United States
                      Environmental Protection Agency
                                Region 10
                            1200 Sixth Avenue
                         Seattle, Washington 98101
              TOTAL MAXIMUM DAILY LOADING (TMDL)
          TO LIMIT DISCHARGES OF 2,3,7,8-TCDD (DIOXIN)
                  TO THE COLUMBIA RIVER BASIN
      In compliance with the provisions of the Clean Water Act, 33 U.S.C. $1251 £t
seq..as amended by the Water Quality Act of 1987, P.L 100-4, the Environmental
Protection Agency is hereby establishing a TMDL to limit discharges of dioxin to the
Columbia River basin.

      This TMDL shall become effective immediately, and is incorporated into the
water quality management plans for the states of Washington, Oregon, and Idaho
under Clean Water Act s303(e). Subsequent state actions  must be consistent with this
TMDL
      Signed this  <3fS+^  day of P^hnuuxr-ix , 1991 .
                                 Dana A. Rasmussen
                                 Regional Administrator, Region 10
                                 U.S. Environmental Protection Agency

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               TOTAL MAXIMUM  DAILY LOAD (TMDL)

                         FOR 2,3,7,8-TCDD

                  IN THE COLUMBIA RIVER BASIN
                          Decision Document
                           February 25,1991


Developed pursuant to the provisions of the Clean Water Act, 33 U.S.C. $1251, et seq,
as amended by the Water Quality Act of 1987, P.L 100-4.
                         TABLE OF CONTENTS

                                                            Page

  1.  SCOPE	1-1
     A.  Water Quality-Limited Segments	1-1
     B.  Pollutant Causing Exceedance of WQ Standards  	1-1
     C.  Source Categories Considered  	1-2

  2.  NEED FOR A TMDL  	2-1
     A.  Overview	2-1
     B.  The Concern	2-2
     D.  Water Quality Limited Status  	2-3

  3.  DEVELOPMENT OF THE TMDL  	3-1
     A.  Overview 	3-1
     B.  Process  	3-1
     C.  Loading Capacity 	3-2
     D.  Sources  	3-2
     E.  Allocation of Loads  	3-4
     F.  Judicial Review	3-11

  4.  SUMMARY 	4-1
  APPENDICES
      A.  LOADING CAPACITY	A-1
      B.  ALLOCATION ISSUES	B-1
      C.  WASTE LOAD ALLOCATION METHODS CONSIDERED	C-1

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Final TMDL for D/ox/n Discharges to the Columbia Basin
                                                                          1-1
                          TOTAL MAXIMUM DAILY LOAD
                                       FOR
                  2,3,7,8-TCDD IN THE COLUMBIA RIVER BASIN


                                Decision Document
1.
SCOPE
      This total maximum daily load (TMDL) addresses the following segments,
      pollutants, and source categories:
      WATER QUALITY-LIMITED SEGMENTS:
RIVER SEGMENT
Columbia River (RM

n i
(RM
(RM
(RM







n
n
n
n
n
n
n
Snake River
"
n
n
n
(RM
(RM
(RM
(RM
(RM
(RM
(RM
(RM
(RM
0 -
0 -
309 -
596 -
0 -
86 -
120 -
147 -
203 -
218 -
247 -
0 -
0 -
745)
309)
596)
745)
86)
120)
147)
203)
218)
247)
309)
176)
176)
APPLICABLE WATER QUALITY RULES:1
WAC
WAC
WAC
WAC
OAR
OAR
OAR
OAR
OAR
OAR
OAR
WAC
WAC
173-201-047 2
173-201-080(19) 3
173-201-080(20) 3
173-201-080(21) 3
340-41-202 & 205(2) (p)
340-41-442 & 445(2) (p)
340-41-482 & 485(2) (p)
340-41-522 & 525(2) (p)
340-41-562 & 565(2) (p)
340-41-602 & 605(2) (p)
340-41-642 & 645(2) (p)
173-201-047 2
173-201-080(97) 3
IDAPA 16.01.2120 & .2200
Willamette River (RM 0 -
187)
OAR
340-41-442 & 445(2) (p)




4,5
4,5
4,5
4,5
4,5
4,5
4,5


6,7
4.5
             In addition to the following, all waste load allocations and permit limits must ensure
             compliance with applicable water quality standards of downstream states [40 CFR
             §122.4(d)].
             WAC 173-201-047 describes Washington's applicable criteria for toxic substances.
             WAC 173-201-080 describes Washington's classification for specific waterbodies.
             OAR 340-41-xx2 describes beneficial uses designated by Oregon.
             OAR 340-41-xx5(2)(p) describes Oregon's applicable criteria for toxic substances.
             IDAPA 16.01.2120 describes the designated uses for the confluence of the Clearwater
             and Snake River in Idaho.
             IDAPA 16.01.2200 describes Idaho's criteria for hazardous and deleterious materials.
      POLLUTANT CAUSING EXCEEDANCE OF WQ STANDARDS:

           2,3,7,8 - tetrachlorodibenzo-para-dioxin  (2,3,7,8-TCDD)

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Final TMDL for Dioxin Discharges to the Columbia Basin
                                                                           1-2
       SOURCE CATEGORIES CONSIDERED:
 Source    Allocation
Category      Type

    1        WLA1
    2      Reserved
                                 Source Description

                                Pulp & Paper Mills -- Chlorine Bleaching
                                All Other Sources:
                                  Pulp & Paper Mills ~ Non-Chlorine Bleaching
                                  Woodtreaters Using Pentachlorophenol
                                  Municipal Wastewater Treatment Facilities
                                  Canadian Sources
                                  Other Point Sources
                                  Port Activities
                                  Urban Areas
                                  Other Nonpoint Source
                                  Background
           Figure 1-1.  Columbia River Basin.
                                                             CELGAR
                                                             (Outlets]-. RC.)
  LONG VIEW FIBER
  (Longnr.. WA)
 WEYERHAEUSER
 (IxmgTiev. WA)
 JAKES RIVER
 Ofeuna, OR)

 BOISE CASCADE
 (St Helena OR)
 POPE t TALBOT
 (Halsey, OR)
         WLA = waste load allocation

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Final TMDL for Dioxin Discharges to the Columbia Basin
2.    NEED FOR A TMDL

      A.     Overview

      The Columbia River and segments of the Snake and Willamette Rivers are
currently water quality-limited due to the presence of excessive levels of 2,3,7,8-TCDD.
This pollutant is the most toxic of a group of compounds known as polychlorinated
dibenzo-para-dioxins (dioxin). The concern over dioxin levels in the Columbia River is
based on data describing concentrations of 2,3,7,8-TCDD in effluents and treatment
plant sludges at chlorine-bleaching pulp mills as well as in fish tissue below these mills.

      Section 303(d)(1)(C) of the Clean Water Act (CWA) and EPA's implementing
regulations (40 CFR Part 130) require each state to identify waters for which existing
required pollution controls are not stringent enough to attain applicable water quality
standards. For these water quality-limited segments, each state is then to establish
total maximum daily loads (TMDLs) for appropriate pollutants of concern.  By definition
(40 CFR, s 130.2), a TMDL is the sum of the individual waste load allocations (WLAs)
for point sources and load allocations (LAs) for nonpoint sources and natural
background. The CWA states that the TMDL:

      "shall be established at a level necessary to implement the applicable
      water quality standards with seasonal variations and a margin of safety
      which takes into account any lack of knowledge concerning the
      relationship between effluent limitations and water quality."

      Thus, the TMDL is effectively an implementation plan for achieving water quality
standards using an appropriate  margin of safety. A margin of safety may be provided
(1) by using conservative assumptions in the calculation of the loading capacity of the
waterbody and (2) by establishing allocations that in total are lower than the defined
loading capacity. The water quality standard being protected by this TMDL is
0.013 parts per quadrillion (ppq) 2,3,7,8-TCDD in the water (see Appendix A).

      The national focus on toxics discharges as evidenced  in the 1987 amendment
to Section 304 of the CWA, 33 U.S.C. s 1314(1), gives additional urgency to the
establishment this TMDL  Congress intended s 304(1) to focus state water quality
protection programs on immediately addressing water quality problems due to point
source discharges of toxic pollutants. States are required to  develop lists of impaired
waters,  identify point sources and amounts of toxic pollutants they discharge.and to
develop individual control strategies (ICSs) for each such point source.  An ICS may
be a draft or a final  National Pollutant Discharge Elimination System (NPDES) permit.
The s 304(1) lists developed for Washington, Oregon, and Idaho have identified dioxin
levels in the Columbia, Snake, and Willamette Rivers as exceeding applicable water
quality standards.  Limits included in ICS's, developed under s304(l), must be
consistent with waste load allocations (WLAs) where a TMDL has been established.

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Final TMDL for Dioxin Discharges to the Columbia Basin
      B.    The Concern

      Dioxins are produced as a result of human activities, such as the manufacture
of chlorinated  herbicides, the combustion of domestic and industrial wastes, and the
production of chlorine-bleached wood pulp. Both water column concentrations of
dioxin in the Columbia River and the water quality standard for 2,3,7,8-TCDD are below
levels which can be measured with current analytical technology.  However, because
some organisms, such as fish, accumulate dioxin in their bodies, 2,3,7,8-TCDD has
been found at detectable levels in the tissue of fish taken from the Columbia River
basin. As discussed below, these tissue levels are of concern and indicate that these
waters exceed state water quality standards.

      The state water quality standard applicable to 2,3,7,8-TCDD in the Columbia
River basin has been determined to be 0.013 ppq (see Appendix A). The EPA criterion
on which  this standard is based was derived from human health concerns resulting
primarily from  consumption of contaminated fish.  In establishing EPA's 1984 2,3,7,8-
TCDD criterion values, the following factors were developed and used:  a biocon-
centration factor (this relates the concentration in fish tissue to the concentration in the
water in which the fish lives), fish consumption rates, and a cancer potency factor.
These factors  relate water column concentrations to fish tissue concentration and
cancer  risk. A fish tissue concentration of 0.07 ppt and a water concentration of 0.013
ppq (the applicable water quality standard) are both estimated to result in a life-time
cancer  risk of  10~8 (one excess cancer per one million people).

      In 1987, EPA initiated a National Bioaccumulation Study (NBS) designed to
gather screening information on the prevalence and concentrations of selected toxic
compounds in fish tissue and other aquatic organisms. This study was conducted on
a broad scale  across the United States and included testing for 2,3,7,8-TCDD.
Sampling  sites included relatively undisturbed  background areas, streams below
industrial, agricultural, and urban activities,  and segments below mills using chlorine to
bleach pulp. The NBS identified concerns related to chlorine-bleaching kraft pulp mills.
Fish samples collected at several locations below chlorine-bleaching pulp mills on the
Columbia River within EPA Region 10 (from the Canadian border to the mouth) have
shown detectable concentrations of 2,3,7,8-TCDD. Another EPA study, the "104 Mill
Study" (1988), subsequently confirmed, through testing of effluents and sludges, that
chlorine-bleaching pulp mills are a significant source of 2,3,7,8-TCDD.

      Figure 2-1 displays estimates of risk of excess cancer resulting from
consumption of fish at various locations along the length of the river. The risk
estimates  were obtained by applying the fish consumption and cancer potency factors
used in  developing the EPA criterion for 2,3,7,8-TCDD to fish tissue concentrations
actually measured. Fish tissue data used came from EPA's National Bioaccumulation
Study O987). tne Northwest Pulp & Paper Associations's Columbia River  Fish Study
(Beak Consultants, 1989), the Washington  Department of Ecology's work on Lake
Roosevelt (1989-1990), and from efforts in Canada.  The resulting risk estimates
(Figure 2-1) are consistently higher than the 10~6 level, confirming that the water quality
standard and, therefore, the loading capacity of the system, are being exceeded.  This
is consistent with, and supported by, predicted water column concentrations of
2,3,7,8-TCDD (based on in-stream dilution of pulp mill discharges as measured in the
104 Mill  Study) which also exceed the water quality standard.

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Final TMDL for Dioxin Discharges to the Columbia Basin
                                                                        2-3
                   Figure 2-1.  Columbia River Fish Tissue Data
          -2
in
5
          -3 -
          -4 -
          -5 -
          -B
          -7 -
           -8
                                     AA
                                   * AA
                                                             A

                                                            A*
                                          Basis for Loading Capacity
                                                                  A
                                                                  A
 A

&4
                                                             A

                                                             A
                           200            400

                                     River Mile
                              A   Fish t issue TCDD
                                                         600
                                                                        800
      C.    Water Quality-limited Status

      Oregon has identified the Columbia River (river miles 0 - 309) and the Willamette
River (RM 0-187) as being water quality-limited for 2,3,7,8-TCDD.  Washington has
similarly identified the Columbia and Snake Rivers within that state as being water
quality-limited for 2,3,7,8-TCDD. The state of Idaho has also identified the confluence
of the Clearwater and Snake Rivers as being water quality-limited for 2,3,7,8-TCDD.
On June 14,1990, EPA approved these listings pursuant to CWA Section 303(d).

      On March 21,1990 the states of Oregon, Washington, and Idaho stated that
they would not adopt a TMDL for dioxin in the Columbia River as state actions but
rather requested that EPA establish this TMDL as a federal action.  The states
acknowledged that while the development of a TMDL has been a cooperative effort,
the interstate nature of the Columbia River Basin and the desirability of consistency
and equity in regulating dischargers in this basin necessitated that the TMDL be a
federal action. Therefore, on June 14,1990, pursuant to Section 303(d), EPA formally
disapproved the expressed intent of Washington, Oregon, and Idaho to not submit
TMDLs and, subsequently, developed this final TMDL for dioxin discharges to the
Columbia River basin as a federal action.

      This TMDL provides a framework to control 2,3,7,8-TCDD discharges to the
Columbia River Basin and achieve compliance with water quality standards. The
following sections of the decision document describe the established TMDL and the
process used to develop it.

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Final TMDL for Dioxin Discharges to the Columbia Basin
3.     DEVELOPMENT OF THE TMDL
      A.    Overview

      Development of a TMDL provides a process for weighing the needs of
competing activities which affect water quality in a watershed and creating an
integrated pollution control strategy for point and nonpoint sources.  This process
allows regulatory agencies to take a holistic view of water quality problems from the
perspective of in-stream conditions.

      The total load of a pollutant to a waterbody is attributable to point sources,
nonpoint sources, and natural background.  The TMDL process distributes portions of
the stream's loading capacity to the various sources, including background conditions,
in a way that will achieve water quality standards. The level of refinement reflected in
actual allocations depends on the amount of available data. The Water Quality
Management Regulations [40 CFR, s 130.2] state, for example, that:

      "Load allocations are best estimates of the loading, which may range
      from reasonably accurate estimates to gross allotments, depending on
      the availability of data and appropriate techniques for predicting the
      loading."

      As previously pointed out, Section 303(d) states that a margin of safety should
be used which takes into account any lack of knowledge concerning the relationship
between effluent limitations and water quality. Thus, the law indicates that the TMDL
process should move forward using available information.  As new information
becomes available in the future, the TMDL can be refined.
      B.    Process

      The TMDL identifies the amount of a pollutant that may be discharged to a
water quality-limited stream. TMDLs can be expressed in terms of either chemical
mass per time, toxic'rty, or other appropriate measure. The TMDL for a particular
waterbody is dependent on such factors as the location of sources, stream flow, water
quality standards, background conditions, and in-stream pollutant reactions. The
process of developing and implementing a TMDL for 2,3,7,8-TCDD in the Columbia
River basin consists of several steps:
                    •

 •    define the loading capacity of the river at key points

 •    identify sources which potentially contribute loads of 2,3,7,8-TCDD

 •    allocate loads to point sources, nonpoint sources (NPS), and background

 •    implement the TMDL through Water Quality Management Plans and NPDES
      permits

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Final TMDL for Dioxin Discharges to the Columbia Basin
      C.    Loading Capacity

      WLAs and LAs represent the allocated portions of a receiving water's loading
capacity. The loading capacity is the greatest amount of pollutant loading that the
river can receive without violating water quality standards.  A TMDL must not exceed
the loading capacity of a waterbody.

      Two fundamental issues must be determined at the outset when establishing a
TMDL  These are (1) the definition of upstream and downstream boundaries of the
waterbody for which the TMDL is being determined and (2) the flow conditions
(design flow) appropriate for calculating the loading capacity or amount of pollutant
which can be assimilated. Having defined the extent of the waterbody and the
appropriate flow conditions, the loading capacity is calculated to achieve the applicable
water quality standard (see Appendix A for discussion of applicable standards for
dioxin and river flow rates occurring in the Columbia River Basin).

      A loading capacity of approximately 6 mg of 2,3,7,8-TCDD per day has been
calculated for the Columbia River at its mouth.
      D.    Sources

      The Columbia River is over 1200 miles long and drains an area of about
259,000 square miles.  Land use and terrain in the basin are diverse.  General activities
affecting water quality in the basin include areas of urban development, industry,
agriculture, and forestry.  In terms of 2,3,7,8-TCDD,  chlorine bleaching pulp mills have
been identified as a major source based on their effluent and sludge data.

      Within EPA Region 10, eight chlorine-bleaching pulp mills currently discharge to
the Columbia River system. These mills, one in Idaho, four in Washington, and three
in Oregon, are shown in Figure 3-1. The eight mills  currently produce over 7,000 tons
per day of bleached pulp. Another chlorine-bleaching pulp mill which discharges to
the Columbia River is located near Castlegar, British Columbia, about 30 miles above
the U.S. - Canadian border. Known sources of 2,3,7,8-TCDD are thus affecting the
Columbia River within EPA Region 10, from the mouth near Astoria, Oregon to the
Canadian border (river mile 745) and the Snake and Willamette Rivers, major drainages
within the Columbia River system. Consequently, the entire Columbia River basin,
including the Snake and Willamette Rivers, are included in the TMDL.  Tributaries
outside of EPA Region 10, such as the Clark Fork in Montana, have also been
considered in developing the TMDL

      Besides chlorine bleaching pulp mills, other potential source categories include
woodtreaters using pentachlorophenol,  major municipal wastewater treatment plants,
agricultural areas, industrial sites, urban areas, and  release from bottom sediments.
Data on dioxin discharges from these sources, however, are minimal or nonexistent for
the following reasons:

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Final TMDL for Dioxin Discharges to the Columbia Basin
3-3
       m  Concern over the extent of dioxin pollution is relatively recent.

       •  Many of the point sources have been considered minor dischargers in the
         past and had minimal monitoring requirements.

       •  It is difficult to characterize  loadings from stormwater or nonpoint sources.
         These inputs are not continuous and are generally driven by weather related
         events such as rain storms or snow melt.

       •  There are analytical obstacles associated with measuring 2,3,7,8-TCDD.  The
         water quality standard of 0.013 parts per quadrillion (ppq) is several orders
         of magnitude below a typical detection limit of 10 ppq for water column
         measurements.

The available data are not adequate to develop WLAs or LAs for these sources.
However, current loadings for some of these other dioxin sources of concern in the
Columbia basin are estimated in Appendix B and summarized later in the following
section.
               Figure 3-1. Location of Chlorine-Bleaching Pulp Mills
                           in the Columbia River Basin
  JAMES RIVER
  (Wouno)
  BOISE CASCADE
  (St Hdou)
  POPE & TALBOT

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Final TMDL for Dioadn Discharges to the Columbia Basin
      E.    Allocation of Loads
      Having identified major sources of 2,3,7,8-TCDD to the Columbia River basin,
the TMDL must establish allocations sufficient to control discharges within the loading
capacity.  These allocations are made considering technical, socioeconomic, and
institutional constraints.  Historically, individual states have used various allocation
schemes on a case-by-case basis or specified that a particular method be used.
Technical guidance has been prepared which describes 19 potential approaches for
allocation of loads (Technical Guidance Manual for Performing Waste Load
Allocations", U.S. Environmental Protection Agency, 1986). When evaluating various
methods, conditions that favor one approach over another must be considered.

      With respect to this TMDL there are some potential problems in using the more
common methods described in the technical guidance:


      •   The geographic scale associated with the Columbia Basin and the number of
          potential sources is considerably larger than the scale typically encountered
          in most TMDL situations.

      •   Common methods focus on waste load allocations for point sources.
          Background sources (e.g. release from bottom sediments) and nonpoint
          source loads, however, may be significant considerations for 2,3,7,8-TCDD
          in the Columbia River basin.

      •   There are few data on 2,3,7,8-TCDD discharges from source categories
          other than chlorine bleaching pulp mills in the basin.

      •   There are complexities in addressing persistent  and highly bioaccumulative
          pollutants such as 2,3,7,8-TCDD.

The last three of these points mean that data and methods of analysis (e.g. predictive
models) are not available to adequately characterize ail pollution sources at this time.
However, the lack of information about some pollution sources or processes is not a
reason to delay implementation of water quality-based controls for known sources
contributing to violations of water quality standards. The key is to work within a logical
framework that will lead to the attainment of water quality standards. After
consideration of the above problems and the issues discussed in Appendix B, the
following approach was developed for this TMDL:


      •   Identify watershed targets to be used  as a framework to guide allocation
          decisions;

      •   Establish WLAs for the major source category for which there are currently
          sufficient data to do so;

      •   Estimate current loadings for other source categories;

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Final TMDL for D/ox/n Discharges to the Columbia Basin
       •  Reserve some of the unallocated loading capacity (beyond that necessary to
          cover the WLAs established and estimated current loadings for other
          sources) to provide an additional component of the margin of safety, some
          of which could be used for future growth.

      This approach provides for further pollution reduction from known sources while
additional data are collected to:  (1) confirm that the reductions required by this TMDL
are leading to water quality standards attainment; and  (2) provide additional
information necessary to refine estimates of assimilative capacities and TMDL
allocations.  This TMDL establishes WLAs that will form the basis of more stringent
limits for dioxin discharges from confirmed point sources. It also estimates loadings
from other sources and incorporates a margin of safety to account for existing
uncertainties. Where new data show that modification  of the TMDL is appropriate, the
TMDL will be revised accordingly.  By allowing future modification of the TMDL,
regulatory agencies can avoid delays in controlling known sources while they continue
to investigate other possible sources.  Decisions on the use of the unallocated load will
be made through a joint effort by the States and EPA.
Watershed Targets:

      The Oregon Department of Environmental Quality (DEQ) has utilized the
concept of watershed targets for developing TMDLs in Oregon. Watershed targets are
particularly useful for TMDLs designed to achieve water quality standards in large
waterbodies adversely affected by a pollutant coming from a variety of sources.
Allocations for major sources are established after watershed targets are identified.
The watershed targets serve as internal check points to determine that water quality
standards will be met at key locations within the drainage. This same technique is also
being used for the Columbia River in this TMDL.

      Watershed targets can be set within the basin by simply identifying the loading
capacity at key points in the drainage system. To determine these targets, the only
data requirements are a water quality criterion and a design flow (in this case, the
mean harmonic stream  flow). The watershed targets focus on high priority tributaries.
In the case of the Columbia, there are three logical points in addition to the lower
Columbia near Bradwood (below Longview) for which loading capacities should be
calculated. These locations are shown in Figure 3-2 and relevant data are summarized
in Table 3-1.

      The Willamette Basin is the most industrialized and populated area in the
Columbia River system. There  are high numbers of both industrial and municipal
dischargers in the drainage compared to other sub-basins in the Columbia River
system. The most logical approach is to establish the watershed target as equal to the
loading capacity for the Willamette River at Portland (0.54 mg/day). The sum of all
allocations to sources in the Willamette Basin must not exceed this watershed target.
By the same token,  loading capacity attributed to flow produced by the Willamette is
not currently available for use in the mainstem Columbia.

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Final TMDL for Dioxin Discharges to the Columbia Basin
3-6
       Because the Willamette Basin is entirely within Oregon, the Oregon Department
of Environmental Quality (ODEQ) has the option, within the context of a TMDL, to
adjust allocations for specific sources which would still meet this watershed target. In
fact, Oregon has already initiated dioxin controls in the Willamette through issuance of
an NPDES permit to Pope & Talbot at Halsey with effluent limits for 2,3,7,8-TCDD
(0.19 mg/day).  Furthermore, DEQ has committed to developing a TMDL for dioxin in
the Willamette which will meet the watershed target.1  A Willamette Basin TMDL could
include different limits for Pope & Talbot, based on needs determined by ODEQ.
         Figure 3-2. Location of Watershed Targets (•) Relative to Pulp Mills
                                                         CELGAR
                                                             r. BC)
                      WEYERHAEUSER
                      (Umf*l»)

                        LONCV1EW FltiEH
                        (Loo«»i.w)

                         JA1OS RIVER
     POPE it TALBOT'
     (IU-T)
      Watershed targets were also evaluated at two other locations in the Columbia
system:  1) at the mouth of the Snake River and 2) at the U.S. - Canadian border.
Far fewer sources exist upstream of these locations than is the case with the
Willamette River basin. However, significant levels of 2,3,7,8-TCDD have been
measured in tissue of fish taken from sites associated with each of these watersheds.
The fish tissue concentrations indicate that the water quality standard and, therefore,
the loading capacity for 2,3,7,8-TCDD is currently exceeded.
      This TMDL will be reviewed by EPA in accordance with §303(d) of the Clean Water Act.

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Final TMDL for D/ox/n Discharges to the Columbia Basin
3-7
      Based on currently available data, reductions in 2,3,7,8-TCDD loads are needed
to meet all three of these watershed targets. These watershed targets must be
achieved in order to ensure attainment of water quality standards where those
watersheds enter the Columbia River.  To the extent that the TMDL results in loading
reductions beyond that necessary to meet the watershed targets, the difference is
available for other downstream uses, future growth, or margin of safety.
          Table 3-1.  Loading Targets for 2,3,7,8-TCDD to Selected
                      Watersheds in the Columbia River System
Watershed
TOTAL COLUMBIA RIVER BASIN
SELECTED SUB-BASINS
Watershed N. of WA/ Canada Border
Snake River Watershed
Willamette River Watershed
TOTAL FOR SUB-BASINS
Harmonic
Mean Flow
(cfs)
188,000 1
72,700 2
37,0003
17, 100 4

Loading
Capacity
(mg/day)
5.97
2.31
1.18
0.54
4.03
      1 Row at Columbia River near Bradwood
      2 Row at Columbia River at WA/Canada border
      3 Row at Snake River below Ice Harbor Dam
      4 Row of Willamette River at Portland
Establish WLAs

      This TMDL focuses on developing waste load allocations for the chlorine
bleaching pulp mills in the basin. These mills constitute the only source category in
the Columbia River basin where site specific quantitative information exists describing
effluent quality and waste loads for 2,3,7,8-TCDD.  Nationally, the median 2,3,7,8-
TCDD concentration in tissue of fish collected below pulp mills using chlorine bleaching
was higher than for fish collected below any other source category studied in the
National Bioaccumulation Study (1987).  In addition, the §304(1) listings under the
Clean Water Act specifically identified these mills in the Columbia River Basin as  point
sources requiring individual control strategies (ICS's). The basis of this listing was not
only data describing  concentrations of 2,3,7,8-TCDD in fish tissue below the mills but
also measured concentrations of 2,3,7,8-TCDD in effluents and treatment plant sludges
at these mills.  The analysis undertaken in developing this TMDL indicates that this
source category would lead to exceedance of water quality standards even if no other
sources existed.

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Final TMDL for D/corfn Discharges to the Columbia Basin
      The proposed TMDL (public notice issued on June 15, 1990) discussed several
alternative methods to establish waste load allocations for chlorine bleaching pulp mills.
The waste load allocation methods evaluated are summarized in Appendix C. The
proposed TMDL allocated approximately 2 mg/day (not including the Canadian Celgar
mill or the planned expansion at Pope & Talbot) to the chlorine bleaching pulp mills.  A
major criterion for evaluating alternative methods for establishing WLAs for chlorine
bleaching pulp mills was the need to verify compliance with resulting NPDES permits.
Allocations for each mill were derived based on the lowest verifiable concentration
(long term average of 4.7 ppq 2,3,7,8-TCDD in the bleached wastestream) in an
assumed average wastewater flow per quantity bleached pulp produced (14,470
gallons/ton). Such an approach yields WLAs which are equal in terms of mass
discharge per unit production of bleached pulp product (0.257 /*g 2,3,7,8-TCDD/ton).

      Table 3-2 displays WLAs based on updated production figures including
planned production increases for Celgar [based on comments from R.W. Sweeney,
Celgar Pulp Co.] and Pope & Talbot [based on comments from CH2M-HHI for James
River and Pope & Talbot; July 20,  1990]. WLAs resulting from allowing 4 different
quantities of 2,3,7,8-TCDD per ton of bleached pulp produced are given  in the table.
Three of the options reflect some of the comments  received during the public
comment period for the proposed TMDL

      Option 1.  This option reflects the belief by the pulp and paper industry that
                 they should  be given the entire loading capacity of the river system.
                 An allowed discharge rate of 0.68 pg 2,3,7,8-TCDD per ton of
                 bleached product results in 100% of the calculated loading capacity
                 being allocated to the existing pulp and paper mills in the basin.

      Option 2.  This option is generally equivalent to the WLAs proposed in the
                 draft TMDL submitted for public comment. Two differences are
                 noted:  (1) the WLA for Pope & Talbot at Halsey is increased based
                 on planned production increases and the NPDES permit recently
                 issued by DEQ; and (2) a WLA has been calculated for the Celgar
                 mill based on planned production increases and the discharge rate
                 (0.257 HQ 2,3,7,8-TCDD per ton of bleached product)  allowed for
                 the other mills.  The calculated WLA for Celgar has no regulatory
                 authority, but is used for comparison purposes and as an estimated
                 loading which should be achievable by Celgar.

      Option 3.  This option reflects the concern by the local pulp mills that the
                 proposed TMDL did not provide  equity with the Celgar mill at
                 Castlegar, British Columbia.  Based on information submitted by
                 both the Celgar mill and the British Columbia Ministry of
                 Environment (see Appendix B), the proposed modernization project
                 at Celgar will result in 2,3,7,8-TCDD discharges which are less than
                 0.05 mg/day (or 0.042 /
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Final TMDL for Dioxln Discharges to the Columbia Basin
3-9
       Option 4.   This is the zero discharge option requested by many commenters.
                  The environmental community believes that zero discharge is the
                  only viable option, because of dioxin's persistence and cumulative
                  build-up in the sediments and biota.


      Table 3-2.  Waste Load Allocation Options for Chorine-Bleaching Pulp Mills
Pulp Mill -- Location
Pot latch -- Lewiston, ID
Boise Cascade -- Uallula, UA
James River -- Camas, UA
Longvieu Fibre -- Longview, UA
Weyerhaeuser -- Longview, UA
Pope & Talbot -- Halsey, OR
Boise Cascade -- St. Helens, OR
James River -- Wauna, OR
Celgar -- Castlegar, B.C.
TOTAL Source Category Allotment
X of Basin Loading Capacity
Production of
Bleached Product
(tons/day)
1,509
957
1,650
310
1.026
1.500
1.035
800
1.200
9,987

(X)
15.1
9.6
16.5
3.1
10.3
15.0
10.4
8.0
12.0
100.0

Uaste Load Allocations
(mg 2,3,7,8-TCDD/day, long term average)
Option 1
(0.68)
1.03
0.65
1.12
0.21
0.70
0.19
0.70
> 0.54
0.82
5.96
100X
Option 2
(0.257)
0.39
0.25
0.42
0.08
0.26
0.19
0.27
0.21
0.31
2.38
40X
Option 3
(0.042)
0.06
0.04
0.07
0.01
0.04
0.06
0.04
0.03
0.05
0.40
7X
Option 4
(0.00)
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
ox
  Note:  a)  The value shown parenthetically under each option represents the equivalent quantity of
          2,3,7,8-TCDD discharged in /tg per ton of bleached pulp produced.

       b)  The ULA listed for Pope & Talbot under Options 1 and 2 has been adjusted to the long term
          average of 0.19 ing/day identified in the NPDES permit issued by the Oregon Department of
          Environmental Quality (November 7, 1990).  See discussion in "Watershed Targets" section.

       c)  The ULAs listed for Celgar are included for comparison purposes only. EPA has no authority to
          establish enforceable ULAs for a Canadian source.
       All available information has been carefully considered.  Based on that
information the "zero discharge" option is not necessary to achieve water quality
standards and would not be enforceable due to the fact that the analytical detection
limit is significantly higher than zero. Option 3 has similar difficulties, especially with
respect to measuring compliance. This leaves Options 1 and 2 as still reasonable.
The existence of other sources (see below), the lack of information on processes
affecting the distribution of 2,3,7,8-TCDD, and the concern over the potential release
from 2,3,7,8-TCDD stored in sediments  and aquatic biota make Option 1 inappropriate.
Consequently, Option 2 is the most reasonable approach at this time and the WLAs
listed under that option are being established as final in this TMDL.  EPA has
concluded that these WLAs are the lowest  levels consonant with analytical practicalities
at this time and, as discussed below, can be accommodated within the available
loading capacity taking into account other existing sources.  NPDES permits issued
subsequent to this TMDL must  be consistent with these waste load allocations.

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Final TMDL for Dioxin Discharges to the Columbia Basin	3-10


      EPA recognizes that, as NPDES permits are developed, some adjustment of the
above WLAs to reflect differences in particular mill capabilities may be appropriate.
Such adjustments, if needed, will be determined on a case-by-case basis in
consultation with the affected states.
Estimated Loadings From Other Sources

      There is insufficient information, at this time, to establish WLAs for other point
sources or LAs for nonpoint sources. However, in order to be reasonably certain that
total loadings under this TMDL will not exceed the loading capacity of the system,
loadings from some of the most significant other source categories are evaluated in
Appendix B and summarized below.

      Canada:

      The Celgar pulp mill is the only Canadian source of dioxin to the Columbia River
for which 2,3,7,8-TCDD has been measured in the effluent. As pointed out in the
previous section, however, EPA has no authority to establish an enforceable WLA for
the Celgar pulp mill in Canada.  In this TMDL, EPA estimates that 2,3,7,8-TCDD
loadings from sources upstream of the U.S.-Canada border will be no more than the
0.31 mg/day which we would allocate to Celgar if it were a Region 10 mill (Table 3-2,
Option 2).  Since Celgar is expected to reduce its  2,3,7,8-TCDD loadings to
0.05 mg/day by 1994, the higher 0.31 mg/day estimate provides  some room to cover
other unidentified sources upstream of the U.S.-Canada border and/or a margin of
safety for the possibility that Celgar may not fully achieve anticipated reductions in its
2,3,7,8-TCDD loading to the Columbia River.

      Other U.S. Point Sources:

      As detailed in Appendix B, woodtreating facilities and municipal wastewater
treatment plants are estimated, in total, to contribute current loadings of less than
2.3 mg/day 2,3,7,8-TCDD. Establishing WLAs for these facilities is not feasible at this
time due to the shortage of data. Recent Resource Conservation and Recovery Act
(RCRA) regulations for woodtreaters and NPDES regulations and  guidance for
stormwater discharges will lead to better information and control of discharges from
these sources in the future. WLAs will be established, if appropriate, for those point
source discharges with existing NPDES permits when information becomes available.

      Other Sources and Background:

      The remaining 22% of the loading  capacity  (1.29 mg/day) will be held in reserve
as part of the needed margin of safety. This will cover contributions from (1) nonpoint
sources such as agricultural or atmospheric inputs, (2) other industrial sources such
as non-chlorine bleaching pulp mills, (3) background levels of 2,3,7,8-TCDD stored in
the sediments  and aquatic biota, and (4) possible future growth.

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Final TMDL for D/'ox/n Discharges to the Columbia Basin	3-tj


Data Collection

      The establishment of this TMDL is not the conclusion of EPA's efforts with
respect to controlling dioxin in the Columbia River basin.  A more comprehensive data
collection program is planned to confirm assumptions made in the development of this
TMDL Monitoring efforts will be designed to obtain better baseline information and to
fill recognized data gaps, particularly with respect to other potential sources of
2,3,7,8-TCDD and the role of sediments. If necessary, the TMDL will be revised based
on new information.

      EPA will work cooperatively with the states to take the following actions:1

      •   Develop a strategy to address water quality concerns related to
          2,3,7,8-TCDD inputs from woodtreating facilities. The proposed strategy
          should identify individual sources in each state to be considered for
          allocations, a sampling plan for determining reductions needed, and  a
          schedule for implementation of the strategy. This should be done in
          conjunction with activities required by  NPDES regulations as implemented
          under recent guidance for controlling stormwater discharges.

      •   Address other point source concerns, such as other major industrial NPDES
          dischargers and major municipal NPDES facilities with formal pretreatment
          programs, by States forwarding to EPA existing state data on
          concentrations of dioxin in sludge.

      •   Develop a strategy that addresses the other source categories  such  as
          urban runoff and agriculture.
      F.    Judicial Review

      Parties seeking to challenge this TMDL are advised that exclusive review of this
TMDL might be in the United States Court of Appeals because arguments could be
made that this TMDL includes "effluent limitations" or is part of a determination as to a
State permit program, or is inextricably bound to the issuance or denial of NPDES
permits.  If that is the case, any petition for such review would have to be filed within
120 days of EPA's action in establishing the TMDL, as described in 40 CFR
Section 23.2.
      This information collection is exempt from the Paperwork Reduction Act because it is being
      sought from fewer than 10 sources.

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Final TMDL for Dtoadn Discharges to the Columbia Basin
4.    SUMMARY

      Although certain types of data are currently lacking, available information
highlights several concerns. Concentrations of 2,3,7,8-TCDD in fish tissue in several
areas of the Columbia River basin exceed levels protective of human health  at the 10~6
risk level and indicate that the state water quality standards are currently being
exceeded. Regional and national data strongly suggest that pulp mills which use
chlorine to bleach are the most significant sources of 2,3,7,8-TCDD to surface waters.
Direct measurements of effluent samples taken from chlorine-bleaching pulp mills in
the Columbia River basin confirms 2,3,7,8-TCDD levels requiring control.

      There is a remaining need to refine information on contributions from  other
potential sources such as woodtreaters, as well as to describe the effect of attenuation
and the role of sediments.  This TMDL reserves a portion of the calculated loading
capacity as unallocated because of this need for information.  The TMDL established
herein for 2,3,7,8-TCDD discharges to the Columbia River Basin completes the
following actions:


    • Establishes waste load allocations to  individual pulp mills which  use chlorine
      bleaching, at this time. Use equal mass discharge per unit production
      (Table 3-2, Option 2) to allocate waste loads to individual pulp mills in that
      source category. NPDES permit limits for these pulp mills must be consistent
      with this TMDL

    • Estimates  loading from Columbia River sources upstream from the U.S.-
      Canada border. The total loading reserved for this source category is
      0.31 mg/day. By 1994 the Celgar pulp mill, is expected to reduce its
      contribution to approximately 0.05 mg/day. The remainder of the 0.31 mg/day
      is reserved as a margin of safety to cover other unidentified sources upstream
      of the U.S.-Canada border and/or a shortfall by Celgar in achieving anticipated
      reductions.

    • Estimates loading from some Region  10 point sources other than the pulp mills
      for which WLAs were established. Appendix B describes the evidence
      suggesting a total 2,3,7,8-TCDD loading from these sources of less than
      2.3 mg/day.

    • Reserves the remaining loading capacity (1.29 mg/day, after subtracting the
      WLAs and estimated loadings for the sources identified above) for (1) other
      undesignated sources, (2) an additional margin of safety to account for
      uncertainties in the assumptions  used in developing this TMDL,  and (3) future
      growth. This reserved portion is equal to approximately 22% of the total loading
      capacity.  As uncertainties are reduced, more of the reserved capacity could  be
      allocated to new or existing sources.

Table 4-1  and Figure 4-1 summarize the overall structure of the Final TMDL  with the
allocations based on currently available information.

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Final TMDL for Dloxin Discharges to the Columbia Basin
4-2
         Table 4-1.    Waste Load Allocations for Chlorine-Bleaching Pulp
                      Mills in Context of Watershed Targets
LOADING CAPACITY FOR ENTIRE COLUMBIA RIVER BASIN
Columbia River Basin above Washington/Canada border
Watershed target
Estimated Canadian Loading including Celgar mill
Snake River Basin above Ice Harbor Dam
Watershed target
Pulp Mi 1 1 ULAs: Potlatch (Lewiston, ID)
Willamette River Basin above confluence with Columbia R.
Watershed target
Pulp Mill WLAs: Pope & Talbot (Halsey, OR)
Remainder of Columbia R. Basin
Pulp Mill WLAs: Boise Cascade (Wallula, WA)
James River (Camas, WA)
Longview Fibre (Longview, WA)
Weyerhaeuser (Longview, WA)
Boise Cascade (St. Helens, OR)
James River (Wauna, OR)
TOTAL
SUM OF WLAs FOR REGION X PULP HILLS IN BASIN
2.3.7.8-TCDD (mg/d)
Loading
WLA Capacity
5.97
2.31
[0.31] '
1.18
0.39
0.54
0.192
0.25
0.42
0.08
0.26
0.27
0.21
1.49
2.07
1 This is not a WLA, but is included for purposes of comparison with the WLAs for U.S. mills.
2 This is the same WLA identified in ODEQ's NPDES permit (issued 11/7/90) for this facility.
i
         Figure 4-1.   Overall Division of Columbia River Basin Loading Capacity
                                     RESERVED (Unallocated)
                               °»>ersources
          WASTE LOAD ALLOCATIONS

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Final TMDL for Dioxin Discharges to the Columbia Basin	        A-1


APPENDIX A.      LOADING CAPACITY
      Waste load allocations (WLAs) for point sources and load allocations (LAs) for
nonpoint sources represent the allocated portions of a receiving water's loading
capacity. The loading capacity is the greatest amount of loading that the river can
receive without violating water quality standards. A TMDL must not exceed the loading
capacity of a waterbody. To determine the appropriate loading capacity available for
allocation requires:


   •  the water quality standard applicable to 2,3,7,8-TCDD and the Columbia River
      basin.


   •  the river flows used to calculate the loading capacity of the Columbia River
      basin at key locations.
      1.    Applicable Water Quality Standards

      The pollutant of concern for this TMDL, 2,3,7,8-TCDD, is the most toxic of a
group of compounds known as polychlorinated dibenzo-para-dioxins. These
compounds are produced as a result of human activities such as the manufacture of
chlorinated herbicides, the combustion of domestic and industrial wastes, and the
production of chlorine-bleached pulp.

      Oregon, Washington, and Idaho have adopted water quality standards for toxic
substances which apply to parts of the Columbia River basin including the Snake and
Willamette Rivers. Because the purpose of this TMDL is to provide a framework for
attaining all applicable water quality standards for dioxin, this multi-state TMDL must be
protective of the waters with the most stringent of those standards. A brief description
of individual state standards follows.

      Oregon has adopted a numeric criterion for  2,3,7,8-TCDD.  Oregon
Administrative Rules (OAR) Chapter 340, Division 41  summarizes water  quality criteria
for toxic substances applicable to all basins. This includes the Columbia River from its
mouth to river mile 309 and the Willamette River from its mouth to river mile 187. OAR
340-41-205(p)(B), for example, states:

      "Levels of toxic substances shall not exceed the most recent criteria
      values for organic and inorganic pollutants established by EPA and
      published in Quality Criteria for Water (1986).  A list of the criteria is
      presented in Table 20."
The ambient water concentration listed in Table 20 for protection of human health from
carcinogenic effects caused by 2,3,7,8-TCDD is 0.000013 ng/L, or 0.013 parts per
quadrillion (ppq). This value represents the 1CT8 risk level, the concentration at which a
lifetime exposure results in a probability of one excess cancer case per one million
people.  It considers the consumption of contaminated water as well as fish or other
aquatic organisms.

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Final TMDL for Dioxin Discharges to the Columbia Basin	A-2


      Washington has identified the Columbia River from the mouth to river mile (RM)
596.6 as a Class A waterbody and from RM 596.6 to the Canadian border (RM 745) as
a Class AA waterbody.  Washington has also identified the Snake River from the mouth
to RM 176.1 as a Class A waterbody.  Washington's rules which apply to toxic
substances  are found in WAC 173-201-047. The narrative part of the  rule indicates
that:
      'Toxic substances shall not be introduced above natural background
      levels in waters of the state which may adversely affect characteristic
      water uses, cause acute or chronic conditions to the aquatic biota, or
      adversely affect public health"

WAC 173-201-047 also states that appropriate concentrations for toxic substances in
Washington are to be determined in consideration with EPA's Quality Criteria for
Water (1986). In the process of developing its lists of degraded waters as required by
s 304(1) of the Clean Water Act, Washington interpreted its standard for 2,3,7,8-TCDD in
a manner consistent with Oregon's  numeric standard, i.e. 0.013 ppq of 2,3,7,8-TCDD
as an ambient water concentration needed to protect human health.

      Idaho has narrative standards which are intended to protect the beneficial uses
of its waters including the Snake River.  The standard, found in IDAPA 16.01.2200,
states:

      "As a result of man-caused point or nonpoint source discharge, waters of
      the State must not contain: 01. Hazardous materials ... in concentrations
      found to be of public health significance or to adversely affect designated
      or protected beneficial uses.  02.  Deleterious materials ...in
      concentrations that impair designated or protected beneficial uses
      without being hazardous."

In the process of developing Idaho's s 304(1) short list, EPA interpreted this standard
also in a manner consistent with Oregon's numeric standard.

      As stated above, this TMDL has been developed to achieve attainment  of the
water quality standards of all affected states. Although the wording  of the applicable
state standards for Idaho, Oregon, and Washington differs, EPA has interpreted these
standards as being equally stringent.  Even if this is not the case, however,
2,3,7,8-TCDD loading to upstream segments still must be restricted  to levels ensuring
the attainment of water quality standards applying to downstream segments.1  Where
this document refers to "the standard" or "the criterion" for 2,3,7,8-TCDD, this means
the 0.013 ppq criterion at the 1CT6 risk level and,  by  implication, the assumptions which
form the basis of that criterion as established by EPA. That criterion, adopted by the
State of Oregon, is the controlling water quality standard which this TMDL protects.
         The Superior Court of Washington for Thurston County recently found that the manner in
         which the State applied their water quality standards to the listing under §304(1) of three pulp
         and paper mills was invalid. EPA believes that this decision does not affect the use of
         0.013 ppq as the water quality standard for dioxin in developing this TMDL because all waste
         load allocations and permit limits must ensure compliance with applicable water quality
         standards of downstream states [40 CFR § 122.4(d)].  Oregon's water quality standard is
         clearly stated as being 0.013 ppq for 2,3,7,8,-TCDD.

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Final TMDL for Dioxtn Discharges to the Columbia Basin
A-3
      2.     River Flow:

      The loading capacity of a stream is determined using the water quality criteria
value and a design flow for the receiving water. Typically, loads are expressed as
chemical mass per time such as pounds per day.  In the case of 2,3,7,8-TCDD, loads
have been expressed as milligrams (mg) per day and are calculated as follows:

        Load (mg/day)  =  0.00245 *  Concentration (ppq) *  Flow (cfs)

The 0.00245 is the factor needed to convert the units of parts per quadrillion (ppq) and
cubic feet per second (cfs) to milligrams per day (mg/day)

      The design flow significantly affects the determination of the loading capacity.
The choice of design flow used to calculate the loading capacity for the Columbia River
basin was based on the  characteristics of the 2,3,7,8-TCDD water quality criterion.
That criterion, 0.013 ppq 2,3,7,8-TCDD, is based on human health concerns over a
lifetime. In order to address human health concerns, the harmonic mean flow is
recommended as the appropriate stream design flow (Draft Technical  Support
Document for Water Quality-based Toxics Control,  U.S. Environmental Protection
Agency, 1990).

      The harmonic mean flow was used to develop this TMDL because it provides a
more reasonable estimate than the arithmetic mean to represent long-term average
river flow. Flood periods in naturally flowing rivers  bias the arithmetic mean above
flows typically measured. This overstates available dilution.  The calculation of the
harmonic mean, however, dampens the effect of peak flows. As a result, the bias is
reduced. The harmonic  mean is also an appropriate conservative estimate of long-
term average flow in highly regulated river basins, such as the Columbia. In a
regulated river basin, the harmonic mean and the arithmetic average are often much
closer numerically.

      Table A-1 summarizes the loading capacity for 2,3,7,8-TCDD in the Columbia
River system at several key locations. A long-term flow record must be used in order
to minimize the effect of either droughts or wet years.  It is also important to  recognize
the effect that reservoirs  have had on flows in the Columbia basin. Many of the major
dams were constructed before  1950. Thus, flow records used to determine the
loading capacity in the Columbia River were those  reported by the U.S. Geological
Survey from 1950 to present.
        Table A-1. Loading Capacity for 2,3,7,8-TCDD in the Columbia River
Gage
12399500
12472800
U019200
14105700
14144700
14222880
14246900
Location
Columbia River at International Boundary
Columbia River below Priest Rapids
Columbia River at McNary Dam
Colunbia River at The Dalles
Colunbia River at Vancouver
Columbia River at Columbia City
Columbia River below Long view
Drainage
Area
(sq.mi.)
59,700
96,000
214,000
237,000
241,000
254,000
256,900
Harmonic
Mean Flow
(cfs)
72,700
95,100
143,000
152,000
159,000
180,000
188,000
Loading
Capacity
(mg/day)
2.31
3.03
4.54
4.83
5.04
5.73
5.97

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Final TMDL for O/ox/n Discharges to the Columbia Basin
A-4
      Flows at three locations on the Columbia River were estimated because of
inadequate long-term records. These locations are at Vancouver (gage #14144700),
at Columbia City (gage #14222880), and below Longview (gage #14246900). The
estimates were based on gaged flows from tributary rivers for the corresponding
segments. Average flow yield from the tributaries for a particular segment was used to
estimate flow from the ungaged portion of that segment. These gaged tributaries are
listed in Table A-2.
   Table A-2.  Loading Capacity for 2,3,7,8-TCDD in the Columbia River Tributaries
Gage
13343500
13353000
14113000
14120000
14123500
14125500
14128500
14142500
14143500
14166000
14211720
14220500
14222500
14223500
14243000
Location
Snake River near Clanks ton
Snake River below Ice Harbor Dam
Klickitat River near Pitt
Hood River near Hood River
White Salmon River near Underwood
Little White Salmon River near Cook
Wind River near Carson
Sandy River below Bull Run River
Washougal River near Washougal
Willamette River at Harrisburg
Willamette River at Portland
Lewis River near Ariel
East Fork Lewis River near Heisson
Kalama River near Kalama
Cowlitz River at Castle Rock
Drainage
Area
(sq.mi.)
103,200
108,500
1,297
279
386
134
225
436
108
3,420
11,100
731
125
198
2,238
Harmonic
Mean Flow
(cfs)
35,700
37,000
1,207
612
951
317
514
1,009
234
7,600
17,100
2,396
196
618
5,721
Loading
Capacity
(mg/day)
1.14
1.18
0.04
0.02
0.03
0.01
0.02
0.03
0.01
0.24
0.54
0.08
0.01
0.02
0.18

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Final TMDL for Dloxin Discharges to the Columbia Basin
B-1
APPENDIX B.  ALLOCATION ISSUES

      In determining appropriate allocation methods for the Columbia, several
concerns have been identified that affect decisions on the TMDL.  Issues identified
which were considered in developing allocations for 2,3,7,8-TCDD to the Columbia
River include:

        •   Loading from the British Columbia pulp mill

        •   Loading from other potential sources such as woodtreaters

        •   Fate, transport, and attenuation

        •   Role of bottom sediments  (cumulative effects and resuspension)

        •   Framework for addressing future allocations  (both growth within the
            pulp industry and allocations to other source categories)


      1.    British Columbia Pulp Mill

      Celgar Pulp Company operates a bleached kraft pulp mill located in Castlegar,
British Columbia.  Wastewater from this mill is discharged to the Columbia River
approximately 30 miles upstream from the United States - Canada border (Figure B-1).
Studies conducted by Canadians have shown elevated concentrations of 2,3,7,8-TCDD
in lake whitefish collected below the Celgar  mill (Mah et a/.,  1989;  EVS, 1990).  In
addition, follow-up analyses by the Washington Department of Ecology of fish from
Lake Roosevelt found elevated levels of TCDD and TCDF (Johnson, 1990). Lake
Roosevelt is the impoundment formed by Grand Coulee Dam on the Columbia River
downstream from the Celgar mill. Because of concern over the amounts of TCDD and
TCDF detected in fish tissue, the Washington Department of Health took action in
August  1990. A health advisory was issued that children under age four and under 40
pounds should not eat whitefish from Lake Roosevelt. Subsequent sampling by the
Washington Department of Ecology suggests that concentrations of 2,3,7,8-TCDD may
also be elevated in sturgeon as well.
             Figure B-1.  Location of Celgar Pulp Co.  (Castlegar, B.C.)
                                           .CELGAR
                                           (CuUec«r. EC.)
                                           BOISE CASCADE
                                           (Wallula)

                                           POTLATCH CORPORATION
                                           (LewiiUm)

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Final TMDL for Dioxin Discharges to the Columbia Basin
B-2
      The discovery of elevated levels of dioxins and furans below Celgar and other
British Columbia pulp mills resulted in action by the Canadian government. New
regulations under the Canadian Environmental Protection Act (CEPA) have been
proposed to regulate the discharge of chlorinated organics.  The Canadian federal
government is proposing limits of non-detectable amounts of dioxins and furans by
January 1994. In addition, the Province of British Columbia (B.C. Environment) has
adopted regulations to control adsorbable organic halides (AOX) discharged from
bleached kraft pulp mills.  The control of AOX requires reductions in the use of chlorine
which, in turn, decreases the formation of dioxins and furans. The new regulations
require that, by  1993, AOX be limited to 2.5 kg per metric tonne of pulp produced.

      Over the  past decade, the B.C. Ministry of Environment has been trying to get
various owners  of the Celgar pulp mill to resolve water pollution problems caused by
their failure to meet waste permit requirements. The identification of chlorinated
organics as a health issue has resulted in increased urgency on the part of the
Canadians to install pulping technology and effluent treatment works to resolve
problems. To meet these government requirements, Celgar has proposed a mill
modernization effort.

      The most recent measurements of effluent quality discharged by the Celgar mill
were obtained during the Canadian Pulp and Paper Association survey (CPPA, 1990).
Information on present and projected levels of 2,3,7,8-TCDD and -TCDF have been
provided by Celgar.  These are summarized in Table B-1.  The load measured in early
1990 from the Celgar pulp mill is less than 1.37 mg/day.  Since this survey, the  mill
has made several improvements that were designed to further reduce dioxin and furan
levels in the effluent.  Results of the follow-up sampling will be available later this year.
The amount of 2,3,7,8-TCDD measured from the Celgar  mill in the 1990 survey is
significantly less than the loading capacity of 2.3 mg/day for the Columbia River at the
International  Boundary. This does not consider other potential sources upstream  of
the border. However, no  other sources have been identified where 2,3,7,8-TCDD  has
been detected.
        Table B-1.  Concentrations of TCDD and TCDF from Celgar Pulp

CPPA 1990 Survey
Projected after modernization
(from bleach plant)
2,3,7
Concentration
(ppq)
ND (14)

,8-TCDO
Load
(mg/day)
< 1.37
< 0.0485
2,3.7
Concentration
(ppq)
310

,8-TCDF
Load
(mg/day)
30.4
< 0.0485

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Final TMDL for Dioxln Discharges to the Columbia Basin	B-3


      Celgar is also seeking government approval to increase the mill's production
from 560 to 1200 air dried metric tonnes of pulp per day.  B.C. Environment recently
completed  public hearings regarding the  proposed Celgar pulp mill expansion project.
Modifications to the mill's production process are being proposed which include
oxygen delignification, 70% substitution of chlorine dioxide for chlorine, and hydrogen
peroxide bleaching followed by primary and secondary effluent treatment.  The
improvements to the Celgar mill are expected to be in place by 1994.  Concentrations
of TCDD and TCDF in the bleach plant effluent are expected to be below detection
limits of 10 ppq.  Maximum daily discharges after modernization are expected to be
<0.05 mg/day for TCDD and <0.05 mg/day for TCDF (Celgar, 1990). Recognizing
problems in the past, B.C. Ministry of the Environment has stated that: "Either Celgar
will have to significantly upgrade pollution control technology in their existing mill to
achieve compliance or they will face heavy penalties for breaking the law."

       Several of the U.S. mills criticized the proposed TMDL (June 15,1990) for a
perceived lack of equity with Canada. The final TMDL estimates a loading of
0.31 mg/day from Celgar. This is equal to the loading which would be allocated to
Celgar if it were a mill  in Region 10. This accounts for Celgar's planned production
after modernization (see Table 3-2) and applies a factor of 0.257 ^g/day of
2,3,7,8-TCDD discharged per ton of bleached  pulp.  This is the same factor used to
calculate the WLAs for the Region 10 mills. This  is not a WLA but rather an estimated
loading.  This estimate provides a margin of safety to cover other unidentified sources
in Canada  and/or a possible shortfall in Celgar's attainment of the projected
0.05 mg/day loading.  As additional information is assembled, this preliminary estimate
may be refined.
      2.    Other Potential Sources

      The development of the TMDL needs to consider all potential sources of
2,3,7,8-TCDD in the Columbia drainage.  Besides chlorine bleaching pulp mills, other
potential source categories include woodtreaters, major municipal wastewater
treatment plants, agricultural areas, industrial sites, and urban areas. Table B-2
summarizes potential sources of TCDD in the Columbia, the type of available
information on loading rates, and median fish tissue concentrations from the National
Bioaccumulation Study (NBS) associated with the source category. The NBS was
conducted as a screening investigation to determine the prevalence of selected
bioaccumulative pollutants in fish.  One of the study objectives was also to identify
general correlations between fish tissue concentrations and sources of these
pollutants.

      The NBS results, listed in Table B-2, clearly indicate that the highest levels of
TCDD contamination in fish were found in areas below chlorine bleaching pulp mills.
However, two other site categories from the NBS in the Columbia basin which were
not immediately below pulp mills had elevated levels of TCDD in fish.  Both sites are
located in the north Portland area. One of the sites, Columbia Slough, is affected by
nonpoint sources,  predominantly urban runoff and a landfill.  The other site is located
below a major woodtreating operation (McCormick & Baxter) which uses
pentachlorophenol (PCP). TCDD contamination  has been associated with PCP.

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Final TMDL for D/ox/n Discharges to the Columbia Basin
                                           B-4
        Table B-2.  Potential Sources of 2,3,7,8-TCDD in the Columbia Basin
       Source Category
   Availability of
       Data
        for
     Region 10
                                                             National Bioaccumulation
                                                            Study Comparative Results
                                                                (from draft report)
                                                               Median Cone, (ppt)
    Chlorine Bleaching Pulp & Paper
    Non-Chlorine Bleaching Pulp & Paper
    Superfund Sites
    Woodtreaters, Incinerators, etc.
    Other Industrial Sites

    Urban Areas
    Municipal Wastewater Treatment Plants
    Agricultural Areas
    Other Sites
    104 mill study
        N/A
Remedial Investigations
     TRI , DMR
        N/A

        N/A
 Sewage Sludge Survey
        N/A
        N/A
4.73
1.30
1.47
1.39
1.27

1.27
0.64
0.56
0.63
                                      Note:   N/A - Not Available
                                             TRI - Toxics Release Inventory  (PCP)
                                             DMR - NPDES Discharge Monitoring Reports
                                        (PCP)
Woodtreaters:
       A number of current and former wood treatment facilities exist in the Columbia
River basin where pentachlorophenol (PCP) has been used as a preservative. A
potential source of 2,3,7,8-TCDD from woodtreating facilities is contaminated PCP.
Thirteen sites near former or existing woodpreserving facilities were sampled during
the National Bioaccumulation Study. The median 2,3,7,8-TCDD concentration in fish
tissue at these sites was 1.39 ppt (compared to 4.73 for the chlorine bleaching pulp
mills). Of the thirteen sites sampled nationally near woodtreaters, only one was in the
Columbia River basin: the Willamette River at Portland (below McCormick & Baxter).
Three species of aquatic organisms were sampled at that site with the following
results:
                         Species

                    Largemouth Bass
                    Sucker
                    Crayfish
       2.3.7.8-TCDD


          0.74  ppt
          2.22  ppt
          2.61  ppt
The values for this site are higher than the median for the NBS. However, organisms
collected from this location are also influenced by other potential sources of 2,3,7,8-
TCDD, such as urban runoff.

      These measured values reflect the need to evaluate information on the potential
discharge of 2,3,7,8-TCDD from woodtreating facilities.  EPA has recently developed a
data system which contains information from the Toxics Release Inventory (TRI).  A
retrieval of reported releases of PCP for 1987 identifies seven facilities (woodtreaters) in
the Columbia  Basin  (Table B-3). Five of these facilities are located in the Willamette
drainage.  Although the TRI information does not contain data on TCDD, the indicated
releases of PCP lead to concern over woodtreaters, particularly in the Willamette basin.
DMR data and inspection reports describing PCP discharges are also available for

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Final TMDL for Dioxin Discharges to the Columbia Basin
B-5
several woodpreserving facilities with NPDES permits in the Columbia basin.
      Table B-3.  POP Discharges from Columbia Basin Woodtreating Facilities
Cataloging
Unit
17010214
17010214
17010216
17010305
17020003
17020003
17040201
17040219
17050114
17050114
17070105
17080001
17080001
17080001
17080003
17090001
17090003
17090003
17090008
17090010
17090010
17090012
Facility Name
B.J. Carney
L.D. McFarland
Poles, Inc.
B.J. Carney Industries, Inc.
Chewelah Log and Post
Col vl lie Post and Pole
Garland Pole Co.
Penta Post
Pressure Treated Timber
Roundy Pole Fence Co.
J.H. Baxter & Co.
All weather Wood Treaters
Exterior Wood. Inc.
Pacific Wood Treating
International Paper Co.
Jasper Wood Treating
J.H. Baxter & Co.
L.D. McFarland
Taylor Lumber & Treating
Dant & Russell
Permapost
HcCormick & Baxter
Location
Sandpolnt, ID
Sandpoint, ID
Oldtown, ID
Spokane. WA
Chewelah, WA
Colvllle, WA
Idaho Falls, ID
Goodlng, ID
Boise, ID
Eagle, ID
The Dalles, OR
Washougal. WA
Washougal, WA
Ridgefield, WA
Long view, WA
Jasper, OR
Eugene, OR
Eugene, OR
Sheridan, OR
North Plains. OR
Hillsboro, OR
Portland, OR
NPDES
DHR
Data







I/R
X
X
o
X
TRI Data (Ibs.
1987
(Water) (Total)
C 1.850






250 2,300
250 1,250
250 1,500
250 13,488
0 250
31 6.999
PCP released)
1988
(Water) (Total)
C 500



C 7


B 1,500
200 202
B 750
B 2,150
150 154
    Notes   TRI data for releases of PCP to:  Water (discharge)
                                   Total (includes water, air and land disposal)
            B  : 1 - 499 Ibs.
            C  : No discharge to water identified         X   :  Loads calculated for PCP
           I/R : Inspection Report                    o   :  Only PCP concentration reported
      The preamble to a proposed RCRA rule relating to the wood preserving industry
(53 FR 53292, December 30,1988) describes ranges of chlorinated dibenzodioxin and
chlorinated dibenzofuran as well as PCP concentrations in wastewaters from
woodtreating facilities.  Thus, an estimate of potential 2,3,7,8-TCDD releases from
woodtreating facilities can be made based on data on PCP discharges. The TRI data
were considered in estimating TCDD wastewater releases from woodtreaters.
However, there are some apparent problems.  Several facilities, for instance, reported
zero discharge to water while others reported the same value of 250 pounds.  DMR
data, on the other hand, appear to provide better information on PCP discharges.
Applying assumed ratios of 2,3,7,8-TCDD per unit PCP (derived from Table 7,
53 FR 53292) to the DMR data, EPA estimates that 1 - 2 mg/day 2,3,7,8-TCDD could
be originating from woodtreating operations in the Columbia basin. This estimate
includes the potential release from facilities where no DMR or TRI data exists.

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Final TMDL for Dioxin Discharges to the Columbia Basin
B-6
      Levels of 2,3,7,8-TCDD observed in fish and sediments below one major
woodtreating operation plus estimates of potential loads point to the need for
additional data. Any allocation scheme used to develop the TMDL must leave room
for these facilities. Using available information, a  range of 1 - 2 mg/day appears to be
a reasonable estimate.  However, this estimate is preliminary and data are still being
generated.  As additional information is assembled, this estimate may be refined. Most
of the released 2,3,7,8-TCDD is associated with site run-off during rainfall. Thus, the
loading from woodtreaters could be reduced by implementing stormwater controls.
Municipal Wastewater Treatment Facilities:

      National data demonstrate that the sludges removed from some municipal
wastewater treatment plants contain dioxins and furans. Generally, octa-chlorinated
forms predominate the dioxins found in these sludges, although 2,3,7,8-TCDD has also
been detected.  Where sludges are contaminated, the wastewater discharges could
also contain 2,3,7,8-TCDD. Testing performed for 2,3,7,8-TCDD in sludge nationally
included five municipal wastewater treatment plants in the Columbia  basin ("National
Sewage-Sludge Survey Facility Analytical Results", U.S. Environmental Protection
Agency, 1989).  Results for these five facilities are listed in Table B-4.
            Table B-4.  Columbia Basin Sludge Testing for 2,3,7,8-TCDD
Cataloging
Unit

17050114

17080001

17090005
17090006

17090012


17060306
17070101
17080001
17080003
17080003
17080003

17080003

17090003
Facility Name
Municioal WWTP's
West Boise STP

Columbia Blvd. STP

Stayton STP
Lebanon STP
" "
Tryon Creek STP

Chlorine Bl . Mills
Potlatch Corp.
Boise Cascade
James River
Boise Cascade
Long view Fibre
Weyerhaeuser

James River
" "
Pope & Talbot
Location

Boise, ID
" "
Portland, OR

Stayton, OR
Lebanon, OR
it it
Lake Oswego, OR


Lewiston, ID
Wallula. WA
Camas, WA
St. Helens, OR
Long view, WA
Long view, WA
" "
Wauna, OR
»i ii
Halsey, OR
2,3,7,8-TCDD Detection
(ng/kg) Limit

ND ( 4.7)
ND ( 6.1)
ND (16.0)
ND ( 8.9)
ND (23.0)
3.3
2.2
ND (57.0)
ND (43.0)

78.0
70.0
12.0
4.2
69.0
25.0
35.0
19.0 (pri.)
89.0 (sec.)
31.0

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Final TMDL for O/ox/n Discharges to the Columbia Basin
B-7
      Of the five municipal facilities whose sludges were examined in the Columbia
basin, only one had detectable levels of 2,3,7,8-TCDD. This indicates that the TMDL
should leave some room for potential allocations to municipal sewage treatment plants.
Analytical results for this treatment plant, however, show that the detected
concentration was at levels much lower than sludge tested at chlorine bleaching pulp
mills (Table B-4). Thus, it can be expected that load estimates for municipal facilities
will be much lower than the loads allocated to the pulp mills based on the sludge data.

      Initial estimates of 2,3,7,8-TCDD discharged from municipal wastewater
treatment facilities can be made using available data.  Permitted total suspended solids
for each facility and an assumed average 2,3,7,8-TCDD concentration in municipal
sludge form the basis of these calculations.  The analysis also assumes that
chlorinated dioxins / furans found in municipal sludge are associated with effluent
solids at the same concentrations.  The average 2,3,7,8-TCDD concentration detected
was 2.8 ng/kg.  The permitted total suspended solids load from Region 10 municipal
wastewater treatment plants in the Columbia Basin is over 170,000 pounds per day.
Based on this information, these municipal wastewater treatment facilities could, as a
group, contribute an average of 0.2 mg/day 2,3,7,8-TCDD.  As additional information is
assembled, this preliminary estimate may be refined.
Other Industrial Sources:

      Non-chlorine bleaching pulp mills (Table B-5) and other potential industrial
sources also need to be considered in the allocation process.  No data has been
presented on 2,3,7,8-TCDD concentrations in either wastewater or sludges for
Columbia basin non-chlorine bleaching pulp mills.  Another potential industrial source
of 2,3,7,8-TCDD is Rhone-Poulenc, located in north Portland. This plant has produced
chlorophenolic herbicides since 1956.  The facility discharges boiler blowdown, cooling
water, site runoff, and treated groundwater to the Willamette River (across from
McCormick & Baxter).  The effluent is known to contain chlorinated phenols, although
2,3,7,8-TCDD was not detected during a National Dioxin Study.
        Table B-5. Non Chlorine Bleaching Pulp Mills in the Columbia Basin
Cataloging
Unit
17010305
17080001
17090003
17090004
17090007
17090012
17090012
Facility
Inland Empire Paper Co.
Boise Cascade Corp.
Willamette Industries
Weyerhaeuser
Snurfit Newsprint
James River II
Smurfit Newsprint
Location
Spokane, WA
Vancouver, WA
Albany, OR
Springfield, OR
Newberg, OR
West Linn, OR
Oregon City, OR
      An estimate of loadings from these sources cannot be determined at this time.
With respect to non-chlorine bleaching pulp mills, an analysis cannot be conducted
because no data has been identified which describes 2,3,7,8-TCDD in either effluents

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Final TMDL for Dioxin Discharges to the Columbia Basin	B-8


or sludges. As to Rhone-Poulenc, available data from the National Dioxin Study
showed non-detect for 2,3,7,8-TCDD. However, the detection limits were higher than
present day limits.  As additional information is gathered, it will be possible to estimate
loadings from these sources.


      3.    Fate. Transport, and Attenuation

      Losses of 2,3,7,8-TCDD in the water column can occur through sedimentation
(see discussion in next section), photolysis, and volatilization, as well as through
uptake by aquatic organisms. 2,3,7,8-TCDD's structural properties, laboratory
bioconcentration experiments, and field observations also indicate a strong potential
for bioaccumulation.  Thus, the role of these processes needs to be expressed in
terms of potential bioavailability.  Limited information exists which can be used to
provide initial estimates on the effects of fate, transport and attenuation in the
Columbia River system.  Readily available,  quality data  have been considered. This
includes information from the Northwest Pulp & Paper Association's Columbia River
Fish Study (1989), from EPA's National Bioaccumulation Study (1987), from the
Washington Department of Ecology's work on Lake Roosevelt (1989-90), and from
efforts in Canada.

      Several approaches exist to evaluate the effects  of fate, transport, and
attenuation. Water quality models, using a variety  of assumptions, can be used to
assess ambient data and to evaluate the need for additional controls.  Available
analytical tools range from simple estimates to complex data-intensive dynamic
models. Analyses can include a loss rate which considers potential adsorption of
TCDD on  particulate matter within the water column. The potential release of TCDD
from the sediment to the overlying water or the potential effect of sediment bound
TCDD on  the benthic and aquatic life food  chain must also be considered. However,
quantitative predications of bioaccumulation for specific cases and regulatory actions
are complicated by many uncertainties.  These uncertainties include the degree of
partitioning between dissolved and bound  phases, definition of the food chain  structure
plus bioenergetic parameters, and the relative importance of other fate and transport
phenomena.

      The Clean Water Act specifically states that  TMDL's shall be established with a
margin of safety which takes into account any lack of knowledge. Based on the lack
of knowledge concerning attenuation of TCDD in the Columbia River basin,
assumptions must be made with respect to attenuation in determining the loading
capacity of the system and allocations of that capacity.  A review of comments
received on the proposed TMDL did not provide conclusive evidence that net
attenuation occurs.  Although TCDD may be lost to the sediments, that loss may only
be temporary because of resuspension, desorption, or biological uptake directly from
the sediments.

      Figure B-2 superimposes predicted  fish tissue concentration data on a graph of
the actual (measured) fish tissue data plotted in Figure 2-1 in  Section 2 of this
document. Water column concentrations of 2,3,7,8-TCDD were modeled based on
(1) the results of TCDD sampling in source effluents (the "104-Mill Study), (2) receiving

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Final TMDL for Dioxln Discharges to the Columbia Basin
                                         8-9
water dilution calculated from the harmonic mean flows at the discharge points, and
(3) an assumption of no net attenuation. Predicted fish tissue concentrations were
then calculated using a bioconcentration factor of 5,000 (the factor used in developing
the water quality criterion).  As in Figure 2-1, all fish tissue concentrations (both
measured and predicted) are displayed in terms of estimated cancer risk based on the
factors used to calculate EPA's water quality criterion for 2,3,7,8-TCDD.  Both the 1CT6
and 1GT4  risk levels are identified. The 10"' risk level corresponds to the 0.013 ppq
ambient 2,3,7,8-TCDD  concentration which is the basis of the TMDL, while 10T4
represents a level of possible concern due to non-cancer effects. Note that the line
plotted between data predicted based on an assumption of no net attenuation closely
follows the data points based on directly measured fish tissue concentrations.
                  Figure B-2. Columbia River Fish Tissue: TCDD
          -2
          -3 -
          -4
                                        Concern due to Non-cancer Effects
                                  A A.
          -5 -
                           D D
          -6
                       A
                       A
                       A
                                         BasIs for Load i ng Capac i ty
          -7 -
          -8
                           200
     400

Fliver M! le
           104-miI I study load
       600


Actual  fish tissue
                                                                       800
      Based on the comparison in Figure B-2 of predicted tissue concentrations with
observed values, an assumption of no net attenuation appears to be reasonable.
Thus, for purposes of developing this TMDL, all 2,3,7,8-TCDD discharged is assumed
to remain in the water column and remain biologically available.  Because this is a
conservative assumption, this TMDL should lead to the attainment of water quality
standards regardless of the actual level of attenuation. If future studies quantify a net
attenuation rate, allocations can be modified to reflect this. This capacity could be
used to provide an increased margin of safety to account for unknown sources,
increase allocations for existing sources, or accommodate future growth needs.  By
the same token, if studies indicate that TCDD releases from historical accumulations in

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Final TMDL lor Dioxin Discharges to the Columbia Basin
                                                                B-10
the sediments constitute a problem, tighter controls may be needed (see discussion in
following section).
      4.    Role of Bottom Sediments

      Sediment concentrations are the result of a complex series of interactions
between TCDD, the overlying water column, solids, aquatic organisms, and the
external loading of TCDD. Because of the hydrophobic nature of dioxin, there is a
tendency for TCDD to move from the water column to the sediments and aquatic
biota. Although attenuation may result in a net loss of TCDD from the water column,
the potential also exists for the sediments to act as a source of dioxin through the
release of TCDD which has accumulated (Figure B-3).
   Figure B-3.  Exchange of TCDD Between Water Column, Sediments, and Biota
                                                        Bioconcentration
                              Water
                             Column
                         Desorption

                      Resuspension
      Sediments
  Partitioning

Deposition
                                 Release

                                 Uptake

                             Bioaccumulation
      Some fraction of the TCDD which enters a river is quickly associated with solids.
The adsorption of TCDD to paniculate matter may ultimately determine levels in fish
tissue.  There are a number of different theories about the role of equilibrium
partitioning and bioaccumulation from contaminated sediments. The fate of TCDD in
the aquatic environment is increasingly being discussed in terms of food chain
mechanisms. Dioxins are believed to be adsorbed to bacteria, fungi, and organic
sediment particles.  These particles are eaten by filter-feeding benthic invertebrates
which in turn are consumed by fish.

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Final TMDL for Dioxin Discharges to the Columbia Basin      	           	B-11
      In addition, solids tend to settle to the bottom of the receiving water. In areas
where the river is not filling in, these particles (and the TCDD associated with them) will
continue to be carried downstream as either bedload or resuspended sediments.  In
areas of sediment accretion, typically  where river velocities are diminished, TCDD will
tend to accumulate in the bottom sediments where it may be available to aquatic
organisms.  Resuspension of sediments either through high streamflows, boat traffic,
or dredging activities must also be considered.

      Current knowledge of the Columbia system is not adequate to determine the
availability of TCDD associated with paniculate matter to benthic organisms or fish on
a basin-wide basis. Existing sediment concentrations probably reflect a combination of
both current and historical discharges of TCDD.  Because the Region's pulp mills have
implemented some process changes  recently, such as the use of different defoamers,
it is unlikely that existing sediment contamination levels are in equilibrium  with current
loadings to the basin. Also, if desorption of dioxin occurs slowly, it may take several
years to observe the effect of reduced discharges in sediments and in biota.

      Limited sediment sampling for  dioxin has been done in the Columbia system.
Data collected in the mainstem Columbia River below Bonneville Dam have not
detected 2,3,7,8-TCDD. However, current detection limits may be  above  the level of
concern considering the low organic content of the sediments analyzed.  TCDD has
been detected in Willamette River sediments below a woodtreating operation.  These
spatial differences  reflect both physical characteristics and the influence of specific
sources. Thus, future studies on the  effect of sediments should address  site-specific
concerns.

      Given these conditions it would not be appropriate to assume a permanent loss
of 2,3,7,8-TCDD through sedimentation.  Indeed, a portion of the loading  capacity
should remain unallocated to account for potential release from the sediments and
from TCDD currently stored in the food chain. As indicated in the discussion on
attenuation, tighter controls will be needed if data show that the cumulative effects of
historical discharges significantly delay attainment of TCDD standards under the
reduced loadings required by this TMDL
      5.    Future Allocations

      TMDLs may provide a framework for dealing with future allocations.  Examples
include the assignment of any unallocated portion of the loading capacity to specific
point or nonpoint sources. Future growth of the pulp industry in the Columbia River
basin, either expansion of existing mills or new mills, is a possibility which should be
considered in this TMDL.

      Developing an equitable framework for future allocations is not an easy task.
This TMDL reserves a portion of the loading capacity as unallocated for 2,3,7,8-TCDD
to account for uncertainties and to provide for future growth. As uncertainties are
reduced, the amount held back can be made available to other sources or for
additional future growth.  Decisions on the  use of the unallocated load will be made on

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Final TMDL for Dioxin Discharges to the Columbia Basin	B-12


a case-by-case basis by EPA in consultation with the affected States.  If proposed
projects are not consistent with this TMDL, a revised TMDL would need to be
established before the proposed increased loadings could be allowed.

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Final TMDL for Dloxln Discharges to the Columbia Basin                                  C-1
APPENDIX C.  WASTE LOAD ALLOCATION METHODS CONSIDERED
      In developing the proposed TMDL, several alternative waste load allocation
methods were considered for allocating portions of the loading capacity to chlorine
bleaching pulp mills. These alternatives were presented in the Decision Document for
the proposed TMDL to illustrate the effect of assumptions made on resulting WLAs and
to stimulate public consideration of the pros and cons of alternative allocation
scenarios. Included in the presentation of options was one preferred alternative.

      There was no information received during the public comment period which has
caused EPA to change its decision about the preferred allocation method (Option 4,
Table C-2). Two additional options were suggested, however. These were:
(1) allocate the entire loading capacity to the bleaching pulp mills, and (2) require zero
discharge of dioxin from the pulp mills.  The first suggestion is clearly inappropriate
since other sources, which are presently difficult to control, would cause the loading
capacity of the system to be exceeded. Appendix B includes  additional discussion and
estimates of sources other than chlorine bleaching pulp mills which supports the
likelihood of this exceedence. The zero discharge option is also further discussed in
this document and in the response to comments. Zero discharge is not necessary in
order to meet water quality standards for dioxin in the Columbia River basin.

      For the convenience of the public, the discussion of options contained in the
Decision Document for the proposed TMDL is repeated here.  The alternative
approaches considered fall into several different categories which include:
             Equal Effluent Concentrations

             Equal Mass Discharge per Unit Production

             Equal Percent Reduction
Equal Effluent Concentrations:


      One allocation option is to set an equal effluent concentration for each pulp mill
which uses chlorine bleaching.  The resultant cumulative load is the portion of the
loading capacity allocated to chlorine bleaching pulp mills located in EPA Region 10.
Some margin of safety is then provided by the difference between the loading capacity
and the WLAs to the chlorine bleaching pulp mills in the Columbia basin of Region 10.
The unallocated amount depends directly on the effluent concentration selected.

      A starting point is to  look at a long term average effluent limit of 10 ppq (the
current general method detection limit) at each mill. This limit is initially applied at the

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Final TMDL for Dioxin Discharges to the Columbia Basin	g-2


point of discharge. Total plant effluent flows are used as a basis to calculate loads.
Discharge monitoring report (DMR) data have been summarized and includes average
effluent discharge rates.

      Using a long term average effluent limit of 10 ppq applied at the point of
discharge and current estimates of monthly average flow at each mill, the cumulative
load from all the mills equals 11.7 mg/day (Table B-1). This is greater than the
loading capacity of 5.97 mg/day.  Consequently, this option must be rejected because
water quality standards would not be met under conservative assumptions, such as no
attenuation. In addition, this would not account for any 2,3,7,8-TCDD from other
sources. Thus, more restrictive controls are needed.

      A permit condition set at a level below the general analytical detection limit
creates a situation where it is difficult, if not impossible, to determine compliance.
Because dioxins and other chlorinated organic compounds are produced in the bleach
plant, concentrations of 2,3,7,8-TCDD are higher in the combined bleach plant flow
than in the total plant effluent.  This means that waste load allocations which result in
total plant effluent concentration limits that are below the general analytical detection
limit could be monitored for compliance by measuring concentrations  in the combined
bleach plant waste stream.  Using estimates of bleach plant flows and a long term
average limit of 10 ppq in the combined bleach plant flow, the cumulative load is
3.7 mg/day or approximately 62 percent of the total loading capacity  (Table B-1).
Although this option yields a cumulative load from chlorine bleaching pulp mills which
is less than the loading capacity, several concerns exist:


       •     there is very little room for allocations to other potential sources, such as
            woodtreaters or the mill in British  Columbia (estimates described in
            Appendix B indicate current loadings from other sources would exceed
            the unallocated portion of the loading capacity)

       •     there would be no margin of safety

      •     future growth in the pulp & paper industry is not addressed

      For these reasons, the possibility of yet lower effluent limits was evaluated. This
was accomplished by setting a "maximum" concentration of 10 ppq, rather than using
a long term average of 10 ppq. To understand how this results in a lower allocation,
the relationship between the waste load allocation (WLA) and the actual permit limits
must be examined.  In certain cases, permit  limits will be different than WLA values.
Because the criteria for 2,3,7,8-TCDD is set to protect human health, the loading
capacity (and WLAs) reflect a long term average.  It is important to consider how the
WLAs address variability in effluent quality. Permit limits are set at the upper bounds of
acceptable performance and are values not to  be exceeded.  Requirements are usually
expressed using two types of permit limits, either daily maximum or monthly average.
Procedures have been developed for computing monthly average permit limits from
long term average WLAs in EPA's TSD (Technical Support Document for Water
Quality-based Toxics Control", U.S. Environmental Protection Agency, 1985).

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Final TMDL for D/ox/n Discharges to the Columbia Basin
C-3
       Assuming a coefficient of variation (C.V.) of 0.6 describes the effluent variability
for 2,3,7,8-TCDD from pulp mills1 and one sample required to be taken per month, a
monthly average permit limit of 10 ppq converts to a long term average WLA value of
4.7 ppq.  Using estimates of bleach plant flows and 4.7 ppq as the long term average
concentration limit for the combined bleach plant flow, the cumulative load is
1.8 mg/day or just over 30 percent of the total loading capacity. This leaves nearly
70 percent of the  loading capacity available to cover loadings from other potential
sources.  This  approach also results in more than a 95 percent reduction in
2,3,7,8-TCDD discharged from these pulp mills when compared to estimates of current
loading based  on results of the 104 mill study.
         Table C-1.  Waste Load Allocations for Chlorine-Bleaching Pulp Mills
Production
(tons/day)
1,509
957
1,650
310
1026
1500
1,035
800
7,837
Percent
17.2
10.9
18.8
3.5
11.7
17.1
11.8
9.1
100.0
Option 1
TCOD ULA
(ma/day)
1.42
0.76
2.20
2.37
2.01
0.19
1.29
1.44
11.67
Potion 2
TCOD ULA
(mg/day)
0.71
0.14
0.87
0.23
0.57
0.19
0.64
0.36
3.72
Option 3
TCOD WLA
(mg/day)
0.33
0.06
0.41
0.11
0.27
0.19
0.30
0.17
1.84
Mill
Potlatch -- Lewiston, ID
Boise Cascade -- Uallula, UA
James River -- Cams, UA
Longview Fibre -- Longview, UA
Weyerhaeuser -- Longview, UA
Pope & Talbot -- Halsey, OR 2
Boise Cascade — St. Helens, OR
James River -- Uauna, OR
TOTAL Source Category Allotment
    Option 1:   Set Equal Long Term Average Effluent Concentration of 10 ppq
                at Point of Discharge

    Option 2:   Set Equal Long Term Average Effluent Concentration of 10 ppq
                at Bleach Plant

    Option 3:   Set Equal Long Term Average Effluent Concentration of 4.7 ppq
                at Bleach Plant
       A C.V. of 0.6 Is recommended In EPA's TSD (Technical Support Document for Water Quality-
       based Toxics Control", U.S. Environmental Protection Agency, 1985) for situations where there
       is insufficient data to estimate a C.V. for a specific pollutant from a specific industrial process. In
       the fact sheet accompanying the public notice for the draft TMDL, EPA solicited information of
       use in developing a more appropriate C.V., if available, from the public. No such information
       was provided.

       The WLAs listed for Pope & Talbot under all options have been adjusted to the long term
       average of 0.19 mg/day identified in the NPDES permit issued by the Oregon Department of
       Environmental Quality (November 7,1990).

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Final TMDL for D/ox/n Discharges to the Columbia Basin
C-4
Equal Mass Discharge per Unit Production:

      A disadvantage of equal effluent concentrations based on current flow rates is
that it may not be equitable for all mills.  A common approach for industrial permits is
to consider production levels in establishing effluent limits. To provide for more equity,
each mill could be allocated an equal amount of 2,3,7,8-TCDD for discharge per
quantity of bleached pulp produced.  One way to accomplish this is to associate
bleach plant flow rates with production quantity of bleach pulp.  In estimating bleach
plant flows, the Washington Department of Ecology used 14,470 gallons of wastewater
generated per ton of bleached pulp produced.  Applying this figure to calculate bleach
plant flows and 4.7 ppq as the long term average concentration limit for the combined
bleach plant flow, the cumulative load is 2.07 mg/day (Table B-2) or approximately
35% of the total loading capacity.
         Table C-2. Waste Load Allocations for Chorine-Bleaching Pulp Mills

             (Option 4: Set Equal Long Term Average Effluent Concentration
             of 4.7 ppq at Bleach Plant and Set Flows at 14,470 gallons / ton
             bleached pulp)
Production
(tons/day)
1,509
957
1,650
310
1026
1500
1,035
800
7,837
Percent
17.2
10.9
18.8
3.5
11.7
17.1
11.8
9.1
100.0
TCOD ULA
(mg/day)
0.39
0.25
0.42
0.08
0.26
0.19
0.27
0.21
2.07
Milt
Potlatch -- Lewi st on, ID
Boise Cascade -- Uallula, UA
James River -- Camas, UA
Longview Fibre -- Longview, UA
Weyerhaeuser -- Longview, WA
Pope & Talbot -- Hatsey, OR '
Boise Cascade -- St. Helens, OR
James River -- Uauna, OR
TOTAL Source Category Allotment
      Although this is an increase of 0.13 mg/day over that shown in Table 5-5, the
approach does address one major problem with using current bleach plant flows.  Mills
have been encouraged to recycle internal waste streams to the maximum extent
possible. One example, Boise Cascade at Wallula, practices extensive recycling.
Under the equal effluent concentration method, a mill that does a high level of
recycling receives a lower allocation.  However, a mill that does not make efficient use
of water in the bleach plant benefits from a high allocation.  This is a major reason for
relating bleach plant flows to pulp production when determining allowable loads. This
      The WLA listed for Pope & Talbot has been adjusted to the long term average of 0.19 mg/day
      identified in the NPDES permit issued by the Oregon Department of Environmental Quality
      (November 7,1990).

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Final TMDL for D/ox/n Discharges to the Columbia Basin	<>5


approach still results in more than a 95 percent reduction in 2,3,7,8-TCDD discharged
from these mills when compared to results of the 104 mill study.  Based on the
evaluation in Appendix B, this reduction, although less than obtained by Option 3, is
still sufficient to achieve total 2,3,7,8-TCDD loadings to the basin which are less than
the loading capacity.


Equal Percent Reduction:

      Another option considered is equal percent reduction for all source
categories.   Because there  is an absence of specific data for loadings of TCDD to
the Columbia, this approach can be viewed in several different ways. The first could
use information on the relative magnitude of 2,3,7,8-TCDD in fish collected below
potential sources of dioxin. Using median tissue concentrations summarized in Table
A-1 as a general indicator of these relative contributions, thirty-six percent (36%) of the
loading capacity could be attributed to chlorine bleaching pulp production. The
remaining sixty-four percent (64%) could be attributed to other sources, such as
municipal wastewater treatment plants or agricultural areas. This analysis excludes
refineries because this industry is not known to be a significant source in the Columbia
drainage. Although this approach does offer some advantages by accounting for
other source categories, there are some major drawbacks. These include:

      •      NBS was intended as a screening study and not to describe source
             category loadings

      •      fish sampled nationally were collected from streams of varying sizes and
             did not account for dilution

      •      results of NBS associated with certain source categories may also
             include other sources (i.e. a site directly below a municipal wastewater
             treatment plant may also be 30 miles below a bleached kraft pulp mill)

      Another option suggested is to use values of 2,3,7,8-TCDD measured in
Columbia River fish and the bioconcentration factor used to develop the water quality
criterion (0.013 ppq) to "back calculate" current TCDD loads.  Although it may be
possible to estimate the relative magnitude of present plus historic TCDD  loading by
looking at tissue concentrations, other factors besides a weighted average
bioconcentration factor of 5000 must be considered.  For instance, bioconcentration
factors specific to the species should be evaluated. The age  of the fish and lipid
content of the samples must also be taken into account.  The 5000 bioconcentration
factor used to develop the criterion is intended to represent the weighted  average
factor for the species mix and lipid content in the "average" American fish / shellfish
diet. The lack of species-specific bioconcentration data, as well as the difficulty in
distinguishing the effects of historic versus current loading, makes using this approach
inappropriate for this TMDL at the present time.

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                           Region 10 Fact Sheet                   February 25, 1991

                                 DIOXIN  LOADING TO  WATERS
                                IN THE COLUMBIA RIVER BASIN
BACKGROUND
The water quality of the Columbia River and segments of
the Snake and Willamette Rivers is currently considered
impaired due to concentrations of a form of dioxin. The
pollutant, 2,3,7,8-TCDD, is the most toxic of a group of
compounds known as polychlorinated dibenzo-para-
dioxins. These compounds, although occuring naturally at
very low concentrations, can be found at elevated levels as
a result of human activities such as the manufacture of
chlorinated herbicides, the combustion of domestic and
industrial wastes, and the production  of chlorine-bleached
pulp.  Concentrations of TCDD measured in fish tissue in
several areas of the Columbia River basin exceed levels
protective  of human health. Pulp mills which use chlorine to
bleach paper products have been associated with some of
the highest concentrations of TCDD in surface waters.
Information also exists quantifying levels of TCDD in
effluents from chlorine-bleaching pulp mills  in the Columbia
River basin. In order to reduce discharges of TCDD to
acceptable levels in the Columbia  River basin, additional
controls are needed on known sources.
WHAT IS A TMDL?
Section 303(d) of the Clean Water Act requires each state
(1) to identify waters for which effluent limitations normally
required are not stringent enough to attain water quality
standards and (2) to establish total maximum daily loadings
(TMDLs) on such waters for the pollutant(s) of concern.

The process of developing a TMDL involves the calculation
of the loading capacity (the amount of loading that the river
can receive without violating water quality standards) and
the allocation of allowable loads to point sources, nonpoint
sources, and background.  A TMDL, by definition, is the
sum of the individual allocations to point sources, nonpoint
sources and background. It is effectively an implementation
plan for achieving water quality standards which includes an
appropriate margin of safety which takes into account any
lack of knowledge concerning the relationship between
source concentrations and water quality.

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                        Concern about issues of equity in the multi-state basin led
                        the states of Oregon, Washington, and Idaho to request
                        that EPA establish the TMDL for dioxin in the Columbia
                        River basin as a federal action. EPA issued a public notice
                        of the proposed TMDL and solicited comments on June 14,
                        1990, pursuant to the requirements of s303(d).


THE FINAL TMDL        EPA has considered oral and written testimony received
                        during the public comment period, and is now establishing
                        a final TMDL, effective February 25, 1991, which provides a
                        framework to control dioxin discharges to the Columbia
                        River basin. The TMDL defines the loading capacity of the
                        entire basin to be about  6 milligrams of 2,3,7,8-TCDD per
                        day.  This value was derived based on an allowable
                        concentration of .013 parts per quadrillion for 2,3,7,8-TCDD
                        and the volume of water in the Columbia River.

                        Because of the vastness of the Columbia River basin and
                        the need to  ensure attainment of water quality standards for
                        TCDD at all  points, the TMDL establishes key checkpoints
                        within the system.  Loading capacities, or "watershed
                        targets," have been established for the Willamette River
                        basin (0.54 mg TCDD/day) and the Snake River basin (1.18
                        mg TCDD/day). Allocations to sources within each of those
                        watersheds  must fit within these watershed targets.

                        EPA has also established specific wasteload allocations for
                        the eight chlorine-bleaching pulp mills located in the
                        Columbia River basin in Oregon, Idaho, and Washington.
                        These allocations lead to an estimated 95% reduction in
                        dioxin discharges from these facilities relative to the levels
                        discharged in 1988. Wastewater discharge permits issued
                        by EPA and the states of Washington and Oregon must be
                        consistent with this TMDL  EPA also estimated future dioxin
                        discharges for the Celgar pulp mill in Castlegar, Canada
                        (expected to be less than 5% of the loading capacity).

                        EPA believes that other sources of dioxin exist in the
                        Columbia River basin.  In the final TMDL, EPA has identified
                        other major sources and estimated their loadings of TCDD.
                        Accordingly, the remainder of the loading capacity
                        (3.59 mg/day or 60 percent) is reserved to account for

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                       these other sources, for future growth, and as a margin of
                       safety until adequate data has been collected and evaluated
                       which either confirms the adequacy of the margin of safety
                       or supports the establishment of additional or modified
                       allocations. In order to obtain this additional data, EPA
                       expects that the states will work in cooperation with EPA to
                       develop strategies to collect the needed information. If
                       future data identifies the need to make additional
                       allocations, or to reduce any existing allocations,  a modified
                       TMDL will be established.

                       The following figure summarizes the overall structure of the
                       TMDL:
                                     RESERVED (Unallocated)
           WASTE LOAD ALLOCATIONS
PUBLIC COMMENTS
The public comment period for the proposed TMDL closed
on July 20,1990. In addition, a public hearing to discuss
the TMDL was held July 17,1990, in Vancouver,
Washington.

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A number of substantive comments were received
concerning the proposed TMDL Major revisions to the
proposed TMDL, which were based upon comments
received, were:

•  estimates of the loadings from major sources other than
   chlorine bleaching pulp mills were made to be
   reasonably sure that the final TMDL will result in the
   achievement of water quality standards.

•  an estimate of the projected loadings from the Celgar
   pulp mill in Castlegar, Canada, was incorporated into the
   TMDL (this replaced the assumption that the entire
   TCDD loading available for the Columbia River at the
   U.S.-Canada border be reserved for Canadian sources)

Other issues which were raised during public comment but
which did not result in changes to the TMDL were:

•  expanding the TMDL to include dioxins and furans other
   than 2,3,7,8-TCDD

•  estimating the attenuation or availability of TCDD in the
   sediments

•  alternative allocation approaches for the pulp mills
   (including allocations of zero for the mills, as well as
   allocation of the entire load  for the mills)

EPA has developed responses to all significant comments
received on the proposed TMDL Copies of the final TMDL
or the responses to comments can be obtained by writing
EPA Region 10, WD-139, 1200 Sixth Avenue, Seattle, WA,
98101, or calling (206) 553-1086.

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                           Response to Comments
               RESPONSE TO COMMENTS RECEIVED
            CONCERNING THE PROPOSED DIOXIN TMDL
                 FOR THE COLUMBIA RIVER BASIN

                           February 25,1990

                          Table of Contents

Subject                                                           Page

Analytical Capabilities	  2
Antibacksliding	  3
Best Available Technology (BAT)	  4
Canada 	  6
Compliance Date 	  6
Economy	  7
Endangered Species	.'	  7
General Approach 	  8
Growth	  9
Health Risk	  10
Law	  11
Losses	  14
Margin of Safety	  14
Mixing Zone	  15
Modeling Approach 	  16
Other Sources 	  17
Permit Limits  	  21
Phased Approach	  22
Production	  23
Public Participation	  24
References	  24
Research	  24
State Planning 	  25
TCDD vs TEC	  25
Watershed Approach 	  26
WLA Approach	  27
Water Quality Limited Status	  30
Water Quality Standard	  31

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                             Response to Comments
                 RESPONSE TO COMMENTS RECEIVED
             CONCERNING THE PROPOSED DIOXIN TMDL
                   FOR THE COLUMBIA RIVER BASIN
ANALYTICAL CAPABILITIES

Comment.  Several comments were received concerning the measurement of dioxin:
           who can measure it, at what levels can it be detected, can compliance
           with WLAs be reliably monitored?

Response.  Nationally there are a limited number of analytical laboratories EPA is
           aware of which are capable of reliably measuring dioxins at levels of
           approximately 10 ppq in water samples. The Weyerhaeuser laboratory at
           the Weyerhaeuser Technology Center in Federal Way, Washington, is one
           of those facilities.  Although one of the commenters supplied  a
           Weyerhaeuser Canada article referring to the Federal Way facility having a
           "mass spectrometer capable of detecting molecules of chemical
           compounds to the parts per quintillion range," Kari Doxsee (Manager of
           the Analytical Chemistry Laboratories, Weyerhaeuser Technology Center)
           has confirmed (July 25,1990) that their typical limit of detection for
           2,3,7,8-TCDD is approximately 10 parts per quadrillion (ppq).

           The limit of detection for any given sample will vary above and below the
           10 ppq level depending on the interferences present in the sample.  For
           example, Weyerhaeuser can frequently measure down to the  1 - 4 ppq
           range.  Improvements in methodology and technology should further
           reduce the limit of detection in the future.

           The TMDL provides the framework for achieving water quality standards in
           the basin by allocating permissible dioxin loadings from various sources.
           The ability to measure compliance with waste load allocations was a major
           concern during the development of this TMDL  If pulp mills exceed their
           long term average WLAs established in this TMDL, then, based on the
           assumptions made in the TMDL, individual samples from their bleached
           effluent would exceed 10 ppq 2,3,7,8-TCDD (i.e. they would contain
           measurable concentrations of 2,3,7,8-TCDD) more than 5% of the time.
           New NPDES permits for the pulp mills covered by the TMDL will specify
           effluent limits necessary to assure compliance with state water quality
           standards and must be consistent with this TMDL (see response to
           comment in "PERMIT LIMITS" section). Effluent sampling location,
           frequency,  and analytical methods are specified in the permit, as well as
           any ambient monitoring requirements.  The permittees are financially
           responsible for all monitoring required under the NPDES permits.

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                              Response to Comments
ANTIBACKSLIDING

Comment.  What are the antibacksliding effects of the TMDL?  It could be a mistake to
           start out with such a strict TMDL and find out later it wasnt necessary, but
           cant then loosen it.

Response.  The TMDL itself is a management tool which is developed from available
           information.  The TMDL may be refined as better information becomes
           available.  Thus, allocations may be adjusted as the TMDL becomes more
           refined.

           The concern expressed in this comment relates to whether the NPDES
           permit limits based on WLAs in a TMDL may be relaxed if the TMDL is
           revised to include a higher WLA. The most important provision of the
           Clean Water Act (CWA) relating to backsliding from water quality-based
           effluent limitations is Section 303(d)(4).  This section has two parts:
           paragraph (A) applies to "non-attainment waters" and paragraph (B)
           applies to "attainment waters." The reach of the Columbia River that the
           TMDL  applies to is currently considered to be a non-attainment water.

           For non-attainment waters, the statute provides that a permittee may be
           allowed to backslide from  a water quality-based effluent limitation  if certain
           conditions are met. First,  the existing permit limit being revised must be
           based  on a TMDL or  waste load allocation established under Section 303.
           Second, the revised permit limit must assure attainment of the water
           quality standard. These conditions would be met if, for example, after the
           TMDL  and waste load allocations were finalized and NPDES permit limits
           based  on the TMDL were  developed, but before all the controls were
           implemented (to bring the waterbody into the attainment category),
           contributions from one of the  sources was found to be less than
           previously estimated.  Then some other allocation(s) .and the permit limits
           based  on those allocations could be increased as long as the revised
           TMDL  would still ensure that water quality standards would be met.

           In the case where the TMDL and waste load allocations have been
           implemented, the waterbody has become an "attainment water," and
           subsequent  information shows that a less stringent TMDL would be
           adequate to meet water quality standards, waste load allocations  may still
           be relaxed if certain conditions are met.  Specifically, Section 303(d)(4)(B)
           provides for backsliding from  water quality-based permit limitations if
           revisions are consistent with the state's  approved antidegradation policy.
           In general, the national antidegradation policy states that an attained water
           cannot be degraded below the level necessary to protect waterbody uses
           that existed after 1975.  In addition, an attained water cannot be
           degraded, unless the state finds, after satisfying public participation
           procedures, that the degradation is necessary to accommodate important

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                              Response to Comments
           social or economic development. However, in this case, the water still
           cannot be degraded to below levels necessary to support propagation of
           fish, shellfish and wildlife and recreation in and on the water.  In addition,
           waters designated by states as "Outstanding National Resource Waters"
           may not under any circumstance suffer long-term degradation of water
           quality.  States are required to adopt antidegradation policies consistent
           with the Federal  policy as a part of their water quality standards.  Under
           S303(d)(4), establishment of a new TMDL based on updated information,
           and recalculation of waste load allocations, could be allowed if consistent
           with the state's antidegradation requirements.
BEST AVAILABLE TECHNOLOGY (BAT)

Comment.  There is no evidence that proposed WLAs are achievable by BAT.

Response.  Waste load allocations in a TMDL are established at levels necessary to
           ensure attainment of water quality standards.  They are not based on any
           given level of treatment technology and are developed because BAT has
           been inadequate to protect water quality [Section 303(d)]. Existing
           effluent guidelines for the pulp and paper industry do not address dioxin.
           Effluent guidelines for BAT relating to dioxin discharges from pulp mills are
           scheduled to be proposed in 1993 and become final in 1995.  At this point
           we do not know whether BAT limits based on those guidelines will be
           more or less stringent than the limits now necessary to conform with the
           TMDL  Absent promulgated effluent guidelines for dioxin from pulp mills,
           permits are to contain Best Professional Judgement (BPJ) limits reflecting
           BAT. Permit limits contain limits based on WLAs only if such limits would
           be more stringent than those based on BPJ BAT.


Comment.  100% chlorine dioxide substitution at Weyerhaeuser Longview may not
           assure compliance with the proposed WLA.

Response.  As pointed out above, the WLAs in the TMDL are established at levels to
           ensure attainment of water quality standards.  They are not based on a
           given treatment technology. Chlorine dioxide substitution is not the only
           alternative to chlorine bleaching. Other alternatives such as oxygen
           delignffication and hydrogen peroxide bleaching may be used to assist in
           the reduction of dioxin contamination in pulp mill effluents while still
           producing a white product.  It is also possible that some products
           currently bleached need not be bleached at all.

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                               Response to Comments
Comment.  Since there are alternative bleaching processes, no discharge of dioxins
           should be allowed.

Response.  EPA disagrees.  Regardless of the existence of alternative processes
           which may lead to zero dioxin discharge, WLAs established pursuant to
           CWA s303(d) need not be set at zero unless that is required to meet
           water quality standards. EPA has determined in this TMDL that water
           quality standards can be met while allowing small but definable WLAs to
           the pulp mills in the basin.


Comment.  There is no established BAT for dioxin discharges from pulp mills, so no
           defensible 303(d) listing could be made by states.

Response.  CWA Section 303(d)  requires that "each State shall identify those waters
           within its boundaries for which the effluent limitations required by section
           301(b)(1)(A) and section 301(b)(1)(B) are not stringent enough to
           implement any water quality standard applicable to such waters."

           While this section specifically provided for listing of waters under
           Section 303(d) when BPT and secondary treatment requirements are not
           stringent enough to implement water quality standards, EPA has
           interpreted the section as not requiring listing under Section 303(d)(1) if
           existing required pollution controls (including BAT requirements) are
           sufficiently stringent to implement water quality standards (50 FR 1775). In
           the absence of national effluent guidelines establishing BAT for dioxin from
           pulp mills, the relevant technology-based requirements which EPA reviews
           to determine whether a water should be listed under Section 303(d)(1) are
           the BPJ requirements in existing permits.  BAT/BPJ effluent limits in
           existing permits have failed to achieve water quality standards for 2,3,7,8-
           TCDD.  It would be too speculative to base a determination of whether
           water quality standards will be achieved based on BAT/BPJ limits or
           effluent guidelines to be developed in the future.  If these technology-
           based limits developed in the future are more stringent than the WLA-
           based limits, then those limits must be complied with and the WLAs
           established here will  have no practical effect.

           Until the effluent guidelines are revised, it is not reasonable to assume that
           technology-based limits based on the revised guideline will result in
           attainment of the water quality standards for dioxin. Based on the current
           effluent guideline development schedule, such an assumption could lead
           to the water quality standard being violated for another 5 years before
           improvements in discharge rates were even initiated. Then, after waiting
           for BAT to  be implemented, additional controls could still be needed,
           resulting in further delays.  This is contrary to the very essence of
           Section 303(d).  EPA believes that the purposes of the Act and the intent

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                              Response to Comments
           of Section 303(d) are best achieved by its interpreting that section as
           requiring TMDLs where existing required pollution controls are failing to
           meet water quality standards.
CANADA
Comment.  Several comments were received concerning the level of dioxin loading
           coming from Canada and the method we proposed to handle that loading
           in the proposed TMDL There was considerable confusion evidenced by
           comments that it was unfair that EPA was proposing to allocate
           2.3 mg/day to the Celgar pulp mill.

Response.  EPA does not have the authority to regulate dischargers  in Canada. This
           TMDL does not attempt to do so.  However, it does recognize that there
           are sources of dioxin to the Columbia River basin above  where the river
           enters Washington State.  Available data indicate that as  the river crosses
           the border it exceeds Washington's water quality standards with respect to
           2,3,7,8-TCDD based upon levels observed in Lake Roosevelt fish. This
           would mean that past upstream loadings and sediment accumulations
           exceeded the loading capacity for 2,3,7,8-TCDD of the Columbia River as
           it crosses the border into Washington State. EPA and Washington State
           are currently working with Canada to reduce those dioxin loads north of
           the border. The Celgar mill is the only source on the Canadian side for
           which confirmation of 2,3,7,8-TCDD loading to the Columbia is available.

           Both the Celgar mill and the British Columbia Ministry of  Environment have
           commented that this mill will be modernizing, resulting in  2,3,7,8-TCDD
           discharges in 1994 which  are less than 0.05 mg/day. The final TMDL
           reserves a higher loading  of 0.31 mg/day to cover Celgar.  This is not a
           WLA but rather an estimated loading. This estimate provides a margin of
           safety to cover a possible shortfall in Celgar's attainment of the projected
           0.05 mg/day loading and  other possible upstream sources. As additional
           information is assembled,  this preliminary estimate may be  refined.
COMPLIANCE DATE

Comment.  When will compliance with the TMDL be achieved?

Response.  Upon the establishment of the TMDL, the TMDL is automatically
           incorporated into the states' current water quality management plans [see
           40 CFR s 130.7(d)].  Subsequent actions, including effluent limits in NPDES
           permits, must be consistent with the TMDL [40 CFR ssl22.44(d)(1)(vii);
           122.44(d)(6); 130.12(a)]. There is no compliance  date set in the TMDL,

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                             Response to Comments
           but NPDES permits which are individual control strategies (ICSs) under
           CWA Section 304(1) must be designed to achieve compliance with
           established WLAs within three years of establishment of the ICSs. All the
           chlorine bleaching  pulp mills for which WLAs are established in this TMDL
           were listed under s304(1) and are subject to these requirements.
Comment.  The proposed TMDL will result in delayed attainment of standards beyond
           Section 304(1) deadline.

Response.  The Section 304(1) deadline for attainment of water quality standards in
           affected waters is as soon as possible but not later than three years after
           the establishment of the ICSs.  As explained above, establishment of this
           TMDL does not alter that time frame.
ECONOMY

Comment.  Several comments concerned the effect of the proposed TMDL on the NW
           economy:  that it would make region's mills uncompetitive; have a
           negative affect on balance of trade; and cause a loss of jobs.

Response.  As pointed out above, the section of the CWA which requires TMDLs is
           based solely on the need to achieve water quality standards. Economic
           considerations are not a necessary part of the process.
ENDANGERED SPECIES

Comment.  The proposed TMDL will adversely affect bald eagles & therefore violates
           Endangered Species Act. EPA has not consulted with U.S. Fish & Wildlife
           Service (USFWS) about the potential effects of the continued discharge of
           dioxins on bald eagles in the Lower Columbia River which are listed as
           "threatened" by the USFWS.

Response.  EPA has consulted with the USFWS regarding the effects on bald eagles
           of the TMDL for dioxin discharges to the Columbia River basin.  While
           USFWS suggested that EPA participate with them in further investigations
           concerning the accumulation of dioxin in Columbia River eagle eggs,  the
           USFWS concluded that there are insufficient data at this time to determine
           whether this species has been affected by past discharges of
           2,3,7,8.-TCDD, much less whether bald eagles will be affected by the
           reduced dioxin discharges allowed by the final TMDL. The USFWS
           commended  EPA's action to reduce existing discharges of dioxin to the

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                              Response to Comments
           Columbia River basin. There is insufficient information at this time to
           determine the impact of dipxin on eagles. However, it is EPA's position
           that the reduction of the existing discharges of dioxin to the system that
           should result from implementation of the TMDL will not adversely affect
           any endangered  species.  USFWS agreed with this position and did not
           indicate that any  further consultation was necessary under Section 7 of
           the Endangered Species Act with respect to issuing the TMDL
GENERAL APPROACH
Comment.  Several commenters suggested that the TMDL is overly conservative
           and/or is not based on a valid scientific analysis of the issue.

Response.  The legislation requiring TMDLs clearly anticipated that TMDLs be
           established expeditiously even in situations where there may be insufficient
           information.  This includes uncertainty with regard to sources and their
           relationship to concentrations of contaminants in the receiving water. A
           margin of safety is to be utilized to compensate for such lack of
           knowledge.  The focus of this comment was the fact that EPA did not use
           a model which predicted attenuation (losses) of dioxin from the water
           column through sedimentation. All information and methodology available,
           including evidence of attenuation, was considered in the development of
           this TMDL However, inconclusive data led EPA to make conservative
           assumptions with respect to issues such as mechanisms of loss of dioxin
           from the system. The Decision Document for the Final TMDL evaluates
           existing and modeled fish tissue data as evidence of net attenuation and
           concludes that these data support the use of a conservative model at this
           time.
Comment.  Non-CWA authorities, such as Clean Air Act, Federal Insecticide,
           Fungicide & Rodenticide Act, Resource Conservation and Recovery Act
           (RCRA), Toxic Substances Control Act, and Super-fund Amendments and
           Reauthorization Act, need to be used to control all sources.

Response.  Although this TMDL is established under the provisions of the CWA, EPA
           agrees that all applicable authorities should be utilized to reduce the
           production and  discharge of dioxins where it is demonstrated to be
           present at levels of concern.  Three wood-preserving wastes, for example,
           were listed as hazardous wastes under RCRA Subtitle C in
           November 1990. Control of nonpoint sources may also require utilization
           of state law and/or local ordinances.
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                              flesponse to Comments
Comment.  Tissue sample data in the National Bioaccumulation Study (NBS) are not
           adequate to describe relative contributions from the various sources
           studied.

Response.  EPA agrees.  The NBS is primarily useful to demonstrate the range of
           dioxin contamination present in our nation's waters and to give a first cut
           at which types of activities are typically associated with the highest levels
           observed.
Comment.  Attenuation/sedimentation will result in problems being localized in areas
           below major sources.  Therefore, developing the TMDL on basin wide
           basis is inappropriate. It would be more appropriate to rely on BAT or
           attack problems on more local basis.

Response.  EPA disagrees. A solution to the problem of dioxin contamination in the
           Columbia River basin requires that the problem be evaluated at several
           levels (local, sub-basin, and whole basin) to account for multiple sources
           in the entire basin. While it is necessary to look at localized areas of
           contamination, such as through the NPDES permitting process, it is not
           sufficient to do so in isolation.  Dioxin, due to its persistence, may be
           transported for considerable distances and has been  measured in fish
           tissue taken from  areas away from pulp mills.  The TMDL provides for an
           equitable distribution of the loading capacity throughout the basin rather
           than allowing the entire loading capacity to be allocated to any one source
           to the detriment of others.

           BAT limits based on BPJ, existing at the time the Columbia River was
           listed and approved as as303(d) water, were not adequate to attain water
           quality standards.  Whether  BPJ limits to be developed in the future, or
           limitations based on future effluent guidelines for  BAT, will be sufficient to
           attain water quality standards cannot be ascertained at this time.
GROWTH

Comments. Several comments were received relating to concerns about how future
           new sources or growth of existing sources would be handled through the
           TMDL process.

Response.  EPA believes that economic growth can be accommodated in the
           Columbia River basin through the TMDL process.  Indeed, without a plan,
           such as a TMDL, to achieve necessary reductions in dioxin loadings to the
           system, no new discharges of dioxin could be allowed.  As further
           information is developed on the existing sources, uncertainties should

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                              Response to Comments
           diminish and thereby lessen the magnitude of the margin of safety
           needed. This combination of factors may lead to further room for growth.

           Proposals for activities leading to increased dioxin loadings will need to be
           evaluated on a case-by-case basis to determine whether allowance of the
           loadings is consistent with this TMDL and the requirements of the Act.

           Assuming proposals meet water quality standards, additional factors which
           could be considered in evaluating relative priorities include the anticipated
           dioxin loading, efforts taken to minimize dioxin contaminated wastes, and
           the social/economic benefits of the proposed activity.
HEALTH RISK

Comment.  One commenter expressed concern that toxics may be responsible for a
           number of cancers among the population on Puget Island in the lower
           Columbia River.

Response.  EPA is not aware of any evidence linking the cancers described to any
           specific cause. It is a goal of the CWA and state water quality standards
           to protect human health as well as the environment from adverse impacts
           caused by contaminants in surface waters.  The applicable state water
           quality criteria and the dioxin TMDL were established to reduce risks
           associated with dioxin contamination in the Columbia River basin.
Comment.  Fish are being contaminated by dioxin; there is a disproportionate health
           risk to Indians; Indian treaties give rights to have fish to take; the federal
           trust responsibility requires protection of fish; commenters recommend
           zero dioxin discharge for WLAs for pulp mills.

Response.  EPA recognizes the increased risk to people who consume greater than
           average amounts of fish from the Columbia River system. Estimates of
           those risks were given in a draft EPA report by Cleverly and McCormick
           ("Analysis of the  Potential Populations at Risk From the Consumption of
           Freshwater Fish Caught Near Pulp Mills," April 23,1990) and follow-up
           work is in progress.  The TMDL being established for dioxin loading to the
           Columbia River basin is developed based on current state water quality
           standards. If those standards are not sufficiently protective of Indian
           health, changes in those standards should be sought. The states triennial
           review process provides one avenue for seeking such changes.  See also
           responses to previous comments relating to the zero dioxin discharge
           option.
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                              Response to Comments
Comment.  An industry sponsored study by ChemRisk (1989) confirms that there is
           no human health reason or environmental reason to require such strict
           limits. Each mill could be given WLA equivalent to 10-30 ppq in its final
           effluent without exceeding a risk of 1 in a million based on this study and
           industry modeling.

Response.  EPA Region 10 does not agree with the risk estimates provided by the
           pulp mill industry.  The goal of the TMDL is to ensure that state water
           quality standards are attained in the Columbia River system. The WLAs in
           the final TMDL, substantially lower than those which this comment
           suggests, are necessary to meet water quality standards according to
           EPA Region 10's evaluation. The Decision Document for the final TMDL
           provides the basis of EPA's determination.  See also the response for the
           comment relating to the industry sponsored study under the "OTHER
           SOURCES" heading.  Included in the administrative record for this TMDL
           is a letter dated  March 16,1990 from Laurence R. Foster (State
           Epidemiologist, Oregon Department of Human Resources, Health Division)
           to Llewellyn Matthews (Executive Director, Northwest Pulp and Paper
           Association) which summarizes several serious concerns (with which we
           concur) about the referenced study.
LAW

Comment.  The waste load allocations (WLA) in the TMDL violate Washington state
           law provision RCW 90.54.020(3)(b).

Response.  Section 303(d) of the CWA, 33 U.S.C. 1313(d), requires the states or EPA
           (upon disapproval of state submissions) to identify waters within a state's
           boundaries for which effluent limitations under Section 301(b)(1)(A),(B),
           are not stringent enough to implement water quality standards applicable
           to such waters.  Section 303(d) also requires the establishment for these
           waters of a TMDL which is necessary to implement the water quality
           standards. A TMDL establishes allowable loadings for point source
           discharges into these waters (WLA) and load allocations (LA) for nonpoint
           sources.  NPDES permits are then developed with effluent limitations,
           consistent with the WLA, which are designed to meet the water quality
           standards.

           EPA is establishing a TMDL for 2,3,7,8-TCDD in the Columbia River  for
           the states of Oregon, Idaho, and Washington.  NPDES permit limits for
           dioxin discharges to the Columbia River basin must be consistent with the
           TMDL [40 C.F.R. 122.44(d)(1)(vii)(B);  122.44(d)(6); 130.12(a)]. However,
           Sections 301(b)(1)(C) and 510 of the CWA allow the state to implement


                                     11

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                              Response to Comments
           any more stringent limits necessary to meet state requirements.

           The portion of the Washington law referred to states:

               "Notwithstanding that standards of quality established for the
               waters of the state would not be violated, wastes and other
               materials and substances shall not be allowed to enter such
               waters which will reduce the existing quality  thereof, except in
               those situations where it is clear that overriding considerations of
               the public interest will be served." (emphasis added)

           It is EPA's position that the TMDL does not violate this law for two
           reasons. The TMDL does  not authorize the discharge of dioxin to the
           Columbia River; that can only be done  in NPDES permits. These permits
           must contain water quality  based effluent limits consistent with the TMDL.
           While a permit authorizing the discharge of dioxin must be consistent with
           the TMDL, it may also be made more stringent to the extent the state
           determines that effluent limits based on the TMDL would not be sufficient
           to protect water quality standards or to implement other provisions of state
           law.  CWA s301 (b)(1)(C); S401 (a).

           Secondly, effluent limits based on the TMDL  do not reduce the existing
           water quality. The reduction of the discharge of dioxin resulting from the
           implementation of this TMDL will improve the existing quality of the waters
           not degrade it.


Comment.  One commenter challenges EPA's  authority to promulgate this TMDL
           because there is no support in the record that the affected states
           determined not to establish a TMDL for dioxin on the Columbia River.

Response.  Section 303(d)(2) of the CWA requires  EPA to either approve or
           disapprove submissions by states  regarding  the establishment of lists of
           water quality limited waters and load allocations for point source
           discharges to these waters.

           On March 21,1990, the states of Oregon, Washington, and  Idaho sent
           letters to the Director of the Water Division, EPA Region 10,  expressly
           stating that they would not establish state issued TMDL's for dioxin on the
           Columbia River and requesting that EPA establish a TMDL as a federal
           action. This was based on the states' desire for consistency and equity in
           regulating discharges to waters in the multi-state Columbia River basin.
           Based on these submissions EPA, in accordance with Section 303(d)(2),
           disapproved these submissions and established the TMDL.
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                             Response to Comments
           EPA has statutory authority to take this action. As a matter of law, under
           CWAs303(d)(2), an explicit state determination to set no TMDLs must be
           reviewed by the EPA and the EPA is required to approve or disapprove
           the submission. If EPA disapproves it must set its own TMDLs.  Certainly
           a state's decision to not act should not defeat the intent of Congress that
           TMDLs be established for waterbodies meeting the listing criteria under
           CWAs303(d).


Comment.  One commenter raised questions as to the effect of the TMDL on NPDES
           permits and the reviewability of the TMDL in a state forum challenge to the
           permit.

Response.  NPDES permit limits must be consistent with the waste load allocations in
           the TMDL Judicial review of the TMDL must be reviewed in federal court
           and EPA believes that any such review would be based on the
           administrative record. Challenges to NPDES permits must be pursued
           administratively through the agency which issued the permits. See
           discussion under "Judicial Review" in the decision document.
Comment.  The phased approach is contrary to law.

Response.  See response to comments on "Phased Approach."
Comment.  Weyerhaeuser (p. 12 of a letter dated July 20,1990) suggested "that a
           reasonable response to the data gaps in the TMDL decision document
           would be to postpone adoption of a final' TMDI	and [instead] adopt a
           set of load and waste load allocations expressly labeled as provisional for
           the purposes of permitting only.  Compliance with these provisional waste
           load allocations (if retained or as modified) would be due three years after
           permit issuance." An effective period of one year for the provisional permit
           was suggested during which  additional information would be gathered.

Response.  EPA agrees that the TMDL should be established regardless of the need
           for further information. However, the procedural mechanism suggested is
           not provided for in the CWA and EPA believes it is important that these
           dioxin controls be final agency action even if later modified.  The TMDL
           developed may be modified later if new information is obtained which
           supports revision (see also response to comment under
           "ANTIBACKSLIDING"). Further studies are planned but a commitment to
           revising the TMDL at a specific future date would be premature at this
           time.  The waste load allocations in the TMDL will be implemented through
           NPDES permits.  The compliance date for dioxin in the case of the mills
           affected  by this TMDL is dictated by Section 304(1).


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                              Response to Comments
LOSSES

Comment.  Several commenters criticized the lack of consideration of processes
           leading to loss of dioxin from the system. Others commented, however,
           that delaying regulatory action to improve knowledge of these processes
           would be inappropriate.

Response.  EPA agrees that the implementation of this TMDL should  proceed while
           further data are gathered. Appendix B of the final TMDL includes an
           expanded discussion of available information on attenuation and the
           sediments as a loading source to the river system. See also the
           responses in the "GENERAL APPROACH" section.
MARGIN OF SAFETY

Comment.  Several comments were received that the concept of a margin of safety
           needs clarification and that the margin of safety incorporated into the
           proposed TMDL was too large or too small.

Response.  Section 303(d)(1)(C) of the Clean Water Act and EPA implementing
           regulations require each state to identify waters for which existing pollution
           control requirements are not stringent enough to attain water quality
           standards applicable to such waters. Total maximum daily loads (TMDLs)
           are then to be established on such water quality limited segments for
           appropriate pollutants of concern. This provision states that the TMDL:

               "shall be established at a level necessary to
               implement the applicable water quality standards with
               seasonal variations and a margin of safety which
               takes into account any. lack of knowledge concerning
               the relationship between effluent limitations and water
               quality." (emphasis added)

           The margin of safety reflects uncertainties in the development of the
           TMDL  Such uncertainties may relate to, for example, (1) potential
           sources for which measurements of pollutant loadings are not available,
           and (2) the uncertain fate of pollutants once introduced into the
           waterbody. Conceptually it involves establishing WLAs and LAs such that,
           even if some of the assumptions made are in error, implementation of
           those allocations will still result in attainment of the water quality standard.

           The size of the margin of safety needed in, or that is actually provided by,
           a given TMDL is not easily determined and may depend to a large degree


                                      14

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                              Response to Comments
           on professional judgement.  The margin of safety is not something that
           can be precisely calculated.  For instance, using a conservative model to
           estimate pollutant transport and fate results in a cautious estimate of the
           system's loading capacity. This provides a margin of safety, but since we
           do not precisely know the "true" loading capacity we cannot quantify the
           magnitude of this component of the total margin of safety.  Similarly, the
           fact that some sources may not fully utilize their allocation provides an
           additional unquantifiable margin of safety.  In any TMDL, some margin of
           safety may be provided by establishing allocations that in total are lower
           than the defined loading capacity.

           In the final TMDL we use a conservative model to describe transport, fate
           and attenuation, thus providing part of the needed margin of safety. The
           total of the only allocations established  (the WLAs for the existing pulp
           mills in the basin) is also significantly less than the estimated loading
           capacity.  The unallocated portion of the loading capacity also provides a
           margin of safety as noted in the Decision Document.  Of course, EPA
           recognizes that there are existing sources of dioxin to the basin other than
           the chlorine bleaching pulp mills. Thus, only a fraction of the unallocated
           amount constitutes a margin of safety.  The final TMDL estimates loadings
           attributable to additional sources (woodtreaters, municipal wastewater
           treatment facilities, and Canadian sources) to demonstrate their ability to
           fit within the currently unallocated portion of the TMDL.  See also
           responses to comments in the "OTHER SOURCES" category.
MIXING ZONE

Several comments related to the relationship between the TMDL and mixing zone
policies:

Comment.  The water quality standard should be achieved at the point of discharge.
           The bioaccumulative nature of dioxin makes assumptions of dilution
           unreasonable; the TMDL will not adequately address "hot spots."
Comment.  TMDL should include analysis of compliance with mixing zone policies.
Comment.  Proposed WLAs will result in violations of standards at edge of Boise
           Cascade mixing zone and downstream for 1500 meters downstream.
Comment.  Potlatch WLA will result in violation of the water quality standard for a
           considerable distance downstream.

Response.  While effluent limits in NPDES permits need to be consistent with WLAs in
           an established TMDL, WLAs are not effluent limits. States establish mixing
           zone policies as a part of their water quality standards process. Where a
           state allowed mixing zone is less than the entire river flow, NPDES effluent
           limits may need to be more restrictive than the WLA would require. An


                                      15

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                              Response to Comments
           analysis of this issue, if appropriate, occurs as a part of the NPDES
           permitting process.

           The is no evidence in the record to support assertions of nonattainment of
           standards outside of state allowed mixing zones.  Development of
           analyses needed for such determinations would require time and money.
           In light of s304(I) and S303(d) deadlines, EPA believes it should move
           forward now, rather than duplicate efforts which the state should conduct
           during the permitting process.

           One comment was that no mixing zone should  be allowed  due to the
           bioaccumulative nature of this persistent pollutant. However, this issue
           more directly relates to the appropriateness of existing water quality
           standards of the states in which the pulp mills are located and thus is not
           addressed in the TMDL
MODELING APPROACH

Comment.  The geometric mean flow is a better measure of average dilution available
           in flow regulated systems.  This results in a loading capacity of
           0.75 mg/day vs. 0.54 mg/day used in the proposed TMDL for the
           Willamette River basin.

Response.  EPA's evaluation of available data suggests that the more conservative
           measure of the mean, the harmonic mean, more accurately represents the
           average dilution available in the river.  EPA's Draft 'Technical Support
           Document for Water Quality-based Toxics Control" (1990) recommends
           general use of the harmonic mean for this purpose. The harmonic mean
           is an appropriate estimate of long-term average flow in highly regulated
           river basins, such as the Columbia and Willamette. In a regulated river
           basin, the harmonic mean and the geometric mean are reasonably close.
           The differences suggested in the comment appear to be the  result of
           differences in the period of record used for flow data. Flow records used
           to determine the loading capacity in the Columbia Basin were those
           reported  by the U.S. Geological Survey from 1950 to present.


Comment.  The TMDL should utilize available models to reflect the flow dynamics of
           the system, as well as the transport & fate of dioxin; at the very least a
           sensitivity analysis should be done.

Response.  The more sophisticated a model is, the more information is needed to use
           it. Unfortunately, EPA does not at this time have sufficient information to
           justify using models requiring estimates of the dynamic processes referred
           to.  While some parameters could perhaps be reasonably estimated,


                                      16

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                              Response to Comments
           others (such as loading from historical deposits in the sediment) would
           need to be given such wide ranges of values that the results from such a
           model would be of negligible value. Thus, EPA has chosen to use a
           conservative approach which reflects the amount of available data.
Comment.  Less dioxin should be discharged during dry (low river flow) seasons.

Response.  The water quality standard which is the basis of the TMDL is based on the
           human health effects of a long term (70 year) exposure to dioxin through
           consumption of contaminated fish and drinking water. Seasonal variations
           in river flow are thus not of great significance.  The TMDL, therefore,
           calculates the loading capacity of the system based on harmonic mean
           flows which reflect the average dilution provided by the river.
OTHER SOURCES

Comment.  Dioxins/furans in Portland Harbor are not from the Pope & Talbot, Halsey
           Pulp Mill (based on "fingerprinting").

Response.  Region 10 acknowledges that there are likely to be sources of dioxin
           loading to the Willamette basin in addition to the Halsey mill. One such
           source may be contributions from sediments contaminated  by past
           dischargers. However, this does not reduce the need to control the
           discharges from current known sources, including the Pulp  & Talbot mill.
           It does,  however, support the acknowledged need to gather further
           information to quantify the contributions from these other sources.
Comment.  There is a clear need for additional evaluation of other sources, including
           dredging and nonpoint sources.

Response.  Region 10 agrees.  As controls on the pulp mills are being implemented,
           further information will be collected concerning other possible sources
           (see discussion on phased approach).  The Corps of Engineers is
           considering work which will evaluate the effects of dredging.
Comment.  Site specific data on sources such as woodtreaters in the Columbia basin
           are not needed to estimate the magnitude of their dioxin discharges
           relative to the unallocated portion of the total loading capacity.  National
           data can be used for this purpose.
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                              Response to Comments
Response.  Region 10 agrees that information describing loadings from similar
           activities in other locations would be useful in evaluating the potential
           magnitude of contribution from those same activities in the Columbia River
           basin.  The final TMDL uses some national data combined with small
           amounts of Regional data to estimate dioxin loadings from two additional
           source categories.

           Besides chlorine bleaching pulp mills, the source for which the best
           information exists is municipal wastewater treatment facilities.  National
           data demonstrate that the  sludges removed from some municipal plants
           contain dioxins and furans. Octa-chlorinated forms predominated the
           dioxins found in these sludges.  Presumably where sludges are
           contaminated, the wastewater discharges  (which contain suspended
           solids) would also contain  these compounds.  Of the five municipal
           facilities whose sludges were examined in  the Columbia basin only one
           had detectable levels of 2,3,7,8-TCDD.  The highest 2,3,7,8-TCDD
           concentration measured for that facility was 3.3 ng/kg. The national
           average was similar at 2.8  ng/kg. If we assume that the suspended solids
           in the effluent from the facilities in our Region also contain that
           concentration of 2,3,7,8-TCDD, a loading can be estimated based on the
           Total Suspended Solids (TSS) discharge data reported for the facilities in
           the basin.  This approach results in  an estimated loading of 0.2 mg/day
           2,3,7,8-TCDD to the entire basin from these facilities (see Appendix B of
           the Decision Document for the Final TMDL). As additional information is
           assembled, this preliminary estimate may be refined.

           Another likely source of dioxins is the woodtreating industry. We know
           that pentachlorophenol (PCP), one of the chemicals used in this industry,
           is frequently contaminated with varying amounts of dioxins. This is one of
           the source categories which we plan to study further in our efforts to
           control dioxin loadings to the Columbia R. At this time, however, we have
           no direct information on how much  dioxin from these facilities may
           ultimately be transported to surface waters. Process wastewaters from
           these sources are generally not permitted  for discharge.  The most likely
           mechanisms of transport of 2,3,7,8-TCDD  contaminated PCP are
           stormwater and subsurface flow from retention ponds near surface waters.
           PCP has been monitored,  but not limited, under NPDES permits covering
           stormwater discharges from some of these facilities. Based on that data
           and an assumed ratio of 2,3,7,8-TCDD to PCP in the discharge, it is
           estimated that 1 - 2 mg 2,3,7,8-TCDD/day could be originating from
           woodtreating operations in the Columbia River basin (see Appendix B of
           the Decision Document).

           A third potential source category is  non-chlorine bleaching pulp mills and
           other potential industrial sources. An estimate of loadings from these


                                      18

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                              Response to Comments
           sources cannot be determined at this time because no data has been
           identified which describes 2,3,7,8-TCDD in either effluents or sludges.  As
           additional information is gathered, it will be possible to estimate loadings
           from these sources. See also Appendix B of the Decision Document for
           the Final TMDL
Comment.  EPA is ignoring available information of other sources of dioxin. EPA must
           use existing data to estimate waste loads from these sources.

Response.  The public notice of the proposed TMDL specifically requested that any
           relevant information in the possession of commenters be provided. We
           have carefully reviewed the supplied information and have found little
           additional data of use in establishing WLAs for sources outside of the pulp
           mill category. However, the final TMDL estimates potential contributions
           from two additional source categories (see response above).
Comment.  Lack of dates and commitments for State and EPA action regarding
           collection of further data on other sources, indicates that the phased
           approach is a pretense.

Response.  The phased approach results from EPA's recognition that needed
           reductions in loadings from the pulp mills should not be delayed while
           gathering information on other sources.  The high expense of analyzing
           dioxins, budgetary constraints, and uncertainties relating to the results of
           future monitoring, make it difficult to predict the rate of progress in
           gathering further information and making any necessary adjustments to
           the TMDL.  (See also the response to comments in the "Phased
           Approach" category.)  EPA has developed this TMDL recognizing the
           limited information available, and has incorporated a margin of safety  into
           the analysis such that, not withstanding the current limits on information,
           water quality standards are expected to be attained.
Comment.  An industry sponsored fish study (Beak Consultants, 1989) shows higher
           fish tissue concentrations above the mills than below; other sources need
           to be accounted for.

Response.  The existence of other sources is recognized by EPA and is the reason
           that WLAs to the pulp mills were limited to less than loading capacity of
           the system. The industry sponsored study had several weaknesses in its
           design which make it difficult to draw conclusions about the relative
           significance of pulp mill discharges versus other sources of dioxin to the
           system. The most critical problem with this study was the location of
           sampling sites.  For example, the referenced study took no samples from
                                      19

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                              Response to Comments
           the reservoir above McNary Dam directly downstream of Wallula. The
           nearest downstream samples were taken from below McNary Dam.
           Based on the 104 Mill Study, however, the Boise Cascade mill at Wallula
           contributed the highest dioxin loading to the river of any mill in the Region.
           Fish from the reservoir above McNary Dam, into which this mill discharges
           its wastewater, also had some of the highest tissue concentrations of
           TCDD in the Pacific Northwest.
Comment.  The proposed TMDL does not address how much dioxin toxicrty is in the
           river system already (e.g. available from sediments), as well as loading
           from all sources.

Response.  The final TMDL has an expanded discussion of other sources of dioxin to
           the system including  bottom sediments (see Appendix B of the TMDL).


Comment.  What input might there be from pulp mill air emissions to the Columbia
           River?

Response.  Since dioxins are formed in combustion processes, one would expect
           them to be produced in the boilers at pulp mills. The Region is aware of
           the analysis of dioxins and furans in one sample of boiler fly ash (from an
           Alaskan pulp mill).  The results of that analysis showed total TCDD levels
           of -74.6 ppb; 2,3,7,8-TCDD was not analyzed separately.  Thus, although
           air emissions are likely to contain dioxins and other chlorinated organics,
           we do not know enough to estimate potential contributions to the
           Columbia River from  these air emissions. Given the probable wide
           dispersal of the air participates, only a small fraction would be expected to
           fall on water directly.  Dioxin's affinity for solids would also mean that
           direct erosion would  be required to transport dioxin contaminated solids
           settling on land to surface waters. Thus, the transport of dioxin
           contaminated pulp mill boiler emissions is probably a minor source relative
           to their direct wastewater discharges.  EPA believes that any contribution
           from this source is more than adequately covered  by the margin of safety
           built into the TMDL.
Comment.  Application of the TMDL concept to dredging and disposal activities is
           inappropriate as these activities are sufficiently regulated under Section
           404 and 401 of the CWA of 1977 and Section 103 of the Ocean Dumping
           Act of 1972.

Response.  The TMDL process should take into consideration all sources of the
           pollutant of concern.  To the extent that dredging of sediments results in
           the transfer of dioxin from those sediments to the water column, that


                                      20

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                              Response to Comments
           activity is using some of the loading capacity which is, therefore, not
           available for other users of the system. Of course, if dredging and
           disposal activities are regulated under Section 404 such that there are no
           associated discharges of dioxin, then any future TMDL would have no
           effect on these activities.

           The Corps of Engineers (COE)  recently completed analyses of TCDD in
           sediments in areas to be dredged in the Columbia River. Columbia River
           sediment had non-detect TCDD in areas with mostly sandy, silty sand, or
           sandy silt sediments. TCDD was found at two stations in the Willamette
           River in low ppt concentrations. These stations, however, also contain
           other pollutants at levels of concern, which will be considered in making
           dredging and dredged material  disposal decisions.

           The Final TMDL emphasizes the control of point source discharges of
           dioxin through NPDES permits.  While uncertainty about the release of
           dioxin from sediments contributes to the need for a significant margin of
           safety, the Final TMDL does not provide specific allocations for dredging
           activities.
Comment.  The TMDL must identify quantities assigned to WLAs, LAs, margin of
           safety, and reserve capacity.

Response.  The final TMDL identifies WLAs for chlorine bleaching pulp mills, estimates
           loadings from other sources, and leaves unallocated a portion of the
           loading capacity. As described in response to the "MARGIN OF SAFETY"
           comment, the margin of safety cannot be precisely quantified as it is
           comprised of a variety of conservative assumptions  made in estimating the
           loading capacity and evaluating contributions from the various sources as
           well as the unallocated loading capacity.
PERMIT LIMITS

Comment.  Concentration and flow limits could unfairly penalize mills that practice
           extensive recycling.

Response.  The Final TMDL includes no concentration or flow limits for pulp mills. The
           TMDL specifies allowable loadings (WLAs) for the pulp mills in the basin.
           In order to be equitable, the WLAs are proportional to quantities of
           bleached product produced. The factor (0.257 ^g/ton) used to arrive at
           the WLA was based on an assumed concentration of 2,3,7,8-TCDD
           (10 ppq maximum or 4.7 ppq long term average) and an average flow of
           14,470 gallons of wastewater discharged per ton of bleached product.  If a
                                      21

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                              Response to Comments
           mill uses extensive wastewater recycling to reduce discharge flows from
           the chlorinated wastestreams, they could have higher concentrations of
           2,3,7,8-TCDD in the discharged wastewater while still being in compliance
           with the loading limit and the WLA NPDES permits based on this TMDL
           should include dipxin load limitations consistent with the WLAs, not the
           concentration which was assumed in its derivation.
Comment.  The TMDL should be specific about how permit limits should be derived
           from WLAs and how compliance will be measured. How will below
           detection or below quantrtation limit results be handled?

Response.  The TMDL is specific in describing WLAs as a long term average loading
           limit. There are several ways in which the states could translate the WLAs
           into permit requirements. As long as the NPDES permits include limits
           consistent with the TMDL and compliance is effectively monitored, the
           states will be allowed flexibility in how they achieve that goal. WLAs have
           been established at levels such that inadequate plant performance will
           lead to individual samples having concentrations which are measurable.

Comment.  If 2,3,7,8-TCDD is the only pollutant addressed by the TMDL, polluters will
           be liable for CWA penalties for discharging other chlorinated organics.

Response.  The response to comments under the heading TEC vs TCDD" addresses
           the reasons why this TMDL focuses on 2,3,7,8-TCDD. The CWA liability of
           dischargers for various pollutants in their wastestreams is a question of
           compliance with the limits in their NPDES permit(s).
PHASED APPROACH

Comment.  Several comments were received relating to the legality, timing, and effects
           of the phased approach discussed in the proposed TMDL

Response.  It appears that the "phased approach" terminology led to considerable
           confusion.  The TMDL now being established is "final."  It reflects EPA's
           best professional judgement given the information available at this time.
           The law requires that a TMDL be established at a level which reflects
           existing uncertainties. As further information is obtained, however, the
           TMDL may also be modified or revised through the same process used to
           develop it in the first place. The levels of uncertainty involved in this TMDL
           are not insignificant. Therefore, EPA chose to not only acknowledge
           those uncertainties, but to also state its intention to actively gather
           additional data to improve our knowledge with respect to certain issues.
           There is no required time frame for this next "phase" and, given budgetary


                                     22

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                              Response to Comments
           constraints and other uncertainties, we cannot at this time predict when
           this TMDL might be revised.

           One concern expressed was whether a revised TMDL could conceivably
           result in reduced WLAs to the pulp mills.  If new information indicates that,
           contrary to our present evaluation, other uncontrollable sources of dioxin
           are more significant than the present TMDL assumed, further reductions
           would be necessary in the existing WLAs.

           Another comment was that, while this TMDL is in effect, further efforts
           should be undertaken to eliminate chlorine bleaching.  As EPA begins to
           implement its pollution prevention initiative, this would seem to be a
           possible direction for the future. However, EPA does not believe at this
           time that it is necessary to eliminate all chlorine bleaching of paper
           products to meet water quality standards.
PRODUCTION

Comment.  Weyerhaeuser Longview produces 407 tons per day (TPD) of bleached
           fine paper grades and 639 TPD of bleached paper board = 1046 TPD
           total bleached product (1026 TPD was used in proposed TMDL).

Response.  Our production estimates are based on those used by the Washington
           Department of Ecology in developing their draft permit for Weyerhaeuser
           Longview. As of August 31, 1990, Ecology was still estimating Kraft fine
           paper production at 400 TPD and 626 TPD of Kraft paperboard
           production. These are the only products listed which are bleached at the
           plant. The suggested change represents only a 2% difference and would
           need to be corroborated before it could be accepted.  No change in
           production figures is justified at this time.


Comment.  Boise Cascade, St. Helens, produces over 1100 tons/day pulp and is in
           the midst of a $400 million renovation which will increase production.

Response.  The 1035 ton/day figure used in the TMDL is  based on Oregon
           Department of Environmental Quality's draft permit dated May 25, 1990,
           for the City of St. Helens. A final  permit just issued was consistent with
           this figure. Boise Cascade has submitted no  information to revise this
           estimate and made no comment  relating to its production rates during the
           comment period.
                                     23

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                             Response to Comments
PUBLIC PARTICIPATION

Comment.  Several comments were received about the adequacy of the public
           comment process for the proposed TMDL. Those making these
           comments felt that a longer comment period was needed or that
           workshops with industry should have been held to discuss technical
           issues.

Response.  EPA and the states have been very open in the process of developing the
           proposed TMDL Both industry and environmental groups have had
           copies of earlier drafts (December 22,1989 and April 20,1990) of the
           TMDL which were very similar to the proposed version.  In fact we
           received informal comments on these drafts.  The effective comment
           period for these parties was, therefore, much longer than the formal 35
           day period held after the Public Notice on June 15,1990, and more than
           adequate in the opinion of EPA.  EPA also believes that the 35 day period
           was itself adequate in light of statutory deadlines for  Agency action on
           such matters under CWAs303(d) and s304(1).

           Although industry and others were able to provide information and
           comment to  EPA, as were all parties, we did not feel it was appropriate to
           hold workshops with industry. The only way that industry workshops
           could have served any useful function, other than that already available,
           was if EPA provided information to industry which was not publicly
           available.  That would clearly have been inappropriate.
REFERENCES

Comment.  The TMDL needs more reference information to support river flows used,
           effluent flows, TCDD data used, justification for Coefficient of Variation
           used.

Response.  The final TMDL decision document contains more complete references for
           data and assumptions used.
RESEARCH

Comment.  Additional research on sources, effects, and analytical methods should be
           done by an independent group, but funded by those who are
           contaminating public waters.

Response.  Additional research is planned by a number of entities on related subjects.


                                     24

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                              Response to Comments
           Such work will include, but not be limited to, monitoring by the pulp mills
           given WLAs in the final TMDL
STATE PLANNING

Comment.  EPA needs to clarify how the TMDL fits in with state water quality planning
           efforts.

Response.  Upon the establishment of the TMDL, it automatically becomes a part of
           the Water Quality Management Plans of the affected states. Subsequent
           NPDES permitting actions requiring state or federal approval will  need to
           be consistent with the TMDL. State water quality planning efforts will also
           need to be consistent with the TMDL.  Since the TMDL is subject to
           change as further knowledge is gained, state water quality planning efforts
           will need to react to future changes in the TMDL or, in some cases, may
           cause such changes.
TCDD VS TEC

Comment.  Several comments related to the appropriateness of regulating just
           2,3,7,8-TCDD at this time. Some thought that other organochlorines,
           including other dioxins and furans, should be covered by the TMDL.

Response.  EPA Region 10 does not believe it is appropriate to use a toxicity
           equivalency concentration (TEC) approach for including other compounds
           in the TMDL for the following reasons:

           •   2,3,7,8-TCDD is the most toxic of all dioxin and furan compounds, and
               thus is the chemical of greatest concern. Controlling 2,3,7,8-TCDD
               discharges will greatly reduce the risk posed by dioxins and furans in
               general.

           •   It is expected that actions taken to reduce 2,3,7,8-TCDD discharges
               will also reduce the production of other dioxins and furans. This is
               supported by recent information supplied by three pulp and paper
               mills in the Columbia River basin (Boise-Cascade at Wallula, Potlatch
               at Lewiston, and James River at Camas) indicating that as effluent
               concentrations of dioxins have decreased, the concentrations of
               furans have also decreased.

           •   There does not appear to be sufficient information available on other
               dioxin/furan congeners upon which to base a numeric water quality


                                     25

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                               Response to Comments
               criterion or a TMDL for TEC. For example, while relative toxicities of
               other dioxins/furans have been estimated, little is known regarding
               their tendency to be taken up and bioconcentrated in fish tissues.
               Additionally, little is known regarding whether or not other dioxins and
               furans are metabolized by fish or other organisms, which would affect
               their persistence.

               It is not clear that states intend to regulate carcinogenic substances in
               wastewater discharges at a cumulative level of one increased
               incidence of cancer for all (or a group of) chemicals.  For example, in
               Oregon's Water Quality Standards, water quality criteria for
               carcinogenic substances are set at a concentration which would result
               in one additional cancer per one million people on a chemical by
               chemical basis. Thus permit limits are generally based on a chemical
               by chemical basis using the "one in a million increased cancer risk"
               criteria.  Historically, carcinogenic substances have been regulated in
               Washington and Idaho on a chemical by chemical basis as well, rather
               than attempting to regulate for all chemicals on a cumulative basis.
               While regulation on a cumulative basis may be desirable at some
               point in the future, states must first develop methodologies for such
               actions, as well as a determination as to whether cumulative
               evaluations would be based on the same cancer risk endpoint of one
               additional cancer per million people.

               EPA also does not believe there is adequate information available at
               this time to factor PCBs, DDTs, or other related compounds into a
               single toxicity equivalency approach.
WATERSHED APPROACH

Comment.   Several people commented on the TMDL approach of evaluating the
            whole Columbia River basin and the use of watershed targets for major
            sub-basins. For the most part, commenters were supportive of this broad
            approach. One commenter, however, felt that the WLAs for the pulp mills
            were inequitable, since they constituted differing fractions of the loading
            capacity for each of the watersheds.  Another commenter thought that
            since the Willamette River basin was entirely within Oregon, that state
            should have the responsibility to allocate loadings in that basin.

Response.   It is true that the sum of the WLAs to the pulp mills in the various
            watersheds varied  as a percentage of the loading capacity for the
            watershed.  This resulted from treating each of the pulp mills equitably
            based on existing bleached pulp production.  This approach should not,
            however, give any  one state an economic advantage over others, beyond


                                       26

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                              Response to Comments
           that which accrues from having greater water volumes available for
           dilution. To the extent that existing pulp mills utilize more of the loading
           capacity in a given watershed, there will be less room for other sources or
           growth in that watershed.

           This TMDL establishes a WLA to one source on the Willamette River
           (Pope & Talbot at Halsey). However, because the Willamette Basin is
           entirely within Oregon, the Oregon Department of Environmental Quality
           has the option, within the context of a TMDL, to adjust allocations for
           specific sources which would still meet this watershed target.  See also
           discussion under "Watershed Targets" in the Decision Document.
WLA APPROACH

Comment.  The most equitable allocation method to pulp mills is that based on
           production rates.

Response.  EPA Region 10 agrees and has followed this approach.

Comment.  WLAs are inequitable since they result in differing concentration limits for
           the various pulp mills.

Response.  Since the pulp mills in the Columbia River basin differ in the efficiency with
           which they use water, WLAs cannot be established which are equitable on
           both a production rate basis and a concentration in effluent basis. Since
           the ultimate goal of the TMDL is to control mass loading to the basin, not
           the concentration in the effluent, the production basis was selected for
           establishing the WLAs for pulp mills.  Use of a concentration basis for the
           WLAs would also be counterproductive with respect to a general EPA goal
           of minimizing water usage in and pollutant discharge from industrial
           processes.
Comment.  WLAs should be based on production capacity rather than actual
           production.

Response.  Basing WLAs purely on production capacity would allow plants with
           substantial unused capacity to discharge greater amounts of dioxin per
           amount of bleached product produced than would be allowed  for mills
           operating at capacity.  This would be counter to EPA's effort to be
           equitable to the mills while establishing WLAs that will lead to attainment of
           water quality standards.  Where plans for substantial production increases
           are proposed and confirmed, however, EPA will consider changing WLAs
           on a case-by-case basis within the context of this TMDL. See  also the


                                      27

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                              Response to Comments
           response to comment in the "GROWTH" section.
Comment.  Each mill should be given WLA equivalent to 10-30 ppq in final effluent;
           this would have risk less than 1 in a million based on industry modeling.
           Process for further refinement of TMDL could be incorporated.

Response.  See response under "Health Risk."
Comment.  The allowable discharge should be based on ability to avoid discharge
           rather than receiving water's capacity.

Response.  EPA agrees that ability to avoid discharges should be considered in
           establishing effluent limits.  That is the technology-based approach to
           regulating point sources and is the goal of BAT. For the pulp mill industry
           EPA plans to promulgate in 1995  revised BAT effluent guidelines which will
           minimize the production and discharge of dioxin based upon technological
           consideration. The TMDL, in accordance with Section 303(d) of CWA, is
           required to achieve water quality standards in waters where existing
           pollution control requirements (including existing technology-based limits)
           have not been adequate to do so. (See also response under "BAT").
Comment.  Proposed WLAs will not achieve a sufficient reduction of 2,3,7,8-TCDD,
           based on fish tissue concentrations, to fit within defined loading capacity.

Response.  The water quality standard which is the basis of this TMDL is itself based
           on the health effects of 2,3,7,8-TCDD. Although the standard is expressed
           as a concentration of 0.013 ppq in the water, it is primarily based on a fish
           tissue concentration (0.07 ppt) which is predicted to cause one excess
           cancer per one million people (1CT6) who consume an assumed quantity of
           this fish over 70 years.  Thus, the 10"" risk level,  a fish concentration of
           0.07 ppt and a water concentration of 0.013 ppq are, in the context of the
           2,3,7,8-TCDD criterion,  equivalent. This comment points out the fact that
           measured dioxin levels  in fish sampled in the National Bioaccumulation
           Study in many cases exceeded the acceptable level (0.07 ppt) by a
           greater factor than that required by the TMDL as a reduction in the pulp
           mill discharges. This interpretation of the data is one which EPA was
           aware of in its development of the TMDL. It is one of the reasons that the
           agency chose to conservatively assume no net attenuation in its model of
           the system. However, the dioxin loadings the NBS fish tissue data reflect
           are not known.  They may, in fact, be the result of even higher historic
           loadings than were measured in the "104 Mill Study." EPA, therefore,
           chose not to estimate needed loading reductions based on the fish tissue
           data.


                                      28

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                              Response to Comments
Comment.  The proposed TMDL is inconsistent in that it assumes pulp mills are only
           34% of the current dioxin loading and yet a 95% reduction in loading by
           that category alone will result in meeting standards.

Response.  EPA disagrees with the interpretation of the proposed TMDL made by this
           commenter.  WLAs in the TMDL do not represent EPA's assumptions of
           existing dioxin discharges by industry, but rather an apportioning of the
           load they will be allowed to contribute in the future.  The proposed TMDL
           pointed out that there were several weaknesses in trying to use the NBS
           data to estimate relative loadings of various source categories.  EPA does
           not assume that the pulp mills have contributed 34% of the past or current
           loading to the system.  Based on currently available information, EPA
           believes that the pulp mills have contributed a higher share of the loading
           in the past and  that other sources will fit within the reserved capacity.
           However,  EPA does not now have sufficient information  to accurately
           estimate the exact fraction of the total dioxin loading to the Columbia River
           contributed by the pulp mills in the past. The final TMDL allocates
           approximately 35% of the loading capacity to chlorine bleaching pulp mills
           in the Region. If future information shows that other sources can not be
           controlled to the levels estimated in the final TMDL as adequate to cover
           their loadings, the TMDL will need to be modified. In the mean time, EPA
           believes that the requirements of the TMDL (approximately a 95%
           reduction  in pulp mill dioxin discharges relative to the year 1988) will result
           in water quality  standards being met. See response to comments on
           "Other Sources."
Comment.  Pulp mill allocations for the main part of the Columbia River (that excluding
           the Snake River, Willamette River and Canada) should not exceed 34%.


Response.  It is not clear why the commenter proposed the 34% figure as a
           maximum, but it seems to be based on either (1) the belief that pulp mills
           contribute about 34% of the current loading to the basin, or (2) that the
           proportion of the mainstem part of the Columbia allocated to pulp mills
           should not exceed the proportion of the loading capacity for the entire
           basin allocated to Region 10 pulp mills.

           (1) As pointed out in responses to other comments, although the NBS
           data might seem to indicate that pulp mills contribute approximately 34%
           of the total load, this results from an inappropriate assumption.  Region 10
           believes that in the  Columbia River Basin, pulp mills are, in fact, the most
           significant contributor of 2,3,7,8-TCDD (even after the reductions in their
           contribution they have already achieved).


                                      29

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                               Response to Comments
            (2) Although the proposed TMDL allocated about 34% of the basin loading
            capacity to Region 10 pulp mills, Canadian sources should be considered
            if one is trying to look at the industry's allocated proportion of the total
            loading capacity. Including Celgar's loading raises the total pulp mill
            contribution on a basin-wide basis to about 40% of the loading capacity.
            In any event, the fact that there is a concentration of mills along the lower
            Columbia River combined with equity of WLAs among the pulp mills, leads
            to a higher proportion of the loading capacity in that area allocated to the
            pulp mills than in other basins with fewer pulp mills.


Comment.   The proposed TMDL allocation of 34% to mills is inconsistent with 304(1)
            determination that receiving water for Longview Fibre's discharge (& other
            mills) is water quality limited "due entirely or substantially" to its discharge.

Response.   The allocation of 34% of the loading capacity to the future discharges from
            pulp mills in Region 10 does not imply that 34% is the portion of current or
            past loading contributed by those sources. Although even 34% would
            constitute a substantial proportion of the total loading, EPA believes that
            pulp mills have been responsible for a greater share in the past.
WATER QUALITY LIMITED STATUS

Comment.   No state submissions of water quality limited segments were ever made.

Response.   Since the National Bioaccumulation Study results became known, it has
            been generally acknowledged that the fish tissue concentrations indicated
            that the Columbia, Willamette, and Snake Rivers were water quality limited
            for dioxin (2,3,7,8-TCDD).  This, combined with dilution analyses of
            measured pulp mill waste concentrations, was the basis for the states
            initiating the TMDL process.  When Ecology, ODEQ, and IDEQ each
            requested that EPA Region 10 establish the TMDL as a federal action, the
            letters (dated March 21,1990) they sent each recognized "the designation
            of this river as water quality limited for dioxin ..." The 1990 Water Quality
            Assessment (Section 305(b)) reports from both Washington and Oregon
            also list the applicable portions of the Columbia, Willamette, and Snake
            Rivers as water quality limited under Section 303(d) of the Clean Water Act
            due to dioxin contamination.


Comment.   The Washington state water  quality standard is not equal to .013 ppq.

Response.   While it is true that Washington has not adopted a numeric criterion for


                                       30

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                              Response to Comments
           2,3,7,8-TCDD, it currently has what is called a "narrative standard" which
           applies to most toxic substances including dioxin. The state has
           interpreted this standard consistently with EPA's water quality criterion at
           the 1GT6  risk level in both their section 304(1) and 305(b) listing processes.
           In accordance with the EPA criteria, this corresponds to a concentration of
           0.013 ppq.  See response to previous comment.

           Furthermore, even without a narrative criterion for the state of Washington,
           EPA would have used .013 ppq as the basis for the TMDL because of the
           need to ensure that the TMDL will protect the waters of the state of
           Oregon, where the .013 ppq criterion is a part of the state's water quality
           standards. See the discussion in Appendix A of the Decision Document
           for the final TMDL
Comment.  There is no established BAT for dioxin discharges from pulp mills, so no
           defensible s303(d) listing could be made by states.

Response.  See response to comment under BAT section.
WATER QUALITY STANDARD

Comment.  Several comments were received concerning the appropriateness of the
           water quality standard for dioxin used in the development of the TMDL.

Response.  The existing state standards are the legal basis for the whole TMDL
           process.  As such, the TMDL must be designed to ensure compliance
           with those standards. Comments on the appropriateness of water quality
           standards are best addressed to the respective states for consideration in
           their triennial review process. As a regional authority, EPA  Region 10 is
           responsible for ensuring that all state water quality standards are met.  In
           the case of the Columbia River system, that means that Washington
           state's standards affect activities in Idaho. It also means that along the
           Washington-Oregon border, where water travels  back and forth between
           those states, the most stringent of the state standards must be achieved.
           As the Decision Document for the proposed TMDL explained, Oregon  has
           explicitly adopted a standard of 0.013 parts per quadrillion for
           2,3,7,8-TCDD.  Washington has a narrative standard which the
           Department of Ecology has indicated  should be interpreted as equal to
           EPA's federal criterion at the 10~6 risk level, the same as Oregon's
           standard.  (See also comment and response under "WATER QUALITY
           LIMITED STATUS" section.)
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                               Response to Comments
Comment.  Bioaccumulation factor should be 0.03 to 0.8 rather than 5,000 as used in
           EPA criterion derivation.

Response.  The bioconcentration factor of 5000 referenced in the comment was that
           used by EPA in the development of its water quality criterion for
           2,3,7,8-TCDD. This bioconcentration factor relates the concentration of
           2,3,7,8-TCDD in the water to concentrations in fish tissue.  Since the state
           of Oregon has adopted EPA's criterion in its water quality standards, and
           the states of Washington and Idaho are using EPA's criterion as the basis
           for implementing their narrative criteria for toxic substances, EPA Region
           10 must use the national criterion, and the bioconcentration factor used in
           its derivation, as the basis for the TMDL

           The commenter cites an EPA study on TCDD in Lake Ontario sediments,
           water, and fish as the basis for his comments.  However, this study used
           an approach which is different from, and not directly comparable to, that
           used in developing EPA's water quality criterion for 2,3,7,8-TCDD. The
           bioaccumulation factor (BAF) recommended by the commenter (0.03 to
           0.8) was based upon the relationship between 2,3,7,8-TCDD
           concentrations in sediments to those observed in fish tissue, rather than
           comparing water and fish tissue. In order to apply BAFs based upon
           sediment/fish tissue relationships, the concentrations of dioxin  in the
           sediments must be known, as well as the contribution of specific
           discharges to the overall 2,3,7,8-TCDD concentration in the sediments.
           This information is not available at this time. In addition, the results of the
           referenced study in Lake Ontario indicate that the study results, including
           the BAFs, are site-specific, even within Lake Ontario.  Thus it would not be
           appropriate to apply the bioaccumulation factors from that study directly to
           a system such as the Columbia River, which has very  different  dynamic
           processes than Lake Ontario.

           As a final note, the authors of the Lake Ontario study reach a very
           different conclusion from their data than does the commenter.  The study
           reports a bioaccumulation factor of 11,000  (relating the concentrations of
           TCDD in water to fish tissue) based on their laboratory studies, and a
           bioconcentration factor of 140,000 based on field results.  The  authors
           further note that "...If the laboratory BAFs are applied to best estimates of
           Lake Ontario water dioxin concentration, rather than to the laboratory
           exposure water TCDD concentrations, lake trout TCDD residues are under
           estimated by a factor of fourteen.  Since the best available models indicate
           that a large  proportion of TCDD present in  Lake Ontario water should be
           bioavailable, the reported Lake Ontario BAF of 140,000 is a reasonable
           estimate.  A Lake Ontario lake trout BAF based on the predicted dissolved
           TCDD concentration would be 180,000."
                                       32

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             PROPOSED TOTAL MAXIMUM DAILY LOAD

                                 FOR

               TCDD IN THE COLUMBIA RIVER BASIN
                         TMDL Decision Document
                              June 15, 1990
Developed pursuant to the provisions of the Clean Water Act, 33 U.S.C. §1251. et seq.
as amended by the Water Quality Act of 1987, P.L. 100-4.
                         TABLE OF CONTENTS
        1.   SCOPE  	2
            •  Water Quality Limited Segments	2
            •  Pollutant Causing Exceedance of WQ Standards ... 2
            •  Source Categories Considered	3

        2.   BACKGROUND	3
            •  Overview  	3
            •  Process	4

        3.   BOUNDARIES	5
            •  Areas of Concern	5

        4.   LOADING CAPACITY	6
            •  Water Quality Standard	7
            •  River Flow	8

        5.   ALLOCATION APPROACH 	 9
               Overview  	9
               Issues  	  10
               Development of TMDL	  14
               Wasteload Allocation Methods Considered	  19
               Proposed  Wasteload Allocation Approach  	  24
               Development of Information on Other Sources ...  25

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Proposed TMDL for Dioxin Discharges to the Columbia Basin
                   PROPOSED TOTAL MAXIMUM DAILY LOAD
                                       FOR
                     TCDD IN THE COLUMBIA RIVER BASIN


                                 Decision Document


 1.     SCOPE

       This TMDL addresses the following segments, pollutants, and source categories:


       WATER QUALITY LIMITED SEGMENTS:


          RIVER SEGMENT                          APPLICABLE WATER  QUALITY RULES:
          Columbia River   (RM   0     745)      WAC 173-201-047 1
                           (RM   0     309)      WAC 173-201-080(19)  2
                           (RM 309  -  596)      WAC 173-201-080(20)  2
                           (RM 596  -  745)      WAC 173-201-080(21)  2
                           (RM   0  -   86)      OAR 340-41-202 &  205(2) (p) 3'4
                           (RM  86  -  120)      OAR 340-41-442 &  445(2) (p) 3'4
                           (RM 120  -  147)      OAR 340-41-482 &  485(2) (p) 3'4
                           (RM 147  -  203)      OAR 340-41-522 &  525(2)(p) 3'4
                           (RM 203  -  218)      OAR 340-41-562 &  565(2) (p) 3'4
                           (RM 218  -  247)      OAR 340-41-602 &  605(2) (p) 3'4
                           (RM 247     309)      OAR 340-41-642 &  645(2) (p) 3'4
          Snake River      (RM   0     176)      WAC 173-201-047 1
                           (RM   0     176)      WAC 173-201-080(97)  2
                                                 IDAPA 16.01.2120  & .2200 s'6
          Willamette River  (RM 0     187)      OAR 340-41-442 &  445(2)(p) 3-4

           1  WAC 173-201 -(M7 describes Washington's applicable criteria for toxic substances.
           2  WAC 173-201-OSt) describes Washington's classification for specific waterbodies.
           3  OAR 340-41-xx2 describes beneficial uses designated by Oregon.
           4  OAR 340-41-xx5( 2 )(p) describes Oregon's applicable criteria for toxic substances.
           5  IDAPA 16.01.212D describes the designated uses for the confluence of the Clearwater and
             Snake River in Ul.iho.
           8  IDAPA 16.01.221X1 describes Idaho's criteria for hazardous and deleterious materials.


       POLLUTANT CAUSING EXCEEDANCE OF  WQ STANDARDS:

           2,3,7,8 - tetrachlorodibenzo-para-dioxin  (2,3,7,8-TCDD)

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Proposed TMDL for Dioxin Discharges to the Columbia Basin
       SOURCE CATEGORIES CONSIDERED:

        Source    Allocation
       Category     Type        Source Description

           1          VILA       Pulp  & Paper Mills   --   Chlorine Bleaching
           2      Reserved     All Other Sources:
                                   Pulp & Paper Mills   --  Non-Chlorine  Bleaching
                                   Municipal  Wastewater  Treatment Plants
                                   Other Point Source
                                   Port Activities
                                   Urban Areas
                                   Other Nonpoint Source
                                   Upstream Inputs


2.     BACKGROUND

                                      Overview
       The Columbia River and segments of the Snake and Willamette Rivers are
 currently water quality limited due to the presence of excessive levels of dioxin (2,3,7,8-
 TCDD).   The concern over dioxin levels in the  Columbia River is based on data
 describing concentrations of 2,3,7,8-TCDD in fish tissue below chlorine-bleaching pulp
 mills as well as in effluents and treatment plant sludges at these mills.

       Section 303(d)(l)(C) of the Clean Water Act (CWA) requires each state to
 identify waters for which technology-based effluent limitations are not stringent enough
 to attain water quality standards applicable to such waters and to establish total
 maximum  daily loads (TMDLs) on such water quality limited segments for appropriate
 pollutants  of concern. This provision states that the TMDL:

       "shall be established al a level necessary to implement the applicable water quality standards
       with seasonal variations and a margin of safety which takes  into account any lack of
       knowledge concerning the  relationship between effluent limitations and water quality."

       The TMDL is effectively an implementation plan for achieving water quality
 standards using an  appropriate margin of safety. The TMDL process defines the
 allocation  of loads  to point sources, nonpoint sources, and background.

       Oregon has  identified the Columbia River (river miles 0 - 309) and the
 Willamette River (RM 0 - 187) as being water quality limited for 2,3,7,8-TCDD.
 Washington has similarly identified the Columbia and Snake Rivers within that state as
 being water quality limited for 2,3,7,8-TCDD. The state of Idaho has also identified the
 confluence of the Clearwater and Snake Rivers  as being water quality limited for 2,3,7,8-
 TCDD. EPA has approved  these listings persuant to CWA Section 303(d).

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Proposed TMDL for Dioxin Discharges to the Columbia Basin 	4


       On March 21, 1990 the states of Oregon, Washington, and Idaho stated that they
would not adopt a TMDL for dioxin in the Columbia River as state actions but rather
requested that EPA establish this TMDL as a federal action.  The states acknowledged
that while the development of a TMDL has been a cooperative effort, the interstate
nature of the Columbia River Basin and the desirability of consistency and equity in
regulating dischargers in this basin necessitated that the TMDL be  a federal action.
Therefore, persuant to Section 303(d), EPA formally disapproved the expressed intent of
Washington, Oregon, and Idaho to not submit TMDLs and is proposing a TMDL for
dioxin in the Columbia River basin as a federal action.

       The urgency of establishing this TMDL is supported by the national focus on
toxics discharges as evidenced in the recent amendment to Section  304 of the CWA,
33 U.S.C. § 1314(1).  In 1987, Congress amended this section to focus state water quality
protection programs on immediately addressing water quality problems due to point
source discharges of toxic pollutants.  States are required to develop lists of impaired
waters, identify point sources and amounts of toxic pollutants they discharge, and to
develop individual control strategies (ICSs) for each such point source. An ICS may be
a draft or a final NPDES permit.  The §304(1) lists developed for Washington, Oregon,
and Idaho have identified dioxin levels in the Columbia, Snake, and Willamette Rivers
as exceeding water quality standards for dioxin.  Limits included in ICSs, developed
under §304(1), must be consistent with waste  load allocations (WLAs) where a TMDL
has  been established.

       This TMDL provides a framework to control dioxin discharges  to the Columbia
River Basin. The following sections of the decision document describe the proposed
TMDL and the process used to develop it.
                                       Process
       The TMDL identifies the amount of a pollutant that may be discharged to a
 water quality limited stream.  TMDLs can be expressed in terms of either chemical mass
 per time, toxicity, or other appropriate measure.  The TMDL for a particular water is
 dependent on such factors as the location of sources, streamflow, water quality
 standards, background conditions, and in-stream pollutant reactions.  The process of
 developing and implementing a TMDL for 2,3,7,8-TCDD in the Columbia River basin
 consists of several steps:


  o   define the loading capacity of the river at key points

  o   identify sources which potentially contribute loads of 2,3,7,8-TCDD

  o   allocate loads to point sources, NFS, and background

  o   implement the TMDL through WQ management plans and NPDES permits

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Proposed TMDL for Dioxin Discharges to the Columbia Basin	5


       Section 303(d) states that a margin of safety should be used which takes into
account anv lack of knowledge concerning the relationship between effluent limitations
and water quality. Thus, the  law indicates that the TMDL process should move forward
using available information.  As  new information becomes available in the future, the
TMDL can be refined.

       Two fundamental issues must be determined at the outset when establishing a
TMDL.  These are (1) the definition of upstream and downstream boundaries of the
waterbody for which the TMDL is being determined and  (2) the flow conditions (design
flow) appropriate for calculating the loading capacity or amount of pollutant which can
be assimilated.
3.     BOUNDARIES
                                 Areas of Concern
       The pollutant, 2,3,7,8-TCDD, is the most toxic of a group of compounds known as
polychlorinated dibenzo-para-dioxins.  These compounds are produced as a result of
human activities such as the manufacture of chlorinated herbicides, the combustion of
domestic and industrial wastes, and the production of chlorine-bleached pulp.  In 1987,
EPA initiated a National Bioaccumulation Study (NBS). This effort was designed to
gather screening information on the prevalence and concentrations of selected toxic
compounds in fish tissue and other aquatic organisms.  This study was conducted on a
broad scale across the United States  and included testing for 2,3,7,8-TCDD. Sampling
sites included relatively undisturbed background areas, streams below industrial,
agricultural, and urban activities, and segments below mills using chlorine  to bleach
pulp.  The National Bioaccumulation Study identified concerns related to bleached kraft
pulp mills. Fish samples collected at several locations below chlorine-bleaching pulp
mills on the Columbia River within EPA Region 10 (from the Canadian border to the
mouth) have shown detectable concentrations of 2,3,7,8-TCDD.  Another EPA study, the
"104 Mill Study," subsequently confirmed (through testing of effluents and sludges) that
chlorine-bleaching pulp mills are a significant source of 2,3,7,8-TCDD.

       Within EPA Region 10, eight  chlorine-bleaching pulp mills currently discharge to
the Columbia River system.  These mills, one in Idaho, four in Washington, and three in
Oregon, are shown in Figure 1. The eight mills currently produce over 7,000 tons per
day of bleached pulp.  Another chlorine-bleaching pulp mill which discharges to the
Columbia River is located near Castlegar, British Columbia, about 20 miles above the
U.S. - Canadian border. Known sources of 2,3,7,8-TCDD are thus affecting the
Columbia River within EPA  Region  10, from the mouth near Astoria, Oregon to the
Canadian border (river mile  745) and the Snake and Willamette Rivers, major river
basins within the Columbia River drainage basin. Consequently, the entire Columbia
River basin, including  the Snake and Willamette Rivers, are included in the proposed
TMDL.  Tributaries outside of EPA  Region 10, such as the Clark Fork in Montana,
have also been considered in developing the proposed TMDL.

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  Proposed TMDL for Dioxin Discharges to the Columbia Basin
              Figure 3-1.  Location of Region 10 Chlorine-Bleaching Pulp Mills
                               in the Columbia River Basin
                                                                 CELCAR
                                                                 (Coitlefar. B£)
JAMES RIVER
(V*ua>)
BOEK CASCADE
(St Bttan)
                                                                 POTLATCH CORPORATION
                                                                 (UwMoa)
POPE 4 TALBOT
             WEYERHAEUSER
             (UafTt««)
               LONGV1EW FIBER
   4.
LOADING CAPACITV
         By definition (40 CFR, s 130.2), a TMDL is the sum of the individual wasteload
   allocations (WLAs) for point sources and load allocations (LAs) for nonpoint sources
   and natural background.   Wl.As and LAs represent the allocated portions of a receiving
   water's loading capacity.  The loading capacity is the greatest amount of loading that the
   river can receive without violating water quality standards.  A TMDL must not exceed
   the loading capacity of a waterbody.  To determine the appropriate loading capacity
   available for  allocation requires the following information:

         •   the water quality standard applicable to 2,3,7,8-TCDD and the Columbia
             River basin.

         •   the river flows  used to calculate the loading capacity of the Columbia River
             basin at key locations.

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Proposed TMDL for Dioxin Discharges to the Columbia Basin	7


       A.  Water Quality Standard

       Oregon, Washington, and Idaho have adopted water quality standards for toxic
substances which apply to parts of the Columbia River basin including the Snake and
Willamette Rivers.  Since the purpose of this TMDL is to provide a framework for
attaining all applicable water quality standards for dioxin, this multi-state TMDL must
be protective of the waters with the most stringent of those standards. A brief
description of the individual state standards follows.

       Oregon has adopted numeric criteria for 2,3,7,8-TCDD. Table 20 of Oregon
Administrative Rules (OAR) Chapter 340,  Division 41 summarizes water quality criteria
for toxic substances applicable to all basins. This includes the Columbia River from its
mouth to river mile 309 and the Willamette River from its mouth to river mile 187.
The concentration for 2,3,7,8-TCDD listed  in Table 20 is based on EPA's Quality
Criteria for Water (1986).  For 2,3,7,8-TCDD, the criterion identified is 0.000013 ng/L,
or 0.013 parts per quadrillion (ppq).  This value represents an ambient water
concentration needed to protect human health. It considers the consumption of both
contaminated water as well as fish or other aquatic organisms. The criterion adopted by
Oregon is based on the 10~6 risk level, the  concentration at which a  lifetime exposure
results in a probability of one excess cancer case per one  million people.

       Washington has identified the Columbia River from the mouth to river mile 596.6
as a Class A waterbody and from river mile 596.6 to the Canadian border (RM 745) as
a Class AA waterbody.  Washington has also identified the Snake River from the mouth
to river mile 176.1 as a Class A waterbody. Washington's rules which apply to toxic
substances are found in WAC 173-201-047.  The narrative part of the rule indicates that:

       Toxic substances shall noi be introduced above natural background levels in waters of the
       state which may adversely affect characteristic water uses, cause acute or chronic conditions
       to the aquatic biota, or adversely affect public health"

WAC 173-201-047 also states that appropriate concentrations for toxic substances in
Washington are to be determined in consideration with EPA's Quality Criteria for
Water (1986).  In the process of developing its §304(1)  short list, Washington interpreted
its standard in a manner consistent with Oregon's numeric standard, i.e. 0.013 ppq of
2,3,7,8-TCDD as an ambient water concentration needed  to protect  human health.

       Idaho has narrative >tandards which are intended to protect the beneficial uses of
its waters including the Snake River.  The  standard at IDAPA 16.01.2200 states:

       "As a result of man-cauM.il point or nonpoint source discharge, waters of the State must not
       contain: 01.  Hazardous materials ... in concentrations found to be of public health
       significance or to advcr•*.-!> affect designated or protected beneficial uses. 02. Deleterious
       materials ... in concentration;* that impair designated or protected beneficial uses without
       being hazardous."

In the process of approving Idaho's §304(1) short list, EPA interpreted this standard in a
manner consistent with Oregon's numeric standard, i.e. 0.013  ppq of 2,3,7,8-TCDD as an
ambient water concentration needed to protect human  health.

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Proposed TMDL for Dioxin Discharges to the Columbia Basin	8


       As stated above, this  TMDL has been developed to achieve attainment of the
water quality standards of all affected states.  Although the wording of the applicable
state standards for Idaho, Oregon, and Washington differs, EPA has interpreted these
standards as being equally stringent. Even if this had not been the case, however,
2,3,7,8-TCDD loading to upstream segments would still need to be restricted to levels
ensuring the attainment of water quality standards applying to downstream segments.


       B. River Flow

       The loading capacity  of a stream is determined using the water quality criteria
value and a design flow for  the receiving water. Typically, loads are expressed as
chemical mass per time such as pounds per day. In the case of 2,3,7,8-TCDD,  loads
have been expressed as milligrams (mg) per day which are calculated as follows:

         Load (mg/day)   =   0.00245 *  Concentration  (ppq)  *  Flow (cfs)

The 0.00245 is the factor needed to convert the units of parts per quadrillion (ppq) and
cubic feet per second (cfs) to milligrams per day (mg/day)

       The  design flow significantly affects the determination of the loading capacity.
The river flow used to  calculate the loading capacity focuses on the rationale behind the
development of the criteria  for 2,3,7,8-TCDD. The water quality criteria for 2,3,7,8-
TCDD, 0.013 ppq, is based  on human health  concerns. In the case of design flows for
human health protection, the harmonic mean flow rather than the arithmetic mean flow
has been recommended as the basis for TMDLs due to the fact that the it better reflects
average  available dilution ("Draft Technical Support Document for Water Quality-based
Toxics Control",  U.S. Environmental Protection Agency, 1990). Table  1 summarizes the
loading capacity for 2,3,7,8-TCDD in  the Columbia  River system at several locations for
which flow  data are available.
         Table 4-1.  Loading Capacity for TCDD in the Columbia River System

Location

Columbia R. below Priest Rapids
Columbia River at McNary Dam
Columbia River at The Dalles
Columbia River at Vancouver
Columbia River at Columbia City
Columbia River below Longview
Snake River near Clarkston
Snake R. below Ice Harbor Dam
Willamette River at Harrisburg
Willamette River at Portland
Harmonic
Mean Flow
(cfs)
95,400
143,000
152,000
159,000
180,000
188,000
35,700
37,000
7,600
17,100
Loading
Capacity
(mg/day)
3.03
4.54
4.83
5.04
5.73
5.97
1.14
1.18
0.24
0.54

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Proposed TMDL for Dioxin Discharges to the Columbia Basin
5.    ALLOCATION APPROACH
       A.  Overview

       The total load of a pollutant to a waterbody is attributable to point sources,
nonpoint sources, and natural background sources. The TMDL process distributes
portions of the stream's loading capacity to various sources including background
conditions in a way that will achieve water quality standards.  Decisions on actual
allocations depend on the amount of available data. The Water Quality Management
Regulations [40 CFR, § 130.2] state that:

       "Load allocations are best estimates of the loading, which may range from reasonably
       accurate estimates to gross  allotments, depending on the availability of data and appropriate
       techniques for predicting the loading."

       Allocation of the loading capacity is made considering technical, socioeconomic,
and institutional constraints.  Historically,  individual states have used various allocation
schemes appropriate to their  needs and may even specify that a particular method be
used.  Technical guidance has been prepared which describes  19 potential approaches
for allocation of loads ('Technical Guidance Manual for Performing Waste Load
Allocations", U.S. Environmental  Protection Agency, 1986).  When evaluating various
methods,  conditions that favor one approach over another must be considered.

       In terms of TCDD and the Columbia River, there are some potential problems in
using the more common methods described in the technical guidance:

       •  Common methods focus on wasteload allocations for point sources.
          Background sources and nonpoint source loads are not adequately addressed
          due to the difficulty associated  with measuring these  inputs.

       •  The geographic scale associated with the Columbia Basin and the number of
          potential sources is considerably larger than  the scale typically encountered in
          most TMDL situations.

       •  There are complexities in addressing persistent and highly bioaccumulative
          pollutants such as  TCDD.

       As a result of these concerns regarding common methods, a different approach
towards developing a TMDL for  the Columbia is  needed.  This approach should
consider major issues identified for TCDD in the  Columbia as well as the pros and cons
associated with various alternatives for allocating the loading capacity.  The key is to
work within a logical framework that will  lead to the attainment of water quality
standards. The following sections discuss  general issues affecting the allocation process
(Section B), development of general framework of the  TMDL (Section C), wasteload
allocation methods considered (Section D), the proposed wasteload allocation approach
(Section E), and the development of information on other sources (Section F).

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Proposed TMDL for Dioxin Discharges to the Columbia Basin	10


       B.  Issues

       In determining appropriate allocation methods for the Columbia, a number of
issues have been identified that affect decisions on the TMDL.  Issues identified to date
which need to be considered in developing allocations for 2,3,7,8-TCDD to the
Columbia River include:


       •  Loading from the British Columbia pulp mill

       •  Loading from other potential sources such as woodtreaters

       •  Attenuation

       •  Role of bottom sediments  (cumulative effects and resuspension)

       •  Framework for addressing future allocations (both growth within the pulp
          industry and  allocations to other source categories)



British Columbia Pulp  Mill:
       Celgar Pulp Company operates a bleached kraft pulp mill located in Castlegar,
 British Columbia. Wastewater from this mill is discharged to the Columbia River
 approximately 30 miles upstream from the United States - Canada border. Studies
 conducted by Environment Canada showed elevated concentrations of 2,3,7,8-TCDD in
 lake whitefish collected below the  Celgar mill (Mah .et a], 1989). Follow-up sampling by
 the Washington Department of Ecology found elevated levels of TCDD in fish collected
 from Lake Roosevelt on the upper Columbia River which is also below the Celgar mill
 (Johnson, 1990).

       The discovery of elevated levels of dioxins and furans below Celgar and other
 British Columbia pulp mills resulted in action by the  Canadian government.  New
 regulations under the Canadian Environmental Protection Act have been proposed to
 strictly control the discharge of chlorinated organics.  The B.C. government is proposing
 adsorbable organic halogens limits of 2.5 kg/ton and  1.5 kg/ton be met by 1991 and
 1994 respectively. The Canadian federal government is proposing limits of non-
 detectable amounts of dioxins and  furans by January  1994. Celgar is currently seeking
 government approval to increase the mill's production from 560 to 1200 air dried metric
 tonnes of pulp per day.  Modifications to the mill's production process are also being
 proposed which include oxygen delignification and maximum substitution of chlorine
 dioxide for chlorine.  Improvements to the Celgar mill are expected to be in place by
 1992 which will  meet proposed limits for chlorinated  organics. TCDD concentrations in
 the effluent are expected to be reduced to below detectable levels using approved
 analytical methods.  Although major reductions in TCDD loads are anticipated, some
 type of allocation must be identified to account for the upstream Canadian sources.

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Proposed TMDL for Dioxin Discharges to the Columbia Basin	U


Woodtreaters & Other Potential Sources:

       The development of the TMDL needs to consider all potential sources of 2,3,7,8-
TCDD in the Columbia drainage.  Besides chlorine bleaching pulp mills, other potential
source categories include woodtreaters, major municipal wastewater treatment plants,
agricultural areas, industrial sites, and urban areas. Table 5-1 summarizes potential
sources of TCDD in the Columbia, the type of available information on loading rates,
and median fish tissue concentrations from the National Bioaccumulation Study (NBS)
associated with the source  category.  The NBS was conducted as a screening
investigation to determine  the prevalence of selected bioaccumulative pollutants in fish.
One of the study objectives was also to identify general correlations between fish tissue
concentrations and sources of these pollutants.
          Table 5-1. Potential Sources of 2,3,7,8-TCDD in the Columbia Basin
Source Category
Chlorine Bleaching Pulp & Paper
Non-Chlorine Bleaching Pulp & Paper
Superfund Sites *
Woodtreaters, Incinerators, etc.
Other Industrial Sites
Urban Areas
Municipal Uastewater Treatment Plants
Agricultural Areas
Other Sites
Availability of
Data
for
Region 10
104 mill study
N/A
Remedial Investigations
N/A
N/A
N/A
Sewage Sludge Survey
N/A
N/A
National Bioaccumulation
Study Comparative Results
Median Cone, (ppt)
5.02
1.22
1.51
0.66
1.53
1.53
1-.08
0.71
0.63
                                      Note:   N/A   Not Available
       The NBS results, listed in Table 5-1, clearly indicate that the highest levels of
 TCDD contamination in fish were found in areas below chlorine bleaching pulp mills.
 However, two other sites from the NBS in the Columbia basin which were not
 immediately below pulp mills had elevated levels of TCDD in fish.  Both sites are
 located in the north Portland area.  One of the sites, Columbia Slough, is affected by
 nonpoint sources, predominantly urban runoff and a landfill.  The other site is located
 below a major woodtreating operation (McCormick & Baxter) which uses
 pentachlorophenol (PCP). TCDD contamination has been associated with PCP.

       EPA has recently developed a data system which contains information from the
 Toxics Release Inventory (TRI). A data retrieval of reported releases of PCP for 1987
 identifies seven facilities (woodtreaters) in the Columbia Basin. Five of these facilities
 are located in the Willamette drainage. Although the TRI information does not contain
 data on TCDD releases, the indicated releases of PCP lead to concern over
 woodtreaters, particularly in the Willamette basin. Because of the lack of information
 on TCDD releases, it is difficult to currently  assign an allocation to woodtreaters.
 However, the allocation scheme used does need to leave room for these facilities as

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 Proposed TMDL for Dioxin Discharges to the Columbia Basin	12


 further information becomes available.  Other users of PCP not included in the TRI
 data will also have to be considered in  the allocation process. Furthermore, non-
 chlorine bleaching pulp mills and former mill sites as well as other potential sources
 listed in Table 5-1, which are present in the Columbia basin, will also have to be
 considered in the allocation process.

        Testing has also been performed for 2,3,7,8-TCDD in sludge at five municipal
 wastewater treatment plants in the Columbia basin ("National Sewage-Sludge Survey
 Facility Analytical Results", U.S. Environmental Protection Agency, 1989).  Only one
 facility had any detectable amount of TCDD and it was at levels  much lower than sludge
 tested at chlorine bleaching pulp mills.  This indicates that the TMDL should  leave
  some capacity for allocations to municipal sewage treatment plants.  However, it can be
  expected that the allocations will be much lower than that for the pulp mills based on
  the sludge data.
  Attenuation:
        Losses of 2,3,7,8-TCDD in the water column can occur through sedimentation
  and through-uptake by aquatic organisms. There is very little data to quantitatively
  describe net attenuation in the Columbia River system and how it affects bioavailability.
  Water quality models, using a variety of assumptions, have been used by some groups to
  assess the need for control of TCDD discharges. Some such analyses have used a loss
  rate of TCDD which considers potential adsorption'of TCDD on paniculate matter
  within the water column.  However, the potential release of TCDD from the sediment to
  the overlying water or the potential effect of sediment-bound TCDD on the benthic and
  aquatic life food chain has not been considered in these models.

        The Clean Water Act specifically states that TMDL's shall be established with a
  margin  of safety which takes into account any lack of knowledge.  Based on the lack of
  knowledge concerning attenuation of TCDD in the Columbia River basin, assumptions
  must  be made in determining allocations of loading.  For the  purposes of this analysis, it
  is assumed that net attenuation does not occur. Thus, all 2,3,7,8-TCDD discharged is
  assumed to remain biologically available.  Because this is a conservative assumption, a
  TMDL designed under this  scenario should lead to the attainment of water quality
  standards regardless of the actual level of attenuation.  If future studies quantitatively
  document net attenuation rates,  allocations can be modified to reflect this.  This capacity
  could be used to provide an increased margin of safety to account for unknown sources
  or could be used to accommodate future growth needs.  By the same token, if studies
--indicate that TCDD releases from historical accumulations in the sediments constitute a
  problem, tighter controls may be needed (see discussion in following section).

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Proposed TMDL for Dioxin Discharges to the Columbia Basin	13


Role of Bottom Sediments:
       Attenuation generally implies a net loss of TCDD from the system.  However,
attenuation through deposition of sediments does raise other issues, namely cumulative
effects and pollutant build-up. Bottom sediments in portions of the Columbia River
basin are known to be contaminated with 2,3,7,8-TCDD.  Sediment concentrations are
the result of a complex series  of interactions between TCDD, the overlying water
column, sediments, aquatic organisms, and the external loading of TCDD.  Because the
Region's pulp mills have implemented some process changes recently, such as the use of
different defoamers, it is unlikely that existing sediment contamination levels are in
equilibrium with current loadings to the basin.  Existing sediment concentrations
probably reflect a combination of both current and historical discharges of TCDD.

       Some fraction of the TCDD which enters a river is associated with particulates.
These solids tend  to settle to the bottom of the receiving water. In areas where the
river is not filling  in, these particles (and the  TCDD associated with them) will continue
to be carried downstream as either bedload or resuspended sediments.  In areas of
sediment accretion, typically where river velocities are diminished, TCDD will tend to
accumulate in the bottom sediments.

       Current knowledge of the Columbia system is not adequate to estimate the
availability of TCDD associated with sediments to benthic organisms or bottom feeding
fish.  There are a number of different theories about the role of equilibrium partitioning
and bioaccumulation from contaminated sediments.  It is also difficult to estimate the
effects of resuspension of these sediments  either through high streamflows, boat traffic,
or dredging activities.  It is noteworthy that routine dredging is required in precisely
those areas where there  is net sediment accretion.  Given these conditions it would not
be appropriate to assume a permanent loss of 2,3,7,8-TCDD through sedimentation. As
indicated in the discussion on  attenuation, tighter controls will be needed if data shows
that the cumulative effects of  historical discharges significantly delay attainment of
TCDD standards under the reduced loadings  required by this TMDL.
 Future Allocations:
       The TMDL adopted by the regulatory agencies may provide a framework for
 dealing with future allocations. Examples include the assignment of any "reserve" or
 "other source" allotment to specific point or nonpoint sources.  Future growth within the
 pulp industry, either expansions or new mills, must also be considered.  This framework
 is needed within EPA Region 10 so that  the states, industry, and the public can know
 generally what to expect. Such a framework could define the boundaries on future
 permitting of loads from pulp mills in each state. Without a framework, there could be
 a "first come, first serve" approach to industry expansion.

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Proposed TMDL for Dioxin Discharges to the Columbia Basin	14


       Developing an equitable framework for future allocations is not an easy task.
The methods of allocating the loading capacity between the permitting authorities (i.e.
the states and EPA) are as numerous as those for allocating among existing sources.
Approaches could include proportions based on existing production capacity, per capita
basis, and various hybrid methods.  Because this issue is of interest to the public, this
proposed TMDL recognizes the need to develop such a framework. A presentation of
several alternatives for allocating the  loading capacity is also intended to stimulate
comments during the public notice period.
       C. Development of the TMDL
 General Framework:

       A TMDL, by definition, is the sum of the individual allocations (WLAs for point
 sources and LAs for nonpoint sources and background).  TMDLs are to be established
 with a margin of safety which takes into account any lack of knowledge concerning the
 relationship between effluent limitations and water quality. The margin of safety is to
 take into account uncertainties in the development of the TMDL, including uncertainties
 in ambient and effluent monitoring data and the existence of unregulated and unknown
 sources. In the proposed TMDL, the margin of safety has two main components:  (1)
 the total of the allocations made is significantly lower than the defined loading capacity,
 and (2) that loading capacity itself was calculated using a conservative model which
 excluded any factors for loss of TCDD from the system.

       Thus, the  margin of safety recognizes situations where more data is needed to
 develop comprehensive TMDLs which cover all sources,  such as nonpoint source inputs.
 With respect to the Columbia River and TCDD, several  factors contribute  to the
 shortage of data. First, it is often difficult to characterize nonpoint source  loads. These
 inputs are not continuous and are generally driven by weather related events such as
 rain storms or snow melt.   The second reason leading to a present lack of assessment
 data focuses on the analytical obstacles associated with measuring 2,3,7,8-TCDD. The
 water quality standard of 0.013 parts per quadrillion (ppq) is several orders of
 magnitude below a typical detection limit of 10 ppq for water column measurements.
 Lastly, issues described in the previous section such as inputs from Canada, potential
 inputs from other sources, and attenuation also contribute to the lack of hard data. All
 of these factors support currently defining a relatively large margin of safety associated
 with the TMDL for TCDD in the Columbia River.

       There is, however, enough information to identify some significant sources.  In
 response to concerns over insufficient information, particularly the lack of data on
 sources of 2,3,7,8-TCDD other than the pulp mills, the TMDL will be developed using a
 phased approach. In the first phase, the TMDL is established with a margin of safety
 large enough to account for any lack of knowledge.  As additional data is collected, the
 TMDL can be refined and allow for a lower margin of safety.

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                                                                                I
Proposed TMDL for Dioxin Discharges to the Columbia Basin	15


       The first phase of this TMDL provides an initial focus on chlorine bleaching pulp
mills.  Results of the National Bioaccumulation Study showed that fish collected below
pulp mills using chlorine bleaching had the highest median TCDD concentration of any
source category.  In addition, the §304(1) listing under the Clean Water Act specifically
identified these mills as point sources requiring ICS's. The basis of this listing was not
only data describing concentrations of 2,3,7,8-TCDD in fish tissue below chlorine
bleaching pulp mills but also measured concentrations of 2,3,7,8-TCDD in effluents and
treatment plant sludges at these mills. The first phase of TMDL development for
2,3,7,8-TCDD in the Columbia will also initiate a more comprehensive data collection
program. Monitoring efforts will be designed to obtain better baseline information and
to fill recognized data gaps, particularly on other potential sources of TCDD.  The
following two concepts were used in developing the proposed TMDL for the Columbia
River basin:

       •  Watershed Targets

       •  Source Control
Watershed Targets:

       The Oregon Department of Environmental Quality (DEQ) has created a logical
framework for establishing TMDLs designed to achieve water quality standards in
waterbodies affected by both point and nonpoint source pollution.  In the Tualatin River
DEQ applied the concept of defining watershed targets on major tributaries.  Wasteload
allocations for point sources are established after watershed targets are identified.  The
watershed targets serve as internal check points to determine that water quality
standards will be met at key locations within the drainage. This same technique can
also be used for the Columbia River.
       Watershed targets are set within the basin by simply identifying the loading
 capacity at key points in the drainage system.  To determine these targets, the only data
 requirements are a water quality criterion and a design flow (in this case, the mean
 harmonic stream flow).  The proposed watershed targets focus on high priority
 tributaries. In the case of the Columbia, there are three logical starting points in
 addition to the lower Columbia near Bradwood (below Longview).  These locations are
 summarized  in Table 5-2 and shown in Figure 5-1.

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Proposed TMDL for Dioxin Discharges to the Columbia Basin	16
          Table 5-2.       Loading Targets for TCDD to Selected Watersheds
                          in the Columbia River System
Watershed
TOTAL COLUMBIA RIVER BASIN
SELECTED SUB-BASINS
Watershed N. of WA/ Canada Border
Snake River Watershed
Willamette River Watershed
TOTAL FOR SUB-BASINS
REMAINDER AVAILABLE FOR
MAINSTEM COLUMBIA RIVER BASIN
Harmonic
Mean Flow
(cfs)
188, OOO1
72,2002
37, OOO3
17,100*


Loading
Capacity
(mg/day)
5.97
2.30
1.18
0.54
4.02

1.95
           Row at Columbia River near Bradwood
           Row at Columbia River at WA/Canada border
           Row at Snake River below Ice Harbor Dam
           Row of Willamette River at Portland
       Detectable levels of TCDD have been measured in tissue of fish taken from sites
 associated with these watershed target locations.  Because these fish tissue
 concentrations are above the 10"6 risk level, the loading capacity for TCDD is currently
 exceeded. Consequently, reductions in TCDD  loads are needed to meet these
 watershed targets.  Furthermore, these watershed targets must be met in order  to ensure
 attainment of water quality standards in the Columbia.  It is also impractical to allocate
 any of this upstream loading capacity to downstream sources at this time because there
 is no extra load currently available.  Therefore, the loading capacity at each of  these
 three points should be subtracted from the basin total of 5.97 mg/day.

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  Proposed TMDL for Dioxin Discharges to the Columbia Basin	:	17
        Figure 5-1.  Location of Watershed Targets (•) Relative to the Pulp Mills
                                                                CELCAR
                                                                (Cutlef ar. EC)
                                                                POTLATCH CORPORATION
                                                                (Ltvtaton)
JA1IES RIVER
(Ytuna)
BOISE CASCADE
(3t
POPE ft TAtBOT
WEYERHAEUSER
(Un«Tl«w)

  LONCV1EW FIBER
  (LonfvUw)

    JAMES RIVER
    (Camu)
         The Columbia River at the International Boundary also includes flow from both
  Canada and from the Pend Oreille River.  In addition to TCDD loads from the
  Canadian mill on the upper Columbia River, the Clark Fork / Pend Oreille basin has
  potential TCDD sources in Montana (Stone.Container pulp mill in Missoula and
  Superfund sites  near Butte). At a minimum, the loading capacity for TCDD at the
  border cannot be exceeded without violating water quality standards.  Thus, the entire
  loading capacity available at the border has been allotted to the upstream sources. The
  TCDD loading capacity provided by streamflow at the border cannot be allocated to
  downstream sources until the upstream sources of TCDD (particularly the Celgar mill in
  British Columbia) are controlled.

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Proposed TMDL for Dioxin Discharges to the Columbia Basin	18


       The Willamette Basin is the most industrialized and populated area in the
Columbia River system.  The most logical approach is to establish the watershed target
at the loading capacity for the Willamette River at Portland.  The sum of all allocations
to sources in the Willamette Basin must not exceed the watershed target. By the same
token, loading capacity attributed to flow produced by the Willamette is not currently
available for use in the mainstem Columbia. The same logic applies to the Snake River
   t .1  *^  .* .  *    ••««                                   "   ff
and the Potlatch mill.
 Source Control:
       The first phase of this TMDL provides an initial focus on developing allocations
 to those major source categories for which adequate data exists, such as chlorine
 bleaching pulp mills.  The remainder of the loading capacity will be held as a margin of
 safety for other potential sources of TCDD where current data are insufficient to
 estimate specific wasteload allocations.  Alternatives need to consider the portion of the
 loading capacity to be allocated to chlorine bleaching pulp mills relative to the size  of
 the margin of safety.
       The chlorine bleaching pulp and paper industry is the only source in Region 10
 for which we have site specific quantitative information on effluent quality which is
 sufficient to describe wasteloads.  This industry also happens to be the source category
 associated with the highest TCDD concentration observed in fish tissue (NBS).  As
 shown in Table 5-1, there is little or no information available concerning loadings from
 other potential sources of 2,3,7,8-TCDD.  Thus, the first phase will focus on wasteload
 allocations to the chlorine bleaching pulp industry. As further information becomes
 available, allocations can be identified for other source categories. Having established
 watershed target allocations, the following sections discuss methods to establish
 wasteload allocations within the chlorine bleached pulp mill source category.

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Proposed TMDL for Dioxin Discharges to the Columbia Basin	•_    19


       D. Wasteload Allocation Methods  Considered
                                                              n

       In developing the proposed TMDL, several alternative wasteload allocation
 methods have been considered.  Options focus on different approaches for allocating
 portions of the loading capacity to chlorine bleaching pulp mills.  These alternatives are
 presented in the following sections to illustrate the effect of assumptions made on
 resulting WLAs and to stimulate public consideration of the pros and cons of alternative
 allocation scenarios.  Included in the presentation of options is one preferred alternative.
 Following the public notice period on the proposed TMDL, other options may also be
 considered as a result of comments.  Alternative approaches currently considered fall
 into several different categories which include:


       •  . Equal Effluent Concentrations

       •   Equal Mass Discharge per Unit Production

       •   Equal Percent Reduction
 Equal Effluent Concentrations:


       One allocation option is to set an equal effluent concentration for each pulp mill
 which uses chlorine bleaching.  The resultant cumulative load is the portion of the
 loading capacity allocated to chlorine bleaching pulp mills located in EPA Region 10.
 The margin of safety is then the difference between the loading capacity and  the WLAs
 to the chlorine bleaching pulp mills in the Columbia basin of Region 10.

       A starting point is to look at a long term average effluent limit of 10 ppq (the
 current general method detection limit) at  each mill.  This limit is initially applied at the
 point of discharge. Total, plant effluent flows are used as  a basis to calculate loads.
 Discharge  monitoring report (DMR) data has been summarized and includes average
 effluent discharge rates.

        Using a long term average effluent limit of 10 ppq applied at the point of
 discharge and current  estimates of monthly average flow at each mill, the cumulative
 load from  all the mills exceeds 12 mg/day (Table 5-3). This is greater than  the loading
 capacity of 5.97 mg/day.  Consequently, this option must be rejected because there is no
 guarantee  that water quality standards will be met under conservative assumptions, such
 as no attenuation.  In  addition, this would  not account for any 2,3,7,8-TCDD  from other
 sources. Thus, more restrictive controls are needed.

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Proposed TMDL for Dioxin Discharges to the Columbia Basin   	20
         Table 5-3.  Waste Load Allocations for Chlorine-Bleaching Pulp Mills

                  (Option 1:  Set Equal Long Term Average Effluent
                  Concentration of 10 ppq at Point of Discharge)
Production
(tons/day)
1,509
957
1.650
310
1026
550
1.035
800
7,837
Percent
19.5
11.7
20.7
3.8
13.5
7.1
13.4
10.3
100.0
TCDD ULA
(dig/day)
1.42
0.76
2.20
2.37
2.01
0.99
1.29
1.44
12.47
Hill
Potlatch -- Lewiston, ID
Boise Cascade -- Uallula, WA
James River -- Camas, WA
Longview Fibre -- Longview, WA
Weyerhaeuser -- Longview. WA
Pope & Talbot -- Halsey, OR
Boise Cascade -- St. Helens, OR
James River -- Wauna, OR
TOTAL Source Category Allotment
       A permit condition set at a level below the general analytical detection limit
 creates a situation where it is difficult, if not impossible, to determine compliance.
 Because dioxins and other chlorinated organic compounds are produced in the bleach
 plant, concentrations of 2,3,7,8-TCDD are higher in the combined bleach plant flow than
 in the total plant effluent.  This means that waste load allocations which result in total
 plant effluent concentration limits that are below the general analytical detection limit
 could be monitored for compliance by measuring concentrations in the combined bleach
 plant waste stream.  Using estimates of bleach plant flows and a limit of 10 ppq in the
 combined bleach plant flow,  the cumulative load is 4.0 mg/day or approximately 67
 percent of the total loading capacity  (Table 5-4).
         Table 5-4. Waste Load Allocations for Chlorine-Bleaching Pulp Mills

                  (Option 2: Set Equal Long Term Average Effluent
                   Concentration of 10 ppq at Bleach Plant)
Production
(tons/day)
1,509
957
1,650
310
1026
550
1,035
800
7,837
Percent
19.5
11.7
20.7
3.8
13.5
7.1
13.4
10.3
100.0
TCDD WLA
(mg/day)
0.71
0.14
0.87
0.23
0.57
0.49
0.64
0.36
4.02
Hill
Potlatch -- Lewiston, ID
Boise Cascade -- Wallula, WA
James River -- Camas, WA
Longview Fibre -- Longview, WA
Weyerhaeuser -- Longview, WA
Pope & Talbot -- Halsey, OR
Boise Cascade -- St. Helens, OR
James River -- Wauna, OR
TOTAL Source Category Allotment

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Proposed TMDL for Dioxin Discharges to the Columbia Basin
21
       Using a long term average of 10 ppq at the bleach plant to develop the waste
load allocations for chlorine bleaching pulp mills yields a cumulative load which is less
than the loading capacity.  However, several concerns exist which include:


       •  the margin of safety is small  (33% of the loading capacity)

       •  there is very little room for allocations to other potential sources, such as
          woodtreaters or the mill in British Columbia, once these loads are quantified

       •  future growth in the pulp & paper industry is not addressed


       For these reasons, the possibility of yet lower effluent limits should be evaluated.
This can be accomplished by setting a "maximum" concentration of 10 ppq, rather than
using a long term average  of 10 ppq. To understand how this results in a lower
allocation, the relationship between the wasteload allocation (WLA) and the actual
permit limits must be examined.  In certain cases, permit limits will be  different than
WLA values. Because the criteria for 2,3,7,8-TCDD is set to protect human health, the
loading capacity (and WLAs) reflect a long term average. It is important to consider
how the WLAs address variability in effluent quality. Permit limits are set at the upper
bounds of acceptable performance and are values not to be exceeded.  Requirements
are usually expressed using two types of permit limits, either daily maximum or monthly
average.  Procedures have been developed for computing monthly average permit limits
from long term average WLAs in EPA's TSD ('Technical Support Document for Water
Quality-based Toxics Control",  U.S. Environmental'Protection Agency,  1985).
         Table 5-5. Waste Load Allocations for Chlorine-Bleaching Pulp Mills

                  (Option 3: Set Equal Long Term Average Effluent
                   Concentration of 4.7 ppq at Bleach Plant)
Production
(tons/day)
1.509
957
1,650
310
1026
550
1,035
800
7.837
	
Percent
19.5
11.7
20.7
3.8
13.5
7.1
13.4
10.3
100.0
TCDD WLA
(nig/day)
0.33
0.06
0.41
0.11
0.27
0.23
0.30
0.17
1.88
Hill
Potlatch -- Lewiston, ID
Boise Cascade -- Uallula, UA
James River -- Camas, WA
Long view Fibre -- Longview, UA
Weyerhaeuser -- Longview, WA
Pope & Talbot -- Halsey, OR
Boise Cascade -- St. Helens, OR
James River -- Wauna, OR
TOTAL Source Category Allotment

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Proposed TMDL for Dioxm Discharges to the Columbia Basin
22
       Effluent monitoring requirements for 2,3,7,8-TCDD in the pulp mill permits is
proposed as monthly sampling.  With a coefficient of variation of 0.6 (as recommended
in the technical support document) and one sample per month, a monthly average
permit limit of 10 ppq converts to a long term average WLA value of 4.7 ppq.  Using
estimates of bleach plant flows  and 4.7 ppq as the long term average concentration limit
for the combined bleach plant flow, the cumulative load is 1.9 mg/day or just over 30
percent of the total loading capacity. This leaves a margin of safety of nearly 70 percent
of the loading capacity to account for the lack of information on other potential sources.
This approach also results in more than a 95 percent reduction in TCDD discharged
from these pulp mills when compared to estimates of current loading based on results of
the 104 mill study.
 Equal Mass Discharge per Unit Production:

       A disadvantage of equal effluent concentrations based on current flow rates is
 that it may not be equitable for all mills.  A common approach for industrial permits is
 to consider production levels in establishing effluent limits.  To provide for more equity,
 each mill could be allocated an equal amount of 2,3,7,8-TCDD for discharge per
 quantity of bleached pulp produced.  One way to accomplish this is to associate bleach
 plant flow rates with production quantity of bleach pulp.  In estimating bleach plant
 flows, the Washington Department of Ecology used 14,470 gallons of wastewater
 generated per ton of bleached pulp produced. Applying this figure to  calculate bleach
 plant flows and 4.7 ppq as the long term average concentration limit for the combined
 bleach plant flow, the cumulative load is 2.01 mg/day (Table 5-5) or approximately 34%
 of the total loading capacity.
          Table 5-6.  Waste Load Allocations for Chorine-Bleaching Pulp Mills

                  (Option 4: Set Equal Long Term Average Effluent
                   Concentration of 4.7 ppq at Bleach Plant and Set
                   Flows at  14,470 gallons / ton bleached pulp)
Production
(tons/day)
1,509
957
1,650
310
1026

550
1,035
800
7,837
•
Percent
19.5
11.7
20.7
3.8
I 13.5
|
I 7.1
| 13.4
| 10.3
I 100.0
± 	 j
TCDD ULA
(mg/day)
0.39
0.25
0.42
0.08
0.26

0.14
0.27
0.21
2.01
Mill
Potlatch --
Boise Cascade
James River
Lewiston, ID
-- Uallula, UA
-- Camas, WA
Long view Fibre -- Long view, UA
Weyerhaeuser

Pope & Talbot
Boise Cascade
James River
TOTAL Source
-- Longview, WA

-- Halsey, OR
-- St. Helens, OR
-- Wauna, OR
Category Allotment

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Proposed TMDL for Dioxin Discharges to the Columbia Basin       	23


       Although this is an increase of 0.13 mg/day over that shown in Table 5-5, the
approach does address one major problem with using current bleach plant flows.  Mills
have been encouraged to recycle internal waste streams to the maximum extent possible.
One example, Boise Cascade at Wallula, practices extensive recycling.  Under the equal
effluent concentration method, a mill that does a high level of recycling receives a lower
allocation. However, a mill that does not make efficient use of water in the bleach
plant actually receives a high allocation.  This is a major reason for relating bleach plant
flows to pulp production when determining allowable loads.  Again, the margin of safety
exceeds 65 percent of the loading capacity.  This approach also results in more than a 95
percent reduction in TCDD discharged from these mills when compared to results of the
104 mill study.
Equal Percent Reduction:

       Another option considered is equal percent reduction for all source categories.
Because there is an absence of specific data for loadings of TCDD to the Columbia, this
approach can be viewed in several different ways.  The first could use information on
the relative magnitude of 2,3,7,8-TCDD in fish collected  below potential sources of
dioxin. Using median tissue concentrations summarized  in Table 5-1 as a general
indicator of these relative contributions, thirty-six percent (36%) of the loading capacity
could be attributed to chlorine bleaching pulp production.  The remaining sixty-four
percent (64%) could be attributed to other sources, such as municipal wastewater
treatment plants or agricultural areas. This analysis excludes refineries because this
industry is not known to be a significant source in the Columbia drainage. Although this
approach does offer some advantages by accounting for other  source categories, there
are some major drawbacks. These include:


       •   NBS was intended  as a screening study and not to describe source category
           loadings

       •   fish sampled nationally were collected from streams of varying sizes and did
           not account for dilution

       •   results of NBS associated with  certain source  categories may  also include
           other sources (i.e. a site directly below a POTW may also be 30 miles  below
           a bleached kraft  pulp mill)

       Another option suggested  is to use values of 2,3,7,8-TCDD measured in Columbia
River fish and the bioconcent ration factor used to develop the water quality criteria
(0.013 ppq) to "back calculate" current TCDD loads.  Although it may be possible to
estimate the relative magnitude of present plus historic TCDD loading by looking at
tissue concentrations, other factors  besides a weighted average bioconcentration factor of
5000 must be considered.  For instance, bioconcentration factors specific to the species
should be evaluated. The age of the fish and lipid content of the samples must also be
taken into account.  The 5000 bioconcentration factor used to develop the criteria is

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Proposed TMDL for Dioxin Discharges to the Columbia Basin       	24
intended to represent the weighted average factor for the species mix and lipid content
in the "average" American fish / shellfish diet. The lack of species-specific
bioconcentration data, as well as the difficulty in distinguishing the effects of historic
versus current loading, makes using this approach inappropriate for this TMDL at the
present time.
       E.  Proposed Wasteload Allocation Approach

       Although certain types of data are currently lacking, available information
 highlights several concerns.  Concentrations of TCDD in fish tissue in several areas of
 the Columbia River basin exceed levels protective of human health at the Iff8 risk level.
 Regional and national data strongly suggest that pulp mills which use chlorine to bleach
 are the largest source of TCDD  to surface waters. Information also  exists quantifying
 levels of TCDD in effluents from chlorine-bleaching pulp mills in the Columbia River
 basin.

       Remaining data needs must address upstream inputs from Canada, contributions
 from other potential sources such as wood treaters, attenuation,  and  the role of
 sediments. A margin of safety will be  defined to account for any lack of information.
 Region 10's proposed alternative for developing a TMDL for 2,3,7,8-TCDD on the
 Columbia River is the following phased approach:


       •  Establish the watershed targets identified in Table 5-2 as  the basis for
           allocation decisions which will lead to attainment of water quality standards.
           Shifting of loads from upstream areas will not even be considered until solid
           technical information shows either that these targets are met or that the
           targets can be achieved as the result of enforcable  control actions.


        •  Establish wasteload allocations to individual dischargers in one source
           category, pulp mills which use chlorine bleaching, at this time. Use equal
           mass discharge per unit production (Table 5-6)  to allocate waste loads to
           individual pulp mills  in that source category. In addition to a long term
           average concentration of 4.7 ppq at the bleach plant, flow limits need to be
           set to ensure compliance with wasteload allocations.  NPDES permit limits
           for these pulp mills can not be less  stringent than the loadings listed in
           Table 5-7.

        •  Reserve the remainder of the loading capacity (3.96 mg/day or 66 percent) as
            a margin of safety. Additional data will be collected and evaluated to
            confirm the adequacy of the margin of safety and,  possibly, to support
            additional or modified allocations.

        The table on the followin page summarizes the overall structure of the proposed
 TMDL with the allocations based on currently available information.

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Proposed TMDL for Dioxin Discharges to the Columbia Basin	25
                   -.
Waste Load Allocations for Chlorine-Bleaching Pulp Mills
in Context of Watershed Targets
   LOADING CAPACITY FOR ENTIRE COLUMBIA RIVER BASIN

   Columbia River Basin above Washington/Canada border
     Watershed target

   Snake River Basin above Ice Harbor Dam
     Watershed target
     Pulp Mill ULAs:   Pot latch (Lewiston, ID)

   Willamette River Basin above confluence with Columbia R.
     Watershed target
     Pulp Mill WLAs:   Pope & Talbot (Halsey. OR)

   Remainder of Columbia R. Basin
     Watershed target
     Pulp Mill WLAs:
                     Boise Cascade (Wallula, WA)
                     James River (Camas, WA)
                     Longview Fibre (Longvieu, WA)
                     Weyerhaeuser (Longview, WA)
                     Boise Cascade (St. Helens, OR)
                     James River (Wauna, OR)
                     TOTAL

   Sum of WLAs for Region 10 pulp mills
                                                      TCDO (mg/dav)
                                                    WLA
                        0.39
                         0.14
                         0.25
                         0.42
                         0.08
                         0.26
                         0.27
                         0.21
                         1.49

                         2.01
                                 5.97
                                 2.30
                                  1.18
                                  0.54
                                  1.95
                                                    Watershed
                                          WLA as     as X of
                                           X of     Total Basin
                                          Watershed  Loading Cap.
33.1
25.9
         100
          38.5
          19.8
           9.0
          32.7
76.4
        F.  Development of Information on Other Sources

        In order to confirm that TCDD loadings from other sources fit within the margin
 of safety provided in the proposed TMDL, EPA proposes the following actions to be
 taken by the states in cooperation with EPA:1

            ».   Develop a strategy to address water quality concerns related to TCDD
                inputs from woodtreating facilities.  The proposed strategy should identify
                sources to be considered for allocations, a sampling plan for determining
                reductions needed, and a schedule for implementation of the strategy.

            >   Address other point source concerns, such as other major industrial
                NPDES dischargers and major municipal NPDES facilities with formal
                pretreatment programs, by forwarding existing state data on
                concentrations of dioxin in sludge.

            +   Develop a strategy that addresses the other source categories such as
                urban runoff and agriculture.

 1  This information collection is exempt from the Paperwork Reduction Act because it is being sought from
   fewer than 10 persons.

-------
                  United States Environmental Protection Agency
                                  Region 10
                          1200 Sixth Avenue, WD-139
                          Seattle, Washington  98101

        NOTICE OF PROPOSED ESTABLISHMENT OF A TOTAL
      MAXIMUM DAILY LOADING (TMDL) TO LIMIT DISCHARGES
              OF DIOXIN TO THE COLUMBIA RIVER BASIN
 Public Notice Issuance Date:     June 15, 1990
 Public Hearing Date:            July 17, 1990
 End of Public Comment Period:  July 20, 1990
 1.    Background

      The Columbia River and segments of the Willamette and Snake Rivers contain
 amounts of a toxic chemical, 2,3,7,8 TCDD (dioxin), which exceed applicable water
 quality standards. The Clean Water Act requires, in such cases, that the states
 calculate the maximum amount of the pollutant that the affected waterbody can safely
 receive.  This loading capacity is used to establish a total maximum daily load which
 allocates allowable loads to point sources, nonpoint sources, and background. The
 TMDL is effectively an implementation plan for achieving water quality standards.

      Recognizing the interstate nature of the Columbia River and the desirability of
 consistency and equity in regulating dischargers in this multi-state river basin, the
 involved states decided not to adopt a Columbia River dioxin TMDL as a state action.
 Instead, they requested that EPA establish one as a federal action.
 2.    Tentative Determination

      Region 10 is hereby proposing to establish a TMDL for 2,3,7,8 TCDD in the
 Columbia River Basin. Development of the proposed TMDL has been a cooperative
 effort by EPA Region 10, the Oregon Department of Environmental Quality, the
 Washington Department of Ecology, and the Idaho Division of Environmental Quality.

      Based on state standards for TCDD and river flows in the basin,.loading
 capacities are calculated for various points in the system. The calculated loading
 capacity is about 6 milligrams (mg) TCDD/day at a point downstream of Longview,
-Washington.  This point is below the major sources  of dioxin to the basin. Watershed
 targets, similarly calculated for four major segments of the entire basin, are:
 2.3 mg/day for the Columbia River as it crosses the Washington-British Columbia
 border; 1.18 mg/day for the Snake River Basin above Ice Harbor Dam; 0.54 mg/day
 for the Willamette River Basin; and 1.95 mg/day for the remainder of the basin.

-------
      The vast majority of data on sources of TCDD in the Columbia basin has
focused on pulp mills using chlorine bleaching processes. Additionally, national data
indicate these mills are the most significant sources of 2,3,7,8 TCDD to the nation's
waters.  As a result, Region 10 is currently proposing  a TMDL that identifies specific
wasteload allocations only for these chlorine bleaching pulp mills.  A total of 2 mg/day
is allocated to the existing pulp mills in Region 10. The remainder of the loading
capacities for each identified watershed is held in reserve, as a margin  of safety,
pending development of information on other potential source categories.  The Agency
is also proposing a process for obtaining that information. After reviewing and
responding to comments EPA will issue a final TMDL.
3.    Public Comments

      Persons wishing to comment on the tentative determinations contained in the
proposed TMDL may do so by writing to EPA at the above address to the attention of
the Director, Water Division. Copies of the Fact Sheet and Development Document for
the proposed TMDL may be requested at no charge from the above address or by
calling John Gabrielson at (206) 442-4183. Written comments must be postmarked on
or before July 20, 1990 to be considered in the formulation of final determinations
regarding the TMDL All comments should include the name, address and telephone
number of the commenter and a concise statement of the comment and the relevant
facts upon which it is based.

      A public hearing is scheduled for 7 pm, July 17, 1990, at the P.U.D. Community
Room, 1200 Fort Vancouver Way, in Vancouver, Washington. You may submit oral  or
written statements about the TMDL at the hearing.
4.    Administrative Record

      The Fact Sheet, TMDL Development Document, and other related documents
are on file at the above address and at the following locations: EPA Idaho Operations
Office, 422 W. Washington Street, Boise, Idaho; EPA Oregon Operations Office, 811
S.W. Sixth Avenue, 3rd Roor, Portland, Oregon; and EPA Washington Operations
Office located at the St. Martins College Campus, Lacey, Washington. The
administrative record may be reviewed any time between 8:30 a.m. and 4 p.m.,
Monday through Friday.

-------
                           Region 10 Fact Sheet
                                        June 15, 1990
                            TOTAL MAXIMUM  DAILY  LOADING  FOR
                          DIOXIN  IN  THE  COLUMBIA  RIVER  BASIN
BACKGROUND
The water quality of the Columbia River and segments of
the Snake and Willamette Rivers is currently considered
impaired due to concentrations of a form of dioxin.  The  .
pollutant, 2,3,7,8-TCDD, is the most toxic of a group of
compounds known as polychlorinated dibenzo-para-
dioxins. These compounds, although occuring naturally at
very low concentrations, can be found at elevated levels as
a result of human activities such as the manufacture of
chlorinated herbicides, the combustion of domestic and
industrial wastes, and the production of chlorine-bleached
pulp.  Concentrations of TCDD measured in fish tissue in
several areas  of the Columbia River basin exceed levels
protective of human health.  Regional and national data
indicate that pulp mills which use chlorine to bleach paper
products are associated with some of the highest
concentrations of TCDD in surface waters.  Information also
exists quantifying levels of TCDD in effluents from chlorine-
bleaching pulp mills in the Columbia  River basin.
WHAT IS A TMDL?
Section 303 (d) of the Clean Water Act requires each state
(1) to identify waters for which effluent limitations normally
required are not stringent enough to attain water quality
standards and (2) to establish total maximum daily loads
(TMDLs) on  such water quality limited segments for the
pollutant(s) of concern.

The process of developing a TMDL involves the allocation
of allowable  loads to point sources, nonpoint sources, and
background.  A TMDL, by definition, is the sum of the
individual allocations to point sources, nonpoint sources
and background. It is effectively an implementation plan for
achieving water quality standards using an appropriate
margin of safety which takes into account any lack of
knowledge concerning the relationship between sourc$
concentrations and water quality.

Concern about issues of equity in the multi-state basin led
the states of Oregon, Washington, and Idaho to request

-------
                        that EPA establish the TMDL for dioxin in the Columbia
                        River basin as a federal action.  In order to do so under
                        Section 303 (d), EPA must first take the formal actions of
                        approving the listing of the affected waters as impaired and
                        disapproving the states' expressed intent to not submit the
                        required TMDL. This is being done concurrent to the
                        issuance of the public notice for the federally proposed
                        TMDL.
THE PROPOSED TMDL  The proposed TMDL provides a framework to control dioxin
                        discharges to the Columbia River Basin.  In developing a
                        TMDL, the loading capacity (the greatest amount of loading
                        that this river can receive without violating water quality
                        standards) must first be calculated. The proposed TMDL
                        defines the loading capacity of the entire Columbia River
                        basin to be about 6 milligrams of 2,3,7,8-TCDD per day.
                        This value was derived based on a simple model which
                        conservatively assumed no net losses of TCDD from the
                        system. This assumption was made because, although jt	
                        was recognized that sedimentation occured, EPA could fioF
                        confidently assume that the TCDD bound to bottom
                        sediments was not still biologically available.

                        Because of the vastness of the Columbia River basin and
                        the need to ensure attainment of water quality standards for
                        TCDD at all points, the proposed TMDL establishes three
                        checkpoints within the system.  Loading capacities, or
                        "watershed targets," have been established for the
                        Willamette River basin (0.54 mg TCDD/day), the Snake
                        River basin (1.18 mg TCDD/day), and the portion of the
                        Columbia River basin which drains through Canada into
                        Washington (2.3 mg TCDD/day). Allocations to sources
                        within each of those watersheds must fit within these
                        watershed targets.

                        EPA is also proposing specific wasteload allocations for the
                        eight chlorine-bleaching pulp mills located in the Columbia
:;                        River basin in Oregon, Idaho, and Washington. These
                        allocations, as proposed, would lead to an estimated 95%
                        reduction in dioxin discharges from these facilities.

-------
     United"Stales             Region 10               Alaska
     Environmental Protection      1200 Sixth Avenue          Idaho
     Agency                Seattle WA 98101           Oregon
     _____	.	^^^  Washington
 vvEPA
 ^"-l "                JUN141990
Reply to
Attn of:  WD-139

 Re:   Proposed Dioxin Controls for the Columbia River Basin

To All Interested Parties:

      The Environmental Protection Agency, Region 10, is proposing to establish a
 total maximum daily loading (TMDL) for 2,3,7,8-TCDD (dioxin) in the Columbia River
 basin.

      TMDL development is generally a state responsibility.  However, the states of
 Idaho, Oregon and Washington have requested that EPA establish this TMDL because
 of the desirability of consistency and equity in regulating dischargers in this multi-state
 river basin.  Therefore, although the TMDL development was a cooperative process
 with the states, EPA has taken the following final actions concurrent with proposing the
 attached TMDL:

      .   EPA has  approved the listing of the Lower Columbia River (mouth to RM
          397), Lake Roosevelt (upper Columbia River), the Willamette River (mouth to
          RM 187)  and the Snake River (mouth to the confluence of the Snake and
          Clearwater Rivers) as water quality limited for 2,3,7,8-TCDD under Section
          303(d) of the Clean Water Act (CWA).

      •   EPA has  disapproved,  under Section 303 (d) of the CWA, the expressed
          intent by  the states of Washington, Oregon, and Idaho to not submit a
          TMDL for the waters listed above.

      •   EPA hereby proposes to establish the attached TMDL for dioxin in the
          Columbia River basin.

       Enclosed is the Public Notice, published in several daily newspapers today,
 seeking public comment on this action. Also enclosed is (1) a Fact Sheet that
 summarizes the TMDL and identifies specific issues on which we would like public
 input and (2) the TMDL Decision Document including the technical basis of the
 proposed TMDL EPA has scheduled a public hearing on the TMDL in Vancouver,
 Washington, on July 17, 1990.  The public comment period will end on July 20, 1990.

       If you have any questions on these actions, or if you would like a Copy of the
 TMDL Decision Document, please contact John Gabrielson at (address) or call him
' (206) ^4183.

         O                              Sincerely,
                                         Thomas P. Dunne
                                         Acting Regional Administrator
 Enclosures

-------
               The following table summarizes the overall structure of the
               proposed TMDL:
Table 1.       Waste Load Allocations for Chlorine-Bleaching Pulp Mills
               in Context of Watershed Targets




LOADING CAPACITY FOR ENTIRE COLUMBIA RIVER BASIN
Columbia River Basin above Washington/Canada border
Watershed target
Snake River Basin above Ice Harbor Dam
Watershed target
Pulp Mill WLAs: Potlatch (Lewiston, ID)
Willamette River Basin above confluence with Columbia R.
Watershed target
Pulp .Mill WLAs: Pope & Talbot (Halsey, OR)
Remainder of Columbia R. Basin
Watershed target
Pulp Mill WLAs:
Boise Cascade (Wallula, WA)
James River (Camas, WA)
Longview Fibre (Long view, WA)
Weyerhaeuser (Longview, WA)
Boise Cascade (St. Helens, OR)
James River (Wauna, OR)
TOTAL
Sun of WLAs for Region 10 pulp mills
Watershed
TCDD (mg/day) WLA as as % of
Loading % of Total Basin
WLA Capacity Watershed Loading Cap.
5.97 100

2.30 38.5

1.18 19.8
0.39 33.1

0.54 9.0
0.14 25.9

1.95 32.7

0.25
0142
0.08
0.26
0.27
0^21
1.49 76.4
2.01
                EPA suspects that other sources of dioxin exist in the
                Columbia River basin.  Accordingly, the remainder of the
                loading capacity (3.96 mg/day or 66 percent) is reserved in
                this phase of the TMDL as a margin of safety until adequate
                data has been collected and evaluated which either confirms
                the adequacy of the margin of safety or supports the
                establishment of additional or modified allocations.  In order
                to obtain this additional data,  EPA proposes that the states
                hi cooperation with EPA develop strategies to collect the
                needed information. If future data identifies the need to
                make additional allocations, a modified TMDL would be
                established.

-------
PUBLIC COMMENTS    A Public Hearing for the proposed TMDL is scheduled for
                         7 p.m., July 17, 1990, at the P.U.D. Community Room, 1200
                         Fort Vancouver Way, in Vancouver, WA.  Written
                         comments, postmarked no later than July 20, 1990, may also
                         be sent to EPA, 1200 Sixth Avenue, WD-139, Seattle, WA
                         98101.

                         Although all substantive comments are welcome, EPA is
                         especially interested in comments on the following specific
                         issues:

                         •  the appropriateness of limiting the proposed TMDL to
                            2,3,7,8-TCDD instead of including other forms of dioxin
                         •  the adequacy of the margin of safety held in reserve
                            relative to  other unquantified sources
                         •  present and projected pulp mill production rates
                         •  reasonable quantities of process water to be discharged
                            per ton of  bleached paper product produced
                         •  data on the variability of TCDD in pulp mill effluent
                         •  present and projected magnitude of other sources.
                            including those in Canada
                         •  the appropriateness of proposed  efforts to evaluate the
                            significance of other sources
                         •  the appropriateness of calculating loading capacity
                            without estimating attenuation or availability of TCDD in
                            the sediments (data quantifying these processes for
                            TCDD would be most appreciated)
                         •  analytical detection limits for dioxins by methods
                            currently available through commercial laboratories

-------
    ENVIRONMENTAL LAW
  FEDERAL/STATE RESEARCH
          TOOLS
LEWS KEKIS LEXFS KEXtS

-------
                FEDERAL CASELAW
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environ
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-------
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environ              uses               titles?, 15,16, 21,
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                                    search: sara and cerla
genfed              publaw              full text; all public
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       STATUTORY RESEARCH — STATE

environ              allcde              48 states environmental
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                                    (S. C. and N. D. excluded)

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genfed
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                                        CFRs from 1981 —

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ADMINISTRATIVE LAW RESEARCH  — FEDERAL
LIBRA!!;
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environ
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                       Begins 1971 —

-------
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-------
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combination of legislative
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to retreive: sara and legislative

-------
          LEGISLATIVE RESEARCH — STATE
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    LEXIS FOR
        LEGISLATIVE RESEARCH
          0
mil
• mi
 THE NATIONAL GOVERNOR'S ASSOCIATION
        SUPPORTS ONBOARD VAPOR RECOVERY

ONBOARD VAPOR CANISTERS ARE UNRELIABLE   jj
                           NHTSA

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          FEDERAL LEGISLATIVE HISTORIES—TOOLS OF THE TRADE
TOOL

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genfed/fedreg
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Press coverage

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               Does the Clean Air Act  mandate  "onboard
               vapor recovery systems" and if so,
               how?  How did the mandate become
               part of the final legislation?

                     THE  LAW

Does  the  law  mandate    onboard   vapor  recovery  systems?
(Current  vapor recovery systems recover  vapor at  the  gas
hose—not in the vehicle itself.)
     Lxe 1990 S. 1630    or    Lxe 101 pi 549     or
                    Lxe 104 stat 2399
            (Each Lexsee is a separate entry)

                    focus vapor recovery

If the bill number or  the public  law number, or the Statutes
at Large cite are  known,  the  law  may be retrieved using the
Lexsee feature. The focus feature retrieves words or phrases
within that law.   (Bill numbers may be lexseed  IF  the bill
becomes the final  law.)
To read the entire section star page to section 202.

                     .fu;p*202

If neither the bill  number, nor the public law number,
is known:

libraryrlegis   fileipublaw    search: vapor or fumes


The publaw file collects all  public laws beginning in 1988.
Over time, the words by the regulators  may become more common
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         HISTORY  OF*   THE   BXH.31.

What is the history  of the bill's passage through the 101st
Congress?

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resolutions which affected S. 1630.  BltlOl will reveal date

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of introduction  and  last action date,  (the last action date
provides clues as  to how much action there has been—if the
last action date and date of introduction are the same—the
bill has gone nowhere).  It includes sponsor, committee(s) to
which   bill   is   referred,   committee   actions,   such  as
hearings, amendments  and their  sponsors, publication  of  a
committee report and its number.   It  also includes the CRS
Digest and Index terms.  CRS or Congressional Research Service
provides  the  legislative  research  for  the  Congress.   CRS
digests and indexes  each version of each bill.  Because the
detail is great, the digest will not be online as quickly as
the other elements of the bill track records.  Index terms
are more  current.  BltlOl provides  legislative  history for
bills introduced in  the 101st Congress.
                     SPONSOR

What did the legislator behind the legislation intend for it
to accomplish?

  Lib: legis       File:101st    Search: speaker(Baucus) and
                                   clean air or s. 1630

To proceed to the introductory speech, retrieve the earliest
documents.

        COMMITTEE  MEMBERSHIP

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Committee?  If so, what is his  rank and on what sub-committee
does he serve?

library:legis     file:comtee  search:baucus and environment

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                   COMMITTEE

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Subcommittee action information is rarely available.

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                    HEARINGS

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Library:nexis        File:fednew      Search:(clean  air w/5
amendments or act) or s. 1630 or (hr or h.r. pre/3 3030)

                 focus vapor or onboard


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covers, online  next day-   Fednew  will  cover hearings where
agency administrators  testify,  and hearings of major public
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     m; and headline(hearing)


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including issuance of a  report and its number.  Sometimes,  as
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be searched  in bltrck,  to ascertain whether  they provided
amendments in committee  or  on the floor.


     To retrieve the report:

     Lib: legis File: cmtrpt    Search: clean air

               focus onboard or vapor

Cmtrpt  collects   both   conference  and  committee  reports
beginning in 1990.

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     Lib: nexis    File:  currnt   Search:  environment public
        works  w/25 clean air w/5 amendments

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committee actions, about which little is known.
                      DEBATE

The bill  track  record reveals the date on which the measure
reached the floor.

          file:blt!01          search:s. 1630
The Senate  debated the Clean Air Act  on  page S205.   Did it
include onboard vapor  recovery?

               Ixe 136 Cong Rec S 205

                 focus onboard or vapor


Lxe may retrieve more than one document, as the Cong. Rec. may
have more than one document on a page.  Use  the  star  page
feature to read an inside page.

                    p*S206
During the  debate on the Clean  Air Act,  Congressman Bliley
commented on the onboard vapor recovery systems .  What did he
say, and on what page is his statement to be found?

     Lib; legis     File:  101st    Search:   Speaker (Bliley)
     and onboard or gasoline or vapor w/8 recover!
     and bliley


The speaker segment search retrieves documents wherein Cong.
Bliley actually  speaks,  and is not simply  spoken  of.    The
Congressional  Record  is  paginated  from hard  copy and looks
like [*h!2865]  The h stands for  House section of the Record,
e for Extension of Remarks, d for Digest, s for Senate.
What bills  did the conmittee have in  front  of  it which may
provide clues as to where the idea of vapor recovery systems
may have emanated?


Lib: legis      File: btxlOl      Search: onboard or gasoline
                                     or vapor w/8 recover 1
Committees sometimes will,  from  one bill,  create a separate

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Committees  sometimes  will,  from one bill, create a separate
title for the reported bill.  Note fron the cite display that
each  document includes  the version  of  the  bill.     After
retrieving the bills, the committee report file might explain
what the committee did.
          CONFERENCE  REPORTS

Was there one?  Were onboard systems,  or the  section in which
they are  located,  or the title  discussed?   To retrieve the
report & debate:


Librlegis    FilerlOlst      Search: conference w/5 report or
                         agreement w/8 s. 1630 or  clean air

               focus title ii or vapor or sec. 202
               or onboard

Most conference  reports are  reprinted  in  the Congressional
Record.    They  are  sometimes   referred to as  conference
agreements.    Once  the report  and  debates  about  it  are
retrieved, focus on the specific language, including section
numbers, title numbers and or words or phrases.
The conference report by itself may be retrieved from:

     Libilegis    Filercmtrpt Search: clean air


              E>RESS  COVERAGE

Press coverage of particular legislation and the steps that
legislation has taken can be invaluable in understanding the
sometimes less than clear steps Congress takes.


What  did the  press say  about the  onboard vapor  recovery
options?

     Lib: nexis  File: currnt    Search: onboard or on-board
                                         w/5 recovery

Because  the  issue  of onboard vapor recovery  is  a technical
one, the broad Nexis collection may be best, particularly its
collection  of  technology  and trade   journals.    No  date
restriction is needed; the issue is precise, and legislative
history  may  begin  before  the  Congress  which  passed  the
legislation.  Note  the  use  of  on-board  as  an alternative to
onboard because reporters use different spellings.

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If the  question of press coverage  is  to be the legislation
itself,

          Lib:nexis         File: currnt
     Search: date  aft  1988  and date bef 1991 and (clean air
     w/5 legislation or measure or bill or act or amendment or
     propos!) or (h.r. or hr  w/3 3030) or s. 1630.


Such a  comprehensive search is  necessary  because  the press
does not necessarily  use a  bill   number  and may  refer to
legislation as  "measure" or "bill"  or  "act"  or a "proposed or
proposal."  The press is also  not consistent  in using h.r. or
hr.
Did the President, at signing, make  any comments which might
be helpful in interpreting intent of this legislation? Did he
say anything   about vapor recovery?
library:  genfed  file: presdc  search:  Clean air w/5
                                     amendments or act

             .fo vapor or fumes or onboard

The  Presdc  file   (the  Weekly  Compilation of  Presidential
Documents)  will include statements  the president  makes at
signing (or not signing) legislation.
Have any agencies  begun  to issue regulations as a result of
this new law?

Lib:Genfed  File: Fedreg      Search: date is 1991 and clean
                                        air or 101-549

Because the act was passed late in 1990, we cannot expect any
regulations that year, thus  the date restriction.   Agency
"preambles" are excellent  sources of intent language.
Was the issue of onboard vapor recovery systems raised during
debate on the 1977  Clean Air Amendments?

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Lib: legis   File: caa   Search; vapor recovery

The envirn library contains 4 complete legislative histories,
one of which is for the Clean Air Act.
          FUTURE  LEGISLATION

Is the  issue  of the Clean Air  Act and automobile emissions
back before the current Congress?

library:legis     file:bills     search:clean air and automo!
                                   or vehicle w/10 emission.

The bills file combines the track record and the full text of
all bills  and resolutions and  all versions thereof for the
current Congress.
           STATE

What legislation is currently, or  recently, been before state
legislatures which  address  the issue of clean  air  as it is
affected by gasoline?  Have any of  the bills been signed into
law?  Retrieve the California bills.

     Lib: legis   File: sttrck   Search: clean air


The sttrck file provides bill number, synopsis, index terms,
and sponsor.  Note  the index terms used and add them to the
search:

          m;or air quality and gasoline or petroleum
                .fo  governor or overrid!

Always begin the search with  as few words as possible note the
index terms and thereby broaden the number of documents.  Then
add the second issue.

California  bill No.   2521  was  signed  by  the Governor  on
September 22, 1990.   Does  it mention onboard vapor recovery
systems?

          Ixe to signed legislation using bill number
          as cite

          .fo vapor or onboard

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               BILL VERSION DEFINITIONS
Agreed to House/Senate:  A House/Senate resolution that
 has been agreed to by the House/Senate.

Engrossed Amendment:  A House or Senate bill or resolution
 that has passed one chamber and been referred to the other.
 That chamber, in passing (engrossing) the measure, has
 amended it.  The measure must then return to the other
 chamber, which must agree to it, before the measure
 proceeds to the President.

Engrossed in the House/Senate:  Passed by the House/Senate.
 For simple resolutions, action is complete.

Enrolled:  A bill or resolution has passed by both chambers
 and thus cleared for Presidential signature.

Held at Desk:  A bill not yet referred to committee or ready
 for floor action.

Introduced in the House/Senate:  A bill or resolution
 introduced, read, and referred to committee.

Placed on Calendar:  A Senate measure (or one from the
 House ready for Senate action) scheduled for debate.

Public Print: A bill with amendments incorporated into its
 •text, as opposed to the Engrossed Amendment version,
 where only the text of the amendment is printed.

Received in House/Senate: A bill or resolution received
 from the opposite chamber.

Referred in House/Senate: A bill or resolution received
 from the opposite chamber and referred to committee.

Reported in House/Senate: A bill or resolution reported
 from the committee(s) to which it was referred.

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     STATE LEGISLATIVE RESEARCH—A TASK-ORIENTED APPROACH
    RESEARCH WHEN SPECIFIC INFORMATION IS KNOWN:

    A.  Washington State  Representative Talmadge has
        sponsored a bill which seeks to change certain
        requirements for local initiatives.  How
        far has it progressed?
        lib: codes  file: watrck   search:sponsor(talmadge)
                                         and initiative
        Watrck includes progress of each bill through
        the state legislative process.  The sponsor
        segment contains only the legislator's last name.
    B.  Washington House bill 1025—who sponsored it?
        Has it progressed beyond introduction?
        lib: codes  file: watrck  search: 1025
    C.  Did House Bill 2929 ever pass the legislature?
        If it did, did the final bill define "agricultural
        land?"
        lib: codes  file: watrck   search: 2929
               Ixe 1990 wa hb 2929
               .fo agricultural land

        For all legislation signed by the governor, or
        overriden by the legislature, the full text of the
        final bill can be retrieved through Lexsee.  Any
        particular phrases or words can be retrieved through
        Focus.
II.  TRACKING LEGISLATION WHEN TOPICS ARE KNOWN

     A.  The issue of a waiting period prior to purchase
         of a handgun is before the Congress.  Has the
         Washington state legislature ever considered such
         a law?

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    lib: codes   file: watrck     firearm or handgun

    In retrieving a collection of bills, any search
    should use a minimum or words; note the subject
    terms used by Statenet—add them with a modification
    using the "or" connector.

               .fo waiting period
B.  What bills has the Washington state legislature
    considered which addressed the issue of
    nuclear waste storage?  Which were signed by
    the governor?
    lib: codes   file: watrck      search:nuclear or
                                   radioactive or
                                   atomic w/10 stor!

               .fo governor or overrid!
C.  Retrieve notice of both federal and Washington state
    legislation which addresses the  issue of toxic waste
    disposal.
     lib: codes     file:bltrck,watrck  search: hazard!
                                        or toxic w/10
                                        material or waste

     State  and federal  bill  tracking can  be followed
     through stacking the federal and all the state, or
     particular states.

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