UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
VXXfTJLJ	WASHINGTON, D.C. 20460
,	WATER
MEMORANDUM
SUBJECT: Interim Strategy for the Regulation of Pulp and Paper
^Jflill Dioxin Discharges to the Waters of the United
' Sjbates
—-
FROM:	Rebecca W. Hanmer
Acting Assistant Administrator for Water (WH-556)
TO:	Water Management Division Directors
NPDES State Directors
EPA's goal is to eliminate the presence of dioxin in
discharges from pulp and paper mills to the waters of the United
States. Attached is an interim strategy for the regulation of
dioxin discharges from these mills. This interim strategy calls
for (1) aggressive action to fully implement or, where necessary,
to develop State water quality standards for dioxin applicable to
all water bodies where mills using chlorine bleach processes are
discharging; (2) collection of data on each of the 104 affected
mills, including dioxin levels in their pulps, effluents and
sludges? (3) detailed technical evaluation of wastewater
treatment technologies and/or in-process changes to reduce or
eliminate the presence of dioxin in wastewater discharges; and
(4) issuance of NPDES permits that regulate and require
monitoring for dioxin, examine effluent toxicity and provide for
modification to tighten controls consistent with the final
strategy and the requirements of the Clean water Act (CWA).
Although this document should be used now, I would
appreciate having your comments on this Interim strategy and ask
that you send any comments to me on implementation of the
strategy. We plan to issue a final strategy after reviewing your
comments and the results of the EPA/Paper Industry Cooperative
Dioxin Study now underway to characterize dioxin in the pulp,
effluent and sludge of 104 pulp and paper mills.
Also, you should be aware that the office of Research and
Development (ORD) has developed an expert system which can be
used on an IBM-compatible personal computer to walk through a
dioxin exposure assessment. This expert system is now out for
peer review. ORD expects it to be available for your use this
calendar year.

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Oa on*,
We are developing material similar to the interim strategy
to address permitting of newly constructed bleach kraft pulp and
paper mills.
If you would like to discuss this, please feel free to call
Jim Elder (FTS/202-475-8488) if you have questions on NPDES
permitting; or call Martha Prothro (FTS/202-382-5400) with
questions on water quality standards, analytical studies or
evaluation of technology such as the Bioaccumulation Study or the
Cooperative Study.
Attachment
cc: Environmental Services Division Directors
Water Quality Branch Chiefs
Water Permits Branch Chiefs
Charles Elkins (TS-792)
Susan G. Lepow (LE-132W)
Mahesh Podar (PM-221)
Eric Strassler (PM-223)

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interim strategy for the Regulation of Pulp and Paper Mill
Dioxin Discharges to the Waters of the United States
EPA's.goal is to eliminate the presence of dioxin in
discharges from pulp and paper mills to the water's of the United
States. Ultimately, this goal should be reflected in National
Pollutant Discharge Elimination System (NPDES) permits based on
future national technology-based effluent guidelines and/or on
State water quality standards designed to protect aquatic life
and human health.
Four Office of Water, State, and EPA Regional activities are
necessary to achieve this goal. Many other activities related to
controlling dioxin are underway in other EPA Offices. A final
strategy for the regulation of dioxin in pulp and paper mill
discharges to the waters of the United States will be issued as
soon as possible after review of data now being developed as
discussed below.
This interim strategy calls for (1) aggressive action to
fully implement or, where necessary, develop State water quality
standards for dioxin at all sites where mills using chlorine
bleach processes are discharging; (2) collection of data on each
of the 104 affected mills, including dioxin levels in their
pulps, effluents and sludges; (3) detailed technical evaluation
of wastewater treatment technologies and/or in-process changes to
reduce or eliminate the presence of dioxin in wastewater
discharges; and (4) issuance of NPDES permits that regulate and
require monitoring for dioxin, examine effluent toxicity and
provide for modification to tighten controls consistent with the
final strategy and the requirements of the Clean Water Act (CWA).
Water Quality Standards Development
The Regions will assure that all affected states establish a
firm State water quality regulatory basis for controlling dioxin
at the affected sites as quickly as possible. To accomplish this
task, the Regions will begin immediately to work with States to
develop appropriate numerical water quality criteria for dioxin
for waters receiving discharges from the affected pulp and paper
mills. The criteria can be based upon .the existing EPA criteria
document for dioxin and/or site-specific conditions. In all
cases, initial steps necessary for the adoption of numerical
water quality criteria (or derived numeric criteria) for dioxin
should begin immediately. Such steps include completion of any
necessary exposure assessments, State selection of its preferred
risk level, and compilation of appropriate monitoring data and
background documents. A list of documents which can be used to
assist in adopting dioxin criteria, including development of
site-specific risk assessments, is attached. Public

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participation must be provided for as required by federal
regulations. In addition, the Office of Water will provide
assistance to Regions and States in specific cases.
Regions and States should confer upon and expeditiously
resolve any other State water quality standards issues including
variances or changes in use designation that need to be resolved
in order to address discharges of dioxin from pulp and paper
mills. The goal is to clear the way to set water quality-based
effluent limitations in permits and to encourage the industry to
take all steps necessary to develop technologies that will
eliminate dioxin from their discharges at the earliest achievable
date.
Regions may also need to assist States in immediate State
actions to protect human health through issuance of fish
consumption advisories or bans.
Collection of Data
EPA is now receiving data from the National Bioaccumulation
Study and the EPA/Paper Industry Cooperative Dioxin Study.
As part of the National Bioaccumulation Study, EPA is
obtaining analyses of dioxin levels in fish which have been or
are being collected near bleached kraft pulp mills. Fish tissue
data from areas near a number of these mills have already been
distributed to the Regions. Release of the data generated as
part of the Bioaccumulation Study is being handled using the
procedures established in February 1988.
The EPA/Paper Industry Cooperative Dioxin Study was signed
by all parties on April 25f 1988. As a result of this study, EPA
will receive dioxin data from 104 pulp mills that bleach chemical
pulps, including process information and dioxin analyses on
effluent, sludge and pulp from all 104 mills. Headquarters staff
will provide individual mill data to the Regions as it becomes
available. This study will be completed for all mills by April
1989.
Staff ace in the process of validating analytical methods
for dioxins in pulp mill matrices. Additionally, analytical
comparability studies are being conducted between several U.S.
and Canadian laboratories. This study will ensure that
laboratory capacity will be available for Regional and State
dioxin activities.
Technical Evaluation of Wastewater Treatment Technologies and/or
In-Process Changes to Reduce or Eliminate Dioxin Discharges
EPA has initiated a program to revise the existing pulp and
paper effluent limitations guidelines regulation, with a view

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toward establishing best available technology economically
achievable (BAT) limitations foe dioxin and other nonconventional
or toxic pollutants of concern. As a part of this activity, EPA
is evaluating the effectiveness of various process modifications,
such as oxygen delignification and chlorine dioxide bleaching, in
reducing dioxin generation and discharge. Detailed evaluation of
some of these mills has already begun.
As a part of the Cooperative Dioxin Study, the paper
industry has agreed to conduct a more intensive study of
bleaching lines at approximately 25 mills. This study includes
detailed process evaluation at mills that use a variety of
bleaching processes. The objectives of the study include
determination of the bleaching operations in which dioxin is
formed, process conditions affecting dioxin formation and factors
affecting dioxin removal from the bleaching process.
EPA staff have conducted a treatability study at two
bleached kraft facilities to evaluate total suspended solids
(TSS) and dioxin reduction resulting from coagulant and polymer
addition. When these results are final, a report of the results
will be provided to the Regions.
EPA staff will also seek information from other governments,
including Sweden and Canada, concerning their technology
evaluations, and make the information available to the Regions
and States as appropriate.
Issuance of Interim NPDSS Permits
As soon as possible, permits for the affected mills shall be
reissued or reopened to establish an appropriate best
professional judgment (BPJ) BAT effluent limitation for dioxin
for the mill. The method used for developing a BPJ BAT
limitation for dioxin for an individual mill and the limitation
itself will depend on site-specific circumstances at the
facility. The effluent limitation can be developed by first
requiring the mill to conduct a study leading to development and
implementation of short- and long-term plans for minimization of
use of chlorine and chlorine derivatives in bleach plant
operations. In-plant or other controls may be used in
determining the appropriate BPJ BAT effluent limitation. One
basis for the effluent limitation would be the reduction of
dioxin that can be achieved through optimization of suspended
solids controls, particularly from secondary clarifiers or
lagoons at biological treatment facilities. (The results of the
treatability study may be useful to assist in developing this
limitation.) Initially, the Office of Water will provide
assistance to some Regional and State permitting authorities in
developing these interim control approaches. We are now working
to identify appropriate candidate mills for which interim control
requirements will be developed. We will share the experience

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gained in developing permit provisions for these mills with other
affected Regions and States.
The interim BPJ BAT limitation should in most cases be more
stringent than the existing discharge. Compliance with these
effluent limitations will be required as soon as possible.
Dioxin effluent monitoring shall be required, but where
effluent monitoring is unlikely to provide useful data, may be
established for individual process discharges or other
appropriate in-plant locations. The Cooperative Dioxin Study
will provide dioxin data from effluents, pulps and sludges from
104 mills that bleach chemical pulps with chlorine or chlorine
derivatives. These data will be made available to the Regions
and States as they are received and may be helpful in modifying
or developing the permit monitoring requirements to reflect the
significance of the discharges. Ambient monitoring of the water
column, sediments and fish may be required in the permit or
alternatively through other mechanisms. The availability of
laboratory capacity may impact the frequency of monitoring
required.
The permit shall require both chronic and acute aquatic
toxicity monitoring, a toxicity reduction evaluation (TRE) and
other requirements as necessary to ensure the mills are working
toward a reduction, as soon as possible, of dioxin discharges
for the long-term protection of water quality and human health.
The permit shall also contain a specific reopener. The
reopener shall provide for modification of the permit to reflect
any additional information or data, including information on the
feasibility of process changes or new treatability data. The
reopener will also provide for modification, if necessary, to
reflect the final permitting strategy for dioxin in pulp and
paper effluents and any effluent guidelines limitations
promulgated for dioxins during the permit term.
Discharges from many if not all of the pulp and paper mills
will also be covered by section 304(1) of the CWA.
Interpretation of provisions of section 304(1) will be addressed
soon in proposed regulations. To the extent that pulp and paper
mill discharges of dioxin are covered by section 304(1), the
regulations will provide the Agency's permitting approach.
Attachment

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Selected Bibliography Relevant to Adopting
State Water Quality Criteria for Dioxin
"Guidelines for Deriving Water Quality criteria for the Protection
of Human Health," Federal Register, vol. 45, No. 231, p. 79347,
November 28, 1980.
Draft "Guidelines for the Preparation of Water Quality Advisories
for Human Health Protection," (Request for Science Advisory Board
Review), June 30, 1987.
"Interim Procedures for Estimating Risks Associated with
Exposures to Mixtures of Chlorinated Dibenzo-p-Dioxins and
- Dibenzo Furans (CDDs and CDFs)," [Co-authored by Frank
Gostomski], EPA 625/3-87/012, March 1987.
"Ambient Water Quality Criteria for 2,3,7,8-Tetrachloro-Dibenzo-p-
Dioxin," EPA 440/5-84/007, February 1984.
"Quality Criteria for Water - 1986," EPA 440/5-86/001, May 1987.
"Technical Support Document for Water Quality-Based Toxics
Control," EPA 440/4-85/032, September 1985.
Draft "Guidance for Establishment of Ambient Criteria to Limit
Human Exposure to Contaminants in Fish and Shellfish," (Under
Office of Water Review), June 1988.
"Interim Sediment Criteria Values for Nonpolar Hydrophobic Organic
Contaminants," Sediment Criteria Document Number 17, May 1988.
Public Review Draft, "Proposed Risk Management Actions for Dioxin
Contamination at Midland, Michigan," EPA 905/4-88-006, April
1988.
"Risk Assessment for Dioxin Contamination at Midland, Michigan,"
EPA 905/4-88-005, April 1988.
Draft "Guidance Manual for Assessing Human Health Risks from
Chemical Contamination of Fish and Shellfish," (Under Office of
Water Review), October 1987.

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