Facts Concerning June 1, 2009 State Administrative Order Letter to Georgia-Pacific

Statement: The Crist administration announced today that the dumping can continue for at least another year.
Truth: Florida DEP requested Georgia-Pacific (GP) implement new corrective actions for the company to comply with the requirements of an Administrative Order that was issued in 2002 and recognized that GP had previously complied with the requirements of that Order. The letter did not grant any new authorizations to legally discharge that were not granted by the NPDES permit and Order in 2002. The letter explicitly states that "GP is not authorized to begin construction of the pipeline until such time as the Department is able to review the additional information and corrective actions and complete its evaluation."

Statement: Georgia-Pacific paper mill is operating on a permit that expired almost two years ago.
Truth: This statement implies that GP is operating without a valid permit-not true. The GP NPDES permit issued on August 6, 2002, had an expiration date of August 5, 2007; however, based on the fact that GP applied for permit reissuance in a timely manner, that permit was extended and remains fully valid and enforceable.

Statement: It has been suggested that the new corrective actions required by the June 1, 2009, FDEP letter will not be subject to a public process.
Truth: The June 1, 2009, letter itself is available to the public. Also, all documents produced by GP and submitted to FDEP are, and will be, available to the public. Any member of the public can communicate information or ideas to the FDEP throughout the ensuing process required by the letter. In addition, GP will continue to communicate to and listen to members of the public that are interested in the Palatka facility.

Statement: It has been implied that GP would not be obligated to take alternative action if an economically and environmentally viable alternative to the pipeline was found.
Truth: The FDEP Order issued in 2002 required, and the new additional requirements of the June 1, 2009, letter confirm, that if an economically and environmentally viable alternative to the pipeline was found that will allow full compliance with water quality standards to be met in Rice Creek, it would be required and GP would not be authorized to construct the pipeline.

Statement: Data collected and analyzed by the US EPA revealed that GP is discharging dioxin at levels five times higher than is allowed by law.
Truth: Georgia-Pacific does comply with its dioxin permit limits using the federally approved, and permit mandated, dioxin sampling methodology. Those laboratory reports have consistently reported non-detect for dioxin since the 2001 conversion to elemental-chlorine-free (ECF) bleaching. EPA sampled GP's effluent on September 24, 2008, using an experimental technique that has not undergone an inter-laboratory validation process or technical review. Due to the imprecision of the field duplicate taken at Georgia-Pacific and other problems with the sampling event, the High Volume Extraction did not produce a scientifically defensible quantifiable result. GP is moving forward with studies requested by FDEP to better understand what those results could mean. Also, had the EPA sample(s) been validated, the levels being discharged are well below any public health risk set forth by any state or federal agency regarding fish consumption - the potential mechanism that dioxin could enter the human health food chain.