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(for a 112 kb pdf version of the original file, click here) February 26,2007
By electronic mail:
Response to: SOLICITATION OF WATER QUALITY DATA
AND
INFORMATION FOR 2008 INTEGRATED REPORT - LIST OF
IMPAIRED WATERS AND SURFACE WATER QUALI TY ASSESSMENT [303(d)/305(b)] Dear Mr Gwynne,
Humboldt Bay is impaired with dioxin and TEQ (2,3,7,8-TCDD Equivalent). There is no
denying this impairment, though all sides in any argument about its 303(d)
listing wish it weren’t so. But it is, and it is time to get on with
identifying sources of dioxin and ways to eliminate or vastly reduce those
sources.
PCB (Polychlorinated byphenyl)
G1. What are dioxins?
"Dioxins" refers to a group of chemical compounds
that share certain chemical structures and biological characteristics. Several
hundred of these compounds exist and are members of three closely related
families: the chlorinated dibenzo-p-dioxins (CDDs), chlorinated dibenzofurans
(CDFs) and certain polychlorinated biphenyls (PCBs). Sometimes the term dioxin
is also used to refer to the most studied and one of the most toxic dioxins,
2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD). CDDs and CDFs are not created
intentionally, but are produced inadvertently by a number of human activities.
Natural processes also produce CDDs and CDFs. PCBs are manufactured products,
but they are no longer produced in the United States. From: National Food Safety Program. 2002, Updated 2006.Questions and
Answers about Dioxins U. S. Department of Health and Human Services, U. S.
Department of Agriculture, U. S. Department of Veterans Affairs,U. S.
Environmental Protection Agency,U. S. Department of Defense, U. S. Department
of State. http://www.cfsan.fda.gov/~lrd/dioxinqa.html#g1
Humboldt Bay is already listed as impaired for PCBs. The TEQ
(toxic equivalency of a dioxin or dioxin-like compound relative to 2,3,7,8
TCDD) for PCB are not part of the data sets currently under consideration, i.e.
PCB was previously found in tissue of organisms that live in Humboldt Bay and,
in separate measurements that did not include PCBs, dioxins have been found in
the tissue of organisms that live in Humboldt Bay. As yet, no one has conducted
tests that take into consideration the presence of both PCB and dioxin in
tissue samples or analyzed the symbiosis or magnification that would result.
This factor adds further emphasis to the need to keep the Bay listed as
impaired for dioxin, since the health effects (to both humans and wildlife)
caused by dioxin itself is exacerbated by the same effects caused by the
dioxin-like PCBs.
To
further identify dioxin-like PCBs, please see National Academy Sciences
(NAS). 2003. Exposure and Human Health Reassessment of
2,3,7,8-Tetrachlorodibenzo-p-Dioxin (TCDD) and Related Compounds Review
Draft Part I: Estimating Exposure to Dioxin-Like Compounds
Volume 1: Sources of Dioxin-Like Compounds in the United States. http://www.epa.gov/ncea/pdfs/dioxin/nas-review/ Chapter 11. “Sources of Dioxin-like
PCBs.” http://www.epa.gov/ncea/pdfs/dioxin/nas-review/pdfs/part1_vol1/dioxin_pt1_vol1_ch11_dec2003.pdf
According to a recent study of the effect of PCP contamination of
fish tissue, people eating fish caught in Humboldt Bay may be at greatest risk
to exposure to PCBs and dioxins:
Judd N,* Griffith WC,* Faustman EM. Regul Toxicol Pharmacol. 2004
Oct;40(2):125-35. Contribution of PCB exposure from fish consumption to total
dioxin-like dietary exposure. Sources of dioxin in Humboldt Bay: Data based on numeric information is important for establishing
that a water body is or is not meeting, or not likely to meet, existing water
quality standards is critical to establishing or refuting a 303(d) listing.
Equally important is documented information of conditions known or regarded as
probable sources of dioxin to the water body coupled with information about the
presence of these sources that show existing water quality standards are not
likely to be met. Both data and information exist to support the 303(d) listing
of Humboldt Bay as dioxin impaired.
An analysis of the sources of dioxin and dioxin-like compounds in
Humboldt Bay is similar yet far simpler than that for San Francisco Bay. The
latter is a complex industrial area with many potential legacy and current
activity sources that may be discharging dioxin. In addition, San Francisco Bay
and its watershed is much larger than Humboldt Bay and its watershed. A review
of “The Inventory of Sources of
Dioxin in the United States” cited below indicates that most know contributors
of dioxin to the environment that may exist in the San Francisco Bay watershed
do not exist in the Humboldt Bay watershed. Two of the largest quantified
sources in the Inventory are backyard trash burning and landfill fires, sources
that may have contributed to dioxin loads in Humboldt Bay in the past, but have
been banned in recent years and are not a currently contributing sources. It is
widely recognized that current sources are those of concern.
The major current contributors of dioxin to Humboldt Bay are most
likely to be reservoir sources, defined in the previously cited Sources of
Dioxin-Like Compounds in the United States. http://www.epa.gov/ncea/pdfs/dioxin/nas-review/,
in this case we cite Chapter 12, Reservoir Sources of CDDss/CDFs and
Dioxin-like PCBs:
Sources of Dioxin-Like Compounds in the United States: Reservoirs are materials or places that
contain previously formed CDD/CDFs or dioxin-like PCBs and have the potential
for redistribution and circulation of these compounds into the
environment. Potential reservoirs
include soils, sediments, biota, water and some anthropogenic materials. Reservoirs become sources when they
have releases of dioxin-like compounds to the circulating environment over a
defined time and space. Like other
sources they would not include purely intermediate products or materials
properly disposed in a secure landfill.
Reservoir sources are not included in the quantitative inventory of
contemporary sources because they do not involve original releases, but rather
the recirculation of past releases. They can, however, contribute to human
exposure and, therefore, are important to consider.
This dynamic system consists of fluxes in and
out of the atmosphere, as well as other exchanges between reservoirs and the
atmosphere. Movement between media can be induced by volatilization, wet and
dry atmospheric particle and vapor deposition, adsorption, erosion and runoff,
resuspension of soils into air, and resuspension of sediments into water. The rate of movement from one
environmental medium to another is termed ‘flux,’ and refers to the direction
and magnitude of flow and exchange over a reference time period and space.
Reservoir sites contributing dioxin
to Humboldt Bay are as follows:
Lumber mill sites where dioxin-contaminated
pentachlorophenol was used extensively and with little regard for environmental
contamination between 1950 and 1985 and which continue to discharge penta and
dioxin into the Bay due to the persistence particularly of dioxin.
In California, PCP has been used extensively for wood preservation
at lumber mills and wood treatment plants. From: Palmer, F et al. State
Water Resources Control Board. March 1988. Report No. 88-5WQ Division of Water
Quality. “Chlorinated Dibenzo-p-dioxin and Dibenzofuran Contamination in
California from Chlorophenol Wood Preservative Use.” (This reference forms the
basis of much of the assessment offered below)
A report submitted to the Regional Board in 1988 summarized what
little staff had been able to learn in visits to closed mills and some that
were then currently operating. (See Status Report on Problems of Disposal of
Pentachlorophenol Wastes from the Timber Industry, Frank Reichmuth, Albert L.
Wellman, North Coast Regional Water Quality Control Board, September 28, 1988.)
A few former and current sawmill sites located on the Humboldt Bay
have been subject to regional water board oversight for penta and dioxin
contamination. These include: Beaver Lumber Company; Schmidbauer Lumber
Company, Arcata and Eureka; Sierra-Pacific Industry, Arcata; and Simpson Timber
Company, Fairhaven and Arcata.
One of the sawmills investigated by the Regional Board staff,
Simpson’s Arcata plant, was not indicated to have used penta in the 1988 report
referenced above. I have testified and documented to the Department of Toxic
Substances Control why this occurred: Because Simpson denied ever using penta
on three separate occasions to three agencies. These included Regional Board
staff, later to the Department of Health Services during a site investigation
in 1990 by its epidemiologists to establish why four former workers at the
plant had contracted rare blood cancers, and to the Department of Toxic
Substances Control during its investigation of contamination at the mill in
1996. It does not seem a far leap to speculate that Simpson denied using penta
because the company did not want to admit how it had disposed of penta
residues, which was later exposed as by dumping the material in a hole in the
ground behind the mill, then later covering the hole with a lunchroom for
workers. Other sawmills likely did not want to get into trouble with the
regulatory agencies and so did not report past use of penta.
Another reason Regional Board staff did not compile an accurate
list of penta-contaminated sawmill sites is because many mills had closed by
the time of the investigation and no one stepped forward to provide information
about past use of penta at these sites.
Nevertheless, Regional Board could, and should, now undertake a
serious investigation of former sawmill sites based on several indicators of
historic penta use. These include the size of the mill (volume of wood and
number of employees) since known sites were larger, more affluent mills; the
type of wood milled, with penta more frequently applied to Douglas fir since
redwood is perceived as self-preserving; and the type of milling process used,
for example remanufacture to fence posts such as was done at Simpson’s Arcata
mill.
Since the above referenced map is a little vague regarding the
exact locations of former sawmills that can reasonably be inferred to be
contributing dioxin to the bay (due to size and other factors plus proximity to
Humboldt Bay and/or streams that flow into the Bay) and which have not been
investigated, below is a list describing the name and location of suspect mill
sites (not all locations are described in the Chamber of Commerce reports but
can be obtained by other means):
From the 1956 directory:
40.
Lane Portland Lbr. Co., Bra-Cut; 30 employees; 200M board feet daily.
Contamination from the North Coast Railroad right-of-way that
rings Humboldt Bay due to the degradation of dioxin-contaminated creosote and
pentachlorophenol used in railroad ties and the probable use of
dioxin-contaminated 2,4,5-T herbicide for vegetation control.
Thirty-two miles of track circle Humboldt Bay. Railroad ties
discharge dioxin as they degrade in much the same way telephone poles are
likely to discharge free and adsorbed dioxin (as described below); the surrounding
ballast and soil contribute adsorbed dioxin to the Bay.
Federal Emergency Management Agency.
Region IX. Draft Environmental Assessment Restoration of the Northwestern
Pacific Railroad, Humboldt, Trinity, and Mendocino Counties, URS Greiner
Woodward Clyde Federal Services, January 2000
Assessment of the Current Business
Position of the North Coast Railroad, The Woodside Consulting Group, August
1993
See also the references below regarding utility poles and railway rights-of-way. This information
indicates that existing water quality standards are not likely to be met for
Humboldt Bay.
Contamination from the discharge of pentachlorophenol laced
with dioxin from thousands of utility poles that ring Humboldt Bay.
Several research articles and
government reports indicate that dioxin is discharged from utility poles and/or
railroad ties. This information indicates that existing water quality standards
are not likely to be met for Humboldt Bay. Photographs of utility poles in a
rainfall event with water discharging to a drain that goes directly to Humboldt
Bay are available at http://alternatives2toxics.org/poisonpoles
Two of the largest potential reservoirs are
soils and pentachlorophenol (PCP) treated wood. PCP contains low levels of CDD/CDFs and wood which has been
treated with this pesticide represents a large reservoir of CDD/CDFs. CDD/CDFs may be released from the
PCP-treated wood to the air by volatilization or to surrounding soils by
leaching. Although hypothesized to
occur, no reliable measurements have been made. Similarly, no empirical
evidence exists on the possible magnitude of reservoir emissions from soil to
air. Pg
2-10
From: U.S. Environmental Protection
Agency, National
Center for Environmental Assessment, Office of
Research and Development.1998. “The Inventory of Sources of Dioxin in the
United States” http://www.epa.gov/nceawww1/pdfs/dioxin/dioxin.pdf The United States (US) Environmental
Protection Agency (EPA) estimated that the use of
From: Lorber, M. et al. U.S.
Environmental Agency. 2002. Investigation of the potential release of
polychlorinated dioxins and furans from PCP-treated utility poles Sci Total Env 290:1-3 (15-39)
The
Agency for Toxic Substances and Disease Registry reports in its Toxicological
Profile for Chlorinated Dibenzo-p-dioxins (update) 1998 http://www.atsdr.cdc.gov/toxprofiles/tp104.html
reports (page441) that
Utility
telecommunication and railway right-of-ways may be contaminated by leaching of
CDDs associated with chlorophenol-treated railway ties and utility poles. A
study in British Columbia showed that CDDs and CDFs were not detected in
parkland ditch sediments (control), but were detected in farmland, utility and
railway right-of-way ditch sediments (Wan and van Oostdam 1995) Wan,
M. T.; Oostdam, J. van 1995. Journal of Environmental Quality 24(2):
257-265. Utility
and railway rights-of-way contaminants: dioxins and furans.
We
believe the information presented above is sufficient to support a 303(d)
listing of Humboldt Bay for dioxin impairment due to the overwhelming evidence
that reservoir sources of dioxin are contributing CDDs and CDFs to Humboldt
Bay. That empirical data supports this information is proof enough that this
listing should be extended until these sources are removed and discharges are
negligible.
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