TOTAL MAXIMUM DAILY LOAD FOR

TOXIC POLLUTANTS IN

MARINA DEL REY HARBOR

PREPARED BY

CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD

LOS ANGELES REGION

AND

U.S. ENVIRONMENTAL PROTECTION AGENCY

REGION 9

FINAL REPORT: OCTOBER 6, 2005
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 ii

TABLE OF CONTENTS

1. INTRODUCTION 1

1.1 REGULATORY BACKGROUND 2

1.2 ENVIRONMENTAL SETTING 4

1.3 ORGANIZATION OF THIS DOCUMENT 8

2. PROBLEM IDENTIFICATION 9

2.1 WATER QUALITY STANDARDS 9

2.1.1 Beneficial Uses 9

2.1.2 Water Quality Objectives (WQOs) 10

2.1.3 Antidegradation 12

2.2 DATA REVIEW 12

2.2.1 Water Column 12

2.2.2 Fish and Shellfish Tissue 13

2.2.3 Sediment 15

2.3 SUMMARY AND FINDINGS CONCERNING TMDLS REQUIRED 19

3 NUMERIC TARGETS 21

3.1 SEDIMENT NUMERIC TARGETS 21

3.2 WATER QUALITY CRITERIA 22

3.3 FISH TISSUE TARGET 22

3.3.1. Deriviation of the Treshold Tissue Residue Level (TTRL) 23

4 SOURCE ASSESSMENT 24

4.1 BACKGROUND ON TOXIC POLLUTANTS 24

4.1.1 Organic Pollutants 24

4.1.2 Metals 25

4.2 POINT SOURCES 25

4.2.1 Stormwater Runofff 26

4.2.2 Summary Point Sources 27

4.3 NONPOINT SOURCES 28

4.3.1. Marina Activities 28

4.3.1.1 Copper Loading from Recreational Boats 28

4.3.2 Atmospheric Deposition 29

5 LINKAGE ANALYSIS, TMDL AND POLLUTANT ALLOCATION 30

5.1 LOADING CAPACITY 30

5.1.1 Critical Conditions 31

5.1.2 Margin of Safety 31

5.2 ALLOCATIONS 31

5.2.1 Load Allocations 32
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 iii

5.2.2 Waste Load Allocation for Storm Water 32

5.2.3 Waste Load Allocation for other NPDES Permits 34

5.2.4 Contaminated Inplace Sediment 34

5.3 SUMMARY OF TMDL 35

6 IMPLEMENTATION 36

6.1 REGULATION BY THE REGIONAL BOARD 36

6.1.1 Stormwater Discharges 37

6.2 POTENTIAL IMPLEMENTATION STRATEGIES 39

6.2.1 Non-Structural Best Management Practices 39

6.2.2 Structural Best Management Practices 39

6.3 IMPLEMENTATION COST ANALYSIS AND CEQA CONSIDERATIONS 39

6.3.1 Implementation Cost Analysis 40

6.3.1.1 Phased Implementation 40

6.3.1.2 Comparison of Costs Estimates with Caltrans Reported Costs 44

6.3.2 Results of a Region-wide Cost Study 45

7 MONITORING 47

7.1 AMBIENT COMPONENT 47

7.2 EFFECTIVENESS COMPONENT 48

7.3 SPECIAL STUDIES 49

8. FINAL TMDL MILESTONES AND IMPLEMENTATION SCHEDULE 50

8.1 FINAL TMDL MILESTONES 50

8.2 IMPLEMENTATION SCHEDULE 50

9 REFERENCES 54
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 iv

LIST OF TABLES

Table 1-1: 1998 303(d) list of metal and organic compound impairments for Marina del

Rey’s back basins 3

Table 1-2. 2002 303(d) List of metal and organic compound impairments for Marina del

Rey’s back basins 3

Table 1-3. Land Use by Sub-watershed Area for Marina del Rey Watershed 7

Table 2-1. Beneficial Uses of Marina del Rey Harbor (LARWQCB, 1994) 9

Table 2-2. Water quality objectives established in the CTR for metals and organic compounds 11

Table 2-3 Water column data for Basin E in Marina del Rey Harbor 12

Table 2-4. Fish tissue listing data from Toxic Substances Monitoring Program

(ppb, wet weight). 14

Table 2-5. Fish tissue listing data from Toxic Substances Monitoring Program

(ppb, wet weight). 14

Table 2.6: Summary of Sediment Quality Data for Marina del Rey’s back basins (96-03). 16

Table 2-7. Summary of marine sediment quality guidelines used in assessment of

TMDL pollutants 18

Table 2-8. Evaluation of sediment data relative to sediment quality guidelines 18

Table 2-9 Sediment Toxicity Data for Marina del Rey’s Back Basins – Amphipod

Survival Rates 19

Table 3-1. Numeric targets for sediment quality in Marina del Rey’s back basins 22

Table 3-2: Numeric Targets for total PCBs in the water column 22

Table 4-1. NPDES Permits in the Marina del Rey Watershed 26

Table 4-2. Annual Loading from Stormwater Water Runoff for Metals (lb/year) 27

Table 4-3. Estimate of Atmospheric Deposition of Metals to Surface Water 29

Table 5-1. Average Annual Total Suspended Solids (TSS) Loading to Marina del Rey 30

Table 5-2. Sediment Loading Capacity Expressed as Mass per Year 31

Table 5-3. Mass-based Allocations 32

Table 5-4. Areal extent of watershed and percent area covered under storm water permits 33
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 v

Table 5-5. Combined storm water allocation apportioned based on percent of watershed. 33

Table 5-6. Per acre waste load allocation for an individual general construction or

industrial storm water permittee (g/day/ac). 34

Table 5-7. Concentration-based waste load allocation for sediment discharged to Marina

del Rey Harbor. 34

Table 6-1. Estimated costs for two types of street sweepers. (Source: USEPA, 1999b.) 41

Table 6-2. Annualized sweeper costs, including purchase price and operation and

maintenance costs ($/curb mile/year). 41

Table 6-3. Estimated Costs for Infiltration Trenches. 42

Table 6-4. Estimated Costs for Austin and Delaware Sand Filters 43

Table 6-5. Total Estimated costs of structural BMP approach for stormwater discharges. 44

Table 6-6. Estimated costs of structural and non-structural compliance measures for the

entire Los Angeles Region. (Source: Devinny et al.) 45

Table 6-7. Comparison of costs for storm water compliance on a per square mile basis. 45

Table 8-1. Implementation Schedule 51
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 vi

LIST OF FIGURES

Figure 1-1 Marina del Rey Harbor 1

Figure 1-2 Marina del Rey sub-watershed areas 6
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 vii

LIST OF ACRONYMS

μg/g Micrograms per Gram

μg/kg Micrograms per Kilogram

μg/L Micrograms per Liter

BMPs Best Management Practices

BPTCP Bay Protection and Toxic Cleanup Program

Caltrans California Department of Transportation

CEQA California Environmental Quality Act

CFR Code of Federal Regulations

COMM Commercial and Sport Fishing

CTR California Toxics Rule

CWA Clean Water Act

DL Detection Limit

EMCs Event Mean Concentrations

ERL Effects Range-Low

+ERM Effects Range-Median

EST Estuarine Habitat

FHWA Federal Highway Administration

FR Federal Register

kg Kilograms

LACDPW Los Angeles County Department of Public Works

LARWQCB Los Angeles Regional Water Quality Control Board

LACDBH Los Angeles County Department OF Beaches and Harbors

MAR Marine Habitat

MdRH Marina del Rey Harbor

MGD Million Gallons per Day

mg/kg Milligrams per Kilogram

MS4 Municipal Separate Storm Sewer System

MTRL Maximum Tissue Residue Level

NAV Navigation

ng/L Nanograms per Liter

NPDES National Pollutant Discharge Elimination System

NPTN National Pesticide Telecommunications Network

O&M Operation and Maintenance

OEHHA Office of Environmental Heath Hazard Assessment

PCBs Polychlorinated biphenyls

PEL Probable Effects Level

pg/L Picograms per Liter

ppb Parts per Billion

ppt Parts per Thousand

RARE Rare, Threatened, or Endangered Species

REC1 Water Contact Recreation

REC2 Non-Contact Water Recreation

SHELL Shellfish Harvesting
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 viii

SIYB Shelter Island Yatch Basin

SQGs Sediment Quality Guidelines

SQOs Sediment Quality Objectives

TEL Threshold Effects Level

TMDL Total Maximum Daily Load

TSMP Toxic Substances Monitoring Program

US United States

USACE United States Army Corps of Engineers

USEPA United States Environmental Protection Agency

WDRs Waste Discharge Requirements

WILD Wildlife Habitat

WLAs Waste Load Allocations

WQA Water Quality Assessment

WQOs Water Quality Objectives
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 1

1. INTRODUCTION

This report presents the required elements of the Total Maximum Daily Load (TMDL)

for toxic pollutants in Marina del Rey’s Back Basins (Basins D, E and F), and

summarizes the technical analyses performed by the California Regional Water Quality

Control Board, Los Angeles Region (Regional Board) and the United States

Environmental Protection Agency, Region 9 (USEPA) to develop this TMDL.

The back basins of the Marina are listed for a variety of toxic pollutants, including

metals, organic compounds and sediment toxicity (Table 1-1). These sections of Marina

del Rey Harbor were included on the 1996, 1998 and 2002 California 303(d) list of

impaired waterbodies (LARWQCB, 1996, 1998, 2002). The Clean Water Act (CWA)

requires a TMDL be developed to restore the impaired waterbodies to their full beneficial

uses.

Figure 1: Marina del Rey Harbor

This TMDL complies with 40 CFR 130.2 and 130.7, Section 303(d) of the CWA and

USEPA guidance for developing TMDLs in California (USEPA, 2000a). In addition to

the summary of the information used in its development, the TMDL includes an

implementation plan and cost estimate to achieve the WLAs and attain water quality

objectives (WQOs) in Marina del Rey’s back basins. The California Water Code (PorterCologne Water Quality Control Act) requires that an implementation plan be developed

to achieve water quality objectives. This TMDL addresses the impairments in Basins D,

E, and F of Marina del Rey Harbor (Figure 1).
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 2

1.1 Regulatory Background

Section 303(d) of the CWA requires that each State “shall identify those waters within its

boundaries for which the effluent limitations are not stringent enough to implement any

water quality objective applicable to such waters.” The CWA also requires states to

establish a priority ranking for waters on the 303(d) list of impaired waters and establish

TMDLs for such waters. The elements of a TMDL are described in 40 CFR 130.2 and

130.7 and Section 303(d) of the CWA, as well as in the USEPA guidance (USEPA,

2000a). A TMDL is defined as the “sum of the individual waste load allocations for

point sources and load allocations for non-point sources and natural background” (40

CFR 130.2) such that the capacity of the waterbody to assimilate pollutant loads (the

loading capacity) is not exceeded. A TMDL is also required to account for seasonal

variations and include a margin of safety to address uncertainty in the analysis (USEPA,

2000a).

States must develop water quality management plans to implement the TMDL (40 CFR

130.6). The USEPA has oversight authority for the 303(d) program and is required to

review and either approve or disapprove the TMDLs submitted by states. In California,

the State Water Resources Control Board (State Board) and the nine Regional Water

Quality Control Boards are responsible for preparing lists of impaired waterbodies under

the 303(d) program and for preparing TMDLs, both subject to USEPA approval. If

USEPA does not approve a TMDL submitted by a state, USEPA is required to establish a

TMDL for that waterbody. The Regional Boards also hold regulatory authority for many

of the instruments used to implement the TMDLs, such as the National Pollutant

Discharge Elimination System (NPDES) permits and state-specified Waste Discharge

Requirements (WDRs).

As part of its 1996 and 1998 regional water quality assessments (WQAs), the Regional

Board identified over 700 waterbody-pollutant combinations in the Los Angeles Region

where TMDLs would be required (LARWQCB, 1996, 1998). These are referred to as

“listed” or “303(d) listed” waterbodies or waterbody segments. A 13-year schedule for

development of TMDLs in the Los Angeles Region was established in a consent decree

that was approved on March 22, 1999 (Heal the Bay Inc., et al. v. Browner, et al. C 98-

4825 SBA).

For the purpose of scheduling TMDL development, the consent decree combined the

more than 700 waterbody-pollutant combinations into 92 TMDL analytical units.

Analytical Unit 54 addresses the impairments in Marina del Rey back basins associated

with organic pollutants (chlordane, dieldrin, DDT, PCBs, benthic community effects, fish

consumption advisory and sediment toxicity) and Analytical Unit 56 addresses the

impairments associated with metals (lead, copper, and zinc). In addition, the Tributyltin

impairment is addressed under Analytical Unit 70. Table 1-1 presents the 1998 303(d) list

of toxic impairments in the Marina del Rey back basins The consent decree also

prescribed schedules for certain TMDLs, and according to this schedule, USEPA must

either approve a state TMDL for Analytical Units 54 and 56 or establish its own, by

March 22, 2006
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 3

Table 1-1: 1998 303(d) list of metal and organic compound impairments for Marina del

Rey’s back basins

Media Pollutant

Analytical Unit 54 Analytical Unit 56 Analytical Unit 70

Sediment DDT

Chlordane

Sediment toxicity

Lead (Pb)

Copper (Cu)

Zinc (Zn)

Fish Tissue DDT

Chlordane

PCBs

Dieldrin

Fish consumption advisory

Lead (Pb)

Copper (Cu)

Zinc (Zn)

Tributyltin (TBT)

Benthic infauna Benthic community effects

Paragraph 8 of the consent decree provides that TMDLs need not be completed for

specific waterbody by pollutant combinations if the State or EPA determines that TMDLs

are not needed for these combinations, consistent with the requirements of Section

303(d). The consent decree provides that this determination may be made either through

a formal decision to remove a combination from the State Section 303(d) list or through a

separate determination that the specific TMDLs are not needed. Paragraph 9 of the

consent decree describes procedures for giving notice that TMDLs are not needed.

On the 2002 303(d) list, the Regional Board de-listed copper, lead, zinc and tributyltin in

fish tissue. The tissue listings for these pollutants were removed because the elevated data

levels upon which the 1998 listings were based no longer reflect valid assessment

guidelines. DDT in sediment was de-listed since sediment concentrations have dropped

below sediment quality guidelines. The benthic community degradation impairment was

also de-listed since the benthic infauna was determined to be only moderately degraded.

In addition, the Regional Board added a new listing for PCBs in sediment for the Marina

del Rey back basins. Current listings are presented in Table 1-2.

Table 1-2. 2002 303(d) List of metal and organic compound impairments for Marina del

Rey’s back basins

Media Pollutant

Sediment Copper (Cu)

Lead (Pb)

Zinc (Zn)

Chlordane

PCBs

Sediment toxicity

Fish Tissue DDT

Dieldrin

Chlordane

PCBs

Fish consumption advisory
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 4

Pursuant to paragraph 8, the Regional Board determined that TMDLs are not required for

chlordane, total DDT, and dieldrin in fish tissue. More recent data shows these pollutants

to be below screening values. A more detailed discussion on these findings is provided in

Section 2.2 Data Review. This constitutes the notice as provided for in paragraph 9 of the

consent decree.

On May 6, 2003, the Regional Board held a California Environmental Quality Act

(CEQA) scoping meeting to solicit input from the public and interested stakeholders in

determining the scope, content and implementation options of the proposed TMDL for

toxic pollutants in Marina del Rey’s back basins. At the scoping meeting, the CEQA

checklist of significant environmental issues and mitigation measures were discussed.

This meeting fulfilled the requirements under CEQA (Public Resources Code, Section

21083.9).

This TMDL will address impairment of beneficial uses due to elevated concentrations of

chlordane, copper, lead, and zinc in Marina del Rey Harbor sediments, and total PCBs in

fish tissue. The sediment toxicity and fish advisory listing will be addressed by the

TMDLs waste load allocations (WLAs) and load allocations (LAs) for these toxic

pollutants. The TMDLs for nearby Ballona Creek required under Analytical Units # 55

and 57 have been addressed in a separate TMDL.

1.2 Environmental Setting

The MdR watershed is approximately 2.9 square miles located in the Santa Monica Bay,

California. It is south of Venice and north of Playa del Rey, and approximately 15 miles

southwest of downtown Los Angeles. The watershed includes the City of Los Angeles,

Culver City and unincorporated areas of Los Angeles County. The climate is warm and

dry most of the year with intermittent wet weather events typically between November

and March.

MdR Harbor (MdRH) was developed in the early 1960s on degraded wetlands that

formed part of the estuary of Ballona Creek Wetlands. MdRH, which opens into Santa

Monica Bay, was constructed by the Army Corps of Engineers and is the largest artificial

small-craft harbor in the United States. MdRH harbors more than 6,000 wet berthed slips

for privately owned pleasure craft, dry storage of approximately 3,000 boats, and launch

facilities, which can accommodate approximately 240 trailered boats. The back basins

(Basins D, E and F) house approximately 2,000 slips (Joseph Chesler, Los Angeles

County Department of Beaches and Harbors, personal communication).

The Corps of Engineers maintains the harbor entrance channel and main channel for

navigation by dredging. Since the late 1980’s, the Corps of Engineers has not been able

to use open water disposal for sediments dredged from the entrance channel due to the

elevated levels of contaminants deposited from adjacent Ballona Creek. Based on Corps

of Engineers’ hydrodynamic numerical modeling (RMA4 model) results, the contaminant

influence from Ballona Creek does not travel to nor affect the back basins (USACE

1999). Therefore, the back basins of the MdRH are assumed to be outside any significant

influence from Ballona Creek.
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 5

The MdR watershed is highly developed with high-density single family residence

(HDSFR), multiple family residence (MFR), and mixed residential comprising the

primary land use in the watershed (46.6%) followed by retail, commercial, and general

office representing the second largest land use (12.2%). The receiving waters of MdRH

constitute 11.6% of the land area and marina facilities cover 9.2% of the land use. Open

space and recreation represents 4.8% of the land use in the watershed. Light industrial

and vacant/urban vacant each represent 4.7% of the land use. The remaining 6% of land

area is covered by educational institutions (3.8%), under construction (1.2%),

institutional and military installations (0.6%), transportation (0.3%), and mixed urban

(0.2%).

For the purposes of this TMDL, the Regional Board has divided the watershed into five

sub-watersheds based on the drainage patterns provided by the Los Angeles County

Department of Public Works (LACDPW). Area 1A drains into the back basins (Basins

D, E and F) of MdRH and Area 1B drains into the rest of the MdRH area (all other

basins). Area 2 drains into Ballona Lagoon and then to the harbor entrance. Area 3

drains into the back basins via storm drains and Area 4 drains into the Oxford Flood

Control Basin (OFCB) via storm drains and then into Basin E through a tidal gate. The

sub-watersheds of the harbor are shown in Figure 1-2. See Table 1-3 for land use

breakdowns by sub-watersheds.
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 6

Figure 1-2: Marina del Rey sub-watershed areas
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 7

Table 1-3. Land Use by Sub-watershed Area for Marina del Rey Watershed

Marina del Rey Watershed (acres)

Land Use Type* Area 1A Area 1B** Area 2** Area 3 Area 4

Education 3 67

General Office 2 17

HDSFR 65 38 304

Institutional 1 9

Light Industrial 2 86

Marina Facilities 65 106

MFR 32 128 201 14 50

Military Installations 1

Mixed Residential 1 13 18

Mixed Urban 3

Open

Space/Recreation

19 65 2 3

Other Commercial 16 3 9 2

Receiving Waters 44 151 13 8

Retail/Commercial 32 30 21 94

Transportation 4 2

Under Construction 2 11 4 6

Urban Vacant 2 4 29

Vacant 53

Total 217 569 326 71 672

* Land use data was provided by the LACDPW on May 20, 2002 by Dr. T.J. Kim

** These sub-watershed areas do not drain to the back basins
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 8

1.3 Organization of this Document

Guidance from USEPA (1991) identifies seven elements of a TMDL. Sections 2 through

7 of this document present these elements, with the analysis and findings of this TMDL

for that element. The required elements are as follows:

 Section 2: Problem Identification. This section describes the nature of the

impairments addressed by this TMDL, and presents data to demonstrate the extent

of impairment. Beneficial uses of the impaired water bodies and the relevant

water quality objectives are also presented.

 Section 3: Numeric Targets. This section identifies the numeric targets

established for the TMDLs and representing attainment of water quality

objectives (WQOs) and beneficial uses.

 Section 4: Source Assessment. This section identifies the potential point sources

and nonpoint sources of organic pollutants and metals to Marina del Rey Harbor

 Section 5: Linkage Analysis, TMDL and Pollutant Allocations. This section

presents the analysis to evaluate the link between sources of toxic pollutants and

the resulting conditions in the impaired waterbody. Each identifiable source is

allocated a quantitative load or waste load allocations for the listed pollutants,

representing the load that it can discharge while still ensuring that the receiving

water meets the WQOs. Allocations are designed to protect the waterbody from

conditions that exceed the applicable numeric target.

 Section 6: Implementation. This section describes the regulatory tools, plans

and other mechanisms available to achieve the WLAs. The TMDL provides cost

estimates to implement best management practices (BMPs) required throughout

the Marina del Rey watershed to meet water quality objectives in the back basins

of the harbor.

 Section 7: Monitoring. This TMDL describes the monitoring to ensure that the

WQOs are attained. If the monitoring results demonstrate the TMDL has not

resulted in attainment of WQOs, then revised allocations will be developed

While the TMDL identifies the goals for a monitoring program, the Executive

Officer will issue subsequent orders to identify the specific requirements and the

specific entities that will develop and implement a monitoring program and

submit technical reports.
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 9

2. PROBLEM IDENTIFICATION

The listings for Marina del Rey’s back basins are based on concentrations of chlordane,

dieldrin, DDT and PCBs in fish tissue and concentrations of copper, lead, zinc,

chlordane, and PCBs in sediments. This section provides an overview of water quality

criteria and guidelines applicable to Marina del Rey and reviews the fish tissue, and

sediment and water quality data compiled for the purpose of this TMDL.

As a result of the data review conducted to prepare this section, the Regional Board

concluded that some of the 303(d) listing decisions were no longer valid. Section 2.2

describes the basis for these conclusions. Pursuant to the consent decree, TMDLs are not

required to address these listings and are therefore not developed.

2.1 Water Quality Standards

California state water quality standards consist of the following elements: 1) beneficial

uses; 2) narrative and/or numeric WQOs; and 3) an anti-degradation policy. In

California, the Regional Boards define beneficial uses in the Water Quality Control Plans

(Basin Plans). Numeric and narrative objectives are specified in each region’s Basin

Plan. The objectives are set to be protective of the beneficial uses in each waterbody in

the region and/or to protect against degradation. Numeric objectives for toxics can be

found in the California Toxics Rule (40 CFR §131.38).

2.1.1 Beneficial Uses

The Basin Plan for the Los Angeles Regional Board (CRWQCB, 1994) defines 7 existing

(E), beneficial uses for Marina del Rey Harbor (Table 2-1).

Table 2-1. Beneficial Uses of Marina del Rey Harbor (LARWQCB, 1994)

Coastal

Feature

Hydro

Unit #

NAV REC1 REC2 COMM MAR WILD SHELL

Marina

del Rey

Harbor

405.13 E E E E E E E

Beneficial use designations apply to all tributaries to the indicated waterbody, if not listed separately.

E: Existing beneficial use

There are existing designated uses to protect aquatic life that use the marine, and wildlife

habitat (MAR and WILD). There are also beneficial uses associated with human use of

the habor including recreational use for water contact (REC1), non-contact water

recreation (REC2), navigation (NAV), commercial and sport fishing (COMM), and

shellfish harvesting (SHELL).

Discharges of toxic pollutants to the harbor back basins may result in impairments of

beneficial uses associated with aquatic life (MAR and WILD), and human use of these

resources (COMM, SHELL, and REC-1).
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 10

2.1.2 Water Quality Objectives (WQOs)

As stated in the Basin Plan, water quality objectives (WQOs) are intended to protect the

public health and welfare and to maintain or enhance water quality in relation to the

designated existing and potential beneficial uses of the water. The Basin Plan specifies

both narrative and numeric water quality objectives. The following narrative water

quality objectives are the most pertinent to this TMDL. These narrative WQOs may be

applied to both the water column and the sediments.

Chemical Constituents: Surface waters shall not contain concentrations of

chemical constituents in amounts that adversely affect any designated

beneficial use.

Bioaccumulation: Toxic pollutants shall not be present at levels that will

bioaccumulate in aquatic life to levels, which are harmful to aquatic life or

human health.

Pesticides: No individual pesticide or combination of pesticides shall be present

in concentrations that adversely affect beneficial uses. There shall be no increase

in pesticide concentrations found in bottom sediments or aquatic life.

Toxicity: All waters shall be maintained free of toxic substances in concentrations

that are toxic to, or that produce detrimental physiological responses in human,

plant, animal, or aquatic life.

The Regional Board’s narrative toxicity objective reflects and implements national policy

set by Congress. The Clean Water Act states that, “it is the national policy that the

discharge of toxic pollutants in toxic amounts be prohibited.” (33 U.S.C. 1251(a)(3).) In

2000, USEPA established numeric water quality objectives for several pollutants

addressed in this TMDL in the California Toxics Rule (CTR) (USEPA, 2000b). The

CTR establishes numeric aquatic life criteria for 23 priority toxic pollutants and numeric

human health criteria for 92 priority toxic pollutants. These criteria are established to

protect human health and the environment and are applicable to inland surface waters

enclosed bays and estuaries.

For the protection of aquatic life, the CTR establishes short-term (acute) and long-term

(chronic) criteria in both freshwater and saltwater. The acute criterion equals the highest

concentration of a pollutant to which aquatic life can be exposed, for a short period of

time, without deleterious effects. The chronic criterion equals the highest concentration

of a pollutant to which aquatic life can be exposed for an extended period of time (4

days) without deleterious effects. Freshwater criteria apply to waters in which the

salinity is equal to or less than 1 part per thousand (ppt) 95 percent or more of the time.

Saltwater criteria apply to waters in which salinity is equal to or greater than 10 ppt 95

percent or more of the time. For waters in which the salinity is between 1 and 10 ppt, the

more stringent of the two criteria apply.

In the CTR, freshwater and saltwater criteria for metals are expressed in terms of the

dissolved fraction of the metal in the water column. These criteria were calculated based

on methods in USEPA’s Summary of Revisions to Guidelines for Deriving Numerical
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 11

National Water Quality Criteria for the Protection of Aquatic Organisms and Their Uses

(50 FR 30792, July 29, 1985), developed under Section 304(a) of the CWA. This

methodology is used to calculate the total recoverable fraction of metals in the water

column and then appropriate conversion factors, included in the CTR are applied, to

calculate the dissolved criteria for metals in the water column.

The human health criteria are established to protect the general population from priority

toxic pollutants regulated as carcinogens (cancer-causing substances) and are based on

the consumption of water and aquatic organisms or aquatic organisms only, assuming a

typical consumption of 6.5 grams per day of fish and shellfish and drinking 2.0 liters per

day of water. Table 2-2 summarizes the aquatic life, and human health criteria for metals

and organic constituents, covered under this TMDL.

Table 2-2. Water quality objectives established in the CTR for metals and organic

compounds

Criteria for the Protection of

Aquatic Life

Criteria for the Protection of

Human Health

Pollutant Saltwater

Acute (μg/L) Chronic (μg/L)

Water &

Organisms (μg/L)

Organisms

only (μg/L)

Chlordane 0.09 0.004 0.00057 0.00059

Total PCBs

1

- 0.03 0.00017 0.00017

Copper (dissolved) 4.8 3.1 1300 -

Lead (dissolved) 210 8.1 - -

Zinc (dissolved) 90 81 - -

1Based on total PCBs, the sum of all congener or isomer or homolog or aroclor analyses.

For PCBs, the Basin Plan states that, “Pass-through or uncontrollable discharges to

waters of the Region, or at locations where the waste can subsequently reach water of the

Region, are limited to 70 picograms per liter (pg/L) measured as a 30 day average for

protection of human health and 14 nanograms per liter (ng/L) measured as a daily

average and 30 ng/L measured as a daily average to protect aquatic life in inland fresh

water and estuarine waters, respectively.” The 30-day average aquatic life value for

PCBs in the Basin is the same as the 4-day average value in the CTR. However, the

human health 30-day average value in the Basin Plan of 70 pg/L is more stringent the

CTR value of 170 pg/L, which is also a 30-day average.

There are no numeric standards for fish tissue in the Basin Plan. The human health

criteria in the CTR were developed to ensure that bioaccumulative substances do not

concentrate in fish tissue at levels that could impact human health.

There are no water quality objectives for sediment in the Basin Plan. The Regional

Board applied best professional judgment to define elevated values for metals in sediment

during the water quality assessments conducted in 1996, 1998, and 2002. The State

Board is in the process of developing sediment quality objectives (SQOs) for enclosed

bays and estuaries, and expects to adopt these objectives and an implementation policy by

February 28, 2007. The final objectives and implementation policy would be subject to

review by the Office of Administrative Law before becoming effective. The Regional
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 12

Board will review the numeric targets in this TMDL for consistency with the final

sediment quality objectives within six months after the effective date.

2.1.3 Antidegradation

State Board Resolution 68-16, “Statement of Policy with Respect to Maintaining High

Quality Water” in California, known as the “Anti-degradation Policy,” protects surface

and ground waters from degradation. Any actions that can adversely affect water quality

in all surface and ground waters must be consistent with the maximum benefit to the

people of the state, must not unreasonably affect present and anticipated beneficial use of

such water, and must not result in water quality less than that prescribed in water quality

plans and policies. Furthermore, any actions that can adversely affect surface waters are

also subject to the federal Anti-degradation Policy (40 CFR 131.12).

2.2 Data Review

This section summarizes the data for Marina del Rey back basins for the listed toxic

pollutants in water, fish and sediments. The summary includes water quality, fish tissue,

and sediment quality data from different sources, for the period of 1993 to 2003.

2.2.1 Water Column

Although no water column impairments for Marina del Rey back basins were listed in the

current CWA 303(d) list, this was due to a lack of data rather than an indication of no

impairment. Some assessment of water quality is useful as sediment and fish tissue

concentrations are ultimately impacted by water-borne inputs of contaminants.

Conversely, high concentrations of contaminants in sediment have the potential to impact

water quality through de-sorption of chemicals into water.

No data were available for assessing water column concentrations of metals and organic

pollutants in Marina del Rey harbor at the onset of developing this TMDL. In order to

bridge this data gap, the Los Angeles County Public Works (LACDPW) collected water

column data for the listed contaminants in the summer of 2002 (June to July). The data

collected represents the results of four sampling episodes during this period (see Table 2-

3).

Table 2-3 Water column data for Basin E in Marina del Rey Harbor

Pollutant Detection

Limit

CTR

chronic

Target

6/6//02

1

6/18/05

1

7/1/02

1

7/16/02 Average

Copper* (g/L) 0.5 3.1 53 58 12.7 16.4 35

Lead* (g/L) 0.5 8.1 n.d n.d n.d 0.52 -

Zinc* (g/L) 1.0 81 55.2 39.4 96 43 58.4

Chlordane (g/L) 0.05 0.004 n.d n.d n.d n.d n.d

DDT (g/L) 0.1 0.001 n.d n.d n.d n.d n.d

Dieldrin (g/L) 0.1 0.0019 n.d n.d n.d n.d n.d

PCB (g/L) 0.5 0.03 n.d n.d n.d n.d n.d

*Values presented are dissolved metal concentrations, n.d: not detected.

1Uncertainty exists with respect to the analytical method used in obtaining this data.
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 13

Dissolved copper concentrations in Basin E ranged from 12.7 μg/L to 58 μg/L, exceeding

both the CTR chronic criterion values of 3.1 μg/L, and the 4.8 μg/L acute criterion for

salt water. Lead was not detected in three samples out of four and the only detectable

concentration was below the acute and chronic criteria for saltwater. Only one sample

exceeded the acute and chronic limits for zinc. Uncertainty exists with regard to the

validity of the analytical methods with which results for the metals were obtained - the

analytes were not removed from their salt matrix prior to analysis. Therefore, a finding of

impairment for copper in the water column cannot be made at present. Further sample

collection and analysis, using appropriate methods, will be required to make a final

determination.

There is no indication that CTR standards are exceeded for any of the organic pollutants

in Marina del Rey. However, this may be as a result of the use of analytical methods with

detection limits that are above CTR standards. Further monitoring will be necessary to

make a final determination of no impairment.

2.2.2 Fish and Shellfish Tissue

As discussed in section 2.2.1, there is limited data on water column concentrations to

address the potential for bioaccumulation in fish. Analysis of fish tissue for chemical

contaminants provides a more direct means for assessing impacts.

Maximum tissue residue levels (MTRLs) were developed by State Board by multiplying

the human health CTR water quality objectives by the bioconcentration factor for each

substance as recommended by USEPA (USEPA, 1991). These objectives represent

levels that protect human health from consumption of fish and shellfish. The MTRLs are

an assessment tool and do not constitute enforceable regulatory limits. MTRLs have

value as alert levels indicating water bodies with potential human health concerns.

However, the MTRLs are no longer used by the State to evaluate fish or shellfish tissue

data for 303(d) listing purposes. Screening values have been developed by the Office of

Environmental Health Hazard Assessment (OEHHA). These screening values relate

human health endpoints to contaminant concentrations in fish based on an average

consumption rate for fish and shellfish (California EPA OEHHA 1999).

To assess potential impairments associated with contaminant concentrations in fish

tissue, we reviewed the 1996 WQA worksheets, which formed the basis for the 1998

303(d) list. Tissue data used in the assessment were data collected as part of the Toxic

Substances Monitoring Program (TSMP) in 1993 and 1995 (Table 2-4).
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 14

Table 2-4. Fish tissue listing data from Toxic Substances Monitoring Program (ppb, wet

weight).

Program TSMP SWRCB OEHHA

Date 1993 1995 1995 1995

Species

White

Croaker

Round

Stingray

Sargo

Yellow

Croaker

Maximum

Tissue

Residue Level

(MTRL)

Screening

Value

(μg/kg)

Number of

individuals

1 1 1 1

Chlordane 128 30.7 8.3 30

Dieldrin 5.6 5.3 0.7 2.0

Total DDTs 230 101 60 -- 100

Total PCBs 490 255 59 5.3 20

The TSMP data represents the results from a single sample (White Croaker) in 1993, and

three samples (Round Stingray, Sargo, and Yellow Croaker) in 1995 that were collected

in Marina del Rey Harbor. The TSMP data indicate concentrations of chlordane, dieldrin,

DDT, and PCBs that are above the MTRLs or OEHHA screening values.

More recent fish data was obtained for the Marina del Rey back basins during the

Southern California Bight Regional Monitoring Project. Fish tissue samples were

analyzed for chlordane, total DDTs, and total PCBs. In addition, the Los Angeles County

Department of Beaches and Harbors (LACDBH) conducted fish tissue analyses at EPA’s

request in 2002. Chlordane, total DDTs, and dieldrin in whole fish were analyzed. Data

from both sources are presented in Table 2-4.

Table 2-5. Fish tissue listing data from Toxic Substances Monitoring Program (ppb, wet

weight).

Source/Date

Bight 98

LACDBH

2002

OEHHA

Location

MdR Basin

D/E

MdR Basin H

MdR Main

Channel -

Entrance

MdR Main

Channel -

Center

MdR back

basins

Species

California

Halibut

California

Halibut

California

Halibut

California

Halibut

White

Croaker

Screening

Value

(μg/kg)

Number of

individuals 1 1 1 1 6

Chlordane 0 0 0 2.4 <1 30

Dieldrin n.a n.a n.a n.a <1 2.0

Total DDTs 7.4 8.8 18.6 35.2 74.4 100

Total PCBs 7 10.8 23 50.2 n.a 20

* 6 fish merged into one composite sample

The (Bight 98) data indicates that total DDT and chlordane are below the fish screening

values at all locations in the harbor. Total PCB concentration in fish tissue exceeded the

fish target in 2 of 4 samples in the harbor. Dieldrin was not measured for the Bight 98

studies. Additional data from the LACDBH 2002 analyses showed chlordane and dieldrin
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 15

to be undetectable and total DDTs to be below screening values. These more recent data

indicate that total PCBs are currently the only fish tissue impairment.

2.2.3 Sediment

Assessment of the extent of sediment impairment was based on data from the following

sources:

Bay Protection and Toxic Cleanup Program Data (BPTCP): Sampling was conducted

in January 93, February 94, June 96 and February 97 at different locations in the Marina

del Rey Harbor. This assessment included three sampling locations in the back harbor (1

in Basin D and 2 in Basin E). The samples were analyzed for sediment chemistry and

toxicity.

Los Angeles County Department of Beaches and Harbors (LACDBH 1996 –2004):

This annual Marina del Rey Harbor sampling program is conducted by the Los Angeles

County Department of Beaches and Harbors. The samples were taken from different

locations throughout the harbor, including 4 stations in the back basins (1 in Basin D, 2 in

Basin E, and 1 in Basin F). The samples were analyzed for sediment chemistry, benthic

community index, water column general chemistry and physical parameters, and bacteria.

Southern California Bight Regional Monitoring Project (Bight 98): provides an

integrated assessment of Southern California coastal estuaries. The samples were

collected in summer of 1998 and were analyzed for sediment chemistry, toxicity (solid

phase, elutriate test and enzyme induced), bioaccumulation in whole fish (juvenile

California Halibut) and AVS/SEM for metals. The samples included three stations in the

Marina del Rey back basin (Basin D and Basin E).

Data from these sources are presented and evaluated in Table 2-6 through 2-9.
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 16

Table 2.6: Summary of Sediment Quality Data for Marina del Rey’s back basins (96-03).

Date Location Pollutants of Concern (metals in mg/Kg and organics in μg/Kg)

Basin D Cu Pb Zn Chlordane Total PCBs

Jun-96 BPTCP (#48002) 320 52.2 520 11.15 130.2

Oct-95 LACDBH (#8) 367 81 387 <20

Oct-96 210 57.2 213 <0.3 <20

Oct-97 300 92 320 <0.4 <20

Oct-98 242 62 238 <0.4 <20

Oct-99 312 91 320 <0.4 <20

Oct-00 307 76 320 <0.4 <20

Oct-01 354 79 293 <2 22.66

Oct-02 330 105 322 <2 <1

Oct-03 351 72 445 <2 <1

Basin E

Jan-93 BPTCP (#44014) 550 240 620 22.1 308.9

Feb-94 427 171 636 38.1 391.5

Jun-96 321 149 400 24.9 237.9

Jun-96 BPTCP (#48001) 266 206 496 14.87 165.3

Oct-95 LACDBH (#10) 299 177 455 110

Oct-96 314 292 440 2 <20

Oct-97 380 210 480 3 <20

Oct-98 172 106 320 <1.4 <20

Oct-99 108 51 157 <0.3 <20

Oct-00 147 88 252 <0.4 <20

Oct-01 122 45 155 <2 50.06

Oct-02 241 89 335 <1 59.7

Oct-03 362 109 648 <2 <1

Oct-95 LACDBH (#11) 373 95 423 <20

Oct-96 346 114 426 0.5 <20

Oct-97 390 120 390 <0.5 <20

Oct-98 312 113 390 <1.1 <20

Oct-99 450 128 450 <0.4 <20

Oct-00 420 103 390 <0.5 <20

Oct-01 359 106 339 <2 58.82

Oct-02 433 109 451 5.3 93.3

Oct-03 403 96 523 <2 <1

1998 Bight 98 (2443) 146.5 117.5 177.31

1998 Bight 98 (2444) 263 98.6 20.1

Basin F

Oct-95 LACDBH (#9) 380 115 419 <20

Oct-96 346 141 382 0.6 <20

Oct-97 360 140 370 <0.5 <20

Oct-98 320 116 360 <1.2 <20

Oct-99 390 149 410 <0.5 <20

Oct-00 167 105 245 <0.5 <30

Oct-01 333 143 324 <2 137.12

Oct-02 368 187 396 <2.15 101.6

Oct-03 294 95 371 <2 <1
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 17

No. of samples 43 43 41 41 39

Average 318 118 386

Min. 108 45 155 <0.3 <1

Max. 550 292 648 110 391.5

The sediment contaminants were evaluated relative to sediment quality guidelines

(SQGs), specifically the values for Effects Range-Low (ERL), Effects Range-Median

(ERM) (Long et al., 1995), Threshold Effects Level (TEL), and Probable Effects Level

(PEL) (MacDonald, 1994). These SQGs are based on empirical data compiled from

numerous field and laboratory studies performed in North America.

The National Oceanic Atmospheric Administration (Long et al., 1995) assembled data

from throughout the country that correlated chemical concentrations in sediments with

effects. These data included spiked bioassay results and field data of matched biological

effects and chemistry. The product of the analysis is the identification of two

concentrations for each substance evaluated. The ERL values were set at the 10th

percentile of the ranked data and represent the point below which adverse biological

effects are not expected to occur. The ERM values were set at the 50th percentile and are

interpreted as the point above which adverse effects are expected.

The TEL and PEL values were developed by the State of Florida and were based on a

biological effects empirical approach similar to the ERLs/ERMs. The development of

the TELs and PELs differ from the development of the ERLs and ERMs in that data

showing no effects were incorporated into the analysis. In the Florida weight-ofevidence approach, two databases were assembled: a “no-effects” database and an

“effects” database. Taking the geometric mean of the 15th percentile value in the effects

database and the 50th percentile value of the no-effects database generated the TEL

values. The PEL values were generated by taking the geometric mean of the 50th

percentile value in the effects database and the 85th percentile value of the no-effects

database. By including the no-effect data in the analysis, a clearer picture of the chemical

concentrations associated with the three ranges of concern (no effects, possible effects,

and probable effects) can be established.

The ERLs and TELs are presumed to be non-toxic levels with a high degree of

confidence of no potential threat. The ERMs and PELs identify pollutant concentrations

that are more probably elevated due to toxic levels. In the “Water Quality Control Policy

for Developing California’s Clean Water Act Section 303(d) List,” ERMs for copper,

zinc, and chlordane, and the PEL value for lead, are identified as the guidelines most

predictive of biological effects (SWRCB, 2004). The listing policy also identifies a

consensus-based SQG for total PCBs as most predictive of biological effects. Table 2-

7.summarizes these guidelines.
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 18

Table 2-7. Summary of marine sediment quality guidelines used in assessment of TMDL

pollutants

Organics

ERL

(μg/kg)

ERM

(μg/kg)

TEL

(μg/kg)

PEL

(μg/kg)

Consensus-based

SQG

(μg/kg)

Chlordane 0.5 6* 2.26 4.79

Total

PCBs 22.7 180 21.6

189 400*

Metals (mg/kg) (mg/kg) (mg/kg) (mg/kg)

Copper 34 270* 18.7 108

Lead 46.7 218 30.2 112*

Zinc 150 410* 124 271

*SQGs most predictive of biological effects (CSWRCB, 2004).

As shown in Table 2-6, several sediment samples had chlordane and total PCBs in

concentrations at or below detection limits; and, in some cases, the detection limits were

greater than the SQG. In Table 2-8, the detection limits were treated as the actual

concentration when evaluating the sediment data.

Table 2-8. Evaluation of sediment data relative to sediment quality guidelines

Pollutant Number of

samples

# >DL # > ERL # > ERM # > TEL # > PEL

# >

Other

SQG

Copper 43 43 43 32 43 42 n.a

Lead 43 43 42 2 40 19 n.a

Zinc 41 41 41 15 41 35 n.a

Chlordane 41 11 27 9 11 10 n.a

PCBs 39 14 13 3 14 3 0

n.a not applicable

Organics in Sediments

Chlordane was detected in 11 out of 41 sediment samples used for this assessment. In 16

of the 41 samples the detection limit was above the SQGs. Based on the assumption that

the detection limit is the actual concentration, 9 of 41 samples exceeded the ERM value.

This number of exceedances of the ERM value indicates that chlordane remains an

impairment in the harbor sediment.

Total PCBs were detected 14 out of 39 sediment samples. Concentrations ranged from <1

to 391.5 μg/kg (calculated as the sum of the congeners). Treating detection limits as true

values, 3 out of the 39 samples had concentrations greater than ERM and no samples

were greater than the consensus-based SQG value of 400 μg/Kg. While there are no

exceedances of the SQG value for total PCBs, the elevated levels of this pollutant in fish

tissue would make a determination of no impairment premature.
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 19

Metals in Sediments

Copper was detected in all sediment samples from Basins D, E, and F of Marina del Rey

Harbor. Sediment concentrations ranged from 108 to 550 mg/kg. All 43 samples were

above ERL guidelines, and 32 of 43 exceeded the ERM value. Copper remains at

elevated concentrations within Marina del Rey’s back basins.

All sediment samples had detectable lead concentrations. Lead in the sediments of

Marina del Rey’s back basins ranged from 45 to 292 mg/kg. Samples from Basins E and

F exhibited higher lead levels than those from Basin D. The PEL guideline was exceeded

in 19 of 43 samples, which indicates a continuing impairment in the sediments of the

back basin.

Zinc concentrations in the sediment samples ranged from 155 to 648 mg/kg in Marina del

Rey’s back basins. All 41 samples exceeded the ERL values, and 15 of 41 samples

exceeded the ERM guideline, confirming the zinc impairment.

Sediment Toxicity

Sediment toxicity data for the Marina del Rey back basins is presented in Table 2-9.

These data were compiled from the Bay Protection and Toxic Cleanup Program (BPTCP)

from 1993 to 1997 and the Southern California Bight 1998 Regional Monitoring Program

(Bight 98). The reported data shows sediment toxicity in seven of nine samples.

Table 2-9 Sediment Toxicity Data for Marina del Rey’s Back Basins – Amphipod Survival

Rates

Source Date Location Specie Survival

BPTCP 1/14/93 Basin E (#44014) Rhepoxynius 53% (T)

2/15/94 Basin E (#48001) Rhepoxynius 32% (T)

2/15/94 Basin E (#48001) Rhepoxynius 42% (T)

2/15/94 Basin E (#48001) Rhepoxynius 35% (T)

6/19/96 Basin E (#44014) Eohaustorius 92% (NT)

2/5/97 Basin E (#48001) Eohaustorius 49% (T)

2/5/97 Basin D (#48002) Eohaustorius 65% (T)

Bight 98 Summer 1998 Basin E (#2443) Eohaustorius 66% (T)

Summer 1998 Basin E (#2444) Eohaustorius 79% (NT)

T – toxic, NT = non toxic

2.3 Summary and Findings concerning TMDLs Required

There is indication of water column impairment by dissolved copper in Marina del Rey

Harbor. However due to the uncertainty involved with the method used for sample

analysis, further monitoring is necessary to make a final determination. Sediment

concentrations of copper, lead, zinc, and chlordane remain elevated, while total PCBs

meet the State’s de-listing criteria. However, more recent fish tissue data indicates that

total PCB concentrations are above fish tissue targets; while fish tissue levels of

chlordane, dieldrin and total DDTs are below the fish tissue targets.

This TMDL will be developed to reduce sediment impairment by copper, lead, zinc, and

chlordane. In addition, the fish tissue impairment by total PCBs will be addressed. Based

on the above assessment of available data, fish tissue impairment by chlordane, dieldrin
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 20

and DDTs, do not require a TMDL. Sediment toxicity and the fish consumption advisory

impairments will be mitigated through implementing TMDLs for the listed pollutants.
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 21

3 NUMERIC TARGETS

Numeric Targets for this TMDL are used to calculate waste load allocations for the

impairing metals and organic compounds, and/or to indicate attainment of water quality

objectives. Sediment quality guidelines are used to calculate the TMDLs for the copper,

lead, zinc, and chlordane impairments in sediments. Water criteria, fish tissue and

sediment quality guidelines are selected as numeric targets for the total PCB fish tissue

impairment. The sediment target for total PCBs is the primary numeric target, which is

used to calculate the TMDL and allocations. Water quality objectives and fish tissue

guidelines for total PCBs are secondary targets that will provide additional means of

assessing success in attaining water quality standards, including the narrative toxicity

objective.

3.1 Sediment Numeric Targets

Numeric targets that are protective of aquatic life beneficial uses are developed for

copper, lead, zinc, total PCBs and chlordane in sediments. While the PCB impairment

occurs in fish tissue only, a sediment target is necessary as PCBs are directly associated

with sediments which are the transport mechanism of these compounds from the Marina

del Rey watershed to the harbor. As discussed in Section 2, the Basin Plan provides

narrative objectives that can be applied to sediments but does not provide numeric WQOs

for sediment quality. To develop the TMDLs, it is necessary to translate the narrative

objectives into numeric targets that identify the measurable endpoint or goal of the

TMDL and represent attainment of applicable numeric and narrative water quality

standards.

Sediment quality guidelines compiled by National Oceanic and Atmospheric

Administration (NOAA) are used in evaluating waterbodies within the Los Angeles

Region for development of the 303(d) list. The sediment quality guidelines are

applicable numeric targets because the impairments and the 303(d) listings are primarily

based on sediment quality data. In addition, the pollutants being addressed have a high

affinity for particles and the delivery of these pollutants is generally associated with the

transport of suspended solids from the watershed or from sediments within the harbor.

The ERLs (Long et al., 1995) guidelines are established as the numeric targets for

sediments in Marina del Rey’s back basins, as summarized in Table 3-2. The State Board

listing policy recommends the use of ERMs, PELs, and other SQGs as a threshold for

listing. ERM and PEL values are interpreted as levels above which the adverse biological

effects are expected, which makes them applicable in the determination of impairment.

The ERL values, on the other hand, represent the levels below which adverse biological

effects are not expected to occur, and are more applicable to the prevention of

impairment. These SQGs are discussed in greater detail in Section 2.2.3. The goal of the

TMDL is to remove impairment and restore beneficial uses; therefore, the ERLs are

selected as numeric targets over the ERMs to limit adverse effects to aquatic life. The

selection of the ERLs, which are lower than ERMs, provides an implicit margin of safety.
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 22

Table 3-1. Numeric targets for sediment quality in Marina del Rey’s back basins

Organics Numeric Target for Sediment

Chlordane 0.5 μg/kg

Total PCBs 22.7 μg/kg

Copper 34 mg/kg

Lead 46.7 mg/kg

Zinc 150 mg/kg

3.2 Water Quality Criteria

The California Toxics Rule (CTR) Criterion for the protection of human health from the

consumption of aquatic organisms is selected as the final numeric target for total PCBs in

the water column. However, given the inability of current analytical methods to detect

concentrations at this low level, an interim numeric target will be applied. The CTR

Chronic Criterion for the protection of aquatic life in saltwater is selected as the interim

numeric target for the fish tissue impairment by PCBs. This numeric target will remain in

effect until advances in technology allow for analysis of PCBs at lower detection limits.

The interim and final numeric targets for total PCBs in the water column are provided in

Table 3-2. As discussed in Section 3, this secondary target will serve as a means of

gauging improvements in water quality, and not as a basis for calculating TMDL

allocations.

Table 3-2: Numeric Targets for total PCBs in the water column

Numeric Targets (μg/L)

Interim 0.03

Final 0.00017

3.3 Fish Tissue Target

The fish tissue target of 5.3 μg/Kg for total PCBs is derived from CTR human health

criteria, which are adopted criteria for water designated to protect humans from

consumption of contaminated fish or other aquatic organisms. The derived fish tissue

target is referred to as the Threshold Tissue Residue Level (TTRL), in this document. Use

of a fish tissue target is appropriate to account for uncertainties in the relationship

between pollutant loadings and beneficial use effects (EPA, Newport Bay TMDL, 2002)

and directly addresses human health impacts from consumption of contaminated fish or

other aquatic organisms. While the detection limit for total PCBs in water is currently

higher than the CTR criteria for the protection of human health, the TTRL numeric target

is detectable with current technology; making compliance monitoring feasible. Thus, the

TTRL provides an effective method for accurately quantifying achievement of the water

quality objectives.
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 23

3.3.1. Deriviation of the Treshold Tissue Residue Level (TTRL)

The TTRL value of 5.3 μg/Kg for total PCBs is derived from the CTR human health

criteria for consumption of organisms only (i.e. 0.00017 μg/L). CTR criteria were

developed by determining pollutant concentrations in edible fish tissue that would pose a

health risk to humans consuming 6.5 grams of fish per day. These fish tissue

concentrations were converted to water column concentrations using a bioconcentration

factor (BCF), which is the ratio of the chemical concentration in fish to the chemical

concentration in water. The TTRL was derived by reverting back to the original fish

tissue concentration upon which the human health criteria are based (see equation 3-1).

This was the same approach used in the Calleguas Creek OC Pesticides and PCBs TMDL

(LARWQCB, 2005a).

TTRL = CTR criterion x BCF (equation 3-1)

TTRL = Threshold Tissue Residue Level μg/Kg

CTR criterion = 0.00017 μg/L

BCF = Bioconcentration Factor = 31200 L/Kg
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 24

4 SOURCE ASSESSMENT

This section identifies the potential sources of metals and organochlorine compounds to

Marina del Rey’s back basins. The toxic pollutants can enter surface waters from both

point and non-point sources. Point sources typically include discharges from a discrete

human-engineered point. These types of discharges are regulated through the federal

National Pollutant Discharge Elimination System (NPDES) program, which the Regional

Boards have been delegated to implement through the issuance of Waste Discharge

Requirements (WDRs). In Los Angeles County urban runoff to Marina del Rey is

regulated under storm water NPDES permits, which are regulated as a point source

discharge. Non-point sources, by definition, include pollutants that reach surface waters

from a number of diffuse land uses and activities that are not regulated through NPDES

permits. Examples of non-point sources in the Marina del Rey Watershed include

atmospheric deposition and boat discharges.

4.1 Background on Toxic Pollutants

The following sections provide background information on the toxic pollutants addressed

in this TMDL, including their properties and uses.

4.1.1 Organic Pollutants

Chlordane was used as a pesticide to control insects on agricultural crops, residential

lawns and gardens, and in buildings, particularly for termite control. In 1988, all

chlordane uses, except for fire ant control, were voluntarily cancelled in the United States

(NPTN, [undated]). Chlordane can still be legally manufactured in the United States for

sale or use by foreign countries. Although it is no longer used in the US, chlordane

persists in the environment, adhering strongly to soil particles. It is assumed that the only

source of chlordane in the watershed is storm water runoff carrying historically deposited

chlordane most likely attached to eroded sediment particles.

Polychlorinated biphenyls (PCBs) are mixtures of up to 209 individual chlorinated

compounds (known as congeners). They were used in a wide variety of applications,

including dielectric fluids in transformers and capacitors, heat transfer fluids, and

lubricants. In 1976, the manufacture of PCBs was prohibited because of evidence they

build up in the environment and can cause harmful health effects. Although it is now

illegal to manufacture, distribute, or use PCBs, these synthetic oils were used for many

years as insulating fluids in electrical transformers and in other products such as cutting

oils. Products made before 1977, which may contain PCBs include old fluorescent

lighting fixtures and electrical devices containing PCB capacitors, and old microscope

and hydraulic oils. Historically, PCBs have been introduced into the environment

through discharges from point sources and through spills and accidental releases.

Although point source contributions are now controlled, non-point sources may still exist,

for example, refuse sites and abandoned facilities may still contribute PCBs to the

environment. Once in a waterbody, PCBs become associated with solid particles and

typically enter sediments (USEPA, 2002).
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 25

4.1.2 Metals

Potential anthropogenic sources of copper include corrosion of brass and copper pipe be

acidic waters, copper brake pads, the use of copper compounds as aquatic algaecides,

sewage treatment plant effluents, runoff and groundwater contamination for agricultural

uses of copper as fungicides and pesticides, and effluents from industrial sources. Major

industrial sources include mining, smelting and refining industries, copper wire mills,

coal burning industries and iron and steel producing industries (MacDonald, 1994). Boats

are another source of copper in the in Marina del Rey harbor. Copper is leached

constantly from the anti-fouling paints used on boats to effectively reduce fouling

organisms. Underwater hull cleaning also contributes copper to the harbor.

The single largest use of lead is in the production of lead-zinc batteries. Lead and its

compounds are used in electroplating, metallurgy, construction materials, coating and

dyes, electronic equipment, plastics, veterinary medicines, fuels and radiation shielding.

Lead is also used for ammunition, corrosive-liquid containers, paints, glassware,

fabricating storage tank linings, transporting radioactive materials, solder, piping, cable

sheathing, and roofing (MacDonald, 1994). Prior, to the phasing out of leaded gasoline,

lead additives in gasoline was a significant source of lead in the environment. Since the

phasing out of leaded gasoline, there has been a gradual decline of lead concentrations in

the environment.

Zinc is primarily used as a coating on iron and steel to protect against corrosion, in alloys

for die-casting, in brass, in dry batteries, in roofing and exterior fittings for buildings, and

in some printing processes. The principal sources of zinc in the environment include

smelting and refining activities, wood combustion, waste incineration, iron and steel

production, and tire wear (MacDonald, 1994). A tire contains about half a pound of zinc,

which is needed to cure the rubber (America Zinc Association). In Marina del Rey

harbor, the use of sacrificial zinc anodes to prevent corrosion on boats, is a potential

source of zinc.

4.2 Point Sources

A point source, according to 40 CFR 122.3, is defined as “any discernable, confined, and

discrete conveyance, including but not limited to, any pipe, ditch, channel, tunnel,

conduit, well, discrete fissure, container, rolling stock, concentrated animal feeding

operation, landfill leachate collection system, vessel, or other floating craft from which

pollutants are or may be discharged.” The NPDES Program, under CWA sections 318,

402, and 405, requires permits for the discharge of pollutants from point sources.

The NPDES permits in the Marina del Rey Watershed include the MS4 and Caltrans

Storm Water Permits, general construction storm water permits, general industrial storm

water permits, and general NPDES permits (Table 4-1).
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 26

Table 4-1. NPDES Permits in the Marina del Rey Watershed

Type of NPDES Permit Number of Permits

Municipal Storm Water 1

California Department of Transportation Storm Water 1

General Construction Storm Water

Tradewind Apartments

Marina Point III Apartments

Marina Waterside

3

General Industrial Storm Water

Fed Ex

Windward Yatch & Repair

Seamark Boatyard

3

Total 8

4.2.1 Stormwater Runofff

Storm water runoff in the Marina del Rey watershed is regulated through a number of

permits. The first is the municipal separate storm sewer system (MS4) permit issued to

the County of Los Angeles and its co-permittees. The second is a separate statewide

storm water permit specifically for the California Department of Transportation

(Caltrans). The third is the statewide Construction Activities Storm Water General

Permit and the fourth is the statewide Industrial Activities Storm Water General Permit.

The permitting process defines these discharges as point sources because the storm water

discharges from the end of a storm water conveyance system. Since the industrial and

construction storm water discharges are enrolled under NPDES permits, these discharges

are treated as point sources in this TMDL.

The Oxford Street Flood Control Basin (OSFCB) and the Washington Street (Palawan

Way) drain are two major stormwater conduits with direct drainage into the back basin E.

OSFCB is a sump for street drainage, from the community north and east of the marina,

draining into Basin E through a tide gate. The Washington Street conduit drains an area

north west of the Marina. The runoff carries relatively high contaminant concentration

into sheltered, low energy areas such as Basin E and F. The OSFCB serves as a settling

basin and detention basin for the major stormwater inflows to the back harbor. Many

studies suggested that the OSFCB may be a significant contributor of contaminants in the

back basins based on the high contamination levels in the drainage basin and the

correlation between back harbor and OSFCB concentrations during storm events (Soule

et al. studies 1977, 1984, Los Angeles County Department of Beaches and Harbors 1996-

2004).

A GIS based Pollutant Loading Model (PLOAD) was used to calculate stormwater

pollutant loads for total recoverable and dissolved copper, lead and zinc for Marina del

Rey’s sub-watersheds (Table 4-2). The detailed calculations are included in Appendix A

The loadings for metals were calculated based on the stormwater event mean

concentrations (EMCs) analyzed by the Los Angeles County Department Public Works
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 27

(LADPW) from 1994 to 2000 for eight land use types. EMCs values for organochlorine

pesticides and PCBs were not available due to non-detectable levels in stormwater.

Table 4-2. Annual Loading from Stormwater Water Runoff for Metals (lb/year)

Sub-watershed Total

Suspended

Solids

Total

Copper

Dissolved

Copper

Total

Lead

Dissolved

Lead

Total

Zinc

Dissolved

Zinc

Average Rain Year

Area 1A 21,933 9.9 4.4 3.3 0.0 71 47.9

Area 3 7,788 1.4 0.8 0.8 0 13 7.6

Area 4 111,742 23 12.4 9.8 0 218 153.7

TOTAL 141,463 34.3 17.6 13.9 0 302 209

Dry Rain Year

Area 1A 10,231 4.6 2.0 1.5 0.0 33.2 22.4

Area 3 3,633. 0.7 0.4 0.4 0 5.8 3.6

Area 4 52,127 10.7 5.8 4.6 0 101.8 71.7

TOTAL 65,992 16 11.5 9.2 0 199 136

Wet Rain Year

Area 1A 38,153 17.3 7.6 5.8 0.0 124.0 83.4

Area 3 13,547 2.4 1.4 1.3 0 21.7 13.3

Area 4 194,378 39.9 21.5 17 0 379.6 267.4

TOTAL 246,078 59.6 30.5 24.1 0 525 364

4.2.2 Summary Point Sources

Urban storm water has been recognized as a substantial source of metals (Characklis and

Wiesner 1997, Davis et al. 2001, Buffleben et al. 2002) and organic pollutants (Suffet and

Stenstrom, 1997). This is reflected in routine storm water monitoring performed by

LACDPW under the MS4 permit (LACDPW, 2002). Studies have also shown that dryweather pollutant loadings are not insignificant (McPherson et al., 2002).

The Oxford Street Flood Control Basin (OSFCB) and the Washington Street (Palawan

way) drain are two major stormwater conduits with direct drainage into the back basin E.

In the Marina del Rey Watershed storm water discharges are regulated under the MS4

permit, the Caltrans permit, the general industrial storm water permit and the general

construction storm water permit. There are also two non-storm water general permits

with low potential to contribute significant loadings to the system.

The most prevalent metals in urban storm water (i.e., copper, lead and zinc) are

consistently associated with the suspended solids (Sansalone and Buchberger 1997, Davis

et al. 2001). These metals are typically associated with fine particles in storm water

runoff (Characklis and Wiesner 1997, Liebens 2001), and have the potential to

accumulate in estuarine sediments posing a risk of toxicity (Williamson and Morrisey,

2000). The organic contaminants in storm water are also associated with suspended

solids and the particulate fraction.

A major contributor of associated metals, and organic compounds to Marina del Rey

Harbor is assumed to be wet-weather runoff discharged from the storm water conveyance
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 28

system. While the loadings of metals are attributable to ongoing activities in the

watershed, the loadings of chlordane and PCBs, reflect historic uses. Although the uses

of these compounds are banned, these legacy pollutants continue to be detected in

sediments at elevated levels.

4.3 Nonpoint Sources

Marina activities and atmospheric deposition are the major non-point sources of

contaminants in the Marina del Rey watershed.

4.3.1. Marina Activities

Elevated metal concentrations occur in the middle and back basins of Marina del Rey

Harbor. The numerous boats that utilize the Marina are a likely contributor to the metals

impairment in this area. Boats have metal components and engines that constantly

corrode from salt water and air. Anti-fouling paints contain heavy metals such as copper

that are designed to constantly ablate or leach out (passive leaching) to effectively reduce

fouling organisms. Lead and zinc concentrations were also found in high amounts in the

back harbor sediments. These metals might have originated from the historical industrial

land uses of the Marina or have been derived from boating activity, including copper and

lead in the boat paints, and zinc in the anodes of boat engines.

4.3.1.1 Copper Loading from Recreational Boats

Copper inputs from recreational boats to Marina del Rey back basins were estimated

based on information obtained from the Dissolved Copper TMDL for Shelter Island

Yacht Basin (SIYB), which was developed by the San Diego Regional Water Quality

Control Board (SDRWQCB, 2005). The San Diego TMDL, adopted on March 9, 2005

, provides dissolved copper loading equations for both passive leaching from wetted hull

surfaces, and from underwater hull cleaning (i.e. wiping down the wetted surface to

remove marine growth). Local conditions (number of moored boats) were applied for

Marina del Rey. Parameters such as mean boat length and wetted surface area were

assumed to be the same as in the SIYB. Passive leaching and hull cleaning were

estimated to contribute approximately 3,693-lb/year and 47.6 lbs lb/year of dissolved

copper, respectively to the Marina del Rey back harbor. Details of these calculations are

provided in the Appendix B.

Copper in the water column can accumulate in sediment through adsorption or by

partitioning in pore water. In this way, sediment acts as a “sink” for copper in the water

column, and concentration levels can build up and persist over time. The rate of

contamination of sediment is dependent on a variety of factors including sediment type

and quality, organic matter content and the degree of contamination in the water column

and associated sediment (SIYB TMDL, 2005). The poor flushing in the harbor’s back

basins increases the likelihood of dissolved copper partitioning to the sediment. However,

there is insufficient information available to quantify copper loading to the sediment from
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 29

boat discharges. This TMDL will require a study designed to estimate copper partitioning

between the water column and sediment.

4.3.2 Atmospheric Deposition

Direct deposition of airborne particles to the water surface may be responsible for

contributing copper, lead and zinc to the Marina del Rey back basins. Indirect deposition

from air to land and subsequent wash into the back basins is accounted for in the

stormwater runoff estimates. Indirect and direct deposition of metals to surface water was

estimated from dry deposition fluxes in the Los Angeles coastal region presented in Sabin

et al., (2004). Table 4-3 shows that the direct air deposition is a relatively small source

for the metals impairment.

Table 4-3. Estimate of Atmospheric Deposition of Metals to Surface Water

Metals Direct Deposition

(kg/yr)

Indirect Deposition

(kg/yr)

Copper 0.14 29

Lead 0.09 22

Zinc 0.46 144
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 30

5 LINKAGE ANALYSIS, TMDL AND POLLUTANT ALLOCATION

The linkage analysis is used to identify the assimilative capacity of the receiving water

for the pollutant of concern by linking the source loading information to the water quality

target. The TMDL is then divided among existing pollutant sources through the

calculation of load and waste load allocations. This section discusses the linkage analysis

used for Marina del Rey’s back basins and identifies the resulting pollutant allocations.

The goals of the Marina del Rey Toxics TMDL is to reduce pollutant loads of copper,

lead, zinc, chlordane, and PCBs from the Marina del Rey watershed to the sediments

back basins of its harbor. The TMDL is also intended to reduce elevated levels PCBs in

fish tissue.

The impairing contaminants in sediment are associated with fine-grained particles that

are delivered to the sediments through suspended solids in stormwater. It is expected that

reductions in loadings of these pollutants will lead to reductions in sediment

concentrations over time. The existing contaminants in surface sediments will be

removed over time as sediments are scoured during storms or removed in dredging

operations. For the legacy pollutants (chlordane and PCBs), some loss will also occur

through the slow decay and breakdown of these organic compounds. Concentrations in

surface sediments will be reduced through mixing with cleaner sediments. Attenuation of

pollutant concentration levels in sediment is expected to translate to reductions in fish

tissue contaminant levels. Also see Section 3.1 herein.

5.1 Loading Capacity

The loading capacity of the sediments was estimated from the annual average total

suspended solids (TSS) loading to the back basins of Marina del Rey Harbor, as

estimated from the PLOAD model (Table 5-1). While the TSS load may not represent the

total sediment loading to the harbor, it represents the finer material with which pollutants

are more readily associated.

Table 5-1. Average Annual Total Suspended Solids (TSS) Loading to Marina del Rey

Subwatershed TSS (lbs/year) TSS (kg/year)

Area 1A 21933 9,948

Area 3 7,788 3,533

Area 4 111,742 50,685

Total 141,463 64166

Assuming fine sediments carried by stormwater to be the main source of contaminated

sediments to the back basins, pollutant specific loading capacity was calculated by

multiplying the average annual total suspended solids load 64,166 kg/yr discharged to the

harbor by the numeric sediment targets (Table 3-2). The resultant numbers are presented

in Table 5-2. The TMDL for sediment is set equal to the loading capacity.
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 31

Table 5-2. Sediment Loading Capacity Expressed as Mass per Year

Metals

Numeric Target

ERL (mg/kg)

TMDL (kg/year)

Copper 34 2.18

Lead 46.7 3.0

Zinc 150 9.6

Organics ERL (μg/kg) TMDL(g/year)

Chlordane 0.5 0.03

PCBs 22.7 1.46

5.1.1 Critical Conditions

The amount of total suspended solids in stormwater run-off is a function of the storms,

which are highly variable between years. The TMDL is based on a TSS load derived

from long-term average rainfall over a 52-year period from 1948 to 2000. This time

period contains a wide range of storms in the Marina del Rey watershed. Use of the

average condition for the TMDL is appropriate because issues of sediment effects on

benthic communities and potential for bioaccumulation to higher trophic levels occurs

over long time periods.

5.1.2 Margin of Safety

TMDLs must include a margin of safety to account for any uncertainty concerning the

relationships between sources, and water and sediment quality. An implicit margin of

safety is applied through the use of more protective SQG values. The ERLs were

selected over the higher ERMs as the numeric targets.

5.2 Allocations

Contaminated sediment generated in the watershed is transported to Marina del Rey’s

back basins through the storm water conveyance system. These are regulated directly in

the NPDES process through storm water permits or indirectly through the issuance of

NPDES permits for discharges to the storm water system. A mass-based load allocation

was developed for direct atmospheric deposition. A grouped mass-based waste load

allocation was developed for storm water permittees (Los Angeles County MS4,

Caltrans, General Industrial and General Construction) by subtracting the mass-based

load allocations from the total loading capacity according to the following equation:

TMDL = Direct Atmospheric Deposition + Combined Storm Water Sources (5-1)

Concentration-based sediment waste load allocations are developed for other point

sources in the watershed. These other point sources have intermittent flows and should

discharge little to no sediment. These sources will have a minor impact on sediment

loading if they are limited by concentration to the applicable ERL-based waste load

allocations.
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 32

5.2.1 Load Allocations

A mass-based load allocation is developed for direct atmospheric deposition. An

estimate of direct atmospheric deposition was developed based on the percent area of

surface water, within the watershed area of the back basins, which is approximately 52

acres or 5.4% of the total watershed area. The load allocation for atmospheric deposition

is calculated by multiplying this percentage by the total loading capacity, according to the

following equation:

Direct Atmospheric Deposition = 0.054 x TMDL (5-2)

The loadings associated with indirect atmospheric deposition are included in the

stormwater waste load allocations.

There will be no load allocations assigned to boat discharges at this time, as contribution

from water column concentrations to sediment loading cannot be quantified. Upon

completion of a study designed to obtain such information, the TMDL will be revised as

necessary.

5.2.2 Waste Load Allocation for Storm Water

A mass-based waste load allocation, for the impairing pollutants in sediment, is

developed for the storm water permittees according to the following equation:

Combined Storm Water Sources = TMDL - Direct Atmospheric Deposition (5-3)

Since, the direct atmospheric deposition is calculated as a percentage of the total loading

capacity equation 5-3 becomes:

Combined Storm Water Sources = TMDL – 0. 054 TMDL (5-4)

Combined Storm Water Sources = 0.946 x TMDL (5-5)

For accounting purposes, it is assumed that Caltrans and the general stormwater

permittees discharge entirely to the MS4 system. This assumption has been supported

though review of the permits. The resulting allocations are presented in Table 5-3.

Table 5-3. Mass-based Allocations

Metals Direct Air (kg/yr) Stormwater

(kg/yr)

Copper 0.12 2.06

Lead 0.16 2.83

Zinc 0.52 9.11

Organics Direct Air (g/yr) Stormwater (g/yr)

Chlordane 0.002 0.03

PCBs 0.079 1.38

USEPA requires that waste load allocations be developed for NPDES-regulated storm

water discharges. Allocations for NPDES-regulated storm water discharges from

multiple point sources may be expressed as a single categorical waste load allocation
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 33

when data and information are insufficient to assign each source or outfall individual

allocations. The combined storm water waste load allocation is divided among the four

storm water permittees (MS4, Caltrans, general industrial and general construction) based

on an estimate of the percentage of land area covered under each permit (Table 5-4).

Table 5-4. Areal extent of watershed and percent area covered under storm water permits

Category Area in acres Percent area

MS4 Permit 880 91.9

Caltrans Storm Water Permit 9.58 1

General Construction Storm Water Permit 14.5 1.5

General Industrial Storm Water Permit 2 0.2

Water (LA for direct atmospheric deposition) 52 5.4

Total 958 100

Based on these areas, the waste load allocations for each storm water permittee are

presented in Table 5-5. In the storm water permits, permit writers may translate the

numeric waste load allocations to BMPs, based on BMP performance data. It is

anticipated that reductions will be achieved either through pollutant control measures or

sediment control measures.

Table 5-5. Combined storm water allocation apportioned based on percent of watershed.

Metals

General Construction

permittees (kg/yr)

General Industrial

permittees (kg/yr)

Caltrans

(kg/yr)

MS4 Permittees

(kg/yr)

Copper 0.033 0.004 0.022 2.01

Lead 0.045 0.006 0.030 2.75

Zinc 0.144 0.018 0.096 8.85

Organics

General Construction

permittees (g/yr)

General Industrial

permittees (g/yr)

Caltrans

(g/yr)

MS4 Permittees

(g/yr)

Chlordane 0.0005 0.0001 0.0003 0.0295

PCBs 0.0219 0.0029 0.015 1.34

Each storm water permittee enrolled under the general construction or industrial storm

water permits will receive individual waste load allocations on a per acre basis, based on

the acreage of their facility as presented in Table 5-6.
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 34

Table 5-6. Per acre waste load allocation for an individual general construction or

industrial storm water permittee (g/day/ac).

Metals

Individual General Construction or

Individual General Industrial Permittee

(g/yr/ac)

Copper 2.3

Lead 3.1

Zinc 10

Organics (mg/yr/ac)

Chlordane 0.03

PCBs 1.5

5.2.3 Waste Load Allocation for other NPDES Permits

Concentration-based sediment waste load allocations have been developed for the minor

NPDES permits and general non-storm water NPDES permits that discharge to Marina

del Rey Harbor to ensure that these do not contribute significant loadings to the system.

The concentration-based waste load allocations are equal to the sediment numeric targets.

All minor NPDES permittees and general non-storm water NPDES permittees shall not

discharge sediments with concentrations greater than the ERLs as listed in Table 5-7.

Monitoring requirements will be placed on these discharges as appropriate in their

respective NPDES permits. Any future minor NPDES permits or enrollees under a

general non-storm water NPDES permit will also be subject to the concentration-based

waste load allocations.

Table 5-7. Concentration-based waste load allocation for sediment discharged to Marina del

Rey Harbor.

Metals Waste Load Allocation for Sediment

Copper 34 mg/kg

Lead 46.7 mg/kg

Zinc 150 mg/kg

Organics Waste Load Allocation for Sediment

Chlordane 0.5 μg/kg

Total PCBs 22.7 μg/kg

5.2.4 Contaminated Inplace Sediment

The waste load allocations and load allocations have been developed to achieve the

numeric targets in the back basins of Marina del Rey Harbor by the end of the

compliance period. However, the Regional Board is aware of toxic pollutants bound up in

insitu sediment. To the extent that the Regional Board or another responsible jurisdiction

or agency determines that toxic pollutants bound in insitu sediments are still preventing

the attainment of numeric targets, the Regional Board will issue appropriate investigatory

orders or cleanup and abatement orders to achieve attainment of the numeric targets.
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 35

5.3 Summary of TMDL

The TMDL is based on pollutant loadings to the sediments of Marina del Rey’s back

basins. The sediment loading capacity is based on an estimate of the annual pollutant

loads that can be delivered to the sediments and still meet the sediment targets. A margin

of safety is provided through the use of ERLs. A grouped waste load allocation for

sediment has been developed for the storm water permittees (MS4, Caltrans, general

industrial and construction storm water permittees). Load allocations have been

developed for direct atmospheric deposition. Concentration-based waste load allocations

apply to all other non-storm water NPDES permittees. It is anticipated that

implementation will be based on BMPs which address pollution prevention and/or

sediment reduction. Compliance with the TMDL will be determined through the sediment

and water quality monitoring program.
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 36

6 IMPLEMENTATION

Because of the high value of the Marina del Rey for commercial and recreational uses

and its important biological function as a shallow coastal water habitat, it should be

targeted for an intensive, marina specific, contaminant management effort designed to

reduce the amount of pollution in urban runoff, and other discharges to the harbor The

County of Los Angeles, City of Los Angeles, and Culver City are jointly responsible for

meeting the mass-based waste load allocations for the MS4 permittees. Caltrans is

responsible for meeting their mass-based waste load allocations, however, they may

choose to work with the MS4 permittees. Since, MdRH is located in an unincorporated

area of the County of Los Angeles, the County of Los Angeles is the primary jurisdiction.

Additional studies and monitoring should assist municipalities in focusing their

implementation efforts on key land uses, critical sources and/or storm periods.

The City of Los Angeles, County of Los Angeles, Culver City, and Caltrans may jointly

decide how to achieve the necessary reductions in organics and metals loading by

employing one or more of the implementation strategies discussed below or any other

viable strategy. The Porter Cologne Water Quality Control Act prohibits the Regional

Board from prescribing the method of achieving compliance with water quality standards,

and likewise TMDLs. Below staff have identified some potential implementation

strategies; however, there is no requirement to follow the particular strategies proposed

herein as long as the allowable organics and metals loading are not exceeded.

6.1 Regulation by the Regional Board

The Porter-Cologne Water Quality Control Act provides that “All discharges of waste

into the waters of the State are privileges, not rights.”

1

Furthermore, all discharges are

subject to regulation under the Porter-Cologne Act including both point and non-point

source discharges.

2

In obligating the State Board and Regional Boards to address all

discharges of waste that can affect water quality, the legislature provided the State Board

and Regional Boards with authority in the form of administrative tools (waste discharge

requirements (WDRs), waivers of WDRs, and Basin Plan waste discharge prohibitions)

to address ongoing and proposed waste discharges. Hence, all current and proposed

discharges must be regulated under WDRs, waivers of WDRs, or a prohibition, or some

combination of these administrative tools. Since the USEPA delegated responsibility to

the State and Regional Boards for implementation of the National Pollutant Discharge

Elimination System (NPDES) program, WDRs for discharges to surface waters also serve

as NPDES permits.

1

See CWC section 13263(g).

2

See CWC sections 13260 and 13376.
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 37

6.1.1 Stormwater Discharges

As required by the federal Clean Water Act, discharges of pollutants to Marina del Rey

Harbor from municipal storm water conveyances are prohibited, unless the discharges are

in compliance with a NPDES permit. In December 2001, the Los Angeles County

Municipal NPDES Storm Water Permit was re-issued jointly to Los Angeles County and

84 cities as co-permittees. The regulatory mechanisms used to implement the TMDL will

include the Los Angeles County MS4 storm water permit, the Caltrans storm water

permit, general industrial storm water permits, general construction storm water permits,

minor NPDES permits, and general NPDES permits. Each NPDES permit assigned a

WLA shall be reopened or amended at re-issuance, in accordance with applicable laws, to

address implementation and monitoring of this TMDL and to be consistent with the waste

load allocations of this TMDL.

The concentration-based waste load allocations for the minor NPDES permits and

general non-storm water NPDES permits will be implemented through NPDES permit

conditions. Permit writers for the non-storm water permits may translate applicable

waste load allocations into effluent limits for the minor and general NPDES permits by

applying applicable engineering practices. The minor and existing general non-storm

water NPDES permittees are allowed up to seven years from the effective date of the

TMDL to achieve the waste load allocations.

The mass-based waste load allocations for the general construction and industrial storm

water permittees (Table 5-6) will be incorporated into watershed specific general permits.

Concentration-based permit limits may be set to achieve the mass-based waste load

allocations. These concentration-based limits would be equal to the concentration-based

waste load allocations assigned to the other NPDES permits (Table 5-7). It is expected

that permit writers will translate the waste load allocations into BMPs, based on BMP

performance data. However, the permit writers must provide adequate justification and

documentation to demonstrate that specified BMPs are expected to result in attainment of

the numeric waste load allocations.

Within seven years of the effective date of the TMDL, the construction industry will

submit the results of BMP effectiveness studies to determine BMPs that will achieve

compliance with the waste load allocations assigned to construction storm water

permittees. Regional Board staff will bring the recommended BMPs before the Regional

Board for consideration within eight years of the effective date of the TMDL. General

construction storm water permittees will be considered in compliance with waste load

allocations if they implement these Regional Board approved BMPs. All general

construction permittees must implement the approved BMPs within seven years of the

effective date of the TMDL. If no effectiveness studies are conducted and no BMPs are

approved by the Regional Board within eight years of the effective date of the TMDL,

each general construction and industrial storm water permit holder will be subject to sitespecific BMPs and monitoring requirements to demonstrate compliance with waste load

allocations.

The general industrial storm water permit shall contain a model monitoring and reporting

program to evaluate BMP effectiveness. A permittee enrolled under the general

industrial stormwater permit shall have the choice of conducting individual monitoring
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 38

based on the model program or participating in a group monitoring effort. A group

monitoring effort will not only assess individual compliance, but will also assess the

effectiveness of chosen BMPs to reduce pollutant loading on an industry-wide or permit

category basis. MS4 permittees are encouraged to take the lead in group monitoring

efforts for industrial facilities within their jurisdiction because compliance with waste

load allocations by these facilities will translate to reductions in contaminate loads to the

MS4 system.

The MS4 and Caltrans permittees shall be allowed a phased implementation schedule to

achieve the waste load allocations. A phased implementation approach, using a

combination of non-structural and structural BMPs could be used to achieve compliance

with the waste load allocations. The administrative record and the fact sheets for the

MS4 and Caltrans storm water permits must provide reasonable assurance that the BMPs

selected will be sufficient to implement the WLAs in the TMDL.

We expect that reductions to be achieved by each BMP will be documented and that

sufficient monitoring will be put in place to verify that the desired reductions are

achieved. The permits should also provide a mechanism to make adjustments to the

required BMPs as necessary to ensure their adequate performance. If non-structural

BMPs alone adequately implement the waste load allocations then additional controls are

not necessary. Alternatively, if the non-structural BMPs selected prove to be inadequate

then structural BMPs or additional controls may be required.

Each municipality and permittee will be required to meet the WLAs at the designated

assessment locations as defined in the TMDL effectiveness monitoring plan, not

necessarily an allocation for their jurisdiction or for specific land uses. Therefore, the

focus should be on developed areas where the contribution of metals, historic pesticides,

and PCBs are highest and areas where activities occur that contribute significant loading

of these toxic pollutants (e.g., high-density residential, industrial areas, boating, and

highways). Flexibility will be allowed in determining how to reduce these toxic

pollutants as long as the WLAs are achieved.

To achieve the necessary reductions to meet the allowable waste load allocations,

permittees will need to balance short-term capital investments directed to addressing this

and other TMDLs in the Marina del Rey watershed with long-term planning activities for

storm water management in the region as a whole. It should be emphasized that the

potential implementation strategies discussed below may contribute to the

implementation of other TMDLs for Marina del Rey. Likewise, implementation of other

TMDLs in the Marina del Rey Watershed may contribute to the implementation of this

TMDL.
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 39

6.2 Potential Implementation Strategies

The implementation strategy selected will need to control the loading of contaminated

sediments to Marina del Rey Harbor during wet weather, since, metals, historic

pesticides, and PCBs are predominately bound to sediment, which are transported with

storm runoff. Municipalities may employ a variety of implementation strategies to meet

the required waste load allocations such as non-structural and structural best

management practices (BMPs). The implementation strategies discussed below

incorporate implementation approaches presented in the Ballona Creek Metals and

Toxics TMDLs, which focus on source control and sediment control (LARWQCB,

2005b). Specific projects, which may have a significant impact, would be subject to a

separate environmental review. The lead agency for subsequent projects would be

obligated to mitigate any impacts they identify, for example by mitigating potential

flooding impacts by designing the BMPs with adequate margins of safety.

6.2.1 Non-Structural Best Management Practices

The non-structural BMPs are based on the premise that specific land uses or critical

sources can be targeted to achieve the TMDL waste load allocations. Non-structural

BMPs provide several advantages over structural BMPs. Non-structural BMPs can

typically be implemented in a relatively short period of time. The capital investment

required to implement non-structural BMPs is generally less than for structural BMPs.

However, the labor costs associated with non-structural BMPs may be higher, therefore,

in the long-term the non-structural BMPs may be more costly. Examples of nonstructural controls include better sediment control at construction sites and improved

street cleaning by upgrading to vacuum type sweepers.

6.2.2 Structural Best Management Practices

Structural BMPs may include placement of storm water treatment devices specifically

designed to reduce sediment loading such as infiltration trenches or filters at critical

points in the storm water conveyance system. During storm events, when flow rates are

high these types of filters may require surge control, such as underground storage vaults

or detention basins to avoid bypassing of the treatment unit.

6.3 Implementation Cost Analysis and CEQA considerations

This section takes into account a reasonable range of economic factors in estimating

potential costs associated with this TMDL. This analysis, together with the other sections

of this staff report, CEQA checklist, response to comments Basin Plan amendment and

supporting documents, were completed in fulfillment of the applicable provisions of the

California Environmental Quality Act (Public Resources Code Section 21159.)

3

3

Because this TMDL implements existing water quality objectives it does not “establish” water quality objectives and no further

analysis of the factors identified in Water Code section 13241 is required. However, the staff notes that its CEQA analysis provides

the necessary information to properly “consider” the factors specified in Water Code section 13241. As a result, the section 13241

analysis would at best be redundant.
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 40

6.3.1 Implementation Cost Analysis

This cost analysis focuses on achieving the grouped waste load allocation by the MS4

and Caltrans storm water permittees in the urbanized portion of the watershed

4

. The

BMPs and potential compliance approaches analyzed here could apply to the general

industrial and construction storm water permittees as well. An evaluation of the costs of

implementing this TMDL amounts to evaluating the costs of preventing contaminated

sediments from entering storm drains and/or reaching the Marina del Rey Harbor. Most

permittees would likely implement a combination of the structural and non-structural

BMPs to achieve their waste load allocations. This analysis considers a potential strategy

combining structural and non-structural BMPs through a phased implementation

approach and estimates the costs for this strategy. It will also be important to document

any possible reductions in sediment loading that may concurrently be achieved via BMPs

implemented under the Bacteria TMDL.

6.3.1.1 Phased Implementation

Under a phased implementation approach, it is assumed that compliance with the grouped

waste load allocation could be achieved in 30% of the urbanized portion of the watershed

through various iterations of non-structural BMPs. Compliance with the remaining 70%

of the urbanized portion of the watershed could be achieved through structural BMPs.

The first step of the potential phased approach would include the implementation of nonstructural BMPs by permittees, such as increasing the frequency and efficiency of street

sweeping. In their National Menu of Best Management Practices for Stormwater – Phase

II, USEPA reports that conventional mechanical street sweepers can reduce non-point

source pollution by 5 to 30% (USEPA, 1999a). The removal efficiencies of sediment for

conventional sweepers are dependent on the size of particles. Conventional sweepers,

including mechanical broom sweepers and vacuum-assisted wet sweepers, have removal

efficiencies of approximately 15 to 50% for particles less than 500 micrometers and up to

approximately 65% for larger particles (Walker and Wong, 1999). USEPA reports that

vacuum-assisted dry street sweeping can remove significantly more pollution, including

fine sediment and metals, before the pollutants are mobilized by rainwater. USEPA

reports a 50 to 88% overall reduction in annual sediment loading for residential areas by

vacuum-assisted dry street sweepers. As reported by Walker and Wong in a 1999 study

of the effectiveness of street sweeping for stormwater pollution control, Sutherland and

Jelen (1997) showed a total removal efficiency of 70% for fine particles and up to 96%

for larger particles by vacuum – assisted dry sweepers (also known as small-micron

surface sweepers). Upgrading to vacuum-assisted dry sweeping would translate to a

significant reduction of sediments. In their 1999 Preliminary Data Summary of Urban

4

This TMDL only addresses 1.5 square miles of the 2.9 square mile Marina del Rey watershed. Water comprises 0.08 square miles

of the area. It is not expected that the MS4 and Caltrans permittees will need to address areas of open water to meet the waste load

allocations. Therefore, areas of water are not considered in the calculation of the cost analysis. The remaining 1.42 square miles is

considered the portion of the watershed that may require BMPs and therefore, used in the cost analysis for the purposes of this TMDL.
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 41

Stormwater Best Management Practices, USEPA estimated cost data for both standard

mechanical and vacuum-assisted dry sweepers as shown in Table 6-1.

Table 6-1. Estimated costs for two types of street sweepers. (Source: USEPA, 1999b.)

Sweeper Type

Life

(Years)

Purchase

Price ($)

Annual O&M Cost

($/curb mile)

Mechanical 5 75,000 30

Vacuum-assisted 8 150,000 15

Table 6-1 illustrates that while the purchase price of vacuum-assisted dry sweepers is

higher, the operation and maintenance costs are lower than for standard sweepers. Based

on this information, USEPA determined the total annualized cost of operating street

sweepers per curb mile, for a variety of frequencies (Table 6-2). In their estimates,

USEPA assumed that one sweeper serves 8,160 curb miles during a year and assumed an

annual interest rate of 8 percent (USEPA, 1999b). According to Table 6-2, permittees

would save money in the long-term by switching to vacuum-assisted dry sweepers.

Table 6-2. Annualized sweeper costs, including purchase price and operation and

maintenance costs ($/curb mile/year).

Sweeping Frequency

Sweeper

Type Weekly Bi-weekly Monthly Quarterly

Twice per

year

Annually

Mechanical 1,680 840 388 129 65 32

VacuumAssisted946 473 218 73 36 18

Under a phased implementation approach, the permittees could monitor effectiveness

using flow-weighted composite sampling of runoff throughout representative storms to

determine the effectiveness of this first step of implementing non-structural BMPs. If

monitoring showed ineffectiveness, permittees could adapt their approach by increasing

frequency of street sweeping or incorporating other non-structural BMPs.

If the WLAs can not be achieved through non-structural BMPs, permittees could

incorporate structural BMPs. Two potential structural BMPs were analyzed in this cost

analysis:

1. Infiltration trenches

2. Sand filters

These approaches are specifically designed to treat urban runoff and to accommodate

high-density areas. They were chosen for this analysis because in addition to addressing

sediment loadings to the creek, they have the additional positive impact of addressing the

effects of development and increased impervious surfaces in the watershed. Both

approaches can be designed to capture and treat 0.5 to 1 inch of runoff. When flow

exceeds the design capacity of each device, untreated runoff is allowed to bypass the

device and enter the storm drain.
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 42

Both infiltration trenches and sand filters must be used in conjunction with some type of

pretreatment device such as a biofiltration strip or gross solids removal system to remove

sediment and trash in order to increase their efficiency and service life. This analysis

provides an estimate of the costs associated with installing sand filters or infiltration

trenches.

In addition, both infiltration trenches and sand filters are efficient in removing bacteria

and could be used to achieve the WLAs in the adopted bacteria TMDL for Marina del

Rey Harbor. USEPA reports that sand filters have a 76% removal rate and infiltration

trenches have a 90% removal rate for fecal coliform (USEPA, 1999c).

As stated previously, it is assumed that 70% of the urbanized portion of the watershed

would need to be treated by structural BMPs. In this cost analysis, it was assumed that

infiltration trenches would treat 35% of the watershed and sand filters would treat the

other 35%. Costs were estimated using data provided by USEPA (USEPA, 1999a and

1999c) and the Federal Highway Administration (FHWA, 2003). USEPA cost data were

reported in 1997 dollars. FHWA costs were reported in 1996 dollars for infiltration

trenches and 1994 dollars for sand filters. Where costs were reported as ranges, the

highest reported cost was assumed. These costs were then compared to costs determined

by Caltrans in their BMP Retrofit Pilot Program (Caltrans, 2004). Caltrans costs were

reported in 1999 dollars. To estimate land acquisition cots for individual projects in this

cost analysis would be purely speculative.

Infiltration trenches. Infiltration trenches store and slowly filter runoff through the

bottom of rock-filled trenches and then through the soil. Infiltration trenches can be

designed to treat any amount of runoff, but are ideal for treating small urban drainage

areas less than five to ten acres. Soils and topography are limiting factors in design and

siting, as soils must have high percolation rates and groundwater must be of adequate

depth. Potential impacts to groundwater by infiltration trenches could be avoided by

proper design and siting. Infiltration trenches are reported to achieve 75 to 90%

suspended solids removal and 75 to 90% metals removal by USEPA and FHWA. In their

BMP Retrofit Pilot Program, Caltrans assumed that constituent removal was 100 percent

for storm events less than the design storm, because all runoff would be infiltrated.

Table 6-3 presents estimated costs for infiltration trenches designed to treat 0.5 inches of

runoff over a five-acre drainage area with a runoff coefficient equal to one. Staff

determined that 130 devices, designed to treat five acres each, would be required to treat

35% of the land area of the watershed.

Table 6-3. Estimated Costs for Infiltration Trenches.

Construction

Costs

($ million)

Maintenance

Costs

($ million/year)

Based on USEPA estimate (1997 dollars) 2.88 0.58

Based on FHWA estimate (1996 dollars) 2.75 Not reported

Sand Filters. Sand filters work by a combination of sedimentation and filtration. Runoff

is temporarily stored in a pretreatment chamber or sedimentation basin, and then flows by
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 43

gravity or is pumped into a sand filter chamber. The filtered runoff is then discharged to

a storm drain or natural channel. The costs of two types of sand filters were analyzed: 1)

the Delaware sand filter, which is installed underground and suited to treat drainage areas

of approximately one acre and 2) the Austin sand filter, which is installed at-grade and

suited to larger drainage areas up to 50 acres. The underground sand filter is especially

well adapted for applications with limited land area and is independent of soil conditions

and depth to groundwater. However, both types of sand filters must consider the

imperviousness of the drainage areas in their design.

USEPA estimated a 70% removal of total suspended solids and 45% removal of lead and

zinc for both types of sand filters. FHWA reported high sediment, zinc and lead removal,

but low copper removal for Austin sand filters and high sediment and moderate to high

metals removal for Delaware sand filters. Caltrans reported a 50% reduction in total

copper, a 7% reduction in dissolved copper, an 87% reduction in total lead, a 40%

reduction in dissolved lead, an 80% reduction in total zinc and a 61% reduction in

dissolved zinc by the Austin sand filters they tested. Caltrans reported a 66% reduction

in total copper, a 40% reduction in dissolved copper, an 85% reduction in total lead, a

31% reduction in dissolved lead, a 92% reduction in total zinc and a 94% reduction in

dissolved zinc by the Delaware sand filter they tested.

USEPA and FHWA reported costs per acre for 0.5 inches of runoff. Total costs were

calculated by multiplying the per-acre cost by the total acreage of the urbanized portion

of the watershed not addressed through an integrated resources plan or non-structural

BMPs. Estimated costs are presented in Table 6-4. There are significant economies of

scale for Austin filters. USEPA reported that costs per acre decrease with increasing

drainage area. FHWA reported two separate costs based on drainage area served.

Economies of scale are not a factor for Delaware filters, as they are limited to drainage

areas of about one acre.

Table 6-4. Estimated Costs for Austin and Delaware Sand Filters

Austin Sand Filter

Construction Costs

($ million)

Austin Sand Filter

Maintenance Costs

($ million/year)

Delaware Sand

Filter Construction

Costs ($ million)

Delaware Sand Filter

Maintenance Costs

($ million/year)

Based on USEPA

estimate (1997

dollars)

2.93 0.15 1.74 0.09

Based on FHWA

estimate* (1994

dollars)

0.54 Not reported 2.22 Not reported

*FHWA cost estimate for Austin filter was calculated assuming a drainage area greater than five acres.

The costs would be $4.6 million for Austin filters designed for a drainage area of less than two acres.

Based on the adaptive management approach, and some assumptions about the

efficiencies of each stage of the approach, the cost analysis arrived at the total costs for

achieving the WLAs in the Toxic Pollutants TMDL as shown in Table 6-5. The total

costs do not include the cost savings associated with switching to vacuum-assisted street

sweepers. As stated previously, the costs associated with this adaptive management

approach could be applied towards the cost of achieving the WLAs in the Metals TMDLs

and the adopted Bacteria TMDL.
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 44

Table 6-5. Total Estimated costs of structural BMP approach for stormwater discharges.

Total Construction

($ million)

Total Maintenance

($ million/year)

Based on USEPA estimate(1997 dollars) 7.6 0.8

Based on FHWA estimate(1994/1996 dollars) 5.5 Not reported

6.3.1.2 Comparison of Costs Estimates with Caltrans Reported Costs

Estimated costs for structural BMPs were compared to costs reported by Caltrans in their

BMP Retrofit Pilot Program (Caltrans, 2004). Caltrans sited five Austin sand filters and

one Delaware sand filter as part of their study. The five Austin sand filters served an

average area of 2 acres and the Delaware sand filter served an area of 0.7 acres. Caltrans

sited two infiltration trench/biofiltration strip combinations as part of their study. Each

trench and biofiltration strip used in combination served an area of 1.7 acres. Based on

these drainage areas, the average adjusted cost of the Austin sand filters in the Caltrans

study was $156,600 per acre, the adjusted cost of the Delaware filter was $310,455 per

acre and the average adjusted cost of the infiltration trench/biofiltration strips was

$84,495 per acre. These costs are approximately an order of magnitude greater than the

costs determined using estimates provided by USEPA and FHWA. It should be noted that

costs calculated using EPA and FHWA estimates were based on infiltration trench and

sand filter designs that would treat 0.5 inches of runoff, while the Caltrans study costs

were based on an infiltration trench design that would treat 1 inch of runoff and sand

filter designs that would treat 0.56 to 1 inches of runoff. This could explain some of the

differences in costs.

The differences in costs can also be explained by a third party review of the Caltrans

study, conducted by Holmes & Narver, Inc. and Glenrose Engineering (Caltrans, 2001).

Holmes & Narver, Inc. and Glenrose Engineering (Caltrans, 2001). The review

compared adjusted Caltrans costs with costs of implementing BMPs by other state

transportation agencies and public entities. The adjusted costs exclude costs associated

with the unique pilot program and ancillary costs such as improvements to access roads,

landscaping or erosion control, and non-BMP related facilities. For the comparison, all

costs were adjusted for differences in regional economies. The third party review

determined that the median costs reported by Caltrans were higher than the median costs

reported by the other agencies for almost every BMP considered, including sand filters

and infiltration BMPs. The review attributed the higher Caltrans costs to the small scale

and accelerated nature of the pilot program. The third party review then gave

recommendations for construction cost reductions based on input from other state

agencies. These included simplifying design and material components, combining

retrofit work with ongoing construction projects, changing methods used to select and

work with construction contractors, allowing for a longer planing horizon, constructing a

larger number of BMPs at once, and implementing BMPs over a larger drainage area.
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 45

6.3.2 Results of a Region-wide Cost Study

In their report entitled “Alternative Approaches to Storm Water Quality Control,

Prepared for the Los Angeles Regional Water Quality Board,” Devinny et al. estimated

the total costs for compliance with Regional Board storm water quality regulations as

ranging from $2.8 billion, using entirely non-structural systems, to between $5.7 billion

and $7.4 billion, using regional treatment or infiltration systems. The report stated that

final costs would likely fall somewhere within this range. Table 6-6 presents the report’s

estimated costs for the various types of structural and non-structural systems that could

be used to achieve compliance with municipal storm water requirements throughout the

Region.

Table 6-6. Estimated costs of structural and non-structural compliance measures for

the entire Los Angeles Region. (Source: Devinny et al.)

Compliance Approach Estimated Costs

Enforcement of litter ordinances $9 million/year

Public Education $5 million/year

Increased storm drain cleaning $27 million/year

Installation of catch basin screens, enforcing litter laws, improving street cleaning $600 million

Low –flow diversion $28 million

Improved street cleaning $7.5 million/year

On-site BMPs for individual facilities $240 million

Structural BMPs – 1

st

estimation method $5.7 billion

Structural BMPs – 2

nd

estimation method $4.0 billion

The Devinny et al. study calculates costs for the entire Los Angeles Region, which is

3,100 square miles, while the Marina del Rey watershed is 2.9 square miles. When

compared on a per square mile basis, the costs estimated in section 6.5.1 are within the

range calculated by Devinny et al. (Table 6-7).

Table 6-7. Comparison of costs for storm water compliance on a per square mile basis.

Construction Costs

($ million/square mile)

Based on U.S. EPA estimate 2.62

Based on FHWA estimate 1.91

Maximum cost calculated by Devinny et al. 1.84 –2.39

The Devinny et al. study also estimated benefits associated with storm water compliance.

It was determined that the Region-wide benefits of a non-structural compliance program

would equal approximately $5.6 billion while the benefits of non-structural and regional

measures would equal approximately $18 billion. Region-wide estimated benefits

included:

 Flood control savings due to increased pervious surfaces of about $400 million,

 Property value increase due to additional green space of about $5 billion,

 Additional groundwater supplies due to increased infiltration worth about $7.2

billion,

 Willingness to pay to avoid storm water pollution worth about $2.5 billion,
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 46

 Cleaner streets worth about $950 million,

 Improved beach tourism worth about $100 million

 Improved nutrient recycling and atmospheric maintenance in coastal zones worth

about $2 billion,

 Savings from reduction of sedimentation in Regional harbors equal to about $330

million, and

 Unquantifiable health benefits of reducing exposure to fine particles from streets.
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 47

7 MONITORING

There are three objectives of monitoring associated with the TMDL. The first is to

collect additional water, and fish tissue quality data to evaluate the extent of impairment

in these media. The second is to assess the effectiveness of the TMDL and ultimately

achieving the waste load allocations. The third is to conduct special studies to address

the uncertainties in the TMDL and to assist in the design and sizing of BMPs. To achieve

these objectives, a monitoring program will need to be developed for the TMDL that

consists of three components: (1) ambient monitoring, (2) effectiveness monitoring and

(3) special studies.

The monitoring program and any required technical reports will be established pursuant

to a subsequent order issued by the Executive Officer. As a planning document, the

TMDL identifies the type of information necessary to refine and update it, and to assess

its effectiveness. The Executive Officer will comply with any necessary legal

requirements in developing the monitoring program, requiring technical reports, and

establishing special studies.

7.1 Ambient Component

A monitoring program is necessary to assess water quality throughout Marina del Rey

Harbor and to assess fish tissue and sediment quality in the harbor’s back basins. Data on

background water quality for copper will help refine the numeric targets and waste load

allocations and assist in the effective placement of BMPs. In addition, fish tissue data is

required in Marina del Rey's back basins to confirm continued impairment.

Water quality samples shall be collected monthly from the back basins and analyzed for

chlordane and total PCBs at detection limits that are at or below the minimum levels until

the TMDL is reconsidered in the sixth year. The minimum levels are those published by

the State Water Resources Control Board in Appendix 4 of the Policy for the

Implementation of Toxic Standards for Inland Surface Water, Enclosed Bays, and

Estuaries of California, March 2, 2000. Special emphasis should be placed on achieving

detection limits that will allow evaluation relative to the CTR standards. If these can not

be achieved with conventional techniques, then a special study should be proposed to

evaluate concentrations of organics.

Water quality samples shall also be collected monthly from the back basins and analyzed

for total recoverable and dissolved copper, lead, and zinc until the TMDL is reconsidered

in the sixth year. For total recoverable and dissolved copper analyses, monthly samples

will be collected throughout the harbor. For metals water column analysis, methods that

allow for (1) the removal of salt matrix to reduce interference and avoid inaccurate results

prior to the analysis; and (2) the use of trace metal clean sampling techniques, should be

applied. Examples of such methods include EPA Method 1669 for sample collection and

handling, and EPA Method 1640 for sample preparation and analysis.

Storm water monitoring shall be conducted for total recoverable and dissolved metals

(copper, lead, and zinc) and organics (chlordane and total PCBs) to provide assessment of

water quality during wet-weather conditions and loading estimates from the watershed to
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 48

the harbor. Special emphasis should be placed on achieving lower detection limits for

organochlorine compounds.

The MS4 and Caltrans storm water permittees are jointly responsible for conducting

bioaccumulation testing of fish within the harbor. The permittees are required to submit,

for approval of the Executive Officer, a monitoring plan that will provide the data needed

to confirm or challenge continued impairment of the 303(d) listed pollutants.

Representative sediment sampling shall be conducted quarterly within the back basins of

the harbor for copper, lead, zinc, chlordane, and total PCBs at detection limits that are

lower than the ERLs. Sediment samples shall also be analyzed for total organic carbon,

grain size and sediment toxicity. Initial sediment toxicity monitoring should be conducted

quarterly in the first year of the TMDL to define the baseline and semi-annually,

thereafter, to evaluate effectiveness of the BMPs until the TMDL is reconsidered in the

sixth year. The sediment toxicity testing shall include testing of multiple species, a

minimum of three, for lethal and non-lethal endpoints. Toxicity testing may include: the

28-day and 10-day amphipod mortality test; the sea urchin fertilization testing of

sediment pore water; and the bivalve embryo testing of the sediment/water interface. The

chronic 28-day and shorter-term 10-day amphipod tests may be conducted in the initial

year of quarterly testing and the results compared. If there is no significant difference in

the tests, then the less expensive 10-day test can be used throughout the rest of the

monitoring, with some periodic 28-day testing.

7.2 Effectiveness Component

The water quality samples collected during wet weather, shall be analyzed for total

dissolved solids, settleable solids and total suspended solids if not already part of the

sampling program. Sampling shall be designed to collect sufficient volumes of settleable

and suspended solids to allow for analysis of copper, lead, zinc, chlordane, total PCBs,

and total organic carbon in the sediment.

Monthly representative sediment sampling shall be conducted at existing monitoring

locations within the back basins of the harbor, and analyzed for copper, lead, zinc,

chlordane, and total PCBs at detection limits that are lower than the ERLs. The, sediment

samples shall also be analyzed for total organic carbon and grain size. Sediment toxicity

testing shall be conducted semi-annually, and shall include testing of multiple species (a

minimum of three) for lethal and non-lethal endpoints. Toxicity testing may include: the

28-day or 10-day amphipod mortality test; the sea urchin fertilization testing of sediment

pore water; and the bivalve embryo testing of the sediment/water interface.

Toxicity shall be indicated by an amphipod survival rate of 70% or less in a single test, in

conjunction with a statistically significant decrease in amphipod survival relative to

control organisms (significance determined by T-test, a=0.05). Accelerated monitoring

may be conducted to confirm toxicity at stations identified as toxic. Accelerated

monitoring shall consist of six additional tests, approximately every two weeks, over a

12-week period. If the results of any two of the six accelerated tests are less than 90%

survival, then the MS4 and Caltrans permittees shall conduct a Toxicity Identification

Evaluation (TIE). Alternatively, responsible parties have the option of foregoing
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 49

accelerated toxicity testing and conducting a TIE directly following an indication of

toxicity. The TIE shall include reasonable steps to identify the sources of toxicity and

steps to reduce the toxicity The Phase I TIE shall include the following treatments and

corresponding blanks: baseline toxicity; particle removal by centrifugation; solid phase

extraction of the centrifuged sample using C8, C18, or another approved media;

complexation of metals using ethylenediaminetetraacetic acid (EDTA) addition to the

raw sample; neutralization of oxidants/metals using sodium thiosulfate addition to the

raw sample; and inhibition of organo-phosphate (OP) pesticide activation using piperonyl

butoxide addition to the raw sample (crustacean toxicity tests only).

Bioaccumulation monitoring of fish and mussel tissue within the harbor shall be

conducted annually. The permittees are required to submit for approval of the Executive

Officer a monitoring plan that will provide the data needed to assess the effectiveness of

the TMDL The general industrial storm water permit shall contain a model monitoring

and reporting program to evaluate BMP effectiveness. A permittee enrolled under the

general industrial permit shall have the choice of conducting individual monitoring based

on the model program or participating in a group monitoring effort. MS4 permittees are

encouraged to take the lead in group monitoring efforts for industrial facilities within

their jurisdiction because compliance with waste load allocations by these facilities will

in many cases translate to reductions in contaminate loads to the MS4 system.

7.3 Special Studies

Special studies are necessary to refine source assessments, to provide better estimates of

loading capacity, and to optimize implementation efforts. The Regional Board will reconsider the TMDL in the sixth year after the effective date in light of the findings of

these studies.

Studies required for this TMDL include:

• Evaluate partitioning coefficients between water column and sediment to assess the

contribution of water column discharges to sediment concentrations in the harbor, and

• Evaluate the use of low detection level techniques to determine water quality

concentrations for those contaminants where standard detection limits cannot be used

to assess compliance for CTR standards or are not sufficient for estimating source

loadings from tributaries and storm water.

Studies recommended for this TMDL include:

• Develop and implement a monitoring program to collect the data necessary to apply a

multiple lines of evidence approach;

• Refine the relationship between pollutants and suspended solids aimed at better

understanding of the delivery of pollutants to the watershed, and

• Evaluate the effectiveness of BMPs to address pollutants and/or sediments.
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 50

8. FINAL TMDL MILESTONES AND IMPLEMENTATION SCHEDULE

The TMDL milestones and implementation schedule are summarized in Table 8-1. The

schedule allows time for dischargers to perform special studies and to develop

implementation plans before any waste load reductions are required.

8.1 Final TMDL Milestones

The Regional Board intends to reconsider this TMDL six years after the effective date of

the TMDL to re-evaluate the waste load allocations and the implementation schedule

based on the additional data obtained from the special studies. The Regional Board will

consider extending the implementation schedule from 10 years up to 15 years if an IRP

approach is pursued. Until the TMDL is revised, the waste load allocations will remain as

presented in Section 5. Revising the TMDL will not create a conflict, since the total

contaminated sediment reductions are not required until 10-15 years after the effective

date.

8.2 Implementation Schedule

The implementation schedule for all NPDES permittees is summarized in Table 8-1. The

municipalities and Caltrans are encourage to work together to meet the waste load

allocations. For the MS4 and Caltrans storm water permittees the proposed

implementation schedule consists of a phased approach, with compliance to be achieved

in incremental percentages of the watershed, with total compliance achieved within 10

years. This schedule is based on a combination of structural and non-structural strategies

designed specifically to reduce toxic pollutant loading to Marina del Rey Harbor.

However, should the responsible jurisdictions and agencies pursue an integrated water

resources approach that includes beneficial re-use of storm water, the Regional Board

will consider extending the allowable time to 15 years, in recognition of the additional

planning and time needed for this approach (see Table 8.1).
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 51

Table 8-1. Implementation Schedule

Date Action

Effective date of the TMDL Regional Board permit writers shall incorporate the waste

load allocations for sediment into the NPDES permits.

Waste load allocations will be implemented through NPDES

permit limits in accordance with the implementation

schedule contained herein, at the time of permit issuance,

renewal or re-opener.

On-going The Executive Officer shall promptly issue appropriate

investigatory and clean up and abatement orders to address

any toxicity hotspots within sediments identified as a result

of data submitted pursuant to this TMDL, any U.S. Army

Corps of Engineer dredging activity, or any other

investigation.

Within 6 months after the

effective date of the State Board

adopted sediment quality

objectives and implementation

policy

The Regional Board will re-assess the numeric targets and

waste load allocations for consistency with the State Board

adopted sediment quality objectives.

5 years after effective date of the

TMDL

Responsible jurisdictions and agencies shall provide to the

Regional Board result of any special studies.

6 years after effective date of the

TMDL

The Regional Board shall reconsider this TMDL to reevaluate the waste load allocations and the implementation

schedule.

NON-STORM WATER NPDES PERMITS (INCLUDING MINOR AND GENERAL

PERMITS)

7 years after effective date of the

TMDL

The non-storm water NPDES permittees shall achieve the

concentration-based waste load allocations for sediment per

provisions allowed for in NPDES permits.

GENERAL INDUSTRIAL STORM WATER PERMITS

7 years after effective date of the

TMDL

The general industrial storm water permittees shall achieve

the mass-based waste load allocations for sediment per

provisions allowed for in NPDES permits. Permits shall

allow an iterative BMP process including BMP effectiveness

monitoring to achieve compliance with permit requirements.

GENERAL CONSTRUCTION STORM WATER PERMITS

7 years from the effective date of

the TMDL

The construction industry will submit the results of the BMP

effectiveness studies to the Regional Board for

consideration. In the event that no effectiveness studies are

conducted and no BMPs are approved, permittees shall be

subject to site-specific BMPs and monitoring to demonstrate

BMP effectiveness.
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 52

Date Action

8 years from the effective date of

the TMDL

The Regional Board will consider results of the BMP

effectiveness studies and consider approval of BMPs no later

than eight years from the effective date of the TMDL.

9 years from the effective date of

the TMDL

All general construction storm water permittees shall

implement Regional Board-approved BMPs.

MS4 AND CALTRANS STORM WATER PERMITS

12 months after the effective date

of the TMDL

The MS4 and Caltrans storm water NPDES permittees must

submit a coordinated monitoring plan, to be approved by the

Executive Officer, which includes both ambient monitoring

and TMDL effectiveness monitoring. Once the coordinated

monitoring plan is approved by the Executive Officer,

monitoring shall commence within 6 months. The draft

monitoring report shall be made available for public

comment and the Executive Officer shall accept public

comments for at least 30 days.

5 years after effective date of

TMDL (Draft Report)

5 1⁄2 years after effective date of

TMDL (Final Report)

The MS4 and Caltrans storm water NPDES permittees shall

provide a written report to the Regional Board outlining how

they will achieve the waste load allocations for sediment to

Marina del Rey Harbor. The report shall include

implementation methods, an implementation schedule,

proposed milestones, and any applicable revisions to the

TMDL effectiveness monitoring plan. The draft report shall

be made available for public comment and the Executive

Officer shall accept public comments for at least 30 days.

Schedule for MS4 and Caltrans Permittees if Pursuing a TMDL Specific Implementation Plan

8 years after effective date of the

TMDL

The MS4 and Caltrans storm water NPDES permittees shall

demonstrate that 50% of the total drainage area served by

the MS4 system is effectively meeting the waste load

allocations for sediment.

10 years after effective date of the

TMDL

The MS4 and Caltrans storm water NPDES permittees shall

demonstrate that 100% of the total drainage area served by

the MS4 system is effectively meeting the waste load

allocations for sediment.

Schedule for MS4 and Caltrans Permittees if Pursuing an Integrated Resources Approach, per

Regional Board Approval

7 years after effective date of the

TMDL

The MS4 and Caltrans storm water NPDES permittees shall

demonstrate that 25% of the total drainage area served by

the MS4 system is effectively meeting the waste load

allocations for sediment.

9 years after effective date of the

TMDL

The MS4 and Caltrans storm water NPDES permittees shall

demonstrate that 50% of the total drainage area served by

the MS4 system is effectively meeting the waste load
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 53

Date Action

allocations for sediment.

11 years after effective date of the

TMDL

The MS4 and Caltrans storm water NPDES permittees shall

demonstrate that 75% of the total drainage area served by

the MS4 system is effectively meeting the waste load

allocations for sediment.

15 years after effective date of the

TMDL

The MS4 and Caltrans storm water NPDES permittees shall

demonstrate that 100% of the total drainage area served by

the MS4 system is effectively meeting the waste load

allocations for sediment.
Toxics TMDL for Marina del Rey Back Basins Final Report: October 6, 2005 54

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