Need to return call by / at/between and . Signature:

Project No.: 0172.08.005.607 Page 1 of 1

Project Name: 2011 Prelim Cat Rev CBI?

Yes

No

TELEPHONE CALL RECORD

Incoming

Outgoing

Date: 10/18/11 Time: 4:00 am

pm

Company Name: Proctor and Gamble ERG Staff Name: Kimberly Landick

Contact Name: Michael Childress Contact Phone Number: (570) 833-3306

General Subject: 2009 TRI Dioxin Discharges

TOPICS DISCUSSED AND ACTION TAKEN

On October 18, 2011 at 4:00 pm I called Michael Childress and left a message. 

On October 19, 2011 at 10:20am, Mr. Childress returned my call. He stated that the facility has had no major 

changes in pulp bleaching operations between 2005 and 2009. He requested that the rest of the questions be sent 

via email so that he could verify the data. Email address: childress.mg@pg.com. Please see attached email 

correspondence. 
Proctor & Gamble, Mehoopany, PA Email Correspondence

From: Kimberly Landick

To: childress.mg@pg.com

Date: 12/07/2011 11:58 AM

Subject: RE: Request for 2009 TRI Data Clarification

Mr. Childress,

Thank you for your response. At this point we have no further questions. We will contact you if further questions 

arise. 

Thanks again,

Kimberly

From: Michael Childress

To: Kimberly Landick

Date: 11/30/2011 2:34 PM

Subject: RE: Request for 2009 TRI Data Clarification

Dear Kimberly – in response to your questions: 

a. Question 1: What is the P&G pulp analysis data based on? 

For TRI reporting purposes, the pulp congener analysis data are based on the best available data. 

Depending on the pulp, these data may come from: direct sampling from the pulp vendors; National 

Council for Air and Stream Improvement (NCASI) data; or from conservative estimates based on other 

pulps from the same supplier. P&G obtains pulp sampling data directly from the pulp vendors 

(when possible) and do NOT do any P&G testing for these values. P&G considers the direct 

sampling data from the pulp vendors to be the best data; however, when that data are not available the 

NCASI data or conservative estimates are used.

b. Question 2: Could we release a copy of the data? 

i. P&G and its pulp suppliers consider this pulp characteristic data proprietary, so we don’t 

intend to release data on our entire pulp supply used at our Mehoopany facility. We have 

enclosed data (see below) on ONE of the species of pulp in our 2009 P&G Mehoopany 

TRI report so that you may have a representative sample to answer your question.

c. Question 3: What is the source of the estimated release amounts and could you receive a 

copy? 

i. The estimated release amounts are simply the multiplication of pulp congener 

concentration (from Question 2) TIMES the tonnage of this pulp used at our facility in 

2009 which will yield net grams of dioxin released to the environment from this pulp 

species.

ii. P&G considers the total capacity of pulp we consume annually at a facility proprietary 

(because that is a direct release of our manufacturing capacity and utilization); However, 

in order to answer your question, we will continue with the same approach used in 

Question #2 – we will provide data on tonnage of ONE of the pulps we used in 2009 

(see under column... annual purchased pulp)– same species as the concentration 

analysis that we referred to in Question #2; 

1. We used xxx Tons of YYY Pulp. Therefore if we take the amount of this pulp 

species tonnage used in 2009 and using the various congener concentrations 

(table below) summarized the net grams of each dioxin congener generated in 

2009. This of course is simply the multiplication of congener concentration 

(from Question #2) times the tonnage in Question #3 yielding net grams of 

dioxin released to environment.
Impor

ted or 

Not 

Impor

ted 

Annual 

Purcha

sed 

Pulp 

(ADM

T)

Total 

Dioxin 

(grams/

yr) 

Suppl

ier

Fiber 

Type

Dioxin 

Congeners

EPA 

Label

Diox

in 

Dat

a 

(ppt

)

Annu

al 

Dioxi

n 

Cont

ent 

(MT)

Annu

al 

Dioxi

n 

Conte

nt 

(gram

s)

Data 

Source

Import

ed

157,70

7

0.82165

347

Aracr

uz THK

TCDD ND (0.3 

ppt) 17 0 0 0 P&RS 

2004 

File Data 2,3,7,8 TCDF 16 0.37 0

0.058

352

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

HpCDD 10 0.32 0

0.050

466

NCASI 

1,2,3,4,6,7,8,9 

OCDD 12 4.06 0

0.640

29

1,2,3,4,7,8 

HxCDF 3 0.03 0

0.001

183

1,2,3,6,7,8 

HxCDF 4 0.03 0

0.001

183

1,2,3,7,8,9 

HxCDF 5 0.03 0

0.001

183

2,3,4,6,7,8 

HxCDF 6 0.03 0

0.001

183

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

HpCDF 1 0.13 0

0.010

251

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

HpCDF 2 0.13 0

0.010

251

1,2,3,4,6,7,8,9 

OCDF 11 0.08 0

0.012

617

I hope this meets and exceeds your questions. 

Regards, 

Mike Childress

Mehoopany Environmental Group

The Procter & Gamble Paper Products Co.

Phone: (570) 833-3306

Cell: (570) 240-0389

From: Kimberly Landick

To: childress.mg@pg.com

Date: 11/09/2011 3:04 PM

Subject: RE: Request for 2009 TRI Data Clarification

Mr. Childress, 

Thank you for providing the additional information. We understand that the Dioxin Congener Reporting Tool is a 

company tool used to report the congener-specific release amounts. You state below that the tool uses P&G pulp 

analysis data that provide the congener-specific speciation for each pulp. What is the P&G pulp analysis data based 
on (e.g., direct sampling, literature, etc.)? Could we receive a copy of the data? Additionally, what is the source of 

the estimated release amounts and could we also receive a copy? 

Please call me at 703-633-1119 to discuss the answers to the questions above so we can better understand the 

underlying calculations. Again, thank you for your response. 

Kimberly

From: Michael Childress

To: Kimberly Landick

Date: 11/07/2011 3:55 PM

Subject: RE: Request for 2009 TRI Data Clarification 

Kimberly,

Dioxin Congener Reporting Tool –

The Dioxin Congener Reporting Tool assists the facility in reporting for the Dioxin Form R - Schedule 1. The 

facility inputs the pulp usage data and also inputs the total grams released to each environmental media. The Tool 

uses the P&G pulp analysis data (these data provide the congener-specific speciation for each pulp) and the facilityspecific pulp usage data to determine a weight percentage usage for each of the 17 dioxin congeners. This weight 

percentage breakdown is then applied to each estimated release value to provide a dioxin-congener specification of 

each reportable release on the Dioxin Form R – Schedule 1.

Hope this helps, 

Mike Childress

Mehoopany Environmental Group

The Procter & Gamble Paper Products Co.

Phone: (570) 833-3306

Cell: (570) 240-0389

P lease consider the environment before printing this e-mail.

From: Kimberly Landick

To: childress.mg@pg.com

Date: 10/31/2011 11:34 AM

Subject: RE: Request for 2009 TRI Data Clarification

Mr. Childress, 

Thank you for providing the information below. We have one follow-up question in order to correctly interpret your 

answers: 
Please explain the Dioxin Congener Tool that is used for calculations. We realize that it allows for the reporting of 

the congener-specific release amounts but would like to clarify the values that are used. Please provide an example. 

Again, thank you for your response.

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: Michael Childress

To: Kimberly Landick

Date: 10/26/2011 2:20 PM

Subject: RE: Request for 2009 TRI Data Clarification 

Kimberly - First I would like to clarify that we are a large consumer paper production plant that utilizes other 

manufacturers to supply our pulp. The pulp material has resident dioxins and its congeners. The total amount of 

pulp used with its dioxins and congeners is understood and using a calculation determines the amount of dioxin 

and its congeners released to our effluent water. The dioxin already exists in the pulp that is received at our 

facility. Procter & Gamble (P&G) is aware that under the EPA TRI program, dioxin does have a qualifier that 

states:

Dioxin and dioxin-like compounds (manufacturing; and the processing or otherwise use of 

dioxin and dioxin-like compounds if

the dioxin and dioxin-like compounds are present as contaminants in a chemical and if they were 

created during the manufacture of that chemical.)

The dioxin in the pulps received by P&G are already contaminants in the pulp and do not meet the qualifier; 

however the pulp (and the dioxin) is imported which is considered manufacturing under TRI. Clarification has 

been requested by EPA as to whether the manufacturing by importation of the dioxin meets the qualifier or not. 

Clarification has not yet been received. Therefore, P&G considers the imported pulp and dioxin as being 

reportable and not meeting the qualifier. 

With that being said, please find for your review our answer to your questions below high-lighted in green font.

1. Does the mill use hypochlorite to bleach pulp? No

2. Please verify the 2009 dioxin discharges found in the attachment (Proctor & Gamble Mehoopany Dioxin 

Discharges.xlsx). Verified and confirmed correct.

3. Were the data reported for 2009 based on actual measurement(s) of effluent discharges? No

4. If not actual data, what was the basis for estimating releases to water? Dioxin congener tool for 

calculations. [When estimating the dioxin congener-specific releases, the facility uses the congener 
breakdown in the pulps received and applies that to the estimated release amount. The dioxin congener 

tool allows for the reporting of the congener-specific release amounts.]

5. How were analytical results at or below the analytical minimum level or detection limit treated (i.e., were < 

"less than" values treated as zero, or as some fraction of the detection limit)? [P&G performs sampling on 

the pulps used by the facilities. When using these data for TRI threshold calculations and reporting, the 

following practices were followed: When congeners were non-detect, 0 was used. When congener data 

were not available, the facility would default to the most conservative congener data available for the 

pulps used on site.]

6. Did the mill recognize that EPA's TRI dioxin and dioxin/like congener numbering sequence changed for the 

2008 reporting year and beyond? [P&G recognizes that the congener numbering sequence changed for 

reporting year 2008 and modified its reporting tools accordingly.]

Respectfully submitted, 

Mike Childress

Mehoopany Environmental Group

The Procter & Gamble Paper Products Co

Phone: (570) 833-3306

Cell: (570) 240-0389

From: Kimberly Landick

To: childress.mg@pg.com

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

BC: Landick, Kimberly

Date: 10/19/2011 10:41 AM

Subject: Request for 2009 TRI Data Clarification

Mr. Childress,

Thank you for your time on the phone this morning. Eastern Research Group, Inc. (ERG) under EPA Contract No. 

68-C-02-095 is emailing you on EPA’s behalf to request clarification of 2009 TRI data for the Proctor & Gamble 

Facility in Mehoopany, PA (TRI ID: 18629PRCTRROUTE). Please see below for further background.

EPA reviews TRI data to fulfill its review obligation under Section 304(b) of the Clean Water Act. The CWA 

requires EPA to annually review and, if appropriate, revise its water pollution control technology-based regulations, 

called “effluent limitations guidelines” or "effluent guidelines,” that limit the discharge of pollutants to waters of the 

U.S. from various categories of industrial facilities. EPA is currently conducting its 2011 annual review of existing 

effluent guidelines and potential industrial guidelines which may need to be included (see 

http://www.epa.gov/guide/304m/ for further information). EPA will discuss this review and the results in its 2011 

Effluent Guidelines Program Plan scheduled for publication in the Federal Register in 2011. 

As part of the 2011 annual review, EPA is evaluating the data reported to the 2009 TRI and needs further 

information to complete the review. Specifically, we would like to clarify the amount of dioxin reported to the 2009 

TRI. Please confirm/review the following data and questions below. 

1. Does the mill use hypochlorite to bleach pulp?

2. Please verify the 2009 dioxin discharges found in the attachment (Proctor & Gamble Mehoopany Dioxin 

Discharges.xlsx). 

3. Were the data reported for 2009 based on actual measurement(s) of effluent discharges?

4. If not actual data, what was the basis for estimating releases to water? 

5. How were analytical results at or below the analytical minimum level or detection limit treated (i.e., were < "less 

than" values treated as zero, or as some fraction of the detection limit)?
6. Did the mill recognize that EPA's TRI dioxin and dioxin/like congener numbering sequence changed for the 2008 

reporting year and beyond? 

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

call me at (703) 633-1119. If you would like to speak directly with EPA regarding this request, you can contact 

William F. Swietlik of EPA's Office of Water/Engineering Analysis Division by phone at (202) 566-1129 or by 

email: swietlik.william@epa.gov. 

Thank you,

Kimberly

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

Kimberly D. Landick

Environmental Engineer

Eastern Research Group, Inc. 

14555 Avion Parkway, Suite 200

Chantilly, VA 20151

kimberly.landick@erg.com

Phone: 703-633-1119
Procter & Gamble Paper Products Co

Mehoopany, PA

18629PRCTRROUTE

TRI Data

Grams 

Discharged

Basis of 

Estimate

0.0200029 E1

1 2 3 4 5 6 7 8 9

Total Water 

Release Grams 

Discharged 0.0004927 0.000493 0.000313 0.0003125 0.0003125 0.0003125 0.00029 0.00029 0.00029

10 11 12 13 14 15 16 17 Total

0.0020535 0.001994 0.012139 0.0000323 0.0000256 0.0000258 0.000627 0 0.0200029

Questions:

1. Does this facility still operate their bleaching process?

2. What does the plant use for bleaching (e.g., sodium hypochlorite)?

3. What is the basis for the 2009 dioxin water release distribution (e.g., sampling)?

4. If the distribution is based on measured data,

4a. Were the concentrations below the detection limit?

4b. Where was the sample taken (e.g., bleach plant effluent, final effluent)?

2009

2009

Congener 

Number
CASNU

Congener 

Number

1746016 1

40321764 2

39227286 3

57653857 4

19408743 5

35822469 6

3268879 7

51207319 8

57117416 9

57117314 10

70648269 11

57117449 12

72918219 13

60851345 14

67562394 15

55673897 16

39001020 17

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

Octachlorodibenzofuran

Dioxin Congeners

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

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

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

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

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

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

Octachlorodibenzo-p-dioxin

Tetrachlorodibenzofuran, 2,3,7,8-

Pentachlorodibenzofuran, 1,2,3,7,8-

Pentachlorodibenzofuran, 2,3,4,7,8-

Tetrachlorodibenzo-p-dioxin, 2,3,7,8-

Pentachlorodibenzo-p-dioxin, 1,2,3,7,8-

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

Hexachlorodibenzo-p-dioxin, 1,2,3,6,7,8-

Hexachlorodibenzo-p-dioxin, 1,2,3,7,8,9-

Chemical Name