Palouse River 

 Chlorinated Pesticide and PCB 

Total Maximum Daily Load 

Water Quality Improvement Report 

and 

Implementation Plan

July 2007 

Publication No. 07-03-018 
Publication Information 

This report is available on the Department of Ecology’s website at 

www.ecy.wa.gov/biblio/0703018.html 

For more information contact: 

Publications Coordinator 

Environmental Assessment Program 

P.O. Box 47600 

Olympia, WA 98504-7600 

E-mail: jlet461@ecy.wa.gov

Phone: (360) 407-6764 

Washington State Department of Ecology - www.ecy.wa.gov/

o Headquarters, Lacey 360-407-6000 

o Northwest Regional Office, Bellevue 425-649-7000 

o Southwest Regional Office, Lacey 360-407-6300 

o Central Regional Office, Yakima 509-575-2490 

o Eastern Regional Office, Spokane 509-329-3400 

Data for this project are available at Ecology’s Environmental Information Management (EIM) 

website at www.ecy.wa.gov/eim/index.htm. Search User Study ID AJOH0046 (2005 fish tissue 

samples and 2004 river water samples) or BRWA0001 (2005-2006 Pullman stormwater 

samples). 

Ecology’s Project Tracker Code for this study is 05-008-01. 

Any use of product or firm names in this publication is for descriptive purposes only and does 

not imply endorsement by the author or the Department of Ecology. 

If you need this publication in an alternate format, call Joan LeTourneau at (360) 407-6764. 

Persons with hearing loss can call 711 for Washington Relay Service. Persons with a speech 

disability can call 877-833-6341. 

Cover photo: Electrofishing in the North Fork Palouse River (Elaine Snouwaert) 

 
Palouse River 

Chlorinated Pesticide and PCB 

Total Maximum Daily Load 

Water Quality Improvement Report 

and 

Implementation Plan 

by 

Art Johnson, Brandee Era-Miller, and Kristin Kinney 

Environmental Assessment Program 

Olympia, Washington 98504-7710 

and 

Elaine Snouwaert 

TMDL/Watershed Unit 

Water Quality Program – Eastern Region 

Spokane, Washington 98205-1295 

Waterbody Numbers: Palouse River (WA-34-1010), 

S.F. Palouse River (WA-34-1020), N.F. Palouse River (WA-34-1030) 
This page is purposely left blank
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan

Page i 

Table of Contents 

Page

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

Glossary and Acronyms.......................................................................................................v 

Abstract................................................................................................................................1 

Acknowledgements..............................................................................................................2 

Executive Summary.............................................................................................................3 

Background....................................................................................................................3 

Study Area .....................................................................................................................3 

Applicable Water Quality Criteria.................................................................................3 

Numerical TMDL Targets .............................................................................................4 

Recent Ecology Studies .................................................................................................4 

TMDL Analysis .............................................................................................................5 

Monitoring Plan .............................................................................................................7 

Recommendations..........................................................................................................8 

Implementation ..............................................................................................................8 

Part 1 ..................................................................................................................................11 

What is a Total Maximum Daily Load (TMDL)? .............................................................13 

Federal Clean Water Act Requirements ......................................................................13 

TMDL Process Overview ............................................................................................13 

Elements Required in a TMDL....................................................................................14 

Total Maximum Daily Load Analyses: Loading Capacity..........................................14 

Why is Ecology Conducting a TMDL Study in This Watershed?....................................15 

Overview......................................................................................................................15 

Study Area ...................................................................................................................15 

Pollutants Addressed by This TMDL Study and Implementation Plan.......................18 

Water Quality Standards and Beneficial Uses...................................................................21 

Beneficial Uses ............................................................................................................21 

Toxic Substances .........................................................................................................21 

Water Quality Criteria..................................................................................................22 

Numeric TMDL Targets ..............................................................................................23 

Review of Historical Pesticide/PCB Data..........................................................................25 

Recent Department of Ecology Studies .............................................................................31 

Low-level Pesticide Analysis.......................................................................................31 

Expanded Fish Tissue Survey......................................................................................34 

Stormwater Pilot Study................................................................................................38 

Evaluation of Other Potential Sources...............................................................................41 

NPDES Discharges ......................................................................................................41 

Hazardous Waste/Toxics Cleanup Sites ......................................................................43 

Abandoned Landfills/Dumps.......................................................................................44 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan

Page ii 

TMDL Analysis .................................................................................................................45 

Loading Capacity.........................................................................................................45 

Wasteload and Load Allocations .................................................................................47 

Margin of Safety ..........................................................................................................49 

Achieving Water Quality Standards ............................................................................49 

Seasonal Variation .......................................................................................................53 

Recommendations........................................................................................................53 

Part 2 ..................................................................................................................................55 

Implementation Plan ..........................................................................................................57 

Introduction..................................................................................................................57 

What Needs to be Done?..............................................................................................57 

Who Needs to Participate?...........................................................................................59 

What is the Schedule for Achieving Water Quality Standards?..................................67 

Reasonable Assurances................................................................................................67 

Measuring Progress Toward Goals (Monitoring Plan)................................................68 

Adaptive Management.................................................................................................69 

Potential Funding Sources ...........................................................................................70 

Summary of Public Involvement Methods ..................................................................73 

References..........................................................................................................................75 

Appendices.........................................................................................................................79 

Appendix A. Biological Information on Fish Samples...............................................81 

Appendix B. Contaminant Data on Fish Samples ......................................................89 

Appendix C. Tracking Tables.....................................................................................97 

Appendix D. Response to Comments .......................................................................105 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan

Page iii 

List of Figures and Tables 

 Page

Figures 

Figure 1. Palouse River Basin...........................................................................................16 

Figure 2. Mean Monthly Flows in the Palouse River .......................................................17 

Figure 3. Location of Water Samples Collected by Ecology in May 2004. .....................32 

Figure 4. Location of Fish Samples Collected by Ecology in May - August 2005..........34 

Figure 5. Mean Total PCB Concentrations in Palouse River Fish Compared to 

Freshwater Edible Fish Tissue Samples Collected Statewide ...........................................37 

Figure 6. One-Day Precipitation Probabilities in Pullman, WA.......................................38 

Figure 7. Pullman Area Showing Sampling Sites for 2005-06 Stormwater Pilot Study..39 

Figure 8. Time Trends in Levels of 303(d) Listed Pesticides and PCBs in Fillets 

from Lower Palouse River Fish .........................................................................................51 

Tables

Table ES- 1. Numerical Targets for the Palouse River Chlorinated Pesticide and 

PCB TMDL..........................................................................................................................4 

Table ES- 2. Loading Capacity Status for 303(d) Listed Pesticides and PCBs in the 

Palouse River, Based on Fish Tissue Concentrations and EPA Bioconcentration 

Factors..................................................................................................................................5 

Table ES-3. Wasteload and Load Allocations for the Palouse River .................................6 

Table ES-4. Estimates of Reductions Needed in Fish Tissue Concentrations of 

Dieldrin and PCBs to Meet Water Quality Standards in the Palouse River ........................7 

Table 1. Palouse River 303(d) Listings for Toxics in Edible Fish Tissue 

(2002/2004 list)..................................................................................................................19 

Table 2. Additional River Segments Found to be Impaired by Dieldrin and PCBs 

During Ecology’s 2005 Fish Tissue Study ........................................................................19 

Table 3. Washington State Water Quality Criteria for Chlorinated Pesticides and 

PCBs Detected in the Palouse River Basin........................................................................22 

Table 4. Numerical Targets for the Palouse River Chlorinated Pesticide and 

PCB TMDL........................................................................................................................24 

Table 5. Historical Ecology Data on Chlorinated Pesticides and PCBs Detected in 

Palouse River Fish .............................................................................................................26
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan

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Table 6. USGS Data on Chlorinated Pesticides and PCBs Detected in Whole Body 

Samples of Largescale Suckers Collected from the Palouse River Basin in 1992 

and 1994.............................................................................................................................27 

Table 7. USGS Data on Chlorinated Pesticides and PCBs Detected in Sediment 

Samples Collected from the Palouse River Basin in 1992 and 1994................................27 

Table 8. USGS Data on Chlorinated Pesticides Detected in Water Samples Collected 

from the Palouse River Basin in 1993-95..........................................................................28 

Table 9. Results of a Low-Level Analysis for Chlorinated Pesticides in the Palouse 

River Water Samples Collected by Ecology on May 11, 2004 .........................................33 

Table 10. Mean Concentrations of 303(d) Listed Pesticides and PCBs in Palouse 

River Fish Fillets Analyzed by Ecology in 2005 Compared to Human Health Criteria....35 

Table 11. Concentrations of 303(d) Listed Pesticides and PCBs in Pullman 

Stormwater Samples Collected in 2005-06........................................................................40 

Table 12. Washington WWTPs that Discharge to Surface Water in the Palouse 

River Basin.........................................................................................................................41 

Table 13. Results of a Chlorinated Pesticide and PCB Analysis on a Composite 

Effluent Sample Collected from the Pullman WWTP on October 9, 1999.......................42 

Table 14. Hazardous Waste/Toxic Cleanup Sites Evaluated for the Palouse River 

Chlorinated Pesticides and PCB TMDL............................................................................43 

Table 15. Loading Capacity of the Palouse River for 303(d) Listed Pesticides and 

PCBs ..................................................................................................................................45 

Table 16. Loading Capacity Status of the Palouse River, Based on Fish Tissue 

Concentrations of 303(d) Listed Pesticides and PCBs ......................................................46 

Table 17. Wasteload and Load Allocations for Dieldrin and PCBs in the Palouse 

River...................................................................................................................................47 

Table 18. PCB and Dieldrin Interim Wasteload Allocations for Palouse River 

Wastewater Treatment Plants ............................................................................................48 

Table 19. Comparison of Historical and Recent Data on 303(d) Listed Pesticides 

and PCBs in Lower Mainstream Palouse River Fish (ug/Kg, wet weight) ......................50 

Table 20. Estimates of Reductions Needed in Fish Tissue Concentrations of Dieldrin 

and PCBs to Meet Water Quality Standards in the Palouse River ....................................52 

Table 21. 2004 303(d) Listings Recommended for a Category 1 Classification..............58 

Table 22. Activities and Resources to Reduce Dieldrin and PCBs ..................................65 

Table 23. Potential Funding Sources for Implementation Projects ..................................70 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan

Page v 

Glossary and Acronyms 

Glossary 

303(d) list: Section 303(d) of the federal Clean Water Act requires Washington State 

periodically to prepare a list of all surface waters in the state for which beneficial uses of the 

water – such as for drinking, recreation, aquatic habitat, and industrial use – are impaired by 

pollutants. These are water quality limited estuaries, lakes, and streams that fall short of state 

surface water quality standards, and are not expected to improve within the next two years. 

Best Management Practices (BMPs): Physical, structural, and/or operational practices that, 

when used singularly or in combination, prevent or reduce pollutant discharges. 

Clean Water Act: Federal act passed in 1972 that contains provisions to restore and maintain 

the quality of the nation’s waters. Section 303(d) of the Clean Water Act establishes the TMDL 

program. 

Designated Uses: Those uses specified in Chapter 173-201A WAC (Water Quality Standards 

for Surface Waters of the State of Washington) for each waterbody or segment, regardless of 

whether or not the uses are currently attained. 

Existing Uses: Those uses actually attained in fresh and marine waters on or after November 

28, 1975, whether or not they are designated uses. Introduced species that are not native to 

Washington, and put-and-take fisheries comprised of non-self-replicating introduced native 

species, do not need to receive full support as an existing use. 

Harmonic Mean Flow: One of several methods of calculating an average rate of flow. The 

harmonic mean is defined as Qh = n/∑(1/Qi) where n is the number of recorded flows Qi. 

The harmonic mean is never larger than the geometric mean or the arithmetic mean. 

Load Allocation (LA): The portion of a receiving waters’ loading capacity attributed to one or 

more of its existing or future sources of nonpoint pollution or to natural background sources. 

Loading Capacity: The greatest amount of a substance that a waterbody can receive and still 

meet water quality standards. 

Margin of Safety: Required component of TMDLs that accounts for uncertainty about the 

relationship between pollutant loads and quality of the receiving waterbody. 

Municipal Separate Storm Sewer Systems (MS4): A conveyance or system of conveyances 

(including roads with drainage systems, municipal streets, catch basins, curbs, gutters, ditches, 

manmade channels, or storm drains): (i) owned or operated by a state, city, town, borough, 

county, parish, district, association, or other public body having jurisdiction over disposal of 

wastes, storm water, or other wastes and (ii) designed or used for collecting or conveying 

stormwater; (iii) which is not a combined sewer; and (iv) which is not part of a Publicly Owned 

Treatment Works (POTW) as defined in the Code of Federal Regulations at 40 CFR 122.2. 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan

Page vi 

National Pollutant Discharge Elimination System (NPDES): National program for issuing, 

modifying, revoking and reissuing, terminating, monitoring and enforcing permits, and imposing 

and enforcing pretreatment requirements under the Clean Water Act. The NPDES program 

regulates discharges from wastewater treatment plants, large factories, and other facilities that 

use, process, and discharge water back into lakes, streams, rivers, bays, and oceans. 

Nonpoint Source: Pollution that enters any waters of the state from any dispersed land-based or 

water-based activities, including but not limited to atmospheric deposition, surface water runoff 

from agricultural lands, urban areas, or forest lands, subsurface or underground sources, or 

discharges from boats or marine vessels not otherwise regulated under the National Pollutant 

Discharge Elimination System Program. Generally, any unconfined and diffuse source of 

contamination. Legally, any source of water pollution that does not meet the legal definition of 

“point source” in section 502(14) of the Clean Water Act. 

Phase I Stormwater Permit: The first phase of stormwater regulation required under the 

federal Clean Water Act. The permit is issued to medium and large municipal separate storm 

sewer systems (MS4s) and construction sites of five or more acres. 

Phase II Stormwater Permit: The second phase of stormwater regulation required under the 

federal Clean Water Act. The permit is issued to smaller municipal separate storm sewer 

systems (MS4s) and construction sites over one acre. 

Point Source: Sources of pollution that discharge at a specific location from pipes, outfalls, and 

conveyance channels to a surface water. Examples of point source discharges include municipal 

wastewater treatment plants, municipal stormwater systems, industrial waste treatment facilities, 

and construction sites that clear more than 5 acres of land. 

Pollution: Such contamination, or other alteration of the physical, chemical, or biological 

properties, of any waters of the state, including change in temperature, taste, color, turbidity, or 

odor of the waters, or such discharge of any liquid, gaseous, solid, radioactive, or other substance 

into any waters of the state as will or is likely to create a nuisance or render such waters harmful, 

detrimental, or injurious to the public health, safety, or welfare, or to domestic, commercial, 

industrial, agricultural, recreational, or other legitimate beneficial uses, or to livestock, wild 

animals, birds, fish, or other aquatic life. 

Stormwater: The portion of precipitation that does not naturally percolate into the ground or 

evaporate but instead runs off roads, pavement, and roofs during rainfall or snow melt. 

Stormwater can also come from hard or saturated grass surfaces such as lawns, pastures, 

playfields, and from gravel roads and parking lots. 

Surface Waters of the State: Lakes, rivers, ponds, streams, inland waters, salt waters, 

wetlands, and all other surface waters and watercourses within the jurisdiction of Washington 

State. 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan

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Total Maximum Daily Load (TMDL): A distribution of a substance in a waterbody designed 

to protect it from exceeding water quality standards. A TMDL is equal to the sum of all of the 

following: (1) individual wasteload allocations (WLAs) for point sources, (2) the load allocations 

(LAs) for nonpoint sources, (3) the contribution of natural sources, and (4) a Margin of Safety to 

allow for uncertainty in the wasteload determination. A reserve for future growth is also 

generally provided. 

Wasteload Allocation (WLA): The portion of a receiving water’s loading capacity allocated to 

existing or future point sources of pollution. WLAs constitute one type of water quality-based 

effluent limitation. 

Watershed: A drainage area or basin in which all land and water areas drain or flow toward a 

central collector such as a stream, river, or lake at a lower elevation. 

Acronyms and Abbreviations 

BCF bioconcentration factor 

BHC benzene hexachloride (hexachlorocyclohexane) 

DDD dichlorodiphenyl dichloroethane 

DDE dichlorodiphenyl dichloroethylene 

DDT dichlorodiphenyl trichloroethylene 

Ecology Washington State Department of Ecology 

EPA U.S. Environmental Protection Agency 

ERO Ecology Eastern Regional Office 

NRCS Natural Resources Conservation Service 

NTR National Toxics Rule 

PCB polychlorinated biphenyl 

RCW Revised Code of Washington (the laws for Washington State) 

TOC total organic carbon 

TSS total suspended solids 

WAC Washington Administrative Code 

WDFW Washington Department of Fish and Wildlife 

WDOH Washington State Department of Health 

WSU Washington State University 

WWTP wastewater treatment plant 

USGS U.S. Geological Survey 

cfs cubic feet per second 

mg/L milligrams per liter (parts per million) 

ug/L micrograms per liter (parts per billion) 

ng/L nanograms per liter (parts per trillion) 

ug/Kg micrograms per kilogram (parts per billion) 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan

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Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan

Page 1 

Abstract 

The lower Palouse River has been listed by the state of Washington under Section 303(d) of the 

federal Clean Water Act for non-attainment of the U.S. Environmental Protection Agency (EPA) 

human health criteria for 4,4’-DDE, heptachlor epoxide, alpha-BHC, dieldrin, and PCB-1260 in 

edible fish tissue. These chlorinated pesticides, breakdown products, and polychlorinated 

biphenyls (PCBs) are no longer used in the United States, having been banned in the 1970s and 

1980s. EPA requires states to set priorities for cleaning up 303(d) listed waters and to establish a 

water quality improvement plan or Total Maximum Daily Load (TMDL) for each. A TMDL 

includes an analysis of how much of a pollutant load a waterbody can assimilate without 

violating water quality standards. 

Part 1 of this report reviews data on the levels and sources of chlorinated pesticides and PCBs in 

the Palouse River basin. The results are used to: (1) recommend a change in the listing status for 

4,4’-DDE, heptachlor epoxide, and alpha-BHC from Category 5 (TMDL required) to Category 1 

(meets standards); and (2) propose a fish tissue-based TMDL for dieldrin and PCBs. Wasteload 

and load allocations are proposed for sources. 

Part 2 of this report describes the implementation plan that the Department of Ecology will use to 

bring the Palouse River into compliance with water quality standards. The plan recommends 

monitored natural attenuation, as well as stormwater and agricultural best management practices, 

to reduce dieldrin and PCB levels. 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan

Page 2 

Acknowledgements 

The authors of this report thank the following people for their contributions to this study: 

• Landowners Cheryl Morgan, John Pearson, Dave Weber, Bill Wade, David Lange, 

Redgy Parsons, Carl Lautenschlager, Janet Schmidt, and Jon Jones. 

• Nancy Hoobler and Rob Buchert of the Palouse County Conservation District. 

• Gary Devore of the Adams County Conservation District. 

• Roger Marcus of the Whitman County Parks Department. 

• Andy Rogers of the City of Colfax. 

• Bob Weaver, Lucinda Morrow, and John Sneva of the Washington Department of Fish 

and Wildlife. 

• Sonia Mumford, Kenneth Lujan, and Laura Hawn of the U.S. Department of Fish and 

Wildlife. 

• Washington State Department of Ecology staff: 

o Casey Deligeannis, Jim Ross, and Brandi Lubliner. 

o Manchester Laboratory: Jeff Westerlund, Myrna Mandjikov, Karin Feddersen, 

Dean Momohara, Pam Covey, Sara Sekerak, and Will White. 

o This report benefited from review comments by Dale Norton, Karin Baldwin, and 

Ron McBride. 

o The final report was formatted by Joan LeTourneau, Shara Trantum, and Donna Ward. 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan

Page 3 

Executive Summary 

Background 

Every two years, the Washington State Department of Ecology (Ecology) prepares the 303(d) list 

of waterbodies that do not meet Washington State water quality standards. The federal Clean 

Water Act requires that a Total Maximum Daily Load (TMDL) be developed for each waterbody 

on the list. The TMDL determines the amount of a pollutant that can be discharged to the 

waterbody and still meet standards and allocates that load among sources. Ecology then works 

with the local community to develop a strategy to control the pollution and a monitoring plan to 

assess the effectiveness of the water quality improvement activities. 

The lower Palouse River (near Hooper and Winona, Washington) has been 303(d) listed for nonattainment of the human health criteria for 4,4’-DDE, heptachlor epoxide, alpha-BHC, dieldrin, 

and PCB-1260 in edible fish tissue, based on samples collected by Ecology in 1984 and 1994. 

These chlorinated pesticides, 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 human carcinogens by the U.S. Environmental 

Protection Agency (EPA). 

 

Study Area 

This TMDL is for the Palouse River from the Washington-Idaho border at river mile 123.4, to 

the Snake River confluence, including the Washington portion of the South Fork (Water 

Resource Inventory Area 34). The segment of the mainstem between the Washington-Idaho 

state line and the town of Colfax is locally referred to as the North Fork. The North Fork and 

South Fork merge at Colfax to form the mainstem of the Palouse River. 

The primary land use in the basin is dryland agriculture and rangeland. Soil erosion has been a 

major challenge in the Palouse. About 40% of the rich Palouse soils have been lost in the last 

century because of erosion by water. As a result, many farmers have voluntarily implemented 

erosion control practices. Urban areas make up less than 1% of the basin in Washington. The 

South Fork Palouse River is particularly influenced by urban pollution sources, having the two 

largest cities in its drainage: Pullman, Washington, and Moscow, Idaho. 

Applicable Water Quality Criteria 

Two sets of Washington State water quality criteria apply to the chlorinated pesticides and PCBs 

that have been detected in the Palouse River: one for aquatic life and one for human health. The 

human health criteria for carcinogens are primarily at issue in this TMDL and are established to 

keep the risk of developing cancer to a pre-specified level. In Washington, the risk level is set 

such that no more than 1 in 1,000,000 (10-6) people would be likely to develop cancer over a 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan

Page 4 

lifetime due to fish and water consumption. Almost all of the cancer risk is due to fish 

consumption. 

Numerical TMDL Targets 

For the Palouse River chlorinated pesticide and PCB TMDL, the determination as to whether 

Washington State water quality standards have been achieved will be based on the fish tissue 

criteria Ecology uses to identify waterbodies that exceed standards and warrant 303(d) listing. 

These criteria, shown below, are derived from EPA bioconcentration factors and the human 

health water quality criteria for fish consumption. 

Table ES- 1. Numerical Targets for the Palouse River Chlorinated Pesticide and PCB TMDL

Chemical 

Human Health 

WQ Criteria* 

(parts per trillion) 

EPA 

 Bioconcentration 

Factor 

Numerical Fish Tissue 

Target for TMDL†

(parts per billion) 

alpha-BHC 13 130 1.7 

Heptachlor epoxide 0.11 11,200 1.2 

4,4'-DDE 0.59 53,600 32 

Dieldrin 0.14 4,670 0.65 

Total PCBs 0.17 31,200 5.3 

*for fish consumption 

†human health criterion x 0.001 (unit conversion factor) x bioconcentration factor 

Recent Ecology Studies 

Ecology conducted three recent field studies in response to the chlorinated pesticide and PCB 

listings for the Palouse River: a low-level analysis of chlorinated pesticides in water samples 

(May 2004); an intensive survey of chlorinated pesticide and PCB residues in fish fillet samples 

(May–August 2005); and a pilot study of chlorinated pesticides, PCBs, and other contaminants in 

Pullman stormwater runoff (winter and early spring 2005–06). 

None of the fish fillet samples exceeded human health criteria for alpha-BHC or heptachlor 

epoxide, and the average 4,4’-DDE concentration met the criterion in all areas. Dieldrin and 

PCBs were close to human health criteria levels in both upper and lower mainstem fish. There 

were moderate PCB and dieldrin exceedances in the South Fork. There were no exceedances in 

the North Fork for PCBs, dieldrin, or the other 303(d) listed pesticides. These results are 

consistent with the low-level pesticide analysis of river water conducted the previous year. 

Ecology issued the Phase II Municipal Stormwater Permit for Eastern Washington that became 

effective February 16, 2007 under the National Pollutant Discharge Elimination System 

(NPDES). Pullman will be regulated under Phase II. Three Pullman storm drains were selected 

for sampling as being representative of the city as a whole: Stadium Way, College Street, and 

Benewah Street. The drains were sampled during three storm events. 303(d) pesticides and 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan

Page 5 

PCBs were detected in all of the Pullman storm drain samples. Dieldrin and PCBs were present 

in the highest concentrations and substantially exceeded human health criteria. 

TMDL Analysis 

Loading capacity is the maximum amount of a pollutant that can be delivered to a waterbody and 

still achieve water quality standards. The loading capacity of the Palouse River was calculated 

for 303(d) listed chemicals by multiplying streamflow by the human health water quality 

criterion. The river’s loading capacity for most chemicals is substantially less than one gram per 

day. 

The 2005 fish tissue data were used to calculate the chlorinated pesticide and PCB 

concentrations in the water column and to make a comparison with the water quality criteria. 

This analysis determined the current status of the river with respect to loading capacity for 

303(d) pesticides and PCBs. The results are shown in Table ES-2. 

Table ES- 2. Loading Capacity Status for 303(d) Listed Pesticides and PCBs in the Palouse 

River, Based on Fish Tissue Concentrations and EPA Bioconcentration Factors (Values greater 

than 1 exceed loading capacity) 

Exceedance Factors 

Chemical (Estimated ambient water concentration / human health water quality criterion) 

Lower Mainstem Upper Mainstem South Fork North Fork 

alpha-BHC <1 <1 <1 <1 

Heptachlor epoxide <1 <1 <1 <1 

4,4'-DDE <1 <1 <1 <1 

Dieldrin 1.7 1.3 2.4 <1 

Total PCBs <1 1.4 3.4 <1 

The loading capacity analysis indicates that: 

1. The South Fork Palouse River exceeds loading capacity for dieldrin and PCBs by factors of 

2 to 3, respectively. 

2. The mainstem Palouse River (below Colfax) slightly exceeds loading capacity for dieldrin 

and PCBs. 

3. The North Fork Palouse River is below loading capacity. 

The focus of the TMDL is therefore to reduce dieldrin and PCB levels in the mainstem and, 

especially, the South Fork. 

A TMDL must identify the total allowed pollutant amount and its components: appropriate 

wasteload allocations (WLAs) for point sources; load allocations (LAs) for nonpoint sources; 

and natural background. The allocations proposed for dieldrin and PCBs in the Palouse River 

are shown in Table ES-3. 
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Table ES-3. Wasteload and Load Allocations for Dieldrin and PCBs in the Palouse River 

(grams per day) 

Source Total 

PCBs Dieldrin 

South Fork Palouse River 

Wasteload Allocations 

 Pullman WWTP (interim WLA) 0.0022 0.0018 

 Albion WWTP (interim WLA) 0.0001 0.0001 

 Stormwater BMPs BMPs 

Load Allocations 

 Nonpoint 0.010 0.008 

 Natural Background 0 0 

Margin of Safety 0.0032 0.0026 

Total Allocations 0.016 0.013 

TMDL 0.016 0.013 

Mainstem Palouse River 

Wasteload Allocations 

 Colfax WWTP (interim WLA) 0.0004 0.0003 

Load Allocations 

 Nonpoint 0.026 0.021 

 Natural Background 0 0 

Margin of Safety 0.0064 0.0052 

Total Allocations 0.032 0.026 

TMDL 0.032 0.026 

The data available to determine if wastewater treatment plant (WWTP) discharges were causing 

or contributing to exceedances of human health criteria for dieldrin or PCBs in the Palouse River 

were extremely limited. Although Ecology suspects that the main sources of PCB and dieldrin 

are from nonpoint sources, the widespread presence of these contaminants in the environment 

increases the likelihood they are present in the WWTP effluents. Other water quality 

assessments of WWTPs have found PCBs and dieldrin in wastewater effluent (Golding, 2001; 

Serdar, 2003; Johnson et al., 2004). Therefore WLAs were assigned for the three WWTPs that 

discharge to parts of the river where loading capacity is exceeded. Because the receiving waters 

already exceed loading capacity, the WLAs were set to meet the human health criteria at the end 

of pipe for each facility’s design flow. These are interim WLAs that will be revised as more 

knowledge is gained about the levels being discharged. 

Because of the variability of storm events, EPA recommends that effluent limits for NPDESregulated municipal stormwater discharges be expressed as best management practices (BMPs) 

rather than as numeric limits. BMPs for Pullman stormwater are included as part of the 

implementation plan for this TMDL (Part 2 of this report). 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan

Page 7 

For nonpoint sources, the LAs for dieldrin and PCBs were set equal to the loading capacities 

minus the sum of the WLAs and margin of safety. Because dieldrin and PCBs are man-made 

chemicals, there is no contribution from natural background. Therefore the LA for natural 

background is zero for both chemicals. A 20% margin of safety was included in the allocations 

to account for uncertainty in understanding the relationship between pollutant discharges and 

water quality impacts. 

As with other chemicals banned by EPA, environmental concentrations of dieldrin and PCBs 

have decreased over time. The effects of the ban are evident in fish that have been analyzed 

from the lower Palouse River, where the concentrations measured in 2005 are one to two orders 

of magnitude lower than those recorded in 1984 and 1995. Reduced soil erosion in the Palouse 

watershed has probably also played a part in lowering contaminant residues in the fish. 

Estimates of further reductions required to meet the numerical TMDL targets and bring the river 

into compliance with water quality standards are shown in Table ES-4. 

Table ES-4. Estimates of Reductions Needed in Fish Tissue Concentrations of Dieldrin and 

PCBs to Meet Water Quality Standards in the Palouse River 

Lower Mainstem Upper Mainstem South Fork North Fork 

Dieldrin 41% 23% 59% 0% 

Total PCBs 0% 26% 71% 0% 

It is proposed that natural attenuation, monitoring, and BMPs be relied on to bring the Palouse 

River into compliance with water quality standards for dieldrin and PCBs. A monitored natural 

attenuation approach is warranted because (1) the levels are low relative to human health criteria, 

(2) the chemicals of concern are no longer used, (3) fish tissue concentrations have decreased 

over the past 10–20 years and will continue to decrease without further action being taken, and 

(4) a monitored natural attenuation approach is consistent with EPA-approved TMDLs in other 

states with similar 303(d) listings. The Washington State Department of Health has reviewed the 

fish tissue data for the Palouse River and does not consider a fish consumption advisory to be 

warranted. 

Monitoring Plan 

Additional monitoring, inspections, and investigations are planned or recommended in four areas 

for this TMDL: 

• Conduct periodic fish tissue monitoring for dieldrin and PCBs. 

• Evaluate wastewater treatment facilities (including the collection systems) as potential 

dieldrin and PCB sources. 

• Identify and clean up sources of dieldrin and PCBs to the Pullman storm drain system. 

• Identify and clean up abandoned landfills and old dumps vulnerable to high water events or 

surface runoff during storms. 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan

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Recommendations 

1. The 303(d) Category 5 listings (Polluted Waters that Require a TMDL) for 4,4’-DDE, 

heptachlor epoxide, and alpha-BHC in the Palouse River should be moved to Category 1 

(Meets Tested Standards for Clean Waters). 

2. Ecology should periodically monitor fish tissue for dieldrin and PCBs in the mainstem 

Palouse River below Colfax and in the South Fork Palouse River to assure levels are 

continuing to decline at the expected rate. A monitoring frequency of once every five years 

is recommended. 

3. PCBs and dieldrin should be monitored in the influent and effluent of the Pullman, Albion, 

and Colfax WWTPs. 

4. In light of elevated concentrations of dieldrin and PCBs in Pullman stormwater and the 

potential for adverse water quality impacts, Ecology, the City of Pullman, and Washington 

State University should work cooperatively to identify and clean up sources of these 

chemicals to the storm drain system. 

5. An effort should be made to identify abandoned landfills and old dumps vulnerable to high 

water events or surface runoff during storms, determine if they are sources of dieldrin or 

PCBs to the Palouse River, and remediate as needed. 

6. It is anticipated that most sources of dieldrin and PCB are from nonpoint sources. However, 

if levels do not continue to decline in Palouse River fish as anticipated, then the Moscow, 

Idaho WWTP should be re-evaluated as a possible contributor to the problem. Initially this 

could consist of sampling Paradise Creek to quantify dieldrin and PCB loading from the 

Moscow area. 

7. Chemical analysis of the above samples should employ detection limits low enough to 

compare to human health water quality criteria. 

Implementation 

The implementation plan for this TMDL expands on the recommendations made in Part 1 of the 

report. It will serve as both the implementation strategy and the implementation plan required by 

Ecology’s memorandum of agreement with EPA. 

Waterbody segments found to meet water quality standards during the study will be moved from 

Category 5 (Polluted Waterbodies Requiring a TMDL) to Category 1 (Meets Tested Standards) 

on Ecology’s Water Quality Assessment. Ecology will rely on natural attenuation, monitoring, 

and stormwater and agricultural BMPs to bring the mainstem Palouse River and the South Fork 

Palouse River into compliance with water quality standards. Wasteload allocations for point 

sources will ensure these facilities are not contributing to elevated levels of PCBs and dieldrin in 

the rivers. Limited data suggest that compliance with the water quality standards could be 

achieved by 2012 for dieldrin and PCBs in the mainstem Palouse River, and by 2017 for dieldrin 

and 2022 for PCBs in the South Fork Palouse River. 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan

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Several agencies and programs will work collaboratively to ensure that levels of dieldrin and 

PCBs continue to decline. Entities that regulate or discharge stormwater and wastewater, 

regulate landfills, monitor water quality, or provide technical assistance and funding for methods 

that reduce erosion should participate in this TMDL. Entities that agreed to participate in this 

implementation plan include the Environmental Assessment and Water Quality programs within 

the Department of Ecology, Whitman County Health Department, the cities of Pullman, Colfax 

and Albion, Washington State University, and the conservation districts in the watershed. 

The success of the implementation plan will be measured by tracking the progress of 

implementation actions and reassessing pollutant levels in the Palouse River and South Fork 

Palouse River fish tissue. If progress is not being made at the predicted rate, the TMDL 

coordinator and the partner organizations will evaluate other methods and activities that could 

help the river meet water quality standards. 
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Part 1 
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What is a Total Maximum Daily Load (TMDL)? 

Federal Clean Water Act Requirements 

The Clean Water Act established a process to identify and clean up polluted waters. Under the 

Clean Water Act, each state is required to have its own water quality standards designed to 

protect, restore, and preserve water quality. Water quality standards consist of designated uses 

for protection, such as cold water biota and drinking water supply, and criteria, usually numeric 

criteria, to achieve those uses. 

Every two years, states are required to prepare a list of waterbodies – lakes, rivers, streams, or 

marine waters – that do not meet water quality standards. This list is called the 303(d) list. To 

develop the list, Ecology compiles its own water quality data along with data submitted by local 

state and federal governments, tribes, industries, and citizen monitoring groups. All data are 

reviewed to ensure that they were collected using appropriate scientific methods before they are 

used to develop the 303(d) list. The 303(d) list is part of the larger Water Quality Assessment. 

The Water Quality Assessment is a list that tells a more complete story about the condition of 

Washington’s water. This list divides waterbodies into one of five categories: 

Category 1 – Meets standards for parameter(s) for which it has been tested 

Category 2 – Waters of concern 

Category 3 – Waters with no data available 

Category 4 – Polluted waters that do not require a TMDL because: 

4a. – Has a TMDL approved and its being implemented 

4b. – Has a pollution control plan in place that should solve the problem 

4c – Is impaired by a non-pollutant such as low water flow, dams, culverts 

Category 5 – Polluted waters that require a TMDL – on the 303d list. 

TMDL Process Overview 

The Clean Water Act requires that a Total Maximum Daily Load or TMDL be developed for 

each of the waterbodies on the 303(d) list. A TMDL identifies how much pollution needs to be 

reduced or eliminated to achieve clean water. Then Ecology works with the local community to 

develop a strategy to control the pollution and a monitoring plan to assess effectiveness of the 

water quality improvement activities. 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan

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Elements Required in a TMDL 

The goal of a TMDL is to ensure the impaired water will attain water quality standards. A 

TMDL includes a written, quantitative assessment of water quality problems and of the pollutant 

sources that cause the problem. The TMDL determines the amount of a given pollutant that can 

be discharged to the waterbody and still meet standards (the loading capacity) and allocates that 

load among the various sources. 

If the pollutant comes from a discrete (point) source such as a municipal or industrial facility’s 

discharge pipe, that facility’s share of the loading capacity is called a wasteload allocation. If it 

comes from a set of diffuse (nonpoint) sources such as general urban, residential, or farm runoff, 

the cumulative share is called a load allocation. 

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 problem or its loading 

capacity. A reserve capacity for future loads from growth pressures is sometimes included as 

well. The sum of the wasteload and load allocations, the margin of safety and any reserve 

capacity must be equal to or less than the loading capacity. 

TMDL = Loading Capacity = sum of all Wasteload Allocations + sum of all Load Allocations 

+ Margin of Safety 

Total Maximum Daily Load Analyses: Loading Capacity 

Identification of the contaminant loading capacity for a waterbody is an important step in 

developing a TMDL. EPA defines the loading capacity as “the greatest amount of loading that a 

waterbody can receive without violating water quality standards” (EPA, 2001). The loading 

capacity provides a reference for calculating the amount of pollution reduction needed to bring a 

waterbody into compliance with standards. The portion of the receiving water’s loading capacity 

assigned to a particular source is a load or wasteload allocation. By definition, a TMDL is the 

sum of the allocations, which must not exceed the loading capacity. 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan

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Why is Ecology Conducting a TMDL Study 

in This Watershed? 

Overview 

The lower Palouse River (near Hooper and Winona, WA) has been listed by the state of 

Washington under Section 303(d) of the Clean Water Act for non-attainment of the human 

health-based water quality criteria for 4,4’-DDE, heptachlor epoxide, alpha-BHC, dieldrin, and 

PCB-1260. The human health-based criteria were issued to Washington in 1992 by EPA in the 

National Toxics Rule (NTR) (40CFR131.36). The listings are based on sampling of edible fish 

tissue conducted by the Washington State Department of Ecology (Ecology) in 1984 and 1994. 

These chlorinated pesticides, 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 human carcinogens by EPA. Detailed profiles 

including use, regulations, environmental occurrence, and health effects have been prepared by 

the Agency for Toxic Substances and Disease Registry and are available at 

www.atsdr.cdc.gov/toxpro2.html. 

Study Area 

 

This TMDL is for the Palouse River from the Washington-Idaho border at river mile (r.m.) 

123.4, to the Snake River confluence, including the Washington portion of the South Fork 

(Water Resource Inventory Area 34). 

The Palouse River drains approximately 3,300 square miles of the Columbia Plateau in 

southeastern Washington and the Idaho Panhandle (Figure 1). Eighty-three percent of the basin 

is in Washington State, primarily Whitman County. 

The headwaters of the Palouse River originate in the forested mountains of Idaho at an elevation 

of 5,300 ft. It flows for over 165 miles through dryland farming in the central part of the basin 

and rangeland to the west, before its confluence with the Snake River at an elevation of about 

500 ft. Major tributaries to the Palouse are the South Fork Palouse River and Paradise, Rebel 

Flat, Rock, Union Flat, and Cow Creeks. 

 

The segment of the mainstem between the Washington-Idaho state line and the town of Colfax is 

locally referred to as the North Fork. The North Fork and South Fork merge at Colfax to form 

the mainstem of the Palouse River. The North Fork contributes about 83% of the annual mean 

flow of the Palouse River at Colfax (Ahmed, 2004). 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan

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Figure 1. Palouse River Basin (from Ebbert and Roe, 1998)

The primary land use is dryland agriculture (67%), with some rangeland (26%) and forested 

areas (6%) (Ecology, 2003). Wheat, barley, lentils, and peas are the major crops. Irrigated 

farming along the Palouse River and its tributaries contributes less than 1% of land use 

(Wagner and Roberts, 1998). 

With a population of only about 47,000, urban areas make up less than 1% of the basin in 

Washington (Ecology, 2003). The major Washington cities are Pullman (pop. 26,779), 

Colfax (4,124), and Palouse (1,408). Moscow (21,674) and Potlatch (773) are the largest Idaho 

cities in the basin. 

The South Fork Palouse River is particularly influenced by urban pollution sources, having the 

two largest cities in its drainage basin. The Moscow wastewater treatment plant (WWTP) 

discharges to Paradise Creek, and the Pullman WWTP discharges to the South Fork about two 

miles below the Paradise Creek confluence. Pelletier (1993) developed a TMDL for ammonia in 

the South Fork. He concluded that “Effluent from...Moscow and Pullman comprise most of the 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan

Page 17 

river flow during July-November of a typical year and during any month of the year for design 

low flows.” 

Flows in the Palouse River and its tributaries have a strong seasonal variation, with high 

discharge in the late winter and early spring due to snow melt, and low flow in late summer 

(Figure 2). Summers are hot and dry; winters are cool with occasional cold snaps. Precipitation 

increases from west to east, ranging from approximately 13 inches annually in the southwestern 

part of the basin to over 25 inches in the mountainous headwaters. Approximately 85% of the 

precipitation occurs between October and May, with 40% occurring between November and 

January (Wagner and Roberts, 1998). 

0

200

400

600

800

1,000

1,200

1,400

1,600

1,800

2,000

Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar

Flow (cfs)

Palouse @ Hooper S.F. @ Pullman N.F. near Colfax

Figure 2. Mean Monthly Flows in the Palouse River [USGS historical data]. 

Soil erosion has been a major challenge in the Palouse. Farming began in the late 1800s. 

Erosion became particularly serious in the early 1900s when steep lands once used for hay and 

pasture were converted to grain production (Ebbert and Roe, 1998; USDA, 1978). About 40% 

of the rich Palouse soils have been lost in the last century because of erosion by water (Pimentel 

et al., 1995). 

Many farmers have voluntarily implemented erosion control practices in the basin. Since the late 

1970s, erosion from cropland has been reduced by at least 10% (Ebbert and Roe, 1998). The 

United States Geologic Survey (USGS) and Ecology have analyzed the total suspended sediment 

data for Hooper (Hallock and Ebbert, 1996; Ebbert and Roe, 1998). Although there were 

indications of improvement, the data were considered inconclusive because the recent period of 

record was short and because large storm events skewed some of the older data. 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan

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The fish fauna in the Palouse River is limited with respect to species generally considered 

desirable as food. The predominant species of catchable size are large-scale suckers, northern 

pike minnow, smallmouth bass, and chiselmouth. Of these, only smallmouth bass are locally 

considered to be a sportfish. Other species known to occur in the drainage include rainbow trout, 

brown trout, channel catfish, and carp; their distribution is either limited to tributaries (trout), 

sparse (catfish), or confined to the last few miles of the mainstem (carp). 

According to the Washington Department of Fish and Wildlife (WDFW), there is very little sport 

fishing above Palouse Falls (r.m. 7.0) in the Washington portion of the Palouse River. Because 

most of the land is privately-owned, there are few places where the public has access to potential 

fishing sites. There is a limited smallmouth bass fishery on the North Fork and some fishing in 

Rock Creek for brown trout and smallmouth bass. Rainbow trout are stocked annually in Union 

Flat Creek, but this fishery is small and mainly for children. While there are certain cultural 

groups that target specific species in other eastern Washington river basins, WDFW has never 

observed them fishing in the Palouse. (Personal communication, Bob Weaver/Chris Donely, 

WDFW). 

Pollutants Addressed by This TMDL Study and 

Implementation Plan 

This TMDL study and implementation plan is for the following chemicals in fish tissue and the 

water column: 

• 4,4’-DDE (breakdown product of the insecticide DDT) 

• heptachlor epoxide (breakdown product of the insecticide heptachlor) 

• alpha-BHC (component of the insecticide benzene hexachloride) 

• dieldrin (insecticide) 

• PCBs (industrial use chemicals) 

The PCB data presented in this report are expressed in terms of Aroclor-equivalents (e.g., PCB1260) or total PCBs (sum of Aroclor-equivalents or sum of individual PCB compounds, also 

known as congeners). Aroclor is the trade name of the commercial PCB mixtures predominantly 

used in the United States. The TMDL is for total PCBs. 

The 303(d) listings in Table 1 are specifically addressed by this TMDL study and 

implementation plan. In addition, the river segments listed in Table 2 were found to contain fish 

with dieldrin and PCB concentrations above the human health criteria during a 2005 fish tissue 

study conducted by Ecology and described later in this report. 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan

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Table 1. Palouse River 303(d) Listings for Toxics in Edible Fish Tissue (2002/2004 list) 

Listing 

ID Parameter 

Township 

Range 

Section 

Water 

Course/ 

Grid # 

Lower 

Route 

# 

Listing Basis 

14190 4,4'-DDE 15N-37E-26 NX00WG 29.009 

Hopkins et al. (1985). Excursions beyond the NTR* 

criterion in a multiple fish composite of edible tissue 

of largescale sucker and northern squawfish samples 

at river mile (RM) 19.5 in 1984. 

8819 4,4'-DDE 17N-40E-20 NX00WG 75.039 

Davis and Serdar (1996). Excursions beyond the 

NTR criterion in edible squawfish tissue at RM 40.8 

in 1994. 

14191 alpha-BHC 15N-37E-26 NX00WG 29.009 

Hopkins et al. (1985). Excursions beyond the NTR 

criterion in a multiple fish composite of edible tissue 

of largescale sucker and northern squawfish samples 

at RM 19.5 in 1984. 

8818 Dieldrin 17N-40E-20 NX00WG 75.039 

Davis and Serdar (1996). Excursions beyond the 

NTR criterion in edible squawfish tissue at RM 40.8 

in 1994. 

8822 Heptachlor 

epoxide 17N-40E-20 NX00WG 75.039 

Davis and Serdar (1996). Excursions beyond the 

NTR criterion in edible squawfish tissue at RM 40.8 

in 1994. 

8820 PCB-1260 17N-40E-20 NX00WG 75.039 

Davis and Serdar (1996). Excursions beyond the 

NTR criterion in edible squawfish tissue at RM 40.8 

in 1994. 

*EPA National Toxics Rule 

Table 2. Additional River Segments Found to be Impaired by Dieldrin and PCBs During 

Ecology’s 2005 Fish Tissue Study 

Waterbody 

and ID 

Township 

Range 

Section 

LL ID # LL ID Lower 

Route # 

Water 

Course # 

Lower 

Route # 

Location 

Description 

Palouse 

River 

WA-34-1010 

17N-42E-22 1182144465889 120.461759 NX00WG 118.261 Shields Road 

Bridge Area 

16N-44E-19 6.436 6.272 Near Risbeck 

16N-44E-33 15.903043 15.397 Near Shawnee 

15N-44E-15 22.904577 22.237 Near Albion 

South Fork 

Palouse 

River 

WA-34-1020 

15N-45E-31 

1173663468898 

32.526 

ZX82FM 

31.499 Downstream of 

Pullman WWTP 

LL = latitude and longitude 
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Water Quality Standards and Beneficial Uses 

Water quality standards for surface waters of the state of Washington are codified in 

Chapter 173-201A of the Washington Administrative Code (WAC). 

Beneficial Uses 

Under the 1997 water quality standards, the mainstem Palouse is a Class B river from the mouth 

to its confluence with the South Fork Palouse River. The Palouse River from the South Fork 

confluence to the Idaho border (North Fork Palouse River) is a Class A river. The South Fork 

Palouse River is Class A to the Idaho border. Beneficial uses for Class A and B waters include, 

but are not limited to, the following (WAC 173-201A-030): 

(i) Water supply (domestic (except Class B), industrial, agricultural). 

(ii) Stock watering. 

(iii) Fish and shellfish: 

 Salmonid migration, rearing, spawning (except Class B), and harvesting. 

 Other fish migration, rearing, spawning, and harvesting. 

 Clam, oyster, and mussel rearing, spawning, and harvesting (except Class B). 

 Crustaceans and other shellfish (crabs, shrimp, crayfish, scallops, etc.) rearing, 

 spawning, and harvesting. 

(iv) Wildlife habitat. 

(v) Recreation (primary contact recreation (Class A), secondary contact recreation (Class B) 

sport fishing, boating, and aesthetic enjoyment). 

(vi) Commerce and navigation. 

Recent changes to the water quality standard have reclassified the segment of the Palouse River 

from the mouth to the Palouse Falls to also include fish spawning and rearing, primary contact 

recreation, and domestic water supply as beneficial uses. 

Toxic Substances 

WAC 173-201A-030 states the following with regard to toxic substances: 

(vii) Toxic, radioactive, or deleterious material concentrations shall be below those which have 

the potential either singularly or cumulatively to adversely affect characteristic water uses, 

cause acute or chronic conditions to the most sensitive biota dependent upon those waters, or 

adversely affect public health, 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 introduced above natural background levels in waters of the 

state which have the potential either singularly or cumulatively to adversely affect characteristic 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan

Page 22 

water uses, cause acute or chronic toxicity to the most sensitive biota dependent upon those 

waters, or adversely affect public health, as determined by the department. 

(2) The department shall employ or require chemical testing, acute and chronic toxicity testing, 

and biological assessments, as appropriate, to evaluate compliance with subsection (1) of this 

section and to ensure that aquatic communities and the existing and characteristic beneficial 

uses of waters are being fully protected.

(5) Concentrations of toxic and other substances with toxic propensities not listed in 

subsection (3) of this section shall be determined in consideration of USEPA Quality Criteria for 

Water, 1986, as revised, and other relevant information as appropriate. Human health-based 

water quality criteria used by the state are contained in 40 CFR 131.36 (known as the National 

Toxics Rule). 

(6) Risk-based criteria for carcinogenic substances shall be selected such that the upper-bound 

excess cancer risk is less than or equal to one in one million. 

Water Quality Criteria 

Washington State water quality criteria that apply to the chlorinated pesticides and PCBs that 

have been detected in the Palouse River drainage are shown in Table 3 (from sections (3) and (5) 

of WAC 173-201A-040). There are two sets of criteria: one for aquatic life and one for human 

health. 

Table 3. Washington State Water Quality Criteria for Chlorinated Pesticides and PCBs Detected 

in the Palouse River Basin (ng/L; parts per trillion) (The Palouse River is 303(d) listed for the 

underlined chemicals) 

 

Criteria for Protection 

of Aquatic Life 

Criteria for Protection 

of Human Health 

Chemical 

Freshwater 

Chronic* 

Freshwater 

Acute†

Fish 

Consumption

Water + Fish 

Consumption 

4,4'-DDT - - - - 0.59 0.59 

4,4'-DDE - - - - 0.59 0.59 

4,4'-DDD - - - - 0.84 0.83 

DDT (and metabolites) 1.0 1,100 - - - - 

Dieldrin 1.9 2,500 0.14 0.14 

Heptachlor epoxide - - - - 0.11 0.10 

Hexachlorobenzene - - - - 0.77 0.75 

gamma-BHC (Lindane) 80 2,000 63 19 

alpha-BHC - - - - 13 3.9 

Endrin 2.3 180 810 760 

Chlordane 4.3 2,400 0.59 0.57 

PCBs 14 2,000 0.17 0.17 

*24-hour average not to be exceeded †

an instantaneous concentration not to be exceeded at any time 
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Aquatic Life Criteria 

The aquatic life criteria are designed to protect for both short-term (acute) and long-term 

(chronic) effects of toxics exposure. Aquatic life criteria are primarily intended to avoid direct 

lethality to fish and other aquatic life within the specified exposure periods. The chronic criteria 

for PCBs and many of the chlorinated pesticides are to protect fish-eating wildlife from adverse 

effects due to bioaccumulation. 

The exposure periods assigned to the acute criteria are expressed as: (1) an instantaneous 

concentration not to be exceeded at any time, or (2) a 1-hour average concentration not to be 

exceeded more than once every three years on the average. The exposure periods assigned to the 

chronic criteria are expressed as either: (1) a 24-hour average not to be exceeded at any time, or 

(2) a 4-day average concentration not to be exceeded more than once every three years on the 

average. Exceedances of aquatic life criteria have rarely been observed in the Palouse River. 

Human Health Criteria 

Criteria for the protection of human health are contained in the EPA National Toxics Rule 

(NTR), issued to Washington State in 1992. In freshwaters, the criteria take into account the 

combined exposure of both drinking the water and eating fish that lived in the water. The criteria 

are established to protect against non-carcinogenic illness and to keep the risk of developing 

cancer to a pre-specified level. In Washington, the cancer risk is set such that no more than 1 in 

1,000,000 (10-6) people with full exposure would be likely to develop cancer in response to that 

exposure. 

Full exposure is defined by set assumptions on body size, fish and water consumption, and the 

number of years exposed. For example, in Washington the risk is correlated to an average-sized 

man consuming 6.5 grams per day of fish (approximately 5 pounds per year), drinking 2 liters of 

water (if a freshwater body), and continuing this pattern for 70 years. People with higher or 

lower exposure patterns would face higher or lower risks. This basic exposure pattern is the 

same for both cancer-causing and non-cancer-causing chemicals. The chemicals at issue in the 

present TDML are all classed as carcinogens. Almost all the cancer risk comes from fish 

consumption. 

Numeric TMDL Targets 

For the Palouse River chlorinated pesticide and PCB TMDL, the determination as to whether 

Washington State water quality standards have been achieved will be based on the fish tissue 

criteria Ecology uses to identify waterbodies that exceed standards and warrant 303(d) listing 

(Ecology, 2006). These criteria (Table 4) are derived from EPA bioconcentration factors (BCF1

) 

and water column criteria established for fish consumption under the NTR. In essence, the 

303(d) fish tissue criteria are the NTR water quality criteria expressed in tissue form. 

 

1 BCF= Ct/Cw, where Ct is the contaminant concentration in tissue (wet weight) and Cw is the 

concentration in water. 
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Table 4. Numerical Targets for the Palouse River Chlorinated Pesticide and PCB TMDL

Chemical 

Human Health 

WQ Criteria* 

(parts per trillion) 

EPA 

 Bioconcentration 

Factor 

Numerical Fish Tissue 

Target for TMDL†

(parts per billion) 

alpha-BHC 13 130 1.7 

Heptachlor epoxide 0.11 11,200 1.2 

4,4'-DDE 0.59 53,600 32 

Dieldrin 0.14 4,670 0.65 

Total PCBs 0.17 31,200 5.3 

*for fish consumption 

†human health criterion x 0.001 (unit conversion factor) x bioconcentration factor 

Basing the numeric targets on fish tissue rather than water quality criteria applies more directly 

to the human health concerns at issue in this TMDL. Because fish integrate water column 

concentrations over time, relatively few fish samples can provide representative data, in contrast 

to water where a much larger sample size would be required to determine compliance with 

standards. 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan

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Review of Historical Pesticide/PCB Data 

The Department of Ecology (Ecology) fish tissue data that resulted in 303(d) listings for the 

Palouse River are summarized in Table 5 and are compared to the listing criteria. Each of these 

samples was a composite formed by pooling tissues from five individual fish. Ecology’s data 

requirement for 303(d) listing a waterbody for toxics is that at least three single-fish samples or 

one composite of at least five fish exceed criteria for protection of human health. 

Ecology’s fish samples were collected in the lower mainstem Palouse River at Hooper in 1984 

(r.m. 19.5) and about 20 miles upstream near Winona in 1994 (r.m. 40.8). The analyses included 

up to 43 chlorinated pesticides, breakdown products, and PCB mixtures; only detected 

compounds are shown in Table 5. 

Fillets were analyzed from bridgelip sucker (Catostomus columbianus) and northern pike 

minnow (Ptychocheilus oregonensis, a.k.a. northern squawfish). 4,4’-DDE was present in the 

highest concentrations of 73–130 ug/Kg wet weight (parts per billion). Concentrations of 

dieldrin, heptachlor epoxide, alpha-BHC, and PCB-1260 were 6.3– 6 ug/Kg. Criteria for fish 

consumption were exceeded by a factor of 2 for PCBs, factors of 2–4 for DDE, and a factor of 5 

for heptachlor epoxide. Alpha-BHC and dieldrin concentrations exceeded criteria by factors of 

10–20. A whole fish sample had about twice the concentrations found in the fillets. 

Ecology also analyzed pesticides in a limited number of water samples collected from the 

Palouse River near Winona in 1994 (Davis, 1996). Only herbicides were found, none of which 

are on the 303(d) list. The detection limit for chlorinated pesticides (50 ng/L, parts per trillion) 

was not low enough to determine if human health criteria were exceeded. PCBs were not 

analyzed. 

USGS has done extensive sampling in the Central Columbia Plateau as part of the National 

Water Quality Assessment program. Their data on chlorinated pesticides and PCBs in fish and 

sediment samples collected from the Palouse River basin in 1992 and 1994 are summarized in 

Tables 6 and 7 (Munn and Gruber, 1997). 

USGS analyzed whole largescale suckers collected from the upper Palouse River in Idaho, the 

North and South Forks, the lower mainstem, Paradise Creek, and Pine Creek. Each data point 

represents a single sample. Whole fish data cannot be compared to 303(d) criteria, which apply 

to edible tissue only. 

4,4’-DDT, 4,4’-DDE, 4,4’-DDD, hexachlorobenzene, and dieldrin were detected in most of the 

USGS whole fish samples. The highest total DDT concentrations (DDT+DDE+DDD) were 

found in the North and South Forks, 180–450 ug/Kg. PCBs were only detected in fish from the 

North Fork and Paradise Creek (5.0 ug/Kg detection limit). The PCB concentration in the 

Paradise Creek fish sample was relatively high at 820 ug/Kg. No pesticides or PCBs were 

detected in fish from the upper Palouse River in Idaho. Alpha-BHC and heptachlor epoxide 

were not detected in any of the fish samples. 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan

Page 26 

Table 5. Historical Ecology Data on Chlorinated Pesticides and PCBs Detected in Palouse River 

Fish (ug/Kg wet weight; parts per billion) (Highlighted results are for fillets exceeding 303(d) 

criteria) 

Location:

Largescale N. Pike Bridgelip N. Pike 303(d)

Sucker Minnow Sucker Minnow Human

Tissue: Whole Body Fillet Fillet Fillet Health

Date: Sep-94 Sep-94 Sep-84 Sep-84 Criteria

4,4'-DDE 170 73 92 130 32

4,4'-DDD 18 nd 10 5 45

4,4'-DDT 12 J nd 23 2 32

Total DDT 200 73 125 137 32

Cis-Chlordane 5.7 1.2 J na na

Trans-Chlordane 14 nd na na

Oxychlordane 7.2 2.4 J na na

Cis-Nonachlor 1.7 J 0.75 J na na

Trans-Nonachlor 4.7 J 2.1 J na na

Total Chlordane 33 6.5 na na 8.3

Dieldrin 13 7 NJ na na 0.65

alpha-BHC nd nd 37 16 1.7

gamma-BHC (Lindane) 0.27 NJ 0.44 J na na 8.2

Heptachlor epoxide 14 6.3 na na 1.2

Hexachlorobenzene 10 3.6 na na 6.7

DDMU 2.7 J nd na na

PCB - 1254 13 J nd nd nd 5.3

PCB - 1260 18 J 11 J <10 <10 5.3

Total PCBs 31 J 11 J <10 <10 5.3

Palouse R. nr Winona Palouse R. @ Hooper

Species:

Data from: Davis and Serdar (1996) and Hopkins et al. (1985) 

J = The analyte was positively identified. The associated numerical value is an estimate. 

NJ = There is evidence that the analyte is present. The associated numerical value is an estimate. 

nd = not detected 

na = not analyzed or not reported 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

Page 27 

Table 6. USGS Data on Chlorinated Pesticides and PCBs Detected in Whole Body Samples of Largescale Suckefrom the Palouse River Basin in 1992 and 1994 (ug/Kg wet weight; parts per billion)

Location 4,4'-DDD 4,4'-DDE 4,4'-DDT Total DDT Hexachloro- benzene Dieldrin Endrin Total Chlorda

Palouse R. @ Harvard (ID) nd nd nd nd nd nd nd nd N.F. Palouse R. @ Colfax nd 160 24 180 26 32 nd nd 

" 22 400 29 450 33 22 nd 53 

S.F. Palouse @ Colfax nd 340 nd 340 16 nd nd nd Palouse R. @ Hooper 5.1 87 7.0 99 14 7.8 9.2 nd Paradise Creek 58 120 nd 180 11 nd nd nd Pine Creek 6.9 120 8.6 140 27 21 10 14 Data from Munn and Gruber (1997) nd = not detected

Table 7. USGS Data on Chlorinated Pesticides and PCBs Detected in Sediment Samples Collected from the PaloBasin in 1992 and 1994 (ug/Kg organic carbon; parts per billion) 

Location 4,4'-DDD 4,4'-DDE 4,4'-DDT Total DDT Hexachloro- benzene Lindane Dieldrin Tot

Chlor

Palouse R. @ Harvard (ID) nd nd nd nd nd nd nd nd 

" nd nd nd nd nd nd nd nd 

N.F. Palouse R. @ Colfax 150 530 160 840 330 170 110 nd 

" nd 320 92 410 470 140 150 61

S.F. Palouse @ Pullman nd 380 nd 430 nd nd nd nd S.F. Palouse @ Colfax 120 230 nd 350 nd nd nd nd Palouse R. @ Hooper nd 230 nd 230 180 nd nd nd Paradise Creek nd 180 110 290 nd nd 100 14Union Flat Creek 240 1,000 130 1,400 370 130 nd nd Pine Creek nd nd nd nd 92 nd nd nd Data from Munn and Gruber (1997) nd = not detected nr = analyzed but data not reported
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

Page 28

Generally similar results were obtained on the USGS sediment samples. (Note that these data 

are normalized to total organic carbon.) Total DDT concentrations were again elevated in the 

North and South Forks. The highest total DDT concentration, 1,400 ug/Kgoc, was reported in 

Union Flat Creek. PCBs were apparently not detected at or above 1.0 ug/Kgoc in the sediments, 

but the report is unclear on this point. Once again, alpha-BHC and heptachlor epoxide were not 

detected. There are no state standards or 303(d) criteria for pesticides or PCBs in freshwater 

sediments. 

Wagner and Roberts (1998) report USGS pesticide data for 72 filtered water samples from the 

Palouse basin, including the lower mainstem, North and South Forks, Paradise Creek, Rebel Flat 

Creek, Pine Creek, Rock Creek, and Union Flat Creek. The sampling was done in 1993–95. 

As with Ecology’s water samples, herbicides were the most frequently detected compounds. 

Table 8 summarizes the chlorinated pesticide data in Wagner and Roberts. Lindane is an 

insecticide currently approved for use on livestock in the Palouse basin. Lindane was routinely 

detected in the Palouse River at Hooper, being reported in half of the 44 samples analyzed from 

this location. Ten out of 28 samples from other sites in the basin also had lindane detected. The 

median and maximum concentrations at Hooper were 5 and 81 ng/L (parts per trillion), 

respectively. 

Table 8. USGS Data on Chlorinated Pesticides Detected in Water Samples Collected from the 

Palouse River Basin in 1993-95 (ng/L, dissolved, parts per trillion) 

Palouse River @ Hooper Other Palouse Basin Sites Chemical 

MDL* Median Maximum Detections MDL Median Maximum Detections

Lindane 4 5 81 22 4 <4 47 10 

Dieldrin 1 <1 10 3 1 - - - - 0 

4,4'-DDE 6 <6 3 3 6 - - - - 0 

alpha-BHC 2 <2 7 1 2 - - - - 0 

Data from Wagner and Roberts (1998) 

*MDL - method detection limit 

Other chlorinated pesticides were rarely detected in the USGS water samples. Three samples 

from the Palouse River at Hooper had detectable concentrations of dieldrin and 4,4’-DDE. 

Alpha-BHC was detected in one sample. Maximum concentrations were 10, 3, and 7 ng/L, 

respectively. Detection limits for these compounds were 1 ng/L for dieldrin, 2 ng/L for alphaBHC, and 6 ng/L for 4, 4’-DDE. Heptachlor epoxide was not analyzed. 

The lindane concentrations measured by USGS were at or below the Washington State aquatic 

life criterion of 80 ng/L for chronic exposure (Table 6). All but one sample met the 1.9 ng/L 

chronic aquatic life criterion for dieldrin. Detection limits for 4,4’-DDE in the USGS analyses 

were not low enough to compare with aquatic life criteria; the maximum concentration reported 

did exceed the 1 ng/L chronic criterion. There are no state aquatic life criteria for heptachlor 

epoxide, alpha-BHC, or hexachlorobenzene. 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

Page 29

Human health criteria are more restrictive than aquatic life criteria, ranging from 0.14 ng/L for 

dieldrin to 63 ng/L for lindane (Table 3). Approximately 15% of the USGS water samples 

exceeded human health criteria for lindane. Dieldrin and alpha-BHC concentrations exceeded 

human health criteria in 4% and 1% of samples, respectively. Detection limits for dieldrin, 

DDT compounds, and most other pesticides were not low enough to determine compliance with 

human health criteria in the majority of samples. 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

Page 30

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Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

Page 31

Recent Department of Ecology Studies 

Ecology conducted three recent field studies in response to the chlorinated pesticide and PCB 

listings for the Palouse River; the results of these studies are summarized below. The complete 

data generated by these efforts can be accessed through Ecology’s Environmental Information 

Management system (EIM, www.ecy.wa.gov/eim/). 

The Ecology Manchester Environmental Laboratory prepared written case narratives assessing 

the quality of these data. The reviews include a description of analytical methods and an 

assessment of holding times, tuning, initial and continuing calibration verification and 

degradation checks, method blanks, matrix spike/matrix spike duplicate recoveries, laboratory 

control samples, surrogate recoveries, laboratory duplicates, and standard reference materials. 

The case narratives are available on request. 

Overall, very few problems were encountered in the analysis of these samples. Some low-level 

results on fish and water samples were qualified as estimated values. Large amounts of 

interfering substances were encountered in the stormwater samples; all of the concentrations 

reported here are estimates. 

Low-level Pesticide Analysis 

The detection limits in the historical water quality data were not low enough to compare with the 

human health criteria at issue in the 303(d) listings. Therefore, Ecology analyzed a small set of 

reconnaissance samples to better determine current pesticide levels in the Palouse River. The 

analysis employed a large volume injection technique that gives detection limits in the sub-parts 

per trillion range. PCBs were not analyzed due to the high cost of a low-level analysis. 

Four samples were collected (Figure 3). One sample from the Palouse River at Hooper was 

analyzed for 29 chlorinated pesticides or breakdown products, including all compounds 

previously detected in the drainage. A second sample from this site and one sample each from 

the North and South Forks near Colfax were analyzed for DDT compounds only. The results are 

summarized in Table 9. At the time these samples were taken (May 11, 2004), river flow was 

237 cfs at Hooper. Total suspended solids ranged from 3–19 mg/L at the sampling sites. 

Six compounds were detected in the Hooper sample. These included three of the four 303(d) 

listed pesticides – 4,4’-DDE, heptachlor epoxide, and dieldrin, but not alpha-BHC – as well as 

lindane and endrin. Lindane was present at the highest concentration (0.68 ng/L) but did not 

exceed human health criteria. This is consistent with earlier USGS findings. Dieldrin exceeded 

human health criteria by a factor of 3. Heptachlor epoxide was at the criterion. Endrin did not 

exceed criteria. Other pesticides were not detected at or above 0.31 ng/L. 

4,4’-DDE concentrations in the four samples ranged from 0.091 to 0.16 ng/L. The highest 

concentration was in the South Fork. The human health criterion for 4,4’-DDE is 0.59 ng/L. 

Neither DDT nor its other major metabolite DDD was detectable at any of these sites. The 

human health criterion for DDT is 0.59 ng/L; the DDD criterion is 0.84 ng/L. 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

Page 32

Overall, these results point to dieldrin as being the major pesticide contaminant of concern at the 

time these samples were collected. 



Washington

Idaho



N.F. Palouse River

Rock Creek

Hooper

Endicott Colfax

Albion

Garfield

Pullman

Moscow

Palouse

Potlatch

S.F. Palouse River

P aradise Creek

Rebel F la t Creek

Co w Creek

Palouse Riv er

Union Flat Creek







0 5 10 15

Miles

Snake River

Figure 3. Location of Water Samples Collected by Ecology in May 2004.
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

Page 33

Table 9. Results of a Low-Level Analysis for Chlorinated Pesticides in the Palouse River 

Water Samples Collected by Ecology on May 11, 2004 (ng/L, parts per trillion) 

Sample No.:

4,4'-DDE 0.091 J 0.092 J 0.063 J 0.16 J

4,4'-DDT 0.38 U 0.37 U 0.38 U 0.37 U

4,4'-DDD 0.31 U 0.31 U 0.31 U 0.31 U

2,4'-DDE 0.31 U na na na

2,4'-DDT 0.31 U na na na

2,4'-DDD 0.31 U na na na

gamma-BHC (Lindane) 0.68 na na na

alpha-BHC 0.31 U na na na

beta-BHC 0.31 U na na na

delta-BHC 0.31 U na na na

Dieldrin 0.44 J na na na

Endrin 0.42 na na na

Endrin aldehyde 0.54 U na na na

Endrin ketone 0.31 U na na na

Aldrin 0.31 U na na na

Heptachlor 0.31 U na na na

Heptachlor epoxide 0.13 J na na na

Endosulfan I 0.11 J na na na

Endosulfan II 0.82 U na na na

Endosulfan sulfate 0.85 U na na na

Hexachlorobenzene 0.39 U na na na

Oxychlordane 0.31 U na na na

trans-Chlordane 0.31 U na na na

trans-Nonachlor 0.31 U na na na

cis-Chlordane 0.31 U na na na

cis-Nonachlor 0.31 U na na na

Methoxychlor 0.31 U na na na

Mirex 0.31 U na na na

Pentachloroanisole 0.31 U na na na

Site: Palouse R.

@ Hooper

N.F. Palouse

@ Colfax

204006

S.F. Palouse

@ Colfax

204008 204005 204007

Note: Detected concentrations in bold font 

J = The analyte was positively identified. The associated numerical result is an estimate 

U = The analyte was not detected at or above the reported result. 

na = not analyzed 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

Page 34

Expanded Fish Tissue Survey 

The 303(d) listings for the Palouse River were based on fish tissue data that were 10 to 20 years 

old. Because concentrations were likely to have changed since that time and because the number 

of samples analyzed were few and restricted to the lower river, Ecology undertook an expanded 

survey of chlorinated pesticides and PCBs in Palouse River fish during 2005. The objective was 

to determine if and where 303(d) criteria were exceeded and to make recommendations on the 

scope and focus for a TMDL. 

The design of the fish tissue survey is described in Johnson et al. (2005). Skin-on fillets were 

analyzed from five fish species collected by electrofishing or gill net in the North Fork, South 

Fork, and upper and lower mainstem between May and August 2005. Each sample was a 

composite consisting of pooled fillets from between three to five individuals per species. A total 

of 204 fish were analyzed for the study. Sampling sites are shown in Figure 4. Only two sites 

could be sampled on the lower mainstem because access to the river was limited. 



Washington

Idaho

Rock Creek

Hooper

Endicott Colfax

Albion

Garfield

Pullman

Moscow

Palouse

Potlatch

S.F. Palouse River

P aradise Creek

Rebel F la t Creek

Co w Creek

Palouse Riv er

Union Flat Creek

N.F. Palouse River



0 10 20

Miles

Snake River

 









   

Figure 4. Location of Fish Samples Collected by Ecology in May - August 2005. 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

Page 35

The species analyzed were smallmouth bass (Micropterus dolomieui), northern pike minnow 

Ptychocheilus oregonensis), largescale sucker (Catostomus macrocheilus), chiselmouth 

(Arcocheilus alutaceus), and common carp (Cyprinus carpio). Other species generally 

considered more desirable in this region’s sport fishery, such as rainbow trout, brown trout, and 

catfish, were not found at any location in the river. In most areas only pike minnow, suckers, 

and chiselmouth were encountered. Biological data on the specimens analyzed can be found in 

Appendix A. 

The fish samples were analyzed for 24 chlorinated pesticides/breakdown products and eight PCB 

mixtures. The concentrations of 303(d) listed chemicals detected in the samples are summarized 

in Table 10. Pesticides other than those listed in Table 10 either met human health criteria or 

were not detected. The complete chemical data are in Appendix B. 

Table 10. Mean Concentrations of 303(d) Listed Pesticides and PCBs in Palouse River Fish 

Fillets Analyzed by Ecology in 2005 Compared to Human Health Criteria (ug/kg, wet weight; 

parts per billion) (Highlighted values exceed human health criteria) 

 Reach 

No. of 

Composite 

Samples 

 alpha-BHC Heptachlor 

epoxide 4,4'-DDE Dieldrin Total PCBs 

Lower Mainstem 10 0.40 U 0.40 U 13 1.1 4.4 

Upper Mainstem 10 0.40 U 0.40 U 25 0.84 7.2 

South Fork 12 0.40 U 0.40 U 27 1.6 18 

North Fork 14 0.40 U 0.40 U 25 0.34 3.9 

303(d) Human Health Criteria 1.7 1.2 32 0.65 5.3 

U = not detected at or above reported value 

None of the Palouse fish samples exceeded human health criteria for alpha-BHC or heptachlor 

epoxide. The average 4,4’-DDE concentration met the criterion in all areas. Dieldrin and PCBs 

were close to human health criteria levels in both upper and lower mainstem fish. There were 

moderate PCB and dieldrin exceedances in the South Fork. There were no exceedances in the 

North Fork for PCBs, dieldrin, or the other 303(d) listed pesticides. 

These results are consistent with the reconnaissance sampling of river water Ecology conducted 

the previous year. The North Fork fish tissue samples show no evidence of the elevated 

pesticide/PCB concentrations reported by USGS in limited fish samples from the early 1990s, 

previously described. 

The pesticide and PCB levels measured in lower Palouse River fish in 2005 were one-to-two 

orders of magnitude lower than those found by Ecology in 1984 and 1994 and on which the 

303(d) listings are based (Table 5). Relative to human health criteria, the highest concentrations 

in 2005 were for dieldrin and PCBs in South Fork fish, 1.6 and 18 ug/Kg, respectively, on 

average. 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

Page 36

Figure 5 compares the Palouse River PCB data to statewide fish tissue data Ecology and EPA 

have collected in recent years, as reported by Seiders and Kinney (2004). As shown in this 

figure, the mean total PCB concentrations in fish from the Palouse River rank among the lower 

10% or lower 20% (South Fork) of fish samples statewide. Because of variable and often high 

detection limits in the statewide data, a similar comparison cannot be made for dieldrin. 

Historically, lindane has exceeded human health criteria in Palouse River water samples. Low 

concentrations of 0.091–1.2 ug/Kg were detected in 60% of Ecology’s 2005 fish samples 

(Appendix B). The human health fish tissue criterion for lindane is 8.2 ug/Kg. 

Lindane is only slightly bioaccumulated by aquatic organisms. Lindane (gamma-BHC) 

isomerizes to alpha-, beta-, and delta-BHC by biological processes and to beta-BHC by 

photochemical reaction (Callahan et al., 1979). Lindane does not appear to be a human health 

concern for fish consumption in the Palouse River and is therefore not considered further in this 

TMDL. 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

Page 37

1

10

100

1000

10000

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Percentile (n=350)

Total PCBs (ug/Kg, ww)

Statewide values

Figure 5. Mean Total PCB Concentrations in Palouse River Fish Compared to Freshwater 

Edible Fish Tissue Samples Collected Statewide (modified from Seiders and Kinney, 2004)

Lower Mainstem Palouse River

North Fork Palouse River

Upper Mainstem Palouse River

South Fork Palouse River
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

Page 38

Stormwater Pilot Study 

The Phase II Municipal Stormwater Permits for Eastern Washington became effective in 

February 2007, under the National Pollutant Discharge Elimination System (NPDES). Phase II 

communities are identified under the rule as jurisdictions that: (1) own and operate a stormwater 

system; (2) discharge to surface waters; (3) are located in urbanized areas; and (4) have a 

population of greater than 10,000. Pullman is the only Washington town in the Palouse River 

basin with a population over 10,000 and is thus likely to be regulated under Phase II. EPA has 

not made a final decision on Phase II permitting for Moscow, Idaho. 

In November 2002, EPA issued a Policy Memorandum on Wasteload Allocations for 

Stormwater indicating that stormwater discharges from permitted entities must be addressed 

under wasteload allocations established for TMDLs. In 2005, Ecology received a grant from 

EPA to conduct a pilot project to estimate the municipal stormwater load of pollutants from 

Phase II cities. In view of the TMDLs scheduled for the Palouse basin – which, in addition to 

toxics, include temperature, fecal coliform bacteria, dissolved oxygen, nutrients, and pH – 

Ecology decided to conduct the study in Pullman. The technical studies being conducted for 

these other TMDL parameters are described in Mathieu and Carroll (2006) and Bilhimer et al. 

(2006). 

The design of the Pullman stormwater study is detailed in Lubliner (2005). For purposes of this 

study, a storm event was defined as 0.2 inches of rainfall in a 24-hour period. Precipitation 

probabilities for Pullman are shown in Figure 6. As indicated in this figure, the probability of 

precipitation exceeding 0.2 inches is approximately 10% for November through March and less 

than 10% for April through September. 

Figure 6. One-Day Precipitation Probabilities in Pullman, WA (Lubliner, 2005)
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

Page 39

Stormwater runoff from Pullman drains to four creeks: Airport Creek, Paradise Creek, Missouri 

Flat Creek, and Dry Creek. Airport Creek empties into Paradise Creek at the Pullman city limits. 

The other three creeks are tributaries that converge with the South Fork Palouse River in 

Pullman. 

Three storm drains were selected for sampling (Figure 7). The Stadium Way drain serves the 

largest stormshed in Pullman, and land use is characteristic of the city as a whole, including light 

commercial, residential, and portions of Washington State University (WSU). The second site, 

College Street, drains the southwestern side of WSU. Benewah Street drains the southern end of 

the WSU campus, including high density residential, and several commercial areas along 

Highway 270 and Latah Street. 

Figure 7. Pullman Area Showing Sampling Sites for 2005-06 Stormwater Pilot Study (Lubliner, 

2006). 

The storm drains were sampled over three storm events during the winter and early spring of 

2005-2006 and analyzed for chlorinated pesticides, PCBs, fecal coliform bacteria, and ancillary 

water quality parameters. Each pesticide/PCB sample was a grab composite that covered the 

first three hours of the storm. 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

Page 40

The results for 303(d) listed pesticides and PCBs are summarized in Table 11. Pesticides other 

than those listed in Table 11 either met human health water quality criteria or were not detected. 

Table 11. Concentrations of 303(d) Listed Pesticides and PCBs in Pullman Stormwater Samples 

Collected in 2005-06 (ng/L, parts per trillion) 

 Storm drain Date alphaBHC 

Heptachlor 

epoxide 

 4,4'-

DDE Dieldrin Total PCBs 

10/13/2005 0.49 J 0.39 J 2.0 J 3.1 UJ 4.1 

Stadium Way 1/30/2006 0.10 J 0.16 J 2.0 J 0.50 J 1.5 

4/5/2006 0.20 J 0.18 J 4.8 J 0.36 J 11 

10/13/2005 0.46 J 0.38 J 1.3 J 0.37 J 8.3 

College Street 1/30/2006 0.21 J 0.33 J 1.7 J 0.53 J 18 

4/5/2006 0.15 J 0.16 J 1.5 J 0.11 J 13 

10/13/2005 0.52 J 0.32 UJ 2.0 J 1.3 J 17 

Benewah Street 1/30/2006 0.17 J 0.23 J 3.3 J 5.0 J 18 

4/5/2006 0.20 J 0.20 J 1.4 J 2.0 J 45 

Human Health WQ Criteria* 13 0.11 0.59 0.14 0.17 

UJ = The analyte was not detected at or above the reported estimated result. 

J = The analyte was positively identified. The associated numerical result is an estimate. 

*for fish consumption 

303(d) pesticides and PCBs were detected in all of the Pullman storm drain samples. Dieldrin 

and PCBs were present at the highest concentrations, 0.11–5.0 and 1.5–45 ng/L, respectively. 

Human health criteria were substantially exceeded for dieldrin (0.14 ng/L) and PCBs 

(0.17 ng/L). The highest concentrations were recorded for the Benewah Street drain, followed 

by College Street and, lastly, Stadium Way. 

A final report on the stormwater study has been completed: Pullman Stormwater Pilot Study for 

Pesticides, PCBs, and Fecal Coliform Bacteria, 2005-2006 (Lubliner, 2006). 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

Page 41

Evaluation of Other Potential Sources 

NPDES Discharges 

Washington facilities that currently have NPDES permits to discharge to surface water in the 

Palouse basin are listed in Table 12. All the surface water discharges are from wastewater 

treatment plants (WWTPs). 

Table 12. Washington WWTPs that Discharge to Surface Water in the Palouse River Basin 

Facility Type Size Receiving Water 

Albion Municipal Minor South Fork Palouse River 

Colfax Municipal Minor Mainstem Palouse River 

Colton Municipal Minor Union Flat Creek 

Endicott Municipal Minor Rebel Creek 

Garfield Municipal Minor Silver Creek 

Oakesdale Municipal Minor Pine Creek 

Palouse Municipal Minor North Fork Palouse River 

Pullman Municipal Major South Fork Palouse River 

Rosalia Municipal Minor Pine Creek 

St. John Municipal Minor Pleasant Valley Creek 

Pesticide and PCB data have been reported for the Pullman WWTP, the largest NPDES 

discharger in the Washington portion of the basin (City of Pullman, 1999). Pullman discharges 

to the South Fork. 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

Page 42

Composite samples of Pullman’s final effluent were analyzed in 1997 and 1999. No chlorinated 

pesticides or PCBs were detected in either sample. The 1999 data are shown in Table 13. 

Pesticides and PCBs have not been analyzed in effluent from other Washington WWTPs or from 

the Moscow WWTP (Sonia Vidanage, EPA Region 10, 2/24/06 email). 

Table 13. Results of a Chlorinated Pesticide and PCB Analysis on a Composite Effluent 

Sample Collected from the Pullman WWTP on October 9, 1999 (ug/L; parts per billion) 

Chemical Concentration

4,4'-DDE 0.05 U 

4,4'-DDT 0.05 U 

4,4'-DDD 0.05 U 

gamma-BHC (Lindane) 0.05 U 

alpha-BHC 0.05 U 

beta-BHC 0.05 U 

delta-BHC 0.05 U 

Dieldrin 0.05 U 

Endrin 0.05 U 

Endrin aldehyde 0.05 U 

Aldrin 0.05 U 

Heptachlor 0.05 U 

Heptachlor epoxide 0.05 U 

Endosulfan I 0.05 U 

Endosulfan II 0.05 U 

Endosulfan sulfate 0.05 U 

Hexachlorobenzene 0.05 U 

Chlordane 0.05 U 

Methoxychlor 0.05 U 

PCB-1016 0.50 U 

PCB-1221 0.50 U 

PCB-1232 0.50 U 

PCB-1242 0.50 U 

PCB-1248 0.50 U 

PCB-1254 0.50 U 

PCB-1260 0.50 U 

U = The analyte was not detected at or above the reported result. 

Although no chlorinated pesticides or PCBs were detected in Pullman effluent, the detection 

limits were not low enough to determine if human health criteria were exceeded. In many cases 

the criteria are two or more orders of magnitude lower. 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

Page 43

Hazardous Waste/Toxics Cleanup Sites 

The Ecology Eastern Regional Office (ERO) was consulted to determine if there are hazardous 

waste or toxics cleanup sites in the Palouse River basin that could be sources for the chemicals of 

concern in this TMDL. Table 14 provides a listing and assessment of sites of potential interest. 

Ten sites have been investigated. There is no evidence that any of these sites are sources of 

chlorinated pesticides or PCBs to the Palouse River. 

Table 14. Hazardous Waste/Toxic Cleanup Sites Evaluated for the Palouse River Chlorinated 

Pesticides and PCB TMDL (prepared by Lisa Brown HWTR and Elaine Snouwaert WQP, 

Ecology Eastern Regional Office) 

Site Name (Location) Comment 

Rogers Bros/NK Seed 

Sumner N & 3rd, Colfax 

Site had soil and groundwater contamination that included dieldrin. 

All contaminated soils have been removed. Calculations indicated 

groundwater has low potential to affect dieldrin concentrations in the 

Palouse River 

Colfax Grange Supply 

Walla Walla Highway 

Inspected in 1995. Some areas of concern, but limited to currently used 

pesticides. 

Passmore Aviation 

Route 1, Box 21, LaCrosse Does not appear to be of concern for the TMDL. 

Dale's Flying Service 

Route 1, Box 12, Palouse Does not appear to be of concern for the TMDL. 

Nu-Chem 

2622 S. Grand, Pullman Does not appear to be of concern for the TMDL. 

McKiernan Bros Farm & Auto 

Palouse Highway, Pullman Most recent concerns had to do with oil. 

Dion Flying Service 

Rosalia Airport 

Received complaint in 1997, followed with an inspection. The concern 

was limited to currently used chemicals draining to the ground. 

Rosalia Producers 

Rosalia Does not appear to be of concern for the TMDL. 

Laramie Davis (crop duster) 

RR2, Box 3, St. John Does not appear to be of concern for the TMDL. 

Sprague Grange Supply 

Box 307, Sprague Inspected in 1993, no mishandlings of chemicals. 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

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Abandoned Landfills/Dumps 

Old municipal landfills and dumps located on or near the Palouse River are potential sources of 

chlorinated pesticides and PCBs. The following relevant information was obtained through ERO 

files. 

• The City of Pullman used to dump refuse directly into the South Fork just west of town. A 

closed landfill is located near this site. There is no sign of a direct discharge, but it is near 

the river. An incinerator used for burning municipal garbage and other waste material was 

also located on the north bank about 1⁄2 mile downstream. Ash, bricks, and other residues 

from this facility are still evident on the river bank. 

• High water events in 1996-97 uncovered an old dump site about two miles downstream of 

Colfax on the mainstem. An oxbow was fortified at the upstream end with automobile 

bodies. The channel was then used as a disposal site until the early 1970s when it was 

covered. Refuse was visible for miles downstream after the flood waters receded. Whatever 

toxics were associated with this site appear to have been flushed out over the years. Refuse 

that did not wash away was covered in place. 

• The Whitman County Health Department collected water samples at this site in May 1997. 

Two samples were analyzed: one from an eroded channel that cut through the fill and another 

from a seep of discolored water on the river side of the fill. No chlorinated pesticides or 

PCBs were detected at or above 1.0 ug/L (unpublished data collected by John Skyles, 

Whitman County Health Department, Colfax). 

Marti and Chern (1991) assessed groundwater and surface water contamination at the 

Washington State University chemical waste landfill in Pullman. The landfill was located on 16 

acres at the eastern edge of the campus on a south facing slope bordered by Airport Creek, a 

tributary to Paradise Creek. Marti and Chern concluded that “In general, contaminant 

concentrations were low, confirming previous groundwater sample results.” Low concentrations 

(<1.0 ug/L) of chlorinated pesticides were detected in only 1 of the 16 wells sampled. The 

detections included DDT compounds and heptachlor epoxide, but not dieldrin or alpha-BHC. 

No chlorinated pesticides were detected in an Airport Creek water sample collected downstream 

of the site. PCBs were not detected in any groundwater or surface water samples. 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

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TMDL Analysis

Loading Capacity 

Loading capacity is the maximum amount of a pollutant that can be delivered to a waterbody and 

still achieve water quality standards. Loading capacity can be calculated by multiplying 

streamflow by the pollutant water quality criterion. EPA recommends using the long-term 

harmonic mean flow for carcinogens, since the adverse impacts are realized over a lifetime of 

exposure (EPA, 1991). Harmonic mean is the appropriate measure of central tendency when 

dealing with rates, in this case rates of flow. The harmonic mean is always less than the 

arithmetic mean and is expressed as Qh = n/∑(1/Qi) where n is the number of recorded flows Qi. 

As previously described, flows in the South Fork Palouse River can be comprised primarily of 

WWTP effluent any month of the year. For effluent dominated streams such as the South Fork, 

EPA (1991) recommends using the arithmetic mean flow. 

The loading capacity of the mainstem and South Fork was calculated for 303(d) listed chemicals 

(Table 15). The harmonic mean for the mainstem Palouse River was derived from USGS 

historical streamflow data for Hooper. The arithmetic mean for the South Fork is based on the 

combined flow of the South Fork Palouse River at Pullman and Missouri Flat Creek. (The 

period of record for the USGS gauging station on the South Fork at Colfax was limited to 1993-

95, so the data were not sufficient to use in this analysis.) Pelletier (1993) observed a trend 

toward increasing flows in the South Fork during the period 1960-80, which was attributed to 

increasing flows out of the Moscow WWTP. The mean flow was therefore calculated using data 

from 1980–2003 (most recent verified data currently available). Loading capacities are 

substantially less than one gram per day for most chemicals. 

Table 15. Loading Capacity of the Palouse River for 303(d) Listed Pesticides and PCBs 

 

 

Reach/Chemical 

Human Health 

Water Quality Criteria 

(ng/L) 

Loading 

Capacity 

(grams/day) 

Mainstem (harmonic mean flow = 76 cfs*)

alpha-BHC 13 2.4 

Heptachlor epoxide 0.11 0.020 

4,4'-DDE 0.59 0.11 

Dieldrin 0.14 0.026 

Total PCBs 0.17 0.032 

South Fork (arithmetic mean = 38 cfs†

 )

alpha-BHC 13 1.2 

Heptachlor epoxide 0.11 0.010 

4,4'-DDE 0.59 0.055 

Dieldrin 0.14 0.013 

Total PCBs 0.17 0.016 

*USGS site #13351000 Palouse River @ Hooper 

†

USGS site #13348000 S.F. Palouse River @ Pullman plus site #1332800 Missouri Flat Creek @ Pullman 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

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Loading capacity can also be expressed in terms of the contaminant concentration in the water. 

The 2005 fish tissue data were used to back-calculate ambient water column concentrations and 

make a determination as to the current status of the river with respect to loading capacity for 

303(d) listed pesticides and PCBs (Table 16). The mean fish tissue values were used in the 

calculation. This is appropriate since the human health water quality criteria apply to the average 

exposure (dose) over a lifetime of fish consumption. 

Table 16. Loading Capacity Status of the Palouse River, Based on Fish Tissue Concentrations of 

303(d) Listed Pesticides and PCBs 

Mean Fish Tissue EPA Bioconcentration Est. Ambient Water Human Health Exceedance

Concentration Factor Concentration * WQ Criteria Factor

(ug/Kg) (L/Kg) (ng/L) (ng/L) for Water†

Lower Mainstem

alpha-BHC <0.40 130 <3 13 <1

Heptachlor epoxide <0.40 11,200 <0.04 0.11 <1

4,4'-DDE 13 53,600 0.24 0.59 <1

Dieldrin 1.1 4,670 0.24 0.14 1.7

Total PCBs 4.4 31,200 0.14 0.17 <1

Upper Mainstem

alpha-BHC <0.40 130 <3 13 <1

Heptachlor epoxide <0.40 11,200 <0.04 0.11 <1

4,4'-DDE 25 53,600 0.47 0.59 <1

Dieldrin 0.84 4,670 0.18 0.14 1.3

Total PCBs 7.2 31,200 0.23 0.17 1.4

South Fork

alpha-BHC <0.40 130 <3 13 <1

Heptachlor epoxide <0.40 11,200 <0.04 0.11 <1

4,4'-DDE 27 53,600 0.50 0.59 <1

Dieldrin 1.6 4,670 0.34 0.14 2.4

Total PCBs 18 31,200 0.58 0.17 3.4

North Fork

alpha-BHC <0.40 130 <3 13 <1

Heptachlor epoxide <0.40 11,200 <0.04 0.11 <1

4,4'-DDE 25 53,600 0.47 0.59 <1

Dieldrin 0.34 4,670 0.07 0.14 <1

Total PCBs 3.9 31,200 0.13 0.17 <1

Reach/Chemical

*fish tissue concentration / bioconcentration factor x 0.001 (unit conversion factor) 

†

estimated ambient water concentration / human health water quality criteria 

Based on Table 16, the following conclusions appear warranted with respect to the Palouse 

River’s loading capacity for the pesticides and PCBs of concern in this TMDL: 

• The mainstem Palouse River (below Colfax) is below loading capacity for 4,4’-DDE, 

heptachlor epoxide, and alpha-BHC, but slightly exceeds loading capacity for dieldrin and 

for PCBs in the upper mainstem only. 

• The South Fork Palouse River is below loading capacity for 4,4’-DDE, heptachlor epoxide, 

and alpha-BHC, but exceeds loading capacity for dieldrin and PCBs by factors of 2–3. 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

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• The North Fork Palouse River is below loading capacity for 4,4’-DDE, heptachlor epoxide, 

alpha-BHC, dieldrin, and PCBs. 

This analysis supports a change in the listing status for 4,4’-DDE, heptachlor epoxide, and alphaBHC in the Palouse River. The current Category 5 listings (Polluted Waters that Require a 

TMDL) for these compounds should be moved to Category 1 (Meets Tested Standards for Clean 

Waters). 

The remainder of Part 1 of this report is devoted to the development of a TMDL for dieldrin and 

PCBs in the mainstem and South Fork Palouse River. 

Wasteload and Load Allocations 

A TMDL must identify the total pollutant amount allowed and its components: appropriate 

wasteload allocations for point sources; load allocations for nonpoint sources; and natural 

background. The allocations proposed for dieldrin and PCBs in the Palouse River are shown in 

Table 17. 

Table 17. Wasteload and Load Allocations for Dieldrin and PCBs in the Palouse River 

(grams per day) 

Source Total 

PCBs Dieldrin 

South Fork Palouse River 

Wasteload Allocations 

 Pullman WWTP (interim WLA) 0.0022 0.0018 

 Albion WWTP (interim WLA) 0.0001 0.0001 

 Stormwater BMPs BMPs 

Load Allocations 

 Nonpoint 0.010 0.008 

 Natural Background 0 0 

Margin of Safety 0.0032 0.0026 

Total Allocations 0.016 0.013 

TMDL 0.016 0.013 

Mainstem Palouse River 

Wasteload Allocations 

 Colfax WWTP (interim WLA) 0.0004 0.0003 

Load Allocations 

 Nonpoint 0.026 0.021 

 Natural Background 0 0 

Margin of Safety 0.0064 0.0052 

Total Allocations 0.032 0.026 

TMDL 0.032 0.026 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

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The data that were available to determine if WWTP discharges were causing or contributing to 

exceedances of human health water quality criteria for dieldrin or PCBs in the Palouse River 

were extremely limited and insufficient to determine compliance with the criteria. Effluent 

samples analyzed for TMDLs in other parts of Eastern Washington show that PCBs and dieldrin 

are discharged from WWTPs, with PCBs commonly exceeding criteria (Golding, 2001; 

Serdar, 2003; Johnson et al., 2004). 

Although Ecology suspects that the main sources of PCB and dieldrin are from nonpoint sources, 

the widespread presence of PCB and dieldrin in the environment increases the likelihood they are 

present in the WWTP effluents. Therefore wasteload allocations (WLAs) were assigned for the 

Pullman, Albion, and Colfax WWTPs (Table 18). Because the receiving waters already exceed 

loading capacity for these compounds, the WLAs were set to meet the human health criteria at 

the end of pipe for each facility’s design flow. These are interim WLAs that will be revised as 

more knowledge is gained about the levels being discharged. 

Table 18. PCB and Dieldrin Interim Wasteload Allocations for Palouse River Wastewater 

Treatment Plants 

 WWTP Chemical 

 Design 

Flow 

(mgd) 

Human 

Health 

Criteria 

(ng/L) 

Interim 

WLA* 

(grams/day) 

Total 

PCBs 3.4 0.17 0.0022 Pullman 

Dieldrin 3.4 0.14 0.0018 

Total 

PCBs 0.12 0.17 0.0001 Albion 

Dieldrin 0.12 0.14 0.0001 

Total 

PCBs 0.60 0.17 0.0004 Colfax 

Dieldrin 0.60 0.14 0.0003 

* = mgd x criteria/1000 x 3.79 

As previously described, storm events in the Palouse are infrequent and of short duration. EPA 

recognizes that establishing numeric limits for municipal stormwater discharges is rarely feasible 

because of the variability of storm events (EPA, 2002). EPA therefore recommends that effluent 

limits for NPDES-regulated municipal stormwater discharges should be expressed as best 

management practices (BMPs) rather than as numeric limits (EPA, 2002). BMPs for Pullman 

stormwater are described in the implementation plan (Part 2 of this report). 

For nonpoint sources, the load allocations for dieldrin and PCBs were set equal to the loading 

capacities (Table 15) minus the sum of the wasteload allocations and margin of safety. Because 

dieldrin and PCBs are man-made chemicals, there is no contribution from natural background. 

Therefore the load allocation for natural background is zero for both chemicals. 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

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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. In recognition of the 

uncertainties associated with stormwater and WWTP loading of PCBs and dieldrin, including 

those from the Moscow area, this TMDL includes a safety margin of 20% of the loading 

capacities of the South Fork and mainstem Palouse River (Table 15). 

Achieving Water Quality Standards 

Dieldrin was widely used in the United States from 1950 to 1974 as a broad spectrum insecticide 

on termites and other soil-dwelling insects, and on corn, cotton, citrus, and other crops. As such, 

it is primarily associated with nonpoint sources. In an EPA (1992) national study of chemical 

residues in freshwater fish, dieldrin concentrations decreased according to the following land use 

categories: agricultural > urban/industrial > wastewater treatment plants. EPA banned the use of 

dieldrin on food products in 1974. All uses were voluntarily cancelled by industry in 1984. 

(EPA, 1992 and 2000). 

PCBs are commercial products containing various mixtures of chlorinated biphenyls. In the 

United States, PCBs were produced commercially from 1929 until 1977. After 1974, PCBs were 

primarily used as dielectric (nonconductor) fluids in capacitors and transformers. Prior to 1974 

other uses of PCBs included: plasticizers in plastic and rubber products; lubricants in hydraulic 

and vacuum fluids; ink carriers and solvents in making carbonless paper; and as a sealer for 

gaskets and furnaces. The EPA (1992) study found the highest PCB residues in fish from 

urban/industrial rivers and streams. Thus, like dieldrin, PCBs are primarily a nonpoint pollutant, 

but associated with urban areas more so than agriculture. In 1974, EPA banned the productionbased discharge of PCBs. Their manufacture, processing, and distribution in commerce were 

banned in 1979; continued use was allowed in closed electrical systems. In 1982 and 1985, 

further restrictions were placed on PCBs in electrical equipment. 

As with other chemicals banned by EPA, environmental concentrations of dieldrin and PCBs 

have decreased over time. The effects of the ban are evident in lower Palouse River fish, where 

the concentrations measured in 2005 are one to two orders of magnitude lower than those 

recorded in 1984 and 1995 (Table 19). The trend toward decreasing concentrations of PCBs, 

dieldrin, and other 303(d) listed chemicals in the lower Palouse River is illustrated in Figure 8. 

Reduced soil erosion in the Palouse watershed has probably also played a part in lowering 

contaminant concentrations in the fish. 

 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

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Table 19. Comparison of Historical and Recent Data on 303(d) Listed Pesticides and PCBs 

in Lower Mainstream Palouse River Fish (ug/Kg, wet weight) 

1984/1994 2005 

Chemical (1-3 

composite 

samples)

(mean of 10 

composites 

samples) 

alpha-BHC 16 - 37 <0.40 

Heptachlor epoxide 6.3 <0.40 

4,4'-DDE 73 - 137 13 

Dieldrin 7 1.1 

Total PCBs 11 4.4 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

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Figure 8. Time Trends in Levels of 303(d) Listed Pesticides and PCBs in Fillets from Lower 

Palouse River Fish (ug/Kg, wet weight; parts per billion) 

4,4'-DDE

0

20

40

60

80

100

120

140

160

1980 1985 1990 1995 2000 2005

Fish Tissue Conc. (ug/Kg, wet)

Alpha BHC

0

5

10

15

20

25

30

35

40

1980 1985 1990 1995 2000 2005

Fish Tissue Conc. (ug/Kg, wet)

Heptachlor epoxide

0

2

4

6

8

10

12

14

1980 1985 1990 1995 2000 2005

Fish Tissue Conc. (ug/Kg, wet)

Dieldrin

0

2

4

6

8

10

12

14

16

1980 1985 1990 1995 2000 2005

Fish Tissue Conc. (ug/Kg, wet)

Total PCBs

0

2

4

6

8

10

12

14

16

18

20

1980 1985 1990 1995 2000 2005

Fish Tissue Conc. (ug/Kg, wet)
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

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The goal of a TMDL is to develop a plan to achieve water quality standards in a waterbody. For 

the Palouse River, the specific goal is to reduce the levels of dieldrin and PCBs in the mainstem 

and South Fork to the point where there is no significant human health risk from long-term fish 

consumption. The numeric targets for achieving this objective are the 303(d) fish tissue criteria, 

which are based directly on the water quality criteria.. Estimates of the further reductions 

required to meet the targets and bring the river into compliance with water quality standards are 

shown in Table 20. Concentrations need to be reduced from approximately 0–41% in the 

mainstem and 59–71% in the South Fork. No reductions are required in the North Fork. 

Table 20. Estimates of Reductions Needed in Fish Tissue Concentrations of Dieldrin and PCBs 

to Meet Water Quality Standards in the Palouse River 

Reach/Chemical 

Mean Fish Tissue 

Concentration 

(ug/Kg) 

Numeric Fish Tissue 

Target for TMDL 

(ug/Kg) 

Reduction Required 

to Meet Standards 

(%) 

Lower Mainstem 

Dieldrin 1.1 0.65 41 

Total PCBs 4.4 5.3 0 

Upper Mainstem 

Dieldrin 0.84 0.65 23 

Total PCBs 7.2 5.3 26 

South Fork 

Dieldrin 1.6 0.65 59 

Total PCBs 18 5.3 71 

North Fork 

Dieldrin 0.34 0.65 0 

Total PCBs 3.9 5.3 0 

It is proposed that natural attenuation, monitoring, and BMPs be relied on to bring the Palouse 

River into compliance with water quality standards for dieldrin and PCBs. A monitored natural 

attenuation approach is warranted for a number of reasons: 

• The levels are low relative to human health criteria. 

• The chemicals of concern are no longer used. 

• Fish tissue concentrations have decreased over the past 10–20 years and will continue to 

decrease without further action being taken. 

• A monitored natural attenuation approach is consistent with EPA-approved TMDLs in other 

states with similar 303(d) listings 

(e.g., www.epa.gov/owow/tmdl/examples/pesticides/pa_cheat.html). 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

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The Washington State Department of Health (WDOH) does not consider this level of fish 

contamination to represent a significant human health risk. WDOH does not consider a fish 

consumption advisory to be warranted (Dave McBride, WDOH, personal communication). 

It is not possible to predict with certainty how long it will take for water quality standards to be 

achieved in the Palouse River, thus the need for monitoring. The mainstem is close to meeting 

the TMDL targets for dieldrin and PCBs at the present time. By inspection, the rates of decrease 

in lower mainstem fish (Figure 8) imply a half-life of approximately 10 years for both dieldrin 

and PCBs (1995 and 2005 data). If these rates apply to the South Fork – which appears to be the 

major source of contamination – compliance would be achieved in the South Fork within 10–15 

years for dieldrin and within 15–20 years for PCBs. Similarly, the mainstem would be expected 

to comply within about 5 years. These conclusions are based on limited historical data. 

Seasonal Variation 

Seasonal increases and decreases in concentration are less important than the long-term exposure 

to a carcinogen. Fish integrate water column concentrations over time. Therefore, using fish 

tissue data to assess loading capacity and set numeric TMDL targets adequately considers 

seasonal variations of water column concentrations for 303(d) listed pesticides and PCBs in the 

Palouse River. 

Recommendations 

1. The 303(d) Category 5 listings (Polluted Waters that Require a TMDL) for 4,4’-DDE, 

heptachlor epoxide, and alpha-BHC in the Palouse River should be moved to Category 1 

(Meets Tested Standards for Clean Waters). 

2. Ecology should periodically monitor fish tissue for dieldrin and PCBs in the mainstem 

Palouse River below Colfax and in the South Fork Palouse River to assure levels are 

continuing to decline at the expected rate. 

3. PCBs and dieldrin in the influent and effluent of South Fork Palouse River WWTPs should 

be monitored to fill the data gap on sources to and loading from these facilities. 

4. In light of elevated concentrations of dieldrin and PCBs in Pullman stormwater and the 

potential for adverse water quality impacts, Ecology, the City of Pullman, and Washington 

State University should work cooperatively to identify and clean up sources of these 

chemicals to the storm drain system. 

5. An effort should be made to identify abandoned landfills and old dumps vulnerable to high 

water events or surface runoff during storms, determine if they are sources of dieldrin or 

PCBs to the Palouse River, and remediate as needed. 

6. It is anticipated that most sources of dieldrin and PCB are from nonpoint sources. However, 

if levels do not continue to decline in Palouse River fish as anticipated, then the Moscow, 

Idaho WWTP should be re-evaluated as a possible contributor to the problem. Initially this 

could consist of sampling Paradise Creek to quantify dieldrin and PCB loading from the 

Moscow area. 

7. Chemical analysis of the above samples should use detection limits low enough to compare 

to human health water quality criteria. 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

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Part 2 
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Implementation Plan 

Introduction 

This implementation plan is intended to describe the framework for improving water quality. It 

expands on the recommendations made in Part 1 of this report. This plan describes the roles and 

authorities of cleanup partners (i.e., those organizations with jurisdiction, authority, or direct 

responsibility for cleanup) and the programs or other means through which they will address 

these water quality issues. 

Typically, Ecology produces an implementation strategy which is submitted with the technical 

analysis to the U.S. Environmental Protection Agency (EPA) for approval of the TMDL. Then, 

following EPA approval, Ecology and interested and responsible parties develop a Water Quality 

implementation plan. However, this implementation plan will serve as both the implementation 

strategy and the implementation plan. 

This implementation plan describes how water quality standards will be met for dieldrin and 

PCBs. TMDL reductions should be achieved by 2012 for dieldrin and PCBs in the mainstem 

Palouse River and by 2017 for dieldrin and 2022 for PCBs in the South Fork Palouse River.

What Needs to be Done? 

Four chlorinated pesticides (heptachlor epoxide, 4,4’-DDE, dieldrin, and alpha-BHC) and PCBs 

were listed on the 2004 303(d) list as an impairment to the Palouse River. The TMDL analysis 

demonstrates that heptachlor epoxide, 4,4’-DDE, and alpha-BHC currently meet human health 

criteria and therefore water quality standards. Ecology recommends that these listings be moved 

from Category 5 (the 303(d) list) to Category 1 (Meets tested standards) during the next Water 

Quality Assessment. 

According to the Water Quality Program’s Policy 1-11 (Ecology 2006), to move a Category 5-

listed water body segment to Category 1, new data must meet the following requirements and be 

collected in a manner consistent with the policy: 

A Category 5 determination will be changed if a more recent assessment qualifies a 

waterbody segment for placement in another category. 

A more recent toxic pollutant assessment that results in a Category 5 change must be based 

on data from the same medium (tissue or water column) as was assessed to determine initial 

impairment. The change of a Category 5 determination may also occur if information from a 

TMDL or verification study confirms that the impairment no longer exists. 

Fin fish fillet tissue samples, whole shellfish tissue samples, and edible shellfish muscle 

samples must have at least three single-fish samples or a single composite sample made up of 

at least five separate fish of the same species. Fin fish fillet tissue samples may be analyzed 

with skin on or skin off. All fish samples must be from resident fish to be considered for 

Categories 1 or 5. 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

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Due to local migration of species, toxic pollutant tissue studies that collect samples near 

Category 5 waterbody segments may be sufficient to represent more recent water quality 

conditions of the local area. In this case, tissue data and rationale that the samples collected 

from an adjacent or nearby waterbody segment are comparable may be considered for 

change in category determination. 

The data from the current study meets these conditions. Table 21 lists the river segments which 

will be recommended for this change. 

Table 21. 2004 303(d) Listings Recommended for a Category 1 (Meets tested standards) 

Classification. 

Listing 

Identification 

number 

Waterbody Parameter Township Range Section 

14190 Palouse River 4,4’-DDE 15N 37E 26 

8819 Palouse River 4,4’-DDE 17N 40E 20 

14191 Palouse River Alpha-BHC 15N 37E 26 

8822 Palouse River Heptachlor epoxide 17N 40E 20 

Two remaining parameters (dieldrin and PCBs) currently violate water quality standards in the 

South Fork Palouse River and the mainstem Palouse River. Ecology will rely on natural 

attenuation and the implementation of stormwater and agricultural BMPs and effluent wasteload 

allocations to bring the Palouse River and the South Fork Palouse River into compliance with 

water quality standards. Monitoring will be conducted to track the progress in meeting water 

quality standards. 

This TMDL implementation plan also addresses the additional river segments found to be 

impaired during the fish tissue survey (Table 2). 

Natural Attenuation 

Since dieldrin and PCBs are not being manufactured, distributed or used, concentrated sources of 

these chemicals should not exist. Instead, the technical analysis for this TMDL suggests that 

these chemicals are entering the Palouse River from nonpoint sources. In other words, historical 

use of these chemicals has deposited them in the environment including the Palouse River. 

Those deposited on land may wash into streams through stormwater runoff. 

The technical analysis for this TMDL demonstrates that the levels of both dieldrin and PCBs 

have decreased over time. Without any apparent sources of these chemicals it is expected that 

they should continue to decrease in the future. 

Stormwater 

The highest levels of dieldrin and PCBs were found in the South Fork Palouse River. This subwatershed is the most urbanized in the Palouse River watershed. In addition, high levels of 

these chemicals were also found in stormwater samples from the city of Pullman and 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

Page 59

Washington State University storm drains. Therefore, Ecology recommends that the city of 

Pullman and Washington State University adopt stormwater BMPs that address dieldrin and 

PCBs. Since these pollutants adhere to soil particles, applying BMPs that address sediment will 

likely reduce current levels. 

In addition, any construction activity required to obtain a construction stormwater permit should 

apply stormwater BMPs to prevent sediment from reaching surface water. 

Effluent Wasteload Allocations 

WLAs described in Part 1 of this report will be included in the NPDES permits for the three 

treatment plants discharging to waterbodies impaired by PCBs and dieldrin. If future data 

collection indicates the facilities are out of compliance with the wasteload allocations, future 

permits will outline a compliance schedule to assist the treatment plants in meeting these targets. 

Agriculture 

The agricultural community’s efforts to reduce erosion in the watershed have likely played a role 

in the observed reduction of these toxins. Dieldrin and PCBs tend to adhere to soil particles and 

can be deposited into streams through erosion. BMPs such as direct seed technology should 

continue to be implemented and encouraged in the watershed. Conservation districts and 

Ecology will continue to support practices that reduce soil erosion in the watershed through 

technical assistance and funding. 

Monitoring 

To ensure the levels of dieldrin and PCBs continue their downward trend, Ecology will monitor 

fish in the Palouse River and the South Fork Palouse River and compare the results to data 

collected during the TMDL and past studies. If concentrations of dieldrin and PCBs have not 

continued to decline, Ecology will apply adaptive management to this TMDL (see Adaptive 

Management section later in this report). Ecology and the Whitman County Health Department 

may also conduct monitoring at abandoned landfills to determine if they are sources of dieldrin 

and PCBS. 

Who Needs to Participate? 

Several agencies and programs will work collaboratively to assure levels of dieldrin and PCBs in 

the South Fork Palouse River and Palouse River fish continue to decline and meet water quality 

standards. Entities that regulate or discharge stormwater, regulate landfills, monitor water 

quality or provide technical assistance and funding for methods that reduce erosion should 

participate in this TMDL. 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

Page 60

The Department of Ecology – Environmental Assessment Program 

Ecology’s Environmental Assessment program will sample Palouse River fish every five years 

or as resources allow. At a minimum fish will be sampled 10 years after TMDL approval. The 

results will be compared to current levels to determine if dieldrin and PCBs are continuing to 

decline at the expected rates. More details about this sampling can be found in the Measuring 

Progress Towards Goals section later in this report. 

The Department of Ecology – Water Quality Program 

Ecology’s Water Quality Program will regulate stormwater discharges through the Construction, 

Municipal and Industrial Stormwater Permits. 

A Construction Stormwater Permit is required for all soil disturbing activities (including 

clearing, grading, and/or excavation) where one or more acre will be disturbed, and stormwater 

will be directly discharged to a receiving water (e.g., wetlands, creeks, unnamed creeks, rivers, 

marine waters, ditches, estuaries), or to storm drains that discharge to a receiving water. A 

permit is also required for construction projects smaller than one acre if the project is part of a 

“common plan of development or sale” in which the total land disturbance exceeds one acre. 

Any size construction activity may be required to obtain a permit if Ecology determines it to be a 

significant source of pollutants to waters of the state. If all stormwater is retained on-site and 

cannot enter surface waters of the state under any condition, permit coverage is not needed. 

Construction site operators must apply for a permit 60 days prior to discharging stormwater. 

A Municipal Stormwater Permit is required for public entities in urbanized areas (as defined by 

the 2000 Census) that operate municipal separate storm sewer systems (MS4). A special purpose 

district such as a sewer district, flood control district, port, public university or college, prison 

complex, drainage district, or parks and recreation district is regulated as a secondary permittee 

under the municipal permit. Storm sewer systems in very discrete areas such as individual 

buildings do not require permit coverage. The City of Pullman and Washington State University 

will be included under the Phase II Municipal Stormwater Permit for Eastern Washington. 

Coverage under the Industrial Stormwater General Permit is required for industrial facilities 

that discharge stormwater from their industrial areas to waters of the state, or to storm drains that 

discharge to waters of the state. No permit is required if the facility treats and retains all the 

stormwater on site. 

Ecology’s Water Quality Program will also monitor the progress of this implementation plan, 

review monitoring data, and apply adaptive management if the trend towards meeting water 

quality goals does not continue. 

Ecology will include WLAs in the NPDES permits for the cities of Pullman, Colfax and Albion’s 

WWTPs. The purpose of these WLAs is to ensure point sources are not contributing to the 

elevated levels of PCBs and dieldrin in the South Fork Palouse River and the Palouse River. The 

NPDES permits will include monitoring requirements and if necessary future permits will 

include a compliance schedule. 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

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Ecology will also pursue resources to obtain water quality data for the treatment plants’ influents 

and effluents. This data will be used to revise the interim WLAs if necessary. If PCB and 

dieldrin levels are elevated in the influent, it will indicate a need to locate potential sources to the 

sewer system. 

If levels of PCBs and dieldrin do not decline as anticipated and no sources are located within 

Washington, Ecology will seek opportunities to measure loading coming from Moscow, Idaho. 

Whitman County Regional Health Department 

The Whitman County Regional Health Department will investigate an abandoned landfill and 

incinerator along the South Fork Palouse River as funding allows. It is anticipated that the 

Department will be able to use a current solid waste enforcement grant to partially fund this 

investigate. 

City of Pullman 

The city of Pullman will be regulated under the Eastern Washington Phase II Municipal 

Stormwater General Permit. The Phase II Municipal Permit is scheduled to be issued and take 

effect in winter 2006-2007. At a minimum, the permit will require permit holders to address the 

following federal requirements: 

1. Develop and implement a Stormwater Management Program (SWMP) which shall 

include: 

a. Public education and outreach 

b. Public participation and involvement 

c. Illicit discharge detection and elimination 

d. Construction site runoff control 

e. Post-construction runoff control 

f. Pollution prevention and good housekeeping 

2. Compliance with TMDL requirements 

3. Program evaluation and reporting 

The terms and conditions of Ecology’s Phase II Municipal Stormwater Permit are currently 

drafted and were published for public review from February 15 through May 19, 2006. More 

information on the stormwater permits can be found on Ecology’s website at 

www.ecy.wa.gov/programs/wq/stormwater/index.html. 

Ecology’s municipal stormwater permits establish the primary activities needed to control 

pollution from urban stormwater. This TMDL assumes that compliance with the Phase II 

stormwater permit is the only requirement the city of Pullman needs to fulfill to accomplish the 

objectives of this TMDL. In the event Pullman is determined to not require coverage under the 

Phase II Municipal Stormwater Permit, Pullman can comply with this TMDL by implementing 

the recommendations in the Eastern Washington Stormwater Manual, paying particular attention 

to developing and carrying out the eight core elements outlined in Chapter 2 of the manual. Since 

the Pullman Stormwater Pilot Study for Pesticides, PCBs, and Fecal Coliform Bacteria

(Lubliner, 2006) indicated stormwater was a significant source of PCBs and dieldrin, BMPs and 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

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maintenance and operation practices must be conducted to ensure sediment, which may carry 

PCBs and dieldrin, does not enter local streams. 

Since dieldrin and PCBs attach to sediment particles, Ecology believes that the best stormwater 

BMPs to reduce these pollutants are measures that reduce the amount of sediment discharged to 

streams. The city of Pullman’s schedule to address stormwater, especially suspended sediment is 

outlined below. 

Immediate and Ongoing 

1. Control of suspended sediment in stormwater: 

a. Per City of Pullman Design Standards (2001 Edition) require Erosion and 

Sediment Control plans for land altering activities. The degree of sediment and 

erosion control is somewhat dependent on the project scope. 

b. During the Site Plan and Subdivision Review process advise developers and 

contractors on the need to comply with Ecology’s Construction Stormwater 

General Permit when disturbing more than 1 acre. 

c. Require erosion control plans as part of the building permit review process. 

d. Continue to train engineering and building division personnel as Certified Erosion 

and Sediment Control Leads (CESCL). Currently two engineering staff members 

and all four of our building inspectors are CESCLs . 

e. Increase annual storm drain pipe maintenance (jetting and cleaning) to eventually 

complete cleaning of entire sub-basins over time as budgeting allows. Prioritize 

sub-basin cleaning by past land use activity. 

By December 2008 

2. Revise City’s Design Standards to reference the Stormwater Management Manual for 

Eastern Washington as the technical reference for best available practice. [Current 

reference is Manual for Puget Sound basin] 

3. Complete storm drain computer mapping project. 

In addition the city of Pullman installed a stormwater treatment device (Vortechnics 5000) at the 

city’s Maintenance and Operations (M&O) yard. The M&O yard consists of the maintenance 

and operations facilities, transit storage area, and equipment rental division (automotive shop). 

All the stormwater from the M&O yard is piped to this treatment device. This treatment device 

will be inspected and cleaned at regular intervals. It is designed to remove sediment and oil. 

Washington State University 

Washington State University (WSU) will be regulated as a secondary permittee under the Phase 

II Municipal Stormwater General Permit. As a secondary permittee WSU will also be required 

to address the following federal requirements: 

1. Develop and implement a Stormwater Management Program (SWMP) which shall 

include: 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

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a. Public education and outreach 

b. Public participation and involvement 

c. Illicit discharge detection and elimination 

d. Construction site runoff control 

e. Post-construction runoff control 

f. Pollution prevention and good housekeeping 

2. Compliance with TMDL requirements 

3. Program evaluation and reporting 

Ecology’s municipal stormwater permits establish the primary activities needed to control 

pollution from urban stormwater. This TMDL assumes that compliance with the Phase II 

stormwater permit is the only requirement WSU needs to fulfill to accomplish the objectives of 

this TMDL. In the event WSU is determined to not require coverage under the Phase II 

Municipal Stormwater NPDES permit, WSU can comply with this TMDL by implementing the 

recommendations in the Eastern Washington Stormwater Manual, paying particular attention to 

developing and carrying out the eight core elements outlined in Chapter 2 of the manual. Since 

the Pullman Stormwater Pilot Study for Pesticides, PCBs, and Fecal Coliform Bacteria 

(Lubliner, 2006) indicated stormwater was a significant source of PCBs and dieldrin, BMPs and 

maintenance and operation practices must be conducted to ensure sediment, which may carry 

PCBs and dieldrin, does not enter local streams. 

WSU currently has an active stormwater program with plans to expand it in the future. 

Activities in this program that should help reduce dieldrin and PCBs include: 

1. Proactively removing all PCB sources on campus to a level below Federal and 

Washington State regulations. 

2. Continuing illicit discharge detection program (which includes connecting floor drains to 

sanitary sewer). 

3. Developing a computerized mapping system of existing stormwater lines, catch basin 

locations, and drainage areas. 

4. Overseeing construction projects one acre or greater that require Construction 

Stormwater NPDES permits. 

5. Using video inspection and repairing all storm sewer lines as budgeting allows. 

6. Sweeping streets and parking lots with new waterless street sweeper. 

7. Applying washed gravel without fines to roads for winter traction. 

Cities of Pullman, Colfax, and Albion’s WWTPs 

NPDES permits for the cities of Pullman, Colfax, and Albion’s WWTPs will include WLAs for 

PCBs and dieldrin. Because the current level of PCBs and dieldrin in their wastewater is not 

known, these municipalities should work closely with Ecology to analyze wastewater influent 

and effluent. Ecology is seeking resources to initiate a study of the wastewater influents and 

effluents. This study will help determine the need for additional implementation activities, 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

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revisions to the interim WLAs and a schedule for WWTP monitoring. The NPDES permit will 

include requirements for monitoring PCBs and dieldrin following Ecology’s initial study. 

If the wastewater influent has elevated concentrations of PCBs and dieldrin the city will: 

• Work with Ecology to develop a compliance schedule to meet the WLAs. 

• Develop a strategy for determining sources to the system and identifying possible corrective 

actions. 

If elevated levels of PCBs and dieldrin are found in Pullman’s wastewater influent, the city 

should work closely with Washington State University to ensure a source is not located on 

campus. 

Palouse River Watershed Conservation Districts (Palouse, Whitman, 

Palouse-Rock Lake, Adams, Pine Creek and Spokane) 

The Spokane County Conservation District currently has a State Revolving Fund loan to assist 

landowners who wish to make the transition from conventional farming techniques to 

conservation tillage and direct seeding operations. This program is designed to reduce nonpoint 

source pollution from eroding agricultural lands. Chlorinated pesticides and PCBs are known to 

attach to sediment particles, therefore converting to conservation tillage and direct seeding 

operations will aid in the reduction of these pollutants. The Spokane County Conservation 

District has a memorandum of understanding (MOU) with Palouse, Whitman, Palouse-Rock 

Lake, Pine Creek, and Adams conservation districts to offer this loan program to landowners 

throughout the entire Palouse River Watershed. 

In addition, all of these conservation districts provide funding and technical assistance to help 

landowners implement BMPs to reduce or stop erosion. These practices often include riparian 

restoration, grassed waterways, fencing, and other BMPs approved by the Natural Resources 

Conservation Service. 

These conservation districts will continue to promote and implement best management practices 

through their current programs and will seek other funding opportunities for future efforts. Each 

conservation district will report an estimate of acres transitioned to conservation tillage or direct 

seed technology and number of BMP projects that will substantially reduce erosion to the TMDL 

coordinator annually. 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

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The actions described above should accelerate the natural attenuation rate of both dieldrin and 

PCBs in the watershed. Table 22 provides a summary of the actions, organizational 

responsibilities, and timeline for this implementation plan. 

Table 22. Activities and Resources to Reduce Dieldrin and PCBs 

Performance Measures 

Source Action Item Organization 

What When 

Issue municipal stormwater 

permit to the city of Pullman 

and WSU 

2007 

Provide technical assistance On-going 

Issue and monitor 

compliance with 

municipal, 

construction and 

industrial 

stormwater permits 

Ecology’s Water 

Quality Program 

Monitor permit implementation 

by reviewing annual reports 

Annually 

Implement requirements of 

Phase II municipal stormwater 

permit 

On-going 

Require Erosion and Sediment 

Control plans for land altering 

activities and building permits 

On-going 

Continue to train engineering 

and building division personnel 

as Certified Erosion and 

Sediment Control Leads 

(CESCL) 

On-going 

Increase annual storm drain pipe 

maintenance 

On-going; report 

progress annually 

Revise City’s Design Standards 

to reference the Stormwater 

Management Manual for 

Eastern Washington

2008 

City of Pullman 

Complete storm drain computer 

mapping project 

2008 

Implement requirements of 

Phase II municipal stormwater 

permit 

On-going 

Proactively removing all PCB 

sources on campus to a level 

below Federal and Washington 

State regulations 

Report progress 

annually 

Continue illicit discharge 

detection program 

On-going; report 

progress annually 

Complete computerized 

mapping system of existing 

stormwater lines, catch basin 

locations and drainage areas 

On-going 

Stormwater 

Reduce pollutants in 

urban stormwater 

Washington State 

University 

Oversee construction projects 

one acre or greater that require 

Construction Stormwater 

NPDES permits 

On-going 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

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Performance Measures 

Source Action Item Organization 

What When 

Inspect and repair all storm 

sewer lines 

On-going; report 

progress annually 

Maintain streets and parking lots On-going 

Abandoned 

and old 

landfills 

Determine if 

abandoned and old 

landfills could be 

sources of dieldrin 

and PCBs 

Whitman County 

Regional Health 

Department 

Investigate an abandoned 

landfill and incinerator along the 

South Fork Palouse River to 

determine if they are sources 

As funding 

allows; goal is to 

complete 

investigation by 

2009 

Report number of acres 

converted to conservation tillage 

or BMP projects that 

significantly reduce erosion 

Agricultural Annually 

sediment 

Promote and 

implement direct 

seed technology and 

other BMPs to 

reduce erosion 

Palouse Watershed 

Conservation Districts 

(Spokane County, 

Palouse, Whitman, 

Palouse-Rock Lake, 

Pine Creek, Adams) 

Seek additional funding 

opportunities to support this 

action 

As needed 

Ecology Incorporate WLAs into NPDES 

Permits 

Meet WLAs at end 2008 

of pipe for Pullman, 

Colfax and Albion 

WWTPs Pullman, Colfax, 

Albion WWTPs 

Meet conditions of NPDES 

permit 

2008 

Assess levels of PCBs and 

dieldrin in influent and effluent 

of WWTPs 

2008 

Wastewater 

Revise WLAs or 

seek sources to 

treatment systems if 

necessary 

Ecology and/or 

WWTPs 

Develop source identification 

plan for WWTPs if necessary 

If necessary 

Monitor fish tissue 

concentrations of 

dieldrin and PCBs 

Ecology’s 

Environmental 

Assessment Program 

Sample Palouse River and South 

Fork Palouse River fish to 

determine tissue concentrations 

Every 5 years 

(2012, 2017, 

2022) 

Monitor 

implementation of 

this plan 

Ecology’s Water 

Quality Program 

Track progress of activities 

outlined in this plan with partner 

organizations 

Annually 

Apply adaptive 

management if 

targets are not being 

met 

Ecology’s Water 

Quality Program 

Investigate further monitoring to 

locate sources of dieldrin and 

PCBs 

2017 

All 

Determine if 

Moscow Idaho 

could be a source 

Ecology’s Water 

Quality Program 

Seek opportunities to monitor 

Paradise Creek to assess loading 

If necessary 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

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What is the Schedule for Achieving Water Quality Standards? 

Fish tissue concentrations of dieldrin and PCBs have decreased by 2 to 3 orders of magnitude 

over the past 10 to 20 years and will continue to decrease without further action being taken. 

However the actions outlined in the previous section will assure that the levels of these pollutants 

continue to decline and may even accelerate the timeframe when the Palouse River will reach 

water quality standards for dieldrin and PCBs. 

Although it is not possible to predict exactly how long it will take for water quality standards to 

be achieved in the Palouse River, it is possible to estimate a timeframe and monitor progress. 

The mainstem is close to meeting the TMDL targets for dieldrin and PCBs at the present time. 

The rates of decrease in lower mainstem fish imply a half-life of approximately 10 years for both 

dieldrin and PCBs (1995 and 2005 data). If these rates apply to the South Fork (which appears 

to be the major source of contamination) compliance would be achieved in the South Fork within 

10 to 15 years for dieldrin and within 15 to 20 years for PCBs. Similarly, the mainstem would 

be expected to comply within about 5 years. 

Reasonable Assurances 

When establishing a TMDL, reductions of a particular pollutant are allocated among the 

pollutant sources (both point and nonpoint sources) in the waterbody. TMDLs (and related 

Action Plans) must show “reasonable assurance” that these sources will be reduced to their 

allocated amount. Education, outreach, technical and financial assistance, permit administration, 

and enforcement will all be used to ensure that the goals of this water clean up plan are met. 

Ecology believes that natural attenuation and the implementation of stormwater and agricultural 

BMPs that reduce sediment contributions to surface water are already supporting this TMDL and 

add to the assurance that dieldrin and PCBs in the Palouse River will meet Washington State 

water quality standards within a reasonable timeframe. This assumes that both dieldrin and PCB 

will continue to decline at the rate observed over the past 10 to 20 years. 

Ecology’s issuance of the Phase II Eastern Washington Stormwater Permit in 2007 will add to 

the assurance that dieldrin and PCBs will be reduced in the South Fork Palouse River. The city 

of Pullman and WSU will be covered under this permit. 

WLAs incorporated into NPDES permits for Pullman, Colfax and Albion will assure that the 

treatment facilities are not elevating the levels of PCBs and dieldrin in the Palouse and South 

Fork Palouse rivers. 

While Ecology is authorized under Chapter 90.48 RCW to impose strict requirements or issue 

enforcement actions to achieve compliance with state water quality standards, it is the goal of all 

participants in the Palouse River TMDL process to achieve clean water through voluntary 

control actions. 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

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Measuring Progress Toward Goals (Monitoring Plan) 

Additional monitoring, inspections, and investigations are planned or recommended in four areas 

for this TMDL: 

• Conduct periodic fish tissue monitoring for dieldrin and PCBs. 

• Evaluate wastewater treatment facilities (including the collection systems) as potential 

dieldrin and PCB sources. 

• Identify and clean up sources of dieldrin and PCBs to the Pullman storm drain system. 

• Identify and clean up abandoned landfills and old dumps vulnerable to high water events or 

surface runoff during storms. 

The success of this implementation plan will be measured by tracking the progress of 

implementation actions and reassessing pollutant levels in Palouse River and South Fork Palouse 

River fish tissue. 

Performance measures and targets 

Ecology’s TMDL coordinator will work with the organizations outlined in this document to track 

the progress of this implementation plan. Each organization should track the progress they have 

made on their performance measures. The TMDL coordinator will contact each organization 

annually and record the implementation progress in the tracking tables in Appendix C. 

 

The TMDL coordinator will review implementation activities and water quality data collected by 

the Environmental Assessment Program to determine whether progress is being made or if 

adaptive management is needed. 

Effectiveness monitoring plan 

Effectiveness monitoring determines if the TMDL targets and water quality standards have been 

met. Ecology’s Environmental Assessment Program will periodically monitor fish tissue for 

dieldrin and PCBs in the mainstem Palouse River below Colfax and in the South Fork Palouse 

River. Sampling sites and timing will be similar to those of the 2005 survey. To the extent 

possible, the species and size ranges analyzed will be appropriate for comparing to the 2005 data. 

Fish tissue samples from the 2005 collection have been archived to aide in comparing the data. 

Fish tissue monitoring will be done on a 5-year cycle. Five years is the monitoring period 

typically employed in effectiveness monitoring for TMDLs. This timeline also fits within the 

estimated time frame when the mainstem is projected to achieve compliance with standards. All 

fish tissue data will be provided to the Washington State Department of Health and shared with 

stakeholders. 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

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Adaptive Management 

TMDL reductions should be achieved by 2012 for dieldrin and PCBs in the mainstem Palouse 

River and by 2017 for dieldrin and 2022 for PCBs in the South Fork Palouse River. Partners will 

work together to monitor progress towards these goals, evaluate successes, obstacles, and 

changing needs, and make adjustments to the implementation plan as needed. 

Ecology will use any additional data collection to update the WLAs. If necessary Ecology will 

update NPDES permits to include new WLAs, a compliance schedule and monitoring 

requirements. If future monitoring suggests that Washington State University is a source of 

PCBs and dieldrin their permit to discharge to Pullman’s collection system will be updated to 

include WLAs. 

It is ultimately Ecology’s responsibility to assure that cleanup is being actively pursued and 

water standards are achieved. If the effectiveness monitoring indicates that progress is not being 

made at the rate predicted, the TMDL Coordinator and the partner organizations will evaluate 

other methods and activities that could help the water meet water quality standards. Such 

activities may include sampling Paradise Creek at the Idaho border to determine if loading may 

be coming from the Moscow area. Chemical analysis of samples should use detection limits low 

enough to compare to human health water quality criteria. 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

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Potential Funding Sources 

Ecology’s Centennial Clean Water Fund, Section 319, and State Revolving Fund loans can 

provide financial assistance to help implementation of the TMDL (water quality improvement 

plan). In addition to Ecology’s funding programs, there are many other funding sources 

available for watershed planning and implementation, point and nonpoint source pollution 

management, fish and wildlife habitat enhancement, stream restoration, and education. Public 

sources of funding include federal and state government programs, which can offer financial as 

well as technical assistance. Private sources of funding include private foundations, which most 

often fund nonprofit organizations with tax-exempt status. 

Forming partnerships with other government agencies, nonprofit organizations, and private 

businesses can often be the most effective approach to maximize funding opportunities. 

Some of the most commonly accessed funding sources for TMDL implementation are shown in 

Table 23 and are described below. 

Table 23. Potential Funding Sources for Implementation Projects

Fund Source Type of Project Funded Maximum Amounts 

Centennial Clean Water Fund Watershed planning, stream restoration, 

& water pollution control projects. 

$500,000 

Section 319 Nonpoint Source 

Fund 

Nonpoint source control; i.e., pet waste, 

stormwater runoff, & agriculture, etc. 

$500,000 

State Water Pollution Control 

Revolving Fund 

Low-interest loans to upgrade pollution 

control facilities. 

10% of total SRF annually 

Coastal Zone Protection Fund 

(also referred to as Terry 

Husseman grants) 

Stream restoration projects to improve 

water quality. 

~$50,000 

Conservation Reserve Program 

(CRP) 

Establishes long-term conservation cover 

of grasses, trees and shrubs on eligible 

land. 

Rental payments based on the 

value of the land; plus 50% - 90% 

cost share dependant on practices 

implemented 

Environmental Quality 

Incentives Program (EQIP) 

Natural resource protection. Dependent on practices 

implemented 

Wildlife Habitat Incentive 

Program (WHIP) 

Provide funds to enhance and protect 

wildlife habitat including water. 

$25,000 dependent on practices 

implemented 

Conservation Security 

Program (CSP) 

Provides financial assistance for 

conservation on private working lands. 

Dependent on practices 

implemented 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

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Centennial Clean Water Fund (CCWF) 

A 1986 state statute created the Water Quality Account, which includes the Centennial Clean 

Water Fund (CCWF). Ecology offers CCWF grants and loans to local governments, tribes, and 

other public entities for water pollution control projects. The application process is the same for 

CCWF, 319 Nonpoint Source Fund, and the state Water Pollution Control Revolving Fund. 

Section 319 Nonpoint Source Fund 

The 319 Fund provides grants to local governments, tribes, state agencies, and nonprofit 

organizations to address nonpoint source pollution to improve and protect water quality. 

Nonpoint source pollution includes many diffuse sources of pollution, such as stormwater runoff 

from urban and residential development, agricultural and timber practices, and other activities. 

Non-governmental organizations can apply to Ecology for funding through a 319 grant to 

provide additional implementation assistance. 

State Water Pollution Control Revolving Fund 

Ecology also administers the Washington State Water Pollution Control Revolving Fund. This 

program uses federal funding from U.S. Environmental Protection Agency and monies 

appropriated from the state’s Water Quality Account to provide low-interest loans to local 

governments, tribes, and other public entities. The loans are primarily for upgrading or 

expanding water pollution control facilities, such as public sewage and stormwater plants, and 

for activities to address nonpoint source water quality problems. 

Coastal Zone Protection Fund 

Since July 1998, water quality penalties issued under Chapter 90.48 RCW have been deposited 

into a sub-account of the Coastal Protection Fund (also referred to as Terry Husseman grants). A 

portion of this fund is made available to regional Ecology offices to support on-the-ground 

projects to perform environmental restoration and enhancement. Local governments, tribes, and 

state agencies must propose projects through Ecology staff. Stakeholders with projects that will 

reduce erosion are encouraged to contact their local TMDL coordinator to determine if their 

project proposal is a good candidate for Coastal Zone Protection funding. 

Conservation Reserve Program (CRP) 

The Conservation Reserve Program (CRP) is a voluntary program for agricultural landowners. 

Through CRP, landowners can receive annual rental payments and cost-share assistance to 

establish long-term, resource conserving covers on eligible farmland. Included under CRP is the 

Continuous Conservation Reserve Program (CCRP), which provides funds for special practices 

for both upland and riparian land. Landowners can enroll in CCRP at anytime. There are 

designated sign up periods for CRP. 

 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

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The Commodity Credit Corporation (CCC) makes annual rental payments based on the 

agriculture rental value of the land, and it provides cost-share assistance for 50 to 90% of the 

participant’s costs in establishing approved conservation practices. Participants enroll in CRP 

contracts for 10 to 15 years. 

 

The program is administered by the CCC through the Farm Service Agency (FSA), and program 

support is provided by Natural Resources Conservation Service, Cooperative State Research and 

Education Extension Service, state forestry agencies, and local Soil and Water Conservation 

Districts. (Farm Service Agency, 2006) 

Environmental Quality Incentives Program (EQIP) 

The federally funded Environmental Quality Incentives Program (EQIP) is administered by 

NRCS. EQIP is the combination of several conservation programs that address soil, water, and 

related natural resource concerns. EQIP encourages environmental enhancements on land in an 

environmentally beneficial and cost-effective manner. The EQIP program: 

• Provides technical assistance, cost share, and incentive payments to assist crop and livestock 

producers with environmental and conservation improvements on the farm. 

• Has 75% cost sharing but allows 90% if producer has limited resources or beginning farmer. 

• Divides program funding 60% for livestock-related practices, 40% for cropland. 

• Has contracts lasting five to ten years. 

• Has no annual payment limitation; sum not to exceed $450,000 per farm. 

Wildlife Habitat Incentive Program 

The Wildlife Habitat Incentive Program (WHIP) is administered by NRCS. WHIP is a voluntary 

program for people who want to develop and improve wildlife habitat primarily on private land. 

Through WHIP, NRCS provides both technical assistance and up to 75% cost-share assistance to 

establish and improve fish and wildlife habitat. WHIP agreements between NRCS and the 

participant generally last from five to ten years from the date the agreement is signed. 

Conservation Security Program 

The Conservation Security Program (CSP) is a voluntary program that provides financial and 

technical assistance to promote the conservation and improvement of soil, water, air, energy, 

plant and animal life, and other conservation purposes on tribal and private working lands. 

Working lands include cropland, grassland, prairie land, improved pasture, and range land, as 

well as forested land that is an incidental part of an agriculture operation. The program provides 

equitable access to benefits to all producers, regardless of size of operation, crops produced, or 

geographic location. CSP is administered by NRCS (NRCS, 2006). 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

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Each year different watersheds are selected for CSP enrollment. It is not known when this 

program will come to the Palouse watershed. However, since the program rewards producers 

who already have conservation practices in place, producers are encouraged to use other federal, 

state, and local funding sources to prepare their land for enrollment (R. Riehle, NRCS 2006, 

personal communication. March 17). 

Summary of Public Involvement Methods 

In April 2005, a press release was issued to announce the start of this TMDL effort. Several 

newspapers published articles about this project. On April 27, 2005 a public meeting was held in 

Colfax, Washington to present information about the fish tissue study and TMDLs. 

Ecology maintains a mailing list of people interested in water quality in the Palouse River 

watershed. Several updates about this project have been sent to this mailing list. 

Information about this project has been available on Ecology’s website at: 

www.ecy.wa.gov/programs/wq/tmdl/palouse/index.html. 

A Quality Assurance Project Plan (QAPP) for the fish tissue study was developed. Members of 

the Palouse Watershed Planning Unit were invited to review and comment on the QAPP. 

A press release was issued on May 21, 2007 inviting the public to view and comment on this 

report. Advertisements announcing the comment period were placed in several of the local 

newspapers. The 30-day public comment period ran from May 24, 2007 to June 22, 2007. 

Comments received are responded to in Appendix D. 
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References 

Ahmed, A., 2004. North Fork Palouse River Fecal Coliform Bacteria Total Maximum Daily 

Load Recommendations. Washington State Department of Ecology, Olympia, WA. 

Publication No. 04-03-022. www.ecy.wa.gov/biblio/0403022.html

Bilhimer, D, J. Carroll, and K. Sinclair, 2006. Quality Assurance Project Plan: South Fork 

Palouse River Temperature Total Maximum Daily Load Study. Washington State Department of 

Ecology, Olympia, WA. Publication No. 06-03-104. www.ecy.wa.gov/biblio/0603104.html

Callahan, M.A. et al., 1979. Water-Related Environmental Fate of 129 Priority Pollutants. 

EPA-440/4-79-029a. 

City of Pullman, 1999. Application for Renewal of NPDES Municipal Wastewater Discharge 

Permit WA-004465-2. Pullman Wastewater Treatment Plant, Pullman, WA. 

Davis, D., 1996. Washington State Pesticide Monitoring Program: 1994 Surface Water 

Sampling Report. Washington State Department of Ecology, Olympia, WA. Publication 

No. 96-305. www.ecy.wa.gov/biblio/96305.html

Davis, D and D. Serdar, 1996. Washington State Pesticide Monitoring Program: 1994 Fish 

Tissue and Sediment Sampling Report. Washington State Department of Ecology, Olympia, 

WA. Publication No. 96-352. www.ecy.wa.gov/biblio/96352.html

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Appendices 
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Appendix A. Biological Information on Fish Samples 

Table A-1. Biological Information on Ecology's 2005 Palouse River Fish Samples. 

Sample ID Sample No. Collection 

Date Species 

Total 

Length 

(mm) 

Weight 

(g) Sex Age (yrs) 

NF CHM-1 05288366 6/8/05 CHM 214 93 M 2 

 6/8/05 CHM 226 101 M 4 

 6/8/05 CHM 210 83 M 2 

 6/9/05 CHM 229 109 M 3 

 6/9/05 CHM 208 85 F 2 

 Mean 217 94 n/a 2.6 

NF CHM-2 05288367 6/8/05 CHM 218 91 M 2 

 6/8/05 CHM 224 101 M 3 

 6/8/05 CHM 206 81 F 2 

 6/8/05 CHM 208 86 M 2 

 6/9/05 CHM 215 88 F 2 

 Mean 214 89 n/a 2.2 

NF CHM-3 05288368 6/8/05 CHM 206 76 M 2 

 6/8/05 CHM 208 86 F 2 

 6/8/05 CHM 226 104 M 4 

 6/8/05 CHM 227 103 M 3 

 6/8/05 CHM 211 97 M 2 

 Mean 216 93 n/a 2.6 

NF CHM-4 05288369 6/8/05 CHM 224 100 M 3 

 6/8/05 CHM 216 87 M 3 

 6/8/05 CHM 213 91 M 2 

 6/8/05 CHM 204 78 M 2 

 6/9/05 CHM 220 93 M 3 

 Mean 215 90 n/a 2.6 

NF CHM-5 05288370 6/8/05 CHM 206 72 F 2 

 6/8/05 CHM 216 95 M 2 

 6/8/05 CHM 221 93 M 3 

 6/9/05 CHM 203 90 F 2 

 6/8/05 CHM 215 90 M 2 

 Mean 212 88 n/a 2.2 

NF LSS-1 05288371 6/8/05 LSS 200 102 M 2 

 6/8/05 LSS 199 82 F 2 

 6/8/05 LSS 201 84 F 2 

 6/9/05 LSS 195 84 F 2 

 6/8/05 LSS 219 129 F 2 

 Mean 203 96 n/a 2 

 
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Sample ID Sample No. Collection 

Date Species 

Total 

Length 

(mm) 

Weight 

(g) Sex Age (yrs) 

NF LSS-2 05288372 6/9/05 LSS 390 626 M 5 

 6/9/05 LSS 410 757 F 7 

 6/9/05 LSS 409 815 M 8 

 6/9/05 LSS 397 772 M 7 

 6/8/05 LSS 415 735 F 7 

 Mean 404 741 n/a 6.8 

NF LSS-3 05288373 6/9/05 LSS 393 643 M 7 

 6/9/05 LSS 445 920 F 9 

 6/9/05 LSS 387 445 M 5 

 6/9/05 LSS 368 518 M 5 

 6/7/05 LSS 380 571 M 5 

 Mean 395 619 n/a 6.2 

NF LSS-4 05288374 6/9/05 LSS 417 875 M 7 

 6/9/05 LSS 398 712 M 7 

 6/9/05 LSS 390 591 M 8 

 6/9/05 LSS 390 597 M 6 

 6/9/05 LSS 400 648 M 8 

 Mean 399 685 n/a 7.2 

NF LSS-5 05288375 6/9/05 LSS 385 593 M 6 

 6/9/05 LSS 385 589 M 7 

 6/9/05 LSS 387 558 M 7 

 6/9/05 LSS 390 568 M 7 

 6/9/05 LSS 421 770 F 7 

 Mean 394 616 n/a 6.8 

NF NPM-1 05288376 6/7/05 NPM 224 115 M 3 

 6/8/05 NPM 266 175 M 4 

 6/8/05 NPM 249 145 M 5 

 6/8/05 NPM 224 97 M 5 

 6/9/05 NPM 258 154 F 4 

 Mean 244 137 n/a 4.2 

NF NPM-2 05288377 6/8/05 NPM 272 182 M 6 

 6/8/05 NPM 246 147 M 5 

 6/8/05 NPM 237 130 M 5 

 6/8/05 NPM 246 136 F 5 

 6/8/05 NPM 243 122 M 5 

 Mean 249 143 n/a 5.2 

NF NPM-3 05288378 6/8/05 NPM 243 126 M 3 

 6/9/05 NPM 256 136 F 4 

 6/9/05 NPM 275 174 M 6 

 6/9/05 NPM 225 118 F 3 

 6/9/05 NPM 234 137 M 4 

 Mean 247 138 n/a 4 

 
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Sample ID Sample No. Collection 

Date Species 

Total 

Length 

(mm) 

Weight 

(g) Sex Age (yrs) 

NF NPM-4 05288379 6/8/05 NPM 307 264 M 6 

 6/8/05 NPM 361 458 M 8 

 6/8/05 NPM 310 301 M 6 

 Mean 326 341 n/a 6.7 

NF NPM-5 05288380 6/8/05 NPM 313 296 M 6 

 6/9/05 NPM 399 621 F 9 

 6/9/05 NPM 399 570 F 8 

 6/9/05 NPM 368 420 F 7 

 Mean 370 477 n/a 7.5 

SF CHM-1 05288381 5/24/05 CHM 259 177 M 4 

 5/24/05 CHM 211 100 F 3 

 5/24/05 CHM 200 76 M 2 

 5/25/05 CHM 192 72 F 2 

 Mean 216 106 n/a 2.75 

SF CHM-2 05288382 5/24/05 CHM 240 123 F 3 

 5/24/05 CHM 194 70 M 2 

 5/25/05 CHM 234 123 F 3 

 5/25/05 CHM 232 122 F 3 

 Mean 225 110 n/a 2.75 

SF LSS-1 05288383 5/24/05 LSS 300 262 F 5 

 5/24/05 LSS 225 161 F 3 

 5/24/05 LSS 224 126 nd 3 

 5/24/05 LSS 204 127 M 2 

 5/25/05 LSS 215 120 F 2 

 Mean 234 159 n/a 3 

SF LSS-2 05288384 5/24/05 LSS 205 93 M 2 

 5/25/05 LSS 220 144 F 3 

 5/25/05 LSS 203 101 M 2 

 5/23/05 LSS 264 223 M 4 

 5/23/05 LSS 231 152 F 3 

 Mean 225 143 n/a 2.8 

SF LSS-3 05288385 5/24/05 LSS 286 266 M 3 

 5/25/05 LSS 251 182 M 4 

 5/25/05 LSS 233 151 F 3 

 5/25/05 LSS 205 92 M 2 

 5/24/05 LSS 227 145 M? 3 

 Mean 240 167 n/a 3 

SF LSS-4 05288386 5/23/05 LSS 420 718 F 9 

 5/23/05 LSS 435 932 F 10 

 5/24/05 LSS 465 1115 F 11 

 5/24/05 LSS 365 589 M 4 

 Mean 421 839 n/a 8.5 

 
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Sample ID Sample No. Collection 

Date Species 

Total 

Length 

(mm) 

Weight 

(g) Sex Age (yrs) 

SF LSS-5 05288387 5/25/05 LSS 399 745 M 6 

 5/25/05 LSS 460 1007 M 12 

 5/23/05 LSS 408 766 M 6 

 5/24/05 LSS 451 1020 F 7 

 Mean 430 885 n/a 7.8 

SF NPM-1 05288388 5/25/05 NPM 255 158 F 4 

 5/25/05 NPM 261 155 F 4 

 5/25/05 NPM 232 108 M 3 

 5/25/05 NPM 240 120 M 3 

 5/24/05 NPM 206 72 M 2 

 Mean 239 123 n/a 3.2 

SF NPM-2 05288389 5/24/05 NPM 257 165 M 5 

 5/24/05 NPM 252 148 F 5 

 5/24/05 NPM 225 116 M 4 

 5/25/05 NPM 210 71 F 3 

 5/25/05 NPM 206 69 M? 3 

 Mean 230 114 n/a 4 

SF NPM-3 05288390 5/23/05 NPM 228 115 M 3 

 5/24/05 NPM 236 150 F 3 

 5/25/05 NPM 208 86 M 3 

 5/25/05 NPM 206 78 M 3 

 5/24/05 NPM 212 85 F 4 

 Mean 218 103 n/a 3.2 

SF NPM-4 05288391 5/24/05 NPM 235 128 F 3 

 5/24/05 NPM 225 98 F 4 

 5/24/05 NPM 213 92 M 4 

 5/24/05 NPM 207 81 F 4 

 5/24/05 NPM 244 107 F 5 

 Mean 225 101 n/a 4 

SF NPM-5 05288392 5/24/05 NPM 350 383 F 7 

 5/24/05 NPM 397 644 F 8 

 5/24/05 NPM 307 260 F 6 

 5/24/05 NPM 363 481 F 7 

 Mean 354 442 n/a 7 

LWR LSS-1 05288393 6/22/05 LSS 420 788 M? 7 

 6/22/05 LSS 400 667 M 6 

 6/23/05 LSS 413 970 F? 6 

 6/22/05 LSS 423 903 M 7 

 6/22/05 LSS 402 713 M 5 

 Mean 412 808 n/a 6.2 

 
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Sample ID Sample No. Collection 

Date Species 

Total 

Length 

(mm) 

Weight 

(g) Sex Age (yrs) 

LWR LSS-2 05288394 6/22/05 LSS 440 931 F 7 

 6/22/05 LSS 433 978 M 6 

 6/22/05 LSS 346 511 M 4 

 6/22/05 LSS 445 1053 M 7 

 6/22/05 LSS 376 614 M 4 

 Mean 408 817 n/a 5.6 

LWR LSS-3 05288395 6/23/05 LSS 445 1035 F 7 

 6/23/05 LSS 424 924 M 6 

 6/22/05 LSS 425 924 M 6 

 6/22/05 LSS 409 710 F? 4 

 6/22/05 LSS 431 942 F 6 

 Mean 427 907 n/a 5.8 

LWR LSS-4 05288396 6/22/05 LSS 350 496 M 3 

 6/22/05 LSS 424 951 F 6 

 6/23/05 LSS 431 891 M 6 

 6/22/05 LSS 410 748 M 5 

 6/23/05 LSS 422 863 M 5 

 Mean 407 790 n/a 5 

LWR LSS-5 05288397 6/22/05 LSS 390 730 F 4 

 6/23/05 LSS 441 942 M 9 

 6/22/05 LSS 424 820 F 7 

 6/22/05 LSS 422 906 M 6 

 6/23/05 LSS 410 731 M 5 

 Mean 417 826 n/a 6.2 

LWR NPM-1 05328474 6/23/05 NPM 192 65 U 2 

 6/23/05 NPM 210 83 M? 3 

 6/23/05 NPM 285 253 F? 5 

 Mean 229 134 n/a 3.3 

LWR NPM-2 05328475 8/3/05 NPM 420 792 F? 7 

 6/22/05 NPM 443 844 F 8 

 6/23/05 NPM 462 980 F 9 

 6/23/05 NPM 481 1145 F? 10 

 6/23/05 NPM 484 937 F 15 

 Mean 458 940 n/a 9.8 

LWR CHM-1 05328476 6/23/05 CHM 211 108 F 3 

 6/23/05 CHM 183 65 M 2 

 6/23/05 CHM 183 71 F 2 

 6/23/05 CHM 220 114 F 3 

 Mean 199 90 n/a 2.5 

LWR SMB-1 05328477 6/23/05 SMB 208 115 F 2 

 6/23/05 SMB 172 64 F 2 

 Mean 190 90 n/a 2 

 
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Sample ID Sample No. Collection 

Date Species 

Total 

Length 

(mm) 

Weight 

(g) Sex Age (yrs) 

LWR CARP-1 05328478 8/3/05 CARP 280 394 M? 3 

MID LSS-1 05328479 6/6/05 LSS 421 863 M 6 

 6/6/05 LSS 456 1013 M 10 

 6/6/05 LSS 460 995 M 11 

 6/6/05 LSS 452 951 M 11 

 Mean 447 956 n/a 9.5 

MID LSS-2 05328480 6/6/05 LSS 423 731 F 6 

 6/6/05 LSS 461 1006 F 9 

 6/6/05 LSS 435 871 F 7 

 6/6/05 LSS 452 850 F 9 

 Mean 443 865 n/a 7.8 

MID LSS-3 05328481 6/6/05 LSS 426 878 M 6 

 6/6/05 LSS 432 920 M 7 

 6/6/05 LSS 426 839 M 7 

 6/6/05 LSS 423 835 M 6 

 Mean 427 868 n/a 6.5 

MID LSS-4 05328482 6/6/05 LSS 461 1060 M 10 

 6/6/05 LSS 446 998 F 7 

 6/6/05 LSS 430 944 M 5 

 6/6/05 LSS 429 873 M 6 

 Mean 442 969 n/a 7 

MID NPM-1 05328483 6/6/05 NPM 260 149 M 5 

 6/6/05 NPM 215 82 M 3 

 6/6/05 NPM 191 66 F 3 

 Mean 222 99 n/a 3.7 

MID NPM-2 05328484 6/6/05 NPM 190 59 U 3 

 6/6/05 NPM 251 139 F 4 

 6/6/05 NPM 195 72 F 4 

 6/6/05 NPM 240 121 M 4 

 Mean 219 98 n/a 3.8 

MID CHM-1 05328485 6/6/05 CHM 198 72 F 3 

 6/6/05 CHM 217 110 M 2 

 6/6/05 CHM 225 102 M 3 

 6/6/05 CHM 225 83 M 3 

 6/6/05 CHM 253 137 F 4 

 Mean 224 101 n/a 3 

MID SMB-1 05328486 6/6/05 SMB 181 79 F 2 

 6/6/05 SMB 184 73 M 2 

 6/6/05 SMB 184 76 M 2 

 Mean 183 76 n/a 2 

 
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Sample ID Sample No. Collection 

Date Species 

Total 

Length 

(mm) 

Weight 

(g) Sex Age (yrs) 

MID SMB-2 05328487 6/6/05 SMB 164 60 F 2 

 6/6/05 SMB 176 74 U 2 

 6/6/05 SMB 184 83 U 2 

 6/6/05 SMB 171 62 M 2 

 Mean 174 70 n/a 2 

MID SMB-3 05328488 6/6/05 SMB 230 142 M 3 

 6/6/05 SMB 260 192 M 3 

 Mean 245 167 n/a 3 

 

n/a = not applicable CARP = Carp, Cyprinus carpio 

? = Unsure of sex of fish CHM = Chiselmouth, Acrocheilus alutaceus 

U = Sex not determined LSS = Largescale sucker, Catostomus macrocheilus

NF = North Fork Palouse River NPM = Northern pike minnow, Ptychocheilus oregonensis

SF = South Fork Palouse River SMB = Smallmouth bass, Micropterus dolomieui

MID = Middle Palouse River 

LWR = Lower Palouse River 
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Appendix B. Contaminant Data on Fish Samples 

Table B-1. Contaminant Data for Palouse River Fish Fillet Samples Collected in 2005 

(ug/Kg wet weight) 

Location LWR_FISH LWR_FISH LWR_FISH LWR_FISH LWR_FISH LWR_FISH

Date 6/22/05 6/22/05 6/22/05 6/22/05 6/22/05 6/23/05

Sample ID LWR LSS-1 LWR LSS-2 LWR LSS-3 LWR LSS-4 LWR LSS-5 LWR NPM-1

Sample No. 05288393 05288394 05288395 05288396 05288397 05328474

Species Largescale Largescale Largescale Largescale Largescale Northern Pike N

Sucker Sucker Sucker Sucker Sucker Minnow

Alpha-BHC 0.38 U 0.39 U 0.38 U 0.39 U 0.39 U 0.39 U

Beta-BHC 0.95 U 0.98 U 0.96 U 0.99 U 0.97 U 0.98 U

Delta-BHC 0.38 U 0.39 U 0.38 U 0.39 U 0.39 U 0.39 U

Lindane 0.38 U 0.39 U 0.15 J 0.39 U 0.39 U 0.39 U

Heptachlor 0.38 U 0.39 U 1.3 0.39 U 0.39 U 0.39 U

Heptachlor Epoxide 0.38 U 0.39 U 0.89 0.39 U 0.51 J 0.39 U

4,4'-DDT 1.4 0.98 0.79 1.1 1.3 0.39 U

4,4'-DDE 23 16 16 11 24 9.3

4,4'-DDD 1.3 0.91 0.87 0.72 1.2 0.29 J

Aldrin 0.38 U 0.39 U 0.38 U 0.39 U 0.39 U 0.39 U

Dieldrin 0.34 J 0.99 J 1 J 1.2 J 0.7 J 0.73 J

Endrin 0.38 UJ 0.39 UJ 0.38 UJ 0.39 UJ 0.39 UJ 0.39 UJ

Endrin Aldehyde 0.38 UJ 0.39 UJ 0.38 UJ 0.39 UJ 0.39 UJ 0.39 UJ

Endrin Ketone 0.38 UJ 0.39 UJ 0.38 UJ 0.39 UJ 0.39 UJ 0.39 UJ

cis-Chlordane 0.38 U 0.39 U 0.38 U 0.39 U 0.39 U 0.39 U

trans-Chlordane 0.38 U 0.39 U 0.38 U 0.39 U 0.39 U 0.39 U

cis-Nonachlor 0.38 0.31 J 0.38 U 0.36 J 0.37 J 0.18 J

trans-Nonachlor 0.38 U 0.39 U 0.38 U 0.39 U 0.39 U 0.19 J

Oxychlordane 0.38 U 0.39 U 0.49 NJ 0.39 U 0.27 NJ 0.19 J

Hexachlorobenzene 1.1 0.67 1 0.56 0.84 0.92

Endosulfan I 0.38 UJ 0.39 UJ 0.38 UJ 0.39 UJ 0.39 UJ 0.29 J

Endosulfan II 0.38 UJ 0.39 UJ 0.38 UJ 0.39 UJ 0.39 UJ 0.39 UJ

Endosulfan Sulfate 0.38 UJ 0.39 UJ 0.38 UJ 0.39 UJ 0.39 UJ 0.55 J

Methoxychlor 1.9 U 2 U 1.9 U 2 U 1.9 U 2 U

PCB-aroclor 1016 3.8 U 3.9 U 3.8 U 3.9 U 3.9 U 3.9 U

PCB-aroclor 1221 3.8 U 3.9 U 3.8 U 3.9 U 3.9 U 3.9 U

PCB-aroclor 1232 3.8 U 3.9 U 3.8 U 3.9 U 3.9 U 3.9 U

PCB-aroclor 1242 3.8 U 3.9 U 3.8 U 3.9 U 3.9 U 3.9 U

PCB-aroclor 1248 3.8 U 3.9 U 3.8 U 3.9 U 3.9 U 3.9 U

PCB-aroclor 1254 6.1 5.1 11 10 6.2 4.7 NJ

PCB-aroclor 1260 3.8 U 3.9 U 3.8 U 3.9 U 3.9 U 3.9 U

PCB-aroclor 1268 3.8 U 3.9 U 3.8 U 3.9 U 3.9 U 3.9 U

Mercury (mg/Kg ww) 0.16 0.14 J

Lipids (%) 2.77 1.96 2.64 2.36 1.91 1.55

U = The analyte was not detected at or above the reported result.

J = The analyte was positively identified. The associated numerical result is an estimate.

UJ = The analyte was not detected at or above the reported estimated result.

NJ = There is evidence that the analyte is present. The associated numerical result is an estimate.
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

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Table B-1 (cont.). Contaminant Data for Palouse River Fish Fillet Samples Collected in 2005 

(ug/Kg wet weight) 

Location LWR_FISH LWR_FISH LWR_FISH LWR_FISH MID_FISH MID_FISH

Date 6/22/05 6/23/05 6/23/05 8/3/05 6/6/05 6/6/05

Sample ID LWR NPM-2 LWR CHM-1 LWR SMB-1 LWR CARP-1 MID LSS-1 MID LSS-2

Sample No. 05328475 05328476 05328477 05328478 05328479 05328480

Species Northern Pike Chiselmouth Smallmouth Common Largescale Largescale

Minnow Bass Carp Sucker Sucker

Alpha-BHC 0.39 U 0.37 UJ 0.39 UJ 0.4 U 0.4 U 0.38 U

Beta-BHC 0.96 U 0.74 U 0.79 U 1 U 1 U 0.96 U

Delta-BHC 0.39 U 0.37 UJ 0.39 UJ 0.4 U 0.4 U 0.38 U

Lindane 0.39 U 0.37 U 0.39 U 0.4 U 0.22 J 0.34 J

Heptachlor 0.39 U 0.37 U 0.39 U 0.4 U 0.4 U 0.38 U

Heptachlor Epoxide 0.39 U 1.5 0.79 0.4 U 0.4 U 0.38 U

4,4'-DDT 0.81 0.37 U 0.34 J 0.26 J 2.6 1.7

4,4'-DDE 51 6.5 5.1 8.3 43 21

4,4'-DDD 1.7 0.44 0.2 J 0.61 1.1 0.98

Aldrin 0.39 U 0.37 UJ 0.39 UJ 0.4 U 0.4 U 0.38 U

Dieldrin 1.1 J 0.81 J 2.4 J 0.59 J 0.8 J 0.5 J

Endrin 0.39 UJ 0.37 UJ 0.39 UJ 0.4 UJ 0.4 UJ 0.38 UJ

Endrin Aldehyde 0.39 UJ 0.37 UJ 0.39 UJ 0.32 J 0.4 UJ 0.4 J

Endrin Ketone 0 0.37 UJ 0.39 UJ 0.4 UJ 0.4 UJ 0.38 UJ

cis-Chlordane 0.29 J 0.22 J 0.39 U 0.22 J 0.17 J 0.12 J

trans-Chlordane 0.25 J 0.37 U 0.87 0.26 J 0.3 J 0.25 J

cis-Nonachlor 1 0.28 J 0.39 U 0.18 J 0.7 0.38 U

trans-Nonachlor 0.89 0.2 J 0.39 U 0.21 J 0.22 J 0.17 J

Oxychlordane 0.52 0.37 U 0.39 U 0.15 J 0.2 J 0.17 J

Hexachlorobenzene 1.7 0.81 0.97 1.2 1.7 1.9

Endosulfan I 0.7 J 0.37 UJ 0.39 UJ 0.4 UJ 0.4 UJ 0.38 UJ

Endosulfan II 0.39 UJ 0.18 J 0.39 UJ 0.4 UJ 0.4 UJ 0.38 UJ

Endosulfan Sulfate 0.39 UJ 0.37 UJ 0.39 UJ 0.48 J 0.4 UJ 0.38 UJ

Methoxychlor 1.9 U 3.7 U 3.9 U 2 U 2 U 1.9 U

PCB-aroclor 1016 3.9 U 3.7 U 3.9 U 4 U 4 U 3.8 U

PCB-aroclor 1221 3.9 U 3.7 U 3.9 U 4 U 4 U 3.8 U

PCB-aroclor 1232 3.9 U 3.7 U 3.9 U 4 U 4 U 3.8 U

PCB-aroclor 1242 3.9 U 3.7 U 3.9 U 4 U 4 U 3.8 U

PCB-aroclor 1248 3.9 U 3.7 U 3.9 U 4 U 4 U 3.8 U

PCB-aroclor 1254 12 2.4 J 3.9 U 4 U 9.6 6.1 NJ

PCB-aroclor 1260 3.9 U 3.7 U 3.9 U 4 U 4 U 3.8 U

PCB-aroclor 1268 3.9 U 3.7 U 3.9 U 4 U 4 U 3.8 U

Mercury (mg/Kg ww) 0.749

Lipids (%) 1.94 2.46 0.46 2.03 2.11 1.53

U = The analyte was not detected at or above the reported result.

J = The analyte was positively identified. The associated numerical result is an estimate.

UJ = The analyte was not detected at or above the reported estimated result.

NJ = There is evidence that the analyte is present. The associated numerical result is an estimate.
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

Page 91

Table B-1 (cont.). Contaminant Data for Palouse River Fish Fillet Samples Collected in 2005 

(ug/Kg wet weight) 

Location MID_FISH MID_FISH MID_FISH MID_FISH MID_FISH MID_FISH

Date 6/6/05 6/6/05 6/6/05 6/6/05 6/6/05 6/6/05

Sample ID MID LSS-3 MID LSS-4 MID NPM-1 MID NPM-2 MID CHM-1 MID SMB-1

Sample No. 05328481 05328482 05328483 05328484 05328485 05328486

Species Largescale Largescale Northern Pike Northern Pike Chiselmouth Smallmouth

Sucker Sucker Minnow Minnow Bass

Alpha-BHC 0.37 U 0.39 U 0.36 U 0.38 U 0.36 U 0.38 U

Beta-BHC 0.93 U 0.96 U 0.89 U 0.95 U 0.91 U 0.94 U

Delta-BHC 0.37 U 0.39 U 0.36 U 0.38 U 0.36 U 0.38 U

Lindane 0.37 J 0.27 J 0.14 J 0.23 J 0.24 J 0.38 U

Heptachlor 0.37 U 0.39 U 0.36 U 0.38 U 0.36 U 0.38 U

Heptachlor Epoxide 0.37 U 0.39 U 0.36 U 0.38 U 0.36 U 0.38 U

4,4'-DDT 3.2 2.9 0.21 J 0.23 J 0.14 J 0.36 J

4,4'-DDE 43 40 32 18 15 6

4,4'-DDD 1.4 1.3 0.95 0.65 0.69 0.13 J

Aldrin 0.37 U 0.39 U 0.36 U 0.38 U 0.36 U 0.38 U

Dieldrin 1.1 J 1.4 J 1 J 1.2 J 0.85 J 0.49 J

Endrin 0.37 UJ 0.39 UJ 0.36 UJ 0.38 UJ 0.36 UJ 0.38 UJ

Endrin Aldehyde 0.37 UJ 0.39 UJ 0.34 J 0.46 NJ 0.35 J 0.38 UJ

Endrin Ketone 0.37 UJ 0.39 UJ 0.25 NJ 0.38 UJ 0.36 UJ 0.38 UJ

cis-Chlordane 0.18 J 0.18 J 0.2 J 0.19 J 0.2 J 0.38 U

trans-Chlordane 0.58 0.37 J 0.25 J 0.27 J 0.25 J 0.11 J

cis-Nonachlor 0.63 0.69 0.57 0.55 0.27 J 0.38 U

trans-Nonachlor 0.48 J 0.23 J 0.3 J 0.18 J 0.25 J 0.38 U

Oxychlordane 0.41 0.21 J 0.23 J 0.21 J 0.16 J 0.38 U

Hexachlorobenzene 2.8 2.3 1.3 1.2 1.1 0.38 J

Endosulfan I 0.37 UJ 0.39 UJ 0.36 UJ 0.46 NJ 0.27 J 0.4 J

Endosulfan II 0.37 UJ 0.39 UJ 0.45 J 0.38 UJ 0.36 UJ 0.38 UJ

Endosulfan Sulfate 0.37 UJ 0.39 UJ 0.38 J 0.38 UJ 0.36 UJ 0.38 UJ

Methoxychlor 1.9 U 1.9 U 1.8 U 1.9 U 1.8 U 1.9 U

PCB-aroclor 1016 3.7 U 3.9 U 3.6 U 3.8 U 3.6 U 3.8 U

PCB-aroclor 1221 3.7 U 3.9 U 3.6 U 3.8 U 3.6 U 3.8 U

PCB-aroclor 1232 3.7 U 3.9 U 3.6 U 3.8 U 3.6 U 3.8 U

PCB-aroclor 1242 3.7 U 3.9 U 3.6 U 3.8 U 3.6 U 3.8 U

PCB-aroclor 1248 3.7 U 3.9 U 3.6 U 3.8 U 3.6 U 3.8 U

PCB-aroclor 1254 10 9.1 8.8 8 5.8 3.8 U

PCB-aroclor 1260 3.7 U 3.9 U 3.6 U 3.8 U 3.6 U 3.8 U

PCB-aroclor 1268 3.7 U 3.9 U 3.6 U 3.8 U 3.6 U 3.8 U

Mercury (mg/Kg ww)

Lipids (%) 2.19 2.7 0.9 0.88 1.13 0.44

U = The analyte was not detected at or above the reported result.

J = The analyte was positively identified. The associated numerical result is an estimate.

UJ = The analyte was not detected at or above the reported estimated result.

NJ = There is evidence that the analyte is present. The associated numerical result is an estimate.
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

Page 92

Table B-1 (cont.). Contaminant Data for Palouse River Fish Fillet Samples Collected in 2005 

(ug/Kg wet weight) 

Location MID_FISH MID_FISH NF_FISH NF_FISH NF_FISH NF_FISH

Date 6/6/05 6/6/05 6/8/05 6/8/05 6/8/05 6/8/05

Sample ID MID SMB-2 MID SMB-3 NF CHM-1 NF CHM-2 NF CHM-3 NF CHM-4

Sample No. 05328487 05328488 05288366 05288367 05288368 05288369

Species Smallmouth Smallmouth Chiselmouth Chiselmouth Chiselmouth Chiselmouth

Bass Bass

Alpha-BHC 0.4 U 0.38 U 0.4 UJ 0.39 UJ 0.4 UJ 0.4 UJ

Beta-BHC 1 U 0.94 U 1 U 0.98 U 0.79 U 0.8 U

Delta-BHC 0.4 U 0.38 U 0.4 U 0.39 U 0.4 UJ 0.4 UJ

Lindane 0.4 U 0.38 U 0.14 J 0.39 U 0.4 U 0.4 U

Heptachlor 0.4 U 0.38 U 0.4 U 0.39 U 0.4 U 0.4 U

Heptachlor Epoxide 0.4 U 0.38 U 0.4 U 0.39 U 0.4 U 0.4 U

4,4'-DDT 0.48 1.6 0.4 U 0.17 J 0.4 U 0.4 U

4,4'-DDE 9.3 51 9.2 10 13 10

4,4'-DDD 0.28 J 1.1 0.59 0.53 0.67 0.58

Aldrin 0.4 U 0.38 U 0.4 UJ 0.39 UJ 0.4 UJ 0.4 UJ

Dieldrin 0.56 J 0.43 J 0.23 J 0.18 J 0.34 J 0.44 J

Endrin 0.4 UJ 0.38 UJ 0.4 UJ 0.39 UJ 0.4 UJ 0.4 UJ

Endrin Aldehyde 0.4 UJ 0.38 UJ 0.4 UJ 0.39 UJ 0.46 UJ 0.26 UJ

Endrin Ketone 0.4 UJ 0.38 UJ 0.4 UJ 0.39 UJ 0.4 UJ 0.4 UJ

cis-Chlordane 0.4 U 0.15 J 0.13 J 0.39 U 0.4 U 0.4 U

trans-Chlordane 0.4 U 0.34 J 0.4 U 0.39 U 0.4 U 0.4 U

cis-Nonachlor 0.11 J 0.74 J 0.4 U 0.39 U 0.26 J 0.4 U

trans-Nonachlor 0.085 J 0.36 J 0.15 J 0.22 J 0.26 J 0.4 U

Oxychlordane 0.13 J 0.23 J 0.18 J 0.39 U 0.4 U 0.4 U

Hexachlorobenzene 0.71 0.68 1 0.94 0.71 0.62

Endosulfan I 0.4 UJ 0.68 J 0.4 UJ 0.39 UJ 0.4 UJ 0.4 UJ

Endosulfan II 0.4 UJ 0.38 UJ 0.4 UJ 0.39 UJ 0.4 UJ 0.4 UJ

Endosulfan Sulfate 0.4 UJ 0.38 UJ 0.4 UJ 0.25 J 1 UJ 1.2 UJ

Methoxychlor 2 U 1.9 U 2 U 2 U 4 U 4 U

PCB-aroclor 1016 4 U 3.8 U 4 U 3.9 U 4 U 4 U

PCB-aroclor 1221 4 U 3.8 U 4 U 3.9 U 4 U 4 U

PCB-aroclor 1232 4 U 3.8 U 4 U 3.9 U 4 U 4 U

PCB-aroclor 1242 4 U 3.8 U 4 U 3.9 U 4 U 4 U

PCB-aroclor 1248 4 U 3.8 U 4 U 3.9 U 4 U 4 U

PCB-aroclor 1254 4 U 9.4 5.1 NJ 5.5 NJ 3.6 J 2.4 J

PCB-aroclor 1260 4 U 3.8 U 4 U 3.9 U 4 U 4 U

PCB-aroclor 1268 4 U 3.8 U 4 U 3.9 U 4 U 4 U

Mercury (mg/Kg ww) 0.12 0.318

Lipids (%) 0.47 0.26 1.4 1.59 1.28 1.36

U = The analyte was not detected at or above the reported result.

J = The analyte was positively identified. The associated numerical result is an estimate.

UJ = The analyte was not detected at or above the reported estimated result.

NJ = There is evidence that the analyte is present. The associated numerical result is an estimate.
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

Page 93

Table B-1 (cont.). Contaminant Data for Palouse River Fish Fillet Samples Collected in 2005 

(ug/Kg wet weight) 

Location NF_FISH NF_FISH NF_FISH NF_FISH NF_FISH NF_FISH

Date 6/8/05 6/8/05 6/8/05 6/7/05 6/9/05 6/9/05

Sample ID NF CHM-5 NF LSS-1 NF LSS-2 NF LSS-3 NF LSS-4 NF LSS-5

Sample No. 05288370 05288371 05288372 05288373 05288374 05288375

Species Chiselmouth Largescale Largescale Largescale Largescale Largescale N

Sucker Sucker Sucker Sucker Sucker

Alpha-BHC 0.4 UJ 0.39 UJ 0.38 UJ 0.39 UJ 0.39 UJ 0.4 UJ

Beta-BHC 0.79 U 0.96 U 0.94 U 0.98 U 0.98 U 0.8 U

Delta-BHC 0.4 UJ 0.39 U 0.38 U 0.39 U 0.39 U 0.4 UJ

Lindane 0.4 U 0.39 U 0.38 U 0.088 J 0.19 J 0.4 U

Heptachlor 0.4 U 0.39 U 0.38 U 0.39 U 0.39 U 0.4 U

Heptachlor Epoxide 0.4 U 0.39 U 0.38 U 0.39 U 0.39 U 0.4 U

4,4'-DDT 0.4 U 0.75 1.9 2 3.2 2

4,4'-DDE 11 5.5 18 25 40 27

4,4'-DDD 0.69 0.39 J 0.75 1.1 1.4 1

Aldrin 0.4 UJ 0.39 UJ 0.38 UJ 0.39 UJ 0.39 UJ 0.4 UJ

Dieldrin 0.43 J 0.11 J 0.26 J 0.33 J 0.55 J 0.2 J

Endrin 0.4 UJ 0.39 UJ 0.38 UJ 0.39 UJ 0.39 UJ 0.4 UJ

Endrin Aldehyde 0.63 J 0.39 UJ 0.38 UJ 0.39 UJ 0.39 UJ 0.4 UJ

Endrin Ketone 0.4 UJ 0.39 UJ 0.38 UJ 0.39 UJ 0.39 UJ 0.4 UJ

cis-Chlordane 0.4 U 0.087 J 0.11 J 0.14 J 0.21 J 0.4 U

trans-Chlordane 0.4 U 0.39 U 0.38 U 0.39 U 0.39 U 0.4 U

cis-Nonachlor 0.4 U 0.39 U 0.38 U 0.39 U 0.39 U 0.2 J

trans-Nonachlor 0.4 U 0.087 J 0.17 J 0.16 J 0.26 J 0.4 U

Oxychlordane 0.4 U 0.11 J 0.13 J 0.12 J 0.22 J 0.28 J

Hexachlorobenzene 0.75 0.54 0.79 0.86 1.9 0.9

Endosulfan I 0.4 UJ 0.39 UJ 0.38 UJ 0.39 UJ 0.39 UJ 0.4 UJ

Endosulfan II 0.4 UJ 0.39 UJ 0.38 UJ 0.39 UJ 0.39 UJ 0.4 UJ

Endosulfan Sulfate 0.4 UJ 0.39 UJ 0.38 UJ 0.17 J 0.39 UJ 1.1 UJ

Methoxychlor 4 U 1.9 U 1.9 U 2 U 2 U 4 U

PCB-aroclor 1016 4 U 3.9 U 3.8 U 3.9 U 3.9 U 4 U

PCB-aroclor 1221 4 U 3.9 U 3.8 U 3.9 U 3.9 U 4 U

PCB-aroclor 1232 4 U 3.9 U 3.8 U 3.9 U 3.9 U 4 U

PCB-aroclor 1242 4 U 3.9 U 3.8 U 3.9 U 3.9 U 4 U

PCB-aroclor 1248 4 U 3.9 U 3.8 U 3.9 U 3.9 U 4 U

PCB-aroclor 1254 4.1 4 NJ 3.8 U 3.9 U 5.1 NJ 3.2 J

PCB-aroclor 1260 4 U 3.9 U 3.8 U 3.9 U 3.9 U 4 U

PCB-aroclor 1268 4 U 3.9 U 3.8 U 3.9 U 3.9 U 4 U

Mercury (mg/Kg ww) 0.056 0.266

Lipids (%) 1.65 2.09 2.86 1.7 3.12 2.28

U = The analyte was not detected at or above the reported result.

J = The analyte was positively identified. The associated numerical result is an estimate.

UJ = The analyte was not detected at or above the reported estimated result.

NJ = There is evidence that the analyte is present. The associated numerical result is an estimate.
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

Page 94

Table B-1 (cont.). Contaminant Data for Palouse River Fish Fillet Samples Collected in 2005 

(ug/Kg wet weight) 

Location NF_FISH NF_FISH NF_FISH NF_FISH NF_FISH SF_FISH

Date 6/7/05 6/8/05 6/8/05 6/8/05 6/8/05 5/24/05

Sample ID NF NPM-1 NF NPM-2 NF NPM-3 NF NPM-4 NF NPM-5 SF CHM-1

Sample No. 05288376 05288377 05288378 05288379 05288380 05288381

Species Northern Pike Northern Pike Northern Pike Northern Pike Northern Pike Chiselmouth

Minnow Minnow Minnow Minnow Minnow

Alpha-BHC 0.39 UJ 0.4 UJ 0.39 UJ 0.4 UJ 0.37 UJ 0.4 UJ

Beta-BHC 0.99 U 1 U 0.98 U 1 U 0.74 U 1 U

Delta-BHC 0.39 U 0.4 U 0.39 U 0.4 U 0.37 UJ 0.4 U

Lindane 0.1 J 0.4 U 0.21 J 0.4 U 0.37 U 1

Heptachlor 0.39 U 0.4 U 0.39 U 0.4 U 0.37 U 0.4 U

Heptachlor Epoxide 0.39 U 0.4 U 0.39 U 0.4 U 0.37 U 0.4 U

4,4'-DDT 0.39 J 0.4 U 0.29 J 0.26 J 0.32 J 0.58

4,4'-DDE 33 28 54 54 53 25

4,4'-DDD 0.99 0.96 1.7 1.5 1.6 2.1

Aldrin 0.39 UJ 0.4 UJ 0.39 UJ 0.4 UJ 0.37 UJ 0.4 UJ

Dieldrin 0.32 J 0.34 J 0.42 J 0.6 J 0.37 UJ 0.66 J

Endrin 0.39 UJ 0.4 UJ 0.39 UJ 0.4 UJ 0.37 UJ 0.4 UJ

Endrin Aldehyde 0.39 UJ 0.4 UJ 0.21 J 0.4 UJ 0.37 UJ 0.4 UJ

Endrin Ketone 0.39 UJ 0.4 UJ 0.39 UJ 0.4 UJ 0.37 UJ 0.4 UJ

cis-Chlordane 0.39 U 0.19 J 0.23 J 0.22 J 0.37 U 0.36 J

trans-Chlordane 0.39 U 0.4 U 0.39 U 0.4 U 0.37 U 0.14 J

cis-Nonachlor 0.39 U 0.4 U 0.39 U 0.4 U 0.37 U 0.4 U

trans-Nonachlor 0.44 J 0.24 J 0.37 J 0.42 0.37 J 0.71 U

Oxychlordane 0.24 J 0.13 J 0.35 J 0.28 J 0.28 J 0.21 J

Hexachlorobenzene 1.1 0.83 1.7 1.1 1.2 2.3

Endosulfan I 0.39 UJ 0.4 UJ 0.39 UJ 0.4 UJ 0.37 UJ 0.4 UJ

Endosulfan II 0.39 UJ 0.4 UJ 0.39 UJ 0.4 UJ 0.35 J 0.4 UJ

Endosulfan Sulfate 0.39 UJ 0.4 UJ 0.25 J 0.34 J 0.37 UJ 0.15 NJ

Methoxychlor 2 U 2 U 2 U 2 U 3.7 U 2 U

PCB-aroclor 1016 3.9 U 4 U 3.9 U 4 U 3.7 U 4 U

PCB-aroclor 1221 3.9 U 4 U 3.9 U 4 U 3.7 U 4 U

PCB-aroclor 1232 3.9 U 4 U 3.9 U 4 U 3.7 U 4 U

PCB-aroclor 1242 3.9 U 4 U 3.9 U 4 U 3.7 U 4 U

PCB-aroclor 1248 3.9 U 4 U 3.9 U 4 U 3.7 U 4 U

PCB-aroclor 1254 3.9 U 4.6 NJ 8.4 4 U 8.2 18

PCB-aroclor 1260 3.9 U 4 U 3.9 U 4 U 3.7 U 4 U

PCB-aroclor 1268 3.9 U 4 U 3.9 U 4 U 3.7 U 4 U

Mercury (mg/Kg ww) 0.422

Lipids (%) 2.43 2.34 3.15 3.47 2.77 1.66

U = The analyte was not detected at or above the reported result.

J = The analyte was positively identified. The associated numerical result is an estimate.

UJ = The analyte was not detected at or above the reported estimated result.

NJ = There is evidence that the analyte is present. The associated numerical result is an estimate.
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

Page 95

Table B-1 (cont.). Contaminant Data for Palouse River Fish Fillet Samples Collected in 2005 

(ug/Kg wet weight) 

Location SF_FISH SF_FISH SF_FISH SF_FISH SF_FISH SF_FISH

Date 5/24/05 5/24/05 5/23/05 5/24/05 5/23/05 5/23/05

Sample ID SF CHM-2 SF LSS-1 SF LSS-2 SF LSS-3 SF LSS-4 SF LSS-5

Sample No. 05288382 05288383 05288384 05288385 05288386 05288387

Species Chiselmouth Largescale Largescale Largescale Largescale Largescale N

Sucker Sucker Sucker Sucker Sucker

Alpha-BHC 0.39 UJ 0.39 UJ 0.38 UJ 0.39 UJ 0.39 U 0.39 U

Beta-BHC 0.98 U 0.97 U 0.95 U 0.99 U 0.97 U 0.98 U

Delta-BHC 0.39 U 0.39 U 0.38 U 0.39 U 0.39 U 0.39 U

Lindane 0.8 1.2 1.1 1.2 0.59 0.46

Heptachlor 0.39 U 0.39 U 0.38 U 0.39 U 0.39 U 0.39 U

Heptachlor Epoxide 0.39 U 0.39 U 0.38 U 0.39 U 0.39 U 0.39 U

4,4'-DDT 0.37 J 3.4 3.6 3.3 6.4 3.4

4,4'-DDE 21 19 18 19 35 25

4,4'-DDD 1.7 1.6 1.6 1.8 2 1.1

Aldrin 0.39 UJ 0.39 UJ 0.38 UJ 0.39 UJ 0.39 U 0.39 U

Dieldrin 0.55 J 0.5 J 0.78 J 0.56 J 3.8 J 2.7 J

Endrin 0.39 UJ 0.39 UJ 0.38 UJ 0.39 UJ 0.39 UJ 0.39 UJ

Endrin Aldehyde 0.16 J 0.39 UJ 0.21 J 0.39 UJ 0.39 UJ 0.39 UJ

Endrin Ketone 0.39 UJ 0.39 J 0.47 J 0.39 U 0.39 UJ 0.39 UJ

cis-Chlordane 0.31 J 0.25 J 0.26 J 0.22 J 0.39 U 0.39 U

trans-Chlordane 0.39 U 0.39 U 0.38 U 0.39 U 0.39 U 0.39 U

cis-Nonachlor 0.39 U 0.39 U 0.38 U 0.93 2.8 1.3

trans-Nonachlor 0.35 J 0.21 J 0.3 J 0.42 0.39 U 0.39 U

Oxychlordane 0.27 J 0.18 J 0.38 U 0.28 J 0.39 U 0.39 U

Hexachlorobenzene 1.5 1.6 1.9 2.1 1.4 0.81

Endosulfan I 0.1 J 0.16 J 0.45 J 0.39 UJ 0.39 UJ 0.39 UJ

Endosulfan II 0.39 UJ 0.39 UJ 0.38 UJ 0.39 UJ 0.39 UJ 0.39 UJ

Endosulfan Sulfate 0.14 J 0.41 J 0.62 J 0.089 J 0.39 UJ 0.39 UJ

Methoxychlor 2 U 1.9 U 1.9 U 2 U 1.9 U 2 U

PCB-aroclor 1016 3.9 U 3.9 U 3.8 U 3.9 U 3.9 U 3.9 U

PCB-aroclor 1221 3.9 U 3.9 U 3.8 U 3.9 U 3.9 U 3.9 U

PCB-aroclor 1232 3.9 U 3.9 U 3.8 U 3.9 U 3.9 U 3.9 U

PCB-aroclor 1242 3.9 U 3.9 U 3.8 U 3.9 U 3.9 U 3.9 U

PCB-aroclor 1248 3.9 U 3.9 U 3.8 U 3.9 U 3.9 U 3.9 U

PCB-aroclor 1254 14 12 16 13 33 13

PCB-aroclor 1260 3.9 U 3.9 U 3.8 U 3.9 U 3.9 U 3.9 U

PCB-aroclor 1268 3.9 U 3.9 U 3.8 U 3.9 U 3.9 U 3.9 U

Mercury (mg/Kg ww) 0.049 0.304

Lipids (%) 1.1 2.32 1.83 1.75 1.37 1.4

U = The analyte was not detected at or above the reported result.

J = The analyte was positively identified. The associated numerical result is an estimate.

UJ = The analyte was not detected at or above the reported estimated result.

NJ = There is evidence that the analyte is present. The associated numerical result is an estimate.
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

Page 96

Table B-1 (cont.). Contaminant Data for Palouse River Fish Fillet Samples Collected in 2005 

(ug/Kg wet weight) 

Location SF_FISH SF_FISH SF_FISH SF_FISH SF_FISH

Date 5/24/05 5/24/05 5/23/05 5/24/05 5/24/05

Sample ID SF NPM-1 SF NPM-2 SF NPM-3 SF NPM-4 SF NPM-5

Sample No. 05288388 05288389 05288390 05288391 05288392

Species Northern Pike Northern Pike Northern Pike Northern Pike Northern Pike

Minnow Minnow Minnow Minnow Minnow

Alpha-BHC 0.38 U 0.4 U 0.39 U 0.4 U 0.39 U

Beta-BHC 0.95 U 1 U 0.98 U 1 U 0.97 U

Delta-BHC 0.38 U 0.4 U 0.39 U 0.4 U 0.39 U

Lindane 0.54 0.4 0.87 0.47 0.71

Heptachlor 0.38 U 0.4 U 0.39 U 0.4 U 0.39 U

Heptachlor Epoxide 0.38 U 0.4 U 0.39 U 0.4 U 0.39 U

4,4'-DDT 0.49 NJ 0.61 NJ 0.56 NJ 0.45 NJ 0.62 NJ

4,4'-DDE 28 48 30 22 53

4,4'-DDD 1.4 1.1 1.8 1 1.6

Aldrin 0.38 U 0.4 U 0.39 U 0.4 U 0.39 U

Dieldrin 2.4 J 2.6 J 3.6 J 2.7 J 2 J

Endrin 0.38 UJ 0.4 UJ 0.39 UJ 0.4 UJ 0.39 UJ

Endrin Aldehyde 0.38 UJ 0.4 UJ 0.39 UJ 0.4 UJ 0.39 UJ

Endrin Ketone 0.38 UJ 0.4 UJ 0.39 UJ 0.4 UJ 0.39 UJ

cis-Chlordane 0.38 U 0.4 U 0.39 U 0.4 U 0.39 U

trans-Chlordane 0.38 U 0.4 U 0.39 U 0.4 U 0.39 U

cis-Nonachlor 1.3 1.8 0.39 U 1.2 2.8

trans-Nonachlor 0.38 U 0.4 U 0.39 U 0.4 U 0.26 J

Oxychlordane 0.38 U 0.4 U 0.39 U 0.4 U 0.39 U

Hexachlorobenzene 1.2 2.7 1.5 1 1.5

Endosulfan I 0.38 UJ 0.4 UJ 0.39 UJ 0.4 UJ 0.39 UJ

Endosulfan II 0.38 UJ 0.4 UJ 0.39 UJ 0.4 UJ 0.39 UJ

Endosulfan Sulfate 0.38 UJ 0.4 UJ 0.39 UJ 0.4 UJ 0.39 UJ

Methoxychlor 1.9 U 2 U 2 U 2 U 1.9 U

PCB-aroclor 1016 3.8 U 4 U 3.9 U 4 U 3.9 U

PCB-aroclor 1221 3.8 U 4 U 3.9 U 4 U 3.9 U

PCB-aroclor 1232 3.8 U 4 U 3.9 U 4 U 3.9 U

PCB-aroclor 1242 3.8 U 4 U 3.9 U 4 U 3.9 U

PCB-aroclor 1248 3.8 U 4 U 3.9 U 4 U 3.9 U

PCB-aroclor 1254 16 25 17 12 26

PCB-aroclor 1260 3.8 U 4 U 3.9 U 4 U 3.9 U

PCB-aroclor 1268 3.8 U 4 U 3.9 U 4 U 3.9 U

Mercury (mg/Kg ww) 0.16 0.465

Lipids (%) 1.18 1.78 1.88 1.24 0.92

U = The analyte was not detected at or above the reported result.

J = The analyte was positively identified. The associated numerical result is an estimate.

UJ = The analyte was not detected at or above the reported estimated result.

NJ = There is evidence that the analyte is present. The associated numerical result is an estimate.
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

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Appendix C. Tracking Tables 

Department of Timeline 

Ecology – 

Water Quality 

Program 

2007 2008 2009 2010 2011 2012 2013 2014 

Issue municipal stormwater permit to city of Pullman and WSU Provide stormwater technical assistance Monitor permit implementation by reviewing annual reports Track progress of activities outlined in plan 

Performance Measures

Investigate further monitoring to locate sources of dieldrin and PCBs (if adaptive management is needed) 

 Incorporate 

WLAs into NPDES Permits 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

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Department of Timeline 

Ecology – 

Environmental 

Assessment Program 

2007 - 2012 2013 - 2017 2018 - 2022 Future 

Sample Palouse River and South Fork Palouse River Fish to determine tissue concentrations 

Performance Measures Assess levels of PCBs and dieldrin in influent and effluent of WWTPs 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

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Timeline 

City of Pullman 

2007 2008 2009 2010 2011 2012 2013 2014 

Implement requirements of Phase II municipal stormwater permit Require Erosion and Sediment Control plans for land altering activities and building permits Continue to train engineering and building division personnel as Certified Erosion and Sediment Control Leads (CESCL) Increase annual storm drain pipe maintenance 

Performance Measures

Revise City’s Design Standards to reference the Stormwater Management Manual for Eastern Washington
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

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Timeline 

City of Pullman 

2007 2008 2009 2010 2011 2012 2013 2014 

Complete storm drain computer mapping project 

 Meet conditions 

of NPDES wastewater permit 

Timeline 

Cities of Colfax 

and Albion 2007 2008 2009 2010 2011 2012 2013 2014 

Performance 

Measures

Meet 

conditions of 

NPDES 

wastewater 

permit 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

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Timeline 

Washington State 

University 2007 2008 2009 2010 2011 2012 2013 2014 

Implement requirements of Phase II municipal stormwater permit Proactively removing all PCB sources on campus to a level below Federal and Washington State regulations Illicit discharge detection program Computerized mapping system of existing stormwater lines, catch basin locations and drainage areas 

Performance Measures

Overseeing construction project one acre or greater than require Construction Stormwater NPDES permits 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

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Timeline 

Washington State 

University 2007 2008 2009 2010 2011 2012 2013 2014 

Increase video inspection and repair all storm sewer lines 

Street and parking lot maintenance 

Whitman County Timeline 

Regional Health 

Department 2007 2008 2009 2010 2011 2012 2013 2014 

Performance MeasuresInvestigate an abandoned landfill and incinerator along the South Fork Palouse River to determine if they are 

sources 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

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Palouse Watershed Timeline 

Conservation 

Districts 2007 2008 2009 2010 2011 2012 2013 2014 

Report number of acres converted to conservation tillage or BMP projects that significantly reduce erosion 

Performance Measures Seek additional funding opportunities to 

support this action 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

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Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

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Appendix D. Response to Comments 

A 30-day public comment period ran from May 24 to June 22, 2007. Ecology received the 

following comments: 

Comments from Mark Solomon, Moscow, ID: 

 

Has the WRIA group been informed of the levels of PCBs in the N. Fk? While below human 

health levels they are above Safe Drinking Water standards which could and should effect plans 

to recharge groundwater aquifers with N. Fk water between Potlatch and Palouse. While not 

mentioned in the TMDL, the former Potlatch mill site on the N. Fk floodplain just upstream from 

the WA line is highly contaminated with PCBs from leaking transformers (I worked there as a 

salvage contractor during the teardown in 1982). 

Response: 

In 2006 Ecology made an announcement to the Palouse Watershed Planning Group about the 

results of the fish tissue study. In addition, an email announcement about the public comment 

period was distributed by the Palouse Conservation to the Planning Unit. The fish tissue data 

from this study is available in Appendix B of this report and on Ecology’s Environmental 

Information Management System website (www.ecy.wa.gov/eim/). This TMDL study only 

evaluated the level of PCBs and chlorinated pesticides in fish tissue. It did not measure the levels 

in the water column. However, the fish tissue data can be used to estimate the levels in the water 

column. 

The Environmental Protection Agency's (EPA) Maximum Contaminant Level Goal (MCLG) for 

PCBs is 0 mg/l. EPA's Maximum Contaminant Level (MCL) (allowed level in drinking water) 

for PCBs is 0.0005 mg/l. Ecology’s estimate of the PCB level in the North Fork Palouse (based 

on the levels in the fish tissue) is 0.13 ng/l which is equivalent to 0.00000013 mg/l. These 

estimates can be found in Table 16 of this report. Therefore, our estimate of the PCB levels in the 

North Fork Palouse River is below the Maximum Contaminant Level allowed in drinking water. 

It is important to note though, that this is only an estimate based on the levels in fish tissue and 

not an actual sample taken from the river. The Watershed Planning Unit will use available data 

to determine the feasibility of any activities they implement. 

Thank you for the information about the Potlatch Mill Site. 

Comments from Alex McGregor, The McGregor Company: 

I have read the PCB chlorinated hydrocarbon plan. I think the trend lines are encouraging and the 

recommendation of moving from category five to category one to be appropriate. I found one 

very minor typo on page 65—referencing ‘natural attention’ instead of ‘natural attenuation’. But 

that extremely minor suggestion I found while wearing my proofreader hat aside, it looks very 

solid. 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

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Response: 

Thank you for your review and comment. The typographical error has been corrected. 

Comments from Kevin Gardes, Deputy Public Works Director, City of Pullman: 

I am submitting comments below, on the behalf of the City of Pullman, on the draft Palouse 

River Chlorinated Pesticide and PCB Water Quality Improvement Report and Implementation 

Plan. 

1. In Table ES-3, with respect to interim wasteload allocations we request that Ecology 

recognize that the wasteloads on the point source wastewater treatment plants may need to be 

revised upward (increasing the wasteload allocation) as more data becomes available. 

Ecology acknowledges in the draft document that available information is extremely limited. 

Ecology has also stated to us on numerous occasions that they feel that natural attenuation 

and the implementation of stormwater BMPs is the best approach for addressing toxics, since 

these pollutants are no longer being used. It is our understanding that there really isn’t a good 

method for removing these pollutants at the wastewater treatment plant other than the amount 

normally removed through a typical biological treatment plant. Coupled with that fact that 

these pollutants are being measured in the parts per trillion range, it seems unlikely that the 

city would be able to implement a cost-effective removal strategy at the wastewater treatment 

plant should subsequent testing show concentrations in our effluent above the interim limits 

in Table ES-3. 

Thank you for considering our comments and we appreciate Ecology’s willingness to continue 

working with us to find the best solution to addressing toxics in the South Fork of the Palouse 

River. 

Response: 

Thank you for your review and comment. Because the South Fork Palouse River exceeds the 

loading capacity for dieldrin by 59% and PCBs by 71%, Ecology is not able to include mixing 

zone dilution in the wasteload allocations. Therefore, the interim wasteload allocations can not 

be revised upward until the river can provide the necessary dilution. However, Ecology 

acknowledges that the most likely sources of PCBs and dieldrin to the treatment plant are 

infiltration/inflow (I/I), illicit connections or industrial users. Therefore, if monitoring determines 

the treatment plant’s effluent exceeds the wasteload allocation, Ecology will work with the city 

to develop a compliance schedule for determining sources to the collection system. In managing 

the treatment plant’s NPDES permit, Ecology will focus on implementing the compliance 

schedule over meeting the wasteload allocations. The city and Ecology’s efforts should be 

dedicated to finding and eliminating sources to the collection system rather than treating for 

removal at the treatment plant. 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

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Comments from Gene Patterson, Public Health/Air & Water Quality Manager, 

Washington State University: 

The following are WSU comments to the draft Palouse River Chlorinated Pesticide and PCB 

TMDL Report: 

Page 7, 1st sentence in paragraph after Table ES-4: Delete “attention” and insert 

“attenuation”. 

Page 38, 2nd paragraph, last sentence: Delete “the hospital” since it has moved. 

Page 44, 4th paragraph, last sentence: Replace “John Sykes” with “John Skyles”. 

Page 44, 5th paragraph, first and second sentences: Change “chemical dump” and “dump” to 

“chemical waste landfill”. 

Page 63, add the following sentence to end of the first full paragraph: “If WSU is determined 

not to be subject to an individual NPDES permit, this TMDL assumes that compliance with 

the Eastern Washington Stormwater Manual BMPs is the only requirement that WSU needs 

to fulfill to accomplish the objectives of this TMDL.” 

Page 63, second paragraph, item #5: Change “over the next five years” to “as budgeting 

allows” to be consistent with the City of Pullman section. 

Page 66, Table 22, WSU section, first row: Change “2011” to “on-going, report progress 

annually” to be consistent with the City of Pullman section. 

Page 103, WSU timeline, first row: Change “Video inspection and repair of all storm sewer 

lines” to “Increase video inspection and repair of storm sewer lines” to be consistent with the 

City of Pullman timeline. 

Thank you for the opportunity to review and comment to the draft report. 

Response: 

Thank you for your review and comment. All WSU comments except the 5th comment have been 

incorporated into the text of this report. The 5th comment was addressed by adding the following 

text on page 63: 

In the event WSU is determined to not require coverage under the Phase II Municipal 

Stormwater NPDES permit, WSU can comply with this TMDL by implementing the 

recommendations in the Eastern Washington Stormwater Manual, paying particular attention 

to developing and carrying out the eight core elements outlined in Chapter 2 of the manual. 

Since the Pullman Stormwater Pilot Study for Pesticides, PCBs, and Fecal Coliform Bacteria 

(Lubliner, 2006) indicated stormwater was a significant source of PCBs and dieldrin, BMPs 

and maintenance and operation practices must be conducted to ensure sediment, which may 

carry PCBs and dieldrin, does not enter local streams. 
Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan 

Page 108

Similar language was added for the city of Pullman for consistency. 

Comments from William C. Stewart, Environmental Protection Agency: 

Thank you for the opportunity to comment on the draft Palouse River Toxics Total Maximum 

Daily Load. The document is well written and well organized. 

After a thorough review of this document, I have no comments at this time. 

Again, thank you for the opportunity to review this TMDL and I look forward to seeing the final 

version of this document. I would be happy to discuss this project with you at your convenience. 

Response: 

Thank you for your review and comment.