United States 

Environmental Protection 

Agency 

&EPA 

Region 10 

1200 Sixth Avenue 

Seattle WA 98101 

Alaska 

Idaho 

Oregon 

Washington 

,.._\ DEPARTMENT OF 

ECOLOGY 

State of Washington 

September 4, 1992 

To ask about available formats for the visually impaired call 

360-407-7472. Persons with hearing loss can call 711 for 

Washington Relay Service. Persons with a speech disability 

Reply to 

Attn of: WD-139 can call877-833-6341. 

Michael T. Llewelyn, Program Manager 

Water Quality Program 

Washington Department of Ecology 

P.O. Box 47600 

Olympia, WA 98504-7600 

Re: 

Dear 

Approval of Total Maximum 

Snohomish River 

Mr. ~__.JZ/ 

Daily Load (TMDL) for Lower 

I am pleased to approve the following TMDL and associated 

wasteload allocation that was submitted by your Department on 

March 9, 1992: 

Waterbody 

Segment 

Water body 

Name 

TMDL 

Parameter 

WA-07-1010 Lower Snohomish River Dioxin 

Dioxin controls have been established to ensure compliance 

with the state's narrative water quality standard for toxic 

substances. A wasteload allocation has been implemented 

through effluent limitations in a National Pollutant Discharge 

Elimination System (NPDES) permit for the Weyerhaeuser Paper 

Company, Everett Kraft Mill (NPDES Permit No. WA-000300-0). 

Since the mill is currently closed, actual discharge levels are 

expected to be well below those authorized in the NPDES permit. 

By EPA's approval of this TMDL, it is now incorporated 

into the state's water quality management plan. 

cc: Lynn Singleton, Ecology 

Steve Butkus, Ecology 

Will Kendra, Ecology 

Sincerely, 

{!/~ Charles E. Findley, Director 

Water Division 
United States 

Environmental Protection 

Agency 

&EPA 

Reply to 

Attn of: WD-139 

MEMORANDUM 

Region 10 

1200 Sixth Avenue 

Seattle WA 98101 

AUG 181992 

Alaska 

Idaho 

Oregon 

Washington 

SUBJECT:Recommendation for TMDL Approval 

Lower Snohomish River - dioxin 

FROM: 

TO: 

• 

• 

Amber Wong, Standards to Permits Specialis~,,~~ Water Quality Section [) 

File 

TMDL submitted March 9, 1992 

TMDL package completed August 18, 1992 

EPA Approval Checklist 

Document 1: Transmittal letter 

Document 2: TMDL document 

Document 3: Industrial Section, Washington 

Department of Ecology. 1990 (version 2.0), 

Proposed Effluent Limitations for Dioxin and AOX, 

Olympia, WA 

Document 4: Letter from Richard Burkhalter, 

Ecology to Dave Ragsdale, EPA-WOO, transmitting 

new TCDD and AOX effluent limits, dated January 

29' 1991 

Document 5: Public participation, public notice 

and public hearing documentation 

Document 6: NPDES Permit No. WA-000300-0, 

Weyerhaeuser Paper Company (Everett Kraft Mill), 

issued May 10, 1991, amended May 24, 1991, amended 

February 20, 1992. 

expiration date: May 10, 1996 

Document 7: Fact Sheet for Weyerhaeuser Paper 

Company (Everett) NPDES permit; dated ~ugust 24, 
1990 

Document 8: Response to comments received during 

public hearings and public notice of Weyerhaeuser 

Paper Company (Everett) NPDES permit, dated July 

22, 1991; also, see addendum to Public 

Responsiveness summary 

Transmittal letter - Complete (see Document 1) 

• states that TMDL has been established in accordance 

with Section 303(d) (1) of the Clean Water Act. 

• Review note: meets requirements 

Problem Assessment - Complete (see Document 3) 

Background 

• Framework for TMDL came from EPA Dioxin Strategy 

(1983), National Dioxin Study, five-mill study (1987), 

U.S. EPA-Paper Industry Cooperative Dioxin Study (104 

mill study, 1988). 

• On October 20, 1988, EPA issued an interim strategy for 

regulating dioxin discharges from existing mills. The 

strategy set out proposed interim control measures for 

chlorine minimization and suspended solids controls, 

but stopped short of designating effluent limits. 

• On June 9, 1989, pursuant to Section 304(1) of the 

Clean Water Act, Ecology listed 8 pulp mills as 

violating water quality standards for the priority 

pollutant TCDD. Weyerhaeuser Paper Company (Everett), 

discharging to the Lower Snohomish River, was on this 

list. An Individual Control Strategy (ICS), defined as 

a water quality-based permit, was required for this 

facility. Derivation of the TMDL for the Lower 

Snohomish River for TCDD was part of developing the 

permit. 

Assessment 

• The applicable water quality criterion for TCDD is 

0.014 ppq, based on a 10 -6 risk level and ingestion of 

aquatic organisms only (no drinking water component) . 

• Data from Weyerhaeuser Paper Company (Everett) showed 

measurable quantities of dioxin in the plant effluent. 

These values showed that existing effluent from this 

facility would cause violations of the dioxin water 

quality standard. In addition, dioxin was found in 

2 
fish and shellfish samples taken near the mill. 

One major point source [Weyerhaeuser Paper Company 

(Everett) was identified. It did not have existing 

controls for TCDD. 

• Review notes: Problem assessment accurately gives 

background information, identifies exceedence of water 

quality standard for dioxin due to one major point 

source in the waterbody. supporting information -

effluent, fish data - quantify Weyerhaeuser's 

contribution. 

TMDL document - Complete (see Document 2) 

E States that a loading capacity of 0.19 mgjday has been 

established for the Lower Snohomish River (see Document 

8: Response to Comments, page 21 of 31). 

E Review note: Clearly identifies the load capacity for 

the TMDL. Clearly links this to the water quality 

criterion of 0.014 ppq. Concisely summarizes the 

implementation and monitoring followup (through the 

NPDES permit). References the supporting technical 

documents. 

Supporting Studies - Complete (see Documents 3 and 4) 

E TCDD permit limits for the point source (WLA) were 

calculated based on compliance with the water quality 

criteria, taking into account the tidal prism and 

dilution analysis of the outfall to the Lower Snohomish 

River. Three factors in calculating the WLA were: 1) 

the applicable water quality criterion of 0.014 ppq, 2) 

the harmonic mean flow of 14,070 cfs for the Lower 

Snohomish River (documents 4 and 8), and 3) the 

fraction of the dioxin loading capacity reserved for 

the Snohomish River (0.4037). Based on this analysis, 

the long term TCDD loading for the Lower Snohomish 

River is 0.19 mgjday. 

• NPDES permit limits were calculated according to the 

statistical method outlined in EPA's Technical Support 

Document for Water Quality-based Toxics Control. This 

statistical method takes effluent variability and 

sampling frequency into account. The annual average 

load for the mill = 0.36 mgjday. The daily maximum 

limit = 0.59 mgjday. 

E Weyerhaeuser must meet this level by March 8, 1994. 

• Weyerhaeuser permit issued May 10, 1991. 

3 
First amendment: May 24, 1991. 

Second amendment: February 20, 1992. 

Review notes: Documentation clearly gives basis for 

calculating the TMDL. Tidal prism and dilution 

calculations were used for determining the TCDD loading 

for the Lower Snohomish River. Calculation of the WLA 

- fine. Permit limits to implement the TMDL were 

calculated according to EPA guidance. The date for 

meeting the effluent limits falls within guidelines. 

Public participation - Complete (see Document 5) 

B Public notice of the Weyerhaeuser permit and wasteload 

allocation from August 21, 1990 to October 3, 1990. 

Public hearing on the permit on September 26, 1990. 

• Review notes: Adequate public participation. 

Enforceability - Complete (see Documents 6, 7) 

• NPDES Permit No. WA-000300-0, Weyerhaeuser, Everett 

• Review notes: Valid permit and supporting documentation 

with applicable conditions 

TMDL effectiveness plan - Complete (see Document 6) 

• In permit: effluent and sludge monitoring for dioxins, 

furans, adsorbable organic halogens; ambient 

bioaccumulation. 

• Review notes: Adequate monitoring to assess compliance 

with the TMDL. 

Current Status of the Mill 

• The mill ceased operations earlier this year. 

Discharge of dioxin, if any, should be well below the 

level authorized in the NPDES permit. The mill has not 

formally asked for revocation of their NPDES permit, so 

the permit limits and conditions are still applicable. 

Recommendation, approve TMDL. 

ALW, 8/18/92 

4 
,_ ____ _ 

Page of 2 

TMDL Number: 07-001 

TOTAL MAXIMUM DAILY LOAD 

Department of Ecology 

P.O. Box 47600 

Olympia, WA 98504-7600 

Developed pursuant to 40 CFR 130.7 and the Federal Clean Water Act 

WATERBODY SEGMENT: WA-07-1010 

Lower Snohomish River 

(mouth and east of longitude 122• 13'40"W 

to latitude 47• 56'30"N- Snohomish RM 8.1) 

TMDL PARAMETER: 

2,3,7,8 TCDD (Dioxin) 

SOURCES COVERED BY THIS TMDL: 

Allocation 

Type Source Description 

WLA Weyerhaeuser at Everett 

RECEIVING SYSTEM INFORMATION: 

Basin: Snohomish 

Counties: Snohomish 

APPLICABLE RULES: 

WAC 173-201-047(3) 

WAC 173-201-047(4) 

A TMDL for 2,3,7,8 TCDD of 0.19 mg per day to the Lower Snohomish River. This 

loading rate has been shown to be consistent with the narrative state water 

quality criterion of 0.014 ppq and the long term harmonic mean flow of 14,070 cfs 

for Steamboat Slough. 
Page 2 of 2 

TMDL Number: 07-001 

Technical Documents: 

Industrial Section, Washington Department of Ecology. 1990 (version 2. 0) . 

Proposed Effluent Limitations for Dioxin and AOX. Olympia, WA. 

Burkhalter, R.A. New TCDD and AOX Effluent Limits. Letter to Dave Ragsdale 

dated January 29, 1991. 

Addendum to Public Comment Responsiveness Summary for the Weyerhaeuser Mill at 

Everett. dated June 12, 1991. 

Implementation: 

The WLA has been incorporated into the draft permit. The permit has been 

appealed. Final action on the permit awaits the decision on the appeal. 

Monitoring: 

The draft permit under appeal requires ambient moni taring to assess TMDL 

implementation be conducted by the permittee before 180 days of the permit 

expiration for bioaccumulation of TCDD in 4 species; Starry Flounder, Sandab, 

Mussels, and Crab.