All E-mail Correspondence with AF&PA

From: "Schwartz, Jerry" <Jerry_Schwartz@afandpa.org> 

To: "Elizabeth Sabol" <Elizabeth.Sabol@erg.com> 

CC: <swietlik.william@epa.gov>, "Eleanor Codding" <Eleanor.Codding@erg.com>, "Jessica 

Gray" <Jessica.Gray@erg.com> 

Date: 3/8/2011 6:09 PM 

Subject: RE: Request for 2009 DMR Data Clarification 

Attachments: Cascade Pacific Clarification DMR 2009.xlsx; Cascade Pacific Pulp TCDD lab results 

2009.pdf 

Elizabeth: See the attached for information on Cascades. 

I think this answers all your questions. Please let me know if I am wrong. Jerry 

From: "Schwartz, Jerry" <Jerry_Schwartz@afandpa.org> 

To: "Elizabeth Sabol" <Elizabeth.Sabol@erg.com> 

CC: <swietlik.william@epa.gov>, "Eleanor Codding" <Eleanor.Codding@erg.com>, "Jessica 

Gray" <Jessica.Gray@erg.com> 

Date: 3/8/2011 5:37 PM 

Subject: RE: Request for 2009 DMR Data Clarification 

Attachments: Pulp and Paper Facilities.xlsx 

Elizabeth: Here is the response for the Brunswick mill. Jerry 

Questions: 

 

1. Please confirm the June 2009 concentration for TCDD for Outfall 001. 

2. Are the correct units ug/L, or ng/L? See 

 

3. Was the concentration reported below the detection limit? 

ANSWERS TO 1-3: The mill did not report TCDD data for June 2009. The mill did report TCDD data for 3/1/09 

and the reported value was <2.16 pg/L on the OMR and <0.00000216 ug/L on the DMR, which was reported to the 

mill as below the reporting limit of 2.16 p/L. 

4. Please confirm an average flow of 36.2 MGD for Outfall 0A0. The average flow for Outfall 001 for the month of 

March 2009 was 35.0 MGD. The average flow for Outfall 001 for the month of June 2009 was 36.2 MGD. 

From: "Schwartz, Jerry" <Jerry_Schwartz@afandpa.org> 

To: "Elizabeth Sabol" <Elizabeth.Sabol@erg.com> 

Date: 3/7/2011 5:02 PM 

Subject: RE: FW: Request for 2009 DMR Data Clarification 

Elizabeth: I am still working on Cascade and Brunswick, but here is the contact info for Smurfit. Feel free to call. 

Niall O'Shaughnessy, PE 

Smurfit-Stone Container Corp. 

3700 Crestwood Parkway 

Suite 850 

Duluth, GA 30096 

770-570-1607 (office) 

770-361-7359 (cell) 
From: Elizabeth Sabol [mailto:Elizabeth.Sabol@erg.com] 

Sent: Monday, March 07, 2011 4:25 PM 

To: Schwartz, Jerry 

Cc: Elizabeth Sabol 

Subject: Re: FW: Request for 2009 DMR Data Clarification 

Jerry, 

 Thanks for the information for Smurfit. I was unable to download the attached PDF permit, would you be able to resend the file? 

 Also, I had a few follow-up questions about the sulfide discharges, they are listed below. They should be quick; 

however, if a phone call is easier with the facility contact let me know and I can call them directly to cut out the email chains. 

 For the sulfide discharges confirmed: 

1. What processes at the facility contribute to the sulfide discharges? Please explain why sulfide is used or a 

byproduct of this process. 

2. Are there any treatment technologies in place for the sulfide? 

3. Are both sulfide and flow measurements taken at the same location in the process? If not, is a smaller flow 

associated with the sulfide discharge? 

4. Please provide a description of Outfall 001. 

5. Are the sulfide concentrations reported in 2010 similar to the 2009 concentrations? 

Thanks, 

Elizabeth 

Elizabeth A. Sabol 

Environmental Engineer 

Eastern Research Group, Inc. 

14555 Avion Parkway, Suite 200 

Chantilly, VA 20151 

elizabeth.sabol@erg.com 

Phone:703-633-1659 

From: "Schwartz, Jerry" <Jerry_Schwartz@afandpa.org> 

Sent: 3/3/2011 10:38 AM 

To: Sabol, Elizabeth 

Subject: FW: FW: Request for 2009 DMR Data Clarification 

Elizabeth: Here is a response from Smurfit. Jerry 

Jerry, 

See the response to the questions for the Florence Mill below: 

1. Please confirm the sulfide concentrations and units for 2009 for Outfall 001. 

DMR data and the attached spreadsheet reflects the results accurately. 

 
Let me know if you need any other clarifications or information 

 Niall O'Shaughnessy, PE 

Smurfit-Stone Container Corp. 

3700 Crestwood Parkway 

Suite 850 

Duluth, GA 30096 

770-570-1607 (office) 

770-361-7359 (cell) 

From: "Schwartz, Jerry" <Jerry_Schwartz@afandpa.org> 

To: "Elizabeth Sabol" <Elizabeth.Sabol@erg.com> 

Date: 3/2/2011 5:25 PM 

Subject: RE: Request for 2009 DMR Data Clarification 

thanks 

From: Elizabeth Sabol [mailto:Elizabeth.Sabol@erg.com] 

Sent: Wednesday, March 02, 2011 3:34 PM 

To: Schwartz, Jerry 

Subject: RE: Request for 2009 DMR Data Clarification 

Jerry, 

Friday is great, or a little after! 

As for Cascade Pacific Pulp, we don't have a name. However, from Envirofacts (publically available data website) 

the contact is listed as John McEvoy, Plant Manager (617) 375-5838. 

Thanks, 

Elizabeth 

From: "Schwartz, Jerry" <Jerry_Schwartz@afandpa.org> 

To: "Elizabeth Sabol" <Elizabeth.Sabol@erg.com> 

Date: 3/2/2011 3:05 PM 

Subject: RE: Request for 2009 DMR Data Clarification 

I asked them to get back to me this Friday, but sometimes they are a bit late. 

By the way, do you have a name associated with the Cascades mill? They are not very active members and we are 

still trying to find the right person to talk to. 

From: Elizabeth Sabol [mailto:Elizabeth.Sabol@erg.com] 

Sent: Wednesday, March 02, 2011 2:10 PM 

2. Are any BDL indicators missing? 

There are no missing BDL indicators. 

3. Please confirm an average flow of 13.6 MGD for Outfall 001. 

The annual average flow for Outfall 001 is 13.6 mgd 

4. Does this facility have any permit limits for sulfide? Could you please provide the facility permit if 

available. 

The permit has a monitor and report only for Sulfide. There are no Sulfide numeric limits in the permit. A 

copy of the mill’s NPDES permit is attached. 
To: Schwartz, Jerry 

Subject: RE: Request for 2009 DMR Data Clarification 

Jerry, 

Thanks for the update, I will make sure to note the Rayonier change. Do you have any idea on when you might hear 

back from the facilities? We are on a tight schedule, and looking for the data as soon as it is available. 

Thank you for your time and effort in advance. 

Elizabeth 

From: "Schwartz, Jerry" <Jerry_Schwartz@afandpa.org> 

To: "Elizabeth Sabol" <Elizabeth.Sabol@erg.com> 

Date: 3/2/2011 8:01 AM 

Subject: RE: Request for 2009 DMR Data Clarification 

Elizabeth: I am working on these, but one quick point...Rayonier is no longer a member of AF&PA. Jerry 

From: Elizabeth Sabol [mailto:Elizabeth.Sabol@erg.com] 

Sent: Friday, February 25, 2011 10:00 AM 

To: Schwartz, Jerry 

Cc: swietlik.william@epa.gov; Eleanor Codding; Jessica Gray 

Subject: Request for 2009 DMR Data Clarification 

Jerry, 

 Thank you for your help in retrieving the 2009 TRI data for several Pulp and Paper facilities. As EPA continues its 

2011 review of industry discharges, we would like to also confirm 2009 DMR data for four facilities. 

As before, EPA reviews DMR 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 DMR and needs further 

information to complete the review. Specifically, we would like to clarify TCDD and sulfide discharges in the 2009 

DMR data from the following Pulp and Paper plants (detailed document attached): 

1. Rayonier Performance Fibers; 

2. Brunswick Cellulose, Inc.; 

3. Smurfit-Stone Container; and 

4. Cascade Pacific Pulp. 

 We appreciate your help in interpreting the DMR data correctly. 

 If you have questions regarding this request, you may contact me by phone at (703) 633-1659 or by e-mail at 

elizabeth.sabol@erg.com. 

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. 

Thanks, 

Elizabeth 

Elizabeth A. Sabol 

Environmental Engineer 

Eastern Research Group, Inc. 

14555 Avion Parkway, Suite 200 

Chantilly, VA 20151 

elizabeth.sabol@erg.com 

Phone:703-633-1659 
RAYONIER PERFORMANCE FIBERS

GA0003620

Jesup, GA

2009 DMR Data

Outfall PRAM Code PRAM Desc Date

BDL 

Indicator

Average 

Concentration 

(ug/L)

0A0 34675 TCDD 20090331 6.5e-06

0A0 34675 20090630 < 2.8e-06

0A0 34675 20090930 < 2.8e-06

0A0 34675 20091231 < 8.4e-06

Questions:

1. Please confirm the March 2009 concentration for TCDD for Outfall 0A0.

2. Is the concentration missing a BDL indiciator?

3. Are the correct units ug/L, or ng/L?

4. Please confirm an average flow of 59.02 MGD for Outfall 0A0.
BRUNSWICK CELLULOSE, INC.

GA0003654

Brunswick, GA

2009 DMR Data

Outfall PRAM Code PRAM Desc Date

BDL 

Indicator

Average 

Concentration 

(ug/L)

001 34675 TCDD 20090630 2.16e-06

Questions:

1. Please confirm the June 2009 concentration for TCDD for Outfall 001.

2. Are the correct units ug/L, or ng/L?

3. Was the concentration reported below the detection limit? 

4. Please confirm an average flow of 36.2 MGD for Outfall 0A0.
SMURFIT-STONE CONTAINER

SC0000876

Florence, SC

2009 DMR Data

Outfall

PRAM 

Code PRAM Desc Date

Average 

Concentration BDL 

Indicator

Average 

Concentration 

(mg/L)

Maximum 

Concentration BDL 

Indicator

Maximum 

Concentration 

(mg/L)

001 00745 Sulfide, total (as S) 20090131 < 1.0 < 1.0

001 00745 Sulfide, total (as S) 20090228 4.0 4.0

001 00745 Sulfide, total (as S) 20090331 < 1.0 < 1.0

001 00745 Sulfide, total (as S) 20090430 1.1 1.1

001 00745 Sulfide, total (as S) 20090531 0.79 0.79

001 00745 Sulfide, total (as S) 20090630 1.2 1.2

001 00745 Sulfide, total (as S) 20090731 1.9 1.9

001 00745 Sulfide, total (as S) 20090831 1.34 1.34

001 00745 Sulfide, total (as S) 20090930 < 0.38 < 0.38

001 00745 Sulfide, total (as S) 20091031 0.72 0.72

001 00745 Sulfide, total (as S) 20091130 0.51 0.51

001 00745 Sulfide, total (as S) 20091231 < 0.38 < 0.38

Questions:

1. Please confirm the sulfide concentrations and units for 2009 for Outfall 001.

2. Are any BDL indicators missing?

3. Please confirm an average flow of 13.6 MGD for Outfall 001.

4. Does this facility have any permit limits for sulfide? Could you please provide the facility permit if available.
Cascade Pacific Pulp 

OR0001074

Halsey, OR

2009 DMR Data

Outfall

PRAM 

Code

PRAM 

Desc

Sample 

Date

BDL 

Indicator 

Detection 

Limit pq/l

Average 

Quantity 

(mg/day)

001 34675 TCDD 20090204 10 0.204

001 34675 TCDD 20090512 10 0.204

001 34675 TCDD 20090730 1.9 0.151

001 34675 TCDD 20091231 5.1 0.157

Questions:

1. Please confirm all 2009 TCDD quantities reported for Outfall 001. 

All quantities have been confirmed for 2009. Cascade Pacific Pulp effluent has been non-detect for many years. 

Because Oregon had a TMDL for dioxin on the Willamette River, Cascade Pacific Pulp is required to estimate the loading 

of dioxin to the river. The loading is calculated based on half of the detection limit. 

2. Are BDL indicators missing from the data?

The detection limit for the first and second quarters was 10 pg/l. The third quarter samples were tested with a detection limit

of 1.9 pg/l. The fourth quarter had a reporting limit of 10 pg/l and an estimated detection limit of 5.1 pg/l.

3. Please confirm an average flow of 11 MGD for Outfall 001.

The average effluent flow for Cascade Pacific Pulp for 2009 is 11.00 MGD for Outfall 001.

4. Is Outfall 001 a final effluent/outfall or an internal monitoring point (i.e., bleach plant effluent)?

Outfall 001 is a final effluent monitoring point.

5. Please provide a copy of the underlying 2009 TCDD concentration data for Outfall 001. 

Copies are attached of the lab results as well as the calculation sheets submitted to the Oregon Department of Environmental Quality.