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Eco-System Recovery:
Liftings of Fish Consumption Advisories for Dioxin Downstream of U.S. Pulp Mills

The Alliance for Environmental Technology

September, 1996


Table of Contents


Executive Summary

Fish advisories have become an issue of concern for both anglers and those government agencies charged with safeguarding public health. In response to this growing concern, the Alliance for Environmental Technology (AET) conducted an analysis of U.S. Environmental Protection Agency (EPA) and state environmental and health authority data for fish consumption advisories. The analysis reveals three important findings regarding fish consumption advisories for dioxin.

Most important is the finding that the number of waterbodies under a dioxin advisory downstream of U.S. bleached chemical pulp mills is a very small and diminishing percentage of the overall total of affected waterbodies in the country.
The Report's Findings:
  1. First, according to the AET analysis, the number of waterbodies, such as lakes, rivers, or bays, under a dioxin advisory represents just over 2 percent of the total number of affected waterbodies in the U.S. According to EPA's 1995 National Listing of Fish and Wildife Consumption Advisories (NLFWCA), there are currently 1,740 waterbodies under some type of advisory restricting fish or shellfish consumption (See Figure 1). Of this total, 55 waterbodies are under a consumption advisory for dioxin.
  2. Second, for waterbodies downstream of U.S. bleached chemical pulp mills, dioxin advisories are rarer still. Of the total 1,740 affected waterbodies, there are only 18 advisories downstream of bleached chemical pulp mills, amounting to about one percent of the 1,740 total.
  3. Third, the small number of waterbodies downstream of U.S. bleached chemical pulp mills that are under a dioxin advisory has steadily diminished. Since 1990, 13 states have cleared, i.e., lifted, dioxin advisories from 17 waterbodies downstream of pulp mills, which is more than half the total of 30 such advisories in effect at the end of 1990.

Process changes in pulp manufacture, including the increased use of chlorine dioxide as a bleaching agent, have markedly reduced dioxin discharges and tissue levels in fish living in mill receiving waters. In fact, dioxin levels in mill waste water are now non-measurable at 90 percent of U.S. pulp mills. State officials lift advisories once dioxin fish tissue levels drop and remain below state action levels.

In addition, the number of waterbodies downstream of pulp mills under a dioxin advisory is projected to continue downward. In an EPA study of current dioxin advisories, all such advisories would be lifted following implementation of Agency-proposed measures, which are the same, in this respect, as bleaching with chlorine dioxide.



State Fish Consumption Advisories

State environmental and health departments issue fish consumption advisories or bans to protect sport and subsistence anglers, and the general public, from the risk of consuming locally caught, contaminated fish.

Fish consumption advisories are based on the contamination levels of specific target chemicals, which include, among others, mercury, PCBs (polychlorinated biphenyls), and various pesticides. As such, these advisories are one indicator of the environmental status of a particular aquatic eco-system, for example a lake, bay, or river. Removing or partially rescinding a fish consumption advisory or ban generally signals positive change in the aquatic eco-system under study.

Since 1989, when EPA completed the first national survey of state fish/shellfish advisory programs, the number of states reporting advisories has increased, as has the total number of advisories. In 1995, forty-seven states, the District of Columbia, and the Territory of American Somoa, reported a total of 1,740 waterbodies under some type of advisory restricting fish/shellfish consumption, representing more than a 14 percent increase over 1994 data [1].

The 1995 EPA NLFWCA shows the total number of active advisories on which each target contaminant appears. As shown in Table 1, mercury is listed on 1,308 advisories, PCBs on 438, and all pesticides on 195. b Dioxin appears on 55 advisories.



Dioxin Advisories

In 1995, only 18 waterbodies in 13 states have a dioxin advisory downstream of bleached chemical pulp mills. These 18 affected waterbodies represent about one percent of the total 1,740 U.S. waterbodies under some type of an advisory. Figure 2 shows these 13 states and, for each, indicates the number of waterbodies downstream of bleached chemical pulp mills that are under a dioxin advisory.

The EPA National Dioxin Study conducted in the mid-1980s provided one of the first indications that bleached kraft pulp mills were a possible source of dioxin. Following this study, and as a result of other work such as the "104 Mill Study" conducted jointly by EPA and industry in 1988, scientists identified dioxin as an inadvertent by-product of the prevailing pulp bleaching process [2].

Figure 3 shows the yearly number of waterbodies downstream of pulp mills placed under a dioxin advisory. The single largest yearly increase -- 17 waterbodies in 1990 -- was due to increased federal and state regulatory attention following the results of the national dioxin studies. As a result of process changes at bleached kraft mills, the number of new waterbodies placed under advisory dropped sharply in subsequent years. In fact, no new waterbodies were placed under a dioxin advisory in 1992, 1993, or 1995. These process changes and the resulting dioxin advisory liftings, are discussed in the following sections.

These 18 dioxin advisories downstream of bleached chemical pulp mills are a small and diminishing percentage of the overall total of affected waterbodies in the country. Moreover, it is noteworthy that there are no dioxin advisories on waterbodies downstream of more than 75 percent of U.S. bleached chemical pulp mills, according to EPA's 1995 NLFWCA, and data from state environmental and health authorities.



Industry and Eco-system Responses

In response to the discovery of dioxin as an inadvertant by-product of the prevailing bleaching process at kraft mills, the pulp and paper industry introduced a number of technical changes and process modifications. These modifications included, among others, precursor-free defoamers, improved brown stock washing, and low multiple bleaching.

Key to the industry's dioxin reduction strategy has been the increased substitution of chlorine dioxide for chlorine gas as a bleaching agent [3]. As a result of the increased use of chlorine dioxide, and the other technical and process changes adopted by the industry, dioxin discharges have dropped considerably and, in most cases, have been virtually eliminated [4]. More than 90 percent of U.S. mills are at or below a dioxin final effluent concentration of 10 parts per quadrillion, the nominal "minimum level" that can be measured, according to the National Council for Air and Stream Improvement (NCASI) [5].



Dioxin Advisory Liftings

Since 1990, states have lifted fish consumption advisories for dioxin, demonstrating that current and declining levels of dioxin in receiving waters downstream of bleached chemical pulp mills are an insignificant risk to the aquatic eco-system. State environmental and health authority data show that since 1990, 13 states have lifted dioxin advisories on 17 waterbodies downstream of pulp mills.

As previously discussed, fish tissue levels of dioxin downstream of bleached chemical pulp mills have dropped significantly following process changes made since dioxin was first linked to pulp bleaching. In general, states lift advisories when the dioxin levels in tissue samples taken from fish species in the waterbodies of concern decline below the state's action level, and remain below this level during subsequent samplings.



Future Prospects

Recently, the Maine Department of Environmental Protection issued the 1994 findings of its Dioxin Monitoring Program, which indicate that "concentrations of dioxin in fish tissue have declined in recent years." [6].

Demonstrating the industry's continued commitment to environmental protection, in April of this year, Maine's seven pulp mills, together with the Governor, announced a mutual plan to eliminate dioxin discharges from mills along the Kennebec, Androscoggin, and Penobscot Rivers within four years [7].

Furthermore, EPA has stated that process changes to reduce the formation and discharge of dioxin in mill effluent will provide for the potential lifting of fish advisories at sites downstream of pulp mills [8]. In an analysis of the remaining dioxin advisories, using the Dioxin Reassessment Evaluation model approach and the EPA's proposed Best Available Technology (BAT) options, the agency found that all remaining dioxin advisories downstream of pulp mills could be lifted once the proposed guidelines are implemented [9]. Figure 4, shown below, consistent with EPA's projections, shows the declining number of waterbodies under a dioxin advisory.

More recently, on July 15, 1996, EPA published a notice in the Federal Register announcing its preliminary conclusion regarding the technology basis for BAT options as part of its pulp and paper Cluster Rule. The Cluster Rule, once promulgated, will set effluent limitations and pretreatment guidelines for all pulp, paper, and paperboard mills. Both of the options proposed by EPA include the complete (100 percent) substitution of chlorine dioxide for chlorine as the key process technology [10].



References

  1. U.S. EPA. June 1996. Update: National Listing of Fish and Wildlife Consumption Advisories, Fact Sheet. U.S. Environmental Protection Agency, Office of Water. EPA-823-F-96-006.
  2. U.S. EPA. 1990. U.S. EPA/Paper Industry Cooperative Dioxin Study, "The 104 Mill Study": Statistical Findings and Analyses. U.S. Environmental Protection Agency, Office of Water Regulations and Standards.
  3. Luthe, C.E. et al. 1992. An Evaluation of the Effectiveness of Dioxin Control Strategies on Organochlorine Effluent Discharges from the Canadian Bleached Chemical Pulp Industry. Pulp and Paper Canada. 93:9.
  4. Solomon, K. et al. 1994. A Review and Assessment of the Ecological Risks Associated with the Use of Chlorine Dioxide for the Bleaching of Pulp. Submitted to the Journal of Pulp and Paper Science.
  5. National Council of the Paper Industry for Air and Stream Improvement. June 1993. Summary of Data Reflective of Pulp and Paper Industry Progress in Reducing the TCDD/TCDF Content of Effluents, Pulp and Wastewater Treatment Sludges. NCASI Special Report 93-08.
  6. State of Maine, Department of Environmental Protection. Press Release, June 8, 1995.
  7. Boston Sunday Globe. "Maine Has Pact With Mills to Cut Dioxins in Rivers." April 21, 1996.
  8. U.S. EPA. December 1993. 58 Federal Register 66078, 66160. (12/17/93).
  9. U.S. EPA. November 1993. Regulatory Impact of Proposed Effluent Guidelines and NESHAP for the Pulp, Paper, and Paperboard Industry. U.S. Environmental Protection Agency, Office of Water Regulations and Standards.
  10. U.S. EPA. July 1996. 61 Federal Register 36837. (7/15/96).


Appendices
Appendix A: 1995 EPA National Listing of Fish Consumption Advisories (NLFCA)
Appendix B: Sample Fish Consumption Advisory
Appendix C: Waterbodies Under a Dioxin Advisory Downstream of Pulp Mills
Appendix D: Remaining Dioxin Advisories Near Other Industrial Sites
Appendix E: Waterbodies Cleared of Advisories for Dioxin



b. Because some fish advisories include more than one contaminant, some waterbodies may appear more than once in the 1995 EPA NLFWCA listings. The 1995 NLFWCA shows the breakdown of these listings by the number of affected waterbodies.