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(cluster rule) snappy comebacks?

  If other's have heard from their 'EPA oppressed' local P&P mill that, as
  the "official docket" clearly shows, the rule will "lower dioxins to below
  detectable levels", here is a response, which I am posting because I need
  help in extending its consequences.  Any replies to both lists, not just to
  me, please.
  Jay Ritchlin, I think, pointed out to me that the AET's own submission to
  the docket shows, in one crystal clear paragraph, that non-detect forPCDD/F
  below 1 ppq (TEq) is commonplace, and as low as 0.1 ppq for what is Best
  Avail. Technology (BAT) to the analytical world [:-}].  I.e. for their "not
  detectable" claim (based on EPA's 10 ppq d.l. method, usedby EPA for
  compliance so it has to have dead certainty & therefore a high d.l.) to be
  true, it not only has to go contrary to THEIR own "official" submital, but
  relies on "detection limits" that are 10 times greater than what is
  routinely achieved, and 100 times looser than what can be routinely
  achieved (4 years ago, yet).
  [caveat: I haven't read that whole document in the docket (one of many AET
  submissions), so there may be a hidden landmine, but I believe these facts
  speak for themselves.]
  A related, synnergistic comeback is to argue that even below "non-detect"
  (10 ppq TEq) is a significant risk. I believe there are 94,000 (or is it
  ~60,000?) TCDD molecules in a liter of water with 10 ppq TCDD. 60,000 x
  gal/a.d.ton effluent (4.8 liters per gal., n'est pas?), ie times the volume
  of water from your local bleach plant, is how many molecules of TCDD
  released/day or year?  Once released they will concentrate WAY beyond 10
  ppq (how much, ie the BCF for freshwater lakes & rivers & for salt
  waters?); many in biological organisms, and the closer to humans, the
  greater the concentration.  it only takes a few thousand (10,000 or less)
  TCDD molecules in test animals to observe horrible hormonal effects, such
  as ovarian cells in the testes, and much more.
  Another tack is to dispute the 96% & 97% dioxin reductions (for ECF & TCF,
  vs. a baseline using elemental Cl forms) apparantly claimed by EPA in the
  pretty balanced A.P. story by Josef Herbert that showed up in our
  newspaper.  TCF will only lower dioxin by 97%?????? what the h*ll is this,
  and who actually says it--anyone know?
  As to ECF cutting dioxins 25 fold, ie by 96%, this seems too much, maybe?
  To begin on the cautious side, it is the oxygen in ClO2 that reacts with
  lignin, meaning that you don't have to compensate for their being only one
  atom of Cl in ClO2, thus there really is a serious (~70%?), reduction in
  amnt. of chlorine used (the amount reduced obviously depending on your
  particular baseline bleach sequence, involving the lignin eating abilities
  of Cl2, NaOCl and ClO2) -- and therefore perhaps a 70% or thereabouts
  reduction in dioxins.
  Further, in a publication (AET's) Darrell brought back here from the recent
  Vancouver BC P&P conference I learned what shudda been obvious, that adding
  oxygen in the form of ClO2 means the production of oxygenated organics from
  lignin, which *are more susceptable to degradation*.   But is this enough
  of an effect to get dioxins lowered by 96%?
  If it is, the instant comeback has to be that the chlorine from ClO2 does
  not magically disappear, and other stable, bioaccum. & toxic O-Cl's will be
  formed by the time the reactive oxygenated organic is finished reacting.
  For example, _millwatch_ just reported an IARC article that says over 1/3rd
  the mutagenicity of pulp mill effluent is due to compound MX (originally
  named in water disinfection byproduct studies, it's a tri-chlorinated
  furone).  Chlorphenols, chlorolignins, chloroguacols, chlorocatechols,
  chlorbenzenes, chlorcyclohexanes, thousands of different chloraromatic (or
  otherwise ring shaped) & chloroaliphatic (chains), beginning with
  chloroform, ... ad infinitum ... thousands of different toxic, persistant &
  bioaccumulative O-Cl's (none of which would be detectable using honest,
  d.l.'s!) ...if they just stopped using chlorine.  So: only a 97% dioxin
  reduction for TCF?? I can't believe EPA is claiming that--it must be AP's
  Don't fergit to emphasize that current BKPM (and other?) mills are
  especially enriched in 2,3,7,8-TCDD, so their TEq's are much higher than
  other types of sources (emitting the same # of PCDD).  Anyone know  if this
  is true of ECF mills?
  Also, that ECF produces Cl2 gas (lots, in the acidic conditions common in
  ECF bleach plant vats), therefore the claimed reductions are an unrealistic
  scenario.  ask them point blank for an estimate of their dioxin creation or
  reductions accounting for this.
  Finally, combine 2 tacks:  how many dioxin molecules released if your mill
  reduced dioxins by 96% by going TCF?  I need help w/ this estimate).
  I wont get into the economic arguments--i thought that was one of the good
  aspects of the AP story, reporting that enviros 'claim' (ie the reporting
  left the correct implication that an honest comparison has to include both
  operating & capital costs, minimally) if you include operating costs, TCF
  costs are indistinguishable (this not even counting for the savings by
  reducing your effluent 70-100%, which can only be done by going TCF, due to
  HCl's extreme corrosiveness to metal).  The fact that EPA *illegally*
  ignored foreign mills in determining BAT to not even include (or even give
  an incentive to!) oxy delig, which is so far beyond BAT that about 300
  mills use it.  Also, the worker safety issues--accute tox. Of ClO2,
  chlorform & HOCl  (hypochlorous acid, produced in the conversion of ClO2 to
  Cl2)--and explosion risks.
  Tony Tweedale (Causality is a concept not subject to empirical
  demonstration.   -David Hume)