HomeMy WebLinkAbout2026_06_10 DGinsberg_Clean AirFrom:David Ginsberg
To:Board of Health
Subject:Fwd: Safe Waterways and Clean Air 9for Port Townsend — Research and Invitation to Dialogue
Date:Wednesday, June 10, 2026 3:32:44 PM
Attachments:V_1.30_Safe_Water_Air_Port_Townsend.pdf
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---------- Forwarded message ---------
From: David Ginsberg <davidbginsberg@gmail.com>
Date: Wed, Jun 10, 2026, 3:27 PM
Subject: Safe Waterways and Clean Air 9for Port Townsend — Research and Invitation to
Dialogue
To: <community_relations@ptpc.com>, <abursky@atlasholdingsllc.com>,
<rob.kreizenbeck@ptpc.com>, <andy@atlasholdingsllc.com>,
<tfazio@atlasholdingsllc.com>, <jhudson@atlasholdingsllc.com>
Cc: Scott France <scott@jeffcobeacon.com>, <laura.johnson@doh.wa.gov>,
<ahoward@cityofpt.us>, <jmauro@cityofpt.us>, <JeffBoCC@co.jefferson.wa.us>,
<info@elwha.org>, <info@jamestowntribe.org>, <mady.lyon@ecy.wa.gov>, <epa-
seattle@epa.gov>, <neic-library@epa.gov>, <wafwo@fws.gov>, <info@orcaa.org>,
<Mike.Chapman@leg.wa.gov>, <Steve.Tharinger@leg.wa.gov>,
<Adam.Bernbaum@leg.wa.gov>, <publichealth@co.jefferson.wa.us>,
<dfirenze@ptleader.com>, <ThrivingEarthExchange@agu.org>
David Ginsberg
1240 W Sims Way #102
Port Townsend, WA 98368
davidbginsberg@gmail.com
415-342-7445
Safe Waterways and Air
safewaterandair@gmail.com
———
To: Rob Kreizenbeck, Chief Executive Officer, Crown Paper Group / Port Townsend Paper
Company
To: Bert Brown, Operations Manager, Port Townsend Paper Company
To: Andrew Bursky, Tim Fazio, Jacob Hudson — Managing Partners, Atlas Holdings
Dear Mr. Kreizenbeck, Mr. Brown, and Atlas Holdings leadership,
My name is David Ginsberg. I am a retired entrepreneur and business consultant and a Port
Townsend resident of ten years. I am not a scientist or an engineer. I am a neighbor who wants
safe waterways and clean air in the community where I live.
On May 27, 2026 — the day after eleven workers were killed at the Nippon Dynawave kraft
paper mill in Longview — I began reading the public record on this facility. What I found in
that first week troubled me deeply. In the two weeks that followed, my focus shifted. I spent
that time reading about what other American kraft pulp mills have done to substantially reduce
their pollution — and what the research shows is possible.
The attached document is the result of that research. It describes what the public record shows
about Port Townsend Paper Company's wastewater discharge, air emissions, and safety
conditions. It describes what American mills have demonstrated is achievable. And it asks,
genuinely, whether we can have a real conversation about what comes next.
I am not here to fight. I am here to ask what is possible — and whether we can find that out
together.
I have shared this document with elected officials, tribal governments, regulatory agencies,
and local media — not as a pressure tactic, but because I believe this conversation belongs in
the open. A written response to the questions in the attached document, shared publicly, would
mean a great deal to this community.
I am available by phone at 415-342-7445 or by email at davidbginsberg@gmail.com.
Sincerely,
David Ginsberg
1240 W Sims Way #102
Port Townsend, WA 98368
davidbginsberg@gmail.com
415-342-7445
Safe Waterways and Air
safewaterandair@gmail.com
Attachment: V_1.30_Safe_Water_Air_Port_Townsend.pdf
V_1.30 Safe Waterways and Air davidbginsberg@gmail.com June 2026 Page 1 of 15
Safe Waterways and Clean Air for Port Townsend
What the Public Record Shows, What Other Mills Have Achieved, and an Invitation to Work
Together
Prepared by David Ginsberg, Port Townsend, Washington davidbginsberg@gmail.com 415-342-7445 June 2026
Safe Waterways and Air
Who I Am and Why I Am Writing
My name is David Ginsberg. I am a retired entrepreneur and business consultant who has lived in Port
Townsend for ten years. I am not a scientist or an engineer. I am a neighbor who wants safe waterways
in Port Townsend Bay and clean air in the community where I live. That is the whole of my agenda.
On May 26, 2026, two weeks ago, eleven workers were killed at the Nippon Dynawave kraft paper mill
in Longview, Washington when a white liquor storage tank imploded. I had never looked closely at Port
Townsend Paper Corporation before that day. After Longview, I started reading: government
enforcement databases, permit documents, and federal health records. That first week produced letters
I sent to the Port Townsend City Council and the Jefferson County Board of Commissioners.
In the two weeks since those letters, my focus has shifted. I spent that time reading about what other
American kraft pulp mills have done to substantially reduce their pollution. I found documented results
at mills in North Carolina, Minnesota, and across the country. I also found international benchmarks
that show where this industry is heading globally. In Brazil, the CMPC Guaiba kraft pulp mill has
operated as a certified odorless facility since 2015. In Sweden, Svenska Cellulosa Aktiebolaget (SCA)
Containerboard's Obbola and Munksund mills became the first kraft mills in the world to achieve fully
fossil-free industrial operations, Munksund in 2015 and Obbola in 2022, by replacing oil-fired lime kilns
with biofuel-fired kilns. In Finland, the Metsa Fibre Kemi bioproduct mill started up in September 2023
on zero fossil fuels, achieving energy self-sufficiency of 159 percent in its first year of operation. I
mention these not as direct comparisons to Port Townsend Paper Company (PTPC), but because they
show that what American mills have been doing for decades is part of a global direction, not an outlier.
That research is the foundation of this document.
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Recycling Treated Water Back Into the Mill
This section addresses one of the most powerful and least understood opportunities available to PTPC.
Reducing the harm to Port Townsend Bay is not only about treating the water better before it is
discharged. It is also about how much water is discharged in the first place. These two strategies
multiply each other. Together they are far more powerful than either one alone.
The Arithmetic of Volume Reduction
PTPC discharges approximately 9.6 million gallons of treated wastewater per day into Port Townsend
Bay, approximately 3.5 billion gallons per year. Every pollutant in that water, including the three
confirmed carcinogens, reaches the bay multiplied by that enormous volume.
Consider a specific example. If a treatment system removed 90 percent of chlordane from the
wastewater before discharge, the remaining 10 percent would still travel into Port Townsend Bay in 3.5
billion gallons of water every year. But if the mill simultaneously reduced how much water it discharged
by recycling treated water back into the production process, the total mass of chlordane reaching the
bay would fall by a factor far greater than treatment alone could achieve.
Strategy Reduction in
Concentration
Reduction in
Volume
Reduction in Total Mass
Reaching the Bay
Treatment improvement alone 90%none 90%
Volume reduction alone none 44%44%
Treatment AND water recycling
combined 90%44%Over 94%
The 44 percent volume reduction figure is illustrative only. It is based on the documented water intensity record of 24.41 cubic
meters per ton of pulp at the CMPC Guaiba mill in Brazil, compared to an estimate of PTPC's current rate derived from publicly
available production and discharge figures. Port Townsend Paper Company's actual current water intensity per ton of pulp is
not in the public record. The 44 percent should be understood as an approximation of what is achievable based on the industry
benchmark, not a confirmed measurement of current performance. The 90 percent biochemical oxygen demand reduction
figure is drawn from peer-reviewed research. biochemical oxygen demand measures how much oxygen bacteria consume
breaking down organic waste in the water — high biochemical oxygen demand levels deprive fish and aquatic life of the oxygen
they need to survive. Activated sludge biological treatment at kraft mills achieves 85 to 98 percent biochemical oxygen demand
removal (IntechOpen, Pulp Mill Wastewater: Characteristics and Treatment, 2017; ScienceDirect Topics, Activated Sludge
Process).
V_1.30 Safe Waterways and Air davidbginsberg@gmail.com June 2026 Page 3 of 15
A greater than 94 percent reduction in the total mass of carcinogens reaching
Port Townsend Bay is not a theoretical possibility. It is the documented result of
combining treatment improvements that American mills have already
implemented with water recycling rates that an operating Brazilian mill has
already achieved.
V_1.30 Safe Waterways and Air davidbginsberg@gmail.com June 2026 Page 4 of 15
How Water Recycling Works in Practice
A kraft pulp mill uses water at dozens of different points in the production process, for different
purposes requiring different levels of water purity. Some uses, such as cooling heat exchangers or
washing equipment, can tolerate water with moderate residual content. Others, such as washing pulp
just before it is dried and sold, require cleaner water. A water recycling strategy matches the quality of
treated water to the demands of each use, routing the cleanest treated water to the most demanding
uses and progressively cleaner water to less demanding uses, while only discharging the small
concentrated residual that cannot be further recycled.
The treatment chain that makes this possible begins with primary physical treatment to remove solids,
followed by secondary biological treatment where microorganisms consume dissolved organic matter,
then tertiary advanced treatment using ozone or other oxidation processes to break down compounds
that biology cannot reach, and finally membrane filtration using nanofiltration or reverse osmosis to
produce water clean enough to return to the production process. A properly designed activated sludge
biological treatment system alone can reduce biochemical oxygen demand, the measure of how much
oxygen is consumed breaking down organic matter in the bay, by 85 to 98 percent at kraft pulp mills
(IntechOpen, Pulp Mill Wastewater: Characteristics and Treatment, 2017). The Sodra Cell Varo kraft
mill in Sweden implemented a full-scale biofilm-activated sludge system in 2002 that met all effluent
discharge limits. Adding tertiary ozone treatment achieves more than 90 percent reduction in chemical
oxygen demand combined. chemical oxygen demand measures the total organic pollutant load in the
water, including compounds that biological treatment cannot break down.
American mills have demonstrated what is achievable. A comprehensive study of US pulp and paper
mills documented a 30 percent reduction in total effluent discharge volume, a 75 percent reduction in
biochemical oxygen demand, and a 45 percent reduction in suspended solids, all achieved while
production was increasing (Das and Jain, 2001). These are not projections. They are measured results
at operating American facilities.
WHAT WE DO NOT KNOW
We do not know PTPC's current water use per ton of pulp produced, or whether recycling
treated water back into the production process has been evaluated. We are asking.
V_1.30 Safe Waterways and Air davidbginsberg@gmail.com June 2026 Page 5 of 15
What Can Be Done: Specific Opportunities and Questions
The following describes specific areas where the public record and research into comparable mills
suggest there are opportunities. For each one, my honest question is the same: Is this something you
are already doing? If so, we would welcome knowing that publicly. If it is feasible but not yet in place,
what would it take? If it is not feasible for your specific operation, we would genuinely like to understand
why, and what alternative approach might achieve comparable results.
Industrial Safety
On May 26, 2026, eleven workers were killed at Nippon Dynawave in Longview when a white liquor
storage tank imploded. Washington State Labor and Industries confirmed in Press Release 26-07,
issued June 1, 2026, that no Washington state agency had an established role in inspecting that tank.
PTPC operates the same category of equipment.
Has an independent, third-party structural inspection of every white liquor tank,
caustic storage tank, digester, and pressure vessel at this facility been conducted
since the Longview disaster? If so, were the results shared with Jefferson County
Emergency Management, the Local Emergency Planning Committee, and East
Jefferson Fire Rescue? If not, is that something PTPC would commit to?
A state-of-the-art facility installs permanent continuous monitoring on major tanks and pressure
vessels: ultrasonic thickness sensors, strain gauges detecting structural deformation, pressure
transducers with automatic alarm relay to first responders, and acoustic emission sensors detecting
micro-cracking. This technology is commercially available and in use at responsible industrial facilities
worldwide.
V_1.30 Safe Waterways and Air davidbginsberg@gmail.com June 2026 Page 6 of 15
Investment Who Provides It
Independent structural inspection of all white liquor
tanks, digesters, and pressure vessels by a licensed
mechanical or structural engineer
Acuren Industrial Services
(acuren.com/industries/pulp-paper) — certified for
kraft mill pressure vessels under American
Petroleum Institute 510 and American Petroleum
Institute 653 IIA Industrial Inspection and Analysis
(industrial-ia.com) — pulp and paper certified
inspectors Washington State L&I; fee schedule:
Washington Administrative Code 296-104-700
(effective July 1, 2025)
Permanent continuous monitoring sensors on all major
tanks and vessels — ultrasonic thickness, strain
gauges, pressure transducers, acoustic emission
sensors
Emerson Automation Solutions (emerson.com)
Honeywell Process Solutions (honeywell.com)
Yokogawa Electric (yokogawa.com)
Facility-specific quotation required
Automatic alarm relay system connecting tank
monitors to East Jefferson Fire Rescue dispatch
Facility-specific engineering scope — contact
licensed industrial automation contractor for
quotation
Annual joint training exercises between facility safety
personnel and East Jefferson Fire Rescue
Coordinated through Jefferson County Emergency
Management Contact: Willie Bence,
wbence@co.jefferson.wa.us
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Air Quality and the 14 Detected Compounds
Federal researchers detected 14 sulfur compounds in Port Townsend's air near this facility. Only 4 are
currently regulated. At CMPC Guaiba in Brazil, a system called ODOCON collects gases from more
than 100 individual emission sources across the entire mill, routing all of them to six redundant
incineration locations. A standard mill has two incineration locations. The Guaiba mill made a binding
public commitment to zero odor emissions and has met it since 2015.
Of the 14 sulfur compounds detected near this facility, how many are currently
collected and treated before reaching the surrounding neighborhood? Has a
comprehensive gas collection system covering all emission sources been
evaluated? Following the July 2022 event where a clog went undetected for 24
hours, were redundant backup systems added to ensure a single failure cannot
produce a community exposure event?
Continuous emissions monitoring systems from manufacturers including Thermo Fisher Scientific,
Ametek, and Emerson Process Management measure in real time and can stream data to a public
website. Fence-line air quality monitors placed at the property boundary tell neighbors what is actually
reaching the community, not just what is leaving the stack.
Investment Cost / Provider
Continuous emissions monitoring systems (continuous
emissions monitoring systems) on all major stacks —
measuring hydrogen sulfide, total reduced sulfur, SO2,
and fine particulate matter in real time every minute
Average installed cost: approximately $80,000 per
stack (Source: Market Reports World, Continuous
Emission Monitoring Systems market analysis,
2024) Manufacturers: Thermo Fisher Scientific,
Ametek, Emerson Process Management
Fence-line air quality sensor network — minimum four
stations at compass points around the facility
perimeter, measuring H2S, total reduced sulfur, SO2,
and particulate matter reaching the surrounding
neighborhood
Aeroqual AQS 1 and AQM 65 monitors —
purpose-built for industrial fence-line monitoring of
H2S and sulfur compounds (aeroqual.com) Acoem
Serinus 55 H2S Analyzer and Serinus 57 Total
Reduced Sulfur Analyzer — pulsed ultraviolet
fluorescent technology, the industry standard for
total reduced sulfur measurement at kraft mills
(metone.com) PurpleAir sensors measure
particulate matter only and are not appropriate for
kraft mill sulfur compound monitoring
Comprehensive mill-wide non-condensable gas
(non-condensable gas) collection system upgrade —
covering all emission sources with primary and backup
incineration locations
Valmet Mill-Wide non-condensable gas Solutions (
valmet.com/pulp/air-emission-control/odorous-gas-
control) ANDRITZ non-condensable gas Treatment
Systems (andritz.com) Facility-specific quotation
required — both suppliers have completed
non-condensable gas upgrades at comparable
kraft mills worldwide
V_1.30 Safe Waterways and Air davidbginsberg@gmail.com June 2026 Page 9 of 15
Water Discharge: Treating the Three Carcinogens
Three confirmed probable human carcinogens are present in the treated wastewater discharged into
Port Townsend Bay: benzo(a)anthracene, chlordane, and pentachlorophenol. Conventional biological
wastewater treatment, the kind most mills rely on as their primary system, does not meaningfully
reduce any of the three. They survive secondary treatment largely intact and reach the bay.
Peer-reviewed research documents specific technologies that do work against each one. The reduction
percentages below are drawn from published scientific studies.
Carcinogen Technology How It Works Documented
Reduction
Benzo(a)anthracene
United States
Environmental
Protection Agency
probable human
carcinogen
Ultraviolet C
irradiation (used in
municipal water
systems)
High-energy ultraviolet light breaks
apart the molecular structure of the
compound, destroying it rather
than simply moving it somewhere
else.
More than 99%
removal in 15
minutes. Source:
ScienceDirect
2020.
Chlordane EPA
probable human
carcinogen banned in
US since 1988
Granular activated
carbon (highly porous
filtering material)
The carbon's enormous surface
area adsorbs chlordane molecules
from the water, capturing them
before discharge. Spent carbon is
safely disposed of or regenerated.
More than 99%
removal from the
water column.
Source: World
Health
Organization;
water treatment
literature.
Pentachlorophenol EPA
probable human
carcinogen restricted in
US since 1987
Ozone treatment
(powerful oxidizing
gas that breaks
chemical bonds)
Ozone attacks and breaks apart
the chlorinated molecular
structure, converting
pentachlorophenol into
significantly less toxic intermediate
compounds.
Progressive
decomposition
into significantly
less toxic
compounds.
Source:
ScienceDirect
2006.
These technologies work best in layers. Primary physical treatment first, then secondary biological
treatment achieving more than 90 percent reduction in biological oxygen demand, then tertiary ozone
treatment adding a further 60 percent or more reduction in remaining organic pollutants, then granular
activated carbon capturing persistent compounds like chlordane, then membrane filtration producing
water clean enough to recycle back into the mill.
V_1.30 Safe Waterways and Air davidbginsberg@gmail.com June 2026 Page 10 of 15
Combined with water recycling, the arithmetic becomes compelling. A 99 percent reduction in
chlordane concentration combined with a 44 percent reduction in discharge volume produces a greater
than 99.4 percent reduction in the total mass of chlordane reaching Port Townsend Bay each year. Not
a modest improvement. A near-elimination of a banned carcinogen from Port Townsend Bay.
More than 99% removal of benzo(a)anthracene. More than 99% removal of
chlordane. Progressive destruction of pentachlorophenol. These are documented
results from peer-reviewed research. Combined with water recycling, total
carcinogen mass reaching Port Townsend Bay could fall by more than 99
percent.
What treatment is currently applied to benzo(a)anthracene, chlordane, and
pentachlorophenol before the water is discharged? Has granular activated
carbon filtration, ultraviolet C irradiation, or ozone treatment been evaluated for
this facility? What is the source of chlordane and pentachlorophenol in the
discharge of an unbleached mill that does not use either as a process chemical?
Would Port Townsend Paper Company be willing to commit to achieving the 2029
carcinogen limits now, voluntarily, rather than waiting for the regulatory
deadline?
V_1.30 Safe Waterways and Air davidbginsberg@gmail.com June 2026 Page 11 of 15
Investment Cost / Provider
Continuous real-time effluent monitoring station at the
discharge outfall — flow rate, pH, temperature,
dissolved oxygen, turbidity — with public data
streaming
Estimated cost: $75,000 to $150,000 for systems
processing comparable volumes (Source: Porvoo
Industrial Wastewater Cost Analysis, 2025,
porvoo.co) Manufacturers: YSI/Xylem, Hach,
In-Situ
Granular activated carbon (granular activated carbon)
tertiary treatment system — documented to remove
more than 99% of chlordane from wastewater before
discharge (World Health Organization; water treatment
literature)
Estimated cost: $400,000 to $1,500,000 or more
for complex multi-contaminant streams at high flow
volumes (Source: Anguil Environmental Systems,
published cost analysis, August 2025, anguil.com)
Supplier: Calgon Carbon Corporation (a Chemours
company), calgoncarbon.com
Ultraviolet C irradiation system — documented to
remove more than 99% of benzo(a)anthracene in 15
minutes (ScienceDirect, 2020). Ozone advanced
oxidation system — degrades pentachlorophenol into
less toxic compounds (ScienceDirect, 2006)
ultraviolet-C and ozone systems: facility-specific
quotation required based on flow volume and
contaminant load Contact: Oxidation Technologies
(oxidationtech.com)
Water quality monitoring buoy in Port Townsend Bay
— continuous measurement of temperature, dissolved
oxygen, pH, conductivity, and turbidity near the outfall,
data publicly accessible in real time
Manufacturer: YSI/Xylem monitoring buoy
platforms
(ysi.com/products/monitoring-buoys-and-platforms)
Facility-specific quotation required
Biennial crab and shellfish tissue sampling from
Marine Area 7 — to update the 2014 Washington
Department of Fish and Wildlife baseline study
Coordinated with Washington Department of Fish
and Wildlife Facility-specific quotation required
from a certified marine laboratory
Transparency Systems
A publicly accessible real-time environmental dashboard, operated by PTPC and independently
verified, would display air quality readings, effluent flow rate and key water quality parameters, Port
Townsend Bay water quality from a monitoring buoy, and tank and pressure vessel safety status.
Companies including Envirosuite, Enviro Technology Services, and Sonoma Technology build exactly
these dashboards for industrial facilities. Some kraft mills in Scandinavia already operate public
real-time air quality portals as a standard community relations commitment.
Would PTPC be willing to publish its environmental monitoring data in real time,
accessible to any community member with an internet connection? Would it be
willing to publish an annual plain-language environmental, health, and safety
report written for a general audience? Would it be willing to answer the questions
the Port Townsend Leader asked after the April 2025 spill?
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Investment Provider
Real-time public environmental dashboard —
displaying all monitoring data, updated every 15
minutes, accessible to any community member with an
internet connection
Envirosuite (envirosuite.com) — industrial
environmental intelligence platform Sonoma
Technology (sonomatech.com) — air quality
monitoring and data management Enviro
Technology Services (envirotech.co.uk)
Facility-specific quotation required
Annual plain-language Environmental, Health, and
Safety Report — written for a general audience,
published by March 31 each year, available in print at
Port Townsend Public Library
Facility-specific scope — contact environmental
communications consultants for quotation
Community Advisory Panel — quarterly meetings with
facility management, direct access to all monitoring
data, independent split sampling rights, tribal
representation
Facilitation and administration: contact industrial
community relations consultants Panel structure
guidance: US United States Environmental
Protection Agency Community Advisory Group
model (epa.gov)
Completing the Public Record
Before any new investment is made, PTPC could begin demonstrating good faith by completing what is
already missing. Seven questions on the 2018 State Environmental Policy Act checklist were left
unanswered. The Department of Health said a community health study cannot be completed because
data is missing. The Toxics Release Inventory relies on company self-estimates, not measured values.
Would PTPC be willing to answer the seven unanswered questions from the 2018
State Environmental Policy Act checklist? Would it provide the data identified as
missing in Department of Health Consultation 334-170? Would it replace Toxics
Release Inventory self-estimates with actual measured emissions values? Would
it commission the human health risk assessment that the 2014 crab tissue study
was designed to support?
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What We Are Not Asking
I want to be as clear about this as I am about everything else.
• I am not asking for the mill to close. Port Townsend Paper Corporation employs hundreds of
people in this county. Its closure would be an economic blow to families and to this community. That
is not what we want.
• I am not asking for anything that would harm the workforce. Every improvement described in this
document is an operational investment, not a cutback.
• I am not claiming that PTPC is doing nothing. I genuinely do not know what you are currently
doing, and that is precisely the transparency gap we are asking you to close.
• We are not claiming expertise we do not have. I am a neighbor who spent two weeks reading the
public record and found questions that deserve answers.
• I am not asking for anything that comparable American mills have not already done. Everything
described in this document is drawn from documented practice at operating facilities.
An Honest Invitation
PTPC has operated in this community for nearly a century. This community wants it here for another
century, and for that relationship to be one of genuine trust rather than managed uncertainty.
The people of Port Townsend, the Lower Elwha Klallam Tribe and the Jamestown S'Klallam Tribe who
hold treaty fishing rights in this bay, the workers inside this facility, and the marine life in Port Townsend
Bay all share something: they cannot choose to live somewhere else. The mill can choose how it
operates. That choice matters enormously.
The American mills I found in my research did not reduce their pollution because they were forced to.
They did it because they made a decision to be better neighbors. The results are documented,
published, and nationally recognized. That path is open to Port Townsend Paper Corporation too.
I am asking for a written response to the questions in this document, shared openly with the
community, the tribal governments, and the regulatory agencies copied on the cover letter. I am
available by phone at 415-342-7445 or by email at davidbginsberg@gmail.com. I am genuinely ready
to listen.
Sources and Citations
V_1.30 Safe Waterways and Air davidbginsberg@gmail.com June 2026 Page 14 of 15
The facts in this document are in the public record. The missing information is
what I am asking you to provide. The questions are genuine. The invitation is real.
I am ready to work with you.
All factual claims in this document are drawn from the following publicly available sources. No claim is made
about current Port Townsend Paper Corporation operations beyond what these sources document.
1. Washington State Department of Ecology: PTPC National Pollutant Discharge Elimination System Permit (2025).
Enforcement actions: Notice of Violation April 17, 2026; Notice of Violation (date confirmed as issued in May 2026); Notice
of Violation Docket 24681, June 4, 2026, addressed to Bert Brown, Mill Manager. Air quality penalty press release,
December 14, 2022. All documents available via Washington State Ecology PARIS system: apps.ecology.wa.gov/paris/
2. United States Environmental Protection Agency: Clean Air Act Consent Agreement with PTPC, penalty $342,000, reached
May 20, 2019. Source: Peninsula Daily News, June 9, 2019. Enforcement and Compliance History Online (Enforcement
and Compliance History Online) database, Facility Registry ID 110000490326.
3. Agency for Toxic Substances and Disease Registry (Agency for Toxic Substances and Disease Registry): Port Townsend
Paper Corporation Exposure Investigation, published June 2024, based on air monitoring data collected fall 2018.
Available at: atsdr.cdc.gov/HAC/pha/PortTownsendPaperCorp/Port-Townsend-HC-508.pdf
4. Washington State Department of Health: Consultation 334-170, PTPC.
5. Washington Department of Fish and Wildlife: 2014 Crab Tissue Study, Marine Area 7, Port Townsend Bay.
6. Good Jobs First Violation Tracker: Atlas Holdings penalty record. Available at:
violationtracker.goodjobsfirst.org/parent/atlas-holdings
7. Washington State Labor and Industries: Press Release 26-07, June 1, 2026, regarding the Nippon Dynawave disaster,
Longview, Washington.
8. Port Townsend Leader (Scott Doggett): 'Mill Keeps the Public in the Dark About Spill and Health Risks,' November 19, 2025;
'Has Watchdog Turned Lapdog at Port Townsend Paper Mill,' November 26, 2025.
9. Peninsula Daily News: PTPC settles with United States Environmental Protection Agency for violation of Clean Air Act, June
9, 2019.
10. Hewitt et al. (2008): 'Altered reproduction in fish exposed to pulp and paper mill effluents.' Environmental Toxicology and
Chemistry, 27(3), 682-697. Documents endocrine disruption in fish at mills not using chlorine bleaching.
11. 30-year Jackfish Bay study (2021): PMC 8101260. Documents endocrine disruption in wild fish receiving kraft mill effluent
over three decades.
12. American Forest and Paper Association: 2023 Leadership in Sustainability Award for Water Management, Sappi Cloquet
Mill, Minnesota. Source: BusinessWire, November 14, 2023.
13. Smoky Mountain News: 'Paper and the Pigeon: Canton mill's wastewater permit up for renewal,' February 24, 2021.
Documents Blue Ridge Paper and Evergreen Packaging environmental improvements.
14. Das and Jain (2001): US pulp and paper industry aggregate discharge reductions. Cited in: 'Treatment of pulp and paper
mill wastewater: a review,' ScienceDirect, July 2004.
15. World Health Organization: Chlordane in Drinking-water, background document World Health
Organization/SDE/WSH/03.04/84. Documents persistence and non-degradability of chlordane in water.
16. Photolysis study (benzo(a)anthracene ultraviolet-C removal greater than 99 percent): ScienceDirect article
S1001074220300322, February 2020.
17. Ozonation study (pentachlorophenol degradation): 'Oxidation and detoxification of pentachlorophenol in aqueous phase by
ozonation,' ScienceDirect, November 2006.
V_1.30 Safe Waterways and Air davidbginsberg@gmail.com June 2026 Page 15 of 15
18. Granular activated carbon chlordane removal: 'gamma-Chlordane in Tap Water' technical review,
softprowatersystems.com, September 2025, citing established water treatment literature.
19. Valmet Oyj: CMPC Guaiba pulp mill case studies (2020, 2022, 2025). Available at valmet.com. Documents odorless mill
operations since 2015, six combustion locations, and 100-plus source collection system.
20. CMPC Pulp: 'Achievements in Sustainability: Guaiba Unit records new historical record for water savings,' February 2024.
Documents 24.41 cubic meters per ton water intensity record.
21. Metsa Fibre sustainability reports (2023, 2024): Kemi bioproduct mill environmental performance, zero fossil fuels, 159
percent energy self-sufficiency. Available at metsagroup.com.
22. SCA press release: SCA, the first kraftliner manufacturer with fossil-free industrial processes, sca.com, 2022. Documents
SCA Obbola and Munksund mills achieving fossil-free industrial operations.
23. Valmet: SCA Munksund Paper Mill case study, fossil-free lime kiln, valmet.com, 2019.
24. Fastmarkets: How European pulp and paper mills adapted to the new energy transition reality, May 2023. Documents SCA
Containerboard fossil-free status.
25. IntechOpen: Pulp Mill Wastewater: Characteristics and Treatment, 2017. Documents 85 to 98 percent biochemical oxygen
demand removal in kraft mill activated sludge systems.
26. National Academies Press: Environmental Medicine: Integrating a Missing Element into Medical Education, Case Study 29.
Documents 1987 United States Environmental Protection Agency restrictions on pentachlorophenol.
27. US United States Environmental Protection Agency Hazard Summary: Pentachlorophenol. Available at epa.gov.
Documents United States Environmental Protection Agency Group B2 probable human carcinogen classification.
28. Washington State Department of Labor and Industries: Washington Administrative Code 296-104-700, Boiler and Pressure
Vessel Inspection Fee Schedule, effective July 1, 2025. Available at: app.leg.wa.gov/wac/default.aspx?cite=296-104-700
29. Mainardis et al., ScienceDirect, 2020 (Journal of Cleaner Production): Evaluation of ozonation applicability to pulp and
paper streams. Documents up to 81 percent chemical oxygen demand removal when ozone applied after biological
treatment.
V_1.30 Safe Waterways and Air David Ginsberg Port Townsend, Washington davidbginsberg@gmail.com June 2026