# n ca si

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.or g 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 Mill s My previous communication s to you of August 12 , 30 , and September 23, 2011 conveyed responses from 1 7 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 f acility response included here is :

 Clearwater, Lewiston, Idaho If you have questions ab out 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 rel ated to effluent limitations guidelines review.

ec: Jerry Schwartz, AF&PA Arun Someshwar, NCASIElizabeth 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 t he 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.

# n ca si

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
- 6 417 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 Mill s My previous communication s 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 rec eived since that time from three 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 :

· International Paper, Riegelwood, North Carolina

· Georgi a
- 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 th is 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, NCASIEli zabeth Sabol, ERG September 23, 2011 Page 2 

## International Paper, Riegelwood, North Carolina
General Mill Questio ns: 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 Releas es 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 provid ed 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 diox in 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 analyt ical 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 TR I dioxin and dioxin/like congener numbering sequence changed for the 2008 reporting year and beyond?
YesEli zabeth 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 a s new or decommissioned bleach plants)?
No. 2. Does the mill use hypochlorite to bleach pulp? No, we use C l O 2 . 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. Ho w 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 co ngener numbering sequence changed for the 2008 reporting year and beyond? Yes, these changes were made.Eli zabeth Sabol, ERG September 23, 2011 Page 4



## N ippon, Port Angeles, Washington
General Mill Questions:
1. Were there major cha nges 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 H 2 O 2 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., wer e < “ 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 s equence 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 d ata for the effluent sample.

# n ca si

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 Mill s 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 o perational 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 limitati ons guidelines review.

ec: Jerry Schwartz, AF&PA Arun Someshwar, NCASIElizabeth Sabol, ERG August 30 , 2011 Page 2 

## Domtar, Plymouth, North Carolin a 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 – 200 9. 2. Does the mill use hypochlorite to bleach pulp?
We do not us e 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, p rovide corrected information).
Yes. 2. Were the data reported f or 2009 based on actual measurement(s) of effluent discharges? Partially, f acility 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 ar e from NCASI SARA 313 Guidance for Dioxins and Dioxin

like 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 dete ction 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 2 008 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 u se 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, p rovide corrected inf ormation).
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 approa ches) 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 det ection 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 2 008 reporting year and beyond?
Yes.Elizabeth Sabol, ERG August 30 , 2011 Page 4 

## Georgia

- Pacific, Palatka, Florida
General Mill Questi ons: 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 delignific ation 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 cor rected 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 ba sed 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 d ioxin/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 th e 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 r eported 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


## RockTe nn, 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 bas is for estimating releases to water? RockTenn's Demopolis Mill used the emission factors from Table 14 of the Februar y 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 report ed 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 no t, p rovide 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?
Y es, 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 occur ring 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 t est 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 2 008 reporting year and beyond?
Yes , we changed the numbering sequence to match EPA ’ s sequence change in 2008 and beyond.

# n ca si

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 Mill s 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 Sch wartz 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, Mississ ippi

 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 r esponses, 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, NCASIElizabeth Sabol, ERG

August 12, 2011 Page 2 

## AbitibiBowater, Ca l houn, 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

- l ike 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 esti mating 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 e stimate the releases to wat er. 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 corr ect 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 o f 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 R ecovery 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 Landfil l

– 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 NCA SI SARA HandbookElizabeth 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 limi t 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 question s: 1. Are the attached data accurate for the r eport 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 analytica l 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 sequ ence 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 Fr ee Bleaching.
2. D oes 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 repor t 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 anal ytical 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 dio xin 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 Re leases to Water: 1. Are the attached data accurate for the report made for 2009? (if not, provide corrected information)
YesElizabeth 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 d ata, 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 c oncentrations in that table are based on the study results published in NCASI TB 844. As indicated in that technical bull e tin on Section 1.1 paragraph 2, to the extent possible PCDD and PCDF in raw materials that pass through the mill should not be count ed in the effluent. Paragraph 8 of that section in dic ates 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 paperg rade 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 corre ct. 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 E PA’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 summarize s 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 n ew
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)
Wa ter 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 2009Georgia-Pacific Consumer Products LP Pennington, AL 36916JMSRVROUTE

TRI Data

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

2.0 E1 Total Water Release Grams Discharged 0 0 0 0.01 0.01 0.14 1.7 0.07 0 0 0 0 0.01 0 0.01 0 0.03 1.98

3.6 E1--Corrected CORRECT Total Water Release Grams Discharged 0 0 0 0.09 0.06 0.47 2.65 0.07 0 0 0 0 0 0 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-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 2009Georgia-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 inTRI-MEwebmay vary due to rounding)

Dioxin is reported in grams per year.NCASI Email Correspondence

F rom: "Wiegand, Paul" PWiegand@NCASI.org Sent: August 30, 2011 8:37 A M 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 fo r 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

F rom: 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 info rmation 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

- 1659F rom: Elizabeth Sabol [mailto:Elizabeth.Sabol@erg.com] Sent: August 1 5, 20 11 1:21 P M 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, Su ite 200 Chantilly, VA 20151 elizabeth.sabol@erg.com Phone:703

- 633

- 1659

F rom: "Wiegand, Paul" PWiegand@NCASI.org Sent: August 12, 2011 6:29 P M 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

F rom: "Wiegand, Paul" PWiegand@NCASI.org Sent: July 18, 2011 5:24 P MTo: 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. Ques tions 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, wh at 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 mil l 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

F rom: Jessica Gray Sent: Friday, July 15 , 2011 7:52 A M To: Wiegand, PaulCC: 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 differenc e 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

F rom: Elizabeth Sabol [mailto:Elizabeth.Sabol@erg.com] Sent: July 8 , 2011 12:40 P M 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 differenc e 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

F rom: "Wiegand, Paul" PWiegand@NCASI.org Sent: J uly 8, 2011 12:08 P M To: Elizabeth Sabol [mailto:Elizabeth.Sabol@erg.com] Cc: swietlik.william@epa.gov; Jessica Gray Subject: Re: Pulp and Paper TRI QuestionsElizabeth, 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/dioxin

like 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 1331 8 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