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

October 7, 2011

TO: Elizabeth Sabol, ERG

FROM: Paul Wiegand, NCASI

SUBJECT: Fourth and Final Partial Response on EPA Inquiry Concerning 2009 TRI Reports

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

My previous communications to you of August 12, 30, and September 23, 2011 conveyed

responses from 17 of 19 mills for which you requested additional information regarding 2009

TRI submissions for dioxin and dioxin-like compounds and certain mill operational details. This

memo contains a response we have received since that time from one additional mill. Per our

prior discussions, the remaining mill (Procter & Gamble at Mehoopany, PA) was to be contacted

directly by EPA. As before, the details below have been reproduced verbatim from the response

provided by the mill. The facility response included here is:

 Clearwater, Lewiston, Idaho

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. We are pleased to assist you

with this effort and we will be happy to provide additional help as needed in your efforts related

to effluent limitations guidelines review.

ec: Jerry Schwartz, AF&PA

Arun Someshwar, NCASI
Elizabeth Sabol, ERG

October 7, 2011

Page 2

Clearwater, Lewiston, Idaho

General Mill Questions:

1. Were there major changes in pulp bleaching operations between 2005 and 2009 (such as

new or decommissioned bleach plants)?

No.

2. Does the mill use hypochlorite to bleach pulp?

No.

2009 TRI Form R Report for Dioxin and Dioxin-like Compound Releases to Water:

1. Are the attached data accurate for the report made for 2009? (if not, provide corrected

information)

Yes.

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

Yes.

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

Estimates were based on measurements. (see above).

4. How were analytical results at or below the analytical minimum level or detection limit

treated (i.e., were < “less than” values treated as zero, as some fraction of the detection limit)?

Below detection was valued at 1⁄2 the detection limit.

5. Did the mill recognize that EPA’s TRI dioxin and dioxin/like congener numbering

sequence changed for the 2008 reporting year and beyond?

Yes.
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

September 23, 2011

TO: Elizabeth Sabol, ERG

FROM: Paul Wiegand, NCASI 

SUBJECT: Third Partial Response on EPA Inquiry Concerning 2009 TRI Reports for Dioxin 

and Dioxin-Like Compounds from Select Pulp and Paper Mills

My previous communications to you of August 12 and 30, 2011 conveyed responses from 14 of 

19 mills for which you requested additional information regarding 2009 TRI submissions for 

dioxin and dioxin-like compounds and certain mill operational details. This memo contains 

responses we have received since that time from three additional mills. As before, the millspecific responses, have been reproduced verbatim from response(s) to our inquiry e-mails. 

Facility responses included here are:

· International Paper, Riegelwood, North Carolina

· Georgia-Pacific, Crossett, Arkansas

· Nippon, Port Angeles, Washington

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. We are pleased to assist you 

with this effort and we will be happy to provide additional help as needed in your efforts related 

to effluent limitations guidelines review. 

ec: Jerry Schwartz, AF&PA

Arun Someshwar, NCASI
Elizabeth Sabol, ERG

September 23, 2011

Page 2

International Paper, Riegelwood, North Carolina

General Mill Questions:

1. Were there major changes in pulp bleaching operations between 2005 and 2009 (such as new 

or decommissioned bleach plants)? 

No

2. Does the mill use hypochlorite to bleach pulp? 

No

2009 TRI Form R Report for Dioxin and Dioxin-like Compound Releases to Water:

1. Are the attached data accurate for the report made for 2009? (if not, provide corrected 

information) 

The attached data match the data submitted in 2009. [NCASI Note: “attached data” refers to the 

spreadsheet containing the data provided by EPA]

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

No

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

Each bleach plant’s effluent was sampled for the different dioxin congeners in 2000, and three 

were detected. The dioxin mass released annually from the bleach plants (based on 2000 sample 

concentrations) was divided between the mill effluent (30%) and wastewater sludge sent to the 

landfill (70%).

4. How were analytical results at or below the analytical minimum level or detection limit 

treated (i.e., were < “less than” values treated as zero, as some fraction of the detection limit)? 

“Less than” values were treated as zero.

5. Did the mill recognize that EPA’s TRI dioxin and dioxin/like congener numbering sequence 

changed for the 2008 reporting year and beyond? 

Yes
Elizabeth Sabol, ERG

September 23, 2011

Page 3

Georgia-Pacific, Crossett, Arkansas 

General Mill Questions:

1. Were there major changes in pulp bleaching operations between 2005 and 2009 (such as new 

or decommissioned bleach plants)? 

No.

2. Does the mill use hypochlorite to bleach pulp? 

No, we use ClO2.

2009 TRI Form R Report for Dioxin and Dioxin-like Compound Releases to Water:

1. Are the attached data accurate for the report made for 2009? (if not, provide corrected 

information) 

Yes.

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

No. 

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

NCASI factors were used. 

4. How were analytical results at or below the analytical minimum level or detection limit treated 

(i.e., were < “less than” values treated as zero, as some fraction of the detection limit)? 

NA

5. Did the mill recognize that EPA’s TRI dioxin and dioxin/like congener numbering sequence 

changed for the 2008 reporting year and beyond? 

Yes, these changes were made.
Elizabeth Sabol, ERG

September 23, 2011

Page 4

Nippon, Port Angeles, Washington

General Mill Questions:

1. Were there major changes in pulp bleaching operations between 2005 and 2009 (such as new 

or decommissioned bleach plants)?

No changes in pulp bleaching. This mill is mechanical & deink pulp. We use reductive 

bleaching – sodium bisulfite and sodium hydrosulfite, and H2O2 and there have been no changes

2. Does the mill use hypochlorite to bleach pulp?

No, the mill does NOT use hypo to bleach.

2009 TRI Form R Report for Dioxin and Dioxin-like Compound Releases to Water:

1. Are the attached data accurate for the report made for 2009? (if not, provide corrected 

information).

Yes, the 2009 dioxin data for effluent discharge is accurate. It is based on the 2006 analytical 

data for an effluent sample. The 2006 data was also used to report the 2008 TRI data for effluent 

dioxin.

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

Yes, it is based on the Columbia Analytical report Lab ID E06002241-001 for a sample collected 

on April 5, 2006. One single sample. There have been no new effluent samples since 2006. The 

mill uses a wet venturi scrubber and the scrubber ash is carried to the WWTP. The mill does not 

burn salt laden hog fuel.

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

N/A

4. How were analytical results at or below the analytical minimum level or detection limit treated 

(i.e., were < “less than” values treated as zero, as some fraction of the detection limit)?

Non detects were treated as 1⁄2 DL for reporting purposes in the 2009 TRI and the 2008 TRI.

5. Did the mill recognize that EPA’s TRI dioxin and dioxin/like congener numbering sequence 

changed for the 2008 reporting year and beyond?

Yes, the mill began using the new dioxin reporting by congener (and the new Form R Schedule 1 

for dioxin) for reporting year 2008. The 2008 reporting year also used the 1⁄2 DL and the 2006 

analytical data for the effluent sample.
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

August 30, 2011

TO: Elizabeth Sabol, ERG

FROM: Paul Wiegand, NCASI 

SUBJECT: Second Partial Response on EPA Inquiry Concerning 2009 TRI Reports for 

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

My previous communication to you of August 12, 2011 conveyed responses from 8 of 19 mills 

for which you requested additional information regarding 2009 TRI submissions for dioxin and 

dioxin-like compounds and certain mill operational details. This memo contains responses we 

have received since that time from six additional mills. As before, the mill-specific responses,

have been reproduced verbatim from response(s) to our inquiry e-mails. Facility responses 

included here are:

· Domtar, Plymouth, North Carolina

· Evergreen, Pine Bluff, Arkansas

· Georgia-Pacific, Palatka, Florida

· Kimberly-Clark, Everett, Washington

· RockTenn, Demopolis, Alabama

· SAPPI (S.D. Warren), Skowhegan, Maine

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. We are pleased to assist you 

with this effort and we will be happy to provide additional help as needed in your efforts related 

to effluent limitations guidelines review. 

ec: Jerry Schwartz, AF&PA

Arun Someshwar, NCASI
Elizabeth Sabol, ERG

August 30, 2011

Page 2

Domtar, Plymouth, North Carolina

General Mill Questions:

1. Were there major changes in pulp bleaching operations between 2005 and 2009 (such as new 

or decommissioned bleach plants)? 

There was no major change in the bleaching process 2005 – 2009.

2. Does the mill use hypochlorite to bleach pulp? 

We do not use hypochlorite in the bleaching process.

2009 TRI Form R Report for Dioxin and Dioxin-like Compound Releases to Water:

1. Are the attached data accurate for the report made for 2009? (if not, provide corrected 

information).

Yes.

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

Partially, facility effluent analysis for 2,3,7,8 TCDD and TCDF is non-detect.

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

All other emission factors are from NCASI SARA 313 Guidance for Dioxins and Dioxinlike compounds Table 14.

4. How were analytical results at or below the analytical minimum level or detection limit treated 

(i.e., were < “less than” values treated as zero, as some fraction of the detection limit)? 

ND values for 2,3,7,8 TCDD and 2,3,7,8 TCDF were treated as zero.

5. Did the mill recognize that EPA’s TRI dioxin and dioxin/like congener numbering sequence 

changed for the 2008 reporting year and beyond?

Yes.
Elizabeth Sabol, ERG

August 30, 2011

Page 3

Evergreen, Pine Bluff, Arkansas

General Mill Questions:

1. Were there major changes in pulp bleaching operations between 2005 and 2009 (such as new 

or decommissioned bleach plants)? 

Our facility has not had any changes in the bleaching process from 2005-2009

2. Does the mill use hypochlorite to bleach pulp? 

Our mill utilizes chlorine dioxide for bleaching.

2009 TRI Form R Report for Dioxin and Dioxin-like Compound Releases to Water:

1. Are the attached data accurate for the report made for 2009? (if not, provide corrected 

information).

The dioxin isomer distribution is correct.

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

No

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

Table 14 from the sheets for dioxin & dioxin-like cpds in the NCASI 313 Handbook. 

The basis of estimate reporting codes E1 and E2 are for “emission” factors, M1 and M2 

are for facility monitoring data, and C is for mass balance. The only other option is 

reporting code O (Estimate based on other approaches) which was therefore used.

4. How were analytical results at or below the analytical minimum level or detection limit treated 

(i.e., were < “less than” values treated as zero, as some fraction of the detection limit)? 

ND = 0 as assumed in the NCASI Table.

5. Did the mill recognize that EPA’s TRI dioxin and dioxin/like congener numbering sequence 

changed for the 2008 reporting year and beyond?

Yes.
Elizabeth Sabol, ERG

August 30, 2011

Page 4

Georgia-Pacific, Palatka, Florida

General Mill Questions:

1. Were there major changes in pulp bleaching operations between 2005 and 2009 (such as new 

or decommissioned bleach plants)?

GP Answer: Yes, old Brown Stock Washers were decommissioned, new Brown Stock 

Washers were installed and an oxygen delignification system was installed.

2. Does the mill use hypochlorite to bleach pulp?

GP Answer: No.

2009 TRI Form R Report for Dioxin and Dioxin-like Compound Releases to Water:

1. Are the attached data accurate for the report made for 2009? (if not, provide corrected 

information)

GP Answer: Yes.

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

GP Answer: No.

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

GP Answer: Releases were based on NCASI factors in Table 14 PCDD/F Concentrations 

in Eight ECF Bleached Chemical Pulp Mill Treated Effluents (NCASI 2002) applicable 

to the Palatka facility’s wastewater flow.

4. How were analytical results at or below the analytical minimum level or detection limit treated 

(i.e., were < less thanvalues treated as zero, as some fraction of the detection limit)?

GP Answer: The NCASI Table 14 footnote indicates that “all non-detects were assumed 

= 0”.

5. Did the mill recognize that EPAs TRI dioxin and dioxin/like congener numbering sequence 

changed for the 2008 reporting year and beyond?

GP Answer: Yes.
Elizabeth Sabol, ERG

August 30, 2011

Page 5

Kimberly-Clark, Everett, Washington

General Mill Questions:

1. Were there major changes in pulp bleaching operations between 2005 and 2009 (such as new 

or decommissioned bleach plants)? 

No changes during this time frame. The Mill moved to elemental chlorine free bleaching 

in 2001 using chlorine dioxide.

2. Does the mill use hypochlorite to bleach pulp? 

No.

2009 TRI Form R Report for Dioxin and Dioxin-like Compound Releases to Water:

1. Are the attached data accurate for the report made for 2009? (if not, provide corrected 

information) 

Yes.

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

As noted on the Form R submission (basis of estimate = “C”), it was based on mass 

balance. No actual discharge measurements from 2009 were included in the report. 

Mass balance used various historical dioxin furan data. 

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

Site wide mass balance.

4. How were analytical results at or below the analytical minimum level or detection limit 

treated (i.e., were < “less than” values treated as zero, as some fraction of the detection limit)? 

1⁄2 the DL.

5. Did the mill recognize that EPA’s TRI dioxin and dioxin/like congener numbering sequence 

changed for the 2008 reporting year and beyond? 

Yes.
Elizabeth Sabol, ERG

August 30, 2011

Page 6

RockTenn, Demopolis, Alabama

General Mill Questions:

1. Were there major changes in pulp bleaching operations between 2005 and 2009 (such as new 

or decommissioned bleach plants)? 

No

2. Does the mill use hypochlorite to bleach pulp? 

No

2009 TRI Form R Report for Dioxin and Dioxin-like Compound Releases to Water:

1. Are the attached data accurate for the report made for 2009? (if not, provide corrected 

information).

Yes - The data are accurate.

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

No for all congeners except 2,3,7,8-TCDD. 2,3,7,8-TCDD was measured twice during 

2009 and both measurements were below detection limits and treated as zero in the TRI 

calculations.

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

RockTenn's Demopolis Mill used the emission factors from Table 14 of the February 

2010 NCASI reporting guidance.

4. How were analytical results at or below the analytical minimum level or detection limit 

treated (i.e., were < “less than” values treated as zero, as some fraction of the detection limit)? 

"Less than" values for 2,3,7,8-TCDD were treated as zero. There were no analytical 

results for the other 16 congeners, and the NCASI guidance for the 16 congeners used 

numbers and did not contain "less than" or "greater than" values.

5. Did the mill recognize that EPA’s TRI dioxin and dioxin/like congener numbering sequence 

changed for the 2008 reporting year and beyond? 

Yes - I have verified that the quantities reported for each congener conform to the 

congener numbering in EPA's TRI reporting guidance for the 2009 report year.
Elizabeth Sabol, ERG

August 30, 2011

Page 7

SAPPI (S.D. Warren), Skowhegan, Maine

General Mill Questions:

1. Were there major changes in pulp bleaching operations between 2005 and 2009 (such as new 

or decommissioned bleach plants)?

No

2. Does the mill use hypochlorite to bleach pulp? 

No

2009 TRI Form R Report for Dioxin and Dioxin-like Compound Releases to Water:

1. Are the attached data accurate for the report made for 2009? (if not, provide corrected 

information) 

Yes, these are the numbers reported for 2009 TRI

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

Yes, they were based on the last sample tested on the mill’s final effluent on 5/8/02 (i.e. 

22.04 pg/L)

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

The total congener concentration of 22.04 pg/L is multiplied by the most recent annual 

effluent flow and then corrected for the naturally occurring congeners (i.e. OCDD, 

HpCDD, and OCDF) in the mill’s receiving water, wood, and kaolin clay. The most 

recent annual consumption rates are used for water, wood, and clay and multiplied by a 

combination of 2005 NCASI emission factors and past actual test data to correct for 

naturally occurring congeners. The calculations are very lengthy.

4. How were analytical results at or below the analytical minimum level or detection limit 

treated (i.e., were < “less than” values treated as zero, as some fraction of the detection limit)? 

As zeros, for the effluent data

5. Did the mill recognize that EPA’s TRI dioxin and dioxin/like congener numbering sequence 

changed for the 2008 reporting year and beyond?

Yes, we changed the numbering sequence to match EPA’s sequence change in 2008 and 

beyond.
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

August 12, 2011

TO: Elizabeth Sabol, ERG

FROM: Paul Wiegand, NCASI

SUBJECT: Partial Response on EPA Inquiry Concerning 2009 TRI Reports for Dioxin and

Dioxin-Like Compounds from Select Pulp and Paper Mills

Pursuant to your request, NCASI has contacted 18 of the 19 mills for which you requested

additional information regarding 2009 TRI submissions for dioxin and dioxin-like compounds

and certain mill operational details. Jerry Schwartz at AF&PA has contacted the remaining

company (SAPPI) and will respond separately. To date, we have complete responses from eight

facilities and this memo conveys those responses to you.

Our inquiry of the mills on your behalf was communicated via e-mail. Attached to this memo

are the mill-specific responses, reproduced verbatim, typically from response e-mails. The

facilities that have responded to date are:

 AbitibiBowater at Calhoun, Tennessee

 Boise at Wallula, Washington

 Boise at Jackson, Mississippi

 Clearwater, Arkansas Mill, at McGehee, Arkansas

 International Paper at Franklin, Virginia

 Weyerhaeuser, Vanceboro, North Carolina

 Rayonier, Fernandina, Florida

 Georgia-Pacific, Naheola Mill, Pennington, Alabama

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. We are pleased to assist you

with this effort and we will be happy to provide additional help as needed in your efforts related

to effluent limitations guidelines review.

ec: Jerry Schwartz, AF&PA

Arun Someshwar, NCASI
Elizabeth Sabol, ERG

August 12, 2011

Page 2

AbitibiBowater, Calhoun, TN

General Mill Questions:

1. Were there major changes in pulp bleaching operations between 2005 and 2009 (such as new

or decommissioned bleach plants)?

No major changes between 2005 and 2009

2. Does the mill use hypochlorite to bleach pulp?

No hypochlorite used to bleach pulp

2009 TRI Form R Report for Dioxin and Dioxin-like Compound Releases to Water:

1. Are the attached data accurate for the report made for 2009? (if not, provide corrected

information)

Yes

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

2009 reported data were based on measurements made in previous years, adjusted for the

2009 effluent flow.

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

The effluent data was measured after the post-ECF modifications (ECF in June 2000, data

from October 2000). The October 2000 measured concentrations were then combined with

the 2009 discharge flow to estimate the releases to water. The mill reported the difference

between the effluent and the dioxin measured in the Hiwassee River in 1995 and 1996.

4. How were analytical results at or below the analytical minimum level or detection limit

treated (i.e., were < “less than” values treated as zero, as some fraction of the detection limit)?

non-detects treated as zero

5. Did the mill recognize that EPA’s TRI dioxin and dioxin/like congener numbering sequence

changed for the 2008 reporting year and beyond?

Yes, 2009 is in the correct sequence

Finally, for NPDES DMR data reported in 2009: The 2009 DMR data has all TCDD and TCDF

concentrations reported as below the detection limit, except for the daily maximum concentration

of 1.00 x 10-8 mg/L for 5/2009 outfall 01B. Please verify the value and that it was detected.
Elizabeth Sabol, ERG

August 12, 2011

Page 3

[NCASI note: it would appear from the data provided below that the daily maximum

concentrations should have also carried a “<” sign.]

May 4, 2009:

Boise at Jackson, Mississippi

[NCASI note: the information provided by the mill was sent in an uneditable PDF format.

It is copied below as a picture.]
Elizabeth Sabol, ERG

August 12, 2011

Page 4

Boise at Wallula, Washington

General Mill Questions:

1. Were there major changes in pulp bleaching operations between 2005 and 2009 (such as new

or decommissioned bleach plants)?

No

2. Does the mill use hypochlorite to bleach pulp?

No.

2009 TRI Form R Report for Dioxin and Dioxin-like Compound Releases to Water:

1. Are the attached data accurate for the report made for 2009? (if not, provide corrected

information)

No - correct data is shown in the attached spreadsheet. A revised Form-R was submitted in

September 2010. The revision included:

• Elimination of reporting a "quantity treated on-site" (due to a previously incorrect

assumption)

• Using actual dioxin test results instead of published emission factors for our

effluent and primary sludge

• Correcting a formula for calculating the emissions from the Recovery Boilers that

caused that number to be off by a factor of 10

As a result, the reported "Dioxin and Dioxin-like Compounds" releases changed as

follows:

• Air emissions from 0.18 g to 0.41 g

• To the River – went from 0.21 g to 2.32 g

• To the Landfill – went from 2.10 g to 3.82 g

• Total – went from 2.48 g to 6.55 g

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

Yes - an actual measurement of the effluent minus the river water values reported in the

2010 NCASI SARA Handbook
Elizabeth Sabol, ERG

August 12, 2011

Page 5

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

Based on actual data, in part. Water data from published data.

4. How were analytical results at or below the analytical minimum level or detection limit treated

(i.e., were < less thanvalues treated as zero, as some fraction of the detection limit)?

Included the actual effluent test data in the attached spreadsheet. Used one-half the

detection limit for the ND values.

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

changed for the 2008 reporting year and beyond?

Yes

Clearwater Arkansas Mill at McGehee, Arkansas

General Mill Questions:

1) Were there major changes in pulp bleaching operations between 2005 and 2009 (such as new

or decommissioned bleach plants)?

Answer: No

2) Does the mill use hypochlorite to bleach pulp?

Answer: No

2009 TRI Form R Report for Dioxin and Dioxin-like Compound Releases to Water questions:

1. Are the attached data accurate for the report made for 2009? (if not, provide corrected

information)

We found an error in the reported 1,2,3,4,6,7,8,9 OCDD (Octachlorodibenzo-p-dioxin). We

reported 0.1529 grams per year. An error was made in converting from pg to grams. The

actual emissions of this compound is 1.529 grams per year. All of the other congeners are

correct.

2. Were the data reported for 2009 based on actual measurement(s) of effluent discharges?
Elizabeth Sabol, ERG

August 12, 2011

Page 6

Measurements for 2,3,7,8 TCDD and 2,3,7,8 TCDF were based on actual measurements.

Measurements for the other congeners were not.

3. If not actual effluent data, what was the basis for estimating releases to water.

Estimates for the 2,3,7,8 TCDD and 2,3,7,8 TCDF were base on actual measurements.

Measurements for the other congeners were based on NCASI SARA 313 Reporting

Guidance (February 2010). The data was obtained from Table 14 (Mills with ASBs) of

NCASI's Chemical Specific Information for Dioxin and Dioxin-like Compounds.

4. How were analytical results at or below the analytical minimum level or detection limit treated

(i.e., were < "less than" values treated as zero, as some fraction of the detection limit)?

All non-detects were assumed = 0.

5. Did the mill recognize that EPA’s TRI dioxin and dioxin/like congener numbering sequence

changed for the 2008 reporting year and beyond?

Yes.

International Paper, Franklin, Virginia

General Mill Questions:

1. Were there major changes in pulp bleaching operations between 2005 and 2009 (such as new

or decommissioned bleach plants)?

April 5, 2006 the Franklin Mill stopped using Ozone bleaching and went to ClO2 bleaching

on one bleach line (F Bleach Line). This change did not change the factors we used from

NCASI Dioxin and Dioxin-Like Compounds guidance in Table 14 for Elemental Chlorine

Free Bleaching.

2. Does the mill use hypochlorite to bleach pulp?

The Franklin Mill does not use hypochlorite to bleach pulp.

2009 TRI Form R Report for Dioxin and Dioxin-like Compound Releases to Water:

1. Are the attached data accurate for the report made for 2009? (if not, provide corrected

information)

The data are correct in the attached report.
Elizabeth Sabol, ERG

August 12, 2011

Page 7

[NCASI note: the attached report refers to EPA’s spreadsheet]

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

The data reported for 2009 was not based on actual measurements of effluent discharges.

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

The data used for the 2009 report was based on factors published in NCASI Guidance for

reporting Dioxin and Dioxin-Like Compounds, Table 14, PCDD/F Concentrations in Eight

ECF Bleached Chemical Pulp Mill Treated Effluents (NCASI 2002).

4. How were analytical results at or below the analytical minimum level or detection limit

treated (i.e., were < “less than” values treated as zero, as some fraction of the detection limit)?

Footnote 1 on Table 14 indicates that all non-detects are assumed = 0.

5. Did the mill recognize that EPA’s TRI dioxin and dioxin/like congener numbering sequence

changed for the 2008 reporting year and beyond?

Yes. The Franklin mill reported the congener numbering sequence correctly for 2008,

2009, and 2010.

Weyerhaeuser at Vanceboro, North Carolina

General Mill Questions:

1. Were there major changes in pulp bleaching operations between 2005 and 2009 (such as new

or decommissioned bleach plants)?

No

2. Does the mill use hypochlorite to bleach pulp?

No

2009 TRI Form R Report for Dioxin and Dioxin-like Compound Releases to Water:

1. Are the attached data accurate for the report made for 2009? (if not, provide corrected

information)

Yes
Elizabeth Sabol, ERG

August 12, 2011

Page 8

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

Partially.

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

For all cogeners other than 1,2,3,4,6,7,8,9-OCDD, releases were calculated using the

NCASI Pulp and Paper SARA 313 Chemical Specific Guidance for Dioxin and Dioxin-Like

Compounds (Table 14). The concentrations in that table are based on the study results

published in NCASI TB 844. As indicated in that technical bulletin on Section 1.1

paragraph 2, to the extent possible PCDD and PCDF in raw materials that pass through

the mill should not be counted in the effluent. Paragraph 8 of that section indicates that

OCDD is likely present in measurable amounts in the reported emissions from that study

as well as other mill inputs. Based on those statements, for OCDD, the facility conducted

analysis of the influent concentration for OCDD and found a level of 10.4 pg/l. The

calculations utilize the NCASI factor for OCDD of 73.3 pg/l but subtracts the site-specific

measured native concentration of 10.4 pg/l to arrive at an effluent concentration of 63.3

pg/l.

4. How were analytical results at or below the analytical minimum level or detection limit treated

(i.e., were < “less than” values treated as zero, as some fraction of the detection limit)?

NA

5. Did the mill recognize that EPAâ€TMs TRI dioxin and dioxin/like congener numbering

sequence changed for the 2008 reporting year and beyond?

Yes

Rayonier, Fernandina Beach, Florida

General Mill Questions:

1. Were there major changes in pulp bleaching operations between 2005 and 2009 (such as new

or decommissioned bleach plants)?

There were no major changes.

2. Does the mill use hypochlorite to bleach pulp?

The mill does use Hypochlorite as a viscosity modifier in the process periodically.
Elizabeth Sabol, ERG

August 12, 2011

Page 9

[NCASI note: this mill manufactures dissolving pulp and thus is not subject to the same

requirements promulgated for papergrade chemical pulp mills in the Cluster Rule.]

2009 TRI Form R Report for Dioxin and Dioxin-like Compound Releases to Water:

1. Are the attached data accurate for the report made for 2009? (if not, provide corrected

information)

The data appear to be correct.

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

The data were based on actual quarterly measurements.

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

Same as for #2.

4. How were analytical results at or below the analytical minimum level or detection limit treated

(i.e., were < “less than” values treated as zero, as some fraction of the detection limit)?

Less than results were treated as zero.

5. Did the mill recognize that EPA’s TRI dioxin and dioxin/like congener numbering sequence

changed for the 2008 reporting year and beyond?

The mill did recognize this and made sure to report accordingly.

Georgia-Pacific, Naheola Mill, Pennington, Alabama

I inadvertently switched the water and land release numbers in the 2009 SARA 313 dioxin Form

R. The total grams of dioxin released to all media were reported correctly but the grams released

to water and grams released to land were transposed. I am attaching the spreadsheet that you

sent that includes the originally reported numbers for water releases with the corrected numbers

added in red font. I am also attaching another spreadsheet that summarizes dioxin releases to all

media.

We will be submitting a revised Form R to EPA with the corrected media amounts.

Answers to Paul Wiegand’s questionnaire are also noted below.
Elizabeth Sabol, ERG

August 12, 2011

Page 10

General Mill Questions:

1. Were there major changes in pulp bleaching operations between 2005 and 2009 (such as new

or decommissioned bleach plants)?

No

2. Does the mill use hypochlorite to bleach pulp?

Not virgin pulp but a portion of post-converting tissue broke receives hypo treatment.

2009 TRI Form R Report for Dioxin and Dioxin-like Compound Releases to Water:

1. Are the attached data accurate for the report made for 2009? (if not, provide corrected

information)

Water and Land data were switched, correct data attached.

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

No

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

NCASI release factors.

4. How were analytical results at or below the analytical minimum level or detection limit treated

(i.e., were < less than values treated as zero, as some fraction of the detection limit)?

NA

5. Did the mill recognize that EPAs TRI dioxin and dioxin/like congener numbering sequence

changed for the 2008 reporting year and beyond?

Yes.
Boise White Paper LLC

Wallula, WA

99363BSCSCPOBOX

TRI Data

Grams 

Discharged Basis of Estimate 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17

0.209 O

Total Water Release 

Grams Discharged 0.003746 0.001434 0.001718 0.002868 0.001266 0.020978 0.125814 0.032551 0.001563 0.001795 0 0 0.001019 0.000546 0 0 0.013563

2.320 RY 2009 Form-R Values 0.034618 0.003643 0.005942 0.005709 0.005425 0.261445 1.353729 0.470188 0.030226 0.045469 0.005193 0.004237 0.094554

Effluent Test Data, pg/L 1.34 ND ND ND ND 15.1 87.1 18.2 1.17 1.76 ND ND ND ND ND ND 6.84

DL 0.281 0.459 0.442 0.420 0.281 0.284 0.327 0.401 0.418 0.380

Dioxin and Dioxin-Like Compound Congeners

CASNU Chemical Name

Congener 

Number

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

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

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

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

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

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

3268879 Octachlorodibenzo-p-dioxin 7

51207319 Tetrachlorodibenzofuran, 2,3,7,8- 8

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

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

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

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

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

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

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

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

39001020 Octachlorodibenzofuran 17

2009

Congener Number

2009
Georgia-Pacific Consumer Products LP

Pennington, AL

36916JMSRVROUTE

TRI Data

Grams 

Discharged Basis of Estimate123456789 10 11 12 13 14 15 16 17

2.0 E1

Total Water Release 

Grams Discharged000 0.01 0.01 0.14 1.7 0.070000 0.010 0.010 0.03 1.98

3.6 E1--Corrected

CORRECT Total Water 

Release Grams 

Discharged000 0.09 0.06 0.47 2.65 0.07000000 0.13 0.03 0.14 3.64

Dioxin and Dioxin-Like Compound Congeners

CASNU Chemical Name

Congener 

Number

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

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

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

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

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

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

3268879 Octachlorodibenzo-p-dioxin7

51207319 Tetrachlorodibenzofuran, 2,3,7,8-8

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

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

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

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

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

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

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

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

39001020 Octachlorodibenzofuran 17

2009

Congener Number

2009
Georgia-Pacific, Naheola, Pennington, AL

GramsActual Total

CORRECTED CONGENER SEQUENCE

Grams 

per year 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17

Form R 

Schedule 1 

Section:

2,3,7,8-TCDD1,2,3,7,8-PeCDD1,2,3,4,7,8-HxCDD1,2,3,6,7,8-HxCDD1,2,3,7,8,9-HxCDD1,2,3,4,6,7,8-HpCDD1,2,3,4,6,7,8,9-OCDD2,3,7,8-TCDF1,2,3,7,8-PeCDF2,3,4,7,8-PeCDF1,2,3,4,7,8-HxCDF1,2,3,6,7,8-HxCDF1,2,3,7,8,9-HxCDF2,3,4,6,7,8-HxCDF1,2,3,4,6,7,8-HpCDF1,2,3,4,7,8,9-HpCDF1,2,3,4,6,7,8,9-OCDF

Section 

5.1 - 

Releases 

to Air - 0.00 0.00 0.00 0.01 0.09 0.33 0.01 0.00 0.01 0.01 0.01 0.00 0.01 0.02 - 0.04 0.56

Releases 

to Land 0.00 - - 0.01 0.01 0.14 1.70 0.07 0.00 0.00 0.00 - 0.01 - 0.01 0.00 0.03 1.99

Releases 

to Water - - - 0.09 0.06 0.47 2.65 0.07 - - - - - - 0.13 0.03 0.14 3.64

6.18

Total 

(Will be 

automatically 

Calculated in 

TRI-MEwebmay vary due 

to rounding)

Dioxin is reported in grams per year. 
NCASI Email Correspondence

From: "Wiegand, Paul" PWiegand@NCASI.org

Sent: August 30, 2011 8:37 AM

To: Elizabeth Sabol

Cc: Gray, Jessica; Schwartz, Jerry; Someshwar, Arun; swietlik.william@epa.gov

Subject: Re: Prelimiary Responses to Pulp and Paper TRI Questions

Elizabeth,

Attached is the second round of responses from the mills. There are 6 included here, which brings the 

total response to date to 14 mills. We will provide reminders to the remaining 5 this week.

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

Sent: Thursday, August 25, 2011 11:10 AM

To: Wiegand, Paul

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

Subject: Re: Preliminary Responses to Pulp and Paper TRI Questions

Paul,

I just wanted to follow-up with you on the data collection for the remaining pulp and paper mills. Do you 

have a time frame of when the information would available? 

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

Sent: August 15, 2011 1:21 PM

To: Wiegand, Paul

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

Subject: Re: Preliminary Responses to Pulp and Paper TRI Questions

Paul,

Thank you for your time and effort in collecting and providing the data on these 8 mills. We look forward 

to gathering the responses from the remaining mills.

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: "Wiegand, Paul" PWiegand@NCASI.org

Sent: August 12, 2011 6:29 PM

To: Elizabeth Sabol

Cc: Gray, Jessica; Schwartz, Jerry

Subject: Re: Prelimiary Responses to Pulp and Paper TRI Questions

Elizabeth,

As promised, find attached responses from 8 of the 19 mills about which you requested information 

concerning TRI reports. Please call on me if you have any questions about this information.

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: "Wiegand, Paul" PWiegand@NCASI.org

Sent: July 18, 2011 5:24 PM
To: Jessica Gray

Cc: Sabol, Elizabeth; Schwartz, Jerry

Subject: Re: Pulp and Paper TRI Questions

Jessica,

Thanks for getting back to us. I do recall sending the table some years ago and it was part of our 2005 

handbook. The exact same table is still present in our handbook, as revised in April 2010 and therefore it 

is not likely that the differences between the distribution of congeners reported by the 19 mills in your list 

occurred because of changes to the information in the NCASI TRI Handbook. That still leaves the 

question as to why the congener distribution from these mills might be different from the eight ECF 

bleaching mills on which the data for Table 14 in the handbook was derived. To that end, I propose that 

we ask the mills the following questions. If you concur with this list of questions, we will proceed with 

requesting the information.

Questions for select mills regarding TRI reports for 2009 dioxin and dioxin-like compound releases to 

water:

General Mill Questions:

1. Were there major changes in pulp bleaching operations between 2005 and 2009 (such as new or 

decommissioned bleach plants)?

2. Does the mill use hypochlorite to bleach pulp?

2009 TRI Form R Report for Dioxin and Dioxin-like Compound Releases to Water:

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

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

3. How were analytical results at or below the analytical minimum level or detection limit treated 

(i.e., were < “less than” values treated as zero, as some fraction of the detection limit)?

4. Did the mill recognize that EPA’s TRI dioxin and dioxin/like congener numbering sequence 

changed for the 2008 reporting year and beyond?

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: Jessica Gray

Sent: Friday, July 15, 2011 7:52 AM

To: Wiegand, Paul
CC: Jerry Schwartz; Elizabeth Sabol

Subject: Re: Pulp and Paper TRI Questions

Paul,

Sorry for the delay getting you the information from the handbook that we previously used to calculate 

the dioxin and dioxin-like compound distributions. The attached file includes the distribution we received 

as follow-up to a meeting between EPA, AF&PA, and NCASI on April 5, 2005.

Please let us know if you have any other information that can assist us in determining the difference 

between this distribution and what facilities reported to TRI for 2009.

Thanks,

Jess

Jessica Gray

Eastern Research Group, Inc. (ERG)

14555 Avion Parkway Suite 200

Chantilly, VA 20151

703-633-1681

703-263-7280 (fax)

jessica.gray@erg.com

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

Sent: July 8, 2011 12:40 PM

To: Wiegand, Paul

Subject: Re: Pulp and Paper TRI Questions

Paul,

We are working on pulling together the information from the handbook that we previously used to 

calculate dioxin water distributions in TRI. We will have the this information to you on Monday July 11. 

Hopefully this will help with determining the difference in distributions.

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: "Wiegand, Paul" PWiegand@NCASI.org

Sent: July 8, 2011 12:08 PM

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

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

Subject: Re: Pulp and Paper TRI Questions
Elizabeth,

I’ve gotten a few things off my desk and will begin working on gathering the data we discussed on 

Wednesday afternoon. During that conversation, you mentioned the need to understand dioxin/dioxinlike compound TRI reports for the year 2009 relative to a prior reporting period, but you didn’t recall at 

the time which reporting year that was. Maybe we got crossed up on the e-mail address, but I haven’t 

received anything from you. Can you send me those details?

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