EPA-
Water Quality Assessment of Proposed
   Effluent Guidelines for the Pulp,
   Paper, and Paperboard Industry
          Standards and Applied Science Division
           Office of Science and Technology
       United States Environmental Protection Agency
               Washington, DC 20460
                 November 1993

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                                        EPA -
Water Quality Assessment of Proposed
   Effluent Guidelines for the Pulp,
   Paper, and Paperboard Industry
          Standards and Applied Science Division
            Office of Science and Technology
        United States Environmental Protection Agency
               Washington, DC 20460
                 November 1993

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                     ACKNOWLEDGEMENTS AND DISCLAIMER

This report has been reviewed and approved for publication by the Standards and Applied
Science Division, Office of Science and Technology.  This report was prepared with the support
of Tetra Tech, Inc. (contract 68-C3-0303) under the direction and review of the Office of Science
and Technology. Neither the United States Government nor any of its employees, contractors,
subcontractors, or their employees make any warranty, expressed or implied, or assumes any legal
liability or responsibility  for  any third party's  use of or the results of such use of any
information, apparatus, product, or process discussed  in this report, or represents  that its use by
such party would not infringe on privately owned rights.

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                                        CONTENTS


       Tables  	:.	'.	v

       Figures 	vii

       Executive Summary	  ix

1.     Introduction	1

2.     Description of the Industry  	3

       2.1    Brief Description of the Pulp and Paper Technology	: . .  . .	4

              2.1.1   Chemical Pulping	4
              2.1.2   Pulp Bleaching	4

       2.2    Process Controls and Changes Considered	8

              2.2.1   Oxygen Delignification	8
              2.2.2   Extended Delignification	9
              2.2.3   Chlorine Dioxide Substitution	".	9
              2.2.4   Ozone Delignification	9
              2.2.5   Peroxide Delignification	9

       2.3    Proposed BPT, BCT, and BMP Controls	10

3.     Background	 . .	'	13

       3.1    Pollutants of Concern  	.......:	13

              3.1.1   2,3,7,8-TCDD and 2,3,7,8,-TCDF  	.".:.-	17
              3.1.2   Other Toxic and Nonconventional Contaminants	 21

                     3.1.2.1 AOX	 .'.	21
                     3.1.2.2 Color	22

              3.1.3   Conventional Pollutants	22

       3.2    Recreational Fisheries  	24
       3.3    Fish Advisories	26

4.     Methodology	27

       4.1    Estimating In-Stream Concentrations	31
       4.2    Estimating Impacts to Aquatic Life	32
                                             111

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       4.3
                                   CONTENTS (continued)
Estimating Impacts to Human Health	33
              4.3.1   Comparison to AWQCs for the Protection of Human Health	33
              4.3.2   Estimation of Carcinogenic Risks and Noncarcinogenic Hazards	33

                      4.3.2.1  Potential Carcinogenic Risks	35
                      4.3.2.2  Potential Noncarcinogenic Hazards	36

5.     Results  	41

       5.1    Aquatic Life Impact Assessment	41
       5.2    Human Health Impact Assessment  	42

              5.2.1   Comparison with AWQCs for the Protection of Human Health	42
              5.2.2   Potential Carcinogenic Risk	44

                      5.2.2.1  DRE Model	45
                      5.2.2.2  Simple Dilution Model  	45

              5.2.3   Potential Noncarcinogenic Hazards  	46

                      5.2.3.1  DRE Model	46
                      5.2.3.2  Simple Dilution Model  	47
                      5.2.3.3  Number.of Anglers Potentially Exposed  	48

              5.2.4   Impacts of BAT Controls on Dioxin-Related Fish Advisories  	48

6.     Limitations and Uncertainties	51

       .6.1    Limitations	51
       6.2    Uncertainties Associated with Risk Estimates	„	51

7.     References	55

       Attachments	A-l
                                             IV

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                                          TABLES
Number
1      Selected Process Change Options for Each Subcategory	x

2      Estimated Number of Pollutants and Mills Exceeding Aquatic Life AWQCs	xi

3      Estimated Number of Pollutants and Mills Exceeding Health-Based AWQCs  	xii

4      Average Individual Lifetime Cancer Risks for Recreational and Subsistence Anglers
       at Baseline and at Selected BAT Estimated Using Two Water Quality Models (Simple
       Dilution and DRE)	  xiv

5      Annual Cancer Cases for Recreational and Subsistence Anglers at Baseline and at
       Selected BAT Estimated Using Two Water Quality Models (Simple Dilution  and DRE) . . . xv

6      Number of Mills Exceeding RfDs for Recreational and Subsistence Anglers
       at Baseline and at Selected BAT Estimated Using Two Water Quality Models
       (Simple Dilution and DRE)  	  xvi

7      Number of Receiving Streams That Would Exceed Dioxin-Related State Fish
       Advisory Threshold Limits Under Various Regulatory Alternatives, at Current
       and Selected BAT Conditions, Estimated Using the Simple Dilution and DRE
       Approaches	   xviii

2-1    Receiving Streams for the 103 BAT Pulp and Paper Mills  	7

2-2    Selected Process Options for Each  Subcategory	8

3-1    Toxicity Values for the Contsiminants Analyzed in the Pulp and
       Paper Assessment . . .	15

3-2    Systemic Human Toxicants Evaluated and Their Target Organ Endpoints	16

3-3    Human Carcinogens Evaluated, Weight-of-Evidence Classifications,
       and Target Organs	16

3-4    Affected Organisms and the Physiological and Community
       Impacts that Have Been Linked to  the Presence of 2,3,7,8-TCDD	 18

3-5    Target Organs/Tissues, Effects, and Species-Specific  Toxicity
       Values for TCDD	19

3-6    Various Methodologies and Their Frequency of Use by States for
       Deriving Action Levels for Issuing Fish Advisories 	-	27

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                                   TABLES (continued)
Number
3-7    State Action Levels for Dioxin	27

3-8    Receiving Streams of Bleaching Pulp and Paper Mills Under Dioxin Fish
       Advisories,  the Advisory Type, and Species Whose Consumption Is Limited  	28

5-1    Estimated Number of Pollutants and Mills Exceeding Aquatic Life AWQCs	41

5-2    Estimated Number of Pollutants and Mills Exceeding Health-Based AWQCs  	43

5-3    Average Individual Lifetime Cancer Risk and Annual Increased Incidence of
       Cancer for Recreational and Subsistence Anglers at Baseline and Selected
       BAT Estimated Using the DRE Approach	44

5-4    Average Individual Lifetime Cancer Risk and Annual Increased Incidence of
       Cancer for Recreational and Subsistence Anglers at Baseline and Selected
       BAT Estimated Using the Simple Dilution Approach	1  .... 45

5-5    Number of Pollutants and Mills Exceeding RfDs for Recreational and
       Subsistence Angler Populations Estimated Using the Simple Dilution and
       DRE Approaches	47

5-6    Populations Potentially Exposed to Noncarcinogenic Hazards Under Baseline
       Conditions and After Implementation of the Selected BAT Options, Estimated
       Using the Simple Dilution and DRE Approaches	48

5-7    Number of Receiving Streams That Would Exceed State Fish Advisory Threshold
       Limits Under Various BAT  Options Estimated Using the Simple
       Dilution and DRE Approaches	 49
                                            VI

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                                          FIGURES






Number




2-1    Location of the 103 BAT pulp and paper mills  	




2-2    Location of BAT mills in the northeast United States .  .




2-3    Location of BAT mills in the southeast United States .  .




2-4    Location of BAT mills in the northcentral United States




2-5    Location of BAT mills in the northwest United States   .
5




5




6




6




7
                                              Vll

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                                   EXECUTIVE SUMMARY
The U.S. Environmental Protection Agency (EPA) is developing revised effluent guidelines and "maximum
achievable control technology" (MACT) standards for the pulp, paper,  and paperboard industry.  These
proposed regulations would limit the discharge of pollutants into navigable waters of the United States
and the introduction of pollutants into publicly owned treatment works by existing and new facilities that
produce pulp, paper, and paperboard.  The proposed regulations would establish effluent limitations
guidelines based on the "best practicable control technology currently available" (BPT), "best conventional
pollutant control technology" (BCT), "best available technology economically achievable" (BAT), effluent
"new source  performance  standards" (NSPS)  based  on best available demonstrated  technology,
"pretreatment standards for existing sources" (PSES), "pretreatment standards for new sources" (PSNS),
and "best management practices" (BMP).  EPA is also proposing to regulate emissions of hazardous air
pollutants from pulp and paper production processes, which are major sources under section 112 of the
Clean Air Act (CAA), as amended in 1990.

This environmental assessment has been  prepared in support of EPA's Regulatory Impact  Assessment
(RIA) for the pulp, paper, and paperboard industry effluent guidelines in compliance with Executive Order
12866, which requires EPA to assess the  costs and benefits of significant rulemaking. Through a mill-
specific analysis of 26  pollutants, this assessment evaluates both qualitatively and quantitatively the
potential aquatic  life and human  health benefits  of controlling the discharges from  four bleaching
subcategories that fall under BAT regulations (dissolving kraft, bleached papergrade kraft/soda, dissolving
sulfite, and papergrade sulfite).  In addition, the environmental significance of discharges from the non-
bleaching  segment of the industry is  also qualitatively  examined.   The environmental impacts of air
emissions are discussed in a separate document prepared in support of regulations limiting the emission
of hazardous air pollutants.

Description of the Industry

There are a total of 565 pulp and paper mills in the United States. The chemical pulping and bleaching
process is conducted by 104 mills,  103 of which are the focus of this environmental assessment. Of the
104 bleaching  mills,  94 discharge directly into navigable waterways  and will  be subject  to  BAT
regulations, 9 are indirect dischargers and will be subject to PSES regulations, and  1 does not discharge
wastewater into a navigable waterway and therefore-is not counted as a mill subject to BAT (memorandum
from Doug Spengel, Radian Corporation, to Drew Zacherle, Tetra Tech, Inc., June 7, 1993).   The 103
bleaching  mills being evaluated in this assessment have been grouped by EPA  into 4 subcategories
according to the bleaching process used and the resulting end product. The subcategories and the number
of mills in each subcategory are listed below:
       Subcategory

       Dissolving Kraft (DK)
       Bleached Papergrade Kraft/Soda (PK)
       Dissolving Sulfite (DS)
       Papergrade Sulfite (PS)
Number of Mills

        3
       86
        5
    	9
                                                          103
                                               IX

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The selected regulatory options  for BAT mills are designed to  reduce or eliminate the formation of
dioxins, furans, and other chlorinated organics that result from the chemical pulping and bleaching process.
Of the wide variety of regulatory options originally evaluated as to their ability to meet the standards of
the proposed rule (Attachment 1), EPA selected what appear to be the most appropriate BAT options for
each subcategory (Table 1).


                Table  1. Selected Process Change Options for Each Subcategory
Dissolving
Kraft
Oxygen delignification with
70% substitution of chlorine
dioxide for chlorine
Bleached ^pergrade-^V
Kraft/Soda i-
Oxygen delignification OR
extended delignification with
100% substitution of chlorine
dioxide for chlorine
Dissolving
"„£ Salfife
Oxygen delignification
with 100% substitution
of chlorine dioxide for
chlorine
" "- Pajpergrade
Sulfifcr -
TCP: Totally chlorine-free
bleaching
Approach

This environmental assessment evaluates the potential impacts of bleaching pulp and paper mill effluents
on aquatic life and human health.  Potential impacts on aquatic life are evaluated by comparing modeled
in-stream contaminant concentrations to aquatic life water quality criteria or toxic effect values (referred
to as ambient water quality concentrations, or AWQCs, i^' the: protection of freshwater aquatic life).
These aquatic life AWQCs include published EPA water quality criteria or toxic levels derived from the
scientific  literature for pollutants for which EPA  criteria are  not  available.    Modeled  in-stream
concentrations are compared to both acute AWQCs and chronic AWQCs when available.

Potential impacts on human health are evaluated by (1) comparing estimated in-stream contaminant
concentrations to health-based toxic effect values (referred to as ambient water quality concentrations, or
AWQCs, for the protection of human health); (2) estimating the potential reduction of carcinogenic risk
and noncarcinogenic hazards from the consumption of fish tissue; (3) estimating the annual incidence of
cancer in  the potentially exposed angler population; and (4) estimating the number of existing dioxin-
related state fish advisories that will potentially be lifted after the implementation of the selected BAT
options. Estimates are also made of the potential increase in recreational angler participation due to the
lifting of fish advisories as a result of implementation of the selected BAT options.

Exposure  pathways evaluated in the human health risk assessment (both cancer and noncancer) include
ingestion of fish by recreational and subsistence anglers and their households.  Exposure to contaminants
through the water pathway is also evaluated by the comparison of  modeled in-stream contaminant
concentrations to health-based AWQCs for the ingestion of water and organisms.   The potential human
health cancer risk and noncancer hazards associated with the ingestion of drinking water are not evaluated
because no municipal public water intakes are within the same river reach or within  10 miles downstream
from any bleaching pulp and paper mill effluent discharge (whichever is the greater distance).

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 Results
 Aquatic Life Benefits

 Only one contaminant (pentachlorophenol) at two bleached papergrade kraft/soda mills is pr  :ected to
 exceed acute aquatic life AWQCs under baseline conditions (Table 2).  With the implementation of the
 selected BAT options, it is projected that no exceedances of acute aquatic life AWQCs will occur.

 The implementation of the selected BAT options for each of four bleaching subcategories eliminates the
 exceedances of chronic aquatic life AWQCs for dioxin (with the exception of one mill in the  bleached
 papergrade kraft/soda subcategory) and eight other chlorinated organic compounds that are projected to
 occur as a result of baseline-level discharges (Table 2).  The following pollutants are predicted to exceed
 chronic aquatic life AWQCs under baseline conditions:
     •   4-Chlorocatechol
     •   Pentachlorophenol
     ?   2,3,7,8-TCDD
     •   2,3,7,8-TCDF
     •   3,4,5,6-Tetrachloroguaiacol
3,4,5-Trichloroguaiacol
4,5,6-Trichloroguaiacol
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
 The estimated number of mills exceeding chronic aquatic life AWQCs at baseline is reduced from 28 mills
 to 1 mill after implementation of the selected BAT options.

       Table 2.  Estimated Number of Pollutants and Mills Exceeding Aquatic Life AWQCs
'fe?,^^ f rop^s,,f r ;

Baseline
Selected BAT Option
Total Number of
Pollutants and Mills
(in parenthesis) with
Exceedances

'V: SL*S?
DK
0
0
fe«^%a^4i^yfg' ^^
PK
1(2)
0
DS
0
0
PS
0
0
Baseline = 1(2)
Selected BAT Options = 0
!^M?^*®M^3w^x^'- =7
DK
3(1)
0
PK
9(27)
1(1)
DS
0
0
Baseline = 9(28)
Selected BAT Options = 1(1)
PS
0
• o

Human Health Benefits

1.  Reduction of Health-Based AWQC Exceedances

The implementation of the selected BAT options for each of the four bleaching subcategories is projected
to reduce the number of mills that exceed health-based AWQCs for ingestion of both organisms and water
and organisms from 97 mills at baseline conditions to 78 after BAT implementation (Table 3).  Health-

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      Table 3.  Estimated Number of Pollutants and Mills Exceeding Health-Based AWQCs
Process Change
Option

Baseline
Selected BAT Option
Total Number of
Pollutants and Mills
(in parenthesis) with
Exceed anccs
' Number ef&rtftttan&aiiilMil^ :? °°f
'''::? /"- _WQCI?*^ancesr . V !«*i:i • ^ L .•
(organisms) Human HeiilUi ,~; * ->"-_
DK
3(3)
2(2)
PK
5(80)
2(71)
DS
2(5)
2(5)
PS
2(9)
0
Baseline = 5(97)
Selected BAT Options = 2(78)
/ -, , - »<
- -*~\ --Cwate
DK
7(3)
3(2)
r and organisms) Human Health • ,
PK
8(80)
4(71)
DS
4(5)
4(5)
PS
4(9)
0
Baseline = 8(97)
Selected BAT Options = 5(78)
based AWQCs for protection from the ingestion of contaminated organisms are exceeded under baseline
conditions for the following five contaminants:

    •  Chloroform
    •  Pentachlorophenol
    •  2,3,7,8-TCDD
    •  2,3,7,8-TCDF
    •  2,4,6-Trichlorophenol

Not all 97  mills exceed health-based AWQCs for all 5 contaminants under baseline conditions.  The
selected BAT chlorine-free option for the papergrade sulfite subcategory  eliminates all health-based
AWQC exceedances for ingestion  of organisms.  The selected BAT options  for the dissolving kraft,
bleached papergrade kraft/soda, and dissolving sulfite subcategories reduce the number of contaminants
for which health-based AWQC exceedances are projected to occur to two:  2,3,7,8-TCDD and 2,3,7,8-
TCDF.

Three additional health-based AWQCs, for a total of eight, are projected to exceed health-based AWQCs
for protection from the ingestion of contaminated water and organisms under baseline conditions.  These
eight exceedances are for the following contaminants:

    •  Chloroform
    •  4-Chlorophenol
    •  2,6-Dichlorophenol
    •  Methylene chloride
    •  Pentachlorophenol
    •  2,3,7,8-TCDD
    •  2,3,7,8-TCDF
    •  2,4,6-Trichlorophenol

Not all mills are projected to exceed the health-based AWQCs for all eight contaminants under baseline
conditions.  As expected, all exceedances of health-based AWQCs for the ingestion of water and
organisms for the papergrade sulfite subcategory are eliminated with the implementation of the selected
                                              XII

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 BAT option (totally chlorine-free bleaching).  The selected BAT options for the dissolving kraft, bleached
 papergrade kraft/soda, and dissolving sulfite subcategories are projected to reduce the number of
 contaminants for which health-based AWQC exceedances occur to five:

     •   Chloroform (DS mills only)
     •   2,6-Dichlorophenol (PK mills only)
     •   Pentachlorophenol
     •   2,3,7,8-TCDD
     •   2,3,7,8-TCDF

 Not all the mills projected to exceed the health-based AWQCs exceed them for all five contaminants.

 2.   Reduction of Potential Cancer Risks and Noncancer Hazards

 Two different methods—the simple dilution approach and the Dioxin Reassessment Evaluation (DRE)
 Model  approach—are used to  determine  fish tissue (i.e., fillet) concentrations for  the  following 6
 carcinogens and 11  systemic toxicants for 100 mills located near 68 receiving streams:
               Carcinogens

         Chloroform
         Methylene chloride
         Pentachlorophenol
         2,3,7,8-TCDD
         2,3,7,8-TCDF
         2,4,6-Trichlorosyringol
              Systemic Toxicants
Acetone
2-Butanone
Chloroform
4-Chlorophenol
2,4-Dichlorophenol
Methylene chloride
Pentachlorophenol
2,3,7,8-TCDD
2,3,7,8-TCDF
2,3,4,6-Tetrachlorophenol
2,4,5-Trichlorophenol
The DRE modeling approach is used only to evaluate cancer risk and noncancer hazards associated with
2,3,7,8-TCDD and 2,3,7,8-TCDF.  The simple dilution method is used  to evaluate cancer risk and
noncancer hazards for all of the contaminants listed above. The two models are used to evaluate the
potential accumulation of contaminants  in fish and the resulting impacts on  human health from the
consumption of contaminated fish and to project the effect of the selected BAT options on existing dioxin-
related fish advisories.

The simple dilution approach is a very conservative methodology that assumes that all  of the pollutant
loadings discharged to a receiving stream, including  TCDD and TCDF, are available to the biota,
particularly  fish.   The DRE approach uses a model developed by  EPA's Office of Research and
Development (currently under EPA review) (USEPA, 1993c). The model assumes that the bioavailability
of dioxins is dependent on 'the levels of suspended  solids in the discharge and the receiving stream.
Because two models are used in this assessment, the results are presented as a range. The results from
the DRE model provide the lower end of the range, and the results from the simple dilution approach
provide the upper end.
                                             xm

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Reduction of Cancer Risks

Using the DRE model (which is used in this assessment only to evaluate potential human health impacts
due to exposure to 2,3,7,8-TCDD and 2,3,7,8-TCDF), the average individual lifetime cancer risk after
implementation of selected BAT options for dissolving kraft and bleached papergrade kraft/soda facilities
is predicted to be reduced to the  10"5  level for recreational anglers and to the 10~4 level for subsistence
anglers, as  compared to estimated baseline risks at the 10"3 to 10"4 level for recreational anglers and. the
10~2 to 10"3  level for subsistence anglers (Table 4). For dissolving sulfite facilities, the overall cancer risk
for recreational anglers is estimated to decrease to the 10"5 level after BAT implementation as compared
to the 10"4 level under baseline conditions.  For subsistence anglers the cancer risk associoated with
dissolving sulfite mills is projected to remain at the 10~3  level, the same as under baseline conditions.

Using the simple dilution approach, the average individual lifetime cancer risk for dissolving kraft facilities
is projected to be reduced to the  10~4  level for recreational anglers and to the 10~3 level for subsistence
anglers as compared to estimated baseline risks at the 10"3 level for recreational anglers and the 10"2 level
for subsistence anglers.  The average  individual lifetime cancer risk for bleached papergrade kraft/soda
facilities is predicted to be reduced to the 10~5 level for recreational anglers and to the 10"4 level for
subsistence anglers as compared to estimated baseline risks at the 10"4 level for recreational anglers and
10"2 level for subsistence anglers. The individual lifetime cancer risk associated with dissolving  sulfite
mills is predicted to remain at the 10"4 level for recreational anglers and the 10"3 level for subsistence
anglers under BAT (the same as under baseline conditions).  Using  the simple dilution approach, it is
estimated that approximately 99 percent of cancer risk is due to 2,3,7,8-TCDD and 2,3,7,8-TCDF under
both baseline and BAT conditions (Attachment A-23).

The selected BAT  option for the papergrade sulfite mills is a totally chlorine-free process that completely
eliminates the formation and subsequent discharge of chlorinated organics. The individual lifetime  cancer
risk from these operations for recreational anglers would be reduced to 0 from an estimated baseline risk
at the  10"s  level (using both the  DRE and simple dilution approaches); the risk for  subsistence anglers
would be reduced to 0 from an estimated baseline risk at the 10'4 (DRE approach) to 10'3 (simple dilution
approach) level.
             Table 4. Average Individual Lifetime Cancer Risk for Recreational and
              Subsistence Anglers at Baseline and at Selected BAT Estimated Using
                     Two Water Quality Models (Simple Dilution and DRE)



Subcategory
Dissolving Kraft
Bleached Papergrade
Kraft/soda
Dissolving Sulfite
Papergrade Sulfite

DI

Baseline
10'3
10"4
10"4
io-5
t •: Vf.
Recreation
we 7> '
Selected
; Option
10'5
io-s
io-5
Eliminated
t-Frf '"-'"
^ ' < •f'?
• ' --,-
Baseline ^
io-3
io-4
10*
io-5
?"•;, ,-'; ,
Daoaoa^l
Selected'
Opfionx;
io-4
io-5
io-4
Eliminated
- '™JT •" '" •
;SH • Sjai
°??; „ *^t
•/Baseline:-,
10'2
io-3
10'3
io-4
''s'teir'
^,:?"-'->":'
g$Sr'
;,-Opiion:
io-4
ur»
io-3
Eliminated
sfe'AailW'
- Simple
,- r-1;.
Baseline
io-2
10'2
io-3
io-3
:;-r:'T^ '^%
Diluti^S:
-SelW^l-
OptionS
io-3
10"4
10'3
Eliminated
                                               XIV

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It is estimated that for combined recreational and subsistence anglers, implementation of the selected BAT
options would eliminate between 5 (DRE approach) and 35 (simple dilution approach) cancer cases per
year resulting from the consumption of contaminated fish tissue (Table 5).  Using the DRE approach, it
is estimated that the number of cancer cases per year would be reduced from less than six under baseline
conditions to less than one under the selected BAT options.  Using the simple dilution approach, it is
estimated that the number of cancer cases per year would be reduced from 37.5 under baseline conditions
to 2.5 under the selected BAT options.

Reduction of Noncancer Hazards

The DRE model is used only to evaluate the noncancer hazard associated with 2,3,7,8-TCDD and 2,3,7,8-
TCDF.   The estimated number of mills in the four bleaching subcategories exceeding reference doses
(RfDs) for 2,3,7,8-TCDD and 2,3,7,8-TCDF for recreational anglers using the DRE approach is reduced
from  34 mills under baseline conditions to 7 (a 79 percent reduction) after the implementation of the
selected BAT options (Table 6). The selected BAT totally chlorine-free option for papergrade sulfite mills

                 Table 5. Annual Cancer Cases for Recreational and Subsistence
                    Anglers  at Baseline and at Selected  BAT Estimated Using
                      Two Water Quality Models (Simple Dilution and DRE)
?£~~ ;''-£ ^
v*'*"1 ^ X" ** •<'
Jj^ 4$$BCirf€|H0Ty°
Dissolving Kraft
Bleached
Papergrade
Kraft/soda
Dissolving
Sulfite
Papergrade
Sulfite
Total
•?•-'$-,, '-1
'I' '"i-i-'pi
'.is
0.14
2.81
0.18
0.07
3.20
Recreation
¥vS-< '
Delected;,
<0.01
0.30
0.17
Eliminated
0.47

''v M?t?''<* ~"J
Baseline';
0.7
19.28
0.53
0.18
20.69
-rl\;\i
ffaufi"'*' ' '
"!s§
0.04
0.91
0.50
Eliminated
1.45
V-'t-kH
^;S-1S
~-°» "~°- -'*<;
, Ba^roite^
0.12
2.36
0.13
0.06
2.67
.".&*£
^:;5il-;i
'%g;
<0.01
0.24
0.12
Eliminated
0.36

i'"simp^
'IIS
0.55
15.73
0.38
0.14
16.80
pxh' ";V-S
T^l.*"-'"''" "^
:^V
0.03
0.70
0.35
Eliminated
1.08
        NOTES:
        Total estimated number of cancer cases per year (recreational and subsistence) under baseline conditions using the
            DRE approach = '5.87
        Total estimated number of cancer cases per year (recreational and subsistence) under proposed BAT options using
            the DRE approach = 0.83
        Total estimated number of cancer cases per year (recreational and subsistence) under baseline conditions using the
            simple dilution approach = 37.49
        Total estimated number of cancer cases per year (recreational and subsistence) under proposed BAT options using
            the simple dilution approach = 2.53
        Estimated number of reduced cancer cases per year (recreational and subsistance) using the DRE
            approach = 5.04
        Estimated number of reduced cancer cases per year (recreational and subsistence) using the simple dilution
            approach = 34.96
                                                 XV

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           Table 6.  Number of Mills Exceeding RfDs for Recreational and Subistence
                  Anglers at Baseline and at Selected BAT Estimated Using Two
                        Water Quality Models (Simple Dilution and DRE)
Subcategory
Dissolving Kraft
Bleached
Papergrade Kraft
Dissolving
Sulfite
Papergrade
Sulfite
Total:
Percent
Reduction
Recreational Anglers -\
ORE
Bastline
1
29
2
2
34
Selected
Option"
1
4
2
0
7
79%
Simple Dilution":
Baseline
1
54
5
4
64
Selected;
Option
1
17
4
0
22
66%
«?"/ &ttfosi$t«flc«'Angleirt: ;, "•*„
_ ,-,DBE
"BaseMne
2
57
5
4
68
Selected. ;
Option"
1
17
4
0
22
68%
SimpleTOutkw-
Baseline
2
70
5
7
84
'lejected
^Option
1
46
5
0
52
38%
results in the complete elimination of baseline exceedances for two mills.  Of the seven mills projected
to exceed RfDs after the implementation of the selected BAT options, one is a dissolving kraft mill, four
are bleached papergrade kraft/soda mills, and two are dissolving sulfite mills.

For subsistence anglers, the estimated number of mills in the four bleaching subcategories exceeding RfDs
for 2,3,7,8-TCDD and 2,3,7,8-TCDF using the DRE approach is reduced from 68 at baseline conditions
to 22 (a 68 percent reduction) after the implementation of the selected BAT options. The selected BAT
totally chlorine-free option for  papergrade sulfite mills results in the complete elimination of baseline
exceedances for four  mills.  Of the 22 mills predicted to exceed RfDs after the implementation of the
selected BAT options, 1 is a dissolving kraft mill, 17 are bleached papergrade kraft/soda mills, and 4 are
dissolving sulfite mills.

2,3,7,8-TCDD and 2,3,7,8-TCDF are estimated to be responsible for more than 99 percent of the projected
noncarcinogenic hazard using the simple dilution approach (Attachment A-23). Two additional pollutants,
4-chlorophenol and 2,4,5-trichlorophenol, are projected to exceed their RfDs using the simple dilution
approach but only at baseline conditions and only for bleached papergrade kraft/soda facilities. One mill
is estimated to exceed the RfD for 4-chlorophenol for recreational anglers under baseline conditions using
the simple dilution approach.  Four mills are  estimated to exceed the  RfD  for 4-chlorophenol for
subsistence anglers under baseline conditions using the simple dilution approach. Two mills are estimated
to  exceed the RfD for 2,4,5-trichlorophenol for subsistence anglers under baseline conditions.
                                               XVI

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The estimated number of  mills  exceeding RfDs  for  recreational  anglers  for the four bleaching
subcategories using the simple dilution approach is reduced from 64 mills under baseline conditions to
22 (a 66 percent reduction)  after the implementation of the selected BAT options.  The selected BAT
totally chlorine-free option for papergrade sulfite mills results in the complete elimination of baseline
exceedances for four mills.  Of the 22 mills projected to exceed RfDs after the implementation of the
selected BAT options, 1 is a dissolving kraft mill, 17  are bleached papergrade kraft/soda mills, and 4 are
dissolving sulfite mills. All predicted exceedances under the selected BAT options are for 2,3,7,8-TCDD.

For  subsistence anglers,  the estimated  number  of mills exceeding  RfDs  for the four bleaching
subcategories using the simple dilution approach is reduced from 84 at baseline conditions to 52 (a 38
percent reduction) after the implementation of the selected BAT options.  The  selected BAT  totally
chlorine-free option for papergrade sulfite mills results in the complete elimination of baseline exceedances
for seven mills.  Of the 52 mills exceeding RfDs after the implementation of the selected BAT options,
1 is a dissolving kraft mill, 46 are bleached papergrade kraft/soda mills, and 5 are dissolving sulfite mills.
All predicted exceedances under the selected BAT options are for 2,3,7,8-TCDD and 2,3,7,8-TCDF.

3.  Impact of Proposed BAT Controls on Dioxin-Related Fish Advisories

As  of June 1993,  23  receiving streams (including open waterbodies) had  fish advisories in place for
dioxins.  Twenty-nine chlorine-bleaching pulp and paper mills discharge to these receiving streams in the
vicinity of the fish advisory locations and thus are considered to contribute to the fish tissue concentrations
of dioxins  that have  resulted in the issuance of the advisories.  Because of limitations in available
information, the potential beneficial impacts of the selected BAT options on the lifting of dioxin-related
fish advisories can be assessed for only 25 mills, which affect 20 fish advisories.  For 24 facilities that
discharge to 19 receiving streams with fish advisories in place, the impacts of the  selected BAT options
are analyzed by comparing modeled 2,3,7,8-TCDD and 2,3,7,8-TCDF fish tissue (i.e., fillet) concentrations
for each  selected BAT option, obtained by using the simple dilution and DRE modeling approaches, to
state-specific fish advisory action levels.  With the  exception of one dissolving kraft facility and one
papergrade sulfite  facilty, these mills are all in the  bleached papergrade kraft/soda subcategory.  The
comparison of estimated fish tissue concentrations to  state advisory action levels cannot be done for four
mills because the  states  in  which they are located  issue risk-based  advisories based on site-specific
determinations rather than using state action levels. However, the risk level used to issue one of the four
advisories is known to be 10~5; therefore, this risk level  can be compared to the cancer risk estimated for
that particular mill. In addition, receiving stream flow  data are unavailable for one receiving stream.

Three of the receiving streams  that currently  have dioxin-related fish advisories  in place also have
advisories in place in the same locations for other contaminants: two have advisories in place for mercury
and PCBs, and the third has an advisory in place for mercury. These contaminants are not being regulated
by the proposed pulp, paper, and paperboard rule.  As a result, even if the dioxin-related advisories are
lifted as a result of BAT implementation, advisories for the other contaminants of concern will remain in
place.

The results of this analysis (Table 7) indicate that 14 (using simple dilution approach) to 19 (using the
DRE approach) existing dioxin-related fish advisories could potentially be lifted after implementation of
the selected BAT options.  However, using the DRE approach, two of the receiving streams for which
dioxin-related fish advisories are projected to be lifted after BAT implementation will still have advisories
in place for other contaminants. Using the simple dilution approach, one receiving stream for which the
                                               xvii

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 Table 7. Number of Receiving Streams That Would Exceed Dioxin-Related State Fish Advisory
            Threshold Limits Under Various Regulatory Alternatives at Current and
                         Selected BAT Conditions, Estimated Using the
                             Simple Dilution and DRE Approaches
Discharge Conditions
Current Conditions
Selected BAT Option Conditions
Potentially Eliminated Advisories at
Selected BAT
Simple Dilution
20
6
14
° " ."--. ",: °' "<*>KB " ;v
20
1
19
dioxin-related fish advisory is projected to be lifted after BAT implementation will still have a nondioxin-
related advisory in place.

Based on the number of receiving streams projected to have dioxin-related fish advisories lifted after BAT
implementation and for which no other advisories for other contaminants are in place (i.e., 17 advisories
using the DRE approach and 13 advisories using the simple dilution approach), it is estimated that the
number of recreational anglers using receiving streams that currently have dioxin-related fish advisories
in place could increase from the estimated 135,630 anglers currently fishing these streams  to between
161,389 and 162,425 anglers after BAT implementation.  These estimates are also based on a limited
number of studies that evaluated changes in angler fishing habits due to the presence of fish advisories.
Based on these studies an estimated 20 percent of recreational anglers change their fishing  location or
participation in recreational fishing because of the presence of a fish advisory. For the purpose of this
study, it is  assumed that this 20 percent of the recreational angler population will again  fish in the
receiving streams in question if and when the dioxin-related fish advisories are lifted.

Limitations and Uncertainties
      t
The methodologies used  for this  environmental assessment are subject  to certain limitations and
uncertainties. Some of the problems encountered in the analyses result from lack of available data or lack
of research to evaluate methodological assumptions.

Every effort has been made to use methods and approaches that EPA considers to be standard practice.
Certain  assumptions  are  still  required,  however.   For example, for the  evaluation  of combined
noncarcinogenic hazards from exposure to a chemical mixture, limited  data are available for  actually
quantifying the potential synergistic and/or antagonistic relationships between chemicals in  a chemical
mixture.

Ninety-nine percent of the  estimated carcinogenic risks  and noncarcinogenic hazards calculated in this
study can be attributed to 2,3,7,8-TCDD and 2,3,7,8-TCDF. Therefore, the assumptions and methods used
to analyze the dioxin and furan data will affect the interpretation of the results of the regulatory impact
analysis and comparisons.  Areas of uncertainty relative to the dioxin and furan risk assessment include:

     • Bioconcentration factors used in the risk assessment;
                                              xvm

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     • Use of one-half the EPA-designated detection limit to estimate pollutant discharge loadings for
       all nondetect congeners; and

     • Aquatic  life toxic effect values, cancer slope factors (ql*), reference doses (RfDs), and toxic
       equivalency factors (TEFs), which are currently under review by EPA, used in the risk assessment.

Also, the methodology used to estimate fish advisory-related benefits assumes that the bleaching pulp and
paper mills are the only source of the dioxin in the stream segment and does not incorporate background
contributions either from contaminated sediments due  to'previous  discharge practices or from other
upstream  sources.   Furthermore, although  the discharge of these contaminants may cease  or may be
minimized, sediment contamination and subsequent accumulation of dioxin in aquatic organisms may
continue for years.  Actual improvements can be determined only by site-specific biological monitoring
to assess the appropriateness of eliminating fish consumption advisories.

An additional area of uncertainty involves the estimates of populations exposed to contaminated fish tissue.
For the purpose of this study,  angler  population estimates were based on data extrapolated  from the
number of fishing licenses sold in counties bordering receiving stream reaches and creel survey data. The
actual number of people  using  these receiving streams for their fishing activities is not known.  In
addition, the number of recreational anglers who change their fishing habits as a result of a fish advisory
is based on a few studies with relatively few data.
                                               xix

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                                      1.  INTRODUCTION
 This document presents the methodology for and results pf the environmental assessment conducted to
 estimate potential impacts on aquatic life and human health resulting from exposure to pulp and paper mill
 effluents.  The environmental assessment has been  prepared in  support of the U.S. Environmental
 Protection Agency's (EPA's) Regulatory Impact Assessment (RIA) for the pulp, paper, and paperboard
 industry effluent guidelines in compliance with Executive Order 12866, which requires EPA to assess the
 costs and benefits of significant rulemaking.  Significant rules are those which impose an annual cost to
 industry of $100 million or more or meet certain other economic impact criteria.

 The regulations being proposed by EPA would limit the discharge of pollutants into navigable waters of
 the United States and the introduction of pollutants into publicly owned treatment works by existing and
 new facilities that produce pulp, paper, and paperboard. These proposed regulations would also limit the
 emission of hazardous air pollutants by existing and new facilities in the pulp and paper production source
 category.

 The proposed regulations would establish  effluent limitations guidelines based on the "best practicable
 control technology currently available" (BPT), "best conventional pollutant control technology"  (BCT),
 "best available technology economically achievable" (BAT), effluent "new source performance standards"
 (NSPS) based on best available demonstrated technology, "pretreatment standards for existing sources"
 (PSES), "pretreatment standards for new sources" (PSNS), and "best management practices" (BMP). EPA
 is also proposing to regulate  emissions of hazardous air pollutants from pulp and paper production
 processes, which are considered major sources under section 112 of the Clean Air Act (CAA), as amended
 in 1990.

 Through  mill-specific analyses  of 26  pollutants, this assessment  evaluates  both  qualitatively and
 quantitatively the potential aquatic life and human health benefits of controlling the discharges from four
 bleaching subcategories that fall under BAT regulations (dissolving kraft, bleached papergrade kraft/soda,
 dissolving sulfite, and papergrade sulfite). In addition,  the environmental significance of discharges from
 the non-bleaching segment of the industry is also qualitatively examined. The environmental impacts of
 air emissions are discussed in a separate document prepared in support of regulations limiting the emission
 of hazardous air pollutants.

 For this environmental assessment, potential impacts on water quality are examined for baseline conditions
 and for all options under consideration for which loadings were provided, including selected BAT options,
 to evaluate the environmental benefit  of implementing various  BAT control technologies.  The effluent
 characterization data for BAT mills  were obtained from EPA's Office  of Science and Technology,
 Engineering and Analysis Division (memorandum from Doug  Spengel, Radian Corporation, to Drew
 Zacherle, Tetra Tech, Inc., June 7, 1993) and covered  103 BAT pulp and paper mills  within the  United
 States. Although the environmental impacts of conventional pollutants (e.g., BOD, TSS) are qualitatively
 examined for this environmental assessment, quantification of impacts is conducted only for the bleaching
 segment of the industry.  Therefore, the primary focus of this document is on toxic pollutants in bleaching
 mill effluents,  primarily chlorinated organics.

 This environmental assessment evaluates the impacts of bleaching pulp and paper mill effluents on aquatic
life and human health.  Potential impacts on aquatic life are evaluated by comparing modeled in-stream
contaminant concentrations  to acute and  chronic ambient water quality concentrations  (AWQCs)  for the

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protection of freshwater aquatic life.  The aquatic life AWQCs used include EPA's aquatic life water
quality  criteria and, in cases  where water  quality criteria have not  been developed, other values
representative of the chemicals' aquatic toxicity (Versar, Inc., 1993).

Potential impacts on human health are  evaluated by (1) comparing modeled in-stream contaminant
concentrations to health-based toxic effect values (referred to as ambient water quality concentrations, or
AWQCs,  for the  protection  of  human health);  (2) estimating potential  carcinogenic  risks  and
noncarcinogenic hazards from the consumption offish tissue; (3) estimating the annual incidence of cancer
in the potentially exposed angler population; and (4) comparing estimated  fish tissue levels (at BAT
control levels) with state fish advisory action levels. Estimates are also made of the potential increase in
recreational angler participation due to the lifting of fish advisories as a result of implementation of the
selected BAT options. Health-based AWQCs used in this assessment are derived using standard EPA
methodology (USEPA, 1991c).

Exposure pathways evaluated in the cancer risk and noncancer hazard assessment include ingestion offish
by the households of recreational and subsistence anglers. Exposure to contaminants through the water
pathway is also evaluated by the comparison of modeled in-stream contaminant concentrations to health-
based AWQCs for the ingestion of water and organisms.  The potential human health cancer risk and
noncancer hazards associated with the ingestion of drinking water are not evaluated because no municipal
public water intakes are within the same river reach or within 10 miles downstream from any bleaching
pulp and paper mill effluent discharge (whichever is the greater distance).

The results of these analyses are used as input in the quantification and  monetization of benefits in the
benefits assessment and the RIA for wastewater effluent process technology option analysis.

Chapter 2 of this document presents background information on the pulp, paper, and paperboard industry.
Chapter 3 presents a discussion of the pollutants of concern in pulp  and paper mill effluents and their
potential human health and environmental impacts. Chapter  4 describes the methodology for estimating
potential human health and ecological impacts from bleaching pulp and paper mill effluents.  Chapter 5
presents the results of the evaluations. Chapter 6 provides a discussion of the limitations and uncertainties
associated with the analyses. Chapter 7 presents the references cited in this assessment. The attachments
to this document include all supporting tables, including results of the analyses performed for each mill.
All data, information, and  results of analyses deemed confidential business information (CBI) are part of
the CBI record.

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                            2.  DESCRIPTION OF THE INDUSTRY
There are 565 pulp, paper, and paperboard mills in the United States. The chemical pulping and bleaching
process is conducted by 104 mills, 103 of which are the focus of this environmental assessment. Of the
104  bleaching  mills, 94 discharge directly  into navigable waterways and will  be subject  to  BAT
regulations, 9 are indirect dischargers and will be subject to PSES regulations, and  1 does not discharge
wastewater into a navigable waterway and therefore is not counted as a mill subject to BAT (memorandum
from Doug Spengel, Radian Corporation, to Drew Zacherle, Tetra Tech, Inc., June 7, 1993).  The 103
bleaching mills evaluated in this assessment are grouped into 4 subcategories:
       Subcategory

       Dissolving Kraft (DK)
       Bleached Papergrade Kraft/Soda (PK)
       Dissolving Sulfite (DS)
       Papergrade Sulfite (PS)
Number of Mills

         3
       86
         5
         9
                                                           103
Dissolving Kraft: The dissolving kraft subcategory includes mills where a highly bleached wood pulp is
produced by using a "full cook" process that employs a highly alkaline sodium hydroxide and sodium
sulfide  cooking liquor.   Included  in  the manufacturing  process  is  a "precook"  operation  called
prehydrolysis.  The principal product is a highly bleached and purified dissolving wood pulp, used
primarily for the manufacture of rayon, viscose, acetate,  and other products requiring the virtual absence
of lignin and  a  very high alpha cellulose content.   This subcategory also includes  facilities  that
manufacture dissolving grade kraft pulps and papergrade kraft pulps at the same site.

Bleached Papergrade Kraft/Soda: The bleached papergrade kraft/soda subcategory includes the integrated
production of bleached kraft wood pulp and board as well as coarse, tissue,  and fine papers.  Bleached
kraft wood pulp is produced on-site  using  a "full cook" process that employs  a highly alkaline sodium
hydroxide and  sodium sulfide cooking liquor. The principal products include papergrade market pulp,
paperboard, coarse papers, tissue papers, and fine papers, which include business, writing, and printing
papers.

This subcategory also includes the integrated production of bleached soda wood pulp and fine papers.  The
bleached soda wood pulp is produced on-site using a "full cook" process that employs a highly alkaline
sodium hydroxide cooking liquor. The principal products are fine papers, which include printing, writing,
and business papers, and market pulp.

Dissolving Sulfite: The dissolving sulfite subcategory includes mills where a highly bleached and purified
wood pulp is produced using a "full cook" process that employs  strong solutions of calcium, magnesium,
ammonium, or sodium sulfites.  The pulps produced by this process are viscose, nitrate, cellophane, or
acetate  grades,  and they are used principally for the manufacture of rayon and other products that require
the virtual absence of lignin. This subcategory also includes facilities that produce papergrade wood pulp
and dissolving  sulfite pulps at the same site.

Papergrade Sulfite:  The papergrade sulfite subcategory includes  the integrated production of sulfite wood
pulp and paper, with or without brightening  or bleaching. The sulfite wood pulp is produced on-site using

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a "full cook" process that employs an acidic cooking liquor of calcium, magnesium, ammonium, or sodium
sulfites.  Following the cooking operations, the spent cooking liquor is washed from the pulp in blow pits
or on vacuum or pressure drums.  Also included are mills  that use belt extraction systems  for pulp
washing. The principal products include tissue papers, fine papers, newsprint, and market pulp.

Figures 2-1 through 2-5 illustrate the geographic location of the BAT mills, and Table 2-1 is a list of the
68 receiving streams for these mills.

2.1     Brief Description of the Pulp and Paper Technology

Wood is composed of cellulose, hemicellulose, lignin, and extractives.  Cellulose constitutes 40 percent
of most  wood and is the most valuable component.  Lignin  acts as a bonding agent and provides the
rigidity in the fibers. Hemicellulose is a polysaccharide that is of little or no use. The extractives in
softwood are used to produce turpentine and tall oil.

2.1.1   Chemical Pulping

The chemical  pulping process removes the lignin, allowing the fibers to be separated and improving the
resulting quality of the fibers for the papermaking process.  The majority of mills chemically pulp wood
by using the kraft (sulfate) or sulfite process. The kraft process uses sodium hydroxide and sodium sulfide
heated to 160-180  °C to cleave the lignin bonds, causing  the dissolution of the lignin, as well as the
hemicellulose and extractives.  Fifty-five percent of the total weight of the wood and 90-95 percent of the
lignin are removed in the pulping liquor.  Sulfite mills dissolve the lignin with a heated mixture of sulfur
dioxide and alkaline oxides  (sodium, magnesium, or calcium) in a process known as sulfonation.  Both
pulping processes evaporate the cooking liquor and then burn it in a recovery boiler to recover energy and
inorganic chemicals that can be used in reconstituted pulping  liquor.

2.1.2  Pulp Bleaching

Bleaching is used to whiten pulp by chemically  altering the coloring matter and to impart  a higher
brightness.  The selection of wood type for pulping, the pulping process used, and the desired qualities
and  end  use of the paper product greatly affect the type and degree of pulp bleaching required.  The
whiteness of pulps is usually determined by measuring the reflectance of nearly monochromatic light by
a standard reflectance meter with a scale of 0  to  100.  Unbleached pulps generally exhibit brightness
values in the following ranges:
        Sulfite

        Groundwood

        Semi-chemical kraft
up to 65

40 to 60

25 to 35
Two basic methods are used to increase the brightness of pulps. The first is to use selective bleaching
agents that destroy at least a portion of the chromophobic, or colored, compounds without significantly
reacting with lignin, which binds* wood fibers together.  This method is used to brighten pulps with high
lignin content such as groundwood and semi-chemical pulps. Brightness values above 70 are difficult to
achieve without delignification.  However, significant delignification of these pulps is not desirable due
to the negative impact on yield.  The second method of bleaching includes complete or near-complete

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o  Dissolving Kraft and Soda
A  Dissolving Sulflde
a  Papergrade Sulflde
o  Bleached Papergrade Kraft and Soda
      Figure 2-1.  Location of the 103 BAT pulp and paper mills.
                                             o Dissolving Kraft and Soda
                                               Dissolving Sulflde
                                             a Papergrade Sulflde
                                             o Bleached Papergrade Kraft and Soda
  Figure 2-2. Location of BAT mills in the northeast United States.
                                       5

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      O  Dissolving Kraft and Soda
      A  Dissolving Sulfide
      a  Papergrade Sulfide
      o  Bleached Papergrade Kraft and Soda
   Figure 2-3.  Location of BAT mills in the southeast United States.
                                                  o  Dissolving Kraft and Soda
                                                  A  Dissolving Sulfide
                                                  D  Papergrade Sulflde
                                                  o  Bleached Papergrade Kraft and Soda
Figure 2-4.  Location of BAT mills in the north central United States.
                                       6

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                                             o  Dissolving Kraft and Soda
                                             A  Dissolving Sulflde
                                             a  Papergrade Sulflde

                                             o  Bleached Papergrade Kraft and Soda
                                                       CO
          Figure 2-5.  Location of BAT mills in the northwest United States.

        Table 2-1.  Receiving Streams for the 103 BAT Pulp and Paper Mills
Alabama River
Altamaha River
Androscoggin River
Angelina River
Arkansas River
Atlantic Ocean
Baker Slough
Bayou La Fourche
Blackwater River
Cedar Creek
Chickasaw Creek
Clarion River
Clark Fork River
Codorus Creek
Columbia River
Conecuh River
Coosa River
Cypress Creek
Escanaba River
Escatawpa River
Fenholloway River
Flambeau River
Flint River
Grays Harbor
Hiwassee River
Holston River
Hudson River
Houston Ship Channel
Jackson River
Juniata River
Kennebec River
Lake Champlain
Leaf River
Menominee River
Mississippi River
Mosquito Creek
Neuse River
North River
Ohio River
Ouachita River
Pacific Ocean
Paint Creek
Pamunkey River
Pee Dee River
Penobscot River
Perdido River
Pigeon River
Port Angeles Harbor
Port Gardner Bay
Potomac River; N. Branch
Presumscot River
Rainy River
Red River
Rice Creek
Roanoke River
Sacramento River
Sampit River
Savannah River
Silver Bay
Spirit Creek
St Joseph Sound
Tombigbee River
Turtle River
Ward Cove
Wateree River
Wheeler Lake (Tennessee R.)
Willamette River
Wisconsin River

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removal of the lignin remaining after chemical pulping, followed by further bleaching of the pulp to a
desired degree of brightness.  The latter method is used to bleach kraft,  soda, and sulfite pulps to
brightness levels in the range of 80 to 90 and above.

In recent years there has been a major trend in the industry toward reducing both the types and the amount
of chlorine-containing chemicals used for pulp bleaching. Most of these changes have occurred as a result
of product quality considerations and environmental concerns about the formation of dioxins and other
chlorinated compounds during pulp bleaching and the presence of dioxins in pulp and paper products.
At many mills, chlorine dioxide is  being used  in first-stage bleaching in place of some or all of the
chlorine.  The use of hypochlorite has diminished in response to concerns about chloroform emissions,
and many mill operators have made significant  efforts to improve delignification prior to bleaching to
minimize bleach chemical use and the attendant formation of unwanted chlorinated by-products.

2.2    Process Controls  and Changes Considered

The selected process change options for BAT mills are designed to reduce or eliminate the formation of
dioxins, furans, chloroform, and other chlorinated organics. The selected process changes should reduce
the amount of lignin that needs to be bleached, thereby decreasing the quantities of chemicals needed in
the bleaching process and  reducing or eliminating the amount of chlorine used in the bleaching process.

A wide variety of process change options were originally evaluated by EPA as to their ability to meet the
standards of the proposed rule (Attachment 1). The process change options selected for each subcategory
for the proposed  regulations are listed hi Table 2-2. A brief synopsis of the selected process change
options follows.

2.2.1   Oxygen Delignification

Oxygen delignification, also known as oxygen bleaching, is a pulp treatment process that precedes the
bleaching process.  This process removes the residual lignin by treating the pulp with oxygen under
pressure in an alkaline environment. The removal of residual lignin reduces the downstream chemical
requirements for  pulp bleaching and  the formation of chlorinated organics.  Inorganic chemicals are
removed from the washwaters, and the organic load  removed from the pulp is used for generating heat.
                   Table 2-2. Selected Process Options for Each Subcategory
Dissolving
Kraft

Oxygen delignification
with 70% substitution
of chlorine dioxide for
chlorine
Bleached Papergrade „ ',' l'~
Krsft/Swia ' "7,2
*5 v "Select^ process
Oxygen delignification OR
extended delignification
with 100% substitution of
chlorine dioxide for
chlorine
~7. \<»»«d»g ' -|C
S-<° Cci^t1*!8*6. :••'„,?*?-
<*Chang.&' OfJttfaflfS^,^ '," -z^z?,* - °£
Oxygen deliginification
with 100% substitution
of chlorine dioxide for
chlorine
-.r-vxr ,, yft^^nA^-j^'-.-r.f
Sr" ;/,,s^;:r0:>^
'f / ^v"' „,' 'f**>-'e% s^ffi&f'*^ e?' /
TCP: Totally chlorine-free
bleaching using oxygen
delignification followed by
peroxide

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The oxygen delignification process removes approximately 50 percent of the original residual lignin, which
reduces the number of subsequent bleaching stages.  With oxygen delignification, a four-stage bleaching
sequence is sufficient to attain over 90 percent of the desired brightness level for bleached softwood kraft,
and a three-stage bleaching sequence is sufficient to attain an 85-90 percent brightness level.  In addition,
oxygen delignification reduces chlorine consumption by approximately 50 percent and has been shown
to reduce absorbable organic halogens (AOX) in untreated effluent concentrations by 41 percent and total
organic chlorine by 35 to 50 percent (USEPA, 1990b). The bleached pulp resulting from this technology
is considered to be equal to or superior in quality to conventionally bleached pulps with respect to tear
strength, brightness stability, pitch removal, beating energy, and cleanliness.

2.2.2    Extended  Delignification

Extended delignification, also known as extended cooking, involves extending  the kraft cooking process
to reduce the lignin content and the demand for subsequent bleaching. To maintain the quality of the pulp
during the  extended cooking process, adjustments are made in the alkali profile, residence  time, and
temperature. The two methods most commonly used are modified continuous cook and rapid displacement
heating. Both methods are known to reduce chlorine use by 50 percent, thereby reducing the production
of chlorinated organics.  When used in conjunction with 70 percent or higher  chlorine substitution (see
below), extended delignification can reduce AOX concentrations in untreated effluents by as much as 76
percent (USEPA,  1990b).  Canadian research has demonstrated reductions in AOX  and total  organic
chlorine by 50 percent and 70 percent, respectively.

2.2.3    Chlorine Dioxide Substitution

Chlorine substitution, the most popular of the new processes,  is the partial or  complete replacement of
elemental chlorine  by chlorine dioxide in the first stage of bleaching. Chlorine dioxide is a much stronger
oxidizing agent than elemental chlorine (2.63  times stronger).  Moreover, because it bleaches  pulp by a
different chemical  reaction pathway than that used by chlorine, it produces much smaller quantities of
chlorinated organic compounds than does chlorine. Chlorine dioxide can replace all of the chlorine in the
first bleaching stage.

2.2.4    Ozone Delignification

Ozone delignification is used prior to the chlorine bleaching stage and involves removing  lignin by
subjecting the pulp to ozone (O3) in an alkaline environment and sending the waste liquor to the recovery
system. Although  not presently used on a commercial scale, this process is intended to reduce chlorine
use and the subsequent production of chlorinated organics.

2.2.5    Peroxide Delignification

In peroxide delignification, pulp is subjected to peroxide in an alkaline environment prior to the  bleaching
sequence to reduce the production of chlorinated organics. Currently, only one mill (in Belgium) employs
this process (USEPA, 1990b).

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2.3    Proposed BPT, BCT, and BMP Controls

In addition to the  selected BAT process change options, EPA is also proposing BPT/BCT and BMP
controls for the pulp, paper, and paperboard industry. These treatment alternatives are designed to reduce
effluent;  to  control  conventional pollutants such  as  biochemical  oxygen demand (BOD5)  and total
suspended solids (TSS). To prevent and control spills of the black liquors produced during the processing
of the wood.

EPA is proposing to revise the BPT effluent limitations guidelines for biochemical oxygen demand (BOD5)
and total suspended solids (TSS) for all subcategories of the pulp, paper, and paperboard industry.  These
proposed revisions are based on the application of secondary wastewater treatment with appropriate water
use and reuse. For each subcategory, the proposed effluent limitations are defined by the performance of
the average of the best 50 percent of mills in that subcategory.

EPA is proposing to revise the BCT effluent limitations guidelines for BOD5 and TSS for all subcategories
of the pulp,  paper, and paperboard industry. In most  cases, the proposed BCT effluent limitations are
equal to the proposed BPT effluent limitations.

The BMPs that EPA is proposing will  require the implementation of certain practices, including pulping
liquor spill prevention, containment, and control measures.  BMPs  are known to reduce the amount of
pulping liquor that is discharged to the wastewater treatment  system, as well as to reduce the process
operation cost through increased chemical recovery. Specific  key elements that the BMPs will address
are:

    •  Employee awareness and training;

    •  Engineering analyses of problem areas and appropriate prevention and control strategies;

    •  Preventative maintenance;

    •  Engineered controls and containment;

    •  Work practices;

    •  Surveillance and repair programs;

    •  Dedicated monitoring and alarm systems; and

    •  Record keeping to document implementation of these practices.

Other BMPs that will be selected from a menu of practices for individual mills include:

    •  Secondary containment diking  around pulping liquor and storage tanks;

    •  Covered  storage tank capacity  for collected spills and spilled liquor diversions;
                                              10

-------
Automated spill detection systems, such as high level, flow, and conductivity monitors and alarms;
and

Backup equipment capacity to handle process upset conditions.
                                       11

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12

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                                      3. BACKGROUND
Pulp and paper mill effluent discharges contain toxic chemical compounds (including toxic contaminants
on EPA's list of priority pollutants and nonconventional pollutants), as well as conventional pollutants
such as biological oxygen demand (BOD) and total suspended solids (TSS). These contaminants may alter
aquatic habitats,  impact aquatic life, and subsequently adversely affect  human health through the
consumption of contaminated fish and water.

Toxic and nonconventional pollutants of concern in pulp and paper mill effluent include acetone, ketones,
catechols, guaiacols, aldehydes, chloroform, methylene chloride, chlorinated phenols,  polychlorinated
dibenzo-p-dioxins (PCDDs) and polychlorinated dibenzofurans (PCDFs), adsorbable organic halogens
(AOX), chemical oxygen demand (COD), and color. Of particular concern are the organochlorides, a class
of compounds known for their resistance to biodegradation, toxicity to aquatic life,  and long-range
environmental transport, as well as the level at which they concentrate in the fatty tissues of organisms
through either bioaccumulation or biomagnification (via the food chain).  The effects of toxic and
nonconventional pollutants on  aquatic life vary with the species, concentration of the chemical, and
duration of exposure.  However, a number of studies have linked toxic  or other biological effects in fish,
wildlife, and humans to exposure to these contaminants from pulp and paper mill effluents.

Conventional pollutants (e.g., TSS) can also cause site-specific environmental impacts.  For example,
habitat degradation can result from increased suspended  particulate matter that reduces light penetration
and, thus, primary productivity  or from accumulation of fibers that can alter benthic spawning grounds
and feeding habitat. Another conventional pollutant discharged in pulp and paper mill effluents is BOD,
which may alter ecosystem structural complexity and functional relationships as populations of planktonic
and macrobenthic organisms decrease or die out while pollution- or anoxia-tolerant bacteria flourish.

The following discussion presents a summary of the pollutants of concern found in pulp and paper mill
effluents and a review of their chemical characteristics and their potential effects on aquatic life and
human health. The issuance of dioxin-related fish advisories is also discussed.

3.1 Pollutants of Concern

From 1989 through 1993 EPA conducted  short-term  sampling episodes at several pulp  and paper mills
located nationwide.   These  mills  were  selected because  of their  particular pulping or bleaching
technologies or their  wastewater treatment systems, or because  of particular fiber furnishes used  or
products produced. The samples were analyzed for chlorinated didxins and furans; chlorinated phenolics;
volatile organics; semivolatile organics; pesticides/herbicides; metals; conventional pollutants (BOD5 and
TSS); and nonconventional pollutants (COD, AOX, and total organic halogens (TOX)).   A total  of 159
analytes were detected in samples from  11 mills.  Of the 159 compounds identified,  36 are priority
pollutants, 28 exhibit high to moderate acute toxicity in aquatic life, 37  are systemic toxicants in humans,
55 have been identified as carcinogens/mutagens, and 38 have  drinking water criteria values (USEPA,
1992e). Fifty-seven of the contaminants do not have aquatic toxicity data, and the effects on humans are
unknown for a majority of the  analytes.  During the last several years, many mills have made process
technology  and/or  operating  changes  in the  bleach  plant  to  reduce  the  formation of 2,3,7,8-
tetrachlorodibenzo-p-dioxin (TCDD), 2,3,7,8-tetrachlorbdibenzofuran  (TCDF), and  other  chlorinated
pollutants.  These changes have resulted in much-improved effluents.
                                               13

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 A cooperative long-term sampling effort involving both the industry and EPA was undertaken from 1991
 to 1992. The cooperative agreement provided for the sampling of eight bleaching mills that were chosen
 because of their particular pulping or bleaching technologies or their wastewater treatment systems, or
 because of particular fiber furnishes used or products produced.  Samples were collected to characterize
 the bleach plant effluent, plant exports (final effluent, pulp, and sludge), and wastewater treatment system
 performance. This sampling effort detected 49 unique analytes in the mills' wastewater during any point
 in the production process. Of the 49 contaminants detected, 13 are priority pollutants, 11 exhibit high to
 moderate toxicity to aquatic life, 14  are systemic toxicants in humans, 13  have been identified as
 carcinogens/mutagens, and  11  have drinking water criteria values  (USEPA,  1992c).  The effects on
 humans are unknown for 50 percent of the contaminants.

 The short-term and long-term sampling studies support previous data indicating that most of the priority
 pollutants are not present in bleached kraft mill effluents. However, among the priority pollutants that
 were detected in bleached kraft mill wastewater during these studies  are 2,3,7,8-TCDD, chloroform, and
 methylene chloride, as well as pentachlorophenol and  trichlorophenols.

 Based on an evaluation of the short-term and long-term sampling data,  EPA has identified 26 organic
 compounds of particular concern (USEPA, 1993b) belonging to three chemical groups—(1) dioxins and
 furans,  (2) volatile organic compounds, and  (3) chlorinated phenolics. Of these 26 contaminants, 6 are
 priority pollutants, 11 are systemic human toxicants, 6 are human carcinogens, 24 are aquatic life acute
 toxicants, and  26 are  aquatic life chronic toxicants.   Ambient water quality concentrations  (for the
 ingestion of organisms and water and organisms) for the protection of human health have been established
 for 12 and 13 of the contaminants, respectively (Table 3-1).

 Examples of observed effects  of some of  the  systematic human toxicants include reproductive  and
 developmental effects, liver toxicity, and fetotoxicity (Table 3-2). All  of the human carcinogens evaluated
 are classified as probable, or B2, carcinogens (indicating an agent for which there is sufficient evidence
 of carcinogenicity based on animal studies but inadequate data regarding its carcinogenicity from human
 epidemiological studies) (Table 3-3).

The primary focus of this aquatic life and human health risk assessment is on the 26 organic compounds
 of particular concern that are produced as a result of the pulp bleaching process (Table 3-1).   All 26
organic  compounds are evaluated in the assessment for their chronic aquatic life impacts,  and 24 are
evaluated for their acute aquatic life impacts.  Acute aquatic life toxicity values are unavailable for 2,3,7,8-
TCDD and 2,3,7,8-TCDF. Due to a lack of information on human health toxicity, only the following 13
pollutants are evaluated for their potential human health impacts:
   •  Acetone
   •  2-Butanone
   •  Chloroform
   •  4-Chlorophenol
   •  2,4-Dichlorophenol
   •  2,6-Dichlorophenol
   •  Methylene chloride
Pentachlorophenol
2,3,7,8-TCDD
2,3,7,8-TCDF
2,3,4,6-Tetrachlorophenol
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol •
                                               14

-------
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-------
      Table 3-2.  Systemic Human Toxicants Evaluated and Their Target Organ Endpoints
Systemic Toxicant
Acetone
2-Butanone
Chloroform
2,4-Dichlorophenol
2,3,7,8-TCDD
2,3,7,8-TCDF
Methylene Chloride
Pentachlorophenol
2,3,4,6-Tetrachlorophenol
2,4,5-Trichlorophenol
4-Chlorophenol
Reference Dose Target Organ and Effects x
Increased liver and kidney weights; neurotoxicity
Fetotoxicity
Fatty cysts in liver; fetotoxicity
Decreased delayed hypersensitivity response
Reproductive and developmental effects
Reproductive and developmental effects
Liver toxicity
Liver and kidney pathology
Increased liver weights and centrilobular hypertrophy
Liver and kidney pathology
Unknown
                Table 3-3. Human Carcinogens Evaluated, Weight-of-Evidence
                              Classifications, and Target Organs
Carcinogen
Chloroform
Methylene Chloride
Pentachlorophenol
2,3,7,8-TCDD
2,3,7,8-TCDF
2,4,6-Trichorophenol
Weight-of-Eyidence
Classification
B2
B2
B2
B2
B2
B2
Target Organs
Kidney
Liver
Liver
Liver and Other Organs
Liver and Other Organs
Kidney and Blood
A review of potential impacts on aquatic life and human health from exposure to 2,3,7,8-TCDD and
2,3,7,8-TCDF, as well as other toxic pollutants (i.e., priority pollutants and nonconventional pollutants)
and conventional pollutants, is presented below.
                                             16

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3.1.1  2,3,7,8-TCDD and 2,3,7,8-TCBF

2,3,7,8-TCDD and 2,3,7,8-TCDF were found to occur at every bleaching mill sampled in EPA's 104-Mill
Study (USEPA, 1990d). The identification of these highly toxic chemicals, and other PCDDs and PCDFs,
in pulp and paper mill effluents where chlorine bleaching is used has led to numerous research efforts on
the effects of these chemicals on aquatic life.  Although much of the research has focused on the effects
of TCDD and TCDF on the physiology, life history, and community structure of fish populations, many
of the same impacts have been observed in other aquatic species, as well as in terrestrial species that rely
on aquatic species as a food source (e.g., fish, Crustacea, birds, humans, and other mammals) (Table 3-4).
Both TCDD and TCDF have the same toxic endpoints. However, the toxicity of TCDD to aquatic life
is estimated to  be  two orders of magnitude greater than  that of TCDF, and the toxicity of TCDD  to
humans is estimated to be one order of magnitude greater than that of TCDF.  Therefore, the following
discussion is primarily focused on the nature and properties of TCDD.

Gross signs of TCDD toxicity in laboratory-exposed fish are species-dependent but may include decreased
growth rate, fin necrosis, cutaneous hemorrhage, hyperpigmentation, and edema.  Fish in the early life
stages are more sensitive than adults to TCDD toxicity; thus,  environmental levels of TCDD may affect
fish populations through reduced hatchability and the development of hemorrhages and subcutaneous yolk
sac edema (accumulation of fluid in the membrane sac attached to the embryo) similar to blue-sac disease
(Cook et al.,  1991).  Other impacts on fish exposed to TCDD have also been observed in laboratory
studies (Table 3-5). TCDF has been shown to adversely affect survival, growth, and behavior of fish.

The degree of toxicity of the contaminants found in pulp and paper mill effluents is directly related to the
bioavailability of these compounds and the potential of organisms to accumulate (absorb) the contaminants
in their tissues. Analyses of the tissues of invertebrates and fish downstream  from mill effluents have
revealed a variety of xenobiotics (foreign compounds not  produced by an  organism) compared  to
organisms from upstream  sites (Owens, 1991;  USEPA, 1992d).  The highly hydrophobia organic
chemicals, such as TCDD and TCDF, become tightly bound to organic carbon in the water column and
in sediment particulates and may not be detected in water.  Significant quantities, however, may be taken
up by organisms  from ingestion  of sediments or contaminated organisms.   Body burdens of these
compounds may reach toxic levels.

Other PCDD and PCDF congeners may be more rapidly metabolized in animals, resulting in lower
accumulations and relatively low toxicities. Examination of representatives from  simple food chain/web
organisms have revealed biomagnification  of TCDD and TCDF from phytoplankton and zooplankton
through mussels or fish to  waterfowl (Broman et al., 1992).  Terrestrial wildlife that feed on organisms
exposed to pulp and paper mill effluents are also at risk for toxic and reproductive effects (Gilbertson,
1989; Rabert, 1990).

Because 2,3,7,8-TCDD and 2,3,7,8-TCDF are lipophilic, or readily absorbable by fatty tissues, they may
be concentrated in aquatic organisms that have consumed contaminated  food  or water.  Broman et al.
(1992)  noted that  the wet weight bioconcentration  factor (BCF) for 2,3,7,8-TCDD  in  fish had
experimentally been determined to be in the range of 7,000 to 29,000, lower than  that expected based on
estimates of the water solubility and octanol/water partition coefficient (KDW).  Thomann (1989) observed
that the efficiency of uptake from water increases with increasing log Kow to a maximum when log Kow
                                              17

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Table 3-4. Affected Organisms and the Physiological and Community Impacts That Have Been
                         Linked to the Presence of 2,3,7,8-TCDD
Effect/Impact
1. Enzyme Induction
Z Immunological
3. Wasting Syndrome
4. Hepatic (liver)
5. Growth
6. Developmental (skeletal,
organs)
7. Dermatological (lesions, fin
necrosis)
8. Reproductive (fecundity,
sperm/oocyte development,
spawning)
9. Early Life History (eggs,
embryo, larvae)
10. Gill Function (fused
lamellae)
11. Hematological
12. Bioaccumulation
13. Toxicity (lethal/sublethal)
14. Mutagenicity
15. Carcinogenicity (risk
assessment)
16. Behavioral
17. Community Structure
18. Species Diversity
19. Biomass
20. Distribution
Affected Organisms
Fish
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
4-
+
+
+
Molluscs





+


+


+
+




+
+
+
Crustacea

-------
    Table 3-5.  Target Organs/Tissues, Effects, and Species-Specific Toxicity Values for TCDD
Organ/Tissue^*
HEMATOLOGIC - CC
Leukocytes
Thrombocytes
LYMPHOMYELOID
Thymus - H

Spleen - H, CC

Head kidney - H

EPITHELIAL
Skin - GV, H





Gill - H

Stomach - H


Liver - H










CARDIOVASCULAR
Cardiac


Lesion -•-

Leukopenia
Thrombocytopenia

Involution

Lymphoid depletion

Hypoplasia


Fin necrosis
Fin necrosis, hemorrhage, and
ascites
Fin necrosis
Hyperpigmentation

Lamellar fusion
Hypertrophy and hyperplasia
Necrosis, atrophy, and
hyperplasia
Submucosal edema
Vacuolization, necrosis



Bile duct hyperplasia
Lipidosis
Glycogen depletion
Hypertrophy
Intracytoplasmic inclusions



Myocyte necrosis
Pericarditis-fibrinous
Hypertrophy and hyperplasia
LOAEL* j

1 ug/lcg
1 ug/kg

10 ug/kg
25 ug/kg
10 ug/kg
5 ug/kg
10 ug/kg
25 ug/kg

10 ug/kg
5 ug/kg

25 ug/kg
lug/kg
13.1 ng/g (food)
10 ug/kg
25 ug/kg
10 ug/kg

26 ug/kg
10 ug/kg '•
2.3 mg/kg (food)
10 ng/1
25 ug/kg
1 ug/kg
25 ug/kg
25 ug/kg
10 ng/1
2.3 mg/kg (food)
10 ng/1 •


' 25 ug/kg
25 ug/kg ,
25 ug/kg f
» * » Species'

RBT
RBT

RBT
YP
RBT
YP
RBT
YP

RBT
YP

RBT, YP, C, LMB, CF, BG
C, LMB
CS
RBT
YP
RBT

YP
RBT
RBT

FHM
RBT
YP
YP
YP
YP
RBT
FHM

YP
YP
YP
*- Refetince^-, fS

Spitsbergen et al., 1986
Spitsbergen et al., 1986

Spitsbergen et al., 1986
Spitsbergen et al., 1988
Spitsbergen et al., 1986
Spitsbergen et al., 1988
Spitsbergen et al., 1986
Spitsbergen et al., 1988

Spitsbergen et al., 1986
Spitsbergen et al., 1988

Kleeman et al., 1988
Kleeman et al., 1988
Miller et al., 1979
Spitsbergen et al., 1986
Spitsbergen et al., 1988
Spitsbergen et al., 1986

Spitsbergen et al., 1988
Spitsbergen et al., 1986
Hawkes and Norris, 1977

Adams et al., 1986
Spitsbergen et al., 1986
Spitsbergen et al., 1988
Spitsbergen et al., 1988
Spitsbergen et al., 1988
Spitsbergen et al., 1988
Hawkes and Norris, 1977
Tietge et al., 1986

Spitsbergen et al., 1988
Spitsbergen et al., 1988
Spitsbergen et al., 1988
 "Grossly visible (GV), histological (H), cellular count (CC).
 "LOAEL = lowest observed adverse effect level.           •                                     ,
 "Rainbow trout (RBT), yellow perch (YP), bluegill sunfish (BG), carp (C), largemouth bass (LMB), catfish bullhead (CF), echo salmon (CS), fathead minnow (FHM).
Source: Cooper, 1989.          '                                                                          ,
                                                            19

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 approximately equals 3 to 6, then decreases with increasing log Kow above 6.  He concluded that food
 chain biomagnification would be significant for substances with log Kow approximately equal to 5 to 6.5
 and that this process explains virtually all of the top predator contaminant concentrations.  Complexities
 in natural food webs—including mechanisms that control the uptake, metabolism, and clearance rates—and
 difficulties in assessing the availability of different  toxic compounds as the result of sampling and
 analytical chemistry problems and natural variability make extrapolations from BCFs obtained  in
 laboratory studies to contaminant flux in food webs under field situations difficult (Broman et al, 1992).
 Nevertheless, a  number  of studies have examined  bioaccumulation and  biomagnification of these
 compounds in aquatic environments.  For example, in the northern Baltic Sea, biomagnification of the
 three most toxic 2,3,7,8-substituted polychlorinated dibenzo-p-dioxins and dibenzofurans decreased in total
 2,3,7,8-PCDDs/PCDFs with increasing trophic level in both the littoral and pelagic food chains. The most
 toxic 2,3,7,8-substituted isomers accumulated in the tissue of eider duck, but 80 percent of the consumed
 total PCDDs/PCDFs were metabolized or excreted (Broman  et al., 1992).

 BCF values are  dependent on the  characteristics of the individual chemicals.   Bioconcentration is a
 partitioning process between the lipids of the organisms and the surrounding water, and it is dependent
 on the amount of freely dissolved chemical available to fish through bioconcentration across the gills.
 BCFs, however, may be affected not only by variations in the lipid content of different fish species but
 also by the age of the fish; exposure level; how the concentration of the compound in water was measured
 (freely dissolved or total chemical); low bioavailability (the dioxins are highly hydrophobic); dissolved
 organic carbon content of the water (the higher the organic carbon content, the lower the bioavailability
 of hydrophobic chemicals); organic carbon in sediments; slow uptake rates; migration patterns offish; and
 other factors,  leading to measured BCFs that are lower than those predicted.

 The BCF of  50,000 for 2,3,7,8-TCDD used in this assessment  is  based on a measured value from
 laboratory research on rainbow trout, a pelagic freshwater species having a lipid content of approximately
 7 percent (Cook et al., 1991).  Relative BCFs measured by Mehrle et al. (1988) for TCDD (39,000) and
 TCDF (6,049) for the same lowest exposure concentration of TCDD, where fish were least affected, in
 the same species of fish, yielded a TCDD-to-TCDF BCF ratio of 6.45. Therefore, for this environmental
 assessment, the BCF for 2,3,7,8-TCDD (50,000) is divided by 6.45, resulting in a 2,3,7,8-TCDF BCF of
 7,752  (which was rounded to 8,000).

 The persistent and lipophilic nature of TCDD facilitates its bioaccumulation in the fatty tissues of aquatic
 organisms, particularly fish.   In spite of its relative insolubility, TCDD will  achieve a steady-state
 equilibrium between the water column and the sediments (USEPA, 1993a).  Concentrations of TCDD in
 the water column can become  elevated relative to the concentrations in the sediments because of the
 redistribution of contaminated sediments resulting from bioturbation and scouring.

 2,3,7,8-TCDD is known to be extremely toxic to aquatic life, with concentrations as low as 0.038 ng/L
 producing 45 percent mortality in rainbow trout over a period of 28 days (Mehrle et al., 1988).  Although
 fewer studies have been conducted on 2,3,7,8-TCDF, it is less toxic than TCDD (Mehrle et al., 1988).
 With respect to human health, TCDD is listed as a probable carcinogen and is known to have adverse
 effects on  reproductive capacity and liver function;  TCDF has also been identified as a probable
carcinogen.  More than 99 percent  of the human health-based risk and noncarcinogenic  hazard  from
bleached kraft pulp and paper mill effluent estimated in this assessment is directly related to 2,3,7,8-TCDD
and 2,3,7,8-TCDF (see Chapter 5).
                                              20

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3.1.2 Other Toxic and Nonconventional Contaminants

Of the 57 volatile organic compounds sampled in the short- and long-term sampling studies, chloroform,
methylene chloride, methyl ethyl ketone (2-butanone), and acetone were detected at all of the mills
(USEPA, 1992c, 1992e).  Chloroform and methylene chloride are toxic (priority) pollutants; methyl ethyl
ketone and acetone are nonconventional pollutants.  Twelve of the 20 chlorinated phenolics that were
found in bleach plant and final effluents are associated with the formation and presence of TCDD and
TCDF:
      Pentachlorophenol
      Tetrachlorocatechol
      Tetrachloroguaiacol
      Trichlorosyringol
      2,3,4,6-Tetrachlorophenol
      3,4,5-Trichlorocatechol
3,4,6-Trichlorocatechol
3,4,5-Trichloroguaiacol
3,4,6-Trichloroguaiacol
4,5,6-Trichloroguaiacol
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
2,4,6-Trichlorophenol and pentachlorophenol are toxic (priority) pollutants, and the remaining pollutants
are nonconventionals.

3.1.2.1  AOX. Chlorinated compounds can also be measured collectively as AOX, TOX, or TOC1 (total
organic chlorine). The preferred test measure analyzes AOX concentrations.  Previous EPA studies (i.e.,
the Five Mill Study (USEPA, 1988) and the Integrated Risk Assessment (USEPA, 1990c)) indicate that
although the AOX concentrations can be used to determine the removal of chlorinated organics to assess
loading reductions, they do not provide information on the potential toxicity of the effluent and therefore
are not appropriate to evaluate the potential impacts on the environment.   Although no statistical
relationship has been established between the level of AOX and specific chlorinated organic compounds,
AOX analysis can be an inexpensive method for obtaining the "bulk" measure of the total mass of
chlorinated organic compounds.

Historically, the use of AOX as a universal parameter was based on past environmental studies conducted
in Sweden. Observations from studies in the Gulf of Bothnia off the coast of Sweden indicated decreases
in the density and diversity of fish populations located near the discharges of bleached kraft mills, as
compared to fish populations that were located near discharges of unbleached kraft mills (Neuman and
Karas, 1988).  In addition, fish populations near bleached kraft mill effluents exhibited higher incidences
of skin diseases, skeletal deformities, fungal infections, fin erosion,  smaller reproductive organs, enlarged
livers, higher levels of liver detoxification enzymes,  and alterations  in  blood  chemistry and blood cell
ratios (Andersson et al.,  1988).

Several objections have  been raised regarding the use of AOX as a regulatory parameter and the
conclusion that the abnormalities  found in the Swedish studies could be attributed to the discharge of
organochlorines (Carey et al., 1993).  These objections are based on  the following:

     •   A correlation between AOX and the effects on the ecosystem had never been demonstrated.

     •   The Gulf of Bothnia has long been a source of various pollutants that might have contributed to
        the results of the  Swedish studies.
                                              21

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     •  The bleached kraft mill that was examined had operations that are atypical of well-operated and
        modern North American mills.

     •  Site-specific factors made the unbleached kraft mill unsuitable as a control for comparative
        purposes.

The Canadian government initiated some independent studies to address these objections.  Fish collected
from  Canadian study sites were compared to fish collected from reference sites located away from  the
mills. Fish collected near the mills were found to have smaller reproductive organs, enlarged livers, higher
levels of liver detoxification enzymes, and lower levels of sexual hormones in the blood, and they took
longer to reach maturity and had fewer secondary sexual characteristics (McMaster et al., 1991).  From
this evidence, the Canadian government concluded that the findings of the Gulf of Bothnia study were not
unique and that similar effects occurred in the fish communities located near Canadian bleached kraft mills
(Carey et al., 1993).

The distribution of the effects in the study did not correlate with AOX, and the major component of AOX
(>90 percent) failed to induce effects in laboratory studies. This information raised questions as to  the
applicability  of AOX for judging  impacts on the environment  and its use as a regulatory parameter.
Because of the lack of data to support the use  of AOX in evaluating toxicity, it is not  one of  the
parameters included in this assessment.

3.1.2.2  Color. Color is also a nonconventional pollutant of concern associated with pulp and paper mill
effluent discharges.  The intense brown color associated »..'.. pulp mill effluents is caused by lignin and
its derivatives, which are relatively stable compounds that degrade very slowly in biological treatment
systems and in receiving waters.  These compounds absorb light at wavelengths between 400 and 500
nanometers, the same spectral band that contains the two most important wavelength peaks for chlorophyll
a and a majority  of the other accessory pigments  in algae  (Thut and Schmiege, 1991). The absorption
of these important wavelengths can inhibit photosynthesis and, consequently, primary production and can
diminish  the visual cues necessary for organisms to feed or to reproduce (Owens, 1991; Thut and
Schmiege,  1991).  The effect of color on primary productivity is dependent on the concentration of the
effluent in the receiving stream, seasonal variations, depth distributions, and distance from the discharge
site.

The overall impact of color on aquatic algae is difficult to determine. Algae are capable of adapting over
time to shifts in light levels, or they may become metabolically inactive until they are dispersed out of
the effluent plume.  Primary production losses in phytoplankton as the result of color in pulping effluents
reducing light levels have been measured in the Baltic Sea and in  freshwater streams.  However, total
plankton biomass  may remain at the same level as species shift from autotropic (photosynthetic) organisms
to heterotropic organisms that use organic carbon  inputs (Owens, 1991).

3.1.3  Conventional Pollutants

Prior to the focus  on toxic contaminants found in bleaching pulp and paper mill effluents and their effects
on the aquatic environment, the regulatory community required mills to comply with BPT criteria.  As
efforts have shifted to the priority pollutants, the efforts to define the chemical  compounds in pulp mill
effluents responsible for causing environmental impacts at the community and population levels have been
greatly complicated by the presence of conventional pollutants such as biological oxygen demand (BOD)
and total suspended solids (TSS) (Owens, 1991). Such pollutants, in addition to the pulping and bleaching

                                               22

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chemicals, can alter the quantity of oxygen in the water column and sediments through biological oxidative
reactions  (Poole et al.,  1978) and may be assessed  by measuring the parameters  biochemical oxygen
demand (BOD5) and chemical oxygen demand (COD) in the water column. BOD is the amount of oxygen
required by aerobic (oxygen-requiring) organisms to carry out normal oxidative metabolism or the amount
required by oxidation of metabolic by-products from anaerobic organisms  in water containir  organic
matter. COD is the amount of oxidizable compounds (composed of carbon and hydrogen) prebc.it in the
water.  Another water quality parameter affected by these  pollutants is turbidity.

Suspended solids such as bark, wood fiber, dirt, grit, and other  debris can cause long-term damage to
benthic habitats in freshwater, estuarine, or marine ecosystems. Solids increase water turbidity and reduce
the amount  and quality of light present, reducing  the  growth of phytoplankton, algae, and submerged
aquatic vegetation.  Their presence in the water column can interfere with respiration and feeding by
clogging and abrading delicate gill lamellae in organisms such as bivalve mollusks  and fishes (Hart and
Fuller, 1974, 1979;  Rand and Petrocelli, 1984).  As solids settle out of the water column, they physically
cover and smother stationary or immobile benthic flora and fauna. Freshwater mussels are sensitive to
sedimentation stress, and a  number of species in the United States  are considered endangered and
threatened (Williams et al., 1993).  Feeding and reproductive habitat  of more mobile species, such as
crustaceans and fishes, may also be eliminated as the result of solids settling on the bottom. Sediment
in the water column or deposited on the bottom can also increase the oxygen demand on the water column
as the result of microbial respiration and chemical oxidation of compounds. The resulting reduced oxygen
levels (hypoxia) can cause lethal and sublethal effects on sedentary benthic invertebrate populations or lead
to the replacement of sensitive species by species more tolerant of reduced oxygen.

Fiber mats are a particular problem associated with pulping effluents (Owens, 1991; Thut and Schmiege,
1991). Decomposition of organic matter in the debris reduces dissolved oxygen levels in the water column
and may lead to anoxic conditions in the sediment with accompanying buildup of methane, hydrogen
sulfide, and other toxic gases. In the Gulf of Bothnia study off Sweden,  oxygen levels in the water
column were reduced nearest the effluent, particularly during the summer, with anoxia found in the fiber
mat as the result of increased bacterial biomass and activity (Owens, 1991).  Reduced levels of oxygen
may also complicate efforts to assess chemical toxicity.  Studies of fish indicated that decreased oxygen
led to increases in the toxicity of both organic and inorganic chemicals by about 1.5-fold, as a result of
the increased rate of flow across the gills  at reduced oxygen levels. The effect on lethal  and sublethal
toxicities  appeared  slight; however, this activity resulted in higher concentrations  of pollutants in the
vicinity of gill membranes and accompanying higher  diffusion of the toxics across the membrane (Rand
and Petrocelli, 1984).

Where effluent discharge rates are too low for color to inhibit photosynthesis or in  streams that are too
shallow for color to  significantly attenuate light, algae production can be greatly enhanced by the nutrients
contained in the effluent (Stockner and Costella, 1976). Orthophosphate, and particulate nitrogen and
phosphorus, the most prevalent nutrients in  pulp  mill effluents, have been shown to enhance algal
productivity at effluent concentrations in the receiving  stream of up to 25 percent (Walsh et al., 1982).
However, algal production begins to rapidly  decline at particulate nitrogen and  phosphorus  effluent
concentrations above 25 percent.

The principal sources of soluble BOD materials are the black liquor and  associated soluble materials from
the pulp washing, volatile organics from the condensate streams, and various additives (Poole et al., 1978).
A number of studies have investigated improvements  in microbial treatment of effluents to  reduce BOD,
COD, and AOX (e.g., Haggblom and Salkinoja-Salonen,  1991).   The proposed  secondary wastewater

                                              23

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treatment BPT controls should reduce levels of total suspended solids (TSS) released in pulp, paper, and
paperboard mill effluents by 110 million kg annually and provide improved aquatic habitat quality by
decreasing turbidity and sedimentation in receiving waters as well as by decreasing levels of toxic
chemicals that bind to the solids. Poole et al. (1978) noted that biological treatment may not be effective
in removing the substances that contribute to the color of the waste stream, although new developments
in reducing color would also reduce the total organic content of the effluent, with subsequent reduction
in BOD.  The proposed BMP for chemical oxygen demand (COD) and color effluent limitations will
control losses and discharges of pulping liquors and associated wood extractives to reduce aquatic impacts
from loadings of organic and wood extractive constituents.

3.2  Recreational Fisheries

Two studies conducted by EPA confirm the use of fish tissue as a good indicator of bioaccumulated
TCDD in aquatic ecosystems.  The National Dioxin Study, which began in 1983, found concentrations
of TCDD in fish tissue that range from below the detection limit of 1 pg TCDD/g wet weight of whole
organism to a maximum of 85 pg/g (USEPA, 1987). This study found the most frequent occurrences and
highest concentrations of TCDD in fish tissue in fish collected in the Great Lakes and downstream from
kraft paper mills. The National Study of Chemical Residues in Fish (NSCRF) sampled bottom-feeding
fish and game fish from 388 sites located nationwide (USEPA, 1992d). As a result of the National Dioxin
Study, the site locations for the NSCRF were biased toward areas where dioxins were likely to be found
(e.g., below the discharge of bleaching pulp and paper mills).   In fact, TCDD was detected in fish from
70 percent of the sites, with a maximum tissue concentration of 204 pg/g and an average concentration
of 6.8 pg/g.  TCDF was detected in fish from 89 percent of the sites, with a maximum concentration of
404 pg/g and an average concentration of 13.6 pg/g.

The habitat and physiology of aquatic organisms determine the exposure routes. Water acts as the medium
for the transport and partitioning of dioxins and furans between particulate organic matter, sediments, and
the biota (USEPA, 1993a).  Cook et al. (1990) reported that food ingestion contributed to 75 percent of
the total TCDD uptake in fish and that the uptake from water was considered negligible in the absence
of contaminated sediments. Laboratory exposure studies showed that when TCDD  was added to water
containing contaminated sediments, there was no observed increase in TCDD uptake (Cook et al.,  1990).
It was concluded that the ingestion of sediment and direct gill contact with suspended sediment were more
important in uptake rates than the direct uptake of freely dissolved TCDD via gill ventilation.

The physical and chemical degradation of dioxins and furans  occurs very slowly. Fish are exposed to
dioxins and furans through the ingestion of contaminated sediments and prey species associated with
sediments (USEPA, 1993a). Many species offish, such as minnows and suckers whose diets include large
quantities of detritus, readily  ingest sediment and/or suspended sediments.  Gizzard shad (Dorosomd
cepedianum) consume 20 percent of their wet weight in dry sediment daily and are capable of digesting
50 percent to 66 percent of the organic matter contained therein (Mundahl, 1991). The NSCRF found that
TCDD was found more commonly and at higher average concentrations in bottom-feeding species such
as carp (Cyprimis carpio) than in fish species that live higher in the water column (USEPA, 1992d).  The
concentrations reported in the NSCRF were not normalized for percent lipid concentration, and therefore
conclusions regarding the relationship between high tissue concentration and bottom-feeding fish have not
been validated.

Human exposure to waterborne pollutants usually occurs through the ingestion of contaminated drinking
water or fish tissue.  Because of the virtual insolubility and lipophilic nature of 2,3,7,8-TCDD and 2,3,7,8-

                                              24

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 TCDF, the primary exposure route for these pollutants is through the ingestion of contaminated fish tissue
 (USEPA, 1984).  Human health impacts resulting from the other pollutants in pulp and paper mill effluents
 are also  primarily  the  result of exposures through contaminated drinking water  and ingestion  of
 contaminated fish.  A variety of compounds  may  cause  toxic reactions, are suspected of producing
 abnormal reproductive function, or may be human carcinogens, such as chloroform, methylene chloride,
 chlorinated phenolics, and dioxins and furans.

 International investigations of the effects of dioxins and furans on humans have suggested that several
 unusual mechanisms are involved in the development of acute and chronic impacts resulting from exposure
 to these compounds.  Epidemiological studies suggest that dioxins are carcinogenic to humans through
 increased expression of oncogenes and/or decreases in the expression of tumor suppressor genes through
 the action of the aryl hydrocarbon (Ah) or dioxin receptors; by affecting the regulation of other steroid
 hormone and growth factor receptors, such as estrogen or epidermal growth factor receptors, to alter cell
 differentiation and proliferation; or by compromising immune surveillance and viral defense (Silbergeld,
 1991).  Further work on the noncarcinogenic effects  of dioxins indicates that reproductive function may
 be altered at low levels of exposure.

 The potential impacts  caused by the  ingestion of contaminated drinking water  are not  evaluated for this
 assessment because there are no municipal public water intakes within the same river  reach or 10 miles
 downstream from any pulp and paper mill effluent discharge (whichever was the greater distance). For
 these reasons, the population used to determine the potential impacts to human health  was based  on the
 portion of the population that  is involved in recreational and subsistence fishing.

 3.3 Fish Advisories

 Fish advisories and bans are the management tools used by state agencies to reduce the health risks  to
 recreational and subsistence anglers  that are associated  with eating contaminated fish. Fish advisories
 perform a dual function: (1) they inform the public of  the high levels of pollutants found to occur  in
 locally caught species, and (2) they  provide guidance as to the safe levels of consumption for various
 subgroups in the  population (e.g., children, adults, pregnant or nursing women).

 The two procedures currently available for developing fish consumption advisories are from the U.S. Food
 and Drug Administration (FDA) and EPA. The FDA is charged with regulating the risks to the general
 public from contaminants contained in fish that  are sold  in interstate commerce. The FDA action levels
 are designed to address national needs, and they are based on national consumption patterns.  Also, the
 FDA takes a risk management approach that considers the economic impact the action levels may have
 on the commercial fishing industry.  In contrast, the EPA approach is designed to provide states with a
 methodology that assesses the health risk to the state's recreational and subsistence anglers and allows the
 development of action levels based on the region-specific fishing habits of the groups at  risk. FDA action
 levels are much higher than EPA-derived action levels because of the FDA's national perspective. Action
 levels derived using the EPA risk assessment approach typically indicate a much higher risk associated
 with fish consumption because the scope is local, is concerned only with protecting  the health of the
 public, and does not give any consideration to economic  impacts. The availability of these two methods
 has led  to inconsistencies in action levels from state to state, which can be particularly confusing to
 anglers when waterbodies cross interstate boundaries.

From the 1960s through the 1980s, most state agencies used the FDA action levels  for setting their fish
advisories (Reinert et al., 1991). With the promulgation of the 1987 amendments to the Clean Water Act,

                                               25

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EPA developed water-quality-derived procedures based on risk assessment techniques. Some of the states
replaced their FDA action levels with those derived by using the EPA procedures. However, a 1989
survey (Table 3-6) showed that of the 37 states reporting to have waterbodies under some sort of fish or
shellfish consumption advisory, 34 states still derived some or all contaminant levels of concern from the
FDA action levels (Cunningham et al., 1990).  Thirty states acknowledged the use of or intent to use a
risk assessment methodology, and only 11 states based all of their advisories on risk assessments.

The disparity of state action levels is evident among the fish advisories for streams affected by pulp and
paper mills. Twenty-nine bleaching mills  discharge into receiving streams  that are presently under fish
advisories for dioxins (as of June 1993). These 29 mills are located in 15 states, for which there are  10
different action levels (Table 3-7).

Fish advisories provide the species offish that may contain the contaminants of concern, recommendations
regarding the amount of fish tissue that is safe to consume, and the population subgroups that may be at
risk. As of June 1993, 23 receiving streams of bleaching pulp and paper mills had fish advisories in place
for dioxins (Table 3-8).
                                              26

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   Table 3-6. Various Methodologies and Their Frequency of Use by States
             for Deriving Action Levels for Issuing Fish Advisories

,;'"\; -^-;;.v~r. "A>/;psieflbds\,;r' • '£ _r>,:,,:
Derive some or all contaminant levels of concern
from FDA action levels
Base all advisories on risk assessment
Base advisories on risk assessment only when FDA
action levels do not exist
Currently developing a risk assessment approach
Do not plan to use a risk assessment approach
Method unknown

, -, ~Nsbl>«ar'oi? Stites ': * - ~~
34
11
10
9
10
11
NOTES:   1.   Some states may use more than one method.
         2.   EPA's risk assessment guidelines were used as written or in modified form by 18 states;
             3 states used a state method independent of EPA's approach; 8 states used two or more
             risk assessment methods; 1 state did not specify which risk assessment method was used.
Source: Reinert et al., 1991.
                    Table 3-7.  State Action Levels for Dioxin
                        '"ri?*?;  .*
                        /State,
                                                    " Level
               Arkansas
               California

               Florida
               Louisiana
               Maine
               Maryland
               Michigan
               Minnesota
               Mississippi
               New Hampshire
               North Carolina
               Pennsylvania
               Texas
               Virginia
               Wisconsin
           0.007
Conducts site-specific risk
assessments
           0.009
           0.002
           0.0015
           0.0013
            0.01
          0.000032
           0.005
Sets advisories based on risk
           0.003
  25.00 (FDA action level)
           0.007
           0.003
            0.01
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Table 3-8. Receiving Streams of Bleaching Pulp and Paper Mills Under Dioxin Fish Advisories,
              the Advisory Type, and Species Whose Consumption Is Limited3
Receiving Stream
Blackwater River, VA
Houston Ship Channel, TX
Kennebec River, ME
Escatawpa River, MS
Ouachita River, AR
Escanaba River, MI
Androscoggin River, ME
Bayou La Fourche, LA
Red River, AR
Fenholloway River, FL
Codorus Creek, PA
Neches River, TX
Penobscot River, ME
St. Louis River, MN°
Androscoggin River, NH
Pacific Ocean, CA
Potomac River; N. Branch, MD
Leaf River, MS
Roanoke River, VA
Rainy River, MNC
Pigeon River, NC
Sacramento River, CA
Wisconsin River, WI
Advisory TypAe
NCGP
NCSP
RGP
NCSP, RGP
RGP
NCSP, RGP
NCGP
NCSP
RGP
NCGP
NCGP
RGP
NCGP
NCSP, RGP
NCSP
NCSP, RGP
NCGP
NCGP
NCGP
RGP
NCSP
NCGP, RGP
NCGP
NCGP
NCGP
- ~f'\ _, Fish Species Coveredjbf Advisory- ;
Bottom-feeding species
Catfish, blue crabs
All fish species
All fish and shellfish species
All fish species
All fish species
All fish species
All fish and shellfish species
Catfish fillet
All fish species
Green sunfish
All fish and shellfish species
All fish species
All fish species
All fish species
All fish and shellfish species
Bottom-feeding fish, channel catfish, bullhead
catfish
Bottom-feeding species (>22 in or >5 Ib)
All fish species, except herring, shad, and shellfish
All fish species
All fish species
All fish species
Carp, white bass
                                         28

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                                                 Table 3-8.  (Continued)



''Based on data contained in EPA's Fish Advisory Database as of June 1993.

 Codes that indicate the advisory type:

NCGP:  No consumption fish advisory or ban: Advises against consumption of fish or shellfish species by the general population.

NCSP:  No consumption fish advisory or ban for a subpopulation: Advises against consumption of fish or shellfish species by a subpopulation
        that could be at potentially greater risk (e.g., pregnant women, nursing mothers, or children).

RGP:   Restricted consumption fish advisory or ban: Advises restricted consumption (e.g., a limited number of meals or limited sizes of meals
        per unit time) of fish or shellfish species by the general population.

RSP:   Restricted consumption fish advisory or ban for a subpopulation: Advises restricted consumption (e.g., a limited number of meals or
        limited sizes of meals per unit time) offish or shellfish species by a subpopulation that could be at potentially greater risk (e.g., pregnant
        women, nursing mothers,  or children).

°Advisory also covers PCBs and mercury in the same fish species.

 Separate advisory in place for mercury covering same geographic area
                                                               29

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30

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                                     4. METHODOLOGY
This chapter summarizes the methodology used in the environmental assessment and risk assessment
conducted to estimate potential impacts on aquatic life and human health resulting from exposure to the
effluents of bleaching pulp and paper mills.  Potential impacts are evaluated on a site-specific basis for
each selected BAT option and for baseline conditions for four subcategories of the pulp, paper,.and
paperboard industry (dissolving kraft, bleached papergrade kraft/soda, papergrade sulfite, and dissolving
sulfite) in order to evaluate the environmental benefit of implementing BAT controls. Potential impacts
on aquatic life are evaluated by comparing modeled in-stream contaminant concentrations to EPA's aquatic
life water quality criteria.    Where water quality  criteria  have not been developed, other values
representative of the chemical's aquatic toxicity are used.  These values (criteria and other values) are
referred to in this document as aquatic life ambient water quality concentrations (aquatic life AWQCs).
Modeled in-stream concentrations  are compared to both acute AWQCs and  chronic  AWQCs when
available.  Potential  impacts on  human  health  are evaluated  by  (1) comparing  modeled in-stream
contaminant concentrations to health-based toxic effect values derived using standard EPA methodology
(referred to as human health ambient water quality concentrations, or health-based AWQCs); (2) estimating
potential carcinogenic risks and noncarcinogenic hazards due to the consumption of contaminated fish;
(3) estimating  the annual  incidence  of  cancer in the potentially exposed  angler population;  and
(4) estimating the number of existing  dioxin-related state fish advisories that will be lifted after the
implementation  of the selected BAT options.   Estimates  are  also made of the potential increase in
recreational angler participation due to the lifting of fish advisories as a result of implementation of
selected BAT options.

Exposure pathways evaluated in this assessment include ingestion of fish by recreational and subsistence
anglers and their households.  Exposure to contaminants through the water pathway is also evaluated by
the comparison of modeled in-stream contaminant concentrations to human health-based AWQCs for the
ingestion of water and organisms.   An  evaluation of the potential human carcinogenic risk and
noncarcinogenic hazards associated with the ingestion of drinking water is not included because there are
no municipal public water intakes within the same river reach or 10 miles downstream from any bleaching
pulp and paper mill effluent discharge  (whichever is the greater distance).

All 26 chemicals selected as chemicals of potential concern for which loadings have been provided by
EPA's Office of Science and Technology, Engineering and Analysis Division (BAD), are included in this
environmental assessment (memorandum from Doug Spengel, Radian Corporation, to Drew Zacherle, Tetra
Tech, Inc., June  7, 1993). However, the actual number of pollutants included  in each type of analysis
varies because of the availability of data related to pollutant characteristics (e.g., carcinogenicity, BCFs,
toxicity).

4.1   Estimating In-Stream Concentrations

Estimating in-stream contaminant concentrations for various flow conditions is the first step in evaluating
impacts on aquatic life and human health. Loadings data have been obtained from BAD in kilograms of
pollutant discharged per year for each chemical discharged from a facility under baseline conditions and
each selected BAT option. The loadings data are used to derive effluent concentrations for each chemical.
The effluent concentrations are derived by dividing the  loading by the  plant flow.  The in-stream
concentration is then calculated by multiplying the effluent concentration by the stream dilution factor,
i.e., plant flow/(plant flow + stream flow). Stream dilution factors are derived for three measures of low-

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 flow conditions of the stream at the mill effluent: 1Q10 flow (i.e., the lowest flow measured over a 10-
 year period), 7Q10 flow (i.e., the lowest 7-day average flow in a 10-year period), and harmonic mean flow
 (HMF) (USEPA,  1991c).  Site-specific 7Q10 flows and HMFs are obtained  for each of the mills, as
 reported in Risk Assessment for 2,3,7,8-TCDD and 2,3,7,8-TCDF Contaminated Receiving Waters from
 U.S. Chlorine-Bleaching Pulp and Paper Mills (USEPA, 1990a).  Site-specific 1Q10 flows are derived
 by  multiplying gage-specific  1Q10  flows measured  downstream  of mill effluents  by the  percent
 contribution of the gage flow associated with the site-specific stream (i.e., site-specific stream  flow/gage
 flow). Given the limited data available, the percent contribution of the gage flow is calculated by dividing
 the  mill-specific 7Q10 flow by the gage-measured 7Q10 flow.

 Surrogate flows are derived  for 17 mills that discharge to open waters (e.g.,  oceans, estuaries, lakes).
 These flows are calculated by using the following equation:
                                       F0  = (D • Fj- Fp
 where:
 F0  =  surrogate open water body flow;
 D   =  dilution factor (as provided by USEPA (1990a) and regional EPA personnel); and
 Fp  =  mill plant flow.

 A dilution factor for one mill is not available; therefore, a surrogate flow cannot be calculated.  Also,
 because no HMF flow is available for one mill, no human health risk estimates are calculated for that mill.
 Facility-specific effluent flows and receiving stream flows for all of the mills evaluated in this assessment
 are included as part of the CBI record.

 4.2  Estimating Impacts to Aquatic Life

 Aquatic life impacts are evaluated for 101 mills discharging to 68 receiving streams for the following 26
 pollutants:
     •   Acetone
     •   2-Butanone
     •   4-Chlorocatechol
     •   Chloroform
     •   4-Chlorophenol
     •   6-Chlorovanillin
     •   4,5-Dichlorocatechol
     •   2,4-Dichlorophenol
     •   2,6-Dichlorophenol
     •   2,6-Dichlorosyringaldehyde
     •   5,6-Dichlorovanillin
     •   Methylene chloride
     •   Pentachlorophenol
2,3,7,8-TCDD
2,3,7,8-TCDF
3,4,5,6-Tetrachlorocatechol
3,4,5,6-Tetrachloroguaiacol
2,3,4,6-Tetrachlorophenol
3,4,5-Trichlorocatechol
3,4,6-Trichlorocatechol
3,4,5-Trichloroguaiacol
3,4,6-Trichloroguaiacol
4,5,6-Trichloroguaiacol
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
3,4,5-Trichlorosyringol
Potential impacts on aquatic life are evaluated on a site-specific basis by comparing modeled in-stream
contaminant concentrations with aquatic life criteria and toxicity values (acute and chronic AWQCs) for
these 26 pollutants  (Table 3-1 and Attachment A-4).  The in-stream concentrations under 1Q10 flow
                                              32

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conditions are compared to  acute AWQCs for each chemical discharged from each mill under each
selected BAT option and baseline conditions. The in-stream concentrations under 7Q10 flow conditions
are compared to chronic AWQCs. Exceedances of AWQCs are quantified by dividing the modeled in-
stream concentrations for each flow condition by the respective AWQC for each chemical.

4.3  Estimating Impacts to Human Health

Potential impacts on human health are evaluated on a site-specific basis by (1) comparing estimated in-
stream contaminant concentrations to health-based AWQCs; (2) estimating the potential carcinogenic risk
and noncarcinogenic hazards from the consumption of contaminated fish tissue; (3) estimating the annual
incidence of cancer in the potentially exposed angler population; and (4) estimating the number of existing
dioxin-related state fish advisories that will potentially be lifted after the implementation of the selected
BAT options.  Estimates are also made of the potential increase in recreational angler participation due
to the lifting of fish advisories as a result of implementation of selected BAT options.

4.3.1    Comparison to AWQCs for the Protection of Human Health

For 100 mills that discharge into 68 receiving streams, the in-stream contaminant concentrations under
HMF conditions are compared to health-based AWQCs for ingestion of aquatic organisms (12 pollutants)
and ingestion of water and aquatic organisms  (13 pollutants)  (Table  3-1, Attachment A-4).  The
contaminants are listed below:
     Acetone
     2-Butanone
     Chloroform
     4-Chlorophenol
     2,4,-Dichlorophenol
     2,6-Dichlorophenol (water and organisms
     only)
Methylene chloride
Pentachlorophenol
2,3,7,8-TCDD
2,3,7,8-TCDF
2,3,4,6-Tetrachlorophenol
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
The HMF concentration, which is more reflective of average in-stream concentrations, is used for this
assessment because health-based AWQCs are derived for lifetime exposure conditions rather than for
subchronic or acute conditions.  Exceedances of health-based AWQCs are quantified by dividing the
predicted in-stream concentration under HMF conditions by the health-based AWQC for each chemical
discharged from each facility under each selected BAT option and baseline conditions.

4.3.2    Estimation of Carcinogenic Risks and Noncarcinogenic Hazards

Potential impacts on human health are also evaluated by estimating potential carcinogenic risks and
noncarcinogenic hazards.  This assessment, conducted in accordance with available EPA guidance
including Risk Assessment Guidance for Superfund (USEPA, 1989a) and Assessing Human Health Risk
from Chemically Contaminated Fish and Shellfish: A Guidance Manual (USEPA, 1989b), is performed
for the following contaminants:
                                               33

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           Systemic Pollutants with Reference Doses

    Acetone                  Pentachlorophenol
    2-Butanone               2,3,7,8-TCDD
    Chloroform               2,3,7,8-TCDF
    4-Chlorophenol            2,3,4,6-Tetrachlorophenol
    2,4-Dichlorophenol        2,4,5-Trichlorophenol
    Methylene chloride
  Carcinogens
Chloroform
Methylene chloride
Pentachlorophenol
2,3,7,8-TCDD
2,3,7,8-TCDF
2,4,6-Trichlorophenol
As outlined in EPA guidance, the technical approach for conducting a risk assessment involves a three-step
process:

(1)  Toxicity Assessment  An attempt was made to obtain human health toxic effect values for the 26
     contaminants of potential concern using EPA data sources  such as IRIS  (USEPA, 1992a) and
     HEAST (USEPA, 1992b). Based on the list of chemicals of potential concern, only 11 of the total
     number of chemicals have available reference dose values (RfDs) and 6 have cancer slope factors
     (ql*s)(Table 3-3 and Attachment A-3.).

(2)  Exposure Assessment.   The exposure assessment involves identifying exposure pathways of
     concern, estimating exposure point concentrations, and estimating chronic daily intakes.

     •   Identifying Exposure Pathways of  Concern.   Water-related exposure pathways and target
         populations are identified as part of this step.  Pathways quantitatively evaluated include only
         ingestion of fish by  recreational  and subsistence anglers.   Potential  risks  associated with
         ingestion of drinking water were to be evaluated only for mills upstream and within the same
         reach or within 10 miles of a municipal public water intake. None of the mills evaluated for
         this assessment meet these criteria, however, and therefore potential exposure, cancer risk, and
         noncarcinogenic hazards associated with ingestion of drinking water are not evaluated.

     •   Estimating  Exposure Point Concentrations. The exposure point concentration (EPC) is the
         average concentration contacted over the duration of the exposure period.  For the fish ingestion
         pathway, fish tissue EPCs are calculated using two separate approaches.  In the first approach,
         EPCs are calculated by multiplying the contaminant-specific BCF (Table 3-3) by the estimated
         in-stream concentration under HMF conditions for 11 systemic pollutants and  6 carcinogens
         using a simple dilution calculation. The second approach, which involves the use of the Dioxin
         Reassessment  Evaluation  (DRE)  Model  developed by EPA's Office of Research and
         Development (still under EPA review) (USEPA, 1993c), is applicable only for estimating EPCs
         for 2,3,7,8-TCDD and 2,3,7,8-TCDF. Rather than using an in-stream contaminant concentration
         and the above water-based BCF, the DRE model estimates fish tissue concentrations of dioxin
         and furan by calculating the equilibrium between the contaminants in  fish  tissue and those
         adsorbed to the organic fraction of sediments suspended in the water column. The in-stream
         concentration under HMF conditions is used to estimate exposure point concentrations because
         the exposure pathways evaluated represent lifetime exposure conditions rather  than subchronic
         or acute conditions.

     *    Estimating Chronic Daily Intakes.  Chronic daily intakes (GDIs) are estimated using exposure
         models presented in EPA guidance (USEPA, 1989a, 1989b) for each chemical discharged from
         a facility under each regulatory alternative and baseline conditions. GDIs are expressed in terms
                                             34

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         of milligrams of contaminant contacted per kilogram of body weight per day (i.e., mg/kg/day).
         The GDI is calculated by combining the EPC and exposure parameter estimates (e.g., ingestion
         rate,  exposure frequency, exposure duration, body weight, averaging time) using a chemical
         intake equation. GDIs are estimated for evaluating both carcinogenic risks (based on a lifetime
         average daily dose) and noncarcinogenic hazards (based on an average daily dose during the
         exposure period).   GDIs  are  estimated for both  baseline conditions  and estimated future
         conditions assuming implementation of various selected BAT options.
         The equation and exposure parameter values used to estimate GDIs for ingestion of fish
         presented below:
                                                                          are
                        GDI =
         where:

         GDI =
         EPC =
         BCF =
         CF,  =
         CF2  =
         CF3  =
         IR   =
         EF
         ED

         BW
         AT
                                               (BW)(AT)
Chronic daily intake (mg/kg/day);
Exposure point concentration (in-stream concentration under HMF conditions) (ug/L);
Bioconcentration factor (unitless);
Conversion factor (103 mg/g);
Conversion factor (L/kg);
Conversion factor (10~9 kg/ug); and
Ingestion rate.  At this time no site-specific fish ingestion studies are available for
quantifying ingestion patterns in the vicinity of specific mill effluents.  Therefore,
several studies were compiled to assess  average ingestion rates for recreational and
subsistence angler populations. For recreational anglers an ingestion rate of 25 g/day,
which represents the midpoint of the reported range of average ingestion rates for
recreational anglers of approximately 20 to 30 g/day (Connelly et al., 1990; Pierce
et al., 1981; West et al., 1989) is used. For subsistence anglers an average daily
ingestion rate of 145 g/day, which assumes that an individual eats one average-size
fish meal per day,  is used.  The ingestion rate for subsistence anglers is also
supported by a study conducted by Pao  et al. (1982).
Exposure frequency (365 days/year)  (USEPA 1989a, 1989b);
Exposure duration (30 years for recreational anglers  and 70 years for subsistence
anglers) (USEPA 1989a, 1991a);
Body weight (70 kg) (USEPA 1989a, 1991a); and
Averaging time (70 years x 365 days/year for carcinogens  and  30 years [for
recreational anglers] or  70  years [for  subsistence anglers] x 365  days/year for
noncarcinogens).
(3)    Risk  Characterization.  Carcinogenic  risks and noncarcinogenic hazards are estimated for
      chemicals with available toxicity criteria for the pathways quantitatively evaluated in this study.

4.3.2.1  Potential Carcinogenic Risks.  The potential carcinogenic risks associated with the discharges
of 100 mills and 6 pollutants are expressed as an increased probability of developing cancer over a lifetime
(i.e., excess individual lifetime cancer risk) (USEPA, 1989a). Carcinogenic risks are quantified using the
equation below:
                                               35

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                                    Cancer riskt  = CDIi * SFi
 where:

 Cancer riskj    =   The potential carcinogenic risk associated with exposure to chemical i (unitless);
 CDIj           =   Chronic daily intake for chemical i (mg/kg/day); and
 SFj            =   Slope factor for chemical / (mg/kg/day)"1.

 If the carcinogenic risk  exceeds 10"2, then EPA  guidance (USEPA,  1989a)  recommends using the
 following equation to estimate carcinogenic risk:
 where:

 Cancer risk;
 CDIj
 SF,
                                  Cancer risk, =  1  - e(-CDI> * SFi)
=   Increased carcinogenic risk associated with exposure to chemical i (unitless);
=   Chronic daily intake for chemical i (mg/kg/day); and
=   Slope factor for chemical / (mg/kg/day)"1.
 Chemical-specific cancer risks are summed in accordance with EPA guidance (USEPA, 1989a) in order
 to quantify the combined cancer risk associated with exposure to a chemical mixture. The total potential
 carcinogenic risk is estimated for each exposure pathway, for each facility, and for each selected BAT
 option and baseline conditions.

 4.3.2.2 Potential Noncarcinogenic Hazards. Noncarcinogenic hazards are evaluated for 100 mills and
 11  systemic human toxicants by comparing the estimated dose (i.e., GDI) with a reference dose (RfD)
 (Table 3-3). The hazard quotient, which is used to quantify the potential for an adverse noncarcinogenic
 effect to occur, is calculated using the following equation:

                                                  GDI,
where:
       =  Hazard quotient for chemical i (unitless);
       =  Chronic daily intake for chemical i (mg/kg/day); and
       =  Reference dose for chemical i (mg/kg/day).

If the hazard quotient exceeds unity (i.e., 1), then an adverse health effect may occur.  The higher the
hazard quotient, the more likely that an adverse noncarcinogenic effect will occur as a result of exposure
to the chemical. If the estimated hazard quotient is less than unity, then an adverse noncarcinogenic effect
is highly unlikely to occur.

EPA recommends summing chemical-specific hazard quotients for contaminants with similar endpoints
to evaluate the combined noncarcinogenic hazard from exposure to a chemical mixture (USEPA, 1989a).
The sum  of the chemical-specific hazard quotients is  called the hazard index.  Using this approach
assumes that chemical-specific noncarcinogenic hazards are additive.  Limited data are available for
actually quantifying  the potential synergistic and/or antagonistic relationships between chemicals  in a

                                              36

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 chemical mixture.  For this assessment, only the hazard quotients  that had similar target organs and
 lexicological mechanisms that may result in the effect were summed (i.e., 2,3,7,8-TCDD and 2,3,7,8-
 TCDF).

 Estimation of Increased Incidence of Cancer.  In addition to estimating the potential carcinogenic risk
 associated with consuming contaminated fish tissue, an attempt is made to estimate the increased annual
 incidence of cancer that would occur at the estimated risk levels. For the purpose of this assessment, the
 potentially exposed population is considered to be a fraction of the recreational and  subsistence anglers
 that reside in the vicinity of the discharge and thus might be expected to use the receiving stream for their
 recreational and subsistence fishing activities. Estimates of the number of recreational and subsistence
 anglers potentially exposed are based on site-specific recreational fishing license data and creel survey data
 for several receiving streams for chlorine bleaching pulp and paper mills.

 The number of recreational fishing licenses sold in counties bordering the river reaches where each
 discharge occurs was  obtained  from state fishery officials.  For the purpose of this assessment, it is
 assumed that 95 percent of these licenses were  sold to recreational anglers and 5 percent were sold to
 subsistence anglers.  Actual  creel survey data (Attachment A-5) from eight receiving streams with
 bleaching pulp and paper mills are used to estimate the fraction of the total number  of licensed anglers
 who reside in the  vicinity of a discharge and who actually use the particular receiving stream for their
 recreational and subsistence fishing activities (Attachment A-6). The estimated number of anglers using
 the stream based on creel survey data is compared to the total number of licensed  anglers in counties
 surrounding the reach where the discharge occurs.   The resulting ratio represents  an estimate of the
 fraction of all licensed anglers in the area who fish on the receiving stream.  These ratios range from 0.69
 to 0.005.   The average of these ratios (0.29) is used to extrapolate for all of the mills  the number of
 licensed anglers who actually fish on the receiving stream in question by multiplying  the total number of
 licensed anglers in counties bordering the receiving stream by 0.29.

 For receiving streams with fish  advisories in place, it is  assumed that many recreational anglers would
 adhere to the advisory and not use the stream in question.  However, based on the existing literature, it
 is assumed that most anglers are unaware of fish advisories or continue to use receiving streams for their
 fishing  activities in spite of the presence  of fish  advisories.

 Only a limited number of studies that examine angler behavior in response to fish consumption advisories
 are available. In general, these studies have produced relatively similar results, finding a significant (but
 not complete) level of awareness  of advisories by  anglers and  some degree  of behavioral  change.
 However, the results do not substantiate an assumption that most recreational anglers would stop eating
 contaminated fish  altogether.  Studies conducted by  Silverman (1990) and Knuth and Velicer (1990)
 indicate that approximately 54 to 90 percent of all anglers are aware of state fish advisories in place on
 receiving streams where they fish.  These studies indicate that between 10 and 31  percent of anglers who
 are aware of fish advisories either change their fishing location or participation in fishing activities as a
 result of the fish advisories.  The remainder of those anglers aware of the fish advisories continue to fish
 and either change their consumption habits or change their preparation methods.  The studies by Knuth
and Velicer (1990) also found that there was confusion as to which waters were considered contaminated
 (37 percent of anglers actually fishing in  contaminated waters said they were fishing  in uncontaminated
waters), and other studies indicate that fewer anglers are aware of fish advisories than those found in
studies conducted by Silverman (1990) and Knuth and Velicer (1990). For example, Belton et al. (1986)
found that as few as 50 percent  of anglers in New York  and New Jersey were aware of fish advisories
in place on receiving streams where they fish.
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 For the purpose of this environmental assessment, a conservative estimate of a 20 percent decrease in
 fishing activity due to the presence of a fish advisory is assumed based on the changes in fishing location
 and participation reported in the literature (Silverman, 1990; Knuth and Velicer, 1990).  The actual number
 of anglers still fishing on receiving streams with fish advisories in place is  calculated  by multiplying the
 total number of licensed anglers in counties bordering the receiving stream reach by 0.95 (i.e., percent of
 total licensed anglers considered  to be recreational anglers), then multiplying the result by 0.29 (i.e.,
 percent of recreational anglers estimated to actually use the receiving stream in question for their fishing
 activities) and by 0.80 (i.e., percent of anglers who continue to use a receiving stream for their fishing
 activities in spite of the presence of a fish advisory). It is assumed that fish advisories do not change the
 fishing habits of subsistence anglers.

 In addition  to the anglers themselves, it is assumed that families of anglers would also be exposed to
 contaminated fish. Therefore, for each mill, the estimated number of recreational and subsistence anglers
 are each multiplied by 2.63, the size of the average U.S. household as determined by the 1990 census
 (U.S. Census Bureau, 1992), to estimate the  size of the total potentially exposed population.  The total
 number of potentially exposed recreational and subsistence anglers and their family members for each mill
 is then multiplied by  the estimated increased  individual lifetime cancer risk for each mill. These values
 are then divided by 70 (i.e., approximate number of years in a lifetime) to estimate the annual increased
 incidence of cancer in recreational and subsistence anglers  and their families.

 Comparison with State Action Levels. Twenty-three fish advisories for dioxins were  in place as of June
 1993 on stream segments located downstream of 29  bleaching pulp and paper mills  (including 2 open
 ocean locations in close proximity to pulp mill outfalls).  For this assessment, modeled fish tissue (fillet)
 levels of 2,3,7,8-TCDD and 2,3,7,8-TCDF in  the receiving stream are compared to the state action levels
 (Table 3-7) to estimate whether the selected BAT options by themselves are sufficient to eliminate the fish
 advisories.  Fish tissue concentrations are estimated  using  two separate approaches.   First, fish tissue
 concentrations are calculated by multiplying the estimated in-stream concentrations (expressed as 2,3,7,8-
 TCDD  and  2,3,7,8-TCDF toxicity equivalents)  under HMF  conditions  by  the  chemical-specific
 bioconcentration factor (BCF = 50,000 for 2,3,7,8-TCDD  and 8,000 for 2,3,7,8-TCDF).  Fish tissue
 concentrations are also estimated using ORD's Dioxin Reassessment Evaluation Model, as described
 previously.   Exceedances of state action levels are quantified by  dividing the  estimated fish tissue
 concentration by the state action level for each selected BAT option.  Because it is not the purpose of this
 assessment to determine the validity of the current fish advisories, baseline conditions are not evaluated.

 Two states, in which four dioxin/furan-related fish advisories are in place, do not have specific state
 threshold values for initiating fish advisories.  One of these states currently issues fish advisories when
 the potential increased individual cancer risk  associated with the consumption of fish tissue reaches 10"6
 (a daily consumption rate of 6.5 g/day is assumed).  The  one advisory examined for this assessment,
 however, was set based on a potential increased individual cancer risk of 10"5. The second state has fish
 advisories in place for rivers as well as ocean waters. Fish advisories issued for rivers are based on the
 results of site-specific risk assessments.  Risk assessments are not performed for fish advisories issued in
 ocean waters; instead, generic advisories are issued by the state.  In addition, receiving stream flow data
 are unavailable for one of the receiving streams.  Therefore, threshold exceedance comparisons can be
 conducted for only 24 of the 29 mills.  The advisory issued in the one state that was based on a 10"5 risk
 level is affected by only one facility and is evaluated based on estimated individual cancer risk. Therefore,
 the total number of facilities examined in this assessment is  25.  These 25 mills are assumed to have an
impact on the fish advisories on 20 receiving streams.
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 For those fish advisories  affected by discharges from more than one facility, no attempt is made to
 estimate the cumulative effect of the combined discharges.  Instead, each faculty is evaluated separately
 to determine whether the fish advisory threshold limits would be exceeded under selected BAT options.

 The potential increase in recreational angler participation due to the lifting of fish advisories as a result
 of implementation of the selected BAT options  is also estimated.  This estimate is based on the total
 number of licensed recreational  anglers (TLRA) used in the cancer risk assessment for mills with
 advisories.   The analysis estimates the  increase in recreational angler participation by comparing the
 potential TLRA after the lifting of the advisories with the estimated TLRA with the advisories in place.
 The risk assessment assumes that the fishing habits of recreational anglers are affected by fish advisories,
 whereas the habits of subsistence  anglers remain unchanged.

 As mentioned previously, the potential lifting of the existing advisories is projected by comparing modeled
 fish tissue concentrations for the selected BAT options (using the two approaches described above) to the
 state-specific advisory action levels or the cancer risk level (one state).  The  total number of licensed
 anglers in counties bordering the fish advisory location is first multiplied by 0.95 to estimate the number
 of licensed recreational (as opposed to subsistence) anglers in these counties. This product is multiplied
 by the ratio representing an estimate of the fraction of all licensed recreational anglers who  actually fish
 on the receiving stream in  question. As mentioned previously, this ratio is 0.29.  For receiving streams
 with fish advisories, this product is then  multiplied by 0.80 (the estimated percent of recreational anglers
 who continue to use a receiving stream in spite of the presence of a fish advisory). If it is estimated that
 after implementation of selected BAT options the fish advisory could be lifted,  the 0.80 multiplier is not
 used, thereby increasing the potential recreational angler participation on that particular receiving  stream
 segment by 20 percent. The result represents the estimated number of recreational  anglers using the
 receiving streams for their fishing activities when advisories are in place and after they are lifted.
The equations used for this analysis are:
       TLRA with advisory = total licensed anglers (TLA) * 0.95 * 0.29 * 0.80

       TLRA without advisory = total licensed anglers (TLA) * 0.95 * 0.29

Three  of the  receiving streams that currently have dioxin-related  fish advisories in place also have
advisories in place in the same locations for other contaminants: two have advisories in place for mercury
and PCBs, and the third has an advisory in place for mercury. These contaminants are not being regulated
by the proposed pulp, paper, and paperboard rule.  As a result, even if the dioxin-related advisories are
lifted as a result of BAT implementation, advisories for the other contaminants of concern will remain in
place.  The populations of recreational anglers fishing these streams, therefore, are assumed not to change
as a result of the lifting of the dioxin-related advisories.
                                               39

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40

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                                          5. RESULTS
5.1  Aquatic Life Impact Assessment

The aquatic  life-related benefits analyzed for this environmental assessment include the reduction of
exceedances  of contaminant-specific aquatic life water quality criteria or toxicity concentrations for the
protection of aquatic life (aquatic life AWQCs). The aquatic life assessments involve comparing mill-
specific modeled in-stream contaminant concentrations to both acute and chronic aquatic life AWQCs for
101 bleaching mills (Table 5-1). Twenty-four pollutants are analyzed for acute impacts, and 26 pollutants
are analyzed for chronic impacts under baseline conditions and selected BAT options.  Detailed results
(including all evaluated options) are provided in Attachments A-8 through A-l 1.  Mill-specific results are
considered confidential business information (CBI) and are part of the CBI record.

Two mills in the bleached papergrade kraft/soda subcategory are projected to exceed the acute aquatic life
AWQCs for  pentachlorophenol under baseline conditions (Table 5-1). After the implementation of the
selected BAT options, however, no acute AWQCs are projected to be exceeded.

At baseline  conditions the chronic aquatic life AWQCs are  projected to be exceeded at 28  mills
(Table 5-1) for the following 9 chlorinated organics:
       4-Chlorocatechol
       Pentachlorophenol
       2,3,7,8-TCDD
       2,3,7,8-TCDF
       3,4,5,6-Tetrachloroguaiacol
                         3,4,5-Trichloroguaiacol
                         4,5,6-Trichloroguaiacol
                         2,4,5-Trichlorophenol
                         2,4,6-Trichlorophenol
Not all of the 28 bleaching mills that exceed aquatic life AWQCs exceed them for all 9 contaminants.
Excluding one mill in the bleached papergrade kraft/soda subcategory that exceeds the chronic AWQC
for 2,3,7,8-TCDD,  the implementation of the selected options for the dissolving kraft and bleached
papergrade kraft/soda subcategories eliminates chronic AWQC exceedances.  There  are no projected
     Table 5-1. Estimated Number of Pollutants and Mills Exceeding Aquatic Life AWQCs
                               DK
     PK
                                                DS
                      PS
                                                                DK
                                      PK
                                                                                 DS
                                                                                           PS
           Baseline
                                        1(2)
                             3(1)
                       9(27)
      Selected BAT Option
      0
0
                                      KD
                                  0
  Total Number of Pollutants and
    Mills (in parenthesis) with
         Exceedances
    Baseline = 1(2)
Selected BAT Options = 0
                        Baseline = 9(28)
                   Selected BAT Options = 1(1)
                                               41

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exceedances of aquatic life AWQs for facilities in the dessolving sulfite subcategory under baseline or
under the selected BAT option conditions.

The selected BAT option for the papergrade sulfite subcategory is totally chlorine-free processes. The
implementation of such processes  is  assumed to completely  eliminate the formation of chlorinated
organics, as well as to eliminate all of the projected aquatic life impacts at baseline conditions.

5.2   Human Health Impact Assessment

Impacts to human health are evaluated using site-specific analyses for baseline conditions and for the
conditions that are estimated to be achieved with the implementation of the selected BAT options.  Human
health benefits are quantified by (1) comparing estimated in-stream concentrations to health-based water
quality toxic effect values  (referred to in this document as health-based AWQCs),  (2) estimating the
potential reduction of carcinogenic risk and noncarcinogenic hazards from the consumption of fish tissue;
(3) estimating the annual incidence  of cancer in the potentially exposed angler population;  and
(4) estimating the number of existing dioxin-related state fish advisories that could potentially be lifted
after the implementation of the selected BAT  options.  Also estimated is the potential increase in
recreational angler participation due to the lifting of fish advisories as a result of the implementation of
the selected BAT options. Detailed results (including all evaluated options) are provided in Attachments
A-12 through  A-26.  Mill-specific results are confidential and are provided in the CBI record.

5.2.1 Comparison with AWQCs for the Protection of Human Health

The water quality-related benefits analyzed for the environmental assessment include the reduction in the
number of exceedances of human health-based water quality toxic effect concentrations (health-based
AWQCs) for the protection of human health.  Mill-specific modeled in-stream contaminant concentrations
are compared to  AWQCs  derived  for the protection of human  health from (1) ingestion of  aquatic
organisms and (2) ingestion of water and aquatic organisms for baseline conditions and under selected
BAT options (Table 5-2). Detailed results are provided in Attachments A-12 through A-14.  Mill-specific
results are confidential and are provided in the CBI record.

Modeled receiving water concentrations for 97 of a total of 100 mills are projected to exceed AWQCs for
human health for both organisms and water and organisms at baseline conditions for 5 and 8 pollutants,
respectively (Table 5-2).  The AWQCs for protection from the ingestion of contaminated organisms only
are exceeded for the following five contaminants:

     •  Chloroform
     •  Pentachlorophenol
     •  2,3,7,8-TCDD
     •  2,3,7,8-TCDF
     •  2,4,6-Trichlorophenol

However, not  all 97 mills exceed the AWQCs for all 5 contaminants (Attachment A-12).

The selected BAT totally chlorine-free process  change option for the  papergrade sulfite subcategory
eliminates all projected baseline health-based AWQC exceedances for the ingestion of organisms. The
selected BAT options are also projected to reduce the number of mills with exceedances in the dissolving
                                               42

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     Table 5-2.  Estimated Number of Pollutants and Mills Exceeding Health-Based AWQCs
BAT Process Change Options •
Baseline
Selected BAT Option
Total Number of Pollutants and
Mills (in parenthesis) with
Exceedances
Number of Pollutants and Mills (in parenthesis) with Projected AWQC Exceedances -
Human Health {Organisms)
DK "
3(3)
2(2)
PK
5(80)
2(71)
DS
2(5)
2(5)
PS
2(9)
0
Baseline = 5(97)
Selected BAT options = 2(78)
Human Health (Water and Organisms) :
DK""
7(3)
3(2)
PK
8(80)
4(71)
'DS -'
4(5)
4(5)
- JPS'"
4(9)
0
Baseline = 8(97)
Selected BAT Options = 5(78)
kraft, bleached papergrade kraft/soda, and dissolving sulfite subcategories to 78 and the number of
contaminants with projected exceedances to 2: 2,3,7,8-TCDD and 2,3,7,8-TCDF.

Three additional pollutants, for a total of eight, are projected to exceed the health-based AWQCs for
protection from the ingestion of contaminated water and organisms under baseline conditions:

     •  Chloroform
     •  4-Chlorophenol
     •  2,6-Dichlorophenol
     •  Methylene chloride
     •  Pentachlorophenol
     •  2,3,7,8-TCDD
     •  2,3,7,8-TCDF
     •  2,4,6-Trichlorophenol

However, not all mills exceed the AWQCs for all eight contaminants (Attachment A-12).

All projected baseline exceedances  for the papergrade sulfite  subcategory  are eliminated with the
implementation of the selected totally chlorine-free BAT option. The selected BAT options also reduce
the number of mills exceeding AWQCs in the  dissolving kraft,  bleached papergrade kraft/soda, and
dissolving sulfite subcategories at baseline to 78 and the number of contaminants to 5:

     •  Chloroform (DS mills only)
     •  2,6-Dichlorophenol (PK mills only)
     •  Pentachlorophenol
     •  2,3,7,8-TCDD
     •  2,3,7,8-TCDF

Not. all the mills exceed the AWQCs for ingestion of water and organisms for all five contaminants
(Attachment A-12).
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 5.2.2  Potential Carcinogenic Risk

 As outlined in Chapter 4 (Methodology), two approaches are used to determine 2,3,7,8-TCDD and 2,3,7,8-
 TCDF concentrations in fish tissue  and the potential increased cancer risk  associated with these
 contaminants for 100 mills. Only the simple dilution approach is used to estimate fish tissue concentration
 and  potential  increased cancer risk associated with four other probable carcinogens (i.e., chloroform,
 methylene chloride, pentachlorophenol, and 2,4,6-trichlorophenol).  Using the simple dilution approach,
 it is estimated that 2,3,7,8-TCDD and 2,3,7,8-TCDF contribute more than 99 percent of the cancer risk
 (Attachment A-23).

 The simple dilution approach is a conservative methodology that assumes that all carcinogenic pollutants
 discharged to a receiving stream, including the dioxins and furans, are available to the biota, particularly
 fish.  The Dioxin Reassessment  Evaluation (DRE) Model approach,  developed by EPA's Office  of
 Research and Development (still under EPA review), assumes that the bioavailability of dioxins and furans
 is dependent on the  levels of suspended solids in the discharge and the receiving  stream and  the
 partitioning of contaminants between the sediment and fish tissue.  The DRE approach is applicable for
 evaluating 2,3,7,8-TCDD and 2,3,7,8-TCDF only; therefore,  the other four contaminants  are evaluated
 using the simple dilution approach. Because of the use of two models, the results are presented as a
 range, with the DRE model representing the lower end of the risk and the simple dilution approach
 representing the upper end.

The  subcategory-specific results,  including both the projected individual cancer risks and the projected
 number of individual annual cancer cases for recreational  and subsistence anglers under baseline and
selected BAT  option conditions,  are summarized for the DRE approach and simple dilution approach
 (Tables 5-3 and 5-4, respectively).  Detailed results are provided  in Attachments A-17 through A-20.
Mill-specific results are confidential and are provided in the CBI record.
 Table 5-3.  Average Individual Lifetime Cancer Risk and Annual Increased Incidence of Cancer
             for Recreational and Subsistence Anglers at Baseline and Selected BAT
                              Estimated Using the DRE Approach
Proofs*
Change
Option
Baseline
Selected
BAT
Option

Potential Increased Average Individual Cancer Risk Over a Lifetime :

Recreational Anglers
DK
1.5E-03
3.7E-05
PK
I.8E-04
1.7E-05
DS
1.2E-04
9.3E-5
Baseline avg (4 subcategorics) =
Combined BAT avg for DK,
DS = 2.2E-05
" ~ . <-,-

PS
3.3E-OS
0
2.0E-04
PK,and
*•? - " . """"„-„
- Subsisteace Aagle*sL/«;v
, DK
1.9E-02
5.0E-04
PK -
2.4E-03
2.2E-04
[Potential Increased Incidence of Cancer in Ejjwstd:'
. " <• '•-""< Population ~,f,~I, """'
-.J'ReereMon^jiiigtBrs <•„
""DS ps
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 Table 5-4.  Average Individual Lifetime Cancer Risk and Annual Increased Incidence of Cancer
              for Recreational and Subsistence Anglers at Baseline and Selected BAT
                          Estimated Using the Simple Dilution Approach
  Baseline
         7.3E-03
                8.8E-04
                       4.9E-04
                              8.2E-OS
                                     8.6E-02
                                             1.1E-02
                                                   6.6E-03
                                                          UE-03
                                                                  0.7
                                                                      19.28
                                                                            0.53
                                                                                0.18
                                                                                    0.55
                                                                                         15.73
                                                                                              0.38
                                                                                                   0.14
  Selected
   BAT
  Option
         3.4E-04
                6.7E-05
                       3.6E-04
                                     4.5E-03
                                            9.1E-04
                                                   4.8E-03
                                                                 0.04
                                                                      0.91
                                                                            0.5
                                                                                    0.03
                                                                                          0.70
                                                                                              0.35
         Baseline avg (4 subcategories) = 9.4E-04
          Combined BAT avg for DK, PK, and
                 DS = 9.2E-05
Baseline avg (4 subcategories) = 1.2E-02
Combined BAT avg for DK, PK, and DS
          = 1.2E-03
 Baseline total = 20.69
Total at selected BAT =
       1.45
 Baseline total = 16.80
Total at selected BAT =
       1.08
 Increased Cancer Cases Per Year for Recreational and Subsistence Anglers at Baseline Conditions
 and After Proposed BAT Process Changes, and the Number of Cancer Cases Eliminated After the
               Proposed BAT Process Change Options Are in Place
                             Recreational and Subsistence Anglers Baseline Total =
                                             37.49
                             Recreational and Subsistence Anglers BAT Total = 2.53
                                Cancer Cases Eliminated for Recreational and
                                     Subsistence Anglers = 34.96
5.2.2.1  DRE Model.  Using the DRE model, projected increased average individual cancer risk for
recreational anglers at baseline conditions ranges from 10~3 (dissolving kraft) to 10~5 (papergrade sulfite)
and the average recreational angler risk for all four bleaching subcategories under baseline conditions is
estimated to be at the 10"4 level (Table 5-3).  The projected baseline cancer risk associated with the
bleaching mills in the papergrade sulfite subcategory is eliminated with the implementation of the totally
chlorine-free selected BAT option.  Under the selected BAT options, the average combined risk for mills
in the dissolving kraft, bleached papergrade kraft/soda, and dissolving  sulfite subcategories is reduced to
a level of 10~5. The total increased annual incidence of cancer cases in the recreational angler population
across the four bleaching subcategories at baseline conditions is estimated to be 3.20. This total is reduced
to 0.47  after the selected BAT options are in place.

For the  subsistence angler population, using the DRE approach the estimated increased average individual
cancer risk at baseline conditions ranges from 10"2 (dissolving kraft) to 10"  (papergrade sulfite) and the
average risk level is estimated to be 10~3 for the four bleaching subcategories. The selected totally chlorine
free BAT option eliminates the risk for the papergrade sulfite mills, and the estimated combined risk for
the dissolving kraft, bleached papergrade kraft/soda, and dissolving sulfite mills is reduced to a level of
10"4.  The  total increased annual incidence of cancer in the subsistence angler population  for all four
subcategories is estimated to be 2.67 under baseline conditions, and it is reduced to 0.36 after  the selected
BAT options are in place.  For the combined recreational and subsistence angler population,  the selected
BAT options  are projected to eliminate about five cancer cases per year.

5.2.2.2  Simple Dilution Model.  Using the simple dilution approach, the average estimated increased
individual baseline cancer risk for all four subcategories for recreational anglers is at the  10"4 level (Table
5-4),  and the estimated risk ranges from 10~3 (dissolving kraft) to 10"5 (papergrade sulfite). The selected
BAT options  are projected to reduce the combined risk for dissolving kraft, bleached papergrade kraft/
soda, and dissolving sulfite mills to a level of 10"5 and completely eliminate the risk associated with mills
in the  papergrade sulfite subcategory.   The estimated total annual incidence of cancer across all
                                                  45

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 subcategories for recreational anglers is reduced from 20.69 at baseline to 1.45 after selected BAT option
 implementation.

 The estimated increased individual average cancer risk to subsistence anglers under baseline conditions
 ranges from 10'2 (dissolving kraft and bleached papergrade kraft/soda)  to 10'3 (dissolving sulfite and
 papergrade sulfite) and averages 10'2 for the four bleaching subcategories. After selected BAT option
 implementation, the combined estimated cancer risk for dissolving kraft, bleached papergrade kraft/soda,
 and dissolving sulfite mills is reduced to the 10'3 level.  The totally chlorine-free BAT option proposed
 for the papergrade sulfite subcategory completely eliminates the estimated baseline cancer risk for this
 subcategory.  The projected total increased annual incidence of cancer cases for subsistence anglers is
 reduced from a four-subcategory total of 16.80 at baseline to 1.08 after the implementation of the selected
 BAT options.  For the combined recreational and subsistence angler population, implementation of the
 selected BAT options is estimated to eliminate about 35 cancer cases per year.

 A comparison of the two approaches used in this assessment indicates that the number of cancer cases per
 year estimated by the simple dilution approach is higher than that estimated by the ORE model.   The
 simple dilution model  estimates total cancer cases per year for  all four subcategories and  exposed
 populations to be 37.49 at baseline conditions and 2.53 after selected BAT option implementation.  In
 comparison, the DRE model predicts a baseline value of 5.87 cancer cases per year and a reduction to 0.83
 after selected  BAT  option  implementation.   Combining the  results of both modeling approaches,
 implementation of the selected BAT options is estimated to eliminate about 5 to 35 cancer cases per year.

 5.2.3  Potential Noncarcinogenic Hazard

 The potential noncancer hazard associated with the discharge of 11 systemic toxicants from 100 bleaching
 pulp and paper mills are also evaluated for  recreational and subsistence angler populations.  This hazard
 is estimated by using the simple dilution approach and the DRE model approach to estimate concentrations
 of 2,3,7,8-TCDD and 2,3,7,8-TCDF in fish tissue and to determine the number of mills and contaminants
 for which the RfDs are exceeded.  Nine other systemic pollutants  of concern are also included in the
 simple dilution analysis:
        Acetone
        2-Butanone
        Chloroform
        4-Chlorophenol
        2,4-Dichlorophenol
Methylene chloride
Pentachlorophenol
2,3,4,6-Tetrachlorophenol
2,4,5-Trichlorophenol
The subcategory-specific results for the DRE and simple dilution models for baseline and selected BAT
options are summarized below (Table 5-5). Detailed results are provided in Attachments A-21 through
A-26.  Mill-specific results are confidential and are provided in the CBI record.

5.2.3.1 DRE Model.  The estimated number of mills exceeding the 2,3,7,8-TCDD and 2,3,7,8-TCDF RfDs
for recreational  anglers for the  4 bleaching  subcategories is reduced from  34 mills  under baseline
conditions to 7 (an 79,percent reduction) after the implementation of the selected BAT options (Table 5-5).
The selected BAT totally chlorine-free  option for papergrade sulfite mills  results in the complete
elimination of baseline exceedances for two mills.  Of the seven mills projected to exceed RfDs after the
implementation of the selected BAT options, one is a dissolving kraft mill, four are bleached papergrade
kraft/soda mills, and  two are dissolving sulfite mills.
                                              46

-------
         Table 5-5.  Number of Pollutants and Mills (in Parenthesis) Exceeding RfDs for
                   Recreational and Subsistence Angler Populations Estimated Using
                             the Simple Dilution and DRE Approaches
•3. - Sr;
• Proce$i'€£atttge :
>-~';OjjScm ' y,'j
Baseline
Selected BAT
Option
Total Number of
Mills with
Exceedances
"- '^'"'l','^ -t'~~\ -^uj^fof?^^^^ '„• ,^F:,; ;;;,
..£• s-2l* a" -^^atwijilA^eeS _*, ^ggi '•£?.' t.
"•P'.-'xr 'O^l-; -''-'-',-,? -""«'
/,-DK"-
2(1)
1(1)
' **?
2(29)
1(4)
£&&<';-
2(2)
1(2)
"PS;
2(2)
0
Baseline = 34
Selected BAT Options = 7
% Reduction = 79
„ P7 SSwpte'Dnuteyy?; ':<;°
i-DST
2(1)
1(0
"•Pfe
3(54)
1(17)
'o&,~.
2(5)
1(4)
-'^
1(4)
0
Baseline = 64
Selected BAT Options = 22
% Reduction = 66
'-^4/Mfei''"'" „; ', .^jrSMbstsleoee Aijgijf^" j,;txs^^.t?'A*r _,'^^c,
^Sf£:s,i»E^l,:a:;;
"ksc-
2(2)
KD
iC-w
2(57)
2(17)
t$&
2(5)
2(4)
§Pt;
2(4)
0
Baseline = 68
Selected BAT Options = 22
% Reduction = 68
•t'/ -.Simpe'-DaiitioV ,,3K'
syjNsC'
2(2)
2(2)
>?$£',
4(70)
2(45)
1 J>S,'l'
2(5)
2(5)
«BS -
2(7)
0
Baseline = 84
Selected BAT Options = 52
% Reduction = 38
For subsistence anglers, the estimated number of mills exceeding 2,3,7,8-TCDD and 2,3,7,8-TCDF RfDs
for the 4 bleaching subcategories using the DRE approach is reduced from 68 at baseline conditions to
22 (a 68 percent reduction) after the implementation of the selected BAT options.  The selected BAT
totally chlorine-free option for papergrade sulfite mills results in the complete elimination of baseline
exceedances for four mills.  Of the estimated 22 mills exceeding RfDs after the implementation of the
selected BAT options, 1 is a dissolving kraft mill, 17 are bleached papergrade kraft/soda mills, and four
are dissolving sulfite mills.

5.2.3.2 Simple Dilution Model.  Using the simple dilution approach, the estimated number of mills
exceeding RfDs for recreational anglers for the 4 bleaching subcategories is reduced from 64 mills under
baseline conditions to 22 (a 66 percent reduction) after the implementation of the selected BAT options
(Table 5-5). The proposed BAT totally chlorine-free option for papergrade sulfite mills results in the
complete elimination of baseline exceedances for four mills. Of the estimated 22 mills exceeding RfDs
after the implementation of the selected BAT options, 1  is  a dissolving kraft mill, 17 are bleached
papergrade kraft/soda mills, and four are dissolving sulfite mills.

For subsistence anglers, the estimated number of mills exceeding RfDs for the 4 bleaching subcategories
using the simple dilution approach is reduced from 84 at baseline conditions to 52 (a 38 percent reduction)
after implementation of the selected BAT options. The selected BAT totally chlorine-free option for
papergrade sulfite mills results in the complete elimination of baseline exceedances for seven mills. Of
the estimated 52 mills exceeding RfDs after the implementation of the selected BAT process change
options, 2 are dissolving kraft  mills, 45 are bleached papergrade kraft/soda mills, and five are dissolving
sulfite mills.

Greater than 99 percent of the noncancer hazard estimated using the simple dilution approach can be
attributed to  2,3,7,8-TCDD and 2,3,7,8-TCDF (Attachment A-23).  Only two bleached papergrade
kraft/soda mills exceed the RfD for 2,4,5-trichlorophenol, and four bleached papergrade kraft/soda mills
exceed the RfD for 4-chlorophenol under baseline conditions.  All post-BAT exceedances are limited to
2,3,7,8-TCDD and 2,3,7,8-TCDF.

A comparison of the two modeling approaches used in the analyses indicates that the DRE model predicts
greater reductions in RfD exceedances  overall.  The  estimated reduction in noncarcinogenic hazard
                                               47

-------
 exceedances for subsistence anglers is much larger using the DRE model: 68 percent using the DRE model
 versus 38 percent using the simple dilution model.  For recreational anglers, the DRE model estimates the
 reduction of noncancer hazard exceedances to be 79 percent as opposed to 66 percent estimated using the
 simple dilution approach.

 5.2.3.3     Number of Anglers Potentially  Exposed.  The  estimated number of people potentially
 exposed  to  contaminant  levels  exceeding RfDs  (Table  5-6)  is based  on the  total  number of
 recreational/subsistence anglers and their family members who reside in counties bordering river reaches
 into which bleaching mills discharge and for which exposure to fish tissue contaminant levels is predicted
 to result in exceedances of RfDs for contaminants of concern. The total population exposed for each mill
 is the same as that used to estimate the potential increased incidence of cancer. However, only those
 populations  potentially exposed to  contaminants from mills for which RfDs are exceeded  are counted.
 It should be noted that this method results in an  estimate that exceeds the actual number of people
 expected  to incur a noncancer effect.  It  reflects only the estimated number of people exposed to
 contaminant levels that exceed RfDs. Using the DRE approach, there is a predicted 59.2 percent reduction
 in the size of the population exposed to contaminant levels exceeding RfDs under selected BAT options
 as compared to baseline conditions. There is a predicted 68.1 percent reduction using the simple dilution
 approach.

 5.2.4 Impacts of BAT Controls on Dioxin-Related Fish Advisories

 As of June 1993 a total of 23 receiving streams (including open water bodies) into which 29 bleaching
 mills discharge had dioxin-related fish advisories in place.  With the exception  of one dissolving kraft
 facility  and  one papergrade sulfite facility, these mills are all in the  bleached papergrade  kraft/soda
 subcategory.  The impact of the selected BAT controls on these advisories is projected by comparing
 modeled dioxin and furan fish tissue concentrations estimated for the selected BAT options (using the two
 modeling approaches described in Section 4) to state advisory action levels or state-specific risk levels (as
 appropriate) (Table 5-7).

The comparison of estimated fish tissue concentrations to state advisory action level is performed on 19
 fish advisories related to bleaching pulp and paper mill facilities for selected BAT discharge levels only.
The comparison of estimated fish tissue concentrations to state advisory action levels cannot be done for
three receiving streams because they are located in states where risk-based advisories are issued based on
site-specific determination, not state action levels. However, the risk level used to issue one of the four

     Table 5-6. Populations Potentially Exposed to Noncarcinogenic Hazards Under Baseline
              Conditions and After Implementation of the  Selected BAT Options,
                   Estimated Using the Simple Dilution and DRE Approaches

Baseline
Selected BAT Options
Percent reduction
DRE * ~ iT.. ,„, „
Recreational
Angler
511,488
210,387
„ Subsistence
-Angler «
51,363
19,534
."-Total
562,851
229,921
59.2%
" "" V:; „-„ lSfi»p>,t»i»«0o r—\-i>vP'"
" RecreaU<3na3
. < An$*ir.<
964,547
288,646
>SuW&0Tisr-
-A%ter x<
63,994
39,477
•f< ^c ' •/:*
'^^R*I£F>< "
1,028,541
328,123
68.1%
                                              48

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  Table 5-7.  Number of Receiving Streams That Would Exceed State Fish Advisory Threshold
            Limits Under Various BAT Options Estimated Using the Simple Dilution
                                      and DRE Approaches
it£ Process Change Options '';.
Existing Advisories
Analyzed
Exceedances under Selected
BAT Option
Advisories Potentially
Eliminated at Selected BAT
• ;: ; 0RE • "\;
20
1
19
°:JSunple Dilation" < '-
20
6
14
advisories is known to be 10~5; therefore, this risk level is compared to the cancer risk estimated for that
particular mill.  In addition,  receiving stream flow data are unavailable for one receiving stream and
therefore in-stream contaminant concentrations cannot be calculated.  The total number of advisories
evaluated is 20.  These advisories are affected by discharges from 25 mills.

Implementation of the selected BAT options is projected to eliminate 19 dioxin-related fish advisories
using the DRE modeling approach and 14 advisories using the simple dilution approach (Table 5-7 and
Attachments 15 and 16).

There are limitations regarding fish advisories and the estimated reduction of advisories expected as a
result of the implementation of the selected BAT options.  Estimated fish tissue concentrations after BAT
option implementation assume that the mills are the exclusive source of dioxins and furans; other potential
sources are not  considered.  In addition,  although the  discharge of dioxins and furans may  cease,
contaminated sediments  may continue to be a long-term source of contamination to  the biota that live in
or on the sediment or that feed on sediments, as well as to those organisms which feed on contaminated
biota. Actual determinations of continued fish tissue contamination must be made on a site-specific basis.

For those fish advisories  affected  by discharges from more than  one facility,  no attempt is made to
estimate the cumulative  effect of the combined discharges.  Rather, each facility is  evaluated separately
to determine whether the fish advisory threshold limits would be exceeded under proposed BAT limits.

An estimate is also made of the increase in recreational angler  participation due to the lifting of dioxin-
related fish advisories after the implementation of the selected  BAT options.  As mentioned previously,
of the 20 fish advisories evaluated, 19 are predicted to be lifted under selected BAT options using the
DRE approach and 14 are predicted to be lifted using the simple dilution approach.  However, using the
DRE approach, two of the receiving streams for which dioxin-related fish advisories are projected to be
lifted after BAT implementation will still have advisories in place for other contaminants (mercury and/or
PCBs).  Using the simple dilution approach,  one receiving stream  for which  the dioxin-related fish
advisory is projected to be lifted after BAT implementation will still have a nondioxin-related advisory
in place.

Based on the number of receiving streams that are projected to have dioxin-related fish advisories lifted
after BAT implementation and for which no other advisories for other contaminants are in place (i.e. 17
                                               49

-------
advisories using the DRE approach and 13 advisories using the simple dilution approach), using the DRE
approach it is estimated that the number of recreational anglers using receiving streams that currently have
dioxin-related fish advisories in place may increase by 26,795 anglers (from an estimated 135,630 under
baseline conditions to 162,425 under BAT conditions) as a result of the lifting of fish advisories on the
receiving  streams in question; the simple  dilution approach  predicts that the  recreational angler
participation may increase by  25,759 anglers (from an estimated 135,630 under baseline conditions to
161,389 under BAT conditions (Attachment 7).
                                               50

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                          6.  LIMITATIONS AND UNCERTAINTIES
6.1 Limitations

The  methodologies used for the  water  quality and environmental assessments are subject to certain
limitations and uncertainties.  Some of the problems encountered in the analyses resulted from lack of
available data or lack of research to evaluate methodological assumptions.

For example, because a dilution factor is missing for one mill that discharges to an open water body, a
surrogate flow cannot be calculated. In addition, 1Q10 flow data  are not available for five mills and
therefore 7Q10 flows are used to estimate acute aquatic life risks for those mills.  No human health risk
estimates are calculated for the mill lacking HMF flow data.  Neither potential risks to aquatic life nor
potential risks to  human health  are evaluated for one  mill because contaminant loadings  data are
unavailable.

Every effort was made to use methods and approaches that EPA considers to be standard practice. Certain
assumptions may still be required, however, for the evaluation of combined noncarcinogenic hazards from
exposure to a chemical  mixture.  EPA recommends summing chemical-specific hazard quotients  to obtain
a hazard index (USEPA, 1989a).  Using this  approach assumes that chemical-specific noncarcinogenic
hazards are additive. Limited data are available for actually quantifying the potential synergistic and/or
antagonistic relationships between chemicals in a chemical mixture.   Other areas of uncertainty are
inherently associated with the risk assessment process (USEPA,  1989a, 1989b) but will not be discussed
here. Key uncertainties identified during the environmental assessment are discussed below.

6.2  Uncertainties Associated With Risk Estimates

Several uncertainties specific to  this study  notably  affect the results  of the dioxin  and furan risk
assessment.    Ninety-nine percent of the estimated carcinogenic  risks and  noncarcinogenic hazards
calculated in this study can be attributed to 2,3,7,8-TCDD and 2,3,7,8-TCDF. Therefore, the assumptions
and  methods used to analyze the dioxin  and furan data will affect the interpretation of the results of the
regulatory impact  analysis and comparisons.  Areas of uncertainty  relative to  the dioxin and furan risk
assessment include:

     •  Bioconcentration factors used in the risk assessment;

     •  Use  of  one-half  the EPA-designated detection  limit to  estimate  loadings for all nondetect
        congeners for each selected BAT option and to develop pollutant discharge levels;

     •  Aquatic  life toxic effect values, cancer slope factors (ql*), reference doses (RfDs), and toxic
        equivalency factors (TEFs), which are currently under review by EPA, used in the risk assessment.

The bioconcentration factor (BCF) of 50,000 used in these calculations for 2,3,7,8-TCDD is based on a
measured value  from laboratory research on rainbow  trout, a pelagic freshwater species having a lipid
content of approximately 7 percent (Cook et al., 1991). A higher BCF may be more appropriate for fish
with a higher lipid content. Bioconcentration factors for 2,3,7,8-TCDD may be estimated on the basis of
the ratio of 10,000 per 1 percent lipid  when the total amount  of  the chemical in water is considered
(telephone conversation between P.M. Cook, USEPA, Duluth, MN, and Esther Peters, Tetra Tech, Inc.,
                                               51

-------
 February 17, 1993). The BCF of 8,000 used for 2,3,7,8-TCDF was based on the following rationale:
 relative BCFs measured by Merhle et al. (1988) for TCDD (39,000) and TCDF (6,049) for the same
 lowest exposure concentration of TCDD where fish were least affected, in the same species of fish, yield
 a ratio of 6.45. Dividing 50,000 by 6.45 yields 7,752, which rounds to 8,000.

 BCF values are dependent on the characteristics of individual chemicals. Bioconcentration is a partitioning
 process between the lipids of the organisms and the surrounding water, and is based on the amount of
 freely dissolved chemical available to fish through bioconcentration across the gills. BCFs, however, may
 be affected not only by variations in lipid content of different fish species but also by age of the fish;
 exposure level; how the concentration of the compound in water is measured (freely dissolved or total
 chemical); low bioavailability (the dioxins are highly hydrophobic); dissolved organic carbon content of
 the water (the higher the organic carbon content, the lower the bioavailability of hydrophobic chemicals);
 organic carbon in sediments; slow uptake rates; migration patterns of fish; and other factors that may lead
 to measured BCFs lower than those predicted.

 EPA recommends that BCF  values calculated from the log P-log BCF relationship be used in the
 calculation of reference tissue and ambient concentrations (USEPA, 1991b).  However, the report also
 notes that methods for calculating BCF values do not include metabolism, which will reduce the BCF.
 Thus, calculated BCFs will be conservative, and measured values may be necessary to obtain more precise
 values for chemicals that are metabolized. Furthermore, uptake of strongly hydrophobic compounds such
 as dioxins and furans will also be governed by bioaccumulation,  the net uptake of the chemical from
 exposure to food and sediments as well as water.  Because of these factors, many of the TCDD/TCDF
 congeners do not bioaccumulate in fish (Cook et al.,  1991).

 The simple dilution approach used in this analysis assumes that using the loadings for dioxins and furans
 and mill-specific dilution  factors allows estimation of an  appropriate  water concentration for these
 chemicals and permits the use of BCFs. However, this approach ignores the complexity of the interactions
 of these highly hydrophobic chemicals with sediment organic carbon and suspended particulates in the
 effluent, resulting in reduced bioavailability, losses to sediments through sorption and deposition, and
 losses from volatilization and photolysis reactions.  Thus the simple dilution approach oversimplifies the
 processes involved in the uptake of contaminants by fish.

 A number of  studies  are  currently under way to  assess alternative  measures of the potential for
 accumulation of dioxins and furans in fish (bioaccumulation factors, bioavailability indices, biota-to-
 sediment accumulation factors, regulatory bioaccumulation multipliers) based on water column and bottom
 sediment concentrations that can be used in the absence of site-specific measurements (e.g., Sherman et
 al., 1992; USEPA, 1993a).  Therefore, the new model developed by EPA's Office of Research  and
Development (which is  still under EPA review) is also used in this  assessment to calculate fish tissue
concentration by calculating the equilibrium between dioxin in fish tissue and dioxin adsorbed to the
organic fraction of  sediments  suspended  in the water column.   The  use of the biota-to-sediment
accumulation factor (BSAF) should predict more consistently the bioaccumulation  potential of these
chemicals, although some assumptions are still necessary (USEPA, 1993a). The BSAF is calculated based
on the following equation:

                                        BSAF =   "
                                              52

-------
where:

     BSAF =  biota-to-sediment accumulation factor (unitless)
     Cupid   =  concentration of contaminant in lipid of fish (mg/kg)
     C,,,.    =  concentration of contaminant in bottom sediment organic carbon (mg/kg)

The BSAF used for 2,3,7,8,-TCDD in this assessment was 0.09, which was based on the BSAF estimated
for lake trout in Lake Ontario.  A biota suspended solids accumulation factor (BSSAF) is similar to a
BSAF except that the organic carbon normalized concentration is that of suspended solids rather than
bottom sediments.  EPA has stated that there are currently no data available for assignment of BSSAFs
(USEPA, 1993a).  However, using data from Lake Ontario, EPA estimates that the BSSAF would be 0.3
for lake trout, which is three-fold higher than the BSAF estimated for lake trout in Lake Ontario (i.e.,
0.09).  EPA, however, suggests the use  of available BSAFs as a lower bound for BSSAFs (USEPA,
1993a).  Therefore, for this assessment, the BSSAF for 2,3,7,8-TCDD is assumed to be the same as the
BSAF.

The loadings values for 2,3,7,8-TCDD and 2,3,7,8-TCDF used in this analysis included one-half detection
limit values for those contaminants which were not  detected in the effluent.  As shown in the simple
dilution results, 2,3,7,7-TCDD and 2,3,7,8-TCDF contributed the vast majority of the total carcinogenic
risk for all the selected BAT options.  A significant portion of this risk is associated with the use of one-
half the EPA-designated detection limit for these congeners.  A recent report by Loftus et al. (1992) noted
that the level of detection of the method used is important in the usefulness of the results for assessment
of human risk.

EPA is currently reassessing the human health risk associated with exposure to dioxin.  The dioxin slope
factor and reference doses, as well as the TEF approach, used in this assessment are based on previously
published values and do not represent the results of the dioxin reassessment, which are currently being
developed.

The estimated reduction in fish consumption advisories resulting from process change implementation
determined in this study assumes that the pulp and paper mill effluents are the only source of 2,3,7,8-
TCDD and 2,3,7,8-TCDF.  Furthermore, although the discharge of these compounds may cease or be
minimized, sediment contamination may continue for years, with pollutants continuing to accumulate in
organisms.  Site-specific monitoring may be required to determine actual fish tissue concentrations and
to assess the appropriateness of fish consumption advisories following process changes.

An additional area of uncertainty involves the estimates of populations exposed to contaminated fish tissue.
For the purpose of this study, angler population estimates  were based on data extrapolated from the
number of fishing licenses sold in counties bordering receiving stream reaches and creel survey data. The
actual number of people using these receiving streams for their fishing activities is not known.  In
addition, the number of recreational anglers who change their fishing habits as a result  of a fish advisory
is based on a few studies with relatively few data.
                                              53

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54

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                                     7.  REFERENCES
Adams, W.J., G.M. DeGraeve, T.D. Sabourin, J.D. Cooney, and G.M. Mosher.  1986.  To deity and
   bioconcentration of 2,3,7,8-TCDD to fathead minnows (Pimephalespromelas).  Chemosphen  5:1503-
   1511.

Andersson, T., L. Forlin, J. Hardig, and A. Larsson. 1988.  Physiological disturbances in fish living in
   coastal water polluted with bleached kraft pulp mill effluents. Can. J. Fish. Aquat. Sci. 45:1525-1536.

Belton, T., R. Roundy, and N. Weinstein.  1986.  Urban fishermen: Managing the risks of toxic exposure.
   Environment, 28(9): 19-37

Broman, D., C. Naf, C. Rolff, Y. Zebiihr, B. Fry, and J. Hobbie.  1992. Using ratios of stable nitrogen
   isotopes to estimate bioaccumulation  and flux of polychlorinated dibenzo-p-dioxins  (PCDDs) and
   dibenzofurans (PCDFs) in two food chains from the northern baltic. Environ.  Toxicol. Chem. 11:331-
   345.

Carey, J.H., P.V. Hodson, K.R. Munkittrick, and M.R. Servos. 1993. Recent Canadian  studies on the
   physiological effects of pulp mill effluent on fish. Environment Canada, Fisheries and Oceans.

Connelly, N.A., T.L. Brown, and B.A. Knuth.  1990.  New York statewide angler survey. 1988. Prepared
   for the New York State Department of Environmental Conservation, Albany, NY. April.

Cook, P.M., A.R. Batterman, B.C.  Butterworth, K.S. Lodge, and S.W. Kohlbry.  1990. Laboratory study
   of TCDD bioaccumulation by lake trout from Lake Ontario sediments, food chain, and  water. In Lake
   Ontario TCDD bioaccumulation study - final report. Ch. 6. U.S. Environmental Protection Agency,
   Region 2, New York.

Cook, P.M., D.W. Kuehl, M.K. Walker, and R.E. Peterson. 1991. Bioaccumulation and toxicity of TCDD
   and related compounds in aquatic  ecosystems.  In Banbury Report 35: Biological  basis for risk
   assessment of dioxins  and related compounds, ed. M.A. Gallo, RJ. Sheuplein, and K.A. Van Der
   Heijden, pp. 143-167. Cold Spring Harbor Laboratory Press, Plainview, NY.

Cooper, K.  1989. Effects of polychlorinated dibenzo-p-dioxins  and  polychlorinated dibenzofurans on
   aquatic organisms. CRC Crit. Rev. Aquat Sci. l(2):227-242.

Cunningham, P.A., J.M. McCarthy, and D. Zeitlin.  1990. Results of the 1989 census of state fish/shellfish
   consumption advisory programs.  Research Triangle Institute Report.  Research Triangle Park, NC.
   August.

Gilbertson, M.  1989. Effects on fish and wildlife populations.  In Halogenated biphenyls, terphenyls,
   napthalenes, dibenzodioxins and related products, ed. R. Kimbrough and  A.A. Jensen, pp. 103-127.
   Elsevier, New York.

Haggblom, M., and M. Salkinoja-Salonen. 1991. Biodegradability of chlorinated organic compounds in
   pulp bleaching effluents.  Water Sci. Tech. 24:161-170.
                                              55

-------
 Hart, C.W. Jr., and S.L.H. Fuller.  1974. Pollution ecology of freshwater invertebrates.  Academic Press,
    Inc., New York.

 Hart, C.W. Jr., and S.L.H. Fuller. 1979. Pollution ecology ofestuarine invertebrates.  Academic Press,
    Inc., New York.

 Hawkes,  C.L., and L.A. Noras.   1977.  Chronic oral toxicity of 2,3,7,8-tetrachlorodibenzo-p-dioxin
    (TCDD) to  rainbow trout.  Trans. Am. Fish. Soc. 106:641-645.

 Kleeman, J.M., J.R. Olsen, and R.E. Peterson.  1988.  Species differences in 2,3,7,8-tetrachlorodibenzo-p-
    dioxin toxicity and biotransformation in fish.  Fund. Appl. Toxicol. 10:206-213.

 Knuth, B.A., and C.M. Velicer. 1990.  Receiver-centered risk communication for sport fisheries: Lessons
    from New York licensed anglers. Paper presented at the American Fisheries Society Annual Meeting,
    Pittsburgh, PA, August.

 Loftus, M.L.,  L.M.  Barraj, and J.R. Tomerlin.  1992. Effect  of  the limit  of detection on exposure
    assessment.  J. AOAC Intern. 75(5):911-915.

 McMaster, M.E., G.J. Van Der Kraak, C.B. Portt, K.R. Munkittrick, P.K. Sibley, I.R. Smith, and D.G.
    Dixon.  1991.  Changes in hepatic mixed-function oxygenase (MFO) activity, plasma steroid levels and
    age of maturity of a white sucker (Catastomus commersoni) population exposed to bleached kraft mill
    effluent Aquat. Toxicol. 21:199-218.

 Mehrle, P.M., D.R. Buckler, E.E. Little, L.M.  Smith, J.D. Petty, P.H. Peterman, D.L. Stalling, G.M. De
    Graeve,  JJ.  Coyle,  and W.J.  Adams.  1988.  Toxicity   and  bioconcentration of  2,3,7,8-
    tetrachlorodibenzodioxin and 2,3,7,8-tetrachlorodibenzofuran in rainbow trout.  Environ. Toxicol. Chem.
    7:47-62.

 Miller, R.A., L.A. Norris, and B.R. Loper. 1979.  The response of coho salmon and guppies to 2,3,7,8-
    tetrachlorodibenzo-p-dioxin (TCDD) in water.  Trans. Am. Fish. Soc.  108:401^07.

 Mundahl, N.D.  1991. Sediment processing by gizzard shad, Dorosoma cepedianum, in Acton Lake, Ohio,
    U.S.A. /. Fish Biol. 38:565-572.

 Neuman, E., and P. Karas.  1988. Effects of pulp mill effluent on a Baltic coastal fish community.  Water
   Sci. Technol 20(2):95-106.

 Owens, J.W. 1991. The hazard assessment of pulp and paper effluents in the  aquatic  environment: A
   review. Environ. Toxicol. Chem. 10:1511-1540.

 Pao, E.M., K.H. Fleming, P.M. Guenther, and SJ.  Mickle. 1982.  Foods commonly eaten by individuals:
   Amount per day and per eating occasion. Home Economics Research Report No. 44. U.S. Department
   of Agriculture, Hyattsville, MD.

Pierce, R.S., D.T. Noviello, and S.H.  Rogers. 1981. Commencement Bay seafood consumption study.
   Preliminary report. Tacoma-Pierce County Health Department, Tacoma, WA.
                                              56

-------
Poole, N.J., D.J. Wildish, and D.D. Kristmanson. 1978.  The effects of the pulp and paper industry on
   the aquatic environment.  CRC Crit. Rev. Environ. Control 8:153-195.

Rabert, W.S.  1990. An update on the environmental effects ofTCDD and TCDF releases from pulp and
   paper mills on aquatic and terrestrial animals. U.S. Environmental Protection Agency, Office of Toxic
   Substances,  Health   and  Environmental  Review  Division,   Environmental  Effects  Branch,
   Washington, DC.  June.

Rand, G.M., and S.R. Petrocelli.  1984. Fundamentals of aquatic toxicology. Hemisphere Publishing
   Company, New York. 666 p.

Reinert, R.E., B.A. Knuth, M.A. Kamrin, and Q.J. Stober. 1991. Risk assessment, risk management, and
   fish consumption advisories in the United States.  Fisheries 16(6):5-12.

Sherman,  W.R., R.E. Keenan,  and D.G. Gunster.    1992.  A re-evaluation of bioconcentration and
   bioaccumulation factors for regulatory purposes.  J. Toxicol. Environ. Health 37:211-229.

Silbergeld, E.K.  1991. Carcinogenicity of dioxins.  J. Nat. Cancer Inst. 83(17):! 198-1199.

Silverman, W.M. 1990.  Michigan's sport fish consumption advisory:  A study in risk communication.
   M.S. thesis, University of Michigan, 103 pp.

Spitsbergen, J.M., J.M. Kleeman, and R.E. Peterson.  1988. 2,3,7,8-tetrachlorodibenzo-p-dioxm toxicity
   in yellow perch (Perca flavescens). J. Toxicol. Environ. Health 23:359-383.

Spitsbergen, J.M., K.A.  Schat, J.M.  Kleeman, and  R.E.  Peterson.   1986.   Interactions of 2,3,7,8-
   tetrachlorodibenzo-p-dioxin (TCDD) with  immune responses  of rainbow trout.  Vet.  Immunol.
   Immunopathol. 12:263-280.

Stockner, J.G., and A.C. Costella. 1976. Marine phytoplankton growth in high concentrations of pulpmill
   effluent. Journ. Fish. Res. Bd. Can. 33:2758-2765.

Thomann, R.V.  1989.  Bioaccumulation model of organic chemical distribution in aquatic food chains.
   Environ. Sci.  Technol. 23(6):699-707.

Thut, R.N., and D.C. Schmiege. 1991.  Processing  mills.  In Influences of forest  and rangeland
   management on salmonid fishes and their habitats. Amer. Fish. Soc. Spec. Publ. 19:369-387.

U.S. Census Bureau.  1992.  U.S. 1990 Census Data. U.S. Census Bureau Public Relations Office,
   personal communication.

USEPA. 1984. Ambient water quality criteria for 2,3,7,8-tetrachlorodibenzo-p-dioxin. U.S. Environmental
   Protection Agency, Office of Water Regulations and Standards, Washington, DC.

USEPA.  1987.  The national dioxin study.  U.S. Environmental Protection Agency, Office of Water
   Regulations and Standards.  Washington, DC.
                                              57

-------
 USEPA.  1988.  USEPA/paper industry cooperative dioxin screening study ("Five Mill Study").  EPA-
   440/1-88-025. U.S. Environmental Protection Agency, Office of Water Regulations and Standards.
   Washington, DC.  March.

 USEPA.  1989a. Risk assessment guidance for Superfund.  Volume I:  Human health evaluation manual
   (PanA). Interim final. OSWER Directive 9285.7-Ola. U.S. Environmental Protection Agency, Office
   of Solid Waste and Emergency Response, Washington, DC. December.

 USEPA.  1989b. Assessing human health risk from chemically contaminated fish and shellfish:  A
   guidance manual  EPA-503/8-89-002.  U.S. Environmental Protection Agency, Office of Water
   Regulations and Standards, Washington, DC. September.

 USEPA.  1990a. Risk assessment for 2,3,7,8-TCDD and 2,3,7,8-TCDF contaminated receiving waters
   from U.S. chlorine-bleaching pulp and paper mills.  U.S. Environmental Protection Agency, Office of
   Water Regulations and Standards, Washington, DC. August.

 USEPA. 1990b. Summary of technologies for the control and reduction of chlorinated organicsfrom the
   bleached chemical pulping subcategories of the pulp and paper industry. U.S. Environmental Protection
   Agency, Office of Water Regulations and Standards,  Office of Water Enforcement and Permits,
   Washington, DC.  April.

 USEPA. 1990c. Integrated risk assessment for dioxins and furans from chlorine bleaching in pulp and
   paper mills.  U.S.  Environmental Protection Agency,  Office of Pesticides and Toxic Substances,
   Washington, DC. July.

 USEPA.  1990d.  ("The 104 Mill Study"):  Statistical findings and analyses.  U.S. Environmental
   Protection Agency,  Office of Water Regulations and Standards, Washington, DC. July.

 USEPA.  1991a.  Human health evaluation manual, supplemental guidance: "Standard default exposure
   factors." OSWER Directive 9285.6-03. U.S. Environmental Protection Agency, Office of Solid Waste
   and Emergency Response, Washington, DC. March.

 USEPA.  199 Ib. Assessment and control of bioconcentratable contaminants in surface waters. Draft.
   U.S. Environmental Protection Agency, Office  of Water, Office of Research and  Development,
   Washington, DC. March.

 USEPA. 1991c.  Technical support document for water quality-based toxics control.  EPA/505/2-90-001.
   U.S. Environmental Protection Agency, Office of Water, Washington, DC.

USEPA.  1992a. Integrated Risk Information System (IRIS). U.S. Environmental Protection Agency,
   Health Criteria and Assessment  Office, Washington, DC.  Revised October.

USEPA. 1992b.  Health Effects Assessment Summary Tables (HEAST).  FY-1992. U.S. Environmental
   Protection Agency, Office of Solid Waste and Emergency Response, Washington, DC.
                                             58

-------
USEPA.  1992c.  Categorization assessment report for pulp and paper analytes detected during the long-
   term sampling 1991-1992. U.S. Environmental Protection Agency, Office of Science and Technology,
   Washington, DC.

USEPA.   1992d.  National study of chemical residues in fish.  Vol. 1.  EPA 823-R-92-008a.  U.S.
   Environmental Protection Agency, Office of Science and Technology, Washington, DC. September.

USEPA.  1992e.  Categorization assessment report for pulp and paper analytes detected during the short-
   term sampling 1988-1990. U.S. Environmental Protection Agency, Office of Science and Technology,
   Washington, DC.

USEPA.   1993a.  Interim report on data and methods for assessment of 2,3,7,8-tetrachlorodibenzo-p-
   dioxin risks to aquatic life and associated wildlife.  EPA/600/R-93/055. U.S. Environmental Protection
   Agency, Office of Research and Development, Washington, DC. March.

USEPA. 1993b. Development document for proposed effluent limitation guidelines and standards for the
   pulp,  paper,  and paperboard point source category   U.S. Environmental  Protection Agency,
   Washington, DC.

USEPA.   1993c.  Estimating exposure to  dioxin-like compounds.  Vol. Ill:  Site-specific  assessment
   procedures.  Draft.  U.S. Environmental Protection Agency, Office of Health and Environmental
   Assessment, Exposure Assessment Group, Washington, DC.  July.

Versar, Inc.  1993. Toxicity data for pulp and paper analytes.  Versar, Inc., Springfield, VA.

Walsh, G.E., K.M. Duke, and R.B. Foster. 1982. Algae and crustaceans as indicators of  bioactivity of
   industrial wastes. Water Res. 16:879-883.

West, P.C.,  J.M.  Fly, R. Marans, and F. Larkin.   1989.  Michigan sports anglers fish consumption
   survey, Supplement I, Non-response bias and consumption suppression effect adjustment.  Natural
   Resource Sociology Research Lab, Technical Report No. 2.  School of Natural Resources, University
   of Michigan, Ann Arbor.  September.

Williams, J.D., M.L. Warren, Jr., K.S. Cummings, J.L. Harris, and RJ. Neves. 1993. Conservation status
   of freshwater  mussels of the United States and Canada.  Fisheries  18(9):6-22.
                                              59

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ATTACHMENT A-2. LIST OF THE RECEIVING STREAMS FOR THE 103 BAT
                        PULP AND PAPER MILLS
            This table contains confidential business information (CBI).
                It has therefore been included in the CBI record.

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ATTACHMENT A-3. MILL-SPECIFIC EFFLUENT AJND RECEIVING STREAM
         FLOWS USED IN THE ENVIRONMENTAL ASSESSMENT
            This table contains confidential business information (CBI).
                It has therefore been included in the CBI record.

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           ATTACHMENT A-5.  SUMMARIZATION OF CREEL SURVEY DATA

                        Harvest Rates and Exposed Population Multipliers

Receiving Stream

Angelina River, TX    398995 anglers/year
                      884436.5 Ibs harvested/year
(Not used because     884436.5/398995 = 2.2 Ibs/angler/year or 2.74 grams/angler/day
majority of anglers
from counties not
bordering  receiving
stream segment)
Leaf River, MS
990 Ibs harvested/183 days
53 anglers/183 days

990 lbs/53 anglers =  18.7 Ibs/angler
(18.7 lbs/angler)/183  days = 0.10 Ibs/angler/day or 45.4 grams/angler/day

106 anglers (creel survey)  *-extrapolated for a year
1630 total licensed anglers

106/1630 = 0.065
Chickasaw Creek, Al   748,702 Ibs harvested/year
                      3817 anglers/year

                      748,702/3817 = 196 Ibs/angler/year or 244 grams/angler/day
Two mills discharge
to the same receiving   3817 anglers (creel survey)
stream segment        23158 total licensed anglers

                      3817/23158 = 0.16
Tombigbee River, AL  632,947 Ibs harvested/year
                      1595 anglers/year
Three mills discharge
to different stream     632,947/1595 = 397 Ibs/angler/year or 494 grams/angler/day
segments, each within
the vicinity of the      1595 anglers (creel survey)
creel survey location   5525, 2304, 6305 total licensed anglers for mills 1, 2, 3 respectively
Mill 1

Mill 2

Mill 3
1595/5525 = 0.29

1595/2304 = 0.69

1595/6305 = 0.25

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       ATTACHMENT A-5 (cont).  A SUMMARIZATION OF CREEL SURVEY DATA

             Exposed Population Multipliers (Harvest Rates Unavailable for these Mills)

Receiving Stream

Menaminee River, MI  358 anglers (creel survey)
                      24,446 total licensed anglers

                      358/24,446 = 0.015
Peshtigo River, WI
87 anglers (creel survey)
16,873 total licensed anglers

87/16,873 = 0.005
Wisconsin River, WI   13,154 anglers (creel survey)
                      21,335 total licensed anglers for mills 1 and 2, and
Three mills discharge  34,801 total licensed anglers for mill 3
to two separate stream
segments, each within
the vicinity of the
creel survey location
Mills 1 and 2
MiU 3
13,154/21,335 = 0.62
13,154/34,801 = 0.38
Lake Champlain, NY   1146 anglers (creel survey)
                      6282 total licensed anglers

                      1146/6282 = 0.182

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ATTACHMENT A-6. POTENTIALLY EXPOSED POPULATIONS DERIVED FROM
      THE NUMBER OF TOTAL LICENSED ANGLERS FOR EACH MILL
             This table contains confidential business information (CBI).
                 It has therefore been included in the CBI record.

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    ATTACHMENT A-7.  RECREATIONAL ANGLER POPULATION ESTIMATES FOR
                RECEIVING STREAMS WITH FISH ADVISORIES IN PLACE
4 * "'
Receiving Stream
Blackwater River (VA)
Houston Ship Channel (TX)
Kennebec River (ME)
Escatawpa River (MS)
Ouachita River (AR)
Escanaba River (MI)
Androscoggin River (ME)
Bayou La Fourche (LA)d
Red River (AR)
Fenholloway River (FL)
Codorus Creek (PA)
Neches River (TX)
Penobscott River (ME)
St. Louis River (MM)
Androscoggin River (NH)
Pacific Ocean (CA)d
Potomac River (MD)
Leaf River (MS)
Roanoke River (NC)
Rainy River (MM)
Pigeon River (NC)
Sacramento River (CA)d
Wisconsin River (WI)
TOTAL POPULATION
Total
Licensed
Anglers*
4,713
190,726
27,230
16,030
17,950
10,687
31,091
26,393
28,956
3,897
36,566
74,597
24,182
99,876
1,849
19,096
5,001
1,630
5,999
7,887
5,188
31,953
21,335
692,832
»•>"
# Anglers
w/Advisory*
1,039
42,036
6,001
3,533
3,956
2,355
6,852
—
6,382
859
8,059
16,441
5,330
22,013
408
_.
1,102
359
1,322
1,738
1,143
—
4,702
135,630
,." # Anglers
w/o „
Advisory*
1,298
52,545
7,502
4,416
4,945
2,944
8,566
_.
7,977
1,074
10,074
20,551
6,662
27,516
509
__
1,378
449
1,653
2,173
1,429
—
5,878
—
Advisory Lifted
, ,„ , After BAT?
'j&Kfir' '
Yes
Yes
Yes
Yes
Yes
Yes
Yes
_.
Yes
Yes
Yes
Yes
Yes
Yesf
Yes
_
Yes
Yes
Yes
No
Yes
—
Yesf
_.
SD
No
Yes
Yes
Yes
Yes
Yes
Yes
_
Yes
No
Yes
Yes
Yes
No
Yes
—
No
Yes
Yes
No
No
_
Yesf
—
.Population After BAT
7 E>RE -
1,298
52,545
7,502
4,416
4,945
2,944
8,566
_.
7,977
1,074
10,074
20,551
6,662
22,013
509
_.
1,378
449
1,653
1,738C
1,429
—
4,702
162,425
sb
l,039e
52,545
7,502
4,416
4,945
2,944
8,566
—
7,977
859e
10,074
20,551
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d Evaluation not conducted
° Advisory not lifted after BAT implementation
f Advisory lifted for dioxin, but advisory still in place for other contaminants

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-------

-------
ATTACHMENT A-9.  ESTIMATED NUMBER OF CONTAMINANTS
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      This table contains confidential business information (CBI).
         It has therefore been included in the CBI record.

-------

-------
ATTACHMENT A-10. ESTIMATED HIGHEST LEVEL OF EXCEEDANCE OF AQUATIC
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              AND EACH EVALUATED BAT OPTION BASED ON A
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               This table contains confidential business information (CBI).
                  It has therefore been included in the CBI record.

-------

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-------

-------
ATTACHMENT A-13. ESTIMATED NUMBER OF CONTAMINANTS EXCEEDING
     HUMAN HEALTH AWQCs FOR EACH FACILHTY UNDER BASELINE
      CONDITIONS AND EACH EVALUATED BAT OPTION BASED ON
                   A SIMPLE DILUTION ANALYSIS
            This table contains confidential business information (CBI).
                It has therefore been included in the CBI record.

-------

-------
ATTACHMENT A-14. ESTIMATED HIGHEST LEVEL OF EXCEEDANCE OF HUMAN
    HEALTH AWQCs FOR EACH FACILITY UNDER BASELINE CONDITIONS
             AND EACH EVALUATED BAT OPTION BASED ON A
                       SIMPLE DILUTION ANALYSIS
              This table contains confidential business information (CBI).
                  It has therefore been included in the CBI record.

-------

-------
ATTACHMENT A-15. COMPARISON OF STATE FISH TISSUE CONCENTRATION
    THRESHOLDS FOR ISSUING FISH ADVISORIES TO ESTIMATED FISH
      TISSUE CONCENTRATIONS DERIVED BY SIMPLIFIED DILUTION
             ANALYSIS AND CONTAMINANT-SPECIFIC BCFS.
            This table contains confidential business information (CBI).
                It has therefore been included in the CBI record.

-------

-------
ATTACHMENT A-16.  COMPARISON OF STATE FISH TISSUE CONCENTRATION
    THRESHOLDS FOR ISSUING FISH ADVISORIES TO ESTIMATED FISH
      TISSUE CONCENTRATIONS DERIVED BY DIOXIN REASSESSMENT
                 EVALUATION (USEPA/ORD) ANALYSIS
             This table contains confidential business information (CBI).
                It has therefore been included in the CBI record.

-------

-------
ATTACHMENT A-17. ESTIMATED INCREASED INDIVIDUAL CANCER RISKS AND
       POTENTIAL INCREASED INCIDENCE OF CANCER IN EXPOSED
        RECREATIONAL ANGLER POPULATIONS UNDER BASELINE
            CONDITIONS AND EACH EVALUATED BAT OPTION
                 USING SIMPLE DILUTION APPROACH
             This table contains confidential business information (CBI).
                It has therefore been included in the CBI record.

-------

-------
ATTACHMENT A-18. ESTIMATED INCREASED INDIVIDUAL CANCER RISKS AND
POTENTIAL INCREASED INCIDENCE OF CANCER IN EXPOSED RECREATIONAL
     ANGLER POPULATIONS UNDER BASELINE CONDITIONS AND EACH
       EVALUATED BAT OPTION USING SIMPLE DILUTION APPROACH
               TO ESTIMATE 2,3,7,8-TCDD AND 2,3,7,8-TCDF
                    FISH TISSUE CONCENTRATIONS
             This table contains confidential business information (CBI).
                 It has therefore been included in the CBI record.

-------

-------
ATTACHMENT A-19.  ESTIMATED INCREASED INDIVIDUAL CANCER RISKS AND
 POTENTIAL INCREASED INCIDENCE OF CANCER IN EXPOSED SUBSISTENCE
     ANGLER POPULATIONS UNDER BASELINE CONDITIONS AND EACH
      EVALUATED BAT OPTION USING SIMPLE DILUTION APPROACH
             This table contains confidential business information (CBI).
                It has therefore been included in the CBI record.

-------

-------
ATTACHMENT A-20. ESTIMATED INCREASED INDIVIDUAL CANCER RISKS AND
  POTENTIAL INCREASED INCIDENCE OF CANCER IN EXPOSED SUBSISTENCE
ANGLER POPULATIONS UNDER BASELINE CONDITIONS AND EACH EVALUATED
       BAT OPTION USING DRE APPROACH TO ESTIMATE 2,3,7,8-TCDD
             AND 2,3,7,8-TCDF FISH TISSUE CONCENTRATIONS
             This table contains confidential business information (CBI)
                 It has therefore been included in the CBI record.

-------

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ATTACHMENT A-21.  ESTIMATED NONCANCER HAZARD QUOTIENTS
   FOR INGESTION OF FISH UNDER BASELINE CONDITIONS AND
         EACH EVALUATED BAT OPTION USING SIMPLE
                     DILUTION APPROACH
         This table contains confidential business information (CBI).
             It has therefore been included in the CBI record.

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ATTACHMENT A-22. ESTIMATED NONCANCER HAZARD QUOTIENTS
   FOR INGESTION OF FISH UNDER BASELINE CONDITIONS AND
    EACH EVALUATED BAT OPTION USING DRE APPROACH TO
          ESTIMATE 2,3,7,8-TCDD AND 2,3,7,8-TCDF FISH
                   TISSUE CONCENTRATIONS
         This table contains confidential business information (CBI).
             It has therefore been included in the CBI record.

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