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

Project No.: 0172.09.005.410 Page 1 of 1

Project Name: 2012 Final Cat Rev CBI?

Yes

No

TELEPHONE CALL RECORD

Incoming

Outgoing

Date: 02/28/12 Time: 9:40 am

pm

Company Name: Washington State Department of Ecology ERG Staff Name: Kimberly Landick

Contact Name: Craig McCormack Contact Phone Number: (360) 407-7193

General Subject: 2009 Dioxin Discharges

TOPICS DISCUSSED AND ACTION TAKEN

On February 28, 2012 at 9:40 am I called Craig McCormack and left a message. 

At 10:41am Mr. McCormack returned my call and asked what type of studies I was looking for. Examples are 

source assessments, analytical determination of background concentration, and sediment quality standards. He 

stated that the WA DOE is doing many dioxin studies currently. 

At 12:25pm Mr. McCormack returned my call and stated that they have been doing a lot of environmental 

health studies of Puget Sound, primarily looking at sediments. He asked if I could send an email with a 

summary of our discussion and he would send me what documents he could. His email is: 

cmcc461@ecy.wa.gov. He also stated he would send any information he could find out internally on the Region 

10 high volume experimental sampling. I sent him an email at 1:10pm. 

Please see attached email communication.

On May 2, 2012 at 3:30pm I called Kim Wigfield (360-407-6931) who supervises the WADOE permit writers 

who manage the refinery permits. I asked her if the petroleum refining discharges have been affecting their 

receiving waters at all. Ms. Wigfield stated that she does not know if the discharges are affecting the waters. 

She believes that they are most likely not affecting them, but she does not have data to back that up. She also 

stated that none of the refineries are detecting dioxins in their effluent but most of them are detecting metal 

compounds. The only facility that did detect dioxin recently was Tosoro and upon further monitoring, no 

additional detections were found. She stated that I need to call Teddy Le about the pulp and paper facilities 

(703-407-6948). 

On May 2 at 4pm I called Teddy Le and left a message.

On May 4 at 11:30am, Teddy Le returned my call. He stated that he was not familiar with the Boise White 

Paper Facility (with the dioxin congener detected equal to the minimum level), but that he would look into it 

and get back to me. He quickly glanced at the facility permit and stated that there is a foot note stating that the 

facility much achieve a level less than or equal to the 10 pg/L minimum level for 2,3,7,8-TCDD. Therefore, he 

concluded that because the discharge is equal to the minimum level it is not a concern to WADOE. However, he 

stated he would follow up with an email. 

Please see attached email communication.
WA DOE Email Chain: 

From: Kimberly Landick [mailto:Kimberly.Landick@erg.com] 

Sent: Tuesday, February 28, 2012 10:12 AM

To: McCormack, Craig (ECY)

Cc: William Swietlik; Eleanor Codding

Subject: Recent Washington State Department of Ecology Dioxin Studies

Dear Mr. McCormack,

Thank you for returning my phone call. Eastern Research Group, Inc. (ERG) under EPA Contract No. 68-

C-02-095 is e-mailing you on EPA’s behalf to request recent dioxin data or studies conducted by the 

Washington State Department of Ecology. Please see below for further background. 

EPA reviews publicly-available discharge monitoring report and toxic release inventory 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 2012 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 2012 Effluent Guidelines Program Plan scheduled for publication in the Federal Register in September 

2012. 

From you, we are looking for any recent studies conducted or data collected on wastewater effluent 

discharges of dioxin compounds, specifically from pulp and paper mills and petroleum refineries. 

Previously, EPA reviewed the Washington State Dioxin Source Assessment (July 1998), and we are 

interested in any updates. Also, we are also interested in any information you may have regarding the 

high volume experimental sampling done by Region 10 in Lewiston, ID for dioxin discharges. We believe 

this sampling was done between 2005-2007.

We appreciate your help in providing recent studies and/or data. Please call me at (703) 633-1119 if you 

have any questions. If you would like to speak directly with EPA regarding this request, you can contact 

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

or by email: swietlik.william@epa.gov.

Thank you,

Kimberly

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

Kimberly D. Landick

Environmental Engineer

Eastern Research Group, Inc. 

14555 Avion Parkway, Suite 200

Chantilly, VA 20151

kimberly.landick@erg.com

Phone: 703-633-1119

From: McCormack, Craig (ECY)

Sent: Wednesday, February 29, 2012 11:13 AM
To: Susewind, Kelly (ECY)

Cc: Landick, Kimberly

Subject: FW: Recent Washington State Department of Ecology Dioxin Studies

Kelly:

I believe the Water Quality Program would the appropriate Program to respond to the correspondence 

below requesting information/studies on effluent discharges of dioxins/furans from pulp and paper mills. 

Please contact Kimberly Landick directly with questions regarding her request for information on behalf 

of EPA. If the Water Quality Program is not the appropriate office to respond to the request for 

information then please forward to the office you think can respond with a cc to Ms. Landick. Also, Ms. 

Landick requested contact information within EPA Region – 10 of your counterpart.

Thanks, Regards/Craig

From: McCormack, Craig (ECY)

Sent: Wednesday, February 29, 2012 12:50 PM

To: Landick, Kimberly

Subject: Dioxin in Puget Sound, Washington

http://www.kplu.org/post/puget-sound-tub-tainted-industrial-residue-toxic-dioxin

From: "Kmet, Nancy (ECY)" <nkme461@ECY.WA.GOV>

Sent: Thursday, March 1, 2012 5:27 PM

To: Landick, Kimberly

Subject: FW: Recent Washington State Department of Ecology Dioxin Studies

Your information request came to me in a round-about way. I have attached the dioxin information for the 

pulp mills found in the Ecology Water Quality Program’s Permit And Reporting Information System 

(PARIS) database. The data covers the time period from January 2005 through January 2012. The pulp 

mills submitted this data as required by their NPDES permits.

The Industrial Section manages the pulp mills and the refineries in the state. The section files may have 

additional dioxin information in paper reports. 

The section may have compiled the dioxin information for the refineries in an EXCEL spreadsheet. Please 

contact Kim Wigfield for that information. Kim supervises the Ecology permit writers who manage the 

refinery permits. kim.wigfield@ecy.wa.gov

Teddy Le manages the pulp and paper mill permit writers and may have some additional information for 

the pulp mills. Please contact him for further pulp and paper mill information. teddy.le@ecy.wa.gov

If you have any questions about the data in PARIS please feel free to give me a call. 

Nancy Kmet

Ecology

Water Quality Program

360-407-6158

nancy.kmet@ecy.wa.gov

From: McCormack, Craig (ECY)

Sent: Sunday, March 4, 2012 12:35 PM
To: Landick, Kimberly

Subject: FW: Recent Washington State Department of Ecology Dioxin Studies

Not sure if you received this information

From: Kmet, Nancy (ECY) 

Sent: Thursday, March 01, 2012 10:20 AM

To: McCormack, Craig (ECY)

Cc: Norton, Dale (ECY); Fernandez, Arianne (ECY)

Subject: FW: Recent Washington State Department of Ecology Dioxin Studies

Seven facilities, 6 of which are pulp mills, monitor for 2,3,7,8 TCDD on a routine basis. The attached 

spreadsheet shows the facilities and the associated monitoring point where dioxin monitoring is require. 

You can access this data using PARIS. 

Other facilities may monitor for 2,3,7,8 TCDD when they collect samples for priority pollutant scans but 

this data (at least for now) is in paper reports and not in PARIS. This would only be accessible by going 

through files. 

The refineries conducted some dioxin studies and collected congener data as well on the effluent and an 

upstream process wastewater flow. This data is in paper reports. When I was in the industrial section I 

entered this data in an excel spreadsheet. Check with Kim Wigfield in the industrial section if they 

continued to do this after I left. 

I can show you how to access the data in PARIS.

This is the link to the internal version of PARIS. 

http://ecydblcyorwq06/paris/f?p=paris:home

If external users are interested they can obtain data from the external application.

https://fortress.wa.gov/ecy/wqreports/public/f?p=110:300

Let me know if you have any questions.

Nancy Kmet

360-407-6158

nancy.kmet@ecy.wa.gov

From: Norton, Dale (ECY) 

Sent: Thursday, March 01, 2012 9:09 AM

To: McCormack, Craig (ECY)

Cc: Fernandez, Arianne (ECY); Kmet, Nancy (ECY)

Subject: RE: Recent Washington State Department of Ecology Dioxin Studies

Craig

We have not done any recent effluent monitoring for dioxins in EAP. Here are a couple of potential 

sources of information. 
I would check with Nancy Kmet in the WQP program to see if any effluent monitoring data would have 

been required under NPDES permits. The industrial section in the W2R program regulates refineries. 

Garin Schrieve is the section manager for the industrial section.

Also I believe that some of the new NPDES permits for municipal and industrial discharges to the 

Spokane R. have some monitoring requirements for dioxins. I doubt any data has been generated yet. 

Arianne Fernandez at ERO would be the contact.

Mike Cox (206) 553-1597 is the manager of the Environmental Assessment Section at EPA Region 10

Dale Norton

Washington State Department of Ecology

Environmental Assessment Program

Toxics Studies Unit Manager

360 407-6765

Dale.Norton@ECY.WA.GOV

From: McCormack, Craig (ECY) 

Sent: Wednesday, February 29, 2012 12:29 PM

To: Norton, Dale (ECY)

Subject: FW: Recent Washington State Department of Ecology Dioxin Studies

Dale: Valerie Partridge suggested I forward to you the request for information on dioxin/furan effluent 

discharges – please see below. Thanks/Craig

From: Kimberly Landick [mailto:Kimberly.Landick@erg.com] 

Sent: Monday, March 12, 2012 4:10 PM

To: McCormack, Craig (ECY)

Cc: William Swietlik; Eleanor Codding

Subject: Re: FW: Recent Washington State Department of Ecology Dioxin Studies

Mr. McCormack: 

Thank you for providing information on recent dioxin studies and other people to contact within 

Washington State Department of Ecology. We are currently reviewing the data we received along with 

other sources and will let you know if we have any further questions. 

Thanks again,

Kimberly 

From: Kimberly Landick [mailto:Kimberly.Landick@erg.com] 

Sent: Monday, March 12, 2012 4:54 PM

To: kim.wigfield@ecy.wa.gov; nkme461@ecy.wa.gov; teddy.le@ecy.wa.gov

Cc: William Swietlik; Eleanor Codding

Subject: Pulp and Paper Facility Dioxin Studies

Dear Ms. Kmet, Ms. Wigfield, and Mr. Le:

Thank you for providing the dioxin information for the pulp mills found in the Ecology Water Quality 

Program's Permit and Reporting Information System database. We have some follow-up questions listed 

below. 
As a reminder, Eastern Research Group, Inc. (ERG) under EPA Contract No. 68-C-02-095 is e-mailing 

you on EPA's behalf. EPA reviews publicly-available discharge monitoring report and toxic release 

inventory 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 2012 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 2012 Effluent Guidelines Program Plan scheduled for publication in the 

Federal Register in September 2012. 

We have the following additional questions as we look at the data:

1. Is there Petroleum Refining data available similar to the pulp and paper dioxin data provided?

2. In the attached spreadsheet initially sent to us, titled "Pulp&PaperMillDioxinData1-2005thru2-12 with 

questions" (data corresponding to questions below is highlighted green): 

2a. What is the meaning of the column Limit Max? Is 10 the minimum level (which is the same as the 

EPA minimum level for EPA Method 1613B)?

2b. For Boise Cascade, what does the Monitor Pt Code "SLUD" stand for? Why does it have units of 

#/100ml? 

2c. Similarly, for Kimberly Clark, why are some units #/100mL?

2d. What is the dash representing in the column Value Qualifier? Does this mean TCDD was measured? 

In some cases, values with a "non-detect" qualifier are higher than in places where there is just a dash. 

Are all of these "non-detect?"

2e. What analytical method was used?

We greatly appreciate your time in clarifying these questions. If you would prefer to discuss this on the 

phone, please call me at 703-633-1119. 

Thank you,

Kimberly

From: Kmet, Nancy <nkme461@ecy.wa.gov> 

Sent: Tuesday, March 13, 2012 1:29 PM

To: Landick, Kimberly

Cc: William Swietlik; Eleanor Codding; kim.wigfield@ecy.wa.gov; teddy.le@ecy.wa.gov

Subject: RE: Pulp and Paper Facility Dioxin Studies

One correction, the correct unit for the sludge data is likely ng/kg.

Nancy Kmet

360-407-6158

nancy.kmet@ecy.wa.gov

From: Kmet, Nancy (ECY) 

Sent: Tuesday, March 13, 2012 9:24 AM

To: 'Kimberly Landick'; Wigfield, Kim (ECY); Le, Teddy (ECY)

Cc: William Swietlik; Eleanor Codding

Subject: RE: Pulp and Paper Facility Dioxin Studies

The data I sent in the spreadsheet is part of Ecology’s Permit and Reporting Information System (PARIS) 

which includes discharge monitoring data submitted as per the NPDES permit.
1. The refineries do not monitor dioxin on a frequent basis and do not submit dioxin data on their 

DMRs. The refinery permits do have dioxin monitoring in their permits but submit the data in 

report form. The Industrial Section may have compiled some of that data but Kim Wigfield 

will have to respond to this request.

2. Spreadsheet questions

a. Limit Max is the permit limit for 2,3,7,8 TCDD at the identified monitoring point. 

b. BLCH refers to the bleach plant. SLUD refers to the sludge. The units #/100 mL are

an error. Thanks for pointing that out. They should be picograms/liter.

c. Ditto

d. The dash notes that no data was entered into the field which should mean that an actual 

value was measured.

e. The pulp mills use Method 1613 for dioxin.

You can view the Industrial Section permits at the following link.

http://apps.ecy.wa.gov/industrial/final.asp

As noted previously the data in the spreadsheet represents what is in the Ecology database. The 

industrial section may have additional data in paper report. Please contact Kim Wigfield and Teddy Le 

for that data.

Nancy Kmet

360-407-6158

nancy.kmet@ecy.wa.gov

From: Kimberly Landick [mailto:Kimberly.Landick@erg.com] 

Sent: Tuesday, March 13, 2012 4:52 PM

To: Kmet, Nancy

Cc: William Swietlik 

Subject: RE: Pulp and Paper Facility Dioxin Studies

Ms. Kmet,

Thank you for providing clarification on the data. We will direct further questions to the contacts you 

provided. 

Thanks again,

Kimberly

From: Kimberly Landick [mailto:Kimberly.Landick@erg.com] 

Sent: Monday, April 9, 2012 10:37 PM

To: kim.wigfield@ecy.wa.gov; nkme461@ecy.wa.gov; teddy.le@ecy.wa.gov

Cc: William Swietlik; Eleanor Codding

Subject: Pulp and Paper Facility Dioxin Studies

Dear Ms. Kmet, Ms. Wigfield & Mr. Le:

Thank you for sharing the effluent dioxin data from pulp and paper mills in your area from your Permit 

and Reporting Information System. From the spreadsheets of monitoring data, EPA concludes that on 11

sampling dates, dioxin congeners were detected 12 times in wastewater. Of these, only 5 samples at Boise 

Cascade were detected equal to the minimum level (10 pg/L detected; 10 pg/L ML). Additional detections 

were made in sludge samples.
Have these discharges been affecting your receiving waters? That is, do you find this level of dioxin 

discharge to be a concern? EPA would like to include regional considerations in the annual review 

conclusions about wastewater dioxin discharges from pulp and paper mills.

Similarly, EPA is considering reviewing petroleum refinery data for dioxins and metals. How have the 

petroleum refining discharges been affecting your receiving waters, if at all?

As a reminder, Eastern Research Group, Inc. (ERG) under EPA Contract No. 68-C-02-095 is e-mailing 

you on EPA's behalf. EPA reviews publicly-available discharge monitoring report and toxic release 

inventory 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 2012 annual review of existing effluent guidelines and potential industrial guidelines which 

may need to be included (see http://water.epa.gov/lawsregs/lawsguidance/cwa/304m/index.cfm for further 

information). EPA will discuss this review and the results in its 2012 Effluent Guidelines Program Plan 

scheduled for publication in the Federal Register in 2012. 

If you have any questions or would like to discuss this further, please contact me at 703-633-1119.

Thank you,

Kimberly

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

Kimberly D. Landick

Environmental Engineer

Eastern Research Group, Inc. 

14555 Avion Parkway, Suite 200

Chantilly, VA 20151

kimberly.landick@erg.com

Phone: 703-633-1119

From: Kimberly Landick [mailto:Kimberly.Landick@erg.com] 

Sent: Friday, May 4, 2012 9:01 AM

To: teddy.le@ecy.wa.gov

Cc: William Swietlik; Eleanor Codding

Subject: Pulp and Paper Facility Dioxin Studies

Mr. Le:

Thank you for your time on the phone this morning and for sharing the effluent dioxin data from pulp and 

paper mills in your area from your Permit and Reporting Information System. From the spreadsheets of 

monitoring data, EPA concludes that on 11 sampling dates, dioxin congeners were detected 12 times in 

wastewater. Of these, only 5 samples at Boise Cascade were detected equal to the minimum level (10 

pg/L detected; 10 pg/L ML). Additional detections were made in sludge samples.

Please confirm that these discharges have not been affecting your receiving waters. That is, this level of 

dioxin discharge is not a concern. EPA would like to include regional considerations in the annual review 

conclusions about wastewater dioxin discharges from pulp and paper mills.

As a reminder, Eastern Research Group, Inc. (ERG) under EPA Contract No. 68-C-02-095 is e-mailing 

you on EPA's behalf. EPA reviews publicly-available discharge monitoring report and toxic release 
inventory 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 2012 annual review of existing effluent guidelines and potential industrial guidelines which 

may need to be included (see http://water.epa.gov/lawsregs/lawsguidance/cwa/304m/index.cfm for further 

information). EPA will discuss this review and the results in its 2012 Effluent Guidelines Program Plan 

scheduled for publication in the Federal Register in 2012. 

If you have any questions or would like to discuss this further, please contact me at 703-633-1119.

Thank you,

Kimberly

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

Kimberly D. Landick

Environmental Engineer

Eastern Research Group, Inc. 

14555 Avion Parkway, Suite 200

Chantilly, VA 20151

kimberly.landick@erg.com

Phone: 703-633-1119

From: Le, Teddy

Sent: Friday, May 4, 2012 1:00 PM

To: Kimberly Landick 

Cc: Carruthers, Robert (ECY) (roca461@ECY.WA.GOV)

Subject: RE: Pulp and Paper Facility Dioxin Studies

Dear Kimberly:

Based on the information indicated in your e-mail, wastewater sampling for dioxin at Boise Cascade was 

detected equal to the minimum level of 10 pg/L ML. At this level, according to the terms and conditions 

of the current NPDES permit, Ecology determined that Boise Cascade met the mass permit limit for 

2,3,7,8 TCDD of 0.78 mg/day.

Please refer to the Boise Cascade’s NPDES Permit No. WA000369-7 issued on March 13, 2012, 

Condition S1.A, attached for your convenience, contains dioxin limit of 0.78 mg/day. It states in the 

Footnote (e) that “...Compliance with the mass loading 2,3,7,8 TCDD daily limit shall be demonstrated 

if the 2,3,7,8 TCDD concentration is I 0 parts per quadrillion (ppq) or less, or non-detect at a detection

limit of I 0 ppq or less...”

If you have any questions, please contact me at 360-407-6948.

Thanks

Teddy 

From: Kimberly Landick [mailto:Kimberly.Landick@erg.com] 

Sent: Monday, May 7, 2012 4:33 PM

To: teddy.le@ecy.wa.gov
Cc: Carruthers, Robert

Subject: RE: Pulp and Paper Facility Dioxin Studies

Mr. Le:

Thank you for providing this information. At this point we have no further questions but I will let you 

know if that changes.

Thanks again,

Kimberly

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

Kimberly D. Landick

Environmental Engineer

Eastern Research Group, Inc. 

14555 Avion Parkway, Suite 200

Chantilly, VA 20151

kimberly.landick@erg.com

Phone: 703-633-1119
Puget Sound 'tub' tainted by industrial residue of toxic dioxin | KPLU News for Seattle and the Northwest

http://www.kplu.org/post/puget-sound-tub-tainted-industrial-residue-toxic-dioxin[9/4/2012 12:23:16 PM]

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ENVIRONMENT

Puget Sound 'tub' tainted by

industrial residue of toxic dioxin

By Bellamy Pailthorp

When you think about Puget Sound, a bathtub might not be the first image

to come to mind.

But that’s one way environmentalists and scientists sometimes describe it,

because the shape of Puget Sound is an important factor when it comes

to keeping it clean.

A long-awaited report from the Environmental Protection Agency on the

health effects of dioxin is confirming what many experts have known for a

long time.

Credit US EPA image

A dioxin survey map from the EPA, establishing baseline data through sampling

by the research vessel Bold. Sediment samples were collected and analyzed at

70 locations throughout the Sound.

1:50PM

Mon February 27, 2012

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Puget Sound 'tub' tainted by industrial residue of toxic dioxin | KPLU News for Seattle and the Northwest

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Long wait for official nod to science

Twenty seven years, to be more precise. That's how long many activists

say the public has been waiting for the finalization of a "science

assessment" report that formally links dioxins to many serious and chronic

health hazards that can be life-threatening to humans.

The report validates the peer-reviewed findings of numerous research

teams who had already found exposure to dioxin toxic to human health.

“So, for example, suppressing the immune system, reproductive impacts,

neurological impacts,” says Heather Trim, policy director for People for

Puget Sound.

She says these affects are also applicable to wildlife, such as the Sound's

iconic Orca whales or the endangered Chinook salmon they feed on.

EPA cites progress

The EPA's press release looks less alarming than that of the activist

groups, leading with the news that air emissions of dioxins have

decreased by 90 percent since the 1980s. The decrease is attributed to

decades of work by the agency to reduce toxic emissions. The agency

also says "generally, over a person's lifetime, current exposure to dioxins

does not pose a significant health risk."

But, recent sampling by the EPA has provided baseline data on dioxin

hotspots and found dioxins all around the sound, mostly as legacy

pollution from things like pulp and paper mills.

It also comes from landfills that incinerate trash, especially plastics.

And it has been associated with cement production and diesel exhaust.

“We're finding it in Olympia at Bud Inlet, we're finding it at Lora lakes

Apartments, next to Seatac, Bellingham Bay, Everett in Port Gardiner ...

the Duwamish River, Port Angeles, the Columbia River – It's just all over

the sound from these old industrial sources," Trim says.

She says Puget Sound is like a big tub, so pollutants don’t wash out of it.

Instead, they slosh around and settle in.

A persistent poison

Dioxin works its way from the sediments and soil up the food chain and is

most prevalent in fatty foods such as meat, fish and dairy products.

In some neighborhoods near hotspots, community groups have sounded

alarm bells about health hazards that come from ingesting soil or dust

tainted with dioxin. People for Puget Sound's Heather Trim says that in

places such as Seattle's Georgetown or Capitol Hill, there's concern about

hand-to-mouth transfer when people and animals play outside.

"People basically eat a little bit of soil and dust all day long. And dioxin is

absorbed into that soil," Trim says.

But the EPA says 90 percent of human exposure comes from the foods

we eat, so you can reduce your exposure by eating fewer fatty foods.

More work ahead

Activist groups are celebrating the new health report, but also pressing for
Puget Sound 'tub' tainted by industrial residue of toxic dioxin | KPLU News for Seattle and the Northwest

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new limits on how much dioxins are allowed to remain, says Mike Schade

with the Virginia-based Center for Health, Environment and Justice.

“We can’t just shop our way out of this problem. We really need the

federal government, we need the EPA to step up to the plate and

develop a comprehensive plan of action to protect Americans from

exposure to dioxin,” Schade says.

He says a new clean up standard proposed by EPA administrator Lisa

Jackson would reduce the parts per trillion allowed from 1000 to 72,

making it more than ten times as protective.

But that proposed new standard has been languishing at the White House,

in the office of management and budgets, for a year and a half. 

An EPA health report linking dioxin to cancer is also still yet to come.

Editor's note: The original caption to the photo at the top of this story

misinterpreted the significance of the green dots on the EPA sampling

map. They are not dioxin hotspots, but rather locations where baseline

data samples were collected.

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Puget Sound 'tub' tainted by industrial residue of toxic dioxin | KPLU News for Seattle and the Northwest

http://www.kplu.org/post/puget-sound-tub-tainted-industrial-residue-toxic-dioxin[9/4/2012 12:23:16 PM]

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Pulp&PaperMillDioxinData1-2005thru2-2012.xlsx

dmr_data(1)

Facility Name Permit Number Permit Type Permit Status Ecology Contact

Monitoring Period 

Begin Date

Monitoring Period 

End Date

Submission Non 

Report

Outfall 

Name

Monitor Pt 

Code Parameter Fraction Units Statistical Base Sample Date

Measurement 

Value

Value 

Qualifier

Value Non 

Report Limit Min Limit Max

Benchmark 

Min

Benchmark 

Max

Sample 

Type

Sample 

Frequency

Sub 

Violations

Value 

Violations

Parameter 

Violations

Monitoring 

Point 

Violations

Measurement 

Value 

Description

Value 

Facility 

Notes

Value 

Ecology 

Notes

Admin 

Region Facility Region

SIMPSON TACOMA WA0000850 Industrial NPDES IP Active Robert Carruthers 11/1/2011 11/30/2011 - SLDG SLDG 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Single Sample 11/30/2011 1.54 - - - - - - Grab 2/Year - - - - 1.54 - - Industrial Southwest

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 10/1/2011 10/31/2011 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 - - - 10 - - Composite Quarterly - - - - 10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 8/1/2011 8/31/2011 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 - - - 10 - - Composite Quarterly - - - - 10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 5/1/2011 5/31/2011 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 - - - 10 - - Composite Quarterly - - - - 10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 3/1/2011 3/31/2011 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 - - - 10 - - Composite Quarterly - - - - 10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 2/1/2011 2/28/2011 - SLUD SLUD 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Single Sample 2/28/2011 0.859 - - - - - - Grab Annual - - - - 0.859 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 2/1/2011 2/28/2011 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 - - - 10 - - Composite Quarterly - - - - 10 - - Industrial Eastern

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Active Robert Carruthers 10/1/2011 10/31/2011 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 1.45 < Below Detection - 10 - - Composite Quarterly - - - - <1.450 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Active Robert Carruthers 7/1/2011 7/31/2011 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 0.613 - Below Detection - 10 - - Composite Quarterly - - - - <0.613 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Active Robert Carruthers 4/1/2011 4/30/2011 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 0.578 < Below Detection - 10 - - Composite Quarterly Late Submit - - - <0.578 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Active Robert Carruthers 1/1/2011 1/31/2011 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 0.977 < Below Detection - 10 - - Composite Quarterly - - - - <0.977 - - Industrial Northwest

SIMPSON TACOMA WA0000850 Industrial NPDES IP Active Robert Carruthers 2/1/2011 2/28/2011 - SLDG SLDG 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Single Sample 2/28/2011 1.58 - - - - - - Grab 2/Year - - - - 1.58 - - Industrial Southwest

WEYERHAEUSER LONGVIEW WA0000124 Industrial NPDES IP Active Marc Crooks 2/1/2011 2/28/2011 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Single Sample 2/17/2011 2 < Below Detection - - - - Composite Monthly - - - - <2 - - Industrial Southwest

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 7/1/2010 7/31/2010 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 - Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 6/1/2010 6/30/2010 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 - Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 5/1/2010 5/31/2010 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 - Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 4/1/2010 4/30/2010 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 - Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 3/1/2010 3/31/2010 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 2/1/2010 2/28/2010 - SLUD SLUD 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Single Sample - 1 - - - - - - Grab Annual - - - - 1 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 2/1/2010 2/28/2010 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 2/1/2010 2/28/2010 - 1 1 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - - - - Composite Annual - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 1/1/2010 1/31/2010 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Active Robert Carruthers 10/1/2010 10/31/2010 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 0.995 < Below Detection - 10 - - Composite Quarterly - - - - <0.995 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Active Robert Carruthers 7/1/2010 7/31/2010 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 2.73 < Below Detection - 10 - - Composite Quarterly - - - - <2.730 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Active Robert Carruthers 4/1/2010 4/30/2010 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 1.29 < Below Detection - 10 - - Composite Quarterly - Benchmark E- - <1.290 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Active Robert Carruthers 1/1/2010 1/31/2010 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 1.34 < Below Detection - 10 - - Composite Quarterly - - - - <1.34 - - Industrial Northwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Active Teddy Le 2/1/2009 2/28/2009 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum 2/5/2009 1 < Below Detection - - - - Composite Quarterly - - - - <1 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Active Teddy Le 2/1/2009 2/28/2009 - 1 1 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 0.37 < Below Detection - - - - Composite Annual - - - - <.37 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 1/1/2009 1/31/2009 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 1/1/2009 1/31/2009 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 12/1/2009 12/31/2009 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 11/1/2009 11/30/2009 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 10/1/2009 10/31/2009 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 9/1/2009 9/30/2009 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 8/1/2009 8/31/2009 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 7/1/2009 7/31/2009 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 6/1/2009 6/30/2009 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 5/1/2009 5/31/2009 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 4/1/2009 4/30/2009 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 3/1/2009 3/31/2009 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 2/1/2009 2/28/2009 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 1/1/2009 1/31/2009 - SLUD SLUD 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Single Sample - 1 - - - - - - Grab Annual - - - - 1 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 1/1/2009 1/31/2009 - 1 1 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 1 - - - - - - Composite Annual - - - - 1 - - Industrial Eastern

SIMPSON TACOMA WA0000850 Industrial NPDES IP Active Robert Carruthers 8/1/2009 8/31/2009 - SLDG SLDG 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Single Sample - 0.489 - - - - - - Grab 2/Year - - - - 0.489 - - Industrial Southwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Active Robert Carruthers 10/1/2009 10/31/2009 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 1.34 < Below Detection - 10 - - Composite Quarterly - - - - <1.34 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Active Robert Carruthers 7/1/2009 7/31/2009 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 1.75 < Below Detection - 10 - - Composite Quarterly - - - - <1.75 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Active Robert Carruthers 4/1/2009 4/30/2009 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 1.73 < Below Detection - 10 - - Composite Quarterly - - - - <1.73 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Active Robert Carruthers 2/1/2009 2/28/2009 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 1.54 < Below Detection - 10 - - Composite Quarterly - - - - <1.54 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 1/1/2009 1/31/2009 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum - 1.54 < Below Detection - - - - ContinuousMonthly - - - - <1.54 - - Industrial Northwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 12/1/2008 12/31/2008 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 12/1/2008 12/31/2008 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 11/1/2008 11/30/2008 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 11/1/2008 11/30/2008 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 10/1/2008 10/31/2008 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 10/1/2008 10/31/2008 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 9/1/2008 9/30/2008 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 9/1/2008 9/30/2008 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 8/1/2008 8/31/2008 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 8/1/2008 8/31/2008 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 - Below Detection - - - - Composite Monthly - - - - B|10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 7/1/2008 7/31/2008 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 7/1/2008 7/31/2008 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 6/1/2008 6/30/2008 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 6/1/2008 6/30/2008 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 5/1/2008 5/31/2008 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 5/1/2008 5/31/2008 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 4/1/2008 4/30/2008 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 4/1/2008 4/30/2008 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 3/1/2008 3/31/2008 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 3/1/2008 3/31/2008 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 2/1/2008 2/29/2008 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 2/1/2008 2/29/2008 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 1/1/2008 1/31/2008 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 1/1/2008 1/31/2008 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 12/1/2008 12/31/2008 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 11/1/2008 11/30/2008 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 10/1/2008 10/31/2008 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 9/1/2008 9/30/2008 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 7/1/2008 7/31/2008 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 4/1/2008 4/30/2008 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 1 - - - 10 - - Composite Quarterly - - - - 1 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 1/1/2008 1/31/2008 - SLUD SLUD 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Single Sample - 0.42 - - - - - - Grab Annual - - - - 0.42 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 1/1/2008 1/31/2008 - 1 1 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 1 - - - - - - Composite Annual - - - - 1 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 1/1/2008 1/31/2008 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 12/1/2008 12/31/2008 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum - 0.611 < Below Detection - - - - Continuou Monthly - - - - <.611 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 11/1/2008 11/30/2008 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum - 0.773 < Below Detection - - - - Continuou Monthly - - - - <.773 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 10/1/2008 10/31/2008 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum - 0.395 < Below Detection - - - - Continuou Monthly - - - - <.395 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 9/1/2008 9/30/2008 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum - 0.56 < Below Detection - - - - Continuou Monthly - - - - <.56 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 3/1/2008 3/31/2008 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum - 0.435 < Below Detection - - - - Continuou Monthly - - - - <.435 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 2/1/2008 2/29/2008 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum - 0.647 < Below Detection - - - - Continuou Monthly - - - - <.647 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 1/1/2008 1/31/2008 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum - 1.08 < Below Detection - - - - Continuou Monthly - - - - <1.08 - - Industrial Northwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 12/1/2007 12/31/2007 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 12/1/2007 12/31/2007 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 11/1/2007 11/30/2007 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 11/1/2007 11/30/2007 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 10/1/2007 10/31/2007 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 10/1/2007 10/31/2007 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 9/1/2007 9/30/2007 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 9/1/2007 9/30/2007 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 8/1/2007 8/31/2007 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 8/1/2007 8/31/2007 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 7/1/2007 7/31/2007 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 7/1/2007 7/31/2007 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 6/1/2007 6/30/2007 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 6/1/2007 6/30/2007 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 5/1/2007 5/31/2007 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 5/1/2007 5/31/2007 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 4/1/2007 4/30/2007 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 4/1/2007 4/30/2007 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 3/1/2007 3/31/2007 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 3/1/2007 3/31/2007 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 2/1/2007 2/28/2007 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 2/1/2007 2/28/2007 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 1/1/2007 1/31/2007 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 1/1/2007 1/31/2007 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 10/1/2007 10/31/2007 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 7/1/2007 7/31/2007 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 2/1/2007 2/28/2007 - SLUD SLUD 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Single Sample - 0.376 - - - - - - Grab Annual - - - - 0.376 - Correct the Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 1/1/2007 1/31/2007 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 1/1/2007 1/31/2007 - 1 1 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 4 - - - - - - Composite Annual - - - - 4 - - Industrial Eastern

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 12/1/2007 12/31/2007 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum - 1.34 < Below Detection - - - - ContinuousMonthly - - - - <1.34 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 11/1/2007 11/30/2007 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum - 1.49 < Below Detection - - - - ContinuousMonthly - - - - <1.49 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 10/1/2007 10/31/2007 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum - 0.072 < Below Detection - - - - ContinuousMonthly - - - - <.072 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 9/1/2007 9/30/2007 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum - 0.743 < Below Detection - - - - ContinuousMonthly - - - - <.743 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 8/1/2007 8/31/2007 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum - 0.792 < Below Detection - - - - ContinuousMonthly - - - - <.792 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 7/1/2007 7/31/2007 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum - 1.73 < Below Detection - - - - ContinuousMonthly - - - - <1.73 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 6/1/2007 6/30/2007 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum - 0.459 < Below Detection - - - - ContinuousMonthly - - - - <.459 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 5/1/2007 5/31/2007 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum - 0.465 < Below Detection - - - - ContinuousMonthly - - - - <.465 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 4/1/2007 4/30/2007 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum - 1.16 < Below Detection - - - - ContinuousMonthly - - - - <1.16 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 3/1/2007 3/31/2007 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum - 1.14 < Below Detection - - - - ContinuousMonthly - - - - <1.14 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 2/1/2007 2/28/2007 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum - 0.848 < Below Detection - - - - ContinuousMonthly - - - - <.848 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 1/1/2007 1/31/2007 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum - 1.83 < Below Detection - - - - ContinuousMonthly - - - - <1.83 - - Industrial Northwest
GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 12/1/2006 12/31/2006

- BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 12/1/2006 12/31/2006- BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 11/1/2006 11/30/2006- BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 11/1/2006 11/30/2006- BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 10/1/2006 10/31/2006- BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 10/1/2006 10/31/2006- BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 9/1/2006 9/30/2006- BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 9/1/2006 9/30/2006- BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 8/1/2006 8/31/2006- BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 8/1/2006 8/31/2006- BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 7/1/2006 7/31/2006- BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 7/1/2006 7/31/2006- BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 6/1/2006 6/30/2006- BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 6/1/2006 6/30/2006- BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 5/1/2006 5/31/2006- BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 5/1/2006 5/31/2006- BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 4/1/2006 4/30/2006- BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 4/1/2006 4/30/2006- BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 3/1/2006 3/31/2006- BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 3/1/2006 3/31/2006- BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 2/1/2006 2/28/2006- BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 2/1/2006 2/28/2006- BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 1/1/2006 1/31/2006- BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 1/1/2006 1/31/2006- BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 12/1/2006 12/31/2006-1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum

- 10< Below Detection - 10-- Composite Quarterly - --- <10-- Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 11/1/2006 11/30/2006-1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum

- 10< Below Detection - 10-- Composite Quarterly - --- <10-- Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 10/2/2006 10/31/2006-1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum

- 10< Below Detection - 10-- Composite Quarterly - --- <10-- Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Inactive Robert Carruthers 10/1/2006 10/31/2006-1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum

- 10< Below Detection - 10-- Composite Monthly - --- <10-- Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Inactive Robert Carruthers 9/1/2006 9/30/2006-1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum

- 10< Below Detection - 10-- Composite Monthly - --- <10-- Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Inactive Robert Carruthers 2/1/2006 1/31/2007-1 SLDG 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Single Sample

- 0.864------ Grab Annual---- 0.864-- Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Inactive Robert Carruthers 2/1/2006 2/28/2006-11 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Daily Maximum

- 0.0000163< Below Detection - 0.78-- Composite Semiannual/2 - --- <.0000163-- Industrial Eastern

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 12/1/2006 12/31/2006- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 0.713< Below Detection ---- ContinuousMonthly---- <.713-- Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 11/1/2006 11/30/2006- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 1.43< Below Detection ---- ContinuousMonthly---- <1.43-- Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 10/1/2006 10/31/2006- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 0.766< Below Detection ---- ContinuousMonthly---- <.766-- Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 9/1/2006 9/30/2006- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 1.04< Below Detection ---- ContinuousMonthly---- <1.04-- Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 8/1/2006 8/31/2006- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 1.51< Below Detection ---- ContinuousMonthly---- <1.51-- Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 7/1/2006 7/31/2006- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 0.571< Below Detection ---- ContinuousMonthly---- <.571-- Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 6/1/2006 6/30/2006- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 0.614< Below Detection ---- ContinuousMonthly---- <.614-- Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 5/1/2006 5/31/2006- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 0.969< Below Detection ---- ContinuousMonthly---- <.969-- Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 4/1/2006 4/30/2006- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 0.637< Below Detection ---- ContinuousMonthly---- <.637-- Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 3/1/2006 3/31/2006- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 0.95< Below Detection ---- ContinuousMonthly---- <.95-- Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 2/1/2006 2/28/2006- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 1.36< Below Detection ---- ContinuousMonthly---- <1.36-- Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 1/1/2006 1/31/2006- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 1.01< Below Detection ---- ContinuousMonthly---- <1.01-- Industrial Northwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 12/1/2005 12/31/2005- BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 12/1/2005 12/31/2005- BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 11/1/2005 11/30/2005- BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 11/1/2005 11/30/2005- BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 10/1/2005 10/31/2005- BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 10/1/2005 10/31/2005- BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 9/1/2005 9/30/2005- BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 9/1/2005 9/30/2005- BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 8/1/2005 8/31/2005- BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 8/1/2005 8/31/2005- BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

SIMPSON TACOMA WA0000850 Industrial NPDES IP Inactive Robert Carruthers 10/1/2005 10/31/2005-11 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 2.09------ Composite Quarterly - --- 2.09-- Industrial Southwest

SIMPSON TACOMA WA0000850 Industrial NPDES IP Inactive Robert Carruthers 10/1/2005 10/31/2005- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 1.31--- 10-- Composite Monthly - --- 1.31-- Industrial Southwest

SIMPSON TACOMA WA0000850 Industrial NPDES IP Inactive Robert Carruthers 2/1/2005 2/28/2005- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 3.44< Below Detection - 10-- Composite Monthly - --- <3.44-- Industrial Southwest

WEYERHAEUSER LONGVIEW WA0000124 Industrial NPDES IP Active Marc Crooks 2/1/2005 2/28/2005- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

-3< Below Detection ---- Composite Monthly - --- <3-- Industrial Southwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 12/1/2005 12/31/2005- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 2.02< Below Detection ---- ContinuousMonthly---- <2.02-- Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 11/1/2005 11/30/2005- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 0.977< Below Detection ---- ContinuousMonthly---- <.977-- Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 10/1/2005 10/31/2005- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 1.51< Below Detection ---- ContinuousMonthly---- <1.51-- Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 9/1/2005 9/30/2005- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 1.04< Below Detection ---- ContinuousMonthly---- <1.04-- Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 8/1/2005 8/31/2005- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 0.848------ ContinuousMonthly---- 0.848-- Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 7/1/2005 7/31/2005- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 1.51< Below Detection ---- ContinuousMonthly---- <1.51-- Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 6/1/2005 6/30/2005- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 0.915< Below Detection ---- ContinuousMonthly---- <.915-- Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 5/1/2005 5/31/2005- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 1.83< Below Detection ---- ContinuousMonthly---- <1.83-- Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 4/1/2005 4/30/2005- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 1.54< Below Detection ---- ContinuousMonthly---- <1.54-- Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 3/1/2005 3/31/2005- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 0.72< Below Detection ---- ContinuousMonthly---- <.72-- Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 2/1/2005 2/28/2005- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 2.48< Below Detection ---- ContinuousMonthly---- <2.48-- Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 1/1/2005 1/31/2005- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 1.5< Below Detection ---- ContinuousMonthly---- <1.5-- Industrial Northwest
Pulp&PaperMillDioxinData1-2005thru2-2012.xlsx

Kimberly Clark Worldwide

Everett, WA

Facility Name Permit Number

Monitoring 

Period Begin 

Date

Monitoring 

Period End 

Date Parameter Units

Measurement 

Value

Value 

Qualifier Value Non Report Limit Max Sample Type

Sample 

Frequency

Value 

Violations

Measurement 

Value 

Description

KIMBERLY CLARK WORLDWIDE WA0000621 10/1/2011 10/31/2011 2,3,7,8-TCDD Picograms/L 1.45 < Below Detection Limit/No Detection 10 Composite Sample (24 Hour Time composite) Quarterly - <1.450

KIMBERLY CLARK WORLDWIDE WA0000621 7/1/2011 7/31/2011 2,3,7,8-TCDD Picograms/L 0.613 - Below Detection Limit/No Detection 10 Composite Sample (24 Hour Time composite) Quarterly - <0.613

KIMBERLY CLARK WORLDWIDE WA0000621 4/1/2011 4/30/2011 2,3,7,8-TCDD Picograms/L 0.578 < Below Detection Limit/No Detection 10 Composite Sample (24 Hour Time composite) Quarterly - <0.578

KIMBERLY CLARK WORLDWIDE WA0000621 1/1/2011 1/31/2011 2,3,7,8-TCDD Picograms/L 0.977 < Below Detection Limit/No Detection 10 Composite Sample (24 Hour Time composite) Quarterly - <0.977

KIMBERLY CLARK WORLDWIDE WA0000621 10/1/2010 10/31/2010 2,3,7,8-TCDD Picograms/L 0.995 < Below Detection Limit/No Detection 10 Composite Sample (24 Hour Time composite) Quarterly - <0.995

KIMBERLY CLARK WORLDWIDE WA0000621 7/1/2010 7/31/2010 2,3,7,8-TCDD Picograms/L 2.73 < Below Detection Limit/No Detection 10 Composite Sample (24 Hour Time composite) Quarterly - <2.730

KIMBERLY CLARK WORLDWIDE WA0000621 4/1/2010 4/30/2010 2,3,7,8-TCDD Picograms/L 1.29 < Below Detection Limit/No Detection 10 Composite Sample (24 Hour Time composite) Quarterly Benchmark E <1.290

KIMBERLY CLARK WORLDWIDE WA0000621 1/1/2010 1/31/2010 2,3,7,8-TCDD Picograms/L 1.34 < Below Detection Limit/No Detection 10 Composite Sample (24 Hour Time composite) Quarterly - <1.34

KIMBERLY CLARK WORLDWIDE WA0000621 10/1/2009 10/31/2009 2,3,7,8-TCDD Picograms/L 1.34 < Below Detection Limit/No Detection 10 Composite Sample (24 Hour Time composite) Quarterly - <1.34

KIMBERLY CLARK WORLDWIDE WA0000621 7/1/2009 7/31/2009 2,3,7,8-TCDD Picograms/L 1.75 < Below Detection Limit/No Detection 10 Composite Sample (24 Hour Time composite) Quarterly - <1.75

KIMBERLY CLARK WORLDWIDE WA0000621 4/1/2009 4/30/2009 2,3,7,8-TCDD Picograms/L 1.73 < Below Detection Limit/No Detection 10 Composite Sample (24 Hour Time composite) Quarterly - <1.73

KIMBERLY CLARK WORLDWIDE WA0000621 2/1/2009 2/28/2009 2,3,7,8-TCDD Picograms/L 1.54 < Below Detection Limit/No Detection 10 Composite Sample (24 Hour Time composite) Quarterly - <1.54

KIMBERLY CLARK WORLDWIDE WA0000621 1/1/2009 1/31/2009 2,3,7,8-TCDD #/100ml 1.54 < Below Detection Limit/No Detection - Continuous Monthly - <1.54

KIMBERLY CLARK WORLDWIDE WA0000621 12/1/2008 12/31/2008 2,3,7,8-TCDD #/100ml 0.611 < Below Detection Limit/No Detection - Continuous Monthly - <.611

KIMBERLY CLARK WORLDWIDE WA0000621 11/1/2008 11/30/2008 2,3,7,8-TCDD #/100ml 0.773 < Below Detection Limit/No Detection - Continuous Monthly - <.773

KIMBERLY CLARK WORLDWIDE WA0000621 10/1/2008 10/31/2008 2,3,7,8-TCDD #/100ml 0.395 < Below Detection Limit/No Detection - Continuous Monthly - <.395

KIMBERLY CLARK WORLDWIDE WA0000621 9/1/2008 9/30/2008 2,3,7,8-TCDD #/100ml 0.56 < Below Detection Limit/No Detection - Continuous Monthly - <.56

KIMBERLY CLARK WORLDWIDE WA0000621 3/1/2008 3/31/2008 2,3,7,8-TCDD #/100ml 0.435 < Below Detection Limit/No Detection - Continuous Monthly - <.435

KIMBERLY CLARK WORLDWIDE WA0000621 2/1/2008 2/29/2008 2,3,7,8-TCDD #/100ml 0.647 < Below Detection Limit/No Detection - Continuous Monthly - <.647

KIMBERLY CLARK WORLDWIDE WA0000621 1/1/2008 1/31/2008 2,3,7,8-TCDD #/100ml 1.08 < Below Detection Limit/No Detection - Continuous Monthly - <1.08

KIMBERLY CLARK WORLDWIDE WA0000621 12/1/2007 12/31/2007 2,3,7,8-TCDD #/100ml 1.34 < Below Detection Limit/No Detection - Continuous Monthly - <1.34

KIMBERLY CLARK WORLDWIDE WA0000621 11/1/2007 11/30/2007 2,3,7,8-TCDD #/100ml 1.49 < Below Detection Limit/No Detection - Continuous Monthly - <1.49

KIMBERLY CLARK WORLDWIDE WA0000621 10/1/2007 10/31/2007 2,3,7,8-TCDD #/100ml 0.072 < Below Detection Limit/No Detection - Continuous Monthly - <.072

KIMBERLY CLARK WORLDWIDE WA0000621 9/1/2007 9/30/2007 2,3,7,8-TCDD #/100ml 0.743 < Below Detection Limit/No Detection - Continuous Monthly - <.743

KIMBERLY CLARK WORLDWIDE WA0000621 8/1/2007 8/31/2007 2,3,7,8-TCDD #/100ml 0.792 < Below Detection Limit/No Detection - Continuous Monthly - <.792

KIMBERLY CLARK WORLDWIDE WA0000621 7/1/2007 7/31/2007 2,3,7,8-TCDD #/100ml 1.73 < Below Detection Limit/No Detection - Continuous Monthly - <1.73

KIMBERLY CLARK WORLDWIDE WA0000621 6/1/2007 6/30/2007 2,3,7,8-TCDD #/100ml 0.459 < Below Detection Limit/No Detection - Continuous Monthly - <.459

KIMBERLY CLARK WORLDWIDE WA0000621 5/1/2007 5/31/2007 2,3,7,8-TCDD #/100ml 0.465 < Below Detection Limit/No Detection - Continuous Monthly - <.465

KIMBERLY CLARK WORLDWIDE WA0000621 4/1/2007 4/30/2007 2,3,7,8-TCDD #/100ml 1.16 < Below Detection Limit/No Detection - Continuous Monthly - <1.16

KIMBERLY CLARK WORLDWIDE WA0000621 3/1/2007 3/31/2007 2,3,7,8-TCDD #/100ml 1.14 < Below Detection Limit/No Detection - Continuous Monthly - <1.14

KIMBERLY CLARK WORLDWIDE WA0000621 2/1/2007 2/28/2007 2,3,7,8-TCDD #/100ml 0.848 < Below Detection Limit/No Detection - Continuous Monthly - <.848

KIMBERLY CLARK WORLDWIDE WA0000621 1/1/2007 1/31/2007 2,3,7,8-TCDD #/100ml 1.83 < Below Detection Limit/No Detection - Continuous Monthly - <1.83

KIMBERLY CLARK WORLDWIDE WA0000621 12/1/2006 12/31/2006 2,3,7,8-TCDD #/100ml 0.713 < Below Detection Limit/No Detection - Continuous Monthly - <.713

KIMBERLY CLARK WORLDWIDE WA0000621 11/1/2006 11/30/2006 2,3,7,8-TCDD #/100ml 1.43 < Below Detection Limit/No Detection - Continuous Monthly - <1.43

KIMBERLY CLARK WORLDWIDE WA0000621 10/1/2006 10/31/2006 2,3,7,8-TCDD #/100ml 0.766 < Below Detection Limit/No Detection - Continuous Monthly - <.766

KIMBERLY CLARK WORLDWIDE WA0000621 9/1/2006 9/30/2006 2,3,7,8-TCDD #/100ml 1.04 < Below Detection Limit/No Detection - Continuous Monthly - <1.04

KIMBERLY CLARK WORLDWIDE WA0000621 8/1/2006 8/31/2006 2,3,7,8-TCDD #/100ml 1.51 < Below Detection Limit/No Detection - Continuous Monthly - <1.51

KIMBERLY CLARK WORLDWIDE WA0000621 7/1/2006 7/31/2006 2,3,7,8-TCDD #/100ml 0.571 < Below Detection Limit/No Detection - Continuous Monthly - <.571

KIMBERLY CLARK WORLDWIDE WA0000621 6/1/2006 6/30/2006 2,3,7,8-TCDD #/100ml 0.614 < Below Detection Limit/No Detection - Continuous Monthly - <.614

KIMBERLY CLARK WORLDWIDE WA0000621 5/1/2006 5/31/2006 2,3,7,8-TCDD #/100ml 0.969 < Below Detection Limit/No Detection - Continuous Monthly - <.969

KIMBERLY CLARK WORLDWIDE WA0000621 4/1/2006 4/30/2006 2,3,7,8-TCDD #/100ml 0.637 < Below Detection Limit/No Detection - Continuous Monthly - <.637

KIMBERLY CLARK WORLDWIDE WA0000621 3/1/2006 3/31/2006 2,3,7,8-TCDD #/100ml 0.95 < Below Detection Limit/No Detection - Continuous Monthly - <.95

KIMBERLY CLARK WORLDWIDE WA0000621 2/1/2006 2/28/2006 2,3,7,8-TCDD #/100ml 1.36 < Below Detection Limit/No Detection - Continuous Monthly - <1.36

KIMBERLY CLARK WORLDWIDE WA0000621 1/1/2006 1/31/2006 2,3,7,8-TCDD #/100ml 1.01 < Below Detection Limit/No Detection - Continuous Monthly - <1.01

KIMBERLY CLARK WORLDWIDE WA0000621 12/1/2005 12/31/2005 2,3,7,8-TCDD #/100ml 2.02 < Below Detection Limit/No Detection - Continuous Monthly - <2.02

KIMBERLY CLARK WORLDWIDE WA0000621 11/1/2005 11/30/2005 2,3,7,8-TCDD #/100ml 0.977 < Below Detection Limit/No Detection - Continuous Monthly - <.977

KIMBERLY CLARK WORLDWIDE WA0000621 10/1/2005 10/31/2005 2,3,7,8-TCDD #/100ml 1.51 < Below Detection Limit/No Detection - Continuous Monthly - <1.51

KIMBERLY CLARK WORLDWIDE WA0000621 9/1/2005 9/30/2005 2,3,7,8-TCDD #/100ml 1.04 < Below Detection Limit/No Detection - Continuous Monthly - <1.04

KIMBERLY CLARK WORLDWIDE WA0000621 8/1/2005 8/31/2005 2,3,7,8-TCDD #/100ml 0.848 - - - Continuous Monthly - 0.848

KIMBERLY CLARK WORLDWIDE WA0000621 7/1/2005 7/31/2005 2,3,7,8-TCDD #/100ml 1.51 < Below Detection Limit/No Detection - Continuous Monthly - <1.51

KIMBERLY CLARK WORLDWIDE WA0000621 6/1/2005 6/30/2005 2,3,7,8-TCDD #/100ml 0.915 < Below Detection Limit/No Detection - Continuous Monthly - <.915

KIMBERLY CLARK WORLDWIDE WA0000621 5/1/2005 5/31/2005 2,3,7,8-TCDD #/100ml 1.83 < Below Detection Limit/No Detection - Continuous Monthly - <1.83

KIMBERLY CLARK WORLDWIDE WA0000621 4/1/2005 4/30/2005 2,3,7,8-TCDD #/100ml 1.54 < Below Detection Limit/No Detection - Continuous Monthly - <1.54

KIMBERLY CLARK WORLDWIDE WA0000621 3/1/2005 3/31/2005 2,3,7,8-TCDD #/100ml 0.72 < Below Detection Limit/No Detection - Continuous Monthly - <.72

KIMBERLY CLARK WORLDWIDE WA0000621 2/1/2005 2/28/2005 2,3,7,8-TCDD #/100ml 2.48 < Below Detection Limit/No Detection - Continuous Monthly - <2.48

KIMBERLY CLARK WORLDWIDE WA0000621 1/1/2005 1/31/2005 2,3,7,8-TCDD #/100ml 1.5 < Below Detection Limit/No Detection - Continuous Monthly - <1.5
Pulp&PaperMillDioxinData1-2005thru2-2012.xlsx

Boise Cascade

Wallula, WA

Facility Name Permit Number

Monitoring 

Period Begin 

Date

Monitoring 

Period End 

Date

Outfall 

Name Parameter Units Statistical Base Sample Date

Measurement 

Value

Value 

Qualifier Value Non Report Limit Max Sample Type

Sample 

Frequency

Measurement 

Value 

Description Value Ecology Notes

BOISE CASCADE WALLULA WA0003697 10/1/2011 10/31/2011 1 2,3,7,8-TCDD Picograms/L Maximum - 10 - - 10 Composite Sample (24 Hour Time composite) Quarterly 10 -

BOISE CASCADE WALLULA WA0003697 8/1/2011 8/31/2011 1 2,3,7,8-TCDD Picograms/L Maximum - 10 - - 10 Composite Sample (24 Hour Time composite) Quarterly 10 -

BOISE CASCADE WALLULA WA0003697 5/1/2011 5/31/2011 1 2,3,7,8-TCDD Picograms/L Maximum - 10 - - 10 Composite Sample (24 Hour Time composite) Quarterly 10 -

BOISE CASCADE WALLULA WA0003697 3/1/2011 3/31/2011 1 2,3,7,8-TCDD Picograms/L Maximum - 10 - - 10 Composite Sample (24 Hour Time composite) Quarterly 10 -

BOISE CASCADE WALLULA WA0003697 2/1/2011 2/28/2011 SLUD 2,3,7,8-TCDD #/100ml Single Sample 2/28/2011 0.859 - - - Grab Annual 0.859 -

BOISE CASCADE WALLULA WA0003697 2/1/2011 2/28/2011 1 2,3,7,8-TCDD Picograms/L Maximum - 10 - - 10 Composite Sample (24 Hour Time composite) Quarterly 10 -

BOISE CASCADE WALLULA WA0003697 7/1/2010 7/31/2010 1 2,3,7,8-TCDD Picograms/L Maximum - 10 - Below Detection Limit/No Detection 10 Composite Sample (24 Hour Time composite) Quarterly <10 -

BOISE CASCADE WALLULA WA0003697 6/1/2010 6/30/2010 1 2,3,7,8-TCDD Picograms/L Maximum - 10 - Below Detection Limit/No Detection 10 Composite Sample (24 Hour Time composite) Quarterly <10 -

BOISE CASCADE WALLULA WA0003697 5/1/2010 5/31/2010 1 2,3,7,8-TCDD Picograms/L Maximum - 10 - Below Detection Limit/No Detection 10 Composite Sample (24 Hour Time composite) Quarterly <10 -

BOISE CASCADE WALLULA WA0003697 4/1/2010 4/30/2010 1 2,3,7,8-TCDD Picograms/L Maximum - 10 - Below Detection Limit/No Detection 10 Composite Sample (24 Hour Time composite) Quarterly <10 -

BOISE CASCADE WALLULA WA0003697 3/1/2010 3/31/2010 1 2,3,7,8-TCDD Picograms/L Maximum - 10 < Below Detection Limit/No Detection 10 Composite Sample (24 Hour Time composite) Quarterly <10 -

BOISE CASCADE WALLULA WA0003697 2/1/2010 2/28/2010 SLUD 2,3,7,8-TCDD #/100ml Single Sample - 1 - - - Grab Annual 1 -

BOISE CASCADE WALLULA WA0003697 2/1/2010 2/28/2010 1 2,3,7,8-TCDD Picograms/L Maximum - 10 < Below Detection Limit/No Detection 10 Composite Sample (24 Hour Time composite) Quarterly <10 -

BOISE CASCADE WALLULA WA0003697 2/1/2010 2/28/2010 1 2,3,7,8-TCDD Picograms/L Maximum - 10 < Below Detection Limit/No Detection - Composite Sample (24 Hour Time composite) Annual <10 -

BOISE CASCADE WALLULA WA0003697 1/1/2010 1/31/2010 1 2,3,7,8-TCDD Picograms/L Maximum - 10 < Below Detection Limit/No Detection 10 Composite Sample (24 Hour Time composite) Quarterly <10 -

BOISE CASCADE WALLULA WA0003697 12/1/2009 12/31/2009 1 2,3,7,8-TCDD Picograms/L Maximum - 10 < Below Detection Limit/No Detection 10 Composite Sample (24 Hour Time composite) Quarterly <10 -

BOISE CASCADE WALLULA WA0003697 11/1/2009 11/30/2009 1 2,3,7,8-TCDD Picograms/L Maximum - 10 < Below Detection Limit/No Detection 10 Composite Sample (24 Hour Time composite) Quarterly <10 -

BOISE CASCADE WALLULA WA0003697 10/1/2009 10/31/2009 1 2,3,7,8-TCDD Picograms/L Maximum - 10 < Below Detection Limit/No Detection 10 Composite Sample (24 Hour Time composite) Quarterly <10 -

BOISE CASCADE WALLULA WA0003697 9/1/2009 9/30/2009 1 2,3,7,8-TCDD Picograms/L Maximum - 10 < Below Detection Limit/No Detection 10 Composite Sample (24 Hour Time composite) Quarterly <10 -

BOISE CASCADE WALLULA WA0003697 8/1/2009 8/31/2009 1 2,3,7,8-TCDD Picograms/L Maximum - 10 < Below Detection Limit/No Detection 10 Composite Sample (24 Hour Time composite) Quarterly <10 -

BOISE CASCADE WALLULA WA0003697 7/1/2009 7/31/2009 1 2,3,7,8-TCDD Picograms/L Maximum - 10 < Below Detection Limit/No Detection 10 Composite Sample (24 Hour Time composite) Quarterly <10 -

BOISE CASCADE WALLULA WA0003697 6/1/2009 6/30/2009 1 2,3,7,8-TCDD Picograms/L Maximum - 10 < Below Detection Limit/No Detection 10 Composite Sample (24 Hour Time composite) Quarterly <10 -

BOISE CASCADE WALLULA WA0003697 5/1/2009 5/31/2009 1 2,3,7,8-TCDD Picograms/L Maximum - 10 < Below Detection Limit/No Detection 10 Composite Sample (24 Hour Time composite) Quarterly <10 -

BOISE CASCADE WALLULA WA0003697 4/1/2009 4/30/2009 1 2,3,7,8-TCDD Picograms/L Maximum - 10 < Below Detection Limit/No Detection 10 Composite Sample (24 Hour Time composite) Quarterly <10 -

BOISE CASCADE WALLULA WA0003697 3/1/2009 3/31/2009 1 2,3,7,8-TCDD Picograms/L Maximum - 10 < Below Detection Limit/No Detection 10 Composite Sample (24 Hour Time composite) Quarterly <10 -

BOISE CASCADE WALLULA WA0003697 2/1/2009 2/28/2009 1 2,3,7,8-TCDD Picograms/L Maximum - 10 < Below Detection Limit/No Detection 10 Composite Sample (24 Hour Time composite) Quarterly <10 -

BOISE CASCADE WALLULA WA0003697 1/1/2009 1/31/2009 SLUD 2,3,7,8-TCDD #/100ml Single Sample - 1 - - - Grab Annual 1 -

BOISE CASCADE WALLULA WA0003697 1/1/2009 1/31/2009 1 2,3,7,8-TCDD Picograms/L Maximum - 1 - - - Composite Sample (24 Hour Time composite) Annual 1 -

BOISE CASCADE WALLULA WA0003697 12/1/2008 12/31/2008 1 2,3,7,8-TCDD Picograms/L Maximum - 10 < Below Detection Limit/No Detection 10 Composite Sample (24 Hour Time composite) Quarterly <10 -

BOISE CASCADE WALLULA WA0003697 11/1/2008 11/30/2008 1 2,3,7,8-TCDD Picograms/L Maximum - 10 < Below Detection Limit/No Detection 10 Composite Sample (24 Hour Time composite) Quarterly <10 -

BOISE CASCADE WALLULA WA0003697 10/1/2008 10/31/2008 1 2,3,7,8-TCDD Picograms/L Maximum - 10 < Below Detection Limit/No Detection 10 Composite Sample (24 Hour Time composite) Quarterly <10 -

BOISE CASCADE WALLULA WA0003697 9/1/2008 9/30/2008 1 2,3,7,8-TCDD Picograms/L Maximum - 10 < Below Detection Limit/No Detection 10 Composite Sample (24 Hour Time composite) Quarterly <10 -

BOISE CASCADE WALLULA WA0003697 7/1/2008 7/31/2008 1 2,3,7,8-TCDD Picograms/L Maximum - 10 < Below Detection Limit/No Detection 10 Composite Sample (24 Hour Time composite) Quarterly <10 -

BOISE CASCADE WALLULA WA0003697 4/1/2008 4/30/2008 1 2,3,7,8-TCDD Picograms/L Maximum - 1 - - 10 Composite Sample (24 Hour Time composite) Quarterly 1 -

BOISE CASCADE WALLULA WA0003697 1/1/2008 1/31/2008 SLUD 2,3,7,8-TCDD #/100ml Single Sample - 0.42 - - - Grab Annual 0.42 -

BOISE CASCADE WALLULA WA0003697 1/1/2008 1/31/2008 1 2,3,7,8-TCDD Picograms/L Maximum - 1 - - - Composite Sample (24 Hour Time composite) Annual 1 -

BOISE CASCADE WALLULA WA0003697 1/1/2008 1/31/2008 1 2,3,7,8-TCDD Picograms/L Maximum - 10 < Below Detection Limit/No Detection 10 Composite Sample (24 Hour Time composite) Quarterly <10 -

BOISE CASCADE WALLULA WA0003697 10/1/2007 10/31/2007 1 2,3,7,8-TCDD Picograms/L Maximum - 10 < Below Detection Limit/No Detection 10 Composite Sample (24 Hour Time composite) Quarterly <10 -

BOISE CASCADE WALLULA WA0003697 7/1/2007 7/31/2007 1 2,3,7,8-TCDD Picograms/L Maximum - 10 < Below Detection Limit/No Detection 10 Composite Sample (24 Hour Time composite) Quarterly <10 -

BOISE CASCADE WALLULA WA0003697 2/1/2007 2/28/2007 SLUD 2,3,7,8-TCDD #/100ml Single Sample - 0.376 - - - Grab Annual 0.376 Correct the units (ng/kg)

BOISE CASCADE WALLULA WA0003697 1/1/2007 1/31/2007 1 2,3,7,8-TCDD Picograms/L Maximum - 10 < Below Detection Limit/No Detection 10 Composite Sample (24 Hour Time composite) Quarterly <10 -

BOISE CASCADE WALLULA WA0003697 1/1/2007 1/31/2007 1 2,3,7,8-TCDD Picograms/L Maximum - 4 - - - Composite Sample (24 Hour Time composite) Annual 4 -

BOISE CASCADE WALLULA WA0003697 12/1/2006 12/31/2006 1 2,3,7,8-TCDD Picograms/L Maximum - 10 < Below Detection Limit/No Detection 10 Composite Sample (24 Hour Time composite) Quarterly <10 -

BOISE CASCADE WALLULA WA0003697 11/1/2006 11/30/2006 1 2,3,7,8-TCDD Picograms/L Maximum - 10 < Below Detection Limit/No Detection 10 Composite Sample (24 Hour Time composite) Quarterly <10 -

BOISE CASCADE WALLULA WA0003697 10/2/2006 10/31/2006 1 2,3,7,8-TCDD Picograms/L Maximum - 10 < Below Detection Limit/No Detection 10 Composite Sample (24 Hour Time composite) Quarterly <10 -

BOISE CASCADE WALLULA WA0003697 10/1/2006 10/31/2006 1 2,3,7,8-TCDD Picograms/L Maximum - 10 < Below Detection Limit/No Detection 10 Composite Sample (24 Hour Time composite) Monthly <10 -

BOISE CASCADE WALLULA WA0003697 9/1/2006 9/30/2006 1 2,3,7,8-TCDD Picograms/L Maximum - 10 < Below Detection Limit/No Detection 10 Composite Sample (24 Hour Time composite) Monthly <10 -

BOISE CASCADE WALLULA WA0003697 2/1/2006 1/31/2007 1 2,3,7,8-TCDD #/100ml Single Sample - 0.864 - - - Grab Annual 0.864 -

BOISE CASCADE WALLULA WA0003697 2/1/2006 2/28/2006 1 2,3,7,8-TCDD #/100ml Daily Maximum - 0.0000163 < Below Detection Limit/No Detection 0.78 Composite Sample (24 Hour Time composite) Semiannual/2 p <.0000163 -
Pulp&PaperMillDioxinData1-2005thru2-2012.xlsx

Simpson Tacoma

Facility Name

Permit 

Number

Monitoring 

Period Begin 

Date

Monitoring 

Period End 

Date

Outfall 

Name Parameter Units Statistical Base Sample Date

Measurement 

Value

Value 

Qualifier Value Non Report Limit Max Sample Type

Sample 

Frequency

Measurement 

Value Description

SIMPSON TACOMA WA0000850 11/1/2011 11/30/2011 SLDG 2,3,7,8-TCDD Picograms/L Single Sample 11/30/2011 1.54 - - - Grab 2/Year 1.54

SIMPSON TACOMA WA0000850 2/1/2011 2/28/2011 SLDG 2,3,7,8-TCDD Picograms/L Single Sample 2/28/2011 1.58 - - - Grab 2/Year 1.58

SIMPSON TACOMA WA0000850 8/1/2009 8/31/2009 SLDG 2,3,7,8-TCDD Picograms/L Single Sample - 0.489 - - - Grab 2/Year 0.489

SIMPSON TACOMA WA0000850 10/1/2005 10/31/2005 1 2,3,7,8-TCDD Picograms/L Daily Maximum - 2.09 - - - Composite Sample (24 Hour Time composite) Quarterly 2.09

SIMPSON TACOMA WA0000850 10/1/2005 10/31/2005 BLCH 2,3,7,8-TCDD Picograms/L Daily Maximum - 1.31 - - 10 Composite Sample (24 Hour Time composite) Monthly 1.31

SIMPSON TACOMA WA0000850 2/1/2005 2/28/2005 BLCH 2,3,7,8-TCDD Picograms/L Daily Maximum - 3.44 < Below Detection Limit/No Detection 10 Composite Sample (24 Hour Time composite) Monthly <3.44
Water Quality Name Permit Number Permit Type Permit Status

Outfall 

Name Outfall Type

Facility 

City

Facility 

County

Monitor 

Pt Code Monitor Pt Type Parameter Units Fraction Statistical Base

Is Report 

Only

Benchmark 

Min

Benchmark 

Max Limit Min Limit Max

Parameter 

Impairment

Outfall 

Lat

Outfall 

Long

Waterbody 

Name

Admin 

Region

Facility 

Region

Permittee 

Water Body 

Name

Monitor 

Pt Desc

Limit Set 

Inactive 

Date

Permit 

Version

Limit Set 

Type

Limit Set 

Name

Test 

Method

Sample 

Type

Sample 

Frequency

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active SLUD Surface Water Body Wallula Walla Walla SLUD Industrial (Process)Wastewater 2,3,7,8-TCDD (#/100ml Not Applic Single Sample Y - - - - - 46.05972 -118.924 West Channe Industrial Eastern - sludge - 3 Final DMR (MONUnknown Grab Annual

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active 1 Surface Water Body Wallula Walla Walla BLCH Groundwater 2,3,7,8-TCDD (Picograms/L Not Applic Maximum N - - - 10 - 46.05912 -118.943 Columbia RiveIndustrial Eastern Columbia Riverbleach plan- 3 Final DMR (MONUnknown Composite Quarterly 

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active 1 Surface Water Body Wallula Walla Walla BLCH Groundwater 2,3,7,8-TCDD (Picograms/L Not Applic Single Sample Y - - - - - 46.05912 -118.943 Columbia RiveIndustrial Eastern Columbia Riverbleach plan- 3 Final DMR (MONUnknown Composite Quarterly 

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active 1 Surface Water Body Wallula Walla Walla 1 Industrial (Process)Wastewater 2,3,7,8-TCDD (#/100ml Not Applic Single Sample Y - - - - - 46.05912 -118.943 Columbia RiveIndustrial Eastern Columbia Riveroutfall 001 - 3 Final DMR (MONUnknown Composite Annual

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active 1 Surface Water Body Wallula Walla Walla 1 Industrial (Process)Wastewater 2,3,7,8-TCDD (#/100ml Not Applic Daily Maximum N - - - 0.78 - 46.05912 -118.943 Columbia RiveIndustrial Eastern Columbia Riveroutfall 001 - 3 Final DMR (MONUnknown Composite Annual

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active 1 Surface Water Body Wallula Walla Walla 1 Industrial (Process)Wastewater 2,3,7,8-TCDD (Picograms/L Not Applic Single Sample Y - - - - - 46.05912 -118.943 Columbia RiveIndustrial Eastern Columbia Riveroutfall 001 - 3 Final DMR (MONUnknown Composite Annual

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active 1 Surface Water Body Wallula Walla Walla 1 Industrial (Process)Wastewater 2,3,7,8-TCDD (Picograms/L Not Applic Maximum Y - - - - - 46.05912 -118.943 Columbia RiveIndustrial Eastern Columbia Riveroutfall 001 - 3 Final DMR (MONUnknown Composite Annual

Cosmo Specialty Fibers, Inc. WA0000809 Industrial NPDES IP Active 1 Surface Water Body Cosmopoli Grays Harbor 1 Industrial (Process)Wastewater 2,3,7,8-TCDD (#/100ml Not Applic Single Sample N - - - 0.28 - 46.95293 -123.843 Charley CreekIndustrial Southwest Grays Harbor (IMain Outfa- 3 Final DMR (MONUnknown Composite Quarterly 

GEORGIA PACIFIC CONSUMER PRODUWA0000256 Industrial NPDES IP Active 1 Surface Water Body Camas Clark 1 Industrial (Process)Wastewater 2,3,7,8-TCDD (Picograms/L Not Applic Daily Maximum Y - - - - - 45.57931 -122.414 Washougal Ri Industrial Southwest Columbia R. Main Outfa- 3 Final DMR (MONUnknown Composite Annual

GEORGIA PACIFIC CONSUMER PRODUWA0000256 Industrial NPDES IP Active BLC5 Publically Owned Treatme Camas Clark BLC5 Groundwater 2,3,7,8-TCDD (Picograms/L Not Applic Daily Maximum Y - - - - - 45.5875 -122.407 - Industrial Southwest - BLEACH PLA - 3 Final DMR (MONUnknown Composite Quarterly 

GEORGIA PACIFIC CONSUMER PRODUWA0000256 Industrial NPDES IP Active 1 Surface Water Body Camas Clark 1 Industrial (Process)Wastewater 2,3,7,8-TCDD (Picograms/L Not Applic Single Sample Y - - - - - 45.57931 -122.414 Washougal Ri Industrial Southwest Columbia R. Main Outfa- 3 Final DMR (MONUnknown Composite Annual

GEORGIA PACIFIC CONSUMER PRODUWA0000256 Industrial NPDES IP Active BLC5 Publically Owned Treatme Camas Clark BLC5 Groundwater 2,3,7,8-TCDD (Picograms/L Not Applic Single Sample Y - - - - - 45.5875 -122.407 - Industrial Southwest - BLEACH PLA - 3 Final DMR (MONUnknown Composite Quarterly 

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Active BLCH Surface Water Body Everett Snohomish BLCH Industrial (Process)Wastewater 2,3,7,8-TCDD (Picograms/L Not Applic Maximum N - - - 10 - 47.97333 -122.203 - Industrial Northwest - Bleach Plan- 3 Final DMR (MONUnknown Composite Quarterly 

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Active 100C Surface Water Body Everett Snohomish 100C Industrial (Process)Wastewater 2,3,7,8-TCDD (Picograms/L Not Applic Maximum Y - - - - - 47.97333 -122.203 - Industrial Northwest - Total Facilit - 3 Final DMR (MONUnknown Composite Annual

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Active 100C Surface Water Body Everett Snohomish 100C Industrial (Process)Wastewater 2,3,7,8-TCDD (Picograms/L Not Applic Single Sample Y - - - - - 47.97333 -122.203 - Industrial Northwest - Total Facilit - 3 Final DMR (MONUnknown Composite Annual

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Active BLCH Surface Water Body Everett Snohomish BLCH Industrial (Process)Wastewater 2,3,7,8-TCDD (Picograms/L Not Applic Single Sample Y - - - - - 47.97333 -122.203 - Industrial Northwest - Bleach Plan- 3 Final DMR (MONUnknown Composite Quarterly 

SIMPSON TACOMA WA0000850 Industrial NPDES IP Active BLCH Surface Water Body Tacoma Pierce BLCH Industrial (Process)Wastewater 2,3,7,8-TCDD (Picograms/L Not Applic Daily Maximum Y - - - - - 47.26806 -122.429 - Industrial Southwest - BLEACH PLA- 3 Final DMR (MONUnknown Composite Monthly

SIMPSON TACOMA WA0000850 Industrial NPDES IP Active SLDG Surface Water Body Tacoma Pierce SLDG Groundwater 2,3,7,8-TCDD (Picograms/L Not Applic Single Sample Y - - - - - 47.26806 -122.429 - Industrial Southwest - Prim /sec /- 3 Final DMR (MONUnknown Grab 2/Year

SIMPSON TACOMA WA0000850 Industrial NPDES IP Active 1 Surface Water Body Tacoma Pierce 001C Industrial (Process)Wastewater 2,3,7,8-TCDD (Picograms/L Not Applic Single Sample Y - - - - - 47.26127 -122.421 Puget Sound Industrial Southwest Commencemen 2clarifier ef- 3 Final DMR (MONUnknown Composite Quarterly 

SIMPSON TACOMA WA0000850 Industrial NPDES IP Active BLCH Surface Water Body Tacoma Pierce BLCH Industrial (Process)Wastewater 2,3,7,8-TCDD (Picograms/L Not Applic Single Sample Y - - - - - 47.26806 -122.429 - Industrial Southwest - BLEACH PLA- 3 Final DMR (MONUnknown Composite Monthly

SIMPSON TACOMA WA0000850 Industrial NPDES IP Active 1 Surface Water Body Tacoma Pierce 001C Industrial (Process)Wastewater 2,3,7,8-TCDD (Picograms/L Not Applic Daily Maximum Y - - - - - 47.26127 -122.421 Puget Sound Industrial Southwest Commencemen 2clarifier ef- 3 Final DMR (MONUnknown Composite Quarterly 

STELLA JONES CO ST0007425 Industrial to ground SW Active 1 Surface Water Body Arlington Snohomish 1 Stormwater DIOXINS PPQ Not Applic Maximum N - - - 0.6 - 48.16889 -122.146 - Northwest Northwest - OUTFALL 0 - 2 Final DMR (QUAUnknown Grab Quarterly 

STELLA JONES CO ST0007425 Industrial to ground SW Active 1 Surface Water Body Arlington Snohomish 1 Stormwater DIOXINS PPQ Not Applic Single Sample Y - - - - - 48.16889 -122.146 - Northwest Northwest - OUTFALL 0 - 2 Final DMR (QUAUnknown Grab Quarterly 

WEYERHAEUSER LONGVIEW WA0000124 Industrial NPDES IP Active BLCH Surface Water Body Longview Cowlitz BLCH Industrial (Process)Wastewater 2,3,7,8-TCDD (Picograms/L Not Applic Daily Maximum Y - - - - - 46.13306 -122.993 - Industrial Southwest - Bleach Plan- 2 Final DMR (MONUnknown Composite Monthly

WEYERHAEUSER LONGVIEW WA0000124 Industrial NPDES IP Active BLCH Surface Water Body Longview Cowlitz BLCH Industrial (Process)Wastewater 2,3,7,8-TCDD (Picograms/L Not Applic Single Sample Y - - - - - 46.13306 -122.993 - Industrial Southwest - Bleach Plan- 2 Final DMR (MONUnknown Composite Monthly
Facility Name Permit Number Permit Type Permit Status Ecology Contact

Monitoring Period 

Begin Date

Monitoring Period 

End Date

Submission Non 

Report

Outfall 

Name

Monitor Pt 

Code Parameter Fraction Units Statistical Base Sample Date

Measurement 

Value

Value 

Qualifier

Value Non 

Report Limit Min Limit Max

Benchmark 

Min

Benchmark 

Max

Sample 

Type

Sample 

Frequency

Sub 

Violations

Value 

Violations

Parameter 

Violations

Monitoring 

Point 

Violations

Measurement 

Value 

Description

Value 

Facility 

Notes

Value 

Ecology 

Notes

Admin 

Region Facility Region

SIMPSON TACOMA WA0000850 Industrial NPDES IP Active Robert Carruthers 11/1/2011 11/30/2011 - SLDG SLDG 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Single Sample 11/30/2011 1.54 - - - - - - Grab 2/Year - - - - 1.54 - - Industrial Southwest

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 10/1/2011 10/31/2011 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 - - - 10 - - Composite Quarterly - - - - 10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 8/1/2011 8/31/2011 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 - - - 10 - - Composite Quarterly - - - - 10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 5/1/2011 5/31/2011 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 - - - 10 - - Composite Quarterly - - - - 10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 3/1/2011 3/31/2011 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 - - - 10 - - Composite Quarterly - - - - 10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 2/1/2011 2/28/2011 - SLUD SLUD 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Single Sample 2/28/2011 0.859 - - - - - - Grab Annual - - - - 0.859 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 2/1/2011 2/28/2011 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 - - - 10 - - Composite Quarterly - - - - 10 - - Industrial Eastern

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Active Robert Carruthers 10/1/2011 10/31/2011 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 1.45 < Below Detection - 10 - - Composite Quarterly - - - - <1.450 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Active Robert Carruthers 7/1/2011 7/31/2011 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 0.613 - Below Detection - 10 - - Composite Quarterly - - - - <0.613 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Active Robert Carruthers 4/1/2011 4/30/2011 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 0.578 < Below Detection - 10 - - Composite Quarterly Late Submit - - - <0.578 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Active Robert Carruthers 1/1/2011 1/31/2011 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 0.977 < Below Detection - 10 - - Composite Quarterly - - - - <0.977 - - Industrial Northwest

SIMPSON TACOMA WA0000850 Industrial NPDES IP Active Robert Carruthers 2/1/2011 2/28/2011 - SLDG SLDG 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Single Sample 2/28/2011 1.58 - - - - - - Grab 2/Year - - - - 1.58 - - Industrial Southwest

WEYERHAEUSER LONGVIEW WA0000124 Industrial NPDES IP Active Marc Crooks 2/1/2011 2/28/2011 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Single Sample 2/17/2011 2 < Below Detection - - - - Composite Monthly - - - - <2 - - Industrial Southwest

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 7/1/2010 7/31/2010 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 - Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 6/1/2010 6/30/2010 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 - Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 5/1/2010 5/31/2010 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 - Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 4/1/2010 4/30/2010 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 - Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 3/1/2010 3/31/2010 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 2/1/2010 2/28/2010 - SLUD SLUD 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Single Sample - 1 - - - - - - Grab Annual - - - - 1 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 2/1/2010 2/28/2010 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 2/1/2010 2/28/2010 - 1 1 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - - - - Composite Annual - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 1/1/2010 1/31/2010 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Active Robert Carruthers 10/1/2010 10/31/2010 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 0.995 < Below Detection - 10 - - Composite Quarterly - - - - <0.995 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Active Robert Carruthers 7/1/2010 7/31/2010 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 2.73 < Below Detection - 10 - - Composite Quarterly - - - - <2.730 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Active Robert Carruthers 4/1/2010 4/30/2010 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 1.29 < Below Detection - 10 - - Composite Quarterly - Benchmark E- - <1.290 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Active Robert Carruthers 1/1/2010 1/31/2010 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 1.34 < Below Detection - 10 - - Composite Quarterly - - - - <1.34 - - Industrial Northwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Active Teddy Le 2/1/2009 2/28/2009 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum 2/5/2009 1 < Below Detection - - - - Composite Quarterly - - - - <1 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Active Teddy Le 2/1/2009 2/28/2009 - 1 1 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 0.37 < Below Detection - - - - Composite Annual - - - - <.37 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 1/1/2009 1/31/2009 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 1/1/2009 1/31/2009 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 12/1/2009 12/31/2009 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 11/1/2009 11/30/2009 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 10/1/2009 10/31/2009 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 9/1/2009 9/30/2009 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 8/1/2009 8/31/2009 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 7/1/2009 7/31/2009 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 6/1/2009 6/30/2009 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 5/1/2009 5/31/2009 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 4/1/2009 4/30/2009 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 3/1/2009 3/31/2009 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 2/1/2009 2/28/2009 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 1/1/2009 1/31/2009 - SLUD SLUD 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Single Sample - 1 - - - - - - Grab Annual - - - - 1 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 1/1/2009 1/31/2009 - 1 1 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 1 - - - - - - Composite Annual - - - - 1 - - Industrial Eastern

SIMPSON TACOMA WA0000850 Industrial NPDES IP Active Robert Carruthers 8/1/2009 8/31/2009 - SLDG SLDG 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Single Sample - 0.489 - - - - - - Grab 2/Year - - - - 0.489 - - Industrial Southwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Active Robert Carruthers 10/1/2009 10/31/2009 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 1.34 < Below Detection - 10 - - Composite Quarterly - - - - <1.34 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Active Robert Carruthers 7/1/2009 7/31/2009 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 1.75 < Below Detection - 10 - - Composite Quarterly - - - - <1.75 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Active Robert Carruthers 4/1/2009 4/30/2009 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 1.73 < Below Detection - 10 - - Composite Quarterly - - - - <1.73 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Active Robert Carruthers 2/1/2009 2/28/2009 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 1.54 < Below Detection - 10 - - Composite Quarterly - - - - <1.54 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 1/1/2009 1/31/2009 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum - 1.54 < Below Detection - - - - ContinuousMonthly - - - - <1.54 - - Industrial Northwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 12/1/2008 12/31/2008 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 12/1/2008 12/31/2008 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 11/1/2008 11/30/2008 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 11/1/2008 11/30/2008 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 10/1/2008 10/31/2008 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 10/1/2008 10/31/2008 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 9/1/2008 9/30/2008 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 9/1/2008 9/30/2008 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 8/1/2008 8/31/2008 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 8/1/2008 8/31/2008 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 - Below Detection - - - - Composite Monthly - - - - B|10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 7/1/2008 7/31/2008 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 7/1/2008 7/31/2008 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 6/1/2008 6/30/2008 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 6/1/2008 6/30/2008 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 5/1/2008 5/31/2008 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 5/1/2008 5/31/2008 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 4/1/2008 4/30/2008 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 4/1/2008 4/30/2008 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 3/1/2008 3/31/2008 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 3/1/2008 3/31/2008 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 2/1/2008 2/29/2008 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 2/1/2008 2/29/2008 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 1/1/2008 1/31/2008 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 1/1/2008 1/31/2008 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 12/1/2008 12/31/2008 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 11/1/2008 11/30/2008 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 10/1/2008 10/31/2008 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 9/1/2008 9/30/2008 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 7/1/2008 7/31/2008 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 4/1/2008 4/30/2008 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 1 - - - 10 - - Composite Quarterly - - - - 1 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 1/1/2008 1/31/2008 - SLUD SLUD 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Single Sample - 0.42 - - - - - - Grab Annual - - - - 0.42 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 1/1/2008 1/31/2008 - 1 1 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 1 - - - - - - Composite Annual - - - - 1 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 1/1/2008 1/31/2008 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 12/1/2008 12/31/2008 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum - 0.611 < Below Detection - - - - Continuou Monthly - - - - <.611 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 11/1/2008 11/30/2008 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum - 0.773 < Below Detection - - - - Continuou Monthly - - - - <.773 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 10/1/2008 10/31/2008 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum - 0.395 < Below Detection - - - - Continuou Monthly - - - - <.395 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 9/1/2008 9/30/2008 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum - 0.56 < Below Detection - - - - Continuou Monthly - - - - <.56 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 3/1/2008 3/31/2008 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum - 0.435 < Below Detection - - - - Continuou Monthly - - - - <.435 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 2/1/2008 2/29/2008 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum - 0.647 < Below Detection - - - - Continuou Monthly - - - - <.647 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 1/1/2008 1/31/2008 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum - 1.08 < Below Detection - - - - Continuou Monthly - - - - <1.08 - - Industrial Northwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 12/1/2007 12/31/2007 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 12/1/2007 12/31/2007 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 11/1/2007 11/30/2007 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 11/1/2007 11/30/2007 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 10/1/2007 10/31/2007 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 10/1/2007 10/31/2007 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 9/1/2007 9/30/2007 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 9/1/2007 9/30/2007 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 8/1/2007 8/31/2007 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 8/1/2007 8/31/2007 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 7/1/2007 7/31/2007 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 7/1/2007 7/31/2007 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 6/1/2007 6/30/2007 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 6/1/2007 6/30/2007 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 5/1/2007 5/31/2007 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 5/1/2007 5/31/2007 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 4/1/2007 4/30/2007 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 4/1/2007 4/30/2007 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 3/1/2007 3/31/2007 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 3/1/2007 3/31/2007 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 2/1/2007 2/28/2007 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 2/1/2007 2/28/2007 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 1/1/2007 1/31/2007 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 1/1/2007 1/31/2007 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 10/1/2007 10/31/2007 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 7/1/2007 7/31/2007 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 2/1/2007 2/28/2007 - SLUD SLUD 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Single Sample - 0.376 - - - - - - Grab Annual - - - - 0.376 - Correct the Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 1/1/2007 1/31/2007 - 1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 10 < Below Detection - 10 - - Composite Quarterly - - - - <10 - - Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 1/1/2007 1/31/2007 - 1 1 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum - 4 - - - - - - Composite Annual - - - - 4 - - Industrial Eastern

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 12/1/2007 12/31/2007 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum - 1.34 < Below Detection - - - - ContinuousMonthly - - - - <1.34 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 11/1/2007 11/30/2007 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum - 1.49 < Below Detection - - - - ContinuousMonthly - - - - <1.49 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 10/1/2007 10/31/2007 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum - 0.072 < Below Detection - - - - ContinuousMonthly - - - - <.072 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 9/1/2007 9/30/2007 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum - 0.743 < Below Detection - - - - ContinuousMonthly - - - - <.743 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 8/1/2007 8/31/2007 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum - 0.792 < Below Detection - - - - ContinuousMonthly - - - - <.792 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 7/1/2007 7/31/2007 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum - 1.73 < Below Detection - - - - ContinuousMonthly - - - - <1.73 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 6/1/2007 6/30/2007 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum - 0.459 < Below Detection - - - - ContinuousMonthly - - - - <.459 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 5/1/2007 5/31/2007 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum - 0.465 < Below Detection - - - - ContinuousMonthly - - - - <.465 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 4/1/2007 4/30/2007 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum - 1.16 < Below Detection - - - - ContinuousMonthly - - - - <1.16 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 3/1/2007 3/31/2007 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum - 1.14 < Below Detection - - - - ContinuousMonthly - - - - <1.14 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 2/1/2007 2/28/2007 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum - 0.848 < Below Detection - - - - ContinuousMonthly - - - - <.848 - - Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 1/1/2007 1/31/2007 - BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum - 1.83 < Below Detection - - - - ContinuousMonthly - - - - <1.83 - - Industrial Northwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 12/1/2006 12/31/2006 - BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 12/1/2006 12/31/2006 - BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum - 10 < Below Detection - - - - Composite Monthly - - - - <10 - - Industrial Southwest
GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 11/1/2006 11/30/2006

- BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 11/1/2006 11/30/2006- BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 10/1/2006 10/31/2006- BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 10/1/2006 10/31/2006- BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 9/1/2006 9/30/2006- BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 9/1/2006 9/30/2006- BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 8/1/2006 8/31/2006- BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 8/1/2006 8/31/2006- BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 7/1/2006 7/31/2006- BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 7/1/2006 7/31/2006- BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 6/1/2006 6/30/2006- BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 6/1/2006 6/30/2006- BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 5/1/2006 5/31/2006- BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 5/1/2006 5/31/2006- BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 4/1/2006 4/30/2006- BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 4/1/2006 4/30/2006- BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 3/1/2006 3/31/2006- BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 3/1/2006 3/31/2006- BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 2/1/2006 2/28/2006- BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 2/1/2006 2/28/2006- BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 1/1/2006 1/31/2006- BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 1/1/2006 1/31/2006- BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 12/1/2006 12/31/2006-1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum

- 10< Below Detection - 10-- Composite Quarterly - --- <10-- Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 11/1/2006 11/30/2006-1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum

- 10< Below Detection - 10-- Composite Quarterly - --- <10-- Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Active Robert Carruthers 10/2/2006 10/31/2006-1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum

- 10< Below Detection - 10-- Composite Quarterly - --- <10-- Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Inactive Robert Carruthers 10/1/2006 10/31/2006-1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum

- 10< Below Detection - 10-- Composite Monthly - --- <10-- Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Inactive Robert Carruthers 9/1/2006 9/30/2006-1 BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Maximum

- 10< Below Detection - 10-- Composite Monthly - --- <10-- Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Inactive Robert Carruthers 2/1/2006 1/31/2007-1 SLDG 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Single Sample

- 0.864------ Grab Annual---- 0.864-- Industrial Eastern

BOISE CASCADE WALLULA WA0003697 Industrial NPDES IP Inactive Robert Carruthers 2/1/2006 2/28/2006-11 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Daily Maximum

- 0.0000163< Below Detection - 0.78-- Composite Semiannual/2 - --- <.0000163-- Industrial Eastern

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 12/1/2006 12/31/2006- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 0.713< Below Detection ---- ContinuousMonthly---- <.713-- Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 11/1/2006 11/30/2006- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 1.43< Below Detection ---- ContinuousMonthly---- <1.43-- Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 10/1/2006 10/31/2006- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 0.766< Below Detection ---- ContinuousMonthly---- <.766-- Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 9/1/2006 9/30/2006- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 1.04< Below Detection ---- ContinuousMonthly---- <1.04-- Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 8/1/2006 8/31/2006- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 1.51< Below Detection ---- ContinuousMonthly---- <1.51-- Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 7/1/2006 7/31/2006- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 0.571< Below Detection ---- ContinuousMonthly---- <.571-- Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 6/1/2006 6/30/2006- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 0.614< Below Detection ---- ContinuousMonthly---- <.614-- Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 5/1/2006 5/31/2006- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 0.969< Below Detection ---- ContinuousMonthly---- <.969-- Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 4/1/2006 4/30/2006- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 0.637< Below Detection ---- ContinuousMonthly---- <.637-- Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 3/1/2006 3/31/2006- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 0.95< Below Detection ---- ContinuousMonthly---- <.95-- Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 2/1/2006 2/28/2006- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 1.36< Below Detection ---- ContinuousMonthly---- <1.36-- Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 1/1/2006 1/31/2006- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 1.01< Below Detection ---- ContinuousMonthly---- <1.01-- Industrial Northwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 12/1/2005 12/31/2005- BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 12/1/2005 12/31/2005- BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 11/1/2005 11/30/2005- BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 11/1/2005 11/30/2005- BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 10/1/2005 10/31/2005- BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 10/1/2005 10/31/2005- BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 9/1/2005 9/30/2005- BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 9/1/2005 9/30/2005- BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 8/1/2005 8/31/2005- BLC5 BLC5 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

GEORGIA PACIFIC CONSUMER PRODUCTS WA0000256 Industrial NPDES IP Inactive Teddy Le 8/1/2005 8/31/2005- BLC4 BLC4 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 10< Below Detection ---- Composite Monthly - --- <10-- Industrial Southwest

SIMPSON TACOMA WA0000850 Industrial NPDES IP Inactive Robert Carruthers 10/1/2005 10/31/2005-11 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 2.09------ Composite Quarterly - --- 2.09-- Industrial Southwest

SIMPSON TACOMA WA0000850 Industrial NPDES IP Inactive Robert Carruthers 10/1/2005 10/31/2005- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 1.31--- 10-- Composite Monthly - --- 1.31-- Industrial Southwest

SIMPSON TACOMA WA0000850 Industrial NPDES IP Inactive Robert Carruthers 2/1/2005 2/28/2005- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

- 3.44< Below Detection - 10-- Composite Monthly - --- <3.44-- Industrial Southwest

WEYERHAEUSER LONGVIEW WA0000124 Industrial NPDES IP Active Marc Crooks 2/1/2005 2/28/2005- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable Picograms/L Daily Maximum

-3< Below Detection ---- Composite Monthly - --- <3-- Industrial Southwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 12/1/2005 12/31/2005- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 2.02< Below Detection ---- ContinuousMonthly---- <2.02-- Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 11/1/2005 11/30/2005- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 0.977< Below Detection ---- ContinuousMonthly---- <.977-- Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 10/1/2005 10/31/2005- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 1.51< Below Detection ---- ContinuousMonthly---- <1.51-- Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 9/1/2005 9/30/2005- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 1.04< Below Detection ---- ContinuousMonthly---- <1.04-- Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 8/1/2005 8/31/2005- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 0.848------ ContinuousMonthly---- 0.848-- Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 7/1/2005 7/31/2005- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 1.51< Below Detection ---- ContinuousMonthly---- <1.51-- Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 6/1/2005 6/30/2005- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 0.915< Below Detection ---- ContinuousMonthly---- <.915-- Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 5/1/2005 5/31/2005- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 1.83< Below Detection ---- ContinuousMonthly---- <1.83-- Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 4/1/2005 4/30/2005- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 1.54< Below Detection ---- ContinuousMonthly---- <1.54-- Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 3/1/2005 3/31/2005- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 0.72< Below Detection ---- ContinuousMonthly---- <.72-- Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 2/1/2005 2/28/2005- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 2.48< Below Detection ---- ContinuousMonthly---- <2.48-- Industrial Northwest

KIMBERLY CLARK WORLDWIDE WA0000621 Industrial NPDES IP Inactive Robert Carruthers 1/1/2005 1/31/2005- BLCH BLCH 2,3,7,8-TCDD (dioxin)(teNot Applicable #/100ml Maximum

- 1.5< Below Detection ---- ContinuousMonthly---- <1.5-- Industrial Northwest





































Page 1 Ecology Publication No. 00-03-044

The following article appeared in the

Dioxin 2000: 20th International Symposium on Halogenated

Environmental Organic Pollutants & POPS

Monterey, CA, August 13-17, 2000.

Volume 46, 2000, pp. 291-294

Washington State Dioxin Source Assessment

Bill Yake1, Stacie Singleton2, and Karol Erickson1

1 Washington State Department of Ecology, Environmental Assessment Program,

PO Box 47710, Olympia WA 98504-7710

2 Washington State Department of Ecology, Hazardous Waste Program, PO Box

47600, Olympia WA 98504-7600

Introduction

As an initial step toward improving the management of persistent,

bioaccumulative, and toxic pollutants, the Washington State Department of

Ecology (Ecology) sponsored an effort to gather, consolidate and assess

information about the sources of polychlorinated dioxins and furans (here referred

to simply as “dioxins”) in Washington State1. The federal Environmental

Protection Agency (EPA) undertook a similar effort as part of a large national

study.2,3 Although the EPA draft report provided much valuable information, it

was not clear how relevant the information on sources was to Washington State.

Polychlorinated dioxins and furans belong to a class of pollutants that are

persistent, toxic and bioaccumulative. Pollutants with these characteristics remain

in the environment for decades, often moving from one media to another (e.g.,

from water or air to soil and sediment). They enter and are distributed through the

food web, accumulating in the tissues of animals, including humans. Because

these contaminants cross boundaries between environmental media, they are

regulated by a variety of laws, regulations and programs. For all these reasons

they raise unique, often difficult, management challenges.

The purpose of the Washington State Dioxin Source Assessmentstudy

(http://www.ecy.wa.gov/biblio/98320.html) was to identify actual (“confirmed”)

and potential in-state sources of dioxins. The magnitude of sources and

importance of source categories were evaluated using existing information.

Understanding the sources of dioxins is a logical first step towards an effective

management strategy that will reduce their generation and dispersal.
Page 2 Ecology Publication No. 00-03-044

The assessment:

• Summarized what Ecology knows and does not know about dioxin sources in

Washington State.

• Recommended actions Ecology might take to (1) improve its understanding of

dioxin sources and (2) reduce the magnitude and impact of these sources on

the state’s citizens and environment.

Dioxins are unintended byproducts formed during combustion of organic

compounds in the presence of chloride, incineration of municipal and hospital

wastes, and chlorine bleaching of wood pulp 4,5,6 The production of chlorinated

organic chemicals can also produce dioxins; they are therefore contaminants in

certain chlorinated organic products. Dioxins have no commercial or domestic

applications and are not intentionally produced, except for small quantities used in

research.7, 8

Methods and Materials

Known and potential sources of dioxin in Washington State were evaluated using

of existing source-monitoring data. No resources were allocated for additional

monitoring or modeling. We evaluated a range of environmental media: air,

water, ash, and biosolids.

Source data were used to calculate loads. A load is the rate at which dioxin is

generated or discharged. Loads are expressed in the assessment as milligrams of

dioxin toxic equivalents (TEQs) per day. To calculate a load, we determined the

TEQ for the material tested (e.g., air, water, ash), then multiplied this by the rate

at which that material was generated and/or released.

Source loads were determined from actual analytical test data. Unlike EPA’s

source evaluation work this project did not develop “emission factors” to estimate

the total load from a category of sources.

Where adequate data allow, we calculate loads for individual sources.

“Confirmed source categories” are source categories that have at least one facility

with data adequate to calculate a dioxin load. Both active and closed facilities

with documented dioxin loads were included as “confirmed sources.” In addition

to confirmed source categories, the assessment provides information on “potential

sources categories”. These include sources for which there were dioxin data but

available data did not allow calculation of dioxin loads; for instance,

contaminated sites with confirmed dioxin contamination. Dioxin could be

moving from sites not fully remediated, however, data were not available to

quantify these loads.
Page 3 Ecology Publication No. 00-03-044

We focused on sources located within Washington State’s borders and used only

data generated during the 10 years preceding the assessment. Preferential focus

was placed on data reporting the full range of 2,3,7,8-substituted congeners. The

quality of data used in the assessment was variable. Although detailed review of

data quality was beyond the scope of the project, every attempt was made to use

published data or data that were available from the public record.

Project limitations were largely associated with the relative paucity of data.

Dioxin testing is expensive and results are not always divulged. Additionally,

information needed to calculate loads (ash generation rates, off-site migration

rates) is not always available. Despite these limitations, the assessment revealed

useful perspectives that are helping to direct Ecology’s efforts.

Results and Discussion

Available data allowed identification of 25 facilities or processes with measurable

dioxin loads. At the completion of the assessment 21 were active and four were

closed. Of the 25, 15 discharge to air, nine to water, and nine to land. (Several

discharge to more than one environmental medium.)

The available data on dioxin sources in Washington State was relatively sparse. In

part this is due to limitations in environmental agencies’ lack authority to require

testing. For example, wastewater loads could not be calculated for any of the

approximately 250 municipal wastewater treatment plants in Washington, and

biosolids loads were available for only one of the 250. Similarly, air loads were

available for only 2 of 84 waste-wood boilers, while ash loads were available for

3 of 84.

Each confirmed source category was evaluated to determine 1) the importance of

obtaining additional data and 2) the importance of source reduction and control.

Information used in this evaluation included:

• Data on the amount of dioxin generated by, or released by, sources in each

category.

• Potential for dioxin generated by facilities to be dispersed or contained.

• Number of facilities in each category and the relative data coverage (e.g., the

proportion of facilities in each source category having dioxin data).

• Whether the calculated dioxin loads were from facilities that continue to

operate, or from facilities that are now closed.

• National rank, estimated from the relative magnitude of each source category,

based on EPA’s 1994 national dioxin source assessment.
Page 4 Ecology Publication No. 00-03-044

Table 1 summarizes the importance rankings for confirmed source categories.

Table 1. Importance of Additional Data Collection and Source Control: Confirmed Sources

Source Category Importance of

Additional Data

Importance of Source

Reduction/Control

Incinerators High Variable (importance of

sequestering fly ash - high.)

Hog Fuel (Wood Waste) Boilers High Potentially High

Bleached Pulp and Paper Medium Medium

Cement Kilns Medium/Low Medium/Low

Activated Carbon Regeneration Medium/High Low

Municipal Wastewater Treatment High Potentially Medium

For some source categories (called potential source categories) available data

showed concentrations of dioxins associated with the source, but these data were

inadequate to calculate the amount of dioxin being generated or released.

Potential source categories include cleanup sites, wood treating facilities using

pentachlorophenol, and oil refineries. The importance rankings of these sources

are shown in Table 2.

Table 2. Evaluation of the “Importance” of Other Source Categories

Source Category Importance of Additional

Data Collection

Wood Treaters High

Cleanup Sites Variable

Oil Refineries Medium

Conclusions and associated recommendations, many of which were based on the

importance ratings shown above, were as follows:

Conclusion 1. Dioxin data are incomplete.

Recommendations: A series of recommendations to fill high priority data gaps

were provided. These recommendations focus on improving the quantity and

quality of dioxin data available for waste-wood boilers, incinerators, bleached

pulp mills, fertilizers, biosolids, and wood-treating facilities using

pentachlorophenol.
Page 5 Ecology Publication No. 00-03-044

Conclusion 2. Two of the facilities with some of the highest estimated dioxin

loads ceased operation in 1997.

Recommendations: Carry out follow-up dioxin monitoring in the vicinity of these

facilities to evaluate the extent of off-site contamination and provide a sound basis

for cleanup.

Conclusion 3. Wood-waste boilers and incinerators rate highest in importance for

further source reduction.

Recommendations: Steps to reduce dioxin loads from these source categories

were provided.

Conclusion 4. Compiling existing data on dioxin detected in Washington State’s

environment will help put these source data in context.

Recommendations: Compile soil, sediment, fish and shellfish dioxin data. Based

on the results of this compilation, conduct monitoring to fill critical data gaps and

track key environmental indicators. These indicators will show the effectiveness

of actions taken to reduce dioxin in the environment.

Conclusion 5. This dioxin source assessment provides a major first step in

implementing Ecology’s strategy for managing bioaccumulative, persistent and

toxic compounds.

Recommendation: Use information from this and subsequent PBT projects to

advance and improve strategies that address the management and elimination of

bioaccumulative pollutants.

Acknowledgements

We gratefully acknowledge Washington State Department of Ecology

management for initiating and supporting this project. We acknowledge especially

Tom Fitzsimmons, Dan Silver, Keith Phillips, Megan White, Joe Williams, and

Bill Backous for their considerable support. We also note and appreciate the

sponsorship of the Bioaccumulative Chemicals of Concern Committee (now

called the Persistent, Bioaccumulative, and Toxic Chemicals (PBT) Committee).

To the many individuals, organizations, and firms that assisted in our efforts to

gather data on dioxin emissions in Washington State we extend our thanks and

appreciation.

Funding for this project was provided by EPA RCRA Grant # D-000742-97, the

Hazardous Waste and Toxics Reduction Program, and the Environmental

Investigations and Laboratory Services Program.
Page 6 Ecology Publication No. 00-03-044

References

 

1

 Yake, B., Singleton, S., and Erickson, K. (1998) Washington State Dioxin

Source Assessment. Washington State Department of Ecology, Publication No.

98-320.

2

 EPA (1994) Health Assessment Document for 2,3,7,4-Tetrachlorodibenzo-pdioxin (TCDD) and Related Compounds. Volume 1. (External Review Draft).

EPA/600/BR-92/001a.

3

 EPA (1994) Estimating Exposures to Dioxin-Like Compounds. Volume II:

Properties, Sources, Occurrence and Background Exposures. (External Review

Draft). EPA/600/6-88/005Cb.

4

 Alcock R.E. and Jones K.C. (1996) Environ. Sci. & Technol. 30 (11), 3133.

5

 Birnbaum L.S. (1994). Environ. Health Perspectives, 102(9), 157.

6

 Rappe, C. (1984) Environ. Sci. & Technol., 18 (3), 78A.

7

 ATSDR (1989) Toxicological Profile for 2,3,7,8-Tetrachlorodibenzo-p-dioxin,

ATSDR/TP-88/23.

8

 Federal Register (May 7, 1997) 62(88), 24887.
Washington State

Dioxin

Source Assessment

July 1998

Publication No. 98-320
The Department of Ecology is an equal opportunity agency

and does not discriminate on the basis of race, creed,

 color, disability, age, religion, national origin,

sex, marital status, disabled veteran's status,

Vietnam Era veteran's status or sexual orientation.

If you have special accommodation needs or require this document

in alternative format, please contact the

Environmental Investigations and Laboratory Services Program,

Toxics Investigations Section,

 Joan LeTourneau at (360) 407-6764 (voice).

Ecology's telecommunications device for the deaf (TDD) number at

Ecology Headquarters is (360) 407-6006.

For additional copies of this publication,

please contact:

Department of Ecology

Publications Distributions Office

P. O. Box 47600

Olympia, Washington 98504-7600

(360) 407-7472

Refer to Publication Number 98-320

Appendix D of this report is

Publication Number 98-321
Washington State

Dioxin

Source Assessment

by

Bill Yake1, Stacie Singleton2

and

Karol Erickson1

Washington State Department of Ecology

1

Environmental Investigations and Laboratory Services

2

Hazardous Waste and Toxics Reduction Program

Olympia, Washington 98504-7600

July 1998

Publication No. 98-320

This report is printed on 24-lb Genesis paper.

Processed chlorine free, 20% post-consumer fiber.
 Page i

Table of Contents

Page

List of Figures and Tables ..................................................................................................iii

Executive Summary ............................................................................................................ v

Acknowledgments.............................................................................................................. ix

Funding ........................................................................................................................ x

Acronyms ........................................................................................................................... xi

Introduction ......................................................................................................................... 1

Purpose......................................................................................................................... 1

Background .................................................................................................................. 2

Project Description.............................................................................................................. 7

Media Analyzed ........................................................................................................... 8

Dioxin TEQ Loads ....................................................................................................... 9

Confirmed Dioxin Sources........................................................................................... 9

Potential Dioxin Sources.............................................................................................. 9

Results and Discussion...................................................................................................... 11

Data Gaps................................................................................................................... 11

“Importance” of Source Categories............................................................................ 13

Municipal and Medical Waste Incinerators ............................................................... 14

Hog-fuel Boilers......................................................................................................... 21

Bleached Pulp and Paper Mills .................................................................................. 28

Cement Kilns.............................................................................................................. 32

Municipal Wastewater Treatment.............................................................................. 34

Activated Carbon Regeneration ................................................................................. 36

Small Miscellaneous Sources with Calculated Loads................................................ 39

Other Source Categories ............................................................................................ 39

Potential Source Categories ....................................................................................... 44

Conclusions and Recommendations.................................................................................. 48

Conclusion 1 .............................................................................................................. 48

Recommendation ....................................................................................................... 48

Conclusion 2 .............................................................................................................. 49

Recommendations...................................................................................................... 50

Conclusion 3 .............................................................................................................. 50

Recommendations...................................................................................................... 50

Conclusion 4 .............................................................................................................. 51

Recommendations...................................................................................................... 51

Conclusion 5 .............................................................................................................. 52

Recommendation ....................................................................................................... 52

Glossary............................................................................................................................. 53

References ......................................................................................................................... 55
Page ii

Appendices

A. Supplemental Tables

B. Methods

C. Dioxin loads calculated by three alternative methods for handling quantities less than

the detection limit

D. Dioxin TEQ load calculations

Appendix D is a separate report, Publication Number 98-321
 Page iii

List of Figures and Tables

Page

Figures

Figure 1. Chlorinated Dioxin and Furan Structures ..................................................... 3

Figure 2. Dioxin Source and Fate Conceptual Model.................................................. 5

Figure 3. Number of Facilities with Dioxin Data, by Media.... .................................. 12

Figure 4. TEQ Distribution in Rayonier, Inc., Ash, Air, Wastewater, and Sludge ...... 30

Tables

Table 1a. Importance of Additional Data Collection and Source Control:

Confirmed Source Categories....................................................................... vi

Table 1b. Evaluation of the “Importance” of Other Source Categories........................ vi

Table 2. Municipal and Medical Waste Incinerators .................................................. 14

Table 3. Incinerator Dioxin Loads, Facility Status, and Solid Waste

Disposition.................................................................................................... 16

Table 4. Hog-fuel Boilers ........................................................................................... 22

Table 5. Hog-fuel Boiler Dioxin Loads, Facility Status, and Solid Waste

Disposition.................................................................................................... 24

Table 6. TEQ Loads Into and Out of a Hog-fuel Boiler ............................................. 25

Table 7. Bleached Pulp and Paper Mill Loads, Facility Status, and Solid Waste

Disposition.................................................................................................... 28

Table 8. Cement Kiln Dioxin Loads, Facility Status, and Solid Waste

Disposition.................................................................................................... 32

Table 9. Municipal Wastewater Treatment Loads, Facility Status, and Solid

Waste Disposition......................................................................................... 34

Table 10. Activated Carbon Regeneration Loads ......................................................... 37

Table 11. Cleanup Sites ................................................................................................ 39

Table 12. Wood Treating Facilities .............................................................................. 41

Table 13. Oil Refineries................................................................................................ 43

Table 14. Sources and Disposition of Steel Foundry Dust ........................................... 44

Table 15a. Evaluation of the “Importance” of Confirmed Source Categories ............... 48

Table 15b. Evaluation of the “Importance” of Other Source Categories........................ 48
Page iv
 Page v

Executive Summary

Chlorinated dioxins and furans belong to a class of pollutants that build up

(bioaccumulate) in human and animal tissue, persist in the environment, and are toxic.

Pollutants with these characteristics are referred to as “bioaccumulative chemicals of

concern” (BCCs). They raise special challenges for society and the environment because,

long after being generated, they continue to pose threats in the food chain and the

environment.

Within the Washington State Department of Ecology (Ecology), programs responsible for

air quality, water quality, sediment quality and waste management share responsibility for

these pollutants. The Bioaccumulative Chemicals of Concern (BCC) Committee is

comprised of representatives for these programs and addresses agency-wide issues

associated with toxic, persistent, and bioaccumulative pollutants.

The Washington State Dioxin Source Assessment is sponsored by the BCC Committee.

The purposes of this report are to:

• Summarize what Ecology knows and does not know about dioxin sources in

Washington State.

• Recommend actions Ecology might take to (1) improve its understanding of dioxin

sources and (2) reduce the magnitude and impact of these sources on the state’s

citizens and environment.

This report provides background information on chlorinated dioxins and furans

(collectively referred to in this report as “dioxins”). A simple source and fate model is

presented to help describe the movement of dioxins from source to environmental and

human receptors.

Next, the report discusses (1) steps taken to locate and process data for confirmed and

potential dioxin sources in Washington State, and (2) the limitations imposed by sparse

data. The data are presented, discussed and interpreted in the Results and Discussion

section. This section also describes data gaps.

For the purposes of this report a “source category” is defined as a group of sources

engaging in a similar process (e.g., incineration or wood-treating with

pentachlorophenol). A “confirmed source category” is a source category for which there

are adequate data to calculate a dioxin load from at least one individual source in that

group.
Page vi

Information provided for each of the confirmed source categories includes:

• Data on the amount of dioxin generated by, or released by, sources in each category.

• Potential for dioxin generated by facilities to be dispersed or contained.

• Number of facilities in each category and the relative data coverage

(e.g., the proportion of facilities in each source category having dioxin data).

• Whether the calculated dioxin loads were from facilities that continue to operate,

or from facilities that are now closed.

• National rank, estimated from the relative magnitude of each source category, based

on EPA’s 1994 national dioxin source assessment.

From this information each source category is assigned two importance rankings:

1) the importance of collecting additional dioxin data, and 2) the importance of additional

source control and reduction. Table 1a summarizes the importance rankings for

confirmed source categories.

Table 1a. Importance of Additional Data Collection and Source Control:

Confirmed Source Categories

Source Category Importance of Obtaining

Additional Data

Importance of Source

Reduction/Control

Incinerators High Variable1

Hog Fuel (Wood Waste) Boilers High Potentially High

Bleached Pulp and Paper Medium Medium

Cement Kilns Medium/Low Medium/Low

Activated Carbon Regeneration Medium/High Low

Municipal Wastewater Treatment High Potentially Medium

For some source categories, the amount of dioxin generated could not be determined from

available data. These potential source categories are discussed and the available

information presented. In some cases, available data show concentrations of dioxins

associated with the source, but these data are inadequate to calculate the amount of dioxin

being generated or released. Potential source categories include cleanup sites, wood

treating facilities using pentachlorophenol, and oil refineries. The importance rankings of

these sources are shown in Table 1b.

Table 1b. Evaluation of the “Importance” of Other Source Categories

Source Category Importance of Additional

Data Collection

Wood Treaters High

Cleanup Sites Variable

Oil Refineries Medium

1 Importance of sequestering fly ash is high.
 Page vii

Overall conclusions and associated recommendations, many of which are based on the

importance ratings shown above, are presented. These are summarized below:

Conclusion 1. Dioxin data are incomplete.

Recommendations: A series of recommendations to fill high priority data gaps are

provided. These recommendations focus on improving the quantity and quality of dioxin

data available for hog fuel boilers, incinerators, bleached pulp mills, wood-treating

facilities using pentachlorophenol, and several other sources.

Conclusion 2. Two of the facilities with some of the highest estimated dioxin loads

ceased operation in 1997. These were the Rayonier pulp mill in Port Angeles and the

Cameron-Yakima activated carbon regeneration facility in Yakima.

Recommendations: Carry out follow-up dioxin monitoring in the vicinity of these

facilities to evaluate the extent of off-site contamination and provide a sound basis for

future actions.

Conclusion 3. Hog-fuel (wood-waste) boilers and incinerators rate highest in importance

for further source reduction.

Recommendations: Steps to reduce dioxin loads from these source categories are

presented.

Conclusion 4. Compiling existing data on dioxin detected in Washington State’s

environment will help put these source data in context.

Recommendations: Compile soil, sediment, fish and shellfish dioxin data. Based on the

results of this compilation, conduct monitoring to fill critical data gaps and track key

environmental indicators. These indicators will show the effectiveness of actions taken to

reduce dioxin in the environment.

Conclusion 5. This dioxin source assessment provides a major first step in implementing

Ecology’s strategy for managing bioaccumulative, persistent and toxic compounds.

Recommendation: Use information from this and subsequent BCC projects to advance

and improve strategies that address the management and elimination of bioaccumulative

pollutants.
Page viii
 Page ix

Acknowledgments

We would like to thank Megan White and Keith Phillips for conceiving, initiating and

supporting this project; and Bill Backous for his considerable support as current chair of

the Bioaccumulative Chemicals of Concern Committee. We are also grateful for the

funding provided by EPA and facilitated by the Hazardous Waste and Toxics Reduction

Program (HWTR), as well as funding provided through the Environmental Investigations

and Laboratory Services (EILS) Emerging Issues Fund.

We are particularly grateful to these people and organizations:

◊ The Bioaccumulative Chemicals of Concern Committee (BCC) for sponsoring the

project.

◊ Keith Phillips (former EILS Program Manager) and Bill Backous (current EILS

Program Manager) for their guidance and support.

◊ Megan White (former HWTR Program Manager) and Greg Sorlie (present HWTR

Program Manager) for their guidance and support.

◊ Joe Williams (Air Quality Program Manager) for outreach to the local air pollution

control agencies.

◊ Lorie Hewitt and Rob Kirkwood of HWTR for management support and grant

management.

◊ Art Johnson, Will Kendra, Jim Knudson, Wayne Krafft, Bill Moore, Cheryl Niemi,

and Carol Piening for their insightful peer reviews of the report.

◊ Joan LeTourneau for formatting and editing the final report.

Additional invaluable assistance from within Ecology, including consultation, record

searches and review, from:

◊ Air Quality Program

◊ Industrial, Spills, and Sediments Sections of the Shorelines and Environmental

Assessment Program

◊ Environmental Investigations and Laboratory Services Program

◊ Hazardous Waste and Toxics Reduction Program

◊ Nuclear and Mixed Waste Program

◊ Solid Waste and Financial Assistance Program

◊ Toxics Clean Up Program

◊ Water Quality Program
Page x

We also thank the following agencies and entities for their extensive help locating

documents and other information, as well as providing perspective:

◊ AMTEST Air Quality, Inc.

◊ Benton County Clean Air Authority

◊ Northwest Air Pollution Authority

◊ Olympic Air Pollution Control Authority

◊ Puget Sound Air Pollution Control Authority

◊ Rayonier Pulp and Paper, Port Angeles, Washington

◊ Research Triangle Park, South Carolina

◊ Southwest Air Pollution Control Authority

◊ Spokane County Air Pollution Control Authority

◊ Tacoma City Light

◊ EPA Region X and Headquarters

◊ US Army, Fort Lewis

◊ US Environmental Protection Agency (EPA)

◊ Washington State Department of Health

◊ Yakima Regional Clean Air Authority

Funding

Funding was provided by EPA RCRA Grant # D-000742-97, the Hazardous Waste and

Toxics Reduction Program, and the Environmental Investigations and Laboratory

Services Program.
 Page xi

Acronyms

APC – Air Pollution Control

APCD – Air Pollution Control Device

AQP – Air Quality Program

ASB – Activated Sludge Basin

BAF – Bioaccumulation Factor

BCC – Bioaccumulative Chemicals of Concern (Committee)

BCF – Bioconcentration Factor

CKD – Cement Kiln Dust

d – Day

DMR – Daily Monitoring Report

EILS – Environmental Investigations and Laboratory Services

EPA – United States Environmental Protection Agency

HWTR – Hazardous Waste and Toxics Reduction Program

IARC – International Agency for Research on Cancer

LC50 – Concentration Lethal to 50% of the Population

mg – milligram

MTCA – Model Toxics Control Act

NPDES – National Pollutant Discharge Elimination System

NT – Not Tested

PCB – Polychlorinated Biphenyl

PCDD/F – Polychlorinated Dibenzodioxins and Furans

PCP – Pentachlorophenol

ppb – parts per billion

pptr – parts per trillion

QA/QC – Quality Assurance/Quality Control

RACT – Reasonable Available Control Technology

RCRA – Resource Conservation and Recovery Act

SWFAP – Solid Waste and Financial Assistance Program

TCDD – Tetrachlorodibenzodioxin

TCDF – Tetrachlorodibenzofuran

TCP – Toxics Cleanup Program

TEF – Toxicity Equivalent Factor

TEQ – Toxic Equivalent

WAC – Washington Administrative Code

WPLCS – Wastewater Permit Life Cycle System

WQP – Water Quality Program
Page xii
 Page 1

Introduction

Purpose

Polychlorinated dioxins and furans belong to a class of pollutants that are persistent, toxic

and bioaccumulative. Pollutants with these characteristics remain in the environment for

decades, often moving from one media to another (e.g., from water or air to soil and

sediment). Additionally, they enter and are distributed through the food web,

accumulating in the tissues of animals, including humans. Because these contaminants

cross boundaries between environmental media, they are regulated by a variety of laws,

regulations and programs. For all these reasons they raise unique, often difficult,

management challenges. The Washington State Department of Ecology (Ecology)

Bioaccumulative Chemicals of Concern (BCC) Committee was formed to address these

pollutants and respond to the challenges raised by managing them.

As an initial step toward improving the management of persistent, toxic, and

bioaccumulative pollutants, the BCC Committee sponsored an effort to gather,

consolidate and assess information about the sources of one group of these pollutants: the

polychlorinated dioxins and furans. (In this report, this family of chemicals is referred to

simply as “dioxins”.) The federal Environmental Protection Agency (EPA) undertook a

similar effort as part of a large national study (EPA, 1994a, 1994b). Although the EPA

draft report provided much valuable information, it was not clear how relevant the

information on sources was to conditions in Washington State.

The purpose of the Washington State Dioxin Source Assessment study is to identify

actual (“confirmed”) and potential in-state sources of dioxins. The magnitude of sources

and importance of source categories are evaluated using existing data. Understanding the

sources of dioxins is a logical first step towards an effective management strategy that

will reduce their generation and dispersal.

This report:

• Summarizes what Ecology knows and does not know about dioxin sources in

Washington State.

• Recommends actions Ecology might take to (1) improve its understanding of dioxin

sources and (2) reduce the magnitude and impact of these sources on the state’s

citizens and environment.
Page 2

Background

Dioxins are unintended byproducts formed during combustion of organic compounds in

the presence of chloride, incineration of municipal and hospital wastes, and chlorine

bleaching of wood pulp (Alcock and Jones, 1996; Birnbaum, 1994, Rappe, 1984). The

production of certain chlorinated organic chemicals also produces dioxins; they are

contaminants in certain chlorinated organic products (e.g., pentachlorophenol [PCP] – a

wood preservative). Dioxins have no commercial or domestic applications and are not

intentionally produced, except for small quantities used in research (ATSDR, 1989;

Federal Register, 1997).

Chemical Structure

There are 210 different forms (or congeners) of polychlorinated dibenzo-p-dioxins and

polychlorinated dibenzofurans (dioxins and furans). These are identified by the number

and location of chlorine atoms on the molecule. The most toxic of these congeners have

chlorine atoms at four specific sites (the 2,3,7 and 8 positions). Figure 1 shows the

structure and numbering system for these congeners. The most toxic of the dioxins is

2,3,7,8-tetrachloro dibenzo-p-dioxin (2,3,7,8-TCDD). The 16 other dioxins and furans

with chlorines at the 2,3,7 and 8 positions have been assigned toxicity values relative to

2,3,7,8-TCDD.

These relative toxicity values are called toxicity equivalency factors (TEFs).

2,3,7,8-TCDD is assigned a TEF of 1, and the other congeners are assigned values less

than 1. TEFs are used to express a total toxicity of dioxins when the concentration of

each congener is multiplied by its TEF and all the products are added up (called dioxin

equivalents or TEQs).

Concentrations of dioxins and furans in the environmental media (e.g., wastewater, tissue,

ash) are typically expressed as TEQs. An example of this calculation is shown in

Appendix A, Table A-1.
 Page 3

O

O

1

6 4

9

8

7

2

3

O

1

6 4

9

8

7

2

3

Chlorinated Dioxins

Chlorinated Furans

Figure 1. Chlorinated Dioxin and Furan Structures

Persistence, Bioaccumulation, and Toxicity

As previously noted, Ecology is focusing on the management challenges raised by toxic,

persistent, and bioaccumulative pollutants. This section briefly characterizes dioxins with

respect to these three attributes.

Persistence

Persistence is the resistance of chemicals to decomposition. One measure of persistence

is half-life (T1/2): the time required for 50% of the compound to degrade through

chemical, biochemical, and photochemical processes (Environment Canada, 1994).

Dioxins are extremely persistent in many environmental media. For example, their halflife in anaerobic soils is estimated to be 10 to 12 years; in sediments it may be decades or

centuries (Atkinson, 1992). EPA (1994b) summarizes results from four studies of

2,3,7,8-TCDD concentrations in human subjects; estimates of its half-life ranged from

5.8 to11.3 years. Atkinson (1992) estimates the half-life for dioxins in human tissue at

about five to seven years.
Page 4

Bioaccumulation

Bioaccumulation is defined as the accumulation of chemicals in organisms from the

surrounding media through absorption, ingestion and inhalation (Environment Canada,

1994). The bioaccumulation potential of a substance can be expressed as the

bioaccumulation factor (BAF) or the bioconcentration factor (BCF) (Environment

Canada, 1994). The BCF is the ratio of a chemical concentration in an organism to the

chemical’s concentration in the organism’s surrounding media, assuming steady-state

equilibrium. BCFs are calculated under controlled laboratory tests where chemical

uptake is derived solely from surrounding media. The BAF is a similar ratio, but both

surrounding media and food-chain uptake are considered. BAFs are often calculated

from field data (Environment Canada, 1994).

Dioxins are lipophilic (fat-loving) compounds and are therefore readily accumulated by

most animals. BCFs have been measured for 2,3,7,8-TCDD by many investigators and

range from about 1,000 to 86,000 in aquatic organisms (Marty and Shusterman, 1992).

Toxicity

Toxicity covers a wide range of deleterious effects of a chemical on biological systems.

These effects may be acute (immediate response) or chronic (long-term response).

Dioxins are toxic at very low dosages. Mehrle et al. (1988) report that 50% of juvenile

rainbow trout died when exposed to 0.045 parts 2,3,7,8-TCDD per trillion for 28 days.

Chronic effects include soft tissue sarcomas, thymus and liver damage, birth defects,

reproductive impairment, and immune system depression (Holloway, 1990; Birnbaum,

1994). Recently, the International Agency for Research on Cancer (IARC) concluded that

2,3,7,8-TCDD is a “known human carcinogen” (EPA, 1997a).

Recent concern about the effects of dioxins on organisms has increasingly focused on

endocrine disruption and reproductive impairment (EPA, 1997b). The EPA states

“...2,3,7,8-TCDD is one of the most, if not the most, potent reproductive/

developmental toxicants known” and “studies in various animal species have also

demonstrated that the immune system is a target for toxicity of 2,3,7,8-TCDD” (Federal

Register, 1997).

Because of dioxin’s potency, regulatory standards and criteria are set at very low

concentrations (Appendix Table A-2).
 Page 5

From Source to Human Exposure

Figure 2 shows a conceptual model for primary dioxin exposure pathways for most

organisms, including humans. The top of the figure represents dioxin sources. Dioxins

may be released directly to air, land, and water. They move from sources, through the

environment and food web, to humans and other organisms by many paths.

Pollutant Sources*

Ambient Environment

 Transitory (air, water) Persistent (sediments, soils)*

Food Web

 Crops Algae Forage

 Meat Milk Fish* Wildlife*

Humans

Bold Italic – components included in Ecology’s charge

* – components amenable to Ecology monitoring

Figure 2. Dioxin Source and Fate Conceptual Model

Dioxins are relatively insoluble in water. They bind quickly with carbon-based substrates

(e.g., oils, fats) and particles (e.g., soils, sediments). Dioxins discharged to air may settle

on water, land or vegetation. Stormwater runoff may carry dioxin-tainted soil from fields

or urban sites to streams that ultimately deposit these sediments in lakes, reservoirs or

marine waters. Dioxins in water, soil or sediment can be ingested by organisms and

transferred through the food web. Thus, dioxins move from air and water to sediments,

soils, and biological systems where they persist.
Page 6

The primary route of dioxin exposure to humans is the food chain. This is probably the

primary route for fish and wildlife as well. Wild et al. (1992) estimate that 99.96% of

background human exposure to dioxins is through food intake. Airborne dioxins land on

food or forage; waterborne dioxins may enter the aquatic food webs via filter or bottom

feeders. Humans are exposed to dioxins primarily through the ingestion of fish, meat and

milk (Albers et al., 1996).
 Page 7

Project Description

This section summarizes steps used to locate and process data for confirmed and potential

dioxin sources in Washington State. To manage time and budget constraints, the scope of

the assessment was defined by:

• Use of existing data; no resources were allocated for additional monitoring

• Focus on sources located in Washington State

• Use of data generated during the past 10 years

• Preferential focus on data reporting the full range of 2,3,7,8-substituted congeners

The quality of data used in this assessment is variable. Detailed review of data quality

was beyond the scope of the project; however, every attempt was made to use published

data or data that were available from the public record. For further information on

sampling, analytical procedures, and quality assurance/quality control (QA/QC) the

reader is directed to the source documents cited in the references.

Appendix B provides details on how we addressed the following issues:

• Data gathering

• Data processing conventions

• Detection limits

Understanding the limitations of this project will help the reader draw reasonable

conclusions and exercise interpretive caution.

• No central or comprehensive database or comprehensive monitoring program for

dioxin exists in Washington State. Therefore, these data are likely to be incomplete.

If you know of additional data, please contact the authors at the Washington State

Department of Ecology, PO Box 47600, Olympia, WA, 98504-7600.

• Data gathering was largely limited to public agencies; generally, private data held by

sources were not available.

• Source loads were determined from analytical test data only. Unlike the EPA source

evaluation work (EPA, 1994a), this project did not develop “ emission factors” to

estimate the total load from a category of sources.

• The source loads calculated for facilities may not be fully representative for the

following reasons:

◊ Data Frequency: The lack of multiple data points for most sources precludes

estimating process variability. Dioxin generation rates are often a function of

variables such as feed stock, combustion temperature, and throughput. Variation

in dioxin loads can be considerable, as indicated from facilities where multiple
Page 8

measures are available. Many of the loads we report are calculated from a single

measurement. Many loads may have a high or unknown variability associated

with them.

◊ Analytical Completeness: To minimize negative bias (underestimation of specific

loads), we used only data that report the full range of 2,3,7,8-substituted

congeners. The one exception was the use of wastewater and sludge data for

bleached pulp and paper mills that report concentrations for only two of the 17

toxic congeners (2,3,7,8-TCDD and 2,3,7,8-TCDF).

◊ Calculated loads were not adjusted for the percent of time the facility was

discharging. This is generally not an issue for loads to water or land (e.g., ash or

sludge). However, air loads from small incinerators that operate on a batch mode

or intermittently are calculated from short-term tests and may over-estimate longterm averages. For this reason, we have flagged the loads calculated for the

Olivine Incinerator. There are probably loads from other small incinerators that

would have been adjusted downward if we had located detailed information on

their operating practices.

◊ The quality of data gathered here is variable. Although a comprehensive review

of data quality was beyond the scope of this project, it was clear in several cases

(e.g., estimates of ash generation rates from hog-fuel boilers) that the reliability of

several estimates was uncertain.

Media Analyzed

Loads were calculated from analyses of a range of media including air emissions, sludges,

ash, and wastewater discharges. Air emissions data were obtained primarily from source

tests of stacks. Sludge loads were calculated from analyses of biosolids from treated

municipal and industrial wastewaters. Wastewater loads were calculated primarily from

analyses of process wastewaters; however, some other wastewaters including stormwater

runoff, cooling water discharges and/or ash-quenching or wet-scrubber wastewaters were

also addressed.

Ash loads were calculated from analyses of bottom ash, fly ash (air pollution control

residues), and mixed ash produced by incinerators and industrial boilers. Bottom ashes

are generally a mixture of grate ash and grate siftings. These materials fall to the bottom

of the boiler/incinerator and are mechanically removed (EPA, 1996). Air pollution

control (APC) residues include fly ash, absorbent materials, and condensation or reaction

products. Fly ashes are non-combustible residual particles expelled by flue gas (EPA,

1996a). APC devices include cyclones, wet scrubbers, electrostatic precipitators, and

baghouses. Mixed (or “total”) ashes include both the bottom ash and fly ash generated by

a facility.
 Page 9

Dioxin TEQ Loads

The reporting of dioxin loads is an important concept in this assessment. A “load” is

defined as the rate at which dioxin is generated or discharged. Loads are expressed as a

mass per unit time; in this report the units used are milligrams of dioxin TEQs per day

(mg TEQ/d). To calculate a load, we first determined the TEQ for the material tested

(e.g., air, water, ash). The TEQ is calculated by multiplying the concentration of each

detected 2,3,7,8-substituted congener by the TEF for that congener.1 The resulting TEQ

for each congener is summed to determine the total TEQ of the sample. Appendix Table

A-1 shows an example TEQ calculation for a sample containing many dioxin congeners.

The calculation of dioxin load requires two pieces of information: 1) the concentration of

dioxin congeners in the medium produced or released, and 2) the rate at which that

medium is generated and/or released. These two parameters are often available from the

same data source: e.g., air emission source tests, discharge monitoring reports required

by the National Pollutant Discharge Elimination System (NPDES) wastewater permits.

Dioxin data and production rates for ash and sludge are often reported separately.

Sometimes concentrations of dioxins are measured in soil, stormwater, or other media;

but the rate of generation or discharge is not measured. Loads cannot be calculated in

these cases.

Confirmed Dioxin Sources

Where adequate data allow, we calculate dioxin loads (i.e., the rate at which dioxins were

generated) for individual sources. “Confirmed source categories” are source categories

that have at least one facility with data adequate to calculate a dioxin load.

Both active and closed facilities with documented dioxin loads are included as

“confirmed sources.”

Potential Dioxin Sources

In addition to confirmed source categories, this assessment provides information on

“potential sources categories”. These include source categories for which there may be

dioxin data but available data do not allow calculation of dioxin loads. For instance,

potential sources include contaminated sites with confirmed dioxin contamination.

Dioxin could potentially be moving from some of these sites, if they are not yet fully

remediated. However, data are not available to calculate these loads.

Another potential source category is wood treating that uses pentachlorophenol (PCP).

PCP is contaminated with low concentrations of dioxins, and many sites with confirmed

dioxin contamination are former PCP wood-treating facilities. Although contamination

 

1

 The calculation of TEQ for a media sample containing 5 ppt 2,3,7,8-TCDD and 23 ppt 2,3,7,8-TCDF

(considered 1/10 as toxic as TCDD, it has a TEF of 0.1) is: [5 + (0.1 x 23)] = 7.3 ppt TEQ.
Page 10

of wood-treating sites with dioxin has been confirmed, the rate at which these dioxins are

discharged in stormwater is available only for short-term storm events. These results are

not directly comparable to the more continuous loads presented in the Confirmed Sources

section, although rough estimates can be made. Other potential dioxin source categories

include those identified by EPA (1994a) in their national dioxin source assessment but for

which Washington State data are inadequate to calculate loads.
 Page 11

Results and Discussion

During the course of this project, available data allowed us to identify 25 facilities/

processes with measurable dioxin loads. Of these 21 are active and four are closed.

Fifteen (twelve active, three closed) discharge to air; nine (eight active, one closed) to

water; and nine (eight active, one closed) to land. For the purposes of this report, we

account for dioxin loads in materials sent to landfills, as well as materials that are applied

to land in other ways (i.e. soil amendments, land application).

The dioxin loads reported here were calculated from data from a variety of sources as

described previously (see Project Description).

Appendix Table A-3 summarizes the calculated loads assuming that the concentration of

undetected congeners is zero. Loads calculated using three different methods of handling

detection limits are summarized in Appendix C. The data sets from which the loads were

calculated are tabulated in Appendix D of this report.

Data Gaps

The available data on dioxin sources in Washington State are generally sparse. This is

partly because Ecology’s authority to require dioxin testing is limited. Appendix Table

A-4 summarizes state and federal regulations authorizing or requiring dioxin monitoring.

Figure 3 displays some of the data gaps revealed by this assessment. Processes are

displayed on one axis; the media to which a load is discharged is shown on the other axis.

The dark portion of each bar represents the number of facilities engaged in that process

with adequate data to determine at least one dioxin load. The open portion of the bar

represents the number of facilities for which no dioxin loading data were available.

Data “completeness”, as measured by the proportion of facilities in a source category with

at least one dioxin load, varies greatly. A number of the source categories have loading

data for each of the facilities engaged in that process. However, large segments of

important source categories have no loading data. For example, wastewater loads could

not be calculated for any of the approximately 250 municipal wastewater treatment

plants, and biosolids loads were available for only one of the 250. Likewise, air loads

were available for only 2 of 84 hog-fuel boilers, while ash loads were available for 3 of

84.

It is clear that the data are, at best, partial. We have taken these substantial data gaps into

account in the process-by-process discussions that follow.
MEDIA:

AIR WATER LAND

0 10 20 30 40

3

4

5

6

7

8

9

(9/9)

(0

0 10 20 30 40

3

4

5

6

7

8

9 (Ash) (3/84)

0 10 20 30 40

3

4

5

6

7

8

9

(2/84)

(Wastewater sludge) (1/250)

# of facilities with at least one data point

# of facilities with no data

(Wastewater sludge)

(Ash) 

(Ash) 

(Cement Kiln Dust)

Hog Fuel Boilers

Municipal Waste 

Incineration

Cement Kiln

Process

Activated Carbon 

Regeneration

Medical Waste 

Incineration

Bleached Pulp/Paper 

Wastewater Treatment

Municipal Wastewater 

Treatment

Number of Facilities Number of Facilities Number of Facilities (type of waste)

(3/6)

(0/16)

(2/2)

(1/2)

(0/250)

(1/1)

(2/16)

(5/6)

(2/3)

Figure 3. Number of facilities with dioxin data, by media. Categories include those for which there is at least one data point.
 Page 13

“Importance” of Source Categories

Information about each of the confirmed source categories1 follows. This includes

background information on each category, calculated dioxin loads, completeness of data

coverage for facilities in the category, potential for the dispersion of dioxin loads, and the

national rank of the category based on data reported by EPA (1994a).

EPA’s approach to estimating national dioxin loads differs from the approach used in this

report. The main difference is that this study relies on monitoring data from specific

facilities, while EPA developed “emission factors” for various activities and used them to

estimate the total load generated by that activity. EPA (1998) offers this explanation of

an emission factor:

“The emission factor relates mass of CDD/CDFs [dioxins]...released to the

environment per some measure of activity (e.g., kilograms of material processed per

year...). The emission factor was then multiplied by a national value for the activity

level (e.g., total kg of material processed in the United States annually).”

After information is presented on each of the source categories, the importance of the

category is evaluated in two ways:

• Importance of obtaining additional data

• Importance of additional source control

The importance of obtaining additional data is based primarily on two considerations: the

shortcomings in available data and the potential for the source category to be an important

continuing source of dioxins.

The importance of source control is based on several considerations: the magnitude of

confirmed dioxin loads associated with the source category, the potential magnitude of

loads from untested facilities, and the potential for dispersion of loads generated by the

facilities.

Recommendations at the end of this report are based, in large part, on these

determinations of importance.

1

 In this report the term “confirmed source category” means a source category for which we have data

adequate to calculate at least one dioxin load for at least one facility in that category.
Page 14

Municipal and Medical Waste Incinerators

Background

We located information on 22 municipal waste incinerators and medical waste

incinerators (Table 2). Municipal and medical waste incinerators are discussed jointly

because of their similar functions and because of overlap in the materials burned by these

facilities. Three currently operating incinerators primarily burn municipal solid waste:

Spokane Municipal Incinerator (a waste-to-energy facility), US Army Fort Lewis

Incinerator (Pierce County), and Olivine Municipal Incinerator (Whatcom County). A

fourth municipal waste incinerator, the Skagit County Incinerator, ceased operation

around 1994.

Table 2. Municipal and Medical Waste Incinerators

Municipal Waste Incinerators County Status Dioxin Data

Spokane Spokane Active Air, Ash

Fort Lewis Pierce Active Air

Olivine Whatcom Active Air

Skagit County Skagit Closed

Cogeneration Facility

Tacoma City Light #2 Pierce Closed Air

Municipal/Medical Incinerator

Recomp Whatcom Active Air, Ash

Medical Waste Incinerators

Northwest Hospital King Active Air

US Veterans Adm. Medical Center King Active Air

Battelle Marine Sciences Lab Clallam Active

Capital Medical Center Thurston Active

Forks Community Hospital Clallam Active

Grays Harbor Community Hospital Grays Harbor Active

Island Hospital Skagit Active

Kennewick General Hospital Benton Active

Kittitas Valley Community Hospital Kittitas Active

Mid Valley Hospital Okanogan Active

North Valley Hospital Okanogan Active

Swedish Hospital King Closed

Providence Yakima Hospital Yakima Closed

Skyline Hospital Klickitat Active

St. Joseph Hospital Stevens Active

Providence St. Peter Hospital Thurston Closed
 Page 15

The Recomp Incinerator (formerly Thermal Reduction Company) in Whatcom County

burns both municipal wastes and medical wastes; while Tacoma City Light Steam

Plant #2, which closed in the spring of 1998, burned a mixture of “refuse-derived fuel,”

wood waste and other fuels.

Sixteen medical waste incinerators were identified, three of which no longer operate. In

general, these incinerators are smaller than those that burn municipal waste.

One other facility, Holnam Cement, Inc. of Seattle, conducted several air emissions tests

while burning “Sterifuel,” a sterilized, pelletized medical waste. The Holnam cement

kiln is discussed in the Cement Kilns section.

Table 3 summarizes loading data, facility status, and solid waste disposition information

for all incinerators with dioxin data. Each of these categories is discussed in more detail

below.

Loading Data

Of the 22 incinerators listed in this section, we are able to estimate dioxin loads in air

emissions for seven and loads in ash for three (Table 3). The detailed loading data for

each facility are provided in Appendix Table A-3. At one time there was a wastewater

(cooling tower) discharge from the Recomp Incinerator; however, this discharge was

eliminated approximately two years ago (Zinner, 1998). No dioxin data are available for

this wastewater discharge.

Data are most complete for the Spokane Incinerator. Air emissions are represented by

five source tests that yielded loads averaging 0.25 mg TEQ/day. Two series of ash tests

yielded an average load of 31.2 mg TEQ/day. One ash test (1992) allows comparison of

the grate ash load (0.02 mg TEQ/day) with the fly ash load (24.3 mg TEQ/day). Most of

the dioxin from this facility is associated with captured fly ash. This appears to be the

pattern for relatively new incinerators with highly effective air pollution control devices

(APCDs).

Air and ash data are also available for the new Fort Lewis Incinerator. Based on a single

set of source tests, the air emission from this facility is estimated at 0.003 mg TEQ/day.

Based on one year’s composite samples, the dioxin load in fly ash was

0.76 mg TQ/day. No dioxins were detected in the bottom ash.

In recent years, the Olivine Incinerator has operated infrequently. Loads calculated from

two source tests (1994, 1995) average 3.8 mg TEQ/day. Because of Olivine’s infrequent

operation this load probably overestimates its discharge relative to other facilities. No

data were available on dioxins in Olivine’s ash.
Table 3. Incinerator Dioxin Loads, Facility Status, and Solid Waste Disposition

Incinerators Load to (mg TEQ/day)

 Air Water Land Total

FacilityStatus

Solid Waste Disposit

Municipal WasteSpokane MunicipalIncinerator, Spokane

0.25 31.2 31.5 Active Ash disposed of at the Regional Ash Mono

Olivine Municipal Incinerator,Ferndale

3.8* 3.8* Active but

intermittent

Fly ash disposed of at the Regional Ash MoWA; previously disposed of at on-site landf

Fort Lewis Incinerator,Tacoma

0.002

8

0.76 0.76 Active Ash disposed of at the Regional Ash Mono

Total 4.1* 32.0 36.0

Medical WasteUS Veterans Adm. MedicalCenter, Seattle

0.54 0.54 Active Fly ash designates as hazardous waste; sh

Bottom ash sent to Columbia Ridge Landfil

Northwest Hospital, Seattle 0.15 0.15 Active Fly and bottom ash sent to Columbia Ridge 

OR.

Total 0.69 0.69

Medical/Municipal

Recomp Incinerator, Ferndale 4.0 1.1 5.1 Active Fly ash disposed of at the Regional Ash Mo

WA; previously disposed of at on-site landf

Total 4.0 1.1 5.1

CogenerationTacoma City Light, Tacoma 0.078 Closed Ash was sold to hazardous waste treatmen

Total 0.078

Total 8.8* 33.1 41.9

*The Olivine Incinerator has operated infrequently in recent years. Therefore, these values probably overestimate typical dioxin loads.
 Page 17

Information on air emissions was also available for Tacoma City Light Steam Plant #2.

Four source tests were conducted before the facility closed in 1998 and averaged

0.08 mg TEQ/day. No data were available for ash.

As noted previously, the Recomp Incinerator burns both municipal and medical wastes.

Air emissions data are available for a single source test in 1988. This test yielded a load

of 4 mg TEQ/d. Air pollution control systems at Recomp have changed substantially

since the 1988 test. In 1988 the incinerator had an electrostatic precipitator. Currently air

emissions pass through an evaporative cooling tower, Venturi reactors with hydrated lime

injection and baghouses (Naismith, 1998). The effect of these changes on dioxin air

emissions has not been measured. Three sets of ash results (1994-1996) yield an average

load of 1.1 mg TEQ/day.

Of the 16 medical waste incinerators, air emissions data are available for two – each

based on a single set of source tests. The load for the US Veterans Administration (VA)

Medical Center in Seattle was estimated at 0.54 mg TEQ/day; the load for Northwest

Hospital was estimated at 0.15 mg. TEQ/day. No dioxin data are available for ash.

Dispersion

Dioxin loads emitted to the air can be widely dispersed. Although many of these facility

loads are small, several appear to be appreciable. Few of the medical waste incinerators

have APCDs that remove fly ash prior to discharge: the VA Medical Center and

Northwest Hospital are exceptions. Although no loading data are available for

incinerators without APCDs, any load from these facilities would be discharged to the air

and therefore dispersed.

Ashes generated and collected by incinerators are handled in several different ways. Ash

generated by the Spokane and Fort Lewis incinerators goes to the Regional Ash Monofill

in Roosevelt, Washington. This is also the destination for fly ash currently generated by

the Recomp and Olivine incinerators. Prior to 1990, ash generated by Recomp and

Olivine facilities was disposed of in on-site landfills. Ash generated by Tacoma City

Light Steam Plant #2 was sold to hazardous waste treatment and storage facilities, where

it was used to solidify liquid wastes prior to their disposal.

Several of the facilities currently sending their ash to the Roosevelt landfill are pursuing

other alternatives that could increase dispersion potential.

Fly ash from the VA Medical Center Incinerator designates as hazardous waste. It is

handled by Laidlaw Environmental Services and shipped to a landfill in Utah. Bottom

ash from the VA Incinerator, as well as both fly ash and bottom ash from the Northwest

Hospital Incinerator, are sent to the Columbia Ridge (Solid Waste) Landfill in Arlington,

Oregon (Jill Trohimovich, 1998). Other medical waste incinerators apparently do not

have APCDs that capture fly ash.
Page 18

National Rank

EPA (1994), using a methodology different than the one used here, addressed medical

waste and municipal waste incinerators as separate categories. Based on the sum of loads

to all media, medical waste incinerators were the source category with the largest national

load. Municipal waste incinerators had the second largest dioxin load.

EPA used an “emission factor” approach. This, in general, means that EPA tried to

accounts for all sources when estimating loads. We report only the results of specific

source tests from specific facilities.

Several aspects of EPA’s work should be noted, so comparisons between the two

assessments for medical waste incinerators can be considered in context. The EPA

assessment includes several types of “medical waste” incinerators that we did not address

(e.g., veterinary incinerators, crematoria, and animal shelters). The EPA “emission

factor” was derived from “uncontrolled emissions.” Thus, EPA would have accounted

for particulates escaping in air emissions, that would be captured as fly ash if there were

an air pollution control device in place. We have no data for dioxins in uncontrolled

emissions, or fly ash captured in APCDs from medical waste incinerators. Our data,

therefore, do not account for particulate/fly ash emissions from medical waste

incinerators.

Finally, EPA notes that tests of “controlled-air medical waste incinerators” with a variety

of emission controls yielded lower emission factors. They acknowledge that “based on

these data, it appears that national releases [to air] from medical waste incinerators could

be much lower...” than those they report.
 Page 19

Summary - Incinerators

Incinerators

Data Coverage Air Water Land Overall

Municipal 3 of 4 2 of 4 50-75%

Medical 2 of 16 0 of 16 0-10%

Medical/Municipal 1 of 1 0 of 1 1 of 1 0-100%

Cogeneration 1 of 1 0 of 1 0-100%

Total 7/22 0/1 3/22 0-32%

Confirmed Loads

(mg/ TEQ/day) Air Water Land Total

Municipal 4.11 32.0 36.0

Medical 0.69 - 0.69

Medical/Municipal 4.0 1.1 5.1

Cogeneration 0.078 - 0.078

Total 8.81 33.1 41.9

Dispersion

Potential Air Water Land Overall

Municipal high generally low varies

Medical high unknown varies

Medical/Municipal high discontinued generally low varies

Cogeneration high generally low varies

Total high generally low varies

Active vs. closed: 5 closed; others active

Estimated national rank: Municipal 2nd

Medical 1st

Importance of obtaining additional data: High

Rationale: Although data for some incinerators (especially the newer municipal waste

incinerators, e.g., Spokane and Fort Lewis) are relatively robust, data for the others are

sparse or entirely absent. For example, no fly ash data are available for the Olivine

Incinerator, the Tacoma City Light Cogeneration Plant (now closed), or any of the

medical waste incinerators. Air data for dioxins are not available for a number of medical

waste incinerators; however, adoption of the new federal emissions guidelines for

existing medical waste incinerators should address this data gap (see next page).

Importance of additional source control: Variable

 

1

 Olivine Municipal Incinerator has operated infrequently in recent years. Therefore, this value probably

overestimates average dioxin loads
Page 20

Importance of sequestering fly ash: High

Rationale: The estimated overall load (41.8 mg TEQ/day) associated with incinerators is

high in comparison to other source categories for which data are available. Most of this

load was associated with fly ash. Two of the older incinerators accounted for most of the

air load, although the available data may overestimate the importance of these sources.

Medical waste incineration ranked 1st overall in EPA’s national dioxin source

assessment, while municipal waste incineration ranked 2nd.

Based on the available information, the source control of air emissions seems to be least

stringent for the Olivine and Recomp incinerators. Control of air emissions may be an

issue, as well, for the medical waste incinerators for which no air emissions data are

available. Performance standards for new medical waste incinerators and emissions

guidelines for existing medical waste incinerators will be incorporated into state

regulations over the next several years. This means that air emissions from all medical

waste incinerators will have been tested and will meet these new, federally promulgated

limits by no later than 2004.

Much of the fly ash collected in APCDs is disposed of in the Roosevelt Ash Monofill or

in other ways that appear to sequester this ash effectively. Because the highest loads of

dioxins were associated with fly ash captured by air pollution control devices at these

incinerators, it is important that this ash continue to be sequestered so it is not

reintroduced into the general environment. There is, however, considerable interest by

some facilities in finding less expensive ways of disposing of this ash. It is important that

alternative methods of reuse or disposal continue to effectively sequester these wastes.
 Page 21

Hog-fuel Boilers

Background

Many industrial boilers in Washington are fired wholly or in part by wood-derived fuels.

Fuel derived from waste wood is often called “hogged fuel”; facilities that burn this fuel

are referred to as “hog-fuel boilers.” About 25% of the wood-waste boilers in the state

are located at pulp and paper mills. In addition to wood waste, these boilers often burn

wastewater sludges or fiber, as well as other fuels (Table 4). Burning

salt-laden hog fuel (wood waste from logs rafted on saltwater) has been implicated in the

production of dioxins (Luthe and Prahacs, 1993).

Ecology’s Air Quality Program (Ecology, 1997a) summarized and assessed much of the

available information on Washington’s hog-fuel boilers. Data on boiler locations,

operational status, and fuels, gathered by the Air Quality Program in support of that

assessment (Ecology, 1997b), are summarized in Table 4.

Table 5 summarizes loading data, facility status, and solid waste disposition information

for all hog fuel boilers with dioxin data. Each of these categories is discussed in more

detail below.

Loading Data

Of the 84 hog-fuel boilers listed in Table 4, we were able to estimate dioxin loads in air

emissions from two facilities and loads in ash from three (Table 5). Detailed loading data

are provided in Appendix Table A-3. All of the facilities with dioxin data have air

pollution control equipment that removes much of the fly ash before discharge to the air.

These facilities also generate “bottom” (or “grate”) ash. Often fly ash and bottom ashes

are mixed together prior to disposal.

We found reportable data for both air and ash loads for only one facility, the Rayonier

Inc. pulp mill located in Port Angeles. The mill closed in 1997. Air emissions are

represented by a single source test conducted in 1995 (Foster Wheeler, 1997). This test

yielded a load of 0.17 mg TEQ/d.

Accurate estimates of the rate of ash generation were difficult to obtain. Like other such

facilities, Rayonier was never required to measure ash generation rates. We were,

however, able to obtain two estimates. Perlwitz (1997) estimated that ash was generated

at the rate of three to six tons per day, while allowing that “possible ash generation rates

as high as 15 tons per day could have occurred.” The second estimate
Table 4. Hog-fuel Boilers

Facility County

Active/ Closed

Salt WaterAccess*

# ofBoilers Primary Fuels

SaltyFuels Ot

Allen Logging Clallam Active 1 Green sawdust & planer shavingsBennett Lumber Asotin Active 1 BarkBoise Cascade-Wallula Walla Walla Active 1 Wood & bark NatBoise Cascade-Yakima Yakima Active 1 Wood & barkBoise Cascade-Kettle Falls Plywood Stevens Active 1 Wood & bark SomBoise Cascade-Kettle Falls Lumber Stevens Active 1 Wood & barkBrooks Manufacturing Whatcom Active Yes 1 Dry planer shavings (10% moisture) 10% salty NatBuffelen Woodworking Pierce Active Yes 1 Wood & bark No NatCascade Hardwood Lewis Active 1 Dried planer shavings & sawdust NatCoastCraft Pierce Active Yes 2 Wood UnknownColumbia Harbor Lumber Lewis Active 1 Hog bark & planer shavings NoColville Indian Precision Pine Okanogan Active 1 Hog fuelCowlitz Stud-Morton Lewis Active 1 Hog fuel & planer shavings NoCowlitz Stud-Randle Lewis Active 1 Hog fuel & planer shavings NoDaishowa America Clallam Active Yes 1 Hog fuel - bark wood waste Possible ResGeorgia Pacific Whatcom Active Yes 4 Wood waste 91-100% unknown % NatGN Plywood/Mt Baker Plywood Whatcom Active Yes 1 97% wood, 3% various 20% saltyGrays Harbor Paper LP Grays Harbor Active Yes 2 Hog fuel Unknown #6 fHigh Cascade Lumber Clark Active 1 Hog fuelHigh Cascade Veneer Skamania Active 1 Wood bark NoHoquiam Plywood Grays Harbor Active Yes 1 Wood & bark UnknownFort James Paper Clark Active 1 Hog fuel No Pul

clar

Jeld-Wen Fiber of Washington Yakima Active 1 Hog fuelJeld-Wen of Everett Snohomish Active Yes 1 Hog fuel No NatKimberly-Clark Snohomish Active Yes 1 80% wood; sawdust, bark, other

wood waste

Possible # 2 

prim

Kinnear of Washington Lewis Active 1 Sawdust & shavingsKoenig FA & Sons Snohomish Active 1 SawdustK-Ply Clallam Active 2 75% wood, 20% bark, 5% wood

dust

40% salty

Laymans Lumber Yakima Active No 1 Wood & barkLongview Fibre Chelan Active No 1 Bark & sawdustLongview Fibre Cowlitz Active Yes 3 Hog fuel & non-condensable gases

not included in fuel rates

No #6 f

resitras

Mayr Brother Logging Grays Harbor Active Yes 1 50% bark, 50% woodMorton Forest Products Lewis Active 1 70% bark, 30% wood chips NoNW Hardwoods Cowlitz Active 1 Fine wood fibers, sander dust 10% salty Nat* If the facility is located on the Pacific Ocean or Puget Sound, “yes” is entered
Facility County

Active/ Closed

Salt WaterAccess*

# ofBoilers Primary Fuels

SaltyFuels Ot

NW Hardwoods Lewis Active 1 Sander dust 22% salty NatNW Hardwoods Skagit Active 1 Green sawdustNW Hardwoods Snohomish Active 1 Wood & sander dust 15% salty NatOeser Company Whatcom Active Yes 1 Hog fuel No NatOmak Wood Products Okanogan Active 2 Wood & BarkPacific Hardwoods Pacific Active Yes 1 Wood & bark NoPacific Veneer Grays Harbor Active Yes 1 Wood & bark NoPackwood Lumber Lewis Active 1 Bark & sawdust NoPlum Creek Manufacturing-Arden Stevens Active 1 70% bark, 30% white wood wastePort Townsend Paper Clallam Active Yes 1 Hog fuel Possible #6 rRainier Veneer Pierce Active 1 Wood & barkRayonier Inc. (Pulp) Clallam Closed Yes 1 80-90% hog fuel 2% salty Oil 

prim

SDS Lumber Klickitat Active 1 Bark & sander dust planings NatShakertown Lewis Active 1 Hog fuel, sawdust, shavingsSimpson Tacoma Kraft Pierce Active Yes 1 Wood 50% salty Res

fibe

Simpson Timber* Grays Harbor Active Yes 1 Dry hog fuel, sawdust, sander dustSimpson Timber Mason Active Yes 1 Hog fuel 20% salty Tire Smith Street Mill Snohomish Active Yes 1 Sawdust & dry shavings UnknownStone Consolidated Pierce Active Yes 1 Hog fuel 10% salty Res

slud

Summit Timber Snohomish Active 1 Hog fuel & sawdustTacoma City Light Pierce Active Yes 2 Wood 5% salty NatTebb Fred & Sons Pierce Active Yes 1 Wood UnknownVaagen Brothers Lumber-Colville Ferry Active 1 60% Bark, 40% wood, hog fuel, &

dry shavings

Vaagen Brothers Lumber-Republic Stevens Active 2 80% wood, 20% otherWashington Water Power Stevens Active 1 Hog fuel NatWest Coast Door Pierce Active Yes 1 Wood UnknownWest Coast Forest Products Snohomish Active 1 Wood NatWestern State Hospital Pierce Active Yes 1 Wood Unknown NatWeyerhaeuser-Longview Cowlitz Active 7 Hog fuel & wood No Mix

cuboil; 

Weyerhaeuser-Cosmopolis Grays Harbor Active Yes 1 Wood residuals, biomass No ResWeyerhaeuser-Snoqualmie King Active 2 WoodWeyerhaeuser-Raymond Pacific Active Yes 1 Hog fuel No* If the facility is located on the Pacific Ocean or Puget Sound, “yes” is entered.
Page 24

Table 5. Hog-fuel Boiler Dioxin Loads, Facility Status, and Solid Waste Disposition

Hog-fuel Boilers Load to (mg TEQ/day)

Air Water Land Total

Facility

Status

Solid Waste

Disposition

Rayonier Pulp and

Paper, Port Angeles

0.17 22.2 22.4 Closed Ash was

disposed of in

private landfills.

Fort James Pulp and

Paper, Camas

0.54 0.54 Active Fly ash is

marketed as

"Nutrilime" and

applied to land.

Weyerhaeuser Pulp

and Paper, Longview

0.11 0.11 Active

Daishowa Pulp and

Paper, Port Angeles

0.012 0.012 Active Ash disposed of

in private landfills.

Total 0.28 22.8 23.0

was provided in an application for a disposal site permit submitted by Rayonier to

Clallam County (Jones, 1989). The application estimates the mass of “ash and clinkers”

at 6000 tons per year, or 16.4 tons per day. We chose to use a rate of 6 tons per day to

calculate TEQ loads associated with Rayonier’s ash. Based on this, the five available ash

analyses yielded loads ranging from 1.2 to 69 mg TEQ/d, averaging

22.4 mg TEQ/day. Thus, the Rayonier data indicate that most of the dioxin load is

associated with ash.

Data were available to estimate dioxin in air emissions from Weyerhaeuser Pulp and

Paper, Longview. Information on potential dioxin loads from this facility are contained

in a notable and comprehensive study conducted by Weyerhaeuser (1991) that evaluated

disposal options for sludge and examined how the burning of various fuels affected

dioxin production. For estimating air emissions we used information from a test which

burned wood waste and coal – the test that reflected standard operating conditions at the

boiler. The load associated with this test was 0.11 mg TEQ/d.

Weyerhaeuser measured dioxin concentrations in ash, as well as fuel and air emissions,

for one set of fuel conditions – burning wood waste, coal and sludge from their waste

water treatment plant. The fuels used in this test do not represent operating conditions at

the plant (e.g., wastewater sludge is disposed of in a landfill, see Deposition section).

The resulting loads were, therefore, not included in load calculations presented in

Appendix Table A-3. Nonetheless, the test provides useful information.
Page 25

Weyerhaeuser (1991) measured loads in fuel (wood, coal and sludge) and in the air and

ash emissions of the hog-fuel boiler. The results are shown below:

Table 6. TEQ Loads Into and Out of a Hog-fuel Boiler (Weyerhaeuser, Longview)

Loads in Fuels (mg

TEQ/day)

Loads in Emissions (mg TEQ/day)

Wood 0.00 Air Emission 0.33

Coal 0.00 Grate Ash 0.00

Sludge 6.74 Cyclone Fly Ash 7.92

Electroscrubber Fly Ash 10.58

Total 6.74 18.83

These data lead to several useful observations:

• The dioxin load from this test yields air and ash loads quite similar to those reported

for the Rayonier hog-fuel boiler.

• The distribution of dioxin loads between air (low) and ash (high) is quite similar for

the two boilers.

• Essentially all the dioxin ash load is associated with fly ash rather than grate ash.

• There is a net increase in dioxin load across the boiler (the load leaving the hog-fuel

boiler is greater than the load entering it).

The sludge burned in this test was generated prior to substantial reductions in chlorine

bleaching at this and other Washington mills.

Data from the Fort James Pulp Mill in Camas provides a second fly ash load. The fly ash

was analyzed by Ecology in 1997 as part of a fertilizer and soil amendment study

(Magoon, 1997). The load is estimated at 0.54 mg TEQ/day based on a 1997 production

rate of 6,166 tons/year (Le, 1998a) for fly ash applied to farmland as a soil amendment.

This fly ash is marketed as “Nutrilime.”

Data from the Daishowa mill in Port Angeles provides the third ash load: an estimated

0.012 mg TEQ/ day.
Page 26

Dispersion

Dioxin loads emitted to the air have the potential to be widely dispersed. For the few

facilities having both data and relatively efficient air pollution control devices, most of

the load is captured in the fly ash prior to being dispersed to the air. Air emissions from

boilers without particulate controls will be widely dispersed. Ecology’s Wood Waste

Boiler Survey (Ecology, 1997a) found that 12% of hog fuel boilers had no air pollution

control equipment, while an additional 13% had relatively inefficient “mechanical

collection.”

Fly ash captured by air pollution control devices is handled in several different ways.

Ash from Rayonier and Daishowa was/is sent to nearby private landfills (Matthews,

1998). Fly ash from Fort James is marketed as “Nutrilime” and is applied to agricultural

land (Cascade Earth Sciences Ltd,, 1996). Although we have no loading estimates for

other hog-fuel boiler ash loads, we located some information on the disposition of these

ashes. For instance, portions of the ash from the Boise Cascade mill at Wallula have been

landfilled on-site, added to biosolids for composting and sent to Holnam Cement in

Seattle where it is used in the production of Portland cement (EGR and Associates, Inc.,

1997). Fly ash from the Simpson Tacoma Kraft mill is sent to the regional Rabanco

landfill in Roosevelt, Washington, while the grate ash goes to a private landfill in

Shelton, Washington (McEntee, 1997).

Based on available information, the potential for ash dispersion is variable depending on

the practices at each facility.

National Rank

EPA (1994), using a different methodology, provides national estimates that rank wood

waste boilers 5th largest among source categories. It is likely that this category of sources

is more important in Washington State than nationally for several reasons:

• Timber-related industries represent a much larger portion of commerce in Washington

than nationally.

• The potential for salt-laden hog fuel, derived from logs rafted on salt-water, is much

higher in Washington than nationally.

• Burning of other fuels in wood waste boilers is prevalent (Table 4). These fuels

include sludges from mill wastewater treatment plants, chipped tires and used oil.

• EPA’s national assessment appears to have considered only emissions to air. We

found the highest loads to be associated with fly ash. Thus EPA may have

underestimated the importance of this source nationally.
Page 27

Summary - Hog-fuel Boilers

Hog-fuel Boilers

Air Water Land Overall/Total

Data Coverage 2 of 84 3 of 84 ~3%

Confirmed Loads

(mg/ TEQ/day) 0.28 22.8 23.0

Dispersion Potential High Variable High/Variable

Active vs. closed: 1 closed; most active

Estimated national rank: 5th

Importance of obtaining additional data: High

Rationale: The combination of few data (loads available for only about 3% of the

boilers) and high dioxin loads from at least some of those facilities argues strongly for the

collection of additional information on hog-fuel boilers. This process category has a

relatively high number of facilities (84), with high variability in the factors that lead to

dioxin formation and control (e.g., boiler design and operation, fuels, air pollution control

devices).

Importance of additional source control: Potentially high

Rationale: The estimated overall load (23 mg TEQ/day) associated with hog-fuel boilers

is high in comparison to other source categories for which data are available. Industrial

wood burning rated 5th overall in EPA’s national dioxin source assessment. It is likely to

be relatively more important in Washington State. The boiler that was the largest

confirmed source ceased operations in 1997. However, there are a number of facilities of

equivalent size, burning similar fuels that are likely, in aggregate, to generate significant

loads of dioxin.

The confirmed load associated with fly ash (22.8 mg TEQ/day) was much greater than the

confirmed load associated with air emissions (0.28 mg TEQ/day). This is probably

because the facilities for which data are available have sophisticated particulate control

devices. Many hog-fuel boilers have less sophisticated (or no) particulate controls. The

potential for dispersion of air emissions is high; the potential for the dispersion of fly ash

captured by APCDs is variable. Some fly ash is disposed of in landfills, some is

marketed as a “soil amendment.” The disposition of much of it is unknown.
Page 28

Bleached Pulp and Paper Mills

Background

Seven mills in Washington currently produce bleached pulp and/or paper. An eighth, the

Rayonier Mill in Port Angeles, ceased operation in 1997. A ninth, Longview Fiber, no

longer operates a bleach plant. In the early 1990s, Washington mills shifted from

chlorine bleaching to chlorine dioxide bleaching which decreased the production and

release of dioxins. This section addresses the dioxin loads associated with wastewater

discharges from these facilities.

As process wastewaters are treated, sludges (which can also contain dioxins) are

generated. One facility, the Boise Cascade Mill in Wallula, composts its sludge for

subsequent on-site land application. A second facility, the Weyerhaeuser Mill in

Longview, landfills its sludge. The other mills burn their sludges in hog-fuel boilers.

Although all of the mills have hog-fuel boilers, this section focuses on dioxin loads

associated with the bleached pulp and paper process.

Table 7 summarizes loading data, facility status, and solid waste disposition informa-tion

for bleached pulp and paper mills. Each of these categories is discussed below.

Table 7. Bleached Pulp and Paper Mill Loads, Facility Status, and Solid Waste

Disposition

Bleached Pulp

and Paper Mills

Load to (mg TEQ/day)

 Air Water Land Total

Facility

Status

Solid Waste Disposition

Rayonier Pulp and

Paper, Port Angeles

4.9 4.9 Closed

Weyerhaeuser Pulp

and Paper, Longview

0.13 1.8 1.9 Active Sludge disposed of in

private landfill.

Fort James Pulp and

Paper, Camas

1.9 1.9 Active

Georgia-Pacific Pulp

and Paper, Bellingham

1.7 1.7 Active

Boise Cascade Pulp

and Paper, Wallula

0.76 0.081 0.84 Active Sludge is both composted

and landfilled on site.

Longview Fiber Pulp

and Paper, Longview

0.71 0.71 Active

Kimberly-Clark Pulp

and Paper, Everett

0.40 0.40 Active

Weyerhaeuser Pulp

and Paper, Cosmopolis

0.20 0.20 Active

Simpson Kraft Pulp and

Paper, Tacoma

0.00 0.00 Active

Total 10.7 1.9 12.6
Page 29

Loading Data

Bleached pulp and paper mills are required to treat and test their wastewater prior to

discharge. Since 1991 treated effluent from these mills has been tested for 2,3,7,8-TCDD

and 2,3,7,8-TCDF. Wastewater treatment sludges have been tested for the same two

congeners. Results have been reported to Ecology’s Industrial Section (McCall, 1997).

Because of these testing requirements, data for this source category are relatively

complete. However, the monitoring requires testing for only 2 of the

17 toxic dioxin and furan congeners; calculated TEQ loads probably underestimate

actual TEQ loads.

Table 7 summarizes the dioxin loads determined by averaging all the loads calculated for

each facility.

Most of the data (summarized in Appendix Table A-5) are “self-reported”. In general,

these self-reported data represent conditions at the mills after they were required to

institute dioxin control measures including 1) minimizing the introduction of dioxin

precursors into the pulping and bleaching sequences, and 2) minimizing the use of

elemental chlorine by substitution with chlorine dioxide.

All dioxin loads associated with bleached pulp and paper mills are included in Appendix

Table A-3. These include self-reported data, as well as loads calculated for a limited

number of other effluent tests. These additional tests include data from Ecology

compliance monitoring inspections, as well as several tests conducted at the Rayonier

Mill in Port Angeles between 1990 and 1994. These latter tests were reported in a

summary of information about the mill prepared for Rayonier by Foster Wheeler

Environmental Corporation (1997) as the mill prepared to close.

As noted above, the self-reported data for the bleached pulp and paper mills are restricted

to two congeners: TCDD and TCDF. Because 15 congeners with TEFs were not included

in self-reported data, the TEQ loads associated with these data probably underestimate

full TEQ loads from these sources. As an example, Figure 4 shows the relative

percentages of the full TEQ contributed by the TCDD and TCDF for wastewater and

sludge as calculated using the data (Foster Wheeler, 1997) for the Rayonier mill in Port

Angeles. Similar graphs for air emissions and ash are shown for comparison purposes.
Page 30

Figure 4.

TEQ from 2,3,7,8-TCDD and 2,3,7,8-TCDF

TEQ from all other congeners

Ash

28%

72%

Air

36%

64%

Wastewater

19%

81%

Sludge

9%

91%

Figure 4. TEQ distribution in Rayonier, Inc. wastewater, sludge, air, and ash.

Dispersion

Dioxin loads discharged to water have the potential to be widely dispersed.

One mill (Boise Cascade, Wallula) composts its sludge, and is, on a trial basis, applying it

to an on-site cottonwood plantation (Le, 1998b). A second mill, Weyerhaeuser

(Longview) disposes of its sludge in a privately owned landfill. Other mills burn

wastewater sludges in their hog-fuel boilers. Overall, the potential for the dispersion of

dioxins associated with sludges is variable.

National Rank

EPA (1994), using a different methodology than the one used here, provides estimates

that rank bleached pulp and paper as the fourth largest source category nationally. This

category is likely to be relatively more important in Washington State than nationally,

because pulp and paper bleaching represents a relatively large portion of Washington

State commerce. The EPA assessment could also present a somewhat different picture

than our assessment because:

• EPA included dioxin loads from sludges – with the exception of Boise Cascade

(Wallula) and Weyerhaeuser (Longview) – while Ecology did not.

• EPA included estimates for dioxin loads in pulp and paper products, while Ecology

did not.
Page 31
Page 32

Summary – Bleached Pulp and Paper

Bleached Pulp and Paper

Air Water Land Overall/Total

Data Coverage 9 of 91 2 of 21 100%1

Confirmed Loads

(mg/ TEQ/day) 10.7 1.9 12.6

Dispersion Potential high variable high/variable

Active vs. closed: 1 closed; others active

Estimated national rank: 4th

Importance of obtaining additional data: Medium

Rationale: Of all the source categories addressed in this assessment, wastewater-related

discharges from bleached pulp and paper production have been measured and reported

most often. This is the only facility category with requirements for frequent discharge

monitoring. On the other hand, this monitoring requires testing for only 2 of the

17 dioxin/furan congeners with TEFs. Only a few tests results are available that provide

data for the full range of toxic congeners.

Importance of additional source control: Medium

Rationale: The estimated overall load (12.6 mg TEQ/day) associated with bleached pulp

and paper production is moderate in comparison to other source categories for which data

are available. The mill with the largest average load is no longer operating. Data for this

source category appear to be more complete than for many other categories. Bleached

pulp and paper production rated 4th overall in EPA’s national dioxin source assessment; it

is likely to be relatively more important in Washington State. Actions taken in the early

1990s have decreased dioxin loads from the mills.

The relationship between sludge burning and dioxin destruction/production is not well

quantified.

 

1

 2 out of 17 toxic congeners measured.
Page 33

Cement Kilns

Background

Washington has two presently operating cement kilns: Holnam Cement, Inc. and

Ash Grove Cement Company, both located in Seattle. Cement kilns, which produce

cement from materials including lime, use multiple fuels including coke, used oil, and

tire-derived fuel. The Holnam facility has also conducted several test burns using

“Sterifuel,” a shredded, sterilized medical waste.

The Holnam facility also produces cement kiln dust (CKD), a fine cement-like material

captured by their electrostatic precipitator (an air pollution control device) from the kiln

exhaust. Ash Grove apparently generates no cement kiln dust.

The Lehigh Portland Cement Company (Metaline Falls) operated a coal-fired kiln in

which ceased operation in 1990. A large pile of cement kiln dust was left at this site

(Stoffel, 1998).

Table 8 summarizes loading data, facility status, and solid waste disposition for cement

kilns; these categories are discussed in more detail below.

Table 8. Cement Kiln Dioxin Loads, Facility Status, and Solid Waste Disposition

Cement

Kilns

Load to (mg TEQ/day)

 Air Water Land Total

Facility

Status

Solid Waste Disposition

Holnam Inc.,

Seattle

1.26 0.055 1.31 Active Cement kiln dust is marketed for

agricultural uses, waste stabilization, road building, backfill, etc.

Ash Grove

Cement, Seattle

ND1 Active

Total 1.26 0.06 1.31

Loading Data

Both currently operating cement kilns have tested their stack emissions. Results from

stack tests at Holnam conducted between 1994 and 1996 allowed calculation of six loads

(Appendix Table A-3). The average of these six loads was 1.26 mg TEQ/day. The single

test of air emissions available for the Ash Grove facility (Valid Results, Inc., 1996)

detected no dioxins.

Holnam’s cement kiln dust has been tested three times. The average load from these tests

is 0.055 mg TEQ/day.

 

1

 ND = Not Detected
Page 34

Table 8 summarizes the dioxin loads determined by averaging all the loads for cement

kilns.

Dispersion

Dioxin loads discharged to air can be widely dispersed.

The CKD dioxin load from Holnam is quite small. Since 1987, a majority of Holnam’s

CKD has gone for agricultural use, but construction uses have increased steadily over the

past several years. Currently, about 50% goes for agricultural use. The remainder is used

for a range of other uses: 1) stabilizing sludge-like hazardous wastes, 2) drying and

stabilizing soils, 3) providing a low-grade underlayer for road bed building, and 4)

providing engineered backfill – mixed with wet soils prior to backfilling in mining or

construction (Smith, 1998). The potential for dispersion for CKD is variable.

Approximately 600 tons of CKD was left at the Lehigh site. We have no data regarding

concentrations or loads associated with this facility. Although the storm water has been

diverted from the pile which has also been covered with a clay liner, leachate from

groundwater contact is still migrating offsite (Stoffel, 1998)

National Rank

EPA (1994), using a different methodology than the one used here, provides estimates

that rank cement kilns as the 3rd largest source category nationally (well behind municipal

and medical waste incineration). EPA’s assessment includes kilns that burn hazardous

waste. Neither of the Washington kilns burns hazardous wastes. In both assessments the

loads are associated primarily with air emissions.

Summary – Cement Kilns

Cement Kilns

Air Water Land Overall/Total

Data Coverage 2/3 1/2 50-67%

Confirmed Loads

(mg/ TEQ/day)

1.26 0.06 1.32

Dispersion Potential high variable high/variable
Page 35

Active vs. closed: one facility closed, two active.

Estimated national rank: 3rd

Importance of obtaining additional data: Medium-low

Rationale: Loads from the Holnam facility appear to be well characterized assuming that

there are no major changes in fuels, raw materials or operating parameters at the kiln.

The single test at Ash Grove is probably not adequate. This is the only air emissions test

for a facility assessed in this review that failed to detect even one of the 17 toxic dioxin

and furan congeners. No data are available for CKD at Lehigh; however, based on the

results from Holnam, this may not be a high priority.

Importance of additional source control: Medium-low

Rationale: The estimated overall load (1.32 mg TEQ/day) associated with cement kilns

is fairly low in comparison to other source categories for which data are available.

Cement kilns rated 3rd overall in EPA’s national dioxin source assessment; under current

operating conditions they are likely to be relatively less important in Washington State.

Municipal Wastewater Treatment

Background

Washington has approximately 250 NPDES-permitted municipal treatment plants. These

facilities treat mixtures of domestic, commercial and industrial wastewaters. Wastewater

treatment apparently does not generate dioxins; however, treated wastewaters discharged

from these facilities, as well as associated biosolids (sludges), can contain dioxins passed

along from sources that discharge to the plant.

Table 9 summarizes loading data, facility status, and solid waste disposition for municipal

wastewater treatment plants; these categories are discussed in more detail below.

Table 9. Municipal Wastewater Treatment Loads, Facility Status, and Solid Waste

Disposition

Wastewater Treatment

Plants

Load to (mg TEQ/day)

 Air Water Land Total

Facility

Status

Solid Waste Disposition

Renton Sewage Treatment

Plant, Renton

0.347 0.347 Active Most biosolids land-applied

at several eastern and

western Washington sites.

Loading Data
Page 36

No data were found that could be used to calculate loads associated with treated

wastewater effluent. Biosolids data were available for a single facility. Appendix Table

A-3 includes loading data calculated from two sets of sample results (1987 and 1997) for

biosolids generated by the Renton Wastewater Treatment Plant. The average load

calculated from these measurements was 0.347 mg TEQ/day. Although these data

represent only one of approximately 250 municipal treatment plants, the Renton plant

generates about 15-20% of Washington’s biosolids.

Dispersion

Although we have no data on the magnitude of dioxin loads discharged to water, any such

loads would have the potential to be widely dispersed.

Most biosolids are land-applied. Some facilities give biosolids away to people who use

them on their home gardens (Dorsey, 1997). In 1998, Renton biosolids were used for

silvicultural fertilization (about 62%), agricultural fertilization (about 31%), commercial

compost production (about 7%), and other uses including mine restoration research and

hybrid poplar fertilization (King, 1998). The dispersion potential for sludge is high.

National Rank

EPA (1994), using a different methodology than the one used here, provides estimates

that rank municipal wastewater treatment plants as the 7th largest source category

nationally. This estimate was based entirely on biosolids loads; no wastewater discharge

data were included.

Summary – Municipal Wastewater Treatment Plants

Municipal Wastewater Treatment

Air Water Land Overall/Total

Data Coverage 0/250 1/250 0-0.4%

Confirmed Loads (mg/

TEQ/day)

 0.347 0.347

Dispersion Potential high high high

Active vs. closed: Active

Estimated national rank: 7th

Importance of obtaining additional data: Medium
Page 37

Rationale: Although not expected to be among the major sources of dioxins, loads

associated with municipal wastewater treatment are not well characterized. Data for

biosolids are available for one of approximately 250 facilities; no data are available for

wastewater discharges.

Importance of additional source control: Potentially Medium

Rationale: Additional data are required to assess the magnitude of dioxin loads

associated with municipal wastewater treatment. Based on available information about

the size of dioxin loads, this source category does not appear to rank near the top;

however, the potential for dispersion is high. Because treatment plants do not appear to

generate dioxin, any source control efforts would be targeted at sources to wastewater

treatment plants.

Activated Carbon Regeneration

Background

A single activated carbon regeneration facility, Cameron-Yakima, Inc., operated until

recently in Washington. Cameron-Yakima had ceased all carbon regeneration and waste

processing activities by the end of 1997.

Cameron-Yakima had two combustion units that reprocessed activated carbon using heat

and steam to desorb contaminants. These contaminants included benzene, toluene,

ethylbenzene, xylene, semi-volatile organics, pesticides, and metals (Bison Engineering,

1995).

Loading Data

A single set of air emission tests was conducted on the two treatment units at

Cameron-Yakima in 1994. These tests, required by Ecology, specified a specially

prepared feed material: activated carbon loaded with a known mixture of contaminants

(Bison Engineering, 1995). This feed material represented conditions close to “worst

case” (Warner, 1997). Based on these results (Appendix Table A-3) the total load from

this facility was 37.4 mg TEQ/day, the highest loading rate reported for an individual

facility.
Page 38

Table 10. Activated Carbon Regeneration Loads

Load to (mg TEQ/day)

Air Water Land Total

 Cameron-Yakima, Inc. 37.4 37.4

Total 37.4 37.4

Dispersion

Dioxins loads discharged to air can be widely dispersed.

National Rank

EPA (1994), using a different methodology than the one used here, provides estimates

that place activated carbon regeneration far down the list of source categories that

generate dioxin loads. EPA’s evaluation is probably not directly applicable to

Washington because, while EPA estimated that the total annual amount of granular

activated carbon treated in the US was about 48,000 metric tons (EPA, 1994), CameronYakima treated about 4,500 metric tons annually (Warner, 1997). This represents about

10% of the national production. Thus, while Cameron-Yakima was operating,

Washington State ranked well above the average in this activity. In addition, EPA’s

emission factor was based on only two source tests, while the loading reported for the

single Washington State source is based on a single “moderate worst case” test that may

over-represent emissions from this facility.

Summary – Activated Carbon Regeneration

Activated Carbon Regeneration

Air Water Land Overall/Total

Data Coverage 1/1 100%

Confirmed Loads

(mg/ TEQ/day)

37.4 37.4

Dispersion Potential high high

Active vs. closed: Only source ceased operation in 1997

Estimated national rank: Low

Importance of obtaining additional data: Medium-high (follow-up sampling)
Page 39

Rationale: Because the facility is no longer operating, the need for additional source

assessment monitoring is low. However, because source testing at Cameron-Yakima

yielded the highest dioxin load for a facility documented by this assessment, and because

the potential for this dioxin to be dispersed is high, we rate the need for follow-up

monitoring high. This monitoring should focus on evaluating potential dioxin

contamination downwind of the facility.

Importance of additional source control: Low

Rationale: Cameron-Yakima, Inc. was the only Washington State facility engaging in

this activity. This facility no longer regenerates activated carbon.

Small Miscellaneous Sources with Calculated Loads

For each of three miscellaneous facilities, air emissions loads of less than 0.05 mg TEQ/d

were calculated. These facilities include (1) Kaiser Trentwood Rolling Mill, an

aluminum remelt furnace in Spokane Valley, (2) Kalama Chemical, an industrial boiler in

Kalama, and (3) Conrad Industries, a pyrolysis unit manufacturer in Chehalis. The Kaiser

Trentwood values may be the most significant of the three, since the reported calculated

load represents only one of ten furnaces at this facility. The loads are shown in Appendix

Table A-3.

Other Source Categories

The presence of dioxins has been confirmed but dioxin loads could not be reliably

calculated for several source categories. These are therefore included as Other Source

Categories. For these sources, ratings are given for the importance of obtaining

additional data. No ratings are given for the importance of source reduction or control,

because additional information would be needed to make that determination.

Cleanup Sites

Dioxins may be present at sites regulated under the state Model Toxics Control Act

(MTCA) authority, federal Superfund authority administered by EPA, and sites requiring

RCRA corrective actions and closures. Table 11 summarizes information for these sites.

Of the 38 sites in Table 11, dioxins were detected at 26 sites. Dioxins are suspected at six

additional sites. Included in this table are three where pentachlorophenol (PCP)

contamination is confirmed. PCP is typically contaminated with low levels of dioxins.

Cleanup sites are not routinely tested for dioxins.

Table 11. Cleanup Sites
Page 40

Facility County Status Description Dioxin

Detected

Media Tested

American Crossarm &

Conduit

Lewis Clean Up Complete;

Continued Monitoring

Landfill; PCP Wood Treating Confirmed Surface Water,

Soil, Sediment

Buffalo Don Murphy Rd Pierce Ranked, Awaiting

Clean Up

Chlorinated Phenolic Waste

Storage/Staging

Confirmed Soil

Cameron Yakima, Inc. Yakima Interim Action

Complete; Site Study in

Progress

Activated Carbon

Regeneration/ TSD

Confirmed Air, Soil

Cascade Pole & Lumber

Co Tacoma

Pierce No Further Action PCP Wood Treating PCP Surface Water,

Soil, Groundwater

Cascade Pole

McFarland

Thurston Clean Up in Progress PCP Wood Treating Confirmed Groundwater,

Surface Water,

Soil

Eagle Harbor Kitsap Clean Up in Progress PCP Wood Treating Confirmed Sediment

Eagle Harbor Wyckoff Kitsap Clean Up in Progress PCP Wood Treating Confirmed Soil

East Waterway Snohomish Ranked, Awaiting

Clean Up

Embayment of Puget Sound Suspected Soil, Sediment

Frank Brooks

Manufacturing

Whatcom Ranked, Awaiting

Clean Up

PCP Wood Treating PCP Soil, Groundwater,

Sediment

Hanford Benton Unknown 2,4-D Contaminated Soil

Disposal Site

Confirmed Soil

International Paper

Longview

Cowlitz Clean Up in Progress PCP Wood Treating Suspected Soil, Groundwater

JH Baxter/Port Quendall King Clean Up In Progress Lumber & Wood Products Confirmed Soil

Malarkey Asphalt

Company

King Independent Clean Up

In Progress

Asphalt Felts & Coatings Confirmed Soil

Mount Solo Landfill Cowlitz Clean Up Complete;

De-listed

Weyerhaeuser Landfill Confirmed Groundwater,

Surface Water, Air,

Soil

Oeser Company Whatcom Awaiting Clean Up;

Proposed for EPA

National Priority Listing

PCP Wood Treating Confirmed Soil, Groundwater

Olympic Wood Products Mason Ranked, Awaiting

Clean Up

Saw Mill PCP Soil

Pacific Sound

Resources (formerly

Wyckoff-West Seattle)

King Clean Up In Progress PCP Wood Treating Confirmed Soil, Water,

Sediments,

Groundwater

Pacific Wood Treating Clark Interim Action

Complete; Clean Up in

Progress

PCP Wood Treating Testing

Underway

Soil, Sediment

Port of Anacortes Skagit Awaiting Clean Up Pulp Mill Confirmed Sediment

Port of Seattle Terminal

91 Tank

King Clean Up In Progress;

RCRA Corrective

Action

Former Petroleum Bulk

Terminal; Waste Oil Recycling;

Chemical Reprocessing

Suspected Groundwater,

Surface Water,

Soil, Sediment

Reichhold Chemical

Lone Star

King Ranked, Awaiting

Clean Up

Chemical Manufacturing Suspected Groundwater,

Surface Water,

Soil

Facility County Status Description Dioxin

Detected

Media Tested

Reichhold Chemical Inc. Pierce RCRA Corrective

Action/Post Closure

Chemical Manufacturing Suspected Groundwater, Soil
Page 41

Ross Electric of WA

Coal Creek

Lewis Cleanup In Progress Unclassified Establishment Confirmed Soil

Simpson Pierce Clean Up Complete;

Remediated

Pulp Mill Confirmed Groundwater,

Surface Water, Air,

Soil

Simpson Timber

Company

Mason Clean Up Complete;

Remediated

Pulp Mill Confirmed Groundwater, Soil,

Sediment, Air

Strandly Manning Kitsap/Pierce Clean Up In Progress;

Site Study

Junkyard/Transformer Recycler Confirmed Sediment, Ash

Tacoma Redevelopment

Property

Pierce Remediated Or Clean

Up in Progress

Thea Foss Waterway

Brownfields Redevelopment

Confirmed Groundwater,

Surface Water,

Soil, Sediment

US Army Ft Lewis

Multisite

Pierce Awaiting Clean Up Landfill Confirmed Soil

US BPA Ross OUA Clark Clean Up Complete;

De-listed

Electric Power Generation PCP Soil

US Navy Station Everett Snohomish Independent Clean Up

In Progress

Jetty in Port Gardner Bay,

Old WWII Navy Base

Suspected Groundwater, Soil,

Sediment

US Navy Sub-base Kitsap Clean Up In Progress HW Disposal Site Confirmed Soil

US Navy Sub-base OU3 Kitsap Clean Up Complete;

Continued Monitoring

HW Disposal Site Confirmed Soil

US Navy Whidbey OU2

(Ault Field)

Island Clean Up In Progress HW Disposal Site Confirmed Groundwater, Soil

US Navy Whidbey OU3 Island Clean Up In Progress HW Disposal Site Confirmed Groundwater, Soil,

Sediment

USACE Manchester

Annex

Kitsap Clean Up In Progress Landfill Confirmed Soil, Sediment

Weyerhaeuser-Everett Snohomish Unknown Bleach Plant Site Confirmed Water, Surface

Runoff

Weyerhaeuser-Everett Snohomish Unknown Sludge Ponds Confirmed Sludge

Weyerhaeuser-Everett

East

Snohomish Clean Up Complete Saw Mill Undetected Soil

Both on-going and closed sites are included in this table.

Sediments are also a consideration at many clean-up sites. Sediments accumulate in

retention ponds and may be potential sources of dioxins. They may be particularly

mobile during cleanup, remediation actions, or adjacent dredging operations. The

Ecology Sediments Management Unit maintains a database of contaminated sediments,

including those contaminated with dioxins.

No estimates of dioxin loading could be calculated for these sites. Once they are cleaned

up or stabilized, the chance of continuing off-site contamination is minimized.

The importance of obtaining additional data for these sites is variable, depending on the

nature of the site. For sites with likely dioxin contamination and the potential for dioxin

to be transported off-site, the importance is high. For sites with little potential for dioxin,

or those fully remediated, the importance is low.
Page 42

Wood Treating Facilities

Table 12 lists information for four active and five closed wood treating facilities that

treat(ed) wood with pentachlorophenol (PCP). PCP generally contains measurable

concentrations of various dioxins.

Table 12. Wood Treating Facilities

Facility County Facility

Status

Cleanup

Site

Stormwater Runoff

Receiving Body

American Crossarm & Conduit Lewis Closed EPA Dillenbaugh Creek

Cascade Pole Company Pierce Active MTCA Blair Waterway

Cascade Pole Company Thurston Closed MTCA Budd Inlet

Eagle Harbor-Wykcoff Kitsap Closed MTCA Eagle Harbor

Frank Brooks Manufacturing Whatcom Active MTCA Whatcom Creek

International Paper Cowlitz Closed MTCA Area ditches, Groundwater,

Columbia River

JH Baxter Snohomish Active MTCA Groundwater

Oeser Company Whatcom Active EPA Little Squalicum Creek

Pacific Wood Treating Clark Closed MTCA Lake River

All of the facilities are, or have been, EPA Superfund cleanup sites or sites regulated

under the Model Toxics Control Act (MTCA) and are also listed in Table 11. Dioxin

contamination is confirmed at many of these sites; the source most likely is PCP.

The four active facilities have NPDES permits regulating stormwater discharge to surface

or ground waters. Their existing permits call for dioxin analyses of their stormwater

runoff; however, only the J.H. Baxter facility has started this monitoring. This facility

discharges to groundwater via stormwater detention ponds. Stormwater runoff was

sampled for dioxin and PCP at four drain sites during two rainfall events. The dioxin

TEQ concentrations measured in the stormwater averaged 5,340 pg/L for the two rainfall

events (Martin, 1998). If this represents average stormwater conditions, the average

annual load would be 0.92 mg TEQ/day (based on inches of rain during the monitored

event and average annual rainfall). Because of the highly variable nature of stormwater

runoff, these loads were not considered to be directly comparable to the confirmed loads

presented in earlier sections.

The importance of obtaining additional data for wood treating facilities is high, based on

the high concentrations measured at the one facility with dioxin data. The dispersion

potential for these facilities is high.

Oil Refineries
Page 43

Catalytic reformer wastewater effluent may contain dioxins that are formed during

regeneration of the reformer catalyst. Different types of reformers are regenerated at

different time intervals. Some are regenerated infrequently (every 12 to 18 months) while

other types are regenerated more frequently. In some cases reformer regeneration

wastewater is produced daily.

Five refineries in Washington State have the potential to generate dioxin from their

catalytic reformers. System wash waters were tested for dioxins at three refineries (Table

13). 2,3,7,8-TCDD and 2,3,7,8-TCDF were found at relatively high concentrations (225

pg/L and 5100 pg/L, mean of duplicates, respectively) in one-third of the samples

collected at the Texaco Refinery. At ARCO, only 2,3,7,8-TCDD and 2,3,7,8-TCDF were

analyzed; neither was detected. At U.S. Oil, all 17 toxic congeners were analyzed for;

none were detected. Total TCDF’s and HxCDF’s were found at low concentrations.

It is not possible to calculate a dioxin load for these facilities, because flow rates of wash

water are unknown. However, the wash water flows are estimated to be very small, so

the loads associated with these facilities would be small and in some cases infrequently

generated.

Limited data are available for several of Washington’s refineries as mentioned above.

More data will be collected as a result of requirements to be included in the refinery

NPDES permits when they are renewed. The planned dioxin sample points include

regeneration wastewater and refinery wastewater plant sludges where the dioxin is

expected to concentrate. Flow rates will also be recorded so dioxin loads can be

calculated. The available Washington State refinery data and national data (EPA, 1996b)

indicate that oil refineries are not a significant source of dioxin. The data collected as

part of the NPDES requirements should provide additional information on the

Washington State refineries.

Because few data are available for dioxins in Washington state oil refineries, the

importance of obtaining additional data is considered to be medium. Additional data will

enable Ecology to better evaluate the significance of dioxin loads from refineries.
Page 44

Table 13. Oil Refineries

Facility County Facility

Status

Media Tested

Texaco Skagit Active Refinery catalytic reformer caustic wash

wastewaters (Texaco, 1990)

ARCO Whatcom Active Refinery catalytic reformer wastewaters

(Lynch, 1990)

US Oil & Refining Pierce Active Refinery catalytic reformer wastewaters

(Riley, 1990)

Shell Anacortes Skagit Active Not tested

TOSCO Refining Whatcom Active Not tested

Potential Source Categories

For these categories, we found no dioxin data. However, because of the types of

processes and presence of chlorine/chloride, carbon, heat and/or combustion, they are

potential dioxin source categories.

Structure Fires

Dioxins are potentially produced by structure fires. Although any structure fire could

produce dioxins, fires involving the following are probably the most likely to produce

significant amounts of dioxins: polyvinyl chloride (PVC) materials, chlorinated organic

chemicals, or transformers and other electrical equipment containing PCBs. Other

structures that might produce larger amounts of dioxins when burned include woodtreating facilities, any facility storing PCP, and PCP-preserved wood structures.

No data or information on dioxins produced in structure fires in Washington State were

found.

Illegal Burning of Prohibited Materials

The illegal burning of prohibited materials such as PCBs, PVCs, pesticide containers and

PCP-treated wood probably generates dioxins. We found no information on this category

for Washington.
Page 45

Metal Smelting and Refining

EPA’s draft Dioxin Reassessment (EPA, 1994a) identifies the following industry types as

potentially producing dioxins:

• Primary nonferrous metal smelting/refining (aluminum, copper, lead)

• Secondary nonferrous metal smelting/refining (aluminum, copper, lead)

• Drum and barrel reclamation and incineration

• Scrap electric wire recovery

We did not find any dioxin data associated with these industries in Washington State.

In a separate study, Ecology tested several fertilizers and soil amendments for dioxins.

Ecology found that several had high concentrations of dioxins, particularly those

fertilizers made from electric arc furnace dust from steel mills (K061 wastes).

Previously, K061 wastes had not been analyzed for dioxins. (Ecology also tested

materials made from cement kiln dust and hog-fuel boiler fly ash; these data are included

in the section dealing with Confirmed Sources.)

The steel foundry dust imported by Bay Zinc, Inc. to make fertilizer had a dioxin load

calculated at 11.6 mg TEQ/d, higher than loads associated with Holnam Cement kiln dust

and Ft. James fly ash, both of which are also used as fertilizers or soil amendments. The

imported steel foundry dust load is not discussed in the Confirmed Sources section of this

report because the original source of dioxin was not within Washington State.

This fertilizer study showed that steel foundry dust (K061 waste) is likely to be

contaminated with dioxins. Table 14 lists Washington State generators of K061 waste

and shows current disposal locations.

Table 14. Sources and Disposition of Steel Foundry Dust (KO61)

Facility County Facility

Description

RCRA K061

Waste

Disposition

Seattle Port of

Kent Site

King Primary Metal

Products; Former

Jorgensen site

K061 (1993, onetime, non-recurrent

electric arc dust)

Sent to Arlington, OR Subtitle C Hazardous

Waste Landfill. They are investigating the

SuperDetox process (Reuter, 1998)

Birmingham

Steel Corp

Seattle

Division

King Blast Furnaces &

Steel Mills

K061 (from APCD) Sent to EnviroSource in Idaho; SuperDetox

process renders cement-like solid waste that

is landfilled in Subtitle D Solid Waste

Landfill (Reuter, 1998)

Jorgensen

Forge Corp

King Iron & Steel

Metal Forgings

K061 (from APCD) Sent to Arlington, OR Subtitle C Hazardous

Waste Landfill. They are investigating the

SuperDetox process (Reuter, 1998)
Page 46

Ecology will be conducting additional investigations into dioxin levels of dioxins in

fertilizers and soil amendments, including waste-derived products that may contain K061.

Additional Potential Sources

We did not locate any information for many small, potential sources of dioxin production.

Tire combustion, spills responded to by Ecology and sewage sludge incineration were

investigated as potential dioxin sources, but no data were found. Other potential sources

identified in EPA’s 1994 Dioxin Reassessment include:

• Charcoal briquette combustion (residential)

• Coal combustion (residential, industrial, utility)

• Kraft black liquor boilers

• Motor vehicle fuel combustion (diesel, leaded, unleaded)

• Oil combustion (residential, industrial)

• Organic chemical manufacture

• PCB combustion (transformers, office buildings)

• PCP treated surfaces

• Pyrolysis of brominated flame retardants

• Sewage sludge incineration

• Tire combustion

• Wood burning (residences, forest fires)
Page 47
Page 48

Conclusions and Recommendations

The conclusions and recommendations reached during this study derive, in large part,

from the importance assigned to additional data collection and source control for each of

the confirmed source categories. Tables 15a and 15b summarize the information that led

to these importance ratings.

The Washington State Dioxin Source Assessment leads to five general conclusions and

associated recommendations.

Conclusion 1

Dioxin source data are incomplete.

Washington’s dioxin source data are sparse. The data summarized in this report vary in

quality and completeness. Although these data provide a useful perspective, they are not

comprehensive. The absence of comprehensive source data is not surprising, given the

lack of comprehensive requirements for dioxin source monitoring.

Recommendation

Fill priority data gaps.

Recommendations to fill data gaps are listed below in priority order. These priorities are

based, in large part, on the importance ratings provided in Tables 15a and 15b.

1. Improve the quantity and quality of data available on dioxin loads in air emissions

and fly ash generated by hog-fuel boilers. Factors to consider in setting priorities for

data collection include:

• Whether facilities are burning salty hog fuel, sludge, or other materials containing

chloride or chlorine.

• The size and throughput of the facilities.

2. Improve the completeness of dioxin load data for incinerators.

• Obtain adequate fly ash data for incinerators where these data are sparse or absent.

• Obtain adequate air emissions data for medical waste incinerators.

Implementation of EPA’s new use performance standards for new medical waste

incinerators and emissions guidelines for existing medical waste incinerators will

address these data needs.
Table 15a. Evaluation of the “Importance” of Confirmed Source Categories1

Facility O

Source Cate

gor

y Data Covera

g

e

Confirmed Loads

(m

g/day, estimated)

Status

Summar

y

National

Rank Dis

persion Potential

A

Air Water Land Air Water Land2 Total Air Water Land2

Incinerators 7/22 0/1 3/22 8.8 - 33.1 41.9 largely

active

1st high - generally

low

Hog-Fuel Boilers 2/84 - 3/84 0.3 - 22.8 23.0 1 closed,

83 active

5th high - variable 

Bleached Pulpand Paper

 - 9/9 2/2 - 10.7 1.9 12.6 active 4th - high variable M

Cement Kilns 2/3 - 1/2 1.3 - 0.1 1.4 1 closed,

2 active

3rd high - medium M

Activated CarbonRegeneration

1/1 - - 37.4 - - 37.4 closed low high - - M

Municipal WastewaterTreatment

 - 0/250 1/250 - - 0.3 0.3 active 7th - high high M

1 The development of “importance ratings” and the information contained in this table are discussed in the Results and Discussion chapt2 Loads to land incorporate a range of practices including land application and disposal in landfills. The potential for dispersion associat

addressed in the body of this report

3 Importance of fly ash sequestering – HighTable 15b. Evaluation of the “Importance” of Other Source Categories

Source Category Importance of Additional

Data Collection

Wood Treaters HighCleanup Sites VariableOil Refineries Medium
Page 49

3. When the NPDES permits for the bleached pulp and paper production facilities are

renewed include, as a minimum, requirements to report data on the full range of

dioxin/furan congeners in effluent.

4. Require dioxin and furan testing from all wood-treating facilities currently using

pentachlorophenol.

5. Test steel foundry dust for dioxins.

6. Because dioxins are preferentially associated with solids rather than water, increase

testing of municipal wastewater treatment biosolids for dioxins. This increased

testing should be prioritized based on known or likely industrial sources of dioxins to

the municipal wastewater facility, as well as the volume and final disposition of

biosolids generated by the facility. Based on the results of this testing, re-evaluate

biosolids management practices and initiate testing of wastewater effluents, as

necessary.

7. Most bleached pulp and paper mills burn sludges generated by the treatment of their

wastewaters. Determining whether this process produces or destroys dioxins is an

important step in effectively managing these sludges.

8. This project only addresses sources of dioxin originating within Washington State.

Further evaluation of out-of-state sources that may contribute loads to Washington is

recommended. These include industrial sources discharging to shared watersheds and

airsheds, as well as imported products including fertilizers and soil amendments.

Fertilizer testing authorized by 1998 legislation (SSB 6474) should assist in this

effort.

9. To completely assess the role of cement kilns in dioxin production, additional air

emissions tests at the Ash Grove kiln would be necessary.

10. Where there is a likely potential for dioxin to be present at MTCA, Superfund and

RCRA cleanup sites, the site should be tested for dioxins. This includes sites with

residues from the incineration of PCBs or other chlorinated organics, sites (such as

wood-treating sites) that have a history of pentachlorophenol use, and sites where

2,4,5-T is present at significant concentrations.

Conclusion 2

Two of the facilities with some of the highest estimated loads ceased

operations in 1997.

The Rayonier bleached pulp mill (Port Angeles) and the Cameron-Yakima activated

carbon regeneration facility (Yakima) ceased operation in 1997. When in operation, these
Page 50

facilities had among the highest overall dioxin loads estimated during this assessment.

Both sites are in the initial phases of site characterization for cleanup.

Recommendations

1. Conduct follow-up environmental monitoring for dioxins downwind of the

Cameron-Yakima facility.

2. EPA is engaged in a large monitoring effort near the Rayonier, Port Angeles, site.

Substantial data on dioxin concentrations in soil and sediment will be available in

summer 1998. These data should provide a sound basis for future steps.

Conclusion 3

The importance of further source reduction/control was rated high for

incinerators and hog-fuel boilers.

Recommendations

We suggest Ecology take the following initial actions to reduce the magnitude and

dispersion of these loads:

Incinerators

1. Continue steps to adopt regulations that incorporate (a) federal air emissions

performance standards for new medical waste incinerators, and (b) emissions

guidelines for existing medical waste incinerators.

2. Pursue opportunities for waste reduction and recycling, thereby limiting the amount of

waste disposed of through incineration.

Hog-fuel Boilers

3. Ecology is developing Reasonably Achievable Control Technology (RACT) for hogfuel boilers. The production and release of dioxins by these boilers will be considered

as RACT is defined. One goal of RACT analysis and implementation will be to

reduce the dispersion and overall production of dioxins from these boilers.
Page 51

General

4. Determine if solid and dangerous waste designations adequately capture dioxincontaining wastes including fly ash generated by hog-fuel boilers, municipal waste

incinerators and medical waste incinerators. Expand testing to fill data gaps and

assure that appropriate sequestration of these wastes continues.

Conclusion 4

Compiling existing environmental data would provide critical

supplemental information.

This project, through compilation of existing data, provides a useful beginning in

evaluating dioxin sources. During this project we identified a number of references

containing environmental dioxin data. Compiling existing data on dioxin concentrations

in Washington’s environment and filling the data gaps revealed by this compilation

would:

1. Increase our knowledge of dioxin sources. Additional environmental data are likely

to identify dioxin “hot spots” and presently unrecognized sources.

2. Give context to environmental dioxin data. Washington’s background dioxin

concentrations are unknown. Site assessments for dioxin are difficult to perform

without knowing an area’s background dioxin levels.

3. Represent a logical progression, expanding our knowledge from sources to the

ambient environment as displayed by the Dioxin Source and Fate Conceptual Model

(Figure 2, page 5).

Recommendations

1. Compile existing environmental data to address dioxin concentrations in

Washington’s environment. This project should emphasize compilation of data

on:

• Freshwater and marine sediments

• Soils (including data being generated under 1998 SSB 6474)

• Freshwater and marine fish and shellfish

2. Based on the results of this compilation, design the scope-of-work to fill critical gaps

in ambient data. Such a study should consider use of fish and/or wildlife tissue

analysis. Animal indicators provide integration of cross-media spatial and temporal

dioxin exposures.
Page 52

3. Identify key environmental indicators (e.g., concentrations in the tissue of selected

birds, fish or mammals, and concentrations in sediment cores) based on

environmental monitoring results that are consistent with the dioxin source and fate

conceptual model. Tracking these indicators over time will show whether or not

actions taken to reduce the release of dioxins to the environment are effective.

Conclusion 5

This report represents a major first step in developing a strategy for

managing bioaccumulative, persistent, and toxic compounds.

The process of looking at dioxin sources across media, organizational, and regulatory

boundaries was successful in providing a snapshot view of dioxin releases to the

environment, to the extent existing information allows.

Recommendation

1. Ecology, under the direction of Ecology’s Bioaccumulative Chemicals of Concern

Committee and in cooperation with other agencies, should continue to invest in

projects that further our understanding of bioaccumulative, persistent, and toxic

compounds in Washington State.

2. This report is an early step in a strategy to reduce production and dissemination of

dioxins. Subsequent steps could include the virtual elimination of man-made sources

and the dispersion of dioxin. Information generated by this effort should inform the

development of subsequent strategies to effectively manage and eliminate other

bioaccumulative, persistent, and toxic compounds.
Page 53

Glossary

Air Pollution Control Device (APCD) – In this report, a device that collects particulate

matter from an air emission before it is released to the environment. Examples include

electrostatic precipitators (ESPs), cyclones, multi-cyclones, wet scrubbers, and

baghouses.

Bottom Ash – Ash too heavy to be carried up the stack by flue gas; sometimes referred to

as “grate ash”; may be mixed with grate siftings.

Confirmed Source – A facility or process for which a dioxin load was calculated.

Congener – A series of compounds with the same base structure but varying degrees of

substituted functional groups.

Dioxin – In this report, “dioxin” refers to all toxic (2,3,7,8-chlorine-substituted) forms of

the dioxins and furans.

Fly Ash – Ash too light to fall out as grate or bottom ash; therefore, ash emitted from the

source. Also, ash collected by air pollution control devices rather than being emitted

from the stack in the flue gas.

Load – The rate at which dioxins are generated or emitted by a source. Calculated from

test data measuring release to air, water, and land. Expressed as mg TEQ/day.

Mixed Ash – A mixture of fly ash and grate and/or bottom ash.

Potential Source – Facilities with same or similar processes as confirmed sources but for

which no dioxin load could be calculated.

Toxicity Equivalency Factor (TEF) – A measure of the potency of one congener relative

to that of 2,3,7,8-TCDD. The congener’s concentration is multiplied by the toxicity

equivalency factor to obtain the toxic equivalents for that sample.

Toxic Equivalents (TEQ) – The equivalent toxicity relative to 2,3,7,8-TCDD for each of

the 2,3,7,8-chlorine-substituted dioxin and furan congeners. Also refers to the total

equivalent toxicity if a compound contains more than one congener.
Page 54
Page 55

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Hansen, K.A., K.S. Mackey, and A.F. Blaisdell, 1995. Holnam Inc. Main Cement Kiln

Stack, Seattle Washington July 24-28, 1995. Emissions Test, Amtest Air Quality, Inc.

Hansen, K.A., K.P. Orton, and A.F. Blaisdell, 1990. Tacoma City Light Steam Plant

No. 2 Repowering Project Main Stack Outlet -- Tacoma, Washington. September 10-12

and 15, October 8-9, 1990. Emissions Test, Amtest Air Quality, Inc.

Hansen, K.A., K.P. Orton, and A.F. Blaisdell, 1995. Northwest Hospital Medical Waste

Incinerator Baghouse Stack -- Seattle, Washington. January 18-20, 1995. Emissions

Test, Amtest Air Quality, Inc.

Holloway, M., 1990. A Great Poison. Scientific American, November.

International Technology Corporation, 1996. Trial Burn Report -- U-3 Boiler.

Source Test/Trial Burn, IT Project No. 767617.

Johnson, A., and M. Heffner, 1992. Class II Inspection of the Boise Cascade Pulp &

Paper Mill, Wallula, Washington - April 1992. Washington State Department of

Ecology, Olympia, WA.
Page 59

Johnson, A., D. Serdar, and S. Magoon, 1991. Polychlorinated Dioxins and -Furans in

Lake Roosevelt (Columbia River) Sportfish, 1990. Washington State Department of

Ecology, Olympia, WA. Pub. No. 91-4.

Jones, B., 1989. Memorandum to Andy Brastad, Clallam Co. Re: Operations Permit for

Shotwell Woodwaste Site, from Brian Jones, Rayonier, Port Angeles, WA.

May 24.

King, R., 1998. Letter to Bill Yake. Biosolids Project, King County Wastewater

Treatment Division. February 27.

Le, T., 1998a. Personal communication. Washington State Department of Ecology,

Olympia, WA. February 23.

Le, T., 1998b. Personal communication. Washington State Department of Ecology,

Olympia, WA. January 16.

Luthe, C., and V. Uloth, 1996. Controlling dioxin emissions in coastal power boilers: A

status report. Pulp & Paper Canada. 97:9. pp. 76-82.

Luthe, C., and S. Prahaes, 1996. Dioxins from pulp mill combustion processes:

implications and control. Pulp & Paper Canada. 94:8. pp. 37-46.

Lynch, B., 1990. Letter and attachments from Arco to K. Anderson. Washington State

Department of Ecology. July 9.

Magoon, S., 1997. Fertilizer Study, Data Review. Washington State Department of

Ecology, Olympia, WA.

Marty M.A., and D.J. Shusterman, 1992. Toxic hazards of the pulp and paper industry.

In: Sullivan J.B. and G.R.Krieger (eds.): Hazardous Materials Toxicology: Clinical

Principles of Environmental Health. Baltimore, Williams & Wilkins.

pp. 605-616.

Matthews, C., 1998. Personal communication. Washington State Department of

Ecology, Olympia, WA.

McCall, M., 1997. Memorandum to Bill Yake. Dioxin Data for Pulp and Paper Mills.

Washington State Department of Ecology, Olympia, WA. 1 p. + attachments.

McEntee, D., 1997. Personal communication. Simpson Tacoma Kraft.

Mehrle, P.M., D.R. Buckler, E.E. Little, L.M. Smith, J.D. Petty, P.H. Peterman, D.L.

Stalling, G.M. Degraeve, J.J. Coyle, and W.J. Adams, 1988. Toxicity and

Bioconcentration of 2,3,7,8-tetrachlorodibenzo-p-dioxin and 2,3,7,8-

tetrachlorodibenzofuran in Rainbow Trout. Environ. Toxicol. Chem., 7:47-62.
Page 60

Naismith, A., 1997. Personal communication to Bill Yake. Northwest Air Pollution

Control Agency. April 29.

Naismith, A., 1998. Personal communication. Northwest Air Pollution Control Agency.

March 10.

Pence, R.J., 1992. Emissions Test Results from the 1992 Annual Compliance Tests at the

Spokane Waste to Energy Facility. Report 50100/R138A083.

Perlwitz, P., 1997. Rayonier Inc., Memorandum to Bill Yake re. Response to your

October 15, 1997 letter. November 4.

Phillips, M., 1997. Personal communication to Stacie Singleton. Northwest Air

Pollution Control Agency. July 24.

Rappe, C., 1984. Analysis of polychlorinated dioxins and furans. Environ. Sci. &

Technol. Vol. 18 (3):78A-90A.

Recomp of Washington, 1995. Annual Report for 1994.

Recomp of Washington, 1996. Annual Report for 1995. HazWaste Application.

Recomp of Washington, 1997. Annual Report for Year 1996.

Redman, E.W., 1993. Data transmittal letter to Brian Jones (Rayonier Inc.).

Riley, D.T., 1990. Letter and attachments from U.S. Oil and Refinery to R.A. Burkhalter,

Washington State Department of Ecology. February 19.

Smith, B, 1996. Personal communication to Bill Yake. Cement kiln dust sampling at

Holnam Inc. Washington State Department of Ecology, Bellevue, WA

Smith, B, 1998. Personal communication. Washington State Department of Ecology,

Bellevue, WA. January 20.

Stasch, P., 1996. Longview Fiber Company Class II Inspection, November 2-3, 1993.

Washington State Department of Ecology, Olympia, WA. Pub. No. 94-160.

Stoffel, K., 1998. Personal communication. Washington State Department of Ecology,

Spokane, WA. May 6.

Texaco Inc., Puget Sound Plant, 1990. Dioxin and Furan Study. 5 pp. + attachments.

Anacortes, WA.

Trohimovich, J., 1998. Personal communication. King County Public Health

Department. March 29.
Page 61

U.S. Oil & Refining Company, 1991. Results of Dioxin and Furan Monitoring.

1 p. + attachments. Tacoma, WA.

Valid Results, Inc., 1996. Air Emissions Sources Test, Cement Kiln - Initial Tire Burn.

Warner, M., 1997. Personal communication to Bill Yake. Hazardous Waste and Toxics

Reduction Program, Washington State Department of Ecology. September 18.

Weston (Roy F. Weston, Inc.), 1997. Nos. 1, 2, and 3 Incinerators, Compliance Test

Report, Ft. Lewis Incinerator Modification Project. July.

Weyerhaeuser Environmental Sciences and Technology, 1991. An Investigation of the

Environmental Consequences of the Combustion of Bleached Kraft Wastewater

Treatment Solids (WTS) in Longview Combination Fired Power Boiler No. 11.

7 pp. + appendices.

Wild, S.R., S.J. Harrod, and K.C. Jones, 1994. Influence of sewage sludge applications

to agricultural land on human exposure to polychlorinated dibenzo-p-dioxins (PCDDs)

and –furans (PCDFs). Environmental Pollution, 83:357-369.

Zinner, L., 1998. Personal communication. Washington State Department of Ecology,

Bellevue, WA. March 3.
Appendices
Appendix A

Supplemental Tables
Table A-1. Example calculations of dioxin TEQ and load.

Facility XYZ Facility

Sample Name Ash Analysis

Lab A-1 Analytical Services

Sample Number

Date

123456

1/1/94

Value

(ng/kg) Qual.

TEQ (ng/kg)

<Detection Limit = *

Congener TEF 0 1/2DL DL

TCDD 16.2

2,3,7,8-TCDD 1 2.1 U 0 2.1

PCDD 7.31

1,2,3,7,8-PCDD 0.5 5.4 U 0 2.7

HxCDD 84.9

1,2,3,4,7,8-HxCDD 0.1 5.68 0.568 0.568

1,2,3,6,7,8-HxCDD 0.1 7.24 0.724 0.724

1,2,3,7,8,9-HxCDD 0.1 12.3 1.23 1.23

HpCDD 184

1,2,3,4,6,7,8-HpCDD 0.01 94.4 0.944 0.944

OCDD 0.001 551 0.551 0.551

TCDF 223

2,3,7,8-TCDF 0.1 30.6 3.06 3.06

PCDF 120

1,2,3,7,8-PCDF 0.05 8.53 0.4265 0.4265

2,3,4,7,8-PCDF 0.5 12.7 6.35 6.35

HxCDF 128

1,2,3,4,7,8-HxCDF 0.1 34.6 3.46 3.46

1,2,3,6,7,8-HxCDF 0.1 13.7 1.37 1.37

2,3,4,6,7,8-HxCDF 0.1 25.5 2.55 2.55

1,2,3,7,8,9-HxCDF 0.1 1.9 U 0 0.19

HpCDF 218

1,2,3,4,6,7,8-HpCDF 0.01 160 1.6 1.6

1,2,3,4,7,8,9-HpCDF 0.01 13.6 0.136 0.136

OCDF 0.001 118 0.118 0.118

EPA TEQ 23.09 28.08

Waste Production Rate (tons/year 8,762 8,762

TEQ load (mg/day) 0.503 0.557 0.611

U = Less than detection limit

* = 0: if congener not detected, concentration assumed = 0

1⁄2 DL: if congener not detected, concentration assumed = 1⁄2 detection limit

DL : if congener not detected, concentration assumed = detection limit
Table A-2. Comparative 2,3,7,8 – TCDD Levels Established for

Human Health Protection.

Concentration Criteria or Criterion Comments

0.000000013 ug/L (ppb) USEPA National Toxics Rule (1992) Criterion protecting humans

consuming water & organisms

0.000000014 ug/L (ppb) USEPA National Toxics Rule (1992) Criterion protecting humans

consuming organisms only

0.0000006 ug/L (ppb) Chapter 173-300 WAC Water Quality

Standards for Ground Waters of the State

of Washington (1990)

Carcinogen criterion

1.00 ng/kg (pptr) US Food & Drug Administration (1997) “Level of Concern” for edible

tissue of chicken eggs & catfish

sold for use in human food.

6.671 ng/kg (pptr) Washington State Model Toxics Control

Act (MTCA) Cleanup Levels and Risk

Calculations (CLARC II) Update (1996)

Method B Residential Soil

Standard

USEPA. 1992. National Toxics Rule. U.S. Environmental Protection Agency, Federal

Register Volume 57, No. 246, December 22, 1992.

US Food & Drug Administration (FDA). 1997. FDA/CFSAN Letter to Egg Producers

and Catfish Farmers and Processors. July 8, 1997. Subject: Dioxin Contaminated

Animal Feed. Available on the world wide web at: http://www.fda.gov/

Washington State Department of Ecology. 1996. Model Toxics Control Act Cleanup

Levels and Risk Calculations (CLARC II) Update. Publication #94-145, Updated 1996.

Washington State. 1990. Chapter 173-200 Washington Administrative Code (WAC).

1990. Water Quality Standards for Ground Water of the State of Washington. 8 pgs.

 

1

 Expressed as TEQ
1

211
1

112 1
1

1

12
Table A-4. State and Federal Laws Authorizing Data Collection

Regulatory Authority

Ecology’s authority to require dioxin and furan testing is limited; this results in limited

loading data being available for Washington facilities. This table summarizes

Washington and federal regulations authorizing or requiring dioxin data collection.

Air Sources (General)

New Sources

Chapter 173-400 WAC, General Regulations for Air Pollution Sources

Provides mechanisms for requiring dioxin testing under Section 110 (New source

review) which can lead to the inclusion of dioxin monitoring requirements in the

facility’s Notice of Construction.

Existing Sources

Chapter 173-434-210 WAC, Solid Waste Incinerator Facilities

Chapter 173-405-091 WAC, Kraft Pulping Mills

Chapter 173-410-100 WAC, Sulfite Pulping Mills

These regulations allow Ecology to require “special studies relevant to process

emissions.” Chapter 173-434-210 WAC states “These special studies may include

the requirement to conduct studies of dioxin emission and control measures.”

Municipal Waste Incinerators

Ash

Chapter 173-306 WAC, Special Incinerator Ash Management Standards

Requires collection and analysis of bottom and fly ash from municipal waste

incinerators burning over 12 tons of municipal waste per day. This requirement only

applies to ash that designates as a “state only dangerous waste” and is specified in

WAC 173-306-200(4)(f).

Wastewater Dischargers

Wastewater

Chapter 173-220 WAC, National Pollutant Discharge Elimination System Permit

Program
Allows Ecology to require monitoring including “pollutants which are subject to

reduction or elimination under the terms...of the permit” [Section 210(1)(a)(ii)],

and “pollutants which the department finds could have a significant impact on

surface waters” [Section 210(1)(a)(iii)].

Chapter 173-216 WAC, State Waste Discharge Permit Program

Requires permits to “specify conditions necessary to prevent and control waste

discharges to waters in the state, including...any conditions necessary to meet

applicable water quality standards for surface waters or to preserve or protect

beneficial uses for ground waters” [Section 110(1)(d)] and “any appropriate

monitoring, reporting and record keeping requirements as specified by the

department...” [Section 110(1)(g)].

________________________________________________________________________

Generally, regulatory authority is media-specific. The authority and regulations applied

to one medium do not usually apply to other media. The authority to require or authorize

dioxin testing is often not explicit, but must be interpreted from the regulations, leading

to inconsistencies in the way data are generated. There is no cross-media authority

(e.g., a regulation that applies to persistent, bioaccumulative, toxic pollutants across all

environmental media) that facilitates collection of comprehensive, consistent data from

known or potential sources.
Table A-5. Low, average, and high dioxin loads for bleach pulp and

paper mill facilities, period of record (2,3,7,8-TCDD and 2,3,7,8-TCDF

only). Loads in mg TEQ/day.

Facility # of

Samples

Low

(mg/day)

Average

(mg/day)

High

(mg/day)

James River, Camas - "ASB Effluent" 16 0.00 1.85 23.50

Georgia Pacific - "Effluent" 24 0.62 1.71 4.37

Boise Cascade, Wallula - Secondary and Final Effluent 25 0.00 0.78 3.78

Longview Fibre, Longview - "Final Mill Effluent" 14 0.00 0.76 3.59

Kimberly Clark - Sum of 3 outfalls 11 0.00 0.40 3.34

Weyerhaeuser, Cosmopolis - "Pond D Effluent" 14 0.06 0.21 0.41

Weyerhaeuser, Longview - "Secondary Effluent" 21 0.00 0.13 0.35

Rayonier, Port Angeles - "Final Effluent" 20 0.00 0.10 1.05

Simpson Tacoma Kraft, Tacoma - "Secondary Effluent" 16 0.00 0.00 0.00
Appendix B

Methods
Methods

Data Gathering Strategies

Several strategies were used to gather dioxin data as well as names of organizations and

facilities potentially having dioxin data. To locate data and potential sources within

Ecology, contacts in each program were established. Data files and databases were

searched for both dioxin data and facilities with the potential for dioxin data. These

resources included:

• Air Quality Program (AQP) list of potential hospital/medical waste incinerators

• AQP wood waste boiler survey data

• Environmental Investigations and Laboratory Services (EILS) report bibliography

• Hazardous Waste and Toxics Reduction Program (HWTRP) petition and certificate of

designation files

• Sediment Section database

• Toxics Cleanup Program (TCP) Facility Site Database

• Water Quality Program (WQP) Wastewater Permit Life Cycle System (WPLCS)

database of Daily Monitoring Reports (DMRs)

• Solid Waste and Financial Assistance Program (SWFAP) Municipal Incinerator

Annual Reports and ash data.

Ecology’s Manchester Laboratory database was searched for contracted dioxin analyses.

HWTRP also held a discussion about dioxins and asked attendees for their knowledge of

such data or sources.

The Washington State Department of Health was contacted for lists of hospitals and

veterinary clinics. Regional air pollution control authorities and USEPA were contacted

for dioxin data and potential source names. In a few cases, facilities themselves were

contacted for data or clarification of data.

Lists of potential sources were obtained and combined from a variety of sources:

• Hog-fuel (Wood-Waste) Boilers

The table of hog-fuel (wood-waste) boilers as potential dioxin sources originated

from Ecology’s Air Quality Program wood-waste boiler survey (Ecology, 1997a).

Air pollution control authorities were also contacted for their knowledge of such

boilers in their respective regions.

• Medical Waste Incinerators

The initial list of possible medical waste incinerators was obtained from the AQP.

Additional inquiries were made to regional air pollution control authorities. We

added county locations and facility status (i.e., active or closed). The Department

of Health was contacted for information on veterinary and crematory incinerator
sources (Phillips, 1997). Because these facilities typically do not routinely burn

plastics and since no supporting data were located, veterinary and crematory

incinerators were not included in this list.

• USEPA and State MTCA Cleanup Sites

Staff from Ecology’s TCP provided information about clean-up sites, including

information from their database as well as verbal and written information.

USEPA site managers were also contacted about specific sites.

• Pentachlorophenol Wood Treating Facilities

Active PCP wood treating facilities were identified by WQP staff. TCP site

managers and HWTRP personnel identified the closed sites.

• Oil Refineries

Ecology’s Industrial Section provided reports on dioxin found in catalytic

reformer batched wastewaters. Loads were not calculated for these facilities

because wastewater volumes were not available.

• Municipal Waste Incinerators

Data were obtained from AQP, SWFAP, and local air pollution control agencies.

Conventions Used in Processing Quantitative Data

A single cited document may contain more than one sampling event. A single load was

calculated for each sampling event reported. In some cases, an individual load may

represent a single point in space and time (e.g., loads calculated from a grab sample and

an instantaneous wastewater flow). In other cases, the single load may represent multiday samples collected from several stacks at a single facility and varying stack gas flow

rates associated with the several days and samples. A database was designed for this

assessment. It includes the items shown in Table B-1.
Table B-1. Database Parameters

Major

Parameter

Minor Parameter Description

Citation Title Title of citation containing data

 Type Type of document (e.g., source test, memorandum)

 Author(s) Name(s) of authors

 Organization Affiliation of authors

 Date Publication date

 Publication Number Publication number

Facility Name Name of facility where testing occurred

 County County where facility is located

 Category Facility category (e.g., medical waste incinerator, cement kiln)

Process Type Type of process tested (e.g., wastewater treatment, wood-fired boiler)

Results Material Sampled Material description (e.g., fly ash, wastewater, air emission, etc.)

 Start date Date when sampling began or occurred

 End date Date when sampling ended

 Sampling

 Organization

Affiliation of personnel conducting sampling

 Laboratory Name of laboratory performing analyses

 Type Number and type of congeners tested for

 Mass rate notes How mass rate or load was calculated or detected

 TEQ loads Milligrams TEQ/day calculated in each of 3 ways (see below)

Non-Detectable Quantities

Sampling and analytical methods for dioxins have a range of detection and quantification

limits for individual congeners. Some congeners may be detected and quantified while

others remain undetected. Some congener concentrations are qualified as “estimates”.

For calculating dioxin loads, we treated estimated concentrations as if they were not

qualified (i.e., not flagged as estimates). Dealing with congeners that were not detected is

more complex. If one or several 2,3,7,8-substituted congeners are not detected in a

sample, the total calculated TEQ may be ambiguous. Researchers approach this problem

in different ways:

• If undetected congener concentrations are assumed to be zero, the resulting TEQ is

the minimum TEQ associated with that sample analysis.

• If congener concentrations are assumed to equal the method detection limit, the

resulting TEQ is the maximum TEQ associated with that sample analysis.

• If undetected congener concentrations are assumed to equal one half the detection

limits, the resulting TEQ is an average of the minimum and maximum TEQ for that

sample analysis.

This assessment calculates TEQs in each of the three ways described above. The

minimum TEQ is used to interpret and report results. Appendix C provides a summary of

the three calculated loads.
Appendix C

Dioxin Loads Calculated by

Three Alternative Methods for

Handling Quantities

Less than the Detection Limit
Facility Name Process

Material

Sampled

Start 

Date

End 

Date

Calculated 

Load 

 (<DL=0)

Calculated 

Load 

 (<DL=1/2DL)

Calculated 

Load 

 (<DL=DL)

Ash Grove Cement, Seattle Cement Kiln Air Emission 15-Aug-96 0 0.016 0.031

Boise Cascade Pulp and 

Paper, Wallula

Treatment of 

Process Wastewater

Wastewater, 

Treated 

07-Apr-92 08-Apr-92 0.32 1.31 2.3

Cameron-Yakima, Yakima Activated Carbon 

Regeneration 

(Multiple Hearth)

Air Emission 01-Dec-94 21-Dec-94 4.68 4.68 4.68

Cameron-Yakima, Yakima Activated Carbon 

Regeneration 

(Rotary Kiln)

Air Emission 06-Dec-94 19-Dec-94 32.7 32.7 32.7

Conrad Industries, Chehalis Pyrolysis Unit Air Emission 24-Feb-94 24-Feb-94 0.000405 0.000524 0.000643

Daishowa America Mill, Port 

Angeles

Hog Fuel Boiler Ash, Mixed 22-May-96 22-May-96 0.0116 0.059 0.11

Fort James Pulp and Paper, 

Camas

Hog Fuel Boiler Ash, Fly 20-Oct-97 20-Oct-97 0.544 0.549 0.555

Fort Lewis Incinerator Incinerator Air Emission 15-Jul-97 24-Jul-97 0.0028 0.018 0.034

Fort Lewis Incinerator Incinerator Ash, Bottom 01-May-96 01-Sep-96 0 1.73 3.47

Fort Lewis Incinerator Incinerator Ash, Fly 01-May-96 01-Sep-96 0.76 0.76 0.76

Georgia-Pacific Pulp and 

Paper, Bellingham

Treatment of 

Process Wastewater

Wastewater, 

Treated 

14-Apr-93 15-Apr-93 0 1.81 3.61

Holman Inc., Seattle Cement Kiln Cement Kiln 15-May-96 15-May-96 0.0038 0.078 0.15

Holman Inc., Seattle Cement Kiln Air Emission 26-Jul-95 2.88 2.96 3.05

Holman Inc., Seattle Cement Kiln Air Emission 27-Jul-95 1.09 1.16 1.23

Holman Inc., Seattle Cement Kiln Air Emission 08-Jul-96 1.23 1.28 1.33

Holman Inc., Seattle Cement Kiln Air Emission 09-Jul-96 10-Jul-96 1 1.08 1.16

Holman Inc., Seattle Cement Kiln Air Emission 11-Jul-96 0.64 0.7 0.76

Holman Inc., Seattle Cement Kiln Air Emission 26-May-94 27-May-94 0.71 0.76 0.81

Holman Inc., Seattle Cement Kiln Cement Kiln 20-Oct-97 20-Oct-97 0.0948 0.191 0.287

Holman Inc., Seattle Cement Kiln Cement Kiln 21-Oct-97 21-Oct-97 0.0674 0.137 0.207

Kaiser Aluminum Rolling 

Mill, Trentwood

Aluminum Remelting Air Emission 18-Jun-96 19-Jun-97 0.0314 0.0365 0.0416

Kalama Chemical, Kalama Industrial 

Boiler/Waste Burner

Air Emission 25-Jun-96 30-Jun-96 0.00029 0.0022 0.004

Longview Fiber, Longview Treatment of 

Process Wastewater

Wastewater, 

Treated 

02-Nov-93 03-Nov-93 0.02 1.69 3.35

Northwest Hospital, Seattle Incinerator Air Emission 18-Jan-95 20-Jan-95 0.15 0.15 0.15

Olivine Municipal 

Incinerator, Bellingham

Incinerator Air Emission 17-Mar-95 18-Mar-95 0.41 0.47 0.54

Olivine Municipal 

Incinerator, Bellingham

Incinerator Air Emission 27-Oct-94 28-Oct-94 7.21 7.21 7.21

Rayonier, Inc., Port Angeles Hog Fuel Boiler Ash, Fly 13-Sep-93 68.9 Not Available Not Available

Rayonier, Inc., Port Angeles Hog Fuel Boiler Ash, Fly 19-Feb-97 19-Feb-97 6.27 6.31 6.35

Rayonier, Inc., Port Angeles Hog Fuel Boiler Air Emission 26-Apr-95 26-Apr-95 0.168 0.186 0.205

Rayonier, Inc., Port Angeles Hog Fuel Boiler Ash, Fly 01-Dec-89 12.5 12.5 12.5

Rayonier, Inc., Port Angeles Hog Fuel Boiler Ash, Fly 02-Dec-89 1.23 1.23 1.23

Rayonier, Inc., Port Angeles Treatment of 

Process Wastewater

Wastewater, 

Treated 

01-Dec-89 12.3 Not Available Not Available

Rayonier, Inc., Port Angeles Treatment of 

Process Wastewater

Wastewater, 

Treated 

01-Feb-90 15.3 Not Available Not Available

Rayonier, Inc., Port Angeles Treatment of 

Process Wastewater

Wastewater, 

Treated 

01-Jun-90 0.19 Not Available Not Available

Rayonier, Inc., Port Angeles Treatment of 

Process Wastewater

Wastewater, 

Treated 

01-Dec-91 51.9 Not Available Not Available

Rayonier, Inc., Port Angeles Treatment of 

Process Wastewater

Wastewater, 

Treated 

01-Apr-92 27.1 Not Available Not Available

Rayonier, Inc., Port Angeles Treatment of 

Process Wastewater

Wastewater, 

Treated 

01-Jun-92 20.7 Not Available Not Available

Rayonier, Inc., Port Angeles Treatment of 

Process Wastewater

Wastewater, 

Treated 

01-Sep-92 10 Not Available Not Available

Table C-1. Dioxin loads, not including self-reported data associated with National

Pollutant Discharge Elimination System (NPDES) permits. Loads in mg TEQ/day.

Page 1 of 8
Facility Name Process

Material

Sampled

Start 

Date

End 

Date

Calculated 

Load 

 (<DL=0)

Calculated 

Load 

 (<DL=1/2DL)

Calculated 

Load 

 (<DL=DL)

Rayonier, Inc., Port Angeles Treatment of 

Process Wastewater

Wastewater, 

Treated 

01-Dec-92 3.5 Not Available Not Available

Rayonier, Inc., Port Angeles Treatment of 

Process Wastewater

Wastewater, 

Treated 

01-Feb-94 0 Not Available Not Available

Recomp (Thermal 

Reduction Company), 

Incinerator Air Emission 14-Dec-88 14-Dec-88 4 4 4

Recomp (Thermal 

Reduction Company), 

Incinerator Ash, Mixed 01-Jan-96 31-Dec-96 2.17 2.32 2.48

Recomp (Thermal 

Reduction Company), 

Incinerator Ash, Mixed 01-Jan-94 31-Dec-94 0.617 0.683 0.75

Recomp (Thermal 

Reduction Company), 

Incinerator Ash, Mixed 01-Jan-95 31-Dec-95 0.622 0.672 0.722

Renton Wastewater 

Treatment Plant, Renton

Treatment of 

Municipal 

Wastewater

Sludge from 

Wasterwater 

Treatment

01-Jan-89 0.262 1.18 2.1

Renton Wastewater 

Treatment Plant, Renton

Treatment of 

Municipal 

Wastewater

Sludge from 

Wasterwater 

Treatment

08-Sep-97 08-Sep-97 0.432 Not Available Not Available

Simpson Tacoma Kraft 

Company

Treatment of 

Process Wastewater

Wastewater, 

Treated 

12-Feb-91 13-Feb-91 13.73 13.75 13.77

Spokane Municipal 

Incinerator, Spokane

Incinerator Ash, Mixed 13-Dec-95 38.0 38.0 38.0

Spokane Municipal 

Incinerator, Spokane

Incinerator Air Emission 22-Sep-92 25-Sep-92 0.00398 0.0234 0.0428

Spokane Municipal 

Incinerator, Spokane

Incinerator Air Emission 30-Sep-93 0.0084 0.07 0.13

Spokane Municipal 

Incinerator, Spokane

Incinerator Air Emission 09-Jun-94 10-Jun-94 0.24 0.27 0.3

Spokane Municipal 

Incinerator, Spokane

Incinerator Air Emission 11-May-95 12-May-95 0.0039 0.16 0.31

Spokane Municipal 

Incinerator, Spokane

Incinerator Air Emission 01-Nov-91 01-Nov-91 0.28 0.29 0.3

Spokane Municipal 

Incinerator, Spokane

Incinerator Ash, Bottom 27-Jan-92 02-Feb-92 0.02 Not Available Not Available

Spokane Municipal 

Incinerator, Spokane

Incinerator Ash, Fly 27-Jan-92 02-Feb-92 24.3 Not Available Not Available

Spokane Municipal 

Incinerator, Spokane

Incinerator Ash, Fly 23-Sep-97 02-Oct-97 0.984 0.993 1.003

Tacoma City Light, Steam 

Plant #2, Tacoma

Steam 

Plant/Incinerator

Air Emission 02-Aug-91 02-Aug-91 0.00293 0.01 0.017

Tacoma City Light, Steam 

Plant #2, Tacoma

Steam 

Plant/Incinerator

Air Emission 11-Dec-91 12-Dec-91 0.0318 0.068 0.103

Tacoma City Light, Steam 

Plant #2, Tacoma

Steam 

Plant/Incinerator

Air Emission 20-Mar-92 23-Mar-92 0.0267 0.047 0.067

Tacoma City Light, Steam 

Plant #2, Tacoma

Steam 

Plant/Incinerator

Air Emission 08-Oct-90 09-Oct-90 0.252 0.26 0.269

Veteran's Administration 

Medical Center, Seattle

Incinerator Air Emission 23-Jan-95 25-Jan-95 0.54 0.54 0.54

Weyerhaeuser Paper Co., 

Cosmopolis

Other Wastewater, 

Other

29-May-91 30-May-91 0 0.049 0.098

Weyerhaeuser Paper Co., 

Cosmopolis

Treatment of 

Process Wastewater

Wastewater, 

Treated 

29-May-91 30-May-91 0 0.34 0.67

Weyerhaeuser Pulp and 

Paper, Longview

Hog Fuel Boiler Air Emission 25-Jul-90 25-Jul-90 0.11 0.12 0.13

Page 2 of 8
Date

0 1/2 DL DL

Fort James, Camas - "ASB Effluent"

2/23/94 23.50 23.50 23.50

2/18/94 0.00 0.37 0.74

2/23/94 23.50 23.50 23.50

2/28/94 3.09 3.09 3.09

5/4/94 0.00 0.44 0.88

7/27/94 2.68 2.68 2.68

9/9/94 0.00 0.67 1.33

10/12/94 0.00 0.35 0.70

1/30/95 0.00 0.33 0.66

5/1/95 0.00 0.19 0.37

1/31/96 0.08 0.46 0.84

4/17/96 0.09 0.51 0.94

7/31/96 0.07 0.41 0.75

10/23/96 0.10 0.58 1.06

12/11/96 0.06 0.37 0.68

2/19/97 0.00 0.27 0.54

4/23/97 0.00 0.18 0.35

Georgia Pacific - "Effluent"

11/25/91 0.6 1.2 1.9

2/19/92 1.1 1.7 2.3

5/20/92 1.5 2.9 4.2

8/19/92 0.7 1.3 2.0

11/18/92 0.8 1.4 2.1

2/17/93 1.0 1.6 2.2

5/19/93 0.8 1.5 2.1

8/25/93 1.2 1.9 2.7

11/18/93 1.7 2.3 2.8

2/23/94 1.1 1.7 2.4

5/19/94 1.4 2.1 2.9

8/25/94 2.2 2.9 3.5

11/16/94 1.8 2.6 3.4

2/22/95 2.7 3.2 3.7

5/24/95 2.2 2.8 3.4

8/23/95 2.3 3.1 3.8

11/15/95 4.4 5.1 5.9

1/17/96 2.4 3.2 3.9

4/17/96 1.9 1.9 1.9

7/17/96 1.4 2.0 2.6

10/23/96 1.3 2.0 2.8

1/15/97 1.7 2.3 2.9

4/16/97 0.9 1.6 2.3

7/16/97 4.2 4.9 5.7

Boise Cascade, Wallula - Final Mill Effluent

2/20/92 1.79 1.79 1.79

TEQ Load 

(mg/day)

<DL=

Table C-2. Dioxin loads from bleached pulp and paper mill treated wastewater.

(2,3,7,8-TCDD and 2,3,7,8-TCDF only).

Source: self-reported data associated with National Pollutant 

(DL = Detection Limit)

Discharge Elimination (NPDES) permits

Page 3
2/20/92 2.04 2.04 2.04

2/27/92 2.88 2.88 2.88

4/15/92 0.22 0.45 0.67

8/4/92 2.04 2.04 2.04

12/9/92 0.40 0.91 1.41

2/24/93 0.36 0.54 0.73

Boise Cascade, Wallula - Secondary and Final Effluent

 note: secondary effluent is major portion of final effluent (75-80%)

9/16/91 3.78 3.78 3.78

6/10/93 0.49 0.70 0.92

9/2/93 0.21 0.33 0.45

12/2/93 0.20 0.52 0.83

3/19/94 0.11 0.20 0.30

6/1/94 0.15 0.48 0.80

8/11/94 0.11 0.23 0.35

12/8/94 0.00 0.18 0.36

3/12/95 0.16 0.50 0.84

6/8/95 0.15 0.40 0.65

9/10/95 0.38 0.49 0.60

3/13/96 1.10 1.10 1.10

11/18/95 1.20 1.20 1.20

4/6/96 0.49 0.74 0.98

7/20/96 0.16 0.21 0.26

10/19/96 0.61 0.61 0.61

1/31/97 0.19 0.36 0.52

5/2/97 0.23 0.34 0.46

Longview Fibre, Longview - "Final Mill Effluent"

7/26/91 2.84 2.84 2.84

7/26/91 3.59 3.59 3.59

10/14/91 2.46 2.46 2.46

2/17/92 0.30 1.46 2.62

5/13/92 0.89 1.42 1.94

8/14/92 0.26 0.70 1.13

12/16/92 0.00 0.40 0.81

3/26/93 0.14 0.43 0.72

7/27/93 0.00 0.20 0.39

11/16/93 0.00 0.42 0.84

12/19/94 0.00 0.52 1.04

11/21/94 0.00 0.22 0.44

2/27/95 0.14 0.44 0.74

5/3/95 0.00 0.21 0.42

Kimberly Clark - Sum of 3 outfalls

9/5/91 0.15 0.41 0.68

12/9/91 0.00 0.63 1.26

6/26/92 0.11 0.31 0.50

9/12/92 0.00 0.20 0.39

12/19/92 0.03 0.20 0.36

9/21/93 0.00 0.21 0.41

1/17/94 0.03 0.22 0.42

2/21/95 0.04 0.31 0.58

5/21/96 3.34 3.44 3.53

6/20/96 0.65 0.71 0.78

7/23/96 0.09 0.36 0.63

Weyerhaeuser, Cosmopolis - "Pond D Effluent"

3/22/93 0.13 0.18 0.22

5/3/93 0.06 0.20 0.33

Page 4
10/12/93 0.21 0.26 0.31

12/21/94 0.15 0.20 0.24

3/23/94 0.15 0.24 0.33

5/24/94 0.13 0.22 0.30

8/23/94 0.24 0.53 0.82

1/24/95 0.08 0.12 0.17

5/30/95 0.31 0.40 0.49

12/12/95 0.27 0.32 0.37

2/21/96 0.36 0.41 0.45

6/27/96 0.41 0.54 0.68

9/24/96 0.31 0.42 0.54

1/7/97 0.14 0.19 0.24

Weyerhaeuser, Longview - "Secondary effluent"

12/12/91 0.32 0.66 1.00

3/5/92 0.00 0.37 0.74

5/19/92 0.30 0.72 1.15

9/8/92 0.00 0.13 0.25

11/30/92 0.00 0.36 0.73

1/25/93 0.35 0.48 0.60

3/14/93 0.00 0.13 0.26

5/14/93 0.05 0.18 0.30

8/24/93 0.10 0.23 0.36

10/19/93 0.17 0.29 0.41

6/7/94 0.12 0.70 1.28

8/19/94 0.15 0.52 0.89

11/26/94 0.22 0.71 1.21

2/15/95 0.30 0.91 1.53

2/15/95 0.32 0.81 1.30

2/15/95 0.31 0.86 1.41

3/14/95 0.0369 0.28 0.53

3/14/95 0.00 0.54 1.08

3/14/95 0.02 0.41 0.81

4/19/95 0.26 0.52 0.78

4/19/95 0.24 0.63 1.02

4/19/95 0.25 0.57 0.90

9/30/95 0.14 0.50 0.86

9/30/95 0.09 0.45 0.80

9/30/95 0.12 0.47 0.83

3/6/96 0.03 0.20 0.37

3/6/96 0.05 0.22 0.39

3/6/96 0.04 0.21 0.38

4/24/96 0.10 0.19 0.28

4/24/96 0.10 0.19 0.28

4/24/96 0.10 0.19 0.28

8/13/96 0.13 0.49 0.85

8/13/96 0.13 0.31 0.49

8/13/96 0.13 0.40 0.67

11/13/96 0.07 0.24 0.42

11/13/96 0.10 0.28 0.45

11/13/96 0.09 0.26 0.44

Rayoneir, Port Angeles - "Final effluent"

1/25/93 0.00 0.34 0.69

1/26/93 0.19 0.91 1.63

1/27/93 0.00 0.65 1.29

1/28/93 0.00 0.36 0.71

Page 5
1/29/93 0.00 0.53 1.05

6/4/93 0.23 0.96 1.69

7/20/93 1.05 1.05 1.05

10/12/93 0.21 0.62 1.02

3/8/94 0.00 0.56 1.12

5/30/94 0.00 0.34 0.67

8/31/94 0.00 0.19 0.38

12/12/94 0.14 0.40 0.67

3/21/95 0.00 0.05 0.10

5/10/95 0.00 0.33 0.66

9/6/95 0.00 0.29 0.58

12/20/95 0.00 0.12 0.25

3/6/96 0.00 0.17 0.34

5/1/96 0.00 0.18 0.37

8/6/96 0.09 0.17 0.25

11/21/96 0.12 0.41 0.70

Simpson Tacoma Kraft, Tacoma - "Secondary Effluent"

11/18/91 0.00 0.45 0.90

3/30/92 0.00 0.11 0.23

7/31/92 0.00 0.21 0.43

11/30/92 0.00 0.12 0.24

6/15/93 0.00 0.17 0.34

3/30/94 0.00 0.12 0.25

6/27/94 0.00 0.40 0.80

9/20/94 0.00 0.11 0.21

12/6/94 0.00 0.22 0.44

3/30/95 0.00 0.13 0.26

6/20/95 0.00 0.06 0.12

10/2/95 0.00 0.06 0.13

12/11/95 0.00 0.48 0.97

3/28/96 0.00 0.06 0.13

9/27/96 0.00 0.20 0.40

2/6/97 0.00 0.17 0.34

Page 6
Table C-3. Dioxin loads from bleached pulp and paper mill wastewater sludge.

2,3,7,8-TCDD 2,3,7,8-TCDF

TEF = 1 TEF = 0.1

Date

Value 

(ppt)

TEQ (ppt)

<DL = 

Value 

(ppt)

TEQ (ppt)

<DL = 

Total TEQ (ppt)

<DL = 

0 DL 0 DL 0 1/2 DL DL

Boise Cascade, Wallula - "Clarifer Sludge"

9/16/91 9.1 9.1 9.1 17 1.7 1.7 10.8 10.8

3/31/92 1.3 1.3 1.3 11 1.1 1.1 2.4 2.4

4/15/92 0.45 0.45 0.45 1.6 0.16 0.16 0.61 0.61

8/4/92 1.3 1.3 1.3 3.7 0.37 0.37 1.67 1.67

12/11/92 1.1 1.1 1.1 2.3 0.23 0.23 1.33 1.33

2/24/93 0.28 U 0 0.28 1.9 0.19 0.19 0.19 0.47

6/10/93 0.31 U 0 0.31 1.7 0.17 0.17 0.17 0.48

9/2/93 1.6 1.6 1.6 3.8 0.38 0.38 1.98 1.98

12/2/93 1 U 0 1 2.4 0.24 0.24 0.24 1.24

3/19/94 1 U 0 1 3.3 0.33 0.33 0.33 1.33

8/11/94 0.37 U 0 0.37 1.6 0.16 0.16 0.16 0.53

12/8/94 1 U 0 1 1.7 0.17 0.17 0.17 1.17

3/12/95 1 U 0 1 2.7 0.27 0.27 0.27 1.27

6/8/95 0.55 U 0 0.55 2.4 0.24 0.24 0.24 0.79

9/10/95 1 1 1 20 22 3 3

3/13/96 0.47 0.47 0.47 2.5 0.25 0.25 0.72 0.72

11/18/95 14 14 14 222 22.2 22.2 36.2 36.2

4/6/96 0.65 U 0 0.65 2.8 0.28 0.28 0.28 0.93

7/20/96 0.6 0.6 0.6 1.7 0.17 0.17 0.77 0.77

10/22/96 0.28 0.28 0.28 0.91 0.091 0.091 0.371 0.371

1/31/97 0.33 U 0 0.33 0.77 0.077 0.077 0.077 0.407

Mean TEQ (ppt) 2.95 3.26

Production rate (tons/year dry weight) 11,000 11,000

TEQ load (mg/day) 0.081 0.085 0.089 

2,3,7,8-TCDD 2,3,7,8-TCDF

TEF = 1 TEF = 0.1

Date

Value 

(ppt)

TEQ (ppt)

<DL = 

Value 

(ppt)

TEQ (ppt)

<DL = 

Total TEQ (ppt)

<DL = 

0 DL 0 DL 0 1/2 DL DL

Weyerhaeuser, Longview - "Combined Effluent Sludge"

12/12/91 50 50 50 92 9.2 9.2 59.2 59.2

3/5/92 22 U 0 22 86 8.6 8.6 8.6 30.6

5/19/92 5.3 U 0 5.3 140 14 14 14 19.3

9/8/92 2.7 U 0 2.7 24.1 2.41 2.41 2.41 5.11

11/30/92 2.4 U 0 2.4 38 3.8 3.8 3.8 6.2

3/14/93 8.74 8.74 8.74 64.3 6.43 6.43 15.17 15.17

5/14/93 0.6 U 0 0.6 45.2 4.52 4.52 4.52 5.12

8/24/93 0.67 U 0 0.67 43.4 4.34 4.34 4.34 5.01

10/19/93 0.49 U 0 0.49 27.3 2.73 2.73 2.73 3.22

6/7/94 5.1 U 0 5.1 3.5 U 0 0.35 0 5.45

8/19/94 4.83 U 0 4.83 52 5.2 5.2 5.2 10.03

11/26/94 22.4 22.4 22.4 54.6 5.46 5.46 27.86 27.86

2/15/95 8 U 0 8 65.7 6.57 6.57 6.57 14.57

3/14/95 23.4 23.4 23.4 55.3 5.53 5.53 28.93 28.93

4/19/95 9.32 9.32 9.32 42.7 4.27 4.27 13.59 13.59

9/30/95 4.8 U 0 4.8 114 11.4 11.4 11.4 16.2

3/6/96 3.9 U 0 3.9 55.5 5.55 5.55 5.55 9.45

4/24/96 2 U 0 2 47.4 4.74 4.74 4.74 6.74

8/13/96 3 U 0 3 102 10.2 10.2 10.2 13.2

11/13/96 4.37 U 0 4.37 53.4 5.34 5.34 5.34 9.71

Mean TEQ (ppt) 11.71 15.23

Production Rate (Oven-dried tons/day) 165 165

TEQ load (mg/day) 1.76 2.02 2.28

Citation for mass rate:

Weyerhaeuser Co., 1991. Supplemental Environmental checklist for the Weyerhaeuser Longview 

2,3,7,8-TCDD/TCDF

2,3,7,8-TCDD/TCDF
2,3,7,8-TCDD 2,3,7,8-TCDF

TEF = 1 TEF = 0.1

Date

Value 

(ppt)

TEQ (ppt)

<DL = 

Value 

(ppt)

TEQ (ppt)

<DL = 

Total TEQ (ppt)

<DL = 

0 DL 0 DL 0 1/2 DL DL

2,3,7,8-TCDD/TCDF

 Kraft Mill Modernization Project, November 1991. The mass rate number is a predicted estimate.
Table C-3. Dioxin loads from bleached pulp and paper mill wastewater sludge.

2,3,7,8-TCDD 2,3,7,8-TCDF 2,3,7,8-TCDD/TCDF

TEF = 1 TEF = 0.1

Date Value

(ppt)

TEQ (ppt)

<DL =

Value

(ppt)

TEQ (ppt)

<DL =

Total TEQ (ppt)

<DL =

0 DL 0 DL 0 1/2 DL DL

Boise Cascade, Wallula - "Clarifer Sludge"

9/16/91 9.1 9.1 9.1 17 1.7 1.7 10.8 10.8

3/31/92 1.3 1.3 1.3 11 1.1 1.1 2.4 2.4

4/15/92 0.45 0.45 0.45 1.6 0.16 0.16 0.61 0.61

8/4/92 1.3 1.3 1.3 3.7 0.37 0.37 1.67 1.67

12/11/92 1.1 1.1 1.1 2.3 0.23 0.23 1.33 1.33

2/24/93 0.28 U 0 0.28 1.9 0.19 0.19 0.19 0.47

6/10/93 0.31 U 0 0.31 1.7 0.17 0.17 0.17 0.48

9/2/93 1.6 1.6 1.6 3.8 0.38 0.38 1.98 1.98

12/2/93 1 U 0 1 2.4 0.24 0.24 0.24 1.24

3/19/94 1 U 0 1 3.3 0.33 0.33 0.33 1.33

8/11/94 0.37 U 0 0.37 1.6 0.16 0.16 0.16 0.53

12/8/94 1 U 0 1 1.7 0.17 0.17 0.17 1.17

3/12/95 1 U 0 1 2.7 0.27 0.27 0.27 1.27

6/8/95 0.55 U 0 0.55 2.4 0.24 0.24 0.24 0.79

9/10/95 1 1 1 20 22 3 3

3/13/96 0.47 0.47 0.47 2.5 0.25 0.25 0.72 0.72

11/18/95 14 14 14 222 22.2 22.2 36.2 36.2

4/6/96 0.65 U 0 0.65 2.8 0.28 0.28 0.28 0.93

7/20/96 0.6 0.6 0.6 1.7 0.17 0.17 0.77 0.77

10/22/96 0.28 0.28 0.28 0.91 0.091 0.091 0.371 0.371

1/31/97 0.33 U 0 0.33 0.77 0.077 0.077 0.077 0.407

Mean TEQ (ppt) 2.95 3.26

Production rate (tons/year dry weight) 11,000 11,000

TEQ load (mg/day) 0.081 0.085 0.089

2,3,7,8-TCDD 2,3,7,8-TCDF 2,3,7,8-TCDD/TCDF

TEF = 1 TEF = 0.1

Date Value

(ppt)

TEQ (ppt)

<DL =

Value

(ppt)

TEQ (ppt)

<DL =

Total TEQ (ppt)

<DL =

0 DL 0 DL 0 1/2 DL DL

Weyerhaeuser, Longview - "Combined Effluent Sludge"

12/12/91 50 0 0 92 00 0 0

3/5/92 22 U 0 0 86 00 0 0

5/19/92 5.3 U 0 0 140 00 0 0

9/8/92 2.7 U 0 0 24.1 00 0 0

11/30/92 2.4 U 0 0 38 00 0 0

3/14/93 8.74 0 0 64.3 00 0 0

5/14/93 0.6 U 0 0 45.2 00 0 0

8/24/93 0.67 U 0 0 43.4 00 0 0

10/19/93 0.49 U 0 0 27.3 00 0 0

6/7/94 5.1 U 0 0 3.5 U 0 0 0 0

8/19/94 4.83 U 0 0 52 00 0 0

11/26/94 22.4 0 0 54.6 00 0 0

2/15/95 8 U 0 0 65.7 00 0 0

3/14/95 23.4 0 0 55.3 00 0 0

4/19/95 9.32 0 0 42.7 00 0 0

9/30/95 4.8 U 0 0 114 00 0 0

3/6/96 3.9 U 0 0 55.5 00 0 0

4/24/96 2 U 0 0 47.4 00 0 0

8/13/96 3 U 0 0 102 00 0 0

11/13/96 4.37 U 0 0 53.4 00 0 0

Mean TEQ (ppt) 3.20 0.00

Production Rate (Oven-dried tons/day) 165 165

TEQ load (mg/day) 0.48 0.24 0.00

Citation for mass rate:

Weyerhaeuser Co., 1991. Supplemental Environmental checklist for the Weyerhaeuser Longview

 Kraft Mill Modernization Project, November 1991. The mass rate number is a predicted estimate.
Appendix D

Dioxin TEQ Load Calculations

Appendix D is printed as a separate report, Publication No. 98-321.