Lake Chelan Watershed DDT and PCB 

Total Maximum Daily Load __________________________ 

Water Quality Improvement Report 

June 2006

Publication No. 06-10-022 

Lake Chelan Watershed DDT and PCB 

Total Maximum Daily Load __________________________ 

Water Quality Improvement Report 

Prepared by: 

David Schneider and Randy Coots 

Washington State Department of Ecology 

Water Quality Program 

June 2006 

Publication Number 06-10-022 
You can print or download this document from our Web site at: 

http://www.ecy.wa.gov/biblio/0610022.html

For more information contact: 

Department of Ecology 

Water Quality Program 

Central Regional Office 

15 W Yakima Avenue, Suite 200 

Yakima, WA 98902 

Telephone: (509) 454-7894 

Adams

Benton Asotin

Chelan

Clallam

Clark

Columbia

Cowlitz

Douglas

Ferry

Franklin Garfield

Grant

Grays

Harbor

Island

Jefferson

King

Kitsap

Kittitas

Klickitat

ic Lewis

Lincoln

Mason

Okanogan

Pacif

Pend

Oreille

Pierce

San Juan

Skamania

Spokane

Stevens

Thurston

Skagit

Snohomish

Wahki

Walla

Walla

Whatcom

Whitman

akum Yakima

Northwest

425-649-7000

Southwest

360-407-6300

Eastern

509-329-3400

Central

509-575-2490

Headquarters (Lacey) 360-407-6000

Regional

Office

location

Spokane

Yakima

Lacey

Bellevue

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

Persons with a speech disability can call 877-833-6341.

If you need this publication in an alternate format, please call the Water Quality Program at 509-454-7888. 

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

877-833-6341
Table of Contents 

List of Tables ................................................................................................................................. ii

List of Figures................................................................................................................................ ii

List of Appendices........................................................................................................................ ii

Acknowledgements..................................................................................................................... iii

Executive Summary ..................................................................................................................... v

Introduction................................................................................................................................... 1

Background ................................................................................................................................... 2

Applicable Water Quality Standards......................................................................................... 5

Water Quality and Resource Impairments ............................................................................... 7

Seasonal Variation........................................................................................................................ 9

Technical Analysis...................................................................................................................... 10

Loading Capacity........................................................................................................................ 15

Wasteload and Load Allocations ............................................................................................. 18

Margin of Safety.......................................................................................................................... 21

Summary Implementation Strategy......................................................................................... 23

Reasonable Assurance ............................................................................................................... 33

Adaptive Management.............................................................................................................. 33

Summary of Public Involvement.............................................................................................. 35

Monitoring Strategy ................................................................................................................... 36

Potential Funding Sources ........................................................................................................ 36

References Cited ......................................................................................................................... 38

Lake Chelan Watershed DDT and PCB TMDL Page i
 List of Tables 

Table 1: Selected Freshwater Sediment Quality Guidance Values for Total DDT 

and Total PCBs (μg/Kg. dw) ..............................................................................................viii 

Table 2: Current Total DDT Loads and Reductions Needed in Tributaries and 

Irrigation Drains.................................................................................................................... xi 

Table 3: Land Use within the Lake Chelan Watershed ....................................................................4 

Table 4: Chemical - Criteria for Protection of Aquatic Life – Criteria for 

Protection of Human Health .................................................................................................6 

Table 5: Selected Freshwater Sediment Quality Guidance Values for Total DDT and 

Total PCBs (μg/Kg. dw)..........................................................................................................7 

Table 6: 1998 303(d) Listings for Lake Chelan and Roses Lake.......................................................7 

Table 7: 2004 303(d) Listings for Lake Chelan ...................................................................................7 

Table 8: Lake Chelan Tributary Total DDT Loading Capacities...................................................16 

Table 9: Roses Lake Tributary DDT Loading Capacities ...............................................................16 

Table 10: Lake Chelan Tributary Total DDT Load Allocations.......................................................20 

Table 11: Roses Lake Tributary DDT Load Allocation.....................................................................20 

Table 12: TMDL Implementation Actions and Potential Contributors..........................................30 

Table 13: Total DDT and Total PCB Percent Reduction Targets in Fish Tissue for 

Lake Chelan and Roses Lake...............................................................................................32 

List of Figures 

Figure 1: Study area map for the Lake Chelan basin DDT and PCB TMDL ................................. vi 

Figure 2: Exceedences of Human Health water quality criteria and Aquatic Life criteria 

in Lake Chelan Drainage ...................................................................................................... vii 

Figure 3: Total DDT levels in surface sediments of Lake Chelan June 2003.................................viii 

Figure 4: Wapato Basin Sampling Stations.......................................................................................... ix 

List of Appendices 

Appendix A - Lake Chelan DDT and PCBs in Fish ............................................................. A-1 

Appendix B - Education and Outreach ..................................................................................B-1 

Appendix C - Public Comments and Responses ................................................................. C-1 

Appendix D - Previous Studies .............................................................................................. D-1 

Page ii Lake Chelan Watershed DDT and PCB TMDL
Acknowledgements 

Many thanks to the participants on the Lake Chelan Water Quality Committee, 

for their technical support, wise suggestions, dedication to this project, and 

patience with our efforts. Members of the committee include: Mike Kaputa, 

Buell Hawkins, Bob Sheehan, Ann Congdon, Paul Cross, Jennifer Burns, Dwayne 

Van Epps, Steve Ellis, Mark Marquis, Sandra Olivencia, Tom Robison, Dan 

Hodge, Dan Valoff, Don Phelps, Donna Walsh, Gary Mitchell, Gordon Congdon 

Jr., Greg Story, Gretchen Coker, Jay Kehne, Jennifer Burns, Jim Talley, Jonina 

Vanderbilt, Kelee Hampton, Linda Evans-Parlette, Mike Rickel, Paula Cox, 

Peggy Entzel, Peter Burgoon, Philip Long, Richard Ulhorn, Russ Jones, Scott 

Reynolds, Shiloh, Burgess, and Tim Olson. 

Also, thanks to the Department of Ecology staff who helped direct and support 

this project, including Tom Tebb, Jeff Lewis, Derek Sandison, Jon Merz, Greg 

Bohn, Ryan Anderson, Mark Peterschmidt, Jane Creech, Wendy Valdez, Colleen 

Rauert, Dale Norton, and Will Kendra. 

Lake Chelan Watershed DDT and PCB TMDL Page iii
Page iv Lake Chelan Watershed DDT and PCB TMDL
Executive Summary 

Introduction 

Lake Chelan and Roses Lake, a small lake located adjacent to Lake Chelan, are 

included on Washington States 303(d) list as water quality impaired because of 

non-attainment of the U.S. Environmental Protection Agency (EPA) human 

health criteria for 4,4’ DDT, DDT metabolites 4,4’-DDE and 4,4’ DDD, PCB 1254 

and 1260, in edible fish tissue. Roses Lake is listed for 4,4’-DDE only. 

As required by the Clean Water Act a total maximum daily load assessment 

(TMDL) was conducted for Lake Chelan and Roses Lake to determine loading 

reductions needed to bring the lakes into compliance with water quality 

standards. In this effort the Washington State Department of Ecology collected 

fish tissue, water, and sediment samples during May through November of 2003 

from Lake Chelan, Roses Lake, and their inflows. During the TMDL study, some 

tributaries and irrigation drains to Lake Chelan were discovered to exceed water 

quality standards for DDT, including First Creek, Knapp Coulee, Culvert near 

Crystal View, Purtteman Creek, Culvert at Veroske’s, Cooper Drainage, Bennet 

Road, Keupkin Street, Buck Orchards, Joe Creek, and Stink Creek. Total DDT 

Loads and reductions needed in tributaries and irrigation drains are identified in 

Table 2. Actions identified in the Summary Implementation Strategy section will 

address tributary and irrigation drain exceedences. 

The purpose of this submittal report to EPA is to: 1) provide an assessment of 

DDT, PCB, and pollution to the Lake Chelan watershed, including sources, loads 

and reductions needed to meet Federal and Washington State water quality 

standards; and 2) identify actions and monitoring to be implemented which will 

result in attainment of standards over time. 

This report is organized to describe: the Loading Capacity that Lake Chelan can 

assimilate and still meet water quality standards; the Load Allocations or 

reductions needed from pollutant inputs; the Margin of Safety or conservative 

assumptions based on consideration of any lack of knowledge about causes of 

the water quality problem or its loading capacity; the Summary Implementation 

Strategy or actions and monitoring to be implemented that will reduce pollutant 

inputs; Reasonable Assurance that actions will achieve water quality standards by 

the target dates set and Adaptive Management that will be utilized to attain water 

quality standards. 

Lake Chelan Basin 

Lake Chelan is located in north-central Washington State (Figure 1). It is the 

longest and deepest natural lake in the state. The Lake Chelan watershed drains 

a 924-square-mile area. Ninety percent of the basin is forested or open lands, the 

Lake Chelan Watershed DDT and PCB TMDL Page v
majority managed by U.S. Forest Service and National Park Service. The lake 

itself is divided into two distinct basins, the Lucerne and Wapato basins. 

Agriculture and orchard lands comprise 3 percent of the watershed’s land area, 

almost all located in the more urbanized Wapato basin. Roses Lake, located 

about a mile north of the town of Manson, is one of a cluster of three small lakes 

which drain to Lake Chelan. 

Wapato

Basin

Lucerne

Basin

Figure 1: Study area map for the Lake Chelan basin DDT and PCB TMDL

Results of Field Study 

WATER

Five water surveys from Lake Chelan tributaries and irrigation drains 

were conducted between May and November 2003. Total DDT in the 

Wapato basin discharges ranged from 0.13 to 36 ng/L. Human health 

and aquatic life (chronic exposure) criteria were routinely exceeded 

(Figure 2).

Page vi Lake Chelan Watershed DDT and PCB TMDL
NS16 NS18 NS19 NS21 NS22 NS23 NS24 NS30

0.1

1

10

100

t-DDT in Water (ng/L)

 SS01 SS02 NS13 NS15

Aquatic Life 1.0 ng/L

Human Health 0.59 ng/L

Figure 2: Exceedences of Human Health water quality criteria and Aquatic Life criteria 

in Lake Chelan Drainage, May – November 2003 (ng/L). Aquatic life criterion 

= 1.0 ng/L (parts per trillion). Human health criterion = 0.59 ng/L. See Figure 

4 for sampling stations map. 

• The highest DDT loads were from the Keupkin Street site (NS21) at 43 

mg/day, followed by Buck Orchards (NS22), and Purtteman Creek 

(NS15) at 6.1 and 5.8 mg/day, respectively. 

• Concentrations of DDT, DDE, DDD and PCBs, were determined in 

Lake Chelan waters using semipermeable membrane devices (SPMDs). 

SPMDs were deployed in each basin between 180 and 200 feet for a 

month in May, July and October. In Wapato basin total DDT was 

highest in spring (25 ng/L) followed by summer (18 ng/L), and fall 

(4.3 ng/L). Lake water concentrations during May and June for total 

DDT were two orders of magnitude higher in the Wapato basin than in 

the Lucerne basin. PCBs were generally not detected in SPMDs. Total 

DDT exceeded human health and aquatic life criteria (chronic) in 

Wapato basin through the sample period. 

SEDIMENT

• Surface sediments were collected from 17 sites along a longitudinal 

transect within Lake Chelan. Three additional alluvial samples were 

collected below major tributaries to the lake. Total DDT concentrations 

in Wapato basin sediments averaged 560 ug/Kg, compared to 120 

ug/Kg for Lucerne (Figure 3). Results for PCBs were low, ranging 

from 1.2 to 2.7 ug/Kg, and were mainly detected in the Wapato basin. 

Lake Chelan Watershed DDT and PCB TMDL Page vii
Total DDT in Lake Chelan Surface Sediments

L-47.00 

L-40.62

L-34.33

L

L-17.79

-20.51

L-16.00

L-13.00

W-11.08

W-10.17

W-9.31

W-8.22

W-6.86

W-5.64

W-4.41

W-3.15

W-1.89

W-0.69

0

200

400

600

800

1000

1200

Sample Site - Miles from Outlet

Total DDT ug/Kg

Figure 3: Total DDT levels in surface sediments of Lake Chelan June 2003. 

The state of Washington has not promulgated standards for freshwater 

sediments. However, a number of guidance values are available in the 

scientific literature that can be used to evaluate the sediment results for 

DDT (see Table 1). The average sediment concentration of total DDT 

in both Lucerne and Wapato basins exceed threshold effects guidance 

levels. Concentrations of total DDT in several locations within Wapato 

Basin also exceed the consensus-based probable effects concentration 

for total DDT. 

Table 1: Selected Freshwater Sediment Quality Guidance Values for Total DDT and Total PCBs (μg/Kg. dw)

Freshwater Sediment 

Quality Value 

Total 

DDT 

Total 

PCBs Effects Level 

Apparent Effects 

Threshold (AET) NA 21a

Level above which biological effects have 

always been observed. 

Floating Percentile Method 

(FPM) NA 60a

Proposed level which optimizes reliability 

and sensitivity in predicting adverse 

biological effects. 

Threshold Effects Level (TEL) 

7b 34.1b

Represents the concentration below which 

adverse effects are expected to occur only 

rarely. 

Consensus-Based Threshold 

Effect Concentration (TEC) 

5.3c 59.8c

Concentration below which harmful effects 

on sediment-dwelling organisms are not 

expected. 

Consensus-Based Probable 

Effect Concentration (PEC) 

572c 676c

Concentration above which harmful effects 

on sediment-dwelling organisms are 

expected to occur frequently. 

NA = Data not available 

a = Avocet Consulting 2002; 2003 

b = Smith et al. 1996 

c = MacDonald et al. 2000 

Page viii Lake Chelan Watershed DDT and PCB TMDL
 Figure 4: Wapato Basin Sampling Stations 

• Two shallow (0-40 cm) sediment cores were collected, one from each 

basin. Sedimentation rates were estimated using Pb210 (lead) methods. 

Sedimentation rates were low compared to other Washington lakes, at 

0.19 cm/yr for Lucerne basin, and 0.092 cm/yr for the Wapato basin 

although the results suggest possible disturbance to the sediment 

record. Concentrations of total DDT in the Wapato basin core were an 

order of magnitude higher than in the Lucerne basin core. The peak 

total DDT concentration in the Wapato basin core was 930 ug/Kg 

compared to the mean of 560 ug/Kg in transect surface sediments from 

the Wapato basin. PCBs were not detected. Because the sediment core 

results from the Wapato basin suggest disturbance to the record, 

further sediment core sampling in the Wapato basin is recommended 

to verify sedimentation rates.

FISH

• Roughly 200 game fish were collected and analyzed from Lake Chelan 

and Roses Lake. Species included burbot, mackinaw (lake trout), 

kokanee, rainbow trout, and black crappie. Concentrations of total 

DDT were measured up to 2,400 ug/Kg in Wapato basin fish. The 

Lake Chelan Watershed DDT and PCB TMDL Page ix
highest concentrations were found in mackinaw, followed by burbot, 

kokanee, and rainbow trout. Concentrations of total PCBs were much 

lower than total DDT ranging from <2 to 48 ug/Kg. 

• A subset of mackinaw and burbot tissue samples was analyzed for 

polychlorinated dibenzo-p and polychlorinated dibenzofurans. Tissue 

analysis showed Dioxin 2,3,7,8 TCDD toxic equivalent quotients 

(TEQs) from mackinaw tissue were an order of magnitude above 

criterion, while Lucerne basin burbot were only slightly above. Lake 

Chelan has been listed for Dioxins on the 2004 303(d) list and will be 

addressed at a later date. 

TMDL Target Reductions 

Water quality targets for total DDT and total PCBs in edible fish tissue from Lake 

Chelan’s Wapato basin and Roses Lake are the National Toxics Rule (NTR) 

human health criteria. NTR criteria establish that levels in edible fish tissue shall 

not exceed 32 ug/Kg for total DDT and 5.3 ug/Kg for total PCBs. 

A percent reduction of current load approach was used to meet the water quality 

targets. These percent reductions represent the amount of pollutant load that 

must be reduced to meet the water quality targets. The needed reduction of total 

DDT and total PCBs in fish tissue was based on the fish species with the highest 

mean concentration from each lake. Mackinaw from Lake Chelan’s Wapato 

basin and rainbow trout from Roses Lake were selected. Wapato basin fish will 

require a 97 percent reduction in total DDT and a 63 percent reduction in total 

PCBs to meet water quality targets. Roses Lake fish will require a 67 percent 

reduction in total DDT to meet water quality targets. 

Tributaries and irrigation drains to the lakes also require reductions in current 

loading of total DDT. Target loads for discharges to the lakes were based on the 

Washington State standard (chronic) for protection of aquatic life from DDT and 

metabolites (1.0 ng/L) and the harmonic mean flow from discharge 

measurements completed when water samples were collected. Current loads, 

allowable loads, and reductions needed to meet criteria for the tributaries, 

irrigation drains, and Roses Lake orchard drain are shown in Table 2. 

Page x Lake Chelan Watershed DDT and PCB TMDL
Table 2: Current Total DDT Loads and Reductions Needed in Tributaries and Irrigation Drains. 

Lake Chelan Tributary or 

Irrigation Drain 

Current Total 

DDT Load 

(mg/day) 

Allowable 

Total DDT 

Load 

(mg/day) 

Load 

Reduction 

Needed 

(mg/day) 

Percent 

Reduction 

Needed 

First Creek - SS01 2.2 12 0 0 

Knapp Coulee - SS02 2.4 0.39 2.0 84 

Culvert at Crystal View - NS13 0.14 0.04 0.10 71 

Purtteman Creek - NS15 5.8 2.3 3.5 60 

Culvert at Veroske's - NS16 3.00 0.21 2.8 93 

Cooper drainage - NS18 1.5 0.10 1.4 93 

Bennet Road - NS19 0.29 0.13 0.16 55 

Keupkin Street - NS21 43 1.5 42 97 

Buck Orchards - NS22 6.1 0.46 5.6 92 

Wapato Lake/Joe Creek - NS23 0.04 0.22 0 0 

Stink Creek - NS24 1.9 1.1 0.80 42 

Mill Bay boat ramp - NS30 0.02 0.05 0 0 

Totals 66.4 18.5 58.4 

Roses Lake Orchard Drain 

ST11 3.2 0.15 3.1 95 

Conclusions and Recommendations 

• Upon review of the Department of Ecology TMDL study, the Washington 

State Department of Health has continued a fish consumption advisory for 

mackinaw in Lake Chelan, which was initially issued in 2003 following a 

USEPA study. 

• Fish tissue contaminant monitoring should be conducted every five years to 

track progress toward achieving targets. Mackinaw should be selected for 

collection and analysis, as they provide a worst case scenario for total DDT 

and PCB concentrations in fish. 

• Natural attenuation is the best management strategy for total DDT in Lake 

Chelan and Roses Lake sediments. Active removal of total DDT laden 

sediments from Lake Chelan is probably not an option considering size, 

depth, and the disturbance to fish and invertebrate communities, and habitat. 

• Developed wetlands could be a treatment option available for reducing DDT 

in tributaries and irrigation drains. 

• An evaluation of total DDT concentrations in the water column in the Wapato 

basin should be conducted to better quantify spatial and temporal variations. 

PCBs were generally not detected in water column sampling. 

Lake Chelan Watershed DDT and PCB TMDL Page xi
• An evaluation of the potential contribution of total DDT loading from 

groundwater to the Wapato basin should be conducted. 

• Further investigate fish uptake mechanisms of DDT and PCBs through the 

sediment, water, plants, and aquatic biota. 

Page xii Lake Chelan Watershed DDT and PCB TMDL
Components of the TMDL 

The Washington State Department of Ecology (Ecology) is establishing a total 

maximum daily load (TMDL) for Lake Chelan, Roses (Alkali) Lake and their 

tributaries concerning the water quality pollutants of DDT and PCB. This TMDL 

will address potential impairments of beneficial uses as listed in the 1998 Section 

303(d) list of Washington State’s impaired surface waters for WRIA 47, Chelan 

Watershed. The five components of any TMDL as required by the Clean Water 

Act are defined as: 

Loading Capacity: The maximum amount of pollutant loading that a receiving 

water can absorb without violating the respective state water quality standard. 

Wasteload Allocation: That portion of a receiving water’s loading capacity that 

is allocated, or attributed, to existing or potential point sources of pollution. 

There are no known point sources of DDT and PCB within the Lake Chelan 

watershed; therefore, the wasteload allocations for these pollutants are zero. 

Load Allocation: That portion of a receiving water’s loading capacity that is 

attributed either to one of its existing or potential non-point sources of pollution 

or to natural background sources. Non-point sources of DDT and PCBs are the 

only sources of these pollutants in the Lake Chelan watershed. Potential nonpoint sources include agricultural irrigation return waters, urban and rural 

runoff, stormwater discharges and aerial deposition. 

Summary Implementation Strategy: The summary implementation strategy 

(SIS) identifies a strategy that will be developed into a detailed implementation 

plan for the watershed to address pollutants. Successful completion of the 

actions, effectiveness monitoring, and adaptive management are expected to 

result in water quality standards being met over time. 

Margin of Safety: The TMDL must consider a margin of safety (MOS) that takes 

into account any lack of knowledge about causes of the water quality problem or 

its loading capacity. The sum of the individual allocations and the MOS must be 

equal to or less than the loading capacity. The size of the MOS is inversely 

proportional to the confidence in the data utilized in the calculations of load 

allocations. The MOS should list specific inherent conservative assumptions and 

critical conditions that demonstrate implicit and/or explicit margins of safety 

and list the specific allocations. 

Seasonal Variation: The TMDL should take into account the seasonal variation 

of the parameters of concern. 

Lake Chelan Watershed DDT and PCB TMDL Page xiii
Reasonable Assurance: The TMDL should describe how implementation 

actions, monitoring, and adaptive management will reasonably achieve water 

quality standards by the target dates set. Reasonable assurance is required only 

where point sources exceed the water standards, and therefore non-point sources 

must be consistently reduced in order to compensate for any such exceedances. 

Because this is not the case in the Lake Chelan watershed, reasonable assurances 

are not required. However, with the implementation actions identified in this 

TMDL, funding, ongoing monitoring, and adaptive management, Ecology and 

the Lake Chelan Water Quality Committee can provide reasonable assurance that 

non point source goals will be achieved within the timeline proposed in Table 12. 

Adaptive Management: The TMDL should describe how Ecology and the 

participating entities will track progress over time and adaptively manage 

actions so that changes can be made where necessary to achieve water quality 

standards. 

Page xiv Lake Chelan Watershed DDT and PCB TMDL
Introduction 

Section 303(d) of the federal Clean Water Act (CWA) mandates that the state of 

Washington (state) establish Total Maximum Daily Loads (TMDLs) for surface 

waters that do not meet standards after application of technology-based 

pollution controls. The U.S. Environmental Protection Agency (EPA) has 

established regulations (40 CFR Part 130) and developed guidance (EPA, 1991) 

for setting TMDLs. 

Under the CWA, every state has its own water quality standards designed to 

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

designated uses, such as cold water biota and drinking water supply, and 

numeric standards, to achieve those uses. When a water body fails to meet water 

quality standards after application of required technology-based controls, the 

CWA requires that the state place the water body on a list of “impaired” water 

bodies and to prepare an analysis called a TMDL. 

The goal of a total maximum daily load (TMDL) study is to ensure that an 

impaired water body attains water quality standards within a reasonable period 

of time. The Summary Implementation Strategy section identifies actions that 

should be implemented and potential contributing entities to reduce dichlorodiphenyl-trichloroethane (DDT) and polychlorinated biphenyl (PCB) inputs to 

achieve water quality standards. A phased monitoring approach should be used 

to assess the effectiveness of DDT and PCB reduction efforts. It is anticipated 

that implementation actions should be completed by 2018. At the present time, 

insufficient historical data and limited understanding of the dynamics of DDT 

and PCB cycling within Lake Chelan are available to accurately determine the 

time required to meet the state’s water quality standards through natural 

attenuation and implementation of the TMDL’s actions. Adaptive management 

and planned studies that will be conducted during the Detailed Implementation 

Plan will allow development of a more accurate estimate. Currently, based on 

best professional judgment, it is anticipated that state water quality standards 

will likely be met by 2055. 

A TMDL includes a written, quantitative assessment of water quality problems 

and of the pollutant sources that cause the problem. The TMDL determines the 

amount of a given pollutant, called the loading capacity, which can be 

discharged to the water body and still meet water quality standards and, 

subsequently, allocates that load among the various sources. If the pollutant 

comes from a discrete source (referred to as a point source) such as an industrial 

facility’s discharge pipe, that facility’s share of the loading capacity is called a 

wasteload allocation (WLA). If the pollution comes from a diffuse source 

(referred to as a non-point source) such as farms, stormwater runoff, yards and 

gardens, construction sites etc., that share is called a load allocation (LA). 

Lake Chelan Watershed DDT and PCB TMDL Page 1
The TMDL must also consider seasonal variations and include a margin of safety 

(MOS) that takes into account any lack of knowledge about the causes of the 

water quality problem or its loading capacity. The sum of the individual 

allocations and the MOS must be equal to or less than the loading capacity. 

The general purposes of this submittal report are to: 

• Provide data from water quality sampling from throughout the Lake 

Chelan watershed; 

• Provide an analysis of such data including the loading capacities for the 

pollutants of concern and the load allocations and margin of safety that 

will protect water quality, aquatic life and human health; 

• Identify potential point and non-point sources of pollution; 

• Summarize actions recommended for meeting water quality standards 

and ongoing monitoring to verify whether standards are being met; and 

• Fulfill requirements of the federal CWA. 

A detailed implementation plan (DIP) must be developed within one year after 

TMDL approval by EPA and will be based on the information presented in this 

document. 

Background 

Lake Chelan and Roses Lake are located in Chelan County (WRIA 47) near the 

north central part of the state of Washington (state), approximately 32 miles 

north of the city of Wenatchee. Lake Chelan is the longest (approximately 51 

miles) and deepest (1,486 feet) natural lake in the state and is the third deepest 

freshwater lake in the nation. The lake is also very narrow (average of 1.5 miles) 

and has an average surface area of 32,980 acres. Roses Lake is a comparatively 

smaller lake (130 acres) with a mean depth of only 23 feet. A map of the 

watershed is shown in Figure 1. The Lake Chelan watershed is bordered by the 

Cascade Mountains to the west, by the Sawtooth Mountain Range to the north, 

by the Entiat and Chelan Mountains and the Glacier Peak complex to the south, 

and by the Columbia Plateau to the east. 

The climate of the area surrounding Lake Chelan and Roses Lake is 

predominantly semi-arid typical of Eastern Washington (hot, dry summers and 

mild to severe winters). However, significant variations in climate exist between 

the two ends of the lake. Average annual precipitation at the upper end of the 

lake is 35 inches, the majority of which is snowfall from November through 

March; whereas, the average annual precipitation at the lower end of the lake is 

Page 2 Lake Chelan Watershed DDT and PCB TMDL
10.8 inches. Air temperatures fluctuate widely with the seasons, with a summer 

(July) average maximum temperature of 86.4°F and a winter (January) average 

minimum temperature of 19.8F. Extreme recorded temperatures range from a 

low of minus 15°F to a high of 106°F. 

Lake Chelan was formed by glacial scouring action, which left a steep-sloped 

fjord formed into the area’s granodiorite bedrock. Lake Chelan is divided into 

two distinct basins, partially separated by a glacial sill near Hollywood Beach 

that is commonly referred to as the “narrows”. In fact, the two basins were 

created by two independent glaciers that met and then formed the sill as they 

retreated. The larger of the basins, the Lucerne Basin (northern basin), contains 

over 92 percent of the lake’s total volume (74 percent of lake area) and reaches a 

maximum depth of 1,486 feet. The smaller basin, Wapato Basin (southern basin), 

receives most of its water input from the Lucerne Basin and has a maximum 

depth of only 400 feet. 

Lake Chelan is considered pristine due to its ultra-oligotrophic conditions: 

relatively deep, nutrient poor, high clarity and little organic matter. The two 

major water sources to the lake are the Stehekin River (65 percent of inflow) and 

Railroad Creek (10 percent of inflow). In addition, there are more than 50 

smaller tributaries to the lake, many of which are ephemeral. Due to the shape of 

the valley, most tributaries are steeply incised with cobble, boulder and large 

gravel substrate and relatively short in length. 

The water in Lake Chelan is utilized for domestic and irrigation supply, fisheries, 

power production, transportation, and extensive water recreation, especially 

during the summer. Its hydroelectric dam was constructed in 1927 and raised 

the water level of the lake by 21 feet. Before that, beginning in 1892, a series of 

wooden structures were constructed for damming purposes so that boats could 

reach the town of Chelan. 

The water level in Lake Chelan is replenished during May through June, when 

the lake is refilling from spring runoff. The highest water levels (maximum 

elevation of 1,100 feet) are maintained during July through September. The lake 

is drawn down beginning in early October to provide for the generation of 

electrical power to a potential minimum elevation of 1,079 feet. There has never 

been a need, however, for the water elevation to reach that minimum level. 

The upper end of Lake Chelan is surrounded by mountainous terrain, often so 

steep that there are no beaches, with approximately 50 miles of shoreline in 

National Forest lands and 12 miles in National Park lands. The terrain of the 

lower end of the lake is much less severe and is primarily in private ownership 

and is a highly popular area for summertime recreation. 

Lake Chelan Watershed DDT and PCB TMDL Page 3
Table 3 details the existing land use within the Lake Chelan watershed. More 

than ninety percent of the watershed is surrounded by forests, with moderately 

dense Douglas fir forest along the upper end of the lake, and sparse mixed 

ponderosa pine and shrub-steppe (sage/bitter brush) vegetation along its lower 

end. Agriculture comprises approximately 3.5 percent of the land area, almost 

all of which is located around the southeastern lower end (Wapato Basin) of the 

lake. Urban areas comprise less than one percent and include the cities of Chelan 

and Manson in the Wapato Basin and the smaller towns of Stehekin, Lucerne, 

and Holden that are in the Lucerne Basin of the lake. The Wapato Basin has 

recently experienced a rapid and significant increase in development. 

Table 3: Land Use within the Lake Chelan Watershed 

LAND USE AREA (KM2) PERCENT OF TOTAL 

Lake Chelan 135 5.6 

Other Water Bodies 4 0.2 

Forested Public Lands 2,000 83.6 

Forested Private Lands 163 6.8 

Agriculture – Orchard 47 2.3 

Agriculture – Non-Orchard 31 1.3 

Urban 7 0.2 

Roadways 6 0.2 

Total 2,393 100.0 

Lake Chelan supports a substantial variety of both cold-water and warm-water 

fish species, some of which were introduced by man. The native species are: 

cutthroat trout, bull trout, pygmy and mountain whitefish, burbot (freshwater 

ling cod), northern pikeminnow, redside shiners, slimy sculpin, lake chub, 

peamouth chub, bridgelip sucker, largescaler sucker, longnose sucker, and 

threespine stickleback. Introduced species include: rainbow trout, landlocked 

sockeye salmon (kokanee), landlocked Chinook salmon, lake trout (mackinaw), 

brook trout, grayling, smallmouth bass, black crappie, carp, tench and bluegill. 

Roses Lake (also called Alkali Lake) is one of a cluster of three small lakes often 

referred to as Manson Lakes that are surrounded by many fruit orchards. These 

lakes are located about one mile north of the city of Manson, which itself is 

located near the division between the Lucerne Basin and the Wapato Basin. The 

other two lakes are Wapato Lake and Dry Lake. Roses Lake drains into Dry 

Lake, which then drains into Lake Chelan by way of Stink Creek. 

Roses Lake has only one major surface water source, an irrigation drain. Ground 

water is a major source of water to Roses Lake. The Washington State 

Department of Fish and Wildlife (WDFW) stock the lake with rainbow trout, 

brown trout and black crappie; although, other warm water species exist 

Page 4 Lake Chelan Watershed DDT and PCB TMDL
(bullhead and panfish). All of the climatic and geologic conditions associated 

with Roses Lake are similar to those associated with the Wapato Basin of Lake 

Chelan. 

Applicable Water Quality Standards 

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

surface waters of Lake Chelan as “lake class”. Under these standards, feeder 

streams to a lake are classified as Class AA (extraordinary). The characteristic 

uses defined in the WAC for lake class and Class AA waters, include but are not 

limited to the following (Chapter 173-201A-030[5] WAC): 

(i) Water supply (domestic, industrial, agricultural). 

(ii) Stock watering. 

(iii) Fish and shellfish: 

Salmonid migration, rearing, spawning, and harvesting. 

Other fish migration, rearing, spawning, and harvesting. 

Clam and mussel rearing, spawning, and harvesting. 

Crayfish rearing, spawning, and harvesting. 

(iv) Wildlife habitat. 

(v) Recreation(primary contact recreation, sport fishing, boating, and aesthetic 

enjoyment). 

(vi) Commerce and navigation. 

Toxic substances are addressed in the water quality standards under WAC 173-

201A-030(c)(vii): 

Toxic, radioactive, or deleterious material concentrations shall be below those 

which have the potential either singularly or cumulatively to adversely affect 

characteristics water uses, cause acute or chronic conditions to the most sensitive 

biota dependent upon those waters, or adversely affect public health, as 

determined by the department (see WAC 173-201A-040 and 173-201A-050). 

Other passages addressing toxic substances found in WAC 173-201A-040 are as 

follows: 

(1) Toxic substances shall not be introduced above natural background levels in 

waters of the state which have the potential either singularly or 

cumulatively to adversely affect characteristic water uses, cause acute or 

chronic toxicity to the most sensitive biota dependent on those waters, or 

adversely affect public health, as determined by the department. 

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

toxicity testing, and biological assessments, as appropriate, to evaluate 

Lake Chelan Watershed DDT and PCB TMDL Page 5
compliance with subsection (1) of this section and to ensure that aquatic 

communities and the existing and characteristic beneficial uses of waters are 

being fully protected. 

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

listed in subsection (3) of this section shall be determined in consideration of 

USEPA Quality Criteria for Water, 1986, and as revised, and other 

relevant information as appropriate. Human health-based water quality 

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

National Toxics Rule). 

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

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

In 1992, EPA issued water quality criteria for the protection of human health 

from priority pollutants in the National Toxics Rule (40 CFR 131.36). 

Washington’s human health criteria are specified and contained in this federal 

rule. Human health criteria are calculated for an increased lifetime cancer risk of 

one in one million (10-6) from the consumption of fish or water. Water quality 

criteria that apply to the 303(d) listed chemicals addressed in this TMDL for Lake 

Chelan basin are shown in Table 4. 

Table 4: Chemical - Criteria for Protection of Aquatic Life – Criteria for Protection of Human Health 

Criteria for Protection of 

Aquatic Life 

Criteria for Protection of Human Health 

Chemical Freshwater 

Acute (ng/L) 

Freshwater 

Chronic (ng/L) 

Water and Fish 

Consumption 

(ng/L) 

Fish 

Consumption 

(ng/L) 

Fish Tissue 

4,4’-DDT 0.59 0.59 32 ug/Kg 

4,4’-DDE 0.59 0.59 32 ug/Kg 

4,4-DDD 0.83 0.84 45 ug/Kg 

DDT and 

metabolites 

1,100 1.0 

PCBs 2,000 14 0.17 0.17 5.3 ug/Kg 

The state of Washington has not promulgated standards for freshwater 

sediments. However, a number of guidance values are available in the scientific 

literature that can be used to evaluate the sediment results for DDT (see Table 5). 

The average sediment concentration of total DDT in both Lucerne and Wapato 

basins exceed threshold effects guidance levels. Concentrations of total DDT in 

several locations within Wapato Basin also exceed the consensus-based probable 

effects concentration for total DDT. 

Page 6 Lake Chelan Watershed DDT and PCB TMDL
Table 5: Selected Freshwater Sediment Quality Guidance Values for Total DDT and Total PCBs (μg/Kg. dw)

Freshwater Sediment Quality 

Value 

Total 

DDT 

Total 

PCBs Effects Level 

Apparent Effects Threshold (AET) 

NA 21a

Level above which biological effects have always 

been observed. 

Floating Percentile Method (FPM) NA 60a

Proposed level which optimizes reliability and 

sensitivity in predicting adverse biological effects. 

Threshold Effects Level (TEL) 

7b 34.1b

Represents the concentration below which adverse 

effects are expected to occur only rarely. 

Consensus-Based Threshold Effect 

Concentration (TEC) 5.3c 59.8c

Concentration below which harmful effects on 

sediment-dwelling organisms are not expected. 

Consensus-Based Probable Effect 

Concentration (PEC) 

572c 676c

Concentration above which harmful effects on 

sediment-dwelling organisms are expected to occur 

frequently. 

NA = Data not available 

a = Avocet Consulting 2002; 2003 

b = Smith et al. 1996 

c = MacDonald et al. 2000 

Water Quality and Resource Impairments 

In 1998, Lake Chelan and Roses Lake were included on the state’s 303(d) list of 

impaired waters due to water quality standard violations for 4,4’-DDE, PCB-1254 

and PCB-1260. The Lake Chelan Watershed DDT and PCB TMDL covers all of the 

water bodies within the Lake Chelan watershed, including tributaries, from the 

headwaters of the Stehekin River to the point of discharge (Chelan River) to the 

Columbia River. Table 6 details all of the 1998 303(d) listings, for fish tissue, that 

will be addressed by the TMDL. 

Table 6: 1998 303(d) Listings for Lake Chelan and Roses Lake 

 Old New Water Body 

 Water Body Parameter Listing # Segment # Segment # Class

 Lake Chelan 4, 4’-DDE 8963 WA-47-9020 292NWR Lake 

 Lake Chelan Total PCBs 8964 WA-47-9020 292NWR Lake 

 Roses (Alkali) Lake 4, 4’-DDE 8966 WA-47-9037 370XQC Lake 

Table 7 below details additional impaired water body listings from the 2004 303(d) list that 

were not contained in the 1998 303(d) listings above, and are addressed by the Lake Chelan 

Watershed DDT, PCB, TMDL. 

Table 7: 2004 303(d) Listings for Lake Chelan 

 Old New Water Body 

 Water Body Parameter Listing # Segment # Segment # Class

 Lake Chelan 4,4’-DDD 14325 WA-47-9020 292NWR Lake 

 Lake Chelan 4,4’-DDE 14326 WA-47-9020 292NWR Lake 

 Lake Chelan 4,4’-DDT 14324 WA-47-9020 292NWR Lake 

 Lake Chelan 4,4’-DDT 36426 WA-47-9020 292NWR Lake 

 Lake Chelan Total PCBs 14328 WA-47-9020 292NWR Lake 

Lake Chelan Watershed DDT and PCB TMDL Page 7
It should be noted that: (1) all of the additional impaired waterbody listings 

contained in Table 3 of the first draft of this report were mistakenly labeled as 

from the Chelan River, since later investigation determined that they actually 

were collected from Lake Chelan; (2) the Total PCBs listing in Table 3 of the first 

draft was removed from the present draft, as it represented a combined listing of 

PCB-1254 and PCB-1260 from Table 6, above, and therefore was not a true new 

listing; (3) the 4’,4-DDE listing in Table 3 of the first draft was removed from the 

present draft, as it represented the same 4’,4-DDE listing in Table 6, above, and 

therefore was not a true new listing. 

Additionally, the following tributaries and irrigation drains were identified as 

exceeding DDT standards during the TMDL study and will be addressed in the 

TMDL: 

Lake Chelan Tributary or Irrigation Drain TMDL Study Site

Knapp Coulee SS02 

Culvert at Crystal View NS13 

Purtteman Creek NS15 

Culvert at Veroske’s NS16 

Cooper Drainage NS18 

Bennet Road NS19 

Keupkin Street NS21 

Buck Orchards NS22 

Stink Creek NS24 

Roses lake Orchard Drain ST11 

DDT is a chlorinated insecticide that was heavily used in orchard lands 

throughout the state, including the Lake Chelan watershed, from the early 1940’s 

when it was developed until it was banned in 1972. 

PCBs are chlorinated compounds that were widely used in industrial 

applications as insulating fluids, plasticizers, carbonless paper ink, heat transfer 

and hydraulic fluids, as well as a variety of other uses (e.g. marine paints). EPA 

phased out the use and manufacture of PCBs in 1979. Specific sources of PCBs in 

the watershed are unknown but numerous sources are potential with 

atmospheric deposition extremely probable, since PCBs volatilize easily and have 

been known to travel great distances. In fact, they are routinely found in 

locations unassociated with its use, like the polar regions of earth. 

DDT and PCB levels in the United States environment have been declining for 

the last 30 years due to reductions in manmade sources. However, these toxins 

break down so slowly that residue from past releases may still be in the 

environment many years from now. DDT and PCBs have also been shown to be 

highly persistent in the aquatic environment. In aquatic environments, these 

Page 8 Lake Chelan Watershed DDT and PCB TMDL
pollutants are often found in greatest concentrations in sediment and in the fatty 

tissues of fish and other organisms. Concentrations of these pollutants can 

increase as they proceed through the food chain by a process known as 

biomagnification. Studies have shown that exposure to DDT and PCBs may 

cause a number of adverse health effects, including reproductive or 

developmental defects and cancer. 

Seasonal Variation 

Section 303(d)(1) of the CWA requires that TMDLs “be established at the level 

necessary to implement the applicable water quality standards with seasonal 

variations”. The current regulation also states that determination of “TMDLs 

shall take into account critical conditions” [40 CFR 130.7(c)(1)]. Finally, Section 

303(d)(1)(D) suggests consideration of normal conditions when no critical 

conditions exist. 

A percent reduction approach in fish tissue contaminant concentrations was used 

for meeting water quality targets. The accumulation of DDT and PCBs in fish 

tissues is a time-integrative process. Both human health and chronic aquatic life 

criteria for DDT are driven by lifetime exposures (70 years). Therefore, there is 

no need to establish a “critical condition” season for DDT. 

Although the data is limited, the total DDT concentrations measured in the 

Wapato basin water between 180 and 200 feet appear to follow a seasonal 

pattern. Average concentrations in the lake were highest in May and June, 

followed by July and August. The average concentration in October and 

November was less than a quarter of the level found in July and August. The 

higher springtime total DDT concentration likely results from a combination of 

the start of irrigation, wet season precipitation, increased ground water flows, 

and snowmelt. 

The decline in total DDT from spring through fall suggests irrigation water may 

be associated with Wapato basin total DDT concentrations. One sample site in a 

water body the size of the Wapato basin is inadequate to draw any distinct 

conclusions about seasonal loading, but does suggest more study is needed. 

Concentrations of total DDT from tributaries and irrigation drains did not show 

the high to low response from spring to fall like in-lake concentrations. 

The total DDT load estimates from tributaries and drains suggest there are other 

significant sources of DDT compounds in the basin, like groundwater entering 

the lake. This seasonal pattern for total DDT found in the Wapato basin was not 

seen in the Lucerne basin. 

Lake Chelan Watershed DDT and PCB TMDL Page 9
Technical Analysis 

Historical Data 

DDT

Water Column Data: 

In June 2002, Ecology detected no DDT metabolites at concentrations in excess of 

0.16 ng/L in water samples collected from the Lucerne Basin of Lake Chelan, nor 

in its respective tributaries. However, DDT was found in three small discharges 

to the Wapato Basin. In 1996 and 1997, the Chelan County Conservation District 

(CCCD) reported DDE concentrations as great as 110 ng/L, from Knapp Coulee, 

which is an order of magnitude higher than Ecology’s 2003 data from the same 

site (SS02). The CCCD data was collected from agricultural irrigation return 

water draining from orchard land. 

Sediment Data: 

Historical (1994) sediment analyses from the Wapato Basin and Roses Lake have 

contained the highest concentrations (1,196 μg/Kg) in the watershed. However, 

more recent (2004) sampling by the Lake Chelan Reclamation District (LCRD) 

and Ecology determined DDT sediment concentrations to be two orders of 

magnitude lower, at 46 μg/Kg. The decrease in DDT concentrations over the 

past 10 years suggests that substantial sediment dilution or burial may have 

occurred in Roses Lake. 

The most extensive sediment survey was conducted by the Lake Chelan Water 

Quality Assessment (LCWQA, January 1989). The study found DDT sediments 

concentrations 51 to 699 μg/Kg) approximately 20 times greater in Wapato Basin 

than in the Lucerne Basin. The DDT was concluded to have been transported 

from the surrounding orchard land into the nearby Wapato Basin, but has not 

moved up into the upper Lucerne Basin (Patmont et al., 1989). 

Fish Tissue Data: 

Ecology first discovered elevated concentrations of DDT compounds in fish from 

Lake Chelan in 1982 as part of the Basic Water Monitoring Program (Hopkins 

and Clark, 1985). Since then, Ecology studies have shown continued high DDT 

concentrations in fish from Lake Chelan and Roses Lake. Such concentrations 

continually exceeded the NTR human health criterion for DDT. 

Patmont (1989) found fish tissue DDT concentrations from Lake Chelan to be 

roughly three times higher than the national average and comparable to other 

highly agricultural water bodies in the state. In 2002, the EPA found DDT 

concentrations in Lake Chelan to be greater than 140 other lakes in a National 

Page 10 Lake Chelan Watershed DDT and PCB TMDL
Fish Tissue Study. The specific species was mackinaw with a DDT level 

averaging 1,481 μg/Kg. 

Very little data is available for fish in Roses Lake. In 1992, Ecology found DDT 

concentrations in rainbow trout as great as 103 μg/Kg (Serdar et al., 1994). These 

findings led to the 303(d) listing for 4,4’-DDE in that lake. 

PCBs

Water Column and Sediment Data: 

No historical data has previously been collected for PCBs in water and sediment. 

Fish Tissue Data: 

Ecology in 1992 and 1994 found PCB concentrations in Lake Chelan fish tissue 

ranged from 12 to 99 μg/Kg. In 2002, the EPA found PCB concentrations in 

mackinaw as great as 32.6 μg/Kg. This exceeds NTR Human Health criteria of 

5.3 ug/Kg for total PCBs. 

Current Data 

Lake Chelan DDT and PCBs in Fish –A Total Maximum Daily Load Study (See 

Appendix A for complete assessment) 

Study overview

The Lake Chelan DDT and PCBs in Fish – A Total Maximum Daily Load Study was 

directed at DDT and PCB contamination and transport in the aquatic 

environment and in fish tissue of Lake Chelan, Roses Lake and their tributaries. 

DDT levels exceeded water and fish tissue standards in the Wapato basin. PCB 

levels exceeded fish tissue standards. Inputs of DDT and PCBs will likely be a 

management issue for years into the future as their persistence in the 

environment is well documented. 

Assessment results

Water 

Five water sample surveys from Lake Chelan tributaries and agricultural drains 

were conducted between May and November of 2003. Samples were analyzed 

for 4,4’-DDT and its metabolites 4,4’-DDE and 4,4’-DDD (i.e., total DDT). Total 

DDT concentrations in the Wapato basin discharges ranged from 0.13 to 36 ng/L. 

DDT and its metabolites were not detected in discharges to the Lucerne basin. 

Human health and aquatic life (chronic exposure) water quality criteria for DDT 

(0.59 and 1.0 ng/L, respectively) were routinely exceeded in the Wapato basin. 

PCBs were not analyzed for in tributaries and agricultural drains. 

Lake Chelan Watershed DDT and PCB TMDL Page 11
Total DDT loads (mg/day) from Wapato basin discharges to Lake Chelan were 

calculated using total DDT concentrations and flows (i.e., total DDT 

concentration times instantaneous flow). The Keupkin Street site ranked highest 

at 43 mg/day, followed by Buck Orchards and Purtteman Creek at 6.1 and 5.8 

mg/day, respectively. Water from the Keupkin Street site was collected from an 

irrigation drain manhole in an orchard area above Manson. The annual total 

DDT load to Lake Chelan from discharges sampled during the study was 

estimated at 25 grams per year. 

The dissolved fraction (portion available for biological uptake) of DDT plus 

metabolites and PCBs in Lake Chelan was measured by use of semipermeable 

membrane devices (SPMDs). One SPMD was deployed in each basin for about a 

month during May, July, and October of 2003. Estimates of lake water 

concentrations between 180 and 200 feet depth found total DDT was higher in 

the Wapato basin than in the Lucerne basin. Total DDT concentrations were 

highest in May and June, followed by July and August, and October and 

November. During May and June, estimated concentrations of total DDT in the 

Wapato basin were two orders of magnitude higher than in the Lucerne basin. 

PCBs were generally not detected in SPMDs. 

Estimated total DDT concentrations from SPMDs were compared to human 

health and aquatic life (chronic exposure) water quality criteria. Levels of total 

DDT estimated for the Wapato basin from SPMDs routinely exceeded human 

health and aquatic life criteria. The Lucerne basin results exceeded the human 

health criterion for DDT slightly in the October to November sample and were 

always within criterion for chronic exposure to aquatic life.

Sediment

Surface sediments were collected at 20 locations within Lake Chelan. Three of 

these sites were alluvial, collected at the mouths of Railroad Creek, First Creek, 

and the Stehekin River. First Creek had the only alluvium sample with 

detectable total DDT, at a concentration of 11 ug/Kg. Concentrations of total 

DDT in Wapato basin sediments averaged 560 ug/Kg, compared to 120 ug/Kg in 

the Lucerne basin. Results for PCBs were low, ranging from 1.2 to 2.7 ug/Kg, 

and were mainly detected in the Wapato basin. 

Two shallow (0 – 40 cm) sediment cores were collected, one each from the 

Lucerne and Wapato basins. The sedimentation rate for the Lucerne basin was 

estimated at 0.19 cm/yr. The Wapato basin rate (0.092 cm/yr) was estimated at 

about half the rate estimated for the Lucerne basin, although study data suggest 

possible problems with the dating estimate from the Wapato basin. These 

sedimentation rates are at the low end of the range reported for other 

Washington lakes. Total DDT concentrations in the Wapato core were an order 

Page 12 Lake Chelan Watershed DDT and PCB TMDL
of magnitude higher than sediment of roughly the same age from the Lucerne 

core. PCBs were not detected in cores. 

The accumulation pattern for total DDT in the Lucerne basin core was similar to 

a recent core Ecology collected from Lake Osoyoos. Accumulation patterns for 

the Wapato core suggest sediment disturbance to the record or possibly changes 

in sedimentation rates.

Fish 

A total of 200 fish were collected and analyzed from Lake Chelan and Roses Lake. 

The species were burbot, mackinaw (lake trout), rainbow trout, and kokanee from 

Lake Chelan, and rainbow trout and black crappie from Roses Lake. Fish tissue 

samples were analyzed as five-fish composites of fillet tissue. Some mackinaw 

and rainbow trout were also analyzed individually. 

Average concentrations of total DDT found in Lake Chelan fish were about four 

times higher than other fish tissue studies conducted in eastern Washington. 

Concentrations of PCBs in Lake Chelan fish, though still above the stringent 5.3 

ug/Kg human health criterion for fish tissue, were only a fraction of the levels 

found in other eastern Washington studies. 

Bioaccumulation factors (BAFs) represent the ratio of the concentration of a 

chemical in the tissue of an aquatic organism, from both diet and water exposure, 

to the concentration of the chemical in water. BAFs were calculated for total DDT 

in Lake Chelan fish using tissue concentrations and estimated dissolved water 

concentrations from SPMDs. The mean Lake Chelan BAF for total DDT was 

calculated to be 41,450. In the development of the state adopted human health 

criteria for DDT in fish tissue, EPA used a related parameter called the 

bioaccumulation concentration factor (BCF), which is the ratio of the chemical 

concentration in tissue from only water exposure to the concentration of the 

chemical in water. The EPA BCF value for DDT is 53,600. Based on the data 

collected, the EPA BCF value may be overly conservative for Lake Chelan. A BAF 

which includes exposure from both diet and water should have a higher value 

than a BCF which only includes exposure from water. The mean BAF measured 

for Lake Chelan fish is 23 percent lower than EPA’s BCF value. 

Assessment Recommendations 

Water 

The water quality and fish tissue quality associated with Lake Chelan and Roses 

Lake are being negatively impacted by DDT and PCBs. These chemicals do not 

occur naturally in the environment and thus indicate that anthropogenic activities 

are the only sources. The primary focus of the Lake Chelan Watershed DDT and 

PCB TMDL is the concentration of such pollutants in fish tissue, due to the 

Lake Chelan Watershed DDT and PCB TMDL Page 13
biomagnification of those pollutants. Recommendations for actions to meet water 

quality standards are primarily targeted for the Wapato basin of Lake Chelan and 

its respective tributaries. 

An evaluation of the potential contribution of total DDT loading from 

groundwater to the Wapato basin should be conducted. 

An evaluation of total DDT concentrations in the water column in the Wapato 

basin should be conducted to better quantify spatial and temporal variations. 

Pollutant input to the lakes of the watershed should be limited as much as 

possible. It has been shown that tributary and irrigation drain sources require 

substantial load reductions to meet water quality criteria. The discharge point 

approach to load reduction does not identify specific sources. Loading could 

come from multiple sources that were quantified as one. Investigations of subbasins would be required to identify any specific sources for load reductions. 

Load reductions could occur through developed wetland treatment, if and where 

feasible. Developed wetlands may be one of the few treatment options available 

for reducing total DDT. Data from the Joe Creek site in the Lake Chelan 

Reclamation District study (Burgoon and Cross, 2000) and data from the Wapato 

Lake + Joe Creek site from this TMDL study suggest loads of total DDT through 

wetlands may be reduced to acceptable levels. 

Sediment 

Natural attenuation is the best management strategy for total DDT in Lake 

Chelan and Roses Lake sediments. Active removal of total DDT laden sediments 

from Lake Chelan is probably not an option considering size, depth, cost, and the 

disturbance to fish and invertebrate communities, and habitat. 

Developed wetlands may be a promising treatment option available for reducing 

DDT laden sediment in tributaries and irrigation drains. 

Fish 

Upon review of the Department of Ecology TMDL study, the Washington State 

Department of Health (WDOH) has continued a fish consumption advisory for 

Mackinaw in Lake Chelan, which was initially issued in 2003 following a USEPA 

study. The study data clearly shows that lake trout are efficient in the 

bioaccumulation of DDT and PCBs. The WDOH should continue its fish 

consumption advisory for mackinaw. Public notice and posting at all public boat 

launches to Lake Chelan and Roses Lake should be completed. The public 

should be aware of potential problems from consuming fish in excess of 

recommended levels. 

Page 14 Lake Chelan Watershed DDT and PCB TMDL
Fish tissue contaminant monitoring should be conducted every five years to 

track progress toward achieving targets. Mackinaw should be selected for 

collection and analysis, as they provide a worst case scenario for total DDT, PCB, 

and /furan concentrations in fish. Evaluating fish tissue concentrations will be 

required for a long time into the future. 

Loading Capacity 

Identification of the loading capacity is an important step in developing TMDLs. 

The loading capacity is the amount of pollution a water body can absorb and still 

meet water quality standards. There are no known point sources of either DDT 

or PCBs in the Lake Chelan watershed. As there are no point sources in the 

watershed, a percent reduction approach in fish tissue contaminant 

concentrations was used for meeting water quality targets for total DDT and 

PCBs in Lake Chelan. 

Water 

DDT 

Water column DDT concentrations were estimated by use of semi-permeable 

membrane devices (SPMDs). Total DDT found in SPMDs exceeded the National 

Toxics Rule (NTR) criteria (0.59 ng/L) and aquatic life criteria (1.0 ng/L). As 

evidenced in SPMDs, the DDT concentrations in Lake Chelan’s Wapato basin 

ranged from about 40 times the standard during May and June 2003, to about 

seven times in October and November 2003. Low DDT levels were found in the 

Lucerne basin, at about half the NTR criterion during May and June and slightly 

above the standard in October and November. 

Surface water samples were also taken from tributaries and drains flowing into 

Lake Chelan. The NTR human health and aquatic life criteria for total DDT were 

routinely exceeded in the tributaries discharging to the Wapato basin. Detected 

total DDT concentrations in tributaries to Lake Chelan ranged from an estimated 

0.13 ng/L to 36 ng/L. 

The original review draft of the technical report calculated the loading capacity 

and percent reductions needed from irrigation drains and tributaries using the 

NTR standard for human health of 0.59 ng. The Lake Chelan Water Quality 

Committee (LCWQC) disputed the use of the more stringent NTR standard of .59 

ng/L for tributaries and drains, preferring to use the NTR criterion for aquatic 

life of 1.0 ng/L. The LCWQC reasoned that the TMDL study data suggests inlake concentrations may relate to significant groundwater influences. Also, 

existing t-DDT concentrations in the lake sediments and through the food chain 

may be a significant source of t-DDT impacting fish. Additionally, the NTR 

Lake Chelan Watershed DDT and PCB TMDL Page 15
criterion is based on human exposure to both drinking water and eating fish that 

lived in the water, over a 70-year period. The irrigation drains are not used for 

drinking water or contact recreation. First Creek is the only tributary in the 

Wapato Basin observed being used for fish habitat and currently requires no 

management because water quality was within criteria. 

Ecology agreed that tributaries and drains are not the only source with 

measurable adverse impact on chronic toxicity to Lake Chelan, and with 

arguments about their uses. Additionally, in consideration of the dilution these 

discharges receive from the lake, the state criterion of 1.0 ng/L was used as the 

target for tributaries and drains. 

Table 8 details the individual DDT loading capacities for the various tributaries 

and discharges that enter into the Wapato Basin of Lake Chelan (the basin that 

consistently exceeds the DDT and metabolite human health criterion). Table 9 

details the individual loading capacities for the single discharge that enters Roses 

Lake. 

Table 8: Lake Chelan Tributary Total DDT Loading Capacities 

Tributary or Drain Site Harmonic Mean 

Flow (ft3/sec) 

Loading Capacity 

(mg/day) 

SS01 - First Creek 4.90 12 

SS02 – Knapp Coulee 0.16 0.39 

NS13 - Culvert at Crystal View 0.015 0.04 

NS15 – Purtteman Creek 0.93 2.3 

NS16 – Culvert at Veroske’s 0.087 0.21 

NS18 – Cooper drainage 0.041 0.10 

NS19 – Bennet Road 0.054 0.13 

NS21 – Keupkin Street 0.62 1.5 

NS22 – Buck Orchards 0.19 0.46 

NS23 – Wapato Lake + Joe Creek 0.09 0.22 

NS24 – Stink Creek 0.44 1.1 

NS30 – Mill Bay boat ramp 0.02 0.05 

Total N/A 18.5 

Table 9: Roses Lake Tributary DDT Loading Capacities 

Tributary or Drain Site Harmonic Mean 

Flow (ft3/sec) 

Loading Capacity 

(mg/day) 

ST11 - Orchard drain 0.061 0.15 

Page 16 Lake Chelan Watershed DDT and PCB TMDL
PCBs 

Water column PCB concentrations were estimated by use of semi-permeable 

membrane devices (SPMDs). Only the Wapato Basin of Lake Chelan was found 

to contain a detectable PCB concentration (0.003 ng/L); however, it did not 

exceed the stringent NTR (human health) water column criterion of 0.17 ng/L. 

Accordingly, there will only be a PCB fish tissue loading capacity for the Wapato 

basin and no water column loading capacity applicable to the Lake Chelan 

Watershed DDT, PCB, TMDL.

PCBs were not analyzed from surface water samples due to the difficulty in 

achieving detection with normal analytical techniques. 

Two PCB transformer sites have been identified in the TMDL, one in a Manson 

orchard and one in Stehekin. These sites have been remediated. Also, the Lake 

Chelan Reclamation District has identified and removed nine transformers 

containing PCBs in the Manson area. See Summary Implementation Strategy. It 

is unknown if there are other dump sites around the lake that contain PCBs. 

Fish Tissue 

DDT 

Loading capacity for DDT in fish tissue is based on the National Toxics Rule 

(NTR) human health criteria for edible fish tissue. The NTR has separate 

criterion for DDT, DDE, and DDD in fish tissue (see Table 4). This TMDL used 

the DDT and DDE criterion as the target for reductions needed in fish tissue 

compared to the mean total DDT concentration. The levels not to exceed for 

edible fish tissue are 32 ug/Kg for total DDT, 32 ug/Kg for DDE, and 45 ug/Kg 

for DDD. 

A percent reduction approach in fish tissue contaminant concentrations was used 

for meeting the NTR human health targets. The mean concentrations of total 

DDT (943 ug/Kg) in Lake Chelan mackinaw were calculated to represent the 

current contaminant load in fish tissue and the basis for load reductions. 

Mackinaw had the highest mean concentrations in fish tissue, so basing 

reductions on mackinaw will allow a greater level of protection for consumers of 

all other species. A 97 percent reduction in total DDT is needed in edible fish 

tissue to meet the human health criteria in Lake Chelan. 

The concentration of total DDT in rainbow trout tissue from Roses Lake was 96 

ug/Kg. A 67 percent reduction is needed in edible fish tissue to meet the human 

health criteria in Roses Lake fish. 

Lake Chelan Watershed DDT and PCB TMDL Page 17
PCBs 

Loading capacity for PCBs in fish tissue is based on the National Toxics Rule 

(NTR) human health criteria for edible fish tissue (5.3 ug/Kg). A percent 

reduction approach in fish tissue contaminant concentrations was used for 

meeting the NTR human health targets. The mean concentrations of total PCBs 

(14.5 ug/Kg) in Lake Chelan mackinaw were calculated to represent the current 

contaminant load in fish tissue and the basis for load reductions. A 63 percent 

reduction in total PCBs concentrations is needed in edible fish tissue to meet the 

human health criteria in Lake Chelan. 

Wasteload and Load Allocations 

There are no point sources of DDT or PCBs discharging to Lake Chelan and 

Roses Lake, so there are no wasteload allocations. The only sources of these 

pollutants are non-point sources, so the Lake Chelan Watershed DDT and PCB 

TMDL will contain load allocations. Loading of DDT to the lakes and tributaries 

of the watershed has been an ongoing process, since its application to orchards 

(1940’s - 1970’s), through irrigation return, groundwater, runoff, and soil erosion. 

The sources of PCBs are not as obvious, but probably include soil erosion, 

surface run-off, and aerial transport and deposition. 

Wasteload Allocations 

DDT 

The wasteload allocation for DDT and metabolites is zero, as there are no known 

point sources of these pollutants. 

PCBs 

The wasteload allocation for PCBs is zero, as there are no point sources of that 

pollutant. 

Load Allocations 

DDT 

DDT water quality targets for Lake Chelan and Roses Lake TMDLs are the 

National Toxics Rule (NTR) human health criteria for edible fish tissue. The NTR 

has separate criterion for DDT, DDE, and DDD in fish tissue (see Table 4). This 

TMDL used the DDT and DDE criterion as the target for reductions needed in 

fish tissue compared to the mean total DDT concentration. 

A percent reduction approach in fish tissue contaminant concentrations was used 

for meeting the NTR human health targets. Mackinaw and burbot from Lake 

Chelan and rainbow trout from Roses Lake were used to determine the 

Page 18 Lake Chelan Watershed DDT and PCB TMDL
reductions needed to meet water quality targets. These fish represent the species 

with the highest mean concentration of total DDT sampled from each water 

body. 

Percent reduction calculations for fish tissue from the Wapato basin and Roses 

Lake are as follows: 

Wapato Basin Fish 

% Reduction total DDT = [(943 ug/Kg – 32 ug/Kg) / (943 ug/Kg)] x 100 = 97 % 

Roses Lake Fish 

% Reduction total DDT = [(96 ug/Kg – 32 ug/Kg) / (96 ug/Kg)] x 100 = 67 % 

Tributaries and agricultural drains to the Wapato basin were also assigned 

needed percent reductions of current loads to meet water quality targets. These 

percent reductions represent the amount of the total daily pollutant load that the 

tributaries and drains must be reduced to meet water quality criteria. Water 

quality targets for tributary and drain discharges to Lake Chelan and Roses Lake 

are based on Washington State’s standard, 1.0 ng/L, for the protection of aquatic 

life from DDT in the water column. 

To calculate current and allowable loads, it was assumed that all total DDT loads 

to the lake are available for uptake and bioaccumulation by fish. The twelve 

tributary and drain sites to Lake Chelan were sampled on five occasions between 

May and November 2003. Sampling was conducted at different times of the year 

to incorporate the range of total DDT concentrations found in discharges around 

the Wapato basin. To compare allowable loads to existing loads into Lake 

Chelan, and to quantify the needed percent reductions to meet criterion, the 

mean instream study loads were calculated at the harmonic mean flow 

developed from the range of flow conditions. See TMDL Calculations section, 

page 54, of the TMDL study. 

The current mean DDT contaminant loads, allowable TMDL loads, and load 

reductions needed to meet water quality criteria for discharges to Lake Chelan 

and Roses Lake are shown in Table 10 and 11. 

Lake Chelan Watershed DDT and PCB TMDL Page 19
Table 10: Lake Chelan Tributary Total DDT Load Allocations 

Tributary or 

Discharge Site

Current t-DDT 

Load (mg/day) 

Allowable 

Load (mg/day) 

Needed Load 

Reduction

(mg/day) 

Needed % 

Reduction

SS01 - First Creek 2.2 12 0 0 

SS02 – Knapp Coulee 2.4 0.39 2.0 84 

NS13 – Culvert at Crystal View 0.14 0.04 0.10 71 

NS15 – Purtteman Creek 5.8 2.3 3.5 60 

NS16 – Culvert at Veroske’s 3.0 0.21 2.8 93 

NS18 – Cooper Drainage 1.5 0.10 1.4 93 

NS19 – Bennet Road 0.29 0.13 0.16 55 

NS21 – Keupkin Street 43 1.5 42 97 

NS22 – Buck Orchards 6.1 0.46 5.6 92 

NS23 – Wapato Lake + Joe Creek 0.04 0.22 0 0 

NS24 – Stink Creek 1.9 1.1 0.80 42 

NS30 – Mill Bay boat ramp 0.02 0.05 0 0 

Total 66.4 18.5 58.4 

Table 11: Roses Lake Tributary DDT Load Allocation 

Discharge Site Current 

t-DDT Load

(mg/day) 

Allowable 

Load (mg/day) 

Needed Load 

Reduction

(mg/day) 

Needed % 

Reduction 

ST11 - Orchard Drain 3.2 0.15 3.1 95 

PCBs 

PCB water quality targets for the Lake Chelan TMDL are the National Toxics 

Rule (NTR) human health criteria for edible fish tissue (see Table 4). This TMDL 

used the NTR criterion as the target for reductions needed in fish tissue. The 

levels not to exceed are 5.3 ug/Kg for total PCBs. 

A percent reduction approach in fish tissue contaminant concentrations was used 

for meeting the NTR human health targets. Mackinaw from Lake Chelan was 

used to determine the reductions needed to meet water quality targets. 

Mackinaw represents the species with the highest mean concentration of total 

PCBs sampled. 

Percent reduction calculations for PCBs in fish tissue from the Wapato basin are 

as follows: 

% Reduction total PCBs = [(14.5 ug/Kg – 5.3 ug/Kg) / (14.5 ug/Kg)] x 100 = 63 % 

Page 20 Lake Chelan Watershed DDT and PCB TMDL
Margin of Safety 

The federal Clean Water Act requires that a margin of safety be identified to 

account for uncertainty when establishing a TMDL. The margin of safety can be 

explicit in the form of an allocation, or implicit in the use of conservative 

assumptions in the analysis. The Lake Chelan Watershed DDT and PCB TMDL

includes the following implicit conservative assumptions in the calculated load 

allocations, targets and recommendations: 

• The average total DDT and total PCB concentrations in mackinaw tissue 

from Lake Chelan and rainbow trout from Roses Lake were used in load 

reductions needed in fish tissue. Using the total concentrations from the 

most contaminated fish species would increase the MOS for other species. 

• Load reductions for total DDT needed in fish tissue were based on the lower 

criteria for individual DDT metabolites (4,4’-DDT + 4,4’-DDE - 32ug/Kg) 

instead of the average concentration including the higher criteria for 4,4’ 

DDD of 45 ug/Kg. 

• The mass of tributary and irrigation drain associated total DDT was assumed 

to be completely conserved. The allocations to tributaries and drains assume 

no loss by volatilization, photolysis, or biodegradation. 

• DDT loading from tributaries and irrigation drains was considered 100 

percent available for uptake and bioaccumulation by fish. No sediment 

associated fraction was considered in load allocation calculations. 

• The TMDL assumed the water column has no assimilative capacity for total 

DDT above the water quality standard. 

• The legacy contaminants addressed in this TMDL should continue to decline 

even after all regulatory criteria have been met, due to the absence of new 

sources, local management of the resources, and keeping the public 

informed on issues so they can help reduce contaminants in the system. 

Lake Chelan Watershed DDT and PCB TMDL Page 21
Page 22 Lake Chelan Watershed DDT and PCB TMDL
Summary Implementation Strategy 

Implementation Overview 

The summary implementation strategy (SIS) described in this section identifies 

actions that will be implemented in the watershed to address DDT, PCB, and 

pollutants. The actions listed were developed in partnership by the Lake Chelan 

Water Quality Committee and Ecology. Successful completion of the actions, 

effectiveness monitoring, and adaptive management will result in water quality 

standards being met over time. The SIS complies with the federal mandate of the 

Clean Water Act, state laws to control point and non-point source pollution, and 

the 1997 Memorandum of Agreement between EPA and Ecology. It is 

anticipated that implementation actions should be completed by 2018. At the 

present time, insufficient historical data and limited understanding of the 

dynamics of DDT cycling within Lake Chelan are available to accurately 

determine the time required to meet the state’s water quality standards through 

natural attenuation and implementation of the TMDL’s actions. Adaptive 

management and planned studies that will be conducted during the Detailed 

Implementation Plan phase (see below) will allow development of a more 

accurate estimate. Currently, based on best professional judgment, it is 

anticipated that state’s water quality standards will likely be met by 2055. 

The strategy to implement the TMDL is based upon completion of actions that 

will be outlined in this SIS and, later, more specifically described in a Detailed 

Implementation Plan (DIP). The DIP will be prepared within one year after the 

Lake Chelan Watershed DDT and PCB TMDL Submittal Report has been approved 

by EPA. The DIP will describe the specific implementation activities that will 

need to be performed by all of the various stakeholders in order to achieve the 

TMDL targets. The plan will identify in more detail how, when, and where 

monitoring activities will be implemented. Ecology and other entities will 

provide technical assistance and seek additional funding for these monitoring 

activities and any restoration activities that may be identified as the body of data 

grows. Public input will be sought to help prepare the plan. 

Implementation Plan Development 

The SIS is an outline of the activities identified for implementation of the Lake 

Chelan Watershed DDT and PCB TMDL

A citizen’s workgroup, the Lake Chelan Water Quality Committee, was formed as 

the technical advisory committee (TAC) for the Lake Chelan Watershed DDT and 

PCB TMDL in order to serve as citizen representatives in the development of the 

TMDL and its implementation strategy. Groups represented in the TAC include 

agriculture, conservation districts, irrigation districts, local government, sewer 

districts, state, and federal agencies, community organizations, as well as other 

Lake Chelan Watershed DDT and PCB TMDL Page 23
interested parties. There is a high level of cooperation and communication 

between project participants, and their continued active pursuit of the goals of the 

TMDL. 

Implementation Activities 

The following previous studies have resulted in a list of implementation actions 

being conducted over time, which the Lake Chelan Water Quality Committee has 

been involved in, and is building upon in this TMDL (see Appendix G for 

detailed list of study conclusions and recommendations): 

• Lake Chelan Water Quality Plan, (1991, R.W. Beck) 

• Water Quality Trends and Characteristics of Agricultural Drains (1998, Lake 

Chelan Reclamation District) 

• DDT and Phosphorous Movement in the Manson Lakes Drainage Basin 

(2004, Lake Chelan Reclamation District) 

• Lake Chelan Dam, Federal Energy Commission Relicensing and 401 

Certification, (2004, Department of Ecology) 

The following early implementation actions have been conducted specific to this 

TMDL: 

• The Lake Chelan Reclamation District worked with Chelan PUD to recycle 

nine of its old electrical transformers containing PCBs, at a cost to the District 

of $450,000 dollars. 

• The Chelan PUD is providing information from its studies on water quality, 

fish, food web modeling, etc. related the FERC relicensing of the Chelan Dam. 

• Electrical transformers containing PCBs and contaminated soils identified at 

the old Stehekin power station and a Manson orchard have been cleaned up. 

• A public health notice for mackinaw consumption in Lake Chelan was issued 

by the Washington State Department of Health and Chelan-Douglas Health 

District. 

• Brochures have been distributed educating residents about ways to protect 

water quality, such as environmental landscaping, boating practices, etc. 

• News articles and radio interviews have been provided by committee 

members and elected officials. 

The following recommendations and actions have been identified and are being 

conducted based on the Lake Chelan Watershed DDT, PCB TMDL study: 

Page 24 Lake Chelan Watershed DDT and PCB TMDL
Lake Chelan DDT and PCBs in Fish Total Maximum Daily Load Study 

Recommendations and Actions (2005) 

1. Recommendation: The Washington State Department of Health should 

evaluate the need for fish consumption advisories for Lake Chelan and Roses 

Lake. If advisories are recommended, public notices should be posted at all 

public boat launches to the lakes. The public should be aware of potential 

problems from consuming fish in excess of recommended levels. 

Action: Upon review of the Department of Ecology TMDL study, the 

Washington State Department of Health continued a fish consumption 

advisory for mackinaw in Lake Chelan, which was initially issued in 2004 

following a USEPA study. Brochures that were developed and distributed by 

the Chelan-Douglas Health District in 2004 were updated and redistributed at 

Health District offices, the National Park Service, and the City of Chelan. A 

news release was issued in September, 2005 and the public was informed. 

See news articles in Appendix B. 

2. Recommendation: DDT levels should be the primary focus for water quality 

managers in the Lake Chelan basin. PCB levels should be followed, but 

management options are more limited. 

Action: Management activities are being targeted primarily for DDT. 

However, PCB actions are being implemented, such as education, PCB 

transformer recycling, cleanup of old PCB sites, pesticide pickup days, etc. 

See PCBs below. PCBs levels will also be followed. 

3. Recommendation: Monitoring pollutant levels in mackinaw tissue allows an 

evaluation of the worst-case scenario for total DDT and PCBs in fish tissue. 

Until total DDT and PCBs in fish tissue are within acceptable levels, tissue 

concentrations should continue to be monitored. Because lake sediments act 

as a large source pool for pollutants, evaluating tissue concentrations will be 

required far into the future.

Action: Monitoring is continuing. The Lake Chelan Water Quality 

Committee is currently implementing a Department of Ecology Centennial 

grant to continue monitoring sediment, soil, surface water, groundwater, and 

fish uptake mechanisms (Grant G0400274 - Lake Chelan TMDL Support Project). 

The grant provides $267,000 in Centennial funds from Ecology. An 

additional $89,000 is provided in cash match through an interlocal agreement 

between Chelan County, City of Chelan, Lake Chelan Reclamation District, 

Chelan County PUD, and the Lake Chelan Sewer District. 

4. Recommendation: Natural attenuation is the best management strategy for 

total DDT in Lake Chelan and Roses Lake sediments. Active removal of totalDDT-laden sediments from Lake Chelan is not an option, considering size 

Lake Chelan Watershed DDT and PCB TMDL Page 25
and depth, disturbance to fish and invertebrate communities, and damage to 

habitat. Natural attenuation is also the least costly of management options. 

The rate of attenuation in Roses Lake may be much greater than would be 

expected in Lake Chelan because of differences in productivity. It seems that 

natural attenuation in Roses Lake has improved sediment conditions, 

although fish tissue concentrations have not responded well. 

Action: Continued monitoring will be conducted to compare natural 

attenuation of current DDT and PCB levels in Lake Chelan and Roses Lake 

with applied actions to reduce further inputs. 

5. Recommendation: Pollutant input to the Wapato basin of Lake Chelan and to 

Roses Lake should be controlled to the extent possible, to help in recovery 

and to avoid exacerbating conditions. It has been shown that tributary and 

irrigation drain sources require substantial load reductions to meet water 

quality criteria. The discharge point approach to load reduction does not 

identify specific sources. Loading could come from multiple sources that 

were quantified as one. Investigations of sub-basins would be required to 

identify any specific sources for load reductions.

Action: Pollutant input to the Wapato basin of Lake Chelan and to Roses 

Lake will be addressed through several activities, including the following: 

A. TMDL Support Grant - The Lake Chelan Water Quality Committee is 

currently implementing a Department of Ecology grant which includes 

further identification of sources contributing DDT and PCBs to tributaries, 

irrigation drains, ground water, Roses Lake and Lake Chelan. The grant 

funds actions and monitoring to address soil, sediment, surface water, 

groundwater, fish uptake mechanisms, and education/outreach. 

Monitoring will continue over time to see if load reductions are being met.

B. Agriculture: Historical use of DDT on fruit crops in the Wapato basin has 

been the main source to Lake Chelan and Roses Lake. DDT has been 

transported through erosion of agricultural soils on the surface and 

percolation of water through orchard soils to groundwater. Historical 

improvements in irrigation delivery systems have reduced soil erosion 

and sediment transport. Activities to reduce erosion and groundwater 

transport will be implemented, including: 

• Irrigation water management – The LCWQC and participating entities 

will work with growers and irrigation districts to encourage and 

implement practices that utilize water efficiently, which will improve 

crops, reduce surface runoff and deep percolation and in turn reduce 

DDT transport to ground and surface waters. Examples of practices 

include soil moisture monitoring, monitoring micro climates with 

weather stations, on-farm irrigation system evaluations, irrigation 

Page 26 Lake Chelan Watershed DDT and PCB TMDL
scheduling models, utilization of new LCWQC information, utilization 

of new technologies and other BMPs. 

• Constructed wetlands – Several sites have been identified as good 

locations for constructed wetlands including the outlet area of Dry 

Lake, Stink Creek drainage, Joe Creek drainage, and Cooper drainage. 

Sites with the highest DDT loads include the Keupkin Street drainage, 

Buck Orchards drainage, and Purtteman Creek drainage. These sites 

are located in agricultural areas. A wetland plan will be developed 

and implemented. See #6 below. 

• Riparian vegetation buffers along streams and lakes – Sites will be 

identified and actions implemented to create and protect riparian 

vegetative buffers on agricultural and other land that includes streams 

and lakes shoreline in the watershed. 

• Outreach, education, and technical assistance to growers – Activities 

will be identified and undertaken to provide ongoing outreach, 

education, and technical assistance to growers. 

• Funding – Funding sources will be identified and applications 

submitted to provide funding for ongoing activities. The Department 

of Ecology will provide funding assistance through its grants/loans 

programs to implement actions and ongoing monitoring. 

C. Development: Measures will be implemented to prevent DDT laden 

orchard soils disturbed during construction from being transmitted to 

streams and lakes in the watershed. Language requiring measures to 

prevent DDT laden soils from entering the waterways during and after 

construction will be developed by the Lake Chelan Water Quality 

Committee and included in Development ordinances, comprehensive 

plans, and critical area ordinances. The Eastern Washington Storm Water 

Manual will be utilized in developing ordinances, and guiding municipal 

and construction storm water practices. 

D. Storm water: The LCWQC will research city and county municipal storm 

water systems (plans, deigns, capacities, discharge points, etc.). The 

LCWQC will develop and implement a prioritized list of projects for 

storm water management and filtration (rerouting lines, mechanical 

filtration, settling basins, wetlands, etc.). Storm water monitoring will be 

conducted through G0400274, Lake Chelan TMDL Support grant. 

Monitoring will be conducted associated with implementation of BMPs to 

document environmental results. 

E. Best management Practices (BMPs): The Lake Chelan Water Quality 

Committee will develop a plan to implement a list of BMPs and locations 

to prevent DDT and PCBs from entering surface and ground waters. The 

Lake Chelan Watershed DDT and PCB TMDL Page 27
LCWQC will work with the community, growers, Forest Service, agencies, 

and individuals. Actions planned will include riparian vegetation 

plantings, exclusion fencing, irrigation water management, developed 

wetlands, mechanical filtration, and other BMPs. 

F. Education and outreach: The Lake Chelan Water Quality Committee will 

conduct education and outreach activities for the community, growers, 

schools, media, etc. Activities may include workshops, news releases, 

media interviews, brochures, posters, curriculum, presentations, technical 

assistance, community forums, etc. Utilize previously developed 

brochures, flyers, news releases, and posters (see Appendix B). 

The Lake Chelan Water Quality Committee is currently implementing a 

Centennial Clean Water grant through the Department of Ecology (Grant 

G0400274 - Lake Chelan TMDL Support Project). The education/outreach 

component of the grant requires the following activities: 

1. Continue public outreach efforts of the Lake Chelan Water Quality 

Committee 

2. Provide local coordination of education/outreach for the DDT/PCB 

TMDL Supplemental Implementation Strategy (SIS) and Detailed 

Implementation Plan (DIP). 

3. Coordinate education/outreach and implementation efforts associated 

with ongoing monitoring. 

4. Document environmental benefits relating to efforts conducted with 

this project. 

G. Pesticide Pickup program: Programs for the collection of banned 

pesticides have been successfully implemented in the Lake Chelan 

Watershed and Chelan County. The Washington State Department of 

Agriculture’s Waste Pesticide Program held the first pesticide pick-up 

event in Chelan on October 17, 1999. A total of 6,076 pounds of pesticides 

were collected and 144 pounds of DDT were brought in. 

Five pick-up events have also been held in nearby Wenatchee from 2000 to 

2004. A total of 40,199 pounds of pesticides were collected and 330 

pounds of DDT were brought in. 

Six pick-up events have been held in nearby Orondo from 1998 to 2005. A 

total of 34,627 pounds of pesticides were collected and 248 pounds of DDT 

were brought in. Totals on the amount of DDT returned are not currently 

available for two Orondo pick-up events in 2004 and 2005. 

Page 28 Lake Chelan Watershed DDT and PCB TMDL
Chelan County held an event on October 17, 2005. A total of 2,000 pounds 

of pesticides were turned in. The Lake Chelan Water Quality Committee 

coordinated an event on October 19, 2005. A total of 5,500 pounds of 

pesticides were collected. Totals on the amount of DDT returned are not 

currently available for these collections. 

The Lake Chelan Water Quality Committee will continue to work with the 

USDA Waste Pesticide Program and hold more pick-up events to reduce 

the potential for inappropriate disposal or accidental loss and/or 

catastrophic loss of pesticides, PCBs, and other chemicals in the 

watershed. 

H. Transformer Recycling: The Chelan PUD and National Park Service 

conducted collection and disposal efforts on PCB transformers around 

Lake Chelan during the 1970s. The Lake Chelan Reclamation District 

worked with Chelan PUD in 2003 and 2005 to recycle nine of its irrigation 

system’s electrical transformers containing PCBs, at a cost to the LCRD of 

$450,000. The old transformers were trucked to a certified recycling center 

in Phoenix, AZ and Chelan PUD provided technical assistance by 

acquiring and installing the new PCB-free transformers for the LCRD. 

Electrical transformers containing PCBs and contaminated soils identified 

at the old Stehekin power station and a Manson orchard have been cleaned 

up. Continuing education and awareness, pick-up programs, and technical 

assistance will be implemented in the watershed to address this issue. 

6. Recommendation: Load reductions of target contaminants could occur just 

prior to discharge through developed wetland treatment, if and where 

feasible. Developed wetlands may be one of the few treatment options 

available for reducing total DDT. Data from the Joe Creek site in the Lake 

Chelan Reclamation District study (Burgoon and Cross, 2000) and data from 

the Wapato Lake + Joe Creek site from this TMDL study suggest loads of total 

DDT may be reduced through wetlands. 

Actions: A wetland plan will be developed and implemented to construct 

wetlands. Sites that have thus far been identified as good locations for 

constructed wetlands include: 1) outlet area of Dry Lake, 2) Stink Creek 

drainage 3) Joe Creek drainage, and 4) Cooper drainage. Sites with the 

highest DDT loads include: 5) Keupkin Street drainage, 6) Buck Orchards 

drainage, and 7) Purtteman Creek drainage. Additional locations and means 

to filter DDT laden water will be researched. Locations will be prioritized 

and budgeted. Funding will be solicited. Implementation will be scheduled 

as funding becomes available. 

Lake Chelan Watershed DDT and PCB TMDL Page 29
7. Recommendation: An evaluation of total DDT concentrations in the water 

column from the Wapato basin should be conducted to better quantify spatial 

and temporal variations. 

Actions: The Lake Chelan Water Quality Committee is currently 

implementing a Centennial Clean Water grant through the Department of 

Ecology (Grant G0400274 - Lake Chelan TMDL Support Project). Further 

evaluation of DDT concentrations and movement in the water column is a 

tasked element of the grant. 

8. Recommendation: An evaluation of the importance of total DDT loading 

from groundwater to the Wapato basin should be conducted. 

Actions: The Lake Chelan Water Quality Committee will utilize its 

Centennial Clean Water grant (Grant G0400274 - Lake Chelan TMDL Support 

Project) to conduct monitoring and analysis to further characterize DDT 

loading into Lake Chelan from ground water. Future actions will be 

implemented based on the groundwater characterization. 

Table 12 lists a schedule of implementation actions and potential contributors for 

the Lake Chelan Watershed DDT, PCB, TMDL.

Table 12: TMDL Implementation Actions and Potential Contributors 

Implementation 

Action Item 

Potential Contributors 

2005-06 2007 2008-13 2013-18 2013 2018 2023 2028 2032 2037 2042 2047 2052 2055 

Early 

implementation 

actions 

LCWQC, LCRD, Jean Peterson, Ecology, City of 

Chelan, Chelan County, CDHD, WDOH, 

Chelan PUD, USFS, NPS 

X 

Complete DIP Ecology, LCWQC, EPA 

X 

Implement #1 

Mackinaw fish 

consumption 

advisory 

WDOH, CDHD, Ecology, LCWQC 

X 

Implement #2 

Prioritize DDT 

management 

Ecology, LCWQC, LCRD, CDHD, WDOH, City 

of Chelan, Chelan County, Chelan PUD, USFS, 

NPS 

X X 

Implement #3 

Monitor fish and 

sediment 

Ecology, LCWQC, WDFW, Chelan PUD, 

WDOH, CDHD 

X X X X X X X X X X X X X 

Implement #4 

Monitor natural 

attenuation and 

BMPs 

Ecology, LCWQC 

X X X X X X X X X X X X X 

Page 30 Lake Chelan Watershed DDT and PCB TMDL
Implementation Potential Contributors 

2005-06 2008-13 2013-18 

Action Item 

2007 2013 2018 2023 2028 2032 2037 2042 2047 2052 2055 

Implement #5 

Control pollutant 

loading 

Ecology, LCWQC, LCRD, City of Chelan, 

Chelan County, Chelan PUD, USFS, NPS, 

WSDA 

X X 

Implement #6 

Develop and 

implement a 

wetland plan 

Ecology, LCWQC, LCRD, City of Chelan, 

Chelan County, Chelan PUD, USFS, NPS 

X X 

Implement #7 

Evaluate DDT in 

the water column 

Ecology, LCWQC, Chelan PUD 

X X 

Implement #8 

Evaluate DDT 

loading from 

ground water 

Ecology, LCWQC, Chelan PUD 

X X 

Collect data 

associated with 

actions and 

compliance points 

Ecology, LCWQC, LCRD, City of Chelan, 

Chelan County, Chelan PUD, USFS, NPS, 

WSDA 

X X X X X X X X X X X X X 

Review targets and 

data 

Ecology, LCWQC 

X X X X X X X X X X X X X 

Implement 

adaptive 

management 

changes 

Ecology, LCWQC, LCRD, City of Chelan, 

Chelan County, Chelan PUD, USFS, NPS, 

X X X X X X X X X X X X 

Water Quality 

standards met 

X 

BMPs - Best Management Practices 

CDHD - Chelan-Douglas Health District 

DIP - Detailed Implementation Plan 

DNR - Washington Department of Natural Resources 

Ecology - Washington State Department of Ecology 

LCRD - Lake Chelan Reclamation District 

LCWQC - Lake Chelan Water Quality Committee 

NPS - National Park Service 

USFS - United States Forest Service 

WSDA - Washington State Department of Agriculture

Lake Chelan Watershed DDT and PCB TMDL Page 31
Compliance with Water Quality Standards 

Ecology is the responsible entity for determining compliance of interim and final 

targets associated with the Lake Chelan Watershed DDT and PCB TMDL. 

The goal of the TMDL is to meet the state’s water quality standards, specifically 

the National Toxics Rule (NTR) human health criteria for edible fish tissue, for 

total DDT, and total PCBs in Lake Chelan and Roses Lake. The specific 

numerical targets are 32 μg/Kg for total DDT and 5.3 μg/Kg for total PCBs in 

edible fish tissue. A percent reduction approach in fish tissue contaminant 

concentrations will be used for meeting the above targets, rather than a 

requirement to meet the specific load allocations. These target concentrations are 

expected to be reached by the 2055. 

In addition to the fish tissue target, a water quality target concentration of 1.0 

ng/L will be applied to tributaries and drains discharging to Lake Chelan and 

Roses Lake to assure that when tissue targets are eventually attained, they are 

not compromised by degrading inputs. 

Table 13 details the percent reductions of total DDT and total PCB concentrations 

in fish tissue from Lake Chelan, Wapato Basin and Roses Lake that are required 

by the Lake Chelan Watershed DDT and PCB TMDL. 

Table 13: Total DDT and Total PCB Percent Reduction Targets in Fish Tissue for Lake Chelan 

and Roses Lake 

Water Body Parameter Formula % Reduction 

Required 

Lake Chelan, Wapato Basin DDT [(943 μg/Kg – 32 μg/Kg)/(943 μg/Kg)] x 100 96.6 

Lake Chelan, Wapato Basin PCB, [(14.5 μg/Kg – 5.3 μg/Kg)/(14.5 μg/Kg)] x 100 63.4 

Roses Lake DDT [(96 μg/Kg – 32 μg/Kg)/(96 μg/Kg)] x 100 66.7 

Page 32 Lake Chelan Watershed DDT and PCB TMDL
Reasonable Assurance 

Reasonable assurance is required only where point sources exceed the water 

standards, and therefore non-point sources must be consistently reduced in order 

to compensate for any such exceedances. Because this is not the case in the Lake 

Chelan watershed, reasonable assurances are not required. However, with the 

implementation actions identified in this TMDL, funding, ongoing monitoring, 

and adaptive management, Ecology and the Lake Chelan Water Quality 

Committee can provide reasonable assurance that non point source goals will be 

achieved within the timeline proposed in Table 12. 

Adaptive Management 

The implementation activities related to the Lake Chelan Watershed DDT and PCB 

TMDL are centered on the maintenance and improvement of long-term activities 

that have reduced water contamination levels since the banning of DDT and 

PCBs. The inclusion of long-term data collection and monitoring of fish tissue in 

the implementation activities is necessary due to the persistent nature of these 

legacy pollutants. Monitoring activities will serve to better define the rate that 

the water quality in the basin is improving. Re-evaluation of the long-term 

trends with additional data will allow the restoration timeframe to be 

determined with greater precision. If the water quality monitoring activities 

show unexpected long-term increases of DDT and PCBs in fish tissues, an 

examination of any potential new sources should also be undertaken. 

Additionally investigation should be conducted to identify significant events in 

the watershed that could resuspend sediments. 

Persistent elevated values of total DDT and total PCB contamination, or data that 

does not show the expected gradual declines over time, will trigger additional 

investigation. This should include, but not be limited to, further the 

investigations of tributary streams and potential groundwater transport of DDT. 

Implementation of the Lake Chelan Watershed DDT and PCB TMDL will be 

adaptively managed such that actions will be completed by 2018, and Lake 

Chelan, Roses Lake and their tributaries will meet the TMDL water quality 

targets by 2055. Adaptive management methods that may be used to implement 

this TMDL include: 

• Adjusting non-point best management practices; 

• Modifying stream sampling frequency and/or locations to further 

delineate DDT and PCB sources; 

• Conducting site specific inspections in identified source areas; 

Lake Chelan Watershed DDT and PCB TMDL Page 33
• Helping develop and fund water quality projects that address DDT 

and PCB pollution; 

• Local educational initiatives; and 

• Other means of conforming management measures to current 

information on the impairment. 

The requirements of the Lake Chelan Watershed DDT and PCB TMDL will be 

satisfied when adequate sampling is attained that shows that TMDL targets are 

being met after successful voluntary implementation of BMPs. If water quality 

standards are met without attaining the load allocation reductions specified in 

Table 11, then the objectives of the TMDL are met and no further reductions are 

needed. If the load allocation reductions in Table 10 and 11 are met, but the 

water bodies still do not meet TMDL targets, then adaptive management 

methods listed in the paragraph above, and any others, may be further employed 

to meet the objectives of the TMDL. Re-evaluation of the status of the TMDL will 

be conducted every five years. 

TMDLs are living documents, which are intended to be revisited periodically to 

evaluate whether the measures to implement the needed reductions are 

achieving targets, and to be revised as conditions change and understanding of 

the problems in the watershed is broadened. Through implementation of the 

Lake Chelan Watershed DDT and PCB TMDL, participants will learn what actions 

will be needed to achieve the TMDL’s targets. After all appropriate and practical 

BMPs have been implemented, then the TAC and Ecology will jointly re-evaluate 

whether or not the targets have been met, and how best to proceed. 

On-going ambient monitoring conducted by Ecology and local entities will assist 

in enabling the implementing jurisdictions to revise and shift implementation 

efforts as necessary in order to bring all tributaries back into compliance with 

TMDL targets. Ecology encourages local organizations and governments to apply 

for grant funding for developing and implementing monitoring programs 

through Ecology’s annual water quality grants program. 

A Detailed Implementation Plan (DIP) will be prepared within one year 

following approval by EPA of this submittal report. Further public input will be 

sought to help prepare the plan. The plan will identify in more detail how, 

when, and where the activities listed in this plan will be implemented. Ecology 

and other entities will provide technical assistance and seek additional funding 

for these monitoring activities and any restoration activities that may be 

identified as the body of data grows. Milestones will be developed as part of the 

DIP and milestone evaluation is anticipated to occur at three to six-year intervals. 

Page 34 Lake Chelan Watershed DDT and PCB TMDL
Summary of Public Involvement 

A citizen’s workgroup, the Lake Chelan Water Quality Committee, has served 

since 2001 as the Technical Advisory Committee (TAC) for the Lake Chelan 

Watershed DDT and PCB TMDL. Participants represented in the TAC include 

agriculture, conservation districts, irrigation districts, local government, sewer 

districts, utility districts, state and federal agencies, community organizations, 

and other interested parties. This workgroup met numerous times during the 

development of the TMDL. There is a high level of cooperation and 

communication between project participants, and their continued active pursuit 

of the goals of the TMDL. 

The following education/outreach information was provided to the community 

(see Appendix B): 

* September - October, 2002 News coverage on EPA National DDT fish tissue 

study results regarding Lake Chelan and follow-up responses with media 

and the public. The news release resulted in several newspaper articles and 

radio interviews. 

* June, 2003 - “DDT and Lake Trout” brochure distributed by Chelan-Douglas 

Health District. Brochures were distributed at health clinics and other 

locations. 

* Various dates - Other media coverage related to the Lake Chelan TMDL. 

Brochures developed and distributed on boating practices and environmental 

landscaping. 

* September, 2005 - News release and coverage on results of monitoring 

study, TMDL allocations, and continuation of public health notice on 

mackinaw consumption. 

* January, 2006 - News release and media coverage on continuation of Lake 

Chelan fish consumption advisory for mackinaw by the Department of 

Health. 

* February, 2006 - Department of Ecology Environmental Excellence awards 

issued to Paul Cross and Jean Peterson for PCB transformer removal efforts. 

The public comment period for this TMDL Submittal occurred from April 21, 

2006 to May 21, 2006. See comments, responses, and public notice newspaper 

display ads (and affidavits of publication) in Appendix B. 

Lake Chelan Watershed DDT and PCB TMDL Page 35
Monitoring Strategy 

Monitoring is included as part of the implementation strategy. It serves to track 

and evaluate the effectiveness of implementation measures. Ecology, the Lake 

Chelan Reclamation District, and the Chelan County Conservation District 

(CCCD) have conducted various monitoring of the waters in the Lake Chelan 

watershed as previously described in this report. Such data has been helpful for 

identifying specific water quality problem areas. 

While DDT and PCBs continue to persist in the environment their effective levels 

are reduced over time through implementation actions, degradation, and by 

natural attenuation through dilution and capping. The natural processes 

resulting in the lower exposure of aquatic life to the pollutants will play a major 

role in the success of the Lake Chelan Watershed DDT and PCB TMDL. The Lake 

Chelan Water Quality Committee, funded through a Centennial Clean Water 

grant (previously described), is currently engaged in continued monitoring. 

Ongoing monitoring of the following areas is recommended, at least once every 

five years, using adaptive management from previously gained knowledge: 

o fish tissue concentrations 

o sediment 

o soils 

o surface water 

o groundwater 

o SIS and DIP implementation actions 

o Other human actions 

Potential Funding Sources 

Potential funding for implementation of the SIS, DIP, and ongoing monitoring 

for Lake Chelan TMDL may be accomplished with project funding provided 

through the Department of Ecology. The Centennial Clean Water Fund, Section 

319 grants under the federal Clean Water Act, and state Revolving Fund (SRF) 

loans comprise the current funding sources available. Ecology can provide 

technical assistance to Lake Chelan watershed stakeholders in applying for 

available grant and loan funds to implement this TMDL. Opportunities for the 

community to apply for external funding sources will also be explored and 

encouraged, including the following sources: 

WSDA: Funding for the Washington Department of Agriculture’s waste 

pesticide pickup program is currently sustained through Department of 

Page 36 Lake Chelan Watershed DDT and PCB TMDL
Agriculture. The benefits of such a program to water quality are direct but 

difficult to quantify as it is a preventative program. 

EQIP: The Natural Resources Conservation Service (NRCS) directs its 

Environmental Quality Incentives Program (EQIP). EQIP provides technical, 

educational, and financial assistance to eligible farmers and ranchers to 

address soil, water, and related natural resource concerns on their lands in an 

environmentally beneficial and cost-effective manner. The program is 

implemented through conservation plans that include structural, vegetative, 

and land management practices, and also includes nutrient management 

plans. Cost-share payments may be made to implement one or more eligible 

structural or vegetative practices, such as livestock exclusion fencing, riparian 

buffer zones (strips), tree planting, and permanent wildlife habitat. Incentive 

payments can be made to implement one or more land management practices, 

such as grazing management or nutrient management. 

CREP: The NRCS also sponsors the Conservation Reserve Enhancement 

Program (CREP) and the Continuous Conservation Reserve Program (CCRP), 

which are voluntary cost share programs designed to restore and enhance 

habitat and increase bank stability along waterways on private lands with a 

cropping history. The prior program offers payments for annual rental, 

signing, cost share, practice, and maintenance in exchange for removing land 

from production and grazing. The latter program provides funds for 

providing a sediment filtration around water sources near crop fields, such as: 

filter strips, riparian buffers, and grass waterways. 

CCCD: The Chelan County Conservation District provides technical 

assistance and cost-share programs to irrigators and ranchers, including 

riparian restoration, fencing, farm plans, sprinkler conversion projects, etc., 

which helps keep soil on-farm and reduce DDT in agricultural runoff water. 

FREP: Because most of the tributaries in the Lake Chelan watershed are 

categorized as Class AA and considered as critical salmon habitat, state and 

federal salmon restoration efforts and associated funding should support 

implementation under this TMDL. For example, the Washington State 

Legislature has authorized the creation of a Small Forest Landowner Office to 

provide technical assistance, develop standards for forest practice alternative 

plans, and administer a Forestry Riparian Easement Program (FREP). The 

FREP is a compensation program intended to partially compensate qualifying 

small forest landowners for leaving forest and fish riparian management zones 

in exchange for a fifty-year easement. The purpose of the program is to 

provide an incentive to small forest landowners to keep their lands in forest 

use. 

Lake Chelan Watershed DDT and PCB TMDL Page 37
Chelan PUD: Chelan PUD has funding available through its FERC relicensing 

agreement and other sources. The Lake Chelan Water Quality Committee will 

work with Chelan PUD to identify and utilize appropriate PUD funding. 

BPA, EPA, other sources: The Lake Chelan Water Quality Committee will 

work with BPA, EPA, and other sources to identify and utilize appropriate 

funding as it becomes available. 

References Cited 

Ecology. (2002) Guidance Document for Developing Total Maximum Daily Loads 

(TMDLs): Water Cleanup Plans. Publication Number 99-23-WQ. Revision of 

the original 1999 publication. 

Ecology, R. Coots. (2003) Quality Assurance Project Plan, Total Maximum Daily Load 

Study, DDT and PCBs in Lake Chelan. Publication Number 03-03-105 

Ecology, R. Coots. (2005) Lake Chelan DDT and PCBs in Fish Total Maximum daily 

Load Study. Publication Number 05-03-014 

Ecology. (2006) Water Quality Program Financial Assistance Fiscal Year 2007 

Funding Cycle Public Workshops 

Hopkins, B. and D. Clark. (1985) Basic Water Monitoring Program – Fish Tissue and 

Sediment Sampling for 1984. Washington State Department of Ecology, 

Olympia, Washington. Publication Number 85-7. 

Patmont, C., G. Pelletier, E. Welch, D. Banton, and C. Ebbesmeyer. (1989) Lake 

Chelan Water Quality Assessment. Prepared by Harper-Owes for the 

Washington State Department of Ecology, Olympia, Washington. 

Publication Number 89-e37. 

Serdar, D.A., A. Johnson, and D. Davis. (1994) Survey of Chemical Contaminants in 

Ten Washington Lakes. Washington State Department of Ecology, Olympia, 

Washington. Publication Number 94-154. 

Cross P., Burgoon P. Lake Chelan Reclamation District (2002-2004). DDT and 

Phosphorous Movement in the Manson Lakes Drainage Basin. 

Washington State Department of Ecology Grant Number G0200114. 

Cross P., Lake Chelan Reclamation District. (1998) Water Quality Trends and 

Characteristics of Agricultural Drains. Washington State Department of 

Ecology Central Regional Office Publication Number WQ 3.6250-02 

CR983156. 

Page 38 Lake Chelan Watershed DDT and PCB TMDL
R.W. Beck, (1991) Lake Chelan Water Quality Plan. Washington State Department of 

Ecology, Central Regional Office. Publication Number WQ 3.4000-70 

CR971802. 

USEPA. (1991) Guidance for water Quality-based Decisions: The TMDL Process. 

April 1991. EPA 444/4-91-001. 

USEPA. (1997) Memorandum of Agreement between the United States 

Environmental Protection Agency and the Washington State Department 

of Ecology Regarding the Implementation of Section 303(d) of the Federal 

Clean Water Act. 

USEPA. (1998) Report of the Federal Advisory Committee on the Total 

Maximum daily Load (TMDL) Program. The National Advisory Council 

for Environmental Policy and Technology (NACEPT). US Environmental 

Protection Agency, Office of the Administrator. EPA 100-R-98-006. 

USEPA. (1999b) Protocol for Developing Sediment TMDLs. EPA-841-B-99-004. 

Office of Water (4503-F), US Environmental Protection Agency. Washington, 

D.C. 

Lake Chelan Watershed DDT and PCB TMDL Page 39
Page 40 Lake Chelan Watershed DDT and PCB TMDL
Appendix A 

“Lake Chelan DDT and PCBs in Fish 

Total Maximum Daily Load Study” 

June 2005 

Ecology Publication Number 05-03-014 

This publication may be viewed at the following website: 

www.ecy.wa.gov/biblio/0503014.html

Paper copy may be obtained upon request. 

Lake Chelan Watershed DDT and PCB TMDL Page A-1
Page A-2 Lake Chelan Watershed DDT and PCB TMDL
Appendix B 

Education and Outreach Materials, News Coverage 

(Paper copies are available upon request) 

May, 2002 – EPA national lakes study finds high levels of DDT in Lake Chelan 

fish tissue. Lake Chelan Water Quality Committee begins work with Ecology 

on DDT, PCB TMDL. 

May, 2003 – Ecology Focus Sheet published and distributed, “Lake Chelan 

DDT/PCB Watershed Cleanup Plan.” 

June, 2003 - DDT and Lake Trout brochure distributed by Chelan-Douglas Health 

District. Brochures distributed at health clinics and other locations (brochure 

updated in 2006). 

May, 2004 – Lake Chelan Mackinaw (Lake Trout) fishing derby. Fish caught in 

the derby are included in TMDL fish tissue sampling. 

August, 2004 – Ecology Focus Sheet, Lake Friendly Landscaping distributed. 

August, 2005 – News release and coverage on completion of the TMDL technical 

study. 

September, 2005 - Department of Health advises people to limit the amount of 

Mackinaw (lake trout) consumption from Lake Chelan. 

January, 2006 – Department of Health issues statewide fish consumption 

advisory and updated brochure, including consumption of Lake Chelan 

Mackinaw (lake trout). 

March 13, 2006 – Ecology presents its Environmental Excellence Award to locals for 

cleaning up Lake Chelan PCBs. 

April 21 – May 21, 2006 – Ecology issues news release and newspaper display 

ads for public notice and 30-day comment period on Draft Lake Chelan DDT, 

PCB TMDL Submittal. 

Lake Chelan Watershed DDT and PCB TMDL Page B-1
Page B-2 Lake Chelan Watershed DDT and PCB TMDL 
Appendix C 

TMDL Public Notice, 

Public Comments and Responses 

PUBLIC NOTICE

A public notice was printed in the following newspapers: 

Newspaper Issue Dates

Chelan Mirror - April 26 and May 3, 2006 

Wenatchee World - April 21, 2006 

Cashmere Record - April 26 and May 3, 2006 

Leavenworth Echo - April 26 and May 3, 2006 

DEPARTMENT OF ECOLOGY 

Seeks comments on the Draft Water 

Cleanup Plan for DDT and PCBs in 

the Lake Chelan Watershed 

The Department of Ecology has drafted a water cleanup plan (TMDL), 

for DDT and PCBs in the Lake Chelan Watershed. The plan 

recommends actions to reduce DDT and PCBs in order to meet state 

water quality standards and protect aquatic habitat. We appreciate 

your interest in improving water quality in the Lake Chelan watershed. 

 Public comment period: April 21 through May 21 -

How you can review the draft Water Quality Improvement Plan: 

• Ask for a reserve copy at the Chelan Community Library 

• Online copy at http://www.ecy.wa.gov/biblio/0610022.html

• Call (509) 454-7894 to have a printed copy mailed to you 

There will be a presentation on these efforts followed by a question 

and answer period. Various state and local officials and other 

professionals will be present at the meeting. 

Public Workshop

Thursday, May 4th 

6:30 – 8:30 pm 

City of Chelan, Council Chambers 

135 E. Johnson 

Chelan, WA 98816 

Please send written comments by May 21, 2006 to David Schneider, 

Dept. of Ecology, 15 W. Yakima Ave, Suite 200, Yakima WA 98902, 

or email dasc461@ecy.wa.gov.

For more information please call David Schneider at (509) 454-7894 If you have

Lake Chelan Watershed DDT and PCB TMDL Page C-1 
Additionally, an Ecology news release was issued to all media outlets 

in Chelan County. 

FOR IMMEDIATE RELEASE – April 18, 2006 

06-060 

Lake Chelan water cleanup plan available for review

YAKIMA – A draft plan outlining ways to clean up Lake Chelan is 

available for review and comment from the Washington Department of Ecology. 

 Legacy affects from the historical use of the pesticide DDT and residual 

PCBs from electric transformers are water-quality concerns that have been 

identified in Lake Chelan. The plan drafted over the last several years 

recommends actions to improve water quality in order to meet state water quality 

standards and protect aquatic habitat. 

 There will be a workshop on Lake Chelan water quality efforts on May 4, 

from 6:30 to 8:30 p.m. at the City of Chelan Council Chambers, 135 East 

Johnson. There will be a presentation on these efforts, followed by a question and 

answer period. Various state and local officials and others will be present at the 

meeting. 

 A copy of the plan is available online at 

www.ecy.wa.gov/biblio/0610022.html. To request a copy, call (509) 454-7894. 

Comments should be mailed to David Schneider, Dept. of Ecology, 15 W. 

Yakima Ave., Suite 200, Yakima, WA 98902; or by email to 

dasc461@ecy.wa.gov. Comments will be accepted through May 21. 

# # #

Contact: Joyce Redfield-Wilder, public information manager, (509) 575-2610, 

or pager (509) 574-0490

Ecology’s Web site: http://www.ecy.wa.gov/

Page C-2 Lake Chelan Watershed DDT and PCB TMDL 
PUBLIC COMMENTS

Lake Chelan Watershed DDT and PCB TMDL Page C-3 
Page C-4 Lake Chelan Watershed DDT and PCB TMDL 
ECOLOGY RESPONSE 

June 6, 2006 

Elizabeth A. Ellis 

Washington State Department of Natural Resources 

Aquatic Resources Program 

1111 Washington St SE 

PO Box 47027 

Olympia, WA 98504-7027 

Dear Ms. Ellis: 

Thank you for commenting on the Lake Chelan Watershed DDT and PCB Total Maximum Daily 

Load Water Quality Improvement Report. The following are responses to your comments: 

DNR Comment #1: Encourage Ecology to develop and refine an environmental fate and 

transport model. The mechanism of loading and transport for both contaminants is unknown. 

DNR supports Ecology’s recommendations to evaluate the potential contribution of total 

DDT/DDE from groundwater, and its transport through sediment, water, plants and aquatic biota. 

Until sources are identified, and the rate of environmental fate understood, recovery options and 

an associated timeline cannot be identified. 

Ecology Response, Comment #1: Ecology appreciates DNR support with our efforts in 

developing and refining an environmental fate and transport model. Work on this has 

already begun. Through an Ecology grant, the Lake Chelan Water Quality Committee 

has hired Geomatrix to develop a hydrologic characterization report, conduct preliminary 

groundwater monitoring, and develop a food web bioaccumulation model. Answers from 

these studies will help to further identify pollutant sources, fate and transport, and 

recovery options. 

DNR Comment #2: Develop detailed recovery options and timelines. Once sources are 

identified, and a fate and transport model developed, DNR encourages Ecology to aggressively 

pursue a variety of options for improving water quality, cleaning up sediment contamination, and 

reducing bioaccumulation. Natural attenuation, although the least costly, could take decades with 

DDT/DDE and PCBs. The safety of the public will need to be taken into account when 

considering cleanup options, not just cost. 

In summary, given that DNR issues use authorizations for activities involving water, it is 

imperative this agency has a clear understanding of the public health and safety issues associated 

with the aquatic land and water bodies, and the timelines for recovery. Please keep DNR 

informed of the status of the Lake Chelan watershed. 

Should Ecology need to coordinate with DNR for sediment sampling or other recovery-associated 

efforts on state aquatic land, please contact Cindi Preston at our Rivers District, (509) 933 3847 

x22. 

Lake Chelan Watershed DDT and PCB TMDL Page C-5 
Ecology Response, Comment #2: When this TMDL is submitted and approved by the 

Environmental Protection Agency (EPA), Ecology and the Lake Chelan Water Quality 

Committee (LCWQC) will use the TMDL, its technical report, and current fate and 

transport studies to develop a Detailed Implementation Plan (DIP) in one year. The DIP 

will specify and schedule a detailed list of activities to improve water quality, reduce 

sediment contamination, and prevent food web bioaccumulation of DDT and PCBs. 

Ecology will continue to work with DNR and the Lake Chelan watershed community to 

protect the safety of the public. 

Ecology has been in contact with Cindi Preston and Tim Goodman, and has encouraged 

them to attend LCWQC meetings as we move forward with this process. Ms. Preston has 

indicated that she will attend and participate. We look forward to working more closely 

with the DNR regarding DDT and PCB issues in Lake Chelan, and authorizations under 

its purview, such as state-owned aquatic lands, recreational docks, boat ramps, piers, and 

other water-dependant projects. 

Should you have any further questions or comments, please feel free to contact me at (509) 454-

7894. 

Sincerely, 

David Schneider 

Department of Ecology 

Water Quality Program 

cc: Cindi Preston, DNR Rivers District 

 Tim Goodman, DNR Sediment Quality Unit 

Page C-6 Lake Chelan Watershed DDT and PCB TMDL 
Appendix D 

Previous Studies 

and Recommendations 

Related to DDT and PCBs 

“DDT and Phosphorous Movement in the Manson Lakes Drainage Basin” 

(2004, Lake Chelan Reclamation District):

A. Improve hydraulic regime in effluent area of Manson Lakes to reduce 

velocities and improve effectiveness of existing wetlands. 

B. Construct additional wetland areas to enhance wetland treatment 

capacity. 

C. Install control structures in Dry and Roses Lake to reduce peak and spring 

flows through the lakes and into Stink Creek. 

D. Improve riparian corridors of Stink Creek and Joe Creek to reduce erosion. 

E. Convert available land in outlet area of Dry Lake to wetlands. 

F. Evaluate cost effectiveness of alum dosing in effluent from Roses and Dry 

Lakes to sequester TP in sedimentation ponds or wetlands. 

G. Evaluate cost effectiveness of alum addition to the lakes to reduce mixing 

and diffusion of TP from sediment into the water column. 

H. Implement a Lake Management Plan, including future residential 

development 

“Water Quality Trends and Characteristics of Agricultural Drains” (1998, Lake 

Chelan Reclamation District): 

Toxic substances and pesticides were found in all eight drains. As technology 

advances, it would be useful to consider structural alternatives to treat the drain 

water some or all of the time. A study of the potential for constructed wetlands 

or small packaged treatment plants to treat a background level of water would 

be of interest. The fact that all of the drains are influenced by storm water runoff 

would require the bypassing of some of the water during larger hydrologic 

events. 

Lake Chelan Watershed DDT and PCB TMDL Page D-1 
“Lake Chelan Water Quality Plan” (1991, R.W. Beck): 

(1) Adoption of consistent clearing, grading, and drainage plan ordinances 

for the entire Lake Chelan basin. 

(2) Adoption of rigid design standards for all new drainage facilities using 

either the Department of Ecology manual or the King County manual as 

revised by the City of Chelan. 

(3) Preparation of a comprehensive drainage plan for the lower Lake Chelan 

Basin. 

Chelan PUD, Lake Chelan Dam, Federal Energy Commission Relicensing and 

401 Certification process (2005, Dept. of Ecology): 

Erosion: U.S. Forest Service (USFS) erosion control, National Park Service (NPS) 

erosion control, NPS Stehekin area implementation plan, large woody debris 

management plan. 

Fisheries: Comprehensive fish management plan, food web model, fish creel 

survey, water quality monitoring plan, funding for bull trout recovery plan, fish 

stocking, collection and stocking of fish eggs, tributary barrier improvements. 

Chelan River Comprehensive Management Plan: Minimum flows, Chelan River 

temperature, flow security (flows in tailrace during non-power operation), 

tailrace and Reach 4 habitat improvements, and lake level management. 

Wildlife Habitat Plan: Wildlife habitat restoration, upland habitat 

improvements, riparian habitat improvements, conservation easements. 

Recreation Resources: Docks and recreation facilities (USFS and NPS), operation 

and maintenance of Riverwalk, Old Mill, and Manson Bay parks, Reach 1 access 

trail, Riverwalk trail loop extension, operation and maintenance under Don 

Gordon bridge, reservation of lands, micro parks, utility improvements for local 

trail, trail linkage to PUD parks, Don Morse Park erosion, community recreation 

fund. 

Cultural Resources: Public education, consultation, cultural resources 

management, survey of the Lake Chelan National Recreation Area, site 

protection.

Page D-2 Lake Chelan Watershed DDT and PCB TMDL