URGENT TCF Letter Sign-on

Fri, 22 Jan 1999 16:58:47 -0500

>Hi Folks:
>Here's a letter urging Congress to prod EPA to issue strong rules
>to curb organochlorine pollution from pulp and paper mills. This letter
>also supports adoption of a federal government purchasing policy for
>totally chlorine-free paper products.
>We have a tight time frame for sign-ons, but if you are able to turn this
>around by Monday, March 18th, it will make it onto the hill and into a
>press packet at a news conference next Thursday. Sorry for the crunch!
FAX # TO: spencer@nwf.org
>THANKS, Alicia Culver (Government Purchasing Project)
>>Subject: Revised Cluster Rule sign-on

>>Dear Representative:
>>The U.S. Environmental Protection Agency (EPA) is about to make a
>>decision regarding the level of dioxin and other related toxics that the
>>pulp and paper industry will be allowed to release for the foreseeable
>>future. EPA is developing comprehensive Clean Air Act and Clean Water
>>Act (CWA) standards for the industry in one rulemaking, the "Cluster
>>Rule." According to the most recent Toxics Release Inventory, pulp and
>>paper mills have the highest pollution rate (pounds per facility) of any
>>industry sector, an average of 457, 457 pounds of reportable toxics per
>>facility per year, making them a major source of toxic pollution.
>>The undersigned public interest groups representing millions of
>>Americans believe that both the law and sound public health policy
>>demand that the EPA require pulp and paper mills to install Totally
>>Chlorine-Free (TCF) technology. Further, the federal government should
>>help create a market for environmentally superior TCF paper products by
>>giving them strong preferences in federal procurement.
>>Totally Chlorine-Free technology has clear and dramatic environmental
>>benefits compared to the use of chlorine-based bleaching agents. Most
>>important, TCF technology enables mills to reuse their water so that they
>>can "close the loop" and cease discharging altogether, an important goal
>>of the CWA. TCF processes do not create dioxin or the wide range of
>>organochlorines that are known to persist in the environment for
>>decades, rise up the food chain, and eventually lodge in human tissue.
>>Many of these substances have been linked to cancer, as well as
>>endometriosis, reproductive abnormalities, impaired immune systems, and
>>behavioral and learning disorders. As a result of these pollutants,
>>several states advise against eating lobster tomalley and fish caught
>>downstream of mills.
>>Switching to TCF technology will also make America's pulp and paper
>>industry much more competitive internationally by lowering operating
>>costs. TCF processes use significantly less water and energy . TCF
>>technologies also decrease liability costs, chemical costs, and effluent
>>and sludge disposal treatment costs, and avoid dangerous, and
>>sometimes fatal, chlorine accidents. TCF technology is clearly both
>>technically and economically available. World wide more than 60 mills
>>use TCF processes, including the Louisiana Pacific mill in Samoa,
>>California. These plants have demonstrated that we need not
>>compromise in paper quality to use TCF processes.
>>Unfortunately the EPA is not even considering TCF as a regulatory
>>option. EPA's proposed rule presents two options. Option A calls for
>>merely switching from elemental chlorine to chlorine dioxide in the
>>bleaching process. Chlorine dioxide substitution is completely
>>unacceptable as it decreases but does not eliminate the discharge of
>>dioxin and other toxic organochlorines. Chlorine dioxide also prevents
>>mills from going closed-loop because it makes the wastewater too
>>corrosive to recycle through the plant so it must be dumped into the
>>nearest stream.
>>Option B calls for the use of oxygen in the pulping process (oxygen
>>delignification) while still allowing chlorine dioxide as a bleaching agent.
>>Oxygen delignification technology is a necessary first step towards a
>>closed-loop, TCF future. Nearly one-half of pulp produced in the U.S.
>>already is made using oxygen delignification or extended cooking.
>>Contrary to industry claims, hard economic data show that the
>>annualized costs of Option A and Option B are virtually identical.
>>In addition to Options A and B, EPA is considering incentives to mills to
>>move towards TCF processes. We strongly support the federal
>>government establishing procurement preferences for chlorine-free
>>paper products to help create a stable market for these products. Since
>>President Clinton issued his first Executive Order directing the federal
>>government to buy recycled and other environmentally preferable
>>products, a growing number of unbleached and non-chlorine bleached
>>products have come onto the market. Chlorine-free products may contain
>>recycled content that has not been rebleached with chlorine-containing
>>compounds, which we support. These products include tissues, paper
>>towels, coffee filters, printing and writing paper, file folders and copy
>>The federal government, as the nation's single largest consumer of paper
>>products, could have a dramatic impact on stimulating the market for TCF
>>paper products in the United States. In order to achieve this, the federal
>>government should issue a clear procurement directive to buy
>>chlorine-free paper products as long as they contain the minimum amount
>>of recycled content required under the existing Executive Order, are
>>cost-competitive, and meet the government's needs. In doing this, the
>>federal government would be following in the footsteps of several
>>states, such as Vermont, Oregon, and Massachusetts, as well as
>>several cities, such as Chicago, Ann Arbor, and Seattle, which have
>>similar incentives in place.
>>This upcoming regulation of the pulp and paper industry presents a
>>tremendous opportunity to eliminate dangerous toxic discharges from
>>one of the most polluting industries in our country and to require and
>>reward pollution prevention through use of TCF processes. We ask you
>>to support TCF technologies through both new regulation and federal