The following are our concerns:
Landspreading
--- A solid waste landspreading permit was included in the water pollution
permit, which is unusual.
More importantly, the permit notice provides no information about the
quality or quantity of sludge to be landspread, or where the landspreading
sites will be. We asked the DNR for any data they might have on the
chemical nature of the sludge, but they told us they had none.
Nor is an explanation given in the permit notice for the need to landspread.
Afterall, Glatfelter is one of the companies planning to burn sludge in
the Minergy Incinerator. DNR staff told us only one type of
sludge from the wastewater treatment would be spread, but no such restriction
is mentioned in the permit.
In addition, no mention is made of any public notice, comment or public
hearing opportunity related to the specific landspreading sites or plans
of the company. This may be our only chance
to comment.
Such vagueness is unacceptable. We know the sludge will be contaminated
with a wide range of chlorinated organics, heavy metals, and a whole host
of other chemicals. Neighbors of proposed landspreading sites will
be exposed, and the general public which will be forced to eat foods grown
on those soils. We should be allowed a significant say in whether
it should be allowed --- but this permit gives so little information that
it's impossible to evaluate it.
This entire landspreading section should be removed from the proposed
permit, and it should stand alone for proper review, after all sludge chemical
data reports and specific site proposals have been made. The public
should not be asked to simply "sign-off" at this point. We also question
the legality of the public notice, because landspreading is not mentioned
in notice title.
Solids Dumped in Lake --- This permit would allow Glatfelter to dump up to 1,211 tons of solids in Little Lake Butte des Mort each year. This is the same as allowing them to discharge 60 dump truck loads of sludge in the flowage --- an unacceptable situation. The sludge will carry hundreds of kinds of chemicals into the Lake, the Fox River and Green Bay.
Lack of Limits
--- The permit sets no limits for Ammonia Nitrogen, total PCBs, or a whole
host of other chemical contaminants (especially heavy metals, solvents,
phthalates, etc.) known to accompany typical waste paper de-inking plants.
A wide ranging analysis of the wastewater recently detected chromium, copper,
cyanide, chloroform, methylene chloride, phenol, and endosulfan.
At the very least, the permit must include regular monitoring to determine
whether the detection levels were accurate, or understated. And the
permit should include a requirement that if concentrations 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
into a public water supply. The DNR needs to have a better picture
of the situation, and clear responses if problems are detected.
Chlorine Compounds
--- Glatfelter uses chlorinated compounds in de-inking or bleaching of
their pulp, and they recycle chlorine bleached waste paper. We object
to the lack of any limits 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, chlorpyrifos,
or AOX samples were required. (AOX is a measurement of total
chlorinated residues --- chlorine can form thousands of different compounds
with other chemicals.) The chloroform releases show the presence
of chlorinated chemicals, and the public should be told what those concentrations
are, before the company is issued a permit with no limits for these chemicals.
And what are the air emissions of chloroform as a result of this permit?
Chloroform is a known cause of cancer in humans.
No Monitoring
--- The permit does not require ANY monitoring for the chemicals of concern
listed above. Therefore, the DNR will be guessing 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 historical data.
Glatfelter is one of the most difficult polluters on the Fox River,
and has been penalized for violations several times. They need to
be tracked and monitored carefully, to allow prompt and effective enforcement
actions and appropriate permit changes in the future.
Dioxin and Furan Samples Inadequate --- The permit requires Glatfelter to sample only one of the 79 kinds of dioxin. Many other kinds of dioxins, and the related furans, also have toxic properties and should also be monitored regularly. The company recycles bleached papers and its processes are undoubtedly contaminated with many kinds of dioxins and furans. Dioxins and furans are some of the most toxic man-made chemicals, and scientists have yet to discover any safe level of exposure to them.
Only One Sample
Taken --- We object to the notion that one chemical scan
in 5 years is adequate to show the true chemical nature of this company's
wastewater.
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 wastewater treatment dollars at stake, the
temptation is too high to risk allowing the company to "put on a good face"
for the test. Instead, the DNR should collect several samples on
several surprise visits to get the true picture, and should randomly assign
the samples for analysis at a variety of independent laboratories, to ensure
honesty.
It's impossible for one sample in 5 years to have any statistical significance.
The paper industry is famous for demanding "sound science." They
need to provide the basic data to make "sound science" possible.
Flow Limits --- The permit should include maximum limits on wastewater flow quantities, and restrictions on flow during monitoring events, to prevent short term violations and to ensure accurate, undiluted samples.
Dilution is
No Solution --- Little Lake Butte des Mort is not a true
river, with full river flow. It's a flowage lake, an impounded
river with stagnant pockets on both sides of the main flow. It's
unhealthy to apply the usual river dilution standards (called "wasteload
allocations") to this stagnant water situation.
As last summer proved, the nutrient levels are clearly too high in
Little Lake Butte des Mort, the Fox River and Green Bay. (Click to
go to related article - "Green and Gooey.")
Healthy water quality is not being maintained at minimum standards. The
gross algae blooms and decomposition befouled the whole area, causing serious
suffering to local residents, and wildlife health problems as well.
The phosphorus, nitrogen and BOD (Biological Oxygen Demand) must be further
restricted in this permit.
The proposed permit would give the company an "alternate phosphorus
concentration limit" of twice the recommended standard, claiming that they
need time to learn how much phosphorus they need to operate their biological
stage of wastewater treatment.
But after all these years they should already know, and if they don't,
they should be able to complete studies within a month --- they don't deserve
another 3 years for this study.
The ratio of total pollution flows to background water in Little Lake
Butte des Mort is 1 to 22, so industrial flows are a significant portion
of Little Lake Butte des Morts' water. The permit analysis used flows
downstream of Wisconsin Tissue Mills, which is not similar to Glatfelter's
discharge point upstream.
The flow is not "uni-directional" as claimed by DNR. To the west
of Glatfelter's the Lake widens and creates large pockets for backwash,
as shown by the toxic "PCB Deposit A" --- a major deposit zone to the side
of Glatfelter's discharge pipe. This stagnant water should not be
used for dilution.
Acutely Toxic
--- This permit allows Glatfelter's pollution to be
diluted by lake water 20 to 1
before it has to meet standards, because they're allowed a "Zone of Initial
Dilution" (ZID).
This is a serious loophole in Wisconsin's laws, which the paper industry
lobbied hard for. A ZID allows the discharge of acutely toxic
water, on the theory that the initial velocity of the water is too fast
for fish to exist in anyway. (!!) Yet this pipe is actually
to a lake, not a river --- making this ZID especially inappropriate.
We also object to DNR's proposal to drop monitoring requirements because
of the extreme dilution allowed.
Acid/Alkaline
Discharges --- We object to the lenient time frames allowed
for violating Wisconsin's pH standards for discharges. Fish and aquatic
wildlife could be seriously injured by repeated acid or alkaline discharges.
It's not enough to "report" violations, they should stop.
They should not be "forgiven" for 7.5 hours of violations each month.
They already have a very wide pH range to work within.
Mercury Must
Be Limited --- We are very disturbed that mercury is
not restricted in this permit. Instead, DNR requires only studies.
But it isn't enough to study such a serious issue. Glatfelter has
known for years about the mercury problem in the Fox River --- they should
not be given five more years to report additional study results.
They should be required to meet limits immediately.
The DNR background document states: "Reported
effluent concentrations [of mercury] exceed the monthly average limits
based on wildlife criterion and human health criterion."
Bioassays
Inadequate --- The proposed permit requires Glatfelter
to perform "bioassays," which are tests where minnows and water fleas are
exposed to different concentrations of wastewater. If a certain number
of minnows or fleas die at certain concentrations, the company fails the
tests.
These tests provide valuable information, but they are no substitute
for actual chemical monitoring, and they tell us nothing about accumulation
of toxic chemicals up the food chain or chemical effects on other wildlife
which may be more sensitive.
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, acute and chronic mixing zones could
be large, permanent areas of toxic water in Little Lake Butte des Mort.
Glatfelter frequently failed these bioassays in the recent past, and
their laboratories lacked adequate quality controls on the tests.
The DNR admits that it is recommending bioassays because of a "reasonable
potential for water quality standards to be exceeded." Later, DNR
staff make another statement: "... there is uncertainty
regarding the potential for fish and aquatic life toxicity."
Given this potential and uncertainty, why is DNR granting the permit?
These statements highlight the need for increased chemical sampling and
stricter limits. Without chemical data, how will DNR or the Company
begin to address a toxicity problem if the company continues to fail the
bioassays?
Water Treatment Additives --- This permit should (but it doesn't) spell out exactly which water treatment additives will be permitted in the cooling water (this is water used for cooling equipment, it's not used in actual paper making processes). These water additives can include highly toxic "biocides" used to prevent zebra mussels, bacteria, or lime build-up in the pipes. DNR did not include any chemical limits in this proposed permit for cooling water "because these discharges are seasonal." Yet, this is a public water supply used by people and wildlife all year. And some biocides include persistent chemicals which will accumulate downstream. Chemical discharges should be monitored and restricted all year. DNR needs better data before it can justify this part of the permit.
By-Pass Loopholes --- This permit gives approval for wastewater treatment bypasses, without penalty, as long as the DNR is notified promptly. In other words, the permit limits are meaningless. Bypasses allow untreated wastewater to be discharged directly into Little Lake Butte des Morts.
Inadequate Public Notice --- For this public notice to be useful and meaningful, it should include total permitted discharges of all known chemicals, as well as all known past discharges and violations under the permit which is to be replaced. All chemical releases should be expressed in simple terms of pounds or tons per year --- not in ml/l or other concentration standards which are hard for most members of the public to understand. Does this permit represent an increase or decrease in discharges? How can such basic information be left out?
Conclusion
This industry is requesting the privilege to discharge it's contaminated
wastes onto farmland which produces food for human consumption, and into
a public waterbody which is used for drinking water supplies, fish eating,
duck eating and other human consumption. We believe the public must
be given more information in a more understandable form --- so we can easily
evaluate whether the company deserves this privilege.
Other Permits
Also Weak
We've received a number of 5-year permit renewal notices recently, and
they all appear to be as weak as this one. Something is clearly wrong
at Gov. Thompson's new version of the DNR.
What
You Can Do:
Please write a letter to the DNR expressing your concerns about this
permit. (Refer to Wis. Pollutant Discharge Elimination Permit
# WI-0001121-6 for P.H. Glatfelter Company).
Deadline for letters: April
6, 1998