May, 1998
Table of Contents
Public Hearing -- Fort James Water Pollution
1. Excessive SolidsLife Tools’ Street Fair
2. Phosphorus Doubled
3. Lack of Limits
4. Toxic Chlorine Compounds Ignored
5. Only 1 Scan in 5 Years
6. Lack of Ongoing Monitoring
7. Lack of Flow Limits
8. Wasteload Allocations
9. Acid/Caustic Discharges
10. Bioassays Inadequate
11. Non-Contact Water
12. Poor Public Notice
13. By-Pass Loopholes
Public Hearing
Write a Letter!
Realtors Donate Big Money to Campaigns
Should the Fox River be a Superfund Site?
Arguments Against -- Arguments in FavorPCB Program Rescue Success
Please Write a Letter Today!
Chlorinated Drinking Water Under Fire
Internet Information on Local Pollution
Public Hearing -- Fort James Water Pollution
Clean Water Action Council and the Brown County Conservation Alliance
have requested a public hearing on a proposed new water pollution permit
for Fort James’ Broadway Mill (the old Fort Howard mill) on the Fox River
in Green Bay.
Some of our concerns include:
This permit would allow Fort James to dump up to 3,841 tons of solids in the Fox River each year. This is the same as allowing them to discharge 256 dump truck loads, an unacceptable situation. The sludge will invariably contain hundreds of kinds of toxic chemical contaminants chlorinated organics, heavy metals, etc. --- typical from the deinking residues of paper recycling.
The permit allows phosphorus to be discharged at twice the DNR’s usual
recommended standard. This means Fort James could legally dump 57,870 pounds
of phosphorus in the river each year, creating a powerful fertilizing effect
downstream. (This equals 2 dump truck loads of fertilizer.) Our members
have noticed increases in algae in the lower Fox River and Bay in the past
year. In addition, in our legal case challenging the Kidney Island
expansion, several experts testified that the lower Bay is already experiencing
dissolved oxygen sags, below the water quality standard, which threatens
fish who need oxygen to breathe. The algae and oxygen sags show a clear
need to cut back on phosphorus releases in this area.
The DNR proposes an “alternate phosphorus concentration limit” of twice
the recommended standard., to allow the company time to study alternatives.
But Fort James has studied their phosphorus situation for years. They shouldn’t
need another year for this study, especially when they’re claiming they
should be excused from the tight limit altogether.
The permit sets no limits for Ammonia Nitrogen, Total PCBs, or a whole
host of other chemical contaminants (especially dioxins, furans, heavy
metals, solvents, pthalates, pentachlorophenol, etc.) known to accompany
typical waste paper deinking plants. The permit should require that if
concentrations of any chemicals above health standards are detected, this
constitutes a violation and corrective actions should be taken immediately.
These are serious toxins, including human carcinogens, being discharged
upstream of Green Bay and the Great Lakes. The DNR needs to have a clear
response ready if problem chemicals are detected.
It is inconceivable that 256 dump truck loads of deinking solids and
189 dump truck loads of BOD (Biological Oxygen Demanding chemicals) could
be discharged into a public water supply without more specific chemical
limits in the permit for the wide range of other chemicals which will accompany
this material.
4. Toxic Chlorine Compounds Ignored
Fort James is known to use huge quantities of hypochlorite bleach in
the drinking or bleaching of their pulp, and they recycle chlorine bleached
waste paper. We object to the lack of any limits on the company’s paper
process wastewaters for the many kinds of chlorinated compounds which will
unavoidably be released as part of this operation. We’re concerned that
no chlorine, chlorinated resin acids, dioxins, furans, chloroform, chloramines,
trihalomethanes, chlorpyrifos, or AOX samples were mentioned in the proposed
permit.
Toxic Release Inventory data for Fort Howard still shows large amounts
of chloroform released to the air. This shows the presence of chlorinated
chemicals in the wastewater, and the public should be told what those concentrations
are, before the company is issued a permit with no limits or monitoring
requirements for these chemicals.
DNR requires only one sample scan in 5 years to define this company’s
overall wastewater chemicals. It is especially disturbing that this sample
is collected by the company itself, analyzed by the consultants of their
choice, and the company has weeks to prepare and clean-up its operations
before the scheduled sampling date. With millions of waste treatment
dollars at stake, the company would be highly tempted to modify its process
temporarily to allow it to pass the test with minimal trouble.
In place of this suspect process, the DNR should collect several samples
on several surprise visits to get the true picture, and should randomly
assign samples for analysis at a variety of different independent labs,
to ensure anonymity and honesty.
It’s impossible for one sample in 5 years to have any statistical significance
or scientific validity.
6. Lack of Ongoing Monitoring
The DNR neglects to require ongoing monitoring for most of the chemicals
of concern listed above. Therefore, the DNR will be operating in the dark
as to the potential impacts of this mill in the future. This means future
permit reviews and river health studies will be much poorer because of
the lack of adequate data. This is completely unacceptable.
Fort James is one of the largest polluters of the Fox River. They need
to be tracked and monitored carefully, to allow prompt and effective enforcement
actions, and appropriate rule and permit changes in the future.
Industry always calls for “Sound Science” --- now they need to live
up to it by providing realistic monitoring.
7. Lack of Flow Limits
Permits should include maximum limits on flow, and restrictions on flow during monitoring events, to prevent short term exceedances and to ensure accurate, undiluted samples of waste.
As mentioned under phosphorus above, the river and bay are not meeting basic water quality standards downstream from Fort James. This means the wasteload allocation process is flawed and excessive phosphorus, nitrogen and BOD levels must be further restricted in this permit.
We object to the lenient time frames allowed for exceeding Wisconsin’s
pH standards for discharges. It’s not enough to “report” exceedances, they
should “stop” exceedances. They should not be “forgiven” for 7.5 hours
of exceedance each month. They already have a wide range to work within,
from pH 5 to 9.
Under DNR’s proposal, and because Fort James dumps 9.5 million gallons
of wastewater daily, Fort James would be allowed to dump nearly 40,000
gallons of
highly acidic or caustic waste into the Fox River up to 7.5 times each
month --- a large dose which could repeatedly poison aquatic life. And
if their pH mistakes can happen this frequently, it suggests that other
chemcial levels could have similar variability which would not be detected
by the DNR’s poor monitoring requirements.
This pH variation should also be analyzed and documented with bioassays.
At what dilution does acid or caustic cease to be a problem? Changing pH
levels can make other chemicals in the wastewater more toxic.
The permit requires occasional tests where minnows and water fleas are
exposed to varying concentrations of Fort James wastewater. If a certain
percentage of the creatures die or fail to reproduce, the company fails
the test.
These bioassays may provide valuable information, but they are no substitute
for actual chemical monitoring, and they tell us nothing about bioaccumlation
up the food chain or chemical effects on other species which may be more
sensitive. Other types of health effects in higher organisms,
including humans, could be completely undetected.
These bioassays are especially worrisome, when they measure health
effects only after a 20 to 1 dilution of background water to wastewater.
With such a large volume discharge, the ZID, acute and chronic mixing zones
could be huge permanent areas of toxic water.
Without chemical data, how will DNR or the company begin to address
a toxicity problem if the company fails the bioassay test?
We strenuously object to the discharge of 20,101 pounds (10 tons) of
residual chlorine, and associated unknown chlorinated compounds along with
the 33 million gallons per day of non-contact cooling water. (This is water
used in the industrial boilers --- not used directly in paper making.)
Numerous health agencies have called for the elimination of all chlorinated
chemicals for non-essential purposes and certainly the restriction of these
chemicals from entering the general environment. Chlorine and chlorine
compounds have been linked with a wide range of human and wildlife health
effects.
Alternative treatments should be used instead.
For DNR’s public notices to be useful and meaningful, they should include
(but they don’t) total permitted discharges of all known chemicals, all
known past discharges and any violations under the previous permits. It’s
important for citizens to know whether this permit represents an increase
or decrease
in pollution.
It’s irritating to be forced to perform complex mathematical calculations
and unit conversions in order to evaluate the permit limits in everyday
language (pounds and tons.) DNR’s public notices are written to be read
only by engineers.
After all the DNR talk about “customer service” it’s obvious they don’t
consider ordinary taxpayers to be their customers.
This permit gives wide-open approval for treatment bypasses, as long as the DNR is notified.It says, “All other bypasses of waste treatment facilities are prohibited unless the following conditions are met --- d. In the event of an unanticipated bypass, the permittee notified the Department verbally within 24 hours and in writing within 5 days of each unanticipated bypass.” This means untreated wastes can be dumped in the river as long as DNR is notified.
The Fox River will never heal when DNR grants such permits.
Please attend this important public hearing, and show public support for clean water.
Wednesday, May 27
6:00 p.m.
Location:
Green Bay City Hall, Room 203
(Council Chambers)
100 N. Jefferson Street
Green Bay.
Please take a moment to write a brief letter expressing your opinion of the Fort James discharge permit. Refer to: WPDES Permit # WI-0001848-5 for Fort Howard Corporation (Fort James) in Green Bay.
By June 2, send letters to:
Mr. Mike Hammers - WT/2
Wis. Dept. of Natural Resources
101 South Webster Street
P.O. Box 7921
Madison, WI 53707
Saturday, May 9
9:00 a.m.- 5:00 p.m.
at Life Tool’s new parking lot 930 Waube Lane , Green Bay (Across from Menard’s West)
Spring has sprung, and it’s time again for a fun outdoor gathering to listen to Bluegrass Music (by the well-known “Fox River Fliers”), to eat Booyah, and drink unique Homebrew Beers!
Clean Water Action Council is co-sponsoring this annual event (rain or shine), and the beer sales (11 a.m. to 4:30 p.m.) are a big fundraiser for us. (A big Thank You goes to the Titletown Brewing Company, which donated beer.).
This year, Life Tools Adventure Outfitters will be hosting a Loon Calling Contest at 2:00 p.m., so round up all the loons you know. he best yodel will get some lucky loon a sleeping bag.
Life Tools will also be hosting factory representatives and equipment demonstrations, and offering bargains on a variety of merchandise as well. Join us!
For more info, call 920-339-8473
Clean Water Action Council has assisted a Shawano couple, Len and Judy
Pubanz, and a local committee of supporters in challenging a proposed wetland
destruction permit.
Together we petitioned the Wisconsin Department of Natural Resources
for a Contested Case Hearing to reverse the permit, and recently the DNR
announced approval for the hearing, which may be scheduled a few months
from now.
It’s another case of DNR reversing itself and issuing a permit it originally
advised against. We have several documents containing strong statements
from DNR staff urging that the permit be denied.
The wetland, which is right next to the Wolf River, would be destroyed
to cut a road through to serve a private home. Alternative routes and alternative
home-building sites are available, but the permit was issued anyway.
This seems to be happening a lot since Gov. Thompson and the Republicans
in the state legislature eliminated the Public Intervenor’s Office and
gave the Governor direct control of the DNR.
Unwise wetland permits are being issued helter-skelter throughout the
state, especially to politically influential parties, in this case,
Hilgenberg Realtors.
Realtors Donate Big Money to Campaigns
Is it just a coincidence that Realtors, developers and the special interest
groups that represent their views at the Wisconsin State Capitol doled
out at least $1.4 million for campaign contributions and lobbying from
1993 to 1997?
The 11,000 member Wisconsin Realtors Association is among the most
active and powerful special interest group in Wisconsin.
Until we get Campaign Finance Reform, we’ve got problems.
Should the Fox River be a Superfund
Site?
Please Write a Letter Today!
Superfund is needed to restore the Fox River. Please write to the EPA
and tell them you support the Superfund designation and want a strong plan
which fully protects public health and wildlife. Letters can be brief
and handwritten. Just tell the EPA how the clean-up would benefit
you and your family, or how the river, bay or Lake Michigan contamination
has impacted your life.
Write to: Mr. Jim Hahnenberg, U.S. EPA Region 5, 77 West Jackson Boulevard, Chicago, IL 60604.
Our co-sponsorship of the recent program called “Restoring the Fox River
-- Perspectives on PCBs and Public Health” was a big success despite all
the confusion and frustration caused by political maneuvers. More than
300 people attended and we had a variety of handouts, presentations, questions,
comments, and discussions from 7:00 to 10:00 p.m. Clearly, the public is
strongly interested in this issue.
In our last newsletter we explained that DNR and EPA were originally
the major sponsors of this public health program, but DNR cancelled it
because of pressure from the Chamber of Commerce and Industry.
Apparently, the polluters don’t want the public to have the latest
scientific information, or to discuss the issue of the Fox River contamination.
Clean Water Action Council and the Sierra Club stepped in to sponsor
and maintain the original event, and ten other groups also sponsored.
After Clean Water spent more than $800.00 on printing, postage, phone
calls and other efforts to publicize the event (and after Sierra Club made
similar investments), the last 3 government speakers (from the federal
Agency for Toxic Substances and Disease Registry, and the Wisconsin Dept.
of Health) cancelled at the last minute, only a few days before the program
was scheduled.
Needless to say we were furious, for several reasons:
1. All these agencies seem more concerned about not offending the polluting industries than they are about protecting public health and doing their jobs. This is not reassuring.
2. All these agencies and their research projects are supported by our public tax dollars. They have an obligation to report and explain their results to the public.
3. The last 2 cancelling agencies sent all their slides and the scripts for their presentations, so that we environmentalists could still present the information --- but this was obviously a lame gesture. It didn’t have the same credibility that the scientists would have had. And the researchers weren’t available to answer any questions.
4. The agencies all claim they intended to reschedule the program later in summer or fall, but this would be too late. The EPA is expected to formally propose Superfund status for the river in May, and the public will have only 60 days to comment afterwards. The public needs the PCB health information now, in order to understand the basic need for clean-up.
We did end up with a wonderful technical talk by Prof. Warren Porter, who chairs the Zoology Department at UW-Madison and has spotless credentials as a researcher on PCBs and other toxics. His presentation saved the day.
Chlorinated Drinking Water Under Fire
A growing body of research evidence suggests that exposure to trihalomethanes,
a group of chemicals found in chlorinated drinking water, may increase
our risk for a host of serious health effects.
A new report released by the California Department of Health Services
indicates that chlorinated drinking water may increase the risk of miscarriages,
birth defects, and provide a partial explanation for our current epidemic
of cancers.
The U.S. Environmental Protection Agency (EPA) has proposed reducing
by as much as half the allowable levels of trihalomethanes (THMs) in drinking
water over the next decade, with a long-term goal of eliminating the chemicals.
Though alternatives to chlorination are available and affordable, 70%
of U.S. cities continue to chlorinate public drinking water.
They have argued that the risks of disease organisms is higher than
the risks from chlorination, yet other less toxic disinfection methods
(ozone, UV radiation, etc.) can disinfect as well or better.
The authors propose steps to ensure a safe water supply for everyone.
These include: implementation of pollution prevention programs in both
urban and rural landscapes; restoring the health and vitality of natural
water filtration systems such as forests, rivers, wetlands and groundwater
recharge areas; shifting to alternative treatment technologies and modernizing
and maintaining our water supply systems.
The researchers also call for a government commitment to full public
disclosure about the quality of water we drink.
Consumers should be alerted to the contaminants in all drinking water
sources, including some bottled water and filtered water. Home water filters
should be checked to ensure they are designed to remove chlorine and chlorine
compounds.
(From the San Francisco Chronicle, April 14, 1998, and Watershed Currents.)
Internet Information on Local Pollution
A new Internet service from the Environmental Defense Fund is called
the Chemical Scorecard, which allows anyone in the U.S. to see toxic chemical
sources and hazards in sharp detail on local street maps, by zip code,
specific industries, or by county, and to send questions to those sources.
It includes information on chemical health effects, as well as rankings
based on pollution loads and health hazards for 17,000 manufacturing facilities
covered by the federal Toxics Release Inventory. Top hazards and multi-year
trends are highlighted.
Some conventional pollutants, such as sulfur dioxide, nitrous oxides,
phosphorus, etc. are not included, and some obvious pollution categories
(power plants, government facilities, etc.) are not included, due to weaknesses
in the federal Inventory law.
The Internet address is: http://www.scorecard.org
|
|
|
|
|