-. 2H - /3 American Paper 1-. .5 22 drifts-G": 31?; I I - I 9? HEALTH imoonam I National Forest Products Association 1250 Connecticut Avenue. NW. Washington. DC. 20036 MkaHlFunr Vice President 202-463-2440 June 23, 1986 Mr. Alec McBride (NH-553) Chief, Water Quality Analysis Branch ?ffice of Water Regulations and Standards Environmental Protection Agency qul street, S.W. .Lagton, D.C. 20460 Tr. McBride: i am pleased to enclose a signed copy of the paper industry's agreement to join with EPA in conducting a joint screening study of the possible presence and sources of dioxin in materials associated with bleached kraft mills. In doing so, we want to express our appreciation for the crucial role you played in bringing this important agreement to fruition. By its terms, the agreement indicates EPA will withdraw the pending "Section 308" request for information directed to Boise Cascade's International Falls mill, pending satisfactory execution of the study. The stated reason for EPA's willingness to do so is that the study "is expected to generate information fully satisfying that asked for'I in the 308 request. For that same reason, we do not expect any other member companies to receive, during the pendency of the study, a 308 request seeking the type of information expected to be generated by the study. We are confident that EPA will not issue any such 5 308 requests since, by executing this agreement, EPA and we have evidenced our understanding that gathering the facts about dioxin can best be done in a cooperative, scientific, joint venture. If some unusual circumstance arises which the Agency believes warrants some other course -- such as issuance of a 308 letter we would expect to be advised beforehand so we might attempt to address EPA's information needs in a cooperative fashion. As indicated in our earlier conversations, we anticipate that the Agency will be as careful in assessing whether there is any real risk connected with the presence of trace amounts of dioxin -- or any chemical that may be associated with our industry as it was diligent in fashioning a program to look for dioxin. For that reason, we are now arranging to meet with the Administrator, and other approPriate Agency officials, to discuss issues relating to risk assessment. We have requested the meeting now, not to be critical of, but to build on, the fine efforts you have made in the area for which you are responsible. Thank you again for your assistance we believe you have helped us shape an agreement that serves the interests of the Agency, the industry and, most importantly, the public. Sincerely, cc: A. James Barnes, Deputy Administrator MCF:slr 6/20/86 DIOXIN SCREENING STUDY Background and Project Introduction Results from the National Dioxin Stu-1y indicate that has been detected in fish and river sediments cull-acted domistream frOm sane pulp and paper mills located in various parts of the country. The Petenwell Flowage in Wisconsin, the Rainy River in Minnesota, and the Androscoggin River in Maine have been identified as areas containing .levels of dioxin to date. OJrrent mstewater treaUrent plant sludges from some Maine, Minnesota, and Wisconsin mills c0ntain parts per trillion (ppt) levels of and other and Available EPA data indicate that, within the paper industry, bleached kraft mills have the highest levels of} 2378-TCDD in wastewater sludge. This would indicate that current process Operations may be responsible. Halever, there are currently no data to document potential process sources of dioxins nor to explain the wide range of sludge concentrations at bleach kraft mills. The paper industry has initiated a sampling program for paper mill wastevater treatment plant sludges. At this writing, paper industry data are not available. The U.S. Ehviromnental Protection Agency (USEPA), the American Paper Institute (API) and the National Council of the Paper Industry for Air and Stream Inprovenent (NCASI), have decided to conduct a cooperative screening study of five bleached kraft mills to determine possible process sources of and and quantify raw waste, sludge, and final effluent loadings of and The cooperative screening study is being conducted to determine the formation and fate of and in bleached kraft pulp and paper making Operations and respective wastewater treatment facilities. The COOperating parties believe a screening study of this nature can most efficiently be con-, ducted by combining the knowledge and resources of federal and state govermnents and industry. On March 5, 1986, the USEPA sent a formal request for information and cooperation to the Boise?Cascade Corporation with respect to its International Falls, Minnesota, mill. Since this cooperative screening study is expected to generate information fully satisfying that asked for in USEPA's March 5, 1986, request, USEPA hereby agrees to withdraw that request pending satisfactory execution of the cooperative screening study. Screening Study Objectives 1. Determine, if present, the source or sources of 2378-TCDD and other and at five bleached kraft pulp and paper mills. - 2. Quantify the untreated wastwater discharge loadings, final effluent discharge lOadings, sludge concentrations, and wastewater treatzrent system efficiency for and other and Determine raw vrastewater and final effluent levels of selected other organic ?1?th -2- 6/20/86 General Project Organization and Responsibilities 1. Joint USEPA and Industry Responsibilities Responsible for: (1) study design; (2) field coordination of sampling collection program,- (3) providing personnel and equipment for sampling; (4) providing quality assurance review of analytical data from all sanples: (S) develogment of final report,- (6) public, local government, and media relations. USEPA ReSponsible for: (1) approval of sampling locations; (2) contract analytical support: (3) coordination of field sampling with participating State Agencies: (4) selection and prioritization of samples for analysis; (5) providing confidential treatnent of process related information in accordance with Agency regulations; (6) preparation of final report, and (7) public, local gOVern'nent, and media relations as necessary. For USBPA the study will be directed through the Office of Water Regulations and Standards, Industrial Technology Division and Manitoring and Data Support Division. Industry API and NCASI will each direct portions of the industry efforts, with the assistance of the five mills participating in the study. Responsible for: (1) providing study sites and a proposed sarrpling plan for each site; (Participating Mills and NCASI) (2) contracting for analytical support,- (NCASI) (3) providing access to facilities, processes and production information to (Participating Mills) (4) public, local government, and media relations as necessary. (API and Participating Mills) (5) Should a step in the kraft pulp and papenraking process be isolated as a major source of dioxin, the industry agrees to undertake a further investigation in atterpt to determine its source and fomation. General Field Sampling Plan A couplets set of samples at each mill will be obtained during a single sampling event. Individual sarrples will be collected over a 24-hour period or other .- suitable corrposite sampling period. Where apprOpriate, process additives may be grab sanpled. The approximate level of detail of sampling to be conducted at each mill is presented in Table 1 along with analytical requirements. The - 1 6/ 20/86 outline presented in Table 1 will be used as a guide for developing specific sampling plans for each mill. All samples will be collected with apprOpriate documentation, coding, and custody procedures. Samples will be kept chilled during collection and shipnent to the analytical laboratory. Process operating conditions and prolnction records iuring the survey will be recorded and made available to study particii'mnts at the conclusion of each mills-specific sazrpling event. General Analytical Plan Table also presents a general analytical plan, and Table 2 presents additional detail on sample prioritization. Samples and analyses are prioritized to conserve analytical resources. Priority 1 analyses will be conducted and reviewed prior to initiating Priority 2 analyses. USEPA, NCASI, and industry participants will consult to select Priority 2 samples and analyses. Analytical costs for each mill will be shared on the basis of 25 percent funding by USEPA and 75 percent funding by industry for all Priority 1 salrples and up to a maximum of 15 Priority 2 samples. Industry's share of the total analytical cost for the screening study shall not exceed $150,000. Quality Assurance Review rIhe coded analytical data will be forwarded from the contract laboratory simultaneously to the EPA and the NCASI quality assurance managers. 'ihe quality assurance mamgers will complete timely reviews of the data, consult with each other and transmit the data to the EPA and NCASI project managers. Should the quality assurance managers disagree as to whether certain samples require reanalyses or followup analyses, the matter will be referred to the USEPA and NQASI project managers for resolution. Analytical costs associated with further analyses beyond that normally omducted by the analytical laboratory to resolve analytical problems will be shared by USEPA and industry on the same basis noted above. An outline of the Quality Assurance Project Plan for this screening study is presented as Attachment 1. Confidentiality Section 308(b) of the Clean Water Act, 33 USC 1318(1)). Provides that confidential treatment may be afforded to trade secrets which are contained in information collected by, or submitted to, USEPA except that confidential treatment is precluded for "effluent data." Information collected pursuant to this dioxin screening study can be afforded such confidential treatment in accordance with 40 CFR Part 2. The participating oorrpanies may make claims of confidentiality on information submitted to USEPA as specified in 40 CFR USEPA will treat such submitted information in accordance with its regulations found at 40 CFR Part 2. USEPA shall choose the appropriate manner in which to release the report for this dioxin screening study after considering the confidentiality provisions in the Clean Water Act and Agency regulations and after consultation with the participating mills, NCASI, and API. .4- 6/20/86 gather butters Any other matters regarding study design, study implementation, analytical Issues, etc, will be referrel to the USEPA and industry project managers in a timely fashion as they arise for resolution with other parties. Final Heart The cooperating parties agree that the final report of this screening study will be limited to a technical document responsive to study objectives. USEPA will have primary responsibility for preparation of the final report. NCASI and API will provide input to the development of the final report and have the opportunity to provide OOImIents on review drafts. In the event industry participants do not agree with EPA's evaluation and conclusions regarding the data resulting Eran this screening study, NCASI and API may provide separate views regarding the data for inclusion in the final report. The undersigned signatories consent to, and approve this Paper Industry Cooperative Dioxin Screening Study: a. Michael C. F?arrar Vice President Environment and Health American Paper Institute Isaiah Gellman Executive Vice President National Council of the Paper Industry for Air and St ream Inprovement stall? C. #45 Alexander C. McBride, Chief Water Qiality Analysis Branch Monitoring and Data Support Division . . TABLE 1 AND A. Samples Treated River Water Treated River Water Sludge Wood Chips B. Pulping Process Combined Process Wastewaters C. Chemical Recovery Plant Recovery Plant C(?meined Wastewaters Recovery Plant Waste Solids (Lime Mud) D. Bleach Plant Pulp (Bleached and Unbleached) Individual Severed Streams from Bleachines Combined Bleach Plant Process i-Jastewaters Bleaching Agents 0r Solutions E. Paper Machines Combined Paper Machine Wastwaters Process Additives (Alum, Clay, Dyes, Other Chemicals) Slimicides F. Utilities, Wastewater Treatment Powerhouse I'Jastwater Pme?xouse Ash to Treatment Wastewater Treatment Primary Sludge Wastevater Treatment Secondary Sludge Wastewater Treatment Conposite Sludge Combined Untreated Process Wastewater Final Treated Process Wastezaater Effluent Other Wastewater Streams to Treatment landfill Machetes) Analytical Packages I :6 ANALYTICAL PACKAGE ,3,x5,6 2 2,5 l??N Hwt-?H '1Iscmer specific analyses for and 2. Package 1 plus and 3. Suspected precursor commie: Chlorinated phenols, vanillins, and guaiacols 5. TSS: Total suspended solids 6. BODS: Five?Day biochemical oxygen demand 6/20/86 TABLE 2 PRIORITIES Es tima ted PRIORITY 1 Samples to be analyzed at all plants Number of Samples a. Process Related Pulp (in out) 2?6 Bleach Plant Wastwaters 4?12 Powerhouse Ash to Treatment 1 Selected Additives 2 b. Effluent Related Combined Bleach Plant Wastewaters 1 Combined Untreated Process Wastwaters 1 Final Treatei Process Wastedater Effluent Conpasite Wastewater Sludge 1 Priority 2 - Samples to be selected from Table 1 15 for analysis based upon Priority 1 results WASHINGTON. 2546-3 .. 9/4 UNITED STATES ENVIRONMENTAL . 4 . v. .- I. M30886 CF FICE OF WATER {Michael C. Farrar Vice President American Paper Institute 1250 Connecticut Avenue, N.W. Washington, D.C. 20036 Dear Mr. Farrar: Thank you for your letter of June 23 transmitting the signed for conducting a joint screening study to investigate the possible presence of dioxin in pulp and paper mills. Your efforts were most helpful in enabling all of us to reach that agreement. As I am sure you have learned from your discussions with ?*Hinistrator's office, EPA is also very interested in issues related to risk assessments for dioxin. Our Office of Pesticides and Toxic Substances has been assigned the lead role in investi- gating those issues. Also, as we have mentioned previously, while EPA cannot agree to relinquish Section 308 authority, we are hopeful that any additional needs for information related to dioxin can be satisfied in a cooperative manner and that there will be no need to generate any information request letters under Section 308. Again, we appreciate your efforts in developing this agreement. My understanding is that the sampling efforts in International Falls earlier this week were highly successful and conducted in the cooperative manner anticipated in the agreement. Sincerely. Ads. Alec McBride, Chief Water Quality Analysis Branch (NH-553) DATE SUBJECT: FROM: 70' THROUGH: UNITED STATES ENVIRONMENTAL - I. November 22, 1985 Analysis of Sludge Samples for PCDD's and PCDF's Douglas H. Kuehl, Research Chemist .Rosemarie c. Russo, 911.13., Acting Director, OEPE (RD-682), u.s. EPA, 'the level of TCDF's ranged up to 1000 pg/g. 401 H. St., S.W., Washington, 0.0. 20460 Norbert A. Jaworski, Director, ERL-D A set of 18 pulp mill and two municipal sewage treatment plant sludge samples are being analyzed by ERL-D for 75 tetrachloro- to octachlorodibenzo-p- dioxins and 138 tetrachloro- to octachlorodibenzofurans. Preliminary data on seven pulp mill samples indicated that TCDD concentrations ranged from ND (1) to 200 pg/g and that much higher levels of hexa-, hepta-, and octachloro- CDD's can be found. The levels of PCDF showed a reverse trend with very low levels of hepta- and octachloro- CDF's, while The levels of PCDD's in the municipal sewage treatment plant sludge ranged from 5 to 25 pg/z for TCDD to 5000 pg/g for 0CDD. The sample also contained 5 to 10 more TCDF than TCDD, but very low levels of higher homologs. The levels of quantifi- cation are estimates not based on a calibration curve, and none of the qualitative identifications have been checked for requirements. The data is considered to be'a preliminary look at sludge samples used to develop modifications to the analytical plan to meet requirements. Complete analyses will proceed after completion of the National Dioxin Study biological tissue analyses. cc: Gilman D. Veith, Associate Director for Research Operations Steven J. Broderius, Acting Branch Chief - Toxic Substances Research Branch Howard Zar, U.S. EPA, Region V, 230 South Dearboru Street, Chicago, IL 60604 IPA Ps1- (Ros. 3-7" rnu;;uxgun nun?qu REEION Teleghone Conversation Memorandum Data: I Returning T0: ZVVK Rd? [Hang/L A1649 call . Dion-J 410010; Fo( ly/o/ AMA: . I Area/Access Code: Telephone No.53 2/ ?00 X: FTS FTS Operator: From: Subject: Summary: [5/049u?72 X: [Pam/I ?r 0019c {ze?znuruc?o A OHC dw? (0 ?4 ?1+7 1W f) 5.1? H41) N0 IL u?f'd Ll 1- CL "71.6- WM Samar [94114004, AdAc7f/s' 4/ I (JH To 1? ?gone 0" 744' 44? ac. I pie-u (@464 (44% Csz/Vc' c, (0 Cum/cw, our g/Hf/p; (Liza/K 41? w. floy- MW aw?, Al?e/r w! 1; oz Original to: $4 Cogy to: Type 0 our 9 .. . 1. DIOXINS IN RAINY- RIVER FISH These results~have caused the Minnesota.Department?of? Minnesota Pollution Control Agency Nevember 6, 1935? 1 Mr; Charles Sutfin Director of Water Division . Environmental ProtectioniAgency Region a i 230 South Dearborn Stree i .Chicago, Illinois 60604 Dear Mr. Sutfin: FiSh samples collected for the National Dioxin Plan fromxthe? Rainy River along the Minnesota-Ontario border were found to haVe significant amounts of 243,7,8 - tetrachlorodihenzo-p?dioxin in them (Table 1). 76. . Sample?Site Species/Sample Type - wi.? 1" 1 . . Northern Pike/Whole Fish 85 - vi international Falls. International Falls ?White Sucker/Whole Fish . 23 International Falls White Sucker/Fillet - - 5.9 Sault-Rapids- Walleye/Whole Fish tr 1 12 Sault Rapids White Sucker/Whole Fish 19 *parts per trilliOn Health tolrecommend that no-fish be consumed from the RainyaRiver frOm International Falls to Sault Rapids near Birchdale,; Minnesota until further sampling Can be done. This was announced in a News Release issued on October 29, 1985. a i" The fish samples_were primarily whole-fish samples which generally contain more 2.3.7.8-TCDD than fillet samples. Therefore, additional fillet samples are needed to complete a comprehensiveihealth risk assessment on the Rainy River.- 1 phone: 1935 West County Road 32. Ho'seville, MinneSota'551'13h2785 Regional Offices - Equai Opportunity Employer Mr. Charles Sutfin Page 2 During the week of October 21-25, staff from the Minnesota Pollution Control Agency (MPCA), the Minnesota Department of Natural Resources (MDNR) and the Ontario Ministry of Environment (OMB) collected additional fish samples (see Tables 2 a 3). The OME is planning to do individual skin?off fillet samples at each of the sites except the site on Lake of the woods near Warroad. Nineteen (primarily 5 fish) composite samples were collected for study by Minnesota. Eleven aquatic sediment samples were collected by the MPCA in an effort to determine the source of the The samples were taken from: Rainy Lake, Moonlight Creek, Rainy River and Lake of the Woods. In phone conversations with Howard Zar and with Pete Redman, various funding mechanisms and options were picked. It is important that the 19 fish and 11 sediment samples that are already collected receive high priority. Fillet data are needed to advise large international recreational and commercial fisheries on the Rainy River and on Lake of the Woods about the safety of eating the fish. The additional data will also help resolve international disparities between the Health and Welfare Department of Canada and the Minnesota Health Department. Currently, the Canadians feel that there is not enough information for a fish consumption advisory while Minnesota feels that, although more information is needed, enough exists to warn people. Disparities like this cause confusion, which may ultimately lead people to ignore public health advice. Currently, we are planning to have potential industrial sources of dioxin initiate and pay for sampling programs. It may be necessary for the MPCA to collect effluent or sludge samples if industries do not cooperate in a timely fashion. We may be asking for additional EPA assistance in the analyses of these samples. Your prompt attention to this matter is appreciated. Di ision of Water Quality 1 TABLE 2. FISH SAMPLES COLLECTED FOR 2.3.7.8-TCDD ON THE RAINY RIVER BY THE MINNESOTA POLLUTION CONTROL AGENCY AND THE DEPARTMENT OF NATURAL RESOURCES LOCATION SPECIES N0. SAMPLE TYPE Rainy Lake Walleye 5 Fillet East Basin White sucker 5 Fillet I White sucker 5 Whole Rainy River Walleye Fillet below Int'l Falls Northern pike Fillet White sucker 5 Fillet White sucker 5 Whole Rainy River Walleye 5 Fillet Sault Rapids White sucker 5 Fillet White sucker 5 Whole Lake of the Woods Walleye 5 Fillet Four Mile Bay Northern pike 5 Fillet White sucker 5 Fillet White sucker 5 Whole Lake of the Woods Walleye 5 Fillet Warroad Walleye 5 Whole Northern pike 3 Fillet White sucker 5 Fillet White sucker 5 Whole TABLE 3. FISH SAMPLES COLLECTED EQR ON THE RAINT RIVER FOR THE ONTARIO MINISTRY OF THE ENVIRONMENT LOCATION SPECIES . No. ?Rainy Lake Walleye 25 Brule Narrows White Suck?r? 10 ?3 Northern pike 3 White Fish 11 Burbot 3 Tullibee 3 Rainy River - walleye 7 Int'l Falls White Sucker 20 smallmOuth bass 18 VRainy River Walleye ,28 Sanlt Rapids White Sucker 22 Northetn pike '12 1 Lake of the Woods Walleye Four Mile Bay White Sucker .912 Northetn pike 12Vi, sir. a 1 SU-TUB-B NOV 2 7 1985 Rarry Schade. Director Hater Duality Division Hinnesota Pollution Control Agency 1?35 Nest County Road-32 90seville, MN 55113 near Hr. Schade: Thank you for your letter of November 6, 1985. we are impressed with your rapid followup to the Rainy River dioxin findings. As you know, the EPA Duluth laboratory and my own staff have been straining to deliver results on the fish and sediments cited in your letter as rapidly as practical. ln consequence. an arrangement has been made by the Duluth Environmental Research Laboratory to analyze 8 fish samples and 2 water samples for on a priority basis; these samples have already been provided to nuluth by your staff. Also, we are prepared to commit regional dioxin funds for the remaining 22 analyses of 7.3.7.8-TCDD requested in your letter; these analyses Should begin when the current National Dioxin Study backlog diminishes. we share your interest in analyses of industry effluent and sludges as well as your preference for obliging facilities to provide such data. Zar has suggested to your staff that, in the short term. several Boise Cascade samples could be substituted for lower priority fish and sediment samples anong the twenty-two. For the long tern, we believe it appropriate to formulate a regional plan for investigating papennill sources that makes maximum effective use of industry resources. state resources, our own analytical capacity. and the results of forthcoming Petenwell flowage analyses. He will be developing this plan in full cooperation with Hr. Hora. Please keep Howard Zar of my staff informed as this proceeds. He can be contacted at 312-886-1491. Very truly yours. Charles H. Suiiln Charles H. Sutfin Director, Hater Division a cc: H. Hora, HPCA 91:55 No.933 page one T0: HWARD ZAR FROM: DAN HELHIG RE: Latitude and longitude coordinates for the samples taken on Rainy Lake. Rainy River. and Lake of the Hoods for dioxin testing. :4 - $995119! SAMPLE 10 MEDIA LATITUDE Rainy L.. East Basin Sediment 48? 35' 29' 92? 53' 34? Rainy L., Brule Narrows Fish 43? 35- 53- 92? 55' 15' kgi Rainy R., Fort Frances Sediment 48? 36' 50' 93? 22' 30' Moonlight Creek. Ranier NL-O Sediment 43? 35' 16' 9 93? 21' 02- Moonlight CPOOR. Ranier Sediment 48Moonlight Creek. Ranier ML-Z Sediment 48? 36' 07' 93? 22' 24' Hater I Falls Hater Intake Hater 48? 36' 25' 93? 24' 11' Rainy R. below Sediment 48? 36' 14' 93? 25' 00' Boise Cascade Fish Rainy R. below I Falls RR-Z Sediment 48? 35' 32' 93? 26' 31' sewage treatment plant Rainy R.. Sault Rapids Sediment 48? 38' 34' 94? 01' 16' Fish Lake of the Hoods 4HB-1 Sediment 48? 51' 12' 94? 41' 38' Four Nile Bay Lake of the Hoods 4HB-2 ?Sediment 48? 51' 19' 94? 41' 30' Four Nile Bay Fish Lake of the ?oods Sediment 48? 53' 22' 94? 41' 02' Curry's Island Lake of Hoods I Fish 48? 56' 06' 95? 15' 22' Narroad November 25, 1985 3 i Dr. Howard Zar' 1 I Environmental ScientiSt[ USEPA, Water Quality Branch 230 South Dearborn Street 3 Chicago, Illinois_ 60604 Dear Dr. Zar: Following are comments on the draft National Dioxin Study report and pctential sites for the National Bioaccumulation Study in Minnesota. - NATIONAL DIOXIN STUDY p. 61 - ?Rainy River near Manitou Rapids" Should be changed to "Rainy River near Sault Rapids, Birchdale, Minnesota." This site should be renamed throughout the reportRainy River near International Falls entry: "Bottom feeder? fillet 5.9 ppt' "Predator whole 85.ppt' p. 70 - Were any otherlsamples for the St. Croix River - taken and analjzed'Data for the Minnesota River near Mankato and for Cannon Lakewnear Faribault are missing. Table 4-18 - Rain? River near Manitou Rapids has 2 pulp and paper mills upstream. Ii.- Rainy Rqur near International Falls - contaminated with 2318-TCDD and is belpw 2 large paper mills. Pike Bay.of Cass Lake near Cass Lake - groundwater near. landfill contaminated with hexachloro-dioxin isomers and phenolics from wood preservation industries. ?1935 West County Fload Minnesota 55113-2735 Regional Oi?ces I LakesIMamhawRodzastar Dr. Howard Zar Page 2 Superior Bay near Duluth - fish having detectable amounts of 2378-TCDD, is of a bleach-kraft paper mill and PCP detected in past and present discharge effluents. Mississippi River (Lake Pepin) near Lake City - fish found to contain appreciable levels of 2378-TCDF and PCBs and is of 2 dischargers who have detected PCBs in their effluents in the past. Mississippi River near Grand Rapids - of a paper mill. Mississippi River (Rice Lake) near Brainerd - reservoir of a paper mill. Mississippi River near Little Falls of a paper mill. Mississippi River near Sartell - of a paper mill and PCP users. St. Croix River near Bayport - of a recent PCP spill. Agate Lake near Brainerd - vicinity of illegal PCB oil incineration. Big Fork River near Big Fork vicinity of PCP wood treating facility. Mississippi River near St. Paul Park - vicinity of PCP formulator with known groundwater contamination by PCP. Thank you for allowing us to comment on these reports. Sincerely, k??w Marvin E. Hora, Head Ambient and Intensive Monitoring Unit Monitoring and Analysis Section Division of Water Quality MEH:tjb April 24. 1985 To: Bruce Baker/Jack Sullivan. From: John Sullivan. NCD Subject: Sampling Information For Sludge Samples Collected {or Dioxir Analysis. Listed below is a summary of information concerning the sites where sludge samples were collected'for dioxin analysis. Samples were sent to the EPA Lab in Duluth on April 23, 1985 via Greyhound Bus. EPA No. DE 0162 01 Fort Howard Paper Collection Date: 1-29-65 Collector: Bary Kincaid. LHD Comments: Grab sample. Sample collected from a settling lagoon. 20 solids estimate. EPA No. DE 0163 01 Green Bay Met. Collection Date: 1-29-85 Collector: Bary Kincaid. LHD Comments: Grab sample. Sample collected from a vacuum filter press. 30 to 35 solids estimate. EPA No. DE 0164 Oi Tomahawk Tissue Collection Date: 1-24-85 Collector: John Sullivan, NCD Comments: Brab sample. Sample collected from sludge press. Primary solids. Virgin fiber in use EPA No. DE 0165 01 Owens Illinois Collection Date: 1-31-85 Collector: John Sullivan. NCD Comments: Grab sample. Sample collected from No. 4 lagoon Just east of bridge on the north end of lagoon. EPA No. DE 0166 Oi hard Paper Collectiog_Date: 2-18-85 Collector: Jack Saltes, with assistance of operator at facility. Comments: Brab sample. Sample collected from primary sludge press. 5 9EPA No. DE 0167 EPA No. DE 0168 DE 0159 EPR ND. DE 0170 EPA No. DE 0111 EEPA No. DE 0172 .EPA No. DE 0173 collected from bolt pr?ss. Ifacility for dioxin analysis.? i. Hausau Pkpor Col-loction :Data: 2-12-93 1 . Collector: pack Saltag, NED a! . - Comments: Brab oamplc. Sludgc prossf?3s?z solids Istimato. Neycrhaouslr 2, ?1 Colloction.Dato: 2-12-85 Collectorllaack Baltus, NCD Comments: Sample collected buforu Zimoro unit. Crab sampll. Honinao Papor Collection Data: 2-12-85 Collector: Jack Salt-s, NCD . Comments: Sample from sludge pross. 35% solids estimate. Fungus growth not-d on sludg- surfacos pcior to shipment to lab. Grab sample. Consolidated Paper - Wisconsin River Division Colloctioninato: 3-18 to 3-20-65 Collector:i?l Enqlar with assistanCI from ?oporators at facility. . Comments: Threo day composite sample. Sample Sample Bplit'with Consolidated Papcr - Hat-r Quality Cantor Colloction Date: 3-11 to 3-13-65 Collector: Robort Durkson, NCD with assistanc- "4roo oporatorn at facility. Comoonts: 1hroo day composite oampll. Sampl- colloctod from the bolt prluo. Sampll split with _facility for dioxin analysis. Paper Joint Treatment Plant . Collectionrnato: 3-13-35 . .Colloctor: Robert Dorkoon. NCD Comments: Brob sample from landfill in an area on ongoingmdiopooal. Rhinolopdor Papar Colloction Data: 3-5-85 I Colloctor:_dohn Sullivan/Jerry Nois, MCD- Commonto: Grab sample fora vacuuo filter Nata: All oaoplao'uaro stored in rairigorotor at a C. Saoplco were shipped to lab in a cooler with ica. l! tho district is askod to colloct additional sludgo or sodisont sanplos 4a- dioxin analysis or {any othor analysis. 1 boliovo tho district should coordinato th?fll?pll?o with tho lab providing the analysis. This will no doubt roduco tho prolongod dolaydin shipping samplos to tho lab bocauso 'shipping forms" will ho proparod in tho fiold rathor than in Madison. A portion oi tho sludgo samplos havo boon rotainod and storod in tho District lab in Rhinolandor in tho ovont additional tosts aro uarrantod. I suspoct if dioxin is iound. no may want to rosamplo and do othor analysos on those oanploo (io. volatilo solids, total solids and othor organic such?ao other form? oi dioxin'and iuransl.? cc: Dalo Urso Davo Hildroth. LHD I Robort Smith. Wisconsin Rapids Dolo Erlandson.?Antigo DATE SUBJECT: FROMUNITED STATES ENVIRONMENTAL PROTECTION AGENCY FRECSKDAIV February 14, 1986 Results or Analysis or Papermill sludges For Howard Zar, Regional Dioxin Study Water Quality Branch Hanager . See Below As part of USEPA's National Dioxin Study Tier 5 sampling of Petenwell Flowage on the Wisconsin River, sludge samples and one municipal STP by the State results for these 12 samples and one from Minnesota were completed for USEPA Duluth by Wright State University under contract. In view of the interest in these results I have provided a summary of the findings and a description of the samples in the attached pages. A Spread sheet is included which includes information on facility process, products, and pulp source when known. _Maine results are included. release in the matter is also attached. We would available. Questions in regard to this information may be referred to me at 312-886-1491. Addressees: HO States A. McBride (NH-553) R. Dunst, NDNR J. Cummings (NH-562-A) M. Hora, MPCA D. Barnes (TS-788) . Rogers, OEPA H. Smith (NH-552) Estenik, OEPA Hesse, HDPH Hochmuth, HDNR Schade, MPCA Region Dioxin Task Force Region A. Levin, 5A Bill Walsh, Region I C. Sutfin, D. Bryson, K. Fenner, J. Newman Duluth ERL Barney, Seng, 5H N. Jaworski N. Sanders, T. Yeates, 55 D. Kuehl B. Constantelos, 5H P. Wise, 56L Y.J. Kim, 5H3 H. Mains, SHE J. Beck, SPA EPA FORM 1320-! (REV. 3-76} 2.3.7.8 - TCDD results for Nisconsin and Minnesota papermill sludges Resolts transmitted to USEPA Region on Jae:'30; 1986 by USEPA - Duluth as part of Tier 5 National Dioxin Study at Petenwell Flowage, Wisconsin plant 2,3,7,8 TCDD recovery . pg/g (not) Ft Howard Paper DEUIGZHI to be rerun nd 9 35 Gr Ray Metro STP DE016301 to be rerun nd 9 9 Tomahawk Tissue DE016401 74 77 Owens Illinois DE016501 ND 9 0.5 56 Owens Ill dup DE016501 ND 6 0.4 78 Hard Paper DE016601 10 80 Hausau Paper DE016701 to be rerun nd 24 Ueyerhauser DE016801 6 i 87 Mosinee Paper DE016901 3.5 70 Consol Nisc R. DE017001 23 90 Consol HOCenter DE017101 159 78 Nekoosa Paper DE017201 128 83 Rhinelander DE017301 7.6 88 Boise Cascade* 414 94 Minnesota, others are Wisconsin In at (Inad- uvrsol nun-sol adctod ?avrIol Idahcd ht cost but nus.- loud-ml: ?lnsul- Dar-sol idatod 4. ?unlle kiwi-unsou- Huu Inn-r furl Ikul'd lacs 9 war Dru-tut 0 Saab]. H.158: num- I?d-raw! nan-I Rune (ins-ad: 5.0. 5-301! Etc-I. Northern Int-unit] Fall- Bum Rapids! Hunt-ruin Ramada Port Eduard: Hark-ms. Yonahauk 5km Point Harri I I Plain-lander Rotludn Id Hasn't-I Grown Bag Ere-en Bag Grun- Bag Baku-u font-innit J-u Hui-(curd Hustbrodr HI I I local-it RI) MISS STEVE DEC EHTEF ?air-g I lulu-min Human utmmin Muscat-ult- Has-taugh- I I Hummus": Has-1min Ilium-um I Fuu Fm: I'm-r Hlmin Humor-min Mmcmin Rndroscaqqm 7 1 [hiri- alchfulf Dllrir Blc-hS-ulF alchSulf Sloan-II- Bldifrl?ti?nd-Id Bch'rH. Bld'itrft HID SEQ WIS Fin. aid-44?) ?l-Jva-wl Fin- Finn/Pade Fin. Fm. Tissu- Fin. Fin-I Fir- Fan- Spoc Tit" Tissue Fin- Earn-d Full/135m.- Fine Fin- Pam/5pm: WISH-INTER mm '7 (Ia-unlit! 7 Consolid 1' Consolid 7 7 Moos. 7 7 7 7' 7 HslPap 1? Green Bay 7 Gran-In Bu; 1' Hump TYPE am DISP HS 095 RS LF Jig.? RE LF BS (IFS LF ,I-?orL-nd ans LF ,FurLand FEB Pr all LF HS HS Fr imp/RES LF HS 95 FISH LF 958 RS RS 7 993 was was Fi? mas 1'16 CRIB H5 ili [59 Jul: 'lrt - I59 Irt. - ?128 Irt - 73.9 25 10 7.6 6 3.5 Perm Germ I'd-Green 8.9 mm) Duran Trim?rcm ?rm VERDE) 52 16.6 2.9 for pap-r {pulp H1) t~ our any-1? Con-Mid Emu-lad Cmiol id "chm-l . - Wisconsin Department of Natural Resources North Central District 107 Sutliff Street, Box 818 Rhinelander, WI 54501 For release January 31, 1986 Dioxin detected in paper mill sludges RHINELANDER, WI -- Traces of dioxin have been detected in sludge used tor land-spreading trom two Wisconsin River paper companies: the Department of Natural Resources announced today. The DNR is conducting follow-up tests in cooperation with the two firms, the U.S. Environmental Protection Agency and other state agencies to determine the source of dioxin and its significance. I?Given the low concentrations of dioxin and the fact the sludge was thinly spread in a limited area, we see no reason for alarm," said Tom Bashaw, DNR wastewater supervisor in Rhinelander. "This is one of many situations where we can detect a chemical but we're not sure what health or environmental risks it may represent," Bashaw continued. "Nevertheless, the DNR has requested that spreading of these sludges on agricultural lands be temporarily suspended until it is determined whether groundwater, soil or crops can be affected,? he said. Bashaw emphasized that land-spread sludges from only these two paper mills are suspected of containing significant dioxin levels. Thus the DNR does not anticipate the need to discontinue other programs for land-spreading sludges from sewage treatment plants or other paper mills. Since February, 1934, sludge from Consolidated Papers, Inc. later Quality Center in lisconsin Rapids has been spread on about - ma, - 2. 3,700 acres of Central Wisconsin farmland used for crops such as potatoes. Another company, Nekoosa Papers, Inc., has spread sludge from its Joint Treatment Plant near Port Edwards on 400 acres of its commercial forest land. Federal and stats officials are reviewing the Nekoosa Papers program to determine if any changes are needed. Tests on these sludges indicated Consolidated Papers had 0.159 parts per billion of dioxin and Nekoosa Papers had 0.123 parts per billion of dioxin. Sludge samples from seven other Wisconsin mills ranged from no detectable amounts of dioxin to 0.074 parts per billion. I No federal or state standards have been set for spreading sludges containing trace amounts of dioxin on agricultural lands. The Wisconsin discovery is part of EPA's National Dioxin Study with the states to determine how widespread dioxin is in the environment and determine if remedial actions are necessary. Typically, paper mill sludges are landfilled, but Consolidated Papers and Nekoosa Papers have been using sludge as a soil conditioner. The program was developed to determine if paper mill sludges could be beneficially reused instead of buried in landfills. As part of its monitoring program, DNR will test leachate from landfills which received sludges that may contain dioxin, to determine if dioxin may be moving toward groundwater. Working with the state agriculture department, at DNR request, the Chicago office of the 0.8. Food and Drug Administration is testing potatoes grown on soils treated with these sludges. No results are available, although agricultural experts believe potatoes are not likely to uptake dioxin. - ma- 3. "We are working closely with the paper industry to address - this situation and are pleased at its willingness to not only to pinpoint dioxin sources, but to take any corrective actions that sight be necessary," said Lyman Wible, adninistrator of DNR's Division of Environmental Standards. ff? wible also stressed that sludges should be considered as a usable or resource rather than a waste and efforts to ensure the safe and beneficial use of this material should continue. I'Dioxin" is a collective term for a family of 75 different compounds. Dioxins are known by-products of producing sany products including the now banned pesticides and silvex. Some paints, wood preservatives and even the once popular hospital cleanser hexachlorophene also contain traces of dioxin. The type of dioxin found in these sludges is Consolidated Papers and Nekoosa Papers are the only two bleach kraft mills in Wisconsin. The kraft process produces wood pulp which, in some paper mills, is bleached before it's used to make paper. Based on studies in Maine and Wisconsin sludges from other bleach kraft paper mills nationwide are being tested for signs of dioxin. Investigators have not_precisely determined why dioxins are present in sludges from bleach kraft paper sills. ?This case illustrates the importance of our current program to routinely sample fish, wildlife, water and sediments for signs of toxic substances,? Bible said.'The network of health and environmental sonitoring programs is our IOlt valuable tool for quickly judging the extent of toxics sovesent in the_ environsent,I he added. -- mar; DNR has signs of dioxin. For more information: Wastewater Supervisor at (715) Industrial Whatewator Section1 I already monitorqd fish in Tom Bashaw, Rhinelander, DNR 1 .362-76i6 or Hike (608) 266-1494, 'in indigo; ~307 yr}: -. we Aj? *narxPei, 9 i, :91 's .. . ?Lf3w~?9 - - - art'l? Vii" I - . . Kalamazoo. MI 49MB {msumioms I NATIONAL COUNCIL OF THE PAPER INDUSTRY FOR AIR AND STREAM IMPROVEMENT. INC. April 11, 1986 Mr. Howard Zar Regional Dioxin Study Manager SWQ - TUBB USEPA Region 230 South Dearborn St. Chicago, IL 60604 Dear Howard: I am writing to you, at Russell Blosser's request, to provide you withiinformation about the in?process sampling to be conducted at selected Consolidated Papers Inc. and Nekoosa Papers Inc. mills in Wisconsin. The sampling strategy and its rationale are detailed below. Consolidated Papers Inc. and Nekoosa Papers Inc. have been asked by the Wisconsin DNR to undertake studies to identify the sources of found in single samples of wastewater treatment sludge. These companies have, in turn, requested assistance in structuring a program that will address the immediate concerns in Wisconsin and be consistent with present and future elements of NCASI's national forest products industry dioxin study. In response to this request, NCASI staff have undertaken a review of pulp and paper production processes to identify potential sources of This review suggests-the following to be possible means by which the chemical might find its way into pulp and paper mill wastewater treatment sludges. 1. Wood or bark might contain 2. might be generated in the bleach plant. 3. might exist as a contaminant in,a purchased chemical used in the production process. 4. might be formed in the burning of coal, bark, sludge, or other fuels and sent to the wastewater treatment system with effluent from particulate control devices or ash handling systems. 5. might be contained in purchased pulp (or secondary fiber). . t: FML Lissa a: 41{r9/ Z. I . . 6. might be contained in raw process water or it might be formed during raw water treatment. 7. might be formed in the wastewater treatment plant if chlorine containing compounds are used for bulking control or other purposes. After much discussion between the two companies and NCASI, it was agreed that the most cost effective approach for identifying the source of the dioxin found in the Consolidated and Nekoosa wastewater treatment sludges would be to work with the hypothesis that the bleach plants were the sources. A program has been devised that will allow this hypothesis to be tested by constructing (and mass balances around the bleach plants. If the generation rates of dioxin in the bleach plants do not account for a high fraction of the dioxin found in the sludges, then a second phase sampling and analysis program could be constructed to deal with other possible vectors. If, however, the bleach plants were found to be the major source of dioxin, the companies would devise appropriate strategies for identifying the factors contributing to dioxin formation. The in-process studies will include the following samples. 1. Unbleached brownstock: If significant amounts of dioxin are found in this sample, it will suggest that additional work is needed to identify the vectors into the pulping process the wood supply and chemical inputs to the liquor cycle, etc.). 2. Bleached pulp from the final stage washer: 3. A sample of bleach plant effluent representing the combined sewers from the bleach plant: 4. Primary sludge and secondary sludge: These samples will be used to estimate the mill-wide dioxin losses, which will be compared to the generation rates documented in the bleach plant mass balances (constructed on the basis of samples 1. through 3. listed above). If it is determined that the mill-wide losses are too high to be accounted for by the generation rates in the bleach plants, thought will have to be given to means for identifying the other vectors listed above. It is known that some of these vectors can be eliminated from consideration at these particular mills, however. The samples listed above will be composite samples, comprised of an as-yet-unspecified number of equal-volume aliquots, collected over a specified time interval. The sampling times at each point in the process will be spread over an interval which includes the best estimate of the time of arrival of materials moving through the mill and waste treatment system. Let me know if I can provide additional information. Sincerely, Reid A. Miner Regional manager- pd Jim Weinbauer, Consolidated Papers Inc. Dick Grund, Nekoosa Papers Inc. Russell Blosser, NCASI Jim McKeown, NCASI 'News Release 1* 49;: Minnesota Pollution Control Agency For more information: FOR IMMEDIATE RELEASE Carol Hockovak. HPCA. 6l2/296-744l - October 29. l985 David Gray. HDH. 6l2/623-5352 2.3.7.8-TCDD DISCOVERED II RAINY RIVER FISH Testing of fish taken from the Rainy River has indicated the presence of (2.3.7.8 T600). the Minnesota Pollution Control Agency (HPCA) and the U.S. Envirmntal Protection Agench (EPA) said today. Because a high concentration of the chemical was found in one of the samples, the Hlnnesota Department of Health (50H) is recommending that no fish be consumed from the affected portion of Rainy River until further sampling and testing can be done. Health officials seld they expect to be able to pre- pare a more definitive health risk assessment by March 1986. The Rainy River lies on the border between Minnesota and Ontario and flows from Rainy Lake to Lake of the Hoods. The health officials' recommendation covers the stretch of the river from below the dam at International Falls/Fort Frances to Sault Rapids near Birchdale. Minnesota. The chemical found in the Rainy River fish is the most toxic form of a family of 75 chemicals celled polycholorinatad dibenzodioxins The levels detected in four whole fish saealas free the river ranged from 12 to 35 Darts per trillion Only one fish fillet saaple was included in the testing: it showed a legal of 5.9 ppt. Fillets. the edible part of the fish. generally contain approximately half the levels of TCOO found in whole fish. The testing was part of the EPA's national study to determine the extent of dioxin contamination in the environment. (more) MI Pres-?lm: Drean D6 career) Rainy River page two Staff from the MPCA. the Minnesota Department of Natural Resources. and the Ontario Ministry of Natural Resources have already collected additional fish samples for further testing. The samples include walleye and white sucker from two locations on the Rainy River; Rainy Lake; and on Lake of the Hoods near Harroad, Minnesota. and in Four-Mile Bay. The Minnesota samples will be analyzed at EPA laboratories. The complex laboratory analysis will take several months to complete. EPA officials said. Minnesota and Ontario environmental agencies are cooperating in the additional sample collection and will be sharing information as test results become available, the MPCA said. I Animal studies have shown that 2.3.7.8-TCOD is extremely toxic, causes cancer, increases susceptibility to other carcinogens, and has fetotoxic effects; however, reactions to vary greatly among different animal Species. Many of the other 74 appear to be much less toxic and carcinogenic. Studies of humans accidently exposed to suggest that animal data may not be directly applicable to humans. The source of the TCDD in the Rainy River is not known. TCDD is a by-product of the manufacture of several substances. chiefly 2,4,5-trichlor0phenol. which is used as the basic ingredient in the manufacture of several pesticides. Recent studies have raised concerns that dioxins may be formed through some bleach-kraft paper production processes. Combustion sources. such as municipal and industrial incinerators, may also (mare) Rainy River page three produce chemicals in the PC00 family, depending on operating temperatures and the types of wastes burned. In an effort to begin to track down the source of the contaminant in the Rainy River fish, MPCA staff have collected sediment samples, which will be analyzed at the same time as the fish samples. The results from the fish and sediment testing will be used to define the extent of TCDD contamination in the Rainy River system, MPCA officials said. SAMPLING RESULTS Sample Site Species/Sample Type (ppt)* International Falls Northern Pike/Whole Fish 85 International Falls Hhite Sucker/Hhole Fish 23 International Falls Hhite Sucker/ Fillet 5.9 Sault Rapids Walleye/whole Fish 12 Sault Rapids Hhite Sucker/Whole Fish 19 parts per trillion ?i I TECHNICAL DATA {Please read Instructions on the r'rrmr brforr rompit rum 1 REPORT NO. 2. 3. ACCESSION N0. EPA-600I6-81- 003 4.1ITEE AND SUBTITLE 5. REPORT DATE Risk Assessment on (2,4,S-Trichlorophenoxy) Acetic Acid sePtember 12: 1980 (2,4,S-Trichloroohenoxvl Proninnir Arid (TCDD) I I 8. PERFORMING ORGANIZATION REPORT NO Carcinogen Assessment Group in. 9. PERFORMING ORGANIZATION NAME AND ADDRESS PROGRAM ELEMENT NO. Carcinogen Assessment Group Office of Health and Environmental Assessment Environmental Protection Agency i In-house I Washington, D.C. 20460 I. 12.5PON50FIING AGENCY NAME AND ADDRESS TYPE OF REPORT AND PERIOD COVERED 9 Office of the General Counsel "esponse/Assessment - 14. SPONSORING AGENCY CODE Env1ronmental Protection Agency . Hashington, 0.8. 20460 15. SUPPLEMENTARY NOTES 16. ASST HACT . have been induced in mice and rats at low doses'g? TCDD. TCDD has been shown to be a cancer promoter. These results, together with the strongly suggestive evidence in epidemiology studies, constitute i substantial evidence that TCDD is likely,to be a human carcinogen. It appears that TCDD is a more potent carcinogen?than aflatoxin Bl which is one of the most potent carcinogens known. The levels of TCDD (contained as an unavoidable contaminant of the used in the studies apparently were too small to produce an observable response in those experiments. The lack of a statistically significant tumOr incidence in most of the studies on the product may be attributed to the very low levels of TCDD in the product relative to the levels at which it produced carcinogenic effects in rats and mice, as well as to deficiencies of those studies. However, since TCDD is a carcinogen, any product containing TCDD, including and silvex, can be considered to pose a human carc1nogen1c hazard. FurthermOre, a rat study on specially purified provides highly suggestive evidence that essentially pure may be a human carcinogen. Quantitative assessments have been caICUlated fOr the carcinogenic risk posed to humans. n. KEY woaDs AND DOCUMENT ANALYSIS 3- Descale'rons' ENDED TERMS c. cosATI Ulour 18. DISTRIBUTION STATEMENT 19. SECURITY CLASS {This Report; 21- N0. PAGES NTIS - Release to Public UNCLASSIFIED a 276 to. smuan cuss {Thu page) 22.I3mce UNCLASSIFIED ?na I EPA Form zazo-i fa? 25-? .uh?m? . th?uJ?I-c??: .- Iv'v?D. an union 5 Date I?i? G. Am n6 to Coa- Locuion Ola? cmef Fro- ISRA IJCK-14 of Regional Administrator 50L _1543? 9 0ff1c? or Great Lanes ultmonal SPA _1g?x-II? ulfico of P6611: Affairs SPL Library St or Regional Lounscl Air, Hater, TOIICS, a Genera} Llu 30110 East: I Lr-rnancy Rasponso [5n air Hana clan: - Ilr iuancc - Iir I Eadiatio: run-nuts L: run-tn 0! SUP I t! rv fOC?r V. f' 30?? I I00 3 CI CK-ll ?at: on S. rl?0ff1ce of Criminal Enforce-cut I I 10 a JACK Orricc of Inspector jays Per Iolocon Action Rc-Ir 3 {Sec Being or Reverse) i5 Fau- {Rev. 11/84] .- . 93:23 HPCFI #0383 681 MINNESOTA POLLUTION CONTROL AGENCY TO: Howard Zar/Judy Back I 5 COMPANTE OR AGENCY: EPA -- haaion FAOSIHILE NUMBER: 1-32-312/335-9095 3 i I. SUBJECT: news release -- fo?l'low up testing to natTOna?l dioxin stud} I I I 1 FROM: I Mockovak AGENCY: HPCA TELEPHONE NUMBER: 612/296-7441 FAOSINILE NUNOER: (612) 297-1455 i DATE: May 28. 1935 PAGES TO FOLLOW: four (4) i PLEASE NUMBER ALL PAGES I . IF YOU HAVE ANY QUESTIONS REGARDING THIS TRANSMITTAL. PLEASE CALL (612)296-7788 1 I :L?l?l 'fx - Magi/MS - ?16% 634/ . ,7 . -meuw;?g page one No we Release Minnesota Pollution Control Agency For further information: FDR RELEASE Carol Mockovak 612/296-7441 9 May 28. 1 86 RESULTS FROM STATE FOLLOH-UP T0 DIOXIN STUDY ANNOUNCED The Minnesota Pollution Control Agency (MPCA) said today that low levels of 2.3.7.8 tetrachlorodibenzo-p-dioxin (2.3.7.8 TCDD) have been found in sludge samples taken from the Potlatch papermill in Cloquet and Western Lake Superior Sanitary District in Duluth. Agency officials emphasized that there is no evidence that area residents have been exposed to harmful levels of the chemical. The results came framEf' testing conducted by MPCA as a follow-up to the Environmental Protection Agency's (EPA) national dioxin study indicating the presence of 2.3.7.8 TCDD in sludges from bleach kraft process paper mills in Maine. Wisconsin. and northern Minnesota. Sludge trillion (Pvt). while those from ran from 51 to 53 ppt. analyzed at the EPA laboratory in Duluth. samples from the Potlatch mill ranged from 26 to 34 parts per The samples were Hastewater from the Potlatch mill receives primary treatment at the plant and then is sent to for secondary treatment. Sludge: are generated at both facilities during the treatment process. Tests were also run on both the solids and lieuid portion of the effluent from The MPCA said that the testing indicated that dioxin is not being discharged into Lake Superior in the water portion of the effluent. Tests run on the solids portion of the effluent did not provide information comparable to the sludge data due to differences in detection limits. Dioxin typically bonds (mare) 1935 W. County Road 82:. MN 55113 86 BB: 29 NO. 883 893 DIOXIN STUDY FOLLOH-UP Page Two to solids and does not accumulate in water. and MPCA officials said the does an excellent Job of removing solids from its wastewater. Sludges at both Potlatch and are currently incinerated. Incineration at proper temperatures and burn time; will destroy dioxin. and officials from Potlatch and are cooperating with HPCA staff to determine whether their burning operations are sufficient to destroy the chemical. officials say they are confident that the high temperatures and long burn times in their facility's fluidized bed incinerator are fully destroying chemicals in the Sludge. In earlier years of its operation, Potlatch disposed of its sludge in the St. Louis River. Before incinerators were fully operational. sludge:: from the plant was spread on grass and cropland (from 1979 to 1985). Although the levels of dioxin in the sludge are well under the Center for Disease Control's level of concern for human contact with soil (l.000 ppt). the HPCA and are deciding what further testing should be done to determine if there has been any environmental impact from the use of the sludge. The state of Hisconsin is currently doing work to find out whether crops grown on land spread with dioxin-containing sludge generated from bleach process paper mills take up the chemical. WCA staff emphasized that it is only sludge containing dioxin that is of concern. Sludges from wastewater treatment plants not receiving wastewater frah bleach process paper mills or from paper mills that do not use the bleach pro- cess are considered a usable or recyclable resource rather than a waste. A small sample of fish from Superior Harbor collected by the state of Hisconsin for the national dioxin study showed low levels of dioxin. Minnesota and Hisconsin officials said they will cooperate in further testing of fish from (more) s?rv ace NFL-H NO. DIOXIN STUDY FDLLOH-UP Page Three the St. Louis River and the Duluth/Superior Harbor in order to get a fuller picture of the extent to which fish in the area may have actumulated dioxin. Results of this work will determine the need for future fish consumption advisories. HPCA officials said there is also a need to do more testing on sludge and effluent from Potlatch. The company told the MPCA that two samples they collected in December 1985 showed no detectible levels of dioxin. The HPCA samples were collected in March 1986. which indicates that the dioxin content of the samples may vary at different periods of time. The EPA began the national dioxin study to discover the extent of dioxin:: contamination across the country. Samples of air. water. soil. and fish were': collected for analysis from over 1,000 sites in 1984. Host test results were released during 1985. A full report on the study will be presented to the U.S. Congress in early fall 1986. The study's finding of dioxin in sludges from bleaCh kraft paper mills has prompted discussions among the EPA. the HPCA, and the paper industry's environmental research organization. the National Council for Air and Stream Improvement. Inc. (NCASI). The groups are considering a national study to discover how dioxin is being produced unintentionally in the bleached pulpmaking process. There is no conclusive data showing the effect of dioxin on humans, but animal studies show that the chemical is extremely toxic. causes cancer, increases susceptibility to other carcinogens, and has fetotoxic effects. Although reactions to the chemical vary greatly and it cannot now be proved that (more) 05/ 28/86 86: 39 MPCR NO. 363 895 DIOXIN STUDY FOLLOH-UP Page Four animal data is directly applicable to humans. the EPA and MPCA said they are taking a conservative and protective stance toward human health concerns in their efforts to find and eliminate the chemical from the environment. The initial round of testing in the EPA's national dioxin study analyzed samples for only one member of the family of 75 polycholorinated dibenzodioxins -- 2.3.7.8 TCDO. It did so because that chemical is by far the most toxic of the 75 related chemicals. The f0110u-up studies conducted at Potlatch and also were analyzed for a second chemical -- 2.3.7.8 tetracholordibenzofurans. This chemical was; found at higher levels than the 2.3.7.8 TCDD. but its significance is less due to its lower toxicity. In analyzing the effect of contamination by these chemicals. the MPCA will consider the combined effects of both substances. .- dial! (to engine OFFICE OF THE GOVERNOR ,rgum/ AUGUSTA. MAINE 04333 gamma roe n-mromt RELEASE UM September l0. ??35 try/?1011? AJPLUM - Governor Joseph E. Brennan today announced that low levels of dioxin I if tin/C, dioxin levels found in sludge from some kraft paper mills. /1??J?%t1r ?Althouqh there is no reason to believe the dioxin levels represent a direct health threat at this time, want tp?be certain that we continue to do all we can to make our environment as safe as possible from the threat of manmade pollution,? Governor Brennan said. A "Accordinglv, upon determination that there are levels of dioxin in the sludqe. have asked the Department of Environmental Protection here and "The kraft mills have voluntarily suspended anv Spreading of sludge since December of last vear in response to preliminary concerns expressed by the DEP. Those areas that received sludge within the past two years will be tested. "Second, federal and state officials, along with the paper conpanies. will be working to determine the source of the dioxin in the sludge with the hope that it can be removed. ?And third. because of the national implications relating to dioxin levels in the sludoe. have asked that we communicate with other states to alert them of our concerns and wark together toward possible solutions. it is exoected that the U. 5. EPA will continue its research efforts and will he workinq with the states to determine the aftent of the problem. "Commissioner Henry warren 0f the Degartment of Environmental Protection will be reSDOnsible for coordinating the State's effort," the i Gavernor said. Ill! 118 release a eaetnluousrnv i - . juuroaeenou orncs September 10. 1935 ?Hf?ggja??f52;fm CONTACT: Henry A. Magnuson OFFICE - 6%2-3166 I none - era-l?oo soa IMMEDIATE RELEASE the governor has indichted, the Paper Industry is c00per- ating fully with the continnibg tests which are set up in an i attempt to pin down whether there are sources of contamination. We want to stress that the indicated levels of contamination would be far below the safe limits established by the U. S. -$nvironmenta1 Protection Agency and the Maine Department of Environmental Protection. At the same time, we believe it is important to find out where these trace amounts are coming from. I Only a few months ago, the Paper Industry. in cooPeration with the EPA. DEP, UHO and the Natural Resources Council of haine, funded a comprehensive study on the composition of paper mill sludge, and it showed no indications of dioxin. That specifically looked for dioxin, with detection limits at less than one part per billion. These recent.tests were with new "equipment having a sensitivity one-thousand times greater. We don?t know what these,new, unverified samplings mean yet they don't give us a clue as to whether the contaminants may come frOm an internal or external source. Obviously, we want?to find that out as much as anyone. In addition to cooperating with the state and federal agencies. we are in the process of retaining eXperts to assist us in the,determinations needed to I address any problems which may become.identified as a result of the current investigations. I I -PIIO- I I i (Ingrarr- Haldn Prev Opts 18. 1985, FOR RELEASE 0N RECEIPT: I?r 0., Tau" ?nds u. 5. Environmental Protection Agency (EPA) has continued last month's test results showing tiny'amounts of dioxin in sludge generated by four Maine paper mills, Henry E. Warren, commissioner of the Maine Department of Environmental Protection, said Friday (Oct. 18). Harren said that William J. Walsh, EPA's regional dioxin coordinator, had notified him by letter that confirmed data for dioxin analyses on paper mill sludges collected last sunmer showed 32 (parts per trillion) in sludge from Boise Cascade at Rumford, 51.3 from International Paper Co. mill at Jay, 2.8 from Scott Paper's paper line operation at Fairfield and 16.6 from S. D. Warren's Hestbrook operation. The EPA said no detectable?anounts of dioxin were found in Great Northern Paper Company's sludge at Hillinocket or at Scott Paper Company's pulp line Operation at Fairfield. Hhen the unconfirmed test results were released by EPA last month Gov. Joseph Brennan said "Although there is no reason to believe the dioxin levels represent a direct health threat at this time, I want to be certain that we continued to do all we can to make our environment as safe as.possible from the threat of manmade pollution." The confirmed levels of dioxin found in sludge from the Rumford and Jay mills on the Androscoggin were similar to levels found in fish samples from the river repzrted by EPA last May. The sludge tests are part of continuing Tederal and state efforts to find the origin of the dioxin. Governor Brennan has named Conmissioner Warren as state coordinator of Maine's role in identifying and dealing with dioxin presence in Maine. 0 acres!? 11. 1935 I Henry.E. Harren, Commissioner UNITED STATEs Envmor?mumt PROTECTION AGENCY REGIOH I Department of Environmental Protection State Hoese Augusta . ME 04333 Dear Commissioner warren: The confirmed data for dioxin analyses on the during the summer of 1985 are as follo?s: Location Boise Cascade - Rumford International Paper - Jay Scott Paper - Fairfield Scott Paper - Fairfield 5.5..3arren - Westbrook Great Northern Paper - Hillinocket ND Kot Detected Parts per Trillion D.L. Detection Level . 1 I I i Sample -Sludge Sludge Sludge Sludge Sludge Sludge so STREET. L'Exmo'ron. 02m (paper line) (pulp line) Q. paper mill sludges collected 2.3.7.3 - ICDD (pg/5 or not) 32.0 51.3 lab duplicate ND - 1.95 D.L. field duplicate ND 4 0.410 D.L. also. confirned data from the tier 5 location, Bangor and Aroostook Rail- road right-of-way at Crindstone. are available. have been analyzed, finding the following levels 35 rpt. 1* em. 17 Wt. 13 ppt, as further analyses are completed. Sincerely. ?1 Killian J. Kalsh Et:icnal Dioxin Coordinator c'c: '.2tt Scott, RE DEP Eteve Groves, HE DEP Savid Frasca. U.S. EPA 13 ppt. and 13 not. Only 6 of 23 samples colletted of dioxin (2.3.7.8 ICDD) I will keep you updated a Pa 1 a sum -: 9 DIOXIN-CONTAMINATED SLUDGE IN MAINE r' HAY LEAD TO STATE prom: STANDARD . x, I The discovery of dioxin in the parts-per trillion range in Maine pulp and papermill sludge may lead to the development of a dioxin standard for the land application of sludge in the state. The state Department of Environmental Protection first became aware of the presence of TCDD in Maine sludge during a 1984 national dioxin study. 'Ironi- cally, Maine was chosen as a control state for the study because of the lack of heavy industry in the state and the supposed pristine condition of the environ- ment there. Analyses of fish in the state turned up small levels of dioxin._ Tracing the source of dioxin in the fish, scientists guessed that pulp and paper mills might be the culprit. Another possible source might have been run off from power line right of ways, because herbicides used on the ROHs contain dioxin. Five PPT of Dioxin Found in Sludge However, when the Kennebec Sanitary Treatment District facility, which re- ceives waste from pulp and paper mills, took a sample of its own sludge, the unverified results from the lab came back at 5 ppt. when the state DEP was informed, Gov. Joseph Brennan issued a press release letting the public know of the presence of dioxin in sludge, but cautioning that the numbers were still unverified. Five pulp and papermill sludges were examined in June by DEP. Lab results analyzed by the federal Environmental Protection Agency, Region 1, showed 2,3,7-8 TCDD in amounts up to 51.3 ppt. DEP Assistant Engineer Karen Townsend' collected samples from five municipal treatment facilities around the state which receive pulp and papermill waste on Nov. 13-15. The samples were sent to the Brehm Research Lab at Hright State University in Dayton, Ohio, where they are still being analyzed. Official results are expected in January. wansend remarked that the reason more tests had not been taken was because each test "is very costly." The POTH samples she collected will cost $600 each to analyze. Fear of Lands readin Dioxin-Thinted Slud There is a great deal of concern in the state about sludge which might be tainted with toxic levels of dioxin. Hhile some scientists have debated the carcinogenicity of the substance, others are certain that it can be harmful to human health. "From a toxicological standpoint, dioxin is considered very toxic," said Townsend. Nevertheless, there is still no federal standard controlling dioxin, and the only state with a dioxin standard is Missouri. Townsend said that if high enough levels of dioxin were found in sludge in Maine, DEP may develop a standard to limit the amount that could be present in sludge to be After the governor announced that unverified tests showed traces of dioxin in papermiI1331udge, an environmental group, Citizens Opposed to Haste Spreading (CONS), was'fermed. The group is seeking to halt the spreading of dioxin-tainted ?sludge on4farms?and forests throughout the state. 0f the 105 municipal publicly owned treatment.works in Maine, approximately N5 are involved in ud Ff: go . ?"There'ls a trend toward of sludge throughout the state, rather than Just dumping the stuff in landfills," Townsend commented. 1 jrwcauf- [094/715 0016 rbiiglrip/7% I I 'Background to findings of.dioxin in Wisconsin Papermill sludges HDNR is issuing a press release in this matter Zar 5wq 886 1491 1/31/86 On Jan. 30. Region forwarded final chemical results to HDNR of analysis of 2.3.7.8 - TCDD (dioxin) in Hisconsin papermill sludges. The analyses were performed by Wright State University under contract to Duluth ERL as part of the National Dioxin Study. Of 12'sludges analyzed for 2.3.7.8 - TCDD. 8 were positive. 1 was non - detect, and three will be rerun. All values were well below 1ppb the CDC level of concern in residential soil. 'However. three values exceed SOppt. which would make them of possible concern if the sludge were being applied to grazing land. No application to grazing land has occurred in Hisconsin. however one of the companies with higher levels (Consolidated) is applying sludge to crop land (potatoes) and another (Nekoosa) is applying sludge to forest land. Although prior comments by CDC have not indicated human health concern regarding crop or forest applications. Hisconsin is expected to take the precaution of stopping the spreading until more information is in. Hisconsin's position will be embodied in a press release that will be attached to this note when received. Hisconsin has also sampled crops. Initial results for potatoes are negative for 2.3.7.8 - TCDD. These results were obtained as part of Tier 5 of the National Dioxin Study. Environmental samples were taken in 1984 and 1985 from Petenwell flowage of the Hisconsin River. near Hisconsin Rapids. Sludge samples were taken throughout the state. The study was done because carp from the Petenwell had exhibited dioxin levels. The carp fishery is now closed. It was the assumption of the.tier 5 study that fish contamination was due to past use of slimicides in the mills. However, the new sludge results and similar results from Maine and Minnesota suggest that some process in the mills is causing dioxin formation. Hhile present data are sparse, the hypothesis is that bleaching of kraft pulp may be the source. Based on sludge results from Haine of several months ago and fish contaminant findings in a number of areas. NCASI. the paper industry's environmental anm has begun a study of the matter. beginning with sampling and analysis of papermill sludges. fish, and food products on a nationwide basis. Region V's Dioxin Task Force has formed a papermill subgroup chaired by H. Zar to determine apprOpriate followup. Zar and G. Amendola are working with headquarters personnel to develop an investigation of selected papermills with positive results in sludge. The investigation is intended to provide a basis for point source control efforts at the facilities. Efforts are also underway to categorize papermills in the region and to.obtain fish samples below mills of greatest interest. State or ?Tisconsin DEPARTMENT January 27, 1986 H5. Louise Fabinski USEPA . Region - 230 South.Dearborn 4 Chicago, IL 60606 Dear Louise: OF HEALTH AND SOCIAL SERVICES DIVISION OF HEALTH MAIL ADDRESS 1 WEST WILSON STREET v.0 sox 309 MADISON. WISCONSIN 53701-0305 We are requesting the assistance of the Center for Disease Control and the Superfund program staff to provide us assistance in assessing the risk on dioxin contaminated sludge. - As you are already aware, we are anticipating the confirmation by the EPA laboratory of 2.3.7.8 TCDD in concentrations up to 200 in sludges from Although still on a small scale, these sludges are part of a land spreading program which in- cludes land used to produce human consumption products. As an interim measure, until the extent of the problem is better defined and understood, we have advised DNR to impose a moratorium on additional spreading of dioxin con- at least two Wisconsin, kraft process; paper mills. taminated sludge. Hopefully no remedial action will be necessary on the areas already spread with the sludge and no significant risk to Wisconsin residents Re are aware of the work already performed by Dr. Hargolis when a similar contamination occurred in Maine. We would ask that this work be extended to assist us in developing a Public Health Policy on the risks posed by spreading contaminated sludge. We are particularly interested in a rec- ommendation on maximum concentrations which could be spread on land for different uses. As soon as the final laboratory results and their data reach us we will forward it to you. expect. Thank you once again for your assistance. Sincerely 30R THE BUREAU OF HEALTH AND PREVENTIONHenry A..nnderson, H.D., Chief Seetion of Environmental and Chrohic Disease Epidemiology . HAhzsg In the meantime this will alert you on what to 51.5 -- 7 Jr? as {Titrifi?iifififi?z?rrm m. . UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Ti REGION 5 mags 230 SOUTH DEARIORN ST. - CHICAGO, ILLINOIS 41. I REPLY TO THE ATTENTION 0F: 5H0-TUB-8 NEAR 3 1 1986 Mr. Russel Dunst Division of Environmental Standards Wisconsin Department of Natural Resources P.0. Box 7921 Madison, HI 53707 Re: Information Requests to Papermills Dear Mr. Dunst: Enclosed for your use and information are Nekoosa Papers, Inc., reSponses to our November 19, 1985. Information Requests concern- ing their Port Edwards Mill and Nekoosa Mill. You will recall they were granted a 30-day extension to respond. We have summarized in Table 1, attached. the chemical usage infor- mation received for both mills. Primarily. two chemicals, mainly in the sodium salt form, were used: Pentachlorophenol (PCP), and 2,4,5-Trichlorophenol Substantial amounts of both were used, but PCP usage was by far the greatest, amounting to 44,682 pounds through 1981 at the Nekoosa Mill and 377,356 pounds through 1983 at the Port Edwards Mill. All process losses were reported as leaving in the wastewater. No specific dioxin contamination was reported. Very uly yo 5, Howard Zar Regional Dioxin Study Manager Enclosures cc: w' Mains, enclosure) "o Sens. SHOP-TUB-s Port Table 1: Smnnary of Chemical Usages by the Nekoosa Papers, Inc. Nekoosa Hill and Port Edwards Hill References: Responses dated 1/23/86 by Nekoosa Papers Inc., to U.S. EPA Information Request dated 11/19/85 Mill Chemical Process Years Nekoosa Slime Control on Paper Machine 68,69 - Othen phenols 53,69 PCP 52:68?71 PCP Preservative for Paper Coating 69-81 Slime Control on Paper Machine 61,68,69 Edwards. 73,74,78 Other phenols 61-67 61-68 73,74,78 PCP Preservative.for Paper Coating 50?83 Range of Yearly 22222:.1151 750;1188.5 660; 12.6 loo?4,900 24-1,241 171-2,304 43-16,592 Mostly. the sodium salt of the chemical listed here was reported used. The Responses often identified this chemical as 2,4,5aT Total Usage, 1,949 573' 5,032 38,000 2,947 5,818 44,356 332,500 American Paper Institute, Inc. 260 Madison Avenue. New York. NY. 100161212: 340-0611) cable address: New York Of?ce of me Prasidm: September 16, 1987 Mr. Steve Sawyer Executive Director Greenpeace International 1611 Connecticut Avenue, N.W. Washington, D.C. 20009 Dear Mr. Sawyer: Recently, I read with interest a new publication of I Greenpeace's Great Lakes Campaign, "No Margin of Safety: A Preliminary Report on Dioxin Pollution and the Need for Emergency Action in the Pulp and Paper Industry." I assume that you, like I, have an interest in legitimately protecting . the reputation of the organization which you represent, and . that credibility is an important component of that reputation. In that regard, we are each entitled to our opinions on matters about which reasonable minds can disagree. But there are a number of incorrect statements of fact in your publication, and I thought you might appreciate having them brought to your attention. I have enumerated them in the attachment to this letter. In general, the facts set out in the attachment substantiate that the U.S. pulp and paper industry is only a minor source of nationwide dioxin co tamination. The attachment also points out that the industry has worked diligently on the joint EPA/Industry five mill screening study which, in essence, is the natural follow-up to the findings that are contained in the National Study. In that sense, the five mill study augments rather than subverts the National Study. From the beginning, we have taken steps to inform the public of the existence of the Five Mill Study. The commencement of the joint study was publicly announced in July, 1986 to employees, local government and press in the locales of the five volunteer participating mills. In Sen-mg the pulp. paper and J'ndusrry addition, in each instance state governments and regional EPA offices have played significant roles in the study. All of these parties have been apprised of the progress of the joint study. Both EPA and the industry have been committed to release the results of the study when it is completed. The points covered in this letter and the attachment are not all-inclusive, and obviously, we also have differences of points of view and interpretation. I hope, however, that in writing to you I have helped clarify what I believe are some very serious misstatements of fact in the "No Margin of Safety" booklet. Sincerely Red Cavaney Statement (page 1): MARGIN OF ATTACHMENT the National Dioxin Study?s preliminary results led to the discovery that pulp and paper mills are a major source of dioxin pollution, despite EPA and industry officials? best efforts to sabotage and delay the study." Relying on data released by EPA as part of its report on municipal incinerators, it appears that the U.S. pulp and paper industry's unintentional generation of dioxin is only a very small percentage of the total dioxin generated in the U.S., perhaps less than 10 percent, for example, of the total generated by municipal incinerators alone. As we later note, the paper industry has made pg effort in any way to delay or to influence the content of the National Dioxin Study. pulp and paper manufacture had been suspected as a source of dioxin pollution since Fact: Statement (page - 7): at least 1980." Fact: This statement probably has reference to the industry?s earlier use of chlorophenol-based slimicides. After possible contamination was discovered, the industry has generally, and voluntarily, discontinued use of these agents to control slime in the production process. The current focus on dioxin came only in late 1985 as the result of detection work done under the National Dioxin Study, and that was a surprise to both EPA and the industry. In 1984, the industry had participated in a study with the State of Maine to determine the components of the industry?s sludge. Samples were analyzed for dioxin with detection limits below one part per billion, which represented the best analytical capability at that time, and no dioxin was found. The National Dioxin Study utilizes more sophisticated testing methodology for detection into the parts per trillion and quadrillion. These new analytical techniques led to the most recent detections. that a major secret research program on pulp and paper mill dioxin sources was underway, belying government and industry claims no serious problem is posed by dioxin pollution from the industry." The joint EPA/industry research program was entered into because of the desire on the part of the industry and EPA to obtain more complete information on the levels of dioxin being generated at some pulp and paper mills, and, equally as important, to identify the sources of the dioxin. The commencement of the joint study was publicly announced to employees, local government and press in the five volunteer mills participating in the In addition, all five state governments and regional EPA offices have played significant roles in the study. All of these parties have been apprised of the progress of the Again, the industry?s contribution to overall levels of dioxin appears to be small. "The public might never have learned the full scope of the joint EPA-Industry As previously noted, the public had been informed of In addition, both EPA and the industry have been committed from the very beginning to publicly release the results of the study when it gave industry control over study design, sampling plans, and pace of the All aspects of the study were jointly agreed to between EPA and the industry. The technology required to measure dioxin of the levels being studied is very new. Currently, only two independent labs in the nation are equipped to test statement (page VI - 11: Fact: joint study. joint study. statement (page VI-Z): Fact: the joint study. is completed. Statement (page VI-Z): study." Fact: samples -- and the process is both complex and time consuming. As a result, many aspects of the study -- most importantly pace -- were in the hands of the laboratory rather than EPA or the industry. We and EPA, however, have always wanted the information sooner rather than later. statement (page VI - 2): EPA signed an agreement with an industry trade association substituting secret studies for regulatory action Again, the Joint EPA/Industry study was publicly But as your report later recognizes, there were many unanswered questions at the time of the initial dioxin detections with, apparently, no clear-cut regulatory direction indicated. "The circumstances suggest that this agreement has delayed not only the pulp and paper dioxin study, but also the entire National Dioxin If anything, the joint study has allowed the National Study to be released earlier than it might Had the questions surrounding the unexpected detections at some pulp and paper mills been examined as part of the National Study rather than separately, more time would have been The joint study is progressing well, and all parties involved have worked hard to see that it is completed as soon as possible. and for industry participation in risk assessment on papermill dioxin and giving industry strong influence over risk assessment both for the joint study and for the National Dioxin Study itself A similar 'informal agreement? to allow industry participation in risk assessments would give industry influence over the National Dioxin Study itself." Fact: announced. Statement (page VI - 2): Study." Fact: have been. necessary. statement (pages VI - 15, 16): Fact: When the proposal for a joint study by EPA and the industry was first presented to the industry, many made the observation that the study would result in a great deal of numerical data which would have little or no meaning to the general public. The suggestion was made that EPA should provide a risk assessment of what those numbers meant. That suggestion was made to EPA as a possible component of the joint study, but it was not included in the final agreement document. The industry has made no attempts to influence any aspect of the National Study, including any attendant risk assessment material, but has stressed the need for EPA to do such work. Statement (page VI - 19): "Costs would be shared 'on the Fact: Statement Fact: statement Fact: basis of 25 percent funding by U.S. EPA and 75 percent funding by industry? for most if not all the samples, possibly suggesting a corresponding ratio of control over the study." The industry agreed to defray a large portion of the testing expenses -- most of which consists of payments to independent laboratories for their work -- in order to get the study underway in a timely manner. No other motives were involvedthe industry "controls" the work of the independent laboratories. (page VI - 19): "Clearly, Ontario officials somehow became involved in the process." To our knowledge no segment of the Canadian government has been involved in any aspect of the joint study. Their comment on it a month after it was launched probably stems from the fact that one of the participating companies has mills on both sides of the border at the location involved in the U.S. study. (page VI - 20): "Except for the Ontario press release and a low?key mention of the study to the American trade press in August, 1986, the joint study was not publicized in the As previously stated, the joint study was publicly announced to local and state press. In subsequent media contacts the industry and EPA have also been forthcoming about the nature of the joint study. Statement Fact: Statement Fact: (page VII - 5): "Increasing demand for paper products in industrialized nations and corresponding higher production, coupled with toxic processes such as chlorine gas delignification, have placed pulp and paper mills among the major sources of pollution, particularly of freshwater lakes and rivers and their associated airsheds." Since 1970, the industry has invested more than $10 billion to clean up the air and water surrounding its mills. Often, these environmental controls were instituted before they were mandated by law. As a result, suspended solids and dissolved organics that escape from the pulp and papermaking process have been reduced by up to 95 percent. A recent Government Accounting Office survey reports an excellent record of industry compliance with Clean Water Act requirements with "key industry pollutants in line with their permits as written and in amounts over a 2-year period that were less than the national standards allowed." In addition, during the 1970?s, the industry reduced air pollution by 41 percent at the same time production was increasing by 24 percent. (page - 4): "Many of these conditions are mirrored in pulp and paper industry waste recovery boilers, which are probably the largest source of pulp mill dioxin air pollution." The National Dioxin Study found no evidence of air- borne emissions of 2,3,7,8 TCDD (and only trace levels of the other CD05 and CDFs) from any pulp or papermaking source.