MEMORANDUM

TO: William Swietlik, U.S. EPA/EAD

FROM: Kimberly Landick, ERG

DATE: November 1, 2011

SUBJECT: AF&PA and NCASI Meeting Minutes for 1 November 2011

On 1 November 2011, EPA met with AF&PA and NCASI to discuss changes in the pulp 

and paper industry. Discussion topics included:

• Introductions;

• New (since April 2005) guidance from NCASI or other sources on how to estimate 

dioxin releases;

• Trends in dioxin generation

• Other wastewater trends

Attachment 1 lists the meeting participants.

Introductions

Paul Wiegand (NCASI) and Jerry Schwartz (AF&PA) introduced themselves. Mr. 

Wiegand and Mr. Schwartz agreed that the 2006 Pulp and Paper Detailed Study looks at 

2002/2003 data and that the conclusions reached in the study are still accurate (as of 2011). 

New Guidance from NCASI or Other Sources

Mr. Wiegand and Mr. Schwartz stated that there is no new guidance from AF&PA or 

NCASI (2005 is the most current) on how to estimate dioxin releases. 

Trends in Dioxin Generation

Mr. Wiegand and Mr. Schwartz were asked if the changes in TWPE in 2009 in the pulp 

and paper industry were from process changes or from a change in congener-specific profiles. 

They both confirmed that they did not know of any significant changes in the bleaching 

processes in the past few years besides possible reductions in chlorine dioxide use. 

Mr. Wiegand and Mr. Schwartz were additionally asked whether there have been any 

changes in the number of dioxin congeners measured in the pulp and paper industry. They 

confirmed that per the Cluster Rule, all facilities must measure for TCDF and TCDD. The lab 

costs are higher if a facility measures for all 17 dioxin congeners, so most only measure for 
TCDF and TCDD. However, some states require full congener testing from time to time but 

there is no standard. 

Other Wastewater Trends

Mr. Wiegand and Mr. Schwartz were asked if they knew of any decrease in water use at 

pulp and paper facilities. Both confirmed that mills are interested in decreasing water use, but 

there have been no significant water use changes. Mr. Schwartz stated that in 2010 AF&PA did a 

sustainability report (available online at: http://www.afandpa.org/pressreleases.aspx?id=1404) 

and found that the volume of water used has decreased by 20.5% since 1995. He added that in 

2008 the volume increased a little because of a huge drop in production due to the slow 

economy. Mr. Schwartz also stated that the data in the 2010 sustainability report are for the 

entire pulp industry. 

Mr. Wiegand and Mr. Schwartz stated that they would assist in collecting the remaining 

dioxin discharge data from pulp and paper facilities. 
Attachment 1

Table A-1. List of Meeting Participants

Name Affiliation Phone Email

Paul Wiegand NCASI 919-941-6417 pwiegand@NCASI.org

Jerry Schwartz AF&PA 202-463-2581 jerry_schwartz@afandpa.org

William Swietlik US EPA 202-566-1129 swietlik.william@epa.gov

Betsy Bicknell ERG 703-633-1612 betsy.bicknell@erg.com

Ellie Codding ERG 703-633-1673 eleanor.codding@erg.com

Elizabeth Sabol ERG 703-633-1659 elizabeth.sabol@erg.com

Kimberly Landick ERG 703-633-1119 kimberly.landick@erg.com
AF&PA and NCASI Email Correspondence Nov 2011 – Feb 2012

From: Kimberly Landick

To: Schwartz, Jerry; Wiegand, Paul

CC: Codding, Eleanor; Lewis, Samantha; Sabol, Elizabeth; Swietlik, William

Date: 2/22/2012 10:37 AM

Subject: Pulp and Paper Dioxin Data

Jerry and Paul:

Thank you for sending the follow up information for International Paper's Riegelwood, NC mill and the 

SAPPI mill. We will let you know if we have any further questions. 

Thank you,

Kimberly

----------------------------------------

Kimberly D. Landick

Environmental Engineer

Eastern Research Group, Inc. 

14555 Avion Parkway, Suite 200

Chantilly, VA 20151

kimberly.landick@erg.com

Phone: 703-633-1119

From: Swietlik, William 

To: Schwartz, Jerry 

CC: Landick, Kimberly; Codding, Eleanor; Lewis, Samantha; Sabol, Elizabeth; Wiegand, Paul

Date: 2/21/2012 6:02 PM

Subject: Re: FW: EPA ELG request for DDLC data from Sappi Skowhegan

Thanks again Jerry.

_______________________

Bill Swietlik

Engineering and Analysis Division (4303-T)

Office of Water/Office of Science and Technology

U. S. EPA

1200 Pennsylvania Ave., N.W.

Washington, DC, 20460

202-566-1129: Desk

202-566-1053: FAX

From: Schwartz, Jerry

To: Landick, Kimberly; Codding, Eleanor; Lewis, Samantha; Sabol, Elizabeth; Swietlik, William

CC: Wiegand, Paul

Date: 2/20/2012 10:44 AM

Subject: FW: EPA ELG request for DDLC data from Sappi Skowhegan

All: Here is some information on the SAPPI mill in response to your request. Sorry for the delay 

in getting this to you. Jerry 
From: Griffin, Thomas [mailto:Thomas.Griffin@sappi.com] 

Sent: Wednesday, February 01, 2012 4:17 PM

To: Schwartz, Jerry

Cc: Hibbard, Kimberly

Subject: EPA ELG request for DDLC data from Sappi Skowhegan. 

Jerry,

Following up on your 1/30/12 e-mail concerning the EPA ELG request for DDLC data from the Somerset 

mill, attached is the TRI Dioxin Congener Distributions data sheet with our 2007 data entered into it. 

Both the 2007 and 2009 distributions were based on the a 2002 analysis of the mill’s final effluent. 2002 

was the last year a full conger scan was conducted on our effluent. I have also attached this data sheet 

so that EPA can see the conger distribution. As noted before, we do make corrections to the naturally 

occurring congers ( i.e. OCDD, HpCDD and OCDF ) contained in the mill’s receiving water, pulp wood and 

kaolin clay. Please call if you have any questions. 

From: Wiegand, Paul

To: Landick, Kimberly

CC: Codding, Eleanor; Lewis, Samantha; Sabol, Elizabeth; Swietlik, William; Schwartz, Jerry

Date: 2/13/2012 12:10 PM

Subject: RE: Pulp and Paper Dioxin Data

Ms. Landick,

I have received a response to your question of International Paper’s Riegelwood, NC mill. The attached 

spreadsheet describes the data used for 2007 and 2009 TRI reporting and the following explanation 

summarizes the reasoning behind TRI reports for those two years. 

For most years of reporting, DDLC releases to water have been based on data from 

measurements made in bleach plant effluents in 2000 for which three congeners were reported. 

2007 was an exception because for that year an actual effluent measurement was used that 

showed non-detect for one congener and thus only two congeners were reported. The mill used 

the earlier convention for purposes of reporting for 2009. 

You should have received a separate response for the Maine mill courtesy of Jerry Schwartz. If you have 

questions, please let me know. 

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: Kimberly Landick

To: Wiegand, Paul

Date: 1/25/2012 12:44 PM

Subject: Follow up on Pulp and Paper Dioxin Data

Hi Paul,

Thank you for giving me a call this morning. I wanted to confirm that for both facilities, we are looking for 

the grams reported for each congener for water in 2007 like we discussed on the phone, but we are also 

wanting to know why the water distributions are different between 2007 and 2009. For example, is the 

difference due to reporting air releases in 2007 and then water releases in 2009 or in how the data was 

processed or for some other reason? 

Please let me know if you have any further questions. 

Thank you!

Kimberly

----------------------------------------

Kimberly D. Landick

Environmental Engineer

Eastern Research Group, Inc. 

14555 Avion Parkway, Suite 200

Chantilly, VA 20151

kimberly.landick@erg.com

Phone: 703-633-1119

From: Wiegand, Paul

To: Landick, Kimberly; Schwartz, Jerry

CC: Codding, Eleanor; Lewis, Samantha; Sabol, Elizabeth; Swietlik, William

Date: 1/17/2012 5:14 PM

Subject: RE: Pulp and Paper Dioxin Data

Kimberly,

My apologies for not replying sooner. I understand the questions you have and will attempt to derive 

more information from the two facilities in question. I will let you know what we find out.

Paul

From: Kimberly Landick

To: Schwartz, Jerry; Wiegand, Paul

CC: Codding, Eleanor; Lewis, Samantha; Sabol, Elizabeth; Swietlik, William

Date: 1/13/2012 12:33 PM

Subject: Pulp and Paper Dioxin Data
Jerry and Paul,

Thank you for the additional plant data (received 12/02/2011). We've incorporated those data into our 

analysis and only have questions on two plants' dioxin data (highlighted in green in the attached Excel 

sheet). These two plant's reported discharges, even with additional data, remain elevated compared to 

earlier years, in terms of estimated TWPE. 

Please see the attached spreadsheet for details on how all of the estimated TWPE is being derived. Please 

note that we are aware that the Proctor and Gamble Paper Products, Co. is not an AF&PA or NCASI 

member; however, they are included in the attachment for our records.

Just to recap from our November 2011 discussion, we continue to resolve why, in the 2009 TRI, some 

facilities reported either greater mass of dioxin released and/or more toxic mix of congeners, such as 

greater percentage of TCDD/TCDF. So far, we have found that no facility has measured greater 

concentrations of dioxin in their effluent wastewater, but that facilities have altered how they are 

estimating or reporting their discharges.

The attached spreadsheet lists reported dioxin data for the 19 plants we've investigated. We are focusing 

on resolving facilities with large increases between their 2007 and 2009 reported releases of dioxin (see 

the column labeled "% increase in TWF (2007 to 2009)"). We compare 2007 and 2009 data because of 

data storage problems with the 2008 data.

Please feel free to call (703-633-1119) or email if you need clarification or would like to discuss our 

questions.

Thank you,

Kimberly

----------------------------------------

Kimberly D. Landick

Environmental Engineer

Eastern Research Group, Inc. 

14555 Avion Parkway, Suite 200

Chantilly, VA 20151

kimberly.landick@erg.com

Phone: 703-633-1119

From: Wiegand, Paul

To: Sabol, Elizabeth; Swietlik, William

CC: Schwartz, Jerry 

Date: 12/2/2011 8:37 AM

Subject: Clarifying data – Pulp and Paper TRI for DDLC

Bill and Elizabeth,

The attached file provides the responses from five of the six facilities for which you requested clarifying 

data supporting 2009 TRI reports for dioxin and dioxin-like compounds. The Kimberly Clark mill in 

Everett, Washington has not yet responded. Please let me know if this information requires any additional 

clarification.
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

To: Wiegand, Paul; Swietlik, William

CC: Bicknell, Betsy; Codding, Eleanor; Landick, Kimberly; Sabol, Elizabeth

Date: 11/2/2011 5:21 PM

Subject: RE: Clarifying data needed

Thanks, Bill, the dates help as well. Jerry

From: Wiegand, Paul

To: Schwartz, Jerry; Swietlik, William

CC: Bicknell, Betsy; Codding, Eleanor; Landick, Kimberly; Sabol, Elizabeth

Date: 11/2/2011 4:58 PM

Subject: RE: Clarifying data needed

Thank you Bill. We'll begin contacting the mills ASAP.

From: Swietlik, Bill

To: Schwartz, Jerry; Wiegand, Paul

CC: Bicknell, Betsy; Codding, Eleanor; Landick, Kimberly; Sabol, Elizabeth

Date: 11/2/2011 4:19 PM

Subject: RE: Clarifying data needed

Jerry/Paul:

Thank you for your time on the phone on Tuesday. I think the discussion was very useful.

The additional information we need for the remaining six facilities is described in the attached Excel table 

below.

Additionally, here are some key dates and milestones to help clarify our timeline:

October 26, 2011: 2010 Final Effluent Guidelines Program Plan published (reviewed 2008 discharge data in 

TRI and DMR).

November 25, 2011: Close of thirty day public comment period for 2010 Final Effluent Guidelines Program 

Plan.
January 2012: Likely publication of 2012 Preliminary Effluent Guidelines Program Plan (reviewed 2009 

discharge data in TRI and DMR), public comment period to follow publication. Typically 30 days.

December 2012: Likely publication of 2012 Final Effluent Guidelines Program Plan, public comment period 

to follow publication.

The information we are currently gathering is 2009 discharge data that will be used in the Final 2012 

Effluent Guidelines Program Plan.

Thank you.

Please call me if you have additional questions.

_______________________

Bill Swietlik

Engineering and Analysis Division (4303-T)

Office of Water/Office of Science and Technology

U. S. EPA

1200 Pennsylvania Ave., N.W.

Washington, DC, 20460

202-566-1129: Desk

202-566-1053: FAX

From: Kimberly Landick

To: Swietlik, William

CC: Codding, Eleanor; Sabol, Elizabeth

Date: 11/1/2011 3:02 PM

Subject: Request for Additional Pulp and Paper Facility Data

Bill, 

As discussed on our earlier call, ERG is requesting the attached additional information from 6 pulp and 

paper facilities. I've drafted an email below containing background information to help clarify the timeline. 

Could you please CC Ellie, Liz, and myself on the email? Please let me know if you have any further 

questions. 

Thanks,

Kim

-----------------------

We would like to request information for the attached list of six facilities.

Additionally, we've included some language below to help clarify the timeline. 

October 26, 2011: 2010 Final Effluent Guidelines Program Plan published (reviewed 2008 discharge data in 

TRI and DMR)

November 25, 2011: Close of thirty day public comment period for 2010 Final Effluent Guidelines Program 

Plan

January 2012: Likely publication of 2012 Preliminary Effluent Guidelines Program Plan (reviewed 2009 

discharge data in TRI and DMR), public comment period to follow publication. 
September 2012: Likely publication of 2012 Final Effluent Guidelines Program Plan, public comment 

period to follow publication.

The information we are currently gathering is 2009 discharge data that will be used in the Final 2012 

Effluent Guidelines Program Plan. 

----------------------------------------

Kimberly D. Landick

Environmental Engineer

Eastern Research Group, Inc. 

14555 Avion Parkway, Suite 200

Chantilly, VA 20151

kimberly.landick@erg.com

Phone: 703-633-1119
ncasi

NATIONAL COUNCIL FOR AIR AND STREAM IMPROVEMENT, INC.

P.O. Box 13318, Research Triangle Park, NC 27709-3318

4815 Emperor Boulevard, Suite 110, Durham, NC 27703

Phone (919) 941-6417 Fax (919) 941-6401

Paul Wiegand

Vice President, Water Quality

pwiegand@ncasi.org

December 2, 2011

TO: Elizabeth Sabol, ERG

FROM: Paul Wiegand, NCASI

SUBJECT: Second Round Responses on EPA Inquiry Concerning 2009 TRI Reports for

Dioxin and Dioxin-Like Compounds from Select Pulp and Paper Mills

This memo and attached material serve to following up our early November discussion in which

EPA requested additional information about dioxin and furan test data used by six mills to

support 2009 TRI Reports for Dioxin and Dioxin-Like Compounds. Pursuant to that request,

NCASI contacted all six mills. To date, the following five have responded and those responses

are compiled here.

 Clearwater, Arkansas Mill, at McGehee, Arkansas

 Clearwater, Lewiston, Idaho

 International Paper, Riegelwood, North Carolina

 Nippon Paper, Port Angeles, Washington

 Rayonier, Fernandina, Florida

If you have questions about any of the responses, we’d be happy to pass those along to the

facilities and/or coordinate other communication as appropriate.

ec: Jerry Schwartz, AF&PA

Arun Someshwar, NCASI
Elizabeth Sabol, ERG

December 2, 2011

Page 2

Clearwater, Arkansas Mill, at McGehee, Arkansas

SECOND ROUND QUESTION:

Provide the effluent sampling and flow data for TCDD and TCDF used to calculate the 2009 TRI

dioxin discharges.

Response:

The following final effluent sampling for 2009 were as follows:

Date TCDD TCDF

2-25-09 ND@0.557 ppq ND@0.735 ppq

7-22-09 ND@0.829 ppq ND@0.594 ppq

Flow data was based on the annual average daily effluent flow of 15.02 million gallons / day.

An error in the excel spreadsheet is the logical explanation for the amount of dioxin / furan

shown in the 2009 TRI discharges. When this error is corrected the wastewater discharges for

total dioxin compounds the amount changes from 0.45589 grams/ year to 0.4351 grams/year.

Clearwater, Lewiston, Idaho

SECOND ROUND QUESTION:

Provide the 2009 effluent sampling and flow data used to calculate the 2009 TRI dioxin

discharges.

Response:

For the 2009 TRI reporting of DDLCs, the mill used data generated from an experimental

sampling methodology known as “high volume sampling” or “high volume extraction.” The

procedure involves the separate collection of solid and dissolved fractions of up to 1000 L of

effluent. The procedure was used as part of a special NPDES permit condition for eight

quarterly sampling episodes between 2005 and 2007. Calculation procedures used convert such

data to effluent loading estimates for purposes of congener specific TRI reporting are necessarily

complicated and, unfortunately, we have been unable to resurrect the raw data needed to

reproduce the 2009 TRI report for DDLCs. This is due, in part, to personnel changes resulting

from a change in ownership between the time these estimates were made and the present. As
Elizabeth Sabol, ERG

December 2, 2011

Page 3

would be expected, collection of sample volumes up to 1000 times larger than is typically

required for dioxin analyses (typical sample volume is 1 L) acts to greatly lower analytical

detection limits which may explain the difference between the 2009 TRI report and earlier

reports made by the mill. If EPA is interested in reviewing the data that derived from the high

volume sampling study, the information should be obtainable through the EPA Region 10 office

which is the NPDES permitting authority for the Lewiston mill.

International Paper, Riegelwood, North Carolina

SECOND ROUND QUESTION:

Provide the 2000 final effluent sampling and flow data used to calculate the 2009 TRI dioxin

discharges. Have there been any changes (since 2006) in the method of estimating releases? If

so, when was the change in estimation procedures and why?

Response:

The original 2000 dioxin test data is not available. The records were discarded as required by our

records retention policy. The average daily 2009 effluent flow was 32.2 million gallons per day.

To my knowledge there have been no changes since 2006 in the method of estimating releases.

Nippon, Port Angeles, Washington

SECOND ROUND QUESTION:

Provide the 2006 final effluent sampling and flow data used to calculate the 2009 TRI dioxin

discharges.

Response:

An image from an Excel spreadsheet showing the calculations is provided below. Attached to

the end of this memo is the actual laboratory analytical report for the sample used in the 2009

TRI calculations.
Elizabeth Sabol, ERG

December 2, 2011

Page 4

TRI Facility ID Number: 98362DSHWMMARIN

Nippon Paper Industries USA Co., Ltd

1902 Marine Drive

Port Angeles, WA 98362

Paul Perlwitz, Env. Mgr. 360-565-7045

TRI EFFLUENT DIOXIN DATE FOR 2009 REPORTING YEAR - table taken out of original TRI dioxin calculations

Sample result 4-5-2006 by CAS, 0600241 √ same as 2008 congener data

Dioxin/Furan Congener analysis to use for WWTP Effluent gallons

DL ppq 1/2 the DL 3,173,139,000 Total gallons discharged as effluent in 2009.

2,3,7,8-TCDD 1 0.290 0.145 0.00174212

1,2,3,7,8-PeCDD 2 0.292 0.146 0.00175414

1,2,3,4,7,8-HxCDD 3 0.282 0.141 0.00169407

1,2,3,6,7,8-HxCDD 4 0.309 0.1545 0.00185626

1,2,3,7,8,9-HxCDD 5 0.291 0.1455 0.00174813

1,2,3,4,6,7,8-HpCDD 6 0.341 0.1705 0.00204850

OCDD 7 0.688 0.344 0.00413304

2,3,7,8-TCDF 8 0.548 0.274 0.00329201

1,2,3,7,8-PeCDF 9 0.273 0.1365 0.00164000

2,3,4,7,8-PeCDF 10 0.273 0.1365 0.00164000

1,2,3,4,7,8-HxCDF 11 0.236 0.118 0.00141773

1,2,3,6,7,8-HxCDF 12 0.259 0.1295 0.00155590

1,2,3,7,8,9-HxCDF 13 0.272 0.136 0.00163399

2,3,4,6,7,8-HxCDF 14 0.303 0.1515 0.00182022

1,2,3,4,6,7,8-HpCDF 15 0.266 0.133 0.00159795

1,2,3,4,7,8,9-HpCDF 16 0.314 0.157 0.00188630

OCDF 17 0.584 0.292 0.00350828

grams

0.0349686

Effluent Analytical Test Results for Dioxin Congeners - see attached PDF copy of report

SECONDARY EFFLUENT TESTING

SAMPLED 4-5-06 Testing by Columbia Analytical Services LAB ID No. E0600241-001

Sample Data Filename: U14993#1

TEQ (Min-Max)1

0.00 - 0.85

Conc.

Compound ppq DL MDL

2,3,7,8-TCDD ND 0.290 1.01

1,2,3,7,8-PeCDDND 0.292 0.96

1,2,3,4,7,8-HxCDDND 0.282 1.06

1,2,3,6,7,8-HxCDDND 0.309 0.93

1,2,3,7,8,9-HxCDDND 0.291 1.01

1,2,3,4,6,7,8-HpCDDND 0.341 0.9

OCDD ND 0.688 0.98

2,3,7,8-TCDF ND 0.548 0.96

1,2,3,7,8-PeCDF ND 0.273 0.93

2,3,4,7,8-PeCDF ND 0.273 0.99

1,2,3,4,7,8-HxCDFND 0.236 1.17

1,2,3,6,7,8-HxCDFND 0.259 1.15

2,3,4,6,7,8-HxCDFND 0.303 1.19

1,2,3,7,8,9-HxCDFND 0.272 1.08

1,2,3,4,6,7,8-HpCDF ND 0.266 1.35

1,2,3,4,7,8,9-HpCDF ND 0.314 1.33

OCDF ND 0.584 1.03

Sum = 0.0

1

 Min is calculated assuming ND as zero (0). Max value is calculated assuming ND is DL.

6/29/2007 PFP Verified the actual CAS report from 4-5-06. It was non-detect for all dioxin parameters.

5/21/2010 PFP verified the correctness of this outfall data used in the 2008 TRI report

Congener #

2009 TRI report for Nippon Paper reported a value

of 0.0349685 in 5.3.1. A for Strait of Jaun de Fuca

effluent discharges.

The dioxin data from the 2006 Columbia

Analytical Services test report was all ND. For the

2008 and 2009 TRI reports a value of 1/2 the DL

was used to report dioxin congeners.
Elizabeth Sabol, ERG

December 2, 2011

Page 5

Rayonier, Fernandina Beach, Florida

SECOND ROUND QUESTION:

Provide the 2009 quarterly measurements and flow data used to calculate the 2009 TRI dioxin

discharges.

Response:

See the table on the following page. We averaged the quarterly measurements and multiplied

this average by our annual discharge flow.
Rayonier - Fernandina Mill

Outfall Eff 001Discharge to the Amelia River pg/L

7-Jan-09 16-Apr-09 9-Jul-09 15-Oct-09 

NDL Value NDL Value NDL Value NDL V

67562-39-4 1,2,3,4,6,7,8-Heptachlorodibenzofuran 1,2,3,4,6,7,8 HpCDF 0.2 1.3 < 0.4 0.0 1.1 3.0 1.4 

55673-89-7 1,2,3,4,7,8,9-Heptachlorodibenzofuran 1,2,3,4,7,8,9 HpCDF < 0.2 0.0 < 0.4 0.0 < 1.2 0.0 < 1.3 70648-26-9 1,2,3,4,7,8-Hexachlorodibenzofuran 1,2,3,4,7,8 HxCDF < 0.1 0.0 < 0.6 0.0 < 1.0 0.0 < 0.9 57117-44-9 1,2,3,6,7,8-Hexachlorodibenzofuran 1,2,3,6,7,8 HxCDF < 0.1 0.0 < 0.6 0.0 < 1.0 0.0 < 0.8 72918-21-9 1,2,3,7,8,9-Hexachlorodibenzofuran 1,2,3,7,8,9 HxCDF < 0.2 0.0 < 0.7 0.0 < 1.4 0.0 < 1.7 60851-34-5 2,3,4,6,7,8-Hexachlorodibenzofuran 2,3,4,6,7,8 HxCDF < 0.1 0.0 < 0.7 0.0 < 1.1 0.0 < 0.9 39227-28-6 1,2,3,4,7,8-Hexachlorodibenzo- p-dioxin 1,2,3,4,7,8 HxCDD < 0.2 0.0 < 0.6 0.0 < 1.9 0.0 < 0.6 57653-85-7 1,2,3,6,7,8-Hexachlorodibenzo- p-dioxin 1,2,3,6,7,8 HxCDD < 0.3 0.0 < 0.6 0.0 < 2.3 0.0 < 0.8 19408-74-3 1,2,3,7,8,9-Hexachlorodibenzo- p-dioxin 1,2,3,7,8,9 HxCDD < 0.2 0.0 < 0.6 0.0 < 1.9 0.0 0.7 35822-46-9 1,2,3,4,6,7,8-Heptachlorodibenzo- p-dioxin 1,2,3,4,6,7,8 HpCDD 0.2 2.7 0.4 5.3 1.4 5.4 1.0 

39001-02-0 1,2,3,4,6,7,8,9-Octachlorodibenzofuran 1,2,3,4,5,6,7,8,9 OCDF 0.3 1.3 0.5 3.7 1.8 7.0 1.4 03268-87-9 1,2,3,4,6,7,8,9-Octachlorodibenzo- p-dioxin 1,2,3,4,5,6,7,8,9 OCDD 0.3 11.6 0.6 31.8 1.6 29.2 1.8 

57117-41-6 1,2,3,7,8-Pentachlorodibenzofuran 1,2,3,7,8 PeCDF < 0.2 0.0 < 1.4 0.0 < 1.4 0.0 < 0.9 57117-31-4 2,3,4,7,8-Pentachlorodibenzofuran 2,3,4,7,8 PeCDF < 0.2 0.0 < 1.4 0.0 1.3 1.6 < 0.9 40321-76-4 1,2,3,7,8-Pentachlorodibenzo- p-dioxin 1,2,3,7,8 PeCDD < 0.3 0.0 < 1.2 0.0 < 3.7 0.0 < 1.3 51207-31-9 2,3,7,8-Tetrachlorodibenzofuran 2,3,7,8 TCDF 0.3 15.9 2.1 7.9 1.3 24.5 1.2 

01746-01-6 2,3,7,8-Tetrachlorodibenzo- p-dioxin 2,3,7,8 TCDD < 0.2 0.0 < 0.6 0.0 < 1.5 0.0 < 1.1 

3.9 32.8 13.3 48.7 26.8 70.7 18.6 

19,688 Million Liter/yr 5.1966 g/yr total CDD/Fs 
7 / 

~ .... c. 

10655 Richmond Avenue Suite 130A Houston, Texas 77042 (713) 266·1599 ph (713) 266-0130 fax A~~~~:~aJ Services INC. 

April 24, 2006 

Ann Schlegel 

Nippon Paper fudustries Co., Ltd. 

'P.O. Box 271 

Port Angeles, WA 98362 

RE: 1613B_fuIIlNPDES Permit Application 

Dear Ann: 

An Employee· Owned Company 

Service Request No: E0600241 

Enclosed are the results of the sample(s) submitted to our laboratory on April 6,2006. For your 

reference, these analyses have been assigned our service request number E0600241. 

All analyses were performed according to our laboratory's quality assurance program. The test 

results meet requirements of the NELAP standards except as noted in the case narrative report. 

All results are intended to be considered in their entirety, and Columbia Analytical Services, Inc. 

(CAS) is not responsible for use ofless than the complete report. Results apply only to the items 

submitted to the laboratory for analysis and individual items (samples) analyzed, as listed in the 

report. 

Please call if you have any questions. My extension is 23. You may also contact me via email at 

lFreemyer@houston.caslab.com. 

Respectfully submitted, 

Columbia Analytical Services, Inc. 

J 

~~ 

ane Free~yer r:J 

Project Chemist 

Page 1 of tJdJ 

• C • 

NELAP Accredited ACIL Seal of Excellence Award 
./ 

Columbia 

Analytical 

Services INC. 

An Employee - Owned Company 

Dioxin/Furan 

Analytical Report 

10655 Richmond Avenue, Suite 130-A, Houston, TX 77042 

Phone (713)266-1599 Fax (713)266-0130 

www.caslab.com 

2 
Client: 

Project: 

Sample Matrix: 

COLUMBIA ANALYTICAL SERVICES, INC 

Nippon Paper Industries Co., Ltd. 

NPDES Pennit Application 

Aqueous 

CASE NARRATIVE 

Service Request No.: 

Date Received: 

E0600241 

04/06/06 

All analyses were performed in adherence to the quality assurance program of Columbia Analytical Services, Inc. 

(CAS). Tbis report contains analytical results for samples designated for Tier II. When appropriate to the method, 

method blank results have been reported with each analytical test. 

Sample Receipt 

One aqueous sample was received for analysis at Columbia Analytical Services on 04/06/06. 

The sample was received at 6°C in good condition and is consistent with the accompanying chain" of custody form. 

The sample was stored in a refrigerator at 4°C upon receipt at the laboratory. 

Data Validation Notes and Discussion 

MS/MSD 

EB25032: Laboratory Control SamplelLaboratory Control Sample Duplicate (LCS/LCSD) samples were analyzed 

and reported in lieu of an MSIMSD for tbis extraction batch. 

Detection Limits 

Detection limits are calculated for each congener in each sample by measuring the height of the noise level for each 

quantitation ion for the associated labeled standard. The concentration equivalent to 2.5 times the height of the 

noise is then calculated using the appropriate response factor and the weight of the sample. The calculated 

concentration equals the detection limit. 

The Form 3 results for each sample have been calculated by CASlHouston to include: 

~ WHO-98 TEFs 

~ Non-detected compounds reported as ND = '0' (zero) 

3 
Client: 

Project: 1613BjulllNPDES Pennit Application 

SAMPLE # 

E0600241-00 1 

Printed 04/24/2006 14:28 

SAMPLE CROSS-REFERENCE 

CLIENT SAMPLE ID 

Outfall 001 

Sample gbmmary 

Service Request: E0600241 

DATE 

04/05106 

TIME 

08:05 

Page 1 ofl 
U1 

CONGENER 

2,3,7,S-Tetrachlorodibenzo-p-dioxin 

1,2,3,7 ,S-Pen tachlorodibenzo-p-dioxins 

1,2,3,4,7,S-Hexachlorodibenzo-p-dioxin 

1,2,3,6,7 ,S-Hexachlorodibenzo-p-dioxin 

1,2,3,7 ,S,9-Hexachlorodibenzo-p-dioxin 

1,2,3,4,6,7,S-Heptachlorodibenzo-p-dioxin 

Octaclllorodibenzo-p-dioxin 

2,3,7,8-Tetrachlorodibenzofuran 

1,2,3,7,S-Pentaclllorodibenzofuran 

2,3,4,7,S-Pentachlorodibenzofuran 

1,2,3,6,7 ,S-Hexachlorodibenzofuran 

1,2,3,7 ,S,9-Hexachlorodibenzofuran 

1,2,3,4,7,8-Hexachlorodibenzofuran 

2,3,4,6,7,8-Hexachlorodibenzofuran 

1,2,3,4,6,7,8-Heptachlorodibenzofuran 

1,2,3,4,7,8,9-Heptaclllorodibenzofuran 

Octachlorodibenzofuran 

Total Tetra-Dioxins 

Total Penta-Dioxins 

Total Hexa-Dioxins 

Total Hepta-Dioxins 

Total Tetra-Furans 

Total Penta-Furans 

Total Hexa-Furans 

Total Hepta-Furans ----

Method 1613B /Dioxins & Furans 

Reporting Limits 

CONGENER 

ABBREVIATION CASRN 

237S-TCDD 1746-01-6 

1237S-PeCDD 40321-76-4 

12347S-HxCDD 39227-2S-6 

12367S-HxCDD 57653-S5-7 

1237S9-HxCDD 1940S-74-3 

123467S-HpCDD 35S22-46-9 

OCDD 326S-S7-9 

2378-TCDF 51207-31-9 

12378-PeCDF 57117-41-6 

2347S-PeCDF 57117-31-4 

12347S-HxCDF 7064S-26-9 

123678-HxCDF 57117-44-9 

123789-HxCDF 72918-21-9 

23467S-HxCDF 60851-34-5 

1234678-HpCDF 67562-39-4 

12347S9-HpCDF 55673-S9-7 

OCDF 39001-02-0 

* * 

* * 

* * 

* * 

* * 

* * 

* * 

* * 

REpORTING LIMITS REpORTING LIMITS 

Aqueous Solids 

PG/L NG/KG 

10 1.0 

50 5.0 

50 5.0 

50 5.0 

50 5.0 

50 5.0 

100 10 

10 1.0 

50 5.0 

50 5.0 

50 5.0 

50 5.0 

50 5.0 

50 5.0 

50 5.0 

50 5.0 

100 10 

10 1.0 

50 5.0 

50 5.0 

50 5.0 

10 1.0 

50 5.0 

50 5.0 

50 5.0 

NOTE: Tissue samples are reported on a wet-weight basis and soil/sediment samples are reported on a dry-weight basis. 
. :. x 

Data Qualifier Flags 

Used when an associated analyte is found in the method blank, as well as in 

the sample 

Confirmation ofthe TCDF compound: When 2378-TCDF is detected on the 

DB-5 column, confirmation analyses are performed on a second column (DB225.) The results from both the DB-5 column and the DB-225 column are 

included in this data package. The results from the DB-225 analyses should 

be used to evaluate the 2378-TCDF in the samples. The confirmed result 

should be used in determining the TEQ value for TCDF. The samples 

requiring confirmation are indicated in the table above. 

Indicates an estimated value - used when the analyte concentration exceeds 

the upper end of the linear calibration range 

Indicates an estimated value - used when the analyte concentration is below 

the method reporting limit (MRL) and above the detection limit (DL) 

EMPC - When the ion abundance ratios associated with a particular 

compound are outside the QC limits, samples are flagged with a 'K' flag. A 

'K' flag indicates an estimated maximum possible concentration for the 

associated compound. 

Indicates the compound was analyzed and not detected . 

User defined; see case narrative for detailed explanation 

Samples that had recoveries of labeled standards outside the acceptance limits 

are flagged with 'Y' flags on the Form 2s. In all cases, the signal-to-noise 

ratios are greater than 10:1, making these data acceptable. 

Indicates concentration is reported as 'Not Detected' 

Peak is saturated; data not reportable 

6 
CAS/HOD - Form Production, Peer Review & Project Review Signatures 'i~-:tt ';'0.'Z'';'~'%o.~:;;.:J.Q-,~·~ .. :~;~'i~'!;.1~w~;mw,';~J';~~~~,TI:~''iJ.~;';''~~~'''::-'!%:;~~'%£:.i<ft~~'f"{l~w:%'..zt,..'<t~~-:,~tf£i:l·i:<1:t:.'$i;"'~JiJ.~,,,,~~;:;''!t:.:~Ji"i1,':?&~W''i--=<~,.i;~mr'~:J~~~J'.:?;~:.m.:~~~~',t,smRem~1':-d'~·:.;:"w""";.,.'%Z.:mmYi::m~;~'ii .~; 

SR# Unique IDI L 060 () 2'i/-()41 

i First Level - Data Processing - to be filled by person generating the forms 

Date Person 1 

Date Person 2 

.' Project Level- Review- to be filled by person doin pro"ect compliance review 

Date Reviewer 

7 

DATA REV_SIG1 (1/13/2006) 
Page 2 of 11 

Form 1 

CLIENT ID. 

PCDD/PCDF ANALYSIS DATA SHEET 

Use for Sample and Blank Results METHOD BLANK 

Lab Name: Columbia Analytical Services Contract: SDG No: 

Lab Code: CAS Method:1613 Case No: Client No: Lab ID: EB25032-MB 

Client Name: Sample Wt/Vol: 1000 g or mL: mL 

Matrix (Solid/Aqueous/Waste/Ash): Aqueous Initial Calibration Date: 01/10/06 

Sample Receipt Date: Instrument ID: AutoSpec-Ultima 

Ext. Date: 04/11/06 GC Column:DB-5 

Ext. Vol (ul) :20.0 Inj. Vol (ul) : 1 . 0 Sample Data Filename: U14998#1 

Analysis Date: 14-APR-06 Time: 19:36:00 Blank Data Filename: U14998#1 

Dilution Factor: 1 Cal. Ver. Data Filename: U14996#1 

Concentration Units (pg/L or ng/Kg dry weight): pg/L % Solids/Lipids: 

CONCENTRATION DETECTION Qual. ION ABUND. 

ANALYTE FOUND LIMIT (1) RATIO (2) 

2,3,7,8-TCDD 

1,2,3,7,8-PeCDD 

1,2,3,4,7,8-HxCDD 

1,2,3,6,7,8-HxCDD 

1,2,3,7,8,9-HxCDD 

1,2,3,4,6,7,8-HpCDD 

OCDD 

2,3,7,8-TCDF 

1,2,3,7,8-PeCDF 

"2 , 3 , 4 , 7 , 8 - PeCDF 

1,2,3,4,7,8-HxCDF 

1,2,3,6,7,8-HxCDF 

1,2,3,7,8,9-HxCDF 

2,3,4,6,7,8-HxCDF 

1,2,3,4,6,7,8-HpCDF 

1,2,3,4,7,8,9-HpCDF 

OCDF 

Total Tetra-Dioxins 

Total Penta-Dioxins 

Total Hexa-Dioxins 

Total Hepta-Dioxins 

Total Tetra-Furans 

Total Penta-Furans 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

0.292 

0.438 

0.453 

0.496 

0.466 

0.261 

0.738 

0.316 

0.321 

0.315 

0.259 

0.282 

0.351 

0.292 

0.324 

0.408 

0.991 

0.292 

0.438 

0.453 

0.261 

0.316 

0.315 

U 

U 

U 

U 

U 

U 

U 

U 

U 

U 

U 

U 

U 

U 

U 

U 

U 

U 

U 

U 

U 

U 

U 

Total Hexa-Furans * 0.259 U 

Total Hepta-Furans * 0.324 U 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

RRT 

(2) 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

MEAN 

RRF 

1. 01 

0.96 

1. 06 

0.93 

1. 01 

0.90 

0.98 

0.96 

0.93 

0.99 

1.17 

1.15 

1.19 

1. 08 

1. 35 

1. 33 

1. 03 

(1) Qualifier U indicates not detected; The K indicates EMPC. The C needs value 

from second column analysis. The B indicates possible blank contamination. 

(2) RRTs and ion ratios are specified in Tables 2 and 9, Method 1613. 

8 
USEPA, EAD 

FORM 2: PCDD/PCDF LABELED COMPOUND AND 

CLEANUP STANDARD RECOVERIES 

Lab Name: Columbia Analytical Services Contract: 

CLIENT ID. 

METHOD BLANK 

SDG No: 

Lab Code: CAS Method:1613 Case No: Client No: Lab ID:EB25032-MB 

Client Name: Sample Wt/Vol: 1000 9 or mL: mL 

Matrix (Solid/Aqueous/Waste/Ash): Aqueous Initial Calibration Date: 01/10/06 

Sample Receipt Date: Instrument ID: AutoSpec-Ultima 

Ext. Date: 04/11/06 GC Column ID: DB-5 

Analysis Date: 14-APR-06 Time: 19:36:00 Sample Data Filename: U14998#1 

Ext. Vol (ul) : 20. 0 Inj . Vol (ul) : 1 . 0 Blank Data Filename: U14998#1 

Dilution Factor: 1 Cal. Ver. Data Filename: U14996#1 

Concentration Units (pg/L or ng/Kg dry weight): pg/L 

LABELED COMPOUNDS 

13C-2,3,7,8-TCDD 

13C-1,2,3,7,8-PeCDD 

13C-1,2,3,4,7,8-HxCDD 

13C-1,2,3,6,7,8-HxCDD 

13C-1,2,3,4,6,7,8-HpCDD 

13C-OCDD 

13C-2,3,7,8-TCDF 

13C-1,2,3,7,8-PeCDF 

13C-2,3,4,7,8-PeCDF 

13C-1,2,3,4,7,8-HxCD~ 

13C-1,2,3,6,7,8-HxCDF 

13C-1,2,3,7,8,9-HxCDF 

13C-2,3;4,6,7,8-HxCDF 

13C-1,2,3,4,6,7,8-HpCDF 

13C-1,2,3,4,7,8,9-HpCDF 

CLEANUP STANDARD 

37Cl-2,3,7,8-TCDD 

SPIKE CONC. 

CONC. FOUND 

2000 1315.60 

2000 1275.77 

2000 1435.64 

2000 1267.12 

2000 1176.54 

4000 1904.86 

2000 1264.67 

2000 1288.56 

2000 1294.63 

2000 1411.10 

2000 1279.18 

2000 1511.23 

2000 1374.69 

2000 1141.05 

2000 1372.10 

800 666.63 

R(%) 

(1) 

65.78 

63.79 

71.78 

63.36 

58.83 

47.62 

63.23 

64.43 

64.73 

70.55 

63.96 

75.56 

68.73 

57.05 

68.61 

83.33 

% Solid/Lipids: 

QC 

Limite (1) 

25-164 

25-181 

32-141 

28-130 

23-140 

17-157 

24-169 

24-185 

21-178 

26-152 

26-123 

29-147 

28-136 

28-143 

26-138 

35-197 

ION 

ABUND. 

RATIO (2) 

0.77 

1. 55 

1. 21 

1.22 

1. 02 

0.89 

0.78 

1. 52 

1. 58 

0.51 

0.51 

0.51 

0.53 

0.44 

0.43 

(1) Contract-required limits for percent recovery (R) are specified 

in Table 7, Method 1613. 

(2) Contract-required limits for RRTs and ion abundance ratios are 

specified in Tables 2 and 9, respectively, Method 1613. NOTE: There 

is no ion abundance ratio for 37C14-2378-TCDD (cleanup standard). 

RRT 

(2) 

1. 009 

1.181 

0.990 

0.992 

1.068 

1.146 

0.977 

1.141 

1.168 

0.971 

0.974 

1. 006 

0.987 

1.045 

1.078 

1.010 

RFP C500273T1 

9 
Page 3 of 6 

Form 1 

CLIENTID. 

PCDD/PCDF ANALYSIS DATA SHEET 

Use for Sample and Blank Results OUTFALL 001 

Lab Name: Columbia Analytical Services Contract: SDG No: 

Lab Code: CAS Method:1613 Case No: Client No: Lab ID: E0600241-001 

Client Name: NIPPON INDUSTRIES Sample Wt/Vol: 1065 9 or mL: mL 

Matrix (Solid/Aqueous/Waste/Ash): Aqueous Initial Calibration Date: 01/10/06 

Sample Receipt Date: 04/06/06 Instrument ID: AutoSpec-Ultima 

Ext. Date: 04/11/06 GC Column:DB-5 

Ext. Vol (ul) :20.0 Inj. Vol (ul) : l. 0 Sample Data Filename: U14993#1 

Analysis Date: 14-APR-06 Time: 15:06:24 Blank Data Filename: U14998#1 

Dilution Factor: 1 Cal. Ver. Data Filename: U14983#1 

Concentration Units (pg/L or ng/Kg dry weight): pg/L % Solids/Lipids: 

CONCENTRATION DETECTION Qual. ION ABUND. 

ANALYTE 

2,3,7,8-TCDD 

1,2,3,7,8-PeCDD 

1,2,3,4,7,8-HxCDD 

1,2,3,6,7,8-HxCDD 

1,2,3,7,8,9-HxCDD 

1,2,3,4,6,7,8-HpCDD 

OCDD 

2,3,7,8-TCDF 

1,2,3,7,8-PeCDF 

2,3,4,7,8-PeCDF 

1,2,3,4,7,8-HxCDF 

1,2,3,6,7,8-HxCDF 

1,2,3,7,8,9-HxCDF 

2,3,4,6,7,8-HxCDF 

1,2,3,4,6,7,8-HpCDF 

1,2,3,4,7,8,9-HpCDF 

OCDF 

Total Tetra-Dioxins 

Total Penta-Dioxins 

Total Hexa-Dioxins 

Total Hepta-Dioxins 

Total Tetra-Furans 

Total Penta-Furans 

Total Hexa-Furans 

FOUND LIMIT (1) RATIO (2) 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

0.290 

0.292 

0.282 

0.309 

0.291 

0.341 

0.688 

0.548 

0.273 

0.273 

0.236 

0.259 

0.303 

0.272 

0.266 

0.314 

0.584 

0.290 

0.292 

0.282 

0.341 

0.548 

0.273 

0.236 

U 

U 

U 

U 

U 

U 

U 

U 

U 

U 

U 

U 

U 

U 

U 

U 

U 

U 

U 

U 

U 

U 

U 

U 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

Total Hepta-Furans * 0.266 U 

RRT 

(2) 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

MEAN 

RRF 

l. 01 

0.96 

1.06 

0.93 

l. 01 

0.90 

0.98 

0.96 

0.93 

0.99 

l.17 

l.15 

l.19 

l. 08 

l. 35 

l. 33 

l. 03 

(1) Qualifier U indicates not detected; The K indicates EMPC. The C needs value 

from second column analysis. The B indicates possible blank contamination. 

(2) RRTs and ion ratios are specified in Tables 2 and 9, Method 1613. 

10 
USEPA, EAD 

FORM 2: PCDD/PCDF LABELED COMPOUND AND 

CLEANUP STANDARD RECOVERIES 

Lab Name: Columbia Analytical Services Contract: 

CLIENT ID. 

OUTFALL 001 

SDG No: 

Lab Code: CAS Method:1613 Case No: Client No: Lab ID:E0600241-001 

Client Name: NIPPON INDUSTRIES Sample Wt/Vol: 1065 g or mL: mL 

Matrix (Solid/Aqueous/Waste/Ash): Aqueous Initial Calibration Date: 01/10/06 

Sample Receipt Date: 04/06/06 Instrument ID: AutoSpec-Ultima 

Ext. Date: 04/11/06 GC Column ID: DB-5 

Analysis Date: 14-APR-06 Time: 15:06:24 Sample Data Filename: U14993#1 

Ext.Vol (ul) :20.0 Inj.Vol(ul) :1.0 Blank Data Filename: U14998#1 

Dilution Factor: 1 Cal. Ver. Data Filename: U14983#1 

Concentration Units (pg/L or ng/Kg dry weight): pg/L 

LABELED COMPOUNDS 

13C-2,3,7,8-TCDD 

13C-1,2,3,7,8-PeCDD 

13C-1,2,3,4,7,8-HxCDD 

13C-1,2,3,6,7,8-HxCDD 

13C-1,2,3,4,6,7,8-HpCDD 

13C-OCDD 

13C-2,3,7,8-TCDF 

13C-1,2,3,7,8-PeCDF 

13C-2,3,4,7,8-PeCDF 

13C-1,2,3,4,7,8-HxCDF 

13C-1,2,3,6,7,8-HxCDF 

13C-1,2,3,7,8,9-HxCDF 

13C-2,3,4,6,7,8-HxCDF 

13C-1,2,3,4,6,7,8-HpCDF 

13C-1,2,3,4,7,8,9-HpCDF 

CLEANUP STANDARD 

37Cl-2,3,7,8-TCDD 

SPIKE CONC. 

CONC. FOUND 

2000 1440.82 

2000 1452.76 

2000 1529.09 

2000 1284.42 

2000 1180.38 

4000 2027.70 

2000 1459.02 

2000 1509.71 

2000 1488.46 

2000 1536.42 

2000 1366.68 

2000 1742.49 

2000 1474.32 

2000 1294.40 

2000 1679.11 

800 806.99 

R(%) 

(1) 

72.04 

72.64 

76.45 

64.22 

59.02 

50.69 

72.95 

75.49 

74.42 

76.82 

68.33 

87.12 

73.72 

64.72 

83.96 

100.87 

% solid/Lipids: 

ION 

QC ABUND. 

Limite(l) RATIO (2) 

25-164 0.77 

25-181 1. 56 

32-141 1.22 

28-130 1.25 

23-140 1. 04 

17-157 0.89 

24-169 0.78 

24-185 1. 60 

21-178 1. 57 

26-152 0.51 

26-123 0.51 

29-147 0.53 

28-136 0.52 

28-143 0.47 

26-138 0.45 

35-197 

(1) Contract-required limits for percent recovery (R) are specified 

in Table 7, Method 1613. 

(2) Contract-required limits for RRTs and ion abundance ratios are 

specified in Tables 2 and 9, respectively, Method 1613. NOTE: There 

is no ion abundance ratio for 37C14-2378-TCDD (cleanup standard) . 

RRT 

(2) 

1.009 

1.181 

0.990 

0.992 

1. 068 

1.146 

0.978 

1.141 

1.169 

0.971 

0.973 

1. 006 

0.987 

1.044 

1.078 

1.010 

RFP C500273T1 

11 
Page 3 of 6 

Form 3 

CLIENT ID. 

PCDD/PCDF TOXICITY EQUIVALENCE SUMMARY 

Use for Sample and Blank Results OUTFALL 001 

Lab Name: Columbia Analytical Services Contract: SDG No: 

Lab Code: CAS Method:1613 Case No: Client No: Lab ID: E0600241-001 

Client Name: NIPPON INDUSTRIES Sample Wt/Vol: 1065 g or mL: mL 

Matrix (Solid/Aqueous/Waste/Ash): Aqueous Initial Calibration Date: 01/10/06 

Sample Receipt Date: 04/06/06 Instrument ID: AutoSpec-Ultima 

Ext. Date: 04/11/06 GC Column ID: DB-5 

Ext. Vol (ul) :20.0 Inj. Vol (ul) :1.0 Sample Data Filename: U14993#1 

Analysis Date: 14-APR-06 Time: 15:06:24 Blank Data Filename: U14998#1 

Dilution Factor: 1 Cal. Ver. Data Filename: U14983#1 

Concentration Units (pg/L or ng/Kg dry weight): pg/L % Solids/Lipids: 

CONCENTRATION TEF (1) TEF-ADJUSTED 

CONCENTRATION 

2,3,7,8-TCDD * X 1.0 * 

l,2,3,7,8-PeCDD * X 1.0 * 

l,2,3,4,7,8-HxCDD * X 0.1 * 

l,2,3,6,7,8-HxCDD * X 0.1 * 

l,2,3,7,8,9-HxCDD * X 0.1 * 

.l,2,3,4,6,7,8-HpCDD * X 0.01 * 

OCDD * X 0.0001 * 

2,3,7,8-TCDF * X 0.1 * 

l,2,3,7,8-PeCDF * X 0.05 * 

2,3,4,7,8-PeCDF * X 0.5 * 

l,2,3,4,7,8-HxCDF * X 0.1 * 

l,2,3,6,7,8-HxCDF * X 0.1 * 

l,2,3,7,8,9-HxCDF * X 0.1 * 

2,3,4,6,7,8-HxCDF * X 0.1 * 

l,2,3,4,6,7,8-HpCDF * X 0.01 * 

l,2,3,4,7,8,9-HpCDF * X 0.01 *. 

OCDF * X 0.0001 * 

Total: O.OOe+OO 

(1) World Health Organization (WHO) adopted TEF's, taken from: Van der Berg, 

et al: Toxic Equivalency Factor (TEFs) for PCBs, PCDDs, PCDFs for 

Hummans and wildlife (Environ Health perspect 106:775-792 (1998). 

6/90 

12 
+ • 

•• 

Columbia 

Analytical 

Services INC. 

An Employee - Owned Company 

Accuracy & Precision Data 

10655 Richmond Avenue, Suite 130-A, Houston, TX. 77042 

Phone (713)266-1599 Fax (713)266-0130 

www.caslab.com 

. 13 
3DFA 

1613 PCDD/PCDF SPIKED SAMPLE SUMMARY 

Lab Name: COLUMBIA ANALYTICAL SERVICES 

Lab Code: CAS LAB. 10: EB25032-LCS/LCSD 

Matrix: Agueous (Solid, Aqueous, Ash, Waste) 

CONCENTRATION UNITS: (pg/L or ng/Kg) 

ANALYTE 

2378-TCDD 

12378-PeCDD 

123478-HxCDD 

123678-HxCDD 

123789-HxCDD 

1234678-HpCD 

OCDD 

2378-TCDF 

12378-PeCDF 

23478-PeCDF 

123478-HxCDF 

123678-HxCDF 

123789-HxCDF 

234678-HxCDF 

1234678-HpCD 

1234789-HpCD 

OCDF 

SPIKE 

ADDED 

(PG) 

200 

1000 

1000 

1000 

1000 

1000 

2000 

200 

1000 

1000 

1000 

1000 

1000 

1000 

1000 

1000 

2000 

LCS 

SAMPLE 

CONC. 

236.953 

1142.781 

1140.988 

1182.803 

1190.949 

1173.949 

2367.582 

234.678 

1154.438 

1118.720 

1152.254 

1236.218 

1046.839 

1098.887 

1193.829 

1128.559 

2873.302 

LCSD 

SAMPLE 

CONC. 

228.954 

1144.849 

1154.629 

1212.112 

1221. 914 

1177.554 

2396.315 

228.572 

1144.380 

1120.674 

1137.928 

1227.706 

1020.131 

1138.267 

1175.436 

1119.096 

2877.585 

LCS% 

RECOV. # 

118.48 

114.28 

114.10 

118.28 

119.09 

117.39 

118.38 

117.34 

115.44 

111. 87 

115.23 

123.62 

104.68 

109.89 

119.38 

112.86 

143.67 

CLIENT 10 

I LCS/LCSD 

LCSD% RPD 

RECOV. # % 

114.48 3.43 

114.48 0.18 

115.46 1.19 

121. 21 2.45 

122.19 2.57 

117.76 0.31 

119.82 1.21 

114.29 2.64 

114.44 0.88 

112.07 0.17 

113.79 1.25 

122.77 0.69 

102.01 2.58 

113.83 3.52 

117.54 1. 55 

111. 91 0.84 

143.88 0.15 

QC 

LIMITS 

50 - 150 

50 - 150 

50 - 150 

50 - 150 

50 - 150 

50 - 150 

50 - 150 

50 - 150 

50 - 150 

50 - 150 

50 - 150 

50 - 150 

50 - 150 

50 - 150 

50 - 150 

50 - 150 

50 - 150 

If an analyte is not detected in either analysis, enter 0 (zero) 

as the concentration. 

# Column to be used to flag values outside QC limits. 

* Compound outside the QC advisory limits of 50 - 150 

EB25032-lcsLCS 0 

14 
Page 4 of 6 

Form 1 

CLIENT ID. 

PCDD/PCDF ANALYSIS DATA SHEET 

Use for Sample and Blank Results LCS 

Lab Name: Columbia Analytical Services Contract: SDG No: 

Lab Code: CAS Method:1613 Case No: Client No: Lab ID: EB25032-LCS 

Client Name: Sample Wt/Vol: 1000 g or mL: mL 

Matrix (Solid/Aqueous/Waste/Ash): Aqueous Initial Calibration Date: 01/10/06 

Sample Receipt Date: Instrument ID: AutoSpec-Ultima 

Ext. Date: 04/11/06 GC Column:DB-5 

Ext. Vol (ul) :20.0 Inj. Vol(ul): 1. 0 Sample Data Filename: U14994#1 

Analysis Date: 14-APR-06 Time: 16:00:59 Blank Data Filename: U14998#1 

Dilution Factor: 1 Cal. Ver. Data Filename: U14983#1 

Concentration Units (pg/L or ng/Kg dry weight): pg/L % Solids/Lipids: 

CONCENTRATION DETECTION Qual. ION ABUND. RRT MEAN 

ANALYTE FOUND LIMIT (1) RATIO (2) (2 ) RRF 

2,3,7,8-TCDD 236.953 0.324 0.76 1.001 1. 01 

l,2,3,7,8-PeCDD 1142.781 0.316 1. 53 1.000 0.96 

l,2,3,4,7,8-HxCDD 1140.988 0.356 1.26 1.000 1.06 

l,2,3,6,7,8-HxCDD 1182.803 0.392 1.26 1.000 0.93 

l,2,3,7,8,9-HxCDD 1190.949 0.368 1.24 1.008 1. 01 

l,2,3,4,6,7,8-HpCDD 1173.949 0.307 1. 04 1.000 0.9.0 

OCDD 2367.582 0.508 0.88 1.000 0.98 

2,3,7,8-TCDF 234.678 0.498 0.80 1.001 0.96 

l,2,3,7,8-PeCDF 1154.438 0.311 1. 57 1.001 0.93 

2,3,4,7,8-PeCDF 1118.720 0.302 1. 54 1.000 0.99 

l,2,3,4,7,8-HxCDF 1152.254 0.275 1. 27 1.000 1.17 

l,2,3,6,7,8-HxCDF 1236.218 0.302 1.27 1.000 1.15 

l,2,3,7,8,9~HxCDF 1046.839 0.323 1. 25 1.000 1.19 

2,3,4,6,7,8-HxCDF 1098.887 0.300 1.26 1.000 1. 08 

l,2,3,4,6,7,8-HpCDF 1193.829 0.511 1. 05 1.000 1.35 

l,2,3,4,7,8,9-HpCDF 1128.559 0.596 1. 05 1.000 1.33 

OCDF 2873.302 0.680 0.92 1.003 1. 03 

Total Tetra-Dioxins 238.164 0.324 

Total Penta-Dioxins 1144.812 0.316 

Total Hexa-Dioxins 3514.741 0.356 

Total Hepta-Dioxins 1177.943 0.307 

Total Tetra-Furans 238.781 0.498 

Total Penta-Furans 2293.898 0.302 

Total Hexa-Furans 4534.199 0.275 

Total Hepta-Furans 2322.387 0.511 

(1) Qualifier U indicates not detectedi The K indicates EMPC. The C needs value 

from second column analysis. The B indicates possible blank contamination. 

(2) RRTs and ion ratios are specified in Tables 2 and 9, Method 1613. 

15 
USEPA, EAD 

CLIENT ID. 

FORM 2: PCDD/PCDF LABELED COMPOUND AND 

CLEANUP STANDARD RECOVERIESLCS 

Lab Name: Columbia Analytical Services Contract: SDG No: 

Lab Code: CAS Method:1613 Case No: Client No: Lab ID:EB25032-LCS 

Client Name: Sample Wt/Vol: 1000 9 or mL: mL 

Matrix (Solid/Aqueous/Waste/Ash): Aqueous Initial Calibration Date: 01/10/06 

Sample Receipt Date: Instrument ID: AutoSpec-Ultima 

Ext .. Date: 04/11/06 GC Column ID: DB-5 

Analysis Date: 14-APR-06 Time: 16:00:59 Sample Data Filename: U14994#1 

Ext. Vol (ul) :20.0 Inj . Vol (ul) : 1. 0 Blank. Data Filename: U14998#1 

Dilution Factor: 1 Cal. Ver. Data Filename: U14983#1 

Concentration Units (pg/L or ng/Kg dry weight): pg/L 

LABELED COMPOUNDS 

13C-2,3,7,8-TCDD 

13C-1,2,3,7,8-PeCDD 

13C-1,2,3,4,7,8-HxCDD 

13C-1,2,3,6,7,8-HxCDD 

13C-1,2,3,4,6,7,8-HpCDD 

13C-OCDD 

13C-2,3,7,~-TCDF 

13C-1,2,3,7,8-PeCDF 

13C-2,3,4,7,8-PeCDF 

13C-1,2,3,4,7,B-HxCDF 

13C-1,2,3,6,7,B-HxCDF 

13C-1,2,3,7,8,9-HxCDF 

13C-2,3,4,6,7,B-HxCDF 

13C-1,2,3,4,6,7,8-HpCDF 

13C-1,2,3,4,7,B,9-HpCDF 

CLEANUP STANDARD 

37Cl-2,3,7,8-TCDD 

SPIKE CONC. 

CONC. FOUND 

2000 1297.00 

2000 1332.03 

2000 1335.95 

2000 1173.48 

2000 1112.75 

4000 2020.65 

2000 1256.33 

2000 1380.71 

2000 1389.59 

2000 1335.60 

2000 1194.36 

2000 1645.77 

2000 1336.78 

2000 1206.99 

2000 1572.22 

800 694.32 

R (%) 

(1) 

64.85 

66.60 

66.80 

58.67 

55.64 

50.52 

62;82 

69.04 

69.48 

66.78 

59.72 

82.29 

66.84 

60.35 

78.61 

86.79 

% Solid/Lipids: 

ION 

QC ABUND. 

Limite (1) RATIO (2) 

25-164 0.80 

25-181 1. 53 

32-141 1.27 

28-130 1. 26 

23-140 1.04 

17-157 0.90 

24-169 0.77 

24-185 1.53 

21-178 1. 58 

26-152 0.51 

26-123 0.52 

29-147 0.51 

28-136 0.51 

28-143 0.44 

26-138 0.44 

35-197 

(1) Contract-required limits for percent recovery (R) are specified 

in Table 7, Method 1613. 

(2) Contract-required limits for RRTs and ion abundance ratios are 

specified in Tables 2 and 9, respectively, Method 1613. NOTE: There 

is no ion abundance ratio for 37C14-2378-TCDD (cleanup standard) . 

RRT 

(2) 

1.009 

1.181 

0.990 

0.992 

1.068 

1.146 

0.977 

1.140 

1.168 

0.971 

0.974 

1.006 

0.987 

1.044 

1. 078 

1.010 

RFP C500273T1 

16 
Form 1 

PCDD/PCDF ANALYSIS DATA SHEET 

Use for Sample and Blank Results 

Page 5 of 6 

CLIENT ID. 

LCSD 

Lab Name: Columbia Analytical Services Contract: SDG No: 

Lab Code: CAS Method:1613 Case No: Client No: Lab ID: EB25032-LCSD 

Client Name: Sample Wt/Vol: 1000 g or mL: mL 

Matrix (Solid/Aqueous/Waste/Ash): Aqueous Initial Calibration Date: 01/10/06 

Sample Receipt Date: Instrument ID: AutoSpec-Ultima 

Ext. Date: 04/11/06 GC Column:DB-5 

Ext. Vol (ul) :20.0 Inj. Vol (ul) :1.0 Sample Data Filename: U14995#1 

Analysis Date: 14-APR-06 Time: 16:46:20 Blank.Data Filename: U14998#1 

Dilution Factor: 1 Cal. Ver. Data Filename: U14983#1 

Concentration Units (pg/L or ng/Kg dry weight): pg/L % Solids/Lipids: 

CONCENTRATION . DETECTION Qual . ION ABUND. RRT MEAN 

ANALYTE FOUND LIMIT (1) RATIO (2) (2) RRF 

2,3,7,8-TCDD 228.954 0.350 0.75 1.001 1. 01 

l,2,3,7,8-PeCDD 1144.849 0.456 1. 54 1.000 0.96 

l,2,3,4,7,8-HxCDD 1154.629 0.244 1.21 1.000 1. 06 

l,2,3,6,7,8-HxCDD 1212.112 0.273 1. 24 1.000 0.93 

l,2,3,7,8,9-HxCDD 1221.914 0.254 1.28 1.008 1. 01 

1 i 2,3,4,6,7,8-HpCDD 1177.554 0.288 1. 03 1.000 0.90 

OCDD 2396.315 0.512 0.87 1.000 0.98 

2,3,7,8-TCDF 228.572 0.316 0.77 1. 001 0.96 

l,2,3,7,8-PeCDF 1144.380 0.326 1. 57 1.001 0.93 

2,3,4,7,8-PeCDF 1120.674 0.337 l. 54 1.000 0.99 

l,2,3,4,7,8-HxCDF 1137.928 0.189 1.24 1.000 1.17 

l,2,3,6,7,8-HxCDF 1227.706 ·0.204 l. 27 1.000 l.15 

l,2,3,7,8,9-HxCDF 1020.131 0.222 l.25 1.000 1.19 

2,3,4,6,7,8-HxCDF . 1138.267 0.213 l.25 1.000 1. 08 

l,2,3,4,6,7,8-HpCDF 1175.436 0.724 l. 05 1.000 1. 35 

l,2,3,4,7,8,9-HpCDF 1119.096 0.856 1.06 1.000 1. 33 

OCDF 2877.585 0.527 0.91 1.003 l. 03 

Total Tetra-Dioxins 228.954 0.350 

Total Penta-Dioxins 1144.849 0.456 

Total Hexa-Dioxins 3588.655 0.244 

Total Hepta-Dioxins 1177.554 0.288 

Total Tetra-Furans 234.866 0.316 

Total Penta-Furans 2271.909 0.337 

Total Hexa-Furans 4524.032 0.189 

Total Hepta-Furans 2294.532 0.724 

(1) Qualifier U indicates not detected; The K indicates EMPC. The C needs value 

from second column analysis. The B indicates possible blank contamination. 

(2) RRTs and ion ratios are specified in Tables 2 and 9, Method 1613. 

17 
USEPA, EAD 

FORM 2: PCDD/PCDF LABELED COMPOUND AND 

CLEANUP STANDARD RECOVERIES 

Lab Name: Columbia Analytical Services Contract: 

CLIENT ID. 

LCSD 

SDG No: 

Lab Code: CAS Method:1613 Case No: Client No: Lab ID:EB25032-LCSD 

Client Name: Sample Wt/Vol: 1000 9 or mL: mL 

Matrix (Solid/Aqueous/Waste/Ash): Aqueous Initial Calibration Date: 01/10/06 

Sample Receipt Date: Instrument ID: AutoSpec-Ultima 

Ext. Date: 04/11/06 GC Column ID: DB-5 

Analysis Date: 14-APR-06 Time: 16:46:20 Sample Data Filename: U14995#1 

Ext. Vol (ul) : 20.0 Inj .Vol{ul) :1.0 Blank Data Filename: U14998#1 

Dilution Factor: 1 Cal. Ver. Data Filename: U14983#1 

Concentration Units (pg/L or ng/Kg dry weight): pg/L 

LABELED COMPOUNDS 

13C-2,3,7,8-TCDD 

13C-1,2,3,7,8-PeCDD 

13C-1,2,3,4,7,8-HxCDD 

13C-1,2,3,6,7,8-HxCDD 

13C-1,2,3,4,6,7,8-HpCDD 

13C-OCDD 

13C-2,3,7,8-TCDF 

13C-1,2,3,7,8-PeCDF 

13C-2,3,4,7,8-PeCDF 

13C-1,2,3,4,7,8-HxCDF 

13C-1,2,3,6,7,8-HxCDF 

13C-1,2,3,7,8,9-HxCDF 

13C-2,3,4,6,7,8-HxCDF 

13C-1,2,3,4,6,7,8-HpCDF 

13C-1,2,3,4,7,8,9-HpCDF 

CLEANUP STANDARD 

37Cl-2,3,7,8-TCDD 

SPIKE CONC. 

CONC. FOUND 

2000 1358.14 

2000 1297.06 

2000 1459.39 

2000 1240.63 

2000 1219.17 

4000 2352.22 

2000 1291.40 

2000 1366.76 

2000 1311.77 

2000 1458.34 

2000 1290.29 

2000 1766.46 

2000 1405.61 

2000 1365.01 

2000 1712.78 

800 724.69 

R{%) 

(1) 

67.91 

64.85 

72.97 

62.03 

60.96 

58.81 

64.57 

68.34 

65.59 

72.92 

64.51 

88.32 

70.28 

68.25 

85.64 

90.59 

% Solid/Lipids: 

QC 

Limite (1) 

25-164 

25-181 

32-141 

28-130 

23-140 

17-157 

24-169 

24-185 

21-178 

26-152 

26-123 

29-147 

28-136 

28-143 

26-138 

35-197 

ION 

ABUND. 

RATIO (2) 

0.78 

1. 54 

1. 23 

1.23 

1. 04 

0.90 

0.77 

1.55 

1. 54 

0.51 

0.52 

0.52 

0.53 

0.43 

0.44 

(1) Contract-required limits for percent recovery (R) are specified 

in Table 7, Method 1613. 

(2) Contract-required limits for RRTs and ion abundance ratios are 

specified in Tables 2 and 9, respectively, Method 1613. NOTE: There 

is no ion abundance ratio for 37C14-2378-TCDD (cleanup standard) . 

RRT 

(2) 

1.009 

1.181 

0.990 

0.992 

1.068 

1.145 

0.977 

1.141 

1.169 

0.971 

0.973 

1.006 

0.987 

1.044 

1. 078 

1. 010 

RFP C500273T1 

18 
Columbia 

Analytical . Services INC. 

An Employee - Owned Company 

Chain-of-custody 

10655 Richmond Avenue, Suite 130-A, Houston, TX 77042 

Phone (713)266-1599 Fax (713)266-0130 

www.caslab.com 

19 
~~Olumbia Analytical Services INC. 

An Employee - Owned Company 

CHAIN OF CUSTODY 

1317 South 13th Ave .• Kelso, WA 98626 • (360) 577-7222 • (800) 695-7222x07 • FAX (360) 636-1068 

PROJECT NAME 

. U{Jn% =:£..ehv--i+ I\y}O\ I a:~ 7 I PROJECT NUMBER I I / 

PROJECT MANAGER J.tn1"l SiPll.f't.1.e \ 7 COMPANY/ADDRESS ff! 

!# CITY/STATEIZIP <-~ 

E-MAIL ADDRESS 8 

/.J... 

PHONE # :g 

LU 

fM-t-% \ \ bO \ It/5"/O~ tY6~D5 

~ 

~ 

W'li.r.>yI3 

SR#: _______ _ 

PAGE OF_1 COC# ____ _ 

o 

<0 

!is 

REMARKS 

,~ 

r---------+_--+_--;---~--+_;-~_+~~~~+_+_~~_+_+~--~+_+_~~~~----~I~ 

INVOICE INFORMATION 

P.O. # --:-:--n:-----,-----

Circle which metals are to be analyzed: 

Total Metals: AI As Sb Ba Be B Ca Cd Co Cr Cu Fe Pb Mg Mn Mo Ni K Ag Na Se Sr TI Sn V Zn Hg 

I]EPORT REQUIREMENTS 

_V_ I. Routine Report: Method 

Blank, Surrogate, as 

required 

Bill To: N..£11~ 

~ " PC;\:Vi£ili{¥ Dissolved Metals: AI As Sb Ba Be B Ca Cd Co Cr Cu Fe Pb Mg Mn Mo Ni K Ag Na Se Sr TI Sn V Zn Hg 

*INDICATE STATE HYDROCARBON PROCEDURE: AK CA WI NORTHWEST OTHER: (CIRCLE ONE) 

II. Report Dup., MS, MSD as 

required 

TURNAROUND REQUIREMENTS I SPECIAL INSTRUCTIONS/COMMENTS: 

III. Data Validation Report 

(includes all raw data) 

_ IV. CLP Deliverable Report 

V. EDD 

24 hr. __ 48hr. 

__ 5 Day 

~ Standard (10-15 working days) 

Provide FAX Results 

Requested Report Date 

~QUISHED BY: EIVED BY: 

~S </;<;'db ~4> /&,'/1) 

\. Sigm~re, a ~ime;t <1'"'lSignatu e 0 I a ITIm::tt;QU (;, t> (; 

.!)Ql' ,(JDi.,u.- 1 laid....... c;; ~ 1./ .. n"'"M1- (.:5 de...s as ~ '-/ 

Printed Name FirM' I Printed Name Firm" 4h/{5)(_ 

"7 

RELINQUISHED BY: 

Signature Date/Time 

Printed Name Firm 

RECEIVED BY: 

Signature Date/Time 

Printed Name Firm 

RCOC #1 06/03 
Folder #: 

Client Name: 

Project Name: 

Project Number: 

Report To: 

~ .... 

-s;. Phone Number: ~ Cell Number: 

~ Fax Number: 

E-mail: 

CAS Samp No. 

E0600241-00 1 

E0600241 

Columbia Analytical Services,Inc. 

1613B full 

NPDES Permit Application 

Ann Schlegel 

Nippon Paper Industries Co., Ltd. 

P.O. Box 271 

Port Angeles, WA 98362 

360-452-0615 

360-452-9004 

ann.schlegel@npiusa.com , 

Client Samp No. Matrix 

Service Request Summary 

SVM 

~~ ~I\o CZl ..... 

~§I 

1

0 CZl Collected n 7. 

Project Chemist: Jane Freemyer 

Originating Lab: HOUSTON 

Logged By: JBECK 

Date Received: 04/0612006 

Internal Due Date: 0412012006 

QAPP: LAB QAP 

Qualifier Set: CAS Standard 

Formset: CAS Standard 

Merged?: 

Report to MDL?: 

P.O. Number: NPDES Permit Application 

EDD: No EDD Specified 

Outfall 001 Water 4/5/06 08051 IT 

Printed 4/1112006 10:57:29AM Service Request for E0600241 

3 - 1000 ml-Glass Bottle NM AMBER Teflon Liner Unpreser 

Location: SMO 

,-

C\J 

Page 1 of 1 
Columbia Analytical Services Inc. 

Cooler Receipt And Preservation Form 

Project/Client: Standard SDG/Columbia Analytical Services,Inc. , Work Order: E0600241 

Cooierreceivedon04/0612006 and opened on 1/'-/t9(D If) ~ /0 by D .... ,.....r~ r;?J"e-5 t I 

1. Were custody seals on outside of cooler? 

2. Were seals intact and signature & date correct? 

3. Is the shipper's airbiII available and filed? NAi~ 9. Did all bottle labels and tags agree with custody papers? 

10. Were the COlTect types of bottles used for the tests indicated? 

, N 11. Were all of the preserved bottles received at the lab with the appropriate pH? 

4. COC# 

5. Were custody papers properly fiIIed out (ink, signed, etc.)? d?N 

12. Were VOA vials checked for absence of air bubbles, and if present, noted below? 

NA 13. Did the bottles originate from CAStE or a branch laboratory? 

6. Type of packing material present 

7. Did all bottles alTive in good condition (unbroken)? 

8. Were all bottle labels complete (i.e. analysis, preservation, etc.)? ~~ 

14. Are CWA Microbiology samples received with >\1, the 24 hr. hold time remaining 

NA fl'om collection? 

NA 15. Was C12/Res negative? 

Lab Code Sample Name 

E0600241-00 1 Outfall 001 

1000ml-Glass Bottle NM AMBER Teflon Liner(Unpreserved) Received Conditions 

Expected Conditions Cooler Rec pH Rec Seal 

Bottle ID Barcode HS pH Temp # Temp Check HS Intact? Corrective Action 

E0600241-00 1.0 1 1111111111111111111111111111111111111111111111111111111111111111111111111111111111111 NA 23.0 NA 

Test List: 1613B 

E0600241-00 1. 02 1111111111111111111111111111111111111111111111111111111111111111111111111111111111111 NA 23.0 NA 

Test List: 1613B 

E0600241-00 1. 03 1111111111111111111111111111111111111111111111111111111111111111111111111111111111111 NA 23.0 ------- ------- ------- Test List: 1613B 

All tests have one or more assigned bottles 

Pllnted 04/111200609:47 Cooler Receipt And Preservation Worksheet 

NA d2 N 

i~N Y N 

~ Y N 

&1N 

~Y A Y 

N 

N 

C\J 

C\J 

Page 1 of 1 
Project 

ID 

SODIUM SULFATE C1-71-2 

ACETONE C1-6B-3 

TOLUENE C1-74-5 

GLASS WOOL GW1-1-4 

DICHLOROMETHANE C1-73-3 

ETHYL ACETATE C1-69-4 

NONANE C1-67-5 

HEXANE C1-73-2 

Columbia Analytical Services, INC. 

EB25032 

Sulfuric Acid Cleanup: 04/12/06 

Silica Gel/Carbon Column: 04/12/06 

Lab 

ID 

1613 

Client 

ID 

SAND C1-33-1 

TRIDECANE C1-74-2 

SULFURIC ACID C1-74-3 

BASIC SILICA GEL S1-24-3 

CARBON: C1-73-5 

ACIDIC SILICA GEL S1-24-4 

SILICA GEL S1-22-6 

Standard: 

Solution ID: 

Volume: 

Spiker: 

Witness: 

Date: 

Standard: 

Solution ID: 

Volume: 

Spiker: 

Witness: 

Date: 

Internal Matrix 

DS-6-1B DS-3-1B 

1000 uL 100 uL 

DB DB 

CID CID 

04/11106 04111106 

Cleanup Recovery 

DS-6-2AIB PJ-/'-J~ 

100 uL 2-d..vi 

CID 

DHF I--

04112/06 y/t'YUt 

Calculated 

Percent 

Solid I Moisture 

Dry I Sample 

Weight Description 

EXTRACTION START: 04/11/06 

EXTRACTION END: 04/11106 

EXTRACTION TECHNIQUE: Sep. Funnel 

TIME STARTED: 1100 

TIME FINISHED: 1500 

EXTRACTS RECEIVED BY tA-. ------~~--------------

DATE RECEIVED 04/14/06, ____________ _ 

('I) 

C\J 
International Paper Riegelwood, NC

Feb-12

Dioxin and Dioxin-like Compound TRI Reports for 2007 and 2009

Releases to Water

TRI Dioxin Congener Distributions

Please fill in the 

column below

Dioxin Distribution

CASNU Chemical Name

2009 

Congener 

Number g/yr g/y

2007 

Congener 

Number

1746016 Tetrachlorodibenzo-p-dioxin, 2,3,7,8- 1 0 0 17

40321764 Pentachlorodibenzo-p-dioxin, 1,2,3,7,8- 2 0 0 15

39227286 Hexachlorodibenzo-p-dioxin, 1,2,3,4,7,8- 3 0 0 7

57653857 Hexachlorodibenzo-p-dioxin, 1,2,3,6,7,8- 4 0 0 8

19408743 Hexachlorodibenzo-p-dioxin, 1,2,3,7,8,9- 5 0 0 9

35822469 Heptachlorodibenzo-p-dioxin, 1,2,3,4,6,7,8- 6 0 0 10

3268879 Octachlorodibenzo-p-dioxin 7 0.02809 0.0281 12

51207319 Tetrachlorodibenzofuran, 2,3,7,8- 8 0.03589 0 16

57117416 Pentachlorodibenzofuran, 1,2,3,7,8- 9 0.00232 0.00232 13

57117314 Pentachlorodibenzofuran, 2,3,4,7,8- 10 0 0 14

70648269 Hexachlorodibenzofuran, 1,2,3,4,7,8- 11 0 0 3

57117449 Hexachlorodibenzofuran, 1,2,3,6,7,8- 12 0 0 4

72918219 Hexachlorodibenzofuran, 1,2,3,7,8,9- 13 0 0 5

60851345 Hexachlorodibenzofuran, 2,3,4,6,7,8- 14 0 0 6

67562394 Heptachlorodibenzofuran, 1,2,3,4,6,7,8- 15 0 0 1

55673897 Heptachlorodibenzofuran, 1,2,3,4,7,8,9- 16 0 0 2

39001020 Octachlorodibenzofuran 17 0 0 11

Total g/y --> 0.0663 0.03042

Data Reported for 2009 Data Used for 2007 Report
SD Warren Skowhegan, ME

Feb-12

Dioxin and Dioxin-like Compound TRI Reports for 2007 and 2009

Releases to Water

TRI Dioxin Congener Distributions

Please fill in the 

column below

Dioxin Distribution

CASNU Chemical Name

2009 

Congener 

Number g/yr g/y

2007 

Congener 

Number

1746016 Tetrachlorodibenzo-p-dioxin, 2,3,7,8- 1 0 0.0000 17

40321764 Pentachlorodibenzo-p-dioxin, 1,2,3,7,8- 2 0.023 0.0229 15

39227286 Hexachlorodibenzo-p-dioxin, 1,2,3,4,7,8- 3 0 0.0000 7

57653857 Hexachlorodibenzo-p-dioxin, 1,2,3,6,7,8- 4 0 0.0000 8

19408743 Hexachlorodibenzo-p-dioxin, 1,2,3,7,8,9- 5 0 0.0000 9

35822469 Heptachlorodibenzo-p-dioxin, 1,2,3,4,6,7,8- 6 0 0.0000 10

3268879 Octachlorodibenzo-p-dioxin 7 0 0.0000 12

51207319 Tetrachlorodibenzofuran, 2,3,7,8- 8 0 0.0000 16

57117416 Pentachlorodibenzofuran, 1,2,3,7,8- 9 0 0.0000 13

57117314 Pentachlorodibenzofuran, 2,3,4,7,8- 10 0 0.0000 14

70648269 Hexachlorodibenzofuran, 1,2,3,4,7,8- 11 0.0364 0.0361 3

57117449 Hexachlorodibenzofuran, 1,2,3,6,7,8- 12 0 0.0000 4

72918219 Hexachlorodibenzofuran, 1,2,3,7,8,9- 13 0.0218 0.0217 5

60851345 Hexachlorodibenzofuran, 2,3,4,6,7,8- 14 0 0.0000 6

67562394 Heptachlorodibenzofuran, 1,2,3,4,6,7,8- 15 0.0253 0.0252 1

55673897 Heptachlorodibenzofuran, 1,2,3,4,7,8,9- 16 0 0.0000 2

39001020 Octachlorodibenzofuran 17 0.0777 0.0439 11

Total g/y --> 0.1842 0.1497

Data Reported for 2009 Data Used for 2007 Report
1 2 3 4 5 6

17 15 7 8 9 10

703584000 692928000 23498240 9556480 10595840 411136

2007 2157.7216 0 208108.8 0 1024235.52 0

2009 0 15937344 0 0 0 0

2009 0 0.023 0 0 0 0

2007 0.0000 0.0229 0.0000 0.0000 0.0000 0.0000

7 8 9 10 11 12 13

12 16 13 14 3 4 5

6585.6 43819553.68 7632640 557312000 5760000 14109440 47308800

0 0 0 0 88.6999344 0 0

0 0 0 0 209664 0 1031332

0 0 0 0 0.0364 0 0.0218

0.0000 0.0000 0.0000 0.0000 0.0361 0.0000 0.0217

14 15 16 17

6 1 2 11

51204160 85760 3033984 2020.96

0 15833404.8 0 0 1234502.042 406.516584

0 2169.728 0 157.028592 86521954.4 35062.1568

0 0.0253 0 0.0777

0.0000 0.0252 0.0000 0.0439

2009 Congener Number

2007 Congener Number

2009 Congener Number

2007 Congener Number

2009 Congener Number

2007 Congener Number

2010 AF&PA SUSTAINABILITY REPORT

American

Forest & Paper

Association

SUSTAINABILITY:

a foundation of the

forest products industry

Contents

Introduction	 2

AF&PA Environmental, Health 

& Safety Principles 2

AF&PA Sustainable Procurement Principles 2

Welcome from AF&PA’s President 3

Executive Summary	 4

Economic Contributions 4

Social Contributions 5

Environmental Performance 5

AF&PA Sustainability Elements 5

n 1. Sustainable Use of Renewable Resources 5

n 2. Leading the Way in Recycling 6

n 3. Reducing Our Environmental Footprint 7

n 4. Generating and Conserving Energy and Materials 8

n 5. Reducing Greenhouse Gases 8

n 6. Benefiting the Communities, Employees, and Families 

Everywhere Our Products are Made and Sold 10

REPORTING SUSTAINABILITY PROGRESS	

1. Sustainable Use of Renewable Resources	 14

n Sustainable Forestry and Procurement 14

2. Leading the Way in Recycling	 15

n Record High Recovery 15

n AF&PA Recycling Incentive Programs 15

n Additional Benefits of Recycling 16

3. Reducing Our Environmental Footprint	 17

n Pulp and Paper Mill Air Emissions Releases 17

n Wood Product Facility Air Emissions Releases 18

n Pulp and Paper Mill Water Discharges 18

n Pulp and Paper Mill Chemical Compound 

Release Reductions 19

n Pulp and Paper Mill TRI Chemical Releases 19

n Wood Products Facility Chemical 

Compound Release Reductions 20

n Pulp and Paper Mill Residuals Management 21

n Wood Products Facility Residuals Management 21

n Adherence to Mandatory AF&PA EHS Principles 21

4. Generating and Conserving

Energy and Materials	 23

n Energy Use and Self-Sufficiency 23

n Fossil Fuel Use Reductions 23

n Renewable Fuels Use 24

n Cogeneration 24

n Conserving Materials and Pollution Prevention 24

5. Reducing Greenhouse Gases	 26

n Emissions Intensity Reductions 26

n Absolute Emissions Reductions 26

n The Carbon Cycle 27

n Advantages of Wood as a Building Product 27

6. Benefiting the Communities,

Employees, and Families Everywhere

Our Products are Made and Sold	 28

n Economic Performance 28

n U.S. Forest Products Exports 30

n Safety Program Recognition 30

n Safety Performance Reporting 30

n Public Engagement and Reporting 31

n Community Involvement and Outreach 32

n Participation in Public Policy Development 32

n Employee Involvement Programs 33

Sustainability and

the Road to the Future	 34

Innovation and Continuous Improvement 34

Research and Development Support 34

Industry Sponsored Research Organizations 34

Support for Academic Institutions 35

Cooperative Partnerships 36

Member Company Corporate Research Programs 36

Internet Addresses for Forest Products Organizations 36
2

AF&PA Sustainable

Procurement Principles

1. Take part in the Sustainable Forestry Initiative® program as a program participant; or

2. Adhere to the following principles:

i. Support programs that supply regionally appropriate information or services to forest landowners, describing the importance 

of and providing implementation guidance on best management 

practices (BMPs); reforestation; afforestation; visual quality management; management of harvest residue; control of invasive exotic plants and animals; characteristics of special sites; and conservation of critical wildlife habitat elements and threatened and 

endangered species, and Forests with Exceptional Conservation 

Value.

ii. Encourage landowners to utilize the services of qualified resource professionals and qualified logging professionals in applying principles of sustainable forest management.

iii. Maintain a program for the purchase of raw material from 

wood producers that have completed training programs and are 

recognized as qualified logging professionals. 

iv. Maintain a program to address adverse weather conditions.

v. Monitor and evaluate the use of BMPs across the wood and fiber 

supply area.

vi. Monitor the use of BMPs by wood producers supplying the 

company’s facilities and use the information to maintain rates of 

conformance to best management practices and to identify areas 

for improved performance. 

vii. If the company procures wood fiber outside North America, 

maintain programs to:

– Promote conservation of biodiversity hotspots and major tropical wilderness areas.

– Ensure fiber sourcing programs support the principles of sustainable forestry, including efforts to thwart illegal logging.

– Assess the risk that fiber-sourcing programs could acquire material from illegal logging.

– Assess the risk that fiber-sourcing programs could take place in 

countries without effective laws addressing worker safety, fair labor practices, indigenous people’s rights, anti-discrimination, anti-harassment, prevailing wages, and workers’ right to organize.

viii. Individually and/or through cooperative efforts provide support or funding for forest research to improve forest health, productivity, and sustainable management of forest resources, and 

the environmental benefits and performance of forest products.

ix. Provide funding and other support for training and education 

programs to foster improvement in the professionalism of wood 

producers, including awareness and implementation of sustainable forest management practices.

x. Comply with applicable federal, provincial, state, and local forestry and related environmental and social laws and regulations.

3. Participate in one of the qualifying sustainable forest management programs, including chain-of-custody certification.

AF&PA Environmental, Health

& Safety (EHS) Principles

The EHS Principles require members:

1. To make environmental, health, and safety considerations priorities in operating existing facilities, as well as in the planning of new 

operations.

2. To recognize, in developing and designing products to meet customer needs, the environmental, health, and safety effects of product manufacture, distribution, use, and disposal.

3. To monitor their environmental, health, and safety performance 

and to report regularly on these matters to their Boards of Directors, 

as well as to confirm their adherence to these principles annually to 

the American Forest & Paper Association.

4. To train employees in their environmental, health, and safety responsibilities and to promote awareness and accountability on these 

matters.

5. To improve environmental, health, and safety performance 

through support of research and development that advances the 

frontiers of knowledge.

6. To communicate with employees, customers, suppliers, the community, public officials, and shareholders to build greater understanding on environmental, health, and safety matters.

7. To participate constructively in the development of public policies 

on environmental, health, and safety matters.

8. To continue to pursue energy conservation, increased energy efficiency, greater utilization of alternatives to fossil fuels, and opportunities for cogeneration of electricity.

Introduction

As a condition of membership, American Forest & Paper Association (AF&PA) companies have formally agreed to adhere 

to the Association’s Sustainable Procurement and Environmental, Health & Safety (EHS) Principles. These self-imposed 

principles guide, demonstrate, and measure progress towards 

the industry’s strong sustainability commitment to protecting 

the environment, the health and safety of employees, and their 

communities.
Welcome from AF&PA’s President

We welcome you to the American Forest & Paper Association’s 2010 Sustainability Report. AF&PA members continue 

to demonstrate leadership in sustainability, and their longstanding commitment to sustainability has produced remarkable 

progress in key indicators as shown in this report. 

In the forest products industry, sustainability means that we 

strive to ensure our resources will be as plentiful and available 

to future generations as they are today; to preserve and grow 

the economic contributions of the industry and its businesses; 

and to foster the well-being of the communities where we live 

and work. Sustainable practices—forest management, efficient 

manufacturing, energy generation and conservation, and fiber 

recovery and recycling—define our dedication to protecting 

our environment and meeting our economic and societal commitments. These sustainable practices are the foundation of our 

industry and, therefore, they serve as the core of this report.

The specific practices identified by AF&PA members as 

those that define sustainability for the forest products industry, 

and which serve as the organizing basis for this report, are:

n Sustainable use of renewable resources

n Leading the way in recycling

n Reducing our environmental footprint

n Generating and conserving energy and materials

n Reducing greenhouse gases

n Benefiting the communities, employees, and families everywhere our products are made and sold

As members of AF&PA, companies are required to adhere 

to and report biennially on a rigorous set of Environmental, 

Health & Safety (EHS) Principles and sustainable forest management and procurement principles. The information in this 

report has been generated through our 2008 EHS performance 

verification survey of members, additional information pertaining to AF&PA sustainability activities, and data from government agency sources. Information regarding recent AF&PA 

initiatives in fiber procurement, recycling, and economic performance tracking is also included in this report. 

Without question, the challenging economic conditions that 

became painfully apparent in 2008 and 2009 have had impacts 

on performance, most notably in the area of economic performance. However, as the report also shows, members have 

reacted to these challenges in proactive ways and continue to 

build on the strong progress already made to further improve 

sustainability performance for the future. Thank you for your 

interest in our industry. For additional information, please refer 

to our website at http://www.afandpa.org.

Best regards,

Donna Harman, President and CEO

June 2010

3
Executive Summary

The American Forest & Paper Association (AF&PA) is proud 

to present its sustainability report for 2010. AF&PA is the national trade association of the forest products industry, representing pulp, paper, packaging and wood product manufacturers, as well as forest landowners. These companies make 

essential products for people from renewable and recyclable 

resources that sustain the environment.

The information in this report has been generated through 

our 2008 EHS performance verification survey of members, 

additional information pertaining to AF&PA sustainability activities, and data from government agency sources. Information regarding recent AF&PA initiatives in fiber procurement, 

recycling, and economic performance tracking is also included 

in this report. 

Adherence to the AF&PA EHS Principles is mandatory for 

our members. Members owning forestland must conform to 

an independent sustainable forest management program, and 

members that source wood fiber from the forest must comply 

with AF&PA Sustainable Procurement Principles. 

Providing essential products and high-quality jobs, while 

pursuing a unique mission of wise and sustainable use of natural resources, the forest products industry has been a long-term 

leader in sustainability. AF&PA members subscribe to the sustainability concepts recognized by a number of international 

forums, including the United Nations General Assembly 2005 

World Summit. These forums have established that the three 

essential pillars of sustainability – the economic, social, and 

environmental elements – are interdependent factors which 

must collectively support long-term viability, growth, and environmental improvement. Each pillar influences or is dependent upon the others, and business practices that support them 

often address more than one, often all three. 

Economic Contributions

While each of the three pillars of sustainability is important and 

interdependent, economic sustainability is absolutely essential to the successful pursuit of overall sustainability. AF&PA 

member companies make important contributions to the economy globally, nationally, regionally, and especially within the 

communities in which they operate. The jobs they provide at 

pulp, paper, and wood products manufacturing facilities are for 

highly skilled employees and produce commensurate wages 

and salaries. Local purchases of raw materials, supplies, and 

AF&PA members utilize the three interdependent 

pillars of sustainability – economic, social, and 

environmental – that must collectively support 

long-term viability, growth, and environmental 

improvement. 

4
5

support services extend the economic reach of these operations 

well beyond the plant gate. Local taxes paid and financial contributions or donations made by companies provide important 

economic support for educational programs, civic organizations, and local government services. 

Social Contributions

AF&PA members are committed to the communities in which 

they operate. They provide direct and indirect employment, 

contribute community volunteers, support education, advance 

health and safety practices, provide recreational opportunities, 

and support arts activities for local citizens. AF&PA member 

pulp, paper, and wood products mills utilize timber harvested 

from forest lands through sustainable forest management practices. These advanced timber procurement activities provide 

highly skilled manufacturing jobs, maintain the environment, 

and support local family-owned businesses in rural communities. Sustainable forest practices utilized by land managers that 

supply the mills also produce important ecosystem, recreation, 

and aesthetic benefits. Members respond to social needs on a 

global scale, providing natural disaster relief including building materials and assistance to world food programs. Member 

support for schools, educational curriculums, and other programs improve the lives of children worldwide.

Environmental Performance

Enhancing and maintaining the environmental performance of 

the industry is a primary objective. This industry continually 

strives for environmental sustainability through pursuit of forest management standards, efficient manufacturing practices, 

specialized energy generation and conservation measures, fiber recovery and recycling activities, responsible use of water 

resources, and a continuous improvement focus. In turn, these 

environmental improvements, through reduction in waste and 

increased efficiencies, improve the economic health of AF&PA 

members. These improved economics provide financial resources for continued environmental improvements and social 

benefits to local communities. 

AF&PA Sustainability Elements

AF&PA members have identified six practices to define sustainability for the forest products industry that span across all 

three pillars – economic, social, and environmental viability. 

These elements are: 

n Sustainable use of renewable resources

n Leading the way in recycling

n Reducing our environmental footprint

n Generating and conserving energy and materials

n Reducing greenhouse gases

n Benefiting the communities, employees, and families everywhere our products are made and sold

This report highlights sustainability performance for each 

of the six elements.

1. Sustainable use of renewable resources

The products of the forest products industry, and the processes 

used to make them, are inherently sustainable. AF&PA members have shown leadership in development and use of forest 

certification programs and sustainable procurement principles.

n AF&PA members owning forestland must conform to an 

independent sustainable forest management program. These 

Many forest products companies have established 

foundations to improve and add value to the 

quality of life in the communities where their 

employees live and work.

SUSTAINABILITY

ECONOMIC

SOCIAL ENVIRONMENTAL

Participation in the development of Life Cycle 

Assessment (LCA) tools is leading an AF&PA 

member paper company to apply the tools to 

decision making regarding the use of recycled 

fiber in product design.
include: the Sustainable Forestry Initiative (SFI®) program; systems endorsed 

by the international Program for the 

Endorsement of Forest Certification 

(PEFC), which in North America are the 

Canadian Standards Association program, the American Tree Farm System®

and SFI; and the seven regional forest 

management standards developed for the 

U.S. by the Forest Stewardship Council 

(FSC). 

n These programs promote good forest 

management practices that guide forest 

management toward sustainable outcomes; ensure that timber and non-timber forest products are produced under 

the highest ecological, social and ethical 

standards; and integrate reforestation, 

nurturing, and harvesting of trees for 

useful products with the conservation of 

soil, air and water resources, protection 

of wildlife and fish habitat, and maintenance of forest aesthetics. 

n All AF&PA members sourcing fiber 

directly from the forest are required to 

adhere to the AF&PA Sustainable Procurement Principles. These require support of programs that supply regionally 

appropriate information and services to 

forest landowners regarding best management practices; reforestation; afforestation (conversion of non-forested land 

to forestland); visual quality management; management of harvest residue; 

and conservation of critical wildlife habitat, threatened and endangered species, 

and Forests with Exceptional Value.

2. Leading the way in recycling

Recovered fiber is an important raw 

material in the production of new paper 

products. 

n Leading the way, the paper industry 

has set and achieved incremental recovery goals since 1990. In the 20 years 

since, recovery has doubled. In 2009, 

63.4 percent of U.S. paper consumed 

was recovered – surpassing AF&PA’s 60 

percent recovery goal three years ahead 

of schedule.

n AF&PA engages in a variety of programs and partnerships. To help educate 

students and their families about the importance of paper recycling, programs 

carried out in conjunction with Scholastic Books and the Keep America Beautiful organization deliver curricula straight 

to the classroom. In addition, AF&PA is 

engaged with the Environmental Paper 

Network, the Environmental Protection 

Agency, and a variety of stakeholders 

that also encourage increased paper recovery.

n The annual AF&PA Recycling Awards 

recognize outstanding business, school, 

and community recycling programs and 

share their best practices on paperrecy63.4%

Paper and Paperboard Recovery Rate

(% of annual consumption recovered for recycling)

6
cles.org, so that they can be replicated by 

other organizations.

n Recycling saves landfill space and 

eliminates associated greenhouse gas 

emissions that would be generated by 

decomposition of the landfilled paper.

n The use of recycled fiber also reduces 

the energy, and associated greenhouse 

gas emissions, required to manufacture 

a number of paper products. 

3. Reducing our 

environmental footprint

Over the past several decades, forest 

products industry manufacturing facilities have dramatically reduced their 

environmental footprint. Modernization of manufacturing processes and expanded pollution control and prevention 

measures have produced these results. 

Having already achieved significant reductions in releases, recent incremental 

reductions in water and air emission 

releases have approached the practical 

limits of what is possible using existing 

technology. Nonetheless, the industry 

continues to pursue increased efficiencies and new innovations that will further enhance sustainability.

n Pulp and paper mill air emissions, 

since 1995, have been substantially reduced. These reductions continued in 

2008. Compared to 2006, sulfur dioxide 

releases decreased 14.6 percent, nitrogen oxides were unchanged, and total 

reduced sulfur (TRS) releases were reduced 18.6 percent.

n At wood products facilities, nitrogen 

oxide releases (per 1000 board feet of 

product produced) have been reduced 

by 29 percent since 2000. However, between 2006 and 2008, these releases increased by 12.8 percent, reflecting a 39 

percent reduction in collective AF&PA 

member production levels for this period due to the sustained drop in housing 

market starts.

n Pulp and paper mill effluent discharge 

volumes (per ton of product produced) 

have decreased 20 percent since 1995 

but were largely unchanged since 2006. 

Since 1995, total suspended solids (TSS) 

and biochemical oxygen demand (BOD) 

effluent release rates have been reduced 

41.1 and 29.4 percent, respectively, and 

remained largely unchanged from 2006 

levels.

n Pulp and paper mill releases of chlorinated compounds have been virtually 

eliminated. Adsorbable organic halides 

(AOX), chlorine, and chlorine dioxide 

releases remain at very low levels. Chloroform releases, also extremely low, decreased 34.7 percent between 2006 and 

2008.

n Aggressive reduction in pulp and paper mill U.S. EPA Toxic Release Inventory (TRI) releases for the core chemicals continued between 2006 and 2008, 

down another 14 percent. Methanol releases, the compound that made up 62 

percent of core chemical releases, were 

reduced 22 percent since 2006. At wood 

products facilities, methanol releases 

have decreased 37 percent compared to 

2006. Wood products formaldehyde re7

Pulp and Paper Mill Emissions Reductions

lbs. per ton SO2 /NOx

lbs. per ton TRS
leases were reduced 26 percent between 

2006 and 2008.

n Pulp and paper mill process residual 

generation rates have been reduced 18.6 

percent since 1995 and were essentially 

unchanged between 2006 and 2008. 

Forty-five percent of pulp and paper mill 

residuals and 96 percent of wood products facilities residuals were beneficially 

utilized in 2008.

n All AF&PA members have once again 

demonstrated adherence to the Association’s EHS Principles. They have reported pursuit of the principles through 

such practices as maintaining written 

environmental protection, health, and 

safety policies; accountability through 

reporting of environmental, health, and 

safety matters to corporate boards of directors; and utilization of environmental 

and safety measure compliance audits.

4. Generating and conserving

energy and materials

Energy savings and the use of renewable 

fuels have been fundamental objectives 

of the industry for decades. The forest 

products industry has been tracking reductions in total energy, purchased energy, and fossil fuel use since the early 

1970s and has taken a leadership role in 

pursuit of energy efficiency and reductions in fossil fuel use. 

n AF&PA member pulp and paper mills 

are largely energy self-sufficient, and 

some mills supply excess energy to the 

electric utility grid. Since 1990, energy 

use per ton of production has been reduced by 8.2 percent, and in 2008, total energy use per ton of production was 

nearly the same as in 2006.

n Since 1990, purchased energy and 

fossil fuel use per ton of production was 

reduced by 26 percent. The percent of 

total energy supplied by purchased and 

fossil fuel has been reduced during each 

reporting period since 1972 and was essentially unchanged in 2008 compared 

to 2006.

n The forest products industry, with its 

reliance on renewable biomass energy, 

leads all other manufacturing industries 

in the use of renewable fuels. In 2008, 

65 percent of the energy needed to operate member pulp and paper mills was 

produced from renewable fuels. At wood 

products facilities, renewable fuels produced 73.5 percent of needed energy. 

U.S. Department of Energy data shows 

that pulp and paper mills and wood products facilities, together, produced 94 percent of the renewable fuel energy generated by all manufacturing facilities in all 

sectors. 

n Virtually all AF&PA member facilities that generate electricity on-site do so 

using cogeneration technology. In 2008, 

the forest products industry surpassed 

the chemical industry and became the 

leader among all manufacturing sectors 

in the use of cogeneration technology, 

generating 37 percent of the total energy 

produced by cogeneration capable systems within all manufacturing sectors. 

5. Reducing greenhouse gases

The forest products industry provides 

valuable solutions to climate change 

issues by carefully managing private 

forests that absorb carbon dioxide, reducing emissions from manufacturing 

processes, manufacturing products that 

store carbon and are made from renewable and recyclable raw materials, and 

generating and using renewable energy.

Emissions Intensity

AF&PA members are committed to reducing greenhouse gas emissions intensity 12 percent by 2012 (expressed in 

metric tons of CO2 per ton of product), 

compared to a year 2000 baseline. This 

includes both direct emissions (those 

generated at AF&PA member manufac2008 Wood Products Facility Energy Sources

 Percent of Total BTUs

8
9

turing facilities) and indirect emissions 

(those associated with purchased electricity). AF&PA members made progress 

towards this goal; in fact, they had exceeded it in 2006, but the data presented 

in this report indicate that it was a challenge to maintain this progress in 2008. 

Pulp and paper mills maintained their 

improvement in 2008. The greenhouse 

gas emissions intensity for wood products facilities increased in 2008, however, due to lower operating rates resulting from the sustained drop in housing 

market starts, product mix changes, and 

reduced wood products membership in 

AF&PA. Overall, the greenhouse gas intensity for the industry increased slightly 

from 2006. 

n At pulp and paper mills, the combined 

direct and indirect emissions intensity 

rate for 2008 was 14.1 percent lower 

than in 2000 and 1.3 percent lower than 

in 2006.

n The share of energy-intensive categories of wood products produced by 

AF&PA membership increased substantially in 2008. Furthermore, government 

regulations required air pollution controls that operate on natural gas and release additional greenhouse gases. As a 

result, the 2008 total direct and indirect 

emissions intensity for member wood 

products facilities increased 26.8 percent 

since 2000 and 32.7 percent compared to 

2006.

n Combined, AF&PA member greenhouse gas intensity decreased 4.3 percent 

since 2000 but increased 10.8 percent 

compared to 2006. Almost 90 percent 

of the increase from 2006 can be attributed to the changes in the wood products 

share of total membership production.

Absolute Emissions Reductions

On an absolute basis, both direct and indirect greenhouse gas emissions at member pulp and paper and wood products 

industry facilities have decreased. 

n Combined, pulp and paper mill and 

wood product facility direct greenhouse 

gas emissions have been decreased 36.6 

percent, 4.2 percent since 2006.

n Combined, pulp and paper mill and 

wood product facility indirect greenhouse gas emissions have been decreased 

4.1 percent since 2000, with a 0.4 percent decrease since 2006. 

n Total direct and indirect emissions 

from AF&PA member facilities amounted to 64.5 million metric tons of CO2

equivalents in 2008. This is a 26.7 percent reduction in emissions from member facilities compared to 2000. Nearly 

40 percent of this reduction can be attributed to efficiency improvements and 

reduced fossil fuel use.

The Carbon Cycle

n Growing forests, the source of the basic raw material for the industry, naturally absorb carbon dioxide from the atmosphere and store it as carbon in trees, 

and forest products contain the carbon 

absorbed from the atmosphere. In 2008, 

because of the reduction in wood products facility production, the quantity 

of CO2 equivalents contained in forest 

products decreased by 29 percent compared to 2006.

n Paper in landfills decomposes and 

produces methane gas, a powerful greenMember Greenhouse Gas Emissions

(Total Direct and Indirect)

Million Metric Tons CO2

Tons CO2 per Ton Product

An AF&PA member’s design and construction of an environmentally 

clean and energy efficient greenfield sawmill is expected to produce 

annual energy savings of $293,432 for that company. The project 

took 18 months and will reduce greenhouse gas emissions per board 

foot of production. Total CO2 emission savings are expected to be 

1,200 metric tons per year. The mill worked with local utilities on 

incentives to use state-of-the-art technologies. It will require less 

energy and raw material to produce finished products.
house gas. In 2008, the landfill methane 

avoided emissions were 20.2 million 

metric tons of CO2 equivalents. Between 

2000 and 2006, the greenhouse gas emissions that have been avoided through 

paper recovery and removal from the 

landfill waste stream have amounted to 

between 21 and 24 million metric tons of 

CO2 equivalents annually. 

Advantages of Wood as a Building 

Product

As a building material, wood requires 

less energy to produce, transport, construct, and maintain than available alternatives. Less energy use translates into 

fewer greenhouse gas emissions. When 

comparing environmental impacts of 

a typical wood-frame house to similar 

structures constructed of steel or concrete over a 20 year period:

n The house built of steel would emit 26 

percent more greenhouse gases than the 

comparable wood-based home.

n The house made from concrete would 

emit 31 percent more greenhouse gases 

than the comparable wood-based home.

6. Benefiting the communities,

employees, and families

everywhere our products

are made and sold

Economic Contributions

The forest products industry, though 

challenged by recent economic conditions, remains a significant and important contributor to U.S. gross domestic 

product (GDP). 

n The industry accounts for approximately five percent of U.S. manufacturing GDP; is among the top 10 manufacturing employers in 48 states; and 

employs nearly 900,000 people earning 

$50 billion annually. In addition, industry companies produce $175 billion in 

products annually.

n Forest product industry economic 

performance is a key concern as recovery from the recession continues. This 

market downturn has severely affected 

forest products industry supported communities where, since 2006, more than 

390,000 employees have lost jobs, including 124,000 in 2009 alone. In 2009, 

paper and market pulp production levels 

were 12.5 percent below those of 1995. 

n Housing starts, which hovered around 

2 million units a year in 2004 and 2005, 

had declined to 554,000 in 2009, their 

lowest level in more than a half century. 

Starts have been edging higher since late 

2009, but the rebound has been gradual 

by historical standards. Reflecting this 

trend, U.S. production of wood products 

declined 39% between 2006 and 2009.

n Although at reduced rates, companies 

have continued to make investments in 

new processes and equipment. Paper 

mill and allied product company capital 

expenditures were $7.6 billion in 2006 

and $6.3 billion in 2008. 

n Exports continue to be an important 

element in U.S. forest products revenue 

streams. From 2002 to 2008, forest prod10
11

ucts exports grew by almost 50 percent, 

from $18.2 billion to $27.1 billion. Exports dropped by 14.4 percent in 2009 

but have risen by 19.5 percent year-overyear in the first two months of 2010. 

Social Contributions

AF&PA members make substantial contributions to the social well-being of the 

communities in which they operate. 

n They provide highly skilled jobs paying commensurate wages that include 

important benefits such as worker health 

care. They support local community 

programs and those benefiting society 

at the state, national, and international 

levels. The forest areas from which the 

industry’s raw materials are obtained are 

sustainably managed to provide important ecosystem services and aesthetic 

benefits.

n Safety programs at 84 pulp and paper mills were enrolled in the Department of Commerce’s prestigious OSHA 

worker safety Voluntary Protection Program (VPP). Sixty-seven wood products 

facility programs were also enrolled. 

Compared to 2006, pulp and paper mill 

worker accident and illness total case incidence rates were 16.6 percent lower in 

2008. Lost work cases were 12.6 percent 

lower. At wood products facilities, total 

case incidence rates were 19.4 percent 

lower, but lost work cases were slightly 

higher by 3.4 percent. In 2008, there were 

six fatalities at member pulp and paper 

mills, and one fatality at wood products 

facilities. Member company and governManufacturer Contribution to GDP

(2007 U.S. Commerce Department Data)

Billions U.S. Dollars – Value Added Contribution to GDP
ment agency personnel conduct detailed 

investigations after any fatality.

n AF&PA members are active in their 

communities. Eighty-seven percent reported they participated in community 

outreach activities, including philanthropic support for environmental programs or groups and serving on community advisory groups. Sixty-four percent 

aided school education programs, while 

74 percent supported community social 

programs.

n AF&PA members actively pursued 

public engagement and reporting in 

2008. Ninety-five percent of members 

engaged in public policy development 

activities. Seventy-five percent met with 

public officials. Ninety-seven percent of 

members conducted employee involvement programs.

Sustainability and the

Road to the Future

AF&PA members are pursuing their 

commitment to sustainability through 

innovation and environmental stewardship. To stay on track for continuous 

improvement, they continue to support 

research and development efforts within 

their companies, industry research organizations, academic institutions, and cooperative partnerships with governments 

and stakeholders.

12

Member Pulp and Paper Mill

Occupational Injuries and Illnesses

Incidence Rate
REPORTING SUSTAINABILITY PROGRESS
1. Sustainable Use 

of Renewable 

Resources

Sustainable Forestry and

Procurement

AF&PA members have shown leadership 

in development of and participation in 

forest certification programs. All AF&PA 

members owning forestland must conform to one or more of the major credible certification systems in the United 

States. These include: the seven regional 

forest management standards developed 

for the U.S. by the Forest Stewardship 

Council (FSC); the Sustainable Forestry 

Initiative® (SFI®) program; and systems 

endorsed by the international Program 

for the Endorsement of Forest Certification (PEFC). In North America, PEFC 

has endorsed the Canadian Standards 

Association program and the American 

Tree Farm System®, as well as SFI.

Currently, all AF&PA members owning forestland participate in the SFI 

program. The SFI provides a set of forestry principles designed to meet present 

needs without compromising the future 

of forests and forest products. The land 

stewardship ethic required by these principles integrates reforestation, nurturing, 

and harvesting of trees for useful products with the conservation of soil, air and 

water resources, protection of wildlife 

and fish habitat, and maintenance of forest aesthetics.

Across North America, close to 200 

million acres/80 million hectares are 

certified to the SFI forest management 

standard. This makes the SFI standard 

the largest single standard in the world. 

The SFI program is directed by an independent non-profit organization, the Sustainable Forestry Initiative Inc., which is 

governed by a multi-stakeholder Board 

of Directors comprised of 18 members. 

The Board has equal representation from 

environmental, economic, and social 

sectors.

In addition, all AF&PA members 

sourcing fiber directly from the forest 

are required to adhere to the organization’s Sustainable Procurement Principles. These principles require support 

of programs that supply regionally appropriate information and services to 

forest landowners regarding best management practices; reforestation; afforestation (conversion of non-forested 

land to forests); visual quality management; management of harvest residue; 

conservation of critical wildlife habitat; 

threatened and endangered species; and 

Forests with Exceptional Value. Among 

other things, these principles encourage 

the use of qualified resource professionals and loggers when applying sustainable forest management principles and 

encourage programs for the purchase of 

raw material from recognized qualified 

logging professionals.

To comply with this procurement policy, most members opt to participate in 

fiber source requirements, unique to the 

SFI program, that provide specific objectives addressing the above elements. 

While both the PEFC and FSC protocols 

include chain-of-custody elements that 

track the flow of fiber from certified lands 

to end markets, neither protocol provides 

objectives that address the vast majority 

of forested acres which are not certified. 

The SFI protocol also includes chain-ofcustody elements. AF&PA members participate in one or a combination of these 

programs. In doing so, they fulfill their 

commitment to the AF&PA Sustainable 

Procurement Principles.

AF&PA member companies in Florida, along with the Florida 

Division of Forestry, host a Florida Forests Teachers Tour to give 

them the opportunity to see demonstrations of harvest operations, 

the papermaking process and a variety of other forestry- related 

activities that underscore the value of sustainable forestry.

REPORTING SUSTAINABILITY PROGRESS

14
15

2. Leading the 

Way in Recycling

Record High Recovery

In 2009, an impressive 63.4 percent 

of the paper consumed in the U.S. was 

recovered for recycling. This achievement is thanks to industry leadership and 

the ongoing commitment of millions of 

Americans who recycle at home, school, 

and work on a daily basis. 

Leading the way, the paper industry 

has set and achieved incremental recovery goals since 1990. In the 20 years 

since, recovery has doubled, surpassing 

the industry’s most recent 60 percent 

goal three years ahead of schedule.

Paper recovery removes a valuable resource from the waste stream, and uses it 

to produce new paper products. Further, 

recycling saves landfill space, thereby 

eliminating associated greenhouse gas 

emissions. 

AF&PA Recycling Incentive

Programs

In order to achieve its mission of ensuring 

a continuing and expanding domestic recovered fiber supply to help meet global 

demand, AF&PA engages in a variety of 

programs and partnerships. To help educate students and their families about the 

importance of paper recycling, programs 

carried out in conjunction with Scholastic Books and the Keep America Beautiful organization deliver curricula straight 

to the classroom. In addition, AF&PA is 

engaged with the Environmental Paper 

Network, the Environmental Protection 

Agency, and a variety of stakeholders 

that also encourage increased paper recovery.

Further, the annual AF&PA Recycling 

Awards recognize outstanding community, business, and school paper recycling 

programs. Together, the 2010 award 

winners – the city of Virginia Beach, 

Virginia, Continental Airlines, and the 

Parkway School District in Chesterfield, 

Missouri – recovered more than 27,000 

tons of paper and paper-based packaging 

for recycling in 2009. 

n Developed in 1997, the Virginia Beach 

recycling program includes a customized, 

voluntary, single-stream, automated system that services 124,000 residents, 94 

City schools, and 106 municipal buildings, along with five public-use drop-off 

sites. Thanks to a variety of education 

and outreach efforts, the City of Virginia Beach recovered nearly 23,800 tons 

of paper and paper-based packaging in 

2009 – more than 68 percent of all recyclables collected.

n Thanks to a renewed commitment to 

the environment in recent years, Continental Airlines has significantly increased the effectiveness of its recycling 

program by maximizing cost-effective, 

manageable, and sustainable collection 

efforts. Continental has recovered 6,000 

tons of paper from its aircraft, hubs, offices and supporting facilities in recent 

years.

n The Parkway School District, serving 

18,000 students in 29 buildings, started 

their recycling program after several elementary students requested of the Board 

of Education that they be better environmental stewards. The results are impressive, including the recovery of more than 

63.4%

Paper and Paperboard Recovery Rate

(% of annual consumption recovered for recycling)

REPORTING SUSTAINABILITY PROGRESS

The paper industry has set and achieved incremental recovery goals 

since 1990. In the 20 years since, recovery has doubled, surpassing 

the industry’s most recent 60 percent goal three years ahead of 

schedule.
1,031 tons of newspaper, magazines, 

catalogs, direct mail, office paper, envelopes, and brochures, along with more 

than 138 tons of paper-based packaging 

in 2009. 

 For details on the award-winning 

programs, case studies of previous winners, free downloadable classroom materials, statistics, interactive features and 

more, visit www.paperrecycles.org.

Additional Benefits of Recycling

In addition to providing an important 

fiber source for papermaking, there 

are other important benefits from the 

AF&PA paper recovery efforts. Paper 

recycling is an important element in the 

effort to manage greenhouse gas emissions. Keeping paper out of landfills, 

where it would otherwise decay, reduces 

the production of methane, a greenhouse 

gas. Paper recovery diverts these paper 

products from the landfill waste stream. 

The use of recycled fiber also reduces 

the energy, and associated greenhouse 

gas emissions, required to manufacture a 

number of paper products. 

For the latest AF&PA information regarding recycling programs 

and resources visit paperrecycles.org

16
17

3. Reducing Our 

Environmental 

Footprint

The forest products industry has worked 

for decades to reduce impacts on the environment. By striving for sustainable 

use of natural resources today, members 

seek the same opportunities for future 

generations. AF&PA’s EHS reporting 

and tracking system shows how the industry has significantly reduced discharges to both air and water while also 

extensively decreasing the generation 

of waste. Modernization of manufacturing processes and expanded pollution 

control and prevention measures have 

produced these results. And, indeed, the 

job is not done. Having already achieved 

significant reductions in releases, recent 

incremental survey-to-survey reductions 

in some releases have slowed. In addition, survey-to-survey changes of a few 

percentage points, up or down, may not 

differ from normal variability. However, 

AF&PA members are looking forward. 

Additional gains must, and will, come 

from new technological advances and 

more aggressive capital expenditures.

Pulp and Paper Mill

Air Emissions Releases

Improved process controls, installation 

of new air pollution control equipment 

and the use of biomass and low sulfur 

fuels have resulted in substantial reductions in air emissions from member pulp 

and paper mills during the past several 

decades. This progress has been made in 

all phases of mill operations from pulping, bleaching and chemical recovery to 

power generation operations. AF&PA’s 

tracking of air emissions reduction progress shows that:

n Sulfur dioxide (SO2) releases have 

been reduced by 36.7 percent since 1995. 

Between 2006 and 2008, these releases 

decreased by 14.6 percent. Sulfur dioxide releases were 6.08 lbs. per ton of 

product produced in 2008 vs. 7.12 lbs. 

per ton in 2006.

n Since 1995, nitrogen oxide (NOX) 

releases have been reduced by 26.5 percent. Releases in 2008 were unchanged 

from those in 2006, 4.6 pounds per ton 

of product produced.

n Total Reduced Sulfur (TRS) compound releases have been reduced by 

63.5 percent since 1995. Significant reductions continued between 2006 and 

Pulp and Paper Mill Emissions Reductions

lbs. per ton SO2 /NOx

lbs. per ton TRS

REPORTING SUSTAINABILITY PROGRESS

Member Wood Products Facility NOx Reductions

0

5

10

15

20

25

1999 2000 2002 2006 2008

lbs. per MCF
2008, 0.219 pounds per ton in 2008 compared to 0.269 lbs. per ton in 2006, an 

18.6 percent reduction.

Wood Product Facility

Air Emissions Releases

AF&PA has been tracking wood products 

facility air emissions releases since 1999. 

Improved boiler operations and modernized equipment have reduced emissions.

n Since 2000, nitrogen oxide (NOX) 

releases at member wood products facilities have decreased 29 percent. NOX

releases from these member operations 

increased by 14.3 percent, from 13.3 to 

15.2 lbs. per thousand cubic feet (MCF) 

of product produced, between 2006 and 

2008. Likely causes for the increase are a 

combination of reduced production levels due to the recent economic downturn 

and the start-up at some facilities of new 

government required air pollution controls that operate on natural gas where 

NOX is a by-product. Wood products facilities do not produce significant SO2 or 

any TRS releases.

Pulp and Paper Mill Water

Discharges

Pulp and paper mills were among the 

first industries to develop and invest in 

effluent treatment technologies. Primary 

treatment systems were in common use 

in the 1950s. By the early 1970s, fully 

operational primary and secondary effluent treatment systems were in use at 

all U.S. mills – an accomplishment that 

mills in other countries would not match 

for decades.

AF&PA water discharge tracking data 

shows:

n The volume of water discharged from 

pulp and paper mills has decreased 20.5 

percent since 1995. Advances in mill 

process technologies, enhanced water 

recycling and reuse practices, and active conservation efforts have reduced 

the amount of water needed to produce 

a ton of product. In 2008, largely due to 

decreases in production, the average water discharge volume from member mills 

was 2.1 percent higher (11.4 thousand 

gallons per ton of product) than in 2006 

(11.1 thousand gallons per ton). 

n Total suspended solids (TSS) are fibrous and finely divided materials, such 

as clay particles, that are not retained in 

pulp and papermaking processes. The 

vast majority of this material (80 to more 

than 90 percent) is removed from the effluent stream by mill treatment systems. 

Advances in mill processes and effluent treatment practices have continued 

to reduce the amount of this material in 

mill water discharges. Since 1995, TSS 

releases have been reduced by 41.1 percent. Member mill TSS releases per ton 

of product produced were largely unchanged at 3.6 pounds per ton in 2008 

versus 3.5 pounds per ton in 2006.

n Effluent treatment systems developed 

and used by pulp and paper mills are 

very effective at removing biochemical 

oxygen demand (BOD), the organic contaminants in effluents that can deplete 

oxygen needed to support aquatic organisms in receiving streams. Mills continue 

to optimize BOD removal performance 

from existing systems and evaluate alternative, high efficiency, treatment technologies. Since 1995, member average 

BOD releases have been reduced 29.4 

percent. Member mill BOD releases per 

ton of product produced were unchanged 

An AF&PA member pulp and paper mill has used a collaborative 

approach with stakeholders to implement a river restoration 

plan. Process modifications improved effluent color, reduced BOD 

releases, and allowed for enhanced river designated uses. 

Pulp and Paper Mill Water Discharge Reductions

Quantity per ton of production

18
19

from 2006 to 2008, 2.6 pounds per ton.

Pulp and Paper Mill Chemical

Compound Release Reductions

Chlorinated compound releases from 

bleached kraft pulp mills have been virtually eliminated through the use of Elemental Chlorine Free (ECF) bleaching 

processes and pulp mill air emission control systems. 

n Since 1995, releases of adsorbable 

organic halides (AOX) in bleached pulp 

and paper mill effluents have been reduced by 80.4 percent. In 2008, AOX 

releases were just 0.198 kilograms per 

metric ton of unbleached pulp produced, 

two percent lower than releases in 2006, 

0.202 kilograms per metric ton.

Industry reports chemical releases to 

the U.S. EPA Toxic Release Inventory 

(TRI) database annually. Tracking release quantities for chlorine compounds 

provides important trend information regarding these substances.

n Chlorine releases, primarily from air 

emission sources, at all reporting pulp 

and paper mills have been decreased by 

91.6 percent since 1995. Chlorine releases in 2008 were essentially the same as in 

2006, just 0.3 percent lower.1

n Chlorine dioxide releases have decreased 71.1 percent since 1995. Compared to 2006, chlorine dioxide releases 

decreased 3.6 percent in 2008.

n Chloroform releases were reduced 

97.8 percent since 1995. Between 2006 

and 2008, chloroform releases decreased 

by 34.7 percent.

Pulp and Paper Mill TRI

Chemical Releases

Periodically, U.S. EPA changes the list of 

chemicals for which release reports must 

be filed. When this occurs, new chemicals are added, some substances can 

be removed from the list, or reporting 

thresholds are modified. A list of Core 

Chemicals, first established in 1988, 

remains relatively constant. Therefore, 

data regarding the release of these compounds is used to compare annual reporting trends. Since 1988, TRI substance 

releases have steadily declined at both 

pulp and paper mills and wood products 

manufacturing facilities.

n Pulp and paper mill TRI core chemical 

releases have decreased 31 percent since 

1995. Between 2006 and 2008, these releases decreased 14 percent. These reducMember Pulp Mill AOX Release Reductions

AOX per kg/tonne of unbleached 

pulp produced

Pulp and Paper Mill Chlorine Compound Release Reductions

(U.S. EPA data)

Million lbs.

1 A corrected value for chlorine releases submitted to U.S. EPA by one mill has been used in 

these calculations.
tions are the result of improved pollution 

control equipment, process changes, raw 

material changes, and other pollution 

prevention measures.

n In 2008, methanol releases amounted 

to 62 percent of the total core chemical releases. Releases of methanol have 

been substantially reduced since the TRI 

reporting program began. Since 1995, 

methanol releases have decreased 39 

percent. Between 2006 and 2008, methanol releases decreased 22 percent. Air 

emissions control modifications at pulp 

mill bleach plants are largely responsible 

for these reductions.

Wood Products Facility

Chemical Compound Release

Reductions

Pollution control equipment installations and changes in materials used in 

the manufacture of wood products have 

produced reductions in TRI chemical releases at wood products manufacturing 

facilities. The data needed to track these 

reductions became available starting in 

1999. New U.S. EPA Maximum Available Control Technology (MACT) standards became effective in 2007–2008 

leading to significant reductions in plywood and composite wood panel facility 

hazardous air pollutant emissions, including methanol and formaldehyde. In 

2008, methanol and formaldehyde made 

up 77 percent of wood product facility 

core chemical releases. 

n Methanol releases have been reduced 

by 42 percent since 1999. Between 2006 

and 2008, methanol releases decreased 

by 37 percent. 

n Formaldehyde releases have been reduced by 40 percent since 1999. Between 

2006 and 2008, releases of formaldehyde 

decreased by 26 percent. 

Pulp and Paper Mill Core Chemical Release Reductions

(U.S. EPA data)

Million lbs.

Pulp and Paper Mill Methanol Release Reductions

(U.S. EPA data)

Million lbs.

Wood Products TRI Compound Release Reductions

(U.S. EPA data)

Million lbs.

20
21

Pulp and Paper Mill Residuals

Management

AF&PA members work to reduce manufacturing process residuals that must be 

disposed of in some fashion.

n Since 1995, pulp and paper mills have 

reduced the total process residuals generation rates in pounds per ton of product 

by 18.6 percent

n Compared to 2006, AF&PA member 

paper mill total process residuals generation rates in 2008 were essentially unchanged at 250 pounds per ton of product in 2006 versus 259 pounds per ton 

in 2008. 

n Since 1995, pulp and paper mill effluent treatment plant residuals generation 

rates in pounds per ton of product have 

been reduced by 26.4 percent. Between 

2006 and 2008, effluent treatment residuals generation rates were essentially 

unchanged, 95 and 92 pounds per ton of 

product produced, respectively.

AF&PA member pulp and paper mills 

seek beneficial uses for process residuals.

n

In 2008, 45 percent of generated residuals were beneficially reused. Ten percent 

was burned for energy recovery, 13 percent applied to land as soil amendments, 

and 22 percent beneficially used in other 

ways. The remaining 55 percent was 

landfilled or placed in dewatering lagoons.

Wood Products Facility

Residuals Management

AF&PA member wood products facilities 

utilized 96 percent of generated process 

residuals in 2008.

n Thirty-six percent of wood products 

facility residuals were utilized in other 

products by off-site facilities. Fifty-seven percent were used for other beneficial 

uses such as energy recovery, landscaping materials, or animal bedding. Three 

percent was applied to land and less than 

one percent was disposed of by burning.

Adherence to Mandatory AF&PA

EHS Principles

All AF&PA members demonstrate adherence to the mandatory EHS Principles in 

maintaining their environmental performance. In 2008:

n Ninety-three percent reported having 

written environmental policies while 

95 percent also have written health and 

safety policies.

n Seventy-seven percent of companies 

also reported having written policies on 

Member Pulp and Paper Mill Total Residuals Reductions

lbs. per ton

Pulp and Paper Mill

Residuals Utilization

Wood Products Facility

Residuals Utilization
responding to environmental, health and 

safety incidents.

n A majority of companies reviewed 

capital improvement projects and product designs for environmental performance implications.

n Ninety percent of the companies conducted accountability and management 

reporting activities. These include reporting on EHS performance to their Board 

of Directors or Board EHS Committee.

n Eighty-two percent of members reported maintaining an environmental audit program.

Pulp and Paper Mill Wastewater Treatment Plant

Residuals Reductions

lbs. per ton

While pulp and paper companies encourage recycling, they are also 

good recyclers themselves. For example, one mill recently outlined 

its program that now recycles metals, scrap wood, batteries, used 

oil, aerosol cans, fluorescent light bulbs and antifreeze, in addition 

to waste paper and fiber.

22
23

4. Generating 

and Conserving 

Energy and 

Materials

While all manufacturing sectors and 

public utilities are currently focused on 

conserving energy and exploring the potential for using renewable fuels, these 

are not new concepts to the forest products industry. Energy savings and the use 

of renewable fuels have been fundamental objectives of the industry for decades. 

The forest products industry has been 

tracking reductions in total energy, purchased energy, and fossil fuel use since 

the early 1970s and has taken a leadership role in pursuit of these efficiencies 

and reductions in fossil fuel use. 

Energy Use and Self-Sufficiency

AF&PA member pulp and paper mills 

are largely energy self-sufficient. Some 

mills supply excess energy to the electric 

utility grid. These mills have also significantly reduced their total amount of energy needed per ton of production over 

the last four decades. 

n Since 1990, energy use per ton of 

production has been reduced by 8.2 percent. 

n In 2008, total energy use per ton of 

production was nearly the same as in 

2006, 24.41 million BTU per ton of production (2008) versus 24.03 (2006).

Fossil Fuel Use Reductions

Use of purchased energy and fossil fuels 

has continued to decline at pulp and paper 

mills.

n Since 1990, purchased energy and fossil fuel use per ton of production was reduced by 26 percent. The percent of total 

energy supplied by purchased and fossil 

fuel has been reduced during each reporting period since 1972.

n Compared to 2006, purchased and fossil fuel use was essentially unchanged in 

2008, 8.51 million BTU per ton of production in 2006 vs. 8.52 in 2008.

REPORTING SUSTAINABILITY PROGRESS

2008 Pulp and Paper Mill Energy Sources

Percent of Total

Pulp and Paper Mill Purchased Energy and Fossil Fuel Use

Percent of total
n In 2008, wood products facilities relied on renewable biomass fuels to provide 73.5 percent of the energy required 

to produce their products. 

Renewable Fuels Use

The forest products industry, with its reliance on renewable biomass energy, leads 

all other manufacturing industries in the 

use of renewable fuels.

n Member pulp and paper mills generated 65 percent of their energy needs from 

renewable fuels in 2008. At wood products facilities, renewable fuels produced 

73.5 percent of needed energy.

n In 2008, U.S. Department of Energy 

data shows that, pulp and paper mills 

and wood products facilities, together, 

produced 94 percent of the renewable 

fuel energy generated by all manufacturing facilities in all sectors. All of these 

renewable fuels are derived from wood. 

Pulp and paper mills produced 88 percent 

of these, while wood products facilities 

produced six percent. All other manufacturers in all other sectors produced just 

six percent.

Cogeneration

Virtually all AF&PA member facilities 

that generate electricity on-site do so using cogeneration technology. In 2008, 

the forest products industry became the 

leader among all manufacturing sectors 

in the use of cogeneration technology. 

Cogenerated electricity is produced by 

using steam extracted from the exhaust 

side of electrical generators for heat in 

either the manufacturing processes or 

for space heating. In non-cogenerating 

systems, all of this exhaust steam is 

condensed by cooling towers or heat exchangers, with the heat energy not beneficially used.

 In 2008, forest products facilities 

generated 37 percent of the total energy 

produced by cogeneration capable systems within all manufacturing sectors. 

No other sector matched this performance. Previously, only the chemical 

sector had surpassed the forest products 

industry in production of energy from 

these systems.

Conserving Materials and

Pollution Prevention

AF&PA members are constantly working to improve efficiencies and product 

design to reduce energy consumption, 

water use and effluent releases, and the 

generation of process residuals. For ex2008 Wood Products Facility Energy Sources

 Percent of Total BTUs

Industry Use of Cogeneration

Electricity Technology

(2008 U.S. DOE data)

Manufacturing Sector Derived

Renewable Fuel Use

(2008 U.S. DOE data)

24
25

ample, increases in product strength and, 

in some cases, product weight reductions 

have allowed members to produce more 

product with less fiber while reducing 

manufacturing wastes and energy requirements, including fuel needed to 

transport materials. In 2008:

n Seventy-five percent of members reported pollution prevention progress, 

and 64 percent participated in voluntary 

government EHS programs. Significantly, 41 percent of members received EHS 

honors or awards in 2008.

A site audit and resulting implementation plan have enabled one 

company to reduce site utilities and chemical costs by more than 

10 percent, or $2.2 million annually. The plan used best practices 

throughout the facility and implemented an audit system for 

continuous improvement. By using only one power boiler instead 

of two 69 percent of the time, SO2 and NOx emissions have been 

reduced along with costs.

Member Pollution Prevention Progress

Percent of Members
5. Reducing 

Greenhouse Gases

The forest products industry provides 

valuable solutions to climate change 

concerns by carefully managing private 

forests that absorb carbon dioxide, reducing emissions from manufacturing 

processes, manufacturing products that 

store carbon and are made from renewable and recyclable raw materials, and 

generating and using renewable energy. 

AF&PA members have made a significant commitment to reduce greenhouse 

gas emissions. Collectively, they have 

pledged to reduce their greenhouse gas 

emissions intensity (metric tons of CO2

equivalents per metric ton of production) 

12 percent by 2012, using year 2000 as 

a baseline. Tracking and accounting for 

these emissions requires tabulating both 

emissions that occur directly at AF&PA 

member manufacturing facilities, as well 

as indirect emissions associated with 

purchased electricity from off-site power 

plants. Quantities of pulp, paper, and the 

several different types of wood products 

manufactured at member mills are combined, expressed in tons, and used to calculate the AF&PA member total releases 

on a per ton of product (intensity) basis.

AF&PA members made good progress towards the above goal; in fact, they 

had exceeded the total in 2006. However, 

the data presented in this report indicated 

that it was a challenge to maintain progress in 2008. This is primarily due to the 

fact that wood products represented a 

much smaller share of the total AF&PA 

member production than in previous 

years. Since wood products are a lot less 

energy intensive to produce than paper 

and paperboard, this structural change 

in membership mix had the effect of increasing greenhouse gas intensity of the 

aggregated membership for 2008, compared to previous years. Additionally, as 

explained below, the intensity for wood 

products also increased significantly in 

2008. These two factors combined to 

offset the continued progress at member 

pulp and paper mills.

Emissions Intensity Reductions

n The combined member pulp and paper 

mill greenhouse gas emissions intensity 

for direct and indirect emissions has decreased 14.1 percent since 2000 and 1.3 

percent between 2006 and 2008. 

n In 2006, the combined direct and indirect greenhouse gas emissions intensity 

for wood products facilities had decreased 

4.5 percent compared to 2000. The proportion of energy-intensity categories of 

wood products within AF&PA membership increased substantially in 2008. Significant changes in AF&PA membership 

as well as varying production decreases 

within these product categories resulted 

in an intensity increase. Furthermore, 

government regulations required installation of air pollution control devices 

that burn natural gas, thereby emitting 

additional greenhouse gases. As a result 

of all of these factors, the 2008 total direct and indirect emissions intensity rate 

for member wood products facilities increased 26.8 percent compared to 2000, 

and 32.7 percent compared to 2006.

n Overall, the 2008 greenhouse gas 

emissions intensity for AF&PA members 

was 4.3 percent less than it was in the 

baseline year 2000. Between 2000 and 

2006, the reduction was 13.7 percent. 

Compared to 2006, the overall member 

greenhouse gas intensity increased by 

10.8 percent in 2008. Almost 90 percent 

of the increase from 2000 can be attributed to the changes in wood products share 

of total membership production. 

Absolute Emissions Reductions

Direct greenhouse gas emissions, those 

generated at AF&PA member manufacturing facilities (both pulp and paper 

mills and wood products manufacturing 

plants) have decreased. Indirect emissions, those associated with purchased 

electricity, at wood products facilities 

have also decreased. Pulp and paper mill 

indirect emissions have remained relatively constant.

Direct Emissions:

n The 2008 pulp and paper mill data 

shows that direct greenhouse gas emissions have been reduced by 36.7 percent 

since 2000, four percent since 2006.

n Wood products facility direct greenhouse gas emissions have been reduced 

by 30.7 percent since 2000, 17.7 percent 

since 2006.

n Combined, pulp and paper mill and 

wood product facility direct greenhouse 

gas emissions have been decreased 36.6 

percent, 4.2 percent since 2006.

REPORTING SUSTAINABILITY PROGRESS

An AF&PA member company has reduced its natural gas use by 10 

percent and eliminated 15,700 tons of CO2 emissions by installing a 

condensing economizer on the cogeneration exhaust stack. This unit 

captures and reuses heat energy to preheat white water. An added 

benefit was increased production that resulted from piping changes 

that increased temperatures and increased paper machine drainage. 

26
27

Indirect Emissions:

n Pulp and paper mill indirect greenhouse gas emissions have increased 

slightly in 2008. These off-site emissions 

were 1.4 percent higher than in 2000 and 

increased 3.2 percent between 2006 and 

2008.

n Wood products facility indirect greenhouse gas emissions have been reduced 

by 29.6 percent since 2000, 19.5 percent 

since 2006.

n Combined, pulp and paper mill and 

wood product facility indirect greenhouse gas emissions have been decreased 

4.1 percent since 2000, with a 0.4 percent 

decrease since 2006.

n Total direct and indirect emissions 

from AF&PA member facilities amounted to 64.5 million metric tons of CO2

equivalents in 2008. This is a 26.7 percent reduction in emissions from member facilities compared to 2000. Nearly 

40 percent of this reduction can be attributed to efficiency improvements and 

reduced fossil fuel use.

The Carbon Cycle

The forest products industry is unique in 

that some significant aspects of nature’s 

carbon cycle are inherent in industry operations.

n Growing forests, the source of the basic raw material for the industry, naturally absorb carbon dioxide from the atmosphere and store it as carbon in trees. 

n The products produced by both pulp 

and paper mills and forest products facilities contain the carbon absorbed from the 

atmosphere. Forest products produced 

by member facilities contained between 

23.8 (2006) and 28.2 (2008) million metric tons of CO2 equivalents annually. In 

2008, because of the reduction in wood 

products facility production, this quantity decreased to 16.8 million metric tons 

of CO2 equivalents, a decrease of 29 percent compared to 2006.

n Paper recyling provides another important greenhouse gas reduction. When 

paper is recycled, it does not end up in 

landfills. Paper in landfills decomposes 

and produces methane gas, a powerful greenhouse gas. Between 2000 and 

2006, the greenhouse gas emissions that 

have been avoided through paper recovery and removal from the landfill waste 

stream have amounted to between 21 and 

24 million metric tons of CO2 equivalents annually. In 2008, the landfill methane avoided emissions were 20.2 million 

metric tons of CO2 equivalents.

Advantages of Wood as a

Building Product

As a building material, wood requires 

less energy to produce, transport, construct, and maintain than available alternatives. Less energy use translates into 

fewer greenhouse gas emissions. When 

comparing environmental impacts of 

a typical wood-frame house to similar 

structures constructed of steel or concrete over a 20 year period:

n The house built of steel would consume 17 percent more energy, emit 26 

percent more greenhouse gases, release 

14 percent more air pollutants, and generate 12 percent more water pollutants 

than the comparable wood-based home.

n The house made from concrete would 

consume 16 percent more energy, emit 

31 percent more greenhouse gases, and 

release 23 percent more pollutants into 

the air than the comparable wood-based 

home.

Member Greenhouse Gas Emissions

(Total Direct and Indirect)

Million Metric Tons CO2

Tons CO2 per Ton Product
6. Benefiting 

the Communities, 

Employees, 

and Families 

Everywhere Our 

Products are 

Made and Sold

Economic Performance

The three pillars of sustainability are 

all inter-related and dependent on each 

other. However, it cannot be overemphasized that sustainable economic performance of individual companies, and the 

industry at large, is essential for achieving sustainability.

The forest products industry contributed approximately five percent to 

the U.S. gross domestic product (GDP) 

in 2007, according to the most recent 

government statistics available. Among 

manufacturers, the forest products sector 

ranked eighth in contribution, just behind 

motor vehicles and transportation equipment and just ahead of the petroleum and 

plastic products sectors. The industry is 

among the top 10 manufacturing employers in 48 states where its nearly 900,000 

employees earn $50 billion annually in 

wages and salaries.

However, recent business and economic conditions have been challenging 

for AF&PA member companies. Since 

2006, more than 390,000 employees have 

Manufacturer Contribution to GDP

(2007 U.S. Commerce Department Data)

Billions U.S. Dollars – Value Added Contribution to GDP

REPORTING SUSTAINABILITY PROGRESS

28
29

lost their jobs including 124,000 in 2009 

alone. Breaking down this number:

n Logging: 7,200

n Paper and allied products: 33,500

n Wood products: 60,000

n Kitchen cabinets: 24,000

In 2008, 18 paper mills were permanently closed, shutting down 27 paper machines. Fourteen paper machines 

were permanently shut down at other 

facilities. As market conditions continued to deteriorate in 2009, 14 paper mills 

were permanently closed, shutting down 

16 machines. Further, 11 more machines 

ceased operations permanently at other 

paper mills.

Between 1995 and 2007, U.S. market 

pulp, paper and paperboard production 

fluctuated about a fairly stable long-term 

trend, rising just two percent over the entire period. However, in part due to the 

worldwide economic downturn, production declined five percent in 2008 and 10 

percent in 2009.

Housing starts, which hovered around 

2 million units a year in 2004 and 2005, 

had declined to 554,000 in 2009, their 

lowest level in more than a half century. 

Starts have been edging higher since late 

2009 but the rebound has been gradual 

by historical standards. Reflecting this 

trend, U.S. production of wood products 

declined 39% between 2006 and 2009, 

and some 220,000 wood products industry jobs were lost during this three-year 

period. Production leveled off during 

early 2010 but has not appreciably rebounded.

Paper and allied product capital expenditures during the past decade have 

varied between $8.5 billion in 1998 to 

$5.1 billion in 2004. Expenditures for 

new processes and equipment rebounded 

to $7.6 billion in 2006 but were $6.3 billion in 2008.

Companies are responding to the economic challenges through use of innovaU.S. Housing Starts

(U.S. Bureau of the Census Data)

Million Units

Paper, Paperboard and Market Pulp Production

(AF&PA Statistics)

Millions of Tons

U.S. Paper Mill and Allied Product Capital Expenditures

(U.S. Bureau of the Census: Annual Survey of Manufacturers)

4

6

8

10

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

Billion U.S. Dollars
tion and the pursuit of excellence to gain 

strength and improve economic performance in the years to come. Examples of 

these measures include:

n Paying down debt

n Reorganizing capital structures

n Pursuing growth strategies, especially 

in product lines with increasing demand

n Shifting capacities to more profitable, 

in-demand products

n Focusing on customers and anticipating or exceeding their needs

n Producing the best products in the industry’s global marketplace

U.S. Forest Products Exports

An important part of the U. S. forest 

products industry’s contribution to the 

economy is its exports. U.S. producers 

have improved their global competitiveness in the past decade, taking advantage 

of stronger growth in emerging economies and the more competitive currency 

after the value of the U.S. dollar reached 

a high point in the first quarter of 2002. 

From 2002 to 2008, forest products exports grew by almost 50 percent, from 

$18.2 billion to $27.1 billion. However, 

as the global recession took hold, U.S. 

forest products exports collapsed, dropping 14.4 percent in 2009. Forest products exports are rebounding, rising by 

21.4 percent year-over-year in the first 

two months of 2010.

Safety Program Recognition

AF&PA member safety programs meet 

high standards. Many mills have been 

enrolled in the Occupational Safety and 

Health Administration’s (OSHA) prestigious Voluntary Protection Program 

(VPP). Within VPP enrolled programs, 

management, labor, and OSHA establish 

cooperative relationships at workplaces 

that have implemented a comprehensive 

safety and health management system. 

Approval into the VPP is OSHA’s official recognition of the outstanding efforts of employers and employees who 

have achieved exemplary occupational 

safety and health records. In 2008:

n Safety programs at 84 AF&PA member pulp and paper facilities were enrolled in the VPP program, an increase of 

two since 2006 when 82 programs were 

recognized.

n Sixty-seven member wood products 

facility safety programs were enrolled in 

the VPP program. In 2006, 100 wood facility programs were registered. This reduction reflects the many wood product 

manufacturing facilities that either did 

not operate in part or all of 2008 or relinquished their AF&PA membership.

n Of the manufacturing industry safety 

programs recognized by the VPP program, only the chemical industry has 

more facilities registered than the forest 

products industry.

Safety Performance Reporting

AF&PA members track and report safety 

performance in accordance with OSHA 

standards. Occupational injury and illness incidents are recorded as any workrelated injury or illness involving medical treatment beyond first aid. Injury and 

U.S. Forest Products Exports

(U.S. Bureau of the Census Data)

Billion U.S. Dollars

Member VPP Enrolled Facilities

% Facilities Enrolled 

30
31

illness statistics are reported as incidence 

rates, defined as recordable incidents 

per 100 equivalent full-time workers. In 

2008: n At member pulp and paper mills, the 

total case incidence rate was 2.21, 16.6 

percent less than the 2006 rate of 2.65. 

The lost work case incidence rate was 

1.11, 12.6 percent less than the 2006 rate 

of 1.27. n Since 1996, pulp and paper mill total 

case incidence rates have been reduced 

by 61.9 percent. Lost work case inci-

dence rates have been reduced by 53.8 

percent. n At wood products facilities, the total 

case incidence rate was 2.00, 19.4 per-

cent lower than the 2006 rate of 2.48. 

The lost work case incidence rate was 

1.17, slightly higher than the 2006 rate 

of 1.13. n Since 1996, wood products facility 

total case incidence rates have been re-

duced by 75.3 percent. Lost work case 

incidence rates have been reduced by 

70.8 percent. n Six fatalities occurred at pulp and pa

-

per mills in 2008. One occurred at a wood 

products facility. Member company and 

government agency personnel conduct 

detailed investigations after any fatality. 

The results of these investigations serve 

as the basis for any necessary changes in 

operations. 

Public Engagement

and Reporting

AF&PA companies are engaged in com-

municating with the public in the com-

munities in which they operate. n Eighty-four percent of members re

-

ported to the public on environmental, 

health and safety performance in 2008. 

Some companies provided formal reports 

while more than half placed information 

on the internet.

Member Public Engagement and Reporting

Percent of Members

Member Wood Products Facility

Occupational Injuries and Illnesses

Incidence Rate

Member Pulp and Paper Mill

Occupational Injuries and Illnesses

Incidence Rate
n More than 20 percent held public 

meetings, and 13 percent provided facility tours.

Community Involvement

and Outreach

AF&PA members are active in their communities.

n Eighty-seven percent reported they 

participated in community outreach activities. These activities included philanthropic support for environmental 

programs or groups and serving on community advisory groups.

n Sixty-four percent aided school education programs, while 74 percent supported community social programs.

Participation in Public Policy

Development

Member companies are actively involved 

in the development of public policy at the 

federal, state, and local levels.

n Ninety-five percent of the companies 

reported participation in the development of public policy related to environmental, health, & safety matters in 2008.

n In addition, 75 percent met with public 

officials; 57 percent encouraged employees to participate in public policy develMember Community Outreach and Social Support Activities

Member Participation in Public Policy Development

Percent of Members

Percent of Members

32
33

Member Employee Involvement Programs

0 20 40 60 80 100

 Confidential Feedback Programs

EHS Performance Recognition Programs

Health/Safety Training Programs

Environmental Training Programs

Reported Employee Involvement Programs

Percent of Members

opment; 52 percent supplied company 

personnel to testify at federal, state, and 

local government hearings; and 59 percent met with interested stakeholders to 

discuss environmental, health, & safety 

matters.

Employee Involvement

Programs

Engaging employees in company EHS 

program planning and execution is a key 

part of the AF&PA EHS principles. 

In 2008:

n Ninety-seven percent of members reported employee involvement in EHS 

programs.

n Employees in 84 percent of companies 

gave confidential feedback regarding 

EHS matters.

n Sixty-nine percent of the companies 

have employee recognition programs for 

improved performance in EHS areas.
Sustainability and the 

Road to the Future

Innovation and Continuous

Improvement

The forest products industry meets its commitment to sustainability through innovation and environmental stewardship. Innovation is enabling the industry to develop new manufacturing processes that use fewer raw materials, reduce waste, and 

lessen energy consumption. It is creating the resources that allow the industry to support local communities and make forest 

products economically and environmentally viable for the future. AF&PA environmental and forest procurement principles 

ensure that value is placed on sustainability.

Research and Development Support

Innovation to date has reduced the industry’s environmental 

footprint and greenhouse gas emissions, as well as allowed the 

industry to support local communities. However, a much larger 

research agenda is being pursued to provide further improvement. In 2008:

n Eighty-two percent of members reported supporting research 

and development activities.

n Fifty-four percent supported internal research and development, while nearly 60 percent support external research activity.

Industry Sponsored Research

Organizations

AF&PA members directly support world-class research and 

technical support programs specifically tailored to meet forest 

products industry needs. Included are programs conducted by:

n National Council for Air and Stream Improvement

n Institute of Paper Science and Technology at the Georgia 

Institute of Technology

n Center for Paper Business and Industry Studies, also at Georgia Tech

Programs pursued by these organizations provide:

n Tracking and reducing greenhouse gas emissions

n Tracking and evaluating control options for reduced air emissions

n Effluent treatment improvements, reductions in effluent discharges, and assessment of conditions in receiving streams

n Information to reduce chemical substances used, produced, 

or released

n Forest sustainability, robust wildlife, and species diversity

n New materials and product platforms for a sustainable forest 

products industry

n New process technologies to support the industry and provide new products – including biofuels and biobased chemical 

feedstocks that serve as an alternative to petrochemicals

n Identification and understanding of social science issues of 

interest to industry stakeholders

n Connections between academic personnel and community 

stakeholders to improve understanding of the industry 

n Dissemination and communication of research findings to 

industry in order to facilitate better decisionmaking

n Increasing management and analytical capacity within the 

industry

34
35 n Skilled industry-oriented PhD and M.S. graduates in a variety of disciplines.

In addition, the U.S. Forest Service’s Forest Products Laboratory in Madison, Wisconsin develops knowledge and technologies for the industry. This lab provides a center of excellence for the science related to processing wood and woody 

materials into valuable products.

Support for Academic Institutions

Members support paper science and engineering programs at 

several colleges and universities that train scientists and engineers for technical, operational, and management positions 

within the industry and conduct research focused on industry 

needs. These include top-rated schools such as:

n Auburn University (Alabama)

n Georgia Institute of Technology

n Miami University (Ohio)

n North Carolina State University

n State University of New York College of Environmental Science and Forestry

n University of Maine

n University of Washington

n University of Minnesota

n Western Michigan University

n University of Wisconsin – Stevens Point

These institutions pursue research agendas of importance to 

the industry including:

n Obtaining the highest possible sustainable value from forestbased biomass

n Improving the efficiency of wood use and decreasing chemical use in pulping and bleaching operations

nIncreasing the use of recycled fiber and improving the strength 

of recycled pulps to reduce the use of virgin wood fiber

n Developing processes that produce biofuels and chemical 

building blocks from renewable forest resources

n Improving environmental management systems

n Optimizing pulping processes to reduce energy requirements

n Developing new effluent treatment and spent pulping liquor 

recovery processes that enhance performance, improve chemical and odor removal, increase energy recovery, and enhance 

water recycling
Cooperative Partnerships

The Agenda 2020 Technology Alliance, a special project of 

AF&PA, works to advance breakthrough technologies for the 

forest products industry with a strong focus on opportunities 

to improve sustainability. Agenda 2020 leads the development 

of a technology agenda for the industry, as evidenced by its 

2010 Technology Roadmap. It works to establish collaborative programs for technology development that include companies, universities, and government agencies as partners. As 

an example, Agenda 2020 manages the Value Prior to Pulping 

(VPP) research program that aims to extract hemicelluloses 

from wood before pulping and convert them to value-added 

fuels and chemicals. The VPP collaboration involves multiple 

companies and research institutions and is funded in part by 

the U.S. Department of Energy. The 2010 Roadmap outlines 

research needs in sustainability-focused areas such as reducing energy consumption, reducing fresh water intake, creating 

biobased products that displace fossil fuel feedstocks, enabling 

the development of products made with less fiber, and increasing the recovery and recycling of waste products.

Member Company Corporate

Research Programs

AF&PA members conduct independent research programs that 

seek to improve efficiencies, eliminate or reduce air and water 

releases, and improve product designs. 

Examples of projects conducted within these programs include:

n Finding ways to reduce energy requirements of existing papermaking processes and equipment

n Increasing recycled water use within mill systems and reducing fresh water withdrawal

n Improving the recyclability of used packaging cartons

n Increasing product packaging efficiency to reduce shipping 

fuel requirements

n Extending the use of wood residuals and other alternative 

fuels to further reduce reliance on fossil fuels

n Utilizing boiler ash and other residuals as fertilizers and soil 

conditioners to enhance forest nutrition and tree growth

n Implementing technologies that increase pulp yield, decrease 

wood use, and reduce generation of air emissions and water 

discharges per ton of product produced

36

Internet Addresses for

Forest Products Organizations

American Forest & Paper Association www.afandpa.org

National Council for Air

and Stream Improvement www.ncasi.org

Technical Association of the

Pulp and Paper Industry www.tappi.org

Institute of Paper Science and Technology www.ipst.gatech.edu

Center for Paper Business

and Industry Studies www.cpbis.gatech.edu

Agenda 2020 Technology Alliance www.agenda 2020.org

Society of Wood Science & Technology www.swst.org

1111 19th Street, NW, Suite 800

Washington, DC 20036

www.afandpa.org

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