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 labeled “Secondary Effluent”, but Jim has confirmed 

that the data comes from testing of the final effluent 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 facility. 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 the 

secondary effluent the final effluent (e.g., the same effluent point that the flow data represents), or is it 

an internal sampling point? 

2. If it is an internal sampling point, are other wastewaters commingled with the process wastewater 

stream prior to discharge? 

3. Do you know the dioxin concentrations at the final effluent? Are they non-detect? 

 

If you have any questions or find it easier to discuss via phone, please call me at 703-633-1659. I 

appreciate your help in interpreting this data correctly. 

 

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>, "Jerry Schwartz" 

<Jerry_Schwartz@afandpa.org>, <Swietlik.William@epamail.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.xlsx 
Response 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.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 Fibre Paper & Packaging, 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 in 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 sampling data and 

corresponding flow data. 

 

Simpson: 

 

Please provide a copy of the 2008 and 2009 dioxin sampling data. Also, 

please provide corresponding flow data. Please note whether this flow 

data is for the final outfall or another internal outfall. If internal, 

please explain. 

 

Again, we appreciate your help in clarifying the TRI 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>, "Eleanor 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 Summary.doc 

Bill et al: Thanks again for extending your deadline for us to respond 

to your request for clarification. Attached are responses for three of 

the four mills. Unfortunately, despite my best efforts, I did not 

receive responses from personnel representing the fourth company. 

Please let me know if I can be of further assistance 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 requesting clarification of 

2009 TRI dioxin data for four Pulp and Paper facilities as part of our 

2011 annual review of industrial discharges under Section 304 of the 

Clean Water Act. 

Specifically, we would like to clarify the amount of dioxin and 

dioxin-like compound releases and the congener distribution reported to 

the 2009 TRI from the following Pulp and Paper plants (see detailed 

document attached): 

1. Longview Fiber Paper & Packaging, Inc.; 2. AbitibiBowater, Inc.; 3. 

Simpson Tacoma Kraft, Co., LLC; and 4. Domtar Paper Co. 

In 2008, these four Pulp and Paper facilities did not report a water 

congener distribution specific to their facility (i.e., they left the 

field blank). For our database purposes, EPA assigned the designated 

Pulp and Paper congener distribution provided previously by AF&PA. In 

2009 however, these facilities reported water congener distributions 
specific to their facility. The reported distributions differ from 

AF&PA designated distributions. The attachment to this email provides 

the detailed congener distribution information. EPA 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 TRI dioxin data 

correctly. 

Please return the requested information to Elizabeth Sabol of ERG via 

e-mail at elizabeth.sabol@erg.com, or to me directly if you prefer. 

If you have questions regarding this request, you may 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 request, 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 Pennsylvania 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 (98632LNGVWSOUTH) 

• Longview’s reported pounds of dioxin did not change from 2008 to 2009. 

• Longview 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 distribution. 

• How did the facility determine the 2009 water dioxin distribution (i.e., does the facility 

now have available monitoring data for dioxin compounds)? 

• If the facility used monitoring data to determine their water 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 conservative assumptions. Recent 

(2008-2010) final effluent 2,3,7,8 TCDD data generated 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 assumptions were not based on water 

dioxin distribution data. (Also note that the company name is Longview Fibre...) 

Dioxin 

Compounds 2009 2008 2007 2006 2005 

Pounds Reported 0.004 0.004 0.005 0.005 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 0.053 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 Hexachlorodibenzo-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 Pentachlorodibenzofuran, 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 Fibre 

Paper & Packaging, 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 in 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 sampling data and corresponding flow data. 

 

Simpson: 

 

Please provide a copy of the 2008 and 2009 dioxin sampling data. Also, please provide corresponding 

flow data. Please note whether this flow data is for the final outfall or another internal outfall. If internal, 

please explain. 

 

Again, we appreciate your help in clarifying the TRI 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 can 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 effluent. 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 following 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 data) 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 estimates were used. They were very 

conservative estimates as you can see from my own calculations 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 distribution. 

• How did the facility determine the 2009 water dioxin distribution (i.e., does the facility 

now have available monitoring data for dioxin compounds)? no

• If the facility used monitoring data to determine their water 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 compared 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 the 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 2009 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 bleach 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 Hexachlorodibenzo-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 Pentachlorodibenzofuran, 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 from 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 distribution (i.e., does the facility 

now have available monitoring data for dioxin compounds)? 

• If the facility used monitoring data to determine their water 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 from 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 exception of 2,3,7,8-TCDF, which 

returned with a value of 6.2 ppq. All congeners, including 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, which 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 calculations have been based on the 

results of that single sample, and the mill has not undertaken water dioxin congeners 

distribution monitoring since then (including in 2009). 

 

Applying annual effluent discharge volumes of 5,376 million 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 effluent 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 a2005 

Pounds Released 0.002 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