July 12 20000

Tom Fitzsimmons
Director
Department of Ecology
PO Box 47600
Olympia WA 98504-7600

In August 1998 the Washington State Department of Ecology announced it would develop a strategy to eliminate release of Persistent Bioaccumulative Toxics (PBTs). WEC has strongly supported the goal of elimination of PBT releases.

In a letter WEC Letter to Carol Kraege, Ecology, dated Feb. 8, 2000 RE Georgia Pacific Mill, WEC stated: "As you know, new federal rules (40 CFR Part 430 subpart E) require paper grade calcium sulfite mills to use Totally Chlorine Free (TCF) bleaching and produce zero dioxins, furans, and other persistent, bioaccumulative compounds. These new rules complement Director Tom Fitzsimmons' 1998 challenge to Washington state to develop a program to eliminate the discharge of persistent and bioaccumulative toxics. WEC fully supports both the new federal rules for calcium sulfite mills and the elimination of PBTs in Washington State ..."

In a WEC Letter to Chipper Hervieux, Ecology, dated Feb. 17, 2000, RE: Toxics in fertilizer/ Elimination of Exemption on Steel Mill Flue Dust, WEC stated: "...WEC calls for banning the use of ANY wastes high in dioxin content, including but not limited to steel mill flue dust, waste from pulp mills, cement kilns, incinerators, coal or other combustion flue deposits, as a fertilizer, fertilizer ingredient, or soil amendment, regardless of the 'K061 exemption'."

These letters both address the fact that despite Ecology's touted strategy, deference is still being given to industry to continue PBT releases. We are very disappointed that the worthy goal of elimination of PBT releases has hardly begun to be implemented by regulatory staff within the Department.

Ecology regulatory staff is currently working on revisions to important state environmental rules such as water quality standards, Air Operating Permits, and amendments to dangerous waste rules. They are drafting new waste water discharge permits for numerous PBT releasing facilities. This regulatory staff is now in an excellent position to educate business of the many excellent alternatives to PBT pollutants, and to include regulatory provisions to begin making the high level goal of elimination of PBTs a reality.

WEC strongly urges the Department to begin to align its regulatory process with the goal of elimination of PBT releases in a timely manner.

Sincerely;

Rodger Herbst

Chair
Pollution and Health Commitee
Washington Environmental Council