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Possible Contamination of Rice Creek and Etonia Creek tributaries Near Palatka, Florida

The following was received by Jim Porter Outdoor Adventures through the mail. A follow-up indicates it is a factual document regarding possible contamination of the waters and fish-life in the Rice Creek and Etonia Creek tributaries in locations very close to the St Johns River near Palatka, Florida.

We have no factual knowledge of the problem, itself, although we have heard some rumor to the effect. However, it would appear prudent that the population in and around that area of Florida, and possible visitors thereto, should be aware of the possible hazards.

March 18, 2002

Dear Concerned Person:

We have examined the following data and information concerning highly-elevated levels of dioxin in fish consumed by humans in Rice Creek and Etonia Creek tributaries in locations very close to the St Johns River near Palatka, Florida.

We believe this situation constitutes a threat to public health and wish to bring this matter to you for formal, official consideration of immediate responses including establishing a public health advisory and posted warning not to consume the fish in this area.

EPA's Fact Sheet concerning Public Health Advisory standards for Dioxin in fish tissue contains the following recommendations for fish consumption advisories:

These advisories are generally based on a higher cancer risk level (1 in 100,000) than the more protective risk level EPA/DEP normally applies for water quality standards (1 in 1,000,000).

When compared to data uncovered Dioxin in fish tissue sampled from tributaries to the St Johns River we have found cause for a public health advisory on consumption of recreational fish caught in Rice Creek, Etonia Creek and the proximate area of the Lower St Johns River (previously reports of these levels were incorrectly compared with FDA levels applicable to commercial fish markets).

The level reported in Rice Creek and Etonia Creek exceed EPA's recommended levels for :

"no meals per month" dioxin level ">1.2 ppt" and

"less than one meal per month" dioxin level of ">0.62 ppt"
contained in EPA's health advisory for dioxin in recreational fish.

The levels detected are as follows:





These samples were taken all from Rice Creek and Etonia Creek.


Upon submittal and review new data is expected to show Rice Creek fish tissue dioxin levels still >.67 ppt ( no more than .5 meals per month) and also show elevated dioxin fish tissue levels in Etonia Creek (actual amounts unknown).

To understand and interpret this data, it is important to know a few things about the unique riverine system of the St Johns River. Although located many miles upstream (to the south) and primarily freshwater, due to a rise of less than 12 inches in topography this area of the Lower St Johns River and tributaries (depicted in the map above) experience both frequent diurnal tide reversals and extended periods of negative flow up the tributaries due to tide (1 to 5 days).

An independent (i.e., non-GP sponsored) fish tissue dioxin study conducted in 1993 reflected bioaccumulation in largemouth bass at 8.8 ppt (exceeding bluegill levels at that time) exceeding the no meals per month level by eight times; and dioxin levels in bowfin fish as high as 48 ppt.

One facility in particular Georgia Pacific ("GP") has discharged 60 milllion gallons per day of paper mill effluent into rice creek. The percentage of GP effluent contribution to flow in Rice Creek is 50% to 97% (under low flow conditions). Sludges contained inside GP's 900 acres of treatment ponds, in GP's clarifier, and in influent to its wastewater treatment lagoons have been shown to contain what we believe are exceptionally high levels of dioxins.

Recent in-plant clarifier sampling of water indicates some level of dioxin even though dioxin is hydrophobic and tends to adsorb into available sediments or solids rather than be found in aqueous sampling:

Sample locations were described as:

Dioxin also continues to be found in the water (aqueous samples) in wastewater ponds again even though dioxin is likely bound in the pond sediments:

One source for this dioxin could be release of sediments through turbidity in the ponds which are disturbed during sludge removal. Dioxin and furan levels in sludge or sediment may also exceed recommended soil remediation standards for dioxin.

The GP sampling of sludge (v. a test blank called G8Filter) at the location described on the second column of the next table of laboratory results (below):

Another potential pathway worthy of investigation is the disposal of this dioxin sludge on-site. The recent permit summary for GP indicates that these sludges are land applied on-site or can be burned (possibly in industrial boilers) despite the high levels of dioxin.

"The dewatered wastewater treatment solids are land applied on-site. If Permittee land applies primary clarifier sludge's off the mill site, the Permittee shall keep records of the amount of sludge disposed, transported, or incinerated in dry tons/day. If a person other than the Permittee is responsible for sludge transporting, disposal, or incineration, the Permittee shall also keep the following records:

  1. name, address, and telephone number of any transporter, and any manifests or bill of lading used.
  2. name and location of the site of disposal, treatment, or incineration.
  3. name, address, telephone number of the entity responsible for disposal, treatment, or incineration site."
DEP - FL0002763 IW Permit; section II (2) Industrial Sludge Management Requirements

It is unknown whether the current and proposed methods of dioxin-sludge disposal meets hazardous materials (RCRA) disposal methods for this level of dioxins would allow land application, we also do not understand whether air pollution permits for the facility would allow burning or incineration of dioxin-laden sediments from the wastewater lagoons in GP's boilers or offsite incinerators.

Although GP installed Chlorine Dioxide in April 2001 and claims to no longer use Elemental Chlorine in its process - the sludge remains in the treatment ponds. Although half-life of dioxin in sediments is unknown; EPA's previously-cited fact sheet states that:

Similarly, dioxin in Rice Creek sediment and in the treatment lagoon sludges and sediment will remain for years to come.

In addition, additional dioxin will likely be produced and available for sediment adsorption and additional bioaccumulation. Recent high-volume EPA sampling at another paper mill in Florida (Buckeye) indicated that even after conversion to an Elemental Chlorine Free (ECF) process, paper mills will still emit dioxins although at reduced levels. Other research shows that only TCF (Total Chlorine Free) technologies can prevent all dioxin formation.

The transport of dioxin on TSS and in riverine system of Rice Creek and the St Johns River was not included in modeling performed by GP in its permit and WQBEL although such toxins modeling and bioaccumulation models are readily available and mathematically less-complex than dilution modeling of conventional pollutants, which have been conducted.

In addition to listing as probably carcinogen in humans, dioxin has been implicated as an "endrocrine disrupter". Endocrine disruption effects include hormone mimics, receptor blocking and cellular changes, include "fish masculinization" have also been identified in Rice Creek by Cody and Bortone in 1999 :

and other hormonal effects were documented by Sepulveda et. al in Largemouth Bass (a species consumed by humans) :

Other aquatic organism and human health effects from endocrine disrupters warrant a public health advisory not to consume fish from Rice Creek. EPA has also published guidance for pregnant women and young children (who frequently catch and eat bluegills, which tested high for dioxin)

We believe that such effects should be examined in Etonia Creek due to tidal reversal and periods of extended flow which could transport these materials upstream into the Etonia. In addition the movement of fish between the St Johns River and among its interconnected tributaries is further cause for concern.

Due the historic (1993-present) levels of dioxin found in fish tissue in these tributaries and the possible movement of fish between tributaries and the mouth of the St Johns River we believe that fish in the St Johns River may also contain high levels of toxic contaminants including dioxin and endocrine disrupters (Cody and Bortone, 1999).

We request your help and assistance in the following actions that we believe are warranted due the historic (1993-present) levels of dioxin found in fish tissue as set forth above:

  1. Please review this data and place a public health advisory warning the public not to consume fish caught in Rice or Etonia Creek.
  2. Please initiate a fish tissue sampling program for the St Johns River which we believe is warranted due the historic (1993-present) levels of dioxin found in fish tissue in these tributaries and the possible movement of fish between tributaries and the mouth of the St Johns River.
  3. Please ensure that dioxin-sludges at the GP wastewater lagoon and other areas are prevented from entering the riverine environment and are removed and properly disposed.
  4. Please ensure actions are taken to assess and remediate dioxin-sediments that may be present in Rice Creek, Etonia Creek and St Johns River sediments so that it is not available for further bioaccumulation.
Thank you for your efforts on behalf of the public in this matter of great concern.

Sincerely yours,

Ralf Brookes, Esq.
Ralf Brookes Attorney
1217 E Cape Coral Parkway #107
Cape Coral, Florida 33904
Fax (208) 441-5423


Linda Young, Clean Water Network
Tallhassee, Florida


Jessica Landman, Natural Resources Defense Council
Washington DC


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