Pulp, seals and dioxin

Jon Sumby

Gunns continually dismiss any issue with dioxin pollution. Dioxins are the most poisonous and persistent chemicals we know; they don’t go away and they don’t disappear. The seals on Tenth Island live their lives where the pulp mill will dump poisonous water; it is a wrong that they suffer for our profit.

THE pulp mill IIS is a large document to work through and assess. It is structured in a way that makes it difficult to draw coherent analysis.

For instance, it has been pointed out to me that most of the information about which forests will be affected, and when and how much timber will be used is in the section about ‘transport’. This would naturally favour the proponent and makes it harder for the community to draw a clear assessment of, and prepare a reply to, this IIS.

Additionally, it seems that every pdf file in the IIS has security settings that do not allow people to copy and paste extracts. This may appear reasonable, but it means anyone who wishes to quote from the IIS must manually re-type the extracts they wish to quote. In the preparation of any comment on this IIS, it means a substantial investment of time, which is a precious commodity in the context of replying to this IIS. If you wish to extract a graph, table or diagram to comment on, you can’t. While content editing is usually disallowed in public documents, in order to protect the integrity of original document, content extraction is usually allowed as a fair and reasonable process to enable people to quote and reply to assertions made in the original documentation. For example, the RPDC guidelines for the pulp mill are downloadable from their website and allow cut and paste of text, so if you wanted to copy a paragraph and then comment on it, you can. It seems that either Gunns are paranoid or have taken to heart the saying, ‘Life was not meant to be easy’.

Browsing through the IIS, I came upon the section ‘V10_A23’, which is an impact assessment on the Tenth Island seal colony; a mere 12 kilometres from the ocean waste disposal site. Reading through this I came across the part assessing dioxins. Dioxins are among the most poisonous and persistent chemicals known and Gunns have repeatedly dismissed the possibility of dioxin pollution as non-existent. The dioxin assessment for the seal colony raised my eyebrows and I think it needs a closer examination.

This part of the IIS starts out by saying:
‘Dioxins:
The following conclusions regarding the bioaccumulation of dioxins by marine organisms have been formulated by review of the literature available for this project:
— Dioxins do not magnify through the marine food chain.
— Dioxins are not significantly bioaccumulated or biomagnified by fish.
— Fish living in local environments where dioxin concentrations are low also have low levels of dioxins.
— The theoretical increase in dioxin levels of fish after the effluent outfall becomes operational is markedly less than the analytical capability to measure.
— There will be no demonstrable increase in dioxin concentrations of fish that might reside around the ocean outfall.
— Animals higher in the food chain, including whales and seals, have relatively high metabolic and/or excretory capacity towards dioxins.
— Seals do not readily assimilate dioxins from their food and do not biomagnify dioxins.’
(Gunns Pulp Mill IIS, V10_A23, p. 4)

This chapter of the IIS concludes: ‘there will be no demonstrable impact on seals from dioxins in the effluent.’ (Gunns Pulp Mill IIS, V10_A23, p. 4)

It is difficult to predict the amount of dioxins that may be released by the mill but it is worth addressing the assumptions made by the Gunns pulp mill IIS. I will use quotes to bring my point across; this method can be challenged as ‘selective’, or ‘out of context’ quotation, so I include websites so you can examine where the quotes derive and their context. I hope the quotes in themselves are sufficient.

Dioxins
Dioxins are among the most poisonous and persistent chemicals known as organochlorines. They are so toxic that exposure standards are set at extremely low levels. If you went to an Olympic-sized swimming pool and dropped three grains of sand into it, and if those grains weren’t sand but were dioxin, those three grains would be enough to make the pool unsafe to swim in, much less drink the water. They are persistent; that is, dioxins remain in the environment for decades as toxic pollution. They are classed as ‘persistent organic pollutants’ or POPs. This means a few things; they can move- dioxins can be measured in the fat of seals in Antarctica, far from factories that made them. They can bio-accumulate, or bio-magnify, since they remain in the bodies of animals, so they become more concentrated as they move up the food chain- from a crab to a fish to a seal. This affects people; today on the ABC website, there was a story about dioxins in the body of a boy in Sydney. In this case the source is Homebush Bay (remember the Greenpeace campaign?) where dioxins are leaking out of the sediment and working up the food-chain until people start seeing deformed fish and eating fish that carry a disturbing concentration of dioxin.
Goto: http://www.abc.net.au/news/newsitems/200607/s1691649.htm

The IIS, V10_A23, p. 4, says that: ‘Dioxins do not magnify through the marine food chain.’

Quotes:
‘Biomagnification in Arctic food chains increases the potential threat from POPs.
Due to the processes of bioaccumulation and biomagnification, POPs can reach very high concentrations in top predators even when levels in air, soil and water are low. Biomagnification is a process that occurs in food chains where animals consume other animals for food but at the same time consume all the contaminants that their prey have accumulated. Since many POPs are not broken down or excreted, concentrations increase with each step from prey to predator. Bioaccumulation of POPs is particularly strong in Arctic marine food chains leading to high levels of POPs in top predators such as seals and polar bears, and ultimately man.’
(http://www.arctic-council.org/en/main/infopage/67/)
[The Arctic Council is a high-level intergovernmental forum that provides a mechanism to address the common concerns and challenges faced by the Arctic governments and the people of the Arctic. Russia serves as Chair of the Council for 2004-2006.]
—
‘Due to a process known as biomagnification, animals high in the food chain, such as dolphins, whales and seals, can be exposed to high concentrations of organochlorines. These chemicals move up through the food chain, increasing their concentrations each time contaminated prey is eaten. Once the contamination reaches the top of the food chain the level of toxins can be many times greater than that in the surrounding environment.’
(http://www.deh.gov.au/settlements/publications/chemicals/scheduled-waste/solutions6.html)
[The DEH in deh.gov.au is the Commonwealth’s Department of Environment and Heritage.]

-The IIS, V10_A23, p. 4, says that: ‘Dioxins are not significantly bioaccumulated or biomagnified by fish.’

Quotes:
‘Mussels link water and sediment
Mussels have an important role in the circulation of dioxins since they filter large amounts of particles in the water and also process the surface sediments. Mussels increase the deposition rate of these substances on the seabed and make them more easily available to organisms living on the sea floor. In addition to this, mussels increase the residence time of substances in the water, and accumulate and excrete them.
Fatty fish contain dioxins
The fat-soluble properties of dioxins cause them to accumulate in fatty tissues. Herring and salmon are fatty fish, and contain the highest dioxin concentrations when calculated by fresh weight.’ (Dioxins in the Baltic Sea (2004). The Helsinki Commission – Baltic Marine Environment Protection Commission: Helsinki, Finland.)
—
‘Soils and sediments are mentioned to be important reservoir sources due to the persistence of these pollutants in the environment. The most important route for human exposure to dioxins is food consumption, contributing for more than 90 % to total exposure. Products of fish and other products of animal origin account for approximately 80 % of the overall dietary dioxin exposure. (Commission of the European Communities 2001 b).’
(Helsinki Commission – Baltic Marine Environment Protection Commission. Project Team for the Implementation of the HELCOM Objective with regard to Hazardous Substances, 7th Meeting, 11-13 March 2002: Helsinki, Finland.)

The IIS, V10_A23, p. 4, says that: ‘Fish living in local environments where dioxin concentrations are low also have low levels of dioxins.’
[The levels of dioxin released by the proposed mill are not known, only estimated. Dioxin is poisonous, persistent, and accumulates in the environment. It cannot be said that a low environmental concentration level means that there will be a low level of dioxin in the food chain. Recall the comment from the Arctic Council; ‘Due to the processes of bioaccumulation and biomagnification, POPs [ e.g. dioxin] can reach very high concentrations in top predators even when levels in air, soil and water are low.’]

Quotes:
‘However, it is important to realise that both invertebrate bioassays and bottom fish bioindices are useless in the determination of bioaccumulation potential unless ecological interactions are taken into consideration. In a study by Rice et al. (2000), the commonly used sediment bioassay invertebrate, Armandia brevis, was exposed to sediments that would typically not be identified as toxic using most invertebrate bioassays. When these Armandia brevis were fed to English sole [a fish], reduced growth and increased hepatic adducts [liver chemicals] were observed. These results indicate that sediment contamination levels that would normally be identified as non-toxic through typical invertebrate bioassay analysis can cause significant adverse effects at higher trophic [food chain] levels.’ (Hall, J.E., (2002). ‘Bioconcentration, Bioaccumulation, and Biomagnification in Puget Sound Biota: Assessing the Ecological Risk of Chemical Contaminants in Puget Sound’. University of Washington: Tacoma, USA.)

The IIS, V10_A23, p. 4, says that: ‘The theoretical increase in dioxin levels of fish after the effluent outfall becomes operational is markedly less than the analytical capability to measure.’
[This is an ambit claim. The ‘theoretical increase’ is less than the ‘capability to measure’. The fact is the proposed mill will put dioxins into Bass Strait. If these are below the ‘capability to measure’ it does not mean they don’t exist, even Gunns says that dioxins will be a part of the mill waste. Dioxins don’t disappear, degrade or change; they’re persistent and poisonous, they don’t go away.]

The IIS, V10_A23, p. 4, says that: ‘There will be no demonstrable increase in dioxin concentrations of fish that might reside around the ocean outfall.’

[‘There will be no …; this is an assertion of faith and therefore unprovable. Dioxins don’t like water and tend to stick to particles in the wastewater, so they usually fall to the seabed near the waste pipe. Then they get eaten by animals that live on the seabed, then by other fish and so on, up the food chain. There is a large body of research that shows this process. Dioxins are poisonous and persistent, they will accumulate no matter the amount of dioxin the pulp mill releases.]

Quotes:
‘The benthic food chain studied consists of species living in or close to sediment accumulation areas. Amphipods and isopods are sediment-dwelling crustaceans. Amphipods feed on material from the sediment and serve as a food source for isopods, which are also carrion feeders. Four-horned sculpins are bottom dwelling fish that feed on both isopods and amphipods. The sculpins are sedentary, and are, therefore, good indicators of environmental pollution within the region they inhabit… Bleaching with chlorine, chlorine dioxide, or hypochlorite is used for further treatment of the pulps. During this bleaching, a large variety of chlorinated aromatic compounds are formed, including not only polychlorinated dibenzo-p-dioxins and dibenzofurans (Swanson 1988), but also alkylated polychlorodibenzofurans (RPCDFs) (Beck et al. 1989). Historically, this group of compounds was first identified… in sludge samples from seven different pulp and paper mills, sediments, and fish (Kuehl et al. 1987).’ ( Lundgren, K. (2003). ‘Properties and Analysis of Dioxin-like Compounds in Marine Samples from Sweden.’ Department of Chemistry, Umea University: Umea, Sweden.)

The IIS, V10_A23, p. 4, says that: ‘Animals higher in the food chain, including whales and seals, have relatively high metabolic and/or excretory capacity towards dioxins.’

Quotes:
‘Marine mammals also have a limited capacity to metabolise chemicals such as organochlorines in comparison to terrestrial mammals. Testing for these chemicals in marine mammal blubber therefore provides some indication of the presence of these chemicals exist in the marine environment.’ ( http://www.deh.gov.au/settlements/publications/chemicals/scheduled-waste/solutions6.html)

The IIS, V10_A23, p. 4, says that: ‘Seals do not readily assimilate dioxins from their food and do not biomagnify dioxins.’

Quotes:
‘Investigators have demonstrated immune dysfunction as a plausible cause for increased mortality among marine mammals and have also demonstrated that consumption of persistent organic pollutant [POP] contaminated diets in seals may lead to vitamin and thyroid deficiencies and concomitant susceptibility to microbial infections and reproductive disorders. Investigators have also noted that immunodeficiency has been induced in a variety of wildlife species by a number of prevalent POPs, including TCDD’s [dioxins], PCBs, chlordane, HCB, toxaphene and DDT.
Exposure to POPs has been correlated with population declines in a number of marine mammals including the common seal the harbour porpoise, bottle-nosed dolphins and beluga whales from the St. Lawrence River. Similarly, investigators have also demonstrated a convincing correlation between environmental concentrations of PCBs and dioxins with reduced viability of larvae in several species of fish. Noteworthy as well is a report suggesting significant reproductive impairment in a number of Great Lakes species described as top level predators dependent on the Great Lakes aquatic food chain. ( http://www.chem.unep.ch/pops/indxhtms/asses123.html)
[chem.unep.ch is the website of the United Nations Environment Program’s Division of Technology, Industry and Economics.]
—-
‘High levels of organochlorines or mixtures of organochlorines in mammals such as seals can lead to preimplantation disorders, spontaneous abortions, or premature pupping. There is substantial information regarding the effects of endocrine-disrupting chemicals during gestation, lactation and adulthood in some wildlife, domestic animals and laboratory animals. The full effects on marine mammals have not yet been established; however, it can be assumed that contamination by these chemicals will result in similar consequences.’
(http://www.deh.gov.au/settlements/publications/chemicals/scheduled-waste/solutions6.html)
—
‘In mammals, the transfer of dioxins from mother to offspring during lactation is an important route of exposure to newborn aquatic mammals… Colborn and Smolen (1996) review several studies examining maternal transfer in marine mammals. These studies reported 98% transfer of the maternal body burden of dioxins to grey seal (Halichoerus grypus) pups. The placental transfer of dioxins is much lower than in milk, with about 1% in grey seals and 2% in Weddell seals (Leptonychotes weddelli).’ ( http://www.deh.gov.au/settlements/publications/chemicals/dioxins/report-11/comparison.html)
—
‘In the North Sea, for example, approximately 20,000 seals – more than half of the seals in Europe – died in just six months in 1988. As in the case of the deformed frogs, scientists at first speculated that there could be multiple causes: poisonous algae, global warming, or a chemical spill. Then, some months later, it was determined that the immediate cause had been a newly discovered distemper virus. Although the episode had been devastating, there was a sigh of relief that the crash had been due to natural causes. But seven years later, further research showed that contact with high concentrations of synthetic chemicals, particularly of PCBs which had lodged in the fish these seals were eating, may have made the seals susceptible to the virus.

That discovery came about through a study in which healthy seal pups caught in relatively clean waters were divided into two groups. One group was fed herring from the heavy polluted Baltic Sea while the other ate herring from the much cleaner Atlantic Ocean. The study began in October 1991, and after only two years, the blubber of the seals that were fed contaminated fish contained 17 parts per million (ppm) of PCBs – concentrations three to ten times higher than those in the control seals. At these levels, the test seals showed a 20 to 50 percent reduction in natural “killer” cells, which attack foreign bodies in the blood, and a 25 to 60 percent reduction in T-cells, the white blood cells essential to orchestrating immune response. Yet, their 17 ppm was only a fraction of the hundred and sometimes thousands ppm found in the wild North Sea seals.

Although seals and other sea mammals are particularly at risk because they feed almost entirely on fish from polluted oceans, people too are at risk; in fact the fish that the test seals consumed has been destined to human consumption. The human immune system is almost identical to that of other mammals and consequently, so are the effects. Recent studies have found that Canadian Inuit children, who also eat large quantities of wild fish, produce fewer antibodies than usual when they are vaccinated for certain diseases. As a result, they too are abnormally susceptible to illness.’ ( http://www.fao.org/ag/AGP/AGPP/Pesticid/Disposal/intro5_en.htm)
[The FAO in fao.org is the United Nation’s Food and Agriculture Organisation.]

The IIS, V10_A23, p. 4 concludes: ‘there will be no demonstrable impact on seals from dioxins in the effluent.’

Seals and Dioxin: Does it Matter?
[Sarcasm mode: On]
Does it Matter? Hell No! Seals are dumb, they stink, damage nets, steal fish. No one will miss them. Tenth Island is just a rock. Just go to the Tourism Tasmania site to see how useless and insignificant Tenth Island is: http://www.discovertasmania.com.au/home/tasmedia_index.cfm?level1=fact%20file&level2=content&chapterid=139

[Umm… there’s a small tour operation there, does it Matter?] Hell No! The pulp mill is a Project of State Significance; a penny-ante, eco-tourism business don’t matter, hey, if you go to their website and click on the map of their tour route, you’ll see they go over the ocean waste pipe.
This is great! They can stop and say, ‘Here is where millions of litres of effluent is dumped at sea every day, look around, it’s just water – everything is good. Now, where did the seals go?… Oh, look, here’s our life-like model…’ (visit: http://www.sealandsea.com/prod01.htm)
[Sarcasm mode: Off]

Gunns continually dismiss any issue with dioxin pollution. Dioxins are the most poisonous and persistent chemicals we know; they don’t go away and they don’t disappear. The seals on Tenth Island live their lives where the pulp mill will dump poisonous water; it is a wrong that they suffer for our profit. The RPDC, in its infinite wisdom will decide if the Gunns IIS about the effect of dioxins on seals is correct, right, adequate, sufficient, and comprehensive. I submit that it is not.

Jon Sumby has trained and worked as a professional photographer, high-rise window cleaner, and marine ecologist. He worked for five years as the Australian representative for the Sea Shepherd Conservation Society and crewed on the 2002/03 Antarctic whaling campaign. He is presently working on a PhD in science and policy-making.

‘This world is indeed a living being endowed with a soul and intelligence … a single visible living entity containing all other living entities, which by their nature are all related.’ — Plato, 4th century BC.