....._---' Page 1 of 2 TMDLNumber: 10-001
TOTALMAXIMUMDAILYLOAD

Department ofEcology P.O. Box 47600 Olympia, WA**98504~7600** Developedpursuant to 40 CFR 130.7 and the Federal CleanwaterAct WATERRODY SEGMENT: WA-10-0020 RECEIVINGSYSTEM INFORMATION: Commencement Bay (Inner) (S. andE.of linebearing 225 true

throughHylebos waterway Light to the mouthofPuyallupRiver, excludes City Waterway) Basin: County: puyallup-White Pierce

TMDLPARAMETER: 2,3,7,8 TCDD (Dioxin) SOURCES COVEREDBYTHIS TMDL: APPLICABLERULES: WAC 173-201-047(3) WAC 173-201 047(4) Allocation Type WLA Source Description Simpsonat Tacoma

ATMDL for 2,3,7,8 TCDDof0.07 mgperday to the StraitofJuandeFuca. This loading rate has been shown to be consistent with the narrative state water quality criterion of 0.014 ppq at the edge ofthe mixing zone. Technical Documents: Industrial Section, Washington Department of Ecology. 1990 (version 2.0). ProposedEffluent Limitations for Dioxin andAOX. Olympia, WA. 

### Publication#92-10-201Page 2 of 2 TMDL Number: 10-001 Implementation: TheWLAhasbeen incorporatedinto theNPDES permit issuedJune 25, 1991 through an interim control program. Monitoring: Ambient monitoring to assess TMDL implementation will be conducted by the permittee before January 28, 1996 for bioaccumulation of TCDD in 4 species; starry Flounder, Sandab, Mussels, and Crab.UnitedStates EnvironmentalProtection Agency

Replyto Attnof: WD-139 MEMORANDUM Region10 1200SixthAvenue SeattleWA98101 

# APR301992 Alaska Idaho Oregon Washington

FROM: SUBJECT:Recommendation for TMDLApproval Commencement Bay (Inner) - dioxin 

### AmberWong, Standards to Permits coordinatOJ;o;'t.L..,,-

# tJ(~ Water Quality section 

# U TO:

# • • File TMDL submittedMarch 9, 1992 TMDLpackage completedApril 30, 1992 EPAApproval Checklist Document 1: Transmittal letter Document 2: TMDL document Document 3: Industrial section, Washington Department ofEcology. 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 andAOX effluent limits, dated January 29, 1991 Document 5: Public participation, pUblic notice and pUblic hearing documentation Document 6: NPDES PermitNo. WA-000085-0 (Simpson-Tacoma Kraft Company), issuedJune 25, 1991, expiration date June 25, 1996 Document 7: Department ofEcology OrderNo. 91- I059,to Simpson-Tacoma Kraft CompanyDocument 8: Fact Sheet for Simpson-Tacoma NPDES permit, revised June 25, 1991 Document 9: Response to Comments received during pUblic notice of simpson-Tacoma NPDES permit, dated August 21, 1991 Transmittal letter - Complete (see Document 1)
• states that TMDLhas been established in accordance with section 303(d)(1) ofthe CleanWater Act.
• Review note: meets requirements ProblemAssessment - 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 ofdesignating effluent limits.
• On June 9, 1989, Ecology listed 8 pUlp mills as violating water quality standards for the priority pollutant TCDD pursuant to section 304(1) ofthe Clean Water Act. simpson-Tacoma, discharging to Inner Commencement Bay, was one ofthese. An Individual Control Strategy (ICS), defined as a water qualitybased permit, was required for Simpson-Tacoma. Derivation ofthe TMDL for CommencementBay for TCOD was part of developing the permit. Assessment
• The applicable water quality criterion for TCOD is 0.014 ppq, based on a 10 -6 risk level and ingestion of aquatic organisms only (no drinking water component).
• Data from Simpson-Tacoma showed measurable quantities of dioxin in effluent and sludge. These values showed that existing effluent would cause violations ofthe dioxin water quality standard.
• only one point source (simpson) was identified, which had no existing controls for TCDO. 2• Review notes: Problem assessment accurately gives background information, identifies exceedence ofwater quality standard for dioxin due to one point source in the waterbody. supporting information - effluent, sludge, fish data - quantify simpson's contribution. TMDL document - Complete (see Document 2)
• states that a load of 0.07 mg/day has been established for the point source.
• Review note: Clearly identifies the load capacity for the TMDL. clearly links this to the water quality criterion. concisely summarizes the implementation and monitoring followup (through the NPDES permit). Clearly references the supporting technical documents. Supporting Studies - Complete (see Documents 3 and 4)
• TCDD limit (WLA) was calculated based on compliance with the water quality criteria at the edge ofthe dilution zone. Three factors in calculating the WLA were: 1) applicable water quality criterion of 0.014 ppq, 2) dilution of 90:1, and 3) background concentration in Commencement Bay of 0.007 ppq (50% of the water quality criterion for TCDD). TCDD limit = 0.63 ppq.
• Mill final effluent flow averages 28.8 mgd. Combined bleachplant effluent flow is estimated at 2.5 mgd. Combined bleachplant effluentTCDD concentration is 7.3 ppq.
• For compliance purposes, annual average load for this mill

## =0.07 mg/day. Daily maximum limit is 0.13 mg/day. For compliance with the daily maximum limit, the final effluent concentration is 1.2 ppq.
• Simpson mustmeet this level by March 8, 1994.
• Permit issued June 25, 1991.
• Review notes: Documentation clearly gives basis for calculating the TMDL. Although dilution calculation is relatively simple, it is valid in the absence ofmore sophisticated analysis. Consideration ofa margin of safety (50%) is good. Calculation of the WLA - fine. Clarification of the number to be used for compliance purposes is good. The date for meeting the effluent limits falls within guidelines. Public participation - Complete (see Document 5) 3• Public notice ofthe permit and load allocation from September 7, 1990 to October 23, 1990. Public hearing on the permit on October 16, 1990.
• Review notes: Adequate pUblic participation. Enforceability - Complete (see Documents 6,7,8 and 9)
• NPDES Permit No. WA-000085-0, Simpson-Tacoma
• Review notes: Valid permit with applicable conditions TMDL effectiveness plan - Complete (see Document 6,7, and 8)
• In permit: ambient monitoring - sediment (in vicinity of outfall), bioaccumulation.
• related monitoring - Superfund action on the St. Paul Waterway, monitoring ofthe cap placed on contaminated sediments. Monitoring plan spelled out in separate document.
• Review notes: Adequate monitoring to assess compliance with the TMDL. Recommendation, approve TMDL. ALW, 4/30/92

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