# 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 De partment 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 avai lable 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 public ation is for descriptive purposes only and does not imply endorsement by the autho r or the Department of Ecology.

If you need this publication in an alternat e 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-Mi ller, 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: Pal ouse River (WA-34-1010), S.F. Palouse River (WA-34-1020), N.F. Palouse River (WA-34-1030)This page is purposely left blankPalouse 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....................................................................................... 44Palouse 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 Implementa tion Plan .......................................................................................................... 57 Introduction.................................................................................................................. 57 What Needs to be Done?.............................................................................................. 57 Who Needs to Participate?........................................................................................... 59 What is the Schedule for Achiev ing 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 ....................................................................... 105Palouse 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 Co llected 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 C oncentrations and EPA Bioconcentration Factors........................................................................................................................

.......... 5

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

Table ES-4. Estimates of Reductions Needed in Fish Tissue Concentrations of Dieldrin and PCBs to Meet Water Qual ity 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 Cr iteria for Chlorinated Pesticides and PCBs Detected in the Palouse River Basin........................................................................ 22 Table 4. Numerical Targets for the Pal ouse River Chlorinated Pesticide and PCB TMDL.......................................................................................................................

. 24 Table 5. Historical Ecology Data on Chlorina ted Pesticides and PCBs Detected in Palouse River Fish ............................................................................................................. 26Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page iv Table 6. USGS Data on Chlorinated Pestic ides 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 Pestic ides and PCBs Detected in Sediment Samples Collected from the Pal ouse 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 fo r Chlorinated Pesticides in the Palouse River Water Samples Collected by Ecology on May 11, 2004 ......................................... 33
Table 10. Mean Concentrations of 303(d) Listed Pesticid es 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 Discha rge 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 Si tes 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 th e 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 Wast eload Allocations for Palouse River Wastewater Treatment Plants ............................................................................................ 48 Table 19. Comparison of Historical and R ecent Data on 303(d) Listed Pesticides and PCBs in Lower Mainstream Pal ouse 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) Listi ngs Recommended for a Cate gory 1 Classification.............. 58
Table 22. Activities and Resources to Reduce Dieldrin and PCBs .................................. 65 Table 23. Potential Funding Sources for Implementation Projects .................................. 70Palouse 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 fo r 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 estuar ies, lakes, and streams that fall short of state surface water quality standards, a nd 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, pr event 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 compri sed of non-self-replica ting introduced native species, do not need to receive fu ll support as an existing use.

Harmonic Mean Flow: One of several methods of calculati ng an average rate of flow. The harmonic mean is defined as Q h = n/ ∑ (1/Q i ) where n is the number of recorded flows Q i
. The harmonic mean is never larger than the geometric mean or the arithmetic mean.

Load Allocation (LA): The portion of a receiving waters’ load ing 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 a nd quality of the r eceiving 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) owne d or operated by a state, city, town, borough, county, parish, district, association, or other public body having jurisdic tion over disposal of wastes, storm water, or other wastes and (ii) designed or us ed for collecting or conveying stormwater; (iii) which is not a combined sewer; and (iv) which is not pa rt 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, m onitoring and enforcing permits, and imposing and enforcing pretreatment requirements unde r the Clean Water Act. The NPDES program regulates discharges from wastew ater treatment plants, large fact ories, 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 limite d 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 polluti on 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 stormwat er regulation required under the federal Clean Water Act. The permit is issued to medium and large municipal separate storm sewer systems (MS4s) and constructi on sites of five or more acres.

Phase II Stormwater Permit: The second phase of stormwat er regulation required under the federal Clean Water Act. The permit is issued to smaller municipal separate storm sewer systems (MS4s) and construc tion sites over one acre.

Point Source: Sources of pollution that discharge at a specific location from pipes, outfalls, and conveyance channels to a surface wa ter. Examples of point sour ce discharges include municipal wastewater treatment plants, municipal stormwater systems, industrial wast e treatment facilities, and construction sites that clea r more than 5 acres of land.

Pollution: Such contamination, or other alteration of the physical, chemical, or biological properties, of any waters of the st ate, including change in temperat ure, taste, color, turbidity, or odor of the waters, or such discharge of any liqui d, 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 le gitimate 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, paveme nt, and roofs during rainfall or snow melt. Stormwater can also come from hard or satu rated grass surfaces such as lawns, pastures, playfields, and from gravel roads and parking lots.

Surface Waters of the State : Lakes, rivers, ponds, stream s, 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 Page vii 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 natura l sources, and (4) a Ma rgin of Safety to allow for uncertainty in the wasteload determin ation. 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 benzen e hexachloride (hexachlorocyclohexane) DDD dichlorodiphe nyl dichloroethane DDE dichlorodiphenyl dichloroethylene DDT dichlorodiph enyl trichloroethylene Ecology Washington Stat e 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 Wa shington State) TOC total organic carbon TSS total suspended solids WAC Washington Ad ministrative 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 l iter (parts pe r trillion) ug/Kg micrograms per kil ogram (parts per billion)Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page viii This page is purposely left blankPalouse 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 th e 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 pest icides, 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 cl eaning up 303(d) listed wa ters and to establish a water quality improvement plan or Total Max imum Daily Load (TMDL) for each. A TMDL includes an analysis of how mu ch of a pollutant load a wa terbody can assimilate without violating water quality standards.

Part 1 of this report reviews data on the levels an d sources of chlorinated pesticides and PCBs in the Palouse River basin. The resu lts are used to: (1) recommend a ch ange in the listing status for 4,4’-DDE, heptachlor epoxide, and alpha-BHC from Category 5 (TMDL requi red) to Category 1 (meets standards); and (2) propose a fish tissue-ba sed 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 wa ter quality standards. The plan recommends monitored natural attenuation, as well as stormw ater 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 pe ople 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 C ounty 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 Departme nt of Ecology staff:

o Casey Deligeannis, Jim Ross, and Brandi Lubliner.

o Manchester Laboratory: Jeff Westerlund, Myrna Ma ndjikov, Karin Feddersen, Dean Momohara, Pam Covey, Sara Sekerak, and Will White.

o This report benefited from re view comments by Dale No rton, Karin Baldwin, and Ron McBride.

o The final report was formatted by Joan LeT ourneau, 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) pr epares the 303(d) list of waterbodies that do not meet Washington State water quality st andards. 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 allocate s 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 wate r 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 epoxid e, 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 polychlor inated 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 probabl e 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 Wa shington 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 refe rred to as the North Fork. The North Fork and South Fork merge at Colfax to form th e mainstem of the Palouse River.

The primary land use in the basin is dryland ag riculture 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 wa ter. 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 infl uenced by urban pollution sources, having the two largest cities in its drainage: Pu llman, Washington, and Moscow, Idaho.


## Applicable Water Quality Criteria

Two sets of Washington State wate r quality criteria appl y to the chlorinated pesticides and PCBs that have been detected in the Palouse River: on e 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 aPalouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 4 lifetime due to fish and water consumption. Al most all of the cancer risk is due to fish consumption.


## Numerical TMDL Targets

For the Palouse River chlorinated pesticide a nd 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 th at 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 Pal ouse 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 conve rsion 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 pe sticide and PCB residues in fish fillet samples (May–August 2005); and a pilo t study of chlorinated pesticides, PCBs, and other contaminants in Pullman stormwater runoff (w inter 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 me t the criterion in all areas. Dieldrin and PCBs were close to human health criteria leve ls 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 unde r the National Pollutant Disc harge Elimination System (NPDES). Pullman will be regula ted 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 durin g three storm events. 303(d) pesticides andPalouse 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 substant ially 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 loadin g capacity of the Palouse River was calculated for 303(d) listed chemicals by multiplying stre amflow by the human health water quality criterion. The river’s loading capacity for most ch emicals is substantially less than one gram per day.

The 2005 fish tissue data were used to cal culate 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 a nd EPA Bioconcentration Fa ctors (Values greater than 1 exceed loading capacity)

Exceedance Factors (Estimated ambient water concentration / human health water quality criterion) Chemical
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 ca pacity for dieldrin and PCBs by factors of 2 to 3, respectively.

2. The mainstem Palouse River (below Colfax) slig htly 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 tota l allowed pollutant amount and its components: appropriate wasteload allocations (WLAs) fo r point sources; load allocati ons (LAs) for nonpoint sources; and natural background. The allocations proposed for dieldrin and PCBs in the Palouse River are shown in Table ES-3.Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 6 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 crit eria 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 pres ence of these contaminants in the environment increases the likelihood they are present in the WWTP effl uents. Other water quality assessments of WWTPs have found PCBs and diel drin in wastewater e ffluent (Golding, 2001; Serdar, 2003; Johnson et al., 2004). Therefore WLAs were assigne d for the three WWTPs that discharge to parts of the river where loading cap acity is exceeded. Because the receiving waters already exceed loading capacity, th e WLAs were set to meet the hum an health criteria at the end of pipe for each facility’s design flow. These ar e interim WLAs that will be revised as more knowledge is gained about th e levels being discharged.

Because of the variability of storm events, EP A recommends that effluent limits for NPDESregulated municipal stormwater di scharges be expressed as best management practices (BMPs) rather than as numeric limits. BMPs for Pu llman 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 P CBs were set equal to the loading capacities minus the sum of the WLAs and margin of safe ty. Because dieldrin and PCBs are man-made chemicals, there is no contribution from natu ral background. Therefor e the LA for natural background is zero for both chemicals. A 20% marg in of safety was included in the allocations to account for uncertainty in understanding the relationship betw een pollutant discharges and water quality impacts.

As with other chemicals banned by EPA, environm ental 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 concentr ations 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 play ed 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 st andards are shown in Table ES-4.

Table ES-4. Estimates of Reductions Needed in Fish Tissue Concentrat ions 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 atte nuation, monitoring, and BMPs be relied on to bring the Palouse River into compliance with water quality standard s for dieldrin and PCBs. A monitored natural attenuation approach is warranted because (1) the le vels are low relative to human health criteria, (2) the chemicals of concern ar e no longer used, (3) fish tissue concentrations have decreased over the past 10–20 years and will continue to de crease without further action being taken, and (4) a monitored natural attenuati on approach is consistent with EPA-approved TMDLs in other states with similar 303(d) listings. The Washingt on State Department of Health has reviewed the fish tissue data for the Palouse River and does no t 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 ol d dumps vulnerable to high water events or surface runoff during storms.Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 8 

## Recommendations

1. The 303(d) Category 5 listings (Polluted Wa ters that Require a TMDL) for 4,4’-DDE, heptachlor epoxide, and alpha-BHC in the Pal ouse River should be moved to Category 1 (Meets Tested Standards for Clean Waters).

2. Ecology should periodically monitor fish tissu e 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 diel drin 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 abandone d landfills and old dumps vulnerable to high water events or surface runoff during storms, dete rmine if they are sour ces of dieldrin or PCBs to the Palouse River, and remediate as needed.

6. It is anticipated that most s ources of dieldrin and PCB are from nonpoint sources. However, if levels do not continue to decline in Palous e 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 implementati on strategy and the implementation plan required by Ecology’s memorandum of agreement with EPA.

Waterbody segments found to meet water quality standards during the st udy will be moved from Category 5 (Polluted Waterbodies Requiring a TM DL) to Category 1 (Meets Tested Standards) on Ecology’s Water Quality Assessm ent. 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 le vels of PCBs and dieldrin in the rivers. Limited data suggest that complia nce with the water quality standards could be achieved by 2012 for dieldrin and PCBs in the ma instem 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 Page 9 Several agencies and programs will work collaborati vely to ensure that levels of dieldrin and PCBs continue to decline. Entities that regu late or discharge stormwater and wastewater, regulate landfills, monitor water quality, or prov ide technical assistance and funding for methods that reduce erosion should participate in this TM DL. 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 Univ ersity, and the conservation di stricts 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 organi zations will evaluate other me thods and activities that could help the river meet water quality standards.Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 10 This page is purposely left blankPalouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 11 

# Part 1Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 12 This page is purposely left blankPalouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 13 

# What is a Total Maximum Daily Load (TMDL)?

Federal Clean Water Act Requirements

The Clean Water Act established a process to id entify and clean up pollute d waters. Under the Clean Water Act, each state is required to have its own water quality standards designed to protect, restore, and preserve wa ter quality. Water quality standa rds consist of designated uses for protection, such as cold water biota and drin king water supply, and cr iteria, usually numeric criteria, to achieve those uses.

Every two years, states are required to prepare a list of waterbodies – lake s, rivers, streams, or marine waters – that do not meet water quality standa rds. This list is call ed 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 usi ng 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 comple te story about the condition of Washington’s water. This list divides waterbodies into one of five categories:

Category 1 – Meets standards for para meter(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 su ch 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 Maxi mum 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 Page 14 

## 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 problem s 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 st andards (the loading capacity) and allocates that load among the various sources.

If the pollutant comes from a discrete (point) so urce such as a municipal or industrial facility’s discharge pipe, that facility’s sh are of the loading capacity is calle d a wasteload allocation. If it comes from a set of diffuse (nonpoi nt) sources such as general urba n, 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 pr oblem 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 le ss than the loading capacity.

TMDL = Loading Capacity = sum of all Wasteloa d Allocations + sum of all Load Allocations + Margin of Safety


## Total Maximum Daily Load Analyses: Loading Capacity

Identification of the contaminant loading capac ity for a waterbody is an important step in developing a TMDL. EPA defines the loading capaci ty 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 reduc tion 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 Page 15 

# Why is Ecology Conducting a TMDL Study in This Watershed?

Overview

The lower Palouse River (near Hooper and Wi nona, WA) has been list ed 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, alph a-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 lis tings are based on sampling of edible fish tissue conducted by the Washingt on State Department of Ecol ogy (Ecology) in 1984 and 1994.

These chlorinated pesticides, breakdown products, and polychlor inated 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 occurren ce, and health effects have been prepared by the Agency for Toxic Substances and Di sease 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, includi ng the Washington portion of the South Fork (Water Resource Inventory Area 34).

The Palouse River drains approximately 3,300 s quare miles of the Columbia Plateau in southeastern Washington and th e Idaho Panhandle (Figure 1). Ei ghty-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 dryl and farming in the central part of the basin and rangeland to the west, before its confluence w ith the Snake River at an elevation of about 500 ft. Major tributaries to th e Palouse are the South Fork Pa louse River and Paradise, Rebel Flat, Rock, Union Flat , and Cow Creeks.

The segment of the mainstem between the Washingt on-Idaho state line and the town of Colfax is locally referred to as the North Fork. The Nort h 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 Page 16 Figure 1. Palouse River Basi n (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 ar e the major crops. Irrigated farming along the Palouse River and its tribut aries contributes less th an 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 Wa shington cities are Pullman (pop. 26,779), Colfax (4,124), and Palouse (1,408). Moscow (2 1,674) 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. Pe lletier (1993) developed a TMDL for ammonia in the South Fork. He concluded that “Effluent from...Moscow and Pullman comprise most of thePalouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 17 river flow during July-November of a typical ye ar and during any month of the year for design low flows.”

Flows in the Palouse River and its tributarie s have a strong seasonal variation, with high discharge in the late winter a nd 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 appr oximately 13 inches annually in the southwestern part of the basin to over 25 inches in the m ountainous headwaters. Approximately 85% of the precipitation occurs between October and May, with 40% o ccurring 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 MarFlow (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 ch allenge in the Palouse. Farming began in the late 1800s. Erosion became particularly serious in the ea rly 1900s when steep lands once used for hay and pasture were converted to gr ain production (Ebbert and Roe, 1998; USDA, 1978). About 40% of the rich Palouse soils have b een 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 tota l suspended sediment data for Hooper (Hallock and Ebbert, 1996; E bbert and Roe, 1998). Although there were indications of improvement, the data were consid ered inconclusive becaus e 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 Page 18 The fish fauna in the Palouse River is limited with respect to species generally considered desirable as food. The predominant species of ca tchable size are large-sc ale 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 ca rp; 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), ther e is very little sport fishing above Palouse Falls (r.m. 7.0) in the Wa shington 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 ba ss fishery on the North Fork and some fishing in Rock Creek for brown trout and smallmouth bass. Rainbow trout are stoc ked 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 ea stern Washington river basins, WDFW has never observed them fishing in the Palouse. (Per sonal 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 produc t of the insect icide heptachlor)

• alpha-BHC (component of the inse cticide benzene hexachloride)

• dieldrin (insecticide)

• PCBs (industrial use chemicals)

The PCB data presented in this report are expressed in term s of Aroclor-equivalents (e.g., PCB1260) or total PCBs (sum of Aroclor-equivalent s 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 specif ically addressed by this TMDL study and implementation plan. In addition, the river segments listed in Ta ble 2 were found to contain fish with dieldrin and PCB concentrations above th e human health criteria during a 2005 fish tissue study conducted by Ecology and descri bed later in this report.Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 19 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 longitudePalouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 20 This page is purposely left blankPalouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 21 

# 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 mainst em Palouse is a Class B river from the mouth to its confluence with the South Fork Palouse Ri ver. The Palouse River from the South Fork confluence to the Idaho border (North Fork Palous e River) is a Class A river. The South Fork Palouse River is Class A to the Idaho border. Be neficial 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, spaw ning (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 (Cla ss 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 in clude fish spawning and rearing, primary contact recreation, and domestic water s upply as beneficial uses.



## Toxic Substances

WAC 173-201A-030 states the following w ith 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 char acteristic water uses, cause acute or chronic conditions to the most sensitive biota dependent upon those waters, or adversely affect public health, as determ ined 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 characteristicPalouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 22 water uses, cause acute or chronic toxicity to the most sensitive biot a dependent upon those waters, or adversely affect public hea lth, as determined by the department. (2) The department shall employ or require chemical testing, ac ute and chronic toxicity testing, and biological assessments, as appropriate, to eval uate 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 toxi c 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 info rmation 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 carc inogenic 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 crite ria that apply to the chlorina ted 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 trillio n) (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 timePalouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 23 

### Aquatic Life Criteria

The aquatic life criteria are designed to protect for both short-term (acute) and long-term (chronic) effects of toxics exposur e. Aquatic life criteria are pr imarily intended to avoid direct lethality to fish and other aquatic life within th e specified exposure periods. The chronic criteria for PCBs and many of the chlorinated pesticides are to protect fish-eati ng wildlife from adverse effects due to bioaccumulation.

The exposure periods assigned to the acute criteria are expres sed 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 ha ve rarely been observed in the Palouse River.



### Human Health Criteria

Criteria for the protection of human health ar e contained in the EPA National Toxics Rule (NTR), issued to Washington State in 1992. In fr eshwaters, the criteria take into account the combined exposure of both drinking the water and eati ng fish that lived in th e water. The criteria are established to protect agai nst non-carcinogenic illness and to keep the risk of developing cancer to a pre-specified level. In Washington, the cancer risk is se t 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 bo dy size, fish and water consumption, and the number of years exposed. For example, in Washi ngton the risk is correlated to an average-sized man consuming 6.5 grams per day of fish (approx imately 5 pounds per year), drinking 2 liters of water (if a freshwater body), and continuing this pattern for 70 y ears. People with higher or lower exposure patterns would face higher or lowe r 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 a nd 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 (BCF 1 ) 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= C t /C w , where C t is the contaminant concentration in tissue (wet weight) and C w is the concentration in water.Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 24 Table 4. Numerical Targets for the Palous e 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 conve rsion 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 sample s can provide representative data, in contrast to water where a much larger sample size w ould be required to determine compliance with standards.Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 25 

# Review of Historical Pesticide/PCB Data

The Department of Ecology (Ecology) fish tissue da ta that resulted in 303(d) listings for the Palouse River are summarized in Table 5 and are co mpared to the listing criteria. Each of these samples was a composite formed by pooling tissues from five individual fi sh. 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 pesticid es, breakdown products, and P CB 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 b illion). Concentrations of dieldrin, heptachlor epoxide, alpha-BHC, a nd 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 f ound 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 dete ction 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 Centra l 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 collec ted from the upper Palous e River in Idaho, the North and South Forks, the lower mainstem, Para dise Creek, and Pine Cr eek. Each data point represents a single sample. Whole fish data ca nnot be compared to 303(d) criteria, which apply to edible tissue only.

4,4’-DDT, 4,4’-DDE, 4,4’-DDD, hexachlorobenzene, a nd dieldrin were detected in most of the USGS whole fish samples. The highest to tal 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 Pe sticides 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 reportedPalouse River Toxics TMDL: Water Quality Improvement Report and Implementation PlanPage 27Table 6. USGS Data on Chlorinated Pesticides and PCBs Detected in Whole Body Samples of Largescale Suckers Collectedfrom the Palouse River Basin in 1992 and1994 (ug/Kg wet weight; parts per billion)Location4,4'-DDD4,4'-DDE4,4'-DDTTotalDDTHexachloro-benzeneDieldrinEndrinTotalChlordaneTotalPCBsPalouse R. @ Harvard (ID) nd nd nd nd nd nd nd nd ndN.F. Palouse R. @ Colfax nd 160 24 180 26 32 nd nd nd" 22 400 29 450 33 22 nd 53 70S.F. Palouse @ Colfax nd 340 nd 340 16 nd nd nd ndPalouse R. @ Hooper 5.1 87 7.0 99 14 7.8 9.2 nd ndParadise Creek 58 120 nd 180 11 nd nd nd 820Pine Creek 6.9 120 8.6 140 27 21 10 14 ndData from Munn and Gruber (1997)nd = not detectedTable 7. USGS Data on Chlorinated Pesticides and PCBs Detected in Sediment Samples Collected from the Palouse RiverBasin in 1992 and 1994 (ug/Kg organic carbon; parts per billion)Location4,4'-DDD4,4'-DDE4,4'-DDTTotalDDTHexachloro-benzeneLindaneDieldrinTotalChlordaneTotalPCBsPalouse R. @ Harvard (ID) nd nd nd nd nd nd nd nd nr" nd nd nd nd nd nd nd nd nrN.F. Palouse R. @ Colfax 150 530 160 840 330 170 110 nd nr" nd 320 92 410 470 140 150 610 nrS.F. Palouse @ Pullman nd 380 nd 430 nd nd nd nd nrS.F. Palouse @ Colfax 120 230 nd 350 nd nd nd nd nrPalouse R. @ Hooper nd 230 nd 230 180 nd nd nd nrParadise Creek nd 180 110 290 nd nd 100 140 nrUnion Flat Creek 240 1,000 130 1,400 370 130 nd nd nrPine Creek nd nd nd nd 92 nd nd nd nrData from Munn and Gruber (1997)nd = not detectednr = analyzed but data not reportedPalouse 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/Kg oc , was reported in Union Flat Creek. PCBs were apparen tly not detected at or above 1.0 ug/Kg oc in the sediments, but the report is unclear on this point. Once again, alpha-BHC a nd heptachlor epoxide were not detected. There are no state sta ndards or 303(d) criteria for pes ticides 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 da ta 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 s ites in the basin also ha d lindane detected. The median and maximum concentrations at Hoope r were 5 and 81 ng/L (p arts 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. Ma ximum concentrations were 10, 3, and 7 ng/L, respectively. Detection limits for these compoun ds 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 we re at or below the Washington State aquatic life criterion of 80 ng/L for chr onic 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 ar e 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 re strictive 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. Di eldrin 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 th e majority of samples.Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 30 This page is purposely left blankPalouse 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 th ese studies are summarized below. The complete data generated by these efforts can be accesse d through Ecology’s Environmental Information Management system (EIM, www.ecy.wa.gov/eim/ ).

The Ecology Manchester Environmental Laborato ry prepared written case narratives assessing the quality of these data. The reviews includ e a description of analytical methods and an assessment of holding times, tuning, initial and continuing calibra tion verification and degradation checks, method blanks, matrix spik e/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 qualif ied as estimated values. Large amounts of interfering substances were enc ountered in the stormw ater samples; all of the concentrations reported here are estimates.


## Low-level Pesticide Analysis

The detection limits in the histor ical 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 draina ge. A second sample from this site and one sample each from the North and South Forks near Colfax were an alyzed for DDT compounds only. The results are summarized in Table 9. At the time these samp les were taken (May 11, 2004), river flow was 237 cfs at Hooper. Total suspe nded solids ranged from 3–19 mg/L at the sampling sites.

Six compounds were detected in the Hooper sample. These incl uded 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 wa s present at the highest concen tration (0.68 ng/L) but did not exceed human health criteria. This is consiste nt with earlier USGS findi ngs. Dieldrin exceeded human health criteria by a factor of 3. Heptachlor epoxide was atthe 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 sample s 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 wa s 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 di eldrin as being the major pesticid e contaminant of concern at the time these samples were collected.

Idaho Washington



##   N

. F

. P a l o u s e R i v e r R o c k C r e e k

Hooper Endicott Colfax

Albion Garfield

Pullman

Moscow Palouse Potlatch

S

. F

. P a l o u s e R i v e r P a r a d i s e C r e e k R

e b e l F

l a t C

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e r

U

n i o n F

l a t C r e e

k 

##    

0 5 10 15 Miles S n a k e R

i v e r

Figure 3. Location of Water Sample s 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

204007 204008 204005

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 analyzedPalouse 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 ba sed on fish tissue data th at 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 surv ey is described in Johnson et al . (2005). Skin-on fillets were analyzed from five fish species collected by el ectrofishing 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 individual s per species. A total of 204 fish were analyzed for the study. Sampli ng sites are shown in Figure 4. Only two sites could be sampled on the lower mainstem because access to the river was limited.

Idaho Washington

R o c k C r e e k

Hooper Endicott Colfax

Albion Garfield

Pullman

Moscow Palouse Potlatch

S

. F

. P a l o u s e R i v e r P a r a d i s e C r e e k R e b e l F

l a t C

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U n i o n F

l a t C r e e

k N

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0 10 20

Miles S n a k e R

i v e r                    

Figure 4. Location of Fish Samples Co llected 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 th is region’s sport fishery, such as rainbow trout, brown trout, and catfish, were not found at any loca tion in the river. In most areas only pike minnow, suckers, and chiselmouth were encountere d. Biological data on the specime ns analyzed can be found in Appendix A.

The fish samples were analyzed for 24 chlorina ted pesticides/breakdown products and eight PCB mixtures. The concentrations of 303(d) listed ch emicals detected in the samples are summarized in Table 10. Pesticides other th an those listed in Table 10 either met human health criteria or were not detected. The complete chem ical data are in Appendix B.

Table 10. Mean Concentrations of 303(d) Listed Pesticides a nd PCBs in Palouse River Fish Fillets Analyzed by Ecology in 2005 Compared to Human Health Criteria (ug/kg, wet weight; parts per billion) (Highlighted va lues 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 c oncentration 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 th e other 303(d) listed pesticides.

These results are consistent w ith the reconnaissance sampling of river water Ecology conducted the previous year. The North Fork fish ti ssue 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 lowe r Palouse River fish in 2005 were one-to-two orders of magnitude lower than those f ound by Ecology in 1984 and 1994 and on which the 303(d) listings are based (Table 5) . Relative to human health crit eria, the highest concentrations in 2005 were for dieldrin and PCBs in Sout h 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 fi sh from the Palouse River rank among the lower 10% or lower 20% (South Fork) of fish samples st atewide. Because of variable and often high detection limits in the statewide data, a simila r comparison cannot be made for dieldrin.

Historically, lindane has exceeded human health cr iteria 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 tissu e 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 a ppear to be a human health concern for fish consumption in th e 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 Comp ared to Freshwater Edible Fish Tissue Samples Collected Stat ewide (modified from Seiders and Kinney, 2004) Lower Mainstem Palouse Rive r N orth Fork Palouse Rive r U pp er Mainstem Palouse Rive r South For k Palouse Rive rPalouse 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 Discha rge Elimination System (NPDES). Phase II communities are identified under the rule as jurisd ictions 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 th e only Washington town in the Palouse River basin with a population over 10,000 a nd is thus likely to be regul ated 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 stormw ater discharges from permitted entities must be addressed under wasteload allocations established for TM DLs. In 2005, Ecology received a grant from EPA to conduct a pilot project to estimate the municipal stormw ater 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 Pullma n. The technical studies being conducted for these other TMDL parameters are described in Ma thieu and Carroll (2006) and Bilhimer et al. (2006).

The design of the Pullman stormwat er 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 approxima tely 10% for November through March and less than 10% for April through September.

Figure 6. One-Day Precipitation Probab ilities 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, Pa radise Creek, Missouri Flat Creek, and Dry Creek. Airpor t Creek empties into Paradise Creek at the Pullman city limits. The other three creeks are tributaries that conv erge with the South Fork Palouse River in Pullman.

Three storm drains were select ed for sampling (Figure 7). The Stadium Way drain serves the largest stormshed in Pullman, and land use is charac teristic of the city as a whole, including light commercial, residential, and por tions of Washington State Univer sity (WSU). The second site, College Street, drains the southwes tern side of WSU. Benewah Str eet drains the southern end of the WSU campus, including high density reside ntial, and several co mmercial areas along Highway 270 and Latah Street.

Figure 7. Pullman Area Showing Sampling Site s 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 sa mple 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 eith er met human health water quality criteria or were not detected.

Table 11. Concentrations of 303(d) Listed Pestic ides 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

1/30/2006 0.10 J 0.16 J 2.0 J 0.50 J 1.5 Stadium Way 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

1/30/2006 0.21 J 0.33 J 1.7 J 0.53 J 18 College Street 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

1/30/2006 0.17 J 0.23 J 3.3 J 5.0 J 18 Benewah Street 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 asso ciated 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 c oncentrations, 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 re corded 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 reporte d 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 Wa shington 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 c onsulted 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 Ev aluated for the Palouse River Chlorinated Pesticides and PCB TMDL (prepared by Lisa Brown HWTR and El aine 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 ch emicals 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 mish andlings of chemicals.Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 44 

## Abandoned Landfills/Dumps

Old municipal landfills and dump s located on or near the Palous e 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 m unicipal 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 ol d dump site about tw o miles downstream of Colfax on the mainstem. An oxbow was fortif ied at the upstream end with automobile bodies. The channel was then used as a dis posal site until the early 1970s when it was covered. Refuse was visible for miles downstr eam 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 Depa rtment collected water sample s at this site in May 1997. Two samples were analyzed: one from an erode d channel that cut thr ough 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 la ndfill 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 gr oundwater sample results. ” Low concentrations (<1.0 ug/L) of chlorinated pestic ides were detected in only 1 of the 16 wells sampled. The detections included DDT compounds and heptachlo r epoxide, but not diel drin 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 Page 45 

# 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. Loadi ng capacity can be calculated by multiplying streamflow by the pollutant wa ter quality criterio n. EPA recommends using the long-term harmonic mean flow for carcinogens, since the a dverse impacts are realiz ed over a lifetime of exposure (EPA, 1991). Harmonic mean is the ap propriate 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 Q h = n/ ∑ (1/Q i ) where n is the number of recorded flows Q i
. As previously described, flows in the South Fork Palouse River can be comprised primarily of WWTP effluent any month of the year. For effl uent dominated streams such as the South Fork, EPA (1991) recommends using the arithmetic mean flow.

The loading capacity of the mainstem and South Fo rk was calculated for 303(d) listed chemicals (Table 15). The harmonic mean for the ma instem Palouse River was derived from USGS historical streamflow data for Hooper. The arit hmetic mean for the South Fork is based on the combined flow of the South Fork Palouse Rive r 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 th is analysis.) Pelletie r (1993) observed a trend toward increasing flows in the South Fork dur ing the period 1960-80, which was attributed to increasing flows out of the Moscow WWTP. The m ean flow was therefore calculated using data from 1980–2003 (most recent verified data curre ntly available). Lo ading capacities are substantially less than one gram per day for most chemicals.

Table 15. Loading Capacity of the Palouse Ri ver 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 @ PullmanPalouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 46 Loading capacity can also be expressed in terms of the contaminant concentration in the water. The 2005 fish tissue data were used to back-calcu late ambient water colu mn 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 h ealth water quality criteri a apply to the average exposure (dose) over a lifetime of fish consumption.

Table 16. Loading Capacity Status of the Palous e 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 / bioconcentratio n factor x 0.001 (unit conversion factor) † estimated ambient water concentration / human health water quality criteria

Based on Table 16, the following conclusions app ear 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 loadi ng 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 Page 47 • The North Fork Palouse River is below loadi ng 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 Catego ry 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 developm ent 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 am ount 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 0.026Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 48 The data that were available to determine if WWTP discharges were causing or contributing to exceedances of human health wate r 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 Ea stern 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 dieldr in are from nonpoint sources, the widespread presence of PCB a nd dieldrin in the environment in creases the likelihood they are present in the WWTP effluents. Therefore wast eload 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 we re set to meet the human health criteria at the end of pipe for each facility’s design flow. These are interim WLAs th at will be revised as more knowledge is gained about the levels being discharged.

Table 18. PCB and Dieldrin In terim Wasteload Allocations fo r 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 Pa louse are infrequent and of short duration. EPA recognizes that establishing numeric limits for munici pal stormwater discharges is rarely feasible because of the variability of storm events (EPA , 2002). EPA therefore re commends 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 implemen tation plan (Part 2 of this report).

For nonpoint sources, the load allo cations for dieldrin and PCBs were set equal to the loading capacities (Table 15) minus the sum of the wasteloa d allocations and margin of safety. Because dieldrin and PCBs are man-made chemicals, th ere 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 Page 49 

## Margin of Safety

A margin of safety is required in a TMDL to account for uncertainty in understanding the relationship between pollutant discharges and wa ter quality impacts. In recognition of the uncertainties associated with stormwater and WWTP loading of PCBs a nd dieldrin, including those from the Moscow area, this TMDL includ es 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 in sects, 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 concentrat ions decreased according to the following land use categories: agricultural > urban/i ndustrial > wastewater treatment plants. EPA banned the use of dieldrin on food products in 1974. All uses we re 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) flui ds in capacitors and tran sformers. Prior to 1974 other uses of PCBs included: plasticizers in pl astic and rubber products; lu bricants in hydraulic and vacuum fluids; ink carriers and solvents in making carbonle ss paper; and as a sealer for gaskets and furnaces. The EPA (1992) study f ound 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 distributi on 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, environm ental concentrations of dieldrin and PCBs have decreased over time. The effects of the ba n 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 tren d toward decreasing concentrations of PCBs, dieldrin, and other 303(d) listed ch emicals in the lower Palouse Rive r 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 Page 50 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 4.4Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 51 Figure 8. Time Trends in Levels of 303(d) List ed 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 Page 52 The goal of a TMDL is to develop a plan to ac hieve 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 wher e there is no significant human h ealth 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.. Estimat es 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 Sta ndards 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 atte nuation, monitoring, and BMPs be relied on to bring the Palouse River into compliance with water quality standard s for dieldrin and PCBs. A monitored natural attenuation approach is warra nted 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 ove r the past 10–20 years and will continue to decrease without further action being taken.

• A monitored natural attenuation approach is c onsistent with EPA-approved TMDLs in other states with similar 303(d) listings (e.g., www.epa.gov/owow/tmdl/example s/pesticides/pa_cheat.html ).Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 53 The Washington State Department of Health (W DOH) 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 (Dav e 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, t hus the need for monitoring. The mainstem is close to meeting the TMDL targets for dieldrin and PCBs at the pr esent time. By inspecti on, the rates of decrease in lower mainstem fish (Figure 8) imply a hal f-life of approximately 10 years for both dieldrin and PCBs (1995 and 2005 data). If these rates appl y to the South Fork – which appears to be the major source of contamination – compliance woul d be achieved in the S outh 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 c onclusions are based on lim ited historical data.



## Seasonal Variation

Seasonal increases and decreases in concentration are less importa nt than the long-term exposure to a carcinogen. Fish integrate water column c oncentrations over time. Therefore, using fish tissue data to assess loading capacity and set numeric TMDL targets adequately considers seasonal variations of water column concentratio ns for 303(d) listed pesticides and PCBs in the Palouse River.



## Recommendations

1. The 303(d) Category 5 listings (Polluted Wa ters that Require a TMDL) for 4,4’-DDE, heptachlor epoxide, and alpha-BHC in the Pal ouse River should be moved to Category 1 (Meets Tested Standards for Clean Waters).
2. Ecology should periodically monitor fish tissu e 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 infl uent and effluent of South Fo rk 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 diel drin 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 abandone d landfills and old dumps vulnerable to high water events or surface runoff during storms, dete rmine if they are sour ces of dieldrin or PCBs to the Palouse River, and remediate as needed.
6. It is anticipated that most s ources of dieldrin and PCB are from nonpoint sources. However, if levels do not continue to decline in Palous e 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 shoul d use detection limits low enough to compare to human health water quality criteria.Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 54 This page is purposely left blankPalouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 55 

# Part 2Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 56 This page is purposely left blankPalouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 57 

# Implementation Plan

Introduction

This implementation plan is intended to describe the framew ork 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 organi zations with jurisdicti on, 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 i mplementation 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 interest ed and responsible parties develop a Water Quality implementation plan . However, this implementation plan will serve as both the implementation strategy and the i mplementation plan

. This implementation plan describes how water qua lity 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 epoxi de, 4,4’-DDE, dieldrin, a nd alpha-BHC) and PCBs were listed on the 2004 303(d) list as an impairment to the Pal ouse 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 change d if a more recent assessment qualifies a waterbody segment for placem ent 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 determ ination may also occur if information from a TMDL or verification study confirms t hat 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 samp les or a single composite sample made up of at least five separate fish of th e same species. Fin fish fillet tissue samples may be analyzed with skin on or skin off. All fish samples mu st be from resident fis h to be considered for Categories 1 or 5.Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 58 Due to local migration of species, toxic pollu tant tissue studies that collect samples near Category 5 waterbody segments may be sufficie nt 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 segm ent 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 (dield rin and PCBs) currently violate water quality standards in the South Fork Palouse River and the mainstem Pa louse 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 cond ucted to track the progress in meeting water quality standards.

This TMDL implementation plan also addresse s the additional river segments found to be impaired during the fish ti ssue 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 techni cal analysis for this TMDL suggests that these chemicals are ente ring the Palouse River from nonpoint sour ces. 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 st reams through stormwater runoff.

The technical analysis for this TMDL demonstrat es 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 d ecrease 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 Pal ouse River watershed. In addition, high levels of these chemicals were also found in stormwat er samples from the city of Pullman andPalouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 59 Washington State University stor m 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 partic les, applying BMPs that address sediment will likely reduce current levels.

In addition, any construction activ ity required to obtain a constr uction 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 impa ired by PCBs and dieldrin. If future data collection indicates the facilities are out of co mpliance with the wasteload allocations, future permits will outline a compliance schedule to assist th e treatment plants in meeting these targets.


### Agriculture

The agricultural community’s efforts to reduce eros ion 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. Cons ervation 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 c ontinue their downward trend, Ecology will monitor fish in the Palouse River and the South Fork Palouse River and compar e 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 adapti ve management to this TMDL (see Adaptive Management section later in this report). Ec ology 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 collaborative ly to assure levels of dieldrin and PCBs in the South Fork Palouse River and Palouse River fi sh continue to decline and meet water quality standards. Entities that regul ate or discharge stormwater, re gulate 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 – En vironmental Assessment Program

Ecology’s Environmental Assessment program will sa mple Palouse River fish every five years or as resources allow. At a minimum fish w ill 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 rate s. 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 discha rges through the Construction, Municipal and Industrial Stormwater Permits.

A Construction Stormwater Permit is required for all soil disturbing activities (including clearing, grading, and/or excavati on) where one or more acre will be disturbed, and stormwater will be directly discharged to a receiving wate r (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 sm aller than one acre if th e 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 wa ters of the state. If all stor mwater is retained on-site and cannot enter surface waters of the state under an y 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 sewe r district, flood control di strict, port, public univer sity or college, prison complex, drainage district, or parks and recreati on 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 Ci ty 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 i ndustrial 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 f acility treats and retains all the stormwater on site.

Ecology’s Water Quality Program will also monito r the progress of this implementation plan, review monitoring data, and apply adaptive mana gement 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 ensu re point sources are not contributing to the elevated levels of PCBs and dieldrin in the Sout h 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 Page 61 Ecology will also pursue resource s to obtain water quality data fo r the treatment plants’ influents and effluents. This data will be used to revi se the interim WLAs if necessary. If PCB and dieldrin levels are elevated in the influent, it w ill indicate a need to locate potential sources to the sewer system.

If levels of PCBs and dieldrin do not decline as anticipated a nd no sources are located within Washington, Ecology will seek opportunities to measure loadi ng coming from Moscow, Idaho.


### Whitman County Regional H ealth 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 unde r the Eastern Washington Phase II Municipal Stormwater General Permit. The Phase II Municipa l 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 Ma nagement 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 establis h the primary activitie s needed to control pollution from urban stormwater. This TMDL assumes that compliance with the Phase II stormwater permit is the only requirement the ci ty 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 St ormwater 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 Pestic ides, PCBs, and Fecal Coliform Bacteria (Lubliner, 2006) indicated stormwater was a sign ificant source of PCBs and dieldrin, BMPs andPalouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 62 maintenance and operation practices must be co nducted to ensure sediment, which may carry PCBs and dieldrin, does not enter local streams.

Since dieldrin and PCBs attach to sediment par ticles, 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 addr ess stormwater, especially suspended sediment is outlined below.

Immediate and Ongoing

1. Control of suspended sediment in stormwater:

a. Per City of Pullman Design Standard s (2001 Edition) require Erosion and Sediment Control plans for land altering ac tivities. The degree of sediment and erosion control is somewhat de pendent on the project scope.
b. During the Site Plan and Subdivision Re view process advise developers and contractors on the need to comply w ith 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 buildi ng 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 maintena nce (jetting and cleani ng) to eventually complete cleaning of entire sub-basins ove r 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 be st 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 stormw ater treatment device (V ortechnics 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 re ntal 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 regul ated 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 Ma nagement Program (SWMP) which shall include:Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 63 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 establis h the primary activitie s 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 covera ge under the Phase II Municipal Stormwater NPDES permit, WSU can comply with this TMDL by implementing the recommendations in the Eastern Washington Stormwater Manual, pa ying particular attention to developing and carrying out the ei ght core elements outlined in Chapter 2 of the manual. Since the Pullman Stormwater Pilot Study for Pestic ides, PCBs, and Fecal Coliform Bacteria (Lubliner, 2006) indicated stormwater was a sign ificant source of PCBs and dieldrin, BMPs and maintenance and operation practices must be co nducted 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 de tection program (which include s 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 a ll storm sewer lines as budgeting allows.

6. Sweeping streets and parking lots wi th new waterless street sweeper.

7. Applying washed gravel without fi nes to roads for winter traction.



### Cities of Pullman, Colfax, and Albion’s WWTPs

NPDES permits for the cities of Pullman, Colf ax, and Albion’s WWTPs will include WLAs for PCBs and dieldrin. Because the current level of PCBs and dieldr in in their wastewater is not known, these municipalities should work closely w ith 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 Page 64 revisions to the interim WLAs and a schedul e 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 concen trations 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 Washi ngton State University to ensu re a source is not located on
campus.


### Palouse River Watershed Conservati on Districts (Palouse, Whitman, Palouse-Rock Lake, Adams, Pine Creek and Spokane)

The Spokane County Conservation Di strict currently has a State Re volving Fund l oan 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 convert ing 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 (M OU) with Palouse, Whitman, Palouse-Rock Lake, Pine Creek, and Adams cons ervation districts to offer this loan program to landowners throughout the entire Pal ouse River Watershed.

In addition, all of these conserva tion districts provide funding and technical assistance to help landowners implement BMPs to reduce or stop eros ion. These practices of ten include riparian restoration, grassed waterways, fencing, and other BMPs approved by the Natural Resources Conservation Service.

These conservation districts will continue to promote and implem ent best management practices through their current programs and will seek othe r funding opportunities for future efforts. Each conservation district will report an estimate of acr es transitioned to conservation tillage or direct seed technology and number of BMP projects that will substantia lly reduce erosion to the TMDL coordinator annually.Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 65 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 fo r 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-goingPalouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 66 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 Annually Agricultural 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 2008 Meet WLAs at end 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 necessaryPalouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 67 

## What is the Schedule for Achieving Water Quality Standards?

Fish tissue concentrations of di eldrin and PCBs have decreased by 2 to 3 orders of magnitude over the past 10 to 20 years and wi ll continue to decrease wit hout 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 th e timeframe when the Palouse River will reach water quality standards for dieldrin and PCBs.

Although it is not possible to pred ict 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 Sout h Fork (which appears to be the major source of contamination) complia nce 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 pa rticular pollutant ar e allocated among the pollutant sources (both point and nonpoint s ources) 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 su rface 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 Wash ington 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 c overed under this permit.

WLAs incorporated into NPDES permits for Pu llman, Colfax and Albion will assure that the treatment facilities are not elev ating the levels of PCBs and di eldrin 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 stat e 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 Page 68 

## 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 ol d dumps vulnerable to high water events or surface runoff during storms.

The success of this implementation plan w ill be measured by tracking the progress of implementation actions and reassessing pollutant le vels in Palouse River and South Fork Palouse River fish tissue.


### Performance measures and targets

Ecology’s TMDL coordinator will work with the or ganizations 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 progres s 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 Progr am will periodically monitor fish tissue for dieldrin and PCBs in the mainstem Palouse Rive r below Colfax and in the South Fork Palouse River. Sampling sites and timing will be simila r to those of the 2005 survey. To the extent possible, the species and size range s analyzed will be appropriate for comparing to the 2005 data. Fish tissue samples from the 2005 collection have b een 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 effectivene ss monitoring for TMDLs. This timeline also fits within the estimated time frame when the mainstem is project ed to achieve compliance with standards. All fish tissue data will be provided to the Washington State Departme nt of Health and shared with stakeholders.Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 69 

## Adaptive Management

TMDL reductions should be achieved by 2012 for di eldrin 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 th ese 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 th at Washington State Univ ersity 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 a ssure that cleanup is be ing actively pursued and water standards are achieved. If the effectiveness monitoring indicat es that progress is not being made at the rate predicted, the TMDL Coordina tor and the partner organizations will evaluate other methods and activities that could help th e water meet water quality standards. Such activities may include sampling Para dise Creek at the Idaho border to determine if loading may be coming from the Moscow area. Chemical anal ysis 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 Page 70 

## Potential Funding Sources

Ecology’s Centennial Clean Water Fund, Sec tion 319, and State Revolving Fund loans can provide financial assistance to help implementa tion of the TMDL (water quality improvement plan). In addition to Ec ology’s funding programs, there are many other funding sources available for watershed planning and impl ementation, point and nonpoint source pollution management, fish and wildlife habitat enhancement, stream restoration, an d education. Public sources of funding include federal and state gover nment programs, which can offer financial as well as technical assistance. Private sources of funding includ e 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 sour ces 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 implementedPalouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 71 

### 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 pollu tion control projects. The applic ation process is the same for CCWF, 319 Nonpoint Source Fund, and the stat e Water Pollution Control Revolving Fund.


### Section 319 Nonpoint Source Fund

The 319 Fund provides grants to local governme nts, tribes, state agencies, and nonprofit organizations to address nonpoint source polluti on to improve and protect water quality. Nonpoint source pollution includes many diffuse s ources of pollution, such as stormwater runoff from urban and residential development, agricultu ral 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. E nvironmental Protection Agency and monies appropriated from the state’s Water Quality Acco unt to provide low-interest loans to local governments, tribes, and other public entities. The loans are primarily for upgrading or expanding water pollution control f acilities, 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 Coasta l 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 an d enhancement. Local governments, tribes, and state agencies must propose projec ts through Ecology staff. Stakehol ders with projects that will reduce erosion are encouraged to contact their local TMDL coordinator to determine if their project proposal is a goo d candidate for Coastal Z one Protection funding.


### Conservation Reserve Program (CRP)

The Conservation Reserve Program (CRP) is a vol untary program for agricu ltural landowners. Through CRP, landowners can rece ive annual rental payments a nd 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 ca n enroll in CCRP at anytime. There are designated sign up periods for CRP.Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 72 The Commodity Credit Corporat ion (CCC) makes annual rent al 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 cons ervation practices. Participants enroll in CRP contracts for 10 to 15 years.

The program is administered by the CCC through th e Farm Service Agency (FSA), and program support is provided by Natural Resources Conserva tion Service, Cooperative State Research and Education Extension Service, state forestry agencies, and local Soil and Water Conservation Districts. (Farm Service Agency, 2006)


### Environmental Quality Inc entives Program (EQIP)

The federally funded Environmental Quality Ince ntives Program (EQIP) is administered by NRCS. EQIP is the combination of several conservation programs that address soil, water, and related natural resource concerns. EQIP encour ages environmental enhancements on land in an environmentally beneficial and cost-effective manner. The EQIP program:

• Provides technical assistance, cost share, and in centive payments to assist crop and livestock producers with environmental and cons ervation improvements on the farm.

• Has 75% cost sharing but allows 90% if producer has limited res ources or beginning farmer.

• Divides program funding 60% for livestock- related practices, 40% for cropland.

• Has contracts lasting fi ve 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 habita t. WHIP agreements between NRCS and the participant generally last from five to ten ye ars from the date the agreement is signed.


### Conservation Security Program

The Conservation Security Program (CSP) is a voluntary progra m 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 pr ivate working lands. Working lands include cropland, grassland, prai rie 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, re gardless of size of operation, crops produced, or geographic location. CSP is admi nistered by NRCS (NRCS, 2006).Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 73 Each year different watersheds are selected fo r 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 en rollment (R. Riehle, NRCS 2006, personal communication. March 17).


## Summary of Public Involvement Methods

In April 2005, a press release was issued to anno unce the start of this TMDL effort. Several newspapers published articles abou t 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 interest ed in water quality in the Palouse River watershed. Several updates abou t this project have been sent to this mailing list.

Information about this project has be en available on Ecology’s website at: www.ecy.wa.gov/programs/wq/tmdl/palouse/index.html

. A Quality Assurance Project Plan (QAPP) for th e fish tissue study was developed. Members of the Palouse Watershed Planning Unit were invi ted to review and comment on the QAPP.

A press release was issued on May 21, 2007 invi ting 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 pe riod ran from May 24, 2007 to June 22, 2007. Comments received are res ponded to in Appendix D.Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 74 This page is purposely left blankPalouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 75 

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. Vol. 1, Fish Sampling and Analysis. U.S. Envi ronmental Protection Agency, Office of Water. EPA-823-B-00-007.Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 76 EPA, 2001. Overview of Current Total Maximum Daily Load - TMDL - Program and Regulations . U.S. Environmental Protection Agency. www.epa.gov/owow/tmdl/overviewfs.html

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# AppendicesPalouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 80 This page is purposely left blankPalouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 81 

## Appendix A. Biological Information on Fish Samples

Table A-1. Biological Information on Ec ology'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 2Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 82 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 4Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 83 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 8.5Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 84 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 6.2Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 85 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 2Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 86 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 2Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 87 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 RiverPalouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 88 This page is purposely left blankPalouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 89 

## 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 Page 90 Table B-1 (cont.). Contaminant Data for Palous e 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 N orthern 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 Palous e 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 Palous e 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 Palous e 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 Palous e 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 N orthern 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 Palous e 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 Palous e 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 N orthern 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. Th e 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 PlanPage 97Appendix C. Tracking TablesTimelineDepartment ofEcology –Water QualityProgram200720082009201020112012201320142015FutureIssue municipalstormwaterpermit to city ofPullman andWSUProvidestormwatertechnicalassistanceMonitor permitimplementationby reviewingannual reportsTrack progressof activitiesoutlined in plan

Performance MeasuresInvestigatefurthermonitoring tolocate sources ofdieldrin andPCBs (ifadaptivemanagement isneeded)IncorporateWLAs intoNPDES PermitsPalouse River Toxics TMDL: Water Quality Improvement Report and Implementation PlanPage 98TimelineDepartment ofEcology –EnvironmentalAssessment Program2007 - 20122013 - 20172018 - 2022FutureSample PalouseRiver and SouthFork Palouse RiverFish to determinetissueconcentrations

Performance MeasuresAssess levels ofPCBs and dieldrinin influent andeffluent of WWTPsPalouse River Toxics TMDL: Water Quality Improvement Report and Implementation PlanPage 99TimelineCity of Pullman200720082009201020112012201320142015FutureImplementrequirements ofPhase IImunicipalstormwaterpermitRequire Erosionand SedimentControl plans forland alteringactivities andbuilding permitsContinue to trainengineering andbuilding divisionpersonnel asCertifiedErosion andSedimentControl Leads(CESCL)Increase annualstorm drain pipemaintenance

Performance MeasuresRevise City’sDesignStandards toreference theStormwaterManagementManual forEasternWashingtonPalouse River Toxics TMDL: Water Quality Improvement Report and Implementation PlanPage 100TimelineCity of Pullman200720082009201020112012201320142015FutureComplete stormdrain computermapping projectMeet conditionsof NPDESwastewaterpermitTimelineCities of Colfaxand Albion200720082009201020112012201320142015Future

Performance MeasuresMeetconditions ofNPDESwastewaterpermitPalouse River Toxics TMDL: Water Quality Improvement Report and Implementation PlanPage 101TimelineWashington StateUniversity200720082009201020112012201320142015FutureImplementrequirements ofPhase IImunicipalstormwaterpermitProactivelyremoving allPCB sources oncampus to alevel belowFederal andWashingtonState regulationsIllicit dischargedetectionprogramComputerizedmapping systemof existingstormwaterlines, catchbasin locationsand drainageareas

Performance MeasuresOverseeingconstructionproject one acreor greater thanrequireConstructionStormwaterNPDES permitsPalouse River Toxics TMDL: Water Quality Improvement Report and Implementation PlanPage 102TimelineWashington StateUniversity200720082009201020112012201320142015FutureIncrease videoinspection andrepair all stormsewer linesStreet andparking lotmaintenanceTimelineWhitman CountyRegional HealthDepartment200720082009201020112012201320142015Future

Performance MeasuresInvestigate anabandonedlandfill andincineratoralong the SouthFork PalouseRiver todetermine ifthey aresourcesPalouse River Toxics TMDL: Water Quality Improvement Report and Implementation PlanPage 103TimelinePalouse WatershedConservationDistricts200720082009201020112012201320142015FutureReport numberof acresconverted toconservationtillage or BMPprojects thatsignificantlyreduce erosion

Performance MeasuresSeek additionalfundingopportunities tosupport thisactionPalouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 104 This page is purposely left blankPalouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 105 

## 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 Sa fe Drinking Water standards whic h 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 si te 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 durin g 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 Pa louse Conservation to the Plan ning 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 ch lorinated pesticides in fish tissu e. 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 Le vel (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. Th erefore, 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. Th e 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 atte ntion’ instead of ‘natur al attenuation’. But that extremely minor suggestion I found while wear ing my proofreader hat aside, it looks very solid.Palouse River Toxics TMDL: Water Quality Improvement Report and Implementation Plan Page 106 Response:

Thank you for your review and comment. The typographical error has been corrected.

Comments from Kevin Gardes, Deputy Pub lic 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 Qu ality 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 th e point source wastewater trea tment plants may need to be revised upward (increasing the wasteload allo cation) 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 bei ng used. It is our understanding that there really isn’t a good method for removing these pollutants at the wast ewater treatment plant other than the amount normally removed through a typica l biological treatment plant. C oupled with that fact that these pollutants are being measured in the part s per trillion range, it seems unlikely that the city would be able to implement a cost-effectiv e removal strategy at the wastewater treatment plant should subsequent testing show concentrations in our ef fluent 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 addr essing 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 a llocations. Therefore, the interi m wasteload allocations can not be revised upward until the river can provide the necessary dilution. However, Ecology acknowledges that the most likel y sources of PCBs and dieldrin to the treatment plant are infiltration/inflow (I/I), illicit c onnections or industrial users. Therefore, if monitoring determines the treatment plant’s effluent exceeds the wast eload allocation, Ecology w ill 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 allocatio ns. 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 Page 107 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 Tabl e ES-4: Delete “attention” and insert “attenuation”.

Page 38, 2nd paragraph, last sentence: De lete “the hospital” since it has moved.

Page 44, 4th paragraph, last sentence: Replace “John Sykes” with “John Skyles”.

Page 44, 5th paragraph, first a nd 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 perm it, this TMDL assumes that compliance with the Eastern Washington Stormwat er 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: Ch ange “2011” to “on-going, report progress annually” to be consis tent with the City of Pullman section.

Page 103, WSU timeline, first row: Change “Vid eo 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 commen t. All WSU comments except the 5 th comment have been incorporated into the text of this report. The 5 th comment was addressed by adding the following text on page 63:

In the event WSU is determined to not re quire 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 Pestic ides, PCBs, and Fecal Coliform Bacteria (Lubliner, 2006) indicated stormwater was a si gnificant 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 we ll written and well organized.

After a thorough review of this documen t, 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 disc uss this project with you at your convenience.

Response:

Thank you for your review and comment.