# Walla Walla River
Chlorinated Pesticides and PCBs Total Maximum Daily Load (Water Cleanup Plan)

Submittal Report

February 2006
Publication Number 05-10-079

# Walla Walla River
Chlorinated Pesticides and PCBs Total Maximum Daily Load (Water Cleanup Plan)

Submittal Report

Prepared by:

Donovan Gray, Karin Baldwin, and Art Johnson

Washington State Department of Ecology Water Quality Program

4601 N. Monroe Street Spokane, Washington 99205-1295

February 2006
Publication Number 05-10-079For additional copies of this document contact:

Department of Ecology Water Quality Program Eastern Regional Office

4601 N. Monroe Street Spokane, Washington 99205-1295

Telephone: 509-329-3557

If you need this publication in an alternate fo rmat, please call the Wa ter Quality Program at
509-329-3557 . Persons with hearing loss can call 711 for Washington Relay Service. Persons with a speech disability can call 877-833-6341

.Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load: Page i Submittal Report 

# Table of Contents

List of Tables and Figures.....................................................................................................

.......... ii

Acknowledgements...............................................................................................................

......... iii

Introduction...................................................................................................................

.................. 1

Background.....................................................................................................................

................ 3

Applicable Criteria............................................................................................................

.............. 9

Water Quality and Resource Impairments.................................................................................... 13

Seasonal Variation .............................................................................................................

........... 17

Technical Analysis.............................................................................................................

........... 19

Loading Capacity...............................................................................................................

........... 26

Load and Wasteload Allocations .................................................................................................

. 29

Margin of Safety ...............................................................................................................

............ 37

Summary Implementation Strategy .............................................................................................. 39

References Cited ...............................................................................................................

............ 57

Appendix A - Evaluation of Toxics in the Walla Walla River................................................. A- 59

Appendix B - Walla Walla Watershed Plan ............................................................................. B- 61

Appendix C - Stormwater Management Manual for Eastern Washingtont.............................. C- 63

Appendix D - Model Municipal Stormwater Manual for Eastern Washington........................ D- 65

Appendix E - Upper Yakima Submittal Report.........................................................................E- 67

Appendix F - Agency for toxic Substance Registry ..................................................................F- 69

Appendix G - Acronyms and Abbreviations ............................................................................ G- 71

Appendix H - Responsiveness Summary.................................................................................. H- 73

Appendix I - Public Participation Materials .............................................................................I- 139Page ii Walla Walla River Chlorinated Pesticid es and PCBs Total Maximum Daily Load Submittal Report 

# List of Tables and Figures

Figure 1. Water Resource Inventory Area (WRIA) 32.................................................................. 4

Figure 2. Land Use in the Walla Walla Basin, 1986-1996 data .................................................... 5

Table 1. Applicable Washington State Water Qual ity Criteria* for Chlorinated Pesticides and

PCBs ..........................................................................................................................

.. 11

Table 2. Oregon State Water Qu ality Criteria* for Chlorina ted Pesticides and PCBs. ............... 12

Table 3. Walla Walla Sub basin (WRIA 32) Toxics 303(d) Listings and Impairments.............. 13

Figure 4. Typical flow patterns in the Walla Walla drainage (.................................................... 18

Figure 5. Water quality monitoring sites where SPMDs were deployed..................................... 20

Figure 6. Location of Walla Walla and College Place WWTPs.................................................. 21

Figure 7. Location of fish samples............................................................................................

... 22

Table 4. Loading Capacity for Chlorinate d Pesticides and PCBs in the Lower
Walla Walla River ........................................................................................................ 26

Table 5. Loading capacities for the Wa lla Walla mainstem and tributaries ................................ 27

Table 6. Loading Capacities for the East Lit tle Walla Walla River and Yellowhawk Creek .... 27

Table 7. Recommended load reductions in the mainstem Lower Walla Walla River................. 28

Table 8. Applicable Washington State Water Qual ity Criteria* for Chlorinated Pesticides and
PCBs as the basis for the load and wa steload allocations and TSS targets.................. 29

Table 9. Load allocations for the Walla Walla mainst em and tributaries, except for the East Little
Walla Walla River and Yellowhawk Creek. ................................................................ 31

Table 10. Load allocations for the East Little Walla Walla River and Yellowhawk Creek. ...... 31

Table 11. Fish Consumption Rates of CRITFC Me mber Tribes and Approximate Fish Meals per Month.................................................................................................................... 31

Table 12. TSS targets/goals a nd corresponding t-DDT concentra tions for the protection of average and high fish consumers among th e general public and tribal members. ...... 32

Table 13. Water quality targets for th e Walla Walla River drainage. ......................................... 33

Table 14. Water Quality Targets for the East Walla Walla River and Yellowhawk Creek. ....... 34

Table 15. Wasteload and Load allocations for PCBs in Garrison Creek, Mill Creek, and
Yellowhawk Creek...................................................................................................... 36

Table 16. Timelines for the achievement of inte rim targets and state water quality standards... 40

Table 17. Summary of management goals for th e Walla Walla chlorinated pesticides and

PCBs TMDL. .............................................................................................................. 41

Table 18. Organization of TMDL en tities and their contributions. ............................................. 45

Table 19. Miscellaneous existing projects related to water quali ty improvement in WRIA 32. 49Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load: Page iii Submittal Report 

# Acknowledgements

The authors of this report w ould like to thank the following people for their contributions:

• The Walla Walla TMDL advisory group for th eir valuable recommendations and support

• The Confederated Tribes of th e Umatilla Indian Reservations (CTUIR) for their valuable assistance during the sampling st ages of the TMDL evaluation.

• Washington State Department of Ecology, Water Quality Program Staff for their valuable advice and support

• Helen Rueda, EPA Region 10, for reviewing drafts of the reportPage iv Walla Walla River Chlorinated Pesticid es and PCBs Total Maximum Daily Load Submittal ReportWalla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load: Page 1 Submittal Report 

# Introduction

The Washington State Department of Ecology (Eco logy) is establishing a water quality clean-up plan or total maximum daily load (TMDL) for th e Washington State port ion of the Walla Walla basin that covers the pollution parameters of chlorinated pesticides and PCBs. This TMDL will address potential impairments of beneficial uses of the Walla Wa lla River and its tributaries in Washington State. Ecology does not have jurisdiction over the portion of the watershed in Oregon State that comprises roughly a quarter of the entire Walla Walla watershed. However, some load allocations are given in this TMDL for streams in Washington where the headwaters are in Oregon. Therefore, Ecology is mindful of the need to develop and foster strong and effective cross-border ties that will help coor dinate implementation efforts and ensure water quality is protected across the basin.

Under the Clean Water Act, every state has its ow n water quality standards designed to protect, restore, and preserve water qual ity. Water quality standards consis t of designated uses (such as cold-water biota and drinking water supply) and numeric standards to achieve those uses. When a water body fails to meet water quality standards after application of best management practices (BMPs) and required technology-ba sed controls, the Clean Water Act requires that the state place the water body on a list of impaired water bodies and to prepare an analysis called a TMDL. BMPs usually apply to nonpoint s ources and are defined in WAC 173-201A as ‘physical, structural and/or managerial practices approved by the department that, when used singularly or in combination, prevent or reduce pollutant discharges.’ Technology-based control typically applies to point sour ces and is the best technology av ailable that is economically achievable and can be applied to facilities to reduce po llution discharges. The U.S. Environmental Protection Agency (EPA) has es tablished regulations [40 Code of Federal Regulations (CFR) Part 130] a nd developed guidance for setting TMDLs (EPA, 1991). In June 2002, Washington State Department of Ecology de veloped its own guidance (which has been used in the writing of this document) for setting TMDLs.

The goal of a TMDL is to ensure that the impa ired water body will attain water quality standards within a reasonable time period. A TMDL includ es a written, quantitative assessment of the water quality problem and of the pollutant s ources that cause the problem. The TMDL determines the amount of a given pollutant (called the loading capacity) that can be discharged to the water body and still meet wa ter quality standards and, subse quently, allocates that load among the various sources. If the pollutant comes from a discrete source (referred to as a point source) such as an industr ial facility’s disc harge pipe, that facility’s share of the loading capacity is a wasteload allocation. If the pollution comes from a diffuse source (referred to as a nonpoint source) such as runoff from roads, parking lots , and fields, that shar e is a load allocation. However, each location that makes up the di ffuse source does not receive an individual allocation. Load allocations are assigned to the broad nonpoint source.

The TMDL must also consider seasonal variations and include a margin of safety that takes into account any lack of knowledge about the causes of the water quality pr oblem or its loading capacity. The sum of the individual allocations and the margin of sa fety must be equal to or less than the loading capacity.Page 2 Walla Walla River Chlorinated Pesticid es and PCBs Total Maximum Daily Load Submittal Report The general purposes of this submittal document are to:

• Provide an analysis of chlorinated pesticid es and PCB data from the Walla Walla River and tributaries from sampling performed by the Environmental Assessment Program (EAP) of the Washington State Depa rtment of Ecology from May 2002 through September 2003.

• Identify potential point and nonpoi nt sources of chlorinated pesticides and PCB pollution.

• Summarize ongoing and planned actions that wi ll allow the Walla Walla River and its tributaries to meet state water quality standards.

• Summarize proposed monitoring ac tivities to verify whethe r those standards are being

met.

• Fulfill requirements of the federal Clean Water Act.

A detailed implementation plan (DIP) will be developed within one year after the TMDL approval by the Environmental Protection Agency (EAP) and will be based on the information presented in this document.Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load: Page 3 Submittal Report 

# Background

Basin Description

The Walla Walla River is located in the south east corner of Washingt on State (Figure 1). The
river extends 61 miles from its h eadwaters in Oregon to its conflu ence with the Columbia River. The drainage basin covers appr oximately 1,760 square-m iles. Approximately three-quarters (73 percent) of the drainage and the last 40 miles of the mainst em lie within Washington. In downstream order, the major Washington tr ibutaries are Russell Creek, Reser Creek, Cottonwood Creek, Birch Creek, Yellowhawk Cree k, Stone Creek, Garrison Creek, Cold Creek, Mill Creek, East Little Walla Walla River, We st Little Walla Walla River, Dry Creek, Mud Creek, Pine Creek, the Touchet River, and the Gardena Creek.

Mill Creek flows from municipal wa tershed conditions in the Blue Mountains. Most of the city of Walla Walla’s drinking water comes from a 36 square-mile protecte d portion of upper Mill Creek. Approximately 14 miles below the waterworks, part of its flow is diverted to Yellowhawk and Garrison creeks year round for irrigati on purposes (Nicholson, pers. comm., 2005).

The two major permitted discharges in the basin are the Walla Walla Wastewater Treatment Plant (WWTP) that discharges to Mill Creek at river mile (R.M.) 5.4 and the College Place WWTP that discharges to Garrison Creek at R.M. 1.0. Yellowhawk, Garrison, and Mill creeks
enter the Walla Walla River between R.M. 37.9 a nd 33.6. The drainage area of the greater Mill Creek watershed is 96 square-miles.Page 4Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily LoadSubmittal ReportFigure 1. Water Resource Inventory Area (WRIA) 32Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load: Page 5 Submittal Report The Washington side of the Walla Walla basi n has few urban areas. The Washington State Office of Financial Management’s (OFM) mo st recent census results show there were approximately 56,700 people living in Walla Walla County in 2004. The major cities are Walla Walla and College Place, with a combined populati on of less than 40,000. Starting as early as the 1920s, the principal form of land use was producti on of small grains such as wheat and barley, and forage crops like alfalfa, and row crops (M apes, 1969). Currently, wheat , pasture, potatoes, alfalfa seed, and hay are the larg est percentage of the irrigate d crops. Pasture makes up roughly a quarter of irrigated lands on the Washington side of the Walla Wa lla basin. Other crops include onions, peas, grapes, apples, asparagus, and barl ey. Roughly 25 percent of the total acreage in
the Walla Walla basin is under th e Conservation Reserve Program (C RP), and just less than 1 percent is under the Conservation Reserve Enha ncement Program (CREP) (Walla Walla County
and Walla Walla Basin Watershed C ouncil, 2004). Figure 2 shows land use patterns as of the late 1980s/early 1990s. About 91 percent of land on the Washington side of the Walla Walla basin is privately owned with approximately 6 percent an d 2 percent owned by fede ral and state entities respectively (Hashim and Stalmaster, 2004).

Figure 2. Land Use in the Walla Walla Basin, 1986-1996 data

The Walla Walla basin consists primarily of ridge s and rolling hills interspersed with valleys. The ridges and hills are underlain by loessal (windblown silt) form ations up to 250 feet thick, except to the west where the soils are sa ndy. The valley floors are underlain by floodplain alluvium ranging in grain size from gravel to si lt. Beneath the floodplain al luvium are clay units
as much as 500 feet thick. Most benches within the valleys and terraces on the valley sides are composed of sand and silt of the Touchet Beds deposited by catastrophic floods from Montana’sPage 6 Walla Walla River Chlorinated Pesticid es and PCBs Total Maximum Daily Load Submittal Report glacial Lake Missoula. The last flood seri es was between about 15,000 and 13,000 years ago. Under all the sediment, and expos ed at the surface locally, ar e the Columbia River Basalts (CRB) which are thousands of feet of lava that erupted 17 to 6 million years ago. There are two major aquifers in the area. The basalts are the de ep confined aquifer. Th e gravels are the shallow unconfined aquifer. In general, streams are in hydraulic continuity with the shallow gravel aquifer. In the Walla Walla Valley the clays serv e to slow water movement between the shallow aquifer and the deep basalt aquifer (Newco mb, 1965, and Carson and Pogue, 1996). Folds and
faults in the basalt can work as natural dams , creating impediments to groundwater flow, large differences in groundwater pressure, and fluctua tions in water levels (HDR/EES Inc., 2005).

Elevation exerts significant control over cl imate in the Walla Walla basin, presenting temperature and precipitation gradie nts from west to east with th e rise in elevation towards the
Blue Mountains. Local climate varies from warm a nd semiarid in the western lowlands that lie in
the rain shadow of the Cascade Mo untains, to cool and relatively wet at higher elevations in the Blue Mountains. The average temper atures range from 20° to 25° F in the winter to 90° F to 95°F in the summer, with summer highs peaking in July and decreasing in late August. The
lower west end of the basin aver ages less than 10 inches of pr ecipitation per year (extremes can be as low as 4 inches), while the higher east end of the basin averages 40 to 60 inches of precipitation per year (HDR/EES Inc., 2005).

Although highly altered by grazing, prescribed burni ng, wildfires, and agri culture, remnants of the original grassland and shrub- steppe vegetation remain. However, the preliminary draft of the Walla Walla Watershed Plan (January 2005, section 3 pg. 4) states that mo st disturbed areas not
under cultivation can be domina ted by non-native invasive sp ecies such as cheat grass ( Bromus

tectorum ), velvet grass ( Holcus lanatus ), yellow star thistle ( Centaurea solstitialis ), barnyard grass ( Echinochloa crusgalli ), tansy ( Tanacetum vulgar ), and rattlegrass ( Bromus brizaeformis ). Of these, Bromus tectorum and Centaurea solstitialis may currently be the most significant invasive species (Schirman, pers. comm ., 2005). Riparian vegetation is limited in most areas throughout the basin, although consid erable riparian enhancement has occurred through efforts by Walla Walla County and Columbia Conservation Di stricts. Areas of shrubs and grasses in the western lowlands gradually give way to the ope n woodlands and then transition into the upland
coniferous forests of the Blue Mountains at hi gher elevations in the ea st (HDR/EES Inc., 2005).Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load: Page 7 Submittal Report Ecology’s Chlorinated Pe sticide and PCB Study

In 1996, the Walla Walla River was listed by the st ate of Washington under Section 303(d) of the
Clean Water Act for non-attainment of the EPA human health criteria for 4,4’-DDE, 4,4’-DDD, dieldrin, chlordane, hexachlorobenzene, heptach lor epoxide, and PCB-1260 in edible fish tissue. The listings are based on samp ling done by Ecology in 1993 (Davis et al ., 1995). The 1996 303(d) listings were maintained on the 1998 a nd draft 2002/2004 lists (Table 3). Garrison Creek, a Walla Walla tributary, was also proposed for listing in 2002/2004 due to human health violations of standards for DDT compounds and he xachlorobenzene in water samples (White et al., 1998). Prior to Ecology’s TMDL evaluation, t oxaphene was absent from Washington’s most recent toxin listings for the Walla Walla as it was previously unknown to violate water quality standards. However, Ecology’s 2002-2003 TMDL evaluation found Pine Creek to have relatively high concentrations of toxaphene, a nd is shown in this report as impaired.

Chlorinated pesticides, their breakdown products , and polychlorinated biphenyls (PCBs) are no longer used in the United States, having been banned in the 1970s and 1980s for ecological concerns. They are now classed as probable hum an carcinogens by EPA. Chlorinated pesticides have a range of possible negativ e human health effects, includ ing nervous system, digestive system, immune system, and reproductive syst em effects. They do not breakdown easily and bind strongly with the soil, and so often persist in the environment for many years. In the Walla Walla River watershed, the primary source of chlo rinated pesticides is thought to be from soil erosion from agricultural land s and runoff from urban areas.

Like chlorinated pesticides, P CBs (Polychlorinated Biphenyls) also breakdown very slowly and persist in the environment. For this reason, bot h chlorinated pesticides and PCBs are commonly referred to as ‘legacy pollutants’. PCBs do not bur n easily, have been used widely as coolants and lubricants, and because they do not conduct electrical charges readily, they have been used
as insulators in electrical transformers. PCBs can have severe human h ealth effects, possibly causing stomach, liver and kidney damage, skin ir ritation, and thyroid gla nd injuries. They are also suspected to be probable human carcinogens. PCBs released into th e air can enter the land or water by settling or from runo ff in snow and rain. Both chlorinated pesticides and PCBs can build up in fish tissue and can reach levels mu ch higher than those in the water, and can accumulate further in humans through fish c onsumption. Detailed profiles including use, regulations, environmental occurrenc e, and health effects have been prepared by the agency for Toxic Substances and Disease Registry (see Appendix F).

In 2002-2003, Ecology initiated a total maximum da ily load (TMDL) evaluation of chlorinated pesticides and PCBs in the Walla Walla River and its tributaries. The evaluation was based on a field study that sampled concentrations of these pollutants in fish tissu e and the water column, including sampling of the waste water treatment pl ant effluents for the cities of Walla Walla and College Place. The study area included the mainstem of the Walla Walla River and its tributaries from the Oregon border to the Columbia River. Tr ibutary sampling was conf ined to sites at or near their mouths. Water sampling was done prim arily on a quarterly basis: May-June, AugustSeptember, November-December of 2002, and November-December of 2003. Fish sampling was limited to resident mainstem species with upper ri ver fish being analyzed separately from lower river fish (see the sampling section under Technical Analysis for further information).Page 8 Walla Walla River Chlorinated Pesticid es and PCBs Total Maximum Daily Load Submittal Report The primary goals of the field study for the Wa lla Walla River chlorinated pesticide/PCB TMDL were to 1) quantify water column concentra tions and loadings of 303( d) listed pesticides and PCBs in the Walla Walla mainstem, major tributaries, and significant point sources; 2) recommend numerical water qual ity targets that will result in fish meeting human health standards; and 3) propose load allo cations to meet the targets. In pursuit of these goals, sufficient
data were obtained to allow an assessment of human health risk from fish consumption. Benchmarks were established to gauge future improvements in water quality.

Historical application of chlorina ted pesticides to soils and crops is the primary source of these chemicals in rivers and streams in agricultural areas like the Walla Walla basin. Because chlorinated pesticides bind strongly to soil part icles, the chief means to meeting pesticide
standards in the Walla Walla River and its trib utaries is to reduce th e amount of soil entering these water bodies. A report by Economic and Engi neering Services, Inc. (EES, as cited from Kuttel, 2001; Pacific Groundwater Group, 1995; Saul et al., 2001) has concl uded that erosion of fine sediment is a problem in the lower Walla Walla basin (EES, 2003). EES identified a number of sources of sediment including road-buildi ng and logging activities in the upper reaches of tributaries, recreational vehicle use, and urban runoff. They concluded, however, that “given the predominance of agricultural land use in the watershed, agricultural practices have been identified as the principal source of fine sedime nt.” Historically, agricu ltural areas have been large contributors to the suspended sediment problem in some drainages in the Walla Walla. Studies conducted in the 1960s showed yields of su spended sediment were greatest in the highly cultivated Touchet River and Dry Creek drainage basins that were contri buting up to 80 percent
of the total sediment load to the Walla Walla River (Mapes, 1969). Soils in these two drainages consist of well-drained silty loams and very fi ne sandy loams that are highly susceptible to erosion from runoff. Recently, much work has been done in the area to address agricultural sources of the problem.

Total suspended solids (TSS) and turbidity are pr oposed as water quality indicators and surrogate numerical targets for chlorinated pesticides in the Walla Walla River and its tributaries. Setting water quality targets based on TSS and turbidity ha s the advantage of translating more directly into land use practices and being easier and le ss expensive to monitor than trace chemical concentrations. Additionally, TSS and turbidity leve ls in rivers and streams have a direct and quantifiable effect on the health of fish and othe r aquatic organisms as we ll as aesthetic values.Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load: Page 9 Submittal Report 

# Applicable Criteria

The Washington State Water Qual ity Standards are published pursu ant to Chapter 90.48 of the Revised Code of Washington (RCW). The authority to adopt rules, regulations, and standards as necessary to protect the envir onment is vested with the stat e Department of Ecology. Under Section 303(c)(3) of the federal Clean Water Act, the EPA Regional Administrator approves the water quality standards adopted by the state. Th rough adoption of these standards, Washington State has designated certain characteristic uses to be protected and the criteria necessary to protect these uses (WAC 173-201A).

Although the Washington State Wa ter Quality Standards were re vised and adopted by the state on July 1, 2003, the standards from November 1997 will be used for this TMDL. The new water quality standards will not take effect for proj ects that require federal action until EPA approves the new standards. TMDLs under development with field work completed will continue to use the 1997 version of the water qualit y standards, per Ecology document Concise Explanatory Statement and Responsiveness Summary for the Adoption of Water Quality Standards, Chapter
173-201A WAC published July 1, 2003. At the time of writing this report, revisions to the water use and criteria classes (WAC 173-201A-030) and toxic substan ces sections (WAC 173-201A040) had not yet been approved, thus the 1997 st andards are employed. However, the toxics
criteria for this TMDL are not be ing revised and are still in effect in the same form they will be in after the revised standards are approved.

Under WAC 173-201A-030 (1997) the Walla Walla Rive r drainage is a predominately a Class A system, although portions of the mainstem and Mill Creek are Class B. The characteristic
beneficial uses of a Class A and Class B water bodies are described in WAC 173-201A-030 (2)(a) and (b) and WAC 173-201A-030 (3)(a ) and(b) (1997) respectively as:

Characteristic uses shall include, but not be limited to, the following: (i) Water supply (domestic, industrial, agricultural). (ii) Stock watering. (iii) Fish and shellfish: Salmonid migration, rearing, spawning, and harvesting. Other fish migration, rearing, spawning, and harvesting. Clam, oyster, and mussel rearing, spawning, and harvesting. Crustaceans and other shellfish (crabs , shrimp, crayfish, scallops, etc.) rearing, spawning, and harvesting. (iv) Wildlife habitat. (v) Recreation (primary contact recreation, sport fishing, boating, and aesthetic enjoyment). (vi) Commerce and navigation. [WAC 173-201A-030(2)(b)and (3)(b)]

State law does not establish a ra nking priority among the benefi cial uses, but the individual waters are expected to support a ll uses within the classification.Page 10 Walla Walla River Chlorinated Pesticid es and PCBs Total Maximum Daily Load Submittal Report Toxic Substances: Washington State Regulations

WAC 173-201A-030 (2) (vii) and (3) (vii) state the follo wing with regard to toxic substances:

Toxic, radioactive, or deleterious material concentrations shall be below those which have the potential either singular ly or cumulatively to adve rsely affect characteristic water uses, cause acute or chronic conditions to the most sensiti ve biota dependent upon those waters, or adversely affect public he alth, as determined by the department (see WAC 173-201A-040 and 173-201A-050).

Toxics substances are further addressed in WAC 173-201A-040 as follows (selected sections):

(1) Toxic substances shall not be introdu ced above natural background levels in waters of the state which have the potential either si ngularly or cumulatively to adversely affect characteristic water uses, cause acute or ch ronic toxicity to the most sensitive biota dependent upon those waters, or adversely af fect public health, as determined by the department.

(2) The department shall empl oy or require chemical tes ting, acute and chronic toxicity testing, and biological assessm ents, as appropriate, to evaluate compliance with subsection (1) of this section and to ensure that aquatic communities and the existing and characteristic benefici al uses of waters are being fully protected.

(5) Concentrations of toxic and other substances with toxi c propensities not listed in Subsection (3) of this section shall be dete rmined in consideration of USEPA Quality Criteria for Water, 1986, as revised, and othe r relevant information as appropriate. Human health-based water quality criteria us ed by the state are contained in 40 CFR 131.36 (known as the National Toxics Rule).

(6) Risk-based criteria for carc inogenic substances shall be selected such that the upperbound excess cancer risk is less than or equal to one in one million.

Washington State water quality crite ria that apply to 303(d) listed pesticides and PCBs in the Walla Walla drainage are shown in Table 1 [fr om sections (3) and (5) of WAC 173-201A-040].
The human health criteria are for a one in one million increased lifetime cancer risk from consumption of water and fish or fish only. A fi sh consumption rate of 6.5 grams per day and a water consumption rate of 2 liters per day are assumed. These criteria were promulgated for Washington in the EPA National Toxics Rule (40 CFR 131.36).Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load: Page 11 Submittal Report Table 1. Applicable Washington State Water Quality Criteria* for Chlorinated Pesticides and PCBs (ng/L; parts per trillion).

Criteria for Protection Criteria for Protection
of Aquatic Life of Human Health

Chemical Freshwater Freshwater Water and Fish Fish

Acute Chronic Consumption Consumption

4,4'-DDT 0.59 0.59

4,4'-DDE 0.59 0.59

4,4'-DDD 0.83 0.84
DDT (and metabolites) 1,100 1.0

Dieldrin 2,500 1.9 0.14 0.14
Heptachlor 520 3.8 0.21 0.21
Heptachlor epoxide 0.10 0.11

Hexachlorobenzene 0.75 0.77

Chlordane 2,400 4.3 0.57 0.59
Toxaphene 730 0.2 0.73 0.75

PCBs 2,000 14 0.17 0.17
*WAC 173-201A-040 (1997 version http://www.ecy.wa.gov/programs/wq/swqs/wac173201a1997.pdf ) EPA promulgated the human health criteria for Washington in 40 CFR 131.36

Toxic Substances: Oregon State Regulations

Approximately one quarter of the Walla Walla dr ainage lies in Oregon State and does not fall under Washington State Department of Ecology’s ju risdiction. Beneficial us es and water quality
standards for the surface waters of the state of Oregon are codifi ed in the Oregon Administrative Rules (OAR) Chapter 340, Division 41. Beneficial uses for the Walla Walla River basin are given in OAR 340-041-0330 and are shown below

Beneficial Uses Walla Walla River Mainstem
from Confluence of North and
South Forks to State Line All Other
Basin

Streams

* Public domestic water supply X X

* Private domestic water supply X X Industrial water supply X Irrigation X X Livestock watering X X Anadromous fish passage X X Salmonid fish rearing X X Salmonid fish spawning X X Resident fish & aquatic Life X X Wildlife & hunting X X Fishing X X Boating X X

Water contact recreation X X Aesthetic quality X X Hydro power X

*With adequate pretreatment (filtration and disinfection) and natural quality to meet drinking water standards.Page 12 Walla Walla River Chlorinated Pesticid es and PCBs Total Maximum Daily Load Submittal Report The newly adopted Oregon Administrative Ru le (OAR) 340-041-0033 states the following with regard to toxic substances.

(1) Toxic substances may not be introduced above natural background levels in waters of the state in amounts, concentrations, or combinations that may be harmful, may chemically change to harmful forms in the en vironment, or may accumulate in sediments or bioaccumulate in aquatic life or wildlife to levels that adversely affect public health, safety, or welfare of aquatic life, wildlif e, or other designated beneficial uses.

(2) Levels of toxic substances in waters of the state may not exceed the applicable criteria
listed...

The revised adopted toxics criteria in Oregon Administ rative Rule (OAR) 340-0410-0033 are not Water Quality Standards as defined under the Clean Water Act as they have not received EPA approval. However, as of February 15, 2005, Oregon Department of Environmental Quality (DEQ) has chosen to use the new criteria to produce TMDLs where they are overly protective with regard to the ‘applicable’ water quality standards (Fitzpatrick, M. pers. comm., 2005). Where the ‘old’ criteria are more stringent these continue to be used for Oregon TMDLs until th e new criteria are approved by the EPA. A complete list of the more stringent criteria can be found in Table 33A of Division 41 at
http://www.deq.state.or.us/wq/wqrules/wqrules.htm

. It should be noted that Table 33A values cannot yet be used for listing a water body as impaired because those standards are yet be approved by EPA. Table 2 shows the new more stringent Oregon State criteria for the toxins addressed in this submittal report. Figures in bold represent the ‘old’ criteria that continue to be employed in Oregon TMDLs where they are mo re stringent than the new
criteria.

Table 2. Oregon State Water Quality Criteria* for Chlorinated Pesticides and PCBs (ng/L; parts per trillion figures in bold represent ‘old’ cri teria still in use where th ey are more stringent).

Criteria for Protection Guidance Values for the
of Aquatic Life Protection of Human Health

Freshwater Freshwater Water and Fish Fish

Chemical Acute Chronic Consumption Consumption

4,4'-DDT 1,100 1.0 0.024 0.024

4,4'-DDE 0.22 0.22

4,4'-DDD 0.31 0.31

Dieldrin 240 1. 9 0.052 0.052
Heptachlor 520 3.8 0.079 0.079
Heptachlor epoxide 520 3.8 0.039 0.039

Hexachlorobenzene 0.28 0.29

Chlordane 2,400 4.3 0.46 0.48
Toxaphene 730 0.2 0.28 0.28

PCBs 2,000 14 0.064 0.064

*OAR 340-041-0033 (‘new’ criteria) and OAR 340-041-0685 (‘old’ criteria).Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load: Page 13 Submittal Report 

# Water Quality and Resource Impairments

Sampling conducted in 1993 indicated the Washingt on State’s water quality standards had been
violated in various water bodies of the Walla Walla drainage a nd these were then considered ‘impaired.’ Several of these water bodies were included on both the state’s 1996 and 1998 Section 303(d) list for non-atta inment of the EPA’s human health criteria for 4,4’DDE; 4,4’DDD; dieldrin; chlordane; hexachlorobenzene; heptachlor epoxide; a nd PCB 1260 in edible fish tissue. Although sections of the Walla Walla and its tributaries were identified as being impaired for other factors (including, but not restricted to: pH; dissolved oxygen; and temperature), this report a ddresses only chlo rinated pesticides and PCB’s.

Although parts of the Oregon side of the Walla Walla drainage appear on the 303(d) list as impaired for temperature, there are currently no listed impairments fo r toxins (Butcher, 2005

pers. comm .). However, it is important to note that in order to meet the most stringent toxin target loads it may be necessary to address activities taking place in Oregon with the help of state and local authorities at a later date. Toxin impairments in the Walla Walla River watershed that
are addressed in this TMDL are summarized in Table 3.

In 2002-2003, Ecology conducted a TMDL evaluati on of the chlorinated pesticide and PCB problem in the Walla Walla River and its trib utaries. This study f ound several additional exceedances previously not on the 1996 and 1998 303( d) lists. These are shown in Table 3 as ‘other areas not meeting standards’. The dead line for the inclusion of new data in the 2004 303(d) list was 12/31/2003. Although water qual ity samples for the Walla Walla TMDL assessment had been collected by this time, the da ta had not yet been anal yzed and so were not
available for inclusion in the current 303(d) list.

Table 3. Walla Walla Sub ba sin (WRIA 32) Toxics 303(d) Listings and Impairments.

Water Body Waterbody ID#(old) Waterbody ID#(new) Parameter Medium Township Range
Section 1996
List 1998
List 2004
List Other

areas not meeting
standards

Walla Walla
River WA-32-
1010 QE90PI 4,4’-DDT Tissue 07N

31E
25 No No
40970

Walla Walla
River WA-32-
1010 QE90PI 4,4’-DDE Tissue 07N

31E
25 Yes Yes
8806

Walla Walla
River WA-32-
1010 QE90PI Chlordane Tissue 07N
31E
25 Yes Yes
8804

Walla Walla
River WA-32-
1010 QE90PI Dieldrin Tissue 07N
31E
25 Yes Yes
8805

Walla Walla
River WA-32-
1010 QE90PI Heptachlor epoxide Tissue 07N
31E
25 Yes Yes
8808

Walla Walla
River WA-32-
1010 QE90PI Hexachlorobenzene Tissue 07N

31E
26 Yes Yes
8809

Walla Walla
River WA-32-
1010 QE90PI Total PCBs Tissue 07N

31E
26 Yes Yes
8810Page 14 Walla Walla River Chlorinated Pesticid es and PCBs Total Maximum Daily Load Submittal Report Water Body Waterbody ID#(old) Waterbody ID#(new) Parameter Medium Township Range
Section 1996
List 1998
List 2004
List Other

areas not meeting
standards

Walla Walla
River WA-32-
1010 QE90PI 4,4’-DDE Tissue 07N
32E
35 No No
14178

Garrison

Creek DH35GB 4,4’-DDT Water 06N
35E

3 No No
14386

Garrison

Creek DH35GB 4,4’-DDE Water 06N
35E

3 No No
40969

Garrison

Creek DH35GB 4,4’-DDD Water 06N
35E

3 No No
40968

Garrison

Creek DH35GB Hexachlorobenzene Water 06N
35E

3 No No
14389

Walla Walla
River QE90PI Toxaphene Tissue 07N
32E

21 No No No X

Walla Walla
River QE90PI 4,4’-DDE Tissue 07N

32E

21 No No No X

Walla Walla
River QE90PI 4,4’-DDD Tissue 07N

32E

21 No No No X

Walla Walla
River QE90PI Chlordane Tissue 07N
32E

21 No No No X

Walla Walla
River QE90PI Dieldrin Tissue 07N
32E

21 No No No X

Walla Walla
River QE90PI Heptachlor epoxide Tissue 07N
32E

21 No No No X

Walla Walla
River QE90PI Hexachlorobenze Tissue 07N

32E

21 No No No X

Walla Walla
River QE90PI PCBs Tissue 07N

32E

21 No No No X

Walla Walla
River QE90PI 4,4’-DDE Water 07N
32E
36 No No No X

Walla Walla
River QE90PI Dieldrin Water 07N
32E
36 No No No X

Walla Walla
River QE90PI Toxaphene Water 07N

32E
36 No No No X

Walla Walla
River QE90PI PCBs Water 07N
32E
36 No No No X

Walla Walla
River QE90PI 4,4’-DDE Tissue 07N
35
31 No No No X

Walla Walla
River QE90PI Dieldrin Tissue 07N
35 No No No XWalla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load: Page 15 Submittal Report Water Body Waterbody ID#(old) Waterbody ID#(new) Parameter Medium Township Range
Section 1996
List 1998
List 2004
List Other

areas not meeting
standards

31

Walla Walla
River QE90PI Chlordane Tissue 07N
35
31 No No No X

Walla Walla
River QE90PI PCBs Tissue 07N
35
31 No No No X

Walla Walla
River QE90PI Toxaphene Tissue 07N
35
31 No No No X

Walla Walla
River QE90PI 4,4’-DDE Water 07N
35E
31 No No No X

Walla Walla
River QE90PI 4,4’-DDT Water 07N
35E
31 No No No X

Walla Walla
River QE90PI Dieldrin Water 07N
35E
31 No No No X

Walla Walla
River QE90PI PCBs Water 07N
35E
31 No No No X

Walla Walla
River QE90PI Chlordane Water 07N
35E
31 No No No X

Dry Creek OT03FJ Dieldrin Water 07N

34E
29 No No No X

Dry Creek OT03FJ Hexachlorobenzene Water 07N
34E
29 No No No X

East Walla
Walla River XO26DW 4,4’-DDE Water 06N
35E
38 No No No X

East Walla
Walla River XO26DW Dieldrin Water 06N
35E
38 No No No X

East Walla
Walla River XO26DW Heptachlor epoxide Water 06N
35E
38 No No No X

Gardena

Creek t-DDT Water 06N
33E

8 No No No X

Garrison

Creek DH35GB t-DDT Water 06N
35E

3 No No No X

Garrison

Creek DH35GB Dieldrin Water 06N
35E

3 No No No X

Garrison

Creek DH35GB PCBs Water 06N
35E

3 No No No X

Garrison

Creek DH35GB Chlordane Water 06N
35E

3 No No No X

Mill Creek SS77BG t-DDT Water 07N
35E
38 No No No XPage 16 Walla Walla River Chlorinated Pesticid es and PCBs Total Maximum Daily Load Submittal Report Water Body Waterbody ID#(old) Waterbody ID#(new) Parameter Medium Township Range
Section 1996
List 1998
List 2004
List Other

areas not meeting
standards

Mill Creek SS77BG 4,4’-DDE Water 07N
35E
38 No No No X

Mill Creek SS77BG Dieldrin Water 07N
35E
38 No No No X

Mill Creek SS77BG Chlordane Water 07N
35E
38 No No No X

Mill Creek SS77BG PCBs Water 07N
35E
38 No No No X

Pine Creek ZX47PC Toxaphene Water 06N
33E

1 No No No X

Pine Creek ZX47PC 4,4’-DDE Water 06N
33E

1 No No No X

Pine Creek ZX47PC 4,4’-DDT Water 06N

33E

1 No No No X

Pine Creek ZX47PC Dieldrin Water 06N

33E

1 No No No X

Pine Creek ZX47PC Heptachlor epoxide Water 06N
33E

1 No No No X

Yellowhawk
Creek RK92TG 4,4’-DDE Water 06N
35E

1 No No No X

Yellowhawk
Creek RK92TG 4,4’-DDT Water 06N
35E

1 No No No X

Yellowhawk
Creek RK92TG Dieldrin Water 06N
35E

1 No No No X

Yellowhawk
Creek RK92TG PCBs Water 06N
35E

1 No No No X

Yellowhawk
Creek RK92TG Chlordane Water 06N
35E

1 No No No XWalla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load: Page 17 Submittal Report 

# Seasonal Variation

Ecology’s TMDL evaluation of the Walla Walla watershed found a strong correlation between the levels of chlorinated pesticides and sedi ment loads in the water column. The correlation
between PCBs and sediment loads was weaker. The TMDL evaluation and historical data both show that the period of highest stream flow and sediment load is January to June, which coincides with the times of highest chlorina ted pesticide and PCB concentrations. Both chlorinated pesticides and PCBs are well known fo r their propensity to bind strongly with soil particles. This and knowledge of the historical pesticide applica tion in the area, leads to the conclusion that the primary source of these chemicals in the Walla Walla River and its tributaries was probably soil erosion.

Elevation can have a significant influence on c limate in the Walla Walla Basin. Temperature and precipitation gradients exist from west to east with the rise in elevation towards the Blue Mountains (see figure 3).

Figure 3 Isopluvial Map of the Walla Walla Watershe d (HDR/EES, from the Walla Walla Watershed Plan, Exhibit 3-3, May 2005)
The majority of soil erosion in the Walla Walla ba sin occurs from precipitation in winter through early spring, flow is sustained though June from snowmelt (see figur e 4). Infrequent storm events during winter months sometimes cause severe fl ooding from heavy rain that can contribute the highest suspended sediments to the water column (Mapes, 1969).Page 18 Walla Walla River Chlorinated Pesticid es and PCBs Total Maximum Daily Load Submittal Report 0 200 400 600 800 1000 1200 1400

May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar AprFlow (cfs) Walla Walla R. Touchet R. Mill Cr.

Yellowhawk Cr. Dry Cr.

Figure 4. Typical flow patterns in the Walla Walla drainage (monthly averages from USGS data, 1951-2002 USGS gauge stations: 14018500; 14017500; 14015000; 14014000; 1401600).
Data collected in Ecology’s TMDL evaluation show ed marked seasonal variations in the level of pesticide/PCB contamination in the mainstem. The highest pesticide c oncentrations always coincided with high flow periods. Similarly the lo west concentrations a lmost always coincided with low flow periods. Runoff from agricultural land is highest during high flow periods which coincides with the high concentrations observed. The highest PCB concentrations were similarl y recorded during high flow months. Seasonal fluctuations in pesticide/PCB leve ls were also pronounced in the tr ibutaries. Pesticides and PCBs increased substantially in the Walla Walla ma instem between the Oregon border and Detour Road. On average, concentrations increased by fa ctors of two to four from the upper to middle river, with an eleven-fold increase for dieldr in. Except for toxaphene, concentrations generally decreased in the lower Walla Walla River (bel ow Cummins Bridge). Th e reduced lower river concentrations are largely attributable to diluti on by the Touchet River. The lower river averaged five times the toxaphene concentrations measured upstream.Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load: Page 19 Submittal Report 

# Technical Analysis

This section summarizes the sampling and data analysis methods used in Ecology’s 2002-2003 TMDL evaluation. Those seeking more detailed information should refer to the technical study (see Appendix A).

Sampling

Ecology’s TMDL evaluation of chlorinated pestic ides and PCBs in the Walla Walla drainage was based on water column, fish tissue, and wastewater treatment plant effluent sampling conducted from May 2002 to September 2003.

The purpose of the water sampling was to 1) identify possible or potential sources of contamination; 2) assess compliance with human health and aquatic life criteria; 3) test for relationships between chlorinated pe sticides, TSS, and turbidity; a nd 4) calculate loadings to and
within the river.

Concentrations of 303(d) listed pesticides and PCBs were sampled using semipermeable membrane devices (SPMDs) developed by the U.S. Geological Survey. A combination of laboratory calibration data and permeability/performance referenc e compounds (PRCs) spiked in deployed SPMDs were used in conjunction with field temperature to obtain an estimate of average concentrations.

An SPMD consists of a polyethylene tube filled with a lipid material called triolein. The rate at which SPMDs take up pesticides and PCBs has been determined in the laboratory. The rate varies with temperature, water flow, and the amount of biological growth on the membrane surface. Performance reference compounds (PRCs) ar e used to account for differences in these parameters between laboratory and field condi tions. PRC compounds are spiked into an SPMD prior to deployment in a stream. The rate at which the PRCs are lost from the SPMD is proportional to the rate at whic h target compounds in the surrounding water are taken up by the SPMD. In other words, PRCs show how well th e SPMD is performing compared to what was observed in the laboratory. The water column concentration determined from the SPMD is adjusted for the loss rate of the PRCs. A high ra te of loss means the SPMD is sampling at a high rate, i.e., there is a high rate of move ment of chemicals through the membrane. SPMDs provide a time-weighted average concentration for the chemicals of interest and measure only the dissolved ready bioavailable fraction. Ecology’ s study deployed SPMDs at ten sites (shown in Figure 4) on a quarterly basis for approximately one month each. Deployments were timed to provide representative data over the range of runoff conditions that normally occur in the drainage. SPMD extracts were analyzed for the 303(d) listed pesticides and PCBs. This analysis was later expanded to in clude toxaphene, based on the examination of the chromatograms from the initial deployment in May. When chlorinated organic compounds are discharged to surface waters, they partition be tween dissolved and particulate fractions. Total pesticide/PCB concentrations in the Walla Walla drainage were mathematically estimated from the SPMD data. This is discussed in greater detail in A Total Maximum Daily Load Evaluation for Chlorinated Pesticides and PC Bs in the Walla Walla River (see Appendix A).Page 20 Walla Walla River Chlorinated Pesticid es and PCBs Total Maximum Daily Load Submittal Report  

	

	

	                



 

 

     

  

  



 

    



 





 

    



  

  

  

 

     

  

 



  

 

         

  

      

    
 



Figure 5. Water quality monitori ng sites where SPMDs were deployed.

In addition to water sampling at the ten sites shown in Figure 4, wastewater treatment plants (WWTPs) at the cities of Walla Walla and College Place were evaluated separately as possible sources of chlorinated pesticides and PCBs. The Walla Walla plant discharges to Mill Creek and the College Place plant discharges to Garrison Creek (Figure 5). The other two WWTPs in the basin (Dayton and Waitsburg) are small discharges (< 1 million gallons pe r day) located over 40 miles up the Touchet River. As such, these plants are unlikely si gnificant pesticide/PCB
contributors to the Walla Walla River. Industrie s and other permitted faci lities in the Walla
Walla basin are not lik ely significant sources.Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load: Page 21 Submittal Report For the TMDL study, composite effluent sample s were collected over a two-day period on a quarterly basis from the Walla Walla and College Place WWTPs. The locations of the effluent sampling sites are given in the TMDL techni cal report (see Appendix A). Sampling was done near the midpoint of the SPMD deployment period. Each sample was analyzed for chlorinated pesticides, PCBs, total suspended solids (TSS), and conductivity.

	

 




	 
  

  	

	     

     

Figure 6. Location of Walla Walla and College Place WWTPs.

The purpose of collecting the fish tissue samples was to 1) determine the extent to which the pesticides and PCBs detected in 1992-93 continue to exceed 303( d) listing criteria, 2) assess appropriateness of applying EPA human health criter ia to the Walla Walla River, and 3) provide data to the Washington Department of Health (WDOH) for a human health assessment. As noted previously, this analysis was limited to resident mainstem species, with upper river fish being analyzed separately from lower river fish us ing the Touchet River-Dry Creek reach as an approximate dividing line (Figure 6). The resident species most frequently consumed from the Walla Walla River are smallmouth bass ( Micropterus dolomieu ), channel catfish ( Ictalurus

punctatus ), and carp ( Cyprinus carpio ). The fish tissue collection for the TMDL focused on these species. Some segments of the local population consume almost a ny fish they catch, therefore two other commonly encountered species, bridgelip suckers ( Catostomus columbianus ) and northern pike minnow ( Ptychocheilus oregonensis ; formerly known as northern squawfish) were
also collected.Page 22 Walla Walla River Chlorinated Pesticid es and PCBs Total Maximum Daily Load Submittal Report Figure 7. Location of fish samples.

Data on pesticides, PCBs, and other contaminants in migratory fish species that inhabit the Walla
Walla River can be found in EPA’s Columbia River Basin Fish Contaminant Survey, 1996-1998 (2002b) or online at http://yosemite.epa.gov/r10/oea.nsf . The Touchet and nearby Dry Creek transport most of the sediment load discha rged from the basin. Inputs of sediments and
associated contaminants from these two tributarie s, as well as Pine Creek , have the potential to result in substantially different water quality c onditions in the lower rive r. Therefore, separate specimens for chemical analysis were obtaine d from the upper and lower river, using the Touchet River-Dry Creek reach as an approximate dividing line (see Figure 6). Samples close to
the confluence with the Columbia River were avoide d in an effort to obtain data representative of the Walla Walla River. The fish samples were co llected in July and Se ptember 2002. Fillets were analyzed for 303(d) listed pesticides, PCBs (Aroclor-equivalents), and percent lipids.

Composite samples were used to obtain a co st efficient estimate of mean chemical concentrations. The target sample size was 20 fish of each species from each location, to be analyzed in composites of five fish each. At th e request of the Confed erated Tribes of the
Umatilla Indian Reservations (CTUIR), several whole fish composites were included in the analysis.Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load: Page 23 Submittal Report Data Analysis

Historical application of chlorina ted pesticides to soils and crops is the primary source of these chemicals in rivers and streams in agricultura l areas like the Walla Walla basin (e.g., Risebrough and Jarman, 1984; Munn and Gruber, 1997). This re servoir of contamination is supplemented by current-day atmospheric deposition (e.g., Wa nia and Mackay, 1996). Once applied or air deposited, chlorinated pesticides bind to soil particles. The chief means to meeting pesticide
standards in the Walla Walla River and its trib utaries is to reduce th e amount of soil entering
these water bodies and maintain low TSS levels in the water column.

For chemical concentrations measured in the SP MD samples, pesticide concentrations in the Walla Walla drainage generally decreased in the following order: t-DDT (t = total) > t-chlordane > dieldrin >hexachlorobenzene > heptachlor epoxide. Toxaphene and PCBs were quantified less consistently than these other compounds, and co ncentrations were more variable. Upper Mill Creek and the upper Walla Walla River at the stat e line had the lowest concentrations of both pesticides and PCBs. The Touchet River also ha d a consistently low level of contamination
relative to the Walla Walla River and other tr ibutaries. On average, the highest t-DDT, tchlordane, and dieldrin concentrations we re found in Yellowhawk Creek, 3.7, 2.7, and 3.8 ng/L, respectively. Maximum t-DDT and dieldrin concen trations of 6.5 and 12 ng/ L (parts per trillion)
were recorded here. The maximum t-chlordane c oncentration however was in Garrison Creek at 6.4 ng/L. Dry Creek had the highest concentra tions of hexachlorobenzene and heptachlor epoxide, averaging 1.5 and 0.6 ng/L. Large amounts of toxaphene were detected in Pine Creek, where concentrations up to approximately 40 ng/L were found. Creeks in the urbanized Mill Creek watershed had higher PCB concentrations than those that drained farming areas. The maximum t-PCB concentrations, 0.77 – 9.2 ng/L, we re measured in Garrison Creek. Lower Mill
Creek and Yellowhawk Creek had the second hi ghest PCB levels, 0.54 – 1.1 ng/L for the two monitoring periods where PCBs were detected in these streams.

Regarding the fish tissue sampling, DDT compounds were present in the highest concentrations in the fillets, followed by PCBs/toxaphene, t-ch lordane, dieldrin, hexachlorobenzene, and heptachlor epoxide, in that orde r. The relative amounts of thes e compounds generally mirrored
what was found in the mainstem water colum n. The similar chemical profile among species suggests a common exposure history indicative of water quality conditions in the Walla Walla River. Average concentrations of t-DDT ranged from 30 – 657 ug/Kg (parts per billion). T-PCB and toxaphene concentrations averaged 8.9 – 238 ug/Kg and 16 – 56 ug/Kg, respectively. For most species, the average t-DDT concentrations were 105 ug/Kg or less, and the average PCB concentrations 48 ug/Kg or less. Total chlo rdane concentrations averaged 2.7 – 19 ug/Kg. Dieldrin, hexachlorobenzene, a nd heptachlor epoxide concentrati ons were 2.1ug/Kg or less. The highest pesticide/PCB concentrations were in ca rp, while the lowest were in smallmouth bass.
Pesticide and PCB concentrations in whole sucker s and pike minnow were typically two to three times higher than the average concentration found in fillets. For bass, the whole fish sample was five to ten times higher than fillets. This is usua lly interpreted as reflecting the higher lipid (fat) content in whole fish as chlorinated organic compounds are preferentially soluble in lipid.

The only compounds consistently detected in WWT P effluents were DDE, chlordane, and PCBs. Concentrations ranged from <0.066 – 0.11 ng/L for DDE, <0.066 – 0.20 ng/L for chlordane, and 0.53 – 2.5 ng/L for t-PCBs. Dieldrin was also detect ed in one or two samples from each plant at concentrations of 0.21 – 0.25 ng/L. The higher PCB and chlordane levels were found in CollegePage 24 Walla Walla River Chlorinated Pesticid es and PCBs Total Maximum Daily Load Submittal Report Place effluent. Only PCBs were detected consiste ntly in both plants, and the levels were not significantly different. DDE and diel drin concentrations were sim ilar in each effluent. Without further dilution, the average t-PCB concentration in the College Place and Walla Walla effluents
would exceed the human health criterion of 0.17 ng/L by factors of approximately 7 and 5, respectively. The 0.14 ng/L dieldrin criterion was slightly exceeded at bo th plants, but by less
than a factor of 2. Effluent con centrations of DDE, chlordane, a nd the other pesticides analyzed were always within human health criteria. For a full descripti on of the results of Ecology’s TMDL evaluation, refer to the TMDL technical report (Appendix A).

The National Research Council (2001) has suggest ed using statistical regression of a water quality indicator on one or more predictor variab les as a simple and useful model for developing TMDLs. This study was able to correlate total DDT with TSS and set instream targets for TSS
reduction to meet DDT criteria fo r aquatic life. TSS was, in turn, linked to the state turbidity standard and to fish habitat requirements. In th e present study, pesticide, TSS, and turbidity data were obtained on 88 water samples from the Walla Walla drainage. These data were examined to determine how pesticide concentrations vary wi th TSS and turbidity. The analysis focused on 4,4’-DDE (a product of DDT breakdown) since this was the compound most consistently quantified in the samples. Other pesticides of co ncern are generally presen t at lower levels than
DDE and exceed the limits of their criteria to a lesser degree. There was a strong positive
correlation between DDE and TSS concentrations in all parts of the watershed. Land use changes directed at meeting DDE based ta rget would also effectively a ddress other problem pesticides identified in this report. However, because DDE occurs in association with its parent compound 4,4’-DDT and co-metabolite 4,4’-DDD, the target must be adjusted to account for the total amount of DDT compounds in the water column. The SPMD data show that the relative amounts of DDT, DDE, and DDD in the Walla Walla mainst em and tributaries are fairly constant, with DDE accounting for 50 ± 4 percent of the t-DDT (Figure 28). Therefore the DDE-based TSS target of 100 mg/L should be redu ced to 50 mg/L to meet a t-DDT criterion (divide by a factor of 2). Additivity is appropriate since these compounds have the same or similar criteria and the same toxic endpoints and modes of action.

All four samples from the East Little Walla Wa lla River exceeded the DDE criterion at TSS concentrations between 6 - 38 mg/L (1 mg/L = 1 part/million), much lower than in other samples. DDT compounds, dieldrin, and heptachlor epoxide were al l unusually high in the East Little Walla Walla, based on grab samples. DDE c oncentrations in Yellowhawk Creek were at or
close to the criterion at TSS c oncentrations of 18 – 29 mg/L. Yellowhawk also had the highest t(total)-DDT, t-chlordane, and dieldrin concentrations in the SPMD samples. These results suggest DDT and other chlorinated pesticides we re applied in these tw o watersheds at higher rates or for a longer period of time than elsewher e in the drainage. Since the other pesticides of concern are generally present at lower levels than DDE and exceed their criteria to a lesser degree, land use changes directed at meeting a DDE-based target would also effectively address
these chemicals.

Turbidity is easier to monitor than TSS and becau se state standards for turbidity already exist, turbidity was selected as a surroga te measure of TSS where sampling both TSS and turbidity is not practical (Johnson, pers comm ., 2005). The turbidity criteria ar e based on the relative change above background. For Class A waters (Chapter 173-201A-030-2 WAC): “Turbidity shall notWalla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load: Page 25 Submittal Report exceed 5 NTU 1 over background turbidity when the backgr ound turbidity is 50 NTU or less, or have more than a 10 percent increase in turb idity when the background is more than 50 NTU.” For this TMDL background, turbidity for the Walla Walla River was based on turbidity
measurements taken at the state line and for Yellowhawk Creek background was based on measurement taken from Mill Creek at Seven Mile Road. State water quality standards allow that it may be necessary to use background conditions of a neighboring or similar watershed as the reference condition. Also turbidity at these sites was low most of the year during the 2002-2003 TMDL evaluation; therefore, it was reasonable to use these data.

The criteria do not set a maximum acceptabl e turbidity level based on beneficial use considerations, but they do limit th e effect of an identified source on raising the turbidity in the receiving water.

Background conditions are further defined in Washingt on’s water quality standards as “. . . the biological, chemical, and physical conditions of th e water body, outside the area of influence of the discharge under consideration” except in headwaters where “. . . it may be necessary to use the background conditions of a neighboring or sim ilar watershed . . .” (Chapter 173-201A-020 WAC).

There is no long-term record on ba ckground turbidities in the Walla Walla River that can be used for a comparison to standards. The historical TSS data indicate that violations of the Class A turbidity standard are routine in the lower rive r. The turbidity data obt ained for the upper and lower Walla Walla River in the present study were compared to the turbidity equivalent to a 5 NTU increase over the upper river. These results show that the river was in violation of 5 NTU allowable increase during most of the winter and spring of 2002-2003 (65 percent of samples). In light of chronic violations of the turbidity standard and the li nk between turbidity and TSS, a regression equation was developed for these two parameters in the Walla Walla drainage. The resulting equation was Turbidity = 0.80 x TSS 0.87 (R 2 = 0.92). This equation was used to calculate turbidity levels that corresponded to the TSS targets for t-DDT.

Because of the difficulty in measuring low levels of PCBs in surface waters, TSS and turbidity targets could not be derived specifically for PCBs in the Walla Walla River and its tributaries. However, PCBs, like chlorinated pesticides, have a strong affinity for soil particles, so it is thought that meeting the TSS/turbidity targets in the Walla Walla drainage will also reduce PCB
concentrations in the river and its tributaries. The water quality targets proposed for pesticides would also hopefully result in the state human h ealth criterion for PCBs being met. For further details, please refer to the TM DL technical report (see Appendix A). The concentration of PCBs
detected in the effluent of the Walla Walla and College Place WWTPs exceeded human health criteria (see Applicable Criteria ) and therefore Garrison Creek and Mill Creek were assigned specific wasteload and load allocations for PCBs . These are discussed fu rther in the wasteload
and load allocation section of this document.

1 nephelometric turbidity unitsPage 26 Walla Walla River Chlorinated Pesticid es and PCBs Total Maximum Daily Load Submittal Report 

# Loading Capacity

Loading capacity is the maximum amount of a pollutant that can be delivered to a water body and still achieve water quality standards. Lo ading capacity can be calculated by multiplying streamflow by the pollutant wa ter quality standard. EPA r ecommends using the long-term harmonic mean flow for carcinogens, since the a dverse impacts are realiz ed over a lifetime of exposure (EPA, 1991). The harmonic mean is preferab le to the arithmetic mean (the ‘average’) for analysis of sets of numbers which are define d in relation to some unit, for example, speed (distance per unit time). The arithmetic mean ove rstates the amount of d ilution available over the long-term, and it is long-term fish consumption that is ultimately of most importance in meeting human health criteria. The harmonic mean is always less than the arithmetic mean.
The harmonic mean is calculated by dividing the number of values by the sum of the reciprocal
of each value

. For most rivers and streams, the harmoni c mean is one-to- three times the 7-day, 10-year low-flow (EPA, 1991).

As an example, loading capacitie s were calculated for the Walla Walla mainstem using the
harmonic mean. Table 4 shows estimates of th e Walla Walla River’s loading capacity for chlorinated pesticides and PCBs , based on the harmonic mean calculated from the flow record for the lower river (USGS gage near Touchet, 1951 – 2002). The loading capacity for chlorinated pesticides ranges from 0.012 – 0.070 grams/day (1 gram = 0.035 ounces). For PCBs, the loading capacity is 0.014 grams/day.

Table 4. Loading Capacity for Chlorinated Pesticides and PCBs in the Lower Walla Walla River (@ 34 cubic feet per second- harmonic mean flow).

Chemical Human Health Water Quality Criteria (ng/L) Loading Capacity (grams/day)

4,4'-DDT 0.59 0.049
4,4'-DDE 0.59 0.049
4,4'-DDD 0.83 0.069

t-DDT 0.59* 0.049

Chlordane 0.57 0.047

Dieldrin 0.14 0.012

Hexachlorobenzene 0.75 0.062 Heptachlor Epoxide 0.10 0.008 Toxaphene 0.2** 0.017

Total PCBs 0.17 0.014

* In the Walla Walla DDT, DDE, and DDD are interrelat ed in that DDE and DDD occu r chiefly as a result of the
breakdown of DDT. There are no human health criteri a for t-DDT, but because the individual breakdown compounds have the same modes of action and toxic endpoints in humans, this TMDL applied the DDT and DDE human health criteria of 0.59 ng/L to t-DDT. ** In the case of toxaphene, the chronic freshwater aqua tic life criteria were used instead of the human health criteria as this is the most stringent standard.Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load: Page 27 Submittal Report Loading capacities based on the harmonic mean are appropriate for situations where contaminant concentrations vary inversely with flow, as in the case of discharg e of WWTP effluent to a river. However, in the Walla Walla, the critical season for chlorinated pesticides, PCBs, and TSS is during the winter and spring when flows are elevat ed. Therefore, a different approach is needed to determine the loading capacity for TSS, which is being used as a surrog ate water quality target
in this TMDL

. The 90 th percentile high flow was used to as sess loading capacity for TSS. The remaining ten percent was allocated for natural generation of sediment and turbidity. At the 90 th
percentile, TSS concentrations would be expect ed to exceed loading capacity no more than ten percent of the time. Estimated TSS loads during critical season, 90 th percentile flows were compared to the loading capacity. The loading cap acities at the TSS targets for the Walla Walla
mainstem and the East Walla Walla River and Yellowhawk Creek are shown in Tables 5 and 6 respectively.

Table 5. Loading capacities fo r the Walla Walla mainstem and tribut aries (except for the East Little Walla Walla River and Yellowhawk Creek) at the 50mg/L and 30mg/L TSS targets.

Loading Capacity (lbs/day) Water Body @ 50mg/L TSS Target @ 30 mg/L TSS Target Upper Walla Walla R. 120,000 69,000 Lower Walla Walla R. 450,000 270,000 Garrison Creek 4,320 2,592 West Little Walla Walla 1,566 940 Mill Creek 47,790 28,674 Dry Creek 19,440 11,664 Mud Creek 1,620 972 Pine Creek 16,470 9,882 Touchet River 202,500 121,500 Gardena Creek 2,160 1,296

The data collected in Ecology’s technical evaluation found higher pe sticide concentrations in the
East Little Walla Walla River and Yellowhawk Creeks than in the rest of the Walla Walla drainage. Therefore, more stringent TSS target s are deemed necessary to achieve compliance with state water quality standards (see the load allocation section). TSS reductions down to 5mg/L are deemed necessary to achieve compliance with the toxics criteria.

Table 6. Loading Capacities for the East Little Walla Walla River and Yellowhawk Creek at the 30mg/L, 15mg/L and 5mg/L TSS targets.

Loading Capacity (lbs/day) Water Body @ 30 mg/L TSS Target @ 15 mg/L TSS Target @ 5 mg/L TSS Target East Little Walla Walla 15,000 N/A* 380 Yellowhawk Creek 15,000 7,600 2,500

* The 15 mg/L TSS Target applies only to Yellowhawk Creek and is necessary to achieve compliance with Class A turbidity standards for the Mill Creek drainage.Page 28 Walla Walla River Chlorinated Pesticid es and PCBs Total Maximum Daily Load Submittal Report The load reductions that appear to be needed in the mainstem lo wer river can be summarized in
Table 7 as follows:

Table 7. Recommended load reductions in the mainstem Lower Walla Walla River.

Estimates of Loading Reductions Needed in the Mainstem Lower Walla Walla River To Meet Water Quality Targets and Goals for

TSS

Time
Period @ 50mg/L TSS Target @ 30 mg/L TSS Target @ 5 mg/L
TSS Goal
January - June 74% 84% 97% July - December 0% 20% 86%

Calculations indicate that no lo ad reductions would be needed in Oregon in order for the Walla Walla River to meet either the 50 mg/L or 30 mg/L targets at the state line (see the load allocation section). TSS reductions on the Oregon side would be called for to attain a 5 mg/L goal. Under this goal scenario, very large TSS reductions would be needed basin-wide in both Washington and Oregon.

The Walla Walla and College Place wastewater tr eatment plants (WWTP) were evaluated as sources of chlorinated pesticides, PCBs, and TSS to Mill and Garrison creeks, respectively, where they discharge. The only compounds consiste ntly detected in the final effluents were DDE, chlordane, and PCBs. Without further dilu tion, total PCB concentrations violated the
human health criterion at both facilities. Howe ver, a comparison of loading estimates suggests that the WWTPs represent less than ten percent of the PCB load in the receiving waters and thus are not as important relative to nonpoint sources and background in these watersheds. Regardless these still represent point sources of PCBs; ther efore, it is still necessary to set wasteload
allocations for them in this TMDL. TSS concentr ations in the effluents are limited through their NPDES permits. Discharge monitoring reports on f ile with Ecology show these facilities are not significant TSS sources.Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load: Page 29 Submittal Report 

# Load and Wasteload Allocations

The ultimate goal of this water clean-up plan is the achievement of the human health water quality criteria as shown in Ta ble 8 (with the exception of T oxaphene where the aquatic life criteria are used as they are most stringent). These criteria form the basis for the load and
wasteload allocations to follow and are the focu s of the remedial implementation targets and strategies employed in this TMDL

Table 8. Applicable Washington State Water Quality Criteria* for Chlorinated Pesticides and PCBs (ng/L; parts per trillion) as the basis for the load and wasteload allocations and TSS targets.

Chemical Water and Fish
Consumption

4,4'-DDT 0.59

4,4'-DDE 0.59

4,4'-DDD 0.83

Total DDT** 0.59

Dieldrin 0.14
Heptachlor 0.21
Heptachlor epoxide 0.10

Hexachlorobenzene 0.75

Chlordane 0.57
Toxaphene*** 0.2

PCBs 0.17
*WAC 173-201A-040 (1997 version http://www.ecy.wa.gov/programs/wq/swqs/wac173201a1997.pdf ) EPA promulgated the human health criteria for Washington in 40 CFR 131.36
**In the Walla Walla DDT, DDE, and DDD are interrelated in that DDE and DDD occur chiefly as a
result of the breakdown of DDT. There are no human h ealth criteria for t-DDT, but because the individual breakdown compounds have the same modes of acti on and toxic endpoints in humans, this TMDL applied the DDT and DDE human health criteria of 0.59 ng/L to t-DDT.
*** The freshwater chronic aquatic life criteria are used as they are most stringent.

TSS targets of 50 mg/L and 5mg/L in the Walla Wa lla mainstem and its tributaries, and the East Little Walla Walla and Yellowhawk Creeks resp ectively are set to achieve compliance with Washington State human health criteria. The state's human health criteria for surface waters were issued to Washington by EPA in the National T oxics Rule (40CFR131.36). These criteria are the legally enforceable human health-based criteria used as control targets in TMDLs and other regulatory activities. In addition to the targets based on the human health-based criteria, this TMDL also provides water quality goals based on local fish consumption rates that can be used to inform future pollution control activities in the area. These goals address the higher
risk/hazard that the tribes and other consumers incur as a result of their higher rates of fish consumption.Page 30 Walla Walla River Chlorinated Pesticid es and PCBs Total Maximum Daily Load Submittal Report The secondary TSS target of 30 mg/L is set to achieve compliance with the state Class A turbidity standard in the Walla Walla River, East Little Walla Walla River and Yellowhawk Creek. Using an EPA approved procedure, a turbid ity target of 15 NTU was calculated for the
Walla Walla River downstream of the state line , which equates to a TSS target of 30mg/L.
The load/wasteload allocations established here-i n for TSS/turbidity were designed to control the following parameters: 4,4’-DDT, 4,4’-DDE, Chlordane, Dieldrin, Heptachlorepoxide, Hexachlorobenzene, and Toxaphene.

Load Allocation

Load allocations, which include a margin of safe ty, are the nonpoint source reductions that need to be achieved in each segment of the river for th e loading capacity to be met. In this TMDL evaluation, TSS is proposed as a surrogate measure for chlorinated pesticid es. Equivalent targets are provided for turbid ity. Achieving the TSS/tu rbidity targets should also address the PCB listings in the drainage, with the exception of Yellowhawk, Garrison, and Mill creeks for which separate load allocations are made.

This TMDL evaluation did not attempt to diffe rentiate between TSS loading from nonpoint sources and background TSS in Washington. Theref ore, 100 percent of the TSS loading capacity is allocated to nonpoint TSS sources and bac kground TSS. The load allocation for the lower Walla Walla River for the initial 50 mg/L target is 450,000 pounds per day. Nonpoint and background sources in Oregon contri bute an unknown part of the TSS load to the East Little Walla Walla River, West Little Walla Walla Ri ver, Pine Creek, and Mud Creek via their upper watersheds. The entire TSS loading capacity of the Walla Walla River at the state line is allocated to nonpoint sources and background in Oregon. The river’s load allocation at the state line for the initial 50 mg/L TSS target is 120,000 pounds per day. The TSS target of 50mg/L corresponds to the state’s water quality standard (based on huma n health criteria) for a DDT concentration of 0.59 mg/L. The 30 mg/L target is based on meeting background turbidity for the
water bodies. Table 9 shows the load allocations for the Walla Walla mainstem and its tributaries except for the East Little Walla Walla River and Yellowhawk Creek. Table 10 shows the load
allocations for the East Little Walla Wa lla River and Yellowhawk Creek. Although these allocations will apply year round, Ecology’s technical study has identified January to June as the critical period for compliance. The remedial ac tivities suggested in th is report are focused on achieving compliance during the cr itical season, but they are exp ected to show improvements year round.Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load: Page 31 Submittal Report Table 9. Load allocations for the Walla Walla mainstem and tributaries, except for the East Little Walla
Walla River and Yellowhawk Creek. (Detailed sample site locations are given in the TMDL technical report, see Appendix A.)

Load Allocation (lbs/day)

Location @ 50 mg/L TSS Target @ 30 mg/L TSS Target

Upper Walla Walla R. @ Pe ppers Bridge 120,000 69,000

Lower Walla Walla R. @ Cummins Bridge 450,000 270,000

Garrison Creek 4,320 2,592

West Little Walla Walla 1,566 940

Mill Creek 47,790 28,674

Dry Creek 19,440 11,664

Mud Creek 1,620 972

Pine Creek 16,470 9,882

Touchet River 202,500 121,500

Gardena Creek 2,160 1,296

Table 10. Load allocations for the East Li ttle Walla Walla River and Yellowhawk Creek. (Detailed sample site locations are given in the TMDL technical report, see Appendix A.)

Load Allocation (lbs/day)
Location @ 30 mg/L TSS Target @ 15 mg/L TSS Target @ 5 mg/L TSS Target East Little Walla Walla River 15,000 N/A* 380 Yellowhawk 15,000 7,600 2,500 * The 15mg/L Target applies only to Yellowhawk Creek and is necessary to achiev e compliance with Class A turbidity standards for the Mill Creek drainage.

Washington State’s human health criteria for DDT compounds and other toxins are based on an average lifetime fish consumption rate of 6.5 grams per day. Since it is belie ved that most tribal members consume fish at higher ra tes than the average fish consumer, state standards may not be adequately protective of tribal members and other individuals with high rates of fish consumption. Table 11 shows fish consumption rates for Columbia River Intertribal Fish Commission (CRITFC) member tribes – Umatill a Confederated Tribes, Yakama Nation, Warm Springs Tribe, and Nez Perce Tribe as determin ed in a CRITFC (1994) fish consumption study.

Table 11. Fish Consumption Rates of CRITFC Member Tribes and Approximate Fish Meals per Month.

Population Fish Consumption Rate (g/day) Approximate Fish
Meals Per Month** General Public – average consumer 6.5* 1
Tribal Members – average consumer 63 8
General Public – high consumer 142 19
Tribal Members – high consumer 389 51
* Washington State standard **assuming 8 ounces (roughly 227 grams) per fish meal and 30 days per monthPage 32 Walla Walla River Chlorinated Pesticid es and PCBs Total Maximum Daily Load Submittal Report In order to address tribes’ concerns Ecology decided to add additional TSS goals 2 that could be used in future pollution control activities to addr ess the higher risk/hazard that the tribes and others incur as a result of their higher fish consumption rates. The EPA recently conducted a health risk assessment for peopl e eating fish from the Columbia River basin (EPA, 2002). Using the values the EPA selected in that study, addi tional numerical TSS goals were developed to protect tribal members and members of the genera l public with high rates of fish consumption in the Walla Walla basin. Those seeking further detail on the EPA study and tribal members’ consumption rates should refer to EPA 2002. Table 12 shows the t-DDT concentrations and their corresponding TSS targets and goals.

Table 12. TSS targets/goals and co rresponding t-DDT concentr ations for the protection of average and high fish consumers among the general public and tribal members.

TSS Estimated Water
Column

t-DDT
Concentration Population Subgroup
Addressed

50 mg/L Target 0.59 ng/L State Standard : General Public –
30 mg/L Target 0.44 ng/L State Standard: Turbidity*
5 mg/L Goal** 0.059 ng/L Tribal Members – average fish consumer
2 mg/L Goal** 0.024 ng/L General Public – high fish consumer
1 mg/L Goal** 0.012 ng/L Tribal Members – high fish consumer

* The turbidity target was based on the state turbidity standard for Class A water bodies (Chapter 173- 201A-030-2 WAC).

** These appear as ‘targets’ in Ecology’s TMDL technical report. See footnote below.

Ecology’s Walla Walla TMDL tec hnical study found that monitoring data indicated an additional TSS target needed to be set for meeting the Clas s A turbidity standard in the Walla Walla River. Using an EPA approved procedure for the lower Yakima River TMDL, a turbidity target of 15
NTU was calculated for the Walla Walla River down stream of the state line, which equates to a TSS target of 30mg/L. The 30 mg/L target wa s added to the other T SS targets to ensure compliance with state turbidity standards. For fu rther details on the deri vation of the turbidity target and the regression equation used to cal culate the corresponding TSS target refer to Ecology’s Walla Walla chlorinated pesticides and PCBs TMDL technical study (Appendix A).

As shown, the approach adopted in this TMDL was specifically designed to not only meet the
load allocations that address state toxicity standards, but also to address state turbidity standards. Additional goals are provided in the study that can be used to in form the development of future water quality targets that specifically address high fish consumers in the Walla Walla basin.
Table 13 summarizes the calculated numerical wa ter quality targets and goals for the Walla Walla River drainage - except for the East Li ttle Walla Walla River and Yellowhawk Creek.

2 In Ecology’s Walla Walla chlorinated pesticide and PCBs TM DL technical report, these ‘ goals’ appear as ‘targets’. This report reserves the use of the term ‘target’ for thos e limits derived from State water quality standards. As the more stringent limits are not based on State standards they do not have the same regulatory significance, and are thus referred to as ‘goals’ here. Please see Ecology’s re sponse to the CTUIR’s comments in Appendix H for further
details.Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load: Page 33 Submittal Report Table 13. Water quality targets for the Walla Walla River drainage. (Excluding the East Walla Walla River and Yellowhawk Creek.)

TSS Turbidity Target Effect of Meeting the Target

50 mg/L Target 24 NTU • achieves compliance with human health water quality criteria for chlorinated pesticides

• addresses average fish consumers among the general public

• provides a moderate level of habitat protection 30 mg/L Target 15 NTU • achieves compliance with the Class A turbidity standard

5 mg/L Goal* 3 NTU • addresses average tribal fish consumers

• provides a high level of habitat protection 2 mg/L Goal* 1 NTU • addresses high fish consumer s among the general public 1 mg/L Goal* <1 NTU • addresses high fish consumers among tribal members

* These appear as ‘targets’ in Ecology’s TMDL technical report. See footnote 2 on previous page.
The same approach used for the Walla Walla mainstem was used for the East Walla Walla River and Yellowhawk Creek. However, more stringent TSS/turbidity targets are recommended for the East Walla Walla River and Yellowhawk Creek sp ecifically, because higher concentrations of the chemicals addressed in this report are found he re relative to the rest of the Walla Walla drainage. Therefore, the 50mg/L TSS target employed for the Walla Walla mainstem is deemed not to be protective enough of water quality st andards for these water bodies. The 30 mg/L TSS target is still applicable as it is necessary to ensure protection of st ate turbidity standards. However a more restrictive target is needed fo r Yellowhawk Creek to meet turbidity standards. Present survey data show that turbidity in Yellowh awk Creek should be at or below 8 NTU, which equates to a TSS concentration of 15mg/L.

A TSS 5 mg/L: 3 NTU turbidity target for the Ea st Little Walla Walla River and Yellowhawk Creek should protect average fish consumers among the general public. The data collected indicate that TSS/turbidity leve ls that would addre ss higher rates of fish consumption among the general public and tribal consumers approach ze ro for these two water bodies and so are not proposed as goals at this time. This effort w ould best be initiated after some water quality improvements have been realized, at which point the relationship between TSS, turbidity, and trace-level pesticide contamination may be more easily and accurately discerned. Those seeking
more detail on how NTU and TSS targets were calculated for the East Walla Walla River and Yellowhawk Creek should refer to Ecology’s Walla Walla TMDL technical study (Appendix A). Table 14 shows water quality targets recommended specifically for the East Little Walla Walla
River and Yellowhawk Creek.Page 34 Walla Walla River Chlorinated Pesticid es and PCBs Total Maximum Daily Load Submittal Report Table 14. Water Quality Targets for the Ea st Walla Walla River and Yellowhawk Creek.

TSS Turbidity Target Effect of Meeting the Target

5 mg/L Target 3 NTU • achieves compliance with human health water quality criteria for chlorinated pesticides

• addresses average fish consumers among the general public

• provides a high level of habitat protection

30 mg/L Target 15 NTU • achieves compliance with the Class A turbidity standard (for mainstem Walla Walla)

• provides a moderate level of habitat protection 15 mg/L Target (Yellowhawk Creek) 8 NTU (Yellowhawk Creek) • achieves compliance with the Class A turbidity standard (for Mill Creek drainage)

Goals to protect consumers with high rates of fish consumption among the general public and tribe to be developed at a later date.

In order to meet the water quality standards at issue in this TMDL, it is recommended that the targets be applied to the Walla Walla River and its tributaries at the stat e line and at the mouths of all tributaries to the mainstem in Washingt on. Each tributary is a natural water body with
fisheries and aesthetic resource values deserving of protection, and the targets protect these
values.

A phased approach should be adopted for meetin g the targets, starting with the 30 mg/L:15 NTU target in the East Little Walla Walla Rive r and Yellowhawk Creek and the 50 mg/L:24 NTU target in other parts of the drainage. The 50 mg/L :24 NTU target is overprotective for chlorinated pesticides in the Touchet River. The target retains its value for habitat protection and meeting the turbidity standard nonetheless. For the East Li ttle Walla Walla River and Yellowhawk Creek, the ultimate 5 mg/L:3 NTU target is overprotective for habitat and turbidity, but appears necessary to meet pesticide standards. Init ially, the targets should be applied directly to all irrigation returns and other potential or probable sour ces at the point they enter the mainstem or tributaries. This is the simplest and most equitable approach. The focu s of remedial actions in this TMDL is largely on agricultural lands because firstl y, most land use in the Walla Wa lla Basin is agricultural, and secondly, the chemicals addressed in this TMDL have historica lly been applied primarily in agricultural areas. In addition, it is impractical to set water quality targ ets tailored for each individual return. Monitoring da ta from the tributaries couple d with knowing where BMPs are and are not being implemented can guide later sa mpling efforts for irrigation returns. Once water quality improvements become realized and TSS/tu rbidity targets are prog ressively achieved, it may be appropriate to develop di fferent targets for the returns.

The 2 mg/L:1 NTU and 1 mg/L:<1 NTU goals im ply exceptional water quality conditions and would be difficult to achieve in an agricultura l basin like the Walla Walla. Because they were extrapolated to equate to t-DDT concentrations below the detection limit, there is a substantial amount of uncertainty in their accuracy. Once er osion and TSS levels are reduced, sediments may possibly carry a lower amount of pesticid es and so the goals (based on the current relationship be pesticides and TSS) may have to be reevaluated as shown in the Yakima toxin TMDL. The appropriateness of these values should be re-assessed once the more easily achieved
targets are met.Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load: Page 35 Submittal Report Wasteload Allocation

Wasteload allocations are point source reductions needed in each segment of the river for the loading capacity to be met. This TMDL evalua tion did not attempt to differentiate between TSS loading from point sources, nonpoint sources, an d background in Oregon. No significant TSS point sources to the Walla Walla River and its tr ibutaries are present or anticipated in Oregon. Therefore, wasteload allocations are zero.

No significant point sources of TSS are present or anticipated in the Washington portion of the
Walla Walla watershed. Wasteload allocations are th erefore zero here as well, with the exception of the Walla Walla and College Place WWTPs. National Pollutant Discharge Elimination System (NPDES) permits limit the amount of TSS that can be discharged by the College Place and Walla Walla WWTPs (wastewater treatment plan ts). The current limits state that the average monthly effluent concentrations for TSS “s hall not exceed 15 mg/L or 15 percent of the respective monthly average influent concentratio ns, whichever is more stringent.” Discharge monitoring reports on file with Ecology show that the Walla Walla and College Place WWTPs are insignificant sources of TSS to the receiving waters. Adjustments to the NPDES permits for these WWTPs are not necessary at this time, a nd TSS allocations should be consistent with permit load limits.

Wasteload and load allocations were assigned fo r PCBs in Garrison Creek and Mill Creek in light of the levels detected in the College Place and Walla Walla WWTP effluents. The
wasteload allocations for PCBs identified in this report shall be added to the NPDES permits for the WWTPs of Walla Walla and College Place on ce the TMDL detailed implementation plan (DIP) is completed. Nonpoint sources coming into the WWTPs may be contributing to elevated
PCB levels found in the WWTP effluent. Future remedial actions directed at nonpoint sources may help to alleviate the PCB problem in the WWTP’s discharge. The WWTP wasteload
allocations were calculated as the product of the human health water quality criterion and the NPDES permit limit for the average monthly efflue nt flow. The remaining loading capacity of these streams was allocated to nonpoint sources. (There is no natural background for PCBs.) In addition to Mill and Garrison creeks, Yellowhawk Creek 3 was also found to be impaired for PCBs and was therefore assigned a load alloca tion. However, because no point source has yet been identified in this tributary, no wasteload allocation for PCBs has been assigned. Further monitoring is needed to determine what (if a ny) point sources of PCBs exist on Yellowhawk Creek. If point sources are identified, they should be addressed through future NPDES or stormwater permits. The PCB wasteload and load allocations for Garrison Creek and Mill Creek,
and the load allocation for Yellowhawk Creek are shown in Table 15 below.

3 Yellowhawk was not assigned a PCB allocation in Ecology’ s Walla Walla toxics TMDL technical report as the TSS targets set to address chlorinated pesticides in the dr ainage were originally deemed sufficient to address the non-point PCB problem as well. Howeve r, the EPA expressed concern over this approach as the correlation between TSS and PCBs was weaker than that for chlorinated pes ticides. Therefore Ecology made the decision to assign
additional PCB allocations to all ex ceedances not already covered under t hose for Garrison and Mill Creeks. Evaluation of Ecology’s 2002-2003 sampling data showed that the only remaining PCB exceedance that needed to
be addressed was that for Yellowhawk Creek.Page 36 Walla Walla River Chlorinated Pesticid es and PCBs Total Maximum Daily Load Submittal Report

Table 15 Wasteload and Load allo cations for PCBs in Garrison Creek, Mill Creek, and Yellowhawk Creek.

Wasteload and load allocations for PCBs (gm/day) Garrison
Creek Mill
Creek Yellowhawk
Creek

Wasteload allocation for WWTP 0.0011 0.0062
Load allocation for nonpoint 0.0017 0.023 0.010

Loading capacity 0.0028 0.029 0.010

It is recommended that the Walla Walla and College Place WWTPs work closely with Ecology to develop practical and cost effective manageme nt plans to reduce PCB concentrations in their effluent. These plans should be professionally designed and include a detailed monitoring and management strategy for determining the source s of PCB contaminate in the WWTPs’ service area and identifying possible remedi al actions. In addition, such plans should include detailed WWTP effluent monitoring to assess whethe r implementation is successful. Ecology and representatives of the WWTPs ha ve already held a preliminary meeting to begin to address issues related to the PCB problem and have co mmitted to further meetings following publication of the submittal report. Through consultation with Ec ology, it should be possi ble to set interim wasteload targets and determine an appropriate and cost effective effluent sampling strategy. Ecology will give technical and financial assistance wherever possible, to ensure the remedial strategies are effective in reducing PCB levels in accordance with the wasteload allocations assigned in this TMDL.

It is probable that urban stormwater runoff is an additional contributing source of chlorinated pesticides and PCBs in the basin. Although the sources of PCB impairment in Yellowhawk Creek have as yet not been identi fied, it is possible that stormwater runoff from the city of Walla Walla may be contributing to the problem. B ecause stormwater runoff was not specifically studied in Ecology's chlorinated pesticide and PCB TMDL evaluation study, sufficient data are
not available with which to set allocations fo r stormwater runoff at this time. The detailed implementation plan (DIP) for this TMDL w ill include a monitoring plan that may help
determine future stormwater allo cations, and will identify those co rrective measures necessary to address chlorinated pesticides and PCBs in storm water. Until data are available, Walla Walla County, Columbia County, and the cities of Walla Walla and Co llege Place, should develop and implement programmatic activities to control sedime nt concentrations in th eir stormwater runoff. Specifically, it is recommended they adopt ordinances or other regulatory mechanisms to require
stormwater runoff controls at construction sites and post-constr uction stormwater controls for development projects, train staff to review deve lopment site plans and perform site inspections, and adopt an operation and maintenance plan that incorporates practices to reduce suspended solids in runoff from their municipal operations

.

These jurisdictions should refer to the Stormwater Management Manualfor Eastern Washington (2004) and Model Municipal Stormwater Program for Eastern Washington (2003) and review their current stormwater management ordinances and municipal practices to determine whether they are adequately protective of surface water quality (see Appendix C and D). Where enhanced stormwater quality management needs are iden tified, specific recommenda tions will be provided by Ecology. These jurisdictions must also carry out any legally manda ted responsibilities with regard to stormwater management, including ad herence to the requirements of any future
NPDES Permits issued to them. Moreove r, they may possibly be required to seek coverage under the Eastern Washington Phase II NPDES Perm it for Municipal Stormwater Discharges.Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load: Page 37 Submittal Report Stormwater permit holders should be in complian ce with applicable quality assurance project plan (QAPP) as part of such compliance. Fu rthermore the permit holders may be required to submit a TMDL summary implementation report de tailing the status and actions taken by the permit holder to implement the TMDL. 

# Margin of Safety

A margin of safety is required in a TMDL to account for uncertainty in understanding the relationship between pollutant discharges and water quality impacts. This TMDL evaluation incorporates several proce dures and assumptions that confer a safety margin.

• Two methods were used to derive the T SS concentration on which the water quality targets were based, thereby increasing confid ence in the appropriate ness of the targets.

• The additive effects from the combined concentrations of DDT, DDE, and DDD were accounted for by basing the water quality targets on t-DDT. Basing targets on t-DDT rather than DDE, DDE, and DDT individually is more protective of water quality than
what strict adherence to the individual criteria calls for.

• Although it was not feasible to set PCB allocatio ns for all tributaries, a loading capacity
for PCBs in the Walla Walla River was based on a conservative assumption for calculating flow (harmonic mean). The harmoni c mean is preferable to the arithmetic
mean here as the arithmetic mean overstate s the amount of diluti on available over the long-term, and it is long-term fish consumption that is ultimately of most importance in meeting human health criteria.

• A watershed drainage area approach to lo ad and wasteload allocation should be protective of individual tributaries.

• A t-DDT target provides a wider margin of sa fety for other chlorinated pesticides, since these are generally present at lower concentrations relative to criteria.

• Ecology’s TMDL evaluation found the levels of chlorinated pesticides, PCBs, and total suspended solids in the Walla Walla River ar e highest during winter and spring when the runoff is highest. Therefore, the loading capacity was calculated based on flows during this period, rather than the pe riod of lowest flow as is of ten the case. In this way, the loading capacity set in this report should be most protective of water quality in the drainage.

• The 90 th percentile statistic was used in developing the turbidity target and assessing loading capacity. This approach implicitly al locates ten percent of the load to natural generation of suspended sediment and turbidity.

• The recommended approach of applying the wate r quality targets directly to tributaries and drains gives a wider margin of safety than requiring only the minimal water quality improvements needed to meet standards in the mainstem.

• A phased approach for implementing the ta rgets/goals is pro posed; the ultimate targets/goals are conservative.Page 38 Walla Walla River Chlorinated Pesticid es and PCBs Total Maximum Daily Load Submittal Report Several sources of uncertainty could not be reso lved with the information currently available.

• Because of difficulties in analyzing trace amoun ts of PCBs in surface water and a lack of information on sources, it is uncertain exactly how the decrease in PCB concentrations will track with the proposed water quality targ ets and at what point in the cleanup process
standards will be achieved.

• As already described, there is uncertainty in the accuracy of the 2 mg/L:1 NTU and 1 mg/L:<1 NTU water quality goals, and the ap propriateness of these values should be reassessed once the more easily achieved targets are met.

• Because estimated toxaphene concentrations exceeded t-DDT levels in Pine Creek, meeting water quality targets for TSS in this creek may not result in toxaphene meeting standards. Source investigation is recommended.

Finally, this study did not inves tigate the bottom sediments in the Columbia River backwater formed in the lower ten miles of the Walla Walla River by McNary Dam. This area is a likely sink for chlorinated pesticides and PCBs associ ated with particulates transported by the Walla Walla River and a potential source of contamination to fish. Sediment recovery will occur as upstream water quality targets are met, but the time for recovery is unknown.Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load: Page 39 Submittal Report 

# Summary Implementation Strategy

Introduction

A summary implementation strate gy (SIS) is needed to meet the requirements of a TMDL submittal for approval as outlined in the 1997 Memorandum of Agreement between the U.S. Environmental Protection Agency and the Washi ngton State Department of Ecology. Its purpose is to present a clear, concise, and sequential concept of how th e waters covered in the TMDL will achieve water quality standards. The SIS in cludes an outline of how a more detailed implementation plan will be developed, those implementation activities that are planned or already underway, a strategy for developing foll ow-up monitoring plans, a summary of public involvement methods, and potential funding needs and sources to make implementation of the plan a reality.

A TMDL advisory group was formed in early 2005 to guide the development of this report. At the time of writing this report, groups currently represented in the advisory group include: the Walla Walla County Watershed Planning Depart ment, Walla Walla WRIA 32 Planning Unit, Gardena Farms Irrigation District; Walla Walla Watershed Alliance; Whitman College; Walla Walla Community College; Walla Walla County Planning Commission; th e Walla Walla County Health Department; Confederated Tribes of the Umatilla Indian Reservations ; Kooskoskie Commons; Washington State University Cooperative Extension program; city of College Place; and city of Walla Walla. The rest of the adviso ry group is made up of local private landowners representing a variety of inte rests from across the basin.

There are several other important organizations working in th e Walla Walla region that are currently not servi ng on the advisory group but their assistan ce in the development of this TMDL is appreciated. These groups in clude Washington Department of Fish and Wildlife, Walla Walla County Conservation District, Columbia Cons ervation District, and the Natural Resource
Conservation Service. Efforts have been made to encourage representatives of these groups to serve at future advisory group meetings. In addition, representatives from the Oregon Department of Environmental Quality and th e Oregon based Walla Walla Watershed Basin Council have been contacted and encouraged to a ttend future advisory gro up meetings to foster
cross-border relations and to ensure coordination of implementation activities across administrative boundaries. It is proposed that repr esentatives from these groups will not serve as official advisory group members because of juri sdictional conflicts. There is currently a high level of cooperation and communication betw een advisory group part icipants, and their continued participation in the TMDL process an d assistance in later implementation phases of the project is appreciated.

Implementation Overview

The strategy to implement the TMDL is based upon the continuation of the many existing efforts already underway throughout the watershed to reduce suspended sediment in project area waterways. Point sources will be addressed by ad herence to discharge limits set in Ecology’s NPDES permits. The nonpoint sources (load alloca tions) will be addressed by the use of BMPs and education. The principal focus of the TMDL will be to continue the implementation of seasonal and year-round BMPs to prevent the entry of sediment in to area water bodies.Page 40 Walla Walla River Chlorinated Pesticid es and PCBs Total Maximum Daily Load Submittal Report Additionally, continued monitoring of implementation activities and water quality is essential in assessing the progress of the TMDL.

The goal of this TMDL is to reduce chlorinated pesticides and PCBs in the Walla Walla River
and its tributaries so that levels meet wate r quality standards. Tabl e 16 shows the recommended interim and final timelines for the achievement of water quality targets/goals set in this report. The timelines shown are meant to represent numbe r of years after completion of the detailed implementation plan (DIP).

Table 16. Timelines for the achievement of in terim targets and state water quality standards

Walla Walla River Mainstem East Walla Walla and Yellowhawk Number of Years
from end of DIP TSS Target/Goal Turbidity Target/Goal TSS Target Turbidity Target

5 50mg/L 24 NTU 30mg/L 15 NTU 10 30mg/L 15 NTU 15mg/L 8 NTU 15 5mg/L 3 NTU 5mg/L 3 NTU 20 2mg/L-1mg/L 1 to < 1 NTU <5mg/L: developed later

A detailed implementation plan (DIP) will be pr epared within a year following EPA’s approval of the TMDL submittal report. Ecology will work closely with the TMDL Advisory Group, and other local entities to implem ent the TMDL and develop the DIP. The DIP will identify specifically how, when, and where voluntary re storation activities wi ll be implemented. A detailed monitoring plan will also be developed. Ecology and other entities will provide technical assistance and seek additional funding for th ese restoration activiti es and monitoring.

Implementation Activities

This report acknowledges and is appreciative of th e many federal, state, local governmental, and non-governmental agencies that have alrea dy sponsored or implemented a variety of conservation activities that may have helped to pa rtially alleviate the toxi n problem addressed in this TMDL. However, the results of Ecology’s TM DL evaluation indicate that further action is needed if state water quality standards are to be met. To this end, it is necessary to identify
available resources and devise future implementation actions. Al so, an effectiveness monitoring strategy needs to be planned as a key component of an adaptive management process essential to
a successful TMDL. This section will discuss these issues in detail.

As stated earlier, Ecology’s TMDL evaluation of chlorinated pesticides and PCBs in the Walla
Walla River concluded that a reduction of total suspended solids (TSS) in the water column was the chief means to meeting water quality targ ets for these chemicals. A recent report by Economic and Engineering Services, Inc.(EES, 2003) identified a number of sources of sediment including road-building and loggi ng activities in the uppe r reaches of tribut aries, recreational vehicle use, and urban runoff. They conclude d, however, that “given the predominance of agricultural land use in the watershed, agricultural practices have been identified as the principal source of fine sediment,” a conclusi on supported by Ecology’s TMDL evaluation.Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load: Page 41 Submittal Report The preliminary draft of the Walla Walla Wate rshed Plan, January 2005 (Appendix B) shows a table of voluntary Watershed Planning manageme nt actions. Many of these actions would serve
to reduce the TSS levels of toxi ns addressed in this TMDL and are reproduced here (Table 17). As stated in the Walla Walla Watershed Plan, no organization or person is required to take on a commitment without their consent. However, once an organization has formally agreed to implement actions identified in the plan, it is expected these commitments be honored; recognizing funding limitations. The watershed plan does not create any obligations for private businesses, citizens or landowners. However, ther e are actions identified for voluntary action in the private sector. Al though the Watershed Planning and TM DL processes are fundamentally different, Ecology has and will continue to seek opportunities for collaboration and cooperation between the two processes. It should be noted that Ecology is required under the federal Clean
Water Act to conduct TMDLs and ensure clean water.

Table 17. Summary of ma nagement goals for the Walla Walla chlo rinated pesticides and PCBs TMDL.

Management Category Project Type

1. Prevent/Mitigate Forest Practices Impacts
Activities on forested lands can have significant impacts on water quality, particularly as they relate to forest practices, soil erosion and water temperature. Protection of forested headwater drainages is critical as a source of high quality water for downstream reaches, which support a variety of beneficial uses 1a. Improve Forest Road/Trail Management • Management of forest roads

• Design of forest roads/culverts

• Construction practices for forest roads

• Erosion control for forest roads

• Decommissioning of forest roads/trails

• Road fill evaluation

• Road density evaluation 1b. Improve timber Harvest Management • Evaluation of unstable slopes

• Timber harvest management plans

• Road and timber harvest buffers

• Restoration of riparian recreation areas

• Soil compaction mitigation

1c. Other Watershed Actions • Watershed assessments

• Coordinated resource management plans

• Water quality monitoring

2. Prevent/Mitigate Agricultural Impacts
Nonpoint chlorinated pesticide and PCB sources are varied in the Walla Walla, but are primarily related to historically applied agricultural chemicals. Ongoing efforts by the Washington State Dept. of Ecology working with the Conservation Districts, NRCS, Irrigation Districts, and local water users to reduce nonpoint source impacts ar e already successfully addr essing some of these problems.
2a. Improve Irrigation Water Management • Irrigation district system improvement

• Irrigation scheduling and management

• On-farm irrigation system Upgrades/conversion

• On-farm sediment ponds

• Off-farm sediment ponds 2b. Improve Cropland Management • In-furrow residue placement

• Row crop erosion control

• Tillage managementPage 42 Walla Walla River Chlorinated Pesticid es and PCBs Total Maximum Daily Load Submittal Report Management Category Project Type 2c. Reduce Impacts of Agricultural Chemicals • Pesticide application training

• Pesticide licensing programs

• Row crop soil erosion controls

• Irrigation water management

• Deep percolation evaluations 2d. Address Livestock Impacts • Maintain Technical/Financial Support to Confined Animal Feeding Operations (CAFO); NPDES Permitting of CAFOS

• Voluntary fencing of streams and buffer strips near streams

• Small landowner assistance programs

• Application of public land grazing

programs

• Manure management

• Support conservation district efforts regarding dairies 2e. Control Other Agricultural Impacts • Roadside spraying evaluations

• Aquatic weed control evaluations

• Silt removal from canals/laterals

• Canal weed control impacts

• Pesticide residue monitoring in aquatic
life

• Agricultural soil monitoring for pesticides

• Educational and assistance programs for
small farm/ranches

• Educational tours/demonstrations for commercial growers

• Consider water quality impacts in routine operations and maintenance of irrigation
canals

3. Prevent/Mitigate Stormwater Impacts
Stormwater runoff from developed and urban areas and industrial sites contains pollutants that impact receiving waters. State and regional guidelines exist (e.g., Eastern Washington’s Stormwater Guidelines) to identify appropriate stormwater management practices. Stormwater ordinances have been adopted by county governments and other municipalities in the Walla Walla
River Basin. 3a. Plan/Implement Municipal Stormwater
Runoff Controls • Municipal stormwater ordinances

• Regional stormwater runoff control guidelines

• Municipal stormwater control plans

• Regional stormwater impact assessments

• Urban/suburban land use awareness programs transportation/de-icing guidelines 3b. Plan/Implement Industrial Stormwater
Runoff Control • Industrial stormwater ordinances

• Regional industrial stormwater guidelines

• Industrial stormwater control plans

• Regional stormwater impact assessmentsWalla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load: Page 43 Submittal Report Most forestry operations are likely to occur on lands on the Oregon side of the Walla Walla drainage as most forestry lands in the basin are located there. These are beyond the jurisdiction of the Washington State Department of Ecol ogy. Ecology’s TMDL evaluation concluded that activities on the Oregon side of the border were relatively mi nor contributors to the toxin problem in the Walla Wall basin. However, it ma y still be necessary to address these Oregon sources in order to meet the most stringent TMDL water quality targets/go als. It is anticipated that existing programs under the state’s forest and fish regulations, DNR’s Habitat Conservation Plan (HCP), and the federal government’s Nort hwest Forest Plan will provide the regulatory framework needed in this regard.

There has been considerable attention in recent years to reducing wate r quality impacts from agriculture on the region's waterways. Existi ng permit programs and voluntary measures to address water quality concerns should continue to be used. Advisory agencies such as the Washington State University (WSU) Coope rative Extension, the Walla Walla County Conservation District, and the Columbia Conserva tion District are availa ble to offer technical
and financial assistance with landowners’ efforts. The Walla Walla Watershed Plan suggests that total sediment loading can be reduced by 85 percent by using no-till practices instead of historical cropping practices involvi ng significant tillage operations . In recent years, irrigators have made great strides towards reduced susp ended sediment and pesticide levels in area waterbodies, and will continue to implement best management practic es (BMPs) in these areas to meet TMDL targets. This plan recommends th at planning decisions be focused toward land practices that decrease su sceptibility to erosion.

Because stormwater runoff was not specifically studied in Ecology's chlorinated pesticide and PCB TMDL evaluation study, sufficien t data are not available with which to set allocations for
stormwater runoff at this time. Until data are available, Walla Walla County, Columbia County, and the cities of Walla Walla and College Place must carry out any legally mandated responsibilities with rega rd to stormwater management, including adherence to the requirements of any future NPDES permits issued to them. These jurisdictions should refer to the Stormwater Management Manual for Eastern Washington (2004) and Model Municipal Stormwater Program for Eastern Washington (2003) and review their stormwat er management ordinances and municipal practices to determine whether they ar e adequately protective of surface water quality (see Appendix C and D respectively). Where e nhanced stormwater quality management needs are identified, specific recommendations will be provided by Ecology, possibly including a requirement to seek coverage under the Ea stern Washington Phase II NPDES Permit for Municipal Stormwater Discharges.

Because urban and suburban household mate rials are potential sources of nonpoint pollution, educational programs focused on the pr oper use and disposal of household hazardous materials
should be advertised and offered to the public. These programs should increase urban and
suburban residents’ awarene ss about how household hazardou s materials should be used and the implications of misuse. Household hazardous materials are herbicid es, pesticides, and cleaning agents, as well as automotive and light i ndustrial fluids that are commonly present in the home or
on a farm.Page 44 Walla Walla River Chlorinated Pesticid es and PCBs Total Maximum Daily Load Submittal Report The following items were identified by the Walla Walla TMDL advisory group which will be looked at during the development of th e Detailed Implementation Plan (DIP):

Several TMDL program implementation topics have emerged that warrant emphasis in the water quality strategy for the TMDL implementation plan. It is the desire of several members of the TMDL Advisory Committee that these site specific issues be discussed in more detail during the Detailed Implementation Plan (DIP) development. Further public input w ill be sought to help prepare this plan. The plan will identify how, when, and where voluntary restoration activities will be implemented.

Actions recommended in the DIP are intended to be specific enough to clearly identify the actions and results; yet general enough to permit some flexibility in carrying them out. It is recognized that some actions will require furthe r investigation prior to full implementation. Additionally it is recogni zed that some actions can be carri ed out only if funding is provided by the State Legislature or other f unding agencies, and that funding decisions will be made over a period of months or years following plan adoption.

The following concepts will be looked at in further detail during the Detailed Implementation Plan development: addressing the correlation be tween TSS and Turbidity to toxins in the Touchet River basin and the Dry Cr eek basin; identifying historic background levels for turbidity in the Walla Walla watershed and various tributaries, including identification of additional sampling sites including soil testing and stream bed sediment loads; identifying additional sampling methods; identification of geographic source differences for toxin contamination including possible atmospheric deposition. As long as TSS con tinues to be the surrogate measure of chlorinated pesticides periodic valid ation of the current fo rmulas should be made.

Many local interests in the Walla Walla Ba sin are involved with TMDL planning and implementation. During the development of the DIP, in areas where soils contributing to turbidity are found to have high levels of pollu tant present, special emphasis on helping to relieve the problem will be employed. Ecology will continue to work closely with these basin
interests to addre ss outstanding issues.

Table 18 lists the possible entities that may use the general implementation actions to meet the targets in this TMDL. The information listed in the table is part of an overall strategy and will likely change as personnel and monetary resource s are better defined during the development of
the DIP.Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load: Page 45 Submittal Report Note: Please refer to the list of acronyms and abbreviations ( Appendix G ) for further assistance
with Table 18.

Table 18. Organization of TMDL entities and their contributions.

Entity Responsibilities to be met

TMDL advisory group Review progress of implementation strategy Ecology Manage the TMDL process, provide guidance and support to other agencies Homeowners with waterfront property Avoid actions that will cause streambank
destabilization or erosion or will otherwise add sediment to area waterways Irrigation Entities (Districts and Companies) Where possible improve irrigation efficiencies, upgrade diversions and, where appropriate, implement BMPs to prev ent entry of suspended sediment into area waterways Irrigators Implement appropriate BMPs to prevent entry of sediment-laden agricultural return flows into
area waterways Columbia Conservation District (CCD) and Walla Walla County Conservation District (WWCCD) and Ecology Continue to fund agricultural BMP implementation: controlling agricultural runoff, reducing suspended sediment in drains and tributaries, preventing streambank
destabilization and erosion.

CCD, WWCCD, WSU Cooperative Extension,
Kooskooskie Commons Extend outreach efforts and technical assistance to agricultural producers (irrigators, livestock managers, othe rs) in the watershed CCD and WWCCD Continue to monitor water quality of the watershed’s surface water (as possible, given funding availability) Walla Walla and Columbia County governments, and Walla Walla, College Place, Waitsburg and Dayton City governments. Administration of stormwater discharge,
Critical Area Ordinances and shoreline master

programs Walla Walla and Columbia County governments and WSDOT Continue to maintain roads and roadside ditches to prevent entr y of sediment into area
waterways

Private and state timber owners Implement forest management practices as required by Forests and Fish rules Ranchers Implement livestoc k management BMPs to prevent streambank destabilization and erosion US Forest Service (USFS) Implement forest management practices as required by the Memorandum of Agreement with Ecology Ecology Review if interim targets have been met after deadlines reached, and if not, devise an alternative action plan Ecology,TMDL advisory group Evaluate if the water quality samples at points of compliance meet the interim and final
targetsPage 46 Walla Walla River Chlorinated Pesticid es and PCBs Total Maximum Daily Load Submittal Report Entity Responsibilities to be met

Ecology, TMDL advisory group. If inte rim target was not met, develop new action plans to meet target Ecology, WWCCD and CCD, TMDL advisory

group Determine changes in monitoring sites, tests, or frequency are needed Ecology, WWCCD, CCD, WSU cooperative extension, Kooskooskie Commons, TMDL advisory group Review program and frequency for accuracy

Ecology, TMDL advisory group Review if final TMDL targets have been met, and if not, identify new timeline and BMPs
needed. Cities, Walla Walla and Columbia county governments, and WSDOT Identify and implement stormwater management plans with any Stormwater Permits issued by the Department of Ecology and/or refer to Ecology’s eastern Washington stormwater manual for guidance on general
stormwater management Walla Walla and College Place WWTPs Monito r and maintain chlorinated pesticides and PCBs wasteload set in NPDES permits and
the TMDL

Reasonable Assurances

The ultimate goal of this TMDL is to meet the ch ronic aquatic toxicity a nd human health criteria for chlorinated pesticides and PCBs. Mainta ining the TMDL goals will be required once compliance has been achieved. Improved water quality will be achieved through the combined
efforts of all basin stakeholders. Local involv ement and commitment to chlorinated pesticide and PCB problems in the Walla Walla River wate rshed are substantial an d are evidenced by the dedication of the people and orga nizations involved in the devel opment of this plan. To support this TMDL, Ecology will work cooperatively w ith all basin stakeholders to promote the implementation of activities contained in this plan.

This water cleanup plan, its TMDL targets, and the associated im plementation activities listed in the plan are not in themselves enforceable. Ho wever, Ecology is oblig ated to implement the approved TMDL. Organizations and their commit ments under laws, rules, and programs to resolve chlorinated pesticide and PCB problem s in the watershed ar e described below.

Washington State Department of Ecology : Ecology has been delega ted authority under the federal Clean Water Act by the U.S. EPA to esta blish water quality standards, administer the NPDES wastewater permitting program, and enfo rce water quality regulations under Chapter 90.48 RCW. Ecology responds to complaints, conduc ts inspections, and issues NPDES permits as part of its responsibilities under state and federal laws and regulati ons. In cooperation with conservation districts, Ecology will pursue impl ementation of BMPs for agricultural and other land uses and may use formal enforcement, including fines, if voluntary compliance is
unsuccessful.Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load: Page 47 Submittal Report The Ecology/Conservation District MOA : Ecology has a Memorandum of Agreement (MOA) with conservation districts, signed in 1988, that allows Ecology to refer agriculture-related water quality complaints to the conservation district s for resolution of th e problems. (However, Ecology will investigate and seek resolution of all complaints th at appear to need immediate action.) Conservation Districts have authority under Chapter 89.08 RCW to develop farm plans to protect water quality and provide animal waste management information, education, and
technical assistance to reside nts on a voluntary basis. When a complaint is referred to a conservation district by Ecology, th e conservation districts will meet with the owner/operator of the property where the violation occurred, assist the owner/operat or in the development of a water quality management plan, pr ovide technical assistance to co mplete the plan and monitor plan implementation, notify Ecology regarding th e owner/operator’s willingness to correct the problem and successful implementation of the wa ter quality management plan, and annually submit to Ecology a formal summary of progres s on referred water quality violations. While Ecology maintains lead enforcemen t responsibility for resolution of the referred complaints, this MOA expedites and streamlines correction of agricultural water quality violations.

The TMDL Advisory Group : A TMDL advisory group was formed to direct and support development of the Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Submittal Report. In such capacity, the advisory group may make suggestions for modifications to the TMDL report. The major ity of members of the advisory group are key community members with interests in compliance, and who promote the success of implementation. The group is a highly functional group and is dedicated to meeting the goals of
the TMDL. State of Oregon DEQ : Since approximately a quarter of th e Walla Walla basin lies in Oregon, the implementation work underway in Oregon has th e potential to positivel y affect water quality in the Washington portion of the river. As is th e case in Washington, the water quality standards program in Oregon is a joint effort between th e Department of Envir onmental Quality (DEQ) and the EPA. DEQ is responsible for developi ng and enforcing water qua lity standards that protect beneficial uses such as drinking wate r, coldwater fisheries, industrial water supply, recreation, and agricultural wate r supply. The EPA develops regulations, policies, and guidance to help Oregon implement the program and to ensure that Oregon's adopted standards are consistent with the requirements of the Clean Water Act and relevant regulations. The EPA has authority to review and approve or disappr ove state standards and, where necessary, to promulgate federal water quality rules. DEQ has the authority and the responsibility to ensure that TMDLs are completed and submitted to EPA. Although no TMDLs are being developed for chlorinated pesticides and PCBs in Oregon, a TMDL is in progress for temperature. It is thought that many of the actions recommended to reduce temperature problems (e .g., riparian restoration and re-vegetation) may also help to reduce sediment loads from soil erosion.

Regulatory Programs : there are a number of local, state, and federal regulatory programs that are already in existence which can be expected to help reduce the chlorinated pesticide and PCB problem in the Walla Walla River and its tributar ies. Local regulatory programs include: land use planning/permitting and its associated program s, including Critical Areas Ordinances and Shoreline Master Programs which are admi nistered by county and city governments

.

State regulatory programs: Discharge permits , including stormwater discharge, impact water quality through management of eros ion and suspended sediment and other pollutants. Ecology recently completed a st ormwater management manual for easternPage 48 Walla Walla River Chlorinated Pesticid es and PCBs Total Maximum Daily Load Submittal Report Washington which is designed to guide local authorities as to how best to meet new stormwater discharge regulations. More spec ifically, Ecology is in the process of developing general stormwater discharge permits for various cities in the Walla Walla basin. When these are finalized, they will help regulate the stormwater component of the chlorinated pesticide and PCB problem. Othe r state regulatory programs include wetland protection programs, the implementation of fo rest practices that minimize water quality impacts under RCW 76.09, the enforcement of Shoreline Management legislation and general environmental review under the SEPA.

Federal regulatory programs: The Safe Dri nking Water Act (SDWA) contains provisions related to surface and groundwater quality incl uding required monitoring of public water systems and requirements for developm ent of Wellhead Protection Plans.

A unique settlement agreement was reached in 2000 between the three largest irrigation districts (Walla Walla River, Hudson's Bay Improvement and Gardena Farms) and the USFWS. This agreement (and its extension si gned in 2001) dictated increased instream
flows to be maintained in the Walla Walla River. These efforts are intended to improve temperature conditions and increase habitat connectivity and may help reduce sediment loads in turn reducing levels of toxins in the water column though this is yet to be determined. A bi-state habitat conservation pl an (HCP) is being developed as a follow up on activity to the settlement agreement, and in cludes other parties such as the city of
Walla Walla

Non-Regulatory Programs : In addition to the regula tory programs in place, there are local, state, and federal non-regulatory programs that may also have beneficial impacts on the chlorinated pesticide and PCB problem. Local non-regulat ory programs include conservation district, Natural Resource Conservation Service (NRCS), and WSU Cooperative Extension Programs designed to reduce erosion and sediment load ing to surface waters, improve water quality monitoring, or vegetate riparian areas. Conservation districts have authority under Chapter 89.08 RCW to develop farm plans to protect water quality and provide animal waste management information, education, and technical assistance to residents on a voluntar y basis. Also, county governments are involved in water quality impr ovements in a variety of programs including, but not limited to, applying for state grants on behalf of landowners.

State non regulatory programs : State management of se veral funding programs is designed to assist various pa rties in improving water qualit y. These programs include the
Centennial Clean Water F und, Washington State Water Po llution Control Fund, Clean Water Act Section 319 Nonpoint Source Fund, a nd participation in Conversation Reserve Enhancement Program (CREP) (state ob ligation ten percent). The Washington Department Fish and Wildlife (WDFW) mana ges the Watershed Recovery Project that involves collecting information about land use practices and wa ter quality within
watersheds. The information is collected in to a usable format to assist watershed managers to prioritize improvements programs. Also there are various forestry easement programs described in the Department of Natural Resources (DNR) Forest Practices Rules (WAC 222).Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load: Page 49 Submittal Report Federal Non-Regulatory Programs: The U.S. Department of Agriculture (USDA) -
Natural Resources Conservation Service (NRCS) and USDA Farm Service Agency (FSA) administers programs such as th e Conservation Reserve Program (CRP), Conservation Reserve Enhancement Program CREP, the Continuous Conservation Reserve Program (CCRP), the Environmenta l Quality Incentives Program (EQIP), the Wildlife Habitat Incentives Program (WHIP), the Grassland Reserve Program (GRP), and the Wetlands Reserve Program (WRP).

Comprehensive Irrigation Dist rict Management Plan (CIDMP) : The executive committee of the Irrigation Districts’ Guideline development proc ess, in collaboration with CTUIR and various other stakeholders, recently completed a manual (C omprehensive Irrigation District Management Plan) that sets up a voluntary and incentive-based process fo r improving irrigation district operations in response to the Endangered Specie s Act and the Clean Water Act. Specifically, the manual describes an innovative and assertive ap proach to water quality problem assessment, monitoring, outreach, BMP implementation, and ad aptive management. Ma ny of the activities outlined in this manual may have potential beneficial impacts on the sediment load and toxin problem in the Walla Walla River.

The United States Forest Service(USFS)/Ecology MOA : In 2000, the USFS – Region 6 and Ecology signed a Memorandum of Agreement (MOA) addressing protection of water quality on federal forest lands in Washington State. As pa rt of the required actions under this MOA, the USFS is actively working to maintain and improve roads that may cause the entry of sediment into area waterways. The USFS has also develope d several programs to restore damaged riparian areas and to educate the public regarding respect fo r rivers and riparian areas. All of these efforts will directly support this TMDL a nd help to ensure its success.

Besides the general assurances listed above, there are a ho st of specific water quality enhancement activities already completed or under way in the Walla Walla basin that are helping to meet TMDL chlorinated pesticide and PCB targets. These activities are summarized in
Table19.

Table 19. Miscellaneous existing projects related to water qu ality improvement in WRIA 32. (Taken from the preliminary draft of the Walla Walla Watershed Plan, January 2005 – see Appendix B.)

Project Lead Agency Duration Comments Couse Creek riparian enhancement (OR) CTUIR (BPA funded) 1996-1998

Stream flow
enhancement WWRID, GFID,HBIC,
USFWS 1999-2002

Upland restoration planning NRCS, WDFW Ongoing

Implementation of conservation tillage Landowners/Conservation
Districts/NRCS/WSU
Extension Ongoing

Installation of other onfarm BMPs Landowners, WWCCD, CCD, NRCS, WSU
Extension Ongoing Included installation of terraces, sediment basins, and vegetated filter strips; enrollment
of landowners in CRP

& CREPPage 50 Walla Walla River Chlorinated Pesticid es and PCBs Total Maximum Daily Load Submittal Report Project Lead Agency Duration Comments Riparian buffer restoration (CREP & others) Landowners, NRCS, CTUIR (BPA funds), FSA
& Conservation Dists. Ongoing Areas like the South
Fork Patit and Blue
Creek Various riparian and
instream restoration projects Landowners, NRCS, and
Tri-state Steelheaders Ongoing

College Place stream
restoration & City of College Place 1998-2001 Along Garrison Creek

Treatment
wetland/WWTP Improvements City of College Place Ongoing

Walla Walla WWTP improvements City of Walla Walla 1999- 2000 Various improvements

Dayton WWTP improvements City of Dayton 1999-2000

Waitsburg WWTP improvements City of Waitsburg 2001-200 1 Various improvements
and new construction

Household hazardous
waste collection Ecology, Landowners, City and County Agencies Ongoing

Livestock removal Landowners, NRCS Ongoing Remove direct stream
access for livestock
and reduce total livestock presence Irrigation efficiency Landowners and City/County Agencies Ongoing

Forest practices Landowners and City/County/State Agencies Ongoing Reduces upland
erosion Increasing industrial
chemical control and accountability Ecology, Landowners, Business, City and County Agencies Ongoing

Adaptive Management

Adaptive management has been defined in state law as “reliance on scientific methods to test the results of actions taken so that the management and related policy can be changed promptly and appropriately” (RCW 79.09.020). It ma y be described as a cycle that occurs in four stages: (i) identification of information needs, (ii) inform ation acquisition and assessment (monitor), (iii) evaluation and decision-making (evaluate), and (iv) management action or response (respond). Oftentimes, the first and fourth stages can be co nsidered as one, since part of the response to newly evaluated data may be to identify new in formation needs. Thus, the key stages of the adaptive management cycle are to “monitor”, “evaluate”, and “respond.” Adaptive management is a continuing attempt to reduce the risk ar ising from the uncertainty associated with information used to develop the management act ions. Generally speaking, each stage of the cycle has an associated uncertainty th at should decrease through each comp leted cycle of the process.

This is one perspective to applying adaptive mana gement. An alternative way to look at adaptive management is to consider it as “experiment al management” wherein the management actions taken are used to test key hypotheses and assump tions used to develop the management actions.
There are subtle differences in application, but concep tually they are similar in that adaptiveWalla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load: Page 51 Submittal Report management attempts to address uncertainty in information. In this TMDL, adaptive management specifically refers to a process wh ereby the advisory group and Ecology devise new implementation strategies in the event that monitoring shows targets are not being met. A feedback loop is implemented consis ting of the followi ng three steps.

Step 1. The water quality improvement plan and associated action items are implemented. Programs and on-site BM Ps are evaluated for technical adequacy of design and installation.

Step 2. The effectiveness of the water quality im provement plan in achieving the goal and objectives is evaluated by comparison to water quality monitoring data. If the goal and objectives are achieved, the implementation efforts are adequate as designed, installed, an d maintained. If not, the plan is modified and objectively reevaluated.

Step 3. Project success and accomplishments s hould be publicized and reported to continue project impl ementation and support.

Where new (not previously identified) source s of suspended sediment bearing chlorinated pesticides and PCBs are discove red, they will be remedied th rough the appropriate jurisdiction. If or when planned implementation activities are not producing expected or required results, Ecology or other entities may c hoose to conduct additional studies to identify the significant sources of toxin input to th e river system. If the causes can be determined, additional implementation measures may be needed. If the shortfall does not have an apparent cause (e.g., everyone is implementing required BMPs and all potential sources have been addressed, but targets are not being met), then more studies may be required. Conversel y, should water quality standards be met prior to achieving the specific target allocat ions outlined here, the purpose of
this TMDL shall be satisfied. Re-evaluation of th e status of this TMDL will be conducted every five years. For non-federal forested areas, the agreements in the forests and fish report incorporate adaptive management as needed to ultimately meet state water quality standards. The USFS also has a policy of adaptive management.

Regular monitoring is essential to ensure succes sful implementation of an adaptive management strategy. The monitoring strategy is discussed in detail below.

Monitoring Strategy

The EPA calls for a monitoring plan for TMDLs where implementation will be phased over time. The monitoring is conducted to provide assurance that the control measures will meet the TMDL targets and achieve water quality standards. Long- term monitoring will be important to ensure
fulfillment of the Walla Walla River TMDL for ch lorinated pesticides and PCBs. Ecology is the lead agency for monitoring the implementation activ ities and will coordinate with the appropriate watershed entities to accomplish these efforts.

A distinction should be made here between implementation monitoring and effectiveness monitoring. Implementation monitoring can begin at any time and is usually more dispersed and on a larger scale than eff ectiveness monitoring. Because the cost of sampling toxin concentrations directly on the scale required in this phase of monitoring will probably be prohibitive, TSS and/or turbidity wi ll be used here as surrogate m easures of toxicity. The goal ofPage 52 Walla Walla River Chlorinated Pesticid es and PCBs Total Maximum Daily Load Submittal Report implementation monitoring is to pinpoint th e most significant sour ces of contamination. Effectiveness monitoring is conducted five years after completion of the detailed implementation plan (DIP) and its primary purpos e is to determine whether implementation activities have been put into effect and whether the water body is in compliance with state wa ter quality standards. Unlike implementation monitoring, effectiveness monitoring typically re quires assessing toxin concentrations directly using SPMDs and fish tissue samples.

A TMDL must include monitoring to measure achievement of target s and water quality standards. NPDES permits require point sources to regularly monitor their discharge effluent. Monitoring data from the Walla Walla and College Place WWTPs will be included with data collected as part of a general monitoring stra tegy for watershed. The goa l of monitoring would be to determine if BMPs are effective in reducing TSS loading to the Walla Walla River and bringing the river into compliance with standa rds. Objectives shoul d include 1) obtaining accurate and representative data on TSS and turb idity in the mainstem Walla Walla River and major tributary sources of TSS, 2) using the data to assess progress toward meeting water quality targets, 3) re-surveying fish a nd the water column to verify th at human health standards for chlorinated pesticides and PCBs are being met, 4) re-assessing the accuracy of the 2 mg/L:1 NTU and 1 mg/L:<1 NTU targets for the mainstem , and 5) developing wate r quality targets to protect high fish consumers in the East Little Walla Walla River and in Yellowhawk Creek.

The Walla Walla Watershed Planning Unit devel oped a sediment model using the SWAT (Soil Water Assessment Tool) model in their efforts to assess the positive impact of alternative agricultural BMPs implemented in the basin (E ES., 2003). The model was used to analyze the
erosion and sediment characteristics of the ba sin as impacted by hist orical and current (or projected) agricultural practices. Both the pl anning unit and Ecology have access to this model and it could be further developed to conduct a basin wide modeling study or to focus on specific drainage areas within the basin. In addition, the model could be used to help evaluate the stream loading associated with other wate r quality parameters individually or as affected by sediments.

Water quality monitoring should begin with colle cting one year of baseline data on TSS and turbidity at the ten sites listed below. Samp ling should be conducted at least twice weekly, similar to what is being done for effectivene ss monitoring in the Yakima TMDL. In order to obtain representative and comparable data, dept h integrating sampling procedures should be
used. Streamflow should be measured.

The following sampling sites are suggested for TMDL effectiveness monitoring:

1. Walla Walla River @ state line

2. Yellowhawk Creek

3. East Little Walla Walla River

4. Garrison Creek
5. Mill Creek

6. Dry Creek

7. Pine Creek

8. Touchet River

9. Gardena Creek

10. Lower Walla Walla River @ Cummins BridgeWalla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load: Page 53 Submittal Report Once BMPs have been implemented, twice-weekly samples would be collected from January through June, the critical period for TSS loading. The pre- and post-data for January-June would be tested for significan t differences and the 90 th percentile values compared to the numerical targets. January-June monitoring would continue on a yearly or less frequent basis, depending on results of the comparisons and pace at which land use changes proceed in the watershed. Monitoring in July-December would be phased in as appropriate to asse ss progress in meeting the more restrictive targets or to acquire more background data.

As the water quality targets for TSS and turb idity are progressively achieved, chlorinated pesticides and PCBs should be an alyzed periodically in resident mainstem fish species and the water column. PCBs should also be analyzed in fish samples from Mill and Garrison creeks. Sample size for fish should be appropriate for ma king a statistical comparis on with criteria used to assess compliance with human health st andards and WDOH should be consulted on the sampling design. Water column sampling and an alysis should employ low-level techniques. Water samples should be focused on the mainstem and include the East Little Walla Walla River and Yellowhawk Creek. TSS and turbidity samples should be collected in conjunction with the pesticide sampling.

A quality assurance project plan (QAPP) should be prepared for whatever monitoring is conducted. The QAPP should follow Ecology guideli nes (Lombard and Kirchmer, 2004) paying particular attention to consistency in sampling and analytical methods.

In addition to the effectiveness monitoring deta iled above, it is recommended that follow-up monitoring work be done to answer key questio ns not answered in the TMDL chlorinated pesticide and PCB evaluation:

• Chlorinated pesticides and P CBs should be analyzed in sediment samples from the
Columbia River backwater in the lower Walla Walla River and an assessment made of potential for uptake of these chemicals by fi sh and of ecological risk. The rate of sediment deposition should be measured and re sults used to predict time to recovery under various cleanup scenarios for the upstream watershed.

• An effort should be made to determine if th ere are remediable PCB sources in the Mill Creek watershed. More intensive sampli ng of Mill and Garrison creeks may help
determine if and where localized sources exis t. Other potential sources in the watershed include agricultural, food processing , chemical, scrap, and waste sites.

• It is recommended that as part of a PCB management strategy the WWTPs of Walla Walla and College Place monitor the output of dischargers in their service areas to determine possible contributors of PCBs to their systems. This strategy should also include WWTP effluent sampling to ascertain whether remedial activities are successful in reducing PCB load. Ecology will provide technical assi stance wherever possible.

• Additional water sampling is required along Yellowhawk Creek in order to identify possible sources of PCBs. The sampling stra tegy will be developed in the Detailed Implementation Plan (DIP). No point sour ces were identified along the Yellowhawk during the TMDL technical study, but if such sources are later identified they will be addressed in NPDES or stormwater permits and monitored regularly to assess compliance with water quality standards.Page 54 Walla Walla River Chlorinated Pesticid es and PCBs Total Maximum Daily Load Submittal Report • The stormwater systems of the cities of Walla Walla and College Place should be sampled for both chlorinated pes ticides and PCBs to ascertai n how much if any these are contributing to the problem - information which can be incorporated in future stormwater discharge permits.

• Sampling should be conducted to locate toxaphene sources in the Pine Creek drainage. Because of the analytical challenges pr esented by toxaphene, some kind of preconcentration technique may be required to obtain useful data.

Funding

Potential funding sources available through Ecology’ s water quality grants program include the Centennial Clean Water Fund, Section 319 grants under the federal Clean Water Act, and the State Revolving Fund (SRF) grants. In addition to Ecology’s funding programs, there are many other funding sources available for watershe d planning and implementation, point and nonpoint source pollution management, fish and wildlife ha bitat enhancement, stream restoration, and education. Public sources of funding include fe deral and state government programs, which can
offer financial as well as t echnical assistance. Private sour ces of funding include private foundations, which most often fund nonprofit organi zations with tax-exempt status. Forming partnerships with othe r government agencies, nonprofit orga nizations, and private businesses can often be the most effective approach to maxi mize funding opportunities. Ecology will work with public entities and local interest groups to prep are appropriate scopes of work, to implement this TMDL, and to assist with applying fo r grant opportunities as they arise.

The NRCS directs its Environmental Quality Incentives Program (EQIP). EQIP provides technical, educational, and financ ial assistance to eligible farmer s and ranchers to address soil, water, and related natural resour ce concerns on their lands in an environmentally beneficial and cost-effective manner. The program is implem ented through conservati on plans that include structural, vegetative, and land management prac tices. Contracts are five to ten years long. The
USDA FSA administers the Conservation Re serve Enhancement Program (CREP) and Conservation Reserve Program (CRP), both of which the NRCS has technical responsibility over. These are both voluntary cost share progra ms designed to restore and enhance habitat and increase bank stability along waterways on privat e lands. A cropping history is needed to be eligible for CRP but not for CREP. Marginal past ure lands are also elig ible. The NRCS provides technical and financial assistance to eligible fa rmers and ranchers to address soil, water, and
related natural resource concerns on their lands in an environm entally beneficial and costeffective manner. These programs offer payments fo r annual rental, signing, cost share, practice, and maintenance in exchange for removing la nd from production and grazing, under 10-15 year contracts. Additionally, the NRCS can initiate funding under Public Law 83-566, the Watershed
Protection and Flood Prevention Act. This federal law can fund watershed pr ojects that include watershed protection, water quality improveme nts, soil erosion reduction, irrigation water management, sedimentation control, and fish and wildlife habitat enhancement.Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load: Page 55 Submittal Report The Walla Walla County and Columbia conservati on districts provide cost-share programs to irrigators and ranchers for ri parian restoration, farm program s, and irrigation conversion programs - all of which could help reduce sedi ment loads in the Walla Walla River and its
tributaries. These conservation districts could also help to provide polyacrylamide (PAM) to farmers that when applied to th e soil helps to reduce soil erosi on. Cost-share can and should be sought by all cooperating groups, but it should be r ecognized that implemen tation of BMPs (with or without cost share) requires that individual landowners make an investment in the practice.

Because much of the Walla Walla basin is cons idered critical ESA habitat for bulltrout and summer steelhead, state and federal funding is av ailable for endangered fish species projects, which will probably help support implementation under this TMDL. The Walla Walla Watershed Planning Unit will have access to funding for proj ects that will further help ameliorate the conditions responsible for the chlorinated pesticide and PCB problem in the area.

CTUIR is involved with a number of habitat, hatchery, harvest, and hydrosystem restoration actions that will ultimately result in increased fi sh production in the Walla Walla and increased tribal consumption of Walla Walla fish. CTUI R’s involvement in th e sub basin provides additional opportunities for fundi ng including but not limited to co st-matching from non-federal rate payer Bonneville Power Administration, EPA tribal gap, and Bureau of Indian Affairs money. These resources may be available to a ssist in on-the-ground science such as fish collections and toxins sampling, and are alrea dy in place to develop and implement habitat restoration projects that may ultimately resu lt in decreased chlorinated pesticide levels.

Summary of Public Involvement

Public involvement is vital in any TMDL. N onpoint TMDLs are successful only when the
watershed landowners and other residents are invo lved, since they are th e closet to and most knowledgeable of the watershed resources. Ecology’s TMDL Evaluation of Chlorinated
Pesticides and PCBs in the Walla Walla River, published in October of 2004 , was subjected to public review and comment. Much of the materi al in this submittal report is based on that publication. In early 2005, a TMDL advisory gro up was founded to disc uss issues and make recommendations to Ecology in the developmen t of this TMDL. Ecology also maintains a mailing list of interested parties so that informati on is readily available to other agencies and the public on matters concerning the TMDL process. The submittal report is opened to public review
and comment before submittal to the EPA.

The Walla Walla basin has a host of local, st ate, federal and tribal agencies, and nongovernmental organizations involved in conservati on activities associated with the mainstem and its tributaries. Many private landowners in th e area are also intimatel y involved with these conservation efforts. Ecology will continue to ta ke steps to try and ensure participation and cooperation from all the great diversity of intere sted parties in this TMDL.Page 56 Walla Walla River Chlorinated Pesticid es and PCBs Total Maximum Daily Load Submittal Report Involving stakeholders in the basin is the key to executing management strategies and actions. Examples of organizations to contact in target ed outreach efforts during implementation include:

• County Conservation Districts and Farm Bureaus.

• Walla Walla Backyard Stream Team.

• Washington State University Cooperative Extension.

• Confederated Tribes of the Uma tilla Indian Reservation (CTUIR).

• Agricultural commodity groups and trade associations.

• Environmental organizations (Blue Mountain Land Trust, C ELP, American Rivers) and civic organizations.

• Walla Walla Watershed Alliance, Kooskoos kie Commons and Native Creek Society.

• Walla Walla County Watershed Planning Department.

• County Commissions and City Councils.

• Tri-State Steelheaders and other hunting, fish ing and outdoor recrea tion interest groups.

• Irrigation districts and or ganized ditch irrigators.

• Agri-businesses and timber companies.

• Economic development organizations.

• Colleges (Walla Walla Community College, Whitman College and Walla Walla College); and indi vidual landowners.

• Government agencies such DOH, WDFW, USDA-NRCS, USFS, and ODEQ and ODFW

• Walla Walla Basin Watershed Council (in Oregon).

• Oregon State University Cooperative Extension.Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load: Page 57 Submittal Report 

# References Cited

Butcher, Don. 2005. Personal communication between Don Butcher of the Oregon State Department of Environmental Quality and Donova n Gray of the Washington State Department of Ecology, February 2005.

Carson, R.J. and Pogue, K.R. 1996. Flood Basalts and Glacier Floods: Roadside Geology of Parts of Walla Walla, Franklin and Columbia Counties, Washington , Division of Geology and Earth Resources Information Circular 90, Wash ington State Dept. of Natural Resources, Olympia, WA.

CRITFC. 1994. A Fish Consumption Survey of the Umatilla, Nez Perce, Yakama, and Warm Springs Tribes of the Columbia River Basin. Tech. Rept. 94-3. Columbia River Inter-Tribal Fish Commission, Portland, OR.

Davis, D. A. Johnson, and D. Serdar. 1995. Washington State Pesticide Monitoring Program: 1993 Fish Tissue Sampling Report . Washington State Dept. Ecology, Olympia, WA.
Pub. No. 95-356.

EES. 2003. Technical Memorandum WRIA 32 – Water Qu ality Task 1 – Erosion and Sediment Modeling for the Walla Walla Basin . Final Draft Report, June 2003, Economic and Engineering Services Inc., Kennewick, WA.

EPA. 1991. Technical Support Document for Water Quality-based Toxics Control

. EPA/505/2-90-001.

EPA. 2002. Columbia River Basin Fish Contaminant Survey, 1996-1998 . EPA Region 10, Seattle, WA. EPA-910/R-02-006.

Fitzpatrick, Martin. 2005. Pe rsonal communication between Mart in Fitzpatrick of the Oregon Dept. of Environmental Quality and Donovan Gray of the Wash ington State Dept. of Ecology, April 13 2005.

Hashim, W.A. and Stalmaster, L. 2004. Washington’s Water Qualit y Management Plan Control Nonpoint Sources of Pollution Volume 1 : Water Quality Summaries for Watersheds in Washington State, Washington St ate Dept. Ecology, Olympia, WA. Publication No 04-10-063.

HDR/EES, Inc. 2005. Walla Walla Watershed Plan, Preliminary , Draft Report, January 2005, HDR/EES, Inc., Pasco, WA.

Johnson, Art. 2005. Personal communication betw een Art Johnson of Washington State Dept. of Ecology’s EAP unit and Donovan Gray of Washington State Dept. of Ecology, March 2005.

Joy, J. and B. Patterson. 1997. A Suspended Sediment and DDT Total Maximum Daily Load Evaluation Report for the Yakima River . Washington State Dept. Ecology, Olympia, WA.
Pub. No. 97-321. Manley, et. al. 1999Page 58 Walla Walla River Chlorinated Pesticid es and PCBs Total Maximum Daily Load Submittal Report Mapes, B.E. 1969. Sediment Transport by Streams in the Walla Walla River Basin, July 1962 – June 1965 . U.S. Geological Survey, Water Supply Paper 1868.

Munn, M.D. and S.J. Gruber. 1997. The Relationship Between Land Use and Organochlorine Compounds in Streambed Sediment and Fish in the Central Columbia Plateau, Washington and Idaho, USA : Environ. Toxicol. Chem. 16(9)1877 - 1887.

National Research Council. 2001. Assessing the TMDL Appr oach to Water Quality Management . Water Science and Technology Adviso ry Board. National Academy Press, Washington, D.C.

Newcomb, R.C. 1965. Geology and Ground-Water Resources of the Walla Walla River Basin, Washington-Oregon : Washington Division of Water Resources Water supply Bull. No. 21, 151p.

Nicholson, Frank. 2005. Persona l communication between Frank Nicholson of the City of Walla Walla and Donovan Gray of Washi ngton State Dept. of Ecology, Spokane WA.

Risebrough, R.W. and W.M. Jarman. 1984. DDT Compounds in Soils and Water Particulates of the Salinas Valley . A report to the State Water Res ources Control Board, Sacramento, CA.

Schirman, Roland. 2005. Personal communicat ion between Roland Schirman of the WSU Cooperative Extension Unit and Donovan Gray of the Washington State Department of Ecology,
March 29 2005.

Walla Walla County and Walla Walla Basin Watershed Council. 2004. Walla Walla Sub basin Plan: May 2004 Version , prepared for: Northwest Powe r and Conservation Council, 84p.

Wania, F. and D. Mackay. 1996. Tracking the Distribution of Persistent Organic Contaminants

. Environ. Sci. Technol. 30(9):390-396A.Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Page A- 59 Submittal Report 

# Appendix A

A Total Maximum Daily Load Evaluation for Chlorinated Pesticides and PCBs in the
Walla Walla River

By Art Johnson, Brandee Era-Miller, Randy Coots, and Steve Golding

October 2004
Publication No 04-03-032

This report is available on the Department of Ecology home page on the World Wide Web

at http://www.ecy.wa.gov/biblio/0403032.html

For a printed copy of this report, contact: Department of Ecology Publica tions Distributions Office Address: PO Box 47600, Olympia WA 98504-7600 E-mail: ecypub@ecy.wa.gov Phone: (360) 407-7472
Refer to Publication Number 04-03-032Page A-60 Walla Walla River Chlorinated Pesticid es and PCBs total Maximum Daily Load Submittal Report - DRAFTWalla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Page B- 61 Submittal Report 

# Appendix B

Walla Walla Watershed Plan Preliminary Draft

By HDR/EES, Inc.

January 2005

This report is available on the Walla Walla Watershed Planning home page on the World Wide Web at http://www.wallawallawaters hed.org/wsplanning.html#documents

For a printed copy of this report, contact: HDR/EES, Inc. 2805 St. Andrews Loop, Suite A Pasco, Washington 99301Page B-62 Walla Walla River Chlorinated Pesticid es and PCBs total Maximum Daily Load Submittal ReportWalla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Page C- 63 Submittal Report 

# Appendix C

Stormwater Management Manual for Eastern Washington

Prepared By: The Washington State Departm ent of Ecology’s Water Quality Program

September 2004
Publication No. 04-10-076

This report is available on the Department of Ecology home page on the World Wide Web at http://www.ecy.wa.gov/biblio/0410076.html

If you have a credit card, you can order printed copies of the manual and the manual on CD at the following Internet address: https://wws2.wa.gov/prt/printwa/wsprt/default.asp

OR:

For a printed copy of this report, contact: Department of Ecology Publica tions Distributions Office Address: PO Box 47600, Olympia WA 98504-7600 E-mail: ecypub@ecy.wa.gov Phone: (360) 407-7472
Refer to Publication Number 04-10-076Page C-64 Walla Walla River Chlorinated Pesticid es and PCBs total Maximum Daily Load Submittal ReportWalla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Page D- 65 Submittal Report 

# Appendix D

Model Municipal Stormwater Manage ment for Eastern Washington

Prepared By: The Washington State Departm ent of Ecology’s Water Quality Program

September 2003
Publication No. 03-10-076

This report is available on the Department of Ecology home page on the World Wide Web at http://www.ecy.wa.gov/biblio/0310076.html

If you have a credit card, you can order printed copies of the manual and the manual on CD at the following Internet address: https://wws2.wa.gov/prt/printwa/wsprt/default.asp

OR:

For a printed copy of this report, contact: Department of Ecology Publica tions Distributions Office Address: PO Box 47600, Olympia WA 98504-7600 E-mail: ecypub@ecy.wa.gov Phone: (360) 407-7472
Refer to Publication Number 03-10-076Page D-66 Walla Walla River Chlorinated Pesticid es and PCBs total Maximum Daily Load Submittal ReportWalla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Page E- 67 Submittal Report 

# Appendix E

Upper Yakima River Basin Suspended Sediment , Turbidity and Organochlorine Pesticide Total Maximum Daily Load, Submittal report.

Prepared By: Jane Creech and Joe Joy

August 2002
Publication No. 02-10-047

This report is available on the Department of Ecology home page on the World Wide Web at http://www.ecy.wa.gov/biblio/0210047.html

If you have a credit card, you can order printed copies of the manual and the manual on CD at the following Internet address: https://wws2.wa.gov/prt/printwa/wsprt/default.asp

OR:

For a printed copy of this report, contact: Department of Ecology Publica tions Distributions Office Address: PO Box 47600, Olympia WA 98504-7600 E-mail: ecypub@ecy.wa.gov Phone: (360) 407-7472
Refer to Publication Number 02-10-047Page E-68 Walla Walla River Chlorinated Pesticid es and PCBs total Maximum Daily Load Submittal ReportWalla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Page F- 69 Submittal Report 

# Appendix F

By Congressional mandate, the Agency for Toxic Substances and Disease Registry (ATSDR) produces "toxicological profiles" for hazardous substances found at National Priorities List (NPL) sites. These hazardous s ubstances are ranked based on frequency of occurrence at NPL sites, toxicity, and poten tial for human exposure.

Further information:

• ATSDR ToxProfiles 2004TM CD-ROM - The toxicological profiles are also available as a complete set on CD-ROM.

• Public Health Statements (PHS) - The PHS are a series of summaries about hazardous substances taken from Chapter One of thei r respective ATSDR Toxicological Profiles.

• ATSDR ToxFAQsTM - The ToxFAQsTM are a series of 2-page fact sheets about
hazardous substances.

To request a copy of the ToxProfilesTM CD-ROM, PHS, or ToxFAQsTM call 404-498-0261 or email your request to atsdric@cdc.gov

.
For more information on the above listed publications, write

Division of Toxicology, Agency for Toxi c Substances and Disease Registry 1600 Clifton Road, Mailstop F-32, Atlanta, GA 30333

For more information 24 hours/day

You may call the ATSDR toll free number at 1-888-42-ATSDR (1-888-422-8737) to get 24-hour
recorded information about Division of T oxicology programs. This phone number includes options to be transferred to ATSD R personnel for tech nical assistance.

ATSDR Internet home p age via World Wide Web : http://www.atsdr.cdc.gov

The profiles, public health statements, ToxFAQs TM and other information are available on the

Internet.Page F-70 Walla Walla River Chlorinated Pesticid es and PCBs total Maximum Daily Load Submittal ReportWalla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Page G- 71 Submittal Report 

# Appendix G

Acronyms and Abbreviations

AKART All Known and Reasonable Technology BMP Best Management Practice
CAO Critical Areas Ordinance CAFO Contained Animal Feeding Operation
CCD Columbia Conservation District
CD Conservation District CIDMP Comprehensive Irriga tion District Management
Plan
CRB Columbia River Basalts CREP Conservation Reserve Enhancement Program CRP Conservation Reserve Program
CTUIR Confederated Tribes of the Umatilla Indian
Tribes CWA Clean Water Act (Federal) DEQ/ODEQ Oregon Department of Environmental Quality DOE/Ecology Washington Stat e Department of Ecology DOH Washington State Department of Health DDD Dichlorodiphenyl Dichloroethane DDE Dichlorodiphenyl Dichloroethylene DDT Dichlorodiphenyl Trichloroethylene EES Economic and Engineering Services, Inc. EPA U.S. Environmental Protection Agency EQIP Environmental Quality Incentives Program ESA Endangered Species Act (Federal) GPS Global Positioning System
HCP Habitat Conservation Plan MOA Memorandum of Agreement NOAA National Oceanic and Atmospheric
Administration NPDES National Pollutant Discharge Elimination System
NRCS Natural Resource Conservation Service
NTR National Toxics Rule NTU Nephelometric Turbidity Unit ODFW Oregon Department of Fish and Wildlife OFM Washington State Office of Financial Management PCB Polychlorinated Biphenyl
PNW Pacific Northwest RCW Revised Code of Washington
RM River MilePage G-72 Walla Walla River Chlorinated Pesticid es and PCBs total Maximum Daily Load Submittal Report SPMD Semipermeable Membrane Device TMDL Total Maximum Daily Load TSS Total Suspended Solids
USFS U.S. Forest Service USGS U.S. Geologic Survey WAC Washington Administrative Code WDFW Washington Department of Fish and Wildlife WRIA 32 Water Resource Inventory Area (Walla Walla Basin) WSU Washington State University
WWCCD/WWCD Walla Walla C ounty Conservation District
WWTP Wastewater Treatment Plant mg/L milligrams per liter (parts per million) ug/L micrograms per liter (parts per billion) ng/L nanogram per liter (parts per trillion) ug/Kg micrograms per kilogr am (parts per billion)Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Page H- 73 Submittal Report 

# Appendix H

Responsiveness Summary
(Note: Due to editing, page numbers in the fina l draft of the submittal report may differ from those cited in the comments.)Page H-74 Walla Walla River Chlorinated Pesticid es and PCBs total Maximum Daily Load Submittal ReportWalla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Page H- 75 Submittal Report 1) Comment:

1.1) Response:

Ecology agrees that maintaining and restoring ripari an areas will be very im portant to the success of this TMDL. We are aware of and apprecia te the work the local community has already accomplished with regard to water quality improvements. Ecology is committed to working cooperatively and collaborativel y with the local community to implement sound watershed agricultural practices and partner with existing programs such as CRP and CREP to achieve the necessary water quality improvements. Ecology w ill continue to educate the local community about water quality issues and seek funding to help both educa tional and riparian restoration
efforts.Page H-76 Walla Walla River Chlorinated Pesticid es and PCBs total Maximum Daily Load Submittal Report 2) Comment:Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Page H- 77 Submittal ReportPage H-78 Walla Walla River Chlorinated Pesticid es and PCBs total Maximum Daily Load Submittal ReportWalla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Page H- 79 Submittal ReportPage H-80 Walla Walla River Chlorinated Pesticid es and PCBs total Maximum Daily Load Submittal Report 2.1) Response: First Page, First Bullet

Flow information was used in the calculation of the allocations recommended in the Walla Walla toxics TMDL technical report. In addition to th e data on general flow conditions (see technical report pages 45-46), flow data was also obtained from WWTP records (see technical report, page 36, under Effluent Samples ). Pages 101-102 of the technical re port describe in detail how flow was used in the calculation of the loading capac ities, load and wasteloa d allocations. We agree that the Walla Walla WWTP discharge to Mill Cr eek is relatively insignificant. The submittal report (p.27, 3 rd paragraph, 3 rd sentence) states “the WWTPs repr esent less than ten percent of the PCB load in the receiving wa ters and thus are not as importa nt relative to nonpoint sources”. In addition p.32, final paragraph, 3 rd sentence (same document) states “Nonpoint sources coming into the WWTPs may be contri buting to elevate PCB levels found in the WWTP effluent.” However, effluent samples taken by Ecology of the WWTPs’ effluent did show PCB concentrations were in exceedance of state and federal water quality standards. Ecology is required under the federal Clean Water Act and RCW 90.48 to address water quality impairments to waters of the state. In the case of point source discharges such as WWTPs this is
done in the form of wasteload allocations in a TMDL. RCW 90.48. requires that point source dischargers of pollutants into wa ters of the state us e all known, available and reasonable methods of prevention, control, and trea tment (AKART) to reduce polluta nt concentrations to within acceptable limits, regardless of whether the facility in question is the source of the pollutant or merely the conduit.

2.2) Response: First Page, Second Bullet

At the time the phrase referenced in the bulle t was written, the Walla Walla WWTP was still in the process of developing a water re-use progr am. This phrase has now been removed from the text to reflect the latest developments.

2.3) Response: Second Page, First Bullet

The toxics TMDL submittal report does not imply or state that Ecology’s intention is to restore Mill Creek to a ‘pristine’ state. The toxin reductions required in the report are those necessary to meet state and federal water quality standards, but will not completely eliminate these toxins.

2.4) Response: Second Page, Second Bullet

See response to 2.1) First Page, First Bullet

2.5) Response: Second Page, Third Bullet

We agree that carp and suckers are not consum ed by a large segment of the local population. However, the human health criteria and water qual ity targets in the TMDL are intended to make it safe to eat all fish species ca ught in the river. The technical study analyzed carp and suckers, in addition to pike minnow, carp, catfish, and smallm outh bass. These are the predominant resident fish species that presently exist in the river. Migratory species like steelhead were not analyzed because the results would primarily reflect resi dues accumulated elsewhere. The selection ofWalla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Page H- 81 Submittal Report water quality targets that will bring the river in to compliance with pesticide and PCB standards was based on water quality criteria established by EPA, not on the levels of contamination in the Walla Walla fish and analyzed for the techni cal study. While there is some evidence that pesticide concentrations have decreased over time, the compar ison shown by Mr. Slovensky to illustrate a decrease in PCB concentrations in suckers is not appropriate because the older data are for whole fish samples and the newer data are for fillet samples and are therefore not comparable.

2.6) Response: Second Page, Fourth Bullet, First Point

From the information cited by Mr. Slovensky it do es appear that the Montana human health criteria are based on a less prot ective risk factor than Ecology’s criteria. In the National Toxics Rule, EPA gave the states l eeway to select either a 10 -5 (one in one hundred thousand) or 10 -6
(one in one million) risk level; Washington chose 10 -6

.

2.7) Response: Third Page, First Point

See response to 2.5) Second Page, Third Bullet

2.8) Response: Third Page, Second Point

Ecology remains committed to en couraging the use of appli cable BMPs and/or AKART to
address all sources of PCBs in the Walla Walla Basin. Specific strategies for addressing various
contaminant sources will be addressed in the Detailed Implementation Plan to be compiled in collaboration with the Walla Walla TMDL advisory group. As part of this process the advisory group may choose to investigate potential PCB c ontaminated paint in the baffle system and accompanying channels. However, known PCB point s ources such as the effluent from the Walla Walla and College Place WWTPs are required under state and federal legislation to receive a
wasteload allocation.

2.9) Response: Third Page, First Bullet

See response to 2.1) First Page, First Bullet and 2.8) Third Page, Second Point. We agree that PCB congener analysis is expensive, but costs could be lowered if a simple data report is requested vs. an exhaustive data package.

2.10) Response : Third Page, Second Bullet

See response to 2.1) First Page, First BulletPage H-82 Walla Walla River Chlorinated Pesticid es and PCBs total Maximum Daily Load Submittal Report 2.11) Response: Fourth Page, First Bullet

The chart plots data for creeks that have signific ant urban and/or agricultu ral land use, so would not be considered “background” in the sense of being uncontaminated. We agree that the levels in WWTP effluent appear to be generally similar to or slightly less than the other sites shown in this comparison.

2.12) Response: Fourth Page, Second Bullet

As described in the Walla Walla toxics TMDL technical report, PCB-4 (a specific PCB compound not found in environment) was spiked into these samples prior to analysis and thus should not be used to compare PCB levels among waterbodies.

2.13) Response: Fourth Page, Third Bullet

See response to 2.1) First Page, First Bullet and 2.8) Third Page, Second Point.Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Page H- 83 Submittal Report 3) Comment:

3.1) Response: Second Paragraph

The chlorinated pesticides and PCBs and associ ated sediment reductions prescribed in the submittal report are those calculated as necessary to achieve compliance with state and federal water quality standards. Page 97 of the Walla Walla chlorinated pesticides and PCBs TMDL technical report summarizes the success that has been achieved in the suspended solids/DDT
TMDL for the Yakima River. The TSS and turbid ity targets in the Yakima TMDL were similar to those proposed for the Walla Walla River. Page 106 of the technical report also cites a sediment loading study by Economic and Engineering Services, Inc. that concludes it is feasible to reduce sediment loading in the Walla Walla basin by 85%.

3.2) Response: Third ParagraphPage H-84 Walla Walla River Chlorinated Pesticid es and PCBs total Maximum Daily Load Submittal Report The statement referred to was only intended to he lp describe the general conditions in the basin. The sentence now reads ‘flow is sustained thoug h June from snowmelt’. The Walla Walla toxics TMDL technical report reviews hist orical data on pesticide leve ls in deposits of streambed
sediments collected in the Walla Walla River and tributary mouths (Table 3). The concentrations were low to non-detectable. A USGS study refe renced in the technical report (Mapes, 1969)
found that most of the eroded soil in the Walla Walla basin consists of fine silt and clay that is kept in suspension by turbulence and transported out of the system.

3.3) Response: Fourth Paragraph

The Walla Walla TMDL toxics technical re port acknowledges that the TSS target is overprotective for chlorinated pesticides in the Touchet but points out that the more stringent target remains pertinent for the Touchet in order to meet turbidity standards in the mainstem, as well as for protection of fish and wildlife (page 96). Dry Creek also had at least one exceedance each for DDT, PCBs, chlordane, and heptachlor epoxi de and is a significant source of turbidity to the mainstem. Each of these pesticide/P CB exceedances represents a one month average concentration. There is currently no information to suggest a “higher allowed TSS” target would be appropriate for Dry Creek.

3.4) Response: Fifth Paragraph, First Three Sentences

We agree that all sources of suspended solids do not have equal amounts of the compounds in question. However, as described in the technical report, it is clear that the Walla Walla and its tributaries have significant water quality problems that include chlorinated pesticides, PCBs, TSS, and turbidity to varying degrees dependi ng on location. These streams must meet water quality standards for these parameters, and others not addressed in this report, in order for water quality to be improved. A range of beneficial uses are affected including sport fishing, fish and wildlife habitat, and aesthetic values (see pages 87-94 of the technical report). The technical study showed that once TSS levels in the mainstem are reduced below 50 mg/L one would expect the river to be in compliance with pest icide standards. This presumes a basin-wide approach to the problem, which is appropriate given the range of impaired uses and sources.

3.5) Response: Fifth Paragraph, Final Sentences

The distinction here is that 100 mg/L TSS predic ts DDE violations, while the TSS target of 50 mg/L takes into account the total DDT concen tration (i.e., DDT plus its breakdown products DDE and DDD). The 30 mg/L target is base d solely on meeting tu rbidity standards.Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Page H- 85 Submittal Report 4.) Comment:

4.1) Response:

See responses to Comment 3 above.Page H-86 Walla Walla River Chlorinated Pesticid es and PCBs total Maximum Daily Load Submittal Report 5.) Comment:Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Page H- 87 Submittal Report 5.1) Response:Page H-88 Walla Walla River Chlorinated Pesticid es and PCBs total Maximum Daily Load Submittal Report 5.2) Response : Following negotiations w ith the Walla Walla Watershed Planning Department, Ecology agreed to add language to the submittal re port that covered the outstanding issues that the TMDL advisory group felt needed addressi ng. This language appears in its entirety (as shown below) in the submittal report on pages 42 and 45 (the page numbers referred to below have changed due to subsequent editing) with minor additions as approved by the Walla Walla Watershed Planning Department. Ecology’s additions are shown in bold.

Additional TMDL language for PCB/Chlo rinated Pesticides Submittal Report

Page 39 – prior to table

As stated in the Walla Walla Watershed Plan, no organization or person is required to take on a commitment without their consent. However, once an organization has formally agreed to implement actions identified in the plan, it is expected these commitments be honored; recognizing funding limitations. The watershed plan does not create any obligations for private businesses, citizens or landowners. Howe ver, there are actions identified for voluntary action in the private sector. Although the Watershed Planni ng and TMDL processes are fundamentally different, Ecology has and w ill continue to seek opportunities for collaboration and cooperation between the two pr ocesses. It should be noted that Ecology is required under the federal Clean Water Act to conduct TMDLs and ensure clean water.

To be included on page 41– end of page

The following items were identified by the Walla Walla TMDL advisory group which will be looked at during the development of th e Detailed Implementa tion Plan (DIP): Several TMDL program implementation topics have emerge d that warrant emphasis in the water quality strategy for the TMDL implementation plan. It is the desire of several members of the TMDL Advisory Committee that these si te specific issues be discusse d in more detail during the Detailed Implementation Plan (DIP) development. Further public input w ill be sought to help prepare this plan. The plan will identify how, when, and where voluntary restoration activities will be implemented.

Actions recommended in the DIP are intended to be specific enough to clearly identify the actions and results; yet general enough to permit some flexibility in carrying them out. It is recognized that some actions will require furthe r investigation prior to full implementation. Additionally it is recogni zed that some actions can be carri ed out only if funding is provided by the state legislature or other funding agencies, and that funding decisions will be made over a period of months or years following plan adoption.

The following concepts will be looked at in further detail during the Detailed Implementation Plan development: addressing the correlation be tween TSS and Turbidity to toxins in the Touchet River basin and the Dry Cr eek basin; identifying historic background levels for turbidity in the Walla Walla watershed and various tributaries, including identification of additional sampling sites including soil testing and stream bed sediment loads; identifying additional sampling methods; identification of geographic source differences for toxin contamination including possible atmospheric deposition. As long as TSS con tinues to be the surrogate measure of chlorinated pesticides periodic valid ation of the current fo rmulas should be made.Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Page H- 89 Submittal Report Many local interests in the Walla Walla Ba sin are involved with TMDL planning and implementation. During the development of the DIP, in areas where soils contributing to turbidity are found to have high levels of pollu tant present, special emphasis on helping to relieve the problem will be employed. Ecology will continue to work closely with these basin
interests to addre ss outstanding issues.Page H-90 Walla Walla River Chlorinated Pesticid es and PCBs total Maximum Daily Load Submittal Report 6.) Comment:Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Page H- 91 Submittal ReportPage H-92 Walla Walla River Chlorinated Pesticid es and PCBs total Maximum Daily Load Submittal Report 6.1) Response : p.9 Change made. 2 nd Paragraph, 2 nd sentence now reads – “...until the EPA approves the new standards” 2 nd paragraph, final sentence now reads – “However, the toxics
criteria for this TMDL are not be ing revised and are still in effect in the same form they will be in after the revised standards are approved”.

6.2) Response : 3 rd Paragraph – The final sentence of paragraph 2 already states that which was said in paragraph 3. Paragraph 3 was ther efore redundant and deleted from the text.

6.3) Response : 4 th Paragraph – changes made

6.4) Response : p.10, 1 st paragraph – change made

6.5) Response : p.11 – addition made

6.6) Response : p.17 1 st paragraph, 1 st sentence - sentence now reads – “...the levels of chlorinated pesticides and sediment load in th e water column. The correlation between PCBs and
sediment loads was weaker”.Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Page H- 93 Submittal Report 6.7) Response : Pg 26 final paragraph, last sentence - sentence added-“TSS reductions down to 5mg/L are deemed necessary to achieve compliance with toxics criteria”

6.8) Response : Pg.27-28 first two paragraphs - First sentence (page 29 second paragraph) now reads-“TSS targets of 50mg/L and 5mg/L in the ma instem Walla Walla and tributaries, and the
East Little Walla Walla and Yellowhawk Creeks respectively are set to achieve....” p.30 first paragraph, and p.33 discuss why more stringent TSS targets were deemed necessary in the East
Little Walla Walla and Yellowhawk Creeks.

6.9) Response : Load allocation, 2 nd paragraph – The use of the term ‘background’ in this paragraph refers to TSS background levels and not contaminant background levels. The central premise of this report is that soils are the chief vector for legacy chlorinated pesticides and PCBs entering the water column in the Walla Walla basin, hence its mention here. Although no natural ‘background’ levels exist for chlorinated pe sticides and PCBs (as these are manmade compounds), some degree of sediment loading can be expected hence the term ‘background’. The first sentence of this paragraph has been re vised to better clarify th at the word ‘background’
refers to TSS.

6.10) Response : p. 29 1 st paragraph – Toxaphene was added to list of contaminants in the final paragraph before the Load Allocation section. As the first paragr aph on page 29 does not list any contaminants specifically, it is unclear wh at this comment is referring to. The Load Allocation section (p. 28) of the report states that the Wash ington state water quality cr iteria are the ultimate basis for the sediment allocations and TSS target s. We believe the report explains clearly under
the Technical Analysis and Loading Capacity sections how the criteria were employed in calculating these. In addition these methods are explained in further de tail in the Walla Walla chlorinated pesticides and PCBs TMDL technical report. The appl icable toxaphene criteria are listed in Table 1, of the submittal report.

6.11) Response : Pg 31 3 rd second full paragraph (now pg. 34 first paragraph)

- sentence amended to-“...the Walla Walla River and its tributaries at the ....”. p.32, 1 st paragraph, 3 rd
sentence (now pg. 35 first paragraph) under the Wasteload Allocation section: sentence amended to-“...to the Walla Walla River and its tributaries are present...”

6.12) Response : p.35 last bullet - bullet removed.Page H-94 Walla Walla River Chlorinated Pesticid es and PCBs total Maximum Daily Load Submittal Report 7.) Comment:Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Page H- 95 Submittal Report 7.1) Response: Second Paragraph, First Sentence

There are at least four laborator ies (see table below) in North America certified to analyze lowlevel PCB congeners by EPA Method 1668 (High Resolution GC/MS).

LabName City ContactPhone EMailAddress

Axys Analytical Services Ltd Sidney, BC (250) 655-5800 dfyles@axys.com

Pace Analytical Services, Inc. Minneapolis, MN (612) 607-1700 cgaylord@pacelabs.com

Pacific Rim Laboratories, Inc. Surrey, BC (604) 532-8711 dave@pacificrimlabs.com

STL Sacramento West Sacramento, CA (916) 374-4308 lstafford@stl-inc.com EPA considers the analytical method to be accurate below 1 ppt.Page H-96 Walla Walla River Chlorinated Pesticid es and PCBs total Maximum Daily Load Submittal Report 7.2) Response: Second Paragraph, Second Sentence

The Walla Walla toxics submittal report, Page 10, final paragraph states: “Washington state water quality criteria that appl y to 303 (d) listed pesticides and PCBs in the Walla Walla drainage...... were promulgated for Washington in the EPA National Toxics Rule (40 CFR 131.36).” Supporting information on how EPA derived human health criteria for PCBs and other
chemicals can be found at: http://www.epa.gov/waterscience/criteria/humanhealth/

7.3) Response: Second Paragraph, Third Sentence Field procedures, analytical methods, and data qu ality relevant to PCBs are described on pages
21- 43 of the Walla Walla toxics TMDL technical report. Details of the analytical methods used
for PCBs can be found at http://www.epa.gov/sw-846/main.htm and http://synectics.net/resources/

.

7.4) Response: Third Paragraph, First and Second Sentence See response to 7.2) Second Paragraph, Second Sentence above

7.5) Response: Fourth Paragraph, Final Sentence See response 7.2) Second Paragraph, Second Sentence above and also response to Mr. Putnam 9.5) 5. The PCB human health criteria are based on the commercial mixtures of PCBs used in the laboratory studies that establ ished animal carcinogenicity.

7.6) Response: Page Two, Final Two Paragraphs Ecology is mandated under the federal Clean Wate r Act and RCW 90.48 to address water quality impairments of waters of Washi ngton state. Ecology’s sampling of the effluent from the Walla Walla and College Place WWTPs found PCB levels to exceed state and federal water quality standards, which resulted in these two facili ties being assigned wastel oad allocations. Under WAC 173-201A-510 these facilities have 10 years to achieve full compliance with PCB limits following adoption in their NPDES permits, during which time Ecology is committed to working cooperatively and collaboratively with the WWTPs to develop strategi es to address these impairments. Ecology does not recommend any dr edging as a remedial action for PCB clean-up
in the Walla Walla River.Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Page H- 97 Submittal Report 8.) Comment:Page H-98 Walla Walla River Chlorinated Pesticid es and PCBs total Maximum Daily Load Submittal Report 8.1) Response : (1) The water quality criteria on which the plan is based apply to a range of fish species, not just carp or suckers. The same crite ria and TMDL targets would apply regardless of the type of fish collected during the techni cal study. Also see res ponse to Mr. Slovensky’s

comments 2.5) Second Page, Third Bullet.

8.2) Response : (2) See response to Ms. McConville 7.1) Second Paragraph, First Sentence

. There are at least four laborat ories in North Ameri ca certified to analy ze PCB congeners. EPA considers the analytical method to be accurate belo w 1 ppt. We agree that it is expensive. Cost per sample is in the range of $600 - $800 for a wate r sample, but could be lower if a simple data report is requested vs. an exhaustive data package.

8.3) Response : (3) The samples collected by Ecology of the effluent from the Walla Walla and College Place WWTPs showed that PCB concen trations exceeded Wa shington water quality
standards and therefore th ese facilities were assigned wastel oad allocations. Ecology is mandated under the Clean Water Act and RCW 90.48 to ensure water quality impairments are addressed. The Walla Walla penitentiary is currently regulated under a te mporary state waste discharge permit. The permit contains no PCB limit at this time as no information currently exists to
substantiate such action. However if it is determined that a PCB impairment exists appropriate limits may be added to the permit in future. RCW 90.48. requires that point source discharges of pollutants into waters of the state use AKART to reduce pollutant concentrations to within acceptable limits, regardless of whether the facility in question is the source of the pollutant or merely the conduit. PCBs are manmade highly persistent carcinoge nic toxins. There are no ‘background’ levels for these compounds as they do not occur naturally in the environment.

8.4) Response : (4) The current NPDES permits for the College Place and Walla Walla WWTPs do not specifically contain any limits for PCBs, because the wasteload allocation assigned in the TMDL submittal report has not yet been approved by EPA. Once the draft of the TMDL submittal report has been finalized it will be se nt to EPA for additional review and approval. Once EPA approves the final draft of the report the PCB wasteload alloca tions will be adopted into the current NPDES permits. It is expected that the cities of College Place and Walla Walla will adjust their pretreatment standards in ac cordance with the Walla Walla toxics TMDL and any permit changes.

8.5) Response : (5) The chemical data in the technical report accounted for the method blank in keeping with requirements of the EP A methods used in the analyses. This is discussed in further detail in response to Dr. Esvelt’s comments 17.2) 3a, 3f , 3g and 4 below.Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Page H- 99 Submittal Report 8.6) Response : (6) See response to Mr. Slovenky’s comment 2.2) First Page, Second Bullet.

8.7) Response : (7) The technical report in cluded an example calculation of loading capacity for pesticides and PCBs in the Walla Walla mainst em, using the harmonic mean flow for the period of record (page 101 of the chlorinated pesticid es and PCBs toxic repor t). This is a typical approach for determining loading capacity in TMDLs. The report estimated loading capacities
for TSS based on the 90 th percentile flow. Loading capacities fo r PCBs were also calculated for Mill Creek and Garrison Creek, taking into account the time period when WWTP effluent is discharged to these creeks; the former used th e harmonic mean for December through April, and the latter used the harmonic mean for the entire year.

8.8) Response : (8) The wasteload allocation for the Wa lla Walla treatment plant was based on the harmonic mean for Mill Creek for December through April.

8.9) Response : (9) See responses to Ms. McConville’s comments 7.5) Fourth Paragraph, Final

sentence. Washington state’s chlorina ted pesticide and PCB water quality criteria are promulgated by the EPA National Toxics Rule. Th e load and wasteload allocation assigned in this report were calculated as those necessary to achieve co mpliance with these criteria.

8.10) Response : (10) and (11) The public comment pe riod was extended an additional 30 days,
and the relevant data was turned over to Dr. Es velt as requested. See resp onses to Dr. Esvelt’s
comments for further information.Page H-100 Walla Walla River Chlorinated Pesticid es and PCBs total Maximum Daily Load Submittal Report 9.) Comment:

9.1) Response : (1) The wasteload allocation for the College Place WWTP effl uent is based on the human health water quality criterion for PCBs . This criterion is much lower than drinking
water limits because fish bioaccumulate PCBs to le vels tens of thousands of times higher than in the surrounding water. Also, drinking water limits take into account the economic impact of the regulation.

9.2) Response : (2) See response to Ms. McConville 7.1) Second Paragraph, First Sentence.
There are at least four laborat ories in North Ameri ca certified to analy ze PCB congeners. EPA considers the analytical method to be accurate below 1 ppt. Also see response to Mr. Slovensky’s

comments 2.9) Third Page, First Bullet and response to Mr. Nicholson’s comment 8.2) #2.

9.3) Response : (3) See response to Mr. Nicholson’s comment 8.2) #2.

9.4) Response : (4) The technical study analyzed carp a nd suckers, in addition to pike minnow, carp, catfish, and smallmouth bass. These are the pr edominant resident fish species that presently exist in the river. Migratory species like steelh ead were not analyzed because the results would primarily reflect residues accumulated elsewhere. Th e selection of water quality targets that will bring the river into compliance with pesticid e and PCB standards was based on water quality criteria established by EPA, and analyzed fo r the technical study. See also response to Mr.
Nichloson’s comment 8.2) #1 and response to Mr. Slovensky’s comments 2.5) Second Page,
Third Bullet.Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Page H- 101 Submittal Report 9.5) Response : (5) The EPA human health criteria at issue in the TMDL are based on total PCBs. The animal exposure data from which th e criteria were derive d were obtained using commercial Aroclor mixtures which contain cong eners with a wide range of toxicities. EPA recommends summing congeners when assessing compliance with water quality criteria. See also responses to Ms. McConville’s comments 7.2) Second Paragraph, Second Sentence and 7.5) Fourth Paragraph, Final Sentence.

9.6) Response : (6) The chemical data in the technical report accounted for the method blank in keeping with requirements of the EPA methods used in the analyses. See also response to Mr.
Nicholson 8.5) 5.Page H-102 Walla Walla River Chlorinated Pesticid es and PCBs total Maximum Daily Load Submittal Report 10.) Comment:

10.1) Response : (1) Many of the Best Management Prac tices (BMPs) that are recommended in the report have been employed by farming comm unities across the st ate including the Walla Walla drainage to good effect. Ecology ac knowledges the positive conservation work accomplished by local entities through the implemen tation of BMPs, and encourages more of the

same.

10.2) Response : (2) The chlorinated pesticides (e.g. DDT) addressed in this report are legacy pollutants in the sense that they were banned during th e 1960’s, 1970’s and 1980’s, and no longer see large scale agricultural use in the US A. However, these chemicals have a propensity to bond with soil particles, and breakdown very slowly. Current a pplication is not considered a threat to water quality in the area, but the erosion of contaminated soils in areas where chlorinated pesticides were previously a pplied is indeed considered a problem.Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Page H- 103 Submittal Report 10.3) Response : (3) Although we acknowledge that water qu antity may have an effect on water quality impairments, flow issues are beyond the scope of this TMDL document. Ecology’s Water Resource Program and Shorelines and Environmen tal Assistance Program in collaboration with local community entities like Watershed Planning Units is/are responsible for managing water quantity related issues across th e state. Every effort is made to facilitate cross-program communication and cooperation to ensure best management of the state’s water resources.

10.4) Response : (4) Land use in the Walla Walla drainage is predominately agricultural, and as such point source pollution disc hargers are not abundant. In th is TMDL the only point-source polluters identified as contributors to the chlo rinated pesticides and PCB problem in the Walla Walla are the wastewater treatment plants (WWT Ps) for the cities of Walla Walla and College Place. Analysis of effluent samples collected fr om these facilities showed PCB concentrations were above state water quality criteria and ther efore they were assigned wasteload allocations. See also response to Mr. Slovensky’s comment 2.2) First Page, Second Bullet. Stormwater
runoff from urban environments such as the ci ties of Walla Walla and College Place was not sampled during Ecology’s study of the Walla Wa lla area, and it was not possible to assign allocations to this potential source. However, local authorities’ respons ibilities under current federal and legislation and local ordinances are mentioned in the report and local authorities are encouraged and expected to abide by said regulations.Page H-104 Walla Walla River Chlorinated Pesticid es and PCBs total Maximum Daily Load Submittal Report (Note – the first letter from th e Confederated Tribes of the Umatilla Indian Reservation was received a few days prior to the start of the public comment period, but because we believe it provides important detail to the comments recei ved later in the second letter, we decided to include the first letter):Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Page H- 105 Submittal ReportPage H-106 Walla Walla River Chlorinated Pesticid es and PCBs total Maximum Daily Load Submittal ReportWalla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Page H- 107 Submittal Report 11.) Comment:Page H-108 Walla Walla River Chlorinated Pesticid es and PCBs total Maximum Daily Load Submittal Report 11.1) Response: Sep 16 th letter, First Page, Second Paragraph, and Nov18th letter, Final Two Paragraphs

Ecology greatly appreciates the efforts that the Confederated Tribes of the Umatilla Indian Reservation (CTUIR) staff have put into the chlorinated pesticid es and PCBs TMDL project over the past few years, and believe that the intere st, insight, and informa tion provided by your tribe has been vital in developing a successful TMDL project. The targets in the TMDL are based on the water quality criteri a in standards and federal rule ( 40CFR131.36), and are the water quality
standards-based load allocations th at would form the basis of a legal agreement with the USEPA. The goals in the TMDL are based on site-specifi c considerations (in this case the larger amounts of fish consumed by the Umatilla Tribe and the subsequent higher risk the tribe incurs) and are not part of the water quality standards-based load allocation agreed upon with the USEPA.
Because our toxic criteria in our standards and the federal rules serve as the legal foundation for our Clean Water Act regulatory actions we cannot use a numeric criteri on that is not in our standards. Ecology is committed to working with the other Pacific Northwest (PNW) states and
the USEPA to reduce toxics in water and fish to le vels protective of the different groups that use
or could use these resources. Th is includes tribal consumers. Th e early planning stages of this effort are now focused on the Columbia River. In the specific case of the Umatilla tribe and the Walla Walla River, Ecology will begin the toxi cs reduction program by working with local groups and the tribe to develop and implement Best Management Practices (BMPs) or other control strategies to reach the reductions identified as targets in the TMDL. Once these targets are met, Ecology will continue to work toward meeting the more stringent TSS goals. However as these goals are not based on state water quality standards they can have no regulatory significance, hence the use of the word ‘goal’. Ecology’s intent in this TMDL program is to
focus state resources on actions that will lead to reductions in toxi cs in the water and sediments, and subsequently to reductions in toxics in the fishery resources and other aquatic life in the river
system.Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Page H- 109 Submittal Report 11.2) Response: Sep 16 th letter
, Second Page, First Paragraph

All of the pesticides in question have an affinity for soil particles. As stated in the chlorinated pesticides and PCBs TMDL techni cal report (page 86): “Since the ot her pesticides of concern are generally present at lower levels than DDE and exceed their criteria to a lesser degree, land use changes directed at meeting a DDE-based target w ould also effectively address these chemicals.” We cannot envision any other outcome than a reduc tion in pesticide levels in Walla Walla as TSS levels are brought under control. However, "site-specific evidence” for water quality improvements will require BMP implementation a nd effectiveness monitoring as described in the submittal report.

11.3) Response: Sep 16 th letter, Second Page, Second Paragraph

It is not clear what “biological pools” this comm ent refers to. Aquatic animals and plants would be expected to come into equilibrium with the DDT concentration in the ambient water and thus
would not constitute a source in the usual sense of the word. We agree that small terrestrial inputs of DDT compounds may cause unacceptable levels in the receiving waters. While many examples exist of significant reductions in fish tissue concentrations follo wing source control of DDT, only time will tell what level of cleanup can be achieved in the Walla Walla River. The 2 nd
comment in this paragraph was addressed in Ecology’s reply to the preceding paragraph. We agree the relationship between TSS and DDE de termined for the mainstem may not hold for other areas. The technical report does however include an analysis that suggests the TSS target
for the mainstem would be effective in meeti ng human health criteria for DDT compounds in most tributaries (chlorinated pesticides and P CBs TMDL technical report, pages 84-85). A sitespecific TSS target was developed for two of th e most contaminated tributaries, Yellowhawk
Creek and the East Little Walla Walla River. At the request of the TMDL advisory group, additional language was added to submittal repor t on pages 42 and 45 that describes further
efforts to address this issue. These will be de alt with during the development of the Detailed Implementation Plan in collaborati on with the TMDL advisory group.

11.4) Response: Sep 16 th letter, Second Page, Third Paragraph, and Nov 18 th letter, Final Two Paragraphs

As a result of subsequent negotiations with CTUIR staff, Ecology has added text to the Load and
Wasteload Allocation section of the toxics submittal report (page ) that addresses this concern. The TSS targets represent Ecology’s adaptive mana gement tool for assessing the success of BMP implementation and therefore will remain where they are in the text.Page H-110 Walla Walla River Chlorinated Pesticid es and PCBs total Maximum Daily Load Submittal Report 12.) Comment:

12.1) Response:

We feel federal and state programs such as the Conservation Reserve Program (CRP), Conservation Reserve Enhanced Program (CREP) , Environmental Quality Incentives Program (EQIP), and other existing conservation progr ams serve both the producer and environment equally well. We financially support conservatio n efforts through grant programs, such as the Centennial Clean Water Fund (C CWF) and Environmental Prot ection Agency (EPA) Section 319 Funds. These grant programs are applied for a nd administered by local entities. We have committed to work with local agencies, communi ties and private landowners to attain clean water goals outlined in the TMDL. However, Ec ology retains the right to pursue enforcement
action under the Clean Water Ac t and RCW 90.48 when such action is deemed appropriate.Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Page H- 111 Submittal Report 13.) Comment:Page H-112 Walla Walla River Chlorinated Pesticid es and PCBs total Maximum Daily Load Submittal Report 13.1) Response: First Page, Second Paragraph, Second Sentence

Ecology is mandated under the Clean Water Ac t and RCW 90.48 to address water quality impairments. Washington state standards are de rived from the National Toxics Rule, and they represent levels deemed necessary to protect human health and aquatic life from the harmful effects of these known or suspected carcinogeni c substances. TMDLs do not add any furtherWalla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Page H- 113 Submittal Report regulation than already exists unde r this legislation. TMDLs evaluate water quality and devise a plan to improve water quality that may result in changes to permit limits. TMDLs focus and coordinate programs and groups already working on water quality issues to restore the water body to a healthy condition.

13.2) Response: First Page, Third Paragraph, Second to Fourth Sentences

TMDLs are not a regulatory policy. Please se e response above. Semipermeable membrane devices (SPMDs) have been show n to give results that are co mparable to other low-level sampling methods. Studies in suppo rt of this conclusion are:

Ellis et al. 1995. Evaluation of Lipid-Contai ning Semipermeable Membrane Devices (SPMDs) for Monitoring Organochlorine Contaminants in th e Upper Mississippi River. Environ. Toxicol.
Chem. 14:1875-1884.

Hyne, R. et al. 2004. Comparison of Time-Integrated Pesticide Concentrations Determined from Field-Deployed Passive Samplers with Daily River-Water Extractions. Environ. Toxicol. Chem. 23(9): 2090-2098.

Rantalainen et al. 1998. Lipid- Containing Semipermeable Membrane Devices (SPMDs) as
Concentrators of Toxic Chemicals in the Lowe r Fraser River, British Columbia. Chemosphere
37: 1119-1138.

Other low-level sampling methods were not used in the Walla Walla beca use they require using complex extraction devices in the field and give a measurement that represents only a single point in time vs. the month long deployment pe riod for SPMDs. The SPMD data collected for the TMDL were used in conjunction with conve ntional sampling of whole water grab samples, fish tissue, and WWTP effluent samples to identify and rank s ources. SPMDs are particularly well suited to this task because they provide extremely low detection limits and give good reproducibility because of thei r standardized design. The wate r quality targets and load
allocations in the TMDL were based on the conve ntional sampling data, w ith the exception that
the SPMD data were used to establish the ra tio between DDT and its breakdown products DDE and DDD. The SPMD extracts were analyzed by EPA methods.

13.3) Response: First Page, Third Paragraph, Final Sentences

Binding is primarily a function of the organic carbon content of the particles. SPMDs measure the dissolved fraction which is available for uptak e by plants and animals. This is one of the major advantages of their use over whole water samples. The EPA recommends using the
dissolved rather than total water concentration to assess bioaccumulation of pesticides and PCBs
in fish:

EPA. 2000. Methodology for Deriving Ambient Wate r Quality Criteria for the Protection of
Human Health. EAP/822/B-98/005.

It is true that SPMD data cannot be directly compared to fish ti ssue data because 1) there is no metabolic breakdown or excretion, 2) the SPMD upt akes rates are faster and their capacity greater, and 3) SPMDs seldom reach steady st ate concentrations. However when published bioaccumulation data are used in conjunction with SPMD data to predict fish tissue concentrations, the predicted and measured concentrations usually agree.Page H-114 Walla Walla River Chlorinated Pesticid es and PCBs total Maximum Daily Load Submittal Report 13.4) Response: First Page, Fourth Paragraph

The coefficient of determination or R 2 of 0.73 was for all mainstem data. The Walla Walla toxics technical report does state on page 84 that the R 2 of all the combined data (0.45) alone would not be able to predict DDE violati ons Therefore a quantile plot wa s used to confirm that a DDEbased TSS target was accurate and reas onable (page 84-86) across the watershed.

13.5) Response: Second Page, First Paragraph

The purpose of the Walla Walla TMDL submittal report is to give an overview of the chlorinated pesticides and PCBs problem in the Walla Wa lla Basin and recommend broad strategies to achieve compliance with state a nd federal water quality criteri a. Ecology acknowledges that further monitoring and land use assessments are n eeded to find locations contributing to the problem. However, this level of detail is more appropriate in the Detailed Implementation Plan (DIP) to be developed later in collaboration with the Walla Walla TMDL advisory group. Language detailing the need for additional monitoring has been added to pages 42 and 45 at the request of the Walla Walla TMDL advisory group.

13.6) Response: Second Page, Second Paragraph

The TSS load reductions allocated in this report are those Ecology has deemed necessary to achieve compliance with state and federal chlori nated pesticide and PCB water quality standards. The turbidity-based targets were calculated from all relevant data, following nationally recognized procedures, and are based on the 90 th percentile of background tu rbidities recorded at the established background turbidity location. The 90 th percentile is the turbidity exceeded by 10% of the samples. This EPA-approved approa ch allows for seasonal variation and natural generation of suspended sediment and turbidity. Adaptive management is an integral part of TMDL implementation. In the event that manage ment strategies outline in the submittal report are not successful, alternative approaches will be developed in conj unction with the TMDL advisory group and implemented.

13.7) Response: Second Page, Third Paragraph, First Sentence

As noted on page 26 of the Walla Walla toxics technical report, th e National Academy of Sciences has recommended the approach of us ing the relationship be tween a water quality indicator (pesticides in this case) and one or more predictor variab les (TSS and turbidity in this case) as a ”simple and useful model for developi ng TMDLs”. The TSS and turbidity targets were developed as tools to be used in monitoring progress toward achi eving water quality standards.
As described in the technical report (page 83), “Setting water qua lity targets based on TSS and turbidity has the advantage of translating more dir ectly to land use practices and being easier and less expensive to monitor than trace chemical concentrations. Additionally, TSS and turbidity
levels in river and streams have a direct and quantifiable effect on the health of fish and other aquatic organisms, as well as aesthetic values.” The ultimate objective of this TMDL is to meet state pesticide/PCB criteria a nd turbidity standards. The tech nical study determined that the turbidity targets are necessary in order to ac hieve state water quality criteria in Washington Administrative code 173-201A. The TSS goals are necessary to protect people who consume large amounts of fish.Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Page H- 115 Submittal Report 13.8) Response: Second Page, Third Paragraph, Remaining Sentences

Washington state water quality st andards define background as “t he biological, chemical, and physical conditions of a waterbody, outside the area of influence of the discharge under consideration.” Background for the Walla Walla River was established during the technical study
at the state line to reflect minimal human influe nces on water quality. The turbidity targets are based on samples taken from this location. TMDL targets are the amount of pollution that needs to be reduced to meet existing state standards.

14.) Comment:

14.1) Response:

Please see previous responses to 13. Mr. Greg Farrens, Mr. Robert Hutchens, Mr. Jack Myrick,
and Dr. Roland Schirman. Several efforts were ma de to obtain representa tive data. Sampling for the TMDL technical study occurred from May 2002 until September 2003. During this time, fish tissue samples were collected, grab samples from the river and tributaries were taken, samples from the treatment plants were taken, and devices put into the water collected data for 30 days. In addition, any available historic data was sought. Monitoring will continue to be an important part of the efforts to reduce ch lorinated pesticides in the watershed.Page H-116 Walla Walla River Chlorinated Pesticid es and PCBs total Maximum Daily Load Submittal Report The majority of the implementation activitie s or best management practices (BMPs) recommended in the report were taken from the Walla Walla Watershed Plan. These BMPs have already been applied by farming communities across the state including the Walla Walla drainage to good effect. The Submittal Report acknowledges watershed residents’ efforts to improve water quality through the implementation of BMPs and enc ourages more of the same.

There are no natural sources of chlorinated pesticides or PCBs, but these man-made compounds do bind to soil particles. The tu rbidity targets in the TMDL are necessary to meet current state water quality standards and do not result in new regulations. The submittal report assigned TSS
load allocations to 10 tribut aries in addition to two for the upper and lower Walla Walla mainstem. Data collected during Ecology’s 2002- 2003 study suggests that th e pesticide problem is not isolated, but extends to varying degrees across the Walla Walla Basin (with the exception of the Touchet River drainage where the chemicals in question were not widely used historically). Refinement of th e TSS targets may occur as a re sult of further monitoring during implementation.

Financial assistance is needed to help watershed residents im prove water quality. Some funding sources the agricultural industr y may use to apply BMPs are mentioned on page 51 of the Submittal Report. Since TMDLs are neither a general permit nor a rule, economic impact statements are not a requirement. Economic impact statements, cost-benefit analyses, or economic analyses mandated by the Regulatory Fairness Act [Revised Code of Washington (RCW) 19.85] and Administrative Procedure Act (RCW 34.05) apply on ly to rules. In addition, the TMDL does not propose a specific cour se of action for a specific location.Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Page H- 117 Submittal Report 15.) Comment:

15.1) Response: Second Paragraph

The time frame for technical studi es conducted by Ecology is typica lly one year. Because a large number of samples were analyzed and the range of flows that occurred during the study included the normal range of flows, Ecology cons iders the study to be credible.Page H-118 Walla Walla River Chlorinated Pesticid es and PCBs total Maximum Daily Load Submittal Report 15.2) Response: Third Paragraph

The correlation between turbidity and toxics was demonstrated in the technical study suggests that reducing turbidity levels will decrease toxic concentrat ions. Ecology acknowledges that further monitoring and land use assessments are need ed to find areas cont ributing to the problem. Language detailing the need for additional monitoring has been added to pages 42 and 45 at the request of the Walla Walla TMDL advisory group. Many of the st rategies to reduce chlorinated pesticides and PCBs would also reduce turbidity levels. The TSS targets represent the minimum reductions necessary to meet state standards.

15.3) Response: Fourth Paragraph

Financial assistance is needed to help watershed residents im prove water quality. Some funding sources the agricultural industr y may use to apply BMPs are mentioned on page 51 of the Submittal Report. Since TMDLs are neither a general permit nor a rule, economic impact statements are not a requirement. Economic impact statements, cost-benefit analyses, or economic analyses mandated by the Regulatory Fairness Act [Revised Code of Washington (RCW) 19.85] and Administrative Procedure Act (RCW 34.05) apply on ly to rules. In addition, the TMDL does not propose a specific c ourse of action for a specific location.

15.4) Response: Fifth Paragraph

Thank you for supporting the implementation strategyWalla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Page H- 119 Submittal Report 16.) Comment:Page H-120 Walla Walla River Chlorinated Pesticid es and PCBs total Maximum Daily Load Submittal ReportWalla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Page H- 121 Submittal Report 16.1) Response : Pg 4: Change made

16.2) Response : Pg 5: Change made

16.3) Response : Pg 6, First Comment: Change made

16.4) Response : Pg 6, Second Comment: Addition madePage H-122 Walla Walla River Chlorinated Pesticid es and PCBs total Maximum Daily Load Submittal Report 16.5) Response : Pg 8, First Comment: The sample size in Ecology’s 2002-2003 water quality study met Washington Department of Health requirements. In addition the study methods, analysis and conclusions were subjected to exte nsive internal peer revi ew and EPA review and
found sound.

16.6) Response : Pg 8, Second Comment: Changed to ‘the chief means’. The technical report found that the legacy chemicals addressed in th is TMDL have bound with soil particles and are entering surface waters primarily through soil eros ion from adjacent lands (where the chemicals were historically applied). Th e positive correlation between suspended sediments and toxic chemeicals is the foundqation for this conclusi on. While other measures can and ought to be taken, reducing the amount of soil entering surface wa ters is certainly the most important step to
take.

16.7) Response : Pg 8, Third Comment: Addition made

16.8) Response : Pg 17, First Comment: Addition made

16.9) Response : Pg 17, Second Comment: See respons e to Dr. Schirman’s comments 3.2) Third Paragraph. Change made to the text for clarification.

16.10) Response : Pg 22: See response to Pg 8, Second Comment.

16.11) Response : Pg 35: See response to Dr. Schirman’s comments 3.2) Third Paragraph.

16.12) Response : Pg 36, First Comment: See response to 16.6) Pg 8, Second Comment and 16.9) Pg 17, Second Comment above. Background tu rbidity was assessed following standard Ecology procedure. Also see response to Mr . Farrens, Mr. Hutchens, Mr.Myrick, and Dr. Schirman, 13.7) and 13.8) Second Page, Third Paragraph. Sufficient turbidity and suspended
sediment data were obtained to obtain the conc lusions in the submittal report. No significant
stream bottom sediment sinks were identif ied during Ecology’s 2002-2003 study with the exception of the Columbia River backwater in the lower Walla Walla River mainstem. This area is addressed on page 50, first bullet of the submittal report.

16.13) Response : Pg 36, Second Comment: The data collected for this TMDL study show that there is a statistically significant positive rela tionship between Total Suspended Sediments (TSS) and chlorinated pesticides. Those areas such as the Touchet River drainage which did not see historically high levels of pesticide applicati on would not be expected to see high levels of chlorinated pesticides in the water column. Howe ver, even those waterbodi es that do not show exceedances for chlorinated pesticides may still require TSS reductions to meet water quality criteria for turbidity – as is the case for the Touchet River.

16.14) Response : Pg 37, First Comment: The paragraph in question defines the summary implementation strategy and is standard languag e used in all TMDLs. A description of the implementation strategy to be used follows this paragraph. Ecology acknowledges and is appreciative of the voluntary im plementation of water quality remedi al projects that have already taken place in the Walla Walla River drainage. Th e data collected in this study indicates that
much work remains to be done to achieve co mpliance with state water quality standards. Ecology will continue to seek collaborativ e and cooperative solutio ns to water quality impairments in the drainage by offering technical and financial assistan ce. However, under RCW 90.48 and the federal Clean Water Act Ecology is responsible for ensuring clean water and retains the right to pursue enfor cement actions where appropriate.Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Page H- 123 Submittal Report 16.15) Response : Pg 37, Second Comment: Addition made

16.16) Response : Pg 38, First Comment: Change made

16.17) Response : Pg 38, Second Comment: See respons e to Pg 8, Second Comment above.

16.18) Response : Pg 39: Change made

16.19) Response : Pg 41, First Comment: Most private a nd public forestry lands in the Walla Walla drainage are situated in Oregon, hence Oregon can reasonably be expected to see more forestry related activities. In addition, forest ry activities are restricted in the Mill Creek headwaters since it is a designated municipal waters hed. The text of the repor t has been clarified.

16.20) Response : Pg 41, Second Comment: Addition made

16.21) Response : Pg 41, Third Comment: Change made

16.22) Response : Pg 43: TMDLs are required for wate r bodies included on the 303(d) list and therefore are not voluntary. Target s are required parts of submitt al reports and represent the amount that pollutants must be reduced in order to meet water quality sta ndards. As such targets are not voluntary. S ee also response under 16.14) Pg 37, First Comment above.

16.23) Response : Pg 45: Change made

16.24) Response : Pg 49, First Comment: Change made

16.25) Response : Pg 49, Second Comment: These areas have been identified as potential sample sites for evaluating whether or not the TM DL targets are being met. In order to determine if the TMDL targets are being met, monitoring s hould be conducted at sites comparable to those used in the technical study. The suggested sampling sites in ques tion would represent comparable sampling locations. However, there is no obligation on Ecology or the TMDL advisory group to use these sample sites should th ey decide otherwise later. Also this does not preclude the inclusion of additional sample sites should it be deemed necessary.

16.26) Response : Pg 50, First Comment: Change made

16.27) Response : Pg 50, Second Comment: Addition made

16.28) Response : Pg 51, First Comment: Addition made

16.29) Response : Pg 51, Second Comment: The scope and purpose of future monitoring projects has yet to be determined, so it is not possible to say at this stage where the additional sampling sites will be located. This is something that will have to be determined when planning
individual studies. See also 16.25) response to Pg 49, Second Comment above.

16.30) Response : None of the chemical compounds that are addressed in this TMDL occur naturally in the environment, and as such no natural background exists for them. All the
chemicals addressed in this report are known or presumed carcinogens, persistent in the environment, and bioaccumulate in animal tissu e and therefore represen t serious threats to human and aquatic life. In order to reflect the amount of turbidity that occurs naturally, human
influences must be minimal to none existent. In this study, background was set at state line to include only that turbid ity that is the result of processes within the study area. This background turbidity level was included in the calculation of TSS targets. Because background levels ofPage H-124 Walla Walla River Chlorinated Pesticid es and PCBs total Maximum Daily Load Submittal Report turbidity were assessed dur ing the study and factored into the ta rgets, naturally occurring levels of turbidity are not included in the margin of safety discussion.

16.31) Response : Turbidity background levels were dete rmined using an approved procedure, in accordance with state legislation that has be en used in similar TMDLs. The methods applied in this TMDL have been subj ected to internal peer review and EPA review and found sound. Also see Ecology’s responses to the Columb ia Blue Mountain Farm Bureau’s comment 15.2) Third Paragraph and response to Mr. Farrens, Mr. Hutc hens, Mr. Myrick, and Dr. Schirman

comment 13.6), 13.7) and 13.8) Second Page, Second Paragraph and Third Paragraph.

16.32) Response : All 303(d) listings on the Washington si de of the watershed are addressed in this TMDL. Each major tributary has been given a load allocation to achieve, so implementation
activities can be customized based on the sources of chlorinated pesticides and/or PCBs found in each tributary. The report recommends that priority areas for remedial work be identified during the development of the Detailed Implementation Plan (DIP).

16.33) Response : This report has referenced and draw n extensively from the WRIA 32 Planning Unit Plan. Ecology is committed to continuing to work cooperatively and collaboratively with the Watershe d Planning group as far as possible to achieve compliance with the water quality criteria.Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Page H- 125 Submittal Report 17.) Comment:Page H-126 Walla Walla River Chlorinated Pesticid es and PCBs total Maximum Daily Load Submittal ReportWalla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Page H- 127 Submittal ReportPage H-128 Walla Walla River Chlorinated Pesticid es and PCBs total Maximum Daily Load Submittal ReportWalla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Page H- 129 Submittal ReportPage H-130 Walla Walla River Chlorinated Pesticid es and PCBs total Maximum Daily Load Submittal ReportWalla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Page H- 131 Submittal Report 17.1) Response - 2 : The WWTP wasteload allocations for PCBs were based on treatment plant flow and the human health water qu ality criterion. It is true that different methods were used to sample and analyze the receiving waters. The wasteload allocations for the WWTPs were determined by comparing PCB levels detected in the effluent with state water quality criteria. The receiving water PCB data were used only to put the WWTP PCB contri bution in perspective
and were not used in the cal culation of the WWTP wasteload allocations. Furthermore, thePage H-132 Walla Walla River Chlorinated Pesticid es and PCBs total Maximum Daily Load Submittal Report WWTP and receiving water PCB loads differed by an order of magnitude or more. Therefore the
fact that different methods were used in thei r measurement does not seem to be a significant

concern.

17.2) Response 3a, 3f, 3g, 4 : The calculation procedures for total PCBs are detailed in EPA Method 1668A. The complete text of the method can be found at http://synectics.net/resources/
and http://www.epa.gov/sw-846/main.htm . Environmental chemical data are normally not blank
corrected therefore the Department of Ecology does not blank correct. With regard to the 5x rule: the general concept is that if the concentration in a sample is greater than 5 times the method blank, then it is assumed that most of the chem ical is native to the sample, no more than 20% being due to blank contamination. In that instance the data are re ported without blank correcting. If the method blank is higher, then the reporting limit must be raised. PCB congener data are usually not blank correct ed. Blank correcting can be done, but only if large numbers of blanks are analyzed in conjunction with each sample set. Section 17.6.1.4.4 of EPA Method 1668A for analyzing PCB congeners states that: “Blank-corrected results may be reported in addition to reporting of separate results fo r samples (Section 17.6.1.4.1) and blanks (Section 17.6.1.4.2). The recommended procedure for blank correc tion (Reference 20) is that a result is significantly above the blank level, and the level in the blank may be subtracted, if the result is greater than the mean plus 2 standa rd deviations of results of anal yses of 10 or more blanks for a sample medium.” The analyses conducted fo r the Walla Walla WWTPs followed the usual procedure of having a single method blank with each set of samples. Therefore the procedures to
blank correct and calculate total PCB concentra tions for the WWTP effluent samples are not appropriate in this case.

17.3) Response 3b: The conclusion about low accuracy appears to stem from inappropriately blank correcting the data. Total PCB concentr ations during this sa mpling event were in reasonable agreement. Two side-by-side samp les were prepared over a two-day period by compositing subsamples of the effluent; one of the samples was split. The split results were 0.79 and 0.74 ng/L, for an average of 0.76 ng/L. The othe r sample had 1.0 ng/L. The result used in the technical report was the average of the latt er two values, 0.88 ng/L. Considering these measurements were being made at the sub-parts per trillion level and that the TMDL technical study extended over a one-year period, consiste nt results were obtained for both WWTPs. Total PCBs ranged from 0.75 – 0.88 ng/L in the Walla Walla effluent and 0.53 – 2.5 ng/L in the College Place effluent. College Place was experiencing an upset fo r part of the study and this may have contributed to the wider variation. Also see responses to 17.2) 3a, 3f, 3g,4.

17.4) Response 3c : Unclear what error is being referre d to here, unless it stems from blank correcting the data. The laborat ory reported a total PCB concen tration of 1290 pg/L. The TMDL technical report shows a value of 1.3 ng/L (1,290/1,000 = 1.290 ng/L rounded to 1.3 ng/L).

17.5) Response 3d : The Walla Walla total PCB concentrations shown in the technical report - 0.88 ng/L (May 02), 0.65 ng/L (Sept. 05) 0.75 ng/L (Dec. 05) 0.87 ng/L (Feb. 05) - do not appear to decrease significantly.Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Page H- 133 Submittal Report 17.6) Response 3e : The College Place total PCB concentr ations shown in the technical report were 2.5 ng/L (May 02), 0.92 ng/L (Sept. 05) 1.3 ng/L (Dec. 05) 0.53 ng/L (Feb. 05). College Place experienced some upsets during 2002 wh ich may have caused this variation.

17.7) Response 5 : See responses to Mr. Slovensky’s comments 2.1) First Page, First Bullet.

17.8) Response 6., 6a, 6b, 6c, 6d, 7, 7a, 7b : See responses to 3a above and Ms McConville’s

comments 7.5) Fourth Paragraph, Final sentence , and Mr. Nicholsn’s comment 8.9) #9 . Washington state’s chlorinated pesticide and P CB water quality criteria are promulgated by the
EPA National Toxics Rule. The load and wastel oad allocation assigned in this report were calculated as those necessary to achie ve compliance with these criteria.

17.9) Response 8 : We agree it would be inaccurate to assess the potential impact of Walla Walla WWTP by comparison to the loading capacity of the mainstem, which was calculated in the technical report using the harmonic mean for the period of record. However, as described on page 102, the loading capacity for PCBs in Mill Cr eek and assessment of the relative impact of
Walla Walla WWTP was based on the harmonic mean flow in Mill Creek for December through April.

17.10) Response 9 : See responses to Mr. Slovensky’s comments 2.9) and 2.10) Third Page,
First and Second Bullet ; Ms McConville’s comments 7.1) Second Paragraph

, First Sentence and 7.6) Second Page, Final Two Paragraphs, Mr. Nicholson’s comment 8.2) #2, and Mr. Putnam’s

comment 9.2) #2.

17.11) Response 10 : See responses to Mr. Slovensky’s comment 2.1) First Page, First Bullet

, and 2.7) Third Page, Second Point, and Mr. Nicholson’s comment 8.3) #3.

17.12) Response : Summary, Fourth Bullet : The Walla Walla WWTP will most likely have pretreatment authority in 2007, making assessmen t of the wastewater collection system the responsibility of the WWTP. We agree that an assessment of th e collection system would be good initial step in addressing the PCB problem.Page H-134 Walla Walla River Chlorinated Pesticid es and PCBs total Maximum Daily Load Submittal Report 18.) Comment:Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Page H- 135 Submittal Report 18.1) Response : Second Paragraph - See response to Columbia Blue Mountain Farm Bureau’s

comments 15.1) Second Paragraph. Data Ecology collected during the 2002-2003 sampling period show there is a significant chlorinated pe sticides and PCBs water quality problem that needs to be addressed. Data suggest that th e problem is too large to be an anomaly.

18.2) Response : Third Paragraph - See previous responses to 1.1) Mr. Fishella’s comments, Dr. Schirman’s comments, 3.1) Second Paragraph and 3.4) Fifth Paragraph

, 10.1) Louis Riley and Janice Riley’s comments #1, 12.1) Mr. Bishop’s comments, Mr. Farrens, Mr. Hutchens, Mr. Myrick, and Dr.Schirman’s comments 13.1) First Page, Second Paragraph, Second Sentence, 13.6) Second Page, Second Paragraph, 13.7) Second Page, Third Paragraph, 14.1) Keith Farrens comments, and Columbia Blue Mountain Farm Bureau’s comments 15.1) Second Paragraph.

18.3) Response : Fourth Paragraph - Fish tissue samples have been analyzed on three separate occasions over a recent 10-year period - 1992, 1993, and 2002 - and all of th ese investigations found impaired levels of chlo rinated pesticides and PCBs.Page H-136 Walla Walla River Chlorinated Pesticid es and PCBs total Maximum Daily Load Submittal Report 19.) Comment: (Note: The following comments were rece ived shortly after the close of the public comment period, but because we feel they elucidate Mr. Hutchens’ previous comments and raise some additional important points, we include them here.)

19.1) Response : (1) No. Turbidity can be elevated without a violation of PCB or CP standards,
if none of the constituen ts causing the turbidity c ontain PCBs or CPs.

19.2) Response : (2) The TMDL did not set a standard for turbidity; that standard already exists. The turbidity standard has been part of the stat e’s surface water quality standards for decades and can be found at WAC 173-201A-030( 1) and (2) [for Class AA and Class A waters]. The state’s turbidity standard is not an absolute value, but sets a maximum allowable change in turbidity based on an estimate of background turbidity leve ls. This was the basis for setting the TSS targets for turbidity compliance in the Walla Walla TMDL. The TMDL also recommends TSS targets that can be used as surrogates to tr ack changes in chlorinated pesticide levels.

19.3) Response : (3) See answer to Keith Farrens, 14.1) Walla Walla County Farm Bureau regarding random vs. timed sampling.Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Page H- 137 Submittal Report 19.4) Response : (4) The PCB/Chlorinated Pesticide study was designed to collect the necessary information needed to develop a TMDL, but stil l stay within a reasona ble budget. The costs of laboratory analyses for PCBs and chlorinated pesticides are much higher than for fecal coliform. It would have been prohibitively expensive to conduct fecal coliform like sampling for the toxics
TMDL. The focus of the toxics TMDL was on th e Walla Walla mainstem because that was the waterbody on the 303(d) list. The Touchet was not on the 303(d) list for pesticides or PCBs.

19.5) Response : (5) The large volume of water that the Touchet River contributes to the Walla
Walla mainstem has a cumulative dilution effect on the mainstem. However, data collect on the Touchet River indicates that the river is impair ed for turbidity. All streams must meet water quality standards to protect beneficial uses, ther efore the Touchet River st ill needs to meet TSS targets for turbidity compliance.

19.6) Response : (6) Yes. One monitoring station at the mouth of the Touchet River is sufficient
to make a determination as to whether the Touc het is a source of chlorinated pesticides, PCBs, TSS, and turbidity to the Walla Walla River. One s ite is not sufficient to determine what parts of
the Touchet watershed are c ontributing to the problem. 19.7) Response : (7) More restrictive targets were reco mmended for the East Little Walla Walla River and Yellowhawk Creek because pesticide leve ls were clearly much higher than in other tributaries. The technical repo rt acknowledges that the basin- wide TSS/turbidity targets are overprotective for pesticides in the Touchet, but maintains that it is appropriate to apply them here because of the Touchet’s role in turbidity exceedances in the mainstem and for protection of fish and wildlife habitat (page 96). These stream s need to meet water quality standards for turbidity as well as for PCBs and chlorinated pesticides. 19.8) (8) Both watersheds showed a relationship between TSS, turbidity, and pesticides. The correlation exists irrespective of farming method s. The type of agriculture being practiced factors into remedies for the problem. 19.9) (9) Since TMDLs must be approved by a federal agency, they do not meet the definition of action under SEPA [Washington Administar tive Code (WAC) 197.11.704(2 )(b)(3)]; therefore there is no responsibility to complete an enviro nmental impact statement. TMDLs are also not considered to be a major federal action re quiring NEPA analysis, as defined by EPA’s implementing regulation for the NEPA program at 40 CFR Part 6; therefore NEPA analyses are no completed for TMDLs. However, individual projects constructed to implement the TMDL may require SEPA/NEPA review. In other words, an environmental impact statement is not required since a specific course of action has not b een proposed for a sp ecific location. 19.10) (10) It is true that the Walla Walla Wa tershed Planning Unit and various other entities
focused on flow related issues have received more financial assistance than the TMDL advisory group and other entities working on water qualit y issues to date. Water quantity has often
received more attention than quality across Eastern Washingt on due to the relatively arid conditions experienced there and the need to meet growing agricultural and urban needs. However, it should be also noted that the Wa lla Walla Watershed Planning Unit has been in existence far longer than the TMDL advisory group, and is further along towards project implementation than the TMDL process is. It is hoped that as the TMDL process moves closer towards project implementation there will be a ri se in the number of water quality specific projects funded. Recently the Walla Walla Water Management Initiative began with the aim toPage H-138 Walla Walla River Chlorinated Pesticid es and PCBs total Maximum Daily Load Submittal Report foster more cooperative and coll aborative water management in the area, and water quality concerns will play an importa nt role in this process.

19.11) Response : (11) The Watershed Planning process is mandated by Washington state law, as a means to achieve locally driven management of water resources. Water quantity is the focus of such groups although water quality concerns are sometimes considered (See response to

comment 19.10) # 10 above). Ecology is delegated aut hority to manage the federally mandated TMDL process. As such Ecology is required to ensure that water quality impairments are addressed and is responsible for achieving co mpliance with state and federal water quality criteria. Therefore, unlike in the Watershed planning process, Ecol ogy retains control and decision making authority for setting TMDLs. However, Ecology recognizes that local knowledge and support of the process are esse ntial for success and strives to get public involvement and input through entities like the TMDL advisory groups. Ecology is committed to working cooperatively and collabo ratively with local communities and other entities to achieve water quality improvements.Walla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Page H- 139 Submittal Report 

# Appendix I

Public Participation MaterialsPage H-140 Walla Walla River Chlorinated Pesticid es and PCBs total Maximum Daily Load Submittal ReportWalla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Page H- 141 Submittal ReportPage H-142 Walla Walla River Chlorinated Pesticid es and PCBs total Maximum Daily Load Submittal ReportWalla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Page H- 143 Submittal ReportPage H-144 Walla Walla River Chlorinated Pesticid es and PCBs total Maximum Daily Load Submittal ReportWalla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Page H- 145 Submittal ReportPage H-146 Walla Walla River Chlorinated Pesticid es and PCBs total Maximum Daily Load Submittal ReportWalla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Page H- 147 Submittal ReportPage H-148 Walla Walla River Chlorinated Pesticid es and PCBs total Maximum Daily Load Submittal ReportWalla Walla River Chlorinated Pesticides and PCBs Total Maximum Daily Load Page H- 149 Submittal Report

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