<<
EPA
Questions
2002
discharge.
doc>>

Jim
Ketchum
Kimberly
Clark
Worldwide
Everett,
WA
98201
425­
259­
7308
jketchum@
kcc.
com
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Thank
you.

Your
company
reported
releasing
8.19
grams
of
dioxin
and
dioxin­
like
compounds
to
surface
water
(
Everett
Harbor)
in
TRI
in
2002.
Your
company
reported
that
the
basis
of
estimate
for
this
discharge
was
mass
balance
calculations.

Could
you
please
explain
how
the
mass
balance
was
calculated?

The
Pulp
Mill
Bleach
Plant
and
No.
14
Wood
Waste
Boiler
are
the
site's
dioxins
sources.
Using
mill
specific
data
collected
over
a
5
year
period,
emission
factors
were
determined
for
each
source.
Again
using
mill
specific
data,
it
was
determined
where
the
dioxins
were
dispersed.
Using
this
data,
stream
partition
factors
were
calculated.
These
factors
are
used
to
determine
the
path
dioxins
exiting
the
two
sources
will
follow.

In
2002,
did
your
company
ever
analyze
any
wastewater,
either
an
in­
plant
stream,
such
as
bleach
plant
effluent,
or
the
final
discharge
to
Everett
Harbor?

Yes,
24
hour
composites
were
analyzed.

If
they
did,
were
any
of
the
dioxins
ever
detected?

Full
congener
spectrum:
Primary
Treatment
Outfall
001
=
68.3
pg/
L
Primary
Treatment
Outfall
003
=
36.9
pg/
L
Secondary
Treatment
Outfall
008
=
15.95
pg/
L
2,3,7,8­
TCDD,
TCDF
only:
Bleach
Plant
Effluent
TCDD
=
ND
TCDF
=
35.3
pg/
L
How
did
your
company
determine
the
wastewater
flow
associated
with
the
dioxin
discharges?

In
2002,
the
flow
exiting
Outfalls
001
and
008
were
continuously
monitored.
The
Primary
Treatment
Outfall
003
flow
was
the
difference
between
the
continuously
monitored
raw
water
flow
into
the
facility
and
the
sum
of
the
flows
exiting
the
site
(
001
and
008).
Did
the
mass
balance
account
for
the
transfer
of
dioxins
generated
in
any
combustion
device
to
wastewater?

The
wood
waste
boiler
ash
is
the
facility's
primary
source
of
dioxins.
The
mass
balance
accounts
for
this
source.

If
you
need
any
additional
information
I
can
be
reached
by
e­
mail
or
at
(
703)
633­
1698.

Thank
you,

TJ
Finseth
