From: Schwartz, Jerry

Sent: Thursday, February 24, 2011 2:26 PM

To: Elizabeth Sabol [mailto:Elizabeth.Sabol@erg.com] ; Swietlik.William@epamail.epa.gov

Cc: Eleanor Codding; jmontgo@simpson.com Subject: RE: Clarification of Dioxin Data



### Elizabeth: We realize that the attached table is l abeled “Secondary Effluent”, but Jim has confirmed
that the data comes from testing of the final efflu ent composited over a 24 hour period. As you can
see, the results are all “zero” for TCDD and almost all “zero” for TCDF. I hope that answers your
questions below. Jerry

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

Sent: Monday, February 14, 2011 10:09 AM

To: Schwartz, Jerry; Swietlik.William@epamail.epa.gov

Cc: Eleanor Codding Subject: RE: Clarification of Dioxin Data

Jerry,

Thank you for the information for the Simpson facil ity. I have a few follow-up questions regarding the Simpson data provided, please find below.

1. To confirm, the dioxin data provided are labeled as the results for the "Secondary Effluent". Is th e secondary effluent the final effluent (e.g., the sa me effluent point that the flow data represents), o r is it an internal sampling point? 2. If it is an internal sampling point, are other w astewaters commingled with the process wastewater stream prior to discharge? 3. Do you know the dioxin concentrations at the fin al effluent? Are they non-detect?

If you have any questions or find it easier to disc uss via phone, please call me at 703-633-1659. I appreciate your help in interpreting this data corr ectly.

Thanks,

Elizabeth

Elizabeth A. Sabol Environmental Engineer Eastern Research Group, Inc. 14555 Avion Parkway, Suite 200 Chantilly, VA 20151 elizabeth.sabol@erg.com

Phone:703-633-1659

From: "Montgomery, Jim" <jmontgo@simpson.com>

To: "Elizabeth Sabol" <Elizabeth.Sabol@erg.com>, "Jerr y Schwartz" <Jerry_Schwartz@afandpa.org>, <Swietlik.William@epa mail.epa.gov>

CC: "Eleanor Codding" <Eleanor.Codding@erg.com>

Date: 2/7/2011 7:23 PM Subject: RE: Clarification of Dioxin Data

Attachments: effluent congeners 2008 and 2009.xlsxResponse for Simpson:

Flow data on attached is for final effluent flow.

Jim Montgomery

Environmental Manager

Simpson Tacoma Kraft Co. LLC

From: Elizabeth Sabol [mailto:Elizabeth.Sabol@erg.c om] Sent: Friday, February 04, 2011 1:11 PM To: Jerry Schwartz; Swietlik.William@epamail.epa.go v Cc: Eleanor Codding; Montgomery, Jim Subject: RE: Clarification of Dioxin Data

Jerry,

Thanks again for all of the facility data provided.

Below, I have included a couple follow-up questions regarding the responses provided for Longview Fibre Paper & Packa ging, Inc. and Simpson Tacoma Kraft, Co.,LLC.

Longview:

1. For 2008 through 2010 final effluent data, is 2, 3,7,8-TCDD the only parameter being monitored? 2. When was the earlier detection of 2,3,7,8-TCDF i n the effluent sampled? 3. Please clarify the statement "these assumptions were not based on

water dioxin distribution data". I am unclear what the facility is saying. 4. Please provide a copy of the 2008-2010 dioxin sa mpling data and corresponding flow data.

Simpson:

Please provide a copy of the 2008 and 2009 dioxin s ampling data. Also, please provide corresponding flow data. Please note whether this flow
data is for the final outfall or another internal o utfall. If internal, please explain.

Again, we appreciate your help in clarifying the TR I data. I look forward to hearing from you.

Thanks,

Elizabeth

>>> "Schwartz, Jerry" <Jerry_Schwartz@afandpa.org> 2/3/2011 3:09 PM >>> Bill: Here is a response from Simpson. Jerry -----Original Message-----From: "Schwartz, Jerry" <Jerry_Schwartz@afandpa.org>

To: <Swietlik.William@epamail.epa.gov>

CC: "Elizabeth Sabol" <Elizabeth.Sabol@erg.com>, "Elea nor Codding" <Eleanor.Codding@erg.com>

Date: 1/28/2011 6:11 PM Subject: RE: Clarification of Dioxin Data

Attachments: Response to EPA 2009 Pulp and Paper Dioxin Distn S ummary.doc

Bill et al: Thanks again for extending your deadli ne for us to respond to your request for clarification. Attached are re sponses for three of the four mills. Unfortunately, despite my best eff orts, I did not receive responses from personnel representing the f ourth company.
Please let me know if I can be of further assistanc e on this. Jerry

-----Original Message----- From: Swietlik.William@epamail.epa.gov [mailto:Swietlik.William@epamail.epa.gov] Sent: Monday, January 10, 2011 9:42 AM To: Schwartz, Jerry Cc: Elizabeth Sabol; Eleanor Codding Subject: Re: Clarification of Dioxin Data

From: Swietlik.William@epamail.epa.gov [mailto:Swietlik.William@epamail.epa.gov] Sent: Monday, January 10, 2011 9:42 AM To: Schwartz, Jerry Cc: Elizabeth Sabol; Eleanor Codding Subject: Re: Clarification of Dioxin Data

Jerry:

As we have done in previous years, EPA is requestin g clarification of 2009 TRI dioxin data for four Pulp and Paper facili ties as part of our 2011 annual review of industrial discharges under S ection 304 of the

Clean Water Act.

Specifically, we would like to clarify the amount o f dioxin and dioxin-like compound releases and the congener dist ribution reported to the 2009 TRI from the following Pulp and Paper plan ts (see detailed document attached):

1. Longview Fiber Paper & Packaging, Inc.; 2. Abiti biBowater, Inc.; 3. Simpson Tacoma Kraft, Co., LLC; and 4. Domtar Paper Co.

In 2008, these four Pulp and Paper facilities did n ot report a water congener distribution specific to their facility (i .e., they left the field blank). For our database purposes, EPA assign ed the designated Pulp and Paper congener distribution provided previ ously by AF&PA. In 2009 however, these facilities reported water conge ner distributionsspecific to their facility. The reported distribut ions differ from

AF&PA designated distributions. The attachment to this email provides the detailed congener distribution information. E PA would like to confirm these distributions and determine what they are based on (e.g., sampling data, etc.). Specific questions are asked about each facility in the attachment to which we would appreciate your reply.

We appreciate your help in interpreting the 2009 TR I dioxin data correctly.

Please return the requested information to Elizabet h Sabol of ERG via e-mail at elizabeth.sabol@erg.com, or to me directl y if you prefer.

If you have questions regarding this request, you m ay contact Elizabeth Sabol of ERG by phone at (703) 633-1659 or at the e -mail address listed

above.

If you would like to speak with me regarding this r equest, I am available at (202) 566-1129 or by e-mail: swietlik. william@epa.gov.

_________________ Bill Swietlik

US EPA
Office of Water Engineering and Analysis Division (4303T) 1200 Penn sylvania Ave., NW Washington, DC 20460

202-566-1129: Phone

202-566-1053: FAX

### 1 Facility Information – Dioxin Distributions

1. Longview Fiber Paper & Packaging, Inc. – Longview, WA (98632LNGVWSOUT H)

• 

### Longview’s reported pounds of dioxin did not change from 2008 t o 2009.

• 

### Longview did not report any dioxin distribution in 2008, but rep orted a water release

dioxin distribution in 2009.

• 

### Please confirm the 2009 facility-reported water dioxin dist ribution.

• 

### How did the facility determine the 2009 water dioxin distribut ion (i.e., does the facility now have available monitoring data for dioxin compounds)?

• 

### If the facility used monitoring data to determine their wat er dioxin distribution, where was the monitoring conducted (e.g., final effluent) and how are non-detect results

included in the distribution?

RESPONSE:

The mill’s dioxin TRI data are based on extremely conser vative assumptions. Recent (2008-2010) final effluent 2,3,7,8 TCDD data genera ted pursuant to the mill’s NPDES permit were all non-detect. Nonetheless, based on an earlier detection of 2,3,7,8 TCDF in effluent sampled pursuant to the permit, the mill assumed (based on comparisons to analyses of boiler ash) the presence of 2,3,7,8 TCDD and the other congeners in the
distributions included in the table below. These assum ptions were not based on water dioxin distribution data. (Also note that the company name is Longview Fib re ...)

Dioxin Compounds 2009 2008 2007 2006 2005

Pounds Re ported 0.004 0.004 0.005 0.005 NR
NR – Not Reported.

Congener

Number Chemical Name TWF 2009

Distribution (grams) 2009

Distribution (%)

1 Tetrachlorod ibenzo

- p

- dioxin, 2,3,7,8

- 703,584,000 0.053 2.70

2 Pentachlorodibenzo

- p

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

- 692,928,000 0.074 3.76

3 Hexachlorodibenzo

- p

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

- 23,498,240 0.049 2.49

4 Hexachlorodibenzo

- p

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

- 9,556,480 0.072 3.66

5 Hexachl orodibenzo

- p

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

- 10,595,840 0.036 1.83

6 Heptachlorodibenzo

- p

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

- 411,136 0.303 15.41

7 Octachlorodibenzo

- p

- dioxin 6,586 0.313 15.92

8 Tetrachlorodibenzofuran, 2,3,7,8

- 43,819,554 0.358 18.21

9 Pentachlorodibenzofura n, 1,2,3,7,8

- 7,632,640 0.171 8.70

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

- 557,312,000 0.172 8.75

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

- 5,760,000 0.057 2.90

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

- 14,109,440 0.084 4.27

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

- 47,308,800 0 0

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

- 51,204,160 0.099 5.04

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

- 85,760 0.089 4.53

### 2 16 Heptachlorodibenzofuran, 1,2,3,4,7,8,9

- 3,033,984 0 0

17 Octachlorodibenzofuran 2,021 0.036 1.83



### E-mail Follow-Up for Longview:

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

Sent: Friday, February 04, 2011 1:11 PM

To: Jerry Schwartz; Swietlik.William@epamail.epa.gov

Cc: Eleanor Codding; Montgomery, Jim Subject: RE: Clarification of Dioxin Data

Jerry,

Thanks again for all of the facility data provided.

Below, I have included a couple follow-up questions regarding the responses provided for Longview Fibr e Paper & Packaging, Inc. and Simpson Tacoma Kraft, C o.,LLC.

Longview:

1. For 2008 through 2010 final effluent data, is 2, 3,7,8-TCDD the only parameter being monitored? 2. When was the earlier detection of 2,3,7,8-TCDF i n the effluent sampled? 3. Please clarify the statement "these assumptions were not based on water dioxin distribution data". I am unclear what the facility is saying. 4. Please provide a copy of the 2008-2010 dioxin sa mpling data and corresponding flow data.

Simpson:

Please provide a copy of the 2008 and 2009 dioxin s ampling data. Also, please provide corresponding
flow data. Please note whether this flow data is fo r the final outfall or another internal outfall. If internal, please explain.

Again, we appreciate your help in clarifying the TR I data. I look forward to hearing from you.

Thanks,

Elizabeth

From: "DuVall, Steven D" sdduvall@longfibre.com

Sent: Tuesday, February 22, 2011 6:57 PM

To: Sabol, Elizabeth; Schwartz, Jerry Subject: Last words on Longview Fibre Paper and Packaging, Inc. Dioxin Reporting

Elizabeth/Jerry:

This reply is based upon what little knowledge I ca n dredge up since most of the key players have retired. I will be doing the same at the end of this week.

First, we did do a test for 2,3,7,8-TCDD in 2004. That test was non detect so the MRL of ~8 ppq was used. I believe this highly over estimates the actual value for 2,3,7,8-TCDD.

We do not have any speciation data for mill effluen t. We did have a speciation for testing done on boiler fly ash. That testing showed that 2 ,3,7,8-TCDD was about 20% of the total.

### 3

That ratio was applied to the total D/F in the mill effluent making the total D/F at 40 ppq. Again, this is based upon an old MRL value.

That value was used for total reporting for the fol lowing years:

2006 @ 2.384 grams 2007 @ 2.35 grams 2008 @ 1.99 grams
2009 @ 1.84 grams

Actual 2,3,7,8-TCDD testing showed the following:

2008 Non Detect , EDL= 0.412 ppq and MRL = 9.8 ppq

2009 Non Detect , EDL= 2.81 ppq and MRL = 9.17 ppq

2010 Non Detect , EDL= 0.971 ppq and MRL = 12.2 ppq

If I were to have done the reporting, I would have used 50% of the EDL for 2,3,7,8- TCDD and applied the 5X factor (from old fly ash da ta) for total D/F. I have attached a simple spreadsheet for comparison.

2008 = 0.206 ppq 2,3,7,8-TCDD or 1.03 ppq total D/F

. 2009 = 1.4 ppq 2,3,7,8-TCDD or 7 ppq total D/F. 2010 = 0.486 ppq 2,3,7,8-TCDD or 2.43 ppq total D/ F.
Total flows are as follows:

2006 = 15,748,000,000 gallons per year (43.145 MGD) 2007 = 15,518,000,000 gallons per year (42.515 MGD) 2008 = 13,723,000,000 gallons per year (37.597 MGD) 2009 = 13,140,000,000 gallons per year (36.000 MGD) 2010 = 12,157,000,000 gallons per year (33.307 MGD)

Data is sparse and expensive to obtain, so estimate s were used. They were very conservative estimates as you can see from my own c alculations on the attached spreadsheet.

Steven D. DuVall
Environmental Services Manager

email: 

### sdduvall @longfibre.com

phone: 360.575.5584

cell: 360.431.9198

fax: 360.575.6110 300 Fibre Way

P.O. Box 639 Longview, WA 98632 

### longviewfibre.com

Longview Fibre Paper and Packaging, Inc.



### 2. AbitibiBowater, Inc. Coosa Pines Operations – Coosa Pines, AL (35044SPLPNALABA)

• 

### AbitibiBowater’s reported pounds of dioxin decreased from 2008 to 2009.

### 4

• 

### AbitibiBowater did not report any dioxin distribution in 2008, but reported a water

release dioxin distribution in 2009.

• 

### Please confirm the 2009 facility-reported water dioxin dist ribution.

• 

### How did the facility determine the 2009 water dioxin distribut ion (i.e., does the facility now have available monitoring data for dioxin compounds)? no

• 

### If the facility used monitoring data to determine their wat er dioxin distribution, where was the monitoring conducted (e.g., final effluent) and how are non-detect results

included in the distribution?

RESPONSE:

There are two reasons the Coosa Pines mill dioxin number decreased in 2009. First, the mill experienced significant down time in 2009 as co mpared to 2008, which meant less coal was combusted in the boilers, so the overall emissions via air and land (ash), and water decreased, as dioxin releases are associated with combustion. Second, in 2008 and before, dioxin data reported by t he mill did not follow the distributions AF&PA previously provided EPA. In 2009, that distribution was used (monitoring data were not used to calculate the 200 9 distribution). The mill also monitors bleach plant effluent for 2,3,7,8-TCDD and 2 ,3,7,8-TCDF pursuant to its NPDES permit and has not reported those compounds in b leach plant effluent since

at least 2002.

Dioxin Compounds 2009 2008 2007 2006 2005

Pounds Released 0.0006 0.0008 NR NR NR
NR – Not Reported.

Congener

Number Chemical Name TWF 2009

Distribution (grams) 2009

Distribution (%)

1 Tetrachlorodibenzo

- p

- dioxin, 2,3,7,8

- 703,584,000 0.2013 65.46

2 Pentachlorodibenzo

- p

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

- 692,928,000 0 0

3 Hexachlorodibenzo

- p

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

- 23,498,240 0 0

4 Hexachlorodibenzo

- p

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

- 9,556,480 0 0

5 Hexachlorodibe nzo

- p

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

- 10,595,840 0 0

6 Heptachlorodibenzo

- p

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

- 411,136 0 0

7 Octachlorodibenzo

- p

- dioxin 6,586 0 0

8 Tetrachlorodibenzofuran, 2,3,7,8

- 43,819,554 0 0

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

- 7,632,640 0 0

10 Pentac hlorodibenzofuran, 2,3,4,7,8

- 557,312,000 0 0

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

- 5,760,000 0 0

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

- 14,109,440 0 0

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

- 47,308,800 0 0

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

- 51 ,204,160 0.1062 34.54

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

- 85,760 0 0

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

- 3,033,984 0 0

17 Octachlorodibenzofuran 2,021 0 0

### 5

3. Domtar Paper, Co. – Bennettsville, SC (29512WLLMTHWY91)

• 

### Domtar Paper’s reported pounds of dioxin did not change f rom 2008 to 2009.

• 

### Domtar Paper did not report any dioxin distribution in 2008, but reported a water release

dioxin distribution in 2009.

• 

### How did the facility determine the 2009 water dioxin distribut ion (i.e., does the facility now have available monitoring data for dioxin compounds)?

• 

### If the facility used monitoring data to determine their wat er dioxin distribution, where was the monitoring conducted (e.g., final effluent) and how are non-detect results

included in the distribution?

• 

### Domtar Paper’s reported pounds of dioxin did not change f rom 2008 to 2009.

RESPONSE:

First, it appears EPA has reversed the data in the last two columns of the table (2009 Distribution grams and percentage).

Second, the mill sampled its final effluent on October 15, 2002 for the 17 congeners for dioxin and furan. All 17 congeners were reported in the test results at less than or equal to their respective detection limits (DL), with the excep tion of 2,3,7,8-TCDF, which returned with a value of 6.2 ppq. All congeners, inc luding 2,3,7,8-TCDF, were calculated using the established convention of one-half the DL to calculate the grams per year value. The resultant total grams per year, whi ch is the total of all 17 congeners, therefore is actually a "less than or equal to" value, and is a conservative estimate. Since the 2002 reporting year, TRI calculatio ns have been based on the results of that single sample, and the mill has not un dertaken water dioxin congeners distribution monitoring since then (including in 2009 ).

Applying annual effluent discharge volumes of 5,376 mil lion gallons (MG) and 5,442 MG for 2008 and 2009, respectively, the mill calculated 0 .8657 grams/year (2008) and 0.8764 grams/year (2009) total dioxin based on efflue nt discharge.

The mill has not exceeded a dioxin/furan Cluster Rule limit since inception of testing. Further, it has had monthly non-detects for both 2,3,7, 8-TCDD and 2,3,7,8-TCDF since July 2003.

Dioxin Compounds 2009 2008 2007 2006 a 2005

Pounds Released 0.0 02 0.002 0.0018 0.002 0.002

TWPE 224,937 1,553 1,536 1,669 1,715

Congener

Number Chemical Name TWF 2009

Distribution (grams) 2009

Distribution (%)

1 Tetrachlorodibenzo

- p

- dioxin, 2,3,7,8

- 703,584,000 3.06 0.0268

2 Pentachlorodibenzo

- p

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

- 692,928,000 8.81 0.0772

### 6 3 Hexachlorodibenzo

- p

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

- 23,498,240 4.59 0.0402

4 Hexachlorodibenzo

- p

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

- 9,556,480 4.59 0.0402

5 Hexachlorodibenzo

- p

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

- 10,595,840 4.23 0.0371

6 Heptachlorodibenzo

- p

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

- 411,136 3.99 0.035

7 Octachlorodibenzo

- p

- dioxin 6,586 29.38 0.2575

8 Tetrachlorodibenzofuran, 2,3,7,8

- 43,819,554 7.28 0.0638

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

- 7,632,640 3.88 0.034

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

- 557,312,000 4.46 0.0391

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

- 5,760,000 3.88 0.034

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

- 14,109,440 3.64 0.0319

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

- 47,308,800 2.70 0.0237

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

- 51,204,160 2 .70 0.0237

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

- 85,760 3.29 0.0288

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

- 3,033,984 4.23 0.0371

17 Octachlorodibenzofuran 2,021 5.28 0.0463