1111
Nineteenth
Street,
NW,
Suite
800
 
Washington,
DC
20036
 
202
463­
2700
Fax:
202
463­
2785
 
www.
afandpa.
org
America's
Forest
&
Paper
People

­
Improving
Tomorrow's
Environment
Today

May
17,
2005
(
via
E­
mail)

Ms.
Lynn
Zipf
USEPA,
Office
of
Water
1200
Pennsylvania
Ave.,
NW
4303T
Washington,
DC
20460
Re:
Additional
Industry
Discharge
Information
Dear
Ms.
Zipf:

We
would
like
EPA
to
consider
the
following
information
as
it
moves
ahead
in
its
detailed
study
of
the
pulp
and
paper
point
source
sector.
This
information
supports
our
previous
correspondence
and
discussion
seriously
questioning
the
validity
of
the
PCS
or
TRI
data
showing
discharges
of
dioxin
from
industry
mills.

Pursuant
to
state
law,
bleached
kraft
mills
in
Maine
have
undertaken
comprehensive
effluent
and
fish
tissue
testing
for
several
years.
As
stated
in
the
law,

The
key
requirement
is
that
`
a
(
bleach
kraft
pulp)
mill
may
not
discharge
dioxin
into
its
receiving
waters
after
December
31,
2002.
To
determine
compliance,
there
are
interim
tests
and
a
final
test.
Two
interim
tests,
of
effluent
from
the
bleach
plant
require
that
1)
TCDD
(
2378­
tetrachlorodibenzo­
p­
dioxin,
the
most
toxic
of
the
17
toxic
dioxins
and
furans)
must
be
below
10
ppq,
parts
per
quadrillion
or
picograms
per
gram,
pg/
g
by
July
31,
1998
and
2)
TCDF
(
2378­
tetrachlorodibenzofuran)
must
be
below
the
same
detection
limit
by
December
31,
1999.
As
the
final
test
to
confirm
that
there
is
no
discharge,
by
December
31,
2002
fish
(
or
surrogate)
below
a
bleached
kraft
pulp
mill
must
have
no
more
dioxin
than
fish
(
or
surrogate)
above
the
mill,
the
so
called
"
above/
below
(
A/
B)
fish
test".
1
Thus,
Maine
bleached
kraft
mills
are
subject
to
extremely
rigorous
dioxin
requirements.
They
must
demonstrate
that
both
dioxin
and
furan
are
below
the
10
ppq
minimum
level
in
bleach
plant
effluent
and
they
must
pass
the
"
above/
below"
fish
tissue
test.
As
demonstrated
by
the
data
in
the
report,
the
mills
have
been
in
compliance
with
the
first
requirement
for
bleach
plant
effluent
for
some
time.
Much
of
even
the
early
data
showed
no
dioxin
or
furan
at
levels
well
below
10
ppq.
The
Report
now
shows
that
the
mills
have
met
the
second
requirement
for
fish
tissue
as
well.

1
See
page
10
of
the
attached
report,
"
Dioxin
Monitoring
Program,
Final
Report,
Maine
Department
of
Environmental
Protection,
April
2005,"
found
on
the
Maine
DEP
website
at
http://
mainegovimages
informe.
org/
dep/
blwq/
docmonitoring/
dioxin/
2004/
04dmprpt.
pdf
AMERICAN
FOREST
&
PAPER
ASSOCIATION
GROWING
WITH
AMERICA
SINCE
1861
Ms.
Lynn
Zipf
May
2,
2005
Page
2
of
2
The
Commissioner
of
the
Maine
Department
of
Environmental
Protection
(
DEP)
announced
the
results
by
stating,
"
The
results
are
now
in
and
here
is
the
good
news.
All
kraft
pulp
mills
have
demonstrated
compliance
with
the
Above/
Below
test
this
year."
The
DEP
announcement
of
the
results
also
noted,
"
This
means
that
the
mills
are
no
longer
discharging
dioxins
into
Maine's
environment."

The
mills
have
undertaken
the
above/
below
testing
for
several
years.
Some
mills
had
already
demonstrated
compliance
before
this
year's
results.
Moreover,
the
general
trend
over
time
has
been
that
the
fish
tissue
levels
of
dioxin
below
the
mills
were
declining,
which
is
consistent
with
the
effluent
results.
While
there
are
still
some
elevated
fish
tissue
levels,
the
DEP
correctly
attributes
that
to
"
residual
levels
of
contamination
from
historical
discharges."
However,
even
these
levels
of
dioxins
and
furans
are
below
the
current
state
fish
tissue
action
level
of
1.5
parts
per
trillion
(
ppt)
and
most,
if
not
all,
are
below
a
possible
future
level
of
0.4
ppt.

Thank
you
for
you
consideration
of
this
information,
which
supports
our
position
that
revision
of
the
effluent
guidelines
for
the
pulp
and
paper
point
source
sector
is
not
warranted.
Please
feel
free
to
contact
me
at
(
202)
463­
2581,
if
you
have
any
questions
about
this
information.

Sincerely,

Jerry
Schwartz
Senior
Director,
Water
Quality
Programs
Enclosures
