" in the 2011 distribution? In 2009, one-half the detection limit was used for the congeners that were reported by the testing laboratory as ND. Since 2009, ND congeners were reported as zero per the NCASI SARA 313 Handbook, Dioxin and Dioxin-like Compounds, Consideration of Non-detects, pages 2 & 3

4. If there are updated sampling data, please provide a copy of the results. Were any congeners detected above the Method 1613B Minimum Level in 2011 (see table above for minimum levels)? 2012 values are included in the table above. There were no 2011 congeners detected above the Method 1613B Minimum Level (see table above). 2012 2.3448 Total Water Release (g)

Effluent Sampling Data - Provided to EPA as Part of 2011 Annual Reviews (pg/L)Simpson Tacoma Kraft Co. LLC Tacoma, WA 98421SMPSN801PO

Year Gram Released 2009 2.2429 Congener Number 1 2 3 4 5 6 7 8 9

2011 0.7893 2009 (Submitted by Facility During 2011 Annual Review) 0 0 0.0717 0.1191 0.0947 0.4535 0.9023 0.028 0.0827 2011 0 0.0062 0 0.0101 0.0042 0.0971 0.5746 0.0093 0.011

Congener Number 1 2 3 4 5 6 7 8 9 Sampling Data (Confirmed with Facility During 2011 Annual Review) 0 0 3.05 5.07 4.03 19.3 38.4 4.76 3.52 Method 1613 B Minimum Level 10 50 50 50 50 50 100 10 50

Facility Specific Questions: 1. Please confirm the 2011 dioxin distribution shown above. 2. Are there any updated sampling data for dioxin compounds (updated data sources, new sampling, etc.)? 3. Can you explain why congeners 3 and 11 were reported in the 2009 distribution and reported as "0" in the 2011 distribution? 4. Can you explain why congeners 2 and 15 were reported in the 2011 distribution and reported as "0" in the 2009 distribution? 5. If there are updated sampling data, please provide a copy of the results. Were any congeners detected above the Method 1613B Minimum Level in 20

ANSWERS:

1 The 2011 dioxin distribution appear to be entered correctly as shown above. 2 See tab DATA for 2012 data. 3 The congeners 3 and 11 in 2011 were non-detect, while in 2009 they were not non-detect. There is no known cause for the difference. 4 The congeners 2 and 15 in 2009 were non-detect, while in 2011 they were not non-detect. There is no known cause for the difference. 5 Updated test data for 2012 are in the DATA tab.

Regarding the minimal levels mentioned above, the lab doing the testing reported that they are able to achieve accurate results below the mentioned method limits. Total Water Release (g)

Effluent Sampling Data - Provided to EPA as Part of 2011 An10 11 12 13 14 15 16 17

0.1647 0.0576 0.0698 0 0.0928 0 0 0.106 0.0121 0 0.0084 0 0.0085 0.0223 0 0.0255

10 11 12 13 14 15 16 17

7.01 2.45 2.97 0 2.95 0 0 4.51

50 50 50 50 50 50 50 100 3.95

011 (see table above for minimum levels)? nual Reviews (pg/L)Simpson Tacoma Kraft Co. LLC Tacoma, WA Data from Facility Contact

2011 TEST DATA-All zero values were non-detects As reported in EPA TRI

AFPA Secondary Effluent 2011 pg/Liter Emissions Based on Annual testing (Re-arranged order) cogen # Date 1st Quarter 2nd Quarter 3rd Quarter 4th Quarter Average Grams/Year Effluent Flow gal/Yr
1 17-2378 TCDD 0 0 0 0 0 0.0000 1 0.0223
2 15-12378 PeCDD 1.03 0 0 0 0.2575 0.0062 2 0.0000
3 7-123478 HxCDD 0 0 0 0 0 0.0000 3 0.0000
4 8-123678 HxCDD 1.67 0 0 0 0.4175 0.0101 4 0.0084
5 9-123789 HxCDD 0 0.698 0 0 0.1745 0.0042 5 0.0000
6 10-1234678 HpCDD 8.58 7.44 0 0 4.005 0.0971 6 0.0085
7 12-12346789 OCDD 34.9 30.3 13.3 16.3 23.7 0.5746 7 0.0000
8 16-2378 TCDF 1.54 0 0 0 0.385 0.0093 8 0.0101
9 13-12378 PeCDF 1.19 0.625 0 0 0.45375 0.0110 9 0.0042
10 14-23478 PeCDF 2 0 0 0 0.5 0.0121 10 0.0971
11 3-123478 HxCDF 0 0 0 0 0 0.0000 11 0.0255
12 4-123678 HxCDF 0.837 0.55 0 0 0.34675 0.0084 12 0.5746
13 5-123789 HxCDF 0 0 0 0 0 0.0000 13 0.0110
14 6-234678 HxCDF 0.766 0.639 0 0 0.35125 0.0085 14 0.0121
15 1-1234678 HpCDF 1.87 1.81 0 0 0.92 0.0223 15 0.0062
16 2-1234789 HpCDF 0 0 0 0 0 0.0000 16 0.0093
17 11-12346789 OCDF 2.56 1.65 0 0 1.0525 0.0255 17 0.0000
0.7894 Total Gr/Year 0.7894

2009 TEST DATA-All zero values were non-detects As reported in EPA TRI

AFPA Secondary Effluent 2009 pg/Liter Emissions Based on Annual testing (Re-arranged order) cogen # Date 1st Quarter 2nd Quarter 3rd Quarter 4th Quarter Average Grams/Year Effluent Flow gal/Yr
1 17-2378 TCDD 0 0 0 0 0 0.0000 1 0.0000
2 15-12378 PeCDD 0 0 0.0000 2 0.0000
3 7-123478 HxCDD 3.05 3.05 0.0717 3 0.0576
4 8-123678 HxCDD 5.07 5.07 0.1191 4 0.0698
5 9-123789 HxCDD 4.03 4.03 0.0947 5 0.0000
6 10-1234678 HpCDD 19.3 19.3 0.4535 6 0.0928
7 12-12346789 OCDD 38.4 38.4 0.9023 7 0.0717
8 16-2378 TCDF 0 0 0 4.76 1.19 0.0280 8 0.1191
9 13-12378 PeCDF 3.52 3.52 0.0827 9 0.094710 14-23478 PeCDF 7.01 7.01 0.1647 10 0.4535
11 3-123478 HxCDF 2.45 2.45 0.0576 11 0.1060
12 4-123678 HxCDF 2.97 2.97 0.0698 12 0.9023
13 5-123789 HxCDF 0 0 0.0000 13 0.0827
14 6-234678 HxCDF 3.95 3.95 0.0928 14 0.1647
15 1-1234678 HpCDF 0 0 0.0000 15 0.0000
16 2-1234789 HpCDF 0 0 0.0000 16 0.0280
17 11-12346789 OCDF 4.51 4.51 0.1060 17 0.0000
2.2428 Total Gr/Year 2.2428

2012 TEST DATA-All zero values were non-detects 4th Quarter test was only done on congeners 1 and 8

AFPA Secondary Effluent 2012 pg/Liter cogen # Date 1st Quarter 2nd Quarter 3rd Quarter 4th Quarter Average
1 17-2378 TCDD 0 0 0 0 0.00
2 15-12378 PeCDD 0 0 1.21 0.40
3 7-123478 HxCDD 0 0 0 0.00
4 8-123678 HxCDD 0 0 2.76 0.92
5 9-123789 HxCDD 0 0 0 0.00
6 10-1234678 HpCDD 12 14.7 15.4 14.03
7 12-12346789 OCDD 32.7 36.3 50.3 39.77
8 16-2378 TCDF 0 0 0 0 0.00
9 13-12378 PeCDF 0 0 1.06 0.35
10 14-23478 PeCDF 0 0 0 0.00
11 3-123478 HxCDF 0 0 1.25 0.42
12 4-123678 HxCDF 0 0 1.26 0.42
13 5-123789 HxCDF 0 0 0 0.00
14 6-234678 HxCDF 0 0 0 0.00
15 1-1234678 HpCDF 0 0 3.03 1.01
16 2-1234789 HpCDF 0 0 0 0.00
17 11-12346789 OCDF 0 0 3.02 1.01Rayonier Performance Fibers LLC Fernandina Beach, FL 32034TTRYNFOOTO

TRI Data Year Grams Released 2009 5.1966 Congener Number 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17

2011 7.3298 2009 (Submitted by Facility During 2011 Annual Review) 0 0 0 0 0.0167 0.471 3.468 0.2859 0 0.0076 0 0 0 0 0.0714 0 0.876 2011 0 0 0 0 0 0.4308 5.7761 0.3973 0 0 0 0 0 0 0.0806 0 0.645

Congener Number 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Sampling Data - Mean Values (Submitted by Facility During 2011 Annual Review) ND ND ND ND 0.8 23.9 176.2 14.5 ND 0.4 ND ND ND ND 3.6 ND 44.5 Method 1613 B Minimum Level 10 50 50 50 50 50 100 10 50 50 50 50 50 50 50 50 100

Facility Specific Questions: 1. Please confirm the 2011 dioxin distribution shown above. 2. Are there any updated sampling data for dioxin compounds (updated data sources, new sampling, etc.)? 3. Can you explain why congeners 5 and 10 were reported in the 2009 distribution and reported as "0" in the 2011 distribution? 4. If there are updated sampling data, please provide a copy of the results. Were any congeners detected above the Method 1613B Minimum Level in 2011 (see table above for minimum levels)? Total Water Release (g)

Effluent Sampling Data - Provided to EPA as Part of 2011 Annual Reviews (pg/L)