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

2. Company Background One of the most modern newsprint mills in the world Newest newsprint paper machine in North America

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

4. Company Background 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

5. Spokane River PCB Source Assessment *Using EPA Method 1668A with a 100 pg/L PQL per congener

6. PCB Analysis at IEP

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

8. Production of PCB 11 2006 worldwide production of color organic pigments ~ 250M 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 )

9. Other PCBs in Pigments From Hu and Hornbuckle, 2010

10. Federal Regulations SUBCHAPTER R - TOXIC SUBSTANCES CONTROL ACT, PART 761 Manufacturing and processing of PCBs was banned under TSCA in 1979 …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 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)

11. PCB Paradox Reference PCB Concentration (ppm) Magnitude Difference Federal Allowance50---- IEP's Effluent0.000002420,833,333 WA Current HHWQC0.00000017294,117,647 EPA Current HHWQC0.000000064781,250,000 *Spokane Tribe WQS0.000000003414,836,795,252

12. What does this mean to IEP? 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:  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

13. 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 t-PCB Load Reduction Required to Meet Water Quality Criterion NTR (170 pg/l) Spokane Tribe (3.37 pg/l) NTR Spokane Tribe Stateline47776615 none required 97% Upriver Dam5377801597% Monroe St.1,4131,2082415%98% Ninemile2,2811,2432546%99% Little Spokane River9783215%98% Lake Spokane (lower)3,6641,5623157%99% Little Falls3,6641,5623157%99% Spokane Arm3,6641,5623157%99%

14. PCB Loading in Spokane River SourceLoad (mg/day) City of Spokane Stormwater 690 Stateline477 Spokane WWTP194 Little Spokane River 95 Kaiser65 Inland Empire Paper 45 Liberty Lake WWTP 2.9 Total Measured1569 Long Lake3,664 Measured 43% of Load City of Spokane Stormwater= 690 Idaho Washington Monroe Street Upper Falls Dam (RM 74.5) Ninemile Dam (RM 58.1) 477 Stateline (RM 96.1) Liberty Lake WWTP= 2.9 Little Spokane River= 97 Kaiser= 65= 65 354 (mid) 721 (bottom) Upriver Dam (RM 80.2) Inland Empire= 45 Long Lake Dam (RM 33.9) 1,413 2,281 3,664 Spokane WWTP= 194 Flow Total PCBs, mg/day

15. PCB Sources to Spokane River

16. NPDES Permits After a long and expensive DO TMDL battle, stakeholders worked together to develop more effective and immediate plan to improve WQ: S7. 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.” Termed “Straight to Implementation (STI)” Also effluent testing Method 1668 & BMP’s

17. Toxics Task Force (SRRTTF) Memorandum of Agreement 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)

18. Toxics Task Force (SRRTTF) Technical Workshop 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

19. Toxics Task Force (SRRTTF) 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 presentationswww.srrttf.org

20. Other Efforts 2010 Advance Notice of Proposed Rulemaking addressing PCB Reassessment of Use Authorizations 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

21. 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

22. Up to 200 known chemical processes that may inadvertently create PCB byproducts: 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 PCBs are Nationwide Issue

23. Questions?