[]TL: Comments on Ark NPDES Permits for IP & GP Mills (GP) SO: Pat Costner, Greenpeace USA DT: 7-JAN-91 Keywords: toxics effluent pulp greenpeace groups reports us gp arkansas georgia pacific international paper business / [part 1 of 14] GREENPEACE U.S.A. January 3, 1991 TO: ARKANSAS DEPARTMENT OF POLLUTION CONTROL AND ECOLOGY RE: PROPOSED INDIVIDUAL CONTROL STRATEGIES AND MODIFICATIONS TO WASTEWATER DISCHARGE PERMITS OF THE FOLLOWING FACILITIES: GEORGIA PACIFIC CORPORATION, CROSSETT, ARKANSAS AND INTERNATIONAL PAPER CORPORATION, PINE BLUFF, ARKANSAS Proposed wastewater discharge permit modifications, prepared and presented for public review and comment by the Arkansas Department of Pollution Control and Ecology (ADPC&E), authorize Georgia Pacific Corporation and International Paper Corporation, two bleached kraft pulp and paper mills, to discharge the following quantities of 2,3,7,8-tetrachlorodibenzo-p-dioxin (2,3,7,8-TCDD) into Coffee Creek and the Arkansas River, respectively: ----- Proposed Permissible Daily Discharge of 2,3,7,8-TCDD, Based on Allowable Concentrations in Treated Effluent Maximum Concentration Maximum Daily Daily Discharge in Effluent, Flow, of 2,3,7,8-TCDD, picograms per liter gallons per day picograms per day Georgia Pacific 0.32 65 million 78.7 million International 3.06 27 million 312.7 million Paper ----- According to U.S. EPA, a lifetime intake of 0.420 picograms per day of 2,3,7,8-TCDD for an adult of average size may be associated with an increased cancer risk of one in one million, the level of risk commonly regarded as tolerable by federal and state agencies. On this basis, the above quantities of 2,3,7,8- TCDD are sufficient to meet or exceed such an `acceptable daily intake' for the number of people shown below, presented as `person-doses': [Greenbase Inventory October 27, 1991 ] =======[#]======= []TL: Comments on Ark NPDES Permits for IP & GP Mills (GP) SO: Pat Costner, Greenpeace USA DT: 7-JAN-91 Keywords: toxics effluent pulp greenpeace groups reports us gp arkansas georgia pacific international paper business / []TL: Comments on Ark NPDES Permits for IP & GP Mills (GP) SO: Pat Costner, Greenpeace USA DT: 7-JAN-91 Keywords: toxics effluent pulp greenpeace groups reports us gp arkansas georgia pacific international paper business / [part 2 of 14] Proposed Permissible Daily Discharges of 2,3,7,8-TCDD in `Person-Doses' per Day Based on Allowable Concentrations in Treated Effluent Facility Picograms `Person-Doses' Lifetime `Pers per Day per Day* per Year** Georgia Pacific 78.7 million 187 million 2.7 million International 312.7 million 744 million 10.6 million Paper ----- In other words, based on the stated effluent limits, ADPC&E is proposing to allow the Georgia Pacific pulp mill to discharge a quantity of 2,3,7,8-TCDD, commonly referred to simply as `dioxin,' into Coffee Creek that exceeds an `acceptable' lifetime dose of dioxin for more than two million people. Similarly, the Department proposes that the International Paper mill be allowed to discharge a quantity of dioxin that exceeds an `acceptable' lifetime dose for more than ten million people. ADPC&E has, however, specified in the draft permits a method for the analysis of the mills' effluents that has a minimum detection limit of 10 picograms per liter. I.e., the analytical method specified is too insensitive to measure the 2,3,7,8-TCDD concentration limits the Department proposes to impose on Georgia Pacific of 0.32 picograms per liter and International Paper of 3.06 picograms per liter. Indeed, ADPC&E stipulates, in the draft permits, that all samples having 2,3,7,8-TCDD values that fall below the minimum detection limit of 10 picograms per liter will be assumed to contain `zero' 2,3,7,8-TCDD. Because of this limited analytical method and the Department's stipulations, the two pulp mills will actually be allowed to discharge the following quantities of 2,3,7,8-TCDD, while reporting `zero discharge' of this dioxin: ----- Actual Proposed Allowable Daily Discharge of 2,3,7,8-TCDD, based on a minimum detection limit of 10 picograms per liter Facility Picograms `Person-Doses' Lifetime `Person-Doses' per Day per Day* per Year** Georgia Pacific 2.46 billion 5.86 billion 83.7 million -------------------- * Assuming an average adult weight of 70 kilograms, or 154 pounds. ** Based on an average adult, weighing 70 kilograms [154 pounds] and an average lifetime of 70 years, which yields an `acceptable' lifetime dose of 2,3,7,8-TCDD of 10,731 picograms. * Assuming an average adult weight of 70 kilograms, or 154 pounds. ** Based on an average adult, weighing 70 kilograms [154 pounds] and an average lifetime of 70 years, which yields an `acceptable' lifetime dose of 2,3,7,8-TCDD of 10,731 picograms. International 1.02 billion 2.43 billion 34.7 million Paper ----- For the protection of fish, wildlife and the general public, the dispersal into Arkansas waterways of such quantities of dioxin must be regarded as intolerable. Likewise, the dioxin in pulp mill discharges is accompanied by even larger quantities of other complex organochlorines which, although known to be present in the effluent of these pulp mills, are not addressed in these proposed permit modifications or Individual Control Strategies, [part 3 of 14] GENERAL COMMENTS 1 > The Arkansas Department of Pollution Control and Ecology (rovide the public with that information essential for an infohe adequacy of the proposed permit limitations and the ICSs. For example, neither the fact sheets accompanying the draft permits nor the draft permits themselves offer the following vital information + quantities of 2,3,7,8-TCDD currently discharged; + quantities of total polychlorinated dioxins and furans currently discharged, expressed as individual congeners or groups of congeners or as toxic equivalents (TEQs) of 2,3,7,8-TCDD; + quantities of total organohalides currently discharged, determined as total absorbable organohalides (AOX); + quantities of total polychlorinated dioxins and furans, expressed as individual congeners or as TEQs, present in fish captured downstream from the mills, as measured in the National Bioaccumulation Study (NBS) and/or subsequent studies. + Identification of wastewaters discharged at all outfalls, e.g., process wastes, cooling water, etc. The most basic information required by ADPC&E and the public is a chlorine mass balance: the quantities and chemical forms of chlorine used; the quantities and chemical forms of chlorine released; and the fate of such released chlorine -- wastewater discharge, vent to air, incorporation in pulp, incorporation in sludge and/or ash from sludge incineration. Without this mass balance data, neither ADPC&E nor the public can determine the degree to which remediation measures may simply shift 2,3,7,8- TCDD and other organochlorine contaminants from one environmental medium to another rather than achieving a true reduction in the generation of these chlorinated contaminants. Current dioxin/furan and AOX data surely exist for these mills, and should have been provided to the public. Yet, either the information was not solicited from the mills or ADPC&E neglected to release it to the public. In either case, ADPC&E's failure to provide this information to the public and the Department's apparent failure to integrate such information into the decisionmaking process whereby these draft permits were prepared necessitates withdrawal and subsequent further modification of the draft permits prior to their resubmission to the public for comment. Given the lack of this most basic information, we petition the Department to suspend reissuance of these permits until all pertinent information has been gathered and/or examined by ADPC&E and, subsequently, made available to the public. 2 > ADPC&E has failed to develop ICSs or permit modifications that protect public health and the environment from the harmful effects of the hundreds of chlorinated contaminants discharged by chlorine-bleaching pulp and paper mills. To achieve this essential end, ADPC&E must develop and enforce regulations that address not only 2,3,7,8-TCDD but also total organochlorine discharges, expressed as AOX. Further, such organochlorine limits must be of sufficient stringency to meet the definition of Best Available Technology (BAT). Some states have existing and proposed limits of roughly 1.5 kg AOX per ton of bleached pulp. Such limits are, however, not sufficiently stringent to meet the requirements of federal law. In particular, such permits fail to meet the technological standard for BAT. AOX is a nonconventional pollutant under the Clean Water Act, Section 301(b)(2)(F). [Subparagraphs (b)(2)(C), (D), (E), and (F) of this provision divide pollutants into three categories: toxics (subparagraphs C and D), conventional (subparagraph E), and all others (subparagraph F) labeled "nonconventional". AOX is neither a category C nor a category D pollutant. Pollutants in category E are the "conventional" pollutants. Category F applies to AOX because none of the other three does.] Nonconventional pollutants under section 301(b)(2)(F) are subject to technology- based effluent limitations under the Best Available Technology standard. 301(b)(2). []TL: Comments on Ark NPDES Permits for IP & GP Mills (GP) SO: Pat Costner, Greenpeace USA DT: 7-JAN-91 Keywords: toxics effluent pulp greenpeace groups reports us gp arkansas georgia pacific international paper business / [part 4 of 14] In issuing permits governing discharges of nonconventional pollutants, ADPC&E must apply the "same factors that must be considered in establishing the national effluent limitations." Natural Resources Defense Council v. U.S.Environmental Protection Agency, 863 F.2d 1420, 1425 (9th Cir. 1988); see, also 40 CFR Sections 123.25(a)(37) and 125.3(d)(3). Obviously, this means that in drafting the permits, ADPC&E must set the effluent limitations at the Best Available Technology level. The factors that are "to be taken into account" in determining BAT effluent limitations are listed at Section 304(b)(2)(B) and 40 CFR Section 125.3(d)(3). They are: the age of the equipment and facilities involved, the process employed, the engineering aspects of the application of various types of control techniques, process changes, the cost of achieving such effluent reduction, non-water quality environmental impact (including energy requirements).... Effluent limitations based upon the best available technology standard should be implemented with reference to the best performing plant in the industry, as ruled in Kennecott v. United States, 780 F.2d 445, 448 (4th Cir. 1985). The exemplary plant need not be located within this country, as ruled in American Frozen Food Institute v. Train, 539 F.2d 107, 132 (D.C. Cir. 1976). For kraft mills, the best-performing plants in the United States are Procter and Gamble in Oglethorpe, Georgia, producing fluff pulp while achieving an AOX discharge level of under 0.5 kg/ADT, and the Union Camp fine papers mill in Franklin, Virginia, using an O-Z-E-D bleaching sequence to achieve AOX levels well below 0.5 kg/ADT. Kraft pulp mills in Europe (see table) making a variety of high brightness paper products are achieving annual AOX discharge levels of 0.5 or lower. In the absence of compelling reasons for the inability of the mills in Arkansas to attain the same low levels of AOX discharge, under federal law, DPC&E must impose annual AOX discharges of 0.5 or less for all Arkansas kraft and sulfite mills. The exemplary plants, kraft and sulfite, are achieving low AOX numbers through a combination of oxygen-based technologies. The specific application of the best available technology may involve numerous changes in the pulp manufacturing process, including oxygen delignification, oxygen reinforced extraction, hydrogen peroxide bleaching, ozone, and for some kraft mills, continued use of at least some chlorine dioxide, though not necessarily any in the first bleaching phase. These and other innovations permit kraft mills to produce high brightness pulps with either no AOX discharges or discharges as low as 0.5 kg/ADT. We refer ADPC&E, first, to the 1988 Ontario MISA report prepared by McCubbin, Sprague, and Bonsor in which data was presented in support for setting an AOX level of 1.5 kg for kraft mills. Further, however, we refer ADPC&E to a more recent report in which McCubbin says that the earlier report's recommendation for a level of 1.5 AOX by 1993 is "now laughably outdated," based on "the rapid development of acknowledge in this field." 1 Significantly, because mills outside the United States are competing to produce pulp products that they can market as "environmentally friendly," McCubbin states that the only way to take "maximum account of the latest technology" is to consider what the industry is saying and doing -- not to rely on outdated published literature. McCubbin therefore presents data both from recent technical presentations at technical conferences in Seattle, Canada, and Finland in 1990, and from his own investigations of North American pulp mills. []TL: Comments on Ark NPDES Permits for IP & GP Mills (GP) SO: Pat Costner, Greenpeace USA DT: 7-JAN-91 Keywords: toxics effluent pulp greenpeace groups reports us gp arkansas georgia pacific international paper business / [part 5 of 14] McCubbin's report demonstrates that the AOX level of 1.5 kg/tonne chosen by DOE is, in his words, "laughable." Rather, an effluent level even for non-alternatively bleached pulp based on BAT is at most in the range of 0.4 kg AOX/ADT. And, considering alternative bleaching technologies, and the lack of particular products that require full bleaching at all, the appropriate levels can and should be significantly lower. There is no question that oxygen-based bleaching methods are an available technology for the elimination of organochlorine pollution. The Clean Water Act does not require that the technology be widely used. Nor is it something that has to be easily affordable for the discharger. Indeed, it is not appropriate for ADPC&E to engage in a cost-benefit analysis in determining BAT. That is, as ruled in Association of Pacific Fisheries v. E.P.A., 615 F. 2d 794, 818 (9th Cir. 1980), the permit may not relax the best available technology standard merely because the costs to comply will be high: Only where the costs to comply are unreasonable may ADPC&E issue a permit that does not fully implement the technology standard. In the case of conversion to chlorine-free bleaching, the technology is not only available and affordable, it is likely cost effective. 2 Many, if not most of the mills that use oxygen bleaching do so to save bleaching costs -- oxygen is cheaper than chlorine. The switch to chlorine-free bleaching is mandatory under the Clean Water Act, and in many cases will be a good investment for the pulp mills. Even U.S. EPA has noted, in its draft risk assessment of fish contamination in the Columbia River that in the case of the pulp and paper industry "BACT seems to be oxygen delignification". 3 Arkansas law allows no wastewater to be discharged in this state that has not been subjected to treatment under the relevant technological standard. Nor is ADPC&E's apparent dismissal of applicable antidegradation laws for permits allowing more pollution justified. Arkansas law implements the antidegradation requirement of the federal Clean Water Act, which establishes water quality sufficient to support beneficial uses as the "absolute floor" for the nation's water. See, e.g., EPA, "Questions & Answers On: Antidegradation" (1986). Indeed, as described clearly at 40 CFR 131.12, even where water quality exceeds this floor, degradation may occur only where "necessary to accommodate important economic or social development in the area in which the waters are located." In short, before any mill in Arkansas is allowed to discharge dioxin and other organochlorines into state waters, the state must meet two standards: First, "all known, available methods of treatment" must be applied. Second, the waters cannot be degraded unless "necessary to accommodate important economic or social development," and cannot be degraded at all if water quality is already below that necessary to support beneficial uses. []TL: Comments on Ark NPDES Permits for IP & GP Mills (GP) SO: Pat Costner, Greenpeace USA DT: 7-JAN-91 Keywords: toxics effluent pulp greenpeace groups reports us gp arkansas georgia pacific international paper business / [part 6 of 14] Neither of these determinations have been made nor can they be made for Arkansas' mills. Cleaner and ecologically productive waters are essential to the economy of this region, for tourism, fishing and recreation. No case has been or can be made for allowing these interests to be ignored for the pulp and paper industry. Nor can the industry itself justify degrading water quality, given that technology exists to reduce significantly -- indeed, in many instances, to avoid altogether -- organochlorine discharges. Finally, the lack of compelling need to bleach most pulp and paper products from these mills also demonstrates the lack of necessity to allow continued pollution and degradation of Arkansas' waters; certainly it is not "clear that overriding considerations of [the] public interest will be served" by such discharges. 3 > ADPC&E has failed to require timely compliance for proposed 2,3,7,8-TCDD limitations. The draft permits grant improper compliance deadlines. Limits for 2,3,7,8-TCDD and AOX must be imposed in the shortest reasonable time necessary to achieve the specified requirements of the permits. Yet there is no evidence ADPC&E has even considered what that shortest time might be for each of these mills. The deadline for compliance with 301(b)(2)(A) of the Act, which imposes the best available technology requirement, was March 31, 1989. 301(b)(2)(D) and (F). Nevertheless, the draft permits impermissibly extend this statutory deadline. Based upon this provision, the pulp mills should be given only as much time as is necessary to convert to the bleaching process that uses no chlorine or chlorine dioxide and results in zero (or, for kraft mills, very low) AOX and dioxin discharges. Finally, these permits, as proposed, make no attempt to govern sludge management practices at the mills. Because these activities are extensions of wastewater pollution controls, they should fall within the scope of the NPDES permit. By the same token, air emissions of volatile organics, such as chloroform, methylene chloride, and carbon tetrachloride, also should be addressed. In any event, they are reasonably foreseeable environmental consequences of the issuance of the permit and should be addressed in an environmental impact statement. This is also the first instance in which ADPC&E has made an attempt to establish how much, if any, dioxin can be legally discharged into state waters -- a subject which warrants close public scrutiny, aside from individual permit considerations. We therefore take this opportunity to call for preparation of Environmental Impact Statements for any expansion plans for Arkansas mills, and for these permit actions. []TL: Comments on Ark NPDES Permits for IP & GP Mills (GP) SO: Pat Costner, Greenpeace USA DT: 7-JAN-91 Keywords: toxics effluent pulp greenpeace groups reports us gp arkansas georgia pacific international paper business / [part 7 of 14] 4 > It is improper for ADPC&E to write clauses into permits which would allow for the modification of dioxin or AOX limits, pending the outcome of further study or control plans. Drafts of all permits made public so far contain language which allows for later modification of AOX and dioxin limits following completion of the mills' control plans. This language is improper. ADPC&E, having formally adopted water quality and BAT-based effluent standards for the industry, cannot at some later date decide not to enforce them at some mills. If any future modifications to these permits are to occur, they must do so through formal variance procedures, and with full public scrutiny. []TL: Comments on Ark NPDES Permits for IP & GP Mills (GP) SO: Pat Costner, Greenpeace USA DT: 7-JAN-91 Keywords: toxics effluent pulp greenpeace groups reports us gp arkansas georgia pacific international paper business / [part 8 of 14] 5 > ADPC&E has failed to regulate, via inclusion in these discharge permits, numerous other pollutants that these mills have reported that are not accounted for in the proposed permit. Pollutant scans, Toxics Release Inventory data, and other information on file at the Department show that other water pollutants are being discharged by these mills which have not been addressed by the permit. Among these are sodium sulfate, chloroform, acetone, resin acids, chlorophenolics, and metals. Many of these unaddressed compounds are 307(a) pollutants, as defined by the Clean Water Act, and thus are subject to all applicable water quality standards. Others, though organochlorines, may not be adequately addressed by AOX limits, since AOX limits are commonly technology-based, not water quality based. []TL: Comments on Ark NPDES Permits for IP & GP Mills (GP) SO: Pat Costner, Greenpeace USA DT: 7-JAN-91 Keywords: toxics effluent pulp greenpeace groups reports us gp arkansas georgia pacific international paper business / [part 9 of 14] 6 > By proposing limits and requiring effluent monitoring for 2,3,7,8-TCDD alone, ADPC&E fails to regulate the other chlorinated dioxins and furans that are known to be present in the effluents of these chlorine-bleaching kraft pulp mills. ADPC&E has tacitly recognized the occurrence of 2,3,7,8- tetrachlorodibenzofuran (2,3,7,8-TCDF) in the effluents of thesemills by requiring the monitoring of 2,3,7,8-TCDF in pulps, certain wastewaters, aeration basin effluents, as part of the proposed ICS Chlorine Minimization Program and Total Suspended Solids Minimization Program. Further, ADPC&E also tacitly recognizes the occurrence of other dioxin and furan congeners in the ICS fish monitoring requirements. Nevertheless, the Department failed to address any dioxin and furan, other than 2,3,7,8-TCDD, in the draft permits. Limiting discharge concentrations and discharge monitoring to only one of the dioxins and furans, 2,3,7,8-TCDD, ignores the threats posed by other congeners. For example, for effluents from chlorine-bleaching kraft mills, approximately 50 percent of the expected toxicological contribution from dioxins and furans is attributable to the furan component. Recognizing that other dioxin and furan isomers share identical, albeit less potent toxicological properties, the U.S. Environmental Protection Agency has long relied on toxic equivalency factors for assessing overall risks from exposure to mixtures of dioxins and furans. Reflecting this policy and the commonly concurrent occurrence of many other dioxins and furans other than 2,3,7,8-TCDD, the National Bioaccumulation Study gathered data for all isomers. Similarly, ADPC&E proposes requiring the monitoring of fish tissues for all chlorinated dioxins and furans, reported in TEQs, in fish taken at unspecified points downstream from the Georgia Pacific and International Paper mills. EPA's proposed ICS/NPDES permit reissuance for the Potlatch mill in Lewiston, Idaho (p 73) likewise acknowledges that: (T)he NPDES regulations at 40 CFR 122.44(d)(l) require that permits include limits on all pollutants or parameters which "are or may be discharged at a level which will cause, have the reasonable potential to cause, or contribute to an excursion above any State water quality standard, including State narrative criteria for water quality" (54 Fed. Reg. 23868-23899; June 2, 1989). These and related statutes cannot be ignored in developing permit limits. ADPC&E must clearly and specifically limit "all pollutants", not just 2,3,7,8-TCDD, that have the reasonable potential to contribute to an excursion above the one-in-one- million cancer criterion. The objective of the Clean Water Act is to "restore and maintain the chemical, physical, and biological integrity of the Nation's waters." Section 101. Given that it is already unlikely that the waters will be "restored" by the deadline imposed by Section 304(l) of the Act, ADPC&E is compelled by this law to set a zero discharge limit for 2,3,7,8-TCDD and associated dioxins and furans and to take immediate measures to control all other known sources discharging into state waters. Sweden's Chemicals Inspectorate issued a report last year which stated: "The Swedish National Chemicals Inspectorate has not been able to, during this investigation, find any concrete proof that any (paper) product must be chlorine bleached, as a necessary functional requirement." No such product evaluation has been made to substantiate organochlorine pollution rights for Arkansas mills, and we hereby call on EPA and/or ADPC&E to make such an evaluation. Any NPDES permit approved by ADPC&E must be in keeping with all applicable state laws. Arkansas law expressly disallows unnecessary or avoidable pollution. Wastewater discharge permits must be changed to reflect this, by eliminating dioxins and all other organochlorines from pulp mill discharges. 7 > U.S. EPA's water quality criterion for 2,3,7,8-TCDD of 0.013 parts per quadrillion is not sufficiently protective of public health or the environment, in light of evidence that has come to pass since its initial establishment. This current federal criterion does not meet the commonly accepted standard of protection of one-in-a-million cancer risk. The National Human Adipose Tissue Survey 4 and numerous other studies show that people in the U.S. and other industrialized nations carry dangerously high levels of dioxins and furans in their adipose tissue and breast milk. An average breast-fed baby already ingests up to 100 times more dioxins than the World Health Organization (WHO) deems tolerable for a healthy adult, much less a developing infant.5 []TL: Comments on Ark NPDES Permits for IP & GP Mills (GP) SO: Pat Costner, Greenpeace USA DT: 7-JAN-91 Keywords: toxics effluent pulp greenpeace groups reports us gp arkansas georgia pacific international paper business / [part 10 of 14] At a June 1990 dioxin conference sponsored by Oregon Department of Environmental Quality, Donald Barnes of U.S. EPA's Science Advisory Board noted that current dioxin body burdens of humans in industrialized countries are associated with a cancer risk of one in one thousand. I.e., the dioxin body burden now common in U.S. citizens already exceeds the commonly accepted risk standard of one in one million by a factor of 1,000. This evidence of already elevated body burdens is particularly disturbing given dioxin's known immunosuppressive effects in primates,6 and the fact that it targets the thymus,7 a gland that is of utmost importance in the developing immune systems of very young children. However, U.S. EPA's water quality criterion (WQC) considers only dioxin's cancer-causing potential. Disturbing evidence has also come to light this year regarding dioxin's potential for causing harm to humans. Recent epidemiological evidence from Seveso,Italy documents elevated cancer incidence, as well as other diseases. 8 Moreover, two key epidemiological studies which have often been used to support the notion that humans are less susceptible than non-human animals to dioxin's effects have been shown to be fraudulent.9 10 EPA's current WQC for 2,3,7,8-TCDD also underestimates the average U.S. fish consumption rate, and even more seriously underestimates the amount of fish eaten by Native Americans and Asian Americans. 11 EPA now points out that these populations eat 150 grams of fish per day, not the 6.5 grams per day used to derive the water quality criterion. Further, the current WQC for 2,3,7,8-TCDD also is based on an estimated bioaccumulation potential of 5,000. However, more recent data from EPA's Duluth lab have shown that the factor may actually be as high as 159,000 in some fish species.12 All of this evidence argues for a much stronger water quality criterion for 2,3,7,8-TCDD if public health is to be protected to the level intended by the State of Arkansas. []TL: Comments on Ark NPDES Permits for IP & GP Mills (GP) SO: Pat Costner, Greenpeace USA DT: 7-JAN-91 Keywords: toxics effluent pulp greenpeace groups reports us gp arkansas georgia pacific international paper business / [part 11 of 14] 8 > ADPC&E has failed to require the use of state-of-the-art analytical methods in the monitoring of mill effluents, sludges, pulps, wastewaters, aeration basin effluents, and fish tissues for 2,3,7,8-TCDD, 2,3,7,8-TCDF, and total dioxins/furans. The Department has specified the use of EPA Method 1613, with a minimum detection limit of 10 parts per quadrillion (ppq)*, despite having proposed limits for the Georgia Pacific and International Paper effluents of 0.32 ppq and 3.06 ppq, respectively. Further, in the draft permits, ADPC&E proposes to allow "a value of zero" 2,3,7,8-TCDD to be assigned to all -------------------- * One part per quadrillion (1 ppq) = 1 picogram per liter (1 pg/L) effluent samples for which analysis results in a measurement of less than 10 ppq. Based on these proposals, these pulp mills will actually be allowed to discharge the quantities of 2,3,7,8- TCDD shown below: Actual Proposed Allowable Daily Discharge of 2,3,7,8-TCDD, based on a minimum detection limit of 10 ppq Facility Picograms per Day `Person-Doses' per Day** Georgia Pacific 2.46 billion 5.86 billion International 1.02 billion 2.43 billion Paper However, according to Martha Prothro, Director of EPA's Office of Water Regulations and Standards, "a detection limit of 20 parts per quintillion [0.020 parts per quadrillion] in drinking water" has been established by Dr. Christoffer Rappe, University of Umea, Sweden. 13 Further, at this year's International Dioxin Symposium in Bayreuth, Germany, Dr. Rappe presented a paper documenting the sampling and analysis of surface water and drinking water at 0.001 ppq levels. 14 In fact, as noted in Director Prothro's letter, the Agency is also aware that the Canadian government proposes requiring TCDD and TCDF concentrations in pulp and paper mill effluents to be ""non-measurable," where "non-measurable" is defined as the Limit of Quantitation (LOQ) of a reference method." For a 1 liter sample of pulp and paper effluent, Dr. Chung Chiu of Environment Canada reports a method detection limit of 2 pg/L [2 ppq]. Dr. Chiu also observes, "For very clean samples, such as drinking water, one could use a sample size much larger than 1 L. If one used a 10 L sample, for example, the analytes would be concentrated by a factor of 10 in the cleaned extract thus lower- ing the method detection limit." I.e., rather than the detection limit for TCDD of 2 pg/L proven for pulp and paper mill efflu- ents, a detection limit for drinking water of 0.2 pg/L [0.2 ppq] is readily achievable. We reiterate that the Clean Water Act requires ADPC&E to develop dioxin control strategies for pulp mills that will assure that water quality be restored by June 4, 1993. Since the 2,3,7,8-TCDD limits proposed by ADPC&E are unverifiable by the analytical methods also proposed by ADPC&E, the only reliable method for limiting the quantity of 2,3,7,8- TCDD discharged by these mills is to eliminate the use of chlorine -- the source of this and other dioxin, furans and organochlorines. []TL: Comments on Ark NPDES Permits for IP & GP Mills (GP) SO: Pat Costner, Greenpeace USA DT: 7-JAN-91 Keywords: toxics effluent pulp greenpeace groups reports us gp arkansas georgia pacific international paper business / [part 12 of 14] 9 > Continued discharges of organochlorines will cause -------------------- ** Assuming an average adult weight of 70 kilograms, or 154 pounds. unacceptable adverse effects on bald eagles. Bald eagles face a significant threat of extinction. Contamination of the environment with organochlorine compounds exacerbates the species' risk of extinction by contributing to severe reproductive failure in resident eagle populations. Continued discharges of these substances to Arkansas waterways by pulp mills, including discharges contemplated by the proposed new NPDES permits, pose a continuing threat to the survival of this species. Because discharges of these substances -- especially considered in combination with other sources of organochlorines and related compounds -- pose a direct risk of serious injury to the species, the approval of permits that allow continued additions of these toxins to the environment violates the federal Endangered Species Acts. ADPC&E should act strongly now to eliminate entirely the use of chlorine in pulp mills in Arkansas. Only a zero discharge level for 2,3,7,8-TCDD and other organochlorine compounds will achieve this end. []TL: Comments on Ark NPDES Permits for IP & GP Mills (GP) SO: Pat Costner, Greenpeace USA DT: 7-JAN-91 Keywords: toxics effluent pulp greenpeace groups reports us gp arkansas georgia pacific international paper business / [part 13 of 14] 10 > The permits must include monitoring for chronic toxicity to (a) river otter or other aquatic mammals and (b) bald eagles, osprey, or other aquatic-dependent birds. 2,3,7,8-TCDD and other complex organochlorines are particularly pernicious to reproductive processes, so that protection of wildlife requires knowing whether reproduction is being adversely affected by pulp mill discharges of chlorinated hydrocarbons. It does not matter whether some of the chlorinated hydrocarbons affecting such wildlife derive from sources other than pulp mills. Any permit to a pulp mill to discharge organochlorines must necessarily consider cumulative impacts of intentionally (and unnecessarily) discharging chlorinated hydrocarbons to water bodies already contaminated with PCBs, DDE, and chlorinated hydrocarbons discharged by upstream facilities and at an earlier point in time. []TL: Comments on Ark NPDES Permits for IP & GP Mills (GP) SO: Pat Costner, Greenpeace USA DT: 7-JAN-91 Keywords: toxics effluent pulp greenpeace groups reports us gp arkansas georgia pacific international paper business / [part 14 of 14] 11 > The permitted discharge of dioxin into water bodies must consider the presence of coplanar PCBs in those waterbodies. Coplanar PCBs are dioxin equivalents in their mode of action and toxic effects. As PCBs are extraordinarily persistent and widespread in waterbodies as a result of leaking transformers and PCB-contaminated landfill runoff, the state of Arkansas cannot claim to be protecting the propagation of aquatic wildlife absent a calculation of the cumulative impacts of residual PCBs and dioxins and furans, and intentionally-added dioxins and furans. 12 > ADPC&E has not discussed the feasibility of a zero organochlorine discharge goal for Arkansas pulp mills. The major alternative to chlorine bleaching, i.e., bleaching kraft pulp off-white without the use of chlorine or its derivatives, has not been discussed by ADPC&E in terms of economic viability, social desirability, attainment of water quality standards), or environmental integrity. This failure to discuss an option that is already being practiced by some pulp mills worldwide is arbitrary and capricious. --- Thank you for the opportunity to comment on these proposed permits and Individual Control Strategies. Yours for the Earth Pat Costner Research Director Toxics Campaign Greenpeace USA Referenced Documents (1) Neil McCubRear(Sth90 esecReducing Dioacture of Bleached Wood Pulp," Washington, D.C (3) Cleverly, David, Office of Research and Development, U.S. Environmental Protection Agency, and Craig McCormack, Office of Policy Planning and Evaluation, U.S. Environmental Protection Agency, "Analysis of the Potential Populations at Risk from the Consumption of Freshwater Fish Caught near Paper Mills," (draft), April 23, 1990. (4) U.S. Environmental Protection Agency, "Broad Scan Analysis of the FY82 National Human Adipose Tissue Survey Specimens, Volume I - Executive Summary," EPA-560/5-86-035, Washington, D.C., December 1986. (5) World Health Organization, "PCBs, PCDDs, and PCDFs in Breast Milk: Assessment of Health Risks," World Health Organization, Regional Office for Europe, EH 29, 1988. (6) Hong, R., K. Taylor, and R. Abonour, "Immune abnormalities associated with chronic TCDD exposure in Rhesus," Chemosphere, Vol. 18, Nos. 1-6, pp. 313-320, 1989. (7) U.K. Department of the Environment, "Dioxins in the Environment," Pollution Paper No. 27, London, 1989. (8) Bertazzi, P.A. et al, "Ten year mortality study of the population involved in the Seveso incident in 1976," Am. J. Epidemiol., Vol. 129, No. 6, pp. 1187-1200, 1989. (9) F. Rohleder, Presentation to the 9th International Dioxin Symposium, Toronto, Canada, 1989. (10) Memo from Cate Jenkins, Waste Characterization Branch, Chracterization and Assessment Division, U.S. EPA, to Raymond C. Loehr, Chair, Executive Committee, Science Advisory Board, U.S. EPA. Re: Newly Revealed Fraud by Monsanto in Epidemiological Study Used by EPA to Assess Human Health Effects from Dioxins; February 23, 1990. (11) Cleverly, David, Office of Research and Development, U.S. EPA, and Craig McCormack, Office of Policy Planning and Evaluation, U.S. EPA, "Analysis of the Potential Populations at Risk from the Consumption of Freshwater Fish Caught near Paper Mills," (draft copy), April 23, 1990. (12) Memo from Philip Cook, Chief of Hazardous Waste Research Branch, ERL-Duluth, to Jim Cummings, Office of Assistant Administrator for Solid Waste and Emergency Response, U.S. Environmental Protection Agency, Re: 2,3,7,8-TCDD in Aquatic Environments; February 4, 1987. (13) Letter from Martha Prothro, Director, U.S. EPA Office of Water Regulations and Standards, to John Bonine, Western Natural Resources Law Clinic: Re: Dr. Christopher Rappe of the University of Umea in Sweden; July 20, 1990. (14) C. Rappe, L.O. Kjeller and S.E. Kulp, "Sampling and Analysis of PCDDs and PCDFs in Surface Water and Drinking Water at 0.001 ppq Levels," Dioxin `90, Bayreuth, Germany, September 1990. ---------- Command: [Greenbase Inventory October 27, 1991 ] =======[#]=======