Inland Empire Paper Company Spokane River Forum Conference

Inland Empire Paper Company Spokane River Forum Conference The PCB Paradox March 26, 2013

Company Background One of the most modern newsprint mills in the world n Newest newsprint paper machine in North America n Inland Empire Paper Company

Company Background n Recently completed installation of a new system for processing waste chips ¡ Reduce natural gas consumption 77% (500 MCF) ¡ Reduce CO 2 by 30, 000 tons per year Inland Empire Paper Company wood by

Company Background n Integrated recycling facility installed in 1991 ¡ ¡ Paper produced at IEP can be made with up to 60% recycled materials Recycle over 120, 000 tons/year of ONP, magazines and office waste Inland Empire Paper Company

Spokane River PCB Source Assessment *Using EPA Method 1668 A with a 100 pg/L PQL per congener Inland Empire Paper Company

PCB Analysis at IEP Inland Empire Paper Company

PCB 11 Concentration in Consumer Goods One cereal box can contaminate ~ 2, 000 L of water to the WQS of 64 pg/L PCB 11 mostly associated with materials printed with yellow ink 38 ppb Collected in the US ND Collected from worldwide locations

Production of PCB 11 • 2006 worldwide production of color organic pigments ~ 250 M t • 25% of this production is diarylide yellow, containing a few ppb of PCB 11 • 65% of all diarylide yellow is used in printing • We estimate worldwide production of PCB 11 ~ 1. 5 metric tons in 2006 (Rodenburg et al. 2009, ES&T )

Other PCBs in Pigments From Hu and Hornbuckle, 2010 Inland Empire Paper Company

Federal Regulations SUBCHAPTER R - TOXIC SUBSTANCES CONTROL ACT, PART 761 n Manufacturing and processing of PCBs was banned under TSCA in 1979 n …pigments that contain 50 ppm or greater PCB may be processed, distributed in commerce, and used in a manner other than a totally enclosed manner until January 1, 1982… 40 C. F. R. § 761. 3 (g), Reserved after 1999 n The concentration of inadvertently generated PCBs in products leaving any manufacturing site or imported into the United States must have an annual average of less than 25 ppm, with a 50 ppm maximum” 40 C. F. R. § 761. 3 (1) Inland Empire Paper Company

PCB Paradox Reference PCB Concentration (ppm) Magnitude Difference Federal Allowance 50 ---- IEP's Effluent 0. 0000024 20, 833, 333 WA Current HHWQC 0. 00000017 294, 117, 647 EPA Current HHWQC 0. 000000064 781, 250, 000 *Spokane Tribe WQS 0. 000034 14, 836, 795, 252 Inland Empire Paper Company

What does this mean to IEP? n n Currently there are no technologies available to achieve any of these WQS Elimination of recycling may be our only viable option Likely impact the balance of our industry, resulting in the elimination or reduction of recycling in our country We have not solved the problem: ¡ ¡ n n Put into landfill, it still exists Incineration, opportunity to disperse into the atmosphere Transferring the cost to others and willfully allowing the continued contamination of our environment is not a solution Best solution is the elimination of this source of PCB’s that continues to enter our environment Inland Empire Paper Company

Reductions Needed to Meet Standards Location on Spokane River Current t-PCB Load (mg/day) Target t-PCB Load (mg/day) at Water Quality Criterion NTR (170 pg/l) Spokane Tribe (3. 37 pg/l) t-PCB Load Reduction Required to Meet Water Quality Criterion NTR Spokane Tribe Stateline 477 766 15 Upriver Dam 537 780 15 Monroe St. 1, 413 1, 208 24 15% 98% Ninemile 2, 281 1, 243 25 46% 99% Little Spokane River 97 83 2 15% 98% Lake Spokane (lower) 3, 664 1, 562 31 57% 99% Little Falls 3, 664 1, 562 31 57% 99% Spokane Arm 3, 664 1, 562 31 57% 99% Inland Empire Paper Company none required 97%

PCB Loading in Spokane River Total PCBs, mg/day Idaho 477 Stateline (RM 96. 1) Washington Liberty Lake WWTP= 2. 9 Kaiser= 65 Inland Empire= 45 354 (mid) 721 (bottom) Upriver Dam (RM 80. 2) City of Spokane Stormwater= 690 1, 413 Spokane WWTP= 194 Monroe Street Upper Falls Dam (RM 74. 5) Flow 2, 281 Ninemile Dam (RM 58. 1) Little Spokane River= 97 3, 664 Source Load (mg/day) City of Spokane Stormwater 690 Stateline 477 Spokane WWTP 194 Little Spokane River 95 Kaiser 65 Inland Empire Paper 45 Liberty Lake WWTP 2. 9 Total Measured 1569 Long Lake 3, 664 Long Lake Dam (RM 33. 9) Measured 43% of Load

PCB Sources to Spokane River Inland Empire Paper Company

NPDES Permits n After a long and expensive DO TMDL battle, stakeholders worked together to develop more effective and immediate plan to improve WQ: n S 7. REGIONAL TOXICS TASK FORCE: “The goal of the Regional Toxics Task Force is to develop a comprehensive plan to bring the Spokane River into compliance with applicable water quality standards for PCBs. ” n n Termed “Straight to Implementation (STI)” Also effluent testing Method 1668 & BMP’s Inland Empire Paper Company

Toxics Task Force (SRRTTF) Memorandum of Agreement n n n n City of Spokane (Wastewater & Stormwater) Inland Empire Paper Company Kaiser Aluminum Lake Spokane Association Liberty Lake Sewer and Water District Spokane County (Utilities & Stormwater) Spokane Regional Health District Spokane Riverkeeper The Lands Council Washington State Department of Health Coeur d’Alene Tribe of Indians U. S. Environmental Protection Agency Idaho Department of Environmental Quality Washington State Department of Ecology Idaho Municipal Dischargers (Coeur d’Alene, Post Falls and Hayden) Inland Empire Paper Company

Toxics Task Force (SRRTTF) Technical Workshop n n National experts on PCBs Work in other watersheds: ¡ ¡ ¡ Delaware River Basin Hudson River & NY/NJ Harbor Indiana Harbor to Lake Michigan Puget Sound Lower Duwamish Portland Harbor Inland Empire Paper Company

Toxics Task Force (SRRTTF) n Technical Workshop What did we learn: ¢ ¢ ¢ ¢ Most watersheds are dealing in ppm and pounds, we are dealing with ppq and grams Atmospheric deposition by itself will likely cause exceedance of WQS Rainwater has been measured at concentrations >100 ppq Snow is 100 times more effective than rain at scavenging PCBs Stormwater in our basin is largest known contributor +90% of PCB’s in Spokane River samples are in dissolved phase Total PCB levels below 1, 000 pg/L are variable and highly blank influenced See www. srrttf. org for archive of presentations Inland Empire Paper Company

Other Efforts n 2010 Advance Notice of Proposed Rulemaking addressing PCB Reassessment of Use Authorizations ¢ n IEP submitted comments in collaboration with the Spokane Riverkeepers and the Lands Council ECOS ¢ ¢ Collaborative presentations with Riverkeepers & Rutgers Resulted in a Resolution from the ECOS Committee Inland Empire Paper Company

ECOS Resolution ¡ Recommends that EPA, industry, and states work together to develop alternative pigment and ink manufacturing processes in the next five years that do not generate PCBs; ¡ Supports a national R & D effort to reduce or eliminate inadvertently -created PCB products; ¡ Supports EPA’s proposed rulemaking to reassess the current use authorizations for PCBs, which includes products with PCBs and products with inadvertently-generated PCBs; ¡ Recommends that U. S. EPA continue its efforts to reduce PCBs and work with the international community on the elimination of PCBs Inland Empire Paper Company

PCBs are Nationwide Issue n Up to 200 known chemical processes that may inadvertently create PCB byproducts: ¢ ¢ ¢ ¢ n n Paint Inks Titanium Dioxide (white pigments) Ag chemicals Plastics Soaps Silicone rubber Caulk measured up to = 300, 000 ppm 2010 – 1, 084 fish advisories for PCB’s in 40 States 5, 578 water bodies on 303(d) list for PCBs Many States are adopting revised FCR n Inland Empire Paper Company

Questions?