west virginia department of environmental protection

West Virginia Department West Virginia Department of Environmental of Environmental

ProtectionProtection

August 12, 2014

Kanawha City Office

Upper Kanawha Tributary Upper Kanawha Tributary WatershedsWatersheds

TMDL Status Update MeetingTMDL Status Update Meeting

AgendaAgenda

““Introduction to TMDLs” recapIntroduction to TMDLs” recap Overview of TMDL Project & Overview of TMDL Project &

StatusStatus Overview of Allocation Strategies Overview of Allocation Strategies Discussion – Free form questions Discussion – Free form questions

and answers and answers

What’s a TMDL?What’s a TMDL? ““Total Maximum Daily Load” Total Maximum Daily Load”

How much pollutant a stream can How much pollutant a stream can receive and remain healthyreceive and remain healthy

Pollution Budget - prescribes reductions Pollution Budget - prescribes reductions (where needed) of pollutants that result (where needed) of pollutants that result in the restoration of an impaired stream in the restoration of an impaired stream

TMDL development required by TMDL development required by Clean Water Act for streams Clean Water Act for streams impaired by a pollutantimpaired by a pollutant

TMDL = TMDL = WLA + WLA + LA + MOS LA + MOS

= “sum of”= “sum of” WLA = “wasteload WLA = “wasteload

allocations” allocations” LA = “load LA = “load

allocations”allocations” MOS = “margin of MOS = “margin of

safety” safety”

WLAs - pollutant loads WLAs - pollutant loads from “point sources” from “point sources” Discharge from pointDischarge from point Need NPDES permitNeed NPDES permit

LAs - pollutant loads LAs - pollutant loads from “nonpoint sources” from “nonpoint sources” and backgroundand background Precipitation/runoff Precipitation/runoff

drivendriven No permit requiredNo permit required

What’s an impaired stream?What’s an impaired stream? Stream that doesn’t meet Stream that doesn’t meet water quality standardswater quality standards

West Virginia Water Quality Standards are codified in 47 West Virginia Water Quality Standards are codified in 47

CSR 2CSR 2 http://www.dep.wv.gov/WWE/Programs/wqs/Documents/http://www.dep.wv.gov/WWE/Programs/wqs/Documents/

Rules/WVDEP_47CSR2_WQS_FinalRule%206_27_2011.pdfRules/WVDEP_47CSR2_WQS_FinalRule%206_27_2011.pdf

Standards include “Designated UsesStandards include “Designated Uses“

for WV waters and “water quality criteria”for WV waters and “water quality criteria”

to protect those usesto protect those uses

Criteria can be numeric or narrativeCriteria can be numeric or narrative

Impaired streams are enumerated on the 303(d) listImpaired streams are enumerated on the 303(d) list

West Virginia Section 303(d) List / Integrated Report

Numeric Criteria of ConcernNumeric Criteria of Concern

Total IronTotal Iron Aquatic Life/Public Water SupplyAquatic Life/Public Water Supply Not to exceed 1.5 mg/l as a 4 day average Not to exceed 1.5 mg/l as a 4 day average

concentration more than once in a three year concentration more than once in a three year period period

Public Water Supply - 1.5 mg/l Public Water Supply - 1.5 mg/l

Fecal ColiformFecal Coliform Water Contact Recreation/Public Water SupplyWater Contact Recreation/Public Water Supply Shall not exceed 200 counts/100ml as a monthly Shall not exceed 200 counts/100ml as a monthly

geometric mean (5 samples/month) geometric mean (5 samples/month) Nor to exceed 400 counts/100 ml in more than 10% Nor to exceed 400 counts/100 ml in more than 10%

of samples in a monthof samples in a month


Dissolved AluminumDissolved AluminumAquatic LifeAquatic LifeNot to exceed 750 ug/l as a 1 hour average Not to exceed 750 ug/l as a 1 hour average concentration more than once in a three year concentration more than once in a three year periodperiodNot to exceed 750 ug/l as a 4 day average Not to exceed 750 ug/l as a 4 day average concentration more than once in a three year concentration more than once in a three year period period

pHpHAquatic Life/Water Contact Recreation/Public Aquatic Life/Water Contact Recreation/Public Water Supply (All Uses)Water Supply (All Uses)No values below 6.0 nor above 9.0.No values below 6.0 nor above 9.0.

Numeric criteria of concernNumeric criteria of concern

ChlorideChloride Aquatic Life/Water Contact Recreation/Public Aquatic Life/Water Contact Recreation/Public

Water SupplyWater Supply Not to exceed 230 mg/l as a 4 day average Not to exceed 230 mg/l as a 4 day average

concentration more than once in a three year concentration more than once in a three year period period

Total ManganeseTotal Manganese Public Water SupplyPublic Water Supply Not to exceed 1.0 mg/l within a 5 mile zone immediately Not to exceed 1.0 mg/l within a 5 mile zone immediately

upstream of a water supply used for public or private upstream of a water supply used for public or private consumptionconsumption


SeleniumSelenium Aquatic Life/Public Water SupplyAquatic Life/Public Water Supply Not to exceed 20 ug/l as a 1 hour average Not to exceed 20 ug/l as a 1 hour average

more than once in a three year period more than once in a three year period Not to exceed 5 ug/l as a 4 day average Not to exceed 5 ug/l as a 4 day average

concentration more than once in a three concentration more than once in a three year periodyear period

Public Water Supply - 50 ug/l Public Water Supply - 50 ug/l

Narrative CriteriaNarrative CriteriaPrevious 47 CSR 2 - 3.2.i AssessmentPrevious 47 CSR 2 - 3.2.i Assessment

Based on Benthic Macroinvertebrates (aquatic bugs)Based on Benthic Macroinvertebrates (aquatic bugs)

Stream scored based on abundance and type of bugs Stream scored based on abundance and type of bugs

presentpresent

Streams with impaired communities were placed on Streams with impaired communities were placed on

the 303(d) list and slated for TMDLsthe 303(d) list and slated for TMDLs

Narrative CriteriaNarrative Criteria2012 Legislative Changes2012 Legislative Changes

Senate Bill 562 passed by the 2012 West Virginia Senate Bill 562 passed by the 2012 West Virginia Legislature amended the WV Water Pollution Control Act Legislature amended the WV Water Pollution Control Act

Requires DEP to develop and secure legislative approval of Requires DEP to develop and secure legislative approval of new rules to interpret 47 CSR 2-3.2.inew rules to interpret 47 CSR 2-3.2.i

Section 22-11-7b : Section 22-11-7b : http://www.legis.state.wv.us/wvcode/ChapterEntire.cfm?http://www.legis.state.wv.us/wvcode/ChapterEntire.cfm?chap=22&art=11chap=22&art=11

No biological TMDLs are part of this effortNo biological TMDLs are part of this effort Streams currently listed as biologically impacted will Streams currently listed as biologically impacted will

undergo Stressor Identification processundergo Stressor Identification process

Stressor Identification ProcessStressor Identification Process

Method to evaluate stressor/s of Method to evaluate stressor/s of biologically impacted streamsbiologically impacted streams

Process used to evaluate if numeric criteria Process used to evaluate if numeric criteria TMDLs (iron, fecal) will address biological TMDLs (iron, fecal) will address biological stressorsstressors

Information will be retained and may be Information will be retained and may be used to delist streams in the futureused to delist streams in the future

Impaired WatersImpaired Waters

43 43 named streams in Upper Kanawha watershed, named streams in Upper Kanawha watershed,

Mainstem Kanawha not part of this effortMainstem Kanawha not part of this effort

TMDL Watersheds

MDAS ModelMDAS Model

Watershed Model Watershed Model Runs dynamically on a 1-hour time stepRuns dynamically on a 1-hour time step Represents land use (hydrologic Represents land use (hydrologic

processes) and river processesprocesses) and river processes Can include nonpoint and point sourcesCan include nonpoint and point sources Streambank Erosion component - Bank Streambank Erosion component - Bank

Pin StudyPin Study

Modeling ApproachModeling Approach Segment watershedSegment watershed Configure model to represent all sources Configure model to represent all sources Calibrate model for hydrology (flow) and water Calibrate model for hydrology (flow) and water

qualityquality MetalsMetals

Iron Iron Dis. AluminumDis. Aluminum ManganeseManganese FecalFecal ChloridesChlorides pHpH SeleniumSelenium SedimentSediment

Run MDAS for Baseline conditions (existing)Run MDAS for Baseline conditions (existing) Run MDAS for TMDL scenario(s)Run MDAS for TMDL scenario(s)

Upper Kanawha WatershedUpper Kanawha WatershedProject StatusProject Status

Completed:Completed: Monitoring Monitoring

Source tracking Source tracking

Baseline Modeling Baseline Modeling

Bio. Stressor IdsBio. Stressor Ids

Status Update Status Update

MeetingMeeting

Next Steps:Next Steps:

AllocationsAllocations

Draft Document Draft Document

Public MeetingPublic Meeting

EPA ApprovalEPA Approval

Universal Reduction of targeted sourcesUniversal Reduction of targeted sources Streambank erosion, Failing Septics, etcStreambank erosion, Failing Septics, etc

Top-down approachTop-down approach

Headwater subwatersheds Headwater subwatersheds

analyzed firstanalyzed first

Allocation strategy dictates Allocation strategy dictates

order and magnitude of reductionorder and magnitude of reduction

If necessary, loads are reduced then routed If necessary, loads are reduced then routed to downstream subwatershedto downstream subwatershed

Allocation Methodology Allocation Methodology

WVDEP priorities:WVDEP priorities: Ensure criteria compliance at all sws outletsEnsure criteria compliance at all sws outlets Target the primary causative sourcesTarget the primary causative sources

Strategy in generalStrategy in general Critical conditions must be consideredCritical conditions must be considered Sometimes only one significant source in Sometimes only one significant source in

swssws Always some amount of professional Always some amount of professional

judgementjudgement

Allocation Methodology Allocation Methodology

Fecal Coliform SourcesFecal Coliform Sources Point sourcesPoint sources

HAUsHAUs Package Plants Package Plants Municipal Sewage PlantMunicipal Sewage Plant Mining BathousesMining Bathouses MS4 areasMS4 areas

Nonpoint sourceNonpoint source Failing septic systems and/or straight pipe Failing septic systems and/or straight pipe

illicit dischargesillicit discharges Stormwater runoff from urban/residential Stormwater runoff from urban/residential

landslands Stormwater runoff from agricultural landsStormwater runoff from agricultural lands

Fecal Coliform StrategyFecal Coliform Strategy

100% reduction of all untreated sewage 100% reduction of all untreated sewage discharges (failing septics, straight discharges (failing septics, straight pipes) as required by WV Bureau for pipes) as required by WV Bureau for Public Health regulationsPublic Health regulations

Sensitivity analysis to address severity Sensitivity analysis to address severity of agricultural vs. urban/residential of agricultural vs. urban/residential impacts impacts

Iron SourcesIron Sources Streambank erosionStreambank erosion Abandoned Mine Lands and seepsAbandoned Mine Lands and seeps Bond Forfeitures Lands and seepsBond Forfeitures Lands and seeps Upland Sediment SourcesUpland Sediment Sources

Harvested ForestHarvested ForestOil and GasOil and GasAgricultureAgricultureUrban Residential outside MS4 areasUrban Residential outside MS4 areasRoadsRoads

Active MiningActive Mining MS4 areasMS4 areas Construction Stormwater General PermitsConstruction Stormwater General Permits

Iron Allocation StrategyIron Allocation Strategy

Streambank erosion loadings reduced to best Streambank erosion loadings reduced to best available in watershedavailable in watershed

Sediment sources set to iron loadings equivalent Sediment sources set to iron loadings equivalent to 100 mg/l TSSto 100 mg/l TSS

Future growth for Construction Stormwater area Future growth for Construction Stormwater area initially allocated at 2.5% of subwatershed areainitially allocated at 2.5% of subwatershed area

AML seeps set to WQ criteria at dischargeAML seeps set to WQ criteria at discharge

Iron Allocation Strategy Iron Allocation Strategy continuedcontinued

Sensitivity Analysis based reductions, if Sensitivity Analysis based reductions, if neededneeded mining permits / bond fortfeiture reduced mining permits / bond fortfeiture reduced

below baselinebelow baseline sediment sources reduced below 100 mg/l TSSsediment sources reduced below 100 mg/l TSS Construction stormwater growth allowance Construction stormwater growth allowance

reducedreduced

Dissolved Aluminum/pH Sources and Dissolved Aluminum/pH Sources and StrategyStrategy

Horsemill Br, Sugarcamp Br, Cedar CrkHorsemill Br, Sugarcamp Br, Cedar Crk SourcesSources

AMLAML Active MiningActive Mining

StrategyStrategy Evaluate effects on pH and Al(d) of any Evaluate effects on pH and Al(d) of any

concurrent iron TMDLs being developed concurrent iron TMDLs being developed Add alkalinity to counter acid effects of AML Add alkalinity to counter acid effects of AML

seeps, and evaluate Al(d) attainmentseeps, and evaluate Al(d) attainment Sensitivity – increase alkalinity and/or Sensitivity – increase alkalinity and/or

reduce aluminum to attain both pH and reduce aluminum to attain both pH and Al(d) criteriaAl(d) criteria

Chloride Sources & StrategyChloride Sources & Strategy SourceSource

Certain permitted mining dischargesCertain permitted mining discharges

Reductions StrategyReductions Strategy Mining outlets – Mining outlets –

Reduce problematic point source discharges to Reduce problematic point source discharges to criteria at end of pipe (230 mg/l) criteria at end of pipe (230 mg/l)

Manganese Sources & Manganese Sources & StrategyStrategy

Horsemill Branch & Sugarcamp Branch Horsemill Branch & Sugarcamp Branch (Kelly Creek) are impaired for manganese (Kelly Creek) are impaired for manganese based on proximity to drinking water intakebased on proximity to drinking water intake

SourcesSources Bond Forfeiture Bond Forfeiture AML AML

StrategyStrategy AML seeps reduced to water quality at end of AML seeps reduced to water quality at end of

pipepipe Evaluate contribution from Bond Forfeiture sites Evaluate contribution from Bond Forfeiture sites

and reduce as necessaryand reduce as necessary

Selenium Sources and Selenium Sources and StrategyStrategy

SourcesSources Certain permitted mining dischargesCertain permitted mining discharges

StrategyStrategy Reduce discharges from instream Reduce discharges from instream

structures and large volume continuous structures and large volume continuous discharges to criteria discharges to criteria

Reduce on-bench outlets as necessary Reduce on-bench outlets as necessary to attain criteria at all subwatershedsto attain criteria at all subwatersheds

WVDEP TMDL Process (4 WVDEP TMDL Process (4 yrs)yrs)

Stream Selection - (4/2011)Stream Selection - (4/2011)

Pre-TMDL monitoring, source identification and Pre-TMDL monitoring, source identification and

characterization - (7/2011 – 6/2012)characterization - (7/2011 – 6/2012)

Contract to model water quality and hydrology – Contract to model water quality and hydrology –

(1/2013) (1/2013)

Determine baseline condition and allocate Determine baseline condition and allocate

pollutant loadspollutant loads

Draft Report developmentDraft Report development

Finalization and EPA approvalFinalization and EPA approval

Upper Kanawha Watershed Upper Kanawha Watershed TMDL Path ForwardTMDL Path Forward

Allocate loads and wasteloads and Allocate loads and wasteloads and develop draft reportdevelop draft report

Formal public comment period and Formal public comment period and public meeting on the draft TMDLs in public meeting on the draft TMDLs in Fall 2014Fall 2014

Address comments, prepare final draft Address comments, prepare final draft and submit to EPA for approval (final and submit to EPA for approval (final draft will include Response Summary)draft will include Response Summary)

Contact InformationContact Information

Comments should be submitted to Steve Young Comments should be submitted to Steve Young at [email protected] at [email protected] (10 meg limit for (10 meg limit for email)email)

Questions - contact Dave Montali, Jim Laine, Questions - contact Dave Montali, Jim Laine, Mike McDaniel Mike McDaniel (304) 926-0499(304) 926-0499 [email protected], [email protected],

[email protected], or [email protected], or [email protected]@wv.gov

Discussion/Discussion/Questions...Questions...