\rR-96-001_ _
                      '396
          Washington, DC 20460
ITOTiri
  14 TMDL
ment Cost
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                               TABLE OF CONTENTS
PARTI. STUDYOVERVIEW
  Purpose of the Study
  Study Approach
  Selection of TMDLs for Cost Estimation
  Development of a Data and Information Collection System
  Information Collection, Case Study Development, and Follow-up
  Presenting Cost Estimates in Fult-time Equivalents and Dollars
                                                                                     1
                                                                                     1
                                                                                     2
                                                                                     2
                                                                                     5
                                                                                     5
PART n. COST ESTIMATION APPROACH
PARTIIL COST SUMMARY
  Relationships Between Costs and TMDL Features
     Cost and m-House FTEs
     Cost and Watershed Size
     Cost and Model Complexity
     Cost and Pollutants
     Cost and Distribution of Point and Nonpoint Sources
     Cost and Public Participation
  Examination of TMDL Costs by Component
                                                                                     9
                                                                                     9
                                                                                    12
                                                                                    13
                                                                                    13
                                                                                   13
                                                                                    14
                                                                                    14
PART IV. FINDINGS
                                                                                   20
  Decision Factors for Amounts Spent on TMDL Development
  Relationship of TMDL to Other Water Quality Program Activities
  Cost Minimization Strategies
  Funding sources
.< Benefits   ''•-'-
                                                                                    20
                                                                                    21
                                                                                    21
                                                                                    22
                                                                                    22
PARTV. FEDERAL TMDL RESOURCES
                                                                                   23
  Availability of Funding
  TMDL Coordinators '
                                                                                   23
                                                                                   23
PART VI. TMDL CASE EXAMPLES
                                                                                   25
  Appoquinimink River
  Lake Chelan
                                                                                   26
                                                                                   32

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  Chenoweth Run
  Cobbossee Lake
  Delaware River Estuary
  Flint Creek
  Hillsdale Lake
  Little Deep Fork Creek
  Lower Minnesota River
  Oil Branch Creek
  South Fork Salmon River
  Sycamore Creek
  Truckee River
  Yankee Hill Lake
APPENDIX A
 39
 44
 50
 60
 67
 74
 84
 89
 93
 98'
105
113
117

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                          PARTI. STUDY OVERVIEW
        The U.S. Environmental Protection Agency's (EPA) Office of Water initiated this study
 to provide information on the costs  to  state and local water pollution  control agencies  of
 implementing requirements for development of total maximum daily loads (TMDLs). TMDLs
 were established under Section 303(d) of the Clean Water Act and EPA's Water Quality
 Planning and Management Regulations (40 CFR Part 130).  This study addresses the need for
 comprehensive information about costs associated with specific TMDL development activities.

 PURPOSE OF THE STUDY
              '••••.          •                          , '      '               -v
        The purpose of this study is two-fold:  to estimate development costs for a number of
 TMDLs through case examples; and to observe patterns from the case examples that help explain
 costs.  In  addition to presenting cost estimates, the study illustrates the range of activities
 involved in TMDL  development, representing a variety  of  budget sizes,  water quality
 impairments and geographic scales.  The study also identifies funding sources for each case
 example. Additionally, in cases where water quality managers were able to describe benefits of
 TMDLs, the study reports these benefits.

 STUDY APPROACH        -'    '_               -

        The study's  overall approach was to conduct an analysis of costs associated with TMDL
 development activities for. a number of state and local  water pollution control  entities.   This
 analysis was designed to  determine factors that affect TMDL development costs, as well  as
 funding sources that state and local water pollution control entities use1 for TMDL development:
 The components of the study methodology are:
    •   Selection of TMDLs for cost estimation;
    •   Development of a data collection protocol;
                                                              !
    •   Collection  and review of background documents,  including TMDL   case studies,
        summaries, and final reports, CWA Section 319 grant applications, USD A hydrologic.
        unit area (HUA) annual reports, and EPA mini-grant profiles;
  .  •.   In-depth telephone  interviews with regional EPA TMDL coordinators, participating state
        and local water  program directors, state grant coordinators, and other  program  staff
        including engineers, water quality specialists, modelers, and analysts;
    •   Development of TMDL case studies;
    •   Follow-up and review as necessary; and
'    •   Analysis of information and development of findings.

       .Given the unique nature of each TMDL, this study is intended to present a range of cost
 estimates across a  number of distinctive TMDLs.  It does not try to  extrapolate TMDL
 development costs  for broader programs or regions.  Rather, it  characterizes factors that
 contribute to cost differentials among individual TMDLs.
                                         Pagel

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SELECTION OF TMDLs FOR COST ESTIMATION

       A list of candidate TMDLs for cost estimation was compiled from existing EPA TMDL
case  studies,  listings  of TMDL/nonpoint  source  mini-grant  projects  (FY92-94),  and
conversations with regional EPA TMDL coordinators.   From this list, twenty TMDLs were
selected for cost estimation.  Those twenty make up a diverse sample, based on geographic
location, watershed size, pollutants,  and complexity.  As a result of quality of information and
time constraints, fourteen of the original twenty TMDL  case studies were completed for this
study.  TMDLs were selected for inclusion in the study based on the following considerations:
   •   Geographic Distribution - A study objective was to select two TMDLs in each  of the
       ten EPA regions. Not  all EPA regions, however,  could recommend candidate TMDLs,
       Instead,  the  study  selected  TMDLs that represented the  broadest possible  national
       distribution while meeting other selection criteria. Figure 1 is a map illustrating the
       geographic distribution of the 14 TMDLs for which case examples were developed.
   •   Pollutants - In selecting candidates for the study, attention was given to the type and
       number of pollutants addressed in an attempt to represent a range of the most common
       pollutants  for  which TMDLs are conducted:   nitrogen;  phosphorus;  low dissolved
       oxygen; total suspended solids (sediment); toxics; and metals.
   •   Scale - A variety of small and large scale projects, as defined by square mileage  of the
       watershed, were selected for inclusion in the study.  Size  categories are:   small ^100
       square miles; medium <1,000 square miles; and large >1,000 square miles.
   •   Complexity Level - Another objective was to represent a range of complexity levels.
       Sophistication of water quality model was used as a proxy for overall TMDL complexity
       to guide TMDL selection. Figure 2 is a matrix showing the distribution of the 14 TMDLs
       for which case examples were developed according to pollutants and complexity level.

DEVELOPMENT OF A DATA AND INFORMATION COLLECTION SYSTEM

       The interview/data collection guide used to collect information from participating state
and local water pollution control officials  for this  study is based, in large part, on  EPA's
Guidance for Water Quality-based Decisions:  The  TMDL Process, published in April  1991.
EPA's guidance states that a TMDL is composed of four parts: loading capacity (LC), wasteload
allocations  (WLAs),  load  allocations  (LAs),  and  an  appropriate margin  of safety (MOS),
According to EPA's Guidance, TMDL development involves quantification of pollutant sources
and allocation of allowable loads  to sources.  Further, TMDL development  includes the
following five activities:
   1.  Pollution selection;
                                                f             "                   I
   2.  Estimation of assimilative capacity;                                             -
   3.  Estimation of pollutant loading from all sources;
   4.  Predicative.analysis and TMDL establishment; and
   5.  Allocation - WLAs, LAs.
                                        Page 2

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 2s
I

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        Figure 2. Range of Complexity and Pollutants Covered by Selected TMDLs

Level
of
Complexity
Simple
Mid-
Range
Complex
Pollutant
N
fflL
IKK

P
f f -. \
COB
CHE
APQ
BOD/DO
FLT
OIL
LDF
APQ
TSS
SYC
YNK
SAM
TRK

NfL3
CHN

LMR
Metals


DEL
                                         KEY:
                  APQ = Appoquinimmk River    LDF :
                  CHE = Lake Chelan           LMR=
                  CHN= ChenowethRun        OIL =
                  COB = Cobbossee Lake        SAM =
                  DEL = Delaware River Estuary  SYC =
                  FLT = Flint Creek            TRK =
                  fflL = Hillsdale Lake         YNK =
Little Deep Fork Creek
Lower Minnesota River
Oil Branch Creek
South Fork Salmon River
Sycamore Creek
Truckee River
Yankee Hill Lake
Using  EPA's TMDL Guidance and  the identified TMDL development activities,  an
interview/data collection guide was developed for  this TMDL Cost Study.  The guide is
comprised of the following five sections:
   •   General  Background  -  This  section addressed demographic and other general
       background questions relating to many TMDLs.  Responses to these questions provided
       the basis for the cost study and cost comparison.
   •   Development Activities - For the purpose of consistency among case studies, this section
       broke the TMDL development process into six customary activity categories.  For each
       activity category, participants were asked to provide estimates of number of staff, total
       time (in years, months, weeks, days, or hours), and average annual salary levels for
       persons conducting those tasks.  Responses to these questions provided estimates  of the
       level of effort required to implement TMDLs.
   •   General Water Quality Management Activities -  This section addressed issues related
       to  water  program work on TMDLs in relation to other water quality  management
       activities.
   •   Historic and Projected Revenue Data - This section requested sources and amounts of
       funding for the year or years TMDLs were conducted.
   •   Benefits - This section explored direct and indirect benefits of the TMDL process.
                                        Page 4

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       As previously mentioned, for the purpose of comparison across case examples, the
TMDL development process was divided into six cost categories. These categories are:
   •   Data Collection/Monitoring - Includes compiling available  information,  analysis of
       historical data and  other available demographic information, identification of data
       collection  needs,  collection  of  ambient  water quality  samples,  monitoring flow,
       installation and operation of continuous water quality monitoring equipment, collection
       of point source data, data standardization, and quality assurance/quality control.
   •   Modeling - Includes initial calibration, development,  and operation of mathematical
       models to simulate natural processes and pollution within bodies of water.  Models range
       from a simple series of calculations to complex computer programs.
   •   Analysis - Includes  development of TMDLs, wasteload allocations  (WLAs) and load
       allocations (LAs), pollution control scenarios, and cost analysis.
   •   Outreach - Includes public meetings, educational efforts, and creation of citizen advisory
       and/or TMDL strategy groups.      ;
   •   Formal Public Participation - Includes public notice of TMDLs, receiving, compiling
       and publishing public comment on the TMDL, and public hearings.
   •   Administration  -  Includes  inter- and  intra-agency  planning meetings,  scheduling,
       coordination of field- and laboratory staff, grant administration!, and development of
       summary and final reports.

INFORMATION COLLECTION,, CASE STUDY DEVELOPMENT, AND FOLLOW-UP

       The TMDL background and demographic  information included within this study was
gathered using a multi-phase collection process. After the interview/data collection guide was
developed and TMDLs were selected, background information and documents were solicited
from  each of the participating agencies.  This  information includes  TMDL case studies,
summaries, and final reports; CWA Section 319 grant applications; USD A hydrologic unit area
(HUA) annual reports; and EPA mini-grant profiles. Next, .in-depth telephone interviews were
conducted with water program managers and other relevant TMDL development personnel.

       After completion  of the telephone interviews,  case studies of  costs  associated with
individual TMDLs were developed.   Each  case study contains comparative demographic
information, as well as a range of estimated and potential costs for discrete elements of TMDLs.
As a  final step, all case study write-ups were sent to water program  managers to clarify any
remaining questions and confirm profile information.

PRESENTING COST ESTIMATES IN FULL-TIME EQUIVALENTS AND DOLLARS

       Cost estimates have been developed for level of effort in full-time equivalents (FTEs) and
dollars.  Both are important to understanding and  comparing cost estimates, and for predictive
purposes. FTEs normalize cost estimates, elinoinating any salary and benefit differentials among
studied jurisdictions.   FTE  estimates  also are helpful to program managers in understanding
staffing implications of TMDL projects.  Dollar estimates are important for determining funding

                                        PageS

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needs and identifying opportunities for grant assistance.  Dollars also are typically associated
with contract costs, which can be substantial for some TMDL activities.  While FTEs are less
important for activities that are typically contracted, in some instances water quality programs
may consider undertaking selected activities in-house.
                                          Page 6

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                 PART H. COST ESTIMATION APPROACH
      In-depth phone interviews provided most of the information necessary to estimate TMDL
costs. In calculating TMDL costs, only costs to the government agency or agencies responsible
for TMDLs were counted.  Implementation costs, including pollution prevention and control
activities which are a result of a TMDL, are not counted.  Figure 3 is a flow chart that outlines
the strategy for calculating the total cost of each TMDL.

             Figure 3. Strategy for Calculating the Cost TMDL Development
Base
Approach
Obtain estimates of staff tim<
necessary to complete each
component of TMDL developm
*
Obtain or estimate
current average salary
or hourly rate of staff
1
Obtain estimate
of staff benefits
1
Obtain estimates of any
capital or contracting costs
and convert to 1 995 dollars.
*
Compute total costs
in 1995 dollars ^

Alternative
Approach

3 • • Obtain cost estimates
IB «|frr including staff and •••••»
Lent capital costs for each
component of TMDL
development

^_ Use 1.25 as a
^^ benefits multiplier
. •





                                     ..Page 7

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       Dotted arrows in the flow chart represent the approach taken when the basic approach
was not possible.  Most programs provided sufficient data to use the basic approach where the
starting point is the level of effort expended on each component of TMDLs (See Part I for a
description of the cost components of TMDLs).   For most  TMDLs in this study,  only one
agency's  efforts were estimated.   This  level of effort is referred to as "in-house" full-tune
equivalents (FTEs).  For other TMDLs that required major efforts from teams of agencies, level
of effort was calculated for more than one agency.  FTEs in this case are not referred  to as "in-
house," since they are from multiple agencies.

       The level of effort (in FTEs) was multiplied by a 1995 average FTE salary for the staff
working on the TMDL to present all personnel costs in 1995 dollars, regardless of the year work
actually occurred.  This approach assumes that one FTE produces the same output in a recent:
year as in the current year.  The product of staff effort and salary was then multiplied by the
benefits multiplier for the particular agency developing the TMDL  (the multiplier equals one
plus the cost of benefits as percent of total salary).  A multiplier of 1.25, which is a mid-range
value, was assumed for those agencies that did not  provide one. This final output provides the
total personnel cost in 1995 dollars.

       Other costs that are not part of direct efforts  of personnel conducting TMDLs include
capital costs, laboratory costs, work by contractors,  and in-kind services from other government
agencies.   Where  significant and available, estimates were obtained for these costs.   These
estimates  were converted to 1995 dollars using a  price index of state  and local government
purchases,1 and added to personnel-costs to develop a total cost estimate for TMDLs.

       In cases where  agencies provided cost estimates rather than level of effort for each
component of a TMDL, the  costs were converted  to  1995 dollars using the same  index.
Slimming these costs yields total TMDL costs. In the case of Lake Chelan, level of effort was
estimated from cost estimates rather than vice versa.
1 The 1995 figure is currently unavailable for the price index of state and local government purchases. An estimate
of the 1995 figure was calculated by averaging the annual percentage increase of the index for the years 1984 to
1994. This average increase was then applied to the 1994 figure to approximate the 1995 figure.

2 The level of effort for Lake Chelan was calculated as if state personnel conducted all of the activities necessary to
develop the TMDL.


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                          PART HI. COST SUMMARY
RELATIONSHIPS BETWEEN COSTS AND TMDL FEATURES     ,

       Figure 4 on the following page is a matrix that summarizes basic information for each
TMDL in this study. The matrix presents total cost to date or projected cost, in-house level of
effort measured in full-time equivalents (FTEs), watershed size, model complexity, type of
pollution, point sources, nonpoint sources, level of expenditure on public participation activities
for each TMDL, and the page number on which each case study can be found.  Before analyzing
the figures contained in the matrix, several characteristics of the data deserve special attention:
   •   For most  of the TMDL case examples, the TMDL development  process has been
       completed such that the cost represents a total cost.  For a few cases, such as Yankee Hill
       Lake, Chenoweth Run, and the Delaware River Estuary, the TMDL development process
       is  ongoing as of this writing.  Thus, those programs are expecting to incur additional
       costs. For Little Deep Fork,  all costs are projected costs.

  • •   In-House FTEs represent efforts of only one lead agency in developing the TMDL. Thus,
       the total level of effort is not necessarily represented. For example, in the case of Flint
       Creek, the level of effort  measured by in-house FTEs (2.00) seems to be disproportionate
       to  the cost of developing the TMDL ($1,023,531).  However,  many other  agencies
       participated in TMDL activities, contributing approximately 14 FTEs.
   •   Model Complexity is based on an elementary rating system that evaluates modeling
       efforts as "simple," "mid-range," or "complex."  The ratings are adapted from EPA's
       Compendium  of Watershed-Scale Models for TMDL Development (EPA841-R-92-002, ,
       published in June 1992), as well as information obtained from water quality managers.

       The analysis of data in Figure 4 is based on observation only. The sample size  does not
establish statistical significance for making predictions or determining causality.  Observation of
the data, however, does produce general patterns of cost that  are at least related to,  if not
determined by, various features of the TMDL.

       A  close look at  cost data in Figure 4 reveals a wide range of costs for TMDL case
examples, from $4,039 to $1,023,531.  Case examples are listed vertically in the matrix from
lowest to highest cost. Figure 5  depicts these costs graphically. In addition to the wide range of
total costs, a gap exists in total costs represented by the cases: six TMDLs are below $25,000,
and eight are above $100,000. This fact may indicate that TMDLs require either comparatively
modest efforts and expenses or relatively concentrated efforts and  significant expenses.

Cost and In-House FTEs

       Figure .4 also suggests that several characteristics of a TMDL  are correlated to the
magnitude of its total cost. For example, the number of in-house FTEs  working on a TMDL
tends to be directly proportional to the cost. This relationship is intuitive: costs increase as level
of effort  increases. , The Truckee River, Lower Minnesota,  and  Flint Creek seem  to  be
exceptions,

                                        Page9

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however, in each case, there  is a reason  for the apparently disproportionate costs.  For the
Truckee River, all modeling work was completed  by a contractor;  contractor FTEs are not
calculated as TMDL FTEs in this study.  For the Lower  Minnesota River, a  significant
percentage of total costs was incurred many years ago (up to 21 years), so converting to current
dollars seems to produce disproportionate costs.  For Flint Creek, many federal agencies, whose
FTEs are not tabulated, contributed a substantial portion of the total effort.

Cost and Watershed Size

       The watershed size for a TMDL also seems to correspond to the cost of the TMDL  - the
smaller the watershed, the lower the cost.  This relationship seems to hold true except for the
South Fork Salmon River and Hillsdale Lake.  Figure 6 illustrates this point.  The figure plots
each TMDL case example on a chart with natural log of watershed size on the x-axis and natural
log of cost  on the y-axis.  A logarithmic scale is used because a standard linear scale does not
produce a  discernible relationship.3   A trend  line is included  in Figure 6 to  estimate the
relationship. This trend shows that the percentage change in cost increases in fixed proportion to
the percentage change in watershed size.


                   Figure 6.  Relationship between  Watershed Size and TMDL Cost
            15.0
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       8
       
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Cost and Model Complexity

       Model complexity is another factor that appears to influence TMDL cost. As expected,
TMDLs  with simple models  tend to cost  less than  TMDLs with complex models.   Two
discernible exceptions to this observation are; Sycamore Greek and Flint Creek. Both of these
relatively expensive TMDL efforts used simple models.  They incurred higher costs for oflier
(non-modeling) aspects of their TMDL development efforts.                        .

Cost and Pollutants                           -

       There does not appear to be a recognizable pattern that associates the cost of a TMDL to
the number or type of pollutants for which TMDLs are developed.  Lack of such a pattern does
not necessarily rule out a relationship between type of pollution and TMDL cost. For instance,
with other'aspects being equal, a TMDL that must address numerous pollutants including toxic
substances is likely to require more effort than one which addresses a single, non-toxic pollutant.

Cost and Distribution of Point and Nonpoint Sources

       The distribution of point and nonpoint sources addressed by a TMDL also seems to be
related to the cost of a TMDL. Those TMDLs addressing only one type of source (either point or
nonpoint) tend to be less expensive than those addressing both types.   Figure 7 displays this
relationship graphically and demonstrates that average costs of single-source TMDLs are lower
than average costs of multiple-source TMDLs.
                   Figure 7. Relationship between Pollutant Distribution and Cost
    $500,000  •-

    $450,000  --

    $400,000  ' -

  .  $350,000  "

H   $300,000  --
I—< .
a   $250,000  --
o
J
«   $200,000  • -

£   $150,000  ••

 ,:  $100,000  --

     $50,000  --

         $0  •-
                                                            $468,260 (avg.)
                              $47,211 (avg.)
                             TMDLs with Only
                             One Type of Source
                                                 TMDLs with Both Point
                                                 and Nonpoint Sources
                                        Page 13

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Cost and Public Participation

       Finally, there  appears  to  be a correlation between TMDL costs and the  level of
expenditure on activities related to public participation. Relatively inexpensive TMDLs tend to
have low or no expenditures on activities related to public participation. There are two apparent
exceptions  to  this observation, Sycamore Creek and Flint Creek.   Both of these relatively
expensive TMDLs had relatively low expenditures on public participation activities.

EXAMINATION OF TMDL COSTS BY COMPONENT

       As stated in Part I, the cost of each TMDL was generated by defining components for
TMDL  development activities.   These components are:   data collection and  monitoring;
modeling; analysis; outreach; public participation; and administration.   For the analysis that
follows, outreach and public participation are combined into one category (making a total of five
categories), because many programs do  not make a distinction between these two components.
Figures 8a  and 8b present the cost of each TMDL,  broken down into the five cost categories.
Figure 8a contains those TMDLs that  cost less than $25,000, and Figure 8b contains  those
TMDLs that cost more than $25,000. This split at $25,000 renders scales for each figure that
allow more illustrative comparisons of TMDLs. Figure 9 displays the component costs of each
TMDL as a percentage of total cost.  Several important characteristics  of the data are noted
below:

   •   Staff who worked on the Appoquinimink River TMDL provided information' on level of
       effort and costs  using their own categories rather than the five listed  above.   Then-
       categories were adjusted to fit the five standard categories as follows:
           Appoquinimink Categories
           Planning/Administration
           Preliminary Assessment
           Data Collection
           Modeling Strategy and Model Development
           Public Participation
Standard Categories
Administration
Analysis   .   .
Data Collection and Monitoring
Modeling
Outreach and Public Participation
   •   Staff who worked on the Lower Minnesota River TMDL did not make a distinction
       between modeling and analysis costs. Thus, in Figures 8b and 9, analysis costs are $0 for
       therLower Minnesota River, and modeling costs include the cost of analysis. In addition,
       costs  for  outreach  and public participation  are included as  part  of the cost of
       administration.

   •   Staff who worked on the Lake Chelan TMDL did not make  a distinction between data
       collection and modeling costs.  Thus, data collection costs  have been  included in
       modeling costs.                                                              ,
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    •  The fact that a few cost categories are actually sums of two cost categories (with one of
       those categories listed at $0) tends to distort the results in Figures 8b and 9. For example,
       in Figure 8b, Lake Chelan displays very high modeling costs and no data collection costs.
       This is somewhat misleading, since data collection costs are part of the modeling costs.
       Likewise, Figure 9 displays Lake Chelan's modeling cost at approximately 80 percent of
       the  total cost  of  the TMDL.   In  fact,  modeling  and  data collection constitute
       approximately 80 percent of the total cost.
       Figures 8a and 8b show that expenditures on certain components of TMDL development
vary extensively among TMDLs in the study.  For example, two TMDLs which have a similar
total cost,  the Delaware River Estuary and the Lower Minnesota River, have significantly
different administrative costs. Differences may be caused by one or both of two factors. First,
each TMDL development process may be unique and require varying degrees of effort for certain
components.  Second, each agency may group and report efforts such that cost categories are not
directly comparable.  It  is likely that both of these factors account for the wide swings in
expenditures among components. Figure 9 points out these variations more clearly than Figures
8a and 8b.  For instance, Figure 9  shows that data collection and monitoring  costs,  as a
percentage  of total cost,  for each program are highly variable.  Other cost categories display
similar results, when compared among TMDLs.

       Aside from indicating high variance in component costs among TMDLs in the study,
Figure 9 shows that the costs of some components tend to be lower than other components. For
example, administrative costs and the costs of outreach and public participation are lower than
data collection and monitoring costs in almost all cases. Figure 10 illustrates this point more
clearly.
                                        Page 15

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       Figure 10 is a pie chart that displays the average cost of each component of a TMDL as a
percentage of the total average cost of a TMDL.  Remember that the Modeling pie piece in
Figure 10 includes data collection costs for Lake Chelan  and analytical costs for the Lower
Minnesota River and is,  therefore,  somewhat larger than it might be otherwise.   Barring
differences in the way  that various agencies aggregate costs, Figure 10 clearly shows that
modeling and data collection/monitoring are, on  average,  the  most costly components  of
developing a TMDL.   Analytical  costs are also  substantial, while costs  associated with
administration and outreach and public participation are relatively small.

       This cost summary section compares costs and cost components among all of the TMDLs
in this  study.   Such comparisons are useful in identifying patterns and variances among
programs, but the individual case studies presented in Part VI provide further insight into  the
costs  of developing a TMDL.  First, Part IV summarizes  factors influencing decisions about
dedicating different levels of effort in developing a TMDL.  Part V provides information on
federal  TMDL resources, including availability of funding  and staff who serve  as TMDL
coordinators.
                       Figure 10. Component Costs, Average of All TMDLs
                       Outreach & Pub. Administration
                          Partic.        6%
                            6%
                     Analysis
                      16%
Data Coll. &
Monitoring
   40%
                              Modeling
                                32%
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                              PART IV.  FINDINGS
       This study has shown that level of effort and associated costs necessary to' complete
TMDL activities varies for any given TMDL project, depending on an array of factors, including:
   •   Type of water body and geographic features;
   •   Complexity of the water quality problem;
   •   Number and type of pollutants;
   •   Availability of data;
   •   Complexity of the model used;
   *   Number and type of sources; and
   •   Political sensitivity and level of public involvement.
In addition, many other factors can conceivably influence costs of a particular TMDL.

       Each TMDL case example provides a section labeled Cost Analysis that examines factors
such as those listed above that program staff considered during TMDL development. This part
of the report summarizes those sections and describes overall findings by synthesizing responses
from a number of water quality programs and officials.  This is accomplished in five sections:
(1) decision factors for amounts spent on TMDL activities; (2) relationship of TMDL to other
water quality program activities; (3) cost minimization approaches; (4) funding sources; and (5)
benefits of TMDLs.                                                      '

DECISION FACTORS FOR AMOUNTS SPENT ON TMDL DEVELOPMENT

       Many different  factors influenced TMDL managers'  choices in spending on TMDL
development, but several are common among those studied:
   •   Ability to use TMDL development elements  -  data,  modeling, analysis, as well  as
       outreach, and public  participation - to support other water quality program activities
       tended to increase investment in those areas;
   •   Availability of existing data,  models, and analyses decreased  the level  of additional
       expenditures necessary in these areas;
   •   Level of participation in TMDL development by organizations other than the lead
       agency(ies)  is often inversely proportional to the level of in-house (i.e., lead) effort and
       expenditures; and
   •   Availability of funding from a variety of sources - state program funds, state grants, local
       cost-sharing, and federal grants, as well as in-kind contributions - increased the amount
       managers were willing to spend especially with respect  to data collection, modeling, and
       analysis.
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       The overall magnitude and complexity of a particular TMDL project framed many of the
decisions about  expenditures in all of the cost categories.  This is particularly apparent for
expenditures on modeling. In general, TMDL modelers chose to spend an amount that allowed
them to capture a level of complexity commensurate with complexity of the waterbody and
pollution problems. Two other decision factors cited less often are:  prior availability of various
types of data that are necessary to conduct a TMDL; and lack of experience in conducting  certain
TMDL activities, resulting in less attention to and spending on those activities.
       Leveraging resources - both financial and  in-kind services- - appears to be the most
significant factor affecting TMDL expenditure decisions.   As illustrated in the case studies,
partnerships between agencies involved  in water quality management  have been key  to
successful leveraging of resources for  TMDL development.   Selected decision factors are
discussed in more detail below.

RELATIONSHIP OF TMDL TO OTHER WATER QUALITY PROGRAM ACTIVITIES

       Overall, managers felt that TMDLs were cost-effective and also  increased the cost-
effectiveness of other water quality program efforts, because of the strong linkages between
TMDLs and other activities. One characteristic noted in almost all TMDL development efforts is
that ample opportunities exist to share valuable information among water quality management
and protection efforts. Such sharing may occur within one particular agency or among several
agencies at different levels of government In addition, a TMDL may benefit from data that are
available, or it may generate data that are useful to other water quality programs. For example,
many TMDL analysts noted that their respective,agencies would be undertaking water quality
monitoring efforts even in the absence of TMDL efforts.

COST MINIMIZATION STRATEGIES

       One aspect of TMDL development shared by all of the programs in  this study is an
attempt to minimize costs where possible.  Several methods of cost  minimization were used by
most or many agencies, such as obtaining data from available sources rather than collecting new
data. Data collection can be an expensive undertaking, especially when it involves capital costs
for equipment that measures various properties of water quality.   Another cost minimization
strategy is sharing costs with other water quality initiatives and/or generating information that is
useful to other water quality initiatives.  This strategy may not decrease costs of developing a
TMDL, but it may decrease costs of other initiatives or decrease total costs  incurred by a water
quality agency.  Other cost minimization techniques that were mentioned include:
   •   Working closely with point source dischargers;
   •   Organization of multi-agency groups not only to  spread costs, but also to take advantage
       of the skills and resources of additional agencies; and
   •   Use of in-kind services from other institutions.
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FUNDING SOURCES

       One hurdle all water quality managers must jump in developing a TMDL is resolving
how to fund the costs outlined in this study.  A wide variety of federal, state, and local funding
sources were used to pay for TMDL activities among the programs in this study, including:
       •  Water quality program operating funds (typically State general revenues);
       •  NPDES permit fees;
       •  State and local grants; and
       •  A variety of specific federal water quality grants, such as 205  (j) Grants, 319 (h)
          Grants, and TMDL mini-grants.

BENEFITS

       Water quality managers typically described TMDL benefits in two  ways: in terms of
direct benefits to waterbodies, meaning improved water quality; and in terms of indirect benefits
in the form of increased understanding, awareness, and coordination that they felt also will result
in water quality improvements. Notably, few quantitative measures of benefits were available.
Although several managers cited observed water quality improvement, many indicated it would
be a couple years into TMDL implementation  before improvements were measurable and/or
observable.
       Awareness of the benefits of TMDL development is useful in justifying costs of a TMDL.
Benefits of TMDL development may relate not only to water quality issues, but also to a broader
range of issues involving the effectiveness of government-sponsored environmental initiatives, in
water as well as other media.
       Water quality managers who participated in a TMDL development process highlighted
both direct and indirect types of benefits; some of these are:  .
   •   Enhanced public awareness of water quality problems;
   •   Improved scientific knowledge of chemical, biological, and physical  processes within
       watersheds;
   •   Heightened coordination of internal and external stakeholders;
   *   Improved efficiency in conducting aspects of the TMDL process;
   •   Improved water quality, including fewer violations of pollution standards; and
   •   Lower risks to human and ecological health.
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                   PARTY.  FEDERAL TMDL RESOURCES
AVAILABILITY OF FUNDING

       The basic funding sources available to states and Indian Tribes under the Clean Water
Act (CWA) for implementing the Watershed Approach include:  Section 106, which provides
base support for overall water quality management programs (e.g., monitoring,  permitting,
enforcement, etc.);  Section 314 (Clean Lakes), which provides funding to assess and mitigate
lake water quality problems; Section 319, which provides funding to implement nonpoint source
control measures;  and Section 604(b),  which' provides support  for water  quality planning
activities (it does  not  provide support for implementation of program activities).   The
approximate annual funding available nationally for each program is as follows:  Section 106 -
$80 million; Section 314 - not funded in FY 95 (historically averages approximately $5 million);
Section 319 - $100 million; and Section 604(b) - $15-20 million.  In addition, other program
(e.g., Wetlands) and project oriented funding is available under Section 104(b)(3) of the CWA.

TMDL COORDINATORS

The following is a list of TMDL Coordinators for all 10 EPA regions.
Mark Vobrhees
Water Quality Management Section
US EPA Region 1 (WQM-2103)
J.F: Kennedy Building
Boston, MA 02203
phone: (617) 565-4173
fax:    (617)565-4940

Thomas Henry
Water Management Division
Water Quality Section
US EPA Region 3 (3 WM12)
841 Chestnut Street
Philadelphia, PA 19107
phone: (215) 597-0414
fax:    (215) 597-8541

Robert Pepin
US EPA Region 5 (5WQS-TUB8)""
77 West Jackson Street
Chicago, IL 60604
phone: (312) 886-1505
fax:    (312)886-7804
Rosella O'Connor
Water Management Division
US EPA Region 2
26 Federal Plaza, Room 813
New York, NY 10278
phone: (212) 264-8479
fax:    (212) 264-2194  or 9597

Jim Greenfield
Water Quality Management Division
US EPA Region 4
345 Courtland Street, N.E.
Atlanta, GA  30365
phone: (404) 347-2126  x6597
fax:    (404) 347-3269
Troy Hill-
Water Management Division (6W)
US EPA Region 6
1445 Ross Avenue
Dallas, TX 75202-2733
phone: (214) 665-6647
fax:   (214) 665-6489
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John Houlihan
Planning and Evaluation Section
US EPA Region 7
726 Minnesota Avenue
Kansas City, KS 66101
phone: (913) 551-7432
fax:   (913) 551-7765

Dave Smith
303(d) Coordinator
US EPA Region 9
75 Hawthorne Street
San Francisco, CA 94105
phone: (415) 744-2012
fax:   (415) 744-1078
Bruce Zander
Water Quality Req. Section
US EPA Region 8 (8WM-SP)
999 18th Street, Suite 500
Denver, CO  80202-2405.
phone:  (303) 293-1580
fax:    (303)293-1674

Alan Henning
Environmental Services Division
US EPA Region 10 (ES-097)
1200 Sixth Avenue
Seattle, WA  98101
phone:  (206) 553-8293
fax:    (206) 553-0165
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PART VI. TMDL CASE EXAMPLES
        APPOQUINIMINK RTVER
           LAKE CHELAN
          CHENOWETH RUN
          COBBOSSEE LAKE
      DELAWARE RIVER ESTUARY
            FLINT CREEK
          HILLSDALE LAKE ,
       LITTLE DEEP FORK CREEK
       LOWER MINNESOTA RIVER
         OIL BRANCH CREEK
      SOUTH FORK SALMON RIVER
          SYCAMORE CREEK
          TRUCKEE RIVER
        - YANKEE HILL LAKE
              Page 25

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                APPOQUINIMINK RIVER, DELAWARE
Key Features
Title:
Location:
Size/Scope:
Comparative Size:
Pollutant(s):
Sources of Pollutants:
Model Use and Complexity:


Total Cost
Funding Sources:
  Appomniamlnk River,        "                         ;
       V     -. :f : V->          '        	            " ^
  New Castle County, northeastern Delaware; 'USSPA Region JIL
  5.2 mile tidal freshwater river segment? 47 square mile watershed
  Small; <100mi2,   '   ,     '*
 " Phosphorus,, dissolved oxygen.
  Point .sources—one discharger (the Mddietowj3*0dessa-
  TowDsendwastewatertreataentpiaB.t)> One wasteload aUoCafion
  (WEA) developed.           ", [
  Honponrt sources?—extensive agricultural land use. One load
  allocation (LA) developed.
  The EUTRO4 version of EPA's \#ASP4 water quality tnodel and
  the. BYNHYB hydrodynamic submodel were used to ran complex
„  - simulations of liver and poUution processes.
  $145,527^  "           '-
   vs                       % •>
  EPA nonpoiat somce TMDL Miai-Grant; State jgeneral revenues;
  Local generalievenues.	-   f
Summary

       Delaware Department of Natural Resources and Environmental Control (DNREC)
initiated the TMDL process for the 5.2 mile tidal freshwater portion of the river segment
due to low levels of dissolved oxygen (DO). The low DO concentrations are the result of
excessive algal  growth  caused  by phosphorus loading from  the  single  wastewater
treatment plant and nonpoint sources, primarily agricultural runoff. DNREC developed
Phase I of a TMDL for a segment of the Appoquinimink River.

       The Appoqmnimink River drains a 47 square mile watershed, 61 percent of which
is covered by agricultural lands.  Forestlands, wetlands, and towns are the other key
features of the watershed. Designated uses of the TMDL segment are:  primary contact
recreation; secondary contact recreation; fish, aquatic life, and wildlife;  industrial water
supply; and agricultural water supply.

       As illustrated in Table 1, DNREC's total in-house effort for the  Appoquinimink
TMDL to date is 0.96 FTE, at a cost of $145,527.  DNREC received  assistance from
several local institutions in managing the TMDL work, but maintained almost exclusive
authority over the project. The work completed to this point has occurred as Phase I of
the TMDL.  Expenditures for Phase I provided benefits initially through modification and
reissuance of the NPDES permit for the wastewater treatment plant.  However, water
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quality standards have not been fully met, and Phase II may be initiated to address
remaining water quality violations.

       Some factors, such as the presence of only one point source and the availability of
information on nonpoint source loading, simplified the TMDL process and lowered costs.
Other factors, such as the abundance of nonpoint sources  and the intricacy of the
modeling effort, complicated the-TMDL process.

       State general revenues-supplied funds for salaries, monitoring, nonpoint source
load assessments, installation and maintenance of gauges for stream  flow  and tide,
bathymetric surveys, purchasing and deployment of hydrolabs, and other activities.  In
FY 1992, DNREC received a nonpoint source mini-grant from EPA in the amount of
$8,000 to assist development of a TMDL for the Appoquinimink River.
Table 1. Summary of TMDL Costs for the Appoquinimink River
Activity
Planning/Administration
Preliminary Assessment
Data Collection
Preliminary Modeling
Model Testing
Public Participation
TOTAL
DNREC FTEs*
0.08
0.33
0.26
0.02
0.21
0.06
0.96
Cost($)
6,875. •
25,000
49,381** -'
43,917***
16,027
4,327
145,527
Cost as % of Total
4.7
17.1
33.9
30.1
11.0
2.9
90, 7****
*1 FTE (Average) = $43,948.  ,
**This cost includes county staff time.
***This cost includes contractor fees.                          ;
****Cost as a percent of total does not add to exactly 100 as a result of rounding.
Cost Analysis

       The level of expenditures on the Appoquinimink River TMDL were dictated by
four principal factors:   availability of state and federal funding,  state and  county
wastewater planning priorities, availability of historical water quality, data, and level of
public participation. Because DNREC obtained a mini-grant from EPA and had access to
point  and nonpoint source loading data, it was able  to devote substantial resources to
modeling.  DNREC spent relatively few resources on public participation as a result of
tune constraints and inexperience with public hearings  concerned with TMDLs  (the
Appoquinimink was DNREC's first TMDL, and public involvement is  slated to play a
more significant role throughout the entire TMDL process in the future).

       A portion of the costs of conducting the TMDL, such as data collection, would
have been incurred even in the absence of a TMDL,  For instance, there is still the need to
conduct  testing  for  purposes  of general water quality assessments,  Section 305(b)
reporting, and compliance monitoring  for the NPDES program.   In addition, certain
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activities necessary to develop the TMDL generate information that is useful for other
water quality programs, increasing the cost-effectiveness of the TMDL.

       DNREC used several creative avenues to minimize costs. For example, to reduce
costs, DNREC worked with New Castle County to acquire point  source discharge data
from the Middletown-Odessa-Townsend Wastewater Treatment Plant.  This agreement
saved approximately $5,446 (1995 dollars) in data collection costs that DNREC would
have otherwise incurred.  In addition, when possible, DNREC utilized available water
quality  data.  Particularly useful were Rural Clean Water Program studies that were
conducted  from 1980 through 1986 that measured nonpoint  source loading rates for
phosphorus and nitrogen.

       DNREC also attempted to obtain additional funding where possible to aid its
TMDL efforts. In 1992, DNREC sought and received an EPA TMDL mini-grant in the
form of contractual support for initial calibration and evaluation of the WASP4 model for
point and nonpoint source loading.

       According to DNREC staff, the expenditures on the Appoquinimink TMDL have
produced or are expected to produce several benefits for the watershed, including:
    •  Improved water quality, including fewer violations of DO standards;
    •  Improved scientific knowledge of chemical, biological, and physical processes
       within the watershed;
    •  Improved efficiency in conducting aspects of the TMDL process;
    •  Heightened coordination with both internal and external stakeholders; and
    •  Enhanced public awareness of problems within the watershed.


Cost Breakdown

       DNREC uses a specific set of cost categories for its TMDL  development process.
While these categories are similar to the standard six categories used in this study, there
are some differences. DNREC's categories and descriptions of each are provided below.
    •  Planrjing/Administration:   Includes  meetings,  scheduling, and other general
      planning activities.
    •  Preliminary Assessment:  Includes compiling available information, discussions
       •with other agencies and groups to determine relevant issues, evaluations of-water
       quality,  analysis  of historical data  and  other available information,  and
       identification of data needs.
    • Data Collection:  Includes development of a monitoring plan, coordination with
      field and laboratory staff,  collection of water quality and sediment samples,
      installation and maintenance of gauges for stream/low and tide, bathymetric
      surveys, operation of continuous water quality monitoring systems (hydrolabs),
       collection  of point source  data from the wastewater treatment plant,  and
      standardization and audit of data.
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    •   Preliminary Modeling: Includes preparation of work assignments for modeling
       contractors, initial model  calibration, nonpoint source  load estimation, and
       development of written materials.

    •   Model Testing:  Includes fine tuning modeling parameters,  recalibration of the
       model, evaluation of various pollution control scenarios, and'analysis of costs of
       different control scenarios:

    •   Public Participation:   Includes holding  a public hearing and  advertising,
       receiving,  and responding  to public comment on the TMDL and the  NPDES
       permit for the wastewater treatment plant.                          '   ,
            Platomftg/Adtninistrati&tifor the Appoquinimink River TMDL

       In-lioase FTEs                 ••   Cost                   Fan
-------
       In-house FTEs
           0,26
Data Collection for the Appaqidnimink River TMJ>L
                       Cost
                       - - funding Source(s)
                         State and local
       The total cost of $49,381 for data collection is split between the state and New
Castle County.  For its staff time, DNREC incurred a cost of $6,575.  This time was spent
for development  of a monitoring plan, coordination with field and laboratory  staff,
collection of water quality samples, operation of hydrolabs, and standardization and audit
of data.   An additional cost of $37,360 was  paid to the U.S. Geological Survey by
DNREC (from state general funds) for various services, including installation, operation,
and maintenance  of one tide gauge and one stream gauge for a two-year period and
measurements of bathymetry and tidal velocity. New Castle County  incurred a cost of
approximately $5,446 in collecting point source data from the wastewater treatment plant.
Several costs are not included in the estimate here.  These include capital costs associated
with data collection equipment and fees for laboratory analysis. The  cost estimate for the
state's data  collection  effort is based on two  field technicians working two days per
month over a two-year period.
             Preliminary Modeling for the Appoqitinimirik River TM&L
       In-house FTEs
           0.02
$43,917^
                                             Funding SoUreeYs)
                                             Federal and State
       Development of the Appoquinimink TMDL involved two modeling efforts. The
first effort, for which DNREC used contractor services, is referred to  as "preliminary
modeling."  The second effort, which DNREC conducted is described below as "model-
testing."  For preliminary modeling, the contractor used,EUTRO4 and DYNHYD5,
which are versions of EPA's WASP4 water quality model.  This model was set up to
simulate concentrations of dissolved oxygen (DO) and nutrients in the river to determine
the cause of violations of DO standards.  Model simulations used the Full Linear DO
Balance, which is defined in the WASP4 user's manual as a fairly complex model.  This
particular model was chosen for several reasons:  (1) ability to analyze both point and
nonpoint sources; (2) ability to account for tidal fluctuations;  (3) access to user support;
and (4) ease of use compared to other models that could accomplish similar tasks.

       The majority of the preliminary modeling effort was carried out by a consulting
firm, which was paid through the EPA mini-grant and state funding. The only direct non-
contracting costs incurred by DNREC were for preparation of the work assignment for
the contractor and oversight of contractor activities. These activities required a time
1 New Castle County's data collection cost was $5,000 in 1992.  This cost converts to $5,446 in 1995
dollars, using a price index for government purchases (1.0892).
2 The contractor's portion of this cost was $40,000 in 1993, which converts to $42,475 in 1995 dollars,
using the price index for government purchases (1.061875).
                                     Page 30

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 commitment of one week for an engineer. This staff time translates into a cost of $1,442,
 which was paid by the state.                      ,>
                 Mod'el Testingfor the Appoqmnfmink River TMDL  ,
        In-faoHseFIBs          ,    -     .Cost                  Funding Sourcefe)
	"0,2.1    s   -	    $16,027      	       "" State	

       For  model testing, DNREC  built upon  the  WASP4 model to include full
 phytoplankton dynamics, benthic nutrient fluxes,  and field-measured sediment oxygen
 demand (SOD). Then, DNREC re-calibrated the model. In addition, DNREC developed
 a list of pollution control scenarios and executed the model to determine  expected
 dissolved oxygen response in the river .under various control options. Finally, DNREC
 drafted a report to present the findings from model simulations and highlight the need for
 the TMDL.  Model development required one DNREC engineer to spend three days per
 week over a period of six months. The state paid the cost of this engineer's time. "
              Public*'Participation f&r the Appoquinimink Jiiver TMDL
                                      Cost  ,                 Funding Spurce(s)
            0.06
$4,327
State
       To involve the public in the TMDL process, DNREC published a public hearing
 notice to solicit oral and written comments from interested parties. DNREC held the
 hearing to address the TMDL and to consider comments on the application for reissuance
 of the NPDES permit to the Middletown-Odessa-Townsend Wastewater Treatment Plant.
 DNREC also produced a report on the development of the preliminary TMDL and made
 this report available for  public review.  The staff time spent to conduct the public
 participation activities was relatively short, approximately three weeks for an engineer.
 The state provided me funding for this staff time.
 For more information contact:

 Richard W. Greene                                         ;
 Delaware Department of Natural Resources and Environmental Control
 Division of Water Resources                            '
 89 Kings Highway
 P.O. Box 1401                                            ;
 Dover, Delaware 19903                        •
 Phone (302) 739-4590
 Fax (302) 739-6140                        .     '
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                      LAKE CHELAN, WASHINGTON
Key Features
Title:
Location:

Size/Scope:
Comparative Size:
Pollutant(s):
Sources of Pollutants:
Model Use and Complexity:


Total Cost
Funding Sources:
LakeChelan.
Chelan County; Northern Cascades;, north-central Washington; -
IJSBPARegionX.            '          f
52 square mile Jake; 924 square mile watershed.
Medium, ^IQOG mi2.
Phosphorus, Bacteria.
Point sources—Chinook salmon net pens.
Nonpoint sources-HDirect precipitation, stomiwater runoff forest
runoff; and agricultural runoff; tributaries; grouadwater inflows;
and septic system inputs.
A steady-statemass balance model and Monte Carlo analysis
techniques were used to ius simulations of river and pollution
processes {mid-range 'complexity)*
$993,337,      '      , •       ' '       f,  ,
Federal Cleaa Water Act Section 319 grant; State Centennial Clean
Water Fund grant; and State and Local general revenues.
Summary

       la 1992, the Washington State Department of Ecology (DOE) developed a TMDL
for Lake Chelan to address concerns about nutrient loading resulting from rapid urban
development and increased agricultural activities  in  and around  the  lake watershed.
While the lake was not water-quality limited and did not appear on the state's 303(d) list,
population increases and development pressures heightened concerns about maintaining
long-term water quality.   Pollutant  concerns focused primarily around  the issue of
phosphorus enrichment from nonpoint sources.

       Lake Chelan is located in the Northern Cascades approximately 100 miles east of
Seattle and 50 miles south of the Canadian border.  The Lake stretches over 50 miles and
has an average width of approximately one mile. The topography of the  lake basin is
primarily mountainous. The lake has a surface area of 52 square miles and a watershed of
approximately 924 square miles. It is considered one of the most pristine bodies of water
in North America, with a high degree of clarity and extremely low nutrient levels.  The
lake is classified as ultra-oligotrophic, and  primary uses  of  the waterbody include
irrigation, production of hydroelectric power, recreation, and fish propagation.

       In 1986, DOE conducted its first water quality assessment of the lake,to determine
the nutrient loading limits necessary to maintain the lake's ultra-oligotrophic nature. In
1990, the Lake Chelan Water Quality Committee, comprised of representatives from
local governments, prepared a water quality plan based on the  1986 assessment.  The
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water quality plan also included a TMDL for total phosphorus in Lake Chelan.  While a
TMDL  for total  phosphorus was  established, load .allocations (LAs) and waste load
allocations (WLAs) were not set.

       As illustrated in Table 2, DOE's  total estimated in-house effort for the Lake
Chelan  TMDL to date is 12.13  FTEs, at  a  total  cost of $993,337.  DOE  received
assistance from several local institutions administering and managing the TMDL, as well
as  conducting the  field work.    Expenditures provided benefits  initially  through
establishment of TMDLs for phosphorus within the waterbody.

       Some factors, such as the number of nonpoint sources and the lack of historical
data, complicated the TMDL process.  Other factors, such as the presence of only one
point source,  and the abundant wilderness  areas within the  watershed simplified the
TMDL process and lowered costs.                                       ,

       State general revenues supplied funds for salaries, monitoring, nonpoint  source
load  assessments, modeling, public outreach  and education, and  other activities.
Furthermore, the Lake Chelan Water Quality Committee received a  state  Centennial
Clean Water Fund Grant in the amount of $80,000  for their work, consultant fees, and
associated administration  costs.  The Centennial Clean Water Fund is a water quality
grant program funded through the sale of tobacco products.  In FY 1994, DOE received a
Clean Water Act Section 319 grant from EPA in the amount of $60,000 to assist with the
TMDL for Lake Chelan.               -
Table 2. Summary of TMDL Costs for Lake Chelan
Activity
Data Collection/Monitorihg/Modeling
Analysis
Public Participation/Outreach
Administration
TOTAL
FTEs*
7.32.
1.20
2.65
0.96
12.13
Cost($)
813,245
44,890
99,222
35,980
993,337
Cost as % of Total
81.9
4.5
10.0
3.6
. 100.0 -.
*FTEs for the Lake Chelan TMDL were calculated based on cost figures that were reported by DOE staff
and an estimate of the average salary and benefits of DOE staff.
Cost Analysis

      . The magnitude and complexity of the project were primary factors in determining
the cost of the TMDL.  The lake's many unique geological features contributed to the
enormity of the undertaking.  For example, technically, Lake Chelan is a fjord (a glacial
lake), which'stretches 50 miles and is approximately 1600 feet deep.  Furthermore, in the
case of Lake Chelan, the retreating glaciers left a large sill in the center of the lake.  Both
the great depth of the lake and the sill, significantly affect lake turnover and complicate
the modeling dynamics.
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       Funding issues, the number of nonpoint sources, and other factors  influenced
DOE's decision to undertake the level of effort that it chose for Lake Chelan.  Because
DOE obtained a CWA Section 319 grant from  EPA, it was able to devote  substantial
resources to its initial data collection, monitoring, and modeling efforts.  DOE spent a
relatively large amount on activities related to public education and outreach  because of
the substantial number nonpoint sources.

       A portion of the  costs of conducting the TMDL, such as data collection, are
shared by DOE's other water quality initiatives, including  water quality assessments,
water quality inventories, and NPDES support.   For example, DOE would  take water
quality samples in the absence of the Lake Chelan TMDL. hi addition, certain activities
necessary to develop the TMDL generated information  that is useful for other water
quality programs, increasing the cost-effectiveness of the TMDL.

       To reduce costs, DOE worked with the  Lake Chelan Reclamation District and
other local  organizations on  activities  related  to  education  and outreach for BMP
implementation. DOE also sought additional funding to aid its TMDL  efforts. In 1994,
DOE sought and received an EPA CWA Section 319  grant to assist with development of
the TMDL.
Cost Breakdown

       For the purpose of consistency among case studies, the TMDL development
process is divided into the following six cost categories.

    •  Monitoring/Data Collection;
    •  Modeling;
    •  Analysis;
    •  Outreach;                                                              ,
    •  Public Participation; and
    •  Administration.

       In reporting its costs, DOE has combined data collection,  monitoring,  and
modeling into a single cost category, and also has combined public participation and
outreach into one category.  With the exception of costs related to public participation
and public outreach, costs outlined in this analysis represent only those expenses incurred
by DOE.  Monitoring and subsequent modeling activities conducted as part of the water
quality  assessment and other water quality studies required the greatest investment, of
resources.  Throughout the TMDL process, DOE built upon existing information and
relied upon in-kind services from other organizations  for  its public participation and
outreach activities.

       Because information for the Lake Chelan TMDL was reported in dollars, rather
than level of effort, FTE estimates are calculated from costs.  All estimates of FTEs in the
gray boxes below are based on a 1995 salary of $30,000 and a benefits multiplier of 1.25.
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          Data Colle&fon/Mamforing/ModettngfortkeJLake Chelan TM&L
        in-hottseFTEs
            732
    Cost -
, '$813,245'
Bunding Source(s)
 State aod local
       In the mid-1980's, an independent study was conducted indicating that Lake
 Chelan would support one-quarter to one-half million more residents, and associated
 septic systems, without affecting the Lake's water quality.  Concerned about that finding,
 local governments within the watershed appealed to the state to conduct another study of
 the waterbody.  In response, DOE conducted some  initial scoping of the waterbody,
 including conducting literature  reviews and compiling available information about the
"watershed.

       In 1986, DOE initiated the Lake Chelan Water Quality Assessment. To conduct
 this assessment, DOE engaged the servipes of a contractor, which relied on the work of
 numerous subcontractors to conduct the study.  This intensive assessment was designed
 to:   (1) provide baseline water quality data; (2) evaluate.the  suitability of on-site
 wastewater disposal systems within the developing lower basing and  (3) estimate the
 potential sources and impacts of nutrients, bacteria,  and other chemicals of concern.
 Additionally, the assessment determined average  spring and summer values for each of
 the following water quality parameters:  secchi disk depth; temperature; pH; dissolved
 oxygen (DO); total suspended solids (TSS); specific conductance; total phosphorus; total
 nitrogen;  total  coliform;  particulate  N:P; and water column  N:P.  In  addition,  the
 contractor conducted hydrology studies,  septic tank  evaluations, installed monitoring
 wells, and conducted limnology studies.

       DOE  used  a steady-state  mass  balance model  and  Monte  Carlo  analysis
 techniques to determine the maximum allowable load increase from point  and nonpoint
 sources.  DOE  included  a  margin of safety  by calculating the permissible loading
 conservatively.  In addition, DOE approved the Lake Chelan Water Quality Committee's
 Plan for Lake Chelan which included a schedule for implementation of pollution control
 scenarios and the potential costs  of implementing those scenarios. Finally, DOE drafted a
 report to present the findings from model simulations and highlight the  need for the
 TMDL.

       .Water quality monitoring has been part of ongoing Clean Water Act Section 319
 grant implementation activities.  Currently, a long-term monitoring strategy is beginning
 to emerge as coordination is developed among stakeholders and  current monitoring gaps
 are identified. The initial recommendations from the current Water Quality Management
 Area  (WQMA)  assessment  are that annual monitoring,  of unspecified frequency, is
 required in order to develop long-term trends. This strategy might include installation of
 permanent water quality monitoring stations to monitor selected water quality parameters
 on a bi-annual basis (flow, fecal coliform,  TSS, turbidity, DO, temperature, pH, clarity,
 sedimentation, TP, ammonia nitrogen, nitrites, nitrates, and conductivity).  This strategy
 may  also  assess water quality  trends and runoff from agricultural drains to  evaluate
 pollutant loading during worst case conditions.  Finally, as part of its  general ambient
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monitoring activities, DOE may conduct monthly total phosphorus sampling at the lake
outlet. Due to the quality and importance of Lake Chelan, DOE hopes to obtain Clean
Water Act Section 319 funding to enable implementation of its  long-term monitoring
plan.

       All costs  for the  initial  scoping are associated  with DOE  staff time.  DOE
dedicated the equivalent of one staff person working full-time for six months to complete
initial scoping.  This staff time translates into a cost of approximately $30,000 in 1989
($36,197 in 1995 dollars), which was paid by the  state.  The majority of the data
collection and monitoring activities were carried out  by a contracting firm and several
sub-contractors, these efforts were paid for with state  funding.  The cost of the contract
was $425,000 over the years 1989 to 1990 ($502,378 in 1995 dollars).  Other direct non-
contracting costs incurred by DOE were for grant  management activities, including
preparation of a workplan, and several small water quality studies.  These activities cost
approximately $80,000 in 1990 ($92,604 in 1995 dollars), and were funded from the
Centennial Clean Water Fund, Modeling activities cost approximately $10,000 in 1989
($12,066 in 1995 dollars) and also were funded with state general revenues.  Long-term
monitoring activities will  be partially funded with a  $170,000 (75 percent cost share)
grant to the Lake Chelan Reclamation District.
                       Analysis for the Lake ChelauTM&L
       In-house FTEs
           1.20
 Cost
$44,890
                             State
       DOE's  analysis  activities  in conjunction  with  TMDL  creation  included
development of WLAs and LAs for total phosphorus.  Although Lake Chelan currently
meets  water quality standards for  all pollutants,  DOE  established  calculations (i.e.,
assessments of existing loads) for total phosphorus in accordance with EPA's TMDL
guidance, which highlights the importance of identifying and protecting pristine waters as
well as those classified as water quality-limited (USEPA, 1991).

       All costs for analyses in  support of the TMDL were incurred by DOE.  DOE
dedicated staff over a three-year period (1990 to 1992) to perform required analysis and
develop appropriate TMDL levels. The staff time cost $40,000 total, which converts to a
cost of $44,890 in 1995 dollars.
           Public Participation and Outreach for the Lake CHetan TMDL
       In-house FEE?
           2.65
$99,222 '
                     " -  Fundidg'Soureefe)
                     Federal, State, and Local
       The  Lake Chelan TMDL  was politically .sensitive because of controversies
surrounding future development in and around the lake.  The Lake's recreational value,
concerns about rising population, and increased nutrient loading ecological straining on
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 the Lake have come to the forefront of the political debate. In particular, the concern is
 that algal growth caused by phosphorus (the primary limiting nutrient) loading will
 impair the Lake's water quality.  ,

        In addition, other issues involving,selection of appropriate land uses within the
 watershed and the preservation of wetlands have involved  federal, state, and local
 government agencies. Government agency involvement includes:  the City of Chelan;
 Chelan County; the Chelan County Public Utility District; the Lake Chelan Reclamation
, District; the Lake Chelan Sewer District; and the U.S. Forest Service.   To coordinate
 multi-agency interests, DOE organized a Lake Chelan Water Quality Committee and
 charged it to prepare a Lake Chelan Water Quality Plan.

        The purpose of this plan was to develop specific steps to ensure that the water
 quality within the Lake Chelan watershed is maintained. As a result of the development
 pressures within the watershed, the plan's primary recommendations were to expand
 sewage facilities to  accommodate future growth.   Specific tasks included: on-site,
 wastewater  management;  stormwatef management;  agricultural activities; and boat
 sewage disposal.                          .

        As part of this process, DOE staff met with local stakeholders on a routine basis
 for approximately three years. After this time, DOE provided grant funding so that local
 stakeholders could attempt to implement the objectives developed in the water quality
 plan.  Currently, the Lake Chelan Water Quality Committee is implementing three grants
 related to its outreach and public participation activities.   The cost for DOE's  public
 participation and outreach efforts  is $91,000 over the three-year period from 1991 to
 1993. This figure converts to a cost of $99,222 in 1995 dollars.
In-house ffTBs
v ^ 0.96
Administration for the Lake Chelan
Cost
$35,980
TMDL
Pundmg Sourcefe)
State
        Administrative  costs  associated  with TMDL  development  included grant
 administration and staff coordination activities, as well as development of a final report.
 Additional costs were incurred for staff time required to conduct scheduling and other
 general administrative activities. These costs total $20,000 in nominal dollars, and were
 incurred over the five-year period from 1989 to 1993. This figure converts to $22,541 in
 1995 dollars. The state, through DOE's budget, paid all of these costs (travel costs are
 not included in this estimate).  Administrative activities of the Lake Chelan Water
 Quality  Committee  include  oversight  of the  six   subcommittees  charged  with
 implementing the Water Quality Plan. These activities were funded with a $12,000 grant
 in 1991 from DOE. This cost converts to $13,439 in 1995 dollars.
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For more information contact:

Steve R.Butkus
Washington State Department of Ecology
Water Quality Program
P.O. Box 47600
Olympia, Washington 98504-7600
Phone (360) 407-6482
Fax (360) 407-6426
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                     CHENOWETH RUN, KENTUCKY
Key Features
Location:
Size/Scope:
Comparative Size:
P0Ihrtant(s):

Sources of Pollutants:

Model tlse antl Complexity:
Total Cost
Funding Sources;
 Cheaowetk Run.
 Jeffersoa County, aorfhrantralKmtueJqr; USEPA Region IV,
 8.5 anile creek;. 17 square mile watershed.
 Small 5100 sail
 Phosphorus, ortbophospiaateii suspended-solids,. unioiiized
 aromoiria, and BOP.,
 PonitsQurees—wastewater treatment plant, light industries,
                         " *      '       s \    "
,, Nonpoint sources—urban runoff, pasture lands.
       •"                         f  •.      \
 Noraodel.
 $19,625 current; $35,000 anticipated: cumulative.
< EPA nonpoint source 7MDL Mini-Grant; State general revenues;
 Funding fiom the Metropolitan Sewer District,
Summary

       The Water Division of the Kentucky Department for Environmental Protection.
(KDEP) is in the process of implementing a TMDL for 8.5 miles of Chenoweth Run.
KDEP initiated the TMDL process for Chenoweth Run to address pollutant levels in the
creek,  at the urging of public interest  groups.  Existing pollutants include dissolved
solids, suspended  solids,  unionized ammonia, phosphorus, orthophosphate,  and BOD.
The impetus for initiating the TMDL was to determine the most significant source(s) of
pollutants and to allocate specific load restrictions for phosphorus.

       The watershed primarily consists of urban lands, with  a few open spaces and
agricultural fields  downstream.  The designated uses of the run  are primary contact
recreation, secondary contact recreation, and warm water aquatic  habitat.  Sources  of
pollution include the City of Jeffersontown Wastewater Treatment Plant, light industries,
urban runoff, and pasture lands. Chenoweth Run drains a 17 square mile watershed.

       As illustrated in Table 3, KDEP's total in-house effort expended by KDEP on the
Chenoweth Run TMDL to date is 0.26 FTE, for a total cost of $19,625.  KDEP has
received substantial technical assistance from both the Metropolitan Sewer District and
the U.S. Geological Survey,  as well  as financial assistance from  EPA?s  mini-grant
program.  The total expected cost for completion of the TMDL is $35,000. KDEP staff
describe this as a relatively simple TMDL that requires only moderate expenditures.  At
this time, the TMDL is not phased, but KDEP  may  consider phasing it based on  the
contribution of nonpoint source loading to the problems of Chenoweth Run.
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       To date, KDEP has spent $19,625 on the Chenoweth Run TMDL, in total KDEP
expects to spend $35,000 on TMDL related activities.  KDEP received a total of $35,000;
nonpoint source mini-grant from EPA late in 1994 in the amount of $20,000 to develop
the TMDL for Chenoweth Run;  state general funds have contributed $7,500; and the
Metropolitan Sewer District has supplied another $7,500.
Table 3. Summary of TMDL Costs for Chenoweth Run
Activity
Monitoring/Data Collection
Modeling
Analysis
Outreach and Public Participation
Administration
TOTAL
KDEP FTEs*
0.08
0.00
0.15
0.01
0.02
0.26*,**
Cost ($)
12,500**
0
6,000
375
750
19,625***
Cost as % of Total
63.6
0.0
30.5
1.9
3.8
99.8****
*1 FEE (Average) = $39,000.
**The Metropolitan Sewer District paid most of the cost for laboratory analysis.
***These figures represent level of effort as of June 22, 1995. Anticipated total cost for completion of the
   TMDL is $35,000.
****Cost as a percent of total does not add to exactly 100 as a result of rounding.
Cost Analysis

       The level of expenditures on the Chenoweth Run TMDL were dictated by three
key factors:  the decision not to model the waterbody, the availability of additional grant
funding, and the decision to spend relatively little on the public participation and outreach
aspects of the TMDL. Cost was a prohibitive factor in deciding whether to develop a
model for Chenoweth Run. However, KDEP staff are not sure that modeling would have
yielded enough useful information to make the process cost-effective.  KDEP staff also
believe that the TMDL is not overly  complex, and,  thus, does not require  excessive
expenditures in general. One reason why KDEP may have spent relatively few resources
on public participation is that public awareness of the state of Chenoweth Run was fairly
high. In fact, a local environmental interest group was a major impetus hi initiating the
TMDL process.                                   ;                .

       Some of the costs of conducting the TMDL, such as data collection, can be spread
over other water quality initiatives.  In fact, KDEP does not count its data collection and
analysis costs as direct costs of the TMDL.  These are counted as  general departmental
expenditures.  In addition, some of the activities necessary to develop the TMDL can
generate information that is useful  for other water quality programs, increasing the cost-
effectiveness of the TMDL.

       KDEP used several outside sources to obtain  additional funding and cut costs
where possible. To reduce costs, KDEP used existing data from the wastewater treatment
plant.   KDEP  also obtained  information  from a  collaborative effort  with the U.S.
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Geological Survey and the Metropolitan Sewer District. Analysis of data, which to this
point has been provided by the Sewer District, has been especially useful to KDEP in its
efforts to implement the TMDL.

       According to KDEP  staff, expenditures on the Chenoweth Run TMDL to date
have produced a few notable benefits for the watershed. These include an increased level
of public awareness and participation in water quality-protection efforts. Furthermore,
KDEP staff are hopeful that the TMDL process will help to reduce application of lawn
chemicals  and encourage voluntary control of nonpoint  source pollution  from an
upstream industrial park, as the study results are made public through the final report and
presentations to the stakeholders involved. Upon completion of the TMDL,  the desired
benefit will  be  reduced levels of pollutants  in the  run,  especially  lower levels of
phosphorus discharge from the wastewater treatment plant and other sources.  The goal is
to restore and maintain the designated uses of Chenoweth Run.


Cost Breakdown

       For the purpose of consistency .among case studies, the TMDL development
process is divided into the following six  cost categories:
    •  MonitoringVData Collection;
    •  Modeling;
    •  Analysis;
    •  Outreach;
    •  Public Participation; and
    •  Administration.
In reporting its costs, KDEP has combined outreach and public participation into one cost
category. Information about activities  undertaken within each of these categories and
information on costs, FTEs, and funding sources are provided below.
             Monitoring/&attt Collection for the Chetimve&i Run TMDL
       lii-house FTBs                  "  Cost           '       Fundittg SpTireefe)
         s  Q.OS   ,,               ,    $12,500     "             Federal aad State-
       Costs associated with monitoring/data collection to date consist of staff time
necessary to collect  samples  from  five monitoring stations  along  Chenoweth Run
($3,000) plus analysis of water samples. KDEP already has access to five years of water
quality data from one monitoring station at me wastewater treatment plant. KDEP's own
sampling and data collection efforts began in January 1995 and should be completed by
January 1996. The U.S. Geological Survey also has collected water quality samples five
or six times over the  course of the TMDL process.  Costs for U.S. Geological Survey
sampling are not included here.  The Metropolitan Sewer District has funded most of the
water sample analysis efforts to date.  The District has  analyzed water quality samples
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collected and sent the results to KDEP for a cost of $7,500. In addition, the laboratory at
KDEP has spent approximately $2,000 on sample analysis.  This $2,000, along with the
$3,000 KDEP  spent on sample collection is funded by the federal mini-grant and state
general revenues.  In the future, further analysis of samples will  occur at KDEP's
laboratory within the Department of Environmental Services.
In-house fc'l'Bs
0.00
Modeling for the Chenoweth Run TMDL
Cost
SO
-. '
Funding: Source(s)
N/A '
       At this stage in the TMDL process, KDEP has not developed a  model for
phosphorus  loading.   KDEP  is  using  QUAL2E  to model BOD  and  ammonia
concentrations to set permit limits for the wastewater facility. KDEP set up the stream in
QUAL2E several years ago, independent of the TMDL process, as part of their normal
waste load allocation procedures.  As implementation of the TMDL reaches  a more
advanced stage, the U.S. Geological Survey may conduct modeling of urban  runoff and
other nonpoint sources.
In-house ETEs
0.15
Analysis for the Cnenvwefh Run TMDL
Cost
- ^ $6,000 '"'' ' " "'""
Funding Semfce(s)
State and Local
       Analysis activities for the Chenoweth Run TMDL involve evaluating data that
have been collected, writing reports, and producing graphic representations of data.  Two
KDEP staff spent 40 days of time on these efforts.
Outreach
Tn-Tiouse FTEs
O.OJ
and Public Participation for the
" ' Cost
S375
Chenoweth
Run TMDL
i ff
Funding Source(s)
Federal and State
       To date, outreach and public participation for the Chenoweth Run TMDL consist
of a presentation to environmental organizations,  a presentation to local governments,
meetings, progress reports, and letters.  These activities required 2.5 days of one staff
person's time.  The mini-grant and the state paid the cost of this outreach and public
participation.
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fa-hmis&FTEs
0,02
Administration for the Cheiioweth Run
Cost
'$750
TMDL
Funding' Sourcefs) -
Federal and State
       Administration of TMDL activities to date has required 5 days of one KDEP staff
person's time.  The mini-grant and the state paid this cost.
For more information contact:

DaveLeist
Department of Environmental Protection
Division of Water                 '
Frankfort Office Park
14ReillyRoad
Frankfort, Kentucky 40601
Phone (502) 564-3410
Fax (502) 564-4245
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                        COBBQSSEE LAKE, MAINE
Key Features
Title:
Location:
Size/Scope:
Comparative Size:
Pollutants):
Sources of Pollutants:

Model Use and Complexity:


Total Cost
Funding Sources:
Cobbossee Lake. ,   ,, •     ,
Keanebec County, soufhemMaiiie; tJSEPARegion L
"Affected waterslied^ 14.86 mi2.
Small, <100 mi*
Phosphorus,            ^    -
Nonpoiat sources^nmpejeousfeturji flows associated i?rfth aisa
agricultural activities.
Empirical models developed by Vollenwetder{1969), and
modified by DMoh. and Rigler (1974) were used to run simple
simalations of tile lake and to determine pollutant loading*
$6,057.       '     ^  '
Federal Clean Water ActlMDL Mini-Grant
Summary

       As a result of severe water quality degradation, in 1993, the Cobbossee Watershed
District (CWD) developed  a special TMDL for Cobbossee Lake.   Since 1992,  an
accelerated level of eutrophication has impaired water quality in Cobbossee Lake and the
surrounding watershed.   Phosphorous,  the primary  limiting nutrient,  comes from
Annabessacook Lake  upstream,  as well as the numerous and varied nonpoint sources
throughout the watershed.

       CWD initiated the  TMDL process for the Cobbossee Lake  portion  of the
watershed to determine nonpoint sources, develop nonpoint source load allocations (LAs)
to attain established water quality criteria, and to determine the extent to which future
development can be  conducted while  at  the same time  maintaining water  quality.
Conducting an assessment of nonpoint sources from the direct Cobbossee Lake watershed
and their impact on the waterbody relative to sources in other lake watersheds upstream
(e.g., Annabessacook Lake) was a secondary objective of the TMDL. Other TMDL goals
included attainment of the State of Maine's water quality standard that mandates the
absence or elimination of culturally induced algal blooms.

       Cobbossee Lake is a large (approximately 5,000+ acres), deep, highly scenic lake
located in Kennebec County, Maine. Approximately 10 miles from the state capitol, the
lake, is bordered by five small towns.  Local topography varies considerably, ranging
from gentle rolling hills to areas which are relatively flat and heavily forested. Primary
land uses within the  9,500 acre  watershed include:  approximately  1,800 acres  of
agricultural lands; 1,300 acres of lands under residential and  commercial development;
and 6,400 acres composed of forests, wetlands, and open areas.  The TMDL segment of
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the Cobbossee Lake watershed is approximately 14.86 square miles and is in the lower
reaches of a multiple lake watershed administered by the Cobbossee Watershed District
(CWD).  Designated uses of the TMDL segment of the watershed include: agriculture;
water contact recreation and non-water contact  recreation; commercial water supply;
municipal and domestic water supply; and ptopagation of cold water aquatic life.

       As depicted, in Table 4, the CWD's total in-house effort for the Cobbossee Lake
TMDL is 0.13  FTE; for a total cost of $6,057.   CWD conducted all of the field and
analysis work for the project, but received some technical assistance from the Maine
Department of Environmental Protection (MDEP).  As part of the TMDL development
process, CWD  modeled and produced a final load  allocation  for phosphorus within
Cobbossee Lake.  Thus far, work completed producing the TMDL for phosphorus has
occurred as Phase I of the TMDL process; continued follow-up monitoring for this and
other pollutants is ongoing.

       In FY 1992, CWD received Clean Water Act (CWA) TMDL mini-grant funding
from EPA in the amount of $12,000 to assist with its Cobbossee Lake TMDL activities.
This grant covered all TMDL development expenditures to date.
Table 4. Summary of Cobbossee Lake TMDL Costs
ACTIVITY
Monitoring/Data Collection
Modeling
Analysis
Outreach ,
Formal Public Participation
Administration
TOTAL
CWD FTEs
0.03
0.02
0.05
0.00
0.00
0.03
0.13
Cost ($)
1,369
. 938
2,344
0
0
1,406
6,057
Cost as % of Total
22.6
15.4
38.6
O.Q
0.0
23,2
99.8*
*Cost as a percent of total does not add to exactly 100 as a result of rounding.
Cost Analysis

       The level of expenditures on the Cobbossee Lake TMDL were dictated by three
principal factors: the relatively simple modeling simulations needed, the small size of the
lake watershed, and the availability of over. 20 years of historical monitoring data.

       Another factor affecting CWD's decision to undertake the level of effort that it
chose for the Cobbossee Lake TMDL,  was the receipt of federal grant money to assist
with nonpoint source load estimation and other TMDL development activities.  lii fact,
EPA  TMDL  mini-grant  funding has paid  for  all costs  associated with  TMDL
development to date.

       CWD devoted no resources to formal public participation and outreach related
activities associated with the  TMDL.   While there  was. a  significant  amount of
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controversy surrounding the TMDL, the fact that no resources were spent on public
participation is an indication of a need to use the limited resources on more technical
aspects of the TMDL. Since completion of the TMDL, CWD received federal 319 grant
funding to begin an educational outreach program for five of the municipalities within the
watershed district.                                     •

       Many of CWD's costs associated with the TMDL, such as monitoring and data
collection,  also occur as part of other water quality initiatives. Some of CWD's other
water quality initiatives are watershed management, technical transfer, public assistance,
monitoring and lake restoration.

       CWD employed several methods to minimize TMDL costs where possible. For
example, whenever possible, CWD used available water quality data. Significant sources
of data included over 20 years of data compiled by CWD as part of it's ambient water
quality monitoring activities.

       The direct benefits of the Cobbossee Lake TMDL include that the lake has been
targeted for better management through the development of LAs for phosphorous, as well
as an assessment of nonpoint source loading from the TMDL portion of the watershed. In
addition, the Cobbossee  Lake TMDL  will help decision-makers to  determine  water
quality impacts from direct  (in  lake)  pollutant loading relative  to the  impact of
phosphorous loading from upstream lake watersheds.   Furthermore, the  TMDL has
benefited the CWD by serving as a tool to  guide future lake/watershed management
efforts. Wife the TMDL,  CWD has identified those sources of phosphorous which are
either  the most significant contributors and/or the most easily  addressed within the
watershed.                   •
Cost Breakdown

       The Cobbossee Lake TMDL has been an Devolving process since its inception in
the early-1970s when CWD began to monitor the Lake. For the purpose of consistency
among case studies, the TMDL development process is divided into the following six
cost categories.

    •   Monitoring/Data Collection;
    •   Modeling;
    •   Analysis;
    •   Outreach;
    •   Public Participation; and
    •   Administration.

       All costs outlined in this analysis represent only those expenses incurred by CWD
in  the  TMDL development process.   One-time expenses  including  analysis  and
administration required the greatest investment of resources.  Ongoing expenses include
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 monitoring and model recalibration to account for water quality changes.  These activities
 are undertaken as part of CWD's water quality program.
           Monitoring/Data Collection Costs for the Cobbossee Lake TMJDL
       - In-house FTEs  "      <            Cost         "   '      Fandmg Sourcefe)
           ^0,03     '         '''        Sl,3^     ,    /  '          Factor
       Water quality monitoring for TMDL development was principally conducted by
 CWD. CWD, as part of its ongoing ambient water quality monitoring activities, has been
 monitoring District lakes (approximately 18), including Cobbossee Lake,  for over 20
 years.  In fact,  the TMDL portion of Cobbossee Lake watershed has 'been monitored
 monthly during the spring, summer, and fall, on an ongoing basis since 1973. Monitored
 parameters include total phosphorus, temperature, dissolved oxygen (DO), chlorophyll-a,,
 pH, and alkalinity.

       Beyond routine monthly water quality sampling, CWD compiled and incorporated
 land use information as part of the TMDL development procedure. This effort involved
. compiling all existing land .use data by type, subwatershed, and town. In addition, new
 aerial infra-red photographs were  obtained,  reviewed, and then confirmed by ground-
 truthing land use types  and boundaries.  Selected CWD staff coordinated the  water
 quality sampling and land use verification activities.

       Two CWD. staff dedicated a total of approximately two and one-half weeks tune
 to water  quality sampling and other monitoring activities.   CWD plans  to  continue-
 monitoring Cobbossee Lake.  This staff time translates into a cost of $1,219.  The cost of
 purchasing the new aerial infra-red photos was $150. Several costs are not counted in the
 estimate here, including capital costs  associated with data collection and monitoring
 equipment and fees for laboratory analysis.
                   Modeling Costs for the Cobbossee Lake TMDL
        In-house PTEs                    Cost                   Funding Sourcefs)
            0.02                        $938       ""   >           Federal
       Modeling for TMDL development within Cobbossee Lake has evolved to account
 for changes in the lake as well as the region. Model development was initiated because
 Cobbossee Lake had been experiencing a decline in water clarity and failed to meet
 Maine's-GP A standard.  In  addition, total phosphorous concentrations in the lake were
 high and Secchi disk transparency (SDT) values were below average for Maine lakes.  As
 a result, CWD was concerned about limiting development in watershed communities.
 Therefore, TMDL activities were initiated in part to guide future development within the
 watershed.                                  .
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       Model development for the TMDL took place over an two year period beginning
in 1993.  During this period CWD, utilized two models.  The first, a land use-based
export coefficient model (developed by Reckhow et al.), helped to determine nonpoint
source phosphorus loading to the lake. The second, an empirical model developed by
Dillon and Rigler (1974), helped to generate a TMDL for the Cobbossee Lake watershed.
As part of this process, CWD used data collected in 1991 and 1992 as well as earlier
years,  were reviewed to  calibrate the model.  CWD also  incorporated,  current  and
historical water quality values into the model to establish a range of possible phosphorus
reduction goals.

       CWD's primary remaining concern is that continued development and population
growth in neighboring communities could result in total phosphorus levels exceeding lake
load allocations. For this reason, CWD has developed several alternative  strategies to
attain load allocation limits. In addition, if water quality goals are achieved, the District
can recalibrate the  model and run it using new values  to allow for lesser restrictions to
development of the watershed.

       CWD dedicated approximately 40 hours of one persons staff time  to modeling
efforts for Cobbossee Lake, which translates into a cost of $938.
                   Analysis Costs for the Cobbossee Lake TM&L
       Tn-houseFTEs                    Costs     „     - , „_',    FundingSotircete)
           0.05                        $2,344            ,  ,     ,
       CWD's analysis  activities  in  conjunction  with  TMDL  creation  included
development of a LA for total phosphorus.  Other activities included computer entry of
water quality and land use data, and analysis of output. CWD dedicated 100 hours of one
staff person's time to performing required analysis and developing an appropriate TMDL
level, which translates into a cost of $2,344.
                   Outreach Costs for the CobbosseeLake TMDL
       In-house FTEs    ,          .   -  Cost                 s Funding SourCefe)
            0	^   $0	Not applicable
       No educational or other outreach efforts were conducted in conjunction with the
Cobbossee Lake TMDL development process.  However, CWD recently received a CWA
Section 319 grant for educational  outreach efforts to five municipalities within the
Cobbossee Watershed District.
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       In-htHis&FTEs-
           ' 0
Public participation Costs for the Cobbossee Lake TMDL
                         Cost              -    Funding Sourcefs)
        	SO	    Not applicable
       The Cobbossee Lake  TMDL development process required no formal public
participation activities. In addition, had such activities been required they would have
fallen under the purview of the Maine Department of Environmental Protection (MDEP),
the state's primary environmental regulatory entity.
                Admmistration Casts for the Cobbossee Lake TMDL
       In-hoaseFTEs
           O.OS
                        Cost
                        $1,406
Funding Sourcefe)
  .  federal
       Administrative  costs  associated  with TMDL development  included  grant
administration and staff coordination activities, as well as development of a final report
summarizing the TMDL development process and outlining findings.  CWD dedicated
approximately 60 hours of one staff person's time to these efforts, which translates into a
cost of $1,406.                               .     '  .  "  .  ,  '     /
For more information contact:

BillMonagle
Cobbossee Watershed District
P.O. Box 418
Winthrbp, Maine 04364
Phone (207) 377-2234
Fax (207) 377-4038
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             DELAWARE RIVER ESTUARY, NEW JERSEY
Key Features
Title:
Location:

Size/Scope:

Comparative Size:
Pollutant(s):
Sources of Pollutants:
Model Use and, Complexity:
Total Cost
Funding Sources:
 Delaware Rivet Estuary,
 Eastern Delaware; west ami southeast New Jersey; southeastern
..Permsylvania; witMn. USEPA Regions Jl & IH.
 Surface water segment S4 miles, Affected watershed drainage
 area >757£4 mi2.     "" \ "  ",  ''.  '
 Large;> 1,000miV  „, ,        "'
 Metals, approximately tea toxics (bio-orgardcs, PCBs, DDT),'
 Point sources—83 industrial or municipal facilities (HO outfalls).
 "Hie wasteload aSocations (WLAs) developed fox up to ten toxic
 pollutants will be translated: into effluent limitations for toxic
 pollutants, for selected National Pollution Discharge Elimination
, System (3SPDES) dischargers to the estuary.
 Nonpoint sources—^tormwster runoff from urban, agricultural
 and industrial areas; groiiffldwater Boifltration and runoff firom
 Superrund sites; atniospi.eric-depQsitioiri; combined sewer
 6verlbws%{'CSOs); gronrtdwater a^tration. and natural
 background. Load, allocations will be developed during Phase H ,
 of the'"IMDL development process,
 BEA's WASP4 water Duality model and the DYNHYD5
 bydrodynamic submodel were used, to run. complex simulations of
 riverandppllwtion,processes arid develop WLAs forijunanhealfli
 and chronic aquatic life criteria.  Tidal CQRMIX, a near-field
 model which utilizes a modified version of an BPA-supplied
 model, was used to 4eveldp 'WLAs' for modeling'acute criteria.
 DBLTOXj a far-field model, was also used,to develop WLAs for
 toxics.,",
 $£75,426/          /   ',  ,
 Federal C Jean Water Act Section 205(j) and Section 106 grants;  -
 State (DB, W NY, PA^general revenues; Delaware National
 Estoary Program funding; and Delaware River Basin Commission
 general revenues.        ,      ,      '
Summary

       The Delaware River Basin Commission (DRBC) developed Phase I of a TMDL
for a segment of the Delaware River Estuary as part of a strategy to control the release of
substances toxic to humans and aquatic life. This segment is the 84 mile tidal portion of
the river running from the head of the tide at.Trenton, New Jersey to Delaware Bay.
Numerous point source dischargers release a  variety of pollutants  into the waterbody
including metals and a variety of toxic chemicals. Within the watershed, criteria for toxic
pollutants differed considerably among the states bordering the estuary (Delaware, New
Jersey, Pennsylvania).  DRBC, as part of the TMDL development process, developed a
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common set of water quality criteria and implementation-procedures for toxic pollutants.
These new universal criteria replaced the five sets of criteria which previously applied to
this segment of the  estuary.  As with TMDL  and wasteload  allocation development
procedures, the policies used to develop the water quality criteria represented a consensus
of the estuary states, EPA, and the Commission.

       The Delaware River Estuary drains a 7,794 square mile watershed, a large portion
of which is located  within the northeastern industrial corridor.  Agricultural  lands,
forestlands, wetlands, and towns are the other key features of the watershed.  Designated
uses of the TMDL segment include:  agricultural, industrial, and public water supplies;
wildlife, fish, and other aquatic life; arid primary and secondary contact recreation.

       As illustrated in Table 5b, DRBC's total in-house effort for the Delaware River
Estuary TMDL to  date is  10.30 FTEs, for a total cost of $675,426.  The Commission
received  assistance from federal, state, and local institutions  in conducting the TMDL
work,  but  maintained primary management authority over the project.  The work
completed to this point has occurred as Phase I of the TMDL. Expenditures for Phase I
provided benefits initially through development of procedures for permitting authorities
to select the most stringent wasteload allocation, and establish average monthly  and
maximum  daily effluent  limitations  for NPDES  permits.  However,-water quality
standards have not yet been fully met and DRBC is currently initiating Phase n to address
remaining water quality violations stemming from nonpoint sources.

       Some factors,  such as the size and tidal nature of the waterbody, the abundance of
point  sources, the intricacy of the modeling effort, and the-lack of information on
nonpoint sources complicated the TMDL process. Other factors, such as the availability
of information on point source dischargers, and the existence  of five years of historical
ambient water quality data, simplified the TMDL process and lowered costs.

       Table 5a below presents a summary of the revenues applied to Delaware River
Estuary TMDL development. In addition, a portion of these revenues were leveraged to
develop water quality criteria for the tidal  Delaware River, the same criteria which were
used as the water quality objectives for the TMDL.                            ,

       As a multi-jurisdictional Commission, DRBC received revenues from a variety of
sources, including portions of Clean Water Act (CWA) Section 205(j) grants awarded to
the Pennsylvania Department of Environmental Protection (PADEP) and the New Jersey
Department of Environmental  Protection  (NJDEP);  a direct  CWA Section 106  grant;
Delaware National Estuary Program (DELEP) funding; and general program revenues.
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Table So. Delaware River Estuary TMDL Historical Revenue Data
Funding Sources
PADEP 205Q) grants
NJDEP 2050") grants
DELEP
Section 106 grants
General Revenues
TOTAL
Fiscal
Year
1991
$78,000
$50,000
$10,000
$40,000
$55,000
$233,000
Fiscal
Year
1992
$85,000
$50,000
$0
$0
$30,000
$165,000
Fiscal
Year
1993
$85,000
$82,000
$0
$0
$30,000
$197,000
Fiscal
Year
1994
$70,000
$70,000
$10,000
$0
$36,000 .
$186,000
Fiscal
Year
1995
$0
$0 •
$0
$0
$72,000
$72,000
Totals
1990-95
$318,000
$252,000
$20,000
$40,000
$223,000
$853,000
       DRBC is currently completing Phase I of the TMDL which focuses on point
source discharges from industrial and municipal wastewater treatment plants.  Phase II
will concentrate on nonpoint  sources  with emphasis  on sources of  polychlorinated
biphenyls (PCBs),and chlorinated pesticides (particularly DDT and its metabolites),
metals and volatile organics. The Commission will be  seeking funding from the states
and EPA to support monitoring and control strategy development activities.
Table 5b. Summary of Delaware River Estuary TMDL Costs
ACTIVITY
Monitoring/Data Collection
Modeling
Analysis
Outreach
Formal Public Participation
Administration
TOTAL
DRBC FTEs
2.50
2.80
2.90
0.10
0.25
1.75
10.30
Cost ($)
278,733*
122,103**
147,000
8,693***
15,000
105,000
675,426
Cost as % of Total
41.3
18.1
21.8
1.3
2.2
15.5 i
100.2****
""Includes lab-related costs
"""Includes capital costs for computers
***lncludes capital costs for articles and newsletters
****Cost as a percent of total does not add to exactly 100 as a result of rounding.
Cost Analysis

       The level of expenditures on the Delaware River Estuary TMDL was dictated by
five principal factors:
       1.  The size of the watershed;                              •
       2.  The number of point sources;
       3.  The tidal nature of the waterbody;
       4.  The complexity of the pollutants; and
       5.  The multi-jurisdictional nature of the DRBC.
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       The size of the watershed drove the need for the five year data collection; and
monitoring efforts.  The number of point sources added organizational and coordination
challenges, as well as interpersonal dynamic to the data collection efforts.  The tidal
nature of the waterbody and the number and complexity of the pollutants established the
need  to undertake  extensive  complex  modeling of  the  waterbody.   The multi-
jurisdictional nature of the DRBC provided numerous sources of grant  funding and in-
kind contributors to leverage TMDL development activities.

       Several other factors affected DRBC's decision to undertake the level of effort it
chose  for the Delaware River  Estuary TMDL,  including the receipt of federal grant
money and the ability to "piggyback" on many of the efforts of the Delaware National
Estuary Program.  Considered  alone, grant funding,  in-kind services, and cooperative
agreements made up relatively a small portion of the resources devoted to the Delaware
River  Estuary TMDL; however, together they  allowed  DRBC to devote substantially
more resources to this activity than it otherwise could have.      -

       Many  of DRBC's costs associated with TMDL development, such  as data
collection,  monitoring, and establishing water  quality criteria, also occur as part  of
DRBC's other water quality initiatives.  Some'of the  Commission's  other water quality
initiatives are tracking the movement of the salt front, monitoring reservoir  storage,
reviewing  NPDES permits  for  compliance with the  Commission's  water quality
standards, issuing permits for withdrawals from surface and groundwater, as well  as
discharges to surface water, and reviewing any activity for potential impacts on the water
resources of the basin (such  as Superfund  sites and  dredging operations).  Therefore,
DRBC would already be undertaking some water quality activities in the absence of the
Delaware River Estuary TMDL. In addition, certain activities necessary to develop the
TMDL generated information that is useful  for other water quality programs, increasing
the cost-effectiveness of the TMDL.                                   .

       DRBC used several strategies to minimize TMDL costs  where possible.  For
example, DRBC relied upon in-kind contributions from states bordering the estuary for
its data collection efforts.  As a result, the intensive water quality sampling required for
TMDL development was split among multiple agencies. In addition, whenever possible,
DRBC used available water quality data. Fof example, DRBC worked with industrial
and municipal sources to  acquire point source  discharge data.  This agreement  saved
approximately $415,000  in data collection costs that DRBC would  have  otherwise
incurred.        ,

       According to DRBC staff, the expenditures on the Delaware River Estuary TMDL
to date, have produced several benefits for the watershed, including:
    •   Identification of toxic pollutants of concern;
    •   Identification of PCB arid DDT Superfund sites;
    •   Development  of a 'watershed-based approach to  controlling toxic pollutants
       applicable to other areas of the country;
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    •   Demonstrating the benefits of watershed assessments and permitting to both state
       regulatory agencies and NPDES permittees;
    •   Increased indirect  cost savings  through  development  of procedures  targeting
       monitoring to only specific toxic pollutants of concern;
    •   Increased coordination of the monitoring efforts of several states; and
    •   Enhanced ability to target wastewater treatment plant modifications to specific
       pollutant control.

DRBC staff note that direct environmental benefits of improved water quality  are
dependent on the achievement of WLAs  established under Phase I by the  NPDES
permittees, as well as the identification of nonpoint sources requiring additional controls
to meet water quality objectives in Phase n.                                  .      ,
Cost Breakdown

       For the purpose of consistency among case studies,  the  TMDL development
process is divided into the following six cost categories.

    •  Monitoring/Data Collection;
    •  Modeling;
    •  Analysis;
    •  Outreach;
    •  Public Participation; and
    •  Administration.

       With the exception of costs related to monitoring/data collection, costs outlined in
this analysis represent  only those expenses incurred by DRBC.  Data  collection and
ongoing monitoring activities required the greatest investment of resources.  For these
functions, DRBC hired temporary staff and worked with NPDES permittees to obtain
point source discharge data. Throughout the TMDL process, DRBC built upon existing
information and relied upon in-kind services from other organizations for their efforts in
monitoring/data collection, and modeling  activities.    For  example,  the  Delaware
Department of Natural Resources and Environmental Control (DNREC) assisted with
sample collection for several studies and NJDEP provided in-kind services to adapt the
EPA-supported DYNHYD5 and WASP4 models to the tidal Delaware  River.  These
costs have not been captured in this analysis.
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                                                            V
       Mvnitarm§ft>ata C0ttecti&n Gpsts for ike Delaware J&ver Estuary TMJ>L
                                     ' 'Cost
Funding Sourcefe)
    Slate* and'Local.
       Two stakeholders conduct the majority of water quality monitoring for TMDL
development:  the point source dischargers regularly conduct monitoring in association
with their NPDES permit requirements and DRBC monitors the river regularly as part of
its .customary ambient  water quality monitoring activities.   As part  of the TMDL
development process, DRBC initiated monitoring for specific toxics in both existing
water column monitoring programs and a new fish tissue monitoring program.  Metals
and volatile organics have been monitored in the water column for the past five years.
Fish  tissue  monitoring  of  chlorinated  pesticides,  PCBs,  polynuclear  aromatic
hydrocarbons (PAHs), and metals has been conducted at five stations in the estuary for
the last four years.  Other DRBC monitoring activities include field studies on ambient
toxicity and studies on toxics in sediment.

       Beyond routine sampling, DRBC incorporated special monitoring as part of the
TMDL development procedure to  calibrate and validate the model predictions for the
estuary. The monitoring consisted of intensive studies conducted over the last two years
during low river flows.

       Data collection activities for TMDL development consisted  of a monitoring effort
which involved 83 NPDES permittees, each of which conducted effluent water quality
monitoring at their own expense:  DRBC estimated that data collection and monitoring
costs  were approximately $5,000 for each permittee.  DRBC staff time went toward
preparation of letters, interfacing with permittees, inputting all incoming data into a data
base, and preparing a report on data base use.

       In  addition, many of the data collection and monitoring activities were conducted
by neighboring state  agencies.  For example, the Delaware Department of Natural
Resources and Environmental Control was contracted to provide  sample collection for
several of the studies.  The New Jersey Department of Environmental Protection also
provided analytical support for sediment and fish tissue analyses  under contract to the
Commission.

       DRBC staff dedicated approximately two and  one-half person years to its data
collection and monitoring activities, which translates into a cost of $119,550.  The cost of
laboratory analysis of water samples for TMDL monitoring activities was approximately
3 Cost computed as 1 senior staff working 1.7 years x $60,000 average annual salary including indirect
costs = $102,000; 1 modeler working 0.5 years x $33,000 average annual salary including indirect costs =
$16,500; 1 temporary staff working 0.3 years x $3,500 average annual salary including indirect costs =
$1,050; and.$30,000 per year (1991 to present) for fish tissue and water monitoring = $159,183 (when all
dollars are converted to ,1995 using a price index for government purchases).
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$30,000 per year from 1991 to present. DRBC plans to continue to monitor the Delaware
River Estuary.
               Modeling Costs for the Delaware River Estuary TMJ>L
       Tn-house EIBs               s     .Cost  ,           f    ' ffundiag Source(&)
            2,8                 ; "'  - $122,103*               Federal,State,andLocal
       Modeling for TMDL development within the Delaware River Estuary has evolved
to account for changes in the river as well as the region.  The Delaware River Estuary is
unique as a result of the number and complexity of pollutants, and the strong tidal action
in the waterbody.  Given the hydrodynamic complexity of the estuary, the numerous
point source discharges, and the various fate processes affecting toxic pollutants, DRBC.
selected complex mathematical instruments to model the estuary.

       To allocate wasteloads for protection of aquatic life from chronic toxicity and the
protection for human health  DRBC chose the  Water  Quality  Analysis  Simulation
Program (WASP4), 'developed and supported by the U.S. Environmental  Protection
agency.  DRBC  adapted the model for the tidal Delaware River between Trenton, N.J.,
and  the head of Delaware Bay by specifying physical, hydrodynamic, and chemical
characteristics for the estuary.

       The  modeling process  included  the  development  of  input  files  for  the
hydrodynamic model (DYNHYD5) that described the bathymetry, tidal forces, tributaries
and point source inputs, and drinking water withdrawals.  Effluent data on toxic pollutant
concentrations was gathered by requiring the 83 point sources to perform monitoring.
DRBC used  this data to develop input files for the water quality model  (WASP4).
Finally, DRBC conducted field studies to calibrate and  validate the model for metals,
volatile organics and chronic toxicity.

       DRBC chose WASP4 for several reasons:  earlier versions of the WASP models
had  been successfully applied to the Delaware River for allocating  CBOD;  the one
dimensional nature of the hydrodynamic model (DYNETYD5)  was deemed appropriate
for the Delaware River Estuary based on past scientific  studies; and Commission staff
familiarity with the model made it easier to use than other models that could accomplish
similar tasks.

       In addition to. its  expenditures on model calibration and modeling,  DRBC
leveraged its TMDL development resources through in-kind services provided by states
bordering the estuary. For example, the NJDEP provided in-kind services to  help adapt
4 Costs computed as 1 senior staff working 0.8 years x $60,000 average annual salary including indirect
costs s $48,000; 1 modeler working 2.0 years x $33,000 average annual salary including indirect costs =
$66,000; and $8,103 in capital costs for two new computers in 1995 (converted from $7,000 in 1990
dollars, using a price index for government purchases).
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the EPA-suppprted DYNHYD5 and  WASP4 models for the  tidal Delaware River.
Additionally, DRBC utilized consultants for sample cpllection and laboratory analysis of
water samples in studies to calibrate and. validate the DELTOX far-field model., The
DELTOX model, used to develop wasteload allocations for the protection of human
health and chronic aquatic Jife impacts,  consists of 90  nodes, and incorporates 11
tributaries, the headwaters of the Delaware River, the ,C&D  Canal, and a seaward
boundary.  DRBC also engaged a consultant to modify an EPA-supported near-field
model (CORMDQ for use in tidal waters.  This model, used to develop wasteload
allocations for the protection of aquatic life from acute toxicity,  is designed to describe
the wastefield or dispersion area of estuary discharges under the  varying conditions that
occur over a tidal cycle.

       DRBC dedicated the equivalent of one modeler working for two years and one
senior staff person working for almost one year to its modeling activities. In addition, as
part of its modeling effort, DRBC incurred approximately $8,103 in capital expenditures
for new computers.  Staff time and capital expenditures translated into a total cost of
$122,103.
       In-hottse FTEs
            2.9
Analysis Costs far the Delaware Siver Estuary TM2>L
                       Costs
  Funding Sourcefe)
Federal, State, and Local
       DRBC's  analysis  activities conducted  in conjunction  with TMDL creation
included development of four WLAs for toxics.  DRBC developed WLAs to control
impacts to aquatic biota .and human health for four specific endpoints.  The four specific
endpoints are: protecting aquatic life from acute toxicity and chronic toxicity; protecting „
human health from carcinogenic chemicals; and protection of human health from non-
carcinogenic or systemic effects of chemicals. The Commission then translated the four
WLAs'into a single effluent limitation for toxic pollutants using a LOTUS spreadsheet
program developed by DNREC.  Other DRBC analysis activities included preparation of
basis and background documents to support and defend the TMDLs.

       DRBC dedicated two  of its staff over approximately a three-year  period to
perform required analysis and develop appropriate TMDL levels, which translates into a
cost of $147,000.
 Costs computed as 1 senior staff working 1.9 years x $60,000 average annual salary including indirect
costs = $114,000; 1 modeler working 1.0 years x $33,000 average annual salary including indirect costs =
$33,000.
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        In-house fr'i'Bs
            0.1
Outreach Costs for the Delaware River Estuary TMDL  •  .
                       Cost            '" "     Funding Source(s)
                      $8,693°
Federal, State, 3n<3 Local
       To coordinate multi-agency interests, DRBC organized numerous committees and
subcommittees to  address  different  aspects  of TMDL  development.   Committee
representatives included members of  each state environmental agency bordering  the
estuary, USEPA, local governments, and the general public. Committee work included
the creation of TMDL development and implementation procedures.

       DRBC also held public briefings (similar to public hearings, but less formal) prior.
to developing changes to DRBC regulations. Finally, to keep the public informed about
TMDL development activities, the Commission spent $2,693 (in 1995 dollars) for articles
in the Newsletter of the Delaware Estuary Program.  DRBC dedicated approximately 0.10
FTEs to these efforts, which translates into a cost of $6,000.
          Public Participation Costs for the Delaware River Estuary
        In-house FTEs
           0.25
                                             Funding Source(s)
                                           Federal, State, and Local
       Thus far, DRBC  has conducted no formal public participation activities in
conjunction with  its TMDL development procedures.   However, the  Commission
developed water quality criteria for the Delaware River that were presented at a public
hearing in June 1992. In addition, DRBC developed a rationale document to defend the
water quality  criteria.   These same water  quality criteria were  later used for TMDL
development.

       DRBC also integrated the TMDL development process with the Delaware Estuary
Program which had significant public involvement through established scientific,  local
governments and citizen groups.  The Commission has scheduled  formal public hearings
in October 1995 to address WLAs and effluent limitations for NPDES permits.  DRBC
dedicated a total of approximately three months of one senior staff person's time to  these
efforts, which translates into a cost of $15,000.
 Costs computed as 1 senior staff working 0.1 years x $60,000 average annual salary including indirect
costs m $6,000; $2,693 in capital costs for articles in the Newsletter of the Delaware Estuary Program over
the years 1990 to 1995 (this is converted from $2,500 in 1990 through 1995, using a price index for
government purchases).
 Costs are computed as 1 senior staff working 0.25 years x $60,000 average annual salary including
indirect costs = $15,000.
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             Administration Costs far theDelaware River Estuary
       la-ho-aseFTBs"
            t?5
Cost
Eimdirig Sourcefs)
    State, aa4 Local
       Administrative  activities  associated  with   TMDL  development  included:
preparation and administration  of grants; preparation of progress reports;  providing
support for subcommittee and  committee meetings; substantial interaction with the
Delaware Estuary  Program; and interaction  with state  representatives 'and NPDES
permittees. DRBC dedicated one and three-quarter years of one senior staff person's time
to these efforts, which translates into a cost of $105,000.             .
For more information contact:

Thomas Fikslin
Delaware River Basin Commission
25 State Police Drive
P.O. Box 7360
West Trenton, New Jersey 08628
Phone (609) 833-9500 ext. 253
Fax (609) 833-9522
E-mail drbcnet@netaxs.com   ,
 Costs are computed as 1 senior staff working 1.75 years x $60,000 average annual salary including
indirect costs = $105,000.
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                         FLINT CREEK, ALABAMA
 Key Features
 Title:
 Location:
 Size/Scope:
 Comparative Size:
 Pollutant(s):
 Sources of Pollutants:
 Model Use and Complexity:


 Total Cost
 Funding Sources:
FlintCreefc.
Norfii central Alabama; USEPA Region IV.
             •>     i     '           ,            "
Creek, watershed 244 nu ,   '                  "
Mediumj <100G nxf. ,         '                    - '  ,
Dissolved ojsygen.             -         ,       "',';,,
 %                        ••      •!         ^  •, •.  .•  >
Point sources—two -tyastewater treatment plants {WWTJPs) one
eactfor the Cities of Hartselle and Falkvitte*
Npnpoint sources—numerous agjicnituraL
Watershed Screening and Targeting Tool (WSTT); modified
Streeter-Piielps models; and QUA.L2B were used to run sample ,
simulations of river and pollution processes,         ,  ,'  ,
$1,023,531.        'f'ff    _                ' -  \  ..'1
Federal Clean Water Act Section; 31'9 andnonpoint source TMDL
Mini-Grantej State and federal operating budgets.
 Summary

       The Alabama Department of Environmental Management (ADEM) developed a
 preliminary TMDL for a segment of Flint Creek to address low levels of dissolved
 oxygen (DO). The low DO concentrations are the result of excessive algal growth caused
 by nutrient loading from a two wastewater treatment plants (WWTPs) and agricultural
,nonpoint sources.

       This segment is a 25 mile section of the creek which flows from its headwaters
 approximately ten miles north of Cullman to Wheeler Lake just south of Decatur.  Flint
 Creek drains a 244  square  mile watershed, a  large portion  of which  is covered by
 agricultural lands.  Forestlands, animal operations, and urban areas are the  other key
 features of the watershed. Designated uses of the TMDL segment  are: primary contact
 recreation; fish, aquatic life, wildlife; and livestock water supply.

       As illustrated in Table 6, the total inter-agency effort for the Flint Creek TMDL
 date is 15.72 FTEs,  for a total cost of $1,023,531.  ADEM  received assistance from
 several federal and local institutions in conducting the  TMDL work,  but maintained
 primary authority  over project implementation and  financing.   To  date  the  work
 completed on the TMDL has revolved primarily around development of a preliminary
 TMDL for DO.   Expenditures for preliminary steps  have provided benefits initially
 through modification and reissuance of the NPDES permit  for the wastewater treatment
 plant. However, water quality standards have not been fully met and best management
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practices (BMPs) have not yet been initiated in the numbers needed to address remaining
water quality violations.
       Some factors, such as the extensive data collection necessary, an abundance of
nonpoint sources, the geological surveying needed,  and the intricacy of the modeling
effort, complicated the TMDL process. Other factors, such as the presence of seven point
sources throughout  the watershed, including the two  WWTPs,  simplified the TMDL
process and lowered costs.

       In FY 1992,  ADEM received a nonpoint source, mini-grant from EPA in  the
amount of $8,000 (contractual support for the project) to use available data to assess Flint
Creek water quality,  m FY 1993, ADEM received additional nonpoint source mini-grant
funding in the amount of $15,000 to continue to expand the use. and applicability of the
model developed to assess Flint Creek water quality.

       Federal nonpoint  source grants  supplied funds for salaries, monitoring, data
collection, geological surveying, and other activities.  In FY 1993, the Geological Survey
of Alabama (GSA) received a nonpoint source Section 319 grant from the USEPA Office
of Water in the amount of $63,468 for data collection, monitoring, and analysis activities
related to the TMDL. In FY 1994 and FY 1995, GSA received additional Section 319
grant funding in the amounts  of $68,460  and  $77,750 respectively,  for geological
surveying and additional analysis activities.
Table 6. Summary of TMDL Costs for Flint Creek
Activity
Data Collection/Monitoring
Modeling
Analysis
Outreach
Public Participation
Administration
TOTAL
Inter-Agency FTEs
6.52 ,
1.00
7.00
0.04
0.02
1.14
15.72
Cost ($)
500,662
55,000
^415,207
1,875
1,731
49,056
1,023,531 '
Cost as % of Total
48.9
5.3
40.5
0.1
0.1
4.7
99.6*
*Cost as a percent of total does not add to exactly 100 as a result of rounding.
Cost Analysis                                  ,

       Various types of funding and cooperative efforts were a major influence on the
number and depth of TMDL activities that were conducted. Because ADEM obtained
four mini-grants from EPA and was able to obtain extensive point and nonpoint data
through cooperative agreements with other organizations, it was able to devote substantial
resources  to modeling and analysis activities.  Throughout the TMDL  development
process, ADEM has built upon existing information and relied upon in-kind services from
other  organizations for assistance with data collection, monitoring, public participation,
outreach,  and analysis activities.    Monitoring/data  collection  and analysis  activities
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required the greatest investment of resources. For these functions^ ADEM relied upon the
assistance of numerous outside  organizations.  Modeling required the  next  greatest
investment of resources.  Because monitoring and data collection aspects of the TMDL
are slated to continue through at least 1997, all expenses depicted are currently ongoing.

       The Flint Creek TMDL has been developed within a  setting  of cost-sharing,
largely as a result of the number of agencies involved.  A portion of each organization's
costs associated with conducting the TMDL are shared by other water quality initiatives,
both those undertaken by that agency and other cooperating agencies. For example, some
of TVA's other water  quality  initiatives  include water quality monitoring,  BMP
demonstrations,  aquatic plant management,  habitat enhancement,  and environmental
education. TVA would be conducting water quality monitoring and environmental
education programs in the absence  of  the  Flint  Creek TMDL.   In addition,  by
participating in the TMDL, TVA has developed associations with a number,  of other
entities which generate information needed to carry  out TVA's  other water quality
management  activities.   Therefore, cooperative  agreements and  information sharing
arising from intergovernmental interaction on TMDL activities has  further increased the
cost effectiveness and long-term benefits of the TMDL.

       To reduce costs, ADEM worked with the wastewater treatment plants to acquire
point source discharge data. la several instances ADEM had compiled water 'quality data
and  other data from other organizations.  Particularly useful were the ambient water
quality studies compiled by the Geological Survey of Alabama.

       ADEM also sought outside funding to aid its TMDL efforts. In  1992, ADEM
sought and received an EPA TMDL mini-grant in the form of contractual support to
conduct water quality analyses. In 1993, ADEM received additional grant funding to hire
a contractor for assistance developing preliminary TMDLs.

       According to EPA staff,  because  BMPs have  not yet been folly implemented
benefits of the Flint Creek TMDL are not easily quantified. TVA staff, on the other hand,
point out that the public (especially conservation district members) recognize the need to
address pollution from multiple sources,


Cost Breakdown

       For the purpose of consistency among case studies, the TMDL  development
process is divided into the following six cost categories.  .

    •  Monitoring/Data Collection;
    •  Modeling;
    •  Analysis;
    •  Outreach;
    •  Public Participation; and
    •  Administration.
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                                                     Creek TMDL
           132s.
            652.
Cost
Funding Source(s1i
Federal and. Slate-
       Four institutions  have conducted data collection and monitoring for the Flint
 Creek TMDL at a total effort of 6.52 FTEs and a combined cost of $500,662 to date.
 TVA has dedicated 2.15 FTEs at a cost of $102, 375 and $7,500 in equipment to the data
 efforts thus far.  All of TVA's funding  is from federal appropriations.   GSA has
 contributed 4.34 FTEs to this point,  at a cost of $215,077.  GSA's funding  for data
 collection came from a Section 319 Grant and state matching funds. NRCS, using federal
 appropriations, has supplied 0.03 FTEs to assist with data collection to date, at a cost of
 $938.   The U.S.' Geological Survey (USGS) contributed stations for water quality
 monitoring at a cost of $174,772 over two years.    . -   .

       A  preliminary objective  of the Flint Creek  TMDL  was  to  use available
 information on mainframe data bases to  assess water quality in Flint Creek.  Therefore,
 ATJEM began its assessment of water quality by compiling all available information.
 This included  meeting  with  other state organizations  to  discuss  issues  related  to
 attainment of water quality standards, as well as coordination of future data collection and
 monitoring efforts. ADEM began its monitoring and data collection activities for TMDL
 development by adding all available information to  the Watershed  Screening and
 Targeting Tool (WSTT).

       Through a cooperative agreement, the GSA and ADEM are  conducting several
 additional data collection and monitoring activities on an ongoing basis. These activities
 include data collection from 13 surface water sites, 3 stormwater sites, 20 wells, and 31
 springs.  The surface water site parameters include: nitrogen; phosphorus; chloride; TDS;
 TSS; turbidity; pH; temperature; DO; BOD-5; conductance; discharge; and fecal coliform
 and streptococci bacteria counts. With the exceptions of TDS, TSS, turbidity, DO, and
 BOD-5, the parameters for ground water samples are the  same.  Additionally, water pH,
 conductance, temperature, and DO are continuously recorded at two surface water sites.
 USGS water quality  monitoring stations provide some  of these data.   Water quality
 reports are developed and issued at three month intervals.

       The Environmental  Services Division of USEPA and ADEM conducted other
•monitoring activities, including two months of benthic macroinvertebrate sampling at ten
 surface water sites in  the lower part of the Flint Creek watershed.  USEPA and ADEM
 also conducted water quality monitoring at 11 sites along Flint Creek and  three sites
 along Crowdabout Creek.   Water analysis parameters included nitrogen, phosphorus,
 chlorophyll-a,  algae  growth potential  (AGP),   TOC,  TSS,  pH,  temperature, DO,
 conductance, and sediment (sieve) analysis.

       m addition, TetraTech received a TMDL mini-grant to do a loading analysis in the
 hydrologic unit  area (HUA).  This analysis was conducted using data other than that
 compiled by GSA.                             '
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       Finally, the Tennessee Valley Authority (TVA) conducted a pollutant loading
analysis based on aerial photography of land types and land uses, including agriculture
and animal activity in the basin, and urban activity.  This aerial inventory of nonpoint
sources was conducted using an Excel spreadsheet and was initiated primarily to estimate
loads based on a literature review of nonpoint sources.
                       Modeling for the Flint Creek TMDL
                                     i -,  £ "" ^ ,> •"     < **
                                   "  . 'Cost'
                                     "
           LOO
Funding Sourcefs)
     State
       ADEM is conducting all point source modeling for the Flint  Creek TMDL.
ADEM's effort so far consists of one FTE working for a year at an estimated cost of
$55,000. State appropriations are funding the modeling effort.

       As noted  above, ADEM's  modeling efforts  began with adding all available
information to WSTT.  WSTT is a flexible, user-friendly, and relatively low cost PC-
based model developed by Region IV and Tetra Tech for use hi the TMDL program.
WSTT allows users to select and prioritize watersheds using available data from a
number of mainframe  data bases,  as well as user-defined objectives and criteria.  In
addition to prioritizing capability, WSTT also contains a watershed screening model that
can estimate pollutant  loading, assess pollutant sources and be used as an additional
targeting criteria.

       After compiling all available information, ADEM used WSTT to  perform a
preliminary  screening  level  evaluation of Flint  Creek and  associated neighboring
watersheds.  Next, ADEM performed a more detailed analysis using specific mainframe
queries and geographic mapping.  These preliminary applications of WSTT provided a
test of the capabilities and limitations of the1 model, identified additional  outstanding
information, and provided a review of currently available information on a more site-
specific basis.

       ADEM and Region IV used additional grant funding to continue to expand the use
and applicability of WSTT in Alabama.  As part of this process, a wasteload allocation
study was conducted to collect data and calibrate  a new modified Streeter-Phelps (S-P)
model and a QUAL2E model to set discharge limits for the-Hartselle WWTP. As part of
this process, a potential DO depression was identified downstream of the WWTP.

       ADEM is using QUAL2E to determine the point source WLA. The Department
is also using QUAL2E to ascertain'the flow necessary for attainment of Flint Creek's use
classifications. ADEM staff point out that while other viable models exist, QUAL2E was
deemed most appropriate for use on Flint Creek because it has been EPA approved and
has a algal option.
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                        Analysis fw the FKttt Creek TMJ>L
                                     . Cost
           7,00
                                    Fuading Sourcefs)
                                     Federal and State
       Three agencies—NRCS, GSA, and EPA—share the costs for analyses to support
the TMDL.  NRCS has  contributed 4.9 FTEs at a cost of $274,375; GSA has dedicated
1.9 FTEs at a cost of $128,332; and EPA has provided 0.2 FTE at a cost of $12,500.
Federal appropriations are funding EPA and NRCS' analysis activities.  GSA's revenue
sources are Clean Water Act Section 319 Grant funds and state matching funds.

       EPA analysis activities included work on nonpoint source loading, and loading
estimates were based primarily on GSA data.  In addition, EPA used monitoring data
collected for the flux portion of the Army Corps of Engineers "BATHTUB" model to
incorporate additional pollutant loading calculations for nonpoint sources.  Other EPA
analysis activities involved work developing TMDLs, including reading related materials,
and case studies.                                     .

       In addition, Terra Tech received grant funding to determine a preliminary TMDL
for the Creek.  This TMDL was based on loads from the WWTP  as well as runoff
estimates from the surrounding watershed.  Loads  estimated for the nonpoint  source
portion of the model will be used with the WWTP load information as input to the
QUAL2E model.    ADEM  informatixpn  will  be  used  to  estimate in-stream  DO
concentrations at different locations along the creek.    i-         ,
           0.04
Qytreachforthe Mint Creek TMDL
               Cost
              $1,875
Funding Sourcefe)
    Federal
       The Alabama Cooperative Extension Service provides some water quality related
outreach, however, the costs for the Flint Creek TMDL have been computed as if the
local NRCS office is handling all of the outreach.  So far, the office has dedicated  0.04
FTEs at a cost of $1,875. To date, outreach activities related to TMDL development have
included Watershed Conservancy District Meetings and development and distribution of
a project newsletter.
Public Participation for the Flint Creek TMDL
FTEs „' Cost
s 0.02 ' , $t,73l
Funding Sotircefs)
Federal '
      , ADEM, the local soil and water conservation districts, and NRCS are all involved
with public participation activities, however, the costs for the Flint Creek TMDL have
been computed as if TVA is the sole  agency conducting  activities related to public,
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participation.  The agency is using its federal appropriations to fund 0.02 FTE at a cost of
$1,731.
                    Administration/or the mint Creek TMDL
                                                          ferndfag
           1.14
ami State
      Three agencies—GSA, ADEM, and NRCS—are involved in the administrative
aspects of the Flint Creek TMDL.  GSA has used federal grant money and state matching
funds to pay for  0.13 FTE at cost of $10,931.  ADEM has employed state general
revenues to fund  one FTE for administrative tasks at  a cost of $37,500.  NRCS has
dedicated 0.01 FTE to administrative tasks at a cost of $625.  In addition, TVA has also
plays a limited role in administration of the Flint Creek TMDL, costs for TVA's efforts
were not available as of the date of this report.

      Administrative  activities for the TMDL include:  scheduling, organizing, and
conducting Flint Creek TMDL technical committee meetings; development of summary
reports  and progress updates; and  other  general  grant  administration  and  staff,
coordination activities.
For more information contact:

Tony Cofer
Alabama Department of Environmental Management
Nonpoint Source Section
1751 Congressman W.L. Dickinson Drive
P.O. Box 301463
Montgomery, Alabama 36130-1463
Phone (334) 271-7783
Fax (334) 279-3051
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                       HILLSDALE LAKE, KANSAS
Key Features
Title:
Location:  ' ,
    f       f    S
Size/Scope:
Comparative Size:
Poiltttant(s):
Sources of Pollutants:
Model Use and Complexity:


Total Cost
Funding Scarcest
 ESJlsdale Lake..
 Miami County, eastern Kansas; USEPA Region Vfl.
- 134.5'sq«are mile watershed.-
 Medium, tilW mi2.   "                          f
- .Phosphorus, nitrogen, arid chlorophyll-a,
 Point sources — Gardner wastewater treatment plant (WWTP);
 Edgeifoa WWTPj Joteson Coroty Air Industrial Park WWtP;
 Conaestoga Mobile Home Park. Lagoon; Lone Elm Estates
 Lagoon; and Bdgertbn Quany Pond Discharge,
 Nonpoint sources — -"widespread agricultural fields and. animal
 holding areas,
 BUTROMOD 2,50 developed specifically for xise in lake
 eufroplhicafiiaaijjanagerneni was used to run simple sitrffilaffons of
 fhe lake and poflutioii processes.,
 BPA C3ean Water Ae| Section, f 04 Q>) (3) jionpointsowce TMDI/
 mini-grant;
Summary

       The Kansas Department of Health and Environment (KDHE), Office of Science
and Support conducted a nutrient loading study and developed a TMDL for Hillsdale
Lake!  KDHE initiated the TMDL process  for Hillsdale Lake primarily as a result of
concerns about increased nitrogen and phosphorus  nutrient  loading and the desire to
develop eutrophication criteria for the lake.  A secondary purpose for undertaking.the
TMDL included estimation of chlorophyll-a levels.  Concerns about eutrophication and
nutrient loading are due to rapid urbanization in areas surrounding the lake.  Pollution
problems  are  caused by the six municipal  point  source dischargers and numerous
agricultural nonpoint sources.

       The  surface  area of Hillsdale Lake,  used  to develop the TMDLs,  was the
conservation pool area of 4,580 acres. Mean lake depth, as supplied by the Army Corps
of Engineers, was  estimated as 5.3 meters within the conservation pool area.  Hillsdale
Lake drains a 134.5 square mile watershed, a significant portion of which is covered by
forestlands, particularly as compared to most large Kansas  lakes.  In fact, nearly 20
percent of the  Hillsdale Lake watershed is wooded,  the  majority of which  is along
riparian corridors and the lake shoreline. Agricultural lands and urban areas are the other
key features of the watershed. Designated uses of the TMDL area include:  aquatic life
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support; drinking water supply; contact recreation; and aesthetic quality for general non-
contact recreational use.
       As illustrated in Table 7, KDHE's total in-house effort for the Hillsdale Lake
TMDL to date is 0.42 FTE, for a total cost is $21,934.  Some factors, such as the age of
the waterbody and  the availability of historical, loading data,  simplified the TMDL
process and lowered costs. Other factors, such as the abundance of point and nonpoint
sources, complicated the TMDL process.  KDHE maintained management authority and
conducted all of the field work for the project, utilized information collected by the Army
Corps of Engineers and the U.S. Geological Survey.  KDHE's intent was that a Hillsdale
Lake TMDL work group be the driving force behind the TMDL, but dischargers were
reluctant to participate.

       Expenditures to date for the TMDL to date will provide benefits initially through
modification and  reissuance  of the permitted  point source discharges.  However,
development pressures and land use changes, make it uncertain that long term water
quality standards will continue  to  be  fully met.  Therefore, continued monitoring is
planned to detect any future water quality violations. Furthermore, subsequent to verified
attainment  of the waterbody's  beneficial uses,  further  mitigation measures  may be
initiated to address future water quality violations.

       In FY 1992, KDHE received a nonpoint source 104(b)(3) mini-grant from EPA in
the amount of $10,000 to develop the TMDL for Hillsdale Lake.  State general revenues
supplied additional funds for salaries, monitoring, data collectionj nonpoint source load
assessments, model calibration, and other activities.
Table?. Summary of TMDL Costs for Hillsdale Lake
Activity
Monitoring/Data Collection
Modeling
Analysis
Outreach/Public Participation
Administration***
TOTAL
KDHE FTEs*
0.08
. 0.30
0.04
0.00
0.00
0.42
Cost ($)
6,642**
13,478
1,728
86
0
. 21,934
Cost as % of Total
30.2
61.4
7.8
0;3
0.0
99 7#*##
*1 FTE (Average) - $44,928:
**Includes $3,186 of donated laboratory services.
***Administrative costs are included in the other costs as an indirect charge of 20 percent.
****Cost as a percent of total does not add to exactly 100 as a result of rounding.
Cost Analysis

       KDHE's decision to undertake the level of effort that it chose for Hillsdale Lake
was dictated by two primary factors: modeling and data collection requirements for
TMDL development.  Because  KDHE obtained a TMDL/nonpoint source mini-grant
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from EPA it was able to devote considerable resources to its data collection and modeling
activities. Relative to the contentious nature of the TMDL, KDHE spent relatively few
resources on outreach  and public participation activities.  Had further resources been
available, KDHE would  have been able to conduct more outreach activities, possibly
reducing the controversy surrounding the TMDL.

       A portion of the  costs of conducting the TMDL, such as data collection,  are
shared by other water quality initiatives, such as water quality assessments, water quality
inventories,  and NPDES  support.  For example, KDHE,had  compiled several years of
ambient water quality data on Hillsdale Lake outside of any TMDL related activities. In
addition, certain activities necessary to develop the TMDL generated information that is
useful for other water quality programs, increasing the  cost-effectiveness of the TMDL.
For example, water quality samples and data collected as part of the TMDL development
process were compared to data provided by point source dischargers for the renewal of
their NPDES permits.

       KDHE minimized its TMDL development costs by working with the six point
source dischargers to  obtain water  quality  data.  KDHE  alsa leveraged its TMDL
activities by using available water quality data whenever possible. Particularly useful
was  the  ambient water quality data base  that had been  compiled for Hillsdale Lake
beginning in 1985. KDHE also used the department's  lab for its water sample analysis
needs. This arrangement saved approximately $3,186 in data analysis  costs that KDHE
would have incurred had it utilized an outside lab.  KDHE also sought additional funding
to aid its TMDL efforts. In 1992, KDHE sought and received  an EPA TMDL mini-grant
in the amount of $10,000. Future KDHE funding plans include  a FY 1996 request for a
federal Section 319 grant in the amount of $600,000 for a Hillsdale Lake water quality
project.

       The immediate benefits of the Hillsdale Lake TMDL include the development of
WLAs for the six point source discharges, as  well as an assessment of nonpoint sources
and their water  quality impacts relative to point sources.  Furthermore, KDHE staff
developed in-lake eutrophication criteria that will have future  applicability to Kansas
lakes with  similar pollutant and  demographic characteristics.   In addition,  both the
development of the TMDLs and the in-lake eutrophication criteria provided KDHE with a
better understanding of the potential impacts of rapid urbanization in an area of the state
which is expected to have sustained growth. Finally, KDHE gained a greater knowledge
of the TMDL process and associated costs.


Cost Breakdown

       In reporting its costs, KDHE has combined outreach and public participation into
one cost  category. Administrative costs have been combined with other costs  of the
TMDL as a 20 percent indirect charge on other activities. For the purpose of consistency
among case  studies, the TMDL development process is divided into the following six
cost categories:
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       Monitoring/Data Collection;
       Modeling;
       Analysis;
       Outreach;
       Public Participation; and
       Administration.
Monitoring/Data
In-house FTEs
0,08
Collection for the JEfittsdate Luke
Cost
$6,642' '
TMPL
Bunding Sourcefe)
State , ['f
       A number of organizations conducted water quality monitoring for Hillsdale Lake
TMDL development. The primary point source dischargers—Gardner WWTP, Edgerton
WWTP, Johnson County Air Industrial Park WWTP, Connestoga Mobile Home Park
Lagoon, Lone Elm Estates Lagoon, and Edgerton Quarry Pond Discharge—regularly
conduct monitoring in conjunction with their discharge permit requirements.  KDHE
monitors the lake  frequently as part of Kansas' conventional ambient  water quality
monitoring activities. KDHE began initial monitoring and .sampling from Hillsdale Lake
in 1985.

       In addition  to its normal water quality monitoring, KDHE conducted additional.
monitoring for model calibration and final TMDL development. In order to calculate
point source inputs, KDHE collects qualitative samples for total nitrogen  and total
phosphorus, at  intervals, over a one-year period, along with flow estimates  for the
lagoons and pond.  KDHE used flow data collected by staff at the mechanical plants to
develop a comprehensive picture of Lake flow dynamics.  Furthermore, KHDE obtained
effluent nutrient data from dischargers to compare with other data KDHE  staff had
collected.

       Monitoring  and sample collection took place over a one year period. During this
time, KDHE collected effluent samples in order to include seasonal variations, as well as
weekly and daily  variations in  wastewater treatment  plant discharges  to the  extent
possible. Data collection efforts were somewhat constrained by the inability to sample
over weekends, holidays, and during nighttime hours.

       There are two primary methods to conduct monitoring and data collection used to
model waterbodies.   KDHE's selected  method involves cross-sectional models and
available empirical data to develop TMDLs. This approach required less expenditure of
existing resources  and  allowed for a more rapid  examination of alternatives. An
alternative method that entails collecting empirical data over a long enough time period to
be able to construct a pollution budget for the lake and watershed is also available, but,
this approach requires a long time-frame and a relatively large amount  of money for
sampling and analysis.
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       Because KDHE has access to ambient water quality monitoring records for Lake
Hillsdale, collected as part of an ongoing project, it spent relatively little to collect
additional data specific to TMDLs. A total of 160 hours of staff time provided the level
of effort needed to gather necessary data.  In addition, the TMDL effort received routine
laboratory services worth $3,186  (converted to 1995 dollars).  The state paid for data
collection.                                  ,
               Modeling for the Hffisdvle take TMDL
   '         ,        "                   '
In-hoaseFTEs   ,      '          Cost
    '03        *            ,   $13,478  '        %   -
                                                            Fuadlag Sotirce(s.)
       Modeling for TMDL development of Hillsdale Lake has evolved to account for
changes in the lake as well as the region. Hillsdale  Lake is the newest  of the federal
reservoirs built in the state, and located just southwest  of the second-largest urban area in
Kansas.  In 1985, KDHE determined that Hillsdale Lake was potentially threatened by
urbanization and/or increasing point source discharges  within the watershed.  As a result^
KDHE developed a simple desk-top nutrient load modeling study of the watershed.  The
study concluded that urban point source loadings were having a detrimental impact on the
lake and that future increases would result in excessive  eutrophication.

       The study remained in draft form until  1989 when additional  empirical data the
KDHE Lake and Wetland Monitoring Program had collected was incorporated into the
model.  To confirm the results of the KDHE desk-top  study, Johnson  County, _a primary
stakeholder, undertook a nutrient load study of Hillsdale lake during the period 1989-
1990. This initiative, while confirming the validity of  the KDHE desk-top modeling, did
not yield the data necessary to produce a long term annual average nutrient budget for the
lake and watershed.  As a result, in 1992, KDHE applied for and received a TMDL mini-
grant to conduct nutrient budget modeling and produce  TMDLs for Hillsdale Lake.

       In 1993, KDHE used EUTROMOD  2.50  to  analyze phosphorus and nitrogen
Ipading into the  lake and watershed.   EUTROMOD was developed  by the Duke
University School of Forestry and Environmental Studies for use in lake eutrophication
management, with an emphasis on uncertainty analysis. This model was based on earlier
work  hi the southeastern United States, and combined  with region specific-algorithms to
make it applicable to much of the contiguous United States. While KDHE had previously
used EUTROMOD on smaller watersheds, this was its  first attempt to use the model on a
medium-sized waterbody.                       .

       Having  established  total  point  source nutrient loading  for phosphorus  and
nitrogen, KDHE next turned its attention to  nonpoint sources.  Almost since the  lakes
creation in 1982, KDHE has collected water quality data on Hillsdale  Lake.  As a result,
an extensive data base of water quality data currently exists. From this data, KDHE
computed historic  whole-lake  nutrient Concentrations  and used  them for model
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calibrations and to extrapolate mean water  quality estimates using long-term water
quality comparisons.

       Finally, KDHE staff utilized EUTROMOD to compute nonpoint source nutrient
load estimates. Based on the modeling efforts, KDHE determined that crop production,
point source discharges, and feedlots were nearly equal contributors of phosphorus to the
Hillsdale Lake watershed.  The largest source for  nitrogen is cropland, followed by
pasture land, point sources, and direct precipitation to the lake.

       While EUTROMOD did a fairly good job of estimating the point source loading
to the lake, it was somewhat less effective in determining nonpoint source contributions
for the watershed portion. This was primarily a result of the large size of the  watershed,
and the resulting inability to clearly identify pollutant trapping zones during land use data
collection.  If more resources had been available, KDHE could have  collected more
nonpoint source  data,  thereby accounting for  more pollutant  trapping zones,  and
increasing the nonpoint source load portion of the model.

       Modeling costs are equivalent to one staff person spending 30 percent of his/her
time, or  0.3 FTEs.  With the  20 percent indirect  charge, this effort represents a cost of
$13,478.  Along with state funding, federal grant funds were applied to the modeling
efforts.
Analysis for the IffltsdateLake TM&L
In-house FTEs Cost
0.04 ' $1,728
Funding Sourcefe1)
State , *
       KDHE's analysis  activities  in  conjunction  with  TMDL  creation included
development of waste load allocations (WLA) and load allocations (LA) for phosphorus
and nitrogen within the Hillsdale Lake watershed. KDHE also conducted an extensive
literature review on in-lake eutrophication criteria and later  used  the information to
develop site-specific eutrophication criteria for Hillsdale Lake.  Eutrophication criteria
developed for use on Hillsdale Lake, KDHE's first  TMDL,  will be  used  to  address
Kansas lakes with similar pollutant and demographic characteristics in the future.  KDHE
staff spent a total  of 80 hours to complete these activities  for the  TMDL.   The state
covered the cost for this staff time.
           Outreach and Public Participation for the Hittsdate Lake TMDL
       fti-house FTEs
           0.002
$86
Funding Sottrcefs.)
     State
       To involve the public in the TMDL process, KDHE published a public hearing
notice to solicit oral and written comments from interested parties.  KDHE also held a
nonpoint source meeting in Kansas City to present the project and address  questions
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concerning the TMDL.  The staff time required to .conduct these outreach and public
participation activities was minimal, approximately 4 hours.   The state provided the
funding for this staff time.
                   Administration for the ffiltedaleLake TM&I*
       In-lious&PTEs
        %  indirect  ,
Cost
Fundin
       As mentioned previously, KDHE wanted to form a Hillsdale Lake TMDL work
group.  Costs associated with initial coordination and start up of this initiative, while
minimal, were incurred as part of the TMDL development process. More recently, Clean
Water Act Section 319 funds have also been directed to this group.  The current title of
this workgroup is, the Hillsdale Lake Water Quality Project.  Work group meetings have
included:  discussions with officials at the wastewater treatment plants regarding options
for attaining water quality standards; meetings with the agricultural community to discuss
the relationship between land uses and water quality; and othef general organizational
efforts.
          '          '    ,            - -      "              * -
       KDHE incurred additional costs for staff time required to conduct scheduling and
other general administrative activities.  Finally, KDHE drafted a report to present  the
findings from model simulations and highlight the need for the TMDL.  Costs for these
activities are computed as an indirect charge of 2Q% on other TMDL activities.  This
indirect charge roughly equates to $7,488 per FTE,  which means that approximately
$3,145 of the total cost-of the TMDL was spent on administrative activities. The state,
through KDHE's budget, paid all of the administrative costs.
For more information contact:

Ed Carney
Kansas Department of Health and Environment
Science and Standards Section
Office of Science and Support
Forbes Field, Building 283
Topeka, Kansas 66620-0001
-Phone (913) 296-5575         :         ;
Fax (913) 291-3266
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               LITTLE DEEP FORK CREEK, OKLAHOMA
 Key Features
Title:
Location:

Size/Scope:
Comparative Size:
Pollutant(s):

Sources of Pollutants:
Model Use and Complexity:

Total Cost
Funding Sources:
sLitfie Deep Fork Creek      '
 Central Oklahoma; City oiFBristewand Town, of Bepew,- USEPA
 Region YL  "        -        -   '
 Affected watershed 240 mia.
 Medium, ^JOOO mi2.
 tow dissolved oxygen, suspended solids, phosphorus, chlordane,
 andtorbldiry.    '-
 Pointsourceg include:  two WW$P$ one each ffo1 the City of'
 Bristol and: Tows of Depew arid numerous storm sewers.
 TsTonpoint sources include: surface runoff, petroleum activities,
 non-irrigated crop production,, specialty crops, pasture land and
 range land,  '            -      '
 QUAL2Etif a, one~djocaensionar$teady.-gtate njodelswas used to twx
 laid-range 
-------
       As illustrated in Table 8, INCOG and OCC's total in-house effort on the Little
Deep Fork Creek TMDL is estimated to be 6.S7 FTEs, for a total cost of $401,576.
INCOG and OCC, which share authority over the project, have received assistance from
several other federal, state, and local institutions in conducting the TMDL.

       Some factors, such a£ the availability of historical water quality data, confirmation
of data quality and stability from earlier studies of the stream, and the presence of only
two primary point sources, simplified the  TMDL process.   Other factors, such as  the
abundance of nonpoiht sources, the number of entities working on the TMDL, the fact
that this was the first TMDL undertaken by-INCOG, and the intricacy of the modeling
effort, complicated the TMDL process and required additional resources.

       In FY 1992, INCOG received a 604(b) grant from EPA in the amount of $19,712
to conduct water quality monitoring activities within Little Deep Fork Creek.  In  FY
1993, INCOG received a 104(b)(3) grant in the amount of $15,000 to conduct initial
phases of the TMDL for the Little Deep Fork River including determining the stability of
the DO problem and conducting land use studies to identify potential nonpoint sources.
In addition, INCOG agreed to contribute at least $790 in staff time and other project
costs.  Recently, OCC  obtained a FY 1995  Section  319(h) grant in the amount of
$323,285 to conduct the final phases of the Little Deep Fork Creek TMDL.  Matching
funds in the amount of $215,523 for the activities conducted under the Section 319 grant
will be supplied from state general revenues. Additionally, a number of federal and state
agencies are participating in the study and will fund their contributions through their own
operating budgets.  INCOG and OCC indicate that all .phases of the Little Deep Fork
TMDL can be folly funded with the existing INCOG grants and .the 319(h) grant received
by OCC.

       The  costs outlined in this analysis represent only those expenses  incurred by
INCOG and OCC.   Monitoring and data collection  activities required  the greatest
investment of resources.  For  these activities,. INCOG  and OCC will undertake an
extensive chemical  and  biological assessment of the waterbody, as well as land use,
stream riparian, and habitat assessments.  OCC received sufficient funds (within the  FY
95 319(h)  grant) for  development and implementation of best management practice
(BMP) demonstration projects, however, these  costs are not included cost  estimates
presented here, since they are implementation costs rather than development costs.
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Table 8. Summary of Projected TMDL Costs for the Little Deep Fork Creek
Activity
Monitoring/Data
Collection
Modeling
Analysis
Outreach
Public Participation
Administration
TOTAL
INCOG/OCCFTEs
2.26
0.23
0.11
2.60
1.16
0.51
6.87
Cost ($)
$204,720*
.$40,758**
$7,994
$85,275
$36,124
$26,705
$401,576
Cost as % of Total
50.9
10.1
1.9
21.2
8.9
6.6
99.6***
•"Includes $122,000 in capital costs.
"""Includes §24,000 in capital costs.
***Cost as a percent of total does not add to exactly 100 as a result of rounding.
Cost Analysis

       Availability of funding and the complexity of the pollution were major factors
that influenced INCOG and OCC to undertake the level of effort they chose for the Little
Deep Fork Creek TMDL.  The discovery of nonpoint contributing sources .during the
initial monitoring and modeling of the river was the primary impetus for initiating a more
in-depth, phased TMDL.  In addition, because INCOG received 604(b) and 104(b)(3)
mini-grant funding,  and OCC received a 319(h)  grant, they will be able to devote
substantial resources  to monitoring and data collection activities. This effort will include
extensive data collection  and analysis  activities,  performance  of  reference  stream
reconnaissance, and water quality monitoring.

       It is anticipated that the information obtained as a result of this TMDL will serve
future  TMDL  development  efforts within  the Little  Deep  Fork Creek  watershed.
Additionally, the water quality methods developed under this TMDL should also generate
information that is useful for other water quality programs statewide.

       During the initial phase of the TMDL process, INCOG and OCC will collect
existing information  relating to the watershed from other organizations. A number of
government agencies will be contributing hours toward the TMDL that  will not  be
covered by the three grants received by INCOG and OCC.  These contributions are
considered a part of the normal operating budget and function of the respective agency.
For example, INCOG and OCC  will work with the City of Bristow  and the Town of
Depew to acquire point source discharge data from their respective wastewater treatment
plants. In addition, both the City of Bristow and the Town of Depew will participate in
public participation activities related to TMDL development. The Oklahoma Department
of Environmental  Quality  (DEQ)  will  be providing discharge  data, reviewing and
commenting  on the  draft TMDL report, conducting  any  necessary  formal public
participation activities related to the TMDL, and processing the NPDES permit revisions.
Oklahoma State University Extension Service will  perform land  use assessments and
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modeling  under contract to OCC.   The Office of the Secretary of Environment will
administer the grants and coordinate all formal communication among agencies.  The
U.S. Natural Resources Conservation Service will provide land use data, and help to
establish BMPs and education programs with local landowners. Finally, the U.S. Fish
and Wildlife Service will assist with watershed improvement programs.

      , The  primary measure of success  for the Little Deep Fork  TMDL  is the
improvement of water quality in the vicinity of the towns of Bristow and Depew., Such
improvement will enable the segment to assimilate effluent from the Bristow and Depew
and maintain downstream water quality standards.

       Other measures of success are the number of BMPs implemented and the number
of structural measurers implemented.  BMPs  will be established'for the reduction of
nutrients  and  sediments  to  the   creek.    Decreased  sediment  loads  improve
macroinvertebrate and fish habitat and increase oxygen concentrations by reducing SOD
and aquatic plant respiration.  While implementation of BMPs  is considered integral to
the success of the TMDL, such implementation costs are not calculated here.

       Other benefits  of the TMDL are the reduction and or  elimination of nonpoint
sources of nutrient loading within the Little Deep Fork Creek watershed.  With these
reductions, INCOG and OCC can  develop final wasteload allocations  for  the  two
municipal dischargers.   In  addition,  dissolved oxygen  stress  will be reduced  and/or
eliminated within the  study area. Finally, the TMDL process should improve water
quality awareness within the watershed and help to create an atmosphere of cooperation
with local landowners.
Cost Breakdown

       For the purpose of consistency among case studies, the TMDL development
process is divided into the following six cost categories:
   •   Monitoring/Data Collection;
   •   Modeling;
   •   Analysis;                       .
   •   Outreach;
   •   Public Participation; and
   •   Administration.        •
         Momtoringfflata Collection for the Little Deep Fork Creek TM&L
           2.16
  Cost
$204721)
Fuading Source(s)
Federal and. State
       In T989, INCOG conducted an "intensive 24-hour survey" of several portions of
the Little Deep Fork Creek for the purposes of model calibration. INCOG intended to use
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this model to develop waste load allocations for the City of Bristow and the Town of
Depew waste water treatment plants (WWTPs). As part of this effort, parameters relating
to model development for DO were measured.  Based upon data from this study, EPA
concluded that it was likely that nonpoint sources of nutrients were impacting the creek.
As a result, wasteload allocation development was confounded and EPA recommended
that INCOG conduct a phased TMDL for Little Deep Fork Creek.

       The second phase of the TMDL will begin with a characterization of nonpoint
source loading into Little Deep Fork Creek. OCC began this assessment by compiling all
available land use information.  This compilation included a review of a 1985 land use
data base,  interpreted from satellite data.   OCC also plans a  ground-based land  use
inventory  to update the 1985 information and provide a more accurate picture of land
uses within the study  area.  This effort will  focus  on the stream  riparian corridor.
Additionally, a set of aerial photographs of the riparian corridor will be purchased as a
supplement to the information gained through the ground-based land use inventory.

       For the  next part of the nonpoint source load characterization, OCC plans to
contract with Oklahoma State University (OSU) to provide loading estimates of nutrients
and sediments within the  TMDL watershed.  In addition, OCC staff plan to conduct
stream riparian area and  instream  habitat  assessments.   Upon completion of these
assessments, all riparian and instream habitat data will be entered into  the OCC GIS. A
three to four day water sampling exercise will  be. conducted within stream segments
suspected of contributing to water quality problems (e.g., sites in high cattle use areas or
within the urban watershed).

       In addition.to its nonpoint source load characterization, OCC plans to conduct a
variety of  ambient water quality monitoring  activities in conjunction  with TMDL
development, including:

       •   Collection of three years of monthly low flow samples at five sites;
       •   Conducting  annual  fish  collections  and  quarterly benthic  invertebrate
          collections to compile three years of biological data to assess attainment of
          beneficial uses and improvement in water quality;
       •   Setting monthly periphytometers during the first and last years of the study to
          measure stream productivity;
       •   Monitoring diurnal dissolved oxygen profiles at four sites  (split among low
          dissolved oxygen areas and areas  upstream of discharges) each summer over
          two 24-hour periods; and
       •   Monitoring (including biological and habitat assessment  and four months
          water quality sampling) of three reference streams to ascertain achievable
          water quality goals.

       INCOG's costs for its data collection and monitoring activities are computed as
the equivalent of one senior environmental planner working for two months, one civil
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engineer working for one month, and one project manager working for approximately 17
hours, over a three-year period (0.26 FTEs). This staff time translates into a cost of
$19,070, which will be paid for by the federal 604(b) grant and other funding sources.

      OCC will dedicate 2 FTEs as well as approximately $122,000 to  cover capital
costs, for activities related to data collection and monitoring. This translates into a total
cost of $185,650, which will be funded 60 percent through federal grant funds and 40
percent through state general revenues.
           0.231
Modelmgfor the LMe Deep Fork Creek
                    Cost   ,
                   $40,758
Foading Sotircefe)
Federal and State
       INCOG used the QUAL2EU model to develop the original wasteload allocation.
INCOG anticipates that it will use either this model or QUALTX (a version of QUAL2
developed by the Texas Water Commission and popular with EPA Region VI) to develop
the actual TMDL for both point and nonpoint sources.

       QUAL2EU is a one-dimensional, steady state model.  While there are several
quasi-dynamic models that could be used that might better simulate nonpoint source
impacts on the stream, INCOG staff believed that calibration of such models is extremely
difficult and would not be cost effective. Furthermore, INCOG already has developed the
QUAL2EU  model using the most recent data, data whose  accuracy  was confirmed
through INCOG's first phase studies of the stream. Finally, QUAL2EU and QUALTX
allow for nonpoint source loading, enhancing their usefulness in this type of study.

       Upon completion of nonpoint source load estimates from the first phase of the
OCC FY 95 319(h) study, INCOG will recalibrate'the QUAL2EU model to incorporate
nonpoint loading estimates.  This will involve recalibration of the  existing allocation
model using the 1989  data set,  adjusting CBOD decay rates, and  inputting nonpoint
source loads using incremental flow functions.                         -  •    .' •
                                     •.]        ? \
       INCOG's costs for its modeling activities are computed as the equivalent of one
senior environmental planner working for two months and one project manager working
for approximately one-half month, over a three-year period (0.21  FTEs).  This staff time
translates into a cost of $15,904 which will be funded through INCOG general revenues,
the FY 93 104(b)(3) mini-grant, and other sources.

       OCC will dedicate  0.02 FTEs as well as approximately $24,000  to cover capital
costs for activities related to modeling.  This translates into a total cost of $24,854, which
will be funded 60 percent through  federal grant, funds and 40 percent through state
general revenues.
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Analyst.
FTBs
0,11
? far foe Little Deep Fork Creek TMDL
$7,994 - Federal
       Upon completion of nonpoint source loading estimates, INCOG will develop the
initial TMDL which will set new allocations for both WWTPs. INCOG will base these
WLAs on the assumption that there will be a significant decrease in nonpoint source
loading due to implementation of BMPs which are planned for the implementation phase
of the TMDL.  The TMDL may be revised in the future if water quality goals are not
fully achieved after BMP implementation.

       INCOG's costs for analysis activities related to this TMDL are computed as the
equivalent  of one  senior environmental  planner  working for one  month, one  civil
engineer working for approximately one  week, and one project manager working for
approximately 17 hours, over a three-year period. INCOG staff tune translates into a cost
of $7,994 which will be funded through the INCOG FY 93 104(b)(3) grant.
Outreach for the Little Deep
Tn-house FTEs Cost '
2.6 $85,275
Fork
Creek
TMDL
Funding: Sourcefe)
Federal and State
       Public education programs conducted in conjunction with the BMP demonstration
projects are the primary outreach activities associated with the Little Deep Fork Creek
TMDL. As part of this effort, a citizen advisory group will be formed to educate land
owners about structural and cultural best management practices which  can reduce or
control nutrient and sediment loading. The citizen advisory group will also have project
oversight  responsibilities  and will  coordinate  project  developments  with  local
governments and private stakeholders.   OCC will dedicate a half-time water quality
specialist to this project to assist land owners, write conservation and waste management
plans, and conduct public education programs.

       INCOG's costs  for its  outreach activities are computed as the equivalent of one
senior  environmental planner working for one month and one civil engineer working for
approximately one week, over a three-year period (XX10 FTEs). This staff time translates
into a cost of $7,150 which will be paid with pass-through funding from the FY 95 319(h)
grant and matching funds of 40 percent from INCOG.

       OCC will dedicate 2.5 FTEs to activities related to outreach. This translates into a
total cost of $78,125, which will be funded 60 percent through federal grant funds and 40
percent through state general revenues.
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          Formal Public Participation for ike Little Peep Fork Creek TMDL
                                       Cost
                                     $36424'
                        PtmxKng Sourcefe)
                        federal and State'
       To  date, no formal public participation activities  (i.e., public "notices, public
hearings, etc.) have been part of TMDL development. Should formal public participation
activities  become necessary,  they would be the responsibility of the  Oklahoma
Department of Environmental Quality (DEQ), the state's primary regulatory entity.

Additional public  participation activities include watershed education meetings.   For
example, OCC plans to target small groups  of land owners in sub-watersheds and
communities  within the Little Deep Fork watershed  for educational/organizational
meetings to increase awareness of land-stream interactions.  Educational efforts will
include presentations of the nature of the problems within the watershed, costs and
consequences. Finally, these meetings  also will serve to recruit and enroll landowners in
the BMP demonstration program.                                         <

       INCOG's  costs for  its public participation activities  are  computed  as the
equivalent of one senior environmental planner working for one-half month and one.civil
engineer working for approximately 52 hours, over a three-year period (0.07 FTEs)  This
staff time translates into a cost of $4,884 which will be paid with pass-through funding
from the FY 95  319(h) grant and state general revenues.

       OCC will dedicate 1.09 FTEs to activities related to public participation.  This
translates into a total cost of $31,240,  which will be funded 60 percent through federal
grant funds and 40 percent through INCOG match.
               Administration for the Uttle&eep Fork Creek ?MI)L
           0,51
 -Cost
$26,705
Funding Source(s)
|?ederal and Sfate
       One of the first administrative tasks of the. TMDL was to establish and formalize a
cooperative agreement between INCOG and OCC that defined roles and responsibilities
as well as billing procedures for work conducted.  Generally, OCC will provide project
management for the FY 1995 319(h) grant and conduct most of the field work.  INCOG
will act as the technical lead for the stream model, the TMDL, and waste load and load
allocations.  INCOG will also assist with field work,  review of data, and reports,  and
public education activities.
            '             * "       •                      ••              .'.,.'
       A project advisory group will be established to coordinate multi-agency interests
and review activities associated with TMDL development.  This  advisory group will
serve the dual purpose of: (1) establishing data quality objectives and providing technical
assistance; and (2) involving stakeholders directly affected by the outcome of the TMDL
on an ongoing basis.   Government agency  involvement  includes:   INCOG; OCC; the
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Creek County Conservation District Board of Directors; the Town of Depew; the City of
Bristow; EPA; the Office of the Secretary of the Environment; the Oklahoma Department
of Environmental Quality; and Oklahoma State University Cooperative Extension.

       Other administrative costs associated with this TMDL include development of
QA/QC plans, QA oversight, grant administration, staff coordination, data entry,  and
document preparation tasks. Data entry tasks include inputting all riparian and instream
habitat data into the OCC GIS and entering all water quality data acquired into the EPA
STORET system.  Finally, INCOG  and/or OCC will  produce  a variety of reports,
updates, and  other written documentation throughout the TMDL development  process.
Project outputs will include:

       •  Letter reports of all formal agreements between INCOG and OCC;
       •  Minutes and attendance of proceedings at quarterly project advisory  group
          meetings;
       •  A quality assurance/quality control  (QA/QC) plan for all data collection
          activities;
       •  A report summarizing the land use inventory update;
       •  A report summarizing stream riparian and habitat assessment  data for the
          Little Deep Fork Creek and selected tributaries;
       •  A report  summarizing watershed modeling for nutrients and  sediments
          including data from calibration;
       •  Letter reports of all watershed education meetings,  including documentation
          of publication of meeting announcements, number of attendees, agenda,  and
          program enrollees;
       •  Quarterly progress reports on BMP implementation activities; and
       •  Quarterly  and  final reports to document TMDL progress, number of land
          owner contacts, results of awareness surveys, post implementation monitoring,
          and documentation of overall TMDL process.

       INCOG's costs for its administrative activities are computed as the equivalent of
one senior environmental planner working for one month and one civil engineer  working
for approximately 15 days,  over a three-year period  (0.13 FTEs).   This  staff time
translates into a cost of $10,062 which is to be paid with pass-through funding from the
FY 95 319(h) grant and INCOG matching funds.

       OCC  will dedicate 0.38  FTEs  to activities  related to administration.   This
translates into a total cost of $16,643, which will be funded 60 percent through federal
grant funds and 40 percent through state general revenues.
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For more information contact:

Richard Smith
Indian Nations Council of Governments
201 5th Street, Suite 600
Tulsa, Oklahoma 74103-4236
Phone (918) 584-7526
Fax (918) 583-1024
E-mail 71072.2365@compuserye.com

-or-.,

Philip Moershel
Oklahoma Conservation Commission (OCC)
1000 West Wilshire, Suite 123
Oklahoma City, Oklahoma 73116
Phone (405) 858-2008
Fax (405) 842-8744
E-mail phmoersh@ionet.net
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              LOWER MINNESOTA RIVER, MINNESOTA
Key Features
Title:
Location:
Size/Scope:
Comparative Size:
PoButant(s):

Sources of Pollutants:
Model Use and Complexity;

Total Cost
Funding Sources:
 Lower-Minnesota Rivet.
 Southern Minnesota; I/SEPA Region V.
 25 mile river segment; 320 square mile drainage area.
 Carbonaceous biochemical oxygen demand {CBGD} and
, ammonia.
 Point sources — Bine" Lake WWTP and Seneca WWTP,
               V     ""                   f    S "* f    •&,
 Nonpoant sources—agriculture and residential and commercial
 development       , ,        --     '-         '    ' -•;
 ine&MA.-l2 model was nsedto run complex simulations of river
 and pollution processes.      ,         '      ,   *    ,
  '-*'• *• *w    *                          •"•.-*    ,. ,
 5775,000.  -     - -   -       '           ,'-,';,

 State operating budget, which includes, support from Federal and
 Local sources of revenue,      '"           -   '"-"':
Summary

       The Minnesota Pollution Control Agency (MPCA) initiated the TMDL process
because  the  lower Minnesota River was experiencing  violations  of water  quality
standards for both dissolved oxygen and ammonia. These violations were being caused,
in part, by point source discharges from two wastewater treatment plants.   Nonpoint
source loading from agricultural operations, and residential and commercial  development
also was contributing to violations.  MPCA has been conducting TMDL-related activities
for the lower Minnesota River since 1974, when the agency conducted its first intensive
stream survey on the lower segment. The TMDL was considered complete in 1987 when
discharge limitations  were imposed  on the two wastewater treatment plants.  Other
actions, however, which are not included in this cost analysis have been conducted since
1987 that relate to this  TMDL.   Routine monitoring has continued and MPCA has
conducted further modeling and analysis of the river, especially with respect to nonpoint
source problems.

       The lower Minnesota River is a 25 mile segment at the terminus of an agricultural
basin that drains 16,770  square  miles.    The 320  square  mile watershed supports
agriculture and residential and commercial development.  This segment of the river has
two designated use classifications that are delineated at river mile 22.  Upstream from
river mile 22, the river must  support cool  or warm water fish and must be suitable for
aquatic recreation of all kinds.  Downstream from river mile 22, the river is classified as a
rough fishery suitable for boating but not recommended for swimming.
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     .  Due to the long period of time over which activities were conducted for this
 TMDL (1974 to 1987), all cost figures have been converted to 1995 dollars using a price
 index for state and local government purchases.

       As illustrated in Table 9, MPCA's total in-house effort on the lower Minnesota
 River TMDL is 3.56 FTEs, at a total cost of $775,000. MPCA received some assistance
 from the Metropolitan Council in  managing the TMDL work, but it maintained almost
 exclusive authority over the project.                                  .

       The TMDL process undertaken to achieve and maintain water quality standards in
 the lower Minnesota River was fairly complex.  Several factors, such as the presence of
 two wastewater treatment plants,  the frequency of water  quality violations,  and  the
 ongoing need for extensive monitoring and analysis of data, contributed to the complexity
 of this TMDL.   Nonpoint source  pollution  from the upstream watershed  further-
 complicated this TMDL. MPCA considers nonpoint source control to be an integral part
 of the TMDL process.  However, activities such as nonpoint source modeling that have
 occurred since 1987 are not included in this cost analysis.              ,         /

       Revenues for the TMDL primarily came from MPCA operating budgets. These
 state budgets, however, include some revenues from federal  and local sources.  Because
 the TMDL process was incorporated into broader program activities, a precise breakdown
 of funding sources is unavailable. Local funds, which were provided by the Metropolitan
 Council, generally paid for monitoring, laboratory analysis, and river survey costs.
Table 9. Summary of TMDL Costs for the Lower Minnesota River
Activity ,
Monitoring/Data Collection
Modeling and Analysis '
Public Participation and Administration
TOTAL
MPCA FTEs/
0.40
2.83
0.33
3.56
Cost ($)
621,000
138,000
16,000
775,000'
Cost as % of Total
80.1
17.8
2.0
99.9*
*Cost as a percent of total does not add to exactly 100 as a result of rounding.
Cost Analysis

       MPCA was prepared to  devote considerable resources to addressing problems
within the Minnesota River watershed. The sizable expenditures on monitoring and data
collection stem from the fact that MPCA wanted to collect information with a much
higher level of detail than could be obtained through normal monitoring and analysis
procedures.  MPCA uses its Water Quality Management Plan to prioritize river segments
where pollution problems may threaten human health..  The prioritization process placed
the Minnesota River as the highest priority waterbody in need of pollution controls.
Similarly, MPCA's substantial expenditures on modeling and analysis are due to the fact
that the agency used a state-of-the art model and analyzed many scenarios.
                                    Page 85

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       Many MPCA activities within the TMDL process were part of broader programs
and their costs are not considered part of the TMDL. Therefore, only those costs that are
definitely attributable to the TMDL have been estimated.  Even so, some expenditures
attributable to the TMDL have produced information that is useful for other water quality
programs. Thus, the TMDL may have produced cost savings for other aspects  of water
quality protection.

       According to MPCA  staff, the expenditures on the lower Minnesota TMDL
produced several benefits for the watershed. Both wastewater treatment plants upgraded
then- systems to include advanced secondary treatment, increasing levels of dissolved
oxygen and  decreasing levels  of ammonia and resulting  in  overall  water quality
improvements.  In addition, the TMDL process has spurred a basin-wide  effort to assess
and control nonpoint source pollution.


Cost Breakdown

       The lower Minnesota River TMDL has been an evolving process since its
inception in the mid-1970s when MPCA began studying the river.  For the purpose of
consistency among case studies, the TMDL  development process is divided  into the
following six cost categories:
    •   Monitoring/Data Collection;
    •   Modeling;
    •   Analysis;
    •   Outreach;
    •   Public Participation; and
   ' •   Administration.
In reporting its costs, MPCA has  combined modeling and analysis into a single cost
category, and  also has combined public participation and administration into one
category. In addition, the agency has discarded outreach as a category.
          Monitoring/Data Collectwn for the Lower Minnesota Ssver
        In-house FTEs
           0.40
Cost
  Funding Semrce(s) ,
State, Local,. andBederal
       Costs associated with monitoring/data collection consist of staff time necessary to
conduct two intensive stream surveys, laboratory analysis of the samples, and the cost of
two additional studies on sediment oxygen  demand and algal productivity.  The first
intensive stream survey occurred in 1974, and the second, along with the two  studies,
occurred in 1980. These intensive stream surveys provided much more information than
routine monitoring.
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       Routine monitoring has been in place  on the lower Minnesota since  before
 initiation of the TMDL process. MPCA conducts monthly sampling from one monitoring
 station, and the Metropolitan Council conducts weekly and bi-monthly sampling  at five
 stations. While data collection and analysis from routine monitoring have been important
 to the development of the TMDL, the cost of collecting these data is not included in the
 cost of the TMDL.  MPCA and the Metropolitan C9undl would have conducted this
 monitoring in the absence of the TMDL.

       MFCA's cost for the  first intensive survey is based on  eight staff scientists
 working 45 hours each plus a cost of $60,000 to analyze water quality samples. The total
 cost of this survey in 1995 dollars is $190,000.  The cost for the second survey is based
 on eight staff scientists working 60 hours each plus a cost of $180,000 to analyze water
 quality samples. The total cost of the second survey  is $340,000 in 1995.dollars.  In
 addition, the  studies on sediment oxygen demand and algal productivity cost $50,000, in
 1980, or $91,000 in 1995 dollars. The cost displayed in  the box above is the sum of all of
 MPCA's monitoring/data collection costs converted to 1995 dollars. This cost was paid
 by MPCA's  operating budget, which includes  some  revenues from  federal  and local
 sources.
            Modeling and Analysis for the Lower Minnesota River TMDL
       3b-houseFTEs
          '2.83
   Cost
-$138,000
  Funding SoTtrce(g)
State', Local,, and Federal
       In 1985, MPCA used RMA-12, a derivative of the Qual H model, to determine
waste load allocations for the lower Minnesota. At the tune it was used, RMA-12 was a
state-of-the-art model for waste load allocation.  The model simulated a wide variety of
water  quality constituents and  physical  processes, including phytoplankton  algae,
chlorophyll-a, CBOD, dissolved oxygen, benthic oxygen demand, atmospheric re-
aeration, organic nitrogen, ammonia  nitrogen,  nitrite nitrogen^ nitrate  nitrogen,  and
orthophosphate.  Subsequent to the RMA-12 model (after the "end" of the TMDL project
in 1987), MPCA developed a Hydrologic Simulation Program-Fortran (HSPF) model to
assess  the effects of nonpoint source pollution loads on water quality in the Minnesota
River.  MCPA's costs for modeling and analysis of modeling results directly attributable
to the TMDL process are related only to the RMA-12 model. Since the HSPF model was
developed after 1987, the cost of development and analysis is not included as a cost of the
lower Minnesota TMDL.

       For development of the RMA-12 model, one engineer spent approximately three
months. This translates into a cost of $11,000 in 1985, which converts to a 1995 cost of
$15,000. For analysis of model results, a staff scientist spent approximately 31 months,
which corresponds to a 1985 cost of $88,000 (or $123,000 in 1995 dollars).  The cost in
the box above provides these 1985 costs converted to 1995 dollars.  MPCA paid this cost
with its state operating budget/which includes revenues of federal and local origin.
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    Administration and Public Participation for the Lower Minnesota. River TMDL
fo-houseFTEs
    0.33
 Cost
£14f)00
                                                           Fundin
                                                         State, Local, sad Federal
       MPCA's administrative and public participation activities for the lower Minnesota
TMDL involved close interaction with the Metropolitan Council and public notification
under, the NPDES permitting process for the two wastewater treatment plants. For these
activities, two MPCA staff people spent two months each, at a cost of $12,000 in 1987
($16,000 in 1995 dollars).  MPCA paid this cost out  of its operating budget, which
includes federal and local funds along with state revenues.
For more information contact:

Ron Jacobson
Minnesota Pollution Control Agency
Water Quality Division
520 Lafayette Road
St. Paul, Minnesota 55155
Phone (612) 296-7252
Fax (612) 297-8683
                                     Page 88

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                   OIL BRANCH CREEK, OKLAHOMA
Key Features
Title:
Location:
Size/Scope:
Comparative Size:
Poa«tant(s);
Sources of Pollutants:
Model Use and Complexity:

Total Cost
Funding Sources?
 Oil Branch Creek.          , ..  ,              "
 C% of Heavener, southeastern OHa&oma; USEPA Regies VL
 5 square nule watershed,
 Low dissolved oxygen,
 Point sottr-ees — pry of Heavener wastewater treatmentplant.
 Nonpoint sources— Pasture lands (No TMDL activities were
 conducted iornoapoint sources),
 Simple model developed on spreadsheet software for personal
. computers.        - -                    t   '  ' '
 State 1M revenues, which ODEQ receives frorn.BPA* and
 revenues from issuance of permits
Summary

       The  Water Quality Division of the Oklahoma Department of Environmental
Quality (ODEQ) completed a TMDL for Oil Branch Creek in the fall of 1994. ODEQ
initiated the TMDL prpcess for Oil Branch Creek to address low dissolved oxygen levels
in the creek, attributed to wastewater discharge from the City of Heavener.

       Oil Branch Creek drains a five square mile watershed. The watershed consists of
30 percent urban lands, 20 percent pasture lands, arid 50 percent forest. While 70 percent
of the watershed consists  of forest and pasture lands,  ODEQ did not address these
nonpoint sources in the TMDL process.  The designated use of the creek is warm water
aquatic habitat.

       As illustrated in Table 10, ODEQ's total in-house effort on the Oil Branch Creek
TMDL is 0.08 FTE,  for a total cost of $4,039. ODEQ was the sole agency involved in
developing the TMDL.  Because of the relative simplicity of the watershed and the
pollution problems, ODEQ did not dedicate significant resources to this TMDL.
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Table 10. Summary ofTMDL Costs for Oil Branch Creek
Activity
Monitoring/Data Collection
Modeling
Analysis
Administration
TOTAL
ODEQ FTEs
0.04
0.02
. 0.01
0.01
0.08
Cost ($)
2,115
962
481
481
4,039
Cost as % of Total
52.3
23.8
11.9
11,9
99.9*
*Cost as a percent of total does not add to exactly 100 as a result of rounding.
Cost Analysis

      The Oil Branch Creek TMDL was relatively simple and did not require some of
the activities of a more complex TMDL.  ODEQ did not have extreme data needs or a
necessity to conduct outreach or involve the public.  Equipment for this TMDL also was
already available to ODEQ staff.

      According to ODEQ staff, the expenditures on the  Oil Branch Creek TMDL are
producing positive impacts for the region.  The TMDL process may prevent future
downstream water quality impairment.
Cost Breakdown

       For the purpose  of consistency  among  case studies, the TMDL development
process is divided into the following six cost categories:
   •   Monitoring/Data Collection;
   •   Modeling;
   •   Analysis;
   •   Outreach;
   •   Public Participation; and
   •   Administration.
ODEQ determined it was unnecessary  to contact land owners and therefore did not
conduct any outreach or public participation activities for the Oil Branch Creed TMDL.
Thus, only four cost categories are presented below. All of the costs for the TMDL were
funded by state 106 revenues, which ODEQ receives from EPA, and revenues from the
issuance of permits.
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            Monitoring/DataCollection for the Oil Branch Creek TMDL
     Ik-bouse FTB&
         &04
$2,115
        Funding Soureefs)
State 106 Funding ami Pennk Funding
       ODEQ's costs associated with monitoring and data collection consist of staff time
to travel to the site and conduct a brief study involving flow measurement, cross-sectional
analysis, dye analysis, and dissolved oxygen inspection.  No follow-up monitoring has
been conducted yet. After ODEQ  estimates new limits on the Heavener wastewater
treatment plant, it will conduct follow-up monitoring. The cost for monitoring and data
collection is based on two ODEQ staff spending 44 hours total.
                    Modeling for fheQit Branch Creek TMDL
     In-house FTBs
         0.02
 Cost
 $962
        Funding Sourfcefs)
State IQOnndiag and Permit Funding
       ODEQ designed and used a relatively simple spreadsheet model to simulate the
ecology of the creek.  One modeler spent a total of 40 hours developing the model on
standard spreadsheet software.
                     Analysis for tite Oil Branch Creek TMDL
     In-house FTEs. ' s            Cost       "    •          goading Souroefe)
         &01	.$481	'	State aOfrFimdigg and Petmif Pooding
       ODEQ's analysis activities for the Oil Branch Creek TMDL involved evaluating
collected data and setting limits on the wastewater discharges from Heavener. One staff
spent a total of 20 hours conducting these activities.
                  Administration for the Qtt&ranch Creek TMDL
     In-honse FTBs
         0.01
 Cast
 $4S1
       Funding Sonrcefs)
State-106 Funding and Permit Funding
time.
       Administration of TMDL activities involved 20 hours of one ODEQ staff person's
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For more information contact:

Bob Bednar
Oklahoma Department of Environmental Quality
Water Quality Division
1000 NE 10th Street
Oklahoma City, Oklahoma 73117-1212
Phone (405) 271-7360 ext. 202
Fax (405) 271-7339
                                  Page 92

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           SOUTH FORK OF THE SALMON RIVER, IDAHO
 Key Features
Title:
Location:
Size/Scope:
Comparative Size:
B9llirtairt(s):   ,
Sources of Pollutants:
Model Use and Complexity:

Total Cost
Funding Sources;
 South Fork, of the Salmon Rivet
 Central Idaho- USEPA Region X.
 River ibifc; 370 square mile watershed.
 !Vfediuia,<1000nji?,
 Sedanest                   ,
 Paint sources—None.'                   r       '  ,'"

 Nonpoint sources—Silviculture* togging roads, and natural
 erosion..
, Rigorous, localized calculations, as well as the mid-range BOISED
 model were used to simulate river and'sedimentation processes,
 $19,363.
 The State operating budget provided funding fox all of the co,sts,
 althoughFsderal agencies -did support the TMD-L process through
 in-kind services.
Summary

       Idaho Division of Environmental Quality (IDEQ), along with its federal partners,
initiated a TMDL for the South Fork of the Salmon River to supplement the US Forest
Service's  managerial efforts aimed at stopping the declining trends in anadromous fish
populations.   The  1988  Idaho Water Quality Status Report  and  Nonpoint  Source
Assessment listed several segments  of the river as water quality  limited due to  fine
sediment.   Sediment loading, to which forestry activities contribute, is believed to be a
primary cause of lower numbers  of chinook salmon  and steelhead  trout hi the  river
(hydroelectric dams and fishing pressure are other causes). The IDEQ received approval
from EPA in 1992 for the TMDL it developed.

       The  South Fork Salmon  River  is part of a 370  square mile basin where
forestlands, mountains,  and meadows dominate the landscape.  The Boise and Payette
National Forest cover most of the basin, and forestry and tourism constitute the majority
of economic activity in the area, the  South Fork system also is highly valued as a habitat
for chinook salmon, and steelhead trout.

       As illustrated hi Table 11, IDEQ's total in-house effort for the South Fork TMDL
is 0.42 FTE, for a total cost of $19,363. IDEQ received substantial assistance, including
cost-sharing,  technical assistance,  and managerial help, from the United States Forest
Service (USFS) and EPA.  Currently, the TMDL is not phased. If monitoring and future
events warrant further efforts, however, this TMDL could launch into a  second phase.
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       Overall, several factors affected the complexity of this TMDL.  The fact that
sediment was the only pollutant of concern simplified the modeling and analysis aspects
of TMDL development for the South Fork. The availability of historical monitoring data
also bolstered TMDL development.   The multi-jurisdictional nature of this  TMDL
increased coordination efforts, but should prove helpful for implementation of BMPs,
most of which will be implemented on federal lands.

       IDEQ's operating budget supplied funds  for state employees to participate in all
aspects of the TMDL process, including coordinating with federal agencies. The Forest
Service and EPA both  contributed considerable financial and technical resources to
develop the South Fork TMDL.
Table 11. Summary of Idaho's TMDL Costs for the South Fork Salmon River
Activity
Monitoring/Data Collection
Modeling
Analysis
Work Group Negotiation
Public Participation
Administration
TOTAL
IDEQ FTEs
0.10.
0.08
0.06
0.02
0.08
0.08
0.42
Cost ($)
4,062
4,400
2,818
939
3,412
3,732
19,363
Cost as % of Total
20.9
22.7
14.5
4.8
17.6
19.2
99.7*
*Cost as a percent of total does not add to exactly 100 'as a result of rounding.
Cost Analysis

       Public support for a  healthy  fishery,  as well as Forest Service and EPA
involvement were significant factors in determining the level of effort expended for the
South Fork Salmon River TMDL.  Because public support for re-establishing a healthy
fishery is high, the IDEQ had backing to expend substantial resources.  With the Forest
Service and EPA's involvement in developing the TMDL, IDEQ was able to leverage its
resources to accomplish TMDL goals.  As a result, IDEQ was able to conduct state-of-
the-art analyses using specialized technical information without  incurring significant
costs.

       Some of the costs of conducting the TMDL, such as data collection, are shared by
other water quality initiatives  at both the state and federal levels. For  example, both
IDEQ and the Forest Service would monitor and analyze water quality in  the absence of
the South Fork TMDL.  In addition, coordination costs for the South Fork TMDL  can
decrease future coordination costs, as avenues for cooperation are already available.

       IDEQ worked closely with federal agencies to tailor the TMDL to minimize costs
and leverage  its own resources.  The Forest Service and EPA played a vital role in the
work group that developed the TMDL.  In addition, IDEQ used available resources, data,
and the expertise of experienced staff to make decisions efficiently.
                                     Page 94

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       According to IDEQ staff, the expenditures on the South Fork TMDL produced
several benefits for the watershed, including:  :
  .  •  Development of a remedial framework and strategy through which the Forest
       Service can work to improve water quality in the stream;
    •  Development of monitoring criteria  to assess the effectiveness  of remedial
       projects, including a feedback mechanism that allows managers to implement the
       appropriate amount of remedial work; and
    •  Improvement in sediment load levels and concurrent improvement in beneficial
       uses (e.g., increased salmon population) which will not be realized immediately—
       sediment balance improvements in streams occur over periods of five to ten years.


Cost Breakdown

       For the  purpose of consistency among case studies, the TMDL development
process is divided into the following six cost categories:
    •  Monitoring/Data Collection;
    •  Modeling;
    •  Analysis;
    •  Outreach;
    •  Public Participation; and
    •  Administration.
        Monitoring/Data Collection far the South Fork Salmon River TMDL
       in-house fTBs
           0.10
 Cost
$4,062
Funding Skmrcefe)
     State
       IDEQ spent relatively little on monitoring and data collection for the TMDL
because USFS researchers have been monitoring sediment in the South Fork for 25-years
prior to TMDL development.  Monitoring and data collection continued through the
TMDL process, and effectiveness monitoring will be conducted by IDEQ to  determine
the necessity of further actions. The cost for monitoring and data collection consists of
two IDEQ scientists spending a total of five weeks of time.  Under the management of
USFS, the South Fork  Monitoring Committee  has conducted the majority  of data
collection.  The Committee's costs are not included in this analysis because they would
occur in absence of the TMDL. In addition, capital costs for monitoring equipment are
not included.
                                    Page 95

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       In-house FTBs
           0,08
Modeling for tlte South Fork Salmon River TMDL
                     Cost        '           Funding Source(s)
                    $4,400^
     State
       IDEQ used the BOISED variant of the R1/R4 model to simulate sediment loading
to the South Fork.   The model calculates estimated sediment yields from the Idaho
Batholith soils. IDEQ  considered other models, but judged the BOISED model to be
superior.  In addition, IDEQ scientists used sophisticated, site-specific calculations to
estimate sediment loads from the South Fork Salmon River Road. IDEQ contributed the
services of one staff for one month to the modeling effort. In addition, USFS researchers
provided valuable technical assistance for the modeling process.
                 Analysis for the South Fork Salmon River TMDL
       Jn-houseFTEs
           0.06
                     Cost
                    $2,818
Funding Sotirceffi
     State ,„
       The South Fork Salmon River TMDL was developed by a work group comprised
of USFS land managers, and IDEQ and EPA hydrologists and government regulators.
Analysis efforts for the TMDL focused on three main issues:  (1) establishing numeric
goals for instream conditions; (2) allocating loads among various sources of sediment;
and (3) designing BMPs to slow sediment transport.  Work group members selected a
core set of sediment reduction projects designed to meet  the numeric standards.
However, the group also chose an additional set of projects that will be implemented if
the initially selected ones fail to achieve water quality standards. For this analysis effort,
two IDEQ staff spent a total of three weeks of time.
          WorkGroup Negotiation for the South Fork Salmon River TMDL
       Tn-house FTEs
           0.02
                     Cost
                      $939'
Funding Sottrcefs)
     Sbrte
       In reporting its costs, IDEQ has replaced the "Outreach" category with "Work
Group Negotiation." Work group negotiation refers to attending interagency meetings to
discuss how to manage various aspects of the TMDL process.

       IDEQ and its federal partners established a work group to develop the South Fork
TMDL.  This work group was composed of land managers, hydrologists and regulators
from IDEQ, USFS, and EPA. In. order to coordinate with other members, two IDEQ staff
spent a combined total time of one week in work group meetings.
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            Public Participation for the South Fork Salmon Mver TMDL
       In-house FTEs
 Cost
$3*412
Funding Sonrce(s)
     State
       The draft TMDL underwent a public comment process, which produced revisions
for a final TMDL.  IDEQ staff also produced a summary document responding to all
comments received during the public comment process.  For this  public participation
effort, two IDEQ staff spent a total of 168 hours.
              Administration for the South Fork Salmon River TMDL
                                      Cost
                                     $3,732
                      Funding Sourcefe)
                            State
       One IDEQ manager spent 168 hours handling administrative activities..  The
Forest Service also contributed substantial resources to project administration, but its
costs are not included here.                            '
For more information contact:

Geoff Harvey
Idaho Division of Environmental Quality
2110 Ironwood Parkway
Coeur d'Alene, Idaho 83814
Phone (208) 769-1422
Fax (208) 769-1404
                                    Page 97

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                    SYCAMORE CREEK, MICHIGAN
Key Features
Title:
Location:
Size/Scope:
Comparative Size:
Pollutants):
Sources of Pollutants:

Model Use and Complexity:


Total Cost
Funding Sources:    	
Sycamore Creek.           \
Ingflaai County; southern. Michigan;. USEPA Region V.
Total afitected watershed, 106 mi2;, subwatershed 37 mi*

Small; ^JDO'rai4,    \
             H  t ,,   ''../"                s
Sediment,  <  *            '           ,
               ••  S    ••   *rSf    f        •"     f
Nonpointsources—agricultural erosion, stream bank; etosioc, and
xirban runoff* Taree load allocations (LAs) developed*
A simple 
-------
 discharges into Sycamore Creek, a municipal plant, the Mason Wastewater Treatment
 Plant (WWTP), provides advanced treatment for the City of Mason.

        As depicted in Table 12, MDNR's Surface Water Quality Division (SWQD) total
 in-house effort for the Sycamore Creek TMDL, to date is 4.0 FTEs, for a total cost of
 $202,000.  MDNR received assistance from  several agencies  conducting the  TMDL
 work, but maintained primary management authority over the project.  MDNR modeled
 and produced final LAs for sediment within Sycamore Creek. Work completed to date
 producing the TMDL for total suspended solids (TSS) has occurred as  Phase  I of the
 TMDL process. MDNR plans to conduct follow-up monitoring for this pollutant.  All
 revenues for TMDL development were derived from state general funds.
Table 12. Summary of Sycamore Creek TMDL Costs
ACTIVITY
Monitoring/Data Collection
Modeling
Analysis
Outreach/Public Participation
Administration
TOTAL
MDNR FTEs
2.2
0.9
0.7 .
. 0.0
0.2
. 4.0
Costs ($)
111,000
46,000
- 34,000
0"
11,000
202,000
Cost as % of Total
54.9
22.7
16.8
0.0
5.4
99.8*
 *Cost as a percent of total does not add to exactly 100 as a result of rounding.
 Cost Analysis

        The level of expenditures on the Sycamore Creek TMDL to date were dictated by
 four principal factors: (1) lack of historical monitoring data; (2) the number of nonpoint
 source contributors; (3) the extensive modeling and analysis efforts undertaken; and (4) a
 lack of experience conducting TMDLs. Despite the relatively small watershed size, the
 lack of historical data drove the need for extensive data collection and monitoring efforts.
 The three different types of nonpoint  sources—bank erosion, agricultural runoff, and
 urban runoff—complicated the modeling effort. Finally, MDNR inexperience conducting
 TMDLs added,to the expense of the project.  This was because more effort went into
 research and selection  of methodologies (i.e., evaluation of models,  appropriate data
 collection methods,  etc.),  literature  reviews,  analysis,  writing,  and  other  TMDL
 development activities because the Department had no  institutional knowledge to serve as
 a base for TMDL activities.

     ,   The Sycamore Creek TMDL represented a unique  opportunity for MDNR to
 leverage its TMDL development resources by utilizing overlapping resources from other
 water quality initiatives being undertaken within the  watershed.  For example, several
 government  agencies are  working on activities related to the USDA funded Sycamore
 . Due to the inseparability of public participation/outreach costs from other. TMDL activities, the cost is
, recorded as $0.                                                       ,
                                      Page 99

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Creek Hydrologic Unit Area (HUA) project and the Ingham County Health Department
has received grant money to conduct ground water monitoring within the watershed.

       Several costs associated with the TMDL may have been incurred by MDNR in the
absence of development of TMDLs for Sycamore Creek.  Many of these costs, such as
monitoring and  data collection, also  occur as part of MDNR's other water quality
initiatives. In addition, extensive water quality monitoring was undertaken as part of the
HUA project. Finally, in 1995, MDNR applied for and received a CWA  Section 319
National Water Quality Monitoring Program Project grant.

       According to MDNR staff, direct water quality benefits from the TMDL will be
realized after implementation of Phases II and El (follow-up monitoring will determine
progress). MDNR staff anticipate that reducing  sediment loading will improve water
quality by:                                                            '

    •   Increasing oxygen concentrations by reducing SOD and aquatic plant respiration;
    •   Improving fish and microinvertebrate habitat;
    •   Providing a firmer stream bottom that is more appealing for recreation; and
    •   Deepening the channel, thereby improving navigation potential.

Finally, MDNR  staff feel that the  Sycamore Creek TMDL was an invaluable learning
experience because the creek is similar in its both geographic and pollutant features to a
number of creeks throughout lower Michigan.   Therefore,  MDNR staff feel that by
selecting a TMDL with a pervasive problem which is applicable to a number of other
creeks they have increased the long-term cost effectiveness of the TMDL.
Cost Breakdown

       For the purpose of consistency among case studies,  the TMDL development
process is divided into the following six cost categories.

    •  Monitoring/Data Collection;
    •  Modeling;
    •  Analysis;
    •  Outreach;
    •  Public Participation; and
    •  Administration.

       With  the  exception  of costs related to public participation  and educational
outreach, costs outlined  in this analysis represent only those expenses incurred by
MDNR.  For the purposes of this analysis, outreach and public participation have been
combined into one category because all outreach and education related activities were
conducted by the Ingham Soil Conservation District and the Ingham County Cooperative
Extension Service (CES). The Ingham Soil Conservation District received a Clean Water
Act (CWA) Section 205(j) grant from USEPA and CES received USDA HUA project
                                    Page 100

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 area grant funding to provide educational outreach to the farmers and general public
 within the watershed.

        Overall, monitoring and data collection activities required the greatest investment
 of MDNR resources.   One-time  expenses included outreach, public participation,
 analysis, and administrative activities. Ongoing expenses include monitoring and model
 recalibration to account for water quality changes.
           Monitoring/Data Collection Costs far the Sycamore Creek TMDL
            23.
  Cast
$111,000'
Funding Sourcefe)
   '  State
        After biological surveying revealed, that Sycamore Creek was not meeting its
 designated uses, MDNR undertook an extensive monitoring and data collection effort to
 confirm results and develop models.  In addition to ongoing state ambient water quality
 monitoring initiatives, this endeavor comprised extensive channel surveying and land use
 studies, continuous  DO monitoring, and special monitoring to collect .sediment and
 nutrient loading data.

        MDNR has monitored the Sycamore Creek watershed on an ongoing basis since
. 1990.  Chemical monitoring parameters include total suspended  solids (TSS), turbidity,
 total phosphorus, total kjeldahl nitrogen, nitrite  (NO2-N) and nitrate (NO3-N), chemical
 oxygen demand (COD), orthophosphorus,(OP), and ammonia (NH3).   Other measured
 explanatory variables include rainfall, flow, and an erosion-intensity index.

        As part of its land use monitoring, MDNR measured channel dimensions and
 sediment depth at 49 sites in  the watershed using a survey rod and hand level.  In
 addition, in order to  determine how active channel erosion was at each site MDNR staff
 made observations of bank erosion and riparian vegetation.

        MDNR conducted continuous DO monitoring at eight locations.  Monitoring
 lasted from six to 103 days! at each location. In addition, MDNR conducted DO surveys
 twice with, sampling at nine locations  during  summer low flows  to provide data to
 calibrate a low flow DO model. MDNR also analyzed a 24 hour sample of effluent from
 the Mason WWTP as part of this study.

        Next, MDNR undertook a special water quality monitoring program during 1990
 and 1991 to collect sediment and nutrient loading information. This program monitored
 stormflow and baseflow water quality within  three subwatersheds—Marshall Drain,
 Willow Creek,, and Haines  Drain—from March through July of each project year.  The
 Haines Drain subwatershed is outside the Sycamore Creek watershed and served 2s a
 control. Best Management Practices (BMPs) were implemented within Haines Drain
 prior to the initiation of monitoring in 1990. This monitoring process involved collecting
 water quality samples  by hand  two times  each  month during baseflow and using
                                     Page 101

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automatic samplers at one to four hour intervals during runoff events.   MDNR also
monitored two urban watersheds using an automatic sampler at one and on half to four-
hour intervals. These watersheds were monitored to assist with the identification of urban
pollution sources.

       MDNR dedicated approximately two and one-quarter person years to its data
collection and monitoring efforts, which translates into a cost of $111,000.
Modeling Costs far the Sycamore
In-house FTBs ' % " Cost
0.9 $46,000
Creek TMDX,
Fufldiog Saurcefe)
State'
       Model development for the TMDL took place over a two year period beginning in
1990.  MDNR used a relatively simple, quasi-steady state DO model to predict DO"
concentrations in the creek during varying flow  conditions.   Modeling focused on
determining pollutant levels during drought conditions.  MDNR calibrated  the model
using  data  collected during the  1990-91  special monitoring  program, as  well as
continuous DO data collected at one location during the 1988 drought.

       Modeling indicated it was highly unlikely that  Sycamore Creek would  meet
designated DO standards during drought flow conditions.  As a result, MDNR estimated
sediment loads for all urban and agricultural subwatersheds.  MDNR used a simple urban
load estimation  model (Driver  and Tasker, 1988) to predict pollutant loads from the
Mason  urban area.   This  model  utilized rainfall,  drainage area,  impervious  area,
population density, and mean temperatures to predict sediment loading.  Department staff
used available city maps,  aerial photographs, and census population density values as
model inputs. Finally, MDNR used six years of available site-specific monitoring data
and simple regression models to calculate total suspended solid (TSS)  loads for each of
three agricultural subwatersheds.

       MDNR dedicated  approximately one person year to its data  collection and
monitoring efforts, which translates into a cost of $46,000.
Analysis Costs for the Sycamore Cr,eek
Jn-hoiiseFIEs . Costs
0.7 $34,000
TMDL
Funding Source(s)
Sfete '
       MDNR's  analysis activities  in conjunction with  TMDL creation included
development of LAs for the following sources of sediment: organic and loamy soil from
stream banks; agricultural fields; and urban runoff.  Analysis indicated that suspended
solids would have to be reduced by 52 percent in order to reduce DO levels sufficiently to
meet water quality standards at all locations.
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       MDNR dedicated a little less than three-quarters of one person year to performing
required analysis and development of appropriate TMDL levels, which translates into a
cost of $34,000.                                     .•'.''
Outreach and
iB-hottseFTEs
0,00
Public Participation Costs far the Sy
Cost
; /' $ow
camore Creek TMDL
Funding Sourcefs^
Federal and Xocal
       The Ingham County Cooperative Extension Service (CES) was responsible for all
information and education activities within the watershed.  Information, education, and
publicity  activities were developed and implemented in conjunction with the U.S.
Department of Agriculture  (USDA) Sycamore Creek Hydrologic Unit Area (HUA)
project.   Activities included public awareness campaigns; conservation tours;  media
events such as news releases and radio shows; display set-ups; workshops; short courses;
farmer-targeted newsletters; homeowner-targeted newsletters, on-farm demonstrations;
meetings; and presentations.  In fiscal year 1995, total public participation, education, and
outreach funding was $169,835.  This amount includes U.S. Department of Agriculture
Hydrologic Unit Area grant funding and local general revenues.  A portion of this
funding, which cannot be estimated,  was used for education and outreach activities
related to Sycamore Creek TMDL development.

       To date, MDNR has issued public notice of all completed TMDLs, but there have
been no  formal public hearings  or other, public  participation activities.   However,
jurisdictional issues involving different agricultural interests have brought federal, state,
and  local government agencies into the TMDL development process.   Government
agency involvement includes:  the Agricultural Stabilization and Conservation Service;
the  Ingham  County Cooperative  Extension  Service;  the  Ingham  County Health
Department; the Ingham Soil Conservation District; the Michigan Department of Natural
Resources; the USD A; and the USEPA.
                Administration Costs for the Sycamore Creek
       In-house PTEs
 Cost
SUvOOO
Fundmg Sourcefs)
    " State
       Administrative  costs  associated  with  TMDL  development  included grant
administration and staff coordination activities, as well as development of summary and
final  findings  reports about  different  aspects  of the TMDL.,   MDNR dedicated
approximately three months of one staff person's time to these efforts, which translates
into a cost of $11,000.                                                     ,
10
  Due to the inseparability of public participation/outreach costs from other TMDL activities, the cost is
recorded as $0.                                                 ,      •     •
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For more information contact:

John D. Suppnick
Michigan Department of Environmental Quality
Surface Water Quality Division
P.O. Box 30273
Lansing, Michigan 48909
Phone (517) 335-4192
Fax (517) 373-9958
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                        TRUCKEE RIVER, NEVADA
Key Features
Title;
Location:
Size/Scope:
Comparative Size:
PoUtttaptCs):
Sources of Pollutants?
Model Use audi Complexity:

Total Cost
Funding Sources:
   Truckee Blver,  '
   East^entral CalforniaYWesferriNevada- USEPA Region, EC
   Aflfected watersbed 2?300 rai2.
 " Large, > WOO mi*  ,
'  -Nitrogen; phosphorus,, total dissolved soKds.
   PpiatsoaEee& — oae discharger Trnckee Meadows Wastewater
   Reclamation Facility; 1^eev3steloadaItoealJ03Qs(WlA5)wei:e
   developed,         ,
   Nonpoiat sources-^uroerous irrigation return flows associated
 ,,  •wifh.area agricoltural activities. Three load allocations (LAs) were
.:•./„ developed.
  •-ft "~  s                                 '
   DSSAM in was used to run mid-iange simulations of river and
              sses* -
   $158,387.         %                       '
 '  Clean Water Aet{CWA) Section 205(3)5,, Section 205(0(1), and
   Section 6M(b) grants; State general revenues; Local general
 " revenues.                    ,      ' -
Summary            '

       The Nevada Department  of Environmental  Protection  (NDEP)  developed  a
TMDL for the Truckee River to address high levels of nitrogen and phosphorus loading
that, in combination with extended periods of low flow, have caused a variety of water
quality problems, including decreased dissolved oxygen (DO) levels in the river. Primary
sources of nitrogen and phosphorus loading  are the  Truckee  Meadows Wastewater
Reclamation Facility,  located  in Reno,  and  irrigation return flows associated with
surrounding agricultural activities. The fundamental objective of the TMDL was to attain
beneficial uses by improving the oxygen condition in the lower river through control of
nutrient loading.

       The Truckee River emerges from the California side of Lake Tahoe and flows
approximately 70 miles downstream to Pyramid Lake in Nevada.  The topography of the
river basin is mixed, ranging from high  mountains to plains  with both low and high
mountains. The Truckee River watershed stretches approximately 2,300 square miles and
is a closed hydrologic system.   Designated uses of the TMDL  segment of the river
include:   irrigation; livestock  watering;  water contact recreation; non-water  contact
recreation; industrial water  supply;  municipal and  domestic water supply; wildlife
propagation; and propagation of aquatic life.
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       As depicted in Table 13, NDEP's total  in-house effort for the Truckee River
TMDL to date is 1.01 FTEs, for a total cost of $158,387. NDEP received assistance from
several agencies conducting  Ihe TMDL work,  but maintained primary management
authority over the  project.  NDEP modeled and produced a final TMDL for nitrogen
within the Truckee River. Work completed to date producing TMDLs for phosphorus
and dissolved solids has occurred as Phase I of the TMDL process, with continued
follow-up monitoring for these pollutants.

       From FY 1990  through FY  1992, NDEP received Clean. Water Act (CWA)
Section 2050)5 grant funding in the amount of $14,729 to assist with its Truckee River
TMDL activities. In addition, in FY  1992, NDEP received CWA Section 205(j)(l) and
604(b) grant funding in the amount of $9,000.  Other funding for TMDL development is
provided by a variety of sources, state general revenues, county general revenues, and
municipal general revenues.
Table 13. Summary of Truckee River TMDL Costs
ACTIVITY
Monitoring/Data Collection:
Modeling
Analysis
Outreach
Formal Public Participation
Administration
TOTAL
NDEP FTEs*
0.55
0.00
0.17
0.19
0.02
0.08
1.01
Cost ($)
25,200
109,778**
7,576
10,707
1,009
4,117
158,387
Cost as % of Total
15.9
69.3
4.7
6.7
'0.6
2.5
99.7***
*1 FTE (Average) = $36,800
**This cost includes payments to contractors from NDEP, EPA, Washoe County, and cities.
***Cost as a percent of total does not add to exactly 100 as a result of rounding.
Cost Analysis

       The level of effort that NDEP undertook to develop TMDLs for the Truckee River
was affected by two primary factors: (1) ongoing federal financial support for model and
other TMDL development activities, and (2) niter-agency assistance with development
efforts. Grant money allowed NDEP to devote substantially more resources to modeling
than it otherwise would have. Inter-agency involvement in the process allowed NDEP to
leverage its expenditures on data collection and monitoring for TMDL development.

       NDEP devoted  a  relatively small  amount  of resources  to formal  public
participation  activities  associated  with the  TMDL.    Despite  some  controversy
surrounding the TMDL, the relatively low formal public participation costs indicate
success of the public  education and  outreach  activities undertaken  by  NDEP.
Recognizing  that  the waterbody has historically  been highly controversial,  NDEP
organized Truckee River Strategy meetings to  allow stakeholder involvement in the
TMDL development process on an ongoing basis. While cost savings from these efforts
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are not easily quantified, the relatively low formal public participation costs in what is
clearly a controversial situation are somewhat reflective of these savings.

      Several costs associated with the TMDL may have been incurred by NDEP in the
absence of development of TMDLs for the Truckee River. Many TMDL activities, such
as monitoring and data collection, also occur as part of NDEP's  other water quality
initiatives, such as, groundwater protection, nonpoint source control, issuing discharge
permits, and development of water quality standards.

      NDEP used multi-agency cooperation and available data to  minimize TMDL
costs  where possible.   As part of this  effort,  NDEP organized  multi-agency data
collection efforts  and split the  intensive  water quality  sampling required for TMDL
development among three agencies. These efforts saved approximately $12,600 in data
collection costs that NDEP would have  otherwise incurred.  In  addition,  whenever
possible, NDEP utilized available water quality data. Significant sourpes of data were the
1985-1987  river  modeling efforts, the  Truckee  Meadows Wastewater  Reclamation
Facility, (TMWRF), and DRI's data compiled as part of Nevada's  ambient water quality
monitoring activities.

      The TMDL resulted in WLA and LAs that NDEP staff believe resulted in water
quality  improvements.   Additional TMDL benefits included increased  coordination
among the different government agencies and other constituencies involved in the TMDL
development process.  Finally, the development of the TMDL allowed NDEP to assess
nonpoint sources and their water quality impacts relative to point sources.


Cost Breakdown

      The Truckee River TMDL has been an evolving process since its inception in the
mid-1980s when EPA provided initial grant money to model the river. For the purpose of
consistency  among case studies, the TMDL development process  is divided into the
following six cost categories.                                                ,  ?

    •  Monitoring/Data Collection;
    •  Modeling;
    •  Analysis;                 v
    •  Outreach;
    •  Public Participation; and     .
    •  Administration.

      With the exception of costs related to monitoring/data collection and modeling,
the costs outlined in this analysis represent only those expenses incurred by NDEP.  One-
time expenses  included outreach, public participation,  analysis,  and administrative
activities.  Ongoing expenses include monitoring and model recalibration to account for
water quality changes. Model development and ongoing modeling activities required the
greatest investment of resources.  For these functions, NDEP relied upon the expertise of
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 an outside consultant and support from EPA.  Throughout the TMDL process, NDEP
 built upon existing information and relied upon in-kind services from other organizations
 for their efforts in monitoring/data collection, public participation, and outreach activities.
 Among these only  monitoring/data collection costs  have been  captured  within this
 analysis because these are the only activities for which NDEP was able to accurately
 estimate city and county costs.
            Monitoring/Data Collection Costs for the Truckee River TMDL
             '                           s'       *        „'''',  V
        In-house FTEs                    Cost                  Funding Source(s)
	0.55	      $25^00	   Federal, State, an
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account for variations in flow. In addition, other factors have spurred reconfiguration and
upgrading of the model, including upgrades to the TMWRF, increased population levels,
and modified agricultural practices.                                                 .

       Model  development for the TMDL took place over an eight to ten-year period
beginning in the mid 1980s.  During the period from 1985 to 1987, EPA, in conjunction
with an outside consultant,  applied the Dynamic Stream Simulation and Assessment
Model, Version HE (DSSAM HI) to assess the potential water quality changes resulting
from an upgrade to the TMWRF to advanced wastewater treatment. DSSAM HI is based
on three previously  utilized stream models:  the Stream Simulation and Assessment
Model, Version IV (SSAM IV); the Lotic Periphytoin Simulation Model (LPSM); and
the U.S. Geological Survey's Truckee River Water Quality Model.

       DSSAM HE is designed  to determine water quality  in the. Truckee River under
certain flow and nutrient loading conditions.  The model is intended to address ecological
process that are specific to the Truckee River.  Pollutant sources addressed included point
and nonpoint sources. The major point source is the TMWRF; others include industrial
non-contact cooling water, an aquaculture operation, water treatment plants, .stormwater
outfalls, and groundwater discharges. Primary nonpoint sources include agricultural and
urban runoff. Initial modeling efforts were used to set waste load allocations (WLA) and
load allocations (LA) for total nitrogen.

       In 1988,  NDEP used DSSAM m to monitor the  river during installation of
tertiary treatment processes at TMWRF- In the following year, when the facility upgrade
was  fully  functional,  researchers   obtained the  clearest  insight into nitrogen  and
phosphorus  loading processes in the river.  NDEP used this September 1989 data to
calibrate DSSAM HI. In 1990, findings demonstrated .that pollutant levels were still not
adequate to allow many of the  river's designated beneficial uses.  As  a result, NDEP
began a new modeling effort to develop more stringent standards to meet state waterbody
classifications.  The Bureau of Reclamation is currently using the model to conduct an
environmental impact statement (EIS) of the Truckee River watershed basin  and has
provided some additional funding for improvements to the model.

       Presently, TMWRF is approaching its limit for the  discharge of total nitrogen.
Continued population growth in  the Cities of Reno and Sparks is chiefly responsible for
this situation.  If population trends continue as expected, the TMWRF could  exceed its
WLA for total nitrogen in coming  years.  As a result, TMWRF is currently exploring
alternative means to  attain discharge limits,  including flow augmentation through the
purchase of water rights from agricultural interests.  If this occurs, the model will be
rerun using new flow conditions.      ,                       .

       The  cost for  consultants  to customize a prior model of the  Truckee River is
$53,094 in 1995 dollars, approximately $24,000 of which was contributed by NDEP from
1990 to 1993.  The prior modeling  effort was conducted over an eight-year period, and
served as a basis for the TMDL  model customization.   This modeling effort cost
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approximately $55,684 in 1995 dollars. Additional costs associated with the time NDEP
staff dedicated to early modeling activities are not available.  The costs of modeling
efforts to date have been shared among  federal grants, state  general revenues, and
monetary contributions from both the county and city  governments.   Additionally,
Washoe County provided technical guidance and review.n
Analysis Costs for the Trwckee River TM&L
•."'•" S ? f "• , ' "
Tn-honseTTEs " Costs Funding Source(s)
0.17
$7>57<5 S&te
       NDEP's  analysis  activities  in conjunction  with  TMDL  creation  included
development of WLAs and LAs for total dissolved solids and total phosphorus. Although
the  Truckee  currently meets water  quality  standards  for  total dissolved  solids,
conservative "simple mass balance" calculations (i.e., assessments qf existing loads) were
developed for total dissolved solids in accordance with EPA's TMDL  guidance, which
recommends  taking  a proactive pollution prevention  approach  to  water quality
management (EPA, 1991).

       Water  quality standards for  phosphorus  are  not currently being  met on the
Truckee River. Since phosphorus behaves in a manner similar to dissolved solids, NDEP
used similar "simple" calculations to arrive at a reasonable TMDL for phosphorus.

       NDEP dedicated two staff over a  two-month period to perform analysis  and
develop appropriate TMDLs. .The staff time translates into a cost of $7,576.
In-house FTEs
0.19
Outreach Costs far 1ke,Tntckee River
Cost
$10,707
TM&L ' ' ' '\
Funding Source(s)
State
       The Truckee  River TMDL  is  politically sensitive  because of controversies
involving water rights in the West.   Since the activation of Derby Dam in 1915, the
majority of river flow has been withdrawn for agricultural purposes. During times of
rising population and increased nutrient loading, this has placed an ecological strain on
the river.  In particular, low. dissolved oxygen (DO) levels  have impaired the river's
ability to support Lahontan cutthroat trout, a threatened species that supports a local
recreational fishery, and cui-ui, a national endangered species that has historically been a
staple in the diet of the local Pyramid Lake Paiute Tribe.
11 The $50,000 model customization effort occurred in 1993.  Converting to 1995 dollars using a price
index for government purchases yields a cost of $53,094. The applicable portion (approximately 10%) of
the modeling costs from prior efforts consists of $45,000 evenly distributed over the years 1985 to 1992.
When converted to 1995 dollars, the $45,000 becomes $55,684.
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       In addition, other jurisdictional issues involving water rights, inter-basin water
transfers, and preservation of wetlands have brought involvement of federal, state, and
local government agencies.  Government stakeholders include:  the Pyramid Lake Paiute
Tribe; Washoe County; the City of Reno; the City of Sparks; NDEP; the EPA; the U.S.
Geological Survey; and the U.S. Army Corps of Engineers. To coordinate multi-agency
interests, NDEP organized  a Truckee River Strategy that included development of a
framework for  progress  evaluation, establishment  of water quality standards for the
Truckee River, and preservation of the water quality within Pyramid Lake.   TMDL
development was discussed at Truckee River Strategy meetings and other meetings. ..

       NDEP dedicated 400 hours of staff time  to these efforts over  a period of five
years.  Converting this  staff time to cost  and adjusting for inflation  yields a cost of
$10,707. The time dedicated by other, organizations is not represented in this cost.
              Public Participation Casts for the Tmekee River TMDL
           Q.Q2
31,009
Funding: Sourcefe)
     State
       As  a result of the politically sensitive nature of various aspects  of TMDL
development, extensive public participation activities were undertaken in addition to .the
Truckee River Strategy meetings discussed above, including placement of pubh'c notices
and  a presentation of the TMDL  at a public  hearing  of the State  Environmental
Commission. NDEP dedicated 40 hours of staff time to these efforts. This translates into
a cost of $1,009 in 1995 dollars
Administration
In-house FTE&
0.08 , ,
Costs for the
'.Cost
S4U7
Truckee River 23
FandmgSoiurcefe)
" State
       Administrative  costs  associated  with TMDL  development  included grant
administration and staff coordination activities, as well as development of a rationale
document to support and defend the TMDL.  NDEP dedicated one month of one staff
person's time to these efforts.
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For more information contact:

Adele Basham
Nevada Division of Environmental Protection
Capitol Complex
333 West Nye Lane
Carson City, Nevada 89710
Phone (702) 687-4670 ext. 3102
Fax (702) 687-4670
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                    YANKEE HILL LAKE, NEBRASKA
 Key Features
Titles
Location:
Size/Scope:
Comparative Size:
PoU«taitt(s)t
Sources of Pollutants:

Model Use and Complexity:


TotaiCosi  ,
 ,'
Funding Sources?
  Yankee Hil Lake,
  Souifeas&m. Nebraska; USEPA Region VIL
  9,4 square mile watershed           ,            „
  Small <100 mi2,
  '''>'>,         ,  -,
  Suspended, soBds, phosphorus, and nitrogen.
  Paint sources—none,
  Honpoint sources—agnculturanands and aural residential areas. -
            *   ••       ,    ,    ,        f	   f
  AGNPSis &e Bonpoiot source loading model andBUTTiQMOD is
.' the receivingwaier quality modet Ihese models are relatively
'  simple,
  $4,5^8 to dates plus $5S402 to cover ongoing monitoring and
 ', analysis efforts.
  EPiA nonpoint source IMDL Mini-Grant.
 Summary

       The Nebraska Department of Environmental Quality (NDEQ) is in the process of
 completing a TMDL for total suspended solids in Yankee Hill Lake.  NDEQ received a
 mini-grant from EPA to develop a TMDL for the lake, which had been demonstrating
 high levels of pollutants from agricultural practices in the area.

       Yankee Hill Lake is a small  lake  in  a 9.4 square mile  watershed and is
"approximately  seven miles from Lincoln.  The Army Corps of Engineers  originally
 constructed the lake  as  a flood control project.  Land  use in the Yankee Hill Lake
 watershed is primarily  agricultural, with  some  rural residential areas.  The lake is
 protected for full-body contact recreation, agricultural water supply, and warm water
 aquatic life uses.

       As illustrated in Table 14, NDEQ's total in-house effort on the Yankee Hill Lake
 TMDL to date is 0.18 FTE, for a total cost of $4,598. NDEQ expects to expend a total of
 $10,000.   NDEQ has received substantial assistance from  both the Army Corps of
 Engineers and the Natural Resource Conservation Service in the form of access to data, as
 well as" a nonpoint source mini-grant from  EPA in  1992 in the amount of $10,000.
 NDEQ will not exceed this amount in developing the TMDL, due to the relatively simple
 nature of the tasks involved.
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Table 14. Summary of TMDL Costs for Yankee Hill Lake
Activity
Monitoring/Data Collection
Modeling
Analysis
Administration
TOTAL
NDEQFTEs
0.10
0.02
0.03
0.03
0.18
Cost ($)
2,229
465
952
952
4,598
Cost as % of Total
48.4
10.1
20.7
20.7
99.9*
*Cost as a percent of total does not add to exactly 100 as a result of rounding.
Cost Analysis

       NDEQ staff believe that the Yankee, Hill TMDL is fairly straightforward and that
modest costs will yield successful results.  NDEQ further believes that it can accomplish
all its objectives with the $ 10,000 mini-grant.

       NDEQ achieved substantial cost savings by obtaining data from federal agencies
that were already actively monitoring the lake.  In addition, NDEQ may be able to realize
future cost savings, as some of the activities necessary to develop the TMDL can generate
information that is useful for other water quality programs.

       According to NDEQ staff,  the expenditures on the TMDL to date are producing
several positive impacts for the  lake, including probable attainment of all water quality
standards, extension of the life of the lake,  and development of measures to  lessen
sediment loads..
Cost Breakdown

       For the purpose of consistency among case studies, the TMDL  development
process is divided into the following six cost categories:
       Monitoring/Data Collection;
       Modeling;
       Analysis;
       Outreach;
       Public Participation; and
       Administration.

NDEQ has not conducted any outreach or public participation activities for the Yankee
Hill Lake TMDL. Thus, only the other four cost categories are presented below.       ;
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Monitoring/Data
- In-house FTEs
- 0,10 , ^
Collection for the Yankee BUI Lake TMDL
Cost , ^ Funding Source(s)
$2,229 , EPA Mini-Grant
       Costs associated with monitoring/data collection to this point consist of staff time
to:   (1), compile, data that the Army Corps of Engineers and  the Natural Resource
Conservation Service had collected; (2) conduct additional in-house monitoring efforts to"
collect necessary data; and (3) conduct follow-up, evaluative monitoring.  NDEQ was
able to obtain ten years of data from federal agencies. NDEQ's own monitoring of the
lake began in 1994, and is currently ongoing on a monthly basis.

       NDEQ's cost,for monitoring and data collection to date is based on one analyst
working for 80 hours, one  senior analyst working for 60 hours, and one intern working
for 60 hours.
                    Modeling for the Yankee Hill Lake TMDL
       In-house FTEs                    .Cost         -        s  Ponding Sourcefe)
           0>02                        $465      ' - -   -    -    BI^A. Mini-Grant
       NDEQ used a  relatively simple, two-stage modeling process.  The agency
employed the AGNPS model to evaluate event based nonpoint pollutant loadings and the
EUTROMOD.model to estimate annual loadings.  The cost of running these models
reflects 40 hours of work by one analyst.
' InAotiseFTEs
0.03
Analysis for the
Yankee mil Lake TMDL
Cost
" $952
Funding Source(s)
EPAMM-Grant
       NDEQ's analysis activities for the Yankee Hill Lake TMDL involved interpreting
model results and prescribing BMPs for the watershed. The cost for these efforts is based
on one senior analyst working for 60 hours (20 of which have not yet been logged as of
June 22nd, 1995). .                                      ,
Administration for
in-hottseFTEs
0,05
the Yankee HiU Lake
Cost
$952:
TMDL
. Funding Soorcefs)
EPA Mini-Grant '
       NDEQ's administration of TMDL activities to this point has involved one NDEQ
senior analyst spending a total of 60 hours, to write reports and conduct manager related
tasks.
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I
                 For more information contact:

                 Greg Michl
                 Nebraska Department of Environmental Quality
                 Surface Water Section - Water Quality Division
                 Suite 400, The Atrium
                 1200 North Street
                 P.O. Box 98922
                 Lincoln, Nebraska 68509-8922
                 Phone (402) 471-4700
                 Fax (402) 471-2909
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                                  APPENDIX A
                       Interview/Data Collectioii Guide for
                                TMDL Cost Study

       For U.S..EPA's Office of Water, Apogee Research Inc.,  is preparing a report that (1)
illustrates TMDL costs and (2) outlines methods for determining costs.  Through case examples
Apogee plans to explicate administrative, data collection, and other costs associated with TMDL
development. The case examples include a variety of large and small-scale projects, simple and
complex analyses,  and cover  a variety  of different geographic  regions.   Drawing from the
existing TMDL case studies,  a listing  of TMDL/nonpoint  source mini-grant  projects,, and
conversations with regional TMDL coordinators, the {Insert TMDL} has been selected for
inclusion in this study.

      . To date Apogee has been collecting demographic and other background information on
the selected TMDLs.  Now we are requesting a phone interview with you and other staff
involved  in TMDL development, to (1)  fill  in any, remaining "gaps" in the background
information and (2) obtain more in-depth programmatic and cost information.  We would be
pleased to walk through the following questions with you and provide any additional information
or explanations you might desire, or, feel free to respond to the questions in the spaces provided
and fax your answers to Dennis Alvord at Apogee Research, (301) 654-9355.

GENERAL BACKGROUND

       The following questions address demographic  and  other general background questions
relating to many TMDLs.  Responses to these questions will provide the comparative foundation
for the cost study.   •

1.1)  What level/type of public involvement did the TMDL development process entail (i.e.,
public hearings, volunteer activities, etc.)?
1.2)  Was monitoring conducted as part of the TMDL process?  What type and for how
long? Who conducted the monitoring? Was monitoring conducted prior to the TMDL or
special for the TMDL? Will there be follow up monitoring?

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1.3)  What model was utilized?  Describe the modeling process undertaken?  Could you
have utilized a different model? Why/why not?
1.4)  How many staff worked on the TMDL?  How many hours per week do staff typically
work?
1.5) Did consultants work on the TMDL?  What was their role?
1.6) Did any other agencies work on the TMDL? What was their role?
TMDL DEVELOPMENT ACTIVITIES

      For the purposes  of this study we have broken TMDL development into the following
seven categories:

      •  Modeling;
      •  Data Collection;              •
      •  Outreach;
      •  Public Participation;
      •  Analysis;
     , •  Administration;
      •  Monitoring; and
      •  Miscellaneous.

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Please feel free to revise the activity categories to match your TMDL process.
       From these categories, we hope to generate an estimate of the level of effort necessary to
fully  implement  the TMDL.   For each  activity,  a table  is provided  indicating required
information. For each category please provide estimates of
       1)  The number of staff who worked on the activity?
       2)  The amount of time (in hours, days, weeks, or months, whichever is most appropriate)
          they spent on it?
       3)  The average annual salary of the employee(s) working on the particular activity?
       4)  Any other expenses related to the activity (i.e., equipment, training, etc.)?
Additional space  has been provided under each activity for your comments.  An example is
provided below.

       EXAMPLE
ACTIVITY
Example
Number of
Staff
Fred
Mary
Total Time
2 weeks
1 month
Average
Annual Salary
$35,000
Other (specify)
0
Comments:
2.1)    MODELING
ACTIVITY
Modeling
Number of
Staff

Total Time

Average
Annual Salary

Other (specify)

Comments:

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2.2)   DATA COLLECTION
ACTIVITY
Data
Collection
Number of
Staff
->,'
Total Time

Average
Annual Salary
•, • -
Other (specify)

Comments:
2.3)   OUTREACH
ACTIVITY
Outreach
Number of
Staff

Total Time

Average
Annual Salary

Other (specify)

Comments:
2.4)  PUBLIC PARTICIPATION
ACTIVITY
Public
Participation
Number of
Staff

Total Time

Average
Annual Salary

Other (specify)
j

Comments:

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2.5)  ANALYSIS
ACTIVITY
Analysis
Number of
Staff

Total Time

Average
Annual Salary

Other (specify)

Comments:
2.6)  ADMINISTRATION
ACTIVITY
Administration
Number of
. Staff

Total Time

Average
Annual Salary

Other (specify)

Comments:
2.7)  MONITORING
ACTIVITY
Monitoring
Number of
Staff

Total Time

Average
Annual Salary

Other (specify)

Comments:

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2.8)   MISCELLANEOUS
ACTIVITY
Other
Number of
Staff

TotalTime

Average
Annual Salary

Other (specify)

Comments:
GENERAL WATER QUALITY MANAGEMENT ACTIVITIES

     • The following questions address issues related to your programs overall work on TMDLs
relative to'other water quality management activities;

2.9) How many ETEs currently work on activities related to this TMDL?
2.10)  What other water quality management activities are undertaken by your agency? If
possible, please  provide an  estimate of the costs associated with undertaking these
activities.
2.11)  What percentage of your total water quality program is composed of TMDL related
activities as opposed to other water quality management initiatives?
HISTORICAL AND PROJECTED REVENUE DATA

3.1) Please identify sources of funding for the year or years the TMDL was conducted (i.e.,
federal grants, state general revenues, local, private).  If possible, please provide dollar
amounts for those funding sources. An example is depicted in the shaded rows in TABLE
3.1. Space for your comments and/or explanations has been provided below the table.

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3.1
Historical Revenue Data .
Funding Sources
(Please List)
Example:
Section 31 9 Grant
Example:
State General Revenues







Fiscal
Year
1989
so
$3,000-







Fiscal
Year
1990
; so ,
: $5,00&







Fiscal
Year
1991
SUpdfh
38,000 ,
' *







Fiscal
Year
1992
$15,000
$9,500







Fiscal
Year
1993
SOr
$7,350







Fiscal
Year
1994
$0
$6,900







Fiscal
Year
1995
$0
$3*750







Comments:
3,2) If the TMDL is ongoing, what plans are there for future funding?
BENEFITS
4.1) Please explain what direct and indirect benefits have been realized through the TMDL
process (i.e., water quality improvements, scenic improvements, etc.)?

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